EFTA01076251.pdf
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1
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO. 50-2008-CA-028051 XXXX MB AB
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
/
VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN
TAKEN ON BEHALF OF THE PLAINTIFF
DATE: February 17, 2010
U.S. Legal Support
EFTA01076251
1 February 17, 2010 1 THEREUPON,
2 INDEX 2 JEFFREY EPSTEIN
3 WITNESS DIRECTCROSS REDIRECT RECROSS
4 JEFFREY EPSTEIN 3 being by Toni Becker first duly sworn to tell
5 BY MR. EDWARDS 4 4 the whole truth, as hereinafter certified.
6 testified as follows:
EXHIBITS
7 FOR IDENTIFICA PAGE 6 DIRECT EXAMINATION
8 I Jane Doe numb usJeffrey 7 BY MR. EDWARDS:
Epstein complain 35
9 8 Q Can you give us your name.
2 Document, Nonprosecution Agreement 135 9 A Jeffrey Epstein.
10 10 Q Mr. Epstein, you made a comment when you
11
CER1iFILO QUESTIONS 11 came in the room that you were appreciative of me
12 12 being respectful to your housekeeper yesterday
Page Line 13 and I intend for that to be the same with you
13
61 22 14 today.
14 123 20 15 1 want to start by asking you, at this
146 l4 16 point we've gone through a lot of discovery in
15 148
153 5 17 this ease. There aren't may disputed facts as
16 159 13 18 to what actually happened at your house.
162 3
17 19 Generally I think you would agree that you
18 20 derived a way for young females to come to your
19 21 house and engage In varying degrees of sexual
20
21 22 activity, some of the girls as young as 12, some
22 23 of them as old as seventeen or so, most in
23 24 between, but as of yet you haven't provided an
24
25 25 explanation.
3
1 The videotaped deposition of JEFFREY 1 1 want to provide you an opportunity to
2 EPSTEIN in the above-entitled and numbered cause, 2 tell the jury at this time why you did ft.
3 was taken before me, TERRI BECKER, a Registered
4 Professional Reporter and Notary Public for the 3 MR. PIKE: I'm going to object
5 State of Florida at Liege, at 444 West Railroad 4 Confusing, compound and irrelevant, as
6 Avenue, in the City of West Palm Beach, Palm worded.
7 Beach County, in the State ofFlorida, beginning
8 at the hour of 5 eiclock a.m, pursuant to 6 A You know, I would like to answer that
9 the Notice in said cause for the taking of said 7 question, frankly. However, at this time, my
10 deposition which is annexed to the court file 8 attorneys have told me that I can't and 1 must
11 herein, on behalf of the PLAINTIFF in the
12 above-entitled action pending in the above-named 9 invoke my Fifth, Sixth and Fourteenth Amendment
13 court 10 rights or I risk losing their counsel.
14 The appearances at said time and place 11 Accordingly, I therefore assert those rights.
15 were as follows:
16 12 Sorry.
FARMER, JAFFE, WEISSING,
EDWARDS, F1STOS & LEHRMAN, P.L. 13 MR. PIKE: In addition to that I'll move
17 Attorneys for Plaintiff 14 to strike counsel's statement as a
425 North Andrews Avenue, Suite 2 15 narrative, as well.
18 Fort 33301
Tel: 16 MR. EDWARDS: I understand. I wanted to
19 BY: BRAD . WARDS 17 provide him an opportunity, if today was
STEVEN R. JAFFE, ESQ. 18 going to be the day.
20
BURMAN, CRITTON, LUTTIER & COLEMAN 19 MR. PIKE: Same thing, move to strike.
21 Attorneys for Defendant 20 Q Mr. Epstein, how long have you been
303 Banyan Boulevard, Suite 400 21 sexually attractive to underage minor females?
22 Wes orida 33401
Tel: 22 MR. PIKE: Objection, harassing,
23 BY: MICHAEL PIKE, ESQ. 23 argumentative.
24 ALSO PRESENT: 24 A Are you kidding?
JOE ROVNER, Videographer
25 (U.S Legal Support) 25 Q No, l mean, I don't feel Eke I'm
2 (Pages 2 to
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1 divulging any secrets here, right? 1 argumentative, compound, harassing and
2 MR. PIKE: Move to strike. 2 irrelevant.
3 Q That's the question that's pending. 3 Q You can answer.
4 A I would like to answer that question as 4 A I would like to answer, however, I'm
5 well, as all your other questions today, however, 5 going to have to assert my Fifth Amendment, Sixth
6 I have to follow my attorneys' advice. They have 6 Amendment, Fourteenth Amendment right as advised
7 told me I must invoke my Fifth, Sixth and 7 by my counsel, otherwise I risk losing their
8 Fourteenth Amendment right to not answer those 8 advice.
9 questions today, or any questions relevant to 9 Q Mr. Epstein, have you ever been
10 this lawsuit, so accordingly, I'm going to assert 10 diagnosed with a sex addiction to minors by a
11 those rights and under the constitution 11 psychologist or other medical professional?
12 guaranteed by the Fifth and Sixth, and Fourteenth 12 A I intend to respond to all of your
13 amendment. 13 questions at some relevant time; however, today
14 Q Would you consider yourself addicted to 14 at the present time, my attorneys have counseled
15 sex with minor females? 15 me that I cannot provide answers to any questions
16 MR. PIKE: Same objections. 16 relevant to this lawsuit and I must accept their
17 A You know, Mr. Edwards, again, I want to 17 advice or risk losing my Sixth Amendment rights
18 be very respectful. As the current U.S. Attorney 18 to effective representation.
19 has described your law firm as a criminal 19 Accordingly, I assert my Fifth,
20 enterprise and part of one of the largest frauds 20 Federal — Fifth and Sixth and Fourteenth
21 in Florida's history, it has been reported that 21 Amendment rights, to the United States
22 your firm has fabricated multiple cases against 22 Constitution.
23 me in order to fleece unsuspecting investors out 23 MR. PIKE: In addition to that, Mr.
24 of millions and millions of dollars, so 24 Edwards, as the Court has ruled on several
25 unfortunately at this time, although I would Ida 25 matters, Mr. Epstein's medical history is
7 9
1 to answer that question, on advice of counsel I 1 not relevant at this time nor has he placed
2 will have to refrain and assert my Fifth, Sixth 2 same at issue in this case.
3 and Fourteenth Amendment right. 3 MR. EDWARDS: Understood.
4 Q Can you then provide an explanation for 4 Q Mr. Epstein, were you sexually abused as
5 what relevance that soliloquy of yours has to, 5 a minor?
6 whether or not you engaged in sex acts with- 6 A Again?
7 When she was a minor? 7 Q Were you sexually abused, as a minor?
8 MR PIKE: Objection, no, he cannot 8 A You know, again, I would like to respond
9 Argumentative. Compound, harassing. 9 to all -- if any questions seem to be relevant.
10 MR. EDWARDS: Mr. Pike, with all due 10 I would like to respond to any relevant question
11 respect, it was not my idea for him to give 11 at this time; however, my attorneys have
12 this speech about a former ARA law firm I 12 counseled me that I cannot provide answers to the
13 was asking to elaborate on that. 13 questions relevant to this lawsuit today. I must
14 MR. PIKE: Counsel, I'm working with 14 accept their advice or risk losing my Sixth
15 your follow-up question. 15 Amendment right to effective representation.
16 MR. EDWARDS: I understand. 16 Accordingly then, I assert my Fifth, Sixth and
17 MR. PIKE: I'm objecting, object to the 17 Fourteenth Amendment right to the United States
18 form and stating the reasons on the record 18 Constitution.
19 why the form is required to be objected to, 19 Q Isn't it true that you have engaged in
20 based upon your question. 20 some sexual interaction with hundreds of underage
21 MR. EDWARDS: Will he elaborate on the 21 minor females In die last ten years of your
22 relevance of that soliloquy to his touching 22 life? Is that true?
23 -when she was 13, 14 and 15 years old in 23 MR. PIKE: Objection, relevance.
24 a sexual manna? 24 A Mr. Edwards, the current U.S. Attorney
25 MR. PIKE: I'm going to object again, 25 has described your law firm as a criminal
3 (Pages 6 to 9)
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1 enterprise and pan of the largest fraud in 1 50 years old?
