DS9 Document EFTA01158588

0172 1 2 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 3 4 5 =-1 6 7 - Vs- CASE No. 502008CA037319XXXXMB AB Plaintiff, 9 JEFFREY EPSTEIN, 10 Defendant. 11 12 13 CONTINUED DEPOSITION OF JEFFREY EPSTEIN 14 VOLUME III 15 16 Thursday, October 8, 2009 17 18 1:46 - 3:48 p.m. 19 20 250 South Australian Avenue Suite 1400 21 West Palm Beach,Florida 33401 22 23 Reported By: Jeana Ricciuti, RPR, FPR, CLR 24 Notary Public, State of Florida Prose Court Reporting Agency, Inc. 25 0173 1 APPEARANCES: 2 On behalf of the Plaintiff: SPENCER T. KUVIN, ESQUIRE 3 ADAM LANGINO, ESQUIRE LEOPOLD KUVIN, P.A. 4 2295 PGA Boulevard Suite 200 5 Palm Beach Gardens, Florida 33410 Phone: 6 On behalf of §§§. and III. and Jane Doe in Case No. 7 80893: CARA L. HOLMES, ESQUIRE 8 ROTHSTEIN, ROSENFELDT & ADLER 401 East Las Olas Boulevard 9 Suite 1650 Fort Lauderdale, Florida 33301 10 Phone: 11 On behalf of Plaintiff Jane Doe in Case No. 80591 and 80656 via telephone: 12 KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK, P.A. 13 25 West Flagler Street Miami, Florida 33130 14 Phone: 15 On behalf of the Defendant: JACK GOLDBERGER, ESQUIRE 16 STORY KOWLES, PARALEGAL ATTERBURY, GOLDBERGER & WEISS, P.A. EFTA01158588 17 250 South Australian Avenue 18 Suite 1400 West Palm Beach, Florida 33401 Phone: 19 MICHAEL J. PIKE, ESQUIRE 20 BURMAN, CRITTON, LUTTIER & COLEMAN, P.A. 21 303 Banyan Boulevard Suite 400 22 West Palm Beach, Florida Phone: 33401 23 ALSO PRESENT: 24 DAN DOSKEY, VIDEOGRAPHER 25 VISUAL EVIDENCE, INC. 0174 1 2 EXHIBITS 3 WITNESS: CONT'D DIRECT 4 JEFFREY EPSTEIN 5 BY MR. KUVIN 175 6 7 8 EXHIBITS 9 - - - - 10 NUMBER DESCRIPTION PAGE 11 PLAINTIFF'S EX. 9 PHOTOGRAPH OF GHISLAINE 182 MAXWELL 12 PLAINTIFF'S EX. 10 PHOTOGRAPH OF JOANNA 191 SHOGERT 13 PLAINTIFF'S EX. 11 PHOTOGRAPH OF EULA MAXWELL 196 PLAINTIFF'S EX. 12 PHOTOGRAPH 198 14 PLAINTIFF'S EX. 13 PHOTOGRAPH OF 199 PLAINTIFF'S EX. 14 PHOTOGRAPH OF PLAINTIFF'S EX. 15 PHOTOGRAPH OF 201 16 PLAINTIFF'S EX. 16 PHOTOGRAPH OF PRINCE 201 ANDREW 17 PLAINTIFF'S EX. 17 LETTER TO B. KRISCHER FROM 203 M. REITER 18 PLAINTIFF'S EX. 18 RECEIPT OF PURCHASES MADE 206 FROM JAIL 19 PLAINTIFF'S EX. 19 FAA REGISTRY 218 20 21 22 23 24 25 0175 1 PROCEEDINGS 2 - - - 3 THE VIDEOGRAPHER: We're back on the record at 4 1:46. 5 CONTINUED DIRECT EXAMINATION 6 BY MR. KUVIN: 7 Q. Do you personally know John Mack, former CEO 8 at Morgan Stanley? 9 A. I'll have to answer that the same way I've 10 answered most of your questions here today, Mr. Kuvin, 11 which is, I intend to respond to all relevant questions EFTA01158589 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0176 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 0177 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. MR. KUVIN: Okay. Same deposition as shown before, different clip. I'm going to play it for counsel first. MR. PIKE: Thank you. MR. KUVIN: Mr. Videographer, just let me know when you're ready. THE VIDEOGRAPHER: Whenever you are. MR. KUVIN: Okay. (Video played.) VIDEO WITNESS: "What did I do to Jeffrey and what did Jeffrey do to me? I went up there multiple times; I can't count. And I would be on a massage table, massaging his legs, he would turn over, his penis would be hanging out. He would put a vagina -- or a vibrator to my vagina. He would touch my vagina with his fingers. He would touch my breasts. He would try to kiss my mouth. He would bring my hands toward his penis." (Video stopped.) MR. KUVIN: Okay. MR. PIKE: I'm just going to object to the use of the video as to relevance, predicate and foundation. BY MR. KUVIN: Q. All right. Let me get it back to the same location. Sir, first of all, lay the foundation for this, A. I'm going to have the same way I've responded questions here today, which once again, just so I can do you recognize this girl? to respond to that question to most of your other is, I intend to respond to all relevant cannot provide answers to any questions relevant to this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to the lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. Q. Did this girl bring §§§. to your home for a naked massage? A. I'm going to have to respond to that the same way I've responded to most of your other questions here today, which is, I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions that may be relevant to the lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. EFTA01158590 23 Q. I'd like to play this clip for you and then 24 I'm going to ask you a question. 25 MR. PIKE: The same clip you just played? 0178 1 MR. KUVIN: Exactly. 2 MR. PIKE: Same objection. 3 (Video played.) 4 VIDEO WITNESS: "What did I do to Jeffrey and 5 what did Jeffrey do to me? I went out there 6 multiple times; I can't count. And I would be on a 7 massage table, massaging his legs. He would turn 8 over, his penis would be hanging out. He would put 9 a vagina -- or vibrator to my vagina. He would 10 touch my vagina with his fingers. He would touch 11 my breasts. He would try to kiss my mouth. He 12 would bring my hands toward his penis." 13 (Video stopped.) 14 BY MR. KUVIN: 15 Q. Did you do that with that girl? 16 MR. PIKE: Form. 17 THE WITNESS: I intend to respond to all 18 relevant questions regarding this lawsuit; however, 19 at the present time, my attorneys have counseled me 20 I cannot provide answers to any questions that may 21 be relevant to this lawsuit. I must accept this 22 advice or risk losing my 6th Amendment right to 23 effective representation. Accordingly, I must 24 assert my federal constitutional rights as 25 guaranteed by the 5th, 6th and 14th Amendment to 0179 1 the United States Constitution. 2 BY MR. KUVIN: 3 Q. Did you do what that young lady described just 4 now to hundreds of women, including III.? 5 MR. PIKE: Form, argumentative, harassing, 6 lacks appropriate predicate, foundation, lacks 7 identity. 8 THE WITNESS: Excuse me. I'm going to respond 9 to that the same way I've responded to most of your 10 other questions here today, which is, I intend to 11 respond to all relevant questions regarding this 12 lawsuit; however, at the present time, my attorneys 13 have counseled me that I cannot provide answers to 14 any questions relevant to the lawsuit. I must 15 accept their advice or risk losing my 6th Amendment 16 right to effective representation. Accordingly, I 17 must assert my federal constitutional rights as 18 guaranteed by the 5th, 6th and 14th Amendment to 19 the United States Constitution. 20 BY MR. KUVIN: 21 Q. While §§§. was standing naked in your home, 22 specifically in your bathroom, did you tell her that you 23 could get her an interview as a model because of your 24 connections? 25 A. I'm going respond to that the same way I've 0180 1 responded to most of your questions today, Spencer. I 2 intend to respond to all relevant questions regarding 3 this lawsuit; however, at the present time, my attorneys 4 have counseled me I cannot provide answers to any 5 questions that may be relevant to the lawsuit. I must 6 accept this advice or risk losing my 6th Amendment right 7 to effective representation. Accordingly, I must assert EFTA01158591 8 my federal constitutional right as guaranteed by the 9 5th, 6th and 14th Amendment to the United States 10 Constitution. 11 MR. PIKE: Same objection to that line of 12 questioning. 13 BY MR. KUVIN: 14 Q. As §§§. was standing naked in your bathroom 15 before you when she was 15, did you ask her to turn 16 around so you could see her ass better? 17 MR. PIKE: Form, argumentative, harassing, 18 lacks appropriate predicate, foundation. 19 THE WITNESS: I'll respond to that as I 20 responded to your last question, which is, I intend 21 to respond to all relevant questions regarding this 22 lawsuit; however, at the present time, my attorneys 23 have counseled me I cannot provide answers to any 24 questions that may be relevant to this lawsuit. I 25 must accept their advice or risk losing my 6th 0181 1 Amendment right to effective representation; 2 therefore, I must assert my federal constitutional 3 rights as guaranteed by the 5th, 6th and 14th 4 Amendment to the United States Constitution. 5 BY MR. KUVIN: 6 Q. When III. was 15 years old and standing naked 7 in front of you in your bathroom, did you tell her that 8 you could help her become a model? 9 MR. PIKE: Same objections, including 10 foundation. 11 THE WITNESS: Is it different than the last 12 question? 13 MR. KUVIN: Uh-huh. 14 MR. GOLDBERGER: Just go ahead. 15 THE WITNESS: Okay. I intend to respond to 16 all relevant questions pertaining to this lawsuit; 17 however, at the present time, my attorneys have 18 counseled me I cannot provide answers to any 19 questions that may be relevant to this lawsuit, so 20 I've answered most questions here today the same 21 way. I must expect that -- accept their advice or 22 risk losing my 6th Amendment right to effective 23 representation. Accordingly, I assert my federal 24 constitutional rights as guaranteed by the 5th, 6th 25 and 14th Amendment to the United States 0182 1 2 BY 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Constitution. MR. KUVIN: Q. Who is Ghislaine Maxwell? 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. As I have done to most of your other questions here today, I must accept their advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. MR. KUVIN: Let me show the camera what we'll mark as Exhibit 9 to this deposition. THE VIDEOGRAPHER: Okay. (Plaintiff's Exhibit No. 9 was marked for identification.) EFTA01158592 19 BY MR. KUVIN: 20 Q. Let me show you what we've marked as Exhibit 9 21 to your deposition. Do you recognize Ghislaine Maxwell 22 in this photograph? 23 A. Yes. 24 Q. And who is she standing with? 25 A. Her father. 0183 1 Q. And her father is Robert Maxwell? 2 A. Was Robert Maxwell. 3 Q. I'm sorry, he's passed, correct? 4 A. Correct. 