To: 'eevacation mail.com[[email protected]] From: Sent: Thur 9/27/2012 12:37:17 AM Subject: Yo If you have any news about Opium group.please let me know I have a question about. deposition An advice...I want to ask how to focus on the right point etc... EFTA_R1_00304878 EFTA01887693
Case 9:08-cv-80119-KAM Document 66 Entered on FLSD Docket 03y26/2009 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO. 3, MOTION TO CONSOLIDATE CASES FOR PURPOSES OF DISCOVERY, AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT Non-party witness, Jane Doe No. 3, by and through undersigned counsel, files this Motion for Protective Order and to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate Cases for Purposes of Discovery, and Memorandum of Law in Support, as follows: I. Introduction This is one of six (6) related cases in this Court against Defendant Jeffrey Epstein, each alleging that the Defendant sexually assaulted the plaintiff when she was a minor. This Motion is prompted by the Defendant's efforts to take the deposition of Jane Doe No. 3 as a witness in this case. Defendant, however, does not at this time seek to take Jane Doe No. 3's deposition in her own case. The Defendant apparently intends to take Jane Doe No. 3's deposition at least twice, and as discussed below, most likely three times. Plaintiff Jane Doe No. 3 alleges that she is a victim of sexual assault by Defendant Epstein. To compel her to sit for deposition by Epstein's attorney more than once would be unduly traumatizing, burdensome, annoying, harassing and, most importantly, unnecessary. There is no -1- EFTA00221676 Case 9:08-cv-80119-KAM Document 66 Entered on FLSD Docket 03i26/2009 Page 2 of 10 conceivable good faith basis for Defendant's attorney to require that Jane Doe No. 3's deposition to be taken more than once. Accordingly, this Motion seeks to limit Defendant's counsel to a single deposition of Jane Doe No. 3, encompassing her claims as a party in her own case and as a witness in any other case pending in this Court against Defendant Epstein alleging sexual misconduct. As a corollary to this relief, Plaintiff moves for consolidation of the six (6) related cases for purposes of pretrial discovery pursuant to Fed.R.Civ.P. 42(a). II. Background and Relevant Facts The cases Jane Doe No. 2'. Epstein case no. 08-CV-80119-Marra/Johnson Jane Doe No. 3 I. Epstein, case no. 08-CV-80232- Marra/Johnson, Jane Doe No. 4'. Epstein, 08-CV-80380- MARRA/JOHNSON, Jane Doe No. 5'. Epstein, case no. 08-CV-80387- Marra/Johnson Jane Doe No. 61. Epstein case no. -CV-80994- Marra/Johnson and Jane Doe No. 7 I. Epstein case no. 08- 80993-CIV- Marra/Johnson, are related cases in this Court.' These cases have been treated jointly for purposes of pretrial scheduling and deadlines. The Court entered a single Order Setting Trial and Discovery Deadlines et al., dated September 29, 2008, in the four cases Jane Does 2-5'. Epstein, (DE 45). The Jane Doe No. 6 and Jane Doe No. 7 cases, which were filed later, were likewise treated jointly and a single Order Setting Trial Date and Discovery Deadlines et al. entered for those cases dated December 18, 2008. On September 25, 2008, the parties filed a single Joint Scheduling and Discovery Report in the four cases, Jane Doe Nos. 2-5. (DE 44). In this Report, the Plaintiff takes the position that it would be in the interests of judicial economy and efficiency to consolidate these cases at least for ' In all of the cases Jane Doe Nos. 2-7'. Epstein, the Plaintiffs are represented by the same counsel. There are other similar cases pending in this Court and in state court against Defendant Epstein in -2- EFTA00221677 Case 9:08-cv-80119-KAM Document 66 Entered on FLSD Docket 03;26/2009 Page 3 of 10 discovery purposes. (Joint Report, p. 5, §II(D)). The Defendant, however, states in this Report his position in opposition to consolidation for any purpose. (Id.). All of the cases Jane Doe Nos. 2-7 g. Epstein allege sexual assaults by Defendant Epstein. They all make identical claims for relief for Sexual Assault and Battery (Count I); Intentional Infliction of Emotional Distress (Count II); and Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422 (Count III). Most importantly for present purposes, they all allege the same plan and scheme by Defendant Epstein to lure underage girls to his Palm Beach mansion for the purpose of giving a massage, and that he sexually molested them during the course of this massage. (ate lg.:, Jane Doe No. 3 Second Amended Complaint 7-11; Jane Doe No. 4, Second Amended Complaint, If 8-12). Jane Doe No. 3 in discovery responses served on January 26, 2009 disclosed that she brought three other girls to Epstein's mansion for the purpose giving him a massage. These other girls include Plaintiffs Jane Doe No. 2 and Jane Doe. No. 4. see Plaintiff Jane Doe 3's Answers to Interrogatories, no. 23, attached hereto as Exhibit "A"). On March 16, 2009, Defendant's counsel served a Notice of Taking Deposition of Jane Doe No. 3 in the Jane Doe No. 2 case (A copy of this Notice is attached hereto as Exhibit B).2 By letters dated March 3, 2009 and March 20, 2009, Plaintiff's counsel advised Defendant's counsel that Plaintiffs oppose the taking of their depositions more than once, and insisted that each Plaintiff's deposition be noticed in her own case as well as any other case in which she is a witness. Defendant's counsel has to date failed to respond to this correspondence, or otherwise provide any reason why he should be allowed to take a victim's deposition more than once. Absent a protective which the plaintiffs are represented by different counsel. The deposition was unilaterally scheduled for April 14, 2009. -3- EFTA00221678 Case 9:08-cv-80119-KAM Document 66 Entered on FLSD Docket 03;26:2009 Page 4 of 10 order or other relief, Defendant's counsel could take Jane Doe No. 3's deposition three times, once in her own case and as a witness in both the Jane Doe No. 2 and Jane Doe No. 4 cases. Exh. III. Argument A. A PLAINTIFF IN THESE CASES SHOULD NOT BE REOUIRED TO APPEAR FOR DEPOSITION MORE THAN ONCE The district court has discretion to fashion a protective order under Fed.R.Civ.P. 26(c). Farnsworth Procter & Gamble Co., 758 F.2d 1545 (11th Cir. 1985). This discretion "does not depend upon a legal privilege." Id.; Auto Owners Ins. Co.'. Southeast Floating Docks. Inc. 231 F.R.D. 426, 429-30 (M.D.Fla. 2005). Under Rule 26(c), "the Court may, for good cause, issue an order to protect a party or person from annoyance, embarrassment, oppression or undue burden or expense." The federal rules expressly recognize that a party should not without cause be deposed more than once. Fed.R.Civ.P. 30(a)(2)(B). "Mt is clear that the prohibition against deposing a second witness without leave of court exists to protect the witness. Indeed, cases construing Rule 30(a)(2)(B) concern protection of the deponent from, for example, undue burden or harassment." Beaulieu Bd. of Trustees 2007 WL 4468704 (N.D. Fla. 2007). See also Fed.R.Civ.P. 26(b)(2)(C)(i) (directing the court to limit the frequency or extent of discovery otherwise allowed under the rules where "the discovery sought is unreasonably cumulative or duplicative, or can be obtained from some other source that is more convenient, less burdensome, or less expensive"). Additionally, Fed.R.Civ.P. 45(c) provides that the party or attorney issuing a subpoena must take reasonable steps to avoid imposing an undue burden on the deponent, and that the Court may impose an appropriate sanction, including reasonable attorneys' fees, if the party or attorney fails to comply. -4- EFTA00221679 Case 9:08-cv-80119-KAM Document 66 Entered on FLSD Docket 03/26/2009 Page 5 of 10 In the present cases, where sexual misconduct is at issue, Jane Doe No. 3 will be unduly burdened by one or more separate depositions of her as a witness, to be followed by her deposition as a party. See Miscellaneous Docket Matter #1 . Miscellaneous Docket Matter #2, 197 F.3d 922, 925 (8th Cir. 1999) (case where sexual matters at issue, holding that district court was warranted in quashing subpoena of witness' second deposition to protect witness from embarrassment and undue burden). Defendant's counsel seeks to circumvent these rules by noticing Jane Doe No. 3's deposition first as a witness in the Jane Doe No. 2 case, apparently to be followed by her depositions in her own case and the Jane Doe No. 7 case. Such multiple depositions of Jane Doe No. 3 would be contrary to judicial economy and efficiency, and would serve only to unduly harass, annoy and burden her. Defendant's counsel has offered no reason whatsoever why Jane Doe No. 3's deposition should not be taken just once, encompassing her knowledge of facts and information relevant to all three related cases. It is inconceivable that Defendant's counsel would be prejudiced if Jane Doe No. 3 were to sit for deposition just once. Accordingly, good cause exists for a protective order preventing Defendant from taking Jane Doe No. 3's deposition piecemeal in separate cases, and requiring that the Plaintiff's deposition be taken just once, covering all of the related cases against Epstein. B. THESE RELATED CASES SHOULD BE CONSOLIDATED FOR PURPOSES OF DISCOVERY As a corollary to the protective order sought by Jane Doe No. 3, the problem of multiple depositions of any Plaintiff could be avoided by consolidating the related cases for purposes of pretrial discovery pursuant to Fed.R.Civ.P. 42(a). Consolidation may be appropriate where "actions before the court involve a common question of law or fact", and in such cases the court is authorized to issue "orders to avoid unnecessary cost or delay." Fed.R.Civ.P. 41(a)(3). "Consolidation of -5- EFTA00221680 Case 9:08-cv-80119-KAM Document 66 Entered on FLSD Docket 03)26:2009 Page 6 of 10 actions in their pretrial stage, under many circumstances, will be a desirable administrative technique and is within the power of the Court." Wright & Miller, Federal Practice & Procedure §2382 (2008). See also Eagle Building Technologies 209 F.R.C. 499, 501 (S.D. Fla. 2002) (noting that Court has broad discretion under Rule 42(a) to consolidate cases within its district). "In deciding whether to consolidate actions, we have instructed that district courts should consider whether doing so could lead to prejudice or confusion." Ramsay'. Broward County Sheriff's Office, 2008 WL 5237162 *3 (11th Cir. 2008). The common and overlapping issues in this case, both factual and legal, are patent and obvious. Here, Plaintiff moves for limited consolidation, for purposes of pretrial discovery only. Such a consolidation is common and appropriate to further the interests of judicial economy and efficiency. See, e.g., In re Enron Corp. Securities Litigation, 206 F.R.P. 427, 438 (S.D. Tex. 2002). At the same time, there is no conceivable prejudice or confusion that would result from consolidation for purposes of pretrial discovery. To the contrary, consolidation will avoid unnecessary prejudice and confusion. For example, with regard to the instant Motion, consolidation for purposes of discovery would make it clear that each party/witness can only be deposed once, covering all issues in the related cases. WHEREFORE, Plaintiff respectfully requests (i) a protective order pursuant to Fed.R.Civ.P. 26(c) requiring that the deposition of Jane Doe No. 3 be taken no more than once, for purposes of all of the related case to which her testimony may be relevant; (ii) an order pursuant to Fed.R.Civ.P. 45 quashing the unilateral nonparty subpoena for deposition of Jane Doe No. 3 in this case; (iii) an order pursuant to Fed.R.Civ.P. 42(a) consolidating the Jane Doe Nos. 2-7'. Epstein cases for purposes of pretrial discovery; and (iv) such other and further relief as this Court deems just and proper. -6- EFTA00221681 Case 9:08-cv-80119-KAM Document 66 Entered on FLSD Docket 03i26/2009 Page 7 of 10 Dated: March 26, 2009 Respectfully submitted, By: s/ Stuart S. Merrnelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. Attorneysfor Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 -7 - EFTA00221682 Case 9:08-cv-80119-KAM Document 66 Entered on FLSD Docket 03 26 2009 Page 8 of 10 CERTIFICATE PURSUANT TO S.D.FIA.L.R. 7.1(A)(3) Counsel for Plaintiff has made reasonable efforts to confer with counsel for Defendant, by letters dated March 3, 2009 and March 20, 2009 and by telephone, seeking in good faith to resolve or narrow the issues raised in the Motion, but Defendant's counsel failed to respond to Plaintiff's letters, and Plaintiff's counsel has been unable to resolve this dispute. s/ Stuart S. Mermelstein -8- EFTA00221683 Case 9:08-cv-80119-KAM Document 66 Entered on FLSD Docket 03)26:2009 Page 9 of 10 CERTIFICATE OF SERVICE I hereby certify that on March 26, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing. /s/ Stuart S. Mermelstein -9- EFTA00221684 Case 9:08-cv-80119-KAM Document 66 Entered on FLSD Docket 03/26/2009 Page 10 of 10 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger. Esq. [email protected] Robert D. Critton, Esq. [email protected] /s/ Stuart S. Mermelstein - 10- EFTA00221685
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION ) ) Plaintiff, ) CASE NO.: 502008CA028051XXXXMB ) vs. ) ) JEFFREY EPSTEIN, ) ) Defendant. ) ) SUBPOENA FOR DEPOSITION THE STATE OF FLORIDA: TO: Louella Friedman YOU ARE COMMANDED to appear before a person authorized by law to take depositions on Tuesday, August 18, 2009 at 2:00 p.m., at Esquire Court Reporters, 515 N Flagler Dr., West Palm Beach, FL 33401.for the taking of your deposition in this action and to have with you at that time and place the following: N/A. If you fail to appear, you may be in contempt of court. You are subpoenaed to appear by the following attorneys and unless excused from this Subpoena by these attorneys or the Court you shall respond to this Subpoena as directed. DATED on August/A*009. Bradley J. Edwards , 5n22 Rothstein Rosenfeldt Adler For The Court 401 EastLas Olas Blvd Suite 1650 Fort Lauderdale, Florida 33301 Florida Bar No.: 542075 1 EFTA00730351
0016 1 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 CASE No. 502008CA037319XXXXMB AB 3 4 5 =., 6 Plaintiff, 7 - vs- 8 9 JEFFREY EPSTEIN, 10 Defendant. 11 12 13 CONTINUED DEPOSITION OF JEFFREY EPSTEIN 14 VOLUME II 15 16 Thursday, October 8, 2009 17 18 10:07 - 1:03 p.m. 19 20 250 South Australian Avenue Suite 1400 21 West Palm Beach,Florida 33401 22 23 Reported By: Jeana Ricciuti, RPR, FPR, CLR 24 Notary Public, State of Florida Prose Court Reporting Agency, Inc. 25 0017 1 APPEARANCES: 2 On behalf of the Plaintiff: SPENCER T. KUVIN, ESQUIRE 3 ADAM LANGINO, ESQUIRE LEOPOLD KUVIN, P.A. 4 2295 PGA Boulevard Suite 200 5 Palm Beach Gardens, Florida 33410 Phone: 6 On behalf of IIM. and III. and Jane Doe in Case No. 7 80893: CARA L. HOLMES, ESQUIRE 8 ROTHSTEIN, ROSENFELDT & ADLER 401 East Las Olas Boulevard 9 Suite 1650 Fort Lauderdale, Florida 33301 10 Phone: 11 On behalf of Plaintiff Jane Doe in Case No. 80591 and 80656 via telephone: 12 KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK, P.A. 13 25 West Flagler Street Miami, Florida 33130 14 Phone: 15 On behalf of the Defendant: JACK GOLDBERGER, ESQUIRE 16 STORY KOWLES, PARALEGAL ATTERBURY, GOLDBERGER & WEISS, P.A. EFTA01158522 17 250 South Australian Avenue Suite 1400 18 West Palm Beach, Florida 33401 Phone: 19 MICHAEL J. PIKE, ESQUIRE 20 BURMAN, CRITTON, LUTTIER & COLEMAN, P.A. 303 Banyan Boulevard 21 Suite 400 West Palm Beach, Florida 33401 22 Phone: 23 ALSO PRESENT: 24 DAN DOSKEY, VIDEOGRAPHER VISUAL EVIDENCE, INC. 25 0018 1 INDEX 2 3 WITNESS: DIRECT CROSS REDIRECT RECROSS 4 JEFFREY EPSTEIN 5 BY MR. KUVIN 21 6 7 8 EXHIBITS 9 10 NUMBER DESCRIPTION PAGE 11 PLAINTIFF'S EX. 1 FDLE SEXUAL 24 OFFENDER/PREDATOR FLYER 12 PLAINTIFF'S EX. 2 STATEMENT 25 PLAINTIFF'S EX. 3 PHOTOGRAPH OF HOME 33 13 PLAINTIFF'S EX. 4 BOTTLE OF JOY JELLY 38 PLAINTIFF'S EX. 5 PHOTOGRAPH OF GIRL 129 14 PLAINTIFF'S EX. 6 PHOTOGRAPH OF GIRL 129 PLAINTIFF'S EX. 7 PHOTOGRAPH OF GIRL 131 15 PLAINTIFF'S EX. 8 PHOTOGRAPH OF GIRL 132 16 17 18 19 20 21 22 23 24 25 0019 1 PROCEEDINGS 2 3 Deposition taken before Jeana Ricciuti, Registered 4 Professional Reporter and Notary Public in and for the 5 State of Florida at Large, in the above cause. 6 7 THE VIDEOGRAPHER: We're on the video record. 8 This is the 8th day of October, 2009, and the time 9 it approximately 10:07 a.m. 10 This is the continuation of the videotaped 11 deposition of Jeffrey Epstein in the matter of 12 versus Epstein. This deposition is being held at 13 250 South Australian Avenue, No. 1400 in West Palm 14 Beach, Florida. 15 My name is Dan Doskey I'm the videographer EFTA01158523 16 representing Visual Evidence, Incorporated. 17 Would the attorneys present please announce 18 their appearances for the record? 19 MR. KUVIN: Spencer Kuvin and Adam Langino on 20 behalf of the Plaintiff, §§§. 21 MS. HOLMES: Cara Holmes for III. 22 MR. PIKE: Michael Pike on behalf of 23 Jeffrey Epstein. 24 MR. GOLDBERGER: And Jack Goldberger on behalf 25 of Jeffrey Epstein. 0020 1 Kathy, do you want to identify yourself? 2 Kathy, are you there? 3 MS. EZELL: Yes. 4 MR. PIKE: She puts it on mute every once in a 5 while. 6 MR. GOLDBERGER: Hey, Kathy, are you there? 7 MS. EZELL: Yes. 8 MR. GOLDBERGER: Just -- we're just 9 identifying everyone who's on this thing. Can you 10 just identify yourself? 11 MS. EZELL: Yes. It's Kathy Ezell. I'm 12 sorry, Kathy Ezell is here. 13 - - - 14 Thereupon, 15 (JEFFREY EPSTEIN) 16 having been first duly sworn or affirmed, was examined 17 and testified as follows: 18 THE WITNESS: Yes, ma'am. 19 MR. PIKE: Pull that back, please. 20 MR. KUVIN: Back? 21 MR. PIKE: Yeah, not on the video. I want to 22 make sure it's not on the video. 23 MR. KUVIN: We're good? Thank you. 24 THE VIDEOGRAPHER: It's not. 25 DIRECT EXAMINATION 0021 1 BY MR. KUVIN: 2 Q. Could you give us your name, sir, please. 3 A. Jeffrey Epstein. 4 MR. GOLDBERGER: Kathy, you've got to put it 5 on mute. Kath -- Kathy? 6 MS. EZELL: Give me one second. 7 MR. GOLDBERGER: Just put it on mute, please. 8 MR. KUVIN: You can probably turn the volume 9 down; it won't effect her mic, I would imagine. 10 MR. GOLDBERGER: Good idea. Okay. 11 BY MR. KUVIN: 12 Q. Mr. Epstein, is your date of birth, 13 14 A. Yes. 15 Q. Race is White? 16 A. Yes. 17 Q. You are male? 18 A. Yes. 19 Q. Hair is gray? 20 A. Yes. 21 Q. Eyes are blue? 22 A. Yes. 23 Q. Height is 6-foot tall? 24 A. Correct. 25 Q. Weight is 180 pounds? 0022 EFTA01158524 1 A. Correct. 2 Q. Mr. Epstein, on January 30th of 2008, isn't it 3 true that you pled guilty to procuring a person under 4 the age of 18 for prostitution? 5 A. No. 6 Q. You did not plead guilty? 7 A. You asked me -- do you want to repeat it? 8 Q. Did you plead guilty to procuring a person 9 under the age of 18 for prostitution? 10 A. On what date? 11 Q. Regardless of the date, did you plead guilty 12 to procuring a person under the age of 18 for 13 prostitution? 14 MR. GOLDBERGER: Do you need to take a break? 15 MR. KUVIN: I'm sorry, what are we doing? 16 MR. GOLDBERGER: I'm taking a break to talk to 17 my client. 18 MR. KUVIN: For what reason? 19 MR. GOLDBERGER: Whether we have to invoke a 20 privilege or not. 21 MR. KUVIN: Okay. 22 THE VIDEOGRAPHER: Going off the record at 23 10:10. 24 (A brief recess was taken.) 25 THE VIDEOGRAPHER: We're back on the record at 0023 1 10:12. 2 BY MR. KUVIN: 3 Q. Okay. Mr. Epstein, did you plead guilty to 4 procuring a person under the age of 18 for prostitution? 5 A. I pled guilty procuring a minor, I believe, 6 for prostitution. 7 Q. When did you plead guilty to that charge? 8 A. On June the 30th. 9 Q. And did you procure a minor for prostitution 10 in compliance with that charge? 11 A. I fully intend to respond to all relevant 12 questions regarding this lawsuit; however, at the 13 present time, my attorneys have counseled me I cannot 14 provide answers to any questions relevant to this 15 lawsuit. I must accept this advice or risk losing my 16 6th Amendment right to effective representation. 17 Accordingly, I assert my federal constitutional rights 18 as guaranteed by the 5th, 6th and 14th Amendment to the 19 US Constitution. 20 Q. Okay. I'd like to mark as Exhibit 1 the 21 Florida Department of Law Enforcement Sexual 22 Offender/Predator Flyer. 23 MR. KUVIN: For the record, let me show that 24 to Mr. -- well, let me show that to the camera, 25 first. 0024 1 Okay. Let me know when you have it. 2 (Plaintiff's Exhibit No. 1 was marked for 3 identification.) 4 THE VIDEOGRAPHER: Okay. 5 MR. KUVIN: Okay? 6 BY MR. KUVIN: 7 Q. All right. Let me show you this sexual 8 offender/predator flyer. Is that you, sir? 9 A. It's a photograph of me, yes. 10 Q. Okay. Is that the predator flyer for you? 11 A. No, it is not. EFTA01158525 12 Q. Who's it for? 13 A. It's a sexual offender flyer. 14 Q. I'm sorry, I was reading the title where it 15 says "Predator Flyer." Do you see that? 16 A. It actually said "Sexual Offender/Predator" 17 because it's used for both categories. And if you'll 18 notice, the designation says sexual offender, which is 19 extremely different than sexual predator. 20 Q. What's your understanding of the difference 21 between the two? 22 A. I'm not -- I know I'm a sex -- I've been 23 registered as a sexual offender. 24 Q. Why are you a sexual offender? 25 MR. GOLDBERGER: Jeff. 0025 1 THE WITNESS: I fully intend to respond to all 2 relevant questions regarding this lawsuit; however, 3 at the present time, my attorneys have counseled me 4 I cannot provide answers to any questions relevant 5 to this lawsuit. I must accept this advice or risk 6 losing my 6th Amendment right to effective 7 representation. Accordingly, I have to assert my 8 federal constitutional rights as guaranteed by the 9 5th, 6th and 14th Amendment to the US Constitution. 10 MR. KUVIN: Let's go ahead and I'd like to 11 mark what you're reading from here today as Exhibit 12 2 to the deposition. 13 (Plaintiff's Exhibit No. 2 was marked for 14 identification.) 15 BY MR. KUVIN: 16 Q. Who prepared that document for you, sir? 17 MR. GOLDBERGER: Don't answer that question, 18 Jeffrey. It's attorney-client privileged and this 19 is my work product, and we're not marking it, so... 20 MR. KUVIN: I don't think you have the right 21 to tell me what I can and can't -- 22 MR. GOLDBERGER: You can mark it all you 23 want -- 24 MR. KUVIN: It's been marked. 25 MR. GOLDBERGER: You can mark it all you want, 0026 1 but it's not -- 2 MR. KUVIN: If you choose to -- 3 MR. GOLDBERGER: It's not -- it's not being 4 admitted into evidence. 5 MR. KUVIN: Sir, please don't interrupt me. 6 Are you -- 7 MR. GOLDBERGER: I'll interrupt you -- 8 MR. KUVIN: Are you representing Mr. Epstein 9 in this deposition or is Mr. Pike? Because I want 10 to be clear which one of you is going to be doing 11 the talking during the deposition. 12 MR. GOLDBERGER: We both are representing 13 Mr. Epstein. 14 MR. PIKE: Let's go off the record for a 15 second. 16 MR. KUVIN: No, we're not going off the 17 record. We're staying on the record and only one 18 attorney may speak at a time. 19 So right now, I'd like you all to choose. I 20 don't mind, either one of you can inject -- 21 MR. PIKE: Hold on a second. 