2 Florida's history. It has been reported that 2 MR. PIKE: I'm going to object once
3 your firm fabricated multiple cases, many, many 3 again. We are getting way too argumentative
4 multiple cases against me in order to fleece 4 with the questioning. The questioning is
5 unsuspecting investors out ofmillions and 5 compound It is speculative and it is also
6 millions of dollars. Unfortunately, at this time 6 harassing. Whether or not this deposition
7 in response to your question, my attorneys have 7 video, thereofis played in front of a jury
8 advised me that I must assert my Sixth Amendment, 8 is a question of fact, and it will be
9 Fifth Amendment, Fourteenth Amendment right. 9 determined by a judge pursuant to a motion
10 Though, I believe, you know, that I would really 10 in limine, various portions thereof may or
11 like to answer your questions today, but at this 11 may not be played, so hiving placed those
12 moment i must assert those rights or risk having 12 objections on the record I'm going to
13 my attorneys resign. 13 insttuct Mr. Epstein not to answer that
14 Q You're Invoking your Fifth Amendment 14 question.
15 rights to each of these questions because you 15 MR. EDWARDS: Mr. Pftce, I don't know if
16 know your answers will incriminate you and you 16 you watehegainia hours of harassing
17 feel it will result in you being prosecuted for 17 questions tri=that she sometimes
18 your crimes; Isn't that right? 18 invoked her Fifth Amendment rights, I
19 MR. PIKE: Objection, argumentative, 19 understand the adverse advice that would be
20 harassing. Calls fora legal conclusion. 20 given and she was made to answer these
21 Q You can answer. 21 questions and these exact same questions
22 A No, in fact, the Supreme Court recently 22 were asked ofher, in fact, I'm using the
23 said the Fifth Amendment right is there to 23 phraseology from Mr. Luttier. I'm not
24 protect the innocent, so, that's the way I would 24 trying to harass him.
25 like to answer that. 25 Q I'm simply asking him to explain to the
11 13
1 Q Are you actually telling the Jury that 1 jury. If you're saying it didn't happen, if
2 you didn't commit the crimes that have been 2 you're saying it did happen, explain to the jury
3 alleged against you by the various females that 3 why you did it. That's all I want to hear. I'm
4 were under age when you engaged in sex with 4 being respectful about this.
5 them? Are you telling the jury that right now? 5 MR. PIKE: In an effort to keep a clean
6 MR. PIKE: Objection, argumentative, 6 record be respectful to the to the court
7 harassing. 7 reporter rather than having a diatribe back
8 A I would like to respond to that 8 and forth between you and myself, I'll move
9 question, as you know, however, at the present 9 to strike your last statement as
10 time my attorneys have counseled me that I cannot 10 irrelevant. Let's move on.
11 provide answers to any questions relevant to this 11 Q Is it true, Mr. Epstein, you were born
12 lawsuit and i must accept their advice or risk 12 January 20,1953?
13 losing my Sixth Amendment right to effective 13 A Yes.
14 representation. Accordingly, I assert my Fifth, 14 Q Where?
15 Sixth and Fourteenth Amendment right under the 15 A New York.
16 United States Constitution. 16 Q Where in New York?
17 Q Mr. Epstein, you understand that this is 17 A Brooklyn.
19 aeo that will be playe ie Jury in 18 Q Did you go to high school there?
19 trial against you 1m wants answers. 19 A Yes, sir.
20 The jury is going to want answers, so I know that 20 Q Where?
21 you're telling us that you're going to respond at 21 A Lafayette High School.
22 some time In the future; but the time is now. 22 Q After high school did you attend
23 Would you like this opportunity to explain why 23 college?
24 you engaged In sexual activity with.. 24 A Yes.
25 beginning when she was 13 years old and you were 25 Q Where was that?
4 (Pages 10 to 13)
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1 A New York. 1 I'll restate the answer. I would like to
2 Q What college did you attend? 2 respond, intend to respond, and would like to
3 A Cooper Union. 3 respond to all questions today. However, counsel
4 Q Sorry, i didn't hear. 4 has advised me I must take the Fifth, Sixth and
5 A Cooper Union. 5 Fourteenth Amendment right under the U.S.
6 Q Did you get a degree from Cooper Union? 6 Constitution.
7 A No, sir. 7 Q After college where were you employed?
8 Q How many years were you in college? 8 A You Imow, I would like to respond to all
9 A I believe, two. 9 your questions today, however, on advice of
10 Q What did you study? 10 counsel, I intend to take the Fifth, Sixth and
11 A Physics. 11 Fourteenth Amendment rights provided by the
12 Q Why did you leave college early? 12 United States Constitution or risk losing my
13 A I intend to respond to all relevant 13 counsel's representation.
14 questions regarding this lawsuit, however, at the 14 Q Isn't it true that you were a teacher at
15 present time my attorneys have counseled me that 15 the Dalton School in New York after college?
16 I cannot provide answers to questions that may be 16 A Again, I would like to respond to all
17 relevant to this lawsuit, so accordingly I assert 17 your questions; however, my attorneys have
18 my constitutional rights as guaranteed by the 18 counseled me that i cannot provide answers to any
19 Fifth, Sixth and Fourteenth Amendment. 19 questions today regarding to this lawsuit so I
20 Q Are you invoking your Fifth Amendment 20 must accept their advice or risk losing my Sixth
21 rights as to why you left college, Is it safe 21 Amendment right to effective representation.
22 then to presume that that answer you believe 22 Accordingly, I assert my Constitutional rights as
23 would incriminate you in some way? 23 guaranteed by the Fifth, Sixth and Fourteenth
24 MR. PIKE: I'm going to move to strike, 24 Amendment of the constitution.
25 speculative, argumentative, harassing. 25 Q Mr. Eistein, didrit have sex with any
15 17
Calls for a legal conclusion, and 1know 1 underage students while teaching at the Dalton
2 exactly what you're trying to do here, Mr. 2 School?
3 Edwards, is lace the record with questions 3 A Could you repeat that?
4 that would ultimately give you an adverse 4 Q Yes. Did you have sex with any underage
5 inference at any potential trial of this 5 students while teaching at the Dalton School in
6 matter, so having put that on the record, 6 New York?
7 I'm going to instruct him not to answer that 7 A Mr. Edwards, your firm has been
8 question, based upon his Fifth, Sixth and 8 described by the U.S. Attorney as one of the
9 Fourteenth Amendment rights to the United 9 largest — as a criminal enterprise, perpetrating
10 States Constitution. 10 one of the largest frauds in Florida's history.
13. MR. EDWARDS: With all due respect you 11 It has been reported that your firm fabricated
12 cannot invoke his Fifth Amendment rights, 12 multiple cases against me and others in order to
13 your attorneys instructed me in that fact -- 13 fleece unsuspecting investors out of millions and
14 MR. PIKE: lie can. 14 millions of dollars.
15 MR. EDWARDS: 11M. Had to do it 15 Unfortunately at this time in response
16 herself, so, I would like to hear it from 16 to your question, my attorneys have advised me I
17 Mr. Epstein. 17 must assert my Fifth Amendment, Sixth Amendment
18 Q Can we assume you're Invoking your Fifth 18 and Fourteenth Amendment rights, though I believe
19 Amendment rights as to why you left college 19 you know I would like -- really like to answer
20 early, that that answer you feel would 20 your questions but at this time I must assert
21 incriminate you? 21 those rights or have my attorneys resign.
22 MR. PIKE: Once again, move to strike 22 MR. EDWARDS: Mr. Pike, I think you know
23 for the same reasons. 23 he has a couple of options here. He can
24 You can answer. 24 answer questions or he can invoke his Fifth
25 A I've already answered the question. 25 Amendment rights. This nonresponsive
5 (Pages 14 to 17)
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1 verbiage regarding the RBA law firm is not 1 MR. PIKE Mr. Edwards, as you know
2 one of the options, it's inappropriate in 2 there are serious Fifth, Sixth and
3 the deposition and I would ask you to 3 Fourteenth Amendment constitutional rights
4 instruct your client not to obstruct this 4 at issue here, and the witness is attempting
5 process any further. I am not going to 5 to answer your questions to the best of his
6 terminate the deposition. I want it to 6 ability, despite how laced they are with
7 finish, but obviously this is going to be 7 adverse inference presumptions.
8 the subject matter of some motion in the 8 MR. EDWARDS: I don't want the adverse
9 °Duns and you know the judges will not 9 inferences. I want the answers, that's it.
10 appreciate this. I would like to just move 10 I don't want the adverse inferences.
11 this process along by eliminating that 11 MR. PIKE: Having said that, please
12 portion ofhis answer. I understand what he 12 allow the witness to answer to answer the
13 is saying. 'get it, but that's not 13 question.
14 something responsive to any of the questions 14 A Can you please repeat the question?
15 and I think you know it is inappropriate. 15 Q Isn't it true while working at Bear
16 MR. PIKE: I think the deponent is 16 Stearns you were already engaging in sex with
17 answering the questions. If you believe the 17 underage minor females?
