EFTA01076650

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
Related Cases: 
08-80232, 08-80380,08-80381,08-80994, 
08-80993, 08-80811,08-80893,09-80469, 
09-80591,09-80656,09-80802,09-81092. 
VIDEOTAPED DEPOSITION OF JEFFREY EDWARD EPSTEIN 
VOLUME 
(Pages 1 - 189) 
Monday, March 8, 2010 
301 Clematis Street 
Suite 3000 
West Palm Beach, Florida 33401 
10:05 III. - 6:17 III. 
Reported By: 
Vicki L. Lima, Court Reporter 
Notary Public, State of Florida 
Universal Legal Re orting 
Phone -
Job #92076-A 
UNIVERSAL COURT REPORTING 
MI) 
EFTA01076650

Page 2 
Page 4 
1 
2 
APPEARANCES.. 
4 
On Wolf of die PhootIffs. heti Doe 2 through 8: 
ADAM MORONS= ESQUIRE 
5 
JESSICA D. ARBOUR. ESQUIRE a
MERMELSTEN & HOROWITZ IM 
6 
18205 Dian Boulewd 
Seam 2218 
7 
Mimi, Flalda 33160 
8 
On behalf of de Plamtifts, Jane Doc 
BRAD EDWARDS. ESQUIRE 
9 
FANNER. JAFFE, MISSING. 
EDWARDS. P15105 & LEHRMAN.. 
10 
425 Noah Andrews Avenue 
Suite 2 
11 
Fort Lauderdale. Florida 33301 
12 
On lx&Hofelio Phis011. Jane Deo 103: 
KATHERINE W. EZELL, ESQUIRE 
13 
PODHURST ORSECK 
City &sliced Bak Baling 
14 
25 Wo41 Them &ma 
Suite $00 
IS 
Mimi. Florida 33130 
16 
On behalf of the Defendam and Wieneem 
MICHAEL I PIKE. ESQUIRE 
17 
BURMAN. CROTON, LUTHER & COLEMAN 
303 Dawn Boiderard 
18 
SIliN 400 
West Palm Beath Florida 33401 
19 
JACK & GOLDBERGER, ESQUIRE 
20 
ATTERBURY. GOLDBERGER & WEISS. 
One Cleadoke Cute 
21 
250 Australian Ammue Smith 
Suite 1400 
22 
West Palm Beath. Florida 33401 
23 
24 
ALSO PRESENT: 
25 
Ake Ayala. VideograpSer 
1 
PROCEEDINGS 
2 
---
3 
Videotaped deposition taken before Vicki L. Lima, Court 
4 
Reporter, and Notary Public in and for the State of 
5 
Florida at Large, in the above cause. 
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7 
THE VIDEOGRAPHER: We are now on the record. 
8 
This is the videotaped deposition of Jeffrey 
9 
Epstein, taken in the matter of Jane Doe Number 2 
10 
vs. Jeffrey Epstein, Case Number 08-CV-801 19. 
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We are here at 301 Clematis Street, Suite 3000, 
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West Palm Beach, Florida 33401. It is Monday, 
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Match 8th, 2010. The time is 10:05. The court 
14 
reporter is Vicki Lima. The videographer is Alex 
15 
Ayala. 
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Will counsel please introduce themselves? 
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MR. HOROWITZ: Sure. My name is Adam Horowitz 
18 
from Mermeistein & Horowitz, counsel for Plaintiffs 
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Jane Doe 2 through 8. And Just for record 
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purpOses, the deposition is taken -- being taken in 
21 
those cases as well. 
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MR. PIKE: Please introduce yourself. 
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MS. ARBOUR: Jessica Arbour, Mermelstein & 
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Horowitz. 
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MR. EDWARDS: Brad Edwards. 1 represent Jane 
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2 
4 
5 
O 
VOLUME I 
(Pages 1 -189) 
EXAMINATION INDEX 
JEFFREY EDWARD EPSTEIN 
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DIRECT BY MR. HOROWITZ 
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8 
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NO EXHIBITS MARKED 
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2/ 
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• 
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Page 5 
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Doe. It's also been cross-noticed in that case as 
2 
well, but I think it's styled in the Jane Doe 2 
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case. 
4 
MS. EZELL: Katherine Ezell. I represent Jane 
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Doe 103. 
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MR. PIKE: Michael Pike on behalf of Jeffrey 
7 
Epstein. 
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THE VIDEOGRAPHER: Will the court reporter 
9 
please swear in the witness? 
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THE REPORTER: Raise your right hand, please. 
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THEREUPON: 
13 
JEFFREY EDWARD EPSTEIN 
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having been first duly sworn or affirmed, was examined 
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and testified as follows: 
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THE WITNESS: Yes, mat 
17 
DIRECT EXAMINATION 
18 
BY MR. HOROWITZ: 
19 
Q Please tell us your full name? 
20 
A Jeffrey Edward Epstein. 
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Q And is your date of birth January 20, 1953? 
22 
A Yes. 
23 
Q Okay. And I guess that makes you 57 years old 
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at the present time? 
25 
A Correct. 
UNIVERSAL COURT REPORTING 
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EFTA01076651

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Q And you are, sir, a registered sex offender in 
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the State of Florida? 
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A Correct. 
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Q Okay. How long have you been a sex offender in 
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the State of Florida? 
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MR. PIKE: Foam 
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THE WITNESS: I registered on — in, I believe, 
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18, July of '08. 
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BY MR. HOROWITZ: 
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Q Okay. Are you married? 
A No. 
Q Have you ever been married? 
A No. 
Q Are you engaged? 
A No. 
Q Have you ever been engaged? 
MR. PIKE: Form. 
THE WITNESS: On advice of counsel, I'm going 
to assert my Fifth Amendment Right as to that. 
BY MR. HOROWITZ: 
Q Are you suffering from any physical illness or 
injury today that would prevent you from sitting for a 
full day of deposition? 
A No. 
Q Your hearing is okay? 
Page 7 
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A %/hats that? Yes. 
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Q Okay. No back or neck pain at the present 
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time? 
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A No. 
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Q Do you have a girlfriend at the present time? 
6 
MR. PIKE: Form. 
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THE WITNESS: On advice of counsel, fm going 
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to assert my Fifth Amendment Right 
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BY MR HOROWITZ: 
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Q Do you have a driver's license in any state? 
11 
A Yes. 
12 
Q In what state? 
13 
A The United States Virgin Islands. 
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Q Okay. How long have you had a driver's license 
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in the Virgin Islands? 
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A I believe twelve years. 
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Q Okay. Have you ever had a driver's license in 
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the State of Florida? 
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A Yes, sir. 
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Q Okay. And during what years did you have a 
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driver's license in the State of Florida? 
22 
A I don't remember. 
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Q Okay. What address appears on your driver's 
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license in the Virgin Islands? 
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MR. PIKE: Form. 
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Page 8 
THE WITNESS: I don't remember. 
BY MR. HOROWITZ: 
Q Is it the address that you reside in? 
MR. PIKE: Form. 
THE WITNESS: On advice of counsel, I am going 
to assert my Fifth Amendment Right. 
BY MR. HOROWITZ: 
Q Okay. Did you review any documents in 
preparation for today's deposition? 
A No. 
Q Okay. Did you meet with your attorneys 
concerning this deposition at any time before it 
started? 
A At any time I've 
over the past couple of 
months, but not specifically with this deposition. 
Q Okay. I'm asking about — concerning this 
deposition? 
A No. 
Q Okay. In June of 2008, you pled guilty to two 
felonies; is that correct? 
A Correct. 
Q Okay. One of those felonies involved procuring 
a person under the age of 18 for prostitution, correct? 
A Yes. 
Q You pled guilty to that charge, correct? 
Page 9 
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A That's correct. 
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Q Okay. And you were represented by legal 
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counsel at the time of your plea? 
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A That's correct 
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Q Okay. In that particular charge the person 
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under the age of 18 who you allegedly procured for 
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prostitution, was a female, correct? 
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A On advice of cowisel, I am going to have to 
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assert my Fifth Amendment, Sixth Amendment and 
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Fourteenth Amendment Right. 
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Q In June of 2008, you also pled guilty to a 
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felony charge of solicitation of a prostitute, correct? 
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A No, solicitation of prostitution, correct. 
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Q Okay. And to make sure we're on the same page, 
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in June of 2008, you pled guilty to a felony of 
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solicitation of prostitution, correct? 
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A Yes. 
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Q Okay. And you were represented by counsel at 
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the time of that guilty plea as well? 
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A Yes, sir. 
21 
Q Okay. And you were sentenced in Palm Beach 
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County for both of those felonies, correct? 
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A That's correct 
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Q Okay. You actually served your time in Palm 
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Beach County? 
3 (Pages 6 to 9) 
UNIVERSAL COURT REPORTING 
EFTA01076652

