EFTA00159250

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
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Case No. 08-CV-80893-CIV-MARRA/JOHNSON 
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JANE DOE, 
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Plaintiff, 
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vs. 
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JEFFREY EPSTEIN, et al., 
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Defendants. 
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DEPOSITION OF 
Volume 
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Pages 1 through 138 
Videotaped 
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Monday, March 15, 2010 
10:13 a.m. - 12:42 p.m. 
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U.S. Legal Support 
515 East Las Olas Boulevard, 3rd Floor 
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Fort. Lauderdale, Florida 33301 
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Stenographically Reported By: 
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Janet L. McKinney, RPR, FPR, CLR 
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Registered Professional Reporter 
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Florida Professional Reporter 
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Certified LiveNote Reporter 
0002 
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APPEARANCES: 
2 
ON BEHALF OF THE PLAINTIFF: 
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FARMER, JAFFE, WEISSING, EDWARDS, 
FISTOS & LEHRMAN 
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425 North Andrews Avenue 
Suite 2 
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Fort Lauderdale, Florida 33301-3268 
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BY: BRADLEY EDWARDS, ESQ. 
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ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN: 
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BURMAN, CRITTON, LUTTIER 
COLEMAN, LLP 
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303 Banyan Boulevard 
Suite 40C 
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West Palm Beach, Florida 33401 
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BY: MICHAEL J. PIKE, ESQ. 
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ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES: 
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KERMELSTEIN & HOROWITZ, P.A. 
18205 Biscayne Boulevard 
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Suite 2218 
Miami, Florida 3316C 
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BY: STUART S. MERMELSTEIN, ESQ. 
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ON BEHALF OF THE WITNESS: 
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ROBBINS, TUNKEY, ROSS, AMSEL, 
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RABEN & WAXMAN, P.A. 
2250 Southwest Third Avenue 
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4th Floor 
Miami, Florida 33129 
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BY: ALAN S. ROSS, ESQ. 
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Also Present: Sean McGuire, Videographer 
U.S. Legal Support 
0003 
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INDEX 
Page 
Direct Examination By Mr. Edwards 
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Cross-Examination By Mr. Mermelstein 
111 
Redirect Examination By Mr. Edwards 
127 
Recross-Examination By Mr. Mermelstein 
133 
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7 
Certificate of Oath 
137 
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Certificate of Reporter 
138 
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EXHIBITS 
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PLF'S 
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No. 
Description 
Page 
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14 
1 
Jane Doe 102 v. Jeffrey Epstein 
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15 
complaint 
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2A-2G Telephone messages 
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Handwritten notes 
72 
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2H 
Telephone message 
87 
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Gawker.com photo with story 
127 
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WITNESS'S 
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No. 
Description 
Page 
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25 
1 
Target letter 
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0004 
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Videotaped deposition taken before JANET L. 
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McKINNEY, Registered Professional Reporter, Florida 
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Professional Reporter, Certified LiveNote Reporter and 
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Notary Public in and for the Slate of Florida at Large 
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in the above cause. 
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(Whereupon, Witness's Exhibit 1 was marked for 
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identification.) 
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VIDE0GRAPHER: We are now on the video record. 
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Today is Monday, the 15th day of March, 2010. The 
1C 
time is 9:13 a.m.. (sic). We are here al 515 East. 
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Las Olas Boulevard, 3rd Floor, Fort Lauderdale, 
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Florida, for the purpose of taking the videotape 
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deposition of 
taken in Case Number 
08-CIV-80893, ane oe v. effrey Epstein, el. al. 
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The court reporter is Janet. McKinney; the 
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videographer is Sean McGuire, both of V.S. Legal 
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Support. 
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Will counsel and all present please introduce 
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yourself and the court reporter will swear the 
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witness. 
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N.R. EDWARDS: Brad Edwards. I represent the 
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plaintiff, Jane Doe also "Jane Doe"; EW, "EW"; LM, 
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'LM.". 
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MR. MERMELSTEIN: Stuart Mermelstein. I 
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represent Jane Doe Numbers 2 through 8. 
