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Page 172 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No. Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. CONTINUED DEPOSITION OF JEFFREY EPSTEIN VOLUME III Thursday, October 8, 2009 1:46 - 3:48 p.m. 250 South Australian Avenue Suite 1400 West Palm Beach/ Florida 33401 Reported By: Jeana Ricciuti, RPR, FPR, CLR Notary Public, State of Florida Prose Court Reporting Agency, Inc. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Joann Moduli WMMMAIO-496c-aVW099977073134 EFTA01087055 1' ..:4c 17j Page 175 70 21 22 23 21 25 APPE3tRANC FS 2 On behaifotthe Mania SPENCER T. KUYIN, ESQUIRE 3 ADANILANOINO, ESQUIRE LEOPORD KUV1N, PA 4 2193 POA Manna Sufis 200 Palm Florida 33410 6 Salta tad ■ and Iwo Doe In Coo No. 1 CARA I. 110131FS, FSQUIRR 8 ROTHSTEIN, ROSEMEIDT CADLPIC 401 Paµ Las Olaf Boenzad 9 Suite 1440 fat 33301 10 Phone air P near /one Doe la Case WIN and wr THERINII W. 2 MERL, ESQUIRE PODHURSTORSECR. PA • 3 21 Weµ HaslerSerett Hone: S On behalf of the Defendant. TACK CrOLDBEROUR, AI FOAL' :6 STORY ROM FS, PARAI FOAL Al'1 E RBI IRV. 601.1aUEK(it 441; MS, P 250 Sac* Augrolien Avenue Sway 1120 Wne Palialinkla 33401 /Sone: MICHAEL!. Ha ESQUIRE BURMAN, aurrotc.T.U1TXRA COLEMAN, P 303 Beam houleverd Sake 400 Wert P 3 a 33101 hone. ALSO P DAN DOM( RY, VIDLOORAP2IER VISUAL EVIDISNCE,IXC. 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 PROCEEDINGS THE VIDEOGRAPHER: We're back on the record at 1:46. CONTINUED DIRECT EXAMINATION BY MR. KUVIN: Q. Do you personally know John Mack, former CEO al Morgan Stanley? A. I'll have to answer that the same way I've answered most of your questions here today, Mr. Kuvin, NyhIch is, I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my Gth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Ccestitution. MR. KUVIN: Okay. Same deposition as shown before, different clip. I'm going to play it for counsel first. MR. PIKE: 'thank you. MR. KUVIN: Mr. V ideowapher, just let me know when you're ready. 1 2 3 4 6 8 9 - - - EXHIBITS - • • WITNESS: CONEDDIRECT JEFFREY EPSTEIN BY MR. KUVIN 175 EXHIBITS Page 174 10 NUMBER DESCRIPTION PAGI 11 PLAINTIFFS EX. 9 PHOTOGRAPH OF GHISLA1NE 182 MAXWELL 12 PLAINTIFFS FM 10 PHOTOGRAPH OF 191 . 13 PLAINTWFS 1 PHOTOORAPHOF 196 PIAINTWFS EX. 12 PHOTOGRAPH 19 PLAINTIFFS EX 13 PHOTOGRAPH OF 199 PIAINT1FFS RAPH OF 15 16 PLAINTIFFS EX 16 PHOTOGRAPH OF • PtAtbnifFs E .Is PH RAPE! OF 201 111.11 ANDREW 17 PLAINTIFFS EX. 17 LETTERTOB. KRISCHER FROM 203 M. REITER 18 PLAINTIFFSEX. IS RECEIPT OF PURCHASES MADE 206 FROM JAIL 19 PLAINTIFFS EX. 19 FAA REGISTRY 218 20 21 22 23 24 25 Page 176 THE VIDEOGRAPHER: Whenever you are. 2 MR. KUVIN: Okay. 3 (Video played.) 4 VIDEO WITNESS: "What did I do to Jeffrey and 5 what did Jeffrey do to me? I went up there 6 multiple times; I can't count. And I would be on a 7 massage table, massaging his legs, he would turn 8 over, his penis would be hanging out. He would put 9 a vagina -- or a vibrator to my vagina, lie would 10 touch my vagina with his fingers. He would touch 11 my breasts. He would try to kiss my mouth. He 12 would bring my hands toward his penis." 13 (Video stopped.) 14 MR. KUVIN: Okay. MIL PIKE: I'm just going to object to the use 16 of the video as to relevance, predicate and 17 foundation. 18 BY MR- KUVIN: 19 Q. All right. Let me get it back to the same 20 location, 21 Sir, first of all, once again, just sol can 22 lay the foundation for this, do you recognize this girl? 23 A. I'm going to have to respond to that question 24 the same way I've responded to most of your other 25 questions hero today, which is, I intend to respond to 2 (Pages 173 to 176) PROSE COURT REPORTING AGENCY, INC. • Electronically signed by Jeana Ricciuti - - Electronically signed by Jeana Ricclutl bleclerlf0410498e4244•099977073134 EFTA01087056 Page 177 1. all relevant cannot provide answers to any questions 2 relevant to this lawsuit; however, at the present time, 3 my attorneys have counseled me I cannot provide answers 4 to any questions relevant to the lawsuit. I must accept this advice or risk losing my 6th Amendment right to 6 effective representation. Accordingly, I assert my 7 federal constitutional rights as guaranteed by the 5th, 8 6th and 14th Amendment to the United States 9 Constitution. 10 Q. Did this girl brings to your home for a 11 naked massage? 12 A. Pm going to have to respond to that the same 13 way I've responded to most of your other questions here 14 today, which Is, I Intend to respond to all relevant 15 questions regarding this lawsuit; however, at the 16 present time, my attorneys have counseled me I cannot 17 provide answers to any questions that may be relevant to 18 the lawsuit. I must accept this advice or risk losing 19 my 6th Amendment right to effective representation. 20 Accordingly, I assert my federal constitutional rights 21 as guaranteed by the 5th, 6th end 14th Amendment to the 22 United States Constitution. 23 Q. I'd like to play this clip for you and then 24 Pm going to ask you a question. 25 MR. PIKE: The same clip you just played? Page 179 1 the United States Constitution. 2 BY MR. KUVIN: 3 Q. Did you do what that young lad d e s c r i b e d just 4 now to hundreds of women, including M . ? 5 MR. PIKE: Form, argumentative, harassing, 6 lacks appropriate predicate, foundation, lacks identity. 8 THE WITNESS: Excuse me. Pm going to respond 9 to that the same way I've responded to most of your 10 other questions here today, which is, I intend to 11 respond to all relevant questions regarding this 12 lawsuit; however, at the present time, my attorneys 13 have counseled me that I cannot provide answers to 14 any questions relevant to the lawsuit. I must 15 accept their advice or risk losing my 6th Amendment 16 right to effective representation. Accordingly, I 17 must assert my federal constitutional rights as 18 guaranteed by the 5th, 6th and 14th Amendment to 19 the United States Constitution. 20 BY MR. KUVIN: 21 Q. While. was standing naked in your home, 22 specifically in your bathroom, did you tell her that you 23 could get her an interview as a model because of your 24 connections? 25 A. I'm going respond to that the same way I've Page 178 1 MR. KUVIN: Exactly. 2 MR. PIKE: Same objection. 3 (Video played.) 4 VIDEO WITNESS: "What did I do to Jeffrey and 5 what did Jeffrey do to me? I went out there 6 multiple times; I can't count. And I would be on a 7 massage table, massaging his legs. Ho would turn 8 over, his penis would be hanging out. He would put 9 a vagina -- or vibrator to my vagina. He would 10 touch my vagina with his fingers. He would touch 11 my breasts. He would try to kiss my mouth. He 12 would bring my hands toward his penis." 13 (Video stopped.) 14 BY MR. KUVIN: 15 Q. Did you do that with that girl? 16 MR. PIKE: Fenn. 17 THE WITNESS: I intend to respond to all 18 relevant questions regarding this lawsuit; however, 19 at the present time, my attorneys have counseled me 20 I cannot provide answers to any questions that may 21 be relevant to this lawsuit. I must accept this 22 advice or risk losing my 6th Amendment right to 23 effective representation. Accordingly, I must 24 assert my federal constitutional rights as 25 guaranteed by the 5th, 6th and 14th Amendment 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 Page 180 responded to most of your questions today, Spencer. I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions that may be relevant to the lawsuit. I must accept this advice or risk losing my Gth Amendment right to effective representation. Accordingly, I must assert my federal constitutional right as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. MR. PIKE: Same objection to that line of questioning. BY MR. KUVIN: Q. As. was standing naked in your bathroom before you when she was 15, did you ask her to turn around so you could see her ass better? MR. PIKE: Form, argumentative, harassing. lacks appropriate predicate, foundation. THE WITNESS: ri1 respond to that as I responded to your last question, which is, I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions that may be relevant to this lawsuit. I must accept their advice or risk losing my 6th 3 (Pages 177 to 180) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana RIccluti bl8d9df0-4fcb-496c-a244-099977073134 EFTA01087057 Page 181 1 Amendment right to effective representation; 2 therefore, I must assert my federal constitutional 3 rights as guaranteed by the 5th, 6th and 14th 4 Amendment to the United States Constitution. 5 BY MR. KUVIN: 6 Q. When M. was 15 years old and standing naked 7 in front of you in your bathroom, did you tell her that 8 you could help her become a model? 9 MR. PIKE: Same objections, including 10 foundation. 11 THE WITNESS: Is it different than the last 12 question? 13 MR. KUVIN: Uh-huh. 14 MR. GOLDBEftGER: Just go ahead. 15 THE WITNESS: Okay. I intend to respond to 16 all relevant questions pertaining to this lawsuit; 17 however, at the present time, my attorneys have 18 counseled me I cannot provide answers to any 19 questions that may be relevant to this lawsuit, so 20 I've answered most questions here today the same 21 way. I must expect that - accept their advice or 22 risk losing my 6th Amendment right to effective 23 representation. Accordingly, I assert my federal 24 constitutional rights as guaranteed by the 5th, Gth 25 and 14th Amendment to the United Slates Page 183 1 Q. And her father is Robert Maxwell? 2 A. Was Robert Maxwell. 3 Q. Pm sorry, he's passed, correct? 4 A. Correct. 5 Q. She is a close friend of yours, is she not? 6 A. Fm going to respond to that question the same 7 way I've responded to most of your other questions here 8 today, Mr. Kuvin, which is, I intend to respond to all 9 relevant questions regarding to this lawsuit; however, 10 at the present time, my attorneys have counseled me I 11 cannot provide answers to any questions that may be 12 relevant to this lawsuit. I must expect — accept their 13 advice or risk losing my 6th Amendment right to 14 effective representation. Accordingly, I must assert my 15 federal constitutional rights as guaranteed by the 5th, 16 6th and 14th Amendment to the United States 17 Constitution. 18 Q. Ghisluine Maxwell has accompanied you to 19 numerous social events in the last few years; isn't that 20 true? 21 MR. PIKE: Form. 22 THE WITNESS: I'm going to respond to that 23 question the same way I've responded to most of 24 your questions here today, which is, I intend to 25 respond to all relevant questions regarding your Page 1.87 1 Constitution. 