EFTA01246464

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UNITED STATES DISTRICT COURT 
1 
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 
SOUTHERN DISTRICT OF FLORIDA 
2 
IN AND FOR PALM BEACH COUNTY. FLORIDA 
CASE NO. 502008CA028051 XXXXMB AB 
CASE NO. 08-CIV-801 19-MARRA/JOHNSON 
3 
4 
JANE DOE NO. 2. 
Plaintiff. 
5 
. 
Plaintiff. 
-vs- 
VOLUME I OF III 
6 
-vs- 
VOLUME I OF III 
JEFFREY EPSTEIN. 
7 
JEFFREY EPSTEIN. 
Defendant 
8 
Defendant. 
I 
I 
9 
Related eases: 
10 
08-80232. 08-08380. 08-80381. 08-80994 
11 
08-80993. 08-8081 1. 08-80893. 0940469 
12 
VIDE TAPED DEPOSITION OF 
09.80591. 09-80656. 09-80802. 09-81092 
r 
13 
14 
VII 
SMON OF 
15 
Wednesday. March 24.2010 
MMI
10:37 - 6:51 p.m. 
16 
Wednesday. March 24. 2010 
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10:37 - 6:51 p.m. 
18 
250 Australian Avenue South 
Suite 1500 
250 Australian Avenue South 
19 
West Palm Beach. Florida 33401 
Suite 1500 
20 
West Palm Beach. Florida 33401 
21 
22 
Reported By: 
Reported By: 
Cynthia Hopkins. RPR. FPR 
Cynthia Hopkins. RPR. FPR 
23 
Notary Public. State of Florida 
Notary Public. State of Florida 
Prose Court Reporting Services 
Prose Court Reporting Services 
24 
Job No.: 1484 
Job No.: 1484 
25 
Page 2 
Page 4 
1 
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 
1 
DI THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 
IN AND FOR PALM BEACH COUNTY. FLORIDA 
CIRCUIT IN AND FOR PALM BEACH COUNTY. FLORIDA 
2 
CASE NO. 502008CA028058XXXXMB AD 
2 
CASE No302008CA037319XXXXMB AB 
3 
3 
M. 
4
5 
Plaintiff. 
Plaintiff. 
6 
-vs- 
VOLUME I OF III 
5 
7 
VOLUME I OF III 
8 
JEFFREY EPSTEIN. 
J 
AN
EFISISI, 
Defendant. 
8 
9 
/ 
Defendants. 
10 
9 
11 
VI 
SITION OF 
10 
12 
13 
11 
12 
VItSITION 
OF 
14 
Wednesday. March 24. 2010 
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10:37 - 6:51 p.m. 
14 
Wednesday. March 24. 2010 
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10:37 - 6:51 p.m. 
16 
15
17 
250 Australian Avenue South 
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17 
250 Australian Avenue South 
Suite 1500 
Suite 1500 
18 
West Palm Beach. Florida 33401 
16 
West Palm Beach. Florida 33401 
19 
19 
20 
20 
21 
21 
22 
Repotted By: 
22 
Repotted By: 
Cynthia Hopkins. RPR. FPR 
Cynthia Hopkins. RPR. FPR 
23 
Notary Public. State of Florida 
23 
Notary Public. State of Florida 
Prose Court Reporting Services 
Prose Court Reporting Services 
24 
Job No.: 1484 
24 
Job No.: 1484 
25 
25 
1 (Pages 1 to 4) 
PROSE COURT REPORTING AGENCY, INC. 
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APPEARANCES: 
1 
2 
On behalf of the Plaintiffs. 
: 
2 
INDEX 
SPENCER T. KUVIN. ESQUIRE 
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LEOPOLD KUVIN 
4
2925 PGA Boulevard 
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EXAMINATION 
DIRECT CROSS REDIRECT' 
5 
Suite 201) 
Palm Beach Garden. Florida 33410 
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Phone: 
6 
7 
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On behalf of the Plandiffs...... and 
BY MR. KUVIN 
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Jane Doe: 
a 
8 
9 
9 
MATTHEW WEISSING. ESQUIRE 
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EXHIBITS 
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FARMERJAFTE MUSSING. EDWARDS 
FISTOS & LBIRNIAN.P.L 
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12 
_ _ _ 
425 North Andimvx Avenue 
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EXHIBIT 
DESCRIPTION 
PAGE 
11 
Suite 2 
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Fort Lauderdale Florida 33301 
PLAINTIFFS EX. 1 PHOTO 
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12 
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Phone: 
On behalf of Jane Does I throu5h K: 
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PLAINTIFFS EL 2 MOE INC.. 24 
14 
ADAM D. HOROWITZ- ESQUIRE 
PASSENGER MANIFEST' 
MERNIEI-STEIN it HOROWITZ. P.A. 
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PLAINTIFFS EX. 3 HYPERION AIR. INC.. 
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18205 Biscayne Boulevard 
PASSENGER MANIFEST 
Suite 22114 
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PLAINTIFFS EX. 6 PHOTO 
63 
16 
Miami. 
a t 
i 
PLAINTIFFS EL 7 PHOTO 
65 
Phone:
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PLAINTIFFS EX. 8 PHOTO 
68 
17 
E-mail: 
PLAINTIFFS EX. 9 PHOTO 
71 
16 
On behalf of the PI:midis. 101. 102 and 103: 
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PLAINTIFFS EL 10 PHOTO 
100 
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KATHERINE W. EZELI- ESQUIRE 
PLAINTIFFS EL 11 PHOTO 
101 
AMY JOSEFSBERG EDERI. ESQUIRE 
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PLAINTIFFS EL 12 PHOTO 
103 
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PODHURST ORSECK 
25 wear Flatlet Street 
PLAINTIFFS EX. 4 PHONE MESSAGE PADS 
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Suite WO 
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PLAINTIFFS EL 5 CELLPHONE RECORDS 
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Miami.iiiiiiiiii 
Phone: 
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PLAINTIFFS EL 13 PHOTO 
144 
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1Via telephoner 
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Appearances continued... 
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PROCEEDINGS 
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On behalf of the Plaintiff. Jane Doe ll: 
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ISIDRO MANUEL GARCIA. ESQUIRE 
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— — —
GARCIA. ELKINS & BOEHRINGER 
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THE VIDEOGRAPHER: We are now on video 
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224 Datum Avenue. Suite 900 
4 
record. This is Media No. 1 in the videotaped 
5 
West Palm 
Fl 
Beach 
ida 33401 
Phone: 
5 
deposition of 
in the matter of 
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6 
Jane Doe versus Jeffrey Epstein, et al. Today 
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8 
On behalf of the Defendant: 
JACK ALAN GOLDBERGER. ESQUIRE 
7 
is Wednesday. March 24th. 2010. It is 
ATTERBURY. GOLDBERGER & WEISS. P.A. 
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10:36 a.m. We are here at Prose Court 
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250 Australian Avenue South 
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Reporting. 250 South Australian Avenue. West 
Suite 1400 
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West 
ida 33401-5012 
Phony 
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Palm Beach. Florida. 
My name is Joe Kozak. I'm the 
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12 
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videographer. The reporter is Cindy 
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On 
f h Win 
• 
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Hopkins from Prose Court Reporting Agency. 
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Would counsel please introduce 
1 5
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yourselves, and then the court reporter 
will swear in the witness. 
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MR. KUVIN: Good morning. Spencer Kuvin 
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on behalf of one of the Plaintiffs. 
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MR. HOROWITZ: Adam Horowitz on behalf of 
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ALSO PRESENT: 
2 0 
Jane Does 2 through 8. And just for the record 
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Jessica Cadwell. Paralegal 
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purposes. the deposition is also being taken in 
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Burman. Critton. Lanier & Coleman. P.A. 
Joseph Kozak. Videographer 
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the federal cases, I believe, case being 
Prose Court Reporting Services 
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Jane Doe 2 versus Jeffrey Epstein. 
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MR. WEISSING: Matt Weissing on behalf of 
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three of the Plaintiffs. 
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MR. GARCIA: Sid Garcia for Jane Doe. 
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privilege. 
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Roman Numeral II. 
