EFTA01724063.pdf

112 1 THE VIDEOGRAPHER: Going off the video 2 record 1:49 p.m. 3 THE WITNESS: Thank you. 4 (Pause in the proceedings.) 5 THE VIDEOGRAPHER: Back on the video 6 record 2:04 p.m. 7 Q Mr. Epstein, when IIII was a 14-year old 8 girl, isn't it true that while you were 9 the massage table, you ordered to 10 and provide you'a massage? 11 A I believe I've answered that question, 12 didn't I? 13 Q I don't remember where we left off, 14 that's why. 15 MR. IIII: Form, argumentative, 16 speculation. It is compound and assumes 17 facts not in evidence and has been asked and 18 answered. But we did take a break, so you 19 can respond. 20 (Counsel addressing Mr. Epstein.) 21 A The current U.S. Attorney has described 22 your law firm as a criminal enterprise involved 23 in fabricating sexually charged cases against 24 people like me in order to fleece unsuspecting 25 investors out of millions of dollars. He used EFTA01724063  113 1 words like "bogus schemes." 2 Unfortunately at this time in response 3 to your questions, though I would like to answer 4 each and every one, I'm going to have to, on 5 advice of counsel, assert my Sixth Amendment, 6 Fifth Amendment and Fourteenth Amendment rights 7 under the U.S. Constitution, though I would like 8 to answer those questions. 9 Q While was a 14-year old girl 10 providing you a massage, you ordered her to IIIII 11 during that massage; isn't that 12 true? 13 MR. III/: Same objections, 14 argumentative, speculation, harassing, 15 assumes facts not in evidence and lacks 16 predicate. 17 A I asked her to 18 19 A I believe her own sworn testimony 20 contradicts that statement. However,.I would 21 like to answer all your questions here today, but 22 my attorneys advised me, at least today, Mr. 23 I must take my constitutional privileges 24 of the Sixth Amendment, Fifth Amendment and 25 Fourteenth Amendment, keeping in mind that your EFTA01724064  114 1 firm, of you, Mr. and Mr. 's firm 2 has been accused by the U.S. Attorney of 3 perpetrating one of the largest frauds in 4 Florida's history by crafting sexually charged 5 lawsuitS against people like me, to fleece from 6 local people millions of dollars. 7 Q And during this massage by , you 8 began to in front of her; isn't that 9 true? 10 MR. IIII: Same objections? 11 A Unfortunately, though I would like to 12 answer each one of your questions here today, my 13 attorneys have counseled me today at least, I 14 have to assert my Fifth Amendment, Sixth 15 Amendment and Fourteenth Amendment rights under 16 the U.S. Constitution, otherwise I risk losing 17 their effective representation, and the fact that 18 your firm has been accused of fabricating these 19 malicious lawsuits to fleece investors out of 20 millions of dollars, as described by the U.S. 21 Attorney here in South Florida as a criminal 22 enterprise involved in mail fraud, money 23 laundering... Unfortunately I would like to 24 answer each question, but I can't today. 25 Q Isn't it true that while you were EFTA01724065  115 1 2 14-year old 3 MR. Objection, argumentative. 4 Speculation. It is harassing. It assumes 5 facts not in evidence. The question 6 continues to lack predicate, and I also 7 believe the question has been asked and 8 answered sometime ago. 9 A Though I would like to answer each one 10 of your questions today, Mr. my counsel 11 has told me I cannot answer any questions that 12 may be relevant to this lawsuit. The fact that 13 your firm has been accused of major fraud, the 14 largest fraud in South Florida history, by the 15 U.S. Attorney calling your firm a criminal 16 enterprise involved in money laundering -- I 17 believe it is racketeering, but I could be 18 wrong... Monetary transactions via fraud, mail 19 fraud, conspiracy -- sorry -- I would like to 20 answer your questions but today on advice of 21 counsel, I am going to have to assert my rights. 22 Q Isn't it true also that while was a 23 14-year old female, you to the point 24 of while 25 EFTA01724066  116 1 MR. IIII: Same objections incorporated? 2 A Again, the question? 3 Q Isn't it true that during this sexual 4 massage, while you were -- that you 5 to the point of while you were 6 7 MR. IIII: Objection, argumentative, 8 speculation. It is compound. It is vague. 9 It assumes facts not in evidence and lacks 10 predicate. 11 A Though I would like to answer that 12 question with specificity and detail today, no 13 matter how much I would like to, my attorneys 14 have advised me I cannot. They advised me I must 15 assert my Fifth Amendment, Sixth Amendment and 16 Fourteenth Amendment rights under the U.S. 17 Constitution or potentially lose effective 18 representation, so therefore, I will assert those 19 rights. 