EFTA01103374

336 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON 
JANE DOE, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, et al., 
Defendants. 
Related Cases: 
08-80119, 08-80232, 08-80380, 08-80381, 
08-80994, 08-80811, 08-80893, 09-80469, 
09-8-591, 09-80656, 09-80802, 09-81092 
VOLUME III 
CONTINUED VIDEOTAPED DEPOSITION OF 
JEFFREY EPSTEIN 
TAKEN ON BEHALF OF THE PLAINTIFF 
DATE: April 14, 2010 
U.S. Legal Support 
EFTA01103374

April 14,2010 
337 
1 
339 
APPEARANCES (CONTINUED) 
2 
INDEX 
2 
3 
WITNESS 
DIRECT CROSS REDIRECT RECROSS 
PODHURST, ORSECK 
Attorneys for Jane Does I and 3 
4 
JEFFREY EPSTEIN 
City National Bank Building, Suite 88 
5 
BY MR. HOROWrTZ 
340 
4 
25 West Flagier Street 
6 
7 
BY MR. EDWARDS 
418 
BY MS. EZELL 
531 
5 
Tel 
B : 
. 
ELL, ESQ. 
8 
6 
9 
7 
EXHIBITS 
BURMAN, CRrETON, LUTHER & COLEMAN, LLP 
10 
a 
Attorneys for Defendant Jeffrey Epstein 
303 Baryon Boulevard, 
PLAINTIFF'S 
9 
Suite 400 
11 
FOR IDENTIFICATION 
PAGE 
W 
33401 
12 
2 
Multi-page document. 
341 
10 
Tel.
BY: 
ESQ. 
13 
3 
Multi-page document. 
349 
11 
14 
4 
Multi-page document. 
359 
12 
15 
5 
Multi page document. 
369 
13 
16 
6 Multi-page document. 
378 
14 
AL-SO PRESENT: 
17 
7 
Multi-page document. 
384 
JOE ROVNER, Videographer 
18 
8 
Multi-page document. 
391 
15 
(US. Legal) 
19 
9 
Order form from Arnazon.com, 
16 
listing three books. 
507 
17 
18 
20 
19 
21 
20 
22 
21 
23 
22 
23 
24 
24 
25 
25 
338 
340 
Tie continued videotaped deposition of 
1 
THEREUPON, 
2 
JEFFREY EPSTEIN in the above-entitled and 
2 
JEFFREY EPSTEIN 
3 
numbered cause, was taken before one, TERRI 
4 
BECKER, a Registered Professional Reporter and 
3 
being by Terri Becker first duly sworn to tell 
5 
Notary Public for the State of Florida at Large, 
4 
the whole truth, as hereinafter certified, 
6 
at 444 West Railroad Avenue, in the City of West 
5 
testified as follows: 
7 
Palm Beach, Palm Beach County, in the State of 
a 
Florida, beginning at the hour of 10:22 o'clock 
6 
CONTINUED DIRECT EXAMINATION 
9 
a.m., pursuant to the Notice and Adjournment in 
7 
BY MR. HOROWITZ: 
10 
said cause for the taking of said deposition, on 
8 
Q Mr. Epstein, you understand we are 
11 
behalf of the PLAINTIFF in the above-entitled 
12 
action pending in the above-named court. 
continuing your deposition from Part One which 
13 
The appearances at said time and place 
10 
was taken on March 8, 2010? 
14 
were as follows: 
11 
A Yes. 
15 
FARMER, JAFFE, WEISSR4G, EDWARDS, 
FISTOS & LEHRMAN, PL 
12 
Q When we were together on March 8th, you 
16 
Attorneys for Plaintiffs Jane Does, 
13 
told us at that time that you were on probation 
LN. and E.W. 
14 
in the State of Florida. Is that still the 
17 
425 North Andrews Avenue 
Suite 2 
15 
case? 
18 
Fort 
33301 
16 
A Yes. 
Tel: 
ION 
17 
Q I believe you also told as part of the 
19 
BY: BRADLEY J. EDWARDS, ESQ. 
18 
term of your sentence was that you were not 
20 
MERMELSTEIN & HOROWITZ, P.A. 
19 
allowed unsupervised contact with anyone under 
21 
Attorneys for Plaintiffs Jane Does, 
20 
the age of 18. Is that still the case? 
numbers 2 through 8 
21 
A Yes. 
22 
18205 Biscayne Boulevard 
Suite 2218 
22 
Q At that time, you told us that you're 
23 
24 
25 
Mi 
Tel: 
BY: ADAM D. HOROWITZ, ESQ. 
23 
1224 
5 
restricted from possessing pornographic 
material. Is that still the case? 
A Yes. 
2 (Pages 33? to 34 0) 
U.S. Legal Support 
EFTA01103375

341 
343 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Q At that time you told us you were a 
registered sex offender in the State of Florida. 
Is that still the ease? 
A Yes. 
Q At that time you told us you lived at 
358 El Brills Way. Is that still the ease? 
A On advice of counsel, sir, I'm going to 
have to invoke my Sixth, Fifth and Fourteenth 
Amendment rights. 
Q I'm going to hand you a document which 
we will mark as Exhibit 2. We had marked Exhibit 
I at our first session. 
(Multi-page document was marked as 
Plaintiffs Exhibit number 2 for 
identification, as of this date.) 
Q (Handing.) 
I'm going to ask you to please turn to 
page 6. Turn to where it says "Affirmative 
Defenses." Do you see where we are? 
A Yes. 
Q Paragraph one, under the words 
"Affirmative Defenses" says "As to all counts, 
plaintiff actually consented to and was a willing 
participant in the acts alleged, and therefore 
her claims are barred or her damages are required 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
Fifth Amendment 
2 
Q Isn't It try neither you or anyone you 
3 
know has facts to support your contention that 
4 
=consented to and was a willing participant 
5 
in the acts alleged? 
6 
MR. PIKE: Form. 
7 
A As you know I would orally like to 
8 
answer that question, but at least today, I 
cannot I am going to have to invoke my rights 
on advice of counsel under the Fifth, Fourteenth 
and Sixth Amendment. 
Q Okay, moving down to paragraph two, it 
says, in Part, "as to all counts alleged 
plaintiff 
=
a
c
t
u
a
l
l
y
 
consented to and 
participated in conduct similar and/or identical 
to the acts alleged with other persons, which 
were the sole or contributing cause of 
plaintiff's alleged damages." 
My question for you is, what facts are 
you aware of to support your contention that= 
consented to and participated in conduct similar 
to and/or identical to the acts alleged in this 
lawsuit? 
MR. PIKE: Form. 
A Unfortunately I would like to answer 
342 
to be reduced accordin 
" This I'll tell you 
2 
was filed in the case o 
: do you understand 
3 
that? 
1 
A Yes. 
3 
Q Have you seen this document before? 
6 
A Not to my recollection, no. 
Q This statement that plaintiff 
actually consented to and was a willing 
9 
participant in the acts alleged; is that a true 
statement? 
A Sir, at least today I would like to 
answer each one of your questions, but I'm going 
to have to, on advice of counsel, invoke my 
rights of the Sixth, Fifth and Fourteenth 
Amendment. 
Q What facts do you have to support this 
contention here that plaintiff■ actually 
consented to and was a willing participant in the 
acts alleged? 
MR. PIKE: Form. 
A Though I would like to answer each and 
every one of your questions hat today, Mr. 
Horowitz, unfortunately today on the advice of 
counsel, I will have to refuse to answer and 
invoke my rights under the Sixth, Fourteenth and 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
344 
1 
each of your questions here today, Mr. Horowitz, 
2 
but on advice of counsel, at least today, I have 
3 
to assert my rights under the Fourth, Fifth and 
4 
Sixth Amendment. 
5 
Q Isn't It true, sir, that you that this 
6 
contention that
 consented to or participated 
In conduct similar to the acts alleged in this 
lawsuit with other persons? That's a false 
statement; isn't that true? 
MR. PIKE: Form. 
A Mr. Horowitz, I believe you already know 
the answer to most of these questions. I would 
like to give them, but however, at least today on 
advice of my counsel I have to assert my rights 
under the Sixth, Fourteenth and Fifth Amendment. 
Q Isn't it true, sir, you're not aware of 
who has facts anyone to support the statement 
that 
consented to and participated In 
similar or identical acts with other persons? 
MR. PIKE: Form. 
A Though I would like to answer that 
question, as I would like to answer all of your 
questions, at least today my counsel has advised 
me that I must assert my rights under the Sixth, 
Fifth and Fourteenth Amendments. 
3 (Pages 341 to 344) 
U.S. Le al Su ort 
EFTA01103376