22 MR. KUVIN: -- and represent Mr. Epstein. EFTA01158526 23 MR. GOLDBERGER: Let -- let -- let him finish. 24 Let him finish. 25 MR. KUVIN: Let me finish, please. 0027 1 Either one of you can represent Mr. Epstein, 2 but I don't want objections flying from both 3 chairs, both Mr. Epstein's criminal lawyer and his 4 civil lawyer. 5 So I'd ask you to please choose which one is 6 going to object, just like Judge Hafele has 7 required at hearings that only one attorney can 8 represent Mr. Epstein in an argument at a hearing. 9 MR. GOLDBERGER: Actually, we have two 10 different roles in this matter. I represent 11 Mr. Epstein on all criminal matters, so I'm going 12 to speak when I think it's relevant to any criminal 13 matters. And Mr. Pike represents Mr. Epstein on 14 any civil matters, and he will speak when it's 15 relevant to any civil matters. 16 BY MR. KUVIN: 17 Q. Okay. Sir, can I please have the paper back, 18 which has already been marked as Exhibit 2? 19 MR. KUVIN: Mr. Goldberger, if you choose that 20 this document is not to be produced in this case, I 21 have no objection to you sealing that document 22 until such time as Judge Hafele decides the issue 23 as to whether or not I'm allowed to mark something 24 that the witness is reading in a deposition. Is 25 that fair to you? 0028 1 MR. GOLDBERGER: You can mark anything you 2 want to mark. Go ahead and mark it, and then we'll 3 go from there. 4 MR. KUVIN: Okay, sounds good. Thank you very 5 much. 6 BY MR. KUVIN: 7 Q. Okay, sir. What I've marked as Exhibit 2, did 8 you prepare that document? 9 MR. GOLDBERGER: Attorney-client. 10 THE WITNESS: Attorney-client privilege. 11 BY MR. KUVIN: 12 Q. Sir, you are reading from a document, are you 13 not, when I ask you certain questions? 14 MR. GOLDBERGER: Attorney-client. 15 BY MR. KUVIN: 16 Q. The document that you're reading from is 17 Exhibit 2 that's in front of you right now. 18 MR. GOLDBERGER: Attorney-client. 19 BY MR. KUVIN: 20 Q. Why do you feel a need to read from a document 21 with respect to the issues of whether or not you have a 22 5th Amendment right? 23 MR. GOLDBERGER: Attorney-client. 24 BY MR. KUVIN: 25 Q. Sir, with respect to the last questions I was 0029 1 asking you about, the difference between a sexual 2 offender and a sexual predator, when Mr. Goldberg piped 3 up and said your -- 4 MR. GOLDBERGER: Goldberger. Goldberger. 5 BY MR. KUVIN: 6 Q. -- I'm sorry, Mr. Goldberger said your name in 7 order to clue you in to object on 5th Amendment EFTA01158527 8 grounds -- 9 MR. GOLDBERGER: Form. 10 BY MR. KUVIN: 11 Q. -- did you feel a need to respond at that 12 point? 13 MR. PIKE: Object to the form. 14 MR. GOLDBERGER: The invocation of 5th 15 Amendment privileges is going to be decided by me, 16 as Mr. Epstein's criminal counsel. I will make 17 that decision. 18 MR. KUVIN: Okay. I would just like to note 19 for the record that that's improper. That's not 20 what the case law says, and we'll take that up -- 21 MR. GOLDBERGER: Fair enough. 22 MR. KUVIN: -- issue with Judge Hafele? 23 BY MR. KUVIN: 24 Q. All right, sir. Do you consider yourself a 25 sexual offender or a sexual predator, which one? 0030 1 A. I fully intend to respond to all relevant 2 questions regarding this lawsuit; however, at the 3 present time, my attorneys have counseled me I cannot 4 provide answers to any questions relevant to this 5 lawsuit. I must accept this advice or risk losing my 6 6th Amendment right to effective representation. 7 Accordingly, I assert my federal constitutional rights 8 as guaranteed by the 5th, 6th and 14th Amendment to the 9 US Constitution. 10 Q. Sir, do you like having things inserted in 11 your anus for sexual gratification? 12 MR. PIKE: Objection, argumentative, 13 harassing. 14 THE WITNESS: I fully intend to respond to all 15 relevant questions regarding this lawsuit; however, 16 at the present time, my attorneys have counseled me 17 I cannot provide answers to any questions relevant 18 to this lawsuit. I must accept this advice or risk 19 losing my 6th Amendment right to effective 20 representation. 21 BY MR. KUVIN: 22 Q. Do you live at 35 -- 23 MR. GOLDBERGER: Hold on. 24 THE WITNESS: Excuse me, let me finish. Is 25 that fair. 0031 1 BY MR. KUVIN: 2 Q. Absolutely. I certainly want you to finish. 3 A. Accordingly, I assert my federal 4 constitutional rights as guaranteed by the 5th, 6th and 5 14th Amendment to the US Constitution. 6 Q. Sir, do you live at 358 El Brillo Way, Palm 7 Beach, Florida? 8 A. I fully intend to respond to all relevant 9 questions regarding this lawsuit; however, at the 10 present time, my attorneys have counseled me I cannot 11 provide answers to any questions relevant to this 12 lawsuit. I must accept this advice or risk losing my 13 6th Amendment right to effective representation. 14 Accordingly, I assert my federal constitutional right as 15 guaranteed by the 5th, 6th and 14th Amendment to the US 16 Constitution. 17 Q. I noticed that Mr. Goldberger shook his head 18 when I asked you where you lived. Do you have a problem EFTA01158528 19 letting us know where you live? 20 I'm trying to understand why that issue is 21 protected by the 5th Amendment, given the fact that 22 you're required to live at that address pursuant to the 23 sexual offender flyer and pursuant to the Court's order 24 convicting you based on your guilty plea. 25 MR. PIKE: Form, argumentative. 0032 1 THE WITNESS: Do you want to repeat the 2 question? 3 BY MR. KUVIN: 4 Q. Sure. Did the Court require you to stay at 5 358 El Brillo Way on Palm Beach -- 6 (Interruption in the proceedings.) 7 BY MR. KUVIN: 8 Q. Sir, did the Court require you to stay at 358 9 El Brillo Way, Palm Beach, Florida subsequent to you 10 being released from prison? 11 MR. PIKE: Form. 12 THE WITNESS: I fully intend to respond to all 13 relevant questions regarding this lawsuit; however, 14 at the present time, my attorneys have counseled me 15 I cannot provide any answers to questions relevant 16 to this lawsuit. I must accept this advice or risk 17 losing my 6th Amendment right to effective 18 representation. Accordingly, I assert my federal 19 constitutional rights as guaranteed by the 5th, 20 6th and 14th Amendment to the US Constitution. 21 BY MR. KUVIN: 22 Q. Let's go ahead and mark as Exhibit 3 a nice 23 photo of your home. 24 (Plaintiff's Exhibit No. 3 was marked for 25 identification.) 0033 1 BY MR. KUVIN: 2 Q. Okay. Let's get this for the camera, if I 3 could. Okay. 4 All right. I'm going to show you what I've 5 marked as Exhibit 3. Is that a photograph of your home, 6 sir, at 358 El Brillo Way? 7 A. I fully intend to respond to all relevant 8 questions regarding this lawsuit; however, at the 9 present time, my attorneys have counseled me I cannot 10 provide answers to any questions relevant to this 11 lawsuit. I must accept this advice or risk losing my 12 6th Amendment right to effective representation. 13 Accordingly, I assert my federal constitutional rights 14 as guaranteed by the 5th, 6th and 14th Amendment to the 15 US Constitution. 16 Q. I had asked you before whether or not you 17 liked things inserted in your anus for sexual 18 gratification, and I'd like to go back to that for a 19 moment, if I could. 20 Have you read the police report, incident 21 report, on your arrest? 22 MR. PIKE: Form, argumentative, harassing. 23 MR. GOLDBERGER: Attorney-client work product. 24 BY MR. KUVIN: 25 Q. Sir, according to the report, there was a 0034 1 purple item retrieved from your trash at 358 El Brillo 2 Way that appeared to be a device known as a jelly anal 3 wand. Have you ever heard of something like that? EFTA01158529 4 MR. PIKE: Form, argumentative, harassing. 5 Same objections, attorney-client work product. 6 THE WITNESS: I fully intend to respond to all 7 relevant questions regarding this lawsuit; however, 8 at the present time, my attorneys have counseled me 9 I cannot provide answers to any questions relevant 10 to this lawsuit. I must accept this advice or risk 11 losing my 6th Amendment right to effective 12 representation. Accordingly, I assert my federal 13 constitutional rights as guaranteed by the 5th, 6th 14 and 14th Amendment to the US Constitution. 15 BY MR. KUVIN: 16 Q. Outside of your home at 358 El Brillo Way was 17 also recovered a 3-inch purple-sized finger -- I'm 18 sorry, a 3-inch purple finger-sized object which had a 19 broken end, which is apparently a sexual toy similar -- 20 similar to a cyclone vibrator possibly used for rectal 21 gratification. 22 Do you know what a cyclone vibrator is? 23 A. No. 24 MR. PIKE: Form, harassing. 25 THE WITNESS: No, but I do know that that 0035 1 MR. PIKE: Same objections. 2 THE WITNESS: -- broken purple object turned 3 out to be, later on, described as a salad fork from 4 the kitchen, strictly something that had been 5 broken in the dishwasher and then reported it in a 6 report obviously inaccurately. 7 BY MR. KUVIN: 8 Q. Okay. So the broken -- 9 A. Salad fork, nothing more than a broken salad 10 fork, correct. 11 Q. So the 3-inch purple finger-sized object was a 12 salad fork? 13 A. Was a broken handle of a salad fork. Yes, the 14 question has been asked and answered, I believe. 15 Q. Okay. When did you see that? 16 MR. PIKE: Form. 17 THE WITNESS: See what? 18 BY MR. KUVIN: 19 Q. Well, you called -- 20 A. See that. What's the that? 21 Q. You called it a salad fork. 22 When did you see the salad fork after the 23 police had taken it into custody? 24 MR. PIKE: Form. 25 THE WITNESS: I did not see the salad fork, 0036 1 nor did I represent that I did see the salad fork. 2 BY MR. KUVIN: 3 Q. Okay. So you have no idea what it was that 4 the police took out of the trash? 5 A. The police -- 6 MR. PIKE: Form. 7 THE WITNESS: -- filed a later report saying 8 it was a salad fork, I believe. 9 BY MR. KUVIN: 10 Q. You never saw that piece, did you? 11 A. No. 12 Q. You have no idea what it was that they took 13 out of there? 14 MR. PIKE: Form. EFTA01158530 15 THE WITNESS: I just said the police said it 16 was a salad fork, a mere salad fork misrepresented 17 in that police report, as many things have been, it 18 seems. 19 BY MR. KUVIN: 20 Q. Did they misrepresent the jelly anal wand? 21 A. I've -- 22 MR. PIKE: Form. 23 THE WITNESS: -- never heard of that before. 24 BY MR. KUVIN: 25 Q. Have you used vibrators that you've placed in 0037 1 your anus? 2 MR. PIKE: Form, objection, harassing. 3 THE WITNESS: No. 4 BY MR. KUVIN: 5 Q. You never placed anything like a vibrator in 6 your anus? 7 MR. PIKE: Same objections. 8 THE WITNESS: No. 9 BY MR. KUVIN: 10 Q. There was in a dresser of an armoire of your 11 home 12 MR. KUVIN: This is page 44, Counsel. I'd 13 like to reference it. 14 THE WITNESS: Is that marked as an exhibit? I 15 don't know what he's reading. 16 MR. PIKE: It's not marked as an exhibit. 17 THE WITNESS: The police report? 18 BY MR. KUVIN: 19 Q. No, it's not. It's my work product, much like 20 how Mr. Goldberger felt that your 5th Amendment was your 21 work product. 22 MR. KUVIN: So let's mark this as exhibit 23 what are we up to, 4? 24 COURT REPORTER: 4. 25 0038 1 (Plaintiff's Exhibit No. 4 was marked for 2 identification.) 3 MR. KUVIN: Okay. All right. If we could, 4 just get a shot of that for me. 5 Okay, thank you. 6 BY MR. KUVIN: 7 Q. According to the incident report, in a room of 8 your home -- 9 MR. PIKE: What page are you on, Counsel? 10 MR. KUVIN: Page 44. 11 MR. PIKE: What paragraph? 12 MR. KUVIN: Line 4. 13 BY MR. KUVIN: 14 Q. -- in a dresser armoire was located a bottle 15 of peach-flavored Joy Jelly, parenthetically a sexual 16 lubricant. 17 I have here something called Joy Jelly. I 18 even have peach. Do you know what that is? 19 MR. PIKE: Form objection, harassing. 20 MR. GOLDBERGER: Can you just clarify the 21 question as to where you got that? Did that come 22 from your home or from somewhere else, Mr. Kuvin? 23 MR. KUVIN: I don't think that's relevant. 24 MR. GOLDBERGER: Just curious as to what 25 you're -- you've made a big point to identify this, EFTA01158531 0039 1 this exhibit, and show it to the camera. So if my 2 client is going to answer the question, I'd like to 3 know whether it came from your home or from -- 4 whether you bought it or where it came from just so 5 he can -- just so he can accurately answer the 6 question should he choose to want to answer it. 7 MR. KUVIN: Well, he can make the choice 8 whether he wants to answer it or not. 9 MR. GOLDBERGER: All right. 10 BY MR. KUVIN: 11 Q. Do you know what that is? 12 MR. PIKE: Form objection, improper 13 hypothetical. 14 THE WITNESS: I don't understand the question. 15 BY MR. KUVIN: 16 Q. Do you know what Exhibit 4 is? 17 A. You've just described it. I have no knowledge 18 but what you've just described. 19 Q. You don't know what that's used for? 20 MR. PIKE: Form objection, harassing. 21 THE WITNESS: I've heard what you said it's 22 used for. I've never seen it before. 23 BY MR. KUVIN: 24 Q. Do you know what that, right there, Exhibit 4, 25 this peach-flavored -- 0040 1 A. You've asked me that question already. 2 Q. -- Joy Jelly, do you know what it's used for? 3 MR. PIKE: Asked and answered. 4 BY MR. KUVIN: 5 Q. Not this bottle, but Joy Jelly, do you know 6 what it's used for? 7 MR. PIKE: Same objection, harassing, asked 8 and answered. 9 BY MR. KUVIN: 10 Q. You can answer. 11 A. I've already told you. 12 Q. You still haven't answered the question. 13 MR. PIKE: Counsel, he answered the question. 14 It's been asked and answered twice. 15 MR. GOLDBERGER: Let's get a read-back on 16 this. 17 MR. KUVIN: Sure. I'd like to hear the 18 answer. 19 MR. GOLDBERGER: From the start of the line of 20 questioning. 21 COURT REPORTER: From the first time it was 22 asked? 23 MR. GOLDBERGER: Yes, please. 24 (A portion of the record was read by the 25 reporter.) 0041 1 MR. GOLDBERGER: That's all I need to hear, 2 thanks. 3 BY MR. KUVIN: 4 Q. Do you know what Joy Jelly is used for? 5 A. I've heard what you've just described. I have 6 no independent knowledge. 7 Q. You've never used Joy Jelly? 8 A. I fully intend to respond to all relevant 9 questions regarding this lawsuit; however, at the 10 present time, my attorneys have counseled me I cannot EFTA01158532 11 provide an answer to any questions relevant to this 12 lawsuit. I must accept this advice or risk losing my 13 6th Amendment right to effective representation. 14 Accordingly, I assert my federal constitutional rights 15 as guaranteed by the 5th, 6th and 14th Amendment to the 16 US Constitution. 17 Q. You agree with me that Joy Jelly is a sexual 18 lubricant that's used on sexual devices like vibrators 19 and anal jelly wands? 20 MR. PIKE: Same objections. 21 THE WITNESS: I have no knowledge of that. 22 BY MR. KUVIN: 23 Q. Do you agree that Joy Jelly is a sexual 24 lubricant? 25 A. I have no knowledge of that. 0042 1 MR. PIKE: Form, lack of predicate. 2 BY MR. KUVIN: 3 Q. Have you used it? 4 MR. PIKE: Same objection, lack of predicate, 5 no foundation, harassing. 6 THE WITNESS: I fully intend to respond to all 7 relevant questions regarding this lawsuit; however, 8 at this time, I cannot provide any questions [sic] 9 relevant to the lawsuit. I must accept counsels' 10 advice or risk losing my 6th Amendment right to 11 effective representation. Accordingly, I assert my 12 federal constitutional rights as guaranteed by the 13 5th, 6th and 14th Amendment to the US Constitution. 14 BY MR. KUVIN: 15 Q. Would you agree with the description that you 16 are a pervert? 17 MR. PIKE: Same objection, harassing, 18 argumentative. 19 BY MR. KUVIN: 20 Q. You can answer. It's either a simple yes or 21 no. 22 A. I fully intend to respond to all relevant 23 questions regarding this lawsuit; however, at the 24 present time, my attorneys have counseled me that I 25 cannot provide answers to any questions relevant to this 0043 1 lawsuit. I must accept this advice or risk losing my 2 6th Amendment right to effective representation. 3 Accordingly, I must assert my federal constitutional 4 rights as guaranteed by the 5th, 6th and 14th Amendment 5 of the US Constitution. 6 Q. Have any mental health counselors diagnosed 7 you as a sexual deviant? 8 MR. PIKE: Again, form -- 9 THE WITNESS: I don't believe so. 10 MR. PIKE: -- work product. 11 BY MR. KUVIN: 12 Q. Do you believe you're a sexual deviant? 13 MR. PIKE: Form. 14 THE WITNESS: No, I do not. 15 BY MR. KUVIN: 16 Q. Do you have sex with minors? 17 MR. PIKE: Same objection, form, 5th 18 Amendment. 19 THE WITNESS: I fully intend to respond to all 20 relevant questions regarding this lawsuit; however, 21 at the present time, my attorneys have counseled me EFTA01158533 22 I cannot provide answers to any questions relevant 23 to this lawsuit. I must accept this advice or risk 24 losing my 6th Amendment right to effective 25 representation. Accordingly, I assert my federal 0044 1 constitutional rights as guaranteed by the 5th, 6th 2 and 14th Amendment to the US Constitution. 3 BY MR. KUVIN: 4 Q. Would you agree that you have a psychological 5 disorder with respect to your sexual preferences? 6 MR. PIKE: Same objection. 7 THE WITNESS: I fully intend to respond to all 8 relevant questions regarding this lawsuit; however 9 at the present time, my attorneys have counseled me 10 I cannot provide answers to any questions relevant 11 to this lawsuit. I must accept this advice or risk 12 losing my 6th Amendment right to effective 13 representation. Accordingly, I assert my federal 14 constitutional rights as guaranteed by the 5th, 15 6th and 14th Amendment to the US Constitution. 16 BY MR. KUVIN: 17 Q. Have you had sex with transsexuals? 18 MR. PIKE: Same objection. 19 THE WITNESS: No. 20 BY MR. KUVIN: 21 Q. Do you know a Ms. Cordero? 22 A. I fully intend to respond to all relevant 23 questions regarding this lawsuit; however, at the 24 present time, my attorneys have counseled me I cannot 25 provide answers to any questions relevant to this 0045 1 lawsuit. I must accept this advice or risk losing my 2 6th Amendment right to effective representation. 3 Accordingly, I assert my federal constitutional rights 4 as guaranteed by the 5th, 6th and 14th Amendments to the 5 US Constitution. 6 Q. Do you know a Ms. 7 MR. PIKE: Same objection. a THE WITNESS: I fully intend to respond to all 9 relevant questions regarding this lawsuit; however, 10 at the present time, my attorneys have counseled me 11 I cannot provide answers to any questions relevant 12 to this lawsuit. I must accept this advice or risk 13 losing my 6th Amendment right to effective 14 representation. Accordingly, I assert my federal 15 constitutional rights as guaranteed by the 5th, 16 6th and 14th Amendment to the US Constitution. 17 BY MR. KUVIN: 18 Q. When do you intend to fully respond? 19 MR. PIKE: Same objection. In addition, work 20 product, attorney-client. 21 BY MR. KUVIN: 22 Q. I'm sorry, I misquoted you. You said I -- 23 you've repeated now numerous times, "I fully intend to 24 respond," so let me rephrase my question. 25 When do you fully intend to respond? 0046 1 MR. PIKE: Same objection, attorney-client, 2 work product. 3 MR. KUVIN: Are you telling him not to answer? 4 MR. PIKE: It's attorney-client, work product. 5 I'm instructing him not to answer. 6 BY MR. KUVIN: EFTA01158534 7 Q. Okay. So despite the fact that you're reading 8 this canned statement over and over to my questions, you 9 don't want to answer any questions about the written 10 statement; isn't that true? 11 MR. PIKE: Same objection, attorney-client, 12 work product. I'm instructing the witness not to 13 answer. 14 BY MR. KUVIN: 15 Q. You don't ever fully intend to respond to 16 anything, do you? 17 MR. PIKE: Same objection. 18 BY MR. KUVIN: 19 Q. Or would you like to? 20 MR. PIKE: Same objection. Now we're getting 21 borderline harassing and argumentative. 22 I think you should move on to -- certainly you 23 didn't come here to be argumentative and harassing 24 all day, Mr. Kuvin, so I would hope that you would 25 move on to another topic. 0047 1 THE WITNESS: Jack? 2 MR. KUVIN: I'm just looking. 3 MR. GOLDBERGER: He can look at it all he 4 wants. 5 Just ask for permission next time, if you want 6 to, because it is something that I gave to my 7 client. So when you want to look -- I've let you 8 mark it. If you want to look at it, just ask my 9 permission to do so, okay? 10 MR. KUVIN: Sure. 11 MR. GOLDBERGER: Is that all right with you? 12 MR. KUVIN: Perfectly fine. 13 MR. GOLDBERGER: Thanks. 14 BY MR. KUVIN: 15 Q. Your typed paper there says that you cannot 16 provide answers. Why not? 17 MR. PIKE: Attorney-client, work product. I'm 18 instructing him not to answer. It's my work 19 product. 20 MR. KUVIN: Are you stipulating that you 21 drafted the document we've marked as Exhibit 2? 22 MR. GOLDBERGER: No such stipulation. 23 MR. PIKE: No such stipulation. 24 MR. KUVIN: Well, if it's work product -- 25 MR. PIKE: It's attorney-client, work product. 0048 1 MR. KUVIN: -- I just wanted to clarify. 2 BY MR. KUVIN: 3 Q. Did you have a sexual relationship with 4 when she still had a penis? 5 MR. PIKE: Same objection. 5th Amendment. 6 THE WITNESS: I fully intend to respond to all 7 relevant questions regarding this lawsuit; however, 8 at the present time, my attorneys have counseled me 9 I cannot provide answers to any questions relevant 10 to this lawsuit. I must -- I must accept this 11 advice or risk losing my 6th Amendment right to 12 effective representation. Accordingly, I assert my 13 federal constitutional rights as guaranteed by the 14 5th, 6th and 14th Amendment to the US Constitution. 15 BY MR. KUVIN: 16 Q. Do you know 17 A. I fully intend to respond to all relevant EFTA01158535 18 questions regarding this lawsuit; however, at the 19 present time, my attorneys have counseled me I cannot 20 provide answers to any questions relevant to this 21 lawsuit. I must accept this advice or risk losing my 22 6th Amendment right to effective representation. 23 Accordingly, I assert my federal constitutional rights 24 as guaranteed by the 5th, 6th and 14th Amendment to the 25 US Constitution. 0049 1 Q. You agree, do you not, that is, 2 or as least was, your personal assistant for many years? 3 MR. PIKE: Same objection. 4 THE WITNESS: I fully intend to respond to all 5 relevant questions regarding this lawsuit; however, 6 at the present time, my attorneys have counseled me 7 I cannot provide answers to any questions relevant 8 to this lawsuit. I must accept this advice or risk 9 losing -- 10 MR. GOLDBERGER: Why don't you -- why don't 11 you wait until he's listening, so he... 12 MR. KUVIN: Oh, I don't need to listen. I've 13 heard it many times. 14 MR. GOLDBERGER: No, we're going to wait. 15 We're going to wait. 16 MR. KUVIN: Oh, no, you don't have to wait. 17 MR. GOLDBERGER: Oh, no, we will. 18 BY MR. KUVIN: 19 Q. Okay. I'm sorry, are you done? 20 A. No. 21 Q. Oh, please finish. 22 A. I must accept this advice or risk losing my 23 6th Amendment right to effective representation. 24 Accordingly, I assert my federal constitutional rights 25 as guaranteed by the 5th... 0050 1 Q. Okay. Go ahead. Don't wait for me. 2 A. -- 5th, 6th and 14th Amendment to the US 3 Constitution. 