EFTA01249325.pdf
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• UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE,
Plaintiff,
vs. Case No. 08-80893-
CIV-MARRA/JOHNSON
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
MARK EPSTEIN
September 21, 2009
• 11:30 a.m.
One Penn Plaza,
New York, New York
Jacklyn Lisi
•
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515 East Las Olas Boulevard
ESQUIRE Fort Lauderdale, FL 33301
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EFTA_00 108549
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EFTA 00108550
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• UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE,
Plaintiff,
vs. Case No. 08-80893-
CIV-MARRA/JOHNSON
JEFFREY EPSTEIN,
Defendant.
DEPOSITION of MARK EPSTEIN, taken by
• Defendants, at the offices of Esquire Deposition Solutions,
One Penn Plaza, New York, New York 10119, on Monday,
September 21, 2009, commencing at 11:30 a.m., before Jacklyn
Lisi, a Shorthand Reporter and notary public, within and for
the State of New York.
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Mark Epstein September 21, 2009
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1
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APPEARANCES :
ROTHSTEIN ROSENFELDT ADLER, ESQS.
•
Attorneys for Plaintiffs, EW, LM and Jane Doe
3 Las Olas City Centre, Suite 1650
401 East Las Olas Boulevard
4 Fort Lauderdale, Florida 33301
5 BY: BRAD J. EDWARDS, ESQ.
6
7 LEOPOLD KUVIN, ET AL
Attorneys for Plaintiff, BB
8 2925 PGA Boulevard, Suite 200
Palm Beach Gardens, Florida 33410
9
BY: ADAM LANGINO, ESQ.
10 (via telephone)
11
COHEN & GRESSER, LLP
12 Attorneys for the Witness, Mark Epstein
100 Park Avenue
13 New York, New York 10017
14
15
BY: MARK S. COHEN, ESQ.
ALEXIS G. STONE, ESQ. •
16
PODHURST ORSECK, et al
17 Attorneys for Plaintiffs, Jane Does 101 and 102
25 West Flagler Street, Suite 800
18 Miami, Florida 33130
19 BY: KATHERINE EZELL, ESQ.
(via telephone)
20
21
MERMELSTEIN & HOROWITZ, ESQS.
22 Attorneys for Plaintiffs, Jane Does 2 through 8
18205 Biscayne Boulevard, Suite 2218
23 Miami, Florida 33160
24 BY: ADAM H. HOROWITZ, ESQ.
(via telephone)
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Mark Epstein September 21, 2009
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• 1
2
APPEARANCES (continued)
RICHARD H. WILLITS, ESQ.
3 Attorney for Plaintiff, â–
2290 10th Avenue North, Suite 404
4 Lake Worth, Florida 33461
(via telephone)
5
6 BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
Attorneys for the Defendant, Jeffrey Epstein
515 North Flagler Drive, Suite 400
West Palm Beach, Florida 33401
BY: ROBERT CRITTON, ESQ.
(via telephone)
*
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Mark Epstein September 21, 2009
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4
1 STIPULATIONS
2
3 IT IS HEREBY STIPULATED, by and between the attorneys
4 for the respective parties hereto, that all rights provided
5 by the C.P.L.R., and Part 221 of the Uniform Rules for the
6 Conduct of Depositions, including the right to object to any
7 question, except as to form, or to move to strike any
8 testimony at this examination is reserved; and in addition,
9 the failure to object to any question or to move to strike
10 any testimony at this examination shall not be a bar or
11 waiver to make such motion at, and is reserved to, the trial
12 of this action.
13 This deposition may be sworn to by the witness being
14
15
examined before a Notary Public other than the Notary Public
before whom this examination was begun, but the failure to
•
16 do so or to return the original of this deposition to
17 counsel, shall not be deemed a waiver of the rights provided
18 by Rule 3116 of the C.P.L.R. and shall be controlled
19 thereby.
20 The filing of the original of this deposition is
21 waived.
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Mark Epstein September 21, 2009
5
• 2
M. Epstein
THE REPORTER: Please state your name
3 and address for the record?
4 THE WITNESS: (Witness refused to give
5 his address to the court reporter.)
6 MR. COHEN: On the record.
7 For the witness, Mark Epstein, Mark
8 Cohen and Alexis Stone of Cohen & Gresser, 100
9 Park Avenue, New York, New York.
10 MR. EDWARDS: Brad Edwards on behalf
11 of EW, LM and Jane Doe.
12 MR. CRITTON: Robert Critton on
13 behalf of Jeffrey Epstein.
• 14
15
MS. EZELL:
Jane Does 101 and 102.
