EFTA01246464.pdf
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UNITED STATES DISTRICT COURT 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
SOUTHERN DISTRICT OF FLORIDA 2 IN AND FOR PALM BEACH COUNTY. FLORIDA
CASE NO. 502008CA028051XXXXMB AB
CASE NO. 08-CIV-80119-MARRA/JOHNSON 3
4 .
JANE DOE NO. 2.
5 Plaintiff.
Plaintiff.
6 -vs- VOLUME I OF III
-vs- VOLUME I OF III
JEFFREY EPSTEIN. 7 JEFFREY EPSTEIN.
Defendant 8 Defendant.
I I
9
Related eases: 10
08-80232. 08-08380. 08-80381. 08-80994 11
08-80993. 08-8081 1. 08-80893. 0940469 12 VIDE TAPED DEPOSITION OF
09.80591. 09-80656. 09-80802. 09-81092 13
r 14
VIIMMI 15 Wednesday. March 24.2010
SMON OF
10:37 - 6:51 p.m.
16
Wednesday. March 24. 2010 17
10:37 - 6:51 p.m. 18 250 Australian Avenue South
Suite 1500
250 Australian Avenue South 19 West Palm Beach. Florida 33401
Suite 1500 20
West Palm Beach. Florida 33401 21
22 Reported By:
Cynthia Hopkins. RPR. FPR
Reported By:
Cynthia Hopkins. RPR. FPR 23 Notary Public. State of Florida
Notary Public. State of Florida Prose Court Reporting Services
Prose Court Reporting Services 24 Job No.: 1484
Job No.: 1484 25
Page 2 Page 4
1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 1 DI THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
IN AND FOR PALM BEACH COUNTY. FLORIDA CIRCUIT IN AND FOR PALM BEACH COUNTY. FLORIDA
2 CASE NO. 502008CA028058XXXXMB AD 2 CASE No302008CA037319XXXXMB AB
3 3
M.
4
5 Plaintiff. Plaintiff.
6 -vs- VOLUME I OF III 5
7 VOLUME I OF III
JEFFREY EPSTEIN. J
8 AN
EFISISI,
Defendant. 8
9 / Defendants.
10 9
11 10
VI SITION OF
11 VItSITION OF
12
12
13
13
14 Wednesday. March 24. 2010
14 Wednesday. March 24. 2010
10:37 - 6:51 p.m.
10:37 - 6:51 p.m.
15
15
16
16
17 250 Australian Avenue South
17 250 Australian Avenue South
Suite 1500
Suite 1500
18 West Palm Beach. Florida 33401 16 West Palm Beach. Florida 33401
19 19
20 20
21 21
22 Repotted By: 22 Repotted By:
Cynthia Hopkins. RPR. FPR Cynthia Hopkins. RPR. FPR
23 Notary Public. State of Florida 23 Notary Public. State of Florida
Prose Court Reporting Services Prose Court Reporting Services
24 Job No.: 1484 24 Job No.: 1484
25 25
1 (Pages 1 to 4)
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APPEARANCES: 1
2 On behalf of the Plaintiffs. : 2 INDEX
SPENCER T. KUVIN. ESQUIRE 3
LEOPOLD KUVIN 4
2925 PGA Boulevard 5 EXAMINATION DIRECT CROSS REDIRECT'
Suite 201)
6
5 Palm Beach Garden. Florida 33410
Phone:
6 7
7 On behalf of the Plandiffs...... and BY MR. KUVIN 9
Jane Doe: a
8 9
9 MATTHEW WEISSING. ESQUIRE 10 EXHIBITS
FARMERJAFTE MUSSING. EDWARDS 11 _ _ _
10 FISTOS & LBIRNIAN.P.L 12
425 North Andimvx Avenue 13 EXHIBIT DESCRIPTION PAGE
11 Suite 2 14
Fort Lauderdale Florida 33301
PLAINTIFFS EX. 1 PHOTO 16
12 Phone:
13 On behalf of Jane Does I throu5h K: 15 PLAINTIFFS EL 2 MOE INC.. 24
14 ADAM D. HOROWITZ- ESQUIRE PASSENGER MANIFEST'
MERNIEI-STEIN it HOROWITZ. P.A. 16 PLAINTIFFS EX. 3 HYPERION AIR. INC..
15 18205 Biscayne Boulevard PASSENGER MANIFEST
Suite 22114 17 PLAINTIFFS EX. 6 PHOTO 63
16 Miami. a t i PLAINTIFFS EL 7 PHOTO 65
Phone: 18 PLAINTIFFS EX. 8 PHOTO 68
17 E-mail: PLAINTIFFS EX. 9 PHOTO 71
16 On behalf of the PI:midis. 101. 102 and 103: 19 PLAINTIFFS EL 10 PHOTO 100
19 KATHERINE W. EZELI- ESQUIRE PLAINTIFFS EL 11 PHOTO 101
AMY JOSEFSBERG EDERI. ESQUIRE 20 PLAINTIFFS EL 12 PHOTO 103
20 PODHURST ORSECK
PLAINTIFFS EX. 4 PHONE MESSAGE PADS
25 wear Flatlet Street
21 Suite WO
21 PLAINTIFFS EL 5 CELLPHONE RECORDS
Miami.iiiiiiiiii PLAINTIFFS EL 13 PHOTO 144
22 Phone: 22
23 1Via telephoner 23
24 24
25 25
Page 6 Page 8
1 Appearances continued... 1 PROCEEDINGS
2 On behalf of the Plaintiff. Jane Doe ll:
2
3 ISIDRO MANUEL GARCIA. ESQUIRE — — —
GARCIA. ELKINS & BOEHRINGER 3 THE VIDEOGRAPHER: We are now on video
4 224 Datum Avenue. Suite 900 4 record. This is Media No. 1 in the videotaped
West Palm Beach Fl ida 33401
5 Phone: 5 deposition of in the matter of
6 6 Jane Doe versus Jeffrey Epstein, et al. Today
7 On behalf of the Defendant:
7 is Wednesday. March 24th. 2010. It is
8 JACK ALAN GOLDBERGER. ESQUIRE
ATTERBURY. GOLDBERGER & WEISS. P.A. 8 10:36 a.m. We are here at Prose Court
9 250 Australian Avenue South 9 Reporting. 250 South Australian Avenue. West
Suite 1400
10 West ida 33401-5012 10 Palm Beach. Florida.
Phony 11 My name is Joe Kozak. I'm the
11
12 videographer. The reporter is Cindy
12
13 On f h Win • 13 Hopkins from Prose Court Reporting Agency.
14 19 Would counsel please introduce
15 yourselves, and then the court reporter
16 will swear in the witness.
17 MR. KUVIN: Good morning. Spencer Kuvin
17 18 on behalf of one of the Plaintiffs.
18
19 MR. HOROWITZ: Adam Horowitz on behalf of
19
20 ALSO PRESENT: 20 Jane Does 2 through 8. And just for the record
21 Jessica Cadwell. Paralegal 21 purposes. the deposition is also being taken in
Burman. Critton. Lanier & Coleman. P.A.
22 the federal cases, I believe, case being
22 Joseph Kozak. Videographer
Prose Court Reporting Services 23 Jane Doe 2 versus Jeffrey Epstein.
23 24 MR. WEISSING: Matt Weissing on behalf of
24
25 25 three of the Plaintiffs.
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1 MR. GARCIA: Sid Garcia for Jane Doe. 1 privilege.
