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FBI VOL00009
EFTA00159250
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12 Q. Did you ever object to Jeffrey Epstein 13 interacting sexually with underage minor females? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. Would Jeffrey Epstein get angry at you if you 1? did not have an appointment set for him with an 18 underage minor female? 19 MR. PIKE: Form. 20 A. I refuse to answer. 21 Q. Has Jeffrey Epstein contacted you in the last 22 year? 23 A. I refuse to answer. 24 MR. PIKE: Form. 25 Q. Has contacted you within the last 0042 1 year? 2 A. I refuse to answer. 3 Q. Has anybody that is associated with Jeffrey 4 Epstein's party contacted you in the last year? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. By that I mean to include Ghislaine Maxwell, 8 Lesley Groff, any of these people, have they contacted 9 you within the last year? 1C MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. Are you familiar with the names of some of the 13 underage minor females? 14 A. I refuse to answer. 15 Q. Are you familiar with LM? 16 A. I refuse to answer. 17 Q. Do you remember what LM looked like? 18 A. I refuse to answer. 19 Q. Are you familiar with EW? 20 A. I refuse to answer. 21 Q. Do you remember what EW looked like? 22 A. I refuse to answer. 23 Q. Are you familiar with Jane Doe? 24 A. I refuse to answer. 25 Q. These are all females that were underage minor 0043 1 females that Jeffrey Epstein interacted with sexually 2 during a time when you were working for him; isn't that 3 true? 4 A. I refuse to answer. 5 MR. PIKE: Form. 6 Q. And LM was somebody that went over to Jeffrey 7 Epstein's house and was molested at a young age by him. 8 more than ICC times; is that true? 9 MR. PIKE: Form. IC A. I refuse to answer. 11 Q. And EW was also somebody who went over to 12 Jeffrey Epstein's house when she was between 14 and 13 16 years old more than a hundred times; isn't that 3524-006 Page2lof68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009268 EFTA00159270
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14 true? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. And Jane Doe was somebody that went to Jeffrey 18 Epstein's house more than 15 times to be molested by 19 Jeffrey Epstein when she was 14 and 15 years old; is 20 that. true? 21 MR. PIKE: Form. 22 A. I refuse t0 answer. 23 Q. Is it also true that LM brought to Jeffrey 24 Epstein's house between 50 and 75 other underage minor 25 females for Jeffrey Epstein to molest? 0044 1 A. I refuse to answer. 2 MR. ROSS: Form. 3 Q. Are you aware of Jeffrey Epstein's for lack of 4 a better word "ritual" with these underage minor 5 females in his bedroom.? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. Wouldn't it generally begin with Jeffrey 9 Epstein placing a call to or yourself and 10 telling you that he's going to oe in town at the Palm 11 Beach mansion? 12 MR. PIKE: Form. 13 A. I refuse to answer. 14 Q. And then isn't there a list_ of underage minor 15 females stored in the computer system? 16 MR. PIKE: Form. 17 A. I refuse to answer. 18 Q. And that computer system is interconnected 19 from his New York home, his New Mexico home, his 20 island, his home in France, and West Palm Beach; is 21 that. correct? 22 MR. PIKE: Form. 23 A. I refuse to answer. 24 Q. And have you seen that list of underage minor 25 females stored in the computer system? 0045 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. And isn't it true there are over a thousand 4 girls at any given time between the age range of 12 and 5 17 all of which have been molested by Jeffrey Epstein? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. And when Mr. Epstein would call and tell you 9 the time that he was going to be in town it would then IC be your job to get an underage minor female to his 11 house and set. a specific appointment for that person; 12 is that correct? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. And he would tell you the exact time of day 3524-006 Page 22 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009269 EFTA00159271
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16 that he wanted his two or three appointments to molest 17 underage minor females? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. And you would go into the computer system and 21 call the person that he told you he wanted Lo see for 22 that. day; is that correct? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. And that may be 0046 1 or somebody local Lhat you would call on the telephone 2 and tell them to come work at a specific time? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. And didn't Mr. Epstein tell you that the way 6 you need to tell these girls is that Lhey are working 7 so that they do not feel that they have the option to 8 decline? 9 MR. PIKE: Form. 10 A. I refuse to answer. 11 Q. I mean, the psychology of it all was explained 12 in detail by Jeffrey Epstein; isn't that correct? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. And once the girls were inside the bedroom 16 Jeffrey Epstein said that he can take care of the rest, 17 correct? 18 Y. PIKE: Form. 19 A. I refuse to answer. 20 Q. And the underage minor female would show up at 21 the house and be greeted at the door by either 22 yourself, the house manager, or correct? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. Many of these underage minor females including 0047 1 my three clients, LM, EW, and Jane Doe you met 2 personally, right? 3 A. I refuse to answer. 4 MR. PIKE: Form. Q. And then you would lead them upstairs to his 6 bedroom. and leave him alone in the bedroom, leave my 7 client alone in the bedroom? 8 MR. PIKE: Form. 9 A. I refuse to answer. 10 Q. And let's take LM, and she went there many 11 times between the ages of 13 and 16. If she was Laken 12 up to his bedroom she would be left alone in the 13 bedroom until Jeffrey Epstein arrived, correct? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. And Jeffrey Epstein would appear usually naked 17 and order for her to take her clothes off? 3524-006 Page23of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009270 EFTA00159272
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18 A. I refuse to answer. 19 MR. PIKE: Form. 20 Q. And Chen Mr. Epstein would lay face down on 21 the massage table would usually be the next step, 22 correct? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. And you know this ritual because at some point. 0048 1 in Lime Jeffrey Epstein showed you exactly what he does 2 with each of these girls in the bedroom, correct? 3 MR. PIKE: Form. 4 A. I refuse Lo answer. 5 Q. So after about -- he would order the underage 6 minor female to begin massaging him, correct? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. And then he would roll over and begin to lO masturbate with his right hand, correct? 11 A. I refuse to answer. 12 Q. And then he would begin also grabbing the 13 breasts, buttocks, and vagina area of these underage 14 minor females, correct? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. And his ritual was so specific that. with each 18 of them he would demand that they pinch his nipples 19 very hard, right? 20 MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. That's a fetish that you know that. Jeffrey 23 Epstein has, right, he likes his nipples pinched very 24 hard? 25 MR. PIKE: Form. 0049 1 A. I refuse to answer. 2 Q. And as he's masturbating with one hand and has 3 his other hand groping or inserting his fingers into 4 the underage minor's vagina he's also telling them to 5 pinch his nipples, correct? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. And this continues -- and sometimes this 9 escalates to him using vibrators, correct? 1C MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. And have you seen vibrators in the Palm Beach 13 mansion house? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. And other times he orders to 17 participate in these encounters with underage minor 18 females; is that correct? 19 A. I refuse to answer. 3524-006 Page24of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009271 EFTA00159273
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20 Q. Are you familiar with 21 strapping on dildos to have sex with these underage 22 minor females? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. And when would have sex with 0050 1 the underage minor females Jeffrey Epstein would watch 2 and continue to ejac -- continue to masturbate, 3 correct? 4 MR. PIKE: Form. 5 A. I refuse to answer. 6 Q. Has he ever asked you to participate in these 7 threesomes with underage minor females? 8 A. I refuse to answer. 9 MR. PIKE: Form. 10 Q. Have you ever participated in sex with 11 underage minor females al the direction of Jeffrey 12 Epstein? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. The -- this whole experience that I am. 16 explaining right now is identical every single time 17 with these underage minor females; isn't that your 18 understanding? 19 MR. PIKE: Form. 2C A. I refuse to answer. 21 Q. And this whole experience is what he has 22 taught you and the other employees to call a •massage", 23 correct? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0051 1 Q. And it always ends with him ejaculating? 2 A. I refuse to answer. 3 MR. PIKE: Form. 4 Q. And then he offers 200 to $300 cash to the 5 underage minor female, correct? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. And then he also gives them another another 9 option to make money which is each Lime you come to my 10 house and we engage In this sexual interaction I will 11 give you $200, but each female you bring me like you, 12 between the age range of 12 and 16, I will pay you $200 13 per person. 14 MR. PIKE: Form. 15 Q. Is that_ something you're familiar with? 16 A. I refuse to answer. 17 Q. And LK al that offer was one of the girls who 18 brought him 75 plus underage minor females, correct? 19 MR. PIKE: Form. 2C A. I refuse to answer. 21 Q. And so he's basically created a pyramid of 3524-006 Page 25 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009272 EFTA00159274
