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A Fifth. 
1 
80 
with the defendant was consensual? 
2 
Q Have you ever engaged in a sexual tel 
2 
MR. YAREMA: Object to the form. 
with 
3 
A Fifth. 
4 
MR. YAltEMA: Object to the form. 
4 
Q Do you know if M.'s sexual activity 
5 
A Fifth. 
5 
with the defendant was consensual? 
6 
Q Did you ever observe the defendant, 
6 
MR. YAREMA: Object to the form. 
7 
Jeffrey Epstein, with.? 
7 
A Fifth. 
MR. YAREMA: Object to the form. 
8 
Q When you participated hi sexual acts 
9 
A Fifth. 
9 
with each minor, how did you feel? 
10 
Q Did you ever observe the defendant, 
0 
MR. YAREMA: Object to the form. 
11 
Jeffrey Epstein, with 
1 
A Fifth. 
12 
MR. YAREMA: Object to the form? 
2 
Q In your heart, did you know it was 
13 
A Fifth. 
3 
wrong? 
19 
Q Have you ever physically touched a? 
4 
MR. YAREMA: Object to the form, and in 
15 
MR. YAREMA: Object to the form. 
5 
addition this is irrelevant and has already 
16 
A Fifth. 
6 
been addressed by Judge Hafele as an 
17 
Q Have you ever physically touched a? 
7 
inappropriate question. That's my 
18 
MR. YAREMA: Object to the form. 
8 
objection. 
19 
A Fifth. 
9 
A Fifth. 
20 
Q Has the defendant ever made a statement 
0 
Q During this time period did you feel 
21 
to you about 
1 
confused? 
22 
MR. YAREMA: Object to the form. 
2 
MR. YAREMA: Object to the form. 
23 
A Fifth. 
3 
MR. GOLDBERGER: Same — 
24 
Q Has the defendant ever made a statement 
4 
MR. YAREMA: Same objection. 
25 
to you about 
5 
A Fifth. 
79 
81 
MR. YAREMA: Object to the form. 
1 
Q Are you currently In love with the 
2 
A Fifth. 
2 
defendant? 
3 
Q Has 
ever made a statement 
3 
MR. YAREMA: Object to the fonn, same 
4 
to you about 
4 
objection. That question has no relevance 
5 
MR. YAREMA: Object to the form. 
5 
to this... it is inappropriate per Judge 
6 
A Fifth. 
6 
Hafete's order. 
7 
Q Has 
ever made a statement 
7 
MR. GOLDBERGER: Also involves privacy 
8 
to you about N.? 
B 
rights of my client. I 111S1R143 her not to 
MR. YAREMA: Object to the form. 
9 
answer the question. 
10 
A Fifth. 
10 
A Fifth. 
11 
Q Have you ever communicated with 
11 
Q Have you ever been in love with Jeffrey 
12 
MR. YAREMA: Object to the form. 
12 
Epstein? 
13 
A Fifth. 
13 
MR. GOLDBERGER: Same objection. 
4 
Q Have you ever communicated with 
14 
MR. YAREMA: Same objections. 
15 
MR. YAREMA: Object to the form. 
15 
A Fifth. 
16 
A Fifth. 
16 
MR. LANOINO: Thank you. 
17 
Q Did you know that U,U 
was a minor 17 
CROSS EXAMINATION 
18 
at the time of sexual abuse? 
18 
BY 
F.ZELL: 
19 
MR. YAREMA: Object to the form. 
19 
(Discussion off thc record.) 
20 
A Fifth. 
20 
Q Good morning, 
I'm 
21 
Q Did you know ....... 
was a minor at 
21 
Katherine Ezell and I represent Jane Doe 103, 
22 
the time of the sexual abuse? 
22 
whose name Is 
., which shall appear as.. in 
23 
MR. YAREMA: Object to the form. 
.3 
the deposition. 
24 
A Fifth. 
