DS9 Document EFTA01076251

1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA vs. JEFFREY EPSTEIN, CASE NO. 50-2008-CA-028051 XXXX MB AB Plaintiff, Defendant. / VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN TAKEN ON BEHALF OF THE PLAINTIFF DATE: February 17, 2010 U.S. Legal Support EFTA01076251 1 February 17, 2010 2 INDEX 3 WITNESS DIRECTCROSS REDIRECT RECROSS 4 JEFFREY EPSTEIN 5 BY MR. EDWARDS 4 6 EXHIBITS 7 FOR IDENTIFICA PAGE 8 I Jane Doe numb usJeffrey Epstein complain 35 9 2 Document, Nonprosecution Agreement 135 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CER1 iFILO QUESTIONS Page Line 61 22 123 20 146 l4 148 153 5 159 13 162 3 3 1 The videotaped deposition of JEFFREY 2 EPSTEIN in the above-entitled and numbered cause, 3 was taken before me, TERRI BECKER, a Registered 4 Professional Reporter and Notary Public for the 5 State of Florida at Liege, at 444 West Railroad 6 Avenue, in the City of West Palm Beach, Palm 7 Beach County, in the State of Florida, beginning 8 at the hour of 5 eiclock a.m, pursuant to 9 the Notice in said cause for the taking of said 10 deposition which is annexed to the court file 11 herein, on behalf of the PLAINTIFF in the 12 above-entitled action pending in the above-named 13 court 14 The appearances at said time and place 15 were as follows: 16 FARMER, JAFFE, WEISSING, EDWARDS, F1STOS & LEHRMAN, P.L. 17 Attorneys for Plaintiff 425 North Andrews Avenue, Suite 2 18 Tel: 19 Fort 33301 BY: BRAD . WARDS STEVEN R. JAFFE, ESQ. BURMAN, CRITTON, LUTTIER & COLEMAN 21 Attorneys for Defendant 303 Banyan Boulevard, Suite 400 22 Wes orida 33401 Tel: 23 BY: MICHAEL PIKE, ESQ. 24 ALSO PRESENT: JOE ROVNER, Videographer 25 (U.S Legal Support) 20 1 THEREUPON, 2 JEFFREY EPSTEIN 3 being by Toni Becker first duly sworn to tell 4 the whole truth, as hereinafter certified. testified as follows: 6 DIRECT EXAMINATION 7 BY MR. EDWARDS: 8 Q Can you give us your name. 9 A Jeffrey Epstein. 10 Q Mr. Epstein, you made a comment when you 11 came in the room that you were appreciative of me 12 being respectful to your housekeeper yesterday 13 and I intend for that to be the same with you 14 today. 15 1 want to start by asking you, at this 16 point we've gone through a lot of discovery in 17 this ease. There aren't may disputed facts as 18 to what actually happened at your house. 19 Generally I think you would agree that you 20 derived a way for young females to come to your 21 house and engage In varying degrees of sexual 22 activity, some of the girls as young as 12, some 23 of them as old as seventeen or so, most in 24 between, but as of yet you haven't provided an 25 explanation. 1 1 want to provide you an opportunity to 2 tell the jury at this time why you did ft. 3 MR. PIKE: I'm going to object 4 Confusing, compound and irrelevant, as worded. 6 A You know, I would like to answer that 7 question, frankly. However, at this time, my 8 attorneys have told me that I can't and 1 must 9 invoke my Fifth, Sixth and Fourteenth Amendment 10 rights or I risk losing their counsel. 11 Accordingly, I therefore assert those rights. 12 Sorry. 13 MR. PIKE: In addition to that I'll move 14 to strike counsel's statement as a 15 narrative, as well. 16 MR. EDWARDS: I understand. I wanted to provide him an opportunity, if today was 18 going to be the day. 19 MR. PIKE: Same thing, move to strike. 20 Q Mr. Epstein, how long have you been 21 sexually attractive to underage minor females? 22 MR. PIKE: Objection, harassing, 23 argumentative. 24 A Are you kidding? 25 Q No, l mean, I don't feel Eke I'm 17 2 (Pages 2 to U.S. Legal Support EFTA01076252 8 1 divulging any secrets here, right? 2 MR. PIKE: Move to strike. 3 Q That's the question that's pending. 4 A I would like to answer that question as 5 well, as all your other questions today, however, 6 I have to follow my attorneys' advice. They have 7 told me I must invoke my Fifth, Sixth and 8 Fourteenth Amendment right to not answer those 9 questions today, or any questions relevant to 10 this lawsuit, so accordingly, I'm going to assert 11 those rights and under the constitution 12 guaranteed by the Fifth and Sixth, and Fourteenth 13 amendment. 14 Q Would you consider yourself addicted to 15 sex with minor females? 16 MR. PIKE: Same objections. 17 A You know, Mr. Edwards, again, I want to 18 be very respectful. As the current U.S. Attorney 19 has described your law firm as a criminal 20 enterprise and part of one of the largest frauds 21 in Florida's history, it has been reported that 22 your firm has fabricated multiple cases against 23 me in order to fleece unsuspecting investors out 24 of millions and millions of dollars, so 25 unfortunately at this time, although I would Ida 7 1 to answer that question, on advice of counsel I 2 will have to refrain and assert my Fifth, Sixth 3 and Fourteenth Amendment right. 4 Q Can you then provide an explanation for 5 what relevance that soliloquy of yours has to, 6 whether or not you engaged in sex acts with- 7 When she was a minor? 8 MR PIKE: Objection, no, he cannot 9 Argumentative. Compound, harassing. 10 MR. EDWARDS: Mr. Pike, with all due 11 respect, it was not my idea for him to give 12 this speech about a former ARA law firm I 13 was asking to elaborate on that. 14 MR. PIKE: Counsel, I'm working with 15 your follow-up question. 16 MR. EDWARDS: I understand. 17 MR. PIKE: I'm objecting, object to the 18 form and stating the reasons on the record 19 why the form is required to be objected to, 20 based upon your question. 21 MR. EDWARDS: Will he elaborate on the 22 relevance of that soliloquy to his touching 23 -when she was 13, 14 and 15 years old in 24 a sexual manna? 25 MR. PIKE: I'm going to object again, 1 argumentative, compound, harassing and 2 irrelevant. 3 Q You can answer. 4 A I would like to answer, however, I'm 5 going to have to assert my Fifth Amendment, Sixth 6 Amendment, Fourteenth Amendment right as advised 7 by my counsel, otherwise I risk losing their 8 advice. 9 Q Mr. Epstein, have you ever been 10 diagnosed with a sex addiction to minors by a 11 psychologist or other medical professional? 12 A I intend to respond to all of your 13 questions at some relevant time; however, today 14 at the present time, my attorneys have counseled 15 me that I cannot provide answers to any questions 16 relevant to this lawsuit and I must accept their 17 advice or risk losing my Sixth Amendment rights 18 to effective representation. 19 Accordingly, I assert my Fifth, 20 Federal — Fifth and Sixth and Fourteenth 21 Amendment rights, to the United States 22 Constitution. 23 MR. PIKE: In addition to that, Mr. 24 Edwards, as the Court has ruled on several 25 matters, Mr. Epstein's medical history is 9 1 not relevant at this time nor has he placed 2 same at issue in this case. 3 MR. EDWARDS: Understood. 4 Q Mr. Epstein, were you sexually abused as 5 a minor? 6 A Again? 7 Q Were you sexually abused, as a minor? 8 A You know, again, I would like to respond 9 to all -- if any questions seem to be relevant. 10 I would like to respond to any relevant question 11 at this time; however, my attorneys have 12 counseled me that I cannot provide answers to the 13 questions relevant to this lawsuit today. I must 14 accept their advice or risk losing my Sixth 15 Amendment right to effective representation. 16 Accordingly then, I assert my Fifth, Sixth and 17 Fourteenth Amendment right to the United States 18 Constitution. 19 Q Isn't it true that you have engaged in 20 some sexual interaction with hundreds of underage 21 minor females In die last ten years of your 22 life? Is that true? 23 MR. PIKE: Objection, relevance. 24 A Mr. Edwards, the current U.S. Attorney 25 has described your law firm as a criminal 3 (Pages 6 to 9) U.S. Legal Support EFTA01076253 10 12 1 enterprise and pan of the largest fraud in 2 Florida's history. It has been reported that 3 your firm fabricated multiple cases, many, many 4 multiple cases against me in order to fleece 5 unsuspecting investors out of millions and 6 millions of dollars. Unfortunately, at this time 7 in response to your question, my attorneys have 8 advised me that I must assert my Sixth Amendment, 9 Fifth Amendment, Fourteenth Amendment right. 10 Though, I believe, you know, that I would really 11 like to answer your questions today, but at this 12 moment i must assert those rights or risk having 13 my attorneys resign. 14 Q You're Invoking your Fifth Amendment 15 rights to each of these questions because you 16 know your answers will incriminate you and you 17 feel it will result in you being prosecuted for 18 your crimes; Isn't that right? 19 MR. PIKE: Objection, argumentative, 20 harassing. Calls fora legal conclusion. 21 Q You can answer. 22 A No, in fact, the Supreme Court recently 23 said the Fifth Amendment right is there to 24 protect the innocent, so, that's the way I would 25 like to answer that. 11 1 Q Are you actually telling the Jury that 2 you didn't commit the crimes that have been 3 alleged against you by the various females that 4 were under age when you engaged in sex with 5 them? Are you telling the jury that right now? 6 MR. PIKE: Objection, argumentative, 7 harassing. 8 A I would like to respond to that 9 question, as you know, however, at the present 10 time my attorneys have counseled me that I cannot 11 provide answers to any questions relevant to this 12 lawsuit and i must accept their advice or risk 13 losing my Sixth Amendment right to effective 14 representation. Accordingly, I assert my Fifth, 15 Sixth and Fourteenth Amendment right under the 16 United States Constitution. 17 Q Mr. Epstein, you understand that this is 19 aeo that will be playe ie Jury in 19 trial against you 1m wants answers. 20 The jury is going to want answers, so I know that 21 you're telling us that you're going to respond at 22 some time In the future; but the time is now. 23 Would you like this opportunity to explain why 24 you engaged In sexual activity with.. 25 beginning when she was 13 years old and you were 1 50 years old? 2 MR. PIKE: I'm going to object once 3 again. We are getting way too argumentative 4 with the questioning. The questioning is 5 compound It is speculative and it is also 6 harassing. Whether or not this deposition 7 video, thereof is played in front of a jury 8 is a question of fact, and it will be 9 determined by a judge pursuant to a motion 10 in limine, various portions thereof may or 11 may not be played, so hiving placed those 12 objections on the record I'm going to 13 insttuct Mr. Epstein not to answer that 14 question. 15 MR. EDWARDS: Mr. Pftce, I don't know if 16 you watehegainia hours of harassing 17 questions tri=that she sometimes 18 invoked her Fifth Amendment rights, I 19 understand the adverse advice that would be 20 given and she was made to answer these 21 questions and these exact same questions 22 were asked of her, in fact, I'm using the 23 phraseology from Mr. Luttier. I'm not 24 trying to harass him. 25 Q I'm simply asking him to explain to the 13 1 jury. If you're saying it didn't happen, if 2 you're saying it did happen, explain to the jury 3 why you did it. That's all I want to hear. I'm 4 being respectful about this. 5 MR. PIKE: In an effort to keep a clean 6 record be respectful to the to the court 7 reporter rather than having a diatribe back 8 and forth between you and myself, I'll move 9 to strike your last statement as 10 irrelevant. Let's move on. 11 Q Is it true, Mr. Epstein, you were born 12 January 20,1953? 13 A Yes. 14 Q Where? 15 A New York. 16 Q Where in New York? 17 A Brooklyn. 18 Q Did you go to high school there? 19 A Yes, sir. 20 Q Where? 21 A Lafayette High School. 22 Q After high school did you attend 23 college? 24 A Yes. 25 Q Where was that? 4 (Pages 10 to 13) U.S. Legal Support EFTA01076254 14 16 1 A New York. 2 Q What college did you attend? 3 A Cooper Union. 4 Q Sorry, i didn't hear. 5 A Cooper Union. 6 Q Did you get a degree from Cooper Union? 7 A No, sir. 8 Q How many years were you in college? 9 A I believe, two. 10 Q What did you study? 11 A Physics. 12 Q Why did you leave college early? 13 A I intend to respond to all relevant 14 questions regarding this lawsuit, however, at the 15 present time my attorneys have counseled me that 16 I cannot provide answers to questions that may be 17 relevant to this lawsuit, so accordingly I assert 18 my constitutional rights as guaranteed by the 19 Fifth, Sixth and Fourteenth Amendment. 20 Q Are you invoking your Fifth Amendment 21 rights as to why you left college, Is it safe 22 then to presume that that answer you believe 23 would incriminate you in some way? 24 MR. PIKE: I'm going to move to strike, 25 speculative, argumentative, harassing. 15 Calls for a legal conclusion, and 1 know 2 exactly what you're trying to do here, Mr. 3 Edwards, is lace the record with questions 4 that would ultimately give you an adverse 5 inference at any potential trial of this 6 matter, so having put that on the record, 7 I'm going to instruct him not to answer that 8 question, based upon his Fifth, Sixth and 9 Fourteenth Amendment rights to the United 10 States Constitution. 13. MR. EDWARDS: With all due respect you 12 cannot invoke his Fifth Amendment rights, 13 your attorneys instructed me in that fact -- 14 MR. PIKE: lie can. 15 MR. EDWARDS: 11M. Had to do it 16 herself, so, I would like to hear it from 17 Mr. Epstein. 18 Q Can we assume you're Invoking your Fifth 19 Amendment rights as to why you left college 20 early, that that answer you feel would 21 incriminate you? 22 MR. PIKE: Once again, move to strike 23 for the same reasons. 24 You can answer. 25 A I've already answered the question. 1 I'll restate the answer. I would like to 2 respond, intend to respond, and would like to 3 respond to all questions today. However, counsel 4 has advised me I must take the Fifth, Sixth and 5 Fourteenth Amendment right under the U.S. 6 Constitution. 7 Q After college where were you employed? 8 A You Imow, I would like to respond to all 9 your questions today, however, on advice of 10 counsel, I intend to take the Fifth, Sixth and 11 Fourteenth Amendment rights provided by the 12 United States Constitution or risk losing my 13 counsel's representation. 14 Q Isn't it true that you were a teacher at 15 the Dalton School in New York after college? 16 A Again, I would like to respond to all 17 your questions; however, my attorneys have 18 counseled me that i cannot provide answers to any 19 questions today regarding to this lawsuit so I 20 must accept their advice or risk losing my Sixth 21 Amendment right to effective representation. 22 Accordingly, I assert my Constitutional rights as 23 guaranteed by the Fifth, Sixth and Fourteenth 24 Amendment of the constitution. 25 Q Mr. Eistein, didrit have sex with any 17 1 underage students while teaching at the Dalton 2 School? 3 A Could you repeat that? 4 Q Yes. Did you have sex with any underage 5 students while teaching at the Dalton School in 6 New York? 7 A Mr. Edwards, your firm has been 8 described by the U.S. Attorney as one of the 9 largest — as a criminal enterprise, perpetrating 10 one of the largest frauds in Florida's history. 11 It has been reported that your firm fabricated 12 multiple cases against me and others in order to 13 fleece unsuspecting investors out of millions and 14 millions of dollars. 15 Unfortunately at this time in response 16 to your question, my attorneys have advised me I 17 must assert my Fifth Amendment, Sixth Amendment 18 and Fourteenth Amendment rights, though I believe 19 you know I would like -- really like to answer 20 your questions but at this time I must assert 21 those rights or have my attorneys resign. 22 MR. EDWARDS: Mr. Pike, I think you know 23 he has a couple of options here. He can 24 answer questions or he can invoke his Fifth 25 Amendment rights. This nonresponsive 5 (Pages 14 to 17) U.S. Legal Support EFTA01076255 18 20 1 verbiage regarding the RBA law firm is not 2 one of the options, it's inappropriate in 3 the deposition and I would ask you to 4 instruct your client not to obstruct this 5 process any further. I am not going to 6 terminate the deposition. I want it to 7 finish, but obviously this is going to be 8 the subject matter of some motion in the 9 °Duns and you know the judges will not 10 appreciate this. I would like to just move 11 this process along by eliminating that 12 portion of his answer. I understand what he 13 is saying. 'get it, but that's not 14 something responsive to any of the questions 15 and I think you know it is inappropriate. 16 MR. PIKE: I think the deponent is 17 answering the questions. If you believe the 18 responses are inappropriate and feel you can 19 take it up with the Court with the motion 20 you are speaking of, as you've done then you 21 can, as you've done several times before. 22 Q After leaving the Dalton School. is it 23 true that you began working as a money manager at 24 Bear Stearns? 25 A I intend to respond to all your 19 1 questions regarding this lawsuit at some relevant 2 time, however, at the present time my attorneys 3 have counseled me that I cannot provide answers 4 to any questions relevant to this lawsuit. Since 5 the U.S. Attorney has described your law firm as 6 a criminal enterprise, Mr. Edward; and a pan of 7 the largest fraud in Florida's history, I am 8 going to assert my Sixth Amendment, Fifth 9 Amendment and Fourteenth Amendment rights to the 10 U.S. Constitution. 11 Q Isn't It true that while you were 12 working at Bear Stearns you were already engaging 13 in sex with underage minors? 14 A Again, I believe you know the answers to 15 those questions, but -- 16 Q Yes. 17 A May I finish? 18 Q I do. 19 MR. PIKE: Move to strike. Let the 20 witness -- 21 Q Sure - 22 MR. PIKE: Let the witness answer your 23 question. 24 MR. EDWARDS: I would love for him to 25 finish the questions. 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 MR. PIKE Mr. Edwards, as you know there are serious Fifth, Sixth and Fourteenth Amendment constitutional rights at issue here, and the witness is attempting to answer your questions to the best of his ability, despite how laced they are with adverse inference presumptions. MR. EDWARDS: I don't want the adverse inferences. I want the answers, that's it. I don't want the adverse inferences. MR. PIKE: Having said that, please allow the witness to answer to answer the question. A Can you please repeat the question? Q Isn't it true while working at Bear Stearns you were already engaging in sex with underage minor females? A As your firm has been described by the U.S. Attorney, as a criminal enterprise, using some of the cases fabricated against me, personally, I would like to answer that question today; however, upon advice of counsel I must assert my Fifth, Sixth and Fourteenth Amendment rights under the U.S. Constitution or, in fact, risk losing their representation. 21 1 Q At some point in time while at Bear 2 Stearns you met and managed the money for a 3 fellow named Leslie Wexler, correct? 4 A Again, I would like to answer all 5 questions relevant to this lawsuit, but today I 6 must assert my Fifth Amendment, Sixth Amendment 7 and Fourteenth Amendment right to the U.S. 8 Constitution. 9 Q In fact, I read in another deposition of 10 yours that you do not consider yourself to be 11 homosexual, correct? 12 A (No response.) 13 Q You've answered that question before, 14 correct? 15 A Correct. 16 Q Do you consider yourself to be 17 bisexual? 18 A No. 19 Q In any event, you did develop a sexual 20 relationship with Leslie Wexler at some point In 21 time; Is that true? 22 A No. 23 Q Did you have a business relationship 24 with Mr. Wexler? 25 A I intend to respond to all relevant 6 (Pages 18 to 21) U.S. Legal Support EFTA01076256 22 24 1 questions. I would like to answer most of your 2 questions, Mr. Edwards, today, however, 3 especially since your firm has been described by 4 the United States Attorney in South Florida as a 5 criminal enterprise purported to -- purported to 6 have put — pulled off the largest fraud in 7 Florida's history, I would like to answer it, 8 however, my attorneys here today counseled me 1 9 must assert my Fifth, Sixth and Fourteenth 10 Amendment right under the U.S. Constitution, 11 therefore Pm going to do that. 12 Q Are you saying because Rothstein, 13 Rosenfeld, Adler was determined to be a criminal 14 enterprise or somebody was running a criminal 15 enterprise out of that law firm, that is the 16 reason why you are not going to answer these 17 questions today? You linked that together in 18 that answer. I just want to make sure I'm 19 understanding that right? 20 A I'm going to take the Fifth I intend 21 to respond to all relevant questions today. I 22 would like to respond; unfortunately my attorneys 23 have counseled me I can't, l must assert my 24 Fifth, Sixth and Fourteenth Amendment rights 25 under the U.S. Constitution. 1 Therefore l'Ilassert my Constitutional 2 rights under the Fifth, Sixth and Fourteenth 3 Amendment. 4 THE WITNESS: Excuse me, could we take a 5 break? 6 MR. EDWARDS: Already? 7 THE WITNESS: Restroom. 8 THE VIDEOGRAPHER: Going off the video 9 record 11:38 a.m. 10 THE WITNESS: Thank you. 11 (Pause in the proceedings.) 12 THE VIDEOGRAPHER: We're back on the 13 video record at 11:48 a.m. 14 Q How did you meet Chislalne Maxwell? 15 A I intend to respond to all relevant 16 questions to this lawsuit; however, at the 17 present time my attorneys have counseled me that 18 I cannot provide answers to any questions 19 relevant to this lawsuit, and must accept this 20 advice or risk losing effective -- my right to 21 effective representation. Accordingly, 22 therefore, I assert my Fifth, Sixth and 23 Fourteenth Amendment rights to the U.S. 24 Constitution. 25 Q You would agree, would you not, that 23 Q Because other law firms have asked very 2 similar questions and you haven't responded to 3 any of theirs either. I just want to understand 4 what the relationship between Rothstein, 5 Rosenfeld, Adler is to you invoking your Fifth 6 Amendment rights today, if you can articulate 7 that for me. 8 MR. PIKE: Form, compound, 9 argumentative. 10 A ROCIISICill, Rosenfeld, Adler has been 11 described by the U.S. Attorney as a criminal 12 enterprise and as part of the largest fraud in 13 Florida's history. It has been reported that 14 your faro fabricated multiple cases using me, and 15 against me in order to fleece unsuspecting 16 investors out of millions of dollars. 