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MR. KUVIN: I'll agree with that 
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MR. GOLDBERGER: Jack Goldberger on behalf 
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procedure. 
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of Jeffrey Epstein. 
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MR. 
Anyone object to that 
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MS. CADWELL: Jessica Cadwell. paralegal. 
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procedure? 
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on behalf of Jeffre 
stein. 
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MR. GOLDBERGER: Actually I think if, in 
7 
MR. 
on behalf 
7 
fact, this deposition is used in a trial, 1 
a 
of the witness. 
8 
think you would want the lengthier answer as 
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MR. KUVIN: Kathy. your turn. 
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being the answer that is played to the jury. 
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MS. EZELL: Okay. Kathy Ezell and Amy 
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So either you guys can agree that it gets cut 
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Ederi on behalf of Plaintiff, Jane Doe 103. 
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in or she's going to have to -- I can't tell 
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Thereupon. 
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you what to do, but I would suggest that she 
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l
l 
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give the lengthier answer each time. 
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Having been first duly sworn or affirmed, was 
14 
But there's got to be a way that you 
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examined and testified as follows: 
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guys can reach an agreement though, that 
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DIRECT EXAMINATION 
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from a technology perspective, that the 
17 
BY MR. KUVIN: 
17 
lengthy answer that she just gave would be 
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Q. Good morning. 
18 
used during any trial testimony. Can that 
19 
A. Morning. 
19 
be done? 
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21 
Q. Couldyougive us your full name, please. 
A. 
. 
20 
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MR. KUVIN: I don't know procedurally 
whether it can be done. 
22 
Q. il
aiave a middle name? 
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MR. GOLDBERGER: I think -- 
23 
A. 
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MR. KUVIN: I don't know that, well -- 
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Q. Would ou s II that for us? 
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GOLDBERGER: And again, it's not my, 
25 
A. 
25
MR. 
ifs not my deal. I'm just telling you how 
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1 
Q. What's our current address? 
1 
we've done it in the past. 
2 
MR. 
I'm going to instruct the 
2 
MR. KUVIN: I hear you. and I have a 
3 
witness not to answer that question on the 
3 
number of issues primary, primarily of which 
4 
basis of her Fifth and 14th Amendment 
4 
that you're not here to represent anyone 
S 
privileges against self-incrimination. 
5 
currently. 
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MR. KUVIN: Okay. We had spoken before 
6 
MR. GOLDBERGER: Yeah. I am. I'm 
7 
with respect to there are likely going to be 
7 
actually. I'm actually here representing 
8 
answers similar to that throughout this 
8 
Jeffrey Epstein. so... 
9 
deposition. I have agreed to a procedure that 
9 
MR. KUVIN: Okay. With respect to all the 
10 
we can do a shortened answer. However you want 10 
civil cases. though. you're not here to 
11 
to handle that. I leave it up to you. But I do 
11 
represent anyone, so --
12 
agree that whatever the shortened answer is, 
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MR. GOLDBERGER: Yes. I am. 
13 
that it will satisfy the length. lengthy answer 
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MR. KUVIN: With the exception --
14 
that she would like to give. 
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MR. GOLDBERGER: I represent -- I am --1 
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So, do we want to do that with this 
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don't mean to interrupt you. but I am counsel 
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question, or how do you want to handle 
16 
of record in the civil cases. 
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that procedurall ? 
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MR. KUVIN: Oka . Okay. 
18 
MR. 
Well. I think I have given 18 
MR. 
If we have a stipulation, 
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the instruction. I think she, will give her 
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what's the problem? Are you --
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the same instruction in the future to the 
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MR. KUVIN: There is none. 
21 
extent that it's relevant, and I think that if 
21 
MR. 
-- worried about a waiver? 
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we can all just agree that if she simply says 
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MR. GOLDBERGER: No. I'm not worried abou 
23 
or I simply say "The Fifth Amendment," that 
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that at all. I'm worried about what is played 
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will qualify as giving a sufficient answer to 
24 
to a jury if this gets tried. 
25 
-- a, a matter of law. and will invoke that 
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MR. KUVIN: Okay. And I appreciate you 
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coaching M. 
but I think he can handle 
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I choose to invoke my Fifth Amendment right. 
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himself pretty adequately now -- 
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BY MR. KUVIN: 
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MR. GOLDBERGER: I have -- 
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Q. Would ou agree with me that you're 
4 
MR. KUVIN: So I leave it up to 
-- 
4 
approximatel 
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MR. GOLDBERGER: I have all the confidence 
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MR. 
: Same instruction. 
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in 
. 
6 
THE WITNESS: On the advice of my lawyer, 
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MR. KUVIN: Mr. 
with respect to 
7 
I must invoke my Fifth Amendment right. 
8 
how you want to handle it. I think we have an 
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BY MR. KUVIN: 
9 
10 
agreement. 
MR. 
: I'm satisfied that we have 
9 
10
Would you agree with me that your eyes are 
11 
a stipulation, and I assume if there is ever a 
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MR. 
Same instruction. 
12 
trial, that would be played or produced to the 
12 
THE WITNESS: On the advice of my lawyer, 
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jury that simply by using shorthand, what she's 
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I choose to invoke my Fifth Amendment right. 
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really saying is the lengthier answer now. I'm 
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BY MR. KUVIN: 
15 
satisfied with that. 
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Q. Would you agree with me that you were born 
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MR. KUVIN: And I agree with that. 
16 
in 
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BY MR. KUVIN: 
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MR. 
: Same instruction. 
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Q. Okay. Ma'am, what is your current 
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THE WITNESS: On the advice of my lawyer, 
19 
address? 
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I choose to invoke my Fifth Amendment right. 
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MR. 
: Again, I will instruct the 
20 
BY MR. KUVIN: 
21 
witness not to answer the question. 
21 
Q. What are the names of your parents? 
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THE WITNESS: On the instruction of my 
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MR. 
: Same instruction. 
23 
lawyer. I choose to invoke my Fifth Amendment 
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THE WITNESS: On the advice of my lawyer, 
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right. 
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I must invoke my Fifth Amendment right. 
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BY MR. KUVIN: 
1 
BY MR. KUVIN: 
2 
Q. What is our current phone number? 
2 
Q. Areyou married or single? 
3 
MR. 
: Same instruction. 
3 
MR. 
: Same instruction. 
4 
THE WITNESS: On the advice of my lawyer, 
4 
THE WITNESS: On the advice of my lawyer, 
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I choose to invoke my Fifth Amendment right. 
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I must to invoke my Fifth Amendment right. 
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BY MR. KUVIN: 
6 
(Plaintiffs Exhibit No. I was marked for 
7 
8 
Q. What is our cell hone number? 
MR. 
: Same instruction -- 
7 
8 
identification.) 
MR. KUVIN: I'm going to show you what 
9 
THE WITNESS: On the advice of my lawyer, 
9 
we'll mark as Plaintiffs Exhibit I. 
10 
I choose to invoke m Fifth Amendment right. 
10 
And I'll ask the videographer to zoom 
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MR. 
: You have to let me speak 11 
in here fora second. 
12 
before you answer in case there's an objection 
12 
BY MR. KUVIN: 
13 
or any of the other lawyers have an objection. 
13 
Q. Okay. Ma'am, I am going to show you a 
14 
BY MR. KUVIN: 
14 
photograph we've marked as Plaintiffs Exhibit 1 and 
15 
Q. I am going to show you a photograph. Oh, 
15 
ask you if you recognize this registered sex 
16 
what is your date of birth? 
16 
offender. 
17 
MR. 
: Same instruction. 
17 
MR. 
: First, object to the form 
18 
THE WITNESS: On the advice of my lawyer, 18 
of the question. It assumes facts not before 
19 
I choose to invoke my Fifth Amendment right. 
19 
the witness, and I'll give the witness the same 
20 
MR. KUVIN: Let's make is easier. 
20 
instruction as to that question. 
21 
BY MR. KUVIN: 
21 
THE WITNESS: At the advice of my lawyer, 
22 
Q. 
would ou agree with me that 
22 
I must invoke my Fifth Amendment right. 
23 
your date of birth i 
23 
BY MR. KUVIN: 
24 
MR. 
