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0083 1 A. I refuse to answer. 2 MR. PIKE: Form. 3 Q. Who's 4 A. I refuse to answer. 5 Q. Do you know 6 A. I refuse to answer. 7 Q. They're the house managers up at the mansion 8 up in Manhattan, correct? 9 MR. PIKE: Form. 1C A. I refuse to answer. 11 Q. And they assist Mr. Epstein in engaging in 12 underage sex with minors in New York, correct? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. They also maintain a pretty close relationship 16 with the police? 17 A. I refuse to answer. 18 Q. And that's a big component also, right, Chat 19 Jeffrey Epstein has -- is friendly with the law 20 enforcement, correct? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. Like law enforcement would do favors for not 24 only Jeffrey Epstein but his various assistants. If 25 you were speeding around the neighborhood they wouldn't 0084 give you a ticket, correct? 2 MR. PIKE: Form. 3 A. I refuse to answer. 4 Q. Was it ever your job to call the police 5 department and ask if any police reports were on file 6 or anybody complained about the activities at Jeffrey 7 Epstein's house? 8 MR. PIKE: Form. 9 A. I refuse to answer. 1C Q. Have you ever gone physically to the police 11 department? 12 A. I refuse to answer. 13 Q. Was there a flight where you flew alone with 14 Jean Luc Brunel? 15 A. I refuse to answer. 16 Q. Have you ever flown on the plane with Prince 17 Andrew? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. Do you know 21 A. I refuse to answer. 22 Q. That's another model that Jeffrey Epstein 23 knows, correct? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0085 1 Q. Somebody that he had engaged in sex with when 3524-006 Page4lof68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009288 EFTA00159290
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2 she was underage? 3 A. I refuse to answer. 4 Q. She actually got a modeling contract out of 5 it? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. Why does Jean Luc Brunel and Jeffrey Epstein 9 fly together so often? 10 MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. And why does Ghislaine Maxwell also fly so 13 often with Jeffrey Epstein and Jean Luc Brunel? 14 A. I refuse to answer. 15 MR. PIKE: Form. 16 Q. Isn't it true that all three of them are 17 obsessed and addicted to sex with underage minors? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 MR. PIKE: Brad, how much longer do you have? 21 MR. EDWARDS: How long? You want to take a 22 break? 23 MR. PIKE: Yeah. 24 MR. EDWARDS: Sure. It's going a lot faster 25 than I thought it would. 0086 1 VIDEOGRAPHER: Off the record, 11:33 a.m. 2 (Recess Laken al 11:33 a.m.) 3 (Deposition resumed al 11:43 a.m..) 4 VIDEOGRAPHER: On the record, 11:43 a.m.. 5 BY MR. EDWARDS: 6 Q. All right. There's one more message that I 7 wanted to ask you about. As I mentioned, I'm not going 8 to go through all of the messages that I have, but 9 there's one from 9/4/2005, 9:08 a.m. from "Is 10 it okay for stop by and drop something?" 11 A. I refuse to answer. 12 MR. PIKE: Form. 13 Q. So what were your hours working for Jeffrey 14 Epstein? 15 A. I refuse to answer. 16 Q. I mean, some of these messages are 9:00 in the 17 morning and others are as late as 8:30 or 9 at night. 18 So what. were your hours? 19 A. I refuse to answer. 20 Another message from 9/4 also, same day, 21 " I think, "confirmed an 11 a.m., is at 22 11104.." 23 MR. KERMELSTEIN: I chink that's one you did. 24 MR. EDWARDS: Oh, yeah? Okay. 25 Q. All right.. Do you remember that message? 0087 1 A. I refuse to answer. 2 MR. EDWARDS: Do you care how I attach it 3 since it's -- 3524-006 Page 42 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009289 EFTA00159291
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4 MR. ROSS: No. 5 MR. EDWARDS: I'll attach it as whatever it 6 is. 7 MR. ROSS: 4. 8 MR. EDWARDS: 2 -- well, I'll just go 2H since 9 it's a message. You don't have a problem with IC that? 2H? 11 MR. ROSS: whatever. 12 (Whereupon, Plaintiff's Exhibit 2H was marked 13 for identification.) 14 Q. Do you still consider Jeffrey Epstein a 15 friend? 16 A. I refuse to answer. 17 MR. PIKE: Form. 18 Q. Did you ever think of Jeffrey Epstein as a 19 friend? 20 MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. Other than the people that I've mentioned 23 of -- you know, President Pastrana and Ehud Burak and 24 Prince Andrew did you meet any other people of royalty 25 being friends with Jeffrey Epstein? 0088 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. Can you Lell us any of the other folks that 4 Jeffrey Epstein would supply underage minor girls to? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. Do you know a man by the name of Glenn Dubin? 8 A. I refuse Lo answer. 