EFTA00159250.pdf

0001
1 UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
2
Case No. 08-CV-80893-CIV-MARRA/JOHNSON
3
4
5 JANE DOE,
6 Plaintiff,
7 vs.
8 JEFFREY EPSTEIN, et al.,
9 Defendants.

10
11
12
13 DEPOSITION OF
Volume
14 Pages 1 through 138
Videotaped
15
16
17 Monday, March 15, 2010
10:13 a.m. - 12:42 p.m.
18 U.S. Legal Support
515 East Las Olas Boulevard, 3rd Floor
19 Fort. Lauderdale, Florida 33301
20
21
Stenographically Reported By:
22 Janet L. McKinney, RPR, FPR, CLR
23 Registered Professional Reporter
24 Florida Professional Reporter
25 Certified LiveNote Reporter
0002
1 APPEARANCES:
2 ON BEHALF OF THE PLAINTIFF:
3 FARMER, JAFFE, WEISSING, EDWARDS,
FISTOS & LEHRMAN
4 425 North Andrews Avenue
Suite 2
5 Fort Lauderdale, Florida 33301-3268

6
BY: BRADLEY EDWARDS, ESQ.
7
8 ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN:
9 BURMAN, CRITTON, LUTTIER
COLEMAN, LLP
10 303 Banyan Boulevard
Suite 40C
11 West Palm Beach, Florida 33401

12




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 BY: MICHAEL J. PIKE, ESQ.
13
14 ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES:
15 KERMELSTEIN & HOROWITZ, P.A.
18205 Biscayne Boulevard
16 Suite 2218
Miami, Florida 3316C
17

18 BY: STUART S. MERMELSTEIN, ESQ.
19
ON BEHALF OF THE WITNESS:
20
ROBBINS, TUNKEY, ROSS, AMSEL,
21 RABEN & WAXMAN, P.A.
2250 Southwest Third Avenue
22 4th Floor
Miami, Florida 33129
23

24 BY: ALAN S. ROSS, ESQ.
25 Also Present: Sean McGuire, Videographer
U.S. Legal Support
0003
1 INDEX
2
Page
3
Direct Examination By Mr. Edwards 7
4 Cross-Examination By Mr. Mermelstein 111
Redirect Examination By Mr. Edwards 127
Recross-Examination By Mr. Mermelstein 133
6
7 Certificate of Oath 137
8 Certificate of Reporter 138
9
10 EXHIBITS
11 PLF'S
12 No. Description Page
13
14 1 Jane Doe 102 v. Jeffrey Epstein 33
15 complaint
16 2A-2G Telephone messages 62
17 3 Handwritten notes 72
18 2H Telephone message 87
19 4 Gawker.com photo with story 127
20
21
22 WITNESS'S
23 No. Description Page
24
25 1 Target letter 4
0004
1 Videotaped deposition taken before JANET L.




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 2 McKINNEY, Registered Professional Reporter, Florida
3 Professional Reporter, Certified LiveNote Reporter and
4 Notary Public in and for the Slate of Florida at Large
5 in the above cause.
6 (Whereupon, Witness's Exhibit 1 was marked for
7 identification.)
8 VIDE0GRAPHER: We are now on the video record.
9 Today is Monday, the 15th day of March, 2010. The
1C time is 9:13 a.m.. (sic). We are here al 515 East.
11 Las Olas Boulevard, 3rd Floor, Fort Lauderdale,
12 Florida, for the purpose of taking the videotape
13 deposition of taken in Case Number
14 08-CIV-80893, ane oe v. effrey Epstein, el. al.
15 The court reporter is Janet. McKinney; the
16 videographer is Sean McGuire, both of V.S. Legal
17 Support.
18 Will counsel and all present please introduce
19 yourself and the court reporter will swear the
20 witness.
21 N.R. EDWARDS: Brad Edwards. I represent the
22 plaintiff, Jane Doe also "Jane Doe"; EW, "EW"; LM,
23 'LM.".
24 MR. MERMELSTEIN: Stuart Mermelstein. I
25 represent Jane Doe Numbers 2 through 8.
0005
1 MR. PIKE: Michael Pike on behalf of Jeffrey
2 Epstein.
3 MR. ROSS: And good morning, my name is Alan
4 Ross. I represent the witness,
5 THE REPORTER: Would you raise your rig
6 hand, please.
7 Do you solemnly swear or affirm the testimony
8 you're about to give will be the truth, and nothing
9 but the truth, so help you God?
10 THE WITNESS: I do.
11 MR. ROSS: Before the deposition begins and in
12 an effort to streamline the process of getting
13 through this deposition on behalf of the witness we
14 have had marked as Witness Exhibit Number 1 an
15 August 31, 2007 letter from the United States
16 Attorney's Office through
17 her then counsel, which is called a
18 target. letter ide. as a target of a
19 federal Grand Jury investigation in the Southern
20 District of Florida and outlining a number of
21 offenses that. were the subject =alter of
22 investigation.
23 As a result of that, it is anticipated that.
24 some of the questions that may be asked during the
25 course of this deposition she may invoke her Fifth
0006
1 Amendment privilege against self-incrimination.
2 And in order to streamline this we've agreed prior
3 to beginning this that she will simply answer "I




