EFTA01158588.pdf
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0172
1 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
2
CASE No. 502008CA037319XXXXMB AB
3
4
5 =-1
6 Plaintiff,
7
- Vs-
9 JEFFREY EPSTEIN,
10 Defendant.
11
12
13 CONTINUED DEPOSITION OF JEFFREY EPSTEIN
14 VOLUME III
15
16 Thursday, October 8, 2009
17
18 1:46 - 3:48 p.m.
19
20 250 South Australian Avenue
Suite 1400
21 West Palm Beach,Florida 33401
22
23 Reported By:
Jeana Ricciuti, RPR, FPR, CLR
24 Notary Public, State of Florida
Prose Court Reporting Agency, Inc.
25
0173
1 APPEARANCES:
2 On behalf of the Plaintiff:
SPENCER T. KUVIN, ESQUIRE
3 ADAM LANGINO, ESQUIRE
LEOPOLD KUVIN, P.A.
4 2295 PGA Boulevard
Suite 200
5 Palm Beach Gardens, Florida 33410
Phone:
6
On behalf of §§§. and III. and Jane Doe in Case No.
7 80893:
CARA L. HOLMES, ESQUIRE
8 ROTHSTEIN, ROSENFELDT & ADLER
401 East Las Olas Boulevard
9 Suite 1650
Fort Lauderdale, Florida 33301
10 Phone:
11 On behalf of Plaintiff Jane Doe in Case No. 80591 and
80656 via telephone:
12 KATHERINE W. EZELL, ESQUIRE
PODHURST ORSECK, P.A.
13 25 West Flagler Street
Miami, Florida 33130
14 Phone:
15 On behalf of the Defendant:
JACK GOLDBERGER, ESQUIRE
16 STORY KOWLES, PARALEGAL
ATTERBURY, GOLDBERGER & WEISS, P.A.
EFTA01158588
17 250 South Australian Avenue
Suite 1400
18 West Palm Beach, Florida 33401
Phone:
19
MICHAEL J. PIKE, ESQUIRE
20 BURMAN, CRITTON, LUTTIER & COLEMAN, P.A.
303 Banyan Boulevard
21 Suite 400
West Palm Beach, Florida 33401
22 Phone:
23 ALSO PRESENT:
24 DAN DOSKEY, VIDEOGRAPHER
VISUAL EVIDENCE, INC.
25
0174
1
EXHIBITS
2
3 WITNESS: CONT'D DIRECT
4 JEFFREY EPSTEIN
5 BY MR. KUVIN 175
6
7
8
EXHIBITS
9 - - - -
10 NUMBER DESCRIPTION PAGE
11 PLAINTIFF'S EX. 9 PHOTOGRAPH OF GHISLAINE 182
MAXWELL
12 PLAINTIFF'S EX. 10 PHOTOGRAPH OF JOANNA 191
SHOGERT
13 PLAINTIFF'S EX. 11 PHOTOGRAPH OF EULA MAXWELL 196
PLAINTIFF'S EX. 12 PHOTOGRAPH 198
14 PLAINTIFF'S EX. 13 PHOTOGRAPH OF 199
PLAINTIFF'S EX. 14 PHOTOGRAPH OF
PLAINTIFF'S EX. 15 PHOTOGRAPH OF 201
16 PLAINTIFF'S EX. 16 PHOTOGRAPH OF PRINCE 201
ANDREW
17 PLAINTIFF'S EX. 17 LETTER TO B. KRISCHER FROM 203
M. REITER
18 PLAINTIFF'S EX. 18 RECEIPT OF PURCHASES MADE 206
FROM JAIL
19 PLAINTIFF'S EX. 19 FAA REGISTRY 218
20
21
22
23
24
25
0175
1 PROCEEDINGS
2 - - -
3 THE VIDEOGRAPHER: We're back on the record at
4 1:46.
5 CONTINUED DIRECT EXAMINATION
6 BY MR. KUVIN:
7 Q. Do you personally know John Mack, former CEO
8 at Morgan Stanley?
9 A. I'll have to answer that the same way I've
10 answered most of your questions here today, Mr. Kuvin,
11 which is, I intend to respond to all relevant questions
EFTA01158589
12 regarding this lawsuit; however, at the present time, my
13 attorneys have counseled me I cannot provide answers to
14 any questions relevant to this lawsuit. I must accept
15 this advice or risk losing my 6th Amendment right to
16 effective representation. Accordingly, I assert my
17 federal constitutional rights as guaranteed by the 5th,
18 6th and 14th Amendment to the United States
19 Constitution.
20 MR. KUVIN: Okay. Same deposition as shown
21 before, different clip. I'm going to play it for
22 counsel first.
23 MR. PIKE: Thank you.
24 MR. KUVIN: Mr. Videographer, just let me know
25 when you're ready.
0176
1 THE VIDEOGRAPHER: Whenever you are.
2 MR. KUVIN: Okay.
3 (Video played.)
4 VIDEO WITNESS: "What did I do to Jeffrey and
5 what did Jeffrey do to me? I went up there
6 multiple times; I can't count. And I would be on a
7 massage table, massaging his legs, he would turn
8 over, his penis would be hanging out. He would put
9 a vagina -- or a vibrator to my vagina. He would
10 touch my vagina with his fingers. He would touch
11 my breasts. He would try to kiss my mouth. He
12 would bring my hands toward his penis."
13 (Video stopped.)
14 MR. KUVIN: Okay.
15 MR. PIKE: I'm just going to object to the use
16 of the video as to relevance, predicate and
17 foundation.
18 BY MR. KUVIN:
19 Q. All right. Let me get it back to the same
20 location.
21 Sir, first of all, once again, just so I can
22 lay the foundation for this, do you recognize this girl?
23 A. I'm going to have to respond to that question
24 the same way I've responded to most of your other
25 questions here today, which is, I intend to respond to
0177
1 all relevant cannot provide answers to any questions
2 relevant to this lawsuit; however, at the present time,
3 my attorneys have counseled me I cannot provide answers
4 to any questions relevant to the lawsuit. I must accept
5 this advice or risk losing my 6th Amendment right to
6 effective representation. Accordingly, I assert my
7 federal constitutional rights as guaranteed by the 5th,
a 6th and 14th Amendment to the United States
9 Constitution.
10 Q. Did this girl bring §§§. to your home for a
11 naked massage?
12 A. I'm going to have to respond to that the same
13 way I've responded to most of your other questions here
14 today, which is, I intend to respond to all relevant
15 questions regarding this lawsuit; however, at the
16 present time, my attorneys have counseled me I cannot
17 provide answers to any questions that may be relevant to
18 the lawsuit. I must accept this advice or risk losing
19 my 6th Amendment right to effective representation.
20 Accordingly, I assert my federal constitutional rights
21 as guaranteed by the 5th, 6th and 14th Amendment to the
22 United States Constitution.
EFTA01158590
23 Q. I'd like to play this clip for you and then
24 I'm going to ask you a question.
25 MR. PIKE: The same clip you just played?
0178
1 MR. KUVIN: Exactly.
2 MR. PIKE: Same objection.
3 (Video played.)
4 VIDEO WITNESS: "What did I do to Jeffrey and
5 what did Jeffrey do to me? I went out there
6 multiple times; I can't count. And I would be on a
7 massage table, massaging his legs. He would turn
8 over, his penis would be hanging out. He would put
9 a vagina -- or vibrator to my vagina. He would
10 touch my vagina with his fingers. He would touch
11 my breasts. He would try to kiss my mouth. He
12 would bring my hands toward his penis."
13 (Video stopped.)
14 BY MR. KUVIN:
15 Q. Did you do that with that girl?
16 MR. PIKE: Form.
17 THE WITNESS: I intend to respond to all
18 relevant questions regarding this lawsuit; however,
19 at the present time, my attorneys have counseled me
20 I cannot provide answers to any questions that may
21 be relevant to this lawsuit. I must accept this
22 advice or risk losing my 6th Amendment right to
23 effective representation. Accordingly, I must
24 assert my federal constitutional rights as
25 guaranteed by the 5th, 6th and 14th Amendment to
0179
1 the United States Constitution.
2 BY MR. KUVIN:
3 Q. Did you do what that young lady described just
4 now to hundreds of women, including III.?
5 MR. PIKE: Form, argumentative, harassing,
6 lacks appropriate predicate, foundation, lacks
7 identity.
8 THE WITNESS: Excuse me. I'm going to respond
9 to that the same way I've responded to most of your
10 other questions here today, which is, I intend to
11 respond to all relevant questions regarding this
12 lawsuit; however, at the present time, my attorneys
13 have counseled me that I cannot provide answers to
14 any questions relevant to the lawsuit. I must
15 accept their advice or risk losing my 6th Amendment
16 right to effective representation. Accordingly, I
17 must assert my federal constitutional rights as
18 guaranteed by the 5th, 6th and 14th Amendment to
19 the United States Constitution.
20 BY MR. KUVIN:
21 Q. While §§§. was standing naked in your home,
22 specifically in your bathroom, did you tell her that you
23 could get her an interview as a model because of your
24 connections?
25 A. I'm going respond to that the same way I've
0180
1 responded to most of your questions today, Spencer. I
2 intend to respond to all relevant questions regarding
3 this lawsuit; however, at the present time, my attorneys
4 have counseled me I cannot provide answers to any
5 questions that may be relevant to the lawsuit. I must
6 accept this advice or risk losing my 6th Amendment right
7 to effective representation. Accordingly, I must assert
EFTA01158591
8 my federal constitutional right as guaranteed by the
9 5th, 6th and 14th Amendment to the United States
10 Constitution.
11 MR. PIKE: Same objection to that line of
12 questioning.
13 BY MR. KUVIN:
14 Q. As §§§. was standing naked in your bathroom
15 before you when she was 15, did you ask her to turn
16 around so you could see her ass better?
17 MR. PIKE: Form, argumentative, harassing,
18 lacks appropriate predicate, foundation.
19 THE WITNESS: I'll respond to that as I
20 responded to your last question, which is, I intend
21 to respond to all relevant questions regarding this
22 lawsuit; however, at the present time, my attorneys
23 have counseled me I cannot provide answers to any
24 questions that may be relevant to this lawsuit. I
25 must accept their advice or risk losing my 6th
0181
1 Amendment right to effective representation;
2 therefore, I must assert my federal constitutional
3 rights as guaranteed by the 5th, 6th and 14th
4 Amendment to the United States Constitution.
5 BY MR. KUVIN:
6 Q. When III. was 15 years old and standing naked
7 in front of you in your bathroom, did you tell her that
8 you could help her become a model?
9 MR. PIKE: Same objections, including
10 foundation.