9 Q. Do you know his wife? 10 A. I refuse to answer. 11 Q. His wife at some point in time was associated 12 with Jeffrey Epstein; is that correct? 13 A. I refuse to answer. 14 Q. And her name's Eva Dubin; is that right? 15 A. I refuse to answer. 16 Q. Either way, isn't it true that Jeffrey Epstein 17 then started supplying underage females to Glenn Dubin? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. Do you know 21 A. I refuse to answer. 22 Q. Is that somebody who also worked for Jeffrey 23 Epstein? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0089 1 Q. Did Jeffrey Epstein ever get a legitimate 2 massage from somebody that's a masseuse? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. the underage females that we've talked about 3524-006 Page43of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009290 EFTA00159292
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6 particularly, LM, EW, and Jane Doe, those girls were 7 not prostitutes, were they? 8 A. I refuse to answer. 9 Q. These were just girls who were in 8th, 9th, IC 10th grade in high school, right? 11 A. I refuse to answer. 12 Q. These were girls that you knew had never 13 committed prostitution in the past, right? 14 A. I refuse to answer. 15 Q. And that goes for all of these girls on the 16 phone list of underage minors to call, these were not 17 prostitutes, correct? 18 A. I refuse to answer. 19 Q. You never called a prostitution or escort 20 service for Jeffrey Epstein, did you? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. And as well you never called a legitimate 24 massage parlor for Jeffrey Epstein, correct? 25 A. I refuse to answer. 0090 1 MR. PIKE: Form. 2 Q. He devised this scheme of having underage 3 minor girls bring him other underage minor girls so 4 that he could gain access to his target age group, 12 5 to 16 years old, correct? 6 A. I refuse to answer. 7 Q. Have you heard Jeffrey Epstein say "The 8 younger the better?" 9 A. I refuse to answer. 10 Q. And did Jeffrey Epstein tell you that it made 11 him happy the younger the girl was? 12 A. I refuse to answer. 13 MR. PIKE: Form. 14 Q. The less developed the girl is the more 15 excited Jeffrey Epstein gets; is that true? 16 MR. PIKE: Form. 17 A. I refuse to answer. 18 Q. Do you ever plan to talk to Jeffrey Epstein in 19 the future? 20 A. I refuse to answer. 21 M.R. PIKE: Form. 22 Q. Would you ever work for him again? 23 A. I refuse to answer. 24 Q. why didn't you stop working for him sooner? 25 A. I refuse to answer. 0091 1 MR. PIKE: Form. 2 Q. Did you -- well, you knew that it was illegal 3 what he was doing at the time you were doing it, 4 correct? 5 A. I refuse to answer. 6 Q. Did you know that you were part of a large 7 child molestation ring? 3524-006 Page44of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009291 EFTA00159293
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8 MR. PIKE: Form. 9 A. I refuse to answer. IC Q. Did you ever cell anyone while you were 11 working for him. that. you wanted to stop? 12 A. I refuse to answer. 13 MR. PIKE: Form. 14 Q. Did you continue working there because you 15 were just scared to stop? 16 A. I refuse to answer. 17 MR. PIKE: Form. 18 Q. Were you in fear of what. Ghislaine Maxwell or 19 Jeffrey Epstein might do to you if you quit performing 2C your services for his child molestation ring? 21 A. I refuse to answer. 22 MR. PIKE: Form. 23 Q. Did Jeffrey Epstein ever threaten you? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0092 1 Did Ghislaine Maxwell 2 I refuse to answer. 3 How was it decided who would 4 I refuse to answer. 5 Q. And by that, just so it's clear, like I said, 6 there's going to be many, many, many message pads, I 7 have not counted them, but a for rraalad air ha 8 yourself or someone named 9 10 11 employed at Jeffrey Epstein's home. And it seems that 12 13 14 15 16 17 18 19 2C 21 22 23 24 25 0093 1 A. I refuse to answer. 2 Q. And isn't part of the whole scheme that these 3 girls were typically told "Don't tell anybody what. goes 4 on inside this house," right? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. And did Jeffrey Epstein tell you that because 8 these girls are young and they're poor and they're 9 underprivileged type girls they're likely not going to Q. A. Q. A. ever threaten you? call which girl? Various people now to have been on one particular day may call several girls, Who is directing which assistants is going to call the underage minor to give them an appointment? A. I refuse to answer. MR. PIKE: Form. Q. And what would happen on the occasions where Jeffrey Epstein says he's going to be in town and then he's ultimately not in town but a girl shows up anyway? MR. PIKE: Form. A. I refuse to answer. Q. Weren't you just told just to pay her to keep her happy? y call several girls, you may call several girls. h of you, which of the 3524-006 Page 45 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009292 EFTA00159294