17 Q Another long time friend of yours is 18 Gliblaine Maxwell, right? 19 A I intend to respond to all relevant 20 questions. I would like to answer most of these 21 questions today, but I can't because my attorneys 22 have counseled me that I cannot provide answers 23 to any questions relevant to this lawsuit. I 24 must accept their advice or risk losing my Sixth 25 Amendment right to effective representation. 25 1 Ghislaine Maxwell shares your sexual obsession 2 for underage minor females? 3 MR. PIKE: Argumentative, speculation, 4 harassing. 5 A You know, Mr. Edwards, the current U.S. 6 Attorney has described your law firm as a 7 crininal enterprise, and as taking part in one of 8 the largest frauds in Florida's history. It has 9 been widely reported that your firm fabricated 10 multiple cases of a sexual nature against 11 people — other people and me, in order to fleece 12 unsuspecting investors out of millions of 13 dollars, so unfortunately at this time in 14 response to your questions, my attorneys have 15 advised mei must assert my Sixth Amendment, 16 Fifth Amendment and Fourteenth Amendment rights, 17 though 1 believe, as you know, I would really 18 like to answer these questions, but at this 19 moment, although at this time I have to assert 20 those rights or risk losing effective counsel. 21 Q Do you know 22 A I intend to respond to all relevant 23 questions regarding this lawsuit; however, at the 24 present time my counsel has advised me that I 25 cannot provide answers to any questions relevant 7 (Pages 22 to 25) U.S. Legal Support EFTA01076257 26 28 1 to this lawsuit. Your finn has been described as 2 a criminal enterprise, and is part of the largest 3 fraud in Florida's history fabricating sexual 4 cases against me and others. Therefore, 5 unfortunately, although I would like to answer 6 all of your questions today, I'm going to have to 7 assert my Fifth, Sixth and Fourteenth Amendment right. 9 Q Did you and Ghis sexually 10 assault at 'a house? 11 A i intend to respond to all relevant 12 questions regarding this lawsuit; however, at the 13 present time my attorneys have counseled me I 14 cannot provide answers to any questions relevant 15 to this lawsuit and must accept this right or 16 risk losing my Sixth Amendment rights to 17 effective presentation. Accordingly, I assert my 18 Constitutional rights as guaranteed by the Fifth, 19 Sixth and Fourteenth amendments to the U.S. 20 Constitution. 21 Q Stating Ghlslalne Maxwell and you had 22 devised several schemes to lure underage girls to 23 you for sex; isn't that correct? 24 MR. PIKE: Form, argumentative, 25 harassing? 1 present time my attorneys have counseled me that 2 I cannot provide answers to any questions 3 relevant to this lawsuit, no matter how much I 4 would like to. 5 Therefore, I must accept their advice or 6 risk losing my Sixth Amendment right to effective 7 representation; therefore, i have to assert my 8 Fifth, Sixth and Fourteenth Amendment right under 9 the U.S. Constitution. 10 Q Do you own a home in New Mexico? 11 A i intend to respond to all relevant 12 questions regarding this lawsuit and as I've had 13 to do with most of your questions here today, I'm 14 going to have to take my attorneys advice and 15 assert my Fifth, Sixth and Fourteenth Amendment 16 right under the U.S. Constitution or risk losing 17 effective representation. 18 Q Is it true that you have had underage 19 females, at each of those homes, for orgies with 20 you and Ghislaine Maxwell? 21 MR. PIKE: Form, argumentative, 22 speculation and harassing. 23 A I would like to answer that question. I 24 really would. However, as your firm has been 25 described by the U.S. Attorney as a criminal 27 1 A Mr. Edwards, your firm has fabricated 2 multiple cases of sexual harassment claims and 3 other types of sexual cases against me and others 4 in order to be pan of what the U.S. Attorney has described as the largest fraud, the largest fraud 6 in Florida's history. I would like to answer all 7 your questions; however, my attorneys have 8 counseled me that at least today, I must assert 9 my Fifth, Sixth and Fourteenth Amendment rights 10 under the U.S. Constitution. 11 Q Do you own a home in Manhattan? 12 A i intend to respond to all relevant 13 questions to this lawsuit; however, at the 14 present time my attorneys have counseled me that 15 I cannot provide answers to any questions 16 relevant to this lawsuit, and I must accept their 17 advice or risk losing my Sixth Amendment right to 18 effective representation. 19 Accordingly, therefore, I have to assert 20 my Fifth, Sixth and Fourteenth Amendment right 21 under the U.S. Constitution. 22 Q Do you own an island in the V.S. Virgin 23 Islands? 24 A !intend to respond to all relevant 25 questions regarding this lawsuit; however, at the 29 1 enterprise, which its principal purpose was 2 racketeering conspiracy to generate money for the 3 firm and its co-ccnspiritors through the 4 operation of enterprise and through various 5 activities including mail fraud, wire fraud and 6 money laundering, and fabricating multiple sex 7 cases against me and others, though I would like 8 to answer your question today, Mr. Edwards, my 9 courisel has advised me I must take the Fifth, 10 Sixth and Fourteenth Amendment right provided by 11 the U.S. Constitution. 12 Q Do you know somebody named 13 (phonetic)? 14 MR. PIKE: Can you spell that, for the 15 record? 16 MR. EDWARDS: No. 17 MR. PIKE: Or for the court reporter? 18 A No. 19 Q You don't know the name? 20 A No. Could you spell it? 21 Q (Witness shrugs.) 22 A Okay. 23 Q Did your sexual obsession with underage 24 minor females grow at some point in time to allow 25 you access to these underage minors every single 8 (Pages 26 to 29) U.S. Legal Support EFTA01076258 30 32 1 day for sex? 2 MR. PIKE: Overbroad. Speculation, 3 argumentative, compound, harassing and 4 confusing as well; as worded. Do you want 5 to break it down, Mr. Edwards? 6 Q Isn't It true that for the past ten 7 years you have found a way to engage in sexual 8 conduct with underage minors on an every day 9 bask? to MR. PIKE: Speculation. Argumentative. it A As your firm has been described as a 12 criminal enterprise by the United States Attorney 13 and is part of the scheme to defraud people in 14 South Florida of millions of dollars, you have 15 fabricated sexual cases and sexual claims against 16 people like me and others. Unfortunately at this 17 time although I would like to answer your 18 questions, Mr. Edwards, my counsel has advised me 19 I cannot They have advised me I must assert my 20 Fifth, Sixth and Fourteenth Amendment rights 21 under the U.S. Constitution. 22 Q isn't it true that you ►ave promised 23 underage minors money or other benefits to engage 24 in sexual conduct with you over the past ten 25 years? 31 1 A Again, as I've answered many of your 2 questions today, and unfortunately will probably 3 end up not answering most of your questions 4 today, as your firm has been described, the firm 5 bringing this lawsuit, I believe, if I'm wrong 6 please, correct me -- 7 Q You're wrong. 8 A This is the firm that didn't notice this 9 deposition? 10 Q Did not? 11 A Did not? 12 Q No. 13 A I apologize. Though your former firm 14 has been described, and the person you represent, 15 L.M., in this case was represented by the firm 16 that was described by the U.S. Attorney as 17 perpetrating one of the largest frauds in South 18 Florida's history, fabricating multiple sexual 19 cases against me and others in order to fleece 20 unsuspecting investors out of millions and 21. millions of dollars, so though unfortunately, I 22 would like to answer each one of your questions 23 today, my counsel has advised me I must assert my 24 Sixth Amendment, Fourteenth Amendment and Fifth 25 Amendment right, though I believe you know, I 1 2 3 4 5 6 7 a 9 10 11 12 13 10 15 A Can you spell it forme, please? 16 17 A What's the last name, how is it 18 spelled? 19 Q-Ibelieve. 20 A I intend to respond to all relevant 21 questions regarding this lawsuit; however, at the 22 present time my attorneys have counseled me that 23 I cannot provide answers to any questions that 24 may be relevant to this lawsuit and I must accept 25 this advice or risk losing my Sixth Amendment would like to answer those questions, though at this moment I must assert those rights or risk losing my attorneys. Q Sure, let's test that answer. A Okay. Let's talk about Jane DoMJane Doe who was represented bMI firm, had nothing to do with Rothstein, Rosenfeld, Adler. Do you know A Who? A Can you spelt it? Q Common spelling, 33 1 right to effective representation. Accordingly, 2 I assert my Constitutional rights as guaranteed 3 by the Fifth, Sixth and Fourteenth Amendment to 4 the Constitution. 5 Q Just for the record, I can only spell it 6 the way it was spelled in your flight logs from 7 your airplane. I don't know exactly how she 8 spells her name, only how your pilot would spell 9 her name. 10 MR. PIKE: Form, speculating. 11 Q If I misspell it — 12 MR. PIKE: Form, speculation, 13 argumentative, harassing. 14 MR. EDWARDS: That's harassing? 15 MR. PIKE: It assumes facts currently 16 not in evidence in this particular 17 deposition; therefore, I move to strike. 18 MR. EDWARDS: I was responding to his 19 question asking me how to spell her name. I 20 don't know how other than his own pilot. 21 MR. PIKE: Mr. Edwards, he asked you to 22 spell the name, you then spelled the name, 23 then went on with another narrative and 24 there wasn't a question posed, on the floor. 25 Q You would agree you Interacted with- 9 (Pages 30 to 33) U.S. Legal Support EFTA01076259 34 36 1 every day in a sexual way, when she was 15 years 2 old, right? 3 A Again, I'm softy? 4 Q Sure. You would agree that you 5 Interacted with. sexually on an every day 6 basis when she was 15 years old? 7 A You know, again, Mr. Edwards, I would 8 like to answer all your questions here today. My 9 attorneys have asked me — advised me that I must 10 assert my Sixth Amendment, Fourteenth Amendment 11 and Fifth Amendment rights provided by the U.S. 12 Constitution and the fact that the current U.S. 13 Attorney has described your law finn as a 14 criminal enterprise, is one of the largest frauds 15 in Florida's history for fabricating sexual -- 16 cases of a sexual nature against me and others. 17 Unfortunately, although I would like to answer 18 those questions, if I do I risk losing my 19 attorneys' counsel. Therefore, I must assert my 20 right. 21 MR. EDWARDS: Madam court reporter, Ill 22 as an exhibit, the Jane Doe number 23 crsus Jeffrey Epstein complaint, at 24 some point in time. It will be Exhibit 1, 25 as Pm going to go through some of the facts 35 1 as alleged in the complaint and as will be 2 testified to by the plaja. 3 (Jane Doe numberMversus Jeffrey 4 Epstein complaint was deemed marked as 5 Exhibit number 1 for identification, as of 6 this date.) 7 MR. PIKE: Counsel, do you have an extra copy of that for me? 9 MR. EDWARDS: No. 10 MR. PIKE: May I look at it real quick? 11 MR. EDWARDS: No. It has my notes on 12 it. 13 MR. PIKE: I understood, I saw the 14 highlights. 15 MR. EDWARDS: The notes are highlighted 16 so when we copy it, it will not show up. 17 MR. PIKE: Just for the record, that's a 18 current, operative pleading, correct? 19 MR. EDWARDS. Correct. 20 THE WITNESS: What does that mean? 21 MR. PIKE: There may have been some 22 amendments to a complaint and I want to make 23 sure that's the operative complaint at issue 24 that he is speaking of today. 25 THE WITNESS: Can I go off the record 1 for a second? 2 May I ask you a question? 3 MR. PIKE: Sure. Can we take a break 4 fora second? 5 MR. EDWARDS: Again? 6 THE WITNESS: Just a question. 7 MR. PIKE: He wants to speak with me for 8 a second. 9 THE VIDEOGRAPHER: Off the video record 10 12:01 p.m. 11 (Pause in the proceedings.) 12 THE VIDEOGRAPHER: We are back on the 13 video record at 12:02 p.m. 14 Q Is it true, Mr. Epstein, that you and 15 Ghislaine Maxwell forced■ to have sex with 16 you on a daily basis? 17 MR. PIKE: Form, argumentative, 18 harassing. 19 A Unfortunately at this time, though I 20 would really like to answer those questions, and 21 like I have dent for most of your questions here 22 today, Mr. Edwards, your firm was described as a 23 criminal enterprise, a serious criminal 24 enterprise by the current U.S. Attorney. Part of 25 that criminal enterprise was fabricating cases of 37 1 a sexual nature against me and others in order to 2 fleece unsuspecting investors out of millions of 3 dollars. Though, unfortunately at this time no 4 matter how I would like to respond to your 5 questions, I must assert my Sixth Amendment, 6 Fifth Amendment and Fourteenth Amendment rights 7 under the U.S. Constitution or risk having my 8 attorneys resign. 9 Q Isn't it true thaMwas yours and 10 Ghlslaine Maxwell's sex slave front the time she 11 was 15 through the time she escaped when she was 12 19? 13 MR. PIKE: Again objection, 14 argumentative, harassing. 15 A Mr. Edwards, your fimi has been 16 described as — excuse me, as a criminal 17 enterprise by the current U.S. Attorney and part 18 of the largest fraud in Florida's history. Part 19 of that fraud was fabricating multiple cases 20 against people like me and others, of a sexual 21 nature, in order to fleece unsuspecting investors 22 out of millions and millions of dollars, so 23 though I would like to answer that question, my 24 attorneys have told me today I must assert my 25 Sixth Amendment, Fourteenth Amendment and Fifth 10 (Pages 34 to 37) U.S. Legal Support EFTA01076260 38 40 1 Amendment right. 2 Q Isn't it true that you and Chisialne 3 Maxwell celebrated her 16th birthday with her and 4 had sex with her on that day? 5 MR. PIKE: Form. Compound, confusing, 6 argumentative, harassing. 7 A Mr. Edwards, I would like to answer that question. My attorneys have told me today, I 9 have to at least today assert my Fifth Amendment, 10 Sixth Amendment and Fourteenth Amendment rights 11 to the U.S. Constitution, especially my concern 12 is, that your firm has filed fraudulent lawsuits, 13 fabricated lawsuits, and the U.S. Attorney, the 14 current U.S. Attorney has described your firm as 15 a criminal enterprise that — whose main purpose 16 was to generate money for the finn and its 17 co-conspirators through the operation of various 18 criminal activities, including mail fraud, wire 19 fraud and money laundering. 20 m i tAre you saying that the complaint of 21 gainst you, the allegation in that 22 complaint, are fake? 23 MR. PIKE: Form. Misinterprets the 24 witness's testimony. 25 Q Or saying k Is true? 1 the complaint filed byalagainst you, isn't it 2 true, sir, that a friend of yours sent you three, 3 12-year old females for you to sexually abuse on 4 one of your birthdays? 5 MR. PIKE: Form, argumentative, 6 harassing, and irrelevant to this lawsuit. 7 THE WITNESS: Excuse me. A Vetere saying it is part of the 9 lawsuit? 10 Q Yes, I'll read It. 11 "On one of the defendant Epstein's 12 birthdays, a friend of defendant sent him 13 2-year old girls fro ho spoke no 14 t for defendant to sexually exploit and 15 abuse? After doing so they were sent back to 16 next day." 17 sn't that true? 18 MR. PIKE: Once again, move to strike, 19 irrelevant, argumentative, harassing, and 20 for the record, the exhibit that's being 21 read from is a complaint that's unrelated to 22 the instant matter and not filed or 23 incorporated by the current plaintil 24 in this matter. 25 A I would like to answer that question, I 39 1 MR. PIKE: Same objection. 2 Q It is either true or false? 3 A I'll repeat myself, unfortunately, but 4 the current U.S. A has described your law 5 firm that filed that fil m—wm 6 involved in the filing o laim, 7 motions — I'm softy, do you want to tell me what 8 it was then? Would you like to tell me the 9 firm's involvement in this lawsuit, since we will 10 be here the rest of the day? 11 Q Answer the question. 12 A All right. 13 The U.S. Attorney has described that 14 firm as a criminal enterprise perpetrating one of 15 the largest frauds in Florida's history against 16 unsuspecting investors, fleecing them out of 17 millions of dollars by creating, crafting and 18 fabricating fellacious (sic) sexual claims 19 against people like me and others, so 20 unfortunately, though I would like to answer your 21 questions, Mr. Edwards, my counsel has advised me 22 that at least today I must assert my Sixth 23 Amendment, Fifth Amendment and Fourteenth 24 Amendment rights under the U.S. Constitution. 25 Q Isn't It true, sir, and I'm reading from 41 1 really would; however, today my attorneys have 2 told me I have to assert my Fifth Amendment, 3 Sixth Amendment and Fourteenth Amendment rights 4 of the US. Constitution, especially because your 5 firm involved in this lawsuit has fabricated, 6 widely reported, multiple cases of sexual 7 harassment cases against individuals like me and 8 others, perpetrating what the U.S. Attorney 9 called one of the largest frauds in Florida's 10 history, fleecing people out of millions of 11 dollars, so though 1 would like to answer that 12 question, today I have to assert those rights or 13 risk losing my attorneys' counsel. 14 Q Isn't it true that you Contd.as a 15 15-year old girl to have sex with numerous 16 friends of yours? 17 A Are you kidding? 18 Q Reading front a lawsuit. 19 A Sorry. Mr. Edwards. Though I would like 20 to answer that question as well, as I've answered 21 most of your other questions here today, I would 22 like to respond; however, my attorneys here today 23 have advised me I have to assert my Fifth 24 Amendment, Sixth Amendment and Fourteenth 25 Amendment rights under the U.S. Constitution, 11 (Pages 38 to 41) U.S. Legal Support EFTA01076261 42 44 1 especially as your firm has been accused by the 2 U.S. Attorney as being a criminal enterprise, and 3 part of the largest fraud in Florida's history. 4 Basically -- sorry, if I didn't read correctly, 5 um.... the operation of the enterprise through 6 various criminal activities including mail (mud, 7 wire fraud and money laundering, fabricating 8 sexual harassment cases against people like me 9 and others. 10 Q By the way — 11 A Yes, sir? 12 Q - didn't M r trip 13 ticket paid for by you toad she 14 ultimately did not get back on the plane but 15 instead escaped t. 16 A I would like to answer that question, 17 but today I would have to assert my Sixth 18 Amendment fights, my Fifth Amendment tights and 19 my Fourteenth Amendment rights under the U.S. 20 Constitution, especially since your firm has been 21 described as perpetrating one of the largest 22 frauds in Florida's history, fleecing investors 23 out of millions of dollars, being described by 24 the U.S. Attorney of South Florida, as a criminal 25 enterprise engaged in various criminal activities 43 1 including mail fraud, wire fraud and money 7 laundering. 3 Q Do you know a man named Jean Luc 4 Brunel? 5 A Can you spell it? 6 Q He was at your house last week, does 7 that remind you? 8 MR. PIKE: Form, move to strike, 9 speculation, argumentative, harassing. 10 Is there a question on the table, Mr. 11 Edwards? 12 MR. EDWARDS: Yes. 13 Q Do you know him? 14 A Can you spell his name for me, please? 15 Q I don't need to spell his name. Do you 16 know who I'm talking about, Mr. Brunel? 17 A Sorry, Mr. what? 18 Q 19 A I would like to answer that question as 20 well, but my attorneys have counseled me today I 21 have to assert my Sixth Amendment rights, Fifth 22 Amendment rights and Fourteenth Amraultrent rights 23 under the U.S. Constitution or risk losing my 24 right to effective representation. 25 Q What's the purpose for you asking me to 1 spell his name? Are you acting like you don't 2 know him? 3 MR. PIKE: Form, move to strike, 4 argumentative and irrelevant as worded. 5 Mr. Edwards, you know that there are 6 various standing orders, if not in this 7 case, in various other cases, that 8 specifically describe the protections of the 9 Fifth Amendment. Federal Courts have 10 ordered that certain questions that you are 11 asking shall not be answered or Mr. Epstein 12 would risk losing his Fifth Amendment 13 right - le MR. EDWARDS: I understand that. He is 15 asking to spell people's names. 16 MR. PIKE: -- under the United States 17 Constitution. A lot of these questions here 18 today that you're asking have already been 19 ruled on by various Courts, that the Fifth 20 Amendment protects any response thereto, so 21 I would like -- Fm giving you some leeway 22 here with regard to the argumentative 23 questions. We've already -- and I'm not 24 obviously testifying for the witness, but 25 we've already handled a lot of these issues 45 1 in court and we have already adjourned one 2 deposition for being argumentative, and I 3 think you understand what the Court said 4 there, so having said that, and I understand 5 that you have ajob to do, but having said 6 that, I would like to caution you 7 professionally, if you continue with the 8 argumentative questions, I am going to have 9 to terminate this deposition — 10 MR. EDWARDS: I completely understand. 11 MR. PIKE: Okay. We are here today 12 13 MR.. EDWARDS: Mr. Brunel — 14 MR. PIKE: I want the Court to know we 15 are here today to allow you to ask your 16 questions, but the harassing and 17 argumentative tone is not going to be 18 tolerated. 19 MR. EDWARDS: We have a video. We can 20 show the Court the tone. It is obviously 21 not harassing. 22 MR. PIKE: That's fine. 23 Q Mr. Brunel is a long-term friend of 24 yours, right? 25 A I intend to respond to all relevant 12 (Pages 42 to 45) U.S. Legal Support EFTA01076262 46 48 1 questions of this lawsuit; however, today my 2 attorneys have counseled me I cannot provide 3 answers to any questions that may be relevant to 4 this lawsuit and I must accept their advice or 5 risk losing my Sixth Amendment right to effective 6 representation. 7 Q You know him as somebody who has been 8 caught engaging in sex with underage minors in 9 the past; Is that correct? 10 MR. PIKE: Form. 11 A You will have to repeat the question, 12 fm sorry. 13 Q You know Mr. Brunel as somebody who has 14 been caught engaging in sex with minors in the 15 past; is that correct? 