EFTA01723963.pdf

12 1 50 years old? 2 MR.IIIII I'm going to object once 3 again. We are getting way too argumentative 4 with the questioning. The questioning is 5 compound. It is speculative and it is also 6 harassing. Whether or not this deposition 7 video, thereof is played in front of a jury 8 is a question of fact, and it will be 9 determined by a judge pursuant to a motion 10 in limine, various portions thereof may or 11 may not be played, so having placed those 12 objections on the record I'm going to 13 instruct Mr. Epstein not to answer that 14 question. 15 MR. Mr. I don't know if ■ 16 you watched the 13 hours of harassing 17 questions to that she sometimes 18 invoked her Fifth Amendment rights, I 19 understand the adverse advice that would be 20 given and she was made to answer these 21 questions and these exact same questions 22 were asked of her, in fact, I'm using the 23 phraseology from Mr. I'm not • 24 trying to harass him. 25 Q I'm simply asking him to explain to the EFTA01723963  13 1 jury. If you're saying it didn't happen, if 2 you're saying it did happen, explain to the jury 3 why you did it. That's all I want to hear. I'm 4 being respectful about this. S MR. : In an effort to keep a clean 6 record be respectful to the to the court 7 reporter rather than having a diatribe back 8 and forth between you and myself, I'll move 9 to strike your last statement as 10 irrelevant. Let's move on. 11 Q Is it true, Mr. Epstein, you were born 12 January 20, 1953? 13 A Yes. 14 Q Where? 15 A New York. 16 Q Where in New York? 17 A Brooklyn. 18 Q Did you go to high school there? 19 A Yes, sir. 20 Q Where? 21 A Lafayette High School. 22 Q After high school did you attend 23 college? 24 A Yes. 25 Q Where was that? EFTA01723964  14 1 A New York. 2 Q What college did you attend? 3 A Cooper Union. 4 Q Sorry, I didn't hear. 5 A Cooper Union. 6 Q Did you get a degree from Cooper Union? 7 A No, sir. 8 Q How many years were you in college? 9 A I believe, two. 10 Q What did you study? 11 A Physics. 12 Q Why did you leave college early? 13 A I intend to respond to all relevant 14 questions regarding this lawsuit, however, at the 15 present time my attorneys have counseled me that 16 I cannot provide answers to questions that may be 17 relevant to this lawsuit, so accordingly I assert 18 my constitutional rights as guaranteed by the 19 Fifth, Sixth and Fourteenth Amendment. 20 Q Are you invoking your Fifth Amendment 21 rights as to why you left college, is it safe 22 then to presume that that answer you believe 23 would incriminate you in some way? 24 MR. I'm going to move to strike, 25 speculative, argumentative, harassing. EFTA01723965  15 1 Calls for a legal conclusion, and I know 2 exactly what you're trying to do here, Mr. 3 , is lace the record with questions 4 that would ultimately give you an adverse 5 inference at any potential trial of this 6 matter, so having put that on the record, 7 I'm going to instruct him not to answer that 8 question, based upon his Fifth, Sixth and 9 Fourteenth Amendment rights to the United 10 States Constitution. 11 MR. With all due respect you 12 cannot invoke his Fifth Amendment rights, 13 your attorneys instructed me in that fact -- 14 MR. He can. 15 MR. That Had to do it 16 herself, so, I would like to hear it from 17 Mr. Epstein. 18 Q Can we assume you're invoking your Fifth 19 Amendment rights as to why you left college 20 early, that that answer you feel would 21 incriminate you? 22 MR. -: Once again, move to strike 23 for the same reasons. 24 You can answer. 25 A I've already answered the question. EFTA01723966  16 I'll restate the answer. I would like to 2 respond, intend to respond, and would like to 3 respond to all questions today. However, counsel 4 has advised me I must take the Fifth, Sixth and 5 Fourteenth Amendment right under the U.S. 6 Constitution. 7 Q After college where were you employed? 8 A You know, I would like to respond to all 9 your questions today, however, on advice of 10 counsel, I intend to take the Fifth, Sixth and 11 Fourteenth Amendment rights provided by the 12 United States Constitution or risk losing my 13 counsel's representation. 14 Q Isn't it true that you were a teacher at 15 the Dalton School in New York after college? 16 A Again, I would like to respond to all 17 your questions; however, my attorneys have 18 counseled me that I cannot provide answers to any 19 questions today regarding to this lawsuit so I 20 must accept their advice or risk losing my Sixth 21 Amendment right to effective representation. 22 Accordingly, I assert my Constitutional rights as 23 guaranteed by the Fifth, Sixth and Fourteenth 24 Amendment of the constitution. 