Kathy Ezell on behalf of
16 MR. HOROWITZ: Adam Horowitz on
17 behalf of Plaintiffs, Jane Does 2 through 8.
18 MR. WILLITS: Richard Willits on
19 behalf of
20 MR. LANGINO: Adam Langino on behalf
21 of Plaintiff, BB.
22 MR. EDWARDS Okay. That's everybody.
23 MR. COHEN: Okay. Before I start,
24 this is Mark Cohen on behalf of Mark Epstein,
25 I just want to put on the record the details
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Mark Epstein September 21, 2009
•
6
1 M. Epstein
2 of a conversation I've had with Mr. Edwards
3 and make sure that all counsel is agreeable to
4 this.
5 My client, Mark Epstein, is very
6 concerned about being videotaped and having
7 his image recorded.
8 He is concerned about possible future
9 uses of his image. And so Mr. Edwards and I
10 have agreed that this recording, the videotape
11 of my client, will be confidential and will
12 not be revealed in public unless and until
13 there is an order by a court in one of the
14
15
cases that are involved in these depositions
that orders that the video be made public.
•
16 We are prepared to proceed on that
17 basis.
18 As I understand, Mr. Edwards is
19 prepared to proceed, but obviously we need the
20 agreement of all counsel.
21 MR. WILLITS: Richard Willits agrees.
22 MR. CRITTON: Robert Critton agrees.
23 MS. EZELL: Kathy Ezell agrees.
24 MR. EDWARDS: Adam?
25 MR. HOROWITZ: Adam Horowitz, that's
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Mark Epstein September 21, 2009
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• 1
2 fine.
M. Epstein
3 MR. LANGINO: The same with Adam
4 Langino, that's fine.
5 MR. COHEN: All right. Thank you.
6 MR. EDWARDS And Sid Garcia is not in
7 and he is not supposed to be in; right?
8 MR. CRITTON: This is Bob Critton.
9 I assume -- I don't know whether he
10 was going to come or not, but I assume that
11 everyone will also abide and not give Mr.
12 Garcia a copy of the video until he also
13 affirms in writing to Mr. Cohen that he's
• 14
15
agreed to be bound by the same agreement.
MR. EDWARDS: Okay.
16 THE VIDEOGRAPHER: This is tape
17 number one to the videotape deposition of Mark
18 Epstein in the matter of Jane Doe versus
19 Jeffrey Epstein being held before the United
20 States District Court in the Southern District
21 of Florida, case file number 08-80893.
22 This deposition is being held at
23 Esquire Deposition Solutions, One Penn Plaza,
24 New York, New York on September 21, 2009. The
25 time is 11:41 a.m.
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Mark Epstein September 21, 2009
•
8
1 M. Epstein
2 My name is Peter Ledwith. I'm the
3 videographer. The court reporter is Jackie
4 Lisi.
5 Counsel, will you please introduce
6 yourselves and who you represent?
7 MR. EDWARDS: Brad Edwards. I
8 represent EW, LM and Jane Doe.
9 MR. COHEN: Mark Cohen and Ally
10 Stone. I represent the witness, Mark Epstein.
11 MR. CRITTON: Robert Critton on
12 behalf of the defendant, Jeff Epstein.
13 MR. WILLITS: Richard Willits on
14
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behalf of
MR. LANGINO: Adam Langino on behalf
•
16 of Plaintiff BB.
17 MR. HOROWITZ: Adam Horowitz on
18 behalf of plaintiffs Jane Does numbers 2
19 through 8.
20 THE VIDEOGRAPHER: Will the court
21 reporter please swear in the witness?
22 MARK EPSTEIN,
23 having been first duly affirmed, was examined
24 and testified as follows:
25 THE WITNESS: I am an atheist, but I
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Mark Epstein September 21, 2009
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• 1
2
M. Epstein
will affirm I'll tell the truth.
3 EXAMINATION BY
4 MR. EDWARDS:
5 Q. Can you tell us your name?
6 A. Mark Epstein.
7 THE VIDEOGRAPHER: Can you put the
8 microphone on your shirt, please?
9 THE WITNESS: Mark Epstein.
10 Q. Okay. And your date of birth,
11 please?
12 A.
13 Q• And what is your relationship with
• 14
15
the defendant in this case, Jeffrey Epstein?
A. He is my brother.
16 Q. Are you currently married?
17 A. No.
18 Q. What is your current address?
19 A. I'm not giving out my address. I'm
20 concerned about my personal safety because of
21 the nature of this case. You can use his
22 address. You can use my attorney's address.
23 Q. Please elaborate on that for me that
24 you are concerned for your safety because of
25 the nature of this case?
