UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. / Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-8-591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF TAKEN ON BEHALF OF THE PLAINTIFF DATE: April 13, 2010 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 1 of 38 EFTA_00067613 EFTA01246832 2 4 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 April 13,2010 INDEX WITNESS DIRECT CROSS REDIRECT RECROSS BY MR. EDWARDS 5 98 BY MR. HOROWITZ 65 BY MR. LANGINO 77 BY MS. EZELL 81 EXHIBITS PLAINTIFF'S FOR IDENTIFICATION I Message dated August 21, 2005. PAGE 45 APPEARANCES (CONTINUED) 2 LEOPOLD-KUVIN wilwiIfs 3 4 S 6 7 8 10 BY: ADAM J. LANGINO, ESQ. PODIRMST, ORSECK AllOmtp (calm Does I sad 3 Hu& Building. Suite )38 BY: KATHERINE W. EZELL, ESQ. 11 12 BURMAN. CROTON. LUTTIER & COLEMAN, III' pstein 13 14 BY: DAVID YAREMA, ESQ. 15 ROBERT CRITION. ESQ. 16 ATTERBURY, GOLDBERGER & WEISS 17 I for Defendants 18 t9 20 21 22 23 24 25 BY: JACK A. GOLDBERGER. ESQ. ALSO PRESENT: JESSICA CADWEU. JOE ROVNER. Yid:n(40W (US. Legal) 3 i m i. to deposition of in the above-entitled and numbered 3 cause, was taken before me, TERRI BECKER, a 4 Registered Professional Reporter and Notary 5 Public for the State of Florida at Large, at 444 6 West Railroad Avenue, in the City of West Palm 7 Beach. Palm Beach County, in the State of 8 Florida, beginning at the hour of 10:00 o'clock 9 a.m., pursuant to the Notice in said cause far 10 the taking of said deposition which is annexed to 11 the court file herein, on behalf of the PLAINTIFF 12 in the above-entitled action pending in the 13 above-named coon. 14 The appearances at said lime and place 15 were as follows: 16 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL 17 legs Plaintiffs Jane Does, 18 20 BY: BRADLEY J. EDWARDS, ESQ. 21 MERMELSTEIN & HOROWITZ P.A. 22 Attorneys for Plaintiffs Jane Does, 23 25 BY: ADAM D. HOROWITZ. ESQ. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 THEREUPON. being by Terri Becker first duly sworn to tell the whole truth, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MR. EDWARDS: 8 Q Can you tell us your name. 9 A 0 Q What Is your dale of birth? 1 A Q What Is your Social Security number? A Under advice of my counsel, 1 invoke my privileges under the Fifth and Sixth Amendments to the United States Constitution and respectfully decline to answer the question. Q Where were you born? A I'm sorry, though I would like to answer your question, l must invoke my Fifth and Sixth Amendment privileges and refuse to answer your questions. Q What is your current address? MR. GOLDBERGER: There is going to be a continued, obviously, you anticipate I'm sure, continued invocation of Fifth U.S. Legal Support (561) 835-0220 CONFIDENTIAL 2 (Pages 2 to 5) 3501.144-028 Page 2 of 38 EFTA 00067614 EFTA01246833 6 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Amendment privileges. If it is okay with all counsel, to shorten things, I'll simply have the witness say -Filth,. if that satisfies everyone's interest. MR. EDWARDS: That is fine with me. MR. GOLDBERGER: Okay, with that Cathy? MS. EZELL: Yes. MR. HOROWITZ: Yes. Q I'll reask the question, what's your current address? A Fifth. Q Are you currently living at 358 El SHIM Way with a man named Jeffrey Epstein? A The Fifth. Q Are you also familiar with an address in New York, 301 East 66th Street? A The Fifth. Q When Mr. Epstein was incarcerated In Jail, you went to visit him on numerous occasions; is that correct? MR. YAREMA: Objection. A The Fifth. Q When you went to visit him you indicated to jail personnel your address was 301 East 66th Street, apartment 8-D in New York City, New York; 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A The Fifth. Q Do you know a lady by the name of Maritsa Vazques? A The Fifth. Q Is this somebody who helped to falsify a visa for you? MR. YAREMA: Object to the form. A The Fifth. Q Do you know Evelyn Velasaques? A The Fifth. Q Were you ever a working model hat ilw United States? A The Fifth. Q Can you tell us youi parents' names? A The Fifth. Q How is it that you have supported yourself financially, since you have been in this country? MR. YAREMA: Object to the form. A The Fifth. Q Have you supported yourself financially? A The Fifth. Q What Is the last grade you completed in school? A The Fifth, I take the Fifth Amendment. 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Is that correct? MR. YAREMA: Objection. A Fifth. Q Isn't it true when Mr. Epstein was in jail, you visited him on more than 50 occasions? MR. YAREMA: Form objection. Q True? A The Fifth. Q How long have you been in the United States, A The Fifth. Q Who brought you to the United States? MR. YAREMA: Form objection. A The Fifth. Q What is your current status in this country? A The Fifth. MR. YAREMA: Form objection. MR. GOLDBERGER: Let me take a half a second. (Witness and her counsel confer.) Q Are you a U.S. citizen? A The Filth. Q What type of visa are you here on? MR. YAREMA: Form objection. 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Are you in school now? A The Fifth. Q Have you ever attended any school in the United States? A The Fifth. Q Have you ever been employed since residing in the United States? A The Fifth. Q Is Jeffrey Epstein your sole means of financial support today? MR. YAREMA: Object to the form. A The Fifth. Q Since coming to this country, hasn't Jeffrey Epstein always been your sole means of financial support? MR. YAREMA: Object to the form. A The Fifth. Q How much does Jeffrey Epstein pay you today? MR. YAREMA: Object to the form. A The Fifth. Q What does every Epstein pay you for? MR. YAREMA: Object to the form. A The Fifth. Q Does he pay you specifically to be his 9 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3 (Pages 6 to 9) 3501.144-028 Page 3 of 38 EFTA_00067615 EFTA01246834 10 12 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 sex slave? 2 MR. YAREMA: Object to the form. 3 A The Fifth. 4 Q Are you aware that the reports about you 5 Indicate that you were brought to the United States by Jeffrey Epstein when you were roughly 13 or 14 years old to be his lesbian sex slave? MR. YAREMA: Object to the form. A Thc Fifth. Q Is that true? MR, YAREMA: Object to the lomt A The Fifth. Q Have you performed any services for Jeffrey Epstein aside front being his sex slave? MR. YAREMA: Object to the form. A The Fifth. Q What is your sexual orientation? MR. YAREMA: Object to the Iona. MR. GOLDBERGER: I'm going to instruct the witness not to answer that question. It serves no purpose other than to harass or intimidate her, so in addition to Fifth Amendment privileges, I'm objecting on privacy grounds. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Epstein's sex slaves? MR. YAREMA: Object to the Ism A Fifth. Q What does it mean to be JelTrey Epstein's sex slave? MR. YAREMA: Object to the font. A Fifth. Q Are you aware that Jeffrey Epstein reads books on how to be a proper master to his sex slave? MR. YAREMA: Object to the Iona. A Fifth. Q What has Jeffrey Epstein done to train you to be his sex slave? MR. YAREMA: Object to the form. A Fifth. Q What do your parents think about you being Jeffrey Epstein's sex slave? MR. YAREMA: Object to the form. A Fifth. Q When did you first learn that Jeffrey Epstein had a sexual obsession for underage minor females? MR. YAREMA: Object to the form. A Fifth. 11 1 A I take the Fifth. Q I represent a lady named, a young female 3 named S ; you know who that is, right? 4 MIL YAREMA: Object to the form. 5 A The Fifth. 6 Q Jeffrey Epstein made you have sex with 7 didn't he? 8 MR: YAREMA: Object to the form. 9 A The Fifth. 10 Q You did, In fact, engage in sexual 11 activity with M. when she was only 16 years 12 old; isn't that true? 13 MR. YAREMA: Object to the form. 14 A The Fifth. 15 Q Back to my original question: And I'll 16 ask you this way: Do you consider yourself 17 heterosexual, bl-sexual, or can you answer that 18 question? 19 MR. YAREMA: Object to the form. 20 MR. GOLDBERGER: Same objection. Do not 21 answer the question. 22 A Fifth. 23 Q How did you meet Jeffrey Epstein? 24 A Fifth. 25 Q When did you become one of Jeffrey 13 1 Q How many times has Jeffrey Epstein made 2 you have sex with underage minor females? 3 MR. YAREMA: Object to the Porn. 4 A Filth. 5 Q Do you enjoy sex with underage minor 6 females? 7 MR. YAREMA: Object to the fort. 8 A Fifth. 9 Q What is the youngest child that Jeffrey 10 Epstein has forced you to have sex with? 11 MR. YAREMA: Object to the fonts. 12 A Fifth. 13 Q Does Jeffrey Epstein today still make 14 you have sex with underage minor females? 15 MR. YAREMA: Object to the form. 16 A Fifth. 17 Q How many underage minor females has 18 Jeffrey Epstein made you have sex with, since you 19 were over the age of 18? 20 MR. YAREMA: Object to the fonn. 21 A Thc Fifth. 22 Q Prior to turning 18, is it true that 23 Jeffrey Epstein made you have sex with many other 24 children in kid-type orgies? 25 MR. YAREMA: Object to the fonn. U.S. Legal Support (561) 835-0220 CONFIDENTIAL 4 (Pages 10 to 1 3) 3501.144-028 Page 4 of 38 EFTA_00067616 EFTA01246835 14 16 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Filth. Q Has Jeffrey Epstein also made you perform sexually on his friends? MR. YAREMA: Object to the form. A Fifth. Q Do you know David Copperfield? MR. YAREMA: Object to the form. A Fifth. Q Have you ever been made to perform sexually on David Copperfieki? MR. YAIIEMA: Object to the form. A Fifth. Q Do you know Prince Andrew? A Fifth. Q Have you ever been made to perform sexually on Prince Andrew? MR. YAREMA: Object to the form. A Fifth. Q When was the first time that you knew Jeffrey Epstein molested underage girls? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein molest you when you were underage? MR. YAREMA: Object to the form. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Fifth. Q Have you read the nonprosecution agreement between the government and Jeffrey Epstein? A Fifth. Q Are you aware that inside that document you are labeled as a co-conspirator of his crimes against children? MR. YAREMA: Object to the form. A Fifth. Q Isn't it true that your role was to lure or procure underage minor females to Jeffrey Epstein for him to molest, correct? MR. YAREMA: Object to the fonn. A Fifth. Q You also scheduled appointments for Jeffrey Epstein, so there would be designated times for Jeffrey Epstein to molest underage minor females, correct? MR. YAREMA: Object to the fonn. A The Fifth. Q As well, you participated in various sex acts with underage minor females, thus molesting them yourself; is that correct? MR. YAREMA: Object to the font 15 1 A Fifth. 