EFTA01083260.pdf

1-1 nr 1 fi l-13 Pilad (15/2.1F Pa, a fi EXHIBIT 8 EFTA01083260  Case 1:15-cv-07433-RWS Document 161-8 Filed 05/25/16 Page 2 of 6 Pace 1 Page 3 UNITED S TA1ES DISTRICT' COURT IN TI E CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT SOUTHERN DISTRICT OF FLORIDA 2 IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008C.A02805I XXXXMB AB CASE NO. 08.CIV40119-MARRA/JOHNSON 3 4 L.M.. JANE DOE 573. .1. 5 Mauna VOLUME I OF II! 6 VOLUME I OP III lEFIREY EPSTEIN. 7 JEFFREY EPSTEIN, thiencbm Datimdant. 9 Related tack 10 041-80231, 08-08380 0640 ig 43-lit)904 11 te-80993, 08-806I I. 0840693. 0940069 12 Vt1.O,OTAPED DEPOSII ION OP 0940591, 0940656, 0040a02, 0941092 13 14 V1"SUTTON 15 Ortdousday. March 20, 2010 SITION OF 10:37 - 6:51 p.m. 16 Wednesday, March 24. 2010 17 1097 - 6:51 p.m. 18 250 Australian Avaum South Suite 1500 250 Amu:than A‘emit South 19 West Palm Beach. Florida 33401 Suite 1500 20 West Palm !lea.ls. Maki 3340i 21 22 Reported Hy: Cynthia HopIthrs, RPR, FVR Repents! 23 No'-try Puhlic.. Stale ofFlorida Cynthia I lopkitiss RPR, FPR Neary Public. Slam of Pcmaa Prow Court Reporting SeIVICe3 Prose Cant Roportins: Scniccv 2i Job :46.: 1484 Job No.. 11114 125 Page 2 Page 4 1 IN TIIE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 1 IN THE CIRCUIT COURT OVINE FIFTEENTH JUDICIAL IN AND FOR PALM BEACH COUNTY.FLORIDA Mall 1 IN AND FOR PALM BEACH COUNTY, FLORIDA 2 cssr. NO. 501008CA0211058XXX70.48 AD 2 CASE. No 502008CA037319XXXXMB AB 3 3 aw. B.& 4 4 Phlan; t you've 101III 6 VOLCME I OF RI JEFFREY EPSTEIN, 7 JEFitia B AN. Lyelardunt. 9 Defend tuts I) 9 11 VI VIDEOTAPED DWOSON OF 10 12 1: VI FON OF 13 12 Wedavalay, Math ?A, 1010 13 14 14 Wednesday, March 24, 2010 10 37-651p.m 10 37.6 51p.m IS 15 12. 16 17 250 Australian As owe South 17 250 Australian Avenue Saudi Suite 1500 Suite 1500 1$ Wed Palm Ileach, Float 33401 1 Weal Palm Beach, 1lunda 33401 : 20 2C 21 21 22 Reported By. 22 Reponed By. Cynthia Hopkins. RPR. FPR Cynthia I lopkins, RPR, FPR 23 Notary Pubkc, Sturc of Honda 23 NMary Public, Stateof Florida Prose Court Reporting &rocas Prole Court Reporting Services 24 lob No 1134 24 Mb No.: 1484 2.5 1 (Pages 1 to 4) PROSE COURT REPORTING AGENCY, INC. 01111.1 RI 001671 EFTA01083261  Case 1:15-cv-07433-RWS Document 161-8 Filed 05/25/16 Page 3 of 6 Page 21 Page 23 1 answer the question based on her Fifth witness, and I will instruct the witness not to Amendment privilege. answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction ofmy 3 THE WITNESS. On the instruction of my 4 lawyer, I must invoke my Fifth Amendment right. 4 lawyer, I must invoke my Fifth Amendment right. S BY MR. KUVIN. 5 BY MR. KUVIN: 6 Q. Who introduced you to Jeffrey Epstein the 6 Q. Would you agree with me that 7 first time that you met him? 7 Jeffrey Epstein owns numerous planes, private B M.R. RIIONIIART: Same instruction. B planes? 9 THE WITNESS: On the instruction of my 9 MR. RHEINHART, Instruct the witness not 10 lawyer, I must invoke my Fifth Amendment right. 10 to answer. 11 BY MR. KUVIN: 11 TIIE WITNESS: On the instruction of my 12 Q. Did Chislaine Maxwell introduce you to 12 lawyer, I must invoke my Fifth Amendment right. 13 Jeffrey Epstein for the first time? 13 BY MR. KUVIN: 14 MR. RHEINHART: Same instruction. 14 Q. And you've been on every one of those 15 'IHE WITNESS: On the instruction of my 15 private planes; isn't that true? 16 lawyer.linu.st invoke my Fifth Amendment right. 