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counsel has advised me that I may not. And they've 
2 
instructed me that I am to assert my Fourteenth 
3 
Amendment, Sixth Amendment, Fifth Amendment 
4 
Rights. And, though I'd like to answer each one of 
5 
your questions, my counsel has advised me that ill 
6 
choose to do so, which is my preference, I risk 
7 
waiving those rights and/or losing their 
8 
representation. 
9 
BY MR. HOROWITZ 
10 
Q Isn't it true that you and Jane Doe 4 watched a 
11 
videotape of Jane Doe 4 and her boyfriend having sexual 
12 
intercourse? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: Can you describe this videotape 
15 
tome? 
16 
BY MR. HOROWITZ: 
17 
Q Would that refresh your recollection? 
18 
A I don't know. Would you want to tell me about 
19 
it? 
20 
Q My question for you is: Isn't it true that you 
21 
and Jane Doe 4 watched a videotape of Jane Doe 4 and her 
22 
boyfriend having intercourse? Does that refresh your 
23 
recollection? 
24 
MR. PIKE: Same objection, form. 
25 
THE WITNESS: I'd like to answer that question 
Page 159 
1 
— a videotape of her and her boyfriend having sex? 
2 
MR. HOROWITZ: Yes. 
3 
THE WITNESS: Okay. I'd like to answer that 
4 
question, but my counsel has instructed me that I 
5 
must assert my Fourteenth Amendment, Sixth 
6 
Amendment and Fifth Amendment Rights. And, though 
7 
ifs obvious I'd like to answer that question, my 
8 
attorneys have counseled me that I — by doing so, 
9 
I waive those rights, or risk losing their 
10 
representation. 
11 
May I get some — a am? Is this yours? 
12 
MR. HOROWITZ: No. 
13 
THE WITNESS: Okay. 
14 
MR. HOROWITZ: It's mine. 
15 
BY MR. HOROWITZ: 
16 
Q Sir, you don't deny that you sexually abused 
17 
Jane Doe 4, do you? 
18 
MR. PIKE: Form, argumentative. 
19 
THE WITNESS: I'd like to answer that question 
20 
very much so. However, my counsel has advised me 
21 
today that I must assen — at least today, I must 
22 
assert Sixth Amendment Fourteenth Amendment and 
23 
Fifth Amendment Rights. And by choosing to answer, 
24 
I may waive those rights or risk losing their 
25 
representation. 
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Page 160 
So, though your partner after he filed that 
Jane Doe 4 lawsuit was suspended from the practice 
of law by the Florida Bar, or some of these other 
cases brought by Mr. Edwards' firm who is sitting 
next to you, whose partner sits in jail for 
bringing cases of a sexual nature, accusing people 
fallaciously, maliciously, simply to get money, I'd 
like to answer each one of your questions, but 
today, unfortunately, I must respectfully decline. 
BY MR. HOROWITZ: 
Q Sir, are you asserting your Fifth Amendment, 
Sixth Amendment and Fourteenth Amendment Rights to 
protect your innocence, or conceal your guilt? 
MR. PIKE: Form. I'm going to instruct him not 
to answer that question. 
BY MR. HOROWITZ: 
Q Is there any reason that the jury should not 
infer that you did in fact have sexual contact with lane 
Doe 4 when she was a child, given that you've asserted 
the Fifth Amendment? 
MR. PIKE: Form. 
THE WITNESS: The Fifth Amendment has been used 
many times to protect the Innocent, especially 
people who've been falsely accused by people like 
your — Mr. Edwards' partner, Scott Rothstein, who 
Page 161 
sits in jail accused by the U.S. Attorney of 
running the biggest fraudulent scheme in South 
Florida's history, stealing millions of dollars 
from South Florida residents. The U.S. Attorney 
called his enterprise a criminal his firm, 
Mr. Edwards' firm, sitting next to you — another 
one of the lawsuits, a criminal enterprise. 
I'd like to answer that question very 
specifically. However, my attorneys have counseled 
me that today I may not, and I may risk losing my 
rights, my waiver — excuse me - my rights, and 
risk losing my representation, ill choose to 
answer that question. 
BY MR. HOROWITZ: 
Q Okay. I don't want to know why other people 
assert the Fifth Amendment. I want to know why you're 
asserting it. Are you asserting it because you're an 
innocent man, or because you're a guilty man? 
MR. PIKE: Form. 