2 Q I'm assuming you understand why you're 3 here today, correct? 4 MR. YAREMA: Object to the fonn. S A The Fifth. 6 Q For allegations related to Jeffrey 7 Epstein interacting sexually with numerous underage minor females; that's something you know, right? MR. YAREMA: Object to the form. A The Fifth. Q That's something In addition to the civil lawsuits, there were criminal cases involving the same conduct, correct? MR. YAREMA: Object to the feta A Fifth. Q You were a part of that CaMillai Investigation, in fact, you were a co-conspirator of Jeffrey Epstein's; is that right? MR. YAREMA: Object to the form. A Fifth. Q What crimes did you conspire to commit with Jeffrey Epstein against underage minor females? MR. YAREMA: Object to the tom. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17 A Fifth. Q Do you understand that Jeffrey Epstein's interaction with underage minor females is Illegal? Do you understand that? MR. YAREMA: Object to the form. A The Fifth. Q Do you understand that the Lewd and Lascivious Molestation Statute In Florida indicates a person who Intentionally touches in a lewd or lascivious manner, the breasts, genital area or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or entices a person under 16 years of age, to so touch the perpetrator, commits lewd or lascivious molestation? Are you aware of that statute? A Fifth. Q That is a statute that you know Jeffrey Epstein to have violated; Is that true? MR. YAREMA: Object to the form. A The Fifth. Q That's a statute that you yourself have violated; is that true? MR. YAREMA: Object to the form. A The Fifth. Q You've observed Jeffrey Epstein violate U.S. Legal Support (561) 835-0220 CONFIDENTIAL 5 (Pages 14 to 17) 3501.144-028 Page 5 of 38 EFTA_00067617 EFTA01246836 18 20 2 3 4 5 6 8 9 t0 12 13 14 15 16 17 19 19 20 21 22 23 24 25 that statute on many underage minor females, true? MR. YAREMA: Object to the font A The Filth. Q (lave you ever discussed with Jeffrey Epstein that the fact that he is a child molester? MR. YAREMA: Object to the form. A Filth. Q Have you asked Jeffrey Epstein why he has made you interact with underage minor females in a sexual manner? MR. YAREMA: Object to the fon% A Filth. Q During the litigation of these civil cases, has Jeffrey Epstein indicated to you an intent to continue to molest children? MR. YAREMA: Object to the loon. A Fifth. Q Is it your intent to continue to commit sex crimes against minors? MR. YAREMA: Object to the form. A Fifth. Q In addition to your being named as a co-conspirator of Jeffrey Epstein regarding his 1 2 3 4 5 6 7 a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 co-conspirator in the non-prosecution agreement related to Jeffrey Epstein's crimes against minors? MR. YAREMA: Object to the form. A Fifth. Q Do you know or A Fifth. Q These are all people who also participated in Jeffrey Epstein's scheme to lure underage females to him for sex; is that true? MR. YAREMA: Object to the form. A Fifth. Q You and these other co-conspirators played various roles to make sure Jeffrey Epstein was able to engage In sexual contact or conduct, with underage minor females on an everyday basis; is that true? MR. YAREMA: Object to the form. A Fifth. Q Since the time you first met Jeffrey Epstein, has his appetite for underage minor females always been the same? MR. YAREMA: Object to the form. A Fifth. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 19 crimes against minors, there is also a person named listed as a co-conspirator. Do you know A Fifth. Q This Is somebody who lives with you and Jeffrey Epstein; Is that true? MR. YAREMA: Object to the four. A Filth. Q And is somebody who you know to be girlfriend; is that true? MR. YAREMA: Object to the form. A Fifth. Q She's spoken with about this case on numerous occasions; is that true? MR. YAREMA: Object to the form. A Fifth. conversations with= and your observations of them, you believe would implicate you in a crime and that's why you're able to take the Fifth as to that question? MR. YAREMA: Object to the fonn. A Fifth. Q Who is Lesley Groff, also listed as a 1 2 3 4 6 7 9 10 11 12 13 14 15 16 17 19 20 21 22 23 24 25 21 Q By that I mean, have you observed Jeffrey Epstein to interact sexually with underage minor females literally on a doily basis? MR. YAREMA: Object to the form A Fifth. Q Wasn't it one of your specific job duties to make sure that he had different underage minor females to molest on a daily basis? MR. YAREMA: Object to the form. A Fifth. Q In addition to the improper sexual contact between Jeffrey Epstein and underage minor females at the West Palm Beach house, you have observed similar improper and illegal contact by Jeffrey Epstein in his New York mansion, as well, correct? MR. YAREMA: Object to the form. A Fifth. Q In fact, he operates a very similar scheme up there, in that he schedules these appointments with underage minor females, under the guise that it is going to be a massage; is that correct? U.S. Legal Support (561) 835 - 0220 CONFIDENTIAL 6 (Pages 18 to 21) 3501.144-028 Page 6 of 38 EFTA_00067618 EFTA01246837 22 24 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 MR. YAREMA: Object to the loon? 2 A Fifth. 3 Q When he is in New York, he has contact 4 with underage minor females for the purposes of 5 sexually molesting than as well; is that 6 correct? 7 MR. YAREMA: Object to the fonn. 8 A Fifth. Q When he is in his ranch in New Mexico, similarly, Jeffrey Epstein is engaging in sex with underage minor females from that local area as well, and that's something you've observed? MR. YAREMA: Object to the fonn. A Fifth. Q On his island, particularly, he has flown underage minor females to the island for underage kid-type orgies; is that true? MR. YAREMA: Object to the form. A Fifth. Q You're shaking your head indicating, at least to me, indicating that you may not agree with what I'm saying, and I would love to give you the chance to explain it to us. MR. GOLDBERGER: I appreciate that, but don't — 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 when Jeffrey Epstein commits these crimes against children? MR. YAREMA: Object to the font A Fifth. Q Is there any way for you to escape being his sex slave? MR. YAREMA: Object to the form. A Fifth. Q Have you ever wanted to cooperate with the authorities, so that you could escape being his sex slave? MR. YAREMA: Object to the fonn A Fifth. Q Do you represent to others that you are his girlfriend or his sex slave, or sonic other designation? MR. YAREMA: Object to the form. A Fifth. Q Isn't it true that you recently represented to the Probation Officer that you were his live-In girlfriend? MR. YAREMA: Object to the form. A Fifth. Q When Probation calls the house, are you told to tell Probation that he is in the swimming 23 1 MR. EDWARDS: Read too much into it? 2 MR. GOLDBERGER: Exactly. Don't go 3 there. Just ask the questions and we will 4 move right along. 5 MR. EDWARDS: I agree, Jack, I just know 6 if this is played for a jury, I don't want 7 the jury to interpret her shaking ha head 8 as a "No." and then her pleading the Fifth. 9 MR. GOLDBERGER: I appreciate that. 10 Don't take anything as to any head movements 11 or any body movements at all. Just ask the 12 questions and we will let the video speak 13 for itself. 14 Q How many of these — you know what an 15 orgy Is, don't you? 16 A Fifth. 17 Q And how many of these orgies, as I'm 18 calling them, where there are numerous underage 19 minors having sex with each other and with 20 Jeffrey Epstein, have you observed on Jeffrey 21 Epstein's island? 22 MR. YAREMA: Object to the form. 23 A Fifth. 24 Q Is part of your role as Jeffrey 25 Epstein's sex stave, to not tell the authorities 1 2 3 4 S 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 25 pool or doing some other activity that would not allow him to come to the telephone? MR. YAREMA: Object to the fonn. A Fifth. Q Isn't It true you're under strict orders to tell Probation that? MR. YAREMA: Object to the fonn. A Filth. Q Isn't it true you've heard Jeffrey Epstein tell you on numerous occasions, regarding the age of the girls that he wants to his house, for the purposes of sexually molesting, the phrase he uses is "the younger the better," true? MR. YAREMA: Object to the form. A Fifth. Q I asked you earlier about M. out of turn as a result of an objection related to your sexual orientation, but I'll talk specifically about.. right now. You know who that Is, right? MR. YAREMA: Object to the form. A Fifth. Q That is somebody you observed Jeffrey Epstein to call for the purposes of getting her U.S. Legal Support (561) 835-0220 CONFIDENTIAL 7 Pages 22 to 25) 3501.144-028 Page 7 of 38 EFTA_00067619 EFTA01246838 26 to his house to sexually molest; Is that right? 1 28 minor females? 2 MIL YAREMA: Object to the font 2 MR. YAREMA: Object to the form. 3 A Fifth. 3 A Fifth. 4 Q The first time she went to Jeffrey 4 Q You have received oral sex front underage 5 Epstein's house was in 2002 when she was only 14 5 minor females? 6 years old; Is that true? 6 MR. YAREM A: Object to the fonn. 7 MR. YAREMA: Object to the font,. 7 A Fifth. A Fifth. 8 Q All of these sexual acts with minor 9 Q In fact in 2002 you were only 18 years 9 females involving you happened in the presence of 10 old or so yourself; is that right? 10 Jeffrey Epstein? 11 A Fifth. 11 MR. YAREM A: Object to the bona. 12 Q And M. is somebody you observed at 12 A Fifth. 13 Jeffrey Epstein's house on more than 100 13 Q During your interaction with underage 14 occasions between 2002 and 2005, a time period 14 minor females in a sexual manner, isn't it true 15 between 14 and 17 years of age for her; is that 15 that Jeffrey Epstein would participate in the 16 right? 16 sexual acts and the act would be over upon 17 MR. YAREMA: Object to the font,. 17 Jeffrey Epstein ejaculating, correct? 18 A Fifth. 18 MR. YAREMA: Object to the font,. 19 Q And each time M. was summoned to 19 A Filth. 20 Jeffrey Epstein's house, it was for the purposes 20 Q Did Jeffrey Epstein tell you, that when 21 of Jeffrey Epstein sexually molesting her, 21 M. was an underage minor female, he forced her 22 correct? 22 to give hint oral sex? 23 MR. YAREMA: Object to the form. 23 MR. YAREMA: Object to the font 24 A Fifth. 24 A Fifth. 25 Q If it was not Jeffrey Epstein personally 25 Q Do you remember coming over, • 27 29 1 calling ., you observed to call 1 young girl, with braces on, and going up Into 2 S for the purposes of her coming over and 2 Jeffrey Epstein's bedroom on numerous occasions 3 pleasing Jeffrey Epstein sexually, correct? 3 to be sexually molested? 4 MR. YAREMA: Object to the form. 4 MR. YAREMA: Object to the tons 5 A Fifth. 