EFTA01158588

2 
this advice or risk losing my 6th Amendment right to 
3 
effective representation. Accordingly, as I've done 
4 
with most of your questions, I must assert my federal 
5 
constitutional rights as guaranteed by the 5th, 6th and 
6 
14th Amendment to the United States Constitution. 
7 
Q. 
Mr. Epstein, are you aware that after 
8 
September 11, 2001 that the Federal Government started 
9 
tracking all flights of all public and private aircraft? 
10 
MR. PIKE: Form, relevance. 
11 
BY MR. KUVIN: 
12 
Q. 
Are you aware of that? 
13 
A. 
No. 
14 
Q. 
Okay. Are you aware that the FAA keeps track 
15 
of all flights that are made both within the continental 
16 
US and from the continental US abroad? 
17 
MR. PIKE: Same objection. 
18 
THE WITNESS: No. 
19 
BY MR. KUVIN: 
20 
Q. 
Do you know whether or not -- let me ask it 
21 
this way: Have you ever seen the flight tracking 
22 
information for any planes that you may own? 
23 
A. 
I don't believe so. 
24 
Q. 
Is JEGE, Inc. a company that is owned by you? 
25 
A. 
I'll have to answer that question the way I've 
0220 
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 
0221 
1 
Q. 
Isn't is true, sir, that you flew to Thailand 
2 
in 2001? 
3 
MR. PIKE: Form. 
4 
THE WITNESS: I intend to respond to all 
5 
relevant questions regarding this lawsuit; however, 
6 
at the present time, my attorneys have counseled me 
7 
I cannot provide answers to any questions relevant 
8 
to this lawsuit. I must accept this advice or risk 
9 
losing my 6th Amendment right to effective 
10 
representation. Accordingly, I assert my federal 
11 
constitutional rights as guaranteed by the 5th, 6th 
12 
and 14th Amendment to the United States 
answered 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 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. 
The plane that is identified in the FAA 
registry in the document marked Exhibit 19, just so 
we're clear, because I don't think I asked it exactly, 
but is this your plane? 
A. 
I'm going to answer that question the same way 
I've answered most of your 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 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. 
EFTA01158608

13 
14 
BY 
15 
16 
with 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0222 
1 
federal constitutional rights as guaranteed by the 
2 
5th, 6th and 14th Amendment to the United States 
3 
Constitution. 
4 
BY MR. KUVIN: 
5 
Q. 
Isn't it true that you went to Thailand in 
6 
2001 so that you could engage in sexual relations with 
7 
girls under the age of 16 with Prince Andrew without any 
8 
fear of any legal recourse? 
9 
MR. PIKE: Same objection. In addition, 
10 
improper hypothetical, lack of predicate, 
11 
foundation, argumentative, harassing. 
12 
THE WITNESS: I intend to respond to all 
13 
relevant questions regarding this lawsuit; however, 
14 
at the present time, my attorneys have counseled me 
15 
I cannot provide answers to any questions relevant 
16 
to this lawsuit. I must accept this advice or risk 
17 
losing my 6th Amendment right to effective 
18 
representation. Accordingly, I must 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. 
Have you seen the photographs of you and 
24 
Prince Andrew while you were in Thailand with half naked 
25 
women, some of which were under the age of 16? 
0223 
1 
MR. PIKE: Same objections. 
2 
THE WITNESS: I intend --
3 
MR. PIKE: Relevance as well, excuse me. I'm 
4 
sorry. 
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 assert my federal 
12 
constitutional rights as guaranteed by the 5th, 6th 
13 
and 14th Amendments to the United States 
14 
Constitution. 
15 
BY MR. KUVIN: 
16 
Q. 
Did you bring any young women on the plane 
17 
with you when you went to Thailand in 2001? 
18 
MR. PIKE: Same objection. 
19 
THE WITNESS: I intend to respond to all 
20 
relevant questions regarding this lawsuit; however, 
21 
at the present time, my attorneys have counseled me 
22 
I cannot provide answers to any questions relevant 
23 
to this lawsuit. I must accept this advice or risk 
Constitution. 
MR. KUVIN: 
Q. 
Is it true that you went to Thailand in 2001 
Prince Andrew? 
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, and as I've done for most of all 
your questions today, Mr. Kuvin, I must accept this 
advice or risk losing my 6th Amendment right to 
effective representation. Accordingly, I assert my 
EFTA01158609