11 THE WITNESS: Is it different than the last
12 question?
13 MR. KUVIN: Uh-huh.
14 MR. GOLDBERGER: Just go ahead.
15 THE WITNESS: Okay. I intend to respond to
16 all relevant questions pertaining to this lawsuit;
17 however, at the present time, my attorneys have
18 counseled me I cannot provide answers to any
19 questions that may be relevant to this lawsuit, so
20 I've answered most questions here today the same
21 way. I must expect that -- accept their advice or
22 risk losing my 6th Amendment right to effective
23 representation. Accordingly, I assert my federal
24 constitutional rights as guaranteed by the 5th, 6th
25 and 14th Amendment to the United States
0182
1 Constitution.
2 BY MR. KUVIN:
3 Q. Who is Ghislaine Maxwell?
4 A. I intend to respond to all relevant questions
5 regarding this lawsuit; however, at the present time, my
6 attorneys have counseled me that I cannot provide
7 answers to any questions relevant to this lawsuit. As I
8 have done to most of your other questions here today, I
9 must accept their advice or risk losing my 6th Amendment
10 right to effective representation. Accordingly, I
11 assert my federal constitutional rights as guaranteed by
12 the 5th, 6th and 14th Amendment to the United States
13 Constitution.
14 MR. KUVIN: Let me show the camera what we'll
15 mark as Exhibit 9 to this deposition.
16 THE VIDEOGRAPHER: Okay.
17 (Plaintiff's Exhibit No. 9 was marked for
18 identification.)
EFTA01158592
19 BY MR. KUVIN:
20 Q. Let me show you what we've marked as Exhibit 9
21 to your deposition. Do you recognize Ghislaine Maxwell
22 in this photograph?
23 A. Yes.
24 Q. And who is she standing with?
25 A. Her father.
0183
1 Q. And her father is Robert Maxwell?
2 A. Was Robert Maxwell.
3 Q. I'm sorry, he's passed, correct?
4 A. Correct.
5 Q. She is a close friend of yours, is she not?
6 A. I'm going to respond to that question the same
7 way I've responded to most of your other questions here
8 today, Mr. Kuvin, which is, I intend to respond to all
9 relevant questions regarding to this lawsuit; however,
10 at the present time, my attorneys have counseled me I
11 cannot provide answers to any questions that may be
12 relevant to this lawsuit. I must expect -- accept their
13 advice or risk losing my 6th Amendment right to
14 effective representation. Accordingly, I must assert my
15 federal constitutional rights as guaranteed by the 5th,
16 6th and 14th Amendment to the United States
17 Constitution.
18 Q. Ghislaine Maxwell has accompanied you to
19 numerous social events in the last few years; isn't that
20 true?
21 MR. PIKE: Form.
22 THE WITNESS: I'm going to respond to that
23 question the same way I've responded to most of
24 your questions here today, which is, I intend to
25 respond to all relevant questions regarding your
0184
1 lawsuit; however, at the present time, my attorneys
2 have counseled me I cannot provide answers to any
3 questions that may be relevant to that lawsuit. I
4 must accept their advice or risk losing my 6th
5 Amendment right to effective representation.
6 Accordingly, I must assert my federal
7 constitutional right as guaranteed by the 5th, 6th
8 and 14th Amendment of the United States
9 Constitution.
10 BY MR. KUVIN:
11 Q. One of your houseboys that has been deposed in
12 this case testified that you were a rather nice
13 gentleman that used to talk to the staff, and that when
14 Ms. Maxwell came into the picture, that you stopped
15 talking to the staff and the staff had to communicate
16 through Ms. Maxwell. Do you agree or disagree with
17 that?
18 MR. PIKE: Form, foundation, predicate,
19 argumentative, assumes facts not in evidence.
20 THE WITNESS: I'm going to answer that the
21 same way I've answered most of your questions here
22 today, which is, I intend to respond to all
23 relevant questions regarding this lawsuit; however,
24 at the present time, my attorneys have counseled me
25 that I cannot provide answers to any questions that
0185
1 may be relevant to your lawsuit. I must accept
2 their advice or risk losing my 6th Amendment right
3 to effective representation. Accordingly, I assert
EFTA01158593
4 my federal constitutional rights as guaranteed by
5 the 5th, 6th and 14th Amendment of the United
6 States Constitution.
7 BY MR. KUVIN:
8 Q. He also testified that he felt you were a
9 rather normal guy until Ms. Maxwell came into the
10 picture, and that she led you into this life of
11 perversion, sexual perversion. Do you agree with that?
12 MR. PIKE: Same objections.
13 THE WITNESS: I'm going to respond to that the
14 same way I've responded to most of your questions
15 here today, Mr. Kuvin, which is, I intend to
16 respond to all relevant questions regarding this
17 lawsuit; however, at the present time, my attorneys
18 have counseled me I cannot provide answers to any
19 questions relevant to this lawsuit. I must accept
20 their advice or risk losing my 6th Amendment --
21 excuse me -- I must accept their advice or risk
22 losing my 6th Amendment right to effective
23 representation. Accordingly, I must assert my
24 federal constitutional rights as guaranteed by the
25 5th, 6th and 14th Amendment to the United States
0186
1 Constitution.
2 BY MR. KUVIN:
3 Q. Did Ms. Maxwell procure underaged girls for
4 you to have sexual relationships with?
5 A. I'm going to answer that question the same way
6 I've answered most of your other questions today,
7 Mr. Kuvin, which is, I intend to respond to all relevant
8 questions regarding this lawsuit; however, at the
9 present time, my attorneys have counseled me I cannot
10 provide answers to any questions relevant to that
11 lawsuit. Excuse me. I must accept their advice or risk
12 losing my 6th Amendment right to effective
13 representation. Accordingly, I must assert my federal
14 constitutional rights as guaranteed -- guaranteed by the
15 5th, 6th and 14th Amendments to the United States
16 Constitution.
17 Q. Ms. Maxwell procured a particular underaged
18 girl who worked at Donald Trump's Maralago, for you to
19 have a sexual relationship with; isn't that true?
20 MR. PIKE: Form, argumentative, lacks
21 appropriate predicate, foundation, assumes facts
22 not in evidence.
23 THE WITNESS: I'm going to respond to that the
24 same way I've responded to most of your other
25 questions here today, Mr. Kuvin, which is, I intend
0187
1 to respond to all relevant questions regarding this
2 lawsuit; however, at the present time, my attorneys
3 have counseled me I cannot provide answers to any
4 questions relevant to that lawsuit. I must accept
5 their advice or risk losing my 6th Amendment right
6 to effective representation. Therefore, I assert
7 my federal constitutional rights as guaranteed by
8 the 5th, 6th and 14th Amendments to the United
9 States Constitution.
10 BY MR. KUVIN:
11 Q. Do you know where Donald Trump's Maralago
12 estate is?
13 A. Yes.
14 Q. Have you been there?
EFTA01158594
15 A. Yes.
16 Q. Who with?
17 A. I'm going to have to answer that question the
18 same way I've answered most of your other questions here
19 today. I intend to respond to all relevant questions
20 regarding this lawsuit; however, at the present time, my
21 attorneys have counseled me I cannot provide answers to
22 any questions that may be relevant to the same lawsuit.
23 I must accept their advice or risk losing my 6th
24 Amendment right to effective representation.
25 Accordingly, I must assert my federal constitutional
0188
1 rights as guaranteed by the 5th, 6th and 14th Amendment
2 to the United States Constitution.
3 Q. Have you seen the high school transcripts
4 grades of girls that you have had sexual relationships
5 with dating back to 2005?
6 MR. PIKE: Form, relevance, improper
7 hypothetical, lacks facts -- assumes facts not in
8 evidence, lacks appropriate predicate, foundation.
9 THE WITNESS: I'm going to answer that
10 question the same as I've answered most of your
11 other questions here today, Mr. Kuvin, which is, I
12 intend to respond to all relevant questions
13 regarding this lawsuit; however, at the present
14 time, my attorneys have counseled me that I cannot
15 provide answers to any questions that may be
16 relevant to this lawsuit. I must accept their
17 advice or risk losing my 6th Amendment right to
18 effective representation. Accordingly, I assert my
19 federal constitutional rights as guaranteed by the
20 5th, 6th and 14th Amendment to the United States
21 Constitution.
22 BY MR. KUVIN:
23 Q. Do you deny that the high school transcripts
24 which were found in your trash on Palm Beach that showed
25 the ages of some of the girls you were engaged with
0189
1 sexual acts with at your home came from your house?
2 MR. PIKE: Same objection in addition to
3 argumentative and harassing.
4 THE WITNESS: I intend to respond to all
5 relevant questions regarding this lawsuit; however,
6 as I've done with most of your other questions
7 today, at the present time my attorneys have
8 counseled me that I cannot provide answers to any
9 of those questions relevant to this lawsuit. I
10 must accept their advice or risk losing my 6th
11 Amendment right to effective representation.
12 Accordingly, I must assert my federal
13 constitutional rights as guaranteed by the 5th, 6th
14 and 14th Amendments to the United States
15 Constitution.
16 BY MR. KUVIN:
17 Q. Did you have numerous photos of nude young
18 women, girls under the age of 18, back in your home
19 in -- on Palm Beach Island in 2005 and 2006?
20 A. I'm going to have to respond to that question
21 the same way I've responded to most of your questions
22 here today, which is, I intend to respond to all
23 relevant questions regarding this lawsuit; however, at
24 the present time, my attorneys have counseled me I
25 cannot provide answers to any questions relevant to the
EFTA01158595
0190
1 same lawsuit. I must accept their advice or risk losing
2 my 6th Amendment right to effective representation.
3 Accordingly, I must assert my federal constitutional
4 rights as guaranteed by the 5th, 6th and 14th Amendment.
5 Q. Did you have photographs of girls under the
6 age of ten who were nude, either partially or fully
7 nude, in your home on Palm Beach in 2005 and 2006?
8 MR. PIKE: Form.
9 THE WITNESS: I'm going to respond to that
10 question the same way I've responded to most of
11 your other questions, which is, I intend to respond
12 to all relevant questions regarding this lawsuit;
13 however, at the present time, my attorneys have
14 counseled me I cannot provide answers to any
15 questions relevant to this lawsuit. I must accept
16 this advice or risk losing my 6th Amendment right
17 to effective representation. Accordingly, I assert
18 my federal constitutional rights as guaranteed by
19 the 5th, 6th and 14th Amendments of the United
20 States Constitution.
21 THE VIDEOGRAPHER: Mr. Kuvin, I'm sorry I have
22 to change.