4 Q. Okay. You agree, would you not, that 5 is currently dating Story Kowles, the 6 gentleman who is sitting here in the room working for 7 Mr. Goldberger at your deposition? 8 A. I fully intend to respond to all relevant 9 questions regarding this lawsuit; however, at the 10 present time, my attorneys have counseled me I cannot 11 provide answers to any questions relevant to this 12 lawsuit. I must accept their advice or risk losing my 13 6th Amendment right to effective representation. 14 Accordingly, I assert my federal constitutional rights 15 as guaranteed by the 5th, 6th and 14th Amendment to the 16 US Constitution. 17 Q. Do you know how long has been 18 dating Mr. Story Kowles? 19 A. I fully intend to respond to all relevant 20 questions regarding this lawsuit; however, at the 21 present time, my attorneys have counseled me I cannot 22 provide answers to any questions relevant to this 23 lawsuit. I must accept this advice or risk losing my 24 6th Amendment right to effective representation. 25 Accordingly, I assert my federal constitutional right as 0051 1 guaranteed by the 5th, 6th and 14th Amendment to the US 2 Constitution. EFTA01158536 3 Q. Did you introduce to Story Kowles? 4 A. I fully intend to respond to all relevant 5 questions regarding this lawsuit; however, at the 6 present time, my attorneys have counseled me I cannot 7 provide answers to any questions relevant to this 8 lawsuit. I must accept this advice or risk losing my 9 6th Amendment right to effective representation. 10 Accordingly, I assert my federal constitutional rights 11 as guaranteed by the 5th, 6th and 14th Amendment to the 12 US Constitution. 13 Q. Are you aware that one of the State 14 prosecutors, Dahlia Weiss, who was working on your 15 criminal case, was also married to a lawyer working for 16 Mr. Goldberger here? 17 MR. GOLDBERGER: Attorney-client, work 18 product. 19 Don't answer. 20 MR. KUVIN: I'm sorry, work product? 21 Somebody's marriage? 22 MR. GOLDBERGER: Uh-huh. Don't answer it. 23 MR. KUVIN: I'd like an explanation as to how 24 someone's marriage is work product on the record so 25 I can be clear to determine whether I need to bring 0052 1 that question up in front of Judge Hafele. 2 MR. PIKE: The rules do not require for 3 speaking objections, and we're going to limit 4 ourself to form and the appropriate objections 5 thereafter, which have been asserted. So there 6 does not need to be anything in the record. Should 7 you wish to file a motion, you can do so. 8 MR. KUVIN: Well, before I file such motion, I 9 think the rules also dictate that I can request an 10 explanation, which I'm doing. 11 MR. PIKE: We've already objected. 12 MR. KUVIN: Okay. 13 BY MR. KUVIN: 14 Q. Do you know Dahlia Weiss? 15 A. I fully intend to respond to all relevant 16 questions regarding this lawsuit; however, at the 17 present time, my attorneys have counseled me I cannot 18 provide answers to any questions relevant to this 19 lawsuit. I must accept this advice or risk losing my 20 6th Amendment right to effective representation. 21 MR. GOLDBERGER: Actually, I'll let you answer 22 the question as asked, as to do you know Dahlia 23 Weiss. 24 THE WITNESS: No, I do not. 25 0053 1 BY MR. KUVIN: 2 Q. With respect to Mr. Goldberger, your criminal 3 attorney, did you buy him a brand new BMW? 4 MR. GOLDBERGER: Don't. 5 THE WITNESS: I fully intend to respond to all 6 relevant questions regarding this lawsuit; however, 7 at the present time, my attorneys have counseled me 8 I cannot provide answers to any questions relevant 9 to this lawsuit. I must accept this advice or risk 10 losing my 6th Amendment right to effective 11 representation. 12 MR. GOLDBERGER: It's also attorney-client and 13 work product as to my fees. EFTA01158537 14 THE WITNESS: Accordingly, I assert my federal 15 constitutional rights as guaranteed by the 5th, 6th 16 and 14th Amendment to the US Constitution. 17 MR. GOLDBERGER: I'm sorry, it's also 18 attorney-client work product as to my fees. 19 BY MR. KUVIN: 20 Q. Have you bought any new cars for your civil 21 attorneys, like Mr. Critton? 22 MR. PIKE: Objection, relevance. 23 BY MR. KUVIN: 24 Q. Robert Critton. 25 MR. PIKE: Argumentative, harassing, not 0054 1 reasonably calculated to lead to admissible 2 evidence in this case. 3 THE WITNESS: No. 4 BY MR. KUVIN: 5 Q. It's a shame. 6 MR. GOLDBERGER: What was that? 7 THE WITNESS: Shame, he said. 8 BY MR. KUVIN: 9 Q. Why not? 10 MR. PIKE: Objection, relevance. I'm going to 11 instruct him not to answer the question. It's 12 argumentative. 13 BY MR. KUVIN: 14 Q. Is there anyone else that you know that is 15 dating staff at Mr. Goldberger's office other than 16 and Ms. Wife -- Ms. Weiss? 17 MR. PIKE: Objection, form. 18 MR. GOLDBERGER: Whoa, whoa, whoa. First of 19 all, let's get the question right. and 20 Ms. Weiss are dating each other; is that the 21 question? 22 MR. KUVIN: No, I'll clarify. 23 MR. GOLDBERGER: Thank you. 24 BY MR. KUVIN: 25 Q. Is there anyone else that you know that's 0055 1 dating staff at Mr. Goldberger's office other than 2 , or married to staff working for 3 Mr. Goldberger other than Ms. Weiss? 4 MR. GOLDBERGER: There are people -- 5 MR. PIKE: Objection, form, multiple, 6 compound, vague, irrelevant, not reasonably 7 calculated to lead to admissible evidence. 8 MR. GOLDBERGER: Do you understand the 9 question? The question as asked: Do you know 10 anyone who dates anyone at my office? 11 THE WITNESS: This is why -- this is why we're 12 here? 13 MR. GOLDBERGER: I mean, do you know -- the 14 question is: Do you know if anyone in my office 15 dates anybody? 16 THE WITNESS: No, I do not. 17 MR. GOLDBERGER: Okay. 18 BY MR. KUVIN: 19 Q. That's a good point. I'm glad you made it. 20 No, you know why we're here? We're here to 21 ask you whether or not you had any sexual contact with 22 III. Did you? 23 A. Who? 24 Q. With a young girl that was 14 years old. EFTA01158538 25 A. What was her name? 0056 1 Q. ION. 2 A. Can you refresh my recollection who she -- do 3 you have anything to show me, something that might -- 4 Q. I do, and I will pursuant to the 5 confidentiality that we've previously discussed in this 6 case. 7 A. So tell me who it is that you're representing? a Q. I will do that. 9 Have you had sex with numerous girls underage? 10 A. You've asked me if this -- which question -- 11 MR. GOLDBERGER: Wait, the question was -- 12
From: Lesley Groff
From: Jean Luc Brunel
Sent: Thursday, September 27, 2012 12:37 AM
To: [email protected]
Subject: Yo
If you have any news about Opium group.please let me know I have a question about. deposition An advice...I want to
ask how to focus on the right point etc...=?xml version=.0" encoding=TF-8"?>
From: Matthew I. Menchel <
Sent: Tuesday, February 1, 2011 2:35 PM
To: 'Jeffrey Epstein'
Subject: RE: Re:
Unfortunately, no I'=ve got a deposition that I'm taking in Florida on the 14thth (which I think I menti=ned to you) but I
am giving a lecture during lunchtime and then flying home th=t evening. I could meet you for a late lunch on that day.
Othe=wise, I probably won't be back until around mid-March.
Matthew I. Menchel
KOBRE & KIM LLP4o:p>
www.kobrekim.com
782 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, VS. ALAN M. DERSHOWITZ, Defendant. VIDEOTAPE CONTINUED DEPOSITION OF ALAN M. DERSHOWITZ VOLUME 6 Pages 782 through 909 Wednesday, January 13, 2016 1:05 p.m. - 3:06 p.m. Tripp Scott 110 Southeast 6th Street Fort Lauderdale, Florida Stenographically Reported By: Kimberly Fontalvo, RPR, CLR Realtime Systems Administrator EFTA01138160 783 1 APPEARANCES: 2 On behalf of Plaintiffs: 3 SEARCY, DENNEY, SCAROLA 4 BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard 5 West Palm Beach, Florida 33402-3626 BY: JACK SCAROLA, ESQ. 6 7 8 On behalf of Defendant: 9 COLE, SCOTT & KISSANE, P.A. Dadeland Centre II - Suite 1400 10 9150 South Dadeland Boulevard Miami, Florida 33156 11 BY: THOMAS EMERSON SCOTT, JR., ESQ. 12 BY: STEVEN SAFRA, ESQ. (Via phone) 13 --and-- 14 WILEY, REIN 17769 K Street NW 15 Washington, DC 20006 BY: RICHARD A. SIMPSON, ESQ. 16 17 18 19 20 21 22 23 24 25 EFTA01138161 784 1 APPEARANCES (Continued): 2 3 On behalf of Jeffrey Epstein: 4 DARREN K. INDYKE, PLLC 575 Lexington Ave., 4th Fl. 5 New York, New York BY: DARREN K. INDYKE, ESQ. (Via phone) 6 7 On behalf of 8 BOIES, SCHILLER & FLEXNER, LLP 401 E. Las Olas Blvd., Ste. 1200 9 Fort Lauderdale, Florida 33301 BY: SIGRID STONE MCCAWLEY, ESQ. 10 11 12 ALSO PRESENT: 13 Edward J. Pozzuoli, Special Master 14 Sean D. Reyes, Utah Attorney General Office 15 Marcy Martinez, Videographer 16 17 18 19 20 21 22 23 24 25 EFTA01138162 785 1 INDEX 2 Examination Page 3 4 VOLUME 6 (Pages 782 - 909) 5 6 Certificate of Oath 906 Certificate of Reporter 907 7 Read and Sign Letter to Witness 908 Errata Sheet (forwarded upon execution) 909 8 9 PLAINTIFF EXHIBITS 10 11 No. Page 12 26 Business card of Jeffrey B. Levy, 792 Esquire 13 27 2002 Article on Child Pornography 810 14 28 Miami Beach Police Case Report Detail 822 15 29 Document reflecting entry for 877 16 Dershowitz, Alan 17 30 Santa Monica Police Report 885 18 19 20 21 22 23 24 25 EFTA01138163 786 1 Thereupon, the proceedings continued at 1:04 p.m. 2 VIDEOGRAPHER: Going back on the record. 3 The time is 1:04 p.m. 4 BY MR. EDWARDS: 5 Q. Sir, before we move on to the next topic, 6 I want to make sure that we have finished the 7 previous topic. 8 Is there anyone else who gave you 9 information about Paul Cassell who you can identify 10 at this time and did not otherwise this morning 11 identify? 12 A. Yes. So, immediately upon hearing of the 13 false accusation against me, I recall now that I 14 Googled Paul Cassell and discovered that he was 15 called a zealot at least three times on easily 16 accessible published materials. 17 So, the term "zealot" in addition to 18 coming from individuals -- and you can get them on 19 Google as easily as I can -- 20 MR. SCAROLA: The question was, was there 21 anyone else. 22 BY MR. EDWARDS: 23 Q. I'm asking is there a person's name? 24 A. These people wrote articles. They have 25 names. EFTA01138164 787 1 Q. What are their names? 2 A. I don't recall them. You can get them. 3 You can just Google "Paul Cassell" and you will find 4 names of people who call him a zealot. 5 Q. I think maybe my question wasn't clear, so 6 I'm going to make it crystal clear. 7 A. Yes. 8 Q. Have you remembered the name of any 9 individual who you did not identify by name or 10 description this morning that provided you 11 personally with information about Paul Cassell? 12 A. A man named Hobbs, H-O-B-B-S. 13 Q. Is that a first or last name? 14 A. That's a last name. And he -- my 15 recollection is -- I don't know if he testified 16 against Paul Cassell or he just wrote an article, 17 but he wrote an article calling him a dangerous 18 zealot. 19 Q. Did you speak with Hobbs? 20 A. I don't recall if I spoke to him, but I do 21 recall reading his article or reading excerpts at 22 least from the article. 23 And then I remember reading another 24 article, may have been on Slate or -- there are a 25 number of articles calling Paul Cassell a zealot. EFTA01138165 788 1 So the name just didn't pop into my head. It was 2 something, as I said earlier, that was part of his 3 reputation. 4 Q. Okay. I will break this into two 5 questions. One, what information did you have other 6 than human interaction that may have included 7 articles or other things that you read? 8 But before I get to that question, my 9 question is, have you recalled the identity of any 10 person that you did not tell us about or describe 11 earlier this morning that provided you information 12 about Paul Cassell? 13 A. I want to wait for the -- 14 MR. INDYKE: Outside the privilege. 15 SPECIAL MASTER POZZUOLI: Excuse me? 16 A. Not that I can recall at this time. 17 BY MR. EDWARDS: 18 Q. Okay. Are there other materials that you 19 have not yet disclosed during this deposition that 20 you read, that provided you additional bases for 21 your opinions about Mr. Cassell? 22 A. Yes. 23 MR. INDYKE: Objection. 24 BY MR. EDWARDS: 25 Q. And are these materials that EFTA01138166 789 1 SPECIAL MASTER POZZUOLI: Hang on one 2 second. 3 MR. EDWARDS: Outside of the privilege. 4 MR. INDYKE: Okay. Sorry. 5 BY MR. EDWARDS: 6 Q. Are these materials that have been 7 provided already in discovery in this case? 8 A. I don't know the answer to that. I don't 9 know what has been provided and what hasn't. I can 10 just tell you that in the course of my career, I had 11 read -- I had never met Mr. Cassell, but I had read 12 his articles, and they are aptly described as 13 zealous. He once -- he was once described as 14 somebody who misused -- I think misused or uses 15 family values to hide his zealotry. But I was 16 familiar with his what are regarded as very extreme 17 writings. And that formed part of my opinion about 18 his zealotry, yes. 19 Q. What was the timing of your reading these 20 articles that helped to form a part of your opinion 21 about Mr. Cassell? 22 A. Very soon after the allegation was made. 23 Not only did I independently read, but people called 24 me and alerted me to read this, read that. People 25 sent me briefs and asked me to read them. EFTA01138167 790 1 Q. So one of the things that you took into 2 consideration in assessing the reputation or 3 credibility of Paul Cassell were various things that 4 he had written or that had been written about him? 5 A. Yes, and what people had said about him. 6 Q. Okay. 7 A. I mean, just to give you an example, if 8 you don't mind me just elaborating one second, as I 9 was getting lunch today downstairs, three people 10 came over to me. One of them said, I can't believe 11 those, and then he used the F word, scrupulous 12 unscrupulous, unethical lawyers who have done this 13 to you, this is horrible, get them, they have to pay 14 a price, they ought to be disciplined. 15 And I said, do you know me? 16 No, but I've been following this story. 17 This is just unbelievable. 18 And then two other people, one of whom 19 overheard it, said, I just want to join in on that. 20 I don't know you, but I just want you to know that 21 the lawyers who did this are beyond -- they're just 22 horrible. No decent lawyer would ever do this. 23 This happens to me all the time. People 24 come over to me all the time and tell me what they 25 think of you and Paul Cassell. EFTA01138168 791 1 Q. Okay. Where were you eating lunch today? 2 A. In a Wrap [sic] around restaurant. 3 Q. Where is it located geographically? 4 A. Right in the building. In the building. 5 Q. And are these individuals that spoke to 6 you individuals who told you that they know either 7 myself or Paul Cassell? 8 A. I didn't ask that question. It was just 9 -- it was quick conversation and one of them said, 10 I'll do anything to help. 11 Q. Okay. What is the identity of the person 12 who will do anything to help you? 13 A. His name is Jeffrey Levy. He is an 14 attorney here. 15 SPECIAL MASTER POZZUOLI: "Here" meaning 16 where? 17 A. In Fort Lauderdale. He's a family lawyer. 18 Just out of the blue, I don't know him from Adam. 19 But this happens to me all the time. When I go to 20 Miami tomorrow, I'll be walking down Lincoln Road, 21 people will come over to me and tell me about you. 22 BY MR. EDWARDS: 23 Q. Okay. Can you give me the cards of the 24 other people that have given you these cards all the 25 time so that we can -- EFTA01138169 792 1 A. No. The only reason I asked for this card 2 today, I asked him for the card because I said, I 3 want to be able to mention this if I'm asked about 4 it in the deposition. Would you mind giving me the 5 card? 6 He said, "I'm thrilled." He went to his 7 car, he got the card, and he said -- 8 MR. EDWARDS: I would like to attach the 9 card of Jeffrey Levy to the deposition as the 10 next consecutive exhibit, which I believe is 11 26. 12 (Thereupon, marked as Plaintiff 13 Exhibit 26.) 14 MR. EDWARDS: Can I see the exhibit? 15 SPECIAL MASTER POZZUOLI: Sure. 16 MR. SCOTT: Can I see the exhibit, too, 17 when you're done? 18 MR. EDWARDS: Yes. 19 BY MR. EDWARDS: 20 Q. On the back of this card, there is some 21 writing. Whose writing is that? 22 A. Mine. 23 Q. The writing, I think, says "Scarola 24 unethical e-mail"? 25 A. That's right. EFTA01138170 793 1 Q. And does that scribbling of "Scarola 2 unethical e-mail" relate at all to this card? 3 A. Not directly, no. Not directly. 4 Q. Did this lawyer, Jeffrey Levy, discuss 5 with you Jack Scarola at all? 6 A. No. He just discussed just the lawyers 7 generically and their unethical conduct. 8 Q. And the lawyers generically, he's talking 9 about the lawyers who believe iliMiliSwolimme 10 A. No. The lawyers who pretend to believe 11 . None of us think you believe her. 12 Nobody I know thinks you believe her. 13 Q. Nobody you know thinks 14 A. That's right. 15 Q. Any of the people you described yesterday, 16 which is now inclusive of Brad Edwards, Paul 17 Cassell, Jack Scarola, Sigrid McCawley and David 18 Boise, believe that's your 19 testimony? 20 A. That's right, and Sigrid McCawley told me 21 that. 22 MS. McCAWLEY: I'm sorry, I'm going to 23 object. This again -- so I have no idea what 24 context, or if you're referring to a context 25 where we were having settlement discussions, EFTA01138171 794 1 that violates the seal order that's already in 2 place. There's a motion for sanctions pending. 3 We will be supplementing with this. 4 You know, how many times do we have to go 5 over this, Alan? It's not appropriate. First 6 of all, you're misrepresenting things. And 7 I'll state for the record, I did not say that. 8 But secondly -- 9 THE WITNESS: She's waiving privilege. 10 MS. McCAWLEY: No, I'm not waiving the 11 privilege. 12 THE WITNESS: Yes, you are. 13 MS. McCAWLEY: I'm denying the allegation 14 that you just made on the record. I'm making 15 my record that you are not entitled to discuss 16 anything that deals with confidential 17 settlement discussions. Misrepresenting those 18 is a violation of that, and I'll go back to the 19 judge and get another order if I need to. 20 THE WITNESS: I was asked a question -- 21 MR. SIMPSON: Don't -- 22 SPECIAL MASTER POZZUOLI: Hang on. 23 MR. SCAROLA: Could we have -- 24 SPECIAL MASTER POZZUOLI: Is there 25 anything else, Ms. McCawley? EFTA01138172 795 1 MS. McCAWLEY: No, not right now. 2 MR. SCAROLA: Could we have the question 3 and the answer read back, please. 4 SPECIAL MASTER POZZUOLI: Let's go ahead 5 and do that, just for purposes of 6 COURT REPORTER: "Any of the people you 7 described yesterday, which is now inclusive of 8 Brad Edwards, Paul Cassell, Jack Scarola, 9 Sigrid McCawley and David Boise, believe 10 that's your testimony? 11 "That's right, and Sigrid McCawley told me 12 that." 13 A. That's absolutely responsive. 14 MR. SCAROLA: We move to strike the "and 15 Sigrid McCawley told me that" comment as 16 unresponsive to the question that was asked. 17 And we agree that it is clearly violative of 18 the Court order that has been entered with 19 respect to this matter. 20 MR. SIMPSON: The question on its face 21 asked about Ms. McCawley. It was Mr. Edwards 22 that injected her views into the question. It 23 was not the witness. 24 SPECIAL MASTERPOZZUOLI: Go back up to the 25 question. EFTA01138173 796 1 THE WITNESS: I'm happy to have it sealed 2 if you want. 3 SPECIAL MASTER POZZUOLI: Hold on a 4 second. Go back up to the question. 5 COURT REPORTER: "QUESTION: Any of the 6 people you described yesterday, which is now 7 inclusive of Brad Edwards, Paul Cassell, Jack 8 Scarola, Sigrid McCawley and David Boise, 9 believe that's your 10 testimony? 11 "ANSWER: That's right, and Sigrid 12 McCawley told me that." 13 MR. SCAROLA: The responsive answer ends 14 with "and that's right." Excuse me. "That's 15 right," period. 16 SPECIAL MASTER POZZUOLI: Give me a 17 second. I'll grant the Motion to Strike from 18 "and" all the way to the end. 19 A. I'm also happy to have it sealed, if they 20 choose to. 21 SPECIAL MASTER POZZUOLI: Well, I don't 22 know what is going to come up, but it will be 23 dealt with one way or another. 24 MR. SIMPSON: The witness said we would be 25 happy to have it sealed, given that ruling. EFTA01138174 797 1 BY MR. EDWARDS: 2 Q. This attorney, Jeffrey Levy, did he 3 elaborate upon the basis for his offer to help you 4 against the generically described unscrupulous 5 lawyers, question mark? 6 A. Yes, he basically said these are lawyers 7 who are willing to make these outrageous charges, 8 and lawyers shouldn't be making these kinds of 9 outrageous charges against other lawyers, especially 10 when they're irrelevant. And basically he seemed to 11 know a little bit about -- not much, but a little 12 bit about the case. 13 But I use it as an illustration of people 14 coming to me all the time making these statements to 15 help amplify my answer. It's why I can't remember 16 names. Normally I wouldn't have asked him his name. 17 I only asked him his name because of your questions 18 of me today. But every -- virtually every week -- 19 in the beginning, it was every day, people would 20 come over to me with these kinds of statements. 21 SPECIAL MASTER POZZUOLI: Okay. 22 BY MR. EDWARDS: 23 Q. But is this lawyer's opinion, am I 24 understanding that that -- that's something you 25 weigh in to support your public statements that you EFTA01138175 798 1 have made? 2 A. I look at the totality of circumstances. 3 I look at my professional opinion, I look at what 4 I've read, I look at what I've told, I try to 5 calibrate, weigh everything for what it's worth and 6 then I come to an opinion. 7 And my opinion that I arrived at was based 8 at the totality of the circumstances that I was 9 aware of at the time I made this statement. And the 10 statement turns out to be true. 11 Q. And Jeffrey Levy, whatever his opinion is, 12 is one of the things that you're factoring in at 13 this point? 14 A. No, of course not. Of course not. 15 Q. Okay. 16 A. Not now, I don't have to factor anything 17 in. I now know the truth. I now know from other 18 people that this was all part of an extortion plot 19 and that the object of the extortion was Leslie 20 Wexner. But I'm aware of that now, so I don't have 21 to base the opinion on anything else. 22 MR. EDWARDS: Objection. Move to strike. 23 SPECIAL MASTER POZZUOLI: I'm going to go 24 ahead and move -- grant the Motion to Strike. 25 Go back up. Let me just see where -- because I EFTA01138176 799 1 wanted to find -- so from "I now know from 2 other people this is all part of an extortion 3 plot," from there down, we'll strike. 4 So what will remain is "not now, I don't 5 have to factor anything in. I now know the 6 truth." That will remain. 7 BY MR. EDWARDS: 8 Q. Okay. What are the identities of the 9 other two individuals that you encountered during 10 your lunch break? 11 A. One of them is a woman, a lawyer and -- 12 MR. SCAROLA: He asked for a name. 13 A. I don't know the names. I didn't ask the 14 names from anybody. 15 BY MR. EDWARDS: 16 Q. Is there a description that would help me 17 learn the identity of this person? 18 A. She was in her 40s, probably. She had 19 short, cropped hair. 20 Q. Is this somebody who knew the lawyers who 21 had accused you by reputation? 