25 Q Mr. Epstein, did you have sex with any EFTA01723967  17 1 underage students while teaching at the Dalton 2 School? 3 A Could you repeat that? 4 Q Yes. Did you have sex with any underage 5 students while teaching at the Dalton School in 6 New York? 7 A Mr. your firm has been 8 described by the U.S. Attorney as one of the 9 largest -- as a criminal enterprise, perpetrating 10 one of the largest frauds in Florida's history. 11 It has been reported that your firm fabricated 12 multiple cases against me and others in order to 13 fleece unsuspecting investors out of millions and 14 millions of dollars. 15 Unfortunately at this time in response 16 to your question, my attorneys have advised me I 17 must assert my Fifth Amendment, Sixth Amendment 18 and Fourteenth Amendment rights, though I believe 19 you know I would like -- really like to answer 20 your questions but at this time I must assert 21 those rights or have my attorneys resign. 22 MR. Mr. I'll' I think you know 23 he has a couple of options here. He can 24 answer questions or he can invoke his Fifth 25 Amendment rights. This nonresponsive EFTA01723968  18 1 verbiage regarding the RRA law firm is not 2 one of the options, it's inappropriate in 3 the deposition and I would ask you to 4 instruct your client not to obstruct this 5 process any further. I am not going to 6 terminate the deposition. I want it to 7 finish, but obviously this is going to be 8 the subject matter of some motion in the 9 courts and you know the judges will not 10 appreciate this. I would like to just move 11 this process along by eliminating that 12 portion of his answer. I understand what he 13 is saying. I get it, but that's not 14 something responsive to any of the questions 15 and I think you know it is inappropriate. 16 MR. I think the deponent is IM 17 answering the questions. If you believe the 18 responses are inappropriate and feel'you can 19 take it up with the Court with the motion 20 you are speaking of, as you've done then you 21 can, as you've done several times before. 22 Q After leaving the Dalton School, is it 23 true that you began working as a money manager at 24 Bear Stearns? 25 A I intend to respond to all your EFTA01723969  19 1 questions regarding this lawsuit at some relevant 2 time, however, at the present time my attorneys 3 have counseled me that I cannot provide answers 4 to any questions relevant to this lawsuit. Since 5 the U.S. Attorney has described your law firm as 6 a criminal enterprise, Mr. and. a part of 7 the largest fraud in Florida's history, I am 8 going to assert my Sixth Amendment, Fifth 9 Amendment and Fourteenth Amendment rights to the 10 U.S. Constitution. 11 Q Isn't it true that while you were 12 working at Bear Stearns you were already engaging 13 in sex with underage minors? 14 A Again, I believe you know the answers to 15 those questions, but -- 16 Q Yes. 17 A .May I finish? 18 Q I do. 19 MR. : Move to strike. Let the 20 witness -- 21 Q Sure -- 22 MR. IIIII Let the witness answer your 23 question. 24 MR. I would love for him to 25 finish the questions. EFTA01723970  20 1 MR. Mr. as you know 2 there are serious Fifth, Sixth and. 3 Fourteenth Amendment constitutional rights 4 at issue here, and the witness is attempting 5 to answer your questions to the best of his 6 ability, despite how laced they are with 7 adverse inference presumptions. 8 MR. I don't want the adverse 9 inferences. I want the answers, that's it. 10 I don't want the adverse inferences. 11 MR. Having said that, please 12 allow the witness to answer to answer the 13 question. 14 A Can you please repeat the question? 15 Q Isn't it true while working at Bear 16 Stearns you were already engaging in sex with 17 underage minor females? 18 A As your firm has been described by the 19 U.S. Attorney, as a criminal enterprise, using 20 some of the cases fabricated against me, 21 personally, I would like to answer that question 22 today; however, upon advice of counsel I must 23 assert my Fifth, Sixth and Fourteenth Amendment 24 rights under the U.S. Constitution or, in fact, 25 risk losing their representation. EFTA01723971  21 1 Q At some point in time while at Bear 2 Stearns you met and managed the money for a 3 fellow named , correct? 4 A Again, I would like to answer all 5 questions relevant to this lawsuit, but today I 6 must assert my Fifth Amendment, Sixth Amendment 7 and Fourteenth Amendment right to the U.S. 8 Constitution. 9 Q In fact, I read in another deposition of 10 yours that you do not consider yourself to be 11 homosexual, correct? 12 A (No response.) 