EFTA01076650

Page 78 
Page 80 
1 
because they told me that I cannot answer any 
2 
questions that may be relevant to any of your 
3 
lawsuits here today. And if l do so, I risk losing 
4 
their representation, so, unfortunately, Mr. 
5 
Horowitz, I am going to have to assert those 
6 
rights. 
7 
BY MR. HOROWITZ: 
8 
Q Did you pay Jane Doe 3 for bringing Jane Doe 2 
9 
to your home in late 2004? 
10 
MR. PIKE: Form. 
11 
THE WITNESS: Who? 
12 
MR. HOROWITZ: Jane Doe 3. I may ask you a few 
13 
more questions about ha name, so just kind of hold 
14 
that name in your head. 
15 
THE WITNESS: So ifs now not Jane Doe 2? 
16 
MR. HOROWITZ: Well —
17 
THE WITNESS: Are these two friends? I mean, 
18 
these are two friends here supposedly? 
19 
MR. HOROWITZ: Pm not allowed to answer. 
20 
THE WITNESS: Oh, you can't, sorry. I guess 
21 
one friend supposedly brought the other 
22 
acquaintance —
23 
BY MR. HOROWITZ: 
24 
Q My question — my question —
25 
A Sorry. Okay. Sony. What's your question? 
Page 79 
1 
Q Put out of your mind anything else you may 
2 
register. Focus on my question to you. 
3 
A lm going to try. 
4 
Q Did you pay Jane Doe 3 for bringing Jane Doe 2 
3 
to your home in late 2004? 
6 
MR. PIKE: Form. 
7 
THE WITNESS: Did I pay Jane Doe 3, Jane Doe 
8 
2's friend? Is that — 
sorry. Is that — 
9 
BY MR. HOROWITZ: 
10 
Q Do you know them to be friends? 
11 
A Fm asking you, sorry. 
12 
Q Fm not allowed --
13 
A You're not allowed to testify. You can't 
14 
testify that they're friends, okay. Fm sorry. I would 
15 
like to answer those questions, Mr. Horowitz. I'm sure 
16 
the ladies and gentlemen of the jury— these questions 
17 
-- these answers are pretty obvious. However, on advice 
18 
of counsel, I'm not going to be able to answer those 
19 
questions today. And, though I would like to, I'm going 
20 
to have to assert my Fifth Amendment, Sixth Amendment 
21 
and Fourteenth Amendment Rights as provided by the 
22 
Constitutions because my counsel has told me that if I 
23 
don't do so, I risk losing their — potentially risk 
24 
losing their representation. So, though I would like to 
25 
answer that question, as I understand it, I cannot. 
1 
BY MR. HOROWITZ: 
2 
Q Okay. Did you instruct 
to take Jane Doe 
3 
2's name and number for the purpose of calling her to 
4 
come to your house for more sexual activity? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: I'd like to answer that question, 
7 
as I'd like to answer most of your other questions 
8 
that you've asked me here today. However, based on 
9 
advice of counsel, they've advised me I cannot 
10 
answer any questions that may become relevant to 
11 
any of your lawsuits. So, though I would like to 
12 
answer the question, Mr. Horowitz, I cannot because 
13 
my counsel has advised me that if I do, I risk 
14 
losing their representation. So, unfortunately, 
15 
today I caanot answer that question. 
16 
BY MR. HOROWITZ: 
17 
Q Okay. So you've asserted the Fifth Amendment 
18 
as to — privilege as to my questions about Jane Doe 2. 
19 
Is there any reason a jury should not infer from your 
20 
response that you sexually abused Jane Doe 2? 
21 
MR. PIKE: Object to the form of that question, 
22 
and I'm going to instruct him not to answer simply 
23 
because the way the question is worded, it could 
24 
get into attorney-client communications and 
25 
potentially work product I'm not quite sure I 
1 
2 
3 
4 
S 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
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24 
25 
Page 81 
understand the question. So if you'd rephrase it, 
possibly, if you can. 
BY MR. HOROWITZ: 
Q You've asserted a Fifth Amendment privilege to 
various questions I've asked you about Jane Doe 2. My 
question is: Is there any reason in your mind, absent 
anything you've spoken to with your attorney about, why 
the jury should not infer from your assertion of the 
Fifth Amendment privilege, that you in fact sexually 
abused Jane Doe 2? 
MR. PIKE: Form. 
THE WITNESS: Well, I believe, Mr. Horowitz, 
the Fifth Amendment is by the Supreme Court's 
ruling. Ifs, in fact, used to protect the 
innocent, as well as certain people that might be 
not guilty. So in response to that question, with 
the fact that Jane Doe 2 -- the jury will 
understand that Jane Doe 2's lawsuit brought by a 
partner of yours who's been disbarred, constant — 
after, in fact, he brought the lawsuit, well — the 
jury, I have a strange feeling will -- sorry -- the 
jury, I believe, will understand that my taking the 
Fifth Amendment is only as a result of my counsel 
advising me today that I must do so, because if I 
don't do so, I risk losing their representation, 
21 (Pages 78 to 81) 
UNIVERSAL COURT 
G 
EFTA01076670

Page 82 
1 
though I'd like to answer each and every one of 
2 
your questions. 
3 
BY MR. HOROWITZ: 
4 
Q In this case are you asserting the Fifth 
5 
Amendment privilege because you are in fact innocent? 
6 
MR. PIKE: Font 
7 
THE WITNESS: Do you want me to answer that 
8 
question? 
9 
MR. PIKE: Form. It's — it's the same 
10 
objection. 
11 
THE WITNESS: I would like to answer that 
12 
question. As I said before, your partner who's 
13 
been disbarred after filing this lawsuit, 
14 
Mr. Edwards who's sitting there whose partner, in 
15 
fact, is sitting in jail for filing lawsuits of a 
16 
sexual nature against people like me and others. 
17 
Though I would like to answer every one of your 
18 
questions, every single one, my counsel has advised 
19 
me at least today that any question that may be 
20 
relevant to this lawsuit, I must assert my Sixth 
21 
Amendment, Fourteenth Amendment and Fifth Amendment 
22 
Rights, and, though I would like to answer that 
23 
question, as well as every other question you've 
24 
asked here today, I am going to have to assert 
25 
those rights, or lose — risk losing their 
Page 83 
1 
representation. 
2 
BY MR. HOROWITZ: 
3 
Q Okay. I am going to be asking you some 
4 
questions about Jane Doe 3. She's the Plaintiff in —
5 
identified as Jane Doe Number 3. 1 just want you to 
6 
keep her name in your head so — for this series of 
7 
questions, okay? 
8 
A Yes. 
9 
Q Sir, isn't it true that a girl named Jane Doe 3 
10 
came to your Palm Beach home on multiple occasions in 
11 
2004? 
12 
MR. PIKE: Form. 
13 
THE WITNESS: I understand that Jane Doe 3 was 
14 
the girl you mentioned before who was friendly with 
15 
Jane Doe 2. So the two friends, I believe, you're 
16 
just suggesting —tow, there was a question -- oh, 
17 
Fm asking you to testify. I'd like to answer the 
18 
questions about Jane Doe 3. I'd like to answer the 
19 
questions about your former other client you talked 
20 
about, Jane Doe 2, the two friends, but I cannot 
21 
based on my advice of counsel just today at least. 
22 
Though I would like to respond in detail, I am 
23 
going to have to assert on their opinion 
their 
24 
advice, the Sixth Amendment, Fifth Amendment and 
25 
Fourteenth Amendment Rights as provided by the U.S. 
Page 84 
1 
Constitution. And, though I would like to answer 
2 
each and every one of your questions, I cannot do 
3 
so here today. 
4 
BY MR. HOROWITZ: 
5 
Q Did you ever instruct a girl named M. to 
6 
bring underage girls to your home for your sexual 
7 
pleasure? 
8 
MR. PIKE: Form. 
9 
THE WITNESS: I'd like to answer each and every 
10 
one of your questions here today, Mr. Horowitz, 
11 
regarding these lawsuits that you and your 
12 
disbarred partner -- your partner who's been 
13 
disbarred after bringing these lawsuits has 
14 
brought. However, though I'd like to answer that 
15 
question, as you probably understand, my counsel 
16 
who has advised me at least today, that I cannot 
17 
answer any questions that may become relevant or 
18 
may be relevant to this lawsuit, and they've 
19 
advised me I must assert my Sixth Amendment, Fifth 
20 
Amendment and Fourteenth Amendment Rights as 
23. 
provided by the U.S. Constitution, or risk losing 
22 
their representation, so unfortunately, I must 
23 
respond that way. 
24 
BY MR. HOROWITZ: 
25 
Q Did you ever pay.. to bring you other 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 85 
underage girls for your sexual pleasure? 
MR. PIKE: Form. 
THE WITNESS: Can you give me the question 
again? I'm sorry. 
BY
OROWITZ: 
Qmuj the — in your mind, do you know who that 
is? 
A Pm listening. 
Q Well, that's my question -- it was a question. 
A Pm sorry, what was the question? 
Q Do you know who 
-- I mean, in your mind, 
you can picture who that is, right? 
MR. PIKE: Form, move to strike. 
THE WITNESS: Pm going up —
MR. HOROWITZ: It's a question. 
MR. PIKE: What is the question? 
BY MR. HOROWITZ: 
Q Do u — in your mind, can you picture — when 
I say 'M.% do you know who I'm talking about? 
MR. PIKE: Form. 
THE WITNESS: I would like to answer each and 
every one of your questions brought here today 
under these lawsuits filed by you and your partner 
that was disbarred, but on advice of counsel here 
today, Mr. Horowitz, Pm going to have to assert my 
22 (Pages 82 to 85) 
UNIVERSAL COURT REPORTING 
EFTA01076671

Page 86 
1 
Sixth Amendment, Fourteenth Amendment and Fifth 
2 
Amendment Rights. Though I would like to answer 
3 
each and every one of your questions, l cannot do 
4 
so today. 
5 
BY MR. HOROWITZ: 
6 
Q Did you ever pay M. to bring you underage 
7 
girls for your sexual pleasure? 
8 
MR. PIKE: Form. 
9 
THE WITNESS: I would like to answer each one 
10 
of your questions that you've been posing to me 
11 
today. Unfortunately, my counsel has advised mo 
12 
that today I must assert any of my rights under the 
13 
Sixth Amendment, Fifth Amendment and Fourteenth 
14 
Amendment to any questions that may become relevant 
15 
to this lawsuit brought by you and your firm and 
16 
your partner who's been disbarred. But I would 
17 
like to answer that question. However, today I 
18 
cannot. 
19 
BY MR. HOROWITZ: 
20 
Q Between 2000 — strike that. 
21 
In 2004 and 2005, did you pay Jane Doe 3 to 
22 
bring other minor girls to your home for your own sexual 
23 
gratification? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: This is Jane Doe 3, the same girl 
Page 88 
1 
because they've told me I must assert my Sixth 
2 
Amendment, Fourteenth Amendment and Fifth Amendment 
3 
Rights to any question that may become relevant to 
4 
one of your lawsuits. So, though I would like to 
5 
answer that question, as the other questions you've 
6 
asked, I must assert those rights here today. 
7 
BY MR. HOROWITZ: 
8 
Q Sir, if you shake your head after I ask a 
9 
question, should we infer that you're saying 'no- to my 
10 
question? 
11 
MR. PIKE: Form. I am going to instruct him 
12 
not to answer that question. It — Itin -- I'm not 
13 
quite sure that you — what you're trying to do 
14 
here is you're asking a — a question. His — his 
15 
answer is his answer, and ifs a verbal answer, and 
16 
you know the rules of deposition where nods of the 
17 
head, shakes of the head, um-hum and un-huns arc 
18 
not understood by the court reporter. So his 
19 
answer is his verbal response, and no such gesture 
20 
should be interpreted in an manner that would 
21 
benefit your case, Mr. Horowitz. 
22 
MR. HOROWITZ: Okay. Well, the video will --
23 
will will be played, and persons who view the 
24 
video will — will determine from themselves — for 
25 
themselves —
Page 87 
1 
as before, who's the friend of all of the girls you 
2 
keep talking about; is that what you're saying? 
3 
BY MR. HOROWITZ: 
4 
Q Is that your testimony? 
5 
A This is your testimony —I'm sorry — this is 
6 
your -- Fm trying to understand the question. 
7 
Unfortunately, I would like to answer that 
8 
question. However, on advice of counsel here today, 
9 
they've informed me that I must assert my Sixth 
10 
Amendment, Fourteenth Amendment and Fifth Amendment 
11 
Rights. 
12 
Though I would like to answer each and every 
13 
one of your questions, I am going to have to respond to 
14 
that question the same way I've responded to mostly each 
15 
one of your other questions here today and refuse to 
16 
testify. 
17 
BY MR. HOROWITZ: 
18 
Q In 2004 did you receive a phone call from 
19 
In which she informed you that she was bringing Jane Doe 
20 
3 to your home for you to engage in sexual activity? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: Did I receive a call? 
23 
MR. HOROWITZ: That's my question. 
24 
THE WITNESS: I would like to answer that 
25 
question, however, on advice of counsel, I cannot 
Page 66 
1 
MR. PIKE: Absolutely. 
2 
MR. HOROWITZ: -- what to Infer from nodding --
3 
MR. PIKE: But he's not --
4 
THE REPORTER: Wait —
5 
MR. HOROWITZ: — or shaking of the head. 
6 
MR. PIKE: Pm sorry. Correct, but he's not 
7 
going to answer that question. 
8 
MR. HOROWITZ: Okay. 
9 
BY MR. HOROWITZ: 
10 
Q Did you instruct M. to communicate by 
11 
telephone with II. for the purpose of arranging for 
12 
underage girls to come to your home to engage in sexual 
13 
activity? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: I would like to answer each and 
16 
every one of your questions posed today about the 
17 
various lawsuits brought by you and your disbarred 
18 
partner -- your partner who was disbarred after 
19 
they filed these lawsuits. However, on advice of 
20 
counsel, they've told me I must assert my Sixth 
21 
Amendment, Fifth Amendment and Fourteenth Amendment 
22 
Rights as provided by the U.S. Constitution, or if 
23 
I testify I risk losing their representation. So, 
24 
though I would like to answer each one of your 
25 
questions, Mr. Horowitz, I cannot do so today. 
23 (Pages 86 to 89) 
UNIVERSAL COURT REPORTING 
( 
EFTA01076672

