EFTA Document EFTA01723963

12 1 50 years old? 2 MR.IIIII I'm going to object once 3 again. We are getting way too argumentative 4 with the questioning. The questioning is 5 compound. It is speculative and it is also 6 harassing. Whether or not this deposition 7 video, thereof is played in front of a jury 8 is a question of fact, and it will be 9 determined by a judge pursuant to a motion 10 in limine, various portions thereof may or 11 may not be played, so having placed those 12 objections on the record I'm going to 13 instruct Mr. Epstein not to answer that 14 question. 15 MR. Mr. ■ I don't know if 16 you watched the 13 hours of harassing 17 questions to that she sometimes 18 invoked her Fifth Amendment rights, I 19 understand the adverse advice that would be 20 given and she was made to answer these 21 questions and these exact same questions 22 were asked of her, in fact, I'm using the 23 phraseology from Mr. I'm not • 24 trying to harass him. 25 Q I'm simply asking him to explain to the EFTA01723963 13 1 jury. If you're saying it didn't happen, if 2 you're saying it did happen, explain to the jury 3 why you did it. That's all I want to hear. I'm 4 being respectful about this. S MR. : In an effort to keep a clean 6 record be respectful to the to the court 7 reporter rather than having a diatribe back 8 and forth between you and myself, I'll move 9 to strike your last statement as 10 irrelevant. Let's move on. 11 Q Is it true, Mr. Epstein, you were born 12 January 20, 1953? 13 A Yes. 14 Q Where? 15 A New York. 16 Q Where in New York? 17 A Brooklyn. 18 Q Did you go to high school there? 19 A Yes, sir. 20 Q Where? 21 A Lafayette High School. 22 Q After high school did you attend 23 college? 24 A Yes. 25 Q Where was that? EFTA01723964 14 1 A New York. 2 Q What college did you attend? 3 A Cooper Union. 4 Q Sorry, I didn't hear. 5 A Cooper Union. 6 Q Did you get a degree from Cooper Union? 7 A No, sir. 8 Q How many years were you in college? 9 A I believe, two. 10 Q What did you study? 11 A Physics. 12 Q Why did you leave college early? 13 A I intend to respond to all relevant 14 questions regarding this lawsuit, however, at the 15 present time my attorneys have counseled me that 16 I cannot provide answers to questions that may be 17 relevant to this lawsuit, so accordingly I assert 18 my constitutional rights as guaranteed by the 19 Fifth, Sixth and Fourteenth Amendment. 20 Q Are you invoking your Fifth Amendment 21 rights as to why you left college, is it safe 22 then to presume that that answer you believe 23 would incriminate you in some way? 24 MR. I'm going to move to strike, 25 speculative, argumentative, harassing. EFTA01723965 15 1 Calls for a legal conclusion, and I know 2 exactly what you're trying to do here, Mr. 3 , is lace the record with questions 4 that would ultimately give you an adverse 5 inference at any potential trial of this 6 matter, so having put that on the record, 7 I'm going to instruct him not to answer that 8 question, based upon his Fifth, Sixth and 9 Fourteenth Amendment rights to the United 10 States Constitution. 11 MR. With all due respect you 12 cannot invoke his Fifth Amendment rights, 13 your attorneys instructed me in that fact -- 14 MR. He can. 15 MR. That Had to do it 16 herself, so, I would like to hear it from 17 Mr. Epstein. 18 Q Can we assume you're invoking your Fifth 19 Amendment rights as to why you left college 20 early, that that answer you feel would 21 incriminate you? 22 MR. -: Once again, move to strike 23 for the same reasons. 24 You can answer. 25 A I've already answered the question. EFTA01723966 16 I'll restate the answer. I would like to 2 respond, intend to respond, and would like to 3 respond to all questions today. However, counsel 4 has advised me I must take the Fifth, Sixth and 5 Fourteenth Amendment right under the U.S. 6 Constitution. 7 Q After college where were you employed? 8 A You know, I would like to respond to all 9 your questions today, however, on advice of 10 counsel, I intend to take the Fifth, Sixth and 11 Fourteenth Amendment rights provided by the 12 United States Constitution or risk losing my 13 counsel's representation. 14 Q Isn't it true that you were a teacher at 15 the Dalton School in New York after college? 16 A Again, I would like to respond to all 17 your questions; however, my attorneys have 18 counseled me that I cannot provide answers to any 19 questions today regarding to this lawsuit so I 20 must accept their advice or risk losing my Sixth 21 Amendment right to effective representation. 22 Accordingly, I assert my Constitutional rights as 23 guaranteed by the Fifth, Sixth and Fourteenth 24 Amendment of the constitution. 25 Q Mr. Epstein, did you have sex with any EFTA01723967 17 1 underage students while teaching at the Dalton 2 School? 3 A Could you repeat that? 4 Q Yes. Did you have sex with any underage 5 students while teaching at the Dalton School in 6 New York? 7 A Mr. your firm has been 8 described by the U.S. Attorney as one of the 9 largest -- as a criminal enterprise, perpetrating 10 one of the largest frauds in Florida's history. 11 It has been reported that your firm fabricated 12 multiple cases against me and others in order to 13 fleece unsuspecting investors out of millions and 14 millions of dollars. 15 Unfortunately at this time in response 16 to your question, my attorneys have advised me I 17 must assert my Fifth Amendment, Sixth Amendment 18 and Fourteenth Amendment rights, though I believe 19 you know I would like -- really like to answer 20 your questions but at this time I must assert 21 those rights or have my attorneys resign. 22 MR. Mr. I'll' I think you know 23 he has a couple of options here. He can 24 answer questions or he can invoke his Fifth 25 Amendment rights. This nonresponsive EFTA01723968 18 1 verbiage regarding the RRA law firm is not 2 one of the options, it's inappropriate in 3 the deposition and I would ask you to 4 instruct your client not to obstruct this 5 process any further. I am not going to 6 terminate the deposition. I want it to 7 finish, but obviously this is going to be 8 the subject matter of some motion in the 9 courts and you know the judges will not 10 appreciate this. I would like to just move 11 this process along by eliminating that 12 portion of his answer. I understand what he 13 is saying. I get it, but that's not 14 something responsive to any of the questions 15 and I think you know it is inappropriate. 16 MR. I M I think the deponent is 17 answering the questions. If you believe the 18 responses are inappropriate and feel'you can 19 take it up with the Court with the motion 20 you are speaking of, as you've done then you 21 can, as you've done several times before. 22 Q After leaving the Dalton School, is it 23 true that you began working as a money manager at 24 Bear Stearns? 25 A I intend to respond to all your EFTA01723969 19 1 questions regarding this lawsuit at some relevant 2 time, however, at the present time my attorneys 3 have counseled me that I cannot provide answers 4 to any questions relevant to this lawsuit. Since 5 the U.S. Attorney has described your law firm as 6 a criminal enterprise, Mr. and. a part of 7 the largest fraud in Florida's history, I am 8 going to assert my Sixth Amendment, Fifth 9 Amendment and Fourteenth Amendment rights to the 10 U.S. Constitution. 11 Q Isn't it true that while you were 12 working at Bear Stearns you were already engaging 13 in sex with underage minors? 14 A Again, I believe you know the answers to 15 those questions, but -- 16 Q Yes. 17 A .May I finish? 18 Q I do. 19 MR. : Move to strike. Let the 20 witness -- 21 Q Sure -- 22 MR. IIIII Let the witness answer your 23 question. 24 MR. I would love for him to 25 finish the questions. EFTA01723970 20 1 MR. Mr. as you know 2 there are serious Fifth, Sixth and. 3 Fourteenth Amendment constitutional rights 4 at issue here, and the witness is attempting 5 to answer your questions to the best of his 6 ability, despite how laced they are with 7 adverse inference presumptions. 8 MR. I don't want the adverse 9 inferences. I want the answers, that's it. 10 I don't want the adverse inferences. 11 MR. Having said that, please 12 allow the witness to answer to answer the 13 question. 14 A Can you please repeat the question? 15 Q Isn't it true while working at Bear 16 Stearns you were already engaging in sex with 17 underage minor females? 18 A As your firm has been described by the 19 U.S. Attorney, as a criminal enterprise, using 20 some of the cases fabricated against me, 21 personally, I would like to answer that question 22 today; however, upon advice of counsel I must 23 assert my Fifth, Sixth and Fourteenth Amendment 24 rights under the U.S. Constitution or, in fact, 25 risk losing their representation. EFTA01723971 21 1 Q At some point in time while at Bear 2 Stearns you met and managed the money for a 3 fellow named , correct? 4 A Again, I would like to answer all 5 questions relevant to this lawsuit, but today I 6 must assert my Fifth Amendment, Sixth Amendment 7 and Fourteenth Amendment right to the U.S. 8 Constitution. 9 Q In fact, I read in another deposition of 10 yours that you do not consider yourself to be 11 homosexual, correct? 12 A (No response.) 13 Q You've answered that question before, 14 correct? 15 A Correct. 16 0 Do you consider yourself to be 17 bisexual? 18 A No. 19 Q In any event, you did develop a sexual 20 relationship with at some point in 21 time; is that true? 22 A No. 23 0 Did you have a business relationship 24 with Mr.= 25 A I intend to respond to all relevant EFTA01723972 22 1 questions. I would like to answer most of your 2 questions, Mr. today, however, 3 especially since your firm has been described by 4 the United States Attorney in South Florida as a 5 criminal enterprise purported to -- purported to 6 have put -- pulled off the largest fraud in 7 Florida's history, I would like to answer it, 8 however, my attorneys here today counseled me I 9 must assert my Fifth, Sixth and Fourteenth 10 Amendthent right under the U.S. Constitution, 11 therefore I'm going to do that. 12 Q Are you saying because 13 was determined to be a criminal 14 enterprise or somebody was running a criminal 15 enterprise out of that law firm, that is the 16 reason why you are not going to answer these 17 questions today? You linked that together in 18 that answer. I just want to make sure I'm 19 understanding that right? 20 A I'm going to take the Fifth -- I intend 21 to respond to all relevant questions today. I 22 would like to respond; unfortunately my attorneys 23 have counseled me I can't, I must assert my 24 Fifth, Sixth and Fourteenth Amendment rights 25 under the U.S. Constitution. EFTA01723973 23 1 Q Because other law firms have asked very 2 similar questions and you haven't responded to 3 any of theirs either. I just want to understand 4 what the relationship between 5 is to you invoking your Fifth 6 Amendment rights today, if you can articulate 7 that for me. B MR. Form, compound, 9 argumentative. 10 A has been 11 described by the U.S. Attorney as a criminal 12 enterprise and as part of the largest fraud in 13 Florida's history. It has been reported that 14 your firm fabricated multiple cases using me, and 15 against me in order to fleece unsuspecting 16 investors out of millions of dollars. 17 Q Another long time friend of yours is 18 Ghislaine Maxwell, right? 19 A I intend to respond to all relevant 20 questions. I would like to answer most of these 21 questions today, but I can't because my attorneys 22 have counseled me that I cannot provide answers 23 to any questions relevant to this lawsuit. I 24 must accept their advice or risk losing my Sixth 25 Amendment right to effective representation. EFTA01723974 24 1 Therefore I'll assert my Constitutional 2 rights under the Fifth, Sixth and Fourteenth 3 Amendment. 4 THE WITNESS: Excuse me, could we take a 5 break? 6 MR. Already? 7 THE WITNESS: Restroom. 8 THE VIDEOGRAPHER: Going off the video 9 record 11:38 a.m. 10 THE WITNESS: Thank you. 11 (Pause in the proceedings.) 12 THE VIDEOGRAPHER: We're back on the 13 video record at 11:48 a.m. 14 Q How did you meet Ghislaine Maxwell? 