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Mark Epstein September 21, 2009
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1 M. Epstein
2 A. Because I've read -- well, I know
3 that Jeffrey hired a detective or someone from
4 the police when he went out on his days out.
5 So obviously there is probably a concern for
6 safety.
7 I don't want anything to do with this
8 case. I have nothing to do with this case. I
9 don't want my identifying information on any
10 kind of public record.
11 MR. COHEN: If it will make it
12 easier, Mr. Edwards, this is Mark Cohen
13 speaking. Mr. Mark Epstein is authorizing my
14
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firm to accept service if there is a future
subpoena or a need to contact him again.
•
16 THE WITNESS: Before we go on, I want
17 to make a statement.
18 I want to say on the record that
19 initially I was improperly served with a
20 subpoena from Florida, it was supposed to come
21 from New York.
22 It also did not include the required
23 documents giving me my rights and obligations
24 under the Florida laws. So it's a breach of
25 some kind of ethics.
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Mark Epstein September 21, 2009
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M. Epstein
2 So in my book, you are either
incompetent, devious or have no ethical
compass.
So you are not on my high list.
6 Continue with your questions. I just wanted a
7 record of that.
8 MR. CRITTON: Brad, can you move the
9 phone a little closer to Mr. Epstein? I heard
10 you and I heard Mr. Cohen fine, but I'm having
11 trouble with Mr. Epstein.
12 MR. EDWARDS: All right.
13 MR. CRITTON: Thank you.
• 14
15
MR. EDWARDS: I apologize for your
feelings about the subpoena.
16 THE WITNESS: Not accepted.
17 This is too serious of a matter.
18 BY MR. EDWARDS:
19 Q. You do realize that you are
20 subpoenaed to testify today in cases that
21 involve your brother having sex or engaging in
22 sex acts with minors; correct?
23 MR. CRITTON: Form?
24 MR. COHEN: That's --
25 A. I know there is a case against my
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Mark Epstein September 21, 2009
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1 M. Epstein
2 brother. I know that.
3 Q. And you are aware that there are
4 multiple attorneys on the phone that represent
5 girls who were under-age when Mr. Epstein had
6 sex with them?
7 A. I know there are multiple attorneys
8 on the phone.
9 Q. Okay. Have you read the newspaper
10 articles about your brother that detail your
11 brother having sex with under-age girls?
12 MR. CRITTON: Form.
13 A. I've read some of the papers.
14
15
Q.
wrong?
You agree that sex with minors is •
16 MR. CRITTON: Form.
17 MR. COHEN: Objection.
18 Q. You can answer.
19 A. I have no opinion on that.
20 Q. Okay.
21 A. I'm not here to give opinions. I'm
22 here for facts. So ask me questions about
23 facts and I'll be glad to answer them.
24 Q. Well, do you agree with the laws that
25 protect under-age children from adult sexual
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Mark Epstein September 21, 2009
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• 1
2 predators?
M. Epstein
3 MR. COHEN: Objection.
4 MR. CRITTON: Form.
5 A. My information on the case is my
6 brother I know had to spend sometime in jail
7 for some prostitution charge.
8 So I assume the attorneys are
representing the prostitutes he was involved
10 with, so I don't know what the ages of them
11 are or were.
12 I'm not involved with the case. I
13 don't watch all the details about it. That's
• 14
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all.
Q. Would it surprise you to learn that
16 there were more than 30 girls between the ages
17 of 12 and 15 that your brother engaged in sex
18 acts with?
19 MR. CRITTON: Form.
20 A. I don't get surprised by very many
21 things in this world.
22 Q. But you and your brother are a year
23 apart; right?
24 A. 18 months.
25 O. And you grew up together?
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Mark Epstein September 21, 2009
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1 M. Epstein •
2 A. Sure.
3 Q• You still talk to him?
4 A. Occasionally, rarely.
5 Q. So when I ask you, does it surprise
6 you, you are saying that it doesn't surprise
7 you that your older brother engaged in sex
8 with more than 30 girls between 12 and
9 15 years old?
10 MR. COHEN: Objection.
11 MR. CRITTON: Form.
12 A. I don't know how to answer that
13 question. I don't know if it's true, and I
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don't know what the story is.
It's not -- ask me a question about
•
16 facts I'm not going to give you opinions
17 here, that's not what I'm here for.
18
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Mark Epstein September 21, 2009
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• 1
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M. Epstein
3
4
6
7 MR. EDWARDS: Counsel?
8 MR. COHEN: I would suggest you move
9 to an area that's likely to lead to you
10 gathering relevant evidence.
11 We can come back to this burning
12 question maybe later.