16 MR. RHEINHART: Object to the form. It 17 BY MR. RUN/IN. 17 Snuffles facts not before the witness, and 15 Q. When was the first lime you were in will instruct the witness not to answer based 19 lenity Epstein's home located on El Brillo Way on 19 on her Fifth Amendment privilege. 20 Palm Beach Island? 2.0 THE WITNESS: On the instruction of my 21 MR. RHEINHAR Object to the form of the 21 lawyer. I must ins okc my Fifth Amendment right. •.•1 .ss question as compound and assuming facts not 22 BY MR. KUVIN: 23 before the witness. And I instinct the witness 23 Q. Ma'am, isn't it true that you've seen the 24 not to answer based Off her Fifth Amendment 24 passenger manifest for Jeffrey Epstein's plane? 25 privilege. 25 MR. RHEINHART: Object to the form. It Page 22 Page 24 1 THE WITNESS: On the instruction of my 1 assumes facts that are not established as known 2 lawyer, I must invoke my Fifth Amendment right. 2 to this witness, and I instruct the witness not 3 BY MR. KUVIN: 3 to answer the question based on her Fifth 4 Q. Would you agree with me that 4 Amendment privilege. 5 Jeffrey Epstein owns a home at 358 El Brillo Way, 5 TIIE WITNESS: On the instruction 'army Palm Beach Island. Florida? 6 lawyer, I must awoke my Filth Amendment right. 7 MR. RHEINHART: Instruct the witness not MR. KUVIN: Let me show you what we'll 8 to answer based on her Fifth Amendment mark as Exhibit 2. 9 privilege. 9 TIIE WITNESS: On instruction of my 10 iPlaintift's Exhibit No. 2 was marked tbr II counsel. I must invoke my Fifth Amendment 13 identification.) 2 right. 12 MR. KUVIN: Thank you. 13 BY MR. KUVIN: 13 MR. RIlEINHART: Do you want to TO.101 IS on 14 Q. Would you agree with me that you've been 14 it like you did the last time 15 in Mat home numerous times? 15 MR KUVIN. No, that's fine. 16 MR. RHEINHART: 'Instruct the witness not 16 MR. RI lEINHART Take your time. 17 to answer the question based on her Fifth 17 MR. KUVIN: And flip through. 18 Amendment privilege. 18 BY MR. KUVIN: 1.9 THE WITNESS: On instruction of my lawyer, 39 Q. All right. Ma'am, would you agree with me 20 I must invoke my Fifth Amendment right. 20 that this Is a passenger manifest for one of BY MR. KUVIN: 21 Jeffrey Epstein's airplanes? 22 Q. Would you agree with me that you have gone 72 MR. RHEINHART: Instruct the witness nut 23 on Jeffrey Epstein's plane numerous times? 23 to answer the question based on her Fifth 7.; MR. RHEINHART: Object to the form. It 24 Amendment privilege. 25 assumes facts that are not present for the 25 HIE WITNESS: On the instruction uf my 6 (Pages 21 to 24) PROSE COURT REPORTING AGENCY, INC, (writ) isni076 EFTA01083262  Case 1:15-cv-07433-RWS Document 161-8 Filed 05/25/16 Page 4 of 6 Ptee 271 Page 39 3. THE VIDEOORAPHER: We're now on video I 1 personal knowledge and instruct her not to 2 record at II:0I a.m. answer based on her Fifth Amendment privilege. 3 MR. KUVIN: Just for the video record and 3 It's also compound. 4 for the written record Katherine Ezell and Amy 4 THE WITNESS: On the instruction of my 5 Edell have now appeared and are present in 5 lawyer I must invoke my Fifth Amendment person. 6 privilege. 