23 MR. KUVIN: Go ahead.
24 THE VIDEOGRAPHER: We'll go off the record at
25 2:03. This will be the end of tape No. 2.
0191
1 MR. GOLDBERGER: Break time?
2 MR. KUVIN: No, not again. Please not.
3 Just let us know when you're good to go.
4 THE VIDEOGRAPHER: We're back on the record at
5 2:04. This will be the beginning of tape No. 3.
6 BY MR. KUVIN:
7 Q. Do you have security cameras throughout your
8 home on Palm Beach Island?
9 A. I'm going to answer that question the same way
10 I've answered most of your questions here today,
11 Mr. Kuvin. I intend to respond to all relevant
12 questions regarding this lawsuit; however, at the
13 present time, my attorneys have counseled me I cannot
14 provide answers to any questions relevant to the
15 lawsuit. I must accept their advice or risk losing my
16 6th Amendment right to effective representation.
17 Accordingly, I assert my federal constitutional rights
18 as guaranteed by the 5th, 6th and 14th Amendment to the
19 United States Constitution.
20 (Plaintiff's Exhibit No. 10 was marked for
21 identification.)
22 MR. KUVIN: I'll show the camera a photograph
23 here. Okay?
24 THE VIDEOGRAPHER: Lift it up. Yeah, there
25 you go. Okay.
0192
1 MR. KUVIN: Okay?
2 BY MR. KUVIN:
3 Q. Let me show you what we marked as Plaintiff's
4 Exhibit 10. Do you recognize this young lady?
5 A. Yes.
6 Q. Who is she?
7 A. Her name is Joanna Shogert (phonetic).
8 Q. And who is she?
9 A. I just -- her name is Joanna Shogert.
10 Q. How do you recognize her?
EFTA01158596
11 A. I don't understand the question.
12 Q. Well, is she a friend of yours? Did she work
13 for you? How do you recognize her?
14 A. How do I recognize her?
15 Well, I'd like to respond to that question
16 but, however, my attorneys have told me that I can't
17 respond to any questions today that may -- excuse me. I
18 intend to respond to all relevant questions regarding
19 this lawsuit; however, at the present time, my attorneys
20 have counseled me that I cannot provide answers to any
21 questions relevant to this lawsuit. I must accept their
22 advice or risk losing my 6th Amendment right to
23 effective representation. Accordingly, I assert my
24 federal constitutional rights as guaranteed by the 5th,
25 6th and 14th Amendment to the United States
0193
1 Constitution.
2 Q. Did you have sex with Joanna Shogert?
3 A. I'm going to answer that question like I've
4 answered most of your questions here today, which is, I
5 intend to respond to all relevant questions regarding
6 this lawsuit; however, at the present time, my attorneys
7 have counseled me I cannot provide answers to any
8 questions relevant to this lawsuit. I must accept their
9 advice or risk losing my 6th Amendment right to
10 effective representation. Accordingly, I assert my
11 federal constitutional rights as guaranteed by the 5th,
12 6th and 14th Amendment to the United States
13 Constitution.
14 Q. When did you first meet Prince Andrew?
15 And let me make it a compound question so I
16 don't have to repeat it over and over. When did you
17 first meet Prince Andrew, under what conditions did you
18 meet him, and who was present at that first meeting?
19 A. I'm going to answer that question as I've done
20 most of your questions here today, Mr. Kuvin, which is,
21 I intend to respond to all relevant questions regarding
22 this lawsuit; however, at the present time, my attorneys
23 have counseled me I cannot provide answers to any
24 questions relevant to that lawsuit. I must accept their
25 advice or risk losing my 6th Amendment right to
0194
1 effective representation. Accordingly, I must assert my
2 federal constitutional rights as guaranteed by the 5th,
3 6th and 14th Amendment to the United States
4 Constitution.
5 MR. PIKE: In addition, relevance.
6 BY MR. KUVIN:
7 Q. Do you pay Ms. Maxwell a salary?
8 MR. PIKE: Form.
9 BY MR. KUVIN:
10 Q. Ghislaine Maxwell, so we're clear. Do you pay
11 her a salary?
12 A. I'd like -- excuse me. I'm going to answer
13 that question the same way I've answered most of your
14 questions here today, which is, I intend to answer all
15 questions relevant to this lawsuit; however, at the
16 present time, my attorneys have counseled me I cannot
17 provide answers to any questions relevant to this
18 lawsuit. I must accept their advice or risk losing my
19 6th Amendment right to effective representation.
20 Accordingly, I assert my federal constitutional rights
21 as guaranteed by the 5th, 6th and 14th Amendment to the
EFTA01158597
22 United States Constitution.
23 Q. Did you provide any underaged girls for sex to
24 Prince Andrew?
25 MR. PIKE: Form.
0195
1 THE WITNESS: I'm going to respond to that
2 question the same way I've responded to most of
3 your questions here today, Mr. Kuvin, which is, I
4 intend to respond to all relevant questions
5 regarding this lawsuit -- excuse me, however, at
6 the present time, my attorneys have counseled me I
7 cannot provide answers to any questions relevant to
8 the lawsuit, or might be relevant to the lawsuit.
9 I must accept their advice or risk losing my 6th
10 Amendment right to effective representation.
11 Accordingly, I assert my federal constitutional
12 rights as guaranteed by the 5th, 6th and 14th
13 Amendment of the United States Constitution.
14 BY MR. KUVIN:
15 Q. Did you fly with Prince Andrew on your plane,
16 or planes, with any underaged girls, girls under the age
17 of 18?
18 A. I'm going to answer that question the same way
19 I've answered all the other questions here today,
20 virtually, which is, I intend to respond to all relevant
21 questions regarding this lawsuit; however, at the
22 present time, my attorneys have counseled me I cannot
23 provide answers to any questions relevant to the
24 lawsuit. I must accept their advice or risk losing my
25 6th Amendment right to effective representation.
0196
1 Accordingly, I must assert my federal constitutional
2 rights as guaranteed by the 5th, 6th and 14th Amendments
3 to the United States Constitution.
4 Q. Do you know Christine Drangsholt?
5 MR. KUVIN: For the court reporter, it's
6 D-R-A-N-G-S-H-O-L-T.
7 THE WITNESS: I intend to respond to all
8 relevant questions regarding this lawsuit; however,
9 at the present time, my attorneys have counseled me
10 I cannot provide answers to any questions relevant
11 to the lawsuit. I must accept this advice or risk
12 losing my 6th Amendment right to effective
13 representation. Accordingly, I assert my federal
14 constitutional rights as guaranteed by the 5th, 6th
15 and 14th Amendments to the United States
16 Constitution.
17 MR. KUVIN: Let me show the camera what we'll
18 mark as Exhibit 11.
19 (Plaintiff's Exhibit No. 11 was marked for
20 identification.)
21 THE VIDEOGRAPHER: Okay.
22 MR. KUVIN: Okay?
23 BY MR. KUVIN:
24 Q. In Exhibit 11, sir, you're standing with a
25 woman. Who is that woman in that photograph?
0197
1 A. Eula Maxwell (phonetic).
2 Q. Where were you?
3 A. I intend to respond to all relevant questions
4 regarding this lawsuit; however, at the present time, my
5 attorneys have counseled me I cannot provide answers to
6 any questions that may be relevant to this lawsuit. I
EFTA01158598
7 must accept this advice or risk losing my 6th Amendment
8 right to effective representation. Accordingly, I must
9 assert my federal constitutional rights as guaranteed by
10 the 5th, 6th and 14th Amendments to the United States
11 Constitution.
12 MR. KUVIN: And just so the court reporter
13 knows, Ghislaine is spelled G-H-I-S-L-A-I-N-E.
14 BY MR. KUVIN:
15 Q. Who is excuse
16 me?
17 A. I'm going to answer that question the same way
18 I've answered most of your questions here today, which
19 is, I intend to respond to all relevant questions
20 regarding this lawsuit; however, at the present time, my
21 attorneys have counseled me I cannot provide answers to
22 any questions relevant to the lawsuit. I must accept
23 their advice or risk losing my 6th Amendment right to
24 effective representation. Excuse me. Accordingly, I
25 must assert my federal constitutional rights as
0198
1 guarantee -- guaranteed by the 5th, 6th and 14th
2 Amendment to the United States Constitution.
3 (Plaintiff's Exhibit No. 12 was marked for
4 identification.)
5 MR. KUVIN: Let me show to the camera what
6 we've marked as Exhibit 12.
7 BY MR. KUVIN:
8 Q. Let me show you what I've marked as Exhibit
9 12. Do you recognize any of the girls in that
10 photograph?
11 A. I'm going to answer that question the same way
12 I've answered most of your other questions here today,
13 Mr. Kuvin, which is, I intend to respond to all relevant
14 questions regarding this lawsuit; however, at the
15 present time, my attorneys have counseled me that I
16 cannot provide answers to any questions that may be
17 relevant to the lawsuit. I must accept their advice or
18 risk losing my 6th Amendment right to effective
19 representation. Accordingly, I assert my federal
20 constitutional rights as guaranteed by the 5th, 6th and
21 14th Amendment to the United States Constitution.
22 Q. Sir, isn't it true that in what we've marked
23 as Plaintiff's Exhibit 12, the blond standing on the
24 left is , and the blonde, dirty blonde
25 standing on the right is ?
0199
1 A. I intend to respond to all relevant questions
2 regarding this lawsuit; however, as I've done to most of
3 the questions at the present time, my attorneys have
4 counseled me that I cannot provide answers to any of
5 those questions that may be relevant to the lawsuit. I
6 must accept this advice or risk losing my 6th Amendment
7 right to effective representation. Accordingly, I
8 assert my federal constitutional rights as guaranteed by
9 the 5th, 6th and 14th Amendments of the United States
10 Constitution.
11 BY MR. KUVIN:
12 Q. I'm going to show you what we'll mark as
13 Exhibit 13. Let me show it to the camera, first.
14 (Plaintiff's Exhibit No. 13 was marked for
15 identification.)
16 BY MR. KUVIN:
17 Q. Sir, is it true that Exhibit 13 shows your
EFTA01158599
18 personal assistant,
19 A. I intend to respond to all relevant questions
20 regarding this lawsuit; however, at the present time, my
21 attorneys have counseled me that I cannot provide
22 answers to any questions that may be relevant to this
23 lawsuit. I must accept their advice or risk losing my
24 6th Amendment right to effective representation.
25 Accordingly, I assert my federal constitutional rights
0200
1 as guaranteed by the 5th, 6th and 14th Amendment to the
2 United States Constitution.
3 Q. Let me show you what we'll mark as Exhibit 14.
4 (Plaintiff's Exhibit No. 14 was marked for
5 identification.)