2 BY MR. KUVIN: 3 Q. Who is GhIslaine Maxwell? 4 A. I intend to respond to all relevant questions 5 regarding this lawsuit; however, at the present time, my attorneys have counseled me that I cannot provide 7 answers to any questions relevant to this lawsuit. As I 8 have done to most of your other questions here today, I 9 must accept their advice or risk losing my 6th Amendment 10 right to effective representation. Accordingly, I 11 assert my federal constitutional rights as guaranteed by 12 the 5th, 6th and 14th Amendment to the United States 13 Constitution. 14 MR. KUVIN: Let me show the camera what we'll 15 mark as Exhibit 9 to this deposition. 16 THE VIDEOGRAPI-IER: Okay. 17 (Plaintiffs Exhibit No.9 was marked for 18 identification.) 19 BY MR. KUVIN: 20 Q. Let me show you what we've marked as Exhibit 9 21 to your deposition. Do you recognize Ghislaine Maxwell 22 in this photograph? 23 A. Yes. 24 Q. And who is she standing with? 25 A. Her father. Page 184 1 lawsuit; however, at the present time, my attorneys 2 have counseled me I cannot provide answers to any 3 questions that may be relevant to that lawsuit. I 4 must accept their advice or risk losing my 6th 5 Amendment right to effective representation. 6 Accordingly, I must assert my federal 7 constitutional right as guaranteed by the 5th, 6th 8 and 14th Amendment of the United States 9 Constitution. 10 BY MR. KUVIN: 11 Q. One of your houseboys that has been deposed in 12 this case testified that you were a rather nice 13 gentleman that used to talk to the staff, and that when 14 Ms. Maxwell came into the picture, that you stopped 15 talking to the staff and the staff had to communicate 16 through Ms. Maxwell. Do you agree or disagree with 17 that? 18 MR. PIKE: Form, foundation, predicate, 19 argumentative, assumes facts not in evidence. 20 THE WITNESS: I'm going to answer that the 21 same way I've answered most of your questions here 22 today, which is, I intend to respond to all 23 relevant questions regarding this lawsuit; however, 24 at the present time, my attorneys have counseled me 25 that I cannot provide answers to any questions that 4 (Pages 181 to 184} PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Rican' (601-280.428.9381) Electronically signed by Jeana Flicciutl (601.280-428.9381) bf8d9O0-4(cb-496c-a244-09997 7073134 EFTA01087058 Pogo 1 may be relevant to your lawsuit. I must accept 2 their advice or risk losing my 6th Amendment right 3 to effective representation. Accordingly, I assert 4 my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment of the United 6 States Constitution. 7 BY MR. KUVIN: 8 Q. Ho also testified that he felt you were a 9 rather nomad guy until Ms. Maxwell came into the 10 picture, and that she led you into this life of 11 perversion, sexual perversion. Do you agree with that? 12 MR. PIKE: Same objections. 13 THE WITNESS: I'm going to respond to that the 14 same way I've responded to most of your questions 15 hem today, Mr. Kuvin, which is, I intend to 16 respond to all relevant questions regarding this 17 lawsuit; however, at the present time, my attorneys 18 have counseled me 1 cannot provide answers to any 19 questions relevant to this lawsuit. I must accept 20 their advice or risk losing my 6th Amendment -- 21 excuse me -- I must accept their advice or risk 22 losing my 6th Amendment right to effective 23 representation. Accordingly, I must assert my 24 federal constitutional rights as guaranteed by the 25 5th, 6th and 14th Amendment to the United States 1 3 4 5 6 1 0 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 187 to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to that lawsuit. I must accept their advice or risk losing my Gth Amendment right to effective representation. Therefore, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United Stales Constitution. BY MR. KUVIN: Q. Do you know where Donald Trump's Maralago estate is? A. Yes. Q. Have you been there? A. Yes. Q. Who with? A. Pm going to have to answer that question the same way I've answered most of your other questions here today. I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled molcannot provide answers to any questions that may be relevant to the same lawsuit. I must accept their advice or risk losing my 6th Amendment right to effective representation. Accordingly, I must assert my federal constitutional Page 186 1 Constitution. 2 BY MR. KUVIN: 3 Q. Did Ms. Maxwell procure underaged girls for you to have sexual relationships with? 5 A. I'm going to answer that question the same way 6 I've answered most of your other questions today, 7 Mr. Kuvin, which is, I intend to respond to all relevant 8 questions regarding this lawsuit; however, at the 9 present time, my attorneys have counseled me I cannot 10 provide answers to any questions relevant to that 11 lawsuit. Excuse me. I must accept their advice or risk 12 losing my 6th Amendment right to effective 13 representation. Accordingly, I must assert my federal 14 constitutional rights as guaranteed -- guaranteed by the 15 5th, 6th and 14th Amendments to the United States 16 Constitution. 17 Q. Ms. Maxwell procured a particular underaged 18 girl who worked at Donald Trump's Maralago, for you to 19 have a sexual relationship with; isn't that true? 20 MR. PIKE: Form, argumentative, lacks 21 appropriate predicate, foundation, assumes facts 22 not in evidence. 23 THE WITNESS: I'm going to respond to that the 24 same way I've responded to most of your other 25 questions hero today, Mr. Kuvin, which is, I intend Page 188 1 rights as guaranteed by the 5th, 6th and 14th Amendment 2 to the United States Constitution. 3 Q. Have you seen the high school transcripts 4 grades of girls that you have had sexual relationships 5 with dating back to 2005? 6 MR. PIKE: Form, relevance, improper 7 hypothetical, lacks facts -- assumes facts not in 8 evidence, lacks appropriate predicate, foundation. 9 THE WITNESS: I'm going to answer that 10 question the same as I've answered most of your 11 other questions here today, Mr. Kuvin, which is, I 12 intend to respond to all relevant questions 13 regarding this lawsuit; however, at the present 14 time, my attorneys have counseled me that I cannot 15 provide answers to any questions that may be 16 relevant to this lawsuit. I must accept their 17 advice or risk losing my 6th Amendment right to 18 effective representation. Accordingly, I assert my 19 federal constitutional rights as guaranteed by the 20 5th, 6th and 14th Amendment to the United States 21 Constitution. 22 BY MR. KUVIN: 23 Q. Do you deny that the high school transcripts 24 which were found in your trash on Palm Beach that showed 25 the ages of some of the girls you were engaged with 5 (Pages 185 to 188) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana Ricciuti bted9df OA( cb-496c-a244-099977073134 EFTA01087059 Page 189 sexual ads with at your home dune from your house? 2 MR. PUCE: Same objection in addition to 3 argumentative and harassing. 4 THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit; however, 6 as I've done with most of your other questions today, at the present time my attorneys have 8 counseled me that I cannot provide answers to any 9 of those questions relevant to this lawsuit. I 10 must accept their advice or risk losing my 6th 11 Amendment right to effective representation. 12 Accordingly, I must used my federal 13 constitutional rights as guaranteed by the 5th, 6th 14 and 14th Amendments to the United States 15 Constitution. 16 BY MR. KUVIN: 17 Q. Did you have numerous photos of nude young 18 women, girls under the ago of 18, back in your home 19 in -- on Palm Beach Island in 2005 and 2006? 20 A. I'm going to have to respond to that question 21 tho same way I've responded to most of your questions 22 here today, which is, I intend to respond to all 23 relevant questions regarding this lawsuit; however, at 24 the present time, my attorneys have counseled 'no I 25 cannot provide answers to any questions relevant to the Page 191 1 MR. GOLDBERGER: Break time? 2 MR. KUVIN: No, not again. Please not. 3 lust let us know when you're good to go. 4 THE VIDEOGRAPHER: Were back on the record at 5 2:04. This will be the beginning of tape No. 3. 6 BY MR. KUVIN: 7 Q. Do you have security cameras throughout your 8 home on Palm Beach Island? 9 A. I'm going to answer that question the same way 10 I've answered most of your questions here today, 11 Mt Kuvin. I intend to respond to all relevant 12 questions regarding this lawsuit; however, at the 13 present time, my attorneys have counseled me I cannot 14 provide answers to any questions relevant to the 15 lawsuit I must accept their advice or risk losing my 16 6th Amendment right to effective representation. 17 Accordingly, I assert my federal constitutional rights 18 as guaranteed by the 5th, 6th and 14th Amendment to the 19 United States Constitution. 20 (Plaintiffs Exhibit No. 10 was marked for 21 identification.) 22 MR. KU VIN: ru show the camera a photograph 23 here. Okay? 24 THE VIDEOGRAPHER: LIR it up. Yeah, there 25 you go. Okay. Page 190 1 same lawsuit. I must accept their advice or risk losing 2 my 6th Amendment right to effective representation. Accordingly, I must assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment. Q. Did you have photographs of girls under the 6 ago of ten who were nude, either partially or fully 7 nude, in your home on Palm Beach in 2005 and 2006? 8 MR. PIKE: Fenn. 9 THE WITNESS: I'm going to respond to that 10 question the same way I've responded to most of' 11 your other questions, which is, I intend to respond 12 to all relevant questions regarding this lawsuit; 13 however, at the present time, my attorneys have 14 counseled me I cannot provide answers to any 15 questions relevant to this lawsuit. I must accept 16 this advice or risk losing my 6th Amendment right 17 to effective representation. Accordingly, I assert 18 my federal constitutional rights as guaranteed by 19 the 5th, 6th and 14th Amendments of the United 20 States Constitution. 21 THE VIDEOGRAPHER: Mr. Kuvin, fin sorry I have 22 to change. 23 MR. KUVIN: Go ahead 24 THE VIDEOGRAPHER: well go off the record at 25 2:03. This will be the end of tape No.2. Page 192 - 1 MR. KUVIN: Okay? 2 BY MR. KUVIN: 3 Q. Let me show you what we marked as Plaintiffs 4 Exhibit 10. Do you recognize this young lady? 5 A. Yes. 6 Q. Who is sho? 7 A. Her name is 8 Q. And who is she? 9 A. I just -- her name is 10 Q. How do you recognize her? 11 A. I don't understand the question. 