5 A Fifth. 6 Q And do you remember the instance where 6 Q Do you know when it was that Jeffrey 7 Jeffrey Epstein instructed you to lay down naked and engage in a threesome with M. and Jeffrey 7 Epstein developed his plan or scheme to gain access to hundreds of underage minor females for 9 Epstein? 9 the purposes of his sexual gratification? 10 MR. YAREMA: Object to the fonn. 10 MR. YAREMA: Object to the font 11 A Fifth. 11 A Fifth. 12 Q Do you remember that that during that 12 Q Were you a part of the planning of that 13 threesome, Jeffrey Epstein demanded M. to 3 scheme of Jeffrey Epstein's to gain access to 14 straddle you and otherwise engage sexually with 4 underage minor females? 15 you while Jeffrey Epstein was using vibrators 5 MR. YAREMA: Object to the form 16 and/or dildos on you? 6 A Fifth. 17 MR. YAREMA: Object to the fonts 7 Q Do you know Ohislaine Maxwell? 18 A Fifth. A Fifth. 19 Q In addition to your sexual interactions 9 Q Is that somebody who helped Jeffrey 20 with M., isn't it true that you have used 0 Epstein to devise the scheme to allow hint access 21 strap-on dildos and vibrators on other underage 1 to various and a variety of underage minor 22 minors at Jeffrey Epstein's direction? 2 females? 23 MR. YAREMA: Object to the form. 3 MR. YAREMA: Object to the 24 A Fifth. 4 A Fifth. 25 Q You have given oral sex to underage 5 Q Is somebody that was also B (Pages 26 to 29) U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 8 of 38 EFTA_00067620 EFTA01246839 30 32 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Involved In the planning of this scheme to gain access to underage minor females? MR. YAREMA: Object to the fonn. A Filth. Q When Is the first time that you observed Jeffrey Epstein's method of enticing or inducing underage minor females into sexual acts with him inside his bedroom? MR. YAREMA: Object to the form. A Fifth. Q Isn't it trite that after an underage minor female was brought to Jeffrey Epstein's house, typically or or yourself would lead that underage minor female to Jeffrey Epstein's bedroom and leave them atone do the room; is that true? MR. YAREMA: Object to the fonn. A Fifth. Q Then Jeffrey Epstein would appear either naked or wearing a towel; is that true? MR. YAREMA: Object to the form. A Fifth. Q This Is his habit or method of operation, every single time, and that's something that he has told you about his sexual 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 16 19 20 21 22 23 24 25 sex toys on you, correct? A Fifth. Q And he has instructed you to use sex toys and vibrators on other underage minor females, correct? MR. YAREMA: Object to the form. A Fifth. Q You have observed Jeffrey Epstein digitally penetrate the vagina of underage minor females, Including •., correct? MR. YAREMA: Object to the fonn. A Fifth. Q As pan of his plait to avoid detection by law enforcement, you have observed Jeffrey Epstein to pay these underage minor females to be quiet, correct? MR. YAREMA: Object to the form. A Fifth. Q And this is something that he has told you he does, for the purposes of grooming these underage minor females, and avoiding law enforcement detection, correct? MR. YAREMA: Object to the form. A Fifth. Q Jeffrey Epstein has talked to you about 31 1 interaction with underage minors; is that true? 2 MR. YAREMA: Object to the form. 3 A Fifth. 4 Q And he would direct or demand or 5 Instruct the underage minor female to remove her 6 clothing; is that true? 7 MR. YAREMA: Object to the form. 8 A Fifth. Q Then he would perform one or more lewd or lascivious or sexual acts on the underage minor female. Is that true? MR. YAREMA: Object to the form. A Fifth. Q And you have observed Jeffrey Epstein engage in sexual interaction with underage minor females on hundreds and hundreds of occasions, correct? MR. YAREMA: Object to the font A Fifth. Q And you have observed Jeffrey Epstein using vibrators and sexual toys on underage minors, true? MR. YAREMA: Object to the fonn. A Fifth. Q In fact, he has also used vibrators and 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 33 the psychology of brainwashing or grooming underage minor females to perform for him sexually, hasn't he? MR. YAREMA: Object to the fonn. A Fifth. Q And has also spoken with you about the methodology behind gaining access to and grooming underage minor females for sex? MR. YAREMA: Object to form. A Fifth. Q Isn't it true that Ghislaine Maxwell and yourself and had access to a master Ilst of underage minor remain names and phone numbers so that they could be called? MR. GOLDBERGER: Time out. Are you talking to me, counsel? MR. HOROWITZ: Nodding my head, back at you. You were nodding at me. MR. GOLDBERGER: I wasn't nodding at you. I'm not talking to you, I'm not communicating with you.. I don't know what you think we arc doing here. You said "It is true," and I have no idea what you are talking about. Don't inlet-nn the deposition, okay? U.S. Legal Support (561) 835-0220 CONFIDENTIAL 9 (Pages 30 to 33) 3501.144-028 Page 9 of 38 EFTA_00067621 EFTA01246840 1 2 3 4 5 34 MIL HOROWITZ: I think you interrupted. MR. GOI.DBERGER: I didn't do a thing -- MR. EDWARDS: I don't know what's happened here. It has deteriorated here for no reason whatsoever and has nothing to do 1 2 3 4 5 36 A Fifth. Q In addition to that system, isn't it true that Jeffrey Epstein traMcs underage minor females through a modeling agency? MR. YAREMA: Object to the form. 6 with mc or the witness. 6 A Fifth. 7 MR. GOLDBERGER: You're 100 percent 7 Q Is a modeling agency that he is Involved 8 correct 0 in with Jean Luc Brunel; you know who that is 9 MR. EDWARDS: Can we go back to it. 9 right? 10 MR. GOLDBERGER: Absolutely. 10 MR. YAREMA: Object to the form. 11 MR. EDWARDS: Perfect. 11 A Fifth. 12 The silent fight disrupted mc. I lost 12 Q Are you familiar with MC-2 or MC-Squared 13 where I am now. 13 Modeling Agency? 14 MR GOLDBERGER: Sony. 14 A Fifth. 15 MR EDWARDS: Can you read it back. 15 Q You know Jean Luc Brunel, right? 16 THE COURT REPORTER: Certainly. 16 MR. YAREMA: Object to the fonn. 17 (The record was read.) 17 A Fifth. 18 MR. EDWARDS: I'll rephrase the 18 Q Is Jean Luc Brunel somebody that you 19 question. 19 have been made to perform on sexually? 20 Q Isn't it true that yourself, Ghislaine 20 MR. YAREMA: Object to the form. 21 Maxwell and had access to a master 21 A Fifth. 22 of list of underage minor females names and phone 22 Q Jean Luc Brunel is somebody that you 23 numbers so they could be called for the purpose 23 know to also be a child molester, true? 24 of coming to Jeffrey Epstein's house to be 24 MR. YAREMA: Object to the fonn. 25 sexually molested? 25 A Filth. 35 37 1 MR. YAREMA: Object to the form. 1 Q Thls is somebody who for years the 2 A Fifth. 2 public has known of Jean Luc Brunel as a child 3 Q How many underage minor females are on 3 molester, true? 4 that master list? 4 MR. YAREMA: Object to the form S MR. YAREMA: Object to the form. 5 A Fifth. 6 A Fifth. 6 Q In fact, that is the only thing Jeffrey 7 Q Are there photographs of these underage 7 Epstein and Jean Luc Brunel have in common, is 8 minor females on that master list? 8 their obsession for underage minor females, 9 MR. YAREMA: Object to the form. 9 correct? 10 A Fifth. 10 MR. YAREMA: Object to the form. 11 Q Is that master list saved on a computer 11 A Fifth. 12 system, as has been testified to in the past? 12 Q And the modeling agency Is but one other 13 MR. YAREMA: Object to the form. 13 mechanism used by Jeffrey Epstein to gain access 14 A Fifth. 14 to underage minor females for sex, true? 15 Q Has Jeffrey Epstein talked to you about 15 MR. YAREMA: Object to the form. 16 the success of his scheme to procure underage 16 A Fifth. 17 minor females? 17 Q I read you the statute earlier on Lewd 18 MR. YAREMA: Object to the form. 18 and Lascivious Molestation, Chapter 800.04, and 19 A Fifth. 19 that's something that you have witnessed Jeffrey 20 Q By that, I mean, the method where he 20 Epstein violate on hundreds of occasions, 21 molests an underage minor female, then offers 21 correct? 22 them additional money if they will bring him 22 MR. YAREMA: Object to the form. 23 other underage minor females to molest; are you 23 A Fifth. 24 familiar with that system? 24 Q And something that you have witnessed 25 MR. YAREMA: Object to the forum 25 Jeffrey Epstein specifically violate, against 10 (Pages 34 to 37) U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 10 of 38 EFTA_00067622 EFTA01246841 38 40 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 M., true? MR. YAREMA: Object to the font. A Filth. Q Also a statute you have witnessed Jeffrey Epstein violate against then minor, MR. YAREMA: Object to the font A Fifth. Q In fact M. was somebody that Jeffrey Epstein liked or likes; Isn't that true? MR. YAREMA: Object to the fonn. A Fifth. Q In was somebody Jeffrey Epstein met when she was only 13 years old and began sexually molesting her the first day that he met her, true? MR. YAREMA: Object to the fonn. A Filth. Q was one of his main girls, as he would call them; Is that true? MR. YAREMA: Object to the form. A Fifth. Q procured for hint or brought for him to his house, over 50 girls between the ages of 12 and 15 years old; is that true? 1 2 3 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Epstein's house, and he is using all resources to try to intimidate and harass her; is that true? MR. YAREMA: Object to the form. A Fifth. Q In fact, has he talked to you about his tactic of Intimidating and harassing any victims that conic forward against hint, regarding the sexual abuse that they endured by hint? MR. YAREMA: Object to the fem. A Fifth. Q Would you agree that Jeffrey Epstein contributed to the delinquency of these various minors that he sexually abused? MR. YAREMA: Object to the form. A Q In addition to abusing them, he also encouraged them to return to hint to receive more sexual abuse and encouraged them into a life of prostitution, true? MR. YAREMA: Object to the form. A Fifth. Q How many underage minor females have you observed Jeffrey Epstein engage in sex acts with on any of his airplanes? MR. YAREMA: Object to the form. 1 2 3 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 39 MR. YAREMA: Object to the fonn. A Fifth. Q Each of these girls, aged 12 to 15, you observed come into the house, go into Jeffrey Epstein's bedroom and leave the house after being sexually molested, true? MR. YAREMA: Object to the fonn. A Fifth. Q And in addition to M. being sexually molested herself, she was enticed or coerced into bringing her friends over, to also be sexually molested, true? MR. YAREMA: Object to the Ions A Fifth. Q Has