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495 
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Q Two answers ago I believe that you just 
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THE VIDEOGRAPHER: Back on the video 
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told us that you would like to tell the jury 
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record 2:30 p.m. 
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about the evidence that exists, that shows that 
3 
CROSS EXAMINATION (CONTINUED) 
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Jane Doe consented to or was a willing 
4 
BY MR. EDWARDS: 
5 
participant in the acts alleged. So, is there 
5 
Q Mr. Epstein, are you ready? 
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any evidence that you're aware of in existence in 
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A Yes. 
7 
this world that shows that Jane Doe consented to 
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Q The second affirmative defense indicates 
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the acts she alleged against you? 
8 
or says that Jane Doe "actually consented to and 
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MR. PIKE: Fenn. Also calls for work 
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participated in conduct similar and/or idealise] 
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product information? 
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to the acts alleged with other persons, which 
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A Unfortunately today I have to respond by 
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were the sole or contributing cause of Jane Doe's 
12. 
asserting my rights of Sixth, Fifth and 
12 
alleged damages." 
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Fourteenth Amendment. 
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What facts or information do you have to 
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THE VIDEOGRAPHER: Counsel? 
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support that affirmative defense? 
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MR. EDWARDS: Okay. 
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MR. PIKE: Form, May also call for work 
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THE VIDEOGRA.PHER: Going off the video 
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product information. 
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record 2:34 p.m. 
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A Though I would like to answer all your 
18 
(Pause in the proceedings.) 
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questions, Mr. Edwards, at least today counsel 
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(The deposition of Jeffrey Epstein is 
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advised me I must assert my rights under the 
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continued in Volume IV.) 
0 
Sixth, Fifth and Fourteenth Amendment. 
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1 
Q And when you say as an affirmative 
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2 
defense Jane Doe consented to and participated in 
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3 
conduct similar and/or identical to the acts 
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alleged, are you saying that at some other time 
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5 
Jane Doe was sexually molested by somebody of 
494 
496 
UNITED STATES DISTRICT COURT 
1 
similar or identical age to yourself? 
SDI:THE-RN DISTRICT OF FLORIDA 
2 
2 
MR. PIKE: Form. 
CASE NO. 04-CV-80.393-CIV-MARRAIJOHNSON 
3 
A I would like to answer all of your 
3 
4 
4 
questions with respect to Jane Doe and her 
JANE DOE. 
5 
complaints. However, at least today my counsel 
5 
6 
has advised me I must assert my rights under the 
Derma. 
6 
7 
Sixth, Fifth and Fourteenth Amendment. 
vs 
8 
Q The second part of that affirmative 
JEFFREY EPSTEIN. et al.. 
9 
defense indicates that that similar or identical 
a 
10 
conduct that Jane Doe allegedly participated in, 
9 
Defendants 
11 
was the sole or contributing cause of Jane Does 
/ 
12 
alleged damages. 
to 
Related Cases.
13 
Are you acknowledging that that conduct 
11 
0&80119.08-80232,08-80380, 0s-80381, 
14 
is likely to cause damages to a minor child such 
08-80994, 08-80811.08.80893.09.80469. 
15 
as Jane Doe? 
12 
094591.09-80656,09-80802.09-81092 
13 
VOLUME IV 
16 
MR, PIKE: Form. 
14 
CONTINUED VIDEOTAPED DEPOSITION OF 
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A I would like to answer all of your 
JEFFREY EPSTEIN TAKEN ON BEHALF OF THE PLAINTIFF 
1 5 
18 
questions with respect to Jane Doe and her 
16 
19 
complaints... complaint. However, at least today 
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ita 
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my counsel has advised me I must assert my rights 
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under the Sixth, Fifth and Fourteenth Amendment. 
20 
22 
Q Are you taking the position that Jane 
21 
DATE: April M.2010 
22 
23 
Doe's alleged damages were actually caused by a 
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separate or other child molester? 
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MR. PIKE: One second... object to the 
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font I think you need to reword the 
question. 
MR. EDWARDS: Okay. I'll ask it again. 
Q Is it your position, or do you have 
facts or information that Jane Doe was molested 
ti 
by a separate or different child molester? 
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MR. PIKE: Form. 
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A I would like to answer all your 
9 
questions that you posed here today, Mr. Edwards. 
every last one of them. However, at least today 
under advice of counsel, I have been instructed I 
must assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q The next affirmative defense indicates 
that Jane Doe impliedly consented to the ads 
alleged by not objecting. 
What do you mean by that affirmative 
defense? 
MR. PIKE: Form. 
A I would like it answer all your 
questions regarding Jane Doe, and her complaint. 
However, today my attorneys have advised me that 
I must assert my rights under the Sixth, Fifth 
and Fourteenth Amendment. 
Q Do you moan — 
belies ed or was told that the plaintiff, Jane 
2 
Doe, had attained the age of IS years old at the 
3 
time of the alleged acts." That is a false 
4 
statement, isn't it, Mr. Epstein? 
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MR. PIKE: Form. 
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A I would like to answer every question 
7 
you posed today, Mr. Edwards, about Jane Doe and 
8 
her complaint. However, at least today my 
9 
attorneys have advised me I must assert my rights 
10 
under the Sixth, Fifth and Fourteenth Amendment. 
Q What gave you the reasonable belief that 
Jane Doe was 18 years of age or older when you 
touched her In a sexual manner? 
MR. PIKE: Form. 
A I would like to answer all of your 
questions with respect to Jane Doe, Mr. Edwards, 
every one of them. However, today, as you're 
aware, my counsel has advised me I must assert my 
9 
rights under the Sixth, Fifth and Fourteenth 
0 
Amendment. 
1 
Q Didn't Jane Doe tell you when you asked 
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her age that she was 15 years old? 
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MR. PIKE: Form. 
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A I would like to answer that question 
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because I've answered most of your other 
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MR. PIKE: May also call for work 
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product information. Sony. 
Q Do you mean that, for instance, when you 
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would Insert your fingers Into her vagina when 
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she was 14 or 15 years old, that because she 
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didn't object that she impliedly consented to 
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that conduct? 
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MR. PIKE: Form. 
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A What's the question? 
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Q Do you mean by —I'll read your 
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affirmative defense that you have stated. 
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"PlaintiffJane Doe impliedly consented 
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to the acts alleged by not objecting," and I'm 
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asking: By that, do you mean that when you 
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inserted your fingers into her vagina when she 
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was age 14 or IS, that by her not verbally 
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objecting, then in your mind she consented? 
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MR. PIKE: Form. 
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A I would like to answer all your 
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questions Mr. Edwards. However, at least today, 
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at least today, my counsel instructed me I must 
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assert my rights under the Sixth, Fifth and 
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Fourteenth Amendment. 
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Q Your next affirmative defense states 
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that "Defendant," that being you, "reasonably 
500 
1 
questions here today. Unfortunately my counsel 
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here today said I must invoke my rights under the 
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Sixth, Fifth and Fourteenth Amendment. 
Q The second portion of that affirmative 
defense is that you reasonably believed or you 
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were told that Jane Doe attained the age of 18. 
Tell the jury, who told you that Jane 
Doe had attained the age of 18 years old when you 
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engaged in sexual conduct with her? 
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MR. PIKE: Form. 
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A Though I would like very much to answer 
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that question, as most of your other questions 
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here today, as you're aware my counsel has 
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advised me I must assert my rights under the 
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Sixth, Fifth and Fourteenth Amendment. 
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Q In fact, if you learned that she had 
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attained the age of 18 years old, you would not 
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have engaged in sexual conduct with her, would 
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you? 
MR. PIKE: Form. 
A 1 would hire to answer all of your 
questions with respect to lane Doe, Mr. FAwards. 
However, at least today, my counsel advised me 
that I must assert my rights under the Sixth, 
Fifth and Fourteenth Amendment. 
S 
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0 
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Q In fact, there were several times when 
girls were brought to you by other underage minor 
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females and these girls were over the age of 18 
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and you turned them away, as being too old for 
you; isn't that true? 
MR. PIKE: Form. 
A Again, I would like to answer all your 
questions here today. I would like to answer 
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that question. However, my counsel has advised 
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me that at least today I may not and must assen 
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my rights under the Sixth, Fifth and Fourteenth 
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Amendment. 