Page 90 
1 
BY MR. HOROWITZ: 
2 
Q Did you call — did you instruct 
to call 
3 
Jane Doe 3 by telephone to arrange for you to get a 
4 
massage? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: Mr. Horowitz, rd like to answer 
7 
each and every one of your questions, but I am 
8 
going to have to respond today like I've responded 
9 
to most of your other questions asked here today. 
10 
I am going — by — on the advice of counsel, I am 
11 
going to have to assert my Sixth Amendment, 
12 
Fourteenth Amendment and Fifth Amendment rights not 
13 
to answer any questions brought by you, your fin), 
3.4 
your partner that was disbarred from the Florida 
15 
Bar after bringing these lawsuits, and I am going 
16 
to have to refuse to answer that question, Fm 
17 
sorry. 
18 
BY MR. HOROWITZ: 
19 
Q Did you inform s 
that the massage Jane Doe 3 
20 
was to give you would be sexual in nature? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: I would like to answer that 
23 
question, but unfortunately, I am going to have to 
24 
answer that question as Eve answered most of your 
25 
other questions here today. On advice of counsel, 
Page 91 
1 
they've advised that I must assert my Sixth 
2 
Amendment Rights; my Fourteenth Amendment Rights 
3 
and my Fifth Amendment rights as provided by the 
4 
U.S. Constitution. And, though I would like to 
5 
answer these questions brought by you — you, your 
6 
disbarred partner, or Mr. Edwards' firm whose 
7 
partner sits in jail for — for what the U.S. 
8 
Attorney calls a criminal enterprise, I would like 
9 
nothing more than to answer that question, but 
10 
today I am going to have to assert those rights, 
11 BY MR. HOROWITZ: 
12 
Q Did you observe 
speaking with IS by 
13 
telephone and arranging for Jane Doe 3 to come to your 
14 
home for a massage? 
15 
MR. PIKE: Form. predicate, foundation. 
16 
THE WITNESS: I will much — I'd very much like 
17 
to answer that question, like most of your other 
18 
questions here today; however, upon advice of 
19 
counsel, they've advised me I must assert my Sixth 
20 
Amendment, Fifth Amendment and Fourteenth Amendment 
21 
Rights as provided by the U.S. Constitution. And, 
22 
though I would like to answer each and every one of 
23 
your questions brought by you, your firm, your 
24 
partner that was disbarred after bringing these 
25 
claims, Mr. Edwards' firm that's been accused of 
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 
1 
2 
3 
4 
6 
7 
B 
9 
10 
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13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 92 
creating and fabricating cases of a sexual nature 
against me and other people. I cannot answer that 
question today. 
BY MR. HOROWITZ: 
Q Did 
tell you that she confirmed by 
telephone that iane Doe 3 would be coming to your home 
at a specific time to give you a massage? 
MR. PIKE: Form. 
THE WITNESS: I'd like to answer that question 
Mr. Horowitz, as I'd like to answer most of your 
other questions posed here today, but as I've 
responded to mostly all your questions here today, 
on advice of counsel, they've advised me I must 
assert my Sixth Amendment, Fifth Amendment and 
Fourteenth Amendment Rights provided by the U.S. 
Constitution. 
MR. HOROWITZ: Uh-huh. 
THE WITNESS: And WI don't do so, I risk 
losing their representation. And, though your firm 
and its partner that was disbarred after bringing 
these cases, Mr. Edwards's firm, his partner sits 
in the jail accused of» of the largest fraud in 
South Florida's history, I would like nothing more 
than to answer that question, but I must follow the 
advice of counsel, or they've told me I risk losing 
Page 93 
their representation. 
BY MR. HOROWITZ: 
Q Since you've mentioned my partner who you 
describe as disbarred and you also mentioned 
Mr. Rodtstein's involvement, are you suggesting that 
Jane Doe 3 fabricated her allegations of abuse after 
corning into contact with one of these attorneys? 
A I want --
MR. PIKE: Form. 
THE WITNESS: I believe the jury will decide 
that. I believe the jury will decide that 
Mr. Rothstein, Mr. Edwards' partner who sits in 
jail, accused by the U.S. Attorney of the largest 
fraud in South Florida's history for crafting cases 
of a sexual nature, crafting, fabricating it's 
not my words — it's words in the paper — against 
people like me and others, to try to get as much 
money as they could according to the newspapers. 
I'm sorry, but I would like to answer that question 
asked to me before, but I cannot under advice of 
counsel, who've told me I must in response to any 
questions that may be relevant to your lawsuit, 
today at least, to assert my Sixth Amendment, 
Fourteenth Amendment and Fifth Amendment Rights 
under the U.S. Constitution. May I take a break or 
24 (Pages 90 to 93) 
UNIVERSAL COURT REPORTING 
(a 
(M) 
I 
EFTA01076673

Page 94 
Page 96 
1 
a rest? 
2 
MR. HOROWITZ: Yes. 
3 
THE WITNESS: Okay. Thank you. 
4 
THE VIDEDORAPliER: Time off the record 11:52. 
5 
(Thereupon, a short break was taken.) 
6 
THE VIDEOOftAPHER: Time on the record 12:00. 
7 
BY MR. HOROWITZ: 
8 
Q Sir, we have ban discussing Jane Doe 3. Was 
9 
it your intent during the course of Jane Doe 3's first 
10 
visit to your home that you would persuade, induce or 
11 
entice her to engage in sexual activity? 
12 
MR. PIKE: Form. 
13 
THE WITNESS: I'd like to answer that question, 
14 
as I'd like to answer every one of your questions 
15 
here today, Mr. Horowitz however, on advice of 
16 
counsel, I've been informed I must assert my Sixth 
17 
Amendment, Fourteenth Amendment and Fifth Amendment 
18 
Rights as provided by the U.S. Constitution. And, 
19 
though I'd like to answer the questions provide --
20 
asked by you, unfortunately, your — the person who 
21 
filed the lawsuits on your firm's behalf, your 
22 
partner, Jeffrey Herman, who's been disbarred after 
23 
they filed this lawsuit, sued by one of your other 
24 
clients -- one of the girls' parents because he 
25 
brought a lawsuit — some — some craziness — I 
1 
answered? 
2 
BY MR. HOROWITZ: 
3 
Q No. My earlier question was: Was it your 
4 
Intent to engage in sexual activity. My question now, 
5 
it's a very specific one — 
6 
A Okay. 
7 
Q -- during the course of Jane Doe 3's first 
8 
visit to your home, did you in fact persuade, induce or 
9 
entice ha to engage in sexual activity? 
10 
A I'd like to answer that question. Pd like to 
11 
answer every one of your questions here today, 
12 
Mr. Horowitz, and I think the answer is pretty obvious: 
13 
however, I cannot, because under advice of counsel, 
14 
they've advised me I must assert Fifth Amendment, Sixth 
15 
Amendment and Fourteenth Amendment Rights as provided by 
16 
the Constitution. And if I choose to answer, I risk 
17 
losing that representation no matter how much I'd like 
18 
to answer that question. 
19 
Q At no time did Jane Doe 3 tell you that she was 
20 
18 or olda, comet? 
21 
MR. PIKE: Fonn. 
22 
THE WITNESS: Pd like to answer every one of 
23 
your questions. Pd like to answer that question 
24 
specifically. However, sitting here today, I've 
25 
been advised by my counsel that I cannot answer any 
Page 95 
1 
would like to answer every one of your questions; 
2 
however, my counsel has told me I cannot today, so 
3 
I must assert those rights, or risk losing their 
4 
representation. 
5 
BY MR. HOROWITZ: 
6 
Q Sir, are you testifying that my partner was 
7 
sued by a -- a former client? 
8 
A I don't remember — I don't recall — I believe 
9 
the — 
parents, who the first was initially —
10 
this is according to the newspapers -- your -- Mr. 
11 
Herman's clients, I believe. The other 
the parent —
12 
the person who he represented said that in fact he never 
13 
represented her, but I don't have the full details. 
14 
BY MR. HOROWITZ: 
15 
Q But are you -- are you suggesting that he was 
16 
sued by her — by a former client? 
17 
A I did not 
18 
Q Pardon me? 
19 
A No, I did not. 
20 
Q Okay. During the course of Jane Doe 3's first 
21 
visit to your home, did you in fact persuade, induce or 
22 
entice her to engage in sexual activity with you? 
23 
A I just answered that question, didn't I? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: Wasn't that the question I jest 
Page 97 
1 
questions that may be relevant to your -- one of 
2 
your lawsuits. And, though it was brought, I 
3 
believe, your partner that was later disbarred and 
4 
had some association with Mr. Edwards who's sitting 
5 
there with his partner who sits in jail accused of 
6 
ono of the largest frauds in South Florida's 
• 
7 
history. The U.S. Attorney accused his firm while 
8 
he's sitting there accused of being a criminal 
9 
enterprise, I'd like to answer each one of your 
10 
questions; however, my counsel has advised me today 
11 
that I must assert my Sixth Amendment, Fourteenth 
12 
Amendment and Fifth Amendment Rights, so 
13 
unfortunately, I cannot. 
14 
BY MR. HOROWITZ: 
15 
Q Okay. In your own mind, when Jane Doe 3 was at 
16 
your home, you didn't believe that she was 18 or older, 
17 
did you? 
18 
MR. PIKE: Form. 
19 
THE WITNESS: I'd like to answer each one of 
20 
your questions, Mr. Horowitz, here today, but 
21 
unfortunately I'm going to have to respond to that 
22 
question, as I've responded to most of your other 
23 
questions here today, which is that at least for 
24 
today, my counsel has advised me that I cannot 
25 
answer any questions that may be relevant to any 
25 (Pages 94 to 97) 
UNIVERSAL C 
RT REPORTING 
( 
( 
EFTA01076674