Jeffrey Epstein talked to you about an FBI statement that was given by •? A Fifth. Q He has also told you that that FBI statement that was favorable for him is completely false; isn't that true? MR. YAREMA: Object to the lona. A Fifth. Q Has he spoken to you about the fact that she is now telling the complete story and accurate account as to what happened at Jeffrey 1 2 3 4 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 41 A Fifth. Q Have you engaged in sexual acts with any underage minor females on Jeffrey Epstein's airplanes? MR. YAREMA: Object to the form. A Fifth. Q How many times has Jeffrey Epstein talked to you about the reasons why he sexually abuses minors? MR. YAREMA: Object to the form. A Fifth. Q Didn't he tell you that it is his intent to harm these minors in hopes of gaining psychological advantage over them? MR. YAREMA: Object to the form. A Fifth. Q Are you aware that Jeffrey Epstein pled guilty to two felonies related to his interaction with minors? MR. YAREMA: Object to the form. A Fifth. Q And as a result he was incarcerated, and as we spoke about earlier, you visited hint in jail on more than 50 occasions, correct? MR. YAREMA: Object to the loan. U.S. Legal Support (561) 835-0220 CONFIDENTIAL 11 (Pages 38 to 41) 3501.144-028 Page 11 of 38 EFTA_00067623 EFTA01246842 42 44 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 5 6 7 a 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Fifth. Q Aren't your observations with Jeffrey Epstein's interactions with wouldn't you agree he coerced her into a life of prostitution? MR. YAREMA: Object to the loan. A Fifth. Q And based on your observations of Jeffrey Epstein's interactions with M., wouldn't you agree that Jeffrey Epstein coerced her Into a life of prostitution? MR. YAREMA: Object to the form. A Fifth. Q And with respect to Jane Doe and M. and M., wouldn't you agree that Jeffrey Epstein forced these girls to be a prostitute for him? MR. YAREMA: Object to the form. A Fifth. Q Would you agree that Jeffrey Epstein's actions against M., S and Jane Doe, were intentional, deliberate and reckless? MR. YAREMA: Object to the form. A Fifth. Q Would you agree that that intentional, deliberate and reckless conduct by Jeffrey Epstein against •., `and Jane Doe was 1 Q Do you profit from sex trafficking of 2 children? 3 MR. YAREMA: Object to the form. 4 A Fifth. 5 Q Do you know Sergio Cordaro? 6 A Fifth. 7 Q Do you know Mike Sank*? 8 A Fifth. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Would you consider Jeffrey Epstein's criminal enterprise that is designed to molest underage minor females, to be organized? MR. YAREMA: Object to the form. A Fifth. Q is your role in that criminal arrangement to molest underage minor females, to help organize? MR. YAREMA: Object to the form. A Fifth. Q As part of that organization, Isn't it true that you, as well as various staff members, took nietleulous messages regarding appointments and scheduling underage minor females to come over to be sexually molested? MR. YAREMA: Object to the form. A Fifth. 43 1 likely to cause severe emotional distress? 2 MR. YAREMA: Object to the form. 3 A Fifth. 4 Q And isn't it a fact that Jeffrey Epstein 5 has specifically told you that it is his intent 6 to cause severe emotional distress, as it 7 weakened his victims? 8 MR. YAREMA: Object to the form. A Fifth. Q Has Jeffrey Epstein talked to you about your role in what he calls a criminal enterprise? MR. YAREMA: Object to the form. A Fifth. Q Has he talked to you about his organization being a crIntinal enterprise, that you need to help protect? MR. YAREMA: Object to the form. A Fifth. Q What does Jeffrey Epstein do for a living? A Fifth. Q Does he profit from international sex traMckIng of children? MR. YAREMA: Object to the form. A Fifth. 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 45 1 () These were message pads that had a 2 carbon copy that were positioned or stationed in 3 several places around Jeffrey Epstein's home near 4 the telephone; you're familiar with those, 5 right? MR. YAREMA: Object to the form. A Fifth. Q Since I'm assuming that you are going to lake the Fifth on each and every question related to any messages, I will show you only one, which will be marked, this one page, as Plaintiff's Exhibit 1. The date on the message that I will be showing you is 8/21, August 21,2005. (Message dated August 21, 2005 was marked as Plaintiff's Exhibit number 1 for identification, as of this date.) MR. EDWARDS: Do you want to see it first? MR. GOLDBERGER: (Counsel examines document and hands it to the witness.) Q Would you look at the exhibit, please, if you can see it? I don't know if you tan see it over your coffee. A I can see it. Q Okay. Do you recognize it? U.S. Legal Support (561) 835-0220 CONFIDENTIAL 12 (Pages 42 to 45) 3501.144-028 Page 12 of 38 EFTA_00067624 EFTA01246843 46 A Fifth. Q That particular message indicates It Is 1 2 48 Chisiaine Maxwell's sexual interaction with Jane Doe-I02 when she was a minor? 3 from In You're the only'' in the 3 MR. YAREMA: Object to the Ponca. 4 house; is that correct? 4 Q This is one of many underage minor 5 MR. YAREMA: Object to the form. 5 females that was trafficked basically around the 6 A Fifth. 6 globe to be sexually exploited and abused; is 7 Q This is a call front you indicating that 7 that correct? 8 cannot work today and will be 8 MR. YAREMA: Object to the fonn. 9 here at 4:00 p.m.;" is that right? A Fifth. 10 MR. YAREMA: Object to the font? 10 Q Was that typical of Jeffrey Epstein and 11 A Fifth. 11 Chislaine Maxwell to sexually abuse minors on 12 Q Who Is' 12 Jeffrey Epstein's airplane? 13 A Fifth. 13 MR. YAREMA: Object to the font 14 MIL YAREMA: Object to the fonn. 14 A Fifth. 15 Q That's an underage minor female that was 5 Q And also typical of Chislaine Maxwell 16 scheduled to be molested at Jeffrey Epstein's 6 and Jeffrey Epstein to prostitute or pimp out 17 house? 7 underage minors to friends? 18 MR. YAREMA: Object to the form. 8 MR. YAREMA: Object to the form. 19 A Fifth. A Fifth. 20 Q You scheduled that act of molestation; 0 Q By "friends," I am talking specifically 21 is that right? 1 about people of royalty, politicians, 22 MR. YAREMA: Object to the fonn. 2 academicians, businessmen and other professional 23 A Fifth. 3 or personal acquaintances? 24 Q And will be at the house at 4:00 4 MR. YAREMA: Object to the fonn. 25 p.m. is another underage minor female; 5 A Fifth. 47 49 1 Is that correct? 1 Q Were you with Jeffrey Epstein on his 2 MR. YAREMA: Object to the form. 2 birthday when one of his friends sent to him 3 A Fifth. 3 12 — sorry, three 12-year olds for the purposes 4 Q That's somebody else that you were 4 of Jeffrey Epstein sexually abusing them? 5 scheduling to come to his house at 4:00 p.m. for 5 MR. YAREMA: Object to the form. 6 Jeffrey Epstein to engage In sexual acts with 6 A Fifth. 7 her, while she was an underage minor, true? 7 Q How ninny occasions have you observed 8 MR. YAREMA: Object to the form. 8 Jeffrey Epstein to receive as gifts from friends, 9 A Fifth. 9 underage minor females for the purposes of him 10 Q Do you know Les Wexner? 10 sexually abusing them? 11 A Fifth. 11 MR. YAREMA: Object to the form. 12 Q That's somebody that you know owns and 12 A Fifth. 13 operates the Victoria's Secret, the Limited? 13 Q These three 12-year olds were from 14 MR. YAREMA: Object to the fonn. 14 France. Were they sent to him on his birthday by 15 A Is that a question? 15 Jean Luc Brunel or by somebody else? 16 Q Is that somebody that you know to own 16 MR. YAREMA: Object to form. 17 Victoria's Secret or operate Victoria's Secret? 17 A Fifth. 18 A Fifth. 18 Q Have you ever been made to engage in sex 19 Q Do you know If Jeffrey Epstein still 19 with 12-year olds? 20 talks with Leslie Wexner? 20 MR. YAREMA: Object to the form. 21 MR. YAREMA: Object to the form. 21 A Fifth. 22 A Fifth. 22 Q Is It true that Jeffrey Epstein makes 23 Q Do you know Jane Doe-102? 23 you dress up as a 12-year old? 24 A Fifth. 24 MR. YAltEMA: Object to the font. 25 Q Are you aware of Jeffrey Epstein and 25 A Fifth. 13 (Pages 46 to 49) U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 13 of 38 EFTA_00067625 EFTA01246844 50 52 1 Q As part of being Jeffrey Epstein's sex 1 A Fifth. 2 slave, isn't it true that he asks you or requests 2 Q Do you know Bill Riley? 3 of you to dress younger than 12 at times? 3 A Fifth. 4 MR. YAREMA: Object to the form. 4 Q Have you seen the flight logs front 5 A Fifth. 5 Jeffrey Epstein's private airplane flights? 6 Q Have you seen naked photographs of the 6 MR. YAREMA: Object to the form. 7 underage minor females with whom Jeffrey Epstein 7 A Fifth. 8 has engaged in sex acts? 8 Q Are you aware that you're listed as a MR. YAREMA: Object to the form. 9 passenger on many flights, along with Jeffrey 10 A Fifth. 10 Epstein on his private airplane? 11 Q Are there hidden cameras in any of 11 MR. YAREMA: Object to the form 12 Jeffrey Epstein's homes, that you know to have 12 A Fifth. 13 taken surreptitious videos or photographs of 13 Q Certainly conies as no surprise to you, 14 underage minors? 14 since you were on his airplane on numerous 15 MR. YAREMA: Object to the Conn. 15 occasions, correct? 16 A Fifth. 16 MR. YAREMA: Object to the four. 17 Q Does Jeffrey Epstein still watch 17 A Fifth. 18 pornography to this day? 18 Q On September 22,2003, you were listed 19 MR. YAREMA: Object to the form. 19 as being on a flight with ,,lelTrey 20 A Etta,. 20 Epstein, and ■. My question 21 Q Does Jeffrey Epstein watch homemade 21 is who is ■. and who Is..? 22 pornographic videos of underage minors engaging 22 MR. YAREMA: Object to the funn. 23 in sex orgies on his island? 23 A Fifth. 24 MR. YAREMA: Object to the form. 24 () Do you know 25 A Fifth. 25 A Fifth. 51 53 1 () Prior to the search warrant being 1 Q That's somebody that you're familiar 2 executed, you are aware that at least three 2 with, because you have been to Jeffrey Epstein's 3 computers were taken at Jeffrey Epstein's 3 house on many occasions with 4 direction, from Jeffrey Epstein's house, to avoid 4 correct? 5 detection by law enforcement, correct? 5 MR. YAREMA: Object to the form 6 MR. YAREMA: Object to the form. 6 A Fifth. 7 A Correct. 7 Q In fact, do you remember there being a and some other person 8 burglary of Jeffrey Epstein's house where he 9 took those computers to avoid Jeffrey Epstein — 9 actually called the police to investigate the 10 to avoid the authorities obtaining the evidence 10 burglary? 11 contained on those computers, correct? 11 MR. YAREMA: Object to the form. 12 MR. YAREMA: Object to the form. 12 A Fifth. 13 A Fifth. 