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1 
David Copperfield and Jeffrey Epstein used to share 
1 
privilege. 
2 
for sexual -- for sex, iris under the age of 16? 
2 
THE WITNESS: On the instruction of my 
3 
MR. 
: Same objection as 
3 
lawyer, I must invoke my Fifth Amendment 
4 
previously stated to the last I don't know how 
4 
privilege. 
5 
many questions. This question again assumes 
5 
BY MR. KUVIN: 
6 
this witness knows Jeffrey Epstein, has any 
6 
Q. How many people did Jeffrey Epstein use to 
7 
knowledge of Jeffrey Epstein's life. And 
7 
help him bring minor females to his house in Palm 
8 
because it assumes that fact, there is an 
8 
Beach for sex? 
9 
underlying predicate it is ambiguous and 
9 
MR. 
Same objection as the 
10 
compound. I would instruct her not to answer. 
10 
previous question and I instruct her not to 
11 
THE WITNESS: On the instruction of my 
11 
answer. 
12 
lawyer, I must invoke my Fifth Amendment 
12 
THE WITNESS: On the instruction of my 
13 
privilege. 
13 
lawyer, I must invoke my Fifth Amendment 
14 
BY MR. KUVIN: 
14 
privilege. 
15 
Q. From the time you met Mr. Epstein, isn't 
15 
BY MR. KUVIN: 
16 
it true that he would arrange for underage girls. 
16 
Q. Do you agree that Jeffrey Epstein is a 
17 
girls under the age of 18. to have sex with every 
17 
child molester? 
18 
single day? 
18 
MR. 
That question is solely 
19 
MR. 
: Let me try this again. 
19 
intended to harass the witness and it's 
20 
Objection to the form. Any question you're 
20 
ambiguous as to what a child molester means, 
21 
going to ask her that assumes she knows 
21 
and you're asking for a legal conclusion and 
22 
Jeffrey Epstein, she's ever met Jeffrey 
22 
instruct her not to answer. 
23 
Epstein, she's ever seen Jeffrey Epstein, knows 
23 
BY MR. KUVIN: 
24 
where he lives, knows what he does, if it 
24 
Q. In your own o • inion. 
25 
assumes that as part of the question, I will 
25 
MR. 
I will again instruct her 
Page 82 
Page 84 
1 
deem the question to be ambiguous and compound. 
1 
not to answer based on her Fifth Amendment 
2 
because you're asking her to admit as a 
2 
privilege as well as the question having no 
3 
predicate that she knows Mr. Epstein. As to 
3 
legitimate basis and will not lead to 
4 
any question like that. I am going to instruct 
4 
discoverable evidence. 
5 
her to take the Fifth Amendment on that basis. 
5 
THE WITNESS: On the instruction of my 
6 
So I would again instruct her to take the Fifth 
6 
lawyer, I must invoke my Fifth Amendment 
7 
Amendment as to that question. 
7 
privilege. 
8 
THE WITNESS: On the instruction of my 
8 
BY MR. KUVIN: 
9 
lawyer. I must invoke my Fifth Amendment 
9 
Q. Would you agree that Jeffrey Epstein is 
10 
privilege. 
10 
obsessed with undera e females? 
11 
MR. KUVIN: If you want to short circuit 
11 
MR. 
Objection to the form. 
12 
that, anytime I mention Jeffrey Epstein you can 
12 
It's ambiguous as to what you mean by 
13 
have a standing objection on that issue. I 
13 
"obsessed." I'll instruct the witness not to 
14 
have no roblem. 
14 
answer based on her Fifth Amendment privilege, 
15 
MR. 
Great. 
15 
because the question assumes knowledge of 
16 
BY MR. KUVIN: 
16 
Jeffrey Epstein. 
17 
Q. Can you explain. if you would, to a jury 
17 
THE WITNESS: On the instruction of my 
18 
how Mr. Epstein would access underage minor females 18 
lawyer, I must invoke my Fifth Amendment 
19 
for sex eve 
da ? 
19 
privilege. 
20 
MR. 
The question is compound 
20 
BY MR. KUVIN: 
21 
in that it asks about Mr. Epstein every day. 
21 
Q. How would ou define the word "obsessed"? 
22 
underage females, and involves multiple 
22 
MR. 
You can answer that. 
23 
questions in the same question. and also based 
23 
THE WITNESS: I don't know. You like it a 
24 
on the standing objection. I would instruct her 
24 
lot. I don't know. 
-...25 
not to answer based on her Fifth Amendment 
25 
21 (Pages 81 to 8 4) 
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BY MR. KUVIN: 
1 
lawyer, I must invoke my Fifth Amendment 
2 
Q. Okay. Using your definition of obsessed, 
2 
privilege. 
3 
would you agree with me that Jeffrey Epstein was 
3 
BY MR. KUVIN: 
4 
obsessed with undera e females? 
4 
Q. Did you keep a journal with the names of 
5 
6 
MR. 
Same objection; same 
instruction. 
5 
6 
girls in it in the ear 2005? 
MR. 
: Objection to the form as 
7 
THE WITNESS: On the instruction of my 
7 
ambiguous. What do you mean by "journal"? 
8 
lawyer, I must invoke my Fifth Amendment 
8 
MR. KUVIN: I will define it. 
9 
privilege. 
9 
MR. 
: Please. 
10 
BY MR. KUVIN: 
10 
BY MR. KUVIN: 
11 
Q. When was the first time that you learned 
11 
Q. Did you keep a pad of paper. either a 
12 
Mr. Epstein was getting a massage from a girl under 12 
ringed notebook or some other format with the names 
13 
the age of 16? 
13 
of girls and their 
one numbers in it in 2005? 
14 
MR. 
One second. 
14 
MR. 
: I'll instruct the witness 
15 
MR. KUVIN: Sure. 
15 
not to answer based on her Fifth Amendment 
16 
MR. 
I want to make the 
16 
privilege. Also the question remains 
17 
standing objection for the reasons previously 
17 
ambiguous. 
18 
stated, the question is otherwise also compound 
18 
THE WITNESS: On the instruction of my 
19 
in that it assumes multiple facts and asks her 
19 
lawyer, I must invoke my Fifth Amendment 
20 
to answer multiple questions at the same time. 
20 
privilege. 
21 
I'll instruct her not to answer based on her 
21 
BY MR. KUV1N: 
22 
Fifth Amendment. 
22 
Q. Would you agree with me that you kept a 
23 
THE WITNESS: On the instruction of my 
23 
pad of paper or a journal. however you want to 
24 
lawyer, I must invoke my Fifth Amendment 
24 
describe it, that contain the names of hundreds of 
25 
privilege. 
25 
underage girls and their phone numbers? 
i 
Page 86 
Page 88 
1 
BY MR. KUVIN: 
1 
MR. 
Object to the form of the 
2 
Q. Do you know who owns the home at 358 
2 
question. It's compound and asking her to 
3 
El Brillo Wa '≥ 
3 
answer multiple questions at the same time.
4 
MR. 
Same instructions as to 
4 
It's also leading, and I would instruct her not 
5 
the standing objection. 
5 
to answer based on her Fifth Amendment. 
6 
THE WITNESS: On the instruction of my 
6 
THE WITNESS: On the instruction of my 
7 
lawyer, I must invoke my Fifth Amendment 
7 
lawyer, I must invoke my Fifth Amendment right. 
8 
privilege. 
8 
BY MR. KUVIN: 
9 
BY MR. KUVIN: 
9 
Q. Would you agree with me that you kept a 
10 
Q. Have .ou been on Palm Beach Island before? 
10 
of 
notebook, or journal with the names of
11 
MR. 
I am sorry. Can you 
11 
pad 
paper, 
hundreds of girls under the age of 16 so that you 
12 
restate the question? 
12 
could contact them and have them come to 
13 
MR. KUVIN: Sure. 
13 
Jeffrey Epstein's home for sex with him? 
14 
BY MR. KUVIN: 
14 
MR. 
: Objection to the form as 
15 
Q. Have you been on the Island of Palm Beach 
15 
compound and ambiguous, and I'll instruct her 
16 
before? 
16 
not to answer based on Fifth Amendment. 
17 
MR. 
You can answer that yes or 17 
THE WITNESS: On the instruction of my 
18 
no. 
18 
lawyer, I must invoke my Fifth Amendment 
19 
THE WITNESS: Yes. 
19 
privilege. 
20 
BY MR. KUVIN: 
20 
BY MR. KUVIN: 
21 
Q. How man times? 
21 
Q. Do ou know Alfredo Rodriguez? 
22 
MR. 
I'll instruct her not to 
22 
MR. 
: I'll instruct the witness 
23 
answer that question based on her Fifth 
23 
not to answer based on her Fifth Amendment 
24 
Amendment privilege. 
24 
privilege. 
25 
THE WITNESS: On the instruction of my 
25 
THE WITNESS: On the instruction of my 
22 (Pages 85 to 88) 
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1 
lawyer, I must invoke my Fifth Amendment 
1 
prosecution by either the State or the federal 
2 
privilege. 
2 
government? 
3 
BY MR. KUVIN: 
3 
MR. 
: She's not answering that 
4 
Q. Are you aware that Alfredo Rodriguez has 
4 
question. She's not required to answer the 
5 
pled guilty to federal charges for hiding a journal 
5 
question. She's invoked her Fifth Amendment 
6 
containing the names of women? 
6 
privilege. She will continue to do so as to 
7 
MR. 
Objection to the form as 
7 
that question. You can move on. 
8 
compound and instruct her not to answer. 
8 
BY MR. KUVIN: 
9 
THE WITNESS: On the instruction of my 
9 
Q. Ma'am. are you invoking your Fifth 
10 
lawyer, I must choose to invoke my Fifth 
10 
Amendment because your lawyer is advising you to 
11 
Amendment privilege. 
11 
invoke your Fifth Amendment, or because you 
12 
BY MR. KUVIN: 
12 
personally have a fear that you might be prosecuted 
13 
Q. Do you have a personal fear of criminal 
13 
by either the state or the federal government? 
14 
prosecution as ou sit here today? 
14 
MR. 
: We have now been down thin 
15 
MR. 
I instruct the witness -- 
15 
street four times. She's not going to answer 
16 
object to the form. That's the whole basis why 
16 
the question. You can move along or we can 
17 
one would invoke the Fifth Amendment so clearly 17
leave. 
18 
she's does. I am not going to have her answer 
18 
MR. KUVIN: I am just clarifying the 
19 
the question. It's solely meant to harass. 
19 
question. and I appreciate it. And you can 
20 
MR. KUVIN: So is she not going to answer 
20 
object. I just want to make sure that I have a 
21 
that question? 
21 
clear record of every possible machination of 
22 
MR. 
She's not going to answer 
22 
the question so that I don't get hit later with 
23 
that question. 
23 
you didn't ask the specific question you need 
24 
MR. KUVIN: I think what I need to 
24 
to ask. So. I'm not doing it certainly to 
25 
establish is that she personally has a fear, 
25 
harass. I just want to make sure that the 
Page 90 
Page 92 
1 
not her lawyer. So I would like to establish 
1 
record is ve 
clear of my question.