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Q In fact, your target age group for 
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sexual activity is between 12 rind 17 years old; 
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is that Inset 
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MR. PIKE: Form. 
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A Mr. Edwards, I would like to answer that 
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question, as well as your other questions here 
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today. However, my counsel has advised me that I 
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must not, may not, must assert my rights under 
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the Sixth, Fifth and Fourteenth Amendment. 
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Q You know a person named V.R., don't 
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you? 
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A Though I would like to answer all of 
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your questions Mr. Edwards, on advice of counsel 
1 
Q Isn't it true during that period of time 
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when V.R. was your underage sex slave, that she 
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observed you to have sexual intercourse and 
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sexual activity with several females, as young as 
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12 years old? 
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MR. PIKE: Form. 
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A I would like to respond to all of these 
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questions. And I prefer that your partner. Scott 
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Rothstein, who currently sits in jail for 
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fabricating cases of a sexual nature against 
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people like me and others, were here to hear some 
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of these answers. However, with respect to any 
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other question, at least today, my counsel has 
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advised me that I must assert my rights under the 
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Sixth, Fifth and Fourteenth Amendment. 
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Q Why would you prefer that Scott 
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Rothstein bear an answer from you about whether 
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or not you had sex with multiple 12 year olds? 
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MR. PIKE: Form. Move to strike, and 
r 0 
mischaracterizes the witness's testimony. 
r 1 
A At least today, Mr. Edwards, my counsel 
2 
has advised me that I must respond to these 
3 
questions by asserting my rights under the Sixth, 
4 
Fifth and Fourteenth Amendment 
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Q V.R. is somebody who has filed a lawsuit 
502 
today at least, they've instructed me that I must 
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respond by asserting my rights under the Sixth, 
3 
Fifth and Fourteenth Amendment. 
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Q V.R. is somebody who served as your sex 
5 
slave when she was between the ages of 15 and 18 
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years old; isn't that true? 
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MIL PIKE: Form. 
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A I would like to respond to all of your 
9 
questions with respect to V.R. However, on 
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advice of counsel today at least, they've 
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instructed me that I must assert my rights under 
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the Sixth, Fifth and Fourteenth Amendment. 
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Q Do you know Emmy Taylor? 
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A Though I would like to respond to all of 
15 
your questions here today, Mr. Edwards, under 
16 
advice of counsel I must assert my rights under 
17 
the Sixth, Fifth and Fourteenth Amendment. 
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Q Is that somebody who served as the sex 
19 
slave for Cislaine Maxwell at the same time or 
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about the same time that V.R. was your sex slave? 
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MR. PIKE: Form. 
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A I would like to answer all of your 
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questions, Mr. Edwards. However today my counsel 
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has advised me I must assert my rights under the 
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Sixth, Fifth and Fourteenth Amendment. 
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504 
1 
against you under the pseudonym Jane Doe number 
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102; isn't that correct? 
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MR. PIKE: I'm sorry. Can you repeat 
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it? 
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MR. EDWARDS: Sure. 
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Q V.R. is somebody that filed a lawsuit 
7 
against yon under the pseudonym Jane Doe number 
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102? 
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A Though I would like to respond to your 
0 
questions today, Mr. Edwards, with respect to 
1 
these lawsuits, my counsel has advised me that I 
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may not, and must assert my rights under the 
3 
Sixth, Fifth and Fourteenth Amendment 
Q In that complaint, the allegation is 
made that a friend of Jeffrey Epstein sent him 
three 12-year old girls from France, who spoke no 
English, for defendant Epstein to sexually 
exploit and abuse. After doing so, they were 
sent back to France the next day. 
That's a true statement, isn't it? 
MR. PIKE: Form. 
A I would like to respond to all of these 
questions... However, at least today, my counsel 
has advised me that I must assert my rights under 
the Sixth, Fifth and Fourteenth Amendment 
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Q In the complaint filed on behalf of Jane 
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Doc number 102 also known as V.R., was filed by 
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an attorney named Bob Josefsberg with Podhurst. 
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Orseck; isn't that right? 
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MR. PIKE: Can you reread that specific 
6 
question for me? 
7 
THE COURT REPORTER: Sure. 
8 
(Ile record was read.) 
MR. PIKE: To the extent you know the 
answer to that question, you can answer. 
A I think -- I'm going to assert my rights 
under the Sixth, Fifth and Fourteenth Amendment. 
Q And when I asked you a few questions 
back about your sexual Interaction and 
intercourse with I2-year old girls and derived 
that from this complaint, your answer — into 
your answer was injected some response related to 
Scott Rothstein, and so my question is, what do 
you believe, if anything, Scott Rothstein had to 
do with the complaints or assertions that are 
made in the Jane Doe 102 versus Epstein 
complaint? 
MR. PIKE: Form, move to strike. 
Mischaracterizes the witness's testimony. 
A I would like to answer that question. 
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Amendment right. 
MR. EDWARDS: Mark this. 
(Order form from Amazon.com, listing 
three books, was marked as Plaintiff's 
Exhibit number 9 for identification, as of 
this date.) 
MR. PIKE: (Handing to the witness.) 
Q Do you recognize that document that's 
been marked for identification purposes as 
Exhibit 9? 
A No. I do not. 
Q Did you indeed order the three books 
from Amazon.com that are listed on that order 
form that's been marked as Exhibit 9? 
A No. 
Q Have you read the three books that are 
on that order form, Exhibit number 9? 
A No. 
Q Do you know why it is, can you explain 
how that document came to exist? 
A No. 
Q Do you know where that document that 
you're holding marked as Exhibit number 9 came 
from? 
A No. 
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However, at least today they have instructed me 1 
1. 
must respond to that question by asserting my 
2 
Sixth, Filth and Fourteenth Amendment right. 
3 
Q Mr. Epstein, for at least the passed 
4 
decade you have consistently kept at least one 
5 
sex slave at all times. Is that true? 
6 
MR. PIKE: Form. 
7 
A I would like to respond to these 
8 
sexually charged questions. However, upon advice 
9 
of counsel, I must respond simply by asserting my 
r 0 
Sixth Amendment, Fifth Amendment and Fourteenth 
1 
Amendment right. 
s 2 
Q And you have an Amazon.com account, 
r 3 
right? 
4 
5 
have to assert my right to the Sixth Amendment, 
Fifth Amendment and Fourteenth Amendment. 
Q On or about September 4.2005 you 
MR. PIKE: Form. 
A Upon advice of counsel, I'm going to 
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7 
8 
9 
ordered and received -- and later received three 
books from Amazon.com; is that true? 
MR. PIKE: Form. Um... Books? 
... Form. 
A On advice of counsel I have to assert my 
Sixth Amendment, Filth Amendment and Fourteenth 
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4 
508 
Q Would you be surprised if it was taken 
from your trash by police or law enforcement? 
A Would I be surprised? I don't 
understand the question. 
Q Would it surprise you if the police 
pulled that from your trash, outside your house, 
in 2005? 
MR. PIKE: Object to the form. There, 
because... quite frankly, I don't know where 
this document came from. There has been no 
predicate laid as to its origination. Now 
you're talking about a question relative to. 
would it surprise you if the police pulled 
it... I don't think that you've laid the 
proper foundation, so I'm going to object to 
the form. 
MR. EDWARDS: Okay. At trial I'll enter 
it in through another witness. I just want 
him to deny him ever seeing it before I do 
that. It is fine, I'll lay the predicate —
MR PIKE: He's already said that,1 
believe, he never -- you asked him if he 
recognized the document and he said "No." 
MR. EDWARDS: I appreciate that. 
Q Would It surprise you if that was 
44 (Pages 505 to 508) 
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obtained from a trash pull at your house? 
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A You're asking me a hypothetical 
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question. I have no idea. 
4 
Q What is the name and address of the 
5 
purported purchaser of those books? According to 
6 
Exhibit number 9? 
7 
A I don't know. 
MR. PIKE: Form. 
Q Looking at that document you cannot tell 
what address those books were shipped to? 
A It says "billing address.' 
Q What's the billing address? 
A It says what the document says. 
Q What is that? 
A h says Jeffrey Epstein. 
Q What's the address? 
A 358 El Grillo Way. 
Q That address at 358 El Brill° Way is 
your address, correct? 
MR. PIKE: Form. 