13 MR. CRITTON: Let me also add that I
• 14
15
can only object to form, but I also want to
put on the record, other than his name and he
16 is related to Mr. Epstein, there is not one
17 piece of evidence or --
18 THE COURT REPORTER: I can't hear
19 you.
20 MR. CRITTON: I'm sorry. I just want
21 to note for the record that other than his
22 name and his relationship to Mr. Epstein, to
23 Jeffrey Epstein, there has been nothing of
24 relevance or materiality that would lead to
25 admissible evidence at the time of trial.
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Mark Epstein September 21, 2009
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16
1 M. Epstein
2 This is being done to harass or
3 humiliate Mr. Mark Epstein and/or my client.
4 It certainly borders on that, but he is not an
5 expert, his opinions are irrelevant in this
6 case, and as is his own family situation
7 but --
8 MR. EDWARDS: Mr. Critton, as you
9 stated first, I think that your objection is
10 limited to the form. Thanks.
11 Can I mark this as an exhibit?
12 (Plaintiff's Exhibit 1 was so marked
13 for identification.)
14
15
MR. COHEN: I will say that I join in
Mr. Critton's objection for the record.
•
16 BY MR. EDWARDS:
17 Q. How frequently do you talk with your
18 brother now?
19 A. Maybe once every couple of weeks or
20 so, but "now° being just the last month or
21 two.
22 Q. Okay. When you first learned of a
23 criminal investigation into your brother, did
24 you talk to him about the substance of those
25 allegations?
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Mark Epstein September 21, 2009
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M. Epstein
2 A. No.
3 Q. Have you ever asked him or had a
4 conversation with him about the allegations
5 that he's had sex with numerous under-age
6 kids?
7 A. No.
8 Q. Is there a reason why you wouldn't
9 ask him questions about him engaging in sex
10 with 13, 14-year old kids?
11 A. We are not very close. We don't talk
12 very often.
13 MR. CRITTON: Form.
• 14 Q. But when you do talk to him, that
15 conversation doesn't come up?
16 A. No.
17 Q. He went to jail. Did he ever tell
18 you why he went to jail?
19 A. No.
20 Q. Are you familiar with the property at
21
22 A. Yes, I am.
23 Q. Who owns that property?
24 A. Dara Partners.
25 Q. And what is Jeffrey Epstein's
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Mark Epstein September 21, 2009
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1
2
M. Epstein
affiliation with that property?
•
3 A. He rents some apartments in there.
4 Q. How many apartments does Jeffrey
5 Epstein rent at
6 A. It's either 8 or 10, I am not sure.
7 Q. Who are the residents of the
8 apartments that Jeffrey Epstein rents at that
9 location?
10 A. I have no idea.
11 MR. CRITTON: Brad, what was the
12 answer to the last one?
13 MR. COHEN: He has no idea.
14
15
A. I know his pilots used to stay there,
but I don't think he is using pilots any more.
•
16 Q. Why does he rent so many places at
17 the same location?
18 A. I have no idea.
19 Q. Have you ever had any affiliation
20 with that location?
21 A. Sure.
22 Q. In what way?
23 A. I'm one of the partners of Dara
24 Partners.
25 Q. So does your brother rent from you?
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Mark Epstein September 21, 2009
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• 1
2 A.
M. Epstein
No, he rents from Dara Partners. My
3 partner handles that property, I don't know
4 any of the tenants in that building other than
5 one or two.
6 Q. What are the names of the one or two
7 that you do know?
8 A. It is my ex, so I'm not going to give
9 you her name.
10 Q. Is that somebody who lives in one of
11 the places rented by your brother Jeffrey
12 Epstein?
13 A. No.
• 14
15
Q. Do you know any of the tenants that
live in the places rented by your brother,
16 Jeffrey Epstein?
17 A. No.
18 Q. Do you know
19 A. I know the name. I don't know her.
20 Q. Do you know what her relationship is
21 to your brother?
22 A. I think she worked for him.
23 Q. In what capacity?
24 A. I have no idea.
25 Q. Do you know if she lives in
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Mark Epstein September 21, 2009
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20
1 M. Epstein
2
3 A. I don't know where she lives.
4 Q. Would you know her if you saw her?
5 A. No.
6 Q. You've never seen her before?
7 A. I might have seen her somewhere, I
8 don't know.
9 Q. Have you ever talked to her?
10 A. I don't recall talking to her.
11 Q. Do you know
12 A. I know of her.
13 Q. How do you know of her?
14
15
A.
Q.
In the papers.
What papers?
•
16 A. Newspapers. I read some articles.
17 Q. Newspapers about your brother?
18 A. Relating to his case, yes.
19 Q. Okay. And what is your understanding
20 of her relationship with your brother?