15 A I intend to respond to all relevant 16 questions to this lawsuit; however, at the 17 present time my attorneys have counseled me that 18 I cannot provide answers to any questions 19 relevant to this lawsuit, and must accept this 20 advice or risk losing effective -- my right to 21 effective representation. Accordingly, 22 therefore, I assert my Fifth, Sixth and 23 Fourteenth Amendment rights to the U.S. 24 Constitution. 25 Q You would agree, would you not, that EFTA01723975 25 1 • Ghislaine Maxwell shares your sexual obsession 2 for underage minor females? 3 MR. ■: Argumentative, speculation, 4 harassing. S A You know, Mr. the current U.S. 6 Attorney has described your law firm as a 7 criminal enterprise, and as taking part in one of 8 the largest frauds in Florida's history. It has 9 been widely reported that your firm fabricated 10 multiple cases of a sexual nature against 11 people -- other people and me, in order to fleece 12 unsuspecting investors out of millions of 13 dollars, so unfortunately at this time in 14 response to your questions, my attorneys have 15 advised me I must assert my Sixth Amendment, 16 Fifth Amendment and Fourteenth Amendment rights, 17 though I believe, as you know, I would really 18 like to answer these questions, but at this 19 moment, although at this time I have to assert 20 those rights or risk losing effective counsel. 21 Q Do you know 22 A I intend to respond to all relevant 23 questions regarding this lawsuit; however, at the 24 present time my counsel has advised me that i 25 cannot provide answers to any questions relevant EFTA01723976 26 1 to this lawsuit. Your firm has been described as 2 a criminal enterprise, and is part of the largest 3 fraud in Florida's history fabricating sexual 4 cases against me and others. Therefore, 5 unfortunately, although I would like to answer 6 all of your questions today, I'm going to have:to 7 assert my Fifth, Sixth and Fourteenth Amendment 8 right. 9 Q Did you and Ghislaine Maxwell sexually 10 assault at 's house? 11 A I intend to respond to all relevant 12 questions regarding this lawsuit; however, at the 13 present time my attorneys have counseled me I 14 cannot provide answers to any questions relevant 15 to this lawsuit and must accept this right or 16 risk losing my Sixth Amendment rights to 17 effective presentation. Accordingly, I assert my 18 Constitutional rights as guaranteed by the Fifth, 19 Sixth and Fourteenth amendments to the U.S. 20 Constitution. 21 Q Stating Ghislaine Maxwell and you had 22 devised several schemes to lure underage girls to 23 you for sex; isn't that correct? 24 MR. Form, argumentative, 25 harassing? 7r EFTA01723977 27 1 A Mr. your firm has fabricated 2 multiple cases of sexual harassment claims and 3 other types of sexual cases against me and others 4 in order to be part of what the U.S. Attorney has 5 described as the largest fraud, the largest fraud 6 in Florida's history. I would like to answer all 7 your questions; however, my attorneys have 8 counseled me that at least today, I must assert 9 my Fifth, Sixth and Fourteenth Amendment rights 10 under the U.S. Constitution. 11 Q Do you own a home in Manhattan? 12 A I intend to respond to all relevant 13 questions to this lawsuit; however, at the 14 present time my attorneys have counseled me that 15 I cannot provide answers to any questions 16 relevant to this lawsuit, and I must accept their 17 advice or risk losing my Sixth Amendment right to 18 effective representation. 19 Accordingly, therefore, I have to assert 20 my Fifth, Sixth and Fourteenth Amendment right 21 under the U.S. Constitution. 22 Q Do you own an island in the U.S. Virgin 23 Islands? 24 A I intend to respond to all relevant 25 questions regarding this lawsuit; however, at the EFTA01723978 28 1 present time my attorneys have counseled me that 2 I cannot provide answers to any'questions 3 relevant to this lawsuit, no•matter how much I 4 would like to. 5 Therefore, I must accept their advice or 6 risk losing my Sixth Amendment right to effective 7 representation; therefore, I have to assert my 8 Fifth, Sixth and Fourteenth Amendment right under 9 the U.S. Constitution. 10 Q Do you own a home i•n New Mexico? 11 A I intend to respond to all relevant 12 questions regarding this lawsuit and as I've had 13 to do with most of your questions here today, I'm 14 going to have to take my attorneys' advice and 15 assert my Fifth, Sixth and Fourteenth Amendment 16 right under the U.S. Constitution or risk losing 17 effective representation. 18 Q Is it true that you have had underage 19 females, at each of those homes, for orgies with 20 you and Ghislaine Maxwell? 21 MR. : Form, argumentative, 22 speculation and harassing. 23 A I would like to answer that question. 24 really would. However, as your firm has been 25 described by the U.S. Attorney as a criminal EFTA01723979 29 1 enterprise, which its principal purpose was 2 racketeering conspiracy to generate money for the 3 firm and its co-conspiritors through the 4 operation of enterprise and through various 5 activities including mail fraud, wire fraud and 6 money laundering, and fabricating multiple sex 7 cases against me and others, though I would like 8 to answer your question today, Mr. my 9 counsel has advised me I must take the Fifth, 10 Sixth and Fourteenth Amendment right provided by 11 the U.S. Constitution. 12 Q Do you know somebody named 13 (phonetic)? 14 MR. PIKE: Can you spell that, for the 15 record? 16 MR. No. 17 MR. PIKE: Or for the court reporter? 18 A No. 19 Q You don't know the name? 20 A No. Could you spell it? 21 Q (Witness shrugs.) 22 A Okay. 23 Q Did your sexual obsession with underage 24 minor females grow at some point in time to allow 25 you access to these underage minors every single EFTA01723980 30 1 day for sex? 2 MR. : Overbroad. Speculation, 3 argumentative, compound, harassing and 4 confusing as well; as worded. Do you want 5 to break it down, Mr. 6 Q Isn't it true that for the past ten 7 years you have found a way to engage in sexual 8 conduct with underage minors on an every day 9 basis? 10 MR. Speculation. Argumentative. 11 A As your firm has been described as a 12 criminal enterprise by the United States Attorney 13 and is part of the scheme to defraud people in 14 South Florida of millions of dollars, you have 15 fabricated sexual cases and sexual claims against 16 people like me and others. Unfortunately at this 17 time although I would like to answer your 18 questions, Mr. my counsel has advised me 19 I cannot. They have advised me I must assert my 20 Fifth, Sixth and Fourteenth Amendment rights 21 under the U.S. Constitution. 22 Q Isn't it true that you have promised 23 underage minors money or other benefits to engage 24 in sexual conduct with you over the past ten 25 years? EFTA01723981 31 1 A Again, as. I've answered many of your 2 questions today, and unfortunately will probably 3 end up not answering most of your questions 4 today, as your firm has been described, the firm 5 bringing this lawsuit, I believe, if I'm wrong 6 please, correct me -- 7 Q You're wrong. 8 A This is the firm that didn't notice this 9 deposition? 10 Q Did not? 11 A Did not? 12 Q No. 13 A I apologize. Though your former firm 14 has been described, and the person you represent, 15 , in this case was represented by the firm 16 that was described by the U.S. Attorney as 17 perpetrating one of the largest frauds in South 18 Florida's history, fabricating multiple sexual 19 cases against me and others in order to fleece 20 unsuspecting investors out of millions and 21 millions of dollars, so though unfortunately, I 22 would like to answer each one of your questions 23 today, my counsel has advised me I must assert my 24 Sixth Amendment, Fourteenth Amendment and Fifth 25 Amendment right, though I believe you know, I EFTA01723982 7 - • 32 1 would like to answer those questions, though at 2 this moment I must assert those rights or risk 3 losing my attorneys. 4 5 6 Q Sure, let's test that answer. A Okay. Q Let's talk about Jane Doe 102, Jane Doe 7 102, , who was represented by 8 s firm, had nothing to do with 9 Rothstein, Rosenfeld, Adler. Do you know 10 A Who? 11 12 A Can you spell it? 13 Q Common spelling, like the 14 State -- 15 A Can you spell it for me, please? 16 17 A What's the last name, how is it 18 spelled? 19 Q I believe. 20 • A I intend to respond to all relevant 21 questions regarding this lawsuit; however, at the 22 present time my attorneys have counseled me that 23 I cannot provide answers to any questions that 24 may be relevant to this lawsuit and I must accept 25 this advice or risk losing my Sixth Amendment EFTA01723983 33 1 right to effective representation. Accordingly, 2 I assert my Constitutional rights as guaranteed 3 by the Fifth, Sixth and Fourteenth Amendment to 4 the Constitution. 5 Q Just for the record, I can only spell it 6 the way it was spelled in your flight logs from 7 your airplane. I don't know exactly how she 8 spells her name, only how your pilot would spell 9 her name. 10 MR. Form, speculating. 11 Q If I misspell it -- 12 MR. a Form, speculation, 13 argumentative, harassing. 14 MR. That's harassing? 15 MR. It assumes facts currently 16 not in evidence in this particular 17 deposition; therefore, I move to strike. 18 MR. I was responding to his 19 question asking me how to spell her name. I 20 don't know how other than his own pilot. 21 MR. Mr. he asked you to 22 spell the name, you then spelled the name, 23 then went on with another narrative and 24 there wasn't a question posed, on the floor. 25 Q You would agree you interacted with EFTA01723984 34 1 every day in a sexual way, when she was 15 years 2 old, right? 3 A Again, I'm sorry? 4 Q Sure. You would agree that you 5 interacted with sexually on an every day 6 basis when she was 15 years old? 7 A You know, again, Mr. I would 8 like to answer all your questions here today. My 9 attorneys have asked me -- advised me that I must 10 assert my Sixth Amendment, Fourteenth Amendment 11 and Fifth Amendment rights provided by the U.S. 12 Constitution and the fact that the current U.S. 13 Attorney has described your law firm as a 14 criminal enterprise, is one of the largest frauds 15 in Florida's history for fabricating sexual -- 16 cases of a sexual nature against me and others. 17 Unfortunately, although I would like to answer 18 those questions, if I do I risk losing my 19 attorneys' counsel. Therefore, I must assert my 20 right. 21 MR. Madam court reporter, I'll 22 attach as an exhibit, the Jane Doe number 23 102 versus Jeffrey Epstein complaint, at ' 24 some point in time. It will be Exhibit 1, 25 as I'm going to go through some of the facts EFTA01723985 35 1 as alleged in the complaint and as will be 2 testified to by the plaintiff. 3 (Jane Doe number 102 versus Jeffrey 4 Epstein complaint was deemed marked as 5 Exhibit number 1 for identification, as of 6 this date.) 7 MR. : Counsel, do you have an extra 8 copy of that for me? 9 MR. No. 10 MR. IIIII May I look at it real quick? 11 MR. No. It has my notes on 12 it. 13 MR. I understood, I saw the 14 highlights. 15 MR. The notes are highlighted 16 so when we copy it, it will not show up. 17 MR. ■: Just for the record, that's a 18 current, operative pleading, correct? 19 MR. Correct. 20 THE WITNESS: What does that mean? 21 MR.M There may have been some 22 amendments to a complaint and I want to make 23 sure that's the operative complaint at issue 24 that he is speaking of today. 25 THE WITNESS: Can I go off the record EFTA01723986 36 1 for a second? 2 May I ask you a question? 3 MR. Sure. Can we take a break 4 for a second? 5 MR. Again? 6 THE WITNESS: Just a question. 7 MR. He wants to speak with me for 8 a second. 9 THE VIDEOGRAPHER: Off the video record 10 12:01 p.m. 11 (Pause in the proceedings.) 12 THE VIDEOGRAPHER: We are back on the 13 video record at 12:02 p.m. 14 Q Is it true, Mr. Epstein, that you and 15 Ghislaine Maxwell forced to have sex with 16 you on a daily basis? 17 MR. Ill" Form, argumentative, 18 harassing. 19 A Unfortunately at this time, though I 20 would really like to answer those questions, and 21 like I have done for most of your questions here 22 today, Mr. your firm was described as a 23 criminal enterprise, a serious criminal 24 enterprise by the current U.S. Attorney. Part of 25 that criminal enterprise was fabricating cases of EFTA01723987 37 1 a sexual nature against me and others in order to 2 fleece unsuspecting investors out of millions of 3 dollars. Though, unfortunately at this time no 4 matter how I would like to respond to your 5 questions, I must assert my Sixth Amendment, 6 Fifth Amendment and Fourteenth Amendment rights 7 under the U.S. Constitution or risk having my 8 attorneys resign. 