: Same instruction. 
24 
Q. Would you agree with me that this 
25 
THE WITNESS: On the advice of my lawyer, 25 
registered sex offender's name is Jeffrey Epstein? 
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MR. 
Same instruction, same 
objection. 
THE WITNESS: At the advice of my lawyer, 
I must invoke my Fifth Amendment right. 
BY MR. KUVIN: 
Q. Would you agree with me that Jeffrey 
Epstein is a sexual offender? 
MR. 
Object to the form of the 
question and instruct the witness not to answer 
on her Fifth Amendment privilege. 
THE WITNESS: On the advice of my lawyer I 
must invoke my Fifth Amendment right. 
BY MR. KUVIN: 
Q. Would you agree with me that 
Jeffrey Epstein sexual) abused you? 
MR. 
Objection to the form, 
both as to the form of the question as to 
harassing and instruct the witness not to 
answer, based on the Fifth Amendment privilege. 
THE WITNESS: On the advice of my lawyer. 
I must invoke my Fifth Amendment right. 
BY MR. KUVIN: 
Q. Would you agree with me that you were a 
minor when Jeffrey Epstein first had sexual 
relations with you? 
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question. It's ambiguous and compound. and I 
will instruct the witness not to answer based 
on her Fifth Amendment privilege. 
THE WITNESS: On the advice of my lawyer, 
I must invoke my Fifth Amendment right. 
BY MR. KUVIN: 
Q. And wh did ou do that? 
MR. 
: Object to the form. It's 
ambiguous, in fact that what? 
BY MR. KUVIN: 
Q. Why did you bring minor girls to 
Jeffrey Epstein for him to have sex with? 
MR. 
: Same objection as to forty 
and instruct the witness not to answer. 
THE WITNESS: On the advice of my lawyer, 
I must invoke my Fifth Amendment right. 
BY MR. KUVIN: 
Q. What do ou currently do for a job? 
MR. 
: Instruct the witness not 
to answer the question. 
THE WITNESS: On the advice of my lawyer, 
I must invoke my Fifth Amendment right. 
BY MR. KUVIN: 
I.
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1 
MR. 
Object to the form. It 
1 
MR. 
Instruct the witness not 
2 
assumes facts not before the witness. It is a 
2 
to answer the question. 
3 
compound question and I would instruct the 
3 
THE WITNESS: On the advice of my lawyer, 
4 
witness not to answer based on her Fifth 
4 
I must invoke my Fifth Amendment right. 
S 
Amendment privilege. 
5 
BY MR. KUVIN: 
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THE WITNESS: On the advice of my lawyer. 
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ii 
7 
I must invoke my Fifth Amendment right. 
I 
8 
BY MR. KUVIN: 
8 
MR. 
Same instruction. 
9 
Q. Would you agree with me that you have had 
9 
THE WITNESS: On the advice of my lawyer, 
10 
sex with Jeffrey E tein? 
10 
I must invoke my Fifth Amendment right. 
11 
MR. 
Same instruction. 
11 
BY MR. KUVIN: 
12 
THE WITNESS: On the advice of my lawyer. 
12 
I. 
13 
I must invoke my Fifth Amendment right. 
14 
BY MR. KUVIN: 
9 
15 
Q. Would you agree with me that you first had 
15 
MR. 
Instruct the witness not 
16 
sex with Jeffrey Epstein when you were under the age 16 
to answer the question. 
17 
of 18? 
17 
THE WITNESS: On the instruction of my 
18 
MR. 
Same instruction. 
18 
lawyer, I must invoke my Fifth Amendment right. 
19 
THE WITNESS: On the advice of my lawyer. 19 
BY MR. KUVIN: 
20 
I must invoke my Fifth Amendment right. 
20 
• 
21 
BY MR. KUVIN: 
22 
Q. Would you agree with me. ma'am, that you 
23 
brought numerous underage girls to Jeffrey Epstein 
23 
MR. 
Object to the form. It's 
24 
so that he could have sex with them? 
24 
compound and assumes facts not present before 
25 
MR. 
Object to the form of the 
25 
the witness, and I instruct the witness not to 
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answer the question based on her Fifth 
1 
witness, and I will instruct the witness not to 
2 
Amendment privilege. 
2 
answer based on her Fifth Amendment privilege. 
3 
THE WITNESS: On the instruction of my 
3 
THE WITNESS: On the instruction of my 
4 
lawyer, I must invoke my Fifth Amendment right. 
4 
lawyer, I must invoke my Fifth Amendment right. 
5 
BY MR. KUVIN: 
5 
BY MR. KUVIN: 
6 
Q. Who introduced you to Jeffrey Epstein the 
6 
Q. Would you agree with me that 
7 
first time that ou met him? 
7 
Jeffrey Epstein owns numerous planes, private 
8 
MR. 
Same instruction. 
8 
planes? 
9 
THE WITNESS: On the instruction of my 
9 
MR. 
Instruct the witness not 
10 
lawyer, I must invoke my Fifth Amendment right. 10 
to answer. 
11 
BY MR. KUVIN: 
11 
THE WITNESS: On the instruction of my 
12 
Q. Did Ghislaine Maxwell introduce you to 
12 
lawyer, I must invoke my Fifth Amendment right. 
13 
Jeffrey Epstein for the first time? 
13 
BY MR. KUVIN: 
14 
MR. 
Same instruction. 
14 
Q. And you've been on every one of those 
15 
THE WITNESS: On the instruction of my 
15 
private planes: isn't that true? 
16 
lawyer, I must invoke my Fifth Amendment right. 16 
MR. 
: Object to the form. It 
17 
BY MR. KUVIN: 
17 
assumes facts not before the witness, and I 
18 
Q. When was the first time you were in 
18 
will instruct the witness not to answer based 
19 
Jeffrey Epstein's home located on El Brillo Way on 
19 
on her Fifth Amendment privilege. 
20 
Palm Beach Island? 
20 
THE WITNESS: On the instruction of my 
21 
MR. 
Object to the form of the 
21 
lawyer, I must invoke my Fifth Amendment right. 
22 
question as compound and assuming facts not 
22 
BY MR. KUVIN: 
23 
before the witness. And I instruct the witness 
23 
Q. Ma'am, isn't it true that you've seen the 
24 
not to answer based on her Fifth Amendment 
24 
passenger manifest for Jeffrey Epstein's plane? 
25 
privilege. 
25 
MR. 
Object to the form. It 
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1 
THE WITNESS: On the instruction of my 
1 
assumes facts that are not established as known 
2 
lawyer, I must invoke my Fifth Amendment right. 
2 
to this witness, and I instruct the witness not 
3 
BY MR. KUVIN: 
3 
to answer the question based on her Fifth 
4 
Q. Would you agree with me that 
4 
Amendment privilege. 
5 
Jeffrey Epstein owns a home at 358 El Brillo Way, 
5 
THE WITNESS: On the instruction of my 
6 
Palm Beach Island. Florida? 
6 
lawyer, I must invoke my Fifth Amendment right. 
7 
MR. 
: Instruct the witness not 
7 
MR. KUVIN: Let me show you what we'll 
8 
to answer based on her Fifth Amendment 
8 
mark as Exhibit 2. 
9 
privilege. 
9 
10 
THE WITNESS: On instruction of my 
10 
(Plaintiff's Exhibit No. 2 was marked for 
11 
counsel, I must invoke my Fifth Amendment 
11 
identification.) 
12 
right. 
12 
MR. KUVIN: Thank you. 
13 
BY MR. KUVIN: 
13 
MR. 
: Do you want to zoom in on 
14 
Q. Would you agree with me that you've been 
14 
it like you did the last time? 
15 
in that home numerous times? 
15 
MR. KUVIN: No. that's fine. 
16 
MR. 
Instruct the witness not 
16 
MR. 
: Take your time. 
17 
to answer the question based on her Fifth 
17 
MR. KUVIN: And flip through. 
18 
Amendment privilege. 
18 
BY MR. KUVIN: 
19 
THE WITNESS: On instruction of my lawyer, 19 
Q. All right. Ma'am. would you agree with me 
20 
I must invoke my Fifth Amendment right. 