345 
347 
Q Sir, please turn to paragraph three of 
defendant Epstein's first Amended Answer and 
3 
Affirmative Defenses. 
4 
A Same page? 
5 
Q Yes, paragraph three. 
A Okay. 
7 
Q Do you see it says "As to all counts 
8 
plaintiff impliedly consented to the acts alleged 
9 
by not objecting." 
1.0 
My question for you is, what facts do 
11 
you have to support your contention that 
12 
plaintiff= impliedly consented to the acts 
13 
alleged by not objecting? 
14 
MR. PIKE: Fenn. And all of these 
15 
questions call for a legal conclusion, as 
16 
well. 
17 
A Though I would like to answer that 
18 
question, as I would like to answer all of your 
19 
questions here today, on advice of my counsel. 
20 
I'm going to have to assert my rights today of 
21 
the Sixth, Fifth and Fourteenth Amendment. 
22 
Q Isn't it true, sir, that you're not 
23 
aware of any facts to support your contention 
24 
that the plaintiff= consented to the acts 
25 
alleged by not objecting; isn't that true, sir? 
1 
2 
3 
4 
5 
6 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
was not 18 years old at the time of the alleged 
acts? 
MR. PIKE: Form. 
A Though I would like to answer that 
question, as I would like to answer every 
one of your questions here today, on advice of 
counsel I'm going to have to assert my rights 
under the Sixth, Fifth and Fourteenth Amendment, 
sir. 
Q Mr. Epstein, what facts arc you aware of 
to support your contention thatM had attained 
the age of 18 years old at the time of the 
alleged acts? 
MR. PIKE: Same objection. 
A Though I would like to answer that 
question, Mr. Horowitz, I'm going to have to 
respond the same way I've responded to all of 
your questions here today; by asserting my rights 
on advice of counsel under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Isn't it true, sir, you had no reason to 
bane that 
was 18 or older at the time of 
the acts alleged? 
MR. PIKE. F0111). 
A Unfortunately, though I would like to 
346 
1 
MR. PIKE: Form? 
2 
A Can you repeat the question, I'm sorry? 
3 
Q Isn't it true you're not aware of any 
4 
facts to support this contention that 
5 
consented to the acts alleged by not objecting? 
6 
MR. PIKE: Form. 
7 
A At least today, Mr. Horowitz, I'm going 
8 
to have to assert my rights under the Sixth, 
9 
Fifth and Fourteenth Amendment not to answer that 
10 
question, though I would like to. 
11 
Q Isn't it true, sir, you're not aware of 
12 
anyone who has facts to support the contention 
13 
thaI 
consented to the acts alleged by not 
14 
objecting? 
15 
MR. PIKE: Form. 
16 
A Mr. Horowitz, I would like to answer 
17 
your question but at last today, under advice of 
18 
counsel, l have to assert my rights under the 
19 
Sixth, Fifth and Fourteenth Amendment. 
20 
Q Turning to paragraph four, immediately 
21 
following the paragraph... It says "Defendant 
22 
reasonably believed or was told that plaintiff 
23 
had attained the age of 18 years old at the time 
24 
of the alleged acts"? Isn't it true, sir, that's 
25 
not a true statement, is it? You knew that-
1 
2 
3 
4 
5 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
348 
answer that question, Mr. Horowitz, on advice of 
my counsel I'm going to have to assert my rights 
under the Sixth, Fifth and Fourteenth Amendment 
Q Turning to paragraph five of your 
Amended Answer toM's lawsuit, it says: "As 
to all counts, plaintiffs claims are barred, as 
she said she was 18 years or older at the time." 
Now, Mr. Epstein, that's not a true 
statement, is it? 
MR. PUCE: Form. 
A I would like to answer every one of your 
questions with respect to 
however, at least 
today, Mr. Horowitz, I'm going to have to assert 
my rights under the Sixth, Fifth and Fourteenth 
Amendment on advice of my counsel. 
Q Mr. Epstein, 5 
never told you she was 
18 years of age or older; isn't that true? 
MR. PIKE: Form. 
A Though I would like to answer every 
question regarding., at least today I have to 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment, sir, under advice of 
counsel. 
Q Mr. Epstein, you've had a chance now to 
review the Affirmative Defenses one through five, 
4 (Pages 345 to 348) 
U.S. Legal Support 
EFTA01103377

349 
351 
1 
which were filed on your behalf in this lawsuit. 
1 
paragraph one it says, "As to all counts, 
2 
Do you have any facts to support the contentions 
2 
plaintiff actually consented to and was a willing 
3 
in any of those Affirmative Defenses? 
3 
participant in the acts alleged." Do you see 
4 
MR. PIKE: Form. 
4 
that portion of paragraph one? 
5 
A At least today I'm going to have to 
5 
A Yes, sir. 
6 
respond by asserting my rights under the Sixth, 
6 
Q The statement here that the plaintiff, 
7 
Fifth and Fourteenth Amendment, on advice of 
7 
Jane Doe number 3 consented to and was a willing 
8 
counsel. 
8 
participant in the acts alleged: that's not a 
9 
Q I will take back Exhibit I -- pardon me, 
9 
true statement, is it? 
10 
Exhibit 2, and I'm going to hand you what we will 
10 
MR. PIKE: Form. 
11 
mark as Exhibit 3. 
11 
A Who is lane Doc 3? 
12 
(Multi-page document was marked as 
12 
Q You don't know who Jane Doe 3 is? 
13 
Plaintiff's Exhibit number 3 for 
13 
A I do not. Don't you? 
14 
identification, as of this date.) 
14 
Q I do, I'll pull up the list here. There 
15 
Q I'm going to hand you and your 
15 
are a number of cases, as you're aware. 
16 
attorney -- 
16 
Off the record for a second.) 
17 
MR. HOROWITZ: I have extras. 
17 
THE VIDEOGRAPHER: Off the video record 
18 
Q -. defendant Epstein's First Amended 
18 
at 10:35 a.m. 
19 
Answer and the Affirmative Defenses to 
19 
(Pause in the proceedings.) 
20 
plaintiff's Second Amended Complaint. Do you see 
0 
THE VIDEOGRAPHER: Back on the video 
21 
that in front of you? 
1 
record 10:40 a.m. 
22 
A Yes, sir. 
2 
Q Mr. EpsteinSis Jane Doe 3. You 
23 
Q Have you seen that before? 
3 
have in front of you the Amended Answer and 
24 
A No, sir. 
4 
Affirmative Defenses filed in response to Jane 
25 
Q I'm going to ask you to turn to page 6, 
5 
Doe 3's lawsuit? 
350 
352 
the page numbers are at the top, and do you see 
1 
A Yes, sir. 
2 
the words "Affirmative Defenses"? 
2 
Q We marked that as Exhibit 3. Turning to 
3 
A Yes. sir. 
3 
affirmative defense paragraph number one, do you 
4 
Q Paragraph one includes the following 
4 
see where it says "Plaintiff actually consented 
5 
statements -- 
5 
to and was a willing participant in the acts 
6 
MR. PIKE: Can we -- it appears that 
6 
alleged" in paragraph one; do you see that? 
7 
paragraphs one through five are the same. 
7 
MR. PIKE: Form. The document speaks 
8 
Would that be correct, as the ones you just 
8 
for itself. 
9 
previously read? 
9 
Q Do you see where I'm pointing you to? I 
10 
MR. HOROWITZ: Yes. 
10 
want to make sure we are on the same page. 
11 
MR. PIKE: Do you want to stipulate that 
1 
A Yes, I do. 
12 
the answers would be the same and the 
12 
Q The statement that Jane Doe number 3, 
13 
invocations of the Fifth, Sixth and 
3 
consented to and was a willing participant 
14 
Fourteenth would be the same, as well as my 
14 
in the acts alleged; is that a true statement? 
15 
form objections? 
5 
MR. PIKE: Form. 
16 
MR. HOROWITZ: Well, I need to ask the 
6 
A Mr. Horowitz, I would like to answer 
17 
questions as to each client. 
17 
every question about■ here today, however on 
18 
MR. PIKE: So, you do not want to 
18 
advice of counsel they've instructed me to Men 
19 
stipulate to that? 
19 
my rights under the Sixth, Fifth and Fourteenth 
20 
MR. HOROWITZ: I'll stipulate that you 
0 
Amendment. 
21 
have a standing objection, but I need to ask 
21 
Q Mr. Epstein, what facts d v u know of 
22 
the questions and get them on record. 
22 
to support the statements that 
dually 
23 
, 
MR. PIKE: All right, we will just go 
23 
consented to and was a willing participant in the 
24 
through it. Okay. 
24 
facts alleged? 
25 
Q As to Jane Doe 3, do you see In 
25 
MR. PIKE. Form. 
5 (Pages 349 to 352) 
U.S. Legal Support 
EFTA01103378

353 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
Q The acts alleged. 
2 
MR. PIKE: Form. 
3 
A I would like to answer every question 
4 
about. however, at least today on advice of 
5 
counsel, they've instructed me that I must assert 
6 
my rights under the Sixth, Fifth and Fourteenth 
7 
Amendment. 
8 
Q Isn't it true, sir, you are not aware of 
anyone who has facts to support the statement 
thm. consented to and was a willing 
participant in the acts alleged? 
MR. PIKE: Form. 
A I would like to answer every question 
about= however, today under advice of 
counsel, I cannot. They've instructed me to 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Turnip
 paragraph two, ft says: 
"Plaintiff 
actually consented to and 
participated to conduct similar and/or identical 
to acts alleged with other persons, which were 
the sole or contributing cause of plaintiff's 
alleged damages." Sir, that's not a true 
statement, is it? 
MR. PIKE: Form. 
354 
A I would like to answer every question 
2 
abou=uxillY. Mr. Horowitz, however, on 
3 
advice of counsel, they've instructed me I must 
4 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Mr. Epstein, what facts do you know of 
to support the statement that 
actually 
consented to and participated in conduct similar 
and/or identical to the acts alleged with other 
persons? 
MR. PIKE: Form, and once again this 
line of questioning calls fora legal 
conclusions, as well as work product 
information. 
A Though I would like to answer each and 
every question abouModay unfortunately my 
counsel has advised me I must assert my rights 
under the Sixth. Fifth and Fourteenth Amendment 
Q Isn't it true, sir, you're not aware of 
anyone who has facts to support the contention 
thatMconsented to and participated in 
conduct similar and/or identical to the acts 
alleged with other persons? 
MR. PIKE: Form. 
A Though I would like to answer every 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
question you have here today, Mr. Horowitz, 
2 
regarding your client,. on advise of my 
3 
counsel, at least today I must assert my rights 
4 
under the Sixth, Fifth and Fourteenth Amendment. 
5 
Q Turning to paragraph three of your 
6 
Affirmative Defenses, It says "Plaintiff., 
7 
impliedly consented to the acts alleged by not 
8 
objecting." Do you see that? 
9 
A Yes. 
Q The first part of that sentence? 
A Yes, sir. 
Q That's not a true statement, is it, 
sir? 
MR. PIKE: Form. 
A Though I would like to answer every 
question aboutM every single question, 
unfortunately today my counsel has advised me 
that I must assert my rights under the Sixth, 
Fifth and Fourteenth Amendment. 
Q Sir, what factsrSxon have to support 
your contention that= Impliedly consented to 
the acts alleged by not objecting? 
MR. PIKE: Form. 
A Though I would like to answer every 
question about .hat 
you pose here today, Mr. 
356 
1 
Horowitz, at least today, unfortunately my 
2 
counsel advised me that I must assert my rights 
3 
under the Sixth, Fifth and Fourteenth Amendment 
4 
Q Isn't It true, sir, you're not aware of 
5 
anyone who has facts to support your statement 
6 
thaMI lmpliedly consented to the acts alleged 
7 
by not objecting? 
8 
MR. PIKE: Form? 
9 
A Mr. Horowitz, I would like to answer 
10 
every question aboutM, I really would. 
11 
However, today my counsel has advised me that 1 
12 
must assert my Sixth, Fifth and Fourteenth 
13 
Amendment rights. 
14 
Q Turning to paragraph four of your 
15 
Affirmative Defenses, Mr. Epstein, it says "As to 
16 
all counts, defendant reasonably believed or was 
17 
told that the plaintiff had attained the age of 
18 
18 years old at the time of the alleged acts." 
19 
That's not a true statement, is it, sir? 
20 
MR. PIKE: Form. 
21 
A I would like to answer every question 
22 
about. that you've posed here today. 
23 
However, on advice of my counsel, I must assert 
24 
my rights under the Sixth, Fifth and Fourteenth 
25 
Amendment, at least today. 
6 (Pages 353 to 356) 
U.S. Legal Support 
EFTA01103379

