gov.uscourts.nysd.447706.1328.16.pdf

Case 1:15-cv-07433-LAP Document 1328-16 Filed 01/05/24 Page 1 of 8 EXHIBIT 15 (Filed Under Seal) Case 1:15-cv-07433-LAP Document 1328-16 Filed 01/05/24 Page 2 of 8 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO . 08-CV-80893-CIV-MARRA/JOHNSON JANE DOE, Plaintiff , vs . JEFFREY EPSTEIN , et al ., Defendants . ______________________ / Related Cases : 08-80119, 08-80232 , 08-80380 , 08-80381 , 08 -80994 , 08-80811 , 08-80893 , 09-80469 , 09-8-59 1 , 09-80656 , 09-80802 , 09-81092 VIDEOTAPED DEPOSITION OF NADIA MARCINKOVA TAKEN ON BEHALF OF THE PLAINTIFF DATE : April 13 , 2010 U.S. Legal Support (561) 835-0220 GJUFFRE00l 164 Case 1:15-cv-07433-LAP Document 1328-16 Filed 01/05/24 Page 3 of 8 26 28 l to his house to sexunlly molest; is thnt right? l minor females? 2 MR. VAREM/\ : Object to the form . 2 MR. VAR EMA: Object 10 the form. 3 A Fift h. 3 A Fifth . 4 Q The lirst time site went to Jeffrey 4 Q You have received ornl sex from underage 5 Epstein's house wns in 2002 when she was only 14 5 minor l"cmalcs'! 6 years old; is that true? 6 MR. VAREMA : Object to thefonn. 7 MR. VA REMA : Objectto the fo rm . 7 A Finh. 8 I\ Fifth. 8 Q All of these sexual acts with minor 9 Q In fact in 2002 you were only 18 years 9 females involving yon happened in the presence of 10 old or so yourself; is that right? 10 Jeffrey Epstein? 11 A Fifth. 11 MR. VAREMA: Obj ect to the fo1111. 12 Q And E.W. is somebody you observed nt 12 A Fifth. 13 Jeffrey Epstein's house on more than 100 13 Q During your lnternction with nndernge 14 occasions between 2002 and 2005, n time period 14 minor females in a sexual manner, isn't it true 15 between 14 nncl 17 years of age for her; is thnt 15 that Jeffrey Epstein would pnrtici1>ate in the 16 right? 16 sexual acts and the net would he over upon 17 MR. YAR EMA: Object toth c fon n. 17 .Jeffrey Epstein ejaculating, correct? 18 A Fifth. 18 MR. V/\ RE MA: Object to the fonn. 19 Q And each time E.W. wns summoned to 19 A Fi ft h. 20 Jeffrey Epstein's house, it was for the 1>urposcs 20 Q Did Jeffrey Epstein tell you, thnt when 21 of Jeffrey Epstein sexunlly molesting her, 21 E.W. wns 1111 underage minor female, he forced her 22 correct? 22 to give him oral sex? 23 MR. VAREMA : Object to the form. 23 MR. VAREMA: Object to thc fonn. 24 A Fifth . 24 A Fifth. 25 Q If it was not Jeffrey Epstein personally 25 Q Do you remember E.\.V, coming over, n 27 29 1 cnlling E.W., you observed Snrnh Kellen to cnll 1 youn g girl, with braces on, and going up into 2 E.W. for the purposes of her coming over and 2 Jeffrey Epstein's bedroom on numerous occasions 3 pleasing Jeffrey Epstein sexually, correct? 3 to be sexually molested? 4 MR. VAREMA : Objec t to the fo rm. 4 MR. VAREM A: Object to the fo nn. 5 A Fitlh. 5 A Fillh . 6 Q And do you remember the instance where 6 Q Do you know when it was thnt Jeffrey 7 Jeffrey Epstein instructed you to lay down naked 7 Epstein developed his plan or scheme to gain 8 nnd engage in a threesome with E.W. nnd Jeffrey 8 access to hundreds of underage minor females for 9 Epstein? 9 the JHrrposes of his sexual grntilicntion? 10 MR. VAREMA: Object to th e fo 1111. 10 MR. VA REM A: Obj ect to the fo m1. 11 A Fifth. 11 A Fifth . 12 Q Do you remember that that ch1ring that 12 Q Were you n part of the planning of that 13 threesome, Jeffrey Epstein demanded E.W. to 13 scheme of J effrey Epstein's to gnin access to 14 strnddle you nnd otherwise engage sexually with 14 underage minor females? 15 you while .Jeffrey Epstein was using vibrators 15 MR. VA REMA: Object to the form. 16 and/or dildos on you? 16 A Fifth. 