13 Q You've answered that question before, 14 correct? 15 A Correct. 16 0 Do you consider yourself to be 17 bisexual? 18 A No. 19 Q In any event, you did develop a sexual 20 relationship with at some point in 21 time; is that true? 22 A No. 23 0 Did you have a business relationship 24 with Mr.= 25 A I intend to respond to all relevant EFTA01723972  22 1 questions. I would like to answer most of your 2 questions, Mr. today, however, 3 especially since your firm has been described by 4 the United States Attorney in South Florida as a 5 criminal enterprise purported to -- purported to 6 have put -- pulled off the largest fraud in 7 Florida's history, I would like to answer it, 8 however, my attorneys here today counseled me I 9 must assert my Fifth, Sixth and Fourteenth 10 Amendthent right under the U.S. Constitution, 11 therefore I'm going to do that. 12 Q Are you saying because 13 was determined to be a criminal 14 enterprise or somebody was running a criminal 15 enterprise out of that law firm, that is the 16 reason why you are not going to answer these 17 questions today? You linked that together in 18 that answer. I just want to make sure I'm 19 understanding that right? 20 A I'm going to take the Fifth -- I intend 21 to respond to all relevant questions today. I 22 would like to respond; unfortunately my attorneys 23 have counseled me I can't, I must assert my 24 Fifth, Sixth and Fourteenth Amendment rights 25 under the U.S. Constitution. EFTA01723973  23 1 Q Because other law firms have asked very 2 similar questions and you haven't responded to 3 any of theirs either. I just want to understand 4 what the relationship between 5 is to you invoking your Fifth 6 Amendment rights today, if you can articulate 7 that for me. B MR. Form, compound, 9 argumentative. 10 A has been 11 described by the U.S. Attorney as a criminal 12 enterprise and as part of the largest fraud in 13 Florida's history. It has been reported that 14 your firm fabricated multiple cases using me, and 15 against me in order to fleece unsuspecting 16 investors out of millions of dollars. 17 Q Another long time friend of yours is 18 Ghislaine Maxwell, right? 19 A I intend to respond to all relevant 20 questions. I would like to answer most of these 21 questions today, but I can't because my attorneys 22 have counseled me that I cannot provide answers 23 to any questions relevant to this lawsuit. I 24 must accept their advice or risk losing my Sixth 25 Amendment right to effective representation. EFTA01723974  24 1 Therefore I'll assert my Constitutional 2 rights under the Fifth, Sixth and Fourteenth 3 Amendment. 4 THE WITNESS: Excuse me, could we take a 5 break? 6 MR. Already? 7 THE WITNESS: Restroom. 8 THE VIDEOGRAPHER: Going off the video 9 record 11:38 a.m. 10 THE WITNESS: Thank you. 11 (Pause in the proceedings.) 12 THE VIDEOGRAPHER: We're back on the 13 video record at 11:48 a.m. 14 Q How did you meet Ghislaine Maxwell? 15 A I intend to respond to all relevant 16 questions to this lawsuit; however, at the 17 present time my attorneys have counseled me that 18 I cannot provide answers to any questions 19 relevant to this lawsuit, and must accept this 20 advice or risk losing effective -- my right to 21 effective representation. Accordingly, 22 therefore, I assert my Fifth, Sixth and 23 Fourteenth Amendment rights to the U.S. 24 Constitution. 25 Q You would agree, would you not, that EFTA01723975  25 1 • Ghislaine Maxwell shares your sexual obsession 2 for underage minor females? 3 MR. ■: Argumentative, speculation, 4 harassing. S A You know, Mr. the current U.S. 6 Attorney has described your law firm as a 7 criminal enterprise, and as taking part in one of 8 the largest frauds in Florida's history. It has 9 been widely reported that your firm fabricated 10 multiple cases of a sexual nature against 11 people -- other people and me, in order to fleece 12 unsuspecting investors out of millions of 13 dollars, so unfortunately at this time in 14 response to your questions, my attorneys have 15 advised me I must assert my Sixth Amendment, 16 Fifth Amendment and Fourteenth Amendment rights, 17 though I believe, as you know, I would really 18 like to answer these questions, but at this 19 moment, although at this time I have to assert 20 those rights or risk losing effective counsel. 21 Q Do you know 22 A I intend to respond to all relevant 23 questions regarding this lawsuit; however, at the 24 present time my counsel has advised me that i 25 cannot provide answers to any questions relevant EFTA01723976  26 1 to this lawsuit. Your firm has been described as 2 a criminal enterprise, and is part of the largest 3 fraud in Florida's history fabricating sexual 4 cases against me and others. Therefore, 5 unfortunately, although I would like to answer 6 all of your questions today, I'm going to have:to 7 assert my Fifth, Sixth and Fourteenth Amendment 8 right. 