357 
359 
9 
10 
11. 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Q Isn't it true, sir, isn't it true that 
you knew that•was under the age of 18 when 
she came to your home; isn't that true, sir? 
MR. PIKE: Form. 
A I would like to answer every question 
aboutIMI However, at least today my counsel 
has advised me I must assert my rights under the 
Sixth, Fifth and Fourteenth Amendment. 
Q Isn't it true, sir, that you had no 
reason to believe that■ was under lit? 
MR. PIKE: Form. 
A Can you repeat that question? 
Q Glad you asked. Isn't it true, sir, yon 
had no reason to believe that Ewes 18 years 
old or older? 
MR. PIKE: Form. 
A I would like to answer every question 
about In and her — the question you just 
asked, however at least today, my counsel has 
advised me that I must assert my rights under the 
Sixth. Fifth and Fourteenth Amendment. 
Q Isn't it true, sir, that ■ 
never told 
you that she was under the age of 18? 
A Form. 
MR. PIKE: Form. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
5 
containing markings in Exhibit number 3.) 
Q I'm going to band to you the answer and 
Affirmative Defenses, Amended Answer and 
Affirmative Defenses that you filed in the 
lawsuit filed by 
do you have that in front 
of you? Jane Doe number 4. 
A Yes, sir. 
Q I'll ask you to turn to page 6 where 
you'll see the words "Affirmative Defenses" near 
the top of the page? 
MR. PIKE: This is Exhibit 4? 
MR. HOROWITZ: Correct, Exhibit 4. 
(Multi-page document was marked as 
Plaintiffs Exhibit number 4 for 
identification, as of this date.) 
THE WITNESS: Can we take a two-second 
break?? 
MR. HOROWITZ: Sum. 
THE VIDEOGRAPHER: Off the video record 
at 10:48 a.m. 
(Pause in the proceedings.) 
MR. HOROWITZ: Back on the record. 
THE VIDEOGRAPHER: Back on the video 
record 10:49 a.m. 
Q Do you have the Affirmative Defenses in 
358 
1 
MR. HOROWITZ: Strike that. 
2 
. Q Isn't It true, sir.. 
never told you 
3 
she was 18 years or older? Isn't that true, 
4 
sir? 
5 
A I would like to answer every question 
6 
you have today regarding. and what she told 
7 
me. However, today my counsel has advised me I 
8 
must suet my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Okay, paragraph five says the 
plaintiffs claims are barred as she said she was 
18 years or older at the time. 
Sir, that's not a true statement, is 
It? 
MR. PIKE: Form. 
I would like to tell you exactly what 
said, however, my counsel has advised me to 
say that I must assert my rights under the Sixth, 
Fifth and Fourteenth Amendment. 
MR. PIKE: I wrote on your exhibit, page 
3, 
MR. HOROWITZ: We will substitute a 
different one. 
MR. PIKE: Yes, it is just checkmarks. 
(Clew copy was substituted for the page 
360 
I 
front of you, and the answer you filed In the 
2 
Meese, correct? 
3 
A That's correct. 
4 
Q Paragraph one includes the followin 
5 
statement: "As to all counts, plaintiff 
6 
actually consented to and was a willing 
7 
participant In the acts alleged." That's not a 
8 
true statement, is it, sir? 
9 
MR. PIKE: Form. 
0 
A I believe her deposition espeaks 
1 
to this issue. 
2 
Q Do you agree with es 
testimony that 
3 
she was at your home? 
4 
MR. PIKE: Form. 
5 
A Unfortunately today, Mr. Horowitz, 
[16 
though I would like to answer every question 
17 
about., I think her deposition speaks quite a 
I1.
8 
well with some of those issues, but at least, 
9 
with respect to my answering these questions 
0 
today with regard toMand these issues, my 
counsel has advised me I must assert my rights 
2 
under the Sixth, Fifth and Fourteenth 
23 
Amendments. 
4 
Q Are you telling us that. 
in your 
P5 
opinion, was truthful in her deposition? 
7 (Pages 357 to 360) 
U.S. Legal Support 
EFTA01103380

361 
363 
1 
MR. PIKE: Form, misconstrues the 
2 
witness's testimony. Move to strike. 
3 
A I believe, sir, that 
though I would 
4 
o answer that question with respect to Ms. 
5 
s deposition, my counsel has advised me at 
6 
least today I must assert my rights under the 
7 
Sixth, Fifth and Fourteenth Amendments. 
8 
Q Sir, what did you mean when you said 
9 
Ms 
testimony speaks to this issue"? 
10 
MR. PIKE: Asked and answered. 
11 
A I believe I said "deposition testimony' 
12 
Q Yes, what did you mean by that, when you 
13 
said "Her deposition testimony speaks to the 
14 
issue"? 
15 
MR. PIKE: Asked and answered, form. 
16 
A On advice of counsel, I have to assert 
17 
my rights under the Sixth, Fifth and Fourteenth 
18 
Amendment, sir. 
19 
Q What facts do you know of to support the 
20 
statement thaMactually consented to and was 
21 
a willing participant In the acts alleged? 
22 
MR. PIKE: Form. 
23 
A I believe her deposition spoke to that 
24 
directly, but however, myself, Pm going to have 
25 
to assert my Sixth, Fifth and Fourteenth 
1 
however, with respect to my own issues today, I 
2 
am going to have to assert my rights on the 
3 
advice of counsel, under the Sixth, Filth and 
4 
Fourteenth Amendments. 
5 
Q Paragraph two in the Affirmative 
6 
Defenses 
As to all counts alleged 
7 
plaintiff, 
actually consented to and 
8 
participated in similar conduct and/or identical 
9 
to the acts alleged with other persons which were 
10 
the sole or contributing cause to plaintiff's 
11 
damages." 
12 
Sir, you know that's not correct; is 
13 
that correct? 
14 
MR. PIKE: Font. 
15 
A I believe her deposition, in her own 
16 
words sp.aks to this issue, but as far as today 
17 
my to that question answer unfortunately will 
18 
have to be that I assert my rights under the 
19 
Sixth, Fifth and Fourteenth Amendment on advice 
20 
of counsel. 
21 
Q Sir, isn't it true you're not aware of 
22 
any facts to support your contention in this 
23 
answer to the amended complaint that.' 
24 
consented to and participated in conduct similar 
25 
and/or identical to the acts alleged with other 
362 
1 
Amendment rights under advice of counsel, sir. 
2 
Q You read her deposition, correct? 
3 
A No. 
4 
Q You have not read her deposition? 
5 
A No. 
6 
Q But you believe her deposition testimony 
7 
correctly speaks to the issue of the fact that 
8 
she was a willing participant in the nets alleged 
9 
with you? 
10 
A That's not what I said. 
11 
Q Why don't you tell me what you meant 
12 
when you said, "Her deposition testimony speaks 
13 
to the issue." 
14 
A The deposition speaks for itself. Any 
15 
other questions I'm sorry, Mr. Horowitz, but 
16 
today I have to assert my rights under the Sixth. 
17 
Fifth and Fourteenth Amendments. 
18 
Q Isn't it true, sir, that you are not 
19 
aware of anyone who has facts that support the 
20 
statement that=consented to and was a 
21 
willing participant in the acts alleged in her 
22 
lawsuit? 
23 
MR. PIKE: Form. 
24 
A My understanding of her own testimony in 
25 
her deposition speaks to that matter, but, 
9 
1.0 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
364 
1 
persons? 
2 
MR. PIKE: Form? 
3 
A I believe her deposition in her own 
4 
words speaks to this exact question, but however, 
5 
with respect to my answers today, unfortunately 
6 
with respect toM though I would like to 
7 
answer every question with respect tcM on 
8 
advice of counsel I have to assert my rights 
under the Fourteenth, Sixth and Fifth Amendment. 
Q Sir, my question was: What facts do you 
know to be true? Clarify for me. Are you saying 
that you are adopting what-rays 
as true? 
MR. PIKE: Form, misconstrues the 
witness's testimony, and that is not exactly 
what your last question was, so I'm going to 
move —
MR. HOROWITZ: Just to form --
MR. PIKE: No, no, I'm not going to let 
the witness answer a question that's going 
to potentially waive any Constitutional 
privileges here, so it will not be just 
"form" 
Now. having said that, if you can repeat 
the question --
MR. HOROWITZ: Can you repeat the 
8 (Pages 361 to 364) 
U.S. Legal Support 
EFTA01103381