6 BY MR. KUVIN:
7 Q. Sir, does Exhibit 14 show , a
8 girl that you have had a sexual relationship with since
9 before she was 18 years old?
10 MR. PIKE: Form, argumentative, harassing,
11 assumes facts not in evidence, lacks appropriate
12 predicate and foundation.
13 THE WITNESS: I intend to respond to all
14 relevant questions regarding this lawsuit; however,
15 at the present time, my attorneys have counseled me
16 I cannot provide answers to any questions relevant
17 to this lawsuit. I must accept their advice or
18 risk losing my 6th Amendment right to effective
19 representation. Accordingly, I assert my federal
20 constitutional rights as guaranteed by the 5th, 6th
21 and 14th Amendment to the United States
22 Constitution.
23 BY MR. KUVIN:
24 Q. I'm going to show the camera what we'll mark
25 as Exhibit 15.
0201
1 (Plaintiff's Exhibit No. 15 was marked for
2 identification.)
3 BY MR. KUVIN:
4 Q. Sir, does Exhibit 15 show , an
5 underaged girl that you were utilizing back in 2005 and
6 2006 to procure other underaged girls for sex and sexual
7 contact at your home?
8 MR. PIKE: Same objections to Exhibit 15 as
9 were made to Exhibit 14.
10 THE WITNESS: I'm going to answer that the
11 same way I've answered most of your questions here
12 today, Mr. Kuvin, which is, I intend to respond to
13 all relevant questions regarding this lawsuit;
14 however, at the present time, my attorneys have
15 counseled me that I cannot provide answers to any
16 questions that may be relevant to the lawsuit. I
17 must accept their advice or risk losing my 6th
18 Amendment right to effective representation.
19 Accordingly, I am going to assert my federal
20 constitutional rights as guaranteed by the 5th, 6th
21 and 14th Amendments to the United States
22 Constitution.
23 (Plaintiff's Exhibit No. 16 was marked for
24 identification.)
25 MR. KUVIN: Let me show the camera what we've
0202
1 marked as Exhibit 16.
2 BY MR. KUVIN:
EFTA01158600
3 Q. Do you recognize the gentleman in that
4 photograph, sir?
5 MR. PIKE: Hold on for a second.
6 MR. GOLDBERGER: Do you want to discuss it
7 with me?
8 MR. PIKE: Let's take a break for one minute.
9 MR. KUVIN: All right.
10 THE VIDEOGRAPHER: Off the record at 2:16.
11 (A brief recess was taken.)
12 THE VIDEOGRAPHER: We're back on the record at
13 2:45.
14 BY MR. KUVIN:
15 Q. Okay. Do you recognize the person that's
16 shown in Exhibit 16?
17 A. Yes.
18 Q. Who is that?
19 A. Prince Andrew.
20 Q. And how do you know Prince Andrew?
21 A. I'm going to have to respond to that question
22 the same way I've responded to most of your questions
23 here today, Mr. Kuvin, which is, I intend to respond to
24 all relevant questions regarding this lawsuit; however,
25 at the present time, my attorneys have counseled me I
0203
1 cannot provide answers to any questions relevant to this
2 lawsuit. I must accept their advice or risk losing my
3 6th Amendment right to effective representation.
4 Accordingly, I assert my federal constitutional rights
5 as guaranteed by the 5th, 6th and 14th Amendment to the
6 United States Constitution.
7 Q. I'm going to show you a document that we'll
8 mark as Exhibit 17.
9 MR. PIKE: Thank you.
10 (Plaintiff's Exhibit No. 17 was marked for
11 identification.)
12 BY MR. KUVIN:
13 Q. I'm going to give you a minute to take a look
14 at that document and just tell me when you're ready to
15 answer any questions about it.
16 A. Okay.
17 Q. Okay. First of all, have you seen this letter
18 before?
19 MR. GOLDBERGER: Attorney-client privilege,
20 work product.
21 BY MR. KUVIN:
22 Q. Have you seen this letter before outside of
23 the relationship with your attorneys?
24 MR. GOLDBERGER: You can answer that question.
25 THE WITNESS: No.
0204
1 BY MR. KUVIN:
2 Q. Do you know Chief of Police Michael Reiter?
3 Do you know who he is?
4 A. I know who he is.
5 Q. Do you know State Attorney Barry Krischer?
6 A. I know who he is.
7 Q. Did you ever speak with Chief of Police
8 Michael Reiter in the past?
9 A. I don't remember.
10 Q. Did you ever talk to anyone, either at the
11 State Attorney's office, yourself, or Michael Reiter
12 about the prosecution of your claim without the presence
13 of your attorneys?
EFTA01158601
14 A. No.
15 Q. Did you ever talk to any of the police that
16 worked for the Town of Palm Beach without the presence
17 of your attorneys?
18 A. Explain --
19 MR. PIKE: Wait one second.
20 THE WITNESS: I'm sorry.
21 MR. PIKE: Can you state the question again?
22 MR. KUVIN: Sure.
23 BY MR. KUVIN:
24 Q. Did you ever speak to any of the police
25 officers that worked for the Town of Palm Beach without
0205
1 the presence of your attorneys?
2 MR. GOLDBERGER: Is the question, have you
3 ever spoken to a Town of Palm Beach police officer?
4 Is that the -- can we rephrase it like that?
5 MR. KUVIN: Sure.
6 MR. GOLDBERGER: Okay.
7 THE WITNESS: I've been stopped by the police
8 for traffic violations, if that's what you mean.
9 BY MR. KUVIN:
10 Q. Any other times that you had conversations
11 with any of the Town of Palm Beach --
12 A. No.
13 Q. -- police officers?
14 A. Not that I recall specifically.
15 Q. Okay. Now, you were housed at the jail after
16 your plea of guilty that we had spoke about at the
17 beginning of your deposition; is that correct?
18 MR. PIKE: Form.
19 THE WITNESS: Say it again.
20 BY MR. KUVIN:
21 Q. Yes. You were housed at the local jail here
22 in Palm Beach County after your plea of guilty that we
23 spoke about at the beginning of your deposition?
24 MR. PIKE: Form.
25 THE WITNESS: Yes.
0206
1 BY MR. KUVIN:
2 Q. How long were you there?
3 A. 13 months, approximately.
4 Q. All right. And of those 13 months, how many
5 months were you there where you had to stay there 24
6 hours a
7 A. I don't recall specifically.
8 Q. More than a month?
9 A. Yes.
10 Q. More than two months?
11 A. Yes.
12 Q. More than three months?
13 A. Yes.
14 Q. More than four?
15 A. I think so, I don't remember.
16 Q. Do you recall when you were provided work
17 release, when you were able to leave during the daylight
18 hours?
19 A. Not with specificity.
20 Q. While you were there at the jail in Palm
21 Beach -- I'm going to show you what we'll mark as
22 Exhibit 18.
23 (Plaintiff's Exhibit No. 18 was marked for
24 identification.)
EFTA01158602
25
0207
1 BY MR. KUVIN:
2 Q. Did you purchase items from the jail?
3 MR. GOLDBERGER: Hang on a second.
4 MR. PIKE: Hold on one second.
5 THE WITNESS: It looks that way, yes, sir.
6 BY MR. KUVIN:
7 Q. Okay.
8 MR. PIKE: And the document speaks for itself,
9 the composite document speaks for itself.
10 BY MR. KUVIN:
11 Q. I'd like you to take a look at Exhibit 18. It
12 shows purchases -- well, does it show purchases by you?
13 MR. PIKE: Asked and answered.
14 THE WITNESS: Yes.
15 BY MR. KUVIN:
16 Q. Okay. And it appears those purchases took
17 place from 7/8/08 through 9/30/08 is the last one that I
18 have; is that correct?
19 MR. PIKE: The document speaks for itself.
20 BY MR. KUVIN:
21 Q. You can answer.
22 A. The document speaks for itself.
23 Q. Is that correct, the last date is 9/30/08?
24 A. The last date here is 9/30, yes.
25 MR. PIKE: With regard to what you provided to
0208
1 the witness.
2 MR. KUVIN: Sure, absolutely.
3 THE WITNESS: Okay.
4 BY MR. KUVIN:
5 Q. And just so we're clear, this composite
6 exhibit that we've marked as Exhibit 18 contains
7 purchases from 7/8/08, 7/15, 7/22, 7/29, 8/5, 8/12,
8 8/21, 8/26, 9/2, 9/9, 9/23 and 9/30, just so the record
9 is clear; there is no question.
10 A. Okay.
11 Q. Okay?
12 A. Uh-huh.
13 Q. All right. These items that you purchased,
14 did you utilize all of these items yourself?
15 MR. PIKE: Form, relevance.
16 THE WITNESS: I don't understand the question.
17 BY MR. KUVIN:
18 Q. Well, you purchased a number of items that are
19 shown in this receipt.
20 A. Yes.
21 Q. The question is: Did you use them yourself?
22 MR. PIKE: Same objection.
23 THE WITNESS: I don't know if I used all of
24 them, so...
25
0209
1 BY MR. KUVIN:
2 Q. Well, what did you do with the items that you
3 purchased?
4 MR. PIKE: Form, overbroad.
5 BY MR. KUVIN:
6 Q. You can answer.
7 A. I used some, I threw away some.
8 Q. Did you give any away?
9 A. Not that I remember.
EFTA01158603
10 MR. PIKE: Same objection.
11 BY MR. KUVIN:
12 Q. Did you provide any items that you purchased
13 to other inmates while you were there in jail?
14 MR. PIKE: Form.
15 THE WITNESS: Not to the best of my
16 recollection.
17 BY MR. KUVIN:
18 Q. Okay. With respect to all of the items that
19 are listed in these receipts, is it a safe assumption
20 that you either used them yourself or threw them away?
21 MR. PIKE: Asked and answered. If you don't
22 know -- if you know.
23 THE WITNESS: I don't know.
24 BY MR. KUVIN:
25 Q. I'm sorry? I didn't hear you.
0210
1 MR. PIKE: Asked and answered.
2 THE WITNESS: So should I answer?
3 MR. PIKE: You can answer again.
4 THE WITNESS: Ask the question again.
5 BY MR. KUVIN:
6 Q. So can we assume that all of the items that
7 are shown in these receipts were either used by you or
8 thrown away?
9 A. I don't even know if I received some of those
10 items, so I would assume I used most of them.
11 Q. Okay.
12 A. Okay?
13 Q. Sure. Take a look, I just want to make sure,
14 did you receive all these items?