2 
whether the witness has a personal fear. 
2 
MR. 
I understand. You can 
3 
MR. 
Well, first of all, under 
3 
move on. 
4 
the Fifth Amendment you don't have to be in 
4 
BY MR. KUVIN: 
5 
fear. You just have to believe that the 
5 
Q. Ma'am, have you had any direct 
6 
government believes you can be prosecuted for 
6 
communications with the State Attorney's office in 
7 
something. She's been invoking the Fifth 
7 
the last two ears?
8 
Amendment on her own. It is implicit in her 
8 
MR. 
When you say "direct 
9 
invocation in what she fears. She's not going 
9 
communications," can you clarify? 
10 
to answer that question. 
10 
MR. KUVIN: Yes. 
11 
MR. KUVIN: Well, I tend to disagree. She 
11 
BY MR. KUVIN: 
12 
hasn't been invoking it on her own. She's been 
12 
Q. You, personally, have you spoken with 
13 
invoking it after you have instructed her to 
13 
anyone in the State Attorney's office in the last 
14 
invoke it. So I want to know her personal -- 
14 
two years? 
15 
MR. 
: You can take that up with 
15 
MR. KUVIN: I can't imagine there would be 
16 
the judge then. She's not answering the 
16 
a Fifth Amendment for that. 
17 
question. She's invoking her Fifth Amendment 
17 
MR. 
Let me consult. If I 
18 
on her own accord based on the advice of her 
18 
might. Okay? 
19 
lawyer. And you can take it up somewhere else, 
19 
MR. KUVIN: Sure. 
20 
but she's not answering that question. 
20 
MR. 
It would all depend on 
21 
MR. KUVIN: Well, then let me clarify the 
21 
what was said to her if she could consult with 
22 
record. 
22 
them now. For example, if they consulted and 
23 
BY MR. KUVIN: 
23 
they told her they were about to prosecute, 
24 
Q. Ma'am. are you invoking your Fifth 
24 
then there could be a Fifth Amendment claim, 
25 
Amendment because you personally have a concern of 25 
couldn't there? 
23 (Pages 89 to 92) 
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1 
MR. KUVIN: No, not as to the statements 
1 
Q. Have you spoken with anybody at the U.S. 
2 
they told her. I mean. that's certainly not 
2 
Attorney's Office in the last five years? 
3 
Fifth Amendment. That's something that was 
3 
A. No. 
4 
told to her. 
4 
Q. Have you spoken with anyone at the FBI in 
5 
MR. 
: We'll take that up 
5 
the last five years? 
6 
elsewhere if you need to. You can answer. 
6 
A. No. 
7 
MR. KUVIN: Okay. 
7 
Q. Have you spoken with anyone at the 
8 
THE WITNESS: No, I have not. 
8 
Palm Beach Police De .artment in the last five years? 
9 
BY MR. KUVIN: 
9 
MR. 
: When you say, "the Palm 
10 
Q. All right. Ma'am. have you had any 
10 
Beach Police," for any purpose or as related to 
11 
personal communications with anyone working for the 11 
this case? Again, for example. if there was 
12 
federal government in the last two years? 
12 
like a parking ticket --
13 
MR. 
: When you say "the federal 13 
MR. KUVIN: Sure. 
14 
government" do you mean the postal service, the 
14 
MR. 
: -- or some other thing. I 
15 
entire federal government, or do you want to 
15 
want to clarify that. 
16 
clarify that? 
16 
BY MR. KUVIN: 
17 
MR. KUVIN: Well. I certainly could leave 
17 
Q. Let's, let's start with broad, and we can 
18 
it open-ended. If she's talked to a post 
18 
work to specific. Can you recall having any 
19 
office employee, that would be interesting, but 
19 
conversations for any reason with the Palm Beach 
20 
certainly not to this case. 
20 
Police Department in the last five years? 
21 
BY MR. KUVIN: 
21 
A. No. 
22 
Q. Let's talk about the U.S. Attorney's 
22 
Q. Okay. Do you have knowledge whether or 
23 
Office or anyone working on behalf of the U.S. 
23 
not the Palm Beach Police Department ever requested 
24 
Attorney's Office. 
24 
for you to come in for an interview at any time in 
25 
A. Have I personally ever spoken to anyone? 
25 
the last five years? 
Page 94 
Page 96 
1 
Q. Yes, ma'am, personally have you ever had 
1 
MR. 
: If you know the answer tc 
2 
any conversations with anyone at the U.S. Attorney's 
2 
that question because that's something your 
3 
Office or one of their -- one -- a person 
3 
attorney told you, you don't have to answer 
4 
representing to be from that office in the last two 
4 
that question. Otherwise, go ahead and answer. 
5 
years. 
5 
THE WITNESS: No. 
6 
A. No. 
6 
BY MR. KUVIN: 
7 
Q. Okay. Do you know, as you sit here today, 
7 
Q. Okay. When did you first retain an 
8 
whether or not you ever were requested to give a 
8 
attorney? What date did you first retain a -- I 
9 
statement by the State Attorney's office for the 
9 
mean, let me clarify. What date did you first 
10 
Palm Beach Police De 'ailment? 
10 
retain a criminal attorne ? 
11 
MR. 
: May I consult? 
11 
MR. 
: I'll instruct her not to 
12 
MR. KUVIN: Yes. 
12 
answer based on the Fifth Amendment privilege. 
13 
MR. 
: You may answer. And for 13 
THE WITNESS: On the instruction of my 
14 
the record. I was just determining whether the 
14 
lawyer, I must invoke my Fifth Amendment 
15 
answer to that question would be protected by 
15 
privilege. 
16 
the attorney-client privilege. 
16 
BY MR. KUVIN: 
17 
MR. KUVIN: Understood. 
17 
Q. Did you first retain a criminal attorney 
18 
THE WITNESS: No, I don't. I don't know. 
18 
in the year 2005? 
19 
BY MR. KUVIN: 
19 
MR. 
: Same instruction. 
20 
Q. Let me clarify the last two questions I 
20 
THE WITNESS: On the instruction of my 
21 
asked about the State Attorney's Office and the U.S. 
21 
lawyer, I must invoke my Fifth Amendment 
22 
Attorney's Office. Have you spoken with anybody 
22 
privilege. 
23 
personally at the State Attorney's Office in the 
23 
BY MR. KUVIN: 
24 
last five years? 
24 
Q. Did you retain a criminal attorney in 
25 
A. No. 
25 
2004? 
24 (Pages 93 to 9 6) 
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1 
MR. 
Same instruction. 
1 
assumes facts that have not been established 
2 
THE WITNESS: On the instruction of my 
2 
and it's compound. 
3 
lawyer, I must invoke my Fifth Amendment 
3 
THE WITNESS: On the instruction of my 
4 
privilege. 
4 
lawyer, I must invoke my Fifth Amendment 
5 
BY MR. KUVIN: 
5 
privilege. 
6 
Q. Have you ever worked as a professional 
6 
MR. 
: And to clarify the 
7 
model? 
7 
objection is that it assumes that she's ever 
8 
MR. 
May I consult? 
8 
met or knows anything about Jean-Luc Brunel. 
9 
MR. KUVIN: Sure. 
9 
BY MR. KUVIN: 
10 
MR. 
You can answer the 
10 
Q. Were you ever promised anything regarding 
11 
question. 
11 
your modelin career b Jeffrey Epstein?
12 
THE WITNESS: Yes. 
12 
MR. 
: Same objection, instruct 
13 
BY MR. KUVIN: 
13 
the witness not to answer. 
14 
Q. When? 
14 
THE WITNESS: On the instruction of my 
15 
A. I don't remember. I don't remember the dates. 15 
lawyer, I must invoke my Fifth Amendment 
16 
It was at least maybe ten years ago. 
16 
privilege. 
17 
Q. And ou're how old now? 
13 
BY MR. KUVIN: 
18 
MR. 
I'll instruct the witness 
19 
Q. You would agree with me that there is a 
19 
not to answer the question. Nice try. 
19 
financial arrangement between Jean-Luc Brunel and 
20 
Instruct 
not to answer based on 
20 
Jeffrey Epstein. doyou not? 
21 
you 
your Fifth Amendment privilege. 
21 
MR. 
: Objection. It assumes she 
22 
THE WITNESS: On the instruction of my 
22 
has any knowledge of either Mr. Epstein or 
23 
lawyer, I'm going to invoke my Fifth Amendment 
23 
Mr. Brunel. and as to that she is going to 
24 
privilege. 
24 
invoke her Fifth Amendment privilege. The 
25 
MR. KUVIN: I'm just trying to find out. 
25 
question is compound and therefore ambiguous. 
Page 98 
Page 100 
1 
MR. 
Like I said, good try. 
1 
THE WITNESS: On the instruction of my 
2 
Move on. 
2 
lawyer, I must invoke my Fifth Amendment 
3 
BY MR. KUVIN: 
3 
privilege. 
4 
Q. With respect to your work as a 
4 
BY MR. KUVIN: 
5 
professional model. what company did you work for? 
5 
Q. Would you agree with me that 
6 
MR. 
Instruct the witness not 
6 
Ghislaine Maxwell provides underage girls to 
7 
to answer based on the Fifth Amendment 
7 
Mr. Epstein for sex? 
8 
privilege. 
8 
MR. 
Objection to the font. It 
9 
THE WITNESS: On the instruction of my 
9 
assumes she knows anything at all about 
10 
lawyer, I invoke my Fifth Amendment privilege. 
10 
Ghislaine Maxwell and asks her to assume that 
11 
BY MR. KUVIN: 
11 
she does, and therefore it is compound and 
12 
Q. What is your understanding of 
12 
ambiguous, and I would instruct her not to 
13 
Mr. Epstein's involvement with the modeling 
13 
answer. 
14 
industry? 
14 
THE WITNESS: Upon the instruction of my 
15 
MR. 
Standing objection, and 
15 
lawyer, I must invoke my Fifth Amendment 
16 
instruct the witness not to answer based on 
16 
privilege. 
17 
Fifth Amendment, on that basis. 
17 
MR. KUVIN: That's a good point. Take a 
18 
THE WITNESS: Upon the instruction of my 
18 
look at what we'll mark as Exhibit 10. 
19 
lawyer, I must invoke my Fifth Amendment 
19 
(Plaintiff's Exhibit No. 10 was marked for 
20 
privilege. 
20 
identification.) 
21 
BY MR. KUVIN: 
21 
MR. KUVIN: All me to show it to the 
22 
Q. Were you ever promised anything regarding 
22 
camera first. 
23 
24 
your modelin career b Jean-Luc Brunel? 
MR. 
. Instruct the witness not 
23 
24 
MR. 
MR. KUVIN: Okay. 
Okay. 
25 
to answer based on Fifth Amendment. also 
25 
THE WITNESS: Okay. 
25 (Pages 97 to 100) 
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1 
BY MR. KUVIN: 
1 
You're asking the witness three 
2 
Q. Take a look at what we marked as Exhibit 
2 
questions at the same time, and I would 
3 
10. Do you recognize the two people in that 
3 
instruct her not to answer based on the 
4 
photograph? 