21 A. I don't have an understanding about
22 it.
23 MR. CRITTON: Form.
24 A. My brother and I do not have a close
25 relationship, so what he does is his business
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Original Transcript
• UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE,
Plaintiff,
vs. Case No. 08-80893-
CIV-MARRA/JOHNSON
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
MARK EPSTEIN
September 21, 2009
• 11:30 a.m.
One Penn Plaza,
New York, New York
Jacklyn Lisi
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1
• UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE,
Plaintiff,
vs. Case No. 08-80893-
CIV-MARRA/JOHNSON
JEFFREY EPSTEIN,
Defendant.
DEPOSITION of MARK EPSTEIN, taken by
• Defendants, at the offices of Esquire Deposition Solutions,
One Penn Plaza, New York, New York 10119, on Monday,
September 21, 2009, commencing at 11:30 a.m., before Jacklyn
Lisi, a Shorthand Reporter and notary public, within and for
the State of New York.
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Mark Epstein September 21, 2009
2
1
2
APPEARANCES :
ROTHSTEIN ROSENFELDT ADLER, ESQS.
•
Attorneys for Plaintiffs, EW, LM and Jane Doe
3 Las Olas City Centre, Suite 1650
401 East Las Olas Boulevard
4 Fort Lauderdale, Florida 33301
5 BY: BRAD J. EDWARDS, ESQ.
6
7 LEOPOLD KUVIN, ET AL
Attorneys for Plaintiff, BB
8 2925 PGA Boulevard, Suite 200
Palm Beach Gardens, Florida 33410
9
BY: ADAM LANGINO, ESQ.
10 (via telephone)
11
COHEN & GRESSER, LLP
12 Attorneys for the Witness, Mark Epstein
100 Park Avenue
13 New York, New York 10017
14
15
BY: MARK S. COHEN, ESQ.
ALEXIS G. STONE, ESQ. •
16
PODHURST ORSECK, et al
17 Attorneys for Plaintiffs, Jane Does 101 and 102
25 West Flagler Street, Suite 800
18 Miami, Florida 33130
19 BY: KATHERINE EZELL, ESQ.
(via telephone)
20
21
MERMELSTEIN & HOROWITZ, ESQS.
22 Attorneys for Plaintiffs, Jane Does 2 through 8
18205 Biscayne Boulevard, Suite 2218
23 Miami, Florida 33160
24 BY: ADAM H. HOROWITZ, ESQ.
(via telephone)
25
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Mark Epstein September 21, 2009
3
• 1
2
APPEARANCES (continued)
RICHARD H. WILLITS, ESQ.
3 Attorney for Plaintiff, â–
2290 10th Avenue North, Suite 404
4 Lake Worth, Florida 33461
(via telephone)
5
6 BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
Attorneys for the Defendant, Jeffrey Epstein
515 North Flagler Drive, Suite 400
West Palm Beach, Florida 33401
BY: ROBERT CRITTON, ESQ.
(via telephone)
*
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Mark Epstein September 21, 2009
•
4
1 STIPULATIONS
2
3 IT IS HEREBY STIPULATED, by and between the attorneys
4 for the respective parties hereto, that all rights provided
5 by the C.P.L.R., and Part 221 of the Uniform Rules for the
6 Conduct of Depositions, including the right to object to any
7 question, except as to form, or to move to strike any
8 testimony at this examination is reserved; and in addition,
9 the failure to object to any question or to move to strike
10 any testimony at this examination shall not be a bar or
11 waiver to make such motion at, and is reserved to, the trial
12 of this action.
13 This deposition may be sworn to by the witness being
14
15
examined before a Notary Public other than the Notary Public
before whom this examination was begun, but the failure to
•
16 do so or to return the original of this deposition to
17 counsel, shall not be deemed a waiver of the rights provided
18 by Rule 3116 of the C.P.L.R. and shall be controlled
19 thereby.
20 The filing of the original of this deposition is
21 waived.
22
23
24
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Mark Epstein September 21, 2009
5
• 2
M. Epstein
THE REPORTER: Please state your name
3 and address for the record?
4 THE WITNESS: (Witness refused to give
5 his address to the court reporter.)
6 MR. COHEN: On the record.
7 For the witness, Mark Epstein, Mark
8 Cohen and Alexis Stone of Cohen & Gresser, 100
9 Park Avenue, New York, New York.
10 MR. EDWARDS: Brad Edwards on behalf
11 of EW, LM and Jane Doe.
12 MR. CRITTON: Robert Critton on
13 behalf of Jeffrey Epstein.
• 14
15
MS. EZELL:
Jane Does 101 and 102.