24 
losing my 6th Amendment right to effective 
25 
representation. Accordingly, I assert my federal 
0224 
1 
constitutional rights as guaranteed by the 5th, 6th 
2 
and 14th Amendments to the United States 
3 
Constitution. 
4 
BY MR. KUVIN: 
5 
Q. 
Have you bragged to people before that you 
6 
bought -- brought 
to the United States 
7 
to be your Yugoslavian sex slave? 
8 
A. 
I intend to respond to all relevant questions 
9 
regarding this lawsuit; however, at the present time, my 
10 
attorneys have counseled me I cannot provide answers to 
11 
any questions relevant to this lawsuit. I must accept 
12 
their advice or risk losing my 6th Amendment right to 
13 
effective representation. Accordingly, I must assert my 
14 
federal constitutional rights as guaranteed by the 5th, 
15 
6th and 14th Amendments to the United States 
16 
Constitution. 
17 
Q. 
Have you had --
18 
MR. GOLDBERGER: You raised the same objection 
19 
to that question, right? 
20 
MR. PIKE: Yeah, I did. 
21 
BY MR. KUVIN: 
22 
Q. 
Have you had sex with numerous girls under the 
23 
age of 18 in the presence of 
24 
MR. PIKE: Same objections. 
25 
THE WITNESS: I'm going to answer that the 
0225 
1 
same way I've answered most of your questions here 
2 
today, Mr. Kuvin, which is, I intend to respond to 
3 
all relevant questions regarding this lawsuit; 
4 
however, at the present time, my attorneys have 
5 
counseled me I cannot provide answers to any 
6 
questions relevant to the lawsuit. I must accept 
7 
their advice or risk losing my 6th Amendment right 
8 
to effective representation. Accordingly, I assert 
9 
my federal constitutional rights as guaranteed by 
10 
the 5th, 6th and 14th Amendments to the United 
11 
States Constitution. 
12 
BY MR. KUVIN: 
13 
Q. 
What is MC2? 
14 
MR. PIKE: Same objection. 
15 
THE WITNESS: I don't understand the question. 
16 
BY MR. KUVIN: 
17 
Q. 
MC and then a number 2, what is that? 
18 
MR. PIKE: Lack of predicate, foundation. 
19 
THE WITNESS: What is that? 
20 
MR. PIKE: Irrelevant. 
21 
BY MR. KUVIN: 
22 
Q. 
Do you know what it is? 
23 
A. 
No. 
24 
Q. 
You've never heard of that before? 
25 
A. 
MC2? 
0226 
1 
Q. 
Yeah. Capital M, capital C, number 2; sound 
2 
familiar at all? 
3 
A. 
No. 
4 
Q. 
Okay. Are you part owner in a teen modeling 
5 
agency? 
6 
A. 
No. 
7 
Q. 
Do you own any interest in any modeling 
8 
agencies currently? 
EFTA01158610

9 
A. 
I intend to respond to all relevant questions 
10 
regarding this lawsuit; however, at the present time, my 
11 
attorneys have counseled me I cannot provide answers to 
12 
any questions relevant to this lawsuit. I must accept 
13 
this advice or risk losing my 6th Amendment right to 
14 
effective representation. Accordingly, I assert my 
15 
federal constitutional rights as guaranteed by the 5th, 
16 
6th and 14th Amendments to the United States 
17 
Constitution. 
18 
Q. 
Do you know what a sexual device called a Twin 
19 
Torpedo is? 
20 
MR. PIKE: Same objections, irrelevant as 
21 
worded. 
22 
THE WITNESS: Would you like to ask me a bunch 
23 
of questions or are we going to -- do you want to 
24 
individual answers to these? Do you want a 
25 
compound question? 
0227 
1 
BY MR. KUVIN: 
2 
Q. 
I can do it that way, it doesn't matter to me. 
3 
THE WITNESS: It's up to you. 
4 
MR. KUVIN: It's up to you guys. 
5 
MR. PIKE: As I've said, Mr. Kuvin, if you 
6 
want to limit the time that we spend here today and 
7 
ask a compound question if you're going to list 
8 
various items or list individuals by name and ask 
9 
questions, I won't have a compound objection to 
10 
that type of inquiry if it's in light of attempting 
11 
to save time. 
12 
MR. KUVIN: Sure. 
13 
BY MR. KUVIN: 
14 
Q. 
All righty. 
15 
MR. PIKE: But that's limited to the compound 
16 
objection. 
17 
MR. KUVIN: Oh, no, that's fine. 
18 
BY MR. KUVIN: 
19 
Q. 
All right. Did you purchase something called 
20 
a Twin Torpedo, a soap made in the shape of a penis, and 
21 
a soap in the shape of a vagina? 
22 
A. 
I'm going to answer that question like I've 
23 
answered most of your questions here today, which is, I 
24 
intend to respond to all relevant questions regarding 
25 
this lawsuit; however, at the present time, my attorneys 
0228 
1 
have counseled me that I cannot provide answers to any 
2 
questions relevant to this lawsuit. I must accept this 
3 
advice or risk losing my 6th Amendment right to 
4 
effective representation. Accordingly, I assert my 
5 
federal constitutional rights as guaranteed by the 5th, 
6 
6th and 14th Amendment to the United States 
7 
Constitution. 
8 
MR. PIKE: Additionally, just for the Court's 
9 
record, you're questioning the witness on Exhibit 
10 
No. what? 
11 
MR. KUVIN: It's not an exhibit. It's the 
12 
Town of Palm Beach Incident Report with respect to 
13 
Jeffrey Epstein, of which I gave you a copy before. 
14 
And that was referencing, just so the record is 
15 
clear, page 46. 
16 
MR. PIKE: Then I would add additional 
17 
privileges and objections in addition to what 
18 
Mr. Epstein has already raised underneath Florida 
19 
Rule of Criminal Procedure 3.220 and work product. 
EFTA01158611