18 responses are inappropriate and feel you can 18 A As your firm has been described by the
19 take it up with the Court with the motion 19 U.S. Attorney, as a criminal enterprise, using
20 you are speaking of, as you've done then you 20 some of the cases fabricated against me,
21 can, as you've done several times before. 21 personally, I would like to answer that question
22 Q After leaving the Dalton School. is it 22 today; however, upon advice of counsel I must
23 true that you began working as a money manager at 23 assert my Fifth, Sixth and Fourteenth Amendment
24 Bear Stearns? 24 rights under the U.S. Constitution or, in fact,
25 A I intend to respond to all your 25 risk losing their representation.
19 21
1 questions regarding this lawsuit at some relevant 1 Q At some point in time while at Bear
2 time, however, at the present time my attorneys 2 Stearns you met and managed the money for a
3 have counseled me that I cannot provide answers 3 fellow named Leslie Wexler, correct?
4 to any questions relevant to this lawsuit. Since 4 A Again, I would like to answer all
5 the U.S. Attorney has described your law firm as 5 questions relevant to this lawsuit, but today I
6 a criminal enterprise, Mr. Edward; and a pan of 6 must assert my Fifth Amendment, Sixth Amendment
7 the largest fraud in Florida's history, I am 7 and Fourteenth Amendment right to the U.S.
8 going to assert my Sixth Amendment, Fifth 8 Constitution.
9 Amendment and Fourteenth Amendment rights to the 9 Q In fact, I read in another deposition of
10 U.S. Constitution. 10 yours that you do not consider yourself to be
11 Q Isn't It true that while you were 11 homosexual, correct?
12 working at Bear Stearns you were already engaging 12 A (No response.)
13 in sex with underage minors? 13 Q You've answered that question before,
14 A Again, I believe you know the answers to 14 correct?
15 those questions, but -- 15 A Correct.
16 Q Yes. 16 Q Do you consider yourself to be
17 A May I finish? 17 bisexual?
18 Q I do. 18 A No.
19 MR. PIKE: Move to strike. Let the 19 Q In any event, you did develop a sexual
20 witness -- 20 relationship with Leslie Wexler at some point In
21 Q Sure - 21 time; Is that true?
22 MR. PIKE: Let the witness answer your 22 A No.
23 question. 23 Q Did you have a business relationship
24 MR. EDWARDS: I would love for him to 24 with Mr. Wexler?
25 finish the questions. 25 A I intend to respond to all relevant
6 (Pages 18 to 21)
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1 questions. I would like to answer most of your 1 Therefore l'Ilassert my Constitutional
2 questions, Mr. Edwards, today, however, 2 rights under the Fifth, Sixth and Fourteenth
3 especially since your firm has been described by 3 Amendment.
4 the United States Attorney in South Florida as a 4 THE WITNESS: Excuse me, could we take a
5 criminal enterprise purported to -- purported to 5 break?
6 have put — pulled off the largest fraud in 6 MR. EDWARDS: Already?
7 Florida's history, I would like to answer it, 7 THE WITNESS: Restroom.
8 however, my attorneys here today counseled me 1 8 THE VIDEOGRAPHER: Going off the video
9 must assert my Fifth, Sixth and Fourteenth 9 record 11:38 a.m.
10 Amendment right under the U.S. Constitution, 10 THE WITNESS: Thank you.
11 therefore Pm going to do that. 11 (Pause in the proceedings.)
12 Q Are you saying because Rothstein, 12 THE VIDEOGRAPHER: We're back on the
13 Rosenfeld, Adler was determined to be a criminal 13 video record at 11:48 a.m.
14 enterprise or somebody was running a criminal 14 Q How did you meet Chislalne Maxwell?
15 enterprise out of that law firm, that is the 15 A I intend to respond to all relevant
16 reason why you are not going to answer these 16 questions to this lawsuit; however, at the
17 questions today? You linked that together in 17 present time my attorneys have counseled me that
18 that answer. I just want to make sure I'm 18 I cannot provide answers to any questions
19 understanding that right? 19 relevant to this lawsuit, and must accept this
20 A I'm going to take the Fifth I intend 20 advice or risk losing effective -- my right to
21 to respond to all relevant questions today. I 21 effective representation. Accordingly,
22 would like to respond; unfortunately my attorneys 22 therefore, I assert my Fifth, Sixth and
23 have counseled me I can't, l must assert my 23 Fourteenth Amendment rights to the U.S.
24 Fifth, Sixth and Fourteenth Amendment rights 24 Constitution.
25 under the U.S. Constitution. 25 Q You would agree, would you not, that
23 25
Q Because other law firms have asked very 1 Ghislaine Maxwell shares your sexual obsession
2 similar questions and you haven't responded to 2 for underage minor females?
3 any of theirs either. I just want to understand 3 MR. PIKE: Argumentative, speculation,
4 what the relationship between Rothstein, 4 harassing.
5 Rosenfeld, Adler is to you invoking your Fifth 5 A You know, Mr. Edwards, the current U.S.
6 Amendment rights today, if you can articulate 6 Attorney has described your law firm as a
7 that for me. 7 crininal enterprise, and as taking part in one of
8 MR. PIKE: Form, compound, 8 the largest frauds in Florida's history. It has
9 argumentative. 9 been widely reported that your firm fabricated
10 A ROCIISICill, Rosenfeld, Adler has been 10 multiple cases of a sexual nature against
11 described by the U.S. Attorney as a criminal 11 people — other people and me, in order to fleece
12 enterprise and as part of the largest fraud in 12 unsuspecting investors out of millions of
13 Florida's history. It has been reported that 13 dollars, so unfortunately at this time in
14 your faro fabricated multiple cases using me, and 14 response to your questions, my attorneys have
15 against me in order to fleece unsuspecting 15 advised mei must assert my Sixth Amendment,
16 investors out of millions of dollars. 16 Fifth Amendment and Fourteenth Amendment rights,
17 Q Another long time friend of yours is 17 though 1 believe, as you know, I would really
18 Gliblaine Maxwell, right? 18 like to answer these questions, but at this
19 A I intend to respond to all relevant 19 moment, although at this time I have to assert
20 questions. I would like to answer most of these 20 those rights or risk losing effective counsel.
21 questions today, but I can't because my attorneys 21 Q Do you know
22 have counseled me that I cannot provide answers 22 A I intend to respond to all relevant
23 to any questions relevant to this lawsuit. I 23 questions regarding this lawsuit; however, at the
24 must accept their advice or risk losing my Sixth 24 present time my counsel has advised me that I
25 Amendment right to effective representation. 25 cannot provide answers to any questions relevant
7 (Pages 22 to 25)
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1 to this lawsuit. Your finn has been described as 1 present time my attorneys have counseled me that
2 a criminal enterprise, and is part of the largest 2 I cannot provide answers to any questions
3 fraud in Florida's history fabricating sexual 3 relevant to this lawsuit, no matter how much I
4 cases against me and others. Therefore, 4 would like to.
5 unfortunately, although I would like to answer 5 Therefore, I must accept their advice or
6 all of your questions today, I'm going to have to 6 risk losing my Sixth Amendment right to effective
7 assert my Fifth, Sixth and Fourteenth Amendment 7 representation; therefore, i have to assert my
right. 8 Fifth, Sixth and Fourteenth Amendment right under
9 Q Did you and Ghis sexually 9 the U.S. Constitution.
10 assault at 'a house? 10 Q Do you own a home in New Mexico?
11 A i intend to respond to all relevant 11 A i intend to respond to all relevant
12 questions regarding this lawsuit; however, at the 12 questions regarding this lawsuit and as I've had
13 present time my attorneys have counseled me I 13 to do with most of your questions here today, I'm
14 cannot provide answers to any questions relevant 14 going to have to take my attorneys advice and
15 to this lawsuit and must accept this right or 15 assert my Fifth, Sixth and Fourteenth Amendment
16 risk losing my Sixth Amendment rights to 16 right under the U.S. Constitution or risk losing
17 effective presentation. Accordingly, I assert my 17 effective representation.
18 Constitutional rights as guaranteed by the Fifth, 18 Q Is it true that you have had underage
19 Sixth and Fourteenth amendments to the U.S. 19 females, at each of those homes, for orgies with
20 Constitution. 20 you and Ghislaine Maxwell?
21 Q Stating Ghlslalne Maxwell and you had 21 MR. PIKE: Form, argumentative,
22 devised several schemes to lure underage girls to 22 speculation and harassing.