17 MR. VAREMA : Object to the form . 17 Q Do you know Ghislain e Maxwell? 18 A Fifth. 18 A Fifth. 19 Q In addition to your sexual interactions 19 Q Is that somebody who helped Jeffrey 20 with E.W., isn't it true that you have used 20 Epstein to devise the scheme to allow him access 21 strn1>-on dildos nnd vibrntors on other undernge 21 to various and a vnricty of underage minor 22 minors at Jeffrey Epstein's direction? 22 females? 23 MR. YAREMA : Objec t lo the fo1111. 23 MR. V/\REMA: Obj ect to the form. 24 A Fifth. 24 A Fift h. 25 Q You have given ornl sex to undcrnge 25 Q Is Snrnh Kellen somebody thnt was also 8 ( Pages 26 to 29 ) U.S. Legal Support (561) 835-0220 GJUFFRE00 1171 Case 1:15-cv-07433-LAP Document 1328-16 Filed 01/05/24 Page 4 of 8 30 32 1 involved in the plnnnlng or this scheme to gnin 1 sex toys on you, correct? 2 nccess to underage minor fcmnlcs? 2 A Fifth. 3 MR. YAR EMA: Object to the form . 3 Q And he ha s instructed you to use sex 4 A Fif th. 4 toys and vibrators on other undernge minor 5 Q When is the first time thnt you observed 5 fema les, correct? 6 Jeffrey Epstein's method of enticing or inducing 6 MR. YAREMA: Object to the form . 7 undcrngc minor rcmnlcs into scxunl nets with him 7 A Fifth. 8 inside his bedroom? 8 Q You have observed Jeffrey Epstei n 9 MR. YA REM A: Object to the fonn. 9 digitnlly penetrate the vagiun of underage minor 10 A Fifth. 10 remnles, in clu din g E.W., correct? 11 Q Isn't it true that nrtcr nn underage 11 MR. Y AR.EMA: Object to the form . 12 minor fcmnle was brought to Jeffrey Epstein's 12 A Fifth. 13 house, typically Snrah Kellen, or Adrinnn or 13 Q As part or his plnn to avoid detection 14 yourself would lead that underage minor female to 1 4 by lnw enforcement, you hnve observed Jeffrey 15 Jeffrey Epstei n's bedroom nnd lenve them alone in 15 Epstein to pny these underage minor females to be 16 the room; is that trne? 16 quiet, correct? 17 MR. YAREMA: Object to the form . 17 MR. YA REM A: Object to the form. 18 A Fifth. 18 A Fi fth . 19 Q Then Jeffrey Epstein would appcnr either 19 Q And this is somethin g that he has told 20 naked or wearing a towel; is that true? 20 you he docs, for the purposes of grooming these 21 MR. VAR.EMA: Object to the fonn . 21 underage minor females, nnd avoiding law 22 A Fifth. 22 enforcement detection, correct? 23 Q This is his habit or method of 23 MR. YAREMA: Object to the fonn . 24 01>crntio11, every single time, nnd that's 24 A . Fifth. 25 something thnt he hns told you about his sexual 25 Q Jeffrey Epstein has talked to you nbout 31 33 l internction with underngc minors; is that true? l the psychology of brainwnshing or grooming 2 MR. YA REM A: Object to the fonn . 2 underage minor remnles to perform for him 3 A Fifth. 3 sexually, hnsn't he'? 4 Q And he would direct or demnncl or 4 MR. YAREMA: Object to the fo rm. 5 instruct the undernge minor remnle to remove her 5 A Fifth . 6 clothing; is thnt true? 6 Q And Snrnh Kellen has also spoken with 7 MR. YAR.EMA: Object to the form . 7 you about the methodology behind gnining ncccss 8 A Fif th . 8 to and grooming underage minor females for sex? 9 Q Then he would perform one or more lewd 9 MR. YAREMA: Object to form . 10 or lascivious 01· sexunl nets on the underage 10 A Fifth. 11 minor femnlc. Is thnt true? 11 Q Isn't it true that Chislnine Maxwell nncl 12 MR. VAR.EMA : Object to the fo rm. 12 yourself nnd Sn rah Kellen hnd access to a muster 13 A Fifth. 13 list of underage minor femnles names and phone 14 Q And you have observed Jeffrey E11stein 14 numbers so that they could be culled? 