EFTA Document EFTA01724063

112 1 THE VIDEOGRAPHER: Going off the video 2 record 1:49 p.m. 3 THE WITNESS: Thank you. 4 (Pause in the proceedings.) 5 THE VIDEOGRAPHER: Back on the video 6 record 2:04 p.m. 7 Q Mr. Epstein, when IIII was a 14-year old 8 girl, isn't it true that while you were 9 the massage table, you ordered to 10 and provide you'a massage? 11 A I believe I've answered that question, 12 didn't I? 13 Q I don't remember where we left off, 14 that's why. 15 MR. IIII: Form, argumentative, 16 speculation. It is compound and assumes 17 facts not in evidence and has been asked and 18 answered. But we did take a break, so you 19 can respond. 20 (Counsel addressing Mr. Epstein.) 21 A The current U.S. Attorney has described 22 your law firm as a criminal enterprise involved 23 in fabricating sexually charged cases against 24 people like me in order to fleece unsuspecting 25 investors out of millions of dollars. He used EFTA01724063 113 1 words like "bogus schemes." 2 Unfortunately at this time in response 3 to your questions, though I would like to answer 4 each and every one, I'm going to have to, on 5 advice of counsel, assert my Sixth Amendment, 6 Fifth Amendment and Fourteenth Amendment rights 7 under the U.S. Constitution, though I would like 8 to answer those questions. 9 Q While was a 14-year old girl 10 providing you a massage, you ordered her to IIIII 11 during that massage; isn't that 12 true? 13 MR. III/: Same objections, 14 argumentative, speculation, harassing, 15 assumes facts not in evidence and lacks 16 predicate. 17 A I asked her to 18 19 A I believe her own sworn testimony 20 contradicts that statement. However,.I would 21 like to answer all your questions here today, but 22 my attorneys advised me, at least today, Mr. 23 I must take my constitutional privileges 24 of the Sixth Amendment, Fifth Amendment and 25 Fourteenth Amendment, keeping in mind that your EFTA01724064 114 1 firm, of you, Mr. and Mr. 's firm 2 has been accused by the U.S. Attorney of 3 perpetrating one of the largest frauds in 4 Florida's history by crafting sexually charged 5 lawsuitS against people like me, to fleece from 6 local people millions of dollars. 7 Q And during this massage by , you 8 began to in front of her; isn't that 9 true? 10 MR. IIII: Same objections? 11 A Unfortunately, though I would like to 12 answer each one of your questions here today, my 13 attorneys have counseled me today at least, I 14 have to assert my Fifth Amendment, Sixth 15 Amendment and Fourteenth Amendment rights under 16 the U.S. Constitution, otherwise I risk losing 17 their effective representation, and the fact that 18 your firm has been accused of fabricating these 19 malicious lawsuits to fleece investors out of 20 millions of dollars, as described by the U.S. 21 Attorney here in South Florida as a criminal 22 enterprise involved in mail fraud, money 23 laundering... Unfortunately I would like to 24 answer each question, but I can't today. 25 Q Isn't it true that while you were EFTA01724065 115 1 2 14-year old 3 MR. Objection, argumentative. 4 Speculation. It is harassing. It assumes 5 facts not in evidence. The question 6 continues to lack predicate, and I also 7 believe the question has been asked and 8 answered sometime ago. 9 A Though I would like to answer each one 10 of your questions today, Mr. my counsel 11 has told me I cannot answer any questions that 12 may be relevant to this lawsuit. The fact that 13 your firm has been accused of major fraud, the 14 largest fraud in South Florida history, by the 15 U.S. Attorney calling your firm a criminal 16 enterprise involved in money laundering -- I 17 believe it is racketeering, but I could be 18 wrong... Monetary transactions via fraud, mail 19 fraud, conspiracy -- sorry -- I would like to 20 answer your questions but today on advice of 21 counsel, I am going to have to assert my rights. 22 Q Isn't it true also that while was a 23 14-year old female, you to the point 24 of while 25 EFTA01724066 116 1 MR. IIII: Same objections incorporated? 2 A Again, the question? 3 Q Isn't it true that during this sexual 4 massage, while you were -- that you 5 to the point of while you were 6 7 MR. IIII: Objection, argumentative, 8 speculation. It is compound. It is vague. 9 It assumes facts not in evidence and lacks 10 predicate. 11 A Though I would like to answer that 12 question with specificity and detail today, no 13 matter how much I would like to, my attorneys 14 have advised me I cannot. They advised me I must 15 assert my Fifth Amendment, Sixth Amendment and 16 Fourteenth Amendment rights under the U.S. 17 Constitution or potentially lose effective 18 representation, so therefore, I will assert those 19 rights. 20 Q Isn't it true that the ritual that I'm 21 describing occurred with IIII, approximately 100 22 times when she was between the ages of 13 and 16? 23 MR. Same objections, with the 24 additional objection of vague and 25 confusing. EFTA01724067 117 1 A Since your firm has been involved -- 2 according to the U.S. Attorney in crafting these 3 fraudulent lawsuits in order to fleece local 4 investors, and the fact that I believe in 's 5 sworn statements, that's what you've just alleged 6 at least is totally contradicted by your client's 7 own sworn statements, though I would like to 8 answer these questions today, my attorneys have 9 advised me I may not and advised me I must assert 10 my. Fifth, Sixth and Fourteenth Amendment rights 11 under the U.S. Constitution or potentially risk 12 losing effective representation. 13 Q In addition to the sexual abuse directed 14 against that I've just described, isn't it 15 true that you also paid her money to bring you 16 more than 50 other underage minor females for you 17 to similarly abuse? 18 MR. IIII: Same objections. 19 A Though I believe in her own sworn 20 testimony to the U.S. government that she 21 contradicts those assertions, and I'm sure maybe 22 you'll have some explanation at trial, but the 23 ladies and gentlemen of the jury should know 24 about your firm being accused by the U.S. 25 Attorney of perpetrating one of the largest EFTA01724068 118 1 frauds in U.S. history by crafting malicious 2 lawsuits of a sexual nature in order to fleece 3 investors out of millions of dollars, local 4 investors; and though I would like to answer your 5 questions in detail today, Mr. and Mr. 6 ,.my counsel says I may not and have asked 7 me to assert those rights, which'I must 8 unfortunately. 9 Q You keep bringing up this fraud of the 10 former law firm known as 11 in response to my questions, so I would 12 like you to tell the jury at this time which 13 allegation are you now saying is fraudulent or 14 untrue, that's been made by 15 MR. IIII: Form, confusing, compound, 16 and irrelevant. 17 MR. Only made irrelevant by 18 his answers. 19 MR. IIII: Same objections. 20 Q Do you understand the question? 21 . A No. 22 Q You made reference to -- in response to 23 my questions about what you did sexually to 24 25 A Yes, sir? EFTA01724069 119 1 Q -- you have responded with these fraud 2 allegations against the firm of 3 I want you to tell the jury 4 which allegations that is making against you 5 are you disputing at this time or calling a fraud 6 or calling untrue? 7 MR. 'III: Confusing, compound and -- if 8 the court reporter would read back Mr. 9 10 11 .Epstein's response, I think you will see the way you just phrased the question mischaracterizes his testimony. Because 12 well, I'll keep it there unless you want me 13 to go further. You want me to go further? 14 " 15 16 MR. further. MR. No, I want him to go Mischaracterizes the 17 witness's testimony. 18 A 's own statements contradict every 19 one of your allegations that you've made to me 20 today, as a hypothetical. In her own words. And 21 you -- and the potential reasons this concerns me 22 is the fact that the law firm that represented 23 IIII and two others have been accused by the U.S. 24 Attorney of fraudulently producing cases against 25 me and others, to fleece investors in what he's EFTA01724070 120 1 described as one of the largest frauds in South 2 Florida's history. So, it concerns me. It is a 3 factor in the way I'm thinking about answering. 4 Sorry. 5 Q Each time that you 6 or otherwise , you paid 7 her $200; is that correct? 8 MR. 'III: Objection, argumentative, 9 speculative, harassing. It assumes facts 10 not in evidence, and with regard to this 11 line of questioning, the Court has already 12 ruled that the demeanor in which you're 13 presenting this question is improper, and 14 harassing, so if you would -- 15 MR. I'm very comfortable with 16 the demeanor right now, Mr. IIII. These are 17 just the facts of the lawsuit. The facts 18 are outrageous and I understand that, but 19 they have to be asked. 20 MR. IIII: Maybe the demeanor and tone 21 of your question is laced in a manner that 22 it is proper for the video, but the content 23 of the question is the same exact harassing 24 question that was deemed by the Judge to be 25 argumentative. I'm not saying that he's not EFTA01724071 121 1 going to answer your question. 2 3 MR. Okay. MR. IIII: Or that you don't know what 4 his answer will be, but what I'm saying is: 5 could you rephrase the question? 6 Q Answer that question. I'll work on 7 rephrasing it for you at some point. 8 A Sorry, I forgot what the question is by 9 now. 10 0 Isn't it true that each time that you 11 interacted with sexually, meaning 12 her or her in some other way, 13 that you paid her $200 each time? 14 MR. IIII: Form. 15 THE WITNESS: Sorry? 16 MR. Form. Go ahead. 17 A I would like to answer each one of your 18 questions here today. However, my attorneys have 19 counseled me that today I have to assert my Fifth 20 Amendment, Sixth Amendment and Fourteenth 21 Amendment rights under the U.S. Constitution and 22 I'm cognizant of the fact that your firm has 23 crafted these malicious lawsuits, it has been 24 reported that the lawsuits are of a sexual 25 nature, in order to fleece investors, so though I EFTA01724072 122 1 would like to answer those questions, Mr. 2 and Mr. today I must keep my 3 counsel's advice. 4 Q Isn't it true that for each underage 5 minor that brought to you for the purposes 6 of you engaging in sexual activity, you paid her 7 $200? 8 MR. 'III: Objection, speculation. 9 Compound question, and it assumes facts not 10 in evidence. Therefore lacks predicate. 11 A Though I would like to answer that 12 question, as most of your other questions here 13 today, Mr. I intend to respond, 14 hopefully at some point to all of your questions, 15 but today my attorneys have advised me I must 16 invoke my Sixth Amendment, Fifth Amendment and 17 Fourteenth Amendment right under the U.S. 18 Constitution. 19 Q Over the course of relatively a roughly 20 three years, isn't it true that you 21 in a sexual manner on more than 50 22 occasions? 23 MR. IIII: Objection, argumentative. 24 Calls for speculation. It is overbroad, 25 confusing and vague, and it assumes facts EFTA01724073 123 1 not in evidence. 