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 4 refuse to answer.' The parties will understand and
5 the record will reflect that, she is invoking her
6 Fifth Amendment privilege against
7 self-incrimination.
8 If there is some other privilege,
9 attorney-client privilege or sore other objection
1C Chat I may have to a question, I'll specifically
11 state it. But her answer °I refuse to answer• will
12 be on Fifth Amendment grounds if that's acceptable
13 CO everyone.
14 MR. EDWARDS: It's acceptable.
15 KR. MERMELSTEIN: It's acceptable.
16 KR. PIKE: Acceptable.
17 MR. ROSS: Okay. Madam court reporter has
18 already marked the exhibit, and I'll leave that
19 with her.
20 MR. EDWARDS: Okay.
21
22
23
24
25
0007
1 THEREUPON:
2
3 having been first duly sworn or affirmed, was examined
4 and testified as follows:
5 DIRECT EXAMINATION
6 BY K.R. EDWARDS:
7 Q. Can you tell us your full full name.
8 A.
9 Q. At some point in time you were known as
10 is that correct?
11 A. Correct.
12 Q. And when did that change?
13
14
15
16
17
18
19
20 Q. When were ou married?
21 A.
22 Q. uk4v. whni 'mvout le of birth?
23
24
25
A.[
Q.
A. Yes.
0008
1 Q. And who are you married to?
2
3
4
5




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 6 A. Correct.
7
8
9
10
11 w
12
13
14
15 A.
16 Q. w o was t e connection at
17 that invited you?
18
19
20
21
22
23
24
25
0009
1
2
3
4
5
6
7
8
Q. Well, you can continue.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
0010
1
2 A. Yes.
3 Q. So in order to come to the United States you
4 needed to get a work visa?
A. I was invited actually just to kind of get a
6 feeling if I will be suitable. So I came on a business
7 tourist visa which is, I believe, 61/82.




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 8 Q. Okay. And where did you first go when you
9 came to the United States, what state?
IC A. Florida.
11 Q. And what city in Florida?
12 A. Miami.
13 Q. And what did you do for your two weeks when
14 you first arrived in Miami, Florida?
15 A. I do not recall.
16 Q. Okay. But did you do any modeling?
17 A. Well, like I would see some photographers, the
18 agency would send me like on all calls to see
19 photographers to kind of introduce me as a model.
2C why did you make the decision Lo go with
21 in the United Stales when you already were
22 modeling in --
23 A. Um-hum.
24 Q. -- Europe?
25 A. Well, you know, just to expand it was
0011
1 something that I did. And I decided to take a year off
2 after I graduated from. high school and -- you know,
3 just to expand the modeling -- the modeling
4 possibilities, opportunities.
5 Q. Where di uate from high school?
6 A. In
7 Q. What ear?
8 A.
Q. And do you have any college? Have you gone to
10 college after that?
11
12
13
14 did you get your associate's degree from.
15
16 A.
17 Q. chelor's degree right
18 now?
19 A. Yes.
2C Q. From where?
21 A.
22 Q. in wnaL.
23 A.
24 Q. a you been in the
25 program?
0012
A.Since fall
2 Q.And when do you expect to graduate?
3 A.Fall
4 Q.Are you a full-Lime student or part-Lime?
5 A.I'm a full-time student at this time.
6 you first arrived in Miami, Florida in
7 did you decide during that two weeks that_
8 you were going to stay permanently?
9 A. No.