23 you for sex; isn't that correct? 23 A I would like to answer that question. I
24 MR. PIKE: Form, argumentative, 24 really would. However, as your firm has been
25 harassing? 25 described by the U.S. Attorney as a criminal
27 29
1 A Mr. Edwards, your firm has fabricated 1 enterprise, which its principal purpose was
2 multiple cases of sexual harassment claims and 2 racketeering conspiracy to generate money for the
3 other types of sexual cases against me and others 3 firm and its co-ccnspiritors through the
4 in order to be pan of what the U.S. Attorney has 4 operation of enterprise and through various
described as the largest fraud, the largest fraud 5 activities including mail fraud, wire fraud and
6 in Florida's history. I would like to answer all 6 money laundering, and fabricating multiple sex
7 your questions; however, my attorneys have 7 cases against me and others, though I would like
8 counseled me that at least today, I must assert 8 to answer your question today, Mr. Edwards, my
9 my Fifth, Sixth and Fourteenth Amendment rights 9 courisel has advised me I must take the Fifth,
10 under the U.S. Constitution. 10 Sixth and Fourteenth Amendment right provided by
11 Q Do you own a home in Manhattan? 11 the U.S. Constitution.
12 A i intend to respond to all relevant 12 Q Do you know somebody named
13 questions to this lawsuit; however, at the 13 (phonetic)?
14 present time my attorneys have counseled me that 14 MR. PIKE: Can you spell that, for the
15 I cannot provide answers to any questions 15 record?
16 relevant to this lawsuit, and I must accept their 16 MR. EDWARDS: No.
17 advice or risk losing my Sixth Amendment right to 17 MR. PIKE: Or for the court reporter?
18 effective representation. 18 A No.
19 Accordingly, therefore, I have to assert 19 Q You don't know the name?
20 my Fifth, Sixth and Fourteenth Amendment right 20 A No. Could you spell it?
21 under the U.S. Constitution. 21 Q (Witness shrugs.)
22 Q Do you own an island in the V.S. Virgin 22 A Okay.
23 Islands? 23 Q Did your sexual obsession with underage
24 A !intend to respond to all relevant 24 minor females grow at some point in time to allow
25 questions regarding this lawsuit; however, at the 25 you access to these underage minors every single
8 (Pages 26 to 29)
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1 day for sex? 1 would like to answer those questions, though at
2 MR. PIKE: Overbroad. Speculation, 2 this moment I must assert those rights or risk
3 argumentative, compound, harassing and 3 losing my attorneys.
4 confusing as well; as worded. Do you want 4 Q Sure, let's test that answer.
5 to break it down, Mr. Edwards? 5 A Okay.
6 Q Isn't It true that for the past ten 6 Let's talk about Jane DoMJane Doe
7 years you have found a way to engage in sexual 7 who was represented bMI
8 conduct with underage minors on an every day a firm, had nothing to do with
9 bask? 9 Rothstein, Rosenfeld, Adler. Do you know
to MR. PIKE: Speculation. Argumentative. 10 A Who?
it A As your firm has been described as a 11
12 criminal enterprise by the United States Attorney 12 A Can you spelt it?
13 and is part of the scheme to defraud people in 13 Q Common spelling,
14 South Florida of millions of dollars, you have 10
15 fabricated sexual cases and sexual claims against 15 A Can you spell it forme, please?
16 people like me and others. Unfortunately at this 16
17 time although I would like to answer your 17 A What's the last name, how is it
18 questions, Mr. Edwards, my counsel has advised me 18 spelled?
19 I cannot They have advised me I must assert my 19 Q-Ibelieve.
20 Fifth, Sixth and Fourteenth Amendment rights 20 A I intend to respond to all relevant
21 under the U.S. Constitution. 21 questions regarding this lawsuit; however, at the
22 Q isn't it true that you â–ºave promised 22 present time my attorneys have counseled me that
23 underage minors money or other benefits to engage 23 I cannot provide answers to any questions that
24 in sexual conduct with you over the past ten 24 may be relevant to this lawsuit and I must accept
25 years? 25 this advice or risk losing my Sixth Amendment
31 33
1 A Again, as I've answered many of your 1 right to effective representation. Accordingly,
2 questions today, and unfortunately will probably 2 I assert my Constitutional rights as guaranteed
3 end up not answering most of your questions 3 by the Fifth, Sixth and Fourteenth Amendment to
4 today, as your firm has been described, the firm 4 the Constitution.
5 bringing this lawsuit, I believe, if I'm wrong 5 Q Just for the record, I can only spell it
6 please, correct me -- 6 the way it was spelled in your flight logs from
7 Q You're wrong. 7 your airplane. I don't know exactly how she
8 A This is the firm that didn't notice this 8 spells her name, only how your pilot would spell
9 deposition? 9 her name.
10 Q Did not? 10 MR. PIKE: Form, speculating.
11 A Did not? 11 Q If I misspell it —
12 Q No. 12 MR. PIKE: Form, speculation,
13 A I apologize. Though your former firm 13 argumentative, harassing.
14 has been described, and the person you represent, 14 MR. EDWARDS: That's harassing?
15 L.M., in this case was represented by the firm 15 MR. PIKE: It assumes facts currently
16 that was described by the U.S. Attorney as 16 not in evidence in this particular
17 perpetrating one of the largest frauds in South 17 deposition; therefore, I move to strike.
18 Florida's history, fabricating multiple sexual 18 MR. EDWARDS: I was responding to his
19 cases against me and others in order to fleece 19 question asking me how to spell her name. I
20 unsuspecting investors out of millions and 20 don't know how other than his own pilot.
21. millions of dollars, so though unfortunately, I 21 MR. PIKE: Mr. Edwards, he asked you to
22 would like to answer each one of your questions 22 spell the name, you then spelled the name,
23 today, my counsel has advised me I must assert my 23 then went on with another narrative and
24 Sixth Amendment, Fourteenth Amendment and Fifth 24 there wasn't a question posed, on the floor.
25 Amendment right, though I believe you know, I 25 Q You would agree you Interacted with-
9 (Pages 30 to 33)
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1 every day in a sexual way, when she was 15 years 1 for a second?
2 old, right? 2 May I ask you a question?
3 A Again, I'm softy? 3 MR. PIKE: Sure. Can we take a break
4 Q Sure. You would agree that you 4 fora second?
5 Interacted with. sexually on an every day 5 MR. EDWARDS: Again?
6 basis when she was 15 years old? 6 THE WITNESS: Just a question.
7 A You know, again, Mr. Edwards, I would 7 MR. PIKE: He wants to speak with me for
8 like to answer all your questions here today. My 8 a second.
9 attorneys have asked me — advised me that I must 9 THE VIDEOGRAPHER: Off the video record
10 assert my Sixth Amendment, Fourteenth Amendment 10 12:01 p.m.
11 and Fifth Amendment rights provided by the U.S. 11 (Pause in the proceedings.)
12 Constitution and the fact that the current U.S. 12 THE VIDEOGRAPHER: We are back on the
13 Attorney has described your law finn as a 13 video record at 12:02 p.m.
14 criminal enterprise, is one of the largest frauds 14 Q Is it true, Mr. Epstein, that you and
15 in Florida's history for fabricating sexual -- 15 Ghislaine Maxwell forcedâ– to have sex with
16 cases of a sexual nature against me and others. 16 you on a daily basis?
17 Unfortunately, although I would like to answer 17 MR. PIKE: Form, argumentative,
18 those questions, if I do I risk losing my 18 harassing.
19 attorneys' counsel. Therefore, I must assert my 19 A Unfortunately at this time, though I
20 right. 20 would really like to answer those questions, and
21 MR. EDWARDS: Madam court reporter, Ill 21 like I have dent for most of your questions here
22 as an exhibit, the Jane Doe number 22 today, Mr. Edwards, your firm was described as a
23 crsus Jeffrey Epstein complaint, at 23 criminal enterprise, a serious criminal
24 some point in time. It will be Exhibit 1, 24 enterprise by the current U.S. Attorney. Part of
25 as Pm going to go through some of the facts 25 that criminal enterprise was fabricating cases of
35 37
1 as alleged in the complaint and as will be 1 a sexual nature against me and others in order to
2 testified to by the plaja. 2 fleece unsuspecting investors out of millions of
3 (Jane Doe numberMversus Jeffrey 3 dollars. Though, unfortunately at this time no
4 Epstein complaint was deemed marked as 4 matter how I would like to respond to your
5 Exhibit number 1 for identification, as of 5 questions, I must assert my Sixth Amendment,
6 this date.) 6 Fifth Amendment and Fourteenth Amendment rights
7 MR. PIKE: Counsel, do you have an extra 7 under the U.S. Constitution or risk having my
copy of that for me? 8 attorneys resign.
9 MR. EDWARDS: No. 9 Q Isn't it true thaMwas yours and
10 MR. PIKE: May I look at it real quick? 10 Ghlslaine Maxwell's sex slave front the time she
11 MR. EDWARDS: No. It has my notes on 11 was 15 through the time she escaped when she was
12 it. 12 19?
13 MR. PIKE: I understood, I saw the 13 MR. PIKE: Again objection,
14 highlights. 14 argumentative, harassing.