20 Q Isn't it true that the ritual that I'm 21 describing occurred with IIII, approximately 100 22 times when she was between the ages of 13 and 16? 23 MR. Same objections, with the 24 additional objection of vague and 25 confusing. EFTA01724067  117 1 A Since your firm has been involved -- 2 according to the U.S. Attorney in crafting these 3 fraudulent lawsuits in order to fleece local 4 investors, and the fact that I believe in 's 5 sworn statements, that's what you've just alleged 6 at least is totally contradicted by your client's 7 own sworn statements, though I would like to 8 answer these questions today, my attorneys have 9 advised me I may not and advised me I must assert 10 my. Fifth, Sixth and Fourteenth Amendment rights 11 under the U.S. Constitution or potentially risk 12 losing effective representation. 13 Q In addition to the sexual abuse directed 14 against that I've just described, isn't it 15 true that you also paid her money to bring you 16 more than 50 other underage minor females for you 17 to similarly abuse? 18 MR. IIII: Same objections. 19 A Though I believe in her own sworn 20 testimony to the U.S. government that she 21 contradicts those assertions, and I'm sure maybe 22 you'll have some explanation at trial, but the 23 ladies and gentlemen of the jury should know 24 about your firm being accused by the U.S. 25 Attorney of perpetrating one of the largest EFTA01724068  118 1 frauds in U.S. history by crafting malicious 2 lawsuits of a sexual nature in order to fleece 3 investors out of millions of dollars, local 4 investors; and though I would like to answer your 5 questions in detail today, Mr. and Mr. 6 ,.my counsel says I may not and have asked 7 me to assert those rights, which'I must 8 unfortunately. 9 Q You keep bringing up this fraud of the 10 former law firm known as 11 in response to my questions, so I would 12 like you to tell the jury at this time which 13 allegation are you now saying is fraudulent or 14 untrue, that's been made by 15 MR. IIII: Form, confusing, compound, 16 and irrelevant. 17 MR. Only made irrelevant by 18 his answers. 19 MR. IIII: Same objections. 20 Q Do you understand the question? 21 . A No. 22 Q You made reference to -- in response to 23 my questions about what you did sexually to 24 25 A Yes, sir? EFTA01724069  119 1 Q -- you have responded with these fraud 2 allegations against the firm of 3 I want you to tell the jury 4 which allegations that is making against you 5 are you disputing at this time or calling a fraud 6 or calling untrue? 7 MR. 'III: Confusing, compound and -- if 8 the court reporter would read back Mr. 9 .Epstein's response, I think you will see the 10 way you just phrased the question 11 mischaracterizes his testimony. Because 12 well, I'll keep it there unless you want me 13 to go further. You want me to go further? 14 MR. No, I want him to go " 15 further. 16 MR. Mischaracterizes the 17 witness's testimony. 18 A 's own statements contradict every 19 one of your allegations that you've made to me 20 today, as a hypothetical. In her own words. And 21 you -- and the potential reasons this concerns me 22 is the fact that the law firm that represented 23 IIII and two others have been accused by the U.S. 24 Attorney of fraudulently producing cases against 25 me and others, to fleece investors in what he's EFTA01724070  120 1 described as one of the largest frauds in South 2 Florida's history. So, it concerns me. It is a 3 factor in the way I'm thinking about answering. 4 Sorry. 5 Q Each time that you 6 or otherwise , you paid 7 her $200; is that correct? 8 MR. 'III: Objection, argumentative, 9 speculative, harassing. It assumes facts 10 not in evidence, and with regard to this 11 line of questioning, the Court has already 12 ruled that the demeanor in which you're 13 presenting this question is improper, and 14 harassing, so if you would -- 15 MR. I'm very comfortable with 16 the demeanor right now, Mr. IIII. These are 17 just the facts of the lawsuit. The facts 18 are outrageous and I understand that, but 19 they have to be asked. 20 MR. IIII: Maybe the demeanor and tone 21 of your question is laced in a manner that 22 it is proper for the video, but the content 23 of the question is the same exact harassing 24 question that was deemed by the Judge to be 25 argumentative. I'm not saying that he's not EFTA01724071  121 1 going to answer your question. 2 MR. Okay. 3 MR. IIII: Or that you don't know what 4 his answer will be, but what I'm saying is: 5 could you rephrase the question? 