DS9 Document EFTA01103326

vs. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff; ) ) ) 149. ) EPSTEIN and ) ) Defendants. ) West Palm Bach, Florida April 30th, 2009 I008 o'clock A.M. VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Page 1 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX Direct Examination by Mr. Edwards 4 Page 3 EXHIBIT INDEX Plaintiffs Exhibit Hunter I marked for ID. 24 (Exhibit held by Attorney Edwards.) +++++++++ Deposition of JEFFREY EPSTEIN, a witness of lawful age, taken by the Plaintiff, for the purpose of discovery and for use as evidence in the above entitled cause, wherein: E.W. is the Plaintiff, and JEFFREY EPSTEIN and- the Defendants, in the Circuit Court in and for Palm Beach County, Florida, pursuant to notice heretofore filed, before LINDA P. AUKAMP, a Registered Professional Reporter and Notary Public in and for the State of Florida at Large, at 250 Australian Avenue South, Suite 1400, West Patin Beach, Palm Beach County, Florida, on the 30th day of April, 2009, commencing at 10:08 o'clock A.M. Page 2 1 APPEARANCES: 2 For The Plaintiff: 3 ROTHSTEIN, ROSENFELDT, ADLER 401 East Las Olas Boulevard, Suite 1650 4 Fon Lauderdale, Florida, 33301.4252 By BRADLEY JAMES EDWARD, ESQUIRE and 5 WILLIAM J. BERGER, ESQUIRE and RUSSELL ADLER, ESQUIRE 6 7 For The Defendant BURMAN, CRITTON, LUTHER & COLEMAN S I5 North Plaster Drive, Suite 400 9 West Palm Beach, Florida 33401.4349 By JOHN MICHAEL BURMAN, ESQUIRE 10 11 Also for the Defendant 12 ATTER.BURY, GOLDBERGER & WEISS, P.A. 250 Australian Ave. South, Suite 1400 13 West Palm Beach, Florida 33401 By JACK A. GOLDBERGER, ESQUIRE 14 15 Also Present: 16 Jeff Abbott, Videographer, Visual Evidence 17 18 19 20 21 22 23 24 25 Page 1 THEREUPON, 2 THE VIDEOGRAPHEEt: This is the 30th day 3 April, 2009. The time is 10:08 a.m. This is 4 videotaped ition of Jeffrey Epstein in the 5 matter of... versus Epstein. This deposition 6 is being held at 250 Australian Avenue South, 7 West Palm Beach, Florida. My name is Jeff Abbott, lam the videographer representing 9 Visual Evidence, Incorporated. 10 Would the attorneys please announce their 11 appearances for the record. 12 MIt EDWARDS: Brad Edwards on behalf of 3.3 the plaint' "deposition was set in 3.4 the case of 15 THE VIDEOGRAPHER: Oh. 16 MR. EDWARDS: That is a separate client of 17 mine, but that's not the case 18 THE VIDEOGRAPHER: Okay, that's what I 19 had. Sorry. 20 MR. BERGER: And Pm William J. Berger, 21 for the plaintiff, also. 22 MR. GOLDBERGER: Jack Goldberger on behal 2 3 of Jeffrey Epstein. 24 MR. BURMAN: Michael Burman on behalf of 25 le in. I Mat' • -• • • mil.N 1 (Pages 1 to 4) PALM BEACH REPORTING SERVICE, INC. EFTA01103326 Page 5 1 THEREUPON, 2 JEFFREY EPSTEiN, 3 Being a witness in the notice heretofore 4 filed, being of lawful age, and being first duly 5 sworn in the above cause, testified on his oath as 6 follows: 7 THE WITNESS: Yes, I do. 8 DIRECT EXAMINATION 9 Q. (By Mr. Edwards) Can you tell us your 10 fidl name for the record? 11 A. Jeffrey Edward Epstein. 12 Q. And what's your date of birth? 13 A. January 20th, 1953. 14 Q. And your social security number? 15 A. 16 Q. And your current address in West Palm 17 Beach? 18 A. I intend to respond to all relevant 19 questions regarding this lawsuit. However, at the 20 present time my attorneys have counseled me that I 21 cannot provide answers to any questions relevant to 22 this lawsuit, and I must accept the advice or risk 23 losing my Sixth Ansadment right to effective 24 representation. 25 Accordingly, I assert my Fifth, Federal Page 6 3. Constitutional rights as guaranteed by the Fifth, 2 Sixth, and Fourteenth Amendments to the United 3 States Constitution. 4 Q. So you're unwilling to give us your 5 address of your house in Palm Beach Comity? 6 A. I intend to respond to all relevant 7 questions regarding this lawsuit. However, at the 8 present time my attorneys have counseled me that I 9 cannot provide answers to any questions relevant to 10 this lawsuit or risk losing my Sixth Amendment right 11 to effective representation. 12 MR. EDWARDS: Mr. Goldberger, can we enter 13 into an agreement so that we all know that he's 14 reading off of that piece of paper, we know 15 what the whole spiel is, but maybe he can just 16 say fifth or same answer or something like 17 that, so we can continue to move on, rather 18 than read that paper the entire time? We'll be 19 here for days. 20 MR. GOLDBERGER: I think out of an 21 abundance of caution ifs probably appropriate 22 that whatever we feel is the proper response 23 is, so that our invocation of our Fifth 24 Amendment privileges is properly protected, 25 so I think we're in to no have to Ove the full Page 7 1 length - 2 MR. BURMAN: Obviously we can't tell what 3 you're going to play to a jury without the 4 entire spiel, what questions you night play to 5 a jury if you decide to do that when this case 6 is tried, so we're going to go with the entire 7 spiel to every question you ask. If -- that's 8 Mr. Goldberger's representation, or 9 recommendation. 10 MR. EDWARDS: Okay. 11 MR. GOLDBERGER: We will go question by 12 question, and we may or may not invoke Fifth 13 Amendment privileges and there may be times 14 where I'm going to have to think about it, 15 discuss it with Mr. Burman whether we're going 16 to invoke on any particular question, but on 17 those questions that we do invoke Fifth 18 Amendment privileges, I think we have no choice 19 but, as you say, do the entire spiel. 20 Q. (By Mr. Edwards) Can you tell me the 21 addresses of other homes that you own outside of 22 West Palm Beach? 23 A. I intend to respond to all relevant 24 questions regarding this lawsuit. However, in the 25 present my attorneys have counseled me that I cannot 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 8 provide answers to any questions relevant to this lawsuit, and i must accept the advice or risk losing my Sixth Amendment right to effective representation. Q. Have you seen any — MR. GOLDBERGER: And, excuse me, and your Fifth Anwhipeat privileges. THE WITNESS: Yes. Accordingly, i, excuse me, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteen Amendments of the United States Constitution. Q. (By Mr. Edwards) Have you seen any psychologists a psychiatrists in your life? MR. GOLDBERGER: Go ahead. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and i must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly. I assert my constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment of that constitution. 2 (Pages 5 to 8 PALM BEACH REPORTING SERVICE, INC. EFTA01103327 Page 9 1 Q. (By Mr. Edwards) Tell me the names of all 2 the businesses in which you are affiliated in any 3 way? 4 A. I intend to respond to all relevant 5 questions regarding this lawsuit. However, at the 6 present time my attorneys have counseled me that I 7 cannot provide answers to any questions relevant to 8 this lawsuit, and I must accept this advice or risk 9 losing my Sixth Amendment right to effective 10 representation. 11 I also assert my Federal Constitutional 12 Rights as guaranteed by the Fifth, Sixth, and 13 Fourteenth Amendments to the United States 14 Constitution. 15 Q. My understanding is you're currently 16 serving a 12-month jail sentence, is that correct? 17 MR. GOLDBERGER: You can answer, but -- 18 THE WITNESS: Na 19 Q. (By Mr. Edwards) You were currently, you 20 were initially sentenced to 18 months in jail, is 21 that correct? 22 MR. GOLDBERGER: Go ahead. 23 THE WITNESS: Yes. 24 Q. (By Mr. Edwards) And at the present 25 moment are you still under the supervision of that Page 11 1 A. Sorry, could you repeat the question? 2 Q. Sure. 3 I have a videotaped copy of the plea 4 colloquy — 5 A. No, the question before that. That's 6 okay. 7 Q. The question is, where do you intend to 8 reside once you are released from jail? 9 A. I intend to respond to all relevant 10 questions regarding this lawsuit. However, at the 11 present time my attorneys have counseled me that I 12 cannot provide answers to any questions relevant to 13 this lawsuit, and I must accept their advice or risk 14 losing my Sixth Amendment right to effective 15 representation. 16 Accordingly, I assert my Federal 17 Constitutional right as guaranteed by the Fifth, 18 Sixth, and Fourteenth Amendment of the United States 19 Constitution. 20 Q. As you know, that question was asked to 21 you when you pled guilty last June in 2008, and you 22 responded to the judge that you planned to reside in 23 West Palm Beach, Florida. Is that no longer your 24 intent? 25 A. I intend to respond to all relevant Page 10 1 jail sentence? 2 A. Yes. 3 Q. Do you !mow what your release date will 4 be? S A. No. 6 Q. You have not been told the date of your 7 release? 8 A. Not yet. 9 Q. Where do you plan to reside when you're 10 released from jail? 11 A. I intend to respond to all relevant 12 questions regarding this lawsuit. However, at the 13 present time my attorneys have advised me that I 14 must accept the advice, advised me not to answer 15 those questions. I must accept their advice or risk 16 losing my Sixth Amendment right to effective 17 representation. 18 Accordingly, I assert my Federal 19 Constitutional right as guaranteed by the Fifth, 20 Sixth, and Fourteenth Amendment of the constitution. 21 Q. Mr. Epstein, I have a videotaped copy of 22 the plea colloquy where you pled guilty and told 23 that judge you would be residing in West Palm Beach, 24 Florida. Are you saying now that the statement you 25 made to that inlEn312longer true? Page 12 1 questions regarding this lawsuit However, at the 2 present time my attorneys have counseled me that I 3 cannot provide answers to any questions relevant to 4 this lawsuit, and I must accept this advice or risk 5 losing my Sixth Amendment right to effective 6 representation. 7 Accordingly, I assert my Federal 8 Constitutional right as guaranteed by the Fifth, 9 Sixth, and Fourteenth Amendment of the constitution. 10 Q. This deposition is not being taken in the 11 county jail, but rather in your attorney, Jack 12 Goldberger's office, so can you please inform the 13 jury as to your current schedule as it is exists 14 today? 15 MR GOLDBERGER: Let me hold off on that. 16 Okay. 17 THE WITNESS: I don't understand the 18 schedule, the question. 19 MR. GOLDBERGER: Yeah, if you can just, if 2o you can rephrase the question, I think we can 21 answer it for you. 22 Q. (By Mr. Edwards) Okay. Currently you 23 described that you're under the supervision of the 24 jail sentence at this point in time, you're within 25 the 18 months of your,jail sentence. But this isn't 3 (Pages 9 to 12) PALM BEACH REPORTING SERVICE, INC. EFTA01103328 Page 13 1 a jail setting, so obviously you're outside of the 2 jail setting. 3 I am asking you just to tell the jury your 4 current schedule; you wake up, are you released from 5 jail at some time, do you have to report back to 6 jail on a daily basis? 7 A. Yes, I report back to jail at 8:00 p.m. 8 Q. Every single day? 9 A. Yes. 10 Q. And is it seven days a week that you're 11 out on work release? 12 A. No, sir. 13 Q. How many days a week are you out on work 14 release? 15 A. Six. 16 Q. And of those six days, how many hours per 17 day are you out on work release? 18 A. Twelve. 19 Q. And what are the hours that you're out on 20 work release versus the hours that you are confined 21 to the jail? 22 A. Repeat the question, please. 23 Q. What are the hours that you are out on 24 work release outside the jail versus the hours that 25 you are inside the jail, meaning if you report back Page 14 1 to the jail at 8:00 and stay there until 8:00 in the 2 morning, tell me that 3 A. I just did. 4 Q. And is that the schedule? 5 A. !just did. Yes, that's the schedule. 6 Q. Okay. So from 8:00 p.m. until 8:00 an. 7 you're in the jail? 8 A. Yes. 9 Q. And then from 8.00 a.m. to 8:00 p.m. 10 you're out on work release? 11 A. Is that a question? 12 Q. Yes. 13 A. Yes. 14 Q. And where do you, where do you work? 15 MR. GOLDBERGER Objection. 16 THE WITNESS: I intend to respond to all 17 relevant questions to this lawsuit. However, 18 at the present time my attorneys have counseled 19 me that I cannot provide answers to any 20 questions relevant to this lawsuit, and I must 21 accept this advice or risk losing my Sixth 22 Amendment right to effective representation. 23 Therefore, I assert my Federal 24 Constitutional right as guaranteed by the 25 Fifth, Sixths and Fourteenth Amendment of the Page 15 1 constitution. 2 Q. (By Mr. Edwards) Are you saying that 3 providing me an answer as to where you currently 4 work, would somehow incriminate you? 5 MR. GOLDBERGER: Let's not be 6 argumentative. He responded to the question on 7 advice of counsel, and if you think that was an 8 improper invocation, then you have a remedy, 9 but don't argue with the witness, which is what 10 we did. Okay. 11 Q. (By Mr. Edwards) Do you have any plans to 12 leave the country once you're released from jail? 13 A. I intend to respond to all relevant 14 questions regarding this lawsuit. However, at the 15 present time my attorneys have counseled me that I 16 cannot provide answers to any questions relevant to 17 this lawsuit, and must accept the advice or risk 18 losing my Sixth Amendment right to effective 19 representation. 20 Accordingly, I assert my Federal 21 Constitutional right as guaranteed by the Fifth, 22 Sixth, and Fourteenth Amendment of the constitution. 23 Q. Do you currently own any jets or 24 airplanes? 25 A. I intend to respond to all relevant 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 16 questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment ofirnstitution MR. BURMAN: Is a state or federal case? MR. EDWARDS: State. MR BURMAN: Okay. I am going to, in addition to my client's assertion of his rights, also object on the grounds that punitive damages hasn't been allowed in this case yet. That's clearly a financial-type question and, therefore, we object on those grounds, as well. MR. EDWARDS: Thank you. Q. (By Mr. Edwards) Who are the pilots that are employed by you or work for you or fly your airplanes? A. I intend to respond to all relevant questions regarding this lawsuit. However at the 4 (Pages 13 to 16) PALM BEACH REPORTING SERVICE, INC. EFTA01103329 Page 17 1 present time my attorneys have counseled me that I 2 cannot provide answers to any questions relevant to 3 this lawsuit, and must accept their advice or risk 4 losing my Sixth Amendment right to effective 5 representation. 6 Accordingly, I assert my Federal 7 Constitutional rights guaranteed by the Fifth, 8 Sixth, and Fourteenth Amendment to the United States 9 Constitution. 10 Q. What person or persons make your travel 11 arrangements when you travel? 12 A. I intend to respond to all relevant 13 questions regarding this lawsuit However, at the 14 present time my attorneys have advised me that I 15 cannot provide answers to any questions relevant to 16 this lawsuit, and must accept this advice or risk 17 losing my Sixth Amendment right to effective 18 representation. 19 Accordingly, I would have to assert my 20 Federal Constitutional right as guaranteed by the 21 Fifth, Sixth, and Fourteenth Amendment of the 22 constitution. 23 Q. Once you are released from jail, are you 24 under an obligation to report to probation? 25 A. Yes. Page 19 1 questions regarding this lawsuit However, at the 2 present time my attorneys have advised me that I 3 cannot provide answers to any questions currently. 4 Therefore, I must accept this advice or risk losing 5 my Sixth Amendment right to effective 6 representation. 7 Accordingly, ! assert my Federal 8 Constitutional right as guaranteed by the Fifth, 9 Sixth, and Fourteenth Amendment to the constitution. 10 Q. Are you currently working with the Florida 11 Science Foundation? 12 MR. GOLDBERGER: Umm, okay. 13 THE WITNESS: Yes. 14 Q. (By Mr. Edwards) And that is a, a 15 business that operates just next door to your 16 attorney, Jack Goldberger's office, is that correct? 17 A. No. 18 Q. The Florida Science Foundation does not 19 have an office on this floor right next door to your 20 attorney, Jack Goldberger's office? 23. A. Is that a question? 22 Q. Yes. 23 A. You have to rephrase the question, please? 24 Q. Does the Florida Science Foundation have 25 an office right next door to your attorney, Jack Page 18 1 Q. Do you intend to do so? 2 A. Yes. 3 Q. And once you are released, do you, 4 according to your sentence, are you scheduled to 5 serve one year community control or house arrest? 6 MR. GOLDBERGER: That's a compound 7 question. Please rephrase it. 8 THE WITNESS: Yes. 9 Q. (By Mr. Edwards) When you're released 10 from jail, do you intend to serve one year community 11 control as a part of your sentence? 12 A. Yes. 13 Q. And under that provision, will you be able 14 to continue working or will you be strictly confined 15 to your house? 16 MR. GOLDBERGER: That calls for a legal 17 interpretation on the part of my client that 18 he's just not, he's just not competent to 19 answer. So, if you know, fine, but I can't 20 imagine you would know. 23. THE WITNESS: I don't know. 22 Q. (By Mr. Edwards) Who are the people that 23 will be living or working in your house once you are 24 released from jail? 25 A. I intend to respond to all relevant 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 20 Goldbergees office? A. No. Q. What is your role with the Florida Science Foundation? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have advised me that I cannot answer questions relevant to this lawsuit and must accept their advice, or risk losing my Sixth Amendment right to effective representstion. Therefore, I must assert my Federal Constitutional right under the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. What does the Florida Science Foundation do? A. I intend to respond to all relevant questions to this, regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit i must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, lessen my Federal Constitutional rights guaranteed by the Fifth, Sixth, and Fourteenth Amendment to that 5 (Pages 17 to 20) PALM BEACH REPORTING SERVICE, INC. EFTA01103330 Page 21 1 constitution. 2 Q. Have you procured minors for the purposes 3 of prostitution? 4 A. I intend to respond to all relevant 5 questions to this, regarding this lawsuit However, 6 at the present time my attorneys have counseled me 7 that I cannot provide answers to any questions 8 relevant to this lawsuit, and must accept their 9 advice or risk losing my Sixth Amendment right to 10 effective representation. 13. Accordingly, I assert my Federal 12 Constitutional right as guaranteed by the Fifth, 13 Sixth and Fourteenth Amendment of the United States 14 Constitution. 15 Q. Isn't it true that you did plead guilty to 16 two felonies related to prostitution with minors? 17 MR. GOLDBERGER: Wait a minute, let me 18 just hold off a second. 19 (Thereupon, a discussion was had off 20 the record.) 21 MR. GOLDBERGER: You can answer the 22 question. 23 THE WITNESS: Could you repeat the 24 question? 25 Q. (By Mr. Edwards) Isn't it true that you Page 22 1 pled guilty to two felony counts related to 2 procurement of a minor for prostitution and/or 3 solicitation of a minor for prostitution? 4 A. No. 5 Q. What counts did you plead guilty to? 6 A. Procuring a minor for prostitution and 7 soliciting prostitution. 