12 Q. Well, is she a friend of yours? Did she work 13 for you? Flow do you recognize her? 14 A. How do I recognize her? 15 Well, I'd like to respond to that question 16 but, however, my attorneys have told me that I can't 17 respond to any questions today that may -- excuse me. I 18 intend to respond to all relevant questions regarding 19 this lawsuit; however, at the present time, my attorneys 20 have counseled mo that I cannot provide answers to any 21 questions relevant to this lawsuit. I must accept their 22 advice or risk losing my 6th Amendment right to 23 effective representation. Accordingly, I assert my 24 federal constitutional rights as guaranteed by the 5th, 25 Gth and 14th Amendment to the United States (phonetic). 6 (Pages 189 to 192) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Rletiutl Electronically signed by Jeana Riccardi bf8d9tlf041cb-496c-a244-09997 7073134 EFTA01087060 Page 191 1 Constitution. 2 Q. Did you have sex with 3 A. I'm going to answer that question like I've 4 answered most of your questions here today, which is, 1 5 intend to respond to all relevant questions regarding 6 this lawsuit; however, at the present time, my attorneys 7 have counseled me I cannot provide answers to any 8 questions relevant to this lawsuit. I must accept their 9 advice or risk losing my 6th Amendment right to 10 effective representation. Accordingly, I assert my 11 federal constitutional rights as guaranteed by the 5th, 12 6th and 14th Amendment to the United States 13 Constitution. 14 Q. When did you first meet Prince Andrew? 15 And let mo make it a compound question so I 16 don't have to repeat it over and over. When did you 17 first meet Prince Andrew, under what conditions did you 18 meet him, and who was present at that list meeting? 19 A. I'm going to answer that question as I've done 20 most of your questions here today, Mr. Kuvin, which is, 21 I intend to respond to all relevant questions regarding 22 this lawsuit; however, at the present time, my attorneys 23 have counseled met cannot provide answers to any 24 questions relevant to that lawsuit. I must accept their 25 advice or risk losing my 6th Amendment right to IM? Page 195 1 THE WITNESS: Pm going to respond to that 2 question the same way I've responded to most of 3 your questions here today, Mr. Kuvin, which is, I 4 intend to respond to all relevant questions 5 regarding this lawsuit -- excuse me, however, at 6 the present time, my attorneys have counseled me I 7 cannot provide answers to any questions relevant to 8 the lawsuit, or might be relevant to the lawsuit. 9 I must accept their advice or risk losing my 6th 10 Amendment right to effective representation. 11 Accordingly, I assert my federal constitutional 12 rights as guaranteed by the 5th, 6th and 14th 13 Amendment of the United States Constitution. 14 BY MR. KUVIN: 15 Q. Did you fly with Prince Andrew on your plane, 16 or planes, with any underaged girls, girls under the age 17 of18? 18 A. I'm going to answer that question the same way 19 I've answered all the other questions here today, 20 virtually, which is, I intend to respond to all relevant 21 questions regarding this lawsuit; however, at the 22 present time, my attorneys have counseled me I cannot 23 provide answers to any questions relevant to the 24 lawsuit. I must accept their advice or risk losing my 25 6th Amendment right to effective representation. Page 194 1 effective representation. Accordingly, I must assert my 2 federal constitutional rights as guaranteed by the 5th, 3 6th and 14th Amendment to the United States 4 Constitution. 5 Mk PIKE: In addition, relevance. 6 BY MR. KUVIN: 7 Q. Do you pay Ms. Maxwell a salary? 8 MR. PIKE: Form. 9 BY MR. KUVIN: 10 Q. Ohislaine Maxwell, so we're clear. Do you pay 11 her a salary? 12 A. I'd like -- excuse me. I'm going to answer 13 that question the same way I've answered most of your 14 questions here today, which is, I intend to answer all 15 questions relevant to this lawsuit; however, at the 16 present time, my attorneys have counseled me I cannot 17 provide answers to any questions relevant to this 18 lawsuit. I must accept their advice or risk losing my 19 6th Amendment right to effective representation. 20 Accordingly, I assert my federal constitutional rights 21 as guaranteed by the 5th, 6th and 14th Amendment to the 22 United States Constitution. 23 Q. Did you provide any underaged girls for sex to 24 Prince Andrew? 25 MR. PIKE: FO1111 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 Page 196 Accordingly, I must assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. Q. Do you 'mow MR. KUVIN: For the court reporter, it's THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit; however, at the present thne, my attorneys have counseled me I cannot provide answers to any questions relevant to the lawsuit. I must accept this advice or risk losing my 61h Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. MR. KUVIN: Let me show the camera what we'll mark as Exhibit II. (Plaintiffs Exhibit No. 11 was marked for identification.) THE VIDEOORAPHER: Okay. MR. KUVIN: Okay? BY MR. KUVIN: Q. In Exhibit 11, sir, you're standing with a woman. Who Is that woman in that photograph? (.1) 832-7500 7 (Pages 193 to 196) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Juana Ricciuti Electronically signed by Arena RIcciull 618d9dt04tcb-496c-a240-098977073134 EFTA01087061 Page 1 9 / 1 A. (phonetic). 2 Q. Where were you? 3 A. I intend to respond to all relevant questions 4 regarding this lawsuit; however, at the present time, my attorneys have counseled me Icannot provide answers to 6 any questions that may be relevant to this lawsuit. I must accept this advice or risk losing my 6th Amendment 8 right to effective representation. Accordingly, I must 9 assert my federal constitutional rights as guaranteed by 10 the 5th, 6th and 14th Amendments to the United States 11 Constitution. 12 MR. KUVIN: And just so the court reporter 13 knows, Ghislaine is spelled G-H-I-S-L-A-I-N-E. 14 BY MR. KUVIN: 15 Q. Who is ,excirse 16 me? 17 A. I'm going to answer that question the same way 18 I've answered most of your questions here today, which 19 is, I intend to respond to all relevant questions 20 regarding this lawsuit; however, at the present time, my 21 attorneys have counseled me I cannot provide answers to 22 any questions relevant to the lawsuit. I must accept 23 their advice or risk losing my 6th Amendment right to 24 effective representation. Excuse me. Accordingly, I 25 must assert my federal constitutional rights as 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 199 A. I intend to respond to all relevant questions regarding this lawsuit; however, as I've done to most of the questions at the present time, my attorneys have counseled me that I cannot provide answers to any of' those questions that may be relevant to the lawsuit. I must accept this advice or risk losing my Gth Amendment right to effective representation. Accordingly, asset my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments of the United States Constitution. BY MR. KUVIN: Q. Fin going to show you what we'll mark as Exhibit 13. Let me show it to the camera, first. (Plaintiffs Exhibit No. 13 was marked for identification.) BY MR. KUVIN: Q. Sir, is It true that Exhibit 13 shows your personal assistant, 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 that may be relevant to this lawsuit. I must accept their advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights Page 198 1 guarantee -- guaranteed by the 5th, 6th and 14th 2 Amendment tote United States Constitution. 3 (Plaintiffs Exhibit No. 12 was marked for ,1 identification.) 5 MR. KUVIN: Let me show to the camera what 6 we've marked as Exhibit 12. 7 BY MR. KUVIN: 8 Q. Let me show you what I've marked as Exhibit 9 12. Do you recognize any of the girls in that 10 photograph? 11 A. I'm going to answer that question the same way 12 I've answered most of your other questions here today, 13 Mr. Kuvin, which is, I intend to respond to all relevant 14 questions regarding this lawsuit; however, at the 15 present time, my attorneys have counseled me that 1 16 cannot provide answers to any questions that may be 17 relevant to the lawsuit. I must accept their advice or 18 risk losing my 6th Amendment right to effective 19 representation. Accordingly, I assert my federal 20 constitutional rights as guaranteed by the 5th, 6th and 21 14th Amendment to the United States Constitution. 22 Q. Sir, isn't it true that in what we've marked 23 as Plaintiff's Exhibit 12 the blond standing on the 24 left is and the blonde, dirty blonde 25 standing on the right is Page 200 1 as guaranteed by the 5th, 6th and 14th Amendment to the 2 United States Constitution. 3 Q. Let me show you what we'll mark as Exhibit 14. 4 (Plaintiffs Exhibit No. 14 was marked for 5 identification.) 6 BY MR. KUVIN: 7 Q. Sir, does Exhibit 14 show --,a 8 girl that you have had a sexual relationship with since 9 before she was 18 years old? 10 MR. PIKE: Fenn, argumentative, harassing, 11 assumes facts not in evidence, lacks appropriate 12 . predicate and foundation. 13 THE WITNESS: I intend to respond to all 14 relevant questions regarding this lawsuit; however, 15 at the present time, my attorneys have counseled me 16 I cannot provide answers to any questions relevant 17 to this lawsuit. I must accept their advice or 18 risk losing my 6th Amendment right to effective 19 representation. Accordingly, I assert my federal 20 • constitutional rights as guaranteed by the 5th, 6th 21 and 14th Amendment to the United States 22 Constitution. 23 BY MIL KUVIN: 24 Q. I'm going to show the camera what we'll mark 25 as Exhibit 15. 8 (Pages 197 to 200) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RIcchal Electronically signed by Jeana RIcclutl bred9W0-4fcb-496c-a244-099977073134 EFTA01087062 Page 201 (Plaintiffs Exhibit No. IS was marked for 2 identification.) 3 BY MR. KUVIN: 4 Q. Sir, does Exhibit I5 show S an 5 underaged girl that you were utilizing back in 2005 and 6 2006 to procure other underaged girls for sex and sexual / contact at your home? 8 MR. PIKE: Same objections to Exhibit 15 as 9 were made to Exhibit 14. 10 THE WITNESS: I'm going to answer that the 11 same way I've answered most of your questions here 12 today, Mr. Kuvin, which is, I intend to respond to 13 all relevant questions regarding this lawsuit; 14 however, at the present time, my attorneys have 15 counseled me that I cannot provide answers to any 16 questions that may be relevant to the lawsuit. 