2 A Could you repeat the question for me? 3 I'm sorry, Mr. 4 Q Yes. The three-year period between 2002 and 2005 when you were engaging in sexual conduct 6 with , isn't it true that that conduct took 7 place on more than 50 occasions? 8 MR. Same objections. 9 A I believe if you read your own client's 10 FBI statements, what her statement -- it changed 11 dramatically after she decided to file a 12 different lawsuit, at the request of you and your 13 firm, with one of your firms -- there have been 14 many firms it seems, was accused of major fraud. 15 Since the testimony has changed dramatically, I 16 would like to answer those questions, but today 17 my attorneys have advised me I must assert my 18 Sixth Amendment right, my Fifth Amendment right 19 and my Fourteenth Amendment right. 20 Q ** Your answers are not going to 21 incriminate you if the answer is "no," it is only 22 if the answer is "yes" that it will incriminate 23 you, so aren't you telling the jury every single 24 thing I've asked you is not part of a fraud, just 25 happens to be true, isn't it? • EFTA01724074 124 1 MR. Objection, argumentative, 2 irrelevant and move to strike. I'm simply '3 going to instruct the witness not to answer 4 that question because.... I don't understand 5 it. I don't know what to say about that 6 question. 7 A (Gesturing.) 8 Q All of the things that I've told you or 9 that I've asked you about, you while 10 she was underage, you paying her for sexual 11 conduct, those are all things that really 12 happened, there is nothing about that, that 13 anybody has fabricated or made up, is there? 14 MR. IIII: Objection, argumentative, 15 speculative, it assumes facts not in 16 evidence, it certainly mischaracterizes the 17 witness's testimony all day, since I have 18 been here, and I have been here the whole 19 time. It assumes facts not in evidence. It 20 is also overbroad and substantially compound 21 because you're attempting to incorporate all 22 of your questions today into one question. 23 MR. I think you know, Mr. 24 IIII, your objection should be limited to 25 the form. If you object to the form, it is EFTA01724075 125 1 fine. 2 MR. a I'm sorry, that's -- 3 MR. You -- 4 MR. IIII: You've asked me several times today to tell you why. I thought I was 6 helping. I'm sorry. I certainly will keep 7 objecting to -- 8 MR. Appreciate it. 9 MR. IIII: -- the form. 10 MR. Thank you. 11 Q And your answer is? 12 A Repeat the question. 13 Q Every single allegation that has 14 made and I have now questioned you about in terms 15 of your sexual involvement with , they are 16 all true; isn't that correct? There is nothing 17 fabricated about any of these allegations, 18 correct? 19 MR. IIII: Objection, argumentative, 20 speculative, compound. It is vague, 21 overbroad -- 22 MR. You're objecting to form? 23 MR. IIII: Yes, assumes facts not in 24 evidence and lacks predicate. That is 25 form. EFTA01724076 126 1 A And I would like to answer that question 2 specifically today, however, on advice of counsel 3 they've suggested I take theiSixth amendment -- 4 assert my Sixth Amendment, Fifth Amendment and 5 Fourteenth Amendment rights under the U.S. 6 Constitution, keeping well aware of your firm's 7 responsibility in the largest fraud in Florida's 8 history by crafting sexually charged lawsuits 9 against people like me and others. 10 I believe in addition, since her 11 allegations, as you've phrased them, have changed 12 dramatically since her sworn statement, until in 13 fact, after she joined this firm charged with 14 this major fraud and most of her statements have 15 changed, I believe, so... 16 Q You remember when 17 when she was 16 years old, don't you? 18 MR. : Form, relevance, move to 19 strike? 20 A I would like to answer each one of your 21 questions here today, Mr. each and every 22 one of your questions. However, today my counsel 23 has told me I must assert my Sixtt. Amendment, 24 Fourteenth Amendment and Fifth Amendment rights 25 under the U.S. Constitution. EFTA01724077 127 1 Q Isn't it true that when was 14 2 years old, 15 years old and 16 years old, you 3 4 A Separate from the fact that in her own 5 testimony, her own sworn testimony under oath 6 before she decided to file a lawsuit for money, 7 there was never any discussion about anything 8 like that. I would like to answer that question, 9 but my attorneys have advised me, at least today, 10 that I must assert my Sixth Amendment, Fifth 11 Amendment and Fourteenth Amendment rights under 12 the U.S. Constitution. 13 Q Isn't it true when 14 at age 16, you no longer interacted with her 15 sexually but still demanded that she bring you 16 other underage minor females for you to sexually 17 exploit? 18 MR. Objection, speculation. 19 Compound. Harassing, and assumes facts not 20 in evidence. 21 A I believe her testimony changed 22 dramatically from her sworn statements to the 23 FBI -- 24 Q That's not a responsive -- 25 MR. IIII: Excuse me -- EFTA01724078 128 1 MR. It is not a responsive 2 answer so I won't allow 3 MR. IIII: That -- 4 5 6 MR. We'll move to strike it. Let's have an answer to the question. MR. IIII: The witness is trying. If 7 there is a legal basis for your moving to 8 9 10 11 strike, it would be taken up with the Court and you can move to strike. You can continue. MR. Strike it, it is 12 nonresponsive? 13 A Your allegations that you keep throwing 14 at me, relate to the fact that testimony, 15 after giving a sworn statement to the FBI, 16 changed dramatically after she decided to file a 17 lawsuit for money, joining your firm that's been 18 accused by the U.S. Attorney of one of the 19 largest frauds in Florida's history. I would 20 like to answer those questions; however, on 21 advice of counsel today I must assert my Fifth 22 Amendment, Sixth Amendment and Fourteenth 23 Amendment rights under the U.S. Constitution. 24 4 when IIII was 25 she brought you at least ten underage minor EFTA01724079 129 1 females isn't that true? 2 MR. Objection, argumentative, 3 speculation. It is vague and assumes facts 4 not in evidence and lacks predicate. 5 A I -- I -- I unfortunately would like to 6 answer that question as well as every other 7 question you've asked me here today, but my 8 attorneys have advised my I must assert my Fifth 9 Amendment, Sixth Amendment and Fourteenth 10 Amendment rights under the U.S. Constitution. 11 Q After had 12 and you were being criminally investigated for 13 some of the conduct that we've discussed here 14 today; isn't it true that you personally hired 15 and retained and paid for an attorney to 16 represent IIII? 17 MR. Objection, speculation -- 18 MR. Object to the form, Mr. 19 20 MR. I will not. I am allowed to 21 assert the basis for my objections, I am not 22 limited to just saying "form." I'm able to 23 assert the basis as to why, so I don't waive 24 that basis. 25 MR. It is just more of this EFTA01724080 130 1 obstructionist -- 2 MR. It's not obstructionist, it 3 is objecting to form. What is 4 obstructionist is what we are doing now. I 5 will be finished within four seconds. So I 6 am going to object to form, it's 7 argumentative, speculative and it assumes 8 facts not in evidence and it lacks 9 predicate. That's it. 10 A I'm sorry. (Witness shrugs.) Again? 11 Q The response to the question. 12 A I don't know the question. 13 Q You don't remember the question? Did 14 you hire an attorney at some point in time? 15 Do you remember that? 16 MR. Same objection. 17 A Not to the best of my recollection. 18 Q Do you know 19 A ... Do I know ? I don't 20 believe I've ever met 21 Q Is it your testimony today then that you 22 never paid for an attorney to represent III 1 23 A (Witness shakes head.)... On advice of 24 my counsel, I would like to answer that question, 25 but on advice of counsel I'm going to have to EFTA01724081 131 1 assert my Sixth Amendment, Fourteenth Amendment 2 and Fifth Amendment rights against -- excuse me, 3 Sixth Amendment rights of the U.S. Constitution. 4 Q And that attorney that was paid for by 5 you, informed that if she were to tell the 6 FBI exactly what happened at your house, that her 7 You're aware of 8 that, correct? 9 MR. IIII: Same objections. 10 A I recognize, I believe she made one of 11 the statements at her deposition after she 12 decided to sue me fox a bunch of money and your 13 firm has represented a number of... cases of a 14 sexually charged nature that turned out to be 15 fraudulent in order to fleece local investors. 16 The U.S. Attorney described your firm and these 17 cases as a bogus scheme, and I'm aware of that, 18 and would like to answer your question in more 19 detail today, Mr. however my attorneys 20 advised me that at least today, I must assert my 21 rights under the Sixth Amendment, Fourteenth 22 Amendment and Fifth Amendment. 23 MR. IIII: It is the food. 24 MR. I didn't want him in the 25 room in mid answer. EFTA01724082 132 1 THE WITNESS: Ready? Thank you. 2 THE VIDEOGRAPHER: Going off the video 3 record 2:29 p.m. 4 (Pause in the proceedings.) 5 THE VIDEOGRAPHER: Back on the video 6 record 2:50 p.m. 7 Q Isn't it true, Mr. Epstein, that you 8 gave money to coerce her into interacting 9 with you sexually? 10 A Mr. I would like to answer each 11 and every one of your questions here today, but 12 unfortunately, like I've done with mostly all of 13 your other questions, I'm going to have to assert 14 my rights, Sixth Amendment, Fourteenth Amendment 15 and Fifth Amendment on advice of counsel. 16 Although I would like to answer, if I don't 17 follow my counsel's advice, I risk losing 18 representation. 19 Q While committing these sexual acts 20 against when she was just a minor, you knew 21 it would psychologically damage her; isn't that 22 true? 23 MR. Form, lacks predicate, 24 speculation. 25 A I intend to respond at some point to -- EFTA01724083 133 1 I would like to respond to each and every one of 2 your questions, but today on advice of my counsel 3 they've required me to. assert my Fifth Amendment, 4 Sixth Amendment and Fourteenth Amendment rights 5 under the U.S. Constitution, though I would like 6 to answer each of these questions. 7 Q In fact, you deliberately and 8 intentionally caused severe emotionally distress 9 to underage minor females, including ; isn't 10 that true? 11 MR. Objection, argumentative, 12 speculation, it is compound. And it assumes 13 facts not in evidence. 14 MR. ' Okay. 15 A I would like to answer that question, as 16 I would like to answer all of your other 17 questions today regarding However, my 18 attorneys today have advised me that I must 19 assert my Sixth Amendment right to effective 20 representation and 'my Fifth Amendment right and 21 my Fourteenth Amendment right. Though I would 22 like to answer that with specificity, I must 23 follow my attorney's advice. 24 Q Will you admit for the jury that you 25 were investigated federally for your illegal EFTA01724084 134 1 activities with underage minors? . 2 MR. Same objections. 