Page 98 
1 
one of your lawsuits brought by your firm and your 
2 
partner whose — who was disbarred after they 
3 
brought these lawsuits, or the questions Mr. 
4 
Edwards might pose via his partner sitting in jail, 
5 
or a new jail according to the newspapers, accused 
6 
of the largest fraud in South Florida's history for 
7 
crafting cases of sexual nature against people like 
8 
me and others. So, though I'd like to answer that 
9 
question, as your other questions, unfortunately, I 
10 
am going to have to assert my Fifth Amendment, 
11 
Sixth Amendment and Fourteenth Amendment Rights as 
12 
provided by the U.S. Constitution. 
13 
BY MR. HOROWITZ: 
14 
Q Do you base your assertion of the Fifth 
15 
Amendment privilege on the fact that Jane Doe 3's 
16 
attorney was supposedly disbarred? 
17 
THE REPORTER: "Jane Doe 3's attorney was" —
18 
MR. HOROWITZ: "Supposedly disbarred." 
19 
MR. PIKE: I am going to object. That could 
20 
get into attorney-client work product information. 
21 
I am going to instruct him not to answer that 
22 
question, Mr. Horowitz. 
23 
BY MR. HOROWITZ: 
24 
Q Are you — are you suggesting that Jane Doe 3 
25 
is lying because, in your mind, she has an attorney who 
3. 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
23. 
22 
23 
24 
25 
Page 99 
was disbarred? 
MR. PIKE: Form. 
THE WITNESS: I would let the jury decide that 
fact. My suggestions — I'd like to answer every 
one of your questions here today. I'd like to 
respond regarding the — her attorney that was 
disbarred. I'd like to answer questions with 
respect to Mr. Edwards' partner who sits in jail 
for crafting cases of a sexual nature, making 
allegations against people like me and others; 
however today, on advice of counsel, Mr. Horowitz, 
I am going to have to assert my — under — under 
advice of counsel, I am going to have assert my 
Sixth Amendment, Fourteenth Amendment and Fifth 
Amendment Rights, and Pm told that if I choose to 
answer that question, I risk losing their 
representation, so unfortunately, I cannot answer 
that today. 
BY MR. HOROWITZ: 
Q Is it your contention today that Scott 
Rothstein fabricated Jane Doe 3's lawsuit? 
MR. PIKE: Fain. 
MR. HOROWITZ: I would like to answer that 
question. I would like to answer -- I believe your 
partner, Mr. Herman, was disbarred after filing the 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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24 
25 
1 
2 
3 
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5 
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7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
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Page 100 
lawsuit. I'd like to answer every one of your 
questions here today; however, on advice of my 
counsel, I'm told that I must assert my Sixth 
Amendment, Fourteenth Amendment and Fifth Amendment 
Rights, and if I choose to answer that question. I 
risk losing their representation. So, though I 
would like to answer that question, as you probably 
understand, I cannot do so today. 
BY MR. HOROWITZ: 
Q When Jane Doe 3 was at your home, she told you 
she attended 
didn't she? 
MR. PIKE: Form. 
THE WITNESS: I'd like to answer every one of 
your questions here today. Mr. — Horowitz, right, 
Horowitz? 
MR. HOROWITZ: (Nods head). 
THE WITNESS: However, on advice of counsel, I 
cannot answer those questions. They've asked me to 
assert my Sixth Amendment, Fourteenth Amendment and 
Fifth Amendment Rights. And if I choose to answer, 
I risk losing their representation. Though your 
partner after filing this lawsuit was disbarred 
firm the Florida Bar, the — your — the man 
sitting to your right, his partner sits in jail 
accused of the largest fraud in South Florida's 
Page 101 
history for crafting —
MR. HOROWITZ: Uh-huh. 
THE WITNESS: — cases of a sexual nature 
against me and people like me. I would like to 
answer those questions, but unfortunately today, I 
cannot do so. 
• 
BY MR. HOROWITZ: 
Q You were nude in front of Jane Doe 3 in 2004, 
weren't you? 
MR. PEKE: Form. 
MR. HOROWITZ: I'd like to answer each and 
every one of your questions here today, Mr. 
Horowitz; however, on the advice of my counsel, I 
cannot. They've advised me I must assert my Sixth 
Amendment Rights, Sixth Amendment, Fourteenth 
Amendment and Fifth Amendment Rights, so that to 
any question that might be relevant to any of your 
lawsuits crafted by your partner, who I believe has 
been disbarred since filing the lawsuits, and 
Mr. Edwards sitting there with his partner, Mr. 
Rothstein, who's currently sitting in jail for 
crafting cases of a sexual nature against people 
like me and others, I'd like to answer each and 
every one of your questions; however today, my --
on advice of counsel, I cannot do so. 
UNIVERSAL COURT REPORTING 
26 (Pages 98 to 101) 
( 
( 
) 
EFTA01076675

Page 102 
1 
BY MR. HOROWITZ: 
2 
Q In 2004 did you instnict Jane Doe 3 to remove 
3 
her clothing? 
4 
MR. PIKE: Form. 
5 
MR. HOROWITZ: Can you repeat the question? 
6 
BY MR. HOROWITZ: 
7 
Q Remember we — we have been talking about Jane 
8 
Doe 3. 
9 
A I'm doing my best. 
10 
Q In 2004 did you instruct Jane Doe 3 to remove 
11 her clothing? 
12 
MR. PIKE: Font 
13 
THE WITNESS: I would like to answer that 
14 
question. I would like to answer each and every 
15 
one of your other questions here today. However, 
16 
upon advice of my counsel, they've advised me I 
17 
must assert my Sixth Amendment, Fourteenth 
18 
Amendment and Fifth Amendment Rights. So, though 
19 
I'd Bice to answer these questions posed by you 
20 
your partner who's been disbarred, Mr. Edwards' 
21 
partner who sits in jail for crafting lawsuits of a 
22 
sexual nature against people like me and others —
23 
so, though I would like to answer those questions 
24 
with great specificity, I cannot under the advice 
25 
of counsel, so therefore, I'm sorry. 
Page 103 
1 
BY MR. HOROWITZ: 
2 
Q In 2004 did you instruct Jane Doe 3 to pinch 
3 
your nipples and rub your chest? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: N like to answer that 
6 
question. Id like to answer that question very 
much. However, on advice of counsel, they've 
8 
instructed me that I cannot answer any questions 
9 
today that may be relevant to any of your lawsuits 
10 
filed by you, your partner. Jeffrey Herman, that 
11 
was disbarred by the Florida Bar Association after 
12 
filing these lawsuits, questions posed by Mr. 
13 
Edwards and his firm whose partner sits in jail 
14 
accused by the U.S. Attorney of perpetrating the 
15 
largest fraud in U.S. history by fabricating —
16 
totally fabricating cases against people like me 
17 
and others. Though I would like to answer those 
18 
questions, I am going to have to assert my Sixth 
19 
Amendment, Fourteenth Amendment and Fifth Amendment 
20 
Rights as advice of — upon advice of counsel. 
21 BY MR. HOROWITZ: 
22 
Q In 2004 did you ask Jane Doe 3 questions about 
23 
her sexual experience and preferences? 
24 
MR. PIKE: Font 
25 
THE WITNESS: I'd like to answer that 
at...n.901 
C 
Page 104 
1 
question. Id like to answer every question you've 
2 
asked here today. However, upon advice of counsel, 
3 
theyve advised me I must assert my Sixth 
4 
Amendment, Fifth Amendment and Fourteenth Amendment 
5 
Rights — so that cases brought by attorneys like 
6 
you and your partner, Jeffrey Herman, who held a 
7 
press conference on the streets outside Palm Beach, 
8 
he was brought — then later disbarred by the 
9 
Florida Bar Association -- Ed like to answer every 
10 
one of your questions. However, today, on advice 
11 
of counsel, I cannot. 
12 
BY MR. HOROWITZ: 
13 
Q In 20O4didyou 
for 
14 
your own sexual gratification? 
15 
MR. PIKE: Form. 
16 
THE WITNESS: I'd like to answer each and every 
17 
one of your questions posed today, Mr. Horowitz. 
18 
However, at least today upon advice of counsel, I 
19 
— I cannot answer those questions, and I — and 1 
20 
must assert, on advice of my counsel, my Sixth 
21 
Amendment, Fifth Amendment and Fourteenth Amendment 
22 
Flights under the U.S. Constitution. And though 
23 
this lawsuit brought by you and your partner who's 
24 
been disbarred by the Florida Bar Association after 
25 
bringing this lawsuit, sitting next to Mr. Edwards 
Page 105 
1 
whose partner sits in jail for bringing cases of a 
2 
sexual nature, fabricated cases of a sexual nature, 
3 
and fleecing investors out of millions of dollars 
4 
in South Florida, I'd like to answer each and every 
5 
one of your questions. However today, I cannot do 
6 
so upon advice of counsel. 
7 
BY MR. HOROWITZ: 
8 
Q
in 2004 did you touch 
for 
9 
your own sexual gratification? 
10 
MR. PIKE: Form. 
11 
THE WITNESS: I'd like to answer that 
12 
question. I'd very much like to answer that 
13 
question, like all the other questions you've asked 
14 
here today, questions posed by your firm, your 
15 
partner, Jeffrey Herman, whose been disbarred by 
16 
the Florida Bar Association after bringing this 
17 
case, Mr. Edwards' partner, Scott Rothstein, whose 
18 
purpose was — according to the U.S. Attorney, ran 
19 
with Mr. Edwards and part of the firm, the largest 
20 
fraud — one of the largest frauds in South 
21 
Florida's history for fabricating cases, misleading 
22 
investors, fleecing unsuspecting investors out of 
23 
millions of dollars by fabricating cases of a 
24 
sexual nature against people like me and others. 
25 
However, my counsel today has advised me that I 
UNIVERSAL COURT REPORTING 
IIIIIIIIIIIII/ 
( 
27 (Pages 102 to 105) 
( 
) 
EFTA01076676

