DS9 Document EFTA01083260

1-1 nr 1 fil-13 Pilad (15/2.1F Pa, a fi EXHIBIT 8 EFTA01083260 Case 1:15-cv-07433-RWS Document 161-8 Filed 05/25/16 Page 2 of 6 Pace 1 UNITED S TA1 ES DISTRICT' COURT Page 3 IN TI E CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT SOUTHERN DISTRICT OF FLORIDA 2 IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008C.A02805 I XXXXMB AB CASE NO. 08.CIV40119-MARRA/JOHNSON 3 JANE DOE 573. .1. 4 5 L.M.. Mauna VOLUME I OF II! 6 VOLUME I OP III lEFIREY EPSTEIN. thiencbm 7 JEFFREY EPSTEIN, Datimdant. 9 Related tack 10 041-80231, 08-08380 0640 ig 43-lit)904 11 te-80993, 08-806I I. 0840693. 0940069 12 Vt1.O,OTAPED DEPOSI I ION OP 0940591, 0940656, 0040a02, 0941092 13 14 V1 "SUTTON SITION OF 15 Ortdousday. March 20, 2010 10:37 - 6:51 p.m. 16 Wednesday, March 24. 2010 17 1097 - 6:51 p.m. 18 250 Australian Avaum South Suite 1500 250 Amu:than A‘emit South 19 West Palm Beach. Florida 33401 Suite 1500 20 West Palm !lea.ls. Maki 3340i 21 22 Reported Hy: Cynthia HopIthrs, RPR, FVR Repents! Cynthia I lopkitiss RPR, FPR Neary Public. Slam of Pcmaa 23 No'-try Puhlic.. Stale of Florida Prow Court Reporting SeIVICe3 Prose Cant Roportins: Scniccv 2i Job :46.: 1484 Job No.. 11114 125 Page 2 Page 4 1 IN TIIE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 1 IN THE CIRCUIT COURT OVINE FIFTEENTH JUDICIAL IN AND FOR PALM BEACH COUNTY. FLORIDA Mall 1 IN AND FOR PALM BEACH COUNTY, FLORIDA 2 cssr. NO. 501008CA0211058XXX70.48 AD 2 CASE. No 502008CA037319XXXXMB AB 3 aw. 3 B.& 4 4 Phlan; t you've 101 III 6 VOLCME I OF RI JEFFREY EPSTEIN, 7 JEFitia B AN. Lyelardunt. 9 Defend tuts I) 9 VI FON OF 11 12 VI VIDEOTAPED DWOSON OF 1: 10 13 14 IS 12. Wedavalay, Math ?A, 1010 10 37-651p.m 12 13 14 15 16 Wednesday, March 24, 2010 10 37.6 51p.m 17 250 Australian As owe South Suite 1500 17 250 Australian Avenue Saudi Suite 1500 1$ Wed Palm Ileach, Float 33401 1 Weal Palm Beach, 1 lunda 33401 : 20 2C 21 21 22 Reported By. 22 Reponed By. Cynthia Hopkins. RPR. FPR Cynthia I lopkins, RPR, FPR 23 Notary Pubkc, Sturc of Honda 23 NMary Public, Stateof Florida Prose Court Reporting &rocas Prole Court Reporting Services 24 lob No 1134 24 Mb No.: 1484 2.5 1 (Pages 1 to 4) PROSE COURT REPORTING AGENCY, INC. 01111.1 RI 001671 EFTA01083261 Case 1:15-cv-07433-RWS Document 161-8 Filed 05/25/16 Page 3 of 6 4 S 6 7 B 9 10 11 12 13 14 15 16 17 15 19 20 21 .ss •.•1 Page 21 1 answer the question based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN. Q. Who introduced you to Jeffrey Epstein the first time that you met him? M.R. RIIONIIART: Same instruction. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Did Chislaine Maxwell introduce you to Jeffrey Epstein for the first time? MR. RHEINHART: Same instruction. 'IHE WITNESS: On the instruction of my lawyer.linu.st invoke my Fifth Amendment right. BY MR. RUN/IN. Q. When was the first lime you were in lenity Epstein's home located on El Brillo Way on Palm Beach Island? 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 19 2.0 MR. RHEINHAR Object to the form of the 21 question as compound and assuming facts not 22 23 before the witness. And I instinct the witness 23 24 not to answer based Off her Fifth Amendment 24 25 privilege. 25 Page 22 1 THE WITNESS: On the instruction of my 2 lawyer, I must invoke my Fifth Amendment right. 3 BY MR. KUVIN: 4 Q. Would you agree with me that 5 Jeffrey Epstein owns a home at 358 El Brillo Way, Palm Beach Island. Florida? 