EFTA01158588

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IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
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- Vs-
CASE No. 502008CA037319XXXXMB AB 
Plaintiff, 
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JEFFREY EPSTEIN, 
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Defendant. 
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CONTINUED DEPOSITION OF JEFFREY EPSTEIN 
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VOLUME III 
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Thursday, October 8, 2009 
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1:46 - 3:48 p.m. 
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250 South Australian Avenue 
Suite 1400 
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West Palm Beach,Florida 33401 
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Reported By: 
Jeana Ricciuti, RPR, FPR, CLR 
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Notary Public, State of Florida 
Prose Court Reporting Agency, Inc. 
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0173 
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APPEARANCES: 
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On behalf of the Plaintiff: 
SPENCER T. KUVIN, ESQUIRE 
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ADAM LANGINO, ESQUIRE 
LEOPOLD KUVIN, P.A. 
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2295 PGA Boulevard 
Suite 200 
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Palm Beach Gardens, Florida 33410 
Phone: 
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On behalf of §§§. and III. and Jane Doe in Case No. 
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80893: 
CARA L. HOLMES, ESQUIRE 
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ROTHSTEIN, ROSENFELDT & ADLER 
401 East Las Olas Boulevard 
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Suite 1650 
Fort Lauderdale, Florida 33301 
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Phone: 
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On behalf of Plaintiff Jane Doe in Case No. 80591 and 
80656 via telephone: 
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KATHERINE W. EZELL, ESQUIRE 
PODHURST ORSECK, P.A. 
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25 West Flagler Street 
Miami, Florida 33130 
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Phone: 
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On behalf of the Defendant: 
JACK GOLDBERGER, ESQUIRE 
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STORY KOWLES, PARALEGAL 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
EFTA01158588

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250 South Australian Avenue 
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Suite 1400 
West Palm Beach, Florida 33401 
Phone: 
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MICHAEL J. PIKE, ESQUIRE 
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BURMAN, CRITTON, LUTTIER & COLEMAN, P.A. 
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303 Banyan Boulevard 
Suite 400 
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West Palm Beach, Florida 
Phone: 
33401 
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ALSO PRESENT: 
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DAN DOSKEY, VIDEOGRAPHER 
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VISUAL EVIDENCE, INC. 
0174 
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EXHIBITS 
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WITNESS: 
CONT'D DIRECT 
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JEFFREY EPSTEIN 
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BY MR. KUVIN 
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EXHIBITS 
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- - - -
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NUMBER 
DESCRIPTION 
PAGE 
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PLAINTIFF'S EX. 9 
PHOTOGRAPH OF GHISLAINE 
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MAXWELL 
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PLAINTIFF'S EX. 10 
PHOTOGRAPH OF JOANNA 
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SHOGERT 
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PLAINTIFF'S EX. 11 
PHOTOGRAPH OF EULA MAXWELL 196 
PLAINTIFF'S EX. 12 
PHOTOGRAPH 
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PLAINTIFF'S EX. 13 
PHOTOGRAPH OF 
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PLAINTIFF'S EX. 14 
PHOTOGRAPH OF 
PLAINTIFF'S EX. 15 
PHOTOGRAPH OF 
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PLAINTIFF'S EX. 16 
PHOTOGRAPH OF PRINCE 
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ANDREW 
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PLAINTIFF'S EX. 17 
LETTER TO B. KRISCHER FROM 203 
M. REITER 
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PLAINTIFF'S EX. 18 
RECEIPT OF PURCHASES MADE 
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FROM JAIL 
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PLAINTIFF'S EX. 19 
FAA REGISTRY 
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0175 
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PROCEEDINGS 
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- - -
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THE VIDEOGRAPHER: We're back on the record at 
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1:46. 
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CONTINUED DIRECT EXAMINATION 
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BY MR. KUVIN: 
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Q. 
Do you personally know John Mack, former CEO 
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at Morgan Stanley? 
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A. 
I'll have to answer that the same way I've 
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answered most of your questions here today, Mr. Kuvin, 
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which is, I intend to respond to all relevant questions 
EFTA01158589

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a 
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regarding this lawsuit; however, at the present time, my 
attorneys have counseled me I cannot provide answers to 
any questions relevant to this lawsuit. I must accept 
this advice or risk losing my 6th Amendment right to 
effective representation. Accordingly, I assert my 
federal constitutional rights as guaranteed by the 5th, 
6th and 14th Amendment to the United States 
Constitution. 
MR. KUVIN: Okay. Same deposition as shown 
before, different clip. I'm going to play it for 
counsel first. 
MR. PIKE: Thank you. 
MR. KUVIN: Mr. Videographer, just let me know 
when you're ready. 
THE VIDEOGRAPHER: Whenever you are. 
MR. KUVIN: Okay. 
(Video played.) 
VIDEO WITNESS: "What did I do to Jeffrey and 
what did Jeffrey do to me? I went up there 
multiple times; I can't count. And I would be on a 
massage table, massaging his legs, he would turn 
over, his penis would be hanging out. He would put 
a vagina -- or a vibrator to my vagina. He would 
touch my vagina with his fingers. He would touch 
my breasts. He would try to kiss my mouth. He 
would bring my hands toward his penis." 
(Video stopped.) 
MR. KUVIN: Okay. 
MR. PIKE: I'm just going to object to the use 
of the video as to relevance, predicate and 
foundation. 
BY MR. KUVIN: 
Q. 
All right. Let me get it back to the same 
location. 
Sir, first of all, 
lay the foundation for this, 
A. 
I'm going to have 
the same way I've responded 
questions here today, which 
once again, just so I can 
do you recognize this girl? 
to respond to that question 
to most of your other 
is, I intend to respond to 
all relevant cannot provide answers to any questions 
relevant to this lawsuit; however, at the present time, 
my attorneys have counseled me I cannot provide answers 
to any questions relevant to the lawsuit. I must accept 
this advice or risk losing my 6th Amendment right to 
effective representation. Accordingly, I assert my 
federal constitutional rights as guaranteed by the 5th, 
6th and 14th Amendment to the United States 
Constitution. 
Q. 
Did this girl bring §§§. to your home for a 
naked massage? 
A. 
I'm going to have to respond to that the same 
way I've responded to most of your other questions here 
today, which is, I intend to respond to all relevant 
questions regarding this lawsuit; however, at the 
present time, my attorneys have counseled me I cannot 
provide answers to any questions that may be relevant to 
the lawsuit. I must accept this advice or risk losing 
my 6th Amendment right to effective representation. 
Accordingly, I assert my federal constitutional rights 
as guaranteed by the 5th, 6th and 14th Amendment to the 
United States Constitution. 
EFTA01158590