24 
Are you aware that in 2004 and 5, there 
25 
Q Do you know ir 
sexual activity 
75 
was a sort of hidden staircase that would take 
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one from the kitchen upstairs to the master 
1 
134 
Q Do you recall that Jeffrey Epstein would 
2 
bedroom and massage area? 
2 
Join in by performing oral sex on one or the 
3 
MR. YAREMA: Object to the form. 
3 
other of you — you or ..? 
4 
A Fifth. 
4 
MR. YAREMA: Object to the form. 
5 
Q Do you recall there being nude 
5 
A Fifth. 
6 
photographs on the staircase? 
6 
Q Do you recall that also happening, 
7 
MR. YAREMA: Object to the form. 
7 
meaning the oral sex, being performed on the 
8 
A Fifth. 
8 
massage table — 
9 
Q Did you know 
9 
MR. YAREMA: Objection. 
10 
A Fifth. 
10 
Q 
to 
11 
Q Did 
come to the house at 358 El 
1 
MR. YAREMA: Object to the form. 
12 
Brill° Way to provide a massage to Jeffrey 
12 
A Fifth. 
13 
Epstein? 
13 
Q Were you present one day when Jeffrey 
14 
MR. YAREMA: Object to the form. 
14 
Epstein held.. down on the massage table and 
15 
A Fifth. 
15 
while holding her inserted his penis Into M's 
16 
Q Did that massage become sexual in 
16 
vagina? 
17 
nature? 
17 
MR. YAREMA: Object to the form. 
18 
MR. YAREMA: Object to the form. 
18 
A Fifth. 
19 
A Fifth. 
19 
Q Do you recall he stated that he wanted 
20 
Q Did • 
become a regular visitor at 
20 
you to observe this? 
21 
Jeffrey Epstein's house? 
21 
MR. YAREMA: Object to the form. 
22 
MR. YAREMA: Object to the form. 
22 
A Filth. 
23 
A Fifth. 
23 
Q Do you recall that.. had rules, 
24 
Q Do you remember that she came maybe 
24 
lines, that she had stated Jeffrey Epstein was 
25 
hundreds of times? 
25 
not to cross, in their encounters? 
83 
MR. YAREMA: Object to the fonn. 
1 
MR. YAREMA: Object to the form. 
2 
A Fifth. 
2 
A Fifth. 
3 
Q Do you recall that she was under the age 
3 
Q Do you recall that.. had forbidden 
4 
of 18 at the time she was coming to Jeffrey 
4 
any kind of vaginal penetration? 
5 
Epstein's home? 
5 
MR. YAREMA: Object to the form 
6 
MR. YAREMA: Object to the fonn. 
6 
A Fifth. 
7 
A Fifth. 
7 
Q Do you recall that.. refused to touch 
8 
Q Were you younger than.. at the time? 
8 
Jeffrey Epstein's penis? 
9 
MR. YAREMA: Object to the form. 
9 
MR. YAREMA: Object to the fonn. 
10 
A Fifth. 
10 
A Fifth. 
11 
Q Do you remember occasions when you and 11 
Q Do you recall that day when Jeffrey 
12 
Jeffrey Epstein were already in bed when 
12 
Epstein held.. on her stomach on the massage 
13 
arrived? 
13 
table and began pumping his penis into her 
14 
MR. YAREMA: Object to the fonn. 
14 
vagina, that she screamed "No"? 
15 
A Fifth. 
15 
MR. YAREMA: Object to the fonn. 
16 
Q Do you recall Jeffrey Epstein 
16 
A Fifth. 
17 
instructing. to remove her clothes and Join 
17 
Q Do you recall that upon her screaming, 
18 
the two of you in bed? 
18 
Epstein stopped and apologized? 
19 
MR. YAREMA: Objoci to the fomi. 
19 
MR. YAREMA: Object to the fonn. 
20 
A Fifth. 
20 
A Fifth. 
21 
Q Do you recall that you and Jeffrey 
,21 
Q Do you recall that Jeffrey Epstein paid 
22 
Epstein bringing sex toys In bed for you and 
22 
her $1,000 for that visit? 