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A That's correct. 
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Q Okay. And at the time of your sentence, did 
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the Judge advise you as to what your sentence would be? 
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A I believe so. 
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Q You were there when the Judge entered the 
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sentence? 
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MR. PIKE: Font 
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THE WITNESS: Yes. 
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BY MR. HOROWITZ: 
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Q Okay. Your sentence included jail time; is 
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that right? 
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A That's correct. 
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Q Okay. And the sentence you received was twelve 
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months, followed by six months; is that correct? 
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A I believe so. 
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Q 1.1h-huh. And was it at — as part of that 
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sentence, that you were designated as a sex offender? 
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MR. PIKE: Fonn. 
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THE WITNESS: Asa result of that sentence. 
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BY MR. HOROWITZ: 
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Q You were designated as a sex offender? 
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A That's correct. 
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Q Okay. So that would have been that June/July 
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2008 time frame? 
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A I believe so. 
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Q Okay. Do you register your home address as 
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part of your sex offender designation? 
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MR. PIKE: Form. 
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THE WITNESS: I believe so. 
5 
BY MR- HOROWITZ: 
6 
Q Okay. What address do you provide as your home 
7 
address as part of your sex offender registration? 
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MR. PIKE: Form. 
3 
THE VMNESS: On advice of counsel, I will have 
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to assert my Fifth Amendment, Sixth Amendment and 
11 
Fourteenth Amendment Right. 
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BY MR. HOROWITZ: 
13 
Q Okay. Do you tell the State of Florida where 
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you live as part of your sex offender registration? 
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A Do I tell the State of Florida? 
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Q My department within the State of Florida 
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where you live as part of your sex offender 
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registration? 
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A 
I believe so. 
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Q What address do you tell them that you live in? 
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MR. PIKE: Form, same objection. 
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THE WITNESS: And I am going to assert my Fifth 
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Amendment, Sixth Amendment and Fourteenth Amendment 
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Rights. 
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BY MR. HOROWITZ: 
Page 12 
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Q Do you tell any departments of the State of 
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Florida what vessels or vehicles you own as part of your 
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sex offender registration? 
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A My sex offender registration will speak for 
5 
itself, but I believe so. I don't remember. 
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Q Okay. What vehicles or vessels do you inform 
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the State of Florida that you own or have an interest in 
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as part of your sex offender registry? 
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MR. PIKE: Fonn, same objection. 
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THE WITNESS: I don't recall. 
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THE REPORTER: What did you say? 
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THE WITNESS: I don't recall. 
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BY MR. HOROWITZ: 
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Q If you know, are there locations that you 
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cannot live in because of your status as a sex 
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offender? 
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A 
I believe I — 
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MR. PIKE: Form. 
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THE WITNESS: — I believe I can livc in any 
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location. 
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BY MR. HOROWITZ: 
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Q Any location? 
A Yes, sir. 
Q If you know, are there places you cannot work 
because of your status as a sex offender? 
Page 
1 
MR. PIKE: Form. 
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THE WITNESS: I don't believe so. 
3 
BY MR. HOROWITZ: 
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Q If you know, are there people that you cannot 
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come into contact with because of your status as a sex 
6 
offender? 
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MR. PIKE:. Form. 
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THE WITNESS: I do not know. 
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BY MR. HOROWITZ: 
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Q Okay. Since being sentenced — strike that 
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As part of your sentence, are you forbidden 
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from having sexual contact with minors? 
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MR. PIKE: Form, argumentative. 
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THE WITNESS: I'm sorry? 
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BY MR. HOROWITZ: 
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Q As part of your sentence, are you forbidden 
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front having sexual contact with minors? 
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MR. PIKE: Same objection. 
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THE WITNESS: I don't know 
I believe that 
20 
sexual contact with minors is against the law, so I 
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would assume so. 
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BY MR. HOROWITZ: 
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Q Okay. As part of registering as a sex 
24 
offender, do you have to provide the State of Florida 
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with your business address? 
A.,ra..,...b.)•05e• -•••••••••• 
UNIVERSAL COURT REPORTING 
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EFTA01076653

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Page 16 
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A Yes, I believe so. 
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Q Okay. And what business address do you provide 
3 
the State of Florida --
4 
MR. PIKE: Form. 
5 
BY MR. HOROWITZ: 
6 
Q 
— as part of your registry with the -- as a 
7 
sex offender? 
8 
THE WITNESS: On advice of counsel, I am going 
9 
to assert my Fifth Amendment, Fourteen Amendment 
10 
and Sixth Amendment Right. 
11 BY MR. HOROWITZ: 
12 
Q How many vehicles do you tell the State of 
13 
Florida that you own as part of your registration as a 
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sex offender? 
15 
A I don't know. I -- I don't know. I don't 
16 
recall. 
17 
Q With respect to those matters that you -- you 
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do know that you provide to the State of Florida --
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A Yes. 
20 
Q 
— who provides that information, meaning you 
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or someone on your behalf? 
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MR. PIKE: Form. 
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THE WITNESS: 1 do. 
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BY MR. HOROWITZ: 
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Q Okay. And where do you send in that 
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THE WITNESS: That's correct. 
BY MR. HOROWITZ: 
Q Are you still under community control? 
A Yes, sir. 
Q Okay. When does that end? 
A JWy 21st — 
Q 2010? 
A 
July 10 — yes, 2010. 
Q July 21st, 2010, your conummity control 
ceases? 
A That's correct. 
Q Okay. Do you have a community control 
officer? 
A Yes, sir. 
Q What is his or her name? 
A Miss Elkins, Officer Elkins. 
Q How often do you see Miss Elkins in person? 
A At least twice a week. 
Q Okay. How much time do you spend with Miss 
Elkins when you see her? 
A It varies —
Q And —
A 
— up to an hour each time. 
Q Okay. And the typical occasion which you come 
face-to-face with Miss Elkins, what -- what — what do 
1 
I 
Page 15 
1 
information? 
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A Its done at the Stockade In Palm Beach County. 
3 
Q Okay. So since being released, you travel to 
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the Stockade to provide that information? 
5 
A On advice of counsel, I am going to assert my 
6 
Fifth Amendment Fourteen Amendment and Sixth Amendment 
7 
Right. 
THE VIDEOGRAPHER: Sorry to interrupt. 1 need 
9 
to go off the record fora second because of 
10 
sound. 
11 
MR. HOROWITZ: All right. 
12 
THE VIDEOORAPHER: Time off the record 10:14. 
13 
(Thereupon, a short break was taken.) 
14 
THE VIDEOGRAPHER: lime on the record 10:15. 
15 
BY MR. HOROWITZ: 
16 
Q Sir, as part of your sentence in 2008, you also 
17 
had to provide a DNA sample to the court; is that 
18 
correct? 
19 
MR. PIKE: Form. 
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THE WITNESS: That's correct. 
21 BY MR. HOROWITZ: 
22 
Q And per the =twice in the summer of 2008, you 
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were to be under community control after your time in 
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Jail: is that correct? 
25 
MR. PIKE: Form. 
Page 17 
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you do? 
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MR. PIKE: Form. 
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THE WITNESS: I talk to Miss Elkins. 
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BY MR. HOROWITZ: 
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Q What do you talk about? 
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A lf there's — my schedule. 1— I prepare a 
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schedule for Miss Elkins. 
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Q Okay. A written schedule? 
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A Yes, sir. 
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Q Okay. And you do that every week, or twice a 
11 
week? 
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A Every week. 
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Q Okay. When was the last time you provided Miss 
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Elkins with a copy of your schedule? 
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A Last Monday. 
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Q Okay. What is Miss Elkins' first name? 
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A I don't know. 
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Q Okay. And so do you drive or get driven to the 
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Stockade to see Miss Elkins? 
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A Yes. 
21 
Q Okay. And has that been true since you were 
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released from jail? 
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MR. PIKE: Form. 
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THE WITNESS: No. 
25 
BY MR. HOROWITZ: 
5 (Pages 14 to 17) 
UNIVERSAL COURT REPORTING 
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Q Okay. For how long have you been seeing Miss 
2 
Elkins one to two times per week? 
3 
A Miss Elkins was -- had replaced my former 
4 
probation officer, which is Carmine Sloan (phonetic), 
5 
about a month ago. 
6 
Q Okay. Did you have a — another probation 
7 
officer before Carmine Sloan? 
8 
A No, sir. 
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Q Okay. And when Carmine Sloan was your 
10 
probation officer, were you also seeing -- were you 
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seeing him one to two times a week? 
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A It's her, but yes. 
13 
Q Okay. And were you providing Miss Sloan with a 
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-- a written schedule? 
15 
A 
Yes. 
16 
Q Okay. Other than providing Miss Sloan with a 
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written schedule, what else -- what else do you talk 
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about? 
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A Just my daily activities. 
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Q Well, what do you tell her about your daily 
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activities? 
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A 
Where I will be. Just my schedule. Where I 
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will be. 
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Q Okay. Is that the subject matter each time 
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that you go see ha? 
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A Basically, yes. 
Q And that takes up to an hour? 
A Yes. 
Q Okay. Anything else that you talk about other 
than your schedule with either Miss Sloan or your —
your current -- Miss Elkins? 
A Not that I can recall. 
Q And it takes an hour approximately to talk 
about your schedule? 
MR. PIKE: Asked and answered. 
THE WITNESS: Up to an hour. 
BY MR. HOROWITZ: 
Q Up to an hour? 
A Yes. 
Q Up to an hour? 
A Yes. 
Q Okay. Is anyone else with you when you meet --
when you met with Miss Elkins or Miss Sloan? 
MR. PIKE: Form. 
THE WITNESS: Which time? 
BY MR. HOROWITZ: 
Q Typically. It — do you go alone? 
A It's — ifs — it's in the office. 
MR. PIKE: Same objection. 
THE WITNESS: It's at the probation office. 
Page 20 
1 
BY MR. HOROWITZ: 
2 
Q Okay. Is anyone within earshot such that they 
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can hear your conversation? 
4 
A I don't know. 
5 
Q Okay. Do you travel to go see Miss Elkins or 
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Miss Sloan with anybody else? 
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MR. PIKE: Form. 
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THE WITNESS: On advice of counsel. I am going 
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to assert my Fifth Amendment, Sixth Amendment and 
10 
Fourteenth Amendment Right. 
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BY MR. HOROWITZ: 
12 
Q Other than the probation officer, whether it be 
13 
Miss Sloan or Miss Elkins, is there anyone else from 
14 
their office that is present when you meet with them? 
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MR. GOLDBERGER: From their office, did you 
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say? 
17 
MR. HOROWITZ: Yes. 
18 
THE WITNESS: Maybe a couple of times, maybe 
19 
another probation officer. 
20 
BY MR. HOROWITZ: 
21 
Q Okay. And who is that? 
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A I don't know. 
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Q Is there anything else, other than your written 
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schedule, that you provide to Miss Elkins or Miss Sloan 
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during the course of your community control? 
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Page 21 
A Not that I can recalL 
Q Okay. What sort of things would we find on 
that schedule? 
MR. PIKE: Form. 
THE WITNESS: Where I intend to be. 
BY MR. HOROWITZ: 
Q Okay. So it would have a physical location --
MR. PIKE: Fonn. 
BY MR. HOROWITZ: 
Q 
— such as "office," or would it say an 
address? 
A It just might say "office." It might say an 
address. 
Q Okay. What addresses do you provide Miss Sloan 
or Miss Elkins as your address when you are providing 
your written schedule? • 
MR. PIKE: Form. 
MR. GOLDBERGER: Form. 
THE WITNESS: On advice of counsel, I am going 
to have to assert my Fifth Amendment, Sixth 
Amendment and Fourteenth Amendment Right. 
BY MR. HOROWITZ: 
Q Other than telling Miss Elkins and Miss Sloan 
that you're at the office, where else do you tell them 
that you will be? 
."..2.421.47:4 ••••• ,,,
•UL 
UNIVERSAL COURT REPORTING 
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EFTA01076655