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Q. 
I'd like to play this clip for you and then 
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I'm going to ask you a question. 
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MR. PIKE: The same clip you just played? 
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MR. KUVIN: Exactly. 
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MR. PIKE: Same objection. 
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(Video played.) 
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VIDEO WITNESS: "What did I do to Jeffrey and 
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what did Jeffrey do to me? I went out there 
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multiple times; I can't count. And I would be on a 
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massage table, massaging his legs. He would turn 
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over, his penis would be hanging out. He would put 
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a vagina -- or vibrator to my vagina. He would 
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touch my vagina with his fingers. He would touch 
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my breasts. He would try to kiss my mouth. He 
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would bring my hands toward his penis." 
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(Video stopped.) 
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BY MR. KUVIN: 
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Q. 
Did you do that with that girl? 
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MR. PIKE: Form. 
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THE WITNESS: I intend to respond to all 
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relevant questions regarding this lawsuit; however, 
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at the present time, my attorneys have counseled me 
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I cannot provide answers to any questions that may 
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be relevant to this lawsuit. I must accept this 
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advice or risk losing my 6th Amendment right to 
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effective representation. Accordingly, I must 
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assert my federal constitutional rights as 
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guaranteed by the 5th, 6th and 14th Amendment to 
0179 
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the United States Constitution. 
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BY MR. KUVIN: 
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Q. 
Did you do what that young lady described just 
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now to hundreds of women, including III.? 
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MR. PIKE: Form, argumentative, harassing, 
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lacks appropriate predicate, foundation, lacks 
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identity. 
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THE WITNESS: Excuse me. I'm going to respond 
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to that the same way I've responded to most of your 
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other questions here today, which is, I intend to 
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respond to all relevant questions regarding this 
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lawsuit; however, at the present time, my attorneys 
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have counseled me that I cannot provide answers to 
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any questions relevant to the lawsuit. I must 
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accept their advice or risk losing my 6th Amendment 
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right to effective representation. Accordingly, I 
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must assert my federal constitutional rights as 
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guaranteed by the 5th, 6th and 14th Amendment to 
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the United States Constitution. 
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BY MR. KUVIN: 
21 
Q. 
While §§§. was standing naked in your home, 
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specifically in your bathroom, did you tell her that you 
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could get her an interview as a model because of your 
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connections? 
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A. 
I'm going respond to that the same way I've 
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responded to most of your questions today, Spencer. I 
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intend to respond to all relevant questions regarding 
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this lawsuit; however, at the present time, my attorneys 
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have counseled me I cannot provide answers to any 
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questions that may be relevant to the lawsuit. I must 
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accept this advice or risk losing my 6th Amendment right 
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to effective representation. Accordingly, I must assert 
EFTA01158591

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my federal constitutional right as guaranteed by the 
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5th, 6th and 14th Amendment to the United States 
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Constitution. 
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MR. PIKE: Same objection to that line of 
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questioning. 
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BY MR. KUVIN: 
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Q. 
As §§§. was standing naked in your bathroom 
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before you when she was 15, did you ask her to turn 
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around so you could see her ass better? 
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MR. PIKE: Form, argumentative, harassing, 
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lacks appropriate predicate, foundation. 
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THE WITNESS: I'll respond to that as I 
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responded to your last question, which is, I intend 
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to respond to all relevant questions regarding this 
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lawsuit; however, at the present time, my attorneys 
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have counseled me I cannot provide answers to any 
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questions that may be relevant to this lawsuit. I 
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must accept their advice or risk losing my 6th 
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Amendment right to effective representation; 
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therefore, I must assert my federal constitutional 
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rights as guaranteed by the 5th, 6th and 14th 
4 
Amendment to the United States Constitution. 
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BY MR. KUVIN: 
6 
Q. 
When III. was 15 years old and standing naked 
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in front of you in your bathroom, did you tell her that 
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you could help her become a model? 
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MR. PIKE: Same objections, including 
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foundation. 
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THE WITNESS: Is it different than the last 
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question? 
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MR. KUVIN: Uh-huh. 
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MR. GOLDBERGER: Just go ahead. 
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THE WITNESS: Okay. I intend to respond to 
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all relevant questions pertaining to this lawsuit; 
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however, at the present time, my attorneys have 
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counseled me I cannot provide answers to any 
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questions that may be relevant to this lawsuit, so 
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I've answered most questions here today the same 
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way. I must expect that -- accept their advice or 
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risk losing my 6th Amendment right to effective 
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representation. Accordingly, I assert my federal 
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constitutional rights as guaranteed by the 5th, 6th 
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and 14th Amendment to the United States 
0182 
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BY 
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Constitution. 
MR. KUVIN: 
Q. 
Who is Ghislaine Maxwell? 
A. 
I intend to respond to all relevant questions 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit. As I 
have done to most of your other questions here today, I 
must accept their advice or risk losing my 6th Amendment 
right to effective representation. Accordingly, I 
assert my federal constitutional rights as guaranteed by 
the 5th, 6th and 14th Amendment to the United States 
Constitution. 
MR. KUVIN: Let me show the camera what we'll 
mark as Exhibit 9 to this deposition. 
THE VIDEOGRAPHER: Okay. 
(Plaintiff's Exhibit No. 9 was marked for 
identification.) 
EFTA01158592

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BY MR. KUVIN: 
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Q. 
Let me show you what we've marked as Exhibit 9 
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to your deposition. Do you recognize Ghislaine Maxwell 
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in this photograph? 
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A. 
Yes. 
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Q. 
And who is she standing with? 
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A. 
Her father. 
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Q. 
And her father is Robert Maxwell? 
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A. 
Was Robert Maxwell. 
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Q. 
I'm sorry, he's passed, correct? 
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A. 
Correct. 
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Q. 
She is a close friend of yours, is she not? 
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A. 
I'm going to respond to that question the same 
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way I've responded to most of your other questions here 
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today, Mr. Kuvin, which is, I intend to respond to all 
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relevant questions regarding to this lawsuit; however, 
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at the present time, my attorneys have counseled me I 
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cannot provide answers to any questions that may be 
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relevant to this lawsuit. I must expect -- accept their 
13 
advice or risk losing my 6th Amendment right to 
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effective representation. Accordingly, I must assert my 
15 
federal constitutional rights as guaranteed by the 5th, 
16 
6th and 14th Amendment to the United States 
17 
Constitution. 
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Q. 
Ghislaine Maxwell has accompanied you to 
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numerous social events in the last few years; isn't that 
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true? 
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MR. PIKE: Form. 
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THE WITNESS: I'm going to respond to that 
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question the same way I've responded to most of 
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your questions here today, which is, I intend to 
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respond to all relevant questions regarding your 
0184 
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lawsuit; however, at the present time, my attorneys 
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have counseled me I cannot provide answers to any 
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questions that may be relevant to that lawsuit. I 
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must accept their advice or risk losing my 6th 
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Amendment right to effective representation. 
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Accordingly, I must assert my federal 
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constitutional right as guaranteed by the 5th, 6th 
8 
and 14th Amendment of the United States 
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Constitution. 
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BY MR. KUVIN: 
11 
Q. 
One of your houseboys that has been deposed in 
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this case testified that you were a rather nice 
13 
gentleman that used to talk to the staff, and that when 
14 
Ms. Maxwell came into the picture, that you stopped 
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talking to the staff and the staff had to communicate 
16 
through Ms. Maxwell. Do you agree or disagree with 
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that? 
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MR. PIKE: Form, foundation, predicate, 
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argumentative, assumes facts not in evidence. 
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THE WITNESS: I'm going to answer that the 
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same way I've answered most of your questions here 
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today, which is, I intend to respond to all 
23 
relevant questions regarding this lawsuit; however, 
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at the present time, my attorneys have counseled me 
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that I cannot provide answers to any questions that 
0185 
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may be relevant to your lawsuit. I must accept 
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their advice or risk losing my 6th Amendment right 
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to effective representation. Accordingly, I assert 
EFTA01158593