3 A I would like to answer that question, as 4 well as all the other questions you've asked me 5 here today, especially since your firm has been 6 accused by the federal, I guess, the federal 7 government,... being considered a criminal -- you 8 firm has been considered and investigated as 9 being a criminal enterprise using sexually 10 fabricated, sexual cases... fabricated cases, to 11 fleece investors out of millions of dollars, but 12 I would like to answer your questions; however my 13 attorneys have demanded that I assert my rights 14 under the Sixth Amendment, Fifth Amendment and 15 Fourteenth Amendment. 16 Q In fact, as a result of that 17 investigation, you, as well as the United States 18 Attorney's Office entered into what has now been 19 known and referred to as the nonprosecution 20 agreement; isn't that correct? 21 MR. IIII: Same objection. The document 22 speaks for itself? 23 A You have to repeat the question. 24 Q As a result of the criminal 25 investigation into your activities with minor EFTA01724085 135 1 females, you reached a resolution with the United 2 States Attorney's Office, in what has now been 3 described as the nonprosecution agreement; is 4 that correct? 5 MR. I'm going to object. Vague, 6 confusing, misrepresents the agreement and 7 the document is the best evidence. Will you 8 mark it? 9 MR. I can mark it. We will 10 copy it at the end and mark it as Exhibit 2. 11 (Document, Nonprosecution Agreement, was 12 deemed, marked as Exhibit number 2 for 13 identification, as of this date.) 14 A Yes. 15 Q In that agreement, there are listed 16 co-conspirators of Jeffrey Epstein, those being 17 18 (phonetic) and a. Can you explain 19 to the jury what those individuals did 'for you 20 related to the crimes that were investigated by 21 the federal government? 22 A Co-conspirators? 23 Q Yes, it says "criminal charges against 24 any co-conspirators of Epstein including but not 25 limited to EFTA01724086 136 1 or Can you explain to 2 the jury what each of those four individuals did 3 for you or conspired with you to do? 4 MR. IIII: Object to the form of the 5 question? 6 A I would like to answer that question, 7 however, today my attorneys advise me that I must 8 assert my Sixth Amendment, Fifth Amendment and 9 Fourteenth Amendment rights under the U.S. 10 Constitution. 11 Q Isn't it fair to say that you, as well 12 as the co-conspirators, operated as an organized 13 criminal enterprise designed to sexually exploit 14 underage minors? 15 MR. Object to argumentative, 16 speculation. It is vague and it assumes 17 facts not in evidence. 18 A Are you suggesting it was a criminal 19 enterprise? Is that the words? 20 Q Yes. 21 A Though I would like to answer that 22 question today, I think the only criminal 23 enterprise that I have been reading about today 24 was your firm, that's been accused of being a 25 criminal enterprise involved in defrauding EFTA01724087 137 1 people, using mail fraud, wire fraud, money 2 laundering, the operation of the enterprise -- 3 this is by the U.S. Attorney (indicating), but 4 though I would like to answer your questions with 5 specificity today, on advice of counsel, though I 6 would like to answer it, they demanded I assert 7 my Sixth Amendment, Fourteenth Amendment and 8 Fifth Amendment right or I risk losing their 9 representation. 10 Q Did you care about any of the underage 11 minor females at the time when. you were engaging 12 in sexual conduct with them? 13 MR. IM Objection, argumentative. 14 Harassing, already been ruled upon by the 15 Court relative to this exact question. 16 MR. I feel comfortable with 17 the question. It goes to punitive damages. 18 The issue related to the Court was a 19 repetitive question on that topic or around 20 that general subject matter. -I'm just 21 asking for Mr. Epstein to tell the jury how 22 he felt about these girls, whether he cared 23 about them, when he was engaging in illegal 24 sexual conduct with them. 25 MR. Counsel, I'm going to EFTA01724088 138 1 instruct him not to answer the question. 2 You can certify it to the Court, if you 3 like. You know what the answer is going to 4 be; however you're attempting to lace this 5 video. You know the Court has already 6 ordered that these types of questions are 7 not permitted because they are argumentative 8 and harassing. In fact, other questions 9 bordered but this question is on exact point 10 with the Court's order. If you want to 11 withdraw the question, that's fine. 12 MR. I don't want to withdraw 13 the question. 14 MR. III/: Then I instruct him not to 15 answer. 16 MR. Mark that somehow, that 17 page, so we can find it in the record, 18 relative to the hearing that will be had on 19 that question and others similar. 20 Q At the time when you were engaging in 21 sexual conduct with underage females, you knew 22 that exposing them to this, was not beneficial or 23 good for these girls; isn't that true? 24 MR. IIII: Objection, argumentative, 25 speculation, assumes facts not in evidence. - EFTA01724089 139 1 Lacks predicate. 2 A Though I would like to answer that 3 question, like most of your other questions here 4 today, on advice of. counsel I must assert my 5 Fourteenth Amendment, Fifth Amendment and Sixth 6 Amendment rights. Though I would like to answer, 7 if I do so, I risk losing my effective 8 representation of counsel. 9 Q Isn't it true, Mr. Epstein, that the 10 only thing that you cared about was accessing as 11 many underage females as possible, for the 12 purposes of sex? 13 MR. Argumentative, speculation, 14 harassing. 15 A What's the question? 16 MR. IIII: And assumes facts not in 17 evidence. 18 Q Isn't it true that the only thing that 19 you cared about when you were interacting with 20 these underage females in a sexual manner, was 21 or your own personal gratification? 22 MR. Form, same exact objections. 23 A Though I would like to answer that 24 question, and to the ladies and gentlemen of the 25 jury, I would very much like to answer that EFTA01724090 140 1 question; however, today my attorneys have 2 advised me I must take -- assert my rights under 3 the Fourteenth, Sixth and Fifth Amendments of the 4 U.S. Constitution, or else I risk losing their 5 representation. 6 MR. IIII: And Mr. just so we 7 don't have to come back on the question that 8 I instructed him not to answer, if you would 9 go ahead and repeat that question, I will be 10 more than happy to let him respond. 11 MR. I don't remember the 12 question we will take it up with the Court 13 and we'll get a ruling on it. 14 MR. IIII: It was whether or not he 15 cared about these -- I believe you quoted it 16 as underage minors, but I would like the 17 court reporter to read back the question 18 just to conserve judicial resources and not 19 go back. So if she can reread the question 20 that would be good. 21 MR. If you can find the 22 question. 23 THE COURT REPORTER: Certainly. 24 MR. I think I know it. 25 Q Did you care about any of these underage EFTA01724091 141 1 minor females that you were engaging in sex with, 2 at the time when you were engaging in these 3 sexual activities? 4 MR. Same objeCtions, as before. 5 A Though I would like to answer that • • 6 question as well as most of your other questions, 7 if not all of your other questions here today, on 8 advice of counsel I will have to assert my 9 Fourteenth Amendment right, my Sixth Amendment 10 right and my Fifth Amendment right, because no 11 matter how much I actually want to answer that 12 question, if I do so I risk losing my counsel's 13 representation. 14 Q At the time you were engaging in sexual 15 activity with these underage minors, including 16 IIII, you knew that this conduct was illegal, 17 didn't you? 18 MR. III/: Same objections. Form. 19 A I would like to answer that question, as 20 well as most of your other questions here today; 21 however, today my counsel has instructed me to 22 assert my Fourteenth Amendment, Sixth Amendment 23 and Fifth Amendment right, and if.I do not, and 24 if, in fact, I answer that question -- if I can 25 answer that question, I potentially risk losing EFTA01724092 142 1 my effective counsel's representation. 2 Q In fact, you told many of these underage 3 minor females not to tell anybody what happened 4 with you in the house, or else they would be in 5 trouble; isn't that true? 6 MR. IIII: Form. 7 A I would like to answer that question, as 8 well as the other questions; however, my counsel 9 has advised me that today I must assert my 10 Fourteenth Amendment, Sixth Amendment and Fifth 11 Amendment rights under the U.S. Constitution. 12 Q The underage minor females that have 13 come forward with information about your sexual 14 interactions with them have been investigated, 15 harassed, humiliated in an effort for you to 16 intimidate them to go away. Is that true? 17 MR. IIII: Objection. Argumentative, 18 speculative, compound. It is overbroad, and 19 assumes facts not in evidence. 20 A Can you repeat the question? 21 Q Sure. Any underage minor female that 22 you engaged in sexual activity with, that has now 23 pursued a lawsuit against you, isn't it true that 24 you've spent a lot of money and a lot of 25 resources investigating them in an effort to EFTA01724093 143 1 intimidate them and hopefully make them go away? 2 MR. 'III: Same objections. 3 A I believe your client's testimony 4 changed dramatically when she joined up with you 5 and your law firm, accused of fraud, when she 6 decided to change her testimony, at least from 7 what the statements said, both to the police and 8 to the FBI, and decided to seek money. However, 9 anything above that or beyond that, I'm going to 10 have to, in fact, assert my Fifth Amendment, 11 Sixth Amendment and Fourteenth Amendment rights 12 as directed by my competent counsel. 13 Unfortunately, they have told me if I don't, I 14 risk losing their representation. 15 Q All right, I'll give you a chance here 16 since you keep bringing up her statement to the 17 FBI as opposed to her sworn testimony for 13 18 hours under oath in this case. Are you saying 19 that the sworn testimony to the FBI was, in fact, 20 the truth? 21 A What I'm saying is, it seems her 22 testimony has changed dramatically after she 23 joined your firm, that's all. 24 Q Okay. Irrespective of her testimony, 25 you've read her testimony and you read her EFTA01724094 144 1 testimony -- to the FBI. You watched her 2 deposition when it was being taken. Which -- 3 A You're making assumptions, I'm sorry. 4 MR. Let him finish the question. 5 THE WITNESS: Sorry. 6 A My fault. 7 MR. IIII: Then I'll object and you'll 8 respond. 9 Q Which are you saying is the truthful 10 testimony, her statement to the FBI or the 11 videotaped deposition that you watched? 12 MR. IIII: Object to the form. 13 A What I've said, and I think I'll repeat 14 myself is until she joined your firm and started 15 to seek money, her testimony was different. 16 That's my understanding. 