13 Q And during the police investigation 14 Q Who are the persons along with 14 inside Jeffrey Epstein's house, you were speaking 15 took the computers front Jeffrey 15 with MEI both in person, at Jeffrey 16 Epstein's house prior to the execution of the 16 Epstein's house, correct? 17 search warrant? 17 MR. YAREMA: Object to tile form. 18 MR. YAREMA: Object to the form. 18 A Correct. 19 A Fifth. 19 Q Is this another person that Jeffrey 20 Q Where are those computers today? 20 Epstein, when she was a minor, violated 21 MR. YAREMA: Object to the form. 21 sexually? 22 A Fifth. 22 MR. YAREMA: Object to the form. 23 Q Were they taken by his investigator, 23 A Fifth. 24 Bill Riley? 24 Q Do you still speak with 25 MR. YAREMA: Object to the form. 25 MR. YAREMA: Object to the form. 14 (Pages 50 to 53) U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 14 of 38 EFTA_00067626 EFTA01246845 54 A Fifth. 1 56 Jeffrey Epstein specifically flew to Palm Beach 2 Q Do you know Bill Clinton? 2 for the purposes of engaging in sex acts with 3 A Fifth. 3 Jane Doe? 4 Q You have been on Jeffrey Epstein's 4 MR. YAREMA: Object to the toms. airplane with Bill Clinton? 5 A Fifth. 6 MR. YAREMA: Object to the fonn. 6 Q Generally, Isn't it true Jeffrey Epstein 7 A Fifth. 7 would fly front place to place for the purpose of 8 Q Isn't take true you have been on Jeffrey 8 engaging in sexual activity with minors at his 9 Epstein's airplane with Doug Band, Bill Clinton's 9 destination? 10 righthand man? 10 MR. YAREMA: Object to the form. 11 MR. YAREMA: Object to the fonn. 11 A Fifth. 12 A Fifth. 12 Q Isn't It true that he employed numerous 13 Q slave you witnessed Improper sexual 13 people for the sole purpose of scheduling 14 activity between Jeffrey Epstein and minors, 14 appointments with underage minor females at each 15 while he was in the presence of Bill Clinton? 15 destination he landed? 16 MR. YAREMA: Object to the form. 16 MR. YAREMA: Object to the form. 17 A Fifth. 17 A Fifth. 18 Q How many times have you ridden on the 18 Q What is Jeffrey Epstein's relationship 19 airplane with Jean Luc Brunel? 19 with Sandy Berger? 20 MR. YAREMA: Object to the font 20 MR. YAREMA: Object to the fonn. 21 A Fifth. 21 A Fifth. 22 Q Each time that Jean Luc Brunel visits 22 Q Do you know what Jeffrey Epstein's 23 Jeffrey Epstein's house, does he bring underage 23 relationship is with Alan Dershowitz? 24 minors to Jeffrey Epstein's house to engage in 24 MR. YAREMA: Object to the form. 25 sex with? 25 A Fifth. 55 57 1 MR. YAREMA: Object to the form. Q That's somebody who you know to have 2 A Fifth. 2 stayed at Jeffrey Epstein's house on many 3 Q Do you know Glenn Dubin? 3 occasions, correct? 4 A Fifth. 4 MR. YAREMA: Object to the form. 5 Q Do you know li n? A Fifth. 6 A Fifth. 6 Q And also somebody who you know to have 7 Q Is that somebody that was a sexual abuse 7 been at the house when M. was In Jeffrey 8 victim at one point in time of Jeffrey Epstein 8 Epstein's bedroom getting sexually abused, 9 and Jean Luc Brunel? 9 correct? 10 MR. YAREMA: Object to the Conn. 10 MR. YAREMA: Object to the fonn. 11 A Fifth. 11 A Fifth. 12 Q Between 2002 and 2005 when M. was 12 Q Alan Dershowitz is also somebody that 13 abused by Jeffrey Epstein sexually, isn't it true 13 you also know to have been at the house when M. 14 that Jeffrey Epstein took flights to Palm Beach 14 was being sexually abused in Jeffrey Epstein's 15 for the purposes of sexually abusing M.? 15 bedroom, correct? 16 MR. YAREMA: Object to the form. 16 MR. YAREMA: Object to the fonn A Fifth. 17 A Fifth. Q And between those same years of 2002 and 18 Q Generally, Alan Dershowitz is familiar 2005, Isn't it true that Jeffrey Epstein took 19 with Jeffrey Epstein's habit of engaging in airplane flights to Palm Beach front places 20 sexual acts with minors on a daily basis, outside of the State, to engage in sexual acts 21 correct? with M.? 22 MR. YAREMA: Object to the form. MR. YAREMA: Object to the form. 23 A Fifth. A Fifth. 24 Q When Alan Dershowltz was In town, 5 Q From 2003 through 2005, Isn't it true 25 Jeffrey Epstein did not break his schedule for 15 (Pages 54 to 57) U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 15 of 38 EFTA_00067627 EFTA01246846 58 Alan Dershowitz, meaning he continued to sexually 1 60 Q Whnt was the purpose of that flight? 2 abuse minors despite Alan Dershowitz being a 2 MR. YAREMA: Object to the form. 3 guest In the house? 3 A Fifth. 4 MR. YAREMA: Object to the fonn. 4 Q Did you sign a confidentiality agreement 5 A Fifth. 5 with Jeffrey Epstein? 6 Q Alan Dershowitz never engaged in any 6 MR. YAREMA: Object to the tome sexual activity with these underage minors; isn't 7 A Fifth. 8 that true? 8 Q When is the last time that you observed 9 MR. YAREMA: Object to the fonn. 9 Jeffrey Epstein have sex with a minor? 10 A Fifth. 10 MR. YAREMA: Object to the form. 1 Q have you been made to have sex with 11 A Fifth. 12 Chislaine Maxwell? 12 Q Since being on probation, has Jeffrey 13 MR. YAREMA: Object to the lona. 13 Epstein been able to, or has he flown to his 14 A Fifth. 14 island? 15 Q Do you know 15 MR. YAREMA: Object to the Conn 16 A Fifth. 16 A Fifth. 17 Q Similar to you being Jeffrey Epstein's 17 Q To your knowledge, has Jeffrey Epstein 18 sex slave, is MEM, or was 113 flown to New York while on probation or community 19 Chislaine Maxwell's sex slave? 19 control? 20 MR. YAREMA: Object to the font 20 MR. YAREMA: Object to the fonn. 21 A Fifth. 21 A Filth. 22 Q Chislaine Maxwell is somebody who you 22 Q Isn't it true that he has flown both to 23 know to be IA-sexual, true? 23 New York and to his island, and you have 24 MR. YAREMA: Object to the form. 24 accompanied him on those trips, since he was on 25 A Fifth. 25 community control? 59 61 Q You know that Chislaine Maxwell engaged 1 MR. YAREMA: Object to the form. 2 in sexual acts with underage minor females, true? 2 A Fifth. 3 MR. YAREMA: Object to the form. 3 Q Isn't it also true that Jeffrey Epstein 4 A Fifth. 4 has indicated to you that he will always engage 5 Q This is yet another friend of Jeffrey 5 in sex acts with underage minor females? 6 Epstein's that is into the act of molesting 6 MR. YAREMA: Object to the form. 7 underage minor females, right? 7 A Fifth. 8 MR. YAREMA: Object to the form. 8 Q In fact, that's something that he has 9 A Fifth. 9 told you, that he believes he is entitled to do; 10 Q Now, you are the next participant in 10 isn't that right? 11 that activity, meaning you have been groomed to 11 MR. YAREMA: Object to the fonn. 12 enjoy and appreciate the acts of sex with 12 A Filth. 13 underage minors, true? 13 Q Isn't It true that Jeffrey Epstein 14 MR. YAREMA: Object to the form. 14 believes and has told you that if he doesn't 15 A Fifth. 15 physically force the underage minor female into 16 Q Has Jeffrey Epstein instructed you to 16 any act, then he is entitled to engage in sex 17 Ile to his Probation Officer in any way? 17 with any underage minor female despite the age? 18 MR. YAREMA: Object to the form. 18 MR. YAREMA: Object to the form. A Fifth. 19 A Fifth. Q Mr. Visoski testified that you took a 20 Q What is the youngest female you have helicopter flight within the last year with 21 witnessed or observed Jeffrey Epstein to engage Jeffrey Epstein to Miami. Do you remember that 22 in sex with? flight? 23 MR. YAREMA: Object to the fonn. MR. YAREMA: Object to the form. 24 A Fifth. 5 A Fifth. 25 Q Do you have a bunk account at Chase Bank 16 (Pages 58 to 61) U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 16 of 38 EFTA_00067628 EFTA01246847 1 2 3 4 5 6 62 In New York? A Fifth. Q And the money in that bank account under your name is money that was given to you by Jeffrey Epstein, correct? MR. YAREMA: Object to the fon. 1 2 3 4 5 6 64 Q That's somebody who these days refers to himself as Jeffrey Epstein's personal assistant, right? MR. YAREMA: Object to the fonn. A Fifth. Q That's somebody who you know to work for 7 A Fifth. 7 or at the Florida Science Foundation, which is 8 Q For the passed ten or so years, you have 8 owned by Jeffrey Epstein, correct? 9 lived with Jeffrey Epstein under his control, 9 MR. YAREMA: Object to the form. 10 right? 10 A Fifth. 11 MR. YAREMA: Object to the form. 11 Q It is also somebody that you know to 12 A Fifth. 12 have stayed at Jeffrey Epstein's house with= 13 Q You get to lead the life of a 13 correct? 14 millionaire, and to lead that life, you were only 14 MR. YAREMA: Object to the fonn. 15 required to be Jeffrey Epstein's sex slave and to 15 A Fifth. 16 bring Jeffrey Epstein other slaves? 16 Q This is somebody that has been 17 MR. YAREMA: Object to the form. 17 Involved — is somebody who's been 18 A Fifth. 18 Involved sexually with for at least 19 Q Is this 301 East 66th Street apartment 19 a year, right? 20 still an apartment that you frequent today? 20 MR. YAREMA: Object to the tome. 21 MR. YAREMA: Object to the form. 21 A Fifth. 22 A Fifth. 22 Q In fact, you know that they took a trip 23 Q And you're familiar with the nine or ten 23 around the world together and during that trip 24 apartments that Jeffrey Epstein owns or controls 24 they discussed Jeffrey Epstein and his 25 up there at 301 East 66th Street, aren't you? 25 interaction with underage minor females, 63 65 1 MR. YAREMA: Object to the form. 1 correct? 2 A Fifth. 2 MR. YAREMA: Object to the form. 3 Q At any given time, there are between S 3 A Fifth. 4 and 16 underage minors living in or staying at 4 MR. EDWARDS: Done. I don't have S those apartments? 5 anything else. 6 MR. YAREMA: Object to the fonn. 6 MR. GOLDBERGER: Okay. 7 A Fifth. 7 MR. HOROWITZ: I do, why don't we take a 8 Q On the various passenger lists on 8 short break. 9 Jeffrey Epstein's airplane, where it will list, MR. GOLDBERGER: We are stopping at 10 for instance, Jeffrey Epstein, 10 11:50. 11 going from Florida to St. 11 MR. HOROWITZ: What? 12 Thomas, then generically, female, female; would 12 MR. GOLDBERGER: 11:50. 13 you know who those female, females are? 13 MR. HOROWITZ: I kind of remember that 14 MR. YAREMA: Object to the form. 14 e-mail. 15 A Fifth. 15 THE VIDEOGRAPHER: Off the video record. 16 Q Are those females listed generically 16 (Pause in the proceedings.) 17 rather than specifically because they are 17 THE V1DEOCRAPHER: We are back on the 18 underage minor females engaging in sex with you 18 video record at 11:18 a.m.) 19 or Jeffrey Epstein? 19 (At this time Robert Critton joined the 20 MR. YAREMA: Object to the fonn. 20 proceedings.) 21 A Fifth. 21 CROSS EXAMINATION 22 Q Is someone that you see on 22 BY MR. HOROWITZ: 23 ■ regular basis at Jeffrey Epstein's house? 23 between 200t and 2006, 24 MR. YAREMA: Object to the fonn. 24 did Jeffrey Epstein instruct you to place 25 A Fifth. 