16 MR. PiKE: Form. 17 A I intend to respond to all relevant 18 questions regarding this lawsuit; however, at the 19 present time my attorneys have counseled me that 20 I cannot provide answers to any questions 21 relevant to this lawsuit, and I must accept their 22 advice or risk losing my Sixth Amendment tight to 23 effective representation as your firm has been 24 described by the US. Attorney as a criminal 25 enterprise and part of one of the largest frauds 1 that I cannot provide answers to any questions 2 relevant to this lawsuit and I must accept their 3 advice or risk losing my Fifth, Sixth and 4 Fourteenth Amendment rights under the U.S. 5 Constitution. 6 Q When you were bein criminally 7 investigated and= was i is it 8 true that you made a personal telephone call to 9 her telling her not to come forward with any of 10 the information she knew? 11 MR. PiKE: Form. 12 A Again? 13 Q Putting a time frame on It, the time 14 frame where you were being criminally 15 investigated — 16 A What time frame is that? 17 Q In her complaint it is not specific, 18 but, let's just make it whenever. At some int 19 in time did you place a telephone call to in . 20 Meriting her not to come forward with 21 any information about you engaging In sex with 22 her while she was a minor? 23 MR. PiKE: Form. 24 A I intend to respond to all relevant 25 questions regarding this lawsuit; however, at the 47 1 in Florida's history specifically said you have 2 been fabricating -- the law firm has been 3 fabricating multiple cases of a sexual nature in 4 order to fleece unsuspecting investors out of 5 millions of dollars, including mail fraud, wire 6 fraud and money laundering, so unfortunately, 7 though i would like to answer all your questions 8 here today, I must assert my Sixth Amendment, 9 Fourteenth Amendment and Fifth Amendment right. 10 Q You were Involved in a modeling business 11 with him called M.C. Squared; is that correct? 12 A Again? 13 Q You were involved in a modeling agency 14 with — 15 A What do you mean 16 Q — with Mr. Brunel called M.C. Squared? 17 A "Involved" means what, what do you 18 mean? 19 Q You tell the jury your involvement with 20 the modeling agency. You can clarify for me, 21 Fillet you do that. 22 MR. PIKE: Object to the form. 23 A i intend to respond to all relevant 24 questions regarding this lawsuit. However, at 25 the present time my attorneys have counseled me 49 1 present time my attorneys have counseled me that 2 I cannot provide answers to any questions 3 relevant to this lawsuit and I must accept their 4 advice or risk losing my Sixth Amendment right to 5 effective representation. 6 Q With respect to underage females, isn't 7 it true that you have made the statement, in 8 quotes, "the younger the better"? 9 MR. PIKE: &WM. 10 A Again, as your firm has been described 11 by the current U.S. Attorney as a criminal 12 enterprise involved in mail fraud, wire fraud, 13 money laundering, and specifically crafting, 14 fabricating multiple cases of sexual — of a 15 sexual nature against people like me, and others, 16 in order to fleece many, many unsuspecting 17 investors out of millions of dollars; I would 18 like to answer your questions here today, Mr. 19 Edwards, but unfortunately, my attorneys have 20 counseled me that I must assert my Fifth, Sixth 21 and Fourteenth Amendment right or they will 22 resign. 23 Q Who are your current employees? 24 MR. PIKE: Form. 25 A Say that again. 13 (Pages 46 to 49) U.S. Legal Support EFTA01076263 50 52 1 Q Who are your current employees, people 2 who work for you, that you pay? 3 A I intend to respond to all relevant 4 questions regarding this lawsuit; however, at the 5 present time my attorneys have counseled me that 6 I cannot provide answers to any questions that 7 may be relevant to this lawsuit, or risk losing 8 my Sixth Amendment right to effective 9 representation. Accordingly, therefore, I must 10 assert my Sixth Amendment, Sixth Amendment and 11 Fourteenth Amendment rights as provided by the 12 U.S. Constitution. 13 Q Isn't it true you pay your employees to 14 bring you underage minor females for sex? 15 MR. PIKE: Form, argumentative, 16 speculation, harassing. 17 A Mr. Edwards, your firm has been 18 described the current U.S. Attorney as a criminal 19 enterprise, a criminal enterprise, part of the 20 largest fraud in South Florida's history; but 21 part of that fraud was fabricating, urn, 22 fictitious cases against me -- excuse me, against 23 people like me, of a sexual nature, in order to 24 fleece unsuspecting investors out of millions of 25 dollars. 51 1 Unfortunately at this time, though, I 2 would like to answer every one of your 3 questions. My attorney has advised me I must 4 assert my Sixth Amendment, Fourteenth Amendment 5 and Fifth Amendment rights or risk losing them as 6 my attorneys. 7 Q Isn't It true when underage females were 8 brought to you, you would engage in sex with them 9 and pay them? 10 MR. PIKE: Form, argumentative, 11 harassing. 12 A (Witness shakes head.) 13 Q Are you shaking your head to say "no" — 14 A Excuse me. 15 Q Are you shaking your head to say "no, I 16 don't know how to interpret that answer?" 17 A I didn't realize i was shaking my head. 18 MR. EDWARDS: I thought he was actually 19 answering a question. 20 MR. PiKE: Well just strike The miles 21 are well-known to every lawyer who practices 22 in the State of Florida, that it is clear 23 that a nod of the head or shake of the head 24 is not understood by the record, so 25 therefore Mr. Epstein was clearly not 1 responding to one of your questions and you 2 know that, Mr. Edwards. 3 MR. EDWARDS: This is on the video. 4 MR. PiKE: Nonetheless you know the rules. Nonetheless. If we have a question 6 on the table, would you please repeat it so 7 I can recall it and Mr. Epstein can endeavor 8 to answer it. 9 MR. EDWARDS: Sure, and if it was only 10 the court reporter, I would agree, but the 11 jury is going to see a video and everybody 12 knows commonly, if somebody shakes their 13 head, they are saying "no," and if that was 14 the answer, I wanted to give him a chance to 15 elaborate on it, that's it. 16 Q Isn't It true that when underage females 17 would come to your house, you would engage in 18 sexual activity with them and then pay them? 19 MR. PIKE: Same objections. 20 A Unfortunately I would like to answer 21 that question today, but my attorneys have 22 counseled me that i must assert my Sixth 23 Amendment right, my Fifth Amendment right and my 24 Fourteenth Amendment right under the U.S. 25 Constitution. 53 1 The fact that your finn has been 2 described as a criminal enterprise and part of 3 one of the largest frauds in Florida's -- South 4 Florida's history, pan of that fraud has been 5 described as fabricating cases of sexual nature 6 against me and others in order to fleece 7 unsuspecting investors out of millions of 8 dollars. I would like to answer that question, 9 Mr. Edwards; however, today, i must assert my 10 Fifth, Sixth and Fourteenth Amendment right. 11 Q In addition to paying these underage 12 females for sexual activity, you also paid them 13 to bring their underage friends to you, to also 14 engage in sexual activity with them? 15 MR. PIKE: Form. 16 Q Is that correct? 17 A I intend to respond to all relevant 18 questions regarding this lawsuit; however, at the 19 present time my attorneys have counseled me that 20 i may not, and I must assert -- they have advised 21 me must assert my Sixth Amendment right, my 22 Fifth Amendment right and my Fourteenth Amendmen 23 rights under the U.S. Constitution. 24 Q You would pay underage females 200 to 25 $300 for engaging in sexual activity with you or 14 (Pages 50 to 53) U.S. Legal Support EFTA01076264 54 56 i for procuring another underage female to engage 1 2 in sexual activity with you; is that correct? 2 3 MR. PIKE: Form, move to strike. 3 4 Assumes facts not in evidence and calls for 4 5 a legal conclusion as well, argumentative. 5 6 A I intend to respond to all relevant 6 7 questions regarding this lawsuit; however, at the 7 8 present time my attorneys have counseled me that 8 9 I cannot provide answers to any questions that 9 10 may be relevant to this lawsuit, and I must 10 11 accept their advice or risk losing my Sixth 11 12 Amendment right to effective representation. 12 13 Accordingly, therefore, I must assert my 13 14 constitutional rights as guaranteed by the Fifth, 14 15 Sixth and Fourteenth Amendment to the U.S. 15 16 Constitution. 16 17 Q Would you agree that your scheme was 17 18 devised to coerce these underage minors to bring 18 19 you as many other underage minors, as were 19 20 available for you to engage in sexual activity 20 21 with? 21 22 MR. PIKE: Fonn. 22 23 A Can you repeat the question? 23 24 Q Yes. Would you agree that your scheme 24 25 was devised to coerce underage girls into 25 55 1 bringing as many other underage girls to you, as 2 were available for sexual purposes? 3 MR. PIKE: Form. 4 A Did you say "for sexual purposes"? 5 Q Yes, for sexual purposes. 6 A I'm not surprised. Since your firm was 7 described as pin pybsting one of the largest 8 frauds in Florida's history by crafting, 9 fabricated sexual harassment cases against people 10 like me and others in order to fleece 11 unsuspecting investors out of millions of 12 dollars, I would like to answer that question. 13 However, today my attorneys have advised me i 14 must assert my Sixth Amendment, Fifth Amendment 15 and Fourteenth Amendment right under the U.S. 16 Constitution, and if i don't do so, I risk 17 losing — uh... losing effective representation. 18 Q Utilizing this method of using underage 19 minors to bring you other underage minors, you 20 were able to engage in sex with hundreds of 21 underage minor females. Is that true? 22 MR. PIKE: Form, argumentative, 23 harassing and calls for speculation. 24 A Since, Mr. Edwards, your firm has been 25 described as a criminal enterprise by the U.S. Attorney, and as part of the largest fraud in South Florida's history, and as part of the fraud fabricating malicious cases of sexual harassment and other cases of sexual nature against people like me and others, although I would like to answer that question today, my attorneys have advised me i must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights of the U.S. Constitution. Although I believe you know I would really like to answer your questions, but at this moment if I don't assert those rights, i risk having my attorneys resign. Q Isn't it true with this method you were able to interact sexually with underage girls every single day? MR. PIKE: Form, asked and answered. Same objections. Q Co ahead. A Oh, I7n sorry. Can you repeat it? Q Sure. With this method of - A "This method" being what, sorry? Q Your method of using underage minors to bring you other underage minors for sex; isn't it true that that method resulted in you engaging in sexual activity with underage minors on an every 57 1 day basis? 2 MR. PIKE: Same objections. 3 A Your firm has been described by the 4 current U.S. Attorney as a criminal enterprise 5 engaged in one of the largest frauds in South 6 Florida's history, and as part of that fraud, 7 creating, fabricating, malicious cases of sexual 8 nature against people like me and others, so 9 unfortunately, though I would like to answer that 10 question today, I must assert my Sixth Amendment, 11 Fourteenth Amendment and Fifth Amendment rights 12 to my counsel's advisement to do, although I 13 believe you know I would really like to answer 14 those questions today, I must assert those rights 15 or risk losing my attorneys representation. 16 Q To keep track of all these underage 17 minors, you stored their names and telephone 18 numbers In your home computer; isn't that 19 correct? 20 MR. PiKE: Form, argumentative, 21 speculation. 22 A Again? Sorry. 23 Q Are you going to answer the question or 24 Just read? if you are going to answer the 25 question, of course, I'll keep reading it as many 15 (Pages 54 to 57) U.S. Legal Support EFTA01076265 58 60 1 times. 2 A Excuse me? 3 MR. PIKE: The witness is attempting to 4 answer your question. He asked you to 5 repeat the question. 6 MR. EDWARDS: He is? 7 MR. PIKE: He asked you to repeat the 8 question. 9 MR. EDWARDS: I don't mind going through 10 that, Mike, because I do want answers, but 11 if I'm going to repeat the question multiple 12 times and get the same answer, we are 13 wasting time. I want to stop us wasting 14 time repeating questions if I'm getting the 15 same nonresponsive answer. 16 MR. PIKE: I understand your intention 17 here. 18 MR. EDWARDS: Yeah. 19 MR. PIKE: — however, these questions 20 are similar in nature, if not identical to 21 various questions that you've asked in other 22 indications, so you coming here today is of 23 no surprise that Mr. Epstein is required to 24 invoke his Fifth, Sixth and Fourteenth 25 Amendment rights under the United States 59 1 Constitution -- 2 MR. EDWARDS: I understand that. 3 MR. PIKE: — if you came here today 4 thinking you were going to pull a rabbit out of a habit, and Mr. Epstein was going to 6 waive his Fifth, Sixth and Fourteenth 7 Amendment rights to the U.S. Constitution, 8 at least not today. That will not be 9 occurring. 10 Q Isn't it true that to keep track of the 11 names and phone numbers of these underage minor 12 females, to Interact with sexually, you stored 13 those names and phone numbers in your home 14 computer? 15 A Thank you. I've heard the question 16 now. It didn't surprise again, I've now heard 17 the question and the fact that your firm has been 18 described as a criminal enterprise by the current 19 U.S. Attorney in South Florida, and part of one 20 of the largest frauds in Florida's history. it is 21 reported that your firm fabricated malicious 22 cases of a sexual nature against people and 23 against me, in order to fleece unsuspecting 24 investors out of millions of dollars. 25 Unfortunately, though I would like to 1 answer each one of your questions today, Mr. 2 Edwards, my attorneys have advised me that I must 3 assert my Sixth Amendment, Fifth Amendment and 4 Fourteenth Amendment rights under the U.S. S Constitution. So although I would like to 6 answer, I must assert those rights or risk having 7 my attorneys resign. 8 Q Do you know 9 A I intend to respond to all relevant 10 questions regarding this lawsuit; however, at the 11 present time my attorneys have counseled me that 12 I cannot provide answers to any questions 13 relevant to this lawsuit and must accept their 14 advice or risk losing my Sixth Amendment right to 15 effective representation. 16 Q Isn't it true you employed 17 to contact underage minor females and make them 18 appointments to be at your house? 19 A Sorry, again? 20 Q Isn't it true you employed 21 for the purposes of contacting underage minor 22 females and scheduling them appointments to be at 23 your house? 24 A The current U.S. Attorney has described 25 your law firm, Mr. Edwards, as a criminal 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 enterprise engaged in one of the largest frauds in South Florida's history. It has been reported that your firm fabricated multiple cases of a sexual nature against me and others, in order to fleece unsuspecting investors out of millions and millions of dollars, so, though unfortunately I would like to answer every one of your questions today my attorneys have counseled me that today I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution. Though I believe you know I would like to answer those questions, although today I must assert those rights or risk having my attorneys resign. Tell the Jury how you know MR. PIKE: Form move to strike. MR. EDWARDS: Move to strike my question? MR. PIKE: (Nods.) MR. EDWARDS: What basis? s' MR. PIKE: Do I have to state a basis? Usually I'm just required to state 'form." MR. EDWARDS: You have done more than 16 (Pages 58 to 61) U.S. Legal Support EFTA01076266 62 I 64 1 2 3 4 5 6 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that today. MR. PIKE: If I went on a diatribe of explaining, you know, what's centbsing, compound and relevant, then you would blame for testifying for the witness. So I just move to strike the question. MR. EDWARDS: Make sure you mark that somewhere on this transcript, somehow. Tell the jury how you know MR. PIKE: Move to strike. A I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Fifth Atinanhinint, Sixth Amuslusart and Fourteenth Amendment right under the U.S. Constitution. Q Isn't It true that you brought her to this country when she was underage and made ha your sex slave, and you've bragged about this? MR. PIKE: Form, argumentative, 1 your firm, Mr. Edwards, as a criminal enterprise 2 involved in mail fraud, wire fraud, money 3 laundering and, in fact, fabricating multiple 4 cases of a sexual nature against me, others, in 5 order to fleece unsuspecting investors in South 6 Florida out of millions and millions of dollars. 7 Unfortunately, though I would like to 8 answer each one of your questions here today, my 9 anomeys have advised me I must assert my Sixth 10 Amendment, Fourteenth Amendment and Fifth 11 Amendment right under the U.S. Constitution, 12 although I believe you know I would like to 13 answer your questions, but at this moment I must 14 assert those rights or risk having my attorneys 15 resign. 16 Q Isn't it true that with each of these 17 underage minor females that were brought to your 18 house, your method of sexually exploiting them 19 was nearly Identical; is that correct? 20 MR. PIKE: Objection, argumentative, 21 conflising, overbroad and vague. 22 A I don't even understand the question. 23 Q Okay. When a 14 or 15-year old would be 24 led Into your bedroom, you would appear from the 25 shower first, usually naked; Is that correct? 63 compound, harassing and calls for 2 speculation. 3 A I intend to respond to all relevant 4 questions regarding this lawsuit; however, at the 5 present time my attorneys have counseled me that 6 I cannot provide answers to any questions 7 relative to this lawsuit and I must accept this 8 advice or risk losing my Sixth Amendment right to 9 effective representation. However, I would like, 10 so I'm clear, the question was, did I bring her 11 here? Specifically — 12 Q Your answer is fine. 13 A Okay. 14 Q Is it true that you demanded numerous 15 underage minor females to have sex with 16 Inside your home while you watched, 17 masturbating? 18 MR. PIKE: Same objections. 19 A You have to repeat the question. 20 Q Isn't it true that you have ordered 21 several underage minor females to have sex with 22 in your home while you watched, 23 masturbating? 24 MR. PIKE: Same objections. 25 A The current U.S. Attorney has described 65 1 MR. PIKE: Objection, argumentative. 2 assumes facts not in evidence, and 3 harassing. 4 A I intend to respond to all relevant 5 questions regarding this lawsuit; however, today 6 my attorneys have advised me that 1 cannot 7 provide answers to any questions relevant to this 8 lawsuit and must accept their advice or risk 9 losing my Sixth Amendment right to effective 10 representation. Accordingly, therefore, I must 11 assert my Constitutional rights — the Fifth 12 Amendment, Sixth Amendment and Fourteenth 13 Amendments to the U.S. Constitution. 14 MR. PIKE: Can we go off the record for 15 a second? 16 MR. EDWARDS: If it is necessary. 17 MR. PIKE: Yes, let's go off the 18 record. 19 THE VIDEOGRAPHER: Going off the video 20 record at 12:35 p.m. 21 (Pause in the proceedings.) 22 THE VIDEOGRAPHER: Back on the video 23 record 12:44 p.m. 24 MR. EDWARDS: Can you tell me what my 25 last question is? 17 (Pages 62 to 6 5) U.S. Legal Support EFTA01076267 66 68 1 THE COURT REPORTER: Certainly. 2 (The record was read.) 3 Q After appearing from the shower naked, 4 you would order the underage minor female to 5 disrobe; isn't that true? 6 MR. PIKE: Same objections. Form. 7 A I intend to respond to all relevant 8 questions regarding this lawsuit; however, at the 9 present time my attorneys have counseled me I 10 cannot provide answers to any questions relevant 11 to this lawsuit and must accept their advice or 12 risk losing my Sixth Amendment right to effective 13 representation. 14 Q You would then order them to, or order 15 her to begin providing you a massage; is that 16 correct? 17 MR. PIKE: Form. 18 A I intend to respond to all relevant 19 questions regarding this lawsuit and I would like 20 to answer each and every one of your questions 21 today, Mr. Edwards; however, my attorneys have 22 told me that I cannot do that today unless and I 23 must assert my Sixth Amendment, Fifth Amendment 24 and Fourteenth Amendment rights under the U.S. 25 Constitution or risk losing my counsel. 1 her vagina; is that correct? 2 MR. PIKE: Form. 3 A I intend to respond to all relevant 4 questions regarding this lawsuit. Unfortunately, 5 today my attorneys have advised we I cannot, must 6 assert my rights under the U.S. Constitution, 7 under the Fifth Amendment and Sixth amendment and 8 Fourteenth amendments of the U.S. Constitution, 9 especially since your finn has been described as 10 a criminal enterprise by the current U.S. 11 Attorney perpetrating one of the largest frauds 12 in South Florida's history, fleecing investors 13 out of millions of dollars by fabricating 14 malicious cases, malicious cases of a sexual 15 nature against people like me and others. 16 Q With many of these underage minors you 17 would use vibrators on them; Is that correct? 18 MR. PIKE: Form. 19 A I would like to respond to that question 20 as l would like to respond to all your other 21 questions today. However, my attorneys have 22 counseled me that I must assert my Sixth 23 Amendment rights, my Fifth Amendment rights and 24 my Fourteenth Amendment nghts under the U.S. 25 Constitution. 67 1 Therefore, I'm going to assert those rights as 2 guaranteed by the Fifth Amendment, Sixth 3 Amendment and Fourteenth Amendment. 4 Q You would then roll over and continue 5 with masturbating; is that correct? 6 MR. PIKE: Form. A I intend to respond to all relevant 8 questions regarding this lawsuit. It is -- it is 9 my understanding that the current U.S. Attorney 10 has described your law finn as a criminal 11 enterprise, yours and Mr. Jaffe's firm, as a 12 criminal enterprise and part of the largest fraud 13 in Florida's history, fabricating malicious cases 14 of a sexual nature against me and others, in 15 order to fleece investors out of millions of 16 dollars, through bogus schemes including 17 conspiracy to — excuse me to commit mail 18 fraud, wire fraud and money laundering, so though 19 I would like to answer each and every one of your 20 questions here today, my attorneys have counseled 21 me I cannot, and must assert my Fifth, Sixth and 22 Fourteenth Amendment rights under the U.S. 23 Constitution. 