7 MR. RHEINHART: Instruct the witness not 8 to answer based on her Fifth Amendment 9 privilege. TIIE WITNESS: On instruction of my I I counsel. I must invoke my Fifth Amendment 2 right. 13 BY MR. KUVIN: 14 Q. Would you agree with me that you've been 15 in Mat home numerous times? 16 MR. RHEINHART: 'Instruct the witness not 17 to answer the question based on her Fifth 18 Amendment privilege. 1.9 THE WITNESS: On instruction of my lawyer, 20 I must invoke my Fifth Amendment right. BY MR. KUVIN: 22 Q. Would you agree with me that you have gone 23 on Jeffrey Epstein's plane numerous times? 7.; MR. RHEINHART: Object to the form. It 25 assumes facts that are not present for the Page 23 witness, and I will instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS. On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that Jeffrey Epstein owns numerous planes, private planes? MR. RHEINHART, Instruct the witness not to answer. TIIE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. And you've been on every one of those private planes; isn't that true? MR. RHEINHART: Object to the form. It Snuffles facts not before the witness, and will instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer. I must ins okc my Fifth Amendment right. BY MR. KUVIN: Q. Ma'am, isn't it true that you've seen the passenger manifest for Jeffrey Epstein's plane? MR. RHEINHART: Object to the form. It Page 24 1 assumes facts that are not established as known 2 to this witness, and I instruct the witness not 3 to answer the question based on her Fifth 4 Amendment privilege. 5 TIIE WITNESS: On the instruction 'army 6 lawyer, I must awoke my Filth Amendment right. MR. KUVIN: Let me show you what we'll mark as Exhibit 2. 9 10 13 12 13 14 15 16 17 18 39 20 21 72 iPlaintift's Exhibit No. 2 was marked tbr identification.) MR. KUVIN: Thank you. MR. RI lEINHART: Do you want to TO.101 IS on it like you did the last time MR KUVIN. No, that's fine. MR. RI lEINHART Take your time. MR. KUVIN: And flip through. BY MR. KUVIN: Q. All right. Ma'am, would you agree with me that this Is a passenger manifest for one of Jeffrey Epstein's airplanes? MR. RHEINHART: Instruct the witness nut 23 to answer the question based on her Fifth 24 Amendment privilege. 25 HIE WITNESS: On the instruction uf my PROSE COURT REPORTING AGENCY, INC, 6 (Pages 21 to 24) (writ) isni076 EFTA01083262 Case 1:15-cv-07433-RWS Document 161-8 Filed 05/25/16 Page 4 of 6 3. 2 3 4 5 7 8 9 10 :2 :3 !4 15 16 17 18 19 20 21 22 23 24 Ptee 271 THE VIDEOORAPHER: We're now on video I 1 record at II:0I a.m. MR. KUVIN: Just for the video record and for the written record Katherine Ezell and Amy Edell have now appeared and are present in person. MR. GOLDBEROEFt: Just one more matter for the record. Jack Goldberger, on behalf of Jeffrey Epstein. Rather than impose a form objection to every question, I think we have reached an agreement that on behalf of Mr. Epstein. I am adopting the form objections that Mr. Rheinhan k making on behalf of his client nuns pro tune to the beginning of this deposition. MR. KUVIN: No objection. MR. GOLDBERGER: Okay. BY MR KUVIN: Q. All right. All right. Ms. M, would you agree with me that there was an agreement between Jeffrey Epstein, Ghislaino Maxwell. Jean-Luc Brunel, yourself and bring in girls from out of slate that were underage? MR. RHEINHART: Object to the form of the 5 question as leading, as compound, and instruct Page 38 the witness not to answer based on her Fifth 2 Amendment privilege. THE WITNESS: On the instruction of my 4 lawyer I must invoke my Fifth Amendment right. BY MR. KUVIN: 6 Q. Would you agree with me that there was an 7 agreement between Jeffiey Epstein, 8 Oltistaint Maxwell, Jean-Luc Brunel, yourself and 9 to bring in girls that were 10 underage from out of state for sexual contact? 