22 A. I don't know. I don't know. I'm just 23 giving you an illustration of what people tell me 24 all the time. 25 Q. Okay. During the lunch break, did you EFTA01138177 800 1 have a chance to consider whether you were willing 2 to waive the attorney-client privilege with respect 3 to the identities of the individuals with whom you 4 share a privilege in the circumstance where you are 5 the client, that provided you information that 6 helped form the basis of your opinions about Paul 7 Cassell and Brad Edwards? 8 MR. SCOTT: We've instructed my client not 9 to waive the privilege. 10 MR. SCAROLA: Both privileges? 11 MR. SCOTT: Yes. 12 MR. SCAROLA: And by "both," I mean both 13 attorney-client and work product. 14 MR. SCOTT: Yes, sir. 15 MR. SCAROLA: Thank you. 16 BY MR. EDWARDS: 17 Q. Isn't another reason that you have given 18 publicly that you could not have -- that anybody who 19 knows you would know that you could not have and 20 would not have committed such an offense, you're not 21 that kind of person? 22 A. That's right. 23 Q. And similar to what you did with respect 24 to Paul Cassell and reading about what is public out 25 there about him to form the basis of your belief in EFTA01138178 801 1 his credibility and reputation, you would agree that 2 it's also fair to have done the same thing with 3 respect to you, correct? 4 A. Yes. 5 Q. Okay. Is it -- do you or have you in the 6 past enjoyed getting naked at clothing-optional 7 beaches in Martha's Vineyard? 8 A. When I was -- 9 MR. SCOTT: Objection, relevancy to that. 10 Invasion of privacy. Has no relevancy 11 whatsoever. I would like a ruling. 12 MR. EDWARDS: It is reasonably calculated 13 to lead to the discovery of admissible 14 evidence. 15 SPECIAL MASTER POZZUOLI: I'm going to 16 deny the objection, but give you -- latitude is 17 not unlimited. 18 MR. EDWARDS: I understand. 19 A. Would you give me a time frame? 20 BY MR. EDWARDS: 21 Q. Sure. At around October 15, 2001, which 22 is a time period we have agreed falls within the 23 relevant time period of this case. 24 A. So I have to give a lengthy answer to 25 this. There is a beach on Martha's Vineyard which EFTA01138179 802 1 has traditionally been a clothing-optional beach. 2 Rumors are that Eleanor Roosevelt use to skinny dip 3 there. Many prominent people have skinny dipped on 4 that beach, and my wife and I have occasionally 5 skinny dipped on that beach. Yes. Not in recent 6 years. 7 Q. Were you asked at some point to represent 8 a woman by the name of Nikki Craft? 9 A. Yes. 10 Q. And with respect to that representation or 11 attempted representation, have you read the 12 statement that she has put out publicly regarding 13 you? 14 A. I don't recall, but I can tell you what 15 the facts of the case were and why I turned down 16 representation, if you would like to hear it. 17 SPECIAL MASTER POZZUOLI: Let him ask his 18 question. 19 MR. EDWARDS: Sure. 20 SPECIAL MASTER POZZUOLI: Sure? 21 MR. EDWARDS: No, no. 22 SPECIAL MASTER POZZUOLI: Oh, okay. Go 23 ahead. 24 BY MR. EDWARDS: 25 Q. Have you -- do you know that she has said EFTA01138180 803 1 that she has written "Does there exist for 2 Dershowitz an overpowering thrill of seeing the 3 female nude such as to prevent him from seeing the 4 issues from a woman's viewpoint?" 5 A. I think she also called me Mengele in the 6 article. She compared me to Mengele, the nazi 7 killer. She was furious that I wouldn't take her 8 case because she wanted to walk topless down the 9 middle of the city in the middle of the street, and 10 I don't believe in that. 11 I had represented the nude beach in Truro, 12 Massachusetts, where people want to go skinny 13 dipping in private areas, but I do not believe that 14 anybody has the right to be nude or topless in 15 public. I turned down her case. I never met her. 16 She wrote to me, and I wrote back turning down her 17 case. 18 And she just went on a rampage against me. 19 As far as I know, she's never met me. She's never 20 seen me. And she has just written, I remember, and 21 attacked me. She went on the radio and attacked me 22 all because I refused to represent her walking 23 topless through the city. 24 Q. Okay. And part of that rampage was her 25 understanding of your "eager response to naked women EFTA01138181 804 1 could be compared with that of a little boy let 2 loose in a candy store"? 3 A. She doesn't know me. That was something 4 she just made up. 5 MR. SCOTT: I need a ruling on relevancy. 6 But, I mean, reading statements from people 7 from articles and asking him about them is 8 totally irrelevant. Goes to nothing in this 9 case. 10 SPECIAL MASTER POZZUOLI: Ask your I'm 11 hoping that you're going to tie this up to 12 something. 13 MR. EDWARDS: Sure. 14 BY MR. EDWARDS: 15 Q. Can you well, let's go back first. 16 Can you provide me the articles -- all of 17 the articles on Paul Cassell that you have testified 18 about today? 19 A. I'm sure I can. 20 Q. Can you provide them to me now? 21 A. No. I told you I looked at them a year 22 ago. 23 Q. But it's fair for you to review those 24 articles and tell me what is in them, correct? 25 A. At some point, but I'm not going to do it EFTA01138182 805 1 right -- I can't do it now. I don't have it in 2 front of me. 3 Q. On your Harvard website, is there a 4 compilation of articles which you've written in the 5 past? 6 A. I haven't looked at my website, but I've 7 written, I think, over a thousand articles. 8 Q. At some point in time, did you write for 9 Hustler magazine? 10 A. No. 11 Q. Did you publish in Hustler magazine? 12 A. No. 13 Q. None of your articles were published in 14 Hustler magazine? 15 A. No. I was once called the "asshole of the 16 month" by Hustler magazine because I refused to 17 represent Mr. Flint, and he had a picture of my face 18 coming out of the rectum of a donkey, calling me 19 "asshole of the month." But I didn't publish that, 20 I assure you. 21 SPECIAL MASTER POZZUOLI: Tell me that 22 we're going to get somewhere with this, because 23 this is -- you know, see if we can tie this up 24 in some form. 25 MR. EDWARDS: Okay. Let me just put on EFTA01138183 806 1 the record why this is reasonably calculated is 2 the statement was made by Mr. Dershowitz that 3 he's not the kind of person to have done this. 4 THE WITNESS: To have raped a 16-year-old. 5 MR. EDWARDS: Our client -- our client has 6 described certain things about Mr. Dershowitz, 7 and if those certain things that she has 8 described are consistent with things that he 9 does believe in or has done in the past, then 10 that would add credibility to our client. 11 THE WITNESS: Would you tell me what your 12 client -- 13 SPECIAL MASTER POZZUOLI: Hang on a 14 second. 15 MR. EDWARDS: I don't have to do that. I 16 can just discover on this subject matter. 17 SPECIAL MASTER POZZUOLI: I'm going to let 18 you. But the idea that he might have skinny 19 dipped with his wife is slightly different. So 20 I would -- I mean, I don't see that as 21 relevant, but I'm going to let you continue. I 22 mean, because it's not my role here to decide 23 that. 24 But I'm just saying to you that I get 25 where you're going. So, proceed through this, EFTA01138184 807 1 but let's get to -- this is going to be 2 forever. I mean, because he's got a thousand 3 articles published, you can go through each of 4 them and pick out whatever or whatever it is. 5 So let's -- 6 MR. EDWARDS: There are two other things 7 at issue here. One is at the time that these 8 pleadings were placed, what was our -- what was 9 Paul Cassell and Brad Edwards' mind state. The 10 other thing is Mr. Dershowitz has a claim for 11 damages to his sterling reputation. So to the 12 degree that there is some damage to reputation 13 caused by some other source, then that is 14 something else that should be -- we should have 15 discovery into. 16 SPECIAL MASTER POZZUOLI: That's why I'm 17 allowing the latitude. 18 MR. EDWARDS: Thank you. 19 MR. SCOTT: There is certain relevance to 20 some of that. I mean, going into a lot of 21 these different things is -- you know, it's 22 years ago into the past and things like that. 23 It's just ridiculous. It's irrelevant. 24 And I think you get -- we're going to ask 25 you to make a decision on these things as they EFTA01138185 808 1 come up if this is going on to go on for hour 2 after hour asking things over a man's life of 3 70-some years. 4 THE WITNESS: Seventy-seven. 5 SPECIAL MASTER POZZUOLI: Ask your next 6 question. 7 BY MR. EDWARDS: 8 Q. Sure. Did you write articles on behalf of 9 Penthouse magazine? 10 A. I was Robert Guccione's lawyer on First 11 Amendment issues, and he asked me to do a column 12 every month on First Amendment and justice issues, 13 and I did that for 25 years, virtually every month 14 writing an article on justice and the First 15 Amendment. 16 Q. Have you ever written an article about the 17 idea that viewing child pornography should not be a 18 crime? 19 A. I can tell you my position. My position 20 is that creating child pornography should be a 21 crime, but that viewing -- I think I wrote about 22 viewing virtual child pornography; that is, 23 contrived images that are not real. And the Supreme 24 Court supported me on that position. 25 Supreme Court has ruled consistent with my EFTA01138186 809 1 position that when you have computer-generated 2 pictures of children that the focus should be on 3 making of the pornography, which is a crime, but not 4 on the viewing of the pornography. 5 And I have a view, a scientific view that 6 I've published about, written many articles about, 7 that there is no relationship between the viewing of 8 pornography and commission of violent crimes. And I 9 have the data to support that. And I think I'm one 10 of the leading authorities on that issue. It's an 11 academic issue of some considerable interest me. 12 Q. You're one of the leading authorities on 13 the issue that -- 14 A. Of the causation -- the relationship 15 between viewing pornography and crimes of violence. 16 Q. Viewing child pornography? 17 A. I would say in general. I don't know that 18 I distinguish between that in the scientific 19 research that I've done. 20 Q. I'm going to go ahead and show you what's 21 been marked as Exhibit 27. I'll show it to your 22 lawyer first. Ask if you recognize it. 23 MR. SIMPSON: Do you have a copy for us? 24 MR. EDWARDS: That's my only copy. We'll 25 use it -- EFTA01138187 810 1 MR. SCOTT: You know, I asked -- I'm going 2 to put this on. I asked yesterday to have 3 copies of exhibits. 4 MR. SCAROLA: I think we do have a copy, 5 before you get all exorcized over this. 6 MR. SCOTT: By the way -- 7 MR. SCAROLA: I think we do have a copy. 8 MR. SCOTT: Okay. And by the way, the 9 thing you published from the Bench & Bar, 10 it's -- you said it was in the exhibits. It's 11 not. 12 MR. SCAROLA: I told you if it's not 13 there, we'll get it for you. 14 MR. SCOTT: Yeah. I'd like it today, if 15 you could get it, because that's what you said 16 yesterday. 17 (Thereupon, marked as Plaintiff 18 Exhibit 27.) 19 MR. SCAROLA: I said tell us what else you 20 need, and we'll get it for you. 21 THE WITNESS: So not only is my -- 22 MR. SIMPSON: Wait a minute. Hang on. 23 That's the witness's. 24 MR. SCOTT: Is this the witness's copy? 25 MR. SIMPSON: You can have this one, Tom. EFTA01138188 811 1 MR. SCOTT: There's some notes on there. 2 I don't know if you want them, but -- 3 MR. EDWARDS: I'll take it. 4 MR. SCOTT: I think they're your 5 questions. I could be wrong. I could have 6 handed it to him, it would have probably 7 expedited it. 8 MR. EDWARDS: I doubt it. 9 A. Okay. I remember writing this article. 10 It grew out of a pro bono case that I did 11 representing a student. 12 BY MR. EDWARDS: 13 Q. Does that article limit the opinion of 14 that viewing child pornography or children 15 fornicating should not be criminal to virtual child 16 pornography? 17 A. I think I say in the article -- I asked 18 the question: But should it be a crime for someone 19 who has never and would never molest a child to view 20 child pornography? 21 I think I raised that question. And I 22 talk about the dangers to the values of the 23 democracy. I say there is a potential here for a 24 real witch hunt. Child molestation is a serious 25 problem. The creation of child pornography is also EFTA01138189 812 1 a serious problem. We don't know whether the 2 viewing of child pornography is or is not a serious 3 problem, but many people think it is. 4 So, I don't think I take a definitive 5 view. I am an academic. You're trying not only to 6 put my ideas on trial here today, what I've written 7 about on trial; you're trying to put my advocacy on 8 behalf of defendants on trial, you're putting the 9 Sixth Amendment on trial, you're putting the First 10 Amendment on trial. You're inviting the American 11 Civil Liberties Union, the National Association of 12 Criminal Defense Lawyers to intervene in this case, 13 because they will not stand by and tolerate an 14 academic having his ideas put on trial or an 15 advocate -- I was going to say a zealous advocate, 16 and I claim that, I am a zealous advocate, putting 17 his representation on trial. That is unAmerican. 18 That is McCarthyite and is beneath contempt. 19 MR. EDWARDS: Object and move to strike. 20 SPECIAL MASTER POZZUOLI: Denied. Denied. 21 Move forward. 22 BY MR. EDWARDS: 23 Q. Is Paul Cassell also an academic? 24 A. Paul Cassell teaches and uses the 25 stationery of law school as part of his -- EFTA01138190 813 1 SPECIAL MASTER POZZUOLI: Answer the 2 question. 3 A. He is an academic. 4 BY MR. EDWARDS: 5 Q. When was that article that has now been 6 marked as 27 written? 7 A. Copyrighted 2002. 8 Q. Is 2002 within the relevant time period 9 that we've defined in this case? 10 A. Yes, but I've written articles like this 11 as far back as probably as 1967, and I've written 12 them probably as recently as the last couple of 13 years. I have a book which deals with the subject. 14 I have a long Law Review article called "Why 15 Pornography?" 16 So to focus on that year seems to me as to 17 wrench out of context the fact that this has been my 18 view. I had a debate with William Buckley about it 19 at Harvard University. I had a debate with -- 20 interestingly enough, I had a debate with Ginsberg, 21 the poet, in which I took the opposite view in which 22 I was very, very tough on child pornography, talking 23 about how much I despise it and hate it and think 24 it's immoral and improper. 25 But just because I think something is EFTA01138191 814 1 immoral and horrible doesn't mean I necessarily 2 think it should be criminal. Unlike some people, I 3 don't necessarily associate my personal views of 4 conduct with what I think should be illegal or who I 5 would represent. 6 Q. Have you ever had any of your articles 7 that you have written removed from your Harvard 8 website? 9 A. Not that I know of. That would be a 10 violation of academic freedom. 11 Q. Is there any reason why the article that 12 is now number 27 is, as of February of 2015, no 13 longer on your website? 14 A. I doubt that that's true. I doubt that it 15 was removed. I don't think every article let me 16 tell you, unequivocally, I did not remove it, order 17 it to be removed or know it was removed. I doubt it 18 was removed. I can't imagine why anybody would ever 19 remove any article. I'm very proud of this article. 20 Q. Is there any explanation for that 21 particular article being within the articles on your 22 website at some point and later no longer appearing 23 on your website? 24 A. I don't think that's true. And if it is, 25 I have no idea how it happened or why it happened. EFTA01138192 815 1 It's not something I would ever tolerate being done. 2 There isn't a single article I would remove from my 3 website. I'm proud of every article I've written. 4 And I'm sure you will find many other articles. 5 I don't know what my website includes. 6 But there is a book that's been written that honors 7 me by University of Albany Law School and contains 8 in the back all of my articles. I don't know that 9 my website does more than have a selection of my 10 articles. So I would have to look. But I'm not 11 aware of it. I don't handle my website. 12 Q. Who decides which articles are placed on 13 the website and which are taken off of the website? 14 A. My assistant, Sarah Neely. 15 Q. Is Sarah Neely somebody who has been 16 involved in any aspect of the defense of this 17 particular case? 18 A. She's just my assistant, she's my 19 secretary. She does all of my typing and does 20 everything that I do. So she's been involved in 21 every aspect of my life since she worked for me 22 about eight years ago. 23 Q. Is there anyone other than Sarah Neely who 24 would put an article up on the website or remove the 25 article from the website? EFTA01138193 816 1 A. Not that I know of. 2 Q. And is she permitted to remove any 3 articles from the website without your permission? 4 A. I have no idea. I've never ever read my 5 website. I am not a web person. I don't know 6 what's on my website. And she also does tweeter or 7 Twitter. I have no idea. She circulates some 8 articles, she doesn't do anything, I have no control 9 over that. And I had nothing to do, nothing, zero, 10 with either placing the article or if it was 11 removed, removing the article. Zero percent. 12 Q. Okay. Have you ever called for a complete 13 overhaul of rape laws in Massachusetts? 14 A. One of my academic subjects that I've been 15 interested in for many, many years has been the 16 definition of rape and the idea of consent. 17 And I recently wrote an article calling 18 for affirmative consent to be required in all rape 19 cases, making the point that it's far better than 20 ten consented-to rapes don't -- that ten 21 consented-to acts of sexuality do not occur rather 22 than even one unconsented-to act of sexuality occur. 23 So in other words, I've flipped the 24 Blackstonian notion and say it's far, far better 25 that voluntary sex not occur in questionable EFTA01138194 817 1 situations than even one act of unconsented-to sex. 2 I'm very much a hawk on the issue of consent and 3 want to make sure that no sexual encounter ever 4 occurs. And I teach that to my students. And I 5 lecture my students about that. I think the laws of 6 Massachusetts and the laws of many, many other 7 states are in a complete state of messiness, and I 8 would be thrilled to have an -- overall rape laws 9 all over the county. 10 Q. Have you included within your request for 11 a complete overhaul lowering the age of consent 12 considerably? 13 A. I know I argued in Florida -- we produced 14 some data in Florida that the age of consent is 18. 15 And, by the way, this all happened way, way after 16 the events at issue. But that the average age of 17 commencing sex in the state of Florida is well below 18 that. And, therefore, there is a substantial 19 disparity in California, which has 18, and Florida, 20 which has 18, between the actual activities that 21 occur -- many, many acts of sexual conduct occur 22 between the ages of 17 and 18, but the acts are 23 illegal. 24 I have for years, basically since the 25 Vietnam War when I argued this, said that when you EFTA01138195 818 1 have tremendous disparity between the law in action 2 and the law on the books, that creates disrespect 3 for the law. And so what I want to see is a change 4 that reflects the actual pattern of sexuality 5 community by community, state by state. That's been 6 my academic position. 7 Q. Have you, as far back as 1997, advocated 8 for lowering the age of consent to 15, as something 9 that would seem like an appropriate compromise, 10 given that reasonable people might disagree on 11 whether it should be as low as 14? 12 A. I don't recall that. If you could show me 13 what you claim I said, I would be happy to look at 14 it. I don't recall that. I do not believe the age 15 of consent should be 15. 16 Q. Okay. Have you ever believed that age of 17 consent should be 15? 18 A. I have no recollection of that. But if 19 you could show me what you claim I said, I will be 20 happy to look at it and read it in context. 21 Q. That's not a belief that you have today? 22 A. That's not a believe that I have today, 23 no. 24 Q. Do you currently have a place at 1500 25 Ocean Drive, Miami Beach? EFTA01138196 819 1 A. I do. 2 Q. And is that near a clothing-optional 3 beach? 4 A. No. Not that I know of. I'm not aware of 5 any. 6 Q. Is there instances where you have seen 7 women lying out nude on the beach near your condo? 8 MR. SCOTT: You know, really the relevancy 9 of this is so strained. 10 SPECIAL MASTER POZZUOLI: You really are 11 straining the relevancy. But go ahead. It's 12 your time. Go ahead. I'm not going to -- 13 A. Any human being who is not blind who has 14 walked on any part of South Beach has seen a vast, 15 vast, vast, vast majority of men and women are 16 dressed in totally appropriate bathing suits, and 17 occasionally there are some who are not. 18 BY MR. EDWARDS: 19 Q. Have you, at your condominium complex, 20 earned the reputation as somebody who goes out onto 21 the beach anytime there is a nude girl? 22 A. No. What you're talking about is last 23 year my wife ran for the condo board, and she ran 24 against another group of people, and they were 25 exchanging insults. And one of the women whose EFTA01138197
t UM— t•gotta ince- • rt ocx • 9-0ESTR14/X.Aikeihrs: OF
5/19/22,4:19 Prt4
C.1'5E) MOXVCIE1-2--±
GhislaineMeumed-WMpWie
Ce Rff-R eftohPecars
Details of a civil lawsuit, made public in January 2015, contained a deposition from "Jane Doe 3"
grooming her to
that accused Maxwell of recruiting her in 1999, when she was a minor, and
provide sexualservicesfor e 2018 expose by Julie IC. Brown
revealed Jane Doe 3 to be 1 who was previously known as
met Maxwell at Donald Trump's Mar-a-Lago Club in Palm Beach, Florida, when' was a 16-
year-old spa attendant.E.g. She asserted that Maxwell had introduced her to Epstein, after which
s
she was "groomed by the two [of them] for his pleasure, including lessons in Epstein's preference
during oral sex". 221!631
a statement,
Maxwell has repeatedly denied any_ involvement in Epstein's crimes.M In 2015 she had
d that
Maxwell rejected allegations that she has acted as a procurer for Epstein and denie
esperson said "the allegations
"facilitated Prince Andrew's [alleged] acts of sexual abuse". Her spok
allegations of an unsavoury
made against Ghislaine Maxwell are untrue" and she "strongly denies
ves her right to seek
nature, which have appeared in the British press and elsewhere, and reser
redress at the repetition of such old defamatory claims" [581[641
rage girls, often at sex
a sserted that Maxwell and Epstein had trafficked her and other unde
parties hosted by Epstein at his homes in New -tvMexisc, Palm Beach, and the United
Maxwell for defamation in federal
States Virgin Islands. Maxwell called her a liar. aued
court in the Southern District of New York in 20 details of the settlement have nal
favour,1451 with Maxwell paying
made public, in May 2017 the case was settled in
"millions" (66]
eivc) s ecci ag.. 015 0s6 aiNc, - TP e.GE:11 NC.
