EFTA01695673.pdf

23 1 Q Because other law firms have asked very 2 similar questions and you haven't responded to 3 any of theirs either. I just want to understand 4 what the relationship between 5 is to you invoking your Fifth 6 Amendment rights today, if you can articulate 7 that for me. 8 MR. : Form, compound, 9 argumentative. 10 A has been 11 described by the O.S. Attorney as a criminal 12 enterprise and as part of the largest fraud in 13 Florida's history. It has been reported that 14 your firm fabricated multiple cases using me, and 15 against me in order to fleece unsuspecting 16 investors out of millions of dollars. 17 Q Another long time friend of yours is 18 Ghislaine Maxwell, right? 19 A I intend to respond to all relevant 20 questions. I would like to answer most of these 21 questions today, but I can't because my attorneys 22 have counseled me that I cannot provide answers 23 to any questions relevant to this lawsuit. I 24 must accept their advice or risk losing my Sixth 25 Amendment right to effective representation. EFTA01695673  24 1 Therefore I'll assert my Constitutional 2 rights under the Fifth, Sixth and Fourteenth 3 Amendment. 4 THE WITNESS: Excuse me, could we take a 5 break? 6 N.R. Already? 7 THE WITNESS: Restroom. 8 THE VIDEOGRAPHER: Going off the video 9 record 11:38 a.m. 10 THE WITNESS: Thank you. 11 (Pause in the proceedings.) 12 THE VIDEOGRAPHER: We're back on the 13 video record at 11:48 a.m. 14 Q How did you meet Ghislaine Maxwell? 15 A I intend to respond to all relevant 16 questions to this lawsuit; however, at the 17 present time my attorneys have counseled me that 18 I cannot provide answers to any questions 19 relevant to this lawsuit, and must accept this 20 advice or risk losing effective -- my right to 21 effective representation. Accordingly, 22 therefore, I assert my Fifth, Sixth and 23 Fourteenth Amendment rights to the U.S. 24 Constitution. 25 Q You would agree, would you not, that EFTA01695674  25 1 Ghislaine Maxwell shares your sexual obsession 2 for underage minor females? 3 MR. Argumentative, speculation, 4 harassing. 5 A You know, Mr. the current U.S. 6 Attorney has described your law firm as a 7 criminal enterprise, and as taking part in one of 8 the largest frauds in Florida's history. It has 9 been widely reported that your firm fabricated 10 multiple cases of a sexual nature against 11 people -- other people and me, in order to fleece 12 unsuspecting investors out of millions of 13 dollars, so unfortunately at this time in 14 response to your questions, my attorneys have 15 advised me I must assert my Sixth Amendment, 16 Fifth Amendment and Fourteenth Amendment rights, 17 though I believe, as you know, / would really 18 like to answer these questions, but at this 19 moment, although at this time I have to assert 20 those rights or risk losing effective counsel. 21 4 Do you know 22 A I intend to respond to all relevant 23 questions regarding this lawsuit; however, at the 24 present time my counsel has advised me that I 25 cannot provide answers to any questions relevant EFTA01695675  26 1 to this lawsuit. Your firm has been described as 2 a criminal enterprise, and is part of the largest 3 fraud in Florida's history fabricating sexual 4 cases against me and others. Therefore, 5 unfortunately, although I would like to answer 6 all of your questions today, I'm going to have to 7 assert my Fifth, Sixth and Fourteenth Amendment 8 right. 9 Q Did you and Ghislaine Maxwell sexually 10 assault at Leslie Wexler's house? 11 A I intend to respond to all relevant 12 questions regarding this lawsuit; however, at the 13 present time my attorneys have counseled me I 14 cannot provide answers to any questions relevant 15 to this lawsuit and must accept this right or 16 risk losing my Sixth Amendment rights to 17 effective presentation. Accordingly, I assert my 18 Constitutional rights as guaranteed by the Fifth, 19 Sixth and Fourteenth amendments to the U.S. 20 Constitution. 21 Q Stating Ghislaine Maxwell and you had 22 devised several schemes to lure underage girls to 23 you for sex; isn't that correct? 24 MR. Form, argumentative, 25 harassing? EFTA01695676  27 1 A Mr. your firm has fabricated 2 multiple cases of sexual harassment claims and 3 other types of sexual cases against me and others 4 in order to be part of what the U.S. Attorney has 5 described as the largest fraud, the largest fraud 6 in Florida's history. I would like to answer all 7 your questions; however, my attorneys have 8 counseled me that at least today, I must assert 9 my Fifth, Sixth and Fourteenth Amendment rights 10 under the U.S. Constitution. 11 Q Do you own a home in Manhattan? 