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Page 187 Page 189 UNITED STATES DISTRICT COURT 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT SOUTHERN DISTRICT OF FLORIDA IN AND FOR PALM BEACH COUNTY. FLORIDA 2 CASE NO. 502008CA028051XXXXIMB AB CASE NO. 08-CIV-80119-MARRA/JOHNSON 3 M. JANE DOE NO. 2. Plaintiff. Plaintiff. 5 -vs- VOLUME II OF III VOLUME II OF III JEFFREY EPSTEIN. 6 Defendant. JEFFREY EPSTEIN. / 7 Defendant. Related cases: a / 0840232. 08-08380. 08-80381. 08-80994 9 08-80993. 08-80811. 08-80893. 09-80469 10 VIDEOTAPED DEPOSITION OF 0940591. 09-80656. 09-80802. 09-81092 11 Wednesday. March 24.2010 / 12 10:37 - 6:51 p.m. 13 VILIMMISITION OF 14 15 250 Australian Avenue South West Palm Beach. Florida 33401 Wednesday. March 24.2010 16 10:37 - 6:51 p.m. 17 250 Australian Avenue South 16 Suite 1500 19 Reponed By: West Palm Beach. Florida 33401 Cynthia Hopkins. RPR. FPR 20 Notary Public. State of Florida Prose Court Repotting Reported By: 21 Cynthia Hopkins. RPR. FPR 22 Notary Public. State of Florida 23 Prose Court Reporting 24 Job No.: 1484 25 Page 188 Page 190 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 t• a 4 Plaintiff. Plaintiff. 5 5 VOLUME II OF III VOLUME II OF III 6 1 7 JEFFREY EPSTEIN. 8 AN EFaillik Defendant. Defendants. a 9 r 9 10 DEPOSITION OF 10 11 12 Wednesday. March 24. 2010 11 12 V1tSMON OF 10:37 - 6:51 p.m. 13 13 14 Wednesday. March 24. X110 10 250 Australian Avenue South 10:31- 6:5I p.m. West Palm Beach. Florida 33401 15 15 16 16 17 250 Australian Avenue South 17 Suite 1500 18 Reported By: 16 West Palm Beach. Florida 33401 Cynthia Hopkins. RPR. FPR 19 19 Notary Public. State of Florida 20 Prose Court Reporting 21 20 22 Reported By: 21 Cynthia Hopkins. RPR. FPR 22 23 Notary Public. State of Florida 23 Prose Court Reporting Services 20 24 Job No.: 1484 25 25 (Pages 187 to 190) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 1 of 48 EFTA_00065365 EFTA01246511 Page 191 Page 193 APPEARANCES: 1 — — — 2 On behalf of the Plaintiffs. : SPENCER T. KUVIN. ESQUIRE 2 INDEX LEOPOLD KUVIN 3 2925 PGA Boulevard 4 _ _ _ Suite 201) S Palm Beach Garden. Florida 33410 5 EXAMINATION DIRECT CROSS REDIRECT Phone: 6 BY MR. KUVIN 194 6 On behalf of the Mantas.... . and lane Doe: 7 BY MR. HOROWITZ 214 BY MR. WEISSING 271 g 9 MATTHEW WE1SSING. ESQUIRE 8 BY MR. GARCIA 325 FARMER.1AFTE WEISSING. EDWARDS 9 10 ETSTOS & LEHRIMAN.P.L 425 North Andrews Avenue 10 — — — 11 Suite 2 11 EXHIBITS Fon Lauderdale Florida 33301 12 _ _ _ 12 13 Phone: On behalf of Jane Does I through a: 13 14 ADAM D. HOROWITZ- ESQUIRE 14 EXHIBIT DESCRIPTION PAGE 15 MERMELSTEIN S HOROWITZ. P.A. IS205 Biscayne Boulevard 15 Suite 2215 16 PLAINTIFFS EX. 14 REQUEST FOR WARRANT 19- 16 Miami. i PLAINTIFFS EX. 15 ANSWER AND 342 Phone: 17 Email: 17 AFFIRMATIVE DEFENSES IS On behalf of the Plunk'''. 101. 102 and 103: 18 19 KATHERINE W. EMELL. ESQUIRE AMY JOSEFSBER(1 EDERI. ESQUIRE 19 20 PODHURST ORSECK 20 21 25 West Flatlet Street Suite S00 21 22 22 23 23 24 IVra telephone) 29 25 25 Page 192 Page 194 1 Appearances continued... 1 PROCEEDINGS 2 On behalf of the Plaintiff. Jane Doe II: 2 * * * • * 3 1511)RO MANUEL GARCIA. ESQUIRE GARCIA. ELKINS & BOERRINGER 3 THE VIDEOGRAPHER: We're now back on the 4 224 Datum Avenue. Suite 900 4 record. It is 2:19 p.m. Starting Media Unit s West Palm Beach Fl ida 33401 Phone: 5 No. 2. 6 6 CONTINUED DIRECT EXAMINATION 8 On behalf of the Defendant: JACK ALAN GOLDBERGER. ESQUIRE 7 BY MR. KUVIN: ATTERBURY. GOLDBERGER & WEISS. P.A. 8 Q. All right. Did Jeffrey Epstein talk to 9 250 Australian Avenue South 9 you about whether or not he was going to be going to Suite 1400 10 West Pa r ida 33401-5012 10 jail after he was arrested? Phone: 11 MR. Objection to the form. 11 12 12 standing objection. Instruct the witness not 13 On behalf of t • W' • • 13 to answer. 1 4 14 THE WITNESS: On the instruction of my 15 lawyer. I must invoke my Fifth Amendment right. 16 BY MR. KUVIN: 17 Q. How did you first learn of the criminal 17 18 investigation with respect to Mr. Epstein? 18 19 19 MR. Objection to the form. 20 ALSO PRESENT: 20 standing objection. Instruct the witness not 21 Jessica Cadwell. Paralegal 21 to answer. 22 Burman. triton. Luther & Coleman. P.A. Joseph Kozak. Videographer 22 THE WITNESS: On the instruction of my Prose Court Reporting Services 23 lawyer. I must exercise my Fifth Amendment 23 24 24 right. 25 25 2 (Pages 191 to 194) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 2 of 48 EFTA_00065366 EFTA01246512 Page 195 Page 197 1 BY MR. KUVIN: 1 not know about. 2 Q. Do you know who tipped off Jeffrey Epstein 2 But if you can answer, go ahead. 3 about an ongoing investigation against him back in 3 THE WITNESS: No. 4 2005? 4 BY MR. KUVIN: 5 MR. Same objection as 5 Q. Let me show what we'll mark as Exhibit 14. 6 previously stated to the last two questions and 6 which purports to be a request for a warrant for 7 same instruction. 7 your arrest. 8 THE WITNESS: On the instruction of my 8 MR. : Okay. 9 lawyer, I must invoke my Fifth Amendment right. 9 (Plaintiffs Exhibit No. 14 was marked for 10 BY MR. KUVIN: 10 identification.) 11 Q. Were you aware that there was a warrant 11 BY MR. KUVIN: 12 issued for your arrest in connection with 12 Q. Just yes or no; have you seen that request 13 Jeffrey Epstein? 13 for a warrant before? 14 MR. Objection to the form, 14 A. No. 15 standing objection, same instruction. 15 Q. All right. If you would turn to the 16 THE WITNESS: On the instruction of my 16 probable cause affidavit. If you would go ahead and 17 lawyer, I must invoke my Fifth Amendment right. 17 turn to the -- keep turning, and again. There we 18 BY MR. KUVIN: 18 go. 19 Q. Have you seen the warrant that was issued 19 All right. There's a document attached to 20 for your arrest in connection with Jeffrey Epstein? 20 this exhibit entitled. Probable Cause Affidavit. 21 MR. Same objection and same 21 Have you had a chance to read through this 22-page 22 instruction as the last question. 22 document in the . ast? 23 THE WITNESS: On the instruction of my 23 MR. : I'm sorry. Are you asking 24 lawyer, I must invoke my Fifth Amendment right. 24 her if she's ever seen it before or if she's 25 25 ever read it before? Page 196 Page 198 1 BY MR. KUVIN: 1 MR. KUVIN: Good point. 2 Q. Have you seen the probable cause affidavit 2 BY MR. KUVIN: 3 with respect to the arrest warrant issued for your 3 Q. Let's ask first: Have ever seen it 4 5 arrest on Ma 1.2006? MR. : Hang on one second. I 4 5 before? A. I don't believe so. 6 will object to the form. Can you, can you 6 Q. Okay. If you would turn to -- keep it in 7 repeat the question just for the record? 7 front of you -- if we turn to Page 22, and we look 8 MR. KUVIN: Yes. 8 at the last paragraph. 9 BY MR. KUVIN: 9 Do you agree that Epstein in the years. 10 Q. Have you been made aware, or have you -- 10 2005. 2004 and 2005, did commit lewd and lascivious 11 let me clarify. Have you seen the probable cause 11 molestation on a 14- ear-old girl? 12 affidavit that was attached to your warrant for 12 MR. Just if I can clarify, are 13 14 arrest on Ma I. 2006? MR. : Object to the form. I 13 14 you asking whether that's what the document says? 15 don't believe there ever was a warrant issued. 15 MR. KUVIN: No. fm asking whether she's 16 but go ahead and answer the question, if you 16 aware of it. 17 can. 17 MR. I'm going to object to the 18 THE WITNESS: No. 18 form. It calls for a legal conclusion that 19 BY MR. KUVIN: 19 she's not competent to make. That's ambiguous 20 Q. Have you seen the request for a warrant 20 in that regard. and also the standing objection 21 with the attached probable cause affidavit that was 21 and I will instruct her not to answer. 22 23 issued on M a 1st. 2006? MR. : Object to the form. 22 23 THE WITNESS: On the advice of my lawyer. I must to invoke my Fifth Amendment right. 24 Assumes her knowledge of something that she ma) 24 BY MR. KUVIN: 25 not know. the existence of something ,he may 25 Q. Do you agree that in the years 2004 and 3 (Pages 195 to 198) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 3 of 48 EFTA_00065367 EFTA01246513 Page 199 Page 201 1 2005 Mr. Epstein molested hundreds of 14, IS, and 1 Jeffrey Epstein took nude photos of girls under the 2 3 16-year-old irls? MR. Same objection to the 2 3 age of IS? MR. Objection to the form. 4 form, standing objection and also calls for a 4 standing objection, instruct the witness not to 5 legal conclusion and is ambiguous. Instruct 5 answer. 6 the witness not to answer. 6 THE WITNESS: On the instruction of my 7 THE WITNESS: On the instruction of my 7 lawyer, I must invoke my Fifth Amendment right. 8 lawyer, I must invoke my Fifth Amendment right. 8 BY MR. KUVIN: 9 BY MR. KUVIN: 9 Q. Have you taken any photographs of girls 10 Q. Do you agree that the facts contained 10 under the age of 18, nude photographs of girls under 11 within this probable cause affidavit are true and 11 the age of IS ourself'? 12 accurate? 12 MR. : Object to the form as 13 MR. Objection to the form. 13 ambiguous. Can we get a time period or any 14 You've never established that she's read it, so 14 sort of -- 15 how can she say whether it's true and accurate. 15 MR. KUVIN: Sure. 16 I instruct the witness not to answer the 16 MR. -- limitation of that? 17 question. Do you want to clarify your 17 MR. KUVIN: Absolutely. 18 question? 18 BY MR. KUVIN: 19 MR. KUVIN: No. 19 Q. In the years of 2004 to 2006. did you ever 20 BY MR. KUVIN: 20 taken any nude photographs of underage girls being 21 Q. Were you present at 358 El Brillo Way when 21 girls under the a e of 18? 22 the search warrant was issued for that home? 22 MR. : Object to the form as 23 MR. Objection to the form as 23 ambiguous. Instruct the witness not to answer. 24 to any knowledge of 358 El Brillo Way. Also 24 THE WITNESS: On the advice of my lawyer, 25 ambiguous. Are you asking about when the 25 I must exercise my Fifth Amendment right. Page 200 Page 202 1 warrant was issued or when the warrant was 1 MR. KUVIN: And just so we're clear, when 2 executed? 2 you say "instruct the witness not to answer." 3 MR. KUVIN: I don't know. You criminal 3 you mean for the Fifth Amendment grounds as 4 guys know the language. 4 opposed to -- 5 BY MR. KUVIN: 5 MR. : Well, technically that 6 Q. When the cops came into the house and 6 would be manufacturing child pornography, so if 7 searched the home at 358 El Brillo Way. were you 7 the truthful answer that question would be yes, 8 there? 8 she would be admitting to a crime. 9 MR. Objection to the form as 9 MR. KUVIN: No I understand that. 10 to compound, and assuming knowledge as to 10 MR. : So yes, I'm instructing 11 358 El Brillo Way or any search by the police. 11 her not to answer the question. 12 Instruct the witness not to answer. 12 MR. KUVIN: Because there have been some 13 THE WITNESS: On the instruction of my 13 questions that we've instructed her, you've 14 lawyer, I must exercise my Fifth Amendment 14 instructed her not to answer at all, and then 15 privilege. 15 others -- I ust wanted for clarify. 16 BY MR. KUVIN: 16 MR. Thank you. I was getting 17 Q. Are you aware of any covert cameras that 17 sloppy. I apologize. 18 exist in the home at 358 El Brillo Way? 18 MR. KUVIN: That's okay. 19 MR. Objection to the form. 19 BY MR. KUVIN: 20 Standing objection as it relates to El Brillo 20 Q. All right. Do you agree that you have -- 21 Way, and instruct the witness not to answer. 21 well, let me ask you this: Have you taken any video 22 THE WITNESS: On the instruction of my 22 of girls under the age of 18, nude girls under the 23 24 lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: 23 24 age of 18 in the ears 2004 through 2006? MR. : Once again -- 25 Q. Are you aware or whether or not 25 MR. KUVIN: Go ahead. 4 (Pages 199 to 202) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 4 of 48 EFTA_00065368 EFTA01246514 Page 203 Page 205 1 MR. Wait. Hold on a second. 1 Standing objection as to knowledge of 2 Let me go back to the prior question about 2 Mr. Epstein. Instruct the witness not to 3 still photographs. 3 answer based on the Fifth Amendment. 4 MR. KUVIN: Yes. 4 THE WITNESS: On the instruction of my 5 MR. Okay. And I think the 5 lawyer I must exercise my Fifth Amendment 6 question was whether she had taken between '04 6 right. 7 and '06 any still photographs of nude women 7 BY MR. KUVIN: 8 under the age of 18. 8 Q. Do you know whether or not an attempt to 9 MR. KUVIN: Yes. 9 give a $90,000 donation was an attempt to stop the 10 MR. Is that correct? I want 10 Palm Beach Police from investigating Mr. Epstein? 11 to go back to that question. 11 MR. : Objection to the form. 12 MR. KUVIN: Okay. You can go back to that 12 Standing objection as previously stated, and 13 question. 13 the same instructions as the previous question. 14 THE WITNESS: No. 14 THE WITNESS: At the instruction of my 15 BY MR. KUVIN: 15 lawyer, I must invoke my Fifth Amendment right. 16 Q. Have you taken any nude videotape of girls 16 MR. KUVIN: Hold on a second. Almost 17 under the age of 18 for the years 2004 through 2006? 17 done. 18 A. No. 18 BY MR. KUVIN: 19 Q. Asking those same questions, have you 19 Q. Is your mother also named ? 20 taken any nude photographs of girls under the age of 20 A. No. 21 IS from 2004 through 2006? 21 Did ou ever live at 22 A. No. 23 Q. Have you taken any nude video of girls 23 MR. : Instruct the witness not 24 under the age of 18 from 2004 to 2006? 24 to answer based on the Fifth Amendment 25 A. No. 25 privilege against self-incrimination. Page 204 Page 206 1 Q. Do you know what the COUQ Foundation is? 1 THE WITNESS: On the instruction of my 2 A. Can you repeat that? 2 lawyer, I must invoke my Fifth Amendment right. 3 Q. Do ou know what the COUQ Foundation is? 3 BY MR. KUVIN: 4 MR. Mr. Kuvin, can I clarify? 4 Did ou ever live at 5 Are you asking if she's ever heard of such an I 'n New York, New York? 6 entity or whether she actually knows what that 6 MR. : Same instruction as 7 entity is? 7 previous question. 8 MR. KUVIN: Let's start with if she's ever 8 THE WITNESS: On the instruction of my 9 heard over it, and then I will follow up with 9 lawyer, I must invoke my Fifth Amendment right. 10 the following question of whether she knows 10 BY MR. KUVIN: 11 what it is. 11 Have ou ever gone by the name of 12 MR. Okay. 12 / 13 BY MR. KUVIN: 13 MR. : Same instruction as the 14 Q. Have you ever heard of this, about the 14 previous two questions. 15 COUQ Foundation before? 15 THE WITNESS: On the instruction of my 16 MR. • I instruct her not to 16 lawyer I must invoke my Fifth Amendment right. 17 answer based on her Fifth Amendment privilege. 17 BY MR. KUVIN: 18 THE WITNESS: On the advice of my lawyer, 18 Did ou change your name from 19 I must assert my Fifth Amendment right. 19 to 9 20 BY MR. KUVIN: 20 MR. : Objection to the form and 21 Q. Were you aware that Mr. Epstein, through 21 it assumes a prior question that there was no 22 the COUQ Foundation, attempted to make a $90,000 22 answer to, and I would instruct the witness not 23 donation to the Palm Beach Police Department in 23 to answer. 24 2006? 24 THE WITNESS: Upon the instruction of my 25 MR. Objection to the form. 25 lawyer. I must invoke my Filth Amendment right. S (Pages 203 to 206) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 5 of 48 EFTA_00065369 EFTA01246515 Page 207 Page 209 1 BY MR. KUVIN: 1 compound, instruct the witness not to answer. 2 Have you ever used the alias of 2 THE WITNESS: On the instruction of my 3 i i 3 lawyer, I must invoke my Fifth Amendment right. 4 MR. Objection to the -- I'm 4 BY MR. KUVIN: 5 6 sorry. Instruct the witness not to answer based on Fifth Amendment privileges. 5 6 • Haveyou ever used illegal drugs with 7 THE WITNESS: Upon the instruction of my 7 MR. : Same objection and 8 lawyer, I must invoke my Fifth Amendment right. 8 instruction as to the previous question. 9 BY MR. KUVIN: 9 THE WITNESS: On the instruction of my 10 Q. Do ourparents live in-'f • 10 lawyer, I must invoke my Fifth Amendment right. 11 MR. Instruct the witness not 11 BY MR. KUVIN: 12 to answer the based on her Fifth 12 O. ever use the number of 13 question Amendment privilege. 13 you phone 14 THE WITNESS: On instruction of my lawyer 14 MR. : Instruct the witness not 15 I must invoke my Fifth Amendment right. 15 to answer based on her Fifth Amendment 16 BY MR. KUVIN: 16 privilege. 17 Q. Do ou have an brothers and sisters? 17 THE WITNESS: On the instruction of my 18 MR. Same instruction as the 18 lawyer, I must invoke my Fifth Amendment right. 19 previous question. 19 BY MR. KUVIN: 20 THE WITNESS: On the instruction of my 20 Have ou ever used the phone number 21 lawyer, I must invoke my Fifth Amendment right. 21 22 BY MR. KUVIN: 22 MR. : Thank you. 23 Q. Have ourparents met Jeffrey Epstein? 23 THE WITNESS: I don't recognize that 24 MR. Objection to the form. 24 number. 25 Standing objection and also instruct the 25 Page 208 Page 210 1 witness not to answer based on her Fifth 1 BY MR. KUVIN: 2 Amendment privilege. 2 Q. Okay. When the police entered Jeffrey 3 THE WITNESS: On the instruction of my 3 Epstein's home, they took something that's called a 4 lawyer, I must invoke my Fifth Amendment right. 4 bottle of Peach Flavored Joy Jelly. Just a 5 BY MR. KUVIN: 5 foundation of what I'm about to ask you. 6 Q. Do your parents know what you've done with 6 Have you ever seen anything called Peach 7 Jeffrey Epstein as it relates to this case? 7 Flavored Joy Jelly ever anywhere, first of all? 8 MR. Objection to the form as 8 Have you ever seen that before anywhere? 9 stated to the previous question, and same 9 MR. Just so I am clear about 10 instruction. 10 your question -- 11 THE WITNESS: On the instruction of my 11 MR. KUVIN: Not necessarily in a home, 12 lawyer, I must invoke my Fifth Amendment right. 12 just anywhere in her entire life has she ever 13 BY MR. KUVIN: 13 seen a bottle of something called Peach 14 Q. Have you ever used illegal drugs with 14 Flavored Joy Jelly. 15 Jeffrey Epstein? 15 THE WITNESS: No, I have not. 16 MR. Objection to the form. 16 BY MR. KUVIN: 17 Standing objection, instruct the witness not to 17 Q. Okay. Also taken from the home were, was 18 answer. 18 an adult sex toy called a Twin Torpedo which, 19 THE WITNESS: On the instruction of my 19 according to Detective Recarey during his deposition 20 lawyer, I must invoke my Fifth Amendment right. 20 was a double-headed dildo. Not with respect to 21 BY MR. KUVIN: 21 Mr. Epstein, but in your life, have you ever seen 22 Q. Have you ever used illegal drugs with 22 something called a Twin Torpedo or double-headed 23 Ghislaine Maxwell? 23 dildo? 24 MR. . Objection to the form, 24 A. No. I have not. 25 assumes knowledge of Ghislaine Maxwell. It's 25 Q. Also confiscated from the home was soap in 6 (Pages 207 to 210) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 6 of 48 EFTA_00065370 EFTA01246516 Page 211 Page 213 1 the shape of a penis and vagina. Once again, not 1 THE WITNESS: On the instruction of my 2 necessarily with respect to Mr. Epstein's home, in 2 lawyer, I must invoke my Fifth Amendment right. 3 your entire life have you ever seen soap in the 3 BY MR. KUVIN: 4 shape of a penis and vagina? 4 Q. Do you agree that these corporations that 5 A. Not that I recall. 5 I just mentioned were utilized by Jeffrey Epstein in 6 Q. Doyou ever recall being in Ohio? 6 an attempt to have sexual relationships with 7 MR. : Ever in her life? 7 underage girls? 8 MR. KUVIN: The state, ever in her life. 8 MR. : Objection to the form as 9 BY MR. KUVIN: 9 to compound. and also assumes knowledge of 10 Q. Let's start there, recall being in the 10 Mr. Epstein, asks for more than one answer to 11 State of Ohio for any reason? 11 the question. I would instruct her not to 12 A. Maybe for a layover, but not that I 12 answer based on her Fifth Amendment privilege 13 specifically remember. 13 because the question assumes knowledge of 14 Q. Okay. Do you know an Ivan Robles? 14 Mr. Epstein. 15 A. No. 15 THE WITNESS: Upon instruction of my 16 Q. Have you seen a gentleman by the name of 16 lawyer I must invoke my Fifth Amendment right. 17 Alan Dershowitz at the home of Jeffrey Epstein 17 MR. KUVIN: I think I am done. Hang on 18 before? 18 one second. 19 MR. : Objection to the form. 19 All right. I appreciate it. That's all 20 Standing objection, presumes knowledge of 20 the questions I have at this time. Reserve the 21 Jeffrey Epstein or his home. Instruct the 21 right to ask any follow-up questions if other 22 witness not to answer. 22 attorneys raise new and different issues by 23 THE WITNESS: On the instruction of my 23 theirquestionin:. 24 lawyer, I must exercise my Fifth Amendment 24 MR. Understood. 25 right. 25 MR. KUVIN: Pass the witness at this time. Page 212 Page 214 1 BY MR. KUVIN: 1 Who wants to go? Mr. Horowitz, do you have a 2 Q. Have you ever heard of the El Zorro Ranch 2 microphone? 3 Corporation? 3 MR. HOROWITZ: I do. 4 MR. Instruct the witness not 4 CROSS (MI ) 5 to answer based on her Fifth Amendment 5 BY MR. HOROWITZ: 6 privilege. 6 Q. Ms. did ou use the telephone 7 THE WITNESS: On the instruction of my 7 number, the t any time between 2001 8 lawyer I must exercise my Fifth Amendment 8 and 2006? 9 right. 9 A. On the advice of my lawyer, I must exercise my 10 BY MR. KUVIN: 10 Fifth Amendment right. 11 Q. Have you ever heard of the New York 11 . Did ou use the telephone number 12 Strategy Grou ? 12 between 2001 and 2006 at Jeffrey 13 MR. Same instruction. 13 Epstein's ex nse? 14 THE WITNESS: On the instruction of my 14 MR. : Objection to the form in 15 lawyer, I must invoke my Fifth Amendment right. 15 that it assumes knowledge of Jeffrey Epstein. 16 BY MR. KUVIN: 16 Standing objection as previously stated with 17 Q. Have you ever heard of the Ghislaine 17 Mr. Kuvin. Instruct the witness not to answer. 18 Corporation? 18 based on her Fifth Amendment right. 19 MR. Same instruction. 19 THE WITNESS: On the instruction of my 20 THE WITNESS: On the instruction of my 20 lawyer, I must exercise my Fifth Amendment 21 lawyer, I must invoke my Fifth Amendment right. 