gov.uscourts.nysd.447706.1328.44.pdf

Case 1:15-cv-07433-LAP Document 1328-44 Filed 01/05/24 Page 1 of 14 .D$"8-&:
%&$-"3"5*0/ $0.104*5& EXHIBIT 9 (Filed Under Seal) Case 1:15-cv-07433-LAP Document 1328-44 Filed 01/05/24 Page 2 of 14 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 . - - - - - - - - - - - - - - - - - - -- -- I Related Cases : 08 - 80119 , 08-80232 , 08-80380, 08-80381, 08-80994 , 08 - 80811 , 08-80893 , 09 - 80469 , 09-8-591 , 09 - 80656 , 09 - 80802 , 09-81092 VIDEOTAPED DEPOSITION OF NADIA MARCINKOVA TAKEN ON BEHALF OF THE PLAINTIFF DATE : April 13, 2010 U.S. Legal Support (561) 835-0220 Case 1:15-cv-07433-LAP Document 1328-44 Filed 01/05/24 Page 3 of 14 54 56 l A Fiftb . 1 Jeffrey Epstein s11ecifically flew to Palm Beach 2 Q Do you know Bill Clinton? 2 for the purposes of engaging in sex net with 3 A Fifth. 3 Jane Doc'! 1) Q You have been on Jeffrey Epstein's 4 MR. YA RE MA : Object to the fom1 . 5 airplane with Bill Clinton? 5 A Fifth. 6 MR. VAREMA: Objecl lo the fo rm. 6 Q Ge11ernlly, isn't it true .Jeffrey Epstein 7 A Fifth . 7 would rly from place to 11lacc for the purpose of 8 Q Isn't take true you have IJeen on Jeffrey 8 engaging i11 sexual activity with minors at his 9 Epstein's airplane with Dong Band, nm Clinton's 9 destination? 10 righthnnd man'! 10 M R. VAREMA: Object lo the fo rm. 11 MR. VAR EMA: Objccl to U1c fo rm. 11 A Fifth. 12 A Fifth. 12 Q Isn't it tru e Uiat he employed numerous 13 Q f-lnve you witnessed im()roper sexunt 13 1>eople l"or the sole purpose of scheduling 14 activity between Jeffrey Epstein nncl minors 14 nppointments with undernge miuor females nt ench 15 while he was in tJ1e presence of BIii Clinton? 15 des tination he lauded? 16 M R. Y AREMA : Objecl lo the fo rm. 16 MR. VAR.EMA: Object to th e form. 17 A Fifth. 17 A Fi fth. 18 Q How ma ny times have you l"idden on the 18 Q Whnt is Jeffrey E pstein's rclalionship 19 nirplane with Jean Luc Brunel'! 19 with Sandy Berger? 20 MR. YAREMA: Object to the fonn. 20 MR. YAREMA: Obj ect to th e fonn . 21 A Fifth . 21 A Fifth. 22 Q Each time that Jenn Luc Brunel visits 22 Q Do you know what Jeffrey Epstein's 23 Jeffrey Epstein's hou se, does he bring und erage 23 relationship is with Alnn Dershowitz? 24 minors to Jeffrey Epstein's house to engage in 24 M R. VA REMA: Object to the fonn . 25 sex with? 25 A Finh. 55 57 1 MR. VAR.EMA : Objec t to the fo 1111. l Q Thnt's somelJody who you know to have 2 A Fifth . 2 stayed at Jeffrey Epstein's house on many 3 Q Do you know Glenn Dubin? 3 occasions, correct'? 4 A Fifth. 4 MR. YA REMA: Obj ect to the form. 5 Q Do you know Aline Weber'? 5 A Fifth. 6 A Fifth. 6 Q And also somebody who you know to have 7 Q Is that somebocly thnt was n sexual abuse 7 been at the house when E.W. was in Jeffrey 8 victim at one point in time or Jeffrey Epstein 8 Epstein's bedroom getting sexually nlJused, 9 and Jean Luc Brunel? 9 correct? 10 M R.. VAR.EM A: Object to Lhe fo nn . 10 MR. YAR.EMA: Object to the form. 11 A Fifth . 11 A Fi ft h. 12 Q Between 2002 and 2005 when E.W. was 12 Q Alnn Dershowitz is also somebody that 13 abused by J effre y Epstein sexu:tlly, isn't it tru e 13 you also know to have been at the hou se wh en L.M. 14 that Jeffrey Epstein took flights to Palm Beach 14 was being sexually abused in Jeffrey Epstein's 15 for the purposes of sexually abusing E.W.? 15 bedroom, correct'? 16 MR. VAR.E MA : Objecl to the fo rm. 16 MR. VAR.EMA : Object to th e form . 