20 
Not necessarily the document in front of you, but 
21 
the questions and the answer you're attempting to 
22 
elicit. 
23 
BY MR. KUVIN: 
24 
Q. 
Whose mobile wireless number is 
? 
25 
A. 
I intend to respond to all relevant questions 
0229 
1 
regarding this lawsuit; however, at the present time, my 
2 
attorneys have counseled me I cannot provide answers to 
3 
any questions relevant to this lawsuit. I must accept 
4 
this advice or risk losing my 6th Amendment right to 
5 
effective representation. Accordingly, I hereby assert 
6 
my federal constitutional rights as guaranteed by the 
7 
5th, 6th and 14th Amendments to the United States 
8 
Constitution. 
9 
Q. 
I'm going to read you, for speed's sake, three 
10 
separate phone numbers, and it's the same question for 
11 
each. Do you recognize the following phone numbers? 
12 
They all have Area Code III. The first one is 
. 
13 
the second is 
, and the third is 
. 
14 
A. 
I intend to respond to all relevant questions 
15 
regarding this lawsuit; however, at the present time, my 
16 
attorneys have counseled me I cannot provide answers to 
17 
any questions relevant to this lawsuit. I must accept 
18 
this advice or risk losing my 6th Amendment right to 
19 
effective representation. Accordingly, I must assert my 
20 
federal constitutional rights as guaranteed by the 5th, 
21 
6th and 14th Amendments to the United States 
22 
Constitution. 
23 
Q. 
Did 
have the phone number 
24 
or 
or III -- I'm sorry, same number 
25 
again. So two numbers: Either 
or 
? 
0230 
1 
A. 
I intend to respond to all relevant questions 
2 
regarding this lawsuit; however, at the present time, my 
3 
attorneys have counseled me I cannot provide answers to 
4 
any questions relevant to the lawsuit. I must accept 
5 
this advice or risk losing my 6th Amendment right to 
6 
effective representation. Accordingly, I must assert my 
7 
federal constitutional rights as guaranteed by the 5th, 
8 
6th and 14th Amendments to the Constitution. 
9 
Q. 
Do you have an egg-shaped penis? 
10 
A. 
I intend to respond to all relevant questions 
11 
regarding this lawsuit; however, at the present time, my 
12 
attorneys have counseled me I cannot provide answers to 
13 
any questions that may be relevant to this lawsuit. I 
14 
must accept this advice or risk losing my 6th Amendment 
15 
right to effective representation. Accordingly, I must 
16 
assert my federal constitutional rights as guaranteed by 
17 
the 5th, 6th and 14th Amendment to the United States 
18 
Constitution. 
19 
Q. 
Do you have any identifying marks on your 
20 
penis? 
21 
A. 
I intend to respond to all relevant questions 
22 
regarding this lawsuit; however, at the present time, my 
23 
attorneys have counseled me I cannot provide answers to 
24 
any questions relevant to the lawsuit. I must accept 
25 
their advice or risk losing my 6th Amendment right to 
0231 
1 
effective representation. Accordingly, I hereby assert 
2 
my federal constitutional rights as guaranteed by the 
3 
5th, 6th and 14th Amendments to the United States 
4 
Constitution. 
EFTA01158612