8 Q. Have you had sex with minor girls? 9 A I intend to respond to all relevant 10 questions regarding this lawsuit. However, at the 11 present time my attorneys have advised me that I 12 cannot provide answers to any questions relevant to 13 this lawsuit at the present time, and I must accept 14 that advice or risk losing my Sixth Amencirnent right 15 to effective representation. 16 Accordingly, I assert my Federal 17 Constitutional right under the Fifth, Sixth, and the 18 Fourteenth Amendment to the Constitution. 19 Q. Have you engaged in sex acts with girls 20 who at the time you engaged in those sex acts were 21 minors? 22 A. I intend to respond to all relevant 23 questions to this lawsuit. At the present time my 24 attorneys have counseled me that I cannot respond, 25 I'm som. provide answers to any uestions relevant 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 B 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 23 to this lawsuit, and I must accept that advice or risk losing their representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment. Did you intentionally touch my client, A. I don't understand the question, sorry. Q. For the purpose of this lawsuit, we have used the pseudonym to describe my client. Do you know who Pm talking about when I refer toMil A. I intend to respond to all relevant questions to those, this lawsuit. However, at the present time my attorneys have advised me that I cannot accept, answer any questions relevant to this lawsuit, and must accept their advice, or risk losing my Sixth Amendment right to effective rgrc istation. Q. Did you — A. Accordingly -- excuse me -- I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. MR. BURMAN: We further object on the ground tha name has not been disclosed Page 24 and you've objected to that. MR. EDWARDS: Thanks. (By Mr. Edwards) Did you touch my client NM, against her will? A. We don't know who is. You haven't told me who is. Q. Okay. MR. EDWARDS: Do you have an exhibit slicker? (Thereupon, Plaintiffs Exhibit Number 1 was marked for Identification by Attorney Edwards.) Q. (By Mr. Edwards) Pm going to show you an exhibit that I have marked for identification purposes as Plaintiffs Exhibit 1. Do you recognize the girl on the left in the photograph? A. I intend to respond to all relevant questions regarding — THE WITNESS: Excuse me one second. (Thereupon, a discussion was had off the record.) THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. Howeveriz2a Jre,sent the time atto have 6 (Pages 21 to 24) PALM BEACH REPORTING SERVICE, INC. EFTA01103331 Page 25 1 counseled me that I cannot provide answers to 2 any questions relevant to this lawsuit. I must 3 accept their advice or risk losing my Sixth 4 Amendment right to effective representation. 5 Accordingly, I assert my Federal 6 Constitutional right as given by the Fifth, 7 Sixth -- as provided by the Fifth, Sixth, and 8 Fourteenth Amendment to the constitution. 9 Q. (By Mr. Edwards Do you know somebody by 10 the name o 11 A. I intend to respond to all relevant 12 questions regarding this lawsuit. However, at the 13 present time my attorneys have counseled me that I 14 cannot provide answers to any questions relevant to 15 this lawsuit, and must accept their advice or risk 16 losing my Sixth Amendment right to effective 17 representation. 18 Accordingly, I assert my Federal 19 Constitutional right as guaranteed by the Fifth, 20 Sixth and Fourteenth Amendment to the constitution. 21 Q. For the purposes of this deposition, when 22 I refer toM, I'm speaking of 23 Back to mthiitial questi . 24 touch my client,.., against her will? 25 A. I intend to respond to all relevant Page 27 1 A. I intend to respond to all relevant 2 questions regarding this lawsuit. However, at the 3 present time my attorneys have counseled me that 1 4 cannot provide answers to any questions relevant to 5 this lawsuit, and 1 must accept this advice or risk 6 losing my Sixth Amendment right to effective 7 representation. 8 Accordingly, I assert my Federal 9 Constitutional right as guaranteed by the Fifth, 10 Sixth, and Fourteenth Amendment to the United States 11 Constitution. 12 Q. Did you engage in sex or sex acts with a 13 female named (phonetic)? 14 A. I intend to respon to all relevant 15 questions regarding this lawsuit. However, at the 16 present time my attorneys have counseled me that I 17 cannot provide answers to any questions relevant to 18 this lawsuit, and I must accept this advice or risk 19 losing my Sixth Amendment right to effective 20 representation. 21 Accordingly, I assert my Federal 22 Constitutional right under the Fifth, Sixth, and 23 Fourteenth Amendment of the constitution. 24 Q. Between 2001 and 2005 did you en 25 sex or sex acts with a minor female named Page 26 1 questions regarding this lawsuit. However, at the 2 present time my attorneys have advised me that I 3 cannot provide answers to any questions relevant to 4 this lawsuit, and must accept their advice or risk 5 losing my Sixth Amendment right to effective 6 representation. 7 Accordingly, I assert my Fifth, Sixth, and 8 Fourteenth — Fifth, Sixth and Fourteenth Amendment 9 of the constitution. 10 Q. Did engage in sex or sex acts with my 11 clien against her will? 12 A. I intend to respond to all relevant 13 questions regarding this lawsuit. However, at the 14 present time my attorneys have advised me that I 15 cannot provide any questions relevant to this 16 lawsuit, and must accept their advice or risk losing 17 my Sixth Amendment right to effective 18 representation. 19 Accordingly, I assert my Federal 20 Constitutional right as guaranteed by the Fifth, 21 Sixth, and Fourteenth Amendment to that 22 constitution. 23 Q. Isn't it true that when you touthec. 24 against her will, you knew her to be a minor at the 25 time? Page 28 1 (phonetic)? 2 A. I intend to respond to all relevant 3 questions regarding this lawsuit. However, at the 4 present time my attorneys have counseled me that I 5 cannot provide answers to any questions relevant to 6 this lawsuit, and I must accept this advice or risk 7 losing my Sixth Amendment right to effective 8 representation. 9 Accordingly, I assert my Federal 10 Constitutional rights as guaranteed by the Fifth, 11 Sixth, and Fourteenth Amendment to the United States 12 Constitution. 13 Q. Between 2001 and 2005 did vou engage in 14 sex or sex acts with a minor named Mphonetic)? 15 A. I intend to respond to all relevant 16 questions regarding this lawsuit. However, at the 17 present time my attorneys have counseled me that I 18 cannot provide answers to any questions relevant to 19 this lawsuit, and I must accept this advice or risk 20 losing my Sixth Amendment right to effective 21 representation. 22 Accordingly, I assert my Federal 23 Constitutional right as guaranteed by the Fifth, 24 Sixth, and Fourteenth Amendment to the United States 25 Constitution. 7 (Pages 25 to 28) PALM BEACH REPORTING SERVICE, INC. EFTA01103332 Page 29 1 Q. Between 2001 and 2005 did you will 2 sex or sex acts with a minor female named 3 int (phonetic)? 4 A. I intend to respond to all relevant 5 questions regarding this lawsuit. However, at the 6 present time my attorneys have counseled me that I 7 cannot provide answers to any questions relevant to a this lawsuit, and must accept their advice or risk 9 losing my Sixth Amendment right to effective 10 representation. 11 Accordingly, i assert my Federal 12 Constitutional right as guaranteed by the Fifth, 13 Sixth, and Fourteenth Amendment to the United States 14 Constitution. 15 MR. BURMAN: Mr. Edwards, can I inquire of 16 you one thing? Do you have a RICO count in 17 UN's case? 18 MR. EDWARDS: Yes. 19 MR. BURMAN: Okay. These other girls, are 20 any of than your clients, as well? 23. MR. EDWARDS: Some may be. 22 MR. BURMAN: Okay. Thank you. 23 MR. EDWARDS: Some are not. 24 MR. BURMAN: Okay. 25 Q. (By Mr. Edwards) Between 2001 and 2005 Page 31 1 Q. Between 2001 and 2005 did you eruriS 2 sex or sex acts with a minor female named 3 (phonetic)? 4 A. I intend to respond to all relevant 5 questions regarding this lawsuit. However, at this 6 time my attorneys have counseled me that I cannot 7 provide answers to any questions relevant to this 8 lawsuit, and I must accept this advice or risk 9 losing my Sixth Amendment right to effective 10 representation. 11 Accordingly, I assert my Federal 12 Constitutional right as guaranteed by the Fifth, 13 Sixth, and Fourteenth Amendment of the United States 14 Constitution. 15 Q. Between 2001 and 2005 did you ensi 16 sex or sex acts with a minor female named 17 (phonetic)? 18 A. I intend to respond to all relevant 19 questions regarding this lawsuit. However, at the 20 present time my attorneys have counseled me that I 21 cannot provide answers to any questions relevant to 2 2 this lawsuit, and must accept this advice or risk 23 losing my Sixth Amendment right to effective 24 representation. 25 Accordingly, I assert my Federal Page 30 1 did you engage in sex or sex acts with a minor 2 female named IMIMEliphonetic)? 3 A. I intend to respond to all relevant 4 questions regarding this lawsuit. However, at the 5 present time my attorneys have counseled me that I 6 cannot provide answers to any questions relevant to 7 this lawsuit, and must accept this advice or risk B losing my Sixth Amendment right to effective 9 representation. 10 Accordingly, I assert my Federal 11 Constitutional rights as guaranteed by the Fifth, 12 Sixth, and Fourteenth Amendment to the constitution. 13 Q. Between 2001 and 2005 did you engage in 14 sex or sex acts with a minor female named 15 (phonetic)? 16 A. I intend to respond to all relevant 17 questions regarding this lawsuit. However, at the 18 present time my attorneys have counseled me that I 19 cannot provide answers to any questions relevant to 20 this lawsuit, and I must accept this advice or risk 21 losing my Sixth Amendment right to effective 22 representation. 23 Accordingly, I assert my Federal 24 Constitutional right as guaranteed by the Fifth, 25 Sixth?. and Fourteenth Amendment to the constitution. Page 32 1 Constitutional rights as guaranteed by the Fifth, 2 Sixth, and Fourteenth Amendment to the United States 3 Constitution. 4 Q. Between 2001 and 2005 did you engage in 5 sex or sex acts with a minor female named - 6 (phonetic)? 7 A. I intend to respond to all relevant a questions regarding this lawsuit. However, at the 9 present time my attorneys have counseled me that I 10 cannot provide answers to any questions relevant to 11 this lawsuit I must accept this advice or risk 12 losing my Sixth Amendment right to effective 13 representation. 14 Accordingly, I assert my Federal 15 Constitutional right under the Fifth, Sixth, and 16 Fourteenth Amendment to the constitution. 17 Q. Between 2001 and 2005 did you e in 18 sex or sex acts with a minor female named 19 (phonetic)? 2 0 A. I intend to respond to all relevant 21 questions regarding this lawsuit However, at the 2 2 present time my attorneys have counseled me that I 23 cannot provide answers to any questions relevant to 24 this lawsuit, and must accept this advice or risk 25 Iosing my Sixth Amendment right to effective 8 (Pages 29 to 32) PALM BEACH REPORTING SERVICE, INC. EFTA01103333 Page 33 1 representation. 2 Accordingly, I assert my Federal 3 Constitutional right as guaranteed by the Fifth, 4 Sixth, and Fourteenth Amendment to the United States 5 Constitution. 6 THE WITNESS: Can we take a break for, a 7 bathroom break, is that okay? 8 THE VIDEOGRAPHER: We're off the record at 9 10:39. 10 (Thereupon, a discussion was had off 11 the record.) 12 THE VIDEOGRAPHER: We're back on the 13 record at 10:44. 14 Q. (By Mr. Edwards) Between 2001 and 2005 15 did you engalii sex or sex acts with a minor 16 female name' (phonetic)? 17 A. I intend to respond to all relevant 18 questions regarding this lawsuit. However, at the 19 present time my attorneys have counseled me that I 20 cannot provide answers to questions relevant to this 21 lawsuit, and I must accept their advice or risk 22 losing my Sixth Amendment right to effective 23 representation. 24 Accordingly, I assert my Federal 25 Constitutional right as guaranteed by the Fifth, Page 34 1 Sixth and the Fourteenth Amendment to the United 2 States Constitution. 3 THE WITNESS: Can I see you a second, 4 Mike? 5 MIL BURMAN: Sure. 6 THE VIDEOORAPHER: We're off the record at 7 10:45. 8 (Thereupon, a brief break was taken.) 9 THE VIDEOGRAPHER: Back on the record at 10 10:46. 11 Q. (By Mr. Edwards) Between the year 2001 12 and 2005 did you eriy in sex or sex acts with a 13 minor female named in 14 MR. BURMAN: Object to form, form vague 15 and indefinite. Last name, please. 16 MR. EDWARDS: You can answer the question. 17 THE WITNESS: I intend to respond to all 18 relevant questions regarding this lawsuit 19 However, at the present time my attorneys have 20 counseled me that I cannot provide answers to 21 any questions relevant to this lawsuit, and 22 must accept this advice or risk losing my Sixth 23 Amendment right to effective representation. 24 Accordingly, I assert my Federal 25 Constitutional right as guaranteed b the Page 35 1 Fifth, Sixth, and Fourteenth Amendment to the 2 United States Constitution. 3 Q. (By Mr. Edwards) Between the year 2001 4 and 2005 did you en ge in sex or sex acts with a 5 minor female named honetic)? 6 MR. BURMAN: O ect to form, vague and 7 indefinite. Last name, please. 8 MR. EDWARDS: You can answer. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit. 11 However, at the present time my attorneys have 12 counseled me that I cannot provide answers to 13 any questions relevant to this lawsuit. I must 14 accept this advice or risk losing my Sixth 15 Amendment right to effective representation. 16 Accordingly, I assert my Federal 17 Constitutional rights as guaranteed by the 18 Fifth, Sixth and Fourteenth Amendment to the 19 United States Constitution. 20 Q. (By Mr. Edwards) Between 2001 and 2005 21 did you engage in sex or sex acts with a minor 22 female named (phonetic)? 23 MR. BURMAN: Object to form, vague and 24 indefinite. Last name, please. 25 MR. EDWARDS: You may answer. Page 36 1 THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit. 3 However, at the present time my attorneys have 4 counseled me that I cannot provide answers to 5 any questions relevant to this lawsuit, and 6 must accept this advice or risk losing my Sixth 7 Amendment right to effective representation. 8 Accordingly, I assert my Federal 9 Constitutional right as guaranteed by the 10 Fifth, Sixth and Fourteenth Amendment to the 11 United States constitution. 12 Q. (By Mr. Edwards) Between 2001 and 2005 13 did you engage in sex or sex acts with a minor 14 female named phonetic)? 15 MR. BURMAN: Object to the form, vague and 16 indefinite. Last name, please. 17 MR. EDWARDS: You can answer if - 18 THE WITNESS: 1 intend to respond to all 19 relevant questions regarding this lawsuit. 20 However, at the present time my attorneys have 21 counseled me that I cannot provide answers to 22 any questions relevant to this lawsuit. I must 23 accept this advice or risk losing my Sixth 24 Amendment right to effective representation. 25 Accordinfy, I assert my Federal 9 (Pa-es 33 to 36) PALM BEACH REPORTING SERVICE, INC. EFTA01103334 Page 37 1 Constitutional right as guaranteed by the 2 Fifth, Sixth and Fourteenth Amendment to the 3 United States Constitution. 4 Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor 6 female named (phonetic)? 7 MR. BURMAN: Object to form, vague and 8 indefinite. Last name, please. 9 MR. EDWARDS: You can answer, if you know. 10 THE WITNESS: 1 intend to respond to all 11 relevant questions regarding this lawsuit. 12 However, at the present time my attorneys have 13 counseled me that I cannot provide answers to 14 any questions relevant to this lawsuit. I must 15 accept this advice or risk losing my Sixth 16 Amendment right to effective representation. 17 Accordingly, I assert my Federal 18 Constitutional right as guaranteed by the 19 Fifth, Sixth, and Fourteenth Amendment to the 20 United States Constitution. 21 Q. (By Mr. Edwards) Between 2001 and 2005 22 did you engaga in sex or sex acts with a minor 23 female named (phonetic)? 24 MR. BURMAN: Object to form, vague and 25 indefinite. Last name, please. Page 38 1 MR. EDWARDS: You can answer. 2 THE WITNESS: I intend to respond to all 3 relevant questions regarding this lawsuit. 4 However at the present time my attorneys have 5 counseled me that I cannot provide answers to 6 any questions relevant to this lawsuit, and 7 must accept this advice or risk losing my Sixth 8 Amendment right to effective representation. 9 Accordingly, I assert my Federal 10 Constitutional right as guaranteed by the 11 Fifth, Sixth, and Fourteenth Amendment to the 12 United States Constitution. 13 Q. (By Mr. Edwards) Between 2001 and 2005 14 did you engage in sex or sex acts with a minor 15 female named (phonetic)? 16 MR. BURMAN: Object to form, vague and 17 indefinite. Last name, please. 18 MR. EDWARDS: You can answer. 19 THE WITNESS: i intend to respond to all 20 relevant questions regarding this lawsuit 21 However, at the present time my attorneys have 22 counseled me that I cannot provide answers to 23 any questions relevant to this lawsuit, and 24 must accept this advice or risk losing my Sixth 25 Amendment right to effective representation. 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 39 Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female that you referred to as (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. MR. BURMAN: Or flavor. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor Page 40 1 female named phonetic)? 2 MR. 13 : Object to form, vague and 3 indefinite. Last name, please. 4 MR. EDWARDS: You can answer. 5 THE WITNESS: I intend to respond to all 6 relevant questions regarding this lawsuit 7 However, at the present time my attorneys have 8 counseled me that I cannot provide answers to 9 any questions relevant to this lawsuit, and 10 must accept this advice or risk losing my Sixth 11 Amendment right to effective representation. 12 Q. (By Mr. Edwards) Between -- 13 THE WITNESS: Sorry? 14 MR. EDWARDS: I didn't realize you weren't 15 finished. 16 THE WITNESS: Accordingly, I assert my 17 Federal Constitutional right as guaranteed by 18 the Fifth, Sixth and Fourteenth Amendment to 19 the United States Constitution. 2 0 Q. (By Mr. Edwards) Between 2001 and 2005 21 did you in sex or sex acts witha 12-year-old 2 2 girl named onetic)? 23 MR B : Object to form, vague and 24 indefinite. Last name, please. 2 5 MR. EDWARDS: You can answer. 10 (Pages 37 to 4 0) PALM BEACH REPORTING SERVICE, INC. EFTA01103335 Page 41 1 THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit. 3 However, at the present time my attorneys have 4 counseled me that I cannot provide answers to 5 any questions relevant to this lawsuit, and 6 must accept this advice or risk losing my Sixth 7 Amendment right to effective representation. 8 Accordingly, I assert my Federal 9 Constitutional right as guaranteed by the 10 Fifth, Sixth, and Fourteenth Amendment to the 11 constitution. 12 Q. (By Mr. Edwards) Between 2001 and 2005 13 did you engage in sex or sex acts with a minor 14 female named (phonetic)? 15 MR. BURMAN: Object to form, vague and 16 indefinite. Last name, please. 17 MR. EDWARDS: You can answer. 