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my federal constitutional rights as guaranteed by 
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the 5th, 6th and 14th Amendment of the United 
6 
States Constitution. 
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BY MR. KUVIN: 
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Q. 
He also testified that he felt you were a 
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rather normal guy until Ms. Maxwell came into the 
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picture, and that she led you into this life of 
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perversion, sexual perversion. Do you agree with that? 
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MR. PIKE: Same objections. 
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THE WITNESS: I'm going to respond to that the 
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same way I've responded to most of your questions 
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here today, Mr. Kuvin, which is, I intend to 
16 
respond to all relevant questions regarding this 
17 
lawsuit; however, at the present time, my attorneys 
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have counseled me I cannot provide answers to any 
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questions relevant to this lawsuit. I must accept 
20 
their advice or risk losing my 6th Amendment --
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excuse me -- I must accept their advice or risk 
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losing my 6th Amendment right to effective 
23 
representation. Accordingly, I must assert my 
24 
federal constitutional rights as guaranteed by the 
25 
5th, 6th and 14th Amendment to the United States 
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BY 
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girl 
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have 
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to respond to all relevant questions regarding this 
2 
lawsuit; however, at the present time, my attorneys 
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have counseled me I cannot provide answers to any 
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questions relevant to that lawsuit. I must accept 
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their advice or risk losing my 6th Amendment right 
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to effective representation. Therefore, I assert 
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my federal constitutional rights as guaranteed by 
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the 5th, 6th and 14th Amendments to the United 
9 
States Constitution. 
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BY MR. KUVIN: 
11 
Q. 
Do you know where Donald Trump's Maralago 
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estate is? 
13 
A. 
Yes. 
14 
Q. 
Have you been there? 
Constitution. 
MR. KUVIN: 
Q. 
Did Ms. Maxwell procure underaged girls for 
you to have sexual relationships with? 
A. 
I'm going to answer that question the same way 
I've answered most of your other questions today, 
Mr. Kuvin, which is, I intend to respond to all relevant 
questions regarding this lawsuit; however, at the 
present time, my attorneys have counseled me I cannot 
provide answers to any questions relevant to that 
lawsuit. Excuse me. I must accept their advice or risk 
losing my 6th Amendment right to effective 
representation. Accordingly, I must assert my federal 
constitutional rights as guaranteed -- guaranteed by the 
5th, 6th and 14th Amendments to the United States 
Constitution. 
Q. 
Ms. Maxwell procured a particular underaged 
who worked at Donald Trump's Maralago, for you to 
a sexual relationship with; isn't that true? 
MR. PIKE: Form, argumentative, lacks 
appropriate predicate, foundation, assumes facts 
not in evidence. 
THE WITNESS: I'm going to respond to that the 
same way I've responded to most of your other 
questions here today, Mr. Kuvin, which is, I intend 
EFTA01158594

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rights as guaranteed by the 5th, 6th and 14th Amendment 
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to the United States Constitution. 
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Q. 
Have you seen the high school transcripts 
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grades of girls that you have had sexual relationships 
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with dating back to 2005? 
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MR. PIKE: Form, relevance, improper 
7 
hypothetical, lacks facts -- assumes facts not in 
8 
evidence, lacks appropriate predicate, foundation. 
9 
THE WITNESS: I'm going to answer that 
10 
question the same as I've answered most of your 
11 
other questions here today, Mr. Kuvin, which is, I 
12 
intend to respond to all relevant questions 
13 
regarding this lawsuit; however, at the present 
14 
time, my attorneys have counseled me that I cannot 
15 
provide answers to any questions that may be 
16 
relevant to this lawsuit. I must accept their 
17 
advice or risk losing my 6th Amendment right to 
18 
effective representation. Accordingly, I assert my 
19 
federal constitutional rights as guaranteed by the 
20 
5th, 6th and 14th Amendment to the United States 
21 
Constitution. 
22 
BY MR. KUVIN: 
23 
Q. 
Do you deny that the high school transcripts 
24 
which were found in your trash on Palm Beach that showed 
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the ages of some of the girls you were engaged with 
0189 
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sexual acts with at your home came from your house? 
2 
MR. PIKE: Same objection in addition to 
3 
argumentative and harassing. 
4 
THE WITNESS: I intend to respond to all 
5 
relevant questions regarding this lawsuit; however, 
6 
as I've done with most of your other questions 
7 
today, at the present time my attorneys have 
8 
counseled me that I cannot provide answers to any 
9 
of those questions relevant to this lawsuit. I 
10 
must accept their advice or risk losing my 6th 
11 
Amendment right to effective representation. 
12 
Accordingly, I must assert my federal 
13 
constitutional rights as guaranteed by the 5th, 6th 
14 
and 14th Amendments to the United States 
15 
Constitution. 
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BY MR. KUVIN: 
17 
Q. 
Did you have numerous photos of nude young 
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women, girls under the age of 18, back in your home 
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in -- on Palm Beach Island in 2005 and 2006? 
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A. 
I'm going to have to respond to that question 
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the same way I've responded to most of your questions 
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here today, which is, I intend to respond to all 
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relevant questions regarding this lawsuit; however, at 
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the present time, my attorneys have counseled me I 
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cannot provide answers to any questions relevant to the 
A. 
Yes. 
Q. 
Who with? 
A. 
I'm going to have to answer that question the 
same way I've answered most of your other questions here 
today. I intend to respond to all relevant questions 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled me I cannot provide answers to 
any questions that may be relevant to the same lawsuit. 
I must accept their advice or risk losing my 6th 
Amendment right to effective representation. 
Accordingly, I must assert my federal constitutional 
EFTA01158595