4 
Fifth Amendment. 
5 
MR. 
: I'll instruct the witness 
5 
THE WITNESS: On the instruction of my 
6 
not to answer based on her Fifth Amendment 
6 
lawyer, I must invoke my Fifth Amendment 
7 
privilege. 
7 
privilege. 
8 
THE WITNESS: On the instruction of my 
8 
MR. KUVIN: Just so we're clear, had she 
9 
lawyer, I must invoice my Fifth Amendment 
9 
answered the first two questions, then 
10 
privilege. 
10 
obviously I wouldn't have to ask the third one 
11 
BY MR. KUVIN: 
11 
that has all of them in it but --
12 
Q. Would you agree with me that's 
12 
MR. 
: If you had accepted her 
13 
Ghislaine Maxwell on the right and Jeffrey Epstein 
13 
answer, you would have known that she wasn't 
14 
on the left? 
14 
going to answer these, and we could have saved 
15 
MR. 
: Objection to the form. It 15 
a few minutes. 
16 
assumes that she knows who Ghislaine Maxwell 
16 
MR. KUVIN: And as you well know, I must 
17 
and Jeffrey Epstein are, and therefore it's 
17 
ask the question in order to gain the inference 
18 
compound and ambiguous, and I would instruct 
18 
at trial. 
19 
her not to answer. 
19 
MR. 
: I understand. 
20 
THE WITNESS: On the instruction of my 
20 
MR. KUVIN: All right. 
21 
lawyer, I must invoke my Fifth Amendment 
21 
(Plaintiff's Exhibit No. 12 was marked for 
22 
privilege. 
22 
identification.) 
23 
MR_ KUVIN: Okay. I will mark this as 
23 
BY MR. KUVIN: 
24 
Exhibit II. 
24 
Q. Do you recognize the gentleman that is 
25 
25 
shown --
Page 102 
Page 104 
1 
(Plaintiff's Exhibit No. II was marked for 
1 
MR. 
We'll have a job here. 
2 
identification.) 
2 
MR. KUVIN: That is true. 
3 
BY MR. KUVIN: 
3 
BY MR. KUVIN: 
4 
Q. Let me show you what we marked as 
4 
Q. -- that is shown in Exhibit 12? 
5 
Exhibit II. Han on one second. 
5 
MR. KUVIN: Let me hold this for the 
6 
MR. 
Sure. 
BY MR. KUVIN: 
6 
7 
camera first.
7 
MR. 
I'm sorry. Is there a 
8 
Q. Do you recognize the young lady shown in 
8 
question pending? 
9 
Exhibit II? 
9 
MR. KUVIN: Yes. 
10 
MR. 
I'll instruct the witness 
10 
BY MR. KUVIN: 
11 
not to answer based on her Fifth Amendment 
11 
Q. Do you recognize the gentleman shown in 
12 
privilege. 
12 
Exhibit 12? 
13 
THE WITNESS: On the instruction of my 
13 
MR. 
I instruct her not to 
14 
lawyer. I must invoke my Fifth Amendment 
14 
answer based on the Fifth Amendment. 
15 
privilege. 
15 
THE WITNESS: On the instruction of my 
16 
BY MR. KUVIN: 
16 
lawyer, I must invoke my Fifth Amendment 
17 
Q. Do you agree with me that the young girl 
17 
privilege. 
18 
shown in Exhibit II was recruited by Ghislaine 
18 
BY MR. KUVIN: 
19 
Maxwell to, for sexual activity with 
19 
Q. Would you agree with me that that is 
20 
Jeffrey Epstein? 
20 
Prince Andrew shown in Exhibit 12? 
21 
MR. 
Objection to the form. It 
21 
MR. 
Same instruction. 
22 
assumes she knows who the person is in Exhibit 
22 
THE WITNESS: On the instruction of my 
23 
II. and assumes she knows who Ghislaine Maxwell 23 
lawyer, I must invoke my Fifth Amendment 
24 
is. and assumes she knows who Jeffrey Epstein 
24 
privilege. 
25 
is. and is therefore compound. 
25 
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Page 105 
Page 107 
1 
BY MR. KUVIN: 
1 
break now. 
2 
Q. Would you agree with me that you have been 
2 
MR. KUVIN: Okay. 
3 
present where Jeffrey Epstein and Prince Andrew have 
3 
THE VIDEOGRAPHER: We're now off video 
4 
had sexual relations with underage girls? 
4 
record. The time is 11:57 a.m. 
5 
MR. 
Objection to the form, 
5 
(A luncheon recess was held.) 
6 
it's compound in that it assumes she knows who 
6 
(Plaintiffs Exhibit No's 4 was marked for 
7 
the person is in Picture 12. she knows who 
7 
identification.) 
8 
Prince Andrew is, and she knows who Jeffrey 
8 
(Plaintiffs Exhibit No. 5 was marked for 
9 
Epstein is. It's compound and ambiguous, and 
9 
identification.) 
10 
I'll instruct her not to answer based on her 
10 
THE VIDEOGRAPHER: We're now on video 
11 
Fifth Amendment. 
11 
record. The time is 1:02 p.m. 
12 
THE WITNESS: On the instruction of my 
12 
MR. KUVIN: All right, counsel. I'm going 
13 
lawyer, I must invoke my Fifth Amendment 
13 
to ask a couple more general questions, and 
14 
privilege. 
14 
then when we get into the specifics of the 
15 
BY MR. KUVIN: 
15 
individual girls. I just want to make sure, 
16 
Q. Would you agree with me that Prince Andrew 
16 
once again, on the record, as we've done in 
17 
and Jeffrey Epstein used to share underaged girls 
17 
every deposition in this case, that we'll use 
18 
for sexual relations? 
18 
the Plaintiffs full name with the 
19 
MR. 
Same objection previously 19 
understanding that the final transcript will 
20 
stated, requires her to also speculate who 
20 
only contain their initials, and there will be 
21 
Prince Andrew is. I instruct her not to answer 
21 
a key at the conclusion that's only provided to 
22 
based on the Fifth Amendment. 
22 
the parties in this case and their counsel to 
23 
THE WITNESS: On the instruction of my 
23 
be kept confidential going forward. But 
24 
lawyer, I must invoke my Fifth Amendment 
24 
obviously, for the purposes of this deposition, 
25 
privilege. 
25 
we will be using full names. 
Page 106 
Page 108 
1 
MR. 
Also requires speculation 
1 
MR. 
Agreed. 
2 
as to who Jeffrey Epstein is as well. 
2 
MR. KUVIN: Okay. Is there any 
3 
BY MR. KUVIN: 
3 
disagreement with that around the table? 
4 
Q. Do ou know who Prince Andrew is? 
4 
MR. HOROWITZ: Agreed. 
5 
MR. 
• I'll instruct her not to 
5 
MR. WEISSING: Agreed. 
6 
answer based on the Fifth Amendment. 
6 
MS. EZELL: Agreed. 
7 
THE WITNESS: On the instruction of my 
7 
MR. KUVIN: Jack, do you agree to the --
8 
lawyer. I must invoke my Fifth Amendment 
8 
MR. GOLDBERGER: I thought I'm not a pan 
9 
privilege. 
9 
of it. 
10 
MR. KUVIN: It's almost 12:00. Do you 
10 
MR. KUVIN: Well, you've been playing a 
11 
want to take a uick lunch? 
11 
pan, so I want to make sure you agree. 
12 
MR. 
Sure. How much longer do 12 
MR. GOLDBERGER: Yeah. I agree. I agree. 
13 
you think you will be. Mr. Kuvin, before we go 
13 
MR. 
: Hold on. Let me just 
14 
on to other counsel? 
14 
explain to her what we're talking about. 
15 
MR. KUVIN: Probably not that much longer. 
15 
MR. KUVIN: Please do. 
16 
MR. 
Okay. 
16 
MR. 
: But when the transcript is 
17 
MR. KUVIN: I have to get through a couple 
17 
typed up, it won't have her name it will just 
18 
of more generic stuff, and then get into the 
18 
have initials. But we'll get a code that 
19 
specifics of m cases and then -- 
19 
explains the name. So that way you would be 
20 
MR. 
Okay. So. we. but just so 
20 
asked if you recognize the name not a set of 
21 
we have a sense of planning whether this is the 
21 
initials that you may not understand or a Jane 
22 
right time for a lunch break. You're not going 
22 
Doe number that you do not know. 
23 
to finish in the next 15 or 20 minutes? 
23 
MR. KUVIN: That's way too confusing. 
24 
MR. KUVIN: No. not even close. 
24 
Okay? 
25 
MR. 
Okay. Let's take a lunch 
25 
MR. 
Correct. 
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BY MR. KUVIN: 
1 
objection to the form. 
2 
Q. Let's take a look at what Tve marked -- 
2 
THE WITNESS: At the instruction of my 
3 
premarked as Exhibit 4. It's a stack of documents, 
3 
lawyer, I must invoke my Fifth Amendment 
4 
just so you understand what this is and your 
4 
privilege. 
5 
attorney can object or agree or disagree as he sees 
5 
BY MR. KUVIN: 
6 
fit, but this is a stack of documents that was part 
6 
Q. Yes. Do
7 
of the trash pull from Jeffrey Epstein's home as 
7 
MR. 
Instruct the witness not 
8 
part of the criminal investigation. Just so you're 
8 
to answer the question based on her Fifth 
9 
aware of what these are. 
9 
Amendment privilege. 
10 
MR. 
That was retrieved, that 
10 
THE WITNESS: On the instruction of my 
11 
was retrieved by the Palm Beach Police 
11 
lawyer, I must exercise my Fifth Amendment 
12 
Department from the trash -- 
12 
privilege. 
13 
MR. KUVIN: That's correct. 
13 
BY MR. KUVIN: 
14 
MR. 
: -- at the home of what is 14 
Q. Will you agree with me that on the first 
15 
known to be Mr. Epstein's home? 
15 
page of Exhibit 4, you were to arrange for roses to 
16 
MR. KUVIN: Correct. 
16 
be delivered to Jane Doe No. 103 at her high school 
17 
MR. 
: Okay. 
17 
performance? 
18 
MR. KUVIN: All right. And that's not a 
18 
MR. 
Objection to the form. 
19 
question. I just wanted to kind of give you a 
19 
It's compound in that it assumes this is the 
20 
context for what I'm going to be asking you 
20 
witness's handwriting and assumes the witness 
21 
about. 
21 
knows a person by the name of Jane Doe No. 103 
22 
MR. 
Thank you. 
22 
and the witness otherwise knows Jeffrey Epstein 
23 
BY MR. KUVIN: 
23 
whose name is at the bottom of the paper, and 
24 
Q. All right. In taking a look at Exhibit 4, 
24 
therefore, it's compound and ambiguous, and 
25 
I'd like you to take a look at the front page, the 
25 
instruct her not to answer. 
Page 110 
Page 112 
1 
first page of those documents. 
1 
THE WITNESS: On the instruction of my 
2 
3 
Is that our handwriting, ma'am? 
MR. 
: Instruct the witness not 
2 
3 
lawyer, I must exercise my Fifth Amendment
right. 