12 A I intend to respond to all relevant 13 questions to this lawsuit; however, at the 14 present time my attorneys have counseled me that 15 I cannot provide answers to any questions 16 relevant to this lawsuit, and I must accept their 17 advice or risk losing my Sixth Amendment right to 18 effective representation. 19 Accordingly, therefore, I have to assert 20 my Fifth, Sixth and Fourteenth Amendment right 21 under the U.S. Constitution. 22 Q Do you own an island in the U.S. Virgin 23 Islands? 24 A I intend to respond to all relevant 25 questions regarding this lawsuit; however, at the EFTA01695677  28 1 present time my attorneys have counseled me that 2 I cannot provide answers to any'questions 3 relevant to this lawsuit, no matter how much I 4 would like to. 5 Therefore, I must accept their advice or 6 risk losing my Sixth Amendment right to effective 7 representation; therefore, I have to assert my 8 Fifth, Sixth and Fourteenth Amendment right under 9 the U.S. Constitution. 10 Q Do you own a home in New Mexico? 11 A I intend to respond to all relevant 12 questions regarding this lawsuit and as I've had 13 to do with most of your questions here today, I'm 14 going to have to take my attorneys' advice and 15 assert my Fifth, Sixth and Fourteenth Amendment 16 right under the U.S. Constitution or risk losing 17 effective representation. 18 Q Is it true that you have had underage 19 females, at each of those homes, for orgies with 20 you and Ghislaine Maxwell? 21 MR. : Form, argumentative, 22 speculation and harassing. 23 A I would like to answer that question. I 24 really would. However, as your firm has been 25 described by the U.S. Attorney as a criminal EFTA01695678  29 1 enterprise, which its principal purpose was 2 racketeering conspiracy to generate money for the 3 firm and its co-conspiritors through the 4 operation of enterprise and through various 5 activities including mail fraud, wire fraud and 6 money laundering, and fabricating multiple sex 7 cases against me and others, though I would like 8 to answer your question today, Mr. my 9 counsel has advised me I must take the Fifth, 10 Sixth and Fourteenth Amendment right provided by 11 the O.S. Constitution. 12 Q Do you know somebody named 13 (phonetic)? 14 MR. Can you spell that, for the 15 record? 16 MR. No. 17 MR. Or for the court reporter? 18 A No. 19 Q You don't know the name? 20 A No. Could you spell it? 21 Q (Witness shrugs.) 22 A Okay. 23 Q Did your sexual obsession with underage 24 minor females grow at some point in time to allow 25 you access to these underage minors every single EFTA01695679  30 1 day for sex? 2 MR. : Overbroad. Speculation, 3 argumentative, compound, harassing and 4 confusing as well; as worded. Do you want 5 to break it down, Mr. 6 Q Isn't it true that for the past ten 7 years you have found a way to engage in sexual 8 conduct with underage minors on an every day 9 basis? 10 MR. : Speculation. Argumentative. 11 A As your firm has been described as a 12 criminal enterprise by the United States Attorney 13 and is part of the scheme to defraud people in 14 South Florida of millions of dollars, you have 15 fabricated sexual cases and sexual claims against 16 people like me and others. Unfortunately at this 17 time although I would like to answer your 18 questions, Mr. my counsel has advised me 19 I cannot. They have advised me I must assert my 20 Fifth, Sixth and Fourteenth Amendment rights 21 under the U.S. Constitution. 22 Q Isn't it true that you have promised 23 underage minors money or other benefits to engage 24 in sexual conduct with you over the past ten 25 years? EFTA01695680  31 1 A Again, as I've answered many of your 2 questions today, and unfortunately will probably 3 end up not answering most of your questions 4 today, as your firm has been described, the firm 5 bringing this lawsuit, I believe, if I'm wrong 6 please, correct me -- 7 Q You're wrong. 8 A This is the firm that didn't notice this 9 deposition? 10 Q Did not? 11 A Did not? 12 Q No. 13 A I apologize. Though your former firm 14 has been described, and the person you represent, 15 IIII, in this case was represented by the firm 16 that was described by the U.S. Attorney as 17 perpetrating one of the largest frauds in South 18 Florida's history, fabricating multiple sexual 19 cases against me and others in order to fleece 20 unsuspecting investors out of millions and 21 millions of dollars, so though unfortunately, I 22 would like to answer each one of your questions 23 today, my counsel has advised me I must assert my 24 Sixth Amendment, Fourteenth Amendment and Fifth 25 Amendment right, though I believe you know, I EFTA01695681  32 1 would like to answer those questions, though at 2 this moment I must assert those rights or risk 3 losing my attorneys. 4 Q Sure, let's test that answer. 