17 must accept their advice or risk losing my 6th 18 Amendment right to effective representation. 19 Accordingly, I am going to assert my federal 20 constitutional rights as guaranteed by the 5th, 6th 21 and 14th Amendments to the United States 22 Constitution. 23 (Plaintiffs Exhibit No. 16 was marked for 24 identification.) 25 MR. KUVIN: Let me show the camera what we've Page 203 1 cannot provide answers to any questions relevant to this 2 lawsuit. I must accept their advice or risk losing my 3 6th Amendment right to effective representation. 4 Accordingly, I assert my federal constitutional rights 5 as guaranteed by the 5th, 6th and 14th Amendment to the 6 United States Constitution. 7 Q. I'm going to show you a document that we'll 8 mark as Exhibit 17. 9 MR. PIKE: Thank you. 10 (Plaintiffs Exhibit No. 17 was marked for 11 identification.) 12 BY MR. KUVIN: 13 Q. I'm going to give you a minute to take a look 14 at that document and just tell inc when you're ready to 15 answer any questions about it. 16 A. Okay. 17 Q. Okay. First of all, have you seen this letter 18 before? 19 MR. GOLDBERGER: Attorney-client privilege, 20 work product. 21 BY MR. KUVIN: 22 Q. Have you seen this letter before outside of 23 the relationship with your attorneys? 24 MR. GOLDBERGER: You can answer that question. 25 THE WITNESS: No. 2 3 4 5 6 7 8 9 1.0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 202 marked as Exhibit 16. BY MR. KUVIN: Q. Do you recognize the ganleman in that photograph, MR. PIKE: Hold on for a second. MR. GOLDBERGER: Do you want to discuss it with me? MR. PIKE: Let's take a break for one minute. MR. KUVIN: All right. THE VIDEOGRAPHER: Off the record at 2:16. (A brief recess was taken.) THE VIDEOGRAPHER: We're back on the record at 2:45. BY MR. KUVIN: Q. Okay. Do you recognize the person that's shown in Exhibit 16? A. Yes. Q. Who is that? A. Prince Andrew. Q. And how do you know Prince Andrew? A. I'm going to have to respond to that question the same way I've responded to most of your questions here today, Mr. Kuvin, which is, [intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I Page 204 1 BY MR. KUVIN: 2 Q. Do you know Chief of Police Michael Reiter? 3 Do you know who he is? 4 A. I know who he is. Q. Do you know State Attorney Bony Krischer? 6 A. I know who he is. 7 Q. Did you ever speak with Chief of Police 8 Michael Reiter in the past? 9 A. I don't remember. 10 Q. Did you ever talk to anyone, either at the 11 State Attorney's office, yourself, or Michael Reiter 12 about the prosecution of yotir claim without the presence 13 of your attorneys? 14 A. No. 15 Q. Did you ever talk to any of the police that 16 worked for the Town of Palm Beach without the presence 17 of your attorneys? 18 A. Explain - 19 MR. PIKE: Wait one second. 20 THE WITNESS: I'm sorry. 21 MR. PIKE: Can you state the question again? 22 MR. KUVIN: Sure. 23 BY MR. KUVIN: 24 Q. Did you ever speak to any of the police 25 officers that worked for the Town of Palm Beach without 9 (Pages 201 to 204) PROSE COURT REPORTING AGENCY, INC. .Electrancaltystgand by RIctiutt Etactronleally signed by Jana Rleelutl blead104fcb-496c-a244.099977073134 EFTA01087063 Page 205 1 the presence of your attorneys? 2 MR. GOLDBERGER: Is the question, have you 3 ever spoken to a Town of Palm Beach police officer? 4 Is that the — can we rephrase it like that? 5 MR. KUVIN: Sure. 6 MR. GOLDBERGER: Okay. 7 THE WITNESS: I've been stopped by the police 8 for traffic violations, if that's what you mean. 9 BY MR. KUVIN: 10 Q. Any other times that you had conversations 11 with any of the Town of Palm Beach — 12 A. No. 13 Q. --police officers? 14 A. Not that I recall specific* 15 Q. Okay. Now, you were housed at the jail after 16 your plea of guilty that we had spoke about at the 17 beghming of your deposition; is that correct? 18 MR. PIKE: Form. 19 THE WITNESS: Say it again. 20 BY MR. KUVIN: 21 Q. Yes. You were housed at the local jail here 22 in Palm Beach County after your plea of guilty that we 23 spoke about at the beginning of your deposition? 24 MR. PIKE: Form. 25 THE WITNESS: Yes. Page 20'r 1 BY MR. KUVIN: 2 Q. Did you purchase items from the jail? 3 MR. GOLDBERGER: Hang on a second. 4 MR. PIKE: Hold on one second. 5 THE WITNESS: It looks that way, yes, sir. 6 BY MR. KUVIN: 7 Q. Okay. 8 MR. PIKE: And the document speaks for itself, 9 the composite document speaks for itself. 10 BY MR. KUVIN: 11 Q. I'd like you to take a look at Exhibit 18. It 12 shows purchases well, does it show purchases by you? 13 MR. PIKE: Asked and answered. 14 THE WITNESS: Yes. 15 BY MR. KUVIN: 16 Q. Okay. And it appears those purchases took 17 place from 7/8/08 through 9/30/08 is the last one that I 18 have; is that correct? 19 MR. PIKE: The document speaks for itself. 20 BY MR. KUVIN: 21 Q. You can answer. 22 A. The document speaks for itself. 23 Q. Is that correct, the last date is 9/30/08? 24 A. The last date here is 9/30, yes. 25 MR. PIKE: With regard to what you provided 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 Page 206 BY MR. KUVIN: Q. How long were you there? A. 13 months, approximately. Q. All right. And of those 13 months, how many months were you there where you had to stay there 24 hours a day? A. I don't recall specifically. Q. More than a month? A. Yes. Q. More than two months? A. Yes. Q. More than three months? A. Yes. Q. More than four? A. I think so,Idon't remember. Q. Do you recall when you were provided work release, when you were able to leave during the daylight hours? A. Not with specificity. Q. While you were there at the jail in Palm Beach -- I'm going to show you what we'll mark as Exhibit 18. (Plaintiffs Exhibit No. 18 was marked for identification.) 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 Page 208 the witness. MR. KUVIN: Sure, absolutely. THE WITNESS: Okay. BY MR. KUVIN: Q. And just so we're clear, this composite exhibit that we've marked as Exhibit 18 contains purchases from 7/8/08, 7/15,7/22, 7/29, 8/5,8/12, 8/21, W26,9/2, 9/9, 9/23 and 9/30, just so the record is clear; there is no question. A. Okay. Q. Okay? A. Uh-huh. Q. All right. These items that you purchased, did you utilize all of these items yourself? MR. PIKE: Form, relevance. THE WITNESS: I don't understand the question. BY MR. KUVIN: Q. Well, you purchased a number of items that are shown in this receipt. A. Yes. Q. The question is: Did you use them yourself? MR. PIKE: Same objection. THE WITNESS: I don't knots if I used all of them, so... 10 (Pages 205 to 208) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana Ricciuti bf8d9d10-4fcb-496c-a244.099977073134 EFTA01087064 Page 209 1 BY MR. KUVIN: 2 Q. Well, what did you do with the items that you 3 purchased? 4 MR. PIKE: Form, overbroad. 5 BY MR. KUVIN: 6 Q. You can answer. 7 A. I used some, I threw away sane. 8 Q. Did you give any away? 9 A. Not that I remember. 10 MR. PIKE: Same objection. 11 BY MR. KUVIN: 12 Q. Did you provide any items that you purchased 13 to other inmates while you were there in jail? 14 MR. PIKE: Form. 15 THE WITNESS: Not to the best of my 16 recollection. 17 BY MR. KUVIN: 18 Q. Okay. With respect to all of the items that 19 are listed in these receipts, is it a safe assumption 20 that you either used them yourself or threw them away? 21 MR. PIKE: Asked and answered. If you don't 22 know —if you know. 23 THE WITNESS: I don't know. 24 BY MR. KUVIN: 25 Q. I'm sorry? I didn't hear you. Page 211 1 the form you filled out, the infonnation or the product 2 that you put on that form actually was provided? 3 A. No, never. 4 Q. If we look at the items that are contained 5 within these receipts, I'd like you to go, if you would, 6 to the second invoice here dated 7/15/08. The third 7 item down is a Lubriderm lotion. 8 A. Yes. 9 Q. Do you see that? 10 A. Yes. 11 Q. Did you purchase that? 12 A. It appears so. 13 Q. Did you receive it? 14 A. I don't remember. 15 Q. Did you use the Lubriderm lotion that you 16 received or that you may have received in jail? 17 MR. PIKE: Form. 18 BY MR. KUVIN: 19 Q. Let me strike that and re-ask it. 20 A. Okay. 21 Q. Did you use the Lubridenn lotion which you had 22 purchased from the jail while you were there? 23 A. I might have. 24 Q. What for? 25 A. To moisturize my hands and face. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 210 MR. PIKE: Asked and answered. THE WITNESS: So should I answer? MR. PIKE: You can answer again. THB WITNESS: Ask the question again. BY MR. KUVIN: Q. So can we assume that all of the items that are shown in these receipts were either used by you or thrown away? A. I don't even know if I received some of those items, so I would assume I used most of them. Q. Okay. A. Okay? Q. Sure. Take a look, I just want to make surd, did you receive all these items? A. I don't know. MR. PIKE: Asked and answered. BY MR. KUVIN: Q. How did you purchase them? A. I filled out a form. Q. And how were they provided to you? MR. PIKE: Form. THE WITNESS: Sometimes they would come in a bag. BY MR. KUVIN: Q. Okay. And did you determine whether or not 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 Page 212 Q. Okay. Did you use Lubriderm lotion while you were in jail to masturbate at all? A. No. MR. PIKE: Fonn objection, harassing. THE WITNESS: Absolutely not. BY MR. KUVIN: Q. It appears, if you would turn to 7/29/08, which is approximately two weeks later, and the second thing down is another bottle of Lubriderm lotion. Do you see that? A. Yes. Q. What did you use that for? MR. PIKE: Asked and answered. MR. KUVIN: It's a second bottle. MR. PIKE: It's the same question, Spencer. Can we got to something relevant? THE WITNESS: No problem. MR. PIKE: He can answer. THE WITNESS: My hands and my face. BY MR. KUVIN: Q. Okay. A. I believe the first bottle went missing. Q. If we turn to approximately one month later on 821/08, do you have that one? A. Yes. t , n (Pages 209 to 212) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Mocha' Electronically signed by Jeana Modell hf8d9df0.4fcb-496c•a244.099977073134 EFTA01087065 Page 213 1 Q. All right. On that occasion, you bought two 2 bottles of hand lotion again. 3 A. Yes. 4 Q. What did you use those for? A. Nothing 6 Q. What did you do with them? 7 A. They were bought by accident. 8 Q. How did you buy them by accident? 