EFTA01246832.pdf

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, 09-8-591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF TAKEN ON BEHALF OF THE PLAINTIFF DATE: April 13, 2010 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 1 of 38 EFTA_00067613 EFTA01246832  2 4 April 13,2010 APPEARANCES (CONTINUED) 2 LEOPOLD-KUVIN 2 INDEX wilwiIfs 3 WITNESS DIRECT CROSS REDIRECT RECROSS 3 4 4 5 BY MR. EDWARDS 5 98 6 BY MR. HOROWITZ 65 S BY: ADAM J. LANGINO, ESQ. 6 7 BY MR. LANGINO 77 7 8 BY MS. EZELL 81 PODIRMST, ORSECK 8 AllOmtp (calm Does I sad 3 Hu& Building. Suite )38 10 EXHIBITS 11 PLAINTIFF'S 10 FOR IDENTIFICATION PAGE BY: KATHERINE W. EZELL, ESQ. 11 12 12 BURMAN. CROTON. LUTTIER & COLEMAN, III' I Message dated August 21, 2005. 45 pstein 13 13 14 14 BY: DAVID YAREMA, ESQ. 15 15 ROBERT CRITION. ESQ. 16 16 ATTERBURY, GOLDBERGER & WEISS 17 17 I for Defendants 18 19 18 20 t9 21 BY: JACK A. GOLDBERGER. ESQ. 20 22 21 ALSO PRESENT: 23 22 JESSICA CADWEU. JOE ROVNER. Yid:n(40W 24 23 (US. Legal) 25 24 25 3 m i. to deposition of 1 THEREUPON. i in the above-entitled and numbered 2 3 cause, was taken before me, TERRI BECKER, a 4 Registered Professional Reporter and Notary 3 being by Terri Becker first duly sworn to tell 5 Public for the State of Florida at Large, at 444 4 the whole truth, as hereinafter certified, 6 West Railroad Avenue, in the City of West Palm 5 testified as follows: 7 Beach. Palm Beach County, in the State of 8 Florida, beginning at the hour of 10:00 o'clock 6 DIRECT EXAMINATION 9 a.m., pursuant to the Notice in said cause far 7 BY MR. EDWARDS: 10 the taking of said deposition which is annexed to 8 Q Can you tell us your name. 11 the court file herein, on behalf of the PLAINTIFF 12 in the above-entitled action pending in the 9 A 13 above-named coon. 0 Q What Is your dale of birth? 14 The appearances at said lime and place 1 A 15 were as follows: 16 12 Q What Is your Social Security number? FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL 13 A Under advice of my counsel, 1 invoke my 17 legs Plaintiffs Jane Does, 14 privileges under the Fifth and Sixth Amendments 15 to the United States Constitution and 18 16 respectfully decline to answer the question. 17 Q Where were you born? 18 A I'm sorry, though I would like to answer 20 BY: BRADLEY J. EDWARDS, ESQ. 21 19 your question, l must invoke my Fifth and Sixth MERMELSTEIN & HOROWITZ P.A. 20 Amendment privileges and refuse to answer your 22 Attorneys for Plaintiffs Jane Does, 21 questions. 23 22 Q What is your current address? 23 MR. GOLDBERGER: There is going to be a 24 continued, obviously, you anticipate I'm 25 BY: ADAM D. HOROWITZ. ESQ. 25 sure, continued invocation of Fifth 2 (Pages 2 to 5) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 2 of 38 EFTA 00067614 EFTA01246833  6 1 Amendment privileges. If it is okay with 1 A The Fifth. 2 all counsel, to shorten things, I'll simply 2 Q Do you know a lady by the name of 3 have the witness say -Filth,. if that 3 Maritsa Vazques? 4 satisfies everyone's interest. 4 A The Fifth. 5 MR. EDWARDS: That is fine with me. 5 Q Is this somebody who helped to falsify a MR. GOLDBERGER: Okay, with that Cathy? 6 visa for you? 7 MS. EZELL: Yes. 7 MR. YAREMA: Object to the form. 8 MR. HOROWITZ: Yes. A The Fifth. 9 Q I'll reask the question, what's your 9 Q Do you know Evelyn Velasaques? 10 current address? 10 A The Fifth. 11 A Fifth. 11 Q Were you ever a working model hat ilw 12 Q Are you currently living at 358 El 12 United States? 