2 Roman Numeral II. 2 MR. KUVIN: I'll agree with that
3 MR. GOLDBERGER: Jack Goldberger on behalf 3 procedure.
4 of Jeffrey Epstein. 4 MR. Anyone object to that
5 MS. CADWELL: Jessica Cadwell. paralegal. 5 procedure?
6 on behalf of Jeffre stein. 6 MR. GOLDBERGER: Actually I think if, in
7 MR. on behalf 7 fact, this deposition is used in a trial, 1
a of the witness. 8 think you would want the lengthier answer as
9 MR. KUVIN: Kathy. your turn. 9 being the answer that is played to the jury.
10 MS. EZELL: Okay. Kathy Ezell and Amy 10 So either you guys can agree that it gets cut
11 Ederi on behalf of Plaintiff, Jane Doe 103. 11 in or she's going to have to -- I can't tell
12 Thereupon. 12 you what to do, but I would suggest that she
13 l l 13 give the lengthier answer each time.
14 Having been first duly sworn or affirmed, was 14 But there's got to be a way that you
15 examined and testified as follows: 15 guys can reach an agreement though, that
16 DIRECT EXAMINATION 16 from a technology perspective, that the
17 BY MR. KUVIN: 17 lengthy answer that she just gave would be
18 Q. Good morning. 18 used during any trial testimony. Can that
19 A. Morning. 19 be done?
20 Q. Couldyougive us your full name, please. 20 MR. KUVIN: I don't know procedurally
21 A. . 21 whether it can be done.
22 Q. il aiave a middle name? 22 MR. GOLDBERGER: I think --
23 A. 23 MR. KUVIN: I don't know that, well --
24 Q. Would ou s II that for us? 24 MR. GOLDBERGER: And again, it's not my,
25 A. 25 ifs not my deal. I'm just telling you how
Page 10 Page 12
1 Q. What's our current address? 1 we've done it in the past.
2 MR. I'm going to instruct the 2 MR. KUVIN: I hear you. and I have a
3 witness not to answer that question on the 3 number of issues primary, primarily of which
4 basis of her Fifth and 14th Amendment 4 that you're not here to represent anyone
S privileges against self-incrimination. 5 currently.
6 MR. KUVIN: Okay. We had spoken before 6 MR. GOLDBERGER: Yeah. I am. I'm
7 with respect to there are likely going to be 7 actually. I'm actually here representing
8 answers similar to that throughout this 8 Jeffrey Epstein. so...
9 deposition. I have agreed to a procedure that 9 MR. KUVIN: Okay. With respect to all the
10 we can do a shortened answer. However you want 10 civil cases. though. you're not here to
11 to handle that. I leave it up to you. But I do 11 represent anyone, so --
12 agree that whatever the shortened answer is, 12 MR. GOLDBERGER: Yes. I am.
13 that it will satisfy the length. lengthy answer 13 MR. KUVIN: With the exception --
14 that she would like to give. 14 MR. GOLDBERGER: I represent -- I am --1
15 So, do we want to do that with this 15 don't mean to interrupt you. but I am counsel
16 question, or how do you want to handle 16 of record in the civil cases.
17 that procedurall ? 17 MR. KUVIN: Oka . Okay.
18 MR. Well. I think I have given 18 MR. If we have a stipulation,
19 the instruction. I think she, will give her 19 what's the problem? Are you --
20 the same instruction in the future to the 20 MR. KUVIN: There is none.
21 extent that it's relevant, and I think that if 21 MR. -- worried about a waiver?
22 we can all just agree that if she simply says 22 MR. GOLDBERGER: No. I'm not worried abou
23 or I simply say "The Fifth Amendment," that 23 that at all. I'm worried about what is played
24 will qualify as giving a sufficient answer to 24 to a jury if this gets tried.
25 -- a, a matter of law. and will invoke that 25 MR. KUVIN: Okay. And I appreciate you
3 (Pages 9 to 12)
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1 coachingM. but I think he can handle 1 I choose to invoke my Fifth Amendment right.
2 himself pretty adequately now -- 2 BY MR. KUVIN:
3 MR. GOLDBERGER: I have -- 3 Q. Would ou agree with me that you're
4 MR. KUVIN: So I leave it up to -- 4 approximatel
5 MR. GOLDBERGER: I have all the confidence 5 MR. : Same instruction.
6 in . 6 THE WITNESS: On the advice of my lawyer,
7 MR. KUVIN: Mr. with respect to 7 I must invoke my Fifth Amendment right.
8 how you want to handle it. I think we have an 8 BY MR. KUVIN:
9 agreement. 9 Would you agree with me that your eyes are
10 MR. : I'm satisfied that we have 10
11 a stipulation, and I assume if there is ever a 11 MR. Same instruction.
12 trial, that would be played or produced to the 12 THE WITNESS: On the advice of my lawyer,
13 jury that simply by using shorthand, what she's 13 I choose to invoke my Fifth Amendment right.
14 really saying is the lengthier answer now. I'm 14 BY MR. KUVIN:
15 satisfied with that. 15 Q. Would you agree with me that you were born
16 MR. KUVIN: And I agree with that. 16 in
17 BY MR. KUVIN: 17 MR. : Same instruction.
18 Q. Okay. Ma'am, what is your current 18 THE WITNESS: On the advice of my lawyer,
19 address? 19 I choose to invoke my Fifth Amendment right.
20 MR. : Again, I will instruct the 20 BY MR. KUVIN:
21 witness not to answer the question. 21 Q. What are the names of your parents?
22 THE WITNESS: On the instruction of my 22 MR. : Same instruction.
23 lawyer. I choose to invoke my Fifth Amendment 23 THE WITNESS: On the advice of my lawyer,
24 right. 24 I must invoke my Fifth Amendment right.
25 25
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1 BY MR. KUVIN: 1 BY MR. KUVIN:
2 Q. What is our current phone number? 2 Q. Areyou married or single?
3 MR. : Same instruction. 3 MR. : Same instruction.
4 THE WITNESS: On the advice of my lawyer, 4 THE WITNESS: On the advice of my lawyer,
5 I choose to invoke my Fifth Amendment right. 5 I must to invoke my Fifth Amendment right.
6 BY MR. KUVIN: 6 (Plaintiffs Exhibit No. I was marked for
7 Q. What is our cell hone number? 7 identification.)
8 MR. : Same instruction -- 8 MR. KUVIN: I'm going to show you what
9 THE WITNESS: On the advice of my lawyer, 9 we'll mark as Plaintiffs Exhibit I.
10 I choose to invoke m Fifth Amendment right. 10 And I'll ask the videographer to zoom
11 MR. : You have to let me speak 11 in here fora second.
12 before you answer in case there's an objection 12 BY MR. KUVIN:
13 or any of the other lawyers have an objection. 13 Q. Okay. Ma'am, I am going to show you a
14 BY MR. KUVIN: 14 photograph we've marked as Plaintiffs Exhibit 1 and
15 Q. I am going to show you a photograph. Oh, 15 ask you if you recognize this registered sex
16 what is your date of birth? 16 offender.
17 MR. : Same instruction. 17 MR. : First, object to the form
18 THE WITNESS: On the advice of my lawyer, 18 of the question. It assumes facts not before
19 I choose to invoke my Fifth Amendment right. 19 the witness, and I'll give the witness the same
20 MR. KUVIN: Let's make is easier. 20 instruction as to that question.
21 BY MR. KUVIN: 21 THE WITNESS: At the advice of my lawyer,
22 Q. would ou agree with me that 22 I must invoke my Fifth Amendment right.
23 your date of birth i 23 BY MR. KUVIN:
24 MR. : Same instruction. 24 Q. Would you agree with me that this
25 THE WITNESS: On the advice of my lawyer, 25 registered sex offender's name is Jeffrey Epstein?
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1 MR. Same instruction, same 1 question. It's ambiguous and compound. and I
2 objection. 2 will instruct the witness not to answer based
3 THE WITNESS: At the advice of my lawyer, 3 on her Fifth Amendment privilege.
4 I must invoke my Fifth Amendment right. 4 THE WITNESS: On the advice of my lawyer,
S BY MR. KUVIN: 5 I must invoke my Fifth Amendment right.
