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Page 1 Page 3 UNITED STATES DISTRICT COURT 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT SOUTHERN DISTRICT OF FLORIDA 2 IN AND FOR PALM BEACH COUNTY. FLORIDA CASE NO. 502008CA028051 XXXXMB AB CASE NO. 08-CIV-801 19-MARRA/JOHNSON 3 4 JANE DOE NO. 2. Plaintiff. 5 . Plaintiff. -vs- VOLUME I OF III 6 -vs- VOLUME I OF III JEFFREY EPSTEIN. 7 JEFFREY EPSTEIN. Defendant 8 Defendant. I I 9 Related eases: 10 08-80232. 08-08380. 08-80381. 08-80994 11 08-80993. 08-8081 1. 08-80893. 0940469 12 VIDE TAPED DEPOSITION OF 09.80591. 09-80656. 09-80802. 09-81092 r 13 14 VII SMON OF 15 Wednesday. March 24.2010 MMI 10:37 - 6:51 p.m. 16 Wednesday. March 24. 2010 17 10:37 - 6:51 p.m. 18 250 Australian Avenue South Suite 1500 250 Australian Avenue South 19 West Palm Beach. Florida 33401 Suite 1500 20 West Palm Beach. Florida 33401 21 22 Reported By: Reported By: Cynthia Hopkins. RPR. FPR Cynthia Hopkins. RPR. FPR 23 Notary Public. State of Florida Notary Public. State of Florida Prose Court Reporting Services Prose Court Reporting Services 24 Job No.: 1484 Job No.: 1484 25 Page 2 Page 4 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 1 DI THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL IN AND FOR PALM BEACH COUNTY. FLORIDA CIRCUIT IN AND FOR PALM BEACH COUNTY. FLORIDA 2 CASE NO. 502008CA028058XXXXMB AD 2 CASE No302008CA037319XXXXMB AB 3 3 M. 4 5 Plaintiff. Plaintiff. 6 -vs- VOLUME I OF III 5 7 VOLUME I OF III 8 JEFFREY EPSTEIN. J AN EFISISI, Defendant. 8 9 / Defendants. 10 9 11 VI SITION OF 10 12 13 11 12 VItSITION OF 14 Wednesday. March 24. 2010 13 10:37 - 6:51 p.m. 14 Wednesday. March 24. 2010 15 10:37 - 6:51 p.m. 16 15 17 250 Australian Avenue South 16 17 250 Australian Avenue South Suite 1500 Suite 1500 18 West Palm Beach. Florida 33401 16 West Palm Beach. Florida 33401 19 19 20 20 21 21 22 Repotted By: 22 Repotted By: Cynthia Hopkins. RPR. FPR Cynthia Hopkins. RPR. FPR 23 Notary Public. State of Florida 23 Notary Public. State of Florida Prose Court Reporting Services Prose Court Reporting Services 24 Job No.: 1484 24 Job No.: 1484 25 25 1 (Pages 1 to 4) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 1 of 47 EFTA_00065318 EFTA01246464 Page 5 Page 7 APPEARANCES: 1 2 On behalf of the Plaintiffs. : 2 INDEX SPENCER T. KUVIN. ESQUIRE 3 LEOPOLD KUVIN 4 2925 PGA Boulevard 5 EXAMINATION DIRECT CROSS REDIRECT' 5 Suite 201) Palm Beach Garden. Florida 33410 6 Phone: 6 7 7 On behalf of the Plandiffs...... and BY MR. KUVIN 9 Jane Doe: a 8 9 9 MATTHEW WEISSING. ESQUIRE 10 EXHIBITS 10 FARMERJAFTE MUSSING. EDWARDS FISTOS & LBIRNIAN.P.L 11 12 _ _ _ 425 North Andimvx Avenue 13 EXHIBIT DESCRIPTION PAGE 11 Suite 2 14 Fort Lauderdale Florida 33301 PLAINTIFFS EX. 1 PHOTO 16 12 13 Phone: On behalf of Jane Does I throu5h K: 15 PLAINTIFFS EL 2 MOE INC.. 24 14 ADAM D. HOROWITZ- ESQUIRE PASSENGER MANIFEST' MERNIEI-STEIN it HOROWITZ. P.A. 16 PLAINTIFFS EX. 3 HYPERION AIR. INC.. 15 18205 Biscayne Boulevard PASSENGER MANIFEST Suite 22114 17 PLAINTIFFS EX. 6 PHOTO 63 16 Miami. a t i PLAINTIFFS EL 7 PHOTO 65 Phone: 18 PLAINTIFFS EX. 8 PHOTO 68 17 E-mail: PLAINTIFFS EX. 9 PHOTO 71 16 On behalf of the PI:midis. 101. 102 and 103: 19 PLAINTIFFS EL 10 PHOTO 100 19 KATHERINE W. EZELI- ESQUIRE PLAINTIFFS EL 11 PHOTO 101 AMY JOSEFSBERG EDERI. ESQUIRE 20 PLAINTIFFS EL 12 PHOTO 103 20 PODHURST ORSECK 25 wear Flatlet Street PLAINTIFFS EX. 4 PHONE MESSAGE PADS 21 Suite WO 21 PLAINTIFFS EL 5 CELLPHONE RECORDS 22 Miami.iiiiiiiiii Phone: 22 PLAINTIFFS EL 13 PHOTO 144 23 1Via telephoner 23 24 24 25 25 Page 6 Page 8 1 Appearances continued... 1 PROCEEDINGS 2 On behalf of the Plaintiff. Jane Doe ll: 3 ISIDRO MANUEL GARCIA. ESQUIRE 2 — — — GARCIA. ELKINS & BOEHRINGER 3 THE VIDEOGRAPHER: We are now on video 4 224 Datum Avenue. Suite 900 4 record. This is Media No. 1 in the videotaped 5 West Palm Fl Beach ida 33401 Phone: 5 deposition of in the matter of 6 6 Jane Doe versus Jeffrey Epstein, et al. Today 7 8 On behalf of the Defendant: JACK ALAN GOLDBERGER. ESQUIRE 7 is Wednesday. March 24th. 2010. It is ATTERBURY. GOLDBERGER & WEISS. P.A. 8 10:36 a.m. We are here at Prose Court 9 250 Australian Avenue South 9 Reporting. 250 South Australian Avenue. West Suite 1400 10 West ida 33401-5012 Phony 10 11 Palm Beach. Florida. My name is Joe Kozak. I'm the 11 12 12 videographer. The reporter is Cindy 13 On f h Win • 13 Hopkins from Prose Court Reporting Agency. 1 4 19 Would counsel please introduce 1 5 16 yourselves, and then the court reporter will swear in the witness. 17 MR. KUVIN: Good morning. Spencer Kuvin 17 18 on behalf of one of the Plaintiffs. 18 19 MR. HOROWITZ: Adam Horowitz on behalf of 19 20 ALSO PRESENT: 2 0 Jane Does 2 through 8. And just for the record 21 Jessica Cadwell. Paralegal 21 purposes. the deposition is also being taken in 22 Burman. Critton. Lanier & Coleman. P.A. Joseph Kozak. Videographer 22 the federal cases, I believe, case being Prose Court Reporting Services 2 3 Jane Doe 2 versus Jeffrey Epstein. 23 24 MR. WEISSING: Matt Weissing on behalf of 24 25 25 three of the Plaintiffs. 2 (Pages 5 to 8 PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 2 of 47 EFTA_00065319 EFTA01246465 Page 9 Page 11 1 MR. GARCIA: Sid Garcia for Jane Doe. 1 privilege. 2 Roman Numeral II. 2 MR. KUVIN: I'll agree with that 3 MR. GOLDBERGER: Jack Goldberger on behalf 3 procedure. 4 of Jeffrey Epstein. 4 MR. Anyone object to that 5 MS. CADWELL: Jessica Cadwell. paralegal. 5 procedure? 6 on behalf of Jeffre stein. 6 MR. GOLDBERGER: Actually I think if, in 7 MR. on behalf 7 fact, this deposition is used in a trial, 1 a of the witness. 8 think you would want the lengthier answer as 9 MR. KUVIN: Kathy. your turn. 9 being the answer that is played to the jury. 10 MS. EZELL: Okay. Kathy Ezell and Amy 10 So either you guys can agree that it gets cut 11 Ederi on behalf of Plaintiff, Jane Doe 103. 11 in or she's going to have to -- I can't tell 12 Thereupon. 12 you what to do, but I would suggest that she 13 l l 13 give the lengthier answer each time. 14 Having been first duly sworn or affirmed, was 14 But there's got to be a way that you 15 examined and testified as follows: 15 guys can reach an agreement though, that 16 DIRECT EXAMINATION 16 from a technology perspective, that the 17 BY MR. KUVIN: 17 lengthy answer that she just gave would be 18 Q. Good morning. 18 used during any trial testimony. Can that 19 A. Morning. 19 be done? 20 21 Q. Couldyougive us your full name, please. A. . 20 21 MR. KUVIN: I don't know procedurally whether it can be done. 22 Q. il aiave a middle name? 22 MR. GOLDBERGER: I think -- 23 A. 23 MR. KUVIN: I don't know that, well -- 24 Q. Would ou s II that for us? 24 GOLDBERGER: And again, it's not my, 25 A. 25 MR. ifs not my deal. I'm just telling you how Page 10 Page 12 1 Q. What's our current address? 1 we've done it in the past. 2 MR. I'm going to instruct the 2 MR. KUVIN: I hear you. and I have a 3 witness not to answer that question on the 3 number of issues primary, primarily of which 4 basis of her Fifth and 14th Amendment 4 that you're not here to represent anyone S privileges against self-incrimination. 5 currently. 6 MR. KUVIN: Okay. We had spoken before 6 MR. GOLDBERGER: Yeah. I am. I'm 7 with respect to there are likely going to be 7 actually. I'm actually here representing 8 answers similar to that throughout this 8 Jeffrey Epstein. so... 9 deposition. I have agreed to a procedure that 9 MR. KUVIN: Okay. With respect to all the 10 we can do a shortened answer. However you want 10 civil cases. though. you're not here to 11 to handle that. I leave it up to you. But I do 11 represent anyone, so -- 12 agree that whatever the shortened answer is, 12 MR. GOLDBERGER: Yes. I am. 13 that it will satisfy the length. lengthy answer 13 MR. KUVIN: With the exception -- 14 that she would like to give. 14 MR. GOLDBERGER: I represent -- I am --1 15 So, do we want to do that with this 15 don't mean to interrupt you. but I am counsel 16 question, or how do you want to handle 16 of record in the civil cases. 17 that procedurall ? 17 MR. KUVIN: Oka . Okay. 18 MR. Well. I think I have given 18 MR. If we have a stipulation, 19 the instruction. I think she, will give her 19 what's the problem? Are you -- 20 the same instruction in the future to the 20 MR. KUVIN: There is none. 21 extent that it's relevant, and I think that if 21 MR. -- worried about a waiver? 22 we can all just agree that if she simply says 22 MR. GOLDBERGER: No. I'm not worried abou 23 or I simply say "The Fifth Amendment," that 23 that at all. I'm worried about what is played 24 will qualify as giving a sufficient answer to 24 to a jury if this gets tried. 25 -- a, a matter of law. and will invoke that 25 MR. KUVIN: Okay. And I appreciate you 3 (Pages 9 to 12) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 3 of 47 EFTA_00065320 EFTA01246466 Page 13 Page 15 1 coaching M. but I think he can handle 1 I choose to invoke my Fifth Amendment right. 2 himself pretty adequately now -- 2 BY MR. KUVIN: 3 MR. GOLDBERGER: I have -- 3 Q. Would ou agree with me that you're 4 MR. KUVIN: So I leave it up to -- 4 approximatel 5 MR. GOLDBERGER: I have all the confidence 5 MR. : Same instruction. 6 in . 6 THE WITNESS: On the advice of my lawyer, 7 MR. KUVIN: Mr. with respect to 7 I must invoke my Fifth Amendment right. 8 how you want to handle it. I think we have an 8 BY MR. KUVIN: 9 10 agreement. MR. : I'm satisfied that we have 9 10 Would you agree with me that your eyes are 11 a stipulation, and I assume if there is ever a 11 MR. Same instruction. 12 trial, that would be played or produced to the 12 THE WITNESS: On the advice of my lawyer, 13 jury that simply by using shorthand, what she's 13 I choose to invoke my Fifth Amendment right. 14 really saying is the lengthier answer now. I'm 14 BY MR. KUVIN: 15 satisfied with that. 15 Q. Would you agree with me that you were born 16 MR. KUVIN: And I agree with that. 16 in 17 BY MR. KUVIN: 17 MR. : Same instruction. 18 Q. Okay. Ma'am, what is your current 18 THE WITNESS: On the advice of my lawyer, 19 address? 19 I choose to invoke my Fifth Amendment right. 20 MR. : Again, I will instruct the 20 BY MR. KUVIN: 21 witness not to answer the question. 21 Q. What are the names of your parents? 22 THE WITNESS: On the instruction of my 22 MR. : Same instruction. 23 lawyer. I choose to invoke my Fifth Amendment 23 THE WITNESS: On the advice of my lawyer, 24 right. 24 I must invoke my Fifth Amendment right. 25 25 Page 14 Page 16 1 BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. What is our current phone number? 2 Q. Areyou married or single? 3 MR. : Same instruction. 3 MR. : Same instruction. 4 THE WITNESS: On the advice of my lawyer, 4 THE WITNESS: On the advice of my lawyer, 5 I choose to invoke my Fifth Amendment right. 5 I must to invoke my Fifth Amendment right. 6 BY MR. KUVIN: 6 (Plaintiffs Exhibit No. I was marked for 7 8 Q. What is our cell hone number? MR. : Same instruction -- 7 8 identification.) MR. KUVIN: I'm going to show you what 9 THE WITNESS: On the advice of my lawyer, 9 we'll mark as Plaintiffs Exhibit I. 10 I choose to invoke m Fifth Amendment right. 10 And I'll ask the videographer to zoom 11 MR. : You have to let me speak 11 in here fora second. 12 before you answer in case there's an objection 12 BY MR. KUVIN: 13 or any of the other lawyers have an objection. 13 Q. Okay. Ma'am, I am going to show you a 14 BY MR. KUVIN: 14 photograph we've marked as Plaintiffs Exhibit 1 and 15 Q. I am going to show you a photograph. Oh, 15 ask you if you recognize this registered sex 16 what is your date of birth? 16 offender. 17 MR. : Same instruction. 17 MR. : First, object to the form 18 THE WITNESS: On the advice of my lawyer, 18 of the question. It assumes facts not before 19 I choose to invoke my Fifth Amendment right. 19 the witness, and I'll give the witness the same 20 MR. KUVIN: Let's make is easier. 20 instruction as to that question. 21 BY MR. KUVIN: 21 THE WITNESS: At the advice of my lawyer, 22 Q. would ou agree with me that 22 I must invoke my Fifth Amendment right. 23 your date of birth i 23 BY MR. KUVIN: 24 MR. : Same instruction. 24 Q. Would you agree with me that this 25 THE WITNESS: On the advice of my lawyer, 25 registered sex offender's name is Jeffrey Epstein? 4 (Pages 13 to 1 6) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 4 of 47 EFTA_00065321 EFTA01246467 1 2 3 4 S 6 / 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 17 MR. Same instruction, same objection. THE WITNESS: At the advice of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that Jeffrey Epstein is a sexual offender? MR. Object to the form of the question and instruct the witness not to answer on her Fifth Amendment privilege. THE WITNESS: On the advice of my lawyer I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that Jeffrey Epstein sexual) abused you? MR. Objection to the form, both as to the form of the question as to harassing and instruct the witness not to answer, based on the Fifth Amendment privilege. THE WITNESS: On the advice of my lawyer. I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that you were a minor when Jeffrey Epstein first had sexual relations with you? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 19 question. It's ambiguous and compound. and I will instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the advice of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. And wh did ou do that? MR. : Object to the form. It's ambiguous, in fact that what? BY MR. KUVIN: Q. Why did you bring minor girls to Jeffrey Epstein for him to have sex with? MR. : Same objection as to forty and instruct the witness not to answer. THE WITNESS: On the advice of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. What do ou currently do for a job? MR. : Instruct the witness not to answer the question. THE WITNESS: On the advice of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: I. Page 18 Page 20 1 MR. Object to the form. It 1 MR. Instruct the witness not 2 assumes facts not before the witness. It is a 2 to answer the question. 3 compound question and I would instruct the 3 THE WITNESS: On the advice of my lawyer, 4 witness not to answer based on her Fifth 4 I must invoke my Fifth Amendment right. S Amendment privilege. 5 BY MR. KUVIN: 6 THE WITNESS: On the advice of my lawyer. 6 ii 7 I must invoke my Fifth Amendment right. I 8 BY MR. KUVIN: 8 MR. Same instruction. 9 Q. Would you agree with me that you have had 9 THE WITNESS: On the advice of my lawyer, 10 sex with Jeffrey E tein? 10 I must invoke my Fifth Amendment right. 11 MR. Same instruction. 11 BY MR. KUVIN: 12 THE WITNESS: On the advice of my lawyer. 12 I. 13 I must invoke my Fifth Amendment right. 14 BY MR. KUVIN: 9 15 Q. Would you agree with me that you first had 15 MR. Instruct the witness not 16 sex with Jeffrey Epstein when you were under the age 16 to answer the question. 17 of 18? 17 THE WITNESS: On the instruction of my 18 MR. Same instruction. 18 lawyer, I must invoke my Fifth Amendment right. 19 THE WITNESS: On the advice of my lawyer. 19 BY MR. KUVIN: 20 I must invoke my Fifth Amendment right. 20 • 21 BY MR. KUVIN: 22 Q. Would you agree with me. ma'am, that you 23 brought numerous underage girls to Jeffrey Epstein 23 MR. Object to the form. It's 24 so that he could have sex with them? 24 compound and assumes facts not present before 25 MR. Object to the form of the 25 the witness, and I instruct the witness not to S (Pages 17 to 20) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 5 of 47 EFTA_00065322 EFTA01246468 Page 21 Page 23 1 answer the question based on her Fifth 1 witness, and I will instruct the witness not to 2 Amendment privilege. 2 answer based on her Fifth Amendment privilege. 3 THE WITNESS: On the instruction of my 3 THE WITNESS: On the instruction of my 4 lawyer, I must invoke my Fifth Amendment right. 4 lawyer, I must invoke my Fifth Amendment right. 5 BY MR. KUVIN: 5 BY MR. KUVIN: 6 Q. Who introduced you to Jeffrey Epstein the 6 Q. Would you agree with me that 7 first time that ou met him? 7 Jeffrey Epstein owns numerous planes, private 8 MR. Same instruction. 8 planes? 9 THE WITNESS: On the instruction of my 9 MR. Instruct the witness not 10 lawyer, I must invoke my Fifth Amendment right. 10 to answer. 11 BY MR. KUVIN: 11 THE WITNESS: On the instruction of my 12 Q. Did Ghislaine Maxwell introduce you to 12 lawyer, I must invoke my Fifth Amendment right. 13 Jeffrey Epstein for the first time? 13 BY MR. KUVIN: 14 MR. Same instruction. 14 Q. And you've been on every one of those 15 THE WITNESS: On the instruction of my 15 private planes: isn't that true? 16 lawyer, I must invoke my Fifth Amendment right. 16 MR. : Object to the form. It 17 BY MR. KUVIN: 17 assumes facts not before the witness, and I 18 Q. When was the first time you were in 18 will instruct the witness not to answer based 19 Jeffrey Epstein's home located on El Brillo Way on 19 on her Fifth Amendment privilege. 20 Palm Beach Island? 20 THE WITNESS: On the instruction of my 21 MR. Object to the form of the 21 lawyer, I must invoke my Fifth Amendment right. 22 question as compound and assuming facts not 22 BY MR. KUVIN: 23 before the witness. And I instruct the witness 23 Q. Ma'am, isn't it true that you've seen the 24 not to answer based on her Fifth Amendment 24 passenger manifest for Jeffrey Epstein's plane? 25 privilege. 25 MR. Object to the form. It Page 22 Page 24 1 THE WITNESS: On the instruction of my 1 assumes facts that are not established as known 2 lawyer, I must invoke my Fifth Amendment right. 2 to this witness, and I instruct the witness not 3 BY MR. KUVIN: 3 to answer the question based on her Fifth 4 Q. Would you agree with me that 4 Amendment privilege. 5 Jeffrey Epstein owns a home at 358 El Brillo Way, 5 THE WITNESS: On the instruction of my 6 Palm Beach Island. Florida? 6 lawyer, I must invoke my Fifth Amendment right. 7 MR. : Instruct the witness not 7 MR. KUVIN: Let me show you what we'll 8 to answer based on her Fifth Amendment 8 mark as Exhibit 2. 9 privilege. 9 10 THE WITNESS: On instruction of my 10 (Plaintiff's Exhibit No. 2 was marked for 11 counsel, I must invoke my Fifth Amendment 11 identification.) 12 right. 12 MR. KUVIN: Thank you. 13 BY MR. KUVIN: 13 MR. : Do you want to zoom in on 14 Q. Would you agree with me that you've been 14 it like you did the last time? 15 in that home numerous times? 15 MR. KUVIN: No. that's fine. 16 MR. Instruct the witness not 16 MR. : Take your time. 17 to answer the question based on her Fifth 17 MR. KUVIN: And flip through. 18 Amendment privilege. 18 BY MR. KUVIN: 19 THE WITNESS: On instruction of my lawyer, 19 Q. All right. Ma'am. would you agree with me 20 I must invoke my Fifth Amendment right. 20 that this is a passenger manifest for one of 21 22 BY MR. KUVIN: Q. Would you agree with me that you have gone 21 22 Jeffrey Epstein's ai lanes? MR. : Instruct the witness not 23 24 on Jeffrey E stein 's lane numerous times? MR. . Object to the form. It 23 24 to answer the question based on her Fifth Amendment privilege. 25 assumes fact. that are not present for the 25 THE WITNESS: On the instruction of my 6 (Pages 21 to 24) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 6 of 47 EFTA_00065323 EFTA01246469 Page 25 Page 27 1 lawyer I must exercise my Fifth Amendment 1 Amendment privilege. 2 right. 2 THE WITNESS: On the instruction of my 3 BY MR. KUVIN: 3 lawyer, I must invoke my Fifth Amendment right. 4 Q. And would you agree with me that you 4 BY MR. KUVIN: 5 appear as a passenger on these flight manifests on 5 Q. Would you also agree with me that the two 6 numerous occasions? 6 unknown females listed on the passenger manifest 7 MR. Object to the form. It 7 marked as Exhibit 2 were underage girls, under the 8 assumes facts not established as known to this 8 age of IS? 9 witness, and I instruct the witness not to 9 MR. : Object to the form. It 10 answer the question. 10 calls for speculation. Also it's not been 11 THE WITNESS: On the instruction of my 11 established this witness has any knowledge of 12 lawyer, I must exercise my Fifth Amendment 12 this document and instruct her not to answer 13 right. 13 based on her Fifth Amendment privilege. 14 BY MR. KUVIN: 14 THE WITNESS: On the instruction of my 15 Q. Would you agree with me that your name 15 lawyer, I must invoke my Fifth Amendment right. 16 does, in fact, appear on the passenger manifest for 16 BY MR. KUVIN: 17 these planes for this lane? 17 Q. Would you agree with me that the girls 18 MR. Same objection and same 18 that are listed as females one, and the second 19 instruction. 19 female for this flight of January II, 2005, from 20 THE WITNESS: On the advice of my lawyer, 20 West Palm Beach to the U.S. Virgin Islands, that 21 I must invoke my Fifth Amendment right. 21 those two females were under the age of 17? 22 BY MR. KUVIN: 22 MR. : Same objection. It has 23 Q. Who are the two females that appear on the 23 not been established the witness has any 24 passenger manifest for January II, 2005. on the 24 knowledge of this document. It calls for her 25 first page of Exhibit 2? 