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same lawsuit. I must accept their advice or risk losing 
2 
my 6th Amendment right to effective representation. 
3 
Accordingly, I must assert my federal constitutional 
4 
rights as guaranteed by the 5th, 6th and 14th Amendment. 
5 
Q. 
Did you have photographs of girls under the 
6 
age of ten who were nude, either partially or fully 
7 
nude, in your home on Palm Beach in 2005 and 2006? 
8 
MR. PIKE: Form. 
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THE WITNESS: I'm going to respond to that 
10 
question the same way I've responded to most of 
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your other questions, which is, I intend to respond 
12 
to all relevant questions regarding this lawsuit; 
13 
however, at the present time, my attorneys have 
14 
counseled me I cannot provide answers to any 
15 
questions relevant to this lawsuit. I must accept 
16 
this advice or risk losing my 6th Amendment right 
17 
to effective representation. Accordingly, I assert 
18 
my federal constitutional rights as guaranteed by 
19 
the 5th, 6th and 14th Amendments of the United 
20 
States Constitution. 
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THE VIDEOGRAPHER: Mr. Kuvin, I'm sorry I have 
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to change. 
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MR. KUVIN: Go ahead. 
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THE VIDEOGRAPHER: We'll go off the record at 
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2:03. This will be the end of tape No. 2. 
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MR. GOLDBERGER: Break time? 
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MR. KUVIN: No, not again. Please not. 
3 
Just let us know when you're good to go. 
4 
THE VIDEOGRAPHER: We're back on the record at 
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2:04. This will be the beginning of tape No. 3. 
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BY MR. KUVIN: 
7 
Q. 
Do you have security cameras throughout your 
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home on Palm Beach Island? 
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A. 
I'm going to answer that question the same way 
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I've answered most of your questions here today, 
11 
Mr. Kuvin. I intend to respond to all relevant 
12 
questions regarding this lawsuit; however, at the 
13 
present time, my attorneys have counseled me I cannot 
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provide answers to any questions relevant to the 
15 
lawsuit. I must accept their advice or risk losing my 
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6th Amendment right to effective representation. 
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Accordingly, I assert my federal constitutional rights 
18 
as guaranteed by the 5th, 6th and 14th Amendment to the 
19 
United States Constitution. 
20 
(Plaintiff's Exhibit No. 10 was marked for 
21 
identification.) 
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MR. KUVIN: I'll show the camera a photograph 
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here. Okay? 
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THE VIDEOGRAPHER: Lift it up. Yeah, there 
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you go. Okay. 
0192 
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MR. KUVIN: Okay? 
2 
BY MR. KUVIN: 
3 
Q. 
Let me show you what we marked as Plaintiff's 
4 
Exhibit 10. Do you recognize this young lady? 
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A. 
Yes. 
6 
Q. 
Who is she? 
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A. 
Her name is Joanna Shogert (phonetic). 
8 
Q. 
And who is she? 
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A. 
I just -- her name is Joanna Shogert. 
10 
Q. 
How do you recognize her? 
EFTA01158596

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A. 
I don't understand the question. 
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Q. 
Well, is she a friend of yours? Did she work 
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for you? How do you recognize her? 
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A. 
How do I recognize her? 
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Well, I'd like to respond to that question 
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but, however, my attorneys have told me that I can't 
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respond to any questions today that may -- excuse me. I 
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intend to respond to all relevant questions regarding 
19 
this lawsuit; however, at the present time, my attorneys 
20 
have counseled me that I cannot provide answers to any 
21 
questions relevant to this lawsuit. I must accept their 
22 
advice or risk losing my 6th Amendment right to 
23 
effective representation. Accordingly, I assert my 
24 
federal constitutional rights as guaranteed by the 5th, 
25 
6th and 14th Amendment to the United States 
0193 
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Constitution. 
2 
Q. 
Did you have sex with Joanna Shogert? 
3 
A. 
I'm going to answer that question like I've 
4 
answered most of your questions here today, which is, I 
5 
intend to respond to all relevant questions regarding 
6 
this lawsuit; however, at the present time, my attorneys 
7 
have counseled me I cannot provide answers to any 
8 
questions relevant to this lawsuit. I must accept their 
9 
advice or risk losing my 6th Amendment right to 
10 
effective representation. Accordingly, I assert my 
11 
federal constitutional rights as guaranteed by the 5th, 
12 
6th and 14th Amendment to the United States 
13 
Constitution. 
14 
Q. 
When did you first meet Prince Andrew? 
15 
And let me make it a compound question so I 
16 
don't have to repeat it over and over. When did you 
17 
first meet Prince Andrew, under what conditions did you 
18 
meet him, and who was present at that first meeting? 
19 
A. 
I'm going to answer that question as I've done 
20 
most of your questions here today, Mr. Kuvin, which is, 
21 
I intend to respond to all relevant questions regarding 
22 
this lawsuit; however, at the present time, my attorneys 
23 
have counseled me I cannot provide answers to any 
24 
questions relevant to that lawsuit. I must accept their 
25 
advice or risk losing my 6th Amendment right to 
0194 
1 
effective representation. Accordingly, I must assert my 
2 
federal constitutional rights as guaranteed by the 5th, 
3 
6th and 14th Amendment to the United States 
4 
Constitution. 
5 
MR. PIKE: In addition, relevance. 
6 
BY MR. KUVIN: 
7 
Q. 
Do you pay Ms. Maxwell a salary? 
8 
MR. PIKE: Form. 
9 
BY MR. KUVIN: 
10 
Q. 
Ghislaine Maxwell, so we're clear. Do you pay 
11 
her a salary? 
12 
A. 
I'd like -- excuse me. I'm going to answer 
13 
that question the same way I've answered most of your 
14 
questions here today, which is, I intend to answer all 
15 
questions relevant to this lawsuit; however, at the 
16 
present time, my attorneys have counseled me I cannot 
17 
provide answers to any questions relevant to this 
18 
lawsuit. I must accept their advice or risk losing my 
19 
6th Amendment right to effective representation. 
20 
Accordingly, I assert my federal constitutional rights 
21 
as guaranteed by the 5th, 6th and 14th Amendment to the 
EFTA01158597