13 SHIM Way with a man named Jeffrey Epstein? 13 A The Fifth. 14 A The Fifth. 14 Q Can you tell us youi parents' names? 15 Q Are you also familiar with an address in 15 A The Fifth. 16 New York, 301 East 66th Street? 16 Q How is it that you have supported 17 A The Fifth. 17 yourself financially, since you have been in this 18 Q When Mr. Epstein was incarcerated In 18 country? 19 Jail, you went to visit him on numerous 19 MR. YAREMA: Object to the form. 20 occasions; is that correct? 20 A The Fifth. 21 MR. YAREMA: Objection. 21 Q Have you supported yourself financially? 22 A The Fifth. 22 A The Fifth. 23 Q When you went to visit him you indicated 23 Q What Is the last grade you completed in 24 to jail personnel your address was 301 East 66th 24 school? 25 Street, apartment 8-D in New York City, New York; 25 A The Fifth, I take the Fifth Amendment. 7 9 1 Is that correct? 1 Q Are you in school now? 2 MR. YAREMA: Objection. 2 A The Fifth. 3 A Fifth. 3 Q Have you ever attended any school in the 4 Q Isn't it true when Mr. Epstein was in 4 United States? S jail, you visited him on more than 50 occasions? 5 A The Fifth. 6 MR. YAREMA: Form objection. 6 Q Have you ever been employed since 7 Q True? 7 residing in the United States? 8 A The Fifth. 8 A The Fifth. 9 Q How long have you been in the United 9 Q Is Jeffrey Epstein your sole means of 10 States, 10 financial support today? 11 A The Fifth. 11 MR. YAREMA: Object to the form. 12 Q Who brought you to the United States? 12 A The Fifth. 13 MR. YAREMA: Form objection. 13 Q Since coming to this country, hasn't 14 A The Fifth. 14 Jeffrey Epstein always been your sole means of 15 Q What is your current status in this 15 financial support? 16 country? 16 MR. YAREMA: Object to the form. 17 A The Fifth. 17 A The Fifth. 18 MR. YAREMA: Form objection. 18 Q How much does Jeffrey Epstein pay you 19 MR. GOLDBERGER: Let me take a half a 19 today? 20 second. 20 MR. YAREMA: Object to the form. 21 (Witness and her counsel confer.) 21 A The Fifth. 22 Q Are you a U.S. citizen? 22 Q What does every Epstein pay you for? 23 A The Filth. 23 MR. YAREMA: Object to the form. 24 Q What type of visa are you here on? 24 A The Fifth. 25 MR. YAREMA: Form objection. 25 Q Does he pay you specifically to be his 3 (Pages 6 to 9) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 3 of 38 EFTA_00067615 EFTA01246834  10 12 1 sex slave? 1 Epstein's sex slaves? 2 MR. YAREMA: Object to the form. 2 MR. YAREMA: Object to the Ism 3 A The Fifth. 3 A Fifth. 4 Q Are you aware that the reports about you 4 Q What does it mean to be JelTrey 5 Indicate that you were brought to the United 5 Epstein's sex slave? 6 States by Jeffrey Epstein when you were roughly 6 MR. YAREMA: Object to the font. 7 13 or 14 years old to be his lesbian 7 A Fifth. 8 sex slave? 8 Q Are you aware that Jeffrey Epstein reads 9 MR. YAREMA: Object to the form. 9 books on how to be a proper master to his sex 10 A Thc Fifth. 10 slave? 11 Q Is that true? 11 MR. YAREMA: Object to the Iona. 12 MR, YAREMA: Object to the lomt 12 A Fifth. 13 A The Fifth. 13 Q What has Jeffrey Epstein done to train 14 Q Have you performed any services for 14 you to be his sex slave? 15 Jeffrey Epstein aside front being his sex slave? 15 MR. YAREMA: Object to the form. 16 MR. YAREMA: Object to the form. 16 A Fifth. 17 A The Fifth. 17 Q What do your parents think about you 18 Q What is your sexual orientation? 18 being Jeffrey Epstein's sex slave? 