6 Q Answer that question. I'll work on 7 rephrasing it for you at some point. 8 A Sorry, I forgot what the question is by 9 now. 10 0 Isn't it true that each time that you 11 interacted with sexually, meaning 12 her or her in some other way, 13 that you paid her $200 each time? 14 MR. IIII: Form. 15 THE WITNESS: Sorry? 16 MR. Form. Go ahead. 17 A I would like to answer each one of your 18 questions here today. However, my attorneys have 19 counseled me that today I have to assert my Fifth 20 Amendment, Sixth Amendment and Fourteenth 21 Amendment rights under the U.S. Constitution and 22 I'm cognizant of the fact that your firm has 23 crafted these malicious lawsuits, it has been 24 reported that the lawsuits are of a sexual 25 nature, in order to fleece investors, so though I EFTA01724072  122 1 would like to answer those questions, Mr. 2 and Mr. today I must keep my 3 counsel's advice. 4 Q Isn't it true that for each underage 5 minor that brought to you for the purposes 6 of you engaging in sexual activity, you paid her 7 $200? 8 MR. 'III: Objection, speculation. 9 Compound question, and it assumes facts not 10 in evidence. Therefore lacks predicate. 11 A Though I would like to answer that 12 question, as most of your other questions here 13 today, Mr. I intend to respond, 14 hopefully at some point to all of your questions, 15 but today my attorneys have advised me I must 16 invoke my Sixth Amendment, Fifth Amendment and 17 Fourteenth Amendment right under the U.S. 18 Constitution. 19 Q Over the course of relatively a roughly 20 three years, isn't it true that you 21 in a sexual manner on more than 50 22 occasions? 23 MR. IIII: Objection, argumentative. 24 Calls for speculation. It is overbroad, 25 confusing and vague, and it assumes facts EFTA01724073  123 1 not in evidence. 2 A Could you repeat the question for me? 3 I'm sorry, Mr. 4 Q Yes. The three-year period between 2002 and 2005 when you were engaging in sexual conduct • 6 with , isn't it true that that conduct took 7 place on more than 50 occasions? 8 MR. Same objections. 9 A I believe if you read your own client's 10 FBI statements, what her statement -- it changed 11 dramatically after she decided to file a 12 different lawsuit, at the request of you and your 13 firm, with one of your firms -- there have been 14 many firms it seems, was accused of major fraud. 15 Since the testimony has changed dramatically, I 16 would like to answer those questions, but today 17 my attorneys have advised me I must assert my 18 Sixth Amendment right, my Fifth Amendment right 19 and my Fourteenth Amendment right. 20 Q ** Your answers are not going to 21 incriminate you if the answer is "no," it is only 22 if the answer is "yes" that it will incriminate 23 you, so aren't you telling the jury every single 24 thing I've asked you is not part of a fraud, just 25 happens to be true, isn't it? EFTA01724074  124 1 MR. Objection, argumentative, 2 irrelevant and move to strike. I'm simply '3 going to instruct the witness not to answer 4 that question because.... I don't understand 5 it. I don't know what to say about that 6 question. 7 A (Gesturing.) 8 Q All of the things that I've told you or 9 that I've asked you about, you while 10 she was underage, you paying her for sexual 11 conduct, those are all things that really 12 happened, there is nothing about that, that 13 anybody has fabricated or made up, is there? 14 MR. IIII: Objection, argumentative, 15 speculative, it assumes facts not in 16 evidence, it certainly mischaracterizes the 17 witness's testimony all day, since I have 18 been here, and I have been here the whole 19 time. It assumes facts not in evidence. It 20 is also overbroad and substantially compound 21 because you're attempting to incorporate all 22 of your questions today into one question. 23 MR. I think you know, Mr. 24 IIII, your objection should be limited to 25 the form. If you object to the form, it is EFTA01724075  125 1 fine. 2 MR. a I'm sorry, that's -- 3 MR. You -- 4 MR. IIII: You've asked me several times today to tell you why. I thought I was 6 helping. I'm sorry. I certainly will keep 7 objecting to -- 8 MR. Appreciate it. 9 MR. IIII: -- the form. 10 MR. Thank you. 11 Q And your answer is? 12 A Repeat the question. 13 Q Every single allegation that has 14 made and I have now questioned you about in terms 15 of your sexual involvement with , they are 16 all true; isn't that correct? There is nothing 17 fabricated about any of these allegations, 18 correct? 