5 A Okay. 6 Q Let's talk about Jane Doe 102, Jane Doe 7 102, , who was represented by III 8 firm, had nothing to do with 9 Do you know 10 A Who? 11 12 A Can you spell it? 13 Q Common spelling, like the 14 State -- 15 A Can you spell it for me, please? 16 17 A What's the last name, how is it 18 spelled? 19 , I believe. 20 A I intend to respond to all relevant 21 questions regarding this lawsuit; however, at the 22 present time my attorneys have counseled me that 23 I cannot provide answers to any questions that 24 may be relevant to this lawsuit and I must accept 25 this advice or risk losing my Sixth Amendment EFTA01695682  33 1 right to effective representation. Accordingly, 2 I assert my Constitutional rights as guaranteed 3 by the Fifth, Sixth and Fourteenth Amendment to 4 the Constitution. 5 Q Just for the record, I can only spell it 6 the way it was spelled in your flight logs from 7 your airplane. I don't know exactly how she 8 spells her name, only how your pilot would spell 9 her name. 10 MR. Form, speculating. 11 Q If I misspell it 12 MR. Form, speculation, 13 argumentative, harassing. 14 MR. That's harassing? 15 MR. It assumes facts currently 16 not in evidence in this particular 17 deposition; therefore, I move to strike. 18 MR. I was responding to his 19 question asking me how to spell her name. I 20 don't know how other than his own pilot. 21 MR. Mr. he asked you to 22 spell the name, you then spelled the name, 23 then went on with another narrative and 24 there wasn't a question posed, on the floor. 25 Q You would agree you interacted with EFTA01695683  34 1 every day in a sexual way, when she was 15 years 2 old, right? 3 A Again, I'm sorry? 4 Q Sure. You would agree that you 5 interacted with IIII sexually on an every day 6 basis when she was 15 years old? 7 A You know, again, Mr. I would 8 like to answer all your questions here today. My 9 attorneys have asked me -- advised me that I must 10 assert my Sixth Amendment, Fourteenth Amendment 11 and Fifth Amendment rights provided by the U.S. 12 Constitution and the fact that the current U.S. 13 Attorney has described your law firm as a 14 criminal enterprise, is one of the largest frauds 15 in Florida's history for fabricating sexual -- 16 cases of a sexual nature against me and others. 17 Unfortunately, although I would like to answer 18 those questions, if I do I risk losing my 19 attorneys' counsel. Therefore, I must assert my 20 right. 21 MR. Madam court reporter, I'll 22 attach as an exhibit, the Jane Doe number 23 102 versus Jeffrey Epstein complaint, at 24 some point in time. It will be Exhibit 1, 25 as I'm going to go through some of the facts EFTA01695684  35 1 as alleged in the complaint and as will be 2 testified to by the plaintiff. 3 (Jane Doe number 102 versus Jeffrey 4 Epstein complaint was deemed marked as 5 Exhibit number 1 for identification, as of 6 this date.) 7 MR. Counsel, do you have an extra 8 copy of that for me? 9 MR. No. 10 MR. May I look at it real quick? 11 MR. No. It has my notes on 12 it. 13 MR. I understood, I saw the 14 highlights. 15 MR. The notes are highlighted 16 so when we copy it, it will not show up. 17 MR. Just for the record, that's a 18 current, operative pleading, correct? 19 MR. correct. 20 TEE WITNESS: What does that mean? 21 MR. : There may have been some 22 amendments to a complaint and I want to make 23 sure that's the operative complaint at issue 24 that he is speaking of today. 25 THE WITNESS: Can I go off the record EFTA01695685  36 1 for a second? 2 May I ask you a question? 3 MR. Sure. Can we take a break 4 for a second? MR. Again? 6 THE WITNESS: Just a question. 7 MR. He wants to speak with me for 8 a second. 9 THE VIDEOGRAPHER: Off the video record 10 12:01 p.m. 11 (Pause in the proceedings.) 12 THE VIDEOGRAPHER: We are back on the 13 video record at 12:02 p.m. 14 Q Is it true, Mr. Epstein, that you and 15 Ghislaine Maxwell forced I'll to have sex with 16 you on a daily basis? 17 MR. : Form, argumentative, 18 harassing. 19 A Unfortunately at this time, though I 20 would really like to answer those questions, and 21 like I have done for most of your questions here 22 today, Mr. your firm was described as a 23 criminal enterprise, a serious criminal 24 enterprise by the current U.S. Attorney. Part of 25 that criminal enterprise was fabricating cases of EFTA01695686  1 2 a sexual nature against me and others in order to fleece unsuspecting investors out of millions of 37 1 3 dollars. Though, unfortunately at this time no 4 matter how I would like to respond to your 5 questions, I must assert my Sixth Amendment, 6 Fifth Amendment and Fourteenth Amendment rights 7 under the U.S. Constitution or risk having my 8 attorneys resign. 9 Q Isn't it true that IIII was yours and 10 Ghislaine Maxwell's sex slave from the time she 11 was 15 through the time she escaped when she was 12 19? 