24 Q You would then rub the underage minor 25 female's vagina and/or insert your fingers into 69 1 Q And with many of these underage minors, 2 you would give and/or receive oral sex from them; 3 is that correct? 4 MR. PIKE: Form. 5 A I intend to respond to all relevant 6 questions regarding this lawsuit, and 1 would 7 like to answer each and every one of your a questions; however, my attorneys have counseled 9 me that today I must assert my Sixth Amendment, 10 Fifth Amendment and Fourteenth Amendment rights 11 under the U.S. Constitution, especially since 12 your fine has been described by the current U.S. 13 Attorney as perpetrating one of the largest 14 frauds in Florida -- in Florida's history, by 15 fabricating malicious cases of a sexual nature 16 against me and others. 17 Q ID June of 2008 you pled guilty to a 18 couple of felonies, right? 19 MR. PIKE: Form, vague and confusing. 20 A Again? 21 Q In June of 2008, you pled guilty to two 22 felonies; is that correct? 23 MR. PIKE: Same objection. 24 A Yes. 25 Q And what were those felonies that you 18 (Pages 66 to 69) U.S. Legal Support EFTA01076268 70 72 1 pled guilty to? 2 A Solicitation of prostitutes, not 3 underage prostitutes but simply prostitutes. 4 Solicitation of prostitutes and one count of 5 procuring a minor for underage sex. 6 Q You have taken the Fifth as to questions 7 related to many of these underage minors, but the 8 underage minors that were the vi ' • ' the 9 cases where you pled guilty, wer is that 10 one of them? 11 MR. PIKE: Form, mischaracterizes the 12 witness's testimony. Calls for a legal 13 conclusion? 14 A Again. 15 Q What was the name of the any of the 16 underage minors that were the subject of the 17 criminal charges to which you pled guilty? 18 A I don't know. 19 Q So, tell me about those charges. What 20 were the allegations of those charges? 21 MR. PIKE: Form. 22 A Solicitation of prostitution, not 23 underage prostitution... Prostitution. 24 Q Were the victims or the prostitutes, as 25 you would say, were they minors? 71 1 MR. PIKE: Form. 2 A I pled guilty to solicitation of 3 prostitution. 4 Q Okay, so tell me what those cases were about. What happened? 6 MR. PIKE: Form again. 7 A I... (Witness shrugs.) I can't tell you 8 any more than that. 9 Q You don't know what you pled guilty to? 10 A I just told you -- 11 MR. PIKE: Object to the form, asked and 12 answered, 13 Q Do you know what you pled guilty to, the 14 facts? 15 A Solicitation of prostitution. 16 Q I understand that that's the charge. 17 What were the underlying facts? What did you do, 18 did you pull up In a car, talk to the person, did 19 they come over to your house, how did you get 20 them, those kinds of things. Tell the jury what 21 were the underlying facts about the charges you 22 pled guilty to? 23 MR. PIKE: Object to the form. Move to 24 strike. 25 A I don't 'mow. 1 Q You don't know what you pled guilty to? 2 A I pled guilty to solicitation of 3 prostitution, not underage prostitution, but 4 prostitution. 5 Q My understanding from reading the court 6 files that one of these females vs asE Do you 7 know who that is? 8 A I intend to respond to all relevant 9 questions in this lawsuit. However, at the 10 present time my attorneys have counseled me that 11 I cannot provide answers to any of these 12 questions today. So accordingly, I must assert 13 my constitutional rights under the Fifth, Sixth 14 and Fourteenth Amendments of the U.S. 15 Constitution. 16 Q You're aware• is somebody that 17 alleges she was at your house on more than 100 3.8 occasions; is that true? 19 MR. PIKE: Form. 20 A Can you repeat the question, sir? 21 Q Are you aware that Is a female that 22 alleges that when she was underage, she was at 23 your house on more than 100 occasions? 24 MR. PIKE: Form, predicate. 25 A I intend to respond to all relevant 73 1 questions to this lawsuit, Mr. Edwards. However, 2 today my attorneys have counseled me that I must 3 respond by invoking my Fifth Amendment right, my 4 Sixth Amendment right and my Fourteenth Amendment 5 right under the U.S. Constitution or risk losing 6 than as my attorneys, so therefore I must assert 7 those rights. 8 Q You understand that her complaint was 9 that Epstein tumult on to her stomach on the 10 massage bed and inserted his penis in to her 11. vagina, Stated Epstein began to pump his penis 12 in her vagina and, she became upset over this. 13 She said her head was being held against the bed 14 forcibly as he continued to pump inside of her 15 while she screamed "no." 16 Are you aware of those allegations? 17 MR. PIKE: Form, predicate. 18 A I'm sorry, did you say there is a 19 complaint? 20 Q In the incident report that led to a 21 charging document, that led to a charge that you 22 bane pled guilty to. Are you aware of that 23 Information coming from M ) 24 MR. PIKE: I'm sorry, Mr. Edwards; what 25 are you reading from? 19 (Pages 70 to 73) U.S. Legal Support EFTA01076269 74 76 1 MR. EDWARDS: The 87-page Palm Beach 2 Police Department incident report where 3 there are numerous underage females 4 describing their interaction with Mr. 5 Epstein at his house. I'm reading 6 specifically from page 41 related t 7 who was one of the victims he pi 8 to. 9 MR. PIKE: Is that the same document 10 that you're seeking production of, in this 11 same exact case? 12 MR. EDWARDS: I don't know what you're 13 talking about. This is something from the 14 State Attorney's file. 15 MR. PIKE: Okay. Sony. What's the 16 question? 17 Q Are you aware of that allegation? What 18 I just read to you. 19 A I would like to answer that question, 20 but, however, today my attorneys have advised me 21 I must assert my Fifth Amendment, Sixth Amendment 22 and Fourteenth Amendment rights under the U.S. 23 Constitution. 24 Q Assuming your attorneys have advised you 25 but because of Res indicate, double Jeopardy, you 75 1 cannot be charged for any crimes that you have 2 already pled guilty to relating ME, so I 3 would like you to explain to the jury, in your 4 words, or your version of the story, what was 5 your interaction withM at your house when she 6 was a minor? 7 MR. PIKE: Object to the form as 8 worded. Could disclose attorney/client 9 communications. 10 A I intend to respond to all relevant 11 questions regarding this lawsuit. 1 would like 12 to answer each of your questions today, however, 13 my attorneys have counseled me that I may not. 14 They've advised me that I must assert my Fifth 15 Amendment, Sixth Amendment and Fourteenth 16 Amendment rights under the U.S. Constitution. 17 Therefore, if I don't, I tisk losing their 18 counsel. Therefore, I mist assert those rights 19 here today, Mr. Edwards. 20 Q Are you aware that= Advised police 21 that she was ripped and torn in her vagina area 22 and had dl Molly walking to the car after this 23 episode where you forcibly inserted your penis 24 into her vagina? 25 MR. PIKE: Objection, relevance, 1 argumentative, compound, harassing. 2 A This was who? 3 Q The question is, are you aware.? 4 A MINI The current U.S. Attorney, since he has 6 described your firm as a criminal enterprise and 7 part of one of the largest frauds in Florida's 8 history by fabricating, fabricating, malicious 9 cases of a sexual nature against people like me 10 and others, and fleecing investors out of 11 millions of dollars by using means described in 12 the complaint against your firm, including mail 13 fraud, wire fraud, money laundering; I'm afraid 14 today, though I would like to answer each one of 15 your questions, my attorneys have counseled me 16 that I must not, !must assert my Sixth 17 Amendment, Fifth Amendment and Fourteenth 18 Amendment rights under the U.S. Constitution, and 19 I believe you know I would like to answer those 20 questions. I must assert those rights or risk 21 losing my attorneys tailor!. 22 Q Do you knov 23 A Spell it, please. 24 Q I don't know how to spell her name, bat 25 do you know'? I don't know that she would 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 77 have ever spelled her name for you. MR. PIKE: Form, move to strike. Q Her name is A I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I may not provide answers today, though I would like to, and I must, in fact, take their advice or risk losing their representation, so therefore, I must assert those rights under the U.S. Constitution. Q Do you know the names of any of the females that you allegedly solicited for prostitution and pled guilty to? MR. PIKE: Relevance. A Sitting here today, no, I do not. Q You asked me to spell=s name. That's somebody that your attorneys took her deposition about a year and a half ago. Does that help to refresh your recollection as to who =is? A I would like to answer that question but today, according to my attorneys, I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. 20 (Pages 74 to 77) U.S. Legal Support EFTA01076270 78 80 1 2 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Constitution. I must accept their advice or risk losing my Sixth Amendment right to effective representation, Mr. Edwards, so though I would like to answer the question, today I must assert those rights. mil There is another victim, her name Is that was listed as one of the females at your house and you pled guilty to the solicitation of. 1 would like to ask you if you remember her? MR. PIKE: Form, confusing, compound. A =? Q I don't know her first time, initial last name Is IM MR. PIKE: Same objection. A I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my right to effective representation. Therefore, though I would like to answer the questions, I must assert those rights. 79 1 Q With each case that results In a 2 charge - 3 THE WITNESS: Excuse me, is there some 4 water? THE VIDEOGRAPHER: Off the record? 6 MR. EDWARDS: Stopping again? 7 THE WITNESS: Can I get some water? Mr. a Jaffe, can you pass some water? 9 THE VIDEOGRAPHER: There is no water 10 here. it THE WITNESS: Sony. 12 Q With each conviction, charge, or with 13 each charge that leads to a conviction, there are la facts and circumstances that lead up to that plea 15 of guilty. 16 MR. PIKE: Form. 17 Q What are the facts and circumstances 18 that led to you pleading guilty to the two 19 felonies that you've described? 20 MR. PIKE: Form, overbroad, compound, 21 coniltsing, calls for a legal conclusion. 22 A I would like to respond to that 23 question. I would like to respond to that 24 question, but today my attorneys have advised me 25 I must assert my Fifth Amendment, Sixth Amendment 1 and Fourteenth Amendment rights to the U.S. 2 Constitution or risk losing effective 3 representation. Accordingly, I must assert my 4 rights as guaranteed by the Constitution. 5 Q Just so you are clear, since your 6 attorney made it an objection that it was 7 unclear, then you invoked your Fifth Amendment 8 rights — 9 A Sorry. 10 Q I'm talking about the cases where you 11 already pled guilty and you can't be charged 12 again. What were the facts and circumstances 13 that led up to you pleading guilty to these 14 felonies? 15 A I've answered the question. 16 MR. PIKE: Same objection, asked and 17 answered. 18 THE VIDEOGRAPHER: Counsel. 19 (Indicating five minutes left on tape.) 20 MR. EDWARDS: Okay. 21 Q Just so the Jury understands, these 22 three females that were the subject of the guilty 23 pleas in State Court, were procured by your 24 method of having underage minor females locate 25 other underage minor females and bring them to 81 1 your house; isn't that correct? 2 MR. PIKE: Objection, argumentative, 3 compound, harassing, assumes facts not in 4 evidence. I move to strike. 5 A You have to t the uestion. 6 Q Okay are all people 7 that were, at the time you engaged In sexual 8 activity with them, were underage and were 9 brought by other underage minor females; is that 10 true? 11 MR. PIKE: Same objections incorporated 12 as well as motion to strike. 13 A I don't understand — I'm sorry, I don't 14 understand the question. 15 Q Isn't it true that you used underage 16 minor females to bring other underage minor 17 females to your house for sex? 18 MR PIKE: Asked and answered. 19 A (Witness shrugs.) 20 MR. PIKE: Way earlier on. 21 MR. EDWARDS: He doesn't understand the 22 question - 23 MR. PIKE: You can answer the question. 24 Q I'm going through the progression. 25 MR. PIKE: You can answer, but it is 23. (Pages 78 to 81) U.S. Legal Support EFTA01076271 82 84 1 asked and answered. 2 A As your firm, Mr. Edwards and Mr. 3 Jaffe's has been described by the U.S. Attorney 4 as perpetrating one of the largest frauds in 5 South Florida's history by crafting malicious 6 cases of a sexual nature against people like me 7 and others, in order to fleece, using bogus 8 schemes, in the U.S. Attorney's words, investment 9 schemes. Unfortunately, though I would like to 10 answer every one of your questions if I'm able, 11 my attorneys have advised me I must assert my 12 Sixth Amendment, Fourteenth Amendment and Fifth 13 Amendment rights under the U.S. Constitution. 14 Therefore, at the moment I cannot answer that 15 question. 16 Q The acts related to your guilty plea 17 occurred at your Palm Beach house; is that 18 correct? 19 MR. PIKE: Form. 20 A Again, sorry. 21 Q If you were soliciting prostitutes, It 22 wasn't out on the street, it wasn't at a hotel. 23 These were girls that you solicited to be 24 prostitutes at your house In Palm Beach, 25 correct? 83 1 MR. PIKE: Objection, relevance, 2 argumentative. Calls for speculation as 3 worded and assumes facts not in evidence. 4 A Though I would like to answer that 5 question, my attorneys today have advised me I 6 cannot answer you today, and they've advised me I 7 must assert my Sixth Amendment, Fifth Amendment 8 and Fourteenth Amendment rights under the U.S. 9 Constitution. Otherwise I risk losing their 10 representation. So, accordingly I must assert 11 those rights, Mr. Edwards, and Mr. Jaffe. 12 Q In what county did you plead guilty to 13 these felony offenses? 14 A Palm Beach County. 15 Q These were crimes that occurred here In 16 Palm Beach County? 17 MR. PIKE: Form. 18 Q Is that correct? 19 A ... I pled guilty in Palm Beach County. 20 Q Isn't it true that you kept a calendar 21 or schedule — 22 THE VIDEOGRAPHER: I have to change the 23 tape. 24 MR. EDWARDS: Change it. 25 THE VIDEOGRAPHER: Off the video record 1 1:05 p.m. 2 (Pause in the proceedings.) 3 THE VIDEOGRAPHER: Back on the video 4 record 1:15 p.m. 5 Q Mr. Epstein, as it relates to the 6 charges you pled guilty to, are you saying today 7 that those females that you interacted with 8 sexually, were prostitutes prior to meeting you? 9 A I'm saying I pled guilty to the 10 solicitation of prostitution. 11 Q Right, and you would certainly agree 12 that that would require yourself and one other 13 Individual for that act of prostitution, 14 correct? 15 MR. PIKE: Form. Also calls for a legal 16 conclusion. 17 A I pled guilty to solicitation of 18 prostitution. 19 Q Are you saying that those females that 20 were the victims, at least listed as victims by 21 the State, were prostitutes prior to meeting 22 you? 23 MR PIKE: Form. Vague. Irrelevant? 24 A I pled guilty to solicitation of 25 prostitution. 85 1 Q Do you have any remorse for your 2 actions — 3 MR. PIKE: Form. 4 Q — against these victims that led to 5 your plea of guilty? 6 MR. PIKE: Form, argumentative. 7 A I pled guilty to solicitation of 8 prostitution, not underage prostitution, simply, 9 prostitution. 10 Q Are you saying now that the subjects of 11 that, which were called victims, were not 12 underage when you engaged In sex with them? 13 MR. PIKE: Form, argumentative, 14 speculation, assumes facts not in evidence, 15 as well as mischaracterizes the witness's 16 testimony. 17 A I pled guilty to solicitation of 18 prostitution, not underage prostitution, 19 solicitation of prostitution. 20 Q I was under the impression you pled 21 guilty to a second degree felony, that being 22 procuring a minor for the purposes of 23 prostitution. 24 A That's correct. 25 Q So a minor Is somebody under the age of 22 (Pages 82 to 85) U.S. Legal Support EFTA01076272 86 88 1 18, and I'm asking for the guilty plea related to 2 that count; are you at all remorseful for your 3 interactions with that minor? 4 MR. PIKE: Same objections. 5 A What minor? 6 Q The charge is procuring a minor. You 7 tell me. Who was that minor? 8 A I don't know. 9 Q You were never told during the State 10 Attorney's prosecution of you, who this person 11 was? 12 A No. 13 Q Why did you plead guilty to a felony 14 charge that resulted In you going to jail, 15 without even knowing who the victim was? 16 MR. PIKE: Form. That question calls 17 for attorneyklient information, and 18 therefore, I'm going to instruct him not to 19 answer that. 20 Q If it has anything to do with any 21 conversations with your attorney, I don't want to 22 know. I'm Just going off of the plea colloquy 23 between you and the Judge, where you understood 24 the charges and have been advised and apprised of 25 the charges and you still willingly, willfully 87 1 plod guilty to the charges. I'm taking now that 2 you're saying, you don't even know what those 3 charges were about? 4 MR. PIKE: What was the question? I 5 don't know the question on the table now. 6 Q Who was the minor? 7 A I don't know. 8 Q You were never told the tune or Initials 9 of that minor victim by the State Attorney's 10 Office or the prosecutor? 11 A Not that I recall. 12 Q Just so the jury understands, this 13 method of paying underage minor females to bring 14 you other underage minor females for sex, is 15 something that you do In New York, and New 16 Mexico, Florida, everywhere, not just West Palm 17 Beach; isn't that right? 18 MR. PIKE: Again, form, compound, again 19 IISSUMCS facts not in evidence. 20 Argumentative and harassing, and moreover, 21 we have already been down this road before 22 in separate related questions that have 23 already been asked and answered. 24 A I would like to respond to each one of 25 your questions; however, today my attorneys have 1 advised me I cannot and they've advised me I must 2 assert my Sixth Amendment right, my Fifth 3 Amendment right and my Fourteenth Amendment right 4 under the U.S. Constitution, therefore, that's 5 what I'm going to do. 6 Q Where is the calendar or schedule of 7 your underage sex appointments? 8 MR. PIKE: Form, speculation. 9 A You said where is... 10 MR. PIKE: "Again." 11 Q Where is the calendar or schedule that 12 kept for you for your appointments 13 for sex with underage females? 14 MR. PIKE: Same objection. 15 Q If there is not one, you can tell me 16 there Is not one. 17 A I would like to answer each one of your 18 questions today. However, I have been advised by 19 counsel that I must assert my Fifth Amendment, 20 Sixth Amendment and Fourteenth Amendment rights 21 under the U.S. Constitution or risk losing their 22 representation. Therefore, I'm going to have to 23 assert those constitutional rights, though I 24 would like to answer that question. 25 Q Are you still in possession of the 89 1 computers that were taken from your house prior 2 to the execution of the search warrant? 3 A Again. Am I still...? 4 Q Are you still In possession of the 5 computers that were removed from your house just 6 prior to the execution of the search warrant? 7 A I intend to respond to all relevant 8 questions regarding this lawsuit. However, at 9 the present time my attorneys have counseled me I 10 cannot respond to any questions that may be 11 relevant to this lawsuit, no matter how much I 12 might want to. I must accept this advice or risk 13 losing my Sixth Amendment right to 14 representation. Therefore, I must assert my 15 rights under the Fifth, Sixth and Fourteenth 16 Amendments of the U.S. Constitution. 17 Q Who is it that removed those computers 18 from your house prior to the execution of the 19 search warrant? 20 MR. PIKE: Objection, predicate. 21 A I intend to respond to all relevant 22 questions regarding this lawsuit. However, at 23 the present time my attorneys have counseled me 24 that I cannot provide answers to any questions 25 that may be relevant to this lawsuit, no matter 23 (Pages 86 to 89) U.S. Legal Support EFTA01076273 90 92 1 how much I would like to, and I must accept their 2 advice or risk losing their representation. 3 Accordingly, therefore, I would have to assert 4 those rights, Mr. Edwards. 5 Q It is my understanding, through 6 information and belief, it is my understanding 7 that this computer system contained the complete 8 list of names of underage minor females with whom 9 you engaged in sexual activity; is that correct? 10 A You're - 11 MR. PIKE: Objection. 12 A -- you're asking for my understanding? 13 Q No— la A Are you asking me to tell you what your 15 understanding is? 16 Q Did the computers that were removed from 17 your home Just prior to the execution of the 18 search warrant contain the complete list of 19 underage minor females with whom you engaged in 20 sexual activity? 21 MR. PIKE: Form. 22 A Though I would like to answer that 23 question, like all your other questions here 24 today, unfortunately my attorneys have counseled 25 me that I'm going to have to assert my Sixth 91 1 Amendment, Fifth Amendment and Fourteenth 2 Amendment rights under the U.S. Constitution. I 3 point -- excuse me. I would point out that your 4 film was described by the current U.S. Attorney S as a criminal enterprise involved in money 6 laundering, creating and fabricating malicious 7 cases of a sexual nature against people like me 8 and others, in order to fleece local investors 9 out of millions of dollam 10 I believe the senior partner of that 11 firm currently sits in jail. Unfortunately 12 though I would like to answer all of your 13 questions, today my attorneys have counseled me I 14 must assert my rights under the Sixth Amendment, 15 Fourteenth Amendment and Fifth Amendment of the 16 U.S. Constitution. 17 Q Isn't it true, you and nd 18 Ghislaine Maxwell and operated 19 as an organized criminal enterprise designed to 20 sexually exploit minor? 