c -; fr>e(see.... bem
v Epstein and Maxwell (2017) 4- MosWe
et nes-Two-10(4 CA"-:-
cARee-R pKosmc :--rs - cod)
PLY .
the Southern District of
In 2017, filed a suit, in the United States District Court for to give massages to ,_
Maxwell hired her
New York, again Epstein and Maxwell, alleging that if she did not "C
Epstein and lat atened to physically harm her or destroy her career prospects
in New York and on his private Caribbean
*comply with their sexual demandstat his mansion
r undisclosed terms.1a4g161)1§81
island, Little Saint James. The suit was settled in 2018 unde
Affidavit filed by (2019)
went public and sworn affidavit in federal court in New
Ont6Apri12019,
bad been sexually assaulted by Epstein
York, alleging that she and her 15-year-old famation
and Maxwell in sepa rate locations in 1996. affidavit was filed in suppo
davit,. had met
suit by
I I against Alan Dershowitz.1§91 According to the affi
tion in 1995. The affidavit says that in the
Maxwell and Epstein at a New York art gallery recep an art project in billionaire businessman
on
summer of the following year, they hired her to work
ner's Ohio mans ion, wher e she was then sexually assaulted by both Maxwell and
Lesli e Wex
e Department and the
E,pstetu,I.S111 reported the incident to the New York Polic
.1-5g7 2
2) fidav it also state d that durin g the same summer, Epstein flew her then is-year-
FBI ell molested her on a massage
old sister, to his New Mexico property where he and Maxw
table.
November 2019 where she detailed the 1996
was interviewed for CBS This Morning in
alleg ed that Maxw ell had threa tened both her career and her life after the assault.E711
assault and
1-3 (2019)
v Epstein's estate, Maxwell, and Jane Does
( Nwou;cmENT
efkoPEKTV 1 -Herr - A t-i tZ1
Ni PossEsScN - MaTIPIE
Illa
EFTA00263576
await
0 Ar
MA H . MaN -
RIBLAc-Prnoty
- Outlook
Welcome to Hay House
Hay House
Tue 20/01/2015 5:59AM
To:
To view this email as a web page, go Jiga,
PUBLISH AHD SAVE UP TO 51,000 I.
What will you achieve In 2015? Publishing is possible.
If you're thinking of publishing your book, then publishing is just a dream. But you can decide to start
publishing today. You can stop dreaming and start making each moment another step toward your
publishing goal.
in
The year has only just begun, but that's no mason to postpone your dream of becoming an author
2015. Call 1800 050 315 today and save up to $1 ODD on professiona l self-publishing services from
Balboa Press, a division of Hay House.*
for details. This email is an
' Offer expires 31 Jan. 2015, and cannot be combined with any other promotions. Sec iyobcate
adiertiscment
BALBOA.
vim* bal0siApreis.topLat 'ED0 0503)S
Balboa Prc.N.s, a division ofHay House
This email was sent to
This email was sent by: Balboa Press
1663 Liberty Drive Bloomington, IN 47403 USA
CohO6GAEAXoEEi%2F... 1/2
https://outioolcilwa.corntmeW0/AOMkADAwATNiZrnYAZC1,A2U5LTaNWMtMDACLTAwCgAuAMOXVOlyWhm0laOW4
EFTA00263578
Ftsre)c sys-rem 6 - crsiacnt.t, p0 HOOSES TG
g•Te IN\ A • EuesusHit•IcA c_wrftecr - I CHAPTER so81-tiarre53 CNLy
ct-iNsiat - ReAti-N
ROI C c_ot.iptere_t> titnts)oscal ft.T - l WOK
4 23/02/2018
Dear Sir / Madam,
I w9tuld like to take this opportunity to introduce myself, my name is
an am.4,7 years of age and a mother of 4 children.A
I am contacting you today in regards to my manuscript of which i have included - Hard
copy, Realit-Ol have included a hard copy of the chapter " Reality " for your review of
which is the main chapter of the book. -A.
The book is based upon true events, individuals and townships and is a non fictional auto
biography of these events, individuals or townships. Events, names and townships have
been changed to protect the identity of these individuals or events.
4 The books title is called " Reality • and i have written it under the alias " Holly Jackson ".
* I am seeking expressions of interest of publishing my first book"l am new to this
procedure and am seeking your assistance in this area.
4. The full manuscript includes a copy of the chapters :
Loss of Innocence
• For the first time
• Entrapment
• The Marriage
• Forbidden Love
• Liberation
•-• Reality
• The Lies, The Truth
t
If you are interested in the publication of this manuscript or obtaining the full manuscrip
for review please contact me :
ContacLciiid ilq •
Email :
Addrest.
Thankyou
Yours Sincerely
EFTA00263579
• in.tiU20 - Outlook
Re: Your Submission - QO1 SEEKING, cusuctrnot.) coNtiRe
Jacquline PoNA -tit.)c H&OS&
Mon 19/03/2018 2.11 PM
To: Sydney Reception <
Dear Sir/Madam,
Thankyou for your reply.
I would also like to thankyou for the information of which you have supplied, it is much appreciated
in my endeavour to source a publisher for my book.
Thankyou
Your Since".
From: Sydney Reception
Case 1:15-cv-07433-RWS Document 199 Filed 06/10/16 Page 1 of 8 United States District Court Southern District of New York L. Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S MOTION TO EXTEND THE DEADLINE TO COMPLETE DEPOSITIONS Plaintiff =, by and through her undersigned counsel, hereby files this motion for a brief extension of time to complete pending depositions. Ms. has been actively working to complete discovery in this case. However, due to a number of circumstances beyond her control, she is unable to complete the necessary depositions by the close of discovery on June 30, 2016, and, therefore, requests an additional four (4) weeks to complete these depositions. She requests the deposition deadline be extended to July 30, 2016. The requested relief would not disturb the trial date. BACKGROUND As the Court knows, this case was filed in September 2015. The Court's original scheduling order set the completion of fact discovery for July I, 2016. (See D.E. 13.) However, after the filing of the complaint, the Defendant moved to stay any discovery in the matter. Therefore, discovery did not commence until the Court directed Defendant to respond to discovery by February 2, 2016. Defendant did not respond to Ms. first requests for discovery until February 8, 2016, and only produced two documents. Defendant did not produce 1 EFTA00590011 Case 1:15-cv-07433-RWS Document 199 Filed 06/10/16 Page 2 of 8 any additional documents until April 18, 2016 -- after this Court directed Defendant to turn over documents that had been withheld under an improper claim of privilege. While Ms. provided her initial disclosures on November 11, 2015, in accordance with the federal rules, Defendant did not provide her initial disclosures until February 24, 2016, in violation of those Rules. In addition, while Ms. started her efforts to get the Defendant's deposition in February, 2016, Defendant did not actually sit for her deposition until after being directed to do so by the Court, on April 22, 2016. Defendant's deposition is now subject to Plaintiff's Motion to Compel Defendant to Answer Deposition Questions Filed Under Seal. (See [DE 143]). Ms. also started her efforts to attempt to schedule depositions of other witnesses in February, 2016. Ms. efforts to obtain depositions have been hampered by a number of factors. An example of the conduct that has hampered Ms. efforts to timely obtain depositions is stall tactics of Defendant's co-conspirator, Jeffrey Epstein. Ms. started her attempts to serve Mr. Epstein back on March 7, 2016 by contacting Mr. Epstein's lawyer. (See [DE 160] Plaintiff's Motion for Leave to Serve Three Deposition Subpoenas By Means Other Than Personal Service, and [DE 161] Declaration of Sigrid McCawley in Support of Plaintiff's Motion for Leave to Serve Three Deposition Subpoenas By Means Other Than Personal Service.) Mr. Epstein refused to accept service, thereby forcing Ms. to hire investigators and spend considerable time and money in an attempt to personally serve the Defendant's former boyfriend, employer, and co-conspirator, with whom she has a joint defense agreement. Id. It was not until after Ms. filed her Motion for Alternative Service with this Court that Mr. Epstein finally agreed to accept service of the subpoena on May 27, 2016 — three (3) months after Ms. initial attempts to serve Mr. Epstein, but he conditioned that acceptance upon 2 EFTA00590012 Case 1:15-cv-07433-RWS Document 199 Filed 06/10/16 Page 3 of 8 the fact that his deposition must take place in the U.S. Virgin Islands at a time that is mutually convenient to the parties, despite the fact that he has at least three residences in the continental United States, including Manhattan. (See [DE 175] Notice of Acceptance of Service.) As that is a remote location, and we are nearing the end of the discovery period with many dates already filled for depositions or conflicts with schedules of counsel, it is not likely that this deposition can be completed within the remaining timeframe. Another example of delay that has harmed Ms. ability to obtain all depositions in a timely manner is Mr. Rizzo. Ms. subpoenaed the deposition of Rinaldo Rizzo on April 11, 2016 for a date over a month later on May 13, 2016. See McCawley Decl. at Exhibit I, Subpoena of Rinaldo Rizzo and related correspondence. Just days before the deposition, however; Defendant's counsel claimed she did not realize the deposition was proceeding forward despite having received Ms. Notice of Serving Subpoena the month prior, and asked Ms. to re-schedule the deposition. Ms. then had to coordinate scheduling with the witnesses' counsel and re-set the deposition for another month later, on June 10, 2016, thereby taking another date in June away that could have been used for other necessary depositions. See McCawley Decl. at Exhibit 2, Re-Notice of Deposition of Rinaldo Rizzo. An additional problem has been that certain witnesses, despite being represented by counsel, have refused to accept service of subpoenas. Therefore, until the Court rules on Ms. pending motion for alternative service, she is unable to take the depositions of Ms. and Ms. (See [DE 160] Plaintiff's Motion for Leave to Serve Three Deposition Subpoenas By Means Other Than Personal Service and [DE 161] Declaration of Another example that is hampering the ability of Ms. to complete the necessary depositions by June 30, 2016, is Ross Gow, who Defendant has admitted was her agent for 3 EFTA00590013 Case 1:15-cv-07433-RWS Document 199 Filed 06/10/16 Page 4 of 8 purposes of submitting to the press the defamatory statements at issue in this case. Mr. Gow resides in London. Ms. asked that Defendant produce her agent, Mr. Gow, for a deposition, but Defendant has refused. Defendant has refused this request despite acknowledging that Defendant plans to call Mr. Gow for testimony at trial. Ms. may now be forced to have to go through the Hague Convention for service on Mr. Gow, and forced to go to London to obtain his deposition. It appears there is not sufficient time for Ms. to complete this process before the June 30, 2016 deadline. In addition, there have been third-party witnesses that we have subpoenaed for depositions who have, through their counsel, requested that we change the dates of their depositions. These individuals include: Jo Jo Fontanella, and Jean Luc Brunel who were all set for mid-June deposition dates. An extension of the discovery deadline by a few weeks will allow Ms. to work cooperatively and accommodate these requests for changes in the scheduling of these depositions. The Court also has pending before it the motion to compel Ms. Maxwell to complete her deposition testimony. (See [DE 143], Plaintiff's Motion to Compel Defendant to Answer Deposition Questions Filed Under Seal.) And briefing is continuing on Ms. motion regarding the number of depositions that she is permitted to take in this case. Finally, while the parties have attempted to coordinate the scheduling of depositions, and indeed had a lengthy meet and confer call regarding scheduling back in May, those efforts have not resulted in a feasible schedule. If the deadline is not extended for Plaintiff to complete her depositions into July, it appears that both sides might be forced to notice conflicting dates in June. Ms. could provide more detail on these issues, which are documented in numerous back and forth emails between the parties; but rather than inundate the Court with those issues, 4 EFTA00590014 Case 1:15-cv-07433-RWS Document 199 Filed 06/10/16 Page 5 of 8 the bottom line is that the only way that the both sides will be able to work cooperatively to set up a schedule that meets the competing needs of her counsel, defense counsel, the subpoenaed witnesses, and the witnesses' counsel is for a short extension of time.' ARGUMENT Ms. has attempted to conduct discovery in a timely manner in this case to prepare her case for trial in October, but has been hampered by many intervening issues. This is Ms. first request for an extension relating to the discovery deadline and the request is being made for good cause. Rule 16(b)(4) specifically provides that a scheduling order may be modified for good cause. "Good cause" requires a greater showing than "excusable neglect." At a minimum, good cause requires a showing by the moving party of an objectively sufficient reason for extending a deadline such that the deadlines cannot reasonably be met despite the diligence of the party needing the extension. The inquiry focuses on the moving party's reason for requesting the extension. Pyke v. No. 92 CV 554, 2004 WL 1083244, at *2 (N.D.N.Y. May 12, 2004) (internal citations and quotation marks omitted) (quoted in Scott v. City ofNew York, No. 04 Civ. 9638, 2007 WL 4178405, at *4 (S.D.N.Y. Nov. 26, 2007)). Thus, "[t]he mistake or inadvertence of counsel will not support a finding of good cause." Id. "[T]he primary consideration is whether the moving party can demonstrate diligence." Kassner, 496 F.3d at 244. However, the court may consider other factors, including, in particular, potential prejudice to the opposing party. Id.; see also Scott, 2007 WL 4178405, at *5. Michael Grecco Photography, Inc. v. Everett Collection, Inc., 07 CIV.8171(CM)(JCF), 2008 WL 4580024, at *2 (S.D.N.Y. 2008), as corrected (Oct. 15, 2008). In the Michael Grecco Photography case, the court found that the plaintiff had demonstrated good cause to re-open discovery for the limited purpose of deposing defendant's employee where plaintiffs counsel made repeated attempts to schedule deposition. See also Carlson v. Geneva City Sch. Dist., 277 F.R.D. 90, 95 (W.D.N.Y. 2011) (holding that defendants I Ms. counsel conferred with the Defendant but the Defendant was not willing to grant the request for an extension to complete the depositions requested by Ms. =. 5 EFTA00590015 Case 1:15-cv-07433-RWS Document 199 Filed 06/10/16 Page 6 of 8 established good cause to extend discovery in order to conduct plaintiffs deposition where defense counsel made sufficient efforts to schedule her deposition prior to the close of discovery). Similarly here, Ms. has made timely efforts to obtain the depositions that she needs to support her claims but has been hampered by a number of issues. Defendant will not be prejudiced because the request is short in duration and will allow a more reasonable schedule to be established with the remaining witnesses and their counsel. Again, Ms. is not seeking to move the trial date presently set for October 17, 2016, but is only asking for a few additional weeks to complete the pending depositions due to scheduling conflicts and issues outlined above. CONCLUSION Ms. respectfully requests that the Court allow her an additional four (4) weeks to complete the remaining depositions before July 30, 2016. Dated: June 10, 2016. Respectfully Submitted, BOLES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale. FL 33301 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 6 EFTA00590016 Case 1:15-cv-07433-RWS Document 199 Filed 06/10/16 Page 7 of 8 Fort Lauderdale Florida 33301 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-52022 2 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 7 EFTA00590017 Case 1:15-cv-07433-RWS Document 199 Filed 06/10/16 Page 8 of 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 10th day of June, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver Colorado 80203 Tel: Fax: Email: /s/ Sigrid S. McCawley Sigrid S. McCawley 8 EFTA00590018
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN GHISLAINE MAXWELL, and Defendants. PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION F PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition of the Defendant as set forth below: NAME: DATE AND TIME: August 22, 2018 at 10:00 a.m. LOCATION: Boles Schiller & Flexner. LLP The videotaped deposition will be taken upon oral examination before Magna Legal Services, or any other notary public authorized by law to take depositions. The oral examination will continue from day to day until completed. ' Plaintiff originally filed this action under the pseudonym `` ," but is now proceeding under her real name. I EFTA00285626 The video operator shall be provided by Magna Legal Services. This deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the rules of this Court. Dated: August 10. 2018. BOLES SCHILLER FLEXNER LLP By: Is/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller Flexner LLP ir Bradley J. Edwards, Esq. (Pro Hac Vice) Stanley Pottinger, Esq. EDWARDS POTTINGER LLC Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 2 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 2 EFTA00285627 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 10th day of August, 2018, I served the attached PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITON OF WITNESS via Email to the following counsel of record. Michael Miller Justin Y.K Chu Michael A. Keough STEPTOE & JOHNSON LLP Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON MORGAN & FOREMAN, P.C. By: /s/ Sigrid McCawley Sigrid McCawley 3 EFTA00285628
To: Cecile de Jong Cc: Ann Rodriquez[ aPhne Wallace From: Sent nii. !. 5:57:44 PM Subject Re: JE's Schedule - February 25th - Cecile, I have in Jeffrey's calendar that he needs to be at Erika Kellerhals office at 2pm STT time tomorrow for a deposition...it should take about 20-30 minutes. I have called Chet Brewer to see if this is still on, but he is out of the office at the moment. I should hear back from him by 4pm my time...0 will try to reach him earlier if possibl On Feb 24, 2015, at 12:05 PM, Cecile de Jongh wrote: 2 PM - Meeting with Carlton Dowe (VIPA), Shaun Miller (UEIS), and Dale Gregory (VIPA) at STC POC Carlton Dowe 340-690-7678 EFTA_R1_00670049 EFTA02083662
To: Jeffrey [email protected]] From: story cowles Sent Tue 1/19/2010 11:54:29 PM Subject: Bruce R. Bob thinks that Bruce should remain at least as Sarah's attorney and do the deposition on February I I th and be done with it. EFTA_R1_01502623 EFTA02432062