15 A. I don't know.
16 MR. PIKE: Asked and answered.
17 BY MR. KUVIN:
18 Q.
1 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
2
CASE No. 502008CA037319XXXXMB AB
3
4
5 =-1
6 Plaintiff,
7
- Vs-
9 JEFFREY EPSTEIN,
10 Defendant.
11
12
13 CONTINUED DEPOSITION OF JEFFREY EPSTEIN
14 VOLUME III
15
16 Thursday, October 8, 2009
17
18 1:46 - 3:48 p.m.
19
20 250 South Australian Avenue
Suite 1400
21 West Palm Beach,Florida 33401
22
23 Reported By:
Jeana Ricciuti, RPR, FPR, CLR
24 Notary Public, State of Florida
Prose Court Reporting Agency, Inc.
25
0173
1 APPEARANCES:
2 On behalf of the Plaintiff:
SPENCER T. KUVIN, ESQUIRE
3 ADAM LANGINO, ESQUIRE
LEOPOLD KUVIN, P.A.
4 2295 PGA Boulevard
Suite 200
5 Palm Beach Gardens, Florida 33410
Phone:
6
On behalf of §§§. and III. and Jane Doe in Case No.
7 80893:
CARA L. HOLMES, ESQUIRE
8 ROTHSTEIN, ROSENFELDT & ADLER
401 East Las Olas Boulevard
9 Suite 1650
Fort Lauderdale, Florida 33301
10 Phone:
11 On behalf of Plaintiff Jane Doe in Case No. 80591 and
80656 via telephone:
12 KATHERINE W. EZELL, ESQUIRE
PODHURST ORSECK, P.A.
13 25 West Flagler Street
Miami, Florida 33130
14 Phone:
15 On behalf of the Defendant:
JACK GOLDBERGER, ESQUIRE
16 STORY KOWLES, PARALEGAL
ATTERBURY, GOLDBERGER & WEISS, P.A.
EFTA01158588
17 250 South Australian Avenue
Suite 1400
18 West Palm Beach, Florida 33401
Phone:
19
MICHAEL J. PIKE, ESQUIRE
20 BURMAN, CRITTON, LUTTIER & COLEMAN, P.A.
303 Banyan Boulevard
21 Suite 400
West Palm Beach, Florida 33401
22 Phone:
23 ALSO PRESENT:
24 DAN DOSKEY, VIDEOGRAPHER
VISUAL EVIDENCE, INC.
25
0174
1
EXHIBITS
2
3 WITNESS: CONT'D DIRECT
4 JEFFREY EPSTEIN
5 BY MR. KUVIN 175
6
7
8
EXHIBITS
9 - - - -
10 NUMBER DESCRIPTION PAGE
11 PLAINTIFF'S EX. 9 PHOTOGRAPH OF GHISLAINE 182
MAXWELL
12 PLAINTIFF'S EX. 10 PHOTOGRAPH OF JOANNA 191
SHOGERT
13 PLAINTIFF'S EX. 11 PHOTOGRAPH OF EULA MAXWELL 196
PLAINTIFF'S EX. 12 PHOTOGRAPH 198
14 PLAINTIFF'S EX. 13 PHOTOGRAPH OF 199
PLAINTIFF'S EX. 14 PHOTOGRAPH OF
PLAINTIFF'S EX. 15 PHOTOGRAPH OF 201
16 PLAINTIFF'S EX. 16 PHOTOGRAPH OF PRINCE 201
ANDREW
17 PLAINTIFF'S EX. 17 LETTER TO B. KRISCHER FROM 203
M. REITER
18 PLAINTIFF'S EX. 18 RECEIPT OF PURCHASES MADE 206
FROM JAIL
19 PLAINTIFF'S EX. 19 FAA REGISTRY 218
20
21
22
23
24
25
0175
1 PROCEEDINGS
2 - - -
3 THE VIDEOGRAPHER: We're back on the record at
4 1:46.
5 CONTINUED DIRECT EXAMINATION
6 BY MR. KUVIN:
7 Q. Do you personally know John Mack, former CEO
8 at Morgan Stanley?
9 A. I'll have to answer that the same way I've
10 answered most of your questions here today, Mr. Kuvin,
11 which is, I intend to respond to all relevant questions
EFTA01158589
12 regarding this lawsuit; however, at the present time, my
13 attorneys have counseled me I cannot provide answers to
14 any questions relevant to this lawsuit. I must accept
15 this advice or risk losing my 6th Amendment right to
16 effective representation. Accordingly, I assert my
17 federal constitutional rights as guaranteed by the 5th,
18 6th and 14th Amendment to the United States
19 Constitution.
20 MR. KUVIN: Okay. Same deposition as shown
21 before, different clip. I'm going to play it for
22 counsel first.
23 MR. PIKE: Thank you.
24 MR. KUVIN: Mr. Videographer, just let me know
25 when you're ready.
0176
1 THE VIDEOGRAPHER: Whenever you are.
2 MR. KUVIN: Okay.
3 (Video played.)
4 VIDEO WITNESS: "What did I do to Jeffrey and
5 what did Jeffrey do to me? I went up there
6 multiple times; I can't count. And I would be on a
7 massage table, massaging his legs, he would turn
8 over, his penis would be hanging out. He would put
9 a vagina -- or a vibrator to my vagina. He would
10 touch my vagina with his fingers. He would touch
11 my breasts. He would try to kiss my mouth. He
12 would bring my hands toward his penis."
13 (Video stopped.)
14 MR. KUVIN: Okay.
15 MR. PIKE: I'm just going to object to the use
16 of the video as to relevance, predicate and
17 foundation.
18 BY MR. KUVIN:
19 Q. All right. Let me get it back to the same
20 location.
21 Sir, first of all, once again, just so I can
22 lay the foundation for this, do you recognize this girl?
23 A. I'm going to have to respond to that question
24 the same way I've responded to most of your other
25 questions here today, which is, I intend to respond to
0177
1 all relevant cannot provide answers to any questions
2 relevant to this lawsuit; however, at the present time,
3 my attorneys have counseled me I cannot provide answers
4 to any questions relevant to the lawsuit. I must accept
5 this advice or risk losing my 6th Amendment right to
6 effective representation. Accordingly, I assert my
7 federal constitutional rights as guaranteed by the 5th,
a 6th and 14th Amendment to the United States
9 Constitution.
10 Q. Did this girl bring §§§. to your home for a
11 naked massage?
12 A. I'm going to have to respond to that the same
13 way I've responded to most of your other questions here
14 today, which is, I intend to respond to all relevant
15 questions regarding this lawsuit; however, at the
16 present time, my attorneys have counseled me I cannot
17 provide answers to any questions that may be relevant to
18 the lawsuit. I must accept this advice or risk losing
19 my 6th Amendment right to effective representation.
20 Accordingly, I assert my federal constitutional rights
21 as guaranteed by the 5th, 6th and 14th Amendment to the
22 United States Constitution.
EFTA01158590
23 Q. I'd like to play this clip for you and then
24 I'm going to ask you a question.
25 MR. PIKE: The same clip you just played?
0178
1 MR. KUVIN: Exactly.
2 MR. PIKE: Same objection.
3 (Video played.)
4 VIDEO WITNESS: "What did I do to Jeffrey and
5 what did Jeffrey do to me? I went out there
6 multiple times; I can't count. And I would be on a
7 massage table, massaging his legs. He would turn
8 over, his penis would be hanging out. He would put
9 a vagina -- or vibrator to my vagina. He would
10 touch my vagina with his fingers. He would touch
11 my breasts. He would try to kiss my mouth. He
12 would bring my hands toward his penis."
13 (Video stopped.)
14 BY MR. KUVIN:
15 Q. Did you do that with that girl?
16 MR. PIKE: Form.
17 THE WITNESS: I intend to respond to all
18 relevant questions regarding this lawsuit; however,
19 at the present time, my attorneys have counseled me
20 I cannot provide answers to any questions that may
21 be relevant to this lawsuit. I must accept this
22 advice or risk losing my 6th Amendment right to
23 effective representation. Accordingly, I must
24 assert my federal constitutional rights as
25 guaranteed by the 5th, 6th and 14th Amendment to
0179
1 the United States Constitution.
2 BY MR. KUVIN:
3 Q. Did you do what that young lady described just
4 now to hundreds of women, including III.?
5 MR. PIKE: Form, argumentative, harassing,
6 lacks appropriate predicate, foundation, lacks
7 identity.
8 THE WITNESS: Excuse me. I'm going to respond
9 to that the same way I've responded to most of your
10 other questions here today, which is, I intend to
11 respond to all relevant questions regarding this
12 lawsuit; however, at the present time, my attorneys
13 have counseled me that I cannot provide answers to
14 any questions relevant to the lawsuit. I must
15 accept their advice or risk losing my 6th Amendment
16 right to effective representation. Accordingly, I
17 must assert my federal constitutional rights as
18 guaranteed by the 5th, 6th and 14th Amendment to
19 the United States Constitution.
20 BY MR. KUVIN:
21 Q. While §§§. was standing naked in your home,
22 specifically in your bathroom, did you tell her that you
23 could get her an interview as a model because of your
24 connections?
25 A. I'm going respond to that the same way I've
0180
1 responded to most of your questions today, Spencer. I
2 intend to respond to all relevant questions regarding
3 this lawsuit; however, at the present time, my attorneys
4 have counseled me I cannot provide answers to any
5 questions that may be relevant to the lawsuit. I must
6 accept this advice or risk losing my 6th Amendment right
7 to effective representation. Accordingly, I must assert
EFTA01158591
8 my federal constitutional right as guaranteed by the
9 5th, 6th and 14th Amendment to the United States
10 Constitution.
11 MR. PIKE: Same objection to that line of
12 questioning.
13 BY MR. KUVIN:
14 Q. As §§§. was standing naked in your bathroom
15 before you when she was 15, did you ask her to turn
16 around so you could see her ass better?
17 MR. PIKE: Form, argumentative, harassing,
18 lacks appropriate predicate, foundation.
19 THE WITNESS: I'll respond to that as I
20 responded to your last question, which is, I intend
21 to respond to all relevant questions regarding this
22 lawsuit; however, at the present time, my attorneys
23 have counseled me I cannot provide answers to any
24 questions that may be relevant to this lawsuit. I
25 must accept their advice or risk losing my 6th
0181
1 Amendment right to effective representation;
2 therefore, I must assert my federal constitutional
3 rights as guaranteed by the 5th, 6th and 14th
4 Amendment to the United States Constitution.
5 BY MR. KUVIN:
6 Q. When III. was 15 years old and standing naked
7 in front of you in your bathroom, did you tell her that
8 you could help her become a model?
9 MR. PIKE: Same objections, including
10 foundation.