20 
that this is a passenger manifest for one of 
21 
22 
BY MR. KUVIN: 
Q. Would you agree with me that you have gone 
21 
22 
Jeffrey Epstein's ai lanes? 
MR. 
: Instruct the witness not 
23 
24 
on Jeffrey E stein 's lane numerous times? 
MR. 
. Object to the form. It 
23 
24 
to answer the question based on her Fifth 
Amendment privilege. 
25 
assumes fact. that are not present for the 
25 
THE WITNESS: On the instruction of my 
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lawyer I must exercise my Fifth Amendment 
1 
Amendment privilege. 
2 
right. 
2 
THE WITNESS: On the instruction of my 
3 
BY MR. KUVIN: 
3 
lawyer, I must invoke my Fifth Amendment right. 
4 
Q. And would you agree with me that you 
4 
BY MR. KUVIN: 
5 
appear as a passenger on these flight manifests on 
5 
Q. Would you also agree with me that the two 
6 
numerous occasions? 
6 
unknown females listed on the passenger manifest 
7 
MR. 
Object to the form. It 
7 
marked as Exhibit 2 were underage girls, under the 
8 
assumes facts not established as known to this 
8 
age of IS? 
9 
witness, and I instruct the witness not to 
9 
MR. 
: Object to the form. It 
10 
answer the question. 
10 
calls for speculation. Also it's not been 
11 
THE WITNESS: On the instruction of my 
11 
established this witness has any knowledge of 
12 
lawyer, I must exercise my Fifth Amendment 
12 
this document and instruct her not to answer 
13 
right. 
13 
based on her Fifth Amendment privilege. 
14 
BY MR. KUVIN: 
14 
THE WITNESS: On the instruction of my 
15 
Q. Would you agree with me that your name 
15 
lawyer, I must invoke my Fifth Amendment right. 
16 
does, in fact, appear on the passenger manifest for 
16 
BY MR. KUVIN: 
17 
these planes for this lane? 
17 
Q. Would you agree with me that the girls 
18 
MR. 
Same objection and same 18 
that are listed as females one, and the second 
19 
instruction. 
19 
female for this flight of January II, 2005, from 
20 
THE WITNESS: On the advice of my lawyer, 20 
West Palm Beach to the U.S. Virgin Islands, that 
21 
I must invoke my Fifth Amendment right. 
21 
those two females were under the age of 17? 
22 
BY MR. KUVIN: 
22 
MR. 
: Same objection. It has 
23 
Q. Who are the two females that appear on the 
23 
not been established the witness has any 
24 
passenger manifest for January II, 2005. on the 
24 
knowledge of this document. It calls for her 
25 
first page of Exhibit 2? 
25 
to speculate, and I instruct her not to answer 
Page 26 
Page 28 
1 
MR. 
I'll object to the form, 
1 
based on her Fifth Amendment privilege. 
2 
and it has not been established this witness 
2 
THE WITNESS: On the instruction of my 
3 
knows anything about this document, and I will 
3 
lawyer, I must invoke my Fifth Amendment right. 
4 
instruct her not to answer based on the Fifth 
4 
BY MR. KUV1N: 
S 
Amendment privilege. 
5 
Q. Would you agree with me that the two 
6 
THE WITNESS: On the instruction of my 
6 
females shown on the flight with you of January II, 
7 
8 
lawyer I must invoke my Fifth Amendment right. 
BY MR. KUVIN: 
7 
8 
2005 were under the a e of 16? 
MR. 
Same objection as to form 
9 
Q. Do you agree with me that you took a 
9 
It has not been established this witness knows 
10 
flight on Jeffrey Epstein's plane from West Palm 
10 
anything about whether there were these 
11 
Beach to the U.S. Virgin Islands. St. Thomas on 
11 
witnesses, these females and who they are, so 
12 
January II, 2005? 
12 
it's asking her to speculate. and I instruct 
13 
MR. 
Instruct the witness not 
13 
her not to answer based on her Fifth Amendment 
14 
to answer the question based on her Fifth 
14 
privilege. 
15 
Amendment privilege. 
15 
THE WITNESS: On the instruction of my 
16 
THE WITNESS: On the instruction of my 
16 
lawyer, I must invoke my Fifth Amendment 
17 
lawyer I must invoke my Fifth Amendment right. 
17 
privilege. 
18 
BY MR. KUVIN: 
18 
BY MR. KUV1N: 
19 
Q. Would you agree with me that on that 
19 
Q. Ma'am, you were on that flight of 
20 
flight were you. Jeffrey Epstein, 
20 
January 11. 2005. wereyou not?
21 
and two unknown females? 
21 
MR. 
I instruct the witness not 
22 
MR. 
Object to the form. Again 22 
to answer based on her Fifth Amendment 
23 
assumes facts that have not been established 
23 
privilege. 
24 
this witness has any knowledge of and instruct 
24 
THE WITNESS: On the instruction of my 
25 
the witness not to answer based on her Fifth 
25 
lawyer I must invoke my Firth Amendment right. 
7 (Pages 25 to 28) 
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Page 29 
BY MR. KUVIN: 
1 
Page 31 
MR. 
Same instruction. 
2 
Q. You also agree with me that the two girls 
2 
THE WITNESS: On the instruction of my 
3 
that are listed as on that flight with you of 
3 
lawyer, I must invoke my Fifth Amendment right. 
4 
January 11, 2005, were under the age of 15 years 
4 
BY MR. KUVIN: 
5 
old? 
5 
Q. Who is 
6 
MR. 
Object to the form. It 
6 
MR. 
: Same instruction. 
7 
calls for speculation, lack of personal 
7 
THE WITNESS: On the advice of my lawyer, 
8 
knowledge, and instruct the witness not to 
8 
I must invoke my Fifth Amendment right. 
9 
answer based on her Fifth Amendment privilege. 
9 
BY MR. KUVIN: 
10 
THE WITNESS: On the instruction of my 
10 
Q. Who is Mark Zeff. 
11 
lawyer, I must invoke my Fifth Amendment right. 11 
MR. 
Same instruction. 
12 
BY MR. KUVIN: 
12 
THE WITNESS: On the advice of my lawyer, 
13 
Q. Would you agree with me that the two 
13 
I must invoke my Fifth Amendment right. 
14 
females listed as being on that flight with you of 
14 
BY MR. KUVIN: 
15 
January I 1 of 2005 were under the age of 14 years 
15 
Q. Who is David Mullen? 
16 
old? 
16 
MR. 
: Same instruction. 
17 
MR. 
Object to the form. It 
17 
THE WITNESS: On the advice of my lawyer, 
18 
calls for speculation. The witness has no 
18 
I must invoke my Fifth Amendment right. 
19 
personal knowledge and instruct the witness not 
19 
BY MR. KUVIN: 
20 
to answer based on her Fifth Amendment 
20 
Q. Who is Todd Meister? 
21 
privilege. 
21 
MR. 
: Same instruction. 
22 
THE WITNESS: On the instruction of my 
22 
THE WITNESS: On the advice of my lawyer, 
23 
lawyer, I must invoke my Fifth Amendment right. 23 
I must invoke my Fifth Amendment right. 
24 
BY MR. KUVIN: 
24 
BY MR. KUVIN: 
25 
Q. Would you agree with me that the two 
25 
Q. Who is Jean-Luc Brunel? 
Page 30 
Page 32 
1 
females listed as being on the flight with you of 
1 
MR. 
Same instruction. 
2 
January II, 2005, from West Palm Beach to the U.S. 
2 
THE WITNESS: On the advice of my lawyer, 
3 
Virgin Islands, with Jeffrey Epstein as well, were 
3 
I must invoke my Fifth Amendment right. 
4 
under the age of 13 years old and you were aware of 
4 
BY MR. KUVIN: 
S 
that? 
5 
Q. Ma'am, would you agree with me that all of 
6 
MR. 
Object to the form both as 
6 
the names I just recently mentioned where you 
7 
compound. it also assumes facts that it has not 
7 
invoked your Fifth Amendment, were involved in a 
8 
been established this witness has any knowledge 
8 
conspiracy to abuse underaged girls, girls under the 
9 
of. calls for her to speculate, and I instruct 
9 
age of 18 for sexual ain and pleasure? 