Page 106 
1 
cannot answer those questions — any questions that 
2 
may be relevant to any of your lawsuits. So, 
3 
though I would like to answer that question today, 
4 
I am going to have to rely on my counsel's advice. 
5 
BY MR. HOROWITZ: 
6 
Q In 2004 did you rub 
7 
MR. PIKE: Fonn. 
B 
THE WITNESS: Excuse me. I'd like to answer 
9 
that question, as I would like to answer mostly 
10 
every question you've asked me hem today; however, 
11 
upon advice of counsel, I cannot answer that 
12 
question. They've advised me I must assert my 
13 
Sixth Amendment, Fifth Amendment and Fourteenth 
14 
Amendment Rights against self excuse me, against 
15 
-- under the U.S. Constitution. And though your 
16 
partner, Jeffrey Herman, was disbarred after filing 
17 
this lawsuit, Mr. Edwards' partner sits in jail for 
18 
fabricating cases of a sexual nature, fleecing 
19 
unsuspecting Florida investors and others out of 
20 
millions of dollars for cases of a sexual nature 
21 
with — I'd like to answer your questions; however, 
22 
if I 
I'm told that if I do so, I risk losing my 
23 
counsel's representation; therefore, I must accept 
24 
their advise. 
25 
BY MR. HOROWITZ: 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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24 
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Page 108 
assert my Sixth Amendment, Fourteenth Amendment and 
Fifth Amendment Rights, not to answer that 
question. Ed like to answer it, though your 
partner who brought this lawsuit has been disbarred 
after bringing the lawsuit. Mr. Edwards' partner 
who sits next to you, his partner sits in jail for 
fabricating cases of a sexual nature against people 
like me, fleecing people out of millions of dollars 
because this is about - about - of money. Just a 
money, money case. I'd like to answer those 
questions, Mr. Horowitz. However, my counsel today 
has said, I cannot answer any questions today that 
may be relevant to this lawsuit, and I must accept 
their advice, or risk losing their representation. 
BY MR. HOROWITZ: 
Q In 2004 did you ejaculate in front of Jane Doe 
3? 
MR PIKE: Form. 
THE WITNESS: rd like to answer that question. 
However, today my counsel has advised me that I 
cannot answer any questions that may be relevant to 
your lawsuits, and Fm going to have to answer that 
question as I've answered most of your other 
questions here today. This is no different than 
the other questions I've had to answer where my 
Page 107 
1 
In 2004 did ou try to insert your fingers into 
2
3 
MR. PIKE: Form. 
4 
THE WITNESS: I'd like to answer that 
5 
question. I'd like to answer every one of your 
6 
questions here today; however, my counsel has 
7 
advised me that I cannot answer any questions that 
8 
may be relevant to any of your lawsuits brought by 
9 
you and your disbarred partner, Jeffrey Herman, or 
10 
the questions by Mr. Edwards' partner, Scott — his 
11 
firm, Scott Rothstein's fir, who -- Scott 
12 
Rothstein sits in jail for fabricating cases of a 
13 
sexual nature — excuse me —
14 
MR. HOROWITZ: Continue. 
15 
THE WITNESS: So, though I'd like to answer 
16 
that question, as Pa like to answer each and every 
17 
one of your questions today, I cannot do so on --
18 
upon advice of counsel. 
19 
BY MR. HOROWITZ: 
20 
Q In 2004 did you masturbate in front of Jane Doe 
21 
3? 
22 
MR. PIKE: Form. 
23 
THE WITNESS: I'd like to answer each and every 
24 
one of your questions, especially that one today; 
25 
however, my counsel has advised me that I must 
Page 109 
1 
counsel has advised me that I have to take these 
2 
rights, but I prefer to answer, but if I do so, I 
3 
risk losing their representation. And, though 
4 
posed by you and your partner, Jeffrey Herman, that 
5 
was disbarred after filing these lawsuits, sitting 
6 
next to Mr. Edwards, whose partner sits in jail 
7 
accused of the largest - perpetrating the largest 
8 
- one of the largest Melds in South Florida's 
9 
history, accused by the U.S. Attorney of being a 
10 
his firm of being a criminal enterprise, I'd like 
11 
to answer each and every one of your questions; 
12 
however, today under the advice of counsel, I 
13 
cannot 
14 
BY MR. HOROWITZ: 
15 
Q Did you have sexual contact with Jane Doe 3 
16 
during a massage in 2004? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: I'd like to answer that question, 
19 
as I'd like to answer each and every one of your 
20 
other questions here today. However, upon the 
21 
advice of counsel, I cannot. And they've asked me 
22 
that -- they've required me to assert my Sixth 
23 
Amendment, Fourteenth Amendment and Fifth Amendment 
24 
Rights as provided by the U.S. Constitution. 
25 
Though your firm's partner sits disbarred --
28 (Pages 106 to 109) 
UNIVERSAL COURT REPORTING 
EFTA01076677

Page 110 
1 
Jeffrey Herman is disbarred after he brought this 
2 
case, Mr. Edwards' partner sits in jail accused by 
3 
the 
I Attorney of perpetrating the largest fraud 
4 
in U.S. or south Florida's history for fabricating 
5 
cases of a sexually charged nature against me and 
6 
people like me. So, though I would like to answer 
7 
your questions with specificity, Mr. Horowitz, I 
8 
cannot do so here today upon advice of counsel. 
9 
BY MR. HOROWITZ: 
10 
Q During her first visit in 2004 to your home, 
11 
did you pay $200 to Jane Doe 3 after you had sexual 
12 
contact with her? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: I'd like to answer that 
15 
question. I'd really like to answer that 
16 
question. I cannot do so, however, because my 
17 
counsel has told me that I cannot answer any 
18 
questions relevant — that may be relevant to any 
19 
of your lawsuits filed by you and your partner, 
20 
Jeffrey Herman, who was disbarred — disbarred by 
21 
the Florida Bar Association after filing these 
22 
lawsuits, or Mr. Edwards' partner who sits in jail 
23 
accused of perpetrating one of the largest frauds 
24 
in South Florida's history, fleecing South Florida 
25 
investors of millions of dollars by crafting, 
Page 111 
1 
fabricating and falsely creating cases of a sexual 
2 
nature against people like me and others in order 
3 
to simply gain money. So, though I'd like to 
4 
answer your questions, Mr. Horowitz, I am going to 
5 
have to answer this question, as I've answered most 
6 
of your questions here today, which is on the 
7 
advice of counsel I cannot answer. 
8 
BY MR. HOROWITZ: 
9 
You never asked Jane Doe 3 for permission to 
10 
did you? 
11 
MR. PIKE: Form, asked and answered. 
12 
THE WITNESS: I'd like to answer that question, 
13 
as I would like to answer most of your other 
14 
questions here today. However, upon advice of my 
15 
counsel -- excuse me -- they've instructed me that 
16 
I must assert my Sixth Amendment, Fourteenth 
17 
Amendment and Fifth Amendment Rights of provided 
18 
by the U.S. Constitution. And, though you, your 
19 
partner, Jeffrey Herman — excuse me — who was 
20 
disbarred by the Florida Bar Association after 
21 
filing this case and your other cases, or Mr. 
22 
Edwards' partner who sits in jail — sits in jail, 
23 
accused of perpetrating one of the largest frauds 
24 
in Florida's history by maliciously fabricating 
25 
cases of a sexual nature against me and other 
Page 112 
1 
people like me. So as you might imagine, I would 
2 
like to answer these questions, but like the other 
3 
questions I've asked — I've answered here today, I 
4 
am going to have to accept my attorney's counsel or 
5 
risk losing their representation. 
6 
BY MR. HOROWITZ: 
7 
Q In fact, sir, Jane Doe 3 indicated to you that 
8 
she did not want you to 
isn't that 
9 
correct? 
10 
MR. PIKE: Fonn. 
11 
THE WITNESS: I'd like to answer all your 
12 
questions here today, Mr. Horowitz. I would really 
13 
like to answer that question specifically. 
14 
However, as I sit here today, my counsel has 
15 
advised me that I must assert my Sixth Amendment 
16 
Rights, my Fourteenth Amendment Rights and my Fifth 
17 
Amendment Rights as provided by the U.S. 
18 
Constitution. So, though you and your partner. 
19 
Jeffrey Herman, who filed this lawsuit, held a 
20 
press conference in Palm Beach months before he 
21 
became disbarred -- disbarred — he's no longer an 
22 
attorney is my understanding now, but he was 
23 
disbarred by the Florida — the Florida Bar 
24 
Association, or Mr. Edwards' partner who sits in 
25 
jail accused of fabricating cases strictly to get 
1 
2 
3 
4 
5 
6 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 113 
money from Florida investors, from Florida people, 
I'd like to answer each and every one of your 
questions, Mr. Horowitz, but today, on advice of 
counsel, I cannot. 
BY MR. HOROWITZ: 
as se a in
...Me 
t 
Q Sir, you touched 
while she w 
you she dad not want you to touch her; isn't that right? 
MR. PIKE: Form, asked and answered. 
THE WITNESS: I'd lila to answer each and every 
one of your questions today, Mr. Horowitz, 
however, upon advice of my counsel I cannot. 
They've asked me -- they've required me to assert 
my Sixth Amendment, Fourteenth Amendment and Fifth 
Amendment Rights as provided by the U.S. 
Constitution to any questions that may be relevant, 
or may become relevant to this lawsuit. So, though 
your partner was disbarred after you filed this 
claim, or your firm filed this claim, Mr. Edwards 
who sits next to you, his partner sits in jail, so 
I'd like to answer each one of these questions. 
However, today, on the advice of counsel, I cannot. 
BY MR. HOROWITZ: 
Q Did you try to persuade Jane Doe 3 that it was 
okay for you to 
29 (Pages 110 to 113) 
UNIVERSAL COURT REPORTING 
(IIIII) 
EFTA01076678

Page 114 
Page 116 
1 
MR. PIKE: Form. 
2 
THE WITNESS: I would like to answer each and 
3 
every one of your questions here today, 
4 
Mr. Horowitz, however, upon advice of counsel, I'm 
5 
— they've required me to assert my Fourteenth 
6 
Amendment, Sixth Amendment and Fifth Amendment 
7 
Rights as provided by the U.S. Constitution. So, 
8 
although I would like to answer that question, and 
9 
respond to questions posed by you, for, I guess, 
10 
your partner, Mr. Herman, who has been disbarred by 
11 
the Florida Bar Association after filing these 
12 
cases, disbarred, or Mr. Edwards' partner who sits 
13 
next to you, has filed other cases where his 
14 
partner sits in jail for fabricating cases, trying 
15 
to get money from Florida investors, I'd lace to 
16 
answer each one of your questions here today Mr. 
17 
Horowitz, but upon advice of counsel, they've 
18 
advised me that if I do so, I risk losing their 
19 
representation, so I must accept their advice. 
20 
BY MR. HOROWITZ: 
21 
Q Mr. Epstein, you don't deny that you sexually 
22 
abused Jane Doe3 when she was a child, do you? 
23 
MR. PIKE: Form. 
24 
THE WITNESS: I would like to answer every one 
25 
of your questions here today, Mr. Horowitz, but 
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 
MR. PIKE: Form, asked and answered. 
THE WITNESS: I would like to answer every one 
of your questions, Mr. Horowitz, posed here today. 
Unfortunately, I guess, your — your other partner 
who filed these lawsuits has been disbarred in the 
interim by the Florida Bar Association, so he's not 
here today. However, I'd like to answer those 
questions, but my counsel has told me that I have 
to assert my Sixth Amendment, Fifth Amendment and 
Fourteenth Amendment Rights as provided by the U.S. 
constitution. So, though I would like to answer 
your questions, Mr. Edwards' questions whose 
partner sits in jail for perpetrating one of the 
largest frauds in South Florida's history, accused 
by the U.S. Attorney — his firm accused by the 
U.S. Attorney is now -- the firm is bankrupt by 
perpetrating the -- one of the largest frauds in 
South Florida's history and being called a criminal 
enterprise by the current South Florida's U.S. 
Attorney, I would like to answer every one of your 
question, very much so, however, my -- on advice of 
counsel, I cannot do so here today. 
BY MR. HOROWITZ: 
Q Sir, is there any reason in your mind that a 
jury should not infer from your assertion of the Fifth 
Page 115 
1 
like in response to most of your other questions 
2 
here today, I cannot. On the advice of counsel, 
3 
they've told me I must accept their advice or risk 
4 
losing their representation. They've advised me 
5 
that I must assert my Sixth Amendment, Fourteenth 
6 
Amendment and Fifth Amendment rights. So, though 
7 
your partner, Jeffrey Herman, was disbarred after 
8 
filing these cases, disbarred, no longer an 
9 
attorney, Mr. Edwards' partner who sits to your 
10 
right, his partner sits in. I believe, Saint Luck 
11 
Jail according to today — today's newspaper, 
12 
accused of perpetrating the largest fraud in South 
13 
Florida history against people like me, crafting. 
14 
fabricating, malicious sexually charged -- cases of 
15 
a sexually charged nature in order to fleece 
16 
investors, I would like to answer that question. 
17 
However today, I must accept my client's —
18 
attorney's advice. 
19 
BY MR. HOROWITZ: 
20 
Q Mr. Epstein, did you instruct 
to take Jane 
21 Doe 3's name and telephone number for the purpose of 
22 
calling her home - strike that. 
23 
Did you instruct It 
to take Jane Doe 3's name 
24 
and telephone number for the purpose of calling Jane Doe 
25 
3 to come to your home for sexual activity? 
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 117 
Amendment privilege, that you sexually abused Jane Doe 3 
when she was a child? 
MR. PIKE: Form, speculation, calls for a legal 
conclusion. 
THE WITNESS: The Supreme Court has said that 
the Fifth Amendment should be used by people who 
are innocent, Mr. Horowitz. That's one of the 
benefits of the Fifth Amendment. My counsel has 
advised me I cannot answer your questions here 
today, though I'd like to. I'm sure this — these 
soft of embarrassing questions posed for the jury 
where your partner has been disbarred since filing 
this claim, or Mr. Edwards' partner who sits in 
jail probably for the rest of his life for crafting 
cases of a sexual nature to fleece people for -- of 
money, just money, money, money. His firm is 
bankrupt. So, yes, Pd like to answer these 
questions, and all your questions here today, but 
unfortunately, on advice of counsel, I cannot. 
BY MR. HOROWITZ: 
Q Sir, are you asserting your Fifth, Sixth and 
Fourteenth Amendment privileges because you're 
innocent? Is that what you're telling us? 
MR. PIKE: Form. 
THE WITNESS: I would like to answer every one 
UNIVERSAL COURT REPORTING 
30 (Pages 114 to 117) 
( 
) 
EFTA01076679