17 Q Are you denying any sexual involvement 18 with at this time? 19 MR. IIII: Form. 20 A I would like to answer that question. I 21 would like to answer it as with most of your 22 questions here today; however, my attorneys have 23 advised me that I must take that -- assert my 24 rights under the Sixth Amendment, Fourteenth 25 Amendment and Fifth Amendment, no matter how much . . . EFTA01724095 145 1 I would like to answer that question, or 2 potentially risk losing my counsel. 3 Q Isn't your game plan with all of these 4 civil lawsuits that have been filed against you, 5 to spend as much money as you can to investigate, 6 and harass these young women into hopefully 7 dropping the lawsuits against you? 8 MR. III': Objection. Relevance. Move 9 to strike. It is argumentative and 10 harassing. 11 A I would like to answer that question. I 12 think you know the answer to that question. 13 Q Yes. 14 A (Witness nods.) However, today my 15 attorneys have advised me I must assert my Sixth 16 Amendment rights, my Fourteenth Amendment rights 17 and my Fifth Amendment rights. 18 Q You don't have any remorse for the 19 sexual abuse that you committed against , do 20 you? 21 MR. IIII: Objection. It is 22 argumentative. It is harassing. It is, I 23 believe, confined under the Judge's order 24 and it assumes facts not in evidence? 25 A That being said, I would like to answer EFTA01724096 146 1 that question today, but my attorneys have 2 advised me that I must assert my Fourteenth 3 Amendment rights, my Fifth Amendment rights and 4 my Sixth Amendment rights. 5 Q In fact, you recently sued , didn't 6 you? 7 A Yes, and you and your firm that's been 8 accused of the largest fraud in Florida's 9 history, described by the U.S. Attorney as a 10 criminal enterprise involved in money laundering, 11 conspiracy to commit one crime -- excuse me, mail 12 fraud, commit conspiracy to commit wire fraud. 13 Yes, I sued you, your firm and 14 0 ** Tell the jury -- 15 A Yes. 16 Q -- the basis for the evidence that you 17 have to support the allegations in the complaint 18 against 19 MR. IIII: I'm going to instruct the 20 witness not to answer that question in this 21 medium, as it is wholly irrelevant 22 currently, as were it, to this particular 23 lawsuit. 24 MR. Just so you can rethink 25 that position, the lack of remorse goes to EFTA01724097 147 1 punitive damages, that is an aspect of the 2 case that IIII has against Mr. Epstein. 3 MR. IIII: This lawsuit, the current one 4 Mr. Epstein is noticed for, and the lawsuit 5 in which Mr. Epstein has filed against the 6 former and 7 Mr. is not proper for this 8 medium -- 9 MR. I understand your 10 position. 11 MR. III': -- in that regard, I'm going 12 to instruct him not to answer any questions 13 relative to that lawsuit because of that 14 objection, as well as, it is my 15 understanding that Mr. has set Mr. 16 Epstein's deposition, I believe, either 17 early next week or mid-March, on the case of 18 Epstein versus IIII and 19 'lilt' Mr. as well as 20 Therefore when that time approaches, that 21 would be the appropriate time for those type 22 of questions, related to that lawsuit. 23 MR. I understand your position 24 completely, Mr. 25 MR. IIII: Thank you. EFTA01724098 148 1 Q ** But as it relates to, obviously 2 sued you making the allegations that you sexually 3 her from when she was 13 years old to 4 when she was 16 years old and now you've sued her 5 in something that is seemingly related to that 6 case, and I just want to understand what your 7 factual basis is, or what evidence you're using 8 to support your lawsuit against so that the 9 jury can he valuate whether that is evidence of 10 lack of remorse that would go to punitive damages 11 claims that has against you. 12 MR. : I would instruct him not to 13 answer that question, for the same reasons 14 stated. 15 MR. Let's mark that. 16 Q Is it your feeling that because you are 17 wealthy and these children are poor, that you are 18 entitled to sexually abuse them? 19, MR. IIII: Argumentative. 20 Q In speaking about these children, and 21 including IIII 22 MR. IIII: Argumentative, speculation, 23 compound, it's vague, and it assumes facts 24 not in evidence. 25 A In keeping with your firm's propensity EFTA01724099 149 • 1 for filing fellacious (sic), manufactured, 2 sexually charged cases, based on nothing but thin 3 air, accused by the U.S. Attorney of the largest 4 fraud in South Florida's history, by 5 manufacturing sexual cases, I would like to 6 answer each and every one of your questions, 7 including why I sued you, but today I'm not going 8 to be able to. I have to simply listen to my 9 counsel and assert my Sixth Amendment, Fourteenth 10 Amendment and Fifth Amendment right. 11 Q This answer that you keep reciting, 12 about the firm -- 13 A You do know who they are, right? 14 Q -- you are aware, obviously, that all of 15 the lawsuits that were filed against you, 16 including 's, were filed at least a year 17 before, or approximately a year before 18 had any of these cases; you're 19 aware of that, right? 20 MR. IIII: Form. 21 A I do not know when got 22 involved in these cases. I do know that the 23 moment that they did surface, and, in fact, I 24 understand you shared information with all the 25 other attorneys that you so -- that the jury EFTA01724100 150 1 should understand that the information 2 gathered -- according to the U.S. Attorney, by 3 illegal means, has been shared with all the other 4 attorneys that you keep representing have filed 5 cases against me; yes, I'm aware of that. 6 Q I don't understand that answer. , 7 do you -- 8 MR. III,: Do you have a question? 9 MR. I want to understand what 10 his answer was. As in all depositions, if 11 you don't understand the answer, clarify the 12 answer. 13 MR. No, you have to ask a 14 question. 15 MR. I did. And he's 16 responding to it. 17 MR. The witness has answered the 18 question. Do you have another question to 19 clarify his answer? 20 MR. Yes. 21 Q Please clarify your answer. 22 MR. M I will instruct him not to 23 answer. It's vague and confusing, it's 24 narrative. 25 MR. Me saying "clarify your EFTA01724101 151 1 4 6 7 answer" is narrative? MR. What do you mean by "clarify your answer? MR. I didn't hear what he said. Say it again so I can hear it. MR. Would you please read back what Mr. Epstein just testified to, madam 8 court reporter. 9 (The record was read.) 10 MR. Okay. 11 MR. It was an. answer, a 12 question -- 13 MR. I understand -- I mean I 14 don't understand the answer, but now I know 15 the answer. 16 MR. Okay. 17 Q At this point in time, please tell the 18 jury what is your defense of the claims being 19 asserted against you in this lawsuit by III.? 20 MR. I'm going to object. Calls 21 for a legal conclusion. 22 A What are the claims? So since you're 23 representing , can you tell me what the 24 claims are? 25 Q Yes, we've gone through it. She went to EFTA01724102 152 1 your house when she was 13, 14, 15, 16 years 2 old -- 3 A Is that a claim? 4 Q -- she was in your bedroom. You 5 instructed You 6 You on 7 her. You coerced her into recruiting other 8 underage minor females, roughly 50 or so more. 9 These are all claims that have amounted 10 to various counts, coercion, prostitution, 11 intentional infliction of emotional distress, 12 battery, committing various crimes against her. 13 what are your defenses to that? Normal defenses 14 are "I didn't do it," "I did it, but it didn't 15 hurt her," we are trying to understand so we know 16 how to provide this case to the jury, what are 17 your defenses to these allegations? 18 MR. I'm going to object to this 19 line of questioning. It is compound; as 20 worded it could call for disclosure of 21 attorney/client information as well as work 22 product. I believe in this particular case 23 there is a document filed, answer in 24 affirmative defenses, and the affirmative 25 defenses are set forth there and the EFTA01724103 153 1 document there speaks for itself. 2 MR. Okay. 3 Q Respond. 4 A The document speaks for itself. 5 Q ** So you agree with the affirmative 6 defenses that were filed in your case? If you 7 were to testify, we could expect that to be your 8 testimony? 9 MR. That's not what the witness 10 testified. The witness testified that the 11 document speaks for itself, and again, I'm 12 going to object to attorney/client, work 13 product and instruct the witness not to 14 answer. 15 Q I'm not asking what your legal defense 16 is. I'm asking: what is your response to the 17 claims? 18 MR. Same objection. 19 Q What is your personal response? 20 A I would like to respond to that 21 question. I would like to respond today to that 22 question; however, today my attorneys have told 23 me that I cannot respond. They've asked me to 24 assert my Fourteenth Amendment, Sixth Amendment 25 and Fifth Amendment rights of the U.S. EFTA01724104 154 1 Constitution, though I would really like to 2 respond. They are telling me if I did so, I will 3 lose risking their representation. 4 Q I know you've invoked your Fifth 5 Amendment rights related to many of these 6 questions, but isn't it true you recently 7 contacted at The New York Daily News 8 and spoke to him about 's case as well as 9 several of the other girls, who have claims 10 against you? 11 A Who? 12 Q New York Daily News. 13 A Can you repeat the question? 14 Q Didn't you recently, within the last 15 year, contact of The New York Daily 16 News and discuss these cases that have been filed 17 against you and the allegations made by these 18 various females? 19 MR. Form. 20 A I would like to answer that question, 21 but unfortunately today my attorneys have advised 22 me I cannot. They've advised me I must assert my 23 Sixteenth -- excuse me, my Fourteenth Amendment, 24 Sixth Amendment and Fifth Amendment right, so 25 therefore, I will do so. EFTA01724105 155 1 Q Why is it that you will talk to 2 about this but you will not talk to the jury 3 about this? 4 MR. I= Form. Argumentative, 5 speculation. Misstates the witness's 6 testimony. It assumes facts -- the question 7 assumes facts not in evidence and now lacks 8 predicate. 9 A So who is again? 10 Q reporter with The New York 11 Daily News. Did you not talk to him? If you 12 didn't talk to him, tell me that. That's fine. 13 MR. Same objections. 14 A I would like to tell you answers to each 15 one of your questions, however today my attorneys 16 have demanded that I respond by asserting my 17 Fourteenth Amendment, Sixth Amendment, Fifth 18 Amendment privilege, though I would like to 19 respond, but they said if I do so, I risk losing 20 their representation. 21 Q Didn't you tell these 22 underage minors were not victims at all and that 23 regardless of their age, you did not personally 24 consider them victims? 25 MR. Same objection. EFTA01724106 156 1 A (Laughter.)... Did I tell... I would 2 like to answer that question, but today on advice 3 of my counsel, I must -- as I have done with 4 mostly each one of your questions, I have to 5 assert my Fifth Amendment, Sixth Amendment and 6 Fourteenth Amendment rights under the U.S. 7 Constitution. 