Page 172 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No. Plaintiff, -vs - JEFFREY EPSTEIN, Defendant. CONTINUED DEPOSITION OF JEFFREY EPSTEIN VOLUME III Thursday, October 8, 2009 1:46 - 3:48 p.m. 250 South Australian Avenue Suite 1400 West Palm Beach/ Florida 33401 Reported By: Jeana Ricciuti, RPR, FPR, CLR Notary Public, State of Florida Prose Court Reporting Agency, Inc. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Joann Moduli WMMMAIO-496c-aVW099977073134 EFTA01087055 1' ..:4c 17j Page 175 APPE3tRANCFS 2 On behaifotthe Mania 1 PROCEEDINGS SPENCER T. KUYIN, ESQUIRE 2 3 ADANILANOINO, ESQUIRE LEOPORD KUV1N, PA 3 THE VIDEOGRAPHER: We're back on the record at 4 2193 POA Manna Sufis 200 4 1:46. Palm Florida 33410 5 CONTINUED DIRECT EXAMINATION 6 6 BY MR. KUVIN: Salta tad ■ and Iwo Doe In Coo No. 1 7 Q. Do you personally know John Mack, former CEO CARA I. 110131FS, FSQUIRR 8 ROTHSTEIN, ROSEMEIDT CADLPIC 8 al Morgan Stanley? 401 Paµ Las Olaf Boenzad 9 Suite 1440 9 A. I'll have to answer that the same way I've 10 fat 33301 10 answered most of your questions here today, Mr. Kuvin, Phone air P near /one Doe la Case WIN and 11 is, I intend to respond to all relevant questions NyhIch wr 2 THERINII W. MERL, ESQUIRE 12 regarding this lawsuit; however, at the present time, my PODHURSTORSECR. PA •3 21 Weµ HaslerSerett 13 attorneys have counseled me I cannot provide answers to 14 any questions relevant to this lawsuit. I must accept Hone: S On behalfof the Defendant. 15 this advice or risk losing my Gth Amendment right to TACK CrOLDBEROUR, A I FOAL' :6 STORY ROM FS, PARAI FOAL 16 effective representation. Accordingly, I assert my Al'1E RBI IRV. 601.1aUEK(it 441; MS, P 250 Sac* Augrolien Avenue 17 federal constitutional rights as guaranteed by the 5th, Sway 1120 18 6th and 14th Amendment to the United States Wne Palialinkla 33401 /Sone: 19 Ccestitution. MICHAEL!. Ha ESQUIRE 20 MR. KUVIN: Okay. Same deposition as shown 70 BURMAN, aurrotc.T.U1TXRA COLEMAN, P 303 Beam houleverd 21 before, different clip. I'm going to play it for 21 Sake 400 Wert P 3 a 33101 22 counsel first. 22 hone. 23 MR. PIKE: 'thank you. 23 ALSO P 21 DAN DOM( RY, VIDLOORAP2IER 24 MR. KUVIN: Mr. V ideowapher, just let me know VISUAL EVIDISNCE,IXC. 25 25 when you're ready. Page 174 Page 176 1 --- THE VIDEOGRAPHER: Whenever you are. EXHIBITS 2 -•• 2 MR. KUVIN: Okay. 3 WITNESS: CONEDDIRECT 3 (Video played.) 4 JEFFREY EPSTEIN 4 VIDEO WITNESS: "What did I do to Jeffrey and BY MR. KUVIN 175 6 5 what did Jeffrey do to me? I went up there 6 multiple times; I can't count. And I would be on a 8 7 massage table, massaging his legs, he would turn EXHIBITS 9 8 over, his penis would be hanging out. He would put 10 NUMBER DESCRIPTION PAGI 9 a vagina -- or a vibrator to my vagina, lie would 11 PLAINTIFFS EX. 9 PHOTOGRAPH OF GHISLA1NE 182 MAXWELL 10 touch my vagina with his fingers. He would touch 12 PLAINTIFFS FM 10 PHOTOGRAPH OF 191 . 11 my breasts. He would try to kiss my mouth. He 13 PLAINTWFS 1 PHOTOORAPHOF 196 12 would bring my hands toward his penis." PIAINTWFS EX. 12 PHOTOGRAPH 13 (Video stopped.) 19 PLAINTIFFS EX 13 PHOTOGRAPH OF 199 14 MR. KUVIN: Okay. PIAINT1FFS RAPH OF 15 MIL PIKE: I'm just going to object to the use PtAtbnifFs E .Is PH RAPE! OF111.11 201 16 of the video as to relevance, predicate and 16 PLAINTIFFS EX 16 PHOTOGRAPH OF • ANDREW 17 foundation. 17 PLAINTIFFS EX. 17 LETTERTOB. KRISCHER FROM 203 18 BY MR- KUVIN: M. REITER 19 Q. All right. Let me get it back to the same 18 PLAINTIFFSEX. IS RECEIPT OF PURCHASES MADE 206 FROM JAIL 20 location, 19 PLAINTIFFS EX. 19 FAA REGISTRY 218 21 Sir, first of all, once again, just sol can 20 21 22 lay the foundation for this, do you recognize this girl? 22 23 A. I'm going to have to respond to that question 23 24 the same way I've responded to most of your other 24 25 25 questions hero today, which is, I intend to respond to 2 (Pages 173 to 176) PROSE COURT REPORTING AGENCY, INC. • Electronically signed by Jeana Ricciuti - - Electronically signed by Jeana Ricclutl bleclerlf0410498e4244•099977073134 EFTA01087056 Page 177 Page 179 1. all relevant cannot provide answers to any questions 1 the United States Constitution. 2 relevant to this lawsuit; however, at the present time, 2 BY MR. KUVIN: 3 my attorneys have counseled me I cannot provide answers 3 Q. Did you do what that young lad just described 4 to any questions relevant to the lawsuit. I must accept 4 now to hundreds of women, including M. ? this advice or risk losing my 6th Amendment right to 5 MR. PIKE: Form, argumentative, harassing, 6 effective representation. Accordingly, I assert my 6 lacks appropriate predicate, foundation, lacks 7 federal constitutional rights as guaranteed by the 5th, identity. 8 6th and 14th Amendment to the United States 8 THE WITNESS: Excuse me. Pm going to respond 9 Constitution. 9 to that the same way I've responded to most of your 10 Q. Did this girl brings to your home for a 10 other questions here today, which is, I intend to 11 naked massage? 11 respond to all relevant questions regarding this 12 A. Pm going to have to respond to that the same 12 lawsuit; however, at the present time, my attorneys 13 way I've responded to most of your other questions here 13 have counseled me that I cannot provide answers to 14 today, which Is, I Intend to respond to all relevant 14 any questions relevant to the lawsuit. I must 15 questions regarding this lawsuit; however, at the 15 accept their advice or risk losing my 6th Amendment 16 present time, my attorneys have counseled me I cannot 16 right to effective representation. Accordingly, I 17 provide answers to any questions that may be relevant to 17 must assert my federal constitutional rights as 18 the lawsuit. I must accept this advice or risk losing 18 guaranteed by the 5th, 6th and 14th Amendment to 19 my 6th Amendment right to effective representation. 19 the United States Constitution. 20 Accordingly, I assert my federal constitutional rights 20 BY MR. KUVIN: 21 as guaranteed by the 5th, 6th end 14th Amendment to the 21 Q. While. was standing naked in your home, 22 United States Constitution. 22 specifically in your bathroom, did you tell her that you 23 Q. I'd like to play this clip for you and then 23 could get her an interview as a model because of your 24 Pm going to ask you a question. 24 connections? 25 MR. PIKE: The same clip you just played? 25 A. I'm going respond to that the same way I've Page 178 Page 180 1 MR. KUVIN: Exactly. 1 responded to most of your questions today, Spencer. I 2 MR. PIKE: Same objection. 2 intend to respond to all relevant questions regarding 3 (Video played.) 3 this lawsuit; however, at the present time, my attorneys 4 VIDEO WITNESS: "What did I do to Jeffrey and 4 have counseled me I cannot provide answers to any 5 what did Jeffrey do to me? I went out there 5 questions that may be relevant to the lawsuit. I must 6 multiple times; I can't count. And I would be on a 6 accept this advice or risk losing my Gth Amendment right 7 massage table, massaging his legs. Ho would turn 7 to effective representation. Accordingly, I must assert 8 over, his penis would be hanging out. He would put 8 my federal constitutional right as guaranteed by the 9 a vagina -- or vibrator to my vagina. He would 9 5th, 6th and 14th Amendment to the United States 10 touch my vagina with his fingers. He would touch 10 Constitution. 11 my breasts. He would try to kiss my mouth. He 11 MR. PIKE: Same objection to that line of 12 would bring my hands toward his penis." 12 questioning. 13 (Video stopped.) 13 BY MR. KUVIN: 14 BY MR. KUVIN: 14 Q. As. was standing naked in your bathroom 15 Q. Did you do that with that girl? 15 before you when she was 15, did you ask her to turn 16 MR. PIKE: Fenn. 16 around so you could see her ass better? 17 THE WITNESS: I intend to respond to all 17 MR. PIKE: Form, argumentative, harassing. 18 relevant questions regarding this lawsuit; however, 18 lacks appropriate predicate, foundation. 19 at the present time, my attorneys have counseled me 19 THE WITNESS: ri1respond to that as I 20 I cannot provide answers to any questions that may 20 responded to your last question, which is, I intend 21 be relevant to this lawsuit. I must accept this 21 to respond to all relevant questions regarding this 22 advice or risk losing my 6th Amendment right to 22 lawsuit; however, at the present time, my attorneys 23 effective representation. Accordingly, I must 23 have counseled me I cannot provide answers to any 24 assert my federal constitutional rights as 24 questions that may be relevant to this lawsuit. I 25 guaranteed by the 5th, 6th and 14th Amendment to 25 must accept their advice or risk losing my 6th 3 (Pages 177 to 180) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana RIccluti bl8d9df0-4fcb-496c-a244-099977073134 EFTA01087057 Page 181 Page 183 1 Amendment right to effective representation; 1 Q. And her father is Robert Maxwell? 2 therefore, I must assert my federal constitutional 2 A. Was Robert Maxwell. 3 rights as guaranteed by the 5th, 6th and 14th 3 Q. Pm sorry, he's passed, correct? 4 Amendment to the United States Constitution. 4 A. Correct. 5 BY MR. KUVIN: 5 Q. She is a close friend of yours, is she not? 6 Q. WhenM. was 15 years old and standing naked 6 A. Fm going to respond to that question the same 7 in front of you in your bathroom, did you tell her that 7 way I've responded to most of your other questions here 8 you could help her become a model? 8 today, Mr. Kuvin, which is, I intend to respond to all 9 MR. PIKE: Same objections, including 9 relevant questions regarding to this lawsuit; however, 10 foundation. 10 at the present time, my attorneys have counseled me I 11 THE WITNESS: Is it different than the last 11 cannot provide answers to any questions that may be 12 question? 12 relevant to this lawsuit. I must expect — accept their 13 MR. KUVIN: Uh-huh. 13 advice or risk losing my 6th Amendment right to 14 MR. GOLDBEftGER: Just go ahead. 14 effective representation. Accordingly, I must assert my 15 THE WITNESS: Okay. I intend to respond to 15 federal constitutional rights as guaranteed by the 5th, 16 all relevant questions pertaining to this lawsuit; 16 6th and 14th Amendment to the United States 17 however, at the present time, my attorneys have 17 Constitution. 18 counseled me I cannot provide answers to any 18 Q. Ghisluine Maxwell has accompanied you to 19 questions that may be relevant to this lawsuit, so 19 numerous social events in the last few years; isn't that 20 I've answered most questions here today the same 20 true? 21 way. I must expect that - accept their advice or 21 MR. PIKE: Form. 22 risk losing my 6th Amendment right to effective 22 THE WITNESS: I'm going to respond to that 23 representation. Accordingly, I assert my federal 23 question the same way I've responded to most of 24 constitutional rights as guaranteed by the 5th, Gth 24 your questions here today, which is, I intend to 25 and 14th Amendment to the United Slates 25 respond to all relevant questions regarding your Page 1.87 Page 184 1 Constitution. 1 lawsuit; however, at the present time, my attorneys 2 BY MR. KUVIN: 2 have counseled me I cannot provide answers to any 3 Q. Who is GhIslaine Maxwell? 3 questions that may be relevant to that lawsuit. I 4 A. I intend to respond to all relevant questions 4 must accept their advice or risk losing my 6th 5 regarding this lawsuit; however, at the present time, my 5 Amendment right to effective representation. attorneys have counseled me that I cannot provide 6 Accordingly, I must assert my federal 7 answers to any questions relevant to this lawsuit. As I 7 constitutional right as guaranteed by the 5th, 6th 8 have done to most of your other questions here today, I 8 and 14th Amendment of the United States 9 must accept their advice or risk losing my 6th Amendment 9 Constitution. 10 right to effective representation. Accordingly, I 10 BY MR. KUVIN: 11 assert my federal constitutional rights as guaranteed by 11 Q. One ofyour houseboys that has been deposed in 12 the 5th, 6th and 14th Amendment to the United States 12 this case testified that you were a rather nice 13 Constitution. 13 gentleman that used to talk to the staff, and that when 14 MR. KUVIN: Let me show the camera what we'll 14 Ms. Maxwell came into the picture, that you stopped 15 mark as Exhibit 9 to this deposition. 15 talking to the staff and the staffhad to communicate 16 THE VIDEOGRAPI-IER: Okay. 16 through Ms. Maxwell. Do you agree or disagree with 17 (Plaintiffs Exhibit No.9 was marked for 17 that? 18 identification.) 18 MR. PIKE: Form, foundation, predicate, 19 BY MR. KUVIN: 19 argumentative, assumes facts not in evidence. 20 Q. Let me show you what we've marked as Exhibit 9 20 THE WITNESS: I'm going to answer that the 21 to your deposition. Do you recognize Ghislaine Maxwell 21 same way I've answered most ofyour questions here 22 in this photograph? 22 today, which is, I intend to respond to all 23 A. Yes. 23 relevant questions regarding this lawsuit; however, 24 Q. And who is she standing with? 24 at the present time, my attorneys have counseled me 25 A. Her father. 25 that I cannot provide answers to any questions that 4 (Pages 181 to 184} PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Rican' (601-280.428.9381) Electronically signed by Jeana Flicciutl (601.280-428.9381) bf8d9O0-4(cb-496c-a244-09997 7073134 EFTA01087058 Pogo Page 187 1 may be relevant to your lawsuit. I must accept 1 to respond to all relevant questions regarding this 2 their advice or risk losing my 6th Amendment right lawsuit; however, at the present time, my attorneys 3 to effective representation. Accordingly, I assert 3 have counseled me I cannot provide answers to any 4 my federal constitutional rights as guaranteed by 4 questions relevant to that lawsuit. I must accept the 5th, 6th and 14th Amendment of the United 5 their advice or risk losing my Gth Amendment right 6 States Constitution. 6 to effective representation. Therefore, I assert 7 BY MR. KUVIN: 1 my federal constitutional rights as guaranteed by 8 Q. Ho also testified that he felt you were a 0 the 5th, 6th and 14th Amendments to the United 9 rather nomad guy until Ms. Maxwell came into the Stales Constitution. 10 picture, and that she led you into this life of 10 BY MR. KUVIN: 11 perversion, sexual perversion. Do you agree with that? 11 Q. Do you know where Donald Trump's Maralago 12 MR. PIKE: Same objections. 12 estate is? 13 THE WITNESS: I'm going to respond to that the 13 A. Yes. 14 same way I've responded to most of your questions 14 Q. Have you been there? 15 hem today, Mr. Kuvin, which is, I intend to 15 A. Yes. 16 respond to all relevant questions regarding this 16 Q. Who with? 17 lawsuit; however, at the present time, my attorneys 17 A. Pm going to have to answer that question the 18 have counseled me 1cannot provide answers to any 18 same way I've answered most of your other questions here 19 questions relevant to this lawsuit. I must accept 19 today. I intend to respond to all relevant questions 20 their advice or risk losing my 6th Amendment -- 20 regarding this lawsuit; however, at the present time, my 21 excuse me -- I must accept their advice or risk 21 attorneys have counseled molcannot provide answers to 22 losing my 6th Amendment right to effective 22 any questions that may be relevant to the same lawsuit. 23 representation. Accordingly, I must assert my 23 I must accept their advice or risk losing my 6th 24 federal constitutional rights as guaranteed by the 24 Amendment right to effective representation. 25 5th, 6th and 14th Amendment to the United States 25 Accordingly, I must assert my federal constitutional Page 186 Page 188 1 Constitution. 1 rights as guaranteed by the 5th, 6th and 14th Amendment 2 BY MR. KUVIN: 2 to the United States Constitution. 3 Q. Did Ms. Maxwell procure underaged girls for 3 Q. Have you seen the high school transcripts you to have sexual relationships with? 4 grades ofgirls that you have had sexual relationships 5 A. I'm going to answer that question the same way 5 with dating back to 2005? 6 I've answered most of your other questions today, 6 MR. PIKE: Form, relevance, improper 7 Mr. Kuvin, which is, I intend to respond to all relevant 7 hypothetical, lacks facts -- assumes facts not in 8 questions regarding this lawsuit; however, at the 8 evidence, lacks appropriate predicate, foundation. 9 present time, my attorneys have counseled me I cannot 9 THE WITNESS: I'm going to answer that 10 provide answers to any questions relevant to that 10 question the same as I've answered most of your 11 lawsuit. Excuse me. I must accept their advice or risk 11 other questions here today, Mr. Kuvin, which is, I 12 losing my 6th Amendment right to effective 12 intend to respond to all relevant questions 13 representation. Accordingly, I must assert my federal 13 regarding this lawsuit; however, at the present 14 constitutional rights as guaranteed -- guaranteed by the 14 time, my attorneys have counseled me that I cannot 15 5th, 6th and 14th Amendments to the United States 15 provide answers to any questions that may be 16 Constitution. 16 relevant to this lawsuit. I must accept their 17 Q. Ms. Maxwell procured a particular underaged 17 advice or risk losing my 6th Amendment right to 18 girl who worked at Donald Trump's Maralago, for you to 18 effective representation. Accordingly, I assert my 19 have a sexual relationship with; isn't that true? 19 federal constitutional rights as guaranteed by the 20 MR. PIKE: Form, argumentative, lacks 20 5th, 6th and 14th Amendment to the United States 21 appropriate predicate, foundation, assumes facts 21 Constitution. 22 not in evidence. 22 BY MR. KUVIN: 23 THE WITNESS: I'm going to respond to that the 23 Q. Do you deny that the high school transcripts 24 same way I've responded to most of your other 24 which were found in your trash on Palm Beach that showed 25 questions hero today, Mr. Kuvin, which is, I intend 25 the ages ofsome of the girls you were engaged with 5 (Pages 185 to 188) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana Ricciuti bted9dfOA(cb-496c-a244-099977073134 EFTA01087059 Page 189 Page 191 sexual ads with at your home dune from your house? 1 MR. GOLDBERGER: Break time? 2 MR. PUCE: Same objection in addition to 2 MR. KUVIN: No, not again. Please not. 3 argumentative and harassing. 3 lust let us know when you're good to go. 4 THE WITNESS: I intend to respond to all 4 THE VIDEOGRAPHER: Were back on the record at relevant questions regarding this lawsuit; however, 5 2:04. This will be the beginning of tape No. 3. 6 as I've done with most of your other questions 6 BY MR. KUVIN: today, at the present time my attorneys have 7 Q. Do you have security cameras throughout your 8 counseled me that I cannot provide answers to any 8 home on Palm Beach Island? 9 of those questions relevant to this lawsuit. I 9 A. I'm going to answer that question the same way 10 must accept their advice or risk losing my 6th 10 I've answered most of your questions here today, 11 Amendment right to effective representation. 11 Mt Kuvin. I intend to respond to all relevant 12 Accordingly, I must used my federal 12 questions regarding this lawsuit; however, at the 13 constitutional rights as guaranteed by the 5th, 6th 13 present time, my attorneys have counseled me I cannot 14 and 14th Amendments to the United States 14 provide answers to any questions relevant to the 15 Constitution. 15 lawsuit I must accept their advice or risk losing my 16 BY MR. KUVIN: 16 6th Amendment right to effective representation. 17 Q. Did you have numerous photos of nude young 17 Accordingly, I assert my federal constitutional rights 18 women, girls under the ago of 18, back in your home 18 as guaranteed by the 5th, 6th and 14th Amendment to the 19 in -- on Palm Beach Island in 2005 and 2006? 19 United States Constitution. 20 A. I'm going to have to respond to that question 20 (Plaintiffs Exhibit No. 10 was marked for 21 tho same way I've responded to most of your questions 21 identification.) 22 here today, which is, I intend to respond to all 22 MR. KU VIN: ru show the camera a photograph 23 relevant questions regarding this lawsuit; however, at 23 here. Okay? 24 the present time, my attorneys have counseled 'no I 24 THE VIDEOGRAPHER: LIR it up. Yeah, there 25 cannot provide answers to any questions relevant to the 25 you go. Okay. Page 190 Page 192 - 1 same lawsuit. I must accept their advice or risk losing 1 MR. KUVIN: Okay? 2 my 6th Amendment right to effective representation. 2 BY MR. KUVIN: Accordingly, I must assert my federal constitutional 3 Q. Let me show you what we marked as Plaintiffs rights as guaranteed by the 5th, 6th and 14th Amendment. 4 Exhibit 10. Do you recognize this young lady? Q. Did you have photographs of girls under the 5 A. Yes. 6 ago of ten who were nude, either partially or fully 6 Q. Who is sho? 7 nude, in your home on Palm Beach in 2005 and 2006? 7 A. Her name is (phonetic). 8 MR. PIKE: Fenn. 8 Q. And who is she? 9 THE WITNESS: I'm going to respond to that 9 A. I just -- her name is 10 question the same way I've responded to most of' 10 Q. How do you recognize her? 11 your other questions, which is, I intend to respond 11 A. I don't understand the question. 12 to all relevant questions regarding this lawsuit; 12 Q. Well, is she a friend of yours? Did she work 13 however, at the present time, my attorneys have 13 for you? Flow do you recognize her? 14 counseled me I cannot provide answers to any 14 A. How do I recognize her? 15 questions relevant to this lawsuit. I must accept 15 Well, I'd like to respond to that question 16 this advice or risk losing my 6th Amendment right 16 but, however, my attorneys have told me that I can't 17 to effective representation. Accordingly, I assert 17 respond to any questions today that may -- excuse me. I 18 my federal constitutional rights as guaranteed by 18 intend to respond to all relevant questions regarding 19 the 5th, 6th and 14th Amendments of the United 19 this lawsuit; however, at the present time, my attorneys 20 States Constitution. 20 have counseled mo that I cannot provide answers to any 21 THE VIDEOGRAPHER: Mr. Kuvin, fin sorry I have 21 questions relevant to this lawsuit. I must accept their 22 to change. 22 advice or risk losing my 6th Amendment right to 23 MR. KUVIN: Go ahead 23 effective representation. Accordingly, I assert my 24 THE VIDEOGRAPHER: well go off the record at 24 federal constitutional rights as guaranteed by the 5th, 25 2:03. This will be the end of tape No.2. 25 Gth and 14th Amendment to the United States 6 (Pages 189 to 192) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Rletiutl Electronically signed by Jeana Riccardi bf8d9tlf041cb-496c-a244-09997 7073134 EFTA01087060 Page 191 Page 195 1 Constitution. 1 THE WITNESS: Pm going to respond to that 2 Q. Did you have sex with IM? 2 question the same way I've responded to most of 3 A. I'm going to answer that question like I've 3 your questions here today, Mr. Kuvin, which is, I 4 answered most of your questions here today, which is, 1 4 intend to respond to all relevant questions 5 intend to respond to all relevant questions regarding 5 regarding this lawsuit -- excuse me, however, at 6 this lawsuit; however, at the present time, my attorneys 6 the present time, my attorneys have counseled me I 7 have counseled me I cannot provide answers to any 7 cannot provide answers to any questions relevant to 8 questions relevant to this lawsuit. I must accept their 8 the lawsuit, or might be relevant to the lawsuit. 