9 Q Isn't it true that was yours and 10 Ghislaine Maxwell's sex slave from the time she 11 was 15 through the time she escaped when she was 12 -.19? 13 MR. Again objection, 14 argumentative, harassing. 15 A Mr. your firm has been 16 described as excuse me, as a criminal 17 enterprise by the current U.S. Attorney and part 18 of the largest fraud in Florida's history. Part 19 of that fraud was fabricating multiple cases 20 against people like me and others, of a sexual 21 nature, in order to fleece unsuspecting investors 22 out of millions and millions of dollars, so 23 though I would like to answer that question, my 24 attorneys have told me today I mist assert my 25 Sixth Amendment, Fourteenth Amendment and Fifth EFTA01723988 • 38 Amendment right. 2 Q Isn't it true that you and Ghislaine 3 Maxwell celebrated her 16th birthday with her and 4 had sex with her on that day? 5 MR.M Form. Compound, confusing, 6 argumentative, harassing. 7 A Mr. I would like to answer that 8 question. My attorneys have told me today, I 9 have to at least today assert my Fifth Amendment, 10 Sixth Amendment and Fourteenth Amendment rights • 11 to the U.S. Constitution, especially my concern 12 is, that your firm has filed fraudulent lawsuits, 13 fabricated lawsuits, and the U.S. Attorney, the 14 current U.S. Attorney has described your firm as 15 a criminal enterprise that -- whose main purpose 16 was to generate money for the firm and its 17 co-conspirators through the operation of various 18 criminal activities, including mail fraud, wire 19 fraud and money laundering. 20 Q Are you saying that the complaint of 21 L.M. against you, the allegation in that 22 complaint, are false? 23 MR. Form. Misinterprets the 24 witness's testimony. 25 Q Or saying it is true? EFTA01723989 39 1 MR. Same objection. 2 Q It is either true or false? 3 A . I'll repeat myself, unfortunately, but 4 the current V.S. Attorney has described your law 5 firm that filed that filed L.M.'s claim -- was 6 involved in the filing of L.M.'s claim, 7 motions -- I'm sorry, do you want to tell me what 8 it was then? Would you like to tell me the 9 firm's involvement in this lawsuit, since we will 10 be here the rest of the, day? 11 Q Answer the question. 12 A All right. 13 The U.S. Attorney has described that 14 firm as a criminal enterprise perpetrating one of 15 the largest frauds in Florida's history against 16 unsuspecting investors, fleecing them out of 17 millions of dollars by creating, crafting and 18 fabricating fellacious (sic) sexual claims 19 against people like me and others, so 20 unfortunately, though I would like to answer your 21 questions, Mr. my counsel has advised me 22 that at least today I must assert my Sixth 23 Amendment, Fifth Amendment and Fourteenth 24 Amendment rights under the U.S. Constitution. 25 Q Isn't it true, sir, and I'm reading from EFTA01723990 40 1 the complaint filed billillagainst you, isn't it 2 true, sir, that a friend of yours sent you three, 3 12-year old females for you to sexually abuse on 4 one of your birthdays? 5 MR. Form, argumentative, 6 harassing, and irrelevant to this lawsuit. 7 THE WITNESS: Excuse me. 8 A You're saying it is part of the 9 lawsuit? 10 Q Yes, I'll read it. 11 "On one of the defendant Epstein's 12 birthdays, a friend of defendant Epstein sent him 13 three, 12-year old girls from France who spoke no 14 English for defendant to sexually exploit and 15 abuse? After doing so they were sent back to 16 France the next day." 17 Isn't that true? 18 MR. III. Once again, move to strike, 19 irrelevant, argumentative, harassing, and 20 for the record, the exhibit that's being 21 read from is a complaint that's unrelated to 22 the instant matter and not filed or 23 incorporated by the current plaintiff, L.M., 24 in this matter. 25 A I would like to answer that question, I • EFTA01723991 41 1 really would; however, today my attorneys have 2 told me I have to assert my Fifth Amendment, 3 Sixth Amendment and Fourteenth Amendment rights 4 of the U.S. Constitution, especially because your 5 firm involved in this lawsuit has fabricated, 6 widely reported, multiple cases of sexual 7 harassment cases against individuals like me and 8 others, perpetrating what the U.S. Attorney 9 called one of the largest frauds in Florida's 10 history, fleecing people out of millions of 11 dollars, so though I would like to answer that 12 question, today I have to assert those rights or 13 risk losing my attorneys' counsel. 14 Q Isn't it true that you forced as a 15 15-year old girl to have sex with numerous 16 friends of yours? 17 A Are you kidding? 18 Q Reading from a lawsuit. 19 A Sorry, Mr. Though I would like 20 to answer that question as well, as I've answered 21 most of your other questions here today, I would 22 like to respond; however, my attorneys here today 23 have advised me I have to assert my Fifth 24 Amendment, Sixth Amendment and Fourteenth 25 Amendment rights under the U.S. Constitution, EFTA01723992 42 1 especially as your firm has been accused by the 2 U.S. Attorney as being a criminal enterprise, and 3 part of the largest fraud in Florida's history. 4 Basically -- sorry, if I didn't read correctly, 5 the operation of the enterprise through 6 various criminal activities including mail fraud, 7 wire fraud and money laundering, fabricating 8 sexual harassment cases against people like me 9 and others. 10 Q By the way -- 11 A Yes, sir? 12 Q -- didn't receive a round trip 13 ticket paid for by you to Thailand, and she 14 ultimately did not get back on the plane but 15 instead escaped to Australia? 16 A I would like to answer that question, 17 but today I would have to assert my Sixth 18 Amendment rights, my Fifth Amendment rights and 19 my Fourteenth Amendment rights under the U.S. 20 Constitution, especially since your firm has been 21 described as perpetrating one of the largest 22 frauds in Florida's history, fleecing investors 23 out of millions of dollars, being described by 24 the U.S. Attorney of South Florida, as a criminal 25 enterprise engaged in various criminal activities EFTA01723993 43 1 including mail fraud, wire fraud and money 2 laundering. 3 Q Do you know a man named. Jean Luc 4 Brunel? 5 A Can you spell it? 6 Q He was at your house last week, does 7 that remind you? 8 MR. Form, move to strike, 9 speculation, argumentative, harassing. 10 Is there a question on the table, Mr. 11 12 MR. Yes. 13 Q Do you know him? 14 A Can you spell his name for me, please? 15 Q I don't need to spell his name Do you 16 know who I'm talking about, Mr. Brunel? 17 A Sorry, Mr. what? 18 Q B-r-u-n-e-l. 19 A I would like to answer that question as 20 well, but my attorneys have counseled me today I 21 have to assert my Sixth Amendment rights, Fifth 22 Amendment rights and Fourteenth Amendment rights 23 under the U.S. Constitution or risk losing my 24 right to effective representation. 25 Q What's the purpose for you asking me to EFTA01723994 44 1 spell his name? Are you acting like you don't 2 know him? 3 MR. : Form, move to strike, 4 argumentative and irrelevant as worded. 5 Mr. you know that there are 6 various standing orders, if not in this 7 case, in various other cases, that 8 specifically describe the protections of the 9 Fifth Amendment. Federal Courts have 10 ordered that certain questions that you are 11 asking shall not be answered or Mr. Epstein 12 would risk losing his Fifth Amendment 13 right -- 14 MR. I understand that. He is 15 asking to spell people's names. 16 MR. -- under the United States 17 Constitution. A lot of these questions here 18 today that you're asking have already been 19 ruled on by various Courts, that the Fifth 20 Amendment protects any response thereto, so 21 I would like -- I'm giving you some leeway 22 here with regard to the argumentative 23 questions. We've already -- and I'm not 24 obviously testifying for the witness, but 25 we've already handled a lot of these issues EFTA01723995 45 1 in court and we have already adjourned one 2 deposition for being argumentative, and I 3 think you understand what the Court said 4 there, so having said that, and I understand 5 that you have a job to do, but having said 6 that, I would like to caution you 7 professionally, if you continue with the 8 argumentative questions, I am going to have 9 to terminate this deposition -- 10 MR. I completely understand. 11 MR. Okay. We are here today 12 to -- 13 MR. Mr. Brunel -- 14 MR. I want the Court to know we 15 are here today to allow you to ask your 16 questions, but the harassing and 17 argumentative tone is not going to be 18 tolerated. 19 MR. We have a video. We can 20 show the Court the tone. It is obviously 21 not harassing. 22 MR. That's fine. 23 Q Mr. is a long-term friend of 24 yours, right? 25 A I intend to respond to all relevant I 4. EFTA01723996 46 1 questions of this lawsuit; however, today my 2 attorneys have counseled me I cannot provide , 3 answers to any questions that may be relevant to 4 this lawsuit and I must accept their advice or 5 risk losing my Sixth Amendment right to effective 6 representation. 7 Q You know him as somebody who has been 8 caught engaging in sex with underage minors in 9 the past; is that correct? 10 MR. Form. 11 A You will have to repeat the question, 12 I'm sorry. 13 Q You know Mr. as somebody who has 14 been caught engaging in sex with minors in the 15 past; is that correct? 16 MR. Form. 17 A I intend to respond to all relevant 18 questions regarding this lawsuit; however, at the 19 present time my attorneys have counseled me that 20 I cannot provide answers to any questions 21 relevant to this lawsuit, and I must accept their 22 advice or risk losing my Sixth Amendment right to 23 effective representation as your firm has been 24 described by the U.S. Attorney as a criminal 25 enterprise and part of one of the largest frauds EFTA01723997 47 1 in Florida's history specifically said you have 2 been fabricating -- the law firm has been 3 fabricating multiple cases of a sexual nature in 4 order to fleece unsuspecting investors out of 5 millions of dollars, including mail fraud, wire 6 fraud and money laundering, so unfortunately, 7 though I would like to answer all your questions 8 here today, I must assert my Sixth Amendment, 9 Fourteenth Amendment and Fifth Amendment right. 10 Q You were involved in a modeling business 11 with him called is that correct? 12 A Again? 13 Q You were involved in a modeling agency 14 with -- 15 A What do you mean -- 16 Q -- with Mr. called 17 A "Involved" means what, what do you 18 mean? 19 Q You tell the jury your involvement with 20 the modeling agency. You can clarify for me, 21 I'll let you do that. 22 MR. : Object to the form. 23 A I intend to respond to all relevant 24 questions regarding this lawsuit. However, at 25 the present time my attorneys have counseled me EFTA01723998 48 1 that I cannot provide answers to any questions 2 relevant to this lawsuit and I must accept their 3 advice or risk losing my Fifth, Sixth and 4 Fourteenth Amendment rights under the U.S. 5 Constitution. 6 Q When you were being criminally 7 investigated and was in Australia, is it 8 true that you made a personal telephone call to 9 her telling her not to come forward with any of 10 the information she knew? 11 MR. I= Form. 12 A Again? 13 Q Putting a time frame on it, the time 14 frame where you were being criminally 15 investigated -- 16 A What time frame is that? 17 Q In her complaint it is not specific, 18 but, let's just make it whenever. At some point 19 in time did you place a telephone call to in 20 Australia warning her not to come forward with 21 any information about you engaging in sex with 22 her while she was a minor? 23 MR. Form. 24 A I intend to respond to all relevant 25 questions regarding this lawsuit; however, at the EFTA01723999 49 1 present time my attorneys have counseled me that 2 I cannot provide answers to any questions 3 relevant to this lawsuit and I must accept their 4 advice or risk losing my Sixth Amendment right to 5 effective representation. 