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le say anything anyway? Isn't that what he told you? 11 MR. PIKE: Form. 12 A. I refuse to answer. 13 Q. Did Ghislaine Maxwell talk to you about that 14 as well? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. Have you seen Jeffrey Epstein angry? 18 A. I refuse to answer. 19 Q. Isn't it true that he's very nice and engaging 2C as long as he gets his way and gets you to cooperate, 21 right? 22 A. I refuse to answer. 23 Q. But if he doesn't get his way he gets very, 24 very angry and mad and scary; isn't that true? 25 A. I refuse to answer. 0094 1 Q. And you've seen both sides of him, right? 2 A. I refuse to answer. 3 Q. In fact, you know of girls who were 13 years 4 old and cooperated with everything he said because they 5 felt they had no choice up in that bedroom, right? 6 A. I refuse to answer. 7 MR. PIKE: Form. 8 Q. And you also know girls who resisted and were 9 yelled at and told Lo grab their money and get out of 10 there, right? 11 A. I refuse to answer. 12 Q. Wouldn't you agree Chat that house upstairs 13 can be somewhat confusing in how it's -- how it's laid 14 out? 15 A. I refuse to answer. 16 Q. In fact, there's a stairwell that starts from 17 the kitchen, there's a door and it almost blends in in 18 the kitchen with the other closets, correct? 19 A. I refuse to answer. 20 MR. PIKE: Form. 21 Q. But you open that door and there's a stairway 22 that twists it seems to the left and there's another 23 door at the Lop of that stairway, right? 24 A. I refuse Lo answer. 25 Q. And then when you exit that stairway you take 0095 1 a right and you head towards a little hallway that 2 eventually leads into Mr. Epsteln's bedroom, right? 3 A. I refuse to answer. 4 Q. And if it's your first. Lima in that bedroom. as 5 a 14-year-old girl and you don't like what's happened 6 up there would you agree that it's a Lough way to find 7 your -- a place to find your way out of? 8 MR. PIKE: Form. 9 A. I refuse to answer. IC Q. Did Jeffrey -- didn't Jeffrey Epstein tell you 11 that he would act as a father-type figure to these 3524-006 Page46of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009293 EFTA00159295
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12 girls? 13 A. I refuse to answer. 14 MR. PIKE: Form. 15 Q. And he would propose that what they are doing 16 for him or with him despite the law is okay? 1? A. I refuse to answer. 18 M.R. PIKE: Form. 19 Q. And they could continue to make a lot of money 20 if they would come over and be his sex victims, right? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. And you were aware when my client, LK, was 24 pregnant at. 16 years old that Jeffrey Epstein bought 25 everything on her baby registry, right? CC96 1 A. I refuse to answer. 2 MR. PIKE: Form. 3 Q. Was it you or that took all of 4 the gifts over to her home? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. I believe it was in a -- did 8 Jeffrey Epstein own a Mercedes? 9 MR. PIKE: Form. 10 A. I refuse to answer. 11 Q. And do you remember when loaded 12 up the Mercedes with all the baby gifts and Look it. to 13 my client's trailer? 14 A. I refuse to answer. 15 Q. And that was so that while LM that was to 16 thank her while she was pregnant she continued to bring 17 him 13-, 14-, and 15-year-old girls to molest, correct? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. Because LM would no longer qualify as somebody 21 he'd be sexually interacting with as she was pregnant, 22 correct? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. Because Lhe only real disqualifications for 0097 1 interacting sexually with Mr. Epstein are if you have 2 tattoos, right? 3 A. I refuse to answer. 4 Q. If you're African-American or black? 5 A. I refuse to answer. 6 O. You've never known him to interact with an 7 African-American or black girl, have you? 8 A. I refuse to answer. 9 Q. If you've been pregnant? IC A. I refuse to answer. 11 Q. Or if you are pregnant, correct? 12 A. I refuse to answer. 13 Q. But certainly he was not above having a 3524-006 Page47of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009294 EFTA00159296