365 
367 
1 
question? 
1 
read that correctly? 
2 
(Discussion off the record.) 
2 
MR. PIKE: Form. I'm going to instruct 
3 
Q Are you suggesting to us you are 
3 
him not to answer that question. Did you 
4 
adopting what- says is true in her 
4 
read that correctly? 
5 
deposition? 
5 
Q Do you see where I am? Do you see where 
6 
MR. PIKE: Form. 
6 
l am, paragraph four? 
7 
A Sir, I would like to answer every 
7 
MR. PIKE: You can answer that question 
8 
question with respect to■ 
However, today on 
8 
as to whether or not you see where he is 
9 
advice of counsel, I have to assert my rights 
9 
identifying paragraph four in the document 
10 
under the Fourteenth, Sixth and Fifth Amendment. 
10 
in front of you. 
11 
Q In paragraph three of your Affirmative 
11 
A I don't think you read it completely, 
12 
Defenses, it says "As to all counts, plaintiff 
12 
did you? 
13 
impliedly consented to the acts alleged by 
13 
Q "As to all counts defendant reasonably 
14 
not objecting." 
14 
believed or was told the plaintiff had attained 
15 
Sir, that's not true, is it? 
15 
the age of 18 years old at the time of the 
16 
MR. PIKE: Form. 
16 
alleged acts." Did I read that correctly now? 
17 
A I believe her own testimony in her 
17 
MR. PIKE: I instruct you not to answer 
18 
deposition speaks to that, however, at least 
18 
that question. It is not formed right. Did 
19 
today, Mr. Horowitz, I have to assert my rights 
19 
you read it correctly connotates an implied 
20 
under the Sixth, Fifth and Fourteenth Amendment. 
20 
potential waiver, did you read it correctly, 
21 
Q What information do you have to support 
21 
is it correct? 
22 
your assertion that plaintiff impliedly 
22 
Q Did I accurately read the statement in 
23 
consented to the acts alleged by not objecting? 
23 
your Affirmative Defenses? 
24 
MR. PIKE: Form. 
24 
MR. PIKE: That is — you can answer 
25 
A Information separate from her own 
25 
that question. 
366 
368 
1 
testimony? 1-- with respect to any other 
1 
A Yes. 
2 
question, I'm going to have to assert my rights 
2 
Q Okay. Isn't it true, sir, that you 
3 
under the Sixth, Fifth and Fourteenth Amendment 
3 
knew, you knew, that . 
was not 18 years old 
4 
upon advice of counsel. 
4 
before May of 2005; isn't that true? 
5 
Q Let's make sore we are on the same page, 
5 
MR. PIKE: Form. 
6 
then. 
6 
A Though I would like to answer every 
7 
A Please. 
7 
question regarding■ and what she said, at 
8 
Q Separate from her deposition 
8 
least today upon advice of counsel, I have to 
9 
testimony — 
9 
assert my rights under the Sixth, Fifth and 
10 
A Yes? 
10 
Fourteenth Amendment, sir. 
11 
Q -- my question Is: Do you have any 
11 
Q Isn't it true, sir, you had no reason to 
12 
facts to support your assertion that 
12 
believe up until May 2005 that M. was 18 years 
13 
impliedly consented to the acts alleged by not 
13 
old or older? 
14 
objecting? 
14 
MR. PIKE: Form. 
15 
MR. PIKE: Form. 
15 
A Separate and apart from her own 
16 
A Separate from her own testimony with 
16 
testimony I believe on the subject, at least with 
17 
respect to her consenting, at least today, though 
17 
respect to today, to answer these questions I'm 
18 
I would like to answer that question, I'm going 
18 
going to have to assert my rights under the 
19 
to have to assert my rights under the Sixth, 
19 
Sixth. Fifth and Fourteenth Amendment on advice 
20 
Fifth and Fourteenth Amendment upon advice of 
20 
of counsel. 
21 
counsel, sir. 
21 
Q Isn't it true, sir, that prior to May of 
22 
Q Okay, paragraph four of the Affirmative 
22 
2005, 
never told you she wns 18 years old or 
23 
Defenses says, "As to all counts, defendant 
23 
older. 
24 
reasonably believed or was told that plaintiff 
24 
MR. PIKE: Form. 
25 
had attained the age of 18 years old." Did I 
25 
A Though I would like to answer that 
9 (Pages 365 to 368) 
U.S. Le al Su 
ort 
EFTA01103382

369 
1 
question with respect to what 
told me, at 
1 
witness's testimony? 
2 
least today I'm going to have to assert my rights 
2 
A I would like to answer every single 
3 
under the Fourteenth, Sixth and Fifth Amendment 
3 
question regarding ■'s claims, every single 
4 
upon advice of counsel. 
4 
one, however, today, upon advice of counsel, at 
5 
Q As to paragraph five, states the 
5 
least today, theyve instructed me to assert my 
6 
following: "Plaintiff's claims are barred as she 
6 
rights under the Sixth, Fifth and Fourteenth 
7 
said she was 18 yean or older at the time." 
7 
Amendment. 
8 
Sir, you know that's not true. That 
8 
Q Sir, what facts do you know of to 
9 
never happened before May of 2005; isn't that 
9 
support the statement that 
consented to and 
10 
correct? 
10 
was a willing participant In the acts alleged? 
11 
MR. PIKE: form. 
11 
MR. PIKE: Form. 
12 
A Though I would like to answer every 
12 
A Separate and apart from her own 
13 
question with respect to whatMsaid and did, 
13 
deposition testimony. I'm sorry, but I would like 
14 
1, unfortunately today, have to assert my rights 
14 
to answer every question with respect to her 
15 
under the Sixth, Fifth and Fourteenth Amendment 
15 
behavior — can you repeat the question, sir? 
16 
upon advice of counsel. 
16 
Q Sure. What facts do you know of to 
17 
Q I'm going to hand you what will be 
17 
support the statement that plaintiff,E, 
18 
marked as Exhibit 5, Defendant Epstein's First 
18 
consented to, and was a willing participant in 
19 
Amended Answer in the Affirmative Defenses to 
19 
the acts alleged? 
20 
Plaintiff's Second Amended Complaint in the 
20 
MR. PIKE: Form. 
21 
lawsuit filed by ■ 
21 
A Separate and apart from her own 
22 
(Handing.) 
22 
testimony on the subject, I cannot answer today 
23 
(Multi-page document was marked as 
23 
that question, though I would like to. And upon 
24 
Plaintiffs Exhibit number 5 for 
24 
advice of counsel, I must assert my rights under 
25 
identification, as of this date.) 
25 
the Sixth, Filth and Fourteenth Amendment. 
370 
372 
1 
Q I'm going to ask you again to turn to 
1 
Q Isn't it true, sir, you're not aware of 
2 
page 6 where it says "Affirmative Defenses." 
2 
anyone who has facts to support the statement 
3 
Do you see where it says "Affirmative 
3 
that A.C. consented to and was a willing 
4 
Defenses"? 
4 
participant in the acts alleged? 
S 
A Urn-hum. 
5 
MR. PIKE: Form. 
6 
Q Paragraph one includes the following 
6 
A Unfortunately — I would like to answer 
7 
statements: "As to all counts plaintiff actually 
7 
every question about Es alleged participation 
8 
consented to and was a willing participant in the 
8 
in any event. However, today, upon advice of 
9 
acts alleged, and therefore her claims are barred 
9 
counsel I have been instructed that I must assert 
10 
or her damages are required to be reduced 
10 
my rights under the Sixth, Fifth and Fourteenth 
11 
accordingly." 
11 
Amendment. 
12 
Sir, this statement that =consented 
12 
Q Sir. paragraph two of the Affirmative 
13 
to and was a willing participant in the acts 
13 
Defenses says: "As to all counts alleged 
14 
alleged; that's not true, is it? 
19 
plaintiff actually consented to and participated 
15 
MR. PIKE: Form, 
15 
in conduct similar and/or Identical to the acts 
16 
A I believe her own deposition speaks to 
16 
alleged with other persons which were the sole or 
17 
that exact question, but at least as far as my 
17 
contributing cause to plaintiffs alleged 
18 
answers are concerned today, Mr. Horowitz, 
18 
damages." 
19 
unfortunately upon advice of my own counsel, I 
19 
Now, sir, that's not a true statement 
20 
have to assert my rights under the Sixth, Fifth 
20 
that plaintiff consented to and participated in 
21 
and Fourteenth Amendment 
21 
similar acts with other persons, is it? 
22 
Q Do you agree with 
s statements with 
22 
MR. PIKE: Form. 
23 
regard to her activity at your home as stated in 
23 
A I would love to respond to every 
24 
her deposition testimony? 
24 
question with respect to similar acts performed 
25 
MR. PIKE: Form, misconstrues the 
25 
by 
with other people. However, at least 
10 (Pages 369 to 372) 
U.S. Legal Support 
EFTA01103383