THE WITNESS: I'd love to answer that 
question. However, my attorneys have counseled me 
that I cannot and must assert my rights under the 
Sixth Amendment Fourteenth and Fifth, even to that 
question. Though I would be more than happy to 
answer it, my attorneys have counseled me that by 
UNIVERSAL COURT REPORTING 
41 (Pages 158 to 161) 
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EFTA01076690

Page 162 
1 
doing so, I may waive those rights and risk losing 
2 
their representation. 
3 
BY MR. HOROWITZ: 
4 
Q Okay. Sir, I'm going to ask you a few 
5 
questions about a young woman named Jane Doe 5. 
6 
A Yes. Okay. 
7 
Q First name is Jane Doe 5. 
8 
MR. PIKE: You said her last name was Jane Doe 
9 
5? 
10 
MR. HOROWITZ: Yes. 
11 
BY MR. HOROWITZ: 
12 
Q So you know her as Jane Doe 5? 
13 
MR. PIKE: Form, mischaracterizes the witness' 
14 
testimony, move to strike. Let's not play with 
15 
words. 
16 
BY MR. HOROWITZ: 
17 
Q Do you recognize her name as 
or Jane Doe 
18 
5? 
19 
A 1don't recognize her name. 
20 
Q Okay. Well, for the moment I would like you to 
21 
hold on to that name, so — because I'll be asking you a 
22 
series of questions about it, okay? 
23 
A Okay. 
24 
Q Isn't it true that a girl named Jane Doe 5 came 
25 
to your Palm Beach estate in approximately 2001 or 
Page 163 
1 
2002? 
2 
MR. PIKE: Form. 
3 
THE WITNESS: I'd like to answer that question 
4 
with respect to Miss Jane Doe 5. 
5 
Q I asked you the right -- I know you did write 
6 
it down. 
7 
A I know. But how did you pronounce it? 
8 
Q Jane Doe 5. 
9 
A Okay. However, my attorneys have counseled me 
10 
that at least today I cannot answer questions that may 
11 
become relevant to any of your lawsuits that you have 
12 
filed with respect to these girls, or your partner filed 
13 
before he became suspended by the Florida Bar for 
14 
improper behavior. 
15 
So, though Pa like to answer that question, 
16 
Mr. Horowitz, as I would Ince to answer every one of 
17 
your questions, at least today, I am going to have to 
18 
assert the rights dictated to me by my counsel, either 
19 
the Sixth Amendment, Fourteenth and — or Fifth 
20 
Amendment, or all of the above. 
21 
I mean, I would like to answer each and every 
22 
one of your questions. If I do so, I'm told that I risk 
23 
waiving those rights, or losing their representation. 
24 
BY MR. HOROWITZ: 
25 
Q All right. 
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Page 164 
A Excuse me. 
Q In either 2001 or 2002, did 
inform you 
that she had received a telephone call in which she was 
referred to an underage girl named Jane Doe 5 who would 
be willing to come to your home and give you a massage 
for money? 
MR. PIKE: Form. 
THE WITNESS: I'd like to answer that question, 
as Pd like to answer mostly every one of your 
questions here today. These questions, my 
attorneys have counseled me. I cannot answer today 
because — as they may be relevant to the lawsuit. 
They have instructed me that I must assert my 
Sixth Amendment, Fourteenth Amendment and Fifth 
Amendment Rights, though I'd very much like to 
answer that question. 
BY MR. I IOROWITZ: 
Q Did E. inform you that she was provided with 
Jane Doe 5's telephone number? 
MR. PIKE: Form. 
THE WITNESS: Again? 
BY MR. HOROWITZ: 
Q Did NI inform you that she was provided with 
Jane Doe 5's telephone number? 
A "Provided with" — I — I don't understand the 
Page 165 
question. 
MR. PIKE: Form to that. And I know you're 
going to ask it again. 
THE WITNESS: Yes, he is. 
BY MR. HOROWITZ: 
Q Did — I'll try and ask it as fundamentally as 
I can. 
A Okay 
Q Did M. inform you that she had Jane Doe 5's 
telephone number? 
A I'd like to answer that question. I've been 
have -- Pd like to answer every question you've asked 
here today. However, on advice of counsel, they've 
instructed me that I cannot answer that question today 
because it may be relevant to one of your lawsuits filed 
by either you, Mr. Edwards -- Mr. Edwards' partner who 
sits in jail, your partner who's been suspended from the 
Florida Bar. 