21 right. 22 BY MR. KUVIN: 22 BY MR. HOROWITZ: 23 Q. Have you ever heard of the Financial 23 Did ou use the telephone number 24 Strategy Grou .? 24 at Jeffre Epstein's direction? 25 MR. • Same instruction. 25 MR. : Same objection as the 7 (Pages 211 to 2 1 4) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 7 of 48 EFTA_00065371 EFTA01246517 Page 215 Page 217 1 previous question and the same instruction. 1 lawyer, I must choose to exercise my Fifth 2 THE WITNESS: On the instruction of my 2 Amendment right. 3 lawyer, I must exercise my Fifth Amendment 3 BY MR. HOROWITZ: 4 right. 4 Q. Did Jeffrey Epstein ever admit to you that 5 BY MR. HOROWITZ. 5 between the years 2001 and 2006 he had sexual 6 Q. Was a telephone number from 6 contact with underage girls who came to• quote. work 7 which you placed telephone calls on behalf of 7 for him? 8 Jeffrey Epstein? 8 MR. : Objection to the form. 9 MR. Same objection as the 9 standing objection previously stated. Also 10 previous question and the same instruction. 10 ambiguous as to the term "work for him." 11 THE WITNESS: On the instruction of my 11 Instruct the witness not to answer based on her 12 lawyer, I must invoke my Fifth Amendment right. 12 Fifth Amendment privilege. 13 BY MR. HOROWITZ: 13 THE WITNESS: On the instruction of my 14 Q. Between 2001 and 2006 14 lawyer, I must choose to exercise my Fifth 15 set up massa e tables for Jeffrey Epstein? 15 Amendment right. 16 MR. • Same objection as the 16 BY MR. HOROWITZ: 17 previous question, same instruction. 17 Q. Between the years 2001 and 2006. did 18 THE WITNESS: On the instruction of my 18 Jeffrey Epstein ever tell you that he masturbated in 19 lawyer, I must invoke my Fifth Amendment right. 19 the presence of underage girls who came to. quote• 20 BY MR. HOROWITZ: 20 work for him? 21 Q. Between 2001 and 2006, 21 MR. : Objection to the form. 22 arrange massage oils before Jeffrey Epstein's 22 Standing objection previously stated and 23 massages? 23 instruct the witness not to answer. 24 MR. Objection to the form. 24 THE WITNESS: On the instruction of my 25 It's compound and assumes facts not admitted to 25 lawyer, I must exercise my Fifth Amendment Page 216 Page 218 1 be to the knowledge of this witness, and I 1 right. 2 instruct her not to answer based on her Fifth 2 BY MR. HOROWITZ: 3 Amendment privilege. 3 Q. Do you know a girl named -- or did you 4 THE WITNESS: On the instruction of my 4 know a girl named Jane Doe No. 2. (spells name), 5 lawyer, I must invoke my Fifth Amendment right. 5 when she was still under the age of 18? 6 BY MR. HOROWITZ: 6 A. On the instruction of my lawyer, I must choose 7 At any time between 2001 and 2006, 7 to invoke my Fifth Amendment right. I to place telephone calls to girls under the 8 Q. Do you acknowledge that Jane Doe No. 2 9 age of IS when Jeffrey Epstein was in Palm Beach to 9 came to Jeffrey Epstein's Palm Beach estate in late 10 see if the girls wanted to. quote/unquote, work? 10 2004? 11 MR. Objection to the form as 11 MR. Objection to the form. 12 compound and instruct the witness not to answer 12 Standing objection previously stated as to 13 based on her Fifth Amendment privilege. 13 compound and ambiguous, and I instruct the 14 THE WITNESS: On the instruction of my 14 witness not to answer based on her Fifth 15 lawyer, I must invoke my Fifth Amendment right. 15 Amendment privilege, based on the prior, based 16 BY MR. HOROWITZ: 16 on the prior answer to the prior question. 17 Q. Between the years 2001 and 2006, did you 17 THE WITNESS: Sony. 18 and Jeffrey Epstein have an understanding between 18 MR. HOROWITZ: There was a question 19 the two of you that the term "work" referred to him 19 pending. 20 having sexual contact with girls under the age of 20 MR. There was a question 21 18? 21 pending. I have instructed you not to answer. 22 MR. Objection to the form, 22 THE WITNESS: Oh. then upon the 23 standing object, standing objection, and 23 instruction of my lawyer. I must invoke my 24 instruct the witness not to answer. 24 Fifth Amendment right. 25 THE WITNESS: On the instruction of m 25 8 (Pages 215 to 218) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 8 of 48 EFTA_00065372 EFTA01246518 Page 219 Page 221 1 BY MR. HOROWITZ: 1 THE WITNESS: On the instruction of my 2 Q. Between the years 2001 and 2006. did 2 lawyer, I must invoke my Fifth Amendment right. 3 Jeffrey, did Jeffrey Epstein instruct you to 3 BY MR. HOROWITZ: 4 communicate by telephone to arrange for girls under 4 Q. Did you tell Jeffrey Epstein that you had 5 the age of 18 to come to his house for his sexual 5 to confirm by telephone that Jane Doe No. 2 would be 6 gratification? 6 coming to his home at a specific time to give him a 7 MR. : Objection to the form. 7 massage? 8 Standing objection previously stated, and also 8 MR. Objection to the form. 9 it's ambiguous. Instruct the witness not to 9 standing objection as previously stated, and 10 answer based on her Fifth Amendment privilege. 10 the same instruction to the witness. 11 THE WITNESS: On the instruction of my 11 THE WITNESS: On the instruction of my 12 lawyer, I must exercise my Fifth Amendment 12 lawyer, I must invoke my Fifth Amendment right. 13 privilege. 13 BY MR. HOROWITZ: 14 BY MR. HOROWITZ: 14 Q. Did Jeffrey Epstein tell you that it was 15 Q. In late 2004, did you receive a telephone 15 his intent during the course of Jane Doe No. 2's 16 call wherein you were told that a girl named Jane 16 visit to his home to have sexual contact with her? 17 Doe No. 3 was bringing Jane Doe No. 2 to Jeffrey 17 MR. Objection to the form as 18 Epstein's home? 18 previously stated to the last question and same 19 MR. : Objection to form. 19 instruction to the witness. 20 Standing objection, compound, and instruct the 20 THE WITNESS: On the instruction of my 21 witness not to answer based upon her Fifth 21 lawyer, I must invoke my Fifth Amendment right. 22 Amendment privilege. 22 BY MR. HOROWITZ: 23 THE WITNESS: On the instruction of my 23 Q. At any point did Jane Doe No. 2 tell you 24 25 lawyer, I must exercise my Fifth Amendment right. 24 25 that she was I8 ears old or older? MR. Objection to the form, Page 220 Page 222 1 BY MR. HOROWITZ: 1 assumes knowledge of a person by the name of 2 Q. Did Jeffrey Epstein observe you receive a 2 Jane Doe No. 2. It's a compound question and 3 telephone call wherein you were told that Jane Doe 3 instruct the witness not to answer. 4 No. 3 was brio in Jane Doe No. 2 to his home? 4 THE WITNESS: On the instruction of my 5 MR. Standing objection to the 5 lawyer, I must invoke my Fifth Amendment right. 6 form as stated to the previous question, same 6 BY MR. HOROWITZ: 7 instruction. 7 Q. In your own mind, is it. is it accurate to 8 THE WITNESS: On the instruction of my 8 say that you never believed that Jane Doe No. 2 was 9 lawyer, I must invoke my Fifth Amendment right. 9 18 or older correct? 10 BY MR. HOROWITZ: 10 MR. Objection to the form, 11 Q. Did Jeffrey Epstein instruct you to 11 same basis as the prior question, and the same 12 communicate by telephone to arrange for Jane Doe 12 instruction. 13 No. 2 to come to his home for his sexual 13 THE WITNESS: On the instruction of my 14 gratification? 14 lawyer, I must invoke my Fifth Amendment right. 15 MR. Standing objection as 15 BY MR. HOROWITZ: 16 previously stated, same instruction to the 16 Q. Did Jane Doe No. 2 tell ou that she 17 witness. 17 attended . 18 THE WITNESS: On the instruction of my 18 MR. Same objection as the 19 lawyer, I must invoke my Fifth Amendment right. 19 previous question, same instruction. 20 BY MR. HOROWITZ: 20 THE WITNESS: On the instruction of my 21 Q. Did Jeffrey Epstein inform you that Jane 21 lawyer, I must invoke my Fifth Amendment right. 22 Doe No. 2 would be giving him a massage that was 22 BY MR. HOROWITZ: 23 sexual in nature? 23 Q. Are you aware -- did, did Jeffrey Epstein 24 MR. . Standing objection to the 24 tell you that he sexually abused Jane Doe No. 2 when 25 form and the same instruction to the witness. 25 she was a child? 9 (Pages 219 to 222) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 9 of 48 EFTA_00065373 EFTA01246519 Page 223 Page 225 1 MR. Objection to the form. 1 answer that. You can move on. 2 Standing objection relating to Jeffrey Epstein 2 MR. HOROWITZ: You're, you're directing 3 or any knowledge of Jeffrey Epstein. Also as 3 her not to answer that? 4 to Jane Doe No. 2, same instruction to the 4 MR. I'm directing her not to 5 witness. 5 answer that question because there are. there 6 THE WITNESS: On the instruction of my 6 are legal bases for the objections that 7 lawyer, I must invoke my Fifth Amendment right. 7 underlie the Fifth Amendment invocation, and at 8 BY MR. HOROWITZ: 8 some point presumably a judge will rule on 9 Q. Did Jeffrey Epstein instruct you to take 9 those before the jury ever hears this. 10 Jane Doe No. 2's name and telephone number for the 10 BY MR. HOROWITZ: 11 purpose of calling her to come to his house for more 11 Q. Ms. did you know a girl named Jane 12 13 sexual activit ? MR. Objection to the form. 13 12 Doe No. 3 when she was still a child? MR. Objection to the form as 14 Standing objection, same objection to the 14 to what you mean by when you say a child and 15 previous question, same instruction. 15 also assumes knowledge of a person, so I 16 THE WITNESS: On the instruction of my 16 instruct the witness not to answer. 17 lawyer, I must invoke my Fifth Amendment right. 17 THE WITNESS: On the instruction of my 18 BY MR. HOROWITZ: 18 lawyer, I must invoke my Fifth Amendment right. 19 Q. Did Jeffrey Epstein instruct you to put 19 BY MR. HOROWITZ: 20 Jane Doe No. 2's name and telephone number into a 20 Q. Did, did Jeffrey Epstein instruct ou to 21 master journal or log in which you and he archived 21 communicate by telephone with for the 22 the names and contact information of teenage girls? 22 purpose of arranging for underage girls to come to 23 MR. Objection to the form, 23 his house so that he. Jeffrey Epstein, could engage 24 standing objection, otherwise compound and 24 in sexual activit ? 25 instruct the witness not to answer. 25 MR. Objection to the form. Page 224 Page 226 1 1 THE WITNESS: On the instruction of my 1 Standing objection, compound and ambiguous. 2 lawyer, I must invoke my Fifth Amendment right. 2 Instruct the witness not to answer on Fifth 3 BY MR. HOROWITZ 3 Amendment grounds. 4 Q. Did you, in fact, place Jane Doe No. 2's 4 THE WITNESS: On the instruction of my 5 name and telephone number into a master journal or 5 lawyer, I must invoke my Fifth Amendment right. 6 log in which you and Jeffrey Epstein archived the 6 BY MR. HOROWITZ: 7 names and contact information for teenage girls? 7 Q. Did Jeffrey Epstein instruct you to 8 MR. Objection to the form, 8 communicate by telephone to arrange for Jane Doe No. 9 same as the previous question, ambiguous and 9 3 to give him a massy e? 10 compound, and I instruct the witness not to 10 MR. : Same objection as stated 11 answer. 11 to the previous question. and standing 12 THE WITNESS: On the instruction of my 12 objection. and instruct the witness not to 13 lawyer, I must invoke my Fifth Amendment right. 13 answer. 14 BY MR. HOROWITZ: 14 THE WITNESS: On the instruction of my 15 Q. You have asserted a Fifth Amendment 15 lawyer, I must invoke my Fifth Amendment right. 16 objection as to a number of my questions relating to 16 BY MR. HOROWITZ: 17 Jane Doe No. 2. Is there any reason in your mind a 17 Q. Did Jeffrey Epstein inform you that the 18 jury should not infer from your responses today that 18 massage Jane Doe No. 3 was to give him would be 19 you did, in fact, assist Mr. Epstein in procuring 19 sexual in nature? 20 minors for sexual activi ? 20 MR. : Same standing objection 21 MR. Right. Objection to the 21 previously stated, and I instruct the witness 22 form. We're not going to answer that. That 22 not to answer. 23 calls for a legal conclusion, and for her to 23 THE WITNESS: On the instruction of my 24 speculate on legal objections that have been 24 lawyer, I must invoke my Fifth Amendment right. 25 made by her counsel. and were not going to 25 10 (Pages 223 to 226) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 10 of 48 EFTA_00065374 EFTA01246520 1 Page 227 BY MR. HOROWITZ: 1 Page 229 MR. Same objection to the 2 Q. Did Jeffrey Epstein observe you speaking 2 previous question, same instruction. 3 with by telephone arranging for Jane 3 THE WITNESS: On the instruction of my i 4 Doe No. 3 to come to his home to give him a massage. 4 lawyer, I must invoke my Fifth Amendment right. 5 MR. Objection to the form. 5 BY MR. HOROWITZ: 6 Standing objection, otherwise compound and 6 •. Jane Doe No. 3 told you she attended- 7 ambiguous and instruct the witness not to I correct? 8 answer. 8 MR. Instruct the witness not 9 THE WITNESS: On the instruction of my 9 to answer based on her Fifth Amendment 10 lawyer, I must invoke the Fifth Amendment 10 privilege. 11 right. 11 THE WITNESS: On the instruction of my 12 BY MR. HOROWITZ: 12 lawyer, I must invoke my Fifth Amendment right. 13 Q. Did you tell Jeffrey Epstein that you had 13 BY MR. HOROWITZ: 14 confirmed by telephone that Jane Doe No. 3 would be 14 Q. Did Jeffrey Epstein instruct you to take 15 coming to his home, his home at a specific time to 15 Jane Doe No. 3's name and telephone number for the 16 give him a massy e? 16 purpose of calling her to come back to his home for 17 MR. Same objection as stated 17 more sexual activit ? 18 to the previous question. Same instruction to 18 MR. Objection to the form. 19 the witness. 19 standing objection previously stated. Instruct 20 THE WITNESS: On the instruction of my 20 the witness not to answer. 21 lawyer, I must invoke my Fifth Amendment right. 21 THE WITNESS: On the instruction of my 22 BY MR. HOROWITZ: 22 lawyer I must invoke my Fifth Amendment right. 23 Q. Did Jeffrey Epstein tell you it was his 23 BY MR. HOROWITZ: 24 intent during the course of Jane Doe No. 3's visit 24 Q. Did you, in fact, after Jane Doe No. 3's 25 to his home to engage her in sexual activity? 25 first visit to Jeffrey Epstein's home, call her to Page 228 Page 230 1 MR. Same objection stated to 1 arrange for her to come back to his house for more 2 the previous two questions and the same 2 sexual activi ? 3 instruction. 3 MR. Standing objection to the 4 THE WITNESS: On the instruction of my 4 form of the question. Instruct the witness not 5 lawyer, I must invoke my Fifth Amendment right. 5 to answer. 6 BY MR. HOROWITZ: 6 THE WITNESS: On the instruction of my 7 Q. Did Jeffrey Epstein tell you that during 7 lawyer I must invoke my Fifth Amendment right. 8 the course of Jane Doe No. 3's visit to his home. 8 BY MR. HOROWITZ: 9 that he did, in fact, persuade her to engage in 9 Q. Did Jeffrey Epstein instruct you to put 10 sexual activit ? 10 Jane Doe No. 3's name and telephone number into a 11 MR. : Objection to the form. 11 master journal or log in which you and he archived 12 Standing objection previously stated. Instruct 12 the names and contact information for underage 13 the witness not to answer. 13 girls? 14 THE WITNESS: On the instruction of my 14 MR. Objection to the form, 15 lawyer, I must invoke my Fifth Amendment right. 15 standing objection. Otherwise compound and 16 BY MR. HOROWITZ: 16 ambiguous and instruct the witness not to 17 Q. At any point did Jane Doe No. 3 tell you 17 answer. 18 that she was 18 or older? 18 THE WITNESS: On the instruction of my 19 MR. Objection to the form and 19 lawyer I must invoke the Fifth Amendment. 20 instruct the witness not to answer. 20 BY MR. HOROWITZ: 21 THE WITNESS: On the instruction of my 21 Q. Did you, in fact, put Jane Doe No. 3's 22 lawyer, I must invoke my Fifth Amendment right. 22 name and telephone number into a master journal or 23 BY MR. HOROWITZ: 23 log, in which you and Jeffrey Epstein had archived 24 Q. In your mind you didn't believe that Jane 24 the names and information of teenage girls? 25 Doe No. 3 was 18 or older. correct? 25 MR. Objection to the font). 11 (Pages 227 to 230) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 11 of 48 EFTA_00065375 EFTA01246521 Page 231 Page 233 1 standing objection and otherwise compound and 1 answer. 2 instruct the witness not to answer. 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 exercise my Fifth Amendment 4 BY MR. HOROWITZ: 5 right. 5 . Did ou, in fact, communicate with 6 BY MR. HOROWITZ: 6 by telephone to arrange for Jane Doe 7 Q. Okay. You've asserted a Fifth Amendment 7 to Jeffre No. 4 to come Epstein's home? 8 objection and assertion of the privilege as to my 8 MR. : Standing objection as 9 questions about Jane Doe No. 3. Is there any reason 9 previously stated. Instruct the witness not to 10 why a jury should not infer from your assertion of 10 answer. 11 the privilege that you did, in fact, assist 11 THE WITNESS: On the instruction of my 12 Jeffrey Epstein in procuring minors for his sexual 12 lawyer, I must invoke my Fifth Amendment right. 13 pleasure? 13 BY MR. HOROWITZ: 14 MR. : Same objection I stated 14 Q. Did Jeffrey Epstein inform you that the 15 the last time as to the other client. There 15 massage Jane Doe No. 4 was to give him would be 16 have been legal objections lodged to the 16 sexual in nature? 17 questions. If a judge rules as to the legality 17 MR. : Objection to the form. 18 of the questions and the propriety of the 18 Standing objection previously stated. Instruct 19 answers, then the jury can draw whatever 19 the witness not to answer. 20 inference the judge's instructs them to draw. 20 THE WITNESS: On the instruction of my 21 but until then we're not going to speculate on 21 lawyer, I must invoke my Fifth Amendment right. 22 what the jury ought to conclude based on 22 BY MR. HOROWITZ: 23 questions that haven't been ruled to be proper. 23 Q. Did Jeffre Epstein observe you speaking 24 MR. HOROWITZ: So were clear, you have 24 with to arrange for Jane Doe No. 4 to 25 instructed her not to answer? 25 come to his home for sexual activity? Page 232 Page 234 1 MR. : I've instructed her not to 1 MR. : Objection to the form. 2 answer, yes. 2 Standing objection as previously stated, and 3 BY MR. HOROWITZ: 3 compound and ambiguous and instruct the witness 4 Q. Ms. did you know a girl named Jane 4 not to answer. 5 Doe No. 4 when she was still a child? 5 THE WITNESS: On the instruction of my 6 A. On the instruction of my lawyer, I must invoke 6 lawyer, I choose to invoke my Fifth Amendment 7 my Fifth Amendment right. 7 right. 8 Q. Did Jane Doe No. 4 come to 8 BY MR. HOROWITZ: 9 Jeffrey Epstein's Palm Beach home on multiple 9 Q. Prior to May of 2005, did you answer phone 10 occasions between 2003 and 2005? 10 calls at Jeffrey Epstein's home from Jane Doe No. 4 11 MR. : Objection to the form. 11 during which you arranged for Jane Doe No. 4 to come 12 standing objection. Otherwise compound and 12 to Jeffrey E• stein's home? 13 instruct the witness not to answer based on her 13 MR. : Objection to the form. 14 Fifth Amendment privilege. 14 Standing objection previously stated. It's 15 THE WITNESS: On the instruction of my 15 compound. and instruct the witness not to 16 lawyer, I must choose to invoke my Fifth 16 answer. 17 Amendment right. 17 THE WITNESS: At the instruction of my 18 BY MR. HOROWITZ: 18 lawyer, I must invoke my Fifth Amendment right. 19 Q. At any time prior to May of 2005 did 19 BY MR. HOROWITZ: 20 21 Jeffre E stein instruct you to communicate with by telephone to arrange for Jane Doe 20 21 Q. Prior to May of 2005, did Jeffrey Epstein observe you speaking with Jane Doe No. 4 by 22 No. 4 to come to his home? 22 telephone after your making arrangements for Jeff -- 23 MR. : Standing objection to the 23 for Jane Doe No. 4 to come to his home? 24 form of the question. Otherwise ambiguous and 24 MR. : Objection to the form. 25 compound. and instruct the witness not to 25 standing objection. and instruct the witness 12 (Pages 231 to 23 4) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 12 of 48 EFTA_00065376 EFTA01246522 Page 235 Page 237 1 not to answer. 1 Standing objection and instruct the witness not 2 THE WITNESS: On the instruction of my 2 to answer. 3 lawyer, I must invoke my Fifth Amendment right. 3 THE WITNESS: On the instruction of my 4 BY MR. HOROWITZ: 4 lawyer, I must invoke my Fifth Amendment right. 5 Q. Prior to May of 2005, did Jeffrey Epstein 5 BY MR. HOROWITZ: 6 instruct you to get Jane Doe No. 4's telephone 6 Q. Did Jane Doe No. 4 tell you and 7 number so that you could communicate with her for 7 Jeffrey Epstein that she attended Royal Palm Beach 8 the purpose of schedulin future massages? 8 High School? 9 MR. Objection to the form, 9 MR. Objection to the form. 10 standing objection, otherwise compound and 10 standing objection. instruct the witness not to 11 instruct the witness not to answer. 11 answer. 12 THE WITNESS: On the instruction of my 12 THE WITNESS: On the instruction of my 13 lawyer, I must invoke my Fifth Amendment 13 lawyer, I must invoke my Fifth Amendment right. 14 privilege. 14 BY MR. HOROWITZ: 15 BY MR. HOROWITZ: 15 Q. Did Jane Doe No. 4 re:ularl discuss her 16 Q. Did you on multiple occasions tell Jeffrey 16 life at with you in the 17 Epstein that you had confirmed by telephone that 17 presence of Jeffrey E tein? 18 Jane Doe No. 4 would be coming to his home for a -- 18 MR. : Objection to form, 19 at a specific time to ive him a massage? 19 standing objection as well as ambiguous as to 20 MR. Objection to the form. 20 what "regularly" means. Instruct the witness 21 It's compound and standing objection as well. 21 not to answer. 22 and instruct the witness not to answer. 22 THE WITNESS: On the instruction of my 23 THE WITNESS: On the instruction of my 23 lawyer, I must invoke my Fifth Amendment right. 24 lawyer, I must invoke my Fifth Amendment 24 BY MR. HOROWITZ: 25 privilege. 25 Q. Did Jane Doe No. 4 come to Jeffrey Page 236 Page 238 1 BY MR. HOROWITZ: 1 Epstein's Palm Beach home on dozens of occasions 2 Q. Did Jeffrey Epstein tell you it was his 2 between 2003 and May of 2005, to give him massages 3 intent during the course of Jane Doe No. 4's visits 3 during which he en a ed her in sexual activity? 