10 
her not to answer based on her Fifth Amendment 
10 
MR. 
: Object to the form of the 
11 
privilege. 
11 
question. It calls for a legal conclusion. It 
12 
THE WITNESS: On the instruction of my 
12 
is compound. It calls for her to speculate. 
13 
lawyer I must invoke my Fifth Amendment right. 
13 
There is no basis for her to be able to give a 
14 
BY MR. KUVIN: 
14 
legal opinion as to what a conspiracy is, and I 
15 
Q. Who is 
? 
15 
instruct her not to answer based on her Fifth 
16 
MR. 
I'm sony. Can you repeat 16 
Amendment privilege. 
17 
the name? 
17 
THE WITNESS: On the advice of my lawyer. 
18 
MR. KUVIN: 
18 
I must invoke my Fifth Amendment right. 
19 
MR. 
I'll instruct the witness 
19 
BY MR. KUVIN: 
20 
not to answer based on her Fifth Amendment 
20 
Q. Would you agree with me that all of the 
21 
privilege. 
21 
names I just mentioned were individuals that were 
22 
THE WITNESS: On instruction of my lawyer, 22 
working together for their own sexual gain and 
23 
I must invoke my Fifth Amendment right. 
23 
pleasure? 
24 
BY MR. KUVIN: 
24 
MR. 
: Object to the form of the 
25 
Q. Who's Ohislaine Maxwell? 
25 
question as ambiguous and compound. I instruct 
8 (Pages 29 to 32) 
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1 
her not to answer based on her Fifth Amendment 
1 
BY MR. KUVIN: 
2 
privilege. 
2 
Q. Would you agree with me that Jeffrey 
3 
THE WITNESS: On the advice of my lawyer I 
3 
Epstein worked closely with Jean-Luc Brunel in order 
4 
must invoke my Fifth Amendment privilege. 
4 
to obtain girls from out of state and bring them to 
5 
BY MR. KUVIN: 
5 
Florida for their own sexual pleasure? 
6 
Q. What is MC S •oared? 
6 
MR. 
Object to the form as 
7 
MR. 
I instruct the witness not 
7 
ambiguous. whose own sexual pleasure. and 
8 
to answer based on her Fifth Amendment 
8 
instruct the witness not to answer the question 
9 
privilege. 
9 
based on her Fifth Amendment privilege. 
10 
THE WITNESS: On the advice of my lawyer I 10 
MR. KUVIN: Perfectly good objection. She 
11 
must invoke my Fifth Amendment right. 
11 
doesn't have to answer the question. Let me 
12 
BY MR. KUVIN: 
12 
clarify. 
13 
Q. Would you agree with me that MC Squared is 13 
BY MR. KUVIN: 
14 
a modeling agency that was funded by 
14 
Q. Would you agree with me, ma'am. that both 
15 
Jeffrey Epstein? 
15 
Jean-Luc Brunel and Jeffrey Epstein worked together 
16 
MR. 
I instruct the witness not 
16 
to obtain underage girls from out of state and bring 
17 
to answer based on her Fifth Amendment 
1"/ 
them to Florida for both of their own sexual 
18 
privilege. 
18 
pleasure? 
19 
THE WITNESS: The advice of my lawyer I 
19 
MR. 
I'm going to object as 
20 
must invoke my Fifth Amendment right. 
20 
compound and instruct -- I object to the form 
21 
BY MR. KUVIN: 
21 
as compound. and instruct the witness not to 
22 
Q. Would you agree with me that MC Squared 
22 
answer based on her Fifth Amendment privilege. 
23 
24 
was wholly funded b Jeffrey Epstein? 
MR. 
• Object to the form of the 
23 
24 
THE WITNESS: On the instruction of my 
lawyer I must invoke my Fifth Amendment right. 
25 
question as to what "wholly funded" means, and 
25 
Page 34 
Page 36 
1 
I would instruct the witness not to answer the 
1 
BY MR. KUVIN: 
2 
question based on her Fifth Amendment 
2 
A. Would you agree with me that 
3 
privilege. 
3 
Ghislaine Maxwell. Jean-Luc Brunel- and Jeffrey Epsteit 
4 
THE WITNESS: On the advice of my lawyer I 
4 
worked together to obtain underage girls from out of 
5 
must invoke my Fifth Amendment right. 
5 
state and bring them into the State of Florida for their 
6 
BY MR. KUVIN: 
6 
own sexual .lea ure? 
7 
Q. Would you agree with me that 
7 
MR. 
: Object to the form of the 
8 
Jeffrey Epstein is the sole individual whose money 
8 
question as compound and ambiguous. and 
9 
was used to start the corn • any. MC Squared? 
9 
instruct the witness not to answer based on her 
10 
MR. 
Instruct the witness not 
10 
Fifth Amendment privilege. 
11 
to answer the question based on her Fifth 
11 
THE WITNESS: On the instruction of my 
12 
Amendment privilege. 
12 
lawyer. I must invoke my Fifth Amendment right. 
13 
THE WITNESS: On the advice of my lawyer I 13 
(Katherine Ezell and Amy Ederi 
14 
must invoke my Fifth Amendment right. 
14 
entered the deposition.) 
15 
BY MR. KUVIN: 
15 
MR. GOLDBERGER: That's why we're --
16 
Q. Would you agree with me that 
16 
MR. KUVIN: That's why we lost them. 
17 
Jean-Luc Brunel worked with Jeffrey Epstein to 
17 
MR. 
: Do you want to take a 
18 
obtain underage girls for both of their sexual 
18 
one-minute break so we can --
19 
pleasure? 
19 
MR. KUVIN: Yeah, let's take a quick 
20 
MR. 
Object to the form of the 
20 
one-minute break. 
21 
question as ambiguous and instruct the witness 
21 
THE VIDEOGRAPHER: We're now off video 
22 
not to answer based on her Fifth Amendment 
22 
record. The time is 10:56 a.m. 
23 
privilege. 
23 
(A brief recess was held.) 
24 
THE WITNESS: On the advice of my lawyer I 
24 
(Plaintiffs Exhibit No. 3 was marked for 
25 
must invoke my Fifth Amendment right. 
25 
identification.) 
9 (Pages 33 to 36) 
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1 
THE VIDEOGRAPHER: We're now on video 
1 
personal knowledge and instruct her not to 
2 
record at 11:01 a.m. 
2 
answer based on her Fifth Amendment privilege. 
3 
MR. KUVIN: Just for the video record and 
3 
It's also compound. 
4 
for the written record Katherine Ezell and Amy 
4 
THE WITNESS: On the instruction of my 
5 
Eden have now appeared and are present in 
5 
lawyer I must invoke my Fifth Amendment 
6 
person. 
6 
privilege. 
7 
MR. GOLDBERGER: Just one more matter for 
7 
BY MR. KUVIN: 
8 
the record. Jack Goldberger. on behalf of 
8 
Q. The witness says that you may not have 
9 
Jeffrey Epstein. Rather than impose a form 
9 
knowledge or we don't know whether you have 
10 
objection to every question. I think we have 
10 
knowledge regarding this passenger manifest, so let 
11 
reached an agreement that on behalf of 
11 
me ask you, do you have any knowledge about this 
12 
Mr. Epstein. I am adopting the form objections 
12 
passenger manifest? 
13 
that Mr. 
is making on behalf of his 
13 
MR. 
Object to the form of the 
14 
client nunc pro tunc to the beginning of this 
14 
question as ambiguous as to this and what a 
15 
deposition. 
15 
manifest is, and also her knowledge, and I will 
16 
MR. KUVIN: No objection. 
16 
instruct her not to answer based on her Fifth 
17 
MR. GOLDBERGER: Okay. 
17 
Amendment privilege. 
18 
BY MR. KUVIN: 
18 
THE WITNESS: On the instruction of my 
19 
Q. All right. All right. 
would 
19 
lawyer, I must invoke my Fifth Amendment 
20 
you agree with me that there was an agreement 
20 
privilege. 
21 
between Jeffrey Epstein, Ghislaine Maxwell. 