25 to speculate, and I instruct her not to answer Page 26 Page 28 1 MR. I'll object to the form, 1 based on her Fifth Amendment privilege. 2 and it has not been established this witness 2 THE WITNESS: On the instruction of my 3 knows anything about this document, and I will 3 lawyer, I must invoke my Fifth Amendment right. 4 instruct her not to answer based on the Fifth 4 BY MR. KUV1N: S Amendment privilege. 5 Q. Would you agree with me that the two 6 THE WITNESS: On the instruction of my 6 females shown on the flight with you of January II, 7 8 lawyer I must invoke my Fifth Amendment right. BY MR. KUVIN: 7 8 2005 were under the a e of 16? MR. Same objection as to form 9 Q. Do you agree with me that you took a 9 It has not been established this witness knows 10 flight on Jeffrey Epstein's plane from West Palm 10 anything about whether there were these 11 Beach to the U.S. Virgin Islands. St. Thomas on 11 witnesses, these females and who they are, so 12 January II, 2005? 12 it's asking her to speculate. and I instruct 13 MR. Instruct the witness not 13 her not to answer based on her Fifth Amendment 14 to answer the question based on her Fifth 14 privilege. 15 Amendment privilege. 15 THE WITNESS: On the instruction of my 16 THE WITNESS: On the instruction of my 16 lawyer, I must invoke my Fifth Amendment 17 lawyer I must invoke my Fifth Amendment right. 17 privilege. 18 BY MR. KUVIN: 18 BY MR. KUV1N: 19 Q. Would you agree with me that on that 19 Q. Ma'am, you were on that flight of 20 flight were you. Jeffrey Epstein, 20 January 11. 2005. wereyou not? 21 and two unknown females? 21 MR. I instruct the witness not 22 MR. Object to the form. Again 22 to answer based on her Fifth Amendment 23 assumes facts that have not been established 23 privilege. 24 this witness has any knowledge of and instruct 24 THE WITNESS: On the instruction of my 25 the witness not to answer based on her Fifth 25 lawyer I must invoke my Firth Amendment right. 7 (Pages 25 to 28) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 7 of 47 EFTA_00065324 EFTA01246470 1 Page 29 BY MR. KUVIN: 1 Page 31 MR. Same instruction. 2 Q. You also agree with me that the two girls 2 THE WITNESS: On the instruction of my 3 that are listed as on that flight with you of 3 lawyer, I must invoke my Fifth Amendment right. 4 January 11, 2005, were under the age of 15 years 4 BY MR. KUVIN: 5 old? 5 Q. Who is 6 MR. Object to the form. It 6 MR. : Same instruction. 7 calls for speculation, lack of personal 7 THE WITNESS: On the advice of my lawyer, 8 knowledge, and instruct the witness not to 8 I must invoke my Fifth Amendment right. 9 answer based on her Fifth Amendment privilege. 9 BY MR. KUVIN: 10 THE WITNESS: On the instruction of my 10 Q. Who is Mark Zeff. 11 lawyer, I must invoke my Fifth Amendment right. 11 MR. Same instruction. 12 BY MR. KUVIN: 12 THE WITNESS: On the advice of my lawyer, 13 Q. Would you agree with me that the two 13 I must invoke my Fifth Amendment right. 14 females listed as being on that flight with you of 14 BY MR. KUVIN: 15 January I 1 of 2005 were under the age of 14 years 15 Q. Who is David Mullen? 16 old? 16 MR. : Same instruction. 17 MR. Object to the form. It 17 THE WITNESS: On the advice of my lawyer, 18 calls for speculation. The witness has no 18 I must invoke my Fifth Amendment right. 19 personal knowledge and instruct the witness not 19 BY MR. KUVIN: 20 to answer based on her Fifth Amendment 20 Q. Who is Todd Meister? 21 privilege. 21 MR. : Same instruction. 22 THE WITNESS: On the instruction of my 22 THE WITNESS: On the advice of my lawyer, 23 lawyer, I must invoke my Fifth Amendment right. 23 I must invoke my Fifth Amendment right. 24 BY MR. KUVIN: 24 BY MR. KUVIN: 25 Q. Would you agree with me that the two 25 Q. Who is Jean-Luc Brunel? Page 30 Page 32 1 females listed as being on the flight with you of 1 MR. Same instruction. 2 January II, 2005, from West Palm Beach to the U.S. 2 THE WITNESS: On the advice of my lawyer, 3 Virgin Islands, with Jeffrey Epstein as well, were 3 I must invoke my Fifth Amendment right. 4 under the age of 13 years old and you were aware of 4 BY MR. KUVIN: S that? 5 Q. Ma'am, would you agree with me that all of 6 MR. Object to the form both as 6 the names I just recently mentioned where you 7 compound. it also assumes facts that it has not 7 invoked your Fifth Amendment, were involved in a 8 been established this witness has any knowledge 8 conspiracy to abuse underaged girls, girls under the 9 of. calls for her to speculate, and I instruct 9 age of 18 for sexual ain and pleasure? 10 her not to answer based on her Fifth Amendment 10 MR. : Object to the form of the 11 privilege. 11 question. It calls for a legal conclusion. It 12 THE WITNESS: On the instruction of my 12 is compound. It calls for her to speculate. 13 lawyer I must invoke my Fifth Amendment right. 13 There is no basis for her to be able to give a 14 BY MR. KUVIN: 14 legal opinion as to what a conspiracy is, and I 15 Q. Who is ? 15 instruct her not to answer based on her Fifth 16 MR. I'm sony. Can you repeat 16 Amendment privilege. 17 the name? 17 THE WITNESS: On the advice of my lawyer. 18 MR. KUVIN: 18 I must invoke my Fifth Amendment right. 19 MR. I'll instruct the witness 19 BY MR. KUVIN: 20 not to answer based on her Fifth Amendment 20 Q. Would you agree with me that all of the 21 privilege. 21 names I just mentioned were individuals that were 22 THE WITNESS: On instruction of my lawyer, 22 working together for their own sexual gain and 23 I must invoke my Fifth Amendment right. 23 pleasure? 24 BY MR. KUVIN: 24 MR. : Object to the form of the 25 Q. Who's Ohislaine Maxwell? 25 question as ambiguous and compound. I instruct 8 (Pages 29 to 32) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 8 of 47 EFTA_00065325 EFTA01246471 Page 33 Page 35 1 her not to answer based on her Fifth Amendment 1 BY MR. KUVIN: 2 privilege. 2 Q. Would you agree with me that Jeffrey 3 THE WITNESS: On the advice of my lawyer I 3 Epstein worked closely with Jean-Luc Brunel in order 4 must invoke my Fifth Amendment privilege. 4 to obtain girls from out of state and bring them to 5 BY MR. KUVIN: 5 Florida for their own sexual pleasure? 6 Q. What is MC S •oared? 6 MR. Object to the form as 7 MR. I instruct the witness not 7 ambiguous. whose own sexual pleasure. and 8 to answer based on her Fifth Amendment 8 instruct the witness not to answer the question 9 privilege. 9 based on her Fifth Amendment privilege. 10 THE WITNESS: On the advice of my lawyer I 10 MR. KUVIN: Perfectly good objection. She 11 must invoke my Fifth Amendment right. 11 doesn't have to answer the question. Let me 12 BY MR. KUVIN: 12 clarify. 13 Q. Would you agree with me that MC Squared is 13 BY MR. KUVIN: 14 a modeling agency that was funded by 14 Q. Would you agree with me, ma'am. that both 15 Jeffrey Epstein? 15 Jean-Luc Brunel and Jeffrey Epstein worked together 16 MR. I instruct the witness not 16 to obtain underage girls from out of state and bring 17 to answer based on her Fifth Amendment 1"/ them to Florida for both of their own sexual 18 privilege. 18 pleasure? 19 THE WITNESS: The advice of my lawyer I 19 MR. I'm going to object as 20 must invoke my Fifth Amendment right. 20 compound and instruct -- I object to the form 21 BY MR. KUVIN: 21 as compound. and instruct the witness not to 22 Q. Would you agree with me that MC Squared 22 answer based on her Fifth Amendment privilege. 23 24 was wholly funded b Jeffrey Epstein? MR. • Object to the form of the 23 24 THE WITNESS: On the instruction of my lawyer I must invoke my Fifth Amendment right. 25 question as to what "wholly funded" means, and 25 Page 34 Page 36 1 I would instruct the witness not to answer the 1 BY MR. KUVIN: 2 question based on her Fifth Amendment 2 A. Would you agree with me that 3 privilege. 3 Ghislaine Maxwell. Jean-Luc Brunel- and Jeffrey Epsteit 4 THE WITNESS: On the advice of my lawyer I 4 worked together to obtain underage girls from out of 5 must invoke my Fifth Amendment right. 5 state and bring them into the State of Florida for their 6 BY MR. KUVIN: 6 own sexual .lea ure? 7 Q. Would you agree with me that 7 MR. : Object to the form of the 8 Jeffrey Epstein is the sole individual whose money 8 question as compound and ambiguous. and 9 was used to start the corn • any. MC Squared? 9 instruct the witness not to answer based on her 10 MR. Instruct the witness not 10 Fifth Amendment privilege. 11 to answer the question based on her Fifth 11 THE WITNESS: On the instruction of my 12 Amendment privilege. 12 lawyer. I must invoke my Fifth Amendment right. 13 THE WITNESS: On the advice of my lawyer I 13 (Katherine Ezell and Amy Ederi 14 must invoke my Fifth Amendment right. 14 entered the deposition.) 15 BY MR. KUVIN: 15 MR. GOLDBERGER: That's why we're -- 16 Q. Would you agree with me that 16 MR. KUVIN: That's why we lost them. 17 Jean-Luc Brunel worked with Jeffrey Epstein to 17 MR. : Do you want to take a 18 obtain underage girls for both of their sexual 18 one-minute break so we can -- 19 pleasure? 19 MR. KUVIN: Yeah, let's take a quick 20 MR. Object to the form of the 20 one-minute break. 21 question as ambiguous and instruct the witness 21 THE VIDEOGRAPHER: We're now off video 22 not to answer based on her Fifth Amendment 22 record. The time is 10:56 a.m. 23 privilege. 23 (A brief recess was held.) 24 THE WITNESS: On the advice of my lawyer I 24 (Plaintiffs Exhibit No. 3 was marked for 25 must invoke my Fifth Amendment right. 25 identification.) 9 (Pages 33 to 36) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 9 of 47 EFTA_00065326 EFTA01246472 Page 37 Page 39 1 THE VIDEOGRAPHER: We're now on video 1 personal knowledge and instruct her not to 2 record at 11:01 a.m. 2 answer based on her Fifth Amendment privilege. 3 MR. KUVIN: Just for the video record and 3 It's also compound. 4 for the written record Katherine Ezell and Amy 4 THE WITNESS: On the instruction of my 5 Eden have now appeared and are present in 5 lawyer I must invoke my Fifth Amendment 6 person. 6 privilege. 7 MR. GOLDBERGER: Just one more matter for 7 BY MR. KUVIN: 8 the record. Jack Goldberger. on behalf of 8 Q. The witness says that you may not have 9 Jeffrey Epstein. Rather than impose a form 9 knowledge or we don't know whether you have 10 objection to every question. I think we have 10 knowledge regarding this passenger manifest, so let 11 reached an agreement that on behalf of 11 me ask you, do you have any knowledge about this 12 Mr. Epstein. I am adopting the form objections 12 passenger manifest? 13 that Mr. is making on behalf of his 13 MR. Object to the form of the 14 client nunc pro tunc to the beginning of this 14 question as ambiguous as to this and what a 15 deposition. 15 manifest is, and also her knowledge, and I will 16 MR. KUVIN: No objection. 16 instruct her not to answer based on her Fifth 17 MR. GOLDBERGER: Okay. 17 Amendment privilege. 18 BY MR. KUVIN: 18 THE WITNESS: On the instruction of my 19 Q. All right. All right. would 19 lawyer, I must invoke my Fifth Amendment 20 you agree with me that there was an agreement 20 privilege. 21 between Jeffrey Epstein, Ghislaine Maxwell. 21 BY MR. KUVIN: 22 Jean-Luc Brunel. yourself and to 22 Q. Based on the objection, do you know what a 23 bring in girls from out of state that were underage? 23 manifest is? 24 MR. : Object to the form of the 24 MR. Object to the form of the 25 question as leading, as compound, and instruct 25 question as ambiguous and instruct her not to Page 38 Page 40 1 the witness not to answer based on her Fifth 1 answer based on her Fifth Amendment privilege. 2 Amendment privilege. 2 THE WITNESS: On the instruction of my 3 THE WITNESS: On the instruction of my 3 lawyer I must invoke my Fifth Amendment right. 4 lawyer I must invoke my Fifth Amendment right. 4 BY MR. KUVIN: 5 BY MR. KUVIN: 5 Q. Have ou heard the word "manifest" before? 6 Q. Would you agree with me that there was an 6 MR. I'll instruct the witness 7 agreement between Jeffrey Epstein, 7 not to answer based on her Fifth Amendment 8 Ghislaine Maxwell, Jean-Luc Brunel, yourself and 8 privilege. 9 to bring in girls that were 9 THE WITNESS: On the instruction of my 10 underage from out of state for sexual contact? 10 lawyer I must invoke my Fifth Amendment right. 11 MR. : Object to the form of the 11 BY MR. KUVIN: 12 question as leading and compound, and I 12 Q. Would you agree with me, ma'am. that you 13 instruct the witness not to answer based on her 13 have seen this passenger manifest, listed as 14 Fifth Amendment privilege. 14 Exhibit 3, in the 'est? 15 THE WITNESS: On the instruction of my 15 MR. I'll instruct the witness 16 lawyer I must invoke my Fifth Amendment 16 not to answer based on her Fifth Amendment 17 privilege. 17 privilege. 18 BY MR. KUVIN: 18 THE WITNESS: On the instruction of my 19 Q. All right. Let me show you what we've 19 lawyer I must invoke my Fifth Amendment right. 20 premarked as Plaintiffs Exhibit 3. Do you 20 BY MR. KUVIN: 21 recognize this as the passenger manifest for one of 21 Q. Who is 22 Jeffrey Epstein's lanes? 22 MR. I'll instruct the witness 23 MR. : I object to the form of 23 not to answer based on her Fifth Amendment 24 the question. It assumes facts that this 24 privilege. 25 witness. evidence that this witness has no 25 THE WITNESS: On the instruction of my 10 (Pages 37 to 40) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 10 of 47 EFTA_00065327 EFTA01246473 Page 41 Page 43 1 lawyer I must invoke my Fifth Amendment 1 listed in the risen er list to the left? 2 privilege. 2 MR. : Object to the form. the 3 4 MR. KUVIN: S ellin for the court reporter i 3 4 question is leading and the witness instruct not to answer based on the Fifth Amendment 5 BY MR. KUVIN: 5 privilege. 6 Q. Who is Eva Andersson, with two S's? 6 THE WITNESS: On the instruction of my 7 MR. • I'll instruct the witness 7 lawyer, I must invoke my Fifth Amendment right. 8 not to answer based on her Fifth Amendment 8 BY MR. KUVIN: 9 privilege. 9 Q. Would you agree with me that you were on a 10 THE WITNESS: On the instruction of my 10 plane with Jeffrey E stein on April 27. 2005? 11 lawyer, I must invoke my Fifth Amendment right. 11 MR. : Same instruction. 12 BY MR. KUVIN: 12 THE WITNESS: On the instruction of my 13 Q. Who is (phonetic)? 13 lawyer, I must invoke my Fifth Amendment right. 14 MR. Same instruction. 14 BY MR. KUVIN: 15 THE WITNESS: On the instruction of my 15 Q. Would you agree with me that on that plane 16 lawyer, I must invoke my Fifth Amendment right. 16 of April 27, 2005. from Teterboro. New Jersey. to 17 BY MR. KUVIN: 17 West Palm Beach. was a female who was under the age 18 Q. Who is (phonetic)? 18 of 16? 19 MR. Same instruction. 19 MR. : Object to the form. It 20 THE WITNESS: On the instruction of my 20 assumes facts not established. Any personal 21 lawyer I must invoke my Fifth Amendment right. 21 knowledge by this witness, and instruct her not 22 BY MR. KUVIN: 22 to answer based on her Fifth Amendment 23 Q. Who is Chris Valdez (phonetic)? 23 privilege. It also calls for speculation. 24 MR. Same instruction. 24 THE WITNESS: On the instruction of my 25 THE WITNESS: On the instruction of my 25 lawyer, I must invoke my Fifth Amendment Page 42 Page 44 1 lawyer I must invoke my Fifth Amendment right. 1 privilege. 2 BY MR. KUVIN: 2 BY MR. KUVIN: 3 Q. Who is James Stanley? 3 Q. Would you agree with me that on the flight 4 MR. Same instruction. 4 of April 27, 2005. from Teterboro. New Jersey to 5 THE WITNESS: On the instruction of my 5 West Palm Beach was a female on the plane with you 6 lawyer. I must invoke my Fifth Amendment right. 6 that was under the of 15? 7 BY MR. KUVIN: 7 MR. : Object to the form of the 8 Q. Who is S hia Stanley? 8 It requires speculation. It assumes 9 MR. Same instruction. 9 question. facts not established before this witness. 10 THE WITNESS: On the instruction of my 10 I'll instruct her not to answer based on her 11 lawyer I must invoke my Fifth Amendment right. 11 Fifth Amendment privilege. It's also 12 BY MR. KUVIN: 12 ambiguous. 13 Q. Who is Alexis Stanley? 13 THE WITNESS: On the instruction of my 14 MR. Same instruction. 14 lawyer,I must invoke my Fifth Amendment 15 THE WITNESS: On the instruction of my 15 privilege. 16 lawyer. I must invoke my Fifth Amendment right. 16 BY MR. KUVIN: 17 BY MR. KUVIN: 17 Q. Will you turn to May 6. 2005, please. And 18 Q. Ma'am, if you would, in Exhibit 3, would 18 this is, for the record, in Exhibit 3. On May 6th. 19 you turn to the date of April 27.2005. for me? 19 2005, ma'am. will you agree with me that you took a 20 21 through It's about halfway the packet. April 27, '05. Are you there? 20 21 flight from Teterboro. New Terse West Palm Beach. with Jeffre E. tein 22 A. Uh-huh. 22 David Mullen. Larry 23 Q. Okay. On this particular date, will you 23 Morrison and another female? 24 agree with me that you flew from Teterboro. 24 MR. : Object to the form of the 25 New Jersey to %Vest Palm Beach on a plane with people 25 question as compound. calling for speculation. 11 (Pages 41 to 44) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 11 of 47 EFTA_00065328 EFTA01246474 Page 45 Page 47 I instruct the witness not to answer based on 1 BY MR. KUVIN: 2 her Fifth Amendment privilege. 2 Q. Do you also agree with me on that flight 3 THE WITNESS: On the instruction of my 3 of June 20th, 2005. was an unidentified female, 4 lawyer, I must invoke my Fifth Amendment 4 according to thepassenger manifest? 5 privilege. 5 MR. Object to the form -- 6 BY MR. KUVIN: 6 excuse me -- as leading, and instruct the 7 Q. Would you agree with me, ma'am, that on 7 witness not to answer based on her Fifth 8 the flight of May 6th, 2005. that's shown in 8 Amendment privilege. 9 Exhibit 3, that the female identified in the 9 THE WITNESS: On the instruction of my 10 passenger manifest was under the age of 16? 10 lawyer, I must choose to invoke my Fifth 11 MR. : Object to the form. It 11 Amendment privilege. 12 assumes facts not established that this witness 12 BY MR. KUVIN: 13 has any personal knowledge. It calls for her 13 Q. Would you agree with me that that female 14 to speculate, and I'll instruct her not to 14 listed on the flight of June 20. 2005, was under the 15 answer based on her Fifth Amendment privilege. 15 age of 16 years old? 16 THE WITNESS: On the instruction of my 16 MR. Objection to the form as 17 lawyer, I must invoke my Fifth Amendment 17 leading and also requiring speculation. I'll 18 privilege. 18 instruct the witness not to answer based on her 19 BY MR. KUVIN: 19 Fifth Amendment privilege. 20 Q. Would you agree with me that the female 20 THE WITNESS: On the instruction of my 21 identified in the passenger manifest of May 6th, 21 lawyer, I must choose to invoke my Fifth 22 2005, was under the a e of 15? 22 Amendment privilege. 23 MR. : Same objection as the 23 BY MR. KUVIN: 24 previous question, same instruction. 24 Q. Would you agree with me that the 25 THE WITNESS: On the instruction of my 25 unidentified female on the passenger manifest of Page 46 Page 48 1 lawyer I must invoke my Fifth Amendment 1 June 20, 2005. was under the age of 14? 2 privilege. 2 MR. Objection, calls for 3 BY MR. KUVIN: 3 speculation, instruct the witness not to answer 4 Q. Would you agree with me that the female 4 based on her Fifth Amendment privilege. 5 listed in the passenger manifest of May 6th, 2005, 5 THE WITNESS: On the instruction of my 6 was under the a e. was under the age of 14? 6 lawyer, I must invoke my Fifth Amendment 7 MR. Same instruction as to the 7 privilege. 8 previous two questions and the same objection 8 BY MR. KUVIN: 9 as to those two questions. 9 Q. Turn to the date of June 30, if you would, 10 THE WITNESS: On the instruction of my 10 2005. Would you agree with me that you took a 11 lawyer I must invoke my Fifth Amendment 11 flight from Teterboro. New Jersey, to West Palm 12 privilege. 12 Beach on June 30. 2005. with Jeffrey Epstein? 13 BY MR. KUVIN: 13 MR. Object to the form as 14 Q. If you would turn to the date of June 20 14 leading and compound, instruct the witness not 15 of 2005 for me, please. On the date of June 20, 15 to answer based on her Fifth Amendment 16 2005, would you agree with me that you took a flight 16 privilege. 17 with Jeffrey Epstein from West Palm Beach to 17 THE WITNESS: On the instruction of my 18 Teterboro, New Jerse ? 18 lawyer I must, I must invoke my Fifth Amendment 19 MR. Object to the form as 19 right 20 leading. I'll instruct the witness not to 20 BY MR. KUVIN: 21 answer based on her Fifth Amendment privilege. 21 Q. Would you agree with me that 22 THE WITNESS: On the instruction of my 22 was on that fli t? 23 lawyer, I must invoke my Fifth Amendment 23 MR. Same instruction. 24 privilege. 24 THE WITNESS: On the instruction of my 25 25 lawyer I must invoke my Firth Amendment 12 (Pages 45 to 48) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 12 of 47 EFTA_00065329 EFTA01246475 Page 49 Page 51 1 privilege. 1 THE WITNESS: On the instruction of my 2 BY MR. KUVIN: 2 lawyer I must invoke my Fifth Amendment 3 Q. Would you agree with me that there was 3 privilege. 