9 Q Did you and Ghislaine Maxwell sexually 10 assault at 's house? 11 A I intend to respond to all relevant 12 questions regarding this lawsuit; however, at the 13 present time my attorneys have counseled me I 14 cannot provide answers to any questions relevant 15 to this lawsuit and must accept this right or 16 risk losing my Sixth Amendment rights to 17 effective presentation. Accordingly, I assert my 18 Constitutional rights as guaranteed by the Fifth, 19 Sixth and Fourteenth amendments to the U.S. 20 Constitution. 21 Q Stating Ghislaine Maxwell and you had 22 devised several schemes to lure underage girls to 23 you for sex; isn't that correct? 24 MR. Form, argumentative, 25 harassing? 7r EFTA01723977  27 1 A Mr. your firm has fabricated 2 multiple cases of sexual harassment claims and 3 other types of sexual cases against me and others 4 in order to be part of what the U.S. Attorney has 5 described as the largest fraud, the largest fraud 6 in Florida's history. I would like to answer all 7 your questions; however, my attorneys have 8 counseled me that at least today, I must assert 9 my Fifth, Sixth and Fourteenth Amendment rights 10 under the U.S. Constitution. 11 Q Do you own a home in Manhattan? 12 A I intend to respond to all relevant 13 questions to this lawsuit; however, at the 14 present time my attorneys have counseled me that 15 I cannot provide answers to any questions 16 relevant to this lawsuit, and I must accept their 17 advice or risk losing my Sixth Amendment right to 18 effective representation. 19 Accordingly, therefore, I have to assert 20 my Fifth, Sixth and Fourteenth Amendment right 21 under the U.S. Constitution. 22 Q Do you own an island in the U.S. Virgin 23 Islands? 24 A I intend to respond to all relevant 25 questions regarding this lawsuit; however, at the EFTA01723978  28 1 present time my attorneys have counseled me that 2 I cannot provide answers to any'questions 3 relevant to this lawsuit, no•matter how much I 4 would like to. 5 Therefore, I must accept their advice or 6 risk losing my Sixth Amendment right to effective 7 representation; therefore, I have to assert my 8 Fifth, Sixth and Fourteenth Amendment right under 9 the U.S. Constitution. 10 Q Do you own a home i•n New Mexico? 11 A I intend to respond to all relevant 12 questions regarding this lawsuit and as I've had 13 to do with most of your questions here today, I'm 14 going to have to take my attorneys' advice and 15 assert my Fifth, Sixth and Fourteenth Amendment 16 right under the U.S. Constitution or risk losing 17 effective representation. 18 Q Is it true that you have had underage 19 females, at each of those homes, for orgies with 20 you and Ghislaine Maxwell? 21 MR. : Form, argumentative, 22 speculation and harassing. 23 A I would like to answer that question. 24 really would. However, as your firm has been 25 described by the U.S. Attorney as a criminal EFTA01723979  29 1 enterprise, which its principal purpose was 2 racketeering conspiracy to generate money for the 3 firm and its co-conspiritors through the 4 operation of enterprise and through various 5 activities including mail fraud, wire fraud and 6 money laundering, and fabricating multiple sex 7 cases against me and others, though I would like 8 to answer your question today, Mr. my 9 counsel has advised me I must take the Fifth, 10 Sixth and Fourteenth Amendment right provided by 11 the U.S. Constitution. 12 Q Do you know somebody named 13 (phonetic)? 14 MR. PIKE: Can you spell that, for the 15 record? 16 MR. No. 17 MR. PIKE: Or for the court reporter? 18 A No. 19 Q You don't know the name? 20 A No. Could you spell it? 21 Q (Witness shrugs.) 22 A Okay. 23 Q Did your sexual obsession with underage 24 minor females grow at some point in time to allow 25 you access to these underage minors every single EFTA01723980  30 1 day for sex? 2 MR. : Overbroad. Speculation, 3 argumentative, compound, harassing and 4 confusing as well; as worded. Do you want 5 to break it down, Mr. 6 Q Isn't it true that for the past ten 7 years you have found a way to engage in sexual 8 conduct with underage minors on an every day 9 basis? 10 MR. Speculation. Argumentative. 