373 
375 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
today upon advice of counsel I must assert my 
2 
rights under the Sixth, Fifth and Fourteenth 
3 
Amendment. 
4 
Q Sir, what facts do you have to support 
5 
the assertion that 
articipated in conduct 
6 
similar and/or identkal to the acts alleged In 
7 
her lawsuit against you, with other people? 
8 
MR. PIKE: Form. 
9 
A Separate and apart from her own 
0 
deposition, her own testimony, I would like to 
give all the facts with respect tows 
behavior with other people. However, today my 
counsel has advised me that I must assert my 
rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q Have you read her deposition testimony? 
MR. PIKE: Form. 
A No. 
Q Have you listened to her deposition 
testimony? 
A I don't recall. 
Q Am I accurate then, whatever you know 
about her lawsuit is something your attorneys 
have shared with you? 
MR. PIKE: Form. 
1 
information you have about. testimony came 
2 
from your lawyers, or did you hear here it from 
3 
some other source? 
4 
MR. PIKE: Form. 
S 
Pm going to instruct you not to answer 
6 
that question. 
7 
Q Have you heard frond source other 
8 
than your attorneys what 
estified about? 
9 
MR. PIKE: You can answer that 
10 
question. 
11 
A No. 
12 
Q Sir, paragraph three of your Affirmative 
13 
Defenses to as lawsuit says, "As to all 
14 
counts plaintiff impliedly consented to the acts 
15 
alleged by not objecting." Do you see that? 
16 
A Yes, sir. 
17 
Q Sir, you know that's not a true 
18 
statement, isn't it? 
19 
MR. PIKE: Form. 
20 
A I would like to answer every question 
21 
with respect tr..M and what she did or alleged 
22 
to have done. However, today I have to assert my 
23 
rights under the, Sixth, Fifth and Fourteenth 
24 
Amendment, upon advice of counsel. 
25 
Q Sir, what facts do you have to support 
2 
3 
4 
5 
6 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
374 
Q Or do you have it from another source? 
MR. PIKE: One second. 
MR. HOROWITZ: You have to wait for the 
question --
MR. PIKE: No. 
MR. HOROWITZ: That's the way the rules 
worked. 
MR. PIKE: You're asking a question, 
then you're pausing to elicit a response to 
waive attorney/client privilege, okay? Then 
you're jumping into another question. If 
you would like me to sit in your chair and 
teach you how to ask the questions, I will 
be happy to do so. 
MR. HOROWITZ: You couldn't teach me a 
single thing. 
MR. PIKE: However, today we're here for 
you. We're here for you to ask your 
questions. If you would like to break up 
your questions, you can do so. But as to 
that last question, I'm going to instruct 
you not to answer, because, as you know, it 
is attorney/client information. If you want 
to try again, we're here all day. 
Q Sir, is it accurate to say that an 
20 
21 
122 
23 
24 
25 
376 
1 
your assertion that =consented to the acts 
2 
alleged by not objecting? 
3 
MR. PIKE: Form. 
4 
A Unfortunately any facts I might have, my 
5 
attorneys have counseled me I must assert my 
6 
lights under the Sixth, Fourteenth and Fifth 
7 
Amendment, so I must assert those rights today, 
8 
sir. 
9 
Q Sir, isn't it true you're not aware of 
10 
anyone who has facts to support the statement 
11 
that A.C. consented to the acts alleged by not 
12 
objecting? 
13 
MR. PIKE: Form. 
14 
A Though I would like to answer those 
15 
questions with respect to the facts about 
16 
at least today my counsel has advised me I must 
17 
assert my rights under the Sixth, Fifth and 
18 
Fourteenth Amendment. 
19 
Q Turning to paragraph four of the 
Affirmative Defenses, isn't it true, sir, that 
you knew that-.vas IS years, was under 18 
years old when she came to your home? 
MR. PIKE: Form? 
A Though I would like to answer every 
question about Ms. `I 
cannot, on advice of 
11 (Pages 373 to 376) 
U.S. Legal Su ort 
EFTA01103384

377 
379 
counsel today, and they've asked me to assert my 
1 
today advised me I must assert my rights under 
2 
rights under the Sixth, Fifth and Fourteenth 
2 
the Sixth, Fifth and Fourteenth Amendment 
3 
Amendment. 
3 
Q Isn't it true, sir, there are no facts 
4 
Q Isn't it true, sir that you had no 
4 
that you're aware of to support the statement 
5 
reason to believe that 
vas Ift years or older 
5 
that■ consented to and was a willing 
6 
when she was at your home? 
6 
participant in the acts alleged? 
7 
MR. PIKE: Form. 
7 
MR. PIKE: Form. 
8 
A Though I would like to answer every 
8 
A Though, the question of whether she was 
9 
question about •today, Mr. Horowitz.,, my 
9 
a willing participant in the acts alleged, I 
10 
counsel has advised me I must at least today 
10 
would real • like to answer those questions with 
11 
assert my rights under the Sixth, Fifth and 
11 
respect t 
However, at least today my 
12 
Fourteenth Amendment. 
12 
counsel has advised me f must assert my rights 
13 
Q Isn't it true, sir, 
never told you 
13 
under the Sixth, Fifth and Fourteenth Amendment. 
14 
she was IS years old or older? 
14 
Q Turning to paragraph two of the 
15 
MR. PIKE: Form. 
15 
Affirmative Defenses, what facts do you have to 
16 
A Though I would like to answer that 
16 
support your assertion that 
consented to and 
17 
question regarding what Ms. ■ 
told me, my 
17 
participated in conduct similar and/or identical 
18 
counsel has advised me that today I must assert 
18 
to the acts alleged with other persons? 
19 
my rights under the Sixth. Fifth and Fourteenth 
19 
MR. PIKE: Form. 
20 
Amendment 
20 
A Thoughlwould like to answer the 
21 
Q Isn't it true, sir, no one ever told you 
21 
question about the acts that sties performed with 
22 
that 
was 18 years old or older when she was 
22 
other persons similar to the ones alleged here, 
23 
at your home? 
23 
at least today under advice of counsel. I have 
24 
MR. PIKE: n=orm. 
24 
been instructed to assert my rights under the 
25 
A Though I would like to answer that 
25 
Sixth, Fifth and Fourteenth Amendment 
378 
380 
question, with respect to what people told me how 
1 
Q Sir, you know that= never consented 
2 
old she was or what she told me how old she was, 
2 
to or participated in similar or identical acts 
3 
sorry, but my counsel advised me today i must 
3 
with other persons; isn't that right? 
4 
assert my rights under Sixth, Fifth and 
4 
MR. PIKE: Form. 
5 
Fourteenth Amendment. 
5 
A I would very much like to answer that 
6 
Q Okay. 
6 
question, very much. However, sir, at least 
7 
(Multi page document was marked as 
7 
today my counsel has advised me I must assert my 
8 
Plaintiff's Exhibit number 6 for 
8 
rights under the Sixth, Fifth and Fourteenth 
9 
identification, as of this date.) 
9 
Amendment. 
10 
Q Moving on to Exhibit 6, Epstein's First 
10 
Q Sir, isn't it true you're not aware of 
11 
Amended Answer in Affirmative Defense is to make 
11 
anyone who has facts to support your assertion 
12 
his First Amended Complaint in the Jane Doe 
12 
that 
M
 
ons ented to or participated in similar 
13 
number 6 case, and I'll hand you a copy of that 
13 
or identical acts with other persons? 
14 
and represent to you that Jane Doe 6 ie., 
1.4 
MR. PIKE: Form. 
15 
okay? task you to turn to page 6 — I see 
15 
A I'm sorry, can you read that question 
16 
you've already done that, of the Affirmative 
16 
back? 
17 
Defenses. 
17 
Q Sir, Isn't it true you're not aware of 
18 
What facts do you have to support the 
18 
anyone who has facts to support your assertion 
19 
contention in paragraph one tha 
consented 
19 
that 
consented to and participated to 
20 
to and was a willing participant in the acts 
0 
similar or identical acts with other people? 
21 
alleged? 
1 
MR. PIKE: Form. 
22 
MR. PIKE: Form? 
2 
A Though I would like to answer that 
23 
A Though I would like to answer the 
23 
question regarding does anyone else have 
24 
question regarding what 
consented to and how 
24 
information with respec to 
participating 
25 
she was a participant in the events, my counsel 
25 
with other people in similar acts as your 
12 (Pages 377 to 380) 
U.S. Legal Support 
EFTA01103385

381 
383 
question posed, tmfortunately, today, sir, I'm 
going to have to assert my rights upon advice of 
3 
counsel under the Sixth, Fifth and Fourteenth 
1 
Amendment. 
Q Turning to paragraph three of your 
Affirmative Defenses, sir, it is not a true 
7 
statement that■ impliedly consented to the 
acts alleged by not objecting. is it, sir? 
9 
MR. PIKE: Foam 
10 
A The question regarding. implied 
11. 
consent that you've just posed. I would like to 
12 
answer that question. I would like to answer all 
13 
the questions with respect walla' you've 
14 
posed here today. However, upon advice of 
15 
counsel I have to assert my rights under the 
16 
Sixth, Fifth and Fourteenth Amendment. 
17 
Q Slr, what facts do ou have to support 
18 
your contention that 
consented to the acts 
19 
alleged by not objecting? 
20 
MR. PIKE: Form. 
21 
A Though I would like to answer that 
22 
question regarding the facts that I have 
23 
regarding =s 
consent, my attorneys have 
24 
advised me that today I have to assert — at 
25 
least today, I have to assert my rights under the 
1 
to the question of whalMold me, I would 
2 
like to respond to every question regarding. 
3 
my counsel has advised me that today at least, I 
4 
must assert my rights under the Sixth, Fifth and 
5 
Fourteenth Amendment. 
6 
Q Isn't it true, sir, t 
u could 
7 
plainly tell by looking at 
that she was not 
8 
18 years old? 
9 
MR. PIKE: Form. 
10 
A Sir,1 would like to answer that 
11 
question, as I would like to answer every other 
12 
question regarding your plaintiff= However 
13 
today on advice of counsel, they've Instructed me 
14 
I must assert my rights under the Sixth, Fifth 
15 
and Fourteenth Amendment. 
16 
MR. PIKE: Form. 
17 
A Isn't it true, sir, no one told you MI 
18 
was 18 years old or older. 
19 
MR. PIKE: Form. 
20 
A Though I would like to answer ev 
21 
question of what people told me regarding. 
22 
allegedly, my counsel has instructed me I must 
23 
respond by asserting my Sixth, Fifth and 
24 
Fourteenth Amendment rights, sir. 
25 
Q Sir, I'm going to hand you what we will 
382 
1. 
Sixth. Fifth and Fourteenth Amendment. 
Q Sure, turning to paragraph four. it says 
"As to all counts" — strike that. 
4 
Isn't it true, sir, that you knew when 
5 
=was at your home that she was not 18 years 
6 
old? 
7 
MR. PIKE: Form. 
8 
A I would like to answer the question 
9 
about., every question abouMtere today 
10 
that you've posed. However, upon advice of my 
11 
counsel they've advised me that I must assert my 
12 
rights under the Sixth, Fifth and Fourteenth 
13 
Amendment. 
14 
Q Isn't It true, sir, you had no reason to 
15 
believe that. was 18 years of age or older? 
16 
MR. PIKE: Form. 
17 
A The question regarding my reason to 
18 
believe MVOs 18 or over? I would really like 
19 
to answer that question, but however, today my 
20 
counsel has advised me I must assert my rights 
21. 
under the Fifth, Sixth and Fourteenth Amendment, 
22 
sir. 
23 
Q Isn't it true 
never told you she 
24 
was 18 or older? 
25 
A Though I would very much like to respond 
384 
1 
mark ax Exhibit 7. It is Defeodant Epstein's 
2 
First Amended Answer and Affirmative Defenses to 
3 
Plaintiffs First Amended Complaint in Jane Doe 7 
4 
ease filed by ■ 
S 
(Multi-page document was marked as 
6 
Plaintiffs Exhibit number 7 for 
7 
identifkation, as of this date.) 
8 
Q I ask you to take a look at that, 
9 
please, and turn to page 6, of the Affirmative 
10 
Defenses. 
11 
THE WITNESS: Take a five-minute break/ 
12 
MR. HOROWITZ: Sure. 
13 
THE VIDEOGRAPHER: Off the record at 
14 
11:13 am. 
15 
(Pause in the proceedings.) 
16 
THE VIDEOGRAPHER: Back on the video 
17 
record 11:21 a.m. 
10 
Q Mr. Epstein, do you have in front of you 
19 
the Affirmative Defenses filed in your behalf in 
20 
M.'s lawsuit? 
21 
A Yes. 
22 
Q What facts do you have to support your 
23 
contention that 
consented to and was a 
24 
willing participant in the acts alleged? 
25 
MR. PIKE: Form. 
13 (Pages 381 to 384) 
U.S. Legal Support 
EFTA01103386