8 Q You were 51 when IIII was 14, and you 9 were interacting with her sexually. Is it your 10 testimony that despite'the disparity in age you 11 do not consider be a victim? 12 MR. Argumentative, speculation, 13 assumes facts not in evidence. Compound, 14 lacks predicate. 15 A Not only does it contradict your own 16 client's statements to the FBI under sworn 17 testimony, I would like to answer that question. 18 Hopefully one day I can answer that question, but 19 today my attorneys have said I cannot. They 20 advised me I must assert my Sixth Amendment, 21 Fifth Amendment and Fourteenth Amendment rights. 22 Q In the last ten years, what is the 23 youngest underage minor female that you have 24 interacted with sexually? 25 MR. Argumentative, speculation, EFTA01724107 157 1 assumes facts not in evidence. 2 A The answer to that question is -- I 3 would like to give you an answer to that today, 4 but my attorneys have advised me I must assert my 5 Fourteenth Amendment rights, my Sixth Amendment 6 rights and Fifth Amendment rights. 7 Q Do you know 8 A Doesn't ring a bell. 9 Q Former housekeeper/employee of yours, 10 worked at the Palm Beach house? 11 A ... Could. Don't know. 12 Q So you would be unable to answer what 13 did for you? 14 A Yes.. 15 Q Are you aware that our investigator 16 spoke with former housekeeper 17 for you, or housemanager for•you, out in 18 California? 19 A No. 20 Q Any reason why when asked about the 21 activity that occurred in your house, he would 22 tear up and say, "I was hoping to forget 23 everything I saw"? 24 MR. Objection, argumentative. 25 Speculative. Assumes facts not in EFTA01724108 158 1 evidence. 2 A Again, the question? 3 Q Is there any reason that when asked -- 4 A I don't know who he is. 5 MR. Also, hearsay. 6 THE VIDEOGRAPHER: Counsel? 7 MR. Go ahead. 8 THE VIDEOGRAPHER: Going off the video 9 record 3:23 p.m. 10 (Pause in the proceedings.) 11 THE VIDEOGRAPHER: Back on the video 12 record 3:30 p.m. 13 Q This person that I asked you about, 14 is that somebody who has 15 contacted you within the last six months? 16 A ... No. 17 Q In taking a break and thinking about 18 some of these questions, have you remembered who 19 that person is, or still no real memory of him at 20 all? 21 A No real memory. 22 Q To the best of your knowledge, he never 23 worked for you? 24 MR. Form. 25 A Not that I can recall, but there are EFTA01724109 159 1 lots of people who work for me, so... 2 Q Can you tell the jury who the various 3 people are that work for you now? 4 A I believe I answered that question 5 already. 6 Q In that you invoked your Fifth 7 Amendment, correct? 8 A That's correct, Sixth Amendment and 9 Fourteenth Amendment. 10 Q Eigthteen and twenty-first? 11 A (Witness shrugs.) 12 MR. Move to strike. 13 Q ** Have you, during this litigation, and 14 by "this litigation," I don't only mean 's 15 case, but the various other lawsuits that have 16 been filed against you by other females alleging 17 sexual misconduct by you against them. Who have 18' you retained attorneys for, what witnesses have 19 you retained attorneys for? 20 MR. Object to the form. 21 MR. Okay. 22 MR. I'll instruct him not to 23 answer because I don't understand the 24 question. Okay? 25 MR. All right. EFTA01724110 160 1 Q During this civil discovery and 2 litigation -- 3 A Um-hum? 4 Q -- have you paid for, and/or retained an 5 attorney for any other witnesses? 6 A Any other witnesses? 7 Q Yes, like I'll give you an example that 8 you may, just to refresh your recollection or 9 tell you what I'm talking about, 10 you know who that is, right? 11 A Yes. 12 Q She is someone to works for you now, 13 she's a housekeeper. We took her deposition 14 already. At least that's what her testimony 15 was. 16 MR. Form. 17 A I would like to answer that question but 18 I have to assert my Sixth Amendment, Fourteenth 19 and Fifth. 20 Q That somebody who has informed us that 21 you paid for and obtained an attorney by the name 22 of to represent her during this 23 process. Is that -- 24 MR. Form. 25 A I have to assert my Fifth Amendment, EFTA01724111 161 1 Sixth Amendment and Fourteenth Amendment, right. 2 Q Other people that have indicated that 3 you retained and paid for an attorney to 4 represent them are 5 6 Ghislaine Maxwell, your 7 8 David Rogers, Have I 9 missed anybody else that during this litigation 10 you've paid for or retained attorneys? 11 MR. Form, same objection. 12 A I'm not clear. Are you suggesting I've 13 paid for attorneys for all these people? 14 Q Yes. 15 A (Laughter,) I would like to answer those 16 questions today, but on the advice of counsel 17 have to invoke my Sixth Amendment, Fifth 18 Amendment and Fourteenth Amendment right. 19 Q If you have not, tell me which of those 20 on that list that you have not paid for or 21 retained attorneys for? 22 MR. Same objection. 23 A Same answer. 24 Q You're invoking your Fifth Amendment, 25 right? EFTA01724112 162 1 A And Sixth Amendment and Fourteenth 2 Amendment... and Fifth Amendment. 3 Q 4,+ Is it a company or is it you, 4 personally, that is paying for the attorneys' 5 fees related to your representation? 6 MR. I'm going to object to the 7 form. I'm going to instruct him not to 8 answer that question based on relevance; and 9 it is vague also. 10 Q Who is writing the check to your 11 attorneys for your representation in this 12 lawsuit? 13 A (No response.) 14 Q Who is paying the bill? 15 A I believe I am. 16 Q And is it you, personally, or is this 17 one of your corporations or companies? 18 MR. Form, speculation. 19 A I'm not sure. 20 Q As you sit here today, ycu're not really 21 sure whether it is coming from one of the other 22 corporations that we've discovered during 23 discovery or it is coming from you, personally? 24 Is that correct? 25 MR. Asked and answered. EFTA01724113 163 1 A I believe -- I would like to answer but 2 I have to invoke my Sixth, Fourteenth and Fifth 3 Amendment rights. 4 Q As it relates to any of the other 5 witnesses who have had attorneys retained for ' 6 them, is it also your response to invoke your 7 Fifth Amendment rights, rather than to provide me 8 with an answer, as to who is paying the bill for 9 those attorneys? 10 A I would like to answer those questions, 11 but today my attorneys have asked me not to 12 respond to any questions that may be relevant to 13 this lawsuit, so I must follow their advice and 14 invoke the Sixth Amendment, Fifth Amendment and 15 Fourteenth Amendment, right. 16 Q Have you interacted sexually with any 17 underage minors in the last year, while on house 18 arrest or work release from jail? 19 MR. Objection. Argumentative and 20 compound and lacks predicate. 21 A I would like to answer that question, 22 but on advice of counsel, at least today, they've 23 advised me I must invoke my Sixth Amendment, 24 Fourteenth and Fifth Amendment right. 25 MR. It is also overbroad. EFTA01724114 164 1 Q If me narrowing down will help you to 2 respond, I will. Is there-any need for that? 3 A (Witness shakes head.) 4 MR. Okay. 5 THE WITNESS: Sorry. 6 Q Is it your intent to interact sexually 7 with minors in the future? 8 MR. Same objection. 9 A I would like to answer that question, 10 but today my counsel has advised me I must invoke 11 the rights of the Sixth Amendment, the Fourteenth 12 Amendment and the Fifth Amendment of the U.S. 13 Constitution. 14 0 Are you currently treating with a 15 psychologist related to any sex addiction that 16 you have with minors? 17 A I would like to answer that question, as 18 well, as most of the other... questions you've 19 asked me today; however, on advice of counsel 20 they've asked me to invoke my Sixth Amendment, 21 Fourteenth Amendment and Fifth Amendment right, 22 therefore, though I would like to answer that 23 question, as well as the other ones, I risk 24 losing the representation if I do so. 25 MR. Moreover I'm going to object EFTA01724115 165 1 to relevance as I have in the past since Mr. 2 Epstein's medical history is not at issue in 3 this case; under the legal terms. 4 Q You would agree, wouldn't you, that you 5 targeted these underage girls including 6 because of their young age? 7 MR. Argumentative, speculative, 8 harassing. Assumes facts not in evidence. 9 A I would like to answer that question, as 10 well as most of the other questions you've asked 11 me here today. My counsel has advised me that I 12 must assert my Fourteenth Amendment, Sixth 13 Amendment and Fifth Amendment right. Though I 14 would like to answer those questions today... if 15 I do so, I risk losing their representation. 16 Q You would also agree, wouldn't you, that 17 you targeted these underage females for sex, 18 including , because they were poor? 19 MR. l= Same objections. 20 A I would like to answer that question. I 21 would really like to answer that question, as 22 well as the other questions you've asked me here 23 today, however, on advice of my counsel they've 24 demanded that I assert my Fifth Amendment, Sixth 25 Amendment and Fourteenth Amendment rights. If I EFTA01724116 166 1 answer that question, I risk losing their 2 representation. 3 Q You would agree, wouldn't you, that you 4 sexually for three years? 5 MR. Same objection. 6 A I think you've asked me that question 7 before. I assert the same rights as before. 8 Q That's the Fifth, Sixth and Fourteenth 9 amendments, just so the record is clear? 10 A Yes. 11 Q You would agree, wouldn't you, that you 12 coerced into prostitution? 13 MR. Same objections. 14 A I believe her own testimony reflects, at 15 least the sworn statement to the FBI, reflects 16 that that is not the case; and though I would 17 like to answer that question in great detail, I 18 cannot do so today on advice of counsel, that 19 have asked me to assert my Sixth Amendment, Fifth 20 Amendment and Fourteenth Amendment rights. If I 21 do so, I risk losing their representation. 22 Q You would agree with me that you groomed 23 into becoming a prostitute? 24 MR. I'm going to object. 25 Argumentative, speculative. Certainly lacks EFTA01724117 167 1 predicate and assumes facts not in 2 evidence. 3 A You know I would like to answer that 4 question, but I can't today. Under advice of 5 counsel I have to assert my Fourteenth Amendment, 6 Sixth Amendment and Fifth Amendment rights. If I 7 answer the question, I risk losing their 8 counsel. 9 0 You would agree, wouldn't you, that you 10 brainwashed into believing that this 11 lifestyle of prostitution was right? 12 MR. Same objections. 13 A I would like to answer that question, as 14 most of your other questions here today, Mr. 15 On advice of counsel today, I'm going 16 to have to assert my Fifth Amendment, Sixth 17 Amendment, Fourteenth Amendment rights. If I 18 answer that question, I risk losing their 19 representation. 20 Q Would you agree that your interaction 21 with when she was a minor, was degrading to 22 her? 23 MR. Same objections. 