11 A As your firm has been described as a 12 criminal enterprise by the United States Attorney 13 and is part of the scheme to defraud people in 14 South Florida of millions of dollars, you have 15 fabricated sexual cases and sexual claims against 16 people like me and others. Unfortunately at this 17 time although I would like to answer your 18 questions, Mr. my counsel has advised me 19 I cannot. They have advised me I must assert my 20 Fifth, Sixth and Fourteenth Amendment rights 21 under the U.S. Constitution. 22 Q Isn't it true that you have promised 23 underage minors money or other benefits to engage 24 in sexual conduct with you over the past ten 25 years? EFTA01723981  31 1 A Again, as. I've answered many of your 2 questions today, and unfortunately will probably 3 end up not answering most of your questions 4 today, as your firm has been described, the firm 5 bringing this lawsuit, I believe, if I'm wrong 6 please, correct me -- 7 Q You're wrong. 8 A This is the firm that didn't notice this 9 deposition? 10 Q Did not? 11 A Did not? 12 Q No. 13 A I apologize. Though your former firm 14 has been described, and the person you represent, 15 , in this case was represented by the firm 16 that was described by the U.S. Attorney as 17 perpetrating one of the largest frauds in South 18 Florida's history, fabricating multiple sexual 19 cases against me and others in order to fleece 20 unsuspecting investors out of millions and 21 millions of dollars, so though unfortunately, I 22 would like to answer each one of your questions 23 today, my counsel has advised me I must assert my 24 Sixth Amendment, Fourteenth Amendment and Fifth 25 Amendment right, though I believe you know, I EFTA01723982 7- • 32 1 would like to answer those questions, though at 2 this moment I must assert those rights or risk 3 losing my attorneys. 4 Q Sure, let's test that answer. 5 A Okay. 6 Q Let's talk about Jane Doe 102, Jane Doe 7 102, , who was represented by 8 s firm, had nothing to do with 9 Rothstein, Rosenfeld, Adler. Do you know 10 A Who? 11 12 A Can you spell it? 13 Q Common spelling, like the 14 State -- 15 A Can you spell it for me, please? 16 17 A What's the last name, how is it 18 spelled? 19 Q I believe. 20 • A I intend to respond to all relevant 21 questions regarding this lawsuit; however, at the 22 present time my attorneys have counseled me that 23 I cannot provide answers to any questions that 24 may be relevant to this lawsuit and I must accept 25 this advice or risk losing my Sixth Amendment EFTA01723983  33 1 right to effective representation. Accordingly, 2 I assert my Constitutional rights as guaranteed 3 by the Fifth, Sixth and Fourteenth Amendment to 4 the Constitution. 5 Q Just for the record, I can only spell it 6 the way it was spelled in your flight logs from 7 your airplane. I don't know exactly how she 8 spells her name, only how your pilot would spell 9 her name. 10 MR. Form, speculating. 11 Q If I misspell it -- 12 MR. a Form, speculation, 13 argumentative, harassing. 14 MR. That's harassing? 15 MR. It assumes facts currently 16 not in evidence in this particular 17 deposition; therefore, I move to strike. 18 MR. I was responding to his 19 question asking me how to spell her name. I 20 don't know how other than his own pilot. 21 MR. Mr. he asked you to 22 spell the name, you then spelled the name, 23 then went on with another narrative and 24 there wasn't a question posed, on the floor. 25 Q You would agree you interacted with EFTA01723984  34 1 every day in a sexual way, when she was 15 years 2 old, right? 3 A Again, I'm sorry? 4 Q Sure. You would agree that you 5 interacted with sexually on an every day 6 basis when she was 15 years old? 7 A You know, again, Mr. I would 8 like to answer all your questions here today. My 9 attorneys have asked me -- advised me that I must 10 assert my Sixth Amendment, Fourteenth Amendment 11 and Fifth Amendment rights provided by the U.S. 12 Constitution and the fact that the current U.S. 13 Attorney has described your law firm as a 14 criminal enterprise, is one of the largest frauds 15 in Florida's history for fabricating sexual -- 16 cases of a sexual nature against me and others. 17 Unfortunately, although I would like to answer 18 those questions, if I do I risk losing my 19 attorneys' counsel. Therefore, I must assert my 20 right. 21 MR. Madam court reporter, I'll 22 attach as an exhibit, the Jane Doe number 23 102 versus Jeffrey Epstein complaint, at ' 24 some point in time. It will be Exhibit 1, 25 as I'm going to go through some of the facts EFTA01723985  35 1 as alleged in the complaint and as will be 2 testified to by the plaintiff. 3 (Jane Doe number 102 versus Jeffrey 4 Epstein complaint was deemed marked as 5 Exhibit number 1 for identification, as of 6 this date.) 7 MR. : Counsel, do you have an extra 8 copy of that for me? 9 MR. No. 10 May I look at it real quick? MR. IIIII 11 MR. No. It has my notes on 12 it. 13 MR. I understood, I saw the 14 highlights. 