9 A. Because you fill out a check form and 10 sometimes the forms don't make any sense, they just 11 deliver in other things. 12 Q. Sir, did you get those two bottles? 13 A. Yes. Yes. 14 Q. And you never used them? 15 A. No. I threw them away. 16 Q. Okay. If we turn to 9/9/08, do you see that 17 entry? 18 A. Yes. 19 Q. All right. And another invoice here, on that 20 date a bottle of hand lotion, do you see that? 21 A. Yes, I do. 22 Q. Did you get it? 23 A. I don't know. 24 Q. Do you know if you used it? 25 A. Definitely not. Page 215 1 A. No. 2 Q. Is it your testimony here today that you did 3 not use any of the bottles of hand lotion or Lubridenn 4 lotion that we had previously just gone through to 5 masturbate while you were in jail? 6 A. That's correct. 7 Q. Did Ghislainc Maxwell visit you in jail? 8 A. No. 9 Q. Did 10 in jail? 11 A. I intend to respond to all relevant questions 12 regarding this lawsuit; however, at the present time, my 13 attorneys have counseled me I cannot provide answers to 14 any questions relevant to this lawsuit. I must accept 15 this advice or risk losing my 6th Amendment right to 16 effective representation. Accordingly, I assert my 17 federal constitutional rights as guaranteed by the 5th, 18 6th and 14th Amendment to the United States 19 Constitution. 20 Q. Did you have sex with 21 you were housed at the Palm Bench jail facility? 22 MR. PIKE: Form. 23 THE WITNESS: I intend to respond to all 24 relevant questions regarding this lawsuit; however, 25 at the present time, my attorneys have counseled me visit you while you were while Page 214 1 Q. How do you know you definitely did not use it? 2 A. Because it was not — anything that said hand 3 lotion I did not use, I throw in the garbage. 4 Q. Why is that? A. Because it wasn't something that I had 6 ordered. 7 MR. PIKE: Can 1-- can I just have an 8 agreement that the objections to this line of 9 questioning is irrelevant, so I don't have to -- 10 MR. KUVIN: Sure. 11 MR. PIKE: — interrupt. 12 MR. KUVIN: Sure. 13 MR. PIKE: Agreed? 14 MR. KUVIN: Agreed. 15 BY MR. KUVIN: 16 Q. Let's turn again to 9/30/08, the last invoice 17 in there. 18 A. Yes. 19 Q. Do you see there is an entry for two snore 20 bottles of hand lotion. Do you see that? 21 A. Correct. 22 Q. What did you do with those? 23 A. To the best of my knowledge, I threw them 24 right away. 25 Q. You didn't use them for anything? Page 216 1 I cannot provide answers to any questions relevant 2 to this lawsuit. As I've answered most of your 3 question today, Mr. Kuvin, I must accept this 4 advice or risk losing my 6th Amendment right to 5 effective representation. Accordingly, I assert my 6 federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. 9 BY MR. KUVIN: 10 Q. Did you pay girls so that they would not 11 testify against you in the civil proceedings that have 12 been filed in both Federal and State Court? 13 MR. PIKE: Fenn. 14 THE WITNESS: Okay. Like most of your other 15 questions here today, Mr. Kuvin, I'm going to 16 respond by saying I intend to respond to all 17 relevant questions regarding this lawsuit; however, 18 at the present time, my attorneys have counseled me 19 I cannot provide answers to any questions relevant 20 to this lawsuit. I must accept this advice or risk 21 losing my 6th Amendment right to effective 22 representation. Accordingly, I must assert my 23 federal constitutional rights as guaranteed by the 24 5th, 6th and 14th Amendments to the United States 25 Constitution. 12 (Pages 213 Lo 216 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana RIcciuti bf8d9df0-4fcb-496c-a244-09997 7073134 EFTA01087066 Page 217 1 BY MR. KUVIN: 2 Q. Did you have sex with when 3 she was under the age of 14? 4 MR. PIKE: Form. 5 THE WITNESS: I intend to respond to all 6 relevant questions regarding this lawsuit; however, 7 at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant 9 to this lawsuit. 1 must accept this advice or risk 10 losing my 6th Amendment right to effective 11 representation. Accordingly, I must assert my 12 federal constitutional rights as guaranteed by the 13 5th, 6th and 14th Amendment to the Constitution. 14 BY MR. KUVIN: 15 Q. Did you tell people that was 16 your sex slave? 17 MR. PIKE: Same objection. 18 THE WITNESS: I intend to respond to all 19 relevant questions regarding this lawsuit; however, 20 at the present time, my attorneys have counseled me 21 I cannot provide answers to any questions relevant 22 to this lawsuit. I must accept this advice or risk 23 losing my 6th Amendment right to effective 24 representation. Accordingly, I must assert my 25 federal constitutional rights as guaranteed by the Page 219 1 any questions relevant to this lawsuit. I must accept 2 this advice or risk losing my Gth Amendment right to 3 effective representation. Accordingly, as I've done 4 with most of your questions, I must assert my federal 5 constitutional rights as guaranteed by the 5th, 6th and 6 14th Amendment to the United States Constitution. 7 Q. Mr. Epstein, are you aware that after 8 September 11, 2001 that the Federal Government started 9 tracking all flights of all public and private aircraft? 10 MR. PIKE: Fenn, relevance. 11 BY MR. KUVIN: 12 Q. Are you aware of that? 13 A. No. 14 Q. Okay. Are you aware that the FAA keeps track 15 of all flights that are made both within the continental 16 US and from the continental US abroad? 17 MR. PIKE: Saint objection. 18 THE WITNESS: No. 19 BY MR. KUVIN: 20 Q. Do you know whether or not — let me ask it 21 this way: Have you ever seen the flight tracking 22 information for any planes that you may own? 23 A. 1 don't believe so. 24 Q. Is JEGE, Inc. a company that is owned by you? 25 A. l'Ilhave to answer that question the way I've Page 218 1 5th, 61h and 14th Amendment to the United States 2 Constitution. Excuse me. 3 MR. KUVIN: This is 19. 4 (Plaintiffs Exhibit No. 19 was marked for 5 identification.) 6 BY MR. KUVIN: 7 Q. I have an FAA registry for a Boeing 727, 8 manufacture year 1969, with — I'm just looking for the 9 tail number here. I'm sorry, I'm just hying to find 10 the tail number. 11 A. Not a problem. 12 Q. Let's do this, it's a Mode S Code 13 I'll show this to your counsel first. 14 Here it is,19n sorry, Tail No. N908JE. 15 There's no question pending just yet. 16 MR. PIKE: Thank you. 17 Okay. 18 BY MR. KUVIN: 19 Q. Let me show you what we marked as Exhibit 19. 20 III give you a minute to take a look at that. 21 A. Okay. 22 Q. What is .1A EGE, Inc.? 23 A. T intend to respond to all relevant questions 24 regarding this lawsuit; however, at the present time, my 25 attorneys have counseled me I cannot provide answers to Page 220 1 answered most of your other questions here today, which 2 is, 1 intend to respond to all relevant questions 3 regarding this lawsuit; however, at the present time, my 4 attorneys have counseled me I cannot provide answers to 5 any questions relevant to this lawsuit. 1 must accept 6 this advice or risk losing my 6th Amendment right to 7 effective representation. Accordingly, I assert my 8 federal constitutional rights as guaranteed by the 5th, 9 Gth and 14th Amendment to the United States 10 Constitution. 11 Q. The plane that is identified in the FAA 12 registry in the document marked Exhibit 19, just so 13 we're clear, because I don't think I asked it exactly, 14 but is this your plane? 15 A. I'm going to answer that question the same way 16 I've answered most of your questions today, Mr. Kuvin, 17 which is, I intend to respond to all relevant questions 18 regarding this lawsuit; however, at the present time, my 19 attorneys have counseled me I cannot provide answers to 20 any questions relevant to this lawsuit. I must accept 21 this advice or risk losing my 6th Amendment right to 22 effective representation. Accordingly, I assert my 23 federal constitutional rights as guaranteed by the 5th, 24 61h and 14th Amendment to the United States 25 Constitution. 13 (Pages 217 to 220) PROSE COURT REPORTING AGENCY, INC. Elictronlcalltilonird-by TanaTBoefuif — Electronically signed by Jenne Riceluti bf8d9d10.4feb-496c•a244-099977073134 EFTA01087067 Page 221 1 Q. Isn't is true, sir, that you flew to Thailand 2 in 2001? 3 MR. PIKE: Form. 4 THE WITNESS: I intend to respond to all S relevant questions regarding this lawsuit; however, 6 at the present time, my attorneys have counseled me 7 I cannot provide answers to any questions relevant 8 to this lawsuit. 1 must accept this advice or risk 9 losing my 6th Amendment right to effective 10 representation. Accordingly, I assert my federal 11 constitutional rights as guaranteed by the 5th, Gth 12 and 14th Amendment to the United States 13 Constitution. 14 BY MR. KUVIN: 15 Q. Is it true that you went to Thailand in 2001 16 with Prince Andrew? 17 MR. PIKE: Porn 18 THE WITNESS: I intend to respond to all 19 relevant questions regarding this lawsuit; however, 20 at the present time, my attorneys have counseled me 21 I cannot provide answers to any questions relevant 22 to this lawsuit, and as I've done for most of all 23 your questions today, Mr. Kuvin, I must accept this 24 advice or risk losing my 6th Amendment right to 25 effective representation. Accordingly, I assert my Page 223 1 MR. PIKE: Same objections. 2 THE WITNESS: I intend -- 3 MR. PIKE: Relevance as well, excuse me. I'm 4 sorry. 5 THE WITNESS: I intend to respond to all 6 relevant questions regarding this lawsuit; however, 7 at the present time, my attorneys have counseled me 8 I cannot provide answers to any questions relevant 9 to this lawsuit. I must accept this advice or risk 10 losing my 6th Amendment right to effective 11 representation. Accordingly, lessen my federal 12 constitutional rights as guaranteed by the 5th, Gth 13 and 14th Amendments to the United States 14 Constiltdion. 15 BY MR. KUVIN: 16 Q. Did you bring any young women on the plane 17 with you when you went to Thailand in 2001? 18 h4R. PIKE: Same objection. 19 THE WITNESS: I intend to respond to all 20 relevant questions regarding this lawsuit; however, 21 at the present time, my attorneys have counseled me 22 I cannot provide answers to any questions relevant 23 to this lawsuit. I must accept this advice or risk 24 losing my 6th Amendment right to effective 25 representation. Accordingly, I assert my federal Page 222 1 federal constitutional rights as guaranteed by the 2 Sth, 6th and 14th Amendment to the United States 3 Constitution. 4 BY MR. KUVIN: 5 Q. Isn't it true that you went to Thailand in 6 2001 so that you could engage in sexual relations with 7 girls under the age of 16 with Prince Andrew without any 8 fear of any legal recourse? 