19 MR. YAREMA: Object to the Iona. 19 MR. YAREMA: Object to the form. 20 MR. GOLDBERGER: I'm going to instruct 20 A Fifth. 21 the witness not to answer that question. It 21 Q When did you first learn that Jeffrey 22 serves no purpose other than to harass or 22 Epstein had a sexual obsession for underage minor 23 intimidate her, so in addition to Fifth 23 females? 24 Amendment privileges, I'm objecting on 24 MR. YAREMA: Object to the form. 25 privacy grounds. 25 A Fifth. 11 13 1 A I take the Fifth. 1 Q How many times has Jeffrey Epstein made Q I represent a lady named, a young female 2 you have sex with underage minor females? 3 named you know who that is, right? 3 MR. YAREMA: Object to the Porn. S; 4 MIL YAREMA: Object to the form. 4 A Filth. 5 A The Fifth. 5 Q Do you enjoy sex with underage minor 6 Q Jeffrey Epstein made you have sex with 6 females? 7 didn't he? 7 MR. YAREMA: Object to the fort. 8 MR: YAREMA: Object to the form. 8 A Fifth. 9 A The Fifth. 9 Q What is the youngest child that Jeffrey 10 Q You did, In fact, engage in sexual 10 Epstein has forced you to have sex with? 11 activity with M. when she was only 16 years 11 MR. YAREMA: Object to the fonts. 12 old; isn't that true? 12 A Fifth. 13 MR. YAREMA: Object to the form. 13 Q Does Jeffrey Epstein today still make 14 A The Fifth. 14 you have sex with underage minor females? 15 Q Back to my original question: And I'll 15 MR. YAREMA: Object to the form. 16 ask you this way: Do you consider yourself 16 A Fifth. 17 heterosexual, bl-sexual, or can you answer that 17 Q How many underage minor females has 18 question? 18 Jeffrey Epstein made you have sex with, since you 19 MR. YAREMA: Object to the form. 19 were over the age of 18? 20 MR. GOLDBERGER: Same objection. Do not 20 MR. YAREMA: Object to the fonn. 21 answer the question. 21 A Thc Fifth. 22 A Fifth. 22 Q Prior to turning 18, is it true that 23 Q How did you meet Jeffrey Epstein? 23 Jeffrey Epstein made you have sex with many other 24 A Fifth. 24 children in kid-type orgies? 25 Q When did you become one of Jeffrey 25 MR. YAREMA: Object to the fonn. 4 (Pages 10 to 1 3) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 4 of 38 EFTA_00067616 EFTA01246835  14 16 1 A Filth. 1 A Fifth. 2 Q Has Jeffrey Epstein also made you 2 Q Have you read the nonprosecution 3 perform sexually on his friends? 3 agreement between the government and Jeffrey 4 MR. YAREMA: Object to the form. 4 Epstein? 5 A Fifth. 5 A Fifth. 6 Q Do you know David Copperfield? 6 Q Are you aware that inside that document 7 MR. YAREMA: Object to the form. 7 you are labeled as a co-conspirator of his crimes 8 A Fifth. 8 against children? 9 Q Have you ever been made to perform 9 MR. YAREMA: Object to the form. 10 sexually on David Copperfieki? 10 A Fifth. 11 MR. YAIIEMA: Object to the form. 11 Q Isn't it true that your role was to lure 12 A Fifth. 12 or procure underage minor females to Jeffrey 13 Q Do you know Prince Andrew? 13 Epstein for him to molest, correct? 14 A Fifth. 14 MR. YAREMA: Object to the fonn. 15 Q Have you ever been made to perform 15 A Fifth. 16 sexually on Prince Andrew? 16 Q You also scheduled appointments for 17 MR. YAREMA: Object to the form. 17 Jeffrey Epstein, so there would be designated 18 A Fifth. 18 times for Jeffrey Epstein to molest underage 19 Q When was the first time that you knew 19 minor females, correct? 20 Jeffrey Epstein molested underage girls? 