19 MR. IIII: Objection, argumentative, 20 speculative, compound. It is vague, 21 overbroad -- 22 MR. You're objecting to form? 23 MR. IIII: Yes, assumes facts not in 24 evidence and lacks predicate. That is 25 form. EFTA01724076  126 1 A And I would like to answer that question 2 specifically today, however, on advice of counsel 3 they've suggested I take theiSixth amendment -- 4 assert my Sixth Amendment, Fifth Amendment and 5 Fourteenth Amendment rights under the U.S. 6 Constitution, keeping well aware of your firm's 7 responsibility in the largest fraud in Florida's 8 history by crafting sexually charged lawsuits 9 against people like me and others. 10 I believe in addition, since her 11 allegations, as you've phrased them, have changed 12 dramatically since her sworn statement, until in 13 fact, after she joined this firm charged with 14 this major fraud and most of her statements have 15 changed, I believe, so... 16 Q You remember when 17 when she was 16 years old, don't you? 18 MR. : Form, relevance, move to 19 strike? 20 A I would like to answer each one of your 21 questions here today, Mr. each and every 22 one of your questions. However, today my counsel 23 has told me I must assert my Sixtt. Amendment, 24 Fourteenth Amendment and Fifth Amendment rights 25 under the U.S. Constitution. EFTA01724077  127 1 Q Isn't it true that when was 14 2 years old, 15 years old and 16 years old, you 3 4 A Separate from the fact that in her own 5 testimony, her own sworn testimony under oath 6 before she decided to file a lawsuit for money, 7 there was never any discussion about anything 8 like that. I would like to answer that question, 9 but my attorneys have advised me, at least today, 10 that I must assert my Sixth Amendment, Fifth 11 Amendment and Fourteenth Amendment rights under 12 the U.S. Constitution. 13 Q Isn't it true when 14 at age 16, you no longer interacted with her 15 sexually but still demanded that she bring you 16 other underage minor females for you to sexually 17 exploit? 18 MR. Objection, speculation. 19 Compound. Harassing, and assumes facts not 20 in evidence. 21 A I believe her testimony changed 22 dramatically from her sworn statements to the 23 FBI -- 24 Q That's not a responsive -- 25 MR. IIII: Excuse me -- EFTA01724078  128 1 MR. It is not a responsive 2 answer so I won't allow 3 MR. IIII: That -- 4 MR. We'll move to strike it. 5 Let's have an answer to the question. 6 MR. IIII: The witness is trying. If 7 there is a legal basis for your moving to 8 strike, it would be taken up with the Court 9 and you can move to strike. 10 You can continue. 11 MR. Strike it, it is 12 nonresponsive? 13 A Your allegations that you keep throwing 14 at me, relate to the fact that testimony, 15 after giving a sworn statement to the FBI, 16 changed dramatically after she decided to file a 17 lawsuit for money, joining your firm that's been 18 accused by the U.S. Attorney of one of the 19 largest frauds in Florida's history. I would 20 like to answer those questions; however, on 21 advice of counsel today I must assert my Fifth 22 Amendment, Sixth Amendment and Fourteenth 23 Amendment rights under the U.S. Constitution. 24 4 when IIII was 25 she brought you at least ten underage minor EFTA01724079  129 1 females isn't that true? 2 MR. Objection, argumentative, 3 speculation. It is vague and assumes facts 4 not in evidence and lacks predicate. 5 A I -- I -- I unfortunately would like to 6 answer that question as well as every other 7 question you've asked me here today, but my 8 attorneys have advised my I must assert my Fifth 9 Amendment, Sixth Amendment and Fourteenth 10 Amendment rights under the U.S. Constitution. 11 Q After had 12 and you were being criminally investigated for 13 some of the conduct that we've discussed here 14 today; isn't it true that you personally hired 15 and retained and paid for an attorney to 16 represent IIII? 17 MR. Objection, speculation -- 18 MR. Object to the form, Mr. 19 20 MR. I will not. I am allowed to 21 assert the basis for my objections, I am not 22 limited to just saying "form." I'm able to 23 assert the basis as to why, so I don't waive 24 that basis. 25 MR. It is just more of this EFTA01724080  130 1 obstructionist -- 2 MR. It's not obstructionist, it 3 is objecting to form. What is 4 obstructionist is what we are doing now. I 5 will be finished within four seconds. So I 6 am going to object to form, it's 7 argumentative, speculative and it assumes 8 facts not in evidence and it lacks 9 predicate. That's it. 10 A I'm sorry. (Witness shrugs.) Again? 11 Q The response to the question. 12 A I don't know the question. 13 Q You don't remember the question? Did 14 you hire an attorney at some point in time? 15 Do you remember that? 16 MR. Same objection. 