EFTA00181510

Mark Epstein 
September 21, 2009 
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M. Epstein 
A. I have no idea. I don't know what --
how do you define a good capacity for dealing 
with people? 
People didn't walk around punching 
him in the face, so I guess he dealt with them 
okay. 
Q. Okay. When you were boys together, 
could he talk other boys into doing things? 
Was he a leader? 
MR. COHEN: Objection. 
A. I have no idea. 
How far back in history am I supposed 
to be going with this? 
These are stupid questions. 
MR. COHEN: I know they are, but we 
are almost done. 
Q. Are you saying you can't answer those 
questions? 
MR. COHEN: He has answered them. 
Move on, counsel. 
MS. EZELL: I don't have any others, 
but I didn't hear him answer those questions. 
MR. COHEN: 
Would you like the 
record read back or would you like to read it 
• 
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EFTA00181590

Mark Epstein 
September 21, 2009 
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M. Epstein 
when you get it? 
MS. EZELL: I got what he said. 
Thank you. 
MR. COHEN: Anyone else? 
MR. LANCING: Yes. 
This is Adam Langino, and I represent 
BB. 
THE WITNESS: Fifi? 
MR. COHEN: BB. 
THE WITNESS: I thought he said Fifi 
and it was a dog. 
MR. COHEN: No, they are using 
letters. 
okay? 
MR. LANGINO: Everybody can hear me 
MR. EDWARDS: Yes. 
MR. COHEN: Yes. 
MR. EDWARDS: Got you. 
MR. COHEN: You are coming through 
fine. 
EXAMINATION BY 
MR. LANGINO: 
Q. Was Jeffrey Epstein close to his 
father? 
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EFTA00181591

Mark Epstein 
September 21, 2009 
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M. Epstein 
A. Yes. 
Q. Did you notice any changes in Jeffrey 
Epstein after he started a relationship with 
Ms. Maxwell? 
MR. CRITTON: Form. 
A. I didn't spend a lot of time with 
him 
too much time with him. I don't know 
what you are talking about. 
Q. Do you have an opinion if Jeffrey 
Epstein changed at all once he started a 
relationship with Ms. Maxwell? 
MR. COHEN: Objection. 
A. I have no idea. 
Changed in what way? 
Q. I could not hear that last response. 
Excuse me? 
A. Changed in what way? 
I don't understand your question. 
Q. Well, you know Jeffrey Epstein better 
than I do. So my question is --
A. Maybe. I don't know how well you 
know him. I think there are people who know 
him better than I do, so you could be one of 
them. 
• 
0 
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EFTA00181592

Mark Epstein 
September 21, 2009 
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Q• 
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M. Epstein 
Okay. The question is once he 
started a relationship with Ms. Maxwell, did 
you notice a change in him? 
Was he more agitated? Was he 
happier? Was he sadder? 
Did you notice any type of emotional 
change in your brother once he started a 
relationship with Ms. Maxwell? 
A. I can't connect anything to that, no. 
Q. Do you have an opinion of Ms. 
Maxwell? 
MR. COHEN: Objection. 
MR. CRITTON: Form. 
A. I had very little dealings with her. 
Q. So what is your answer? 
A. I don't have an opinion of her. 
Q. All right. And who is your brother's 
best friend? 
A. I already answered. 
Q. I didn't hear it? 
A. I have no idea. 
Q. Okay. Can you give me the name of 
one of his close friends? 
A. I have no idea. 
• 
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EFTA00181593

Mark Epstein 
September 21, 2009 
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M. Epstein 
Q. Can you give me a name of one his 
close friends from Coney Island where you guys 
grew up? 
A. There is a Warren. 
Q. Warren what? 
A. Eisenstein. 
Q. Do you know his address? 
A. No. 
Q. Do you know his telephone number? 
A. No. 
Q. Do you know if he still lives in New 
York? 
A. No, he lives out of state. 
Q. Do you know which state? 
A. Texas. 
Q. Texas? 
A. Yes. 
Q. Do you know which city in Texas? 
A. Dallas or Houston, one of the big 
ones. I'm not sure. 
Q. Do you know his date of birth? 
A. No. 
Q. Okay. Thank you for your time. I 
have no further questions. 
• 
0 
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EFTA00181594

Mark Epstein 
September 21, 2009 
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M. Epstein 
Oh, sorry, can you spell his last 
name, I didn't catch that, the friend's last 
name? 
A. It's Eisenstein. 
Q. Can you spell it? 
A. No. 
Q. Did you and Mr. Eisenstein go to the 
same primary school? 
A. I think he went to the same schools, 
yeah. He was my brother's age. I think he 
was in the same school. 
Q. And which school was that once again? 
A. P.S. 188. 
Q. And that is in Brooklyn? 
A. Yes. 
MR. LANGINO: All right. Thank you 
very much. 
MR. COHEN: Thank you. 
Anyone else? 
MR. HOROWITZ: Yes, this is Adam 
Horowitz. Just a few questions. 
Can you hear me okay? 
MR. COHEN: Yes, we hear you great. 
MR. HOROWITZ: Great. 
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EFTA00181595