20 MR. YAREMA: Object to the fonn. 21 MR. YAREMA: Object to the form. 21 A The Fifth. 22 A Fifth. 22 Q As well, you participated in various sex 23 Q Did Jeffrey Epstein molest you when you 23 acts with underage minor females, thus molesting 24 were underage? 24 them yourself; is that correct? 25 MR. YAREMA: Object to the form. 25 MR. YAREMA: Object to the font 15 17 1 A Fifth. 1 A Fifth. 2 Q I'm assuming you understand why you're 2 Q Do you understand that Jeffrey Epstein's 3 here today, correct? 3 interaction with underage minor females is 4 MR. YAREMA: Object to the fonn. 4 Illegal? Do you understand that? S A The Fifth. 5 MR. YAREMA: Object to the form. 6 Q For allegations related to Jeffrey 6 A The Fifth. 7 Epstein interacting sexually with numerous 7 Q Do you understand that the Lewd and 8 underage minor females; that's something you 8 Lascivious Molestation Statute In Florida 9 know, right? 9 indicates a person who Intentionally touches in a 10 MR. YAREMA: Object to the form. 10 lewd or lascivious manner, the breasts, genital 11 A The Fifth. 11 area or buttocks, or the clothing covering them, 12 Q That's something In addition to the 12 of a person less than 16 years of age, or forces 13 civil lawsuits, there were criminal cases 13 or entices a person under 16 years of age, to so 14 involving the same conduct, correct? 14 touch the perpetrator, commits lewd or lascivious 15 MR. YAREMA: Object to the feta 15 molestation? Are you aware of that statute? 16 A Fifth. 16 A Fifth. 17 Q You were a part of that CaMillai 17 Q That is a statute that you know Jeffrey 18 Investigation, in fact, you were a co-conspirator 18 Epstein to have violated; Is that true? 19 of Jeffrey Epstein's; is that right? 19 MR. YAREMA: Object to the form. 20 MR. YAREMA: Object to the form. 20 A The Fifth. 21 A Fifth. 21 Q That's a statute that you yourself have 22 Q What crimes did you conspire to commit 22 violated; is that true? 23 with Jeffrey Epstein against underage minor 23 MR. YAREMA: Object to the form. 24 females? 24 A The Fifth. 25 MR. YAREMA: Object to the tom. 25 Q You've observed Jeffrey Epstein violate 5 (Pages 14 to 17) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 5 of 38 EFTA_00067617 EFTA01246836  18 20 that statute on many underage minor females, 1 co-conspirator in the non-prosecution agreement 2 true? 2 related to Jeffrey Epstein's crimes against 3 MR. YAREMA: Object to the font 3 minors? 4 A The Filth. 4 MR. YAREMA: Object to the form. 5 Q (lave you ever discussed with Jeffrey 5 A Fifth. 6 Epstein that the fact that he is a child 6 Q Do you know or molester? 7 8 MR. YAREMA: Object to the form. a A Fifth. 9 A Filth. Q These are all people who also t0 Q Have you asked Jeffrey Epstein why he 10 participated in Jeffrey Epstein's scheme to lure has made you interact with underage minor females 11 underage females to him for sex; is that true? 12 in a sexual manner? 12 MR. YAREMA: Object to the form. 13 MR. YAREMA: Object to the fon% 13 A Fifth. 14 A Filth. 14 Q You and these other co-conspirators 15 Q During the litigation of these civil 15 played various roles to make sure Jeffrey Epstein 16 cases, has Jeffrey Epstein indicated to you an 16 was able to engage In sexual contact or conduct, 17 intent to continue to molest children? 17 with underage minor females on an everyday basis; 19 MR. YAREMA: Object to the loon. 18 is that true? 19 A Fifth. 19 MR. YAREMA: Object to the form. 20 Q Is it your intent to continue to commit 20 A Fifth. 