23 
to use on each other? 
23 
MR. YAREMA: Object to the form. 
24 
MR. YAREMA: Object to the fonn. 
24 
A Fifth. 
25 
A Fifth. 
25 
Q Did you engage In sex with 
when she 
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was under 18? 
MR. YAREMA: Object to the form. 
1 
2 
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end of a play performance during her senior year? 
MR. YAREMA: Object to the Conn. 
3 
A Fifth. 
3 
A Fifth. 
4 
Q Did Jeffrey Epstein watch you and M. 
4 
THE VIDEOGRAPHER: Counsel, can we stop 
5 
having sex while he masturbated? 
5 
for one minute? 
6 
MR. YAREMA: Object to the form. 
6 
MS. EZELL: Sure. 
7 
A Fifth. 
7 
THE VIDEOGRAPHER: Off the video record 
8 
Q Are you aware that M's activities 
8 
11:43 a.m. 
9 
with Jeffrey Epstein escalated further and 
(Short pause.) 
10 
further as time went on? 
10 
(Whereupon at this point in time, Mr. 
11 
Mit. YAREMA: Object to the form. 
11 
Langino left the proceedings.) 
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A Filth. 
12 
THE VIDEOGRAPHER: Back on the video 
13 
Q Did you see Jeffrey Epstein use 
13 
record 1:43 a.m. 
14 
vibrators and strap-on — use vibrators on M.? 
14 
CROSS EXAMINATION (CONTINUED) 
15 
MR. YAREMA: Object to the form. 
15 
BY MS. EZELL: 
16 
A Fifth. 
16 
Q Were you present in October 2005 when 
17 
Q Dld you and 
M
.
 
engage in sex with 
17 
the Palm Beach Police Department raided Jeffrey 
18 
strap-on penises? 
18 
Epstein's home? 
19 
MR. YAREMA: Object to the form. 
19 
MR. YAREMA: Object to the form 
20 
A Fifth. 
20 
A Fifth. 
21 
Q Did you see Jeffrey Epstein perform oral 
21 
Q You and others were aware that there 
22 
sex on M. numerous times? 
22 
would be a raid at that time; were you not? 
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MR. YAREMA: Object to the form. 
23 
MR. YAREMA: Object to the loon 
24 
A Fiflh. 
24 
A Fifth. 
25 
Q Did Jeffrey Epstein pay M. an 
25 
Q Who informed you that there would be a 
87 
89 
1 
additional 5200 to perform oral sex on you? 
1 
raid on the house? 
2 
MR. YAREMA: Object to the form. 
2 
MR. YAREMA: Object to the fonn. 
3 
A Fink 
3 
A Fifth. 
4 
Q Do you recall that each time a new toy 
4 
Q Did you participate in the removal of 
5 
or activity was Introduced when S 
was there to 
5 
nude photographs, sex toys, computer records from 
6 
give massages, Jeffrey Epstein paid 
6 
358 El Brillo Way prior to the raid? 
7 
additional money? 
7 
MR. YAREMA: Object to the roma 
MR. YAREMA: Objea to the coml. 
8 
A Fifth. 
9 
A Fifth. 
9 
Q Do you know who rentoved those objects at 
10 
Q Would Jeffr 
psteln masturbate while 
10 
that time? 
11 
watching you and 
perform sexual acts? 
11 
MR. YAREMA: Object to the form. 
12 
MR. YAREMA: Object to the form. 
12 
A Fifth. 
13 
A Fifth. 
13 
Q Do you remember that at times Jeffrey 
14 
Q Do you recall that Jeffrey Epstein 
14 
Epstein paid 
M
.
 
t
o
 
just sleep in his bed in the 
15 
provided M. with gifts of purses and 
15 
nude? 
16 
bathingsults? 
16 
MR. YAREMA: Object to the form. 
17 
MR. YAREMA: Object to the form. 
17 
A Fifth. 
18 
A Fifth. 