Mark Epstein 
September 21, 2009 
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M. Epstein 
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EXAMINATION BY 
MR. HOROWITZ: 
Q. Mr. Epstein, any family members that 
you would say your brother Jeffrey is now 
close with? 
A. No. 
Q. Not a single family member that he is 
close with? 
A. No, we don't have a very big family. 
Q. Other than yourself, who are the 
closest blood relatives? 
A. There are some cousins that are 
around. 
Q. Any cousins that live in Florida? 
A. We do have a cousin in Florida, yes. 
Q. Who is that? 
A. I'm not telling you my cousin's 
names. I'm not having you bother my cousins 
over this nonsense. They know less of this 
than I do. 
Q. You are refusing to answer the 
question? 
A. Yes. 
Q. And this is a first cousin of his? 
• 
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EFTA00181596

Mark Epstein 
September 21, 2009 
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M. Epstein 
A. Yes. 
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Q. Where in Florida does he live? 
A. Next question. 
Q. I'd like to get some background on 
this person that you are not going to give me 
the name of. 
Where does he or she live? 
A. Next question. 
Q. Is it a male or female? 
A. Next question. 
Q. Mr. Epstein, to your knowledge, does 
your brother Jeff like getting massages? 
A. I have no idea. 
I think everybody likes getting 
massages. 
Q. How long have you known your brother 
to enjoy getting massages? 
MR. COHEN: Objection. 
A. I have no idea. I don't think about 
what he does. 
Q. Has he ever talked to you about 
getting massages? 
A. No. 
Q. Have you ever gotten a massage with 
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EFTA00181597

Mark Epstein 
September 21, 2009 
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M. Epstein 
him? 
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A. No. 
Q. Have you ever seen him get a massage? 
A. Not that I remember. 
Q. Does he ever complain about physical 
injuries for which he'd like to get a massage? 
A. No, we don't talk about that. No. 
Q. Has he ever complained to you about 
back pain, shoulder pain? 
A. No. 
I don't complain about my back pain 
either, so I don't put much weight on that. 
Q. Have you known of anyone to give him 
a massage? 
A. No. There was a girl years ago, but 
I'm talking 20 years ago, there was some woman 
that he used in Florida, I don't remember her 
name, but I know there was a woman who used to 
give him massages. 
Q. Where would she go to give him 
massages? 
A. I believe to his home. 
Q. She would come to his home about 20 
years ago? 
• 
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EFTA00181598

Mark Epstein 
September 21, 2009 
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M. Epstein 
A. I don't know. I don't remember. 
Q. On the different occasions you've 
been to his home in Palm Beach, have you ever 
seen or known of him to receive a massage? 
A. Not that I remember, no. 
Q. What about on the different times 
that you've been on a plane with your brother 
Jeff, have you seen or known of him to get a 
massage on those trips? 
A. No. 
Q. Has he ever treated you to a massage? 
A. No, I buy my own, thank you. 
Q. Other than your brother, do you have 
any family members who have been accused of 
sexual abuse? 
A. No. 
MR. HOROWITZ: All right. I've got 
no other questions. 
MR. CRITTON: Mr. Epstein, my name is 
Bob Critton and I represent your brother Jeff. 
I have just a few questions. 
THE WITNESS: Go ahead. 
EXAMINATION BY 
MR. CRITTON: 
ESQUIRE 
Am Al na.in 
ilZo 
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EFTA00181599

Mark Epstein 
September 21, 2009 
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M. Epstein 
Q. If I understand your testimony, you 
haven't been to your brother's house in Palm 
Beach in approximately 10 years? 
A. Yeah. 
Q. And the conversations you've had with 
him over the past five, six, seven, eight 
years have been basically hey, Jeffrey, how 
are you doing? And/or he'll say hey, Mark, 
how are you doing? 
A. Well, the one's prior to five years 
ago, 90 percent of the phone calls were 
dealing with my mother. 
My mother had a bunch of medical 
issues for 10 years before she died. She had 
been in a very big car accident, so... 
Q. Your mother died approximately 
five years ago? 
A. Five and a half years ago, yes. 
Q. 
So conversations that you had with 
your brother prior to your mother's death 
would have mostly centered around her and her 
condition? 
A. Mostly, yes. 
Q. And then subsequently, after your 
• 
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Mark Epstein 
September 21, 2009 
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M. Epstein 
mother passed away, the conversations that you 
had with your brother, if I understood your 
testimony, were basically, "How are you 
doing?" "How are you doing?" 
A. More or less. A funny story about a 
friend or something, yes. 
Q. With regard to the criminal charges 
that were brought against your brother and 
whatever has occurred with regard to those 
criminal charges, would it be a correct 
statement that you have never discussed any of 
those issues with your brother? 
A. That's correct. 
Q. With regard to the civil cases that 
have been filed against your brother, would it 
be a correct statement that you have never 
discussed any of the allegations of the civil 
cases? 
A. That's correct. 
Q. And with regard to the newspaper 
articles that have been written or the lawyers 
who have sought publicity to put information 
in the newspaper about your brother's 
confessions to sensationalize the story, would 
0 
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Mark Epstein 
September 21, 2009 
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M. Epstein 
it be a correct statement that you never 
discussed those newspaper articles with him? 
MR. EDWARDS: Objection to the form. 
Q. Let me ask it in a simpler form. 
With regard to any newspaper article 
that you've seen about your brother relating 
to allegations here and people in Palm County, 
would it be a correct statement that you have 
not discussed those with your brother? 
A. Correct. 
MR. CRITTON: That's all I have. 
Thank you, sir. 
MR. COHEN: I have no questions. 
MR. EDWARDS: I only have two 
follow-up questions. 
EXAMINATION BY 
MR. EDWARDS: 
Q. When you called your brother to tell 
him that you were subpoenaed, did he tell you 
that he would hire you an attorney? 
A. No. 
Q. How did it come to be that he hired 
you an attorney and an attorney is here with 
you today? 
• 
0 
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EFTA00181602