22 
United States Constitution. 
23 
Q. 
Did you provide any underaged girls for sex to 
24 
Prince Andrew? 
25 
MR. PIKE: Form. 
0195 
1 
THE WITNESS: I'm going to respond to that 
2 
question the same way I've responded to most of 
3 
your questions here today, Mr. Kuvin, which is, I 
4 
intend to respond to all relevant questions 
5 
regarding this lawsuit -- excuse me, however, at 
6 
the present time, my attorneys have counseled me I 
7 
cannot provide answers to any questions relevant to 
8 
the lawsuit, or might be relevant to the lawsuit. 
9 
I must accept their advice or risk losing my 6th 
10 
Amendment right to effective representation. 
11 
Accordingly, I assert my federal constitutional 
12 
rights as guaranteed by the 5th, 6th and 14th 
13 
Amendment of the United States Constitution. 
14 
BY MR. KUVIN: 
15 
Q. 
Did you fly with Prince Andrew on your plane, 
16 
or planes, with any underaged girls, girls under the age 
17 
of 18? 
18 
A. 
I'm going to answer that question the same way 
19 
I've answered all the other questions here today, 
20 
virtually, which is, I intend to respond to all relevant 
21 
questions regarding this lawsuit; however, at the 
22 
present time, my attorneys have counseled me I cannot 
23 
provide answers to any questions relevant to the 
24 
lawsuit. I must accept their advice or risk losing my 
25 
6th Amendment right to effective representation. 
0196 
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 
0197 
1 
A. 
Eula Maxwell (phonetic). 
2 
Q. 
Where were you? 
3 
A. 
I intend to respond to all relevant questions 
4 
regarding this lawsuit; however, at the present time, my 
5 
attorneys have counseled me I cannot provide answers to 
6 
any questions that may be relevant to this lawsuit. I 
Accordingly, I must assert my federal constitutional 
rights as guaranteed by the 5th, 6th and 14th Amendments 
to the United States Constitution. 
Q. 
Do you know Christine Drangsholt? 
MR. KUVIN: For the court reporter, it's 
D-R-A-N-G-S-H-O-L-T. 
THE WITNESS: I intend to respond to all 
relevant questions regarding this lawsuit; however, 
at the present time, my attorneys have counseled me 
I cannot provide answers to any questions relevant 
to the lawsuit. I must accept this advice or risk 
losing my 6th Amendment right to effective 
representation. Accordingly, I assert my federal 
constitutional rights as guaranteed by the 5th, 6th 
and 14th Amendments to the United States 
Constitution. 
MR. KUVIN: Let me show the camera what we'll 
mark as Exhibit 11. 
(Plaintiff's Exhibit No. 11 was marked for 
identification.) 
THE VIDEOGRAPHER: Okay. 
MR. KUVIN: Okay? 
BY MR. KUVIN: 
Q. 
In Exhibit 11, sir, you're standing with a 
woman. Who is that woman in that photograph? 
EFTA01158598

7 
must accept this advice or risk losing my 6th Amendment 
8 
right to effective representation. Accordingly, I must 
9 
assert my federal constitutional rights as guaranteed by 
10 
the 5th, 6th and 14th Amendments to the United States 
11 
Constitution. 
12 
MR. KUVIN: And just so the court reporter 
13 
knows, Ghislaine is spelled G-H-I-S-L-A-I-N-E. 
14 
BY MR. KUVIN: 
15 
Q. 
Who is 
excuse 
16 
me? 
17 
A. 
I'm going to answer that question the same way 
18 
I've answered most of your questions here today, which 
19 
is, I intend to respond to all relevant questions 
20 
regarding this lawsuit; however, at the present time, my 
21 
attorneys have counseled me I cannot provide answers to 
22 
any questions relevant to the lawsuit. I must accept 
23 
their advice or risk losing my 6th Amendment right to 
24 
effective representation. Excuse me. Accordingly, I 
25 
must assert my federal constitutional rights as 
0198 
1 
guarantee -- guaranteed by the 5th, 6th and 14th 
2 
Amendment to the United States Constitution. 
3 
(Plaintiff's Exhibit No. 12 was marked for 
4 
identification.) 
5 
MR. KUVIN: Let me show to the camera what 
6 
we've marked as Exhibit 12. 
7 
BY MR. KUVIN: 
8 
Q. 
Let me show you what I've marked as Exhibit 
9 
12. Do you recognize any of the girls in that 
10 
photograph? 
11 
A. 
I'm going to answer that question the same way 
12 
I've answered most of your other questions here today, 
13 
Mr. Kuvin, which is, I intend to respond to all relevant 
14 
questions regarding this lawsuit; however, at the 
15 
present time, my attorneys have counseled me that I 
16 
cannot provide answers to any questions that may be 
17 
relevant to the lawsuit. I must accept their advice or 
18 
risk losing my 6th Amendment right to effective 
19 
representation. Accordingly, I assert my federal 
20 
constitutional rights as guaranteed by the 5th, 6th and 
21 
14th Amendment to the United States Constitution. 
22 
Q. 
Sir, isn't it true that in what we've marked 
23 
as Plaintiff's Exhibit 12, the blond standing on the 
24 
left is 
, and the blonde, dirty blonde 
25 
standing on the right is 
? 
0199 
1 
A. 
I intend to respond to all relevant questions 
2 
regarding this lawsuit; however, as I've done to most of 
3 
the questions at the present time, my attorneys have 
4 
counseled me that I cannot provide answers to any of 
5 
those questions that may be relevant to the lawsuit. I 
6 
must accept this advice or risk losing my 6th Amendment 
7 
right to effective representation. Accordingly, I 
8 
assert my federal constitutional rights as guaranteed by 
9 
the 5th, 6th and 14th Amendments of the United States 
10 
Constitution. 
11 
BY MR. KUVIN: 
12 
Q. 
I'm going to show you what we'll mark as 
13 
Exhibit 13. Let me show it to the camera, first. 
14 
(Plaintiff's Exhibit No. 13 was marked for 
15 
identification.) 
16 
BY MR. KUVIN: 
17 
Q. 
Sir, is it true that Exhibit 13 shows your 
EFTA01158599