A On advice of counsel. I'm going to have 
to assert my Fifth Amendment, Sixth Amendment and 
Fourteenth Amendment right. 
Q Jeffrey Epstein, that's your name, 
correct? 
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A I don't know. 
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Q Is there anybody else that lives in your 
3 
house, besides yourself, that has sex slaves? 
4 
MR. PIKE: I'm sorry... Mr. Horowitz, I 
5 
believe, interrupted you, I think he gave 
6 
you another exhibit, I think it's Exhibit 9, 
7 
which I think he wants you to follow up with 
B 
a question. 
MR. EDWARDS: It is just placed on the 
table. I'm waiting for an answer. 
MR. PIKE: I'm not being smarter. I'm 
just saying, are you going to follow through 
with the question that's currently on the 
table or the one that —
MR. EDWARDS: I asked a question and 
many waiting for an answer. 
MR. PIKE: Seriously, I'm not trying to 
be rude or smart. You put an exhibit in 
front of him and --
MR. HOROWITZ: I wanted to give the 
court reporter the exhibits. She gets the 
exhibits. 
MR. PIKE: I've got to know what 
question is on the table, that's all. 
MR. HOROWITZ: I didn't interrupt you, 
510 
1 
A Correct. 
2 
Q Can I see the document? 
3 
A (Handing to counsel.) 
4 
Q Mr. Epstein, the person whose deposition 
5 
6 
was taken yesterday and has been wkaile orted 
in the newspapers as your sex slave 
7 
is she indeed your sex slave? 
8 
. 
E: Form. 
A On advice of counsel, I'm going to 
0 
respond by asserting my Sixth Amendment, Fifth 
Amendment and Fourteenth Amendment right. 
Q Does anybody other than yourself have 
access to your Amazon.com account? 
MR. PIKE: Form. 
A I don't know. 
Q You have never read "Slave Craft, 
Roadmaps for Erotic Servitude, Principles, Skills 
and Tools"? 
MR. PIKE: Asked and answered. He was 
already asked these questions -- I'm sorry, 
answered. 
A I've answered the question "No." 
Q Why was it ordered to your house, the 
shipping address and billing address both being 
358 El Brine Way? 
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did l? 
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MR. EDWARDS: No, it is asked on --I 
3 
asked a question, it is still on the table. 
4 
A Ask the question. 
S 
Q Anybody else in your house have sex 
6 
slaves? 
7 
MR. PIKE: Form. 
8 
A I have to respond to that question as I 
9 
did to most of your other questions today, which 
0 
is l have to assert my rights to the Sixth, Fifth 
1 
and Fourteenth Amendment. 
2 
Q Art you familiar with the various 
3 
messages that are — that were taken from your 
4 
home at 358 El Brill° Way? 
5 
MR. PIKE: Form. 
6 
A I'm going to have to assert my rights 
under the Sixth, Fifth and Fourteenth Amendment. 
Q Have you read the messages that were 
taken and placed In the State Attorney's Office 
file related to the criminal charges against 
you? 
MR. PIKE: Fonn. 
A I don't recall. 
Q Why is it that underage minor females 
were calling your home in 2004 and 2005 for, In 
45 (Pages 509 to 512) 
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quotes, "work"? 
MR. PIKE: Wait a second. Form, lacks 
predicate, foundation, and for the record, 
you're referring to a stack of documents 
that have not been marked —
MR. EDWARDS: Not referring to anything. 
just so that your objection is clear. 
MR. PIKE: You're referring to what I 
see as a stack of documents that look like 
message pads. You're clarifying and... 
making a prelude into your question as to 
why were underage girls calling your home 
for work? 
MR. EDWARDS; Right. 
MR. PIKE: You're not allowing the 
witness to see the exhibits to which you 
refer, and I think it is an improper 
question and lacks predicate and 
foundation. 
MR. EDWARDS: No matter what I show the 
witness, any answer he gives is going to 
incriminate him, so he is going to invoke 
his Fifth Amendment rights, which is why 
right now, he is not going to see these. At 
trial he will see all of these things. 
514 
MR. PIKE: I'm glad you said that. I 
2 
think that's a false statement. I move to 
3 
strike it. Mr. Edwards, you provided a 
4 
document to Mr. Epstein not two minutes ago 
5 
and he answered questions without invoking 
the Fifth Amendment right. 
MR. EDWARDS: And it incriminated him. 
MR. PIKE: If the Fifth Amendment comes 
into play. 
MR. EDWARDS: It should have. 
MR. PIKE: Thank you. If the Fifth 
Amendment comes into play, he will invoke 
the Fifth. He does not know certain 
information. Not knowing something, my 
friend, is not a waiver. Follow? So he is 
trying to --
MR. EDWARDS: It is —
MR. PIKE: -- trying to actually work 
with you on your questions. Maybe if you 
show him what you're talking about he can 
answer your question. 
Q Why were underage minor females calling 
your house to, quote, unquote. "work"? 
MR. PIKE: Form. 
A Unfortunately, I have to answer that 
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question, as I've answered most of your other 
questions here today, Mr. Edwards, which is that 
my attorneys advised me to assert my Sixth 
Amendment, Fifth Amendment and Fourteenth 
Amendment right. 
i
t Do you know 
A As Eve answered most of your other 
questions hem today, I'm going to have to 
respond that my attorneys have instructed me to 
assert my rights to the Sixth, Fifth and 
Fourteenth Amendment. 
Q That's somebody who is listed in the 
agreement between yourself and the United States 
of America as a coconspirator of yours. Does 
that help refresh your recollection as to who Ms. 
a
s?
MR. PIKE: Fr. 
A I'm going to have to respond by 
asserting my rights to the Sbcth, Fifth and 
Founeenth Amendment. 
Q Do you remember receiving messages from 
Adrian that would read something like, "I left a 
mesas e for 
to confirm for 11:00 o'clock 
and 
or 4:30," many messages like that? 
516 
1 
MR. PIKE: I'm sorry, but before he 
2 
answers, I'm just curious, you're again 
3 
referring to a stack of documents that's 
4 
about an inch thick. Do you want to mark 
5 
anything as an exhibit? 
6 
MR. EDWARDS: No, I really don't, Mike, 
7 
but appreciate all the help you're 
8 
providing. Thanks. 
9 
MR. PIKE: Yeah. You're welcome. Do 
0 
you know where these documents came from? 
1 
MR. EDWARDS: Yes. 
2 
MR. PIKE: Where did you obtain that 
3 
them from? 
4 
MR. EDWARDS: It is not my deposition. 
5 
You had that chance already. 
6 
MR. PIKE: No, I asked the right -- no, 
7 
that's not really part of my case over 
8 
there. Critton took your deposition, not 
9 
me. That's a case separate and distinct 
0 
from these cases, so my question to you is: 
1 
Pin just curious, you have a stack of 
2 
documents, I think you said earlier they 
3 
came from the State Attorney's Office file? 
4 
MR. EDWARDS: It is not my deposition. 
I'm asking questions. Your client is going 
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left message for 
o'clock and Mfor 
4:30"? 
A I don't recall. 
Q And when a message such as that is left, 
is that Indicating .= 
is going to come to 
your house for you to molest her at 11:00 and 
will come for you to molest her at 4:30? 
MR. PIKE: Form. 
A I'm going to have to respond by 
asserting my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Why would underage minor females call 
your home and leave messages like, "I have a girl 
for him." Do you know? 
MR. PIKE: Form. 
A On advice of my counsel, today at least, 
to give answers or not give answers. 
MR. PIKE: Okay. 
MR. EDWARDS: These will come in with 
the appropriate person at trial, period. 
MR. PIKE: Okay. 
A Question? Sony. 
Q Sure. 
Do you remember receiving a message from 
, such as, "I 
to confirm for I1:00 
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Q In a newspaper article dated October 30, 
2006 entitled, "The Return Of A," In quotes, 
'Very Passionate' end quote, "Jeffrey Epstein," 
there is a quote from somebody that is called in 
this article "A Friend," and the quote is: 
"Speaking about Jeffrey Epstein, his life Is 
about making money and living an erotic life and 
his escape isn't alcohol or drugs, it is sex." 
Is that a true statement? 
MR. PIKE: Form. 
A Is it a true statement that that's what 
the article says? 
Q No, is it a true statement that your 
life is about making money and living an erotic 
life and your escape is not alcohol or drugs, it 
Is sex? 