4 to his home to induce her to engage in sexual 4 MR. Objection to the form, 5 activity? 5 standing objection. It's also otherwise 6 MR. : Objection to the form. 6 compound and instruct the witness not to 7 standing objection and instruct the witness not 7 answer. 8 to answer. 8 THE WITNESS: On the instruction of my 9 THE WITNESS: On the instruction of my 9 lawyer, I must invoke my Fifth Amendment right. 10 lawyer. I must invoke my Fifth Amendment right. 10 BY MR. HOROWITZ: 11 11 Q. Prior to May of 2005, did Jeffrey Epstein BY MR. HOROWITZ: 12 Q. Did Jeffrey Epstein tell you that, in 12 instruct you to communicate with Jane Doe No. 4. via 13 fact, during Jane Doe No. 4 -- 4's visits to his 13 telephone, to arrange for Jane Doe No. 4 to come to 14 home. he was able to induce her to engage in sexual 14 his Palm Beach home so he could engage Jane Doe 15 activity? 15 No. 4 in sexual activit ? 16 MR. Objection to the form. 16 MR. Objection to the form as 17 same objection as the previous questions. 17 stated in the previous question. Same 18 Instruct the witness not to answer. 18 instruction to the witness. 19 THE WITNESS: On the instruction of my 19 THE WITNESS: On the instruction of my 20 lawyer. I must invoke my Fifth Amendment right. 20 lawyer, I must invoke my Fifth Amendment right. 21 BY MR. HOROWITZ: 21 BY MR. HOROWITZ: 22 Q. Did both you and Jeffrey Epstein know that 22 Q. Did Jeffrey Epstein instruct you to tell 23 Jane Doe No. 4 was younger than 18 when she came to 23 Jane Doe No. 4 to lie to police investigators during 24 Jeffrey Epstein's home in 2003 and 2004? 24 the course of their 2005 investigation? 25 MR. : Objection to the foi tn. 25 MR. Objection to the form as 13 (Pages 235 to 238) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 13 of 48 EFTA_00065377 EFTA01246523 Page 239 Page 241 1 stated to the last several questions and 1 MR. Objection to the form. 2 instruct the witness not to answer. 2 Its a compound question and standing objection 3 THE WITNESS: On the instruction of my 3 as well. Instruct the witness not to answer. 4 lawyer, I must invoke my Fifth Amendment right. 4 THE WITNESS: On the instruction of my 5 5 lawyer. I must invoke my Fifth Amendment right. BY MR. HOROWITZ: 6 Q. Did you, in fact, tell Jane Doe No. 4 to 6 BY MR. HOROWITZ: 7 lie to police invest, investigators during the 7 Q. Did you inform Jeffrey Epstein that you 8 course of their 2005 investigation of Jeffrey 8 had been provided Jane Doe No. 5's telephone number? 9 Epstein? 9 MR. Same objection as the 10 MR. : Object to the form because 10 previous question, same instruction. 11 it presumes knowledge of Jane Doe No. 4. 11 THE WITNESS: Upon instruction of my 12 Instruct the witness not to answer. 12 lawyer, I must invoke my Fifth Amendment right. 13 THE WITNESS: Upon the instruction of my 13 BY MR. HOROWITZ: 14 lawyer. I must invoke my Fifth Amendment right. 14 Q. Did Jeffrey Epstein instruct you to call 15 BY MR. : 15 Jane Doe No. 5 to come to his home and give him a 16 Q. Okay. You've asserted a Fifth Amendment 16 massage in either 2001 or 2002? 17 objection and privilege as to my questions about 17 MR. Objection to the form. 18 Jane Doe No. 4, yourself. and Jeffrey Epstein. Is 18 same objection as the previous questions and 19 there any reason in your mind why a jury should not 19 same instruction to the witness. 20 infer from your assertion of the privilege that you 20 THE WITNESS: On the instruction of my 21 did, in fact, assist Mr. Epstein in committing 21 lawyer, I must invoke my Fifth Amendment right. 22 sexual abuse u n Jane Doe No. 4? 22 BY MR. HOROWITZ: 23 MR. : I am going to instruct the 23 Q. Did Jeffrey Epstein inform you that the 24 witness not to answer the question for the 24 massage Jane Doe No. 5 was to give him would be 25 reasons I stated at the last client that we 25 sexual in nature? Page 240 Page 242 1 discussed. The questions are legally not 1 MR. : Same objection previously 2 proper in our view, and therefore the questions 2 stated, standing objection and instruct the 3 and answers should not be held against her 3 witness not to answer. 4 until a judge rules on the propriety of the 4 THE WITNESS: Upon the instruction of my 5 questions. And we can address that another 5 lawyer, I must invoke my Fifth Amendment right. 6 day. I'm instructing her not to answer. 6 BY MR. HOROWITZ: 7 BY MR. HOROWITZ: 7 Q. Did Jeffrey Epstein observe you speaking 8 Q. Okay. Ms. do you know a girl 8 with Jane Doe No. 5 on the telephone to arrange for 9 named Jane Doe No. 5 when she was still a child 9 Jane Doe No. 5 to come to his home for a massage? 10 under the age of 18? 10 MR. : Same objection as previous 11 A. At the instruction my lawyer. I must invoke my 11 questions and same, to the form of the 12 Fifth Amendment right. 12 question, and same instruction. 13 Q. Did a child under the age of 18 named Jane 13 THE WITNESS: Upon the instruction of my 14 Doe No. 5 come to Jeffrey Epstein's Palm Beach home 14 lawyer, I must invoke my Fifth Amendment right. 15 in approximate) 2001 or 2002? 15 BY MR. HOROWITZ: 16 MR. Objection to the form. 16 Q. Did you tell Jeffrey Epstein that you had 17 Instruct the witness not to answer. 17 confirmed by telephone that Jane Doe No. 5 would be 18 THE WITNESS: On the instruction of my 18 at his home at a specific time to give him a 19 lawyer, I must invoke my Fifth Amendment right. 19 massage? 20 BY MR. HOROWITZ: 20 MR. : Objection to the form and 21 Q. In 2001 or 2002 did you inform 21 instruct the witness not to answer. 22 Jeffrey Epstein that you received a telephone call 22 THE WITNESS: On the instruction of my 23 in which you were referred to an underage girl named 23 lawyer, I must invoke my Fifth Amendment right. 24 Jane Doe No. 5 who would be willing to come to his 24 BY MR. HOROWITZ: 25 home to give him a massage for money? 25 Q. Did Jeffrey Epstein tell you that it was 14 (Pages 239 to 242) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 14 of 48 EFTA_00065378 EFTA01246524 Page 243 Page 245 1 his intent, during the course of Jane Doe No. 5's 1 Amendment objection or privilege as to my questions 2 visit to his home, to persuade her to engage in 2 about Jane Doe No. 5. Is there any reason in your 3 sexual activ it ? 3 mind why a jury should not infer that the reason 4 MR. : Objection to the form. 4 you're asserting the Fifth Amendment is because you 5 standing objection. Instruct the witness not 5 and Jeffrey Epstein committed a crime in inducing 6 to answer based on Fifth Amendment. 6 and enticing Jane Doe No. 5 to come to his home for 7 THE WITNESS: On the instruction of my 7 sexual activit ? 8 lawyer. I must invoke my Fifth Amendment right. 8 MR. : Once again. I instruct the 9 9 witness not to answer. Legal basis is the BY MR. HOROWITZ: 10 Q. Did Jeffrey Epstein tell you that during 10 question is not reasonably calculated to lead 11 the course of Jane Doe No. 5's visit to his home in 11 to admissible evidence. It's not otherwise 12 either 2001 or 2002 that he succeeded in persuading 12 proper discovery. And for the reasons I stated 13 her to enga e in sexual activity with him? 13 as to the prior witnesses, until the legality 14 MR. : Objection to the form. 14 and propriety of the questions is ruled upon by 15 standing objection. Otherwise compound and 15 the court, there should be no inference drawn. 16 instruct the witness not to answer based on the 16 BY MR. HOROWITZ: 17 Fifth Amendment. 17 Q. Ms. -- 18 THE WITNESS: On the instruction by my 18 MR. : One second. Go ahead. 19 lawyer, I must invoke my Fifth Amendment right. 19 I'm sorry. 20 20 MR. HOROWITZ: You're conferring about a BY MR. HOROWITZ: 21 Q. Did Jeffrey Epstein instruct you to take 21 privilege I trust? 22 Jane Doe No. 5's name and telephone number down so 22 MR. : Yes, privilege issue. 23 that you and he could call Jane Doe No.5 to come to 23 BY MR. HOROWITZ: 24 his home for more sexual activity? 24 Q. Ms. , do, did you know a girl named 25 MR. Objection to the form. 25 Jane Doe No. 6 when she was still a child under the Page 244 Page 246 1 Instruct the witness not to answer. 1 age of 18? 2 THE WITNESS: On the instruction of my 2 A. At the advice of counsel, I must invoke my 3 lawyer, I must invoke my Fifth Amendment right. 3 Fifth Amendment right. 4 BY MR. HOROWITZ: 4 Q. Ms. . did Jane Doe No. 6 come to 5 Q. After Jane Doe No. 5's first visit, did 5 Jeffrey Epstein's Palm Beach home in approximately 6 Jeffrey Epstein instruct you to call her on the 6 August of 2004 when she was still a child? 7 telephone to arrange for her to come back for more 7 MR. : Objection to the form, 8 sexual activit ? 8 standing objection, and instruct the witness 9 MR. : Objection to the form as 9 not to answer. 10 previously stated, and form, standing objection 10 THE WITNESS: On the instruction of 11 and instruct the witness not to answer. 11 counsel, I must invoke my Fifth Amendment 12 THE WITNESS: On the instruction of my 12 right. 13 lawyer, I must invoke my Fifth Amendment right. 13 BY MR. HOROWITZ: 14 BY MR. HOROWITZ: 14 Q. Ms. =, were you aware that Jane Doe 15 Q. Did you, in fact, call Jane Doe No. 5 on 15 No. 6 was just 13 years old when she came to Jeffrey 16 the telephone to arrange for her to come back to 16 Epstein's home in Au ust of 2004? 17 Jeffrey Epstein's home for more sexual activity? 17 MR. : Objection to the form. It 18 MR. : Same objection previously 18 assumes multiple facts. It's therefore 19 stated, and standing objection, and instruct 19 compound. Instruct the witness not to answer. 20 the witness not to answer and objection to 20 THE WITNESS: On the advice of counsel, I 21 form. 21 must invoke my Fifth Amendment right. 22 THE WITNESS: On the instruction of my 22 BY MR. HOROWITZ: 23 lawyer, I must invoke my Fifth Amendment right. 23 Q. In 2004 did you receive a phone call from 24 BY MR. HOROWITZ: 24 a girl named M. wherein she stated she was 25 Q. Ms.= you have asserted a Fifth 25 bringing Jane Doe No. 6 to Jeffrey Epstein, home 15 (Pages 243 to 246) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 15 of 48 EFTA_00065379 EFTA01246525 Page 247 Page 249 1 2 for a massa e? MR. Objection to the form. 1 2 THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. 3 Instruct the witness not to answer. 3 BY MR. HOROWITZ: 4 THE WITNESS: On the advice of counsel, I 4 Q. Did Jeffrey Epstein observe you speaking 5 must invoke my Fifth Amendment right. 5 with.. by telephone to arrange for Jane Doe No. 6 BY MR. HOROWITZ: 6 to come to his home for a massage? 7 Q. Did Jeffrey Epstein instruct ou to 7 MR. Objection to the for 8 communicate by telephone with M. for the purpose 8 standing objection and otherwise compound 9 of under -- arranging for underage minor girls to 9 instruct the witness not to answer. 10 come to his home for a massage? 10 THE WITNESS: On the instruction of my 11 MR. : Objection to the form. 11 lawyer, I must invoke my Fifth Amendment right. 12 It's a compound question. Instruct the witness 12 BY MR. HOROWITZ: 13 not to answer. 13 Q. Did Jeffrey E stein confirm with you that 14 THE WITNESS: On the advice of counsel, I 14 you had spoken with M. by telephone to confirm a 15 must invoke my Fifth Amendment right. 15 specific time that Jane Doe No. 6 would be at his 16 BY MR. HOROWITZ: 16 home? 17 Q. Did you, in fact, communicate by telephone 17 MR. Objection to the form, 18 with M. for the purpose of arranging for underage 18 standing objection. Instruct the witness not 19 minor girls to come to Jeffrey Epstein's home to 19 to answer. 20 give him a masse e? 20 THE WITNESS: On the instruction of my 21 MR. Same objection stated to 21 lawyer, I choose to invoke my Fifth Amendment 22 the previous question. Same instruction to the 22 right. 23 witness. 23 BY MR. HOROWITZ: 24 THE WITNESS: On the instruction of my 24 Q. Did Jeffrey Epstein tell you that it was 25 lawyer, I must invoke my Fifth Amendment right. 25 his intention during the course of Jane Doe No. 6's Page 248 Page 250 1 BY MR. HOROWITZ: 1 visit to his home to persuade her to engage in 2 Q. In 2004 did JefLrey Epstein instruct you 2 sexual activi with him? 3 to communicate with M. by telephone to arrange for 3 MR. : Objection to the form, 4 Jane Doe No. 6 to give him, to give him a massage 4 standing objection. Instruct the witness not 5 6 for his own sexual ratification? MR. : Objection to the form for 5 6 to answer. THE WITNESS: At the instruction of my 7 the same reasons stated to the previous 7 lawyer, I must choose to invoke my Fifth 8 questions and instruct the witness not to 8 Amendment right. 9 answer. 9 BY MR. HOROWITZ: 10 THE WITNESS: On the instruction of my 10 Q. Did Jeffrey Epstein tell you that during 11 lawyer I must invoke my Fifth Amendment right. 11 the course of Jane Doe No. 6's visit to his home he 12 12 succeeded in persuading her to engage in sexual BY MR. HOROWITZ: 13 Q. Did you, in fact, communicate with M. by 13 activity with him? 14 telephone to arrange for Jane Doe No. 6 to come to 14 MR. : Same objection as stated 15 Jeffrey Epstein's home for his sexual gratification? 15 to the previous question to form. Instruct the 16 MR. : Objection to the form. 16 witness not to answer. 17 Instruct the witness not to answer. 17 THE WITNESS: On the instruction of my 18 THE WITNESS: On the instruction of my 18 lawyer, I must invoke my Fifth Amendment right. 19 lawyer, I must invoke my Fifth Amendment right. 19 BY MR. HOROWITZ: 20 20 Q. Did Jeffrey Epstein instruct you to take BY MR. HOROWITZ: 21 Q. Did Jeffrey Epstein inform you that the 21 Jane Doe No. 6's name and telephone number to call 22 massage Jane Doe No. 6 was to give him would be 22 her to come to his home for more sexual activity 23 sexual in nature? 23 with him? 24 MR. : Objection to the form. 24 MR. : Objection to the form. 25 Instruct the witness not to answer. 25 Instruct the %tiness not to answer. 16 (Pages 247 to 250) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 16 of 48 EFTA_00065380 EFTA01246526 Page 251 Page 253 1 THE WITNESS: On the instruction of my 1 MR. Instruct the witness not 2 lawyer, I must invoke my Fifth Amendment right. 2 to answer the question for the legal reasons I 3 BY MR. HOROWITZ: 3 previously stated. Also the Fifth Amendment is 4 Q. Did you, in fact, take Jane Doe No. 6's 4 designed to protect both the innocent and the 5 name and telephone number down so that you could 5 guilty, and I would just assert the same things 6 call her to come to Jeffrey Epstein's home for more 6 I previously said, that until a judge rules on 7 sexual activit ? 7 the propriety of the questions, there should be 8 MR. Objection to form. 8 no negative inference drawn from the answer. 9 Instruct the witness not to answer. 9 BY MR. HOROWITZ: 10 THE WITNESS: At the instruction of my 10 Q. Ms. M are, are you asserting your 11 lawyer, I must invoke my Fifth Amendment right. 11 Fifth Amendment privilege today because you're an 12 BY MR. HOROWITZ: 12 innocent person, or to conceal your criminal 13 Q. Did Jeffrey Epstein instruct you to put 13 activity? 14 Jane Doe No. 6's name and telephone number into a 14 MR. : I am going to instruct her 15 master journal or log in which he archived the names 15 not to answer that question. That's not a 16 and contact information of teenage girls with whom 16 proper question. She could invoke the Fifth 17 18 he had sexual activit ? MR. Objection to the form. 17 18 Amendment for any reason. She doesn't have to explain why. If a judge wants to ask her that. 19 Instruct the witness not to answer. 19 she'll tell the judge. 20 THE WITNESS: On the instruction of my 20 If you're going to move to, if you're 21 lawyer, I must invoke my Fifth Amendment right. 21 going to move to another person, could we maybe 22 BY MR. HOROWITZ: 22 take a five-minute break? 23 Q. Did you, in fact, put Jane Doe No. 6's 23 MR. HOROWITZ. Sure. 24 name and telephone number into a master journal or 24 MR. -- before the next person, 25 log in which you and Jeffrey Epstein archived the 25 if you're done -- Page 252 Page 254 1 names and contact information of teenage girls who 1 MR. HOROWITZ: We've got lots more girls. 2 would had sexual activi with Jeffrey Epstein? 2 MR. : Okay. That's fine. But 3 MR. Objection to the form. 3 now a good breaking point? 4 Standing objection. It's compound. Instruct 4 MR. HOROWITZ: Sure. 5 the witness not to answer. 5 MR. : Thanks. 6 THE WITNESS: At the instruction of my 6 THE VIDEOGRAPHER: We're now off video 7 lawyer, I must invoke my Fifth Amendment right. 7 record. The time is 3:14 p.m. 8 BY MR. HOROWITZ: 8 (A brief recess was held.) 9 tir. Did Jeffrey Epstein instruct you to call 9 THE VIDEOGRAPHER: We're now on the videc 10 M . on the telephone to arrange for Jane Doe No. 6 10 record. The time is 3:24 p.m. 11 to come back and give him another massage for his 11 MR. HOROWITZ: I've been told I can start 12 sexual pleasure? 12 my questions without Jack Goldberger in the 13 MR. Objection to the form, 13 room. 14 Instruct the witness not to answer. 14 MR. : Absolutely. 15 THE WITNESS: At the instruction of my 15 BY MR. HOROWITZ: 16 lawyer, I must invoke my Fifth Amendment right. 16 Q. Ms. =, did you know a. did you know a 17 BY MR. HOROWITZ: 17 girl named Jane Doe No. 7 when she was still, still 18 Q. Ms. you have asserted a Fifth 18 a child under the age of 18? 19 Amendment objection and privilege as to all my 19 A. At the instruction of my lawyer I must invoke 20 questions about Jane Doe No. 6 and Jeffrey Epstein. 20 my Fifth Amendment privilege. 21 Is there any reason in your mind why a jury should 21 Q. Ms. =, did a girl named Jane Doe 22 not infer from your assertion of the privilege that, 22 No. 7 come to Jeffrey Epstein's Palm Beach home on 23 in fact, you and Jeffrey Epstein engaged in criminal 23 multiple occasions between 2003 and May of 2005? 24 conduct in inducing her to come to his home for his 24 MR. : Objection to the form. 25 sexual pleasure'? 25 Instruct. instruct the witness not to answer. 17 (Pages 251 to 25 4) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 17 of 48 EFTA_00065381 EFTA01246527 Page 255 Page 257 1 THE WITNESS: On the instruction of my 1 BY MR. HOROWITZ: 2 lawyer, I must invoke my Fifth Amendment 2 Q. Sure. At any time prior to May of 2005, 3 privilege. 3 did Jeffrey Epstein confirm with you that you had 4 BY MR. HOROWITZ: 4 spoken to Jane Doe No. 7 by telephone and that Faith 5 Q. Prior to May of 2005, did ou receive a 5 would be coming to his home at a particular time to 6 phone call from a girl named wherein 6 give him a massage? 7 she told you she was bringing Jane Doe No. 7 to 7 MR. : Object to form. 8 Jeffrey Epstein's home togive him a massage? 8 THE WITNESS: On the instruction of my 9 MR_ : Objection to the form. 9 lawyer, I must invoke my Fifth Amendment 10 THE WITNESS: At the instruction of my 10 privilege. 11 lawyer, I must invoke my Fifth Amendment 11 BY MR. HOROWITZ: 12 privilege. 12 Q. And did you, in fact, speak to Jane Doe 13 MR. : We're trying to speed 13 No. 7 by telephone and confirm that Jane Doe No. 7 14 things along here. 14 would be coming to Jeffrey Epstein's home at a 15 MR HOROWITZ: Fine. 15 particular time to ive him a massage? 16 BY MR. HOROWITZ: 16 MR. : Object to the form. 17 Q. At any time prior to 2005, did 17 THE WITNESS: On the instruction of my 18 Jeffrey E stein instruct you to communicate with 18 lawyer, I must invoke my Fifth Amendment 19 by telephone to arrange for Jane Doe 19 privilege. 20 No. 7 to give him a massage? 20 BY MR. HOROWITZ: 21 MR. : Objection to the form. 21 Q. Did Jeffrey Epstein tell you it was his 22 THE WITNESS: At the instruction of my 22 intention during the course of Jane Doe No. 7's 23 lawyer, I must invoke my Fifth Amendment 23 visits to his home to persuade or entice her to 24 25 privilege. 24 25 engage in sexual activit ? MR. : Object to form. Page 256 Page 258 1 BY MR. HOROWITZ: 1 THE WITNESS: At the instruction of my 2 Q. Did Jeffrey Epstein inform you that the 2 lawyer I must invoke my Fifth Amendment 3 massage Jane Doe No. 7 was to give him would be 3 privilege. 4 sexual in nature? 4 BY MR. HOROWITZ: 5 MR. : Objection to the form. 5 Q. Did Jeffrey Epstein ever tell you that 6 THE WITNESS: At the instruction of my 6 during the course of Jane Doe No. 7's visits to his 7 lawyer, I must invoke my Fifth Amendment 7 home that he succeeded in persuading her or enticing 8 9 privilege. BY MR. HOROWITZ: 8 9 her to engage in sexual activity? MR. Object to form. 10 Q. Did Jeffrey Epstein observe you speaking 10 THE WITNESS: At the instruction of my 11 with by telephone to arrange for Jane 11 lawyer I must invoke my Fifth Amendment 12 Doe No. 7 to come to his home to give him a massage 12 privilege. 13 that was sexual in nature? 13 BY MR. HOROWITZ: 14 MR. : Objection to the form. 14 Q. Ms. . did you ask Jane Doe No. 7 how 15 THE WITNESS: At the instruction of my 15 old she was when she came to Jeffrey Epstein's home: 16 lawyer, I must invoke my Fifth Amendment 16 MR. Objection to form. 17 privilege. 17 THE WITNESS: At the instruction of my 18 BY MR. HOROWITZ: 18 lawyer, I must invoke my Fifth Amendment 19 Q. At any time prior to May of 2005, did 19 privilege. 20 Jeffrey Epstein confirm with you that she (sic) had 20 BY MR. HOROWITZ: 21 spoken to Jane Doe No. 7 by telephone and that Jane 21 Q. And Jane Doe No. 7 never told you that she 22 Doe No. 7 would be coming to his home to give him a 22 was IS or older: is that correct? 23 massage? 23 MR. Objection to form. 24 MR. : I'm sony. Can you 24 THE WITNESS: On the instruction of my 25 restate your question. Mr. Horowitz? 25 lawyer. I must invoke my Filth Amendment 18 (Pages 255 to 258) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 18 of 48 EFTA_00065382 EFTA01246528 Page 259 Page 261 1 privilege. 1 MR. Object to form. 2 BY MR. HOROWITZ: 2 THE WITNESS: At the instruction of my 3 Q. And when Jane Doe No. 7 came to Jeffrey 3 lawyer I must invoke my Fifth Amendment 4 Epstein's home, she appeared to you to look younger 4 privilege. 5 than I8, correct? 