9 MR. PIKE: Same objection. In addition, 10 improper hypothetical, lack of predicate, 11 foundation, argumentative, harassing. 12 THE WITNESS: I intend to respond to all 13 relevant questions regarding this lawsuit; however, 14 at the present time, my attorneys have counseled me 15 I cannot provide answers to any questions relevant 16 to this lawsuit. I must accept this advice or risk 17 losing my 6th Amendment right to effective 18 representation. Actordingly,1 must assert my 19 federal constitutional rights as guaranteed by the 20 5th, 6th and 14th Amendment to the United States 21 Constitution. 22 BY MR. KUVIN: 23 Q. Have you seen the photographs of you and 24 Prince Andrew while you were in Thailand with half naked 25 women, some of which were under the age of 16? Page 224 1 constitutional rights as guaranteed by the 5th, 6th 2 and 14th Amendments to the United States 3 Constitution. 4 BY MR. KUVIN: 5 Q. Have you brodtaabefore that you 6 bought -- brought to the United States 7 to be your Yugoslavian sex slave? 8 A. I intend to respond to all relevant questions 9 regarding this lawsuit; however, at the present time, my 10 nttorneys have counseled me I cannot provide answers to 11 any questions relevant to this lawsuit. I must accept 12 their advice or risk losing my 6th Amendment right to 13 effective representation. Accordingly, I must assert my 14 federal constitutional rights as guaranteed by the 5th, 15 6th and 14th Amendments to the United States 16 Constitution. 17 Q. Have you had — 18 MR. GOLDBERGER: You raised the same objection 19 to that question, right? 20 MR. PIKE: Yeah, I did. 21 BY MR. KUVIN: 22 Q. Have you had sex with numerousgirls under the 23 age of 18 in the presence of= 24 MR. PIKE: Same objections. 25 THE WITNESS: I'm going to answer that the 14 (Pages 221 to 224) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Rledull fascfronleeig signed by Joan. RlccMl bilided10-4fcb-496c-a244-09997 7073134 EFTA01087068 Page 225 1 same way I've answered most of your questions here 2 today, Mr. Kuvin, which is, I intend to respond to 3 all relevant questions regarding this lawsuit; 4 however, at the present time, my attorneys have 5 counseled me I cannot provide answers to any 6 questions relevant to the lawsuit. I must accept 7 their advice or risk losing my 6th Amendment right 8 to effective representation. Accordingly, I assert 9 my federal constitutional rights as guaranteed by 10 the 5th, 6th and 14th Amendments to the United 11 States Constitution. 12 BY MR. KUVIN: 13 Q. What is MC2? 14 MR. PIKE: Same objection. 15 MB WITNESS: I don't understand the question. 16 BY MR. KUVIN: 17 Q. MC and then a number 2, what is that? 18 MR. PIKE: Lack of predicate, foundation. 19 THE WITNESS: What is that? 20 MR. PIKE: Irrelevant. 21 BY MR. KUVIN: 22 Q. Do you know what it is? 23 A. No. 24 Q. You've never heard of that before? 25 A. MC2? 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 Page 227 BY MR. KUVIN: Q. I can do it that way, it doesn't matter to me. THE WITNESS: It's up to you. MR. KUVIN: It's up to you guys. MR. PIKE: As I've said, Mr. Kuvin, if you want to limit the time that we spend here today and ask a compound question if you're going to list various items or list Individuals by name and ask questions, I won't have a compound objection to that type of inquiry if it's in light of attempting to save time. MR. KUVIN: Sure. BY MR. KUVIN: Q. All righty. MR. PIKE: But that's limited to the compound objection. MR. KUVIN: Oh, no, that's fine. BY MR. KUVIN: Q. All right. Did you purchase something called a Twin Torpedo, a soap made in the shape of a penis, and a soap in the shape of a vagina? A. I'm going to answer that question like I've answered most of your questions here today, which is, I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys Page 226 Q. Yeah. Capital M, capital C, number 2; sound 2 familiar at all? A. Na Q. Okay. Are you part owner in a teen modeling 5 agency? 6 A. Na 7 Q. Do you own any interest in any modeling 8 agencies currently? 9 A. I intend to respond to all relevant questions 10 regarding this lawsuit; however, nt the present time, my 11 attorneys have counseled me I cannot provide answers to 12 any questions relevant to this lawsuit. I must accept 13 this advice or risk losing my Gth Amendment right to 14 effective representation. Accordingly, I assert my 15 federal constitutional rights as guaranteed by the 5th, 16 6th and 14th Amendments to the United States 17 Constitution. 18 Q. Do you know what a sexual device called a Twin 19 Torpedo is? 20 MR. PIKE: Same objections, irrelevant as 21 worded. 22 THE WITNESS: Would you like to ask me a bunch 23 of questions or are we going to -- do you want to 24 individual answers to these? Do you want a 25 compound question? Page 228 1 have counseled me that I cannot provide answers to any 2 questions relevant to this lawsuit. I must accept this 3 advice or risk losing my 6th Amendment right to 4 effective representation. Accordingly, I assert my 5 federal constitutional rights as guaranteed by the 5th, 6 6th and 14th Amendment to the United States 7 Constitution. 8 MR. PIKE: Additionally, just for the Courts 9 record, you re questioning the witness on Exhibit 10 No. what? 11 MR. KUVIN: It's not an exhibit. It's the 12 Town of Palm Beach Incident Repoli with respect to 13 Jeffrey Epstein, of which I gave you a copy before. 14 And that was referencing, just so the record is 15 clear, page 46. 16 MR. PIKE: Then I would add additional 17 privileges and objections in addition to what 18 Mr. Epstein has already raised underneath Florida 19 Rule of Criminal Procedure 3.220 and work product. 20 Not necessarily the document in front of you, but 21 the questions and the answer you're attempting to 22 23 BY MR. KUVIN: 24 Q. Whose mobile wireless number is 25 A. I Intend to respond to all relevant questions lizacsrnai,a,mrazwax, 15 (Pages 225 to 228) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Facelift' ----------------- Electronically signed bt8d9dI0-41cb-496c-a244-099977073134 EFTA01087069 Page 229 1 regarding this lawsuit; however, at the present time, my 2 attorneys have counseled me I cannot provide answers to 3 any questions relevant to this lawsuit. I must accept 4 this advice or risk losing my 6th Amendment right to 5 effective representation. Accordingly, I hereby assert 6 my federal constitutional rights as guaranteed by the 7 5th, 6th and 14th Amendments to the United States 8 Constitution. 9 Q. Pm going to read you, for speed's sake, three 10 separate phone numbers, and it's the same question for 11 each. Do you recognize the following phone numbers? 12 They all have Area Code M. The first one is 13 the second is and the third is 14 A. I intend to respond to all relevant questions 15 regarding this lawsuit; however, at the present time, my 16 attorneys have counseled melcannot provide answers to 17 any questions relevant to this lawsuit. 1 must accept 18 this advice or risk losing my 6th Amendment right to 19 effective representation. Accordingly, I must assert my 20 federal constitutional rights as guaranteed by the 5th, 21 6th and 14th Amendments to the United States 22 Constitution. 23 Did or have the phone number 24 or El -- Pr 25 again. So two numbers: Either ins same number , on 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 Page 231 effective representation. Accordingly, I hereby assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. MR. PIKE: In addition, same objection and privilege which regard to the Florida Rule of Procedure 3.220 and work product. Not necessarily the document you're talking or speaking from, but the testimony. MR. KUVIN: I was just reading this. I wasn't asking questions from this at the moment. BY MR. KUVIN: Q. Does your penis have any deformities? MR. PIKE: Form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers the any questions relevant to the lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the Constitution, as I've done with most of your questions hero today. Page 230 1 A. I intend to respond to all relevant questions 2 regarding this lawsuit; however, at the present time, my 3 attorneys have counseled me I cannot provide answers to 4 any questions relevant to the lawsuit. I must accept this advice or risk losing my 6th Amendment right to 6 effective representation. Accordingly, I must assert my 7 federal constitutional rights as guaranteed by the 5th, 8 6th and 14th Amendments to the Constitution. 9 Q. Do you have an egg-shaped penis? 10 A. I intend to respond to all relevant questions 11 regarding this lawsuit; however, at the present time, my 12 attorneys have counseled me I cannot provide answers to 13 any questions that may be relevant to this lawsuit. I 14 must accept this advice or risk losing my 6th Amendment 15 right to effective representation. Accordingly, I must 16 assert my federal constitutional rights as guaranteed by 17 the Sth, 6th and 14th Amendment to the United States 18 Constitution. 19 Q. Do you have any identifying marks on your 20 penis? 21 A. I intend to respond to all relevant questions 22 regarding this lawsuit; however, at the present time, my 23 attorneys have counseled mot I cannot provide answers to 24 any questions relevant to the lawsuit. 1 must accept 25 their advice or risk losing my 6th Amendment right to Page 232 1 BY MR. KUVIN: 2 Q. Did you ever utilize Dollar-Rent-a-Car to rent 3 cars while you were hero in Palm Beach at any time? 4 A. I intend to respond to all relevant questions, 5 Mr. Kuvin, regarding this lawsuit; however, at the 6 present time, my attorneys have counseled me I cannot 7 provide answers to any questions that may prove relevant 8 to this lawsuit. I must accept this advice or risk 9 losing my 6th Amendment right to effective 10 representation. Accordingly, I must assert my federal 11 constitutional rights as guaranteed by the 5th, 6th and 12 14th Amendment to the United States Constitution. 13 Q. What was your personal cell phone carrier back 14 in 2004? 15 A. I intend to respond to all relevant questions 16 regarding this lawsuit. 17 Q. Let me make this quicker. I'm sorry for 16 interrupting you, I apologize. Let's say, what was your 19 cell phone carrier back from 2004 through 2006. 20 MR. PIKE: And I'm not objecting to compound; 21 however, there are various allegations in your 22 complaint regarding a time frame. So therefore, 23 with regard to the allegations in your complaint, 24 relative to your question, I'm not objecting to the 25 compound, I'm saying it's overbroad. 