18 THE WITNESS: I intend to respond to all 19 relevant questions regarding this lawsuit. 20 However, at the present time my attorneys have 21 counseled me that I cannot provide answers to 22 any questions relevant to this lawsuit. I must 23 accept their advice or risk losing my Sixth 24 Amendment right to effective representation. 25 Accordingly, I assert my Federal Page 42 1 Constitutional right as guaranteed by the 2 Fifth, Sixth and the Fourteenth Amendment to 3 the constitution. 4 Q. (By Mr. Edwards) Between 2001 and 2005 5 did you engage in sex or sex acts with a minor 6 female named =phonetic)? 7 MR. BURMAN: Object to form, vague and 8 indefinite. Last name, please. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit. 11 However, at the present time my attorneys have 12 counseled me that I cannot provide answers to 13 any questions relevant to this lawsuit, and 14 must accept their advice or risk losing my 15 Sixth Amendment right to effective 16 representation. 17 Accordingly, I assert my Federal 18 Constitutional right as guaranteed by the 19 Fifth, Sixth, and Fourteenth Amendment to the 20 United States Constitution. 21 Q. (By Mr. Edwards) Between 2001 and 2005 22 did you e in sex or sex acts with a minor 23 female (phonetic)? 24 MR. BURMAN: Object to form, vague and 25 indefinite. Lastname,please. Page 43 1 MR. EDWARDS: You can answer. 2 THE WITNESS: I intend to respond to all 3 relevant questions regarding this lawsuit. 4 However, at the present time my attorneys have 5 counseled me that I cannot provide answers to 6 any questions relevant to this lawsuit, and 7 must accept this advice or risk losing my Sixth 8 Amendment right to effective representation. 9 Accordingly, I assert my Federal 10 Constitutional right as guaranteed by the 11 Fifth, Sixth, and Fourteenth Amendment to the 12 United States Constitution. 13 Q. (By Mr. Edwards) Between 2001 and 2005 14 did you engage in sex or sex acts with a minor 15 female namedM (phonetic)? 16 MR. BURMAN: Object to form, vague and 17 indefinite. Last name, please. 18 MR. EDWARDS: You may answer. 19 THE WITNESS: I intend to respond to all 20 relevant questions regarding this lawsuit. 21 However, at the present time my attorneys have 22 counseled me that I cannot provide answers to 23 any questions relevant to this lawsuit, and 24 must accept this advice or risk losing my Sixth 25 Amendment right to effective representation. Page 44 1 Accordingly, I assert my Federal 2 Constitutional right as guaranteed by the 3 Fifth, Sixth, and Fourteenth Amendment of the 4 United States Constitution. 5 Q. (By Mr. Edwards) Between 2001 and 2005 6 did you engagejash or sex acts with a minor 7 female named .MA (phonetic)? 8 MR. BURMAN: Object to form, vague and 9 indefinite. Last name, please. 10 MR. EDWARDS: You can answer. 11 THE WITNESS: I intend to iespund to all 12 relevant questions regarding this lawsuit. 13 However, at the present time my attorneys have 14 counseled me that I cannot provide answers to 15 any questions relevant to this lawsuit, and I 16 must accept this advice or risk losing my Sixth 17 Amendment right to effective representation. 18 Accordingly, I assert my Federal 19 Constitutional right as guaranteed by the 20 Fifth, Sixth, and Fourteenth Amendment to the 21 United States Constitution. 22 MR. GOLDBERGER: One moment 23 (Thereupon, a discussion was had off 24 the record.) 25 ,.., 11Lao heresAttorney Adler entered 11 (Pages 41 to 44) PALM BEACH REPORTING SERVICE, INC. EFTA01103336 Page 45 1 the deposition room) 2 MR. EDWARDS: We're back on. 3 Q. (By Mr. Edwards) Between 2001 and 2005 4 did you enpgsm sex or sex acts with a minor 5 female named (phonetic)? 6 MR. BURMAN: Object to form, vague and 7 indefinite. Last name, please. 8 MR. EDWARDS: You can answer. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit. 11 However, at the present time my attorneys have 12 counseled me that I cannot provide answers to 13 any questions relevant to this lawsuit, and 14 must accept this advice or risk losing my Sixth 15 Amendment right to effective representation. 16 Accordingly, I assert my Federal 17 Constitutional right as guaranteed by the 18 Fifth, Sixth, and Fourteenth Amendment to the 19 constitution. 20 Q. (By Mr. Edwards) Between 2001 and 2005 21 did you engage in sex or sex acts with a minor 22 female named phonetic)? 23 MR. BURMAN: Object to form, vague and 24 indefinite. Last name, please. 25 MR. EDWARDS: You may answer. 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 47 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named (phonetic)? MR. BURMAN: Object to the form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named 111.111(phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. Page 46 1 THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit. 3 However, at the present time my attorneys have 4 counseled me that I cannot provide answers to 5 any questions relevant to this lawsuit, and 6 must accept this advice or risk losing my Sixth 7 Amendment right to effective representation. 8 Accordingly, I assert my Federal 9 Constitutional rights as guaranteed by the 10 Fifth, Sixth, and the Fourteenth Amendment to 11 the United States Constitution. 12 Q. (By Mr. Edwards) Between 2001 and 2005 13 did you engage in sex or sex acts with a minor 14 female named phonetic)? 15 MR BURMAN: Object to form, vague and 16 indefinite. Last name, please. 17 MR. EDWARDS: You may answer. 18 THE WITNESS: I intend to respond to all 19 relevant questions regarding this lawsuit. 20 However, at the present time my attorneys have 21 counseled me that I cannot provide answers to 22 any questions relevant to this lawsuit, and I 23 must accept this advice or risk losing my Sixth 24 Amendment right to effective representation. 25 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 48 MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named phonetic)? MR. BURMAN Object to form, vague and indefinite. And last name, please? MR. GOLDBERGER: Is that or IIIIIIP MR. EDWARDS: — dra. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and 12 (Pages 45 to 48) PALM BEACH REPORTING SERVICE, INC. EFTA01103337 Page 49 1 must accept this advice or risk losing my Sixth 2 Amendment right to effective representation. 3 Accordingly, I assert my Federal 4 Constitutional right as guaranteed by the 5 Fifth, Sixth, and Fourteenth Amendment to the 6 United States Constitution. 7 Q. (By Mr. Edwards) Between 2001 and 2005 8 did you engage in sex or sex acts with a minor 9 female named (phonetic)? 10 MR. BURMAN: Object to form, vague and 11 indefinite. Last name, please. 12 MR. EDWARDS: You can answer. 13 THE WITNESS: I intend to respond to all 14 relevant questions regarding this lawsuit. 15 However, at the present time my attorneys have 16 counseled me that I cannot provide answers to 17 any questions relevant to this lawsuit, and I 18 must accept this advice or risk losing my Sixth 19 Amendment right to effective representation. 2 0 Accordingly, I assert my Federal 21 Constitutional rights as guaranteed by the 22 Fifth, Sixth, and Fourteenth Amendment to the 23 United States Constitution. 24 Q. (By Mr. Edwards) Between 2001 and 2005 25 did you engage in sex or sex acts with a minor Page 50 1 female namedd hbonetic)? 2 MR. B : jest to form, vague and 3 indefinite. Last name, please. 4 MR. EDWARDS: You can answer. 5 THE WITNESS: I intend to respond to all 6 relevant questions regarding this lawsuit. 7 However, at the present time my attorneys have 8 counseled me that I cannot provide answers to 9 any questions relevant to this lawsuit, and I 10 must accept this advice or risk losing my Sixth 11 Amendment right to effective representation. 12 Accordingly, I assert my Federal 13 Constitutional right as guaranteed by the 14 Fifth, Sixth, and Fourteenth Amendment to the 15 United States Constitution. 16 Q. (By Mr. Edwards) Between 2001 and 2005 17 did you engage in sex or sex acts with a minor 18 19 female named bonetic)? MR. BURMAN: bject to form, vague and 20 indefinite. Last name, please. 21 MR. EDWARDS: You can answer. 22 THE WITNESS: I intend to respond to all 23 relevant questions regarding this lawsuit. 24 However, at the present time my attorneys have 25 counseled me that I cannot provide answers to Page 51 1 any questions relevant to this lawsuit, and 2 must accept this advice or risk losing my Sixth 3 Amendment right to effective representation. 4 Accordingly, I assert my Federal 5 Constitutional right as guaranteed by the 6 Fifth, Sixth, and Fourteenth Amendment to the 7 United States Constitution. 8 Q. (By Mr. Edwards) Between 2001 and 2005 9 did you engage in sex or sex acts with a minor 10 female named =phonetic)? 11 MR. BURMAN: Object to form, vague and 12 indefinite. Last name, please. 13 MR. EDWARDS: You can answer. 14 THE WITNESS: I intend to respond to all 15 relevant questions regarding this lawsuit 16 However, at the present time my attorneys have 17 counseled me that I cannot provide answers to 18 any questions relevant to this lawsuit, and I 19 must accept this advice or risk losing my Sixth 20 Amendment right to effective representation. 21. Accordingly, I assert my Federal 22 Constitutional right as guaranteed by the 23 Fifth, Sixth, and Fourteenth Amendment to the 24 United States Constitution. 25 Q. (By Mr. Edwards) Between 2001 and 2005 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 52 did you engage in sex or sex acts with a minor female named (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However at the present time myttome s have - 13 (Pages 49 to 52) PALM BEACH REPORTING SERVICE, INC. EFTA01103338 Page 53 1 counseled me that I cannot provide answers to 2 any questions relevant to this lawsuit, and I 3 must accept this advice or risk losing my Sixth 4 Amendment right to effective representation. Accordingly, I assert my Federal 6 Constitutional right as guaranteed by the 7 Fifth, Sixth, and Fourteenth Amendment to the 8 United States Constitution 9 Q. (By Mr. Edwards) Between 2001 and 2005 10 did you engage in sex or sex acts with a minor 11 female named El==. 12 MR. BURMAN: Object to form, vague and 13 indefinite. Last name, please. 14 MR. EDWARDS: You can answer. 15 THE WITNESS: I intend to respond to all 16 relevant questions regarding this lawsuit. 17 However, at the present time my attorneys have 18 counseled me that I cannot provide answers to 19 any questions relevant to this lawsuit, and I 20 must accept this advice or risk losing my Sixth 21 Amendment right to effective representation. 22 Accordingly, I assert my Federal 23 Constitutional right as guaranteed by the 24 Fifth, Sixth, and Fourteenth Amendment to the 25 constitution. 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 55 any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) For the purposes of these next questions, when I refer to "the minor Its" I'm refeninc to S, my client, which is the plaintiff in this lawsuit. My question is -- MR. GOLDBERGER: You've identified that correct? MR. EDWARDS: Correct. Q. (By Mr. Edwards) With each of these girls, isn't it true that you paid somebody else to 1 Page 54 1. Q. (By Mr. Edwards) Isn't it true that at 2 the time you engaged in sex or sex acts with each of 3 the people we have just discussed, you knew they 4 were minors? 5 MR. BURMAN: Object to form. 6 THE WITNESS: I intend to respond to all 7 relevant questions regarding this lawsuit. 8 However, at the present time my attorneys have 9 counseled me that I cannot provide answers to 10 any questions relevant to this lawsuit, and 11 must accept this advice or risk losing my Sixth 12 Amendment right to effective representation. 13 Accordingly, I assert my Federal 14 Constitutional right under the Fifth, Sixth, 15 and Fourteenth Amendment to the United States 16 Constitution. 17 Q. (By Mr. Edwards) With each of these 18 girls, isn't it hue that you used someone else to 19 recruit them to your house? 20 MR. BURMAN: Object to form, vague and 23. indefinite. 22 THE WITNESS: I intend to respond to all 23 relevant questions regarding this lawsuit. 24 However, at the present time my attorneys have 25 counseled me that I cannot rovide answers to 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 56 bring them to your house? MR. BURMAN: Object to the form, vague and indefinite. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, ! assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) For each of these minor girls, isn't it true that you paid each of them for sex or sex acts? MR. BURMAN: Object to form, vague and indefinite. Further explaining that to the extent that no ►ast names have been identified for most of the girls. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However at the .resent time attom have 14 Pa es 53 to 56) PALM BEACH REPORTING SERVICE, INC. EFTA01103339 Page 57 1 counseled me that I cannot provide answers to 2 any questions relevant to this lawsuit, and 3 must accept this advice or risk losing my Sixth 4 Amendment right to effective representation. 5 Accordingly, I assert my Federal 6 Constitutional tight as guaranteed by the 7 Fifth, Sixth, and Fourteenth Amendment to the 8 United States Constitution. 9 Q. (By Mr. Edwards) Isn't it true that in 10 order to recruit each of these minor girls to your 11 house, you had someone tell them, "A rich guy in 12 Palm Beach will pay you cash to go to his house and 13 give him a massage"? 14 MR. BURMAN: Object to form, vague and 15 indefinite, to the extent last names of the 16 girls have not been identified. 17 THE WITNESS: I intend to respond to all 18 relevant questions regarding this lawsuit 19 However, at the present time my attorneys have 20 counseled me that I cannot provide answers to 21 any questions relevant to this lawsuit. I must 22 accept this advice or risk losing my Sixth 23 Amendment right to effective representation. 24 Accordingly, I assert my Federal 25 Constitutional right as guaranteed by the Page 58 1 Fifth, Sixth, and Fourteenth Amendment of the 2 United States Constitution. 3 Q. (By Mr. Edwards) Each of these minor 4 girls, when arriving at your house, was greeted at 5 the door by one of your employees at your mansion, 6 isn't that correct? 7 MR. BURMAN: Object to form, vague and 8 indefinite. No description of last names of 9 the alleged minor girls. 10 THE WITNESS: I intend to respond to all 11 relevant questions regarding this lawsuit 12 However, at the present time my attorneys have 13 advised me that I cannot provide answers to any 14 questions relevant to this lawsuit, and I must 15 accept this advice or risk losing my Sixth 16 Amendment right to effective representation. 17 Accordingly, I assert my Federal 18 Constitutional right as guaranteed by the 19 Fifth, Sixth, and Fourteenth Amendment to the 20 United States Constitution. 21 Q. (By Mr. Edwards) Each of these minor 22 girls was escorted up to your bedroom by one of your 23 employees, isn't that correct? 24 MR. BURMAN: Object to the form, vague and 25 indefinite. Page 59 1 THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit. 3 However, at the present tint my attorneys have 4 counseled me that I cannot provide answers to 5 any questions relevant to this lawsuit, and I 6 must accept this advice or risk losing my Sixth 7 Amendment right to effective representation. 8 Accordingly, I assert my Federal 9 Constitutional rights as guaranteed by the 10 Fifth, Sixth, and Fourteenth Amendment to the 11 United States Constitution. 12 May I just ask, step outside for a second, 13 I want to just ask a question. 14 MR. BURMAN: Sure. 15 THE VIDEOGRAPHER: Going off the record at 16 11:11. 17 (Thereupon, a brief break was taken.) 18 THE VIDEOGRAME12: Okay, we're back on the 19 record at 11:16. 20 Q. (By Mr. Edwards) Previously I named, or I 21 gave you the names of 49 minor girls. Isn't it true 22 that you engaged in sex or sex acts with each of 23 them? 24 MR. BURMAN: Object to the form, vague and 25 indefinite. Last names weren't provided for Page 60 1 most of them. 2 THE WITNESS: I intend to respond to all 3 relevant questions regarding this lawsuit 4 However, at the present time my attorneys have 5 counseled me that I cannot provide answers to 6 any questions relevant to this lawsuit, and 7 must accept that advice or risk losing my Sixth 8 Amendment right to effective representation. 9 Accordingly, I assert my Federal 10 Constitutional right as guaranteed by the 11 Fifth, Sixth, and Fourteenth Amendment to the 12 constitution. 13 Q. (By Mr. Edwards) With respect to each of 14 the minor girls that was taken into your bedroom by 15 one of your employees, isn't it true that you 16 entered the room wearing only a towel? 17 MR. BURMAN: Object to form, vague and 18 indefinite, last names of the alleged minor 19 girls weren't provided. 20 THE WITNESS: I intend to letwnd to all 21 relevant questions regarding this lawsuit 22 However, at the present time my attorneys have 23 counseled me that 1 cannot provide answers to 24 any questions relevant to this lawsuit, and 25 must accept this advice or risk losing my Sixth 15 (Pages 57 to 60) PALM BEACH REPORTING SERVICE, INC. EFTA01103340 Page 61 1 Amendment right to effective representation. 2 Accordingly, my federal, I have to assert 3 my Federal Constitutional rights as guaranteed 4 by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. 6 Q. (By Mr. Edwards) With respect to each of 7 these minor girls, isn't it true that you ordered 8 each of them to get naked to give you a massage? 9 MR. BURMAN: Object to form, vague and 10 indefinite with regard to the alleged minor 11 girls, the names weren't provided. Last names 12 weren't provided. 13 MR. EDWARDS: You can answer. 14 THE WITNESS: I intend to respond to all 15 relevant questions regarding this lawsuit. 16 However, at the present time my attorneys have 17 counseled me that I cannot provide answers to 18 any questions relevant to this lawsuit, and I 19 must accept this advice or risk losing my Sixth 20 Amendment right to effective representation. 21 Accordingly, I assert my Federal 22 Constitutional right as guaranteed by the 23 Fifth, Sixth, and Fourteenth Amendment to the 24 United States Constitution. 25 Q. (By Mr. Edwards) With rebind to each of Page 62 1 the 49 named minor girls, isn't it true that you 2 masturbated in front of each of them? 3 MR. BURMAN: Object to the form, vague and 4 indefinite with regard to the alleged minor 5 girls, their last names weren't provided. 6 THE WITNESS: I intend to respond to all 7 relevant questions regarding this lawsuit 8 However, at the present time my attorneys have 9 counseled me that i cannot provide answers to 1 o any questions relevant to this lawsuit, and I 11 must accept their advice or risk losing my 12 Sixth Amaidment right to effective 13 representation. 14 Accordingly, lessen my Federal 15 Constitutional rights as guaranteed by the 16 Fifth, Sixth, and Fourteenth Amendment to the 17 United States Constitution. 18 Q. (By Mr. Edwards) Isn't it true that you 19 asked each of the minor girls to do similar things 20 to you, such as rub your nipples? 21 MR. BURMAN: Object to the form, vague and 22 indefinite with regard to the alleged minor 23 girls, the last names weren't provided. 24 THE WITNESS: I intend to respond to all 25 relevant uestions re anii this lawsuit. Page 63 1. However, at the present time my attorneys have 2 counseled me that I cannot provide answers to 3 any questions relevant to this lawsuit, and I 4 must accept this advice or risk losing my Sixth 5 Amendment right to effective reptw‘ntation. 