6 Q. Would you agree with me that Jeffrey 6 BY MR. KUVIN:
/ Epstein is a sexual offender? 7 Q. And wh did ou do that?
8 MR. Object to the form of the 8 MR. : Object to the form. It's
9 question and instruct the witness not to answer 9 ambiguous, in fact that what?
10 on her Fifth Amendment privilege. 10 BY MR. KUVIN:
11 THE WITNESS: On the advice of my lawyer I 11 Q. Why did you bring minor girls to
12 must invoke my Fifth Amendment right. 12 Jeffrey Epstein for him to have sex with?
13 BY MR. KUVIN: 13 MR. : Same objection as to forty
14 Q. Would you agree with me that 14 and instruct the witness not to answer.
15 Jeffrey Epstein sexual) abused you? 15 THE WITNESS: On the advice of my lawyer,
16 MR. Objection to the form, 16 I must invoke my Fifth Amendment right.
17 both as to the form of the question as to 17 BY MR. KUVIN:
18 harassing and instruct the witness not to 18 Q. What do ou currently do for a job?
19 answer, based on the Fifth Amendment privilege. 19 MR. : Instruct the witness not
20 THE WITNESS: On the advice of my lawyer. 20 to answer the question.
21 I must invoke my Fifth Amendment right. 21 THE WITNESS: On the advice of my lawyer,
22 BY MR. KUVIN: 22 I must invoke my Fifth Amendment right.
23 Q. Would you agree with me that you were a 23 BY MR. KUVIN:
24 minor when Jeffrey Epstein first had sexual 24 I.
25 relations with you?
Page 18 Page 20
1 MR. Object to the form. It 1 MR. Instruct the witness not
2 assumes facts not before the witness. It is a 2 to answer the question.
3 compound question and I would instruct the 3 THE WITNESS: On the advice of my lawyer,
4 witness not to answer based on her Fifth 4 I must invoke my Fifth Amendment right.
S Amendment privilege. 5 BY MR. KUVIN:
6 THE WITNESS: On the advice of my lawyer. 6 ii
7 I must invoke my Fifth Amendment right. I
8 BY MR. KUVIN: 8 MR. Same instruction.
9 Q. Would you agree with me that you have had 9 THE WITNESS: On the advice of my lawyer,
10 sex with Jeffrey E tein? 10 I must invoke my Fifth Amendment right.
11 MR. Same instruction. 11 BY MR. KUVIN:
12 THE WITNESS: On the advice of my lawyer. 12 I.
13 I must invoke my Fifth Amendment right.
14 BY MR. KUVIN: 9
15 Q. Would you agree with me that you first had 15 MR. Instruct the witness not
16 sex with Jeffrey Epstein when you were under the age 16 to answer the question.
17 of 18? 17 THE WITNESS: On the instruction of my
18 MR. Same instruction. 18 lawyer, I must invoke my Fifth Amendment right.
19 THE WITNESS: On the advice of my lawyer. 19 BY MR. KUVIN:
20 I must invoke my Fifth Amendment right. 20 •
21 BY MR. KUVIN:
22 Q. Would you agree with me. ma'am, that you
23 brought numerous underage girls to Jeffrey Epstein 23 MR. Object to the form. It's
24 so that he could have sex with them? 24 compound and assumes facts not present before
25 MR. Object to the form of the 25 the witness, and I instruct the witness not to
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1 answer the question based on her Fifth 1 witness, and I will instruct the witness not to
2 Amendment privilege. 2 answer based on her Fifth Amendment privilege.
3 THE WITNESS: On the instruction of my 3 THE WITNESS: On the instruction of my
4 lawyer, I must invoke my Fifth Amendment right. 4 lawyer, I must invoke my Fifth Amendment right.
5 BY MR. KUVIN: 5 BY MR. KUVIN:
6 Q. Who introduced you to Jeffrey Epstein the 6 Q. Would you agree with me that
7 first time that ou met him? 7 Jeffrey Epstein owns numerous planes, private
8 MR. Same instruction. 8 planes?
9 THE WITNESS: On the instruction of my 9 MR. Instruct the witness not
10 lawyer, I must invoke my Fifth Amendment right. 10 to answer.
11 BY MR. KUVIN: 11 THE WITNESS: On the instruction of my
12 Q. Did Ghislaine Maxwell introduce you to 12 lawyer, I must invoke my Fifth Amendment right.
13 Jeffrey Epstein for the first time? 13 BY MR. KUVIN:
14 MR. Same instruction. 14 Q. And you've been on every one of those
15 THE WITNESS: On the instruction of my 15 private planes: isn't that true?
16 lawyer, I must invoke my Fifth Amendment right. 16 MR. : Object to the form. It
17 BY MR. KUVIN: 17 assumes facts not before the witness, and I
18 Q. When was the first time you were in 18 will instruct the witness not to answer based
19 Jeffrey Epstein's home located on El Brillo Way on 19 on her Fifth Amendment privilege.
20 Palm Beach Island? 20 THE WITNESS: On the instruction of my
21 MR. Object to the form of the 21 lawyer, I must invoke my Fifth Amendment right.
22 question as compound and assuming facts not 22 BY MR. KUVIN:
23 before the witness. And I instruct the witness 23 Q. Ma'am, isn't it true that you've seen the
24 not to answer based on her Fifth Amendment 24 passenger manifest for Jeffrey Epstein's plane?
25 privilege. 25 MR. Object to the form. It
Page 22 Page 24
1 THE WITNESS: On the instruction of my 1 assumes facts that are not established as known
2 lawyer, I must invoke my Fifth Amendment right. 2 to this witness, and I instruct the witness not
3 BY MR. KUVIN: 3 to answer the question based on her Fifth
4 Q. Would you agree with me that 4 Amendment privilege.
5 Jeffrey Epstein owns a home at 358 El Brillo Way, 5 THE WITNESS: On the instruction of my
6 Palm Beach Island. Florida? 6 lawyer, I must invoke my Fifth Amendment right.
7 MR. : Instruct the witness not 7 MR. KUVIN: Let me show you what we'll
8 to answer based on her Fifth Amendment 8 mark as Exhibit 2.
9 privilege. 9
10 THE WITNESS: On instruction of my 10 (Plaintiff's Exhibit No. 2 was marked for
11 counsel, I must invoke my Fifth Amendment 11 identification.)
12 right. 12 MR. KUVIN: Thank you.
13 BY MR. KUVIN: 13 MR. : Do you want to zoom in on
14 Q. Would you agree with me that you've been 14 it like you did the last time?
15 in that home numerous times? 15 MR. KUVIN: No. that's fine.
16 MR. Instruct the witness not 16 MR. : Take your time.
17 to answer the question based on her Fifth 17 MR. KUVIN: And flip through.