17 A Not to the best of my recollection. 18 Q Do you know 19 A ... Do I know ? I don't 20 believe I've ever met 21 Q Is it your testimony today then that you 22 never paid for an attorney to represent III 1 23 A (Witness shakes head.)... On advice of 24 my counsel, I would like to answer that question, 25 but on advice of counsel I'm going to have to EFTA01724081  131 1 assert my Sixth Amendment, Fourteenth Amendment 2 and Fifth Amendment rights against -- excuse me, 3 Sixth Amendment rights of the U.S. Constitution. 4 Q And that attorney that was paid for by 5 you, informed that if she were to tell the 6 FBI exactly what happened at your house, that her 7 You're aware of 8 that, correct? 9 MR. IIII: Same objections. 10 A I recognize, I believe she made one of 11 the statements at her deposition after she 12 decided to sue me fox a bunch of money and your 13 firm has represented a number of... cases of a 14 sexually charged nature that turned out to be 15 fraudulent in order to fleece local investors. 16 The U.S. Attorney described your firm and these 17 cases as a bogus scheme, and I'm aware of that, 18 and would like to answer your question in more 19 detail today, Mr. however my attorneys 20 advised me that at least today, I must assert my 21 rights under the Sixth Amendment, Fourteenth 22 Amendment and Fifth Amendment. 23 MR. IIII: It is the food. 24 MR. I didn't want him in the 25 room in mid answer. EFTA01724082  132 1 THE WITNESS: Ready? Thank you. 2 THE VIDEOGRAPHER: Going off the video 3 record 2:29 p.m. 4 (Pause in the proceedings.) 5 THE VIDEOGRAPHER: Back on the video 6 record 2:50 p.m. 7 Q Isn't it true, Mr. Epstein, that you 8 gave money to coerce her into interacting 9 with you sexually? 10 A Mr. I would like to answer each 11 and every one of your questions here today, but 12 unfortunately, like I've done with mostly all of 13 your other questions, I'm going to have to assert 14 my rights, Sixth Amendment, Fourteenth Amendment 15 and Fifth Amendment on advice of counsel. 16 Although I would like to answer, if I don't 17 follow my counsel's advice, I risk losing 18 representation. 19 Q While committing these sexual acts 20 against when she was just a minor, you knew 21 it would psychologically damage her; isn't that 22 true? 23 MR. Form, lacks predicate, 24 speculation. 25 A I intend to respond at some point to -- EFTA01724083  133 1 I would like to respond to each and every one of 2 your questions, but today on advice of my counsel 3 they've required me to. assert my Fifth Amendment, 4 Sixth Amendment and Fourteenth Amendment rights 5 under the U.S. Constitution, though I would like 6 to answer each of these questions. 7 Q In fact, you deliberately and 8 intentionally caused severe emotionally distress 9 to underage minor females, including ; isn't 10 that true? 11 MR. Objection, argumentative, 12 speculation, it is compound. And it assumes 13 facts not in evidence. 14 MR. ' Okay. 15 A I would like to answer that question, as 16 I would like to answer all of your other 17 questions today regarding However, my 18 attorneys today have advised me that I must 19 assert my Sixth Amendment right to effective 20 representation and 'my Fifth Amendment right and 21 my Fourteenth Amendment right. Though I would 22 like to answer that with specificity, I must 23 follow my attorney's advice. 24 Q Will you admit for the jury that you 25 were investigated federally for your illegal EFTA01724084  134 1 activities with underage minors? . 2 MR. Same objections. 3 A I would like to answer that question, as 4 well as all the other questions you've asked me 5 here today, especially since your firm has been 6 accused by the federal, I guess, the federal 7 government,... being considered a criminal -- you 8 firm has been considered and investigated as 9 being a criminal enterprise using sexually 10 fabricated, sexual cases... fabricated cases, to 11 fleece investors out of millions of dollars, but 12 I would like to answer your questions; however my 13 attorneys have demanded that I assert my rights 14 under the Sixth Amendment, Fifth Amendment and 15 Fourteenth Amendment. 16 Q In fact, as a result of that 17 investigation, you, as well as the United States 18 Attorney's Office entered into what has now been 19 known and referred to as the nonprosecution 20 agreement; isn't that correct? 21 MR. IIII: Same objection. The document 22 speaks for itself? 23 A You have to repeat the question. 24 Q As a result of the criminal 25 investigation into your activities with minor EFTA01724085  135 1 females, you reached a resolution with the United 2 States Attorney's Office, in what has now been 3 described as the nonprosecution agreement; is 4 that correct? 