So, though I'd like to answer that question, at 
least today, my counsel said I risk waiving those rights 
under the Sixth, Fourteenth and Fifth, or risk losing 
their representation. 
Q Did you instruct 
to call Jane Doe 5 to 
come to your home and give you a massage in 2001 or 
2002? 
42 (Pages 162 to 165) 
UNIVERSAL COURT REPORTING 
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1 
MR. PIKE: Form. 
2 
THE WITNESS: This is the same Jane Doe 5 --
3 
whatever her name is? 
4 
MR. HOROWITZ: Yes, keep that same person in 
5 
your head. 
6 
THE WITNESS: It's a little bit tough. I'd 
7 
like to answer that question. I'd like to answer 
8 
all your questions. However, today, my counsel has 
9 
advised me that I cannot answer any questions that 
10 
may be relevant to the lawsuit, and they've 
11 
instructed me that I must assert my Fourteenth, 
12 
Fifth and Sixth Amendment Rights. 
13 
And by answering those questions, that I choose 
14 
— that prefer to do so today, they've instructed 
15 
me that I may waive those rights, or risk losing 
16 
their representation. 
17 
BY MR. HOROWITZ: 
18 
Q Did you inform 
that the massage Jane Doe 5 
19 
was to give you would be sexual in nature? 
20 
MR. PIKE: Form. 
21 
THE WITNESS: I'd like to answer each and every 
22 
one of your questions. My counsel has advised me 
23 
— my counsel has advised me that I cannot today, 
24 
and they've instructed me that I should assert my 
25 
Fourteenth Amendment, Sixth Amendment and Fifth 
Page 167 
1 
Amendment rights. 
2 
And if l choose not to do so, l risk waiving 
3 
those rights, or losing their representation. So, 
4 
though I'd like to answer that question, I cannot. 
5 
BY MR. HOROWITZ: 
6 
Q Did you observe ■. speaking with Jane Doe 5 
7 
on the telephone to arrange for Jane Doe 5 to come to 
8 
your home for a massage? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: I'd like to answer each one of 
11 
your questions, Mr. Horowitz, each and every one 
12 
that you've posed hero today, but I am going to 
13 
have to answer that question, as I've answered most 
14 
of your other questions here today, which is my 
15 
counsel has advised me, at least today, at least 
16 
today, that I cannot answer those questions and 
17 
must assert my Fourteenth Amendment Rights, Sixth 
18 
Amendment Rights and Fifth Amendment Rights or --
19 
BY MR. HOROWITZ: 
20 
Q Did —
21 
A I'm sorry. 
22 
Q Pm sorry, go ahead. 
23 
A 
— or risk waiving those rights, or losing 
24 
their representation. 
25 
Q Did 
tell you that she had confirmed by 
Page 169 
1 
telephone that Jane Doe 5 would be at your home at a 
2 
specific time to give you a massage? 
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 posed here today, Mr. Horowitz, However, 
on advice of counsel, they've instructed me that I 
8 
must assert my Fifth Amendment, Sixth Amendment and 
9 
Fourteenth Amendment Right 
10 
BY MR. HOROWITZ: 
11 
Q Was it your intent during the course of Jane 
12 
Doe 5's visit to your home in either 2001 or 2002, that 
13 
you would persuade, induce or entice her to engage in 
14 
sexual activity? 
15 
MR. PIKE: Form. 
16 
THE WITNESS: It would give me great pleasure 
17 
to be able to answer that question to you, as it --
18 
as all the other questions you've asked about these 
19 
girls here today. My counsel has told me that I 
20 
cannot answer those questions that may be relevant 
21 
to any of the lawsuits brought by you, your partner 
22 
that's been suspended or disbarred -- I'm not 
23 
really sure what the difference Is -- or 
24 
Mr. Edwards' partner who sits in a Florida jail for 
25 
fleecing people out of millions of dollars by 
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Page 169 
crafting cases of a sexual nature against people 
like me and others, and those are -- though I'd 
late to answer those questions, my counsel has 
advised me, at least today, that I cannot. 
BY MR. HOROWITZ: 
Q During the course of Jane Doe 5's visit to your 
home in 2001 or 2002, did you, in fact, persuade, induce 
or entice her to engage in sexual activity with you? 
MR. PIKE: Form. 
THE WITNESS: Though I'd like to answer that 
question, as well as every other question you've 
asked me here today, I stn going to respond in a 
similar fashion, which is my counsel, at least 
today, has told me I may not, may not respond, and 
must assert my rights under the Fourteenth, Sixth 
and Fifth Amendment. 