6 Accordingly, I assert my Federal 7 Constitutional rights as guaranteed by the 8 Fifth, Sixth, and Fourteenth Amendment to the 9 United States Constitution. 10 Q. (By Mr. Edwards) With respect to all of 11 the named 49 minor girls, isn't it true that you 12 tried to touch each of them in a sexual way? 13 Wt. BURMAN: Object to font vague and 14 indefinite with regard to the alleged minor 15 girls, last names weren't provided. 16 THE WITNESS: I intend to respond to all 17 relevant questions regarding this lawsuit 18 However, at the present time my attorneys have 19 counseled me that I cannot provide answers to 20 any questions relevant to this lawsuit. I must 21 accept this advice or risk losing my Sixth 22 Amendment right to effective representation. 23 Accordingly, I assert my Federal 24 Constitutional rights as guaranteed by the 25 Fifth, Sixth, and Fourteenth Amendment to the 1 2 3 4 5 6 8 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 64 United States Constitution. Q. (By Mr. Edwards) With respect to each of the 49 minor girls, isn't it true that you touched their bare breasts? MR. BURMAN: Object to form, vague and indefinite with regard to the alleged minor girls, last names weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. And I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) With respect to each of these 49 minor girls, isn't it true that you inserted your fingers into their vaginas? MR. BURMAN: Object to form of the question, vague and indefinite with regard to the alleged minor girls, last names weren't vided. e...“...-Seawaottamar aaa•••••••eassaa..........vawaserwarirsesearsaw. 16 (Pages 61 to 64) PALM BEACH REPORTING SERVICE, INC. EFTA01103341 Page 65 i. THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit. 3 However, at the present time my attorneys have 4 counseled me that I cannot provide answers to 5 any questions relevant to this lawsuit, and I 6 must accept this advice or risk losing my Sixth 7 Amendment right to effective representation. 8 Accordingly, I assert my Federal 9 Constitutional rights as guaranteed by the 10 Fifth, Sixth, and Fourteenth Amendment to the 11 United States Constitution. 12 Q. (By Mr. Edwards) With respect to the 49 13 named minor girls, isn't it true that you attempted 14 to use vibrators on each of them? 15 MR. BURMAN: Object to the form of the 16 question, vague and indefinite with regard to 17 the alleged minor girls, last names weren't 18 provided. 19 MR. EDWARDS: You can answer. 20 THE WITNESS: I intend to respond to all 21 relevant questions regarding this lawsuit. 22 However, at the present time my attorneys have 23 counseled me that I cannot provide answers to 24 any questions relevant to this lawsuit, and I 25 must accept this advice or risk losing my Sixth Page 66 1 Amendment right to effective representation. 2 Accordingly, I assert my Federal 3 Constitutional rights as guaranteed by the 4 Fifth, Sixth, and Fourteenth Amendment to the 5 United States Constitution. 7 Q. (By Mr. Edwards) Be 001 and 2005 did you have a woman named living 6 8 at your Palm Beach house with you? 9 A. I intend to respond to all relevant 10 questions regarding this lawsuit. However, at the 11 present time my attorneys have counseled me that I 12 cannot provide answers to any questions relevant to 13 this lawsuit, and I must accept this advice or risk 14 losing my Sixth Amendment right to effective 15 representation. 16 Accordingly, I assert my Federal 17 Constitutional right as guaranteed by the Fifth, 18 Sixth, and Fourteenth Amendment to the United States 19 Constitution. your Yugoslavian Ideesbituaa ex s ve? 20 rue that you consi 21 22 A. I intend to respond to all relevant 23 questions regarding this lawsuit. However, at the 24 present time my attorneys have counseled me that I 25 cannot vide answers to an uestions relevant 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 67 this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Can you tell me why it is that you just I asked you the last question about MR. GOLDBERGER: Don't answer that. Q. (By Mr. Edwards) Did you think the question was ninny? MR. BURMAN: Object to form. MR. GOLDBERGER: You can answer. THE WITNESS: No. B Mr. Edwards) Do you know A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Page 68 1 Accordingly, I assert my Federal 2 Constitutional rights as guaranteed by the Fifth, 3 Sixth, and Fourteenth Amendment to the United States 4 Constitution. 5 Q. Isn't it true that you brought Minn) 6 the room to have threesome sex with you and many of 7 these minor female girls? 8 MR BURMAN: Object to the form of the 9 question, vague and indefinite with regard to to the word "may" and with regard to the fact that 11 last names haven't been described, or 12 disclosed. 13 THE WITNESS: I intend to respond to all 14 relevant questions regarding this lawsuit. 15 However, at the present time my attorneys have 16 counseled me that I cannot provide answers to 17 any questions relevant to this lawsuit, and I 18 mist accept this advice or risk losing my Sixth 19 Amendment right to effective representation. 20 Accordingly, i assert Federal 21 Constitutional rights as guaranteed by the 22 Fifth, Sixth, and Fourteenth Amendment to the 23 United States Constitution. 24 Q. (By Mr. Edwards) Isn't it true that you 25 'aculated in front of each of these minor a ls? 17 (Pages 65 to 68) PALM BEACH REPORTING SERVICE, INC. EFTA01103342 Page 69 1 MR. BURMAN: Object to form, vague and 2 indefinite. Last names were not provided of 3 the alleged minor girls. 4 THE WITNESS: I intend to respond to all 5 relevant questions regarding this lawsuit. 6 However, at the present time my attorneys have 7 counseled me that I cannot provide answers to 8 any questions relevant to this lawsuit, and I 9 must accept this advice or risk losing my Sixth 10 Amendment right to effective representation. 13. Accordingly, I assert my Federal 12 Constitutional rights as guaranteed by the 13 Fifth, Sixth, and Fourteenth Amendment to the 14 United States Constitution. 15 Q. (By Mr. Edwards) With respect to each of 16 these 49 minor girls, isn't it true that you paid 17 each of them for sex? 18 MR. BURMAN: Object to the form, vague and 19 indefinite. Last names of the many of the 20 minor girls were not provided, alleged minor 21 girls. 22 THE WITNESS: I intend to respond to all 23 relevant questions regarding this lawsuit. 24 However, at the present time my attorneys have 25 counseled me that I cannotprovide answers to Page 70 1 any questions relevant to this lawsuit, and I 2 must accept this advice or risk losing my Sixth 3 Amendment right to effective representation. 4 Accordingly, I assert my Federal Constitutional rights as guaranteed by the 6 Fifth, Sixth, and Fourteenth Amendment to the 7 United States Constitution. 8 Q. (By Mr. Edwards) Isn't it true that you 9 offered each of the 49 minor girls money if she 10 would bring you more minor girls for you to engage 11 in sex or sex acts with? 12 MR. BURMAN: Object to the fan, vague and 13 indefinite. Last names of many of the alleged 14 minor girls weren't provided. 15 THE WITNESS: I intend to respond to all 3.6 relevant questions regarding this lawsuit. 17 However, at the present time my attorneys have 18 counseled me that I cannot provide answers to 19 any questions relevant to this lawsuit, and 20 must accept their advice or risk losing my 21 Sixth Amendment right to effective 22 representatiOn. 23 Accordingly, I assort my Federal 24 Constitutional rights as guaranteed by the 25 Fifth,Sixth and Fourteenth Amendment to the Page 71 1 United States Constitution. 2 Q. (By Mr. Edwards) With respect to each of 3 the 49 named minor girls, isn't it true that the sex 4 or sex acts occurred in your bedroom? 5 MR. BURMAN: Object to form of the 6 question, vague and indefinite with regard to 7 the alleged minor girls, the last names weren't 8 provided. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit. 11 However, at the present time my attorneys have 12 counseled me that I cannot provide answers to 13 any questions relevant to this lawsuit, and 14 must accept this advice or risk losing my Sixth 15 Amendment right to effective representation. 16 Accordingly, I assert my Federal 17 Constitutional right as guaranteed by the 18 Fifth, Sixth, and Fourteenth Amendment to the 19 United States Constitution. 20 Q. (By Mr. Edwards) With respect to each of 21 these minor girls, isn't it true that certain other 22 employees of yours played a role in authoring your 23 sexual contact with these minors? 24 MR. BURMAN: Object to the form of the 25 question, vague and indefinite with regard to Page 72 1 the alleged minors, last names weren't 2 provided. 3 THE WITNESS: Could you repeat the 4 question? Sorry. 5 Q. (By Mr. Edwards) Sure. 6 With respect to the 49 minor girls whose 7 names i provided, isn't it true that certain 8 employees of yours played a role in furthering 9 sexual contact between you and these minors? 10 MR. BURMAN: Same objection. 11 THE WITNESS: I intend to respond to all 12 relevant questions regarding this lawsuit. 13 However, at the present time my attorneys have 14 counseled me that I cannot provide answers to 15 any questions relevant to this lawsuit, and I 16 must accept this advice or risk losing my Sixth 17 Amendment right to effective representation. 18 Accordingly, I assert my Federal 19 Constitutional rights as guaranteed by the 20 Fifth, Sixth, and Fourteenth Amendment to the 21 United States Constitution. 22 Q. (By Mr. Edwards) Some of your employees 23 were delegated the responsibility of cleaning your 24 sex toys after you engaged in sex with minor girls, 25 isn't that true? 18 (Paces 69 to 72) PALM BEACH REPORTING SERVICE, INC. EFTA01103343 Page 73 3. MR BURMAN: Are you referring to the 49 2 alleged minors that you just identified, or is 3 this a generic question? 4 MR. EDWARDS: Yes, the 49, that -- 5 THE WITNESS: Can you repeat the question 6 please? 7 MR. EDWARDS: — are known to us. 8 MR. BURMAN: Okay. Object to the form, 9 vague and indefinite with regard to the alleged 10 minors, last names weren't provided. 13. THE WITNESS: I intend to imp und to all 12 relevant questions regarding this lawsuit 13 However, at the present time my attorneys have 14 counseled me that I cannot provide answers to 15 any questions relevant to this lawsuit, and I 16 must accept this advice or risk losing my Sixth 17 Amendment right to effective representation. 18 Accordingly, I assert my Federal 19 Constitutional right as guaranteed by the 20 Fifth, Sixth, and Fourteenth Amendment to the 21 United States Constitution. 22 Q. (By Mr. Edwards) Isn't it true that you 23 hired employees to work for you for the sole purpose 24 of scheduling minor girls to come to your house for 25 sex? Page 74 1 MR. BURMAN: Once again, are you referring 2 to the 49 you identified, or just generic? 3 MR. EDWARDS: General question. 4 MR. BURMAN: General question? 5 MR. EDWARDS: Right. 6 THE WITNESS: I intend to respond to all 7 relevant questions regarding this lawsuit. 8 However, at the present time my attorneys have 9 counseled me that I cannot provide answers to 10 any questions relevant to this lawsuit, and I 11 must accept this advice or risk losing my Sixth 12 Amendment right to effective representation. 13 Accordingly, I assert my Federal 14 Constitutional rights as guaranteed by the 15 Fifth, Sixth, and Fourteenth Amendment to the 16 United States Constitution. 17 Q. (By Mr. Edwards) Isn't it true that you 18 hired employees that were delegated responsibilities 19 in order to assist you in avoiding detection of your 20 actions by law enforcement? 21 THE WITNESS: What's the question? 22 MR.. BURMAN: Object to the form, vague and 23 indefinite. 24 THE WITNESS: Could you repeat it again? 25 MR. EDWARDS: Sure, ni clean it, Page 75 1 Q. (By Mr. Edwards) Isn't it true that you 2 had employees working for you with a purpose of 3 helping you to avoid detection of your criminal 4 activities by law enforcement? 5 MR. BURMAN: Object to form, vague an 6 indefinite. 7 THE WITNESS: I intend to respond to all 8 relevant questions regarding this lawsuit. 9 However, at the present time my attorneys have 10 counseled me that I cannot provide answers to 11 any questions relevant to this lawsuit, and I 12 must accept this advice or risk losing my Sixth 13 Amendment right to effective representation. 14 Accordingly, I assert my Federal 15 Constitutional rights as guaranteed by the 16 Filth, Sixth, and Fourteenth Amendment to the 17 united States Constitution. 18 Q. (By Mr. Edwards) Did you have operable 3.9 surveillance equipment inside your house from 2001 20 through 2006 in your Palm Beach house? 21 MR. BURMAN: Objection, vague and 22 indefinite. 23 THE WITNESS: I intend to respond to all 24 relevant questions regarding this lawsuit. 25 However, at this present time my attorney has Page 76 1 counseled me that I cannot provide answers to 2 any questions relevant to this lawsuit, and I 3 must accept this advice or risk losing my Sixth 4 Amendment tight to effective representation. 5 Accordingly, I assert my Federal 6 Constitutional rights as guaranteed by the 7 Fifth, Sixth, and Fourteenth Amendment to the 8 United States Constitution. 9 Q. (By Mr. Edwards) Did you destroy or 10 tamper with evidence, including computer images, 11 computer equipment, surveillance equipment, photos, 12 notes, diaries, or photocopy records as a result of 13 the criminal investigation of you between 2001 and 14 2006? 15 MR. GOLDBERGER: Let me object on the 16 form. Are you asking, are you suggesting that 3.7 there is a criminal investigation that went on 18 between 2001 and 2006? Is that the question? 19 MR. EDWARDS: Well, at some time, at some 20 point in time there was, since he pled guilty. 21 MR GOLDBERGER: But what's the purpose of 22 the 2001 to 2006? Maybe you can rephrase the 23 question. 24 MR. EDWARDS: Okay. 25 (B Mr. Edwards) How about this. Have 19 Pa es 73 to 76 PALM BEACH REPORTING SERVICE, INC. EFTA01103344 Page 77 1 you ever at any time destroyed or tampered with any 2 evidence of your involvement with minor girls? 3 A. I intend to respond to an relevant 4 questions regarding this lawsuit. However, at the 5 present time my attorneys have counseled me that 6 cannot answer questions with respect to this 7 lawsuit, and must accept their advice or risk losing 8 my Sixth Amendment right to effective 9 representation. 10 Accordingly, I assert my Federal 11 Constitutional Rights as guaranteed by the Fifth, 12 Sixth, and Fourteenth Amendments to the United 13 States Constitution. 14 Q. Have you ever destroyed computer images or 15 computer equipment because of a fear it would be 16 used against you in a prosecution for your sexual 17 involvement with minor girls? 18 A. I intend to respond to all relevant 19 questions regarding this lawsuit However, at the 20 present time my attorneys have counseled me that 1 21 cannot provide answers to any questions relevant to 22 this lawsuit, and I must accept this advice or risk 23 losing my Sixth Amendment right to effective 24 representation. 25 Accordingly, i assert my Federal Page 78 3. Constitutional rights as guaranteed by the Fifth, 2 Sixth, and Fourteenth Amendment to the United States 3 Constitution. 4 Q. Did you ever, at any time, destroy 5 photographs, notes, or diaries in an effort to avoid 6 detection by law enforcement? 7 A. I intend to respond to all relevant 8 questions regarding this lawsuit. However, at the 9 present time my attorneys have counseled me that 1 o cannot provide answers to any questions relevant to 11 this lawsuit, and I must accept this advice or risk 12 losing my Sixth Amendment right to effective 13 representation. 14 Accordingly, I assert my Federal 15 Constitutional rights as guaranteed by the Fifth, 16 Sixth, and Fourteenth Amendment to the United States 17 Constitution. 18 Q. Did other people hired by you destroy or 19 tamper with evidence in an effort to avoid detection 20 of criminal activities or prosecution? 21 A. I intend to respond to all relevant 22 questions regarding this lawsuit. However, at the 23 present time my attorneys have counseled me that I 24 cannot provide answers to any questions relevant to 25 this lawsuit and I must accept this advice or risk Page 79 1 losing my Sixth Amendment right to effective 2 representation. 3 Accordingly, lessen my Federal 4 Constitutional rights as guaranteed by the Fifth, 5 Sixth, and Fourteenth Amendment to the United States 6 Constitution. 7 Q. Was your house at some point in time in 8 Palm Beach burglarized by a former housekeeper named 9 Juan Allessee (phonetic)? 10 A. Yes. 11 Q. In relation to that burglary, did you 12 provide the Palm Beach Police Department with 13 surveillance video from the inside of your house? 14 A. I intend to respond to all relevant 15 questions regarding this lawsuit However, at the 16 present tint my attorneys have counseled me that I 17 cannot provide answers to any questions relevant to 18 this lawsuit, and I must accept this advice or risk 19 losing my Sixth Amendment right to effective 20 representation. 21 Accordingly, I assert my Federal 22 Constitutional rights as guaranteed by the Fifth, 23 Sixth, and Fourteenth Amendment to the United States 24 Constitution. 25 Q. At the time your house was burglarized, ' Page 80 1 how many operable surveillance cameras were inside 2 your house? 3 A. I intend to respond to all relevant 4 questions regarding this lawsuit. However, at the 5 present time my attorneys have counseled me that I 6 cannot provide answers to any questions relevant to 7 this lawsuit, and I must accept this advice or risk 8 losing my Sixth Amendment right to effective 9 representation 22 assert deral 25 guiQqlty. plfHleaothwoccurr ceil : thriIdeon cor JuTdrno3yr0 d i F te indicate rds , b2e0; b that elieve is yourou thatw, were 23 something you'd quarrel with? 24 A. No. 10 11 Constitutional rights as guaranteed by the Fifth, 12 Sixth, and Fourteenth Amendment to the United States 13 Constitution. 14 Q. How long have you been on work release? 3.5 MR. GOLDBERGER: Hang on. Yeah, he can -- 16 that's fine. 17 THE WITNESS: A little over six months. 18 Q. (By Mr. Edwards) You know the date that 19 you started work release? 20 A. No. 21 20 (Pages 77 to 80) PALM BEACH REPORTING SERVICE, INC. EFTA01103345 Page 81 1 in the county jail after that June 30th, 2008 plea 2 before you were granted work release? 3 MR. GOLDBERGER: If you know. 4 THE WITNESS: Couple of months. 5 Q. (By Mr. Edwards) Do you know if any of 6 your victims were informed of your petition for work 7 release? 8 A. I do not know. 9 Q. When NM the Florida Science Foundation 10 created? 11 A. I intend to respond to all relevant 12 questions regarding this lawsuit. However, at the 13 present time my attorneys have counseled me that I 14 cannot provide answers to any questions relevant to 15 this lawsuit, and must accept this advice or risk 16 losing my Sixth Amendment right to effective 17 representation. 18 Accordingly, I assert my Federal 19 Constitutional rights as guaranteed by the Fifth, 20 Sixth, and Fourteenth Amendment to the United States 21 Constitution. 