MIL PIKE: Form. 
A Though I would like to answer that 
question, as well as all your other questions 
posed here today, Mr. Edwards, on advice of my 
counsel, he has instructed me I must assert my 
rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q Another article entitled "The 
Fanaticist," from New York Magazine dated 
518 
1 
they've advised me I must assert my right under 
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the Sixth, Fifth and Fourteenth Amendment 
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Q Did you ever employ any underage minor 
1 
females for any legitimate purpose at your home, 
5 
358 El Brillo Way? 
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MIL PIKE: Form. 
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A At least today, Mr. Edwards, though I 
8 
would like to answer every one of your... 
questions, my counsel has advised me I must 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Isn't it true, Mr. Epstein, that each 
underage minor female that contacted — that 
called your home or was called from your home, 
was called for the purposes of coming to your 
house to satisfy you sexually? 
MIL PIKE: Form. 
THE WITNESS: I think Eve answered that 
question before. 
A I will answer it unfortunately the same 
way, which is although I would like to answer 
each and every one of the questions you've posed 
here today, on advice of my counsel they've 
instructed me I must assert my rights under the 
Sixth, Fifth and Fourteenth Amendment. 
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520 
December 10, 2007, a quote or several quotes arc 
attributed to you, and it reads: "I told 
Epstein," this is the author "and Rubenstein the 
sort of story New York Magazine wanted to do, and 
Epstein seemed to find ironic delight in every 
word. A secretive genius, I said," a statement 
from the author. "She indicates you corrected 
her saying "Not secretive, private," and the next 
quote, which I will ask you about, is that you 
stated "And If I was a genius, l wouldn't be 
sitting here, a gay with sex issues;" do you 
remember saying that? 
MR. PIKE: Form. 
Q 
to a reporter In New York? 
MR. PIKE: Form. Move to strike. 
A Though I would like to answer every 
question you've posed here today, Mr. Edwards, on 
advice of counsel I have to assert my Sixth 
Amendment, Fifth Amendment and Fourteenth 
Amendment right. 
MR. PIKE: Mr. Edwards, if you would, I 
know you — 
THE WITNESS: Take a break? 
MR. PIKE: Actually one second. 
You provided the title of the second 
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article that you just questioned him. Could 
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you please, for the record, provide the 
title to the first article. 
MR. EDWARDS: I did. 
MR. PIKE: I didn't hear it. 
MR. EDWARDS: I will do it again. "A 
Rehm, Of A 'Very Passionate Jeffrey 
Epstein.' 
MR. PIKE: Thank you. 
MR. EDWARDS: "Very passionate" is in 
quotes, as I said the first time. 
MR. PIKE: Thank you. 
THE VIDEOGRAPHER: Going off the video 
record 3:02 p.m. 
(Pause in the proceedings.) 
THE VIDEOGRAPHER: Back on the video 
record at 3:15 p.m. 
Q In the same ankle, "The Fanaticist," 
there is a quote by "Michael Wolff." Do you know 
Michael Wolff, the columnist? 
A I have to respond the same way I've 
responded to most of your questions here today, 
which is, I must assert my rights under the 
Sixth, Filth and Fourteenth Amendment. 
Q Mr. Wolff says in a quote In this 
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to be ridiculous. You can't read —
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MR. EDWARDS: What 
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MR. PIKE: You can't read someone else's 
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quote and say "Are you admitting something 
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from someone else's quote.' He didn't make 
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the quote, so how can it be an admission, 
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despite who it is. 
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MR. HOROWITZ: That's a form objection. 
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MR. PIKE: You're right, form. 
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Q Your attorney, Jack Goldberger, made the 
1 
statement, "Jeffrey Epstein never denied the 
12 
girls came to the house." This was related to 
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the criminal investigation of you. 
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Do you admit thnt the girls, 
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specifically Jane Doe, came to your house? 
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A Mr. Edwards, l would like to respond to 
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that question as I responded to most of the other 
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questions today, but unfortunately my counsel has 
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advised me I must assert my rights under the 
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Sixth, Fifth and Fourteenth Amendment. 
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Q Mr. Epstein, can you tell the jury who 
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MEMMIMMW 
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MR. PIKE: Form. 
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A Unfortunately, Mr. Edwards, I have to 
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respond to that question as I responded to moat 
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article, "Ile has never," speaking about Mr. 
2 
Epstein, "been secretive about the girls. At one 
3 
point when his troubles began he was talking to 
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me and said, 'What can I say? I like young 
o 
girls." Is that a comment or statement that you 
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made to Michael Wolff? 
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MR. PIKE: Form. 
8 
A Unfortunately I have to respond to that 
question as I did to most of your questions 
today, which is I must assert my rights under 
advice of counsel, under the Sixth, Fifth and 
Fourteenth Amendment. 
Q On several occasions your attorney or 
one of your attorneys, Jack Goldberger, has made 
the statement "Jeffrey Epstein has never denied 
that the girls came to the house." Arc you 
admitting that the girls that are now plaintiffs, 
at least came to your house? 
MR. PIKE: Form. 
A I would like to answer that question 
you've just quoted an attorney's statement? 
Q Right, Jack Goldberger's statement. 
A So what's the question? 
MR. PIKE: You can't — hold on right 
there. This is ridicubus. This Ls getting 
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of your other questions today, because on advice 
2 
of counsel they've instructed me to assert my 
3 
rights under the Sixth, Fifth and Fourteenth 
4 
Amendment. 
5 
Q You're aware that she is somebody listed 
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as a eo-conspirator of yours related to your 
criminal activity in the Nonprosecution 
Agreement, correct? 
MR. PIKE: Fenn. 
A With respect to that question as most of 
your other questions here today, on advice of 
counsel I have been instructed to assert my 
rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q Isn't it true that you paid her to have 
underage minor females brought to your house, at 
specific times, as you directed? 
MR. PIKE: Form, asked and answered. 
A As I've answered most of your questions 
here today, unfortunately my counsel has advised 
me that I must assert my rights under the Sixth, 
Fifth and Fourteenth Amendment. 
Q Another co-conspirator of yours, as she 
Is labeled in the Nooprosecution Agreement, is 
Lesley Groff. What role did she play or what did 
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she conspire with you to do? 
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MR. PIKE: Form. 
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A Mr. Edwards, I have to respond to that 
4 
question as I did to most of your other questions 
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here today, which is, on advice of counsel, 
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they've instructed me to assert my rights under 
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the Sixth, Fifth and Fourteenth Amendment. 
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Q Today what role does Story Cowles play 
in your life? 
MR. PIKE: Form. 
A I would like to answer all your 
questions, Mr. Edwards. However, at least today, 
my counsel has advised me that I must assert my 
rights under the Sixth, Filth and Fourteenth 
Amendment. 
Q Is Story Cowles your personal 
assistant? 
MR. PIKE: Form. 
A Mr. Edwards, I would like to answer all 
your questions here today. However, upon advice 
of counsel, they've instructed me that I must 
assert my Fifth, Sixth and Fourteenth Amendment 
rights to that question. 
Q And Story Cowles, in addition to being 
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your personal assistant, 
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underage minor females in the communities 
surrounding each of your homes? 
MR. PIKE: Form. 
A Though I would like to answer each and 
every one of your questions, Mr. Edwards, my 
attorneys have advised me at least today, at 
least today, that I may not. I must assert my 
rights as provided by the Sixth. Fifth and 
Fourteenth Amendment. 
Q Isn't it true that within that computer 
system were the names and telephone numbers of 
hundreds of underage minor females that you 
sexually molested? 
MR. PIKE: Form. 
A I would like to answer every one of your 
questions today, Mr. Edwards. However, upon 
advice of counsel I must assert my rights as 
protected by the Sixth. Fifth and Fourteenth 
Amendment. 
Q Can you explain to the jury what 
Gislaine Maxwell's role was in helping you to 
access underage minors? 
MR. PIKE: Form, assumes facts not in 
evidence. 
A You know I would like to answer each and 
526 
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boyfriend; is that true? 
2 
MR. PIKE: Form. 
3 
A Though I would like to answer all your 
4 
questions, Mr. Edwards, on advice of counsel 
5 
they've instructed me that I must assert my 
6 
rights under the Sixth, Fifth and Fourteenth 
7 
Amendment. 