11 THE WITNESS: Is it different than the last
12 question?
13 MR. KUVIN: Uh-huh.
14 MR. GOLDBERGER: Just go ahead.
15 THE WITNESS: Okay. I intend to respond to
16 all relevant questions pertaining to this lawsuit;
17 however, at the present time, my attorneys have
18 counseled me I cannot provide answers to any
19 questions that may be relevant to this lawsuit, so
20 I've answered most questions here today the same
21 way. I must expect that -- accept their advice or
22 risk losing my 6th Amendment right to effective
23 representation. Accordingly, I assert my federal
24 constitutional rights as guaranteed by the 5th, 6th
25 and 14th Amendment to the United States
0182
1 Constitution.
2 BY MR. KUVIN:
3 Q. Who is Ghislaine Maxwell?
4 A. I intend to respond to all relevant questions
5 regarding this lawsuit; however, at the present time, my
6 attorneys have counseled me that I cannot provide
7 answers to any questions relevant to this lawsuit. As I
8 have done to most of your other questions here today, I
9 must accept their advice or risk losing my 6th Amendment
10 right to effective representation. Accordingly, I
11 assert my federal constitutional rights as guaranteed by
12 the 5th, 6th and 14th Amendment to the United States
13 Constitution.
14 MR. KUVIN: Let me show the camera what we'll
15 mark as Exhibit 9 to this deposition.
16 THE VIDEOGRAPHER: Okay.
17 (Plaintiff's Exhibit No. 9 was marked for
18 identification.)
EFTA01158592
19 BY MR. KUVIN:
20 Q. Let me show you what we've marked as Exhibit 9
21 to your deposition. Do you recognize Ghislaine Maxwell
22 in this photograph?
23 A. Yes.
24 Q. And who is she standing with?
25 A. Her father.
0183
1 Q. And her father is Robert Maxwell?
2 A. Was Robert Maxwell.
3 Q. I'm sorry, he's passed, correct?
4 A. Correct.
5 Q. She is a close friend of yours, is she not?
6 A. I'm going to respond to that question the same
7 way I've responded to most of your other questions here
8 today, Mr. Kuvin, which is, I intend to respond to all
9 relevant questions regarding to this lawsuit; however,
10 at the present time, my attorneys have counseled me I
11 cannot provide answers to any questions that may be
12 relevant to this lawsuit. I must expect -- accept their
13 advice or risk losing my 6th Amendment right to
14 effective representation. Accordingly, I must assert my
15 federal constitutional rights as guaranteed by the 5th,
16 6th and 14th Amendment to the United States
17 Constitution.
18 Q. Ghislaine Maxwell has accompanied you to
19 numerous social events in the last few years; isn't that
20 true?
21 MR. PIKE: Form.
22 THE WITNESS: I'm going to respond to that
23 question the same way I've responded to most of
24 your questions here today, which is, I intend to
25 respond to all relevant questions regarding your
0184
1 lawsuit; however, at the present time, my attorneys
2 have counseled me I cannot provide answers to any
3 questions that may be relevant to that lawsuit. I
4 must accept their advice or risk losing my 6th
5 Amendment right to effective representation.
6 Accordingly, I must assert my federal
7 constitutional right as guaranteed by the 5th, 6th
8 and 14th Amendment of the United States
9 Constitution.
10 BY MR. KUVIN:
11 Q. One of your houseboys that has been deposed in
12 this case testified that you were a rather nice
13 gentleman that used to talk to the staff, and that when
14 Ms. Maxwell came into the picture, that you stopped
15 talking to the staff and the staff had to communicate
16 through Ms. Maxwell. Do you agree or disagree with
17 that?
18 MR. PIKE: Form, foundation, predicate,
19 argumentative, assumes facts not in evidence.
20 THE WITNESS: I'm going to answer that the
21 same way I've answered most of your questions here
22 today, which is, I intend to respond to all
23 relevant questions regarding this lawsuit; however,
24 at the present time, my attorneys have counseled me
25 that I cannot provide answers to any questions that
0185
1 may be relevant to your lawsuit. I must accept
2 their advice or risk losing my 6th Amendment right
3 to effective representation. Accordingly, I assert
EFTA01158593
4 my federal constitutional rights as guaranteed by
5 the 5th, 6th and 14th Amendment of the United
6 States Constitution.
7 BY MR. KUVIN:
8 Q. He also testified that he felt you were a
9 rather normal guy until Ms. Maxwell came into the
10 picture, and that she led you into this life of
11 perversion, sexual perversion. Do you agree with that?
12 MR. PIKE: Same objections.
13 THE WITNESS: I'm going to respond to that the
14 same way I've responded to most of your questions
15 here today, Mr. Kuvin, which is, I intend to
16 respond to all relevant questions regarding this
17 lawsuit; however, at the present time, my attorneys
18 have counseled me I cannot provide answers to any
19 questions relevant to this lawsuit. I must accept
20 their advice or risk losing my 6th Amendment --
21 excuse me -- I must accept their advice or risk
22 losing my 6th Amendment right to effective
23 representation. Accordingly, I must assert my
24 federal constitutional rights as guaranteed by the
25 5th, 6th and 14th Amendment to the United States
0186
1 Constitution.
2 BY MR. KUVIN:
3 Q. Did Ms. Maxwell procure underaged girls for
4 you to have sexual relationships with?
5 A. I'm going to answer that question the same way
6 I've answered most of your other questions today,
7 Mr. Kuvin, which is, I intend to respond to all relevant
8 questions regarding this lawsuit; however, at the
9 present time, my attorneys have counseled me I cannot
10 provide answers to any questions relevant to that
11 lawsuit. Excuse me. I must accept their advice or risk
12 losing my 6th Amendment right to effective
13 representation. Accordingly, I must assert my federal
14 constitutional rights as guaranteed -- guaranteed by the
15 5th, 6th and 14th Amendments to the United States
16 Constitution.
17 Q. Ms. Maxwell procured a particular underaged
18 girl who worked at Donald Trump's Maralago, for you to
19 have a sexual relationship with; isn't that true?
20 MR. PIKE: Form, argumentative, lacks
21 appropriate predicate, foundation, assumes facts
22 not in evidence.
23 THE WITNESS: I'm going to respond to that the
24 same way I've responded to most of your other
25 questions here today, Mr. Kuvin, which is, I intend
0187
1 to respond to all relevant questions regarding this
2 lawsuit; however, at the present time, my attorneys
3 have counseled me I cannot provide answers to any
4 questions relevant to that lawsuit. I must accept
5 their advice or risk losing my 6th Amendment right
6 to effective representation. Therefore, I assert
7 my federal constitutional rights as guaranteed by
8 the 5th, 6th and 14th Amendments to the United
9 States Constitution.
10 BY MR. KUVIN:
11 Q. Do you know where Donald Trump's Maralago
12 estate is?
13 A. Yes.
14 Q. Have you been there?
EFTA01158594
15 A. Yes.
16 Q. Who with?
17 A. I'm going to have to answer that question the
18 same way I've answered most of your other questions here
19 today. I intend to respond to all relevant questions
20 regarding this lawsuit; however, at the present time, my
21 attorneys have counseled me I cannot provide answers to
22 any questions that may be relevant to the same lawsuit.
23 I must accept their advice or risk losing my 6th
24 Amendment right to effective representation.
25 Accordingly, I must assert my federal constitutional
0188
1 rights as guaranteed by the 5th, 6th and 14th Amendment
2 to the United States Constitution.
3 Q. Have you seen the high school transcripts
4 grades of girls that you have had sexual relationships
5 with dating back to 2005?
6 MR. PIKE: Form, relevance, improper
7 hypothetical, lacks facts -- assumes facts not in
8 evidence, lacks appropriate predicate, foundation.
9 THE WITNESS: I'm going to answer that
10 question the same as I've answered most of your
11 other questions here today, Mr. Kuvin, which is, I
12 intend to respond to all relevant questions
13 regarding this lawsuit; however, at the present
14 time, my attorneys have counseled me that I cannot
15 provide answers to any questions that may be
16 relevant to this lawsuit. I must accept their
17 advice or risk losing my 6th Amendment right to
18 effective representation. Accordingly, I assert my
19 federal constitutional rights as guaranteed by the
20 5th, 6th and 14th Amendment to the United States
21 Constitution.
22 BY MR. KUVIN:
23 Q. Do you deny that the high school transcripts
24 which were found in your trash on Palm Beach that showed
25 the ages of some of the girls you were engaged with
0189
1 sexual acts with at your home came from your house?
2 MR. PIKE: Same objection in addition to
3 argumentative and harassing.
4 THE WITNESS: I intend to respond to all
5 relevant questions regarding this lawsuit; however,
6 as I've done with most of your other questions
7 today, at the present time my attorneys have
8 counseled me that I cannot provide answers to any
9 of those questions relevant to this lawsuit. I
10 must accept their advice or risk losing my 6th
11 Amendment right to effective representation.
12 Accordingly, I must assert my federal
13 constitutional rights as guaranteed by the 5th, 6th
14 and 14th Amendments to the United States
15 Constitution.
16 BY MR. KUVIN:
17 Q. Did you have numerous photos of nude young
18 women, girls under the age of 18, back in your home
19 in -- on Palm Beach Island in 2005 and 2006?
20 A. I'm going to have to respond to that question
21 the same way I've responded to most of your questions
22 here today, which is, I intend to respond to all
23 relevant questions regarding this lawsuit; however, at
24 the present time, my attorneys have counseled me I
25 cannot provide answers to any questions relevant to the
EFTA01158595
0190
1 same lawsuit. I must accept their advice or risk losing
2 my 6th Amendment right to effective representation.
3 Accordingly, I must assert my federal constitutional
4 rights as guaranteed by the 5th, 6th and 14th Amendment.
5 Q. Did you have photographs of girls under the
6 age of ten who were nude, either partially or fully
7 nude, in your home on Palm Beach in 2005 and 2006?
8 MR. PIKE: Form.
9 THE WITNESS: I'm going to respond to that
10 question the same way I've responded to most of
11 your other questions, which is, I intend to respond
12 to all relevant questions regarding this lawsuit;
13 however, at the present time, my attorneys have
14 counseled me I cannot provide answers to any
15 questions relevant to this lawsuit. I must accept
16 this advice or risk losing my 6th Amendment right
17 to effective representation. Accordingly, I assert
18 my federal constitutional rights as guaranteed by
19 the 5th, 6th and 14th Amendments of the United
20 States Constitution.
21 THE VIDEOGRAPHER: Mr. Kuvin, I'm sorry I have
22 to change.