4 
to answer based on the Fifth Amendment 
4 
MR. KUVIN: I forgot to mention this at 
5 
privilege. 
5 
the beginning, but objection to form usually 
6 
THE WITNESS: At the instruction of my 
6 
covers all that stuff like vague and compound, 
7 
lawyer, I must exercise my Fifth Amendment 
7 
and --
8 
right. 
8 
MR. 
: Okay. 
9 
BY MR. KUVIN: 
9 
MR. KUVIN: --I'll leave it up to you, 
10 
Q. And, in fact, that is your handwriting on 
10 
but objection to form as far as the civil arena 
11 
this notepad is it not? 
11 
context will cover all of those. 
12 
MR. 
Same instruction. It's 
12 
MR. 
: Just figured I'd make the 
13 
the same question. 
13 
record clear in case we ever have an issue, or 
14 
THE WITNESS: On the instruction of my 
14 
in case you want to correct it based on what I 
15 
lawyer, I must invoke my Fifth Amendment right. 15 
believe to be the improper form. I will give 
16 
BY MR. KUVIN: 
16 
you a chance to correct it. 
17 
Q. In this note do you agree that you 
17 
BY MR. KUVIN: 
18 
arranged for an extension of one month on the rental 
18 
Q. No problem. All right. On Page 2 of 
19 
car for a 
lad under the age of 16? 
19 
Exhibit 4, if you'd take a look at that. Is that 
20 
MR. 
Objection to the form. It 
20 
your handwritin ? 
21 
is compound. It assumes that this is her 
21 
MR. 
: Instruct the witness not 
22 
handwriting. It doesn't identify who the 
22 
to answer based on the Fifth Amendment 
23 
lady might be, and it's otherwise ambiguous, so 
23 
privilege. 
24 
I instruct her not to answer on the Fifth 
24 
THE WITNESS: On the instruction of my 
25 
Amendment privilege in addition to the legal 
25 
lawyer. I choose to exercise my Fifth Amendment 
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1 
right. 
1 
MR. 
Okay. I would be happy 
2 
BY MR. KUVIN: 
2 
to. 
3 
Q. Do you know who Larry is, as referred to 
3 
MR. KUVIN: I just want to clarify, 
4 
in Page 2 of Exhibit 4? 
4 
because I don't think --
5 
MR. 
I'm sorry. Can you -- 
5 
MR. 
Okay. 
6 
BY MR. KUVIN: 
6 
MR. KUVIN: I don't think this is a 
7 
Q. Do ou know who -- 
7 
problem but I 'ust want to clear it up. 
8 
MR. 
-- restate the question? 
8 
MR. 
Thank you, Mr. Kuvin. 
9 
BY MR. KUVIN: 
9 
I'll let her answer that question. 
10 
Q. Do you know who Larry is as referred to in 
10 
MR. KUVIN: Not a problem. 
11 
Page 2 of Exhibit 4? 
11 
MR. 
So the question pending 
12 
MR. 
So, just so I'm clear. 
12 
is, is that your handwriting? 
13 
what the question is, the document on its face 
13 
MR. KUVIN: Correct. 
14 
has the name Larry in it. You're just asking 
14 
BY MR. KUVIN: 
15 
this witness whether she knows who this person 
15 
Q. Is this your handwriting? Just yes or no. 
16 
Larry is? 
16 
A. No. 
17 
MR. KUVIN: Correct. 
17 
Q. Okay. Thank you. All right. Let's look 
18 
MR. 
• Instruct the witness not 
18 
at Page 4 of Exhibit 4. All right. This one's a 
19 
to answer based on her Fifth Amendment 
19 
little different. Is this our handwriting? 
20 
privilege. 
20 
MR. 
Let me consult with her 
21 
THE WITNESS: On the instruction of my 
21 
again. 
22 
lawyer, I must invoke my Fifth Amendment right. 22 
Okay. That's fine. You can answer 
23 
BY MR. KUVIN: 
23 
the question consistent with the 
24 
Q. Do you know why Larry was recommending 
24 
conversation we just had. 
25 
that Mr. Epstein leave? 
25 
THE WITNESS: No. 
Page 114 
Page 116 
1 
MR. 
Objection to the form and 
1 
BY MR. KUVIN: 
2 
instruct the witness not to answer based upon 
2 
Q. Do you know who 
is as referred to 
3 
her Fifth Amendment privilege. 
3 
in this note of Pa _e 4 of Exhibit 4? 
4 
THE WITNESS: On the instruction of my 
4 
MR. 
: Instruct the witness not 
5 
lawyer, I must invoke my Fifth Amendment right. 
5 
to answer based on her Fifth Amendment 
6 
BY MR. KUVIN: 
6 
privilege. 
7 
Q. Would you agree with me that Larry was 
7 
THE WITNESS: On the instruction of my 
8 
calling to warn Mr. Epstein to leave town because he 
8 
lawyer, I must exercise my Fifth Amendment 
9 
was going to be arrested? 
9 
right. 
10 
MR. 
Objection to the form. 
10 
BY MR. KUVIN: 
11 
The question assumes facts that are not before 
11 
Q. All right. Let's look at Page 5, 
12 
her, and it requires her to speculate, and also 
12 
Exhibit 4. 
13 
implies that she knows anything at all about 
13 
Before we go to Page 5, rather, going 
14 
Jeffrey Epstein, so I will instruct her not to 
14 
back St
aris 4 for a minute. Will you agree with me 
15 
answer. 
15 
that 
as referred to in Page 4 of Exhibit 4 
16 
THE WITNESS: On the instruction of my 
16 
is a girl that is under the age of 16? 
17 
lawyer, I wish to exercise my Fifth Amendment 
17 
MR. 
: Object to the form. You 
18 
right. 
18 
previously asked if she knew who 
was, 
19 
BY MR. KUVIN: 
19 
and she invoked her Fifth Amendment privilege. 
20 
Q. Take a look at Page 3 of Exhibit 4, 
20 
Since the new
 presumes that she does 
21 
please. Is that our handwriting? 
21 
know who 
is she is going to invoke her 
22 
MR. 
I'll instruct her not to 
22 
Fifth Amendment privilege upon my instruction. 
23 
answer based on the Fifth Amendment privilege. 
23 
MR. KUVIN: All right. Let's look at 
24 
MR. KUVIN: Before we do that, would you 
24 
Page 5. 
25 
consult with her? 
25 
MR. 
Let her answer. 
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Page 117 
Page 119 
1 
MR. KUVIN: I'm sorry. go ahead. 
1 
that Page 5 of Exhibit 4 appears to be a receipt for 
2 
3 
THE WITNESS: On the instruction of my 
lawyer. I must invoke my Fifth Amendment 
2 
3 
books ordered
 
MR. 
red throw h Amazon.com? 
: You can answer that yes or 
4 
privilege. 
4 
no. 
5 
BY MR. KUVIN: 
5 
THE WITNESS: It looks like a receipt from 
6 
Q. MI right. Take a look at Page 5, if you 
6 
Amazon. 
7 
would. Have you ever ordered anything. anything 
7 
BY MR. KUVIN: 
8 
yourself from Amazon.com? 
8 
Q. Okay. And did you place this order for 
9 
MR. 
• You're asking for herself 
9 
Jeffrey Epstein? 
10 
or anyone else if she has ever placed an order 
10 
MR. 
: Instruct the witness not 
11 
with Amazon.com for any reason? 
11 
to answer the question in that the question 
12 
MR. KUVIN: I am asking whether she 
12 
presumes that she knows who Jeffrey Epstein is. 
13 
personally has ever placed an order with a 
13 
and therefore, I instruct her not to answer. 
14 
compan called Amazon.com. 
14 
THE WITNESS: On advice of counsel. I must 
15 
MR. 
Yes or no. You can answer 15 
invoke my Fifth Amendment privilege. 
16 
that. 
16 
BY MR. KUVIN: 
17 
THE WITNESS: Yes. 
17 
Q. Have you ever read the book identified in 
18 
BY MR. KUVIN: 
18 
Page 5 of Exhibit 4 called Slave Craft: Road Maps 
19 
Q. Okay. So you would agree with me that you 
19 
for Erotic Servitude - Principals. Skills and Tools? 
20 
know what Amazon.com is? 
20 
MR. 
: Instruct the witness not 
21 
A. Yes. 
21 
to answer based on her Fifth Amendment 
22 
Q. Okay. Now, have you ever placed an order 
22 
privilege. 
23 
through Amazon.com for things to be delivered at 
23 
THE WITNESS: On the instruction of my 
24 
358 El Brillo Wa ? 
24 
lawyer, I must choose to invoke my Fifth
25 
MR. 
Instruct the witness to 
25 
Amendment right. 
Page 118 
Page 120 
1 
invoke her Fifth Amendment privilege as to that 
1 
BY MR. KUVIN: 
2 
question. 
2 
Q. Did you ever see that book I just 
3 
THE WITNESS: On the instruction of my 
3 
described at the home of Jeffrey Epstein on 
4 
lawyer, I must invoke my Fifth Amendment 
4 
358 El Brillo Wa ? 
5 
privilege. 
5 
MR. 
: Objection to the form in 
6 
BY MR. KUVIN: 
6 
that it presumes she knows Jeffrey Epstein and 
7 
Q. Will ou a ree with me -- 
7 
has ever been to 358 El Brillo Way. So, I 
8 
MR. 
• I'm sorry. Mr. Kuvin, for, 
8 
instruct her not to answer based on the Fifth 
9 
for the record, the page. pages of this exhibit 
9 
Amendment. 
10 
are not numbered, but the page we're looking at 
10 
THE WITNESS: On the instruction of my 
11 
purports to be a receipt for an order from 
11 
lawyer. I must choose to invoke my Fifth 
12 
Amazon.com; is that correct? 
12 
Amendment right. 
13 
MR. KUVIN: Correct. I just want her to 
13 
BY MR. KUVIN: 
14 
establish foundation before I got into 
14 
Q. Have you ever seen the book, Training With 
15 
specifics. 
15 
Miss Abernathy: A Workbook for Erotic Slaves and 
16 
MR. 
No, but you referred to it 16 
Their Owners, at the home of Jeffrey Epstein on 
17 
18 
as Page 5, but they are not numbered, so I just 
wanted to make sure that were looking at the 
17 
18 
358 El Brillo Wa ? 
MR. 
: Same objection and same 
19 
same page on the exhibit. 
19 
instruction as the previous question. 
20 
MR. KUVIN: That is true. I'm just trying 
20 
THE WITNESS: On the instruction of my 
21 
to establish foundation for the questions I'm 
21 
lawyer, I must choose to invoke my Fifth 
22 
about to ask her. 
22 
Amendment right. 
23 
MR. 
Understood. 
23 
BY MR. KUVIN: 
24 
BY MR. KUVIN: 
24 
Q. Have you ever read that book that I just 
25 
Q. All right. Ma'am. would you agree with me 
25 
described which is shown in Page S of Exhibit 4? 
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1 
MR. 
Same instruction. 