25 telephone calls io arrange for girls under the 17 (Pages 62 to 65) U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 17 of 38 EFTA_00067629 EFTA01246848 66 68 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 age of 18 to come to his home for his sexual gratification? MR. YAREMA: Object to the form. A Fifth. Q Between 2001 and 2006 did you, in fact, place telephone calls to arrange for girls under the age of Is to come to Jeffrey Epstein's home for his sexual gratification? MR. YAREMA: Object to the form. A Fifth. Q Are you personally aware that a girl named M . came to Jeffrey Epstein's Palm Beach home in late 2004? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein admit to you he sexually abused M.? MR. YAREMA: Object to the form. A Fifth. Q Isn't it true in late 2004 you made arrangements by telephone to bring S to Jeffrey Epstein's home? MR. YAREMA: Object to the fonn. A Fifth. Q Did Jeffrey Epstein instruct you to 1 2 3 4 5 6 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 A Fifth. Q Did Jeffrey Epstein admit to you that he sexually abused in his Palm Beach home in 2004? MR. YAREMA: Object to the form. A Fifth. Q Did you ever instruct a girl named a to bring other underage girls to Jeffrey Epstein's home for Jeffrey Epstein's sexual pleasure? MR. YAREMA: Object to the form. A Fifth. Q In 2004 did you communicate by telephone with for the purpose of bringing ■. to Jeffrey Epstein's home for sexual activity MR. YAREMA: Object to the fonn. A Fifth. Q Did Jeffrey Epstein instruct you to communicate with for the purpose of making arrangements for M. to come to his home? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein tell you it was his intent during the course of M.'s visit to his 5 home to persuade, induce or entice her to engage 67 communicate by telephone to arrange for M. to 2 come to his home for his sexual gratification? 3 MR. YAREMA: Object to the fonn. 4 A Fifth. 5 Q Did Jeffrey Epstein inform you that M. 6 would be giving him a massage that was sexual in 7 nature? MR. YAREMA: Object to the form. 9 A Fifth. 10 Q Did Jeffrey Epstein tell you it was his 11 intent during the course of M.'s visit to his 12 home to persuade, induce or entice her to engage 13 in sexual activity? 14 MR. YAREMA: Object to the fonn. 15 A Fifth. 16 Q Did Jeffrey Epstein tell you that, in 17 fact, he succeeded in persuading, Inducing or 18 enticing M. to engage in sexual activity with 19 hint? 20 MR. YAREMA: Object to the form. 21 A Fifth 22 Q Are you personally aware that a girl 23 named M . came to Jeffrey Epstein's Palm Beach 24 home on multiple occasions in 2004? 25 MR. YAREMA: Object to the form. 1 2 3 4 S 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 69 In sexual activity with him? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein admit to you that he had succeeded in, in fact, persuading, inducing or enticing M. to engage in sexual activity with him? MR. YAREMA: Object to the form. A Fifth. Q Are you personally aware that a teenage girl named came to Jeffrey Epstein's Palm Beach home on multiple occasions between 2003 and 2005? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein admit to you that he sexually abused St MR. YAREMA: Object to the form A Fifth. Q At any time prior to May of 2005, did Jeffrey Epstein instruct you to place telephone calls to M. for the purpose of arranging for her to come to his home and engage in sexual activity? MR. YAREMA: Object to the form. U.S. Legal Support (561) 835-0220 CONFIDENTIAL 18 (Pages 66 to 69) 3501.144-028 Page 18 of 38 EFTA_00067630 EFTA01246849 70 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Filth. Q Did you, in fact, communicate by telephone with • for the purpose of arranging for her to come to his home for sexual activity? MR. YAREMA: Object to the tom. A Fifth. Q At any lime prior to May of 2005, did you place a telephone call to I= wherein you arranged fore to come to Jeffrey Epstein's home for sexual activity? MR. YAREMA: Object to the form. A Fifth. Q Prior to May of 2005, did you ever observe speaking with M. by telephone to arrange for M. to come to Jeffrey Epstein's home? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein tell you that it was his intention to sexually abuse ■. during the course of her visits to his home? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein tell you that he succeeded in engaging `In sexual activity 1. 2 3 4 S 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 3 24 25 in either 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Did you, in fact, call M. to come to Jeffrey Epstein's home and give him a massage in sexual nature in 2001 or 2002? MR. YAREMA: Object to the tom. A Fifth. Q Did you either observe or overhear speaking with M. on the telephone to arrange for M. to conic to Jeffrey Epstein's home for a massage of a sexual nature? MR. YAREMA: Object to the form. A Filth. Q Did Jeffrey Epstein tell you it was his intent during the course of M.'s visit to his home to persuade, induce or entice her to engage In sexual activity? MR. YAREMA: Object to the form. A Fifth. Q Didn't Jeffrey Epstein admit to you that he succeeded in persuading, inducing or enticing M. to engage in sexual activity with him nt his home while she was still a minor? MR. YAREMA: Object to the form. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 71 while she was still a minor, at his home? MR. YAREMA: Object to the form. A Fifth. Q Are you personally aware that a teenage girl named an came to Jeffrey Epstein's Palm Beach home in approximately 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein admit to you that he sexually abused M . at his home while she was sun a child? MR. YAREMA: Object to the form. A Fifth. Q In 2001 or 2002, did inform you that she received a telephone call in which she was referred to M., who would be willing to come to Jeffrey Epstein's home for sexual activity? MR. YAREMA: Object to the form. A Fifth. (Whereupon, at this point in the proceedings, Robert Critton leit the deposition room.) Q Did Jeffrey Epstein instruct you to call M. to come to his home and give him a massage 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1.3 A Fifth. Q Are you personally aware that a girl named came to Jeffrey Epstein's home in approximately August 2004? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein admit to you that he had sexually abused M. when she was only 13 years old? MR. YAREMA: Object to the fonn. A Fifth. Q In 2004 did you participate in a telephone call wherein you arranged for ■. to come to Jeffrey Epstein's home for the purpose of giving him a massage that was to be sexual In nature? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein instruct you to communicate by telephone and make arrangement for M. to conic to his home for sexual activity while she was still a child? MR. YAREMA: Object to the foam A Fifth. Q Did Jeffrey Epstein tell you it was his U.S. Legal Support (561) 835-0220 CONFIDENTIAL 19 (Pages 70 to 7 3) 3501.144-028 Page 19 of 38 EFTA_00067631 EFTA01246850 74 intention during the course of M.'s visit to his home to persuade, Induce or entice her to engage in sexual activity with him? 1 2 3 76 MR. YAREMA: Object to the form. A Fifth. Q Dld you participate in a telephone call 4 MR. YAREMA: Object to the font. 4 wherein you arranged for M. to tome to Jeffrey A Fifth. 5 Epstein's home for a massage? 6 Q Did Jeffrey Epstein tell you that, In 6 MR. YAREMA: Object to the form. 7 fact, he succeeded in persuading, inducing and 7 A Fifth. 8 enticing. to engage in sexual activity with Q Did Jeffrey Epstein instruct you to 9 him while she was still a child at his home? 9 participate in a telephone call wherein you were 10 MR. YAREMA: Object to the form. 10 to arrange for to come to Ids home for 11 A Fifth. 11 sexual activity? 12 Q Are you personally aware that a girl 12 MR. YAREMA: Object to the fonn. 13 named e came to Jeffrey Epstein's home in Palm 13 A Fifth. 14 Beach on multiple occasions between 2003 and May 14 Q Did Jeffrey Epstein admit to you It was 15 of 2005? 15 his intention during the course of visit 16 MR. YAREMA: Object to the fonn. 16 to his home, to engage her in sexual activity 17 A Fifth. 17 while she was still a child? 18 Q Did Jeffrey Epstein admit to you that he 18 MR. YAREMA: Object to the form. 19 sexually abused. at his home between 2003 and 19 A Fifth. 20 May of 2005? 20 Q Did Jeffrey Epstein admit to you he had, 21 MR. YAREMA: Object to the form. 21 In fact, persuaded, enticed and engaged in 22 A Fifth. 22 sexual activity at his home while she was still a 23 Q Prior to May of 2005, did you receive a 23 child? 24 phone call front a girl named wherein 24 MR. YAREMA: Object to the form. 25 she told you she was bringing e to Jeffrey 25 A Fifth. 75 77 1 Epstein's home to give him a massage? 1 MR. HOROWITZ: No other questions at 2 MR. YAREMA: Object to the form. 2 this point. 3 A Fifth. 3 MR. LANGINO: I have less than ten 4 Q At any time prior to 2005, did Jeffrey 4 minutes of questioning. 5 Epstein instruct you to communicate with MI 5 MR. GOLDBERGER: Fine, that will bring 6 by telephone to make arrangements for. 6 us right to the break. 7 to come to his home? 7 CROSS EXAMINATION 8 MR. YAREMA: Object to the Fenn. 8 BY MR. LANGINO: 9 A Fifth. 9 Q I'm Adam Langino and I represent.. 10 Q Prior to M.'s visits to Jeffrey 10 and.. 11 Epstein's home, did Jeffrey Epstein tell you it 11 Do you know an individual named M? 12 was his intention to induce, entice and engage 12 A Fifth. 13 N., to engage in sexual activity with him? 13 Q Do you know an individual named M.? 14 MR. YAREMA: Object to the fonn. 14 A Fifth. 15 A Fifth. 15 Q Have you seen at the defendant's 16 Q After visits to Jeffrey Epstein's 16 Palm Beach property? 17 home, did Jeffrey Epstein tell you that he 17 MR. YAREMA: Object to the form. 18 succeeded in enticing, engaging and persuading 18 A Fifth. 19 to engage in sexual activity with him while 19 Q (lave you seen.. al the defendant's 20 she was still a child? 20 Palm Beach property? 21 MR. YAREMA: Object to the fonn. 21 MR. YAREMA: Object to the form. 22 A Fifth. 22 A Fifth. 23 Q Are you personally aware that a teenage 23 Q Have you ever engaged in a sexual act 24 girl minted came to Jeffrey Epstein's Palm 24 with 25 Beach home in approximately 2001 or 2002? 25 MR. YAREMA: Object to the fonn. 20 (Pages 74 to 77) U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 20 of 38 EFTA_00067632 EFTA01246851 78 A Fifth. 1 80 with the defendant was consensual? 2 Q Have you ever engaged in a sexual tel 2 MR. YAREMA: Object to the form. with 3 A Fifth. 