15 MR. EDWARDS: The notes are highlighted 15 A Mr. Edwards, your fimi has been
16 so when we copy it, it will not show up. 16 described as — excuse me, as a criminal
17 MR. PIKE: Just for the record, that's a 17 enterprise by the current U.S. Attorney and part
18 current, op
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO. 50-2008-CA-028051 XXXX MB AB
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
/
VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN
TAKEN ON BEHALF OF THE PLAINTIFF
DATE: February 17, 2010
U.S. Legal Support
EFTA01076251
1 February 17, 2010 1 THEREUPON,
2 INDEX 2 JEFFREY EPSTEIN
3 WITNESS DIRECTCROSS REDIRECT RECROSS
4 JEFFREY EPSTEIN 3 being by Toni Becker first duly sworn to tell
5 BY MR. EDWARDS 4 4 the whole truth, as hereinafter certified.
6 testified as follows:
EXHIBITS
7 FOR IDENTIFICA PAGE 6 DIRECT EXAMINATION
8 I Jane Doe numb usJeffrey 7 BY MR. EDWARDS:
Epstein complain 35
9 8 Q Can you give us your name.
2 Document, Nonprosecution Agreement 135 9 A Jeffrey Epstein.
10 10 Q Mr. Epstein, you made a comment when you
11
CER1iFILO QUESTIONS 11 came in the room that you were appreciative of me
12 12 being respectful to your housekeeper yesterday
Page Line 13 and I intend for that to be the same with you
13
61 22 14 today.
14 123 20 15 1 want to start by asking you, at this
146 l4 16 point we've gone through a lot of discovery in
15 148
153 5 17 this ease. There aren't may disputed facts as
16 159 13 18 to what actually happened at your house.
162 3
17 19 Generally I think you would agree that you
18 20 derived a way for young females to come to your
19 21 house and engage In varying degrees of sexual
20
21 22 activity, some of the girls as young as 12, some
22 23 of them as old as seventeen or so, most in
23 24 between, but as of yet you haven't provided an
24
25 25 explanation.
3
1 The videotaped deposition of JEFFREY 1 1 want to provide you an opportunity to
2 EPSTEIN in the above-entitled and numbered cause, 2 tell the jury at this time why you did ft.
3 was taken before me, TERRI BECKER, a Registered
4 Professional Reporter and Notary Public for the 3 MR. PIKE: I'm going to object
5 State of Florida at Liege, at 444 West Railroad 4 Confusing, compound and irrelevant, as
6 Avenue, in the City of West Palm Beach, Palm worded.
7 Beach County, in the State ofFlorida, beginning
8 at the hour of 5 eiclock a.m, pursuant to 6 A You know, I would like to answer that
9 the Notice in said cause for the taking of said 7 question, frankly. However, at this time, my
10 deposition which is annexed to the court file 8 attorneys have told me that I can't and 1 must
11 herein, on behalf of the PLAINTIFF in the
12 above-entitled action pending in the above-named 9 invoke my Fifth, Sixth and Fourteenth Amendment
13 court 10 rights or I risk losing their counsel.
14 The appearances at said time and place 11 Accordingly, I therefore assert those rights.
15 were as follows:
16 12 Sorry.
FARMER, JAFFE, WEISSING,
EDWARDS, F1STOS & LEHRMAN, P.L. 13 MR. PIKE: In addition to that I'll move
17 Attorneys for Plaintiff 14 to strike counsel's statement as a
425 North Andrews Avenue, Suite 2 15 narrative, as well.
18 Fort 33301
Tel: 16 MR. EDWARDS: I understand. I wanted to
19 BY: BRAD . WARDS 17 provide him an opportunity, if today was
STEVEN R. JAFFE, ESQ. 18 going to be the day.
20
BURMAN, CRITTON, LUTTIER & COLEMAN 19 MR. PIKE: Same thing, move to strike.
21 Attorneys for Defendant 20 Q Mr. Epstein, how long have you been
303 Banyan Boulevard, Suite 400 21 sexually attractive to underage minor females?
22 Wes orida 33401
Tel: 22 MR. PIKE: Objection, harassing,
23 BY: MICHAEL PIKE, ESQ. 23 argumentative.
24 ALSO PRESENT: 24 A Are you kidding?
JOE ROVNER, Videographer
25 (U.S Legal Support) 25 Q No, l mean, I don't feel Eke I'm
2 (Pages 2 to
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1 divulging any secrets here, right? 1 argumentative, compound, harassing and
2 MR. PIKE: Move to strike. 2 irrelevant.
3 Q That's the question that's pending. 3 Q You can answer.
4 A I would like to answer that question as 4 A I would like to answer, however, I'm
5 well, as all your other questions today, however, 5 going to have to assert my Fifth Amendment, Sixth
6 I have to follow my attorneys' advice. They have 6 Amendment, Fourteenth Amendment right as advised
7 told me I must invoke my Fifth, Sixth and 7 by my counsel, otherwise I risk losing their
8 Fourteenth Amendment right to not answer those 8 advice.
9 questions today, or any questions relevant to 9 Q Mr. Epstein, have you ever been
10 this lawsuit, so accordingly, I'm going to assert 10 diagnosed with a sex addiction to minors by a
11 those rights and under the constitution 11 psychologist or other medical professional?
12 guaranteed by the Fifth and Sixth, and Fourteenth 12 A I intend to respond to all of your
13 amendment. 13 questions at some relevant time; however, today
14 Q Would you consider yourself addicted to 14 at the present time, my attorneys have counseled
15 sex with minor females? 15 me that I cannot provide answers to any questions
16 MR. PIKE: Same objections. 16 relevant to this lawsuit and I must accept their
17 A You know, Mr. Edwards, again, I want to 17 advice or risk losing my Sixth Amendment rights
18 be very respectful. As the current U.S. Attorney 18 to effective representation.
19 has described your law firm as a criminal 19 Accordingly, I assert my Fifth,
20 enterprise and part of one of the largest frauds 20 Federal — Fifth and Sixth and Fourteenth
21 in Florida's history, it has been reported that 21 Amendment rights, to the United States
22 your firm has fabricated multiple cases against 22 Constitution.
23 me in order to fleece unsuspecting investors out 23 MR. PIKE: In addition to that, Mr.
24 of millions and millions of dollars, so 24 Edwards, as the Court has ruled on several
25 unfortunately at this time, although I would Ida 25 matters, Mr. Epstein's medical history is
7 9
1 to answer that question, on advice of counsel I 1 not relevant at this time nor has he placed
2 will have to refrain and assert my Fifth, Sixth 2 same at issue in this case.
3 and Fourteenth Amendment right. 3 MR. EDWARDS: Understood.
4 Q Can you then provide an explanation for 4 Q Mr. Epstein, were you sexually abused as
5 what relevance that soliloquy of yours has to, 5 a minor?
6 whether or not you engaged in sex acts with- 6 A Again?
7 When she was a minor? 7 Q Were you sexually abused, as a minor?
8 MR PIKE: Objection, no, he cannot 8 A You know, again, I would like to respond
9 Argumentative. Compound, harassing. 9 to all -- if any questions seem to be relevant.
10 MR. EDWARDS: Mr. Pike, with all due 10 I would like to respond to any relevant question
11 respect, it was not my idea for him to give 11 at this time; however, my attorneys have
12 this speech about a former ARA law firm I 12 counseled me that I cannot provide answers to the
13 was asking to elaborate on that. 13 questions relevant to this lawsuit today. I must
14 MR. PIKE: Counsel, I'm working with 14 accept their advice or risk losing my Sixth
15 your follow-up question. 15 Amendment right to effective representation.
16 MR. EDWARDS: I understand. 16 Accordingly then, I assert my Fifth, Sixth and
17 MR. PIKE: I'm objecting, object to the 17 Fourteenth Amendment right to the United States
18 form and stating the reasons on the record 18 Constitution.
19 why the form is required to be objected to, 19 Q Isn't it true that you have engaged in
20 based upon your question. 20 some sexual interaction with hundreds of underage
21 MR. EDWARDS: Will he elaborate on the 21 minor females In die last ten years of your
22 relevance of that soliloquy to his touching 22 life? Is that true?
23 -when she was 13, 14 and 15 years old in 23 MR. PIKE: Objection, relevance.
24 a sexual manna? 24 A Mr. Edwards, the current U.S. Attorney
25 MR. PIKE: I'm going to object again, 25 has described your law firm as a criminal
3 (Pages 6 to 9)
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1 enterprise and pan of the largest fraud in 1 50 years old?