0005 
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MR. PIKE: Michael Pike on behalf of Jeffrey 
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Epstein. 
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MR. ROSS: And good morning, my 
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Ross. I represent the witness, 
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THE REPORTER: Would you raise your rig 
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hand, please. 
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Do you solemnly swear or affirm the testimony 
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you're about to give will be the truth, and nothing 
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but the truth, so help you God? 
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THE WITNESS: I do. 
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MR. ROSS: Before the deposition begins and in 
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an effort to streamline the process of getting 
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through this deposition on behalf of the witness we 
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have had marked as Witness Exhibit Number 1 an 
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August 31, 2007 letter from the United States 
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Attorney's Office 
through 
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her then counsel, 
which is called a 
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target. letter ide. 
as a target of a 
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federal Grand Jury investigation in the Southern 
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District of Florida and outlining a number of 
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offenses that. were the subject =alter of 
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investigation. 
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As a result of that, it is anticipated that. 
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some of the questions that may be asked during the 
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course of this deposition she may invoke her Fifth 
0006 
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Amendment privilege against self-incrimination. 
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And in order to streamline this we've agreed prior 
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to beginning this that she will simply answer "I 
name is Alan 
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0008 
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refuse to answer.' The parties will understand and 
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the record will reflect that, she is invoking her 
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Fifth Amendment privilege against 
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self-incrimination. 
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If there is some other privilege, 
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attorney-client privilege or sore other objection 
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Chat I may have to a question, I'll specifically 
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state it. But her answer °I refuse to answer• will 
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be on Fifth Amendment grounds if that's acceptable 
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CO everyone. 
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MR. EDWARDS: It's acceptable. 
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KR. MERMELSTEIN: It's acceptable. 
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KR. PIKE: Acceptable. 
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MR. ROSS: Okay. Madam court reporter has 
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already marked the exhibit, and I'll leave that 
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with her. 
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MR. EDWARDS: Okay. 
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0007 
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THEREUPON: 
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having been first duly sworn or affirmed, was examined 
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and testified as follows: 
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DIRECT EXAMINATION 
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BY K.R. EDWARDS: 
7 
Q. Can you tell us your full 
8 
A. 
Q. At some point in time you 
is that correct? 
A. Correct. 
Q. And when did that change? 
ou married? 
Q. When were 
A. 
Q. uk4v. whni 'mvout  le of birth? 
A. [
Q. 
A. Yes. 
full name. 
were known as 
Q. And who are you married to? 
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A. Correct. 
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w 
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A. 
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Q. 
w o was t e connection at 
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that invited you? 
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Q. Well, you can continue. 
A. Yes. 
Q. So in order to come to the United States you 
needed to get a work visa? 
A. I was invited actually just to kind 
feeling if I will be suitable. So I came on 
tourist visa which is, I believe, 61/82. 
of get a 
a business 
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Q. Okay. And where did you first go when you 
came to the United States, what state? 
A. Florida. 
Q. And what city in Florida? 
A. Miami. 
Q. And what did you do for your two weeks when 
you first arrived in Miami, Florida? 
A. I do not recall. 
Q. Okay. But did you do any modeling? 
A. Well, like I would see some photographers, the 
agency would send me like on all calls to see 
photographers to kind of introduce me as a model. 
why did you make the decision Lo go with 
in the United Stales when you already were 
modeling in --
A. Um-hum. 
Q. -- Europe? 
A. Well, you know, just to expand it was 
something that I did. And I decided to take a year off 
after I graduated from. high school and -- you know, 
just to expand the modeling -- the modeling 
possibilities, opportunities. 
Q. 
Where di
 
uate from high school? 
A. In 
Q. What ear? 
A. 
Q. And do you have any college? Have you gone to 
college after that? 
did you get your associate's degree from. 
A. 
Q. 
chelor's degree right 
now? 
A. Yes. 
Q. From where? 
A. 
Q. in wnaL. 
A. 
Q. 
a you been in the 
program? 
A. Since fall 
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. 
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you first arrived in Miami, Florida in 
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did you decide during that two weeks that_ 
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you were going to stay permanently? 