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14 pregnant 16-year-old girl bringing him underage minor 15 females, correct? 16 A. I refuse to answer. 17 Q. In fact -- 18 MR. PIKE: Form. 19 Q. -- it was his belief that he was doing her a 20 favor in that he was giving her money for providing a 21 service, correct? 22 MR. PIKE: Form. 23 A. I refuse to answer. 24 Q. Is it Jeffrey Epstein's belief that he did 25 these girls a favor? CO9S 1 A. I refuse to answer. 2 Q. I mean, doesn't he think that these girls are 3 lucky that he ever -- that. Lhey ever -- that he ever 4 allowed them out of their trailer and into his mansion, 5 correct? 6 A. I refuse to answer. 7 MR. PIKE: Form. 8 Q. We've defined the molestation statute or at 9 least I read it to you earlier and now we've talked 10 about this scheme of Jeffrey Epstein gaining access to 11 this number of underage minor females. At the time 12 when you were working for him did you recognize him as 13 a serial child molester? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. Jo you know of anybody that ever worked for 17 him that quit working for him because of what he was 18 doing? 19 A. I refuse to answer. 20 MR. PIKE: Form. 21 Q. Jo you know Michael Friedman? 22 A. I refuse to answer. 23 Q. Is that somebody you ever met there? 24 A. I refuse to answer. 25 Q. What countries does Jeffrey Epstein typically CC99 bring underage minor females from? 2 A. I refuse Lo answer. 3 Q. Jo you know why he chooses the countries that 4 he chooses to import underage minor females from? 5 A. I refuse to answer. 6 MR. PIKE: Form. 7 Q. Was Nadia -- do you know how old 8 was when she came to this country? 9 refuse Lo answer. 10 Q. Have you had conversations with 11 IIIIIIIplabout Jeffrey Epstein bringin!lig lico this 12 country. 13 A. I refuse to answer. 14 Q. She's been described by some as his 15 Yugoslavian lesbian sex slave. Is that something that. 3524-006 Page48of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009295 EFTA00159297
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16 is an accurate description based on the observations 17 you have? 18 A. I refuse to answer. 19 MR. PIKE: Form. 20 Q. Did ou ever engage in any lesbian sex with 21 22 A. I refuse to answer. 23 Q. Has ever had sex with Jeffrey 24 Epstein? 25 MR. PIKE: Form. 0100 1 A. I refuse to answer. 2 Q. Do you know how it is that met 3 Jeffrey Epstein? 4 A. I refuse to answer. 5 Q. Do you know Story Cowles? 6 A. I refuse to answer. 7 Q. You know who Sergio Cordero is? 8 A. I refuse to answer. 9 Q. Well, that's somebody who also assists 10 Mr. Epstein in bringing him. underage minor females for 11 sex, correct? 12 A. I refuse to answer. 13 MR. PIKE: Form. 14 Q. And Khalid Monroe, you know who that is? 15 A. I refuse to answer. 16 Q. Also somebody Lhat through MC Squared or some 17 affiliation with that modeling agency would help for 18 Jeffrey Epstein to gain access Co underage minor 19 females for sex, correct? 20 MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. And do you know of trips that Kr. Cordero, 23 Mr. Brunel, and Mr. Epstein took to Brazil specifically 24 for the purposes of Mr. Epstein engaging in sex with 25 12-year-old girls? 0101 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. Are you -- you are aware that Jeffrey Epstein 4 pled guilty to two felonies related to his sexual S interactions, correct? 6 A. I refuse to answer. 7 Q. Okay. 8 VIDEOGRAPHER: Excuse me, counsel. 9 MR. ROSS: I object on privilege grounds -- 10 attorney-client privilege grounds. 11 MR. EDWARDS: Okay, fine. I was trying to get 12 into an area we may get answers. 13 VIDEOGRAPHER: Could I just get you to put 14 your phone on the table? I'm. starting to get 15 interference. 16 MR. ROSS: The phone? 17 VIDEOGRAPHER: Yes, sir. 3524-006 Page49of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009296 EFTA00159298
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18 MR. EDWARDS: You got a secret phone? 19 VIDEOGRAPHER: It's anytime it receives any 20 kind of information. 21 MR. ROSS: Oh, okay, yeah, it's -- 22 VIDEOGRAPHER: It's not that it's ringing. 23 MR. ROSS: Right. It's not doing iL now. 24 VIDEOGRAPHER: I apologize for the 25 interruption. 0102 1 Q. All right. I ask you that question because 2 there was also something called a non-prosecution 3 agreement. Are you familiar with that document? 4 A. I refuse to answer. 5 MR. ROSS: Attorney-client privilege. 6 Q. And that is also a document that included your 7 name as a co-conspirator; are you familiar with that? 8 A. I refuse to answer. 9 MR. ROSS: Attorney-client privilege. 10 Q. And that is because of your involvement with 11 calling on the telephone underage minors to bring them 12 to Jeffrey Epstein's house, correct? 13 A. I refuse to answer. 14 Q. Or for your involvement in scheduling 15 appointments in Jeffrey Epstein's appointment book for 16 underage minor -- underage minor females to be involved 17 with Jeffrey Epstein sexually, correct? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. IL is certainly not because you sought out 21 this child molestation ring in hopes of rising to the 22 Lop, correct? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. Didn't you do everything that you did that 0103 1 anybody could ever say is illegal at the direction of 2 Jeffrey Epstein? 