22 Q. Isn't it true that you created the Florida 23 Science Foundation months before pleaing guilty 24 knowing that you would eventually be on work release 25 in an office right next to your attorney's office? Page 82 1 MR. BURMAN: Object to the form. 2 THE WITNESS: I intend to respond to all 3 relevant questions regarding this lawsuit. 4 However, at the present time my attorneys have 5 counseled me that I cannot provide answers to 6 any questions relevant to this lawsuit, and 7 must accept this advice or risk losing my Sixth 8 Amendment right to effective representation. 9 Accordingly, I assert my Federal 10 Constitutional rights as guaranteed by the 11 Filth, Sixth, and Fourteenth Amendment to the 12 constitution. 13 Q. (By Mr. Edwards) Since being sentenced in 14 June of 2008, have you had contact with any minors? 15 MR.. GOLDBERGER: You can answer that. 16 THE WITNESS: I intend to respond to all 17 relevant questions regarding this lawsuit. 18 However, at the present time my attorneys have 19 counseled me that I cannot provide answers to 20 any questions relevant to this lawsuit, and 21 must accept this advice or risk losing my Sixth 22 Amendment right to effective representation. 23 Accordingly, I assert my Federal 24 Constitutional rights as guaranteed by the 25 Fifth, Sixth and Fourteenth Amendment to the %Ow Page 83 1 constitution. 2 Q. (By Mr. Edwards) Do you currently have 3 access to a computer that you use? 4 A. I intend to respond to all relevant 5 questions regarding this lawsuit However, at the 6 present time my attorneys have counseled me that I 7 cannot provide answers to any questions relevant to 8 this lawsuit I must accept this advice or risk 9 losing my Sixth Amendment right to effective 10 representation. 11 Accordingly, I assert my Federal 12 Constitutional rights as guaranteed by the Fifth, 13 Sixth, and Fourteenth Amendment to the constitution. 14 Q. What is e-mail address that you have been 15 using since being sentenced in 2008? 16 MR. GOLDBERGER: Object to the form, 17 assumes facts not in evidence. 18 THE WITNESS: I intend to respond to all 19 relevant questions regarding this lawsuit. 20 However, at the present time my attorneys have 21 counseled me that I cannot provide answers to 22 any questions relevant to this lawsuit, and I 23 must accept this advice or risk losing my Sixth 24 Amendment right to effective representation. 25 Accordingly, I assert my Federal Page 84 1 Constitutional rights as guaranteed by the 2 Fifth, Sixth, and Fourteenth Amendment to the 3 United States Constitution. 4 Q. (By Mr. Edwards) Do you intend to 5 communicate with any minors once you are released to 6 house arrest? 7 A. I intend to respond to all relevant 8 questions regarding this lawsuit. However, at the 9 present time my attorneys have counseled me that I 10 cannot provided answers to any questions relevant to 11 this lawsuit, and I must accept this advice or risk 12 losing my Sixth Amendment right to effective 13 ivin dation. 14 Accordingly, I assert my Federal 15 Constitutional rights as guaranteed by the Fifth, 16 Sixth, and Fourteenth Amendment to the United States 17 Constitution. 18 Q. Is it true that you have been diagnosed by 19 a psychologist with a sexual disorder related to 20 your sexual appetite for minor girls? 23. A. I intend to respond to all relevant 22 questions regarding this lawsuit. However, at the 23 present time my attorneys have counseled me that I 24 cannot provide answers to any questions relevant to 25 this lawsuit, and I most acceptthis advice or risk 21 (Pages 81 to 84) PALM BEACH REPORTING SERVICE, INC. EFTA01103346 Page 85 1 losing my Sixth Amendment right to effective 2 representation. 3 Accordingly, I assert my Federal 4 Constitutional rights as guaranteed by the Fifth, 5 Sixth, and Fourteenth Amendment to the constitution. 6 Q. Isn't it true that you intend to continue 7 engaging in sex acts with minor girls once you are 8 released? 9 MR. BURMAN: Object to the form. 10 THE WITNESS: I intend to respond to all 11 relevant questions regarding this lawsuit. 12 However, at the present time my attomeys have 13 counseled me that I cannot provide answers to 14 any questions relevant to this lawsuit, and I 15 must accept this advice or risk losing my Sixth 16 Amendment right to effective representation. 17 Accordingly, I assert my Federal 18 Constitutional rights as guaranteed by the 19 Fifth, Sixth, and Fourteenth Amendment to the 20 United States Constitution. 21 Q. (By Mr. Edwards) Have you engaged in sex 22 or sex acts with minor girls outside of the United 23 States? 24 A. I intend to respond to all relevant 25 questions regarding this lawsuit. However, at the Page 86 1 present time my attorneys have counseled me that I 2 cannot provide answers to any questions relevant to 3 this lawsuit, and must accept this advice or risk 4 losing my Sixth Amendment right to effective 5 representation. 6 Accordingly, I assert my Federal 7 Constitutional rights as guaranteed by the Fifth, 8 Sixth, and Fourteenth Amendment to the United States 9 Constitution. 10 Q. Is it true that you have your own island? 11 MR. BURMAN: Object, also on the, on the 12 grounds that the punitive damages haven't been 13 allowed yet. Not relevant. 14 MR. EDWARDS: Answer. 15 THE WITNESS: I intend to respond to all 16 relevant questions regarding this lawsuit. 17 However, at the present time my attorneys have 18 counseled me that I cannot provide answers to 19 any questions relevant to this lawsuit, and I 20 must accept this advice or risk losing my Sixth 21 Amendment right to effective representation. 22 Accordingly, I assert my Federal 23 Constitutional rights under the Fifth, Sixth, 24 and Fourteenth Amendment to the United States 25 Constitution. Page 87 1 Q. (By Mr. Edwards) Have you engaged in sex 2 or sex acts with minors on the island of Little 3 St. Jeffs? 4 A. I intend to respond to all relevant 5 questions regarding this lawsuit. However, at the 6 present time my attorneys have counseled me that I 7 cannot provide answers to any questions relative to 8 this lawsuit, and must accept this advice or risk 9 losing my Sixth Amendment right to effective 10 representation. 11 Accordingly, I assert my Federal 12 Constitutional rights as guaranteed by the Fifth, 13 Sixth, and Fourteenth Amendment to the United States 14 Constitution. 15 Q. Isn't it true that you have engaged in 16 sexual acts or sex with girls as young as 12 years 17 old? 18 A. I intend to respond to all relevant 19 questions regarding this lawsuit. However, at the 20 present time my attorneys have counseled me that I 21 cannot provide answers to any questions relevant to 22 this lawsuit, and I must accept this advice or risk 23 losing my Sixth Amendment right to effective 24 representation. 25 Accordingly, I assert my Federal Page 88 1 Constitutional tights as guaranteed by the Fifth, 2 Sixth, and Fourteenth Amendment to the United States 3 Constitution. 4 Q. What is the youngest girl that you have 5 engaged in sex or sex acts with in the last ten 6 years? 7 A. I intend to respond to all relevant 8 questions regarding this lawsuit. However, at the 9 present time my attorneys have counseled me that I 10 cannot provide answers to any questions relevant to 11 this lawsuit, and must accept this advice or risk 12 losing my Sixth Amendment right to effective 13 representation. 14 Accordingly, I assert under the Federal 15 Constitutional rights as guaranteed by the Fifth, 16 Sixth and Fourteenth Amendment to the United States 17 Constitution. 18 Q. Have you discussed with any of your 19 friends the fact that you engage in sex or sex acts 20 with minors? 21 A. I intend to respond to all relevant 22 questions regarding this lawsuit. However, at the 23 present time my attorneys have counseled me that I 24 cannot provide answers to any questions relevant to 25 this lawsuit and I must this advice or risk AISIoadal• 22 (Pages 85 to 88 PALM BEACH REPORTING SERVICE, INC. EFTA01103347 Page 89 1 losing my Sixth Amendment right to effective 2 representation. 3 Accordingly, I assert my Federal 4 Constitutional rights as guaranteed by the Fifth, 5 Sixth, and Fourteenth Amendment to the United States 6 Constitution. 7 Q. Did you know that the girls that were 8 providing you massages were under the age of 18 at 9 the time they were doing so? 10 A. I intend to respond to all relevant 11 questions regarding this lawsuit. However, at the 12 present time my attorneys have counseled me that I 13 cannot provide answers to any questions relevant to 14 this lawsuit, and I must accept their advice or risk 15 losing my Sixth Amendment right to effective 16 representation. 17 Accordingly, I assert my Federal 18 Constitutional rights as guaranteed by the Fifth, 19 Sixth, and Fourteenth Amendment to the United States 20 Constitution. 21 Q. Isn't it true that the age group that you 22 enjoy to engage in sex with is between 12 and 16 23 yearsold? 24 MR. BURMAN: Object to form. 25 THE WITNESS: I intend to respond to all Page 91 1 Amendment right to effective representation. 2 Accordingly, I assert my Federal 3 Constitutional rights as guaranteed by the 4 Filth, Sixth, and Fourteenth Amendment to the 5 United States Constitution. 6 Q. (By Mr. Edwards) Isn't it true that you 7 devised a scheme or plan to engage in sex or sex 8 acts with multiple minor girls? 9 A. I intend to respond to all relevant 10 questions regarding this lawsuit. However, at the 11 present time my attorneys have counseled me that I 12 cannot provide answers to any questions relevant to 13 this lawsuit, and I must accept this advice or risk 14 losing my Sixth Amendment right to effective 15 representation. 16 Accordingly, I must assert my Federal 17 Constitutional rights as guaranteed by the Fifth, 18 Sixth, and Fourteenth Amendment to the United States 19 Constitution. 20 THE WITNESS: Can I take a pee break? 21 THE VIDEOGRAPHER: We're off the record at 22 11:50. This will be the end of tape one. 23 (Thereupon, a brief break was taken.) 24 THE VIDEOGRAPHER: This is the beginning 25 of tape number two, and we're back on the Page 90 3. relevant questions regarding this lawsuit. 2 However, at the present time my attorneys have 3 counseled me that I cannot provide answers to 4 any questions relevant to this lawsuit, and I 5 must accept this advice or risk losing my Sixth 6 Amendment right to effective representation. 7 Accordingly, I assert my Federal 8 Constitutional rights as guaranteed by the 9 Fifth, Sixth, and Fourteenth Amendment to the 10 constitution. 11. Q. (By Mr. Edwards) Do you agree with the 12 laws that prohibit you from having sex or engaging 13 in sex acts with minors? 14 MR. BURMAN: Object to form. 15 THE WITNESS: Can you repeat the question? 16 Q. (By Mr. Edwards) Do you agree with the 17 laws that prohibit you from engaging in sex or sex 18 acts with minor girls? 19 MR. BURMAN: Object to the form. 20 THE WITNESS: I intend to respond to all 21 relevant questions regarding this lawsuit. 22 However, at the present time my attorneys have 23 counseled me that I cannot provide answers to 24 any questions relevant to this lawsuit, and I 25 must accept this advice or risk losittgmiSixth Page 92 3. record at 11:59. 2 Q. (By Mr. Edwards) Between 2001 and 2005 3 did you digitally penetrate the vaginas of more than 4 50 minor girls? 5 A. I intend to respond to all relevant 6 questions regarding this lawsuit. However, at the 7 present time my attorneys have counseled me that I 8 cannot provide answers to any questions relevant to 9 this lawsuit, and I must accept their advice or risk 10 losing my Sixth Amendment right to effective 11 representation. 12 Accordingly, I assert my Federal 13 Constitutional right as guaranteed by the Fifth, 14 Sixth and Fourteenth Amendment to the constitution. 15 Q. Between 2001 and 2005 did you masturbate 16 in front of more than 50 minor girls? 17 A. I intend to respond to all relevant 18 questions regarding this lawsuit. However, at the 19 present time my attorneys have counseled me that I 20 cannot provide answers to any questions relevant to 21 this lawsuit, and I must accept this advice or risk 22 losing my Sixth Amendment right to effective 23 representation. 24 Accordingly, I assert my Federal 2 5 Constitutional riAtits as guaranteed by the Fifth. 23 (Pages 89 to 92) PALM BEACH REPORTING SERVICE, INC. EFTA01103348 Page 93 1 Sixth and Fourteenth Amendment to the constitution. 2 Q. Between 2001 and 2005 did you ejaculate in 3 front of more than 50 minor girls? 4 A. I intend to respond to all relevant 5 questions regarding this lawsuit. However, at the 6 present time my attorneys have counseled me that I 7 cannot provide answers to any questions relevant to 8 this lawsuit, and I must accept this advice or risk 9 losing my Sixth Amendment right to effective 10 representation. 11 Accordingly, I assert my Federal 12 Constitutional rights as guaranteed by the Fifth, 13 Sixth, and Fourteenth Amendment to the United States 14 Constitution. 15 Q. Does the body form of a 12 to 16 year old 16 girl sexually appeal to you? 17 MR. BURMAN: Object to the form. 18 THE WITNESS: I intend to respond to all 19 relevant questions regarding this lawsuit. 20 However, at the present time my attorneys have 21 counseled me that I cannot provide answers to 22 any questions relevant to this lawsuit, andl 23 must accept this advice or risk losing my Sixth 24 Amendment right to effective representation. 25 Accordingly, I assert my Federal Page 95 1 present time my attorneys have counseled ire that I 2 cannot provide answers to any questions relevant to 3 this lawsuit, and must accept this advice or risk 4 losing my Sixth Amendment right to effective 5 representation. 6 Accordingly, I assert my Federal 7 Constitutional rights as guaranteed by the Fifth, 8 Sixth, and Fourteenth Amendment to the United States 9 Constitution. 10 Q. During the criminal investigation there 11 were statements to the media that you believed the 12 girls to be 18. Which girls were you referring to? 13 A. I intend to 14 THE WITNESS: Excuse me one second. 15 (Thereupon, a discussion was had off 16 the record.) 17 MR. GOLDBERGER: Urrnt let me object to the 18 form as to vague. I don't know what statements 19 you're talking about. Are you talking about 20 statements that Mr. Epstein made? 21 MR. EDWARDS: Through attorneys. 22 MR. GOLDBE1tGER: Well, is that the 23 question? Why don't you rephrase the question, 24 why don't you rephrase the question so we 25 understand what it is. Page 94 1 Constitutional right as guaranteed by the 2 Fifth, Sixth, and Fourteenth Amendment to the 3 constitution. 4 Q. (By Mr. Edwards) Did you use your wealth, 5 power, and connections to impress or influence minor 6 girls into having sex with you? 7 A. I intend to respond to all relevant 8 questions regarding this lawsuit. However, at the 9 present time my attorneys have counseled me that I 10 cannot provide answers to any questions relevant to 11 this lawsuit, and I must accept their advice or risk 12 losing my Sixth Amendment right to effective 13 representation. 14 Accordingly, I assert my Federal 15 Constitutional rights as guaranteed by the Fifth, 16 Sixth, and Fourteenth Amendment to the United States 17 Constitution. 18 Q. Did you intentionally target economically 19 deprived children for the purposes of having sex or 20 engaging in sex acts with? 21 A. Do you want to rephrase the question? 22 Q. Did you intentionally target economically 23 deprived children for the purposes of sex? 24 A. I intend to respond to all relevant 25 questions regarding this lawsuit. However, at the Page 96 1 Q. (By Mr. Edwards) Various attorneys of 2 yours made representations to the media that you 3 were of, under the belief that the girls that you 4 were engaging in sex acts with were 18 years of age. 5 Which girls were you, was that referring to? 6 MR. GOLDBERGER: Can you identify a 7 specific statement made by a specific attorney? 8 MR.. EDWARDS: We'll get there later on in 9 the deposition. 10 Q. (By Mr. Edwards) Have you ever, at any 11 time, made that statement, that you believed the 12 girls that you were engaging in sex acts with were 13 18 years of age or older? 14 MR. GOLDBERGER: To the media, are you 15 talking about? 16 Q. (By Mr. Edwards) Yourself or through 17 anyone else to anyone else. 18 MR. GOLDBERGER: Object to the — 19 that's — 20 MR. BURMAN: Object to the form. 21 MR. GOLDBERGER: I have no idea what the 22 question is. Just ask the question, 23 happy to try and have the client answer it for 24 you. 25 9. SBA Mr. Edwards) Okay. rin not talking 24 (Pages 93 to 96) PALM BEACH REPORTING SERVICE, INC. EFTA01103349 Page 97 1 about statements to your attorneys, that's 2 privileged. 3 Have you ever made the statement to anyone 4 else, other than your attorneys, that you believed 5 the girls that were giving you massages at your 6 house were ova the age of 18? 7 A. I intend to respond to all relevant 8 questions regarding this lawsuit. However, at the 9 present time my attorneys have counseled me that I 10 cannot provide answers to any questions relevant to 11 this lawsuit, and I must accept this advice or risk 12 losing my Sixth Amendment right to effective 13 representation. 14 Accordingly, I assert my Federal 15 Constitutional rights as guaranteed by the Fifth, 16 Sixth, and Fourteenth Amendment to the United States 17 Constitution. 18 Q Between 2001 and 2005 did you pay any 19 females for sex? 20 A. I intend to respond to all relevant 21 questions regarding this lawsuit. However, at the 22 present time my attorneys have counseled me that I 23 cannot provide answers to any questions relevant to 24 this lawsuit, and I must accept this advice or risk 25 losing my Sixth Amendment ri t to effective Page 99 1 that the alleged minor girls' last names 2 weren't provided. 3 THE WITNESS: I intend to respond to all 4 relevant questions regarding this lawsuit. 5 However, to the present time, at the present 6 time my attorneys have counseled me thatl 7 cannot provide answers to any questions B relevant to this lawsuit, and I must accept 9 this advice or risk losing my Sixth Amendment 10 right to effective representation. 11 Accordingly, i assert my Federal 12 Constitutional rights as guaranteed by the 13 Fifth, Sixth, and Fourteenth Amendment to the 14 United States Constitution. 15 Q. (By Mr. Edwards) How did the minor girls 16 previously named in this deposition arrive to your 17 mansion between 2001 and 2005? 18 MR. BURMAN: Objection, vague and 19 indefinite. 20 MR. GOLDBERGER: And it's, it's vague and 21 indefinite, but to assist in answering the 22 question, can you tell us what mansion you're 23 talking about? 24 MR. EDWARDS: Palm Beach mansion. 25 THE WITNESS: Can the estion? Page 98 1 representation. 2 Accordingly, I assert Federal 3 Constitutional rights under the Fifth, Sixth, and 4 Fourteenth Amendment to the United States 5 Constitution. 6 Q. Between 2001 and 2005 did you tell minor 7 female girls at your house that you prefer to engage 8 in sexual activities with minors? 9 A. I intend to respond to all relevant 10 questions regarding this lawsuit. However, at the 11 present time my attorneys have counseled me that I 12 cannot provide answers to any questions relevant to 13 this lawsuit, and I must accept this advice or risk 14 losing my Sixth Amendment right to effective 15 representation. 16 Accordingly, 1 assert my Federal 17 Constitutional rights as guaranteed by the Fifth, 18 Sixth, and Fourteenth Amendment to the United States 19 Constitution. 