11 MR. RHEINHART: Object to the fonn of the 12 question as leading and compound, and I 13 instruct the witness not to answer based on her 1.4 Fifth Amendment privilege. 15 THE. WITNESS: On the instruction of my S lawyer I must invoke my Fifth Amendment privilege. 18 BY MR. KUVIN: 19 Q. All right. Let tne Miow you what we've 20 premarked as Plaintiffs Exhibit 3. Do you 21 recognize this as the passenger manifest for one of Jeffrey Epstein's planes? 21 MR. R14EINHART : I object to the form of 24 the question. It assumes facts that this 5 witness, evidence that this witness has no 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 2.1 22 23 24 25 Page 39 personal knowledge and instruct her not to answer based on her Fifth Amendment privilege. It's also compound. THE WITNESS: On the instruction of my lawyer I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. The witness says that you may not have knowledge or we don't know whether you have knowledge regarding this passenger manifest, so let me ask you, do you have any knowledge about this • passenger manifest? MR. RHEINHART: Object to the form of the question as ambiguous as to this and what a manifest is, and also her knowledge, and I will instruct her not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my • lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Based on the objection, do you know what a manifest is? MR. RHEINFIART: Object to the form of the question as ambiguous and instruct her not to Page 40 1 answer based on her Filth Amendment privilege. 2 THE WITNESS: On the instruction of my 3 lawyer I must invoke my Fifth Amendment right 4 BY MR. KUVIN' 5 Q. I lave you heard the word "manifest" before? 6 MR. RHEINHART: I'll instruct tha witness 7 not to answer based on her Fitth Amendment 8 privilege. 9 THE WITNESS: On the instruction of my 10 lawyer I must invoke my Fifth Amendment right 11 BY MR. KUM: 12 Q. Would you agree with me. ma'am, that you 13 have seen this passenger manifest, listed as 14 Exhibit 3, in the past? 15 MR. RHEINHART: I'll instruct the witness 16 not to answer based on her Fish Amendment 17 18 THE WITNESS: On the instruction of my 19 lawyer I must invoke my Fifth Amendment right. 20 BY MR. KUVIN: 21 Q. Who 22 MR. RHEINHART: I'll instruct the witness 23 not to answer based on her Fifth Amendment 24 privilege. 25 THE WITNESS: On the instruction of my PROSE COURT REPORTING AGENCY, INC. 10 (Pages 37 to 40) 6WHithOthIN EFTA01083263 Case 1:15-cv-07433-RWS Document 161-8 Filed 05/25/16 Page 5 of 6 Page 97 MR. RHEINHART: Seine ins:ruction. 2 THE WITNESS: On the instruction of my 3 lawyer, I must invoke my Fifth Amendment 4 privilege. 5 BY MR. KUVIN: 6 Q. Have you ever worked as a professional 7 model? 8 MR. RHEINIIART: May I consult? 9 MR KUVIN: Sum. 10 MR. RHEINHART: You can answer the 11 question. 12 THE WITNESS: Yes. 13 BY MR. KtIVIbE A Q. When? 15 A. I don't remember. I don't remember the dates. 