5 Q. She is a close friend of yours, is she not? 6 A. I'm going to respond to that question the same 7 way I've responded to most of your other questions here 8 today, Mr. Kuvin, which is, I intend to respond to all 9 relevant questions regarding to this lawsuit; however, 10 at the present time, my attorneys have counseled me I 11 cannot provide answers to any questions that may be 12 relevant to this lawsuit. I must expect -- accept their 13 advice or risk losing my 6th Amendment right to 14 effective representation. Accordingly, I must assert my 15 federal constitutional rights as guaranteed by the 5th, 16 6th and 14th Amendment to the United States 17 Constitution. 18 Q. Ghislaine Maxwell has accompanied you to 19 numerous social events in the last few years; isn't that 20 true? 21 MR. PIKE: Form. 22 THE WITNESS: I'm going to respond to that 23 question the same way I've responded to most of 24 your questions here today, which is, I intend to 25 respond to all relevant questions regarding your 0184 1 lawsuit; however, at the present time, my attorneys 2 have counseled me I cannot provide answers to any 3 questions that may be relevant to that lawsuit. I 4 must accept their advice or risk losing my 6th 5 Amendment right to effective representation. 6 Accordingly, I must assert my federal 7 constitutional right as guaranteed by the 5th, 6th 8 and 14th Amendment of the United States 9 Constitution. 10 BY MR. KUVIN: 11 Q. One of your houseboys that has been deposed in 12 this case testified that you were a rather nice 13 gentleman that used to talk to the staff, and that when 14 Ms. Maxwell came into the picture, that you stopped 15 talking to the staff and the staff had to communicate 16 through Ms. Maxwell. Do you agree or disagree with 17 that? 18 MR. PIKE: Form, foundation, predicate, 19 argumentative, assumes facts not in evidence. 20 THE WITNESS: I'm going to answer that the 21 same way I've answered most of your questions here 22 today, which is, I intend to respond to all 23 relevant questions regarding this lawsuit; however, 24 at the present time, my attorneys have counseled me 25 that I cannot provide answers to any questions that 0185 1 may be relevant to your lawsuit. I must accept 2 their advice or risk losing my 6th Amendment right 3 to effective representation. Accordingly, I assert EFTA01158593 4 my federal constitutional rights as guaranteed by 5 the 5th, 6th and 14th Amendment of the United 6 States Constitution. 7 BY MR. KUVIN: 8 Q. He also testified that he felt you were a 9 rather normal guy until Ms. Maxwell came into the 10 picture, and that she led you into this life of 11 perversion, sexual perversion. Do you agree with that? 12 MR. PIKE: Same objections. 13 THE WITNESS: I'm going to respond to that the 14 same way I've responded to most of your questions 15 here today, Mr. Kuvin, which is, I intend to 16 respond to all relevant questions regarding this 17 lawsuit; however, at the present time, my attorneys 18 have counseled me I cannot provide answers to any 19 questions relevant to this lawsuit. I must accept 20 their advice or risk losing my 6th Amendment -- 21 excuse me -- I must accept their advice or risk 22 losing my 6th Amendment right to effective 23 representation. Accordingly, I must assert my 24 federal constitutional rights as guaranteed by the 25 5th, 6th and 14th Amendment to the United States 0186 1 2 BY 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 girl 19 have 20 21 22 23 24 25 0187 1 to respond to all relevant questions regarding this 2 lawsuit; however, at the present time, my attorneys 3 have counseled me I cannot provide answers to any 4 questions relevant to that lawsuit. I must accept 5 their advice or risk losing my 6th Amendment right 6 to effective representation. Therefore, I assert 7 my federal constitutional rights as guaranteed by 8 the 5th, 6th and 14th Amendments to the United 9 States Constitution. 10 BY MR. KUVIN: 11 Q. Do you know where Donald Trump's Maralago 12 estate is? 13 A. Yes. 14 Q. Have you been there? Constitution. MR. KUVIN: Q. Did Ms. Maxwell procure underaged girls for you to have sexual relationships with? A. I'm going to answer that question the same way I've answered most of your other questions today, Mr. Kuvin, which is, I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to that lawsuit. Excuse me. I must accept their advice or risk losing my 6th Amendment right to effective representation. Accordingly, I must assert my federal constitutional rights as guaranteed -- guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. Q. Ms. Maxwell procured a particular underaged who worked at Donald Trump's Maralago, for you to a sexual relationship with; isn't that true? MR. PIKE: Form, argumentative, lacks appropriate predicate, foundation, assumes facts not in evidence. THE WITNESS: I'm going to respond to that the same way I've responded to most of your other questions here today, Mr. Kuvin, which is, I intend EFTA01158594 15 16 17 18 19 20 21 22 23 24 25 0188 1 rights as guaranteed by the 5th, 6th and 14th Amendment 2 to the United States Constitution. 3 Q. Have you seen the high school transcripts 4 grades of girls that you have had sexual relationships 5 with dating back to 2005? 6 MR. PIKE: Form, relevance, improper 7 hypothetical, lacks facts -- assumes facts not in 8 evidence, lacks appropriate predicate, foundation. 9 THE WITNESS: I'm going to answer that 10 question the same as I've answered most of your 11 other questions here today, Mr. Kuvin, which is, I 12 intend to respond to all relevant questions 13 regarding this lawsuit; however, at the present 14 time, my attorneys have counseled me that I cannot 15 provide answers to any questions that may be 16 relevant to this lawsuit. I must accept their 17 advice or risk losing my 6th Amendment right to 18 effective representation. Accordingly, I assert my 19 federal constitutional rights as guaranteed by the 20 5th, 6th and 14th Amendment to the United States 21 Constitution. 22 BY MR. KUVIN: 23 Q. Do you deny that the high school transcripts 24 which were found in your trash on Palm Beach that showed 25 the ages of some of the girls you were engaged with 0189 1 sexual acts with at your home came from your house? 2 MR. PIKE: Same objection in addition to 3 argumentative and harassing. 4 THE WITNESS: I intend to respond to all 5 relevant questions regarding this lawsuit; however, 6 as I've done with most of your other questions 7 today, at the present time my attorneys have 8 counseled me that I cannot provide answers to any 9 of those questions relevant to this lawsuit. I 10 must accept their advice or risk losing my 6th 11 Amendment right to effective representation. 12 Accordingly, I must assert my federal 13 constitutional rights as guaranteed by the 5th, 6th 14 and 14th Amendments to the United States 15 Constitution. 16 BY MR. KUVIN: 17 Q. Did you have numerous photos of nude young 18 women, girls under the age of 18, back in your home 19 in -- on Palm Beach Island in 2005 and 2006? 20 A. I'm going to have to respond to that question 21 the same way I've responded to most of your questions 22 here today, which is, I intend to respond to all 23 relevant questions regarding this lawsuit; however, at 24 the present time, my attorneys have counseled me I 25 cannot provide answers to any questions relevant to the A. Yes. Q. Who with? A. I'm going to have to answer that question the same way I've answered most of your other questions here today. I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions that may be relevant to the same lawsuit. I must accept their advice or risk losing my 6th Amendment right to effective representation. Accordingly, I must assert my federal constitutional EFTA01158595 0190 1 same lawsuit. I must accept their advice or risk losing 2 my 6th Amendment right to effective representation. 3 Accordingly, I must assert my federal constitutional 4 rights as guaranteed by the 5th, 6th and 14th Amendment. 5 Q. Did you have photographs of girls under the 6 age of ten who were nude, either partially or fully 7 nude, in your home on Palm Beach in 2005 and 2006? 8 MR. PIKE: Form. 9 THE WITNESS: I'm going to respond to that 10 question the same way I've responded to most of 11 your other questions, which is, I intend to respond 12 to all relevant questions regarding this lawsuit; 13 however, at the present time, my attorneys have 14 counseled me I cannot provide answers to any 15 questions relevant to this lawsuit. I must accept 16 this advice or risk losing my 6th Amendment right 17 to effective representation. Accordingly, I assert 18 my federal constitutional rights as guaranteed by 19 the 5th, 6th and 14th Amendments of the United 20 States Constitution. 21 THE VIDEOGRAPHER: Mr. Kuvin, I'm sorry I have 22 to change. 23 MR. KUVIN: Go ahead. 24 THE VIDEOGRAPHER: We'll go off the record at 25 2:03. This will be the end of tape No. 2. 0191 1 MR. GOLDBERGER: Break time? 2 MR. KUVIN: No, not again. Please not. 3 Just let us know when you're good to go. 4 THE VIDEOGRAPHER: We're back on the record at 5 2:04. This will be the beginning of tape No. 3. 6 BY MR. KUVIN: 7 Q. Do you have security cameras throughout your 8 home on Palm Beach Island? 9 A. I'm going to answer that question the same way 10 I've answered most of your questions here today, 11 Mr. Kuvin. I intend to respond to all relevant 12 questions regarding this lawsuit; however, at the 13 present time, my attorneys have counseled me I cannot 14 provide answers to any questions relevant to the 15 lawsuit. I must accept their advice or risk losing my 16 6th Amendment right to effective representation. 17 Accordingly, I assert my federal constitutional rights 18 as guaranteed by the 5th, 6th and 14th Amendment to the 19 United States Constitution. 20 (Plaintiff's Exhibit No. 10 was marked for 21 identification.) 22 MR. KUVIN: I'll show the camera a photograph 23 here. Okay? 24 THE VIDEOGRAPHER: Lift it up. Yeah, there 25 you go. Okay. 0192 1 MR. KUVIN: Okay? 2 BY MR. KUVIN: 3 Q. Let me show you what we marked as Plaintiff's 4 Exhibit 10. Do you recognize this young lady? 5 A. Yes. 6 Q. Who is she? 7 A. Her name is Joanna Shogert (phonetic). 