18 
personal assistant, 
19 
A. 
I intend to respond to all relevant questions 
20 
regarding this lawsuit; however, at the present time, my 
21 
attorneys have counseled me that I cannot provide 
22 
answers to any questions that may be relevant to this 
23 
lawsuit. I must accept their advice or risk losing my 
24 
6th Amendment right to effective representation. 
25 
Accordingly, I assert my federal constitutional rights 
0200 
1 
as guaranteed by the 5th, 6th and 14th Amendment to the 
2 
United States Constitution. 
3 
Q. 
Let me show you what we'll mark as Exhibit 14. 
4 
(Plaintiff's Exhibit No. 14 was marked for 
5 
identification.) 
6 
BY MR. KUVIN: 
7 
Q. 
Sir, does Exhibit 14 show 
, a 
8 
girl that you have had a sexual relationship with since 
9 
before she was 18 years old? 
10 
MR. PIKE: Form, argumentative, harassing, 
11 
assumes facts not in evidence, lacks appropriate 
12 
predicate and foundation. 
13 
THE WITNESS: I intend to respond to all 
14 
relevant questions regarding this lawsuit; however, 
15 
at the present time, my attorneys have counseled me 
16 
I cannot provide answers to any questions relevant 
17 
to this lawsuit. I must accept their advice or 
18 
risk losing my 6th Amendment right to effective 
19 
representation. Accordingly, I assert my federal 
20 
constitutional rights as guaranteed by the 5th, 6th 
21 
and 14th Amendment to the United States 
22 
Constitution. 
23 
BY MR. KUVIN: 
24 
Q. 
I'm going to show the camera what we'll mark 
25 
as Exhibit 15. 
0201 
1 
(Plaintiff's Exhibit No. 15 was marked for 
2 
identification.) 
3 
BY MR. KUVIN: 
4 
Q. 
Sir, does Exhibit 15 show 
, an 
5 
underaged girl that you were utilizing back in 2005 and 
6 
2006 to procure other underaged girls for sex and sexual 
7 
contact at your home? 
8 
MR. PIKE: Same objections to Exhibit 15 as 
9 
were made to Exhibit 14. 
10 
THE WITNESS: I'm going to answer that the 
11 
same way I've answered most of your questions here 
12 
today, Mr. Kuvin, which is, I intend to respond to 
13 
all relevant questions regarding this lawsuit; 
14 
however, at the present time, my attorneys have 
15 
counseled me that I cannot provide answers to any 
16 
questions that may be relevant to the lawsuit. I 
17 
must accept their advice or risk losing my 6th 
18 
Amendment right to effective representation. 
19 
Accordingly, I am going to assert my federal 
20 
constitutional rights as guaranteed by the 5th, 6th 
21 
and 14th Amendments to the United States 
22 
Constitution. 
23 
(Plaintiff's Exhibit No. 16 was marked for 
24 
identification.) 
25 
MR. KUVIN: Let me show the camera what we've 
0202 
1 
marked as Exhibit 16. 
2 
BY MR. KUVIN: 
EFTA01158600

3 
Q. 
Do you recognize the gentleman in that 
4 
photograph, sir? 
5 
MR. PIKE: Hold on for a second. 
6 
MR. GOLDBERGER: Do you want to discuss it 
7 
with me? 
8 
MR. PIKE: Let's take a break for one minute. 
9 
MR. KUVIN: All right. 
10 
THE VIDEOGRAPHER: Off the record at 2:16. 
11 
(A brief recess was taken.) 
12 
THE VIDEOGRAPHER: We're back on the record at 
13 
2:45. 
14 
BY MR. KUVIN: 
15 
Q. 
Okay. Do you recognize the person that's 
16 
shown in Exhibit 16? 
17 
A. 
Yes. 
18 
Q. 
Who is that? 
19 
A. 
Prince Andrew. 
20 
Q. 
And how do you know Prince Andrew? 
21 
A. 
I'm going to have to respond to that question 
22 
the same way I've responded to most of your questions 
23 
here today, Mr. Kuvin, which is, I intend to respond to 
24 
all relevant questions regarding this lawsuit; however, 
25 
at the present time, my attorneys have counseled me I 
0203 
1 
cannot provide answers to any questions relevant to this 
2 
lawsuit. I must accept their advice or risk losing my 
3 
6th Amendment right to effective representation. 
4 
Accordingly, I assert my federal constitutional rights 
5 
as guaranteed by the 5th, 6th and 14th Amendment to the 
6 
United States Constitution. 
7 
Q. 
I'm going to show you a document that we'll 
8 
mark as Exhibit 17. 
9 
MR. PIKE: Thank you. 
10 
(Plaintiff's Exhibit No. 17 was marked for 
11 
identification.) 
12 
BY MR. KUVIN: 
13 
Q. 
I'm going to give you a minute to take a look 
14 
at that document and just tell me when you're ready to 
15 
answer any questions about it. 
16 
A. 
Okay. 
17 
Q. 
Okay. First of all, have you seen this letter 
18 
before? 
19 
MR. GOLDBERGER: Attorney-client privilege, 
20 
work product. 
21 
BY MR. KUVIN: 
22 
Q. 
Have you seen this letter before outside of 
23 
the relationship with your attorneys? 
24 
MR. GOLDBERGER: You can answer that question. 
25 
THE WITNESS: No. 
0204 
1 
BY MR. KUVIN: 
2 
Q. 
Do you know Chief of Police Michael Reiter? 
3 
Do you know who he is? 
4 
A. 
I know who he is. 
5 
Q. 
Do you know State Attorney Barry Krischer? 
6 
A. 
I know who he is. 
7 
Q. 
Did you ever speak with Chief of Police 
8 
Michael Reiter in the past? 
9 
A. 
I don't remember. 
10 
Q. 
Did you ever talk to anyone, either at the 
11 
State Attorney's office, yourself, or Michael Reiter 
12 
about the prosecution of your claim without the presence 
13 
of your attorneys? 
EFTA01158601

14 
A. 
No. 
15 
Q. 
Did you ever talk to any of the police that 
16 
worked for the Town of Palm Beach without the presence 
17 
of your attorneys? 
18 
A. 
Explain --
19 
MR. PIKE: Wait one second. 
20 
THE WITNESS: I'm sorry. 
21 
MR. PIKE: Can you state the question again? 
22 
MR. KUVIN: Sure. 
23 
BY MR. KUVIN: 
24 
Q. 
Did you ever speak to any of the police 
25 
officers that worked for the Town of Palm Beach without 
0205 
1 
the presence of your attorneys? 
2 
MR. GOLDBERGER: Is the question, have you 
3 
ever spoken to a Town of Palm Beach police officer? 
4 
Is that the -- can we rephrase it like that? 
5 
MR. KUVIN: Sure. 
6 
MR. GOLDBERGER: Okay. 
THE WITNESS: I've been stopped by the police 
for traffic violations, if that's what you mean. 
BY MR. KUVIN: 
Q. 
Any other times that you had conversations 
with any of the Town of Palm Beach --
A. 
No. 
Q. 
-- police officers? 
A. 
Not that I recall specifically. 
Q. 
Okay. Now, you were housed at the jail after 
your plea of guilty that we had spoke about at the 
beginning of your deposition; is that correct? 
MR. PIKE: Form. 
THE WITNESS: Say it again. 
BY MR. KUVIN: 
Q. 
Yes. You were housed at the local jail here 
in Palm Beach County after your plea of guilty that we 
spoke about at the beginning of your deposition? 
MR. PIKE: Form. 
THE WITNESS: Yes. 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0206 
1 
BY MR. KUVIN: 
2 
Q. 
How long were you there? 
3 
A. 
13 months, approximately. 
4 
Q. 
All right. And of those 13 months, how many 
5 
months were you there where you had to stay there 24 
6 
hours a 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
A. 
I don't recall specifically. 
Q. 
More than a month? 
A. 
Yes. 
Q. 
More than two months? 
A. 
Yes. 
Q. 
More than three months? 
A. 
Yes. 
Q. 
More than four? 
A. 
I think so, I don't remember. 
Q. 
Do you recall when you were provided work 
release, when you were able to leave during the daylight 
hours? 
A. 
Not with specificity. 
Q. 
While you were there at the jail in Palm 
Beach -- I'm going to show you what we'll mark as 
Exhibit 18. 
(Plaintiff's Exhibit No. 18 was marked for 
identification.) 
EFTA01158602