18 Amendment privilege. 18 BY MR. KUVIN:
19 THE WITNESS: On instruction of my lawyer, 19 Q. All right. Ma'am. would you agree with me
20 I must invoke my Fifth Amendment right. 20 that this is a passenger manifest for one of
21 BY MR. KUVIN: 21 Jeffrey Epstein's ai lanes?
22 Q. Would you agree with me that you have gone 22 MR. : Instruct the witness not
23 on Jeffrey E stein's lane numerous times? 23 to answer the question based on her Fifth
24 MR. . Object to the form. It 24 Amendment privilege.
25 assumes fact. that are not present for the 25 THE WITNESS: On the instruction of my
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1 lawyer I must exercise my Fifth Amendment 1 Amendment privilege.
2 right. 2 THE WITNESS: On the instruction of my
3 BY MR. KUVIN: 3 lawyer, I must invoke my Fifth Amendment right.
4 Q. And would you agree with me that you 4 BY MR. KUVIN:
5 appear as a passenger on these flight manifests on 5 Q. Would you also agree with me that the two
6 numerous occasions? 6 unknown females listed on the passenger manifest
7 MR. Object to the form. It 7 marked as Exhibit 2 were underage girls, under the
8 assumes facts not established as known to this 8 age of IS?
9 witness, and I instruct the witness not to 9 MR. : Object to the form. It
10 answer the question. 10 calls for speculation. Also it's not been
11 THE WITNESS: On the instruction of my 11 established this witness has any knowledge of
12 lawyer, I must exercise my Fifth Amendment 12 this document and instruct her not to answer
13 right. 13 based on her Fifth Amendment privilege.
14 BY MR. KUVIN: 14 THE WITNESS: On the instruction of my
15 Q. Would you agree with me that your name 15 lawyer, I must invoke my Fifth Amendment right.
16 does, in fact, appear on the passenger manifest for 16 BY MR. KUVIN:
17 these planes for this lane? 17 Q. Would you agree with me that the girls
18 MR. Same objection and same 18 that are listed as females one, and the second
19 instruction. 19 female for this flight of January II, 2005, from
20 THE WITNESS: On the advice of my lawyer, 20 West Palm Beach to the U.S. Virgin Islands, that
21 I must invoke my Fifth Amendment right. 21 those two females were under the age of 17?
22 BY MR. KUVIN: 22 MR. : Same objection. It has
23 Q. Who are the two females that appear on the 23 not been established the witness has any
24 passenger manifest for January II, 2005. on the 24 knowledge of this document. It calls for her
25 first page of Exhibit 2? 25 to speculate, and I instruct her not to answer
Page 26 Page 28
1 MR. I'll object to the form, 1 based on her Fifth Amendment privilege.
2 and it has not been established this witness 2 THE WITNESS: On the instruction of my
3 knows anything about this document, and I will 3 lawyer, I must invoke my Fifth Amendment right.
4 instruct her not to answer based on the Fifth 4 BY MR. KUV1N:
S Amendment privilege. 5 Q. Would you agree with me that the two
6 THE WITNESS: On the instruction of my 6 females shown on the flight with you of January II,
7 lawyer I must invoke my Fifth Amendment right. 7 2005 were under the a e of 16?
8 BY MR. KUVIN: 8 MR. Same objection as to form
9 Q. Do you agree with me that you took a 9 It has not been established this witness knows
10 flight on Jeffrey Epstein's plane from West Palm 10 anything about whether there were these
11 Beach to the U.S. Virgin Islands. St. Thomas on 11 witnesses, these females and who they are, so
12 January II, 2005? 12 it's asking her to speculate. and I instruct
13 MR. Instruct the witness not 13 her not to answer based on her Fifth Amendment
14 to answer the question based on her Fifth 14 privilege.
15 Amendment privilege. 15 THE WITNESS: On the instruction of my
16 THE WITNESS: On the instruction of my 16 lawyer, I must invoke my Fifth Amendment
17 lawyer I must invoke my Fifth Amendment right. 17 privilege.
18 BY MR. KUVIN: 18 BY MR. KUV1N:
19 Q. Would you agree with me that on that 19 Q. Ma'am, you were on that flight of
20 flight were you. Jeffrey Epstein, 20 January 11. 2005. wereyou not?
21 and two unknown females? 21 MR. I instruct the witness not
22 MR. Object to the form. Again 22 to answer based on her Fifth Amendment
23 assumes facts that have not been established 23 privilege.
24 this witness has any knowledge of and instruct 24 THE WITNESS: On the instruction of my
25 the witness not to answer based on her Fifth 25 lawyer I must invoke my Firth Amendment right.
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1 BY MR. KUVIN: 1 MR. Same instruction.
2 Q. You also agree with me that the two girls 2 THE WITNESS: On the instruction of my
3 that are listed as on that flight with you of 3 lawyer, I must invoke my Fifth Amendment right.
4 January 11, 2005, were under the age of 15 years 4 BY MR. KUVIN:
5 old? 5 Q. Who is
6 MR. Object to the form. It 6 MR. : Same instruction.
7 calls for speculation, lack of personal 7 THE WITNESS: On the advice of my lawyer,
8 knowledge, and instruct the witness not to 8 I must invoke my Fifth Amendment right.
9 answer based on her Fifth Amendment privilege. 9 BY MR. KUVIN:
10 THE WITNESS: On the instruction of my 10 Q. Who is Mark Zeff.
11 lawyer, I must invoke my Fifth Amendment right. 11 MR. Same instruction.
12 BY MR. KUVIN: 12 THE WITNESS: On the advice of my lawyer,
13 Q. Would you agree with me that the two 13 I must invoke my Fifth Amendment right.
14 females listed as being on that flight with you of 14 BY MR. KUVIN:
15 January I 1 of 2005 were under the age of 14 years 15 Q. Who is David Mullen?
16 old? 16 MR. : Same instruction.
17 MR. Object to the form. It 17 THE WITNESS: On the advice of my lawyer,
18 calls for speculation. The witness has no 18 I must invoke my Fifth Amendment right.
19 personal knowledge and instruct the witness not 19 BY MR. KUVIN:
20 to answer based on her Fifth Amendment 20 Q. Who is Todd Meister?
21 privilege. 21 MR. : Same instruction.
22 THE WITNESS: On the instruction of my 22 THE WITNESS: On the advice of my lawyer,
23 lawyer, I must invoke my Fifth Amendment right. 23 I must invoke my Fifth Amendment right.
24 BY MR. KUVIN: 24 BY MR. KUVIN:
25 Q. Would you agree with me that the two 25 Q. Who is Jean-Luc Brunel?
Page 30 Page 32
1 females listed as being on the flight with you of 1 MR. Same instruction.
2 January II, 2005, from West Palm Beach to the U.S. 2 THE WITNESS: On the advice of my lawyer,
3 Virgin Islands, with Jeffrey Epstein as well, were 3 I must invoke my Fifth Amendment right.
4 under the age of 13 years old and you were aware of 4 BY MR. KUVIN:
S that? 5 Q. Ma'am, would you agree with me that all of
6 MR. Object to the form both as 6 the names I just recently mentioned where you
7 compound. it also assumes facts that it has not 7 invoked your Fifth Amendment, were involved in a
8 been established this witness has any knowledge 8 conspiracy to abuse underaged girls, girls under the
9 of. calls for her to speculate, and I instruct 9 age of 18 for sexual ain and pleasure?
10 her not to answer based on her Fifth Amendment 10 MR. : Object to the form of the
11 privilege. 11 question. It calls for a legal conclusion. It
12 THE WITNESS: On the instruction of my 12 is compound. It calls for her to speculate.
13 lawyer I must invoke my Fifth Amendment right. 13 There is no basis for her to be able to give a
14 BY MR. KUVIN: 14 legal opinion as to what a conspiracy is
UNITED STATES DISTRICT COURT 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
SOUTHERN DISTRICT OF FLORIDA 2 IN AND FOR PALM BEACH COUNTY. FLORIDA
CASE NO. 502008CA028051XXXXMB AB
CASE NO. 08-CIV-80119-MARRA/JOHNSON 3
4 .