8 Q. And who is she? 9 A. I just -- her name is Joanna Shogert. 10 Q. How do you recognize her? EFTA01158596 11 A. I don't understand the question. 12 Q. Well, is she a friend of yours? Did she work 13 for you? How do you recognize her? 14 A. How do I recognize her? 15 Well, I'd like to respond to that question 16 but, however, my attorneys have told me that I can't 17 respond to any questions today that may -- excuse me. I 18 intend to respond to all relevant questions regarding 19 this lawsuit; however, at the present time, my attorneys 20 have counseled me that I cannot provide answers to any 21 questions relevant to this lawsuit. I must accept their 22 advice or risk losing my 6th Amendment right to 23 effective representation. Accordingly, I assert my 24 federal constitutional rights as guaranteed by the 5th, 25 6th and 14th Amendment to the United States 0193 1 Constitution. 2 Q. Did you have sex with Joanna Shogert? 3 A. I'm going to answer that question like I've 4 answered most of your questions here today, which is, I 5 intend to respond to all relevant questions regarding 6 this lawsuit; however, at the present time, my attorneys 7 have counseled me I cannot provide answers to any 8 questions relevant to this lawsuit. I must accept their 9 advice or risk losing my 6th Amendment right to 10 effective representation. Accordingly, I assert my 11 federal constitutional rights as guaranteed by the 5th, 12 6th and 14th Amendment to the United States 13 Constitution. 14 Q. When did you first meet Prince Andrew? 15 And let me make it a compound question so I 16 don't have to repeat it over and over. When did you 17 first meet Prince Andrew, under what conditions did you 18 meet him, and who was present at that first meeting? 19 A. I'm going to answer that question as I've done 20 most of your questions here today, Mr. Kuvin, which is, 21 I intend to respond to all relevant questions regarding 22 this lawsuit; however, at the present time, my attorneys 23 have counseled me I cannot provide answers to any 24 questions relevant to that lawsuit. I must accept their 25 advice or risk losing my 6th Amendment right to 0194 1 effective representation. Accordingly, I must assert my 2 federal constitutional rights as guaranteed by the 5th, 3 6th and 14th Amendment to the United States 4 Constitution. 5 MR. PIKE: In addition, relevance. 6 BY MR. KUVIN: 7 Q. Do you pay Ms. Maxwell a salary? 8 MR. PIKE: Form. 9 BY MR. KUVIN: 10 Q. Ghislaine Maxwell, so we're clear. Do you pay 11 her a salary? 12 A. I'd like -- excuse me. I'm going to answer 13 that question the same way I've answered most of your 14 questions here today, which is, I intend to answer all 15 questions relevant to this lawsuit; however, at the 16 present time, my attorneys have counseled me I cannot 17 provide answers to any questions relevant to this 18 lawsuit. I must accept their advice or risk losing my 19 6th Amendment right to effective representation. 20 Accordingly, I assert my federal constitutional rights 21 as guaranteed by the 5th, 6th and 14th Amendment to the EFTA01158597 22 United States Constitution. 23 Q. Did you provide any underaged girls for sex to 24 Prince Andrew? 25 MR. PIKE: Form. 0195 1 THE WITNESS: I'm going to respond to that 2 question the same way I've responded to most of 3 your questions here today, Mr. Kuvin, which is, I 4 intend to respond to all relevant questions 5 regarding this lawsuit -- excuse me, however, at 6 the present time, my attorneys have counseled me I 7 cannot provide answers to any questions relevant to 8 the lawsuit, or might be relevant to the lawsuit. 9 I must accept their advice or risk losing my 6th 10 Amendment right to effective representation. 11 Accordingly, I assert my federal constitutional 12 rights as guaranteed by the 5th, 6th and 14th 13 Amendment of the United States Constitution. 14 BY MR. KUVIN: 15 Q. Did you fly with Prince Andrew on your plane, 16 or planes, with any underaged girls, girls under the age 17 of 18? 18 A. I'm going to answer that question the same way 19 I've answered all the other questions here today, 20 virtually, which is, I intend to respond to all relevant 21 questions regarding this lawsuit; however, at the 22 present time, my attorneys have counseled me I cannot 23 provide answers to any questions relevant to the 24 lawsuit. I must accept their advice or risk losing my 25 6th Amendment right to effective representation. 0196 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 0197 1 A. Eula Maxwell (phonetic). 2 Q. Where were you? 3 A. I intend to respond to all relevant questions 4 regarding this lawsuit; however, at the present time, my 5 attorneys have counseled me I cannot provide answers to 6 any questions that may be relevant to this lawsuit. I Accordingly, I must assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. Q. Do you know Christine Drangsholt? MR. KUVIN: For the court reporter, it's D-R-A-N-G-S-H-O-L-T. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to the lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. MR. KUVIN: Let me show the camera what we'll mark as Exhibit 11. (Plaintiff's Exhibit No. 11 was marked for identification.) THE VIDEOGRAPHER: Okay. MR. KUVIN: Okay? BY MR. KUVIN: Q. In Exhibit 11, sir, you're standing with a woman. Who is that woman in that photograph? EFTA01158598 7 must accept this advice or risk losing my 6th Amendment 8 right to effective representation. Accordingly, I must 9 assert my federal constitutional rights as guaranteed by 10 the 5th, 6th and 14th Amendments to the United States 11 Constitution. 12 MR. KUVIN: And just so the court reporter 13 knows, Ghislaine is spelled G-H-I-S-L-A-I-N-E. 14 BY MR. KUVIN: 15 Q. Who is excuse 16 me? 17 A. I'm going to answer that question the same way 18 I've answered most of your questions here today, which 19 is, I intend to respond to all relevant questions 20 regarding this lawsuit; however, at the present time, my 21 attorneys have counseled me I cannot provide answers to 22 any questions relevant to the lawsuit. I must accept 23 their advice or risk losing my 6th Amendment right to 24 effective representation. Excuse me. Accordingly, I 25 must assert my federal constitutional rights as 0198 1 guarantee -- guaranteed by the 5th, 6th and 14th 2 Amendment to the United States Constitution. 3 (Plaintiff's Exhibit No. 12 was marked for 4 identification.) 5 MR. KUVIN: Let me show to the camera what 6 we've marked as Exhibit 12. 7 BY MR. KUVIN: 8 Q. Let me show you what I've marked as Exhibit 9 12. Do you recognize any of the girls in that 10 photograph? 11 A. I'm going to answer that question the same way 12 I've answered most of your other questions here today, 13 Mr. Kuvin, which is, I intend to respond to all relevant 14 questions regarding this lawsuit; however, at the 15 present time, my attorneys have counseled me that I 16 cannot provide answers to any questions that may be 17 relevant to the lawsuit. I must accept their advice or 18 risk losing my 6th Amendment right to effective 19 representation. Accordingly, I assert my federal 20 constitutional rights as guaranteed by the 5th, 6th and 21 14th Amendment to the United States Constitution. 22 Q. Sir, isn't it true that in what we've marked 23 as Plaintiff's Exhibit 12, the blond standing on the 24 left is , and the blonde, dirty blonde 25 standing on the right is ? 0199 1 A. I intend to respond to all relevant questions 2 regarding this lawsuit; however, as I've done to most of 3 the questions at the present time, my attorneys have 4 counseled me that I cannot provide answers to any of 5 those questions that may be relevant to the lawsuit. I 6 must accept this advice or risk losing my 6th Amendment 7 right to effective representation. Accordingly, I 8 assert my federal constitutional rights as guaranteed by 9 the 5th, 6th and 14th Amendments of the United States 10 Constitution. 11 BY MR. KUVIN: 12 Q. I'm going to show you what we'll mark as 13 Exhibit 13. Let me show it to the camera, first. 14 (Plaintiff's Exhibit No. 13 was marked for 15 identification.) 16 BY MR. KUVIN: 17 Q. Sir, is it true that Exhibit 13 shows your EFTA01158599 18 personal assistant, 19 A. I intend to respond to all relevant questions 20 regarding this lawsuit; however, at the present time, my 21 attorneys have counseled me that I cannot provide 22 answers to any questions that may be relevant to this 23 lawsuit. I must accept their advice or risk losing my 24 6th Amendment right to effective representation. 25 Accordingly, I assert my federal constitutional rights 0200 1 as guaranteed by the 5th, 6th and 14th Amendment to the 2 United States Constitution. 3 Q. Let me show you what we'll mark as Exhibit 14. 4 (Plaintiff's Exhibit No. 14 was marked for 5 identification.) 6 BY MR. KUVIN: 7 Q. Sir, does Exhibit 14 show , a 8 girl that you have had a sexual relationship with since 9 before she was 18 years old? 10 MR. PIKE: Form, argumentative, harassing, 11 assumes facts not in evidence, lacks appropriate 12 predicate and foundation. 13 THE WITNESS: I intend to respond to all 14 relevant questions regarding this lawsuit; however, 15 at the present time, my attorneys have counseled me 16 I cannot provide answers to any questions relevant 17 to this lawsuit. I must accept their advice or 18 risk losing my 6th Amendment right to effective 19 representation. Accordingly, I assert my federal 20 constitutional rights as guaranteed by the 5th, 6th 21 and 14th Amendment to the United States 22 Constitution. 23 BY MR. KUVIN: 24 Q. I'm going to show the camera what we'll mark 25 as Exhibit 15. 0201 1 (Plaintiff's Exhibit No. 15 was marked for 2 identification.) 