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 IC Q. Okay. Did you go back to
11 A. Yes, I have. I have -- I went back for
12 Christmas.
13 Q. Okay. Poor question. Going back LcI'm
14 trying to just understand how it was that -- you came
15 over here on a two-week business visa, but eventually
16 you ended up staying for a longer period of Lime,
17 correct?
18 A. Right-
19 Q. Okay. And how did that. come about, just tell
20 me?
21 A. Well, I got. romantically involved with my
22 current husband and so when -- you know, we just
23 started dating, we got engaged, and that's how, you
24 know, our relation evolved -- evolved, and eventually,
25 you know, I got married and -- and stayed.
0013
1 Q. Okay. And since coming to the United States
2 have you always lived in Miami, Florida?
3 A. No.
4 Q. All right. Where else have you lived in the
5 United States?
6 A. New York.
7 Q. Where in New York?
8 A. Manhattan.
9 Q. What, was the address in Manhattan where you
10 lived?
11 MR. ROSS: I'm going to advise you Lo invoke
12 privilege.
13 A. I refuse to answer.
14 Q. Okay. Have you -- are you familiar with an
15 address at 301 East 66th Street in New York?
16 A. I refuse to answer.
17 MR. PIKE: May we take a break for a second?
18 May I speak with you?
19 MR. ROSS: Sure.
20 VIDEOGRAPHER: Off the record, 10:22 a.m.
21 (Recess Laken at 10:22 a.m.)
22 (Deposition resumed at 10:23 a.m.)
23 VIDEOGRAPHER: On the record, 10:23 a.m..
24 MR. ROSS: Brad, let me just interrupt for a
25 moment.
0014
1 MR. EDWARDS: No problem.
2 MR. ROSS: Just to be sure, when the witness
3 answers "I refuse to answer" to be clear the Cull
4 statement that she's not saying for the sake of
5 saving Lime is that. she's invoking her Fifth
6 Amendment right against self-incrimination. Just.
7 to be clear.
8 MR. EDWARDS: That's what I've understood all
9 along.
IC MR. MERMELSTEIN: That's what I understood.
11 MR. ROSS: Okay, fine. Go ahead.




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 12 MR. EDWARDS: This is just for the sake of
13 brevity --
14 MR. ROSS: Exactly.
15 MR. EDWARDS: -- and let's move it on.
16 BY MR. EDWARDS:
17 Q. All right. So I'm going to ask the question
18 again, I don't remember whether you'd responded yet,
19 but are you familiar with the address in Manhattan
20 301 East. 66th Street in New York?
21 A. I refuse to answer.
22 Q. Okay. How long did you live in -- well, what
23 was the first address that you lived in in Miami?
24 A.
25
0015
1 Q. South Shore. Okay.
2 A. Um-hum.
3 Q. Have you ever had your deposition Laken
4 before?
5 A. No.
6 Q. Okay. You're doing very well so far. There's
7 a couple rules I didn't explain but mainly because
8 you're doing very well. I just. have to wait for you to
9 finish your answer; you have to wait for me to finish
10 my question. We have one court reporter. She can only
11 Lake down one of us. Give us an answer that we all
12 understand. Nodding of the head or shaking the head
13 are easy to do and I gel what you're saying, but she
14 doesn't. Ah-ha or un-ah are things that are commonly
15 said. They look the same on paper.
16 If I ask a bad question which could happen, as
17 already happened and probably will again, just tell me
18 'I don't understand the question," I'll ask it again --
19 A. Okay.
20 Q. -- all right?
21 And I'm assuming that's the address,
22 where you began living in !Pk
23
24 A. Correct.
25 Q. How long did you live al that address?
0016
1 A. I'm sorry, I don't understand our uestion.
2 Q. How long did you live al the
3 address that you moved into in the fall in 2002?
4 A. Well, since -- since I came I lived there, I
5 always stayed there whether being in Miami traveling
6 back and forth, and I live currently at this address.
7 Q. Okay. What was the first lime that you moved
8 from that address to live elsewhere?
9 A. I do not recall.
IC Q. Okay. I know that you told me you lived in
11 New York City and we're not going to discuss -- I'm
12 assuming you're not going to answer a lot of questions
13 about New York City, but at what time period did you