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22 underage minor females where the computer system has a 23 thousand of these females ready to come over to work 24 for him? 25 MR. PIKE: Form. 0052 1 A. I refuse to answer. 2 Q. Jo you know what Jeffrey Epstein does for a 3 living? 4 A. I refuse to answer. 5 Q. Does he do anything aside from interacting 6 sexually with underage minor females? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. Do you know how it is that he made his money 10 where he is purported to be a billionaire? 11 A. I refuse to answer. 12 MR. PIKE: Form. 13 Q. Jo you know David Copperfield? 14 A. I refuse to answer. 15 Q. Is David Copperfield somebody that would come 16 into town and interact sexually with underage minor 17 females? 18 A. I refuse to answer. 19 Q. Do you know Martin Nowak? 20 A. I refuse to answer. 21 Q. Is that also somebody that would interact 22 sexually with underage minor females? 23 A. I refuse to answer. 24 Q. Do you know Leslie Wexner? 25 A. I refuse to answer. 0053 1 Q. Is that somebody you've met before? 2 A. I refuse to answer. 3 Q. Has Mr. Epstein himself interacted sexually 4 with Leslie Wexner? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. When Mr. Epstein was being investigated 8 criminally how did you first learn about that? 9 A. I refuse to answer. 10 Q. AL some point in time he was tipped off that 11 his home -- that a search warrant was going to be 12 executed on his home, correct? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. And just a month before the execution of that 16 search warrant -- less than a month before the 17 execution of that search warrant he ordered you to do 18 something with certain evidence, didn't he? 19 MR. PIKE: Form. 20 A. I refuse to answer. 21 Q. In fact, there were aL least three very key 22 computers Lhat contained a lot of the information that 23 I've been asking you about. You're familiar with those 3524-006 Page26of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009273 EFTA00159275
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24 computers that were in his house, correct? 25 MR. PIKE: Form. CC54 1 A. I refuse to answer. 2 Q. And he ordered you to come over and take those 3 computers out of his house, correct? 4 A. I refuse to answer. 5 MR. PIKE: Form. 6 Q. And you could basically take the local 7 database that exposed this criminal enterprise that. 8 I've been talking about dealing with sex with underage 9 minor vehicles -- underage minor females and you could 10 Lake the evidence from his home, correct? 11 MR. PIKE: Form. 12 A. I refuse to answer. 13 Q. And you've seen Lhe material that's on those 14 computers, correct? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. And if I were to look at those computers it 18 would display exactly what I've been describing Co you 19 today, right? 2C MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. And you went to his house with a wale, 23 correct? 24 A. I refuse to answer. 25 M.R. PIKE: Form. 0055 1 Q. There was one other guy with you that helped 2 that assisted you to take these computers from his 3 home; is that right? 4 MR. PIKE: Form. 5 A. I refuse to answer. 6 Q. Where did you take those? 7 A. I refuse to answer. 8 Q. Did you take those -- was it Bill Reilly that 9 went to the home? IC A. I refuse to answer. 11 Q. Do you know who Bill Reilly is? 12 A. I refuse to answer. 13 Q. He's one of the investigators hired by Roy 14 Black to represent Jeffrey Epstein? 15 A. I refuse to answer. 16 Q. Did you Lake those computers ever to your 17 house? 18 A. I refuse to answer. 19 Q. And I guess the house that. I would be talking 20 about is the , have those 21 computers ever been to that house? 22 MR. PIKE: Form. 23 A. I refuse Lo answer. 24 Q. Were you nervous about the fact that you were 25 taking these computers out of the home at a Lime when a 3524-006 Page 27 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009274 EFTA00159276
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0056 1 search warrant was imminent? 2 A. I refuse to answer. 3 Q. Did you ever question when you were directed 4 to lake these computers from his home? 5 A. I refuse to answer. 6 Q. Bow much additional money or bonus were you 7 paid to take the computers that we're talking about out 8 of Jeffrey Epstein's house? 9 MR. PIKE: Form. 1C A. I refuse to answer. 11 Q. Would those computers reveal criminal activity 12 of only Jeffrey Epstein or of others? 13 N.R. PIKE: Form. 14 A. I refuse to answer. 15 Q. Did you talk with about the 16 criminal investigation into Jeffrey Epstein and others? 17 A. I refuse to answer. 18 Q. Well, at some point in Lime what's been marked 19 as Defense Exhibit 1, you received a Grand Jury 20 investigation target letter, correct? 