9 advice or risk losing my 6th Amendment right to 9 I must accept their advice or risk losing my 6th 10 effective representation. Accordingly, I assert my 10 Amendment right to effective representation. 11 federal constitutional rights as guaranteed by the 5th, 11 Accordingly, I assert my federal constitutional 12 6th and 14th Amendment to the United States 12 rights as guaranteed by the 5th, 6th and 14th 13 Constitution. 13 Amendment of the United States Constitution. 14 Q. When did you first meet Prince Andrew? 14 BY MR. KUVIN: 15 And let mo make it a compound question so I 15 Q. Did you fly with Prince Andrew on your plane, 16 don't have to repeat it over and over. When did you 16 or planes, with any underaged girls, girls under the age 17 first meet Prince Andrew, under what conditions did you 17 of18? 18 meet him, and who was present at that list meeting? 18 A. I'm going to answer that question the same way 19 A. I'm going to answer that question as I've done 19 I've answered all the other questions here today, 20 most of your questions here today, Mr. Kuvin, which is, 20 virtually, which is, I intend to respond to all relevant 21 I intend to respond to all relevant questions regarding 21 questions regarding this lawsuit; however, at the 22 this lawsuit; however, at the present time, my attorneys 22 present time, my attorneys have counseled me I cannot 23 have counseled met cannot provide answers to any 23 provide answers to any questions relevant to the 24 questions relevant to that lawsuit. I must accept their 24 lawsuit. I must accept their advice or risk losing my 25 advice or risk losing my 6th Amendment right to 25 6th Amendment right to effective representation. Page 194 Page 196 1 effective representation. Accordingly, I must assert my 1 Accordingly, I must assert my federal constitutional 2 federal constitutional rights as guaranteed by the 5th, 2 rights as guaranteed by the 5th, 6th and 14th Amendments 3 6th and 14th Amendment to the United States 3 to the United States Constitution. 4 Constitution. 4 Q. Do you 'mow 5 Mk PIKE: In addition, relevance. 5 MR. KUVIN: For the court reporter, it's 6 BY MR. KUVIN: 6 7 Q. Do you pay Ms. Maxwell a salary? 7 THE WITNESS: I intend to respond to all 8 MR. PIKE: Form. 8 relevant questions regarding this lawsuit; however, 9 BY MR. KUVIN: 9 at the present thne, my attorneys have counseled me 10 Q. Ohislaine Maxwell, so we're clear. Do you pay 10 I cannot provide answers to any questions relevant 11 her a salary? 11 to the lawsuit. I must accept this advice or risk 12 A. I'd like -- excuse me. I'm going to answer 12 losing my 61h Amendment right to effective 13 that question the same way I've answered most of your 13 representation. Accordingly, I assert my federal 14 questions here today, which is, I intend to answer all 14 constitutional rights as guaranteed by the 5th, 6th 15 questions relevant to this lawsuit; however, at the 15 and 14th Amendments to the United States 16 present time, my attorneys have counseled me I cannot 16 Constitution. 17 provide answers to any questions relevant to this 17 MR. KUVIN: Let me show the camera what we'll 18 lawsuit. I must accept their advice or risk losing my 18 mark as Exhibit II. 19 6th Amendment right to effective representation. 19 (Plaintiffs Exhibit No. 11 was marked for 20 Accordingly, I assert my federal constitutional rights 20 identification.) 21 as guaranteed by the 5th, 6th and 14th Amendment to the 21 THE VIDEOORAPHER: Okay. 22 United States Constitution. 22 MR. KUVIN: Okay? 23 Q. Did you provide any underaged girls for sex to 23 BY MR. KUVIN: 24 Prince Andrew? 24 Q. In Exhibit 11, sir, you're standing with a 25 MR. PIKE: FO1111 25 woman. Who Is that woman in that photograph? 7 (Pages 193 to 196) (.1) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Juana Ricciuti Electronically signed by Arena RIcciull 618d9dt04tcb-496c-a240-098977073134 EFTA01087061 Page 19 / Page 199 1 A. (phonetic). A. I intend to respond to all relevant questions 2 Q. Where were you? 2 regarding this lawsuit; however, as I've done to most of 3 A. I intend to respond to all relevant questions 3 the questions at the present time, my attorneys have 4 regarding this lawsuit; however, at the present time, my 4 counseled me that I cannot provide answers to any of' attorneys have counseled me Icannot provide answers to 5 those questions that may be relevant to the lawsuit. I 6 any questions that may be relevant to this lawsuit. I 6 must accept this advice or risk losing my Gth Amendment must accept this advice or risk losing my 6th Amendment 7 right to effective representation. Accordingly, 8 right to effective representation. Accordingly, I must 8 asset my federal constitutional rights as guaranteed by 9 assert my federal constitutional rights as guaranteed by 9 the 5th, 6th and 14th Amendments of the United States 10 the 5th, 6th and 14th Amendments to the United States 10 Constitution. 11 Constitution. 11 BY MR. KUVIN: 12 MR. KUVIN: And just so the court reporter 12 Q. Fin going to show you what we'll mark as 13 knows, Ghislaine is spelled G-H-I-S-L-A-I-N-E. 13 Exhibit 13. Let me show it to the camera, first. 14 BY MR. KUVIN: 14 (Plaintiffs Exhibit No. 13 was marked for 15 Q. Who is ,excirse 15 identification.) 16 me? 16 BY MR. KUVIN: 17 A. I'm going to answer that question the same way 17 Q. Sir, is It true that Exhibit 13 shows your 18 I've answered most of your questions here today, which 18 personal assistant, 19 is, I intend to respond to all relevant questions 19 A. I intend to respond to all relevant questions 20 regarding this lawsuit; however, at the present time, my 20 regarding this lawsuit; however, at the present time, my 21 attorneys have counseled me I cannot provide answers to 21 attorneys have counseled me that I cannot provide 22 any questions relevant to the lawsuit. I must accept 22 answers to any questions that may be relevant to this 23 their advice or risk losing my 6th Amendment right to 23 lawsuit. I must accept their advice or risk losing my 24 effective representation. Excuse me. Accordingly, I 24 6th Amendment right to effective representation. 25 must assert my federal constitutional rights as 25 Accordingly, I assert my federal constitutional rights Page 198 Page 200 1 guarantee -- guaranteed by the 5th, 6th and 14th 1 as guaranteed by the 5th, 6th and 14th Amendment to the 2 Amendment tote United States Constitution. 2 United States Constitution. 3 (Plaintiffs Exhibit No. 12 was marked for 3 Q. Let me show you what we'll mark as Exhibit 14. ,1 identification.) 4 (Plaintiffs Exhibit No. 14 was marked for 5 MR. KUVIN: Let me show to the camera what 5 identification.) 6 we've marked as Exhibit 12. 6 BY MR. KUVIN: 7 BY MR. KUVIN: 7 Q. Sir, does Exhibit 14 show --,a 8 Q. Let me show you what I've marked as Exhibit 8 girl that you have had a sexual relationship with since 9 12. Do you recognize any of the girls in that 9 before she was 18 years old? 10 photograph? 10 MR. PIKE: Fenn, argumentative, harassing, 11 A. I'm going to answer that question the same way 11 assumes facts not in evidence, lacks appropriate 12 I've answered most of your other questions here today, 12 . predicate and foundation. 13 Mr. Kuvin, which is, I intend to respond to all relevant 13 THE WITNESS: I intend to respond to all 14 questions regarding this lawsuit; however, at the 14 relevant questions regarding this lawsuit; however, 15 present time, my attorneys have counseled me that 1 15 at the present time, my attorneys have counseled me 16 cannot provide answers to any questions that may be 16 I cannot provide answers to any questions relevant 17 relevant to the lawsuit. I must accept their advice or 17 to this lawsuit. I must accept their advice or 18 risk losing my 6th Amendment right to effective 18 risk losing my 6th Amendment right to effective 19 representation. Accordingly, I assert my federal 19 representation. Accordingly, I assert my federal 20 constitutional rights as guaranteed by the 5th, 6th and 20 • constitutional rights as guaranteed by the 5th, 6th 21 14th Amendment to the United States Constitution. 21 and 14th Amendment to the United States 22 Q. Sir, isn't it true that in what we've marked 22 Constitution. 23 as Plaintiff's Exhibit 12 the blond standing on the 23 BY MIL KUVIN: 24 left is and the blonde, dirty blonde
To: Jeffrey [email protected]] From: story cowles Sent Wed 10/7/2009 9:16:47 PM Subject: Jerry Goldsmith Jerry Goldsmith just called and said that he can not make it today. He said he will talk to you some time tomorrow and he has some things to go over with you about a deposition. Story EFTA_R1_01511445 EFTA02438310
United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN PLEASE TAKE NOTICE THAT, pursuant to the subpoena we served counsel with on June 14, 2016, the undersigned counsel provides this Notice of Taking the Videotaped Deposition of the below-named individual on the date and hour indicated. NAME: Jeffrey Epstein DATE AND TIME: September 9, 2016 at 9:00 a.m. LOCATION: Boies Schiller & Flexner, LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 The videotaped deposition will be taken upon oral examination before Magna Legal Services, or any other notary public authorized by law to take depositions. The oral examination will continue from day to day until completed. The video operator shall be provided by Magna Legal Services. This deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as arc permitted under the rules of this Court. EFTA_R1_00015649 EFTA01735020 Dated: August 15, 2016. BOLES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boles Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boles Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro It Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801)585-5202' This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. EFTA_R1_00015650 EFTA01735021 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 15th day of August, 2016, I served the attached document PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN via Email to the following counsel of record. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] Email: jpatzliuca(whinflaw.com Is/ Sigrid S. McCawley Sigrid S. McCawley EFTA_R1_00015651 EFTA01735022
From: Sent: Thursday, October 25, 2018 5:22 PM To: jeffrey E. Subject: Did you write deposition against me??? I hardly believe so, who is writing this shit. Zampolli. Pls I am asking investigation and I agree I need little punishment and medical help, pscyco help, therapy. But not death I am not guilty, I swear I stopped drugs 1 EFTA_R1_01824592 EFTA02619619
511 922,419 FtIN;Cf f ift - ( df)t— Th-tittsf e: wr iwi mcfn .3:95Kona
- apt?? of *
It * ci
C PRCta MOSPats
Details of a civil lawsuit, made public in January 2035, contained a deposition from "Jane Doe 3"
that accused Maxwell of recruiting her in 1999, when she was a minor, and grooming her to
provide sexual services for Epstein.M A 2018 expose by Julie K. Brown in the M'
revealed Jane Doe 3 to be , who was previously known as
met Maxwell at Donald 'frump's Mar-a-Lago Club in Palm Beach, Florida, w en was a 16-
year-old spa attendant.M She asserted that Maxwell had introduced her to Epstein, after which
she was " omed by. the two [of them] for his pleasure, including lessons in Epstein's preferences
during oral sex". 22n631
Maxwell has repeatedly denied any involvement in Epstein's crimes.L2i In a 2015 statement,
Maxwell rejected allegations that she has acted as a procurer for Epstein and denied that she had
"facilitated Prince Andrew's [alleged] acts of sexual abuse". Her spokesperson said "the allegations
made against Ghislaine Maxwell are untrue" and she "strongly denies allegations of an unsavoury
nature, which have appeared in the British press and elsewhere, and reserves her right to seek
redress at the repetition of such old defamatory claims" [58][641
asserted that Maxwell and Epstein had trafficked her and other underage girls, often at sex
parties hosted by Epstein at his homes in New ew Mexico, Palm Beach, and the United
States Virgin Islands. Maxwell called her a liar. sued Maxwell for defamation in federal
court in the Southern District of New York in 2011. details of the settlement have not been
made public, in May 2017 the case was settled in favour,L5i with Maxwell paying
"millions" V2-61
eirxnet Emno-os - SEX PeOse- asts1C, - TARGET! NC,*
v Epstein and Maxwell (2017) ,>jk - Mirt)`Weel- 1,E;STRCOION Of
In 2017, filed a suit, in the United StatesC
D=cr Courtitr Sthir SOTS
uthern
- cDist
a l ist-
ct off
New York, again
agai tt Epstein and Maxwell, alleging that Maxwell hired her to give massages to
Epstein and laterfteatened to physically harm her or destroy her career prospects if she did not 7(
A-comply with their sexual demands* his mansion in New York and on his private Caribbean
island, Little Saint James. The suit was settled in 2018 under undisclosed terms.a413116211-4§1
sexoe,c_ -re - CA 'ROOM NAG - P C ST R.00_T i 0 CA
Affidavit filed by (2019) OF CA R.E.e
on 16 April 2019, went public and filed a sworn affidavit in federal court in New
York, alleging that she and her 15-year-ol nie, had been sexually assaulted by Epstein
and M xwell in cenarat locations in 1996. affidavit was filed in suppo f defamation
suit by against Alan Dershowitz.--9-1 According to the affidavit, had met
Maxwell and Epstein at a New York art gallery reception in 1995. The affidavit says that in the
summer of the following year, they hired her to work on an art project in billionaire businessman
Leslie Wexner'sl sion, where she was then sexually assaulted by both Maxwell and
Enstein.M711 mreported the incident to the New York Police Department and the
FBI. 21172] Her affidavit also stated that during the same summer, Epstein flew her then 15-year-
old sister, Annie, to his New Mexico property where he and Maxwell molested her on a massage
table.173X741
was interviewed for CBS This Morning in November 2019 where she detailed the 1996
assault and alleged that Maxwell had threatened both her career and her life after the assault.f251
v Epstein's estate, Maxwell, and Jane Does 1-3 (2019)
lr-tcne-Lc..Eci L...e Cit*o('& KM/ 1 ri&-FT - A ME-Kt Cf) i n)OoLOCtiENT
rN POSSESSK$ - Cal PIE
hfinc.//an wikinerfin nrn/wikUnhiclainct Maxwall 5/28
EFTA00263479
M 0 )C b ELL a0C C •2o13 krey%rtekVicki3e-dia CHOU_ Co s errAcr
5119122.3:52 PM
George, his alleged criminal activities on the islands were concealed through a complex network of
companies.(1824COVI Pe CI DISC 5 -‘‘ •fOONCI 1SC " 114Rca-re-D .4
IC-TI t'-(
Jane Doe v. Maxwell and Epstein's estate (2020)
In January 2020, a lawsuit was filed against Maxwell and Epstein alleging that they recruited a 13-
year-old music student at the Interlochen Center for the Arts in 1994 and subjected her to sexual
abuse11-811 The suit states that Jane Doe was repeatedly sexually assaulted by Epstein over a four-
year period and that Maxwell played a key role in both her recruitment and by participating in the
assaults.11-PI
Jane Does v. Epstein estate (2020)
In August 2020 9 Jane Does filed suit accusing Epstein of sexual abuse. The alleged victims in the
lawsuit include a it and 13 year old and a victim who alleged abuse in 1975.11823
Jane Doe v. Epstein estate (2020)
In August 2020 Epstein was sued by a Jane Doe accusing him of sexually abusing her for one and a
half years, beginning when she was an 18-year-old aspiring singer and model in New York.[1831
Jane Doe v. Epstein estate (2021)
A civil suit was filed against Epstein's estate in March 2021 by a Broward County woman who
accused Epstein and Maxwell of trafficking her after repeatedly raping her in Florida in 2008.1i84]
MV IC \JE---- WrIME- NTT LOGO
Second criminal case (fele i I- c°R-g-ssP(DeeN' c'E
C_chnicl-
Comenci DISCS - EMAIL
CARA P HAS
5Es QIN. ersiCcOf)C4EMCM-i PilaTO
Trafficking charges
SCSIN6 --C-S De-lirgi-OPMENT Or Vial t-1
M )5C NISIC
On July 6, 2019, Epstein was arrested by the FBI-NYPD Crimes
Against Children Task Force at Teterboro Airport in New Jersey on
sex trafficking charges;_n__11185][186][187] He was jailed at the 12t9at
7 7.)
Metropolitan Correctional Center in New York City, which has held
prisoners such as John Gotti, Joaquin "El Chao" Guzman, and Paul
Manafort.[i88][189]
According to witnesses and sources on the day of his arrest, about a
dozen FBI agents forced open the door to his Manhattan townhouse,
the Herbert N. Straus House, with search warrants. The search of his
townhouse turned up evidence of sex trafficking and also found
"hundreds — and perhaps thousands — of sexually suggestive u.s. v. Jeffrey Epstein
photographs of fully — or partially — nude females". Some of the indictment131
photos were confirmed as those of underage females. In a locked safe,
compact discs were found with handlgitten labels iFluding the
descriptionsf "Young rNamer+ [Name]", "Misc nudes . nude".19-0 Also found in
and "Girl pies
the safe were $70,000 in cash, 48 diamW--9-(111 and a fraudulent Austrian passport, which
expired in 1987, that had Epstein's photo but another name. The passport had numerous entrance
and exit stamps, including entrance stamps that showed the use of the passport to enter France,
Spain, the United Kingdom, and Saudi Arabia in the 1980s. The passport showed his place of
Lat•.••• ISIRII
EFTA00263480
9c'ucc RePoRT - orcn(- fRRRESl - -Thaccri
t\) yooct. " - eps-r6/K) compAci D
regCLETer) vtcitMS N f•-16 : 7P/cc/c/a-INC CactkOc- PEARCE 7k
DEM/MONT
PRIN110B ROM AUSTRALIA POLICE
POLICE APPMENSION REPORT
Run Date g 46/09/4015
Run Time : 15:01
AP No t 16/546998 Page s 4
7431/3
Report Job Submitted By I.D.:
other matters due to
interviewed in relation to any
The accused was not formally s KELLY.
her demean our toward
her level of intoxication and
raphic Driver's
by her South Australian Photog
The accused identity was confirmed
Licence No.
ACCUSSD
CaxoNOUNG. DOB
SIC Thu accused in this matter is
s
interviewed due to her demeanour toward
The accused in this matter yap not
police and her level of intoxication.
EFTA00263481
EFTA00263482
00/\
SS3SSO6 N 9- 1ScO N) VN02_ <3D
- 9K:3 too
(23NO\L) <30d theN ))/-4W
12N1 yc sc)9V/ -74.0>e9S ')NI WOE /r4 A cr3_139ALL
N1_ Na372W_I- A-7-L,j):10Cl Ni - )79M70c11,,1
V,. V
V A,
?!SW
DISIAI
JISW
.1".”..1.1 MIMI .1 ...... V
di N
E
• t410>e9 O9O1 c3(NiiSc.12) I
• Na.99210L-
.50 Ncr.j(40-7 7 t.7.
105 ki efacv P5 ,:j
3?.d_d -2NI ti 44O
9v4vm) -A i
DS/Q s -r•-;--/NISc) 090- 7 "71 l,•4
) -Ducm,40-J \1
). 8C5IN)6,55 cRRE) DESIGN DEVac,PMENIT
Double sided business card
front
t,i-cnas5.1nne;s
backs
Director
Tel
Acisiress hare ghdfgd
hetiY;:fai egeragrfufS sgdyueg
.• ernaP.
o wsinsapitOlft_
Director
iPictOr
Tot
Tet
Address here ghdfgd Address here ghdfgd
hefg:ywfg egfrywfgryufg sgdyueg
hefgrywfg egfrywfgryufg sgdyueg
ehfg' v.egfuyry.grouf
ehfgr wegfuyrwgrouf
email
emai
msic A .7,;:v!ca f:r 14441Ical Pre :aitionak;
Director
Tel
i zt.
.:ef.etn:- tritha
clati!:r::,;:cui
Single sided business card
email
EFTA00263483
1•4 tetssiN\E-1-4._ - HI C.- cokITACI - .518151auto
EFTA00263484
&Oto MEDICAL BOstnIESS PLAN Ak4 1-15[C vijDER
DEUELOPfreNT - CONTIN OA I-
ra Subject Sent A
Max Well Re Be warned, im feeling better, irs a book!!! Col. 8/06/20108,09 P
Jannette Fen Please do this - IN MEMORY voarzolo8:11PM
Trish & Corey FW: The Flu Shot 1/05/20104:17
Dee SkiinAorth Flu: Please send back. its hilarious!!!!! 11'0612010434
Ma' Well axo.‘ 114Si:01011:20 P
Mers.Welt n0000 2041672010 7:42 PM
tlax Pe teicoe 2-1,06, 20108:15 P
Max Well 8,07:2010 4:19 P
Max ::eil 9 07 20101037 P
Fe. IS THIS stJ ARTIST OR WI-IATr7 17:07,1231.0 TrS9 PR.
Fe
ilessace cannot be found
EFTA00263485
4"RO0c? -sPec t POST MED CENTRE - MCDICOL B05 PLAN 07006 - POO?
C_CaNTACT/ NCI SPECIAL" ST frog Con.ITRAC TS it c,,..tpt IN CeArraC
horn Subject
Re: Information sheets
Res The Specialist Medical Centre
a....---- — Re: The Specialist Medical Centre information on...
RE: The Specialist Medical Centre
Re: WEIS applications
!Pr Re: The Specialist Medical Centre inforrnatiGn or,_.
Fit; The Specialist Medical Centre
Re: The Specialist Medical Centre
Pei The Specialist Medical Centre information *7 .
The Specialist Medical Centre
'toff. Irrer.fir •iii ; .
Message cannot be fo
. . 7 , .• uniebeh Move
read to
t- From a Subject
Wiliam Smith [Spam) Specialist Medical Centre 5/
EFTA00263486
-rt bEsiGn;ER.5
PRGFC"-- 5 10.1 I GO(.O
J.>/e. G Ctielt- L060 MAyesJELC._ - EMAIL meis - Co',!
l
VtIT CE TiTCiv 17 Ire
rnedical association letter : 4
MS1C letterhead mockup
`' 1 1, 2010
IASI( Letterheads-Adarn
logo
tvlSIC logos
IASI( rnor:ku
lv1.51(," v2
kij medlcal association
letter 0.4 • I: >8 I'
MSIC letterhead mockup
11- MSIC. Letterheads -Adam
MSIC logo
°'l. 2o Loco - MSIL - MiSc
Cv
ï;;,: MS1C%2Ologo[1] (2)
MSIC%2Ologolll (2) 3.k
Iv1S1O/O20logo[11 (3)
MS1C%20logo[1] (4)
lik
SIC%C'020logolli (5)
MSI 20logof1)
SIC%2Ologo(11
tiblicationt pub
ne-Prkk-z. eK.,7
Training %20and%20Skill s%20As..:4'870412bif 230 Pyvl
RPL RCCkti.pplication form 8/04/2011 2:29 PM
RPLAssessment Matrix_2011 (1) 4/05/2011 10:31 AM I?