5 BY MR. HOROWITZ: 6 MR. : Object to form. 6 Q. Did Jeffrey Epstein instruct you to call 7 THE WITNESS: At the instruction of my 7 Jane Doe No. 7 to tell her to lie to police officers 8 lawyer I must invoke my Fifth Amendment 8 investigatin his criminal activity? 9 privilege. 9 MR. : Object to form. 10 BY MR. HOROWITZ: 10 THE WITNESS: On the instruction of my 11 Q. Did Jane Doe No. 7 tell ou that she was a 11 lawyer, I must invoke my Fifth Amendment 12 student at 12 privilege. 13 MR. : Object to form. 13 BY MR. HOROWITZ: 14 THE WITNESS: At the instruction of my 14 Q. Did you, in fact, call Jane Doe No. 7 to 15 lawyer, I must invoke my Fifth Amendment 15 tell her to lie to police officers investigating 16 privilege. 16 Jeffrey Epstein's criminal activity? 17 BY MR. HOROWITZ: 17 MR. : Object to form. 18 Q. Did Jeffrey Epstein instruct you to take 18 THE WITNESS: At the instruction of my 19 Jane Doe No. 7's name and telephone number down so 19 lawyer, I must invoke my Fifth Amendment 20 you can call Jane Doe No. 7 to come to his home for 20 privilege. 21 more sexual activi ? 21 BY MR. HOROWITZ: 22 MR. : Object to form. 22 Q. Okay. You've asserted a Fifth Amendment 23 THE WITNESS: On the instruction of my 23 objection or privilege as to all of my questions 24 lawyer, I must invoke my Fifth Amendment 24 concerning Jane Doe No. 7 and her visits to Jeffrey 25 privilege. 25 Epstein. Is there any reason that you can think of Page 260 Page 262 1 BY MR. HOROWITZ: 1 that a jury should not infer that you are asserting 2 Q. Did you, in fact, take Jane Doe No. 7's 2 the Fifth Amendment privilege to conceal the 3 name and telephone number down so you could call 3 criminal activi of ourself and Jeffrey Epstein? 4 Jane Doe No. 7 to come to Jeffrey Epstein's home for 4 MR. As previously done. I will 5 6 other sexual activi ? MR. Object to form. 5 6 instruct the witness not to answer that question. I believe it calls for a legal 7 THE WITNESS: On the instruction of my 7 conclusion. It's also not designed to lead to 8 lawyer, I must invoke my Fifth Amendment 8 discoverable evidence, and whether or not any 9 privilege. 9 inference should be drawn will be an issue for 10 BY MR. HOROWITZ: 10 the jury after the judge rules on the 11 Q. Did Jeffrey Epstein instruct you to put 11 objections to the questions. 12 Jane Doe No. 7's name and telephone number into a 12 MR. HOROWITZ: So, did you say you were -- 13 master journal or log in which you and he archived 13 MR. I'm instructing her not to 14 the names of, and telephone numbers of teenage girls 14 answer. 15 with whom he wanted to engage in sexual activity? 15 MR. HOROWITZ: Thank you. 16 MR. Object to form. 16 BY MR. HOROWITZ: 17 THE WITNESS: At the instruction of my 17 Q. Ms. did you know a girl named Jane 18 lawyer, I must invoke my Fifth Amendment 18 Doe No. S when she was still a child under the age 19 privilege. 19 of 18? 20 BY MR. HOROWITZ: 20 A. Upon the instruction of my lawyer, I must 21 Q. Did you, in fact, put Jane Doe No. 7's 21 invoke my Fifth Amendment right. 22 name and telephone number into a master journal or 22 Q. Ms. IM, isn't it true that a girl 23 log in which you archived the names of teenage girls 23 named Jane Doe No. 8 came to Jeffrey Epstein's Palm 24 with whom Jeffrey Epstein did engage in sexual 24 Beach home in approximately 2001 or 2002 when she 25 activity? 25 was still a child under the age of IR? 19 (Pages 259 to 262) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 19 of 48 EFTA_00065383 EFTA01246529 1 Page 263 MR. Object to form. 1 Page 265 BY MR. HOROWITZ: 2 THE WITNESS: On the instruction of my 2 Q. Did you tell Jeffrey Epstein that you had 3 lawyer, I must invoke my Fifth Amendment right. 3 confirmed by telephone that Jane Doe No. 8 would, in 4 BY MR. HOROWITZ: 4 fact, be coming to his home at a particular time to 5 Q. Ms. did ou receive a phone call 5 give him a massa e? 6 from a girl named that she was 6 MR. Object to form. 7 bringing Jane Doe No. 8 to Jeffrey Epstein's home 7 THE WITNESS: On the instruction of my 8 for the purpose of ivin him a massage? 8 lawyer, I must invoke my Fifth Amendment right. 9 MR. Object to form. 9 BY MR. HOROWITZ: 10 THE WITNESS: On the instruction of my 10 Q. Did Jeffrey Epstein tell you that it was 11 lawyer, I must invoke my Fifth Amendment right. 11 his intention that, during the course of Jane Doe 12 BY MR. HOROWITZ: 12 No. 8's visit to his home, that he would persuade or 13 Q. Did Jeffrey Epstein instruct ou to 13 induce her to en a e in sexual activity with him? 14 communicate by telephone with to 14 MR. Object to form. 15 arrange for Carolyn to bring underage girls to his 15 THE WITNESS: Upon the instruction of my 16 home for sexual activi ? 16 lawyer, I must invoke my Fifth Amendment right. 17 MR. Object to form. 17 BY MR. HOROWITZ: 18 THE WITNESS: On the instruction of my 18 Q. Did Jeffrey Epstein tell you that, in 19 lawyer, I must invoke my Fifth Amendment right. 19 fact, during the course of Jane Doe No. S's visit to 20 BY MR. HOROWITZ: 20 his home, he succeeded in persuading or inducing her 21 Q. Did Jeffrey Epstein pay 21 to engage in sexual activity? 22 to bring underage girls to his home for sexual 22 MR. Object to the form. 23 activity? 23 THE WITNESS: Upon instruction of my 24 MR. Object to form. 24 lawyer, I must invoke my Fifth Amendment 25 THE WITNESS: On the instruction of my 25 privilege. Page 264 Page 266 1 lawyer. I must invoke my Fifth Amendment right. 1 BY MR. HOROWITZ: 2 2 Q. Jane Doe No. 8 never told you that she was BY MR. HOROWITZ: 3 Q. Did Jeffrey E stein instruct ou to 3 18 years old or older: is that correct? 4 communicate with by telephone to 4 MR. : Object to form. 5 arrange for Jane Doe No. 8 to give him a massage 5 THE WITNESS: Upon the instruction of my 6 that was to be sexual in nature? 6 lawyer, I must invoke my Fifth Amendment right. 7 MR. Object to form. 7 BY MR. HOROWITZ: 8 THE WITNESS: On the instruction of my 8 Q. And when you saw Jane Doe No. 8, she 9 lawyer. I must invoke my Fifth Amendment right. 9 appeared to ou to be less than 18; is that correct? 10 10 MR. : Object to the form. BY MR. HOROWITZ: 11 Q. Did Jeffrey Epstein inform you that the 11 THE WITNESS: On the instruction of my 12 massage that Jane Doe No. 8 was to give him would be 12 lawyer, I must invoke my Fifth Amendment right. 13 sexual in nature? 13 BY MR. HOROWITZ: 14 MR. Object to form. 14 . Did Jeffrey Epstein instruct you to call 15 THE WITNESS: On the instruction of my 15 on the telephone to arrange for 16 lawyer. I must invoke my Fifth Amendment right. 16 Jane Doe No. 8 to come back and give him another 17 BY MR. HOROWITZ: 17 massage that was to be sexual in nature? 18 Q. Did Jeffrey E stein observe you speaking 18 MR. : Objection to the form. 19 with by telephone making 19 THE WITNESS: On the instruction of my 20 arrangements for Jane Doe No. 8 to come to his home 20 lawyer, I must invoke my Fifth Amendment right. 21 to give him a massy e? 21 BY MR. HOROWITZ: 22 MR. Object to form. 22 Q. Ms. =, you have asserted a Fifth 23 THE WITNESS: On the instruction of my 23 Amendment objection or privilege as to all of my 24 lawyer. I must invoke my Fifth Amendment right. 24 questions about Jane Doe No. 8. Is there any reason 25 25 in your mind why jury should not infer that. in 20 (Pages 263 to 266) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 20 of 48 EFTA_00065384 EFTA01246530 Page 267 Page 269 1 fact, you and Jeffrey Epstein engaged in criminal 1 MR. Same instruction. 2 activity as it relates to Jane Doe No. 8? 2 THE WITNESS: Upon the instruction of my 3 MR. : Instruct the witness not 3 lawyer. I must invoke my Fifth Amendment right. 4 to answer the question. 4 BY MR. . 5 MR. HOROWITZ: Do you have the premarked 5 Q. And did you place at least some of the 6 7 Exhibit 5, b an chance? MR. : I gave it back to 6 7 calls reflected on that phone bill with an eye toward arranging for minor children under the age of 8 Mr. Kuvin. 8 18 to come to Jeffrey Epstein's home for his sexual 9 MR. HOROWITZ: I'll hand it back to you. 9 pleasure? 10 Sorry. 10 MR. Object to the form as 11 BY MR. HOROWITZ: 11 compound and a standing objection, and also 12 Q. Let me ask Ms. to take a look at 12 instruct the witness not to answer based on 13 what's been 'remarked as Exhibit 5. 13 Fifth Amendment. 14 MR. : Do you want us to look at 14 THE WITNESS: Upon the instruction of my 15 the whole thing? 15 lawyer, I must invoke my Fifth Amendment right. 16 MR. HOROWITZ: Well, if we're going to 16 BY MR. HOROWITZ: 17 take more than a -- yeah, we can go off record 17 Q. And with respect to the phone calls 18 19 if she'sgoing to look at the whole thing. MR. : If you want to ask her 19 18 reflected on the bill which you received, did you answer some of those phone calls with an eye toward 20 about every page, we'll look at every page. 20 arranging for procuring underage girls to come to 21 But if you want to just ask some general 21 Jeffrey Epstein's home for his sexual pleasure? 22 questions. perhaps then we can just -- 22 MR. : Object to the, object to 23 MR. HOROWITZ: Well, if you know that 23 the form. Instruct the witness not to answer, 24 you're goin to assert the Fifth Amendment -- 24 based on Fifth Amendment privilege. 25 MR. : I doubt we're answering 25 THE WITNESS: Upon the instruction of my Page 268 Page 270 1 any questions about it, but go on ahead. And 1 lawyer. I must invoke my Fifth Amendment right. 2 if we need to take a break, we'll take a break. 2 BY MR. HOROWITZ: 3 BY MR. HOROWITZ: 3 Q. Do, does the phone, does the premarked 4 Q. Okay. Have you had enough of a look at 4 Exhibit 5 reflect phone calls wherein you arranged 5 those records to determine whether those are the 5 for Jeffrey Epstein to meet children under the age 6 telephone records for the cellphone that you used 6 of 18 for his sexual • leasure? 7 during the time periods set forth on those phone 7 MR. : Objection to the form. 8 bills? 8 It's a compound question, instruct the witness 9 MR. Instruct the witness not 9 not to answer based on the Fifth Amendment. 10 to answer the question based on the Fifth 10 THE WITNESS: Upon the instruction of my 11 Amendment. 11 lawyer, I must invoke my Fifth Amendment right. 12 THE WITNESS: Upon the instruction of my 12 BY MR. HOROWITZ: 13 lawyer, I must invoke my Fifth Amendment right. 13 Q. Would it be accurate to describe Jeffrey 14 BY MR. HOROWITZ: 14 Epstein's home between the years 2001 and 2006 as a 15 Q. Are the phone calls that the telephone 15 house of horrors? 16 bills reflect as having been made phone calls that 16 MR. : Object to the form of the 17 were b our 17 Instruct the witness not to answer. 18 placed MR. Same instruction. 18 question. BY MR. HOROWITZ: 19 THE WITNESS: On the instruction of my 19 Q. Would you say that childhood sexual abuse 20 lawyer, I must invoke my Fifth Amendment right. 20 was committed at Jeffrey Epstein's home every day 21 BY MR. HOROWITZ: 21 that he was in Palm Beach County between the years 22 Q. Okay. Are the phone calls that the phone 22 2001 and 2006? 23 bill reflects as having been received on that 23 MR. : Object to the form. It 24 telephone line phone calls that you, in fact. 24 assumes she knows anything about Jeffrey 25 received? 25 Epstein or his home or when he i. in Palm Beach 21 (Pages 267 to 270) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 21 of 48 EFTA_00065385 EFTA01246531 Page 271 Page 273 1 County, so instruct her not to answer the 1 compound and assumes facts not within the 2 question. 2 knowledge of this witness. Instruct the 3 THE WITNESS: Upon the instruction of my 3 witness not to answer based on the Fifth 4 lawyer. I choose to assert my Fifth Amendment 4 Amendment. 5 right. 5 THE WITNESS: Upon the instruction of my 6 MR. HOROWITZ: No other questions. 6 lawyer, I must invoke my Fifth Amendment right. 7 MR. Thank you. Who is next 7 BY MR. WEISSING: 8 up? 8 Q. Beginning in August of 2002, are you aware 9 MR. KUVIN: Next? Do you want to go next? 9 that M. was coerced by Jeffrey Epstein into sexual 10 MS. EZELL: Do you have a trial date? You 10 conduct? 11 may want to go because you have a trial date. 11 MR. : Objection to form. 12 MR. WEISSING: I do. 12 leading. Well. it's compound. Instruct the 13 MR. KUVIN: Yeah, you do. Whenever you're 13 witness not to answer based on the Fifth 14 ready. Go ahead. After you. 14 Amendment. The question is also ambiguous as 15 MR. • Whenever you're ready. Is 15 to coercion. 16 our videographer ready. 16 THE WITNESS: Upon the instruction of my 17 THE VIDEOGRAPHER: Oh, yeah. Were all 17 lawyer, I must assert my Fifth Amendment right. 18 good. 18 MR. WEISSING: Are you aware that between 19 MR. We're all good? 19 August 2002 and September of 2005, had 20 THE VIDEOGRAPHER: We never went off the 20 sexual conduct with Jeffrey Epstein? 21 record. 21 MR. : Object to the form, 22 CROSS t 22 standing objection. Instruct the witness not 23 BY MR. WEISSING: 23 to answer. 24 Q. Ms.= Mau Weissing here. Do you 24 THE WITNESS: On the instruction of my 25 know..? 25 lawyer, I must invoke my Fifth Amendment right. Page 272 Page 274 1 MR. Instruct the witness not 1 BY MR. WEISSING: 2 to answer the question based on Fifth 2 Q. Okay. Are you aware that between August 3 Amendment. 3 2002 and September of 2005, Jeffrey Epstein engaged 4 THE WITNESS: On the instruction of my 4 in fondling and inappropriate illegal sexual 5 lawyer, I must invoke my Fifth Amendment right. 5 touching of ? 6 BY MR. WEISSING: 6 MR. Objection to the form. 7 Q. Have ou ever met..? 7 standing objection and ambiguous as to 8 MR. Object to the form. I 8 terminology. Instruct the witness not to 9 believe that's been asked and answered several 9 answer. 10 times. Well, not answered several times. But 10 THE WITNESS: Upon the instruction of my 11 I'll instruct her once again not to answer the 11 lawyer, I must invoke my Fifth Amendment right. 12 question. 12 BY MR. WEISSING: 13 BY MR. WEISSING: 13 Q. Are you aware that during that same 14 Q. Are you aware that.. was 14 years of 14 period, that Jeffrey Epstein ensascl in oral sex or 15 age when she first came to Jeffrey Epstein's mansion 10 other sexual misconduct with M.? 16 in 2002? 16 MR. Same objection as the 17 MR. Object to the form. 17 previous question and same instruction to the 18 Instruct the witness not to answer. 18 witness. 19 THE WITNESS: On the instruction of my 19 THE WITNESS: On the instruction of my 20 lawyer, I must invoke my Fifth Amendment right. 20 lawyer, I must invoke my Fifth Amendment right. 21 BY MR. WEISSING: 21 BY MR. WEISSING: 22 Q. Are you aware that at all times that -- 22 Q. Are you aware that in that same time 23 from 2002 to 2005, when came to his mansion. 23 period that Jeffrey Epstein masturbated in the 24 she was a minor child? 24 presence of. 25 MR. Object to the form. It's 25 MR. Objection to the form. 22 (Pages 271 to 27 4) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 22 of 48 EFTA_00065386 EFTA01246532 Page 275 Page 277 1 standing objection and instruct the witness not 1 answer as well as compound. 2 to answer. 2 THE WITNESS: At the instruction of my 3 THE WITNESS: Upon 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. WEISSING: 5 BY MR. WEISSING: 5 Q. At all times that.. was engaged with 6 Q. Are you aware that for all of her 6 the behaviors with Jeffrey Epstein, did he know that 7 behaviors with Jeffrey Epstein that.. was paid by 7 she was a minor child? 8 him? 8 MR. : Objection to the form, 9 MR. : Objection to the font 9 calls for speculations as to Mr. Epstein's 10 leading, as well as the standing objection, and 10 mindset, also assumes she knows Mr. Epstein. so 11 instruct the witness not to answer. 11 I would object as compound and instruct her not 12 THE WITNESS: Upon the instruction of my 12 to answer. 13 lawyer, I must invoke my Fifth Amendment right. 13 THE WITNESS: At the instruction of my 14 BY MR. WEISSING: 14 lawyer, I must invoke my Fifth Amendment right. 15 Q. Did you pay.. for any of her work for 15 BY MR. WEISSING: 16 Jeffrey Epstein? 16 Q. At all times during her interaction with 17 MR. : Objection to the form. 17 Jeffrey Epstein did Jeffrey Epstein tell you that 18 Instruct the witness not to answer. 18 he knew that was a minor child? 19 THE WITNESS: On the instruction of my 19 MR. Objection to form. 20 lawyer. I must invoke my Fifth Amendment right. 20 THE WITNESS: At the instruction of my 21 BY MR. WEISSING: 21 lawyer, I must invoke my Fifth Amendment right. 22 Q. Are you aware that Jeffrey Epstein. during 22 BY MR. WEISSING: 23 the period of August 2nd -- 2002 and September of 23 Q. Did Jeffrey Epstein tell you that he 24 2005 committed numerous criminal and sexual offenses 24 engaged in numerous sexual activities with M. 25 against a minor child? 25 between the periods of August 2nd and September -- Page 276 Page 278 1 MR. Objection to the form. 1 August 2002 and Se ember 2005? 2 Calls for a legal conclusion. It's compound 2 MR. : Objection to the form. 3 and ambiguous and instruct the witness not to 3 THE WITNESS: At the instruction of my 4 answer. 4 lawyer, I must invoke my Fifth Amendment right. 5 THE WITNESS: Upon the instruction of my 5 BY MR. WEISSING: 6 lawyer, I must invoke my Fifth Amendment right. 6 Q. Did Jeffrey E • stein tell ou that he had 7 BY MR. WEISSING: 7 sexual) ex loited 8 Q. Are you aware that due to the influence of I 9 Jeffre E stein's interaction with 9 MR. : Objection to form. It's ■ 10 ambiguous. calls for legal conclusions, and 11 MR. Objection to the form, 11 it's compound. Instruct the witness not to 12 leading. Requires speculation. is ambiguous 12 answer based on Fifth Amendment privilege. 13 and compound, and instruct the witness not to 13 THE WITNESS: On the instruction of my 14 answer. 14 lawyer, I must assert my Fifth Amendment right. 15 THE WITNESS: On the instruction of my 15 BY MR. WEISSING: 16 lawyer, I must invoke my Fifth Amendment right. 16 Q. Did Jeffrey Epstein ever tell you that he 17 BY MR. WEISSING: 17 was harmin intentional) ..? 18 Q. At all times when ■. was engaged with 18 MR. : Objection to the form. It 19 Jeffrey Epstein. he knew that she was a minor child. 19 assumes knowledge of Jeffrey Epstein. Instruct 20 MR. Is that a question or a 20 her not to answer. 21 statement? 21 THE WITNESS: On the instruction of my 22 BY MR. WEISSING: 22 lawyer, I must exert my Fifth Amendment right. 23 Q. Correct? 23 BY MR. WEISSING: 24 MR. Objection to the form, 24 Q. Did you know that Jeffrey Epstein's 25 leading. I'll instruct the witness not to 25 behavior was causing injury. pain and suffering. and 23 (Pages 275 to 278) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 23 of 48 EFTA_00065387 EFTA01246533 Page 279 Page 281 1 emotional trauma to 9 1 ambiguous as to "school children." Instruct 2 MR. Objection to the form, 2 the witness not to answer. 3 calls for speculation and is otherwise a 3 THE WITNESS: At the instruction of my 4 standing objection. 4 lawyer, I must invoke my Fifth Amendment right. 5 THE WITNESS: At the instruction of my 5 BY MR. WEISSING: 6 lawyer, I must invoke my Fifth Amendment right. 6 Q. With regard to the young girls who you 7 BY MR. WEISSING: 7 contacted to set up sexual encounters with 8 Q. Were you aware that Jeffrey Epstein was 8 Jeffrey Epstein, were they between the ages, school 9 using his wealth and the proximity of his mansion to 9 girls between the axes of 13 and 17 years of age? 10 lead young underage girls into having sexual 10 MR. : Objection to the form. 11 behaviors with him? 11 Its compound and instruct the witness not to 12 MR. Objection to form, 12 answer. 13 standing objection and ambiguous. 13 THE WITNESS: Upon the instruction of my 14 THE WITNESS: At the instruction of my 14 lawyer, I must invoke my Fifth Amendment right. 15 lawyer I must invoke my Fifth Amendment right. 15 BY MR. WEISSING: 16 BY MR. WEISSING: 16 Q. Now, do you believe that Jeffrey Epstein 17 Q. Were you scheduling girls to 17 presents a clear danger to female children in this 18 meet with Jeffry E stein? 18 community? 19 MR. Objection to form, 19 MR. Objection to form, 20 standing objection. 20 standing objection. 21 THE WITNESS: At the instruction of my 21 THE WITNESS: On the instruction of my 22 lawyer, I must invoke my Fifth Amendment right. 22 lawyer, I must invoke my Fifth Amendment right. 23 BY MR. WEISSING: 23 BY MR. WEISSING: 24 Q. In scheduling girls to meet with 24 Q. Did Jeffrey Epstein tell you that he was 25 Jeffrey Epstein, did you ever call any escort 25 intentionally engaging in sexual misconduct with Page 280 Page 282 1 services? 1 .. in an effort to hun her? 2 MR. Objection to form. 2 MR. : Objection to the form, 3 standing objection. 3 standing objection and also ambiguous. 4 THE WITNESS: At the instruction of my 4 THE WITNESS: On the instruction of my 5 lawyer I must invoke my Fifth Amendment right 5 lawyer, I must invoke my Fifth Amendment right. 6 BY MR. WEISSING: 6 BY MR. WEISSING: 7 Q. In scheduling sexual encounters for 7 Q. Did Jeffrey Epstein tell that he knew 8 Jeffrey Epstein, did you ever contact any, any known 8 that his sexual behavior with MI. was, in fact, 9 prostitutes? 9 injuring her? 10 MR. Objection to form. 10 MR. : Objection to form. 11 THE WITNESS: At the instruction of my 11 THE WITNESS: At the instruction I must 12 lawyer, I must invoke my Fifth Amendment right. 12 invoke my Fifth Amendment right. 13 BY MR. WEISSING: 13 BY MR. WEISSING: 14 Q. With regard to the girls who were 14 Q. Were you aware that Jeffrey Epstein 15 scheduled, these were basically school children, 15 touched.. with -- in her, in the intimate areas 16 correct? 16 of her body? 17 MR. Objection to form, 17 MR. Objection to the form, 18 leading, and also a standing objection. 18 both compound, standing objection and 19 THE WITNESS: At the instruction of my 19 ambiguous. 20 lawyer, I must invoke my Fifth Amendment right. 20 THE WITNESS: On the instruction of my 21 BY MR. WEISSING: 21 lawyer, I must invoke my Fifth Amendment right. 