13 MR. Again objection, 14 argumentative, harassing. 15 A Mr. your firm has been 16 described as -- excuse me, as a criminal 17 enterprise by the current U.S. Attorney and part 18 of the largest fraud in Florida's history. Part 19 'of that fraud was fabricating multiple cases 20 against people like me and others, of a sexual 21 nature, in order to fleece unsuspecting investors 22 out of millions and millions of dollars, so 23 though I would like to answer that question, my 24 attorneys have told me today I must assert my 25 Sixth Amendment, Fourteenth Amendment and Fifth EFTA01695687  38 1 Amendment right. 2 0 Isn't it true that you and Ghislaine 3 Maxwell celebrated her 16th birthday with her and 4 had sex with her on that day? 5 MR. : Form. Compound, confusing, 6 argumentative, harassing. 7 A Mr. I would like to answer that 8 question. My attorneys have told me today, I 9 have to at least today assert my Fifth Amendment, 10 Sixth Amendment and Fourteenth Amendment rights 11 to the U.S. Constitution, especially my concern 12 is, that your firm has filed fraudulent lawsuits, 13 fabricated lawsuits, and the U.S. Attorney, the 14 current U.S. Attorney has described your firm as 15 a criminal enterprise that -- whose main purpose 16 was to generate money for the firm and its 17 co-conspirators through the operation of various 18 criminal activities, including mail fraud, wire 19 fraud and money laundering. 20 Q Are you saying that the complaint of 21 IIII against you, the allegation in that 22 complaint, are false? 23 MR. MI Form. Misinterprets the 24 witness's testimony. 25 Q Or saying it is true? EFTA01695688  391 1 MR. Same objection. 2 Q It is either true or false? 3 A I'll repeat myself, unfortunately, but 4 the current U.S. Attorney has described your law 5 firm that filed that filed IIII's claim -- was 6 involved in the filing of 's claim, 7 motions -- I'm sorry, do you want to tell me what 8 it was then? Would you like to tell me the 9 firm's involvement in this lawsuit, since we will 10 be here the rest of the day? 11 Q Answer the question. 12 A All right. 13 The U.S. Attorney has described that 14 firm as a criminal enterprise perpetrating one of 15 the largest frauds in Florida's history against 16 unsuspecting investors, fleecing them out of 17 millions of dollars by creating, crafting and 18 fabricating fallacious (sic) sexual claims 19 against people like me and others, so 20 unfortunately, though I would like to answer your 21 questions, Mr. my counsel has advised me 22 that at least today I must assert my Sixth 23 Amendment, Fifth Amendment and Fourteenth 24 Amendment rights under the U.S. Constitution. 25 0 Isn't it true, sir, and I'm reading from EFTA01695689  40 1 the complaint filed by IIII against you, isn't it 2 true, sir, that a friend of yours sent you three, 3 12-year old females for you to sexually abuse on 4 one of your birthdays? 5 MR. Form, argumentative, 6 harassing, and irrelevant to this lawsuit. 7 THE WITNESS: Excuse me. 8 A You're saying it is part of the 9 lawsuit? 10 Q Yes, I'll read it. 11 "On one of the defendant Epstein's 12 birthdays, a friend of defendant Epstein sent him 13 three, 12-year old girls from France who spoke no 14 English for defendant to sexually exploit and 15 abuse? After doing so they were sent back to 16 France the next day." 17 Isn't that true? 18 MR. : Once again, move to strike, 19 irrelevant, argumentative, harassing, and 20 for the record, the exhibit that's being 21 read from is a complaint that's unrelated to 22 the instant matter and not filed or 23 incorporated by the current plaintiff, IIII, 24 in this matter. 25 A I would like to answer that question, I EFTA01695690  41 1 really would; however, today my attorneys have 2 told me I have to assert my Fifth Amendment, 3 Sixth Amendment and Fourteenth Amendment rights 4 of the U.S. Constitution, especially because your 5 firm involved in this lawsuit has fabricated, 6 widely reported, multiple cases of sexual 7 harassment cases against individuals like me and 8 others, perpetrating what the U.S. Attorney 9 called one of the largest frauds in Florida's 10 history, fleecing people out of millions of 11 dollars, so though I would like to answer that 12 question, today I have to assert those rights or 13 risk losing my attorneys' counsel. 14 Q Isn't it true that you forced IIII as a 15 15-year old girl to have sex with numerous 16 friends of yours? 17 A Axe you kidding? 18 Q Reading from a lawsuit. 