Though I'd like to respond to each question, my 
counsel has told me that if I choose to do so, I 
risk waiving those rights and losing their 
representation. 
BY MR. HOROWITZ: 
Q Did you pay for Jane Doe 5 to take a taxi to 
your home in either 2001 or 2002? 
MR. PIKE: Form. 
THE WITNESS: I'd like to answer each question 
UNIVERSAL COURT REPORTING 
 J
43 (Pages 166 to 169) 
EFTA01076692

Page 170 
1 
you've asked me here today. However, on advice of 
2 
counsel, they've asked — they've instructed me to 
3 
assert my Fifth Amendment, Sixth Amendment and 
4 
Fourteenth Amendment Rights under the U.S. 
S 
Constitution. 
6 
Though I'd like to answer each question, I have 
7 
to respond, unfortunately, the same way I've 
8 
responded to mostly every one of your questions 
9 
here today, and assert those rights on counsel's 
10 
advice, or risk waiving those rights and losing 
11 
their representation. 
12 
BY MR. HOROWITZ: 
13 
Q During Jane Doe 5's visit to your home in 
14 
either 2001 or 2002, Jane Doe 5 told you she was under 
15 
18, didn't she? 
16 
MR. PIKE: Form. 
17 
THE WITNESS: I'd like to answer that 
18 
question. I'd like to answer every question you've 
19 
asked me here today. I'd like to answer the 
20 
questions posed by you, Mr. Edwards, your partner, 
21 
Mr. Herman, who unfortunately was suspended after 
22 
he filed these cases, Mr. Edwards's partner who's 
23 
sitting — sitting in a jail for fabricating cases 
24 
of a sexual nature against people like me and 
25 
others for stealing money from people in South 
Page 171 
1 
Florida. 
2 
I'd like to answer every question you've asked 
3 
me here today, Mr. Horowitz, but my counsel has 
4 
instructed me that I may not. 
5 
BY MR. HOROWITZ: 
6 
Q When Jane Doe 5 came to your home in either 
7 
2001 or 2002, she appeared to you to be under the age of 
8 
18; isn't that right? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: I'd like to answer all your 
11. 
questions. I'd like to answer each and every one 
12 
of your questions. However, my counsel has 
13 
instructed me that I may not answer any questions 
14 
that may be relevant to this lawsuit, or any of 
15 
your lawsuits brought by your firm, your suspended 
16 
partner or Mr. Edwards' firm, his partner who sits 
17 
in jail excuse me. 
18 
So, though I'd like to answer those questions, 
19 
I was told that — by my counsel that if I choose 
20 
to do so, I risk waive risk waiving my right and 
21 
risk losing their representation. 
22 
BY MR. HOROWITZ: 
23 
Q During Jane Doe 5's visit to your home in 2001 
24 
and 2002, she told you she attended 
25 
isn't that right? 
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Page 172 
MR. PIKE: Form. 
THE WITNESS: I'd like to answer that 
question. I'd lice to answer every question you've 
posed here today, but unfortunately, I am going to 
have to respond the same way I've responded to most 
of these other questions, which is my counsel has 
advised me that at least today, I cannot answer 
those questions. And if I choose to do so, I may 
waive my rights, but
 so I must assert them 
under the Sixth, Fourteenth and Fifth Amendment. 
BY MR. HOROWITZ: 
Q During Jane Doe 5's visit to your home in 2001 
or 2002, were you nude in front of Jane Doe 5? 
A I'd like to answer — 
MR. PIKE: Form. 
THE WITNESS: — that question. I'd like to 
answer every question you've asked me here today. 
But my counsel has advised me that I may not answer 
any questions that may be relevant to your lawsuit, 
Mr. Edwards' lawsuit, his partner's lawsuit who 
sits — his partner who sits in jail, and my 
counsel has advised me that, though his partner 
sits in jail for bringing fabricated cases of a 
sexual nature against people like me and others, 
that I still have to assert my rights under the 
Page 173 
Sixth Amendment, Fifth — Fourteenth Amendment and 
Fifth Amendment; otherwise, I risk waiving those 
rights, or losing their representation. 
BY MR. HOROWITZ: 
Q During the course of Jane Doe 5's visit to your 
home in either 2001 or 2002, did you instruct Jane Doe 5 
to remove all of her clothing? 
MR. PIKE: Fonn. 