15 MR. The notes are highlighted 16 so when we copy it, it will not show up. 17 MR. ■: Just for the record, that's a 18 current, operative pleading, correct? 19 MR. Correct. 20 THE WITNESS: What does that mean? 21 MR.M There may have been some 22 amendments to a complaint and I want to make 23 sure that's the operative complaint at issue 24 that he is speaking of today. 25 THE WITNESS: Can I go off the record EFTA01723986  36 1 for a second? 2 May I ask you a question? 3 MR. Sure. Can we take a break 4 for a second? 5 MR. Again? 6 THE WITNESS: Just a question. 7 MR. He wants to speak with me for 8 a second. 9 THE VIDEOGRAPHER: Off the video record 10 12:01 p.m. 11 (Pause in the proceedings.) 12 THE VIDEOGRAPHER: We are back on the 13 video record at 12:02 p.m. 14 Q Is it true, Mr. Epstein, that you and 15 Ghislaine Maxwell forced to have sex with 16 you on a daily basis? 17 Form, argumentative, MR. Ill" 18 harassing. 19 A Unfortunately at this time, though I 20 would really like to answer those questions, and 21 like I have done for most of your questions here 22 today, Mr. your firm was described as a 23 criminal enterprise, a serious criminal 24 enterprise by the current U.S. Attorney. Part of 25 that criminal enterprise was fabricating cases of EFTA01723987  37 1 a sexual nature against me and others in order to 2 fleece unsuspecting investors out of millions of 3 dollars. Though, unfortunately at this time no 4 matter how I would like to respond to your 5 questions, I must assert my Sixth Amendment, 6 Fifth Amendment and Fourteenth Amendment rights 7 under the U.S. Constitution or risk having my 8 attorneys resign. 9 Q Isn't it true that was yours and 10 Ghislaine Maxwell's sex slave from the time she 11 was 15 through the time she escaped when she was 12 -. 19? 13 MR. Again objection, 14 argumentative, harassing. 15 A Mr. your firm has been 16 described as excuse me, as a criminal 17 enterprise by the current U.S. Attorney and part 18 of the largest fraud in Florida's history. Part 19 of that fraud was fabricating multiple cases 20 against people like me and others, of a sexual 21 nature, in order to fleece unsuspecting investors 22 out of millions and millions of dollars, so 23 though I would like to answer that question, my 24 attorneys have told me today I mist assert my 25 Sixth Amendment, Fourteenth Amendment and Fifth EFTA01723988  • 38 Amendment right. 2 Q Isn't it true that you and Ghislaine 3 Maxwell celebrated her 16th birthday with her and 4 had sex with her on that day? 5 MR.M Form. Compound, confusing, 6 argumentative, harassing. 7 A Mr. I would like to answer that 8 question. My attorneys have told me today, I 9 have to at least today assert my Fifth Amendment, 10 Sixth Amendment and Fourteenth Amendment rights • 11 to the U.S. Constitution, especially my concern 12 is, that your firm has filed fraudulent lawsuits, 13 fabricated lawsuits, and the U.S. Attorney, the 14 current U.S. Attorney has described your firm as 15 a criminal enterprise that -- whose main purpose 16 was to generate money for the firm and its 17 co-conspirators through the operation of various 18 criminal activities, including mail fraud, wire 19 fraud and money laundering. 20 Q Are you saying that the complaint of 21 L.M. against you, the allegation in that 22 complaint, are false? 23 MR. Form. Misinterprets the 24 witness's testimony. 25 Q Or saying it is true? EFTA01723989  39 1 MR. Same objection. 2 Q It is either true or false? 3 A . I'll repeat myself, unfortunately, but 4 the current V.S. Attorney has described your law 5 firm that filed that filed L.M.'s claim -- was 6 involved in the filing of L.M.'s claim, 7 motions -- I'm sorry, do you want to tell me what 8 it was then? Would you like to tell me the 9 firm's involvement in this lawsuit, since we will 10 be here the rest of the,day? 11 Q Answer the question. 12 A All right. 13 The U.S. Attorney has described that 14 firm as a criminal enterprise perpetrating one of 15 the largest frauds in Florida's history against 16 unsuspecting investors, fleecing them out of 17 millions of dollars by creating, crafting and 18 fabricating fellacious (sic) sexual claims 19 against people like me and others, so 20 unfortunately, though I would like to answer your 21 questions, Mr. my counsel has advised me 22 that at least today I must assert my Sixth 23 Amendment, Fifth Amendment and Fourteenth 24 Amendment rights under the U.S. Constitution. 