5 
6 
7 
8 
9 
10 
11 
12 
BY 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0232 
1 
BY MR. KUVIN: 
2 
Q. 
Did you ever utilize Dollar-Rent-a-Car to rent 
3 
cars while you were here in Palm Beach at any time? 
4 
A. 
I intend to respond to all relevant questions, 
5 
Mr. Kuvin, regarding this lawsuit; however, at the 
6 
present time, my attorneys have counseled me I cannot 
7 
provide answers to any questions that may prove relevant 
8 
to this lawsuit. I must accept this advice or risk 
9 
losing my 6th Amendment right to effective 
10 
representation. Accordingly, I must assert my federal 
11 
constitutional rights as guaranteed by the 5th, 6th and 
12 
14th Amendment to the United States Constitution. 
13 
Q. 
What was your personal cell phone carrier back 
14 
in 2004? 
15 
A. 
I intend to respond to all relevant questions 
16 
regarding this lawsuit. 
17 
Q. 
Let me make this quicker. I'm sorry for 
18 
interrupting you, I apologize. Let's say, what was your 
19 
cell phone carrier back from 2004 through 2006. 
20 
MR. PIKE: And I'm not objecting to compound; 
21 
however, there are various allegations in your 
22 
complaint regarding a time frame. So therefore, 
23 
with regard to the allegations in your complaint, 
24 
relative to your question, I'm not objecting to the 
25 
compound, I'm saying it's overbroad. 
0233 
1 
MR. KUVIN: 2004 to 2006? 
2 
MR. PIKE: Overbroad and irrelevant based upon 
3 
the allegations that you've alleged. 
4 
MR. KUVIN: All right. Well, let me clarify 
5 
the question then. 
6 
BY MR. KUVIN: 
7 
Q. 
What was your cell phone carrier from 2004 to 
8 
2005? 
9 
MR. PIKE: Same objections. 
10 
BY MR. KUVIN: 
11 
Q. 
Well, let me try and fix it again. What was 
12 
your cell phone carrier from 2005 to 2006? 
13 
MR. PIKE: Relevance. 
14 
THE WITNESS: I intend to respond to all 
15 
relevant questions regarding this lawsuit; however, 
MR. PIKE: In addition, same objection and 
privilege which regard to the Florida Rule of 
Procedure 3.220 and work product. Not necessarily 
the document you're talking or speaking from, but 
the testimony. 
MR. KUVIN: I was just reading this. I wasn't 
asking questions from this at the moment. 
MR. KUVIN: 
Q. 
Does your penis have any deformities? 
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 the 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 Constitution, as I've 
done with most of your questions here today. 
EFTA01158613

16 
at the present time, my attorneys have counseled me 
17 
I cannot provide answers to any questions relevant 
18 
to this lawsuit. I must accept their advice or 
19 
risk losing my 6th Amendment right to effective 
20 
representation; therefore, I must assert my federal 
21 
constitutional rights as guaranteed by the 5th, 6th 
22 
and 14th Amendments to the United States 
23 
Constitution. 
24 
BY MR. KUVIN: 
25 
Q. 
What were the cell phone carriers of 
or Ghislaine Maxwell from the 
2 
years 2005 to 2006? 
3 
MR. PIKE: Relevance. 
4 
THE WITNESS: I intend to respond to all 
5 
relevant questions regarding this lawsuit. As I've 
6 
answered most of your questions the same way today, 
7 
Mr. Kuvin, at the present time, my attorneys have 
8 
counseled me I cannot provide answers to any of 
9 
your questions that may be relevant to this 
10 
lawsuit. I must accept this advice or risk losing 
11 
my 6th Amendment right to effective representation. 
12 
Therefore, accordingly, I assert my federal 
13 
constitutional rights as guaranteed by the 5th, 6th 
14 
and 14th Amendment to the United States 
15 
Constitution. 
16 
May we take a break, please? 
17 
MR. KUVIN: Sure. 
18 
MR. PIKE: Yes. 
19 
MR. GOLDBERGER: Yes. 
20 
THE VIDEOGRAPHER: Going off the record at 
21 
3:21. 
22 
(A brief recess was taken.) 
23 
THE VIDEOGRAPHER: We're back on the record at 
24 
3:30. 
25 
0235 
1 
BY MR. KUVIN: 
2 
Q. 
Here, let me move this out of the way. 
3 
A. 
You can take your Joy Jelly home now. 
4 
Q. 
It's actually an exhibit to your deposition. 
5 
A. 
Sorry. 
6 
Q. 
Have you read the police department's, the 
7 
Palm Beach Police Department's, probable cause 
8 
affidavit? Have you ever read it? 
9 
MR. PIKE: Attorney-client, work privilege. 
10 
BY MR. KUVIN: 
11 
Q. 
Have you ever read the police department, Palm 
12 
Beach Police Department's incident report regarding you? 
13 
MR. PIKE: Same objection. 
14 
MR. GOLDBERGER: Same objection. 
15 
MR. PIKE: And instruction, I'm sorry. 
16 
BY MR. KUVIN: 
17 
Q. 
Are you circumcised? 
18 
MR. PIKE: Objection, relevance. 
19 
THE WITNESS: I intend to respond to all 
20 
relevant questions regarding this lawsuit; however, 
21 
at the present time, my attorneys have counseled me 
22 
I cannot provide answers to any questions relevant 
23 
to this lawsuit. I must accept this advice or risk 
24 
losing my 6th Amendment right to effective 
25 
representation. Accordingly, I assert my federal 
0236 
EFTA01158614