Page 118 
1 
of your questions posed by you, your partner, Mr. 
2 
Herman, who's been disbarred by the Florida Bar 
3 
after filing this claim, Mr. Edwards' partner who 
4 
sits in jail, his firm accused by the U.S. Attorney 
5 
— accused by the U.S. Attorney of being a criminal 
6 
enterprise, for fleecing South Florida investors 
7 
out of millions of dollars by crafting, malicious, 
8 
fabricated cases of a sexual nature against people 
9 
— other people 
me and others, I would like to 
10 
answer each and every one of your questions. 
11 
However today, on advice of counsel, I cannot 
12 
answer any of your questions that may be relevant 
13 
to this lawsuit. 
14 
BY MR. HOROWITZ: 
15 
Q Sir, you know I also represent Jane Doe Number 
16 
4, do you understand that? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: Yes. 
19 
BY MR. HOROWITZ: 
20 
Q Okay. Isn't it true, sir, that a girl named 
21 
Jane Doe 4 came to your Palm Beach home on multiple 
22 
occasions between 2003 and 2005? 
23 
A Could we take a break? Is that it? 
24 
Q I would like you to answer that question. 
25 
A Sony. I'd like to answer that question. I'd 
Page 119 
1 
like to answer every question you've posed here today 
2 
about you — about these girls you say came to my 
3 
house. However, on advice ofcounsel, I cannot answer 
4 
that question today. I have to assert, on the advice --
5 
my Sixth Amendment, Fifth Amendment and Fourteenth 
6 
Amendment Rights. 
7 
rd like to answer that question about Jane Doe 
8 
4, and I believe she was represented by your partner, 
9 
Jeffrey Herman, who after representing her was disbarred 
10 
by the Florida Bar Association. 
11 
Mr. Rothstein — or Mr. Edwards' partner, 
12 
Mr. Rothstein, who sits in jail accused by the Florida 
13 
U.S. Attorney of running a criminal enterprise in 
14 
Mr. Edwards' firm, fabricating malicious cases to fleece 
15 
investors out of millions of dollars, fabricating cases 
16 
of a sexual nature, I would like to answer every one of 
17 
your questions here today. However, on advice of 
18 
counsel, I cannot do so. 
19 
MR. HOROWITZ: Did you want that break now? 
20 
THE WITNESS: Yes, please. 
21 
MR. PIKE: No, actually before we take a 
22 
break — 
23 
MR. HOROWITZ: Okay. 
24 
MR. PIKE: - my understanding was, is that you 
25 
wanted to take a break around 12:30 or 12:45 for 
Page 120 
1 
lunch. It is 12:35 right now. If you want to keep 
2 
going for another 10 minutes, we'll go for another 
3 
10 minutes, or if you want to just break now for 30 
4 
minutes, go grab something to eat, and then come 
5 
back 
6 
MR. HOROWITZ: Yeah. I mean, this line of 
7 
questioning is going to be more than 10 minutes, so 
8 
I would suggest we take our break now. 
9 
MR. PIKE: You want to take lunch right now? 
10 
MIL HOROWITZ: Yeah. 
11 
MR. PIKE: Okay. 
12 
THE WITNESS: All right. Thank you. 
13 
THE VIDEOGRAPHER: Time off the record 12:30. 
14 
(Thereupon, a lunch break was taken.) 
15 
THE VIDEOGRAPHER: Time on the record 1:11. 
16 
This is Tape 3. 
17 
BY MR. HOROWITZ: 
18 
Q Mr. Epstein, did you pays $200 to bring a 
19 
girl named Jane Doe 4 to your home so that you could 
20 
engage Jane Doe 4 in sexual activity? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: Mr. Horowitz, I'd like to answer 
23 
that. I am going to have to answer that question, 
24 
as I've answered most of your questions here today, 
25 
which is upon advice of counsel, I am going to have 
Page 121 
1 
to assert my Sixth Amendment, Fourteenth Amendment 
2 
and Fifth Amendment Right, though I'd like to 
3 
answer that question. 
4 
I'd also like to correct some of the — a 
5 
previous statement I made regarding your partner 
6 
that he had been disbarred. I understand he wasn't 
7 
disbarred, but he was simply suspended for improper 
8 
behavior, suspended by the Florida Bar. So I would 
9 
like to make the correction that he's not totally 
10 
disbarred, but he's no longer practicing for the 
11 
time being. So 
but on advice of counsel, at 
12 
least with respect to this question, or any 
13 
question that may be relevant to this lawsuit, my 
14 
counsel has told me I must assert those rights. 
15 
BY MR. HOROWITZ: 
16 
Q Okay. And if I'm hearing you correct, your 
17 
testimony that Mr. Herman was disbarred is — was 
18 
erroneous; is that right? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: My testimony that your partner 
21 
who filed these lawsuits was disbarred seems to be 
22 
incorrect. He was -- according to what I was told, 
23 
he has only been disbarred for his greatly improper 
24 
behavior, but — and so he— one day he will, in 
25 
fact, be practicing law again in South Florida — 
UNIVERSAL COURT REPORTING 
31 (Pages 118 to 1 2 1) 
) 
EFTA01076680

Page 122 
Page 124 
1 
MR. HOROWITZ: Okay. 
2 
THE WITNESS: — unlike Mr. Edwards' partner 
3 
who currently sits in jail for perpetrating one of 
4 
the largest frauds in South Florida's history. 
5 
BY MR. HOROWITZ: 
6 
Q Okay. I'm glad we got that squared away. 
7 
Did you pay Jane Doe 4 to bring other minor 
8 
girls to your home for your own sexual gratification? 
9 
MR. PIKE: Form. 
3.0 
THE WITNESS: That question I believe would —
11 
is — is I would like to answer that question. 
12 
Unfortunately, my counsel has advised me that I 
13 
cannot answer any questions today that may become 
14 
relevant to any of your lawsuits filed by you and 
15 
your currently suspended partner, suspended by the 
16 
Florida Bar, or answer questions relevant to Mr. 
17 
Edwards who is sitting on your right, his firm's 
18 
partner who's sitting in jail for fabricating cases 
19 
of a sexual nature against people like me and 
20 
others. 
21 
I'd like to answer -- as you might imagine, I'd 
22 
like to answer these questions, but I risk losing 
23 
my counsel if you do so, so I must accept their 
24 
advice today. 
25 
BY MR. HOROWITZ: 
Page 123 
1 
Q Mr. Epstein, at any time before May2005, did 
2 
you receive a phone call from M. that she was bringing 
3 
Jane Doe 4 to your home so that Jane Doe 4 could give 
4 
you a massage? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: I'd like to answer that question, 
7 
but unfortunately, I am going to have to answer 
8 
that question as I've answered most of your 
9 
questions here today, Mr. Horowitz, which is upon 
10 
advice of counsel, they've told me I cannot answer 
11 
your questions no matter how much I want to. They 
12 
told me I have to assert my Sixth Amendment, Fifth 
13 
Amendment and Fourteenth Amendment Rights. 
14 
Though you're currently suspended -- I keep 
15 
saying "disbarred; but I'm not a lawyer, so I 
16 
don't really understand the difference between 
17 
disbarred and suspended -- he seems to be only 
18 
suspended by the Florida Bar, I — I cannot answer 
19 
that question today upon advice of counsel. 
20 
BY MR. HOROWITZ: 
21 
Q Okay. Sir, at any time before May 2005 did 
22 
you instruct M. to place a telephone call to M., so 
23 
that E. could arrange for Jane Doe 4 to come to your 
24 
home for sexual activity with you? 
25 
MR. PIKE: Form. 
1 
THE WITNESS: I'd like to answer that 
2 
question. I'd lute to answer every specific --
3 
every question you've asked me here today, but I am 
4 
going to have to respond as I've done with most of 
5 
your questions here today, Mr. Horowitz which is 
6 
that upon advice of counsel, I am going to have to 
7 
assert my Sixth Amendment Rights, my Fourteenth 
8 
Amendment Rights and my Fifth Amendment Rights. 
9 
Though I'd like to answer the question, though I'm 
10 
sure the jury will understand your partner has been 
11 
suspended from practicing law in the State of 
12 
Florida, Mr. Edwards' partner is in jail for 
13 
fabricating cases of a sexual nature, so, though 
14 
I'd like to answer that question as your other 
15 
questions today with specificity, my counsel has 
16 
advised me that if I do so, I risk losing their 
17 
representation, so I must decline to answer. 
18 
BY MR. HOROWITZ: 
19 
Q Did you inform fl
 that the massage Jane Doe 4 
20 
was to give you would be sexual in nature? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: I'd like to answer that question, 
23 
just like rd like to answer each and every one of 
24 
your questions here today, Mr. Horowitz 
25 
Unfortunately, my counsel has advised me I cannot 
Page 125 
1 
answer any questions that may become relevant to 
2 
this lawsuit, or any of the lawsuits filed by you, 
3 
or your partner that's been suspended by the 
4 
Florida Bar from practicing law in the State of 
5 
Florida after he's had conferences, held public 
6 
conferences accusing me of things, of Mr. Edwards' 
7 
partner who sits in jail probably for the rest of 
8 
his life for fabricating cases against people like 
9 
me and others. So, though rd like to answer that 
10 
question, Tm going to have to answer that question 
11 
as I've answered most of your questions here today, 
12 
which is upon advice of counsel, I must refrain 
13 
from answering. 
14 
BY MR. HOROWITZ: 
15 
Q Did you either observe or overhear ■ 
16 
speaking with S 
making arrangements for Jane Doe 4 to 
17 
come to your home for sexual activity? 
18 
MR. PIKE: Form. 
19 
THE WITNESS: I'd like to answer that 
20 
question. Ed really like to answer that 
21 
question. However, today, my counsel has advised 
22 
me that I cannot. And they've advised me I must 
23 
assert my rights under the Sixth Amendment, 
24 
Fourteenth Amendment and Fifth Amendment of the 
25 
U.S. constitution. So, though I'd like to answer 
UNIVERSAL COURT REPORTING 
32 (Pages 122 to 125) 
) 
EFTA01076681