6 Q With respect to underage females, isn't 7 it true that you have made the statement, in 8 quotes, "the younger the better"? 9 MR. Form. 10 A Again, as your firm has been described 11 by the current U.S. Attorney as a criminal 12 enterprise involved in mail fraud, wire fraud, 13 money laundering, and specifically crafting, 14 fabricating multiple cases of sexual -- of a 15 sexual nature against people like me, and others, 16 in order to fleece many, many unsuspecting 17 investors out of millions of dollars; I would 18 like to answer your questions here today, Mr. 19 but unfortunately, my attorneys have 20 counseled me that I must assert my Fifth, Sixth 21 and Fourteenth Amendment right or they will 22 resign. 23 Q Who are your current employees? 24 MR. IIIII Form. 25 A Say that again. EFTA01724000 50 1 Q ' Who are your current employees, people 2 who work for you, that•you pay? 3 A I intend to r'espond to all relevant 4 questions regarding this lawsuit; however, at the present time my attorneys have counseled me that 6 I cannot provide answers to any questions that 7 may be relevant to this lawsuit, or risk losing 8 my Sixth Amendment right to effective 9 representation. Accordingly, therefore, I must 10 assert my Sixth Amendment, Sixth Amendment and 11 Fourteenth Amendment rights as provided by the 12 U.S. Constitution. 13 Q Isn't it true you pay your employees to 14 bring you underage minor females for sex? 15 MR. Form, argumentative, 16 speculation, harassing. 17 A Mr. your firm has been 18 described the current U.S. Attorney as a criminal 19 enterprise, a criminal enterprise, part of the 20 largest fraud in South- Florida's history; but 21 part of that fraud was fabricating, um, 22 fictitious cases against me excuse me, against 23 people like me, of a sexual nature, in order to 24 fleece unsuspecting investors out of millions of 25 dollars. EFTA01724001 51 1 Unfortunately at this time, though, I 2 would like to answer every one of your 3 questions. My attorney has advised me I must 4 assert my Sixth Amendment, Fourteenth Amendment 5 and Fifth Amendment rights or risk losing them as 6 my attorneys. 7 Q Isn't it true when underage• females were 8 brought to you, you would engage in sex with them 9 and pay them? 10 MR. Form, argumentative, 11 harassing. 12 A (Witness shakes head.) 13 Q Are you shaking your head to say "no" -- 14 A Excuse me. 15 Q Are you shaking your head to say "no, I 16 don't know how to interpret that answer?" 17 A I didn't realize I was shaking my head. 18 MR. I thought he was actually 19 answering a question. 20 MR. We'll just strike. The rules 21 are well-known to every lawyer who practices 22 in the State of Florida, that it is clear 23 that a nod of the head or shake of the head 24 is not understood by the record, so 25 therefore Mr. Epstein was clearly not EFTA01724002 52 1 responding to one of your questions and you 2 know that, Mr. 3 MR. This is on the video. 4 MR.IIIII Nonetheless you know the 5 rules. Nonetheless. If we have a question 6 on the table, would you please repeat it so 7 I can recall it and Mr. Epstein can endeavor 8 to answer it. 9 MR. Sure, and if it was only 10 the court reporter, I would agree, but the 11 jury is going to see a video and everybody 12 knows commonly, if somebody shakes their 13 head, they are saying "no," and if that was 14 the answer, I wanted to give him a chance to 15 elaborate on it, that's it. 16 Q Isn't it true that when tnderage females 17 would come to your house, you would engage in 18 sexual activity with them and then pay them? 19 MR. Same objections. 20 A Unfortunately I would like to answer 21 that question today, but my attorneys have 22 counseled me that I must assert my Sixth 23 Amendment right, my Fifth Amendment right and my 24 Fourteenth Amendment right under the U.S. 25 Constitution. EFTA01724003 53 1 The fact that your firm has been 2 described as a criminal enterprise and part of 3 one of the largest frauds in Florida's -- South 4 Florida's history, part of that fraud has been 5 described as fabricating cases of sexual nature 6 against me and others in order to fleece 7 unsuspecting investors out of millions of 8 dollars. I would like to answer that question, 9 Mr. however, today, I must assert my 10 Fifth, Sixth and Fourteenth Amendment right. 11 '0 In addition to paying these underage 12 females for sexual activity, you also paid them 13 to bring their underage friends to you, to also 14 engage in sexual activity with them? 15 MR. NM Form. 16 Q Is that correct? 17 A I intend to respond to all relevant 18 questions regarding this lawsuit; however, at the 19 present time my attorneys have counseled me that 20 I may not, and I must assert -- they have advised 21 me I must assert my Sixth Amendment right, my 22 Fifth Amendment right and my Fourteenth Amendment 23 rights under the U.S. Constitution. 24 Q You would pay underage females 200 to 25 $300 for engaging in sexual activity with you or EFTA01724004 54 1 for procuring another underage female to engage 2 in sexual activity with you; is that correct? 3 MR. : Form, move to strike. 4 Assumes facts not in evidence and calls for 5 a legal conclusion as well, argumentative. 6 A I intend to respond to all relevant 7 questions regarding this lawsuit; however, at the 8 present time my attorneys have counseled me that 9 I cannot provide answers to any questions that 10 may be relevant to this lawsuit, and I must 11 accept their advice or risk losing my Sixth 12 Amendment right to effective representation. 13 Accordingly, therefore, I must assert my 14 constitutional rights as guaranteed by the Fifth, 15 Sixth and Fourteenth Amendment to the U.S. • 16 Constitution. 17 Q Would you agree that your scheme was 18 devised to coerce these underage minors to bring 19 you as many other underage minors, as were 20 available for you to engage in sexual activity 21 with? 22 MR. Form. 23 A Can you repeat the question? 24 Q Yes. Would you agree that your scheme 25 was devised to coerce underage girls into EFTA01724005 55 1 bringing as many other underage girls to you, as 2 were available for sexual purposes? 3 MR. : Form. 4 A Did you say "for sexual purposes"? 5 Q Yes, for sexual purposes. 6 A I'm not surprised. Since your firm was 7 described as perpetrating one of the largest 8 frauds in Florida's history by crafting, 9 fabricated sexual harassment cases against people 10 like me and others in order to fleece 11 unsuspecting investors out of millions of 12 dollars, I would like to answer that question. 13 However, today my attorneys have advised me I 14 must assert my Sixth Amendment, Fifth Amendment 15 and Fourteenth Amendment right under the U.S. 16 Constitution, and if I don't do so, I risk 17 losing -- uh... losing effective representation. 18 Q Utilizing this method of using underage 19 minors to bring you other underage minors, you 20 were able to engage in sex with hundreds of 21 underage minor females. Is that true? 22 MR. IM Form, argumentative, 23 harassing and calls for speculation. 24 A Since, Mr. your firm has been 25 described as a criminal enterprise by the U.S. EFTA01724006 56 1 Attorney, and as part of the largest fraud in. 2 South Florida's history, and as part of the fraud 3 fabricating malicious cases of sexual harassment 4 and other cases of sexual nature against people 5 like me and others, although I would like to 6 answer that question today, my attorneys have 7 advised me I must assert my Sixth Amendment, 8 Fourteenth Amendment and Fifth Amendment rights 9 of the U.S. Constitution. Although I believe you 10 know I would really like to answer your 11 questions, but at this moment if I don't assert 12 those rights, I risk having my attorneys resign. 13 Q Isn't it true with this method you were 14 able to interact sexually with underage girls 15 every single day? 16 MR. Form, asked and answered. 17 Same objections. 18 Q Go ahead. 19 A Oh, I'm sorry. Can you repeat it? 20 Q Sure. With this method of -- 21 A "This method" being what, sorry? 22 Q Your method of using underage minors to 23 bring you other underage minors for sex; isn't it 24 true that that method resulted in you engaging in 25 sexual activity with underage minors on an every EFTA01724007 57 1 day basis? 2 MR. Same objections. 3 A Your firm has been described by the 4 current U.S. Attorney as a criminal enterprise 5 engaged in one of the largest frauds in South 6 Florida's history, and as part of that fraud, 7 creating, fabricating, malicious cases of sexual 8 nature against people like me and others, so • 9 unfortunately, though I would like to answer that 10 question today, I must assert my Sixth Amendment, 11 Fourteenth Amendment and Fifth Amendment rights 12 to my counsel's advisement to do, although I 13 believe yop know I would really like to answer 14 those questions today, I must assert those rights 15 or risk losing my attorney's representation. 16 Q To keep track of all these underage 17 minors, you stored their names and telephone 18 numbers in your home computer; isn't that 19 correct? 20 MR. la Form, argumentative, 21 speculation. 22 A Again? Sorry. 23 Q Are you going to answer the question or 24 just read? If you are going to answer the 25 question, of course, I'll keep reading it as many EFTA01724008 58 1 times. 2 A Excuse me? 3 MR. The witness is attempting to 4 answer your question. He asked you to 5 repeat the question. 6 MR. He is? 7 MR. He asked you to repeat the 8 question. 9 MR. I don't mind going through 10 that, III. because I do want answers, but 11 if I'm going to repeat the question multiple 12 times and get the same answer, we are 13 wasting time. I want to stop us wasting 14 time repeating questions if I'm getting the 15 same nonresponsive answer. 16 MR. I understand your intention 17 here. 18 MR. Yeah. 19 MR. IIIII -- however, these questions 20 are similar in nature, if not identical to 21 various questions that you've asked in other 22 indications, so you coming here today is of 23 no surprise that Mr. Epstein is required to 24 invoke his Fifth, Sixth and Fourteenth 25 Amendment rights under the United States EFTA01724009 59 1 Constitution -- 2 MR. I understand that. 3 MR. : -- if you came here today 4 thinking you were going to pull a rabbit out 5 of a habit, and Mr. Epstein was going to 6 waive his Fifth, Sixth and Fourteenth 7 Amendment rights to the U.S. Constitution, 8 at least not today. That will not be 9 occurring. 10 Q Isn't it true that to keep track of the 11 names and phone numbers of these underage minor 12 females, to interact with sexually, you stored 13 those names and phone numbers in your home 14 computer? 15 A Thank you. I've heard the question 16 now. It didn't surprise -- again, I've now heard 17 the question and the fact that your firm has been 18 described as a criminal enterprise by the current 19 U.S. Attorney in South Florida, and part of one 20 of the largest frauds in Florida's history, it is 21 reported that your firm fabricated malicious 22 cases of a sexual nature against people and 23 against me, in order to fleece unsuspecting 24 investors out of millions of dollars. 25 Unfortunately, though I would like to EFTA01724010 60 1 answer each one of your questions today, Mr. 2 my attorneys have advised me that I must 3 assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. 5 Constitution. So although I would like to 6 answer, I must assert those rights or risk having 7 my attorneys resign. 8 Q Do you know 9 A I intend to respond to all relevant 10 questions regarding this lawsuit; however, at the 11 present time my attorneys have counseled me that 12 I cannot provide answers to any questions 13 relevant to this lawsuit and must accept their 14 advice or risk losing my Sixth Amendment right to 15 effective representation. 16 Q Isn't it true you employed 17 to contact underage minor females and make them 18 appointments to be at your house? 19 A Sorry, again? 20 Q Isn't it true you employed 21 for the purposes of contacting underage minor 22 females and scheduling them appointments to be at 23 your house? 