21 MR. PIKE: Objection, argumentative, 22 speculation, calls fora legal conclusion 23 and continues to assume facts not in 24 evidence. 25 A Thought would like to answer that 1 question, Mr. Edwards, like most of your other 2 questions here today... and hopefully will get to 3 do so at sane point, my lawyers have advised me I 4 must today assert my constitutional rights under 5 the Sixth Amendment, Fifth Amendment and 6 Fourteenth Amendment of the U.S. Constitution and 7 I must accept their advice or risk losing 8 effective repri...naltation. 9 Q And as part of that organization you 10 developed code terms such as "Work" or "Manage" 11 as opposed to engage in sex with minors; is that 12 true? 13 MR. PIKE: Form, argumentative, 14 speculation, harassing, assumes facts not in 15 evidence. 16 A Can you... you...? 17 Q You developed code terms such as you - 18 A "You" me? 19 Q Yes, you, would ask these girls if they 20 would like to give you a massage or work for you, 21 rather than asking them to do what was going to 22 be done, which is engage in sexual activity with 23 you; isn't that true? 24 MR. PIKE: Same objections. 25 A Are you asking if I developed code 93 1 words? Is that the question? 2 Q Right. Code words. 3 A I would like to respond to that 4 question, but unfortunately today my attorneys 5 told me I have to respond by taking -- invoking 6 my Sixth Amendment, Fourteenth Amendment and 7 Fifth Amendment rights of the U.S. Constitution, 8 or risk losing my amendment right to effective 9 representation. Accordingly I assert my 10 Constitutional rights as guaranteed by those 11. amendments. 12 Q What did it mean within your 13 organization when someone, some underage minor 14 female was coming over to work for you? 15 MR. PIKE: Form 16 A What did if mean? 17 Q Right, what did it mean? What did it 18 mean to you was going to happen when an underage 19 minor female would either call to work or IM 20 would tell you this person was coming to 21 work for you at a specific time? 22 MR. PIKE: Objection, vague, 23 speculative, assumes facts not in evidence. 24 A I would like to answer that question, as 25 most of your other questions today. However, 24 (Pages 90 to 93) U.S. Legal Support EFTA01076274 94 96 1 today my attorneys have counseled me that I must 2 invoke my Sixth Amendment, Fourteenth Amendment 3 and Fifth Amendment right, or risk -- and if I 4 don't, I risk losing them as my attorneys so, 5 therefore, I must wort those rights. 6 Q You're laughing as If my questions are 7 ludicrous right now but you're aware that there 8 were trash pulls from your home where there were 9 message pads, messages taken by various employees 10 of yours, where these terms, "Massage," "Work" 11 were used in conjunction with underage minor 12 females coining over to your house, weren't you? 13 MR. PIKE: Same objections, form, as 14 well. Move to strike, and also assumes 15 facts not in evidence. Lack predicates. 16 Q You're aware of the trash pull and the 17 message pads, correct? 18 MR. PIKE: Same objections. 19 Do you have any documents with you here 20 today that you speak of? 21 MR. EDWAFtDS: No, but at this point in 22 time in the trial, they will already about 23 in evidence. 24 A Pin aware of a trash pull? What's a 25 "trash pull"? I'm sorry. 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 Q Are you aware of I'll ask it of you this way: When would take a phone message for you, what did she write it down with? MR. PIKE: Form. A The question makes no sense tome, sorry. Q If another employee of yours were to answer the telephone, be it your housekeeper, housemanager, would answer the phone, take a message for you and write It down so that you could read it later, what would that message be written on? A Most likely paper. Q Okay, Is that paper typically In the form of a message pad that has a carbon copy sheet to the back? A No. Q You're unfamiliar with the documents that I'm talking about, that being a message pad that Informs you as to who called, the lime they called and the purpose for calling? MR. PIKE: For purposes of the question you're specifically talking about a message pad, nothing related to what you're defining 1 as a trash pull, just what someone takes as 2 a message at Mr. Epstein's home and -- 3 A Do I know what a message pad is? 4 Q No. In your home, do you typically have 5 your housekeeper, housemanager, or somebody else, 6 when they take a message for you, write on a 7 specific pad that informs you as to who is 8 calling, the time they are calling and the 9 purpose for their calling, and there Is a carbon 10 copy sheet evidencing that message? 11 MR. PIKE: Objection, asked and 12 answered. 13 Q You know what I'm talking about? 14 A I know what a message pad is. 15 Q Do you use them commonly in your home or 16 did you back prior to your arrest? 17 A I would like to answer that question, 18 but today my attorneys have advised me I have to 19 assert my Fifth Amendment, Sixth Amendment and 20 Fourteenth Amendment rights under the U.S. 21 Constitution, so therefore, I'm going to do that 22 or I risk losing their representation. 23 Q Is my question to you confusing? Do you 24 know what I'm talking about? 25 MR. PIKE: Form 97 1 A Not specifically, no. 2 Q Okay. 3 The information- 4 A Is there something you have to show me, 5 so I know what you're talking about? 6 Q I don't have it to show you today, but 7 If the Information and evidence that I have 8 learned through this process is accurate and 9 correct, it would seem a foregone conclusion that 10 you and I would be on the same page, at least 11 about this document, so -- 12 A Okay. 13 Q — if we are going to get to a point you 14 tell me "This document doesn't exist" or "I don't 15 know what you're talking about," okay, that's 16 fine, but that's something we can hash out. 17 Here is my question: When a 18 housekeeper/housemanager would take a message for 19 you from any taller, is there a specific message 20 pad that has a carbon copy located near your 21 telephone, for them to write down the name of the 22 caller, the purpose for the call and the time 23 called? 24 MR. PIKE: Fenn. 25 Q Is that something you're familiar with? 25 (Pages 94 to 97) U.S. Legal Support EFTA01076275 98 100 1 A I would like to respond to that 2 question. Today my attorneys have counseled me I 3 must assert my Sixth Amendment, Fifth Amendment 4 and Fourteenth Amendment right under the U.S. 5 Constitution. 6 Q You're Invoking your Fifth Amendment 7 right is not that you understand the question. 8 You understand my question and are electing to 9 invoke your Fifth Amendment rights; is that 10 correct? 11 A Yes. 12 Q When or a housekeeper or 13 housemanager, whoever happened to be employed at 14 the time, would take messages, what form would 15 you normally or typically receive them In? 16 A (Witness shrugs.) 17 MIt PIKE: Same objections. 18 A I don't understand the question. 19 Q When a caller would call the home, 20 housemanager or housekeeper or 21 don't know what you would call her, assistant, 22 would answer the phone, and take a message for 23 you so that you would know who called, what would 24 they typically write down the message on so that 25 you would have It? 99 1 MR. PIKE: Objection. Object to the 2 fens, lacks predicate. You have not 3 established anything here today relative to 4 a housekeeper or housemanager or the like. 5 Urn... And Pm trying to understand the 6 question. But — 7 MR. EDWARDS: Really? 8 MR. PIKE: — it lacks predicate. 9 MR. EDWARDS: This will play well. 10 A Piece of paper. 11 Q Normally they would write It down on a 12 piece of paper and give It to you? 13 A I didn't say that. 14 Q Have you ever been given a message that 15 is ripped out of a message pad that has a carbon 16 copy to it? 17 A Oh, I see. Okay. I intend I would 18 like to answer that question, but today my 19 attorneys have advised me I must respond by 20 invoking my Sixth Amendment right, my Fifth 21 Amendment right and my Fourteenth Amendment 22 rights under the U.S. Constitution. Though I 23 would like to answer these questions, accordingly 24 I must assert those tights or I risk losing my 25 representation here today. 1 Q Between the years 2002 and 2005, who was 2 your house manager? 3 A (No response.) 4 Q If there is more than one, tell us that. 6 A The question is unclear. I'm sorry. 7 Q Okay, let me start with between 2002 and 8 2005, did you employ a hossemanager? 9 MR. PIKE: Form. 10 A Where? 11 Q At your Palm Beach home. 12 A I intend to respond to all relevant 13 questions here today, Mr. Edwards. Hopefully we 14 will get some. But my attorneys have advised me 15 that today I must invoke my Sixth Amendment, 16 Fifth Amendment and Fourteenth Amendment rights 17 under the U.S. Constitution; or risk losing them 18 as counsel. So today I have to assert those 19 privileges. 20 Q Do you knoa 21 A I intend to respond to all relevant 22 questions regarding this lawsuit. However, at 23 the present time no matter how much I would like 24 to answer that question, I cannot, because my 25 counsel _the attorneys have told me that I have 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 101 to invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment or, in fact, risk losing their representation. Therefore, I'm going to have to assert my rights under those. Is a female that was born A Is that a question? Q Not yet. When Is the first time that you met her? MR. PIKE: Objection, speculation. MR. EDWARDS: That assumes that he did meet her; is that what you're saying? MR. PIKE: Your question assumes -- MR. EDWARDS: He met her? MR. PIKE: -- exactly what he just said which hasn't been established on the record yet pursuant to the appropriate Florida Rules of Civil Procedure and the Evidence Code. Lacks predicate. A That being said, I would like to answer that question, but today my attorneys have counseled me that I cannot, and they've advised me I must assert my Sixth Amendment right, my Fourteenth Amendment right, and my Fifth Amendment right under the U.S. Constitution. 26 (Pages 98 to 101) U.S. Legal Support EFTA01076276 102 104 1 THE WITNESS: Can you throw me one of 2 the suckey candies, please 3 Thank you. 4 MR. EDWARDS: (Handing candy.) 5 THE WITNESS: Appreciate it. 6 Q Isn't It true ou me for the Ant 7 time I just before her 8 fourteenth birthday? 9 MR. PIKE: Same objections. 10 A You know, your firm has been accused by 11 the U.S. Attorney of perpetrating one of the 12 largest frauds in South Florida history by 13 crafting sexually charged lawsuits against people 14 like me and others in order to fleece 15 unsuspecting investors here in South Florida out 16 of millions of dollars. The firm of you and Mr. 17 Jaffe. The U.S. Attorney described it as bogus 18 schemes connived by your firm. 19 I would like to answer every one of your 20 questions here today, however, my attorneys have 21 counseled me that 1 may not, and have advised me 22 that I have to invoke my Sixth Amendment, Fifth 23 Amendment and Fourteenth Amendment rights under 24 the U.S. Constitution. Therefore, that's what I 25 will do, otherwise I risk losing their 103 1 representation. 2 Q Isn't it true= as a 13 or 14-year 3 old girl was taken to your house by another 4 underage minor female, that being 6 MR. PIKE: Form. 7 THE WITNESS: Tissue, please. 8 MR. EDWARDS: (Handing tissue.) 9 A I would like to answer that question 10 like all the other questions you've asked me here 11 today, but today my attorneys have counseled me 12 that I have to invoke my Sixth Amendment right, 13 my Fifth Amendment right and Fourteenth Amendment 14 rights under the U.S. Constitution; therefore 15 that's what I will do. 16 Q Do you know wbo 17 right, she had a lawsuit against you previously? 18 MR. PIKE: Form. 19 A Again the last mune? 20 21 A Could you spell it for mc? 22 Q Well, the pseudonym that she used in her 23 lawsuit against on alleging similar facts to 24 those alleged i versus Jeffrey Epstein was 25 versus Jeffrey Epstein. 1 A And now the question? 2 Q You know who she is, correct? 3 MR. PIKE: Form. 4 A I would like to answer that question 5 here, Mr. Edwards, but unfortunately today my 6 attorneys have counseled me I must invoke my 7 Fifth Amendment. Sixth Amendment and Fourteenth 8 Amendment rights under the U.S. Constitution, and 9 if I don't, I risk losing their representation, 10 therefore I must assert those rights. 11 en I asked you aboutiM or 12 you sat there for a while thinking hard 13 about whether or not you knew them. Doyou 14 remember either= o 15 MR. PIKE: I move to strike counsel's 16 statement because the statement as worded 17 assumes facts certainly not in evidence. It 18 is argumentative, speculates as to what is 19 "thinking hard," and, counsel, i don't 20 understand the question on the table, 21 combined with your narrative. If you could 22 repeat the question? 23 MR. EDWARDS: Sure. 24 Q I'm asking If during this questioning 25 process, has It refreshed your recollection as to 1 2 3 4 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 105 who is or do you really have no Idea who that is? MR PIKE: Form. Asked and answered. Q Do you rememberM A Are you going to ask one question? Which question would you like answered first? Q Do you remernberM A I would like to answer that question. 1 would like to answer that question today, however my attorneys today have advised me that I must assert my Fourteenth Amendment, Fifth Amendment and Sixth Amendment rights under the U.S. Constitution, no matter how much I would like to answer these questions. So unfortunately, I'm going to assert those rights. Q When you first met= isn't it true that she was just about to begin her ninth grade year In high school? MR. PIKE: Same objections. Form. A I believe her testimony in front of the FBI, in a sworn deposition says something else, but I don't recall exactly what. I don't have any recollection. Q Of= MR. PIKE: Form. 27 (Pages 102 to 105) U.S. Legal Support EFTA01076277 106 108 1 A You asked the question when I met her, I 2 think, if I met her. 3 Q You have no recollection as to when you 4 met her? 5 A I don't have recollection if I ever met 6 her. I just told you, I did read her FBI 7 statement, w I know what she has said and it is 8 not what you've just represented to me. 9 Q Your only knowledge of any interaction 10 you may have had will Is derived from an FBI 11 statement that she gave; Is that true? 12 A I believe what you just represented she 13 said was not what she had sworn to. 14 Q I'm not asking what she said. I'm 15 asking do you independently remember If she was 16 entering into her ninth grade year of high school 17 when you met her? Independent of anything you've 18 read. 19 MR. PIKE: All right, let me just move 20 to strike the... Diatribe between Mr. 21 Edwards and Mr. Epstein. I'm confused as to 22 what question is on the table now. 23 MR. EDWARDS: Okay. 24 Q Independent of anything you've ever 25 mad- 1 Q When you first came into the room today, 2 didn't you look at me and say "I likeM" Isn't 3 that the statement that you made to me? 4 MR. PIKE: Form. Move to strike. 5 A I don't believe I said that 6 Q What Is It that you believe you did say 7 referencing= when you sat down in that seat 8 prior to the cameras rolling? 9 MR. PIKE: Form. Counsel, I was here 10 during that whole time and I don't recall 11 any such statement. 12 MR. EDWARDS: You weren't in the room. 13 A 1 don't remember. I don't know. 14 Sorry. 15 Q So is it your testimony right now that 16 you did not say to me "I 17 A That's 18 MR. PIKE: Objection. 19 A -- that's correct. 20 Q Do you IllteM? 21 MR. PIKE: Form, predicate, and 22 relevance. 23 A I would like to answer all your 24 questions here as I've... tried to do my best, 25 however, my attorneys have advised me that I must 107 1 A Okay. 2 Q — do you remember meeting`, just 3 before sbe entered into her ninth grade year in 4 high school? 5 A I would like to answer that question, 6 however my attorneys today have advised me that 7 though her own statements are contradictory to 8 what you just said, her sworn statements to the 9 FBI contradict what you just said. I have to 10 invoke my Sixth Amendment, Fifth Amendment and 11 Fourteenth Amendment rights to the U.S. 12 Constitution. 13 Q Just a few minutes ago when you asked 14 when you met her, you said, "I don't know if I've 15 ever met her," so Is that your testimony, that 16 you don't know if you ever met 17 A My testimony is very clear. I must 18 assert the rights my attorneys have asked me to 19 assert today, though her testimony under oath to 20 the FBI is not what you represented it to be, to 21 me, and the ladies and gentlemen of the jury who 22 are watching this, hopefully. 23 MR. PIKE: Form. 24 Q We will get into that. 25 A Okay. 109 1 assert my Sixth Amendment, Fourteenth Amendment 2 and Fifth Amendment rights under the U.S. 3 Constitution. 4 Q When you first met., Isn't it true S that you knew she was an economically 6 disadvantaged girl that needed money? 7 MR. PIKE: Objection, speculation, 8 assumes facts not in evidence, and it is 9 argumentative as worded. 10 A I would like to answer all your 11 questions here today, Mr. Edwards, and Mr. 12 Jaffe. However, on advice of counsel I have to 13 assert my Sixth Amendment, Fifth Amendment and 14 Fourteenth Amendment rights under the U.S. IS Constitution, or risk losing my right to 16 effective representation. So accordingly I must 17 assert those rights as guaranteed by the Sixth, 18 Fifth and Fourteenth amendments. 19 Q When she was a 14-year old girl, she was 20 taken into your bedroom and you ordered her to 21 take her clothes off; Is that correct? 22 MR. PIKE: Objection, vague, confusing. 23 As to "her' I'm not quite sure who you... 24 Q Virlien=was a I4-year old girl, she 25 was taken up to your bedroom and you ordered her 28 (Pages 106 to 109) U.S. Legal Support EFTA01076278 110 112 to take her clothes off; isn't that true? 2 MR. PIKE: Objection, speculation, and 3 assumes facts not in evidence. Lacks 4 predicate. 5 A Though once again what you've just 6 represented to me is a total contradiction to the 7 FBI sworn statement that I read of= I must 8 unfortunately respond by asserting the rights 9 demanded by my attorneys today, which is my Sixth 10 Amendment, Fifth Amendment and Fourteenth 11 Amendment right against sorry, given by the 12 U.S. Constitution, though her testimony is 13 exactly — does not purport in any way to what 14 you've just said. 15 Q And whenMwas 14 years old, you 16 ordered she begin to give you a manage while she 17 was naked and you were naked; isn't that true? 18 MR. PIKE: Same objections. 19 A Sorry, you have to repeat the question 20 for me. 21 Q When-was a 14-year old girl — 22 A Right. Yes? 23 Q you laughed and said, "right" about 24 what? 25 A I didn't hear the first part of your 1 THE VIDEOGRAPHER: Going off the video 2 record 1:49 p.m 3 THE WITNESS: Thank you. 4 (Pause in the proceedings.) 5 THE VIDEOGRAPHER: Back on the video 6 record 2:04 p.m. 7 Q Mr. Epstein, when was a 14-year old 8 girl, Isn't it true that while you were naked o0 9 the massage table, you ordered-to take off 10 her clothes and provide you a massage? 11 A I believe I've answered that question, 12 didn't i? 13 Q i don't remember where we left off, 14 that's why. 15 MR. PiKE; Form, argumentative, 16 speculation. It is compound and assumes 17 facts not in evidence and has been asked and 18 answaed. But we did take a break, so you 19 can respond. 20 (Counsel addressing Mr. Epstein.) 21 A The current U.S. Attorney has described 22 your law firm as a criminal enterprise involved 23 in fabricating sexually charged cases against 24 people like me in order to fleece Mc iresing 25 investors out of millions of dollars. He used 111 1 question. Now I understood it. 2 Q When-Was a 14-year old girl, wasn't 3 it true that you received a massage from her 4 while she was naked and you were naked? 5 MR. PIKE: Objection, speculation, 6 assumes facts not in evidence, lacks 7 predicate. 8 A I understand that your lino has been 9 accused by the U.S. Attorney of South Florida, 10 perpetrating one of the largest frauds in 11 Florida's history, by crafting malicious, 12 sexually charged ons against people like 13 me. I understand testimony is not what 14 you've just described, though she swore to the 15 FBI... under oath. Though I would like to answer 16 your questions here today, my attorneys have 17 advised me I may not. I must assert my Sixth, 18 Fifth and Fourteenth Amendment rights under the 19 U.S. Constitution or risk losing their 20 representation. 21 THE WITNESS: Restroom break. 22 MR. EDWARDS: Excuse me? 23 THE WITNESS. Restroom break. 24 MR. EDWARDS: Stopping again? 25 THE WITNESS: Yeah. 113 1 words like "bogus schemes." 2 Unfortunately at this time in response 3 to your questions, though I would like to answer 4 each and every one, I'm going to have to, on 5 advice of counsel, assert my Sixth Amendment, 6 Fifth Amendment and Fourteenth Amendment rights 7 under the U.S. Constitution, though I would like 8 to answer those questions. 9 Q WhileMwas a naked 14-year old girl 10 providing you a massage, you ordered her to pinch 11 your nipples during that massage; Isn't that 12 true? 13 MR. PIKE: Same objections, 14 argumentative, speculation, harassing, 15 assumes facts not in evidence and lacks 16 predicate. 17 A i asked her to pinch her nipples? 18 Q Pinch your nipples? 19 A I believe her own sworn testimony 20 contradicts that statement. However, I would 21 like to answer all your questions here today, but 22 my attorneys advised me, at least today, Mr. 23 Edwards, I must take my constitutional privileges 24 of the Sixth Amendment, Fifth Amendment and 25 Fourteenth Amendment, keeping in mind that your 29 (Pages 110 to 113) U.S. Legal Support EFTA01076279 114 116 1 firm, of you, Mr. Edwards, and Mr. Jaffes firm 2 has been accusal by the U.S. Attorney of 3 perpetrating one of the largest frauds in 4 Florida's history by crafting sexually charged 5 lawsuits against people like me, to fleece from 6 local people millions of dollars. 7 Q And during this massage la, you began to masturbate in front of her, isn't that 9 true? 10 MFt. PIKE: Same objections? 