25 
0207 
1 
BY MR. KUVIN: 
2 
Q. 
Did you purchase items from the jail? 
3 
MR. GOLDBERGER: Hang on a second. 
4 
MR. PIKE: Hold on one second. 
5 
THE WITNESS: It looks that way, yes, sir. 
6 
BY MR. KUVIN: 
7 
Q. 
Okay. 
8 
MR. PIKE: And the document speaks for itself, 
9 
the composite document speaks for itself. 
10 
BY MR. KUVIN: 
11 
Q. 
I'd like you to take a look at Exhibit 18. It 
12 
shows purchases -- well, does it show purchases by you? 
13 
MR. PIKE: Asked and answered. 
14 
THE WITNESS: Yes. 
15 
BY MR. KUVIN: 
16 
Q. 
Okay. And it appears those purchases took 
17 
place from 7/8/08 through 9/30/08 is the last one that I 
18 
have; is that correct? 
19 
MR. PIKE: The document speaks for itself. 
20 
BY MR. KUVIN: 
21 
Q. 
You can answer. 
22 
A. 
The document speaks for itself. 
23 
Q. 
Is that correct, the last date is 9/30/08? 
24 
A. 
The last date here is 9/30, yes. 
25 
MR. PIKE: With regard to what you provided to 
0208 
1 
the witness. 
2 
MR. KUVIN: Sure, absolutely. 
3 
THE WITNESS: Okay. 
4 
BY MR. KUVIN: 
5 
Q. 
And just so we're clear, this composite 
6 
exhibit that we've marked as Exhibit 18 contains 
purchases from 7/8/08, 7/15, 7/22, 7/29, 8/5, 8/12, 
8/21, 8/26, 9/2, 9/9, 9/23 and 9/30, just so the record 
is clear; there is no question. 
A. 
Okay. 
Q. 
Okay? 
A. 
Uh-huh. 
Q. 
All right. These items that you purchased, 
did you utilize all of these items yourself? 
MR. PIKE: Form, relevance. 
THE WITNESS: I don't understand the question. 
BY MR. KUVIN: 
Q. 
Well, you purchased a number of items that are 
shown in this receipt. 
A. 
Yes. 
Q. 
The question is: Did you use them yourself? 
MR. PIKE: Same objection. 
THE WITNESS: I don't know if I used all of 
them, so... 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0209 
1 
BY MR. KUVIN: 
2 
Q. 
Well, what did you do with the items that you 
3 
purchased? 
4 
MR. PIKE: Form, overbroad. 
5 
BY MR. KUVIN: 
6 
Q. 
You can answer. 
7 
A. 
I used some, I threw away some. 
8 
Q. 
Did you give any away? 
9 
A. 
Not that I remember. 
EFTA01158603

10 
MR. PIKE: Same objection. 
11 
BY MR. KUVIN: 
12 
Q. 
Did you provide any items that you purchased 
13 
to other inmates while you were there in jail? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: Not to the best of my 
16 
recollection. 
17 
BY MR. KUVIN: 
18 
Q. 
Okay. With respect to all of the items that 
19 
are listed in these receipts, is it a safe assumption 
20 
that you either used them yourself or threw them away? 
21 
MR. PIKE: Asked and answered. If you don't 
22 
know -- if you know. 
23 
THE WITNESS: I don't know. 
24 
BY MR. KUVIN: 
25 
Q. 
I'm sorry? I didn't hear you. 
0210 
1 
MR. PIKE: Asked and answered. 
2 
THE WITNESS: So should I answer? 
3 
MR. PIKE: You can answer again. 
4 
THE WITNESS: Ask the question again. 
5 
BY MR. KUVIN: 
6 
Q. 
So can we assume that all of the items that 
7 
are shown in these receipts were either used by you or 
8 
thrown away? 
9 
A. 
I don't even know if I received some of those 
10 
items, so I would assume I used most of them. 
11 
Q. 
Okay. 
12 
A. 
Okay? 
13 
Q. 
Sure. Take a look, I just want to make sure, 
14 
did you receive all these items? 
15 
A. 
I don't know. 
16 
MR. PIKE: Asked and answered. 
17 
BY MR. KUVIN: 
18 
Q. 
How did you purchase them? 
19 
A. 
I filled out a form. 
20 
Q. 
And how were they provided to you? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: Sometimes they would come in a 
23 
bag. 
24 
BY MR. KUVIN: 
25 
Q. 
Okay. And did you determine whether or not 
0211 
1 
the form you filled out, the information or the product 
2 
that you put on that form actually was provided? 
3 
A. 
No, never. 
4 
Q. 
If we look at the items that are contained 
5 
within these receipts, I'd like you to go, if you would, 
6 
to the second invoice here dated 7/15/08. The third 
7 
item down is a Lubriderm lotion. 
8 
A. 
Yes. 
9 
Q. 
Do you see that? 
10 
A. 
Yes. 
11 
Q. 
Did you purchase that? 
12 
A. 
It appears so. 
13 
Q. 
Did you receive it? 
14 
A. 
I don't remember. 
15 
Q. 
Did you use the Lubriderm lotion that you 
16 
received or that you may have received in jail? 
17 
MR. PIKE: Form. 
18 
BY MR. KUVIN: 
19 
Q. 
Let me strike that and re-ask it. 
20 
A. 
Okay. 
EFTA01158604