23 MR. KUVIN: Go ahead.
24 THE VIDEOGRAPHER: We'll go off the record at
25 2:03. This will be the end of tape No. 2.
0191
1 MR. GOLDBERGER: Break time?
2 MR. KUVIN: No, not again. Please not.
3 Just let us know when you're good to go.
4 THE VIDEOGRAPHER: We're back on the record at
5 2:04. This will be the beginning of tape No. 3.
6 BY MR. KUVIN:
7 Q. Do you have security cameras throughout your
8 home on Palm Beach Island?
9 A. I'm going to answer that question the same way
10 I've answered most of your questions here today,
11 Mr. Kuvin. I intend to respond to all relevant
12 questions regarding this lawsuit; however, at the
13 present time, my attorneys have counseled me I cannot
14 provide answers to any questions relevant to the
15 lawsuit. I must accept their advice or risk losing my
16 6th Amendment right to effective representation.
17 Accordingly, I assert my federal constitutional rights
18 as guaranteed by the 5th, 6th and 14th Amendment to the
19 United States Constitution.
20 (Plaintiff's Exhibit No. 10 was marked for
21 identification.)
22 MR. KUVIN: I'll show the camera a photograph
23 here. Okay?
24 THE VIDEOGRAPHER: Lift it up. Yeah, there
25 you go. Okay.
0192
1 MR. KUVIN: Okay?
2 BY MR. KUVIN:
3 Q. Let me show you what we marked as Plaintiff's
4 Exhibit 10. Do you recognize this young lady?
5 A. Yes.
6 Q. Who is she?
7 A. Her name is Joanna Shogert (phonetic).
8 Q. And who is she?
9 A. I just -- her name is Joanna Shogert.
10 Q. How do you recognize her?
EFTA01158596
11 A. I don't understand the question.
12 Q. Well, is she a friend of yours? Did she work
13 for you? How do you recognize her?
14 A. How do I recognize her?
15 Well, I'd like to respond to that question
16 but, however, my attorneys have told me that I can't
17 respond to any questions today that may -- excuse me. I
18 intend to respond to all relevant questions regarding
19 this lawsuit; however, at the present time, my attorneys
20 have counseled me that I cannot provide answers to any
21 questions relevant to this lawsuit. I must accept their
22 advice or risk losing my 6th Amendment right to
23 effective representation. Accordingly, I assert my
24 federal constitutional rights as guaranteed by the 5th,
25 6th and 14th Amendment to the United States
0193
1 Constitution.
2 Q. Did you have sex with Joanna Shogert?
3 A. I'm going to answer that question like I've
4 answered most of your questions here today, which is, I
5 intend to respond to all relevant questions regarding
6 this lawsuit; however, at the present time, my attorneys
7 have counseled me I cannot provide answers to any
8 questions relevant to this lawsuit. I must accept their
9 advice or risk losing my 6th Amendment right to
10 effective representation. Accordingly, I assert my
11 federal constitutional rights as guaranteed by the 5th,
12 6th and 14th Amendment to the United States
13 Constitution.
14 Q. When did you first meet Prince Andrew?
15 And let me make it a compound question so I
16 don't have to repeat it over and over. When did you
17 first meet Prince Andrew, under what conditions did you
18 meet him, and who was present at that first meeting?
19 A. I'm going to answer that question as I've done
20 most of your questions here today, Mr. Kuvin, which is,
21 I intend to respond to all relevant questions regarding
22 this lawsuit; however, at the present time, my attorneys
23 have counseled me I cannot provide answers to any
24 questions relevant to that lawsuit. I must accept their
25 advice or risk losing my 6th Amendment right to
0194
1 effective representation. Accordingly, I must assert my
2 federal constitutional rights as guaranteed by the 5th,
3 6th and 14th Amendment to the United States
4 Constitution.
5 MR. PIKE: In addition, relevance.
6 BY MR. KUVIN:
7 Q. Do you pay Ms. Maxwell a salary?
8 MR. PIKE: Form.
9 BY MR. KUVIN:
10 Q. Ghislaine Maxwell, so we're clear. Do you pay
11 her a salary?
12 A. I'd like -- excuse me. I'm going to answer
13 that question the same way I've answered most of your
14 questions here today, which is, I intend to answer all
15 questions relevant to this lawsuit; however, at the
16 present time, my attorneys have counseled me I cannot
17 provide answers to any questions relevant to this
18 lawsuit. I must accept their advice or risk losing my
19 6th Amendment right to effective representation.
20 Accordingly, I assert my federal constitutional rights
21 as guaranteed by the 5th, 6th and 14th Amendment to the
EFTA01158597
22 United States Constitution.
23 Q. Did you provide any underaged girls for sex to
24 Prince Andrew?
25 MR. PIKE: Form.
0195
1 THE WITNESS: I'm going to respond to that
2 question the same way I've responded to most of
3 your questions here today, Mr. Kuvin, which is, I
4 intend to respond to all relevant questions
5 regarding this lawsuit -- excuse me, however, at
6 the present time, my attorneys have counseled me I
7 cannot provide answers to any questions relevant to
8 the lawsuit, or might be relevant to the lawsuit.
9 I must accept their advice or risk losing my 6th
10 Amendment right to effective representation.
11 Accordingly, I assert my federal constitutional
12 rights as guaranteed by the 5th, 6th and 14th
13 Amendment of the United States Constitution.
14 BY MR. KUVIN:
15 Q. Did you fly with Prince Andrew on your plane,
16 or planes, with any underaged girls, girls under the age
17 of 18?
18 A. I'm going to answer that question the same way
19 I've answered all the other questions here today,
20 virtually, which is, I intend to respond to all relevant
21 questions regarding this lawsuit; however, at the
22 present time, my attorneys have counseled me I cannot
23 provide answers to any questions relevant to the
24 lawsuit. I must accept their advice or risk losing my
25 6th Amendment right to effective representation.
0196
1 Accordingly, I must assert my federal constitutional
2 rights as guaranteed by the 5th, 6th and 14th Amendments
3 to the United States Constitution.
4 Q. Do you know Christine Drangsholt?
5 MR. KUVIN: For the court reporter, it's
6 D-R-A-N-G-S-H-O-L-T.
7 THE WITNESS: I intend to respond to all
8 relevant questions regarding this lawsuit; however,
9 at the present time, my attorneys have counseled me
10 I cannot provide answers to any questions relevant
11 to the lawsuit. I must accept this advice or risk
12 losing my 6th Amendment right to effective
13 representation. Accordingly, I assert my federal
14 constitutional rights as guaranteed by the 5th, 6th
15 and 14th Amendments to the United States
16 Constitution.
17 MR. KUVIN: Let me show the camera what we'll
18 mark as Exhibit 11.
19 (Plaintiff's Exhibit No. 11 was marked for
20 identification.)
21 THE VIDEOGRAPHER: Okay.
22 MR. KUVIN: Okay?
23 BY MR. KUVIN:
24 Q. In Exhibit 11, sir, you're standing with a
25 woman. Who is that woman in that photograph?
0197
1 A. Eula Maxwell (phonetic).
2 Q. Where were you?
3 A. I intend to respond to all relevant questions
4 regarding this lawsuit; however, at the present time, my
5 attorneys have counseled me I cannot provide answers to
6 any questions that may be relevant to this lawsuit. I
EFTA01158598
7 must accept this advice or risk losing my 6th Amendment
8 right to effective representation. Accordingly, I must
9 assert my federal constitutional rights as guaranteed by
10 the 5th, 6th and 14th Amendments to the United States
11 Constitution.
12 MR. KUVIN: And just so the court reporter
13 knows, Ghislaine is spelled G-H-I-S-L-A-I-N-E.
14 BY MR. KUVIN:
15 Q. Who is excuse
16 me?
17 A. I'm going to answer that question the same way
18 I've answered most of your questions here today, which
19 is, I intend to respond to all relevant questions
20 regarding this lawsuit; however, at the present time, my
21 attorneys have counseled me I cannot provide answers to
22 any questions relevant to the lawsuit. I must accept
23 their advice or risk losing my 6th Amendment right to
24 effective representation. Excuse me. Accordingly, I
25 must assert my federal constitutional rights as
0198
1 guarantee -- guaranteed by the 5th, 6th and 14th
2 Amendment to the United States Constitution.
3 (Plaintiff's Exhibit No. 12 was marked for
4 identification.)
5 MR. KUVIN: Let me show to the camera what
6 we've marked as Exhibit 12.
7 BY MR. KUVIN:
8 Q. Let me show you what I've marked as Exhibit
9 12. Do you recognize any of the girls in that
10 photograph?
11 A. I'm going to answer that question the same way
12 I've answered most of your other questions here today,
13 Mr. Kuvin, which is, I intend to respond to all relevant
14 questions regarding this lawsuit; however, at the
15 present time, my attorneys have counseled me that I
16 cannot provide answers to any questions that may be
17 relevant to the lawsuit. I must accept their advice or
18 risk losing my 6th Amendment right to effective
19 representation. Accordingly, I assert my federal
20 constitutional rights as guaranteed by the 5th, 6th and
21 14th Amendment to the United States Constitution.
22 Q. Sir, isn't it true that in what we've marked
23 as Plaintiff's Exhibit 12, the blond standing on the
24 left is , and the blonde, dirty blonde
25 standing on the right is ?
0199
1 A. I intend to respond to all relevant questions
2 regarding this lawsuit; however, as I've done to most of
3 the questions at the present time, my attorneys have
4 counseled me that I cannot provide answers to any of
5 those questions that may be relevant to the lawsuit. I
6 must accept this advice or risk losing my 6th Amendment
7 right to effective representation. Accordingly, I
8 assert my federal constitutional rights as guaranteed by
9 the 5th, 6th and 14th Amendments of the United States
10 Constitution.
11 BY MR. KUVIN:
12 Q. I'm going to show you what we'll mark as
13 Exhibit 13. Let me show it to the camera, first.
14 (Plaintiff's Exhibit No. 13 was marked for
15 identification.)
16 BY MR. KUVIN:
17 Q. Sir, is it true that Exhibit 13 shows your
EFTA01158599
18 personal assistant,
19 A. I intend to respond to all relevant questions
20 regarding this lawsuit; however, at the present time, my
21 attorneys have counseled me that I cannot provide
22 answers to any questions that may be relevant to this
23 lawsuit. I must accept their advice or risk losing my
24 6th Amendment right to effective representation.
25 Accordingly, I assert my federal constitutional rights
0200
1 as guaranteed by the 5th, 6th and 14th Amendment to the
2 United States Constitution.
3 Q. Let me show you what we'll mark as Exhibit 14.
4 (Plaintiff's Exhibit No. 14 was marked for
5 identification.)