18 
Q Do you recall at times he paid her to 
19 
Q Do you recall that Jeffrey Epstein 
19 
just cuddle with him? 
20 
provided M. with a blue 2000 Dodge Neon which 20 
MR. YAREMA: Object to the form. 
21 
had been rented for her? 
21 
A Fifth. 
22 
MR. YAREMA: Object to the fonn. 
22 
Q Did you ever driveM. to Or from 358 
23 
A Fifth. 
23 
El Milo Way? 
24 
Q Do you recall that Jeffrey Epstein 
24 
MR. YAREMA: Object to the form. 
25 
ordered that roses be delivered ton at the 
25 
A Filth. 
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Q Did you ever know 
to drive 
A.H. to or from 358 El Brillo Way? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you remember the houseman at that 
time as being Alfredo Rodriguez? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you remember Alfredo Rodriguez being 
instructed to drive S 
to or from 358 El Brillo 
Way? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you recall a time when Alfredo 
Rodriguez discovered M. asleep upstairs naked? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Were you aware Jeffrey Epstein 
repeatedly asked M. to allow him to photograph 
her in the nude? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did you allow Jeffrey Epstein to take 
photographs, nude photographs of you? 
MR. YAREMA: Object to the form. 
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he would pay her 1,000 or 51,500 If she would 
lose ten pounds? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did you know M. to be a good student? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did it appear that you that M. was 
smart? 
MR. YAREMA: Object to the fort. 
A Fifth. 
Q Did you observe that M. was concerned 
about her grades? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Do you recall Jeffrey Epstein expressing 
interest in M.'s college ambitions? 
MR. YAREMA: Object to the form. 
A Filth. 
Q Have you known Jeffrey Epstein to brag 
about donations he's made to colleges like NYU, 
Columbia, Harvard and Wharton? 
MR. YAREMA: Object to the Porn. 
A Fifth. 
Q Do you know that 
M
.
 
wanted very much 
91 
1 
A Fifth. 
2 
Q Do you recall a time when M. gave in 
3 
and did allow Jeffrey Epstein to photograph her 
4 
while nude? 
5 
MR. YAREMA: Object to the form. 
6 
A Fifth. 
7 
Q Did you ever see any of those 
8 
photographs taken by Jeffrey Epstein of • in 
9 
the nude? 
10 
MR. YAREMA: Object to the torn. 
11 
A Fifth. 
12 
Q Do you know whether those photographs 
13 
were ever developed? 
14 
MR. YAREMA: Object to the form 
15 
A Fifth. 
16 
Q Do you know what kind of camera Jeffrey 
17 
Epstein liked to use when taking photographs of 
18 
women posing in the nude? 
19 
MR. YAREMA: Object to the form. 
20 
A Fifth. 
21 
Q Did you ever hear here Jeffrey Epstein 
22 
tell 
M
.
 
that she needed to lose ten pounds? 
23 
MR. YAREMA: Object to the form. 
24 
A Fifth. 
25 
Q Did you ever hear here him tell her that 
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L3 
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93 
to go to school in New York at NYU or at 
Columbia? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did you know that Jeffrey Epstein 
promised to help her get into one of those 
schools? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you know whether he did help? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you know whether he offered to pay 
some of her college expenses? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did you ever observe Jeffrey Epstein 
working with M. on her college applications? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did you ever see M. Just hanging out 
al Jeffrey Epstein's house studying while nude? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did you know that Jeffrey Epstein gave 
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1 
M. airline tickets and theater tickets in New 
2 
York? 
3 
MR. YAREMA: Object to the fonn. 
4 
A Fifth. 
5 
Q Did you and M. ever go shopping 
6 
together? 
7 
MR. YAREMA: Object to the tinm.
8 
A Fifth. 
9 
Q Did you call M. once and ask her to go 
shopping with you for Jeffrey Epstein on his 
birthday? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did you and 
M
.