3 A. I refuse to answer. 4 Q. And if it wasn't at the direction of Jeffrey 5 Epstein it was at the direction of Ghislaine Maxwell or 6 Sarah Kellen, correct? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. I mean, those things were not things that you 1C would have done but for being under the supervision of 11 Jeffrey Epstein; isn't that right.? 12 MR. PIKE: Form. 13 A. I refuse to answer. 14 Q. And you continued to do these things either 15 out of fear or because you were just impressed with 16 Jeffrey Epstein's lifestyle? 17 A. I refuse to answer. 18 Q. Aren't you angry for him involving you in this 19 criminal activity? 3524-006 Page50of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009297 EFTA00159299
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20 A. I refuse to answer. 21 MR. PIKE: Form. 22 Q. Do you ever intend in the future to talk about 23 what he did and what he involved you in? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0104 1 Q. Wouldn't you like to separate yourself being 2 the person that you are from this person who brought 3 you into this mess? 4 MR. PIKE: Form. 5 A. I refuse to answer. 6 Q. Is Jeffrey Epstein paying for your attorney 7 now? 8 MR. PIKE: Form. 9 A. I refuse to answer. 10 MR. ROSS: Well, actually you can answer. 11 A. No, my parents help me. 12 Q. Are you aware of Jeffrey Epstein's closest 13 friends now? 14 A. I refuse to answer. 15 MR. PIKE: Form. 16 Q. Who are the people that you believe are 17 Jeffrey Epstein's enemies? 18 MR. PIKE: Form. 19 A. I refuse to answer. 2C Q. Did you ever find out. that Jeffrey Epstein and 21 Ghislaine Maxwell had been targeting and preying upon 22 underage females for sex for more than a decade? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. Who is Jeffrey Epstein's girlfriend now, if 0105 1 you know? 2 A. I refuse to answer. 3 MR. PIKE: Form. 4 Q. Since being on house arrest. has Jeffrey 5 Epstein continued to engage in sex with underage minor 6 females? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. Knowing that his habit was more than -- was at IC least two underage minor females for sex every single 11 day do you believe that he stopped? 12 MR. PIKE: Form. 13 A. I refuse to answer. 14 Q. Isn't it your belief that he will continue Lo 15 do that once all of these cases are over? 16 A. I refuse to answer. 17 MR. PIKE: Form. 18 Q. Isn't it true that Jeffrey Epstein believes 19 that he is entitled to have sex with whomever he wants 2C including 12-, 13-, 14-year-old girls? 21 MR. PIKE: Form. 3524-006 Page5lof68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009298 EFTA00159300
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22 A. I refuse to answer. 23 Q. Do you know whether he continues -- do you 24 know whether he intends to continue to molest underage 25 minors within the United States? 0106 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. Do you know Mike Sanka? 4 A. I refuse to answer. 5 Q. That's somebody else that assisted Jeffrey 6 Epstein in gaining access to underage minor females 7 that were foreigners, correct? 8 A. I refuse to answer. 9 MR. PIKE: Form. le Q. He's also involved in the modeling agency, 11 too, correct? 12 MR. PIKE: Form. 13 A. I refuse to answer. 14 Q. That's a friend of or former friend of Jean 15 Luc Brunel's? 16 A. I refuse to answer. 17 Q. How many times has Jean Luc Brunel shown up at 18 Jeffrey Epstein's house with underage minor females? 19 MR. PIKE: Form. 2C A. I refuse to answer. 21 Q. And when that. would happen isn't it true that 22 they would have orgies with these underage minor 23 females? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0107 1 Q. What was done -- or let me ask it a different 2 way. Strike that. 3 Where is the scheduling book for the massage 4 appointments for Jeffrey Epstein? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. Is that something else that was removed from 8 the home prior to the search warrant being executed? 9 A. I refuse to answer. 10 MR. PIKE: Form. 11 Q. DO you know how it is that -- well, did 12 Jeffrey Epstein ever tell you that because of the 13 people he knew he would not be going to prison for the 14 crimes that he committed? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. And is it your understanding that Ken Starr 18 had played a major role in devising the non-prosecution 19 agreement or having the government agree not to 20 prosecute Jeffrey Epstein for his crimes against 21 minors? 22 A. I refuse to answer. 23 MR. PIKE: Form. 3524-006 Page 52 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009299 EFTA00159301