THE WITNESS: I'd like to answer that 
question. Pd like to answer every question you've 
asked me here today with specificity. However, my 
counsel has told me that I may not answer any 
questions that may be relevant to this lawsuit, 
must assert my rights under the Fourteenth, Sixth 
and Fifth Amendment, so I must respectfully 
decline, Mr. Horowitz. 
BY MR. HOROWITZ: 
Q During the course of lane Doe 5's visit to your 
home in 2001 or 2002, did you instruct Jane Doe 5 to 
pinch your nipples and rub your chest? 
MR. PIKE: Form. 
THE WITNESS: Like all the other questions --
questions you've asked me here today, I'd love to 
answer that question. I'd love to answer each and 
every one of your questions here today, but my 
I 
44 (Pages 170 to 173) 
UNIVERSAL COURT REPORTING 
EFTA01076693

2 
3 
4 
5 
6 
7 
8 
Page 174 
1 
counsel has told me I cannot. They've instructed 
2 
me that I have to assert my Fourteenth, Fifth and 
3 
Sixth Amendment Rights. And, though I'd like to 
4 
answer -- prefer to answer, that by doing so, I may 
5 
waive those rights, and risk — and/or risk losing 
6 
their representation. 
7 
BY MR. HOROWITZ: 
8 
Q Okay. During the course of Jane Doe 5's visit 
9 
to your home in 2001 or 2002, isn't it true you asked 
10 
Jane Doe 5 questions about her sexual experience and 
11 
preferences? 
12 
MR. PIKE: Form. 
13 
THE WITNESS: I'd like to answer each and every 
14 
one of your question about Jane Doe 5 -- Jane Doe 5 
15 
and her claims. However, my attorneys have told me 
16 
I cannot, at least today, answer any of those 
17 
questions that may be relevant to the lawsuit that 
18 
you have filed, your suspended partner has filed, 
19 
Mr. Edwards has filed, his partner in jail has 
20 
filed. 
21 
Unfortunately, there's lots of things I cannot 
22 
answer questions to. My partner -- my counsel has 
23 
told me that I risk waiving my rights and losing 
24 
their representations, if I choose to do so. 
25 
BY MR. HOROWITZ: 
Page 176 
1 
that question very much. However, my counsel has 
2 
advised me I may not, today anyway, and I must 
3 
assert my right under the Sixth, Fourteenth or --
4 
and/or Fifth Amendment. 
5 
And, though I'd like to answer that question 
6 
specifically — I'd like to answer it to you, I'd 
7 
like to answer it to your partner who's not here 
8 
because he's been suspended from the practice of 
9 
law in South Florida after he filed this lawsuit. 
10 
I'd like to answer that question specifically to 
11 
Mr. Edwards' partner who remains in jail for 
12 
perpetrating a fraud on people in South Florida, 
13 
stealing money from them. 
14 
Unfortunately, under -- my counsel has told me 
15 
that I must respectfully decline and assert my 
16 
rights, or risk waiving those rights and losing 
17 
their representation. 
18 
THE WITNESS: I'm going to have to take a 
19 
break. 
20 
THE VIDEOGRAPHER: Going off the record. Time 
21 
off the record 2:25. 
22 
(Thereupon, a short break was taken.) 
23 
THE VIDEOGRAPHER: Time on the record 2:37. 
24 
'Ills is Tape 4. 
25 
BY MR. HOROWITZ: 
Page 175 
1 
Q During the course of Jane Doe 5's visit to your 
home in 2001 and 2002, did you remove Jane Doe 5's bra 
and 
MR. PIKE: Form. 
THE WITNESS: The answer is: I'd like to 
answer that question. I believe Jane Doe 5 
testified that that was not the case, or you're 
asking me a question that she testified to 
something else? But, though I cannot answer those 
10 
questions, my counsel has advised me that I have to 
11 
assert my rights under the Fifth, Fourteenth and 
12 
Sixth Amendment. So, though I'd like to answer 
13 
that question, I may not. 
14 
BY MR. HOROWITZ: 
15 
Q Well, which version of events is true, that you 
16 
did touch her breasts, or that you did not touch her 
17 
breasts? 
18 
A Are you asking me whether she tells the truth 
19 
or not in her deposition? Is that the question? 
20 
Q My question is: Which version of events is 
21 
true, that she touched your breasts -- that 
23 
24 
25 
MR. PIKE: Form. 