22 Q. Were the girls who you contacted on behalf 22 BY MR. WEISSING: 23 of Jeffrey Epstein, school children in this 23 Q. Are ou aware that Jeffrey Epstein 24 community? 24 penetrated % va ina? 25 MR. Objection to form and 25 MR. : Obection to the form. 24 (Pages 279 to 282) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 24 of 48 EFTA_00065388 EFTA01246534 Page 283 Page 285 1 standing objection. 1 MR. Objection to the form in 2 THE WITNESS: At the instruction of my 2 that assumes knowledge of Jeffrey Epstein or 3 lawyer, I must invoke my Fifth Amendment right. 3 where his mansion is or what goes on in his 4 BY MR. WEISSING: 4 mansion, so instruct her not to answer it. 5 Are you aware that Jeffrey Epstein touched 5 THE WITNESS: On the instruction of my 6 in the intimate portions of her body on dozens 6 lawyer, I must invoke my Fifth Amendment right. 7 of occasions between August 2002 and September of 7 BY MR. WEISSING: 8 2005? 8 Q. Between August 2002 and S tember of 2005, 9 MR. Objection to the form, 9 did Jeffrey Epstein coerce or engage. in sexual 10 standing objection. 10 activity at his mansion? 11 THE WITNESS: At the instruction of my 11 MR. Objection to form and 12 lawyer, I must invoke my Fifth Amendment right. 12 ambiguous as to "coercion." 13 BY MR. WEISSING: 13 THE WITNESS: On the instruction of my 14 Q. Did Jeffrey Epstein tell you that he had 14 lawyer, I must invoke my Fifth Amendment right. 15 touched in the intimate portions of her body 15 BY MR. WEISSING: 16 and penetrated her body with a design to injure her 16 Q. Between August 2002 and September 2005, 17 between Au ust 2002 and September of 2005? 17 did Jeffrey Epstein engage in sexual misconduct with 18 MR. Objection to the form as 18 19 compound and instruct the witness not to 19 MR. Objection to the form and 20 answer. 20 ambiguous as to "sexual misconduct." 21 THE WITNESS: On the instruction of my 21 THE WITNESS: At the instruction of my 22 lawyer, I must invoke my Fifth Amendment right. 22 lawyer. I must invoke my Fifth Amendment right. 23 BY MR. WEISSING: 23 BY MR. WEISSING: 24 Q. Do ou know who M. is? 24 Q. Between August 2002 and September of 2005 25 MR. Instruct the witness not 25 did Jeffrey Epstein engage in conduct with M. for Page 284 Page 286 1 2 to answer based on the Fifth Amendment. THE WITNESS: On the instruction of my 1 2 his sexual atification? MR. : Objection to form. 3 lawyer, I must invoke my Fifth Amendment right. 3 THE WITNESS: At the instruction of my 4 BY MR. WEISSING: 4 lawyer I must invoke my Fifth Amendment right. 5 Q. Were you aware when M. first came to 5 BY MR. WEISSING: 6 Jeffrey Epstein's mansion in 2002 that she was a. 6 Q. Were you aware that between August 2002 7 she was a 14- ear-old child? 7 and September of 2005. Jeffrey E n engaged in 8 MR. • Objection to the form. 8 sexual, engaged in behavior with M. for his sexual 9 standing objection. 9 gratification? 10 THE WITNESS: At the instruction of my 10 MR. : Objection to the form. the 11 lawyer, I must invoke my Fifth Amendment right. 11 standing objection previously stated and 12 BY MR. WEISSING: 12 ambiguous. 13 Q. How many minor female children have been 13 THE WITNESS: At the instruction of my 14 brought to Jeffrey Epstein's mansion for the 14 lawyer, I must invoke my Fifth Amendment right. 15 purposes of his sexual ratification? 15 BY MR. WEISSING: 16 MR. Objection to the form, 16 Q. Between August -- during that same period 17 ambiguous as to time period and standing 17 of time, did Jeffrey Epstein engage in oral sex or 18 objection. 18 other misconduct with 9 19 THE WITNESS: On the instruction of my 19 MR. : Standing objection to 20 lawyer, I must invoke my Fifth Amendment right. 20 form. 21 BY MR. WEISSING: 21 THE WITNESS: At the instruction of my 22 Q. Between the years of 2001 and 2005, were 22 lawyer, I must invoke my Fifth Amendment right. 23 more less or less than 1.000 underage female 23 BY MR. WEISSING: 24 children brought to Jeffrey Epstein's mansion for 24 Q. During that same period of time. did 25 his sexual eratification? 25 Jeffrey Epstein engage in masturbation and fondling 25 (Pages 283 to 286) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 25 of 48 EFTA_00065389 EFTA01246535 Page 287 Page 289 1 of the minor child's sexual organs? 1 THE WITNESS: At the instruction of my 2 MR. : Can you, can you clarify 2 lawyer, I must invoke my Fifth Amendment right. 3 what you said, "the minor child"? 3 BY MR. WEISSING: 4 MR. WEISSING: Yes. Were talking about 4 Q. During that same period did Jeffrey 5 I. 5 Epstein tell you that he knew that ■. was a minor 6 MR. : I just want to make sure 6 child? 7 you're limiting the question to M. 7 MR. Objection to the form, the 8 MR. WEISSING: All right. 8 standing objection. 9 MR. : On that basis, we're 9 THE WITNESS: At the instruction of my 10 objecting to the form, and standing objection. 10 lawyer, I must invoke my Fifth Amendment right. 11 It assumes multiple facts this witness does not 11 BY MR. WEISSING: 12 acknowledge she does have information about, 12 Q. Did Jeffrey Enin tell you that he knew 13 and therefore the question is compound and 13 that he was injuring M. through numerous sexual 14 ambiguous. and I instruct her not to answer. 14 encounters with her between August 2002 and 15 THE WITNESS: On the instruction of my 15 September of 2005? 16 lawyer I must invoke my Fifth Amendment right. 16 MR. Objection to the form. and 17 BY MR. WEISSING: 17 standing objection. Also compound question and 18 Q. You knew that during that period of time, 18 ambiguous, and instruct the witness not to 19 that Jeffrey Epstein was engaged in fondling and 19 answer the question. 20 penetrating the sexual organs of M.? 20 THE WITNESS: At the instruction of my 21 MR. : Objection to form, 21 lawyer, I must invoke my Fifth Amendment right. 22 leading, and also a standing objection. 22 BY MR. WEISSING: 23 THE WITNESS: At the instruction of my 23 Q. Did know that Jeffrey Epstein was 24 lawyer I must invoke my Fifth Amendment right. 24 injuring M. through sexual contact with her during 25 25 that period of time? Page 288 Page 290 1 BY MR. WEISSING: 1 MR. Objection to the form. It 2 Q. Did you know during that period of time 2 assumes knowledge of Jeffrey Epstein and a 3 that Jeffrey Epstein was engaging in sexual 3 and instruct the witness not to answer. 4 penetration of ? 4 THE WITNESS: At the instruction of my 5 MR. Objection to the form, 5 lawyer, I must invoke my Fifth Amendment right. 6 standing objection previously stated. 6 BY MR. WEISSING: 7 THE WITNESS: At the instruction of my 7 Q. Did you know that the criminal conduct by 8 lawyer, I must invoke my Fifth Amendment right. 8 Jeffrey Epstein against was causing damage to 9 BY MR. WEISSING: 9 M.? 10 01 ::ouring that period of time did you know 10 MR. Objection to the form. It 11 that M. was a minor child? 11 calls for a legal conclusion that the witness 12 MR. Objection to form, 12 is not competent to give. Also calls for 13 standing objection and assumes multiple facts 13 speculation as to harm, if any, to a person she 14 and therefore can't be answered without. 14 hasn't even acknowledged that she knows. so 15 because the question is too ambiguous. 15 it's an improper question. I instruct her not 16 Instruct the witness not to answer. 16 to answer based on the Fifth Amendment. 17 THE WITNESS: At the instruction of my 17 THE WITNESS: At the instruction of my 18 lawyer I must invoke my Fifth Amendment right. 18 lawyer I must invoke my Fifth Amendment right. 19 BY MR. WEISSING: 19 BY MR. WEISSING: 20 Q. From August 2002 to September 2005, did 20 Q. Are you aware that in the State of Florida 21 Jeffrey Epstein know that ■. was a minor child? 21 it is a crime to engage in sex, sexual activity with 22 MR. Objection to the form, 22 a minor child? 23 calls for speculation and also a standing 23 A. Can you repeat the question, please? 24 objection as assuming knowledge of Jeffrey 24 Q. Yes. Are you aware that in the State of 25 Epstein. Instruct the witness not to answer. 25 Florida it is against. it is a crime to engage in 26 (Pages 287 to 290) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 26 of 48 EFTA_00065390 EFTA01246536 1 2 3 4 5 6 7 8 9 10 Page 291 sexual activit with a minor child? MR. Can -- I'd just ask you to clarify, when you say "sexual activity; are you using a legal term of art, or do you have a specific definition? MR. WEISSING: Sexual activity. MR. Okay. You mean by an adult with a minor child? MR. WEISSING: Yes. MR. Okay. Hold on one second. 1 2 3 4 5 6 7 8 9 10 Page 293 MR. Objection to the form to the extent it assumes knowledge of Jeffrey Epstein or M. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. WEISSING: Q. At all times that Jeffrey Epstein was involved with S. she was a minor child, or was she a minor child? MR. Objection to the form. 11 I'm going to object. It calls for a legal 11 standing objection. It assumes facts that 12 conclusion. I'm going to instruct her not to 12 there has been no admission this witness knows 13 answer the question. 13 anything about. Instruct her not to answer. 14 MR. WEISSING: No — 14 THE WITNESS: At the instruction of my 15 MR. I'm instructing her not to 15 lawyer, I must invoke my Fifth Amendment right. 16 answer the question. It calls for a legal 16 BY MR. WEISSING: 17 conclusion. It's not a factual question that 17 Q. Did Jeffrey Epstein intentionally 18 is designed to lead to discoverable evidence. 18 penetrate M. during his, while she was at his 19 BY MR. WEISSING: 19 mansion? 20 Q. Did you know that M. was suffering 20 MR. Same objection to the 21 injury and emotional and psychological trauma as a 21 form. 22 result of the behavior engaged in with her by 22 THE WITNESS: At the instruction of my 23 Jeffrey Epstein? 23 lawyer, I must invoke my Fifth Amendment right. 24 MR. Objection to the form. 24 BY MR. WEISSING: 25 Assumes knowledge of the existence of a person 25 Q. Did Jeffrey Epstein engage in masturbation Page 292 Page 294 1 by the name of M. which has not been 1 in front of while she was a minor child at his 2 acknowledged. I instruct her not to answer. 2 mansion? 3 THE WITNESS: On the advice of counsel, I 3 MR. : Objection to the form. 4 must invoke my Fifth Amendment right. 4 THE WITNESS: At the instruction of my 5 BY MR. WEISSING: 5 lawyer, I must invoke my Fifth Amendment right. 6 . Were you at the mansion the first time 6 BY MR. WEISSING: 7 that . came to see Jeffrey Epstein? 7 Q. Did you know that Jeffrey Epstein was 8 MR. : Objection to the form. 8 engaging in sex his sexual gratification in the 9 Standing objection as to knowledge of 9 presence of 9 10 Jeffrey Epstein or any mansion. 10 MR. : Objection to the form. 11 THE WITNESS: On the advice of counsel, I 11 THE WITNESS: On the instruction of my 12 must invoke my Fifth Amendment right. 12 lawyer, I must invoke my Fifth Amendment right. 13 BY MR. WEISSING: 13 BY MR. WEISSING: 14 Q. Did Jeffrey tein tell you that he 14 Q. Did you know that Epstein touched 5 in 15 intended to injure M. by engaging her in sexual 15 the intimate portions of her body on numerous, 16 activity? 16 dozens of occasions between August of 2002 and 17 MR. : Object to the form. 17 September of 2005? 18 Assumes knowledge of Jeffrey Epstein and., 18 MR. : Object to the form. 19 Standing objection. 19 THE WITNESS: At the instruction of my 20 THE WITNESS: On the advice of my lawyer, 20 lawyer, I must invoke my Fifth Amendment right. 21 I must invoke my Fifth Amendment right. 21 BY MR. WEISSING: 22 BY MR. WEISSING: 22 Q. Have you met Jane Doe? 23 Q. Did Jeffrey Epstein tell you that he 23 A. At the instruction of my lawyer. I must invoke 24 intended to cause severe emotional distress to 24 my Fifth Amendment ri ht. 25 by engaging her in sexual activity? 25 Q. would you set up the 27 (Pages 291 to 2 9 4) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 27 of 48 EFTA_00065391 EFTA01246537 Page 295 Page 297 1 massage table where minor children were escorted in 1 massage table and order them to take their clothes 2 Jeffrey Epstein's mansion? 2 off? 3 MR. : Objection to the form. 3 MR. Objection to form. 4 Ifs a compound question that assumes things 4 THE WITNESS: At the instruction of my 5 about her job and other things that are not 5 lawyer, I must invoke my Fifth Amendment right. 6 established and instruct her not to answer. 6 BY MR. WEISSING: 7 THE WITNESS: At the instruction of my 7 Q. After they disrobed, are you aware that he 8 lawyer. I must invoke my Fifth Amendment right. 8 would allow them to massage him? 9 BY MR. WEISSING: 9 MR. : Are we talking about a 10 I. Between 2001 and 2005 10 specific person on a specific date, or are you 11 asking a general practice and policy? 12 MR. Instruct the witness not 12 MR. WEISSING: General. 13 to answer based on Fifth Amendment privilege. 13 MR. : Object to the question as 14 THE WITNESS: At the instruction of my 14 ambiguous. open ended, and instruct the witness 15 lawyer. I must invoke my Fifth Amendment right. 15 not to answer. 16 BY MR. WEISSING: 16 THE WITNESS: On the instruction of my 17 Q. were you 17 lawyer, I must invoke my Fifth Amendment right. 18 responsible for setting up a massage table in the 18 BY MR. WEISSING: 19 mansion? 19 Q. Are you aware that Jeffrey Epstein 20 MR. : Objection to the form. 20 routinely would turn on. turn onto his back and ask 21 THE WITNESS: On the instruction of my 21 the to inch his ni les? 22 lawyer. I must invoke my Fifth Amendment right. 22 girls MR. : Objection to the form. 23 BY MR. WEISSING: 23 It's a compound question. 24 Q. for, with 24 THE WITNESS: At the instruction of my 25 Jeffrey Epstein, were you responsible for escorting 25 lawyer, I must invoke my Fifth Amendment right. Page 296 Page 298 1 underage girls to the massage table area in the 1 BY MR. WEISSING: 2 mansion? 2 Q. After exposing his naked body to these 3 MR. Objection to form. 3 girls, are you aware that he would then masturbate 4 THE WITNESS: At the instruction of my 4 in their presence? 5 lawyer, I must invoke my Fifth Amendment right. 5 MR. Object to the form. You 6 BY MR. WEISSING: 6 keep asking questions about what 7 Q. After escorting underage girls to the 7 Jeffrey Epstein did. She's not acknowledged 8 massage area in the mansion, did you leave them 8 she even knowns a Jeffrey Epstein. You can ask 9 alone? 9 her if Jeffrey Epstein went to the moon: she's 10 MR. • Objection to fonn. 10 not going to answer the question. but you can 11 THE WITNESS: At the instruction of my 11 keeping asking. 12 lawyer, I must invoke my Fifth Amendment right. 12 THE WITNESS: On the instruction of my 13 BY MR. WEISSING: 13 lawyer. I must invoke my Fifth Amendment right. 14 Q. After the underage girls were left alone. 14 BY MR. WEISSING: 15 are you aware that Jeffrey Epstein appeared either 15 Q. The amount of, the amount of money given 16 naked or, or wrapped in a towel? 16 to these was dependent upon the extent 17 MR. Objection to form. Calls 17 young girls of behavior engaged in by Jeffrey Epstein: is that 18 for speculation and compound question. Assumes 18 correct? 19 facts that she's not acknowledged any personal 19 MR. Objection to form. leading 20 knowledge of. 20 and otherwise objection to the form for the 21 THE WITNESS: On the instruction of my 21 reasons previously stated. 22 lawyer, I must invoke my Fifth Amendment right. 22 THE WITNESS: On the instruction of my 23 BY MR. WEISSING: 23 lawyer, I must invoke my Fifth Amendment right. 24 Q. Are you aware that after appearing naked 24 BY MR. WEISSING: 25 in front of underage girls. he would lay down on the 25 Q. Were the girls paid more if they used 28 (Pages 295 to 298) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 28 of 48 EFTA_00065392 EFTA01246538 Page 299 Page 301 1 vibrators or sexual to s? 1 lawyer, I must invoke my Fifth Amendment right. 2 MR. Objection to the form. 2 BY MR. WEISSING: 3 THE WITNESS: On the instruction of my 3 Q. Were you aware that during that period of 4 lawyer, I must invoke my Fifth Amendment right. 4 time that Jane Doe was a minor child? 5 BY MR. WEISSING: 5 MR. : Objection to the form. 6 Q. Regarding Jane Doe, when she was first 6 THE WITNESS: At the instruction of my 7 brought to Epstein's mansion in 2003, she was in 7 lawyer, I must invoke my Fifth Amendment right. 8 middle school, or was she in middle school? 8 BY MR. WEISSING: 9 MR. Objection to form. 9 Q. Were you aware that during that period of 10 THE WITNESS: On the instruction of my 10 time that Jeffrey Epstein engaged in fondling and 11 lawyer, I must invoke my Fifth Amendment right. 11 sexual touchin of Jane Doe? 12 BY MR. WEISSING: 12 MR. Form. 13 Q. Are you aware that in 2003 when Jane Doe 13 THE WITNESS: At the instruction of my 14 was brought to Epstein's mansion, she was in middle 14 lawyer, I must invoke my Fifth Amendment right. 15 school? 15 BY MR. WEISSING: 16 MR. Objection to the form. 16 Q. During that period of time, were you aware 17 Once again to answer the question, she would 17 that Jeffrey Epstein engaged in masturbation in the 18 have to implicitly admit that she knows Jeffrey 18 presence of Jane Doe? 19 Epstein or knows anything about Jeffrey Epstein 19 MR. Objection to form. 20 which she is not going to do, so to go onto the 20 THE WITNESS: The instruction of my 21 second half of the question, it's a compound 21 lawyer, I must invoke my Fifth Amendment right. 22 question as to whatever happened with 22 BY MR. WEISSING: 23 Mr. Epstein. But you keep asking her. She's 23 Q. During that period of time, are you aware 24 not going to answer them. So, they're compound 24 that Jeffrey Epstein engaged in sexual penetration 25 and ambiguous. 25 of Jane Doe? Page 300 Page 302 1 THE WITNESS: On the instruction of my 1 MR. : Objection to form. 2 lawyer, I must invoke my Fifth Amendment right. 2 THE WITNESS: On the instruction of my 3 BY MR. WEISSING: 3 lawyer, I must invoke my Fifth Amendment right. 4 Q. Are you aware that between February 2003 4 BY MR. WEISSING: 5 and June of 2005 that Jane Doe engaged in sexual 5 Q. During that period of time, are you aware 6 7 conduct with Jeffrey Epstein at his mansion? MR. Objection to the form. 6 7 that Jeffrey Epstein perpetuated that kind of behavior upon Jane Doe on dozens of occasions? 8 THE WITNESS: At the instruction of my 8 MR. : Objection to the form. 9 lawyer, I must invoke my Fifth Amendment right. 9 It's ambiguous and otherwise standing 10 BY MR. WEISSING: 10 objection. 11 Q. In 2003 she was only -- are you aware that 11 THE WITNESS: On the instruction of my 12 she was only 14 years of age when she first came to 12 lawyer, I must invoke my Fifth Amendment right. 13 the mansion? 13 BY MR. WEISSING: 14 MR. Objection to form. 14 Q. Are you aware that when he was engaging in 15 THE WITNESS: At the instruction of my 15 the sexual conduct with Jane Doe, that he was doing 16 lawyer, I must invoke my Fifth Amendment right. 16 so with the specific intent to cause her emotional 17 18 BY MR. WEISSING: Q. Between February of 2003 and June 2005, 17 18 and psycholo ical in and damage? MR. : Objection to the form. 19 was Jeffrey Epstein aware that she was 14, 15, 16 19 Calls for a legal conclusion and is ambiguous 20 years of age? 20 and is compound. 21 MR. Objection to form. Calls 21 THE WITNESS: The instruction of my lawyer 22 for her to speculate on the state of mind of a 22 I must invoke my Fifth Amendment right. 23 person she's not admitting she has any 23 BY MR. WEISSING: 24 knowledge of. 24 Q. Did Jeffrey Epstein tell you that when he 25 THE WITNESS: At the instruction of my 25 would engage in the sexual conduct with Jane Doe. 29 (Pages 299 to 302) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 29 of 48 EFTA_00065393 EFTA01246539 Page 303 Page 305 1 that he was intentionally and deliberately 1 going to instruct the witness not to answer it 2 attempting to cause her psychological and emotional 2 at all. 3 pain and sufferin 3 BY MR. WEISSING: 4 Objection to form for the 4 Q. Okay. Did you engage in an agreement with 5 reasons previously stated. 5 Jeffrey Epstein that you would seek out underage 6 THE WITNESS: At the instruction of my 6 female children for his sexual gratification? 7 lawyer, I must invoke my Fifth Amendment right. 7 MR. : Objection to the form. 8 BY MR. WEISSING: 8 It's a compound question. Instruct the witness 9 Q. Did you see evidence that Jeffrey 9 not to answer. 10 Epstein's sexual misconduct with her led to 10 THE WITNESS: On the instruction of my 11 emotional distress on her behalf? 11 lawyer, I must invoke my Fifth Amendment right. 12 MR. • Objection to the form. 12 BY MR. WEISSING: 13 THE WITNESS: At the instruction of my 13 Q. Are you aware that Jane Doe was injured as 14 lawyer, I must invoke my Fifth Amendment right. 14 a result of sex traffickin: committed against her? 15 BY MR. WEISSING: 15 MR. : Objection to form. Uses 16 Q. Are you aware that all of Jeffrey 16 legal terminology like "sex trafficking." and 17 Epstein's behavior with the minor children were 17 presumes as part of the question that she knows 18 violations of numerous criminal laws? 18 a person by the name of Jane Doe, which she 19 MR. Objection to the form. It 19 does not acknowledge. Therefore she's not 20 calls for a legal conclusion. I will instruct 20 going to answer the question in that form. I 21 her not to answer the question at all. 21 instruct her not to answer, based on Fifth 22 BY MR. WEISSING: 22 Amendment because the answer would implicitly 23 Q. Did you know that Jeffrey Epstein's 23 acknowledge that she knows these people or that 24 behavior with these minor children was criminal in 24 she knows Mr. Epstein. 25 nature? 25 THE WITNESS: On the instruction of my Page 304 Page 306 1 MR. Objection to the form. It 1 lawyer, I must invoke my Fifth Amendment right. 2 assumes she has knowledge of whatever conduct 2 BY MR. WEISSING: 3 Jeffrey Epstein, whoever that may be, may have 3 Q. Are you aware that Jane, Jane Doe suffered 4 engaged in. So it requires her to speculate as 4 emotional and psychological trauma and injury as a 5 to a legal conclusion that she's not going to 5 result of the behavior engaged with her by 6 give. 6 Jeffrey Epstein? 