17 A Fifth. 17 A Fifth. 18 Q And between those same years of 2002 and 18 Q Generally, Alan Dershowitz is familiar 19 ioos, isn't it true thal Jeffrey E1,stei11 took 19 with Jeffrey Epstein's habit of engaging in 20 airplnne nights to Pnlm Bench from places 20 sexual acts with minors on a <laily basis, 21 outside ol" the State, to engage in sexual acts 21 correct? 22 witl1 L.M .? 22 MR. YAREMA: Object to the form. 23 MR. YAR EMA: Obj ect to th e fo rm . 23 A Fitl h. 24 A Fifth. 24 Q When Alan Dershowitz was in town, 25 Q From 2003 through 2005, i n't it true 25 Jeffrey Epstein did not break his schedule l"or 15 (Pages 54 to 57 ) U.S. Legal Support (561) 835-0220 Case 1:15-cv-07433-LAP Document 1328-44 Filed 01/05/24 Page 4 of 14 58 60 1 Alan Dcrshowi t;o;, meanin g he con tinued lo sexually 1 Q What was the purpose of that ni ght'! 2 abuse minors despite Al a n Dcrsh owitz being a 2 MR. YA REMA : Object to the fo1111 . 3 guest in the house? 3 A Fi fth . 4 MR. YAR EMA : Object to th e form. 4 Q Did you sign a confidcnliality agrcc111cnl 5 A Firth. 5 with Jeffrey Epstein? 6 Q Alan Dcrshowitz never engaged in any 6 MR.. YAREMA : Objccl to the fo rm. 7 sexual :ictivity with these undernge minors; isn't 7 A Fiflh. 8 that true? B Q When is the last time that you observed 9 MR. YAR EM A: Object to the form. 9 Jeffrey Epstein have sex with a minor? 10 A Firth. 10 MR. YA REMA : Object to lhe form . 11 Q l:lave you been made to have sex with 11 A Fifth. 12 Chislninc Mi\:ovell? 12 Q Since being on probation, has .Jeffrey 13 MR. VA R.E MA : Object to the form. 13 Epstein been able to, or has he tlow11 to his 14 A Fifth. 14 island? 15 Q Do you know Emmy Taylor? 15 MR. YA RE MA: Object to the form. 16 A Fifth . 16 A Fi fih. 17 Q Similar to you being Jeffrey Epstein's 17 Q To your knowledge, has .lcfTrcy Epstein 18 sex slave, is Emmy Tnylor, or was Emmy Taylor 18 flown to New Vork while on probation or community 19 Ghislnine Maxwell's sex slave'? 19 control? 20 MR. YARE MA: Object to U1e fo 1111. 20 MR. YAREM A: Object to the fo rm. 21 A Fi fth. 21 A Fitlh. 22 Q Ghislaine Maxwell is somebody who you 22 Q Isn't it true that he has flown both to 23 know to be bi-sexual, true? 23 cw York and to his island, and you have 24 M R. YARE MA: Objec t to th e fonn . 24 accompanied him on those trips, since he was on 25 A Fifth . 25 community conl1·ol? 59 61 1 Q You know that Ghislaine Maxwell engngccl 1 MR. YARE MA; Object to the form . 2 in sexual acts with underage minor females, true? 2 A Fifth. 3 MR. YA RE MA: Object to the fonn . 3 Q Isn't il also true that Jeffrey Epstein 4 A Fiflh. 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 net of molesting 6 M R. YA REM A: Object to th e fo n n. 7 undernge minor fenrnlcs, right? 7 A Fifth . B MR. YAR EMA: Obj ect to th e fo1rn . 8 Q In fnct1 that's something that he has 9 A Fifth . 9 told you , thnt 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 and apprecin te the acts of sex with 12 A Fifth. 13 u11<lcrage minors, true'! 13 Q Isn't it true that Jeffrey Epstein 14 MR. YAREMA : Object to the fo nn . 14 believes and bas told you that if he doesn't 15 A Fift h. 15 physically force the underage minor female iuto 16 Q Mas ,l effrcy Epstein instruclccl you to 16 any act, then he is entitled lo engage in sex 17 lie to his Prnbalion Officer in any way? 17 with any underage minor female despite the age? 18 MR. Y /\ RE MA: Object to the fo1m. 18 MR. Y ARE MA: Object to th t: form . 