THE WITNESS: I'd like to answer that 
question. As you might imagine Pd like to answer 
Page
1 
Q Okay. We've been discussing Jane Doe 5 for 
2 
some time now. Okay. I'm going to ask you a few more 
3 
questions about her. During the course of 
Doc C's 
4 
visit to our home in 2001 and 2002, 
I 
6 
MR. PIKE: Form, and assumes facts not in 
7 
evidence. 
8 
THE WITNESS: I'd like to answer that 
9 
question. I'd like to answer every question you've 
10 
asked me here today. But on advice of counsel, 
11 
they've instructed me, I must assert my Sixth 
12 
Amendment, Fourteenth Amendment and Fifth Amendment 
13 
Rights. 
14 
BY MR. HOROWITZ: 
15 
Q During the come of lane Doe 5's visit to our 
16 
home in 2001 and 2002, 
18 
19 
20 
21 
22 
23 
24 
25 
MR. PIKE: Form. 
THE WITNESS: Pm afraid it's the same answer 
as most of the other answers I've given here 
today. Though I would like to answer these 
questions with specificity, especially that 
question, my counsel has advised me that I may not, 
and must assert my rights under the Sixth 
Amendment. Fourteenth and Fifth Amendment. 
UNIVERSAL COURT REPORTING 
45 (Pages 174 to 177) 
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EFTA01076694

Page 178 
1 
And if I chose to answer, which I prefer to do, 
2 
they've advised me I may waive those rights, or 
3 
risk losing their representation. 
4 
BY MR. HOROWITZ: 
5 
Q During the course of Jane Doe Ss visit to our 
6 
home in 2001 and 2002, did 
-
I
 
8 
MR. PIKE: Form. 
9 
THE WITNESS: I'd vety much like to answer that 
10 
question as well, Mr. Horowitz, but my attorneys 
11 
have advised me today that I cannot, and I must 
12 
assert my rights under the Sixth, Fifth and 
13 
Fourteenth Amendments. 
14 
Though it would -- I'd prefer to answer the 
15 
question, they told me that if I choose to do so, I 
16 
risk waiving those rights. I would prefer to have 
17 
that conversation with your partner that was 
18 
suspended or disbarred from the Florida Bar after 
19 
filing the lawsuit on Jane Doe 5's behalf. I'd 
20 
prefer to talk to Mr. Edwards' partner, if he was 
21 
able to be here, except he's in jail for 
22 
fabricating cases of a sexual nature against people 
23 
like me. So, believe me, I'd like to answer those 
24 
questions, but today my attorneys have told me I 
25 
may not. 
Page 179 
1 
BY 
HOROWITZ: 
2 
Q During the course of Jane Doe 5's visit to our 
3 
home in 2001 or 2002, 
5 
MR. PIKE: Form. 
6 
THE WITNESS: Pd like to answer that 
7 
THE VIDEOGRAPHER: Hold on. There's major 
8 
static. Time off the record 2:40. 
9 
(Thereupon, a short break was taken.) 
10 
THE VIDEOGRAPHER: Time on the record 2:41. 
11 
MR. HOROWITZ: Back on the record. I don't 
12 
know that we did or did not get an answer to this 
13 
question, so I'm going to repeat it. And if you 
14 
have to repeat your answer, I apologia. 
15 
MR. PIKE: Thank you. 
16 
BY MR. HOROWITZ: 
17 
Q During the course of Jane Doe 5's visit to 
ur 
18 
home in 2001 or 2002, 
20 
MR. PIKE: Form. 
21 
THE WITNESS: I'd like to answer the questions 
22 
about Jane Doe 5. However, my attorneys have told 
23 
me that I may not answer any questions regarding 
24 
anything that may be relevant to any of the 
25 
lawsuits brought by you, your film your partner 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
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Page 180 
that was suspended or disbarred after he brought 
these lawsuits. So, though I'd like to answer the 
question, Mr. Horowitz, my attorneys have advised 
me, at least today, that I must assert my rights 
under the Sixth, Fourteenth and Fifteen -- Fifth 
Amendment, and I respectfluly have to decline. 
BY MR. HOROWITZ: 
Q During the course of Jane Doe 5's visit to your 
home in 2001 or 2002, did you masturbate in her 
presence? 
MR. PIKE: Form. 
THE WITNESS: I'd very much like to answer 
every question, every single question regarding 
Jane Doe 5 and her claims. However, my attorneys 
have advised me, at least today, that I may not do 
so, and must assert my rights under the Sixth 
Amendment, Fourteenth and Fifth Amendment. 