21 A. I refuse to answer. 22 Q. Well, we have it right. here. I'm familiar 23 with it. I know you got the letter and I know that, 24 you know, the substance of it you're not going to tell 25 me about. But this letter is dated August 31st, 2007, 0057 1 the search warrant was executed on his home back in 2 October of 2005. So during those two years leading up 3 to this target letter who did you talk to? 4 A. I refuse to answer. 5 Q. Did you -- 6 MR. ROSS: And privilege. Attorney-client 7 privilege. 8 Q. Okay. In addition to your attorney did you 9 talk to anybody else about the criminal investigation? 10 A. I refuse to answer. 11 Q. And was your initial computer -- 12 computer -- was your initial attorney in this case, 13 correct? 14 MR. ROSS: You can answer yes or no. 15 A. Yes. 16 Q. Okay. And that_ was an attorney that was hired 17 for you by Jeffrey Epstein? 18 MR. ROSS: Invoke. 19 A. I refuse to answer. 20 Q. Someone that was paid for by Jeffrey Epstein 21 Lo represent you? 22 n. PIKE: Form. 23 A. I refuse to answer. 24 Q. So once he hired you a criminal attorney then 25 it seemed like you did something wrong? 0058 1 KR. PIKE: Form. 3524-006 Page28of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009275 EFTA00159277
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2 A. I refuse to answer. 3 Q. You hadn't actually gone into any relationship 4 with Jeffrey Epstein with the intent Lo commit crimes, 5 did you? 6 A. I refuse to answer. 7 Q. You didn't know that he was a child molester 8 when you first met him, did you? 9 MR. PIKE: Form. 10 A. I refuse to answer. 11 Q. Were you impressed by his money and his 12 lifestyle? 13 A. I refuse to answer. 14 Q. Did you think that he could get you further in 15 life if you would just listen to what he said? 16 MR. PIKE: Form. 17 A. I refuse to answer. 18 Q. AL this point in time you have no contact with 19 him as a child molester, do you? 20 M.R. PIKE: Form. 21 A. I refuse to answer. 22 Q. Did Jeffrey Epstein assist in getting you a 23 visa? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0059 1 Q. Has he done any favors for your family? 2 A. I refuse to answer. 3 MR. PIKE: Form. 4 Q. Is he paying for your college? 5 A. I refuse to answer. 6 MR. PIKE: Form. 7 Q. Right now is he paying for your college? 8 MR. ROSS: Invoke. 9 A. I refuse to answer. 10 MR. PIKE: Form. 11 Q. Did Jeffrey Epstein ever talk to you about the 12 chances of him going to prison? 13 A. I refuse to answer. 14 MR. PIKE: Form. 15 Q. Did Jeffrey Epstein ever talk to you about 16 what he intended his defenses Lo be to the criminal 17 actions he committed against these underage minors? 18 A. I refuse to answer. 19 MR. PIKE: Form. 20 Q. Did he tell you that he would spend as much 21 money as possible to intimidate and harass these 22 underage minor victims? 23 A. I refuse to answer. 24 MR. PIKE: Form. 25 Q. Did he tell you that he would destroy their 0060 1 credibility? 2 A. I refuse to answer. 3 Q. Did he tell you that. he could scare them to go 3524-006 Page29of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009276 EFTA00159278
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4 away? 5 A. 1 refuse to answer. 6 MR. PIKE: Form and form to the last question. 7 MR. EDWARDS: All right. Let's see, what did 8 I say, I said this was -- 9 MR. ROSS: 1. IC MR. EDWARDS: -- Plaintiff's 1 and we're going 11 to write on the back of it and then -- okay. 12 Q. Jeffrey Epstein kept message pads near all of 13 his phones in his home, right? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 O. And those are message pads that have a carbon 17 copy back side to them, you're familiar with them? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. And this is for anybody who lakes a message 21 they write it down that somebody called, the reason for 22 calling, the time that they called? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. And many a times anytime that Jeffrey Epstein 0061 1 was in town there were at least two scheduled 2 "massages" for lack of a better word, with Jeffrey 3 Epstein and these underage minor females, correct? 4 A. I refuse to answer. 5 MR. PIKE: Form. 6 Q. And do you have the -- and there was a 7 particular scheduling book that contained these 8 appointments with -- between Jeffrey Epstein and 9 underage minor females, correct? 10 MR. PIKE: Form. 11 A. I refuse to answer. 12 O. And it was your primary responsibility Co 13 assist in setting these appointments up, 14 right? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. IL Look at least two or three full-Lime 18 employees to keep up with Jeffrey EpsLein's addiction 19 to underage minors, correct? 20 A. I refuse to answer. 21 MR. PIKE: Form. 22 Q. Lesley Groff did pretty much the same thing up 23 in New York, right? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0062 1 Q. And you're familiar that there is this group 2 of girls in New York that were summoned to his home for 3 generally the exact same thing as the Palm Beach girls? 4 A. I refuse to answer. 5 Q. All right. 3524-006 Page 30 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009277 EFTA00159279