15 engage in sexua l interaction with underage minor 15 MR. GOLDBERGER: Timeout. Are you 16 fema les on hundreds nnd hundreds of occasions, 16 ta lkin g lo me, counsel? 17 correct? l7 MR. HOROWITZ: Nodding my hc.1d, back at 18 MR. YAREMA: Object lo the form . 18 you. You were nodding at me. 19 A Fifth. 19 MR. GOLDBERG ER : I wasn't nodding al 20 Q And you have observed ,Jeffrey Epstein 20 you. I'm not talking to you, I'm not 21 using vibrntors nnd sexual toys on underage 21 communicating with you .. I don't know what 22 minors, true? 22 you th ink we are doing here. You said "It 23 MR. YAREMA: Object to thcfonn. 23 is true," and I hove no idea what you are 24 A Fifth . 24 talking nbout. Don't interrupt the 25 Q In fact, he has also used vibrators and 25 depos ition, okay? 9 (Pages 30 t o 33: U.S. Legal Support (561) 835-0220 GJUFFRE00 1172 Case 1:15-cv-07433-LAP Document 1328-16 Filed 01/05/24 Page 5 of 8 34 36 1 MR. HOROWI TZ: I th ink you interrupted. 1 A Fifth. 2 MR. GOLDBERGER: I didn 't do a thing-- 2 Q In addition to that system, isn't it 3 MR. EDWARDS : I don't know what's 3 true that Jeffrey Epstein trnffics underage minor 4 lrnppencd here. It hns deteriorated here for 4 females through a modeling agency? 5 no reaso n wh atsoever and has nothin g to do 5 MR. YA REMA: Objec t lo the fonn. 6 with me or the witness. 6 A Fifth. 7 MR. GOLDBERGER: You're 100 percent 7 Q Is n modeling agency that he is involved 8 correct. 8 in with Jenn Luc llrunel; you know who that is 9 MR. EDWARDS: Can we go back to it. 9 right? 10 MR. GOLDB ERGER: Absolutely. 10 MR. YA R.EM A: Object to the form. 11 MR. EDW ARDS: Perfect. 11 A Fifth . 12 The s il ent tight disrupted me. I lost 12 Q Arc you familiar with MC-2 or MC-Squared 13 where I am now. 13 Modeling Agency? 14 MR. GOLDB ERGER: Sorry. 14 A Fifth . 15 MR. EDWARDS: Can you read it back. 15 Q You know Jean Luc Brunel, right? 16 THE COURT REPORTER: Certai nly. 16 MR. YAREMA: Object to the fonn . 17 (The record was read.) 17 A Fifth . 18 MR. EDWARDS: I'll rephrase the 18 Q Is ,Jean Luc Brunel somebody that you 19 question. 19 have been made to perform on sexually? 20 Q Isn't it true that yourse lf, Ghislaine 20 MR. YAREMA: Objccltothefonn. 21 Mnxwell and Sarah Kellen had access lo a master 21 A Fifth. 22 of list of underage minor l'emnles nnmes and phone 22 Q .Jenn Luc Brunel is somebod y that you 23 numbers so they could be cnllecl for the purpose 23 know to also he a child molester, true? 24 of coming to Jeffrey Epstein's house to be 24 MR. YAREMA: Object to the fonn. 25 sexually molested? 25 A Fifth. 35 37 1 MR. YAREMA: Object to the form. 1 Q This is somebody who for yen rs the 2 A Fifth. 2 public has known of .Jenn Luc Brunel as a child 3 Q How man)' undcrnge minor females a re on 3 molester, true? 4 Iha t master list? 4 MR. YA REMA: Object to the fonn. 5 MR. YAREMA: Object to the form. 5 A Fifth. 6 A Fifth. 6 Q In fnct, that is the only thing Jeffrey 7 Q Are there photographs of these underage 7 Epstein and Jean Luc Brunel have in common, is 8 minor females on thnt master list? 8 their obsession for underage minor females, 9 MR. YAREMA: Object to the fo1111. 9 correct? 10 A Fifth. 10 MR. YAREMA: Object to the form . 11 Q Is that muster list saved on a computer 11 A Fifth. 12 system, ns has been testilicd to in the past'! 12 Q And the modeling agency is but one other 13 MR. YAREMA: Object to the fo nn. 13 mechanism used by Jeffrey Epstein to gain access 1/J A Fifth. 14 to underage minor females for sex, true? 15 Q Has Jeffrey Epstein talked to you :ibout 15 MR. YAREMA: Object to the form . 