 
purchase adult sex toys 
to use for Jeffrey Epstein's birthday, as a show, 
for him? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Are you aware that Jeffrey Epstein told 
he would pay her to bring other young girls 
to give him massages? 
MR. YAREMA: Object to the Porn. 
A Fifth. 
Q Do you know that Jeffrey Epstein paid 
M. 5200 for each girl that she brought to him, 
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5 
A The Fifth. 
Q Do you know if typically girls who 
Epstein knew, were given tickets to go to the 
show, then Invited back stage? 
MR. YAREMA: Object to the form. 
A Fifth. 
THE VIDEOGRAPHER: Can you speak up? 
THE WITNESS: (Adjusts microphone.) 
Q Did M. ever tell you that David 
Copperfteld tried to feel her butt during dinner? 
MR. YAREMA: Object to the font). 
A Fifth. 
Q Did you ever hear Jeffrey Epstein 
telling any of the young women who came to give 
him massages, that he was a brain scientist? 
MR. YAREMA: Object to the Comm. 
A Fifth. 
Q Did you know M.? 
A Fifth. 
Q And from now on I will use the initials 
M. Do you know that M. visited Jeffrey 
Epstein at 358 El Brlllo Way some 15 to 20 times? 
MR. YAREMA: Object to the form? 
A Filth. 
Q Did you ever Interact with M. while 
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to give him a massage? 
MR. YAREMA: Object to the form. 
A Fifth. 
MR. GOLDBERGER: I guess we will have to 
take a break now, if that's all right with 
you. 
MS. EZELL: Okay. 
THE VIDEOGRAPHER: 11:50 a.m., going off 
the video record. 
MR. GOLDBERGER: I will be done at 1:15 
so we can go until 1:30. 
(Pause in the proceedings.) 
THE VIDEOGRAPHER: We are bock on the 
video record at 1:36 p.m. 
CROSS EXAMINATION (CONTINUED) 
BY MS. EZELL: 
Q f 
did you ever have dinner 
at Jeffrey Epstein's house, with David 
Copperfield as a guest, when 
was present? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q Have you met David Copperfleid? 
A Fifth. 
Q (lave you ever been given tickets to go 
see one of his shows? 
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97 
she was there to give a massage? 
MR. YAREMA: Object to the form 
A Fifth. 
Q Dld you know that at the time she was 
visiting Mr. Epstein and providing massages, she 
was under the age of 18? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you recall being introduced to M. 
by Mr. Epstein? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you recall that Jeffrey Epstein 
Instructed you and M. to kiss and fondle each 
other around the breasts and buttocks while 
massaging him? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did you ever see Mr. Epstein use a large 
vibrator/massager on M.? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein ever ask you to 
purchase a digital camera for hint to give 
M
.
?
 
MR. YAREMA: Object to the form. 
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A Filth. 
2 
Q Did you know that Jeffrey Epstein gave 
3 
a digital camera? 
4 
MIL YAREMA: Object to the Iona. 
5 
A PM. 
6 
MS. EZELL: I don't have any other 
7 
questions. Thank you. 
8 
MR. GOLDBERGER: You still have your 
microphone on. You must have something on 
your mind, Brad. 
REDIRECT EXAMINATION 
BY MR. EDWARDS: 
Q 
through the whole day 
you've taken the Fifth on just about every single 
question. Is there any reason why we should not 
presume that the answer to these questions would 
Incriminate you? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q The reason that you have taken the Fifth 
is because the questions you have been asked 
would have been answered in the affirmative and 
you're afraid of prosecution for your 
Involvement, true? 
MR. GOLDBERGER: Don't answer that 
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THE STATE OF FLORIDA) 
COUNTY OF PALM BEACH) 
I, TERRI BECKER, a Registered 
Pmfessional Reporter and Notary Public for the 
State of Florida at Large, do hereby certify that 
I reported the videotaped deposition of 
the WITNESS, called by the PLAINTIFF 
in the above-entitled action: that the witness 
was duly swami by me; that the foregoing pages, 
numbered from 1 to 104, inclusive, constitute a 
true record of the deposition by said witness. 