4 MR. YAltEMA: Object to the form. 4 Q Do you know if M.'s sexual activity 5 A Fifth. 5 with the defendant was consensual? 6 Q Did you ever observe the defendant, 6 MR. YAREMA: Object to the form. 7 Jeffrey Epstein, with.? 7 A Fifth. MR. YAREMA: Object to the form. 8 Q When you participated hi sexual acts 9 A Fifth. 9 with each minor, how did you feel? 10 Q Did you ever observe the defendant, 0 MR. YAREMA: Object to the form. 11 Jeffrey Epstein, with 1 A Fifth. 12 MR. YAREMA: Object to the form? 2 Q In your heart, did you know it was 13 A Fifth. 3 wrong? 19 Q Have you ever physically touched a? 4 MR. YAREMA: Object to the form, and in 15 MR. YAREMA: Object to the form. 5 addition this is irrelevant and has already 16 A Fifth. 6 been addressed by Judge Hafele as an 17 Q Have you ever physically touched a? 7 inappropriate question. That's my 18 MR. YAREMA: Object to the form. 8 objection. 19 A Fifth. 9 A Fifth. 20 Q Has the defendant ever made a statement 0 Q During this time period did you feel 21 to you about 1 confused? 22 MR. YAREMA: Object to the form. 2 MR. YAREMA: Object to the form. 23 A Fifth. 3 MR. GOLDBERGER: Same — 24 Q Has the defendant ever made a statement 4 MR. YAREMA: Same objection. 25 to you about 5 A Fifth. 79 81 MR. YAREMA: Object to the form. 1 Q Are you currently In love with the 2 A Fifth. 2 defendant? 3 Q Has ever made a statement 3 MR. YAREMA: Object to the fonn, same 4 to you about 4 objection. That question has no relevance 5 MR. YAREMA: Object to the form. 5 to this... it is inappropriate per Judge 6 A Fifth. 6 Hafete's order. 7 Q Has ever made a statement 7 MR. GOLDBERGER: Also involves privacy 8 to you about N.? B rights of my client. I 111S1R143 her not to MR. YAREMA: Object to the form. 9 answer the question. 10 A Fifth. 10 A Fifth. 11 Q Have you ever communicated with 11 Q Have you ever been in love with Jeffrey 12 MR. YAREMA: Object to the form. 12 Epstein? 13 A Fifth. 13 MR. GOLDBERGER: Same objection. 4 Q Have you ever communicated with 14 MR. YAREMA: Same objections. 15 MR. YAREMA: Object to the form. 15 A Fifth. 16 A Fifth. 16 MR. LANOINO: Thank you. 17 Q Did you know that U,U was a minor 17 CROSS EXAMINATION 18 at the time of sexual abuse? 18 BY F.ZELL: 19 MR. YAREMA: Object to the form. 19 (Discussion off thc record.) 20 A Fifth. 20 Q Good morning, I'm 21 Q Did you know ....... was a minor at 21 Katherine Ezell and I represent Jane Doe 103, 22 the time of the sexual abuse? 22 whose name Is ., which shall appear as.. in 23 MR. YAREMA: Object to the form. .3 the deposition. 24 A Fifth. 24 Are you aware that in 2004 and 5, there 25 Q Do you know ir sexual activity 75 was a sort of hidden staircase that would take 21 (Pages 78 to 81) U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 21 of 38 EFTA_00067633 EFTA01246852 1 82 one from the kitchen upstairs to the master 1 134 Q Do you recall that Jeffrey Epstein would 2 bedroom and massage area? 2 Join in by performing oral sex on one or the 3 MR. YAREMA: Object to the form. 3 other of you — you or ..? 4 A Fifth. 4 MR. YAREMA: Object to the form. 5 Q Do you recall there being nude 5 A Fifth. 6 photographs on the staircase? 6 Q Do you recall that also happening, 7 MR. YAREMA: Object to the form. 7 meaning the oral sex, being performed on the 8 A Fifth. 8 massage table — 9 Q Did you know 9 MR. YAREMA: Objection. 10 A Fifth. 10 Q to 11 Q Did come to the house at 358 El 1 MR. YAREMA: Object to the form. 12 Brill° Way to provide a massage to Jeffrey 12 A Fifth. 13 Epstein? 13 Q Were you present one day when Jeffrey 14 MR. YAREMA: Object to the form. 14 Epstein held.. down on the massage table and 15 A Fifth. 15 while holding her inserted his penis Into M's 16 Q Did that massage become sexual in 16 vagina? 17 nature? 17 MR. YAREMA: Object to the form. 18 MR. YAREMA: Object to the form. 18 A Fifth. 19 A Fifth. 19 Q Do you recall he stated that he wanted 20 Q Did • become a regular visitor at 20 you to observe this? 21 Jeffrey Epstein's house? 21 MR. YAREMA: Object to the form. 22 MR. YAREMA: Object to the form. 22 A Filth. 23 A Fifth. 23 Q Do you recall that.. had rules, 24 Q Do you remember that she came maybe 24 lines, that she had stated Jeffrey Epstein was 25 hundreds of times? 25 not to cross, in their encounters? 83 MR. YAREMA: Object to the fonn. 1 MR. YAREMA: Object to the form. 2 A Fifth. 2 A Fifth. 3 Q Do you recall that she was under the age 3 Q Do you recall that.. had forbidden 4 of 18 at the time she was coming to Jeffrey 4 any kind of vaginal penetration? 5 Epstein's home? 5 MR. YAREMA: Object to the form 6 MR. YAREMA: Object to the fonn. 6 A Fifth. 7 A Fifth. 7 Q Do you recall that.. refused to touch 8 Q Were you younger than.. at the time? 8 Jeffrey Epstein's penis? 9 MR. YAREMA: Object to the form. 9 MR. YAREMA: Object to the fonn. 10 A Fifth. 10 A Fifth. 11 Q Do you remember occasions when you and 11 Q Do you recall that day when Jeffrey 12 Jeffrey Epstein were already in bed when 12 Epstein held.. on her stomach on the massage 13 arrived? 13 table and began pumping his penis into her 14 MR. YAREMA: Object to the fonn. 14 vagina, that she screamed "No"? 15 A Fifth. 15 MR. YAREMA: Object to the fonn. 16 Q Do you recall Jeffrey Epstein 16 A Fifth. 17 instructing. to remove her clothes and Join 17 Q Do you recall that upon her screaming, 18 the two of you in bed? 18 Epstein stopped and apologized? 19 MR. YAREMA: Objoci to the fomi. 19 MR. YAREMA: Object to the fonn. 20 A Fifth. 20 A Fifth. 21 Q Do you recall that you and Jeffrey ,21 Q Do you recall that Jeffrey Epstein paid 22 Epstein bringing sex toys In bed for you and 22 her $1,000 for that visit? 23 to use on each other? 23 MR. YAREMA: Object to the form. 24 MR. YAREMA: Object to the fonn. 24 A Fifth. 25 A Fifth. 25 Q Did you engage In sex with when she 22 (Pages 82 to 85) U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 22 of 38 EFTA_00067634 EFTA01246853 1 2 86 was under 18? MR. YAREMA: Object to the form. 1 2 88 end of a play performance during her senior year? MR. YAREMA: Object to the Conn. 3 A Fifth. 3 A Fifth. 4 Q Did Jeffrey Epstein watch you and M. 4 THE VIDEOGRAPHER: Counsel, can we stop 5 having sex while he masturbated? 5 for one minute? 6 MR. YAREMA: Object to the form. 6 MS. EZELL: Sure. 7 A Fifth. 7 THE VIDEOGRAPHER: Off the video record 8 Q Are you aware that M's activities 8 11:43 a.m. 9 with Jeffrey Epstein escalated further and (Short pause.) 10 further as time went on? 10 (Whereupon at this point in time, Mr. 11 Mit. YAREMA: Object to the form. 11 Langino left the proceedings.) 12 A Filth. 12 THE VIDEOGRAPHER: Back on the video 13 Q Did you see Jeffrey Epstein use 13 record 1:43 a.m. 14 vibrators and strap-on — use vibrators on M.? 14 CROSS EXAMINATION (CONTINUED) 15 MR. YAREMA: Object to the form. 15 BY MS. EZELL: 16 A Fifth. 16 Q Were you present in October 2005 when 17 Q Dld you and M . engage in sex with 17 the Palm Beach Police Department raided Jeffrey 18 strap-on penises? 18 Epstein's home? 19 MR. YAREMA: Object to the form. 19 MR. YAREMA: Object to the form 20 A Fifth. 20 A Fifth. 21 Q Did you see Jeffrey Epstein perform oral 21 Q You and others were aware that there 22 sex on M. numerous times? 22 would be a raid at that time; were you not? 23 MR. YAREMA: Object to the form. 23 MR. YAREMA: Object to the loon 24 A Fiflh. 24 A Fifth. 25 Q Did Jeffrey Epstein pay M. an 25 Q Who informed you that there would be a 87 89 1 additional 5200 to perform oral sex on you? 1 raid on the house? 2 MR. YAREMA: Object to the form. 2 MR. YAREMA: Object to the fonn. 3 A Fink 3 A Fifth. 4 Q Do you recall that each time a new toy 4 Q Did you participate in the removal of 5 or activity was Introduced when S was there to 5 nude photographs, sex toys, computer records from 6 give massages, Jeffrey Epstein paid 6 358 El Brillo Way prior to the raid? 7 additional money? 7 MR. YAREMA: Object to the roma MR. YAREMA: Objea to the coml. 8 A Fifth. 9 A Fifth. 9 Q Do you know who rentoved those objects at 10 Q Would Jeffr psteln masturbate while 10 that time? 11 watching you and perform sexual acts? 11 MR. YAREMA: Object to the form. 12 MR. YAREMA: Object to the form. 12 A Fifth. 13 A Fifth. 13 Q Do you remember that at times Jeffrey 14 Q Do you recall that Jeffrey Epstein 14 Epstein paid M . t o just sleep in his bed in the 15 provided M. with gifts of purses and 15 nude? 16 bathingsults? 16 MR. YAREMA: Object to the form. 17 MR. YAREMA: Object to the form. 17 A Fifth. 18 A Fifth. 18 Q Do you recall at times he paid her to 19 Q Do you recall that Jeffrey Epstein 19 just cuddle with him? 20 provided M. with a blue 2000 Dodge Neon which 20 MR. YAREMA: Object to the form. 21 had been rented for her? 21 A Fifth. 22 MR. YAREMA: Object to the fonn. 22 Q Did you ever driveM. to Or from 358 23 A Fifth. 23 El Milo Way? 24 Q Do you recall that Jeffrey Epstein 24 MR. YAREMA: Object to the form. 25 ordered that roses be delivered ton at the 25 A Filth. 23 (Pages 86 to 8 9) U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 23 of 38 EFTA_00067635 EFTA01246854 90 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 10 19 20 21 22 23 24 25 Q Did you ever know to drive A.H. to or from 358 El Brillo Way? MR. YAREMA: Object to the form. A Fifth. Q Do you remember the houseman at that time as being Alfredo Rodriguez? MR. YAREMA: Object to the form. A Fifth. Q Do you remember Alfredo Rodriguez being instructed to drive S to or from 358 El Brillo Way? MR. YAREMA: Object to the form. A Fifth. Q Do you recall a time when Alfredo Rodriguez discovered M. asleep upstairs naked? MR. YAREMA: Object to the form. A Fifth. Q Were you aware Jeffrey Epstein repeatedly asked M. to allow him to photograph her in the nude? MR. YAREMA: Object to the form. A Fifth. Q Did you allow Jeffrey Epstein to take photographs, nude photographs of you? MR. YAREMA: Object to the form. 1 2 3 4 6 7 9 10 1.1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 he would pay her 1,000 or 51,500 If she would lose ten pounds? MR. YAREMA: Object to the form. A Fifth. Q Did you know M. to be a good student? MR. YAREMA: Object to the form. A Fifth. Q Did it appear that you that M. was smart? MR. YAREMA: Object to the fort. A Fifth. Q Did you observe that M. was concerned about her grades? MR. YAREMA: Object to the fonn. A Fifth. Q Do you recall Jeffrey Epstein expressing interest in M.'s college ambitions? MR. YAREMA: Object to the form. A Filth. Q Have you known Jeffrey Epstein to brag about donations he's made to colleges like NYU, Columbia, Harvard and Wharton? MR. YAREMA: Object to the Porn. A Fifth. Q Do you know that M . wanted very much 91 1 A Fifth. 