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6 MR. PIKE: Form. 7 Q. I'm going to show you an exhibit here, we'll 8 mark it as -- you know what, it's a bunch of message 9 pads, I'm going to mark it as 2A, -B, -C, -D, whatever. IC So we'll say 2A. 11 (Whereupon, Plaintiff's Exhibit 2A through 2H 12 were marked for identification.) 13 Q. DO you recognize it? 14 A. I refuse to answer. 15 Q. Okay. 16 MR. PIKE: May I see that? 17 MR. EDWARDS: Sure. 18 Q. Do you recognize the handwriting on it? 19 A. I refuse to answer. 20 Q. IL indicates hasn't confirmed 21 for 11 yet, so she is keeping on hold in case 22 doesn't call back." 23 What does that message mean? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0063 1 Q. an underage minor female that Jeffrey 2 Epstein was going to molest at 11:00, correct? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. And if wasn't available then ou had 6 another underage minor female named that could 7 step in her place and fulfill that role for Jeffrey 8 Epstein, correct? 9 MR. PIKE: Form. 10 A. I refuse to answer. 11 Q. All right. 2B is another message pad and I'm 12 going to -- we'll stop skipping the process of moving 13 this on and I'm assuming you're not going to be able to 14 answer as to whether or not you -- you recognize that 15 either, right? 16 A. I refuse to answer. 17 Q. Okay. This is a message from 9/4/05, so 18 September 4th 2005, 7:25 p.m. saying "- 19 cancelled She would like to speak Lo you I 20 believe about college," and a telephone number. And 21 then a question from. you, "Should I schedule anyone 22 else?' what did that message mean? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. That another typical ploy of Kr. Epstein's, 0064 that. he would promise these girls something in order to 2 get them to allow him to sexually abuse them? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. Because he certainly did not want them. to tell 6 the police, correct? 7 A. I refuse to answer. 3524-006 Page 31 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009278 EFTA00159280
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8 Q. And did you have many meetings about what to 9 do if any of these girls told the police? IC A. I refuse Lo answer. 11 MR. PIKE: Form. 12 Q. Was it always known that Jeffrey Epstein would 13 hire everyone attorneys and tell everyone just not to 14 talk? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. And at the same time then he could employ a 18 bunch of investigators, dig up a bunch of dirt on these 19 girls, and intimidate them and scare them to go away, 2C correct? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. And Jeffrey Epstein doesn't like -- he didn't 24 like any of these underage minor females, right? 25 MR. PIKE: Form. 0065 1 A. I refuse to answer. 2 Q. In fact, it was the opposite, he liked Co hurt 3 them; isn't that. true? 4 MR. PIKE: Form. 5 A. I refuse to answer. 6 Q. And after they came forward if they told the 7 truth he was dead set on hurting them even more, 8 correct? 9 MR. PIKE: Form. 10 A. I refuse to answer. 11 Q. And that's also a feeling that. Ghislaine 12 Maxwell shared as well, correct? 13 A. I refuse to answer. 14 Q. And that's something that she also told you, 15 •Don't worry. If we get caught we have it covered and 16 we'll just attack these little girls.• 17 MR. PIKE: Form. 18 A. I refuse to answer. 19 Q. All right. There's another message from 2C 9/1C/C5. says confirmed for 4 p.m-" 21 Can you tell us what that. message means? 22 MR. PIKE: Form. 23 A. I refuse to answer. 24 Q. IL's another underage minor female that 25 Jeffrey Epstein's going to molest. at 4 p.m., correct? 0066 1 A. I refuse to answer. 2 Q. And when I say "molest.", you know, he may say 3 "massage", I mean, that's -- that's something 4 interchangeable, right? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. IL's the routine that I described in detail 8 that is identical with every single girl every single 9 time, correct? 3524-006 Page 32 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009279 EFTA00159281