1 
BY MR. KUVIN: 
2 
THE WITNESS: On the instruction of my 
2 
Q. This note, Page 9 of Exhibit 4, appears to 
3 
lawyer, I must choose to invoke my Fifth 
3 
state that 
is trying to move -- and then 
4 
Amendment right. 
4 
there's a blanked out name, for 11 then 
S 
BY MR. KUVIN: 
5 
could work at 6. Do you know anyone with the name 
6 
Q. Let's look at the sixth page of Exhibit 4, 
6 
M? 
7 
please. Is that your handwriting? 
7 
MR. 
If she knows anyone in the 
8 
A. No. 
8 
world by that name? 
9 
Q. All right. Let's look at Page 7. Is that 
9 
MR. KUVIN: Yeah. We could start with 
10 
your handwriting? 
10 
that. 
11 
A. No. 
11 
MR. 
I'm saying, in the 
12 
Q. Okay. Look at the next page which would 12 
context, are you asking in the context of this 
13 
be Page 8. Is that your handwriting? 
13 
note which you just read, or are you asking. 
14 
A. No. 
19 
generically, does she know anyone in the world 
15 
Q. Let's see how much quicker this goes. 
15 
by the name of 
? 
16 
Let's look at Page 9. Is that your handwriting? 
16 
MR. KUVIN: Why don't we rust do it in 
17 
A. No. 
17 
the context of this note. 
18 
Q. Look at Pa e 9 a ain, if you would. 
18 
BY MR. KUVIN: 
19 
MR. 
• When you say Page 9, 19 
Q. Is this note referring to you when it 
20 
that's the page that purports to say 10:00. 
20 
says,' 
"? 
21 
MR. KUVIN: Dr. Bard. 
21 
MR. 
: Instruct the witness not 
22 
MR. 
-- Dr. Bard at the top? 22 
to answer based on her Fifth Amendment 
23 
MR. KUVIN: Correct. 
23 
privilege. 
24 
MR. 
Okay. 
24 
THE WITNESS: On the advice of counsel. I 
25 
25 
must invoke my Fifth Amendment right. 
Page 122 
Page 124 
1 
BY MR. KUVIN: 
1 
BY MR. KUVIN: 
2 
Q. Doyou know who Dr. Bard is? 
2 
In the context of this note, do you know 
3 
4 
MR. 
Instruct the witness not 
to answer based on the Fifth Amendment, because 
3 
4 
who 
is? 
MR. 
: Same instmction. 
5 
this sheet of paper has Jeffrey Epstein's name 
5 
THE WITNESS: On the advice of counsel, I 
6 
on the bottom, so the question implies that she 
6 
must invoke my Fifth Amendment right. 
7 
knows some connection between Dr. Bard and 
7 
BY MR. KUVIN: 
8 
Mr. Epstein. 
8 
Q. All ri t. Let's look at Page 10. 
9 
MR. KUVIN: Hang on a minute. Based on 
9 
MR. 
: Mr. Kuvin, let me go back 
10 
the objection, let me reword the question. 
10 
MR. KUVIN: Sure. 
11 
BY MR. KUVIN: 
11 
MR. 
: As to Page 1 of this 
12 
Q. Independent from this note and independent 
12 
exhibit. I think you had asked the witness 
13 
from anyone who may or may not be known as 
13 
whether this was her handwriting. 
14 
Jeffrey Epstein, do you know anyone by the name of 
14 
MR. KUVIN: Do you want to have her go 
15 
Dr. Bard? 
15 
back and answer? 
16 
A. I'm sorry. Ask the question again. 
16 
MR. 
: Yes, I would. Having 
17 
Q. Yes. I don't want you to assume anything 
17 
consulted with her further, I will have her go 
18 
from, the purpose of my question has anything to do 
18 
back to this question. 
19 
with someone who may be known as Jeffrey Epstein. 19 
MR. KUVIN: Let's do that. I'll, I'll go 
20 
All I'm asking you is, generally, do 
20 
back and ask the question so that we can be 
21 
you know a 
rson b the name of Dr. Bard? 
21 
clear. 
22 
MR. 
Let me consult. 
22 
BY MR. KUVIN: 
23 
MR. KUVIN: Yes, yeah. 
23 
Q. On the Exhibit 4. the first page of 
24 
THE WITNESS: At the advice of counsel, I 
24 
Exhibit 4, ma'am. is that your handwriting? Yes or 
25 
must invoke my Filth Amendment right. 
25 
no. 
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1 
A. No. 
1 
it in giving my advice, so thank you for 
2 
Q. Okay. All right. Let's skip Page 10. 
2 
clarifying. 
3 
because I think that's just a duplicate, and go to 
3 
MR. KUVIN: Absolutely. 
4 
Page 11, if ou would. 
4 
BY MR. KUVIN: 
5 
MR. 
: Page I 1 is -- 
5 
Q. All right. In Page II of Exhibit 4, 
6 
MR. KUVIN: It looks like DTG Operations, 
6 
there's a reference in the top right-hand comer. a 
7 
d/b/a Dollar Rent a Car. 
7 
message to a Mr. Goldsmith. Do you see that? 
8 
MR. 
: Got it. It's a printed 
8 
A. Uh-huh. 
9 
sheet, not a handwritten sheet. 
9 
Q. Yes? 
10 
MR. KUVIN: Correct. 
10 
MR. 
: You have to say yes or no 
11 
MR. 
: Okay. Thank you. 
11 
on the record. 
12 
BY MR. KUVIN: 
12 
THE WITNESS: Yes. I see it. 
13 
Q. All right. Do you know a gentleman by the 13 
BY MR. KUVIN: 
14 
name of Janusz Banasiak, spelled J-a-n-u-s-z, 
14 
Q. Okay. All right. Do you know who 
15 
B-a-n-a-s-i-a-k? 
15 
Mr. Goldsmith is? 
16 
MR. 
: Instruct the witness not 16 
MR. 
: I instruct the witness 
17 
to answer based on her Fifth Amendment 
17 
not to answer based on her privilege against 
18 
privilege. 
18 
self-incrimination. 
19 
THE WITNESS: On the instruction of, my 
19 
THE WITNESS: At the advice of counsel, I 
20 
lawyer, I must invoke my Fifth Amendment 
20 
must invoke my Fifth Amendment privilege. 
21 
privilege. 
21 
BY MR. KUVIN: 
22 
BY MR. KUVIN: 
22 
Q. Is this your handwriting on exhibit -- on 
23 
Q. Ma'am, isn't it true that you rented cars 
23 
the messages shown in Exhibit 4. Page II? 
24 
through Dollar Rent a Car for underage girls, girls 
24 
MR. 
: Same instruction. 
25 
under the age of 18? 
25 
THE WITNESS: At the advice of counsel, I 
Page 126 
Page 128 
1 
MR. 
Instruct the witness not 
1 
must invoke m Fifth Amendment privilege. 
2 
to answer based on the Fifth Amendment 
2 
MR. 
: Hold on a second. In 
3 
privilege. 
3 
MR. KUVIN: Yeah, check. 
4 
THE WITNESS: On the instruction of my 
4 
MR. 
: Okay. Can you repeat the 
5 
lawyer, I must invoke the Fifth Amendment 
5 
question again? Maybe I misheard it. 
6 
privilege. 
6 
Mr. Kuvin. 
7 
BY MR. KUVIN: 
7 
MR. KUVIN: Yeah, not a problem. Let me 
8 
Q. Did you rent any can from Dollar Rent a 
8 
lay a little foundation for it. 
9 
Car in West Palm Beach in the last five years? 
9 
MR. 
: That's okay. If you can 
10 
MR. 
Same instruction. 
10 
just ask the question again. I think I just 
11 
THE WITNESS: On the instruction of my 
11 
misheard what you were asking. 
12 
lawyer, I must invoke my Fifth Amendment 
12 
BY MR. KUVIN: 
13 
privilege. 
13 
Q. Is this your handwriting shown on the 
14 
BY MR. KUVIN: 
14 
messages which is Page II of Exhibit 4? 
15 
Q. Let's take a look at Page II. 
15 
A. No. 
16 
MR. 
If we can just -- let me 
16 
. Oka . Is this handwriting that of 
17 
go back, Mr. Kuvin, to clarify the prior two 
17 
18 
questions. When you say, "did you rent," did 
18 
MR. KUVIN: 
-- I'm 
sorry.
19 
you mean did she personally pay for the rental, 
19 
=? 
How do you we 
it. 
. 
20 
or was she, in any way, involved in arranging 
20 
MS. CADWELL: 
. 
21 
the rental? 
21 
MR. KUVIN: I knew somebody would know. 
22 
MR. KUVIN: The second part, in any way 
22 
MR. 
: Did we get a 
23 
involved in arranging for the rental of a 
23 
pronunciation, I'm sorry? 
24 
vehicle. 
24 
MR. KUVIN: Yes. 
25 
MR. 
That's how I inter-Feted 25 
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1 
BY MR. KUVIN: 
1 
appear to be directed -- well, let me. let me back 
2 
3 
4 
Q.
 this the handwriting of 
MR. 
if ou know? 
Hold on. Let me object to 
2 
3 
4 
up. 
Page 11 of Exhibit 4 appears to be a 
message dated October 2nd. 2005. from In 
Do you 
S 
the form in that it presumes she knows what 
5 
see that top left-hand corner? 
6 
handwriting is like or that she's 
6 
A. Yes. 
/ 
ever known 
So before you ask the 
7 
Q. Okay. At 10:40 a.m. My question is: Did 
8 
question. try to clarify that. 
8 
you call and leave a message at 10:40 a.m. on 
9 
MR. KUVIN: Well, that's what I'm trying 
9 
October 2, 2005, stating: Mick 
and she 
10 
to find out. 
10 
can't come toda ? 
11 
BY MR. KUVIN: 
11 
MR. 
Instruct the witness not 
12 
13 
O
ourecognize this as the handwriting 
of 
And it can be a yes or no. 
. 
12 
13 
to answer the question based on her Fifth 
Amendment privilege. 
14 
MR. 
My. my objection to the 
14 
THE WITNESS: On the instruction of my 
15 
form is that you, you haven't asked her whether 
15 
lawyer I must exercise my Fifth Amendment 
16 
she actually knows who 
is, or 
16 
privilege. 
17 
whether she would recognize her handwriting if 
17 
BY MR. KUVIN: 
18 
she saw it. 
18 
Q. Upside down at the bottom of Page I I is 
19 
MR. KUVIN: I would love to ask that 
19 
another phone message dated 10/1 of 2005. Appears 
20 
question if she'd answer it. 
20 
to be written to someone named M. 
Do you see 
21 
MR. 
Well, if she'll answer. 
21 
that? 
22 
that's a different question. But I think you 
22 
A. Yes. 
23 
need to ask it first otherwise this question is 
23 
Q. 
ou
ambiguous. 
24 
MR. 
: Is it written. I'm sorry. 
25 
MR. KUVIN: All right. 
25 
is it written to someone named 
or it 
Page 130 
Page 132 
1 
2 
BY MR. KUVIN: 
Q. Not, not to beat a dead horse on the 
1 
2 
to be a phone call 
is
s 
from a person named 
. 
3 
point, do you know 
Mi 
3 
MR. KUVIN: From a person named 
4 
MR. 