2 Florida's history. It has been reported that 2 MR. PIKE: I'm going to object once
3 your firm fabricated multiple cases, many, many 3 again. We are getting way too argumentative
4 multiple cases against me in order to fleece 4 with the questioning. The questioning is
5 unsuspecting investors out ofmillions and 5 compound It is speculative and it is also
6 millions of dollars. Unfortunately, at this time 6 harassing. Whether or not this deposition
7 in response to your question, my attorneys have 7 video, thereofis played in front of a jury
8 advised me that I must assert my Sixth Amendment, 8 is a question of fact, and it will be
9 Fifth Amendment, Fourteenth Amendment right. 9 determined by a judge pursuant to a motion
10 Though, I believe, you know, that I would really 10 in limine, various portions thereof may or
11 like to answer your questions today, but at this 11 may not be played, so hiving placed those
12 moment i must assert those rights or risk having 12 objections on the record I'm going to
13 my attorneys resign. 13 insttuct Mr. Epstein not to answer that
14 Q You're Invoking your Fifth Amendment 14 question.
15 rights to each of these questions because you 15 MR. EDWARDS: Mr. Pftce, I don't know if
16 know your answers will incriminate you and you 16 you watehegainia hours of harassing
17 feel it will result in you being prosecuted for 17 questions tri=that she sometimes
18 your crimes; Isn't that right? 18 invoked her Fifth Amendment rights, I
19 MR. PIKE: Objection, argumentative, 19 understand the adverse advice that would be
20 harassing. Calls fora legal conclusion. 20 given and she was made to answer these
21 Q You can answer. 21 questions and these exact same questions
22 A No, in fact, the Supreme Court recently 22 were asked ofher, in fact, I'm using the
23 said the Fifth Amendment right is there to 23 phraseology from Mr. Luttier. I'm not
24 protect the innocent, so, that's the way I would 24 trying to harass him.
25 like to answer that. 25 Q I'm simply asking him to explain to the
11 13
1 Q Are you actually telling the Jury that 1 jury. If you're saying it didn't happen, if
2 you didn't commit the crimes that have been 2 you're saying it did happen, explain to the jury
3 alleged against you by the various females that 3 why you did it. That's all I want to hear. I'm
4 were under age when you engaged in sex with 4 being respectful about this.
5 them? Are you telling the jury that right now? 5 MR. PIKE: In an effort to keep a clean
6 MR. PIKE: Objection, argumentative, 6 record be respectful to the to the court
7 harassing. 7 reporter rather than having a diatribe back
8 A I would like to respond to that 8 and forth between you and myself, I'll move
9 question, as you know, however, at the present 9 to strike your last statement as
10 time my attorneys have counseled me that I cannot 10 irrelevant. Let's move on.
11 provide answers to any questions relevant to this 11 Q Is it true, Mr. Epstein, you were born
12 lawsuit and i must accept their advice or risk 12 January 20,1953?
13 losing my Sixth Amendment right to effective 13 A Yes.
14 representation. Accordingly, I assert my Fifth, 14 Q Where?
15 Sixth and Fourteenth Amendment right under the 15 A New York.
16 United States Constitution. 16 Q Where in New York?
17 Q Mr. Epstein, you understand that this is 17 A Brooklyn.
19 aeo that will be playe ie Jury in 18 Q Did you go to high school there?
19 trial against you 1m wants answers. 19 A Yes, sir.
20 The jury is going to want answers, so I know that 20 Q Where?
21 you're telling us that you're going to respond at 21 A Lafayette High School.
22 some time In the future; but the time is now. 22 Q After high school did you attend
23 Would you like this opportunity to explain why 23 college?
24 you engaged In sexual activity with.. 24 A Yes.
25 beginning when she was 13 years old and you were 25 Q Where was that?
4 (Pages 10 to 13)
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1 A New York. 1 I'll restate the answer. I would like to
2 Q What college did you attend? 2 respond, intend to respond, and would like to
3 A Cooper Union. 3 respond to all questions today. However, counsel
4 Q Sorry, i didn't hear. 4 has advised me I must take the Fifth, Sixth and
5 A Cooper Union. 5 Fourteenth Amendment right under the U.S.
6 Q Did you get a degree from Cooper Union? 6 Constitution.
7 A No, sir. 7 Q After college where were you employed?
8 Q How many years were you in college? 8 A You Imow, I would like to respond to all
9 A I believe, two. 9 your questions today, however, on advice of
10 Q What did you study? 10 counsel, I intend to take the Fifth, Sixth and
11 A Physics. 11 Fourteenth Amendment rights provided by the
12 Q Why did you leave college early? 12 United States Constitution or risk losing my
13 A I intend to respond to all relevant 13 counsel's representation.
14 questions regarding this lawsuit, however, at the 14 Q Isn't it true that you were a teacher at
15 present time my attorneys have counseled me that 15 the Dalton School in New York after college?
16 I cannot provide answers to questions that may be 16 A Again, I would like to respond to all
17 relevant to this lawsuit, so accordingly I assert 17 your questions; however, my attorneys have
18 my constitutional rights as guaranteed by the 18 counseled me that i cannot provide answers to any
19 Fifth, Sixth and Fourteenth Amendment. 19 questions today regarding to this lawsuit so I
20 Q Are you invoking your Fifth Amendment 20 must accept their advice or risk losing my Sixth
21 rights as to why you left college, Is it safe 21 Amendment right to effective representation.
22 then to presume that that answer you believe 22 Accordingly, I assert my Constitutional rights as
23 would incriminate you in some way? 23 guaranteed by the Fifth, Sixth and Fourteenth
24 MR. PIKE: I'm going to move to strike, 24 Amendment of the constitution.
25 speculative, argumentative, harassing. 25 Q Mr. Eistein, didrit have sex with any
15 17
Calls for a legal conclusion, and 1know 1 underage students while teaching at the Dalton
2 exactly what you're trying to do here, Mr. 2 School?
3 Edwards, is lace the record with questions 3 A Could you repeat that?
4 that would ultimately give you an adverse 4 Q Yes. Did you have sex with any underage
5 inference at any potential trial of this 5 students while teaching at the Dalton School in
6 matter, so having put that on the record, 6 New York?
7 I'm going to instruct him not to answer that 7 A Mr. Edwards, your firm has been
8 question, based upon his Fifth, Sixth and 8 described by the U.S. Attorney as one of the
9 Fourteenth Amendment rights to the United 9 largest — as a criminal enterprise, perpetrating
10 States Constitution. 10 one of the largest frauds in Florida's history.
13. MR. EDWARDS: With all due respect you 11 It has been reported that your firm fabricated
12 cannot invoke his Fifth Amendment rights, 12 multiple cases against me and others in order to
13 your attorneys instructed me in that fact -- 13 fleece unsuspecting investors out of millions and
14 MR. PIKE: lie can. 14 millions of dollars.
15 MR. EDWARDS: 11M. Had to do it 15 Unfortunately at this time in response
16 herself, so, I would like to hear it from 16 to your question, my attorneys have advised me I
17 Mr. Epstein. 17 must assert my Fifth Amendment, Sixth Amendment
18 Q Can we assume you're Invoking your Fifth 18 and Fourteenth Amendment rights, though I believe
19 Amendment rights as to why you left college 19 you know I would like -- really like to answer
20 early, that that answer you feel would 20 your questions but at this time I must assert
21 incriminate you? 21 those rights or have my attorneys resign.
22 MR. PIKE: Once again, move to strike 22 MR. EDWARDS: Mr. Pike, I think you know
23 for the same reasons. 23 he has a couple of options here. He can
24 You can answer. 24 answer questions or he can invoke his Fifth
25 A I've already answered the question. 25 Amendment rights. This nonresponsive
5 (Pages 14 to 17)
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1 verbiage regarding the RBA law firm is not 1 MR. PIKE Mr. Edwards, as you know
2 one of the options, it's inappropriate in 2 there are serious Fifth, Sixth and
3 the deposition and I would ask you to 3 Fourteenth Amendment constitutional rights
4 instruct your client not to obstruct this 4 at issue here, and the witness is attempting
5 process any further. I am not going to 5 to answer your questions to the best of his
6 terminate the deposition. I want it to 6 ability, despite how laced they are with
7 finish, but obviously this is going to be 7 adverse inference presumptions.
8 the subject matter of some motion in the 8 MR. EDWARDS: I don't want the adverse
9 °Duns and you know the judges will not 9 inferences. I want the answers, that's it.
10 appreciate this. I would like to just move 10 I don't want the adverse inferences.
11 this process along by eliminating that 11 MR. PIKE: Having said that, please
12 portion ofhis answer. I understand what he 12 allow the witness to answer to answer the
13 is saying. 'get it, but that's not 13 question.
14 something responsive to any of the questions 14 A Can you please repeat the question?
15 and I think you know it is inappropriate. 15 Q Isn't it true while working at Bear
16 MR. PIKE: I think the deponent is 16 Stearns you were already engaging in sex with
17 answering the questions. If you believe the 17 underage minor females?