7 MR. GOLDBEROEFt: Just one more matter for 7 BY MR. KUVIN: 8 the record. Jack Goldberger, on behalf of a Q. The witness says that you may not have 9 Jeffrey Epstein. Rather than impose a form 9 knowledge or we don't know whether you have 10 objection to every question, I think we have 10 knowledge regarding this passenger manifest, so let reached an agreement that on behalf of 11 me ask you, do you have any knowledge about this • :2 Mr. Epstein. I am adopting the form objections 12 passenger manifest? :3 that Mr. Rheinhan k making on behalf ofhis 13 MR. RHEINHART: Object to the form of the !4 client nuns pro tune to the beginning of this 14 question as ambiguous as to this and what a 15 deposition. 15 manifest is, and also her knowledge, and I will 16 MR. KUVIN: No objection. 16 instruct her not to answer based on her Fifth 17 MR. GOLDBERGER: Okay. 17 Amendment privilege. 18 BY MR KUVIN: 18 THE WITNESS: On the instruction of my • 19 Q. All right. All right. Ms. M, would 19 lawyer, I must invoke my Fifth Amendment 20 you agree with me that there was an agreement 20 privilege. 21 between Jeffrey Epstein, Ghislaino Maxwell. 2.1 BY MR. KUVIN: 22 Jean-Luc Brunel, yourself and 22 Q. Based on the objection, do you know what a 23 bring in girls from out of slate that were underage? 23 manifest is? 24 MR. RHEINHART: Object to the form of the 24 MR. RHEINFIART: Object to the form of the 5 question as leading, as compound, and instruct 25 question as ambiguous and instruct her not to Page 38 Page 40 the witness not to answer based on her Fifth 1 answer based on her Filth Amendment privilege. 2 Amendment privilege. 2 THE WITNESS: On the instruction ofmy THE WITNESS: On the instruction of my 3 lawyer I must invoke my Fifth Amendment right 4 lawyer I must invoke my Fifth Amendment right. 4 BY MR. KUVIN' BY MR. KUVIN: 5 Q. I lave you heard the word "manifest" before? 6 Q. Would you agree with me that there was an 6 MR. RHEINHART: I'll instruct tha witness 7 agreement between Jeffiey Epstein, 7 not to answer based on her Fitth Amendment 8 Oltistaint Maxwell, Jean-Luc Brunel, yourself and 8 privilege. 9 to bring in girls that were 9 THE WITNESS: On the instruction ofmy 10 underage from out of state for sexual contact? 10 lawyer I must invoke my Fifth Amendment right 11 MR. RHEINHART: Object to the fonn of the 11 BY MR. KUM: 12 question as leading and compound, and I 12 Q. Would you agree with me. ma'am, that you 13 instruct the witness not to answer based on her 13 have seen this passenger manifest, listed as 1.4 Fifth Amendment privilege. 14 Exhibit 3, in the past? 15 THE. WITNESS: On the instruction of my 15 MR. RHEINHART: I'll instruct the witness S lawyer I must invoke my Fifth Amendment 16 not to answer based on her Fish Amendment privilege. 17 18 BY MR. KUVIN: 18 THE WITNESS: On the instruction of my 19 Q. All right. Let tne Miow you what we've 19 lawyer I must invoke my Fifth Amendment right. 20 premarked as Plaintiffs Exhibit 3. Do you 20 BY MR. KUVIN: 21 recognize this as the passenger manifest for one of 21 Q. Who Jeffrey Epstein's planes? 22 MR. RHEINHART: I'll instruct the witness 21 MR. R14EINHART : I object to the form of 23 not to answer based on her Fifth Amendment 24 the question. It assumes facts that this 24 privilege. 5 witness, evidence that this witness has no 25 THE WITNESS: On the instruction of my 10 (Pages 37 to 40) PROSE COURT REPORTING AGENCY, INC. 6WHithOthIN EFTA01083263  Case 1:15-cv-07433-RWS Document 161-8 Filed 05/25/16 Page 5 of 6 Page 97 Page 99 MR. RHEINHART: Seine ins:ruction. 1 assumes facts that have not been established 2 THE WITNESS: On the instruction of my 2 and it's compound. 3 lawyer, I must invoke my Fifth Amendment 3 THE WITNESS: On the instruction of my 4 privilege. 