1 
constitutional rights as guaranteed by the 5th, 6th 
2 
and 14th Amendments to the United States 
3 
Constitution. 
4 
BY MR. KUVIN: 
5 
Q. 
Was a search warrant performed and executed at 
6 
your home on Palm Beach Island? 
7 
MR. GOLDBERGER: Attorney-client, work 
8 
privilege. 
9 
I'll instruct you not to answer. 
10 
BY MR. KUVIN: 
11 
Q. 
Do you know 
spelled 
, 
12 
; Daniel Estes, spelled E-S-T-E-S; or Douglas 
13 
Schoettle, S-C-H-O-E-T-T-L-E? 
14 
A. 
I intend to respond to all relevant questions 
15 
regarding this lawsuit; however, at the present time, my 
16 
attorneys have counseled me I cannot provide answers to 
17 
any questions relevant to this lawsuit. And as I've 
18 
answered most of your questions today, Mr. Kuvin, I must 
19 
accept this advice and risk losing -- or risk losing my 
20 
6th Amendment right to effective representation. 
21 
Accordingly, I assert my federal constitutional rights 
22 
as guaranteed by the 5th, 6th and 14th Amendments to the 
23 
United States Constitution. 
24 
Q. 
Did you have a chef working for you at your 
25 
Palm Beach home back in 2005? 
0237 
1 
A. 
I intend to respond to all relevant questions 
2 
regarding this lawsuit; however, at the present time, my 
3 
attorneys have counseled me I cannot provide answers to 
4 
any questions relevant to this lawsuit at this time. I 
5 
must accept their advice or risk losing my 6th Amendment 
6 
right to effective representation. Accordingly, I must 
7 
assert my federal constitutional rights as guaranteed by 
8 
the 5th, 6th and 14th Amendment to the United States 
9 
Constitution. 
10 
MR. PIKE: Additionally, predicate and 
11 
foundation. 
12 
BY MR. KUVIN: 
13 
Q. 
Did you own or do you currently own a 2004 
14 
black Chevy Suburban, bearing Florida tag X99-EGL? 
15 
A. 
I intend to respond to all relevant questions 
16 
regarding this lawsuit; however, at the present time, my 
17 
attorneys have counseled me I cannot provide answers to 
18 
any questions that may be relevant to the lawsuit. I 
19 
must accept their advice or risk losing my 6th Amendment 
20 
right to effective representation; therefore, I assert 
21 
my federal constitutional rights as guaranteed by the 
22 
5th, 6th and 14th Amendment to the United States 
23 
Constitution. 
24 
Q. 
I think I asked this before, and I apologize 
25 
if I did, but your date of birth is January 20, 1953, 
0238 
1 
correct? 
2 
A. 
You asked that before. 
3 
Yes, correct. 
4 
Q. 
Okay, I'm sorry. 
5 
Do you own a -- or did you own -- let me 
6 
clarify. 
7 
A. 
Do you want to do compound again? 
8 
Q. 
Yeah. Did you or do you currently own a 2005 
9 
black Cadillac Escalade ESV, bearing Florida license tag 
10 
Q29-9GT? 
11 
A. 
I intend to respond to all relevant questions 
EFTA01158615

12 
regarding this lawsuit; however, at the present time, my 
13 
attorneys have counseled me I cannot provide answers to 
14 
any questions that may be relevant to the lawsuit. I 
15 
must accept their advice or risk losing my 6th Amendment 
16 
right to effective representation. Accordingly, I 
17 
assert my federal constitutional rights as guaranteed by 
18 
the 5th, 6th and 14th Amendment to the United States 
19 
Constitution. 
20 
Q. 
Have you hired attorneys for either 
21 
, Ghislaine Maxwell, 
or any 
22 
other --
23 
MR. GOLDBERGER: Attorney-client, work 
24 
product. 
25 
Are you done? I'm sorry. 
0239 
1 
BY MR. KUVIN: 
2 
Q. 
-- or any other women in this case? 
3 
MR. GOLDBERGER: Okay. Now attorney-client, 
4 
work product. 
5 
I direct you not to answer. 
6 
BY MR. KUVIN: 
7 
Q. 
Do you know the name of the girl that was with 
8 
l'i. when she was brought to your home? 
9 
MR. PIKE: Form, lack of predicate, 
10 
foundation. 
11 
THE WITNESS: Like I've done to many of your 
12 
other questions and responded to many of your other 
13 
questions today, Mr. Kuvin, that question -- I must 
14 
answer that, I intend to answer all relevant 
15 
questions regarding this lawsuit; however, at the 
16 
present time, my attorneys have counseled me I 
17 
cannot provide answers to any questions that may be 
18 
relevant. I must accept this advice or risk losing 
19 
my 6th Amendment right to effective representation; 
20 
therefore, I assert my federal constitutional 
21 
rights as guaranteed by the 5th, 6th and 14th 
22 
Amendment to the Constitution. 
23 
BY MR. KUVIN: 
24 
Q. 
Did you, in fact, give III. $200 for a -- for 
25 
her to get naked and give you a massage while you were 
0240 
1 
naked and, in addition, touch her in her vagina without 
2 
her permission in 2005? 
3 
MR. PIKE: Predicate, foundation --
4 
THE WITNESS: I believe that's been asked and 
5 
answered. 
6 
MR. PIKE: Harassing. And I believe as 
7 
worded, that question has been asked and answered 
8 
in sub parts. I believe you've asked those 
9 
questions initially at the beginning of this 
10 
deposition. The same objections would, therefore, 
11 
apply and be incorporated. 
12 
MR. KUVIN: I disagree, but... 
13 
THE WITNESS: Like most of your other 
14 
questions here today, I intend to respond to all 
15 
relevant questions regarding this lawsuit; however, 
16 
at the present time, my attorneys have counseled me 
17 
I cannot provide answers to any questions that may 
18 
be relevant. I must accept this advice or risk 
19 
losing my 6th Amendment privilege. Accordingly, I 
20 
assert my federal constitutional rights as 
21 
guaranteed by the 5th, 6th and 14th Amendment to 
22 
the US Constitution. 
EFTA01158616