24 A I would like to answer that question. I 25 would like to answer all of your questions here EFTA01724118 168 1 today; however, my counsel has advised me that I 2 must assert my Fourteenth Amendment rights, my 3 Sixth Amendment rights and my Fifth Amendment 4 rights, and though I would like to answer those 5 questions, if I do so I risk losing their 6 representation. 7 THE WITNESS: Can we take a ten-minute B break for some air? 9 MR. We have 15 minutes and 10 we're done. 11 THE WITNESS: Continue then? 12 MR. Okay. 13 Q Would you agree that you intentionally 14 indoctrinated into this very deviant sexual 15 lifestyle? 16 MR. Okay, I'm going to object. 17 It is argumentative. It is confusing. It 18 is speculative, vague, lacks predicate and 19 assumes facts not in evidence. 20 A And on top of that, I would like to 21 answer that question, but my counsel has advised 22 me I must assert my Fourteenth Amendment, Sixth 23 Amendment and Fifth Amendment rights under the 24 U.S. Constitution. Although I would like to 25 answer all your questions today, I cannot do so EFTA01724119 169 1 risking losing their representation. 2 Q Would you agree that you were personally 3 responsible for destroying her life? 4 MR. Same act objections. 5 A Her life? 6 s? 7 A I would like to answer that question, 8 and I understand how your firm has been accused 9 of fabricated sexually charged lawsuits in order 10 to fleece investors locally in South Florida. 11 The U.S. Attorney has called your law firm a 12 criminal enterprise based on filing fellacious 13 (sic) sexually charged cases. Although I would 14 like to answer that question today, Mr. 15 and Mr. IIIII, my counsel has told me that I have 16 to assert my rights under the Sixth Amendment, 17 Fifth Amendment and Fourteenth Amendment, and if 18 I don't do so, I risk losing their 19 representation. 20 Q We have a factual basis for asking every 21 question and making every allegation. I want to 22 provide you with a last opportunity to tell the 23 jury which of these allegations, if any, being. 24 made by , are false or fabricated in any 25 way? EFTA01724120 170 1 MR. Same objections. Mr. 2 you know the tenor of that question 3 cannot be answered without waiver of Fifth, 4 Sixth and Fourteenth. I appreciate the ' 5 question and the semantics of it, but it 6 is... It is -- can you rephrase it? 7 MR. Yes. 8 Q Many times -- you know the allegations 9 now, we've gone through them, 's allegations 10 and assertion of facts as to what happened 11 between you and her when she was 13, 14 and 15 12 years old and you were.50, 51, 52 years old. 13 Several times you responded saying something 14 about something 15 about her FBI statement, what have- you; I want to 16 give you a chance to tell the jury, which of her 17 allegations, if any, that you believe now are 18 false or fabricated in any way. 19 MR. Same objections. 20 A I would like to respond to that 21 question, the fact that her firm, the law firm 22 representing her has been accused by the U.S. 23 Attorney of being a criminal enterprise, 24 manufacturing, fabricating, out of thin air, 25 cases involving sexual allegations, sexual EFTA01724121 171 1 allegations in order to simply fleece local 2 investors out of millions of dollars, so I would 3 very much like to answer that question regarding 4 the truthfulness of 's allegations; however 5 today my counsel has told me that I must assert 6 my Fifth Amendment rights, Sixth Amendment rights 7 and Fourteenth Amendment rights under the U.S. B Constitution, though I would very much like to 9 answer that questions but if I do I risk losing 10 their representation. 11 Q Would you agree you owe at least 12 $15,000,000 to compensate her for the damage 13 which you have caused? 14 MR. Objection. I move to 15 strike. Argumentative. Compound. Lacks 16 substantial predicate. Assumes... -facts... 17 not in evidence. 18 A As you might imagine, though your law 19 firm has been accused of perpetrating a fraud 20 involving millions and millions of dollars, on 21 unsuspecting investors here in South Florida, 22 millions of dollars by fabricating similar 23 allegations, convincing people to give money to 24 the firm that helped bring this lawsuit, I'm 25 afraid I would like to answer those questions but EFTA01724122 172 1 no matter how much I would like to answer those 2 questions, I am going to have to decline based on 3 my counsel's advice to invoke, at least today, my 4 Fifth Amendment, Sixth Amendment and Fourteenth 5 Amendment rights under the U.S. Constitution; 6 because if I don't, I risk losing their 7 representation. 8 Q Is it true that you're currently worth 9 more than one billion dollars personally? 10 A I would like to answer that question, as 11 I would like to answer most of your other 12 questions. I know that's a lot of money -- 13 actually the amount of money that the U.S. 14 attorneys accused your firm of trying to steal 15 from the people of South Florida. It was 1.2 16 billion dollars, the U.S. Attorney claimed your 17 firm perpetrated the largest fraud in South 18 Florida's history by stealing that sum of money 19 from local investors, based on false allegations 20 of sexually charged claims, and although I would 21 like to answer these questions with specificity, 22 under advice of counsel today, I'm going to have 23 to refuse, based on my Sixth Amendment, 24 Fourteenth Amendment and Fifth Amendment right, 25 and though I would like to answer the question, I EFTA01724123 173 1 have been told if I do so I risk losing their 2 representation, Mr. 3 Q I'm simply asking: What is your 4 personal net worth at this time? 5 MR. Form. 6 A I think I've answered the question, 7 but... 8 Q What is your personal net worth at this 9 time? So the answer should be a number or should 10 be you invoking your Fifth Amendment rights. 11 Seemed like the opposite. 12 MR. Asked and ansyered, he did 13 invoke his Fifth, Sixth and Fourteenth. 14 MR. His answer included 15 something about =III'', and 16 stealing some certain amount of money, 17 which obviously is nonresponsive, I move to 18 strike it and ask that he actually responds 19 to the question with something that's 20 responsive. He can answer the question, 21 invoke Fifth Amendment rights, and we will 22 get out of here. 23 Q We will start over again. 24 Can you please tell the jury what your 25 current personal net worth is currently? EFTA01724124 174 1 A I would like to do that today, however, 2 I'm sure that one of the reasons, since your firm 3 has been accused of stealing millions of dollars 4 from local investors based on fabricated, totally 5 fabricated claims, this is not by me but the U.S. 6 Attorney, has called your firm a criminal 7 enterprise charged with stealing hundreds of 8 millions of dollars frankly, from local 9 investors, based on false claims of sexually 10 charged nature, I would like to answer that 11 question in detail. However, my attorneys have 12 advised me I cannot answer any qugstions that may 13 be relevant to this lawsuit and by doing so, I 14 must invoke my Sixth Amendment, Fifth Amendment, 15 Fourteenth Amendment right and by answering the 16 question, I risk losing their representation. 17 Q Is it true you're worth 1.8 billion 18 dollars? 19 MR. Same objection. 20 A Same answer. 21 Q Put the answer. 22 MR. For the record. 23 A I'm sure that's an interesting question 24 and I would like to answer that question for 25 you. I'm sure you would like to know as your EFTA01724125 175 1 firm has been charged with stealing over a 2 billion dollars from local investors and your 3 senior partner of both you and Mr. sitting 4 there shaking his head, sits in jail accused of 5 fleecing local and foreign investors based on 6 false sexual claims from people. And although I 7 would like to answer that question, like I would 8 answer most of your other questions, my counsel 9 has advised me today, ladies and gentlemen of the 10 jury, I cannot answer that question. Maybe I can 11 in the future. However, if I do so today, I risk 12 losing their representation, so I must assert 13 those rights under the Sixth, Fifth and 14 Fourteenth amendments. 15 Q You would agree, would you not, that it 16 would take a jury award of at least 45 million 17 dollars in punitive damages to punish you for 18 doing what you did to 19 MR. Same objections. 20 A I would like to answer that question, as 21 I would like to answer all your other and Mr. 22 's questions today. However, while he sits 23 shaking his head I'm going to have to respond 24 to -- my counsel has advised me I cannot answer 25 that question today, though I would like to. EFTA01724126 176 1 Though I would like to.answer with specificity, 2 however if I, do so, I xisk losing their 3 representation so I must assert my rights under 4 Sixth, Fifth and Fourtebnth Amendment. S Q Isn't it true, Mr. Epstein, that as long 6 as you have the money to do it, you will continue 7 to engage in sex with minors? 8 MR. Again, extremely 9 argumentative, speculative. I'm allowing 10 the question to give leeway, so we don't 11 have to come back here again. It is 12 harassing. 13 A And with that, I'm sure this -- ladies 14 and gentlemen of the jury, be able to see 15 you and your partner, who your firm has been 16 accused of massive fraud in South Florida trying 17 to steal hundreds of millions of dollars from 18 local investors, from creating, fabricating 19 malicious, sexually charged claims, called by the 20 U.S. Attorney a criminal enterprise charged with 21 money laundering, conspiracy to commit other -- 22 federal violations, so though I would like to 23 answer that question, Mr. and Mr. 24 today, I cannot. I must invoke my Sixth, Fifth 25 and Fourteenth Amendment rights, on advice of EFTA01724127 177 1 counsel or risk losing their representation. 2 Q Am I correct in my understanding that 3 you have invoked your Fifth Amendment rights 4 because your answers would incriminate you and S lead to your prosecution? 6 MR. I'm going to -- 7 MR. Exactly as phrased by Mr. 8 to IIII I did not say anything but 9 allow her to answer the question. 10 MR. Object to the form. 11 A In fact, since you are a lawyer I'm sure 12 you're aware the Supreme Court has said the Fifth 13 Amendment is used more often to protect innocent 14 people. So that's -- but today on advice of 15 counsel I've taken that right. 16 MR. (Gesturing.) 17 MR. I have no questions. 18 We will read. 19 MR. No further questions. 20 THE VIDEOGRAPHER: Off the video record, 21 3:52 p.m. 22 THE COURT REPORTER: Can he read your 23 copy Mr. 24 MR. Yes. 25 THE COURT REPORTER: Thank you all. EFTA01724128 ' 178 1 MR. On the record,.I don't want a 2 word index. 3 THE COURT REPORTER: Okay. 4 (Discussion off the record.) 5 MR. I would like this tomorrow, 6 please. 7 Let's go regular but definitely before 8 that -- before Tuesday, if possible. 9 THE COURT REPORTER: Sure, that will be 10 50 percent expedite? 11 MR. That's fine. 12 THE COURT REPORTER: My pleasure. 