5 MR. I'm going to object. Vague, 6 confusing, misrepresents the agreement and 7 the document is the best evidence. Will you 8 mark it? 9 MR. I can mark it. We will 10 copy it at the end and mark it as Exhibit 2. 11 (Document, Nonprosecution Agreement, was 12 deemed, marked as Exhibit number 2 for 13 identification, as of this date.) 14 A Yes. 15 Q In that agreement, there are listed 16 co-conspirators of Jeffrey Epstein, those being 17 18 (phonetic) and a. Can you explain 19 to the jury what those individuals did 'for you 20 related to the crimes that were investigated by 21 the federal government? 22 A Co-conspirators? 23 Q Yes, it says "criminal charges against 24 any co-conspirators of Epstein including but not 25 limited to EFTA01724086  136 1 or Can you explain to 2 the jury what each of those four individuals did 3 for you or conspired with you to do? 4 MR. IIII: Object to the form of the 5 question? 6 A I would like to answer that question, 7 however, today my attorneys advise me that I must 8 assert my Sixth Amendment, Fifth Amendment and 9 Fourteenth Amendment rights under the U.S. 10 Constitution. 11 Q Isn't it fair to say that you, as well 12 as the co-conspirators, operated as an organized 13 criminal enterprise designed to sexually exploit 14 underage minors? 15 MR. Object to argumentative, 16 speculation. It is vague and it assumes 17 facts not in evidence. 18 A Are you suggesting it was a criminal 19 enterprise? Is that the words? 20 Q Yes. 21 A Though I would like to answer that 22 question today, I think the only criminal 23 enterprise that I have been reading about today 24 was your firm, that's been accused of being a 25 criminal enterprise involved in defrauding EFTA01724087  137 1 people, using mail fraud, wire fraud, money 2 laundering, the operation of the enterprise -- 3 this is by the U.S. Attorney (indicating), but 4 though I would like to answer your questions with 5 specificity today, on advice of counsel, though I 6 would like to answer it, they demanded I assert 7 my Sixth Amendment, Fourteenth Amendment and 8 Fifth Amendment right or I risk losing their 9 representation. 10 Q Did you care about any of the underage 11 minor females at the time when. you were engaging 12 in sexual conduct with them? 13 MR. IM Objection, argumentative. 14 Harassing, already been ruled upon by the 15 Court relative to this exact question. 16 MR. I feel comfortable with 17 the question. It goes to punitive damages. 18 The issue related to the Court was a 19 repetitive question on that topic or around 20 that general subject matter. -I'm just 21 asking for Mr. Epstein to tell the jury how 22 he felt about these girls, whether he cared 23 about them, when he was engaging in illegal 24 sexual conduct with them. 25 MR. Counsel, I'm going to EFTA01724088  138 1 instruct him not to answer the question. 2 You can certify it to the Court, if you 3 like. You know what the answer is going to 4 be; however you're attempting to lace this 5 video. You know the Court has already 6 ordered that these types of questions are 7 not permitted because they are argumentative 8 and harassing. In fact, other questions 9 bordered but this question is on exact point 10 with the Court's order. If you want to 11 withdraw the question, that's fine. 12 MR. I don't want to withdraw 13 the question. 14 MR. III/: Then I instruct him not to 15 answer. 16 MR. Mark that somehow, that 17 page, so we can find it in the record, 18 relative to the hearing that will be had on 19 that question and others similar. 20 Q At the time when you were engaging in 21 sexual conduct with underage females, you knew 22 that exposing them to this, was not beneficial or 23 good for these girls; isn't that true? 24 MR. IIII: Objection, argumentative, 25 speculation, assumes facts not in evidence. - EFTA01724089  139 1 Lacks predicate. 2 A Though I would like to answer that 3 question, like most of your other questions here 4 today, on advice of. counsel I must assert my 5 Fourteenth Amendment, Fifth Amendment and Sixth 6 Amendment rights. Though I would like to answer, 7 if I do so, I risk losing my effective 8 representation of counsel. 9 Q Isn't it true, Mr. Epstein, that the 10 only thing that you cared about was accessing as 11 many underage females as possible, for the 12 purposes of sex? 13 MR. Argumentative, speculation, 14 harassing. 15 A What's the question? 16 MR. IIII: And assumes facts not in 17 evidence. 