21 
Q. 
Did you use the Lubriderm lotion which you had 
22 
purchased from the jail while you were there? 
23 
A. 
I might have. 
24 
Q. 
What for? 
25 
A. 
To moisturize my hands and face. 
0212 
1 
Q. 
Okay. Did you use Lubriderm lotion while you 
2 
were in jail to masturbate at all? 
3 
A. 
No. 
4 
MR. PIKE: Form objection, harassing. 
5 
THE WITNESS: Absolutely not. 
6 
BY MR. KUVIN: 
7 
Q. 
It appears, if you would turn to 7/29/08, 
8 
which is approximately two weeks later, and the second 
9 
thing down is another bottle of Lubriderm lotion. Do 
10 
you see that? 
11 
A. 
Yes. 
12 
Q. 
What did you use that for? 
13 
MR. PIKE: Asked and answered. 
14 
MR. KUVIN: It's a second bottle. 
15 
MR. PIKE: It's the same question, Spencer. 
16 
Can we get to something relevant? 
17 
THE WITNESS: No problem. 
18 
MR. PIKE: He can answer. 
19 
THE WITNESS: My hands and my face. 
20 
BY MR. KUVIN: 
21 
Q. 
Okay. 
22 
A. 
I believe the first bottle went missing. 
23 
Q. 
If we turn to approximately one month later on 
24 
8/21/08, do you have that one? 
25 
A. 
Yes. 
0213 
1 
Q. 
All right. On that occasion, you bought two 
2 
bottles of hand lotion again. 
3 
A. 
Yes. 
4 
Q. 
What did you use those for? 
5 
A. 
Nothing. 
6 
Q. 
What did you do with them? 
7 
A. 
They were bought by accident. 
8 
Q. 
How did you buy them by accident? 
9 
A. 
Because you fill out a check form and 
10 
sometimes the forms don't make any sense, they just 
11 
deliver in other things. 
12 
Q. 
Sir, did you get those two bottles? 
13 
A. 
Yes. Yes. 
14 
Q. 
And you never used them? 
15 
A. 
No. I threw them away. 
16 
Q. 
Okay. If we turn to 9/9/08, do you see that 
17 
entry? 
18 
A. 
Yes. 
19 
Q. 
All right. And another invoice here, on that 
20 
date a bottle of hand lotion, do you see that? 
21 
A. 
Yes, I do. 
22 
Q. 
Did you get it? 
23 
A. 
I don't know. 
24 
Q. 
Do you know if you used it? 
25 
A. 
Definitely not. 
0214 
1 
Q. 
How do you know you definitely did not use it? 
2 
A. 
Because it was not -- anything that said hand 
3 
lotion I did not use, I threw in the garbage. 
4 
Q. 
Why is that? 
5 
A. 
Because it wasn't something that I had 
EFTA01158605

6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0215 
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 
0216 
1 
2 
3 
4 
5 
6 
ordered. 
MR. PIKE: Can I -- can I just have an 
agreement that the objections to this line of 
questioning is irrelevant, so I don't have to 
MR. KUVIN: Sure. 
MR. PIKE: -- interrupt. 
MR. KUVIN: Sure. 
MR. PIKE: Agreed? 
MR. KUVIN: Agreed. 
BY MR. KUVIN: 
Q. 
Let's turn again to 9/30/08, the last invoice 
in there. 
A. 
Yes. 
Q. 
Do you see there is an entry for two more 
bottles of hand lotion. Do you see that? 
A. 
Correct. 
Q. 
What did you do with those? 
A. 
To the best of my knowledge, I threw them 
right away. 
Q. 
You didn't use them for anything? 
A. 
No. 
Q. 
Is it your testimony here today that you did 
not use any of the bottles of hand lotion or Lubriderm 
lotion that we had previously just gone through to 
masturbate while you were in jail? 
A. 
That's correct. 
Q. 
Did Ghislaine Maxwell visit you in jail? 
A. 
No. 
Q. 
Did 
visit you while you were 
in jail? 
A. 
I intend to respond to all relevant questions 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled me I cannot provide answers to 
any questions relevant to this lawsuit. I must accept 
this advice or risk losing my 6th Amendment right to 
effective representation. Accordingly, I assert my 
federal constitutional rights as guaranteed by the 5th, 
6th and 14th Amendment to the United States 
Constitution. 
Q. 
Did you have sex with 
while 
you were housed at the Palm Beach jail facility? 
MR. PIKE: Form. 
THE WITNESS: I intend to respond to all 
relevant questions regarding this lawsuit; however, 
at the present time, my attorneys have counseled me 
I cannot provide answers to any questions relevant 
to this lawsuit. As I've answered most of your 
question today, Mr. Kuvin, I must accept this 
advice or risk losing my 6th Amendment right to 
effective representation. Accordingly, I assert my 
federal constitutional rights as guaranteed by the 
7 
5th, 6th and 14th Amendments to the United States 
8 
Constitution. 
9 
BY MR. KUVIN: 
10 
Q. 
Did you pay girls so that they would not 
11 
testify against you in the civil proceedings that have 
12 
been filed in both Federal and State Court? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: Okay. Like most of your other 
15 
questions here today, Mr. Kuvin, I'm going to 
16 
respond by saying I intend to respond to all 
EFTA01158606

17 
relevant questions regarding this lawsuit; however, 
18 
at the present time, my attorneys have counseled me 
19 
I cannot provide answers to any questions relevant 
20 
to this lawsuit. I must accept this advice or risk 
21 
losing my 6th Amendment right to effective 
22 
representation. Accordingly, I must assert my 
23 
federal constitutional rights as guaranteed by the 
24 
5th, 6th and 14th Amendments to the United States 
25 
Constitution. 
0217 
1 
BY MR. KUVIN: 
2 
Q. 
Did you have sex with 
when 
3 
she was under the age of 14? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: I intend to respond to all 
6 
relevant questions regarding this lawsuit; however, 
7 
at the present time, my attorneys have counseled me 
8 
I cannot provide answers to any questions relevant 
9 
to this lawsuit. I must accept this advice or risk 
10 
losing my 6th Amendment right to effective 
11 
representation. Accordingly, I must assert my 
12 
federal constitutional rights as guaranteed by the 
13 
5th, 6th and 14th Amendment to the Constitution. 
14 
BY MR. KUVIN: 
15 
Q. 
Did you tell people that 
was 
16 
your sex slave? 
17 
MR. PIKE: Same objection. 
18 
THE WITNESS: I intend to respond to all 
19 
relevant questions regarding this lawsuit; however, 
20 
at the present time, my attorneys have counseled me 
21 
I cannot provide answers to any questions relevant 
22 
to this lawsuit. I must accept this advice or risk 
23 
losing my 6th Amendment right to effective 
24 
representation. Accordingly, I must assert my 
25 
federal constitutional rights as guaranteed by the 
0218 
1 
5th, 6th and 14th Amendment to the United States 
2 
Constitution. Excuse me. 
3 
MR. KUVIN: This is 19. 
4 
(Plaintiff's Exhibit No. 19 was marked for 
5 
identification.) 
6 
BY MR. KUVIN: 
7 
Q. 
I have an FAA registry for a Boeing 727, 
8 
manufacture year 1969, with -- I'm just looking for the 
9 
tail number here. I'm sorry, I'm just trying to find 
10 
the tail number. 
11 
A. 
Not a problem. 
12 
Q. 
Let's do this, it's a Mode S Code 53106661. 
13 
I'll show this to your counsel first. 
14 
Here it is, I'm sorry, Tail No. N908JE. 
15 
There's no question pending just yet. 
16 
MR. PIKE: Thank you. 
17 
Okay. 
18 
BY MR. KUVIN: 
19 
Q. 
Let me show you what we marked as Exhibit 19. 
20 
I'll give you a minute to take a look at that. 
21 
A. 
Okay. 
22 
Q. 
What is JA 
EGE, Inc.? 
23 
A. 
I intend to respond to all relevant questions 
24 
regarding this lawsuit; however, at the present time, my 
25 
attorneys have counseled me I cannot provide answers to 
0219 
1 
any questions relevant to this lawsuit. I must accept 
EFTA01158607