24 A The current U.S. Attorney has described 25 your law firm, Mr. as a criminal EFTA01724011 61 1 enterprise engaged in one of the largest frauds 2 in South Florida's history. It has been reported 3 that your firm fabricated multiple cases of a 4 sexual nature against me and others, in order to 5 fleece unsuspecting investors out of millions and 6 millions of dollars, so, though unfortunately 7 would like to answer every one of your questions 8 today my attorneys have counseled me that today I 9 must assert my Sixth Amendment, Fifth Amendment 10 and Fourteenth Amendment rights under the U.S. 11 Constitution. Though I believe you know I would 12 like to answer those questions, although today I 13 must assert those rights or risk having my 14 attorneys resign. 15 Q Tell the jury how you know 16 17 MR. Form move to strike. 18 MR. Move to strike my 19 question? 20 MR. (Nods.) 21 MR. What basis? 22 ** MR. Do I have to state a 23 basis? Usually I'm just required to state 24 "form." 25 MR. You have done more than EFTA01724012 62 1 that today. 2 MR. If I went on a diatribe of 3 explaining, you know, what's confusing, 4 compound and relevant, then you would blame 5 for testifying for the witness. So I just 6 move to strike the question. 7 MR. Make sure you mark that 8 somewhere on this transcript, somehow. 9 Q Tell the jury how you know 10 11 MR. : Move to strike. 12 A I intend to respond to all relevant 13 questions regarding this lawsuit. However, at 14 the present time my attorneys have counseled me 15 that I cannot provide answers to any questions 16 relevant to this lawsuit and must accept their 17 advice or risk losing my Sixth Amendment right to 18 effective representation. Accordingly, I assert 19 my Fifth Amendment, Sixth Amendment and 20 Fourteenth Amendment right under the U.S. 21 Constitution. 22 Q Isn't it true that you brought her to 23 this country when she was underage and made her 24 your sex slave, and you've bragged about this? 25 MR. Form, argumentative, EFTA01724013 63 1 compound, harassing and calls for 2 speculation. 3 A I intend to respond to all relevant 4 questions regarding this lawsuit; however, at the 5 present time my attorneys have counseled me that 6 I cannot provide answers to any questions 7 relative to this lawsuit and I must accept this 8 advice or risk losing my Sixth Amendment right to 9 effective representation. However, I would like, 10 so I'm clear, the question was, did I bring her 11 here? Specifically -- 12 Q Your answer is fine. 13 A Okay. 14 Q Is it true that you demanded numerous 15 underage minor females to have sex with 16 inside your home while you watched, 17 masturbating? 18 MR. : Same objections. 19 A You have to repeat the question. 20 Q Isn't it true that you have ordered 21 several underage minor females to have sex with 22 in your home while you watched, 23 masturbating? 24 MR. Same objections. 25 A The current U.S. Attorney has described EFTA01724014 64 1 your firm, Mr. as a criminal enterprise 2 involved in mail fraud, wire fraud, money 3 laundering and, in fact, fabricating multiple 4 cases of a sexual nature against me, others, in 5 order to fleece unsuspecting investors in South 6 Florida out of millions and millions of dollars. 7 Unfortunately, though I would like to 8 answer each one of your questions here today, my 9 attorneys have advised me I must assert my Sixth 10 Amendment, Fourteenth Amendment and Fifth 11 Amendment right under the U.S. Constitution, 12 although I believe you know I would like to 13 answer your questions, but at this moment I must 14 assert those rights or risk having my attorneys 15 resign. 16 Q Isn't it true that with each of these 17 underage minor females that were brought to your 18 house, your method of sexually exploiting them 19 was nearly identical; is that correct? 20 MR. III. Objection, argumentative, 21 confusing, overbroad and vague. 22 A I don't even understand the question. 23 Q Okay. When a 14 or 15-year old would be 24 led into your bedroom, you would appear from the 25 shower first, usually naked; is that correct? EFTA01724015 65 1 MR. : Objection, argumentative, 2 assumes facts not in evidence, and 3 harassing. 4 A I intend to respond to all relevant 5 questions regarding this lawsuit; however, today 6 my attorneys have advised me that I cannot 7 provide answers to any questions relevant to this 8 lawsuit and must accept their advice or risk 9 losing my Sixth Amendment right to effective 10 representation. Accordingly, therefore, I must 11 assert my Constitutional rights the Fifth 12 Amendment, Sixth Amendment and Fourteenth 13 Amendments to the U.S. Constitution. 14 MR. Can we go off the record for 15 a second? 16 MR. If it is necessary. 17 MR. Yes, let's go off the 18 record. 19 THE VIDEOGRAPHER: Going off the video 20 record at 12:35 p.m. 21 (Pause in the proceedings.) 22 THE VIDEOGRAPHER: Back on the video 23 record 12:44 p.m. 24 MR. Can you tell me what my 25 last question is? EFTA01724016 66 1 2 3 THE COURT REPORTER: Certainly. (The record was read.) Q After appearing from the shower naked, 4 you would order the underage minor female to 5 disrobe; isn't that true? 6 MR. Same objections. Form. 7 A I intend to respond to all relevant 8 questions regarding this lawsuit; however, at the 9 present time my attorneys, have counseled me I 10 cannot provide answers to any questions relevant 11 to this lawsuit and must accept their advice or 12 risk losing my Sixth Amendment right to effective 13 representation. 14 Q You would then order them to, or order 15 her to begin providing you a massage; is that 16 correct? 17 MR. : Form. 18 A I intend to respond to all relevant 19 questions regarding this lawsuit and I would like 20 to answer each and every one of ycur questions 21 today, Mr. however, my attorneys have 22 told me that I cannot do that today unless and I 23 must assert my Sixth Amendment, Fifth Amendment 24 and Fourteenth Amendment rights under the U.S: 25 Constitution or risk losing my counsel. EFTA01724017 67 1 Therefore, I'm going to assert those rights as 2 guaranteed by the Fifth Amendment, Sixth 3 Amendment and Fourteenth Amendment. 4 Q You would then roll over and continue 5 with masturbating; is that correct? 6 MR. 'III: Form. 7 A I intend to respond to all relevant 8 questions regarding this lawsuit. It is -- it is 9 my understanding that the current U.S. Attorney 10 has described your law firm as a criminal 11 enterprise, yours and Mr. firm, as a 12 criminal enterprise and part of the largest fraud 13 in Florida's history, fabricating malicious cases 14 of a sexual nature against me and others, in 15 order to fleece investors out of millions of 16 dollars, through bogus schemes including 17 conspiracy to -- excuse me -- to commit mail 18 fraud, wire fraud and money laundering, so though 19 I would like to answer each and every one of your 20 questions here today, my attorneys have counseled 21 me I cannot, and must assert my Fifth, Sixth and 22 Fourteenth Amendment rights under the U.S. 23 Constitution. 24 Q You would then rub the underage minor 25 female's vagina and/or insert your fingers into EFTA01724018 68 1 her vagina; is that correct? 2 MR. I= Form. 3 A I intend to respond to all relevant 4 questions regarding this lawsuit. Unfortunately, 5 today' my attorneys have advised me I cannot, must 6 assert my rights under the U.S. Constitution, 7 under the Fifth Amendment and Shah amendment and 8 Fourteenth amendments of the U.S. Constitution, 9 especially since your firm has been desCribed as 10 a criminal enterprise by the current U.S. 11 Attorney perpetrating one of the largest frauds 12 in South Florida's history, fleecing investors 13 out of millions of dollars by fabricating 14 malicious cases, malicious cases of a sexual 15 nature against people like me and others. 16 Q With many of these underage minors you 17 would use vibrators on them; is that correct? 18 MR. : Form. 19 A I would like to respond to that question 20 as I would like to respond to all your other 21 questions today. However, my attorneys have 22 counseled me that I must assert my Sixth 23 Amendment rights, my Fifth Amendment rights and 24 my Fourteenth Amendment rights under the U.S. 25 Constitution. EFTA01724019 1 Q And with many of these underage minors, 2 you would give and/or receive oral sex from them; 3 is that correct? 4 MR. IIII/ Form. 5 A I intend to respond to all relevant 6 questions regarding this lawsuit, and I would 7 like to answer each and every one of your 8 questions; however, my attorneys have counseled 9 me that today I must assert my Sixth Amendment, 10 Fifth Amendment and Fourteenth Amendment rights 11 under the U.S. Constitution, especially since 12 your firm has been described by the current U.S. 13 Attorney as perpetrating one of the largest 14 frauds in Florida -- in Florida's history, by 15 fabricating malicious cases of a sexual nature 16 against me and others. 17 Q In June of 2008 you pled guilty to a 18 couple of felonies, right? 19 MR. Form, vague and confusing. 20 A Again? 21 Q In June of 2008, you pled guilty to two 22 felonies; is that correct? 23 MR. Same objection. 24 A Yes. 25 Q And what were those felonies that you 691 EFTA01724020 70 1 pled guilty to? 2 A Solicitation of prostitutes, not 3 underage prostitutes but simply prostitutes. 4 Solicitation of prostitutes and one count of 5 procuring a minor for underage sex. 6 Q You have taken the Fifth as to questions 7 related to many of these underage minors, but the 8 underage minors that were the victims in the 9 cases where you pled guilty, were -; is that 10 one of them? 11 MR.M Form, mischaracterizes the 12 witness's testimony. Calls for a legal 13 conclusion? 14 A Again. 15 Q What was the name of the any of the 16 underage minors that were the subject of the 17 criminal charges to which you pled guilty? • 18 A I don't know. 19 Q So, tell me about those charges. What 20 were the allegations of those charges? 21 MR. •Form. 22 A Solicitation of prostitution, not 23 underage prostitution... Prostitution. 24 Q Were the victims or the prostitutes, as 25 you would say, were they minors? EFTA01724021 71 1 MR. Form. 2 A I pled guilty to solicitation of 3 prostitution. 4 Q Okay, so tell me what those cases were 5 about. What happened? 6 MR. Form again. 7 A (Witness shrugs.) I can't tell you 8 any more than that. 9 Q You don't know what you pled guilty to? 10 A I just told you 11 MR. Object to the form, asked and 12 answered. 13 0 Do you know what you pled guilty to, the 14 facts? 15 A Solicitation of prostitution. 16 Q I understand that that's the charge. 17 What were the underlying facts? What did you do, 18 did you pull up in a car, talk to the person, did 19 they come over to your house, how did you get 20 them, those kinds of things. Tell the jury what 21 were the underlying facts about the charges you 22 pled guilty to? 23 MR. Object to the form. Move to 24 strike. 25 A I don't know. EFTA01724022 72 1 Q You don't know what you pled guilty to? 2 A I pled guilty to solicitation of 3 prostitution, not underage prostitution, but 4 prostitution. 5 Q My understanding from reading the court 6 files that one of these females was Do you 7 know who that is? 8 A I intend to respond to all relevant 9 questions in this lawsuit. However, at the 10 present time my attorneys have counseled me that 11 I cannot provide answers to any of these 12 questions today. So accordingly, I must assert 13 my constitutional rights under the Fifth, Sixth 14 and Fourteenth Amendments of the U.S. 15 Constitution. 16 Q You're aware is somebody that 17 alleges she was at your house on more than 100 18 occasions; is that true? 19 MR. : Form. 20 A Can you repeat the question, sir? 21 Q Are you aware that is a female that 22 alleges that when she was underage, she was at 23 your house on more than 100 occasions? 24 MR. IIII/ Form, predicate. 25 A I intend to respond to all relevant EFTA01724023 73 1 questions to this lawsuit, Mr. However, 2 today my attorneys have counseled me that I must 3 respond by invoking my Fifth Amendment right, my 4 Sixth Amendment right and my Fourteenth Amendment S right under the U.S. Constitution or risk losing 6 them as my attorneys, so therefore I must assert 7 those rights. 8 Q You understand that her complaint was 9 that Epstein turned II 10 11 ■ 12 13 14 15 16 Are you aware of those allegations? 17 MR. I M Form, predicate. 18 A I'm sorry, did you say there is a 19 complaint? 