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24 Q. Is it also your understanding that Bill 25 Clinton played somewhat of a role in helping Jeffrey 0108 1 Epstein out of the trouble that he would have been in 2 related to his sexual interactions wiLh minor females? 3 A. I refuse to answer. 4 MR. PIKE: Form. 5 Q. Did Jeffrey Epstein tell you that you need to 6 cooperate if you want the protection that me and my 7 connections can give you for this activity? 8 MR. PIKE: Form. A. I refuse to answer. Q. You admit that you called LE on the telephone for her to come to Jeffrey Epstein's house to be molested by Jeffrey Epstein when she was an underage female? A. I refuse to answer. MR. PIKE: Form. Asked and answered twice. Q. Do you agree that you called EW on the telephone for the purposes of her coming to Jeffrey Epstein's house for him to sexually molest her? MR. PIKE: Sark objection. A. I refuse to answer. Q. And do you agree that you called Jane Doe and told her to come to your house to work, meaning for Jeffrey Epstein to sexually molest her? MR. PIKE: Asked and answered. A. I refuse to answer. 9 10 11 12 13 14 15 16 17 18 19 2C 21 22 23 24 25 0109 1 2 3 4 5 6 7 8 9 IC 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. The first trial that is set in these cases is in July of this year. Do you intend Lo be in the local area? MR. ROSS: You can answer. A. Yes. Q. Okay. And what address will you be at? MR. ROSS: You can answer. A. Q. A. Q. And the ZIP is? A. Q. And I presume that if I needed to find you or locate you or anything else I could go through your attorney? A. Yes. Q. Okay. Who do you live at that address with? MR. ROSS: You can answer. 3524-006 Page53of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009300 EFTA00159302
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9 IC 11 12 13 14 15 16 17 18 19 20 A. 21 Q. She's great. I'm sure she got that. 22 A. Would ou like me to spell it out? 23 second word, 24 25 . 6: ne way to never in a witness 0111 0110 1 2 3 4 5 Q. A.n• ave you to your 6 involvement with Jeffrey Eostein? 7 A. I refuse to answer. 8 Q. Have you told your parents? A. I refuse to answer. Q. Are your parents in the country now? MR. ROSS: You can answer. A. No. Q. Do they have plans to come back? MR. ROSS: You can answer. A. They may visit, I'm not sure. Q. But on a permanent basis they're in A. Yes. Q. Okay. What's the address where they are in I 2 3 is just move to There's no way. MR. ROSS: Couldn't get anyone to type the subpoena. 4 MR. EDWARDS: Right, exactly. All right. I 5 don't have any other questions for you. Thank you. 6 THE WITNESS: Thank you. 7 CROSS-EXAMINATION 8 BY MR. MERMELSTEIN: 9 Q. Okay. Mrs. Ross, I have some questions for 1C you. Your husband, what does he do for a 11 living? 12 13 14 la 16 17 18 19 2C 21 22 23 24 25 Q. And pelieve you testified that you met him 0112 1 in Europe, correct? 3524-006 Page 54 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000930 1 EFTA00159303
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2 3 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0113 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0114 1 A. I refuse to answer. 2 Q. In 2004 and 2005 you were employed by Jeffrey 3 Epstein, correct? A. Correct. Q. And did he have a different employment or profession then? A. Yes. Q. What was he doing then? V. usa ne work ior mt. bguareo. 3524-006 Page 55 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009302 EFTA00159304
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4 MR. PIKE: Form. 5 A. I refuse to answer. 6 Q. And as an employee of Jeffrey Epstein you were 7 under his instruction and supervision, correct? 8 MR. PIKE: Form. 9 A. I refuse to answer. IC MR. PIKE: Let's go off the record for a 11 second. 12 MR. MERMELSTEIN: Sure. 13 VIDEOGRAPHER: Off the record at 12:12 p.m. 14 (Discussion off the record.) 15 MR. MERMELSTEIN: I'll be brief on the general 16 questions. 17 VIDEOGRAPHER: On the record, 12:14 p.m. 18 BY MR. MERMELSTEIN: 19 Q. And as an employee of Jeffrey Epstein were you 20 also subject to the -- to the instructions and 21 supervision of Ghislaine Maxwell? 22 MR. PIKE: Form. 23 A. I refuse to answer. 24 Q. And as an employee of Jeffrey Epstein did you 25 work under the supervision and instruction of his 0115 1 primary assistant 2 MR. PIKE: orm. 3 A. I refuse to answer. 4 Q. Okay. Did Jeffrey Epstein tell you that -- 5 that he recruited from western Palm Beach County 6 underage girls to come to his Palm Beach mansion for 7 sexual activity? 8 MR. PIKE: Form. 9 A. I refuse to answer. 10 Q. And did Jeffrey Epstein have a computer 11 database at his Palm Beach mansion where he listed 12 underage high school girls in Palm. Beach County and 13 their contact information so that he could have these 14 underage minors come to his house for sexual activity? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. And did Jeffrey Epstein tell you that the 18 reason he brought in underage minors from western Palm 19 Beach County is because he anticipated they would be 20 impressed, in awe, and intimidated by his wealth? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. And as young girls who were impressed and in 24 awe and intimidated of his wealth they would do what he 25 asked them to do? 0116 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. And as young underage girls who were 4 impressed, intimidated, and in awe of his wealth they 5 would be unlikely to -- to complain to authorities that 3524-006 Page56of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009303 EFTA00159305
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6 he was engaging in sexual activity with them? 7 A. I refuse to answer. 8 MR. PIKE: Form. 9 Q. Okay. Did Jeffrey Epstein instruct you to IC call girls on the telephone to schedule appointments 11 for Chem to come to his Palm Beach house for massages 12 which were, in fact, to be sexual activity? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. Prior to May 2005 did you call Jane Doe 4 to 16 schedule appointments for her Co come to the Epstein 17 house to engage in -- to give Jeffrey Epstein a massage 18 which would, in fact., be sexual activity with Jeffrey 19 Epstein? 20 MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. Okay. Prior to May 2005 while you were al the 23 Epstein house in Palm Beach did you receive calls from 24 Jane Doe 4 regarding the scheduling of an appointment 25 for her to come to the Epstein house Lo give Jeffrey 0117 1 Epstein a massage? 2 MR. PIKE: Form. 3 A. I refuse to answer. 4 Q. When Jane Doe 7 -- let me strike that. 5 Do you know Jane Doe 7? 6 A. I refuse to answer. 7 Q. When Jane Doe 7 was a minor female did you 8 call Jane Doe 7 Co schedule appointments for her to 9 come to the Epstein house in Palm Beach to give Epstein 10 a massage? 11 MR. PIKE: Form. 12 A. I refuse to answer. 13 Q. When Jane Doe 7 was a minor female did you 14 receive calls from Jane Doe 7 while you were at the 15 Epstein house for her to come to the house by 16 appointment and give Jeffrey Epstein a massage? 17 MR. PIKE: Form. 18 A. I refuse to answer. 19 Q. The computer database that Jeffrey Epstein 20 maintained girls from western Palm. Beach County who 21 would come to the house in Palm Beach Co give Epstein a 22 massage, did that computer database include the name 23 and contact information for Jane Doe 2? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0118 1 O. Do you know who Jane Doe 2 is? 2 A. I refuse to answer. 3 Q. Do you know who Jane Doe 5 is? 4 A. I refuse to answer. 5 Q. Did the computer database that Epstein 6 maintained on his computers in his home have the name 7 and contact information for Jane Doe 5 so that. Epstein 3524-006 Page 57 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009304 EFTA00159306
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8 could contact her for -- for massages in his Palm Beach 9 home? IC MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. Do you know the name Jane Doe 6? 13 A. I refuse to answer. 14 Q. Did the computer database that. Epstein 15 maintained in his home of underage girls who he would 16 have come over for massages and sexual activity did 17 that computer database include the name and contact 18 information for Jane Doe 6? 19 A. I refuse to answer. 2C Q. Do you know the name Jane Doe 3? 21 A. I refuse to answer. 22 Q. Did the computer database that Jeffrey Epstein 23 maintained in his home include the name and contact 24 information of Jane Doe 3 so that he could contact Jane 25 Doe 3 to come to his Palm Beach home and give him a 0119 1 massage which would become sexual activity? 2 A. I refuse to answer. 3 Q. Did the computer database that Jeffrey Epstein 4 maintained in his home include the name Jane Doe 4? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. Do you know Jane Doe 4? 8 A. I refuse to answer. 9 Q. Did the -- did Jeffrey Epstein tell you that 10 he maintained the contact information for Jane Doe 4 in 11 his computer database in his home so that he could 12 contact her to come to his Palm Beach mansion for 13 massages? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. Did you know for a fact that the computer 17 database included the name Jane Doe 4 so that Jeffrey 18 Epstein could contact her and she would come to the 19 Palm Beach mansion to give Jeffrey Epstein a massage? 2C RR. PIKE: Form. 21 A. I refuse to answer. 22 Q. Did you know that the computer database that 23 Jeffrey Epstein maintained his home contained the name 24 and contact information of Jane Doe 7 -- 25 A. I refuse -- sorry. 0120 1 Q. I'm sorry -- so he would contact Jane Doe 7 2 and have her come to his house Lo give him a massage? 3 A. I refuse to answer. 4 Q. Are you aware that the computer database that. 5 Jeffrey Epstein maintained in his home contained the 6 name Jane Doe 8 so that he could contact Jane Doe 8 and 7 have him come to the house in Palm. Beach for purposes 8 of giving him a massage? 9 MR. PIKE: Form. 3524-006 Page58of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009305 EFTA00159307