18 Q Isn't it true that the only thing that 19 you cared about when you were interacting with 20 these underage females in a sexual manner, was 21 or your own personal gratification? 22 MR. Form, same exact objections. 23 A Though I would like to answer that 24 question, and to the ladies and gentlemen of the 25 jury, I would very much like to answer that EFTA01724090  140 1 question; however, today my attorneys have 2 advised me I must take -- assert my rights under 3 the Fourteenth, Sixth and Fifth Amendments of the 4 U.S. Constitution, or else I risk losing their 5 representation. 6 MR. IIII: And Mr. just so we 7 don't have to come back on the question that 8 I instructed him not to answer, if you would 9 go ahead and repeat that question, I will be 10 more than happy to let him respond. 11 MR. I don't remember the 12 question we will take it up with the Court 13 and we'll get a ruling on it. 14 MR. IIII: It was whether or not he 15 cared about these -- I believe you quoted it 16 as underage minors, but I would like the 17 court reporter to read back the question 18 just to conserve judicial resources and not 19 go back. So if she can reread the question 20 that would be good. 21 MR. If you can find the 22 question. 23 THE COURT REPORTER: Certainly. 24 MR. I think I know it. 25 Q Did you care about any of these underage EFTA01724091  141 1 minor females that you were engaging in sex with, 2 at the time when you were engaging in these 3 sexual activities? 4 MR. Same objeCtions, as before. 5 A Though I would like to answer that • • 6 question as well as most of your other questions, 7 if not all of your other questions here today, on 8 advice of counsel I will have to assert my 9 Fourteenth Amendment right, my Sixth Amendment 10 right and my Fifth Amendment right, because no 11 matter how much I actually want to answer that 12 question, if I do so I risk losing my counsel's 13 representation. 14 Q At the time you were engaging in sexual 15 activity with these underage minors, including 16 IIII, you knew that this conduct was illegal, 17 didn't you? 18 MR. III/: Same objections. Form. 19 A I would like to answer that question, as 20 well as most of your other questions here today; 21 however, today my counsel has instructed me to 22 assert my Fourteenth Amendment, Sixth Amendment 23 and Fifth Amendment right, and if.I do not, and 24 if, in fact, I answer that question -- if I can 25 answer that question, I potentially risk losing EFTA01724092  142 1 my effective counsel's representation. 2 Q In fact, you told many of these underage 3 minor females not to tell anybody what happened 4 with you in the house, or else they would be in 5 trouble; isn't that true? 6 MR. IIII: Form. 7 A I would like to answer that question, as 8 well as the other questions; however, my counsel 9 has advised me that today I must assert my 10 Fourteenth Amendment, Sixth Amendment and Fifth 11 Amendment rights under the U.S. Constitution. 12 Q The underage minor females that have 13 come forward with information about your sexual 14 interactions with them have been investigated, 15 harassed, humiliated in an effort for you to 16 intimidate them to go away. Is that true? 17 MR. IIII: Objection. Argumentative, 18 speculative, compound. It is overbroad, and 19 assumes facts not in evidence. 20 A Can you repeat the question? 21 Q Sure. Any underage minor female that 22 you engaged in sexual activity with, that has now 23 pursued a lawsuit against you, isn't it true that 24 you've spent a lot of money and a lot of 25 resources investigating them in an effort to EFTA01724093  143 1 intimidate them and hopefully make them go away? 2 MR. 'III: Same objections. 3 A I believe your client's testimony 4 changed dramatically when she joined up with you 5 and your law firm, accused of fraud, when she 6 decided to change her testimony, at least from 7 what the statements said, both to the police and 8 to the FBI, and decided to seek money. However, 9 anything above that or beyond that, I'm going to 10 have to, in fact, assert my Fifth Amendment, 11 Sixth Amendment and Fourteenth Amendment rights 12 as directed by my competent counsel. 13 Unfortunately, they have told me if I don't, I 14 risk losing their representation. 15 Q All right, I'll give you a chance here 16 since you keep bringing up her statement to the 17 FBI as opposed to her sworn testimony for 13 18 hours under oath in this case. Are you saying 19 that the sworn testimony to the FBI was, in fact, 20 the truth? 21 A What I'm saying is, it seems her 22 testimony has changed dramatically after she 23 joined your firm, that's all. 24 Q Okay. Irrespective of her testimony, 25 you've read her testimony and you read her EFTA01724094  144 1 testimony -- to the FBI. You watched her 2 deposition when it was being taken. Which -- 3 A You're making assumptions, I'm sorry. 