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 14 move there? Was it right after you got here two weeks,
15 a year later? I'm just trying to get a year as to when
16 you moved Lo New York?
17 MR. ROSS: I'm going Lo instruct you not to
18 answer.
19 A. I refuse to answer.
20 Q. Okay. Do you know a guy by the name of Jean
21 Luc Brunel?
22 A. I refuse to answer.
23 Q. Where are your parents?
24 A. They're in
25 Q. And since you ve been n t e United States
C017
1 have they come to the United Stales?
2 A. Yes, they have visited me.
3 Q. Have they ever met Jeffrey Epstein?
4 A. I refuse to answer.
5 Q. Have they ever met Jean Luc Brunel?
6 A. I refuse to answer.
7 Q. Where are you currently employed?
8 A. I pursue -- I go to school full-time, I do not
9 work.
10 Q. Are you also still in the modeling business
11 though?
12 A. No, I'm not.
13 Q. And when was the last. Lime you did any
14 modeling?
15
16
17 Q. And why did you stop modeling at that. tire?
18 A. I wanted -- I always kind of knew that it's
19 something Lhat I'm going to be doing and I just decided
20 to go and pursue a college degree.
21 Q. Okay. Is it something that you ever plan to
22 go back to, modeling?
23 A. No.
24 Q. Are you involved at all with the modeling
25 industry?
C018
1 A. No.
2 Q. I mean, helping to recruit models, helping
3 others to recruit models, anything like that?
4 A. No.
5 Q. Do you ever -- do you currently talk Co
6 Er. Brunel?
7 A. I refuse to answer.
8 Q. When is the last time that you talked to
9 Jeffrey Epstein?
IC A. I refuse to answer.
11 Q. Do you know a woman by the name of Ghislaine
12 Maxwell?
13 A. I refuse to answer.
14 Q. Do you know someone by the name of
15




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 16 A. I refuse to answer.
17 Q. Do you know a person named
18 A. I refuse to answer.
19 Q. Did Jeffrey Epstein have anything Lo do with
20 you moving to New York City?
21 A. I refuse to answer.
22 Q. Did you ever live in a place in New York City
23 owned or controlled by Jeffrey Epstein?
24 A. I refuse to answer.
25 Q. Are you familiar with the modeling agency MC
0019
1 Squared?
2 A. I refuse to answer.
3 Q. Do you know of underage females being
4 transported into this country to work for the modeling
5 agency MC Squared?
6 A. I refuse to answer.
7 Q. Do you know of those underage females being
8 given work visas and staying at the 301 East 66th
9 Street address?
10 A. I refuse to answer.
11 Q. Can you say whether you have observed
12 Mr. Brunel or Mr. Epstein engaging in sex with underage
13 females?
14 A. I refuse to answer.
15 Q. Do you know where Mr. Brunel lives?
16 A. I refuse to answer.
17 Q. Is it true that. Mr. Brunel slays in the 301
18 East. 66th address frequently with underage females?
19 A. I refuse to answer.
20 Q. AL what point were you hired to work for
21 Mr. Epstein?
22 Nil. PIKE: Form.
23 MR. EDWARDS: You can still answer the
24 question. Mr. Pike is making a legal objection.
25 A. I refuse to answer.
0020
1 Q. And how did -- how did it come about that you
2 began working with Jeffrey Epstein?
3 MR. PIKE: Form.
4 A. I refuse Lo answer.
Q. What did Jeffrey Epstein pay you in salary?
6 MR. PIKE: Form.
7 A. I refuse to answer.
8 Q. What was the time period that. you worked for
9 him?
10 A. I refuse to answer.
11 Q. Why did you stop working for him?
12 MR. PIKE: Form.
13 A. I refuse to answer.
14 Q. What initially were you hired to do?
15 A. I refuse to answer.
16 MR. PIKE: Form.
17 Q. Has Jeffrey Epstein ever paid you to stay