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le A. I refuse to answer. 11 Q. And it's basically as far as he can get with 12 this underage minor female without her crying or 13 screaming or running out of the house? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. Did you ever see any of the girls cry or 17 scream or run out of the house? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. Did you have a personal relationship with any 21 of Lhese underage minor females? 22 A. I refuse to answer. 23 Q. There's another message here from 9/10/05, 24 same day later in the day, IC p.m. saying will 25 be at 11. Do you want me to cancel • 0067 1 Do you know what that message means? 2 MR. PIKE: Form. 3 A. I refuse to answer. 4 Q. What. is this? 5 There's another message from 9/11/05 saying "I 6 got a car for," and then the name is blotted out. The 7 State Attorney's Office blotted the names of minors out 8 sometimes in their file. So do you -- do you know -- 9 can you fill in that blank? 10 A. I refuse to answer. 11 Q. Do you know if this was the car that he rented 12 for Jane Doe 4? 13 A. I refuse to answer. 14 Q. All right. Or the car that he rented for AK? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. You're familiar with both of those people, 18 right? 19 A. I refuse to answer. 20 Q. In fact, Ai was somebody that. was over at 21 Jeffrey Epstein's house many times, correct? 22 A. I refuse to answer. 23 MR. PIKE: Form. 24 Q. 9/3/2005. Message from saying "I left. 25 message for to confirm for 11 a.m. and 0068 1 for 4:30 p.m." 2 Do you remember leaving that message? 3 A. I refuse to answer. 4 Q. And this is -- 5 MR. PIKE: Form. 6 Q. It's his typical schedule where he schedules 7 one underage minor female to molest in the morning and 8 one in the afternoon, correct? 9 MR. PIKE: Form. IC A. I refuse to answer. 11 Q. I mean, considering this is -- have you ever 3524-006 Page33of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009280 EFTA00159282
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12 worked anywhere else where there is somebody sexually 13 molesting underage minor females on a daily basis like 14 this? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. At sore point in time did you tell your 18 parents that this was happening? 19 MR. PIKE: Form. 20 A. I refuse to answer. 21 Q. Did you ever talk to anybody else in the house 22 and say "Hey, look, this is not right•? 23 A. I refuse to answer. 24 Q. Do you feel sorry for these girls? 25 A. I refuse to answer. 0069 1 Q. And you say you do or you do not remember AH? 2 A. I refuse to answer. 3 Q. Okay. And do you know what happened up in Lhe 4 bedroom between AH as a minor and Jeffrey Epstein? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. well, this is what she tells police: "She 8 arrived at the house, went upstairs to the bedroom.. 9 She advised she immediately removed her clothing and 10 and Epstein were alread naked in the 11 be room. AH explained that and she 12 had a sexual encounter that included kissing, touching, 13 and oral sex. AH remembered that she climaxed and was 14 removing herself from the massage table. Epstein then 15 turned AH onto her stomach on Lhe massage table and 16 inserted his penis into her vagina. AH stated Epstein 17 began to pump his penis in her vagina. AH became upset 18 over this. She said her head was being held forcibly 19 against the bed as he continued to pump inside her. 20 She screamed 'No,' and Epstein stopped. He would 21 normally pay her $200, but for this he apologized and 22 paid her a thousand dollars for that visit." 23 Are you familiar with that encounter? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0070 1 Q. Do you remember a time when AH as a 2 16-year-old I believe at this time left her house -- 3 left the house visibly upset? 4 MR. PIKE: Form. 5 A. I refuse to answer. 6 7 8 9 MR. PIKE: Form. IC A. I refuse to answer. 11 Q. These message pads were message pads that were 12 taken from trash pulls outside of Jeffrey Epstein's 13 home and for the most_ -- well, there's so many messages 3524-006 Page 34 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009281 EFTA00159283
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14 here, but most. of them are by somebody other than 15 yourself. So my question is who are the other people 16 that would take messages for Jeffrey Epstein for 17 underage minor females to come to the house? 18 MR. PIKE: Form. 19 A. I refuse to answer. 2C Q. And the messages include CL, 'Can I come work 21 today?" 22 what. does "work" mean? 23 A. I refuse to answer. 24 M.R. PIKE: Form. 25 Q. That means come to your house and get paid for C071 1 Jeffrey Epstein sexually molesting this person while 2 she was underage; is that correct? 3 A. I refuse to answer. 4 MR. PIKE: Form. 5 Q. And it was also pretty frequent that the girls 6 would come in tandem, isn't that true, two at a time? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. And one being the girl that would bring the IC new girl there, would wait downstairs while the new 11 girl was upstairs getting molested but then getting 12 paid? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. How did Jeffrey Epstein explain himself to you 16 as to why he did this? 17 MR. PIKE: Form. 18 A. I refuse to answer. 19 Q. Do you know when it is that he first. became 20 sexually obsessed with underage minor females? 21 MR. PIKE: Asked and answered. 22 A. I refuse to answer. 23 MR. PIKE: Form. 24 Q. Did you know that he was a school teacher at 25 the Dalton School? 0072 1 A. I refuse to answer. 2 Q. And at that point in lime -- well, are you 3 aware of him molesting underage minors while he was a 4 teacher there? 5 A. I refuse to answer. 6 Q. There's another note that's not a message pad 7 which I guess I will -- since it has your name on it I 8 will mark it as what are we on -- 3 -- wail, C -- 9 MR. ROSS: 3. IC MR. EDWARDS: I messed up. 11 MR. ROSS: 3. 12 (Whereupon, Plaintiff's Exhibit 3 was marked 13 for identification.) 14 Q. Look at that while I fix what. I've messed up 15 over here. 3524-006 Page 35 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009282 EFTA00159284