JANE DOE NO. 2.
5 Plaintiff.
Plaintiff.
6 -vs- VOLUME I OF III
-vs- VOLUME I OF III
JEFFREY EPSTEIN. 7 JEFFREY EPSTEIN.
Defendant 8 Defendant.
I I
9
Related eases: 10
08-80232. 08-08380. 08-80381. 08-80994 11
08-80993. 08-8081 1. 08-80893. 0940469 12 VIDE TAPED DEPOSITION OF
09.80591. 09-80656. 09-80802. 09-81092 13
r 14
VIIMMI 15 Wednesday. March 24.2010
SMON OF
10:37 - 6:51 p.m.
16
Wednesday. March 24. 2010 17
10:37 - 6:51 p.m. 18 250 Australian Avenue South
Suite 1500
250 Australian Avenue South 19 West Palm Beach. Florida 33401
Suite 1500 20
West Palm Beach. Florida 33401 21
22 Reported By:
Cynthia Hopkins. RPR. FPR
Reported By:
Cynthia Hopkins. RPR. FPR 23 Notary Public. State of Florida
Notary Public. State of Florida Prose Court Reporting Services
Prose Court Reporting Services 24 Job No.: 1484
Job No.: 1484 25
Page 2 Page 4
1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 1 DI THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
IN AND FOR PALM BEACH COUNTY. FLORIDA CIRCUIT IN AND FOR PALM BEACH COUNTY. FLORIDA
2 CASE NO. 502008CA028058XXXXMB AD 2 CASE No302008CA037319XXXXMB AB
3 3
M.
4
5 Plaintiff. Plaintiff.
6 -vs- VOLUME I OF III 5
7 VOLUME I OF III
JEFFREY EPSTEIN. J
8 AN
EFISISI,
Defendant. 8
9 / Defendants.
10 9
11 10
VI SITION OF
11 VItSITION OF
12
12
13
13
14 Wednesday. March 24. 2010
14 Wednesday. March 24. 2010
10:37 - 6:51 p.m.
10:37 - 6:51 p.m.
15
15
16
16
17 250 Australian Avenue South
17 250 Australian Avenue South
Suite 1500
Suite 1500
18 West Palm Beach. Florida 33401 16 West Palm Beach. Florida 33401
19 19
20 20
21 21
22 Repotted By: 22 Repotted By:
Cynthia Hopkins. RPR. FPR Cynthia Hopkins. RPR. FPR
23 Notary Public. State of Florida 23 Notary Public. State of Florida
Prose Court Reporting Services Prose Court Reporting Services
24 Job No.: 1484 24 Job No.: 1484
25 25
1 (Pages 1 to 4)
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APPEARANCES: 1
2 On behalf of the Plaintiffs. : 2 INDEX
SPENCER T. KUVIN. ESQUIRE 3
LEOPOLD KUVIN 4
2925 PGA Boulevard 5 EXAMINATION DIRECT CROSS REDIRECT'
Suite 201)
6
5 Palm Beach Garden. Florida 33410
Phone:
6 7
7 On behalf of the Plandiffs...... and BY MR. KUVIN 9
Jane Doe: a
8 9
9 MATTHEW WEISSING. ESQUIRE 10 EXHIBITS
FARMERJAFTE MUSSING. EDWARDS 11 _ _ _
10 FISTOS & LBIRNIAN.P.L 12
425 North Andimvx Avenue 13 EXHIBIT DESCRIPTION PAGE
11 Suite 2 14
Fort Lauderdale Florida 33301
PLAINTIFFS EX. 1 PHOTO 16
12 Phone:
13 On behalf of Jane Does I throu5h K: 15 PLAINTIFFS EL 2 MOE INC.. 24
14 ADAM D. HOROWITZ- ESQUIRE PASSENGER MANIFEST'
MERNIEI-STEIN it HOROWITZ. P.A. 16 PLAINTIFFS EX. 3 HYPERION AIR. INC..
15 18205 Biscayne Boulevard PASSENGER MANIFEST
Suite 22114 17 PLAINTIFFS EX. 6 PHOTO 63
16 Miami. a t i PLAINTIFFS EL 7 PHOTO 65
Phone: 18 PLAINTIFFS EX. 8 PHOTO 68
17 E-mail: PLAINTIFFS EX. 9 PHOTO 71
16 On behalf of the PI:midis. 101. 102 and 103: 19 PLAINTIFFS EL 10 PHOTO 100
19 KATHERINE W. EZELI- ESQUIRE PLAINTIFFS EL 11 PHOTO 101
AMY JOSEFSBERG EDERI. ESQUIRE 20 PLAINTIFFS EL 12 PHOTO 103
20 PODHURST ORSECK
PLAINTIFFS EX. 4 PHONE MESSAGE PADS
25 wear Flatlet Street
21 Suite WO
21 PLAINTIFFS EL 5 CELLPHONE RECORDS
Miami.iiiiiiiiii PLAINTIFFS EL 13 PHOTO 144
22 Phone: 22
23 1Via telephoner 23
24 24
25 25
Page 6 Page 8
1 Appearances continued... 1 PROCEEDINGS
2 On behalf of the Plaintiff. Jane Doe ll:
2
3 ISIDRO MANUEL GARCIA. ESQUIRE — — —
GARCIA. ELKINS & BOEHRINGER 3 THE VIDEOGRAPHER: We are now on video
4 224 Datum Avenue. Suite 900 4 record. This is Media No. 1 in the videotaped
West Palm Beach Fl ida 33401
5 Phone: 5 deposition of in the matter of
6 6 Jane Doe versus Jeffrey Epstein, et al. Today
7 On behalf of the Defendant:
7 is Wednesday. March 24th. 2010. It is
8 JACK ALAN GOLDBERGER. ESQUIRE
ATTERBURY. GOLDBERGER & WEISS. P.A. 8 10:36 a.m. We are here at Prose Court
9 250 Australian Avenue South 9 Reporting. 250 South Australian Avenue. West
Suite 1400
10 West ida 33401-5012 10 Palm Beach. Florida.
Phony 11 My name is Joe Kozak. I'm the
11
12 videographer. The reporter is Cindy
12
13 On f h Win • 13 Hopkins from Prose Court Reporting Agency.
14 19 Would counsel please introduce
15 yourselves, and then the court reporter
16 will swear in the witness.
17 MR. KUVIN: Good morning. Spencer Kuvin
17 18 on behalf of one of the Plaintiffs.
18
19 MR. HOROWITZ: Adam Horowitz on behalf of
19
20 ALSO PRESENT: 20 Jane Does 2 through 8. And just for the record
21 Jessica Cadwell. Paralegal 21 purposes. the deposition is also being taken in
Burman. Critton. Lanier & Coleman. P.A.
22 the federal cases, I believe, case being
22 Joseph Kozak. Videographer
Prose Court Reporting Services 23 Jane Doe 2 versus Jeffrey Epstein.
23 24 MR. WEISSING: Matt Weissing on behalf of
24
25 25 three of the Plaintiffs.
2 (Pages 5 to 8
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1 MR. GARCIA: Sid Garcia for Jane Doe. 1 privilege.