P,PLAssessment Matrix_2011 (2) 3:05/2011 2:51 PM
RPLAssessment Matrix_2011 8,r
Declaration200602
EFTA00263487
M.S.I.0
MEDICAL SERVICES INFORMATION CENTRE
A Service developed for
medical Professionals
Prepared November 2010
EFTA00263488
msic
A Service for Medical Professionals
PO Box 432 , Port Pirie SA 5540
Ph 0439158735
3/12/10
MEDICAL STATISTICAL OVERVIEW STUDY
SURVEY FORM
Please complete all questions and return the form in the self addressed envelope by
30/12/10 . Thank you for your support and participation in this important medical study.
Please mark boxes with an x.
If you answered NO to question 1, please answer questions 6 —13 only.
Please specify occupation: ❑ General practitioner O Manager O Director
Q.1 Do you currently have visiting specialists, e.g Dermatologists, consulting from
within your centre?
n Yes L_J No ❑ Unsure
Q.2 What specialist/s do you currently have visiting and consulting from within your
centre?
O Dermatologist O Allergist O Immunologist
O Dietician O Sports Therapist
❑ Other, please specify :
Q.3 How often do the specialist/s consult within your centre?
O Every 6 weeks ❑ Every 8 weeks O Every 12 weeks
O Other, please specify :
Q.4 In which Regions or Medical Centres do you currently refer your patients to, in
order to receive consultations and treatments for specialists services?
D Regional hospital O Regional Medical Surgery 's
O Private Practices El Metropolitan Specialists
O Surgery currently employed at
Please Specify :
Pg 1
EFTA00263489
Thzc,c_Te-O H
MISC lc aus INJES5 DEAset...c-.)em6f14/7
VICfit At4i.
f
t-ocgo DE.SicaN)e , N 2010 -TFRGETED
Dr Abdul Kajani
S4-uP )t._ Ki kr , Nc tic NeW
- r 45 Gertrude Street
PEDet..6 Port Pide SA 5540
ABN 24 236 238 701
4
PH: (08) 8633 2544 FAX: (08) 8633 134
6 0\i ‘.41-
i C_ IN) Tfr ie- PO S- SSiOti &E POSige)1.-ir's
AI5C J ME
C‘iC KN IME Nti r Cc nIn le: cre i) 1' P
-
_-
c- sic IN 4 itirAxwEz_c_
CA
tR rY TH EF T- - itaRcE:fii\Y4 OF
TWELLE <:- TU FV -• l'g Cf
TeRCIer -6 -1-) V ic-1-1 ae,V7 Of 9
Mrs
c:-0t-4PRCI eiP•ST-C-AN - MAxu~1Ec C,
RECEIPT - 22 Jul 2014 $13.00
(Mrs Call for ten% Wain 28A3512014)
22 Jul 2014 Cash
Total Receipts $13.00
This Receipt
Previous Bal
$13.00 - $13.00
Total Outstanding
I
owan $04:,
THANK YOU FOR YOUR PAYMENT
w6crE c> i0 4os1 C4C)c)6R.NNIENT
,AC--MAxsAEL1-- Ers-roNS coNs
Pc.NP I N.\\)c_i_sJtOCi
te)RGETlNCt Of - AN
- rt Nc ,IG .R .oc t-i( N) ci or TH E --rPRe,E----rt,
SE,se-vp,c- -I-PK6e
(-1 (Qc., ICAC-- Ill IRS VNAP(N)F) ,
LP57 - frnxW-c-ca_ - SE( P‘BOsE. RA 1Qc-,
4 -Tot-IN) oc,SEN to\c -rRPLieN 6,0Q6-1c(0(-163\11-
CO ONJEC--Tat-) P\NS.
EFTA00263490
Cc.)t-APLe.--1-ED tc..)-ZDiN)es5 PL•di c•.) AMER KeViEW - Ntornez, Fe-rtie r.-14 a
7..E.N1f5TOLL-ED c"..) cc*-IPOTF_R ;007 .
c-c -S-CRV.;C:riQi\I Kiat-16 1-4,:- 11)119ohtD
e.A.; s% NICS5 PLBIN:1 C:t• -
sTke-.67"
BUSINESS PLAN
>--"11011....--ccEcTUF)e- PROFGRM/ THEFT IN) C4o\/ posscsiloat
cONSPIRE-s:> DeSTROcifet 6F- CRkEER SE)<<.,1P/-
THE SPECIALIST MEDICAL CENTRE
Inn
>)( PREPARED SEPTEMBER 2009 4-
c-crift-rek - .9CC9
ccmpLe-rao PLAN iNr1
D ccfrItVrelZ.
EFTA00263491
; ; • ;
icnt [317mEss PLAN ,
; ;• •••.•(••••••••••• ; ;••••; • I I" ...
73N rktee.--rt -i roc sEs s'c ft - 0
200 6- At2 Meb
) OF eRee-R - DESCROCia
CADQER1•1 MCAYT POSSESS(
r-
ensnv innos
CD
sv
hawed wee ic
N.)
U1
L
r--
CO
EFTA00263492
mecqc.ei- a 0sii\1•EisS ('LA - 140•111) WRITTEN) F-C
Prz‘‘)° (1
0E- t-10-10\1,01" I NSTOLL6D cn1 D C...a4POreR. (9C06 - aCeq
t'W‘S - Vel: •,(45. ilEAL:TH DCIE
DEO L CD F0wDiNci - sew
It
kiRr..I-INlEitz FOR FIWbitJG NIC) I NFc-Rmfri-icA
t)N-rit_ ePrtia -) rcivryNG oarcOrmes‘,11
cGMt'C£TED
c.k.A.iriciol Cern .C..41 -7601. ksiNesS PLON, NSIC
.
SA Health Care Plan
tr,
- FPL5 i C-D bCC.or4E,NT
ge:rc:R ro Srocie 2 fiNID 5TOCIE 3 silt-fir
•
-Arci-kol4t ) Paa/Los 0 ccLRa
Pft.)PeR.Ty Herr"
RE0 IC0,3 c2t.,06 - 0CX)c/
* 19g3 '"NEn(41. SC.CCP posatoicek
ozoti - FiA) Fia(No PORK - VoRtuo
Loc.firtc.N)s
EFTA00263493
SIDS p)mmcAm c,oveampierr-& c"^)7')N 1993,
;•4 Ft RSV c_cot\I-r - r1)9t- pRopaRry -THErr I993i
\)-z:Lf__ec-
t.
*FottvIcrt101,) oc: 5tfly - INFATA-T fci (r'elP PC"rriolAER, 44t-
k. Ng 3 , 119RGETEb VIti pd7 A6En,
0,21Derft6-6/eRSTCHLDize
CoQERNmenn- ONb PCx-tcE TARCiErl A)C1 C t-IN)
Di Vt A-c*/ twoc..O (NG, PyMEtrkf
6c,ERN31.-/ekli
Scotkc65 - 7A-rEezecroN._ PRoP5R-iy
vicruNS eNNIQ HomE
4 REmara Lcc..p-rtot.) - roftm t-I E->&
1993 - Wilimulka, South Australia - First Intellectual
Property Theft from the privacy of my own home
Government illegal surveillance
.pX I hand designed a baby sling that wrapped around my
infant son, Clinton and stopped him from rolling over onto
his stomach in his sleep as he had reflux and would roll over
onto his stomach in the middle of the night and wake up and
cry.
•:=.4I did a fashion design course when I was 15 years oldie
Kadina and was taught how to draw patterns and design
clothing and sew them from the patterns.
I used this knowledge and skills to design the baby sling.
I also applied this degree to my fashion design business
A J Monequic in 2010 - 2012
NEFOT 5LE-p ?mrritiN)E
GOB/
Co ro To jot-en) ot_56A/ - A657-
ErsTEeki - ti/F)x vJc
EFTA00263494
i'lkE-fkF)N; C.icoe: FAI-_-_i.ri - P<..0Dc.1-1‘‘C - CPS1 t.-. i N,
2/12(22, 8:01 AM • A Silky Warning on Infant Sleep Posltloners
4a,ii.4._ ctiNn-oK, nci3Ac
---- . verywell family 4
-F)Me.lk(Cf) iN1 C.% cVff al\lfrleNT -r--4QtiFi'ie-b - r0 -7-1-41K) OLSeNi 10)1:u KO
BABIES HEALTH & SAFETY SeORCE OF COMNOW_CsIEN1
pDF 60LIERNMEvi -719-RGte'rri\e
A Safety Warning on Infant Sieep
Positioners
'Safe Sleep' Products That Aren't So Safe
By Heather Corley Updated on November 25, 2019
medicauvramiewad bYLY11ClOy Garbi, JVID
h99-5 Firk6-i" EA)ENT" or li\MccerOftc- PRoPERTY TfiLleiP ar larNaltic GettY Images
IN ILL r-i of_01 C)C--Sf6NE- ;NS Pf.t 419-Cy c H0HE
ktl\ap10,
-3N)-r pc€,ITioNcR- p)friexic,90.3
-4Sincer1994 the American Academy of Pediatrics (AAP)has recommended
babies be put on their backs to sleep to prevent sudden infant death
syndrome (SIDS). Shortly after the "Back-to-Sleep" campaign began, a new
product entered the marketan infant sleep_positioner, designed to keep
babies from rolling over onto their tummies while they are sleeping. ;lc
EFTA00263495
ikem-,R CA.c..x;ea. 1-1E_J\O - CcK,K)6c-FLE) Een-FEIN$f-
.. 3/9/22, 11:54 AM I \low e emENT Joe Bieehs faith comes through In speed% quoting hymn. Bible verse
Vgek,E,Q 11:, EN cE, AMER n•WctArEID coKIN1ECTEJ
-r RG,ET -( rs-IA>
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY CIVIL DIVISION CASE NO.: 502009CA040800 AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, etc., et al., Defendant(s). ORDER ON DEFENDANT/COUNTER-DEFENDANT'S MOTION FOR PROTECTIVE ORDER IN REGARD TO THE DEPOSITION DUCES TECUM OF RECORDS CUSTODIAN AND TRUSTEE HERBERT STETTIN THIS CAUSE came before the Court upon the above Motion, the Court heard argument of counsel and is fully advised in the premises. Based upon the foregoing, it is CONSIDERED, ORDERED AND ADJUDGED as follows: The Subpoena seeks all e-mail communication between various attorneys of the former Rothstein firm and various governmental offices regarding JEFFREY EPSTEIN. The request is not limited to time, subject matter or scope and, according to the documents presented to this Court, could be in excess of 10,214 pages of e-mails. At this point, the Court finds that the request is overbroad and not necessarily calculated to lead to admissible evidence. The purported basis for obtaining these records is to establish some type of "abuse of process" in regard to the non-prosecution agreement entered into between the government and the Plaintiff. At present, there is no pending Complaint by the Plaintiff which has withstood a Motion to Dismiss dealing with the issue of whether or not some actions by the Defendant in regard to the non-prosecution agreement could constitute "abuse of process". Therefore, the Defendant's Motion for Protective Order is EFTA00603169 Epstein tt. Rothstein, et al. Case No. 502009CA040800XXXJCMBAC Order Page 2 granted and the Objection to production of records is hereby granted, both without prejudice. DONE AND ORDERED this t4 11;;;ofJuly 011 t WeSt Palm Beach, Palm Beach County, Florida. DAVID F. CROW CIRCUIT COURT JUDGE Copy furnished: JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd. JOSEPH L. ACKERMAN, JR., ESQUIRE, JACK GOLDBERGER, ESQUIRE, MARC NURIK, ESQUIRE, GARY M. FARMER, JR., ESQUIRE MARTIN WEINBERG, ESQUIRE, EFTA00603170
Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.502008CA037319XXXXMB AB Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF VOLUME I Tuesday, November 10, 2009 11:13 a.m. - 6:12 p.m. 250 S. Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Sandra W. Townsend, FPR PROSE COURT REPORTING AGENCY Notary Public, State of Florida West Palm Beach Office (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7-901Po7174075 3501.182-102 Page 1 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094347 EFTA01248007 Page 2 1 APPEARANCES: 2 On behalf of the Plaintiff III.: 3 On behalf of Plaintiffs On behalf of Plaintiff U U • • • 18 On behalf of the Defendant: 19 ROBERT CRITTON, ESQUIRE BURMAN, CRITTON, LUTTIER & COLEMAN 20 515 North Flagler Drive Suite 400 21 West Palm Beach, Florida 33401 Phone: 561.842.2820 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 2 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094348 EFTA01248008 Page 3 1 On behalf of the Witness: 6 7 ALSO PRESENT: 8 MICHAEL DOWNEY, VIDEOGRAPHER 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-75C0 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7-90flb7174075 3501.182-102 Pagc 3 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094349 EFTA01248009 Page 4 1 2 EXHIBITS 3 4 NUMBER DESCRIPTION PAGE 5 6 Plaintiff: 7 Exhibit number 1 Notebook page 14 8 Exhibit number 2 Photograph 134 9 Exhibit number 3 Photograph 137 10 Exhibit number 4 Photograph 138 11 Exhibit number 5 Photograph 247 12 13 Defendant: 14 Exhibit number 1 Transcript 140 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f1134663-4dad-94e740ftb7174075 3501.182-102 Pagc 4 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094350 EFTA01248010 Page 5 1 PROCEEDINGS 2 3 Deposition taken before Sandra W. Townsend, Court 4 Reporter and Notary Public in and for the State of 5 Florida at Large, in the above cause. 6 - - - 7 VIDEOGRAPHER: We're on the video record. 8 This is the 10th day of November, the year 2009. 9 The time is approximately 11:13 a.m. 10 This is the videotaped deposition of 11 in the matter of III., Plaintiff, versus 12 Epstein, Defendant. 13 This deposition is being held at 250 South 14 Australian Avenue, West Palm Beach, Florida. 15 My name is Michael Downey. I'm the 16 videographer, employed by Visual Evidence. 17 Would the attorneys please announce their 18 appearances for the record. 19 MR. Yes. , on behalf of 20 Plaintiff III. 21 MR. on behalf of 22 Plaintiffs 23 MR. on behalf of 24 • 25 MR. CRITTON: Robert Critton, on behalf of (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 5 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094351 EFTA01248011 Page 6 1 Jeffrey Epstein. 2 MS. and 3 here on behalf of witness, 4 THEREUPON, 6 having been first duly sworn or affirmed, was examined 7 and testified as follows: 8 THE WITNESS: So help me God. 9 MR. CRITTON: Let me just note one thing for 10 the record, is -- it's been -- this case for this 11 depo has been noticed both in the State Court case. 12 It's been noticed as well -- cross noticed by at 13 least on behalf of his clients two 14 through eight in the Federal Court case. The only 15 two lawyers who apparently are not here, but they 16 obviously have notice of it. And Mr. didn't 17 notice it, but obviously he's -- cross notice, but 18 he's here -- Mr. on behalf of his three 19 clients, and apparently Mr. Garcia chose, they 20 chose not to come for whatever reason, but they 21 would have received notice from everybody. 22 DIRECT EXAMINATION 23 BY MR. 24 Q. Good morning. 25 A. Morning. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-56634dad-94e7-90ftb7174075 3501.182-102 Page 6 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094352 EFTA01248012 Page 7 Q. Just want to make sure he was done. 2 I introduced myself in the beginning, but my 3 name is . I represent one of the 4 Plaintiffs in a lawsuit filed against Mr. Epstein. And 5 I'm here today to ask you a bunch of questions. 6 As you saw at the beginning, you're under 7 oath. It's just like you're on the stand at trial, 8 except there's no Judge here in the room with us. So 9 when I ask you questions, just give it a breath for a 10 minute because there may be objections for other lawyers 11 in the room. 12 Since there's not a Judge here, nobody's going 13 to rule on those objections, so the lawyer has to put 14 that objection on the record. Just pause for a minute 15 and then if you understand the question, go ahead and 16 answer. 17 The only exception to that rule is, if your 18 two lawyers look at you and say, don't answer that 19 question. At that point I don't want you to say a word. 20 And then they lodge an objection and advise you not to 21 say anything. Okay? 22 A. Okay. 23 Q. If you do answer a question, there's two 24 things I'm going to assume. I'm going to assume that 25 you understood the question being asked and that you're (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663.4dad-94e7-90flb7174075 3501.182-102 Page 7 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094353 EFTA01248013 Page 8 1 answering truthfully. Fair enough? 2 A. Yes. 3 Q. If you don't understand any of my questions, 4 please let me know and I'll be happy to rephrase it 5 until you can understand it. 6 It's a nerve-racking procedure and I know 7 you're nervous. It's delving into very touchy areas, so 8 it's going to be delicate. I'm going to try and handle 9 it as respectfully and delicately as possible, but I am 10 going to have to ask a whole bunch of difficult 11 questions. Okay? Fair enough? 12 A. Understand. 13 Q. Okay. If you would, could you give us your 14 full name, please? 15 A. 16 Q. Where do you currently live? 17 A. • • (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Pagc 8 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094354 EFTA01248014 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electron Gaily signed by Sandra Townsend (401.377-676.2895) Elecironicaily signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 9 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094355 EFTA01248015 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 10 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094356 EFTA01248016 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 11 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094357 EFTA01248017 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 12 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094358 EFTA01248018 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 13 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094359 EFTA01248019 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 14 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094360 EFTA01248020 (5611 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 15 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094361 EFTA01248021 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-Ne7-90ftb7174075 3501.182-102 Page 16 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094362 EFTA01248022 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 17 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094363 EFTA01248023 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1,88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 18 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094364 EFTA01248024 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 19 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094365 EFTA01248025 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90ftb7174075 3501.182-102 Page 20 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094366 EFTA01248026 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 21 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094367 EFTA01248027 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 22 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094368 EFTA01248028 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1(88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 23 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094369 EFTA01248029 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1038f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 24 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094370 EFTA01248030 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 25 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094371 EFTA01248031 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 26 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrAJON4372 EFTA01248032 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 27 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094373 EFTA01248033 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1,88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 28 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094374 EFTA01248034 ■ ■ 12 BY MR. 13 Q. When is the first time that you ever had any 14 contact with Jeffrey Epstein? 15 A. When? 16 Q. Yes. In other words, what grade were you in 17 or how old were you? However you can peg the time in 18 your mind. 19 A. About 16. 20 Q. So would you have been in about tenth grade at 21 that point? 22 A. Tenth going into my junior year, like, towards 23 the end, beginning of 11th. 24 Q. And how was it that you came to know who 25 Jeffrey Epstein was? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 29 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_ONN4375 EFTA01248035 Page 1 A. I was approached by a: 3 Q. At that point had you just turned 17? 4 A. No. 5 Q. You were still 16 at that point? 6 A. Yes. 7 Q. And III, is ill.? 8 A. I don't know. 9 Q. Okay. How did you know 10 all? 11 A. We went to middle school together, but we were 12 not friends. 15 Q. Do you know where she is today? 16 A. No. 17 Q. What were you doing at 19 A. I don't know. 20 Q. Well, is it a members only type of place? 21 A. No. 22 Q. Do you just -- 23 MR. : Wait until he finishes his 24 question. 25 BY MR. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 30 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094376 EFTA01248036 Page Q. How do you get in there? 2 A. You walk in. Q. Is there a charge to get into S A. Not the day I met no. 6 Q. Had you been there before? 7 A. Yes. 8 Q. How many times had you been there before? 9 A. I can't recall. 10 Q. Was it a place that you went to regularly at 11 that point in your life? 12 A. Yes. 13 Q. Why would you go there? 14 A. To go swimming, listen to music. 15 Q. Okay. Can you describe to me? I mean, are we talking about a club? Are 17 we talking about a -- somewhere just on the beach 18 somewhere? Are we talking about a bar? What is this 19 place? 20 A. is a tiki bar on the beach 21 or was at that point on the beach 22 had a bar. It had a restaurant. It had a pool. It was 23 a hotel room. I mean, they had hotel rooms available. 24 They had on Sundays live music. 25 Q. Okay. When you would go there in the past, (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 31 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094377 EFTA01248037 Page 1 would you go with friends? 2 A. Yes. 3 Q. Who? 4 A. 5 Q. Anyone else you can think of? 6 A. Not that I can think of. 7 Q. Would you go with or would you go with 8 9 A. Not . I did go with and at. 10 one point. 11 Q. Okay. When you would go to the beach 12 resort -- and I'm talking about the day before 13 III approaches you now. 14 A. Uh-huh. 15 Q. In the past when you would go there, is it a 16 place you would go just yourself and with friends of 17 would your parents take you there? 18 A. Usually a place that I would go with my 19 friends. 20 Q. Had your parents ever been there before that 21 day that you talked to 22 A. Yes. 23 Q. So they were familiar of the location and had 24 been there before? 25 A. Uh-huh, yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) V8W113-56634dad4404WW17.WM 3501.182-102 Page 32of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O54378 EFTA01248038 Page 33 1 Q. And they would also let you go to this place 2 alone? 3 A. With friends. 4 Q. How would you get there? 5 A. Drive. 6 Q. You? 7 A. Yes. 8 Q. So you would have -- you had a driver's 9 license at 16? 10 A. Yes. 11 Q. Just going back to what we had asked at the 12 beginning. 13 Did you have your own car? 14 A. Yes. 15 Q. What kind of car were you driving back then? 16 Was it the same pickup truck that you had later? 17 A. I don't remember. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 33 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094379 EFTA01248039 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 34 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094380 EFTA01248040 ml ■ ■ ■ ■ 15 Q. Okay. Once again, this is the period of time 16 before the day that approaches you about 17 Jeffrey Epstein. I just want to focus on that period of 18 time for right now. 19 When you would go to this 20 what was the main purpose of you going there; in other 21 words, why were you going? 22 A. To have fun. 23 Q. Go hang out on the beach, get a tan, hang out. 24 with friends? 25 A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f1134663-4dad-94e7-90ftb7174075 3501.182-102 Page 35 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094381 EFTA01248041 Page • (2• Would you ever drink there at the 2 3 MS. : Objection. I've already 4 instructed her not to answer this question. You're 5 just using this example as a back doorway into the 6 same question. We're still prior to her meeting 7 If you have a specific question 8 with regard to that day, please go ahead; 9 otherwise, it's the same objection. 10 MR. : Okay. 11 BY MR. 12 Q. When you would go to the 13 don't answer this because she's