11 A Unfortunately, though I would like to 12 answer each one of your questions here today, my 13 attorneys have counseled me today at least, I 14 have to assert my Fifth Amendment, Sixth 15 Amendment and Fourteenth Amendment rights under 16 the U.S. Constitution, otherwise 1 risk losing 17 their effective representation, and the fact that 18 your firm has been accused of fabricating these 19 malicious lawsuits to fleece investors out of 20 millions of dollars, as described by the U.S. 21 Attorney here in South Florida as a criminal 22 enterprise involved in mail fraud, money 23 laundering... Unfortunately! would like to 24 answer each question, but I can't today. 25 Q Isn't it true that while you were 115 1 masturbating you inserted your fingers into her 2 14-year old vagina? 3 MR. PIKE: Objection, argumentative. 4 Speculation. It is harassing. It assumes 5 facts not in evidence. The question 6 continues to lack predicate, and I also 7 believe the question has been asked and 8 answered sometime ago. 9 A Though I would like to answer each one 10 of your questions today, Mr. Edwards, my counsel 11 has told me 1 cannot answer any questions that 12 maybe relevant to this lawsuit. The fact that 13 your firm has been accused of major fraud, the 14 largest fraud in South Florida history, by the 15 U.S. Attorney calling your firm a criminal 16 enterprise involved in money laundering — I 17 believe it is racketeering, but 1 could be 18 wrong... Monetary transactions via fraud, mail 19 fraud, conspiracy — sorry —I would like to 20 answer your questions but today on advice of 21 counsel, l am going to have to assertinirights. 22 Q Isn't it true also that while Wan 23 14-year old rental., you masturbated to the point 24 of laculating while Inserting your fingers into 25 vagina? 1 MR. PIKE: Same objections incorporated? 2 A Again, the question? 3 Q Isn't it true that during this sexual 4 massage, while you were — that you masturbated 5 to the point of ejaculating while you were 6 inserting your lingers into= vagina? 7 MR. PIKE: Objection, argumentative, 8 speculation. It is compound. It is vague. 9 it assumes facts not in evidence and lacks 10 predicate. 11 A Though I would like to answer that 12 question with specificity and detail today, no 13 matter how much I would like to, my attorneys 14 have advised me I cannot. They advised me I must 15 assert my Fifth Amendment, Sixth Amendment and 16 Fourteenth Amendment rights under the U.S. 17 Constitution or potentially lose effective 18 representation, so therefore, I will assert those 19 rights. 20 Q Isn't it true that the ritual that I'm 21 describing occurred with approximately 100 22 times when she was between the ages of 13 and 16? 23 MR. PIKE: Same objections, with the 24 additional objection of vague and 25 confusing. 117 1 A Since your firm has been involved -- 2 according to the U.S. Attorney in crafting these 3 fraudulent lawsuits in order to fleece local 4 investors, and the fact that I believe in L.M.'s 5 sworn statements, that's what you've just alleged 6 at least is totally contradicted by your client's 7 own sworn statements, though I would like to 8 answer these questions today, my attorneys have 9 advised me I may not and advised me I must assert 10 my Fifth, Sixth and Fourteenth Amendment rights 11 under the U.S. Constitution or potentially risk 12 losing effective representation. 13 Q In addition to the sexual abuse directed 14 against= that I've just described, Isn't It 15 true that you also paid her money to bring you 16 more than 50 other underage minor females for you 17 to similarly abuse? 18 MR. PIKE: Same objections. 19 A Though I believe in her own swum 20 testimony to the U.S. government that she 21 contradicts those assertions, and I'm sure maybe 22 you'll have some explanation at trial, but the 23 ladies and gentlemen of the jury should know 24 about your firm being accused by the U.S. 25 Attorney of perpetrating one of the largest 30 (Pages 114 to 117) U.S. Legal Support EFTA01076280 118 120 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 frauds in U.S. history by crafting malicious lawsuits of a sexual nature in order to fleece investors out of millions of dollars, local investors; and though I would like to answer your questions in detail today, Mr. Edwards, and Mr. Jaffe, my counsel says I may not and have asked me to assert those rights, which I must unfortunately. Q You keep bringing up this fraud of the former law firm known as Rothstein, Rosenfeld, Adler in response to my questions, so I would like you to tell the jury at this time which allegation are you now saying is fraudulent or untrue, that's been made by= MR. PIKE: Form, confusing, compound, and irrelevant. MR. EDWARDS: Only made irrelevant by his answers. MR. PIKE: Same objections. Q Do you understand the question? A No. Q You made reference to — in response to my questions about what you did sexually to A Yes, sir? 1 described as one of the largest frauds in South 2 Florida's history. So, it concerns me. It is a 3 factor in the way I'm thinking about answering. 4 Sorry. 5 Q Each time that you digitally penetrated 6 or otherwise fondled her sexually, you paid 7 her $200; is that correct? 8 MR. PIKE: Objection, argumentative, 9 speculative, harassing. It assumes facts 10 not in evidence, and with regard to this 11 line of questioning, the Court has already 12 ruled that the demeanor in which you're 13 presenting this question is improper, and 14 harassing, so if you would -- 15 MR. EDWARDS: I'm very comfortable with 16 the demeanor right now, Mr. Pike. These are 17 just the facts of the lawsuit. The facts 18 are outrageous and I understand that, but 19 they have to be asked. 20 MR. PIKE: Maybe the demeanor and tone 21 of your question is laced in a manner that 22 it is proper for the video, but the content 23 of the question is the same exact harassing 24 question that was deemed by the Judge to be 25 argumentative. I'm not saying that he's not 119 1 Q -- you have responded with these fraud 2 allegations against the firm of Rothstein. 3 Rosenfeld, Adler. I want you to tell the jury 4 which allegations that is making against you 5 are you disputing at this time or calling a fraud 6 or calling untrue? 7 MR. PIKE: Confusing, compound and — if the court reporter would read back Mr. 9 Epstein's response, I think you will see the 10 way you just phrased the question 11 mischaracterizes his testimony. Because -- 12 well, I'll keep it there unless you want me 13 to go further. You want me to go further? 14 MR. EDWARDS: No, I want him to go 15 further. 16 MR. PIKE: Mischaracterizes the 17 witness's testimony. 18 A own statements contradict every 19 one of your allegations that you've made to me 20 today, as a hypothetical. In her own words. And 21 you -- and the potential reasons this concerns me 22 is the fact that the law firm that represented 23 and two others have been accused by the U.S. 24 Attorney of fraudulently producing cases against 25 me and others, to fleece investors in what he's 121 1 going to answer your question. 2 MR. EDWARDS: Okay. 3 MR. PIKE: Or that you don't know what 4 his answer will be, but what I'm saying is: 5 could you rephrase the question? 6 Q Answer that question. I'll work on 7 rephrasing it for you at some point. 8 A Sorry, I forgot what the question is by 9 now. 10 Q Isn't It true that each time that you 11 interacted withIMI sexually, meaning digitally 12 penetrated her or fondled her in some other way, 13 that you paid her $200 each time? 14 MR. PIKE: Form. 15 THE WITNESS: Sorry? 16 MR. PIKE: Form. Go ahead. 17 A I would like to answer each one of your 18 questions here today. However, my attorneys have 19 counseled me that today I have to assert my Fifth 20 Amendment, Sixth Amendment and Fourteenth 21 Amendment rights under the U.S. Constitution and 22 I'm cognizant of the fact that your firm has 23 crafted these malicious lawsuits, it has been 24 reported that the lawsuits are of a sexual 25 nature, in order to fleece investors, so though I 31 (Pages 118 to 121) U.S. Legal Support EFTA01076281 122 124 1 would like to answer those questions, Mr. 2 Edwards, and Mr. Jaffe, today I must keep my 3 counsel's advice. 4 Q Isn't It true that for each underage 5 minor that= brought to you for the purposes 6 of you engaging in sexual activity, you paid her 7 5200? 8 MR. PIKE: Objection, speculation. 9 Compound question, and it assumes facts not 10 in evidence. Therefore lacks predicate. 11 A Though I would like to answer that 12 question, as most of your other questions here 13 today, Mr. Edwards, I intend to respond, 14 hopefully at some point to all of your questions, 15 but today my attorneys have advised me I must 16 invoke my Sixth Amendment, Fifth Amendment and 17 Fourteenth Amendment right under the U.S. 18 Constitution. 19 Q Over the course of relatively a roughly 20 three years, isn't it true that you touched or 21 fondle in a sexual manner on more than 50 22 occasions? 23 MR. PIKE: Objection, argumentative. 24 Calls for speculation. It is overbroad, 25 confusing and vague, and it assumes facts 123 1 not in evidence. 2 A Could you repeat the question forme? 3 I'm sorry, Mr. Edwards. 4 Yes. The three-year period betwee when you were engaging In sexual conduct 6 wit isn't it true that that conduct took 7 place on more than 50 occasions? MR. PIKE: Same objection 9 A I believe if you read your own client's 10 FBI statements, what her statement it changed 11 dramatically after she decided to file a 12 different lawsuit, at the request of you and your 13 firm, with one of your firms — there have been 14 many firms it seems, was accused of major fraud. 15 Since the testimony has changed dramatically, I 16 would like to answer those questions, but today 17 my attorneys have advised me I must assert my 18 Sixth Amendment right, my Fifth Amendment right 19 and my Fourteenth Amendment right. 20 Q ** Your answers are not going to 21 incriminate you if the answer is "no," it is only 22 if the answer is "yes" that it wi0 incriminate 23 you, so aren't you telling the jury every single 24 thing I've asked you is not part of a fraud, just 25 happens to be true, isn't it? 1 MR. PIKE: Objection, argumentative, 2 irrelevant and move to strike. Pm simply 3 going to instruct the witness not to answer 4 that question because... I don't understand 5 it. I don't know what to say about that 6 question. 7 A (Gesturing.) 8 Q All of the things that I've told you or 9 that I've asked you about, you touching her while 10 she was underage, you paying her for sexual 11 conduct, those are all things that really 12 happened, there is nothing about that, that 13 anybody has fabricated or made up, is there? 14 MR. PIKE: Objection, argumentative, 15 speculative, it assumes facts not in 16 evidence, it certainly mischaracterizes the 17 witness's testimony all day, since I have 18 been here, and I have been here the whole 19 time. It assumes facts not in evidence. It 20 is also overbroad and substantially compound 21 because you're attempting to incopmate all 22 of your questions today into one question. 23 MR. EDWARDS: I think you know, Mr. 24 Pike, your objection should be limited to 25 the fonn. If you object to the form it is 125 1 fine. 2 MR. PIKE: I'm sorry, that's - 3 MR. EDWARDS: You — 4 MR. PIKE: You've asked me several times 5 today to tell you why. I thought I was 6 helping. Fm sorry. I certainly will keep 7 objecting to 8 MR. EDWARDS: Appreciate it. 9 MR. PIKE: — the form. 10 MR. EDWARDS: Thank you. 11 Q And your answer is? 12 A Repeat the question. 13 Q Every single allegation that. has 14 nude and I have now questioned vou about in terns 15 of your sexual Involvement within they are 16 all true; isn't that correct? There is nothing 17 fabricated about any of these allegations, 18 correct? 19 MR. PIKE: Objection, argumentative, 20 speculative, compound. It is vague, 21 overbroad — 22 MR. EDWARDS: You're objecting to form? 23 MR. PIKE: Yes, assumes facts not in 24 evidence and lacks predicate. That is 25 Conn. 32 (Pages 122 to 125) U.S. Legal Support EFTA01076282 126 128 1 A And I would like to answer that question 2 specifically today, however, on advice of counsel 3 they've suggested I take the Sixth amendment -- 4 assert my Sixth Amendment, Fifth Amendment and 5 Fourteenth Amendment rights under the U.S. 6 Constitution, keeping well aware of your firm's 7 responsibility in the largest fraud in Florida's history by crafting sexually charged lawsuits 9 against people like me and others. 10 I believe in addition, since ha 11 allegations, as you've phrased them, have changed 12 dramatically since her sworn statement, until in 13 fact, after she joined this firm charged with 3.4 this major fraud and most of her statements have 15 changed, I believe, so... 16 Q You re r when-became pregnant 17 when she wa ears old, don't you? 18 MR. PIKE: Form, relevance, move to 19 strike? 20 A I would like to answer each one of your 21 questions here today, Mr. Edwards; each and every 22 one of your questions. However, today my counsel 23 has told me I must assert my Sixth Amendment, 24 Fourteenth Amendment and Fifth Amendment rights 25 under the U.S. Constitution. 127 1 Q Isn't It true that when was 14 2 years old, 15 years old and 16 years old, you 3 touched her genitals? 4 A Separate from the fact that in ha own 5 testimony, her own sworn testimony under oath 6 before she decided to file a lawsuit for money, 7 there was never any discussion about anything 8 like that. I would like to answer that question, 9 but my attorneys have advised me, at least today, 10 that I must assert my Sixth Amendment, Fifth 11 Amendment and Fourteenth Amendment rights under 12 the U.S. Constitution. 13 Q Isn't it true when she became pregnant 14 at ageMou no longer interacted with her 15 sexually but still demanded that she bring you 16 other underage minor females for you to sexually 17 exploit? 18 MR. PIKE: Objection, speculation. 19 Compound. Harassing, and assumes facts not 20 in evidence. 21 A I believe her testimony changed 22 dramatically from her sworn statements to the 23 FBI 24 Q That's not a responsive — 25 MR. PIKE: Excuse me 1 MR. EDWARDS: It is not a responsive 2 answer so I won't allow — 3 MR. PIKE: That — 4 MR. EDWARDS: Well move to strike it. 5 Let's have an answer to the question. 6 MR. PIKE: The witness is trying. If 7 there is a legal basis for your moving to 8 strike, it would be taken up with the Court 9 and you can move to strile. 10 You can continue. 11 MR. EDWARDS: Strike it, it is 12 nonresponsive? 13 A Your allegations thatiarkeep throwing 14 at me, relate to the fact that= testimony, 15 after giving a sworn statement to the FBI, 16 changed dramatically after she decided to file a 17 lawsuit for money, joining your firm that's been 18 accused by the U.S. Attorney of ono of the 19 largest frauds in Florida's history. I would 20 like to answer those questions; however, on 21 advice of counsel today I must assert my Fifth 22 Amendment, Sixth Amendment and Fourteenth 23 Amendment:iris under the U.S. Constitution. 24 Q Whe was a pregnant.year-old, 25 she brought you at least ten underage minor 129 1 females during her pregnancy; isn't that true? 2 MR. PIKE: Objection, argumentative, 3 speculation. It is vague and assumes facts 4 not in evidence and lacks predicate. 5 A I —I —I unfortunately would like to 6 answer that question as well as every other 7 question you've asked me here today, but my 8 attorneys have advised my I must assert my Fifth 9 Amendment, Sixth Amendment and Fourteenth 10 Amendment rights the U.S. titution. 11 Q After had her son a ears old, 12 and you were being criminally hives 'gated for 13 some of the conduct that we've discussed here 14 today; isn't it true that you personally hired 15 and retained and paid for an attorney to 16 representM 17 MR. PIKE: Objection, speculation -- 18 MR. EDWARDS: Object to the form, Mr. 19 Pike. 20 MR. PIKE: I will not. I am allowed to 21 assert the basis for my objections, I am not 22 limited to just saying "form? I'm able to 23 assert the basis as to why, so I don't waive 24 that basis. 25 MR. EDWARDS: It is just more of this 33 (Pages 126 to 129) U.S. Legal Support EFTA01076283 130 132 1 obstructionist -- 2 MR. PIKE: It's not obstructionist, it 3 is objecting to form. What is 4 obstructionist is what we are doing now. I 5 will be finished within four seconds. So 6 am going to object to form, it's 7 argumentative, speculative and it assumes facts not in evidence and it lacks 9 predicate. That's it. 10 A I'm sorry. (Witness shrugs.) Again? 11 Q The response to the question. 12 A I don't know the question. 13 Q You don't remember the question? Did 14 you Mr= an attorney at some point In time? 15 Do you remember that? 16 MR. PIKE: Same objection. 17 A Not to the 18 Q Do you kno 19 A ... Do I know James Eisenberg? I don't 20 believe I've ever met James Eisenberg. 21 Q Is It your testimony today then that ou 22 never paid for an attorney to represen 23 A (Witness shakes head.)... On advice of 24 my counsel, I would like to answer that question, 25 but on advice of counsel I'm going to have to 131 1 assert my Sixth Amendment, Fourteenth Amendment 2 and Fifth Amendment rights against -- excuse me. 3 Sixth Amendment rights of the U.S. Constitution. 4 Q And that attorney that was paid for by 5 yoµ Informed= that if she were to teU the 6 FBI exactly what happened at your house, that her 7 son could be taken from her. You're aware of 8 that, correct? 9 MR. PIKE: Same objections. 10 A I recognize, I believe she made one of 11 the statements at her deposition after she 12 decided to sue me for a bunch of money and your 13 film has represented a number of... cases of a 14 sexually charged nature that turned out to be 15 fraudulent in order to fleece local investors. 16 The U.S. Attorney described your firm and these 17 cases as a bogus scheme, and I'm aware of that, 18 and would like to answer your question in more 19 detail today, Mr. Edwards; however my attorneys 20 advised me that at least today, I must assert my 21 rights under the Sixth Amendment Fourteenth 22 Amendment and Fifth Amendment. 23 MR. PIKE: It is the food. 24 MR. JAFFE: I didn't want him in the 25 room in mid answer. 1 THE WITNESS: Ready? Thank you. 2 THE VIDEOGRAPHER: Going off the video 3 record 2.29 p.m. 4 (Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video 6 record 2:50 p.m. 7 Q Isn't it true, Mr. Epstein, that you B gave= money to coerce her into interacting 9 with you sexually? 10 A Mr. Edwards, I would like to answer each 11 and every one of your questions here today, but 12 unfortunately, like I've done with mostly all of 13 your other questions, I'm going to have to assert 14 my rights, Sixth Amendment, Fourteenth Amendment 15 and Fifth Amendment on advice of counsel. 16 Although I would like to answer, if I don't 17 follow my counsel's advice, I risk losing 18 representation. 19 Q White committing these sexual acts 20 against= when she was Just a minor, you knew 21 it would psychologically damage her, Isn't that 22 true? 23 MR. PIKE: Form, lacks predicate, 24 speculation. 25 A I intend to respond at some point to — 133 1 I would like to respond to each and every one of 2 your questions, but today on advice of my counsel 3 they've required me to assert my Fifth Amendment, 4 Sixth Amendment and Fourteenth Amendment rights 5 under the U.S. Constitution, though I would like 6 to answer each of these questions. 7 Q In fact, you deliberately and 8 intentionally caused severe emotionally distress 9 to underage minor females, including.' Isn't 10 that true? 11 MR. PIKE: Objection, argumentative, 12 speculation, it is compound. And it assumes 13 facts not in evidence. 14 MR. EDWARDS: Okay. 15 A I would like to answer that question, as 16 I would like to answer all siflaur other 17 questions today regarding= However, my 18 attorneys today have advised me that I must 19 assert my Sixth Amendment right to effective 20 representation and my Fifth Amendment right and 21 my Fourteenth Amendment right. Though I would 22 like to answer that with specificity, I must 23 follow my attorney's advice. 24 Q Will you admit for the jury that you 25 were investigated federally for your Illegal 34 (Pages 130 to 133) U.S. Legal Su ort EFTA01076284 134 :36 activities with underage minors? 2 MR. PIKE: Same objections. 3 A I would like to answer that question, as 4 well as all the other questions you've asked me 5 here today, especially since your firm has been 6 accused by the federal, I guess, the federal 7 government,... being considered a criminal — you 8 firm has been considered and investigated as 9 being a criminal enterprise using sexually 10 fabricated, sexual cases... fabricated cases, to 11 fleece investors out of millions of dollars, but 12 I would like to answer your questions; however my 13 attorneys have demanded that I assert my rights 14 under the Sixth Amendment, Fifth Amendment and 15 Fourteenth Amendment. 16 Q In fact, as a result of that 17 investigation, you, as well as the United States 18 Attorney's Office entered Into what has now been 19 known and referred to as the nonprosecution 29 agreement; isn't that correct? 21 MR. PIKE; Same objection. The document 22 speaks for itself? 23 A You have to repeat the question. 24 Q Asa result of the criminal 25 investigation into your activities with minor 1 2 3 4 S 7 8 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 135 females, you reached a resolution with the United States Attorney's Office, in what has now been described as the nonprosecution agreement; Is that correct? MR PIKE: I'm going to object. Vague, confining, misrepresents the agreement and the document is the best evidence. Will you mark it? MR. EDWARDS: I can mark it. We will copy it at the end and manic it as Exhibit 2. (Document, Nonprosecution Agreement, was deemed narked as Exhibit number 2 for identification, as of this date.) A Yes. Q In that agreement, there are listed co-conspirators of Jeffr stein, those being Leslie Graff (phonetic) and . Can you explain to the jury what those Individuals did for you related to the crimes that were investigated by the federal government? A Co-conspirators? Q Yes, it says "criminal charges against any co-conspirators of Epstein including but not limited to Leslie 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 Graff or . Can you explain to the jury what each of those four individuals did for you or conspired with you to do? MR. PIKE: Object to the form of the question? A I would like to answer that question, however, today my attorneys advise me that I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution. Q Isn't It fair to say that you, as well as the co-conspirators, operated as an organized criminal enterprise designed to sexually exploit underage minors? MR. PIKE: Object to argumentative, speculation. It is vague and it assumes facts not in evidence. A Are you suggesting it was a criminal enterprise? Is that the words? Q Yes. A Though I would like to answer that question today, I think the only criminal enterprise that I have been reading about today was your firm, that's been accused of being a criminal enterprise involved in defrauding 137 1 people, using mail fraud, wire fraud, money 2 laundering, the operation of the enterprise — 3 this is by the U.S. Attorney (indicating), but 4 though I would like to answer your questions with 5 specificity today, on advice of counsel, though I 6 would like to answer it, they demanded I assert 7 my Sixth Amendment, Fourteenth Amendment and 8 Fifth Amendment right or I risk losing their 9 representation. 