16 (Pages 229 to 232) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciull Electronically signed by Jeana RIcciull bf8d9df0-4fcb.496e-a244-09997 7073134 EFTA01087070 Page 233 1 MR. KUVIN: 2004 to 2006? 2 MR. PIKE: Overbroad and irrelevant based upon 3 the allegations that you've alleged. 4 MR. KUVIN: All right. Well, let me clarify 5 the question then. 6 BY ME. KUVIN: 7 Q. What was your cell phone carrier from 2004 to 8 2005? 9 MR. PIKE: Same objections. 10 BY MR. KUV1N: 11 Q. Well, lel me try and fix it again. What was 12 your cell phone carrier from 2005 to 2006? 13 MR. PIKE: Relevance. 14 THE WITNESS: I intend to respond to all 15 relevant questions regarding this lawsuit; however, 16 at the present time, my attorneys have counseled me 17 I cannot provide answers to any questions relevant 18 to this lawsuit. I must accept their advice or 19 risk losing my 6th Amendment right to effective 20 representation; therefore, I must assert my federal 21 constitutional rights as guaranteed by the 5th, 6th 22 and 14th Amendments to the United States 23 Constitution. 24 BY MR. KUVIN: 25 Q. What were the cell phone carriers of Page 235 1 BY MR. KUVIN: 2 Q. Here, let me move this out of the way. 3 A. You can take your Joy Jelly home now. 4 Q. Its actually an exhibit to your deposition. S A. Sorry. 6 Q. Have you read the police department's, the 7 Palm Beach Police Departments, probable cause 8 affidavit? Have you ever read it? 9 MR. PIKE: Attorney-client, work privilege. 10 BY MR. KUVIN: 11 Q. Have you over read the police department, Palm 12 Beach Police Departments incident report regarding you? 13 MR. MICE: Same objection. 14 MR. GOLDBERGER: Same objection. 15 MR. PIKE: And instruction, I'm sorry. 16 BY MR. KUVIN: 17 Q. Are you circumcised? 18 MR. PIKE.• Objection, relevance. 19 THE WITNESS: I intend to respond to all 20 relevant questions regarding this lawsuit; however, 21 at the present time, my attorneys have counseled me 22 I cannot provide answers to any questions relevant 23 to this lawsuit. I must accept this advice or risk 24 losing my 6th Amendment right to effective 25 representation. Accordingly, I assert my federal 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 Page 234 or Chislaine Maxwell from the years 2005 to 2006? MR. PIKE: Relevance. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. As I've answered most of your questions the saute way today, Mr. Kuvin, at the present time, my attorneys have counseled me I cannot provide answers to any of your questions that may be relevant to this lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Therefore, accordingly, I assert my federal constitutional rights as guaranteed by the 5th, Gth and 14th Amendment to the United States Constitution. May wo take a break, please? MR. KUVIN: Sure. MR. PIKE: Yes. MR. GOLDBERGER: Yes. THE VIDEOGRAPHER: Going off the record at 3:21. (A brief recess was taken.) THE VIDEOGRAPHER: Were back on the record at 3:30. 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 Page 236 constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. BY MR. KUVIN: Q. Was a search warrant performed and executed at your home on Palm Beach Island? MR. GOLDBERGER: Attorney-client, work privilege. Ill instruct you not to answer. BY MR. KUVIN: Do n know spelled s led • or A. I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit. And as I've answered most of your questions today, Mr. Kuvin, I must accept this advice and risk losing -- or risk losing my Gth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. Q. Did you have a chef working for you at your Palm Beach home back in 2005? 17 (Pages 233 to 236) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans MGM Electronically signed by Jeans Elected bf8d9df04fcb-496c-a244-099977073134 EFTA01087071 Page 237 A. I intend to respond to all relevant questions 2 regarding this lawsuit; however, at the present time, my 3 attorneys have counseled me I cannot provide answers to 4 any questions relevant to this lawsuit at this time. I 5 must accept their advice or risk losing my 6th Amendment 6 right to effective representation. Accordingly, I must 7 assert my federal constitutional rights as guaranteed by 0 the 5th, 6th and 14th Amendment to the United Slates 9 Constitution. 10 MR. PIKE: Additionally, predicate and 11 foundation. 12 BY MR. KUVIN: 13 Q. Did you own or do you currently own a 2004 14 black Chevy Suburban, bearing Florida tag 15 A. I intend to respond to all relevant questions 16 regarding this lawsuit; however, at the present time, my 17 attorneys have counseled me I cannot provide answers to 18 any questions that may be relevant to the lawsuit. I 19 must accept their advice or risk losing my 6th Amendment 20 right to effective representation; therefore, I assert 21 my federal constitutional rights as guaranteed by the 22 5th, 6th and 14th Amendment to the United States 23 Constitution. 24 Q. I think I asked this before, and I apologize 25 if I did, but your date of birth is January 20, 1953, Page 239 1 BY MR. KUV1N: 2 Q. -- or any other women in this case? 3 MR. GOLDBERGER: Okay. Now attorney-client, 4 work product. 5 I direct you not to answer. 6 BY MR. KUVIN: 7 Q. Do you know the name of the girl that was with 8 when she was brought to your home? 9 MR. PIKE: Form, lack of predicate, 10 foundation. 11 THE WITNESS: Like I've done to many of your 12 other questions and responded to many of your other 13 questions today, Mr. Kuvin, that question -- I must 14 answer that, I intend to answer all relevant 15 questions regarding this lawsuit; however, at the 16 present time, my attorneys have counseled meI 17 cannot provide answers to any questions that may be 18 relevant. I must accept this advice or risk losing 19 my 6th Amendment right to effective representation; 20 therefore, I assert my federal constitutional 21 rights as guaranteed by the 5th, 6th and I 4lb 22 Amendment to the Constitution. 23 BY MR. KUVIN: 24 Q. Did you, in fact, give M. 5200 for a -- for 25 her to get naked and give you a massage while you were Page 238 1 correct? 2 A. You asked that before. 3 Yes, correct. 4 Q. Okay, Pm sorry. Do you own a -- or did you own -- let me clarify. A. Do you want to do compound again? Q. Yeah. Did you or do you currently own a 2005 9 black Cadillac Escalade ESV, bearing Florida license tag 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me 1 cannot provide answers to any questions that may be relevant to the lawsuit. I must accept their advice or risk losing my 6th Amendment right to effective representation. Accordingly, assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. . Have you hired attorneys for either Ghislaine Maxwell, other - MR. GOLDBEROER: Attorney-client, work product. Arc you done? l'm sorry. Cr any Page 240 1 1 naked and, in addition, touch her in her vagina without 2 her permission in 2005? 3 MR. PIKE: Predicate, foundation -- 4 THE WITNESS: I believe that's been asked and 5 answered. 6 MR. PIKE: Harassing. And I believe as I worded, that question has been asked and answered 8 in sub parts. I believe you've asked those 9 questions initially at the beginning of this a deposition. The same objections would, therefore, 11 apply and be incorporated. 12 MR. KUVIN: I disagree, but... 13 THE WITNESS: Like most of your other 14 questions here today, I intend to respond to all 15 relevant questions regarding this lawsuit; however, 16 at the present time, my attorneys have counseled mo 17 I cannot provide answers to any questions that may 18 be relevant. I must accept this advice or risk 19 losing my 6th Amendment privilege. Accordingly, I 20 assert my federal constitutional rights as 21 guaranteed by the 5th, 6th and 14th Amendment to 22 the US Constitution. 23 BY MR. KUVIN: 24 Q. Do ou agree, sir, that your conduct, with 25 respect to M., caused her severe emotional distress? 18 (Pages 237 to 240) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RIcciutI Electronically signed by Jeana Riveted bfededf0-4fcb49600244-099977073134 EFTA01087072 Page 241 MR. PIKE: Same objection. In addition, it's 2 argumentative, harassing and calls for a 3 conclusion. 4 THE WITNESS: Yin going to have to answer that the same way I've answered most of your questions 6 today, Mr. Kuvin, which is, I intend to respond to 7 all relevant questions regarding this lawsuit; 8 however, at the present time, my attorneys have 9 counseled me I cannot provide answers to any 10 questions relevant to the lawsuit. I must accept 11 this advice or risk losing my 6th Amendment right 12 to effective representation. Accordingly, I must 13 assert my federal constitutional rights as 14 guaranteed by the 5th, 6th and 14th Amendment. 15 BY MR. KUVIN: 16 Q. Do you have gray chest hair? 17 A. I intend to respond to all relevant questions 18 regarding this lawsuit; however, at the present time, my 19 attorneys have counseled me I cannot provide answers to 20 any of those questions that may be relevant. I must 21 accept this advice or risk losing my 6th Amendment right 22 to effective representation. Accordingly, I assert my 23 federal constitutional rights as guaranteed by the 5th, 24 6th and 14th Amendments to the United States 25 Constitution. Page 243 1 effective representation. Accordingly, I must assert my 2 federal constitutional rights as guaranteed by the 5th, 3 6th and 14th Amendments to the United States 4 Constitution. 5 Q. Do you have a steam room in your home on Palm 6 Beach Island? 7 MR. PIKE: Same objections. 8 THE WITNESS: I'm going to answer that 9 question the same way I've answered most of your 10 questions here today, which is, I intend to respond 11 to all relevant questions regarding this lawsuit; 12 however, at the present time, my attorneys have 13 counseled me that 1 cannot provide answers to any 14 questions relevant to the lawsuit. I must accept 15 this advice or risk losing my 6th Amendment right 16 to effective representation. Accordingly, I must 17 assert my constitutional rights as guaranteed by 18 the 5th — 5th, 6th and 14th Amendments to the 19 United States Constitution. 