And, though I would prefer to answer, they have 
advised me that if I choose to do so, 'risk 
waiving those rights and risk losing their 
representation. 
BY MR. HOROWITZ: 
Q During the course of Jane Doe 5's visit to your 
home in 2001 or 2002, did you ejaculate in her presence? 
MR. PIKE: Form. 
Page 181 
1 
THE WITNESS: Did I ejaculate in Miss Jane Doe 
2 
5's presence? I'd like to answer that question and 
3 
that all her claims -- however, today, my attorneys 
4 
have counseled me that I may not. 
5 
They've instructed me that I have to assert my 
6 
Sixth Amendment, Fourteenth Amendment and Fifth 
7 
Amendment Rights. Though I'd like to answer that 
8 
question, I am going to have to respond as I've 
9 
answered most of your other questions here today, 
10 
which is by asserting those rights. 
11 BY MR. HOROWITZ: 
12 
Q Did you have sexual contact with lane Doe 5 in 
13 
your Palm Beach home in either 2001 or 2002? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: "Sexual contact"? 
16 
MR. HOROWITZ: Yes. 
17 
THE WITNESS: Can you tell me what you mean by 
18 
that? 
19 
BY MR. HOROWITZ: 
20 
Q Contact, sexual — of a sexual nature. Do you 
21 
understand -- do you understand what that means? 
22 
A I've asked you — 
23 
Q Have you had sexual contact? 
24 
A I've asked you to clarify what you mean, 
25 
please. 
46 (Pages 178 to 181) 
UNIVERSAL COURT REPORTING 
EFTA01076695

Page 182 
1 
Q Well, fm going to use a broad definition, 
2 
okay? 
3 
A 
Yes. 
4 
Q That would involve touching someone's sexual 
5 
o 
s someone else touchi 
ur 
Did you have any of those activities of a 
8 
sexual nature with Jane Doe 5? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: I'd like to respond to every one 
11 
of Jane Doe 5's claims. However, today, my counsel 
12 
has advised me that I may not. So I am going to 
13 
have -- under their instructions have to assert my 
14 
Sixth Amendment, Fourteenth Amendment and Fifth 
15 
Amendment Rights. Though Pd like to answer that 
16 
question, I've been told that if I choose to do so, 
17 
I risks losing their representation and waiving 
18 
those rights. 
19 
BY MR. HOROWITZ: 
20 
Q During the county of Jane Doe 5's visit to our 
21 
home in 2001 or 2002. did ou also 
in the presence of Jane 
23 
Doe 5? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: I'd like to respond to every one 
Page 183 
1 
of Miss Jane Doe 5's complaints or claims. My 
2 
attorneys have told me that, at least today, that I 
3 
may not do so today, and must assert my rights 
4 
under the Sixth Amendment, Fifth Amendment and 
5 
Fourteenth, and I have to respond the same way I've 
6 
responded to most of your — my — your other 
7 
questions posed here today. 
8 
BY MR. HOROWITZ: 
9 
Q Did you pay Jane Doe 5 $200 after you had 
10 
sexual contact with her in your home? 
11 
MR. PIKE: Form. 
12 
THE WITNESS: I'd like to respond to every one 
13 
of Jane Doe 5's claims, but my attorneys have 
14 
advised me that at least today I must assert my 
15 
rights under the Fifth, Sixth and Fourteenth 
16 
Amendment. Though I'd like to answer that 
17 
question, I ant going to have to respond similarly 
18 
that I've answered most of your other questions 
19 
here today. This is no different. 
20 
And I — though I would — I've been advised by 
21 
my attorneys, if I choose to answer, I risk waiving 
22 
my rights and/or risk losing their representation. 
23 
BY MR. HOROWITZ: 
24 
You never asked Jane Doe 5 for permission to 
25 
correct? 
Page 184 
1 
MR. PIKE: Form. 
2 
THE WITNESS: I would like to respond to every 
3 
single one of your client's claims. My attorneys 
4 
have advised me at least today, I cannot answer any 
5 
questions that may be relevant to those claims. 
6 
And, though your partner who filed this lawsuit on 
7 
Miss Jane Doe 5's behalf was disbarred -- suspended 
8 
by the Florida Bar — suspended by the Florida Bar 
9 
after filing this claim, or Mr. Edwards', who filed 
10 
similar claims, partner who sits in jail, I'd like 
11 
to answer every single question. However, today, 
12 
my attorneys told me that if I do so, choose to do 
13 
so, I risk waiving my rights and risk losing their 
14 
representation. 