16 the success of his scheme to procure undernge 16 A Fifth. 17 minor females? 17 Q I rend you the statute earlier on Lewd 18 MR. YAREMA: Object to thcfonn. 18 and Lascivious Molestation, Chapter 800.04, nnd 19 A Fifth. 19 that's something that you have witnessed Jeffrey 20 Q By thnl, I mean , the method where he 20 Epstein violate on hundreds of occasions, 21 molests an undernge minor female, then offers 21 correct'! 22 them additional money if they will bring him 22 MR. YAREMA: Object to the form. 23 other undernge minor females to molest; are you 23 A Fifth. 24 fomilinr with that system'? 24 Q And somethin g that you ha ve witnessed 25 MR. YAREMA: Object to the form. 25 Jeffrey E1>stein speciflcn ll y violate, against 10 (Pages 34 to 37) U.S. Legal Support (561) 835-0220 GJUFFRE00 1173 Case 1:15-cv-07433-LAP Document 1328-16 Filed 01/05/24 Page 6 of 8 46 48 1 A Fifih. 1 Ghislaine Maxwell's sexual interaction with .Jane 2 Q Thnt pnrticular messnge indicates it is 2 Doc-102 when she wns n minor? 3 from Nadia. You're the only "Nadia" in the 3 MR. VA R.EMA: Object to the fonn . 4 honse; is that correct? 4 Q This is one or many undernge minor 5 MR. VAREMA : Object to th e fonn. 5 females thnt was trafficked basically a1·011n1l the 6 A Fi fth . 6 globe to be sexually exploited and abused; is 7 Q This ls n cnll from you inclicnting that 7 that correct? 8 Jane Doe 2nnnot work todny nnd -Jane Doe 2 will be 8 MR. YA REMA: Object 10 the form . 9 here nt 4:00 p.m.;" is thnt right? 9 A Fifth. 10 MR. VAR.EMA: Object to the fo rm ? 10 Q Was that typical of Jeffrey Epstein nnd 11 A Fifth. 11 Ghislaine Mnx,well to sexually abuse minors on 12 Q Who is -Jane Doe 2 ? 12 Jeffrey Epstein's airplane? 13 A Fifth. 13 MR. YA REM A: Object to the fo nn. 14 MR. VAR.EMA: Object to the form . 14 A Fifth. 15 Q That's an underage minor female tJ1at was 15 Q And nlso typical or Ghislaine Maxwell 16 scheduled to be molested nt Jeffrey Epstein's 16 and Jeffrey Epstein to prostitute or pimp out 17 house'? 17 underage minors to friends? 18 MR. VAR.EMA: Object to the fo nn. 18 MR. YAREMA: Object to th e form. 19 A Fifth . 19 A Fifth. 20 Q You scheduled thnt act of molestation; 20 Q By "friends," I am talking specifically 21 is that right? 21 about people of royalty, politicians, 22 MR. VAR.EMA: Object to the form . 22 academicians, businessmen and other professional 23 A Fi fth . 23 or personal acquaintances? 24 Q And -Jane Doe 2 will bent the house nt 4:00 24 MR. YA REMA: Object to the form . 25 p.m. -Jane Doe 2 is another underage minor female; 25 A Fifth. 47 49 1 is that correct? 1 Q Were you with Jeffrey Epstein on his 2 MR. VAREMA: Object to the form. 2 birthday when one of his friends sent to him 3 A Fi fth. 3 12 -- sorry, three 12-year olds for the purposes 4 Q That's somebody else that you were 4 of Jeffrey Epstein sexually abusing them? 5 schedu ling to come to his house at 4:00 p.m. for 5 MR. VAREMA: Object to the fonn . 6 ,Jeffrey Epstein to engage in sexual nets with 6 A Fifth . 7 her, while she was an underage m inor, true? 7 Q How many occasions have you observed 8 MR. Y AREMA: Object to the form . 8 Jeffrey Epstein to receive ns gifts from friends, 9 A Fifth. 9 underage minor fema les for tJ1e purposes of him 10 Q Do you know Les \Vexuer? 10 sexually nbusing them? 11 A Fifth. 11 MR. VAR.EMA: Object to the fonn . 12 Q That's somebody that you know owns and 12 A Fifth. 13 operates the Victoria's Secret, the Limited? 13 Q These three 12-year olds were from 14 MR. YAREMA: Object to the form . 