I instruct the witness not 
4 
Thank you. 
5 
to answer. 
5 
BY MR. KUVIN: 
6 
THE WITNESS: On advice of counsel, I must 
6 
Q. Did you call someone, anyone on October 1 
7 
invoke my Fifth Amendment privilege. 
7 
of 2005 at 9:50 a.m., to confirm two people. one at 
8 
BY MR. KUVIN: 
8 
11:00 and one at 4:00 ..m.? 
9 
Q. Have you seen 
9 
MR. 
: Instruct the witness not 
10 
handwriting in the 
st? 
10 
to answer based on her Fifth Amendment
11 
• 
MR. 
Objection to the form as 
11 
privilege against self-incrimination since this 
12 
previously stated. I'll instruct the witness 
12 
document was seized from Mr. Epstein's home. 
13 
not to answer. 
13 
THE WITNESS: At the instruction of my 
14 
THE WITNESS: On advice of counsel. I must 14 
lawyer, I must invoke my Fifth Amendment 
15 
invoke my Fifth Amendment privilege. 
15 
privilege. 
16 
BY MR. KUVIN: 
16 
BY MR. KUVIN: 
17 
Q. Do you recd
recognize Pa e 11 in Exhibit 4 as 
1/ 
Q. Are you the 
that's referred to in 
18 
the handwriting of 
. 
18 
these phone messa es that we've been looking at? 
19 
MR. 
Objection to the form for 19 
MR. 
Instruct the witness not 
20 
the reasons previously stated many, many times, 
20 
to answer. 
21 
and I will instruct her not to answer. 
21 
THE WITNESS: On the instruction of my 
22 
THE WITNESS: At the advice of counsel, I 
22 
lawyer, I must invoke my Fifth Amendment 
23 
must invoke my Fifth Amendment privilege. 
23 
privilege. 
24 
BY MR. KUVIN: 
24 
BY MR. KUVIN: 
25 
Q. Did you ever see these messages that 
25 
Q. Let's skip Page 12 and go to Page 13 of 
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1 
this same exhibit, if you would. Okay. 
1 
Fifth Amendment right. 
2 
3 
Is that your handwriting on Pa e 13 
which happens to be a note stating 
s 
2 
3 
BY MR. KUVIN: 
Q. Are you aware that Jeffrey Epstein would 
4 
coming"? 
4 
refer to "work" as performing naked massages for 
5 
MR. 
Okay. Hold on. Can you 
5 
him? 
6 
just show me what page you're looking at? 
6 
MR. 
: Object to the form of the 
7 
Okay. We skipped a page. 
7 
question. It's compound and I instruct the 
8 
THE WITNESS: No. 
8 
witness not to answer. 
9 
BY MR. KUVIN: 
9 
THE WITNESS: On advice of counsel. I wish 
10 
Q. Oka 
Doyou recognize whose it is? 
10 
to invoke my Fifth Amendment right. 
11 
. 
MR. 
Let me talk to you again. 11 
BY MR. KUVIN:
12 
BY MR. KUVIN: 
12 
Q. Let's take a look at the next page. Page 
13 
Q. If it's a yes, you might want to talk to 
13 
16. All right. If we look at not the message, the 
14 
him; if it's a no, it might be quick. 
14 
one message, but the note next to that it says: 
15 
A. No, no. Sony. 
15 
on Saturday with 
at 10:30. 
16 
Q. Let's look at Page 14, same exhibit. The 
16 
Do you know who 
is as referred 
17 
note on the right-hand side states, 'The girl from 
17 
to in this note? 
18 
St. Bart's got sick so she won't be able to come. 
18 
A. On the advice of counsel, I must invoke my 
19 
got message from her." First of all, just 
19 
Fifth Amendment right. 
20 
generally, do you see the note I'm referring to? 
20 
Q. Do you know who 
is as referred to in 
21 
A. Yes. 
21 
this note? 
22 
Q. Okay. Do you know what that is talking 
22 
A. On the advice of counsel. I must invoke my 
23 
about? 
23 
Fifth Amendment right. 
24 
A. No. 
24 
MR. GARCIA: I haven't heard the counsel 
25 
Q. Is that your handwriting? 
25 
give any advice. 
Page 134 
Page 136 
1 
A. No. 
1 
MR. 
: You don't know what we've 
2 
Q. Did Mr. Epstein obtain girls under the age 
2 
talked about outside of the room so... 
3 
of 16 from St. Ban's? 
3 
MR. GARCIA: Just changing the procedure 
4 
MR. 
Instruct the witness not 
4 
is all? 
5 
to answer. Object to the form of the question 
5 
MR. 
: I'm changing the procedure 
6 
in that it presumes that she knows who 
6 
for Mr. Kuvin. 
7 
Mr. Epstein is. 
7 
MR. KUVIN: I'm all happy for speed. 
8 
THE WITNESS: On advice of counsel, I must 
8 
BY MR. KUVIN: 
9 
invoke my Fifth Amendment privilege. 
9 
Q. All right. Let's look at Page 17 of 
10 
BY MR. KUVIN: 
10 
Exhibit 4. It appears to be a phone message at the 
11 
Q. All right. Let's take a look at the next 
11 
bottom dated 9/1/05 to Jeffrey from Jean-Luc. Let 
12 
page. Appears to be a note, phone message of -- I 
12 
me ask this: Do you rec 
tze the . hone number 
13 
can't read the date, 2005 to Jeffrey from 
13 
that's listed there of 
14 
Just generally, do you see what I'm 
14 
MR. 
: Instruct the witness not 
15 
talking about so we're on the same page here? 
15 
to answer based on her Fifth Amendment 
16 
A. Yes. 
16 
privilege and self-incrimination. 
17 
Q. Okay. Do you know who 
is? 
17 
THE WITNESS: On advice of counsel. I must 
18 
A. On the advice of counsel, I wish to invoke my 18 
invoke my Fifth Amendment right. 
19 
Fifth Amendment right. 
19 
MR. KUVIN: Let me show this one to the 
20 
Q. All right. The note appears to say: She 
20 
camera if I could. If you could focus on the 
21 
called again, if she could work any time Monday 
21 
bottom message for me. 
22 
through Friday. 
22 
THE VIDEOGRAPHER: I can't really read 
23 
Do you know what that message 
23 
that. 
24 
pertains to? 
24 
MR. KUVIN: Do I need to tilt it? 
25 
A. On advice of counsel. I wish to invoke my 
25 
THE VIDEOGRAPHER: I think you need to 
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1 
bring the whole paper up closer. 
1 
Do you -- first of all, do you see 
2 
MR. KUVIN: Towards you? 
2 
that in front of you? Are we talking about the same 
3 
THE VIDEOGRAPHER: Yes, towards the lens 
3 
thing here? 
4 
MR. KUVIN: Just pass that up so we can 
4 
A. Yes. 
5 
get a good shot of the bottom message. 
5 
Q. Okay. Do you know who " 
" is 
6 
THE VIDEOGRAPHER: Up a little higher. 
6 
referring to in this note? 
7 
please. Let it focus. That's good. Go out. 
7 
MR. 
Instruct the witness not 
8 
Okay. 
8 
to answer based on her Fifth Amendment 
9 
MR. KUVIN: All right. Thank you veiy 
9 
privilege. 
10 
much. 
10 
THE WITNESS: On the instruction of my 
11 
BY MR. KUVIN: 
11 
lawyer, I must invoke my Fifth Amendment 
12 
Q. The message appears to read: 9/1/2005 to 
12 
privilege. 
13 
Jeffrey, 8:08, Jean-Luc. telephone. He has a 
13 
BY MR. KUVIN: 
14 
teacher for you to teach you how to speak Russian. 
14 
Q. Does your handwriting appear anywhere on 
15 
She is two times eight years old. not blonde. 
15 
Page 19 here --
16 
Lessons are free and you can have first today if you 
16 
A. On the —
17 
call. Do you know what that message is referring 
17 
Q. -- on either note? 
18 
to? 
18 
A. On the advice of my lawyer. I must invoke my 
19 
MR. 
Instruct the witness not 
19 
Fifth Amendment privilege. 
20 
to answer the question. Object to the form of 
20 
Q. Is that your handwriting on the left in 
21 
the question because in that it presumes she 
21 
the note that I just read that says: 
22 
has knowledge of either Jeffrey or Jean-Luc or 
22 
11:00 am.? 
23 
that phone number. 
23 
MR. 
Same instruction. 
24 
THE WITNESS: On the advice of counsel, I 
24 
THE WITNESS: On the instruction of my 
25 
wish to invoke my Fifth Amendment right. 
25 
lawyer, I must invoke my Fifth Amendment 
Page 138 
Page 140 
1 
BY MR. KUVIN: 
1 
privilege. 
2 
Q. Would you agree with me that this message 
2 
BY MR. KUVIN: 
3 
is a message from Jean-Luc, that he's providing a 
3 
Q. All right. Let's take a look at the next 
4 
I6-year-old irl to Jeffre Epstein? 
4 
page which is Page 20. Is that your handwriting on 
5 
MR. 
: Object to the form in that 
5 
this paper? 
6 
it calls for speculation and also assumes facts 
6 
MR. 
: Let me talk to her. 
7 
as to Mr. Jean-Luc and Mr. Epstein; therefore, 
7 
THE WITNESS: On the advice of my lawyer, 
8 
I instruct her to invoke her Fifth Amendment 
8 
I wish to invoke my Fifth Amendment privilege. 
9 
privilege. 
9 
BY MR. KUVIN: 
10 
THE WITNESS: On the instruction from my 
10 
Q. Is this a list of girls that were being 
11 
12 
lawyer, I must invoke my Fifth Amendment 
privilege. 
11 
12 
provided to Jeffre E rein for sex? 
MR. 
: Objection to the form, the 
13 
BY MR. KUVIN: 
13 
standing objection previously stated. I will 
14 
Q. Skip the next page if you would, and the 
14 
instruct the witness not to answer that 
15 
following page will be Page 19 of Exhibit 4. It 
15 
question. 
16 
should be two mess es. 
16 
THE WITNESS: On the instruction of my 
17 
MR. 
Show me what you're 
17 
lawyer, I must invoke my Fifth Amendment 
18 
looking at. 
18 
privilege. 
19 
MR. KUVIN: And the top left one says, 
19 
BY MR. KUVIN: 
20 
"Friday." 
20 
Q. Did Jeffrey Epstein not like girls that 
21 
MR. 
: Thank you. 
21 
had tattoos? 
22 
BY MR. KUVIN: 
22 
MR. 
: Objection to the form 
23 
Q. The message on the left-hand side that 
23 
based on the standing objection and the same 
24 
appears to be. have a date of 4/8/05 and a number 7 
24 
instruction. 
25 
written on it. It says: 
11:00 a.m. 
25 
THE WITNESS: On the instruction of my 
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1 
lawyer, I must invoke my Fifth Amendment 
1 
MR. 
Same instruction. 
2 
privilege. 
2 
THE WITNESS: On the advice of my lawyer. 