23 
BY MR. KUVIN: 
24 
Q. 
Do you agree, sir, that your conduct, with 
25 
respect to 
caused her severe emotional distress? 
0241 
1 
MR. PIKE: Same objection. In addition, it's 
2 
argumentative, harassing and calls for a 
3 
conclusion. 
4 
THE WITNESS: I'm going to have to answer that 
5 
the same way I've answered most of your questions 
6 
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 the lawsuit. I must accept 
this advice or risk losing my 6th Amendment right 
to effective representation. Accordingly, I must 
assert my federal constitutional rights as 
guaranteed by the 5th, 6th and 14th Amendment. 
BY MR. KUVIN: 
Q. 
Do you have gray chest hair? 
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 of those questions that may be relevant. 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. 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0242 
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 
0243 
Q. 
Have you told young ladies -- girls under the 
age of 18, when they came to your house and got naked to 
give you a massage, quote, the more you do, the more you 
get paid? 
MR. PIKE: Objection, form, predicate, 
foundation, improper hypothetical and assumes facts 
not in evidence, relevance. 
THE WITNESS: Like most of your questions, 
Mr. Kuvin, 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 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. 
BY MR. KUVIN: 
Q. 
Do you have any tattoos? 
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 
1 
effective representation. Accordingly, I must assert my 
2 
federal constitutional rights as guaranteed by the 5th, 
3 
6th and 14th Amendments to the United States 
4 
Constitution. 
5 
Q. 
Do you have a steam room in your home on Palm 
6 
Beach Island? 
7 
MR. PIKE: Same objections. 
EFTA01158617

8 
THE WITNESS: I'm going to answer that 
9 
question the same way I've answered most of your 
10 
questions here today, which is, I intend to respond 
11 
to all relevant questions regarding this lawsuit; 
12 
however, at the present time, my attorneys have 
13 
counseled me that I cannot provide answers to any 
14 
questions relevant to the lawsuit. I must accept 
15 
this advice or risk losing my 6th Amendment right 
16 
to effective representation. Accordingly, I must 
17 
assert my constitutional rights as guaranteed by 
18 
the 5th -- 5th, 6th and 14th Amendments to the 
19 
United States Constitution. 
20 
BY MR. KUVIN: 
21 
Q. 
Did you provide payments to underaged girls by 
22 
utilizing cash and wire transfers through Western Union 
23 
in 2004 or 2005? 
24 
MR. PIKE: Same objections as raised to the 
25 
previous last three questions incorporated here. 
0244 
1 
THE WITNESS: I intend to respond to all 
2 
relevant questions regarding this lawsuit; however, 
3 
at the present time, my attorneys have counseled me 
4 
I cannot provide answers to any questions relevant 
5 
to the lawsuit. I must accept this advice or risk 
6 
losing my 6th Amendment right to effective 
7 
representation. Accordingly, I assert my federal 
8 
constitutional rights as guaranteed by the 5th, 6th 
9 
and 14th Amendment to the United States 
10 
Constitution. 
11 
BY MR. KUVIN: 
12 
Q. 
Did you -- excuse me. Did you take any 
13 
videotapes of girls that were under the age of 18 in 
14 
your home on Palm Beach Island? 
15 
MR. PIKE: Same objections incorporated. 
16 
THE WITNESS: As I have with most of your 
17 
questions today, I'm going to have to answer that, 
18 
I intend to respond to all relevant questions 
19 
regarding this lawsuit; however, at the present 
20 
time, my attorneys have counseled me I cannot 
21 
provide answers to any questions that may be 
22 
relevant to this lawsuit. I must accept this 
23 
advice or risk losing my 6th Amendment right to 
24 
effective representation. Accordingly, I assert my 
25 
federal constitutional rights as guaranteed by the 
0245 
1 
5th, 6th and 14th Amendment to the United States 
2 
Constitution. 
3 
BY MR. KUVIN: 
4 
Q. 
Have you ever provided a dozen roses to a 
5 
young girl under the age of 18 who came to your house to 
6 
give you a massage? 
7 
MR. PIKE: Form, vague, ambiguous, assumes 
8 
facts not in evidence. 
9 
THE WITNESS: I intend to respond to all 
10 
relevant questions regarding this lawsuit; however, 
11 
at the present time, my attorneys have counseled me 
12 
that I cannot provide answers to any questions that 
13 
may be relevant. I must accept their advice or 
14 
risk losing my 6th Amendment right to effective 
15 
representation. Accordingly, I must assert my 
16 
federal constitutional rights as guaranteed by the 
17 
5th, 6th and 14th Amendment. 
18 
BY MR. KUVIN: 
EFTA01158618