Kathy Ezell on behalf of
16 MR. HOROWITZ: Adam Horowitz on
17 behalf of Plaintiffs, Jane Does 2 through 8.
18 MR. WILLITS: Richard Willits on
19 behalf of
20 MR. LANGINO: Adam Langino on behalf
21 of Plaintiff, BB.
22 MR. EDWARDS Okay. That's everybody.
23 MR. COHEN: Okay. Before I start,
24 this is Mark Cohen on behalf of Mark Epstein,
25 I just want to put on the record the details
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Mark Epstein September 21, 2009
•
6
1 M. Epstein
2 of a conversation I've had with Mr. Edwards
3 and make sure that all counsel is agreeable to
4 this.
5 My client, Mark Epstein, is very
6 concerned about being videotaped and having
7 his image recorded.
8 He is concerned about possible future
9 uses of his image. And so Mr. Edwards and I
10 have agreed that this recording, the videotape
11 of my client, will be confidential and will
12 not be revealed in public unless and until
13 there is an order by a court in one of the
14
15
cases that are involved in these depositions
that orders that the video be made public.
•
16 We are prepared to proceed on that
17 basis.
18 As I understand, Mr. Edwards is
19 prepared to proceed, but obviously we need the
20 agreement of all counsel.
21 MR. WILLITS: Richard Willits agrees.
22 MR. CRITTON: Robert Critton agrees.
23 MS. EZELL: Kathy Ezell agrees.
24 MR. EDWARDS: Adam?
25 MR. HOROWITZ: Adam Horowitz, that's
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Mark Epstein September 21, 2009
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• 1
2 fine.
M. Epstein
3 MR. LANGINO: The same with Adam
4 Langino, that's fine.
5 MR. COHEN: All right. Thank you.
6 MR. EDWARDS And Sid Garcia is not in
7 and he is not supposed to be in; right?
8 MR. CRITTON: This is Bob Critton.
9 I assume -- I don't know whether he
10 was going to come or not, but I assume that
11 everyone will also abide and not give Mr.
12 Garcia a copy of the video until he also
13 affirms in writing to Mr. Cohen that he's
• 14
15
agreed to be bound by the same agreement.
MR. EDWARDS: Okay.
16 THE VIDEOGRAPHER: This is tape
17 number one to the videotape deposition of Mark
18 Epstein in the matter of Jane Doe versus
19 Jeffrey Epstein being held before the United
20 States District Court in the Southern District
21 of Florida, case file number 08-80893.
22 This deposition is being held at
23 Esquire Deposition Solutions, One Penn Plaza,
24 New York, New York on September 21, 2009. The
25 time is 11:41 a.m.
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Mark Epstein September 21, 2009
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8
1 M. Epstein
2 My name is Peter Ledwith. I'm the
3 videographer. The court reporter is Jackie
4 Lisi.
5 Counsel, will you please introduce
6 yourselves and who you represent?
7 MR. EDWARDS: Brad Edwards. I
8 represent EW, LM and Jane Doe.
9 MR. COHEN: Mark Cohen and Ally
10 Stone. I represent the witness, Mark Epstein.
11 MR. CRITTON: Robert Critton on
12 behalf of the defendant, Jeff Epstein.
13 MR. WILLITS: Richard Willits on
14
15
behalf of
MR. LANGINO: Adam Langino on behalf
•
16 of Plaintiff BB.
17 MR. HOROWITZ: Adam Horowitz on
18 behalf of plaintiffs Jane Does numbers 2
19 through 8.
20 THE VIDEOGRAPHER: Will the court
21 reporter please swear in the witness?
22 MARK EPSTEIN,
23 having been first duly affirmed, was examined
24 and testified as follows:
25 THE WITNESS: I am an atheist, but I
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• 1
2
M. Epstein
will affirm I'll tell the truth.
3 EXAMINATION BY
4 MR. EDWARDS:
5 Q. Can you tell us your name?
6 A. Mark Epstein.
7 THE VIDEOGRAPHER: Can you put the
8 microphone on your shirt, please?
9 THE WITNESS: Mark Epstein.
10 Q. Okay. And your date of birth,
11 please?
12 A.
13 Q• And what is your relationship with
• 14
15
the defendant in this case, Jeffrey Epstein?
A. He is my brother.
16 Q. Are you currently married?
17 A. No.
18 Q. What is your current address?
19 A. I'm not giving out my address. I'm
20 concerned about my personal safety because of
21 the nature of this case. You can use his
22 address. You can use my attorney's address.
23 Q. Please elaborate on that for me that
24 you are concerned for your safety because of
25 the nature of this case?