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Q Prior to the police executing, the Palm 
Beach police executing a search warrant on your 
house in October of 2005, did you direct 
to remove at least three computers from 
your home? 
MR. PIKE: Form. 
A Though I would like to answer all your 
questions, Mr. Edwards, my attorneys at least 
today have advised me I must assert my rights 
under the Sixth, Fifth and Fourteenth Amendment. 
Q Where arc those computers today? 
MR. PIKE: Form. 
A Though I would like to answer all your 
questions, my attorneys have advised me I must 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Isn't it true that those computers 
contain the names and telephone numbers of 
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every one of your questions posed here today, Mr. 
Edwards. Unfortunately I have to answer that 
question on advice of counsel by invoking my 
rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q Do you have any remorse for sexually 
molesting Jane Doe? 
MR. PIKE: Form, argumentative. 
A I would like to answer every one of your 
questions regarding Jane Doe. However, at least 
today, my counsel has instructed me to assert my 
rights as protected by the Sixth, Fifth and 
Fourteenth Amendment. 
Q When is the last time that you visited 
your island, Little St. James? 
MR. PIKE: Form. 
A Though I would like to answer all your 
questions, Mr. Edwards, my counsel advised me I 
must assert my rights as protected by the Sixth, 
Fifth and Fourteenth Amendment. 
Q Has any court given you permission to go 
to your island or the Virgin Islands while you 
have been on house arrest? 
MR. PIKE: Form. 
A Mr. Edwards, though I would like to 
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answer all your questions, my counsel has advised 
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me that I must assert my rights protected by the 
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Sixth, Fifth and Fourteenth Amendment. 
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Q Have you interacted sexually with 
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underage minors since beginning your house arrest 
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or community control? 
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MR. PIKE: Fonn. 
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A Though I would like to answer each and 
every one of your questions posed here today, my 
counsel has advised me that I must assert my 
rights protected by the Sixth, Fifth and 
Fourteenth Amendment. 
Q Mr. Epstein, is it your intention to 
testify in the trial of Jane Doe versus Jeffrey 
Epstein? 
MR. PIKE: Object to the form. It may 
disclose attorney/client work product 
information. I instruct him not to answer. 
Q Does Story Cowles work for you at 
Florida Science Foundation? 
MR. PIKE: Form. 
A Though I would like to answer each and 
every one of your questions, Mr. Edwards, at 
least today my counsel has advised melmust 
Essen my rights as protected by the Sixth, Fifth 
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MS. EZELL: Okay. I can begin. Are we 
ending at 4:00? 
MR. PIKE: Yes, we we ending at 4:00. 
CROSS EXAMINATION 
BY MS. FIN I" 
MS Fin I • Let the mond reflect that 
I have 3:22 right now. 
Q Mr. Epstein. good afternoon. 
A Good afternoon. 
Q You were previously deposed by Mr. 
Horowitz on Monday, March 8th of this year. You 
were asked with respect to Jane Doe 103. "Do you 
acknowledge that she's been to your home?" There 
was a form objection and your answer was, "Again 
I would like to answer most of your questions. 
However, today as Fre answered most, almost all 
of your questions and will continue to answer on 
advice of counsel, I believe, this question, I 
have to assert my Fifth Amendment, Fourteenth 
Amendment and Sixth Amendment rights under the 
U.S. Constitution." 
If you were asked the same question 
today, what would your answer be? That question 
was: "Do you acknowledge that Jane Doe 103 has 
been to your home"? 
530 
and Fourteenth Amendment. 
2 
Q Is it your intent in the future to 
3 
engage In sexual activity with underage minor 
children? 
5 
MR. PIKE: Form. 
6 
A I would like to answer each one of those 
7 
questions, Mr. Edwards. However, today my 
8 
counsel has advised me I must assert my rights 
9 
protected by the Sixth, Fifth and Fourteenth 
Amendment. 
Q When you give that answer, that you 
would like to respond to each one of my 
questions, would it then be your preference to 
explain to the jury why it is that you feel 
entitled to sexually molest underage minor 
children? 
MR. PIKE: Form, move to strike. 
Miseharacterizes the witness's testimony. 
A Unfortunately I would like to answer 
that question as well, but my counsel has advised 
me that I must assert my rights as protected by 
the Sixth, Fifth and Fourteenth Amendment. 
MR. EDWARDS: I don't have anything 
Amber. 
MR. PIKE: Ms. Ezell? 
532 
1 
A Please tell me who lane Doe 103 is. 
2 
Q Jane Doe 103 is Jane Doe 103. 
3 
A I would like to answer the question so 
4 
the answer would be the same. 
5 
MR. PIKE: By "answering that question," 
6 
you're invoking Fifth. Sixth and 
7 
Fourteenth? 
B 
THE WITNESS: Yes. 
9 
MR. PIKE: Please do so. 
10 
A I'm invoking my Sixth Amendment, Fifth 
11 
Amendment and Fourteenth Amendment right. 
12 
Q You were then asked "Do you acknowledge 
13 
that Jane Doe 103 came to your home for sexual 
14 
contact during her childhood and that you paid 
15 
her for those services?" 
16 
Mr. Pike said "Form, predicate, 
17 
foundation, argumentative," and your response was 
18 
"I would like to answer that question. I think 
19 
those questions will all have obvious answers. 
20 
and not -- however, today I'm going to have to 
21 
assert my Filth Amendment, Sixth Amendment and 
22 
Fourteenth Amendment rights under the U.S. 
23 
Constitution, because I would like to answer that 
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question, my attorneys have advised me that I 
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cannot today, cannot answer any question that may 
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be relevant to this lawsuit." 
2 
If you were asked that same question 
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today, would your answer be the same? 
4 
MR. PIKE: I'm going to object. Form. 
5 
and I instruct you if your answer is the 
6 
same, please tell Ms. Ezell that. 
7 
A My answer is the same, invoking my right 
8 
under the Sixth, Fifth and Fourteenth Amendment 
9 
Q So, it wasn't just that that day you 
10 
were Instructed not to answer the question, but 
11 
here, five weeks later, today, you also, today, 
12 
can't answer those questions, correct? 
13 
MR. PIKE: Asked and answered. 
14 
A I'm going to, on advice of counsel, Ms. 
15 
Ezell, respectfully assert my rights as protected 
16 
by the Sixth, Fifth and Fourteenth Amendment 
17 
Q Later Mr. Horowitz said, "Sir, are you 
18 
asserting your Sixth, Fifth and Fourteenth 
19 
Amendment privileges because you're innocent? Is 
20 
that what you're telling us?" 
21 
You said "Today on advice of counsel 1 
22 
cannot answer your questions, any of your 
23 
questions that may be relevant to this lawsuit" 
24 
MR. PIKE: Form. 
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Q What would your answer be today to that 
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could answer those questions." 
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can you answer that question today? 
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MR. PIKE: Form. 
4 
A Ma'am, unfortunately In going to have 
5 
to invoke my Sixth Amendment, Fifth and 
6 
Fourteenth Amendment right to that question. 
7 
Q Then you were asked --
8 
THE WITNESS: Can we go off the record 
for a second? 
THE VIDEOGRAPHER: Off the video record 
3:32 p.m. 
THE WITNESS: Just two minutes. 
MR. EDWARDS: For what? We are all 
going to have a discussion off the record? 
MR. PIKE: I think my client wants to 
speak with me. 
MR. EDWARDS: Okay. 
MR. PIKE: Are you okay with that Ms. 
Ezell? 
MS. EZELL: Yes. 
MR. PIKE: Off the record. 
(Pause in the proceedings.) 
THE VIDEOGRAPHER: --
THE WITNESS: Sony, go ahead. 
THE VIDEOGRAPHER: Back on the video 
534 
1 
question? 
2 
MR. PIKE: Same objection. 
3 
A On advice of counsel, with respect to 
4 
that question, 
going to have to assert my 
5 
rights as protected by the Sixth, Fifth and 
6 
Fourteenth Amendment 
7 
Q So again, your answer wasn't just that 
8 
answer then, five weeks ago, but today, you again 
9 
cannot answer on advice of counsel, correct? 
MR. PIKE: Move to strike. 
Mischaracterization. Plaintiff has 
invoked — sorry, defendant has invoked 
Fifth, Sixth and Fourteenth. That's his 
answer. 