20 Q. Is it true that many of the 49 minor girls 21 previously named told you that they were under the 22 age of 15 at the time you were engaging in sex acts 23 with than? 24 ha. BURMAN: Object to fonn of the 25 • estion va and indefinite to the extent Page 100 1 Q. (By Mr. Edwards) How did they arrive at 2 your house? 3 A. "They" arrive? 4 Q. How did any of the minor girls whose names 5 I named previously in this deposition arrive to your 6 house? 7 MR. BURMAN: Object to the form of the 8 question, vague and indefinite to the extent 9 that the alleged minor girls' last names 10 weren't provided. 11 THE WITNESS: I intend to respond to all 12 relevant questions regarding this lawsuit 13 However, at the present time my attorneys have 14 counseled me that I cannot provide answers to 15 any questions relevant to this lawsuit, that I 16 must accept this advice or risk losing my Sixth 17 Amendment tight to effective representation. 18 Accordingly, I assert my Federal 19 Constitutional rights as guaranteed by the 20 Fifth, Sixth, and Fourteenth Amendment to the 21 constitution. 22 Q. (By Mr. Edwards) Many of the minor girls 23 named previously in this deposition did not drive a 24 car to your house or have a driver's license, isn't 25 that true? 25 (Pages 97 to 100) PALM BEACH REPORTING SERVICE, INC. EFTA01103350 Page 101 1 MR. BURMAN: Object to form of the 2 question, vague and indefinite to the extent 3 that the alleged minor girls' last names 4 weren't provided. 5 THE WITNESS: You have to repeat the 6 question, again. Sony. 7 Q. (By Mr. Edwards) Isn't it true that many 8 of the minor girls previously named in this 9 deposition did not drive a car or have driver's 10 licenses? 11 MR. BURMAN: Same objection. 12 THE WITNESS: I intend to respond to all 13 relevant questions regarding this lawsuit. 14 However, at the present time my attorneys have 15 counseled me that I cannot provide answers to 16 any questions relevant to this lawsuit, and I 17 must accept this advice or risk losing my Sixth 18 Amendment right to effective representation. 19 Accordingly, I assert my Federal 20 Constitutional rights as guaranteed by the 21 Fifth, Sixth, and Fourteenth Amendment to the 22 United States Constitution. 23 Q. (By Mr. Edwards) Is it true that you 24 discussed with many of these girls the fact that 25 they were in middle school or high school at the Page 102 1 time they were engaging in sex acts with you at your 2 house? 3 MR BURMAN: Are you referring to the 4 previous 49? 5 MR. EDWARDS: Yes. 6 MR. BURMAN: Okay. Object to form of the 7 question, vague and indefinite to the extent 8 that the names, the last names of many of the 9 alleged minor girls weren't provided. 10 THE WITNESS: I intend to respond to all 11 relevant questions regarding this lawsuit. 12 However, at the present time my attorneys have 13 counseled me that 1 cannot provide answers to 14 any questions relevant to this lawsuit, and I 15 must accept this advice or risk losing my Sixth 16 Amendment right to effective rt.piesuitation. 17 Accordingly, I assert my Federal 18 Constitutional rights as guaranteed by the 19 Fifth, Sixth, and Fourteenth Amendment to the 20 United States Constitution. 21 Q. (By Mr. Edwards) Did any of the girls 22 that engaged in sex acts with you at your house 23 between 2001 and 2005 tell you that they were in 24 middle school or high school? 25 A. Soma repeat the question. Page 103 1 MR. BURMAN: Are you talking about the 497 2 MR. EDWARDS: No. 3 MR. BURMAN: No. 4 Q. (By Mr. Edwards) Did any minor girls that 5 engaged in sex or sex acts with you between the 6 years of 2001 and 2005 at your house tell you that 7 they vim in middle school or high school at the 8 time? 9 MR. BURMAN: Object to the form. 10 THE WITNESS: I intend to respond to all 11 relevant questions regarding this lawsuit. 12 However, at the present time my attomeys have 13 counseled me that I cannot provide answers to 14 any questions relevant to this lawsuit, and I 15 must accept this advice or risk losing my Sixth 16 Amendment right to effective representation. 17 Accordingly, lessen my Federal 18 Constitutional rights as guaranteed by the 19 Fifth, Sixth, and Fourteenth Anmaloient to the 20 constitution. 21 MR. EDWARDS: Okay. What time do you want 22 to break for lunch? 23 MR. GOLDBERGER 1:00. 24 THE WITNESS: 1:15? 25 MR GOLDBERGER: Yeah, 1:15. Is that 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 104 okay? MR. EDWARDS: Yeah, that's fine with me. What time do we have now? THE WITNESS: It will be another hour. (Thereupon, a discussion was had off the record.) Q. (By Mr. Edwards) Did you ever discuss with any minor girls at your house that you would pay them to bring you other minor girls for the purposes of sex? MR BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you tell any of the minor girls that were at your house for sex that you ftrefen'?!:lp,a. Is for sex? 26 (Pages 101 to 104) PALM BEACH REPORTING SERVICE, INC. EFTA01103351 Page 105 1 MR. BURMAN: Object to the form. 2 THE WITNESS: I intend to respond to all 3 relevant questions regarding this lawsuit. 4 However, at the present time my attorneys have 5 counseled me that I cannot provide answers to 6 any questions relevant to this lawsuit, and I 7 must accept this advice or risk losing my Sixth 8 Amendment right to effective representation. 9 Accordingly, I assert my Federal 10 Constitutional rights as guaranteed by the 11 Fifth, Sixth, and Fourteenth Amendment to the 12 constitution. 13 Q. (By Mr. Edwards) Did you tell any of the 14 minor girls at your house between 2001 and 2005 that 15 you do not like girls that have tattoos? 16 MR. BURMAN: Object to the form. 17 THE WITNESS: I intend to respond to all 18 relevant questions regarding this lawsuit. 19 However, at the present time my attorneys have 2o counseled me that I cannot provide answers to 21 any questions relevant to this lawsuit, and 22 must accept this advice or risk losing my Sixth 23 Amendment right to effective representation. 24 Accordingly, I assert my Federal 25 Constitutional right as guaranteed by the Page 106 1 Fifth, Sixth, and Fourteenth nc.nt of the 2 constitution. 3 Q. (By Mr. Edwards) Did you tell any of the 4 minor girls that were at your house not to bring you 5 any girls that were pregnant or had babies? 6 MR. BURMAN: Object to the form. 7 THE WITNESS: I intend to respond to all 8 relevant questions regarding this lawsuit 9 However, at the present time my attorneys have 10 counseled me that I cannot provide answers to 11 any questions relevant to this lawsuit, and I 12 must accept this advice or risk losing my Sixth 13 Amendment right to effective representation. 14 Accordingly, I assert my Federal 15 Constitutional right as guaranteed by the 16 Fifth, Sixth, and Fourteenth Amendment to the 17 constitution? 18 Q. (By Mr. Edwards) Did you specifically 19 instruct any of the minor girls not to bring you any 20 black girls? 21 MR. BURMAN: Object to the form. 22 THE WITNESS: I intend to respond to all 23 relevant questions regarding this lawsuit. 24 However, at the present time my attorneys have 25 counseled me that I cannot Erovide answers to Page 107 1 any questions relevant to this lawsuit, and I 2 must accept this advice or risk losing my Sixth 3 Amendment right to effective representation. 4 Accordingly, I assert my Federal 5 Constitutional rights as guaranteed by the 6 Fifth, Sixth and Fourteenth Amendment of the 7 constitution. 8 Q. (By Mr. Edwards) Isn't it true that you 9 did not like to have sex or engage in sex acts with 10 black girls? 11 MR. BURMAN: Object to the form. 12 THE WITNESS: I intend to respond to all 13 relevant questions regarding this lawsuit. 14 However, at the present time my attorneys have 15 counseled me that I cannot provide answers to 16 any questions relevant to this lawsuit, and I 17 must accept this advice or risk losing my Sixth 18 Amendment right to effective representation. 19 Accordingly, I assert my Federal 20 Constitutional rights as guaranteed by the 21 Fifth, Sixth, and Fourteenth Amendment 22 Q. (By Mr. Edwards) Isn't it true that black 23 girls were brought to your house and you turned them 24 away at the door because you do not like black 25 girls? 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 108 MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment tight to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Isn't it true that you also turned away girls because they were 18 years or older and too old for you? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that i cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert Federal Constitutional ridits as guaranteedb the 5 27 (Pages 105 to 108) PALM BEACH REPORTING SERVICE, INC. EFTA01103352 Page 109 1 Fifth, Sixth and Fourteenth Amendment to the 2 United States Constitution. 3 Q. (By Mr. Edwards) Isn't it true that you 4 also turned away minor girls with tattoos because 5 you did not feel that they were pure? 6 MR. BURMAN: Object to the form. 7 THE WITNESS: I intend to respond to all 8 relevant questions regarding this lawsuit. 9 However, at the present time my attorneys have 10 counseled me that I cannot provide answers to 11 any questions relevant to this lawsuit, and I 12 must accept this advice or risk losing my Sixth 13 Amendment right to effective representation. 14 Accordingly, I assert my Federal 15 Constitutional right as guaranteed by the 16 Fifth, Sixth, and Fourteenth Amendment to the 17 United States Constitution. 18 Q. (By Mr. Edwards) Is it true that your 19 specific instructions were, to these minor girls, to 20 bring you white girls between the ages of 12 and 17 21 that were not pregnant, did not have babies, and did 22 not have tattoos? 23 MR. BURMAN: Object to the form. 24 THE WITNESS: I intend to respond to all 25 relevant questions regarding this lawsuit. Page 111 1 any questions relevant to this lawsuit, and I 2 must accept this advice or risk losing my Sixth 3 Amendment right to effective representation. 4 Accordingly, I assert my Federal 5 Constitutional rights as guaranteed by the 6 Fifth, Sixth, and Fourteenth Amendment to the 7 United States Constitution. 8 Q. (By Mr. Edwards) Why did you laugh about 9 that last question? 10 MR. BURMAN: Object to the form. 11 THE WITNESS: I have a stomachache at the 12 moment. I wasn't laughing. 13 Q. (By Mr. Edwards) Isn't it true that you 14 targeted young, economically deprived kids with 15 little or no parental guidance? 16 MR. BURMAN: Object to the form. 17 THE WITNESS: You have to repeat the 18 question. 19 Q. (By Mr. Edwards) Isn't it true that you 20 were targeting young, economically deprived minor 21 girls with little or no parental guidance? 22 MR. BURMAN: Object to the form. 23 Q. (By Mr. Edwards) For sex. 24 A. I intend to respond to all relevant 25 questions regarding this lawsuit. However, at the Page 110 However, at the present time my attorneys have 2 counseled me that I cannot provide answers to 3 any questions relevant to this lawsuit, and I 4 must accept this advice or risk losing my Sixth 5 Amendment right to effective representation. 6 Accordingly, I assert my Federal 7 Constitutional right as guaranteed by the 8 Fifth, Sixth, and Fourteenth Amendment to the 9 constitution. 10 Q. (By Mr. Edwards) Is it true that you 11 offered each minor girl approximately $200 in cash 12 for sex? 13 MR. BURMAN: Object to the form. Are you 14 back on the 49, or is this generic? 15 MR. EDWARDS: No, generic. 16 THE WITNESS: Would you repeat the 17 question? 18 Q. (By Mr. Edwards) Between 2001 and 2005 19 isn't it true that you offered each minor girl that 20 came to your house for sex $200 for that sex? 23. MR. BURMAN: Object to the form. 22 THE WITNESS: I intend to respond to all 23 relevant questions regarding this lawsuit. 24 However, at the present time my attorneys have 25 counseled me that I cannot urovide answers to Page 112 1 present time my attorneys have counseled me that I 2 cannot provide answers to any questions relevant to 3 this lawsuit, and I must accept their advice or risk 4 losing my Sixth Amendment right to effective 5 representation. 6 Accordingly, I assert my Federal 7 Constitutional rights as guaranteed by the Fifth, 8 Sixth, and Fourteenth Amendment to the United States 9 Constitution. 10 Q. Have you ever told anybody that the girls 11 were over at your house because you just like 12 massages? 13 MR. BURMAN: Object to the form. 14 THE WITNESS: I intend to respond to all 15 relevant questions regarding this lawsuit. 16 However, at the present time my attorneys have 17 counseled me that I cannot provide answers to 18 any questions relevant to this lawsuit, and I 19 must accept this advice or risk losing my Sixth 20 Amendment right to effective representation. 21 Accordingly, I assert my Federal 22 Constitutional right as guaranteed by the 23 Fifth, Sixth, and Fourteenth Amendment to the 24 United States Constitution. 25 . it Edwards true that none 28 (Pages 109 to 112) PALM BEACH REPORTING SERVICE, INC. EFTA01103353 Page 113 1 of these minor girls that you engaged in sex acts 2 with at your house had any massage experience? 3 MR. BURMAN: Object to the form. 4 THE WITNESS: I intend to respond to all 5 relevant questions regarding this lawsuit. 6 However, at the present time my attorneys have 7 counseled me that I cannot provide answers to 8 any questions relevant to this lawsuit, and 9 must accept this advice or risk losing my Sixth 10 Amendment right to effective representation. 11 Accordingly, I assert my Federal 12 Constitutional rights as guaranteed by the 13 Fifth, Sixth, and Fourteenth Amendment to the 14 United States Constitution. 15 Q. (By Mr. Edwards) Between 2001 and 2005 16 did you ever have a professional masseuse give you a 17 massage at your house in Palm Beach? 18 A. I intend to respond to all relevant 19 questions regarding this lawsuit. However, at the 20 present time my attorneys have counseled me that 1 21 cannot provide answers to any questions relevant to 22 this lawsuit, and I must accept this advice or risk 23 losing my Sixth Amendment right to effective 24 representation. 25 Accordingly, I assert my Federal Page 114 1 Constitutional rights as guaranteed by the Fifth, 2 Sixth, and Fourteenth Amendment of the United States 3 Constitution. 4 Q. In fact, when these minor girls would tell 5 you they had no massage experience, didn't you 6 respond by telling them that that is actually better 7 for you? 8 MR. BURMAN: Object to the form. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit. 11 However, at the present time my attorneys have 12 counseled me that I cannot provide answers to 13 any questions relevant to this lawsuit, and I 14 must accept the advice or risk losing my Sixth 15 Amendment right to effective representation. 16 Accordingly, I assert my Federal 17 Constitutional right as guaranteed by the 18 Fifth, Sixth and Fourteenth Amendment to the 19 constitution. 20 Q. (By Mr. Edwards) Did you tell these minor 21 girls to get naked and touch you so that you could 22 get off? 23 MR. BURMAN: Object to the form. 24 THE WITNESS: What? What's — repeat the 25 . Lestion. Page 115 1 Q. (By Mr. Edwards) Did you tell these minor 2 girls between 2001 and 2005 at your Palm Beach 3 mansion to get naked and touch you so that you could 4 get off? 5 A. Get off? 6 MR. GOLDBERGER: Are you asking him if 7 that's a statement that was made? 8 MR. EDWARDS: Yes, to these girls. 9 MR. BURMAN: Object to the font 10 THE WITNESS: I intend to respond to all 11 relevant questions regarding this lawsuit. 12 However, at the present time my attorneys have 13 counseled me that I cannot provide answers to 14 any questions relevant to this lawsuit, and I 15 must accept this advice or risk losing my Sixth 16 Amendment right to effective representation. 17 Accordingly, I assert my Federal 18 Constitutional right as guaranteed by the 19 Fifth, Sixth, and Fourteenth Amendment to the 20 United States Constitution. 21 Q. (By Mr. Edwards) Will you agree that you 22 exchanged money for sexual gratification with at 23 least 50 girls at your Palm Beach mansion between 24 2001 and 2005? 25 MR. BURMAN: Object to the form. Page 116 1 THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit. 3 However, at the present time my attorneys have 4 counseled me not to provide answers to any 5 questions relevant to this lawsuit, and I must 6 accept this advice or risk losing my Sixth 7 Amendment right to effective representation. 8 Accordingly, I assert my Federal 9 Constitutional rights as guaranteed by the 10 Fifth, Sixth, and Fourteenth Amendment to the 11 United States Constitution. 12 Q. (By Mr. Edwards) Between 2001 and 2005 13 you never ordered a professional escort to come to 14 your house for sex, did you? 15 A. Rephrase the question, please. 16 Q. Between 2001 and 2005 you never ordered 17 from an escort service in Palm Beach County for a 18 professional escort to come to your house for sex, 19 did you? 20 A. You never ordered? 21 THE WITNESS: Do I answer the question? 22 MR. GOLDBERGER: You don't understand. 23 Rephrase it. 24 Q. (By Mr. Edwards) Did you ever call an 2 5 escort service to have an escort sent to your house 29 (Pages 113 to 116) PALM BEACH REPORTING SERVICE, INC. EFTA01103354 Page 117 Page 119 1 in Palm Beach for sex? 2 A. I intend to respond to all relevant 3 questions regarding this lawsuit However, at the 4 present time my attorneys have counseled me that I 5 cannot provide answers to any questions relevant to 6 this lawsuit, and I must accept this advice or risk 7 losing my Sixth Amendment right to effective 8 representation. 9 Accordingly, I assert my Federal 10 Constitutional right as guaranteed by the Fifth, 11 Sixth and Fourteenth Amendment to the United States 12 Constitution. 13 Q. You did not call a professional escort 14 because that would likely result in a girl over the 15 age of 18 coming to your house for sex, right? 16 MR. BURMAN: Object to the form. 17 THE WITNESS: I intend to respond to all 18 relevant questions regarding this lawsuit. 19 However, at the present time my attorneys have 20 counseled me that I cannot provide answers to 21 any questions relevant to this lawsuit, and I 22 must accept this advice or risk losing my Sixth 23 Amendment right to effective representation. 24 Accordingly, I assert my Federal 25 Constitutional rights as guaranteed by the Page 118 1. Fifth, Sixth, and Fourteenth Amendment of the 2 constitution. 3 Q. (By Mr. Edwards) Do you enjoy coercing 4 minors into sex acts with you? MR BURMAN: Object to the form. 6 THE WITNESS: I intend to respond to all 7 relevant questions regarding this lawsuit 8 However, at the present time my attorneys have 9 counseled me that I cannot provide answers to 10 any questions relevant to this lawsuit, and I 13. must accept this advice or risk losing my Sixth 12 Amendment right to effective repri..x.ntation. 13 Accordingly, I assert my Federal 14 Constitutional right as guaranteed by the 15 Fifth, Sixth, and Fourteenth Amendment to the 16 United States Constitution. II1By Mr. Edwards) Do you know- 19 7 intend to respond to all relevant 2 0 questions regarding this lawsuit However, at the 21 present time my attorneys have counseled me that I 22 cannot provide answers to any questions relevant to 23 this lawsuit, and I must accept this advice or risk 24 losing my Sixth Amendment right to effective 25 reuresentation. 