19 A Sorry, Mr. Though I would like 20 to answer that question as well, as I've answered 21 most of your other questions here today, I would 22 like to respond; however, my attorneys here today 23 have advised me I have to assert my Fifth 24 Amendment, Sixth Amendment and Fourteenth 25 Amendment rights under the U.S. Constitution, EFTA01695691  42 1 especially as your firm has been accused by the 2 U.S. Attorney as being a criminal enterprise, and 3 part of the largest fraud in Florida's history. 4 Basically -- sorry, if I didn't read correctly, 5 um.... the operation of the enterprise through 6 various criminal activities including mail fraud, 7 wire fraud and money laundering, fabricating 8 sexual harassment cases against people like me 9 and others. 10 Q By the way -- 11 A Yes, sir? 12 Q -- didn't receive a round trip 13 ticket paid for by you to Thailand, and she 14 ultimately did not get back on the plane but 15 instead escaped to Australia? 16 A I would like to answer that question, 17 but today I would have to assert my Sixth 18 Amendment rights, my Fifth Amendment rights and 19 my Fourteenth Amendment rights under the U.S. 20 Constitution, especially since your firm has been 21 described as perpetrating one of the largest 22 frauds in Florida's history, fleecing investors 23 out of millions of dollars, being described by 24 the U.S. Attorney of South Florida, as a criminal 25 enterprise engaged in various criminal activities EFTA01695692  43 1 including mail fraud, wire fraud and money 2 laundering. 3 Q Do you know a man named Jean Luc 4 Brunel? 5 A Can you spell it? 6 Q He was at your house last week, does 7 that remind you? 8 MR. Form, move to strike, 9 speculation, argumentative, harassing. 10 Is there a question on the table, Mr. 11 12 MR. Yes. 13 Q Do you know him? 14 A Can you spell his name for me, please? 15 Q I don't need to spell his name. Do you 16 know who I'm talking about, Mr. Brunel? 17 A Sorry, Mr. what? 18 Q B-r-u-n-e-1. 19 A I would like to answer that question as 20 well, but my attorneys have counseled me today I 21 have to assert my Sixth Amendment rights, Fifth 22 Amendment rights and Fourteenth Amendment rights 23 under the U.S. Constitution or risk losing my 24 right to effective representation. 25 Q What's the purpose for you asking me to EFTA01695693  44 1 spell his name? Are you acting like you don't 2 know him? 3 MR. : Form, move to strike, 4 argumentative and irrelevant as worded. 5 Mr. you know that there are 6 various standing orders, if not in this 7 case, in various other cases, that 8 specifically describe the protections of the 9 Fifth Amendment. Federal Courts have 10 ordered that certain questions that you are 11 asking shall not be answered or Mr. Epstein 12 would risk losing his Fifth Amendment 13 right -- 14 MR. I understand that. He is 15 asking to spell people's names. 16 MR. : -- under the United States 17 Constitution. A lot of these questions here 18 today that you're asking have already been 19 ruled on by various Courts, that the Fifth 20 Amendment protects any response thereto, so 21 I would like -- I'm giving you some leeway 22 here with regard to the argumentative 23 questions. We've already -- and I'm not 24 obviously testifying for the witness, but 25 we've already handled a lot of these issues EFTA01695694  45 1 in court and we have already adjourned one 2 deposition for being argumentative, and I 3 think you understand what the Court said 4 there, so having said that, and I understand 5 that you have a job to do, but having said 6 that, I would like to caution you 7 professionally, if you continue with the a argumentative questions, I am going to have 9 to terminate this deposition -- 10 MR. I completely understand. 11 MR. Okay. We are here today 12 to -- 13 MR. Mr. Brunel -- 14 MR. : I want the Court to know we 15 are here today to allow you to ask your 16 questions, but the harassing and 17 argumentative tone is not going to be 18 tolerated. 19 MR. We have a video. We can 20 show the Court the tone. It is obviously 21 not harassing. 22 MR. : That's fine. 23 Q Mr. Brunel is a long-term friend of 24 yours, right? 25 A I intend to respond to all relevant EFTA01695695  46 1 questions of this lawsuit; however, today my 2 attorneys have counseled me I cannot provide 3 answers to any questions that may be relevant to 4 this lawsuit and I must accept their advice or 5 risk losing my Sixth Amendment right to effective 6 representation. 7 Q You know him as somebody who has been 8 caught engaging in sex with underage minors in 9 the past; is that correct? 10 MR. : Form. 11 A You will have to repeat the question, 12 I'm sorry. 13 Q You know Mr. Brunel as somebody who has 14 been caught engaging in sex with minors in the 15 past; is that correct? 