19 A Fifth. 19 A Fifth. 20 Q Mr. Visosld testified that you took a 20 Q Whnt is the youngest female you have 21 helicopter llight wi thin the last year with 21 witnessed or observed Jeffrey Epstein to eng:ige 22 .Jeffrey E11stei11 to Miami. Oo you remember thn t 22 in sex with? 23 llight? 23 MR. YAREMA : Object to the fo rm. 24 MR. YA REMA : Object to the form . 24 A Firth . 25 A Fifth. 25 Q Do you haven bank account at Chase Bnnk 16 ( Pa ge s 58 t o 61) U.S. Legal Support (561) 835-0220  Case 1:15-cv-07433-LAP Document 1328-44 Filed 01/05/24 Page 5 of 14 Page 187 Page 189 llNlThD STATES DlSTRlCT COURT l TN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT SOUTHERN DrSTRICT OF FLORIDA IN AND FOR PALM BEACH COUNTY, rLORIDA 7. CASE NO. :;o2Q08CA0W051XXXXMB AB 3 CASE NO. 08•ClV·80 I l 9•MA1UWJOHNSON LM., JANE DOE NO. 2, P!aiat1rr: Plaintiff, 5 -vs- VOLUME II OF III VOLUME 11 OF Ill 1 JEFFREY EPSTEIN, Defundant. 6 .,, JEFFREY EPSTEIN, Defen<fuuL !I ~ Rclut1:<l ;;i.se~; 8 ~ 08-80232,08-08380,08-80381,08-80994 9 1 08-80993, 08-8081 t, 08·80893, 09-R0469 10 VIDEOTAPED DEPOSITION OF SARAH KELLEN t 09-80591, 09-80656, 09-80802, 09-81092 11 ,i Wetloi;,sday, March 24, 2010 ~ 12 10:37 • 6:51 p.m. i VIDEOTAPED DEPOSITION OF 13 14 l. [ SARAH KELLEN 15 250 Australim1 Avenue South West Pulm Beach, F!urida33401 I Wednesday, .March 24, 2010 10:37 - 6:51 p.m. 16 17 l 250 Australian Avenue South "'> ~ Suite 1500 Reported By: i West Palm Beach, Flodda 33401 Cynthia Hopkins, Ri>R, FPR } 20 Notary Public, State of Florida i Pfu$e' Court Reporting ·~ Reported By: 21 = Cynthia Hopkins, Rl'R, Fl'R 22 ! Nota.ry Public, State of florida I 23 } Pro$e Court R,,.,....>rtini;i_ l ·2 :, ~ J(lb No.: 1484-,,v i 2s i ---'------------------~--l1--------------------------t~ Page l88 Page 190 l 1 IN1'HE CIRCUIT COURT OF TIIE lSTHJUDICIAL CIRCUIT l IN Tim C!RClJIT COURT or THE FIFTEENTH JUDICIAL i IN AND FOR PALM DTIACII COUNTY, l<LORIDA CIRCUIT IN AND FOR PALM BEACH CO1JNTY. fLOR!DA l 2 CASE N 0 . .5020DliCA028058XXXXIV!B AD 2 CASE No.502008CA037319X~1H AB • i 3 E.W., 3 S.S. I j I 4 Plaintiff, 5 VOUll\4E U OF HI ; .-,. •"'"""· voLUMEII o, m -, J~H'Re.Y 8f'ST8N. ' JEFFREY El'STE!N AND SARAH KEU.EN, '! 8 3 Det~dants. 9 9 Hl DEPOS!TION OF SARAH KELLEN 0 L 1 v1OF.OTAPED DBJ:OSfTION OF 12 WcdIB:sday, March 24, 20!0 2 SARAH KELLEN 10:37 - 6:5 \ p.m. 3 13 4 Wednesday, Mardt24, 2010 14 250 Australian Avenue South 10:37 • 6:51 p.m, West Pa!m Beach, F!orida 3340 ! 15 15 16 16 17 250 Australian Avenue South 11 Suite 1500 18 Reported D_y: 18 West Palm Bca.:h, Florida 3340 I Cynthia Hopkins, RPR, fPR 19 19 Nota1,· Pub!ic, State .of Florida 20 Prnse CCJW1 RepDrliug 21 20 22 kepvrt~d By; 21 C~11thia Hopkins, RPR, FPR 22 23 Notary Public, SlUl\l ofFlurida 23 Pr,ise Court Reporting Ser;,ices 2<1 24 Joo No.: 1484 25 25 1 (Pages 187 to 190) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506  Case 1:15-cv-07433-LAP Document 1328-44 Filed 01/05/24 Page 6 of 14 Page 211 Page 213 the shape of a penis and vagina. Once again,. not 1 THE WITNESS: On the instruction ofmy 2 necessarily with respect to lv1r. Epstein's home, in 2 lawyer, Tmust invoke my Fifth Amendment right. 3 your entire 1ifo have you ever seen soap in the 3 BYMR. KUVIN: 4 shape of a penis and vagina? 4 Q. Do you agree that these corporations that 5 A. Not that I recall. 5 I just mentioned were utilized by Jeffrey Epstein in ,. 