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A. No. 
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Q. Okay. Did you go back to 
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A. Yes, I have. I have -- I went back for 
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Christmas. 
13 
Q. Okay. Poor question. Going back LcI'm 
14 
trying to just understand how it was that -- you came 
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over here on a two-week business visa, but eventually 
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you ended up staying for a longer period of Lime, 
17 
correct? 
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A. Right-
19 
Q. Okay. And how did that. come about, just tell 
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me? 
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A. Well, I got. romantically involved with my 
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current husband and so when -- you know, we just 
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started dating, we got engaged, and that's how, you 
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know, our relation evolved -- evolved, and eventually, 
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you know, I got married and -- and stayed. 
0013 
1 
Q. Okay. And since coming to the United States 
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have you always lived in Miami, Florida? 
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A. No. 
4 
Q. All right. Where else have you lived in the 
5 
United States? 
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A. New York. 
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Q. Where in New York? 
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A. Manhattan. 
9 
Q. What, was the address in Manhattan where you 
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lived? 
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MR. ROSS: I'm going to advise you Lo invoke 
12 
privilege. 
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A. I refuse to answer. 
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Q. Okay. Have you -- are you familiar with an 
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address at 301 East 66th Street in New York? 
16 
A. I refuse to answer. 
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MR. PIKE: May we take a break for a second? 
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May I speak with you? 
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MR. ROSS: Sure. 
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VIDEOGRAPHER: Off the record, 10:22 a.m. 
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(Recess Laken at 10:22 a.m.) 
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(Deposition resumed at 10:23 a.m.) 
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VIDEOGRAPHER: On the record, 10:23 a.m.. 
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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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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 
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understand. Nodding of the head or shaking the head 
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are easy to do and I gel what you're saying, but she 
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doesn't. Ah-ha or un-ah are things that are commonly 
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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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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 
2 
3 
4 
5 
have they come to the United Stales? 
A. Yes, they have visited me. 
Q. Have they ever met Jeffrey Epstein? 
A. I refuse to answer. 
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 
work. 
Q. Are you also still 
though? 
A. No, I'm not. 
Q. And when was the last. Lime you did any 
modeling? 
in the modeling business 
Q. And why did you stop modeling at that. tire? 
A. I wanted -- I always kind of knew that it's 
something Lhat I'm going to be doing and I just decided 
to go and pursue a college degree. 
Q. Okay. Is it something that you ever plan to 
go back to, modeling? 
A. No. 
Q. Are you involved at all with the modeling 
industry? 
A. No. 
Q. I mean, helping to recruit models, helping 
others to recruit models, anything like that? 
A. No. 
Q. Do you ever -- do you currently talk Co 
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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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 
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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. 
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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. 
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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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quiet or keep quiet about what went on in his house? 
MR. PIKE: Form. 
A. I refuse 10 answer. 
Q. Have you talked to 
about the things 
Epstein s ouse? 
MR. PIKE: Form. 
A. I refuse to answer. 
that went on in Jeffrey 
Q. Did you sign a confidentiality agreement with 
Jeffrey Epstein? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. Did that confidentiality agreement outline 
what you should say to authorities should he be caught 
with underage females? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Is there another book or manual or written 
memorialization of what you, as an employee of Jeffrey 
Epstein, should do if confronted by law enforcement? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Are you invoking your Fifth Amendment right 
because you believe you could be prosecuted? 
MR. ROSS: Invoke. 
A. I refuse to answer. 
Q. Are you also invoking because you're scared to 
testify against Jeffrey Epstein? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. When did you first learn that Jeffrey Epstein 
had a sexual obsession for underage females? 
A. I refuse to answer. 
V.A. PIKE: Form. 
Q. Isn't it true that you have seen Jeffrey 
Epstein sexually interacting with females as young as 
12 years old? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. Is it true that you have observed Jeffrey 
Epstein's sexual obsession to include the age range 12 
to 17? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Have you ever had sex with Jeffrey Epstein? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. Have you ever been paid for sex with Jeffrey 
Epstein? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Do you know if 
had sex with 
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Jeffrey Epstein when she was underage? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
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Q. What have you been told about Jeffrey 
24 
Epstein's sexual obsession with underage minor 
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children? 