16 MR. : Form. 17 A I intend to respond to all relevant 18 questions regarding this lawsuit; however, at the 19 present time my attorneys have counseled me that 20 I cannot provide answers to any questions 21 relevant to this lawsuit, and I must accept their 22 advice or risk losing my Sixth Amendment right to 23 effective representation as your firm has been 24 described by the U.S. Attorney as a criminal 25 enterprise and part of one of the largest frauds EFTA01695696  47 1 in Florida's history specifically said you have 2 been fabricating -- the law firm has been 3 fabricating multiple cases of a sexual nature in 4 order to fleece unsuspecting investors out of 5 millions of dollars, including mail fraud, wire 6 fraud and money laundering, so unfortunately, 7 though I would like to answer all your questions 8 here today, I must assert my Sixth Amendment, 9 Fourteenth Amendment and Fifth Amendment right. 10 Q You were involved in a modeling business 11 with him called M.C. Squared; is that correct? 12 A Again? 13 Q You were involved in a modeling agency 14 with -- 15 A What do you mean -- 16 Q -- with Mr. Brunel called M.C. Squared? 17 A "Involved" means what, what do you 18 mean? 19 Q You tell the jury your involvement with 20 the modeling agency. You can clarify for me, 21 I'll let you do that. 22 MR. Object to the form. 23 A I intend to respond to all relevant 24 questions regarding this lawsuit. However, at 25 the present time my attorneys have counseled me EFTA01695697  48 1 that I cannot provide answers to any questions 2 relevant to this lawsuit and I must accept their 3 advice or risk losing my Fifth, Sixth and 4 Fourteenth Amendment rights under the O.S. 5 Constitution. 6 Q When you were being criminally 7 investigated and was in Australia, is it 8 true that you made a personal telephone call to 9 her telling her not to come forward with any of 10 the information she knew? 11 MR. : Form. 12 A Again? 13 Q Putting a time frame on it, the time 14 frame where you were being criminally 15 investigated -- 16 A What time frame is that? 17 Q In her complaint it is not specific, 18 but, let's just make it whenever. At some point 19 in time did you place a telephone call to in 20 Australia warning her not to come forward with 21 any information about you engaging in sex with 22 her while she was a minor? 23 MR. : Form. 24 A I intend to respond to all relevant 25 questions regarding this lawsuit; however, at the EFTA01695698  49 - 1 1 present time my attorneys have counseled me that 2 I cannot provide answers to any questions 3 relevant to this lawsuit and I must accept their 4 advice or risk losing my Sixth Amendment right to 5 effective representation. 6 Q With respect to underage females, isn't 7 it true that you have made the statement, in 8 quotes, "the younger the better"? 9 MR. : Form. 10 A Again, as your firm has been deScribed 11 by the current O.S. Attorney as a criminal 12 enterprise involved in mail fraud, wire fraud, 13 money laundering, and specifically crafting, 14 fabricating multiple cases of sexual -- of a 15 sexual nature against people like me, and others, 16 in order to fleece many, many unsuspecting 17 investors out of millions of dollars; I would 18 like to answer your questions here today, Mr. 19 but unfortunately, my attorneys have 20 counseled me that I must assert my Fifth, Sixth 21 and Fourteenth Amendment right or they will 22 resign. 23 Q Who are your current employees? 24 MR. : Form. 25 A Say that again. EFTA01695699  50 1 0 Who are your current employees, people 2 who work for you, that.you pay? 3 A I intend to respond to all relevant 4 questions regarding this lawsuit; however, at the 5 present time my attorneys have counseled me that 6 I cannot provide answers to any questions that 7 may be relevant to this lawsuit, or risk losing 8 my Sixth Amendment right to effective 9 representation. Accordingly, therefore, I must 10 assert my Sixth Amendment, Sixth Amendment and 11 Fourteenth Amendment rights as provided by the 12 U.S. Constitution. 13 Q Isn't it true you pay your employees to 14 bring you underage minor females for sex? 15 MR. : Form, argumentative, 16 speculation, harassing. 17 A Mr. your firm has been 18 described the current U.S. Attorney as a criminal 19 enterprise, a criminal enterprise, part of the 20 largest fraud in South Florida's history; but 21 part of that fraud was fabricating, um, 22 fictitious cases against me -- excuse me, against 23 people like me, of a sexual nature, in order to 24 fleece unsuspecting investors out of millions of 25 dollars. EFTA01695700  51 1 Unfortunately at this time, though, I 2 would like to answer every one of your 3 questions. My attorney has advised me I must 4 assert my Sixth Amendment, Fourteenth Amendment 5 and Fifth Amendment rights or risk losing them as 6 my attorneys. 7 Q Isn't it true when underage females were 8 brought to you, you would engage in sex with them 9 and pay them? 10 MR. : Form, argumentative, 11 harassing. 