19 
Q. 
Did you ever instruct anyone to deliver a 
20 
bucket of roses after a high school drama performance to 
21 
an underaged girl? 
22 
MR. PIKE: Same objection. In addition, lacks 
23 
predicate and foundation. It's overbroad as well. 
24 
THE WITNESS: I fully intend to respond to all 
25 
relevant questions regarding this lawsuit; however, 
0246 
1 
at the present time, my attorneys have counseled me 
2 
that I cannot provide answers to any questions 
3 
relevant to the lawsuit. I must accept their 
4 
advice or risk losing my 6th Amendment right to 
5 
effective representation. Accordingly, I assert my 
6 
federal constitutional rights as guaranteed by the 
7 
5th, 6th and 14th Amendment to the United States 
8 
Constitution. 
9 
BY MR. KUVIN: 
10 
Q. 
Hold on a second. I may be done. 
11 
Do you know a Dr. Kaku, K-A-K-U? 
12 
A. 
I intend to respond to all relevant questions 
13 
regarding this lawsuit; however, at the present time, my 
14 
attorneys have counseled me I cannot provide answers to 
15 
any questions that may be relevant. I must accept this 
16 
advice or risk losing my 6th right to effective 
17 
representation. Accordingly, I assert my federal 
18 
constitutional rights as guaranteed by the 5th, 6th and 
19 
14th Amendment to the United States Constitution. 
20 
MR. PIKE: Can you hold on one second? 
21 
MR. KUVIN: I'm almost done. 
22 
MR. PIKE: No, no. We're not going anywhere. 
23 
MR. KUVIN: Okay. 
24 
MR. PIKE: Okay. 
25 
0247 
1 
MR. KUVIN: Okay. All right, I appreciate 
2 
your patience. That's all the questions that I 
3 
have right now. I know that Mr. Goldberger needs 
4 
to deal with an issue right now with Ms. Ezell 
5 
regarding any further questions. 
6 
MR. GOLDBERGER: I think we clarified that. 
7 
Ms. Ezell, are you there? 
8 
MS. EZELL: I'm here. 
9 
MR. GOLDBERGER: Yeah. You had a discussion 
10 
with Bob Critton already concerning the question 
11 
you raised with me earlier, right? 
12 
MS. EZELL: Yes, I did, and I don't have any 
13 
questions. 
14 
MR. PIKE: Ms. Ezell, this is Michael Pike. I 
15 
don't know what your conversation was with Bob, but 
16 
did you cross notice this deposition? 
17 
MS. EZELL: No, I did not. 
18 
MR. PIKE: So what is your purpose of being 
19 
here? 
20 
My position is that these are closed 
21 
proceedings and your client, your client did not 
22 
cross notice this deposition and/or your clients. 
23 
So what is your purpose of sitting in on this 
24 
deposition? 
25 
MS. EZELL: Well, I received a notice of it, 
0248 
1 
and I just thought I would listen to it while I was 
2 
doing some other work. And I don't know why it 
3 
would be a closed proceeding. 
EFTA01158619

4 
MR. PIKE: Discovery proceedings are closed if 
5 
it's a pre-trial discovery, ma'am, it's not a court 
6 
proceeding. 
7 
Nonetheless, do you have any questions for the 
8 
witness? 
9 
MS. EZELL: No, I don't. 
10 
MR. PIKE: And Ms. Holmes, who are you here on 
11 
behalf of? Which clients? 
12 
MS. HOLMES: III. and III. 
13 
MR. PIKE: Are you also here on behalf of Jane 
14 
Doe in the case 80893? 
15 
MS. HOLMES: I believe so, yes. 
16 
MR. PIKE: Do you have any questions for the 
17 
witness? 
18 
MS. HOLMES: No, I do not. 
19 
MR. GOLDBERGER: Katherine, we're going to 
20 
end. Do you want me to disconnect you now? 
21 
MS. EZELL: Yes, thanks. 
22 
MR. GOLDBERGER: Okay. 
23 
THE VIDEOGRAPHER: Conclude the deposition and 
24 
go off the record at 3:00 --
25 
MR. PIKE: Wait one second. 
0249 
1 
MR. KUVIN: Oh, wait. 
2 
MR. GOLDBERGER: He's just going to read. 
3 
MR. PIKE: You didn't give the witness a 
4 
chance to read or waive and he'll read. 
5 
THE VIDEOGRAPHER: Conclude the deposition and 
6 
go off the record at 3:48. This will be the end of 
7 
tape No. 3. 
8 
9 
(Witness excused.) 
10 
(Deposition was concluded.) 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0250 
1 
CERTIFICATE OF OATH 
2 
THE STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
5 
6 
I, the undersigned authority, certify that 
7 
JEFFREY EPSTEIN personally appeared before me and was 
8 
duly sworn on the 8th day of October, 2009. 
9 
10 
Dated this 8th day of October, 2009. 
11 
12 
13 
14 
EFTA01158620