13 (Time noted: 4:00 o'clock p.m.) 14 15 16 17 18 19 20 21 22 23 24 25 EFTA01724129 179 1 THE STATE OF FLORIDA) 2 COUNTY OF PALM BEACH) 3 I, a Registered 4 Professional Reporter and Notary Public for the 5 State of Florida at Large, do hereby certify that 6 I reported the videotaped deposition of JEFFREY 7 EPSTEIN, the DEFENDANT, called by the PLAINTIFF 8 in the above-entitled action; that the witness 9 was duly sworn by me; that the foregoing pages, 10 numbered from 1 to 183, inclusive, constitute a 11 true record of the deposition by said witness. 12 I further certify that I am not attorney 13 or counsel of any of the parties, nor a relative 14 or employee of any attorney or counsel connected 15 with the action, nor financially interested in 16 the action. 17 WITNESS MY HAND and official seal in the 18 City of West Palm Beach, County of Palm Beach, 19 State of Florida, this 22nd day of February 2010. 20 21 Registered Professional Reporter and 22 Notary Public, State of Florida at Large. My Commission expires 23 March 13, 2011. 24 25 • EFTA01724130 18.0 1 THE STATE OF FLORIDA) 2 COUNTY OF PALM BEACH) 3 4 5 The foregoing certificate was 6 acknowledged before me this 7 day of 2009, by 8 'mg, who is personally known to me. 9 10 11 12 13 14 15 Notary Public, State of Florida. 16 My commission No. Expires March 13, 2011. 17 18 19 20 21 22 23 24 25 EFTA01724131 181 1 I, JEFFREY EPSTEIN, do hereby 2 certify that I have read the foregoing transcript 3 of my deposition given on February 17, 2010; that 4 together with the correction page attached hereto 5 noting changes in form or substance, if any, it 6 is true and correct. 7 8 JEFFREY EPSTEIN 9 10 11 12 13 14 I do hereby certify that the deposition 15 of JEFFREY EPSTEIN was submitted to the witness 16 for reading and signing; that after he had stated 17 to the undersigned Notary Public that he had read 18 and examined her deposition, he signed the same 19 in the presence of the undersigned authority on 20 the day of 2010. 21 22 23 24 25 EFTA01724132 182 1 ERRATA SHEET 2 In Re: V. EPSTEIN 3 DO NOT WRITE ON TRANSCRIPT ENTER CHANGES HERE: 4 5 PAGE LINE CHANGE REASON 6 7 8 9 10 11 12 13 14 15 JEFFREY EPSTEIN 16 17 18 THE STATE OF FLORIDA) 19 COUNTY OF PALM BEACH) 20 I DO HEREBY CERTIFY THAT JEFFREY EPSTEIN appeared before me and stated that he has read 21 his deposition; further, that this Errata Sheet was signed in my presence on this day 22 of 2010. 23 24 25 EFTA01724133 183 1 U.S. LEGAL SUPPORT Registered Professional Reporters 2 444 West Railroad Avenue Suite 300 3 West Palm Beach, Florida 33401 (561)835-0220 4 February 22, 2010 5 6 • 7 8 10 11 12 13 Since counsel have agreed that you may 14 have the witness read and sign your copy of the deposition, for your convenience, enclosed 15 herewith you will find an Errata Sheet for the witness' use in entering any changes to the 16 deposition. 17 Thank you for your prompt attention. 18 Cordially yours, U.S. LEGAL SUPPORT West Palm Beach, Florida 33401 ATTENTION: In Re: V. EPSTEIN Deposition of: JEFFREY EPSTEIN Dear Mr. 19 20 Registered 21 Professional Reporter, Notary Public, State of Florida at 22 Large. My commission expires March 13, 2011. 23 CC: 24 25 EFTA01724134 UNCLASSIFIED FEDERAL BUREAU OF INVESTIGATION Precedence: IMMEDIATE To: Miami From: Miami PB-3/PBCRA Contact: Approved By: Drafted By': Case ID #: 31E-MM-108062 (pending) Title: JEFFREY EPSTEIN; Date: 03/11/2011 Attn: ASAC SSA SA ason is ar s GHISLAINE MAXWELL; WSTA - CHILD PROSTITUTION Synopsis: Update case file as to interview conducted by writer on March 9, 2011. Details: On March 7, 2011, PB-3 SSA and CE-1 Branch ASAC concurMitt m illequests from AUSA A. Maritillitillial!!ige writer join her in a telephone call to in on March 7, 2011 and accom an AUSA Villafana to an interview on March 9, 2011 with 111111111 11 (protect identity) and proL.ec On the evening of March 7, 2011, AUSA Villafana and writer placed a telephone call to indicated she is willing to cooperate fully witharril involving JEFFREY EPSTEIN and others. She has requested to meet with FBI Agents in along with the for the debra ".ng. On March 9, 2011, AUSA A. Marie Villafana, and IMF Private Investigator protect !tin and writer met for the interview at the United States Attorney's Office in Fort Lauderdale, Florida. UNCLASSIFIED EFTA01724135 UNCLASSIFIED To: Miami From: Miami Re: ??31E-MM-108062, 03/11/2011 and provided information about crimes unciMituring the lel...civil investigation of EPSTEIN by Mr. office. These allegations include possible perjutrillies against EPSTEIN, which is outlined in the February 17, 2010 deposition transcript; possible allegations of human trafficking of underage females by EPSTEIN to high-level public officials and others; and obstruction of justice. has also made contact with about her relationshir. EPSTEIN, to include allegations o human trafficking and child exploitation, not previously known b investigators and prosecutors. explained that would like to make a formal statement to the Federal Bureau o Investigation and cooperate in any criminal investigation. provided documents obtained during the civil investigation or review. Below is the list of items produced to writer: 1 CD containing: 1. Deposition of 2. Deposition of 3. Deposition of 4. Deposition of .5. Deposition of 6. Deposition of 7. Deposition of 8. Deposition of 9. Deposition of 10. Deposition of III) 11. Deposition of Juan (Vol II only) 12. Statement of 13. Confidentiality agreement with Ghislaine Maxwell 14. Jeffrey Epstein Probation File Hard copies of the following documents: 1. Complete flight logs from Jeffrey Epstein plane 2. Non-Prosecution Agreement 3. Transcript of Jeffrey Epstein Deposition taken on February 17, 2010 . vs. Epstein) 4. Court Reporter Affidavit (not signed) (Vol I and II) (Vol I only) Davi Rogers no transcript) !!!!!!!!!!!!!ez (both parts) Vo I, II and UNCLASSIFIED 2 EFTA01724136 UNCLASSIFIED To: Miami From: Miami Re: ??31E-MM-108062, 03/11/2011 5. Copy of portion of Jeffrey Epstein probation file showing Jean Luc Brunel staying at Jeffrey Epstein residence 6. Violation of Probation of Jeffrey Epstein Two DVDs containing the videotaped Deposition of Jeffrey Epstein on February 17, 2010 Evidence obtained during interview will be turned over to case agent SA Jason Richards. UNCLASSIFIED 3 EFTA01724137 UNCLASSIFIED To: Miami From: Miami Re: ??31E-MM-108062, 03/11/2011 LEAD(s): Set Lead 1: (Info) MIAMI AT MIAMI, FLORIDA Read and clear. Set Lead 2: (Action) MIAMI AT WEST PALM BEACH, FLCRIDA (PB-2) • • Determine if follow-up interview of is warranted. Contact Legat or interview if appropriate. UNCLASSIFIED 4 in in EFTA01724138 ITEM(S) CANNOT BE SCANNED DESCRIPTION 3 cus EFTA01724139 • EFTA01724140 EFTA01724141 EFTA01724142 C c—, ( • FD-340 (Fee.. 4-11-03) File Number Field Office Acquiring Evidence MI N\ / P C2J C—C2A - Serial # of Originating Document Date Received O.-4• From 31 E-MIA- logoLg._-/4 90. (Name of Contributor/Interviewee) By (Address) (City and Slate) 54-E. A) e.E.40.-HCi c kiwg.1 To Be Returned 0 Yes ca—aa Receipt Given 0 Yes O -"No Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e) Federal Rules of Criminal Procedure O Yes Federal Taxpayer Information (F11) O Yes Title: O-fir 0- Reference: (Communication Enclosing Martial) Description: 0 Original notes re interview of 0 Li ca'? 4-X c-ov- . . ••••:!' • • • • t•ji 0".• 0,-4• v EFTA01724143 I EFTA01724144 Florida D.A.V.I.D. Individual Summary Page Page 1 of I STATE OF FLORIDA Department of Highway Safety & Motor Vehicles Driver And Vehicle information Database (DAVID) I DIGITAL MAGES ARE RESTRICTED TO LAW ENFORCEMENT USE PURSUANT TO S. 722.142(4), FLORIDA STATUTES - MUtGES INCLUDE PHOTOGRAPHS MC SiGNATIIFtFS Individual Summary Page DI II) Number Class Status VALID MRS W PALM BCH FL 33415 All Addresses On File Date of Birth Sex Hei ght State Of Birth Restrictions Endorsements Issue Date Duplicate Ex iration Date Date SSN Form Number Conditional Messages: UNDER 21 UNTIL: SAFE DRIVER Law enforcement officers may continue to accept the insurance card indicating Property Damage only, as also including PIP, until lunc 30. 2008. Vehicle Information Record VIN I Type I Color I Body I Make I Acquired Date I Reg Driver Licence Transactions Record DI 'ID Number ransactian Date Update Time is T Issue Type hange Type FL Dis View 11-01.06 J11-02-06 20:29:11 ID Duplicate& View View 07-31.06 08-01-06 22: I 5:014 ID Duplicate& 11-20-03 1 I-20-03 10:09:16 ID Original Nose Historical Driver License Activity Vehicle Insurance I Previous Vehicles Photo Array I Signature Array I New Search I Main Menu https://www.hsmv.flejn.net/servlet/DI _Summary 6/6/2008 EFTA01724145 . Page 1 of 2 Goole EFTA01724146 other events may cause road conditions to differ from the map results. Map data ©2006 NAVTEQT" =U... 6/26'2008 EFTA01724147 Page I of Got sic Address 6 6 21 08 EFTA01724148 s.ATUIE/oROINANCI:- LEVEL-FELONY ,2ND DEG UISP-TREATED AS AUULT CHAkOE 002-LARCENY- GRAND 3RD DEGREE DWEL PROP 100 TO UND 300 DULS STATUTE/ORDINANCE- LEVEL-FELONY ,3RD DEG DISP-TREATED AS ADULT • ••II THE FOLLOWING IS A STATUS RECORD.. --.NOT AN ARREST --CONTINUED-- • • *• SID NUMBER: PURPOSE CUDE:C PAGE: 6 ARREST- 4 02/01/2007 OBTS NO. ARREST AGENCY-PALM BEACH COUNTY SHERIFF'S OFFICE . AGENCY CASE . OFFENSE DATE- CHARGE 001-CRIMINAL REGISTRATION.(NOT AN ARREST)- . • REF BURG DWEL GRAND THEFT DWEL' DISP-TREATED'AS ADULT. -a. JUVENILE ARREST- 5 03/09/2007 OBI'S NO. ARREST AGENCY-DEPARTMENT OF CORRECTIONS AGENCY CASE- OFFENSE DATE-03/09/2007 CHARGE 001-PROB VIOLATION- . OR CUMMTY CONT EE UNK FEL MISD JUV NON CRITHIA --CONTINUED-- SID NUMBER:. PURPOSE CODE:C PAGE: 7 STATUTE/ORDINANCE- LEVEL-FELONY DISP- JUVENILE ARREST- 6' 08/08/2007. OBTS NO. ARREST'AGENCY-DEPARTMENT OF CORRECTIONS ( AGENCY CASE OFFENSE DATE-08/08/2007 CHARGE 001-PROB'VlULATION- UR CUMMTY CONT'RE UNK FEL M1SD JUV NON CRITRIA' STATUTE/ORDINANCE- LEVEL-FELONY DISP- -TURNED OVER TO ANOTHER AGENCY • ' SID NUMBER: PURPOSE CODE:C PAGE: ' JUDICIAL- AGENCY-15TH CIRCUIT COURT - WEST PALM BEACH CHARGE 001 -COURT SEQ COURT NO.- SUPPLEMENTAL ARREST DATA- STATUS-REARREST. ,UBT LEVEL-FELONY THIS RECURD CONTAINS FLORIDA INFORMATION ONLY. WHEN EXPLANATION OF A CHARGE OR DISPOSITION IS NEEDED, COMMUNICATE DIRECTLY WITH -THE AGENCY THAT CONTRIBUTED THE RECORD INFORMATTON. THIS RECORD MAY ONLY BE USED FOR CRIMINAL JUSTICE PURPOSES AS DEFINED BY THE CODE OF FEDERAL REGULATIONS. THIS IS A SINGLE-STATE OFFENDER REcORO. END OF RECORD --ERD-- L.\ rkl-A EFTA01724149 FG.L.a.PUR/Cal SnMBER: nFURPOSE CODE:C PAGE: 1 BECAUSE ADDITIUNs OR DELETIONS MAY BE MADE AT ANY TIME, A NEW COPY SHOULD BE REQUESTED WHEN NEEDED FOR FUTURE USE 4.* THIS CRIMINAL HISTORY CONTAINS A JUVENILE ARREST RECORD - FLORIDA CRIMINAL HISTORY - NAME SIAM. ID. NO. FBI NU. DATE REQUESTED 06/26/2006 IWM N IF IR ' X t DATE HEIGHT WEIGHT EYES HAIR BIRTH PLACE SKIN DOC NO. --CONTINUED-- SID NUMBER: II FINGERPR4N1 CLASS IN AVIS - 2 OCCUPATION ADDRESS CITY/STATE WPB, FL PURPOSE CODEiC . PAGE: 2 SOCIAL SECURITY NO: MISCELLANEOUS NO. bukti MRKil AT AKA DOB SOC SCR/MRK/TAT . • UED-- SID NUMBER: PURPOSE CODE:C PAGE: 3 UVENILE *. ARREST- 1 02/28/2006 OBTS NO.