18 responses are inappropriate and feel you can 18 A As your firm has been described by the
19 take it up with the Court with the motion 19 U.S. Attorney, as a criminal enterprise, using
20 you are speaking of, as you've done then you 20 some of the cases fabricated against me,
21 can, as you've done several times before. 21 personally, I would like to answer that question
22 Q After leaving the Dalton School. is it 22 today; however, upon advice of counsel I must
23 true that you began working as a money manager at 23 assert my Fifth, Sixth and Fourteenth Amendment
24 Bear Stearns? 24 rights under the U.S. Constitution or, in fact,
25 A I intend to respond to all your 25 risk losing their representation.
19 21
1 questions regarding this lawsuit at some relevant 1 Q At some point in time while at Bear
2 time, however, at the present time my attorneys 2 Stearns you met and managed the money for a
3 have counseled me that I cannot provide answers 3 fellow named Leslie Wexler, correct?
4 to any questions relevant to this lawsuit. Since 4 A Again, I would like to answer all
5 the U.S. Attorney has described your law firm as 5 questions relevant to this lawsuit, but today I
6 a criminal enterprise, Mr. Edward; and a pan of 6 must assert my Fifth Amendment, Sixth Amendment
7 the largest fraud in Florida's history, I am 7 and Fourteenth Amendment right to the U.S.
8 going to assert my Sixth Amendment, Fifth 8 Constitution.
9 Amendment and Fourteenth Amendment rights to the 9 Q In fact, I read in another deposition of
10 U.S. Constitution. 10 yours that you do not consider yourself to be
11 Q Isn't It true that while you were 11 homosexual, correct?
12 working at Bear Stearns you were already engaging 12 A (No response.)
13 in sex with underage minors? 13 Q You've answered that question before,
14 A Again, I believe you know the answers to 14 correct?
15 those questions, but -- 15 A Correct.
16 Q Yes. 16 Q Do you consider yourself to be
17 A May I finish? 17 bisexual?
18 Q I do. 18 A No.
19 MR. PIKE: Move to strike. Let the 19 Q In any event, you did develop a sexual
20 witness -- 20 relationship with Leslie Wexler at some point In
21 Q Sure - 21 time; Is that true?
22 MR. PIKE: Let the witness answer your 22 A No.
23 question. 23 Q Did you have a business relationship
24 MR. EDWARDS: I would love for him to 24 with Mr. Wexler?
25 finish the questions. 25 A I intend to respond to all relevant
6 (Pages 18 to 21)
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22 24
1 questions. I would like to answer most of your 1 Therefore l'Ilassert my Constitutional
2 questions, Mr. Edwards, today, however, 2 rights under the Fifth, Sixth and Fourteenth
3 especially since your firm has been described by 3 Amendment.
4 the United States Attorney in South Florida as a 4 THE WITNESS: Excuse me, could we take a
5 criminal enterprise purported to -- purported to 5 break?
6 have put — pulled off the largest fraud in 6 MR. EDWARDS: Already?
7 Florida's history, I would like to answer it, 7 THE WITNESS: Restroom.
8 however, my attorneys here today counseled me 1 8 THE VIDEOGRAPHER: Going off the video
9 must assert my Fifth, Sixth and Fourteenth 9 record 11:38 a.m.
10 Amendment right under the U.S. Constitution, 10 THE WITNESS: Thank you.
11 therefore Pm going to do that. 11 (Pause in the proceedings.)
12 Q Are you saying because Rothstein, 12 THE VIDEOGRAPHER: We're back on the
13 Rosenfeld, Adler was determined to be a criminal 13 video record at 11:48 a.m.
14 enterprise or somebody was running a criminal 14 Q How did you meet Chislalne Maxwell?
15 enterprise out of that law firm, that is the 15 A I intend to respond to all relevant
16 reason why you are not going to answer these 16 questions to this lawsuit; however, at the
17 questions today? You linked that together in 17 present time my attorneys have counseled me that
18 that answer. I just want to make sure I'm 18 I cannot provide answers to any questions
19 understanding that right? 19 relevant to this lawsuit, and must accept this
20 A I'm going to take the Fifth I intend 20 advice or risk losing effective -- my right to
21 to respond to all relevant questions today. I 21 effective representation. Accordingly,
22 would like to respond; unfortunately my attorneys 22 therefore, I assert my Fifth, Sixth and
23 have counseled me I can't, l must assert my 23 Fourteenth Amendment rights to the U.S.
24 Fifth, Sixth and Fourteenth Amendment rights 24 Constitution.
25 under the U.S. Constitution. 25 Q You would agree, would you not, that
23 25
Q Because other law firms have asked very 1 Ghislaine Maxwell shares your sexual obsession
2 similar questions and you haven't responded to 2 for underage minor females?
3 any of theirs either. I just want to understand 3 MR. PIKE: Argumentative, speculation,
4 what the relationship between Rothstein, 4 harassing.
5 Rosenfeld, Adler is to you invoking your Fifth 5 A You know, Mr. Edwards, the current U.S.
6 Amendment rights today, if you can articulate 6 Attorney has described your law firm as a
7 that for me. 7 crininal enterprise, and as taking part in one of
8 MR. PIKE: Form, compound, 8 the largest frauds in Florida's history. It has
9 argumentative. 9 been widely reported that your firm fabricated
10 A ROCIISICill, Rosenfeld, Adler has been 10 multiple cases of a sexual nature against
11 described by the U.S. Attorney as a criminal 11 people — other people and me, in order to fleece
12 enterprise and as part of the largest fraud in 12 unsuspecting investors out of millions of
13 Florida's history. It has been reported that 13 dollars, so unfortunately at this time in
14 your faro fabricated multiple cases using me, and 14 response to your questions, my attorneys have
15 against me in order to fleece unsuspecting 15 advised mei must assert my Sixth Amendment,
16 investors out of millions of dollars. 16 Fifth Amendment and Fourteenth Amendment rights,
17 Q Another long time friend of yours is 17 though 1 believe, as you know, I would really
18 Gliblaine Maxwell, right? 18 like to answer these questions, but at this
19 A I intend to respond to all relevant 19 moment, although at this time I have to assert
20 questions. I would like to answer most of these 20 those rights or risk losing effective counsel.
21 questions today, but I can't because my attorneys 21 Q Do you know
22 have counseled me that I cannot provide answers 22 A I intend to respond to all relevant
23 to any questions relevant to this lawsuit. I 23 questions regarding this lawsuit; however, at the
24 must accept their advice or risk losing my Sixth 24 present time my counsel has advised me that I
25 Amendment right to effective representation. 25 cannot provide answers to any questions relevant
7 (Pages 22 to 25)
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1 to this lawsuit. Your finn has been described as 1 present time my attorneys have counseled me that
2 a criminal enterprise, and is part of the largest 2 I cannot provide answers to any questions
3 fraud in Florida's history fabricating sexual 3 relevant to this lawsuit, no matter how much I
4 cases against me and others. Therefore, 4 would like to.
5 unfortunately, although I would like to answer 5 Therefore, I must accept their advice or
6 all of your questions today, I'm going to have to 6 risk losing my Sixth Amendment right to effective
7 assert my Fifth, Sixth and Fourteenth Amendment 7 representation; therefore, i have to assert my
right. 8 Fifth, Sixth and Fourteenth Amendment right under
9 Q Did you and Ghis sexually 9 the U.S. Constitution.
10 assault at 'a house? 10 Q Do you own a home in New Mexico?
11 A i intend to respond to all relevant 11 A i intend to respond to all relevant
12 questions regarding this lawsuit; however, at the 12 questions regarding this lawsuit and as I've had
13 present time my attorneys have counseled me I 13 to do with most of your questions here today, I'm
14 cannot provide answers to any questions relevant 14 going to have to take my attorneys advice and
15 to this lawsuit and must accept this right or 15 assert my Fifth, Sixth and Fourteenth Amendment
16 risk losing my Sixth Amendment rights to 16 right under the U.S. Constitution or risk losing
17 effective presentation. Accordingly, I assert my 17 effective representation.
18 Constitutional rights as guaranteed by the Fifth, 18 Q Is it true that you have had underage
19 Sixth and Fourteenth amendments to the U.S. 19 females, at each of those homes, for orgies with
20 Constitution. 20 you and Ghislaine Maxwell?
21 Q Stating Ghlslalne Maxwell and you had 21 MR. PIKE: Form, argumentative,
22 devised several schemes to lure underage girls to 22 speculation and harassing.