385 
387 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
A Separate and open from her own 
2 
statements with regard to these issues, I would 
3 
like to answer every question here today with 
4 
respect to• 
However upon advice of counsel, 
5 
at least today, I have to assert my rights under 
6 
the Sixth, Fifth and Fourteenth Amendment. 
7 
Q And is it your position that, well, tell 
8 
its if it is your position that 
admitted to 
consenting to and being a willing participant in 
the acts alkged. 
MR. PIKE: Form. 
A Can you repeat the question? 
Q Is it your position that tdmitted 
in her deposition testimony to having consented 
to, and having been a wining participant in the 
acts alleged? 
A I think her deposition speaks for 
itself, but anything beyond that, at least today, 
Mr. Horowitz, I'm going to have to assert my 
rights upon advice of counsel under the Sixth, 
Fifth and Fourteenth Amendment. 
Q Do you believe thatMwas accurate 
when she, according to you, testified that she 
consented to and was a willing participant in the 
acts alleged? 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
386 
MR. PIKE: Form. 
A I would like nothing more than to 
respond to everything.has to say. However, 
at least today, upon advice of my counsel, I'm 
going to have to assert my rights under the 
Sixth, Fifth and Fourteenth Amendment. 
Q Mr. Epstein, you know the statement that 
M
o
n
s
e
n
(
 
ed to and was a willing participant 
in the acts alleged if not a true statement; 
isn't that right? 
MR. PIKE: Form. 
A I would very much like to respond to 
whether■ was a willing participant in any 
alleged act. However, at least today, Mr. 
Horowitz, my counsel has advised me that I must 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Sir, what facts do you know of to 
support the statement 160Mconsented to and 
was a willing participant in the acts alleged? 
MR. PIKE: Form. 
A Though I would like to respell:
d
ry 
question regarding the facts regarding 
what she consented to and what she did not 
consent to, I'm afraid that at least today my 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
counsel has advised me I must assert my rights 
under the Fifth, Sixth and Fourteenth Amendment. 
Q Turning to paragraph two of your 
Affirmative Defenses, what facts are you aware of 
to support your contention that= consented 
to and participated in similar or identical acts 
with other persons? 
MR. PIKE: Fenn. 
A Though I would very much like to respond 
to similar acts the■ participated in with 
respect to your question, sir, at least today my 
counsel has advised me thatl must assert my 
rights under the Sixth, Filth and Fourteenth 
Amendment. 
Q isn't it true, sir, you know of no facts 
to support your contention in the Affirmative 
Defenses thaesartkipated in similar or 
identical acts with other persons? 
MR. PIKE: Form. 
A As I said previously, l would like to 
testify, I would like to answer your questions 
with respect to. 
However, today my counsel 
has advised me that at !cast today I would have 
to assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
388 
1 
Q Isn't it true, sir, you're not aware of 
2 
anyone who has facts to support the contention 
3 
that■ participated or consented to similar or 
4 
identical acts with other people? 
5 
MR. PIKE: Form. 
6 
A The issue of whethernarticipated 
7 
with other people in similar alleged acts, I 
8 
would very much like to answer. However, today my 
counsel has advised me I may not, and have 
advised me I must assert my Sixth, Fifth and 
Fourteenth Amendment rights. 
Q Turning to paragraph three, what facts 
do you have to support your contention that-
consented to the acts alleged by not objecting? 
MR. PIKE: Form. 
A Though I would like to answer every 
question here today regardingMity counsel 
has advised me that at least today I have to 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Isn't it true, sir, you know of no facts 
to support your contention thaeconsented to 
the acts alleged by not objecting? 
MR. PIKE: Form. 
A Though I would like to answer every 
14 (Pages 385 to 388) 
U.S. Legal Support 
EFTA01103387

389 
391 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
question you pose regarding., Mr. Horowitz. 
2 
at least today my counsel has advised me I must 
3 
assert my rights to the Sixth, Fifth and 
4 
Fourteenth Amendment. 
Q Is it true, sir, you're not aware of 
anyone who has facts to support the statement 
that-consented to the acts alleged by not 
objecting? 
MR. PIKE: Form. 
A I would like to answer the question with 
respect to Es consent a not consent. 
However, today my counsel has advised me I must 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment, though I would very much 
like to answer that question. 
Q Turning to paragraph four of the 
Affirmative Defenset 
you did not believe in 
your own mind tha=was 18 years or older 
before May of 2005; isn't that true? 
MR. PIKE: Form. 
A Would you repeat the question, Mr. 
Horowitz? 
Q You didn't believe prior to May 2005 in 
your mind that 
was 18 years old or older, 
isn't that true? 
390 
MR. PIKE: Form. 
A What I believed in my mind, 
unfortunately I would like to answer every 
question with regard tc
 that you posed here 
today, very much would like to answer every 
question with respect to■ However, at least 
today I have to assert my rights on advice of 
counsel under the Sixth, Fifth and Fourteenth 
Amendment. 
jw
Sir, before May of 2005, you knew that 
as under the age of 18; Isn't that right? 
MR. PIKE: Form. 
A Sir, I would like to answer every 
question with respect tc=that you've posed 
here today. However, my counsel has advised me 
that at least today I may not, and must assert my 
rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q Sir, prior to May 2005.never told 
you she was 18 or older; isn't that true? 
MR. PIKE: Form? 
A I would very much like to answer 
questions, every question with respect 
that you've posed here today, Mr. Horowitz. 
However, upon advice of my counsel, they've 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
advised me that I must assert my rights under the 
2 
Sixth, Fifth and Fourteenth Amendment. 
3 
Prior to May 2005. no one told you that 
4 
•was under the age of 18; isn't that right? 
5 
MR. PIKE: Form. 
6 
A I would very much like to answer every 
7 
question with respect to what. and what 
8 
everyone — other people said about. 
However, at least today my counsel advised me 
that I may not. They've advised me that I must 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
(Multi•page document was marked as 
Plaintiffs Exhibit number 8 for 
identification, as of this date.) 
Q Sir, I've just handed you defendant 
Jeffrey Epstein's Answer and Affirmative Defenses 
to plaintiff's Amended Complaints in the Jane 
Does number 8 lawsuit, filed by
 Do you have 
that in front of you? 
A Yes. 
Q I'll ask you to turn, please, to page 6, 
which is the Affirmative Defenses. 
With regard to paragraph one, what facts 
do you have to support your contention that ME 
392 
1 
consented to and was a willing participant in the 
2 
acts alleged? 
3 
MR. PIKE: Form. 
4 
A I would like to answer every question 
5 
about J.M. here today. However, my counsel has 
6 
advised me that at least today — I must assert 
7 
my rights under the Sixth, Fifth and Fourteenth 
8 
Amendment, though I would ve 
mt 
like to 
9 
answer every question regardin 
10 
Q Sir, what facts do you know of to 
11 
support the statement thateonsented to and 
12 
was a willing participant in the acts alleged? 
13 
MR. PIKE: Form. 
14 
A Though I would like to answer every 
15 
question about any alleged incident with 
mh-
16 
counsel has advised me that at least today I must 
17 
assert my rights under the Sixth, Fifth and 
18 
Fourteenth Amendment. 
19 
Q Isn't it true, sir, you're not aware of 
20 
anyone who has facts to support your assertion 
21 
that
 consented to and was a willing 
22 
participant in the acts alleged? 
23 
MR. PIKE: Form. 
24 
A I would like to answer every question 
25 
regarding■ and her claims, and these alleged 
15 (Pages 389 to 392) 
U.S. Legal Support 
EFTA01103388

393 
395 
incidents. However, today, at least today, my 
1 
question that you've posed regarding your client, 
2 
counsel has advised me that I must assert my 
2 
=However, my counsel here today has advised 
3 
rights under the Sixth, Fifth and Fourteenth 
3 
me that 1 must assert my rights under the Sixth, 
4 
Amendment. . 
4 
Fifth and Fourteenth Amendment, at least today. 
Q Okay, turning to paragraph two, what 
5 
Q Turning to paragraph four of the 
6 
fact 
a aware of to support your contention 
6 
Affirmative Defenses, It is on the following page 
7 
that 
consented to and participated in 
7 
If you want to follow along; what facts do you 
8 
similar or identical acts with other people? 
8 
have to support your contention that you believed 
9 
MR. PIKE: Form. 
9 
attained the age of 18 at the time of the 
10 
A With respect to acts with similar other 
10 
alleged acts? 
11 
people, I would very much like to answer that 
11 
MR. PIKE: Form. 
12 
question. However, at least today my counsel has 
12 
A I would very much like to answer every 
13 
advised me that I must assert my rights under the 
13 
question with respect to 
and her claims. 
14 
Sixth, Fifth and Fourteenth Amendment. 
14 
However, today, at least today, my attorneys have 
15 
Isn't it true, sir, that this assertion 
15 
advised me that I must assert my rights under the 
16 
that 
consented to and participated in 
16 
Sixth. Fifth and Fourteenth Amendment. 
17 
similar or identical acts with other persons; 
17 
Q Isn't it true, sir, you knew that 
18 
that's not a true statement, is it? 
18 
was under the age of IS at the time of the 
19 
MR. PIKE: Form. 
19 
alleged acts? 
20 
A I would very much like to answer every 
20 . 
MR. PIKE: Form. 
21 
single question with respect 
t
 
c
.
 