2 Roman Numeral II. 2 MR. KUVIN: I'll agree with that
3 MR. GOLDBERGER: Jack Goldberger on behalf 3 procedure.
4 of Jeffrey Epstein. 4 MR. Anyone object to that
5 MS. CADWELL: Jessica Cadwell. paralegal. 5 procedure?
6 on behalf of Jeffre stein. 6 MR. GOLDBERGER: Actually I think if, in
7 MR. on behalf 7 fact, this deposition is used in a trial, 1
a of the witness. 8 think you would want the lengthier answer as
9 MR. KUVIN: Kathy. your turn. 9 being the answer that is played to the jury.
10 MS. EZELL: Okay. Kathy Ezell and Amy 10 So either you guys can agree that it gets cut
11 Ederi on behalf of Plaintiff, Jane Doe 103. 11 in or she's going to have to -- I can't tell
12 Thereupon. 12 you what to do, but I would suggest that she
13 l l 13 give the lengthier answer each time.
14 Having been first duly sworn or affirmed, was 14 But there's got to be a way that you
15 examined and testified as follows: 15 guys can reach an agreement though, that
16 DIRECT EXAMINATION 16 from a technology perspective, that the
17 BY MR. KUVIN: 17 lengthy answer that she just gave would be
18 Q. Good morning. 18 used during any trial testimony. Can that
19 A. Morning. 19 be done?
20 Q. Couldyougive us your full name, please. 20 MR. KUVIN: I don't know procedurally
21 A. . 21 whether it can be done.
22 Q. il aiave a middle name? 22 MR. GOLDBERGER: I think --
23 A. 23 MR. KUVIN: I don't know that, well --
24 Q. Would ou s II that for us? 24 MR. GOLDBERGER: And again, it's not my,
25 A. 25 ifs not my deal. I'm just telling you how
Page 10 Page 12
1 Q. What's our current address? 1 we've done it in the past.
2 MR. I'm going to instruct the 2 MR. KUVIN: I hear you. and I have a
3 witness not to answer that question on the 3 number of issues primary, primarily of which
4 basis of her Fifth and 14th Amendment 4 that you're not here to represent anyone
S privileges against self-incrimination. 5 currently.
6 MR. KUVIN: Okay. We had spoken before 6 MR. GOLDBERGER: Yeah. I am. I'm
7 with respect to there are likely going to be 7 actually. I'm actually here representing
8 answers similar to that throughout this 8 Jeffrey Epstein. so...
9 deposition. I have agreed to a procedure that 9 MR. KUVIN: Okay. With respect to all the
10 we can do a shortened answer. However you want 10 civil cases. though. you're not here to
11 to handle that. I leave it up to you. But I do 11 represent anyone, so --
12 agree that whatever the shortened answer is, 12 MR. GOLDBERGER: Yes. I am.
13 that it will satisfy the length. lengthy answer 13 MR. KUVIN: With the exception --
14 that she would like to give. 14 MR. GOLDBERGER: I represent -- I am --1
15 So, do we want to do that with this 15 don't mean to interrupt you. but I am counsel
16 question, or how do you want to handle 16 of record in the civil cases.
17 that procedurall ? 17 MR. KUVIN: Oka . Okay.
18 MR. Well. I think I have given 18 MR. If we have a stipulation,
19 the instruction. I think she, will give her 19 what's the problem? Are you --
20 the same instruction in the future to the 20 MR. KUVIN: There is none.
21 extent that it's relevant, and I think that if 21 MR. -- worried about a waiver?
22 we can all just agree that if she simply says 22 MR. GOLDBERGER: No. I'm not worried abou
23 or I simply say "The Fifth Amendment," that 23 that at all. I'm worried about what is played
24 will qualify as giving a sufficient answer to 24 to a jury if this gets tried.
25 -- a, a matter of law. and will invoke that 25 MR. KUVIN: Okay. And I appreciate you
3 (Pages 9 to 12)
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1 coachingM. but I think he can handle 1 I choose to invoke my Fifth Amendment right.
2 himself pretty adequately now -- 2 BY MR. KUVIN:
3 MR. GOLDBERGER: I have -- 3 Q. Would ou agree with me that you're
4 MR. KUVIN: So I leave it up to -- 4 approximatel
5 MR. GOLDBERGER: I have all the confidence 5 MR. : Same instruction.
6 in . 6 THE WITNESS: On the advice of my lawyer,
7 MR. KUVIN: Mr. with respect to 7 I must invoke my Fifth Amendment right.
8 how you want to handle it. I think we have an 8 BY MR. KUVIN:
9 agreement. 9 Would you agree with me that your eyes are
10 MR. : I'm satisfied that we have 10
11 a stipulation, and I assume if there is ever a 11 MR. Same instruction.
12 trial, that would be played or produced to the 12 THE WITNESS: On the advice of my lawyer,
13 jury that simply by using shorthand, what she's 13 I choose to invoke my Fifth Amendment right.
14 really saying is the lengthier answer now. I'm 14 BY MR. KUVIN:
15 satisfied with that. 15 Q. Would you agree with me that you were born
16 MR. KUVIN: And I agree with that. 16 in
17 BY MR. KUVIN: 17 MR. : Same instruction.
18 Q. Okay. Ma'am, what is your current 18 THE WITNESS: On the advice of my lawyer,
19 address? 19 I choose to invoke my Fifth Amendment right.
20 MR. : Again, I will instruct the 20 BY MR. KUVIN:
21 witness not to answer the question. 21 Q. What are the names of your parents?
22 THE WITNESS: On the instruction of my 22 MR. : Same instruction.
23 lawyer. I choose to invoke my Fifth Amendment 23 THE WITNESS: On the advice of my lawyer,
24 right. 24 I must invoke my Fifth Amendment right.
25 25
Page 14 Page 16
1 BY MR. KUVIN: 1 BY MR. KUVIN:
2 Q. What is our current phone number? 2 Q. Areyou married or single?
3 MR. : Same instruction. 3 MR. : Same instruction.
4 THE WITNESS: On the advice of my lawyer, 4 THE WITNESS: On the advice of my lawyer,
5 I choose to invoke my Fifth Amendment right. 5 I must to invoke my Fifth Amendment right.
6 BY MR. KUVIN: 6 (Plaintiffs Exhibit No. I was marked for
7 Q. What is our cell hone number? 7 identification.)
8 MR. : Same instruction -- 8 MR. KUVIN: I'm going to show you what
9 THE WITNESS: On the advice of my lawyer, 9 we'll mark as Plaintiffs Exhibit I.
10 I choose to invoke m Fifth Amendment right. 10 And I'll ask the videographer to zoom
11 MR. : You have to let me speak 11 in here fora second.
12 before you answer in case there's an objection 12 BY MR. KUVIN:
13 or any of the other lawyers have an objection. 13 Q. Okay. Ma'am, I am going to show you a
14 BY MR. KUVIN: 14 photograph we've marked as Plaintiffs Exhibit 1 and
15 Q. I am going to show you a photograph. Oh, 15 ask you if you recognize this registered sex
16 what is your date of birth? 16 offender.
17 MR. : Same instruction. 17 MR. : First, object to the form
18 THE WITNESS: On the advice of my lawyer, 18 of the question. It assumes facts not before
19 I choose to invoke my Fifth Amendment right. 19 the witness, and I'll give the witness the same
20 MR. KUVIN: Let's make is easier. 20 instruction as to that question.
21 BY MR. KUVIN: 21 THE WITNESS: At the advice of my lawyer,
22 Q. would ou agree with me that 22 I must invoke my Fifth Amendment right.
23 your date of birth i 23 BY MR. KUVIN:
24 MR. : Same instruction. 24 Q. Would you agree with me that this
25 THE WITNESS: On the advice of my lawyer, 25 registered sex offender's name is Jeffrey Epstein?
4 (Pages 13 to 1 6)
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1 MR. Same instruction, same 1 question. It's ambiguous and compound. and I
2 objection. 2 will instruct the witness not to answer based
3 THE WITNESS: At the advice of my lawyer, 3 on her Fifth Amendment privilege.
4 I must invoke my Fifth Amendment right. 4 THE WITNESS: On the advice of my lawyer,
S BY MR. KUVIN: 5 I must invoke my Fifth Amendment right.