7 BY MR. WEISSING: 7 MR. Same objection as stated 8 I. 8 to the previous question and instruct the I were you paid bonuses or any kind 9 witness not to answer, because to attempt to 10 of additional monies for bringing minor children for 10 answer that question would implicitly admit 11 his sexual ratification to him? 11 that she knows Jeffrey Epstein or knows 12 MR. : Objection to form. 12 anything about Jane Doe. 13 Assumes facts such as that she ever worked for 13 THE WITNESS: On the instruction of my 14 Jeffrey Epstein or has any immediate knowledge, 14 lawyer, I must invoke my Fifth Amendment right. 15 is otherwise compound and ambiguous, and 15 BY MR. WEISSING: 16 instruct her not to answer. 16 Q. With regard to these girls who were being 17 THE WITNESS: At the instruction of my 17 procured for Jeffrey Epstein, did you arrange for 18 lawyer, I must exert my Fifth Amendment right. 18 their travel to the mansion? 19 BY MR. WEISSING: 19 MR. : Objection to the form. 20 Q. Did you conspire with Jeffrey Epstein to 20 ambiguous to the term "procurement," and for 21 gain access to minor children for his sexual 21 the reasons previously stated, and the standing 22 gratification? 22 objection, and instruct the witness not to 23 MR. It's a question that calls 23 answer the question. 24 for a legal conclusion. It doesn't in any way 24 THE WITNESS: At the instruction of my 25 lead to any discoverable evidence. and I ant 25 lawyer. I must invoke my Filth Amendment right. 30 (Pages 303 to 306) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 30 of 48 EFTA_00065394 EFTA01246540 Page 307 Page 309 1 BY MR. WEISSING: 1 BY MR. WEISSING: 2 Q. did you 2 Q. Are you aware that Jeffrey Epstein engaged 3 coordinate efforts with others in bringing minor 3 in sexual misconduct with Jane Doe at least 20 times 4 female children to his mansion for his sexual 4 between February 2003 and June 2005 while she was a 5 gratification? 5 minor child? 6 MR. Objection to the form. 6 MR. : Objection to the form. 7 Same objection previously made to the standing 7 THE WITNESS: On the instruction of my 8 objection. 8 lawyer, I must invoke my Fifth Amendment right. 9 THE WITNESS: At the instruction of my 9 BY MR. WEISSING: 10 lawyer. I must invoke my Fifth Amendment right. 10 Q. In the scheduling of girls for 11 BY MR. WEISSING: 11 Jeffrey Epstein. did he have a particular interest 12 Q. Were you aware that many of the girls 12 in girls under the a:e of 14? 13 brought to Epstein's were minor -- Epstein mansion 13 MR. : Objection to the form. It 14 were minors. under at a:e of 14 years of age? 14 assumes she did scheduling for Jeffrey Epstein. 15 MR. : Object to the form. 15 In order to answer the question. she has to 16 Instruct the witness not to answer. 16 implicitly admit that %%filch she's not 17 THE WITNESS: At the instruction of my 17 admitting. and therefore she's not answering 18 lawyer. I must invoke the Fifth Amendment 18 the question. 19 right. 19 THE WITNESS: At the instruction of my 20 BY MR. WEISSING: 20 lawyer, I must invoke my Fifth Amendment right. 21 Q. Did you coordinate with some of the girls 21 BY MR. WEISSING: 22 to bring other underage female children to Epstein 22 Q. In procuring girls for Jeffrey Epstein, 23 for his sexual ratification? 23 was he primarily interested in young, skinny and 24 MR. : Objection. Can we narrow 24 attractive girls? 25 down "other girls" and who we are talking 25 MR. : Objection to the form and Page 308 Page 310 1 about? We already have questioning from 1 implicitly assumes that she procured girls for 2 Mr. Horowitz about his clients and Mr. Kuvin 2 Jeffrey Epstein, which she has not admitted to 3 about his clients. Can we narrow that down a 3 or is not admitting to. so therefore she can't 4 little bit? 4 fairly answer the question as it's been asked. S MR. WEISSING: I'm asking about whether or 5 so therefore. I will instruct her not to answer 6 not she had someone she coordinated with to 6 it. 7 bring other irls. Oka ? 7 THE WITNESS: On the instruction of my 8 MR. And same form objection. 8 lawyer, I must invoke my Fifth Amendment right. 9 THE WITNESS: On the instruction of my 9 BY MR. WEISSING: 10 lawyer. I must invoke my Fifth Amendment 10 Q. With regard to the amount paid to the 11 privilege. 11 girls for what they did with Jeffrey Epstein, would 12 BY MR. WEISSING: 12 the standard a ment be several hundred dollars? 13 Q. When you scheduled these girls to come to 13 MR. : Objection to the form. 14 the mansion, you knew that they were coming for 14 standard objection. 15 Jeffrey Epstein's sexual ratification, did you not? 15 THE WITNESS: At the instruction of my 16 MR. Objection to the form. 16 lawyer, I must invoke my Fifth Amendment right. 17 It's a compound question that assumes she did 17 BY MR. WEISSING: 18 scheduling, assumes she brought them to the 18 Q. Did he have a standard escalation of the 19 mansion, assumes she knows what the mansion is, 19 amount that he would pay depending upon the nature 20 and assumes she knows who Jeffrey Epstein is. 20 of the sexual acts that he rformed with them? 21 So it's a compound question that she can't 21 MR. : Objection. objection. The 22 fairly answer without -- in the form that it's 22 question has been asked and answered in 23 asked and instruct her not to answer. 23 different forms several times, and again 24 THE WITNESS: At the instruction of my 24 standing objection as to the form of the 25 law er. I must invoke my Fifth Amendment right. __.. 25 question. 31 (Pages 307 to 310) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 31 of 48 EFTA_00065395 EFTA01246541 Page 311 Page 313 1 THE WITNESS: At the instruction of my 1 happen? 2 lawyer, I must invoke my Fifth Amendment right. 2 MR. Objection to the form for 3 BY MR. WEISSING: 3 the same reasons previously stated. 4 Q. The engaging in sexual practices with 4 THE WITNESS: At the instruction of my 5 underage girls, was this something that went on for 5 lawyer, I must invoke my Fifth Amendment right. 6 a substantialperiod of time? 6 BY MR. WEISSING: 7 MR. : Objection to the form. 7 Q. Are you aware that Epstein received sexual 8 9 It's ambiguous. It assumes facts that she's not conceding. and she can't fairly answer the 8 9 gratification from sexual) abusing minor children? MR. : Object to the form. It 10 question based on the assumptions that are made 10 calls for a legal conclusion and it's 11 in it. I will therefore instruct her not to 11 ambiguous, and the standing objection as to any 12 answer the question. 12 knowledge of Jeffrey Epstein or any abuse of 13 THE WITNESS: At the instruction of my 13 minor children. 14 lawyer I must exercise my Fifth Amendment 14 THE WITNESS: At the instruction of my 15 right. 15 lawyer, I must invoke my Fifth Amendment right. 16 BY MR. WEISSING: 16 BY MR. WEISSING: 17 Q. With regard to the payments made to the 17 Q. Did Jeffrey Epstein ever tell you that he 18 girls, would he make bigger payments to these minor 18 received sexual gratification from sexually abusing 19 girls depending upon the degree of force he used 19 minor children? 20 towards them? 20 MR. : Objection to the form for 21 MR. : Objection to the form. It 21 the same reasons previously stated. 22 assumes numerous facts that have not been 22 THE WITNESS: At the instruction of my 23 established nor that this witness is admitting. 23 lawyer, I must invoke my Fifth Amendment right. 24 So, I instruct her not to answer. 24 MR. : Folks, it's 4:20. We've 25 THE WITNESS: At the instruction of my 25 been at this for a long, long time. This is Page 312 Page 314 1 lawyer, I must invoke my Fifth Amendment right. 1 now getting pointless, and we're terminating 2 BY MR. WEISSING: 2 the deposition at 5:00. So I suggest you pick 3 Q. Along that line, would he make greater 3 up the pace. 4 payments, larger payments to the girls if they -- if 4 You can ask a million questions about what 5 he was more concerned about them reporting the 5 Jeffrey Epstein knew, what Jeffrey Epstein did. 6 crimes committed a ainst him? 6 She doesn't know. She's not going to say, so 7 MR. Objection to the form. It 7 we've got 40 minute and we're out of here. 8 calls for speculation. It calls for a legal 8 MR. GARCIA: I haven't asked any 9 conclusion. It assumes facts that have not 9 questions. 10 been admitted. Standing objection to the form. 10 MR. EDWARDS: There others of us that have 11 THE WITNESS: At the instruction of my 11 questions. 12 lawyer, I must invoke my Fifth Amendment 12 MR. You can take that up with 13 privilege. 13 the judge. We're done at 5:00. 14 BY MR. WEISSING: 14 MS. EZELL: For the record, there are some 15 Q. Would you pay the girls more money because 15 filed cases who attorneys have not been able to 16 of the amount of force used by Jeffrey Epstein 16 ask questions, and we certainly assert our 17 against them and feared that they would report the 17 right to call Ms. again. 18 crimes committed a ainst them? 18 MR. You can, you can certainly 19 MR. Objection to the form. 19 take that up. but I am not, you know, how many. 20 THE WITNESS: On the instruction of my 20 how many times do we have to ask the same 21 lawyer, I must invoke my Fifth Amendment right. 21 question over and over and over again that it's 22 BY MR. WEISSING: 22 clear is a compound question that asks her to 23 Q. Are you aware that after having unlawful 23 assume facts that she's not admitted she knows 24 sex with these minor children, that Epstein would 24 anything about and it's a hypothetical question 25 tell them not to tell any one or had things would 25 not designed to get us anywhere. 32 (Pages 311 to 31 4) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 32 of 48 EFTA_00065396 EFTA01246542 Page 315 Page 317 1 So can we focus on the specific questions 1 THE WITNESS: On the instruction of my 2 that she can answer or from which you can draw 2 lawyer, I must invoke my Fifth Amendment 3 an adverse inference if asked properly, and 3 privilege. 4 let's move it along. 4 BY MR. WEISSING: 5 MS. F7Ft i • Each young woman's case is an s Q. Do ou know Alan Dershowitz? 6 individual case, and we have the right to ask. 6 MR. The question was asked and 7 ask whatever questions that we need to with 7 answered about three-and-a-half hours ago. 8 regard to each one. 8 THE WITNESS: On the instruction of my 9 MR. 9 lawyer. I must invoke my Fifth Amendment 10 MR. GOLDBERGER: Let's just go forward 10 privilege. 11 until 5:00 and see where were at. 11 BY MR. WEISSING: 12 BY MR. WEISSING: 12 Q. Do ou know David Copperfield? 13 Q. Did you know that Jeffrey Epstein received 13 MR. That question was asked 14 sexual gratification from directing others to 14 about three-and-a-half-hours ago. 15 sexually abuse minor children? 15 THE WITNESS: On the instruction of my 16 MR. Objection to the form. 16 lawyer, I must invoke my Fifth Amendment 17 THE WITNESS: On the instruction of my 17 privilege. 18 lawyer. I must invoke the Fifth Amendment 18 BY MR. WEISSING: 19 right. 19 Q. In addition to his place at. in Palm 20 BY MR. WEISSING: 20 Beach. are you aware that Jeffrey Epstein has an 21 Q. Did you know that JeffreyEpstein received 21 apartment located at 301 East 66th Stmt. Apartment 22 sexual gratification from directing to 22 I4G throw E in New York? 23 sexually abuse minor children? 23 MR. That question was asked 24 MR. Objection to the form. It 24 about four hours ago. It's been asked and 25 assumes knowledge of a person named 25 answered. Page 316 Page 318 1 It is otherwise compound and objectionable. 1 THE WITNESS: At the instruction of my 2 THE WITNESS: On the instruction of my 2 lawyer, I invoke my Fifth Amendment privilege. 3 lawyer, I must invoke my Fifth Amendment right. 3 BY MR. WEISSING: 4 MR. WEISSING: Let's go off the record for 4 Q. While in New York, have you procured 5 a moment. 5 underage minor children to engage in sexual acts 6 THE VIDEOGRAPHER: Are we all good wit 6 with Jeffre tein at that location? 7 going off the record? 7 MR. Object to the form. 8 MR. Yeah, that's fine. 8 THE WITNESS: On the instruction of my 9 MR. HOROWITZ: Yes. 9 lawyer, I must invoke my Fifth Amendment 10 THE VIDEOGRAPHER: Were now off the 10 privilege. 11 record at 4:22 p.m. 11 BY MR. WEISSING: 12 (A brief recess was held.) 12 Q. With regard to the minor children procured 13 THE VIDEOGRAPHER: We are now on the 13 for him at that location, were they school children 14 record. It is 4:24 p.m. 14 in the New York area? 15 BY MR. WEISSING: 15 MR. The previous question, 16 Q. Do you know ? 16 objection to the form. The same as all the 17 MR. KUVIN: 17 previous questions, it assumes a fact that's 18 THE WITNESS: On the instruction of my 18 not been established. It can't fairly be 19 lawyer, I must invoke my Fifth Amendment 19 answered. 20 privilege. 20 THE WITNESS: On the instruction of my 21 BY MR. WEISSING: 21 lawyer, I must invoke my Fifth Amendment 22 Q. Do you know -- have you procured minor 22 privilege. 23 children to have sexual relations with 23 BY MR. WEISSING: 24 at Jeffrey Epstein's mansion? 24 Q. Did Jeffrey Epstein have sexual encounters 25 MR. Objection to the form. 25 with underage people while at that apartment? 33 (Pages 315 to 318) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 33 of 48 EFTA_00065397 EFTA01246543 Page 319 Page 321 1 MR. : Objection to the form. 1 privilege. 2 THE WITNESS: On the instruction of my 2 BY MR. WEISSING: 3 lawyer, I must invoke my Fifth Amendment 3 Q. Have you been to Jeffrey Epstein's 4 privilege. 4 property at 6100 Red Hook Quarters, Suite 3-B, in 5 BY MR. WEISSING: 5 St. Thomas. the Virgin Islands? 6 Q. With regard to underage children that he 6 A. On the instruction of my lawyer, I must invoke 7 had sexual encounters with in New York. were those 7 my Fifth Amendment privilege. 8 school children in that area? 8 Q. Over what period of time have you been to 9 MR. : Objection to the form. No 9 that location? 10 factual basis for the question. 10 MR. Objection to the form. 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 invoke my Fifth Amendment 13 privilege. 13 privilege. 14 BY MR. WEISSING: 14 BY MR. WEISSING: 15 Q. Are you aware of another location that he 15 Q. Are you aware of Jeffrey Epstein engaging 16 has at 457 Madison Avenue. lower floor, New York? 16 in sexual encounters with underage persons at that 17 MR. : Objection to the form. 17 location? 18 THE WITNESS: At the instruction my lawyer 18 MR. Objection to the form. 19 I must invoke my Fifth Amendment privilege. 19 THE WITNESS: On the instruction of my 20 BY MR. WEISSING: 20 lawyer, I must invoke my Fifth Amendment 21 Q. Are you aware of Jeffrey Epstein having 21 privilege. 22 sexual encounters with underage children at that 22 BY MR. WEISSING: 23 location? 23 Q. With regard to the underage children he 24 MR. : No factual basis for the 24 engaged in sexual activity with at that location, 25 question. Objection to form. 25 where were those children procured from? Page 320 Page 322 THE WITNESS: On the instruction of my 1 MR. Objection to the form. It 2 lawyer, I must invoke my Fifth Amendment 2 assumes facts that there has not been any basis 3 privilege. 3 to assume this witness has any knowledge of. 4 BY MR. WEISSING: 4 THE WITNESS: On the instruction of my 5 Q. Was it part of your employment to obtain 5 lawyer, I must invoke my Fifth Amendment 6 underage children for sexual encounters with him at 6 privilege. 7 that location? 7 BY MR. WEISSING: 8 MR. Objection to the form. 8 Q. Were you, were you engaged by Jeffrey 9 THE WITNESS: At the instruction of my 9 Epstein to procure school children from the Virgin 10 lawyer, I must invoke my Fifth Amendment 10 Islands area for sexual behavior at that location? 11 privilege. 11 MR. Objection to the form. 12 BY MR. WEISSING: 12 Standing objection, it assumes knowledge of 13 Q. With regard to the underage children he 13 Jeffrey Epstein. 14 had sex with at that location, were those school 14 THE WITNESS: At the instruction of my 15 children from that area? 15 lawyer I must invoke my Fifth Amendment 16 MR. Can I ask what the good 16 privilege. 17 faith basis is to ask the question if he 17 BY MR. WEISSING: 18 actually had sex with someone at that location? 18 Q. Who is Sto Cowles? 19 Because I, I know no factual predicate that I 19 MR. Objection to the form. 20 have heard today for asking the questions, so I 20 THE WITNESS: At the instruction of my 21 will instruct the witness not to answer it 21 lawyer, I must invoke my Fifth Amendment 22 because it presumes that she knows Jeffrey 22 privilege. 23 Epstein. 23 BY MR. WEISSING: 24 THE WITNESS: On the instruction of my 24 Q. Did Mr. Cowles in your presence ever have 25 lawyer. I must invoke my Fifth Amendment 25 sexual encounters with underage persons at any of 34 (Pages 319 to 322 ) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 34 of 48 EFTA_00065398 EFTA01246544 Page 323 Page 325 1 Mr. Epstein's ro rties? 1 MR. WEISSING: I have no other questions. 2 MR. : Objection to the form. It 2 MR. Okay. Ms. Ezell, 3 assumes knowledge of Mr. Epstein. 3 Mr. Garcia, do you want to go next? 4 THE WITNESS: At the instruction of my 4 MR. GARCIA: Is it okay if I go? 5 lawyer, I must invoke my Fifth Amendment 5 MS. EZELL: We were just discussing that. 6 privilege. 6 I'm going to go quite a while, and I believe 7 BY MR. WEISSING: 7 you think you can finish in 30 or 40 minutes, 8 Q. Were you, did you participate in procuring 8 9 underage children for having sex with Mr. Cowles at 9 MR. GARCIA: About 45. About 45 minutes. 10 11 Mr. Epstein's ro rties? MR. : Objection to the form. It 10 11 MS. EZELL: It makes sense for Mr. Garcia to go first. 12 assumes knowledge of Mr. Epstein. 12 MR. Your decision. Do you 13 THE WITNESS: At the instruction of my 13 need a break or are you okay? 14 lawyer, I must invoke my Fifth Amendment 14 THE WITNESS: I'm okay. 15 privilege. 15 MR. I'll slide over. 16 BY MR. WEISSING: 16 THE VIDEOGRAPHER: Are we on a break? 17 Q. Haveyou ever heard of 17 MR. KUVIN: No no breaks 18 MR. : Objection to the form. 18 CROSS i 19 THE WITNESS: On the instruction of my 19 BY MR. GARCIA: 20 lawyer, I must invoke my Fifth Amendment 20 Q. Ms. , I think you've already 21 privilege. 21 answered this question about your cell number. Are 22 MR. WEISSING: Okay. Let's you objected 22 you able to tell me if you have a new cell number 23 to the form. 23 other than the one that was given to you which I 24 MR. : I'm sorry. I didn't mean 24 believe was 25 to object to form. That one I apologize. Just 25 MR. Instruct the witness not Page 324 Page 326 1 instruct the witness not to answer the 1 to answer the question based on her Fifth 2 question. 2 Amendment privilege. 3 BY MR. WEISSING: 3 THE WITNESS: At the instruction of my 4 5 Haveyou ever gone by the name . 4 5 lawyer. I must invoke my Fifth Amendment right. BY MR. GARCIA: 6 A. At the instruction of my lawyer, I must invoke 6 Q. All right. Can you tell me who pays for 7 my Fifth Amendment privilege. 7 that cell number? 8 Q. Have you ever been paid by Jeffrey Epstein 8 MR. : Same instruction. 9 to obtain underage children to have sex with 9 THE WITNESS: On the instruction of my 10 Jean-Luc Brunel? 10 lawyer, I must invoke my Fifth Amendment 11 MR. : Objection to the form. It 11 privilege. 12 assumes knowledge of Jeffrey Epstein. 12 BY MR. GARCIA: 13 THE WITNESS: At the instruction of my 13 Q. Can you tell me how long you've had that 14 lawyer, I must invoke my Fifth Amendment 14 cell number? 15 privilege. 15 MR. Just -- 16 BY MR. WEISSING: 16 THE WITNESS: On the instruction -- 17 Q. Other than the properties that we've 17 MR. : Just so I'm clear, when 18 discussed, are you aware of any other properties 18 you say "that" cell number -- 19 that Jeffrey Epstein owns? 19 MR. GARCIA: The 20 A. At the instruction of my lawyer, I must invoke 20 MR. Thank you. Instruct the 21 my Fifth Amendment privilege. 21 witness not to answer based on Fifth Amendment. 22 Q. Are you aware of the financial assets of 22 THE WITNESS: At the instruction of my 23 Jeffrey Epstein? 23 lawyer. I must invoke my Fifth Amendment right. 24 A. On the instruction of my lawyer, I must invoke 24 BY MR. GARCIA: 25 my Fifth Amendment privilege. 25 Q. All right. Would you have any objection 35 (Pages 323 to 326) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 35 of 48 EFTA_00065399 EFTA01246545 Page 327 Page 329 1 to me dialing that number to see what the response 1 MR. There's all sorts of facts 2 is? 2 that you may be able to prove from other places 3 MR. Would she object to it? 3 that she's doesn't have to admit to. 4 MR. GARCIA: Yeah. 4 MR. GARCIA: I am not asking her for other 5 MR. You can do whatever you 5 facts. I'm asking her if she files income tax 6 want to do. 6 returns. 7 MR. GARCIA: Okay. 7 MR. Correct. You asked her 8 MR. KUVIN: lust do it. 8 that. She's answered your question. 9 MR. GARCIA: Okay. Let's see if I can 'ut 9 MR. GARCIA: Even though the Government 10 it on speaker. And I am dialing 10 has her income tax returns, if she files them. 11 (Telephone call being made: Please leave 11 you are -- you're still asserting a privilege 12 a message. At the tone please record your 12 on information the Government already has? 13 message.) 13 MR. Yes. 14 BY MR. GARCIA: 14 BY MR. GARCIA. 15 Q. Were you able to hear the voice that said. 15 16 "Please leave a message"? a 17 A. Well, I heard what it said. 17 MR. Objection to the form of 18 Q. All right. Do you recognize that voice? 18 the question. Assumes Mr. Epstein. 19 A. My lawyer has instructed me to assert my Fifth 19 THE WITNESS: On the instruction of my 20 Amendment right. 20 lawyer, I must assert my Fifth Amendment right. 21 Q. As to whether or not you recognize a 21 BY MR. GARCIA: 22 voice? 22 Q. What is our lace of birth? 23 MR. : Yes. 23 MR. Instruct the witness not 24 THE WITNESS: Yes, he has. 24 to answer the question. 25 THE VIDEOGRAPHER: And what's the 25 THE WITNESS: On the instruction of my Page 328 Page 330 1 good-faith basis for asserting that privilege? 1 lawyer, I must invoke my Fifth Amendment right. 