MS. EZELL: So he invokes them today, as 
well? 
MR. PIKE: Yes, ma'am. 
Q Mr. Horowitz asked "Between 2005 and 
2006, did your sexual interests include digitally 
penetrating the vaginas of girls between the ages 
of 12 and 17?" 
Mr. Pike objected "Form," and you said, 
"1 find these questions — I would like to 
answer every one of those questions. However, my 
counsel has told me I may not today. I wish I 
536 
1 
record 3:33 pm 
2 
Q Later in that same deposition, Mr. 
3 
Horowitz asked "Did you have surveillance cameras 
4 
la either the interior or exterior of your home 
5 
at El Brillo Way between 2001 and 2006?" 
6 
You answered, "Mr. Horowitz, I'm going 
7 
to answer that question the same way as I've 
8 
answered most of your other questions here 
9 
today. I would like to answer each one of your 
10 
questions regarding your clients with great 
11 
specificity, however my counsel has advised me 
12 
that I may not today, and therefore have to 
13 
invoke my Fourteenth Amendment rights, my Sixth 
14 
Amendment rights and my Fifth Amendment rights as 
15 
provided by the U.S. Constitution." 
16 
So what about today? Can you answer 
17 
that question form today? 
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MR. PIKE: Object to the form. 
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A Unfortunately, Ms. Ezell Mrs. Ezell, 
20 
I'm sorry. 
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Q Ms. Is fine. 
22 
A Okay. Ms. Ezell. Unfortunately on 
23 
advise of counsel, I have to amen my rights as 
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protected by the Sixth, Fifth and Fourteenth 
25 
Amendment 
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MR. PIKE: And Ms. Ezell, let me caution 
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you that I've listened to several of your 
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questions. The first one being a repetition 
4 
of Mr. Horowitz's question approximately 
four weeks ago dealing with your client 103, 
6 
so I did not have a problem with that 
7 
background information being repeated. 
8 
However, it seems that the questions that 
9 
you're discussing now and going over are 
10 
just a repetition of Mr. Horowitz's 
11 
background information, which has already 
12 
been established and really has no relation, 
13 
in my opinion, to your particular clients. 
14 
Given the fact we arc here today, Mr. 
15 
Horowitz has taken the liberty of concluding 
16 
his deposition, obviously with rebuttal 
17 
available, same with Mr. Edwards, I would 
18 
ask, rather than to have to seek assistance 
19 
of the Court, that your questions be 
20 
tailored toward your client. 
21 
MS. EZELL: Mr. Pike, I would beg to 
22 
differ with you. Questions regarding his 
23 
sexual interests, including digitally 
24 
penetrating vaginas of girls between ages of 
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12 and 17 certainly pertain to my client. 
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539 
MR. HOROWITZ: I join in Ms. Ezell's 
comments. 
MR. EDWARDS: Agreed. 
MR. PIKE: Thank you. Three against 
one. Nonetheless, again, I hold steadfast 
the same argument. It is repetitious and 
whether or not — he is not going to waive 
Fifth, Sixth and Fourteenth yesterday and he 
is not going to waive it today, so... 
MS. EZELL: That's fine. My objection 
to that is that it is misleading for him to 
say that "Today I have been instructed not 
to answer it," because then I come here 
hoping five weeks later I may get an answer, 
and unfortunately that's not been the case. 
We have had the same invocation of the 
privileges today, only today, just for 
today. 
MR. PIKE: Well, I --
MS. EZELL: I'm done with that line of 
questioning. 
MR. PIKE: Okay. 
MS. EZELL: But I think I had the right 
to ask. 
MR. PIKE: Thank you. 
538 
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MR. PIKE: Ms. Ezell, you were at that 
2 
deposition. You cross-noticed that 
3 
deposition and these cases have been 
4 
consolidated for discovery, and you have not 
5 
formed, with the exception of one question, 
6 
since you commenced your portion of the 
7 
depo, you have not formed one question 
8 
relative to your particular client. 
You just asked a general question that 
had already been asked by Mr. Horowitz who 
commenced the Volume I of this Volume III or 
IV continuation of the deposition. If you 
want to tailor these questions to your 
client, I have no problem with that, but to 
ask the same exact question Mr. Horowitz 
asked who commenced the deposition is a 
waste of time. 
MS. EZELL: That may be your opinion, 
Mr. Pike, but I believe I have, particularly 
in the way these questions were answered 
five weeks ago, that today, that day he was 
unable to answer because of advice of 
counsel. I certainly have the right to ask 
him whether this day, five weeks later, he 
can answer that question. 
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MS. EZELL: Thank you. 
Q Mr. Epstein, are you a citizen of the 
United States? 
A Yes. 
Q And are you a citizen of the United 
States Virgin Islands? 
A I don't know what that means. 
Q Of what State or territory of the United 
States are you a citizen? 
A I'm a citizen of the United States. 
Q And of what State or territory in the 
United States do you claim to be a citizen? 
A I'm a citizen of the United States. 
Q Where do you vote? 
A I vote in the Virgin Islands. 
Q Where do you pay your taxes? 
MR. PIKE: Form. 
A On advice of counsel, I'm going to have 
to assert my rights as protected by the Sixth, 
Fifth and Fourteenth Amendment. 
Q And I would Just note that your tax 
returns are public documents available to the 
government, and there is no -- no risk of 
incriminating yourself with such a document. Do 
you still maintain the same objection? 
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543 
MR. PIKE: He does, and that calls for a 
2 
legal conclusion, which currently is, I 
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think, under -- it was under appeal and now 
4 
it is back under appeal. 
5 
Q Before serving your jail time in Palm 
6 
Beach County, followed by your community control 
7 
time, was your principal place of residence the 
dwelling in Manhattan? 
9 
A The what? 
10 
Q Your mansion in Manhattan? 
11 
MR. PIKE: Form. 
12 
A Pm sorry, but at least today, I would 
13 
like to answer all your questions, Ms. Ezell. 
14 
However, on advice of counsel I will have to 
15 
respond by invoking my Sixth, Fifth and 
16 
Fourteenth Amendment 
17 
Q I won't repeat the same questions 
18 
regarding the plan or scheme. I'll try not to, 
19 
that have already been covered today. To the 
20 
extent that they didn't just apply to that one 
21 
plaintiff, in most instances, I believe that Mr. 
22 
Edwards said, "young women" or "young girls like 
23 
or including Jane Doe," but there were a few 
24 
additional questions in that area I wanted to 
25 
ask. 
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who came to your home to provide massages and 
2 
other sexual gratification for you, were they 
3 
often transported by 
other 
4 
assistants that you employed? 
5 
MR. PIKE: Form. 
6 
A Though 1 would like to answer each and 
7 
every one of your questions, Ms. Ezell, I 
8 
respectfully must decline. On advice of counsel 
they've instructed me I must assert my rights 
protected by the Sixth. Fifth and Fourteenth 
Amendment. 
Q Would you acknowledge, Mr. Epstein. that 
once the girls were there, beginning with their 
first experience, their first visit, there was a 
sort of a ritual that was followed in regard to 
how they were treated, what they were asked to do 
and what occurred? 
MR. PIKE: I'm sorry, I didn't know if 
that was the question. 
MS. EZELL: It is a question. 
THE WITNESS: What's the question? 
MR. PIKE: What is the question? 
Q From the first visit a girl might make 
to your home, was there a ritual or routine that 
was followed with regard to what happened during 
542 
Within that arrangement whereby girls 
2 
would come or be brought to your home to provide 
3 
massages and other sexual gratification for you, 
4 
were they often brought by taxis that were paid 
5 
for by you or by someone on your behalf? 
6 
MR. PIKE: Form. 
A Though I would like to answer all your 
questions today, Ms. Ezell, Ism going to have to 
9 
respond to that question as I've responded to 
10 
most of your other questions, which is, on advice 
11 
of counsel, at least today, they've instructed me 
12 
to assert my rights as protected by the Sixth, 
13 
Fifth and Fourteenth Amendment 
14 
Q Also, within that same scheme, were 
15 
these girls sometimes transported to or from your 
16 
house by the current houseman employed by you at 
17 
that time? 
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MR. PIKE: Form. 