I further certify that I am not attorney 
or counsel of any of the patties, nor a relative 
or employee of any attorney or counsel connected 
with the action, nor financially interested in 
the action. 
WITNESS MY IIAND and official seal in the 
City of West Palm Bradt, County of Palm Beach, 
State of Florida, this 19th day of April 2010. 
TERRI ECK ER, Registered 
Professional Reporter and 
Notary Public, State of Florida 
at Lame. My Commission expires 
March 13,2011. 
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99 
question. It interferes with the 
attorney/client relationship that I have 
with 
and any discussions she 
and I may have had would come under that 
privilege. 
You can try and dance around that, but 
I'm simply not going to allow her to answer 
that question. If you want to bring it up 
with the Judge, you can. 
MR. EDWARDS: Thanks, Jack. 
MR. GOLDBERGER: Okay. 
THE VIDEOGRAPHER: Off the video record 
at 1:41 p.m. 
THE COURT REPORTER: You're ordering 
this, Brad? 
MR. EDWARDS: Yes. Copies? 
MS. EZELL: Yes. 
MR. YAREMA: Yes: 
THE COURT REPORTER: And Adam wanted it; 
is that right? 
MR. EDWARDS: Yes. 
(Time noted: I:45 p.m.) 
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THE STATE OF FLORIDA) 
COUNTY OF PALM BEACH) 
The foregoing certificate was 
acknowledged before me this 
day of 
2010. 
101 
Notary Public, State of Florida. 
My commission No. 
Expires March 13, 2011. 
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do hereby 
certify that I have read the foregoing transcript 
of my deposition given on April I), 20)0; that 
together with the correction page attached hereto 
noting changes in form or substance, if any, it 
is true and correct. 
I do hereby certify that the deposition 
of 
was submitted to the witness 
for reading and signing; that alter she had 
stated to the undersigned Notary Public that she 
had read and examined her deposition, she signed 
the same in the presence of the undersigned 
authority on the 
day of 
2010. 
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U.S. 1 (GAL SL1PPOR 
Iterenered Pmfoontal RCPOdarN 
444 W40 luaaed A4cnut 
Sonic MP 
Wert Patin Read. Plaid M401 
(561)815.0220 
April 19. 2010 
• 
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a 
tISS 
ATTENTION: JACK GOLDBERGER. ESQ. 
In Re: 110E V. EPSTEIN 
DqatIlion of -
Ds Mr. Otaltraucc 
Sane cannel lone agreeddam ant may 
love the natant read and an your copy et the 
dcpaaarn. for yoga amremeae. OICIOWCI 
ilOC•0 
)0.1 nut Owl an Enna Shed Ice die 
umutot ant a aval tog tiNy than ga. M Orc 
dtwoniun 
Tbank you for your inompi tainaion. 
Conbally yours, 
11.6 LEGAL S(.112P(5111.
. 
....._._ . 
lERRI IILCKER. Rcaucred 
Profasional Reporter. Idogny 
21 
Public. Sole or numb a 
Lair. My c044/04000 cpwcs 
22 
Kw,* I). 2011 
2) 
CC UatlIty Edwards. Eal. 
Adam Ilona in. Log 
...1 
Kultnoc Lull, Ea. 
Onnd Vanua. Ca 
25 
1 
ERRATA SHEET 
2 
In Re: DOE V. EPSTEIN 
3 
DO NOT WRITE ON TRANSCRIPT 
ENTER CHANGES HERE: 
4 
5 
PAGE 
LINE 
CHANGE 
REASON 
6 
7 
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10 
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18 
THE STATE OF FLORIDA) 
19 
COUNTY OF PALM BEACH) 
20 
I DO HERESY CERTIFY THAT 
opwan:d below Inc and stated dial she has read 
21 
her deposition; further. that this Errata Shed 
was sigixst in my Rae= on Ibis 
day 
22 
of 
2010. 
23 
103 
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25 
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