Page 22 
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MR. PIKE: Same objection. 
2 
THE WITNESS: I am going to Inge to assert my 
3 
Fifth Amendment, Fourteenth Amendment and Sixth 
4 
Amendment Right. 
5 
BY MR. HOROWITZ: 
6 
Q Does the schedule — written schedule that you 
7 
provide to Miss Elkins and Miss Sloan simply say a 
8 
location, or do you also describe your activities? 
9 
A Just the location. 
10 
Q Okay. Other than "office," what other 
11 
locations do you from time to time provide to Miss 
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Elkins or Miss Sloan? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: I'm going -- I am going to, on 
15 
advice of counsel, assert my Fifth Amendment, Sixth 
16 
Amendment and Fourteenth Amendment Right. 
17 
BY MR. HOROWITZ: 
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Q Okay. Does your community control officer -
19 
is that — is that the correct term, "community control 
20 
officer? 
21 
MR. PIKE: Form. 
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THE WITNESS: I believe so. 
23 
BY MR. HOROWITZ: 
24 
Q Okay. Does your community control officer ever 
25 
make unannounced visits to your home? 
Page 23 
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A Yes. 
2 
Q Well, where do they travel to to see you? 
3 
MR. PIKE: Form. 
4 
THE WITNESS: On advice of counsel, lam going 
5 
to assert my Fifth Amendment, Sixth Amendment and 
6. 
Fourteenth Amendment Right. 
7 
BY MR. HOROWITZ: 
8 
Q Okay. Other than your own office, are there 
9 
any other locations where you have met Miss Sloan or 
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Miss Elkins to discuss your schedule? 
11 
A My probation office. 
12 
Q Other than the probation office, are there any 
13 
other locations where you've met them? 
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A On advice of counsel, I am going to assert my 
15 
Sixth Amendment, Fourteenth Amendment and Fifth 
16 
Amendment Right. 
17 
BY MR. HOROWITZ: 
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Q Okay. Do you anticipate that you'll be seeing 
19 
Miss Elkins one to two times per week until your 
20 
community control expires? 
21 
A Yes. 
22 
Q You were also ordered at the time of your 
23 
sentence to have no contact, direct or indirect, with 
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various girls; is that correct? 
25 
MR. PIKE: Form, confusing. 
Page 24 
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THE WITNESS: I'm sorry, I don't understand the 
2 
question. 
3 
BY MR. HOROWITZ: 
4 
Q Sure. At the time of your sentence -- we 
5 
talked about that a few times already, that was in 
6 
June/July of 2008? 
7 
A Uh-huh. 
8 
or.? My question is: Isn't it true you were ordered 
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at that time to have no contact, direct or indirect. 
10 
with various girls? 
11 
MR. PIKE: Objection. 
12 
THE WITNESS: I don't recall. 
13 
BY MR. HOROWITZ*. 
14 
Q Do you know —
15 
A I don't recall. 
16 
Q Do you know whether the Judge announced that in 
17 
Court to you on the date of your sentence? 
18 
A I don't recall. 
19 
Q Do you recall a document saying that you were 
20 
directed to have no contact, direct or indirect, with 
21 
various girls as part of your criminal sentence? 
22 
MR. PIKE: Form. 
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THE WITNESS: I believe that was much later. 
24 
BY MR. HOROWITZ: 
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Q Okay. At some point — that happened later? 
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A That's correct. 
Q Okay. What do you understand to be the terms 
of this no-contact order that you believe you were 
provided at a later date? 
MR. PIKE: Form. 
MR. GOLDBERGER: If you know. 
THE WITNESS: Just to have no affirmative 
contact —
MR. GOLDBERGER: Be specific. 
THE WITNESS: -- with — with -- with three 
specific girls. 
MR. HOROWITZ: Let me just nip this in the 
bud. A witness —
MR. GOLDBERGER: 1— lam just trying to help 
you along here. 
MR. HOROWITZ: Okay. 
MR. GOLDBERGER: No problem. You can you 
can ask the questions, and it will take an hour 
later. I'm trying to get you an answer that you 
want 
MR. HOROWITZ: I appreciate that. III — and 
if I'm having a hard time, that's my problem. Not 
yours. 
MR. CiOLDBERGERI Okay. 
MR. HOROWITZ: But what I was addressing was 
UNIVERSAL COURT REPORTING 
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Page 26 
not your assistance, but the fact that you're 
speaking up, and you're familiar with the local 
rules. 
MR. PIKE: Yeah, let me —
MR. HOROWITZ: No, no, no. 
MR. PIKE: I know. I understand. 
MR. HOROWITZ: No, no --
MR. PIKE: Listen, we have got a — we've got a 
long day ahead of us, so let's move along. 
MR. HOROWITZ: This is -- this is in the 
interest of efficiency. 
MR. PIKE: Okay. Let's go. 
MR. HOROWITZ: Per witness, one attorney, okay? 
I don't care who It is, but it can only be one of 
you. 
MR. GOLDBERGER: Okay. So here's the deal: I 
represent Mr. Epstein on his criminal cases If I 
feel it is important for me to interject on issues 
relevant to his criminal case, I'll do so. 
Mr. Pike has taken the — the lead role in 
representing Mr. Epstein civilly. 
MR. HOROWITZ: Well — 
MR. GOLDBERGER: if there are issues relevant 
to the criminal case, I'm going interject. 
As far as your concern about what just occurred 
Page 27 
now, I'm just hying to help you along. 
MR. HOROWITZ: I appreciate that. 
MR. GOLDBERGER: That's the only reason I did 
it. 
MR. HOROWITZ: MI right. I'm going to put 
this on the record again. The local rules provide 
that in a deposition in a civil case one witness, 
one attorney who can object, period. It doesn't 
say if there is also a criminal case, two attorneys 
can speak. So if Mr. Epstein wanted to hire an 
attorney familiar with his criminal case for his 
civil case, he could have done so. If he didn't, 
that was at his own peril. So I'm just going to 
ask you to refrain, and I'm just going to put you 
on notice that if you -- if you interject an 
objection —
MR. GOLDBERGER: Uh-hub. 
MR. HOROWITZ: — I'll seek the relief from the 
Court, and that's -- that's it, but --
MR. GOLDBERGER: That's fine. And Pm going to 
continue to do so, and if you want to adjourn at 
this point, we can do that. But if I think ifs an 
issue relevant to my representation of him on a 
pending criminal case, I'm going to do so, okay? 
MR. HOROWITZ: Okay. 
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MR. GOLDBERGER: And youll — you're free to 
seek whatever relief you want. 
MR. PIKE: And — and let me — let me put 
something on the record, since you chose to do so. 
One, this is — this proceeding has a quasi-
criminal component to it, and your questions today, 
Mr. Horowitz, are interjected in a manner in an 
attempt to cause Mr. Epstein to waive his Fifth 
Amendment Right, along with his Sixth and his 
Fourteenth which are incorporated therein. So the 
fact that Mr. Goldberger is here making sure that 
his client and my mutual client maintain and 
preserve those privileges that are afforded under 
the United States Constitution, he will continue to 
do that today, okay? 
Now, we're here to answer your questions. 
We're here to move forward with the depo. We'd 
like to do that. If you'd like to adjourn to take 
this up with the Court today, we could do that as 
well, but it was — ifs your choice. 
MR. HOROWITZ: Okay. 
MR. PIKE: Okay? 
BY MR. HOROWITZ: 
Q One girl that you were ordered to have no 
contact with is Jane Doe 2, correct? 
Page 29 
1 
MR. PIKE: Form. 
2 
THE WITNESS: I don't know. 
3 
BY MR. HOROWITZ: 
4 
Q Another girl that you were ordered to have no 
5 
contact with is Jane Doe 4, correct? 
6 
MR. PIKE: Form. 
7 
THE WITNESS: No, I don't — you — you've 
8 
asked me a question regarding a criminal case? 
9 
MR. HOROWITZ: Correct. 
10 
THE WITNESS: So regarding my criminal case, I 
11 
believe the answers to the both of those questions 
12 
are no. 
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BY MR. HOROWITZ: 
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Q Okay. I have some more questions about your 
15 
criminal case. 
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A Okay. 
17 
Q Another girl that you were ordered to have no 
18 
contact with as a result of your -- following your 
19 
sentence is Jane Doe 6; is that correct? 
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MR. PIKE: Form. 
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THE WITNESS: I don't believe so. 
22 
BY MR. HOROWITZ: 
23 
Q Okay. And another girl that you were ordered 
24 
to have no contact with as a result of your criminal 
25 
case is Jane Doe 7, correct? 
UNIVERSAL COURT REPORTING 
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Page 30 
Page 32 
1 
A 1 don't believe so. 
2 
Q Okay. Another girl that you were ordered to 
3 
have no contact with is Jane Doe 5? 
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MR. PIKE: Form. 
5 
THE WITNESS: As far as my criminal case, I 
6 
don't believe so. 
7 
BY MR. HOROWITZ: 
8 
Q Okay. Another girl you were ordered to have no 
9 
contact with is Jane Doe 8, correct? 
10 
MR. PIKE: Form. 
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THE WITNESS: I'm sorry, who? 
12 
MR. HOROWITZ: Jane Doe 8. 
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THE WITNESS: I don't believe so. 
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BY MR. HOROWITZ: 
15 
Q Okay. Another girl you were ordered to have no 
16 
contact with is Jane Doe 3, correct? 
17 
MR. PIKE: Same objection. 
18 
THE WITNESS: I don't believe so. 
19 
BY MR. HOROWITZ: 
20 
Q Okay. Are you smut of the names of any girls 
21 
who you were ordered to have no contact with as part of 
22 
your criminal case? 
23 
MR. PIKE: Font 
24 
THE WITNESS: On the advice of counsel, I am 
25 
going to assert my Fifth Amendment, Sixth Amendment 
Page 31 
1 
and Fourteenth Amendment Right. 
2 
MR. HOROWITZ: Okay. I mentioned seven girls' 
3 
names. I'll just put them on the record so you 
4 
know what seven girls I'm talking about. 
5 
THE WITNESS: Okay. 
6 
MR. HOROWITZ: Jane Doe 5, Jane Doe 8, Jane Doe 
7 
6, Jane Doe 2, Jane Doe 3, Jane Doe 7. 
8 
BY MR. HOROWITZ: 
9 
Q Is it your testimony today that you were not 
10 
ordered as a result of a criminal case to have no 
11 
contact with them? 
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MR. PIKE: Form. 
13 
THE WITNESS: That's my best recollection. 
14 
BY MR_ HOROWITZ: 
15 
Q Okay. And, therefore, since you have no 
16 
recollection of being ordered, you've made no 
17 
affirmative attempt to have no contact with them; is 
18 
that correct? 
19 
MR. PIKE: Form, asked and answered. I am 
20 
going to instruct him not to answer that question. 
21 
If you want to rephrase it, go ahead. 
22 
MR. HOROWITZ: Are you going to accept —
23 
accept his advice? 
24 
MR. PIKE: Yeah. 
25 
THE WITNESS: Yes. 
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BY MR. HOROWITZ: 
Q Okay. Have you made any affirmative attempt to 
have no contact with Jane Doe 5, Jane Doe 8, Jane Doe 6, 
Jane Doe 2, Jane Doe 3, Jane Doe 4 or Jane Doe 7? 
MR. PIKE: Form, lack of predicate and 
foundation. 
THE WITNESS: And on the advice of counsel, I 
am going to assert my Fifth Amendment, Sixth 
Amendment and Fourteenth Amendment Right 
BY MR. HOROWITZ: 
Q Have you at any time known the names of the 
girls that you were directed to have no contact with --
MR. PIKE: Same objection. 
BY MR. HOROWITZ: 
Q 
— in the criminal case? 
A Known the names? 
Q Known, known. 
A I was told that in fact some of your — the 
cases that were filed against me by your firm, a firm 
whose partner was disbarred for his conduct, and in fact 
Mr. Edwards sitting there with his firm who is called by 
the U.S. Attorney to be the largest fraud in South 
Florida's history — I believe these girls have always 
been -- and I believe the ladies and gentlemen of the 
jury will eventually be aware that these girls have 
Page 33 
filed the claim many years after they alleged and even 
associated with firms whose partners have been disbarred 
and is part 
one of his partners is currently in jail, 
yes. 
Q Okay. Are you suggesting that a partner of 
mine was disbarred? Is that your testimony? 
MR. PIKE: Form. 
THE WITNESS: Yes, that's — I believe that's 
my understanding. 
BY MR. HOROWITZ: 
Q Okay. Are you suggesting that my clients 
fabricated their claims against you after coming into 
contact with an attorney who you believe was 
disciplined? 
MR. PIKE: Fonn. 
THE WITNESS: You know, I'd really like to 
answer that question, and hopefully some day I 
will. I think the answer is pretty obvious to you 
and the other people in this room, but, however, 
today, Mr. Horowitz, I am going to, on the advice 
of counsel, have to assert my Fifth Amendment, 
Sixth Amendment and Fourteenth Amendment Right, 
though I would like to — and I'm sure you and the 
ladies and gentlemen understand, I'd like to answer 
that question. 
9 (Pages 30 to 33) 
UNIVERSAL COURT REPORTING 
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Page 34 
1 
BY MR. HOROWITZ: 
2 
Q Well, you mentioned an attorney who you believe 
3 
was disciplined, and you mentioned an attorney who you 
4 
believe — 
5 
A 
I don't believe i said "disciplined." i think 
6 
you — i said 'disbarred." 
7 
Q Disbarred, okay. 
8 
A is that correct? 
9 
Q No, ifs wrong, but that was your words. 
10 
A He was not disbarred? 
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Q I'm not allowed to testify to those --
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A Oh, I'm sorry. 
13 
Q I didn't create these rules. 
14 
A 
I thought he was disbarred. I think the paper 
15 
said he was disbarred. 
16 
Q Okay. You mentioned that an attorney was 
17 
disbarred, and another attorney — 
18 
A Your partner was disbarred. Not an attorney, 
19 
correct? 
20 
Q You mentioned that my partner was disbarred, 
21 
and that's your testimony? 
22 
A Yes. 
23 
Q And you mentioned that another attorney 
24 
committed fraud? 
25 
A Yes. 
Page 35 
1 
Q Are you suggesting that somehow the Plaintiffs 
2 
fabricated their allegations because of their 
3 
association with these lawyers? 
4 
MR. PiKE: Form. 
5 
THE WITNESS: In fact, according to the 
6 
newspapers, the attorney who's -- who is currently 
7 
sitting in jail, Mr. Edwards' partner, was accused 
8 
of fabricating many cases not only against people 
9 
like me, but others, of the sexual nature, very 
10 
similar to the ones you've filed. 
11 
BY MR. HOROWITZ: 
12 
Q Okay. As to my clients — I'm not asking about 
13 
anybody else's clients. As to my client, are you 
14 
suggesting that they fabricated any aspect of their 
15 
dealings with you as a result of their dealings with 
16 
their attorney, or some remote dealings with 
17 
Mr. Rothstein? Is that — is that your testimony? 
18 
A 
I think that answer --
19 
MR. PiKE: Form, predicate, foundations, sorry. 
20 
THE WITNESS: I think that answer is pretty 
21 
obvious. But, however, on advice of counsel, I 
22 
cannot answer any questions today that are relevant 
23 
to this law -- to these lawsuits. I would like 
24 
to. I'm sure everybody knows that i would like 
25 
to. You know i would like to. But today, on the 
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Page 36 
advice of counsel, I am going to have to assert my 
Fifth Amendment, Sixteenth — sorry -- Sixth 
Amendment and Fourteenth Amendment Rights as 
guaranteed by the Constitution. 
And if i don't follow their advice and I prefer 
— i would actually prefer to answer the question, 
but if i don't follow their advice, I am going to 
risk losing my counsel, which is a violation. So 
am going to have to assert those rights today. 
MR. PIKE: Okay. And just for the record --
MR. HOROWITZ: Move to strike the 
non-responsive portion. 
MR. PIKE: Just for the record, let's try to go 
— take turns for the court reporter's benefit. 
Finish your answer —
THE WITNESS: Okay. 
MR. PIKE: — finish your question, before both 
of you continue to talk to — over each other, 
thanks. 
BY MR. HOROWITZ: 
Q Mr. Epstein, if i heard you right, you said 
that your attorneys have advised you that your you 
could not answer these questions without waiving the 
Fifth, Sixth and Fourteenth Amendment; is that right? 
MR. PIKE: Form. I am going to instruct him 
Page 37 
not to answer that question because the way it's 
phrased attempts to elicit attorney-client 
communications. 
BY MR. HOROWITZ: 
Q Did 1 paraphrase you correctly? 
A No, you did not. 
Q Okay. Well, sir, are you — are you testifying 
that Jane Doe 2 falsified a lawsuit because of her 
association with a lawyer? 
MR. PiKE: Form, predicate, foundation. 
THE WITNESS: I would really like to answer 
that question, but today, and just today at least 
on the advice of counsel, I cannot, because they 
have advised me that if I do, I risk losing their 
counsel, but as I think it is going to be pretty 
obvious, I would like to answer that question, but 
on the advice of counsel, I am going to assert my 
Fifth, Sixth and Fourteenth Amendment Right as 
provided by the U.S. Constitution. 
BY MR. HOROWITZ: 
Q Well, Mr. Epstein, if you continue to laugh at 
any of my questions, shake your head, nod, it's my 
intention to inform the Court and file a motion that 
you've waived your Fifth Amendment Right. 
MR. PiKE: All right. First of all, that's — 
10 (Pages 34 to 37) 
UNIVERSAL COURT REPORTING 
EFTA01076659