10 Q Did you care about any of the underage 11 minor females at the time when you were engaging 12 In sexual conduct with them? 13 MR. PIKE: Objection, argumentative. 14 Harassing, already been ruled upon by the 15 Court relative to this exact question. 16 MR. EDWARDS: I feel comfortable with 17 the question. It goes to punitive damages. 18 The issue related to the Court was a 19 repetitive question on that topic or around 20 that general subject matter. I'm just 21 asking for Mr. Epstein to tell the jury how 22 he felt about these girls, whether he cared 23 about them, when he was engaging in illegal 24 sexual conduct with them. 25 MR. PIKE: Counsel, I'm going to 35 (Pages 134 to 137) U.S. Legal Support EFTA01076285 138 140 1 instruct him not to answer the question. 2 You can certify it to the Court, if you 3 like. You know what the answer is going to 4 be; however you're attempting to lace this 5 video. You know the Court has already 6 ordered that these types of questions are 7 not permitted because they are argumentative 8 and harassing. in fact, other questions 9 bordered but this question is on exact point 10 with the Court's order. If you want to 11 withdraw the question, that's fine. 12 MR. EDWARDS: I don't want to withdraw 13 the question. 14 MR. PIKE: Then I instruct him not to 15 answer. 16 MR. EDWARDS: Mark that somehow, that 17 page, so we can fmd it in the record, 3.8 relative to the hearing that will be had on 19 that question and others similar. 20 Q At the time when you were engaging in 21 sexual conduct with underage females, you knew 22 that exposing them to this, was not beneficial or 23 good for these girls; isn't that true? 24 MR. PiKE: Objection, argumentative, 25 speculation, =tunes facts not in evidence. 139 1 Lacks predicate. 2 A Though i would like to answer that 3 question, like most of your other questions here 4 today, on advice of counsel I must assert my 5 Fourteenth Amendment, Fifth Amendment and Sixth 6 Amendment rights. Though I would like to answer, 7 if I do so, I visit losing my effective 8 representation of counsel. 9 Q Isn't It true, Mr. Epstein. that the 10 only thing that you cared about was accessing as 11 many underage females as possible. for the 12 purposes of sex? 13 MR. PiKE: Argumentative, speculation, 14 harassing. 15 A What's the question? 16 MR. PIKE: And assumes facts not in 17 evidence. 18 Q Isn't It true that the only thing that 19 you cared about when you were interacting with 20 these underage females in a sexual manner, was 21 ejaculating or your own personal gratification? 22 MR. PIKE: Sam, same exact objections. 23 A Though I would like to answer that 24 question, and to the ladies and gentlemen of the 25 jury, I would very much like to answer that 1 question; however, today my attorneys have 2 advised me I must take assert my rights under 3 the Fourteenth, Sixth and Fifth Amendments of the 4 U.S. Constitution, or else I risk losing their 5 representation. 6 MR. PIKE: And Mr. Edwards, just so we 7 don't have to cane back on the question that 8 i instructed him not to answer, if you would 9 go ahead and repeat that question, I will be 10 more than happy to let him respond. 13. MR. EDWARDS: i don't remember the 12 question we will take it up with the Court 13 and we'll get a ruling on it. 14 MR. PIKE: It was whether or not he 15 cared about these i believe you quoted it 16 as underage minors, but I would like the 3.7 court reporter to read back the question 18 just to conserve judicial resources and not 19 go back. So if she can reread the question 20 that would be good. 21 MR EDWARDS: If you can find the 22 question. 23 THE COURT REPORTER: Certainly. 24 MR. EDWARDS: I think I know it 25 Q Did you care about any of these underage 141 1 minor females that you were engaging in sex with, 2 at the time when you were engaging in these 3 sexual activities? 4 MR. PIKE: Same objections, as before. 5 A Though I would like to answer that 6 question as well as most of your other questions, 7 if not all of your other questions here today, on 8 advice of counsel I will have to assert my 9 Fourteenth Amendment right my Sixth Amendment 10 right and my Fifth An not right, because no 11 matter how much I actually want to answer that 1.2 question, if I do so I risk losing my counsel's 13 representation. 14 Q At the time you were engaging in sexual 15 activity with these underage minors, including 16 you knew that this conduct was illegal, 17 didn't you? Is ME. PIKE: Same objections. Form. 19 A I would like to answer that question, as 20 well as most of your other questions here today, 21 however, today my counsel has instructed me to 22 assert my Fourteenth Amendment, Sixth Amendment 23 and Fifth Amendment right, and if I do not, and 24 if, in fact, I answer that question if I can 25 answer that question, I potentially risk losing 36 (Pages 138 to 141) U.S. Legal Support EFTA01076286 142 144 1 my effective counsel's representation. 2 Q In fact, you told many of these underage 3 minor females not to tell anybody what happened 4 with you in the house, or else they would be In 5 trouble; Isn't that true? 6 MIt PIKE: Fenn 7 A I would like to answer that question, as 8 well as the other questions; however, my counsel 9 has advised me that today I must assert my 10 Fourteenth Amendment, Sixth Amendment and Fifth 11 Amendment rights under the U.S. Constitution. 12 Q The underage minor females that have 13 come forward with information about your sexual 14 interactions with them have been investigated, 15 harassed, humiliated in an effort for you to 16 intimidate them to go away. Is that true? 17 MIt PIKE: Objection. Argumentative, 18 speculative, compound. It is overbroad, and 19 assumes facts not in evidence. 20 A Can you repeat the question? 21 Q Sure. Any underage minor female that 22 you engaged in sexual activity with, that has now 23 pursued a lawsuit against you, isn't it true that 24 you've spent a lot of money and a lot of 25 resources Investigating them in an effort to 143 1 intimidate them and hopefully make them go away? 2 MR. PIKE: Same objections. 3 A I believe your client's testimony 4 changed dramatically when she joined up with you 5 and your law firm, accused of fraud, when she 6 decided to change her testimony, at least from 7 what the statements said, both to the police and to the FBI, and decided to seek money. However, 9 anything above that or beyond that, I'm going to 10 have to, in fact, assert my Fifth Amendment, 11 Sixth Amendment and Fourteenth Amendment rights 12 as directed by my competent counsel. 13 Unfortunately, they have told me if I daft, I 14 risk losing their representation. 15 Q All right, I'll give you a chance here 16 since you keep bringing up her statement to the 17 FBI as opposed to her sworn testimony for 13 18 hours under oath in this case. Are you saying 19 that the sworn testimony to the FBI was, in fact, 20 the truth? 21 A What I'm saying is, it seems ha 22 testimony has changed dramatically after she 23 joined your finn, that's all. 24 Q Okay. Irrespective of her testimony, 25 you've read her testimony and you read her 1 testimony — to the FBI. You watched her 2 deposition when it was being taken. Which — 3 A You're nuking assumptions, I'm sorry. 4 MR. PIKE: Let him finish the question. 5 THE WITNESS: Sorry. 6 A My fault 7 MR. PIKE: Then Ill object and you'll 8 respond. 9 Q Which are you saying is the truthful 10 testimony, her statement to the FBI or the 11 videotaped deposition that you watched? 12 MR. PUCE: Object to the Conn 13 A What I've said, and I think repeat 14 myself is until she joined your firm and started 15 to seek money, her testimony was different. 16 That's my understanding. 17 Q Are you denying any sexual Involvement 18 with= at this time? 19 MR. PIKE: Form 20 A I would Wee to answer that question. I 21 would like to answer it as with most of your 22 questions here today, however, my attorneys have 23 advised me that I must take that — assert my 24 rights under the Sixth Amendment, Fourteenth 25 Arnmdment and Fifth Amendment, no natter how much 1 2 3 4 5 6 a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 145 I would like to answer that question, or potentially risk losing my counsel. Q Isn't your game plan with all of these civil lawsuits that have been tiled against you, to spend as much money as you can to Investigate, and harass these young women into hopefully dropping the lawsuits against you? MR. PIKE: Objection. Relevance. Move to strike. It is argumentative and harassing. A I would like to answer that question. I think you know the answer to that question. Q Yes. A (Witness nods.) However, today my attorneys have advised me I must assert my Sixth Amendment rights, my Fourteenth Amendment rights and my Fifth Amendment rights. Q You don't have any remorse for the sexual abuse that you committed againstM, do you? MR. PIKE: Objection. It is argumentative. It is harassing. It is, I believe, confined under the Judge's order and it assumes facts not in evidence? A 'prat being said, would like to answer 37 (Pages 142 tO 1 4 5) U.S. Legal Support EFTA01076287 146 148 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that position, the lack of remorse goes to 1 that question today, but my attorneys have 2 advised me that I must assert my Fourteenth 3 Amendment rights, my Fifth Amendment rights and 4 my Sixth Amendment righ 5 Q In fact, you recently didn't 6 you? 7 A Yes, and you and your firm that's been 8 accused of the largest fraud in Florida's history. described by the U.S. Attorney as a criminal enterprise involved in money laundering, conspiracy to commit one crime excuse me, mail fraud, mmit wire fraud. Yes, Q ** Tell the jury — A Yes. MR. PIKE: I'm going to instruct the witness not to answer that question in this medium, as it is wholly irrelevant currently, as were it, to this particular lawsuit. MR. EDWARDS: lust so you can rethink 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 147 punitive damages, that is an aspect of the case that has against Mr. Epstein. MR PIKE: This lawsuit, the current one tein is noticed for is not proper for this MR. EDWARDS: I understand your position. MR PIKE: — in that regard, I'm going to instruct him not to answer any questions relative to that lawsuit because of that objection, as well as, it is m MR EDWARDS: I understand your position completely, Mr. Pike. MR PIKE: Thank you. 1 Q ** But as it relates to, obviously- 2 sued you making the allegations that you sexually 3 molested her from when she was 13 tan old to 4 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 O answer that question, for the same reasons stated. MR. EDWARDS: Let's mark that. Q Is it your feeling that because you are wealthy and these children are poor, that you are entitled to sexually abuse them? MR. PIKE: Argumentative. Q In speaking about these children, and indnding MR. PIKE: Argumentative, speculation, compound, it's vague, and it assumes facts not in evidence. A In keeping with your firm's propensity 149 1 for filing fellacious (sic), manufactured, 2 sexually charged cases, based on nothing but thin 3 air, accused by the U.S. Attorney of the largest 4 fraud in South Florida's history, by S manufacturing sexual cases, I would like to 6 answer each and every one of your questions, 7 including why I sued you, but today I'm not going 8 to be able to. ! have to simply listen to my 9 counsel and assert my Sixth Amendment, Fourteenth 10 Amendment and Fifth Amendment right. 11 Q This answer that you keep reciting, 12 about the Rothstein, Rosenfeld, Adler firm — 13 A You do know who they are, right? 14 Q — you are aware, obviously, that all of 15 the lawsuits that were filed against you, 16 including, were tiled at least a year 17 before, or approximately a year before Rothstein, 18 Rosenfeld, Adler had any of these cases; you're 19 aware of that, right? 20 MR. PIKE: Form. 21 A I do not know when Rothstein Adler got 22 involved in these cases. I do know that the 23 moment that they did surface, and, in fact, I 24 understand you shared information with all the 25 other attorneys that you so — that the jury 38 (Pages 146 to 149) U.S. Legal Support EFTA01076288 150 152 1 should understand that the information 2 gathered — according to the U.S. Attorney, by 3 illegal means, has been shared with all the other 4 attorneys that you keep representing have filed 5 cases against me; yes, I'm aware of that. 6 Q I don't understand that answer. Steven, 7 do you - 8 MR. PIKE: Do you have a question? 9 MR. EDWARDS: I want to understand what 10 his answer was. As in all depositions, if 11 you don't understand the answer, clarify the 12 answer. 13 MR. PIKE: No, you have to ask a 14 question. 15 MR. EDWARDS: I did. And he's 16 responding to it. 17 MR. PIKE: The witness has answered the 18 question. Do you have another question to 19 clarify his answer? 20 MR EDWARDS: Yes. 21 Q Please clarify your answer. 22 MR. PIKE: I will instruct him not to 23 answer. it's vague and confusing, it's 24 narrative. 25 MR. EDWARDS: Me saying "clarify your 1 your house when she was 13,14,15,16 years 2 old — 3 A Is that a claim? 4 Q she was in your bedroom. You instructed her to get naked. You inserted your 6 fingers into her vagina. You used a vibrator on 7 her. You coerced her into recruiting other 8 underage minor females, roughly 50 or so more. 9 These are all claims that have amounted 10 to various counts, coercion, prostitution, 11 intentional infliction of emotional distress, 12 battery, committing various crimes against her. 13 What are your defenses to that? Normal defenses 14 arc "I didn't do it," "I did It, but It didn't 15 hurt her," we are trying to understand so we know 16 how to provide this case to the jury, what are 17 your defenses to t►ese allegations? 18 MR. PIKE: I'm going to object to this 19 line of questioning. It is compound; as 20 worded it could call for disclosure of 21 attorney/client information as well as work 22 product. I believe in this particular case 23 there is a document filed, answer in 24 affirmative defenses, and the affirmative 25 defenses are set forth there and the 151 answer" is narrative? 2 MR. PIKE: What do you mean by "clarify 3 your answer? 4 MR. EDWARDS: I didn't hear what he 5 said. Say it again so I can hear it. 6 MR. PIKE: Would you please read back 7 what Mr. Epstein just testified to, madam 8 court reporter. 9 (The record was read.) 10 MR. EDWARDS: Okay. 11 MR. PIKE: It was an answer, a 12 question — 13 MR. EDWARDS: I understand -- I mean I 14 don't understand the answer, but now I know 15 the answer. 16 MR. PIKE: Okay. 17 Q At this point in time, please tell the 18 Jury what is your defense of the claims being 19 asserted against you in this lawsuit by-7 20 MR. PIKE: I'm going to object. Calls 21 for a legal conclusion. 22 A What are the claims? So since you're 23 representing can you tell me what the 24 claims are? 25 Q Yes, we've gone through it. She went to 153 1 document there speaks for itself. 2 MR. EDWARDS: Okay. 3 Q Respond. 4 A The document speaks for itself. 5 Q ** So you agree with the affirmative 6 defenses that were filed in your case? If you 7 were to testify, we could expect that to be your 8 testimony? 9 MR. PIKE: That's not what the witness 10 testified. The winless testified that the 11 document speaks for itself, and again, I'm 12 going to object to attomey/clicnt, work 13 product and instruct the witness not to 14 answer. 15 Q I'm not asking what your legal defense 16 Is. I'm asking: What is your response to the 17 claims? 18 MR. PIKE: Same objection. 19 Q What Is your personal response? 20 A I would like to respond to that 21 question. I would like to respond today to that 22 question; however, today my attorneys have told 23 me that I cannot respond. They've asked me to 24 assert my Fourteenth Amendment, Sixth Amendment 25 and Fifth Amendment rights of the US. 39 (Pages 150 to 153) U.S. Legal Support EFTA01076289 a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 Constitution, though I would really like to 2 respond. They are telling me if I did so, I will 3 lose risking their representation. 4 Q I know you've invoked your Fifth 3 Amendment rights related to many of these 6 question 7 contacte and spoke to him about case as well as several of the other girls, who have claims against you? A Can you repeat the question? Dlda Q year, coma II and discuss these cases that have been filed against you and the allegations made by these various females? MR. PIKE: Form. A I would like to answer that question, but unfortunately today my attorneys have advised me I cannot. They've advised me I must assert my Sixteenth — excuse me, my Fourteenth Amendment, Sixth Amendment and Fifth Might, so therefore, I will do so. 154 156 1 A (Laughter.)... Did I tell... I would 2 like to answer that question, but today on advice 3 of my counsel, 1 must — as I have done with 4 mostly each one of your questions, I have to 5 assert my Fifth Amendment, Sixth Amendment and 6 Fourteenth Amendment rights under the U.S. 7 Constitution. 8 Q You were 51 when was 14, and you 9 were interacting with her sexually. Is it your 10 testimony that despite the disparity in age you 11 do not consider= to be a victim? 12 MR. PIKE: Argumentative, speculation, 13 assumes facts not in evidence. Compound, 14 lacks predicate. 15 A Not only does it contradict your own 16 client's statements to the FBI under sworn 17 testimony, I would like to answer that question. 18 Hopefully one day I can answer that question, but 19 today my attorneys have said I cannot. They 20 advised me I must assert my Sixth Amendment, 21 Fifth Amendment and Fourteenth Amendment rights. 22 Q In the last ten years, what is the 23 youngest underage minor female that you have 24 interacted with sexually? 25 MR. PIKE: Argumentative, speculation, 155 1 Why Is it that you will talk tiM 2 i li a bout this but you will not talk to the Jury 3 a out this? 4 MR. PIKE: Form. Argumentative, S speculation. Misstates the witness's 6 testimony. It assumes facts -- the question 7 assumes facts not in evidence and now lacks 8 predicate. 9 A 10 11 Did you not talk to him? If you 12 didn't talk to him, tell me that. That's fine. 13 MR. PIKE: Some objections. 14 A I would like to tell you answers to each 15 one of your questions, however today my attorneys 16 have demanded that I respond by asserting my 17 Fourteenth Amendment, Sixth Amendment, Fifth 18 Amendment privilege, though I would like to 19 respond, but they said if I do so, I risk losing 20 their representation. 21 Q Didn't you te 22 underage minors were not victims at all and that 23 regardless of their age, you did not personally 24 consider them victims? 25 MR. PIKE: Same objection. 157 1 assumes facts not in evidence. 2 A The answer to that question is — I 3 would like to give you an answer to that today, 4 but my attorneys have advised me I must assert my 5 Fourteenth Amendment rights, my Sixth Amendment 6 rights and Fifth Amendment rights. 7 Q Do you know Michael Friedman? A Doesn't ring a bell. 9 Q Former housekeeper/employee of yours, 10 worked at the Palm Beach house? 11 A ... Could. Don't know. 12 Q So you would be unable to answer what 13 Michael Friedman did for you? 14 A Yes. 15 Q Are you aware that our investigator 16 spoke with Michael Friedman, former housekeeper 17 for you, or housemanager for you, out in 18 California? 19 A No. 20 Q Any reason why when asked about the 21 activity that occurred in your house, he would 22 tear up and say, "I was hoping to forget 23 everything I saw"? 24 MR. PIKE: Objection, argumentative. 25 Speculative, Assumes facts not in 40 (Pages 154 to 157) U.S. Legal Su ort EFTA01076290 158 160 1 evidence. 2 A Again, the question? 3 Q Is there any reason that when asked A I don't know who he is. 5 MR. PIKE: Also, hearsay. 6 THE VIDEOGRAPHER: Counsel? 7 MR. EDWARDS: Go ahead. THE VIDEOGRAPHER: Going off the video 9 record 3:23 p.m. 10 (Pause in the proceedings.) 11 THE VIDEOGRAPHER: Back on the video 12 record 3:30 p.m. 13 Q This person that I asked you about, 14 Michael Friedman, is that somebody who has 15 contacted you within the last six months? 16 A ... No. 17 Q In taking a break and thinking about 18 some of these questions, have you remembered who 19 that person is, or still no real memory of him at 20 all? 21 A No real memory. 22 Q To the best of your knowledge, he never 23 worked for you? 24 MR. PIKE: Form. 25 A Not that I can recall, but there are 159 1 lots of people who work for me, so... 2 Q Can you tell the jury who the various 3 people are that work for you now? 4 A I believe I answered that question 5 already. 6 Q In that you invoked your Fifth 7 Amendment, correct? 8 A That's correct, Sixth Amendment and 9 Fourteenth Amendment. 10 Q Eigthteen and twenty-first? 11 A (Witness shrugs.) 12 MR, PIKE: Move to strike. 