3 
BY MR. KUVIN: 
3 
I must choose to invoke my Fifth Amendment 
4 
Q. Did Jeffrey Epstein not like girls that 
4 
right. 
5 
had blonde hair? 
5 
BY MR. KUVIN: 
6 
7 
MR. 
: Standing objection and the 
same instruction. 
6 
7 
Q. Doyou know who
is? 
MR. 
Same instruction.
8 
THE WITNESS: On the instruction of my 
8 
THE WITNESS: On the advice of my lawyer. 
9 
lawyer, I must invoke my Fifth Amendment 
9 
I wish to invoke my Fifth Amendment privilege. 
10 
privilege. 
10 
BY MR. KUVIN: 
11 
BY MR. KUVIN: 
11 
Q. Do ou know who 
is? 
M. 
12 
Q. Take a look at the next page, if you 
12 
MR. 
Let me consult for a 
13 
would. This one. 
13 
second. 
14 
MR. 
: Thank you. 
14 
MR. KUVIN: Yep. 
15 
BY MR. KUVIN: 
15 
(A discussion was held off the record.) 
16 
Q. Is that your handwriting? 
16 
MR. 
Mr. Kuvin, I'm just asking 
17 
A. On instruction of my lawyer, I must invoke m) 17 
you to clarify. Are you asking if she's ever 
18 
Fifth Amendment privilege. 
18 
heard the name of these people or whether she's 
19 
Q. Is this an additional -- on Page 21, is 
19 
actually ever met someone she knows to have 
20 
this an additional list of girls that were being 
20 
that name? 
21 
22 
provided to Jeffre E stein for sex? 
MR. 
: I'm sorry. Did we change 
21 
22 
MR. KUVIN: Second part, whether she knows 
someone personally by that name. I don't want 
23 
to a different page or the same page? 
23 
to know what somebody may have told her. 
24 
MR. KUVIN: The same page. 
24 
MR. 
Sure. 
25 
25 
MR. KUVIN: Certainly not attorneys or 
Page 142 
Page 144 
1 
BY MR. KUVIN: 
1 
anything like that. I want to know whether she 
2 
Q. Is this an additional list of girls that 
2 
has any 'ersonal knowledge of someone by the 
3 
were -- 
3 
name of 
4 
MR. 
: Thank you. 
4 
MR. 
: Okay. Based on our 
5 
BY MR. KUVIN: 
5 
conversation, she can answer or not answer the 
6 
Q. -- being provided to Jeffrey Epstein for 
6 
question. 
7 
sex? 
7 
THE WITNESS: On the advice of my lawyer, 
8 
MR. 
: Objection to the form. 
8 
I choose to invoke my Fifth Amendment right. 
9 
The same objection and the same instruction. 
9 
MR. KUVIN: Okay. It's like a 
10 
THE WITNESS: On the instruction of my 
10 
cough/sneeze. 
11 
lawyer, I must invoke my Fifth Amendment 
11 
MR. GARCIA: I tried to stifle it. but --
12 
privilege. 
12 
MR. GOLDBERGER: You got it all over me. 
13 
BY MR. KUVIN: 
13 
Just kidding. 
14 
Q.Sa
2. Note on flier
, 
appears to 
14 
MR. GARCIA: You don't want to get this. 
15 
say: 
has a friend, 
• that would like 
15 
I've had if for a couple of days. 
16 
to work tonight. Do you know who 
is refer, 16 
MR. KUVIN: What number are we on? 13. 
17 
referring to in that note? 
17 
That's why I always leave some with numbers 
18 
MR. 
: Instruct the witness not 
18 
still on there to show the picture to the 
19 
to answer based on the privilege against 
19 
camera. 
20 
self-incrimination. 
20 
Exhibit 13 will be pursuant to 
21 
THE WITNESS: On the advice of my lawyer, 21 
confidentiality and the identities of the 
22 
I wish to assert my Fifth Amendment right. 
22 
girls involved in this case. 
23 
BY MR. KUVIN: 
23 
MR. 
As I presume the prior 
24 
Q. Do you know who 
is referring to in 
24 
questions were as well. 
25 
that note? 
25 
MR. KUVIN: Yes. Absolutely. This is 
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1 
different because it's an exhibit. 
1 
in Exhibit 13 came to Mr. Epstein's home when she 
2 
MR. 
: Agreed. 
2 
was only 115 ears old? 
3 
MR. KUVIN: Okay. 
3 
MR. 
: Objection to the form 
4 
(Plaintiff's Exhibit No. 13 was marked for 
4 
based on the standing objection, also 
5 
identification 
5 
speculation as to any age and instruct the 
6 
MR. 
We're moving off of 
6 
witness not to answer. 
7 
Exhibit 12? 
7 
THE WITNESS: On the advice of my lawyer. 
8 
MR. KUVIN: Yes. 
8 
I must choose to exercise my Fifth Amendment 
9 
MR. 
I was looking at the next 
9 
right. 
10 
exhibit. 
10 
BY MR. KUVIN: 
11 
MR. KUVIN: We're done with the trash. 
11 
Q. Do you agree with me that when you 
12 
MR. 
: Okay. 
12 
arranged to have this girl come to Mr. Epstein's 
13 
BY MR. KUVIN: 
13 
home, that ou were aware that she was IS years old? 
14 
Q. Just take a look at Exhibit 13. Do you 
14 
MR. 
: Objection to the form. It 
15 
recognize the girl in that photograph? 
15 
is compound. It assumes facts that are not 
16 
A. On the advice of my lawyer, I must choose to 16 
admitted by this witness, and it's ambiguous in 
17 
exercise my Fifth Amendment privilege. 
17 
that regard, and therefore I instruct her not 
18 
Q. Do you agree with me that that girl shown 
18 
to answer. 
19 
in that photo 
his 
? 
19 
THE WITNESS: On the advice of my lawyer, 
20 
MR. 
: Objection to the form for 20 
I must choose to exercise my Fifth Amendment 
21 
the reasons previously stated, causes her to 
21 
right. 
22 
speculate, and I instruct her not to answer 
22 
BY MR. KUVIN: 
23 
based on her Fifth Amendment privilege. 
23 
Q. Do you agree that when this girl was 
24 
THE WITNESS: On the advice of my lawyer, 24 
brought to Mr. Epstein's home, that she performed a 
25 
I must choose to exercise my Fifth Amendment 
25 
massage on Mr. Epstein while he was naked? 
Page 146 
Page 148 
i 
privilege. 
1 
MR. 
Objection to the form, 
2 
BY MR. KUVIN: 
2 
standing objection. The question assumes that 
3 
Q. Do you agree with me that you arranged to 
3 
this witness has any knowledge of 
4 
have the girl shown in Exhibit 13 be brought to 
4 
Jeffrey Epstein or whether this person ever 
5 
Mr. Epstein's home for sex with Mr. Epstein? 
5 
came to Mr. Epstein's home. It is therefore 
6 
MR. 
: Objection to the form as 
6 
ambiguous, and I instruct her not to answer. 
t 
compound. and also the standing objection, and 
7 
THE WITNESS: On the instruction of my 
8 
instruct the witness not to answer. 
8 
lawyer, I must choose to exercise my Fifth 
9 
THE WITNESS: On the advice of my lawyer, 
9 
Amendment right. 
10 
I must choose to exercise my Fifth Amendment 
10 
BY MR. KUVIN: 
11 
privilege. 
11 
Q. Do you agree with me that this girl shown 
12 
BY MR. KUVIN: 
12 
in Exhibit 13 was 15 years old at the time she was 
13 
Q. Would you agree with me that the girl 
13 
asked by Jeffrey E stein to remove her clothes?
14 
shown in Exhibit 13 did, in fact, come to 
14 
MR. 
Objection to the form. It 
15 
Mr. Epstein's home in 2005? 
15 
requires speculation and assumes facts relating 
16 
MR. 
: Same objection previously 16 
to Mr. Epstein and events that may have 
17 
stated. It's compound as to the date, place, 
17 
occurred which this witness has no knowledge 
18 
person, and also presumes knowledge of 
18 
and has not admitted any knowledge. And I 
19 
Mr. Epstein, so I would instruct her not to 
19 
instruct her not to answer. 
20 
answer. 
20 
THE WITNESS: On advice of counsel I must 
21 
THE WITNESS: On the advice of my lawyer, 
21 
choose to exercise my Fifth Amendment right. 
22 
I must choose to exercise my Fifth Amendment 
22 
BY MR. KUVIN: 
23 
privilege. 
23 
Q. Do you agree that you described for the 
24 
BY MR. KUVIN: 
24 
girl as shown in Exhibit 13 -- bate way. her name 
25 
Q. Do you agree with me that the pin shown 
25 
is.. 
-
-
t
h
a
t
 
you described to M. how to set up 
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the massage table in Jeffrey Epstein's bathroom? 
1 
counsel, I must choose to invoke my Fifth 
2 
MR. 
: Objection to the form for 
2 
Amendment right. 
3 
the reasons previously stated, and instruct the 
3 
BY MR. KUVIN: 
4 
witness not to answer. 
4 
Q. Do yotagree with me that during the 
5 
THE WITNESS: On the advice of counsel, I 
5 
massage that M. was forced to give to Mr. Epstein. 
6 
must choose to exercise my Fifth Amendment 
6 
that he touched her between her legs? 
7 
right. 
7 
MR. 
: Objection to the form. It 
8 
BY MR. KUVIN: 
8 
is ambiguous including the term "forced." It 
9 
Q. Do you agree that you showed M. where 
9 
assumes facts that this witness has not 
10 
the massage oils are kept in Jeffrey Epstein's 
10 
admitted or that this witness has not 
11 
bathroom in his home? 
11 
acknowledged any personal knowledge and 
12 
MR. 
: Objection to the form in 
12 
instruct her not to answer. 
13 
that it assumes knowledge of Jeffrey Epstein, 
13 
THE WITNESS: On the instruction of my 
14 
knowledge that this person was ever at 
14 
lawyer, I must therefore invoke my Fifth 
15 
Jeffrey Epstein's home none of which is 
15 
Amendment right. 
16 
admitted or acknowledged by this witness, and 
16 
BY MR. KUVIN: 
17 
instruct the witness not to answer. 
17 
Q. Do ou agree with me that Mr. Epstein 
18 
THE WITNESS: On advice of counsel I must 18 
touched 
between her legs? 
19 
choose to invoke my Fifth Amendment right. 
19 
MR. 
: Objection to the form and 
20 
BY MR. KUVIN: 
20 
the question presumes knowledge of 
21 
Q. Do you agree that you showed.., as 
21 
Jeffrey Epstein. Instruct the witness not to 
22 
shown in Exhibit 13. where Mr. Epstein kept the 
22 
answer. 
23 
vibrators in his bathroom at his house? 
23 
THE WITNESS: On the instruction of my 
24 
MR. 
: Same objection as stated 
24 
lawyer, I must choose to invoke my Fifth 
25 
to the previous question as to the form of the 
25 
Amendment right. 
Page 150 
Page 152 
1 
question, and instruct the witness not to 
1 
BY MR. KUVIN: 
2 
answer. 