20 BY MR. KUVIN: 21 Q. Did you provide payments to underaged girls by 22 utilizing cash and wire transfers through Western Union 23 in 2004 or 20057 24 MR. PIKE: Same objections as raised to the 25 previous last three questions incorporated here. Page 242 1 Q. Have you told young ladies -- girls under the 2 age of 18, when they came to your house and got naked to 3 give you a massage, quote, the more you do, the more you get paid? MR. PIKE: Objection, form, predicate, foundation, improper hypothetical and assumes facts not in evidence, relevance. 8 THE WITNESS: Lilco most of your questions, 9 Mr. Kuvin, today,1 intend to respond to all 10 relevant questions regarding this lawsuit; however, 11 at the present time, my attorneys have counseled me 12 1 cannot provide answers to any questions relevant 13 to this lawsuit. I must accept this advice or risk 14 losing my 6th Amendment right to effective 15 representation. Accordingly, I assert my federal 16 constitutional rights as guaranteed by the 5th, Gth 17 and 14th Amendment to the United States 18 Constitution. 19 BY MR. Kt./VIN: 20 Q. Do you have any tattoos? 21 A. I intend to respond to all relevant questions 22 regarding this lawsuit; however, at the present time, my 23 attorneys have counseled mel cannot provide answers to 24 any questions relevant to this lawsuit. I must accept 25 this advice or risk losing my 6th Amendment right to Page 244 1 THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit; however, 3 at the present time, my attorneys have counseled me 4 I cannot provide answers to any questions relevant 5 to the lawsuit. I must accept this advice or risk 6 losing my Gth Amendment right to effective 7 representation. Accordingly, I assert my federal 8 constitutional rights as guaranteed by the 5th, 6th 9 and 14th Amendment to the United States 10 Constitution. 11 BY MR. KUVIN: 12 Q. Did you -- excuse me. Did you take any 13 videotapes of girls that were under the ago of 18 in 14 your home on Palm Beach Island? 15 MR. PIKE: Same objections incorporated. 16 THE WITNESS: As I have with most of your 17 questions today, Pm going to have to answer that, 18 I intend to respond to all relevant questions 19 regarding this lawsuit; however, at the present 20 time, my attorneys have counseled me I cannot 21 provide answers to any questions that may be 22 relevant to this lawsuit. I must accept this 23 advice or risk losing my 6th Amendment right to 24 effective representation. Accordingly, I assert my 25 federal constitutional rights as guaranteed by the 19 (Pages 241 to 244) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana Meting bffidadlOsifeb-49k-a244-099977073134 EFTA01087073 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 245 1 5th, 6th and 14th Amendment to the United States 2 Constitution. 3 BY MR. KUVIN: 4 Q. Have you ever provided a dozen roses to a young girl under the age of 18 who came to your house to 6 give you a massage? MR. PIKE: Form, vague, ambiguous, assumes 8 facts not In evidence. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit; however, 11 at the present time, my attorneys have counseled me 12 that I cannot provide answers to any questions that 13 may be relevant. I must accept their advice or 14 risk losing my 6th Amendment right to effective 15 representation. Accordingly, I must assert my 16 federal constitutional rights as guaranteed by the 17 5th, 6th and 14th Amendment. 18 BY MR. KUVIN: 19 Q. Did you ever instruct anyone to deliver a 20 bucket of roses after a high school drama perforinanct to 21 an underaged girl? 22 MR. PIKE: Same objection. in addition, lacks 23 predicate and foundation. It's overbroad as well. 24 THE WITNESS: I fully intend to respond to all 25 relevant questions regarding this lawsuit; however, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 I 18 19 20 21 22 23 24 25 Page 247 MR. KUVIN: Okay. All right, 1 appreciate your patience. That's all the questions that 1 have right now. I know that Mr. Goldberger needs to deal with an issue right now with Ms. Ezell regarding any further questions. MR. GOLDBERGER: I think we clarified that. Ms. Ezell, are you there? MS. EZELL: Fm here. MR. GOLDBERGER: Yeah. You had a discussion with Bob Critton already concerning the question you raised with me earlier, right? MS. EZELL: Yes, I did, and I don't have any questions. MR. PIKE: Ms. Ezell, this is Michael Pike. I don't know what your conversation was with Bob, but did you cross notice this deposition? MS. EZELL: No, I did not. MR. PIKE: So what is your purpose of being here? My position is that those arc closed proceedings and your client, your client did not cross notice this deposition and/or your clients. So what is your purpose of sitting in on this deposition? MS. EZELL: Well, I received a notice of it, Page 246 at the present time, my attorneys have counseled me 2 that I cannot provide answers to any questions 3 relevant to the lawsuit. 1 must accept their advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. BY MR. KUVIN: Q. Hold on a second. 1 ma be done. Do you know a Dr. A. I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions that may be relevant. I must accept this advice or risk losing my 6th right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. MR. PIKE: Can you hold on one second? MR. KUVIN: I'm almost done. MR. PIKE: No, no. We're not going anywhere. MR. KUV1N: Okay. MR. PIKE: Okay. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 218 and I just thought I would listen to it while I was doing some other work. And I don't know why it would be a closed proceeding. MR. PIKE: Discovery proceedings arc closed if It's a pre-trial discovery, ma'am, it's not a court proceeding. Nonetheless, do you have any questions for the witness? MS. EZELL: No, I don't. MR. PIKE: And Ms. Holmes, who am you here on behalf of? Which clients? MS. HOLMES: M. and M. MR. PIKE: Arai also here on behalf of lane Doe in the case MS. HOLMES: 1 believe so, yes. MR. PIKE: Do you have any questions for the witness? MS. HOLMES: No, I do not. MR. GOLDBERGER: Katherine, we're going to end. Do you want me to disconnect you now? MS. FM t • Yes, thanks. MR. GOLDBERGER: Okay. THE VIDEOGRAPHER: Conclude the deposition and go off the record at 3:00-- MR. PIKE: Wait one second. 20 (Pages 245 to 248 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Ricoh/0 Bectronicatry signed by Jeans Ricclud bfildedtO4fcb-496c-a244.099977073134 EFTA01087074 Pa go 249 Page 251 2 3 4 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. KUVIN: Oh, wait. MR. GOLDBERGER: He's just going to read. MR. PIKE: You didn't give the witness a chance to read or waive and he'll read. THE VIDEOGRAPHER: Conclude the deposition and go off the record at 3:48. This will be the end of tape No. 3. (Witness accused.) (Deposition was concluded.) 1 CERTIFICATE 2 TH€STATE OF FLORIDA 3 COUNTY OF PALM REA° I 4 S I, Jeana Ricauli, Renbared Professional Reporter aid Notary Public in and for the State of 6 Florida at largo, do hereby certify that I was authorized to and did report said deposition in 7 stenotype; and that the foregoing pages arc a truo and correct transcription of my shorthand noes of said 8 deposition. 9 1 further certify that said deposition was taken at the lime and place Fiereirrabowt set forth and 1 0 that the taking of said deposition was commenced and completed as hereinabovo set out. I further certify that I am not attorney a 12 counsel of uny of the parties, nor ant I a relative or employee of any attorney or counsel of party connected 3 %nth the action. nor am I financially interested in the action. 14 The foregoing certification of this transcript IS does not apply to nny reproduction of thc Mae by any mean unless under the direct exact and/or direction 16 17 18 19 20 21. 11 22 73 24 25 of die certifying reporter. Dated this 8thday ofOctober, 2009. *ea Riceiuti, PR, FPR, as 1 2 3 4 5 6 a 10 11 12 13 14 15 Page 250 CERTIFICATE OF OATH 11113 STATE OF FLORIDA COUNTY OF PALM BEACH 1, the undersigned authority, certify that JEFFREY EPSTEIN personally appeared before me and was duly sworn on the 8th day of October, 2009. Dated this 8th day of October, 2009. Jeana ificcluti, RPR, FPR, C 16 Notary Public - State of Florida 17 My Commission Expir 13 My Comntlssion No.: 18 19 20 21 22 23 24 25 1 DAM Ocnber 21.2003 2 TO. WPM ErS1EDI do Mcbael l.IW 3 EURA1.431, CIUTI0N, LOTTER it COLEMAN. PA 101 }ewn 13onfoled Suite 400 West Pact Head\ florid' 31.01 NAB' M. v. EPSTEIN NSW Isk• nom ths on 1 hunday. doe Id) 7 O.-”beg, 21X9,y02gavemedepwidon hale above reftere4 many Aolai did NI *lie tIgnaine. 14 is now meows tha1”54 sign rui &miaow 9 As pinked). awed 00114 tonal/4w° be Ibreishe414 you teoush yew, tassel. Moe mad 10 the Itilay.ingimuudeaseirefblly. At the end of the iganxiptpx. mill cud en 11 matt 5betL Asp) read yeue depoi6an, *Ay angst% or cernxtions r:as xlshbamoke should be told on 12 the emu taecc thimpse Ind Ikx +Atoka Rid Nape. DONUT ca tetranwripl huff Once 1) you hwe te44.34 AM noes/ eny c.angto, le me to sign rti daleoe ens. axe =Ireton tbese 14 prim me 1404 42 no4 seal and sign Me 4epeauen 15 xiihick a seesecable tine 0.0 30 dip units I:dentist direord)ihe 43(c.fybee•fonvoied 16 ti the advii5g Wong. mry be Med ‘541h Scathe( due Cart Wpm wilkatv.ther:eaisraer.‘sIgt 1 ? termun In the Will .4 dm Winn *Mit butt te4 t to as 19 20 kin Fticciu6.RM, Flit CLR it Prose Come Rteoting Atiecy, IM: 250S. /v..steslis.5 Aver -T. Ste 1500 22 Wc54 Pair Beech, floads 11401 10 lido hereby olive my Rinabore 24 25 MERRY EPSTEIN Very lauly)aue. Page 252 PROSE COURT REPORTING AGENCY, 21 (Pages 249 to 252) INC. -- ElictruntcTh --- CtRflittarbrcwva giUU Electronically signed by Jeans Riccluti bflIdedf041eb496e.4244.099977073134 EFTA01087075 Page 253 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby codify that I have read the 6 foregoing deposition by me given, and that the statements contained herein are true and correct to the 8 best of my knowledge and belief, with the exception of 9 any corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2009. 14 15 16 17 18 19 JEFFREY EPSTEIN 20 21 22 23 24 25 Pao,' 1 RRATA SHEET 2 IN RE v. EPSTEIN CR:MARA RICCIUTI 3 N OP: JEFFREY EPSIE1N < TAKEN: October & 2009 DO NOT WRIIISON TRANSCRIPT-ENTER CHANGES HMI 6 PAGE P LINE I CHANOE REASON tl 7 10 It 17 13 14 15 16 17 Please roma& the artful *macerate sheet sots (axe so teicoplim my be credbuted lo an peAm Under penalty of perjury. I declare dial I have reed my 19 &Toshio° a/laces id is two and cowect nb§eci to any changes in form or substance entered bere. 20 21 DATE: 22 23 stommuttucw DITONIPIT. 24 25 22 (Pages 253 to 254) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Joann Ricclutl bfildedf0-4fcb496c4244499977073134 EFTA01087076