14 li'rnnce. Were they sent to him on his birthday by 15 A Is that a quest ion? 15 Jean Luc Brunel or by somebody else? 16 Q Is that somebody that you know to own 16 MR. YAREMA : Object tofonn. 17 Victoria's Secret or operate Victoria's Secret'? 17 A Fifth. 18 A Fifth. 18 Q 1-luve you ever been made to engage in sex 19 Q Do you know if Jeffrey Epstein slill 19 with 12-ycar olds? 20 tall<s with Leslie Wexner? 20 MR. YAREMA: Object to the fo1111. 21 MR. YAR EMA: Object to the form . 21 A Firth. 22 A Fifth. 22 Q Is it trnc that Jeffrey Epstein makes 23 Q Do you know Jane Doe-102? 23 you dress up ns a 12-year old? 24 A Fifth. 24 MR. VA REMA: Object to the form. 25 Q Are you aware of Jeffrey Epstein and 25 A Fifth. 13 ( Pages 46 to 49 : U .S. Legal Support (561) 835- 0220 GJU FFRE00 1176 Case 1:15-cv-07433-LAP Document 1328-16 Filed 01/05/24 Page 7 of 8 58 60 1 Alnn Dershowitz, menning he continued to sexu a lly 1 Q Whnt wns the purpose of that night'! 2 abuse minors despite Alnn Dershowitz being a 2 MR. YAREMA: Object to the fo rm. 3 g uest in the house? 3 A Fitlh. 4 MR. YAREMA: Object to the fonn . 4 Q Did you sign a conlidcntinlity agreement 5 A Fifth. 5 with Jeffrey Epstein? 6 Q Alan Dershowitz never cngnged in any 6 MR. YAR EMA: Object 10 the form. 7 sexual activ ity with these underage minors; isn't 7 A Fifth. 8 that true? 8 Q When is the last time that you observed 9 MR. YAREMA: Object to the form. 9 Jeffrey Epstein have sex with a minor? 10 A Fifth. 10 MR. YAR EMA: Object to the fo rm . 11 Q Have you been made to have sex with 11 A Fifth. 12 Ghislaine Maxwell? 12 Q Since being on probation, has Jeffrey 13 MR. YAREMA: Objec t to the form. 13 IJ:pstcin been able to, or has he flown to his 14 A Fi fth. 14 island '! 15 Q Do you know Jane Doe 2 ? 15 MR. YAREMA: Object lo the form. 16 A Filth. 16 A Fil\h. 17 Q Similar to you being .Jeffrey Epstein's 17 Q To your knowledge, has Jeffrey IJ:pstein 18 sex sin vc, is Jane Doe 2 , or was Jane Doe 2 18 flown to New York while on probation or community 19 Ghislain e Mnxwell's sex slnve? 19 control? 20 MR. YA REMA: Object lo the fo1111. 20 MR. YAREMA : Object to the fon n. 21 A Fifth. 21 A Fifth. 22 Q Ghislnine Maxwell is somebody who you 22 Q Isn't it true that he has flown both to 23 know to be bi-sexunl, true? 23 New York :tnd to his island, and you have 24 MR. YAREMA: Object to the fo rm . 24 accompnnied him on those trips, since he was on 25 A Fifth . 25 community contro l? 59 61 l Q You lmow that Ghislnine Ma.xwell engnged 1 MR. YAREMA: Object to the form. 2 in sex ual acts with underage minor females, tru e? 2 A Fifth. 3 MR. YAREMA : Object to the form. 3 Q Isn't it also true that Jeffrey Epstein 4 A Fifth. 4 has indicated to you that he will always engage 5 Q This is yet another friend of Jeffrey 5 in sex acts with underage minor females? 6 Epstein's that is into the act of molesting 6 MR. VAR.EMA: Object to the fonn . 7 underage minor females, right? 7 A Fifth. 8 MR. Y AREM A: Object to the fonn . 8 Q ht fact, that's something that he hns 9 A Fifth. 9 told you, tha t he believes he is entitled to do; 10 Q Now, you are the next participnnt in 10 isn't that right? 11 that activity, meaning you have been groomed to 11 MR. YAREMA: Object to the form . 12 enjoy nnd appreciate the acts of sex with 12 A Fifth. 13 underage minors, true'! 13 Q Isn't it true that Jeffrey Epstein 14 MR. YAREMA: Object to the fonn . 14 believes 1111<1 has told yo u that if he doesn't 15 A Fifth. 15 physically force the undernge minor female into 16 Q Has Jeffrey Epstein instructed you to 16 any act, then he is entitled to engage in sex 17 lie to his Probation Officer in nny wny? 17 with nny underage minor fenrnle despite the nge? 18 MR. YAREMA: Object to the fonn. 18 MR. YAREMA: Object to the fo 1111. 