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 18 quiet or keep quiet about what went on in his house?
19 MR. PIKE: Form.
20 A. I refuse 10 answer.
21 Q. Have you talked to
22 about the things that went on in Jeffrey
23 Epstein s ouse?
24 MR. PIKE: Form.
25 A. I refuse to answer.
0C21
1 Q. Did you sign a confidentiality agreement with
2 Jeffrey Epstein?
3 A. I refuse to answer.
4 MR. PIKE: Form.
5 Q. Did that confidentiality agreement outline
6 what you should say to authorities should he be caught
7 with underage females?
8 MR. PIKE: Form.
A. I refuse to answer.
l0 Q. Is there another book or manual or written
11 memorialization of what you, as an employee of Jeffrey
12 Epstein, should do if confronted by law enforcement?
13 MR. PIKE: Form.
14 A. I refuse to answer.
15 Q. Are you invoking your Fifth Amendment right
16 because you believe you could be prosecuted?
17 MR. ROSS: Invoke.
18 A. I refuse to answer.
19 Q. Are you also invoking because you're scared to
20 testify against Jeffrey Epstein?
21 MR. PIKE: Form.
22 A. I refuse to answer.
23 Q. When did you first learn that Jeffrey Epstein
24 had a sexual obsession for underage females?
25 A. I refuse to answer.
0022
V.A. PIKE: Form.
2 Q. Isn't it true that you have seen Jeffrey
3 Epstein sexually interacting with females as young as
4 12 years old?
5 A. I refuse to answer.
6 MR. PIKE: Form.
7 Q. Is it true that you have observed Jeffrey
8 Epstein's sexual obsession to include the age range 12
9 to 17?
IC MR. PIKE: Form.
11 A. I refuse to answer.
12 Q. Have you ever had sex with Jeffrey Epstein?
13 A. I refuse to answer.
14 MR. PIKE: Form.
15 Q. Have you ever been paid for sex with Jeffrey
16 Epstein?
17 MR. PIKE: Form.
18 A. I refuse to answer.
19 Q. Do you know if had sex with




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 20 Jeffrey Epstein when she was underage?
21 MR. PIKE: Form.
22 A. I refuse to answer.
23 Q. What have you been told about Jeffrey
24 Epstein's sexual obsession with underage minor
25 children?
0023
1 MR. PIKE: Form.
2 A. I refuse to answer.
3 Q. Isn't it true that Jeffrey Epstein interacted
4 sexually with underage minors on an everyday basis?
5 MR. PIKE: Form.
6 A. I refuse to answer.
7 Q. And most of the time Mr. Epstein would
8 interact with underage minors at least two times a day;
9 is that true?
10 MR. PIKE: Form.
11 A. I refuse to answer.
12 Q. Can you explain to the jury how Mr. Epstein
13 would access new underage minor females for sex every
14 day?
15 MR. PIKE: Form.
16 A. I refuse to answer.
17 Q. How many assistants did Jeffrey Epstein hire
18 to bring him underage minor females for sex?
19 A. I refuse to answer.
2C M.R. PIKE: Form.
21 Q. Were you one of those assistants that helped
22 to bring him underage minor females?
23 MR. PIKE: Form.
24 A. I refuse to answer.
25 Q. I know that_ the laws in are probably
0024
1 different than they are here, but are you familiar with
2 the Florida Statutes that protect children against
3 sexual offenders or sexual predators?
4 MR. ROSS: Invoke.
5 A. I refuse to answer.
6 Q. Let me just read you the lewd or lascivious
7 molestation statute and then I'm going to ask you some
8 questions about iL.
9 IL says: 'A person who intentionally touches
IC in a lewd or lascivious manner the breasts, genitals,
11 genital area or buttocks or the clothing covering them
12 of a person less than 16 years of age or forces or
13 entices a person under 16 years of age to so touch the
14 perpetrator, commits lewd or lascivious molestation, a
15 second degree felony.'
16 After hearing that statute isn't that
17 something -- isn't that a crime that you know
18 Mr. Epstein to have committed on an everyday basis
19 while you were working for him?
2C MR. PIKE: Form.
21 A. I refuse to answer.




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 22 Q. And that's a statute that he violated with
23 more than 1CC underage females; is that true?
24 MR. PIKE: Form.
25 A. I refuse to answer.
0025
1 Q. When did you become aware that. Mr. Epstein was
2 a child molester?
3 MR. PIKE: Form.
4 A. I refuse to answer.
5 Q. Have you ever seen him with a female under the
6 age of 12?
7 MR. PIKE: Form.
8 A. I refuse to answer.
9 Q. Have you ever known Jeffrey Epstein to have
10 sex with an adult?
11 MR. PIKE: Form.
12 A. I refuse to answer.
13 Q. Does he -- is he sexually attracted to adults?
14 MR. PIKE: Form.
15 A. I refuse to answer.
16 Q. When was the first time you learned of
17 Mr. Epstein getting a massage from an underage minor
18 female?
19 MR. PIKE: Form.
20 A. I refuse to answer.
21 Q. I realize some of these questions may sound
22 repetitive but during this case we've learned of key
23 terms that different people on Mr. Epstein's let's say
24 payroll or inner circle recognize or talk about. So
25 when I talk about •massages', do you know what. that
0026
1 term means?
2 MR. PIKE: Form.
3 A. I refuse to answer.
4 Q. Isn't "massage• the word that was told by
5 Jeffrey Epstein to all of his employees to refer to
6 whatever acts he engages in with underage females in
7 his bedroom?
8 MR. PIKE: Form.
9 A. I refuse to answer.
10 Q. AL this point -- were you -- were you ever in
11 the bedroom with him when he was engaging in sexual
12 acts with underage females and calling them "massages"?
13 MR. PIKE: Form.
14 A. I refuse to answer.
15 Q. Did you ever participate in any of the sexual
16 acts that Jeffrey Epstein was having with underage
17 females?
18 MR. PIKE: Form.
19 A. I refuse to answer.
20 Q. Now, just so that the record is clear there is
21 not a single piece of evidence that ever indicates that
22 you were involved with underage females, I'm not even
23 implying that and I realize that you invoking it may --