12 A (Witness shakes head.) 13 Q Are you shaking your head to say "no" -- 14 A Excuse me. 15 Q Are you shaking your head to say "no, I 16 don't know how to interpret that answer?" 17 A I didn't realize I was shaking my head. 18 MR. I thought he was actually 19 answering a question. 20 MR. : We'll just strike. The rules 21 are well-known to every lawyer who practices 22 in the State of Florida, that it is clear 23 that a nod of the head or shake of the head 24 is not understood by the record, so 25 therefore Mr. Epstein was clearly not EFTA01695701  52 1 responding to one of your questions and you 2 know that, Mr. 3 MR. This is on the video. 4 MR. : Nonetheless you know the 5 rules. Nonetheless. If we have a question 6 on the table, would you please repeat it so 7 I can recall it and Mr. Epstein can endeavor 8 to answer it. 9 MR. Sure, and if it was only 10 the court reporter, I would agree, but the 11 jury is going to see a video and everybody 12 knows commonly, if somebody shakes their 13 head, they are saying "no," and if that was 14 the answer, I wanted to give him a chance to 15 elaborate on it, that's it. 16 Q Isn't it true that when underage females 17 would come to your house, you would engage in 18 sexual activity with them and then pay them? 19 MR. : Same objections. 20 A Unfortunately I would like to answer 21 that question today, but my attorneys have 22 counseled me that I must assert my Sixth 23 Amendment right, my Fifth Amendment right and my 24 Fourteenth Amendment right under the U.S. 25 Constitution. EFTA01695702  53 1 The fact that your firm has been 2 described as a criminal enterprise and part of 3 one of the largest frauds in Florida's -- South 4 Florida's history, part of that fraud has been 5 described as fabricating cases of sexual nature 6 against me and others in order to fleece 7 unsuspecting investors out of millions of 8 dollars. I would like to answer that question, 9 Mr. however, today, I must assert my 10 Fifth, Sixth and Fourteenth Amendment right. 11 Q In addition to paying these underage 12 females for sexual activity, you also paid them 13 to bring their underage friends to you, to also 14 engage in sexual activity with them? 15 MR. : Form. 16 Q Is that correct? 17 A I intend to respond to all relevant 18 questions regarding this lawsuit; however, at the 19 present time my attorneys have counseled me that 20 I may not, and I must assert -- they have advised 21 me I must assert my Sixth Amendment right, my 22 Fifth Amendment right and my Fourteenth Amendment 23 rights under the U.S. Constitution. 24 Q You would pay underage females 200 to 25 8300 for engaging in sexual activity with you or EFTA01695703  54 1 for procuring another underage female to engage 2 in sexual activity with you; is that correct? 3 MR. : Form, move to strike. 4 Assumes facts not in evidence and calls for 5 a legal conclusion as well, argumentative. 6 A I intend to respond to all relevant 7 questions regarding this lawsuit; however, at the 8 present time my attorneys have counseled me that 9 I cannot provide answers to any questions that 10 may be relevant to this lawsuit, and I must 11 accept their advice or risk losing my Sixth 12 Amendment right to effective representation. 13 Accordingly, therefore, I must assert my 14 constitutional rights as guaranteed by the Fifth, 15 Sixth and Fourteenth Amendment to the O.S. 16 Constitution. 17 Q Would you agree that your scheme was 18 devised to coerce these underage minors to bring 19 you as many other underage minors, as were 20 available for you to engage in sexual activity 21 with? 22 MR. : Form. 23 A Can you repeat the question? 24 Q Yes. Would you agree that your scheme 25 was devised to coerce underage girls into EFTA01695704  55 1 bringing as many other underage girls to you, as 2 were available for sexual purposes? 3 MR. Form. 4 A Did you say "for sexual purposes"? 5 Q Yes, for sexual purposes. 6 A I'm not surprised. Since your firm was 7 described as perpetrating one of the largest 8 frauds in Florida's history by crafting, 9 fabricated sexual harassment cases against people 10 like me and others in order to fleece 11 unsuspecting investors out of millions of 12 dollars, I would like to answer that question. 13 However, today my attorneys have advised me I 14 must assert my Sixth Amendment, Fifth Amendment 15 and Fourteenth Amendment right under the U.S. 16 Constitution, and if I don't do so, I risk 17 losing -- uh... losing effective representation. 18 Q Utilizing this method of using underage 19 minors to bring you other underage minors, you 20 were able to engage in sex with hundreds of 21 underage minor females. Is that true? 22 MR. : Form, argumentative, 23 harassing and calls for speculation. 