20 Q In the incident report that led to a 21 charging document, that led to a charge that you 22 have pled guilty to. Are you aware of that 23 information coming from 24 MR. : I'm sorry, Mr. what 25 are you reading from? EFTA01724024 74 1 ' MR. The 87-page Palm Beach 2 Police Department incident report where 3 there are numerous underage females 4 describing their interaction with Mr. 5 Epstein at his house. I'm reading 6 specifically from page 41 related to ■ 7 who was one of the victims he pled guilty 8 to. 9 MR' Ill" Is that the same document 10 that you're seeking production.pf, in this 11 same exact case? 12 MR. I don't know what you're 13 talking about. This is something from the 14 State Attorney's file. 15 MR. : :Okay. Sorry. What's the 16 question? 17 Q Are you aware of that allegation? What 18 I just read to you. 19 A I would like to answer that question, 20 but, however, today my attorneys have advised me 21 I must assert my Fifth Amendment, Sixth Amendment 22 and Fourteenth Amendment rights under the U.S. 23 Constitution. 24 Q Assuming your attorneys have advised you 25 but because of III , double jeopardy, you EFTA01724025 75 1 cannot be charged for any crimes that you have 2 already pled guilty to relating to , so I 3 would like you to explain to the jury, in your 4 words, or your version of the story, what was 5 your interaction with at your house when she 6 was a minor? 7 MR. Object to the form as 8 worded. Could disclose.attorney/client 9 communications. 10 A I intend to respond to all relevant 11 questions regarding this lawsuit. I would like 12 to answer each of your questions today, however, 13 my attorneys have counseled me that I may not. 14 They've advised me that I must assert my Fifth 15 Amendment, Sixth Amendment and Fourteenth 16 Amendment rights under the U.S. Constitution. 17 Therefore, if I don't, I risk losing their 18 counsel. Therefore, I must assert those rights 19 here today, Mr. 20 Q Are you aware that Advised police 21 that she was 22 23 24 25 MR. Objection, relevance, EFTA01724026 76 1 argumentative, compound, harassing. 2 A This was who? 3 Q The question is, are you aware 4 A 5 The current U.S. Attorney, since he has 6 described your firm as a criminal enterprise and 7 part of one of the largest frauds in Florida's $ history by fabricating, fabricating, malicious 9 cases of a sexual nature against people like Me 10 and others, and fleecing investors out of 11 millions of dollars by using means described in 12 the complaint against your firm, including mail 13 fraud, wire fraud, money laundering; I'm afraid 14 today, though I would like to answer each one of 15 your questions, my attorneys have counseled me 16 that I must not, I must assert my Sixth 17 Amendment, Fifth Amendment and Fourteenth 18 Amendment rights under the U.S. Constitution, and 19 I believe you know I would like to answer those 20 questions. I must assert those rights or risk 21 losing my attorney's representation. 22 Q Do you know 23 A Spell it, please. 24 Q I don't know how to spell her name, but 25 do you know a ? I don't know that she would EFTA01724027 77 1 have ever spelled her name for you. 2 MR. Form, move to strike. 3 Q Her name is 4 A I intend to respond to all relevant S questions regarding this lawsuit. However, at 6 the present time my attorneys have counseled me 7 that I may not provide answers today, though I 8 would like to, and I must, in fact, take their 9 advice or risk losing their representation, so 10 therefore, I must assert those rights under the 11 U.S. Constitution. 12 Q Do you know the names of any of the 13 females that you allegedly solicited for 14 prostitution and pled guilty to? 15 MR. IIIII Relevance. 16 A Sitting here today, no, I do not. 17 Q You asked me to spell 's name. 18 That's somebody that your attorneys took her 19 deposition about a year and a half ago. Does 20 that help to refresh your recollection as to who 21 is? 22 A I would like to answer that question but 23 today, according to my attorneys, I must assert 24 my Fifth Amendment, Sixth Amendment and 25 Fourteenth Amendment rights under the U.S. EFTA01724028 78 1 Constitution. I must accept their advice or risk 2 losing my Sixth Amendment right to effective 3 representation, Mr. so though I would 4 like to answer the question, today I must assert 5 those rights. 6 Q There is another victim, her name is 7 , that was listed as one of the females at 8 your house and you pled guilty to the 9 solicitation of. 10 I would like to ask you if you remember 11 her? 12 MR. Form, confusing, compound. 13 A 14 0 I don't know her first time, initial 15 last name is 16 MR. Same objection. 17 A I intend to respond to all relevant 18 questions regarding this lawsuit. However, at 19 the present time my attorneys have counseled me 20 that I cannot provide answers to any questions 21 relevant to this lawsuit, and I must accept their 22 advice or risk losing my right to effective 23 representation. Therefore, though I would like 24 to answer the questions, I must assert those 25 rights. EFTA01724029 79 1 Q With each case that results in a 2 charge -- 3 THE WITNESS: Excuse me, is there some 4 water? 5 THE VIDEOGRAPHER: Off the record? 6 MR. Stopping again? 7 THE WITNESS: Can I get some water? Mr. 8 IIIII, can you pass some water? 9 THE VIDEOGRAPHER: There is no water 10 here. 11 THE WITNESS: Sorry. 12 Q With each conviction, charge, or with 13 each charge that leads to a conviction, there are 14 facts and circumstances that lead up to that plea 15 of guilty. 16 MR. Form. 17 Q What are the facts and circumstances 18 that led to you pleading guilty to the two 19 felonies that you've described? 20 MR. Form, overbroad, compound, 21 confusing, calls for a legal conclusion. 22 A I would like to respond to that 23 question. I would like to respond to that 24 question, but today my attorneys have advised me 25 I must assert my Fifth Amendment, Sixth Amendment EFTA01724030 80 1 and Fourteenth Amendment rights to the U.S. 2 Constitution or risk losing effective 3 representation. Accordingly, I must assert my 4 rights as guaranteed by the Constitution. 5 Q Just so you are clear, since your 6 attorney made it an objection that it was 7 unclear, then you invoked your Fifth Amendment 8 rights -- 9 A Sorry. 10 Q I'm talking about the cases where you 11 already pled guilty and you can't be charged 12 again. What were the facts and circumstances 13 that led up to you pleading guilty to these 14 felonies? 15 A I've answered the question. 16 MR. Same objection, asked and 17 answered. 18 THE VIDEOGRAPHER: Counsel. 19 (Indicating five minutes left on tape.) 20 MR. Okay. 21 Q Just so the jury understands, these 22 three females that were the subject of the guilty 23 pleas in State Court, were procured by your 24 method of having underage minor females locate 25 other underage minor females and bring them to EFTA01724031 81 1 your house; isn't that correct? 2 MR. : Objection, argumentative, 3 compound, harassing, assumes facts not in 4 evidence. I move to strike.. 5 A You have to repeat the question. 6 Q Okay, are all people 7 that were, at the time you engaged in sexual 8 activity with them, were underage and were 9 brought by other underage minor females; is that 10 true? 11 MR. Same objections incorporated 12 as well as motion to strike. 13 A I don't understand -- I'm sorry, I don't 14 understand the question. 15 Q isn't it true that you used underage 16 minor females to bring other underage minor 17 females to your house for sex? 18 MR. Asked and answered. 19 A (Witness shrugs.) 20 MR. ; Way earlier on. 21 MR. He doesn't understand the 22 question -- 23 MR. You can answer the question. 24 Q I'm going through the progression. 25 MR. You can answer, but it is EFTA01724032 82 1 asked and answered. 2 A As your firm, Mr. and Mr. 3 's has been described by the U.S. Attorney 4 as perpetrating one of the largest frauds in 5 South Florida's history by crafting malicious 6 cases of a sexual nature against people like me 7 and others, in order to fleece, using bogus 8 schemes, in the U.S. Attorney's words, investment 9 schemes. Unfortunately, though I would like to 10 answer every one of your questions if I'm able, 11 my attorneys have advised me I must assert my 12 Sixth Amendment, Fourteenth Amendment and Fifth 13 Amendment rights under the U.S. Constitution. 14 Therefore, at the moment I cannot answer that 15 question. 16 Q The acts related to your guilty plea 17 occurred at your Palm Beach house; is that 18 correct? 19 MR. : Form. 20 A Again, sorry. 21 Q If you were soliciting prostitutes, it 22 wasn't out on the street, it wasn't at a hotel. 23 These were girls that you solicited to be 24 prostitutes at your house in Palm Beach, 25 correct? EFTA01724033 83 1 MR. Objection, relevance, 2 argumentative. Calls for speculation as 3 worded and assumes facts not in evidence. 4 A Though I would like to answer that 5 question, my attorneys today have advised me I 6 cannot answer you today, and they've advised me I 7 must assert my Sixth Amendment, Fifth Amendment 8 and Fourteenth Amendment rights under the U.S. 9 Constitution. Otherwise I risk losing their 10 representation. So, accordingly I must assert 11 those rights, Mr. and Mr. 12 Q In what county did you plead guilty to 13 these felony offenses? 14 A Palm Beach County. 15 Q These were crimes that occurred here in 16 Palm Beach County? 17 MR. Form. 18 Q Is that correct? 19 A ... I pled guilty in Palm Beach County. 20 Q Isn't it true that you kept a calendar 21 or schedule -- 22 THE VIDEOGRAPHER: I have to change the 23 tape. 24 MR. Change it. 25 THE VIDEOGRAPHER: Off the video record • EFTA01724034 84 1 1:05 p.m. 2 (Pause in the proceedings.) 3 THE VIDEOGRAPHER: Back on the video 4 record 1:15 p.m. 5 Q Mr. Epstein, as it relates to the 6 charges you pled guilty to, are you saying today 7 that thdse females that you interacted with 8 sexually, were prostitutes prior to meeting you? 9 A I'm saying I pled guilty to the 10 solicitation of prostitution. 11 Q Right, and you would certainly agree 12 that that would require yourself and one other 13 individual for that act of prostitution, 14 correct? 15 MR Form. Also calls for a legal 16 conclusion. 17 A I pled guilty to solicitation of 18 prostitution. 19 Q Are you saying that those females that 20 were the victims, at least listed as victims by 21 the State, were prostitutes prior to meeting 22 you? 23 MR. : Form. Vague. Irrelevant? 24 A I pled guilty to solicitation of 25 prostitution. EFTA01724035 85 1 Q Do you have any remorse for your 2 actions -- 3 MR. Form. 4 Q -- against these victims that led to 5 your plea of guilty? 6 MR.IM Form, argumentative. 7 A I pled guilty to solicitation of 8 prostitution, not underage prostitution, simply, 9 prostitution. 10 Q Are you saying now that the subjects of 11 that, which were called victims, were not 12 underage when you engaged in sex with them? 13 MR. Form, argumentative, 14 speculation, assumes facts not in evidence, 15 as well as mischaracterizes the witness's 16 testimony. 17 A I pled guilty to solicitation of 18 prostitution, not underage prostitution, 19 solicitation of prostitution. 20 Q I was under the impression you pled 21 guilty to a second degree felony, that being 22 procuring a minor for the purposes of 23 prostitution. 24 A That's correct. 25 Q So a minor is somebody under the age of EFTA01724036 86 1 18, and I'm asking for the guilty plea related to 2 that count; are you at all remorseful for your 3 interactions with that minor? 4 MR. Same objections. 5 A What minor? 6 Q The charge is procuring a minor. You 7 tell me. Who was that minor? 8 A I don't know. 9 Q You were never told during the State 10 Attorney's prosecution of you, who this person 11 was? 12 A No. 13 Q Why did you plead guilty to a felony 14 charge that resulted in you going to jail, 15 without even knowing who the victim was? 16 MR. Form. That question calls 17 for attorney/client information, and 18 therefore, I'm going to instruct him not to 19 answer that. 20 Q If it has anything to do with any 21 conversations with your attorney, I don't want to 22 know. I'm just going off of the plea colloquy 23 between you and the Judge, where you understood 24 the charges and have been advised and apprised of 25 the charges and you still willingly, willfully EFTA01724037 87 1 pled guilty to the charges. I'm taking now that 2 you're saying, you don't even know what those 3 charges were about? 