21 
BY MR. KUVIN: 
22 
Jean-Luc Brunel. yourself and 
to 
22 
Q. Based on the objection, do you know what a 
23 
bring in girls from out of state that were underage? 
23 
manifest is? 
24 
MR. 
: Object to the form of the 
24 
MR. 
Object to the form of the 
25 
question as leading, as compound, and instruct 
25 
question as ambiguous and instruct her not to 
Page 38 
Page 40 
1 
the witness not to answer based on her Fifth 
1 
answer based on her Fifth Amendment privilege. 
2 
Amendment privilege. 
2 
THE WITNESS: On the instruction of my 
3 
THE WITNESS: On the instruction of my 
3 
lawyer I must invoke my Fifth Amendment right. 
4 
lawyer I must invoke my Fifth Amendment right. 
4 
BY MR. KUVIN: 
5 
BY MR. KUVIN: 
5 
Q. Have ou heard the word "manifest" before?
6 
Q. Would you agree with me that there was an 
6 
MR. 
I'll instruct the witness 
7 
agreement between Jeffrey Epstein, 
7 
not to answer based on her Fifth Amendment 
8 
Ghislaine Maxwell, Jean-Luc Brunel, yourself and 
8 
privilege. 
9 
to bring in girls that were 
9 
THE WITNESS: On the instruction of my 
10 
underage from out of state for sexual contact? 
10 
lawyer I must invoke my Fifth Amendment right. 
11 
MR. 
: Object to the form of the 11 
BY MR. KUVIN: 
12 
question as leading and compound, and I 
12 
Q. Would you agree with me, ma'am. that you 
13 
instruct the witness not to answer based on her 
13 
have seen this passenger manifest, listed as 
14 
Fifth Amendment privilege. 
14 
Exhibit 3, in the 'est? 
15 
THE WITNESS: On the instruction of my 
15 
MR. 
I'll instruct the witness 
16 
lawyer I must invoke my Fifth Amendment 
16 
not to answer based on her Fifth Amendment 
17 
privilege. 
17 
privilege. 
18 
BY MR. KUVIN: 
18 
THE WITNESS: On the instruction of my 
19 
Q. All right. Let me show you what we've 
19 
lawyer I must invoke my Fifth Amendment right. 
20 
premarked as Plaintiffs Exhibit 3. Do you 
20 
BY MR. KUVIN: 
21 
recognize this as the passenger manifest for one of 
21 
Q. Who is
22 
Jeffrey Epstein's lanes? 
22 
MR. 
I'll instruct the witness 
23 
MR. 
: I object to the form of 
23 
not to answer based on her Fifth Amendment 
24 
the question. It assumes facts that this 
24 
privilege. 
25 
witness. evidence that this witness has no 
25 
THE WITNESS: On the instruction of my 
10 (Pages 37 to 40) 
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1 
lawyer I must invoke my Fifth Amendment 
1 
listed in the risen er list to the left? 
2 
privilege. 
2 
MR. 
: Object to the form. the 
3 
4 
MR. KUVIN: S ellin for the court 
reporter i 
3 
4 
question is leading and 
 the witness 
instruct
not to answer based on the Fifth Amendment 
5 
BY MR. KUVIN: 
5 
privilege. 
6 
Q. Who is Eva Andersson, with two S's? 
6 
THE WITNESS: On the instruction of my 
7 
MR. 
• I'll instruct the witness 
7 
lawyer, I must invoke my Fifth Amendment right. 
8 
not to answer based on her Fifth Amendment 
8 
BY MR. KUVIN: 
9 
privilege. 
9 
Q. Would you agree with me that you were on a 
10 
THE WITNESS: On the instruction of my 
10 
plane with Jeffrey E stein on April 27. 2005?
11 
lawyer, I must invoke my Fifth Amendment right. 11 
MR. 
: Same instruction. 
12 
BY MR. KUVIN: 
12 
THE WITNESS: On the instruction of my 
13 
Q. Who is 
(phonetic)? 
13 
lawyer, I must invoke my Fifth Amendment right. 
14 
MR. 
Same instruction. 
14 
BY MR. KUVIN: 
15 
THE WITNESS: On the instruction of my 
15 
Q. Would you agree with me that on that plane 
16 
lawyer, I must invoke my Fifth Amendment right. 16 
of April 27, 2005. from Teterboro. New Jersey. to 
17 
BY MR. KUVIN: 
17 
West Palm Beach. was a female who was under the age 
18 
Q. Who is 
(phonetic)? 
18 
of 16? 
19 
MR. 
Same instruction. 
19 
MR. 
: Object to the form. It 
20 
THE WITNESS: On the instruction of my 
20 
assumes facts not established. Any personal 
21 
lawyer I must invoke my Fifth Amendment right. 
21 
knowledge by this witness, and instruct her not 
22 
BY MR. KUVIN: 
22 
to answer based on her Fifth Amendment 
23 
Q. Who is Chris Valdez (phonetic)? 
23 
privilege. It also calls for speculation. 
24 
MR. 
Same instruction. 
24 
THE WITNESS: On the instruction of my 
25 
THE WITNESS: On the instruction of my 
25 
lawyer, I must invoke my Fifth Amendment 
Page 42 
Page 44 
1 
lawyer I must invoke my Fifth Amendment right. 
1 
privilege. 
2 
BY MR. KUVIN: 
2 
BY MR. KUVIN: 
3 
Q. Who is James Stanley? 
3 
Q. Would you agree with me that on the flight 
4 
MR. 
Same instruction. 
4 
of April 27, 2005. from Teterboro. New Jersey to 
5 
THE WITNESS: On the instruction of my 
5 
West Palm Beach was a female on the plane with you 
6 
lawyer. I must invoke my Fifth Amendment right. 
6 
that was under the 
of 15? 
7 
BY MR. KUVIN: 
7 
MR. 
: Object to the form of the 
8 
Q. Who is S hia Stanley? 
8 
It requires speculation. It assumes 
9 
MR. 
Same instruction. 
9 
question. 
facts not established before this witness. 
10 
THE WITNESS: On the instruction of my 
10 
I'll instruct her not to answer based on her 
11 
lawyer I must invoke my Fifth Amendment right. 
11 
Fifth Amendment privilege. It's also 
12 
BY MR. KUVIN: 
12 
ambiguous. 
13 
Q. Who is Alexis Stanley? 
13 
THE WITNESS: On the instruction of my 
14 
MR. 
Same instruction. 
14 
lawyer,I must invoke my Fifth Amendment 
15 
THE WITNESS: On the instruction of my 
15 
privilege. 
16 
lawyer. I must invoke my Fifth Amendment right. 
16 
BY MR. KUVIN: 
17 
BY MR. KUVIN: 
17 
Q. Will you turn to May 6. 2005, please. And 
18 
Q. Ma'am, if you would, in Exhibit 3, would 
18 
this is, for the record, in Exhibit 3. On May 6th. 
19 
you turn to the date of April 27.2005. for me? 
19 
2005, ma'am. will you agree with me that you took a 
20 
21 
through 
It's about halfway 
 the packet. April 27, 
'05. Are you there? 
20 
21 
flight from Teterboro. New Terse 
West Palm 
Beach. with Jeffre E. tein 
22 
A. Uh-huh. 
22 
David Mullen. Larry 
23 
Q. Okay. On this particular date, will you 
23 
Morrison and another female? 
24 
agree with me that you flew from Teterboro. 
24 
MR. 
: Object to the form of the 
25 
New Jersey to %Vest Palm Beach on a plane with people 25 
question as compound. calling for speculation. 
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I instruct the witness not to answer based on 
1 
BY MR. KUVIN: 
2 
her Fifth Amendment privilege. 
2 
Q. Do you also agree with me on that flight 
3 
THE WITNESS: On the instruction of my 
3 
of June 20th, 2005. was an unidentified female, 
4 
lawyer, I must invoke my Fifth Amendment 
4 
according to thepassenger manifest?
5 
privilege. 
5 
MR. 
Object to the form --
6 
BY MR. KUVIN: 
6 
excuse me -- as leading, and instruct the 
7 
Q. Would you agree with me, ma'am, that on 
7 
witness not to answer based on her Fifth 
8 
the flight of May 6th, 2005. that's shown in 
8 
Amendment privilege. 