25 Q Isn't it true, sir, and I'm reading from EFTA01723990  • 40 1 the complaint filed billillagainst you, isn't it 2 true, sir, that a friend of yours sent you three, 3 12-year old females for you to sexually abuse on 4 one of your birthdays? 5 Form, argumentative, MR. 6 harassing, and irrelevant to this lawsuit. 7 THE WITNESS: Excuse me. 8 A You're saying it is part of the 9 lawsuit? 10 Q Yes, I'll read it. 11 "On one of the defendant Epstein's 12 birthdays, a friend of defendant Epstein sent him 13 three, 12-year old girls from France who spoke no 14 English for defendant to sexually exploit and 15 abuse? After doing so they were sent back to 16 France the next day." 17 Isn't that true? 18 MR. III. Once again, move to strike, 19 irrelevant, argumentative, harassing, and 20 for the record, the exhibit that's being 21 read from is a complaint that's unrelated to 22 the instant matter and not filed or 23 incorporated by the current plaintiff, L.M., 24 in this matter. 25 A I would like to answer that question, I EFTA01723991  41 1 really would; however, today my attorneys have 2 told me I have to assert my Fifth Amendment, 3 Sixth Amendment and Fourteenth Amendment rights 4 of the U.S. Constitution, especially because your 5 firm involved in this lawsuit has fabricated, 6 widely reported, multiple cases of sexual 7 harassment cases against individuals like me and 8 others, perpetrating what the U.S. Attorney 9 called one of the largest frauds in Florida's 10 history, fleecing people out of millions of 11 dollars, so though I would like to answer that 12 question, today I have to assert those rights or 13 risk losing my attorneys' counsel. 14 Q Isn't it true that you forced as a 15 15-year old girl to have sex with numerous 16 friends of yours? 17 A Are you kidding? 18 Q Reading from a lawsuit. 19 A Sorry, Mr. Though I would like 20 to answer that question as well, as I've answered 21 most of your other questions here today, I would 22 like to respond; however, my attorneys here today 23 have advised me I have to assert my Fifth 24 Amendment, Sixth Amendment and Fourteenth 25 Amendment rights under the U.S. Constitution, EFTA01723992  42 1 especially as your firm has been accused by the 2 U.S. Attorney as being a criminal enterprise, and 3 part of the largest fraud in Florida's history. 4 Basically -- sorry, if I didn't read correctly, 5 the operation of the enterprise through 6 various criminal activities including mail fraud, 7 wire fraud and money laundering, fabricating 8 sexual harassment cases against people like me 9 and others. 10 Q By the way -- 11 A Yes, sir? 12 Q -- didn't receive a round trip 13 ticket paid for by you to Thailand, and she 14 ultimately did not get back on the plane but 15 instead escaped to Australia? 16 A I would like to answer that question, 17 but today I would have to assert my Sixth 18 Amendment rights, my Fifth Amendment rights and 19 my Fourteenth Amendment rights under the U.S. 20 Constitution, especially since your firm has been 21 described as perpetrating one of the largest 22 frauds in Florida's history, fleecing investors 23 out of millions of dollars, being described by 24 the U.S. Attorney of South Florida, as a criminal 25 enterprise engaged in various criminal activities EFTA01723993  43 1 including mail fraud, wire fraud and money 2 laundering. 3 Q Do you know a man named. Jean Luc 4 Brunel? 5 A Can you spell it? 6 Q He was at your house last week, does 7 that remind you? 8 MR. Form, move to strike, 9 speculation, argumentative, harassing. 10 Is there a question on the table, Mr. 11 12 MR. Yes. 13 Q Do you know him? 14 A Can you spell his name for me, please? 15 Q I don't need to spell his name Do you 16 know who I'm talking about, Mr. Brunel? 17 A Sorry, Mr. what? 18 Q B-r-u-n-e-l. 19 A I would like to answer that question as 20 well, but my attorneys have counseled me today I 21 have to assert my Sixth Amendment rights, Fifth 22 Amendment rights and Fourteenth Amendment rights 23 under the U.S. Constitution or risk losing my 24 right to effective representation. 25 Q What's the purpose for you asking me to EFTA01723994  44 1 spell his name? Are you acting like you don't 2 know him? 3 MR. : Form, move to strike, 4 argumentative and irrelevant as worded. 5 Mr. you know that there are 6 various standing orders, if not in this 7 case, in various other cases, that 8 specifically describe the protections of the 9 Fifth Amendment. Federal Courts have 10 ordered that certain questions that you are 11 asking shall not be answered or Mr. Epstein 12 would risk losing his Fifth Amendment 13 right -- 14 MR. I understand that. He is 15 asking to spell people's names. 