4 also another female on that flight with you? 4 BY MR. KUVIN: 5 MR. Same instruction. 5 Q. Would you agree with me that on both of 6 THE WITNESS: On the instruction of my 6 those flights were girls that were under the age of 7 lawyer, I must invoke my Fifth Amendment 7 16? 8 privilege. 8 MR. : Same form objection as tc 9 BY MR. KUVIN: 9 compound, also ambiguous and requiring 10 Q. Would you agree with me that you had 10 speculation and instruct the witness not to 11 personal knowledge that that female on that 11 answer based on her Fifth Amendment privilege. 12 flight with you of June 30, 2005, was under the age 12 THE WITNESS: The instruction of my lawyer 13 of 16? 13 I must invoke my Fifth Amendment privilege. 14 MR. Object to the form as 14 BY MR. KUVIN: 15 compound and calling for speculation, and 15 Q. Would you agree with me, ma'am. that you 16 instruct the witness not to answer based on her 16 have flown on Jeffrey Epstein's plane from 17 Fifth Amendment privilege. 17 Teterboro. New Jersey. to West Palm Beach. on 18 THE WITNESS: On the instruction of my 18 numerous occasions where there were girls on the 19 lawyer, I must invoke my Fifth Amendment 19 plane under the a e of 16? 20 privilege. 20 MR. : Object to the form as 21 BY MR. KUVIN: 21 compound and ambiguous as to what numerous 22 Q. Would you agree with me that you had 22 means. Instruct the witness not to answer 23 personal knowledge that that young female on the 23 based on her Fifth Amendment privilege. 24 flight of June 30, 2005. was under the age of 15? 24 THE WITNESS: On the instruction of my 25 MR. Same instruction, calls 25 lawyer I must invoke my Fifth Amendment Page 50 Page 52 1 for speculation. 1 privilege. 2 THE WITNESS: On the instruction of my 2 BY MR. KUVIN: 3 lawyer, I must invoke my Fifth Amendment 3 Q. Would you agree with me that you have 4 privilege. 4 flown on Jeffrey Epstein's plane from Teterboro. New 5 BY MR. KUVIN: 5 Jersey. to West Palm Beach on at least 100 occasions 6 Q. Would you agree with me that you had 6 where there were girls on the plane with you under 7 personal knowledge that that young female on the 7 the age of 16? 8 flight of June 30. 2005. with you was under the age 8 MR. Object to the form as 9 of 14? 9 compound, requiring speculation and ambiguous, 10 MR. : Objection to form as to 10 and instruct her not to answer based on her 11 compound and requiring speculation. I'll 11 Fifth Amendment privilege. 12 instruct the witness not to answer based on her 12 THE WITNESS: On the instruction of my 13 Fifth Amendment privilege. 13 lawyer I must invoke my Fifth Amendment 14 THE WITNESS: On the instruction of my 14 privilege. 15 lawyer I must invoke my Fifth Amendment 15 BY MR. KUVIN: 16 privilege. 16 Q. Would you agree with me. ma'am. that you 17 BY MR. KUVIN: 17 have flown on Jeffrey Epstein's plane at least 100 18 Q. Ma'am, just so we can be quicker about 18 times from Teterboro, New Jersey to West Palm Beach 19 this, there are flights of July 5th, July IS. It 19 Florida. where there were girls under the age of IS 20 looks like those are the last two. Would you agree 20 on the plane with ou? 21 with me that on July 5th and July 15, you took 21 MR. Same objections as the 22 flights on Jeffrey E rein's plane? 22 previous question, same instruction. 23 MR. : Object to the form as 23 THE WITNESS: On the instruction of my 24 compound and instruct the witness not to answer 24 lawyer, I must invoke my Fifth Amendment 25 based on Filth Amendment privilege. 25 privilege. 13 (Pages 49 to 52) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 13 of 47 EFTA_00065330 EFTA01246476 Page 53 Page 55 1 BY MR. KUVIN: 1 occasions where Jeffrey Epstein was flying with 2 Q. Would you agree with me that you have 2 girls under the age of 16 from Teterboro. New 3 flown on Jeffrey Epstein's plane from Teterboro. New 3 Jersey. to Florida, West Palm Beach, Florida, with 4 Jersey to West Palm Beach on at least 100 occasions 4 girls under the age of 16, was doing so, so that he 5 where there were girls on the plane with you that 5 could have sexual contact with them? 6 were under the a e of 14? 6 MR. : Object to the form. It's 7 MR. : Objection to the form. 7 compound and requires her to assume facts that 8 It's compound and ambiguous. calls for 8 have not been established, and it's ambiguous, 9 speculation and instruct her not to answer 9 and instruct her not to answer based on the 10 based on her Fifth Amendment privilege. 10 Fifth Amendment privilege. 11 THE WITNESS: On the instruction of my 11 THE WITNESS: On the instruction of my 12 lawyer, I must invoke my Fifth Amendment 12 lawyer, I must assert my Fifth Amendment right. 13 privilege. 13 BY MR. KUVIN: 14 BY MR. KUVIN: 14 Q. Do you agree with me that on the flights 15 Q. Would you agree with me that you have been 15 from West Palm Beach to Paris, where you were 16 on the plane, one of Jeffrey Epstein's -- strike 16 present on the plane with Jeffrey Epstein, that 17 that. 17 there were girls under the age of 16 that 18 Would you agree with me that you have 18 Jeffrey Epstein was having sexual contact with on 19 been on Jeffrey Epstein's plane with him to Paris 19 that plane? 20 where there have been girls on the plane with you 20 MR. : Same objections as 21 under the a e of 16? 21 previously stated. It's compound, ambiguous. 22 MR. Objection to the form as 22 and assumes facts that she has no knowledge, or 23 compound. assuming facts not established the 23 it has not been established that she has any 24 witness has any knowledge, and instruct the 24 knowledge of, and instruct her not to answer 25 witness not to answer based on her Fifth 25 based on the Fifth Amendment, and it's leading. Page 54 Page 56 1 Amendment privilege. It's also leading. 1 THE WITNESS: On the instruction of my 2 THE WITNESS: On the instruction of my 2 lawyer I must invoke my Fifth Amendment right. 3 lawyer. I must invoke my Fifth Amendment 3 BY MR. KUVIN: 4 privilege. 4 Q. Ma'am, you've been on the plane, you've 5 BY MR. KUVIN: 5 been on a plane with Jeffrey Epstein in the past, 6 Q. Would you agree with me that you have been 6 have you not? 7 on the plane with Jeffrey Epstein on flights to 7 MR. Objection to the form as 8 Paris where there have been girls on the plane with 8 leading, and instruct her not to answer based 9 you under the a e of 15? 9 on the Fifth Amendment privilege. 10 MR. : Same objection and same 10 THE WITNESS: On the instruction of my 11 instruction as the previous question. 11 lawyer, I must invoke my Fifth Amendment 12 THE WITNESS: On the instruction of my 12 privilege. 13 lawyer, I must invoke my Fifth Amendment 13 BY MR. KUVIN: 14 privilege. 14 Q. Have you been on a plane with 15 BY MR. KUVIN: 15 Jeffrey Epstein ever in our entire life? 16 Q. Would you agree with me that you have been 16 MR. Instruct the witness not 17 on those same flights we have been discussing where 17 to answer based on her Fifth Amendment right. 18 there have been:iris under the age of 14? 18 THE WITNESS: On the instruction of my 19 MR. : Same instruction and same 19 lawyer I must invoke my Fifth Amendment 20 objection as the previous two questions. 20 privilege. 21 THE WITNESS: On the instruction of my 21 BY MR. KUVIN: 22 lawyer, I must invoke my Fifth Amendment 22 Q. Have you ever been on a plane with 23 privilege. 23 Jeffrey Epstein where there was a girl on the plane 24 BY MR. KUVIN: 24 with you under the a e of 14? 25 Q. Would you agree with me that on the 25 MR. Same instruction. 14 (Pages 53 to 5 6) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 14 of 47 EFTA_00065331 EFTA01246477 Page 57 Page 59 1 THE WITNESS: On the instruction of my 1 MR. Same objection as stated 2 lawyer, I must invoke my Fifth Amendment 2 to the previous question; it's ambiguous and 3 privilege. 3 instruct her not to answer based on the Fifth 4 BY MR. KUVIN: 4 Amendment. 5 Q. Ma'am, isn't it true that you've seen 5 THE WITNESS: On the instruction of my 6 Jeffrey Epstein have sex with girls under the age of 6 lawyer, I must invoke my Fifth Amendment right. 7 14 on his plane? 7 MR. KUVIN: Just to clarify, is the 8 9 MR. : Objection to the form. It assumes facts that it's not been established 8 9 ambigui the word "sex"? MR. : Sex and also assumes that 10 that she would have any knowledge of. and I'll 10 she's ever met Jeffrey Epstein in her life. 11 instruct her not to answer based on her Fifth 11 MR. KUVIN: Any other words in there I 12 13 Amendment right. THE WITNESS: On the instruction of my 12 13 need to clan ? MR. : No. 14 lawyer, I must invoke my Fifth Amendment 14 BY MR. KUVIN: 15 privilege. 15 Q. Okay. Ma'am, do you -- what's your 16 BY MR. KUVIN: 16 definition of the word "sex"? 17 Q. Would you agree with me that you've seen 17 MR. : Object to the form of the 18 Jeffrey Epstein have sex with girls on his plane in 18 question and instruct the witness not to answer 19 your presence Burin fli hts to Paris? 19 based on her Fifth Amendment privilege. 20 MR. Same objection previously : 20 THE WITNESS: On the instruction of my 21 stated, and it assumes facts that have not been 21 lawyer, I must invoke my Fifth Amendment right. 22 established and instruct her not to answer 22 BY MR. KUVIN: 23 based on her Fifth Amendment right. 23 Q. Would you agree with me that the word 24 THE WITNESS: On the instruction of my 24 "sex" means both vaginal intercourse as well as oral 25 lawyer, I must invoke my Fifth Amendment 25 sex? Would you agree with that definition? Page 58 Page 60 1 privilege. 1 MR. You can answer that. 2 BY MR. KUVIN: 2 THE WITNESS: No. 3 Q. Ma'am, isn't it true that you've seen 3 BY MR. KUVIN: 4 Jeffrey Epstein and Jean-Luc Brunel have sex with 4 Q. Okay. Would you agree with me that sex, 5 girls under the age of 14 on Mr. Epstein's plane on 5 for the purpose of our questions here today, will be 6 flights to Paris? 6 limited strictly to vaginal intercourse? 7 MR. Objection to the form. 7 A. Sorry. Can you repeat that? 8 It's compound. as to several answers all at the 8 Q. Yes. For the purpose of my questions here 9 same time and certain facts, and instruct her 9 today, will you agree that the word "sex" will be 10 not to answer based on her Fifth Amendment. 10 limited to vaginal intercourse between a man's penis 11 THE WITNESS: On the instruction of my 11 ma? 12 and a woman's va a? 12 lawyer, I must invoke my Fifth Amendment MR. If you're instructing her 13 privilege. 13 that in the future she should assume that 14 BY MR. KUVIN: 14 that's what you mean by your question, that's 15 Q. Ma'am, isn't it true that you have had sex 15 fine. 16 with Jeffrey E stein on his plane? 16 MR. KUVIN: Oka . 17 MR. : Instruct the witness not 17 MR. If that's what you mean, 18 to answer based on the Fifth Amendment 18 then that's understood. 19 privilege, also object to the form of the 19 MR. KUVIN: That's what I mean. 20 question as compound and ambiguous. 20 MR. Okay. 21 THE WITNESS: On the instruction of my 21 MR. KUVIN: All right. Let's go with that 22 lawyer, I must invoke my Fifth Amendment right. 22 definition. And for the purposes of my 23 BY MR. KUVIN: 23 questions, "oral sex" will mean contact between 24 Q. Isn't it true that you've had sex with 24 an individual's mouth and a man's sexual organ, 25 Jeffrey Epstein on hi, plane on flights to Paris? 25 penis. Fair enough? 15 (Pages 57 to 60) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 15 of 47 EFTA_00065332 EFTA01246478 Page 61 Page 63 1 MR. : Understood. 1 Mr. Epstein's residence, as to her knowledge of 2 MR. KUVIN: Okay. 2 Mr. Epstein and other facts as to which she's 3 BY MR. KUVIN: 3 invoking her Fifth Amendment privilege. 4 Q. Working with those definitions if we 4 THE WITNESS: On the instruction of my 5 could, would you agree with me that you had sex with 5 lawyer, I must to invoke my Fifth Amendment 6 Jeffrey Epstein on his 'lane? 6 privilege. 7 MR. : Objection to the form. 7 MR. KUVIN: Let me show you what we'll 8 It's compound and instruct her not to answer 8 mark as Exhibit 6. And this one I'm going to 9 based on the Fifth Amendment privilege, because 9 show it to the camera real briefly, if I could. 10 to do so would implicitly admit that she's ever 10 Okay. 11 met Jeffrey Epstein in her life, and so as to 11 MR. : Let me see it. Thank you 12 that she's invoking the Fifth Amendment 12 (Plaintiffs Exhibit No. 6 was marked for 13 privilege. 13 identification.) 14 THE WITNESS: On the instruction of my 14 BY MR. KUVIN: 15 lawyer, I must invoke my Fifth Amendment 15 Q. Ma'am, do you recognize any of the girls 16 privilege. 16 shown in Exhibit 6? 17 BY MR. KUVIN: 17 MR. : I'll instruct the witness 18 Q. Would you agree with me that you have had 18 not to answer based on her Fifth Amendment 19 oral sex with Jeffrey Epstein on his plane? 19 privilege. 20 MR. : Same objection stated to 20 THE WITNESS: On the instruction of my 21 the previous question. It's compound and it 21 lawyer, I must invoke my Fifth Amendment right. 22 assumes facts that's not been established as to 22 BY MR. KUVIN: 23 which she is invoking her Fifth Amendment 23 Q. Would you agree with me that that is you 24 25 privilege. THE WITNESS: On the instruction of my 25 24 on the right in this hoto raph, the far right? MR. : I'll instruct the witness Page 62 Page 64 lawyer, I must invoke my Fifth Amendment 1 not to answer. 2 privilege. 2 THE WITNESS: On the instruction of my 3 BY MR. KUVIN: 3 lawyer, I must invoke my Fifth Amendment 4 Q. Would you agree with me that you have had 4 privilege. 5 6 7 sex with Jeffre tein in his home -- MR. : Object to the -- MR. KUVIN: -- here in West Palm, in West 5 6 7 BY MR. KUVIN: • Would ou agree with me that that is on the left in that photograph that 8 Palm Beach? 8 we marked as Exhibit 6? 9 MR. : I'll instruct the witness 9 MR. Same instruction. 10 not to answer based on her Fifth Amendment 10 THE WITNESS: On the instruction of my 11 privilege and same objection previously stated 11 lawyer, I must invoke my Fifth Amendment 12 to the last two questions. 12 privilege. 13 THE WITNESS: On the instruction of my 13 BY MR. KUVIN: 14 lawyer, I must invoke my Fifth Amendment 14 Q. How old areyou in this photograph? 15 privilege. 15 MR. Same instruction. 16 BY MR. KUVIN: 16 THE WITNESS: On the instruction of my 17 Q. Would you agree with me that you have had 17 lawyer, I must invoke my Fifth Amendment 18 oral sex with Jeffrey Epstein in his home in West 18 privilege. 19 Palm Beach? 19 BY MR. KUVIN: 20 MR. GARCIA: Is it West, or Palm Beach? 20 Q. How old is in this 21 MR. KUVIN: Palm Beach Island. I think 21 if ou know? 22 it's, because -- yeah, for clarity, his home on 22 photograph, MR. I'm going to object to the 23 Palm Beach. 23 form in that it assumes facts as to her 24 MR. : Object to the form. It 24 knowledge of anything about Ms. and 25 assumes facts as to her knowledge of 25 as to which she is in‘okino, her Fifth Amendment 16 (Pages 61 to 64) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 16 of 47 EFTA_00065333 EFTA01246479 Page 65 Page 67 1 privilege. 1 THE WITNESS: On the instruction of my 2 THE WITNESS: On the instruction of my 2 lawyer, I must invoke my Fifth Amendment 3 lawyer. I must invoke my Fifth Amendment 3 privilege. 4 privilege. 4 BY MR. KUVIN: 5 MR. KUVIN: This is Exhibit 7. Let me 5 Q. Would you agree with me that 6 show you what well mark as Exhibit 7. 6 has been to Mr. Epstein's home on hundreds of 7 (Plaintiff's Exhibit No. 7 was marked for 7 occasions? 8 identification.) 8 MR. Object to the form as 9 BY MR. KUVIN: 9 compound and also assumes knowledge as this 10 Q. Do you recognize the girl that's shown in 10 witness has and instruct her to invoke her 11 Exhibit 7? 11 Fifth Amendment privilege relating to 12 MR. I need to consult with her 12 Ms. 13 one second. 13 THE WITNESS: On the instruction of my 14 MR. KUVIN: Sure. 14 lawyer, I must invoke my Fifth Amendment 15 THE VIDEOGRAPHER: Are we off the record? 15 privilege. 16 MR. KUVIN: No. no. 16 BY MR. KUVIN: 17 MR. Instruct the witness to 17 Would you agree with me that you directed 18 invoke her Fifth Amendment privilege as to 18 . on hundreds of occasions to bring girls 19 Exhibit 7. 19 under the a e of 16 to Mr. Epstein's house? 20 MR. KUVIN: She's clipped up. Okay. 20 MR. Object to the form of the 21 MR. Now you have to answer. 21 question as compound and ambiguous and assuming 22 THE WITNESS: On the advice of my lawyer, 22 facts as to which there is no factual basis 23 I must invoke my Fifth Amendment privilege. 23 that this witness has any knowledge and 24 BY MR. KUVIN: 24 instruct the witness not to answer based on her 25 Q. Would you agree with me that the girl 25 Fifth Amendment privilege. Page 66 Page 68 1 shown in Exhibit 7 is 1 THE WITNESS: On the instruction of my 2 MR. Instruct the witness not 2 lawyer, I must choose to invoke my Fifth 3 to answer based on the Fifth Amendment 3 Amendment right. 4 privilege. 4 BY MR. KUVIN: 5 THE WITNESS: On the instruction of my 5 Q. Would you agree with me that on hundreds 6 lawyer, I must invoke my Fifth Amendment 6 of occasions you directed to bring 7 privilege. 7 underage girls under the age of 16 to Mr. Epstein's 8 BY MR. KUVIN: 8 home for sex with Mr. E tein? 9 Q. Do you agree with me that was 9 MR. : Object to the form. It's 10 under the age of 16 when she was first asked to go 10 compound and it assumes facts as to this -- 11 to Mr. Epstein's home? 11 that this witness has no personal knowledge. 12 MR. Objection to the form. It 12 and it's been established by this record, and 13 assumes any knowledge witness as to the 13 instruct her to invoke her Fifth Amendment 14 person you identified as It's las 14 privilege. 15 compound and I would instruct her not to answer 15 THE WITNESS: On the instruction of my 16 based on her Fifth Amendment privilege. 16 lawyer, I must invoke my Fifth Amendment 17 THE WITNESS: On the instruction of my 17 privilege. 18 lawyer, I must invoke my Fifth Amendment 18 MR. KUVIN: We'll mark this as Exhibit 8. 19 privilege. 19 (Plaintiff's Exhibit No. 8 was marked for 20 BY MR. KUVIN: 20 identification.) 21 Q. Would ou agree with me that you know 21 BY MR. KUVIN: 22 personally 22 Q. Ma'am. do you recognize the person that's 23 MR. Instruct the witness not 23 shown in Exhibit 8? 24 to answer based on the Fifth Amendment 24 MR. : Let me consult one second. 25 privilege. 25 MR. KUVIN: Sure. 17 (Pages 65 to 68) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 17 of 47 EFTA_00065334 EFTA01246480 Page 69 Page 71 1 MR. : I instruct the witness not 1 MR. GARCIA: He didn't make a Fifth 2 to answer the question based on her Fifth 2 Amendment objection. So can we just rephrase 3 Amendment privilege. 3 the question? 4 THE WITNESS: Based on the instruction of 4 MR. : I would instruct the 5 my lawyer, I must invoke my Fifth Amendment 5 witness not to answer based on the Fifth 6 right. 6 Amendment privilege to clarify. 7 BY MR. KUVIN: 7 MR. KUVIN: Okay. Let's mark this as 8 Q. Would you agree with me that the person 8 Exhibit 9. 9 shown on Exhibit 8 is ou? 9 MR. : And for the record. the 10 MR. : Same instruction. 10 basis is that it assumes her knowledge of 11 THE WITNESS: On the instruction of my 11 anything relating to Jeffrey Epstein, the 12 lawyer, I must invoke my Fifth Amendment 12 question assumed that. 13 privilege. 13 (Plaintiffs Exhibit No. 9 was marked for 14 BY MR. KUVIN: 14 identification.) 15 Q. Would you agree with me that this is a 15 BY MR. KUVIN: 16 modeling shot of you that was taken through one of 16 Q. Ma'am, do you recognize the girl shown in 17 Mr. Epstein's modelin a encies? 17 Exhibit 9? 18 MR. : Object to the form of the 18 MR. : I'll instruct the witness 19 question as compound and assuming facts as to 19 not to answer based on her Fifth Amendment 20 which there has been no basis that this witness 20 privilege. 21 has any personal knowledge, and she's going 21 THE WITNESS: On the instruction of my 22 invoke her Fifth Amendment privilege. 22 lawyer, I must invoke my Fifth Amendment right. 23 THE WITNESS: On the instruction of my 23 BY MR. KUVIN: 24 lawyer, I must invoke my Fifth Amendment 24 Q. Would you agree with me that the girl 25 privilege. 25 shown in Exhibit 9 is ? Page 70 Page 72 1 BY MR. KUVIN: 1 MR. Same instruction. 2 Q. Would you agree with me that you were 2 THE WITNESS: On the instruction of my 3 under the age of 18 in this photograph we've marked 3 lawyer, I must invoke my Fifth Amendment 4 as Exhibit 8? 4 privilege. 5 MR. : Same objection as to the 5 MR. KUVIN: I forgot to do one more thing. 6 previous question and same instruction. 6 If you could give that back to me for just one 7 THE WITNESS: On the instruction of my 7 second just for the record so we can see what 8 lawyer, I must invoke my Fifth Amendment right. 8 we're talking about here. 9 BY MR. KUVIN: 9 Okay. I will give you back Exhibit 10 Q. Would you agree with me that you were 10 9. 11 under the age of 17 in this photograph that we've 11 MR. Thank you. 12 marked as Exhibit 8? 12 BY MR. KUVIN: 13 MR. : Same objection as the 13 Q. Wouldyou agree with me that this 14 previous two question and the same instruction. 