9 
Exhibit 3, that the female identified in the 
9 
THE WITNESS: On the instruction of my 
10 
passenger manifest was under the age of 16? 
10 
lawyer, I must choose to invoke my Fifth 
11 
MR. 
: Object to the form. It 
11 
Amendment privilege. 
12 
assumes facts not established that this witness 
12 
BY MR. KUVIN: 
13 
has any personal knowledge. It calls for her 
13 
Q. Would you agree with me that that female 
14 
to speculate, and I'll instruct her not to 
14 
listed on the flight of June 20. 2005, was under the 
15 
answer based on her Fifth Amendment privilege. 15 
age of 16 years old? 
16 
THE WITNESS: On the instruction of my 
16 
MR. 
Objection to the form as 
17 
lawyer, I must invoke my Fifth Amendment 
17 
leading and also requiring speculation. I'll 
18 
privilege. 
18 
instruct the witness not to answer based on her 
19 
BY MR. KUVIN: 
19 
Fifth Amendment privilege. 
20 
Q. Would you agree with me that the female 
20 
THE WITNESS: On the instruction of my 
21 
identified in the passenger manifest of May 6th, 
21 
lawyer, I must choose to invoke my Fifth 
22 
2005, was under the a e of 15? 
22 
Amendment privilege. 
23 
MR. 
: Same objection as the 
23 
BY MR. KUVIN: 
24 
previous question, same instruction. 
24 
Q. Would you agree with me that the 
25 
THE WITNESS: On the instruction of my 
25 
unidentified female on the passenger manifest of 
Page 46 
Page 48 
1 
lawyer I must invoke my Fifth Amendment 
1 
June 20, 2005. was under the age of 14? 
2 
privilege. 
2 
MR. 
Objection, calls for 
3 
BY MR. KUVIN: 
3 
speculation, instruct the witness not to answer 
4 
Q. Would you agree with me that the female 
4 
based on her Fifth Amendment privilege. 
5 
listed in the passenger manifest of May 6th, 2005, 
5 
THE WITNESS: On the instruction of my 
6 
was under the a e. was under the age of 14? 
6 
lawyer, I must invoke my Fifth Amendment 
7 
MR. 
Same instruction as to the 
7 
privilege.
8 
previous two questions and the same objection 
8 
BY MR. KUVIN: 
9 
as to those two questions. 
9 
Q. Turn to the date of June 30, if you would, 
10 
THE WITNESS: On the instruction of my 
10 
2005. Would you agree with me that you took a 
11 
lawyer I must invoke my Fifth Amendment 
11 
flight from Teterboro. New Jersey, to West Palm 
12 
privilege. 
12 
Beach on June 30. 2005. with Jeffrey Epstein? 
13 
BY MR. KUVIN: 
13 
MR. 
Object to the form as 
14 
Q. If you would turn to the date of June 20 
14 
leading and compound, instruct the witness not 
15 
of 2005 for me, please. On the date of June 20, 
15 
to answer based on her Fifth Amendment 
16 
2005, would you agree with me that you took a flight 16 
privilege. 
17 
with Jeffrey Epstein from West Palm Beach to 
17 
THE WITNESS: On the instruction of my 
18 
Teterboro, New Jerse ? 
18 
lawyer I must, I must invoke my Fifth Amendment 
19 
MR. 
Object to the form as 
19 
right
20 
leading. I'll instruct the witness not to 
20 
BY MR. KUVIN: 
21 
answer based on her Fifth Amendment privilege. 
21 
Q. Would you agree with me that 
22 
THE WITNESS: On the instruction of my 
22 
was on that fli 
t?
23 
lawyer, I must invoke my Fifth Amendment 
23 
MR. 
Same instruction. 
24 
privilege. 
24 
THE WITNESS: On the instruction of my 
25 
25 
lawyer I must invoke my Firth Amendment 
12 (Pages 45 to 48) 
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1 
privilege. 
1 
THE WITNESS: On the instruction of my 
2 
BY MR. KUVIN: 
2 
lawyer I must invoke my Fifth Amendment 
3 
Q. Would you agree with me that there was 
3 
privilege. 
4 
also another female on that flight with you? 
4 
BY MR. KUVIN: 
5 
MR. 
Same instruction. 
5 
Q. Would you agree with me that on both of 
6 
THE WITNESS: On the instruction of my 
6 
those flights were girls that were under the age of 
7 
lawyer, I must invoke my Fifth Amendment 
7 
16? 
8 
privilege. 
8 
MR. 
: Same form objection as tc 
9 
BY MR. KUVIN: 
9 
compound, also ambiguous and requiring 
10 
Q. Would you agree with me that you had 
10 
speculation and instruct the witness not to 
11 
personal knowledge that that 
female on that 
11 
answer based on her Fifth Amendment privilege. 
12 
flight with you of June 30, 2005, was under the age 12 
THE WITNESS: The instruction of my lawyer 
13 
of 16? 
13 
I must invoke my Fifth Amendment privilege. 
14 
MR. 
Object to the form as 
14 
BY MR. KUVIN: 
15 
compound and calling for speculation, and 
15 
Q. Would you agree with me, ma'am. that you 
16 
instruct the witness not to answer based on her 
16 
have flown on Jeffrey Epstein's plane from 
17 
Fifth Amendment privilege. 
17 
Teterboro. New Jersey. to West Palm Beach. on 
18 
THE WITNESS: On the instruction of my 
18 
numerous occasions where there were girls on the 
19 
lawyer, I must invoke my Fifth Amendment 
19 
plane under the a e of 16? 
20 
privilege. 
20 
MR. 
: Object to the form as 
21 
BY MR. KUVIN: 
21 
compound and ambiguous as to what numerous 
22 
Q. Would you agree with me that you had 
22 
means. Instruct the witness not to answer 
23 
personal knowledge that that young female on the 
23 
based on her Fifth Amendment privilege. 
24 
flight of June 30, 2005. was under the age of 15? 
24 
THE WITNESS: On the instruction of my 
25 
MR. 
Same instruction, calls 
25 
lawyer I must invoke my Fifth Amendment 
Page 50 
Page 52 
1 
for speculation. 
1 
privilege. 
2 
THE WITNESS: On the instruction of my 
2 
BY MR. KUVIN: 
3 
lawyer, I must invoke my Fifth Amendment 
3 
Q. Would you agree with me that you have 
4 
privilege. 
4 
flown on Jeffrey Epstein's plane from Teterboro. New 
5 
BY MR. KUVIN: 
5 
Jersey. to West Palm Beach on at least 100 occasions 
6 
Q. Would you agree with me that you had 
6 
where there were girls on the plane with you under 
7 
personal knowledge that that young female on the 
7 
the age of 16? 
8 
flight of June 30. 2005. with you was under the age 
8 
MR. 
Object to the form as 
9 
of 14? 
9 
compound, requiring speculation and ambiguous, 
10 
MR. 
: Objection to form as to 
10 
and instruct her not to answer based on her 
11 
compound and requiring speculation. I'll 
11 
Fifth Amendment privilege. 
12 
instruct the witness not to answer based on her 
12 
THE WITNESS: On the instruction of my 
13 
Fifth Amendment privilege. 
13 
lawyer I must invoke my Fifth Amendment 
14 
THE WITNESS: On the instruction of my 
14 
privilege. 
15 
lawyer I must invoke my Fifth Amendment 
15 
BY MR. KUVIN: 
16 
privilege. 
16 
Q. Would you agree with me. ma'am. that you 
17 
BY MR. KUVIN: 
17 
have flown on Jeffrey Epstein's plane at least 100 
18 
Q. Ma'am, just so we can be quicker about 
18 
times from Teterboro, New Jersey to West Palm Beach 
19 
this, there are flights of July 5th, July IS. It 
19 
Florida. where there were girls under the age of IS 
20 
looks like those are the last two. Would you agree 
20 
on the plane with ou?
21 
with me that on July 5th and July 15, you took 
21 
MR. 
Same objections as the 
22 
flights on Jeffrey E rein's plane? 
22 
previous question, same instruction. 
23 
MR. 