2 MR. I don't have to tell you 2 MR. GARCIA: How can that possibly 3 what the good-faith basis is. She's asserting 3 incriminate her? 4 a privilege as to whether she recognizes a 4 MR. : I will answer that 5 voice or not. If you can identify the voice, 5 question when a judge asks it to me. 6 it could potentially lead back to other places 6 MR. GARCIA: Do you have any case law that 7 that could incriminate her in theory. So, she 7 supports that question as subject to a Fifth 8 has a good faith basis to invoke it. 8 Amendment objection? 9 BY MR. GARCIA: 9 MR. : I'll answer the question 10 Q. Do ou have a 'ob currently? 10 when a judge asks it of me. 11 MR. Instruct the witness not 11 BY MR. GARCIA: 12 to answer. 12 Q. Did ou raduate from high school? 13 THE WITNESS: On the instruction of my 13 MR. : Same objection, same 14 lawyer, I choose to assert my Fifth Amendment 14 instruction. 15 right. 15 THE WITNESS: On the advice of my lawyer, 16 BY MR. GARCIA: 16 I must invoke my Fifth Amendment right. 17 Q. Do ou file income tax returns? 17 BY MR. GARCIA: 18 MR. Same instruction. 18 . What states have you lived in other than 19 THE WITNESS: On the instruction of my 19 an 20 lawyer, I choose to assert my Fifth Amendment 20 MR. : Same instruction. 21 right. 21 THE WITNESS: On the instruction of my 22 MR. GARCIA: The Government. presumably, 22 lawyer, I must invoke my Fifth Amendment right. 23 has her income tax returns, so what is the 23 BY MR. GARCIA: 24 basis for asserting a privilege against 24 Q. Did ou attend college? 25 self-incrimination? 25 MR. : Same instruction. 36 (Pages 327 to 3 3 0) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 36 of 48 EFTA_00065400 EFTA01246546 Page 331 Page 333 1 THE WITNESS: On the instruction of my 1 MR. KUVIN: So it's really kind of 2 lawyer, I must invoke my Fifth Amendment right. 2 comical, so I apologize for my laughing, but 3 BY MR. GARCIA: 3 it's just borderin: -- 4 Q. Have ou ever been to New Mexico? 4 MR. : Your -- 5 MR. Same instruction. 5 MR. KUVIN: -- on absurd. 6 THE WITNESS: On the instruction of my 6 MR. : Look, I think most of the 7 lawyer, I must invoke my Fifth Amendment right. 7 questions that the rest of you-all asked today 8 BY MR. GARCIA: 8 were absurd, and we've answered your questions 9 Q. Do ou have a assport? 9 respectfully. We didn't laugh. We didn't make 10 MR. Same instruction. 10 fun of you. It is unprofessional and 11 THE WITNESS: On the instruction of my 11 disrespectful of you to laugh at the witness 12 lawyer, I must invoke my Fifth Amendment right. 12 when she's asserting a Constitutional right. 13 MR. GARCIA: The Government has access to 13 And don't walk away from me when I'm 14 her passport, and you're saying that's, you can 14 talking to you. 15 object to whether or not she has a passport? 15 MR. KUVIN: I'm not walking away, I'm 16 MR. There's lots of things 16 listening. I'm not walking away at all. I'm 17 that there may be evidence of from other 17 just throwing away my trash. I apologize if it 18 sources that she doesn't have to admit to. She 18 seemed like I was walking away. 19 has a Constitutional right not to admit to. 19 MR. : Uh-huh, which you were. 20 BY MR. GARCIA: 20 Mr. Garcia. if you want to ask your questions, 21 Q. Have ou ever traveled to Mexico? 21 you may ask them. She will answer them. If 22 MR. Same instruction. 22 you don't like the questions, you can certify 23 THE WITNESS: On the instruction of my 23 them to the judge and I will be happy to 24 lawyer, I must invoke my Fifth Amendment right. 24 discuss with the judge whether or not there is 25 25 a good-faith basis. Page 332 Page 334 1 BY MR. GARCIA: 1 MR. GARCIA: Certify all those questions. 2 Q. Do ou have a driver's license? 2 BY MR. GARCIA: 3 MR. Same instruction. 3 Q. Let me ask you, do you, do you deny that 4 THE WITNESS: On the instruction of my 4 you solicited a minor by the name of Jane Doe No. II 5 lawyer, I must invoke my Fifth Amendment right. 5 for the purposes of providing sexual services to 6 BY MR. GARCIA: 6 Jeffrey Epstein? 7 Q. Do you have a driver's license in New 7 MR. Instruct the witness not 8 York? 8 to answer. 9 MR. Same instruction. 9 THE WITNESS: At the instruction of my 10 THE WITNESS: On the instruction of my 10 lawyer, I must assert my Fifth Amendment right. 11 lawyer, I must invoke my Fifth Amendment right. 11 BY MR. GARCIA: 12 BY MR. GARCIA: 12 Q. Do you deny that you solicited Jane Doe 13 Q. Are ou registered to vote? 13 No. 2 on multiple occasions by your cellphone in 14 MR. Same instruction. 14 order for her to provide sexual services for pay to 15 THE WITNESS: On the instruction of my 15 Mr. Epstein? 16 lawyer, I must invoke my Fifth Amendment right. 16 MR. : Same instruction, same 17 MR. : Mr. Kuvin, if you'd like 17 objection to the form previously stated. 18 to keep laughing, feel free. 18 THE WITNESS: At the instruction of my 19 MR. KUVIN: I think it's absolutely absurd 19 lawyer, I must invoke my Fifth Amendment right. 20 that she's objecting to some of these questions 20 BY MR. GARCIA: 21 or taking the Fifth to some of these questions. 21 Q. Do you know why Jeffrey Epstein is only 22 I mean. I want to Sid to ask her now if the sky 22 interested in minor irls? 23 is blue. I think she's going to take the Fifth 23 MR. : Objection to the form, 24 as to that . uestion, as well. 24 standing objection. It assume she has some 25 MR. Look, I. I -- 25 knowledge of Jeffrey Epstein that', implicit in 37 (Pages 331 to 3 3 4 ) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 37 of 48 EFTA_00065401 EFTA01246547 Page 335 Page 337 1 the question. 1 compelled by her parents to do anything. 2 THE WITNESS: On the instruction of my 2 Move on. I will debate the legal issues 3 lawyer. I must invoke my Fifth Amendment right. 3 with the judge, not with you. 4 BY MR. GARCIA: 4 BY MR. GARCIA: S 6 Q. Do your parents approve of your association with Mr. E 'stein? 5 6 Q. Doyou have an siblings? MR. : Instruct the witness not / MR. Objection to the form. 7 to answer. That was also asked and answered 8 What's -- instruct the witness not to answer. 8 many hours ago. 9 THE WITNESS: On the instruction of my 9 THE WITNESS: On the instruction of my 10 lawyer -- 10 lawyer, I must invoke my Fifth Amendment right. 11 MR. GARCIA: To the form or is this some 11 BY MR. GARCIA: 12 constitutional issue that you're raising? 12 Q. Have you ever discussed your relationship 13 MR. Object to the form of your 13 with Mr. Epstein with your siblings, assuming you 14 question as assuming facts that have not been 14 have any? 15 established, and also it's irrelevant to lead 15 MR. : Instruct the witness not 16 to any admissible evidence. But to the extent 16 to answer the question. Objection to the form. 17 that you're asking any questions that could 17 THE WITNESS: At the instruction of my 18 relate to her parents, she is invoking the 18 lawyer, I must invoke my Fifth Amendment right. 19 Fifth Amendment as to that question. 19 BY MR. GARCIA: 20 THE WITNESS: At the instruction of my 20 Q. Do you have a fiance, boyfriend, or 21 lawyer, I must invoke my Fifth Amendment right. 21 significant other? 22 BY MR. GARCIA: 22 MR. : Objection to the form. 23 Q. How did ou meet Mr. Epstein? 23 Instruct the witness not to answer as to the 24 MR. Instruct the witness not 24 Fifth Amendment. 25 to answer. 25 THE WITNESS: On the instruction of my Page 336 Page 338 1 1 THE WITNESS: At the instruction of my 1 lawyer, I must invoke my Fifth Amendment right. 2 lawyer, I must invoke my Fifth Amendment right. 2 BY MR. GARCIA: 3 BY MR. GARCIA: 3 Q. Have you discussed your relationship with 4 Q. Did ourparents know Mr. Epstein? 4 Mr. Epstein with your boyfriend, fiance, or 5 MR. • That question I think was 5 significant other? 6 asked and answered several hours ago, and I'll 6 MR. : Objection to the form, the 7 instruct the witness not to answer as to Fifth 7 standing objection, assumes knowledge of 8 Amendment privilege. 8 Mr. Epstein, and I will instruct her not to 9 THE WITNESS: On the instruction of my 9 answer. 10 lawyer, I must invoke my Fifth Amendment right. 10 THE WITNESS: On the instruction of my 11 BY MR. GARCIA: 11 lawyer, I must invoke my Fifth Amendment right. 12 Q. Have you ever discussed your relationship 12 BY MR. GARCIA: 13 14 with Mr. E ou tein with r parents? MR. Objection to the form. 13 14 Q. Now, you were asked before if you visited Mr. Epstein at the County jail; is that correct, 15 Instruct the witness not to answer. 15 here in Palm Beach County? Do you recall those 16 THE WITNESS: On the instruction of my 16 questions? 17 lawyer, I must invoke my Fifth Amendment right. 17 A. I do recall being asked that. 18 MR. GARCIA: Wouldn't that be a waiver if 18 Q. All right. And did you have to fill out 19 she's discussed it with her parents? 19 any type of log when you visited the Palm Beach 20 MR. Waiver of what? 20 County jail and provide identification to the 21 MR. GARCIA: A waiver of any imagined or 21 Government as to what your name was, and provide 22 real Fifth Amendment right against 22 your name to the Government and who you were 23 self-incrimination. 23 visiting? 24 MR. • It's only waived if it was 24 MR. : Objection to the form 25 compelled and you did it anyway. She %wait 25 because it assume, she went to the Palm Beach 38 (Pages 335 to 338) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 38 of 48 EFTA_00065402 EFTA01246548 Page 339 Page 341 1 County jail. When that question was asked 1 lawyer, I invoke my Fifth Amendment right. 2 before, she invoked her Fifth Amendment 2 BY MR. GARCIA: 3 privilege, so she's not answering the question 3 Q. Why did you go see Jeffrey Epstein at the 4 this time either. 4 County jail? 5 THE WITNESS: At the instruction of my 5 MR. : Objection to the form. It 6 lawyer, I must invoke my Fifth Amendment right. 6 assumes facts that have not been acknowledged 7 BY MR. GARCIA: 7 or admitted. Instruct the witness not to 8 Q. Have you spoken to Jeffrey Epstein about 8 answer. 9 this deposition that ou're giving today? 9 THE WITNESS: At the instruction of my 10 MR. • Instruct the witness not 10 lawyer, I invoke my Fifth Amendment right. 11 to answer the question. 11 BY MR. GARCIA: 12 THE WITNESS: At the instruction of my 12 Q. Were your conversations monitored by 13 lawyer, I invoke my Fifth Amendment right. 13 anyone? 14 BY MR. GARCIA: 14 MR. : Objection to the form. It 15 Q. When is the last time you spoke with 15 assumes facts that have not been admitted or 16 Mr. Epstein? 16 acknowledged and instruct the witness not to 17 MR. Instruct the witness not 17 answer. 18 to answer the question. 18 THE WITNESS: At the instruction of my 19 THE WITNESS: On the instruction of my 19 lawyer, I invoke my Fifth Amendment right. 20 lawyer, I invoke my Fifth Amendment right. 20 BY MR. GARCIA: 21 BY MR. GARCIA: 21 Q. Let me show you what's been filed on your 22 Q. Was anybody else in the room when you 22 behalf as an answer with affirmative defenses. I 23 spoke to Mr. E stein besides the two of you? 23 have some extra copies here. We'll mark her copy as 24 MR. Instruct the witness not 24 Exhibit -- 25 to answer the question. Object to the form 25 THE COURT REPORTER: 15. Yes, 15. Page 340 Page 342 1 because it assumes any knowledge of 1 MR. GARCIA: What is it, 15? 2 Mr. Epstein. 2 THE COURT REPORTER: 15. yes. 3 THE WITNESS: At the instruction of my 3 (Plaintiffs Exhibit No. 15 was marked for 4 lawyer, I invoke my Fifth Amendment right. 4 identification.) 5 BY MR. GARCIA: 5 BY MR. GARCIA: 6 Q. Where are ou currently staying? 6 Q. Could you please take a look at that 7 MR. : Instruct the witness not 7 document. 8 to answer. 8 A. Do you want me to read the whole thing? 9 BY MR. GARCIA: 9 Q. No, just take a look at it so I can ask 10 Q. Are ou current) engaged -- 10 you if you've ever seen it before. 11 MR. : Hold on. Hold on. Let 11 MR. : You can answer. 12 her -- let her respond. 12 THE WITNESS: No. no. 13 THE WITNESS: At the instruction of my 13 BY MR. GARCIA: 14 lawyer, I invoke my Fifth Amendment right. 14 Q. Were you aware that you were a Defendant 15 BY MR. GARCIA: 15 in a civil action filed by Jane Doe II, in the 16 Q. Are you currently engaged in any criminal 16 United States District Court Southern District of 17 activity at the wherever it is that you're staying? 17 Florida? 18 MR. : Object to the form in that 18 MR. : You can answer that other 19 it requires a legal conclusion. Second of all, 19 than if it involves discussions, private 20 I believe it's meant more for harassment than 20 discussions you had with your lawyers. 21 to lead to any discoverable evidence. Third of 21 THE WITNESS: I only would have if my 22 all, she's instructed not to answer the 22 lawyer told me. I don't know for sure. 23 question based on her Fifth Amendment 23 BY MR. GARCIA: 24 privilege. 24 Q. Okay. Take a look at Page 5. Do you see 25 THE WITNESS: On the instruction of my 25 the section that begins with "Affirmative defenses"? 39 (Pages 339 to 342) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 39 of 48 EFTA_00065403 EFTA01246549 Page 343 Page 345 1 A. Uh-huh. Yes. 1 BY MR. GARCIA: 2 Q. Do you have any evidence to support the 2 Q. Did you have any conversations with 3 first affirmative defense, and I'll tell you for the 3 Jane Doe No. II at any time in which she told you 4 record that Jane Doe II, is Jane Doe No. II. was a 4 that she was a, she consented and was a willing S willing participant in the acts alleged. and 5 participant in the acts that are alleged in the 6 7 therefore her claims are barred or her damages are required to be reduced accordingly? 6 7 complaint with Jeffre . rein? MR. : Object to the form because 8 MR. I'm sony. Can you repeat 8 it assumes knowledge of Jane Doe No. II. And 9 the question that you're asking? 9 the witness is going to her invoke her Fifth 10 MR. GARCIA: Can you read it back? 10 Amendment privilege as to any evidence or any 11 (The requested portion of the record was 11 knowledge of Jane Doe No. II. 12 read by the reporter.) 12 THE WITNESS: At the instruction of my 13 BY MR. GARCIA: 13 lawyer, I must invoke my Fifth Amendment right. 14 Q. Do you have any evidence to support that 14 BY MR. GARCIA: 15 affirmative defense? 15 Q. The second affirmative defense on the same 16 A. I don't understand the question. 16 page it says, "As to Plaintiffs claim, Plaintiff 17 Q. Okay. This affirmative defense alleges on 1'i actually consented to and participated in conduct 18 your behalf by Mr. claims that Jane Doe 18 similar and are identical to the acts alleged with 19 No. II consented to and was a willing participant in 19 other persons which were the sole or contributing 20 the acts alleged, and therefore her claims were 20 cause of Plaintiffs alleged damages." 21 barred or her damages were required to be reduced. 21 Do you have any facts to support the 22 Do you have any factual basis for 22 second affirmative defense? 23 asserting that defense, and if so. what facts do you 23 MR. : And once again to the 24 have to sup ion it? 24 extent that, the. the question -- object to the 25 MR. Do you understand the 25 form to the extent the question requires her to Page 344 Page 346 1 question? 1 acknowledge any knowledge of Jane Doe No. II or 2 THE WITNESS: Uh-uh. 2 Jane Doe No. II's activities she would invoke 3 THE COURT REPORTER: Is that a yes? 3 her Fifth Amendment privilege. I would 4 THE WITNESS: Yes, sony. 4 instruct her to do so. 5 MR. : You can answer if you can 5 THE WITNESS: On the instruction of my 6 answer. 6 lawyer, I must invoke my Fifth Amendment right. 7 THE WITNESS: I'm sorry. Do I have any 7 BY MR. GARCIA: 8 facts. 8 Q. So I don't waste any time with the court 9 BY MR. GARCIA: 9 on these issues, can you tell me at least a yes or 10 Q. Right. What, what evidence do you have to 10 no as to whether or not you have any facts to 11 support the claim that Jane Doe No. II consented to 11 support. without telling me what the facts are, 12 and was a willing participant with Jeffrey Epstein 12 whether or not you have any facts to support the 13 in the acts described in the complaint? 13 defenses? 14 MR. : I am just consulting on 14 MR. Whether she personally 15 what might be a privilege issue. 15 does? 16 (A discussion was held off the record.) 16 MR. GARCIA: Yes, exactly. personally. 17 MR. : A portion of the truth of 17 MR. -- or has her defense team 18 that would require attorney-client privilege 18 acting on her behalf? 19 information, so I am going to instruct her not 19 MR. GARCIA: No, just personally. 20 to answer that portion of it, and ask that -- 20 MR. No, I am going to instruct 21 MR. GARCIA: Okay. 21 her not to answer based on her Fifth Amendment. 22 MR. : Hold it. Okay. And as to 22 BY MR. GARCIA: 23 the rest. I'll instruct her not to answer the 23 Q. Do you have any information to support 24 question based on her Fifth Amendment 24 the, any facts to support the third affirmative 25 privilege. 25 defense that the Plaintiff impliectly consented to 40 (Pages 343 to 346) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 40 of 48 EFTA_00065404 EFTA01246550 Page 347 Page 349 1 the acts alleged by not objecting. and therefore her 1 page? 2 claims are barred or her damages are required to be 2 A. What page, sir? 3 reduced accordin 1 ? 3 Q. Page 6. It says, "As to Plaintiff's 4 MR. Once again I would assert 4 claim, Defendant reasonably, reasonably believed or S an attorney-client privilege as to -- this, 5 was told that the Plaintiff had attained the age of 6 this question that you have asked requires a 6 18 years old at the time of the alleged acts." / legal conclusion which would require her to -- 7 Who told you that the Plaintiff was 18 at 8 MR. GARCIA: I'm not asking for the legal 8 the time of the acts involved in this case? 9 conclusion. I'm asking what facts she has to 9 MR. Again, I would instruct 10 support an affirmative defense which requires 10 the witness not to answer the question based on 11 you to put on evidence of what that defense is. 11 both the attorney-client privilege and her 12 MR. Right. But you're asking 12 Fifth Amendment privilege against 13 her what evidence she has of legal conclusions, 13 self-incrimination. 14 which is concepts such as consent, claims being 14 THE WITNESS: At my lawyer's instruction. 15 barred, damages required to be reduced 15 I must assert my Fifth Amendment right. 16 accordingly. those are legal concepts you're 16 BY MR. GARCIA: 17 asking her to make, a lay person to give a 17 Q. At the time that Jane Doe No. II was 18 statement as to what the factual evidence is 18 involved in some sort of a relationship, if you can 19 there to support a legal conclusion. The only 19 call it that, with Mr. Epstein, did you have 20 way she would know if they support the legal 20 counsel? Didyou have a lawyer representing 21 conclusion is based on conversations she's had 21 you? MR. Object to the form. 22 with counsel. 22 She -- the question assumes that them is any 23 MR. GARCIA: So, are you instructing her 23 knowledge of any relationship between Jane Doe 24 not to answer on that basis or -- 24 No. II and a person named Mr. Epstein. She's 25 MR. Yes, that's right, yeah. 25 not going to answer the question based on the Page 348 Page 350 1 MR. GARCIA: -- the Fifth Amendment 1 Fifth Amendment. 2 privilege? 2 THE WITNESS: At the instruction of my 3 MR. On, on that basis only. 3 lawyer, I assert my Fifth Amendment right. 4 As to that question I am instructing her not to 4 BY MR. GARCIA: 5 answer on the basis of the attorney-client 5 Q. Did Jane Doe No. II ever tell you that she 6 privilege. 6 was 18 at the time of the alleged acts? 7 BY MR. GARCIA: 7 MR. Object to the form. 8 Q. Outside of your discussions with counsel. 8 Instruct the witness not to answer based on the 9 do you have any facts to support the third 9 Fifth Amendment. 10 affirmative defense based upon your discussions with 10 THE WITNESS: On the instruction of my 11 Jane Doe No. II or discussions with any other person 11 lawyer, I assert my Fifth Amendment right. 12 or review independently of your counsel of any 12 BY MR. GARCIA: 13 document that would support this third affirmative 13 Q. I think the Fifth Affirmative Defense is 14 defense? 14 pretty much similar, but it says, "As to Plaintiffs 15 MR. Object to the form to the 15 claim, Plaintiffs claims are barred as she said she 16 extent that it requires any acknowledgment of 16 was 18 years or older at the time," end quote. I 17 any knowledge of Jane Doe No. II, I would 17 assume that you're referring to yourself; she told 18 instruct her not to answer the question based 18 that she was 18 tears old at the time? 19 on the Fifth Amendment. 1 9 you MR. Instruct the witness not 20 THE WITNESS: Upon my lawyer's 20 to answer based on her Fifth Amendment 21 instruction, I choose to exert my Fifth 21 privilege. 22 Amendment right. 22 BY MR. GARCIA: 23 BY MR. GARCIA: 23 Q. Do you have any evidence to support that 24 Q. The fourth affirmative defense on Page 6 24 assertion; that is did you make any journal 25 of Exhibit 15. could >ou turn to that on the next 25 entries — by the way. do you keep any type of 41 (Pages 347 to 350) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 41 of 48 EFTA_00065405 EFTA01246551 Page 351 Page 353 1 journal or di ? 1 BY MR. GARCIA: 2 MR. : Instruct the witness not 2 Q. I'm going to give you some dates here. If 3 to answer based on the Fifth Amendment. 3 you want to, I don't know if he wants to write them 4 BY MR. GARCIA: 4 down or take them one at a time: June 16th, 2003; 5 Q. Have ou ever ke t -- 5 July 2nd, 2003; April 9th, 2004; June 7th, 2004; 6 : MR. Hold on, please. Let her, 6 July 30th, 2004; August 30th, 2004; October 9th, 7 let her answer. 7 2004; October 12th, 2004; October 30th. 2004; and 8 THE WITNESS: On the instruction of my 8 November 9th, 2004. Do you recall soliciting Jane 9 lawyer, I assert my Fifth Amendment right. 9 Doe No. II to come to Jeffrey Epstein's home on any 10 BY MR. GARCIA: 10 of those dates? 