21 sex crimes against minors? 21 Q Since the time you first met Jeffrey 22 MR. YAREMA: Object to the form. 22 Epstein, has his appetite for underage minor 23 A Fifth. 23 females always been the same? 24 Q In addition to your being named as a 24 MR. YAREMA: Object to the form. 25 co-conspirator of Jeffrey Epstein regarding his 25 A Fifth. 19 21 crimes against minors, there is also a person 1 Q By that I mean, have you observed named listed as a co-conspirator. 2 Jeffrey Epstein to interact sexually with 3 Do you know 3 underage minor females literally on a doily 4 A Fifth. 4 basis? 5 Q This Is somebody who lives with you and MR. YAREMA: Object to the form 6 Jeffrey Epstein; Is that true? 6 A Fifth. 7 MR. YAREMA: Object to the four. 7 Q Wasn't it one of your specific job 8 A Filth. duties to make sure that he had different 9 Q And is somebody who you 9 underage minor females to molest on a daily 10 know to be girlfriend; is that 10 basis? 11 true? 11 MR. YAREMA: Object to the form. 12 MR. YAREMA: Object to the form. 12 A Fifth. 13 A Fifth. 13 Q In addition to the improper sexual 14 Q She's spoken with about 14 contact between Jeffrey Epstein and underage 15 this case on numerous occasions; is that true? 15 minor females at the West Palm Beach house, you 16 MR. YAREMA: Object to the form. 16 have observed similar improper and illegal 17 A Fifth. 17 contact by Jeffrey Epstein in his New York 18 conversations with= mansion, as well, correct? 19 and your observations of them, you believe 19 MR. YAREMA: Object to the form. 20 would implicate you in a crime and that's why 20 A Fifth. 21 you're able to take the Fifth as to that 21 Q In fact, he operates a very similar 22 question? 22 scheme up there, in that he schedules these 23 MR. YAREMA: Object to the fonn. 23 appointments with underage minor females, under 24 A Fifth. 24 the guise that it is going to be a massage; is 25 Q Who is Lesley Groff, also listed as a 25 that correct? 6 (Pages 18 to 21) U.S. Legal Support (561) 835 - 0220 CONFIDENTIAL 3501.144-028 Page 6 of 38 EFTA_00067618 EFTA01246837  22 24 1 MR. YAREMA: Object to the loon? 1 when Jeffrey Epstein commits these crimes against 2 A Fifth. 2 children? 3 Q When he is in New York, he has contact 3 MR. YAREMA: Object to the font 4 with underage minor females for the purposes of 4 A Fifth. 5 sexually molesting than as well; is that S Q Is there any way for you to escape being 6 correct? 6 his sex slave? 7 MR. YAREMA: Object to the fonn. 7 MR. YAREMA: Object to the form. 8 A Fifth. 8 A Fifth. 9 Q When he is in his ranch in New Mexico, 9 Q Have you ever wanted to cooperate with 10 similarly, Jeffrey Epstein is engaging in sex 10 the authorities, so that you could escape being 11 with underage minor females from that local area 11 his sex slave? 12 as well, and that's something you've observed? 12 MR. YAREMA: Object to the fonn 13 MR. YAREMA: Object to the fonn. 13 A Fifth. 14 A Fifth. 14 Q Do you represent to others that you are 15 Q On his island, particularly, he has 15 his girlfriend or his sex slave, or sonic other 16 flown underage minor females to the island for 16 designation? 17 underage kid-type orgies; is that true? 17 MR. YAREMA: Object to the form. 18 MR. YAREMA: Object to the form. 18 A Fifth. 19 A Fifth. 19 Q Isn't it true that you recently 20 Q You're shaking your head indicating, at 20 represented to the Probation Officer that you 21 least to me, indicating that you may not agree 21 were his live-In girlfriend? 