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Mark Epstein September 21, 2009
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1 M. Epstein
2 A. Because I've read -- well, I know
3 that Jeffrey hired a detective or someone from
4 the police when he went out on his days out.
5 So obviously there is probably a concern for
6 safety.
7 I don't want anything to do with this
8 case. I have nothing to do with this case. I
9 don't want my identifying information on any
10 kind of public record.
11 MR. COHEN: If it will make it
12 easier, Mr. Edwards, this is Mark Cohen
13 speaking. Mr. Mark Epstein is authorizing my
14
15
firm to accept service if there is a future
subpoena or a need to contact him again.
•
16 THE WITNESS: Before we go on, I want
17 to make a statement.
18 I want to say on the record that
19 initially I was improperly served with a
20 subpoena from Florida, it was supposed to come
21 from New York.
22 It also did not include the required
23 documents giving me my rights and obligations
24 under the Florida laws. So it's a breach of
25 some kind of ethics.
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Mark Epstein September 21, 2009
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M. Epstein
2 So in my book, you are either
incompetent, devious or have no ethical
compass.
So you are not on my high list.
6 Continue with your questions. I just wanted a
7 record of that.
8 MR. CRITTON: Brad, can you move the
9 phone a little closer to Mr. Epstein? I heard
10 you and I heard Mr. Cohen fine, but I'm having
11 trouble with Mr. Epstein.
12 MR. EDWARDS: All right.
13 MR. CRITTON: Thank you.
• 14
15
MR. EDWARDS: I apologize for your
feelings about the subpoena.
16 THE WITNESS: Not accepted.
17 This is too serious of a matter.
18 BY MR. EDWARDS:
19 Q. You do realize that you are
20 subpoenaed to testify today in cases that
21 involve your brother having sex or engaging in
22 sex acts with minors; correct?
23 MR. CRITTON: Form?
24 MR. COHEN: That's --
25 A. I know there is a case against my
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Mark Epstein September 21, 2009
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1 M. Epstein
2 brother. I know that.
3 Q. And you are aware that there are
4 multiple attorneys on the phone that represent
5 girls who were under-age when Mr. Epstein had
6 sex with them?
7 A. I know there are multiple attorneys
8 on the phone.
9 Q. Okay. Have you read the newspaper
10 articles about your brother that detail your
11 brother having sex with under-age girls?
12 MR. CRITTON: Form.
13 A. I've read some of the papers.
14
15
Q.
wrong?
You agree that sex with minors is •
16 MR. CRITTON: Form.
17 MR. COHEN: Objection.
18 Q. You can answer.
19 A. I have no opinion on that.
20 Q. Okay.
21 A. I'm not here to give opinions. I'm
22 here for facts. So ask me questions about
23 facts and I'll be glad to answer them.
24 Q. Well, do you agree with the laws that
25 protect under-age children from adult sexual
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• 1
2 predators?
M. Epstein
3 MR. COHEN: Objection.
4 MR. CRITTON: Form.
5 A. My information on the case is my
6 brother I know had to spend sometime in jail
7 for some prostitution charge.
8 So I assume the attorneys are
representing the prostitutes he was involved
10 with, so I don't know what the ages of them
11 are or were.
12 I'm not involved with the case. I
13 don't watch all the details about it. That's
• 14
15
all.
Q. Would it surprise you to learn that
16 there were more than 30 girls between the ages
17 of 12 and 15 that your brother engaged in sex
18 acts with?
19 MR. CRITTON: Form.
20 A. I don't get surprised by very many
21 things in this world.
22 Q. But you and your brother are a year
23 apart; right?
24 A. 18 months.
25 O. And you grew up together?
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Mark Epstein September 21, 2009
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1 M. Epstein •
2 A. Sure.
3 Q• You still talk to him?
4 A. Occasionally, rarely.
5 Q. So when I ask you, does it surprise
6 you, you are saying that it doesn't surprise
7 you that your older brother engaged in sex
8 with more than 30 girls between 12 and
9 15 years old?
10 MR. COHEN: Objection.
11 MR. CRITTON: Form.
12 A. I don't know how to answer that
13 question. I don't know if it's true, and I
14
15
don't know what the story is.
It's not -- ask me a question about
•
16 facts I'm not going to give you opinions
17 here, that's not what I'm here for.
18
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Mark Epstein September 21, 2009
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• 1
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M. Epstein
3
4
6
7 MR. EDWARDS: Counsel?
8 MR. COHEN: I would suggest you move
9 to an area that's likely to lead to you
10 gathering relevant evidence.
11 We can come back to this burning
12 question maybe later.