and her 
21 
A I would very much like to answer every 
22 
alleged claims of alleged incidents. However, 
22 
question with respect to. 
claims. However, 
23 
today, my counsel has advised me I must assert my 
23 
my counsel today has advised me I must assert my 
24 
rights under the Sixth, Fifth and Fourteenth 
24 
rights under the Sixth, Fifth and Fourteenth 
25 
Amendment. 
25 
Amendment. 
394 
396 
1 
Q Isn't it true, sir, you're not aware of 
1 
Q kill it true, sir, you had no reason to 
2 
anyone who has facts to support your assertion 
2 
believe that ■Win IS years old or older at 
3 
that-consented to and participated in 
3 
the time of the alleged acts? 
4 
similar or identical acts with other people? 
4 
MR. PIKE: Form. 
5 
MR. PIKE: Form. 
5 
A I would like to answer every single 
6 
A I would like to answer every question 
6 
question regardingns claims, sir. However,
7 
with respect to 
her alleged claims and 
7 
at least today my counsel has advised me I must 
8 
alleged incidents. However, today my counsel 
8 
assert my rights under the Sixth, Fifth and 
9 
has advised me that I must assert my rights under 
9 
Fourteenth Amendment 
10 
the Sixth, Fifth and Fourteenth Amendment, sir. 
10 
Q Isn't It true, sir, 
ever told you 
11 
Q Turning to paragraph three, what facts 
11 
she was 18 or older? 
12 
do you have to support your assertion that 
12 
MR. PIKE: Form. 
13 
consented to the acts alleged by not objecting? 
13 
A I would very much like to answer every 
14 
MR. PIKE: F0(111. 
14 
question regarding 
claims. However, today 
15 
A I would like to answer every question 
15 
my counsel has advised me that I must assert my 
16 
with respect to= 
claims and alleged 
6 
rights under the Sixth, Fifth and Fourteenth 
17 
incidents. However, today my counsel has advised 
7 
Amendment. 
18 
me I must assert my rights under the Sixth, Fifth 
8 
Q Isn't It true, sir, no one ever told you 
19 
and Fourteenth Amendment. 
9 
that 
was 18 or older? 
20 
Q Isn't it true, sir, you're not aware of 
0 
MR. PIKE: Form. 
21 
anyone who has facts to support your assertion 
1 
A I would like to answer every question 
22 
that 
consented to the facts alleged by not 
2 
with respect to 
claims. However, at least 
23 
objecting? 
3 
today my counsel has advised me that I may not, 
24 
MR. PIKE: Form. 
4 
and though I would like to, they told me I must 
25 
A I would very much like to answer every 
5 
assert my rights under the Sixth, Fifth and 
16 (Pages 393 to 396) 
U.S. Le al Su ort 
EFTA01103389

397 
399 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
i 
Fourteenth Amendment. 
2
Q Sir did on ever pay for a telephone 
3 
numb. 
pay the phone bill? 
4 
A I would have to assert my rights under 
5 
the Sixth, Fifth and Fourteenth Amendment, sir. 
6 
Q Between 2001 and 2006, did you use the 
7 
telephone number • 
to get kids to 
8 
come to your home for your sexual pleasure? 
9 
MR. PIKE: Form. 
A Though I would like to answer all these 
questions regarding phone numbers, I'm sorry but 
I may not on advice of counsel, so I must assert 
my rights under the Sixth. Fifth and Fourteenth 
Amendment. 
Q Did you direct one or more people to use 
the telephone number 
a order to 
get kids, girls, to come to your home for your 
sexual pleasure? 
MR. PIKE: Form. 
A Though I would like to answer every one 
of your questions today regarding phone numbers, 
on advice of counsel. I may not, because it may 
be relevant to other lawsuits or this lawsuit, 
and they've instructed me that I must assert my 
rights under the Sixth, Fifth and Fourteenth 
1 
age of 18 to come to your home for your sexual 
2 
pleasure? 
3 
MR. PIKE: Form. 
4 
A I would like to answer every one of your 
5 
questions regarding these phone numbers and 
6 
allegations. However, today, my counsel has 
7 
advised me that I may not and must assert my 
B 
rights under the Sixth. Fifth and Fourteenth 
9 
Amendment. 
10 
Q slave you ever paid the telephone bill or 
11 
had registered in your name the phone number 
12 
13 
MR. PIKE: Form. 
14 
A Mr. Horowitz, l would like to answer 
15 
each one of your questions regarding phone 
16 
numbers here today, but on advice of counsel 
17 
they've told melmust assert my rights under the 
18 
Sixth, Fifth and Fourteenth Amendment. 
19 
Q Is -a
 telephone number you 
20 
used between 2001 and 2006 to get girls under the 
21. 
age of 18 to come to your home for your sexual 
22 
pleasure? 
23 
MR. PIKE: Form. 
24 
A Though I would like to answer every one 
25 
of your questions regarding telephone numbers, my 
2 
3 
4 
Amendment. 
Q Have you ever either paid or had 
re istered to you the telephone number= 
MR. PIKE: Form. 
A I would like to answer every question 
7 
regarding phone numbers, Mr. Horowitz. My 
8 
attorneys have asked me to respond to most of 
9 
your questions here today by asserting my rights 
10 
under the Sixth, Fifth and Fourteenth Amendment I 
11 
will have to do so with respect to that question. 
12 
Q Between the years 2001 and 2006, did you 
13 
use the telephone number 
in order 
14 
to arrange for girls under the age of IS to come 
15 
to your home for your sexual pleasure? 
16 
MR. PIKE: Form. 
17 
A I would like to answer every one of your 
18 
questions regarding phone numbers here today, Mr. 
19 
Horowitz. However, on advice of counsel, at 
20 
least today, they've instructed me that I must 
21 
assert my rights under the Sixth, Fifth and 
22 
Fourteenth Amendment. 
23 
Q Between 2001 and 2006. did you direct 
24 
one or more people to use the telephone number 
25 
In order to get girls under the 
398 
400 
1 
counsel has advised me that at least today I may 
2 
not, because it may be relevant to this lawsuit 
3 
or another lawsuit, and they've instructed me 
4 
that I must assert my rights under the Sixth, 
5 
Fifth an 
dment. 
6 
Q I 
a telephone number 
7 
that you directed to other people to use in order 
8 
to gel kids to come to your home for your sexual 
9 
pleasure? 
10 
MR. PIKE: Form. 
11 
A I would like to answer every one of your 
12 
questions regarding phone numbers allegedly used 
13 
for these types of purposes. However, my counsel 
14 
today has advised me l may not and have 
15 
instructed me I must assert my rights under the 
16 
Sixth. Fifth and Fourteenth Amendment. 
17 
Q Sir, have you ever paid the phone bill 
18 
or had registered In your name the phone number 
19 
20 
MR. PIKE: Form. 
21 
A Though I would like to answer that 
22 
question as I would like to answer every one of 
23 
your questions here today, my counsel has advised 
24 
me that at least today, I must assert my rights 
25 
under the Sixth, Fifth and Fourteenth Amendment, 
17 (Pages 397 to 400) 
U.S. Legal Support 
EFTA01103390

2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
401 
sir. 
Q Is the tekphonc number i 
a telephone number you used between 2001 and 2006 
hi order to get girls under the age of 18 to come 
to your home for your sexual pleasure? 
MR. PIKE: Form 
A I would like to mower evay one of your 
questions with respect to these telephone 
numbers. However, my counsel today has advised 
me that I must assert, at least today, my rights 
under the Fifth, Sixth and Fourteenth Amendment. 
Q Sir, is 
telephone 
number that you directed other people to use in 
order to get girls under the age of Itt to come to 
your home for your sexual pleasure? 
MR. PIKE: Form 
A I would like to answer every question 
regarding these telephone numbers. However, my 
counsel has advised me that at least today, that 
I may not and they've instructed me I must assert 
my rights under the Sixth, Fifth and Fourteenth 
Amendment 
Q Sir, have you ever registered in your 
same or paid the phone bill for telephone number 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
403 
phone numbers. However, upon advice of my 
counsel, they've instructed me that I must assert 
my rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q Sir, have you ever paid the phone bill 
or had the phone number 
registered 
in your name? 
MR. PIKE: Form. 
A I would very much like to answer every 
question regarding phone numbers that you've 
posed here today, Mr. Horowitz. However, my 
counsel has advised me that at least today I must 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q SIr, is the telephone number Ie 
a telephone number you used between 2001 
and 2004 to get underage girls to come to your 
home for your sexual pleasure? 
MR. PIKE Form. 
A I would very much like to ensues' even' 
one of your questions posed here today with 
regard to telephone numbers or anything else. 
However, my counsel has advised me at least today 
that I may not, and must assort my rights under 
the Sixth, Fifth and Fourteenth Amendment. 
402 
404 
1 
MR. PIKE: Form. 
1 
Sir, is the telephone number 
2 
A I would like
 answer each one of your 
2 
a telephone number you directed others 
3 
questions today, Mr. Horowitz, regarding these 
3 
to use in order to get underage girls to come to 
4 
telephone numbers. My counsel has advised me 
4 
your home for your sexual pleasure? 
5 
that at least today I may not, and must assert my 
5 
MR. PIKE: Form. 
6 
rights under the Sixth, Fifth and Fourteenth 
6 
A I would like to answer every one of your 
7 
Amendment. 
7 
questions regarding phone numbers, Mr. Horowitz. 
8 
Q Is 
a telephone number you 
8 
However, today my counsel has advised me that I 
9 
used between 2001 and 2006 to get girls under the 
9 
must assert my rights under the Sixth, Fifth and 
10 
age of 18 to come to your home for your sexual 
10 
Fourteenth Amendment. 
11. 
pleasure? 
11 
Q Sir, have you ever paid the phone bill 
12 
MR. PIKE: Form. 
12 
or had the phone number 
registered 
13 
A Though I would very much like to answer 
13 
in your name? 
14 
every question regarding — that you've posed 
14 
MR. PIKE: Form. 
15 
here today regarding phone numbers, on advice of 
15 
A Sir, I would like to answer every one of 
16 
cbunsel, I may not. They've instructed me I must 
16 
your questions regarding phone numbers. However, 
17 
assert my rights under the Sixth, Fifth and 
17 
my counsel has advised me that at least today I 
18 
Fourteen 
18 
must assert my rights under the Sixth, Fifth and 
19 
Q Is 
a telephone number you 
19 
Fourteenth Amendment. 
20 
directed other people to use in order to get 
20 
Q Is the telephone number 
a 
21 
girls under the age of 18 to come to your home 
21 
telephone number that you used between 2101 and 
22 
for your sexual pleasure? 
22 
2006 in order to get kids to conic to your home 
23 
MR. PIKE: Form. 
23 
for your sexual pleasure? 
24 
A I would like to answer every one of your 
24 
MR. PIKE: Form. 
25 
questions posed here today regarding various 
25 
A Though I would Tike to answer every one 
18 (Pages 401 to 404) 
U.S. Le al Su ort 
EFTA01103391