14 photograph of was taken when she 15 THE WITNESS: On the instruction of my 15 was under the a e of 18? 16 lawyer, I must invoke my Fifth Amendment right. 16 MR. Objection to the form. It 17 18 BY MR. KUVIN: Q. Would you agree with me that Jeffrey 17 18 assumes this witness has any knowleifihat the n in the photograph is, in fact. 19 Epstein kept this photograph of you in his home, if 19 Therefore,it's ambiguous and 20 you know. 20 compound. and I'll instruct her not to answer 21 MR. : Object to the form of the 21 based on her Fifth Amendment privilege. 22 question as compound and ambiguous, and I would 22 THE WITNESS: On the instruction of my 23 instruct the witness not to answer. 23 lawyer, I must invoke my Fifth Amendment right. 24 THE WITNESS: On the instruction of my 24 BY MR. KUVIN: 25 lawyer, I must invoke my Fifth Amendment right. 25 Q. Would you agree with me that the gill 18 (Pages 69 to 72) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 18 of 47 EFTA_00065335 EFTA01246481 Page 73 Page 75 1 shown in that photograph -- strike that. 1 implicitly assumes that she does. I would 2 Would you agree with me that this 2 instruct her not to answer it based on her 3 photograph was ke t b Jeffrey Epstein in his home? 3 Fifth Amendment privilege. 4 MR. Objection to the form as 4 THE WITNESS: Upon the instruction of my 5 to being compound in that it assumes that she 5 lawyer, I must invoke my Fifth Amendment 6 has any knowledge of Jeffrey Epstein or his 6 privilege. 7 home, and I would instruct her not to answer 7 BY MR. KUVIN: 8 based on her Fifth Amendment. 8 Q. Ma'am. are you aware of the effect, the 9 THE WITNESS: On the instruction of my 9 emotional effect on the underage girls that have 10 lawyer, I must invoke my Fifth Amendment right. 10 been abused by Jeffrey Epstein? Are you aware of 11 BY MR. KUVIN: 11 the emotional effect that it's had on the underage 12 Would you agree with me that 12 that have been abused by Jeffrey Epstein? 13 • was under the age of 16 when this 13 girls MR. Objection to the form as 14 photograph was taken in Exhibit 9? 14 to. again, the question assumes this wimess 15 MR. : Objection to the form as 15 has any knowledge, first, of Jeffrey Epstein, 16 compound and also assuming this witness has any 16 second that Jeffrey Epstein has sexually abused 17 18 knowledge that the rson in the photograph is, in fact, Therefore. I would 17 18 anyone ever, and third, that anyone has been damaged by anything that Jeffrey Epstein has 19 instruct her to invoke her Fifth Amendment 19 done, and fourth, that she would somehow have 20 privilege. 20 any knowledge of these people's emotional 21 THE WITNESS: On the instruction of my 21 situations. For all those reasons, the 22 lawyer, I must invoke my Fifth Amendment right. 22 question is ambiguous and compound. and I would 23 BY MR. KUVIN: 23 instruct her not to answer based on her Fifth 24 Q. Ma'am, is Jeffrey Epstein paying for your 24 Amendment. 25 attorney today? 25 THE WITNESS: Upon the instruction of my Page 74 Page 76 1 MR. I'll instruct the witness 1 lawyer, I must invoke my Fifth Amendment right. 2 not to answer based on her Fifth Amendment 2 BY MR. KUVIN: 3 privilege. 3 Q. Ma'am, do you have any regret for what 4 THE WITNESS: On the instruction of my 4 you've done? 5 lawyer, I must invoke my Fifth Amendment right. 5 MR. : Objection to the form. 6 BY MR. KUVIN: 6 That question is not designed to lead to 7 Q. Ma'am, is Jeffrey Epstein paying for you 7 discoverable evidence. It's meant solely for 8 to keep quiet with respect to the things he has done 8 the purpose of harassment, and I would instruct 9 to underage iris? 9 her not to answer. 10 MR. Objection to the form in 10 BY MR. KUVIN: 11 that it's ambiguous and compound, also assumes 11 Q. Ma'am, do you have any regrets for what 12 this witness has any knowledge at all of 12 Jeffrey Epstein has done through you in obtaining 13 Jeffrey Epstein, and therefore I am instructing 13 underage girls for sexual abuse? 14 her to invoke her Fifth Amendment privilege. 14 MR. : Same objection as the 15 THE WITNESS: On the instruction of my 15 previous question as well as that question is 16 lawyer, I must invoke my Fifth Amendment 16 now free to assume this witness has any 17 privilege. 17 knowledge at all of Jeffrey Epstein or 18 BY MR. KUVIN: 18 Jeffrey Epstein having abused any underage 19 Q. Ma'am, how much is Jeffrey Epstein paying 19 women or girls or anything else that 20 you to keep quiet with respect to things he's done 20 Jeffrey Epstein may ever have done. 21 to underage irls? 21 And therefore, since it assumes that 22 MR. Object to the form as 22 fact, I would instruct her not to answer 23 multiple compound questions, and it's again 23 based on her Fifth Amendment. 24 assuming this witness has any knowledge at all 24 BY MR. KUVIN: 25 of Jeffrey Epstein. Since the question 25 Q. Are you scared of Jeffrey Epstein? 19 (Pages 73 to 7 6) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 19 of 47 EFTA_00065336 EFTA01246482 Page 77 Page 79 1 MR. KUV1N: I'm sorry, you had to respond. 1 lawyer, and I must invoke my Fifth Amendment 2 I cut you off. 2 privilege. 3 THE WITNESS: Upon the instruction of my 3 BY MR. KUVIN: 4 lawyer, I must invoke my Fifth Amendment right. 4 Q. Do ou know who Les Wexner is? 5 BY MR. KUVIN: 5 MR. I'll instruct the witness 6 Q. Are ou scared of Jeffrey Epstein? 6 not to answer based on her Fifth Amendment 7 MR. Objection to the form in 7 privilege. 8 that it assumes this witness has ever met 8 THE WITNESS: On the instruction of my 9 Jeffrey Epstein in her life. Because it 9 lawyer, I must invoke my Fifth Amendment 10 assumes that, I would instruct her not to 10 privilege. 11 answer based on the Fifth Amendment. 11 BY MR. KUV1N: 12 THE WITNESS: On the instruction of my 12 Q. Do you know whether or not Mr. Epstein has 13 lawyer, I must invoke my Fifth Amendment right. 13 had a homosexual relationship with Les Wexner in the 14 BY MR. KUV1N: 14 past? 15 Q. Are you aware of Jeffrey Epstein's sexual 15 MR. Objection to the form in 16 obsession for children? 16 that it again assumes that this witness knows 17 MR. Same instructions as the 17 anything at all about Jeffrey Epstein or has 18 previous question. also objection to the 18 ever met Jeffrey Epstein in her life, and 19 question. It's not designed to lead to any 19 therefore. I would instruct her not to answer 20 discoverable evidence at all. It's simply 20 based on her Fifth Amendment privilege, and the 21 meant for harassment. 21 question is compound and ambiguous. 22 THE WITNESS: On the instruction of my 22 THE WITNESS: On the instruction of my 23 lawyer, I must invoke my Fifth Amendment 23 lawyer, I must invoke my Fifth Amendment 24 privilege. 24 privilege. 25 25 Page 78 Page 80 1 BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. At what point did you realize that 2 Q. Do you know the magician by the name 3 Jeffrey Epstein was sexually attracted to girls 3 David Cop. erfield? 4 under the a e of 18? 4 MR. : I'll instruct the witness 5 MR. Once again, the question 5 not to answer based on her Fifth Amendment 6 assumes this witness knows anything at all 6 right. 7 about Jeffrey Epstein, underage women, sexual 7 THE WITNESS: On the instruction of my 8 abuse of underage women, and she's not going to 8 lawyer, I must invoke my Fifth Amendment 9 answer any questions that assume that as a 9 privilege. 10 predicate. They are objectionable as ambiguous 10 BY MR. KUVIN: 11 and compound, and I instruct her not to answer. 11 Q. You are aware, are you not, that 12 THE WITNESS: On the instruction of my 12 David Copperfield has visited Jeffrey Epstein's home 13 lawyer, I must invoke my Fifth Amendment 13 in Palm Beach? 14 privilege. 14 MR. : Objection to the form as 15 BY MR. KUV1N: 15 it once again assumes she has some knowledge of 16 Q. Are you aware whether or not 16 Jeffrey Epstein, or whether he has a home in 17 Jeffrey Epstein has had any homosexual relationships 17 Palm Beach. Because those facts are implicit 18 in the past? 18 in the question, the question is ambiguous and 19 MR. Same objection as the 19 compound. I would instruct her not to answer 20 previous question. The question as stated 20 based on her Fifth Amendment. 21 assumes this witness has some knowledge of 21 THE WITNESS: On the instruction of my 22 Jeffrey Epstein. And since it assumes that 22 lawyer, I must invoke my Fifth Amendment 23 fact, it is ambiguous and it's compound. and I 23 privilege. 24 instruct her not to answer. 24 BY MR. KUVIN: 25 THE WITNESS: On the instruction of my 25 •. You are aware. are you not. that 20 (Pages 77 to 80) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 20 of 47 EFTA_00065337 EFTA01246483 Page 81 Page 83 1 David Copperfield and Jeffrey Epstein used to share 1 privilege. 2 for sexual -- for sex, iris under the age of 16? 2 THE WITNESS: On the instruction of my 3 MR. : Same objection as 3 lawyer, I must invoke my Fifth Amendment 4 previously stated to the last I don't know how 4 privilege. 5 many questions. This question again assumes 5 BY MR. KUVIN: 6 this witness knows Jeffrey Epstein, has any 6 Q. How many people did Jeffrey Epstein use to 7 knowledge of Jeffrey Epstein's life. And 7 help him bring minor females to his house in Palm 8 because it assumes that fact, there is an 8 Beach for sex? 9 underlying predicate it is ambiguous and 9 MR. Same objection as the 10 compound. I would instruct her not to answer. 10 previous question and I instruct her not to 11 THE WITNESS: On the instruction of my 11 answer. 12 lawyer, I must invoke my Fifth Amendment 12 THE WITNESS: On the instruction of my 13 privilege. 13 lawyer, I must invoke my Fifth Amendment 14 BY MR. KUVIN: 14 privilege. 15 Q. From the time you met Mr. Epstein, isn't 15 BY MR. KUVIN: 16 it true that he would arrange for underage girls. 16 Q. Do you agree that Jeffrey Epstein is a 17 girls under the age of 18. to have sex with every 17 child molester? 18 single day? 18 MR. That question is solely 19 MR. : Let me try this again. 19 intended to harass the witness and it's 20 Objection to the form. Any question you're 20 ambiguous as to what a child molester means, 21 going to ask her that assumes she knows 21 and you're asking for a legal conclusion and 22 Jeffrey Epstein, she's ever met Jeffrey 22 instruct her not to answer. 23 Epstein, she's ever seen Jeffrey Epstein, knows 23 BY MR. KUVIN: 24 where he lives, knows what he does, if it 24 Q. In your own o • inion. 25 assumes that as part of the question, I will 25 MR. I will again instruct her Page 82 Page 84 1 deem the question to be ambiguous and compound. 1 not to answer based on her Fifth Amendment 2 because you're asking her to admit as a 2 privilege as well as the question having no 3 predicate that she knows Mr. Epstein. As to 3 legitimate basis and will not lead to 4 any question like that. I am going to instruct 4 discoverable evidence. 5 her to take the Fifth Amendment on that basis. 5 THE WITNESS: On the instruction of my 6 So I would again instruct her to take the Fifth 6 lawyer, I must invoke my Fifth Amendment 7 Amendment as to that question. 7 privilege. 8 THE WITNESS: On the instruction of my 8 BY MR. KUVIN: 9 lawyer. I must invoke my Fifth Amendment 9 Q. Would you agree that Jeffrey Epstein is 10 privilege. 10 obsessed with undera e females? 11 MR. KUVIN: If you want to short circuit 11 MR. Objection to the form. 12 that, anytime I mention Jeffrey Epstein you can 12 It's ambiguous as to what you mean by 13 have a standing objection on that issue. I 13 "obsessed." I'll instruct the witness not to 14 have no roblem. 14 answer based on her Fifth Amendment privilege, 15 MR. Great. 15 because the question assumes knowledge of 16 BY MR. KUVIN: 16 Jeffrey Epstein. 17 Q. Can you explain. if you would, to a jury 17 THE WITNESS: On the instruction of my 18 how Mr. Epstein would access underage minor females 18 lawyer, I must invoke my Fifth Amendment 19 for sex eve da ? 19 privilege. 20 MR. The question is compound 20 BY MR. KUVIN: 21 in that it asks about Mr. Epstein every day. 21 Q. How would ou define the word "obsessed"? 22 underage females, and involves multiple 22 MR. You can answer that. 23 questions in the same question. and also based 23 THE WITNESS: I don't know. You like it a 24 on the standing objection. I would instruct her 24 lot. I don't know. -...25 not to answer based on her Fifth Amendment 25 21 (Pages 81 to 8 4) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 21 of 47 EFTA_00065338 EFTA01246484 Page 85 Page 87 BY MR. KUVIN: 1 lawyer, I must invoke my Fifth Amendment 2 Q. Okay. Using your definition of obsessed, 2 privilege. 3 would you agree with me that Jeffrey Epstein was 3 BY MR. KUVIN: 4 obsessed with undera e females? 4 Q. Did you keep a journal with the names of 5 6 MR. Same objection; same instruction. 5 6 girls in it in the ear 2005? MR. : Objection to the form as 7 THE WITNESS: On the instruction of my 7 ambiguous. What do you mean by "journal"? 8 lawyer, I must invoke my Fifth Amendment 8 MR. KUVIN: I will define it. 9 privilege. 9 MR. : Please. 10 BY MR. KUVIN: 10 BY MR. KUVIN: 11 Q. When was the first time that you learned 11 Q. Did you keep a pad of paper. either a 12 Mr. Epstein was getting a massage from a girl under 12 ringed notebook or some other format with the names 13 the age of 16? 13 of girls and their one numbers in it in 2005? 14 MR. One second. 14 MR. : I'll instruct the witness 15 MR. KUVIN: Sure. 15 not to answer based on her Fifth Amendment 16 MR. I want to make the 16 privilege. Also the question remains 17 standing objection for the reasons previously 17 ambiguous. 18 stated, the question is otherwise also compound 18 THE WITNESS: On the instruction of my 19 in that it assumes multiple facts and asks her 19 lawyer, I must invoke my Fifth Amendment 20 to answer multiple questions at the same time. 20 privilege. 21 I'll instruct her not to answer based on her 21 BY MR. KUV1N: 22 Fifth Amendment. 22 Q. Would you agree with me that you kept a 23 THE WITNESS: On the instruction of my 23 pad of paper or a journal. however you want to 24 lawyer, I must invoke my Fifth Amendment 24 describe it, that contain the names of hundreds of 25 privilege. 25 underage girls and their phone numbers? i Page 86 Page 88 1 BY MR. KUVIN: 1 MR. Object to the form of the 2 Q. Do you know who owns the home at 358 2 question. It's compound and asking her to 3 El Brillo Wa '≥ 3 answer multiple questions at the same time. 4 MR. Same instructions as to 4 It's also leading, and I would instruct her not 5 the standing objection. 5 to answer based on her Fifth Amendment. 6 THE WITNESS: On the instruction of my 6 THE WITNESS: On the instruction of my 7 lawyer, I must invoke my Fifth Amendment 7 lawyer, I must invoke my Fifth Amendment right. 8 privilege. 8 BY MR. KUVIN: 9 BY MR. KUVIN: 9 Q. Would you agree with me that you kept a 10 Q. Have .ou been on Palm Beach Island before? 10 of notebook, or journal with the names of 11 MR. I am sorry. Can you 11 pad paper, hundreds of girls under the age of 16 so that you 12 restate the question? 12 could contact them and have them come to 13 MR. KUVIN: Sure. 13 Jeffrey Epstein's home for sex with him? 14 BY MR. KUVIN: 14 MR. : Objection to the form as 15 Q. Have you been on the Island of Palm Beach 15 compound and ambiguous, and I'll instruct her 16 before? 16 not to answer based on Fifth Amendment. 17 MR. You can answer that yes or 17 THE WITNESS: On the instruction of my 18 no. 18 lawyer, I must invoke my Fifth Amendment 19 THE WITNESS: Yes. 19 privilege. 20 BY MR. KUVIN: 20 BY MR. KUVIN: 21 Q. How man times? 21 Q. Do ou know Alfredo Rodriguez? 22 MR. I'll instruct her not to 22 MR. : I'll instruct the witness 23 answer that question based on her Fifth 23 not to answer based on her Fifth Amendment 24 Amendment privilege. 24 privilege. 25 THE WITNESS: On the instruction of my 25 THE WITNESS: On the instruction of my 22 (Pages 85 to 88) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 22 of 47 EFTA_00065339 EFTA01246485 Page 89 Page 91 1 lawyer, I must invoke my Fifth Amendment 1 prosecution by either the State or the federal 2 privilege. 2 government? 3 BY MR. KUVIN: 3 MR. : She's not answering that 4 Q. Are you aware that Alfredo Rodriguez has 4 question. She's not required to answer the 5 pled guilty to federal charges for hiding a journal 5 question. She's invoked her Fifth Amendment 6 containing the names of women? 6 privilege. She will continue to do so as to 7 MR. Objection to the form as 7 that question. You can move on. 8 compound and instruct her not to answer. 8 BY MR. KUVIN: 9 THE WITNESS: On the instruction of my 9 Q. Ma'am. are you invoking your Fifth 10 lawyer, I must choose to invoke my Fifth 10 Amendment because your lawyer is advising you to 11 Amendment privilege. 11 invoke your Fifth Amendment, or because you 12 BY MR. KUVIN: 12 personally have a fear that you might be prosecuted 13 Q. Do you have a personal fear of criminal 13 by either the state or the federal government? 14 prosecution as ou sit here today? 14 MR. : We have now been down thin 15 MR. I instruct the witness -- 15 street four times. She's not going to answer 16 object to the form. That's the whole basis why 16 the question. You can move along or we can 17 one would invoke the Fifth Amendment so clearly 17 leave. 18 she's does. I am not going to have her answer 18 MR. KUVIN: I am just clarifying the 19 the question. It's solely meant to harass. 19 question. and I appreciate it. And you can 20 MR. KUVIN: So is she not going to answer 20 object. I just want to make sure that I have a 21 that question? 21 clear record of every possible machination of 22 MR. She's not going to answer 22 the question so that I don't get hit later with 23 that question. 23 you didn't ask the specific question you need 24 MR. KUVIN: I think what I need to 24 to ask. So. I'm not doing it certainly to 25 establish is that she personally has a fear, 25 harass. I just want to make sure that the Page 90 Page 92 1 not her lawyer. So I would like to establish 1 record is ve clear of my question. 2 whether the witness has a personal fear. 2 MR. I understand. You can 3 MR. Well, first of all, under 3 move on. 4 the Fifth Amendment you don't have to be in 4 BY MR. KUVIN: 5 fear. You just have to believe that the 5 Q. Ma'am, have you had any direct 6 government believes you can be prosecuted for 6 communications with the State Attorney's office in 7 something. She's been invoking the Fifth 7 the last two ears? 8 Amendment on her own. It is implicit in her 8 MR. When you say "direct 9 invocation in what she fears. She's not going 9 communications," can you clarify? 10 to answer that question. 10 MR. KUVIN: Yes. 11 MR. KUVIN: Well, I tend to disagree. She 11 BY MR. KUVIN: 12 hasn't been invoking it on her own. She's been 12 Q. You, personally, have you spoken with 13 invoking it after you have instructed her to 13 anyone in the State Attorney's office in the last 14 invoke it. So I want to know her personal -- 14 two years? 15 MR. : You can take that up with 15 MR. KUVIN: I can't imagine there would be 16 the judge then. She's not answering the 16 a Fifth Amendment for that. 17 question. She's invoking her Fifth Amendment 17 MR. Let me consult. If I 18 on her own accord based on the advice of her 18 might. Okay? 19 lawyer. And you can take it up somewhere else, 19 MR. KUVIN: Sure. 20 but she's not answering that question. 20 MR. It would all depend on 21 MR. KUVIN: Well, then let me clarify the 21 what was said to her if she could consult with 22 record. 22 them now. For example, if they consulted and 23 BY MR. KUVIN: 23 they told her they were about to prosecute, 24 Q. Ma'am. are you invoking your Fifth 24 then there could be a Fifth Amendment claim, 25 Amendment because you personally have a concern of 25 couldn't there? 23 (Pages 89 to 92) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 23 of 47 EFTA_00065340 EFTA01246486 Page 93 Page 95 1 MR. KUVIN: No, not as to the statements 1 Q. Have you spoken with anybody at the U.S. 2 they told her. I mean. that's certainly not 2 Attorney's Office in the last five years? 3 Fifth Amendment. That's something that was 3 A. No. 4 told to her. 4 Q. Have you spoken with anyone at the FBI in 5 MR. : We'll take that up 5 the last five years? 6 elsewhere if you need to. You can answer. 6 A. No. 7 MR. KUVIN: Okay. 7 Q. Have you spoken with anyone at the 8 THE WITNESS: No, I have not. 8 Palm Beach Police De .artment in the last five years? 9 BY MR. KUVIN: 9 MR. : When you say, "the Palm 10 Q. All right. Ma'am. have you had any 10 Beach Police," for any purpose or as related to 11 personal communications with anyone working for the 11 this case? Again, for example. if there was 12 federal government in the last two years? 