15 
BY MR. HOROWITZ: 
16 
Q Mr. Epstein, Jane Doe 5 told you when she was 
17 
in your home that she did not want you to touch her 
18 
body, isn't that true? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: I would very much like to answer 
21 
every question regarding Jane Doe 5's claims, but 
22 
today my attorneys have informed me that I may not 
23 
answer, and must assert my rights under the Sixth, 
24 
Fifth and Fourteenth Amendment. So, though I would 
25 
like to answer those questions, I — my attomeys 
Page 185 
1 
have informed me that if I choose to do so, which 
2 
is my preference, I would risk losing their 
3 
representation and waiving my rights. 
4 
BY MR. HOROWITZ: 
5 
Q Mr. Epstein, you made sexual contact with Jane 
6 
Doe 5 after she indicated to you that she did not want 
7 
to be toothed by you, isn't that right? 
8 
MR. PIKE: Form. 
9 
THE WITNESS: I'd like to answer each and every 
10 
one of your questions regarding Miss Jane Doe 5's 
11 
claims. However, my attorneys have advised me that 
12 
today at least, I may not answer those claims, and 
13 
must assert my rights under the Fourteenth 
14 
Amendment, Sixth Amendment and Fifth Amendment.
15 
And, though as you might imagine, I would like 
16 
to answer those claims with — questions with 
17 
specificity, my counsel has told me that if I 
18 
choose to do so, I waive — I might risk losing 
19 
their representation and waive — waiving some of 
20 
my rights. 
21 
BY MR. HOROWITZ: 
22 
Q Did you t to ersuade Jane Doe 5 that it was 
23 
okay for you to 
while she 
24 
was still a child? 
25 
(Videotaped deposition continued in Volume IL) 
UNIVERSAL COURT REPORTING 
47 (Pages 182 to 185) 
( 
) 
EFTA01076696

Page 186 
1 
2 
3
4 
COUNTY OF BROWARD ) 
5 
6 
7 
1, the undersigned authority, certify that 
8 
Jeffrey Edward Epstein personally appeared before me and 
9 
was duly sworn. 
10 
11 
WITNESS my hand and official seal this 22nd day 
12 
of March, 2010. 
13 
14 
15 
16 
Vicki L Lima, Court Reporter 
17 
Notary Public - State of Florida 
Commission No: DD 882608 
18 
Expiration Date: May 26, 2013 
Job #92076-A 
19 
20 
21 
22 
23 
24 
25 
CERTIFICATE 
) 
STATE OF FLORIDA 
) 
COUNT Y OF DROWAILD ) 
1 Vicld L. Lam. Cowl Relent Nanny Public 
m and fin the Slate of Florida in Large, do hereby 
codify that the oforamantictied witness was by the fat 
duly sworn to testify to the whole malt. that I was 
anthonted to and did neon said deposition In 
stonorype; and that the foievoing pages native and 
correct na,uaipliwr am) shorthand noon of
depOnne 
I further candy that the told deposeon was 
taken es the tine and place Wen:above ter forth and 
12 
that the talons of sad deposition was ontianowcd and 
caen$eted as beteinabove set out 
I farther Califr Mail am not an enemy ce 
14 
conned of any of the panics, nor arn I *retrain or 
employed of any attorney cc counsel of any party 
15 
connected with this action. nor aid interested in the 
sit ion 
13 
10 
11 
STATE OF FLORIDA 
) 
16 
The foirgoing certiFumion of loin uanscript 
17 
dees not apply to any reproduction of the same by any 
meant union unda the dtreot camel andSn &Mellon 
18 
or the califyind Rawer. 
19 
iN WITNESS WHEREOF. I have hereunto set my hand 
this 22nd day of Much, 2010. 
20 
21 
22 
23 
24 
25 
Vat L. Lima Court Rnoner 
Notary Public • State otFlonas 
Cossniswen Nv DO 882608 
Emmatioa Date. May 26.2013 
Job *92076-A 
Page 187 
1 
2 
3 
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Page 
189 
1 
ERRATA SHEET 
2 
IN RE: gant Doe Na 2 vs Jeffrey Edward Epstein 
3 
DEPOSITION OP: lerhey Edvaid Epode. Volume I 
4 
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24 
DATE 
SIGNATURE OF DEPONENT 
25 
Job #92076-A 
UNIVERSAL COURT REPORTING 
48 (Pages 186 to 189) 
( 
) 
EFTA01076697