3 BY MR. KUVIN: 4 Q. Sir, does Exhibit 15 show , an 5 underaged girl that you were utilizing back in 2005 and 6 2006 to procure other underaged girls for sex and sexual 7 contact at your home? 8 MR. PIKE: Same objections to Exhibit 15 as 9 were made to Exhibit 14. 10 THE WITNESS: I'm going to answer that the 11 same way I've answered most of your questions here 12 today, Mr. Kuvin, which is, I intend to respond to 13 all relevant questions regarding this lawsuit; 14 however, at the present time, my attorneys have 15 counseled me that I cannot provide answers to any 16 questions that may be relevant to the lawsuit. I 17 must accept their advice or risk losing my 6th 18 Amendment right to effective representation. 19 Accordingly, I am going to assert my federal 20 constitutional rights as guaranteed by the 5th, 6th 21 and 14th Amendments to the United States 22 Constitution. 23 (Plaintiff's Exhibit No. 16 was marked for 24 identification.) 25 MR. KUVIN: Let me show the camera what we've 0202 1 marked as Exhibit 16. 2 BY MR. KUVIN: EFTA01158600 3 Q. Do you recognize the gentleman in that 4 photograph, sir? 5 MR. PIKE: Hold on for a second. 6 MR. GOLDBERGER: Do you want to discuss it 7 with me? 8 MR. PIKE: Let's take a break for one minute. 9 MR. KUVIN: All right. 10 THE VIDEOGRAPHER: Off the record at 2:16. 11 (A brief recess was taken.) 12 THE VIDEOGRAPHER: We're back on the record at 13 2:45. 14 BY MR. KUVIN: 15 Q. Okay. Do you recognize the person that's 16 shown in Exhibit 16? 17 A. Yes. 18 Q. Who is that? 19 A. Prince Andrew. 20 Q. And how do you know Prince Andrew? 21 A. I'm going to have to respond to that question 22 the same way I've responded to most of your questions 23 here today, Mr. Kuvin, which is, I intend to respond to 24 all relevant questions regarding this lawsuit; however, 25 at the present time, my attorneys have counseled me I 0203 1 cannot provide answers to any questions relevant to this 2 lawsuit. I must accept their advice or risk losing my 3 6th Amendment right to effective representation. 4 Accordingly, I assert my federal constitutional rights 5 as guaranteed by the 5th, 6th and 14th Amendment to the 6 United States Constitution. 7 Q. I'm going to show you a document that we'll 8 mark as Exhibit 17. 9 MR. PIKE: Thank you. 10 (Plaintiff's Exhibit No. 17 was marked for 11 identification.) 12 BY MR. KUVIN: 13 Q. I'm going to give you a minute to take a look 14 at that document and just tell me when you're ready to 15 answer any questions about it. 16 A. Okay. 17 Q. Okay. First of all, have you seen this letter 18 before? 19 MR. GOLDBERGER: Attorney-client privilege, 20 work product. 21 BY MR. KUVIN: 22 Q. Have you seen this letter before outside of 23 the relationship with your attorneys? 24 MR. GOLDBERGER: You can answer that question. 25 THE WITNESS: No. 0204 1 BY MR. KUVIN: 2 Q. Do you know Chief of Police Michael Reiter? 3 Do you know who he is? 4 A. I know who he is. 5 Q. Do you know State Attorney Barry Krischer? 6 A. I know who he is. 7 Q. Did you ever speak with Chief of Police 8 Michael Reiter in the past? 9 A. I don't remember. 10 Q. Did you ever talk to anyone, either at the 11 State Attorney's office, yourself, or Michael Reiter 12 about the prosecution of your claim without the presence 13 of your attorneys? EFTA01158601 14 A. No. 15 Q. Did you ever talk to any of the police that 16 worked for the Town of Palm Beach without the presence 17 of your attorneys? 18 A. Explain -- 19 MR. PIKE: Wait one second. 20 THE WITNESS: I'm sorry. 21 MR. PIKE: Can you state the question again? 22 MR. KUVIN: Sure. 23 BY MR. KUVIN: 24 Q. Did you ever speak to any of the police 25 officers that worked for the Town of Palm Beach without 0205 1 the presence of your attorneys? 2 MR. GOLDBERGER: Is the question, have you 3 ever spoken to a Town of Palm Beach police officer? 4 Is that the -- can we rephrase it like that? 5 MR. KUVIN: Sure. 6 MR. GOLDBERGER: Okay. THE WITNESS: I've been stopped by the police for traffic violations, if that's what you mean. BY MR. KUVIN: Q. Any other times that you had conversations with any of the Town of Palm Beach -- A. No. Q. -- police officers? A. Not that I recall specifically. Q. Okay. Now, you were housed at the jail after your plea of guilty that we had spoke about at the beginning of your deposition; is that correct? MR. PIKE: Form. THE WITNESS: Say it again. BY MR. KUVIN: Q. Yes. You were housed at the local jail here in Palm Beach County after your plea of guilty that we spoke about at the beginning of your deposition? MR. PIKE: Form. THE WITNESS: Yes. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0206 1 BY MR. KUVIN: 2 Q. How long were you there? 3 A. 13 months, approximately. 4 Q. All right. And of those 13 months, how many 5 months were you there where you had to stay there 24 6 hours a 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A. I don't recall specifically. Q. More than a month? A. Yes. Q. More than two months? A. Yes. Q. More than three months? A. Yes. Q. More than four? A. I think so, I don't remember. Q. Do you recall when you were provided work release, when you were able to leave during the daylight hours? A. Not with specificity. Q. While you were there at the jail in Palm Beach -- I'm going to show you what we'll mark as Exhibit 18. (Plaintiff's Exhibit No. 18 was marked for identification.) EFTA01158602 25 0207 1 BY MR. KUVIN: 2 Q. Did you purchase items from the jail? 3 MR. GOLDBERGER: Hang on a second. 4 MR. PIKE: Hold on one second. 5 THE WITNESS: It looks that way, yes, sir. 6 BY MR. KUVIN: 7 Q. Okay. 8 MR. PIKE: And the document speaks for itself, 9 the composite document speaks for itself. 10 BY MR. KUVIN: 11 Q. I'd like you to take a look at Exhibit 18. It 12 shows purchases -- well, does it show purchases by you? 13 MR. PIKE: Asked and answered. 14 THE WITNESS: Yes. 15 BY MR. KUVIN: 16 Q. Okay. And it appears those purchases took 17 place from 7/8/08 through 9/30/08 is the last one that I 18 have; is that correct? 19 MR. PIKE: The document speaks for itself. 20 BY MR. KUVIN: 21 Q. You can answer. 22 A. The document speaks for itself. 23 Q. Is that correct, the last date is 9/30/08? 24 A. The last date here is 9/30, yes. 25 MR. PIKE: With regard to what you provided to 0208 1 the witness. 2 MR. KUVIN: Sure, absolutely. 3 THE WITNESS: Okay. 4 BY MR. KUVIN: 5 Q. And just so we're clear, this composite 6 exhibit that we've marked as Exhibit 18 contains purchases from 7/8/08, 7/15, 7/22, 7/29, 8/5, 8/12, 8/21, 8/26, 9/2, 9/9, 9/23 and 9/30, just so the record is clear; there is no question. A. Okay. Q. Okay? A. Uh-huh. Q. All right. These items that you purchased, did you utilize all of these items yourself? MR. PIKE: Form, relevance. THE WITNESS: I don't understand the question. BY MR. KUVIN: Q. Well, you purchased a number of items that are shown in this receipt. A. Yes. Q. The question is: Did you use them yourself? MR. PIKE: Same objection. THE WITNESS: I don't know if I used all of them, so... 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0209 1 BY MR. KUVIN: 2 Q. Well, what did you do with the items that you 3 purchased? 4 MR. PIKE: Form, overbroad. 5 BY MR. KUVIN: 6 Q. You can answer. 7 A. I used some, I threw away some. 8 Q. Did you give any away? 9 A. Not that I remember. EFTA01158603 10 MR. PIKE: Same objection. 11 BY MR. KUVIN: 12 Q. Did you provide any items that you purchased 13 to other inmates while you were there in jail? 14 MR. PIKE: Form. 15 THE WITNESS: Not to the best of my 16 recollection. 17 BY MR. KUVIN: 18 Q. Okay. With respect to all of the items that 19 are listed in these receipts, is it a safe assumption 20 that you either used them yourself or threw them away? 21 MR. PIKE: Asked and answered. If you don't 22 know -- if you know. 23 THE WITNESS: I don't know. 24 BY MR. KUVIN: 25 Q. I'm sorry? I didn't hear you. 0210 1 MR. PIKE: Asked and answered. 2 THE WITNESS: So should I answer? 3 MR. PIKE: You can answer again. 4 THE WITNESS: Ask the question again. 5 BY MR. KUVIN: 6 Q. So can we assume that all of the items that 7 are shown in these receipts were either used by you or 8 thrown away? 9 A. I don't even know if I received some of those 10 items, so I would assume I used most of them. 11 Q. Okay. 12 A. Okay? 13 Q. Sure. Take a look, I just want to make sure, 14 did you receive all these items? 15 A. I don't know. 16 MR. PIKE: Asked and answered. 17 BY MR. KUVIN: 18 Q. How did you purchase them? 19 A. I filled out a form. 20 Q. And how were they provided to you? 21 MR. PIKE: Form. 22 THE WITNESS: Sometimes they would come in a 23 bag. 24 BY MR. KUVIN: 25 Q. Okay. And did you determine whether or not 0211 1 the form you filled out, the information or the product 2 that you put on that form actually was provided? 3 A. No, never. 4 Q. If we look at the items that are contained 5 within these receipts, I'd like you to go, if you would, 6 to the second invoice here dated 7/15/08. The third 7 item down is a Lubriderm lotion. 8 A. Yes. 9 Q. Do you see that? 10 A. Yes. 11 Q. Did you purchase that? 12 A. It appears so. 13 Q. Did you receive it? 14 A. I don't remember. 15 Q. Did you use the Lubriderm lotion that you 16 received or that you may have received in jail? 17 MR. PIKE: Form. 18 BY MR. KUVIN: 19 Q. Let me strike that and re-ask it. 20 A. Okay. EFTA01158604 21 Q. Did you use the Lubriderm lotion which you had 22 purchased from the jail while you were there? 23 A. I might have. 24 Q. What for? 25 A. To moisturize my hands and face. 0212 1 Q. Okay. Did you use Lubriderm lotion while you 2 were in jail to masturbate at all? 3 A. No. 4 MR. PIKE: Form objection, harassing. 5 THE WITNESS: Absolutely not. 6 BY MR. KUVIN: 7 Q. It appears, if you would turn to 7/29/08, 8 which is approximately two weeks later, and the second 9 thing down is another bottle of Lubriderm lotion. Do 10 you see that? 11 A. Yes. 12 Q. What did you use that for? 13 MR. PIKE: Asked and answered. 14 MR. KUVIN: It's a second bottle. 15 MR. PIKE: It's the same question, Spencer. 16 Can we get to something relevant? 