Page 38 
1 
that's argumentative and it's harassing, and you 
2 
don't have a question on the table, so let's --
3 
lees — 
4 
MR. HOROWITZ: Why are you interrupting me? 
5 
MR. PIKE: Because — because this deposition 
6 
is not going to be utilized as a — as a means to 
7 
harass my client. Ask your questions, you'll get 
8 
your answers, and let's move forward. 
9 
BY MR. HOROWITZ: 
10 
Q I'm going to ask that you not shake your head, 
11 
nod or laugh at my questions. Because if you do, it 
12 
will be at your own peril, because Pm -- I will file a 
13 
motion to have your Fifth Amendment Rights waived. 
14 
MR. PIKE: I'm going to move to strike --
15 
MR. HOROWITZ: Okay. 
16 
MR. PIKE: — your two last statements, 
17 
Mr. Horowitz. Let's get on with the deposition. 
18 
BY MR. HOROWITZ: 
19 
Q When you said that you must accept the advice 
20 
of your attorney or risk waiving your Constitutional 
21 
Rights, what advice were you talking about? 
22 
MR. PUCE: Form. I'm going to instruct him not 
23 
to answer that question. He's asserting his 
24 
Constitutional Rights. 
25 
MR. HOROWITZ: And I want to explore what he 
Page 39 
1 
just said about his Constitutional Rights. He said 
2 
he would be losing his Sixth Amendment Right to 
3 
effective representation. Do you understand — is 
4 
that what you said, sir? 
5 
MR. PIKE: Fonn. 
6 
THE WITNESS: Correct. 
7 
BY MR. HOROWITZ: 
8 
Q Okay. Okay. When you say your Sixth Amendment 
9 
Right to effective representation, who -- representation 
10 
by who? Who —who are you talking about? 
11 
MR. PIKE: Form. I'm going to instruct him not 
12 
to answer that question. 
13 
BY MR. HOROWITZ: 
14 
Q Are you suggesting that your attorneys would 
15 
not represent you if -- if you didn't assert your Sixth 
16 
Amendment Right? 
17 
MR. PIKE: Same objection. Pm going to 
18 
instruct him not to answer that question, attorney-
19 
client 
20 
BY MR. HOROWITZ: 
21 
Q How do you ensure that you have no contact with 
22 
the various girls you've been ordered to have no contact 
23 
with? 
24 
MR. PIKE: Form, predicate, foundation. 
25 
THE WITNESS: On advice of counsel, I am going 
Page 40 
1 
to have to assert my Fifth Amendment, Sixth 
2 
Amendment and Fourteenth Amendment Rights as 
3 
guaranteed by the U.S. Constitution, though I would 
4 
like to answer that question. 
5 
BY MR. HOROWITZ: 
6 
Q With respect to those girls whom you've been 
7 
ordered to have no contact with, have you had any 
8 
contact, direct or indirect, with them since receiving 
9 
that order? 
10 
MR. PIKE: Same objection; form, predicate and 
11 
foundation. 
12 
THE WITTIESS: I would like to answer that 
13 
question, however, today my — I have been informed 
14 
that I cannot answer any questions that may be 
15 
relevant to your lawsuit. So Pm going to assert 
16 
my Fifth Amendment, Sixth Amendment and Fourteenth 
17 
Amendment Right. Excuse me, could I use the 
18 
restroom? 
19 
MR. HOROWITZ: Yes. 
20 
THE VIDEOGRAPHER: Time off the record 10:35. 
21 
(Thereupon, a short break was taken.) 
22 
THE VIDEOORAPHER: Time on the record 10:42. 
23 
BY MR. HOROWITZ: 
24 
Q Asa result of your criminal sentence, how many 
25 
girls were you ordered to have no contact with? 
2 
3 
4 
5 
6 
7 
M. and 
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Page 41 
MR. PIKE: Form. 
THE WITNESS: Three. 
BY MR. HOROWITZ: 
Q Okay. And what are their names? 
MR. PIKE: Form. 
THE WITNESS: I believe it was Jane Doe 103, 
MR. HOROWITZ: Can you read that back? 
THE REPORTER: le -
MR. HOROWITZ: No, I don't think that's right. 
That's not what he said. 
(The pending answer was read back by the court 
repo
•) 
MR. HOROWITZ: Thank you. 
BY MR. HOROWITZ: 
Q Is it your testimony, sir, that those are the 
only three girls who, as a result of a criminal case 
against you, you've been ordered to have no contact 
with? 
MR. PIKE: Form. 
THE WITNESS: That's correct. 
BY MR. HOROWITZ: 
Q Okay. With respect to M., do you acknowledge 
that she has been to your home? 
MR. PIKE: Form. 
11 (Pages 38 to 41) 
UNIVERSAL COURT REPORTING 
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Page 42 
Page 44 
1 
THE WITNESS: Sony? 
2 
BY MR. HOROWITZ: 
3 
Q With respect to 
e
 