4 MR. Let him finish the question. 5 THE WITNESS: Sorry. 6 A My fault. 7 MR. IIII: Then I'll object and you'll 8 respond. 9 Q Which are you saying is the truthful 10 testimony, her statement to the FBI or the 11 videotaped deposition that you watched? 12 MR. IIII: Object to the form. 13 A What I've said, and I think I'll repeat 14 myself is until she joined your firm and started 15 to seek money, her testimony was different. 16 That's my understanding. 17 Q Are you denying any sexual involvement 18 with at this time? 19 MR. IIII: Form. 20 A I would like to answer that question. I 21 would like to answer it as with most of your 22 questions here today; however, my attorneys have 23 advised me that I must take that -- assert my 24 rights under the Sixth Amendment, Fourteenth 25 Amendment and Fifth Amendment, no matter how much . . . EFTA01724095  145 1 I would like to answer that question, or 2 potentially risk losing my counsel. 3 Q Isn't your game plan with all of these 4 civil lawsuits that have been filed against you, 5 to spend as much money as you can to investigate, 6 and harass these young women into hopefully 7 dropping the lawsuits against you? 8 MR. III': Objection. Relevance. Move 9 to strike. It is argumentative and 10 harassing. 11 A I would like to answer that question. I 12 think you know the answer to that question. 13 Q Yes. 14 A (Witness nods.) However, today my 15 attorneys have advised me I must assert my Sixth 16 Amendment rights, my Fourteenth Amendment rights 17 and my Fifth Amendment rights. 18 Q You don't have any remorse for the 19 sexual abuse that you committed against , do 20 you? 21 MR. IIII: Objection. It is 22 argumentative. It is harassing. It is, I 23 believe, confined under the Judge's order 24 and it assumes facts not in evidence? 25 A That being said, I would like to answer EFTA01724096  146 1 that question today, but my attorneys have 2 advised me that I must assert my Fourteenth 3 Amendment rights, my Fifth Amendment rights and 4 my Sixth Amendment rights. 5 Q In fact, you recently sued , didn't 6 you? 7 A Yes, and you and your firm that's been 8 accused of the largest fraud in Florida's 9 history, described by the U.S. Attorney as a 10 criminal enterprise involved in money laundering, 11 conspiracy to commit one crime -- excuse me, mail 12 fraud, commit conspiracy to commit wire fraud. 13 Yes, I sued you, your firm and 14 0 ** Tell the jury -- 15 A Yes. 16 Q -- the basis for the evidence that you 17 have to support the allegations in the complaint 18 against 19 MR. IIII: I'm going to instruct the 20 witness not to answer that question in this 21 medium, as it is wholly irrelevant 22 currently, as were it, to this particular 23 lawsuit. 24 MR. Just so you can rethink 25 that position, the lack of remorse goes to EFTA01724097  147 1 punitive damages, that is an aspect of the 2 case that IIII has against Mr. Epstein. 3 MR. IIII: This lawsuit, the current one 4 Mr. Epstein is noticed for, and the lawsuit 5 in which Mr. Epstein has filed against the 6 former and 7 Mr. is not proper for this 8 medium -- 9 MR. I understand your 10 position. 11 MR. III': -- in that regard, I'm going 12 to instruct him not to answer any questions 13 relative to that lawsuit because of that 14 objection, as well as, it is my 15 understanding that Mr. has set Mr. 16 Epstein's deposition, I believe, either 17 early next week or mid-March, on the case of 18 Epstein versus IIII and 19 'lilt' Mr. as well as 20 Therefore when that time approaches, that 21 would be the appropriate time for those type 22 of questions, related to that lawsuit. 23 MR. I understand your position 24 completely, Mr. 25 MR. IIII: Thank you. EFTA01724098  148 1 Q ** But as it relates to, obviously 2 sued you making the allegations that you sexually 3 her from when she was 13 years old to 4 when she was 16 years old and now you've sued her 5 in something that is seemingly related to that 6 case, and I just want to understand what your 7 factual basis is, or what evidence you're using 8 to support your lawsuit against so that the 9 jury can he valuate whether that is evidence of 10 lack of remorse that would go to punitive damages 11 claims that has against you. 12 MR. : I would instruct him not to 13 answer that question, for the same reasons 14 stated. 15 MR. Let's mark that. 16 Q Is it your feeling that because you are 17 wealthy and these children are poor, that you are 18 entitled to sexually a