17 THE WITNESS: No problem. 18 MR. PIKE: He can answer. 19 THE WITNESS: My hands and my face. 20 BY MR. KUVIN: 21 Q. Okay. 22 A. I believe the first bottle went missing. 23 Q. If we turn to approximately one month later on 24 8/21/08, do you have that one? 25 A. Yes. 0213 1 Q. All right. On that occasion, you bought two 2 bottles of hand lotion again. 3 A. Yes. 4 Q. What did you use those for? 5 A. Nothing. 6 Q. What did you do with them? 7 A. They were bought by accident. 8 Q. How did you buy them by accident? 9 A. Because you fill out a check form and 10 sometimes the forms don't make any sense, they just 11 deliver in other things. 12 Q. Sir, did you get those two bottles? 13 A. Yes. Yes. 14 Q. And you never used them? 15 A. No. I threw them away. 16 Q. Okay. If we turn to 9/9/08, do you see that 17 entry? 18 A. Yes. 19 Q. All right. And another invoice here, on that 20 date a bottle of hand lotion, do you see that? 21 A. Yes, I do. 22 Q. Did you get it? 23 A. I don't know. 24 Q. Do you know if you used it? 25 A. Definitely not. 0214 1 Q. How do you know you definitely did not use it? 2 A. Because it was not -- anything that said hand 3 lotion I did not use, I threw in the garbage. 4 Q. Why is that? 5 A. Because it wasn't something that I had EFTA01158605 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0215 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 0216 1 2 3 4 5 6 ordered. MR. PIKE: Can I -- can I just have an agreement that the objections to this line of questioning is irrelevant, so I don't have to MR. KUVIN: Sure. MR. PIKE: -- interrupt. MR. KUVIN: Sure. MR. PIKE: Agreed? MR. KUVIN: Agreed. BY MR. KUVIN: Q. Let's turn again to 9/30/08, the last invoice in there. A. Yes. Q. Do you see there is an entry for two more bottles of hand lotion. Do you see that? A. Correct. Q. What did you do with those? A. To the best of my knowledge, I threw them right away. Q. You didn't use them for anything? A. No. Q. Is it your testimony here today that you did not use any of the bottles of hand lotion or Lubriderm lotion that we had previously just gone through to masturbate while you were in jail? A. That's correct. Q. Did Ghislaine Maxwell visit you in jail? A. No. Q. Did visit you while you were in jail? A. I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. Q. Did you have sex with while you were housed at the Palm Beach jail facility? MR. PIKE: Form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit. As I've answered most of your question today, Mr. Kuvin, I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 7 5th, 6th and 14th Amendments to the United States 8 Constitution. 9 BY MR. KUVIN: 10 Q. Did you pay girls so that they would not 11 testify against you in the civil proceedings that have 12 been filed in both Federal and State Court? 13 MR. PIKE: Form. 14 THE WITNESS: Okay. Like most of your other 15 questions here today, Mr. Kuvin, I'm going to 16 respond by saying I intend to respond to all EFTA01158606 17 relevant questions regarding this lawsuit; however, 18 at the present time, my attorneys have counseled me 19 I cannot provide answers to any questions relevant 20 to this lawsuit. I must accept this advice or risk 21 losing my 6th Amendment right to effective 22 representation. Accordingly, I must assert my 23 federal constitutional rights as guaranteed by the 24 5th, 6th and 14th Amendments to the United States 25 Constitution. 0217 1 BY MR. KUVIN: 2 Q. Did you have sex with when 3 she was under the age of 14? 4 MR. PIKE: Form. 5 THE WITNESS: I intend to respond to all 6 relevant questions regarding this lawsuit; however, 7 at the present time, my attorneys have counseled me 8 I cannot provide answers to any questions relevant 9 to this lawsuit. I must accept this advice or risk 10 losing my 6th Amendment right to effective 11 representation. Accordingly, I must assert my 12 federal constitutional rights as guaranteed by the 13 5th, 6th and 14th Amendment to the Constitution. 14 BY MR. KUVIN: 15 Q. Did you tell people that was 16 your sex slave? 17 MR. PIKE: Same objection. 18 THE WITNESS: I intend to respond to all 19 relevant questions regarding this lawsuit; however, 20 at the present time, my attorneys have counseled me 21 I cannot provide answers to any questions relevant 22 to this lawsuit. I must accept this advice or risk 23 losing my 6th Amendment right to effective 24 representation. Accordingly, I must assert my 25 federal constitutional rights as guaranteed by the 0218 1 5th, 6th and 14th Amendment to the United States 2 Constitution. Excuse me. 3 MR. KUVIN: This is 19. 4 (Plaintiff's Exhibit No. 19 was marked for 5 identification.) 6 BY MR. KUVIN: 7 Q. I have an FAA registry for a Boeing 727, 8 manufacture year 1969, with -- I'm just looking for the 9 tail number here. I'm sorry, I'm just trying to find 10 the tail number. 11 A. Not a problem. 12 Q. Let's do this, it's a Mode S Code 53106661. 13 I'll show this to your counsel first. 14 Here it is, I'm sorry, Tail No. N908JE. 15 There's no question pending just yet. 16 MR. PIKE: Thank you. 17 Okay. 18 BY MR. KUVIN: 19 Q. Let me show you what we marked as Exhibit 19. 20 I'll give you a minute to take a look at that. 21 A. Okay. 22 Q. What is JA EGE, Inc.? 23 A. I intend to respond to all relevant questions 24 regarding this lawsuit; however, at the present time, my 25 attorneys have counseled me I cannot provide answers to 0219 1 any questions relevant to this lawsuit. I must accept EFTA01158607 2 this advice or risk losing my 6th Amendment right to 3 effective representation. Accordingly, as I've done 4 with most of your questions, I must assert my federal 5 constitutional rights as guaranteed by the 5th, 6th and 6 14th Amendment to the United States Constitution. 7 Q. Mr. Epstein, are you aware that after 8 September 11, 2001 that the Federal Government started 9 tracking all flights of all public and private aircraft? 10 MR. PIKE: Form, relevance. 11 BY MR. KUVIN: 12 Q. Are you aware of that? 13 A. No. 14 Q. Okay. Are you aware that the FAA keeps track 15 of all flights that are made both within the continental 16 US and from the continental US abroad? 17 MR. PIKE: Same objection. 18 THE WITNESS: No. 19 BY MR. KUVIN: 20 Q. Do you know whether or not -- let me ask it 21 this way: Have you ever seen the flight tracking 22 information for any planes that you may own? 23 A. I don't believe so. 24 Q. Is JEGE, Inc. a company that is owned by you? 25 A. I'll have to answer that question the way I've 0220 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 0221 1 Q. Isn't is true, sir, that you flew to Thailand 2 in 2001? 3 MR. PIKE: Form. 4 THE WITNESS: I intend to respond to all 5 relevant questions regarding this lawsuit; however, 6 at the present time, my attorneys have counseled me 7 I cannot provide answers to any questions relevant 8 to this lawsuit. I must accept this advice or risk 9 losing my 6th Amendment right to effective 10 representation. Accordingly, I assert my federal 11 constitutional rights as guaranteed by the 5th, 6th 12 and 14th Amendment to the United States answered most of your other questions here today, which is, I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. Q. The plane that is identified in the FAA registry in the document marked Exhibit 19, just so we're clear, because I don't think I asked it exactly, but is this your plane? A. I'm going to answer that question the same way I've answered most of your questions today, Mr. Kuvin, which is, I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. EFTA01158608 13 14 BY 15 16 with 17 18 19 20 21 22 23 24 25 0222 1 federal constitutional rights as guaranteed by the 2 5th, 6th and 14th Amendment to the United States 3 Constitution. 4 BY MR. KUVIN: 5 Q. Isn't it true that you went to Thailand in 6 2001 so that you could engage in sexual relations with 7 girls under the age of 16 with Prince Andrew without any 8 fear of any legal recourse? 9 MR. PIKE: Same objection. In addition, 10 improper hypothetical, lack of predicate, 11 foundation, argumentative, harassing. 12 THE WITNESS: I intend to respond to all 13 relevant questions regarding this lawsuit; however, 14 at the present time, my attorneys have counseled me 15 I cannot provide answers to any questions relevant 16 to this lawsuit. I must accept this advice or risk 17 losing my 6th Amendment right to effective 18 representation. Accordingly, I must assert my 19 federal constitutional rights as guaranteed by the 20 5th, 6th and 14th Amendment to the United States 21 Constitution. 22 BY MR. KUVIN: 23 Q. Have you seen the photographs of you and 24 Prince Andrew while you were in Thailand with half naked 25 women, some of which were under the age of 16? 0223 1 MR. PIKE: Same objections. 2 THE WITNESS: I intend -- 3 MR. PIKE: Relevance as well, excuse me. I'm 4 sorry. 5 THE WITNESS: I intend to respond to all 6 relevant questions regarding this lawsuit; however, 7 at the present time, my attorneys have counseled me 8 I cannot provide answers to any questions relevant 9 to this lawsuit. I must accept this advice or risk 10 losing my 6th Amendment right to effective 11 representation. Accordingly, I assert my federal 12 constitutional rights as guaranteed by the 5th, 6th 13 and 14th Amendments to the United States 14 Constitution. 15 BY MR. KUVIN: 16 Q. Did you bring any young women on the plane 17 with you when you went to Thailand in 2001? 18 MR. PIKE: Same objection. 19 THE WITNESS: I intend to respond to all 20 relevant questions regarding this lawsuit; however, 21 at the present time, my attorneys have counseled me 22 I cannot provide answers to any questions relevant 23 to this lawsuit. I must accept this advice or risk Constitution. MR. KUVIN: Q. Is it true that you went to Thailand in 2001 Prince Andrew? MR. PIKE: Form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit, and as I've done for most of all your questions today, Mr. Kuvin, I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my EFTA01158609 24 losing my 6th Amendment right to effective 25 representation. Accordingly, I assert my federal 0224 1 constitutional rights as guaranteed by the 5th, 6th 2 and 14th Amendments to the United States 3 Constitution. 