Mark Epstein 
September 21, 2009 
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M. Epstein 
A. Another attorney called me and said 
that they would provide me with an attorney. 
Q. Who was that? 
A. Jack. 
Q. Jack Goldberger? 
A. I believe so, yes. 
Q. And was that within days of your 
phone call to your brother? 
A. Within weeks. I don't remember 
exactly when I was served. It's not high on 
my priority list. 
Q. You don't want to have anything to do 
with this case? 
A. I have nothing to do with this case. 
Q. The last question I have to ask you 
is some of the girls have described your 
brother's penis as being egg-shaped. 
Is that something that you would know 
from being his brother and growing up? 
MR. CRITTON: Form. 
MR. COHEN: Objection. 
A. I read that, and that was a shock. I 
never heard that and/or ever saw that. 
Q. Have you ever seen his penis? 
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EFTA00181603

Mark Epstein 
September 21, 2009 
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M. Epstein 
A. Yes. 
Q. Do you remember anything unusual or 
egg-shaped about it? 
A. No. 
MR. EDWARDS: All right. Anybody 
else have anything? 
Q. Oh, did your brother tell you how to 
testify today? 
A. Did he tell me he had to testify 
today? 
Q. Did he tell you how to testify --
A. No. 
Q. -- To come here and say you don't 
know anything about it? 
A. No, nobody tells me what to do. 
MR. COHEN: Okay. We are done. 
(Continued on the next page to 
include jurat and signature.) 
• 
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EFTA00181604

Mark Epstein 
September 21, 2009 
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p.m., 
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M. Epstein 
THE VIDEOGRAPHER: The time is 1:03 
and we are off the record. 
This is the end of tape one. 
(Time noted: 1:03 p.m.) 
MARK EPSTEIN 
Subscribed and sworn to 
Before me this  
 day of 
, 2009. 
Notary Public 
ESQUIRE 
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wviw.esquiresolutions.00m 
EFTA00181605

Mark Epstein 
September 21, 2009 
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INDEX 
WITNESS 
EXAMINATION BY 
PAGE NO. 
M. Epstein 
Mr. Edwards 
9, 91 
Mr. Willits 
73 
Ms. Ezell 
75 
Mr. Langino 
80 
Mr. Horowitz 
85 
Mr. Critton 
88 
Plaintiff's 
EXHIBITS 
DESCRIPTION 
PAGE NO. 
1 
Document 
16 
• 
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EFTA00181606

Mark Epstein 
September 21, 2009 
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CERTIFICATION 
I, Jacklyn Lisi, a Shorthand Reporter, and 
Notary Public, within and for the State of New York, do 
hereby certify: 
That MARK EPSTEIN, the witness whose 
examination is hereinbefore set forth, was first duly sworn 
by me, and that transcript of said testimony is a true 
record of the testimony given by said witness. 
I further certify that I am not related to any 
of the parties to this action by blood or marriage, and that 
I am in no way interested in the outcome of this matter. 
IN WITNESS WHEREOF, I have hereunto set my hand 
this 
day of 
, 2009. 
ESQUIRE 
na_ “a" 
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EFTA00181607

Mark Epstein 
September 21, 2009 
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DEPOSITION ERRATA SHEET 
RE: 
Esquire Deposition Solutions 
File No. 13061 
Case Caption: JANE DOE 
vs. JEFFREY EPSTEIN 
Deponent: Mark Epstein 
Deposition Date: September 21, 2009 
To the Reporter: 
I have read the entire transcript of my Deposition taken 
in the captioned matter or the same has been read to me. 
I request that the following changes be entered upon the 
record for the reasons indicated. I have signed my name to 
the Errata Sheet and the appropriate Certificate and 
authorize you to attach both to the original transcript. 
Page No. 
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ESQUIRE 
.m..".." 
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EFTA00181608

Mark Epstein 
September 21, 2009 
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Deposition of Mark Epstein 
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SIGNATURE: 
DATE: 
Mark Epstein 
ESQUIRE 
..m 
la nd<I G31104.1,407 
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EFTA00181609