do you acknowledge she 
4 
has been to your home? 
5 
MR. PIKE: Same objection. 
6 
THE WITNESS: On advice of counsel —I would 
7 
like to answer all your questions today, 
8 
Mr. Horowitz. I'm sorry your partner that was 
9 
disbarred is not here, because I would like to 
10 
answer his questions because I believe he was the 
11 
one who represented 
So I would like to sec 
12 
Mr. Herman at some point when begets-
13 
potentially gets his license back. But, though I 
14 
would like to answer your questions in more detail, 
15 
on advice of counsel, I am going to have to assert 
16 
my Fifth, Sixth and Fourteenth Amendment Rights 
17 
under the U.S. Constitution. I would like to 
18 
answer the question, but my counsel has told me 
19 
that I risk losing their representation if I do, 
20 
so, therefore, I'm going to have to assert those 
21 
rights. 
22 
BY MIL HOROWITZ: 
23 
Q With respect to M, do you acknowledge that 
24 
she has — she went to your home %%ben she was a child? 
25 
MR. PIKE: Form. 
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Page 43 
THE WITNESS: Again, I would like to answer 
that question, and I'm sure you know I would like 
to answer that question. I'm sure your partner 
that was disbarred while he represented M, I 
believe, or her parents, or he claimed he 
represented one parent, and the other parent sued 
him or tried to bring a lawsuit against your 
partner I would like to answer any questions 
with respect to .„ 
but today on advice of 
counsel, I'm not going to be able to do that 
because they've advised me I must assert my Fifth, 
Sixth and Fourteenth Amendment Right --
MR HOROWITZ: Okay. 
THE WITNESS: - so therefore 
excuse me, I 
am going — should I finish? 
MR. PIKE: Yes. 
THE WITNESS: So, therefore — though I would 
like to answer that question and 
lam going to 
have to assert those rights. 
MR. HOROWITZ: Okay. Move to strike the 
non-responsive — the non-responsive portion of the 
answer. 
BY MR HOROWITZ: 
Do you acknowledge, sir, that with respect to 
M. during her childhood, you paid her for sexual 
1 
contact? 
2 
MR. PIKE: Form. 
3 
THE WITNESS: Again, I would like to answer 
4 
that question, but as most of your other questions 
5 
here today, and I — I understand that your partner 
6 
who represented this 
a
 
was disbarred, but at 
7 
some point in fliture I would like to answer that. 
8 
Today, unfortunately, I am going to have to assert 
9 
my Fifth, Sixth and Fourteenth Amendment Rights 
10 
under the U.S. Constitution because my counsel has 
11 
advise me that, though I would like to answer that 
12 
question, I cannot today. 
13 
BY MR HOROWITZ: 
14 
Q Are you suggesting, sir, that 
fabricated 
15 
or embellished her allegations because of her 
16 
association with a disbarred attorney? 
17 
MR. PIKE: Form, move to strike, 
18 
mischaracterizes the witness' testimony. 
19 
THE WITNESS: Can you repeat the question? 
20 
BY MR. HOROWITZ: 
21 
Q Are you suggesting that 
either fabricated 
22 
or embellished her — her allegations because of any 
23 
association she had with an attorney who's been 
24 
disbarred? 
25 
MR. PIKE: Same objection-
Page 45 
1 
THE WITNESS: It's not an attorney who's been 
2 
disbarred. I believe I said it's your partner that 
3 
was disbarred when -- after representing E, and 
4 
I would like — though I would like to answer those 
5 
questions in detail, today I have been advised by 
6 
counsel that I cannot answer any questions that may 
7 
be relevant to your lawsuits —
8 
MR. HOROWITZ: All right. 
9 
ME WITNESS: — and — excuse mo. 
10 
MR. HOROWITZ: Go ahead, finish. 
11 
THE WITNESS: Thank you. And, though I would 
12 
like to answer the questions, and I know you keep 
13 
trying to strike my answer with respect toa's 
14 
representation by your former partner, Je 
y 
15 
Herman, who was disbarred, who held press 
16 
conferences to try to make a big — so he tried to 
17 
embarrass me as best as he could, I'm - I would 
18 
like to answer those questions, but I cannot on 
19 
advice of counsel. 
20 
BY MR. HOROWITZ: 
21 
Q Okay. And do you fool that because my partner, 
22 
Jeffrey Heenan, was an attorney involved in M.'s case, 
23 
that somehow the allegations she's made agates you are 
24 
fabricated or embellished? 
25 
A I'd let — the ladies and gentlemen of the jury 
•••••• •••
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• 
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 •"'•"^ 
UNIVERSAL COURT REPORTING 
a 
( 
I 
 J 
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Page 46 
1 
will make that decision, I'm sure. I can't — I would 
2 
like to answer those questions. I would really like to 
3 
answer — I think those answers are obvious, frankly. 
4 
But today, on advice of counsel, I'm not going to be 
5 
able to answer those questions. I am going --
6 
Q 
Well - 
7 
A 
Mr. Horowitz, I would like to finish my answer, 
8 
please. Is that okay? 
9 
Q Well, you keep repeating yourself. 
10 
THE WITNESS: Mr. Pike? 
11 
MR. PIKE: Go ahead and finish. 
12 
Please allow -- allow the witness to finish his 
13 
answer. 
14 
THE WITNESS: So lees start -- should — could 
15 
you repeat the question, please? 
16 
MR. HOROWITZ: Yes. 
17 
(The pending question was read back by the 
18 
court reporter.) 
19 
MR. HOROWITZ: That wasn't exactly the 
20 
question, but I'll - let me ask it again. Maybe 
21 
it will be smoother, and just try and follow what 
22 
it is Pm asking. 
23 
THE WITNESS: I'm trying my best. 
24 
BY MR. HOROWITZ: 
25 
Q Do you believe, as we sit here today, that 
Page 47 
1 
because Jeffrey Herman was involved in the 
2 
representation of la, that her allegations of abuse by 
you are fabricated or embellished? 
4 
MR. PIKE: Form, predicate, foundation. 
THE WITNESS: I would very much like to answer 
the question regarding ■ 
-- which 
7 
embellishments, as you've described them, or 
8 
fabrications 
at the same time she met your 
9 
partner that was later disbarred. However, as of 
10 
today, though I would like to answer those 
11 
questions — and I think those answers are pretty 
12 
obvious -- I am going to have to assert my Fifth 
13 
Amendment, Sixth Amendment and Fourteenth Amendment 
14 
Rights under the U.S. Constitution. 
15 
And, though I think again those — that answer 
16 
is obvious, and will be obvious to most people here 
17 
on the jury, my attorneys have advised me I cannot 
18 
answer that question today. 
19 
BY MR. HOROWITZ: 
20 
Q Okay. You told us that in addition to u, 
21 
you were also ordered to have no contact with Jane Doe 
22 
103 and a: is that correct? 
23 
A Excuse me, yes. 
24 
Q And when did you receive such an order? 
25 
MR. PIKE: Form. 
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 
2 
3 
4 
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8
10 
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13 
14 
15 
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22 
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24 
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Page 46 
THE WITNESS: I don't recall. 
BY MR. HOROWITZ: 
Q Okay. Was it -- if I heard you correctly, it 
was in association with your criminal case? 
A That's correct. 
Q Okay. And with respect to Jane Doe 103, do you 
acknowledge that she has been to your home? 
MR. PIKE: Form. 
THE WITNESS: Again, I would like to answer 
most of your questions. However, today, as I've 
answered most 
almost all of your questions and 
will continue to answer, on advice of counsel, I 
believe, this question, I have to assert my Fifth 
Amendment, Fourteenth Amendment and Sixth Amendment 
Rights under the U.S. Constitution. 
BY MR. HOROWITZ: 
Q Okay. And — are you done? 
A (No verbal response). 
Q Do you acknowledge that Jane Doe 103 came to 
your home for sexual contact during her childhood, and 
that you paid her for those services? 
MR. PIKE: Form, predicate, foundation, 
argumentative. 
THE WITNESS: I'd 
I would like to answer 
that question. I think those questions will all 
Page 49 
have obvious answers and not — however, today, I 
am going to have to assert my Fifth Amendment, 
Sixth Amendment and Fourteenth Amendment Rights 
under the U.S. Constitution, because, though I 
would like to answer that question, my attorneys 
have advised me that I cannot -- today cannot 
answer any questions that may be relevant to this 
lawsuit. 
BY MR. HOROWITZ: 
Q Okay. You also told us — provided this name 
of a. 
Do you acknowledge that 
M
.
 
was paid by you 
for sexual contact during her childh 
? 
MR. PIKE: Form, predicate, foundation, 
argument. 
THE WITNESS: I would like to answer that 
question, as I would like to answer most of your 
other questions here today, but I, unfortunately, 
am going to have to answer that one, as I've 
answered most of your other questions, which is 
unfortunately today, I cannot answer any question 
that may be relevant to this lawsuit on advice of 
counsel. I must assert my Fifth Amendment, Sixth 
Amendment and Fourteenth Amendment Right under the 
U.S. Constitution. 
BY MR. HOROWITZ: 
13 (Pages 
46 to 49) 
UNIVERSAL COURT REPORTING 
0 
(a) 
(I) 
EFTA01076662