19 A Fifth. 19 A Fifth. 20 Q Mr. Visoskl testified thnt you took a 20 Q What is the youngest fcmn le you have 21 helicopter night within the Inst year with 21 witnessed or observed Jeffrey Epstein to engage 22 Jeffrey Epstein to Miami. Do you remember thnt 22 in sex with ? 23 llight? 23 MR. YAREMA : Object to the form. 24 MR. YAREMA: Object to the fonn. 24 A Fifth. 25 A Fifth. 25 Q Do you luwe II bnnk account at Chase Bnnk 16 (Pages 58 to 61 : U.S. Legal Support (561) 835-0220 GIUFFRE00 1179 Case 1:15-cv-07433-LAP Document 1328-16 Filed 01/05/24 Page 8 of 8 98 100 1 A Fifth. l THE STATE OF FLORIDA) 2 Q Did you know that J effrey Epstein gave 2 COUNTY OF PALM BEACH) 3 3 I, TERRI BECKER, a Registered A.O. a d igital ca mern? 4 Professional Reporter and Notary Public for the 4 MR. YAREMA: Object to the form. 5 State or Florida at Large, do hereby certiry that 5 A Fifth. 6 I reported the videotaped deposition ol'NADIA 6 MS. EZELL: I don't have any other 7 MARCINKOVA, the WITNESS, ca lled by the PLAINTIFF 7 questions. Thank you. 8 in the abo,•e-entitled action; that the witness 8 MR. GOLDBERGER: You still have your 9 was duly sworn by me; that the foregoing pages, 9 microphone on. You must have something on 10 numbered from I 10 I 04, inclusi ve, constitute a 10 your mind, Brad. 11 true record of the deposition by sa id witness. 11 12 I further certify that I am not allorney REDIRECT EXAMINATION 13 or counsel or any of the parties, nor a relative 12 BY MR. EDWARDS: 14 or employee o f any allorncy or counsel connec ted 13 Q Ms. Marci ukovn, through the whole dny 15 with the action, nor financially interested in 14 yo u've ta ken the Firth 0 11 just a bout every si ngle 16 the action. 15 question. Is there nuy reaso n why we shou ld not 17 WITNESS MY HAND and ollicial sea l in the 16 presume that the a nswer to these questions wo uld 18 City of West Palm Beach, County ol'Palm Beach, 17 incrimi nate you? 19 18 19 MR. YAREMA: Object to the form. A The Fifth . 20 21 '""~~)~~.s~g, TERRI BECKER, Registered ,;,. ,~ 20 Q T he r eason that you have taken the Fifth Pro lessiona I Repm1cr and 21 is because t he q uest ions yo u have been asked 22 Notmy Public, State of Florida 22 wou ld have been nnswered in the affirmat ive and at Large. My Commission expires 23 you ' re a fraid of prosec utio n for yo ur 23 March 13, 2011. 24 invo lvement, tru e? 24 25 MR. GOLDBERGER: Don't answer that 25 99 101 1 question. It interferes with the 1 THE ST ATE OF FLOIUDA) 2 attomey/client relationsh ip that I have 2 COUNTY OF PALM BEACH) 3 with Ms. Marcinkova and any discussions she 3 4 and I may have had would come under that 4 5 privilege. 5 The foregoing certificate was 6 acknow ledged before me this _ _ __ _ __ 6 You can try and dance around that, but 7 day of_ __ __ __ 2010. 7 I'm simply 1101 going to allow her to answer 8 8 that question. If you want 10 b1ing it up 9 9 with the Judge, you can. 10 10 MR. EDWARDS: Thanks, Jack. 11 11 MR. GOLDBERGER: Okay. 12 12 THE V IDEOGRAPHER: Off the video record 13 13 al I :41 p.111. 14 14 THE COURT REPORTER : You're ordering Notary Public, State ofFlorida. 15 this, Brad? 15 My commission No . 16 MR. EDWARDS: Yes. Copies? Expires March 13, 201 I. 17 MS. EZELL: Yes. 16 18 MR. YAREMA : Yes: 17 19 THE COURT REPORTER : And Adam wanted it; 18 19 20 is that right? 20 21 MR. EDWARDS: Yes. tz1 22 (Time noted: I :45 p.m .) 22 23 23 2,1 tz4 25 tz5 26 (Pages 98 to 101 U.S. Legal Support (561) 835-0220 GJUFFREOO 1189