11 Q. Have you ever kept a journal or diary in 11 MR. Objection to the form. 12 the past? 12 Standing objection as previously stated as to 13 MR. : Same instruction. 13 any knowledge of Jeffrey Epstein or Jane Doe 14 THE WITNESS: At the instruction of my 14 No. II, and instruct the witness not to answer. 15 lawyer. I assert my Fifth Amendment right. 15 THE WITNESS: On the instruction -- 16 BY MR. GARCIA: 16 MR. GARCIA: Okay. So your instruction is 17 Q. As to the sixth affirmative defense, what 17 not based on Fifth Amendment? 18 evidence do you have that Plaintiffs alleged 18 MR. It is. I am instructing 19 damages were caused in whole or in part by events 19 her not to answer based on Fifth Amendment. 20 and/or circumstances completely unrelated to the 20 THE WITNESS: On the instruction of my 21 incidents alle: ed in the complaint? 21 lawyer, I must exercise my Fifth Amendment 22 MR. : As to that, I would assert 22 right. 23 an attorney-client privilege. 23 BY MR. GARCIA: 24 BY MR. GARCIA: 24 Q. Do you contest, in any way, that Jane Doe 25 Q. Well, do you have a witness that you can 25 No. II was solicited by you on each of these dates Page 352 Page 354 1 identify that will testif about this? 1 for the of Jeffrey Epstein with 2 MR. Instruct the witness not 2 purposes providing sexual massa es and/or services. 3 to answer that based on the Fifth Amendment 3 MR. Objection to form. It's a 4 privilege. She doesn't have to help you. 4 compound question. It assumes facts that she's 5 THE WITNESS: On the instruction of my 5 not acknowledged or admitted. It is therefore 6 lawyer, I exert my Fifth Amendment right. 6 compound and ambiguous. I would instruct her 7 MR. GARCIA: All right. So your position 7 not to answer based on her Fifth Amendment 8 is that you don't have to answer any questions 8 privilege. 9 about affirmative defenses, but yet you can 9 BY MR. GARCIA: 30 maintain them? 10 Q. Where did ou live in 2003? 11 MR. : That's not what I said. 11 MR. Instruct the witness not 12 You asked to identify a particular witness. If 12 to answer based on the Fifth Amendment. 13 identifying a witness could potentially lead to 13 THE WITNESS: At the instruction of my 14 putting herself in jeopardy for criminal 14 lawyer, I must exercise my Fifth Amendment 15 prosecution, she doesn't have to answer. 15 right. 16 MR. GARCIA: This would be a witness that 16 BY MR. GARCIA: 17 would support her defense, not, not cause her 17 Q. What cellphone number did you have in 18 criminal •rosecution. 18 2003? 19 MR. I, I understand your 19 MR. Same instruction. 20 point, and my point is if identifying such a 20 THE WITNESS: At the instruction of my 21 witness could also lead her potentially to 21 lawyer I must exert my Fifth Amendment right. 22 criminal prosecution by the Government, she 22 BY MR. GARCIA: 23 doesn't have to answer that question and she's 23 Q. Where did ou live in 2004? 24 not going to. Witnesses can have many factual 24 MR. Same instruction. 25 purposes. 25 THE WITNESS: At the instruction of my 42 (Pages 351 to 354) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 42 of 48 EFTA_00065406 EFTA01246552 Page 355 Page 357 1 lawyer I must exercise my Fifth Amendment 1 BY MR. GARCIA: 2 right. 2 Q. There was some doctor that was -- you were 3 4 BY MR. GARCIA: Q. What cellphone number did you have in 3 4 asked about earlier toda . Do you recall his name? MR. : The name that was asked o 5 2004? 5 her? If you remember -- 6 MR. : Same instruction. 6 MR. KUVIN: It's Dr. — 7 THE WITNESS: At the instruction of my 7 MR. GOLDBERGER: Feelgood? 8 lawyer I just exercise my Fifth Amendment 8 MR. KUVIN: No. that's your doctor. Jack. 9 right. 9 Dr. -- hang on. III get it for you. 10 BY MR. GARCIA: 10 MS. F7PI I : Bard, it was Bard. 11 Q. Where did you first recruit Jane Doe 11 MR. KUVIN: Bard. B-a-r-d, I believe. 12 No. II for soliciting her to provide sexual services 12 MR. GARCIA: Dr. Bard. I think that's 13 to Jeffrey E . stein? 13 right. 14 MR. : Objection to the form. 14 BY MR. GARCIA: 15 Standing objection previously stated. Instruct 15 Q. Do you know a Dr. Bard? 16 the witness not to answer based on her Fifth 16 THE WITNESS: At the instruction of my 17 Amendment. 17 lawyer, I choose to exercise my Fifth Amendment 18 THE WITNESS: At the instruction of my 18 right. 19 lawyer I must exercise my Fifth Amendment 19 BY MR. GARCIA: 20 right. 20 Q. Did Dr. Bard ever provide any type of 21 22 BY MR. GARCIA: Q. Did you go to clubs where young women hung 21 22 dental services MR. ces to ou? : Objection to the form. It 23 out and approach them in order to solicit them for 23 assumes facts that have not been established 24 Mr. Epstein? 24 that she's ever seen by Dr. Bard. So, once 25 MR. : Objection to the form. It 25 again, we assert a Fifth Amendment privilege. Page 356 Page 358 1 assumes knowledge of Mr. Epstein, therefore I 1 THE WITNESS: At the instruction of my 2 instruct the witness not to answer based on the 2 lawyer, I must exercise my Fifth Amendment 3 Fifth Amendment privilege. 3 right. 4 THE WITNESS: At the instruction of my 4 BY MR. GARCIA: 5 lawyer, I must exercise my Fifth Amendment 5 Q. Have you ever had any dental work done in 6 right. 6 the past ten years? And I don't mean cavities. fm 7 BY MR. GARCIA: 7 talking about cosmetic-type dental work. 8 Q. Did you ever pay Jane Doe No. II for 8 A. Yes, sir. 9 10 sexual services and/or sexual massages provided to Mr. Epstein? 9 10 Q. All ri ht. What state was it in? MR. One second. 11 MR. Objection to the form for 11 MR. GOLDBERGER: Excuse me. 12 the reasons previously stated in the standing 12 MR. You can answer. You can 13 objection. Instruct the witness not to answer, 13 answer as to what state it occurred. 14 based on the Fifth Amendment. 14 THE WITNESS: In New York. 15 THE WITNESS: On the instruction of my 15 BY MR. GARCIA: 16 lawyer, I choose to exercise my Fifth Amendment 16 Q. Was the dental work paid for by anyone 17 right. 17 other than yourself? 18 BY MR. GARCIA: 18 MR. Instruct the witness not 19 Q. Did ou a in U.S. currency? 19 to answer based on the Fifth Amendment 20 MR. Same objection, same 20 privilege. 21 instruction. 21 THE WITNESS: At the instruction of my 22 THE WITNESS: On the instruction of my 22 lawyer, I must assert my Fifth Amendment right. 23 lawyer, I choose to exercise my Fifth Amendment 23 BY MR. GARCIA: 24 right. 24 Q. What was the name of the doctor that 25 25 rovided the cosmetic dental services? 43 (Pages 355 to 358) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 43 of 48 EFTA_00065407 EFTA01246553 1 2 3 4 5 6 7 Page 359 MR. You can answer. Sony, wait a minute. Instruct the witness not to answer the question based on the Fifth Amendment. BY MR. GARCIA: Q. Did Jeffre stein -- MR. : Hold on. You have to let 1 2 3 4 6 7 Page 361 any type of surgical procedure performed on his penis? MR. Objection to the form to the extent it assumes any knowledge of Mr. Epstein and instruct the witness not to answer. THE WITNESS: On the instruction of my 8 her assert her privilege. 8 lawyer, I must invoke my Fifth Amendment right. 9 THE WITNESS: At the instruction of my 9 BY MR. GARCIA: 10 lawyer, I must assert my Fifth Amendment right. 10 Q. Has he ever told you that he's ever had a 11 BY MR. GARCIA: 11 penile implant added to his penis? 12 Q. Did Jeffrey Epstein suggest that you get 12 MR. Same instruction, same 13 the dental work done? 13 objection. 14 MR. : Instruct the witness not 14 THE WITNESS: On the instruction of my 15 to answer. Objection to the form, instruct the 15 lawyer, I must invoke my Fifth Amendment right. 16 witness not to answer. 16 BY MR. GARCIA: 17 THE WITNESS: On the instruction of my 17 Q. Has Mr. Epstein -- have you ever observed 18 lawyer, I must assert my Fifth Amendment right. 18 Mr. Epstein or has he ever told you that he takes 19 BY MR. GARCIA: 19 Viagra or Cialis? 20 Q. Do ou know Kevin Spacey? 20 MR. Objection to the form. 21 MR. : Are you asking if she's 21 Standing objection. It assumes knowledge of 22 ever met Kevin Spacey? 22 Mr. Epstein, and therefore I would instruct the 23 MR. GARCIA: Yes, I'm sorry. 23 witness not to answer. 24 MR. KUVIN: Them you go. 24 THE WITNESS: On the instruction of my 25 MR. Instruct the witness not 25 lawyer, I must invoke my Fifth Amendment right. Page 360 Page 362 1 to answer the question. 1 BY MR. GARCIA: 2 THE WITNESS: At the instruction of my 2 Q. Did you ever meet Lewis or Dorothy 3 lawyer, I must invoke my Fifth Amendment right. 3 Cullman, C-u-1-1-m-a-n? 4 BY MR. GARCIA: 4 MR. GARCIA: I think the look means that 5 Q. Did ou ever met Chris Tucker? 5 she's goin to oliect. 6 MR. Same instruction. 6 MR. : Are you asking -- I just 7 THE WITNESS: At the instruction of my 7 want to clarify the question. Are you asking 8 lawyer I must invoke my Fifth Amendment 8 if she has ever met a person she knows to have 9 privilege. 9 that name or if she's ever -- 10 BY MR. GARCIA: 10 MR. GARCIA: Yes. 11 Q. Did ou ever meet Bill Clinton? 11 MR. : You can answer the 12 MR. Same instruction. 12 question. 13 THE WITNESS: On the instruction of my 13 THE WITNESS: No. 14 lawyer, I must invoke my Fifth Amendment right. 14 MR. GARCIA: There were two people, Lewis 15 BY MR. GARCIA: 15 L-e-w-i-s and Dorothy Cullman. 16 Q. Did you ever fly with these three 16 MR. : So it's split it in two 17 gentlemen and Jeffrey Epstein to Africa on Jeffrey 17 questions. Do Lewis first and Dorothy second. 18 Epstein's 727 ai lane? 18 Have you met Lewis? 19 MR. : Objection to the form. 19 THE WITNESS: No. 20 It's a compound question. Instruct the witness 20 MR. : Dorothy? 21 not to answer based on the Fifth Amendment. 21 THE WITNESS: No. 22 THE WITNESS: At the instruction of my 22 BY MR. GARCIA: 23 lawyer, I must invoke my Fifth Amendment right. 23 Q. Have you had any other type of cosmetic 24 BY MR. GARCIA: 24 surgery other than the dental surgery that you 25 Q. Has Mr. Epstein ever told jou that he had 25 talked about? 44 (Pages 359 to 362) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 44 of 48 EFTA_00065408 EFTA01246554 Page 363 Page 365 1 MR. What -- we're getting. 1 Fifth Amendment on who this dentist was? 2 we're getting into personal privacy issues 2 MR. Yes, she did. 3 here. Can we, can we get a little foundation 3 BY MR. GARCIA: 4 for why that's relevant? 4 Q. Do you have a Facebook page? 5 MR. GARCIA: I don't think I have to 5 A. No. 6 reveal that to you, but I would proffer this. 6 Q. Have you ever had one? / that if Mr. Epstein paid for it. it might lead 7 A. I may have started one, but I, for like ten 8 to perh s bias on the art of the witness. 8 minutes. 9 MR. Well, why don't you ask it 9 Q. You started one for ten minutes. Did you 10 that way? She's ever had any surgery that was 10 turn it off after ten minutes? 11 paid for by Mr. Epstein or otherwise funded by 11 A. Yes. 12 Mr. Epstein. 12 Q. What year was this? 13 MR. KUVIN: On behalf of the other -- on 13 A. I don't remember. 14 behalf of the other Plaintiffs as well. I would 14 Q. What prompted you to turn it off after ten 15 say that for identification purposes it becomes 15 minutes? 16 imperative if some of the other girls have 16 A. I think it's a stupid site. 17 alleged. as the have in their complaints that 17 Q. How about a --is it called MyFace or 18 they saw Ms. M when they arrived at the 18 MySpace? Sony. MySpace. 19 home if she's changed her physical appearance, 19 MR. KUVIN: It's not YourFace, sorry. Sid. 20 at the date that we go to trial. I believe that 20 MR. GARCIA: Trust me, you don't want to 21 any cosmetic surgery she has might be relevant 21 get that on there. 22 to the case. 22 BY MR. GARCIA: 23 MR. • I understand. I 23 Q. How about a MySpace page, have you ever 24 understand. Hold on one second. No. You can 24 had one of those? 25 go ahead and ask. 25 A. No. Page 364 Page 366 BY MR. GARCIA: 1 Q. No. what, what name did you use on the 2 Q. Okay. Have you ever had any other type of 2 Facebook page? 3 cosmetic sure that was financed by Mr. Epstein? 3 A. I don't remember. 4 MR. : Objection to the form in 4 Q. Did Jeffrey Epstein suggest that wouldn't 5 that it assumes Mr. Epstein, any knowledge of 5 be such a good idea? 6 Mr. Epstein. But if you want to ask her -- go 6 MR. : Objection to the form. 7 ahead and ask her the general question, has she 7 Standing objection. Instruct the witness not 8 ever had it done by anybody, paid by anybody. 8 to answer based on Fifth Amendment. 9 MR. GARCIA: All right. 9 THE WITNESS: At the advice of my lawyer, 10 BY MR. GARCIA: 10 I must invoke my Fifth Amendment right. 11 Q. Have you ever had any other cosmetic 11 BY MR. GARCIA: 12 surgery? 12 Q. Where were you when you set up a Facebook 13 A. No. 13 page for about ten minutes? 14 Q. What type of dental procedure did you have 14 MR. : Objection to the form. 15 done? 15 Sony. Instruct the witness not to answer. 16 A. Invisalign. 16 based on the Fifth Amendment. 17 Q. And what is that? 17 THE WITNESS: At the instruction of my 18 A. Straightens your teeth. 18 lawyer, I must invoke my Fifth Amendment right. 19 Q. Is it something that you wear? 19 BY MR. GARCIA: 20 A. Sometimes. Not all the time. 20 Q. Do you know who Max Brockman, 21 Q. You're still wearing it today? 21 B-r-o-c-k-m-a-n is? 22 A. No. 22 MR. : Instruct the witness not 23 Q. And what year was the dental process done? 23 to answer based on the Fifth Amendment. 24 A. Started two years ago. 24 THE WITNESS: At the instruction of my 25 MR. GARCIA: I'm sorry. Did you take the 25 lawyer. I must invoke my Filth Amendment right. 45 (Pages 363 to 366) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 45 of 48 EFTA_00065409 EFTA01246555 Page 367 Page 369 1 BY MR. GARCIA: 1 lawyer, I must invoke my Fifth Amendment right. 2 Q. Doyou know who is? 2 BY MR. GARCIA: 3 MR. Same instruction. 3 Q. Were you home schooled by your parents or 4 THE WITNESS: At the instruction of my 4 one of your parents, or someone else? 5 lawyer. I must invoke my Fifth Amendment right. 5 A. Myself. 6 BY MR. GARCIA: 6 Q. Do you know what the name of the program 7 Q. Do you hold any professional licenses 7 was that authorized ou to home school yourself? 8 issued by an . an state? 8 MR. : Instruct the witness not 9 • MR. Hold on a second. You can 9 to answer based on the Fifth Amendment. 10 answer. 10 THE WITNESS: On the advice of my counsel, 11 THE WITNESS: No. 11 I must invoke my Fifth Amendment right. 12 BY MR. GARCIA: 12 BY MR. GARCIA: 13 Q. Have you ever held a professional license? 13 Q. Have you ever been a licensed masseuse? 14 A. No. 14 A. No. 15 Q. Do you have any degrees? 15 Q. Have you ever taken any courses to become 16 A. No. Well -- 16 a licensed masseuse? 17 Q. Well -- I'm sorry. go ahead. 17 A. No. 18 A. College degrees or... 18 Q. Have you applied for any licenses and been 19 Q. Any type of degree. high school, college. 19 turned down for same? 20 A. I have a high school degree. 20 A. No. 21 Q. And what year did you receive that degree? 21 Q. Do you have any facts to deny that 22 A. I'm really bad with years. I can't say for 22 Mr. Epstein digitally penetrated Jane Doe No. II on 23 sure. 23 each of the about ten occasions that I listed before 24 Q. Okay. And what high school did you 24 for you? 25 receive it from? 25 MR. : Objection to the form of Page 368 Page 370 1 MR. Instruct the witness not 1 the question in that it assumes knowledge of 2 to answer based on Fifth Amendment. 2 Mr. Epstein and Ms. Doe No. II. It's a 3 THE WITNESS: On the instruction of my 3 compound question. It's ambiguous. And I 4 lawyer, I must invoke my Fifth Amendment right. 4 instruct the witness not to answer based on the 5 BY MR. GARCIA: 5 Fifth Amendment. 6 Q. Were you associated with Mr. Epstein at 6 THE WITNESS: On the instruction of my 7 8 the time that ou attended high school? MR. Objection to the form. 7 8 lawyer, I must exercise my Fifth Amendment right. 9 Standing objection. Instruct the witness not 9 BY MR. GARCIA: 10 to answer. 10 Q. Did you know that Mr. Epstein would 11 THE WITNESS: At the instruction of my 11 digitally penetrate Jane Doe No. ll prior to 12 lawyer, I must invoke my Fifth Amendment right. 12 soliciting her for massy es of Mr. Epstein? 13 BY MR. GARCIA: 13 MR. : Same objection as stated 14 Q. Was it a 'ublic or . 'vale high school? 14 to the previous question, the standing 15 MR. You can answer that. 15 objection to form and instruct the witness not 16 THE WITNESS: 16 to answer. 17 BY MR. GARCIA: 17 MR. GARCIA: Did you -- 18 Q. But you still got a degree from some 18 MR. : Hold on. 19 entity; is that correct? 19 THE WITNESS: On the instruction of my 20 A. Yes. 20 lawyer, I must invoke my Fifth Amendment right. 21 Q. What was the entity that issued you a 21 BY MR. GARCIA: 22 degree? 22 Q. Did you discuss what type of activities 23 MR. Instruct the witness not 23 Mr. Epstein would engage in with Jane Doe No. II 24 to answer based on the Fifth Amendment. 24 prior to soliciting her for massages and sexual play 25 THE WITNESS: On the instruction of my 25 with Mr. Epstein? 46 (Pages 367 to 370) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 46 of 48 EFTA_00065410 EFTA01246556 Page 371 Page 373 1 MR. Object to the form of the 1 lawyer, I invoke my Fifth Amendment right. 2 question as ambiguous and standing objection as 2 BY MR. GARCIA: 3 well. Instruct the witness not to answer. 3 Q. Do ou own an automobile? 4 THE WITNESS: On the instruction of my 4 MR. Same instruction. 5 lawyer, I must invoke my Fifth Amendment right. 5 THE WITNESS: On the instruction of my 6 BY MR. GARCIA: 6 lawyer, I invoke my Fifth Amendment right. 7 Q. Did Mr. Epstein ever tell you that he had 7 BY MR. GARCIA: 8 9 sought out psychological or psychiatric treatment for any reason? 9 8 Q. Who aid for our automobile? MR. Same instruction. 10 MR. Instruct the witness not 10 THE WITNESS: On the instruction of my 11 to answer based on the standing objection. 11 lawyer, I invoke my Fifth Amendment. 12 Objection to form. 12 BY MR. GARCIA: 13 THE WITNESS: On the instruction of my 13 Q. Has Jeffrey Epstein ever purchased an 14 15 lawyer, I must invoke my Fifth Amendment right. BY MR. GARCIA: 14 15 automobile for ou? MR. Objection to the form 16 •. 16 based upon the standing objection and instruct 17 the witness not to answer. 18 THE WITNESS: On the instruction of my 19 MR. Objection to the form, the 19 lawyer, I invoke my Fifth Amendment right. 20 standing objection. Instruct the witness not 20 BY MR. GARCIA: 21 to answer. 21 Q. What limousine service do you use in New 22 THE WITNESS: At the instruction of my 22 York when ou move from place to place? 23 lawyer, I must invoke my Fifth Amendment right. 23 MR. Same instruction. 24 BY MR. GARCIA: 24 THE WITNESS: On the instruction of my 25 Q. Do you own a home or some son of a condo 25 lawyer, I invoke my Fifth Amendment right. Page 372 Page 374 1 or anything like that? 1 BY MR. GARCIA: 2 3 MR. Instructthe witness not to answer based on the Fifth Amendment 2 3 Q. Who a s for our limousine service? MR. : Same instruction. 4 privilege. 4 THE WITNESS: On the instruction of my 5 THE WITNESS: On the instruction of my 5 lawyer, I invoke my Fifth Amendment right. 6 lawyer, I must invoke my Fifth Amendment right. 6 BY MR. GARCIA: 7 BY MR. GARCIA: 7 Q. How do you spend your typical day in New 8 Q. Do ou a rent to any landlord? 8 York? 9 MR. Same instruction. 9 MR. : Instruct the witness not 10 THE WITNESS: On the instruction of my 10 to answer based on the Fifth Amendment. Also 11 lawyer, I must invoke my Fifth Amendment right. 11 objection to the form as to what's a typical 12 BY MR. GARCIA: 12 day. 13 Q. The lace where ou live, who owns it? 13 BY MR. GARCIA: 14 MR. : Same instruction. 14 Q. Monday through Friday, typical work hours. 15 THE WITNESS: At the instruction of my 15 say 9:00 to 5:00, what do you typically do Monday 16 17 lawyer, I must invoke my Fifth Amendment right. BY MR. GARCIA: 16 17 through Frida . 9:00 to 5:00 p.m.? MR. : Instruct the witness not 18 Q. Do you exit a building in New York where 18 to answer based on the Fifth Amendment. 19 you exit from a different buildings parking garage: 19 THE WITNESS: At the instruction of my 20 in other words, do you exit -- strike that. 20 lawyer, I must invoke my Fifth Amendment right. 21 Do you use a different parking garage to 21 BY MR. GARCIA: 22 exit the, from the buildin where you live? 22 Q. What is Financial Trust Company? 23 MR. Instruct the witness not 23 MR. : Instruct the witness not 24 to answer based on the Fifth Amendment. 24 to answer based on the Fifth Amendment. 25 THE WITNESS: On the instruction of my 25 THE WITNESS: At the instruction of my 47 (Pages 371 to 37 4) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 47 of 48 EFTA_00065411 EFTA01246557 Page 375 1 lawyer, I must invoke my Fifth Amendment right. 2 MR. GARCIA: I'm just asking what it is. 3 MR. Understood. 4 BY MR. GARCIA: 5 Q. Well, let me not waste any time. Do you 6 know what it is, es or no? 7 MR. Instruct the witness not 8 to answer based on the Fifth Amendment. 9 THE WITNESS: At the instruction of my 10 lawyer, I invoke my Fifth Amendment right. 11 BY MR. GARCIA: 12 Q. Has Jeffrey Epstein ever told you that he 13 is a government witness, otherwise known as a 14 snitch, or confidential informant? 15 MR. Objection to the form in 16 that it assumes knowledge of Mr. Epstein. 17 Instruct the witness not to answer. 18 THE WITNESS: On the instruction of my 19 lawyer, I invoke my Fifth Amendment right. 20 BY MR. GARCIA: 21 Q. Has he ever told you that he is involved 22 in a case involving, providing information 23 concerning mone laundering? 24 MR. • Same objection and same 25 instruction. Page 376 1 THE WITNESS: At the instruction of my 2 lawyer, I must invoke my Fifth Amendment right. 3 MR. GARCIA: That's all I have. Thank 4 you. 5 MR. : Great. Should we take a 6 break? I know you need to change the tape as 7 well. 8 THE VIDEOGRAPHER: Yes. We're now going 9 off the record. It is 5:18 p.m. 10 (A brief recess was held.) 11 • * * * • 12 13 14 15 16 17 18 19 20 21 22 23 24 25 IIIIII-- 4 8 (Pages 375 to 37 6) PROSE COURT REPORTING AGENCY, INC. CONFIDENTIAL 3501.125-026 Page 48 of 48 EFTA_00065412 EFTA01246558