6 BY MR. KUVIN:
7 Q. Sir, does Exhibit 14 show , a
8 girl that you have had a sexual relationship with since
9 before she was 18 years old?
10 MR. PIKE: Form, argumentative, harassing,
11 assumes facts not in evidence, lacks appropriate
12 predicate and foundation.
13 THE WITNESS: I intend to respond to all
14 relevant questions regarding this lawsuit; however,
15 at the present time, my attorneys have counseled me
16 I cannot provide answers to any questions relevant
17 to this lawsuit. I must accept their advice or
18 risk losing my 6th Amendment right to effective
19 representation. Accordingly, I assert my federal
20 constitutional rights as guaranteed by the 5th, 6th
21 and 14th Amendment to the United States
22 Constitution.
23 BY MR. KUVIN:
24 Q. I'm going to show the camera what we'll mark
25 as Exhibit 15.
0201
1 (Plaintiff's Exhibit No. 15 was marked for
2 identification.)
3 BY MR. KUVIN:
4 Q. Sir, does Exhibit 15 show , an
5 underaged girl that you were utilizing back in 2005 and
6 2006 to procure other underaged girls for sex and sexual
7 contact at your home?
8 MR. PIKE: Same objections to Exhibit 15 as
9 were made to Exhibit 14.
10 THE WITNESS: I'm going to answer that the
11 same way I've answered most of your questions here
12 today, Mr. Kuvin, which is, I intend to respond to
13 all relevant questions regarding this lawsuit;
14 however, at the present time, my attorneys have
15 counseled me that I cannot provide answers to any
16 questions that may be relevant to the lawsuit. I
17 must accept their advice or risk losing my 6th
18 Amendment right to effective representation.
19 Accordingly, I am going to assert my federal
20 constitutional rights as guaranteed by the 5th, 6th
21 and 14th Amendments to the United States
22 Constitution.
23 (Plaintiff's Exhibit No. 16 was marked for
24 identification.)
25 MR. KUVIN: Let me show the camera what we've
0202
1 marked as Exhibit 16.
2 BY MR. KUVIN:
EFTA01158600
3 Q. Do you recognize the gentleman in that
4 photograph, sir?
5 MR. PIKE: Hold on for a second.
6 MR. GOLDBERGER: Do you want to discuss it
7 with me?
8 MR. PIKE: Let's take a break for one minute.
9 MR. KUVIN: All right.
10 THE VIDEOGRAPHER: Off the record at 2:16.
11 (A brief recess was taken.)
12 THE VIDEOGRAPHER: We're back on the record at
13 2:45.
14 BY MR. KUVIN:
15 Q. Okay. Do you recognize the person that's
16 shown in Exhibit 16?
17 A. Yes.
18 Q. Who is that?
19 A. Prince Andrew.
20 Q. And how do you know Prince Andrew?
21 A. I'm going to have to respond to that question
22 the same way I've responded to most of your questions
23 here today, Mr. Kuvin, which is, I intend to respond to
24 all relevant questions regarding this lawsuit; however,
25 at the present time, my attorneys have counseled me I
0203
1 cannot provide answers to any questions relevant to this
2 lawsuit. I must accept their advice or risk losing my
3 6th Amendment right to effective representation.
4 Accordingly, I assert my federal constitutional rights
5 as guaranteed by the 5th, 6th and 14th Amendment to the
6 United States Constitution.
7 Q. I'm going to show you a document that we'll
8 mark as Exhibit 17.
9 MR. PIKE: Thank you.
10 (Plaintiff's Exhibit No. 17 was marked for
11 identification.)
12 BY MR. KUVIN:
13 Q. I'm going to give you a minute to take a look
14 at that document and just tell me when you're ready to
15 answer any questions about it.
16 A. Okay.
17 Q. Okay. First of all, have you seen this letter
18 before?
19 MR. GOLDBERGER: Attorney-client privilege,
20 work product.
21 BY MR. KUVIN:
22 Q. Have you seen this letter before outside of
23 the relationship with your attorneys?
24 MR. GOLDBERGER: You can answer that question.
25 THE WITNESS: No.
0204
1 BY MR. KUVIN:
2 Q. Do you know Chief of Police Michael Reiter?
3 Do you know who he is?
4 A. I know who he is.
5 Q. Do you know State Attorney Barry Krischer?
6 A. I know who he is.
7 Q. Did you ever speak with Chief of Police
8 Michael Reiter in the past?
9 A. I don't remember.
10 Q. Did you ever talk to anyone, either at the
11 State Attorney's office, yourself, or Michael Reiter
12 about the prosecution of your claim without the presence
13 of your attorneys?
EFTA01158601
14 A. No.
15 Q. Did you ever talk to any of the police that
16 worked for the Town of Palm Beach without the presence
17 of your attorneys?
18 A. Explain --
19 MR. PIKE: Wait one second.
20 THE WITNESS: I'm sorry.
21 MR. PIKE: Can you state the question again?
22 MR. KUVIN: Sure.
23 BY MR. KUVIN:
24 Q. Did you ever speak to any of the police
25 officers that worked for the Town of Palm Beach without
0205
1 the presence of your attorneys?
2 MR. GOLDBERGER: Is the question, have you
3 ever spoken to a Town of Palm Beach police officer?
4 Is that the -- can we rephrase it like that?
5 MR. KUVIN: Sure.
6 MR. GOLDBERGER: Okay.
7 THE WITNESS: I've been stopped by the police
8 for traffic violations, if that's what you mean.
9 BY MR. KUVIN:
10 Q. Any other times that you had conversations
11 with any of the Town of Palm Beach --
12 A. No.
13 Q. -- police officers?
14 A. Not that I recall specifically.
15 Q. Okay. Now, you were housed at the jail after
16 your plea of guilty that we had spoke about at the
17 beginning of your deposition; is that correct?
18 MR. PIKE: Form.
19 THE WITNESS: Say it again.
20 BY MR. KUVIN:
21 Q. Yes. You were housed at the local jail here
22 in Palm Beach County after your plea of guilty that we
23 spoke about at the beginning of your deposition?
24 MR. PIKE: Form.
25 THE WITNESS: Yes.
0206
1 BY MR. KUVIN:
2 Q. How long were you there?
3 A. 13 months, approximately.
4 Q. All right. And of those 13 months, how many
5 months were you there where you had to stay there 24
6 hours a
7 A. I don't recall specifically.
8 Q. More than a month?
9 A. Yes.
10 Q. More than two months?
11 A. Yes.
12 Q. More than three months?
13 A. Yes.
14 Q. More than four?
15 A. I think so, I don't remember.
16 Q. Do you recall when you were provided work
17 release, when you were able to leave during the daylight
18 hours?
19 A. Not with specificity.
20 Q. While you were there at the jail in Palm
21 Beach -- I'm going to show you what we'll mark as
22 Exhibit 18.
23 (Plaintiff's Exhibit No. 18 was marked for
24 identification.)
EFTA01158602
25
0207
1 BY MR. KUVIN:
2 Q. Did you purchase items from the jail?
3 MR. GOLDBERGER: Hang on a second.
4 MR. PIKE: Hold on one second.
5 THE WITNESS: It looks that way, yes, sir.
6 BY MR. KUVIN:
7 Q. Okay.
8 MR. PIKE: And the document speaks for itself,
9 the composite document speaks for itself.
10 BY MR. KUVIN:
11 Q. I'd like you to take a look at Exhibit 18. It
12 shows purchases -- well, does it show purchases by you?
13 MR. PIKE: Asked and answered.
14 THE WITNESS: Yes.
15 BY MR. KUVIN:
16 Q. Okay. And it appears those purchases took
17 place from 7/8/08 through 9/30/08 is the last one that I
18 have; is that correct?
19 MR. PIKE: The document speaks for itself.
20 BY MR. KUVIN:
21 Q. You can answer.
22 A. The document speaks for itself.
23 Q. Is that correct, the last date is 9/30/08?
24 A. The last date here is 9/30, yes.
25 MR. PIKE: With regard to what you provided to
0208
1 the witness.
2 MR. KUVIN: Sure, absolutely.
3 THE WITNESS: Okay.
4 BY MR. KUVIN:
5 Q. And just so we're clear, this composite
6 exhibit that we've marked as Exhibit 18 contains
7 purchases from 7/8/08, 7/15, 7/22, 7/29, 8/5, 8/12,
8 8/21, 8/26, 9/2, 9/9, 9/23 and 9/30, just so the record
9 is clear; there is no question.
10 A. Okay.
11 Q. Okay?
12 A. Uh-huh.
13 Q. All right. These items that you purchased,
14 did you utilize all of these items yourself?
15 MR. PIKE: Form, relevance.
16 THE WITNESS: I don't understand the question.
17 BY MR. KUVIN:
18 Q. Well, you purchased a number of items that are
19 shown in this receipt.
20 A. Yes.
21 Q. The question is: Did you use them yourself?
22 MR. PIKE: Same objection.
23 THE WITNESS: I don't know if I used all of
24 them, so...
25
0209
1 BY MR. KUVIN:
2 Q. Well, what did you do with the items that you
3 purchased?
4 MR. PIKE: Form, overbroad.
5 BY MR. KUVIN:
6 Q. You can answer.
7 A. I used some, I threw away some.
8 Q. Did you give any away?
9 A. Not that I remember.
EFTA01158603
10 MR. PIKE: Same objection.
11 BY MR. KUVIN:
12 Q. Did you provide any items that you purchased
13 to other inmates while you were there in jail?
14 MR. PIKE: Form.
15 THE WITNESS: Not to the best of my
16 recollection.
17 BY MR. KUVIN:
18 Q. Okay. With respect to all of the items that
19 are listed in these receipts, is it a safe assumption
20 that you either used them yourself or threw them away?
21 MR. PIKE: Asked and answered. If you don't
22 know -- if you know.
23 THE WITNESS: I don't know.
24 BY MR. KUVIN:
25 Q. I'm sorry? I didn't hear you.
0210
1 MR. PIKE: Asked and answered.
2 THE WITNESS: So should I answer?
3 MR. PIKE: You can answer again.
4 THE WITNESS: Ask the question again.
5 BY MR. KUVIN:
6 Q. So can we assume that all of the items that
7 are shown in these receipts were either used by you or
8 thrown away?
9 A. I don't even know if I received some of those
10 items, so I would assume I used most of them.
11 Q. Okay.
12 A. Okay?
13 Q. Sure. Take a look, I just want to make sure,
14 did you receive all these items?
15 A. I don't know.
16 MR. PIKE: Asked and answered.
17 BY MR. KUVIN:
18 Q.