Page 50 
1 
Q When in the future do you presently intend to 
2 
stop asserting your Fifth, Sixth and Fourteenth 
3 
Amendment Rights, if any, and intend to start answering 
4 
these questions? 
5 
MR. PIKE: Form. I am going to instruct him 
6 
not to answer that question, attorney-client. 
7 
BY MR. HOROWITZ: 
8 
Q Do you intend at trial to start answering these 
9 
questions? 
10 
MR. PIKE: Same objection. I am going to 
11 
instruct him not to answer, attorney-client. 
12 
BY MR. HOROWITZ: 
13 
Q At the time of your sentence you told us — 
14 
which was in the summer of 2008, did you have a private 
15 
psychologist --
16 
MR. PIKE: Font 
17 
BY MR. HOROWITZ: 
18 
Q 
— named Dr. Alexander? 
19 
MR. PIKE: Form. I am going to instruct him 
20 
not to answer that question as well because the 
21 
Judge has already ruled that Mr. Epstein's medical 
22 
history is not an element in any of these cases. 
23 
MR. HOROWITZ: Well, despite — you -- you --
24 
you're aware we have a court order in which 
25 
Mr. Epstein was required to provide us the names of 
Page 51 
1 
his doctors and as well as his prescriptions, 
2 
correct? You're aware of that? 
3 
MR. PIKE: I recall that order, but I don't 
4 
recall — I don't recall — if you have the — if 
5 
you have the answers, then you can provide them to 
6 
me, and maybe I would be better situated to allow 
7 
the client to answer or not answer the questions. 
8 
I saw your associate reaching for something. So 
9 
maybe -- maybe you do have them, you can refresh my 
10 
recollection. 
11 
MR. HOROWITZ: Well, I'm just going to ask the 
12 
witness 
I'm not here to refresh his 
13 
recollection. I want his —
14 
MR. PIKE: Or mine. 
15 
MR. HOROWITZ: Or yours. 
16 
MR. PIKE: Right. 
17 
MR.. HOROWITZ: I want his testimony on today's 
18 
date as to the truth. 
19 
MR. PIKE: Okay. Well, I'm going to instruct 
20 
him not to answer that question right now. Let's 
21 
22 
MR. HOROWITZ: You guys want to talk among 
23 
yourselves? 
24 
MR. PIKE: Sure. Fm still going to maintain 
25 
the objection ifs also attorney-client and work 
1 
2 
3 
4 
5 
6 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 52 
product. 
BY MR. HOROWITZ: 
Q What — are -- are you under the care of any 
physicians at the present time other than Dr. Alexander? 
MR. PIKE: Form, predicate, foundation and 
mischaracterizes, I believe, my objection. 
THE WITNESS: I would like to answer that 
question, as I would like to answer most of your 
other questions hem today, but today I am going to 
have to assert my Fifth Amendment, Sixth Amendment 
and Fourteenth Amendment Rights under the advice •-
on advice of counsel. 
BY MR. HOROWITZ: 
Q All right. What doctors have you been under 
the care of in the past five years? 
MR. PIKE: Form. 
THE WITNESS: I am going to have to assert my 
Fifth Amendment, Sixth Amendment and Fourteenth 
Amendment Rights on advice of counsel, though I 
would like to answer these questions. 
MR. HOROWITZ: Okay. I mean, you -- you cou I d 
— you can tell your client to do what you want, 
but, linen, we have a specific court order. 
MR. PIKE: Do you have a copy of it with you? 
MR. HOROWITZ: During the break I'll get you a 
Page 53 
1 
copy. 
2 
MR. PIKE: I mean, if you have a copy of an 
3 
order, and you want to refresh my recollection --
4 
since the Fifth Amendment and the Sixth Amendment 
5 
and the Fourteenth Amendment are highly technical 
6 
Constitutional Amendments, if you wish to ask my 
7 
client questions based upon an order, I would ask 
8 
that you simply provide me with the order 
9 
beforehand, and then we can make this a much easier 
10 
process. We're here for you, Adam. 
11 
MR. HOROWITZ: Thanks. I'm pretty sure the 
12 
Court gave you a copy of the order, but -- but ifs 
13 
okay. We can move on. During the break we'll 
14 
address it. 
15 
MR. PIKE: No — well, wait a second --
16 
MR. HOROWITZ: During the break we'll address 
17 
it. 
18 
MR. PIKE: -- I am not going to banter with 
19 
you, and nor am I going to accept this type of 
20 
laughing from the corner show over there 
21 
(indicating). Listen, the fact remains is this: 
22 
There have been several orders. That of which I 
23 
was the initial author of the -- of the motions 
24 
that resulted in the positive orders, reflective of 
25 
the Fifth, Sixth and Fourteenth Amendment. So it 
.4.4. ....u..0.006t•Calemir 
UNIVERSAL COURT REPORTING 
 I 
14 (Pages 50 to 53) 
EFTA01076663

Page 54 
1 
is: If you have some of those orders, which are 
2 
probably ten plus, bring them to me, and I will 
3 
read them, and we will make this deposition go 
4 
forward a lot easier. 
5 
BY MR. HOROWITZ: 
6 
Q All right. Are you — have you been prescribed 
7 
any medications in the past five years? 
8 
MR. PIKE: Form. 
9 
THE WITNESS: Ifs the same answer. I would 
10 
like to answer that question, as I would like to 
11 
answer most of your other questions here today. 
12 
However, I've been advised by counsel that at least 
13 
today I cannot answer those questions, and I must 
14 
assert my Fifth Amendment, Sixth Amendment and 
15 
Fourteenth Amendment Right. 
16 
BY MR. HOROWITZ: 
17 
Q So you — you told us in a swom interrogatory 
18 
answer that you were prescribed Lipitor, and that you 
19 
take — you take Lipitor. Are there other medications 
20 
that you receive, for instance, to treat you for a 
21 
sexual disorder? 
22 
MR. PIKE: Form. I am going to instruct him 
23 
not to answer that question as phrased. 
24 
BY MR. HOROWITZ: 
25 
Q Other than Lipitor, are there any other 
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 
Page 56 
MR. PIKE: Form. 
THE WITNESS: I see ifs on the complaint. 
BY MR. HOROWITZ: 
Q You've been a Defendant in that lawsuit for the 
past two years? 
A 
I don't know the time. 
Q Do you know who the Plaintiff is, Jane Doe 2? 
MR. PIKE: Form. 
THE WITNESS: I read the complaint. 
BY MR. HOROWITZ: 
Q Okay. All right. My -- my earlier question to 
you was: Isn't it true that a girl named Jane Doe 2 —
A Uh-huh. 
Q 
— came to your Palm Beach home in — in late 
2004? 
A I — again, I understand that Jane Doe 2 was 
represented by your partner, Jeffrey Herman, who was 
disbarred by The Florida Bar Association. I believe she 
was represented by Mr. Herman prior to his disbarment. 
I believe he represented her in a -- in some type of 
press conference in association with other firms later 
where other partners have gone to jail for representing 
claims of a sexual nature against people like me and 
others, and the U.S. Attorney called one of the other 
firms involved in this the largest fraud in Florida 
Page 55 
1 
medications that you have been prescribed or have taken 
2 
in the past five years? 
3 
A On advice of counsel, I am going to have to 
4 
assert my Fifth Amendment, Sixth Amendment and 
S 
Fourteenth Amendment Rights, though I would like to 
6 
answer that question. 
7 
Q Okay. Is it true, sir, that a — a girl named 
8 
Jane Doe 2 came to your Palm Beach home in late 2004? 
9 
A 
Is she someone you represent? 
10 
Q Do you -- do you — do you not know the answer? 
11 
A I do not know the name. 
12 
Q Okay. Do you know we're here on a case called 
13 
Jane Doe 2 vs. Jeffrey Epstein? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: Yes. 
16 
BY MR. HOROWITZ: 
17 
Q And you've seen that on the deposition notice? 
18 
A Yes. 
19 
Q Are you suggesting that you -- you do not know 
20 
who Jane Doe 2 is? 
21 
MR. PIKE: Fenn. 
22 
THE WITNESS: I've seen it on the allegation -
23 
on your complaint today. 
24 
BY MR. HOROWITZ: 
25 
Q Okay. So we have the answer to that question? 
Page 57 
1 
in South Florida's history. But separate from that, 
2 
unfortunately today, I am going to have to assert my 
3 
Fifth Amendment, Fourteen Amendment and Sixth Amendment 
4 
Rights on the advice of counsel. 
5 
MR. HOROWITZ: Okay. Move to strike that. 
6 
BY MR. HOROWITZ: 
7 
Q Do you believe that Jane Doe 2's lawsuit 
8 
against you was either fabricated, falsified or 
9 
embellished due to any association she had with an 
10 
attorney who was suspended or disbarred, as you say? 
11 
MR. PIKE: Form. 
12 
THE WITNESS: Again? 
13 
BY MR. HOROWITZ: 
14 
Q Do you believe that lane Doe 2's lawsuit was 
15 
elfin fabricated or embellished because of her 
16 
association with any attorney? 
17 
MR. PIKE: Form 
18 
THE WI-MESS: I would like to tell you my 
19 
beliefs. I would like to give you an answer to 
20 
that question. I would like to — I'm sure the 
21 
jury is going to want to explain — understand that 
22 
she was represented by an attorney that was 
23 
disbarred at the time when this lawsuit, I believe, 
24 
got filed. Later he was disbarred. Today I would 
25 
like to answer that question, but however, today on 
15 (Pages 54 to 57) 
UNIVERSAL COURT REPORTING 
EFTA01076664