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 24 may give the wrong light and that's not -- that's not
25 my intention, so -- but were you ever aware of
0027
1 participating in sex with underage females?
2 A. I refuse to answer.
3 Q. Have you read the police reports related to
4 the criminal investigation into Mr. Epstein?
5 A. I refuse to answer.
6 Q. And you're aware of this 87-page police report
7 that details numerous females that indicate that they
8 were involved sexually with Mr. Epstein when they were
9 minors?
10 A. I refuse to answer.
11 N.R. PIKE: Form.
12 Q. Did anyone instruct you to use the code word
13 *massage"?
14 A. I refuse Lo answer.
15 Q. And when referring to these underage minor
16 females that would come over to Mr. Epstein's house did
17 anybody also tell you to use the term 'work•?
18 A. I refuse to answer.
19 MR. PIKE: Form.
20 Q. Meaning when somebody would call to schedule
21 one of these underage females for a massage isn't it
22 true that they would say "It's time to come to work"
23 and schedule a specific appointment?
24 MR. PIKE: Form.
25 A. I refuse to answer.
0028
1 Q. Is there a book or manual or is it written
2 anywhere that the -- that sex with underage minors is
3 to be referred to as a "massage"?
4 A. I refuse to answer.
5 MR. PIKE: Form.
6 Q. Were there ever team meetings, for lack of a
7 better word, where Jeffrey Epstein and possibly
8 Ghislaine Maxwell, yourself, would talk
9 about this organization of obtaining underage girls for
IC Jeffrey Epstein for sex?
11 MR. PIKE: Form.
12 A. I refuse Lo answer.
13 Q. What methods does Jeffrey Epstein use to gain
14 access to underage minor females for sex?
15 MR. PIKE: Form.
16 A. I refuse to answer.
17 Q. What is your understanding of Jeffrey
18 Epstein's involvement with the modeling industry?
19 MR. PIKE: Form.
20 A. I refuse to answer.
21 Q. Have you ever modeled for MC Squared?
22 MR. PIKE: Form.
23 A. I refuse Lo answer.
24 Q. Has Jeffrey Epstein ever promised you anything
25 related to a modeling career?




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 0029
1 MR. PIKE: Form.
2 A. I refuse to answer.
3 Q. Have you ever talked to Jean Luc Brunel about
4 modeling?
5 A. I refuse to answer.
6 Q. Rave you ever talked to Jean Luc Brunel about
7 his desire to have sex with underage females?
8 A. I refuse to answer.
9 Q. Isn't it true that Jean Luc Brunel has been in
10 trouble for years for having sex with underage minors
11 in Europe?
12 A. I refuse to answer.
13 Q. Are you familiar with The McIntyre Reports?
14 A. I refuse to answer.
15 Q. Okay. Are you familiar with reports done on
16 modeling agencies back in the 80's and 90's related to
17 agency owners having sex with underage minors?
18 MR. ROSS: Answer the question.
19 A. No, I'm not.
20 Q. Okay. Did you ever hear of Jean Luc Brunel's
21 reputation for having sex with underage girls?
22 MR. ROSS: Invoke.
23 A. I refuse to answer.
24 Q. Do you know how Jean Luc Brunel knows Jeffrey
25 Epstein?
0030
1 A. I refuse to answer.
2 MR. PIKE: Form.
3 Q. Isn't their connection the obsession for
4 underage minor females?
5 MR. PIKE: Form.
6 A. I refuse to answer.
7 Q. Based on your observations of Jeffrey Epstein
8 would you categorize his obsession for underage minor
9 females as an addiction?
10 MR. PIKE: Form.
11 A. I refuse to answer.
12 Q. Isn't it true that Ghislaine Maxwell delivers
13 underage minor females to Jeffrey Epstein?
14 MR. PIKE: Form.
15 A. I refuse to answer.
16 Q. Have you ever had a sexual relationship with
17 Ghislaine Maxwell?
18 A. I refuse to answer.
19 Q. Do you know what Ghislaine Maxwell does in
20 general for Jeffrey Epstein?
21 MR. PIKE: Form.
22 A. I refuse to answer.
23 Q. Have you seen photographs of underage minor
24 females in Jeffrey Epstein's patrol -- control or
25 possession?
0031
1 MR. PIKE: Form.