16 MR. -- under the United States 17 Constitution. A lot of these questions here 18 today that you're asking have already been 19 ruled on by various Courts, that the Fifth 20 Amendment protects any response thereto, so 21 I would like -- I'm giving you some leeway 22 here with regard to the argumentative 23 questions. We've already -- and I'm not 24 obviously testifying for the witness, but 25 we've already handled a lot of these issues EFTA01723995  45 4.I 1 in court and we have already adjourned one 2 deposition for being argumentative, and I 3 think you understand what the Court said 4 there, so having said that, and I understand 5 that you have a job to do, but having said 6 that, I would like to caution you 7 professionally, if you continue with the 8 argumentative questions, I am going to have 9 to terminate this deposition -- 10 MR. I completely understand. 11 MR. Okay. We are here today 12 to -- 13 MR. Mr. Brunel -- 14 MR. I want the Court to know we 15 are here today to allow you to ask your 16 questions, but the harassing and 17 argumentative tone is not going to be 18 tolerated. 19 MR. We have a video. We can 20 show the Court the tone. It is obviously 21 not harassing. 22 MR. That's fine. 23 Q Mr. is a long-term friend of 24 yours, right? 25 A I intend to respond to all relevant EFTA01723996  46 1 questions of this lawsuit; however, today my 2 attorneys have counseled me I cannot provide , 3 answers to any questions that may be relevant to 4 this lawsuit and I must accept their advice or 5 risk losing my Sixth Amendment right to effective 6 representation. 7 Q You know him as somebody who has been 8 caught engaging in sex with underage minors in 9 the past; is that correct? 10 MR. Form. 11 A You will have to repeat the question, 12 I'm sorry. 13 Q You know Mr. as somebody who has 14 been caught engaging in sex with minors in the 15 past; is that correct? 16 MR. Form. 17 A I intend to respond to all relevant 18 questions regarding this lawsuit; however, at the 19 present time my attorneys have counseled me that 20 I cannot provide answers to any questions 21 relevant to this lawsuit, and I must accept their 22 advice or risk losing my Sixth Amendment right to 23 effective representation as your firm has been 24 described by the U.S. Attorney as a criminal 25 enterprise and part of one of the largest frauds EFTA01723997  47 1 in Florida's history specifically said you have 2 been fabricating -- the law firm has been 3 fabricating multiple cases of a sexual nature in 4 order to fleece unsuspecting investors out of 5 millions of dollars, including mail fraud, wire 6 fraud and money laundering, so unfortunately, 7 though I would like to answer all your questions 8 here today, I must assert my Sixth Amendment, 9 Fourteenth Amendment and Fifth Amendment right. 10 Q You were involved in a modeling business 11 with him called is that correct? 12 A Again? 13 Q You were involved in a modeling agency 14 with -- 15 A What do you mean -- 16 Q -- with Mr. called 17 A "Involved" means what, what do you 18 mean? 19 Q You tell the jury your involvement with 20 the modeling agency. You can clarify for me, 21 I'll let you do that. 22 MR. : Object to the form. 23 A I intend to respond to all relevant 24 questions regarding this lawsuit. However, at 25 the present time my attorneys have counseled me EFTA01723998  48 1 that I cannot provide answers to any questions 2 relevant to this lawsuit and I must accept their 3 advice or risk losing my Fifth, Sixth and 4 Fourteenth Amendment rights under the U.S. 5 Constitution. 6 Q When you were being criminally 7 investigated and was in Australia, is it 8 true that you made a personal telephone call to 9 her telling her not to come forward with any of 10 the information she knew? 11 MR. I= Form. 12 A Again? 13 Q Putting a time frame on it, the time 14 frame where you were being criminally 15 investigated -- 16 A What time frame is that? 17 Q In her complaint it is not specific, 18 but, let's just make it whenever. At some point 19 in time did you place a telephone call to in 20 Australia warning her not to come forward with 21 any information about you engaging in sex with 22 her while she was a minor? 23 MR. Form. 24 A I intend to respond to all relevant 25 questions regarding this lawsuit; however, at the EFTA01723999  49 1 present time my attorneys have counseled me that 2 I cannot provide answers to any questions 3 relevant to this lawsuit and I must accept their 4 advice or risk losing my Sixth Amendment right to 5 effective representation. 6 Q With respect to underage females, isn't 7 it true t