Page 58 
1 
advice of counsel I cannot, and I am going to have 
2 
to assert on their advice my Fifth Amendment, Sixth 
3 
Amendment and Fourteenth Amendment Rights under the 
4 
U.S. Constitution or risk losing their counsel. 
5 
MR. PIKE: Let me take a break really quick. I 
6 
need a 60-second break. 
7 
THE VIDEOGRAPHER: Time off the record 10:59. 
8 
(Thereupon, a short break was taken.) 
9 
THE VIDEOGRAPHER: Time on the record 11:06. 
10 
BY MR. HOROWITZ: 
11 
Sir, between 2001 and 2006 did you instruct 
12 
al to place telephone calls to arrange for girls under 
13 
the age of 18 to come to your home for your sexual 
14 
gratification? 
15 
MR. PIKE: Form. 
16 
THE WITNESS: Though I would life to answer 
17 
that question, today, on advice of counsel, I am 
18 
going to have to assert my Fifth Amendment, Sixth 
19 
Amendment and Fourteenth Amendment Rights under the 
20 
U.S. Constitution. And, though I'd really much 
21 
like to answer that question, today, I cannot. 
22 
BY MR. HOROWITZ: 
23 
Q Is it true, sir, that in late 2004 Ereceived 
24 
a telephone call wherein she was told that a girl named 
25 
Jane Doe 3 was bringing a girl named Jane Doe 2 to your 
Page 59 
1 
home? 
2 
MR PIKE: Form. 
3 
THE WITNESS: Cat you tell me who those people 
4 
are? Are those two of your clients? 
5 
MR. HOROWITZ: Yes, two of the three people 1 
6 
mentioned are my clients. 
7 
BY MR. HOROWITZ: 
8 
Q Are — are — are — are -- are you denying 
9 
that those girls were in your home? 
10 
A Tm asking you for clarification. 
11 
Q Okay. Do you want me to repeat the question? 
12 
A Do I understand the question that two of your 
13 
clients have suggested one of your clients brought the 
14 
other client? 
15 
Q Okay. Let me backup. 
16 
• A Sony. Is that — is that — 
17 
Q My questions aren't suggesting anything. 
18 
They're asking a question. Do you understand that? 
19 
A I understand that. 
20 
Q Okay. My question is: Is it true that in late 
21 
2004 --
22 
A Yes. 
23 
Q 
M. received a telephone call wherein she 
24 
was told that Jane Doe 3 was bringing lane Doe 2 to your 
25 
home? 
Page 60 
1 
MR PIKE: Form. 
2 
THE WITNESS: I'd like to answer that question, 
3 
but unfortunately, today, at least, lam going to 
4 
have to answer that like I've answered many of your 
5 
other questions. Unfortunately, I have to answer 
6 
— on advice of counsel, I am going to have to 
7 
assert my Fifth Amendment, Sixth Amendment and 
8 
Fourteenth Amendment Rights under the U.S. 
9 
Constitution because I've been told that I cannot 
10 
answer any questions that may be relevant to any of 
11 
your lawsuits, or -- and if I do, I risk losing my 
12 
representation. 
13 
BY MR. HOROWITZ: 
14 
Q Okay. Did you instruct 
to communicate by 
15 
telephone to arrange for Jane Doe to come to your home 
16 
for your own sexual gratification? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: Who? I'm sorry, what was the 
19 
name again? 
20 
BY MR. HOROWITZ: 
21 
Q This is about the fifth time I mentioned her 
22 
name. Her name is Jane Doe 2. 
23 
A Uh-huh. 
24 
MR. PIKE: Same objection. 
25 
THE WITNESS: I'd like to answer that question, 
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 
Page 61 
as I would like to answer most of your other 
questions here today, Mr. Horowitz. However, on 
advice of counsel, they have instructed me that I 
cannot answer any questions that may be relevant to 
any of your multiple lawsuits. So, though I would 
like to answer it today, l am going to have to 
assert my Fifth Amendment, Sixth Amendment and 
Fourteenth Amendment Rights as provided by the U.S. 
Constitution. 
BY MR. HOROWITZ: 
Q I am going to stick with the line of questions 
involving Jane Doe 2, so I'm just going to ask that you 
keep that name in your head, okay? Jane Doe 2; you got 
that? 
A Pliny. 
Q Okay. Thank you. Did you inform M. that 
Jane Doe 2 would be giving you a massage
 was sexual 
in nature? 
MR. PIKE: Form. 
THE WITNESS: nave — I'm going to have to 
answer that question — though I would like to 
answer that question today, I am going to have to 
assert my Fifth Amendment, Sixth Amendment and 
Fourteenth Amendment Rights, because on advice of 
counsel I cannot answer that question no matter how 
UNIVERSAL COURT REPORTING 
16 (Pages 58 to 61) 
( 
) 
EFTA01076665

Page 62 
1 
much I actually warn to today. So, unfortunately, 
2 
I'll have to assert those rights. 
3 
BY MR. HOROWITZ: 
4 
Q Did you observe M. speaking by telephone to 
5 
arrange for Jane Doe 2 to come to your home to give you 
6 
a sexual massage? 
7 
MR. PIKE: Form. 
8 
THE WITNESS: Again, Pm going to have to 
9 
answer that the way I've answered your other 
10 
questions, Mr. Horowitz, which is, though I would 
11 
like to answer that question today, on advice of 
12 
counsel, I cannot answer any questions that may be 
13 
relevant to any of your lawsuits. Therefore, I 
14 
must assert my Fifth Amendment, Sixth Amendment and 
15 
Fourteenth Amendment Rights as provided by the U.S. 
16 
Constitution. And if I don't answer that way, I 
17 
risk losing my counsel's representation. 
18 
BY MR. HOROWITZ: 
19 
Q Did III. tell you that she confirmed by 
20 
telephone that Jane Doe 2 would be coming to your home 
21 
at • specific time to give you a massage? 
22 
MR. PIKE: Form. 
23 
THE WITNESS: Though I would like to answer all 
24 
of your questions here today, and I would like to 
25 
answer that question specifically, I am going to 
Page 63 
1 
have to respond the same way I've responded to most 
2 
of your other questions here today, which is on 
3 
advice of my counsel, I am going to have to assert 
4 
my Fifth Amendment, Sixth Amendment and Fourteenth 
5 
Amendment Rights as provided by the U.S. 
6 
Constitution. And, though I would like to answer 
7 
that question, if I do so, I risk losing my 
8 
counsel's representation. 
9 
BY MR. HOROWITZ: 
10 
Q Was it your intent during the course of Jane 
11 
Doe 2's visit to your home, that you would persuade, 
12 
induce or entice her to engage in sexual activity? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: Again, I would like to answer 
15 
that question, as I would like to answer most of 
16 
your other questions here today. However, on 
17 
advice of my counsel, I cannot answer those 
18 
questions today, so I am going to have to assert my 
19 
Fifth Amendment, Sixth Amendment and Fourteenth 
20 
Amendment Rights as provided by the U.S. 
21 
Constitution. And, though 1 would like to answer 
22 
it, and I think — I am going to have to assert 
23 
those rights. 
24 
BY MR. HOROWITZ: 
25 
Q Okay. During the course of Jane Doe 2's visit 
Page 64 
1 
to your home, did you, in fact, persuade, induce or 
2 
entice her to engage in sexual activity with you? 
3 
MR. PIKE: Form. 
4 
THE WITNESS: Thought would like to answer 
5 
that question, as I would like to answer most of 
6 
your other questions here today, on advice of 
7 
counsel, I am not going to be able to answer those 
8 
questions here today. They've advised me I must 
9 
assert my Fourth 
excuse me — Fifth — excuse me 
10 
— Sixth and Fourteenth Amendment Rights as 
11 
provided by the U.S. Constitution. And if I don't 
12 
do so, I potentially risk losing their 
13 
representation, so though I'd like to answer it, I 
14 
must not. 
15 
BY MR. HOROWITZ: 
16 
Q Okay. At no point did Jane Doe 2 tell you that 
17 
she was 18 or older, omen? 
18 
MR. PIKE: Form. 
19 
THE WITNESS: Again, I would like to answer —
20 
I'd really like to answer that question. However, 
21 
I cannot, because on advice of counsel, I've been 
22 
advised that I must assert my Fifth Amendment, 
23 
Fourteenth Amendment and Sixth Amendment Rights as 
24 
provided by the U.S. constitution. And if I don't 
25 
do so,1 potentially risk losing their 
I. 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 65 
representation, though I would like to answer that 
question. 
BY MR. HOROWITZ: 
Q In your own mind, you didn't believe that when 
Jane Doe 2 came to your home that she was 18 or older, 
correct? 
MR. PIKE: Form. 
THE WITNESS: I'd really like to answer that 
question. I'd really Mice to answer most of your 
other questions here today. But however, on the 
advice of counsel, they've advised me I must assert 
my Fifth Amendment, Sixth Amendment and Fourteenth 
Amendment Rights as provided by the Constitution, 
and have asked me or instructed me, not to answer 
any questions that may be relevant to this 
lawsuit. So, though I would like to answer it,1 
cannot. 
BY MR. HOROWITZ: 
Oka . Jane Doe 2 told 
that she attended 
when she came to your home, 
correct? 
MR. PIKE: Form. 
THE WITNESS: I would like to answer that 
question, as I would like to answer every one of 
your questions here today. However, on advice of 
--XL-
17 (Pages 62 to 65) 
UNIVERSAL COURT REPORTING 
EFTA01076666

Page 66 
1 
counsel, I cannot. And, though I would like to. I 
2 
must assert my Fifth Amendment, the Sixth Amendment 
3 
and Fourteenth Amendment Rights as provided by the 
4 
U.S. Constitution. And if I don't do so, I risk 
5 
losing their representation. Though I would like 
6 
to answer, but today I cannot. 
7 
BY MR. HOROWITZ: 
8 
Q During Jane Doe 2's visit to your home in 2004, 
9 
you were nude in front of her; isn't that right, sir? 
10 
MR. PIKE: Form. 
11 
THE WITNESS: I would like to answer that 
12 
question, as I would like to answer most of your 
13 
other questions here today. But my answer is going 
14 
to be virtually the same as I've had to answer most 
15 
of your other questions, which is on advice of 
16 
counsel, I cannot answer those questions. I must 
17 
assert my Fifth Amendment, Sixth Amendment and 
18 
Fourteenth Amendment Rights as provided by the U.S. 
19 
Constitution. And if I don't do so, I've been told 
20 
I lose risking — excuse me — I risk losing their 
21 
representation, and so therefore, I cannot answer 
22 
that question. 
23 
BY MR. HOROWITZ: 
24 
Q During Jane Doe 2's visit to your home in 2004, 
25 
did you instruct het to remove all of her clothing? 
Page 67 
1 
MR. PIKE: Form. 
2 
THE WITNESS: Fa like to answer that 
3 
question. I would like to answer that question, as 
4 
I've had — I would like to answer most of your 
5 
other questions here today. However, upon advice 
6 
of counsel, I have been instructed that I must 
7 
assert my Fifth Amendment, Sixth Amendment and 
8 
Fourteenth Amendment Rights as provided by the U.S. 
9 
constitution. And though I would like to answer 
10 
that question, I cannot. 
11 BY MR. HOROWITZ: 
12 
Q During Jane Doe 2's visit to your home in 2004, 
13 
did you instruct Jane Doe 2 to pinch your nipples and 
14 
rub your chest? 
15 
MR. PIKE: Form. 
16 
THE WITNESS: I'd like to answer that question 
17 
here today, like I'd like to answer most of your 
18 
other questions here today, but, unfortunately, I 
19 
am going to respond, as I've responded to virtually 
20 
all of your questions, which is on advice of 
21 
Counsel today, at least today, I cannot answer 
22 
those questions, but must assert my Fifth 
23 
amendment, Sixth Amendment and Fourteenth Amendment 
24 
Right as provided by the U.S. Constitution. And 
25 
therefore, though I would like to answer it, lam 
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Page 68 
going to be required by my counsel not to. 
BY MR. HOROWITZ: 
Q During Jane Doe 2's visit to your home in 2004, 
did you ask her questions about her sexual experiences 
and preferences? 
MR. PIKE: Form. 
THE WITNESS: Though I would like to answer 
your question here today, Mr. Horowitz, as I would 
like to answer most of your other questions here 
today, my counsel has advised me I must assert my 
Sixth Amendment, Fourteenth Amendment and Fifth 
Amendment Rights. And if I don't follow their 
advice, I risk losing their representation, so 
therefore, I'd going to have to assert those 
rights, though I prefer to answer the question. 
BY MR. HOROWITZ: 
Q During Jane Doe 2's visit to our home in 2004, 
did you unfasten her bra and 
MR. PIKE: Form. 
THE WITNESS: Though I'd like to answer that 
question — I would like to answer all your 
questions here today, I'm going to have to respond 
as I've done to mostly all your other questions 
here today, Mr. Horowitz, which is on advice of my 
counsel, they've advised me I must assert my Sixth 
Page 69 
Amendment Rights, my Fifth Amendment Rights and my 
Fourteenth Amendment Rights under the U.S. 
Constitution. And if I don't do so, and I answer 
your question, which I would like to do, I risk 
losing their representation, so, therefore, I must 
just simply assert those rights. 
THE VIDEOGRAPHER: Three minutes of tape 
remaining. 
MR. HOROWITZ: Okay. Thanks. 
BY MR. HOROWITZ: 
Q During Jane Doe 2's visit to your home in 2004, 
did you nib Jane Doe Ts vagina? 
MR. PIKE? Form. 
THE WITNESS: I'd like to answer that question, 
however, today, at least today, my counsel has 
advised me that I cannot answer any questions that 
may be relevant to your lawsuits --
BY MR. HOROWITZ: 
Q During --
A 
— and --
Q Sorry. 
A Excuse me. 
Q Go ahead. 
A And, though I would like to answer each and 
every one of your questions, I am going to have to 
Ns. 
UNIVERSAL COURT REPORTING 
18 (Pages 66 to 69) 
) 
EFTA01076667