1 Accordingly, I assert my Federal 2 Constitutional rights as guaranteed by the Fifth, 3 Sixth, and Fourteenth Amendment to the constitution. 4 Q. Did you instruct her to assist you in 5 gaining access to minor girls for sex? 6 A. I intend to respond to all relevant 7 questions regarding this lawsuit However, at the 8 present time my attorneys have counseled me that I 9 cannot provide answers to any questions relevant to 10 this lawsuit, and I must accept this advice or risk 11 losing my Sixth Amendment right to effective 12 representation. 13 Accordingly, ! assert my constitutional 14 rights as guaranteed by the Fifth, Sixth, and 15 Fourteenth Amendment to the United States 16 Constitution. 17 Q. Did you instruct any other employees of 18 yours to assist you in pining access to minors for 19 sex? 20 A. I intend to respond to all relevant 23. questions regarding this lawsuit. However, at the 22 present time my attorneys have counseled me that 23 cannot provide answers to any questions relevant to 24 this lawsuit, and I must accept this advice or risk 25 losing my Sixth Amendment right to effective Page 120 1 representation. 2 Accordingly, I assert my Federal 3 Constitutional rights as guaranteed by the Fifth, 4 Sixth, and Fourteenth Amendment to the United States 5 Constitution. 6 Q What people were living with you in your 7 Palm Beach mansion between 2001 and 2005? MR. GOLD13ERGER: Object to the form. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit. 13. However, at the present time my attorneys have 12 counseled me that I cannot provide answers to 13 any questions relevant to this lawsuit, and I 14 must accept this advice or risk losing my Sixth 15 Amendment right to effective representation. 16 Accordingly, I assert my Federal 17 Constitutional rights as guaranteed by the 18 Fifth, Sixth, and Fourteenth Amendment to the 19 United States Constitution. 20 Q. (By Mr. Edwards) Did you meet with people 23. employed by you to discuss a plan to gain access to 22 minor girls for the purposes of sex? 23 A. I intend to respond to all relevant 24 questions regarding this lawsuit. However, at the 25 ,resent time my attomevs have counseled me that I 30 (Pages 117 to 120) PALM BEACH REPORTING SERVICE, INC. EFTA01103355 Page 121 1 cannot provide answers to any questions relevant to 2 this lawsuit, and I must accept this advice or risk 3 losing my Sixth Amendment right to effective 4 representation. 5 Accordingly, I assert my Federal 6 Constitutional rights as guaranteed by the Fifth, 7 Sixth, and Fourteenth Amendment to the United States 8 Constitution. 9 Q. Which employees did you discuss your plan 10 to gain access to minor girls for the purposes of 11 sex? 12 A. I intend to respond to all relevant 13 questions regarding this lawsuit However, at the 14 present time my attorneys have counseled me that I 15 cannot provide answers to any questions relevant to 16 this lawsuit, and I must accept this advice or risk 17 losing my Sixth Amendment right to effective 18 representation. 19 Accordingly, I assert my Federal 20 Constitutional rights as guaranteed by the Fifth, 21 Sixth, and Fourteenth Amendment to the United States 22 Constitution. 23 Q. Is it true that you have many people 24 working in your house in Palm Beach County, or did, 25 between the years 2001 and 2005? Page 123 1. representation. 2 Accordingly, lessen my Federal 3 Constitutional rights as guaranteed by the Fifth, 4 Sixth, and Fourteenth Amendment of the United States 5 Constitution. 6 Q. Did you ever personally procure a, or 7 sorry, strike that. a Did you ever personally go out and recruit 9 a minor girl to bring back to your house for sex? to THE WITNESS: Object to form, no? 11 MR. BURMAN: Object to form. 12 THE WITNESS: I intend to respond to all 13 relevant questions regarding — 14 MR. EDWARDS: I'm sorry, is there 15 something you don't understand about the 16 question? If you don't, TII rephrase it. 17 MR. GOLDBERGER We objected to the form, 18 now you can answer. 19 MR. EDWARDS: I thought he objected to the 20 form, that's why I was -- 21 MR. GOLDBERGER: He asked -- I'm not — 22 Brad, he asked his lawyer a question, that's 23 all. We objected to the form, that's fine. 24 MR. EDWARDS: Okay. 25 MR. GOLDBERCIER: Go ahead and answer. Page 122 1 A. I intend to respond to all relevant 2 questions regarding this lawsuit However, at the 3 present time my attorneys have counseled me that 1 4 cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk 6 losing my Sixth Amendment right to effective 7 representation. a Accordingly, I assert my Federal 9 Constitutional right as guaranteed by the Fifth, 10 Sixth, and Fourteenth Amendment to the United States 11 Constitution. 12 Q. How many employees work in the various 13 houses that you own right now? 14 A. That's — that question is owned right 15 now? I don't understand the question. 16 Q. Well, it's my understanding that you own 17 numerous properties. I just want to know how many 1 a people are actually paid by you or employed by you 19 that work and/or live in those homes? 20 A. I intend to respond to all relevant 21 questions regarding this lawsuit. However, at the 22 present time my attorneys have counseled me that I 23 cannot provide answers to any questions relevant to 24 this lawsuit, and I must accept this advice or risk 25 losin m Sixth Amendment Vitt° effective Page 124 1 THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit 3 However, at the present time my attorneys have 4 counseled mo that I cannot provide answers to any questions relevant to this lawsuit, and I 6 must accept the advice or risk losing my Sixth 7 Amendment right to effective representation. 8 Accordingly, lessen my Federal 9 Constitutional right as guaranteed by the 10 Fifth, Sixth, and Fourteenth Amendments to the 11 United States Constitution. 12 Q. (By Mr. Edwards) Who is the first minor 13 girl that you brought to your house for sex? 14 MR. BURMAN: Object to the form. 15 THE WITNESS: I intend to respond to all 16 relevant questions regarding this lawsuit. 17 However, at the present time my attorneys have 18 counseled me that I cannot provide answers to 19 any questions relevant to this lawsuit, and I 20 must accept the advice or risk losing my Sixth 21 Amendment to effective representation. 22 Accordingly, I assert my Federal 23 Constitutional rights as guaranteed by the 24 Fifth, Sixth, and Fourteenth Amendment to the 25 United States Constitution. 121 to 124 PALM BEACH REPORTING SERVICE, INC. EFTA01103356 Page 125 Page 127 1 Q. (By Mr. Edwards) Have you had sex with 1 relevant questions regarding this lawsuit. 2 over 100 minor girls in the last ten years? 2 However, at the present time my attorneys have 3 MR. BURMAN: Object to the In 3 counseled me that I cannot provide answers to 4 THE WITNESS: I intend to respond to all 4 any questions relevant to this lawsuit, and I 5 relevant questions regarding this lawsuit. 5 must accept this advice or risk losing my Sixth 6 However, at the present time my attorneys have 6 Amendment right to effective representation. 7 counseled me that I cannot provide answers to 7 Accordingly, I assert my Federal 8 any questions relevant to this lawsuit, and I 8 Constitutional rights as guaranteed by the 9 must accept this advice or risk losing my Sixth 9 Fifth, Sixth, and Fourteenth Amendment to the 10 Amendment right to effective representation. 10 United States Constitution. 13. Accordingly, I assert my Federal 11 Q. (By Mr. Edwards) Was the target age range 12 Constitutional rights as guaranteed by the 12 for your criminal enterprise always minors between 13 Fifth, Sixth, and Fourteenth Amendment to the 13 the ages of 12 and 16? 14 United States Constitution. 14 MR. BURMAN: Object to the form. 15 Q. (By Mr. Edwards) When did you devise your 15 THE WITNESS: I intend to respond to all 16 plan to gain access to minor girls for sex? 16 relevant questions regarding this lawsuit. 17 MR. BURMAN: Object to the form. 17 However, at the present time my attorneys have 18 THE WITNESS: I intend to respond to all 18 counseled me that I cannot provide answers to 19 relevant questions regarding this lawsuit. 19 any questions relevant to this lawsuit, and I 20 However, at the present time my attorneys have 20 must accept this advice or risk losing my Sixth 23. counseled me that I cannot provide answers to 21 Amendment right to effective representation. 22 any questions relevant to this lawsuit, and I 22 Accordingly, I assert my Federal 23 must accept this advice or risk losing my Sixth 23 Constitutional rights as guaranteed by the 24 Amendment right to effective representation. 24 Fifth, Sixth, and Fourteenth Amendments to the 25 Accordingly, I assert my Federal 25 United States Constitution. Page 126 Page 128 1 Constitutional rights as guaranteed by the 1 Q. (By Mr. Edwards) What are the names of 2 Fifth, Sixth, and Fourteenth Amendment to the 2 all of the members of your criminal enterprise that 3 United States Constitution. 3 has the common goal of procuring minors for the 4 Q. (By Mr. Edwards) With whom did you meet 4 purposes of sex? 5 to discuss your plan to gain access to minor girls 5 MR BURMAN: Object to the form. 6 for sex? 6 THE WITNESS: I intend to respond to all 7 MR. BURMAN: Object to the form. 7 relevant questions regarding this lawsuit 8 THE WITNESS: I intend to respond to all 8 However, at the present time my attorneys have 9 relevant questions regarding this lawsuit 9 counseled me that I cannot provide answers to 10 However, at the present time my attorneys have 3.0 any questions relevant to this lawsuit, and I 11 counseled me that I cannot provide answers to 11 must accept this advice or risk losing my Sixth 12 any questions relevant to this lawsuit, and I 12 Amendment to effective representation. 13 must accept this advice or risk losing my Sixth 13 Accordingly, I assert my Federal 14 Amendment right to effective representation. 14 Constitutional tights as guaranteed by the 15 Accordingly, I assert my Federal 15 Fifth, Sixth, and Fourteenth Amendment to the 16 Constitutional right as guaranteed by the 16 United States Constitution. 17 Fifth, Sixth, and Fourteenth Amendment to the 17 Q. (By Mr. Edwards) In addition to paying 18 United States Constitution. 18 each of these minor girls approximately $200 for 19 Q. (By Mr. Edwards) Do you agree that you 19 sex, did you also provide transportation for them to 20 have a criminal enterprise that is comprised of at 20 and from your house? 21 the least, yourself, and 21 MR. BURMAN: Are we generic, or are we 22 who have the common goal o nil 22 going with the 49? 23 minors to you for the purposes of sex? 23 MR. EDWARDS: Generic. 24 MR. BURMAN: Object to the form. 24 MR. BURMAN: Generic? Okay. Object to 25 THE WITNESS: I intend to respond to all 25 the form. 32 (Pages 125 to 128) PALM BEACH REPORTING SERVICE, INC. EFTA01103357 Page 129 1 THE WITNESS: You have to repeat the 2 question, Fin sorry. 3 Q. (By Mr. Edwards) In addition to paying 4 minor girls approximately $200 to engage in sex or 5 sex acts with them, did you also provide 6 transportation for these minor girls to and from 7 your house? 8 MIL BURMAN: Same objection. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit. 13. However, at the present time my attorneys have 12 counseled me that I cannot provide any answers 13 relevant to this lawsuit, and I must accept the 14 advice or risk losing my Sixth Amendment right 15 to effective representation. 16 Accordingly, I assert my Federal 17 Constitutional rights as guaranteed by the 18 Fifth, Sixth, and Fourteenth Amendment to the 19 United States Constitution. 20 Q. (By Mr. Edwards) Did you, one of your 21 employees, or someone within your enterprise have an 22 account with Yellow Cab for the purposes of 23 transporting minors to and from your house? 24 MR. BURMAN: Object to form. 25 MR. GOLDBERGER: Do you understand the Page 131 1 Accordingly, I assert my Federal 2 Constitutional right as guaranteed by the 3 Fifth, Sixth and Fourteenth Amendment to the 4 United States Constitution. 5 Sorry, can we take a break again? 6 Bathroom break. 7 MR. EDWARDS: Let's just break for lunch 8 then. 9 MR. GOLDBERGER: I can't, because I've 10 got — there's a reason why, I've got a 11 commitment at 1:15, so — 12 THE VIDEOGRAPHER: Off the record at 13 12:40. 14 (Thereupon, a discussion was had off 15 the record.) 16 (Thereupon, a brief break was taken.) 17 THE VIDEOGRAPHER: Back on the record at 18 12:54. 19 Q. (By Mr. Edwards) Between 2001 and 2005 20 did you or any of your employees or assistants have 21 an account with Yellow Cab? 22 A. I intend to respond to all relevant 23 questions regarding this lawsuit. However, at the 24 present time my attorneys have counseled me that I 25 cannot provide answers to any questions relevant to Page 130 1 question when he says "enterprise"? Do you 2 have any idea what he means? 3 THE WITNESS: No. 4 MR. GOLDBERGER: Can you define 5 enterprise, so we can determine whether we need 6 to answer the question. 7 MR. EDWARDS: Pin talking about persons 8 involved with a common goal. We have defined 9 this earlier. 10 MR. GOLDBERGER: Pm sorry, I was out of 11 the room did you define it? 12 MR. EDWARDS: You were out of the room. 13 MR GOLDBERGER: Okay. 14 MR. EDWARDS: And persons we defined it 15 n, having the common 17 goo o ringing minors to an from the Palm 18 Beach house for the purposes of sex. 19 THE WITNESS: I intend to respond to all 20 relevant questions regarding this lawsuit. 21 However, at the present time my attorneys have 22 counseled me that I cannot provide answers to 23 any questions relevant to this lawsuit, and I 24 must accept this advice or risk losing my Sixth 25 Amendment right to effective reresentation. Page 132 1 this lawsuit, and I must accept their advice or risk 2 losing my Sixth Amendment right to effective 3 representation. 4 Accordingly, I assert my Federal 5 Constitutional right as guaranteed by the Fifth, 6 Sixth, and Fourteenth Amendment to the United States 7 Constitution. 8 Q. Are you currently actually a billionaire? 9 MR. BURMAN: Objection. That goes to 10 punitive damages, and I object. 11 THE WITNESS: I intend to respond to all 12 relevant questions regarding this lawsuit. 13 However, at the present time my attorneys have 14 counseled me that I cannot provide answers to 15 any questions relevant to this lawsuit, and I 16 must accept this advice or risk losing my Sixth 17 Amendment right to effective representation. 18 Accordingly, I assert my Federal 19 Constitutional right as guaranteed by the 20 Fifth, Sixth, and Fourteenth Amendment to the 21 United States Constitution. 22 MR. BURMAN: And I should add for the 23 record that I would instruct him not to answer 24 that question, even if he wasn't invoking the 25 Fifth. 33 (Pages 129 to 132) PALM BEACH REPORTING SERVICE, INC. EFTA01103358 Page 133 1 Q. (By Mr. Edwards) Between 2001 and 2005 2 were you a billionaire? 3 MR. BURMAN: Objection, instruct you not 4 to answer that question based on the fact that 5 that's directed toward punitive damages, and 6 that has not been allowed to file, be filed, or 7 proceeded with in the state court action. 8 You should read that, as well. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit. 11 However, at the present time my attorneys have 12 counseled me that I cannot provide answers to 13 any questions relevant to this lawsuit, and I 14 must accept their advice or risk losing my 15 Sixth Amendment right to effective 16 representation. 17 Accordingly, ! assert my Federal 18 Constitutional rights as guaranteed by the 19 Fifth, Sixth and Fourteenth Amendment to the 20 United States Constitution. 21 Q. (By Mr. Edwards) Between 2001 and 2005 22 what types of cars did you have that you owned, 23 parked in your driveway at your Palm Beach mansion? 24 MIt BURMAN: Object, once again on the 25 grounds that punitive damages have not been Page 135 1 Q. (By Mr. Edwards) What is the square 2 footage of your house in Palm Beach? 3 MR. BURMAN: Object, on the grounds that 4 that question, in part, delves into his 5 financial situation, which has not been 6 approved to be explored in this case yet, 7 because punitive damages have not been approved 8 or allowed to be proceeded with here, and I 9 instruct him not to answer the question. 10 THE WITNESS: I intend to respond to all 11 relevant questions regarding this lawsuit. 12 However, at the present time my attorneys have 13 counseled me that I cannot provide answers to 14 any questions relevant to this lawsuit, and 15 must accept his advice or risk losing my Sixth 16 Amendment right to effective representation. 17 Accordingly, I assert my Federal 18 Constitutional rights as guaranteed by the 19 Fifth, Sixth and Fourteenth Amendment to the 20 United States Constitution. 21 Q. (By Mr. Edwards) Did you tell the minor 22 girls that were at your house that you were 23 extremely wealthy between 2001 and 2005? 24 MR. GOLDBERGER: Object to the form. 25 THE WITNESS: I intend to respond to all Page 134 1 approved yet in this case I instruct him not 2 to answer that question. 3 THE WITNESS: I intend to respond to all 4 relevant questions regarding this lawsuit. 5 However, at the present time my attorneys have 6 counseled me that I cannot provide answers to 7 any questions relevant to this lawsuit, and I 8 must accept this advice or risk losing my Sixth 9 Amendment right to effective representation. 10 Accordingly, I assert my Federal 11 Constitutional rights as guaranteed by the 12 Fifth, Sixth, and Fourteenth Amendment to the 13 United States Constitution. 14 Q. (By Mr. Edwards) Is your house in Palm 15 Beach located on the water? 16 THE WITNESS: I intend to respond to all 17 relevant questions regarding this lawsuit. 18 However, at the present time my attorneys have 19 counseled me that I cannot provide answers to 20 any questions relevant to this lawsuit, and I 21 must accept this advice or risk losing my Sixth 22 Amendment right to effective representation. 23 Accordingly, I assert my Federal 24 Constitutional rights under the Fifth, Sixth, 25 and Fourteenth Amendment to the constitution. Page 136 1 relevant questions regarding this lawsuit. 2 However, at the present time my attorneys have 3 counseled me that I cannot provide answers to 4 any questions relevant to this lawsuit, and I 5 must accept this advice or risk losing my Sixth 6 Amendment right to effective representation. 7 Accordingly, I assert my Federal 8 Constitutional rights as guaranteed by the 9 Fifth, Sixth and Fourteenth Amendment to the 10 United States Constitution. 11 Q. (13y Mr. Edwards) Did you talk to the 12 minor girls that were at your house between 2001 and 13 2005 about all of the houses and cars that you 14 owned? 15 MR. BURMAN: Object to the form. 16 THE WITNESS: I intend to respond to all 17 relevant questions regarding this lawsuit. 18 However, at the present time my attorneys have 19 counseled me that I cannot provide answers to 20 any questions relevant to this lawsuit, and 1 21 must accept this advice or risk losing my Sixth 22 Amendment right to effective representation. 23 Accordingly, I assert my Federal 24 Constitutional rights as guaranteed by the 25 Fifth Sixth and Fourteenth Amendment to the 34 (Pages 133 to 1 3 6) PALM BEACH REPORTING SERVICE, INC. EFTA01103359 Page 137 Page 139 1 NIAWdStmesOmsituSom 1 THE WITNESS: I intend to respond to all 2 • Q. (By Mr. Edwards) Did you use your wealth 2 relevant questions regarding this lawsuit. 