12 like a parking ticket -- 13 MR. : When you say "the federal 13 MR. KUVIN: Sure. 14 government" do you mean the postal service, the 14 MR. : -- or some other thing. I 15 entire federal government, or do you want to 15 want to clarify that. 16 clarify that? 16 BY MR. KUVIN: 17 MR. KUVIN: Well. I certainly could leave 17 Q. Let's, let's start with broad, and we can 18 it open-ended. If she's talked to a post 18 work to specific. Can you recall having any 19 office employee, that would be interesting, but 19 conversations for any reason with the Palm Beach 20 certainly not to this case. 20 Police Department in the last five years? 21 BY MR. KUVIN: 21 A. No. 22 Q. Let's talk about the U.S. Attorney's 22 Q. Okay. Do you have knowledge whether or 23 Office or anyone working on behalf of the U.S. 23 not the Palm Beach Police Department ever requested 24 Attorney's Office. 24 for you to come in for an interview at any time in 25 A. Have I personally ever spoken to anyone? 25 the last five years? Page 94 Page 96 1 Q. Yes, ma'am, personally have you ever had 1 MR. : If you know the answer tc 2 any conversations with anyone at the U.S. Attorney's 2 that question because that's something your 3 Office or one of their -- one -- a person 3 attorney told you, you don't have to answer 4 representing to be from that office in the last two 4 that question. Otherwise, go ahead and answer. 5 years. 5 THE WITNESS: No. 6 A. No. 6 BY MR. KUVIN: 7 Q. Okay. Do you know, as you sit here today, 7 Q. Okay. When did you first retain an 8 whether or not you ever were requested to give a 8 attorney? What date did you first retain a -- I 9 statement by the State Attorney's office for the 9 mean, let me clarify. What date did you first 10 Palm Beach Police De 'ailment? 10 retain a criminal attorne ? 11 MR. : May I consult? 11 MR. : I'll instruct her not to 12 MR. KUVIN: Yes. 12 answer based on the Fifth Amendment privilege. 13 MR. : You may answer. And for 13 THE WITNESS: On the instruction of my 14 the record. I was just determining whether the 14 lawyer, I must invoke my Fifth Amendment 15 answer to that question would be protected by 15 privilege. 16 the attorney-client privilege. 16 BY MR. KUVIN: 17 MR. KUVIN: Understood. 17 Q. Did you first retain a criminal attorney 18 THE WITNESS: No, I don't. I don't know. 18 in the year 2005? 19 BY MR. KUVIN: 19 MR. : Same instruction. 20 Q. Let me clarify the last two questions I 20 THE WITNESS: On the instruction of my 21 asked about the State Attorney's Office and the U.S. 21 lawyer, I must invoke my Fifth Amendment 22 Attorney's Office. Have you spoken with anybody 22 privilege. 23 personally at the State Attorney's Office in the 23 BY MR. KUVIN: 24 last five years? 24 Q. Did you retain a criminal attorney in 25 A. No. 25 2004? 24 (Pages 93 to 9 6) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 24 of 47 EFTA_00065341 EFTA01246487 Page 97 Page 99 1 MR. Same instruction. 1 assumes facts that have not been established 2 THE WITNESS: On the instruction of my 2 and it's compound. 3 lawyer, I must invoke my Fifth Amendment 3 THE WITNESS: On the instruction of my 4 privilege. 4 lawyer, I must invoke my Fifth Amendment 5 BY MR. KUVIN: 5 privilege. 6 Q. Have you ever worked as a professional 6 MR. : And to clarify the 7 model? 7 objection is that it assumes that she's ever 8 MR. May I consult? 8 met or knows anything about Jean-Luc Brunel. 9 MR. KUVIN: Sure. 9 BY MR. KUVIN: 10 MR. You can answer the 10 Q. Were you ever promised anything regarding 11 question. 11 your modelin career b Jeffrey Epstein? 12 THE WITNESS: Yes. 12 MR. : Same objection, instruct 13 BY MR. KUVIN: 13 the witness not to answer. 14 Q. When? 14 THE WITNESS: On the instruction of my 15 A. I don't remember. I don't remember the dates. 15 lawyer, I must invoke my Fifth Amendment 16 It was at least maybe ten years ago. 16 privilege. 17 Q. And ou're how old now? 13 BY MR. KUVIN: 18 MR. I'll instruct the witness 19 Q. You would agree with me that there is a 19 not to answer the question. Nice try. 19 financial arrangement between Jean-Luc Brunel and 20 Instruct not to answer based on 20 Jeffrey Epstein. doyou not? 21 you your Fifth Amendment privilege. 21 MR. : Objection. It assumes she 22 THE WITNESS: On the instruction of my 22 has any knowledge of either Mr. Epstein or 23 lawyer, I'm going to invoke my Fifth Amendment 23 Mr. Brunel. and as to that she is going to 24 privilege. 24 invoke her Fifth Amendment privilege. The 25 MR. KUVIN: I'm just trying to find out. 25 question is compound and therefore ambiguous. Page 98 Page 100 1 MR. Like I said, good try. 1 THE WITNESS: On the instruction of my 2 Move on. 2 lawyer, I must invoke my Fifth Amendment 3 BY MR. KUVIN: 3 privilege. 4 Q. With respect to your work as a 4 BY MR. KUVIN: 5 professional model. what company did you work for? 5 Q. Would you agree with me that 6 MR. Instruct the witness not 6 Ghislaine Maxwell provides underage girls to 7 to answer based on the Fifth Amendment 7 Mr. Epstein for sex? 8 privilege. 8 MR. Objection to the font. It 9 THE WITNESS: On the instruction of my 9 assumes she knows anything at all about 10 lawyer, I invoke my Fifth Amendment privilege. 10 Ghislaine Maxwell and asks her to assume that 11 BY MR. KUVIN: 11 she does, and therefore it is compound and 12 Q. What is your understanding of 12 ambiguous, and I would instruct her not to 13 Mr. Epstein's involvement with the modeling 13 answer. 14 industry? 14 THE WITNESS: Upon the instruction of my 15 MR. Standing objection, and 15 lawyer, I must invoke my Fifth Amendment 16 instruct the witness not to answer based on 16 privilege. 17 Fifth Amendment, on that basis. 17 MR. KUVIN: That's a good point. Take a 18 THE WITNESS: Upon the instruction of my 18 look at what we'll mark as Exhibit 10. 19 lawyer, I must invoke my Fifth Amendment 19 (Plaintiff's Exhibit No. 10 was marked for 20 privilege. 20 identification.) 21 BY MR. KUVIN: 21 MR. KUVIN: All me to show it to the 22 Q. Were you ever promised anything regarding 22 camera first. 23 24 your modelin career b Jean-Luc Brunel? MR. . Instruct the witness not 23 24 MR. MR. KUVIN: Okay. Okay. 25 to answer based on Fifth Amendment. also 25 THE WITNESS: Okay. 25 (Pages 97 to 100) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 25 of 47 EFTA_00065342 EFTA01246488 Page 101 Page 103 1 BY MR. KUVIN: 1 You're asking the witness three 2 Q. Take a look at what we marked as Exhibit 2 questions at the same time, and I would 3 10. Do you recognize the two people in that 3 instruct her not to answer based on the 4 photograph? 4 Fifth Amendment. 5 MR. : I'll instruct the witness 5 THE WITNESS: On the instruction of my 6 not to answer based on her Fifth Amendment 6 lawyer, I must invoke my Fifth Amendment 7 privilege. 7 privilege. 8 THE WITNESS: On the instruction of my 8 MR. KUVIN: Just so we're clear, had she 9 lawyer, I must invoice my Fifth Amendment 9 answered the first two questions, then 10 privilege. 10 obviously I wouldn't have to ask the third one 11 BY MR. KUVIN: 11 that has all of them in it but -- 12 Q. Would you agree with me that's 12 MR. : If you had accepted her 13 Ghislaine Maxwell on the right and Jeffrey Epstein 13 answer, you would have known that she wasn't 14 on the left? 14 going to answer these, and we could have saved 15 MR. : Objection to the form. It 15 a few minutes. 16 assumes that she knows who Ghislaine Maxwell 16 MR. KUVIN: And as you well know, I must 17 and Jeffrey Epstein are, and therefore it's 17 ask the question in order to gain the inference 18 compound and ambiguous, and I would instruct 18 at trial. 19 her not to answer. 19 MR. : I understand. 20 THE WITNESS: On the instruction of my 20 MR. KUVIN: All right. 21 lawyer, I must invoke my Fifth Amendment 21 (Plaintiff's Exhibit No. 12 was marked for 22 privilege. 22 identification.) 23 MR_ KUVIN: Okay. I will mark this as 23 BY MR. KUVIN: 24 Exhibit II. 24 Q. Do you recognize the gentleman that is 25 25 shown -- Page 102 Page 104 1 (Plaintiff's Exhibit No. II was marked for 1 MR. We'll have a job here. 2 identification.) 2 MR. KUVIN: That is true. 3 BY MR. KUVIN: 3 BY MR. KUVIN: 4 Q. Let me show you what we marked as 4 Q. -- that is shown in Exhibit 12? 5 Exhibit II. Han on one second. 5 MR. KUVIN: Let me hold this for the 6 MR. Sure. BY MR. KUVIN: 6 7 camera first. 7 MR. I'm sorry. Is there a 8 Q. Do you recognize the young lady shown in 8 question pending? 9 Exhibit II? 9 MR. KUVIN: Yes. 10 MR. I'll instruct the witness 10 BY MR. KUVIN: 11 not to answer based on her Fifth Amendment 11 Q. Do you recognize the gentleman shown in 12 privilege. 12 Exhibit 12? 13 THE WITNESS: On the instruction of my 13 MR. I instruct her not to 14 lawyer. I must invoke my Fifth Amendment 14 answer based on the Fifth Amendment. 15 privilege. 15 THE WITNESS: On the instruction of my 16 BY MR. KUVIN: 16 lawyer, I must invoke my Fifth Amendment 17 Q. Do you agree with me that the young girl 17 privilege. 18 shown in Exhibit II was recruited by Ghislaine 18 BY MR. KUVIN: 19 Maxwell to, for sexual activity with 19 Q. Would you agree with me that that is 20 Jeffrey Epstein? 20 Prince Andrew shown in Exhibit 12? 21 MR. Objection to the form. It 21 MR. Same instruction. 22 assumes she knows who the person is in Exhibit 22 THE WITNESS: On the instruction of my 23 II. and assumes she knows who Ghislaine Maxwell 23 lawyer, I must invoke my Fifth Amendment 24 is. and assumes she knows who Jeffrey Epstein 24 privilege. 25 is. and is therefore compound. 25 26 (Pages 101 to 104) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 26 of 47 EFTA_00065343 EFTA01246489 Page 105 Page 107 1 BY MR. KUVIN: 1 break now. 2 Q. Would you agree with me that you have been 2 MR. KUVIN: Okay. 3 present where Jeffrey Epstein and Prince Andrew have 3 THE VIDEOGRAPHER: We're now off video 4 had sexual relations with underage girls? 4 record. The time is 11:57 a.m. 5 MR. Objection to the form, 5 (A luncheon recess was held.) 6 it's compound in that it assumes she knows who 6 (Plaintiffs Exhibit No's 4 was marked for 7 the person is in Picture 12. she knows who 7 identification.) 8 Prince Andrew is, and she knows who Jeffrey 8 (Plaintiffs Exhibit No. 5 was marked for 9 Epstein is. It's compound and ambiguous, and 9 identification.) 10 I'll instruct her not to answer based on her 10 THE VIDEOGRAPHER: We're now on video 11 Fifth Amendment. 11 record. The time is 1:02 p.m. 12 THE WITNESS: On the instruction of my 12 MR. KUVIN: All right, counsel. I'm going 13 lawyer, I must invoke my Fifth Amendment 13 to ask a couple more general questions, and 14 privilege. 14 then when we get into the specifics of the 15 BY MR. KUVIN: 15 individual girls. I just want to make sure, 16 Q. Would you agree with me that Prince Andrew 16 once again, on the record, as we've done in 17 and Jeffrey Epstein used to share underaged girls 17 every deposition in this case, that we'll use 18 for sexual relations? 18 the Plaintiffs full name with the 19 MR. Same objection previously 19 understanding that the final transcript will 20 stated, requires her to also speculate who 20 only contain their initials, and there will be 21 Prince Andrew is. I instruct her not to answer 21 a key at the conclusion that's only provided to 22 based on the Fifth Amendment. 22 the parties in this case and their counsel to 23 THE WITNESS: On the instruction of my 23 be kept confidential going forward. But 24 lawyer, I must invoke my Fifth Amendment 24 obviously, for the purposes of this deposition, 25 privilege. 25 we will be using full names. Page 106 Page 108 1 MR. Also requires speculation 1 MR. Agreed. 2 as to who Jeffrey Epstein is as well. 2 MR. KUVIN: Okay. Is there any 3 BY MR. KUVIN: 3 disagreement with that around the table? 4 Q. Do ou know who Prince Andrew is? 4 MR. HOROWITZ: Agreed. 5 MR. • I'll instruct her not to 5 MR. WEISSING: Agreed. 6 answer based on the Fifth Amendment. 6 MS. EZELL: Agreed. 7 THE WITNESS: On the instruction of my 7 MR. KUVIN: Jack, do you agree to the -- 8 lawyer. I must invoke my Fifth Amendment 8 MR. GOLDBERGER: I thought I'm not a pan 9 privilege. 9 of it. 10 MR. KUVIN: It's almost 12:00. Do you 10 MR. KUVIN: Well, you've been playing a 11 want to take a uick lunch? 11 pan, so I want to make sure you agree. 12 MR. Sure. How much longer do 12 MR. GOLDBERGER: Yeah. I agree. I agree. 13 you think you will be. Mr. Kuvin, before we go 13 MR. : Hold on. Let me just 14 on to other counsel? 14 explain to her what we're talking about. 15 MR. KUVIN: Probably not that much longer. 15 MR. KUVIN: Please do. 16 MR. Okay. 16 MR. : But when the transcript is 17 MR. KUVIN: I have to get through a couple 17 typed up, it won't have her name it will just 18 of more generic stuff, and then get into the 18 have initials. But we'll get a code that 19 specifics of m cases and then -- 19 explains the name. So that way you would be 20 MR. Okay. So. we. but just so 20 asked if you recognize the name not a set of 21 we have a sense of planning whether this is the 21 initials that you may not understand or a Jane 22 right time for a lunch break. You're not going 22 Doe number that you do not know. 23 to finish in the next 15 or 20 minutes? 23 MR. KUVIN: That's way too confusing. 24 MR. KUVIN: No. not even close. 24 Okay? 25 MR. Okay. Let's take a lunch 25 MR. Correct. 27 (Pages 105 to 108) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 27 of 47 EFTA_00065344 EFTA01246490 Page 109 Page 111 BY MR. KUVIN: 1 objection to the form. 2 Q. Let's take a look at what Tve marked -- 2 THE WITNESS: At the instruction of my 3 premarked as Exhibit 4. It's a stack of documents, 3 lawyer, I must invoke my Fifth Amendment 4 just so you understand what this is and your 4 privilege. 5 attorney can object or agree or disagree as he sees 5 BY MR. KUVIN: 6 fit, but this is a stack of documents that was part 6 Q. Yes. Do 7 of the trash pull from Jeffrey Epstein's home as 7 MR. Instruct the witness not 8 part of the criminal investigation. Just so you're 8 to answer the question based on her Fifth 9 aware of what these are. 9 Amendment privilege. 10 MR. That was retrieved, that 10 THE WITNESS: On the instruction of my 11 was retrieved by the Palm Beach Police 11 lawyer, I must exercise my Fifth Amendment 12 Department from the trash -- 12 privilege. 13 MR. KUVIN: That's correct. 13 BY MR. KUVIN: 14 MR. : -- at the home of what is 14 Q. Will you agree with me that on the first 15 known to be Mr. Epstein's home? 15 page of Exhibit 4, you were to arrange for roses to 16 MR. KUVIN: Correct. 16 be delivered to Jane Doe No. 103 at her high school 17 MR. : Okay. 17 performance? 18 MR. KUVIN: All right. And that's not a 18 MR. Objection to the form. 19 question. I just wanted to kind of give you a 19 It's compound in that it assumes this is the 20 context for what I'm going to be asking you 20 witness's handwriting and assumes the witness 21 about. 21 knows a person by the name of Jane Doe No. 103 22 MR. Thank you. 22 and the witness otherwise knows Jeffrey Epstein 23 BY MR. KUVIN: 23 whose name is at the bottom of the paper, and 24 Q. All right. In taking a look at Exhibit 4, 24 therefore, it's compound and ambiguous, and 25 I'd like you to take a look at the front page, the 25 instruct her not to answer. Page 110 Page 112 1 first page of those documents. 1 THE WITNESS: On the instruction of my 2 3 Is that our handwriting, ma'am? MR. : Instruct the witness not 2 3 lawyer, I must exercise my Fifth Amendment right. 4 to answer based on the Fifth Amendment 4 MR. KUVIN: I forgot to mention this at 5 privilege. 5 the beginning, but objection to form usually 6 THE WITNESS: At the instruction of my 6 covers all that stuff like vague and compound, 7 lawyer, I must exercise my Fifth Amendment 7 and -- 8 right. 8 MR. : Okay. 9 BY MR. KUVIN: 9 MR. KUVIN: --I'll leave it up to you, 10 Q. And, in fact, that is your handwriting on 10 but objection to form as far as the civil arena 11 this notepad is it not? 11 context will cover all of those. 12 MR. Same instruction. It's 12 MR. : Just figured I'd make the 13 the same question. 13 record clear in case we ever have an issue, or 14 THE WITNESS: On the instruction of my 14 in case you want to correct it based on what I 15 lawyer, I must invoke my Fifth Amendment right. 15 believe to be the improper form. I will give 16 BY MR. KUVIN: 16 you a chance to correct it. 17 Q. In this note do you agree that you 17 BY MR. KUVIN: 18 arranged for an extension of one month on the rental 18 Q. No problem. All right. On Page 2 of 19 car for a lad under the age of 16? 19 Exhibit 4, if you'd take a look at that. Is that 20 MR. Objection to the form. It 20 your handwritin ? 21 is compound. It assumes that this is her 21 MR. : Instruct the witness not 22 handwriting. It doesn't identify who the 22 to answer based on the Fifth Amendment 23 lady might be, and it's otherwise ambiguous, so 23 privilege. 24 I instruct her not to answer on the Fifth 24 THE WITNESS: On the instruction of my 25 Amendment privilege in addition to the legal 25 lawyer. I choose to exercise my Fifth Amendment 28 (Pages 109 to 112) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 28 of 47 EFTA_00065345 EFTA01246491 Page 113 Page 115 1 right. 1 MR. Okay. I would be happy 2 BY MR. KUVIN: 2 to. 3 Q. Do you know who Larry is, as referred to 3 MR. KUVIN: I just want to clarify, 4 in Page 2 of Exhibit 4? 4 because I don't think -- 5 MR. I'm sorry. Can you -- 5 MR. Okay. 6 BY MR. KUVIN: 6 MR. KUVIN: I don't think this is a 7 Q. Do ou know who -- 7 problem but I 'ust want to clear it up. 8 MR. -- restate the question? 8 MR. Thank you, Mr. Kuvin. 9 BY MR. KUVIN: 9 I'll let her answer that question. 10 Q. Do you know who Larry is as referred to in 10 MR. KUVIN: Not a problem. 11 Page 2 of Exhibit 4? 11 MR. So the question pending 12 MR. So, just so I'm clear. 12 is, is that your handwriting? 13 what the question is, the document on its face 13 MR. KUVIN: Correct. 14 has the name Larry in it. You're just asking 14 BY MR. KUVIN: 15 this witness whether she knows who this person 15 Q. Is this your handwriting? Just yes or no. 16 Larry is? 16 A. No. 17 MR. KUVIN: Correct. 17 Q. Okay. Thank you. All right. Let's look 18 MR. • Instruct the witness not 18 at Page 4 of Exhibit 4. All right. This one's a 19 to answer based on her Fifth Amendment 19 little different. Is this our handwriting? 20 privilege. 20 MR. Let me consult with her 21 THE WITNESS: On the instruction of my 21 again. 22 lawyer, I must invoke my Fifth Amendment right. 22 Okay. That's fine. You can answer 23 BY MR. KUVIN: 23 the question consistent with the 24 Q. Do you know why Larry was recommending 24 conversation we just had. 25 that Mr. Epstein leave? 25 THE WITNESS: No. Page 114 Page 116 1 MR. Objection to the form and 1 BY MR. KUVIN: 2 instruct the witness not to answer based upon 2 Q. Do you know who is as referred to 3 her Fifth Amendment privilege. 3 in this note of Pa _e 4 of Exhibit 4? 4 THE WITNESS: On the instruction of my 4 MR. : Instruct the witness not 5 lawyer, I must invoke my Fifth Amendment right. 5 to answer based on her Fifth Amendment 6 BY MR. KUVIN: 6 privilege. 7 Q. Would you agree with me that Larry was 7 THE WITNESS: On the instruction of my 8 calling to warn Mr. Epstein to leave town because he 8 lawyer, I must exercise my Fifth Amendment 9 was going to be arrested? 9 right. 10 MR. Objection to the form. 10 BY MR. KUVIN: 11 The question assumes facts that are not before 11 Q. All right. Let's look at Page 5, 12 her, and it requires her to speculate, and also 12 Exhibit 4. 13 implies that she knows anything at all about 13 Before we go to Page 5, rather, going 14 Jeffrey Epstein, so I will instruct her not to 14 back St aris 4 for a minute. Will you agree with me 15 answer. 15 that as referred to in Page 4 of Exhibit 4 16 THE WITNESS: On the instruction of my 16 is a girl that is under the age of 16? 17 lawyer, I wish to exercise my Fifth Amendment 17 MR. : Object to the form. You 18 right. 18 previously asked if she knew who was, 19 BY MR. KUVIN: 19 and she invoked her Fifth Amendment privilege. 20 Q. Take a look at Page 3 of Exhibit 4, 20 Since the new presumes that she does 21 please. Is that our handwriting? 21 know who is she is going to invoke her 22 MR. I'll instruct her not to 22 Fifth Amendment privilege upon my instruction. 23 answer based on the Fifth Amendment privilege. 23 MR. KUVIN: All right. Let's look at 24 MR. KUVIN: Before we do that, would you 24 Page 5. 25 consult with her? 25 MR. Let her answer. 29 (Pages 113 to 1 1 6) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 29 of 47 EFTA_00065346 EFTA01246492 Page 117 Page 119 1 MR. KUVIN: I'm sorry. go ahead. 1 that Page 5 of Exhibit 4 appears to be a receipt for 2 3 THE WITNESS: On the instruction of my lawyer. I must invoke my Fifth Amendment 2 3 books ordered MR. red throw h Amazon.com? : You can answer that yes or 4 privilege. 4 no. 5 BY MR. KUVIN: 5 THE WITNESS: It looks like a receipt from 6 Q. MI right. Take a look at Page 5, if you 6 Amazon. 7 would. Have you ever ordered anything. anything 7 BY MR. KUVIN: 8 yourself from Amazon.com? 8 Q. Okay. And did you place this order for 9 MR. • You're asking for herself 9 Jeffrey Epstein? 10 or anyone else if she has ever placed an order 10 MR. : Instruct the witness not 11 with Amazon.com for any reason? 