4 lawyer, I must invoke my Fifth Amendment 5 BY MR. KUVIN: 5 privilege. 6 Q. Have you ever worked as a professional 6 MR. RHEINHART: And to clarify the 7 model? 7 objection is that it assumes that she's ever 8 MR. RHEINIIART: May I consult? 8 met or knows anything about Jean-Luc Brunel. 9 MR KUVIN: Sum. 9 BY MR. KUVIN: 10 MR. RHEINHART: You can answer the 10 Q. Were you eve: promised anything regarding 11 question. 11 your modeling career by Jeffrey Epstein? 12 THE WITNESS: Yes. 12 MR. RHEINHART. Same objection, instruct 13 BY MR. KtIVIbE 13 the witness not to answer. A Q. When? 14 THE WITNESS: On the instruction ofmy 15 A. I don't remember. I don't remember the dates. 1b lawyer, I must invoke my Fifth Amendment 16 It was at least maybe ten years ago. 16 privilege. Q. And you're how old now? 17 BY MR. KUVIN: 8 MR. RHEINHART: I'll instruct the witness 18 Q. You would agree with me that there is a 19 not to answer the question. Nice try. 19 financial arrangement between Jean-Luc Brunel and 20 Instruct you not to answer based on 20 Jeffrey Epstein. do you not? 21 your Fifth Amendment privilege. 21 MR. RHEINHART! Objection. It assumes she 22 THE WITNESS: On the instruction ofmy 22 has any knowledge of either Mr. Epstein or 23 lawyer, I'm going to invoke my Filth Amendment 23 Mr. Brunel, and as to that she is going to 24 privilege. 24 invoke her Fifth Amendment privilege. The MR. KUVIN: I'm just trying to find out. 25 question is compound and therefore ambiguous. -.— Page 'Id Page 100 1 MR. RHEINHART: Like I said, good try. 1 THE WITNESS: On the instruction of my 2 Move on. 2 lawyer, I must invoke my Fifth Amendment 3 BY MR. KUVIN: ":4 privilege. 4 Q. With respect to your work as a 4 BY MR. KUVIN: 5 professional model, what company did you work for? 5 Q. Would you agree with me that 6 MR. RHEINHART: Instruct the witness not 6 Ghislaine Maxwell provides underage girls to 7 to answer based on the Fifth Amendment 7 Mr. Epstein for sex? a MR. RHEINHART: Objection to the form. It 8 privilege. 9 THE WITNESS: On the instruction of my assurile‘s she knows anything at all about 10 lawyer, I invoke my Fifth Amendment privilege. 10 Ghislaine Maxwell and asks her to assume that 11 BY MR. KUVIN: 11, she does, and therefore it is compound and 12 Q. What is your understanding of 12 ambiguous, and I would instruct her not to 13 Mr. Epstein's involvement with the modeling 13 answer. 14 industry? 14 THE WITNESS: Upon the instruction of my 15 MR. RHEINHART: Standing objection, and If. lawyer, I must invoke my Fifth Amendment 16 instruct the witness not to answer based on 16 privilege. 17 Fifth Amendment. on that basis. MR. KUVIN: That's a good point. Take a 3e THE WITNESS; Upon the instruction ofmy 1E' look at what we'll mark as Exhibit H./. 19 lawyer. I must awoke my Fifth Amendment 19 (Plaintiffs Exhibit No. 10 was marked for 20 privilege. 20 identification.) 21 BY MR. KUVIN: 21 MR. KUVIN: All me to show it to the 22 Q, Were you ever promised anything regarding 22 camera fist. 23 your modeling career by Jean-Luc Brunel? 23 MR. RHEINHART: Okay. 24 MR. RHEINHART: Instruct the witness not 24 MR. KUVIN: Okay. 25 to answer based on Fifth Amendment, also 25 THE WITNESS: Okay. 25 (Pages 97 to 100) PROSE COURT REPORTING AGENCY, INC. OUNROOM93 EFTA01083264  Case 1:15-cv-07433-RWS Document 161-8 Filed 05/25/16 Page 6 of 6 Page 445 gage 147 1 reasonably designed to lead to discoverable deposition or you may waive reading and allow the evidence. 