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16 MR. ROSS: I'm going to show this to the 17 witness. 18 MR. EDWARDS: Yes. Yes. 19 Q. Do you recognize that document? 20 A. I refuse to answer. 21 Q. There are a lot of different things on here 22 that don't necessarily relate to you. At least I can't 23 tell that they do. But it does indicate 24 parents are going to the embassy on the 23rd.• 25 Do you remember when that happened? 0073 1 A. I refuse to answer. 2 Q. Why did your parents go to the embassy? 3 A. I refuse to answer. 4 Q. More importantly why was Mr. Epstein concerned 5 that your parents were going to the Embassy? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. Was -- at that point in time was Mr. Epstein 9 assisting your parents with anything? 10 A. I refuse to answer. 11 Q. Are your parents citizens of the United 12 States? 13 MR. ROSS: Form. 14 A. I refuse to answer. 15 Q. Are you? 16 A. No. 17 Q. Has Mr. Epstein ever offered to get you a visa 18 for the United States? 19 A. I refuse to answer. 20 MR. PIKE: Form. 21 Q. Do you know Raer Roshan? 22 A. I refuse to answer. 23 Q. That was Jeffrey Epstein's partner in 24 RadarOnline, correct? 25 A. I refuse to answer. 0074 1 Q. And if I showed you every single message pad 2 here would you be able Lo answer any of the questions 3 about any of the messages that were left at Jeffrey 4 EpsLein's house? 5 A. I refuse to answer. 6 MR. EDWARDS: Okay. That saves us a lot of 7 Lire. 8 MR. ROSS: It did. 9 Q. Have you ever met Bill Clinton? 10 A. I refuse to answer. 11 Q. Is Bill Clinton -- was Bill Clinton a friend 12 of Jeffrey Epstein's? 13 A. I refuse to answer. 14 Q. Is Bill Clinton somebody who Jeffrey Epstein 15 has ever procured underage minor females for? 16 A. I refuse to answer. 17 MR. PIKE: Form. 3524-006 Page 36 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009283 EFTA00159285
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18 Q. And just -- and just for, you know, the sake 19 of what the evidence shows, there's no evidence that I 20 have that indicates that that happened, but. if you were 21 going to answer that. question I'm willing to ask it. 22 Have you met him at Jeffrey Epstein's house in 23 Palm Beach County? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0075 1 Q. You have flown on Jeffrey Epstein's airplanes 2 numerous times, correct? 3 A. I refuse to answer. 4 Q. As well has Bill Clinton and you're aware of 5 that., right? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. Have you ever seen the flight logs from 9 Jeffrey Epstein's airplanes? 10 MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. And on many times it is Bill Clinton, Secret 13 Service agents, Jeffrey Epstein, Ghislaine Maxwell, 14 and others. Have you -- do you know 15 about those flights? 16 A. I refuse to answer. 17 MR. PIKE: Form. 18 Q. And have you ever witnessed sex on any of 19 Jeffrey Epstein's flights? 20 A. I refuse to answer. 21 MR. PIKE: Form. 22 Q. Jo you know 23 A. I refuse to answer. 24 Q. Is that somebody that is Ghislaine Maxwell's 25 sex slave? 0076 1 A. I refuse to answer. 2 Q. And isn't it typical for Jeffrey Epstein to 3 have a sex slave that flies with him on the airplane? 4 A. I refuse to answer. 5 MR. PIKE: Form. 6 Q. And one of the qualifications is that the 7 section slave be underage, correct? 8 MR. PIKE: Form. 9 A. I refuse to answer. 10 Q. And if the sex slave is 15 years old isn't it 11 your understanding and based on your observations that 12 he will even make them dress as if they're 11 or 12? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 MR. PIKE: Form. 16 Q. Jo you know President Andres Pastrana? 17 A. I refuse to answer. 18 Q. Jo you know him as somebody who has had sex 19 with underage minor females brought to him by Jeffrey 3524-006 Page 37 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009284 EFTA00159286