24 A Since, Mr. your firm has been 25 described as a criminal enterprise by the U.S. EFTA01695705  56 1 Attorney, and as part of the largest fraud in 2 South Florida's history, and as part of the fraud 3 fabricating malicious cases of sexual harassment 4 and other cases of sexual nature against people 5 like me and others, although I would like to 6 answer that question today, my attorneys have 7 advised me I must assert my Sixth Amendment, 8 Fourteenth Amendment and Fifth Amendment rights 9 of the U.S. Constitution. Although I believe you 10 know I would really like to answer your 11 questions, but at this moment if I don't assert 12 those rights, I risk having my attorneys resign. 13 Q Isn't it true with this method you were 14 able to interact sexually with underage girls 15 every single day? 16 MR. MI: Form, asked and answered. 17 Same objections. 18 Q Go ahead. 19 A Oh, I'm sorry. Can you repeat it? 20 Q Sure. With this method of -- 21 A "This method" being what, sorry? 22 Q Your method of using underage minors to 23 bring you other underage minors for sex; isn't it 24 true that that method resulted in you engaging in 25 sexual activity with underage minors on an every EFTA01695706  57 1 day basis? 2 MR. Same objections. 3 A Your firm has been described by the 4 current O.S. Attorney as a criminal enterprise 5 engaged in one of the largest frauds in South 6 Florida's history, and as part of that fraud, 7 creating, fabricating, malicious cases of sexual 8 nature against people like me and others, so 9 unfortunately, though I would like to answer that 10 question today, I must assert my Sixth Amendment, 11 Fourteenth Amendment and Fifth Amendment rights 12 to my counsel's advisement to do, although I 13 believe you know I would really like to answer 14 those questions today, I must assert those rights 15 or risk losing my attorney's representation. 16 Q To keep track of all these underage 17 minors, you stored their names and telephone 18 numbers in your home computer; isn't that 19 correct? 20 MR. Form, argumentative, 21 speculation. 22 A Again? Sorry. 23 Q Are you going to answer the question or 24 just read? If you are going to answer the 25 question, of course, I'll keep reading it as many EFTA01695707  58 1 times. 2 A Excuse me? 3 MR. : The witness is attempting to 4 answer your question. He asked you to 5 repeat the question. 6 MR. He is? 7 MR. He asked you to repeat the 8 question. 9 MR. I don't mind going through 10 that, Mike, because I do want answers, but 11 if I'm going to repeat the question multiple 12 times and get the same answer, we are 13 wasting time. I want to stop us wasting 14 time repeating questions if I'm getting the 15 same nonresponsive answer. 16 MR. : I understand your intention 17 here. 18 MR. Yeah. 19 MR. : -- however, these questions 20 are similar in nature, if not identical to 21 various questions that you've asked in other 22 indications, so you coming here today is of 23 no surprise that Mr. Epstein is required to 24 invoke his Fifth, Sixth and Fourteenth 25 Amendment rights under the United States EFTA01695708  59 1 Constitution -- 2 MR. I understand that. 3 MR. -- if you came here today 4 thinking you were going to pull a rabbit out 5 of a habit, and Mr. Epstein was going to 6 waive his Fifth, Sixth and Fourteenth 7 Amendment rights to the U.S. Constitution, 8 at least not today. That will not be 9 occurring. 10 Q Isn't it true that to keep track of the 11 names and phone numbers of these underage minor 12 females, to interact with sexually, you stored 13 those names and phone numbers in your home 14 computer? 15 A Thank you. I've heard the question 16 now. It didn't surprise -- again, I've now heard 17 the question and the fact that your firm has been 18 described as a criminal enterprise by the current 19 U.S. Attorney in South Florida, and part of one 20 of the largest frauds in Florida's history, it is 21 reported that your firm fabricated malicious 22 cases of a sexual nature against people and 23 against me, in order to fleece unsuspecting 24 investors out of millions of dollars. 25 Unfortunately, though I would like to EFTA01695709 r 3 1 2 answer each one of your questions today, Mr. my attorneys have advised me that I must assert my Sixth Amendment, Fifth Amendment and 60 4 Fourteenth Amendment rights under the U.S. 5 Constitution. So although I would like to 6 answer, I must assert those rights or risk having 7 my attorneys resign. 8 Q Do you know 9 A I intend to respond to all relevant 10 questions regarding this lawsuit; however, at the 11 present time my attorneys have counseled me that 12 I cannot provide answers to any questions 13 relevant to this lawsuit and must accept their 14 advice or risk losing my Sixth Amendment right to 15 effective representation. 16