11 to answer the question in that the question 12 MR. KUVIN: I am asking whether she 12 presumes that she knows who Jeffrey Epstein is. 13 personally has ever placed an order with a 13 and therefore, I instruct her not to answer. 14 compan called Amazon.com. 14 THE WITNESS: On advice of counsel. I must 15 MR. Yes or no. You can answer 15 invoke my Fifth Amendment privilege. 16 that. 16 BY MR. KUVIN: 17 THE WITNESS: Yes. 17 Q. Have you ever read the book identified in 18 BY MR. KUVIN: 18 Page 5 of Exhibit 4 called Slave Craft: Road Maps 19 Q. Okay. So you would agree with me that you 19 for Erotic Servitude - Principals. Skills and Tools? 20 know what Amazon.com is? 20 MR. : Instruct the witness not 21 A. Yes. 21 to answer based on her Fifth Amendment 22 Q. Okay. Now, have you ever placed an order 22 privilege. 23 through Amazon.com for things to be delivered at 23 THE WITNESS: On the instruction of my 24 358 El Brillo Wa ? 24 lawyer, I must choose to invoke my Fifth 25 MR. Instruct the witness to 25 Amendment right. Page 118 Page 120 1 invoke her Fifth Amendment privilege as to that 1 BY MR. KUVIN: 2 question. 2 Q. Did you ever see that book I just 3 THE WITNESS: On the instruction of my 3 described at the home of Jeffrey Epstein on 4 lawyer, I must invoke my Fifth Amendment 4 358 El Brillo Wa ? 5 privilege. 5 MR. : Objection to the form in 6 BY MR. KUVIN: 6 that it presumes she knows Jeffrey Epstein and 7 Q. Will ou a ree with me -- 7 has ever been to 358 El Brillo Way. So, I 8 MR. • I'm sorry. Mr. Kuvin, for, 8 instruct her not to answer based on the Fifth 9 for the record, the page. pages of this exhibit 9 Amendment. 10 are not numbered, but the page we're looking at 10 THE WITNESS: On the instruction of my 11 purports to be a receipt for an order from 11 lawyer. I must choose to invoke my Fifth 12 Amazon.com; is that correct? 12 Amendment right. 13 MR. KUVIN: Correct. I just want her to 13 BY MR. KUVIN: 14 establish foundation before I got into 14 Q. Have you ever seen the book, Training With 15 specifics. 15 Miss Abernathy: A Workbook for Erotic Slaves and 16 MR. No, but you referred to it 16 Their Owners, at the home of Jeffrey Epstein on 17 18 as Page 5, but they are not numbered, so I just wanted to make sure that were looking at the 17 18 358 El Brillo Wa ? MR. : Same objection and same 19 same page on the exhibit. 19 instruction as the previous question. 20 MR. KUVIN: That is true. I'm just trying 20 THE WITNESS: On the instruction of my 21 to establish foundation for the questions I'm 21 lawyer, I must choose to invoke my Fifth 22 about to ask her. 22 Amendment right. 23 MR. Understood. 23 BY MR. KUVIN: 24 BY MR. KUVIN: 24 Q. Have you ever read that book that I just 25 Q. All right. Ma'am. would you agree with me 25 described which is shown in Page S of Exhibit 4? 30 (Pages 117 to 120) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 30 of 47 EFTA_00065347 EFTA01246493 Page 121 Page 123 1 MR. Same instruction. 1 BY MR. KUVIN: 2 THE WITNESS: On the instruction of my 2 Q. This note, Page 9 of Exhibit 4, appears to 3 lawyer, I must choose to invoke my Fifth 3 state that is trying to move -- and then 4 Amendment right. 4 there's a blanked out name, for 11 then S BY MR. KUVIN: 5 could work at 6. Do you know anyone with the name 6 Q. Let's look at the sixth page of Exhibit 4, 6 M? 7 please. Is that your handwriting? 7 MR. If she knows anyone in the 8 A. No. 8 world by that name? 9 Q. All right. Let's look at Page 7. Is that 9 MR. KUVIN: Yeah. We could start with 10 your handwriting? 10 that. 11 A. No. 11 MR. I'm saying, in the 12 Q. Okay. Look at the next page which would 12 context, are you asking in the context of this 13 be Page 8. Is that your handwriting? 13 note which you just read, or are you asking. 14 A. No. 19 generically, does she know anyone in the world 15 Q. Let's see how much quicker this goes. 15 by the name of ? 16 Let's look at Page 9. Is that your handwriting? 16 MR. KUVIN: Why don't we rust do it in 17 A. No. 17 the context of this note. 18 Q. Look at Pa e 9 a ain, if you would. 18 BY MR. KUVIN: 19 MR. • When you say Page 9, 19 Q. Is this note referring to you when it 20 that's the page that purports to say 10:00. 20 says,' "? 21 MR. KUVIN: Dr. Bard. 21 MR. : Instruct the witness not 22 MR. -- Dr. Bard at the top? 22 to answer based on her Fifth Amendment 23 MR. KUVIN: Correct. 23 privilege. 24 MR. Okay. 24 THE WITNESS: On the advice of counsel. I 25 25 must invoke my Fifth Amendment right. Page 122 Page 124 1 BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. Doyou know who Dr. Bard is? 2 In the context of this note, do you know 3 4 MR. Instruct the witness not to answer based on the Fifth Amendment, because 3 4 who is? MR. : Same instmction. 5 this sheet of paper has Jeffrey Epstein's name 5 THE WITNESS: On the advice of counsel, I 6 on the bottom, so the question implies that she 6 must invoke my Fifth Amendment right. 7 knows some connection between Dr. Bard and 7 BY MR. KUVIN: 8 Mr. Epstein. 8 Q. All ri t. Let's look at Page 10. 9 MR. KUVIN: Hang on a minute. Based on 9 MR. : Mr. Kuvin, let me go back 10 the objection, let me reword the question. 10 MR. KUVIN: Sure. 11 BY MR. KUVIN: 11 MR. : As to Page 1 of this 12 Q. Independent from this note and independent 12 exhibit. I think you had asked the witness 13 from anyone who may or may not be known as 13 whether this was her handwriting. 14 Jeffrey Epstein, do you know anyone by the name of 14 MR. KUVIN: Do you want to have her go 15 Dr. Bard? 15 back and answer? 16 A. I'm sorry. Ask the question again. 16 MR. : Yes, I would. Having 17 Q. Yes. I don't want you to assume anything 17 consulted with her further, I will have her go 18 from, the purpose of my question has anything to do 18 back to this question. 19 with someone who may be known as Jeffrey Epstein. 19 MR. KUVIN: Let's do that. I'll, I'll go 20 All I'm asking you is, generally, do 20 back and ask the question so that we can be 21 you know a rson b the name of Dr. Bard? 21 clear. 22 MR. Let me consult. 22 BY MR. KUVIN: 23 MR. KUVIN: Yes, yeah. 23 Q. On the Exhibit 4. the first page of 24 THE WITNESS: At the advice of counsel, I 24 Exhibit 4, ma'am. is that your handwriting? Yes or 25 must invoke my Filth Amendment right. 25 no. 31 (Pages 121 to 124) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 31 of 47 EFTA_00065348 EFTA01246494 Page 125 Page 127 1 A. No. 1 it in giving my advice, so thank you for 2 Q. Okay. All right. Let's skip Page 10. 2 clarifying. 3 because I think that's just a duplicate, and go to 3 MR. KUVIN: Absolutely. 4 Page 11, if ou would. 4 BY MR. KUVIN: 5 MR. : Page I 1 is -- 5 Q. All right. In Page II of Exhibit 4, 6 MR. KUVIN: It looks like DTG Operations, 6 there's a reference in the top right-hand comer. a 7 d/b/a Dollar Rent a Car. 7 message to a Mr. Goldsmith. Do you see that? 8 MR. : Got it. It's a printed 8 A. Uh-huh. 9 sheet, not a handwritten sheet. 9 Q. Yes? 10 MR. KUVIN: Correct. 10 MR. : You have to say yes or no 11 MR. : Okay. Thank you. 11 on the record. 12 BY MR. KUVIN: 12 THE WITNESS: Yes. I see it. 13 Q. All right. Do you know a gentleman by the 13 BY MR. KUVIN: 14 name of Janusz Banasiak, spelled J-a-n-u-s-z, 14 Q. Okay. All right. Do you know who 15 B-a-n-a-s-i-a-k? 15 Mr. Goldsmith is? 16 MR. : Instruct the witness not 16 MR. : I instruct the witness 17 to answer based on her Fifth Amendment 17 not to answer based on her privilege against 18 privilege. 18 self-incrimination. 19 THE WITNESS: On the instruction of, my 19 THE WITNESS: At the advice of counsel, I 20 lawyer, I must invoke my Fifth Amendment 20 must invoke my Fifth Amendment privilege. 21 privilege. 21 BY MR. KUVIN: 22 BY MR. KUVIN: 22 Q. Is this your handwriting on exhibit -- on 23 Q. Ma'am, isn't it true that you rented cars 23 the messages shown in Exhibit 4. Page II? 24 through Dollar Rent a Car for underage girls, girls 24 MR. : Same instruction. 25 under the age of 18? 25 THE WITNESS: At the advice of counsel, I Page 126 Page 128 1 MR. Instruct the witness not 1 must invoke m Fifth Amendment privilege. 2 to answer based on the Fifth Amendment 2 MR. : Hold on a second. In 3 privilege. 3 MR. KUVIN: Yeah, check. 4 THE WITNESS: On the instruction of my 4 MR. : Okay. Can you repeat the 5 lawyer, I must invoke the Fifth Amendment 5 question again? Maybe I misheard it. 6 privilege. 6 Mr. Kuvin. 7 BY MR. KUVIN: 7 MR. KUVIN: Yeah, not a problem. Let me 8 Q. Did you rent any can from Dollar Rent a 8 lay a little foundation for it. 9 Car in West Palm Beach in the last five years? 9 MR. : That's okay. If you can 10 MR. Same instruction. 10 just ask the question again. I think I just 11 THE WITNESS: On the instruction of my 11 misheard what you were asking. 12 lawyer, I must invoke my Fifth Amendment 12 BY MR. KUVIN: 13 privilege. 13 Q. Is this your handwriting shown on the 14 BY MR. KUVIN: 14 messages which is Page II of Exhibit 4? 15 Q. Let's take a look at Page II. 15 A. No. 16 MR. If we can just -- let me 16 . Oka . Is this handwriting that of 17 go back, Mr. Kuvin, to clarify the prior two 17 18 questions. When you say, "did you rent," did 18 MR. KUVIN: -- I'm sorry. 19 you mean did she personally pay for the rental, 19 =? How do you we it. . 20 or was she, in any way, involved in arranging 20 MS. CADWELL: . 21 the rental? 21 MR. KUVIN: I knew somebody would know. 22 MR. KUVIN: The second part, in any way 22 MR. : Did we get a 23 involved in arranging for the rental of a 23 pronunciation, I'm sorry? 24 vehicle. 24 MR. KUVIN: Yes. 25 MR. That's how I inter-Feted 25 32 (Pages 125 to 128) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 32 of 47 EFTA_00065349 EFTA01246495 Page 129 Page 131 1 BY MR. KUVIN: 1 appear to be directed -- well, let me. let me back 2 3 4 Q. this the handwriting of MR. if ou know? Hold on. Let me object to 2 3 4 up. Page 11 of Exhibit 4 appears to be a message dated October 2nd. 2005. from In Do you S the form in that it presumes she knows what 5 see that top left-hand corner? 6 handwriting is like or that she's 6 A. Yes. / ever known So before you ask the 7 Q. Okay. At 10:40 a.m. My question is: Did 8 question. try to clarify that. 8 you call and leave a message at 10:40 a.m. on 9 MR. KUVIN: Well, that's what I'm trying 9 October 2, 2005, stating: Mick and she 10 to find out. 10 can't come toda ? 11 BY MR. KUVIN: 11 MR. Instruct the witness not 12 13 O ourecognize this as the handwriting of And it can be a yes or no. . 12 13 to answer the question based on her Fifth Amendment privilege. 14 MR. My. my objection to the 14 THE WITNESS: On the instruction of my 15 form is that you, you haven't asked her whether 15 lawyer I must exercise my Fifth Amendment 16 she actually knows who is, or 16 privilege. 17 whether she would recognize her handwriting if 17 BY MR. KUVIN: 18 she saw it. 18 Q. Upside down at the bottom of Page I I is 19 MR. KUVIN: I would love to ask that 19 another phone message dated 10/1 of 2005. Appears 20 question if she'd answer it. 20 to be written to someone named M. Do you see 21 MR. Well, if she'll answer. 21 that? 22 that's a different question. But I think you 22 A. Yes. 23 need to ask it first otherwise this question is 23 Q. ou ambiguous. 24 MR. : Is it written. I'm sorry. 25 MR. KUVIN: All right. 25 is it written to someone named or it Page 130 Page 132 1 2 BY MR. KUVIN: Q. Not, not to beat a dead horse on the 1 2 to be a phone call is s from a person named . 3 point, do you know Mi 3 MR. KUVIN: From a person named 4 MR. I instruct the witness not 4 Thank you. 5 to answer. 5 BY MR. KUVIN: 6 THE WITNESS: On advice of counsel, I must 6 Q. Did you call someone, anyone on October 1 7 invoke my Fifth Amendment privilege. 7 of 2005 at 9:50 a.m., to confirm two people. one at 8 BY MR. KUVIN: 8 11:00 and one at 4:00 ..m.? 9 Q. Have you seen 9 MR. : Instruct the witness not 10 handwriting in the st? 10 to answer based on her Fifth Amendment 11 • MR. Objection to the form as 11 privilege against self-incrimination since this 12 previously stated. I'll instruct the witness 12 document was seized from Mr. Epstein's home. 13 not to answer. 13 THE WITNESS: At the instruction of my 14 THE WITNESS: On advice of counsel. I must 14 lawyer, I must invoke my Fifth Amendment 15 invoke my Fifth Amendment privilege. 15 privilege. 16 BY MR. KUVIN: 16 BY MR. KUVIN: 17 Q. Do you recd recognize Pa e 11 in Exhibit 4 as 1/ Q. Are you the that's referred to in 18 the handwriting of . 18 these phone messa es that we've been looking at? 19 MR. Objection to the form for 19 MR. Instruct the witness not 20 the reasons previously stated many, many times, 20 to answer. 21 and I will instruct her not to answer. 21 THE WITNESS: On the instruction of my 22 THE WITNESS: At the advice of counsel, I 22 lawyer, I must invoke my Fifth Amendment 23 must invoke my Fifth Amendment privilege. 23 privilege. 24 BY MR. KUVIN: 24 BY MR. KUVIN: 25 Q. Did you ever see these messages that 25 Q. Let's skip Page 12 and go to Page 13 of 33 (Pages 129 to 132) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 33 of 47 EFTA_00065350 EFTA01246496 Page 133 Page 135 1 this same exhibit, if you would. Okay. 1 Fifth Amendment right. 2 3 Is that your handwriting on Pa e 13 which happens to be a note stating s 2 3 BY MR. KUVIN: Q. Are you aware that Jeffrey Epstein would 4 coming"? 4 refer to "work" as performing naked massages for 5 MR. Okay. Hold on. Can you 5 him? 6 just show me what page you're looking at? 6 MR. : Object to the form of the 7 Okay. We skipped a page. 7 question. It's compound and I instruct the 8 THE WITNESS: No. 8 witness not to answer. 9 BY MR. KUVIN: 9 THE WITNESS: On advice of counsel. I wish 10 Q. Oka Doyou recognize whose it is? 10 to invoke my Fifth Amendment right. 11 . MR. Let me talk to you again. 11 BY MR. KUVIN: 12 BY MR. KUVIN: 12 Q. Let's take a look at the next page. Page 13 Q. If it's a yes, you might want to talk to 13 16. All right. If we look at not the message, the 14 him; if it's a no, it might be quick. 14 one message, but the note next to that it says: 15 A. No, no. Sony. 15 on Saturday with at 10:30. 16 Q. Let's look at Page 14, same exhibit. The 16 Do you know who is as referred 17 note on the right-hand side states, 'The girl from 17 to in this note? 18 St. Bart's got sick so she won't be able to come. 18 A. On the advice of counsel, I must invoke my 19 got message from her." First of all, just 19 Fifth Amendment right. 20 generally, do you see the note I'm referring to? 20 Q. Do you know who is as referred to in 21 A. Yes. 21 this note? 22 Q. Okay. Do you know what that is talking 22 A. On the advice of counsel. I must invoke my 23 about? 23 Fifth Amendment right. 24 A. No. 24 MR. GARCIA: I haven't heard the counsel 25 Q. Is that your handwriting? 25 give any advice. Page 134 Page 136 1 A. No. 1 MR. : You don't know what we've 2 Q. Did Mr. Epstein obtain girls under the age 2 talked about outside of the room so... 3 of 16 from St. Ban's? 3 MR. GARCIA: Just changing the procedure 4 MR. Instruct the witness not 4 is all? 5 to answer. Object to the form of the question 5 MR. : I'm changing the procedure 6 in that it presumes that she knows who 6 for Mr. Kuvin. 7 Mr. Epstein is. 7 MR. KUVIN: I'm all happy for speed. 8 THE WITNESS: On advice of counsel, I must 8 BY MR. KUVIN: 9 invoke my Fifth Amendment privilege. 9 Q. All right. Let's look at Page 17 of 10 BY MR. KUVIN: 10 Exhibit 4. It appears to be a phone message at the 11 Q. All right. Let's take a look at the next 11 bottom dated 9/1/05 to Jeffrey from Jean-Luc. Let 12 page. Appears to be a note, phone message of -- I 12 me ask this: Do you rec tze the . hone number 13 can't read the date, 2005 to Jeffrey from 13 that's listed there of 14 Just generally, do you see what I'm 14 MR. : Instruct the witness not 15 talking about so we're on the same page here? 15 to answer based on her Fifth Amendment 16 A. Yes. 16 privilege and self-incrimination. 17 Q. Okay. Do you know who is? 17 THE WITNESS: On advice of counsel. I must 18 A. On the advice of counsel, I wish to invoke my 18 invoke my Fifth Amendment right. 19 Fifth Amendment right. 19 MR. KUVIN: Let me show this one to the 20 Q. All right. The note appears to say: She 20 camera if I could. If you could focus on the 21 called again, if she could work any time Monday 21 bottom message for me. 22 through Friday. 22 THE VIDEOGRAPHER: I can't really read 23 Do you know what that message 23 that. 24 pertains to? 24 MR. KUVIN: Do I need to tilt it? 25 A. On advice of counsel. I wish to invoke my 25 THE VIDEOGRAPHER: I think you need to 34 (Pages 133 to 136) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 34 of 47 EFTA_00065351 EFTA01246497 Page 137 Page 139 1 bring the whole paper up closer. 1 Do you -- first of all, do you see 2 MR. KUVIN: Towards you? 2 that in front of you? Are we talking about the same 3 THE VIDEOGRAPHER: Yes, towards the lens 3 thing here? 4 MR. KUVIN: Just pass that up so we can 4 A. Yes. 5 get a good shot of the bottom message. 5 Q. Okay. Do you know who " " is 6 THE VIDEOGRAPHER: Up a little higher. 6 referring to in this note? 7 please. Let it focus. That's good. Go out. 7 MR. Instruct the witness not 8 Okay. 8 to answer based on her Fifth Amendment 9 MR. KUVIN: All right. Thank you veiy 9 privilege. 10 much. 10 THE WITNESS: On the instruction of my 11 BY MR. KUVIN: 11 lawyer, I must invoke my Fifth Amendment 12 Q. The message appears to read: 9/1/2005 to 12 privilege. 13 Jeffrey, 8:08, Jean-Luc. telephone. He has a 13 BY MR. KUVIN: 14 teacher for you to teach you how to speak Russian. 14 Q. Does your handwriting appear anywhere on 15 She is two times eight years old. not blonde. 15 Page 19 here -- 16 Lessons are free and you can have first today if you 16 A. On the — 17 call. Do you know what that message is referring 17 Q. -- on either note? 18 to? 18 A. On the advice of my lawyer. I must invoke my 19 MR. Instruct the witness not 19 Fifth Amendment privilege. 20 to answer the question. Object to the form of 20 Q. Is that your handwriting on the left in 21 the question because in that it presumes she 21 the note that I just read that says: 22 has knowledge of either Jeffrey or Jean-Luc or 22 11:00 am.? 23 that phone number. 23 MR. Same instruction. 24 THE WITNESS: On the advice of counsel, I 24 THE WITNESS: On the instruction of my 25 wish to invoke my Fifth Amendment right. 25 lawyer, I must invoke my Fifth Amendment Page 138 Page 140 1 BY MR. KUVIN: 1 privilege. 2 Q. Would you agree with me that this message 2 BY MR. KUVIN: 3 is a message from Jean-Luc, that he's providing a 3 Q. All right. Let's take a look at the next 4 I6-year-old irl to Jeffre Epstein? 4 page which is Page 20. Is that your handwriting on 5 MR. : Object to the form in that 5 this paper? 6 it calls for speculation and also assumes facts 6 MR. : Let me talk to her. 7 as to Mr. Jean-Luc and Mr. Epstein; therefore, 7 THE WITNESS: On the advice of my lawyer, 8 I instruct her to invoke her Fifth Amendment 8 I wish to invoke my Fifth Amendment privilege. 9 privilege. 9 BY MR. KUVIN: 10 THE WITNESS: On the instruction from my 10 Q. Is this a list of girls that were being 11 12 lawyer, I must invoke my Fifth Amendment privilege. 11 12 provided to Jeffre E rein for sex? MR. : Objection to the form, the 13 BY MR. KUVIN: 13 standing objection previously stated. I will 14 Q. Skip the next page if you would, and the 14 instruct the witness not to answer that 15 following page will be Page 19 of Exhibit 4. It 15 question. 16 should be two mess es. 16 THE WITNESS: On the instruction of my 17 MR. Show me what you're 17 lawyer, I must invoke my Fifth Amendment 18 looking at. 18 privilege. 19 MR. KUVIN: And the top left one says, 19 BY MR. KUVIN: 20 "Friday." 20 Q. Did Jeffrey Epstein not like girls that 21 MR. : Thank you. 21 had tattoos? 22 BY MR. KUVIN: 22 MR. : Objection to the form 23 Q. The message on the left-hand side that 23 based on the standing objection and the same 24 appears to be. have a date of 4/8/05 and a number 7 24 instruction. 25 written on it. It says: 11:00 a.m. 25 THE WITNESS: On the instruction of my 35 (Pages 137 to 140) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 35 of 47 EFTA_00065352 EFTA01246498 Page 141 Page 143 1 lawyer, I must invoke my Fifth Amendment 1 MR. Same instruction. 2 privilege. 2 THE WITNESS: On the advice of my lawyer. 3 BY MR. KUVIN: 3 I must choose to invoke my Fifth Amendment 4 Q. Did Jeffrey Epstein not like girls that 4 right. 5 had blonde hair? 5 BY MR. KUVIN: 6 7 MR. : Standing objection and the same instruction. 6 7 Q. Doyou know who is? MR. Same instruction. 8 THE WITNESS: On the instruction of my 8 THE WITNESS: On the advice of my lawyer. 9 lawyer, I must invoke my Fifth Amendment 9 I wish to invoke my Fifth Amendment privilege. 10 privilege. 10 BY MR. KUVIN: 11 BY MR. KUVIN: 11 Q. Do ou know who is? M. 12 Q. Take a look at the next page, if you 12 MR. Let me consult for a 13 would. This one. 13 second. 14 MR. : Thank you. 14 MR. KUVIN: Yep. 15 BY MR. KUVIN: 15 (A discussion was held off the record.) 16 Q. Is that your handwriting? 16 MR. Mr. Kuvin, I'm just asking 17 A. On instruction of my lawyer, I must invoke m) 17 you to clarify. Are you asking if she's ever 18 Fifth Amendment privilege. 