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20 Epstein? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. Have you ever heard of Ehud Burak? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0077 1 Q. Is that another person that Epstein -- Jeffrey 2 Epstein procures underage minor females for? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. You've met Naomi Campbell I'm assuming? 6 A. I refuse to answer. 7 Q. Anytime separate and apart from any dealings 8 with Jeffrey Epstein have you met her in the modeling 9 industry? That's a model, right? 10 MR. PIKE: Form. 11 MR. ROSS: You can answer the question. 12 A. No, I have not. 13 Q. Okay. Do you know Todd Meister? 14 A. I refuse to answer. 15 Q. Joel Pashcow? 16 A. I refuse to answer. 17 Q. You've been to their houses? 18 A. I refuse to answer. 19 Q. Do you know Aline Weber? 2C A. I refuse to answer. 21 Q. Have you ever stayed at the 301 East 66th 22 Street places with Aline Weber? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. And typically aren't there al least 16 0078 1 underage minor females staying at those various 2 condominiums located at 301 East 66th Street? 3 A. I refuse to answer. 4 Q. And those females get work visas to say that 5 they're models, but actually they are prostituted out 6 by Jeffrey Epstein and John Luc Brunel, correct? 7 A. I refuse to answer. 8 MR. PIKE: Form. 9 Q. And various businessmen and politicians around 10 New York and Washington, J.C. go to those apartments 11 frequently to have sex with underage minors; is chat 12 true? 13 A. I refuse to answer. 14 Q. Do you remember a flight. on December 3rd, 2004 15 that ou took with Jeffrey Epstein, 16 and somebody with initials SH -- 17 A. I refuse to answer. 18 Q. -- from JFK to FBI? 19 MR. PIKE: Form. 20 Q. Do you remember that? 21 A. I refuse to answer. 3524-006 Page38of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009285 EFTA00159287
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22 23 24 25 0079 1 2 3 4 5 6 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0080 1 2 3 4 5 6 7 B 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Q. Who is SH? A. I refuse to answer. Q. Is that an underage minor? A. I refuse to answer. Q. Do you remember a December 27th with Epstein? A. Q. A. Q. A. Q. A. flight that you Look and Jeffrey I refuse to answer. What airport is this, TIST? I refuse to answer. Do you know Doug Band? I refuse to answer. Isn't that Bill Clinton's assistant? I refuse to answer. Q. You've been on the airplane with him before? A. I refuse to answer. Q. Have you been on the airplane with Bill Clinton before? A. I refuse to answer. Q. Who is A. I refuse to answer. Q. That's somebody you've flown with on Jeffrey Epstein's plane on numerous occasions, correct? MR. PIKE: Form. A. I refuse to answer. Q. In fact, during the year 2005 you flew on Jeffrey Epstein's plane would you say more than 50 limes? A. I refuse to answer. MR. PIKE: Form. Q. And you flew to his island, right? A. I refuse to answer. MR. PIKE: Form. Q. You flew to New Mexico? A. I refuse to answer. MR. PIKE: Form. Q. You flew to New Jersey? MR. PIKE: Form. A. I refuse Lo answer. Q. Several of the flights are just yourself, Jeffrey Epstein, and What did you do on those flights? MR. PIKE: Form. A. I refuse to answer. Q. Who's Adam Perrylang? A. I refuse Lo answer. Q. Is that somebody that you were made to have sex with? A. I refuse to answer. Q. Did Jeffrey Epstein ever make you have sex with any females? MR. PIKE: Form. 3524-006 Page 39 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009286 EFTA00159288
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24 A. I refuse to answer. 25 Q. Did he ever make you have sex with any of his 0081 1 friends? 2 MR. PIKE: Form. 3 A. I refuse to answer. 4 Q. Who is Sandy Berger? 5 A. I refuse to answer. 6 Q. That's somebody else that was affiliated with 7 Bill Clinton at one point in Lime, correct? 8 A. I refuse to answer. 9 Q. A close friend of Jeffrey Epstein's? lO MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. He called the house within three weeks of the 13 search warrant being executed. Did he tip off Jeffrey 14 Epstein? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. Is he somebody that's involved with underage 18 minors? 19 A. I refuse to answer. 20 Q. Do you know Igor Zinoviev? 21 A. I refuse to answer. 22 Q. Andrea Metrovich? 23 A. I refuse to answer. 24 Q. Have you flown on the airplane with Alan 25 Dershowitz before? 0082 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. And Jean Luc Brunel is somebody who you have 4 been on the airplane with several Limes, correct? 5 A. I refuse to answer. 6 MR. PIKE: Form. 7 Q. And when Jean Luc Brunel is on this airplane 8 there are underage minor -- minor females on the 9 airplane with you, correct? IC MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. Is there a back room to this airplane? Is 13 there any sort of separation or is it all one big room? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. So if Jeffrey Epstein and Jean Luc Brunel are 17 engaged in sex acts with underage minors did you -- 18 A. I refuse -- 19 Q. Sorry -- did you observe any of those acts? 20 A. I refuse to answer. 21 MR. PIKE: Form. 22 Q. And on numerous of the flights the flight logs 23 indicate someone's name then oftentimes initials, but 24 sometimes it would lust say "three females". Do you 25 know why? 3524-006 Page40of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009287 EFTA00159289