Page 126 
1 
questions posed by you, your partner that's been 
2 
suspended by the Florida Bar after filing these 
3 
types of cases, cases against me, Mr. Edwards who 
4 
sits next to you, his partner in jail for filing 
5 
cases, fabricating cases of a sexually charged 
6 
nature against me and others. The U.S. Attorney 
7 
has accused his firm, his former firm, the firm he 
8 
left now because the firm went bankrupt, for being 
9 
a criminal enterprise, perpetrated one of the 
10 
largest frauds in South Florida's history, fleecing 
11 
investors out of millions and millions of dollars. 
12 
Pd like to answer each and every one of your 
13 
questions, but my counsel has advised me today that 
14 
I cannot. 
15 
BY MR. HOROWITZ: 
16 
Q Prior to May 2005 didn't you instruct Jane Doe 
17 
4 to place phone calls to you on your home phone in 
18 
order to schedule visits to your home? 
19 
MR PIKE: Form. 
20 
THE WITNESS: I'd like to answer each one of 
21 
your questions here today, Mr. Horowitz, that 
22 
question specifically. However, my counsel has 
23 
advised me that today I cannot, and he advised me I 
24 
must assert my Sixth Amendment Rights, my 
25 
Fourteenth Amendment Rights and my Fifth Amendment 
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 128 
counsel. Do you need me to repeat that question to 
refresh your recollection? 
A Yes, please. 
Q Prior to May 2005 did you ever observe M. 
speaking with Jane Doe 4 by telephone to arrange for 
Jane Doe 4 to come to your home to give you a massage? 
A I would like to answer that question -- I 
assume this is the Jane Doe 4 who in her testimony wrote 
a note to me that said "fora good time, call Jane Doe 
4." I assume that's the same Jane Doe 4. 
Unfortunately, I'd like to answer all your questions 
with specificity today, Mr. Horowitz. However, on 
advice of counsel, I cannot. 
Q "Good time 
A Excuse me? 
Q Continue, please. 
A So, therefore, the — and 1 represent — I 
understand you represent Jane Doe 4. I understand your 
partner that's been suspended by the Florida Bar who 
represented Jane Doe 4 in this case — Pd like to 
answer each one of your questions with respect to Jane 
Doe 4. However, I cannot based on advice of counsel, 
and I must assert at their request my Sixth Amendment, 
Fifth Amendment and Fourteenth Amendment Rights under 
the U.S. Constitution. 
Page 127 
1 
Rights. So, though Ed would like to answer 
2 
questions posed by you, your partner who has been 
3 
suspended by the Florida Bar, Mr. Edwards' partner, 
4 
Scott Rothstein, that many people have read about, 
5 
has perpetrated the largest fraud in Florida 
6 
history, specifically for fabricating such cases of 
7 
a sexual nature, fabricating malicious cases in 
8 
order to get money, money, money from people here 
9 
in South Florida. I'd like to answer each and 
10 
every one of your questions, however, upon advice 
11 
of my counsel, they've advised me today I cannot do 
12 
so. 
13 
BY MR. HOROWITZ: 
14 
Q Prior to May 2005 did you ever observe ■ 
15 
speaking with Jane Doe 4 by telephone to arrange for 
16 
Jane Doe 4 to come to your home so that Jane Doe 4 could 
17 
give you a massage? 
18 
THE WITNESS: May I— excuse me, may I have a 
19 
moment with my attorney? 
20 
MR. HOROWITZ: Yes. 
21. 
THE VIDEOGRAPHER: Time off the record 1:20. 
22 
(Thereupon, a short break was taken.) 
23 
THE VIDEOGRAPHER: Time on the record I:23. 
24 
BY MR. HOROWITZ: 
25 
Q Mr. Epstein, you had a moment to speak with 
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 129 
Q When is it that you believe Jane Doe 4 wrote 
you the message you just referred to? 
MR. PIKE: Form. 
THE WITNESS: You know, I'd like to answer all 
those questions with respect to the note that she 
testified to that she wrote saying "for a good time 
call Jane Doe 4." However, on advice of counsel, I 
cannot answer any questions that may be relevant to 
this lawsuit. I'd like to answer each one of your 
questions, but as I've done with most of your other 
questions here today, or those to be posed by 
Mr. Edwards whose partner sits in jail probably for 
the rest of his life to try to get money from 
residents of South Florida, and the biggest fraud 
in South Florida's history, called by the U.S. 
attorney a criminal 
the firm is called a 
criminal enterprise, and I'd like — so I'd surely 
like to answer your question, Mr. Horowitz, 
regarding Jane Doe 4, and — however, on advice of 
counsel at least today, I cannel. 
BY MR. HOROWITZ: 
Q Sir, you said that Jane Doe 4 testified that 
she had written a note to you. Is — was that truthful 
testimony? You acknowledge that she did write such a 
note? 
UNIVERSAL COURT REPORTING 
33 (Pages 126 to 129) 
( 
) 
EFTA01076682

Page 130 
1 
MR. PIKE: Form. 
2 
THE WITNESS: Mr. Horowitz, I'd like to answer 
3 
each and every one of your questions. However, on 
4 
the advice of counsel, I can't answer any of your 
5 
questions with respect to the note that she 
6 
testified she wrote. I can't answer any questions 
7 
separate from — that may be relevant to your 
8 
lawsuit. I can't answer any questions posed by 
9 
you, the attorney sitting next to you whose partner 
10 
sits in jail, your former partner suspended or --
11 
for improper behavior after filing this lawsuit, 
12 
and suspended by the Florida Bar. rd Ince to 
13 
answer every question you ask. However today, 
14 
Mr. Horowitz, I cannot because my counsel is 
15 
telling me if I - if t do, I risk losing their 
16 
representation. 
17 
BY MR. HOROWITZ: 
18 
Q You've read the deposition transcript of Jane 
19 
Doe 4; is that comet? 
20 
MR. PIKE: Form. 
21 
THE WITNESS: You know, again, Mr. Horowitz, I 
22 
would like to answer every one of your questions; 
23 
however, my counsel has told me I cannot. They 
24 
told me 1 must assert my Fifth Amendment, Sixth 
25 
Amendment and Fourteenth Amendment Rights under the 
Page 132 
1 
must assert my Sixth Amendment, Fourteenth 
2 
Amendment and Fifth Amendment Rights. So then my 
3 
— I would like to answer questions posed by you. 
4 
I know your partner could not be here since he was 
5 
suspended by the Florida Bar after filing these 
6 
cases, after holding press conferences he was 
7 
suspended by the Florida Bar. Mr. Edwards, who 
8 
sits on your right, his partner is sitting in jail, 
9 
I'd like to answer every one of your questions. 
10 
However, my counsel said at least today, I cannot 
11 
So I must accept their advice or risk losing their 
12 
representation. 
13 
BY MR. HOROWITZ: 
14 
Q Did 
tell you that she confirmed by 
15 
telephone that Jane Doe 4 would be coming to your home 
16 
at a specific time to give you a massage? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: Again. I'm sorry, could you 
19 
repeat the question? 
20 
BY MR. HOROWITZ: 
21 
Q Did M. tell you that she had confirmed by 
22 
telephone with Jane Doe 4 that Jane Doe 4 would be 
23 
coming to your home at a particular time to receive a 
24 
massage? 
25 
MR. PIKE: Form. 
Page 131 
1 
U.S. Constitution. So in response to that 
2 
question, as in response to most of your other 
3 
questions here today, no matter how much I would 
4 
like to answer those questions, answer those 
5 
questions specifically with respect to Jane Doe 4 
6 
and the -- your former partner — wait 
as a 
7 
current partner, you won't tell me -- but your 
8 
partner who brought the lawsuit who the Florida Bar 
9 
suspended for improper behavior, Mr. Edwards' 
10 
partner who sits in jail for fabricating cases, 
11 
stealing millions of dollars from unsuspecting 
12 
Florida investors, rd like to answer every one of 
13 
your questions. However, my counsel told me today 
14 
that I cannot answer any questions that may be 
15 
relevant to the lawsuit. 
16 
BY MR. HOROWITZ: 
17 
Q Prior to May 2005 did you instruct M. to get 
18 
Jane Doe 4's phone number, so that M. could 
19 
communicate with Jane Doe 4 to schedule Jane Doe 4 for 
20 
massages with you? 
21 
MIL PIKE: Form. 
22 
THE WITNESS: rd like to answer that 
23 
question. I would like to answer your other 
24 
questions posed here today. However, my -- on 
25 
advice of counsel, they've instructed me that I 
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 133 
THE WITNESS: I assume when you say "Jane Doe 
4," this is Jane Doe 4, a girl who testified that 
she wrote a note to me that said "for a good time, 
call Jane Doe 4." I assume that's the same Jane 
Doe 4. I'd like to answer all questions about Jane 
Doe 4, her notes, anything that she said. However, 
my attorneys told me I cannot, and they advised me 
I must assert my rights under the Sixth Amendment, 
Fourteenth Amendment and Fifth Amendment, though 
your partner who filed the lawsuit was suspended by 
the Florida Bar after filing the lawsuit, holding 
press conferences. Mr. Edwards' partner sits in 
jail for fabricating cases of a sexual nature 
against me and others. So, though I would like to 
answer those questions, as you might imagine, 
Mr. Horowitz, is I'd like to answer --
unfortunately, as I've had to answer most of your 
questions here today, I cannot under advice of 
counsel. 
BY MR. HOROWITZ: 
Q Was it your intent during the course of Jane 
Doe 4's visits to your home that you would persuade, 
induce or entice her to engage in sexual activity with 
you? 
MR. PIKE: Form. 
34 (Pages 130 to 133 ) 
UNIVERSAL COURT REPORTING 
EFTA01076683

Page 134 
1 
THE WITNESS: Well, I assume this the Jane Doe 
2 
4 who wrote a note to me, according to her 
3 
testimony that said, "for a good time, call Jane 
4 
Doe 4." !assume that's the same Jane Doe 4 you're 
5 
referring to. 
6 
Unfortunately, your partner couldn't be here 
7 
referring to it because he's been suspended by the 
8 
Florida Bar after filing Jane Doe 4's case. 
9 
Mr. Edwards' partner can't be here because he's 
10 
in jail for filing cases of a malicious nature, of 
11 
sexual cases, fabricated cases. The U.S. Attorney 
12 
Has referred to the entire firm as a criminal 
13 
enterprise, a criminal enterprise of the large —
14 
purporting to have the largest fraud in South 
15 
Florida's history. So, though I would like to 
16 
answer each one of your questions, on advice of 
17 
Counsel today, I cannot. 
18 
BY MR. HOROWITZ: 
19 
Q During the course of Jane Doe 4's visits to 
20 
your home, did you in fact persuade, induce or entice 
21 
her to engage in sexual activity with you? 
22 
A 
I'd very much like to answer each one of your 
23 
questions here today, Mr. Horowitz. However, as I've 
24 
done for mostly all of your other questions, on advice 
25 
of counsel, they've told me I cannot answer those 
Page 135 
1 
questions. rd love to answer the questions directly to 
2 
you. 
3 
I'd like to answer the questions to your 
4 
partner, Jeffrey Herman. Jeffrey Herman who was —
5 
after he filed this Jane Doe 4 case against me -- was 
6 
suspended by the Florida Bar for improper behavior, or 
7 
Mr. Edwards' partner who sits in jail. I much prefer to 
8 
be talking to them. However, I cannot answer questions 
9 
to you, and on advice of counsel, I must assert my 
10 
rights, or risk losing their representation. 
11 
BY MR. HOROWITZ: 
12 
Q You know that Jane Doe 4 was younger than 18 
13 
when she came to your home in 2003 and 2004, correct? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: I'd like to answer that 
16 
question. I'd like to answer each and every one of 
17 
your questions. However, on advice of counsel, 
18 
they've instructed me that I cannot answer any 
19 
questions that may be relevant to any of your 
20 
lawsuits brought by either you, your partner that's 
21 
been suspended by the Florida Bar for improper 
22 
behavior, Mr. Edwards, who sits to your right, 
23 
whose partner sits in jail for bringing fabricated 
24 
cases of a sexual nature against people like me and 
25 
others, called — his firm called a criminal 
Page 136 
1 
enterprise by the U.S. attorney for stealing 
2 
millions of dollars from South Florida residents. 
3 
I'd like to answer every one of your questions. 
4 
However, today, under advice of counsel, I cannot. 
S 
BY MR. HOROWITZ: 
6 
ane Doe 4 told ou that she attended 
7 
when she was in your home; is 
8 
that right? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: I'd like to answer that 
11 
question. I'd lice to answer every question you've 
12 
asked me here today. However, upon advice of 
13 
counsel at least today, I cannot, according to 
14 
their advice, answer any questions that may be 
15 
relevant to this lawsuit — excuse me — I would 
16 
prefer to have had your partner, Jeffrey Herman, 
17 
who — who I actually believe filed the suit, but 
18 
he's been disbarred in the interim — I'm sorry, 
19 
not disbarred. He's been suspended. I'm not 
20 
really sure what the difference is, but he's been 
21 
suspended from practicing law, while Mr. Edwards' 
22 
partner sits in jail for fabricating cases of a 
23 
sexual nature against people like me and others. 
24 
So, though I would like to answer that question, as 
25 
you probably understand, on the advice of counsel 
Page 17 
1 
today,lcannot. 
2 
BY MR. HOROWITZ: 
3 
Q Isn't it true, sir, that on multiple occasions 
4 
Jane Doe 4 discussed her activities at 
5 
with you? 
6 
MR. PIKE: Form. 
7 
THE WITNESS: Again? 
8 
BY MR. HOROWITZ: 
9 
Q Isn't it true, sir, that on multiple 
, asi On \ 
10 
Jane Doe 4 discussed her activities at 
11 
with you? 
12 
MR. PIKE: Form. 
13 
THE WITNESS: 
14 
me? 
15 
MR. HOROWITZ: Yes. 
16 
THE WITNESS: I don't understand the question. 
17 
BY MR. HOROWITZ: 
18 
Q Okay. You know, in your mind, who Jane Doe 4 
19 
is, correct? 
20 
MR. PIKE: Form. 
21 
THE WITNESS: lane Doe 4 is the one girl you 
22 
told - I believe was the one who testified that 
23 
she wrote a note to me that said "for a good time, 
24 
call Jane Doe 4." Is that the Jane Doe 4 -- you 
25 
can't testify, I'm sorry. Yes, I believe that's 
with 
afeme••• 
UNIVERSAL COURT REPORTING 
35 (Pages 134 to 137) 
) 
EFTA01076684