2 Q Do you recall a time when M. gave in 3 and did allow Jeffrey Epstein to photograph her 4 while nude? 5 MR. YAREMA: Object to the form. 6 A Fifth. 7 Q Did you ever see any of those 8 photographs taken by Jeffrey Epstein of • in 9 the nude? 10 MR. YAREMA: Object to the torn. 11 A Fifth. 12 Q Do you know whether those photographs 13 were ever developed? 14 MR. YAREMA: Object to the form 15 A Fifth. 16 Q Do you know what kind of camera Jeffrey 17 Epstein liked to use when taking photographs of 18 women posing in the nude? 19 MR. YAREMA: Object to the form. 20 A Fifth. 21 Q Did you ever hear here Jeffrey Epstein 22 tell M . that she needed to lose ten pounds? 23 MR. YAREMA: Object to the form. 24 A Fifth. 25 Q Did you ever hear here him tell her that 1 2 3 4 5 7 8 9 10 11 12 L3 14 15 16 17 18 19 20 21 22 23 24 25 93 to go to school in New York at NYU or at Columbia? MR. YAREMA: Object to the form. A Fifth. Q Did you know that Jeffrey Epstein promised to help her get into one of those schools? MR. YAREMA: Object to the form. A Fifth. Q Do you know whether he did help? MR. YAREMA: Object to the form. A Fifth. Q Do you know whether he offered to pay some of her college expenses? MR. YAREMA: Object to the form. A Fifth. Q Did you ever observe Jeffrey Epstein working with M. on her college applications? MR. YAREMA: Object to the form. A Fifth. Q Did you ever see M. Just hanging out al Jeffrey Epstein's house studying while nude? MR. YAREMA: Object to the form. A Fifth. Q Did you know that Jeffrey Epstein gave U.S. Legal Support (561) 835-0220 CONFIDENTIAL 24 (Pages 90 to 93) 3501.144-028 Page 24 of 38 EFTA_00067636 EFTA01246855 94 96 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 M. airline tickets and theater tickets in New 2 York? 3 MR. YAREMA: Object to the fonn. 4 A Fifth. 5 Q Did you and M. ever go shopping 6 together? 7 MR. YAREMA: Object to the tinm. 8 A Fifth. 9 Q Did you call M. once and ask her to go shopping with you for Jeffrey Epstein on his birthday? MR. YAREMA: Object to the form. A Fifth. Q Did you and M . purchase adult sex toys to use for Jeffrey Epstein's birthday, as a show, for him? MR. YAREMA: Object to the form. A Fifth. Q Are you aware that Jeffrey Epstein told he would pay her to bring other young girls to give him massages? MR. YAREMA: Object to the Porn. A Fifth. Q Do you know that Jeffrey Epstein paid M. 5200 for each girl that she brought to him, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 18 17 0 2 3 4 5 A The Fifth. Q Do you know if typically girls who Epstein knew, were given tickets to go to the show, then Invited back stage? MR. YAREMA: Object to the form. A Fifth. THE VIDEOGRAPHER: Can you speak up? THE WITNESS: (Adjusts microphone.) Q Did M. ever tell you that David Copperfteld tried to feel her butt during dinner? MR. YAREMA: Object to the font). A Fifth. Q Did you ever hear Jeffrey Epstein telling any of the young women who came to give him massages, that he was a brain scientist? MR. YAREMA: Object to the Comm. A Fifth. Q Did you know M.? A Fifth. Q And from now on I will use the initials M. Do you know that M. visited Jeffrey Epstein at 358 El Brlllo Way some 15 to 20 times? MR. YAREMA: Object to the form? A Filth. Q Did you ever Interact with M. while 1 2 3 4 5 6 7 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 24 25 95 to give him a massage? MR. YAREMA: Object to the form. A Fifth. MR. GOLDBERGER: I guess we will have to take a break now, if that's all right with you. MS. EZELL: Okay. THE VIDEOGRAPHER: 11:50 a.m., going off the video record. MR. GOLDBERGER: I will be done at 1:15 so we can go until 1:30. (Pause in the proceedings.) THE VIDEOGRAPHER: We are bock on the video record at 1:36 p.m. CROSS EXAMINATION (CONTINUED) BY MS. EZELL: Q f did you ever have dinner at Jeffrey Epstein's house, with David Copperfield as a guest, when was present? MR. YAREMA: Object to the form. A The Fifth. Q Have you met David Copperfleid? A Fifth. Q (lave you ever been given tickets to go see one of his shows? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 10 19 20 21 22 23 24 25 97 she was there to give a massage? MR. YAREMA: Object to the form A Fifth. Q Dld you know that at the time she was visiting Mr. Epstein and providing massages, she was under the age of 18? MR. YAREMA: Object to the form. A Fifth. Q Do you recall being introduced to M. by Mr. Epstein? MR. YAREMA: Object to the form. A Fifth. Q Do you recall that Jeffrey Epstein Instructed you and M. to kiss and fondle each other around the breasts and buttocks while massaging him? MR. YAREMA: Object to the form. A Fifth. Q Did you ever see Mr. Epstein use a large vibrator/massager on M.? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein ever ask you to purchase a digital camera for hint to give M . ? MR. YAREMA: Object to the form. U.S. Legal Support (561) 835-0220 CONFIDENTIAL 25 (Pages 94 to 97 3501.144-028 Page 25 of 38 EFTA_00067637 EFTA01246856 98 100 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 A Filth. 2 Q Did you know that Jeffrey Epstein gave 3 a digital camera? 4 MIL YAREMA: Object to the Iona. 5 A PM. 6 MS. EZELL: I don't have any other 7 questions. Thank you. 8 MR. GOLDBERGER: You still have your microphone on. You must have something on your mind, Brad. REDIRECT EXAMINATION BY MR. EDWARDS: Q through the whole day you've taken the Fifth on just about every single question. Is there any reason why we should not presume that the answer to these questions would Incriminate you? MR. YAREMA: Object to the form. A The Fifth. Q The reason that you have taken the Fifth is because the questions you have been asked would have been answered in the affirmative and you're afraid of prosecution for your Involvement, true? MR. GOLDBERGER: Don't answer that 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE STATE OF FLORIDA) COUNTY OF PALM BEACH) I, TERRI BECKER, a Registered Pmfessional Reporter and Notary Public for the State of Florida at Large, do hereby certify that I reported the videotaped deposition of the WITNESS, called by the PLAINTIFF in the above-entitled action: that the witness was duly swami by me; that the foregoing pages, numbered from 1 to 104, inclusive, constitute a true record of the deposition by said witness. I further certify that I am not attorney or counsel of any of the patties, nor a relative or employee of any attorney or counsel connected with the action, nor financially interested in the action. WITNESS MY IIAND and official seal in the City of West Palm Bradt, County of Palm Beach, State of Florida, this 19th day of April 2010. TERRI ECK ER, Registered Professional Reporter and Notary Public, State of Florida at Lame. My Commission expires March 13,2011. 2 3 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 99 question. It interferes with the attorney/client relationship that I have with and any discussions she and I may have had would come under that privilege. You can try and dance around that, but I'm simply not going to allow her to answer that question. If you want to bring it up with the Judge, you can. MR. EDWARDS: Thanks, Jack. MR. GOLDBERGER: Okay. THE VIDEOGRAPHER: Off the video record at 1:41 p.m. THE COURT REPORTER: You're ordering this, Brad? MR. EDWARDS: Yes. Copies? MS. EZELL: Yes. MR. YAREMA: Yes: THE COURT REPORTER: And Adam wanted it; is that right? MR. EDWARDS: Yes. (Time noted: I:45 p.m.) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE STATE OF FLORIDA) COUNTY OF PALM BEACH) The foregoing certificate was acknowledged before me this day of 2010. 101 Notary Public, State of Florida. My commission No. Expires March 13, 2011. U.S. Legal Support (561) 835-0220 CONFIDENTIAL 26 (Pages 98 to 101) 3501.144-028 Page 26 of 38 EFTA_00067638 EFTA01246857 102 1 0 4 2 3 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 do hereby certify that I have read the foregoing transcript of my deposition given on April I), 20)0; that together with the correction page attached hereto noting changes in form or substance, if any, it is true and correct. I do hereby certify that the deposition of was submitted to the witness for reading and signing; that alter she had stated to the undersigned Notary Public that she had read and examined her deposition, she signed the same in the presence of the undersigned authority on the day of 2010. 1 2 4 5 6 7 10 11 12 11 14 15 16 17 18 19 20 U.S. 1 (GAL SL1PPOR Iterenered Pmfoontal RCPOdarN 444 W40 luaaed A4cnut Sonic MP Wert Patin Read. Plaid M401 (561)815.0220 April 19. 2010 • ". a tISS ATTENTION: JACK GOLDBERGER. ESQ. In Re: 110E V. EPSTEIN DqatIlion of - Ds Mr. Otaltraucc Sane cannel lone agreeddam ant may love the natant read and an your copy et the dcpaaarn. for yoga amremeae. OICIOWCI ilOC•0 )0.1 nut Owl an Enna Shed Ice die umutot ant a aval tog tiNy than ga. M Orc dtwoniun Tbank you for your inompi tainaion. Conbally yours, 11.6 LEGAL S(.112P(5111. . ....._._ . lERRI IILCKER. Rcaucred Profasional Reporter. Idogny 21 Public. Sole or numb a Lair. My c044/04000 cpwcs 22 Kw,* I). 2011 2) CC UatlIty Edwards. Eal. Adam Ilona in. Log ...1 Kultnoc Lull, Ea. Onnd Vanua. Ca 25 1 ERRATA SHEET 2 In Re: DOE V. EPSTEIN 3 DO NOT WRITE ON TRANSCRIPT ENTER CHANGES HERE: 4 5 PAGE LINE CHANGE REASON 6 7 8 9 10 11 12 13 14 15 16 17 18 THE STATE OF FLORIDA) 19 COUNTY OF PALM BEACH) 20 I DO HERESY CERTIFY THAT opwan:d below Inc and stated dial she has read 21 her deposition; further. that this Errata Shed was sigixst in my Rae= on Ibis day 22 of 2010. 23 103 24 25 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 27 (Pages 102 to 104) 3501.144-028 Page 27 of 38 EFTA_00067639 EFTA01246858 Page 1 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 28 of 38 EFTA_00067640 EFTA01246859 Paae 2 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 29 of 38 EFTA_00067641 EFTA01246860 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 30 of 38 EFTA_00067642 EFTA01246861 Page 4 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 31 of 38 EFTA 00067643 EFTA01246862 Pa9e 5 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 32 of 38 EFTA 00067644 EFTA01246863 Page 6 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 33 of 38 EFTA_00067645 EFTA01246864 Page "/ U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 34 of 38 EFTA_00067646 EFTA01246865 Pace 8 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 35 of 38 EFTA_00067647 EFTA01246866 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 36 of 38 EFTA_00067648 EFTA01246867 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 37 of 38 EFTA_00067649 EFTA01246868 U.S. Legal Support (561) 835-0220 CONFIDENTIAL 3501.144-028 Page 38 of 38 EFTA_00067650 EFTA01246869