2 
Q. Do you agree with me that El. told 
3 
THE WITNESS: On advice of counsel, I must 
3 
Mr. Epstein to stop touching him there -- touching 
4 
choose to exercise my Fifth Amendment right. 
4 
her there? 
5 
BY MR. KUVIN: 
5 
MR. 
Same objection previously 
6 
Q. Do you agree with me that in 2005 you 
6 
stated to the last question and instruct the 
7 
knowingly provided ■., a 15-year-old girl, to 
7 
witness not to answer. 
8 
Mr. Epstein so that he could sexually abuse her? 
8 
THE WITNESS: On the instruction of my 
9 
MR. 
Objection to the form as 
9 
lawyer, I must invoke my Fifth Amendment right. 
10 
to it calling for a legal conclusion as to 
10 
BY MR. KUVIN: 
11 
assuming multiple facts, since therefore 
11 
Q. Do you agree with me that you have 
12 
compound and instruct the witness not to 
12 
personal knowledge that after telling Mr. Epstein to 
13 
answer. 
13 
stop touching her between her legs, Mr. Epstein 
14 
THE WITNESS: On advice of counsel, I must 14 
apologized and then touched her again between her 
15 
choose to invoke my Fifth Amendment right. 
15 
legs? 
16 
BY MR. KUVIN: 
16 
MR. 
Objection to the form and 
17 
Q. Do you agree with me that M. was given 
17 
the standing objection previously stated as 
18 
to Mr. Epstein to 
alarm a naked massage of him 
18 
well as the question is compound and instruct, 
19 
while he touched 
? 
19 
and ambiguous. and I instruct the witness not 
20 
MR. 
Objection to the form. 
20 
to answer. 
21 
Standing objection and other facts that are 
21 
THE WITNESS: On the instruction of my 
22 
assumed in the question to which this witness 
22 
lawyer, I must choose to exercise my Fifth 
23 
does not admit, and therefore the witness is 
23 
Amendment right. 
24 
instructed not to answer the question. 
24 
BY MR. KUVIN: 
25 
THE WITNESS: On the instruction of my 
25 
Q. Do you agree with me that Mr. Epstein 
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Page 153 
Page 155 
1 
specifically targeted young underage girls that were 
1 
Mr. Epstein naked massa es? 
2 
economically disadvantaged for his own sexual 
2 
MR. 
Object to the form. It's 
3 
pleasure? 
3 
multiple layers of compound questioning, 
4 
MR. 
Objection to the form. 
4 
includes terms like "enterprise" that are 
5 
Several of the terms are ambiguous and it 
5 
ambiguous and may call for a legal conclusion 
6 
assumes knowledge of Mr. Epstein and his 
6 
that this witness is not competent to give. I 
7 
habits, and therefore, I instruct the witness 
7 
instruct the witness not to answer. 
8 
not to answer the question. 
8 
THE WITNESS: On the instruction of my 
9 
THE WITNESS: On the instruction of my 
9 
lawyer, I must choose to exercise my Fifth 
10 
lawyer, I must choose to exercise my Fifth 
10 
Amendment right. 
11 
Amendment right. 
11 
BY MR. KUVIN: 
12 
BY MR. KUVIN: 
12 
Q. Do you agree with me that there is a 
13 
Q. Do you agree with me that Mr. Epstein 
13 
staircase leading out of Mr. Epstein's kitchen in 
14 
would pay these girls 2 to $300 for this sexual 
14 
his home on Palm Beach? 
15 
massage? 
15 
MR. 
Objection to the form, 
16 
MR. 
Objection to the form. 
16 
presumes knowledge of Mr. Epstein or his home 
17 
Standing objection and assumes knowledge of 
17 
on Palm Beach. Instruct the witness not to 
18 
Mr. Epstein and his practices, so therefore, I 
18 
answer. 
19 
instruct the witness not to answer. 
19 
THE WITNESS: On the instruction of my 
20 
THE WITNESS: On the instruction of my 
20 
lawyer, I must choose to invoke my Fifth 
21 
lawyer, I must choose to invoke my Fifth 
21 
Amendment right. 
22 
Amendment right. 
22 
BY MR. KUVIN: 
23 
BY MR. KUVIN: 
23 
Q. Do you agree with me that when M. was 
24 
Q. Do you agree with me that you handed M. 
24 
brought to Mr. Epstein's bathroom, that he walked 
25 
$200? 
25 
out of the shower wearing a towel? 
Page 154 
Page 156 
1 
MR. 
: Objection to the form, 
1 
MR. 
Objection to the form in 
2 
instruct the witness not to answer. 
2 
that it presumes knowledge of ... 
that Ms. 
3 
THE WITNESS: On the instruction of my 
3 
.. was ever at Mr. Epstein's home, that this 
4 
lawyer, I must choose to invoke my Fifth 
4 
witness knows anything about Mr. Epstein or his 
5 
Amendment right. 
5 
home; therefore, the question is compound and 
6 
BY MR. KUVIN: 
6 
ambiguous, and I instruct her not to answer. 
7 
Q. And just so we're clear, do you agree with 
7 
THE WITNESS: On the instruction of my 
8 
me that you handed ill. in 2005, $200 after she was 
8 
lawyer, I must choose to assert my Fifth 
9 
in the bathroom with Mr. Epstein at his home? 
9 
Amendment right. 
10 
MR. 
: Objection to the form. 
10 
BY MR. KUVIN: 
11 
The question_wsumes knowledge of a person by 11 
Q. Do you know M.? 
12 
the name of M., therefore I instruct the 
12 
A. On the instruction of my lawyer, I must choose 
13 
witness not to answer the question. 
13 
to assert my Fifth Amendment privilege. 
14 
THE WITNESS: On the instruction of my 
14 
Q. Did you have 
. -- excuse me, strike 
15 
lawyer, I must choose to invoke my Fifth 
15 
that. Did you tell 
to come over to 
16 
Amendment right. 
16 
Mr. Epstein's home to ive Mr. Epstein a massage? 
17 
BY MR. KUVIN: 
17 
MR. 
Objection to the form. 
18 
Q. Do you agree with me that Mr. Epstein had 
18 
It's compound. Stand objection. standing 
19 
a plan -- let me rephrase that. 
19 
objection, sorry. Instruct the witness not to 
20 
Do you agree with me that Mr. Epstein 
20 
answer. 
21 
had an enterprise, a sexual enterprise, established 
21 
THE WITNESS: On the instruction of my 
22 
by which young girls would be brought to his home, 
22 
lawyer, I must choose to invoke my Fifth 
23 
introduced to you, where you would then set up a 
23 
Amendment right. 
24 
massage table. show them where the oils were, and 
24 
BY MR. KUVIN: 
25 
have these young, girls under the age of 18, give 
25 
Q. Did you introduce M. to Jeffrey Epstein? 
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1 
Page 157 
MR. 
Objection to the form, 
1 
Page 159 
BY MR. KUVIN: 
2 
standing objection. Instruct the witness not 
2 
Q. Would you agree with see that you visited 
3 
to answer. 
3 
a man by the name of Jeffrey Epstein while he was in 
4 
THE WITNESS: On the instruction from my 
4 
jail in Palm Beach Count ? 
5 
lawyer, I must choose to invoke my Fifth 
5 
MR. 
: Objection to the form, 
6 
Amendment right. 
6 
standing objection. Assumes other facts that 
7 
BY MR. KUVIN: 
7 
this witness has not acknowledged, and instruct 
8 
Q. Do ou agree with me that Mr. Epstein 
8 
her not to answer. 
9 
threatened 
with h sical violence? 
9 
THE WITNESS: Upon instruction from the 
10 
MR. 
Objection to the form, the 10 
lawyer, I must choose to invoke my Fifth 
11 
standing objection, as well as ambiguous as to 
11 
Amendment right. 
12 
the term "threaten." Instruct the witness not 
12 
BY MR. KUVIN: 
13 
to answer. 
13 
Q. Do you agree that you arranged to have 
14 
THE WITNESS: Upon instruction from my 
14 
come to Jeffrey Epstein's home for a nude 
15 
lawyer, I must choose to invoke my Fifth 
15 
massage? 
16 
Amendment right. 
16 
MR. 
Objection to the form. 
17 
BY MR. KUVIN: 
17 
standing objection previously stated. 
18 
OI
Do you agree with me that Jeffrey Epstein 
18 
THE WITNESS: On the instruction of my 
19 
told M. that if she talks to anyone about what had 
19 
lawyer, I must choose to invoke my Fifth 
20 
occurred at his home, bad things would happen to 
20 
Amendment right. 
21 
her? 
21 
BY MR. KUVIN: 
22 
MR. 
Objection to the form, 
22 
Q. Do you agree that 
has been to 
23 
24 
it's compound, and a standing objection. Also 
assumes numerous other facts that this witness 
23 
24 
358 El Brillo Wa on at least two occasions? 
MR. 
: Objection to the form. It 
25 
has not acknowledge nor admitted, and therefore 
25 
assumes knowledge of . and of 358 El Brillo 
Page 158 
Page 160 
I instruct her not to answer. 
1 
Way, to which the witness has not acknowledged. 
2 
THE WITNESS: On the instruction from my 
2 
and instruct the witness not to answer. 
3 
lawyer, I must choose to invoke my Fifth 
3 
THE WITNESS: On the instruction of my 
4 
Amendment privilege. 
4 
lawyer. I must choose to invoke my Fifth 
5 
BY MR. KUVIN: 
5 
Amendment right. 
6 
Q. Would you agree with me that in 2005 that 
6 
BY MR. KUVIN: 
7 
Jeffrey Epstein was between the ages of 45 and 55 
7 
Q. Do you agree that Mr. Epstein has an 
8 
years old? 
8 
odd-shaped ems?
MR. 
: Objection to the form. 
9 
MR. 
Objection to the form of 
10 
Standing objection as to any knowledge of 
10 
the question. It assumes knowledge of 
11 
Jeffrey Epstein. Instruct the witness not to 
11 
Mr. Epstein. It assumes knowledge of 
12 
answer. 
12 
Mr. Epstein's body parts, and instruct the 
13 
THE WITNESS: The instruction of my 
13 
witness not to answer. 
14 
lawyer, I must choose to assert my Fifth 
14 
THE WITNESS: On advice -- on the 
15 
Amendment right. 
15 
instruction of my lawyer. I must choose to 
16 
BY MR. KUVIN: 
16 
invoke my Fifth Amendment right. 
17 
Q. Would you agree with me that 
17 
BY MR. KUVIN: 
18 
Jeffrey Epstein has tremendous wealth? 
18 
Q. Have ou seen Jeffrey Epstein's penis?
19 
MR. 
: Objection to the form as 19 
MR. 
Objection to the form. and 
20 
stated in the previous question, and instruct 
20 
we're getting awfully close to a line here. Mr. 
21 
the witness not to answer. 
21 
Kuvin. 
22 
THE WITNESS: On the instruction from the 
22 
MR. KUVIN: I think the identity of 
23 
lawyer, I must choose to invoke my Fifth 
23 
something that 
14 and I5-year-old girls 
24 
Amendment right. 
24 
have seen is directly relevant to the issues in 
25 
25 
this case. If the/ can describe it. then 
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