Page 70 
1 
respond as I've responded to most of your other 
2 
questions here today, Mr. Horowitz, which is I am going 
3 
to have to assert my Sixth Amendment, Fourteenth 
4 
Amendment and Fifth Amendment Rights as provided by the 
5 
U.S. Constitution. I've been advised by counsel that if 
6 
I don't do so, I risk losing their representation. 
7 
Though I would like to answer, I cannot. 
8 
Q Durin Jane Doc 2's visit to our home in 2004, 
9 
did you 
10 
MR. PIKE: Form. 
11 
THE WITNESS: I would like to answer that 
12 
question. I would like to answer all your 
13 
questions here today. However, on advice of 
14 
counsel, they've advised me I must assert my Fifth 
15 
Amendment, Sixth Amendment and Fourteenth Amendment 
16 
Rights as provided by the U.S. Constitution. And, 
17 
though I would like to answer that question, I 
18 
cannot here today --
19 
THE VIDEOGRAPHER: I need to —
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THE W/TNESS: — sorry — but 
21 
MR. PIKE: If you need to finish, go ahead. 
22 
THE WITNESS: — based on my counsel's advice. 
23 
THE VIDEOGRAPHER: Time off the record 11:59 - 
24 
11:19. 
25 
(Thereupon, a short break was taken.) 
Page 71 
3. 
THE VIDEOGRAPHER: Time on the record 11:29. 
2 
This is Tape 2. 
3 
BY MR. HOROWITZ: 
4 
Q Sir, during Jane Doe 2's visit to your home in 
5 
2004, did you masturbate in front of her? 
6 
MR. PIKE: Fonn. 
7 
THE WITNESS: Mr. Horowitz, I would like to 
8 
answer every one of your questions here today. I 
9 
specifically would like to answer that question. 
10 
However, on advice counsel, they've advised me I am 
11 
going to have to assert my Fifth Amendment, Sixth 
12 
Amendment and Fourteenth Rights as provided by the 
13 
U.S. Constitution. And if I don't follow their 
14 
advice, I risk losing their representation, so 
15 
therefore, I am going to have to assert those 
16 
rights. 
17 
BY MR. HOROWITZ: 
18 
Q During Jane Doe 2's visit to your home in 2004, 
19 
did you ejaculate in front of her? 
20 
MR. PIKE: Form. 
21 
THE WITNESS: I'd like to answer the 
22 
question. I'd like to answer most of your other 
23 
questions here today, but I am going to have to 
24 
respond, as I've responded to most of your other 
25 
questions here today, which is my counsel has 
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Page 72 
advised me at least today — excuse me I cannot 
answer any questions that may be relevant to this 
lawsuit. And I — ill do not follow their advice, 
I risk losing their representation. Therefore, I 
am going to have to assert those rights and not 
respond today. 
BY MR. HOROWITZ: 
Q During Jane Doe 2's visit to 
ur home in 2004, 
did ou tell her tha 
A What? 
MR. PIKE: Form. 
BY MR. HOROWITZ 
Q A hard clit. 
MR. PIKE: Same objection. 
THE WITNESS: I would like to respond to that 
question. I would like to answer that question. 
However, I am going to have to respond, as I've 
responded to most of your other questions here 
today, because my — on advice of my counsel. 
they've advised me I must assert my Sixth Amendment 
Rights, my Fifth Amendment Rights and my Fourteenth 
Amendment rights as provided by the Constitution. 
And if I don't do so, and I answer that question, I 
risk losing their representation. So therefore, 
Page 73 
1 
unfortunately, Mr. Horowitz, though I would late to 
2 
answer it, I cannot today. 
3 
BY MR. HOROWITZ: 
4 
Q Did you have sexual contact with Jane Doe 2 at 
5 
your Palm Beach home in late 2004? 
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MR. PIKE: Fonn, predicate, foundation. 
THE WITNESS: I'd very much like to answer that 
question, as I would like to answer most of your 
other questions here today. However, just like 
I've answered for most of your other questions, on 
advice of my counsel today, they've advised me that 
I must assert my Sixth Amendment, Fifth Amendment 
and Fourteenth Amendment Rights as provided by the 
U.S Constitution. And, though I would like to 
answer it, if I do so, I risk losing their 
representation; therefore, I must not respond. 
Thank you. 
BY MR. HOROWITZ: 
Q During Jane Doe 2's visit to your home in 2004, 
did you pay her 5200 after you had sexual contact with 
her? 
MR. PIKE: Form. 
THE WITNESS: Could you repeat the question for 
me? 
BY MR. HOROWITZ: 
UNIVERSAL COURT REPORTING 
19 (Pages 70 to 73) 
) 
EFTA01076668

Page 74 
1 
Q During Jane Doe 2's visit to your home in 2004, 
2 
did you pay her S200 after you had sexual contact with 
3 
her? 
4 
MR. PIKE: Form. 
5 
THE W/TNESS: I would like to answer that 
6 
question — is she saying I paid her $200? Is that 
7 
in the allegation? 
8 
MR. HOROWITZ: I'm just asking the questions. 
9 
THE WITNESS: I know. I'm asking you to 
10 
clarify. Is that — is it — is it in the -- in 
11 
the complaint? 
12 
MR. HOROWITZ: I'm not allowed to answer your 
13 
questions today. 
14 
THE WITNESS: I'm sorry. 
15 
MR. HOROWITZ: I wish I could. 
16 
THE WITNESS: I'm sorry. I wish you could 
17 
too. Fm sure the jury would like you to answer 
18 
some of my questions, but today, Ill answer that 
19 
question — unfortunately, I would like to respond 
20 
to every one of your questions, every single one, 
21 
however, today, on advice of counsel, I cannot. 
22 
And, though I would like to answer each one of your 
23 
questions, on the advice of my counsel, I am going 
24 
to have to assert my Sixth Amendment, Fifth 
25 
Amendment and Fourteenth Amendment Rights not to 
Page 75 
1 
answer, and because — if I answer, they've advised 
2 
me I risk losing their representation. 
3 
BY MR. HOROWITZ: 
4 
You never asked Jane Doe 2 for permission to 
correct? 
6 
MR. PIKE: Form. 
7 
THE WITNESS: I would like to answer each one 
8 
of your questions today, each one. However, on my 
9 
advice of my counsel, they've advised me i cannot 
10 
answer any questions that may be relevant to your 
11 
lawsuit, or her lawsuit, or the lawsuit -- I guess 
12 
it's the lawsuit brought by the same — one of your 
13 
partners originally whose become disbarred. I 
14 
would like to answer it; however, I cannot. On the 
15 
advice of counsel, I must assert my Sixth 
16 
Amend nest, Fourteenth Amendment and Fifth Amendment 
17 
Rights as provided by the Constitution, because 
18 
they've advised me that If I answer those 
19 
questions, I risk losing their representation. 
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MR. HOROWITZ: Okay. Move to strike. 
21 
BY MR. HOROWITZ: 
22 
Q And isn't it true that Jane Doe 2 indicated to 
23 
you that she did not want you to touch her? 
24 
A I woukl like to answer - 
25 
MR. PIKE: Form. 
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Page 76 
THE WITNESS: Excuse me? 
MR. PIKE: Go ahead. 
THE WITNESS: Fm sorry. I would like to 
answer every one of your questions today, every 
one. However, on advice of my counsel, I cannot 
answer any questions that may be relevant to any of 
your lawsuits. And so today, on advice of counsel, 
I must assert my Sixth Amendment, Fifth Amendment 
and Fourteenth Amendment Rights as provided by the 
Constitution, because if I answer these questions, 
I risk — they tell me, I risk losing their 
representation. 
BY MR. HOROWITZ: 
All ri t. Isn't it true that you touched ■ 
after she indicated she did 
not want you to touch her? 
MR. PIKE: Form. 
THE WITNESS: I would like to answer that 
question, as well as each and every question you've 
asked me here today regarding each and one of your 
lawsuits. However, today, on the advice of 
counsel, I am going to have to assert my Sixth 
Amendment, Fifth Amendment and Fourteenth Amendment 
Rights as provided by the Constitution. And, 
though I would like to answer that question, as all 
Page 77 
the other questions today, I am going to have to 
assert those rights because I've been advised that 
not doing so, I might risk losing their counsel. 
BY MR. HOROWITZ: 
Q Did 
0 to ersuade Jane Doe 2 that it was 
okay for to 
MR. PIKE: Form. 
THE WITNESS: I'd like to answer every one of 
your questions here today, every one. However, on 
advice of counsel, they've advised me that I cannot 
answer any questions that may be relevant to any of 
your lawsuits. Therefore, I am going to have to 
assert my Sixth Amendment, Fourteenth Amendment and 
Fifth Amendment Rights as provided by the 
Constitution because, though I would like to answer 
those questions — that question, as well as all 
the other questions you've asked me here today, I 
cannot do so on advice of counsel. 
BY MR. HOROWITZ: 
Q Sir, you don't deny that you sexually abused 
Jane Doe 2, do you? 
MR. PIKE: Fonn. 
THE WITNESS: I would like to answer that 
question. I'd really like to answer that 
question. However, I cannot on advice of counsel, 
20 (Pages 74 to 77) 
UNIVERSAL COURT REPORTING 
Min 
(a) 
EFTA01076669