22 with what I'm saying, and I would love to give 22 MR. YAREMA: Object to the form. 23 you the chance to explain it to us. 23 A Fifth. 24 MR. GOLDBERGER: I appreciate that, but 24 Q When Probation calls the house, are you 25 don't — 25 told to tell Probation that he is in the swimming 23 25 1 MR. EDWARDS: Read too much into it? 1 pool or doing some other activity that would not 2 MR. GOLDBERGER: Exactly. Don't go 2 allow him to come to the telephone? 3 there. Just ask the questions and we will 3 MR. YAREMA: Object to the fonn. 4 move right along. 4 A Fifth. 5 MR. EDWARDS: I agree, Jack, I just know S Q Isn't It true you're under strict orders 6 if this is played for a jury, I don't want to tell Probation that? 7 the jury to interpret her shaking ha head 7 MR. YAREMA: Object to the fonn. 8 as a "No." and then her pleading the Fifth. 8 A Filth. 9 MR. GOLDBERGER: I appreciate that. 9 Q Isn't it true you've heard Jeffrey 10 Don't take anything as to any head movements 10 Epstein tell you on numerous occasions, regarding 11 or any body movements at all. Just ask the 11 the age of the girls that he wants to his house, 12 questions and we will let the video speak 12 for the purposes of sexually molesting, the 13 for itself. 13 phrase he uses is "the younger the better," 14 Q How many of these — you know what an 14 true? 15 orgy Is, don't you? 15 MR. YAREMA: Object to the form. 16 A Fifth. 16 A Fifth. 17 Q And how many of these orgies, as I'm 17 Q I asked you earlier about M. out of 18 calling them, where there are numerous underage 18 turn as a result of an objection related to your 19 minors having sex with each other and with 19 sexual orientation, but I'll talk specifically 20 Jeffrey Epstein, have you observed on Jeffrey 20 about.. right now. You know who that Is, 21 Epstein's island? 21 right? 22 MR. YAREMA: Object to the form. 22 MR. YAREMA: Object to the form. 23 A Fifth. 23 A Fifth. 24 Q Is part of your role as Jeffrey 24 Q That is somebody you observed Jeffrey 25 Epstein's sex stave, to not tell the authorities 25 Epstein to call for the purposes of getting her 7 Pages 22 to 25) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 7 of 38 EFTA_00067619 EFTA01246838  26 28 to his house to sexually molest; Is that right? 1 minor females? 2 MIL YAREMA: Object to the font 2 MR. YAREMA: Object to the form. 3 A Fifth. 3 A Fifth. 4 Q The first time she went to Jeffrey 4 Q You have received oral sex front underage 5 Epstein's house was in 2002 when she was only 14 5 minor females? 6 years old; Is that true? 6 MR. YAREM A: Object to the fonn. 7 MR. YAREMA: Object to the font,. 7 A Fifth. A Fifth. 8 Q All of these sexual acts with minor 9 Q In fact in 2002 you were only 18 years 9 females involving you happened in the presence of 10 old or so yourself; is that right? 10 Jeffrey Epstein? 11 A Fifth. 11 MR. YAREM A: Object to the bona. 12 Q And M. is somebody you observed at 12 A Fifth. 13 Jeffrey Epstein's house on more than 100 13 Q During your interaction with underage 14 occasions between 2002 and 2005, a time period 14 minor females in a sexual manner, isn't it true 15 between 14 and 17 years of age for her; is that 15 that Jeffrey Epstein would participate in the 16 right? 16 sexual acts and the act would be over upon 17 MR. YAREMA: Object to the font,. 17 Jeffrey Epstein ejaculating, correct? 18 A Fifth. 18 MR. YAREMA: Object to the font,. 19 Q And each time M. was summoned to 19 A Filth. 