3 and the minors lack thereof to influence that minor 3 However, at the present time my attorneys have 4 to have sex with you? 4 counseled me that I cannot provide answers to 5 MR. BURMAN: Object to the form. 5 any questions relevant to this lawsuit, and I 6 THE WITNESS: I intend to respond to all 6 must accept the advice or risk losing my Sixth 7 relevant questions regarding this lawsuit 7 Amendment right to effective representation. 8 However, at the present time my attorneys have 8 Accordingly, I assert my Federal 9 counseled me that I cannot provide answers to 9 Constitutional rights as guaranteed by the 10 any questions relevant to this lawsuit, and 10 Fifth, Sixth, and Fourteenth Amendments to the 11 must accept advice or risk losing my Sixth 11 United States Constitution. 12 Amendment right to effective representation. 12 Q. (By Mr. Edwards) Was it part of your plan 13 Accordingly, I assert my Federal 13 to display your wealth and power in an effort to 14 Constitutional rights as guaranteed by the 14 gain sexual access to minor girls? 15 Fifth, Sixth, and Fourteenth Amendment to the 15 MR. BURMAN: Object to the form. 16 United States Constitution. 16 THE WITNESS: I intend to respond to all 17 Q. (By Mr. Edwards) After you ejaculated in 17 relevant questions regarding this lawsuit. 18 front of minor girls, did you tell each one of them 18 However, at the present time my attorneys have 19 that every time she came to your house for sex, you 19 counseled me that I cannot provide answers to 20 would pay her $200 cash? 20 any questions relevant to this lawsuit, and I 21 MR. BURMAN: Object to the form. 21 must accept the advice or risk losing my Sixth 22 THE WITNESS: I intend to respond to all 22 Amendment right to effective representation. 23 relevant questions regarding this lawsuit. 23 Accordingly, I assert my Federal 24 However, at the present time my attorneys have 24 Constitutional rights as guaranteed by the 25 counseled me that I cannot provide answers to 25 Fifth, Sixth, and Fourteenth Amendment to the Page 138 Page 140 1 any questions relevant to this lawsuit, and I 1 United States Constitution. 2 must accept the advice or risk losing my Sixth 2 Q. (By Mr. Edwards) Did you intentionally 3 Amendment right to effective representation. 3 target very poor minor girls because you knew that 4 Accordingly, I assert my Federal 4 demographic would be the most impressed by your 5 Constitutional rights as guaranteed by the 5 wealth and likely listen to you? 6 Filth, Sixth, and Fourteenth Amendment to the 6 MR. BURMAN: Object to the form. 7 United States Constitution. 7 THE WITNESS: I intend to respond to all 8 Q. (By Mr. Edwards) Was it your plan to 8 relevant questions regarding this lawsuit. 9 groom each minor girl to be your personal sex slave? 9 However, at the present time my attorneys have 10 MR. BURMAN: Object to the form. 10 counseled me that I cannot provide answers to 11 THE WITNESS: I intend to respond to all 13. any questions relevant to this lawsuit, and 12 relevant questions regarding this lawsuit. 12 must accept this advice or risk losing my Sixth 13 However, at the present time my attorneys have 13 Amendment right to effective representation. 14 counseled me that I cannot provide answers to 14 Accordingly, I assert my Federal 15 any questions relevant to this lawsuit, and I 15 Constitutional right as guaranteed by the 16 must accept this right or risk losing my Sixth 16 Fifth, Sixth, and Fourteenth Amendment to the 17 Amendment right to effective representation? 17 United States Constitution. 18 Accordingly, I assert my Federal 18 Q. (By Mr. Edwards) None of the minor girls 19 Constitutional rights as guaranteed by the 19 that you engaged in sex or sex acts with had ever 2 0 Fifth, Sixth, and Fourteenth Amendment to the 20 engaged in prostitution prior to meeting you, isn't 23. United States Constitution. 21 that comet? 22 Q. (By Mr. Edwards) Did you impress upon 22 MR. BURMAN: Object to the form. 23 each minor girl that what she was doing with you 23 THE WITNESS: I intend to respond to all 24 sexually was morally right? 24 relevant questions regarding this lawsuit. 25 MR. BURMAN: Object to the form. 25 However at the present time m attorn have 1 35 (Pa es 137 to 140) PALM BEACH REPORTING SERVICE, INC. EFTA01103360 Page 141 1 counseled me that I cannot provide answers to 2 any questions relevant to this lawsuit, and I 3 must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal 6 Constitutional rights as guaranteed by the 7 Fifth, Sixth and Fourteenth Amendment to the 8 United States Constitution. 9 Q. (By Mr. Edwards) Isn't it true that you 10 corrupted and injured minor girls for your own 11 sexual gratification? 12 MR. BURMAN: Object to the form. 13 THE WITNESS: I intend to respond to all 14 relevant questions regarding this lawsuit. 15 However, at the present time my attorneys have 16 counseled me that I cannot provide answers to 17 any questions relevant to this lawsuit, and I 18 must accept this advice or risk losing my Sixth 19 Amendment right to effective ivpiebentation. 20 Accordingly, I assert my Federal 21 Constitutional rights as guaranteed by the 22 Fifth, Sixth, and Fourteenth Amendment to the 23 United States Constitution. 24 Q. (By Mr. Edwards) Isn't it true that you 25 typically engaged in sex or sex acts with minor Page 142 1 girls three or four times each day at your Palm 2 Beach mansion? 3 MR. BURMAN: Object to the form. 4 THE WITNESS: I intend to respond to all 5 relevant questions regarding this lawsuit. 6 However, at the present time my attorneys have 7 counseled me that I cannot provide answers to 8 any questions relevant to this lawsuit, and I 9 must accept this advice or risk losing my Sixth 10 Amendment right to effective representation. 11 Accordingly, I assert my Federal 12 Constitutional rights as guaranteed by the 13 Fifth, Sixth, and Fourteenth Amendment to the 14 United States Constitution. 15 Q. (By Mr. Edwards) Isn't it true that you 16 in, that you coerced minor girls into prostitution? 17 MR. BURMAN: Object to the form. 18 THE WITNESS: I intend to respond to all 19 relevant questions regarding this lawsuit. 20 However, at the present time my attorneys have 21 counseled me that I cannot provide answers to 22 any questions relevant to this lawsuit, and I 23 must accept this advice or risk losing my Sixth 24 Amendment right to effective representation. 25 Accordin0v I assert m Federal Page 143 1 Constitutional rights as guaranteed by the 2 Fifth, Sixth, and Fourteenth Amendment in the 3 United States Constitution. 4 Q. (By Mr. Edwards) Isn't it true that 5 and your employees, including called 6 these minor girls to encourage them to bring more 7 minor girls to you for sex. By called I =an on the 8 telephone? 9 MR. BURMAN: Object to the form. 10 THE WITNESS: Can you repeat the question? 11 Q. (By Mr. Edwards) Isn't it true that you 12 lam a MI assistants or employees, including 13 called minor girls on the telephone to 14 encourage them or command that they bring you other 15 minor girls for sex? 16 MR. BURMAN: Object to the form. 17 THE WITNESS: I intend to respond to all 18 relevant questions regarding this lawsuit. 19 However, at the present time my attorneys have 20 counseled me that I cannot provide answers to 21 any questions relevant to this lawsuit, and I 22 must accept this advice or risk losing my Sixth 23 Amendment right to effective representation. 24 Accordingly, I assert my Federal 25 Constitutional rights as guaranteed by the Page 144 1 Fifth, Sixth, and Fourteenth Amendment to the 2 United States Constitution. 3 Q. (By Mr. Edwards) What are all the 4 telephone numbers assigned to you or your Palm Beach 5 mansion between 2001 and 2005? 6 A. Again? 7 Q. What were all of the telephone numbers 8 assigned to you or your Palm Beach mansion between 9 2001 and 2005? 10 A. I intend to respond to all relevant 11 questions regarding this lawsuit. However, at the 12 present time my attorneys have counseled me that I 13 cannot provide answers to any questions relevant to 14 this lawsuit, and I must accept this advice or risk 15 losing my Sixth Amendment right to effective 16 representation. 17 Accordingly, i assert Federal 18 Constitutional rights as guaranteed by the Fifth, 19 Sixth, and Fourteenth Amendment to the United States 20 Constitution. 21 Q. Who scheduled your massage appointments 22 between 2001 and 2005? 23 A. I intend to respond to all relevant 24 questions regarding this lawsuit. However, at the 2 5 rifeSent time mcaltylneis have counseled me that I 36 (Pages 141 to 144) PALM BEACH REPORTING SERVICE, INC. EFTA01103361 Page 145 Page 147 1 cannot provide answers to any questions relevant to 1 Accordingly,lassert my Federal 2 this lawsuit, and I must accept this advice or risk 2 Constitutional lights as guaranteed by the Fifth, 3 3 Sixth, and Fourteenth Amendment to the United States losing my Sixth AnietaInwat right to effective 4 representation. 4 Constitution. 5 THE WITNESS: Excuse me? 5 Q. Did you rely on and your 6 Accordingly I assert my Federal 6 other assistants to y sc u e these minor 7 Constitutional rights as guaranteed by the 7 girls in a way so that they would not come in 8 Fifth, Sixth, and Fourteenth Amendment to the 8 contact with one another? 9 United States Constitution. 9 MR. BURMAN: Object to form. 10 Q. (By Mr. Edwards) Is it true that you were 10 THE WITNESS: I intend to respond to all 11 ejaculating in front of three or four minor girls 11. relevant questions regarding this lawsuit. 12 per day between 2002 and 2005 at your Palm Beach 12 However, at the present time my alio' nays have 13 mansion? 13 counseled me that I cannot provide answers to 14 MR. BURMAN: Object to the form. 14 any questions relevant to this lawsuit, and I 15 THE WITNESS: I intend to respond to all 15 must accept their advice or risk losing my 16 relevant questions regarding this lawsuit 16 Sixth Amendment Right to effective 17 17 representation. However, at the piesent time my attorneys have 18 counseled me that I cannot provide answers to 18 So, accordingly, l assert my 19 any questions relevant to this lawsuit, and I 19 Constitutional rights as guaranteed by the 20 must accept the advice or risk losing my Sixth 20 Fifth, Sixth and Fourteenth Amendments to the 21 Amendment tight to effective representation. 21 United States Constitution. 22 Accordingly, I assert my Federal 22 MR. EDWARDS: Ready to break? 23 Constitutional rights as guaranteed by the 23 MR. GOLDBERGER: He wants to eat. 24 Fifth, Sixth, and Fourteenth Amendment to the 24 THE VIDEOORAPHER: We're off the record at 25 United States Constitution. 25 1:12. Page 146 Page 148 1 Q. (By Mr. Edwards) Have you ever treated 3. (Thereupon, a lunch break was taken 2 with any doctors or physicians and discussed sexual 2 from 1:12 to 2:32 p.m.) 3 issues with them? 3 THE VTDEOGRAPHER: Were back on record at 4 THE WITNESS: I intend to respond to all 4 2:32. 5 relevant questions regarding this lawsuit 5 MR. EDWARDS: Ready? 6 However, at the present time my attorneys have 6 MR. GOLDI3ERGER: Sure. 7 counseled me that 1cannot provide answers to 7 Q. (By Mr. Edwards) Mr. Epstein, did you 8 any questions relevant to this lawsuit, and I 8 ever care about any of the feelings of the minor 9 must accept this advice or risk losing my Sixth 9 girls that you were engaging in sex with? 10 Amendment right to effective representation. 10 MR. BURMAN: Object to the form. 11 Accordingly, I assert my Federal 11 THE WITNESS: I intend to respond to all 12 Constitutional rights as guaranteed by the 12 relevant questions regarding this lawsuit. 13 Fifth, Sixth, and Fourteenth Amendment to the 13 However, at the present time my attorneys have 14 United States Constitution. 14 counseled me that I cannot provide answers to 15 Q. (By Mr. Edwards) Did you and your 15 any questions relevant to this lawsuit at this 16 assistants or employees use the word work, W-O-R-K, 16 time, so I must accept their advice or I lose 17 to describe you engaging in sex acts with minors at 17 potential -- I risk losing my Sixth Amendment 18 your house? 18 right to effective lepon.entation. 19 A. I intend to respond to all relevant 19 And accordingly, I have to assert my 20 questions regarding this lawsuit. However, at the 20 Federal Constitutional rights as guaranteed by 21 present time my attorneys have counseled me that I 21 the Fifth, Sixth and Fourteenth Amendment to 22 cannot provide answers to any questions relevant to 22 the United States Constitution. 23 this lawsuit, and I must accept their advice or risk 23 Q. (By Mr. Edwards) Did it ever occur to you 24 losing my Sixth Amendment right to effective 24 that any of these girls were somebody's daughter -- 25 representation. 25 MR. BURMAN: Object to the form. 37 (Pages 145 to 148) PALM BEACH REPORTING SERVICE, INC. EFTA01103362 Page 149 1 Q. (By Mr. Edwards) — when you were 2 engaging in sex with them? 3 MR. BURMAN: Object to the form of the 4 question. 5 THE VIDEOGRAPHER: I intend to respond to 6 all relevant questions regarding this lawsuit. 7 However, at the present time my attorneys have 8 counseled me that I cannot provide answers to 9 these questions, as I have to accept their 10 advice or risk losing my Sixth Amendment right 11 to effective representation, Brad. 12 THE WITNESS: Is it okay if I call you 13 Brad? 14 MR EDWARDS: You can continue. 15 THE WITNESS: And, accordingly, I assert 16 my Federal Constitutional rights as guaranteed 17 by the Fifth, Sixth and Fourteenth Amendment to 18 the United States Constitution. 19 Q. (By Mr. Edwards) When you were digitally 20 penetrating these minor girls, did you care about 21 the fact that you were emotionally or 22 psychologically hurting them? 23 MR. BURMAN: Object to the form of the 24 question. 25 THE WITNESS: I intend to respond to all 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 151 Q. (By Mr. Edwards) Isn't it true that at the time that you were sexually battering these minor girls, you didn't care what happened to them and only cared about your only personal sexual gratification? MR. BURMAN: Object to the form. We need to talk outside. THE WITNESS: Me, too? THE VIDEOGRAPHER: We're off the record at 2:35. (Thereupon, a brief break was taken.) THE VIDEOGRAPHER: We're back on the record at 2:36. MR. BURMAN: For the purposes of the record, I will toll you that this line of questioning, in my view, is way beyond the bounds of permissible discovery-type questions, and nothing but pure argument, and if you continue in this vein, I will stop the deposition and we will seek instruction from Judge Hafele about what's permissible and what's not. Q. (By Mr. Edwards) Isn't it true that at the time you were inserting your fingers into the vagina of these little kids, all you cared about was Page 150 1 relevant questions regarding this lawsuit. 2 However, at the present time my attorneys have 3 counseled me that I cannot provide answers to 4 any questions relevant to this lawsuit, and I 5 must accept this advice or risk losing my Sixth 6 Amendment right to effective representation. 7 Accordingly, I assert my Federal 8 Constitutional rights as guaranteed by the 9 Fifth, Sixth, and Fourteenth Amendments to the 10 United States Constitution. 11 Q. (By Mr. Edwards) We have heard over and 12 over again that you intend to respond to this. When 13 do you intend to respond to these questions? 14 MR. BURMAN: Object to the form. 5 THE WITNESS: I intend to respond to all 16 relevant questions regarding this lawsuit. 17 However, at the present time on advice of 18 counsel I cannot provide answers to those 19 questions at this time. I must accept advice 20 of my counsel or risk losing my Sixth Amendment 21 right to effective representation. 22 Accordingly, I'll have to assert my 23 Federal Constitutional rights as guaranteed by 24 the Fifth, Sixth, and Fourteenth Amendment to 25 the United States Constitution. 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 152 your own sexual gratification? MR. BURMAN: The deposition is over. THE VIDEOGRAPHER: Conclude at 2:37, end of tape 2 of 2. MR. BERGER: We're going to order instant copy, and we want the tape, also, Mr. Videographer. MR. BURMAN: We want this as soon as they get theirs, we want ours. (Thereupon, the deposition was adjourned at 2:38 p.m.) 38 (Pages 149 to 1 5 2) PALM BEACH REPORTING SERVICE, INC. EFTA01103363 1 2 3 Page 153 CERTIFICATE OF OATH STATE OF FLORIDA ) : SS COUNTY OF PALM BEACH ) 1 2 3 4 s Page TO I MILEY EPSTEIN elo MENA& URMAN. ESQUIRE 515 N JOHN onb Fluke DriveBrStile 400 Nest Peen Beach, Florida 33401 air. vs. 7117FREY EPSTEIN and 155 4 6 Al tht conclusion of your depositien gives 5 I, the undersigned authority, certify that 7 In the abovutylod cute too Indicated you withod 6 JEFFREY EPS1EIN personally appeared before the and 8 I' astir he analla 7 was duly sworn. TS Meer Is b advise you that you 8 WITNESS my hand and official seal this 1st 9 depositioa is ready. end re ask eat you anger oaks ni (Sal) 4713995 Myour maw 9 day of May, 2009. is conuenithes for at appointment tourer in. 11 If you ere path a °akin se tter 10 attar has endued a copy of Ode trensaipt, rat 11 12 aterideb to read lin copy and Ithward to us 2 photostatic othy Oyu: tired cethectke sheet LINDA P. AUKAMP, RPR 12 13 13 Commission No.: DD 499271 14 it is secunty dist toedo Elite icon u mt . since dm inmalth mum be hold 14 Notary Public- State of Florida 1S brood months handy date of this Wier. 15 My Commission Expires: 12-26-09 If rya have sat/reason which you would 16 16 like Par nth to pact on thedeposition as to re haws to I* *tuna. ukase advise. 17 17 18 18 Tank you for you prompt attetthou. 19 velytnavyvvn. 19 PALM BEACH READRTNG SERVICE. D40. 20 1665 Pain Bach Lakes Ellud. 21 20 Saito 1001 West Palm Beach. Fkeicla 33401 22 n 23 22 23 BY: LINDA P. AUKAMP.RPR 24 Dale Ntay 1st. 2029 25 2 245 Page 154 Page 156 1 REPORTER'S DEPOSITION CERTIFICATE 1 CORRECTION SHEET: 2 2 NAME: JEFFREY EPSTEIN 3 STATE OF FLORIDA ) I RE: E.W. vs. JEFFREY EPSTEIN and 4 COUNTY OF PALM BEACH ) 4 5 I, LINDA P. AUKAMP, a Registered The following corrections, additions or 6 7 Professional Reporter, certify that I was authorized to and did stenographically report the depositim of 5 6 deletions were noted on the transcript of the testimony which I gave in the above-captioned matter held on April 30th, 2009: 8 JEFFREY EPSTEIN; that a review of the transcript was 7 PAGE(S) LINE(S) SHOULD READ 9 requested; and that the transcript is a true and 8 10 complete record of my stenographic notes. 9 11 I FURTHER CERTIFY that on the 1st day of 10 12 May, 2009,1notified JOHN MICHAEL BURMAN, ESQUIRE 11 13 that the deposition of JEFFREY EPSTEIN was ready fa 12 14 reading and signing by the witness. 13 15 I fitrther certify that I am not a 14 16 relative, employee, attorney, or counsel of any of 15 17 the parties, nor am I a relative or employee of any 16 18 of the parties' attorney or counsel connected with 17 19 the action, nor am I financially interested in the 18 2O action. 19 20 21 Dated this 1st day of May, 2009. 21 22 22 SIGNATURE: 23 23 DATE: 24 LINDA P. AUKAMP, RPR 24 25 25 39 (Pages 153 to 156) PALM BEACH REPORTING SERVICE, INC. EFTA01103364