16 It was at least maybe ten years ago. Q. And you're how old now? 8 MR. RHEINHART: I'll instruct the witness 19 not to answer the question. Nice try. 20 Instruct you not to answer based on 21 your Fifth Amendment privilege. 22 THE WITNESS: On the instruction of my 23 lawyer, I'm going to invoke my Filth Amendment 24 privilege. MR. KUVIN: I'm just trying to find out. Page 'Id 1 MR. RHEINHART: Like I said, good try. 2 Move on. 3 BY MR. KUVIN: 4 Q. With respect to your work as a 5 professional model, what company did you work for? 6 MR. RHEINHART: Instruct the witness not 7 to answer based on the Fifth Amendment 8 privilege. 9 THE WITNESS: On the instruction of my 10 lawyer, I invoke my Fifth Amendment privilege. 11 BY MR. KUVIN: 12 Q. What is your understanding of 13 Mr. Epstein's involvement with the modeling 14 industry? 15 MR. RHEINHART: Standing objection, and 16 instruct the witness not to answer based on 17 Fifth Amendment. on that basis. 3 e THE WITNESS; Upon the instruction of my 19 lawyer. I must awoke my Fifth Amendment 20 privilege. 21 BY MR. KUVIN: 22 Q, Were you ever promised anything regarding 23 your modeling career by Jean-Luc Brunel? 24 MR. RHEINHART: Instruct the witness not 25 to answer based on Fifth Amendment, also Page 99 1 assumes facts that have not been established 2 and it's compound. 3 THE WITNESS: On the instruction of my 4 lawyer, I must invoke my Fifth Amendment 5 privilege. 6 MR. RHEINHART: And to clarify the 7 objection is that it assumes that she's ever 8 met or knows anything about Jean-Luc Brunel. 9 BY MR. KUVIN: 10 Q. Were you eve: promised anything regarding 11 your modeling career by Jeffrey Epstein? 12 MR. RHEINHART. Same objection, instruct 13 the witness not to answer. 14 THE WITNESS: On the instruction of my 1b lawyer, I must invoke my Fifth Amendment 16 privilege. 17 BY MR. KUVIN: 18 Q. You would agree with me that there is a 19 financial arrangement between Jean-Luc Brunel 20 Jeffrey Epstein. do you not? 21 MR. RHEINHART! Objection. It assumes she 22 has any knowledge of either Mr. Epstein or 23 Mr. Brunel, and as to that she is going to 24 invoke her Fifth Amendment privilege. The 25 question is compound and therefore ambiguous. -.— Page 100 1 THE WITNESS: On the instruction of my 2 lawyer, I must invoke my Fifth Amendment ":4 privilege. 4 BY MR. KUVIN: 5 Q. Would you agree with me that Ghislaine Maxwell provides underage girls to Mr. Epstein for sex? MR. RHEINHART: Objection to the form. It assurile‘s she knows anything at all about Ghislaine Maxwell and asks her to assume that she does, and therefore it is compound and ambiguous, and I would instruct her not to answer. THE WITNESS: Upon the instruction of my lawyer, I must invoke my Fifth Amendment privilege. MR. KUVIN: That's a good point. Take a look at what we'll mark as Exhibit H./. (Plaintiffs Exhibit No. 10 was marked for identification.) MR. KUVIN: All me to show it to the camera fist. MR. RHEINHART: Okay. MR. KUVIN: Okay. THE WITNESS: Okay. 6 7 a 10 11, 12 13 14 If. 16 1E' 19 20 21 22 23 24 25 and 25 (Pages 97 to 100) PROSE COURT REPORTING AGENCY, INC. OUNROOM93 EFTA01083264 Case 1:15-cv-07433-RWS Document 161-8 Filed 05/25/16 Page 6 of 6 Page 445 1 reasonably designed to lead to discoverable evidence. 3 Ill' MS. EZELL: 4 Q. Did you facilitate these acts as well as 5 assisting Mr. Epstein in avoiding police detection? 