4 MR. What was the question? I . 5 don't know the question on the table now. 6 Q Who was the minor? 7 A I don't know. 8 Q You were never told the name or initials 9 of that minor victim by the State Attorney's 10 Office or the prosecutor? 11 A Not that I recall. 12 Q Just so the jury understands, this 13 method of paying underage minor females to bring 14 you other underage minor females for sex, is 15 something that you do in New York, and New 16 Mexico, Florida, everywhere, not just West Palm 17 Beach; isn't that right? 18 MR.= Again, form, compound, again 19 assumes facts not in evidence. 20 Argumentative and harassing, and moreover, 21 we have already been down this road before 22 in separate related questions that have 23 already been asked and answered. 24 A I would like to respond to each one of 25 your questions; however, today my attorneys have EFTA01724038 88 1 advised me I cannot and they've advised me I must 2 assert my Sixth Amendment right, my Fifth 3 Amendment right and my Fourteenth Amendment right 4 under the U.S. Constitution, therefore, that's 5 what I'm going to do. 6 Q Where is the calendar or schedule of 7 your underage sex appointments? 8 MR. Form, speculation. 9 A You said where is... 10 MR. : "Again." 11 Q Where is the calendar or schedule that 12 kept for you for your appointments 13 for sex with underage females? 14 MR. : Same objection. 15 Q if there is not one, you can tell me 16 there is not one. 17 A I would like to answer each one of your 18 questions today. However, I have been advised by 19 counsel that I must assert my Fifth Amendment, 20 Sixth Amendment and Fourteenth Amendment rights 21 under the U.S. Constitution or risk losing their 22 representation. Therefore, I'm going to have to 23 assert those constitutional rights, though 24 would like to answer that question. 25 Q Are you still in possession of the EFTA01724039 89 1 computers that were taken from your house prior 2 to the execution of the search warrant? 3 A Again. Am I still...? 4 Q Are you still in possession of the 5 computers that were removed from your house just 6 prior to the execution of the search warrant? 7 A I intend to respond to all relevant 8 questions regarding this lawsuit. However, at 9 the present time my attorneys have counseled me I 10 cannot respond to any questions that may be 11 relevant to this lawsuit, no matter how much I 12 might want to. I must accept this advice or risk 13 losing my Sixth Amendment right to 14 representation. Therefore, I must assert my 15 rights under the Fifth, Sixth and Fourteenth 16 Amendments of the U.S. Constitution. 17 Q Who is it that removed those computers 18 from your house prior to the execution of the 19 search warrant? 20 MR. : Objection, predicate. 21 A I intend to respond to all relevant 22 questions regarding this lawsuit. However, at 23 the present time my attorneys have counseled me 24 that I cannot provide answers to any questions 25 that may be relevant to this lawsuit, no matter EFTA01724040 • 90 1 how much I would like to, and I must accept their 2 advice or risk losing their representation. 3 Accordingly, therefore, I would have to assert 4 those rights, Mr. 5 Q It is my understanding, through 6 information and belief, it is my understanding 7 that this computer system contained the complete 8 list of names of underage minor females with whom 9 you engaged in sexual activity; is that correct? 10 A You're -- 11 MR. Ill" Objection. 12 A -- you're asking for my understanding? 13 Q No -- 14 A Are you asking me to tell you what your 15 understanding is? 16 Q Did the computers that were removed from 17 your home just prior to the execution of the 18 search warrant contain the complete list of 19 underage minor females with whom you engaged in 20 sexual activity? 21 MR. IIIII Form. 22 A Though I would like to answer that 23 question, like all your other questions here 24 today, unfortunately my attorneys have counseled 25 me that I'm going to have to assert my Sixth EFTA01724041 91 1 Amendment, Fifth Amendment and Fourteenth 2 Amendment rights under the U.S. Constitution. I 3 point -- excuse me. I would poin: out that your 4 firm was described by the current U.S. Attorney 5 as a criminal enterprise involved in money 6 laundering, creating and fabricating malicious 7 cases of a sexual nature against people like me 8 and others, in order to fleece local investors 9 out of millions of dollars. 10 I believe the senior partner of that 11 firm currently sits in jail. Unfortunately 12 though I would like to answer all of your 13 questions, today my attorneys have counseled me I 14 must assert my rights under the Sixth Amendment, 15 Fourteenth Amendment and Fifth Amendment of the 16 U.S. Constitution. 17 Q Isn't it true, you and and 18 Ghislaine Maxwell and operated 19 as an organized criminal enterprise designed to 20 sexually exploit minor? 21 MR- IIII/ Objection, argumentative, 22 speculation, calls for a legal conclusion 23 and continues to assume facts not in 24 evidence. 25 A Though I would like to answer that EFTA01724042 92 1 question, Mr. like most of your other 2 questions here today... and hopefully will get to 3 do so at some point, my lawyers have advised me I 4 must today assert my constitutional rights under 5 the Sixth Amendment, Fifth Amendment and 6 Fourteenth Amendment of the U.S. Constitution and 7 I must accept their advice or risk losing 8 effective representation. 9 Q And as part of that organization you 10 developed code terms such as "Work" or "Massage" 11 as opposed to engage in sex with minors; is that 12 true? 13 MR. IIIII Form, argumentative, 14 speculation, harassing, assumes facts not in 15 evidence. 16 A Can you... you...? 17 Q You developed code terms such as you -- 18 A "You" me? 19 Q Yes, you, would ask these girls if they 20 would like to give you a massage or work for you, 21 rather than asking them to do what was going to 22 be done, which is engage in sexual activity with 23 you; isn't that true? 24 MR.= Same objections. 25 A Are you asking if I developed code EFTA01724043 93 1 words? Is that the question? 2 Q Right. Code words. 3 A I would like to respond to that 4 question, but unfortunately today my attorneys 5 told me I have to respond by taking -- invoking 6 my Sixth Amendment, Fourteenth Amendment and 7 Fifth Amendment rights of the U.S. Constitution, 8 or risk losing my amendment right to effective 9 representation. Accordingly I assert my 10 Constitutional rights as guaranteed.by those 11 amendments. 12 Q What did it mean within your 13 organization when someone, some underage minor 14 female was coming over to work for you? 15 MR. Form. 16 A What did it mean? 17 Q Right, what did it mean? What did it 18 mean to you was going to happen when an underage 19 minor female would either call to work or 20 would tell you this person was coming to • 21 work for you at a specific time? 22 MR. Objection, vague, 23 speculative, assumes facts not in evidence. 24 A I would like to answer that question, as 25 most of your other questions today. However, EFTA01724044 94 1 today my attorneys have counseled me that I must 2 invoke my Sixth Amendment, Fourteenth Amendment 3 and Fifth Amendment right, or risk -- and if I 4 don't, I risk losing them as my attorneys so, 5 therefore, I must assert those rights. 6 Q You're laughing as if my questions are 7 ludicrous right now but you're aware that there 8 were trash pulls from your home where there were 9 message pads, messages taken by various employees 10 of yours, where these terms, "Massage," "Work" 11 were used in conjunction with underage minor 12 females coming over to your house, weren't you? 13 MR. : Same objections, form, as 14 well. Move to strike, and also assumes 15 facts not in evidence. Lack predicates. 16 Q You're aware of the trash pull and the 17 message pads, correct? ' 18 MR. IIIII Same objections. 19 Do you have any documents with you here 20 today that you speak of? 21 MR. No, but at this point in 22 time in the trial, they will already about 23 in evidence. 24 A I'm aware of a trash pull? What's a 25 "trash pull"? I'm sorry. EFTA01724045 95 1 Q Are you aware of -- I'll ask it of you 2 this way: when would take a phone 3 message for you, what did she write it down 4 with? 5 MR. Form. 6 A The question makes no sense to me, 7 sorry. 8 Q If another employee of yours were to 9 answer the telephone, be it your housekeeper, 10 housemanager, would answer the phone, take a 11 message for you and write it down so that you 12 could read it later, what would that message be 13 written on? 14 A Most likely paper. 15 Q Okay, is that paper typically in the 16 form of a message pad that has a carbon copy 17 sheet to the back? 18 A No. 19 Q You're unfamiliar with the documents 20 that I'm talking about, that being a message pad 21 that informs you as to who called, the time they 22 called and the purpose for calling? 23 MR.= For purposes of the question 24 you're specifically talking about a message 25 pad, nothing related to what you're defining EFTA01724046 96 1 as a trash pull, just what someone takes as 2 a message at Mr. Epstein's home and -- 3 A Do I know what a message pad is? 4 Q No. In your home, do you typically have 5 your housekeeper, housemanager, or somebody else, .6 when they take a message for you, write on a 7 specific pad that informs you as to who is 8 calling, the time they are calling and the 9 purpose for their calling, and there is a carbon 10 copy sheet evidencing that message? 11 MR. Objection, asked and 12 answered. 13 Q You know what I'm talking about? 14 A I know what a message pad is. 15 Q Do you use them commonly in your home or 16 did you back prior to your arrest? 17 A I would like to answer that question, 18 but today my attorneys have advised me I have to 19 assert my Fifth Amendment, Sixth Amendment and 20 Fourteenth Amendment rights under the U.S. 21 Constitution, so therefore, I'm going to do that 22 or I risk losing their representation. 23 Q Is my question to you confusing? Do you 24 know what I'm talking about? 25 MR. Form. EFTA01724047 97 1 A Not specifically, no. 2 Q Okay. 3 The information 4 A Is there something you have to show me, 5 so I know what you're talking about? 6 Q I. don't have it to. show you today, but 7 if the information and evidence that I have 8 learned through this process is accurate and 9 correct, it would seem a.foregone conclusion that 10 you and I would be on the same page, at least 11 about this document, so -- 12 A Okay. 13 Q -- if we are going to get to a point you 14 tell me "This document doesn't exist" or "I don't 15 know what you're talking about," okay, that's 16 fine, but that's something we can hash out. 17 Here is my question: When a 18 housekeeper/housemanager would take a message for 19 you from any caller, is there a specific message 20 pad that has a carbon copy located near your. 21 telephone, for them to write down the name of the. 22 caller, the purpose for the call and the tinle 23 called? 24 MR. Ili Form. 25 Q Is that something you're familiar with? EFTA01724048 98 1 A I would like to respond to that 2 question. Today my attorneys have counseled me I 3 must assert my Sixth Amendment, Fifth Amendment 4 and Fourteenth Amendment right under the U.S. 5 Constitution. 6 Q You're invoking your Fifth Amendment 7 right is not that you understand the question. 8 You understand my question and are electing to 9 invoke your Fifth Amendment rights; is that 10 correct? 11 A Yes. 12 Q When or a housekeeper or 13 housemanager, whoever happened to be employed at 14 the time, would take messages, what form would 15 you normally or typically receive them in? 16 A (Witness shrugs.) 17 MR. Same objections. 18 A I don't understand the question. 19 Q When a caller would call the home, 20 housemanager or housekeeper or , I 21 don't know what you would call her, assistant, 22 would answer the phone, and take a message for 23 you so that you would know who called, what would 24 they typically write down the message on so that 25 you would have it? EFTA01724049 99 MR. Objection. Object to the 2 form, lacks predicate. You have not 3 established anything here today relative to 4 a housekeeper or housemanager or the like. 5 Um... And I'm trying to understand the 6 question. But -- 7 MR. Really? 