2 csourt reporter to simply type it up and distribute 3 Ill' MS. EZELL: 3 it to the lawyers who order it 4 Q. Did you facilitate these acts as well as 4 Do you choose to read or waive? 5 assisting Mr. Epstein in avoiding police detection? 5 THE WITNESS: Waive. 6 MR. REINHART: Same insuuction. 6 MS. EZELL: Thank you. 7 BY MS. EZELL: 7 MR. REINHART: Thank you. Q. Do you know when and by whom the computers a THE VIDEOGRAPHER: Okay, this concludes 9 were removed fiOM the Ei Bt illo mansion? 9 tudivls videotape deposition o The 10 MR. REINHART: Objection to the form, lack of ture is 18:51. foundation. and it also :wanes knowledge ofa tl (Witness excused.) 12 place known as the El Brillo mansion. So instruct 12 (Deposition was concluded.) 13 the witness not to answer the question based on the 13 14 Fifth Amendment. 14 15 THE WITNESS: At the instruetion of my lawyer, 15 16 I must invoke my Fifth Amendment right. 16 1 BY MS. EZELL: 17 12 O. Was Sane No. 11)3 invited to just came and hang 18 19 out at the El Brillo mansion? 19 MR. REINHART: Objection to the form. same as 20 21. the previous question. It assumes knowledge of a 21 22 place known as the El Brillo mansion and a prawn 22 21 by the name of lane No. 103. It is compound and 23 lacking in foundation. 24 23 THE WITNESS. at the instruction of my lawyer. 25 Page 146 rage 4'.8 I must invoke my Fifth Amendment right. 1 CLIt1 1IIE S1.vft.Op FLORIDA BY MS. EZELL: 3 CANTY OF PALM BEACH 3 Q. Have you called any girt.; under the age of IX 4 4 in Palm Beach or \Vest Palm Beach in the last six years? 5 I, Rachel W. Bridge, Registera.1 Professional Reporter. Honda Protlasioral Reporter and Notary 5 MR. REINHART : For any purpose? 6 Public ut sod for the State Of Florida at law, de 6 MS EZELL: Yes. batty catiN Out I was allowed to nag did ropCol 7 .ad deposition in gloomy. and that the Rwegant THE WITNESS: Can you repeat the question? pages mane and coned transcription of my 9 BY MS. EZELL: shorthand notes of said deposibrin. Q. Have you called any girls under the age of 18 9 I Maher atity that tad &roma cos nken at the tone and place heraneborc set bah and 10 in Palm Beach or West Palm Beach in the last six years? IR Ma the taltion af sant depositor vu conimented and MR. REINHART: You can answer that yes or no. anpleted w horemateas on out 11 if you know. l further orally that t ant era attorney or 13 THE WITNESS: I don't think so. coonacl of any of the parties, nos 4113 I a idolise or 14 MS. EZELL: I don't have any other questions. tirolfocc of an) attorney w wand of party connected 13 nab to action, nor an I financially mlereetal m the 15 Thank you. Wien. 1!s THE VIDEOGRAPHF.R; All set? :4 17 MR. REINHART: Yes. the foregang affiliation of this Mutsuc4 15 does not apply to any reprodeohon of the same by any 18 THE VIDEOGRAPHER: This concludes today's mcma unba under the direct coning andror direction 19 vidcvtape dep,asilion of 14.; of the allaying reporter. 17 Dated tint 9th day of April, 20 MR. REINHAR T: I told on, I'm sorry. one last 18 21 thing. Since you're the last defense person or 22 20 plaintiffs lawyer standing. I guess you wed to 21 an. rid e6tiatnR - 23 advise her she has the right to read or waive on 22 2.1 the record. Z sa 25 MS. EZELL- You do have the right to read this ::5 21 (Pages 445 to 443) FROSE COURT REPORT:NG AGENCY, INC. Electronically signed by Rachel Bridge (2014724174827) 905d1499.0cd8-4599-a2a0.6d3.8827668c6 unit i RI 'A'GO.- EFTA01083265