405 
407 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
/5 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
of your questions regarding phone numbers here 
today, Mr. Horowitz, my counsel has advised me 
that I may not and must assert my rights under 
the Sixth, Fifth and Fourteenth Amendment. 
Q Sir, is telephone number 
a telephone number that you directed others to 
use In order to get underage girls to come to 
your home for your sexual pleasure? 
MR. PIKE: Form. 
A Though I would like to answer every one 
of your questions regarding phone numbers, Mr. 
Horowitz, the various phone numbers you've now 
put on the table, my counsel has advised me at 
least today I may not. I must assert my rights 
under the Sixth, Fifth and Fourteenth Amendment. 
Q Sir, have you ever paid the phone bill 
or had registered In your name the telephone 
number 
MR. PIKE: Form. 
A Mr. Horowitz, I would like to answer 
every one of your questions regarding phone 
numbers that you've posed here today. However, 
upon advice of counsel, they've instructed me I 
must assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
22 
23 
24 
25 
regarding these various phone numbers you've 
thrown out today, my counsel have advised me that 
I may not, and must assert my rights under the 
Sixth, Fifth and Fourteenth Amendment. 
Q Sir, have you ever paid the phone bill 
for telephone number 
MR. PIKE: Form. 
A Mr. Horowitz. ) would very much like to 
answer all your questions regarding all the 
various phone numbers you've thrown out here 
today. However, on advice of counsel they've 
asked me to assert my Sixth, Fifth and Fourteenth 
Amendment right. 
is the telephone number 
a telephone number that you used between 
2001 and 2006 in order to get underage girls to 
come to your home for your sexual pleasure? 
MR. PIKE: Form. 
A Mr. Horowitz, with respect to all these 
phone numbers you keep throwing out, I have to 
unfortunately answer the question the same way as 
rye answered all your other questions here 
today, which is I'm going to have to assert my 
rights upon the advice of counsel under the 
Sixth, Fifth and Fourteenth Amendment. 
406 
1 
Q Is 
a telephone number 
2 
that you used between 2001 and 2006 in order to 
3 
get girls under the age of 18 to come to your 
4 
home for your sexual pleasure? 
5 
MR. PIKE: Form. 
6 
A Mr. Horowitz, I would very much like to 
7 
answer every one of your questions regarding 
various numbers you've thrown out here today. I 
have to answer that question like I've answered 
all your other questions here today, which is on 
advice of counsel I may not answer these 
questions as they may not be relevant to another 
lawsuit --
Q Sir — go ahead, sorry. 
A 
though I would like to, I am going to 
have to assert my rights as instructed by 
counsel, under the Sixth, Fifth and Fourteenth 
Amendment. 
Q Sir, is the telephone number 
a telephone number that you directed 
others to use In order to bring girls to your 
home for your sexual pleasure? 
MR. PIKE: Form. 
A Though I would like to answer each and 
every one of your questions, Mr. Horowitz, 
1 
2 
3 
4 
S 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
408 
Q Sir, 
a telephone 
numberitrh 
k 
at you directed other people to use in 
order to get girls to come to your home for your 
sexual pleasure? 
MR. PIKE: Form. 
A Although I would like to answer every 
one of your questions regarding the various phone 
numbers that you've thrown out today, at least 
today. upon advice of counsel, I have to assert 
my rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q Have you ever paid the phone bill for 
telephone number 
MR. PIKE: Form? 
A With respect to all the phone numbers 
you've thrown out here today and asked questions 
with regard to today, my counsel has advised me 
must assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Is the telephone number 
telephone number you directed other people to use 
in order to bring girls under the age of IA to 
your home for your sexual pleasure? 
MR. PIKE: Form. 
A I have to answer that question as I've 
19 (Pages 405 to 408) 
U.S. Legal Support 
EFTA01103392

409 
411 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
answered most of your other questions here today, 
Mr. Horowitz, which is upon advice of counsel I 
have to assert my rights under the Sixth, Fifth 
end Fourteenth Amendment 
Q Sir, have you ever paid the phone bill 
for telephone number 
MR. PIKE: Form. 
A You've asked me many telephone numbers 
here today, Mr. Horowitz. I'm going to have to 
respond to that telephone number as I have to 
each and every one of your other phone numbers 
you've thrown out today, which is upon advice of 
counsel, they've instructed me to assert my 
rights under the Sixth, Fifth and Fourteenth 
Amendment although I would like to answer every 
one of your questions 
Q Is the number S 
a 
telephone number that you directed other people 
to use in order to bring underage girls to your 
home for your sexual pleasure? 
MR. PIKE: Fenn. 
A Though I would like to answer every 
question regarding phone numbers that you've 
posed here today, Mr. Horowitz, unfortunately my 
counsel advised me I must assert my rights under 
1 
interest in a business entity known as Zorro 
2 
Ranch? 
3 
A Though I would like to answer every one 
4 
of your questions, I would have to answer that 
S 
one as I've answered all your other questions 
6 
here today, which is upon advice of counsel today 
7 
they've asked me -- instructed me to assert my 
8 
rights under the Sixth, Filth and Fourteenth 
9 
Amendment. 
10 
Q Sir, have you ever owned or had a 
11 
beneficial interest, been a director or officer 
12 
of New York Strategy Group, LLC? 
13 
A Mr. Horowitz. I would like to answer all 
14 
of your questions here today, but unfortunately 
15 
my counsel has asked me — instructed me to 
16 
assert my rights under the Sixth, Fifth and 
17 
Fourteenth Amendment. 
18 
Q Have you ever owned or had a beneficial 
19 
interest in or been an officer or director or 
20 
founder of the COUQ Foundation? 
21 
A Though I would like to answer every one 
22 
of your questions, Mr. Horowitz, I have to 
23 
respond to that question as I have responded to 
24 
almost all of your other questions here today, 
25 
which is that upon advice of counsel, they've 
410 
1 
the Sixth, Fifth and Fourteenth Amendment. 
2 
Q Sir, have you ever owned or had a 
3 
beneficial interest in a corporation known as 
4 
Nine East 71st Street Corporation? 
S 
A I would like to answer every one of your 
6 
questions here today, Mr. Horowitz, but on advice 
7 
of counsel, at least today, I'm going to have to 
8 
assert my rights under the Sixth, Fifth and 
9 
Fourteenth Amendment. 
10 
Q Sir, have you ever owned or had a 
beneficial Interest in .1. Epstein & Company? 
12 
A Sir, at least today with respect to most 
13 
of your questions, like — I've answered almost 
14 
all of your questions here today, upon advice of 
15 
counsel, they've asked me to assert my rights 
16 
under the Sixth. Fifth and Fourteenth Amendment. 
17 
Q Have you ever owned or had a beneficial 
18 
interest or been nn officer of Zorro Development 
19 
Corporation? 
20 
A I would like to answer every one of your 
21 
questions here today, Mr. Horowitz. However, 
22 
upon advice of counsel at least today, they've 
23 
asked me to assert my rights under the Sixth, 
24 
Fifth and Fourteenth Amendment. 
25 
Q Have you ever owned or had a beneficial 
412 
1 
instructed me I must assert my rights under the 
2 
Sixth. Fifth and Fourteenth Amendment. 
3 
Q Have you ever been an owner, shareholder 
4 
or had a beneficial interest in Financial 
5 
Strategy Group, Inc.? 
6 
A I would like to answer that question, as 
7 
well as every other question you've posed here 
8 
today. However, my counsel has advised me that 
9 
at least today I must assert my rights under the 
10 
Sixth, Fifth and Fourteenth Amendment. 
11 
Q Have you ever owned or had a beneficial 
12 
interest or been a shareholder in Financial 
13 
Trustees, Inc.? 
14 
A Though I would like to answer every one 
15 
of your questions here, that you've posed here 
16 
today, Mr. Horowitz, I have to unfortunately 
17 
answer that question the same way as I've 
18 
answered almost all of your other questions here 
19 
today. Upon advice of my counsel they've 
20 
instructed me to assert my Sixth, Fifth and 
21 
Fourteenth Amendment right. 
22 
Q Sir, have you ever been an owner, 
23 
shareholder, officer or director of the Gislaine 
24 
Corporation? 
25 
A Can you spell that? 
20 (Pages 409 to 412) 
U.S. Legal Support 
EFTA01103393