20 Jeffrey Epstein's house, it was for the purposes 20 Q Did Jeffrey Epstein tell you, that when 21 of Jeffrey Epstein sexually molesting her, 21 M. was an underage minor female, he forced her 22 correct? 22 to give hint oral sex? 23 MR. YAREMA: Object to the form. 23 MR. YAREMA: Object to the font 24 A Fifth. 24 A Fifth. 25 Q If it was not Jeffrey Epstein personally 25 Q Do you remember coming over, • 27 29 1 calling ., you observed to call 1 young girl, with braces on, and going up Into 2 S 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. YAREMA: Object to the form. 4 MR. YAREMA: Object to the tons 5 A Fifth. 5 A Fifth. 6 Q And do you remember the instance where 6 Q Do you know when it was that Jeffrey 7 Jeffrey Epstein instructed you to lay down naked 7 Epstein developed his plan or scheme to gain and engage in a threesome with M. and Jeffrey access to hundreds of underage minor females for 9 Epstein? 9 the purposes of his sexual gratification? 10 MR. YAREMA: Object to the fonn. 10 MR. YAREMA: Object to the font 11 A Fifth. 11 A Fifth. 12 Q Do you remember that that during that 12 Q Were you a part of the planning of that 13 threesome, Jeffrey Epstein demanded M. to 3 scheme of Jeffrey Epstein's to gain access to 14 straddle you and otherwise engage sexually with 4 underage minor females? 15 you while Jeffrey Epstein was using vibrators 5 MR. YAREMA: Object to the form 16 and/or dildos on you? 6 A Fifth. 17 MR. YAREMA: Object to the fonts 7 Q Do you know Ohislaine Maxwell? 18 A Fifth. A Fifth. 19 Q In addition to your sexual interactions 9 Q Is that somebody who helped Jeffrey 20 with M., isn't it true that you have used 0 Epstein to devise the scheme to allow hint access 21 strap-on dildos and vibrators on other underage 1 to various and a variety of underage minor 22 minors at Jeffrey Epstein's direction? 2 females? 23 MR. YAREMA: Object to the form. 3 MR. YAREMA: Object to the 24 A Fifth. 4 A Fifth. 25 Q You have given oral sex to underage 5 Q Is somebody that was also B (Pages 26 to 29) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 8 of 38 EFTA_00067620 EFTA01246839  30 32 1 Involved In the planning of this scheme to gain 1 sex toys on you, correct? 2 access to underage minor females? 2 A Fifth. 3 MR. YAREMA: Object to the fonn. 3 Q And he has instructed you to use sex A Filth. 4 toys and vibrators on other underage minor 5 Q When Is the first time that you observed 5 females, correct? 6 Jeffrey Epstein's method of enticing or inducing 6 MR. YAREMA: Object to the form. 7 underage minor females into sexual acts with him 7 A Fifth. 8 inside his bedroom? 8 Q You have observed Jeffrey Epstein 9 MR. YAREMA: Object to the form. 9 digitally penetrate the vagina of underage minor 10 A Fifth. 10 females, Including •., correct? 11 Q Isn't it trite that after an underage 11 MR. YAREMA: Object to the fonn. 12 minor female was brought to Jeffrey Epstein's 12 A Fifth. 13 house, typically or or 13 Q As pan of his plait to avoid detection 14 yourself would lead that underage minor female to 14 by law enforcement, you have observed Jeffrey 15 Jeffrey Epstein's bedroom and leave them atone do 15 Epstein to pay these underage minor females to be 16 the room; is that true? 16 quiet, correct? 17 MR. YAREMA: Object to the fonn. 17 MR. YAREMA: Object to the form. 18 A Fifth. 16 A Fifth. 