4 BY MR. KUVIN: 5 Q. Have you bragged to people before that you 6 bought -- brought to the United States 7 to be your Yugoslavian sex slave? 8 A. I intend to respond to all relevant questions 9 regarding this lawsuit; however, at the present time, my 10 attorneys have counseled me I cannot provide answers to 11 any questions relevant to this lawsuit. I must accept 12 their advice or risk losing my 6th Amendment right to 13 effective representation. Accordingly, I must assert my 14 federal constitutional rights as guaranteed by the 5th, 15 6th and 14th Amendments to the United States 16 Constitution. 17 Q. Have you had -- 18 MR. GOLDBERGER: You raised the same objection 19 to that question, right? 20 MR. PIKE: Yeah, I did. 21 BY MR. KUVIN: 22 Q. Have you had sex with numerous girls under the 23 age of 18 in the presence of 24 MR. PIKE: Same objections. 25 THE WITNESS: I'm going to answer that the 0225 1 same way I've answered most of your questions here 2 today, Mr. Kuvin, which is, I intend to respond to 3 all relevant questions regarding this lawsuit; 4 however, at the present time, my attorneys have 5 counseled me I cannot provide answers to any 6 questions relevant to the lawsuit. I must accept 7 their advice or risk losing my 6th Amendment right 8 to effective representation. Accordingly, I assert 9 my federal constitutional rights as guaranteed by 10 the 5th, 6th and 14th Amendments to the United 11 States Constitution. 12 BY MR. KUVIN: 13 Q. What is MC2? 14 MR. PIKE: Same objection. 15 THE WITNESS: I don't understand the question. 16 BY MR. KUVIN: 17 Q. MC and then a number 2, what is that? 18 MR. PIKE: Lack of predicate, foundation. 19 THE WITNESS: What is that? 20 MR. PIKE: Irrelevant. 21 BY MR. KUVIN: 22 Q. Do you know what it is? 23 A. No. 24 Q. You've never heard of that before? 25 A. MC2? 0226 1 Q. Yeah. Capital M, capital C, number 2; sound 2 familiar at all? 3 A. No. 4 Q. Okay. Are you part owner in a teen modeling 5 agency? 6 A. No. 7 Q. Do you own any interest in any modeling 8 agencies currently? EFTA01158610 9 A. I intend to respond to all relevant questions 10 regarding this lawsuit; however, at the present time, my 11 attorneys have counseled me I cannot provide answers to 12 any questions relevant to this lawsuit. I must accept 13 this advice or risk losing my 6th Amendment right to 14 effective representation. Accordingly, I assert my 15 federal constitutional rights as guaranteed by the 5th, 16 6th and 14th Amendments to the United States 17 Constitution. 18 Q. Do you know what a sexual device called a Twin 19 Torpedo is? 20 MR. PIKE: Same objections, irrelevant as 21 worded. 22 THE WITNESS: Would you like to ask me a bunch 23 of questions or are we going to -- do you want to 24 individual answers to these? Do you want a 25 compound question? 0227 1 BY MR. KUVIN: 2 Q. I can do it that way, it doesn't matter to me. 3 THE WITNESS: It's up to you. 4 MR. KUVIN: It's up to you guys. 5 MR. PIKE: As I've said, Mr. Kuvin, if you 6 want to limit the time that we spend here today and 7 ask a compound question if you're going to list 8 various items or list individuals by name and ask 9 questions, I won't have a compound objection to 10 that type of inquiry if it's in light of attempting 11 to save time. 12 MR. KUVIN: Sure. 13 BY MR. KUVIN: 14 Q. All righty. 15 MR. PIKE: But that's limited to the compound 16 objection. 17 MR. KUVIN: Oh, no, that's fine. 18 BY MR. KUVIN: 19 Q. All right. Did you purchase something called 20 a Twin Torpedo, a soap made in the shape of a penis, and 21 a soap in the shape of a vagina? 22 A. I'm going to answer that question like I've 23 answered most of your questions here today, which is, I 24 intend to respond to all relevant questions regarding 25 this lawsuit; however, at the present time, my attorneys 0228 1 have counseled me that I cannot provide answers to any 2 questions relevant to this lawsuit. I must accept this 3 advice or risk losing my 6th Amendment right to 4 effective representation. Accordingly, I assert my 5 federal constitutional rights as guaranteed by the 5th, 6 6th and 14th Amendment to the United States 7 Constitution. 8 MR. PIKE: Additionally, just for the Court's 9 record, you're questioning the witness on Exhibit 10 No. what? 11 MR. KUVIN: It's not an exhibit. It's the 12 Town of Palm Beach Incident Report with respect to 13 Jeffrey Epstein, of which I gave you a copy before. 14 And that was referencing, just so the record is 15 clear, page 46. 16 MR. PIKE: Then I would add additional 17 privileges and objections in addition to what 18 Mr. Epstein has already raised underneath Florida 19 Rule of Criminal Procedure 3.220 and work product. EFTA01158611 20 Not necessarily the document in front of you, but 21 the questions and the answer you're attempting to 22 elicit. 23 BY MR. KUVIN: 24 Q. Whose mobile wireless number is ? 25 A. I intend to respond to all relevant questions 0229 1 regarding this lawsuit; however, at the present time, my 2 attorneys have counseled me I cannot provide answers to 3 any questions relevant to this lawsuit. I must accept 4 this advice or risk losing my 6th Amendment right to 5 effective representation. Accordingly, I hereby assert 6 my federal constitutional rights as guaranteed by the 7 5th, 6th and 14th Amendments to the United States 8 Constitution. 9 Q. I'm going to read you, for speed's sake, three 10 separate phone numbers, and it's the same question for 11 each. Do you recognize the following phone numbers? 12 They all have Area Code III. The first one is . 13 the second is , and the third is . 14 A. I intend to respond to all relevant questions 15 regarding this lawsuit; however, at the present time, my 16 attorneys have counseled me I cannot provide answers to 17 any questions relevant to this lawsuit. I must accept 18 this advice or risk losing my 6th Amendment right to 19 effective representation. Accordingly, I must assert my 20 federal constitutional rights as guaranteed by the 5th, 21 6th and 14th Amendments to the United States 22 Constitution. 23 Q. Did have the phone number 24 or or III -- I'm sorry, same number 25 again. So two numbers: Either or ? 0230 1 A. I intend to respond to all relevant questions 2 regarding this lawsuit; however, at the present time, my 3 attorneys have counseled me I cannot provide answers to 4 any questions relevant to the lawsuit. I must accept 5 this advice or risk losing my 6th Amendment right to 6 effective representation. Accordingly, I must assert my 7 federal constitutional rights as guaranteed by the 5th, 8 6th and 14th Amendments to the Constitution. 9 Q. Do you have an egg-shaped penis? 10 A. I intend to respond to all relevant questions 11 regarding this lawsuit; however, at the present time, my 12 attorneys have counseled me I cannot provide answers to 13 any questions that may be relevant to this lawsuit. I 14 must accept this advice or risk losing my 6th Amendment 15 right to effective representation. Accordingly, I must 16 assert my federal constitutional rights as guaranteed by 17 the 5th, 6th and 14th Amendment to the United States 18 Constitution. 19 Q. Do you have any identifying marks on your 20 penis? 21 A. I intend to respond to all relevant questions 22 regarding this lawsuit; however, at the present time, my 23 attorneys have counseled me I cannot provide answers to 24 any questions relevant to the lawsuit. I must accept 25 their advice or risk losing my 6th Amendment right to 0231 1 effective representation. Accordingly, I hereby assert 2 my federal constitutional rights as guaranteed by the 3 5th, 6th and 14th Amendments to the United States 4 Constitution. EFTA01158612 5 6 7 8 9 10 11 12 BY 13 14 15 16 17 18 19 20 21 22 23 24 25 0232 1 BY MR. KUVIN: 2 Q. Did you ever utilize Dollar-Rent-a-Car to rent 3 cars while you were here in Palm Beach at any time? 4 A. I intend to respond to all relevant questions, 5 Mr. Kuvin, regarding this lawsuit; however, at the 6 present time, my attorneys have counseled me I cannot 7 provide answers to any questions that may prove relevant 8 to this lawsuit. I must accept this advice or risk 9 losing my 6th Amendment right to effective 10 representation. Accordingly, I must assert my federal 11 constitutional rights as guaranteed by the 5th, 6th and 12 14th Amendment to the United States Constitution. 13 Q. What was your personal cell phone carrier back 14 in 2004? 15 A. I intend to respond to all relevant questions 16 regarding this lawsuit. 17 Q. Let me make this quicker. I'm sorry for 18 interrupting you, I apologize. Let's say, what was your 19 cell phone carrier back from 2004 through 2006. 20 MR. PIKE: And I'm not objecting to compound; 21 however, there are various allegations in your 22 complaint regarding a time frame. So therefore, 23 with regard to the allegations in your complaint, 24 relative to your question, I'm not objecting to the 25 compound, I'm saying it's overbroad. 0233 1 MR. KUVIN: 2004 to 2006? 2 MR. PIKE: Overbroad and irrelevant based upon 3 the allegations that you've alleged. 4 MR. KUVIN: All right. Well, let me clarify 5 the question then. 6 BY MR. KUVIN: 7 Q. What was your cell phone carrier from 2004 to 8 2005? 9 MR. PIKE: Same objections. 10 BY MR. KUVIN: 11 Q. Well, let me try and fix it again. What was 12 your cell phone carrier from 2005 to 2006? 13 MR. PIKE: Relevance. 