13 MR. CRITTON: Let me also add that I
• 14
15
can only object to form, but I also want to
put on the record, other than his name and he
16 is related to Mr. Epstein, there is not one
17 piece of evidence or --
18 THE COURT REPORTER: I can't hear
19 you.
20 MR. CRITTON: I'm sorry. I just want
21 to note for the record that other than his
22 name and his relationship to Mr. Epstein, to
23 Jeffrey Epstein, there has been nothing of
24 relevance or materiality that would lead to
25 admissible evidence at the time of trial.
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Mark Epstein September 21, 2009
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16
1 M. Epstein
2 This is being done to harass or
3 humiliate Mr. Mark Epstein and/or my client.
4 It certainly borders on that, but he is not an
5 expert, his opinions are irrelevant in this
6 case, and as is his own family situation
7 but --
8 MR. EDWARDS: Mr. Critton, as you
9 stated first, I think that your objection is
10 limited to the form. Thanks.
11 Can I mark this as an exhibit?
12 (Plaintiff's Exhibit 1 was so marked
13 for identification.)
14
15
MR. COHEN: I will say that I join in
Mr. Critton's objection for the record.
•
16 BY MR. EDWARDS:
17 Q. How frequently do you talk with your
18 brother now?
19 A. Maybe once every couple of weeks or
20 so, but "now° being just the last month or
21 two.
22 Q. Okay. When you first learned of a
23 criminal investigation into your brother, did
24 you talk to him about the substance of those
25 allegations?
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2 A. No.
3 Q. Have you ever asked him or had a
4 conversation with him about the allegations
5 that he's had sex with numerous under-age
6 kids?
7 A. No.
8 Q. Is there a reason why you wouldn't
9 ask him questions about him engaging in sex
10 with 13, 14-year old kids?
11 A. We are not very close. We don't talk
12 very often.
13 MR. CRITTON: Form.
• 14 Q. But when you do talk to him, that
15 conversation doesn't come up?
16 A. No.
17 Q. He went to jail. Did he ever tell
18 you why he went to jail?
19 A. No.
20 Q. Are you familiar with the property at
21
22 A. Yes, I am.
23 Q. Who owns that property?
24 A. Dara Partners.
25 Q. And what is Jeffrey Epstein's
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2
M. Epstein
affiliation with that property?
•
3 A. He rents some apartments in there.
4 Q. How many apartments does Jeffrey
5 Epstein rent at
6 A. It's either 8 or 10, I am not sure.
7 Q. Who are the residents of the
8 apartments that Jeffrey Epstein rents at that
9 location?
10 A. I have no idea.
11 MR. CRITTON: Brad, what was the
12 answer to the last one?
13 MR. COHEN: He has no idea.
14
15
A. I know his pilots used to stay there,
but I don't think he is using pilots any more.
•
16 Q. Why does he rent so many places at
17 the same location?
18 A. I have no idea.
19 Q. Have you ever had any affiliation
20 with that location?
21 A. Sure.
22 Q. In what way?
23 A. I'm one of the partners of Dara
24 Partners.
25 Q. So does your brother rent from you?
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Mark Epstein September 21, 2009
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• 1
2 A.
M. Epstein
No, he rents from Dara Partners. My
3 partner handles that property, I don't know
4 any of the tenants in that building other than
5 one or two.
6 Q. What are the names of the one or two
7 that you do know?
8 A. It is my ex, so I'm not going to give
9 you her name.
10 Q. Is that somebody who lives in one of
11 the places rented by your brother Jeffrey
12 Epstein?
13 A. No.
• 14
15
Q. Do you know any of the tenants that
live in the places rented by your brother,
16 Jeffrey Epstein?
17 A. No.
18 Q. Do you know
19 A. I know the name. I don't know her.
20 Q. Do you know what her relationship is
21 to your brother?
22 A. I think she worked for him.
23 Q. In what capacity?
24 A. I have no idea.
25 Q. Do you know if she lives in
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20
1 M. Epstein
2
3 A. I don't know where she lives.
4 Q. Would you know her if you saw her?
5 A. No.
6 Q. You've never seen her before?
7 A. I might have seen her somewhere, I
8 don't know.
9 Q. Have you ever talked to her?
10 A. I don't recall talking to her.
11 Q. Do you know
12 A. I know of her.
13 Q. How do you know of her?
14
15
A.
Q.
In the papers.
What papers?
•
16 A. Newspapers. I read some articles.
17 Q. Newspapers about your brother?
18 A. Relating to his case, yes.
19 Q. Okay. And what is your understanding
20 of her relationship with your brother?
21 A. I don't have an understanding about
22 it.
23 MR. CRITTON: Form.
24 A. My brother and I do not have a close
25 relationship, so what he does is his business
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