19 Q Then Jeffrey Epstein would appear either 19 Q And this is something that he has told 20 naked or wearing a towel; is that true? 20 you he does, for the purposes of grooming these 21 MR. YAREMA: Object to the form. 21 underage minor females, and avoiding law 22 A Fifth. 22 enforcement detection, correct? 23 Q This Is his habit or method of 23 MR. YAREMA: Object to the form. 24 operation, every single time, and that's 24 A Fifth. 25 something that he has told you about his sexual 25 Q Jeffrey Epstein has talked to you about 31 33 1 interaction with underage minors; is that true? 1 the psychology of brainwashing or grooming 2 MR. YAREMA: Object to the form. 2 underage minor females to perform for him 3 A Fifth. 3 sexually, hasn't he? 4 Q And he would direct or demand or 4 MR. YAREMA: Object to the fonn. 5 Instruct the underage minor female to remove her 5 A Fifth. 6 clothing; is that true? 6 Q And has also spoken with 7 MR. YAREMA: Object to the form. 7 you about the methodology behind gaining access 8 A Fifth. 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 or sexual acts on the underage 10 A Fifth. 11 minor female. Is that true? 11 Q Isn't it true that Ghislaine Maxwell and 12 MR. YAREMA: Object to the form. 12 yourself and had access to a master 13 A Fifth. 13 Ilst of underage minor remain names and phone 14 Q And you have observed Jeffrey Epstein 14 numbers so that they could be called? 15 engage in sexual interaction with underage minor 15 MR. GOLDBERGER: Time out. Are you 16 females on hundreds and hundreds of occasions, 16 talking to me, counsel? 17 correct? 17 MR. HOROWITZ: Nodding my head, back at 18 MR. YAREMA: Object to the font 18 you. You were nodding at me. 19 A Fifth. 19 MR. GOLDBERGER: I wasn't nodding at 20 Q And you have observed Jeffrey Epstein 20 you. I'm not talking to you, I'm not 21 using vibrators and sexual toys on underage 21 communicating with you.. I don't know what 22 minors, true? 22 you think we arc doing here. You said "It 23 MR. YAREMA: Object to the fonn. 23 is true," and I have no idea what you are 24 A Fifth. 24 talking about. Don't inlet-nn the 25 Q In fact, he has also used vibrators and 25 deposition, okay? 9 (Pages 30 to 33) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 9 of 38 EFTA_00067621 EFTA01246840  34 36 1 MIL HOROWITZ: I think you interrupted. 1 A Fifth. 2 MR. GOI.DBERGER: 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 traMcs underage minor 4 happened here. It has deteriorated here for 4 females through a modeling agency? 5 no reason whatsoever and has nothing to do 5 MR. YAREMA: Object to the form. 6 with mc or the witness. 6 A Fifth. 7 MR. GOLDBERGER: You're 100 percent 7 Q Is a modeling agency that he is Involved 8 correct 0 in with Jean Luc Brunel; you know who that is 9 MR. EDWARDS: Can we go back to it. 9 right? 10 MR. GOLDBERGER: Absolutely. 10 MR. YAREMA: Object to the form. 11 MR. EDWARDS: Perfect. 11 A Fifth. 12 The silent fight disrupted mc. I lost 12 Q Are you familiar with MC-2 or MC-Squared 13 where I am now. 13 Modeling Agency? 14 MR GOLDBERGER: Sony. 14 A Fifth. 15 MR EDWARDS: Can you read it back. 15 Q You know Jean Luc Brunel, right? 16 THE COURT REPORTER: Certainly. 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 yourself, Ghislaine 20 MR. YAREMA: Object to the form. 21 Maxwell and had access to a master 21 A Fifth. 22 of list of underage minor females names and phone 22 Q Jean Luc Brunel is somebody that you 23 numbers so they could be called for the purpose 23 know to also be 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 Filth.