14 THE WITNESS: I intend to respond to all 15 relevant questions regarding this lawsuit; however, MR. PIKE: In addition, same objection and privilege which regard to the Florida Rule of Procedure 3.220 and work product. Not necessarily the document you're talking or speaking from, but the testimony. MR. KUVIN: I was just reading this. I wasn't asking questions from this at the moment. MR. KUVIN: Q. Does your penis have any deformities? MR. PIKE: Form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers the any questions relevant to the lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the Constitution, as I've done with most of your questions here today. EFTA01158613 16 at the present time, my attorneys have counseled me 17 I cannot provide answers to any questions relevant 18 to this lawsuit. I must accept their advice or 19 risk losing my 6th Amendment right to effective 20 representation; therefore, I must assert my federal 21 constitutional rights as guaranteed by the 5th, 6th 22 and 14th Amendments to the United States 23 Constitution. 24 BY MR. KUVIN: 25 Q. What were the cell phone carriers of or Ghislaine Maxwell from the 2 years 2005 to 2006? 3 MR. PIKE: Relevance. 4 THE WITNESS: I intend to respond to all 5 relevant questions regarding this lawsuit. As I've 6 answered most of your questions the same way today, 7 Mr. Kuvin, at the present time, my attorneys have 8 counseled me I cannot provide answers to any of 9 your questions that may be relevant to this 10 lawsuit. I must accept this advice or risk losing 11 my 6th Amendment right to effective representation. 12 Therefore, accordingly, I assert my federal 13 constitutional rights as guaranteed by the 5th, 6th 14 and 14th Amendment to the United States 15 Constitution. 16 May we take a break, please? 17 MR. KUVIN: Sure. 18 MR. PIKE: Yes. 19 MR. GOLDBERGER: Yes. 20 THE VIDEOGRAPHER: Going off the record at 21 3:21. 22 (A brief recess was taken.) 23 THE VIDEOGRAPHER: We're back on the record at 24 3:30. 25 0235 1 BY MR. KUVIN: 2 Q. Here, let me move this out of the way. 3 A. You can take your Joy Jelly home now. 4 Q. It's actually an exhibit to your deposition. 5 A. Sorry. 6 Q. Have you read the police department's, the 7 Palm Beach Police Department's, probable cause 8 affidavit? Have you ever read it? 9 MR. PIKE: Attorney-client, work privilege. 10 BY MR. KUVIN: 11 Q. Have you ever read the police department, Palm 12 Beach Police Department's incident report regarding you? 13 MR. PIKE: Same objection. 14 MR. GOLDBERGER: Same objection. 15 MR. PIKE: And instruction, I'm sorry. 16 BY MR. KUVIN: 17 Q. Are you circumcised? 18 MR. PIKE: Objection, relevance. 19 THE WITNESS: I intend to respond to all 20 relevant questions regarding this lawsuit; however, 21 at the present time, my attorneys have counseled me 22 I cannot provide answers to any questions relevant 23 to this lawsuit. I must accept this advice or risk 24 losing my 6th Amendment right to effective 25 representation. Accordingly, I assert my federal 0236 EFTA01158614 1 constitutional rights as guaranteed by the 5th, 6th 2 and 14th Amendments to the United States 3 Constitution. 4 BY MR. KUVIN: 5 Q. Was a search warrant performed and executed at 6 your home on Palm Beach Island? 7 MR. GOLDBERGER: Attorney-client, work 8 privilege. 9 I'll instruct you not to answer. 10 BY MR. KUVIN: 11 Q. Do you know spelled , 12 ; Daniel Estes, spelled E-S-T-E-S; or Douglas 13 Schoettle, S-C-H-O-E-T-T-L-E? 14 A. I intend to respond to all relevant questions 15 regarding this lawsuit; however, at the present time, my 16 attorneys have counseled me I cannot provide answers to 17 any questions relevant to this lawsuit. And as I've 18 answered most of your questions today, Mr. Kuvin, I must 19 accept this advice and risk losing -- or risk losing my 20 6th Amendment right to effective representation. 21 Accordingly, I assert my federal constitutional rights 22 as guaranteed by the 5th, 6th and 14th Amendments to the 23 United States Constitution. 24 Q. Did you have a chef working for you at your 25 Palm Beach home back in 2005? 0237 1 A. I intend to respond to all relevant questions 2 regarding this lawsuit; however, at the present time, my 3 attorneys have counseled me I cannot provide answers to 4 any questions relevant to this lawsuit at this time. I 5 must accept their advice or risk losing my 6th Amendment 6 right to effective representation. Accordingly, I must 7 assert my federal constitutional rights as guaranteed by 8 the 5th, 6th and 14th Amendment to the United States 9 Constitution. 10 MR. PIKE: Additionally, predicate and 11 foundation. 12 BY MR. KUVIN: 13 Q. Did you own or do you currently own a 2004 14 black Chevy Suburban, bearing Florida tag X99-EGL? 15 A. I intend to respond to all relevant questions 16 regarding this lawsuit; however, at the present time, my 17 attorneys have counseled me I cannot provide answers to 18 any questions that may be relevant to the lawsuit. I 19 must accept their advice or risk losing my 6th Amendment 20 right to effective representation; therefore, I assert 21 my federal constitutional rights as guaranteed by the 22 5th, 6th and 14th Amendment to the United States 23 Constitution. 24 Q. I think I asked this before, and I apologize 25 if I did, but your date of birth is January 20, 1953, 0238 1 correct? 2 A. You asked that before. 3 Yes, correct. 4 Q. Okay, I'm sorry. 5 Do you own a -- or did you own -- let me 6 clarify. 7 A. Do you want to do compound again? 8 Q. Yeah. Did you or do you currently own a 2005 9 black Cadillac Escalade ESV, bearing Florida license tag 10 Q29-9GT? 11 A. I intend to respond to all relevant questions EFTA01158615 12 regarding this lawsuit; however, at the present time, my 13 attorneys have counseled me I cannot provide answers to 14 any questions that may be relevant to the lawsuit. I 15 must accept their advice or risk losing my 6th Amendment 16 right to effective representation. Accordingly, I 17 assert my federal constitutional rights as guaranteed by 18 the 5th, 6th and 14th Amendment to the United States 19 Constitution. 20 Q. Have you hired attorneys for either 21 , Ghislaine Maxwell, or any 22 other -- 23 MR. GOLDBERGER: Attorney-client, work 24 product. 25 Are you done? I'm sorry. 0239 1 BY MR. KUVIN: 2 Q. -- or any other women in this case? 3 MR. GOLDBERGER: Okay. Now attorney-client, 4 work product. 5 I direct you not to answer. 6 BY MR. KUVIN: 7 Q. Do you know the name of the girl that was with 8 l'i. when she was brought to your home? 9 MR. PIKE: Form, lack of predicate, 10 foundation. 11 THE WITNESS: Like I've done to many of your 12 other questions and responded to many of your other 13 questions today, Mr. Kuvin, that question -- I must 14 answer that, I intend to answer all relevant 15 questions regarding this lawsuit; however, at the 16 present time, my attorneys have counseled me I 17 cannot provide answers to any questions that may be 18 relevant. I must accept this advice or risk losing 19 my 6th Amendment right to effective representation; 20 therefore, I assert my federal constitutional 21 rights as guaranteed by the 5th, 6th and 14th 22 Amendment to the Constitution. 23 BY MR. KUVIN: 24 Q. Did you, in fact, give III. $200 for a -- for 25 her to get naked and give you a massage while you were 0240 1 naked and, in addition, touch her in her vagina without 2 her permission in 2005? 3 MR. PIKE: Predicate, foundation -- 4 THE WITNESS: I believe that's been asked and 5 answered. 6 MR. PIKE: Harassing. And I believe as 7 worded, that question has been asked and answered 8 in sub parts. I believe you've asked those 9 questions initially at the beginning of this 10 deposition. The same objections would, therefore, 11 apply and be incorporated. 12 MR. KUVIN: I disagree, but... 13 THE WITNESS: Like most of your other 14 questions here today, I intend to respond to all 15 relevant questions regarding this lawsuit; however, 16 at the present time, my attorneys have counseled me 17 I cannot provide answers to any questions that may 18 be relevant. I must accept this advice or risk 19 losing my 6th Amendment privilege. Accordingly, I 20 assert my federal constitutional rights as 21 guaranteed by the 5th, 6th and 14th Amendment to 22 the US Constitution. EFTA01158616 23 BY MR. KUVIN: 24 Q. Do you agree, sir, that your conduct, with 25 respect to caused her severe emotional distress? 0241 1 MR. PIKE: Same objection. In addition, it's 2 argumentative, harassing and calls for a 3 conclusion. 4 THE WITNESS: I'm going to have to answer that 5 the same way I've answered most of your questions 6 today, Mr. Kuvin, which is, I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to the lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I must assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment. BY MR. KUVIN: Q. Do you have gray chest hair? A. I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any of those questions that may be relevant. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0242 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 0243 Q. Have you told young ladies -- girls under the age of 18, when they came to your house and got naked to give you a massage, quote, the more you do, the more you get paid? MR. PIKE: Objection, form, predicate, foundation, improper hypothetical and assumes facts not in evidence, relevance. THE WITNESS: Like most of your questions, Mr. Kuvin, today, I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. BY MR. KUVIN: Q. Do you have any tattoos? A. I intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my 6th Amendment right to 1 effective representation. Accordingly, I must assert my 2 federal constitutional rights as guaranteed by the 5th, 3 6th and 14th Amendments to the United States 4 Constitution. 5 Q. Do you have a steam room in your home on Palm 6 Beach Island? 7 MR. PIKE: Same objections. EFTA01158617 8 THE WITNESS: I'm going to answer that 9 question the same way I've answered most of your 10 questions here today, which is, I intend to respond 11 to all relevant questions regarding this lawsuit; 12 however, at the present time, my attorneys have 13 counseled me that I cannot provide answers to any 14 questions relevant to the lawsuit. I must accept 15 this advice or risk losing my 6th Amendment right 16 to effective representation. Accordingly, I must 17 assert my constitutional rights as guaranteed by 18 the 5th -- 5th, 6th and 14th Amendments to the 19 United States Constitution. 