13 Q ** Have you, during this litigation and 14 by "this litigation." I don't only mea 15 case, but the various other lawsuits that have 16 been filed against you by other females alleging 17 sexual misconduct by you against them. Who have 18 you retained attorneys for, what witnesses have 19 you retained attorneys for? 20 MR. PIKE: Object to the form. 21 MR. EDWARDS: Okay. 22 MR- PIKE: ill instruct him not to 23 answer because I don't understand the 24 question. Okay? 25 MR. EDWARDS: All right 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 During this civil discovery and litigation — A Um-hum? Q -• have you paid for, and/or retained an attorney for any other witnesses? A Any other witnesses? Q Yes, like I'll give you an example that you may, just to refresh your recollection or tell you what I'm talking about you know who that is, right? A Yes. Q She is someone to works for you now, she's a housekeeper. We took her deposition already. At least that's what her testimony was. MR PIKE: Form. A I would like to answer that question but I have to assert my Sixth Amendment, Fourteenth and Fifth. Q That somebody who has informed us that you paid for and obtained an attorney by the name of Bruce Reinhart to represent her during this process. Is that — MR. PIKE: Form. A I have to assert my Fifth Amendment, 161 1 Sixth Amendment and Fourteenth Amendment, right. 2 Q Other people that have indicated that 3 you retained and paid for an attorney to 4 represent them are Michael Friedman, 5 Janusz Banaziak 6 Ghislaine Maxwell your brother, Mark Epstein, 7 Larry Visoski, Larry 8 Morrson, David Rogers, Igor linovkw. Have I 9 missed anybody else that during this litigation 10 you've paid for or retained attorneys? 11 MR PIKE: Form, same objection. 12 A I'm not clear. Are you suggesting I've 13 paid for attorneys for all these people? 14 Q Yes. 15 A (Laughter,) I would like to answer those 16 questions today, but on the advice of counsel I 17 have to invoke my Sixth Amendment, Fifth 18 Amendment and Fourteenth Amendment tight 19 Q If you have not, tell me which of those 20 on that list that you have not paid for or 21 retained attorneys for? 22 MR. PIKE: Same objection. 23 A Same answer. 24 Q You're invoking your Fifth Amendment, 25 right? 41 (Pages 158 to 161) U.S. Legal Support EFTA01076291 162 164 1 A And Sixth Amendment and Fourteenth 2 Amendment... and Fifth Amendment 3 Q ** Is it a company or Is It you, 4 personally, that is paying for the attorneys' 5 fees related to your representation? 6 MR. PIKE: I'm going to object to the 7 form. I'm going to instruct him not to 8 answer that question based on relevance; and 9 it is vague also. 10 Q Who Is writing the check to your 11 attorneys for your representation in this 12 lawsuit? 13 A (No response.) 14 Q Who Is paying the bill? 15 A I believe I am. 16 Q And is it you, personally, or is this 17 one of your corporations or companies? 18 MR. PIKE: Form, speculation. 19 A I'm not sure. 20 Q As you sit here today, you're not really 21 sure whether it Is coming from one of the other 22 corporations that we've discovered during 23 discovery or it is coming from you, personally? 24 Is that correct? 25 MIt PIKE: Asked and answered. 163 1 A I believe — I would like to answer but 2 I have to invoke my Sixth, Fourteenth and Fifth 3 Amendment rights. 4 Q As It relates to any of the other 5 witnesses who have had attorneys retained for 6 them, is it also your response to invoke your 7 Fifth Amendment rights, rather than to provide me 8 with an answer, as to who is paying the bill for 9 those attorneys? 10 A I would like to answer those questions, 11 but today my attorneys have asked me not to 12 respond to any questions that may be relevant to 13 this lawsuit, so I must follow their advice and 14 invoke the Sixth Amendment, Fifth Amendment and 15 Fourteenth Amendment, right. 16 Q Have you interacted sexually with any 17 underage minors in the last year, while on house 18 arrest or work release from jail? 19 MR. PIKE: Objection. Argumentative and 20 compound and lacks predicate. 21 A I would like to answer that question, 22 but on advice of counsel, at least today, theyve 23 advised me I must invoke my Sixth Amendment, 24 Fourteenth and Fifth Amendment right. 25 MIt PIKE: It is also overbroad. 1 Q If me narrowing down will help you to 2 respond, l will. Is there any need for that? 3 A (Witness shakes head.) 4 MR. EDWARDS: Okay. 5 THE WITNESS: Sony. 6 Q Is It your Intent to Interact sexually 7 with minors In the future? MR. PIKE: Same objection. 9 A I would like to answer that question, 10 but today my counsel has advised me I must invoke 11 the rights of the Sixth Amendment, the Fourteenth 12 Amendment and the Fifth Amendment of the U.S. 13 Constitution. 14 Q Are you currently treating with a 15 psychologist related to any sex addiction that 16 you have with minors? 17 A I would like to answer that question, as 18 well, as most of the other... questions you've 19 asked me today, however, on advice of counsel 20 theyve asked me to invoke my Sixth Amendment, 21 Fourteenth Amendment and Fifth Amendment right, 22 therefore, though I would like to answer that 23 question, as well as the other ones, I risk 24 losing the representation if I do so. 25 MR. PIKE: Moreover I'm going to object 165 1 to relevance as I have in the past since Mr. 2 Epstein's medical history is not at issue in 3 this case; under the legal terms. 4 Q You would agree, wouldn't you, that you 5 targeted these underage girls including_ 6 because of their young age? 7 MR_ PIKE: Argumentative, speculative, 8 harassing. Assumes facts not in evidence. 9 A I would like to answer that question, as 10 well as most of the other questions you've asked 11 me here today. My counsel has advised me that I 12 must assert my Fourteenth Amendment, Sixth 13 Amendment and Fifth Amendment right. Though I 14 would like to answer those questions today... if 15 I do so, I risk losing their representation. 16 Q You would also agree, wouldn't you, that 17 you targeted these underage females for sex. 18 IncludIng=, because they were poor? 19 MR. PIKE: Same objections. 20 A I would like to answer that question. I 21 would really like to answer that question, as 22 well as the other questions you've asked me here 23 today, however, on advice of my counsel theyve 24 demanded that I assert my Fifth Amendment, Sixth 25 Amendment and Fourteenth Amendment rights. If I 42 (Pages 162 to 165) U.S. Legal Support EFTA01076292 166 168 1 answer that question, i risk losing their 2 representation. 3 Q You would agree, wouldn't you, that you 4 sexually molested.. for three years? 5 MR. PiKE: Same objection. 6 A I think you've asked me that question 7 before. I assert the same rights as before. 8 Q That's the Fifth, Sixth and Fourteenth 9 amendments, just so the record is clear? 10 A Yes. 11 Q You would agree, wouldn't you, that you 12 coerced into prostitution? 13 MR. PiKE: Same objections. 14 A I believe her own testimony reflects, at 15 least the sworn statement to the FBI, reflects 16 that that is not the case; and though I would 17 like to answer that question in great detai1,1 18 cannot do so today on advice of counsel, that 19 have asked me to assert my Sixth Amendment, Fifth 20 Amendment and Fourteenth AnICIRIIIICId rights. If 21 do so,1 risk losing their representation. 22 Q You would agree with me that you groomed 23 into becoming a prostitute? 24 MR. PIKE: I'm going to object. 25 Argumentative, speculative. Certainly lacks 167 1 predicate and assumes facts not in 2 evidence. 3 A You know I would like to answer that 4 question, but I can't today. Under advice of counsel I have to assort my Fourteenth Amendment, 6 Sixth Amendment and Fifth Amendment rights. if i 7 answer the question,1 risk losing their a counsel. 9 Q You would agree, wouldn't you, that you 10 brainwashedM into believing that this 11 lifestyle of prostitution was right? 12 MR. PIKE: Same objections. 13 A I would like to answer that question, as 14 most of your other questions here today, Mr. 15 Edwards. On advice of counsel today, I'm going 16 to have to assert my Fifth Amendment, Sixth 17 Amendment, Fourteenth Amendment rights. if i 18 answer that question, I risk losing their 19 representation_ 20 Q Would you agree that your interaction 21 witbM when she was a minor, was degrading to 22 her? 23 MR. PiKE: Same objections. 24 A I would like to answer that question. I 25 would like to answer all of your questions here 1 today; however, my counsel has advised me that 1 2 must assert my Fourteenth Amendment rights, my 3 Sixth Amendment rights and my Fifth Amendment 4 rights, and though I would like to answer those 5 questions, if i do so I risk losing their 6 representation. 7 THE WITNESS: Can we take a ton-minute 8 break for some air? 9 MR. EDWARDS: We have IS minutes and 10 we're done. 11 THE WITNESS: Continue then? 12 MR. EDWARDS: Okay. 13 Q Would you agree that you intentionally 14 IndoetrinateciM foto this very deviant sexual 15 lifestyle? 16 MR. PIKE: Okay, I'm going to object 17 It is argumentative. It is confusing. It 18 is speculative, vague, lacks predicate and 19 assumes facts not in evidence. 20 A And on top of that, I would like to 21 answer that question, but my counsel has advised 22 me I must assert my Fourteenth Amendment, Sixth 23 Amendment and Fifth Amendment rights under the 24 U.S. Constitution. Although I would like to 25 answer all your questions today, I cannot do so 169 1 risking losing their representation. 2 Q Would you agree that you were personally 3 responsible for destroying her life? 4 MR. PiKE: Same act objections. 5 A Halite? 6 7 A I would like to answer that question, 8 and I understand how your firm has been accused 9 of fabricated sexually charged lawsuits in order 10 to fleece investors locally in South Florida. 11 The U.S. Attorney has called your law firm a 12 criminal enterprise based on filing fallacious 13 (sic) sexually charged cases. Although i would 14 like to answer that question today, Mr. Edwards, 15 and Mr. Jaffe, my counsel has told me that I have 16 to assert my tights under the Sixth Amendment, 17 Fifth Amendment and Fourteenth Amendment, and if 18 I don't do so, I risk losing their 19 representation. 20 Q We have a factual basis for asking every 21 question and making every allegation. I want to 22 provide you with a last opportunity to tell the 23 jury which of these allegations, if any, being 24 made by are false or fabricated in any 25 way? 43 (Pages 166 to 169) U.S. Legal Support EFTA01076293 170 172 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. PIKE: Same objections. Mr. Edwards, you know the tenor of that question cannot be answered without waiver of Fifth, Sixth and Fourteenth. I appreciate the question and the semantics of it, but it is... It is -- can you rephrase it? MR. EDWARDS: Yes. Q Many tines» you know the allegations now, we've gone through them allegations and assertion of facts as to what happened between you and her wilguabiars 13, 14 and 15 years old and you wers years old. Several times you responded saying something about Rothstein, Rosenfeld & Adler, something about her FBI statement, what have you; I want to give you a chance to tell the jury, whkh of her allegations, if any, that you believe now are false or fabricated in any way. MR. PIKE: Same objections. A I would like to respond to that question, the fact that her firm, the law fum representing her has been accused by the U.S. Attorney of being a criminal enterprise, manufacturing, fabricating, out of thin air, cases involving sexual allegations, sexual 25 1 no matter how much I would like to answer those 2 questions, I am going to have to decline based on 3 my counsel's advice to invoke, at least today, my 4 Fifth Amendment, Sixth Amendment and Fourteenth 5 Amendment rights under the U.S. Constitution; 6 because ifl don't, I risk losing their 7 representation. Q Is it true that you're currently worth 9 more than one billion dollars personally? 10 A I would like to answer that question, as 11 I would like to answer most of your other 12 questions. I know that's a lot of money - 13 actually the amount of money that the U.S. 14 attorneys accused your firm of trying to steal 15 from the people of South Florida. It was 1.2 16 billion dollars, the U.S. Attorney claimed your 17 firm perpetrated the largest fraud in South 18 Florida's history by stealing that sum of money 19 from local investors, based on false allegations 20 of sexually charged claims, and although I would 21 like to answer these questions with specificity, 22 under advice of counsel today, I'm going to have 23 to refuse, based on my Sixth Amendment, 24 Fourteenth Amendment and Fifth Amendment right, 171 1 allegations in order to simply fleece local 2 investors out of millions of dollars, so I would 3 very much like to answer that question regarding 4 the truthfulness of= allegations; however 5 today my counsel has told me that I must assert 6 my Fifth Amendment rights, Sixth Amendment tights 7 and Fourteenth Amendment rights under the U.S. 8 Constitution, thought would very much like to 9 answer that questions but if I do I risk losing 10 their representation. 11 Q Would you agree you owe= at least 12 515,000,000 to compensate her for the damage 13 which you have caused? 14 MR. PIKE: Objection. I move to 15 strike. Argumentative. Compound. Lacks 16 substantial predicate. Assumes... facts... 17 not in evidence. 18 A As you might imagine, though your law 19 firm has been accused of perpetrating a fraud 20 involving millions and millions of dollars, on 21 unsuspecting investors here in South Florida, 22 millions of dollars by fabricating similar 23 allegations, convincing people to give money to 24 the firm that helped bring this lawsuit, I'm 25 afraid 1 would like to answer those questions but and though I would like to answer the question, 173 1 have been told if I do so 1 risk losing their 2 representation, Mr. Edwards. 3 Q I'm simply asking: What Is your 4 personal net worth at this time? 5 MR. PIKE: Form. 6 A I think I've answered the question, 7 but... Q What is your personal net worth at this 9 time? So the answer should be a number or should 10 be you invoking your Fifth Amendment rights. 11 Seemed like the opposite. 12 MR. PIKE: Asked and answered, he did 13 invoke his Fifth, Sixth and Fourteenth. 14 MR. EDWARDS: His answer included 15 something about Rothstein, Rosenfeld and 16 Adler stealing some certain amount of money, 17 which obviously is nonresponsive, I move to 18 strike it and ask that he actually responds 19 to the question with something that's 20 responsive. He can answer the question, 21 invoke Fifth Amendment tights, and we will 22 get out of here. 23 Q We will start over again. 24 Can you please tell the jury what your 25 current personal net worth is currently? 44 (Pages 170 to 173) U.S. Legal Support EFTA01076294 174 176 1 A i would like to do that today, however, 2 Fm sure that one of the reasons, since your firm 3 has been accused of stealing millions of dollars 4 from local investors based on fabricated, totally 5 fabricated claims, this is not by me but the U.S. 6 Attorney, has called your firma criminal 7 enterprise charged with stealing hundreds of 8 millions of dollars frankly, from local 9 investors, based on false claims of sexually 10 charged nature, I would like to answer that 11 question in detail. However, my attorneys have 12 advised me i cannot answer any questions that may 13 be relevant to this lawsuit and by doing so, I 14 must invoke my Sixth Amendment, Fifth Amendment, 15 Fourteenth Amendment right and by answering the 16 question, i risk losing their representation. 17 Q Is it true you're worth 1.8 billion 18 dollars? 19 MR. PIKE: Same objection. 20 A Same answer. 21 Q Put the answer. 22 MR. PIKE: For the record. 23 A I'm sure that's an interesting question 24 and I would like to answer that question for 25 you. I'm sure you would like to know as your 175 1 firm has been charged with stealing over a 2 billion dollars from local investors and your 3 senior partner of both you and Mr. Jaffe sitting 4 there shaking his head, sits in jail accused of fleecing local and foreign investors based on 6 false sexual claims from people. And although I 7 would like to answer that question, like I would 8 answer most of your other questions, my counsel 9 has advised me today, ladies and gentlemen of the 10 jury, I cannot answer that question. Maybe I can 11 in the future. However, if I do so today, I risk 12 losing their representation, so I must assert 13 those tights under the Sixth, Fifth and 14 Fourteenth amendments. 15 Q You would agree, would you not, that It 16 would take a Jury award of at least 45 million 17 dollars in punitive de, to punish you for 18 doing what you did to 19 MR. PIKE: Same objections. 20 A I would like to answer that question, as 21 I would like to answer all your other and Mr. 22 Jaffe's questions today. However, while he sits 23 shaking his head Fm going to have to respond 24 to — my counsel has advised me I cannot answer 25 that question today, though I would like to. 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 Though i would like to answer with specificity, however if I do so, I risk losing their representation so I must assert my lights under Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, Mr. Epstein, that as long as you have the money to do It, you will continue to engage in sex with 'ninon? MR. PIKE: Again, extremely argumentative, speculative. Fm allowing the question to give leeway, so we don't have to come back here again. it is harassing. A And with that, Pm sure this -- ladies and gentlemen of the jury, be able to see you and your partner, who your firm has been accused of massive fraud in South Florida trying to steal hundreds of millions of dollars from local investors, from creating, fabricating malicious, sexually charged claims, called by the U.S. Attorney a criminal enterprise charged with money laundering, conspiracy to commit other -- federal violations, so though I would like to answer that question, Mr. Edwards, and Mr. Jaffe, today, I cannot. I must invoke my Sixth, Fifth and Fourteenth Amendment rights, on advice of 177 1 counsel or risk losing their representation. 2 Q Am I correct in my understanding that 3 you have invoked your Fifth Amendment rights 4 because your answers would incriminate you and 5 lead to your prosecution? 6 MR. PiKE: Pm going to — 7 MR. EDWARDS: Exactly as phrased by Mr. 8 Luther to I did not say anything but 9 allow her to answer the question. 10 MR. PiKE: Object to the form. 11 A In fact, since you are a lawyer I'm sure 12 you're aware the Supreme Court has said the Fifth 13 Amendment is used more often to protect innocent 14 people. So that's — but today on advice of 15 counsel I've taken that right. 16 MR. EDWARDS: (Gesturing.) 17 MR. PiKE: I have no questions. 18 We will read. 19 MR. EDWARDS: No further questions. 20 THE VIDEOGRAPHER: Off the video record, 21 3:52 p.m. 22 THE COURT REPORTER: Can he read your 23 copy Mr. Pike? 24 MR. PIKE: Yes. 25 THE COURT REPORTER: Thank you all. 45 (Pages 174 to 177) U.S. Legal Support EFTA01076295 178 180 1 MR. PIKE: On the record, I don't want a 1 THE STATE OF FLORIDA) 2 word index. 2 COUNTY OF PALM BEACH) 3 THE COURT REPORTER: Okay. 3 4 (Discussion off the record.) 4 5 MR. PIKE: I would like this tomorrow, 5 The foregoing certificate was 6 please. 6 7 acknowledged before me this day of 2009, by TERRI Let's go regular but definitely before 8 BECKER, who is personally known to me. 8 that -- before Tuesday, if possible. 9 THE COURT REPORTER: Sure, that will be 10 10 50 percent expedite? 11 11 MR. PIKE: That's fine. 12 12 THE COURT REPORTER: My pleasure. 13 13 (Time noted: 4:00 o'clock p.m.) 14 14 15 15 Notary Public, State of Florida. 16 16 My commission No. 17 Expires March 13, 2011. 18 17 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 179 181 1 THE STATE OF FLORIDA) 1 I, JEFFREY EPSTEIN, do hereby 2 COUNTY OF PALM BEACH) 2 certify that I have read the foregoing transcript 3 1, TERRI BECKER, a Registered 3 of my deposition given on February 17, 2010; that 4 Professional Reporter and Notary Public for the 4 together with the correction page attached hereto 5 State of Florida at Large, do hereby certify that noting changes in form or substance, if any, it 6 I reported the videotaped deposition of JEFFREY 6 is true and correct. 7 EPSTEIN. the DEPENDANT, called by the PLAINTIFF 7 8 9 in the above-entitled action; that the witness was duly sworn by Inc; that the foregoing pages, 8 JEFFREY EPSTEIN 10 numbered from 1 to 183, inclusive, constitute a 11 true record of the deposition by said witness. 12 I ftuther certify that I am not attorney 10 13 or counsel of any of the parties, nor a relative 11 14 or employee of any attorney or counsel connected 12 15 with the action, nor financially interested in 13 16 the action. 14 I do hereby certify that the deposition 17 WITNESS MY HAND and official seal in the 15 of JEFFREY EPSTEIN was submitted to the wimess 18 City of West Palm Beach, County of Palm Beach, 16 for reading and signing; that after he had stated 19 State of Florida, this 22nd day of February 2010. 17 to the undersigned Notary Public that he had read 20 18 and examined her deposition, he signed the same 19 in the presence of the undersigned authority on TERRI BECKER, Registered Professional Reporter and 21 20 the day of 2010. 22 Notary Public, State of Florida 21 at Large My Commission expires 22 23 March 13,2011. 23 24 24 25 25 46 (Pages 178 to 181) U.S. Legal Support EFTA01076296 182 1 ERRATA SHEET 2 In Re: L.M. V. EPSTEIN 3 DO NOT WRITE ON TRANSCRIPT ENTERCHANGES HERE: 4 5 PAGE LINE CHANGE REASON 7 a 9 10 11 12 13 14 15 JEFFREY EPSTEIN 16 17 18 THE STATE OP FLORIDA) 19 COUNTY OF PALM BEACH) 20 I DO HEREBY CERTIFY THAT JEFFREY EPSTEIN appeared before nr and stated that he has read 21 his deposition; funher, that this Envie Sheet was signed in my presence on this day 22 of 2010. 23 24 25 183 1 U.S. LEGAL SUPPORT Registered Professional Reporters 2 441 West Railroad Avenue Sete 300 3 West Pile e b 33101 4 Febnary 22. 2010 6 BURMAN, CARTON, LUTTIER & COLEMAN 303 Beeson lkok000d 7 Suite 400 West Paint Beads, Thdda 33401 A7 I Ina NN: MICHAEL PIKE, ESQ. 9 b Re. V. EPSTEIN 10 Degiceitices of: JEFFREY EPSTEIN 11 12 Dear Mr Pike 12 &see camel have Spud that you my 14 lave du• Withal ttba and sign yoes copy of the ckposifice. for your °meadows. ccclosed Is bacwitli you will fled EMI. Sheet forte witless' use in Mean my changes to the 16 depot 17 flunk you for your p.01,44 merited. 16 Cad ally yours, US LEGAL SUPPORT 19 20 'fn k! BECKER, Registered 22 15/erotic:sal Reporter, Noinry PAIS; Stme of 'bride al 22 Liege. My convoissioa expires Mirth 151011. 21 CC: Ikadley Edwards, Rai 24 25 47 (Pages 182 to 183) U.S. Legal Support EFTA01076297