'O Q. Do you ever recall being in Ohio? 6 an attempt to have sexual relationships with 7 MR. RHETN"HART: Ever in her life? 7 underage girls? 8 lv1R. KUVIN: The state, ever in her tife. 8 MR. RHElNHART: Objection to the fonn as 9 BYMR. KUVffi: 9 to compound, and also assumes knowledge of 10 Q. Let's start there, recall being in the 10 Mr. Epstein, a.s;ks for more than one answer to 11 State of Ohio for any reason? 11 the question. I would instruct her not to 12 A. Maybe for a layover, but not that l 7.2 answer based on her Fifth Amendment privilege 13 specifically remember. 13 because the question assumes knowledge of 14 Q. Okay. Do you know an Ivan Robles? 14 Mr. Epstein. 15 A. No. 15 THE WITNESS: Upon instruction ofmy 16 Q. Have you seen a gentleman by the name of 16 lawyer I must invoke my Fifth Amendment right. 17 Alan Dershowitz at the home of Jeffrey Epstein 17 MR. KUVIN: l think r am <lone. Hang on 18 before? 18 one second. 19 MR. RHEINHART: Objection to the form. 19 All right. I appreciate it. That's all 20 Standing objection, presumes knowledge of 20 the questions l have at this time. Reserve the 21 Jeffrey Epstein or his home. lnstruc-t the 21 right to ask any follow-up questions if other 22 witness not to answer. 22 attorneys raise new and different issues by 23 THE W[TNESS: On the instruction ofmy 23 their questioning. 24 la,,.vyer, l must exercise my Fifth Amendment 24 MR. R.HEINHART: Understood. 25 right. 25 !vfR. KUVIN: Pass the witness at this time. Pa-ge 212 Page 214 l BY MR. KUVlN: 1 Who ,wmts to go? Mr. Horow1tz, do you have a 2 Q. Have you ever heard of the El Zorro Ranch 2 microphone? 3 Corporation? 3 MR. HOROWITZ: l do, MR, RHB!Nlil\RT: lnstruot the witness not 4 CROSS (SARAH KELLEN} 5 to answer based on her Fifth Amendment 5 BY MR. HOROWITZ: 6 priv:ilege. 6 Q. Ms. Kellen, did you use the telephone 7 THE WITh'"ESS: On the instruction of my 7 numbei:, the -Jane Doe 2 at any time between ·2001 8 lawyer f must exercise my Fifth Amendment 8 and2006'? 9 right. 9 A. On the advice ofmy lawyer, Tmu$t exercise my :. 0 BY MR. KUVTN: 10 Fifth Amendment right. ll Q. Have you ever heard of the New York 11 Q. Did you use the telephone number ::. 2 Strategy Group'? 12 -Jane Doe 2 between 200 I and 2006 at Jeffrey 13 MR. RHEINBART: Same instruction. 13 Epst.:in's expense? 14 'THE WITNESS: On the instruction ofmy 14 :MR. RHEJ}UfART: O~jection to the funn in 15 lawyer, I must invoke my Fifth Amendment tight. 1 :t 5 that it assumes knowledge of Jeffrey Epstein. 16 BY MR.K(.JVlN: \ 16 Standing objection a.~ previously stated with. 17 Q. Have you eve-r heard of the Ghislaine f, , l7 Mr. Kuvin. [nsltuct lhe witness not to an~wer, 18 Corporation? / 18 based on her Fifth Amendment right. 19 MR. RHEINHART: Same instruction. I 19 THE WITNESS: On the instruction of my 20 THE WITNESS: On the instruction ofmy 20I lawyer, I must e,xercise my Fifth Amendment 2.1. lawyer, I must invoke my Fifth Amendment right. ! 21 right. 22 BY MR. KlNlN: i 22 BY l'vffi. HOROWITZ: 23 Q. Have you ever heard of the Financial l ! 23 Q. Did you use the telephone number 24 Strategy Group? I 24 -Jane Doe 2 at Jeffrey Epstein's direction? 