15 
Jeana Ricciuti, RPR, FPR, CLR 
16 
Notary Public - State of Florida 
My Commission Expires: 2/17/2013 
17 
My Commission No.: DD 854778 
18 
19 
20 
21 
22 
23 
24 
25 
0251 
1 
CERTIFICATE 
2 
THE STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
5 
I, Jeana Ricciuti, Registered Professional 
Reporter and Notary Public in and for the State of 
6 
Florida at large, do hereby certify that I was 
authorized to and did report said deposition in 
7 
stenotype; and that the foregoing pages are a true and 
correct transcription of my shorthand notes of said 
8 
deposition. 
9 
I further certify that said deposition was 
taken at the time and place hereinabove set forth and 
10 
that the taking of said deposition was commenced and 
completed as hereinabove set out. 
11 
I further certify that I am not attorney or 
12 
counsel of any of the parties, nor am I a relative or 
employee of any attorney or counsel of party connected 
13 
with the action, nor am I financially interested in the 
action. 
14 
The foregoing certification of this transcript 
15 
does not apply to any reproduction of the same by any 
means unless under the direct control and/or direction 
16 
of the certifying reporter. 
17 
Dated this 8th day of October, 2009. 
18 
19 
20 
21 
Jeana Ricciuti, RPR, FPR, CLR 
22 
23 
24 
25 
0252 
1 
DATE: 
October 22, 2009 
2 
TO: 
JEFFREY EPSTEIN 
c/o Michael J. Pike 
3 
BURMAN, CRITTON, LUTTIER & COLEMAN, P.A. 
303 Banyan Boulevard 
4 
Suite 400 
West Palm Beach, Florida 33401 
5 
IN RE: 'gm. v. EPSTEIN 
6 
Please take notice that on Thursday, the 8th 
EFTA01158621

7 
of October, 2009, you gave your deposition in the 
above-referred matter. At that time, you did not waive 
8 
signature. It is now necessary that you sign your 
deposition. 
9 
As previously agreed to, the transcript will 
be furnished to you through your counsel. Please read 
10 
the following instructions carefully: 
At the end of the transcript you will find an 
11 
errata sheet. As you read your deposition, any changes 
or corrections that you wish to make should be noted on 
12 
the errata sheet, citing page and line number of said 
change. DO NOT write on the transcript itself. Once 
13 
you have read the transcript and noted any changes, be 
sure to sign and date the errata sheet and return these 
14 
pages to me. 
If you do not read and sign the deposition 
15 
within a reasonable time (i.e., 30 days unless otherwise 
directed) the original, which has already been forwarded 
16 
to the ordering attorney, may be filed with the Clerk of 
the Court. If you wish to waive your signature, sign 
17 
your name in the blank at the bottom of this letter and 
return it to us. 
18 
Very truly yours, 
19 
20 
Jeana Ricciuti, RPR, FPR, CLR 
21 
Prose Court Reporting Agency, INC. 
250 S. Australian Avenue, Ste 1500 
22 
West Palm Beach, Florida 33401 
23 
I do hereby waive my signature. 
24 
25 
JEFFREY EPSTEIN 
0253 
1 
CERTIFICATE 
2 
3 
THE STATE OF FLORIDA 
4 
COUNTY OF PALM BEACH 
5 
I hereby certify that I have read the 
6 
foregoing deposition by me given, and that the 
7 
statements contained herein are true and correct to the 
8 
best of my knowledge and belief, with the exception of 
9 
any corrections or notations made on the errata sheet, 
10 
if one was executed. 
11 
12 
Dated this 
day of  
13 
2009. 
14 
15 
16 
17 
18 
19 
JEFFREY EPSTEIN 
20 
21 
22 
23 
24 
25 
0254 
1 
ERRATA 
SHEET 
2 
IN RE: Ili. v. EPSTEIN CR: JEANA RICCIUTI 
EFTA01158622

3 
DEPOSITION OF: JEFFREY EPSTEIN 
4 
TAKEN: October 8, 2009 
5 
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 
6 
PAGE # LINE # 
CHANGE 
REASON 
7 
8 
9 
10 
11 
12 
13 
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17 
Please forward the original signed errata sheet to this 
office so that copies may be distributed to all parties. 
18 
Under penalty of perjury, I declare that I have read my 
19 
deposition and that it is true and correct subject to 
any changes in form or substance entered here. 
20 
21 
22 
23 
24 
25 
DATE:  
SIGNATURE OF DEPONENT: 
EFTA01158623