18 heard the name of these people or whether she's 19 Q. Is this an additional -- on Page 21, is 19 actually ever met someone she knows to have 20 this an additional list of girls that were being 20 that name? 21 22 provided to Jeffre E stein for sex? MR. : I'm sorry. Did we change 21 22 MR. KUVIN: Second part, whether she knows someone personally by that name. I don't want 23 to a different page or the same page? 23 to know what somebody may have told her. 24 MR. KUVIN: The same page. 24 MR. Sure. 25 25 MR. KUVIN: Certainly not attorneys or Page 142 Page 144 1 BY MR. KUVIN: 1 anything like that. I want to know whether she 2 Q. Is this an additional list of girls that 2 has any 'ersonal knowledge of someone by the 3 were -- 3 name of 4 MR. : Thank you. 4 MR. : Okay. Based on our 5 BY MR. KUVIN: 5 conversation, she can answer or not answer the 6 Q. -- being provided to Jeffrey Epstein for 6 question. 7 sex? 7 THE WITNESS: On the advice of my lawyer, 8 MR. : Objection to the form. 8 I choose to invoke my Fifth Amendment right. 9 The same objection and the same instruction. 9 MR. KUVIN: Okay. It's like a 10 THE WITNESS: On the instruction of my 10 cough/sneeze. 11 lawyer, I must invoke my Fifth Amendment 11 MR. GARCIA: I tried to stifle it. but -- 12 privilege. 12 MR. GOLDBERGER: You got it all over me. 13 BY MR. KUVIN: 13 Just kidding. 14 Q.Sa 2. Note on flier , appears to 14 MR. GARCIA: You don't want to get this. 15 say: has a friend, • that would like 15 I've had if for a couple of days. 16 to work tonight. Do you know who is refer, 16 MR. KUVIN: What number are we on? 13. 17 referring to in that note? 17 That's why I always leave some with numbers 18 MR. : Instruct the witness not 18 still on there to show the picture to the 19 to answer based on the privilege against 19 camera. 20 self-incrimination. 20 Exhibit 13 will be pursuant to 21 THE WITNESS: On the advice of my lawyer, 21 confidentiality and the identities of the 22 I wish to assert my Fifth Amendment right. 22 girls involved in this case. 23 BY MR. KUVIN: 23 MR. As I presume the prior 24 Q. Do you know who is referring to in 24 questions were as well. 25 that note? 25 MR. KUVIN: Yes. Absolutely. This is 36 (Pages 141 to 1 4 4) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 36 of 47 EFTA_00065353 EFTA01246499 Page 145 Page 147 1 different because it's an exhibit. 1 in Exhibit 13 came to Mr. Epstein's home when she 2 MR. : Agreed. 2 was only 115 ears old? 3 MR. KUVIN: Okay. 3 MR. : Objection to the form 4 (Plaintiff's Exhibit No. 13 was marked for 4 based on the standing objection, also 5 identification 5 speculation as to any age and instruct the 6 MR. We're moving off of 6 witness not to answer. 7 Exhibit 12? 7 THE WITNESS: On the advice of my lawyer. 8 MR. KUVIN: Yes. 8 I must choose to exercise my Fifth Amendment 9 MR. I was looking at the next 9 right. 10 exhibit. 10 BY MR. KUVIN: 11 MR. KUVIN: We're done with the trash. 11 Q. Do you agree with me that when you 12 MR. : Okay. 12 arranged to have this girl come to Mr. Epstein's 13 BY MR. KUVIN: 13 home, that ou were aware that she was IS years old? 14 Q. Just take a look at Exhibit 13. Do you 14 MR. : Objection to the form. It 15 recognize the girl in that photograph? 15 is compound. It assumes facts that are not 16 A. On the advice of my lawyer, I must choose to 16 admitted by this witness, and it's ambiguous in 17 exercise my Fifth Amendment privilege. 17 that regard, and therefore I instruct her not 18 Q. Do you agree with me that that girl shown 18 to answer. 19 in that photo his ? 19 THE WITNESS: On the advice of my lawyer, 20 MR. : Objection to the form for 20 I must choose to exercise my Fifth Amendment 21 the reasons previously stated, causes her to 21 right. 22 speculate, and I instruct her not to answer 22 BY MR. KUVIN: 23 based on her Fifth Amendment privilege. 23 Q. Do you agree that when this girl was 24 THE WITNESS: On the advice of my lawyer, 24 brought to Mr. Epstein's home, that she performed a 25 I must choose to exercise my Fifth Amendment 25 massage on Mr. Epstein while he was naked? Page 146 Page 148 i privilege. 1 MR. Objection to the form, 2 BY MR. KUVIN: 2 standing objection. The question assumes that 3 Q. Do you agree with me that you arranged to 3 this witness has any knowledge of 4 have the girl shown in Exhibit 13 be brought to 4 Jeffrey Epstein or whether this person ever 5 Mr. Epstein's home for sex with Mr. Epstein? 5 came to Mr. Epstein's home. It is therefore 6 MR. : Objection to the form as 6 ambiguous, and I instruct her not to answer. t compound. and also the standing objection, and 7 THE WITNESS: On the instruction of my 8 instruct the witness not to answer. 8 lawyer, I must choose to exercise my Fifth 9 THE WITNESS: On the advice of my lawyer, 9 Amendment right. 10 I must choose to exercise my Fifth Amendment 10 BY MR. KUVIN: 11 privilege. 11 Q. Do you agree with me that this girl shown 12 BY MR. KUVIN: 12 in Exhibit 13 was 15 years old at the time she was 13 Q. Would you agree with me that the girl 13 asked by Jeffrey E stein to remove her clothes? 14 shown in Exhibit 13 did, in fact, come to 14 MR. Objection to the form. It 15 Mr. Epstein's home in 2005? 15 requires speculation and assumes facts relating 16 MR. : Same objection previously 16 to Mr. Epstein and events that may have 17 stated. It's compound as to the date, place, 17 occurred which this witness has no knowledge 18 person, and also presumes knowledge of 18 and has not admitted any knowledge. And I 19 Mr. Epstein, so I would instruct her not to 19 instruct her not to answer. 20 answer. 20 THE WITNESS: On advice of counsel I must 21 THE WITNESS: On the advice of my lawyer, 21 choose to exercise my Fifth Amendment right. 22 I must choose to exercise my Fifth Amendment 22 BY MR. KUVIN: 23 privilege. 23 Q. Do you agree that you described for the 24 BY MR. KUVIN: 24 girl as shown in Exhibit 13 -- bate way. her name 25 Q. Do you agree with me that the pin shown 25 is.. - - t h a t you described to M. how to set up 37 (Pages 145 to 1 48) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 37 of 47 EFTA_00065354 EFTA01246500 Page 149 Page 151 1 the massage table in Jeffrey Epstein's bathroom? 1 counsel, I must choose to invoke my Fifth 2 MR. : Objection to the form for 2 Amendment right. 3 the reasons previously stated, and instruct the 3 BY MR. KUVIN: 4 witness not to answer. 4 Q. Do yotagree with me that during the 5 THE WITNESS: On the advice of counsel, I 5 massage that M. was forced to give to Mr. Epstein. 6 must choose to exercise my Fifth Amendment 6 that he touched her between her legs? 7 right. 7 MR. : Objection to the form. It 8 BY MR. KUVIN: 8 is ambiguous including the term "forced." It 9 Q. Do you agree that you showed M. where 9 assumes facts that this witness has not 10 the massage oils are kept in Jeffrey Epstein's 10 admitted or that this witness has not 11 bathroom in his home? 11 acknowledged any personal knowledge and 12 MR. : Objection to the form in 12 instruct her not to answer. 13 that it assumes knowledge of Jeffrey Epstein, 13 THE WITNESS: On the instruction of my 14 knowledge that this person was ever at 14 lawyer, I must therefore invoke my Fifth 15 Jeffrey Epstein's home none of which is 15 Amendment right. 16 admitted or acknowledged by this witness, and 16 BY MR. KUVIN: 17 instruct the witness not to answer. 17 Q. Do ou agree with me that Mr. Epstein 18 THE WITNESS: On advice of counsel I must 18 touched between her legs? 19 choose to invoke my Fifth Amendment right. 19 MR. : Objection to the form and 20 BY MR. KUVIN: 20 the question presumes knowledge of 21 Q. Do you agree that you showed.., as 21 Jeffrey Epstein. Instruct the witness not to 22 shown in Exhibit 13. where Mr. Epstein kept the 22 answer. 23 vibrators in his bathroom at his house? 23 THE WITNESS: On the instruction of my 24 MR. : Same objection as stated 24 lawyer, I must choose to invoke my Fifth 25 to the previous question as to the form of the 25 Amendment right. Page 150 Page 152 1 question, and instruct the witness not to 1 BY MR. KUVIN: 2 answer. 2 Q. Do you agree with me that El. told 3 THE WITNESS: On advice of counsel, I must 3 Mr. Epstein to stop touching him there -- touching 4 choose to exercise my Fifth Amendment right. 4 her there? 5 BY MR. KUVIN: 5 MR. Same objection previously 6 Q. Do you agree with me that in 2005 you 6 stated to the last question and instruct the 7 knowingly provided ■., a 15-year-old girl, to 7 witness not to answer. 8 Mr. Epstein so that he could sexually abuse her? 8 THE WITNESS: On the instruction of my 9 MR. Objection to the form as 9 lawyer, I must invoke my Fifth Amendment right. 10 to it calling for a legal conclusion as to 10 BY MR. KUVIN: 11 assuming multiple facts, since therefore 11 Q. Do you agree with me that you have 12 compound and instruct the witness not to 12 personal knowledge that after telling Mr. Epstein to 13 answer. 13 stop touching her between her legs, Mr. Epstein 14 THE WITNESS: On advice of counsel, I must 14 apologized and then touched her again between her 15 choose to invoke my Fifth Amendment right. 15 legs? 16 BY MR. KUVIN: 16 MR. Objection to the form and 17 Q. Do you agree with me that M. was given 17 the standing objection previously stated as 18 to Mr. Epstein to alarm a naked massage of him 18 well as the question is compound and instruct, 19 while he touched ? 19 and ambiguous. and I instruct the witness not 20 MR. Objection to the form. 20 to answer. 21 Standing objection and other facts that are 21 THE WITNESS: On the instruction of my 22 assumed in the question to which this witness 22 lawyer, I must choose to exercise my Fifth 23 does not admit, and therefore the witness is 23 Amendment right. 24 instructed not to answer the question. 24 BY MR. KUVIN: 25 THE WITNESS: On the instruction of my 25 Q. Do you agree with me that Mr. Epstein 38 (Pages 149 to 152) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 38 of 47 EFTA_00065355 EFTA01246501 Page 153 Page 155 1 specifically targeted young underage girls that were 1 Mr. Epstein naked massa es? 2 economically disadvantaged for his own sexual 2 MR. Object to the form. It's 3 pleasure? 3 multiple layers of compound questioning, 4 MR. Objection to the form. 4 includes terms like "enterprise" that are 5 Several of the terms are ambiguous and it 5 ambiguous and may call for a legal conclusion 6 assumes knowledge of Mr. Epstein and his 6 that this witness is not competent to give. I 7 habits, and therefore, I instruct the witness 7 instruct the witness not to answer. 8 not to answer the question. 8 THE WITNESS: On the instruction of my 9 THE WITNESS: On the instruction of my 9 lawyer, I must choose to exercise my Fifth 10 lawyer, I must choose to exercise my Fifth 10 Amendment right. 11 Amendment right. 11 BY MR. KUVIN: 12 BY MR. KUVIN: 12 Q. Do you agree with me that there is a 13 Q. Do you agree with me that Mr. Epstein 13 staircase leading out of Mr. Epstein's kitchen in 14 would pay these girls 2 to $300 for this sexual 14 his home on Palm Beach? 15 massage? 15 MR. Objection to the form, 16 MR. Objection to the form. 16 presumes knowledge of Mr. Epstein or his home 17 Standing objection and assumes knowledge of 17 on Palm Beach. Instruct the witness not to 18 Mr. Epstein and his practices, so therefore, I 18 answer. 19 instruct the witness not to answer. 19 THE WITNESS: On the instruction of my 20 THE WITNESS: On the instruction of my 20 lawyer, I must choose to invoke my Fifth 21 lawyer, I must choose to invoke my Fifth 21 Amendment right. 22 Amendment right. 22 BY MR. KUVIN: 23 BY MR. KUVIN: 23 Q. Do you agree with me that when M. was 24 Q. Do you agree with me that you handed M. 24 brought to Mr. Epstein's bathroom, that he walked 25 $200? 25 out of the shower wearing a towel? Page 154 Page 156 1 MR. : Objection to the form, 1 MR. Objection to the form in 2 instruct the witness not to answer. 2 that it presumes knowledge of ... that Ms. 3 THE WITNESS: On the instruction of my 3 .. was ever at Mr. Epstein's home, that this 4 lawyer, I must choose to invoke my Fifth 4 witness knows anything about Mr. Epstein or his 5 Amendment right. 5 home; therefore, the question is compound and 6 BY MR. KUVIN: 6 ambiguous, and I instruct her not to answer. 7 Q. And just so we're clear, do you agree with 7 THE WITNESS: On the instruction of my 8 me that you handed ill. in 2005, $200 after she was 8 lawyer, I must choose to assert my Fifth 9 in the bathroom with Mr. Epstein at his home? 9 Amendment right. 10 MR. : Objection to the form. 10 BY MR. KUVIN: 11 The question_wsumes knowledge of a person by 11 Q. Do you know M.? 12 the name of M., therefore I instruct the 12 A. On the instruction of my lawyer, I must choose 13 witness not to answer the question. 13 to assert my Fifth Amendment privilege. 14 THE WITNESS: On the instruction of my 14 Q. Did you have . -- excuse me, strike 15 lawyer, I must choose to invoke my Fifth 15 that. Did you tell to come over to 16 Amendment right. 16 Mr. Epstein's home to ive Mr. Epstein a massage? 17 BY MR. KUVIN: 17 MR. Objection to the form. 18 Q. Do you agree with me that Mr. Epstein had 18 It's compound. Stand objection. standing 19 a plan -- let me rephrase that. 19 objection, sorry. Instruct the witness not to 20 Do you agree with me that Mr. Epstein 20 answer. 21 had an enterprise, a sexual enterprise, established 21 THE WITNESS: On the instruction of my 22 by which young girls would be brought to his home, 22 lawyer, I must choose to invoke my Fifth 23 introduced to you, where you would then set up a 23 Amendment right. 24 massage table. show them where the oils were, and 24 BY MR. KUVIN: 25 have these young, girls under the age of 18, give 25 Q. Did you introduce M. to Jeffrey Epstein? 39 (Pages 153 to 156) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 39 of 47 EFTA_00065356 EFTA01246502 1 Page 157 MR. Objection to the form, 1 Page 159 BY MR. KUVIN: 2 standing objection. Instruct the witness not 2 Q. Would you agree with see that you visited 3 to answer. 3 a man by the name of Jeffrey Epstein while he was in 4 THE WITNESS: On the instruction from my 4 jail in Palm Beach Count ? 5 lawyer, I must choose to invoke my Fifth 5 MR. : Objection to the form, 6 Amendment right. 6 standing objection. Assumes other facts that 7 BY MR. KUVIN: 7 this witness has not acknowledged, and instruct 8 Q. Do ou agree with me that Mr. Epstein 8 her not to answer. 9 threatened with h sical violence? 9 THE WITNESS: Upon instruction from the 10 MR. Objection to the form, the 10 lawyer, I must choose to invoke my Fifth 11 standing objection, as well as ambiguous as to 11 Amendment right. 12 the term "threaten." Instruct the witness not 12 BY MR. KUVIN: 13 to answer. 13 Q. Do you agree that you arranged to have 14 THE WITNESS: Upon instruction from my 14 come to Jeffrey Epstein's home for a nude 15 lawyer, I must choose to invoke my Fifth 15 massage? 16 Amendment right. 16 MR. Objection to the form. 17 BY MR. KUVIN: 17 standing objection previously stated. 18 OI Do you agree with me that Jeffrey Epstein 18 THE WITNESS: On the instruction of my 19 told M. that if she talks to anyone about what had 19 lawyer, I must choose to invoke my Fifth 20 occurred at his home, bad things would happen to 20 Amendment right. 21 her? 21 BY MR. KUVIN: 22 MR. Objection to the form, 22 Q. Do you agree that has been to 23 24 it's compound, and a standing objection. Also assumes numerous other facts that this witness 23 24 358 El Brillo Wa on at least two occasions? MR. : Objection to the form. It 25 has not acknowledge nor admitted, and therefore 25 assumes knowledge of . and of 358 El Brillo Page 158 Page 160 I instruct her not to answer. 1 Way, to which the witness has not acknowledged. 2 THE WITNESS: On the instruction from my 2 and instruct the witness not to answer. 3 lawyer, I must choose to invoke my Fifth 3 THE WITNESS: On the instruction of my 4 Amendment privilege. 4 lawyer. I must choose to invoke my Fifth 5 BY MR. KUVIN: 5 Amendment right. 6 Q. Would you agree with me that in 2005 that 6 BY MR. KUVIN: 7 Jeffrey Epstein was between the ages of 45 and 55 7 Q. Do you agree that Mr. Epstein has an 8 years old? 8 odd-shaped ems? MR. : Objection to the form. 9 MR. Objection to the form of 10 Standing objection as to any knowledge of 10 the question. It assumes knowledge of 11 Jeffrey Epstein. Instruct the witness not to 11 Mr. Epstein. It assumes knowledge of 12 answer. 12 Mr. Epstein's body parts, and instruct the 13 THE WITNESS: The instruction of my 13 witness not to answer. 14 lawyer, I must choose to assert my Fifth 14 THE WITNESS: On advice -- on the 15 Amendment right. 15 instruction of my lawyer. I must choose to 16 BY MR. KUVIN: 16 invoke my Fifth Amendment right. 17 Q. Would you agree with me that 17 BY MR. KUVIN: 18 Jeffrey Epstein has tremendous wealth? 18 Q. Have ou seen Jeffrey Epstein's penis? 19 MR. : Objection to the form as 19 MR. Objection to the form. and 20 stated in the previous question, and instruct 20 we're getting awfully close to a line here. Mr. 21 the witness not to answer. 21 Kuvin. 22 THE WITNESS: On the instruction from the 22 MR. KUVIN: I think the identity of 23 lawyer, I must choose to invoke my Fifth 23 something that 14 and I5-year-old girls 24 Amendment right. 24 have seen is directly relevant to the issues in 25 25 this case. If the/ can describe it. then 40 (Pages 157 to 160) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 40 of 47 EFTA_00065357 EFTA01246503 Page 161 Page 163 1 obviously it's important because they are the 1 MR. KUVIN: The Epstein matter. 2 only ones that are answering questions in this 2 MR. : I instruct the witness not 3 case. 3 to answer. Objection to the form as compound 4 MR. Well, people have rights. 4 and assumes the existence of Mr. Epstein which, 5 People will assert their rights, and I am just 5 again, we are not acknowledging, and therefore 6 telling you, were getting close to a line 6 am instructing her not to answer. 7 here. 7 THE WITNESS: On the instruction of my 8 MR. KUVIN: I think I'm being 8 lawyer, I choose to assert my Fifth Amendment 9 respectful -- 9 right. 10 MR. You haven't crossed it yet 10 BY MR. KUVIN: 11 because I'm still here, but I'm just warning 11 Q. Are you aware that Mr. Epstein negotiated 12 you. 12 for your immunity from prosecution in the 13 Instruct the witness not to answer 13 non-prosecution agreement that was entered into with 14 any question that presumes existence or 14 the United States Attorney's Office for the Southern 15 any knowledge of Jeffrey Epstein or any of 15 District of Florida? 16 his body pans. 16 MR. : Again, objection to the 17 MR. KUVIN: Okay. 17 form for the reasons previously stated as to 18 THE WITNESS: On the instruction of my 18 the standing objection and instruct her not to 19 lawyer, I must choose to assert my Fifth 19 answer. 20 Amendment right. 20 THE WITNESS: On the instruction of my 21 BY MR. KUVIN: 21 lawyer, I must choose to invoke my Fifth 22 Q. Do you know whether or not Mr. Epstein has 22 Amendment right. 23 any identifying characteristics to any of his 23 BY MR. KUVIN: 24 private genitalia? 24 Q. Do you agree with me that was 25 MR. Objection to the form for 25 emotionally traumatized as a result of the incidents Page 162 Page 164 1 the reason previously stated, because it 1 that occurred Jeffrey E stein's home in 2005? 2 presumes that she has any knowledge of who 2 MR. : Obj=ion to the form. It 3 Jeffrey Epstein is or what his body parts look 3 assumes any knowledge of M. or any incidents 4 like, and I would instruct her not to answer. 4 that would have occurred at a home purporting 5 THE WITNESS: On the instruction of my 5 to belong to a person by the name of Jeffrey 6 lawyer, I must choose to assert my Fifth 6 Epstein, and instruct her not to answer. 7 Amendment right. 7 THE WITNESS: Upon instruction from my 8 BY MR. KUVIN: 8 lawyer, I must choose to invoke my Fifth 9 Q. Have you heard anyone other than your 9 Amendment right. 10 lawyers that have described what any of 10 BY MR. KUVIN: 11 Mr. Epstein's bod arts look like? 11 Q. Do you agree with me that ■. was 12 MR. • Objection to the form. It 12 emotionally traumatized as a result of the incidents 13 is irrelevant what she's heard from other 13 that occurred at Jeffrey E stein's home? 14 people, and again, it presumes facts that she's 14 MR. : Same objection as to the 15 not acknowledged. It is compound, and it is 15 previous question, and instruct the witness not 16 harassing at this point. 16 to answer. 17 THE WITNESS: On instruction of my lawyer. 13 THE WITNESS: On the instruction of my 18 I must choose to invoke my Fifth Amendment 18 lawyer, I must choose to invoke my Fifth 19 right. 19 Amendment privilege. 20 BY MR. KUVIN: 20 BY MR. KUVIN: 21 Q. Were you consulted with respect to the 21 Q. Do ou know Jane Doe No. 102? 22 non-prosecution agreement that was entered into with 22 MR. : Instruct the witness not 23 the United States Attorneys Office for the Southern 23 to answer based on Fifth Amendment privilege. 