25 MR. RHEJNHART: Same instruction. j 25 MR. RHEINHART: Same objection as the 7 (Pages 211 to 214) {561) 832-7500 PROSE COURT REPORTING AG.ENCY, INC. (561) 832-7506  Case 1:15-cv-07433-LAP Document 1328-44 Filed 01/05/24 Page 7 of 14 Page 315 Page 317 1 So can we focus on the specific questions l THE WITNESS: On the instruction ofmy { t 2 that she can answer or from which you can draw 2 lawyer, I must invoke my Fifth Amendment [Jc 3 an adverse inference if asked properly, and 3 privilege. i 4 5 let's move it along. MS. EZELL: Each young woman's case is ari 4 5 BY MR. WEJSSING: Q. Do you know Alan Der.;howitz? ] j 6 individual case, and we have the right to ask, 6 MR. RHEINHART: The question was asked and ~ '? ask whatever questions that we need to with 7 answered about three-and-a-half hours ago. ,l ! 8 regard to each one. 8 THE WITNESS: On the instruction ofmy ! 9 MR+ RHETNHART: I..... 9 lav.yer, I mm,i invoke my Fifth Amendment 1G MR. GOLDBERGER: Let's just go forward 1C privilege. 11 until 5:00 and see vlhere we're at. 11 BY MR. WElSSING: 12 BY MR. Vv'ETSSING; 12 Q, Do you knmv David Copperfield? 13 Q, Did you know that Jeffrey Epstein received 13 MR. RHEINHART: That question was asked 14 sexual gratification from directing others to 14 abo'ut three-and-a-half-hours ago. 15 sexually abuse minor children? 15 THE WITNESS: On the instmction ofmy 16 MR. RHEINHART: Objection to the fonn. 16 lawy;:r, I must invoke my Fifth Amendment n THE WITNESS; On the instruction of my l7 privilege. 18 lawyer, 1 must invoke the Fifth Amendment 18 BY MR. WEISSING: 19 right. 1.9 Q. In addition to his place at, in Palm 20 .BY MR. WElSSING: 20 Reach, are you av.-are thatJeffrey Epstein has an 21 Q. Did you knmv that Jeffrey Epstein received 21 apartment located at 30 I East 66th Street, Apartment 22 sexual gratification from directing Marcinkova to 22 14G through E in New York? 23 sexuaJly abuse minor children? 23 MR. RJ-1EJNIL4RT: That question was asked 24 MR. RHEJNHART: Objection to the form. lt 24 about four hours ago. Tt's been asked and ____2_5_,_ _ _ai_s_su_m_e_,s_k_n_o_w_le_d_g_e_o_f_a_pe_·r_so_n_n_a_m_e_d_M_ar_c_in_k_o_va_.__2_s____ans_·w_c_re_'d_._ _ _ _ _ _ _ _ _ _ _ _ ______,j Page 316 Pagie 318 !~ l It is otherwise compound and objectionable. 1 THE WITNESS: At the instruction of my ~ 2 THE WITNESS: On the instru«;,1.ion of my 2 lawyer, I invoke my Fifth Amendment privilege. ] 3 lawyer, I must invoke my Fifth Amendment right. 3 BY ivtR. WEISSING: . 1 4 MR. WBISSING: Let's go offtherecord. for 4 Q. While in New York,have you procured ~ 5 a moment. 5 underage minor children to engage in sex1.ial acts ·~ 6 THE VIDEOGRAPHER: Are we an good with 6 with Jeffrey Epstein at that location? i '? going. off the record? 7 MR. RHErNHART: Object to the form. i 8 MR. RHBJNHART: Yeah, that's fine. 8 THE WITNESS: On the instruction of my J. 9 MR. HOROWITZ: Yes. 9 lawyer, 1 must invoke my Fifth Amendment ~ 10 THE VIDEOGRAPHER: We're nowoffthe 10 privilege. ·· 11 record at4:22 p.m. 11 BY MR. WEISSrNG: ] 12 {A briefrecess was held.) 12 Q. With regard to the minor children procured ~ 13 fflE VIDEOGRAPHER: We are now on the 13 for him at that location, were they school children ~ 14 record It is 4 :24 p.m. 14 in the New York area? ~ 15 BY MR. WEISSING: 15 MR. RHEINHART: The previous question, j 16 Q. Do you know Nadia Marcinkova? 16 objection to the form. The same as all the i 17 MR. KUVIN: Marcinkova. 17 previous qnestions, it assumes a .fact lhat's ffilj 18 THE WITNESS: On the insttuction of my 18 not been established. It can't fairly be ~ 19 lawyer, 1 must invoke my Fifth Amendment 19 armvered. ,~ 20 privilege. 20 THE WITNESS: On the instruction of my 1~ 21 BY MR. WEISSJNG: 21 lawyer, l must invoke my Fifth Amendment ~ 22 Q. Do you know - have you procured minor