6 Q. Would you agree with me that Jeffrey 6 BY MR. KUVIN:
/ Epstein is a sexual offender? 7 Q. And wh did ou do that?
8 MR. Object to the form of the 8 MR. : Object to the form. It's
9 question and instruct the witness not to answer 9 ambiguous, in fact that what?
10 on her Fifth Amendment privilege. 10 BY MR. KUVIN:
11 THE WITNESS: On the advice of my lawyer I 11 Q. Why did you bring minor girls to
12 must invoke my Fifth Amendment right. 12 Jeffrey Epstein for him to have sex with?
13 BY MR. KUVIN: 13 MR. : Same objection as to forty
14 Q. Would you agree with me that 14 and instruct the witness not to answer.
15 Jeffrey Epstein sexual) abused you? 15 THE WITNESS: On the advice of my lawyer,
16 MR. Objection to the form, 16 I must invoke my Fifth Amendment right.
17 both as to the form of the question as to 17 BY MR. KUVIN:
18 harassing and instruct the witness not to 18 Q. What do ou currently do for a job?
19 answer, based on the Fifth Amendment privilege. 19 MR. : Instruct the witness not
20 THE WITNESS: On the advice of my lawyer. 20 to answer the question.
21 I must invoke my Fifth Amendment right. 21 THE WITNESS: On the advice of my lawyer,
22 BY MR. KUVIN: 22 I must invoke my Fifth Amendment right.
23 Q. Would you agree with me that you were a 23 BY MR. KUVIN:
24 minor when Jeffrey Epstein first had sexual 24 I.
25 relations with you?
Page 18 Page 20
1 MR. Object to the form. It 1 MR. Instruct the witness not
2 assumes facts not before the witness. It is a 2 to answer the question.
3 compound question and I would instruct the 3 THE WITNESS: On the advice of my lawyer,
4 witness not to answer based on her Fifth 4 I must invoke my Fifth Amendment right.
S Amendment privilege. 5 BY MR. KUVIN:
6 THE WITNESS: On the advice of my lawyer. 6 ii
7 I must invoke my Fifth Amendment right. I
8 BY MR. KUVIN: 8 MR. Same instruction.
9 Q. Would you agree with me that you have had 9 THE WITNESS: On the advice of my lawyer,
10 sex with Jeffrey E tein? 10 I must invoke my Fifth Amendment right.
11 MR. Same instruction. 11 BY MR. KUVIN:
12 THE WITNESS: On the advice of my lawyer. 12 I.
13 I must invoke my Fifth Amendment right.
14 BY MR. KUVIN: 9
15 Q. Would you agree with me that you first had 15 MR. Instruct the witness not
16 sex with Jeffrey Epstein when you were under the age 16 to answer the question.
17 of 18? 17 THE WITNESS: On the instruction of my
18 MR. Same instruction. 18 lawyer, I must invoke my Fifth Amendment right.
19 THE WITNESS: On the advice of my lawyer. 19 BY MR. KUVIN:
20 I must invoke my Fifth Amendment right. 20 •
21 BY MR. KUVIN:
22 Q. Would you agree with me. ma'am, that you
23 brought numerous underage girls to Jeffrey Epstein 23 MR. Object to the form. It's
24 so that he could have sex with them? 24 compound and assumes facts not present before
25 MR. Object to the form of the 25 the witness, and I instruct the witness not to
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1 answer the question based on her Fifth 1 witness, and I will instruct the witness not to
2 Amendment privilege. 2 answer based on her Fifth Amendment privilege.
3 THE WITNESS: On the instruction of my 3 THE WITNESS: On the instruction of my
4 lawyer, I must invoke my Fifth Amendment right. 4 lawyer, I must invoke my Fifth Amendment right.
5 BY MR. KUVIN: 5 BY MR. KUVIN:
6 Q. Who introduced you to Jeffrey Epstein the 6 Q. Would you agree with me that
7 first time that ou met him? 7 Jeffrey Epstein owns numerous planes, private
8 MR. Same instruction. 8 planes?
9 THE WITNESS: On the instruction of my 9 MR. Instruct the witness not
10 lawyer, I must invoke my Fifth Amendment right. 10 to answer.
11 BY MR. KUVIN: 11 THE WITNESS: On the instruction of my
12 Q. Did Ghislaine Maxwell introduce you to 12 lawyer, I must invoke my Fifth Amendment right.
13 Jeffrey Epstein for the first time? 13 BY MR. KUVIN:
14 MR. Same instruction. 14 Q. And you've been on every one of those
15 THE WITNESS: On the instruction of my 15 private planes: isn't that true?
16 lawyer, I must invoke my Fifth Amendment right. 16 MR. : Object to the form. It
17 BY MR. KUVIN: 17 assumes facts not before the witness, and I
18 Q. When was the first time you were in 18 will instruct the witness not to answer based
19 Jeffrey Epstein's home located on El Brillo Way on 19 on her Fifth Amendment privilege.
20 Palm Beach Island? 20 THE WITNESS: On the instruction of my
21 MR. Object to the form of the 21 lawyer, I must invoke my Fifth Amendment right.
22 question as compound and assuming facts not 22 BY MR. KUVIN:
23 before the witness. And I instruct the witness 23 Q. Ma'am, isn't it true that you've seen the
24 not to answer based on her Fifth Amendment 24 passenger manifest for Jeffrey Epstein's plane?
25 privilege. 25 MR. Object to the form. It
Page 22 Page 24
1 THE WITNESS: On the instruction of my 1 assumes facts that are not established as known
2 lawyer, I must invoke my Fifth Amendment right. 2 to this witness, and I instruct the witness not
3 BY MR. KUVIN: 3 to answer the question based on her Fifth
4 Q. Would you agree with me that 4 Amendment privilege.
5 Jeffrey Epstein owns a home at 358 El Brillo Way, 5 THE WITNESS: On the instruction of my
6 Palm Beach Island. Florida? 6 lawyer, I must invoke my Fifth Amendment right.
7 MR. : Instruct the witness not 7 MR. KUVIN: Let me show you what we'll
8 to answer based on her Fifth Amendment 8 mark as Exhibit 2.
9 privilege. 9
10 THE WITNESS: On instruction of my 10 (Plaintiff's Exhibit No. 2 was marked for
11 counsel, I must invoke my Fifth Amendment 11 identification.)
12 right. 12 MR. KUVIN: Thank you.
13 BY MR. KUVIN: 13 MR. : Do you want to zoom in on
14 Q. Would you agree with me that you've been 14 it like you did the last time?
15 in that home numerous times? 15 MR. KUVIN: No. that's fine.
16 MR. Instruct the witness not 16 MR. : Take your time.
17 to answer the question based on her Fifth 17 MR. KUVIN: And flip through.