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IC A. I refuse to answer. 11 Q. You removed three computers from the Palm 12 Beach house with another gentleman prior to Lhe search 13 warrant being issued by the Palm Beach police; isn't 14 that correct? 15 A. I refuse to answer. 16 M.R. PIKE: Form. Asked and answered. 17 Q. And Jeffrey Epstein instructed you to remove 18 those computers; is that correct? 19 MR. PIKE: Form, asked and answered. 2C A. I refuse to answer. 21 Q. And Jeffrey Epstein told you that the reason 22 he was instructing you to remove the computers was Co 23 hide his sexual activities with underage minors from 24 the authorities? 25 MR. PIKE: Form. 0121 1 A. I refuse to answer. 2 Q. As an employee of Jeffrey Epstein did you know 3 Janusz Banaziak? 4 A. I refuse to answer. 5 MR. PIKE: Form. 6 Q. Was Janusz Banaziak also an employee of 7 Jeffrey Epstein? 8 MR. PIKE: Form. 9 A. I refuse to answer. 1C Q. When Janusz Banaziak testified that you and 11 another gentleman removed the three computers from 12 Jeffrey Epstein's home he was telling the truth, 13 correct? 14 A. I refuse to answer. 15 MR. PIKE: Form. 16 Q. Did you observe Jeffrey Epstein persuading, 17 inducing, or enticing underage girls to engage in 18 sexual activities with him? 19 A. I refuse to answer. 2C Q. Did you -- strike that. 21 Did you observe Jeffrey Epstein persuading, 22 inducing, or enticing girls who came to his house for 23 the purpose of giving him a massage to engage in sexual 24 activity with him? 25 MR. PIKE: Form. 0122 1 A. I refuse to answer. 2 Q. Did Jeffrey Epstein tell you that he induced, 3 persuaded, or enticed underage girls to engage in 4 sexual activities with him when they came to his Palm 5 Beach mansion to give him a massage? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. Would you instruct -- when you spoke to 9 underage girls Co schedule appointments for massage in 1C Epstein's home would you instruct these girls to lie 11 about their ages and say they were 18 years old when 3524-006 Page59of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009306 EFTA00159308
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12 you knew that they were younger than 18? 13 A. I refuse to answer. 14 Q. Did Jeffrey Epstein instruct you as to what to 15 say to the girls who you contacted by telephone to make 16 appointments to schedule massages in Epstein's home? 1? A. I refuse to answer. 18 MR. PIKE: Form. 19 Q. And would Jeffrey Epstein tell you to have the 20 girls who you contacted by the telephone to make 21 appointments to come to the mansion to give Jeffrey 22 Epstein massages, that they should -- that these girls 23 should lie about their ages to Jeffrey Epstein? 24 MR. PIKE: Form. 25 A. I refuse to answer. C123 1 Q. Prior to May 2005 are you aware that Jeffrey 2 Epstein had numerous appointments with Jane Doe 4 for 3 her to come Lo the mansion to come to give him a 4 massage? 5 A. I refuse to answer. 6 MR. PIKE: Form. 7 Q. Prior to May 2005 are you aware that Jane Doe 8 4 would come to the mansion to give Jeffrey Epstein a 9 massage on a frequent and regular basis? 1C A. I refuse to answer. 11 MR. PIKE: Form. 12 Q. Are you aware that prior to May 2005 Jeffrey 13 Epstein engaged with -- engaged in sexual activities 14 with Jane Doe 4 al the Palm Beach mansion 50 to a 15 hundred times? 16 A. I refuse to answer. 17 MR. PIKE: Form. 18 Q. Did Jeffrey Epstein admit to you that on 19 numerous occasions he -- when Jane Doe 4 was an 20 underage minor he touched her breasts? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. Did Jeffrey Epstein admit to you that on 24 numerous occasions when Jane Doe 4 was an underage 25 minor he touched and groped her buttocks? 0124 1 A. I refuse to answer. 2 Q. Did Jeffrey Epstein admit to you on numerous 3 occasions when Jane Doe 4 was an underage minor chat he 4 rubbed Jane Doe 4's vagina? 5 A. I refuse to answer. 6 MR. PIKE: Form. 7 Q. Did Jeffrey Epstein admit Lo you that on 8 occasions prior to Jane Doe 4 turning the age of 18 9 that he performed oral sex on Jane Doe 4? IC MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. Did Jeffrey Epstein admit to you that on 13 numerous occasions prior to Jane Doe 4 reaching the age 3524-006 Page60of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009307 EFTA00159309