- ARREST AGENCY-PALM BEACH COUNTY SHERIFF'S OFFICE AGENCY CASE- OFFENSE DATE-02/28/2006 CHARGE 001-SWgi- ' INTENT THREAT TO DO VIOLENCE-DOM VIOL STATUTE/ORDINANCE- LEVEL-,RISDEMEANOR,2ND DEG DISP- CHAiG4-002-RESISTING OFFICER- OBSTRUCT WO VIOLENCE STATUTE/ORDINANCE- LEVEL-MISDEMEANOR,1ST DEG" DISP- .1 • --CONTINUED-- SID NUMBER: PURPOSE CODE:C ' PAGE: '4 ARREST- :2 10/06/56006 OBTS NO. ARREST AGENCY-PALM BEACH COUNTY SHERIFF'S OFFICE (IIIIIIIIIII1 AGENCY CASE OFFENSE DATE-10/06/200.6 CHARGE 001-BURGLARY- OF STRUCTURE CONVEYANCE UNARMED WO PENS INSIDE • STATUTE/ORDINANCE- LEVEL-FELONY ,3RD DEG DISPTREATED AS ADULT \ CHARGE 002-LARCENY- THEFT IS 300 OR MORE BUT LESS THAN 5000 DOLS STATUTE/ORDINANCE- LEVEL-FELONY :3RD DEG DISP7TREATED AS ADULT iiINTINUED-- SID NUMBER: PURPOSE CODE:C PAGE: 5 7- 3 10/27/2006 OBTS NO. s'l AGENCYTPALM BEACH COUNTY SHERIFF'S LIFFICE ( ) ENCY CASE- OFFENSE DATE-10/27/2006 URGE 001-BURGLARY- OF DWELLING UNARMED NO ASSLT OR EJATT EFTA01724150 SEX: HEIGHT: s WEIGHT: HAIR COLOR: . EYE COLOR: LAST RES ADD: city STATE: SOC SEC NO: OPER:LIC NO: CASE NO: ENTERING MNE: ENTERING AGY: NOTIFY AGY: PROTECTED.PERSON NAME: DOB: RACE: SEX: • ADDRESS: CITY STATE: CONDITIONS: --END-- DATA - USCEULA COUNTY SHERIFF'S OFFICE /PUBLICLY AVAILABLE • ZIP: 34741 ED FROM PERSOWAND CHILD Received: 2008-:06-26 10:32:42' MSG,NBR: 00023 NNE: OR OR MESSAGE HAS BEEN SENT TO NCIG. -Recbived: 2008-06-26 10:32:43, MSS-NBR: 00024 MNE: --NCIC-- S INTERSTATE IDENTIFICATION INDEX RESPONSE 15 THE RESULT OF YOUR RECORD REQUEST FOR FBI/ THE'FOLLOWING WILL RESPOND TO YOUR AGENCY: FLORIDA - STATE ID END --END-- Received: 2008-06-26 10:32:43 MSG-NBX: 00025 NNE: S.A.CHR.HDR/ . .TNE/1137.TMZ/EDT.DTE/20080626.0RINIIIIIIII.SIDill 1.111 F61 POR/C.TOS/BASED ON F /FEU OF GAATION WEST PALM BEACH.ATN/ URIM1NAL HISTURY REQUESTED --END-- Received: 2006-06-26 10:32:57 MSG-NBR: 00026 MNE: . FC CRICHAR i\c-FLORIDA ITCH RESPONSE-- I TN/IIIIIIII/ EFTA01724151 REVEAL' - PROBATION UR SUPERVISED RELEASE STATUS RECORD - DO NOT ARREST BASED UN THIS INFORMATION - PLEASE CONTACT SUPERVISING AGENCY VIA NLETS, TELEPHONE UR EMAIL lo ADVISE OF CONTACT WITH SUPERVISED INDIVIDUAL. PLEASE BE ADVISED THAT SUPERVISING AUENCY MAY NOT BE oPERALLONAL 24/7. --FLU; HIT RESPoNsE-- #NAME HIT ts87# WARNING - Du NUT ARREST BASED ON THIS INFORMATION ALONE PROBATION OH SUPERVISED RELEASE STATUS SUBJECT MAY BE UNDER SUPERVISION OF THE FL DEPT UF LORRECTIONS CONTACT FL DEPT uF CORRECTIONS PRUB & PAN SER OR AFTER HOURS AT x50 922-68b7 CONFIRM THE STATUS AND SPECIAL CONDITIONS. ONCE THE STATUS IS CONFIRMED AND VIOLATION EXISTS AN ARREST CAN BE MADE AS AUTHORIZED IN SECTION 948.06(1)(a) FLORIDA STATUTES (2005). TU A NAME: RELEASE DATE: 01/30/2009 DUB: ENTRY DATE: 02/16/2007 RACE: PCN ' SEX: N1C: HEIGHT: DEPT CORRECTION: WEIGHT: HAIR COLOR: EYE CoLOR: SKIN TONE: BIRTH COUNTY: BIRTH PLACE:. LAST RES ADD: III CITY STATE: WEST PALM 8CH FL ZIP: SOC SEC NO: SENTENCE CRT: - PALM BEACH COUNTY CLERK OF COURTS .RELEASE LOC: 154 - W PALM - LAKE WORTH START SUPER: 01/31/2007 PROBATION EXPIRES: 01/30/2009 SUPER TYPE: RELEASE FROM SUPERVISION: SUPERVISER • NAME: PHONE NO: CASE NO: ENTERING NNE: ENTERING AGY: FDC - 150 - W PALM BEACH CIRCUIT P&P NOTIFY AGY: NO NO IFY/PUBLICLY AVAILABLE MISC: UFFENSE - BURG/bWELL/OCCUP CONVEY 01/30/2009 --IMAGE-r f • FIN: IMAGE DATE:'02/08/2007 IMAGE TYPE: AUG SHOT IMAGE ENTRY DATE: 02/16/2007, IMAGE:SIZEt BOIS-BYTES_ #NAME HIT X.85)* WARNING - Du NOT ARREST BASED ON THIS INFORMATION ALONE DOMESTIC VIOLENCE OR REPEAT VIOLENCE INJUNCT1ON/NUT WANTED THIS RECORD It STATUS INFORMATION ONLY - DO NOT ARREST BASED ON THIS INFORMATION CONTACT THE ENTERING AGENCY DIRECT FOR COMPLETE DETAILS OF THE INJUNCTION. PROTECTION ORDER SUBJECT BRADY INDI NO, MAY PURCHASE FIREARM MAMEMS DOB: RACE: ISSUE DATE: 07/19/2005 EXPIRATION DATE: NONEXP ENTRY DATE: 06/03/2007 EFTA01724152 histirdUgiAisUh Lid SUPE/IvibEO RELEASE STATUS URI4IIIIIIIIIIMAM SEX4M HAU/IIPUBIlli DOH/ HGTIMMEMWGT/ E AIIIIIISKN/ sOC/ UCA, MIS/OFFENSE - BuRs/uwELL/oecuP CONVEY DPE/200101G0 SCl/ Luc/154 - W PALM - LAKE WORTH DS'S/20070131 EDs/400901J0 DNA/N ukl IS DUG PRUB & PAROLE SERV WEST PALM BEACH 561 637-5115 NItall 1)TE/2007342lb - 18b4 ESI' 1MN/ 1MT/M REPEAT - PROBATION UR SUPERVISED RELEASE STATUS RECURD - DO NOT ARREST BASED ON THIS INFORMATION - PLEASE LUNTACT SUPERVISING AGENCY VIA NLETS, TELEPHONE OR EMAIL TO ADVISE OF GuNTACT WITH SUPERVISED INDIVIDUAL. PLEASE BE ADVISED THAT SUPERVISING AGENCY MAY NUT BE OPERATIONAL 24/1. I_MH/.M DUB: AC:. HGT MIS: WOT: NAM NIL INN: --END-- Received: 2008-06-26 10:31:10 FOI MSG-NBR: 00022 MNE: ATTN: IIIIIIII 0 r-FLUR1DA CON RESPuNS£-- GI. NAM n MI RAC/. SEX/. DUBt SOC/ POR/II 11- 4 r1:17S- CRINI1FAC ORY CONTAINS A JUVENILE ARREST RECORD el HIT NUMBER 01 4,* FLORIDA CRIMINAL HISTORY to AS OF'06/26 AT 11:3"6, AM SID/IIIIIIIIIHA/AIIII EYE RAC/I. DLT/ FPC/ REF/0000 000 HGT/III MGT/ SEXIMMKKN/ POB FB14.51.1.0.1 AFS/IN-2 UGC/ LRA/ /WFB, 'FL . OCIL/ NAM/AKA DO8 SSN tot.' - • MNU r SMT _SIATE OPP IN III -- END -- • so 44.+MESSAGE KEY CNA SEARCHES ALL NCIC PERSONS FILES WITHOUT LIMITATIONS. WARNING - DO NuT ARREST BASED ON. THIS INFuRnATIoN PIKE/ UR SUPERVISEDiRELEASE STATUS HGT URI/ AgYE/ M "NlIIII SEXAS RACIIIPOBIIIIOO8/ Sue oCA . MIS/OFFENSE - bURG/DWELL/OCCUP CONVEY DPE/200v0130 SCI/MMENIMMOO LOG/154'- W PALM - LAKE WORTH UsS/200701J1 EDS/IIIIIIIII SO11/1 n UNA/N ORI IS DOC PROS & PAROLE SERV WEST PALM BEACH SEil 831-5175 'MN/ IMT/M NIG/ DTE/ EST EFTA01724153 am====gina Received: [008-06-26 10:30:06 MSG-NBR: 00020 HNE: ATTN: --NCIC-- THIS NCIC INTERSTATE IVENTIFICAFION INDEX RESPONSE IS THE RESULT OF YOUR INwulitY ON NAM SQL. SEXiM RACillUOB, FBI NO. INQUIRY DATE '208/0b126 bEX RACE BIRTH DATE HE1GHT'WEIGHT EYES HAIR PHOTO XXX °N BIRTH PLACE FINGERPRINT CLASS ALIAS NAMES PATTERN CLASS RS LS RS WU RS LS LS LS LOOIS WU • , . / . , 'SCARS7MARKS- TAIT S SOCIAL SECURITY IDENTIFICATION DATA UPDATED 2006/10/29 THE CRIMINAL HISTORY RECORD IS MAINTAINED AND AVAILABLE FROM THE FOLLOWING: kLURIDA - sTATE:I rHE RECORD:5/ CAN BEOBTAINED THROUGH THE INTERSTATE IDENTIFICATION INDEX BY USING THE APPROPIIATE NCIC TRANSACTION. END - -END - - Received: AlTN: -06-26 101'40:06 IISG-NBR: 00021- MNE: wWi VIRGINA mle ***MESSAGE KEY QWI SEARCHES ALL NCIC PERSONS FILES WITHOUT LIMITATIONS. WARNING - DO NO1 ARREST BASED ON IRIS INFORMATION EFTA01724154 FD-340 File Number Field Office Acquiring Evidence nVAA J P SC 2_14 Serial # of Originating Document Date Received V CL41 From 31 g-151fti- los oc,a_ - lA eis (NAM or COM110031Thltervivircc) (Address) By (City and Slam) S+ G #0 es to Ak- \Ccutkic(4 (XgaA) g ro To Be Returned 0 Yes Receipt Given 0 Yes • Grand Jury Material - Disseminate Only Pwsuant to Rule 6 (e) Federal Rules of Criminal Procedure 0 yes GYNo Federal Taxpayer Information (Eli) K Yes 21( Tide: Reference- .• Wompflankation Eeclosies Material) )r" Description: 0 Original notes re interview of EFTA01724155 1 EFTA01724156 Florida D.A.V.I.D. Individual Summary Page Paul I of STATE OF FLORIDA Department of Highway Safety & Motor Vehicles Driver And Vehicle Information -Database (DAVID) DIGITAL IMAGES ARE RESTRICTED TO LAW ENFORCEMENT USE PURSUANT TO S. 322.142(4), FLORIDA STATUTES IMAGES INCLUDE PHOTOGRAPHS AND SIGNATURES Individual Summary Page SSN I DI II) Stinther Class linV 41 I ,?%1 RV ACII FL Status VALID All Addresses On File Date of Birth Scx Hei t Restrictions Endorsements Issue Date Duplicate Dale Expiration Date Form Number Conditional Messages: SAFE DRIVER State Of Birth Due to the sunset of Florida's No-Fault Law on October I, financial responsibility suspensions with a case number that starts with the number 2, 7.8. and 9 are in the process of being closed. Please disregard these suspensions if they appear on the record: Driver License Transactions Record DUID Number Transaction Date Issue Date U te Time 'Lie Type Issue Type Change Type Ft. Disp View 11-26-03 02-23-01 11-26-03 I 4:41:03 DL Duplicate None Lost View ....... , View I0-04-02 02-23-01 10-04-02 07:27:59 DL Duplicate None Lost DL Replacement None Lost 02-26-02 02-23-01 02-26-02 10:39:31 View 02-23-01 02-23-01 02-23-01 08:51:51 LL Original None Historical Driver License Activity I Vehicle Insurance Photo Array I Signature Array I New Search I Main Menu I Previous Vehicles hups://www.hsmv.ficjn.net/servlet/DLSummary 10/4/2007 EFTA01724157 Pace I of 2 STATE OF FLORIDA Department of Highway Safety & Motor Vehicles Driver And Vehicle Information Database (DAVIN) DIGITAL WOES ARE RESTRICTED TO LAW ENFORCEMENT USE PURSUANT TO S. 322.142(4), FLORIDA STATUTES IMAGES INCLUDE PHOTOGRAPHS AM) SIGNATURES Individual Summary Page DUNI Number Class 334111027 Status VALID Date of Birth Sea Height State Of Birth Restrictions Endorsements Issue Date Duplicate Ex iration Date Date SSN Fonn Number Conditional Messages: SAFE DRIVER Law enforcement officers may continue to accept the insurance card indicating Property Damage only, as also including PIP, until June 30, 2008. Vehicle Information Record I VIN Type I Color I Body I Make I Acquired Date I Reg Driver License Transactions Record DI ID Number Transaction Date Issue Date Update Time Lit Type Issue Type Change. Type-FL Disp View 02-21.08 02-21-08 10:56:39 DL Renewal None View 11-26-03 11-26-03 14:41:03 DL Duplicate None Lost View 10-04-02 10-04-02 07:27:591 DL Duplicate I None Lost View I 02-26-02 02-26-02 10:39:311 DL j Replacement Non Lost View 02-23-01 W2-23-01 OR:51:51 It Original None Historical Driver License Activity Vehicle Insurance Previous Vehicles file://CADOCUME-IMAIFBITOCALS—IkTemil 4/9/2008 EFTA01724158 Page 2 of 2 Photo Array Signature Array I New Search I Main Menu file://CADOCUME-IWIFBI\LOCALS-1 \Temp\==n 4/9/2008 EFTA01724159 Florida D.A.V.I.D. Individual Summary Page Page I of I STATE OF FLORIDA Department of Highway Safety & Motor Vehicles Driver And Vehicle Information Database (DAVII)2) DIGITAL IMAGES ARE RESTRICTED TO LAW ENFORCEMENT USE PURSUANT TO S. 322.142(4), FLORIDA STATUTES - IMAGES INCLUDE PHOTOGRAPHS AM) SIGNATURES Photo Line Up DL Number. Name: • Image sa Imacs Ninic Transaction Dale Status 02/21/2008 A 2 I 1126/2003 A SI 3 I 10/04/2002 A 4 A I SI 02/26/2002 I MEI 02/23/2001 A Individual Summary I New Search I Main Menu If you suspect driver license fraud. please contact DL r rand https://david2.hsmv.flejn.net/servlet/DLPhotoLineup 4'9/2008 EFTA01724160 Received: 2008-04-09 14:38:41 MSG-NBR: MNE: ATTN: --FLORIDA CCH RESPONSE-- QI.NAMArliarip .RACAIISFX/I.DOB/ SOC/ .PU NO CRI ORD SOC/ NO CRIMINAL HISTORY RECORD NAM/ NO NCIC WANT SOC/ NO NCIC WANT N DOB/ RAC/Us Ex/. ***MESSAGE KEYAMPR IRR I LIC PERSONS FILES WITHOUT LIMITATIONS. --FCIC HIT RESPONSE-- FQI : NO RECORDS FOUND --END-- EFTA01724161 Received: 2008-04-09 14:38:13 MSG-NBR: ATTN: KUYRKENDALL N --NCIC-- NO FIABLE RECORD IN THE NCIC INTERSTATE IDENTIFICATION INDEX (III) FOR NAM/ IME.=KSOC/ .S Exa RAC DOB/ END --END-- EFTA01724162