8 MR. -- it lacks predicate. 9 MR. This will play well. 10 A Piece of paper. 11 Q Normally they would write it down on a 12 piece of paper and give it to•you? 13 A I didn't say that. . 14 Q Have you ever been given a message that 15 is ripped out of a message pad that has a carbon 16 copy to it? 17 A Oh, I see. Okay. I intend -- I would 18 like to answer that question, but today my 19 attorneys have advised me I must respond by 20 invoking my Sixth Amendment right, my Fifth 21 Amendment right and my Fourteenth Amendment 22 rights under the U.S. Constitution. Though I 23 would like to answer these questions, accordingly 24 I must assert those rights or I risk losing my 25 representation here today. EFTA01724050 100 1 Q Between the years 2002 and 2005, who was 2 your house manager? 3 A (No response.) 4 Q If there is more than one, tell us that. 6 A The question is unclear. I'm sorry. 7 Q Okay, let me start with between 2002 and 8 2005, did you employ a housemanager? 9 MR. Form. 10 A Where? 11 Q At your Palm 'Beach home. 12 A I intend to respond to all relevant 13 questions here today, Mr. Hopefully we 14 will get some. But my attorneys have advised me 15 that today I must invoke my Sixth Amendment, 16 Fifth Amendment and Fourteenth Amendment rights 17 under the U.S. Constitution; or risk losing them 18 as counsel. So today I have to assert those 19 privileges. 20 Q Do you know 21 A I intend to respond to all relevant 22 questions regarding this lawsuit. However, at 23 the present time no matter how much I would like 24 to answer that question, I cannot, because my 25 counsel -- the attorneys have told me that I have EFTA01724051 101 1 to invoke my Sixth Amendment, Fifth Amendment and 2 Fourteenth Amendment or, in fact, risk losing 3 their representation. Therefore, I'm going to 4 have to assert my rights under those. 5 Q is a female that was born in 6 7 A Is that a question? 8 Q Not yet. When is the first time that 9 you met her? 10 MR. Objection, speculation. 11 MR. That assumes that he did 12 meet her; is that what you're saying? 13 MR. : Your question assumes -- 14 MR. He met her? 15 MR. exactly what he just said 16 which hasn't been established on the record 17 yet pursuant to the appropriate Florida 18 Rules of Civil Procedure and the Evidence 19 Code. Lacks predicate. 20 A That being said, I would like to answer 21 that question, but today my attorneys have 22 counseled me that I cannot, and they've advised 23 me I must assert my Sixth Amendment right, my 24 Fourteenth Amendment right, and my Fifth 25 Amendment right under the U.S. Constitution. EFTA01724052 102 1 THE WITNESS: Can you throw me one of 2 the suckey candies, please 3 Thank you. 4 MR. (Handing candy.) 5 THE WITNESS: Appreciate it. 6 Q Isn't it true you met ■ for the first 7 time in July or August of 2002 just before her 8 fourteenth birthday? 9 MR. Same objections. 10 A You know, your firm ihas been accused by 11 the U.S. Attorney of perpetrating one of the 12 largest frauds in South Florida history by 13 crafting sexually charged lawsuits against people 14 like me and others in order to fleece 15 unsuspecting investors here in South Florida out 16 of millions of dollars. The firm of you and Mr. 17 The U.S. Attorney described it as bogus 18 schemes contrived by your firm. 19 I would like to answer every one of your 20 questions here today; however, my attorneys have 21 counseled me that I may not, and have advised me 22 that I have to invoke my Sixth Amendment, Fifth 23 Amendment and Fourteenth Amendment rights under 24 the U.S. Constitution. Therefore, that's what I 25 will do, otherwise I risk losing their EFTA01724053 103 1 representation. 2 Q Isn't it true as a 13 or 14-year 3 old girl was taken to your house by another 4 underage minor female, that being 5 6 MR. : Form. 7 THE WITNESS: Tissue, please. 8 MR. (Handing tissue.) 9 A I would like to answer that question 10 like all the other questions you've asked me here 11 today, but today my attorneys have counseled me 12 that I have to invoke my Sixth Amendment right, 13 my Fifth Amendment right and Fourteenth Amendment 14 rights under the U.S. Constitution; therefore 15 that's what I will do. 16 Q Do you know who is, 17 right, she had a lawsuit against you previously? 18 MR. Form. 19 A Again the last name? 20 21 A Could you spell it for me? 22 Q Well, the pseudonym that she used in her 23 lawsuit against you alleging similar facts to 24 those alleged in IIII versus Jeffrey Epstein was 25 IIIII. versus Jeffrey Epstein. EFTA01724054 104 1 A And now the question? 2 Q You know who she is, correct? 3 MR'Illii Form. 4 A I would like to answer that question 5 here, Mr. but unfortunately today my 6 attorneys have counseled me I must invoke my 7 Fifth Amendment, Sixth Amendment and Fourteenth 8 Amendment rights under the U.S. Constitution, and 9 if I don't, I risk losing their representation, 10 therefore I must assert those rights. 11 Q When I asked you about or 12 you sat there for a while thinking hard 13 about whether or not you knew them. Do you 14 remember either or 15 MR. IIII/ I move to strike counsel's 16 statement because the statement as worded 17 assumes facts certainly not in evidence. It 18 is argumentative, speculates as to what is 19 "thinking hard," and, counsel, I don't 20 understand the question on the table, 21 combined with your narrative. If you could 22 repeat the question? 23 MR. Sure. 24 Q I'm asking if during this questioning 25 process, has it refreshed your recollection as to EFTA01724055 105 1 who is or do you really have no idea who 2 that is? 3 MR. En Form. Asked and answered. 4 Q Do you remember III.? 5 A Are you going to ask one question? 6 Which question would you like answered first? 7 Q Do you remember 8 A I would like to answer that question. I 9 would like to answer that question today; however 10 my attorneys today have advised me that I must 11 assert my Fourteenth Amendment, Fifth Amendment 12 and Sixth Amendment rights under the U.S. 13 Constitution, no matter how much I would like to 14 answer these questions. So unfortunately, I'm 15 going to assert those rights. 16 Q When you first met ■, isn't it true 17 that she was just about to begin her ninth grade 18 year in high school? 19 MR. Same objections. Form. 20 A I, believe her testimony in front of the 21 FBI, in a sworn deposition says something else, 22 but I don't recall exactly what. I don't have 23 any recollection, 24 Q Of 25 MR. Ill. Form. EFTA01724056 106 1 A You asked the question when I met her, I 2 think, if I met her. 3 Q You have no recollection as to when you 4 met her? 5 A I don't have recollection if I ever met 6 her. d just told you, I did read her FBI 7 statement, so I know what she has said and it is 8 not what you've just represented to me. 9 Q Your only knowledge of any interaction 10 you may have had with is derived from an FBI 11 statement that she gave; is that true? 12 A I believe what you just represented she 13 said was not what she had sworn to. 14 Q I'm not asking what she said. I'm 15 asking do you independently remember if she was 16 entering into her ninth grade year of high school 17 when you met her? Independent of anything you've 18 read. 19 MR.= All right, let me just move 20 to strike the... Diatribe between Mr. 21 and Mr. Epstein. I'm confused as to 22 what question is on the table now. 23 MR. Okay. 24 Q Independent of anything you've ever 25 read -- EFTA01724057 107 1 A Okay. 2 Q -- do you remember meeting just 3 before she entered into her ninth grade year in 4 high school? 5 A I would like to answer that question, 6 however my attorneys today have advised me that 7 though her own statements are contradictory to 8 what you just said, her sworn statements to the 9 FBI contradict what you just said. I have to 10 invoke my Sixth Amendment, Fifth Amendment and 11 Fourteenth Amendment rights to the U.S. 12 Constitution. 13 Q Just a few minutes ago when you asked 14 when you met her, you said, "I don't know if I've 15 ever met her," so is that your testimony, that 16 you don't know if you ever met 17 A My testimony is very clear. I must 18 assert the rights my attorneys have asked me to 19 assert today, though her testimony under oath to 20 the FBI is not what you represented it to be, to 21 me, and the ladies and gentlemen•of the jury who 22 are watching this, hopefully. 23 MR. Form. 24 Q We will get into that. 25 A Okay. EFTA01724058 108 1 Q then you first came into the room today; 2 didn't you look at me and say "I like " Isn't'. 3 that the statement that you made to me? 4 MR. Form. Move to strike. 5 A I don't believe I said that. 6 Q. What is it that you believe you did say 7 referencing when you sat down in that seat 8 prior to the cameras rolling? 9 MR. Form. Counsel, I was here 10 during that whole time and I don't recall 11 any such statement. 12 MR. You weren't in the room. 13 A I don't remember. I don't know. 14 Sorry. 15 Q So is it your testimony right now that 16 you did not say to me "I like 17 A That's 18 Objection. 19 A that's correct. 20 Q Do you like IIII? 21 MR. Form, predicate, and 22 relevance. 23 A I would like to answer all your 24 questions here as I've... tried to do my best, 25 however, my attorneys have advised me that I must EFTA01724059 109 1 assert my Sixth Amendment, Fourteenth Amendment 2 and Fifth Amendment rights under the U.S. 3 Constitution. 4 Q When you first met , isn't it true 5 that you knew she was an economically 6 disadvantaged girl that needed money? 7 MR. Objection, speculation, 8 assumes facts not in evidence, and it is 9 argumentative as worded. 10 A I would like to answer all your 11 questions here today, Mr. and Mr. 12 . However, on advice of counsel I have to 13 assert my Sixth Amendment, Fifth Amendment and 14 Fourteenth Amendment rights under the U.S. 15 Constitution, or risk losing my'right to 16 effective representation. So accordingly I must 17 assert those rights as guaranteed by the Sixth, 18 Fifth and Fourteenth amendments. 19 Q When she was a 14-year old girl, she was 20 taken into your bedroom and you ordered her to 21 take her clothes off; is that correct? 22 MR. ■: Objection, vague, confusing. 23 As to "her," I'm not quite sure who you... 24 Q When was a 14-year old girl, she 25 was taken up to your bedroom and you ordered her EFTA01724060 110 1 to take her clothes off; isn't that true? 2 MR. Objection, speculation, and 3 assumes facts not in evidence. Lacks 4 predicate. 5 A Though once again what you've just 6 represented to me is a total contradiction to the 7 FBI sworn statement that I read of ■, I must 8 unfortunately respond by asserting the rights 9 demanded by my attorneys today, which is my Sixth 10 Amendment, Fifth Amendment and Fourteenth 11 Amendment right against -- sorry, given by the 12 U.S. Constitution, though her testimony is 13 exactly -- does not purport in any way to what 14 you've just said. 15 Q And when lip. was 14 years old, you 16 ordered she begin to give you a massage while she 17 was naked and you were naked; isn't that true? 18 MR. Same objections. 19 A Sorry, you have to repeat the question 20 for me. 21 Q When IIII was a 14-year old girl -- 22 A Right. Yes? 23 Q -- you laughed and said, "right" about 24 what? 25 A I didn't hear the first part of your EFTA01724061 111 . 1 question. Now I understood it. 2 Q When was a 14-year old girl, wasn't 3 it true that you received a massage from her 4 while she was naked and you were naked? 5 MR. Objection, speculation, 6 assumes facts not in evidence, lacks 7 predicate. 8 A I understand that your firm has been 9 accused by the U.S. Attorney of South. Florida, 10 perpetrating one of the largest frauds in 11 Florida's history, by crafting malicious, 12 sexually charged allegations against people like 13 me. I understand testimony is not what 14 you've just described, though she swore to the 15 FBI... under oath. Though I would like to answer 16 your questions here today, my attorneys have 17 advised me I may not. I must assert my Sixth, 18 Fifth and Fourteenth Amendment rights under the 19 U.S. Constitution or risk losing their 20 representation. 21 THE WITNESS: Restroom break. 22 MR. Excuse me? 23 THE WITNESS: Restroom break. 24 MR. Stopping again? 25 THE WITNESS: Yeah. EFTA01724062