24 District of Florida as it relates to this case? 24 THE WITNESS: On instruction of my lawyer,) 25 MR. Which case? 25 I must choose to invoke my Fifth Amendment 41 (Pages 161 to 164) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 41 of 47 EFTA_00065358 EFTA01246504 Page 165 Page 167 1 right. 1 in New York? 2 BY MR. KUVIN: 2 MR. Instruct the witness not 3 Q. Have you known Jeffrey Epstein to keep 3 to answer based on the Fifth Amendment 4 underage, under the a e of IS, sex slaves? 4 privilege. 5 MR. : Objection to the form both 5 THE WITNESS: On the instruction of my 6 as to ambiguity as to what you mean by "sex 6 lawyer, I choose to invoke my Fifth Amendment 7 slaves," and "keep," also the standing 7 right. 8 objection as to any knowledge of Mr. Epstein 8 BY MR. KUVIN: 9 and instruct the witness not to answer. 9 Q. Are you aware that various underage girls 10 THE WITNESS: On the instruction of my 10 brought in from out of the country live at 301 East 11 lawyer, I must choose to invoke my Fifth 11 66th Street? 12 Amendment right. 12 MR. Objection to the form. 13 BY MR. KUVIN: 13 It's compound. and instruct the witness not to 14 Q. Where do most of the models come from that 14 answer. 15 are part of MC uared Modeling Agency? 15 THE WITNESS: On the instruction from my 16 MR. : Objection to the form. It 16 lawyer, I must choose to invoke my Fifth 17 assumes knowledge of an entity by the name of 17 Amendment right. 18 MC Squared Modeling which the witness has not 18 BY MR. KUVIN: 19 acknowledged and therefore I instruct her not 19 Q. You've stayed at that address before, have 20 to answer, and the question is compound. 20 you not? 21 THE WITNESS: On the instruction of my 21 MR. Instruct the witness not 22 lawyer, I must choose to invoke my Fifth 22 to answer. 23 Amendment privilege. 23 THE WITNESS: On the instruction of my 24 BY MR. KUVIN: 24 lawyer, I must choose to invoke my Fifth 25 Q. Who gets visas for the models at MC 25 Amendment right. Page 166 Page 168 1 Squared, if ou know? 1 BY MR. KUVIN: 2 MR. : Same, same objection as to 2 Q. You've stayed there hundreds of times, 3 the previous question, same instruction. 3 have you, hundreds of times have you not? 4 THE WITNESS: On the instruction of my 4 MR. Instruct the witness not 5 lawyer, I must choose to invoke my Fifth 5 to answer. 6 Amendment right. 6 THE WITNESS: On instruction from my 7 BY MR. KUVIN: 7 lawyer, I must choose to invoke my Fifth 8 Q. Do you work with Jeffrey Epstein to get 8 Amendment right. 9 visas for out-of-the-country models or models that 9 BY MR. KUVIN: 10 are -- strike that. 10 Q. Are you aware that Mr. Epstein obtains 11 Do you work with Jeffrey Epstein to 11 visas for girls from out of the country to work as 12 get visas for girls that are underage and bring them 12 models and then ostitutes them out? 13 into the United States so that they can work as 13 MR. Objection to the form of 14 models for MC S, uared? 14 the question in that it is ambiguous and it 15 MR. : Objection to the form and 15 assumes numerous facts that have not 16 assumes knowledge as to Mr. Epstein and as to 16 acknowledged that this witness has any 17 MC Squared and other matters that are not 17 knowledge of, and the term "prostitutes them 18 admitted or acknowledged by this witness. The 18 out" is ambiguous, so I would instruct her not 19 question is compound. I would instruct her not 19 to answer the question. 20 to answer. 20 THE WITNESS: On the instruction of my 21 THE WITNESS: On the instruction from my 21 lawyer, I must choose to invoke my Fifth 22 lawyer. I must choose to invoke my Fifth 22 Amendment right. 23 Amendment right. 23 BY MR. KUVIN: 24 BY MR. KUVIN: 24 Q. You know what Radar Online is. do you not? 25 Q. Do you know who owns 301 East 66th Street 25 MR. Instruct the witness not 42 (Pages 165 to 168) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 42 of 47 EFTA_00065359 EFTA01246505 Page 169 Page 171 1 to answer the question based on her Fifth 1 THE WITNESS: On the instruction from my 2 Amendment privilege. 2 lawyer, I choose to invoke my Fifth Amendment 3 THE WITNESS: On the instruction of my 3 right. 4 lawyer, I must choose to invoke my Fifth 4 BY MR. KUVIN: 5 Amendment right. 5 Q. Would you agree with me that Jeffrey 6 BY MR. KUVIN: 6 Epstein has a list of underage girls that live 7 Q. In fact, you were around when 7 within a close proximity to all of his different 8 Jeffrey Epstein bou ht Radar Online, were you not? 8 homes in eve different state? 9 MR. : Objection to the form, 9 MR. : Objection to the form in 10 standing objection as to any knowledge of 10 that it assumes Mr. Epstein has homes in every 11 Jeffrey Epstein or of Radar Online, and 11 single state and that she knows who Mr. Epstein 12 instruct the witness not to answer. 12 is, and therefore I instruct her not to answer. 13 THE WITNESS: On the instruction from my 13 THE WITNESS: On advice of my lawyer. I 14 lawyer, I must choose to invoke my Fifth 14 must choose to invoke my Fifth Amendment right. 15 Amendment right. 15 BY MR. KUVIN: 16 BY MR. KUVIN: 16 Q. You're aware Mr. Epstein has a home in New 17 Q. Are you aware that Jeffrey Epstein 17 York. right? 18 accessed or obtained underage girls through his 18 MR. : Instruct the witness not 19 Radar connection? 19 to answer, and standing objection of knowledge 20 MR. : Same objection as 20 of Mr. Epstein. 21 previously stated to the last question and same 21 THE WITNESS: On the instruction of my 22 instruction. 22 lawyer, I must invoke my Fifth Amendment right. 23 THE WITNESS: On the instruction from my 23 BY MR. KUVIN: 24 lawyer, I must choose to invoke my Fifth 24 Q. Are you aware that he has a home in New 25 Amendment privilege. 25 Mexico? Page 170 Page 172 1 BY MR. KUVIN: 1 MR. By he, you mean 2 Q. How many different properties does 2 Mr. Epstein? 3 Jeffrey Epstein own? 3 MR. KUVIN: Yeah. 4 MR. Objection to the form. 4 MR. Got to make sure the 5 standing objection. Instruct the witness not 5 question is clear. 6 to answer. 6 MR. KUVIN: Yes. 7 THE WITNESS: On the instruction of my 7 MR. Standing objection to the 8 lawyer, I must choose to invoke my Fifth 8 form and instruct the witness not to answer. 9 Amendment right. 9 THE WITNESS: On the instruction from my 10 BY MR. KUVIN: 10 lawyer, I must choose to invoke my Fifth 11 Q. You've been to all of Jeffrey Epstein's 11 Amendment privilege. 12 home, have ou not? 12 BY MR. KUVIN: 13 MR. Same objection as 13 Q. Are you aware he has a home in the U.S. 14 previously stated to the last question. Same 14 Virgin Islands? 15 instruction. 15 MR. Same instruction, same 16 THE WITNESS: On the instruction from my 16 objection. 17 lawyer, I must invoke my Fifth Amendment right. 17 THE WITNESS: On the instruction of my 18 BY MR. KUVIN: 18 lawyer, I must choose to invoke my Fifth 19 Q. You agree with me that Jeffrey Epstein 19 Amendment right. 20 keeps a list of girls in the nearby areas around all 20 BY MR. KUVIN: 21 of his homes and ro rties? 21 Q. And isn't it true that you kept a list of 22 MR. Objection to the form, for 22 underage girls that could service, in other words, 23 the standing objection as well as ambiguous as 23 give Mr. Epstein naked massages in every place that 24 to "nearby." and "all of his properties," so I 24 he has one of those homes I just described? 25 instruct the witness not to answer. 25 MR. Same objection as 43 (Pages 169 to 172) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 43 of 47 EFTA_00065360 EFTA01246506 Page 173 Page 175 1 previously stated, the standing objection and 1 to Mr. Epstein's house on Palm Beach. you were aware 2 instruct her not to answer. 2 that they were brought so that Mr. Epstein could 3 THE WITNESS: On the instruction of my 3 molest them, correct? 4 lawyer, I must choose to invoke my Fifth 4 MR. : Objection to the form as 5 Amendment right. 5 to knowledge of Mr. Epstein, as to knowledge of 6 BY MR. KUVIN: 6 any home on Palm Beach. and ambiguous as to the 7 Q. Now, you're also aware, are you not, that 7 term "molest," and instruct the witness not to 8 Jeffrey Epstein would pay other girls to bring 8 answer. 9 additional underage girls to him for naked massages, 9 THE WITNESS: On the instruction from my 10 are you not? 10 lawyer. I must choose to invoke my Fifth 11 MR. : Standing objection and 11 Amendment right. 12 instruct the witness not to answer. 12 BY MR. KUVIN: 13 THE WITNESS: On the instruction from my 13 Q. You're aware that Mr. Epstein raped 14 lawyer, I must choose to invoke my Fifth 14 several undera e minors in his bedroom? 15 Amendment privilege. 15 MR. : Objection to the form as 16 BY MR. KUVIN: 16 to knowledge of Mr. Epstein. and also ambiguous 17 Q. And, in fact, you frequently would pay 17 as to the term "rape." 18 other girls to bring additional girls under the age 18 THE WITNESS: On the instruction of my 19 of 18 to Mr. Epstein for naked massages? 19 lawyer, I must choose to invoke my Fifth 20 MR. : Objection to the form, 20 Amendment rights. 21 standing objection as to Mr. Epstein. also as 21 BY MR. KUVIN: 22 to any knowledge of any naked massages by 22 Q. Do ou know what the term "rape" means? 23 anybody to anybody. Instruct the witness not 23 MR. : Not as you used it. If 24 to answer. 24 you want to tell us what you mean by when you 25 THE WITNESS: On the instruction of my 25 used it, we'll be happy to answer -- Page 174 Page 176 lawyer, I choose to invoke my Fifth Amendment 1 MR. KUVIN: I want to know if -- 2 right. 2 MR. : -- or evaluate your 3 BY MR. KUVIN: 3 question. 4 Q. And there was a complete list of girls, 4 MR. KUVIN: I want to know if she has her 5 underage girls, that was stored on Mr. Epstein's 5 own definition of what the phrase or word 6 computer s stem: isn't that true? 6 "rape" means, so that we can use her definition 7 MR. : Objection to the form. 7 of that word. I want to make sure it's 8 It's ambiguous as to what a complete list is, 8 complete) unambi uous. 9 and also a standing objection to any knowledge 9 MR. : Your asking the question. 10 of Mr. Epstein, and instruct the witness not to 10 If you want to define the term, she'll respond 11 answer. 11 to your question. 12 THE WITNESS: On the instruction from my 12 BY MR. KUVIN: 13 lawyer, I must choose to invoke my Fifth 13 Q. Do you what the term or word "rape" means? 14 Amendment privilege. 14 A. Yes. 15 BY MR. KUVIN: 15 Q. Okay. What is your understanding of that 16 Q. In fact, you've seen the list of underage 16 word? 17 girls that exists on Mr. Epstein's computer, have 13 MR. : Now, we're not answering 18 you not? 18 that question. It's your term. It's your 19 MR. Objection to the form, 19 question. If you want to define it. you can go 20 standing objection. 20 ahead and define it. 21 THE WITNESS: On the instruction from my 21 MR. KUVIN: Well, I beg -- 22 lawyer, I must choose to invoke my Fifth 22 MR. : If you want to give her 23 Amendment right. 23 specifics as to what she -- you can define it. 24 BY MR. KUVIN: 24 MR. KUVIN: I beg to differ with you. and 25 Q. When underage minor females were brought 25 I don't know that that's a proper objection. 44 (Pages 173 to 1 7 6) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 44 of 47 EFTA_00065361 EFTA01246507 Page 177 Page 179 1 I'm askin: her her understanding of the word. 1 or vaginal penetration or union with the sexual 2 MR. : And I am instructing her 2 organ of another, or oral, anal or vaginal 3 not to answer it because that question is not 3 penetration of another with any other object, 4 5 likely to lead to discoverable evidence. It's simply meant to harass her. And you can define 4 5 or with an object. Excuse me. All right? MR. Okay. 6 the term in your question. 6 BY MR. KUVIN: 7 MR. KUVIN: Well, with all due respect, 7 Q. Do you understand that definition as I 8 it's certainly not to harass if there have been 8 have explained it to you. or would you like me to 9 girls that were alle in that they were raped. 9 read it again? 10 MR. : Well, you define what you 10 A. Read it again, please. 11 mean by when you say that they allege that they 11 Q. Absolutely. Florida law defines "rape" as 12 have been raped. and she will be happy to 12 oral, anal or vaginal penetration by, or union with 13 evaluate your question. 13 the sexual organ of another: or oral, anal or 14 MR. KUVIN: And that's what I'm trying to 14 vaginal penetration by another with any object. And 15 understand. 15 obviously that is without the other's consent. 16 MR. : She's not going to 16 A. You did not sot that. 17 speculate on what you mean when you frame a 17 MR. Okay. 18 word in your question. 18 BY MR. KUVIN: 19 MR. KUVIN: That's exactly what I'm trying 19 Q. Adding without the other's consent, 20 to do. I'm trying to make sure that we are 20 obviously, to that definition. 21 using the same definition, so I would like to 21 Now, let's use that definition for 22 use her definition of the word. 22 "rape." because that's as it's defined by Florida 23 MR. : Right. She's not going to 23 law. Using that definition, are you aware, as you 24 answer it, so you can either move on we can 24 sit here today, that Jeffrey Epstein has raped 25 stop. 25 underage girls? Page 178 Page 180 1 MR. KUVIN: Okay. So you're instructing 1 MR. Standing objection to the 2 her not to answer the . uestion? 2 form of the question, and I would instruct the 3 MR. : I am instructing her not 3 witness not to answer. 4 to answer the question for the third time. 4 THE WITNESS: On the instruction of my 5 MR. KUVIN: Okay. I just want to be 5 lawyer, I must choose to invoke my Fifth 6 clear. 6 Amendment right. 7 MR. GARCIA: What's the legal objection? 7 BY MR. KUVIN: 8 MR. : I've already stated what 8 Q. Are you aware as ou sit here today that 9 my legal objection is. It's meant solely for 9 Jeffrey Epstein ra d ? 10 harassment. It's not likely to lead to 10 MR. Objection to the form. 11 discoverable evidence. 11 The question assumes that he did, or that she 12 BY MR. KUVIN: 12 has any knowledge of whether he did, so I 13 Q. Okay. For the purpose of my question, I 13 instruct the witness not to answer. 14 would like to, because your attorney won't allow you 14 THE WITNESS: On the instruction of my 15 to define the word "rape," I would like you to use 15 lawyer, I must choose to invoke my Fifth 16 the word and understand the word "rape" to mean 16 Amendment privilege. 17 sexual contact with an individual, including 17 BY MR. KUVIN: 18 sexual -- well, let me clarify here. Hang on. You 18 Q. Are you aware as you sit here today, that 19 know what, if we're going to do it, let's do it 19 Jeffrey Epstein -- well, let me rephrase that. 20 21 22 right since we can't use our definition. MR. : You can use whatever definition you like, but you need to tell me 20 21 22 You are aware, are you not, a sit here toda . that Jeffrey Epstein raped? MR. Objection to the form as 23 what it is. 23 leading, and also again assumes -- your 24 MR. KUVIN: Let's use the definition of 24 question assumes that she knows things that 25 "rape" as defined by Florida law as oral, anal 25 she's not acknowledoed that she knows or 45 (Pages 177 to 180) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 45 of 47 EFTA_00065362 EFTA01246508 Page 181 Page 183 doesn't know, and I instruct her not to answer. 1 MR. Same objection as 2 THE WITNESS: On the instruction of my 2 previously stated as to ambiguity and compound, 3 lawyer, I must choose to invoke my Fifth 3 and instruct the witness not to answer. 4 Amendment right. 4 THE WITNESS: On the instruction of my 5 BY MR. KUVIN: 5 lawyer, I must choose to invoke my Fifth 6 Q. Do you agree that Jeffrey Epstein has 6 Amendment right. 7 raped hundreds of irls under the age of 18? 7 BY MR. KUVIN: 8 MR. : Objection to the form, 8 Q. Have you ever had sexual contact in any 9 standing objection as to any knowledge of 9 manner with any underage girls that were brought to 10 Jeffrey Epstein. Instruct the witness not to 10 Mr. Epstein's home? 11 answer. 11 MR. Objection to the form. 12 THE WITNESS: On the instruction of my 12 Standing objection, compound, instruct the 13 lawyer, I must choose to invoke my Fifth 13 witness not to answer. 14 Amendment privilege. 14 THE WITNESS: On the instruction of my 15 BY MR. KUVIN: 15 lawyer, I must choose to invoke my Fifth 16 Q. You're aware, are you not, that 16 Amendment right. 17 Jeffrey Epstein has raped hundreds of girls under 17 BY MR. KUVIN: 18 the age of 17? 18 Q. Did you keep an appointment book for 19 MR. Objection to the form as 19 Mr. Epstein? 20 leading. Instruct the witness not to answer 20 MR. Objection to the form. 21 for the reasons previously stated to the last 21 standing objection. Instruct the witness not 22 the question. 22 to answer. 23 THE WITNESS: On the instruction of my 23 THE WITNESS: On the instruction of my 24 lawyer, I must choose to assert my Fifth 24 lawyer, I must choose to invoke my Fifth 25 Amendment right. 25 Amendment right. Page 182 Page 184 1 BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. You're aware, as you sit here today, are 2 Q. Did you preserve a document that shows the 3 you not, that Jeffrey Epstein has raped hundreds of 3 appointments ke for Mr. Epstein in the years 2004? 4 girls under the a e of 16? 4 MR. Objection to the form, the 5 MR. : Objection to the form. 5 standing objection, compound question and 6 Standing objection. It assumes numerous facts 6 instruct the witness not to answer. 7 mixed in a compound question, and therefore I 7 THE WITNESS: On the instruction of my 8 instruct the witness not to answer. 8 lawyer, I must choose to invoke my Fifth 9 THE WITNESS: On the instruction of my 9 Amendment right. 10 lawyer, I must choose to assert my Fifth 10 BY MR. KUVIN: 11 Amendment right. 11 Q. Same question with respect to any 12 BY MR. KUVIN: 12 appointments ke for Mr. Epstein in 2005. 13 Q. Isn't it true that Mr. Epstein had at 13 MR. Same objection previously 14 least one or two scheduled appointments for sex with 14 stated to the previous question. 15 underage girls every day while he was here in Palm 15 THE WITNESS: On the instruction of my 16 Beach Coun in the ear 2005? 16 lawyer, I must choose to invoke my Fifth 17 MR. Objection to the form. 17 Amendment right. 18 It's compound, standing objection as well, and 18 BY MR. KUVIN: 19 instruct the witness not to answer. 19 Q. Same with respect to any appointments kept 20 THE WITNESS: On the instruction of my 20 for Mr. Epstein in 2006. 21 lawyer, I must choose to invoke my Fifth 21 MR. Same objection as 22 Amendment right. 22 previously stated to the last two questions. 23 BY MR. KUVIN: 23 THE WITNESS: On the instruction of my 24 Q. Did you actually locate underage girls in 24 lawyer. I must choose to invoke my Fifth 25 Palm Beach for Jeffrey Epstein to rape? 25 Amendment privilege. 46 (Pages 181 to 1 8 4) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 46 of 47 EFTA_00065363 EFTA01246509 Page 185 Page 187 1 BY MR. KUVIN: 1 MR. Yeah, whenever you get to 2 Q. Have you provided any appointment books to 2 a convenient point in your questioning. I think 3 anyone with respect to intments for Mr. Epstein? 3 we can use a break. If you're in the middle of 4 MR. Same standing objection as 4 something, I don't want to stop you. 5 to knowledge of Mr. Epstein. The question is 5 MR. KUVIN: No, this is fine. We can take 6 compound and instruct the witness not to 6 a quick break. Five minutes? 7 answer. 7 MR. : Yes, thank you. 8 THE WITNESS: On the instruction of my 8 THE VIDEOGRAPHER: We're now off the 9 lawyer. I must choose to invoke my Fifth 9 record. It is 2:08 p.m. 10 Amendment right. 10 (A brief recess was held.) 11 BY MR. KUVIN: 11 12 Q. Would Ep -- Mr. Epstein pay the underage 12 13 girls more money if they took off both their tops 13 14 and their bottoms? 14 15 MR. Objection to the form. 15 16 standing objection. Instruct the witness not 16 17 to answer. 17 18 THE WITNESS: On the instruction of my 18 19 lawyer, I must choose to invoke my Fifth 19 20 Amendment right. 20 21 BY MR. KUVIN: 21 22 Q. Would Mr. Epstein pay the underage girls 22 23 more if the would actually touch his penis? 23 24 MR. Same instruction, same 24 25 objection. 25 Page 186 1 THE WITNESS: On the instruction of my 2 lawyer, I must choose to assert my Fifth 3 Amendment right. 4 BY MR. KUVIN: S Q. Would Mr. Epstein pay the underage girls 6 more if he would allow them to have sex with them? 7 MR. Can you restate that 8 again? 9 MR. KUVIN: Yes. 10 BY MR. KUVIN: 11 Q. Would Mr. Epstein pay the underage girls 12 more money if they would allow him to have sex with 13 them? 14 MR. Objection to the form. 15 standing objection. Instruct the witness not 16 to answer. 17 THE WITNESS: On the instruction of my 18 lawyer, I must invoke my Fifth Amendment right. 19 MR. KUVIN: Hang on one second. You can 20 stop at an time I'll si n it. 21 MR. Mr. Kuvin, I don't know i 22 you're getting to a convenient breaking point 23 but -- 24 MR. KUVIN: Do you want to take a quick 25 one? 47 (Pages 185 to 1 87) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-025 Page 47 of 47 EFTA_00065364 EFTA01246510