23 you for sex; isn't that correct? 23 A I would like to answer that question. I
24 MR. PIKE: Form, argumentative, 24 really would. However, as your firm has been
25 harassing? 25 described by the U.S. Attorney as a criminal
27 29
1 A Mr. Edwards, your firm has fabricated 1 enterprise, which its principal purpose was
2 multiple cases of sexual harassment claims and 2 racketeering conspiracy to generate money for the
3 other types of sexual cases against me and others 3 firm and its co-ccnspiritors through the
4 in order to be pan of what the U.S. Attorney has 4 operation of enterprise and through various
described as the largest fraud, the largest fraud 5 activities including mail fraud, wire fraud and
6 in Florida's history. I would like to answer all 6 money laundering, and fabricating multiple sex
7 your questions; however, my attorneys have 7 cases against me and others, though I would like
8 counseled me that at least today, I must assert 8 to answer your question today, Mr. Edwards, my
9 my Fifth, Sixth and Fourteenth Amendment rights 9 courisel has advised me I must take the Fifth,
10 under the U.S. Constitution. 10 Sixth and Fourteenth Amendment right provided by
11 Q Do you own a home in Manhattan? 11 the U.S. Constitution.
12 A i intend to respond to all relevant 12 Q Do you know somebody named
13 questions to this lawsuit; however, at the 13 (phonetic)?
14 present time my attorneys have counseled me that 14 MR. PIKE: Can you spell that, for the
15 I cannot provide answers to any questions 15 record?
16 relevant to this lawsuit, and I must accept their 16 MR. EDWARDS: No.
17 advice or risk losing my Sixth Amendment right to 17 MR. PIKE: Or for the court reporter?
18 effective representation. 18 A No.
19 Accordingly, therefore, I have to assert 19 Q You don't know the name?
20 my Fifth, Sixth and Fourteenth Amendment right 20 A No. Could you spell it?
21 under the U.S. Constitution. 21 Q (Witness shrugs.)
22 Q Do you own an island in the V.S. Virgin 22 A Okay.
23 Islands? 23 Q Did your sexual obsession with underage
24 A !intend to respond to all relevant 24 minor females grow at some point in time to allow
25 questions regarding this lawsuit; however, at the 25 you access to these underage minors every single
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1 day for sex? 1 would like to answer those questions, though at
2 MR. PIKE: Overbroad. Speculation, 2 this moment I must assert those rights or risk
3 argumentative, compound, harassing and 3 losing my attorneys.
4 confusing as well; as worded. Do you want 4 Q Sure, let's test that answer.
5 to break it down, Mr. Edwards? 5 A Okay.
6 Q Isn't It true that for the past ten 6 Let's talk about Jane DoMJane Doe
7 years you have found a way to engage in sexual 7 who was represented bMI
8 conduct with underage minors on an every day a firm, had nothing to do with
9 bask? 9 Rothstein, Rosenfeld, Adler. Do you know
to MR. PIKE: Speculation. Argumentative. 10 A Who?
it A As your firm has been described as a 11
12 criminal enterprise by the United States Attorney 12 A Can you spelt it?
13 and is part of the scheme to defraud people in 13 Q Common spelling,
14 South Florida of millions of dollars, you have 10
15 fabricated sexual cases and sexual claims against 15 A Can you spell it forme, please?
16 people like me and others. Unfortunately at this 16
17 time although I would like to answer your 17 A What's the last name, how is it
18 questions, Mr. Edwards, my counsel has advised me 18 spelled?
19 I cannot They have advised me I must assert my 19 Q-Ibelieve.
20 Fifth, Sixth and Fourteenth Amendment rights 20 A I intend to respond to all relevant
21 under the U.S. Constitution. 21 questions regarding this lawsuit; however, at the
22 Q isn't it true that you â–ºave promised 22 present time my attorneys have counseled me that
23 underage minors money or other benefits to engage 23 I cannot provide answers to any questions that
24 in sexual conduct with you over the past ten 24 may be relevant to this lawsuit and I must accept
25 years? 25 this advice or risk losing my Sixth Amendment
31 33
1 A Again, as I've answered many of your 1 right to effective representation. Accordingly,
2 questions today, and unfortunately will probably 2 I assert my Constitutional rights as guaranteed
3 end up not answering most of your questions 3 by the Fifth, Sixth and Fourteenth Amendment to
4 today, as your firm has been described, the firm 4 the Constitution.
5 bringing this lawsuit, I believe, if I'm wrong 5 Q Just for the record, I can only spell it
6 please, correct me -- 6 the way it was spelled in your flight logs from
7 Q You're wrong. 7 your airplane. I don't know exactly how she
8 A This is the firm that didn't notice this 8 spells her name, only how your pilot would spell
9 deposition? 9 her name.
10 Q Did not? 10 MR. PIKE: Form, speculating.
11 A Did not? 11 Q If I misspell it —
12 Q No. 12 MR. PIKE: Form, speculation,
13 A I apologize. Though your former firm 13 argumentative, harassing.
14 has been described, and the person you represent, 14 MR. EDWARDS: That's harassing?
15 L.M., in this case was represented by the firm 15 MR. PIKE: It assumes facts currently
16 that was described by the U.S. Attorney as 16 not in evidence in this particular
17 perpetrating one of the largest frauds in South 17 deposition; therefore, I move to strike.
18 Florida's history, fabricating multiple sexual 18 MR. EDWARDS: I was responding to his
19 cases against me and others in order to fleece 19 question asking me how to spell her name. I
20 unsuspecting investors out of millions and 20 don't know how other than his own pilot.
21. millions of dollars, so though unfortunately, I 21 MR. PIKE: Mr. Edwards, he asked you to
22 would like to answer each one of your questions 22 spell the name, you then spelled the name,
23 today, my counsel has advised me I must assert my 23 then went on with another narrative and
24 Sixth Amendment, Fourteenth Amendment and Fifth 24 there wasn't a question posed, on the floor.
25 Amendment right, though I believe you know, I 25 Q You would agree you Interacted with-
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1 every day in a sexual way, when she was 15 years 1 for a second?
2 old, right? 2 May I ask you a question?
3 A Again, I'm softy? 3 MR. PIKE: Sure. Can we take a break
4 Q Sure. You would agree that you 4 fora second?
5 Interacted with. sexually on an every day 5 MR. EDWARDS: Again?
6 basis when she was 15 years old? 6 THE WITNESS: Just a question.
7 A You know, again, Mr. Edwards, I would 7 MR. PIKE: He wants to speak with me for
8 like to answer all your questions here today. My 8 a second.
9 attorneys have asked me — advised me that I must 9 THE VIDEOGRAPHER: Off the video record
10 assert my Sixth Amendment, Fourteenth Amendment 10 12:01 p.m.
11 and Fifth Amendment rights provided by the U.S. 11 (Pause in the proceedings.)
12 Constitution and the fact that the current U.S. 12 THE VIDEOGRAPHER: We are back on the
13 Attorney has described your law finn as a 13 video record at 12:02 p.m.
14 criminal enterprise, is one of the largest frauds 14 Q Is it true, Mr. Epstein, that you and
15 in Florida's history for fabricating sexual -- 15 Ghislaine Maxwell forcedâ– to have sex with
16 cases of a sexual nature against me and others. 16 you on a daily basis?
17 Unfortunately, although I would like to answer 17 MR. PIKE: Form, argumentative,
18 those questions, if I do I risk losing my 18 harassing.
19 attorneys' counsel. Therefore, I must assert my 19 A Unfortunately at this time, though I
20 right. 20 would really like to answer those questions, and
21 MR. EDWARDS: Madam court reporter, Ill 21 like I have dent for most of your questions here
22 as an exhibit, the Jane Doe number 22 today, Mr. Edwards, your firm was described as a
23 crsus Jeffrey Epstein complaint, at 23 criminal enterprise, a serious criminal
24 some point in time. It will be Exhibit 1, 24 enterprise by the current U.S. Attorney. Part of
25 as Pm going to go through some of the facts 25 that criminal enterprise was fabricating cases of
35 37
1 as alleged in the complaint and as will be 1 a sexual nature against me and others in order to
2 testified to by the plaja. 2 fleece unsuspecting investors out of millions of
3 (Jane Doe numberMversus Jeffrey 3 dollars. Though, unfortunately at this time no
4 Epstein complaint was deemed marked as 4 matter how I would like to respond to your
5 Exhibit number 1 for identification, as of 5 questions, I must assert my Sixth Amendment,
6 this date.) 6 Fifth Amendment and Fourteenth Amendment rights
7 MR. PIKE: Counsel, do you have an extra 7 under the U.S. Constitution or risk having my
copy of that for me? 8 attorneys resign.
9 MR. EDWARDS: No. 9 Q Isn't it true thaMwas yours and
10 MR. PIKE: May I look at it real quick? 10 Ghlslaine Maxwell's sex slave front the time she
11 MR. EDWARDS: No. It has my notes on 11 was 15 through the time she escaped when she was
12 it. 12 19?
13 MR. PIKE: I understood, I saw the 13 MR. PIKE: Again objection,
14 highlights. 14 argumentative, harassing.
15 MR. EDWARDS: The notes are highlighted 15 A Mr. Edwards, your fimi has been
16 so when we copy it, it will not show up. 16 described as — excuse me, as a criminal
17 MR. PIKE: Just for the record, that's a 17 enterprise by the current U.S. Attorney and part
18 current, op