18 Amendment privilege. 18 BY MR. KUVIN:
19 THE WITNESS: On instruction of my lawyer, 19 Q. All right. Ma'am. would you agree with me
20 I must invoke my Fifth Amendment right. 20 that this is a passenger manifest for one of
21 BY MR. KUVIN: 21 Jeffrey Epstein's ai lanes?
22 Q. Would you agree with me that you have gone 22 MR. : Instruct the witness not
23 on Jeffrey E stein's lane numerous times? 23 to answer the question based on her Fifth
24 MR. . Object to the form. It 24 Amendment privilege.
25 assumes fact. that are not present for the 25 THE WITNESS: On the instruction of my
6 (Pages 21 to 24)
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1 lawyer I must exercise my Fifth Amendment 1 Amendment privilege.
2 right. 2 THE WITNESS: On the instruction of my
3 BY MR. KUVIN: 3 lawyer, I must invoke my Fifth Amendment right.
4 Q. And would you agree with me that you 4 BY MR. KUVIN:
5 appear as a passenger on these flight manifests on 5 Q. Would you also agree with me that the two
6 numerous occasions? 6 unknown females listed on the passenger manifest
7 MR. Object to the form. It 7 marked as Exhibit 2 were underage girls, under the
8 assumes facts not established as known to this 8 age of IS?
9 witness, and I instruct the witness not to 9 MR. : Object to the form. It
10 answer the question. 10 calls for speculation. Also it's not been
11 THE WITNESS: On the instruction of my 11 established this witness has any knowledge of
12 lawyer, I must exercise my Fifth Amendment 12 this document and instruct her not to answer
13 right. 13 based on her Fifth Amendment privilege.
14 BY MR. KUVIN: 14 THE WITNESS: On the instruction of my
15 Q. Would you agree with me that your name 15 lawyer, I must invoke my Fifth Amendment right.
16 does, in fact, appear on the passenger manifest for 16 BY MR. KUVIN:
17 these planes for this lane? 17 Q. Would you agree with me that the girls
18 MR. Same objection and same 18 that are listed as females one, and the second
19 instruction. 19 female for this flight of January II, 2005, from
20 THE WITNESS: On the advice of my lawyer, 20 West Palm Beach to the U.S. Virgin Islands, that
21 I must invoke my Fifth Amendment right. 21 those two females were under the age of 17?
22 BY MR. KUVIN: 22 MR. : Same objection. It has
23 Q. Who are the two females that appear on the 23 not been established the witness has any
24 passenger manifest for January II, 2005. on the 24 knowledge of this document. It calls for her
25 first page of Exhibit 2? 25 to speculate, and I instruct her not to answer
Page 26 Page 28
1 MR. I'll object to the form, 1 based on her Fifth Amendment privilege.
2 and it has not been established this witness 2 THE WITNESS: On the instruction of my
3 knows anything about this document, and I will 3 lawyer, I must invoke my Fifth Amendment right.
4 instruct her not to answer based on the Fifth 4 BY MR. KUV1N:
S Amendment privilege. 5 Q. Would you agree with me that the two
6 THE WITNESS: On the instruction of my 6 females shown on the flight with you of January II,
7 lawyer I must invoke my Fifth Amendment right. 7 2005 were under the a e of 16?
8 BY MR. KUVIN: 8 MR. Same objection as to form
9 Q. Do you agree with me that you took a 9 It has not been established this witness knows
10 flight on Jeffrey Epstein's plane from West Palm 10 anything about whether there were these
11 Beach to the U.S. Virgin Islands. St. Thomas on 11 witnesses, these females and who they are, so
12 January II, 2005? 12 it's asking her to speculate. and I instruct
13 MR. Instruct the witness not 13 her not to answer based on her Fifth Amendment
14 to answer the question based on her Fifth 14 privilege.
15 Amendment privilege. 15 THE WITNESS: On the instruction of my
16 THE WITNESS: On the instruction of my 16 lawyer, I must invoke my Fifth Amendment
17 lawyer I must invoke my Fifth Amendment right. 17 privilege.
18 BY MR. KUVIN: 18 BY MR. KUV1N:
19 Q. Would you agree with me that on that 19 Q. Ma'am, you were on that flight of
20 flight were you. Jeffrey Epstein, 20 January 11. 2005. wereyou not?
21 and two unknown females? 21 MR. I instruct the witness not
22 MR. Object to the form. Again 22 to answer based on her Fifth Amendment
23 assumes facts that have not been established 23 privilege.
24 this witness has any knowledge of and instruct 24 THE WITNESS: On the instruction of my
25 the witness not to answer based on her Fifth 25 lawyer I must invoke my Firth Amendment right.
7 (Pages 25 to 28)
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1 BY MR. KUVIN: 1 MR. Same instruction.
2 Q. You also agree with me that the two girls 2 THE WITNESS: On the instruction of my
3 that are listed as on that flight with you of 3 lawyer, I must invoke my Fifth Amendment right.
4 January 11, 2005, were under the age of 15 years 4 BY MR. KUVIN:
5 old? 5 Q. Who is
6 MR. Object to the form. It 6 MR. : Same instruction.
7 calls for speculation, lack of personal 7 THE WITNESS: On the advice of my lawyer,
8 knowledge, and instruct the witness not to 8 I must invoke my Fifth Amendment right.
9 answer based on her Fifth Amendment privilege. 9 BY MR. KUVIN:
10 THE WITNESS: On the instruction of my 10 Q. Who is Mark Zeff.
11 lawyer, I must invoke my Fifth Amendment right. 11 MR. Same instruction.
12 BY MR. KUVIN: 12 THE WITNESS: On the advice of my lawyer,
13 Q. Would you agree with me that the two 13 I must invoke my Fifth Amendment right.
14 females listed as being on that flight with you of 14 BY MR. KUVIN:
15 January I 1 of 2005 were under the age of 14 years 15 Q. Who is David Mullen?
16 old? 16 MR. : Same instruction.
17 MR. Object to the form. It 17 THE WITNESS: On the advice of my lawyer,
18 calls for speculation. The witness has no 18 I must invoke my Fifth Amendment right.
19 personal knowledge and instruct the witness not 19 BY MR. KUVIN:
20 to answer based on her Fifth Amendment 20 Q. Who is Todd Meister?
21 privilege. 21 MR. : Same instruction.
22 THE WITNESS: On the instruction of my 22 THE WITNESS: On the advice of my lawyer,
23 lawyer, I must invoke my Fifth Amendment right. 23 I must invoke my Fifth Amendment right.
24 BY MR. KUVIN: 24 BY MR. KUVIN:
25 Q. Would you agree with me that the two 25 Q. Who is Jean-Luc Brunel?
Page 30 Page 32
1 females listed as being on the flight with you of 1 MR. Same instruction.
2 January II, 2005, from West Palm Beach to the U.S. 2 THE WITNESS: On the advice of my lawyer,
3 Virgin Islands, with Jeffrey Epstein as well, were 3 I must invoke my Fifth Amendment right.
4 under the age of 13 years old and you were aware of 4 BY MR. KUVIN:
S that? 5 Q. Ma'am, would you agree with me that all of
6 MR. Object to the form both as 6 the names I just recently mentioned where you
7 compound. it also assumes facts that it has not 7 invoked your Fifth Amendment, were involved in a
8 been established this witness has any knowledge 8 conspiracy to abuse underaged girls, girls under the
9 of. calls for her to speculate, and I instruct 9 age of 18 for sexual ain and pleasure?
10 her not to answer based on her Fifth Amendment 10 MR. : Object to the form of the
11 privilege. 11 question. It calls for a legal conclusion. It
12 THE WITNESS: On the instruction of my 12 is compound. It calls for her to speculate.
13 lawyer I must invoke my Fifth Amendment right. 13 There is no basis for her to be able to give a
14 BY MR. KUVIN: 14 legal opinion as to what a conspiracy is