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 2 A. I refuse to answer.
3 Q. Were there surveillance cameras, hidden
4 surveillance cameras inside Jeffrey Epstein's home?
5 MR. PIKE: Form.
6 A. I refuse to answer.
7 Q. Did those surveillance cameras capture
8 underage minor females naked?
9 MR. PIKE: Form.
10 A. I refuse to answer.
11 Q. And didn't Jeffrey Epstein and Ghislaine
12 Maxwell watch those surreptitiously obtained videos of
13 underage minor females?
14 MR. PIKE: Form.
15 A. I refuse to answer.
16 Q. And those videos and photographs of underage
17 minor females were saved on Jeffrey Epstein's computers
18 in his house, right?
19 MR. PIKE: Form.
20 A. I refuse to answer.
21 Q. Have you seen those photographs and videos on
22 Jeffrey Epstein's computers?
23 MR. PIKE: Form.
24 A. I refuse to answer.
25 Q. Who have you talked to related to the criminal
0032
1 investigation into Jeffrey Epstein?
2 A. I refuse to answer.
3 MR. PIKE: Form.
4 MR. ROSS: In addition, attorney-client
5 privilege.
6 Q. And I certainly would do not want to know
7 anything you talked to your attorney about, I
8 apologize.
9 A. (Nods.)
10 Q. Why was it that you were named as a
11 co-conspirator of Jeffrey Epstein's in the
12 non-prosecution agreement?
13 MR. PIKE: Form.
14 A. I refuse to answer.
15 Q. Do you feel like a victim of Jeffrey
16 Epstein's?
17 MR. PIKE: Form.
18 A. I refuse to answer.
19 Q. Do you feel like Jeffrey Epstein brainwashed
20 you to some extent?
21 MR. PIKE: Form.
22 A. I refuse to answer.
23 Q. Do you feel any remorse for any role that. you
24 may have played in having underage minor females at
25 Jeffrey Epstein's house for him to molest them?
0033
1 MR. PIKE: Form.
2 A. I refuse to answer.
3 Q. Have you known Ghislaine Maxwell and Jeffrey




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 4 Epstein to keep sex slaves?
5 A. I refuse to answer.
6 Q. Do you know somebody named
7 A. I refuse to answer.
8 Q. Have you met
9 A. I refuse to answer.
10 MR. EDWARDS: All right. Let me go ahead and
11 mark as -- as Plaintiff's Exhibit. 1 a lawsuit that
12 was filed by Bob Josefsberg on behalf of Jane Doe
13 102 v. Jeffrey Epstein just for the purposes of
14 asking the witness some questions.
15 MR. ROSS: I've seen it.
16 (Whereupon, Plaintiff's Exhibit 1 was marked
17 for identification.)
18 Q. Have you ever read the lawsuit Jane Doe 102 v.
19 Jeffrey Epstein?
20 A. I refuse to answer.
21 Q. In the lawsuit it indicates the plaintiff was
22 15 years old when Ghislaine Maxwell and Jeffrey Epstein
23 had a threesome with this underage minor female. Are
24 you aware of that?
25 MR. PIKE: Form.
0034
1 A. I refuse to answer.
2 Q. And Jeffrey Epstein and/or Ghislaine Maxwell
3 obtained and purchased passports for 15-year-old Jane
4 Doe 102 to transport her to Palm Beach, New York City,
5 Santa Fe, Los Angeles, San Francisco, St. Louis, as
6 well as Europe, the Caribbean, and Africa; are you
7 aware of that?
8 A. I refuse to answer.
9 MR. PIKE: Form.
10 Q. It's also alleged that. Jeffrey Epstein in
11 addition to molesting Jane Doe 102 along with Ghislaine
12 Maxwell forced her to have sex with other models,
13 actresses, and celebrities?
14 A. I refuse to answer.
15 MR. PIKE: Form.
16 Q. It also indicates that Jeffrey Epstein
17 transported other minor girls from Turkey, the Czech
18 Republic, Asia, and other countries. Are you aware of
19 that?
20 MR. PIKE: Form.
21 A. I refuse to answer.
22 Q. Is Jeffrey Epstein involved in the
23 international child sex trade?
24 MR. PIKE: Form.
25 A. I refuse to answer.
0035
1 Q. Is Jean Luc Brunel his partner in that
2 international child sex trade?
3 MR. PIKE: Form.
4 A. I refuse to answer.
5 Q. Are you aware that after -- that Jeffrey