Page 138 
Page 140 
1 
coma. 
2 
BY MR. HOROWITZ: 
3 
Q Is it your testimony that Jane Doe 4 did not 
4 
write such a note after a massage at your house? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: Which question would you like me 
7 
to answer, the first one or --
8 
MR. HOROWITZ: The one I just asked. 
9 
THE WITNESS: I'd like to answer every question 
10 
with respect to everything with respect to Jane Doe 
11 
4, every single thing. However, my attorneys today 
12 
told me that I cannot, and they instructed me to 
13 
assert the Sixth Amendment, Fourteenth and Fifth 
14 
Amendment. 
15 
BY MR. HOROWITZ: 
16 
Q Isn't it true that Jane Doe 4 
larl 
17 
discussed with you her activities at 
18 
19 
MR. PIKE: Form. 
20 
THE WITNESS: My attorneys told me that, though 
21 
I'd like to answer that question, as I'd like to 
22 
answer all your other questions, I have to answer 
23 
it the same way I've answered the others, which is 
24 
asserting my Sixth Amendment, Fourteenth Amendment 
25 
and Fifth Amendment Rights. 
Page 139 
1 
BY MR. HOROWITZ: 
2 
Q Jane Doe 4 told you she could not travel with 
3 
you OM -H. overseas because she was not yet 18; isn't 
4 
that true? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: I'd like to answer that 
7 
question. I'd hire to answer every one of your 
8 
questions. However, my attorneys today have 
9 
instructed me, at least for today, I can't answer 
10 
any questions that may become relevant to your —
11 
one of your lawsuits brought by your firm and at —
12 
your partner that's been suspended by the Florida 
13 
Bar. 
14 
BY MR. HOROWITZ: 
15 
Q Between 2003 and May 2005, were you ever nude 
16 
in front of Jane Doe 4? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: I would like to answer that 
19 
question. Pd late to answer every one of your 
20 
questions here today. However, my attorneys, who 
21 
have advised me, that I cannot answer any questions 
22 
that may be relevant to this or any of your other 
23 
lawsuits brought by you and your partner that was 
24 
suspended from the practice of the law in Florida, 
25 
so I must respectfully decline. 
1 BY MR. HOROWITZ: 
2 
Q Between 2003 and May 2005, did you ever 
3 
instruct Jane Doe 4 to remove her clothing? 
4 
MR. PIKE: Form. 
5 
P. S: Again, I would like to answer 
6 
every one of your questions, every one, every 
7 
specific one, but my attorneys have advised me that 
8 
today at least, I cannot answer any questions 
9 
relevant, or may be relevant to your lawsuit. 
10 
Theyve instructed me thatlmust assert my Sixth 
11 
Amendment, Fourteenth Amendment and Fifth Amendment 
12 
Rights. So, though I'd like to answer the 
13 
question, Mr. Horowitz, I cannot do so. 
14 
BY MR. HOROWITZ: 
15 
Q Between 2003 and May 2005, did you instruct 
16 
Jane Doe4 to pinch your nipples — 
17 
MR. PIKE: Form. 
18 
BY MR. HOROWITZ: 
19 
Q 
and rub your chest? 
20 
MR. PIKE: Same objection. 
21. 
THE WITNESS: Is it — is it one or the other? 
22 
MR. HOROWITZ: It's both. 
23 
THE WITNESS: I see. No. I would-
24 
BY MR. HOROWITZ: 
25 
Q No you did not, sir? 
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 
THE 
Page 141 
A I said — Tin sorry, I couldn't hear. 
Q I thought you said "no" to my question? 
A No. ITU 
TII tell when my I said no. 
I'd like to answer that question. I'd like to answer 
every one of your questions. I'd like to answer each 
and every one. However, my counsel today told me I 
cannot. They told me I have to assert my Sixth 
Amendment, Fourteenth and Fifth Amendment Rights. And 
if I didn't, and if I chose to answer the question, I 
would risk losing their representation. So at least for 
today, I have to assert those rights. 
BY MR. HOROWITZ: 
Q Prior to June of 2005, did you ask Jane Doe 4 
questions about her sexual experience and preferences? 
MR. PIKE: Fonn. 
THE WITNESS: I would be happy to answer that 
question, if I could. My attorneys have told me I 
can't. They've instructed me that I have to assert 
my Sixth Amendment, Fourteenth Amendment and Fifth 
Amendment Rights. I would like to answer the 
question. However, they told me that if I do, I 
risk losing their representation. 
BY MR. HOROWITZ: 
Prior 
to June 2005 did you 
I 
I 
36 (Pages 138 to 141) 
UNIVERSAL COURT REPORTING 
EFTA01076685

Page 142 
Page 144 
1 
MR. PIKE: Form. 
2 
THE WITNESS: Pd like to answer that 
3 
question. Pd like to answer all your other 
4 
questions here today. However, my counsel has told 
5 
me, at least today, I cannot. I have -- they've 
6 
instructed me to assert my Fourteenth Amendment, my 
7 
Sixth Amendment and my Fifth Amendment Right. And 
8 
they told me that if I chose to answer, I would 
9 
risk losing their representation, so therefore, I 
10 
must respectfully decline to answer them. 
11 
BY MR. HOROWITZ: 
12 
aPrior to June 2005 did you rub 
14 
MR. PIKE: Form. 
15 
THE WITNESS: I would like to answer that 
16 
question with specificity. However, my attorneys 
17 
have told me at least today that I must 
18 
respectfully decline and assert my Fifth Amendment, 
19 
Sixth Amendment and Fourteenth Amendment Right. I 
20 
would have preferred that your partner, who after 
21 
he filed the lawsuit, was suspended by the Florida 
22 
Bar for ingot/put practice, or Mr. Edwards' partner, 
23 
who sits in jail, to have been here to at least ask 
24 
some of the questions, but my attorneys have told 
25 
me I cannot answer those questions today, sir. 
Page 143 
1 
BY MR. HOROWITZ: 
2 
s larior to Jtme 2005 did you 
4 
MR. PIKE: Form. 
3 
A I'd like to answer that question. I'd very 
6 
much like to answer that question, but 1cannot today, 
7 
because on advice of my counsel, they have told me that 
8 
I must assert my Sixth Amendment, Fourteenth Amendment 
9 
and Fifth Amendment Rights. And ill chose to answer, 
10 
if I did answer that question, I risk losing their 
11 
representation, so at least for that -- for today, I 
12 
must respectfully decline, sir. 
13 
BY MR. HOROWITZ: 
14 
Prior to Jtme 2005 did you 
16 
MR. PIKE: Form. 
17 
THE WITNESS: You know, I'd like to answer that 
18 
question. I would have preferred that either your 
19 
partner, who was here, would have been here, the 
20 
one who filed the lawsuit, who is suspended by the 
2/ 
Florida Bar, or Mr. Edwards' partner, Scott 
22 
Rothstein, who sits in jail, was to be here. I 
23 
would prefer to respond to them. However, today, I 
24 
cannot answer those questions based on advice of 
25 
counsel, so I must respectfully decline. 
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 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
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13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
BY MR. HOROWITZ: 
Q Prior to June 2005 did you 
MR. PIKE: Form. 
THE WITNESS: rd like to answer that 
question. I'd like to answer every question you've 
asked here today. I'd like to respond to you to 
your partner who's been suspended. I apologize, 
before I said he was disbarred, but — for improper 
behavior after filing this lawsuit. On advice of 
counsel, they've instructed me that I must assert 
my Fourteenth Amendment, Fifth Amendment and Sixth 
Amendment Rights to any question that may become 
relevant to this lawsuit or risk losing their 
representation, therefore, I would have to 
respectfitlly, respectfully decline. 
BY MR. HOROWITZ: 
Q Prior to June 2005 did you give lingerie to 
Jane Doe 4 to wear for you? 
MR. PIKE: Form. 
THE WITNESS: I would like to answer that 
question. I would like to answer all your 
questions. However, I am going to have to respond 
to that question, as I responded to all your other 
questions here today, Mr. Horowitz, which is on 
Page 145 
advice of counsel, they've instructed me I must 
assert my Sixth Amendment, Fourteenth Amendment and 
Fifth Amendment Rights. And if I chose to answer, 
which I prefer to do, that question, I risk losing 
their representation. 
BY MR. HOROWITZ: 
Q Prior to June 2005 was Jane Doe 4 ever nude in 
front of you at your request? 
A I'd like to answer that question. I'd very 
much like to answer that question. However, my 
attorneys have counseled me that I cannot answer that 
question or any question today that may be relevant to 
one of the lawsuits that you've brought, or your partner 
who has brought — your partner who is suspended from 
practice in Florida. So, though 1 would like to answer 
the question, Mr. Horowitz, today under the advice of 
counsel, I cannot 
Q Prior to June 2005 did you coerce Janc Doe 4 
into 
A Again, I'm so . 
Q If — if — if -- if your attorney passing you 
notes is — is causing you to be distracted from 
listening to my questions, lam — lam going to ask 
that you not do it. 
A I — I understand. 
UNIVERSAL COURT REPORTING 
37 (Pages 142 to 145) 
( 
) 
EFTA01076686