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A Though I would like to answer all your 
20 
questions, Ms. Ezell, that question as well as 
21 
the others, I must unfortunately at least today, 
22 
on advice of counsel, invoke my Sixth Amendment, 
23 
Fifth Amendment and Fourteenth Amendment right. 
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Q And again following with that plan as 
25 
discussed previously, were those same young women 
544 
1 
that visit? 
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MR. PIKE: Form. 
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A Ms. Ezell, I would like it answer all 
4 
your questions that you posed here today, but I 
5 
will have to respond unfortunately, as I've 
6 
responded to most of the others which is, my 
7 
counsel advised me I must respond by invoking my 
8 
Sixth, Fifth and Fourteenth Amendment. 
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Q For instance, in addition to the other 
10 
things that Mr. Edwards and Mr. Horowitz asked 
11 
about, within the same area, would Ms. 
Or 
12 
one of your other assistants usually go up and 
13 
lay out the towels and particular massage oils 
14 
that you like? 
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MR. PIKE: Form. 
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A Ms. Ezell. unfortunately I have to 
17 
answer that question as I've answered most of 
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your other questions here today, respectfully 
19 
decline to answer on advice of counsel who's 
20 
asked me to invoke my Sixth Amendment, Fifth 
21 
Amendment and Fourteenth Amendment right. 
22 
Q Was it more or less routine that when a 
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girl would come for the first time, that she 
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would be accompanied to the massage area by 
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another woman or girl? 
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MR. PIKE: Form. 
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A Ms. Ezell, I have to answer that 
3 
question as I answered most of your other 
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questions today, which is on advice of counsel, I 
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have to asses my rights as protected by the 
6 
Sixth, Fifth and Fourteenth Amendment. 
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Q Did it occur quite often that 
8 
would lead the girl up and introduce you 
9 
to her and then quietly leave? 
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MR. PIKE: Form. 
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A Ma'am, I'm going to respectfully have to 
12 
decline to answer that question today on advice 
13 
of counsel. They've asked me to assert my rights 
14 
as protected by the Sixth, Fifth and Fourteenth 
15 
Amendment. I would like to answer each and every 
16 
one of your questions. 
17 
Q Dld it also occur sometime that the girl 
18 
would be accompanied by the girl who brought her, 
19 
and the girl who brought her would go up to your 
20 
bedroom and massage am with her, on her initial 
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visit? 
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MR. PIKE: Form. 
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A Again? Can you -- what's the question? 
24 
Q I'm asking about whether or not there 
25 
was a sort of routine that was followed when the 
546 
1 
girls would come to your home to provide the 
2 
massages and other sexual gratification for you. 
3 
I'm asking whether or not part of that routine 
4 
was that they would be accompanied by the girl 
5 
who brought them? 
6 
MR. PIKE: Form. 
7 
A I'm going to have to, on advice of 
8 
counsel, answer that question by asserting my 
rights as protected by the Sixth, Fifth and 
Fourteenth Amendment. 
Q If they were accompanied by the girl who 
brought them, would it be your usual practice to 
allow them to start the massage and then excuse 
the girl who had brought the second girl for her 
first visit? 
MR. PIKE: Form. 
A I'm going to do my best to respond to 
these questions, but my counsel has advised me 
that I must assert my rights as protected by the 
Sixth, Fifth and Fourteenth Amendment. Ms. Ezell, 
so I respectfully must decline. 
Q Did you have a routine way that you 
liked the massage itself to be conducted? 
MR. PIKE: Form. 
A Ms. Ezell, I'm going to have to 
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respectfully decline to answer that question, on 
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advice of counsel, they've asked me to assert my 
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rights as protected by the Sixth. Fifth and 
4 
Fourteenth Amendment. 
5 
Q Did either Ms. 
or you, or the 
6 
girl who perhaps had been there before Instruct 
7 
the new girl to begin by massaging the back of 
8 
your legs and your back? 
MR. PIKE: Form. 
A I would like to respond to all your 
questions. but unfortunately at least today, my 
counsel has advised me I must assert my rights as 
protected by the Sixth, Fifth and Fourteenth 
Amendment. 
Q And did you or Ms,Mgenerally ask 
the girls or instruct the girls to remove their 
clothing? 
MR. PIKE: Form. 
A Unfortunately, Ms. Ezell I have to 
respectfully decline to answer that question 
today. On advice of counsel, they've asked me to 
assert my Sixth Amendment, Fifth Amendment and 
Fourteenth Amendment right. 
Q After having the back of your legs —
the feet, the back of your legs and your back 
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548 
massaged, would you then typically turn over, 
exposing yourself, laying on your back? 
MR. PIKE: Form. 
A Ms. Ezell, I'm going to respectfully 
have to decline to answer that question today, 
because my counsel has asked me to assert my 
Sixth Amendment, Fifth Amendment and Fourteenth 
Amendment right, though I would like to answer 
every one of your questions. 
Q Would it be your practice at that point, 
depending on the skittishness of the girl to 
begin trying to fondle her breasts or rub her 
vagina? 
MIL. PIKE: Form. 
A Ma'am, I respectfully have to decline to 
answer that today, though I would like to answer 
each one of these questions. My counsel has 
instructed me to assert my Sixth Amendment, Fifth 
Amendment and Fourteenth Amendment right. 
Q Assuming the girl was ill at ease, would 
it be your practice to then talk with her to try 
to elicit from her, her interests, her goals, the 
things that were important to her in her life? 
MR. PIKE: Form. 
Q Was that part of your routine? 
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MR. PIKE: Sony. Form. 
A Ma'am, though I would like to answer 
every one of your questions today, unfortunately 
my counsel has advised me I must assert my rights 
as protected by the Sixth, Fifth and Fourteenth 
Amendment. 
Q Would it generally be your practice, if 
the girl was skittish, to perhaps wait until the 
second visit to introduce a vibrator into the 
routine? 
MR. PIKE: Form. 
A Ms. Ezell. unfortunately I have to 
answer that question the same way as I've 
answered every one of your questions today, which 
is, I would have to assert my rights protected by 
the Sixth, Fifth and Fourteenth Amendment on 
advice of counsel. 
Q Would you try to calm the girl by 
telling her to relax, that there was nothing 
wrong with what was going on? 
MR. PIKE: Form. 
A Ma'am, unfortunately I have to respond 
to that question as I've responded to most of 
your other questions here today, which is by 
invoking my Sixth Amendment, Fifth Amendment and 
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another girl, was it your practice to pay the 
procuring girl at least $200 for bringing the new 
girl? 
MR. PIKE: Form. 
A Again? Sony. Can you repeat the 
question? 
Q Sure. Maybe I can state it a little 
better. 
Did you tell the girls that you would 
pay them $200 every time they brought a new 
girl? 
MR. PIKE: Form. 
A Unfortunately, Ms. Ezell, I'm going to 
have to respond to that question the same way as 
I've responded to most of your other questions 
today. On advice of counsel, they've instructed 
me to assert my Sixth Amendment, Fifth Amendment 
and Fourteenth Amendment right. 
Q And indeed, did you keep that promise 
and either pay them directly or have Ms. 
pay the procurer $200 for each new girl that she 
brought? 
MR. PIKE: Form. 
A Unfortunately, Ms. Ezell, I have to 
respond to that question respectfully the same as 
550 
1 
Fourteenth Amendment right. 
2 
Q Assuming that the girl made it through 
3 
the first session, would you generally wait until 
4 
you had reached climax before dismissing her? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: Earthquake? 
7 
MR. PIKE: Train. For the record a 
8 
train is going by. 
9 
A Ms. Ezell, unfortunately I have to 
10 
respJlgl to that question as I've responded to 
11 
most of the other questions here today, which is 
12 
I must assert my rights protected by the Sixth, 
13 
Fifth and Fourteenth Amendment on advice of my 
14 
counsel. 
15 
Q Would you generally pay the new girl 
16 
$200 for the massage, either by telling her that 
17 
the money was on the counter or by telling her 
18 
that Ms. 
would pay her downstairs? 
19 
MR. PIKE: Form. 
20 
A Unfortunately, Ms. Ezell, today I have 
21 
to respond to that question the same way I've 
22 
responded to all your other questions, which is 
23 
by invoking my Sixth Amendment, Fifth Amendment 
24 
and Fourteenth Amendment right. 