6 MR. REINHART: Same insuuction. 7 BY MS. EZELL: Q. Do you know when and by whom the computers 9 were removed fi OM the Ei Bt illo mansion? 10 MR. REINHART: Objection to the form, lack of foundation. and it also :wanes knowledge of a 12 place known as the El Brillo mansion. So instruct 13 the witness not to answer the question based on the 14 Fifth Amendment. 15 THE WITNESS: At the instruetion of my lawyer, 16 I must invoke my Fifth Amendment right. 1 BY MS. EZELL: 12 O. Was Sane No. 11)3 invited to just came and hang 19 out at the El Brillo mansion? MR. REINHART: Objection to the form. same as 21. the previous question. It assumes knowledge of a 22 place known as the El Brillo mansion and a prawn 21 by the name of lane No. 103. It is compound and lacking in foundation. 23 THE WITNESS. at the instruction of my lawyer. Page 146 I must invoke my Fifth Amendment right. BY MS. EZELL: 3 Q. Have you called any girt.; under the age of IX 4 in Palm Beach or \Vest Palm Beach in the last six years? 5 MR. REINHART : For any purpose? 6 MS EZELL: Yes. 7 THE WITNESS: Can you repeat the question? 9 BY MS. EZELL: Q. Have you called any girls under the age of 18 10 in Palm Beach or West Palm Beach in the last six years? MR. REINHART: You can answer that yes or no. if you know. 13 THE WITNESS: I don't think so. 14 MS. EZELL: I don't have any other questions. 15 Thank you. 1!s THE VIDEOGRAPHF.R; All set? 17 MR. REINHART: Yes. 18 THE VIDEOGRAPHER: This concludes today's 19 vidcvtape dep,asilion of 20 MR. REINHAR T: I told on, I'm sorry. one last 21 thing. Since you're the last defense person or 22 plaintiffs lawyer standing. I guess you wed to 23 advise her she has the right to read or waive on 2.1 the record. 25 MS. EZELL- You do have the right to read this a 9 tl 12 13 14 15 16 17 18 19 20 21 22 23 24 25 gage 147 deposition or you may waive reading and allow the 2 csourt reporter to simply type it up and distribute 3 it to the lawyers who order it 4 Do you choose to read or waive? 5 THE WITNESS: Waive. 6 MS. EZELL: Thank you. 7 MR. REINHART: Thank you. THE VIDEOGRAPHER: Okay, this concludes tudivls videotape deposition o The ture is 18:51. (Witness excused.) (Deposition was concluded.) rage 4'.8 1 CLIt1 1IIE S1.vft.Op FLORIDA 3 CANTY OF PALM BEACH 4 5 I, Rachel W. Bridge, Registera.1 Professional Reporter. Honda Protlasioral Reporter and Notary 6 Public ut sod for the State Of Florida at law, de batty catiN Out I was allowed to nag did ropCol .ad deposition in gloomy. and that the Rwegant pages mane and coned transcription of my shorthand notes of said deposibrin. 9 I Maher atity that tad &roma cos nken at the tone and place heraneborc set bah and IR Ma the taltion af sant depositor vu conimented and anpleted w horemateas on out l further orally that t ant era attorney or coonacl of any of the parties, nos 4113 I a idolise or tirolfocc of an) attorney w wand of party connected nab to action, nor an I financially mlereetal m the Wien. 11 13 :4 the foregang affiliation of this Mutsu c4 15 does not apply to any reprodeohon of the same by any mcma unba under the direct coning andror direction 14.; of the allaying reporter. 17 Dated tint 9th day of April, 18 20 21 22 Z sa ::5 an. e6tiatnR - rid 21 (Pages 445 to 443) FROSE COURT REPORT:NG AGENCY, INC. Electronically signed by Rachel Bridge (2014724174827) 905d1499.0cd8-4599-a2a0.6d3.8827668c6 unit i RI 'A'GO.- EFTA01083265