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 6 Epstein forced Jane Doe 102 to have sex with ocher
7 adult male peers including royalty, politicians,
8 academicians, businessmen and/or other professional and
9 personal acquaintances of Jeffrey Epstein's?
IC MR. PIKE: Form.
11 A. I refuse to answer.
12 Q. Is that something that he did with girls other
13 than Jane Doe 102?
14 MR. PIKE: Form.
15 A. I refuse to answer.
16 Q. Aren't you familiar with Jeffrey Epstein's
17 practice of pimping out, underage minor females to other
18 people that have the same sexual obsession with
19 underage minors?
20 MR. PIKE: Form.
21 A. I refuse to answer.
22 Q. And doesn't he benefit financially from that
23 sex trade?
24 MR. PIKE: Form.
25 A. I refuse to answer.
0036
1 Q. Jane Doe 102 ultimately escaped from him and
2 left to Australia, is that your understanding?
3 A. I refuse to answer.
4 MR. PIKE: Form.
5 Q. Have you ever spoken with Jane Doe 102?
6 A. I refuse to answer.
7 Q. On one of Epstein's birthdays a friend of
8 Jeffrey Epstein sent Co him. 12 -- three 12-year-old
9 girls from France who spoke no English for Epstein to
10 sexually exploit and abuse and after doing so he sent
11 them back Lo France the next day. Are you familiar
12 with that?
13 MR. PIKE: Form.
14 A. I refuse to answer.
15 Q. Isn't that something that is fairly common for
16 Mr. Epstein?
17 A. I refuse to answer.
18 MR. PIKE: Form.
19 Q. Who are Lhe friends that send to Jeffrey
20 Epstein underage minor females for his birthday so that.
21 he can abuse?
22 A. I refuse to answer.
23 MR. PIKE: Form.
24 Q. Is one of those friends Jean Luc Brunel?
25 A. I refuse to answer.
0037
1 Q. Have you ever Mel Prince Andrew?
2 A. I refuse to answer.
3 Q. Has Prince Andrew been involved with underage
4 minor females to your knowledge?
5 A. I refuse to answer.
6 Q. Have you ever met Alan Dershowitz?
7 A. I refuse to answer.




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 8 Q. When Alan Dershowitz stays al Jeffrey
9 Epstein's house isn't it true that he has been at the
IC house when underage minor females have been in the
11 bedroom with Jeffrey Epstein?
12 A. I refuse to answer.
13 Q. Has -- are you familiar with the media
14 publication or online resource RadarOnline?
15 A. I refuse to answer.
16 Q. Is that. something that. you assisted
17 Mr. Epstein with when he purchased RadarOnline?
18 A. I refuse to answer.
19 Q. And do you know his business partner in that.
2C endeavor?
21 A. I refuse to answer.
22 Q. Isn't it also true that he used RadarOnline as
23 another way to gain access to underage minor females
24 for sex?
25 MR. PIKE: Form.
0038
1 A. I refuse to answer.
2 Q. Have you been to all of Jeffrey Epslein's
3 properties?
4 MR. PIKE: Form.
5 A. I refuse to answer.
6 Q. Certainly you've been to the properly at 358
7 El Brillo Way, correct?
8 MR. PIKE: Form.
9 A. I refuse to answer.
10 Q. Have you been to his property in Manhattan?
11 A. I refuse to answer.
12 MR. PIKE: Form.
13 Q. And have you been to his island in -- it was
14 Little St. James, I believe he calls it