25 
Q And If that girl had been brought by 
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I responded to most of your other questions here 
today. My counsel has advised me I must assert 
my rights as protected by the Sixth. Fifth and 
Fourteenth Amendment. 
THE WITNESS: Can we take a two-minute 
break? 
THE VIDEOGRAPHER: Going off the video 
record 3:54 p.m. 
(Pause in the proceedings.) 
THE VIDEOGRAPHER: Back on the video 
record 3:56 p.m. 
Q Did you let the girls know that the more 
they let you do, the more they would be paid? 
MR. PIKE: Form. Again, I'm really 
trying to work with you, Ms. Ezell, but that 
is... is an exact question that Mr. Horowitz 
asked at the commencement of the 
deposition. We are back in generalities 
again, and it is repetitious. If you could, 
let's try to narrow it to your client. 
MS. EZELL: I'm certainly entitled to 
see how my client fits into the big picture 
or my clients, and whether this was part of 
a pattern and whether they indeed were 
treated according to a pattern or scheme or 
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555 
routine. 
1 
pre-existing obligation beginning at 4:00 
2 
MR. PIKE: Okay. I just don't hear any 
2 
o'clock. Hold on a second, guys. So this 
3 
questions regarding your clients. Titers 
3 
deposition will be continued consistent with 
4 
what Pm saying. 
4 
various court orders. 
5 
Q Do you recall that the first time 
5 
MS. EZELL: Okay, thank you. 
6 
came to provide you a massage, you told her to 
6 
THE VIDEOGRAPHER: Going off the video 
7 
take off her clothing, which she refused to do? 
7 
record 4:00 p.m. 
8 
MR. PIKE: Form. 
8 
THECOURT REPORTER: Thank you all. 
9 
A A.H. -- can we use names so there is no 
9 
Same orders as yesterday? 
10 
confusion here? 
10 
MR. EDWARDS: Yes. 
11 
Q A.H. Is ' 
" She is Jane Doe 103. 
11 
MR. HOROWITZ: Yes. 
12 
A I'm going to have to respond to that 
12 
MR. PIKE: Yes. 
13 
question, as I responded to all your other 
13 
MS. F7F-11 • Yes, please. 
14 
questions, Ms. Ezell, respectfully, and on advice 
14 
THE COURT REPORTER: Thank you all. 
15 
of counsel I have to assert my rights as 
15 
(Whereupon, the deposition was adjourned 
16 
protected by the Sixth, Fifth and Fourteenth 
16 
at 4:05 o'clock, p.m., sine die.) 
17 
Amendment. 
17 
18 
Q And when she did refuse to do that, did 
18 
19 
you begin to try to touch her and paw at her and 19 
20 
remove some of her clothing? 
20 
21 
MIL PIKE: Form. 
21 
22 
A Ma'am, I would respectfully -- I would 
22 
23 
like to answer that question, as I would like to 
23 
24 
answer most of the questions you've posed here 
24 
25 
today. Respectfully, I'm going to have to 
25 
554 
556 
decline on advice of counsel and invoke my Sixth 
1. 
THE STATE OF FLORIDA) 
2 
Amendment, Fifth Amendment and Fourteenth 
2 
COUNTY OF PALM BEACH) 
3 
Amendment right. 
3 
I, TERRI BECKER, a Registered 
4 
Over the approximately 17 months that 
4 
Professional Reporter and Notary Public for the 
erne to your borne, did you or your agents 
a
frequently call her at her home number or her 
5 
6 
7 
State of Florida at Large, do hereby certify that 
I reported the videotaped continued deposition of 
JEFFREY EPSTEIN, the DEFENDANT, called by the 
7 
cell number arranging for encounters, arranging 
8
PLAINTIFF in the above.enntied action; that the
8 
for her to come to your home to provide the 
9 
witness was duly sworn by me; that the foregoing 
9 
massage and sexual favors, sometimes as much as 
10 
pages, numbered from 336 to 560, inclusive, 
10 
twice a day? 
11 
constitute a we record of the deposition by 
11 
MR. PIKE: Form. 
12 
said witness. 
12 
Q Let's break it up. 
13 
I further certify that I am not attorney 
13 
During the 17 months that she came to 
14 
or counsel of any of the panics, nor a relative 
14 
your home, did It frequently happen that you or 
15 
or employee of any attorney or counsel connected
with the action, nor financially interested in 
15 
one of your agents would call ahead of time to 
17 
the action. 
16 
tell her that you would be coming to town? 
18 
WITNESS MY HAND and official seal in the 
17 
MR. PIKE: Form. 
19 
City of West Rahn Beach, County of Palm Beach, 
18 
A Ma'am, I'm going to respectfully have to 
20 
State of Florida, this 19th day of Apra2010. 
-..a. 
19 
decline to answer that question on advice of 
21 
_ 
$ 
20 
counsel. Theyve instructed me to assert my 
21 
Sixth Amendment, Fifth Amendment and Fourteenth 
22 
TERRI BECKER, Registere 
22 
Amendment right. 
Professional Reporter and 
23 
MR. PIKE: Ms. Ezell, as you know we've 
23 
Notary Public, State of Florida 
24 
discussed this at the commencement of 
24 
at Large. My Commission expires 
March 13,2011. 
25 
today's deposition, that we had a 
25 
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1 
THE STATE OF FLORIDA) 
1 
ERRATA SHEET 
2 
COUNTY OF PALM BEACH) 
2 
In Re: JANE DOE V. EPSTEIN 
3 
3 
DO NOT WRITE ON TRANSCRIPT 
ENTER CHANGES HERE. 
4 
4 
5 
The foregoing certificate was 
5 
PAGE 
LINE 
CHANGE 
REASON 
6 
acknowledged before me this 
6 
7 
day of 
2010. 
7 
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8 
9 
9 
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14 
15 
Notary Public, State of Florida. 
JEFFREY EPSTEIN 
15 
My commission No. 
16 
17 
Expires March 13, 2011. 
18 
16 
THE STATE. OF FLORIDA) 
17 
19 
COUNTY OF PALM BEACH) 
18 
20 
I DO HEREBY CERTIFY THAT JEFFREY EPSTEIN 
19 
appeared before me and gated that he has mad 
20 
21 
21 
his deposition; further, ant this Errata Sheet 
vas signed in my presence on this 
day 
of 
2010. 
22 
22 
23 
23 
24 
24 
25 
25 
558 
560 
1, JEFFREY EPSTEIN, do hereby 
U.S. LEGAL SUPPORT 
Resestercel Professional Reporters 
2 
certify that I have read the foregoing transcript 
2 
444 West Railroad Avant 
3 
of my deposition given on April 14,2010, that 
3 
Suits 300 
• 
COI 
4 
together with the correction page attached hereto 
S 
noting changes in form or substance, if any, it 
April 
5 
6 
is true and correct. 
6 
SURMA/I.CR.1770N LUTT1ER & COLEMAN 
7 
Senyzn Bou4•aed 
Stet 400 
West Pales Bea* DON& 33401 
B 
JEFFREY EPSTEIN 
ATTENTION: M/CHAEL MKS. ESQ. 
9 
9 
In Re. JANE DOE V. EPSTEIN 
10 
10 
Deposition of. IFJPREY EPSTEIN 
11 
11 
12 
12 
Dear Mr Pikes 
13 
13 
Slaw would haw avoid thm yeti may 
14 
15 
I do hereby certify that the deposition 
of JEFFREY EPSTEIN was submitted to the witness 
14 
15 
hew the mottos mad ad riper:or copy of dm 
depotitiort for to comenioeue enclosed 
herewith you wIE find Si Ernes Shea for the 
16 
for reading and signing; that after he had stated 
16 
wecesf use in emend any changes to the 
**Call* 
17 
to the undersigned Notary Public that he had read 
17 
Thank see for seat lameoPt OINNIOn 
16 
Carnally yours. 
18 
and examined his deposition, he signed the same 
U.S. LEGAL SUPPORT 
19 
in the presence of the undersigned authority on 
19 
20 
20 
the 
day of 
2010. 
21 
TERRI BECKER, ROOM:rid 
Nofetsiond Rammer. Nosey 
21 
Pubic. State of Florida at 
22 
22 
term. My carreistrion maims 
Mott 1).1011. 
23 
23 
24 
24 
CC Admit Itorowila, 
Bradley Edwin* EM 
Kedierine Fall, Hap 
25 
25 
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