0023 
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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. 
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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. 
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Q. Were you one of those assistants that helped 
22 
to bring him underage minor females? 
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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 
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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, 
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genital area or buttocks or the clothing covering them 
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of a person less than 16 years of age or forces or 
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entices a person under 16 years of age to so touch the 
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perpetrator, commits lewd or lascivious molestation, a 
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second degree felony.' 
16 
After hearing that statute isn't that 
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something -- isn't that a crime that you know 
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Mr. Epstein to have committed on an everyday basis 
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while you were working for him? 
2C 
MR. PIKE: Form. 
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A. I refuse to answer. 
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Q. And that's a statute that he violated with 
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more than 1CC underage females; is that true? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
0025 
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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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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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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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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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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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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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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 Little 
15 
St. Jeff's now? 
16 
MR. PIKE: Form. 
17 
A. I refuse to answer. 
18 
Q. And have you witnessed underage child sex 
19 
orgies on that island? 
2C 
MR. PIKE: Form. 
21 
A. I refuse to answer. 
22 
Q. Do you know a female named 
23 
A. I refuse to answer. 
24 
Q. Do you know where 
lives these days? 
25 
A. I refuse to answer. 
0039 
1 
Q. What is your understanding of 
2 
role in Jeffrey Epslein's life? 
3 
A. I refuse to answer. 
4 
MR. PIKE: Form. 
5 
Q. Isn't it true that she gets paid just to bring 
6 
him underage minor females for sex? 
7 
MR. PIKE: Form. 
8 
A. I refuse to answer. 
9 
Q. And additionally, she schedules the 
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appointments for underage minor females for him to 
11 
molest? 
12 
A. I refuse Lo answer. 
13 
MR. PIKE: Form. 
14 
Q. You know 
15 
A. I refuse o answer. 
16 
Q. Does she still work for Ghislaine Maxwell? 
17 
A. I refuse to answer. 
18 
Q. Was she an underage minor child victim of 
19 
Jeffrey Epstein's? 
20 
A. I refuse to answer. 
21 
Q. Through discovery we've talked to numerous 
22 
witnesses about, you know, Jeffrey Epstein and people 
23 
that work for him. I don't know if you'll be able to 
24 
answer any of these questions but. I'll ask them anyway 
25 
one at a time. 
0040 
1 
Is 
somebody who travels with 
2 
Jeffrey Epstein? 
3 
MR. PIKE: Form. 
4 
A. I refuse to answer. 
5 
Q. And when Jeffrey Epstein is coming Lo town 
6 
doesn't he call 
his number one assistant? 
7 
MR. PIKE: Form. 
8 
A. I refuse to answer. 
9 
Q. And at some point in Lime, it looks like in 
10 
early 2005 or lace 2004, you were also an assistant of 
11 
Jeffrey Epstein's, correct? 
12 
V. PIKE: Form. 
13 
A. I refuse to answer. 
14 
Q. And how was it that you transitioned from 
15 
being involved in modeling to being an employee of 
16 
Jeffrey Epstein? 
17 
MR. PIKE: Form. 
18 
A. I refuse to answer. 
19 
Q. Other than arranging for underage minor 
20 
females to come to Jeffrey Epstein's house did you do 
21 
anything else for Jeffrey Epstein? 
22 
MR. PIKE: Form. 
23 
A. I refuse to answer. 
24 
Q. Did you ever fly on Jeffrey Epstein's 
25 
airplane? 
0041 
1 
A. I refuse to answer. 
2 
Q. Did you witness Jeffrey Epstein abuse --
3 
sexually abusing underage minor females on his 
4 
airplane? 
5 
MR. PIKE: Form. 
6 
A. I refuse to answer. 
7 
Q. Did you know that it was illegal for Jeffrey 
8 
Epstein to interact sexually with underage minor 
9 
females? 
IC 
MR. PIKE: Form. 
11 
A. I refuse to answer. 
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