Page 146 
1 
MR. PIKE: Fine. 
2 
THE WITNESS: It was just the fact — it wasn't 
3 
that. It was, in fact, I had put my glasses on. 
4 
BY MR. HOROWITZ: 
5 
Q Your glasses were preventing you from hearing 
6 
me? 
7 
A Yes. 
8 
MR. PIKE: First of all, you're not going to 
9 
tell me how to communicate with my client. I'm 
10 
trying not to take a break again, so that, you 
11 
know, we don't -- we can keep going forward. If 
12 
you'd like me to take a break, I can take another 
13 
break right now. 
14 
MR. HOROWITZ: Well, Pm not here to tell you 
15 
how to do your job, but the Rules of Civil 
16 
Procedure do, and what they say — let me finish --
17 
is that "if you interrupt an examination to 
18 
communicate with your clients, you can be 
19 
sanctioned for it." 
20 
MR. PIKE: Okay. Well, first of all, 
21 
Mr. Horowitz, I didn't interrupt any examination. 
22 
You interrupted the examination. I didn't say a 
23 
word. So, let's just go ahead and proceed 
24 
forward. The witness asked you to repeat the 
25 
question, okay? 
Page 147 
1 
As you are well aware we have hyper-technical 
2 
Constitutional privileges at issue here. If I 
3 
choose to communicate with my client regarding 
4 
those privileges, I will communicate with him. If 
5 
you'd like me to take breaks, I will do so. But 
6 
once again, we're here to answer your questions, 
7 
and I would like to just move forward. 
8 
BY MR. HOROWITZ: 
9 
Q Prior to June 2005 did 
u coerce Jane Doc 4 
10 
into 
11 
MR. PIKE: Form. 
12 
THE WITNESS: I'd like to answer that 
13. 
question. I cannot answer that question on advice 
14 
of counsel, but I'd like to answer that question. 
15 
My counsel has advised me that I must assert my 
16 
Sixth Amendment, Fifth Amendment and Fourteenth 
17 
Amendment Rights. And if I choose to answer that 
18 
question, I risk waiving those rights, and risk 
19 
losing their representation. 
20 
BY MR. HOROWITZ: 
21 
Prior to June 2005 did you 
23 
MR. PIKE: Form. 
24 
THE WITNESS: I'd like to answer that question 
25 
about Jane Doe 4, and all the other girls you've 
Page 148 
1 
mentioned today. However, my counsel has told me I 
2 
cannot answer any questions that may be relevant to 
3 
the lawsuit I'd like to answer that question 
4 
directly to you, Mr. Edwards. Mr. Edwards' 
5 
partner, unfortunately, is in jail, so I can't talk 
6 
to him directly. Your partner has been suspended 
7 
after filing a lawsuit against me. But, though I'd 
8 
like to answer those questions, I risk losing their 
9 
representation and waiving those rights, if I do 
10 
so. 
11 
BY MR. HOROWITZ: 
12 
Q Prior to June 2005 did you masturbate in front 
13 
of Jane Doe 4? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: I'd like to answer that 
16 
question. Pd like to answer all your other 
17 
questions posed here today; however, I cannot do so 
18 
on the advice of counsel. And they told me that if 
19 
I do answer the questions, I may waive those 
20 
rights, or risk losing their representation. 
21 
BY MR. HOROWITZ: 
22 
Q Prior to June 2005 did you ejaculate in front 
23 
of Jane Doe 4? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: I would like to answer that 
Page 149 
1 
question about Jane Doe 4, the girl who wrote "for 
2 
a good time, call" -- I -- from her testimony, "for 
3 
a good time, call Jane Doe 4" or "call Jane Doe 
4 
4." I'm not actually sure. You maybe could clue 
5 
me in. However, my counsel has told me today that 
6 
I — I must assert my Sixth Amendment, Fourteenth 
7 
Amendment and Fifth Amendment Rights as provided by 
8 
the U.S. constitution. And, though I would like to 
9 
answer each and every one of your questions, I 
10 
cannot do so. I risk waive — risk losing or 
11 
waiving those rights and losing their 
12 
representation. 
13 
BY MR. HOROWITZ: 
14 
Q Did Jane Doe 4 come to your Palm Beach home on 
15 
multiple occasions between 2003 and May 2005 to give you 
16 
massages during which you engaged her in sexual 
17 
activity? 
18 
MR. PIKE: Form. 
19 
THE WITNESS: Pd like to answer each and every 
20 
one of your questions posed here today. I would 
21 
like to answer that question, and all the other 
22 
questions you've asked about Jane Doe 4. However, 
23 
upon advice of my counsel, they've instructed me to 
24 
assert my Fourteenth Amendment Rights, my Sixth 
25 
Amendment Rights and my Fifth Amendment Rights as 
UNIVERSAL COURT REPORTING 
a.rapanqSa1.1.90, 
38 (Pages 146 to 149) 
( 
) 
EFTA01076687

Page 150 
1 
provided by the constitution. So, though I'd like 
2 
to answer. I don't. Eve been instructed that I 
3 
risk waiving those rights and losing their 
4 
representation. 
5 
BY MR. HOROWITZ: 
6 
Q Prior to May of 2005 did you pay Jane Doe 4 
7 
$200 after having had sexual contact with her? 
8 
MR. PIKE: Form. 
9 
THE WITNESS: Again? 
10 
BY MR. HOROWITZ: 
11 
Q Prior to May 2005 did you ever pay Jane Doe 4 
12 
$200 after having had sexual contact with her? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: Ed like to answer that 
15 
question. I'd like to answer every one of your 
16 
questions posed here today. However, according to 
17 
my counsel, he's asked me to assert my rights under 
18 
the Fourteenth Amendment, the Sixth Amendment, the 
19 
Fifth Amendment of the U.S. Constitution, and he's 
20 
instructed me that no matter how much I'd like to 
21 
answer these questions, that if I do so, I may 
22 
waive those rights and risk losing his 
23 
representation. 
24 
BY MR. HOROWITZ: 
25 
Q Did you try to persuade Jane Doe 4 that it was 
Page 151 
1 
okay that 
2 
while she was still a timid? 
3 
MR. PIKE: Form. 
4 
THE WITNESS: I'd like to answer that 
5 
question. I'd like to answer every question you've 
6 
asked here today, every question. However, my 
7 
counsel has instructed me at least today, I cannot 
8 
answer those questions, and they've instructed me 
9 
that I must assert my Fourteenth Amendment, Sixth 
10 
Amendment and Fifth Amendment Rights as provided by 
11 
the Constitution. And by not doing so, I may waive 
12 
those rights or risk losing their representation. 
13 
BY MR. HOROWITZ: 
14 
Q Prior to June 2005 did you instruct ■ 
to 
15 
communicate with Jane Doe 4 by telephone to schedule 
16 
Jane Doe 4 to come to your Palm Beach home for sexual 
17 
activity? 
18 
MR. PIKE: Form. 
19 
THE WITNESS: I'd like to answer that 
20 
question. I'd like to answer all your questions. 
21 
I wish your partner that had been suspended from 
22 
practice after he filed Jane Doe 4's lawsuit, or 
23 
Mr. Edwards' who's — who sits next to you, whose 
24 
partner sits in jail, I would like nothing more 
25 
than to answer these questions today, but upon 
Page 152 
1 
advice of my counsel, theyve told me that I must 
2 
assert my Fourteenth Amendment Rights, my Sixth 
3 
Amendment Rights and my Fifth Amendment Rights. 
4 
And by not doing so, I may waive those rights or 
5 
risk losing their representation. Adam, may 1 take 
6 
&quick five minutes? 
7 
MR. HOROWITZ: Sure. 
8 
THE VIDEOGRAPHER: Time off the record 1:50. 
9 
(Thereupon, a short break was taken.) 
10 
THE VIDEOGRAPHER: Time on the record 2:00. 
11. 
BY MR. HOROWfilt: 
12 
Q Prior to June 2005 you instructed Jane Doe 4 to 
13 
call you at your Palm Beach home to con rum the specific 
14 
dates and times you wanted her to come over for sexual 
15 
activity, correct? 
16 
MR. PIKE: Form. 
17 
THE WITNESS: I'd like to answer that 
18 
question. Id like to answer every question you've 
19 
asked me here today, but I'm going to have to 
20 
respond the same way I've responded to most of your 
21 
questions, Mr. Horowitz, which is on advice of 
22 
counsel, I'm going to have to assert the Sixth 
23 
Amendment, Fourteenth Amendment and Fifth Amendmer! 
24 
Rights. Though I'd like to answer that question, 
25 
as all your other questions, I'm informed that if I 
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 153 
do so, I risk waiving those rights and losing my 
representation. 
BY MR. HOROWITZ: 
Q Did you instruct Jane Doe 4 to lie to police 
investigators during their 2005 investigation into your 
criminal activities? 
MR. PIKE: Form. 
THE WITNESS: Did I instruct Jane Doe 4 to 
lie? 
MR. HOROWITZ: That's my question, yes. 
THE WITNESS: I'd like to answer that 
question. I'd like to answer every one of your 
questions here today. I'd like to answer questions 
of unfortunately, the -- I guess your partner 
that filed this lawsuit was suspended by the 
Florida Bar. Pd like to answer. However, my 
counsel has advised me at least today that I must 
assert my rights under the Fourteenth Amendment, 
Sixth Amendment and Fifth Amendment. And if I 
choose to answer that question, which I prefer to 
do, I risk losing their representation and waiving 
those rights, so I must respectfully decline. 
Sony, Mr. Horowitz. 
BY MR. HOROWITZ: 
Q Are you suggesting that you have some 
UNIVERSAL COURT REPORTING 
39 (Pages 150 to 153) 
) 
EFTA01076688

Page 154 
1 
information that Jeffrey Herman was suspended from the 
2 
practice of law because he made false statements in a 
3 
lawsuit against you? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: Jeffrey Herman was your partner. 
6 
Are you asking me why he was suspended? I'm sorry, 
7 
are you asking me —
8 
BY MR. HOROWITZ: 
9 
Q I'm asking you why --
10 
THE REPORTER: Wait a second. 
11 
THE WITNESS: Sorry. Are you asking why your 
12 
partner was suspended from the practice of law in 
13 
South Florida? 
14 
BY MR. HOROWITZ: 
15 
Q I'm asking you whether you have any information 
16 
or you're suggesting here today that his suspension of 
17 
practice of law had anything to do with you or the 
18 
lawsuits against you? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: Am I suggesting that his 
21 
disbarment -- Pm sorry -- his suspension or -- I'm 
22 
sorry — can you do it again? Was he disbarred or 
23 
suspended? 
24 
BY MR. HOROWITZ: 
25 
Q Are you suggesting today in your testimony 
Page 155 
1 
that --
2 
A Yeah. 
3 
Q -- his suspension had anything to do with you 
4 
or the lawsuits against you? 
5 
MR. PIKE: Point 
6 
THE WITNESS: I'd like to answer that question, 
'T 
but my counsel has advised me I cannot today. I 
8 
must assert the Fourteenth Amendment, Sixth 
9 
Amendment and Fifth Amendment Rights, though 
10 
obviously, I'd lilce to answer that question. 
11 
BY MR. HOROWITZ: 
12 
Q Did you instruct 
to tell Jane Doe 4 to lie 
13 
to police investigators during their 2005 investigation 
14 
into your criminal activity? 
15 
MR. PIKE: Form. 
16 
THE WITNESS: I'd very much Ince to answer that 
17 
question. I'd very much like to answer all your 
18 
questions here today, but as I've done with most of 
19 
those questions, on advice of my counsel — it's 
20 
been a long day so far — lam going to have to 
21 
refrain from answering, at least today, to any 
22 
questions that may be relevant to any of your 
23 
lawsuits brought by you, your suspended partner, 
24 
Mr. Edwards and his partner who's in jail. So, 
25 
though I'd like to answer those questions, I risk 
Page 156 
1 
losing or waiving my rights and my counsel's 
2 
representation, so I must respectfully decline 
3 
today. 
4 
BY MR. HOROWITZ: 
5 
Q Did you instruct M. to rent a car for Jane 
6 
Doe 4? 
7 
MR. PIKE: Form. 
8 
THE WITNESS: I'd like to answer that question 
9 
— Jane Doe 4 — have we moved from a different 
10 
person, I'm sorry? 
11 
MR. HOROWITZ: We're on Jane Doe 4. 
12 
THE WITNESS: Okay. I'd like to answer that 
13 
question. I'd like to answer every one of your 
14 
questions. However, my counsel has advised me, at 
15 
least today, that I cannot do so. I must assert my 
16 
Fourteenth Amendment, Fifth Amendment and Sixth 
17 
Amendment Rights. 
18 
BY MR. HOROWITZ: 
19 
Q Did you intend for Jane Doe 4 to use the car 
20 
that you rented for her, for her to come to your home to 
21 
give you sexual massages? 
22 
MR. PIKE: Form. 
23 
THE WITNESS: Did I intend a car that was 
24 
ratted for Jane Doe 4 — could you do the question 
25 
again? 
Page 157 
1 
BY MR. HOROWITZ: 
2 
Q Sure. Did you intend for Jane Doe 4 to use the 
3 
car you rented for her to come to your home to give you 
4 
sexual massages? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: You said I rented a car? 
7 
MR. HOROWITZ: I'm just asking the questions. 
8 
My —
9 
THE WITNESS: I'm sorry, you have to ask the 
10 
question again. 
11 
BY MR. HOROWITZ: 
12 
Q Sure. Previously I asked you if you rented a 
13 
car, and you asserted the Fifth —
14 
A I don't believe you did. 
15 
Q Okay. All right. Did you --
16 
A You asked me if I instructed somebody --
17 
Q That's rilLt. You're correct. The car that 
18 
you instructed .. to rent for Jane Doe 4. Pm talking 
19 
about that -- that vehicle, okay? Did you intend for 
20 
Jane Doe 4 to use that car to acme to your home and give 
21. 
you sexual massages? 
22 
MR. PIKE: Form. 
23 
THE WITNESS: I'd like to answer that 
24 
question. I'd like to answer every question about 
25 
Jane Doe 4 that you asked me here today. My 
A 
UNIVERSAL COURT REPORTING 
40 (Pages 154 to 157) 
( 
) 
EFTA01076689