20 BY MR. KUVIN: 21 Q. Did you provide payments to underaged girls by 22 utilizing cash and wire transfers through Western Union 23 in 2004 or 2005? 24 MR. PIKE: Same objections as raised to the 25 previous last three questions incorporated here. 0244 1 THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit; however, 3 at the present time, my attorneys have counseled me 4 I cannot provide answers to any questions relevant 5 to the lawsuit. I must accept this advice or risk 6 losing my 6th Amendment right to effective 7 representation. Accordingly, I assert my federal 8 constitutional rights as guaranteed by the 5th, 6th 9 and 14th Amendment to the United States 10 Constitution. 11 BY MR. KUVIN: 12 Q. Did you -- excuse me. Did you take any 13 videotapes of girls that were under the age of 18 in 14 your home on Palm Beach Island? 15 MR. PIKE: Same objections incorporated. 16 THE WITNESS: As I have with most of your 17 questions today, I'm going to have to answer that, 18 I intend to respond to all relevant questions 19 regarding this lawsuit; however, at the present 20 time, my attorneys have counseled me I cannot 21 provide answers to any questions that may be 22 relevant to this lawsuit. I must accept this 23 advice or risk losing my 6th Amendment right to 24 effective representation. Accordingly, I assert my 25 federal constitutional rights as guaranteed by the 0245 1 5th, 6th and 14th Amendment to the United States 2 Constitution. 3 BY MR. KUVIN: 4 Q. Have you ever provided a dozen roses to a 5 young girl under the age of 18 who came to your house to 6 give you a massage? 7 MR. PIKE: Form, vague, ambiguous, assumes 8 facts not in evidence. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit; however, 11 at the present time, my attorneys have counseled me 12 that I cannot provide answers to any questions that 13 may be relevant. I must accept their advice or 14 risk losing my 6th Amendment right to effective 15 representation. Accordingly, I must assert my 16 federal constitutional rights as guaranteed by the 17 5th, 6th and 14th Amendment. 18 BY MR. KUVIN: EFTA01158618 19 Q. Did you ever instruct anyone to deliver a 20 bucket of roses after a high school drama performance to 21 an underaged girl? 22 MR. PIKE: Same objection. In addition, lacks 23 predicate and foundation. It's overbroad as well. 24 THE WITNESS: I fully intend to respond to all 25 relevant questions regarding this lawsuit; however, 0246 1 at the present time, my attorneys have counseled me 2 that I cannot provide answers to any questions 3 relevant to the lawsuit. I must accept their 4 advice or risk losing my 6th Amendment right to 5 effective representation. Accordingly, I assert my 6 federal constitutional rights as guaranteed by the 7 5th, 6th and 14th Amendment to the United States 8 Constitution. 9 BY MR. KUVIN: 10 Q. Hold on a second. I may be done. 11 Do you know a Dr. Kaku, K-A-K-U? 12 A. I intend to respond to all relevant questions 13 regarding this lawsuit; however, at the present time, my 14 attorneys have counseled me I cannot provide answers to 15 any questions that may be relevant. I must accept this 16 advice or risk losing my 6th right to effective 17 representation. Accordingly, I assert my federal 18 constitutional rights as guaranteed by the 5th, 6th and 19 14th Amendment to the United States Constitution. 20 MR. PIKE: Can you hold on one second? 21 MR. KUVIN: I'm almost done. 22 MR. PIKE: No, no. We're not going anywhere. 23 MR. KUVIN: Okay. 24 MR. PIKE: Okay. 25 0247 1 MR. KUVIN: Okay. All right, I appreciate 2 your patience. That's all the questions that I 3 have right now. I know that Mr. Goldberger needs 4 to deal with an issue right now with Ms. Ezell 5 regarding any further questions. 6 MR. GOLDBERGER: I think we clarified that. 7 Ms. Ezell, are you there? 8 MS. EZELL: I'm here. 9 MR. GOLDBERGER: Yeah. You had a discussion 10 with Bob Critton already concerning the question 11 you raised with me earlier, right? 12 MS. EZELL: Yes, I did, and I don't have any 13 questions. 14 MR. PIKE: Ms. Ezell, this is Michael Pike. I 15 don't know what your conversation was with Bob, but 16 did you cross notice this deposition? 17 MS. EZELL: No, I did not. 18 MR. PIKE: So what is your purpose of being 19 here? 20 My position is that these are closed 21 proceedings and your client, your client did not 22 cross notice this deposition and/or your clients. 23 So what is your purpose of sitting in on this 24 deposition? 25 MS. EZELL: Well, I received a notice of it, 0248 1 and I just thought I would listen to it while I was 2 doing some other work. And I don't know why it 3 would be a closed proceeding. EFTA01158619 4 MR. PIKE: Discovery proceedings are closed if 5 it's a pre-trial discovery, ma'am, it's not a court 6 proceeding. 7 Nonetheless, do you have any questions for the 8 witness? 9 MS. EZELL: No, I don't. 10 MR. PIKE: And Ms. Holmes, who are you here on 11 behalf of? Which clients? 12 MS. HOLMES: III. and III. 13 MR. PIKE: Are you also here on behalf of Jane 14 Doe in the case 80893? 15 MS. HOLMES: I believe so, yes. 16 MR. PIKE: Do you have any questions for the 17 witness? 18 MS. HOLMES: No, I do not. 19 MR. GOLDBERGER: Katherine, we're going to 20 end. Do you want me to disconnect you now? 21 MS. EZELL: Yes, thanks. 22 MR. GOLDBERGER: Okay. 23 THE VIDEOGRAPHER: Conclude the deposition and 24 go off the record at 3:00 -- 25 MR. PIKE: Wait one second. 0249 1 MR. KUVIN: Oh, wait. 2 MR. GOLDBERGER: He's just going to read. 3 MR. PIKE: You didn't give the witness a 4 chance to read or waive and he'll read. 5 THE VIDEOGRAPHER: Conclude the deposition and 6 go off the record at 3:48. This will be the end of 7 tape No. 3. 8 9 (Witness excused.) 10 (Deposition was concluded.) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0250 1 CERTIFICATE OF OATH 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 6 I, the undersigned authority, certify that 7 JEFFREY EPSTEIN personally appeared before me and was 8 duly sworn on the 8th day of October, 2009. 9 10 Dated this 8th day of October, 2009. 11 12 13 14 EFTA01158620 15 Jeana Ricciuti, RPR, FPR, CLR 16 Notary Public - State of Florida My Commission Expires: 2/17/2013 17 My Commission No.: DD 854778 18 19 20 21 22 23 24 25 0251 1 CERTIFICATE 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 I, Jeana Ricciuti, Registered Professional Reporter and Notary Public in and for the State of 6 Florida at large, do hereby certify that I was authorized to and did report said deposition in 7 stenotype; and that the foregoing pages are a true and correct transcription of my shorthand notes of said 8 deposition. 9 I further certify that said deposition was taken at the time and place hereinabove set forth and 10 that the taking of said deposition was commenced and completed as hereinabove set out. 11 I further certify that I am not attorney or 12 counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected 13 with the action, nor am I financially interested in the action. 14 The foregoing certification of this transcript 15 does not apply to any reproduction of the same by any means unless under the direct control and/or direction 16 of the certifying reporter. 17 Dated this 8th day of October, 2009. 18 19 20 21 Jeana Ricciuti, RPR, FPR, CLR 22 23 24 25 0252 1 DATE: October 22, 2009 2 TO: JEFFREY EPSTEIN c/o Michael J. Pike 3 BURMAN, CRITTON, LUTTIER & COLEMAN, P.A. 303 Banyan Boulevard 4 Suite 400 West Palm Beach, Florida 33401 5 IN RE: 'gm. v. EPSTEIN 6 Please take notice that on Thursday, the 8th EFTA01158621 7 of October, 2009, you gave your deposition in the above-referred matter. At that time, you did not waive 8 signature. It is now necessary that you sign your deposition. 9 As previously agreed to, the transcript will be furnished to you through your counsel. Please read 10 the following instructions carefully: At the end of the transcript you will find an 11 errata sheet. As you read your deposition, any changes or corrections that you wish to make should be noted on 12 the errata sheet, citing page and line number of said change. DO NOT write on the transcript itself. Once 13 you have read the transcript and noted any changes, be sure to sign and date the errata sheet and return these 14 pages to me. If you do not read and sign the deposition 15 within a reasonable time (i.e., 30 days unless otherwise directed) the original, which has already been forwarded 16 to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your signature, sign 17 your name in the blank at the bottom of this letter and return it to us. 18 Very truly yours, 19 20 Jeana Ricciuti, RPR, FPR, CLR 21 Prose Court Reporting Agency, INC. 250 S. Australian Avenue, Ste 1500 22 West Palm Beach, Florida 33401 23 I do hereby waive my signature. 24 25 JEFFREY EPSTEIN 0253 1 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the 6 foregoing deposition by me given, and that the 7 statements contained herein are true and correct to the 8 best of my knowledge and belief, with the exception of 9 any corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2009. 14 15 16 17 18 19 JEFFREY EPSTEIN 20 21 22 23 24 25 0254 1 ERRATA SHEET 2 IN RE: Ili. v. EPSTEIN CR: JEANA RICCIUTI EFTA01158622 3 DEPOSITION OF: JEFFREY EPSTEIN 4 TAKEN: October 8, 2009 5 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 6 PAGE # LINE # CHANGE REASON 7 8 9 10 11 12 13 14 15 16 17 Please forward the original signed errata sheet to this office so that copies may be distributed to all parties. 18 Under penalty of perjury, I declare that I have read my 19 deposition and that it is true and correct subject to any changes in form or substance entered here. 20 21 22 23 24 25 DATE: SIGNATURE OF DEPONENT: EFTA01158623