: Object to the form as 
23 
THE WITNESS: On the instruction of my 
24 
compound and instruct the witness not to answer 
24 
lawyer, I must invoke my Fifth Amendment 
25 
based on Filth Amendment privilege. 
25 
privilege. 
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BY MR. KUVIN: 
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occasions where Jeffrey Epstein was flying with 
2 
Q. Would you agree with me that you have 
2 
girls under the age of 16 from Teterboro. New 
3 
flown on Jeffrey Epstein's plane from Teterboro. New 
3 
Jersey. to Florida, West Palm Beach, Florida, with 
4 
Jersey to West Palm Beach on at least 100 occasions 
4 
girls under the age of 16, was doing so, so that he 
5 
where there were girls on the plane with you that 
5 
could have sexual contact with them? 
6 
were under the a e of 14? 
6 
MR. 
: Object to the form. It's 
7 
MR. 
: Objection to the form. 
7 
compound and requires her to assume facts that 
8 
It's compound and ambiguous. calls for 
8 
have not been established, and it's ambiguous, 
9 
speculation and instruct her not to answer 
9 
and instruct her not to answer based on the 
10 
based on her Fifth Amendment privilege. 
10 
Fifth Amendment privilege. 
11 
THE WITNESS: On the instruction of my 
11 
THE WITNESS: On the instruction of my 
12 
lawyer, I must invoke my Fifth Amendment 
12 
lawyer, I must assert my Fifth Amendment right. 
13 
privilege. 
13 
BY MR. KUVIN: 
14 
BY MR. KUVIN: 
14 
Q. Do you agree with me that on the flights 
15 
Q. Would you agree with me that you have been 
15 
from West Palm Beach to Paris, where you were 
16 
on the plane, one of Jeffrey Epstein's -- strike 
16 
present on the plane with Jeffrey Epstein, that 
17 
that. 
17 
there were girls under the age of 16 that 
18 
Would you agree with me that you have 
18 
Jeffrey Epstein was having sexual contact with on 
19 
been on Jeffrey Epstein's plane with him to Paris 
19 
that plane? 
20 
where there have been girls on the plane with you 
20 
MR. 
: Same objections as 
21 
under the a e of 16? 
21 
previously stated. It's compound, ambiguous. 
22 
MR. 
Objection to the form as 
22 
and assumes facts that she has no knowledge, or 
23 
compound. assuming facts not established the 
23 
it has not been established that she has any 
24 
witness has any knowledge, and instruct the 
24 
knowledge of, and instruct her not to answer 
25 
witness not to answer based on her Fifth 
25 
based on the Fifth Amendment, and it's leading. 
Page 54 
Page 56 
1 
Amendment privilege. It's also leading. 
1 
THE WITNESS: On the instruction of my 
2 
THE WITNESS: On the instruction of my 
2 
lawyer I must invoke my Fifth Amendment right. 
3 
lawyer. I must invoke my Fifth Amendment 
3 
BY MR. KUVIN: 
4 
privilege. 
4 
Q. Ma'am, you've been on the plane, you've 
5 
BY MR. KUVIN: 
5 
been on a plane with Jeffrey Epstein in the past, 
6 
Q. Would you agree with me that you have been 
6 
have you not? 
7 
on the plane with Jeffrey Epstein on flights to 
7 
MR. 
Objection to the form as 
8 
Paris where there have been girls on the plane with 
8 
leading, and instruct her not to answer based 
9 
you under the a e of 15? 
9 
on the Fifth Amendment privilege. 
10 
MR. 
: Same objection and same 
10 
THE WITNESS: On the instruction of my 
11 
instruction as the previous question. 
11 
lawyer, I must invoke my Fifth Amendment 
12 
THE WITNESS: On the instruction of my 
12 
privilege. 
13 
lawyer, I must invoke my Fifth Amendment 
13 
BY MR. KUVIN: 
14 
privilege. 
14 
Q. Have you been on a plane with 
15 
BY MR. KUVIN: 
15 
Jeffrey Epstein ever in our entire life? 
16 
Q. Would you agree with me that you have been 
16 
MR. 
Instruct the witness not 
17 
on those same flights we have been discussing where 
17 
to answer based on her Fifth Amendment right. 
18 
there have been:iris under the age of 14? 
18 
THE WITNESS: On the instruction of my 
19 
MR. 
: Same instruction and same 19 
lawyer I must invoke my Fifth Amendment 
20 
objection as the previous two questions. 
20 
privilege. 
21 
THE WITNESS: On the instruction of my 
21 
BY MR. KUVIN: 
22 
lawyer, I must invoke my Fifth Amendment 
22 
Q. Have you ever been on a plane with 
23 
privilege. 
23 
Jeffrey Epstein where there was a girl on the plane 
24 
BY MR. KUVIN: 
24 
with you under the a e of 14? 
25 
Q. Would you agree with me that on the 
25 
MR. 
Same instruction. 
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1 
THE WITNESS: On the instruction of my 
1 
MR. 
Same objection as stated 
2 
lawyer, I must invoke my Fifth Amendment 
2 
to the previous question; it's ambiguous and 
3 
privilege. 
3 
instruct her not to answer based on the Fifth 
4 
BY MR. KUVIN: 
4 
Amendment. 
5 
Q. Ma'am, isn't it true that you've seen 
5 
THE WITNESS: On the instruction of my 
6 
Jeffrey Epstein have sex with girls under the age of 
6 
lawyer, I must invoke my Fifth Amendment right. 
7 
14 on his plane? 
7 
MR. KUVIN: Just to clarify, is the 
8 
9 
MR. 
: Objection to the form. It 
assumes facts that it's not been established 
8 
9 
ambigui the word "sex"? 
MR. 
: Sex and also assumes that 
10 
that she would have any knowledge of. and I'll 
10 
she's ever met Jeffrey Epstein in her life. 
11 
instruct her not to answer based on her Fifth 
11 
MR. KUVIN: Any other words in there I 
12 
13 
Amendment right. 
THE WITNESS: On the instruction of my 
12 
13 
need to clan ? 
MR. 
: No. 
14 
lawyer, I must invoke my Fifth Amendment 
14 
BY MR. KUVIN: 
15 
privilege. 
15 
Q. Okay. Ma'am, do you -- what's your 
16 
BY MR. KUVIN: 
16 
definition of the word "sex"? 
17 
Q. Would you agree with me that you've seen 
17 
MR. 
: Object to the form of the 
18 
Jeffrey Epstein have sex with girls on his plane in 
18 
question and instruct the witness not to answer 
19 
your presence Burin fli hts to Paris? 
19 
based on her Fifth Amendment privilege. 
20 
MR. 
Same objection previously 
: 
20 
THE WITNESS: On the instruction of my 
21 
stated, and it assumes facts that have not been 
21 
lawyer, I must invoke my Fifth Amendment right. 
22 
established and instruct her not to answer 
22 
BY MR. KUVIN: 
23 
based on her Fifth Amendment right. 
23 
Q. Would you agree with me that the word 
24 
THE WITNESS: On the instruction of my 
24 
"sex" means both vaginal intercourse as well as oral 
25 
lawyer, I must invoke my Fifth Amendment 
25 
sex? Would you agree with that definition? 
Page 58 
Page 60 
1 
privilege. 
1 
MR. 
You can answer that. 
2 
BY MR. KUVIN: 
2 
THE WITNESS: No. 
3 
Q. Ma'am, isn't it true that you've seen 
3 
BY MR. KUVIN: 
4 
Jeffrey Epstein and Jean-Luc Brunel have sex with 
4 
Q. Okay. Would you agree with me that sex, 
5 
girls under the age of 14 on Mr. Epstein's plane on 
5 
for the purpose of our questions here today, will be 
6 
flights to Paris? 
6 
limited strictly to vaginal intercourse? 
7 
MR. 
Objection to the form. 
7 
A. Sorry. Can you repeat that? 
8 
It's compound. as to several answers all at the 
8 
Q. Yes. For the purpose of my questions here 
9 
same time and certain facts, and instruct her 
9 
today, will you agree that the word "sex" will be 
10 
not to answer based on her Fifth Amendment. 
10 
limited to vaginal intercourse between a man's penis 
11 
THE WITNESS: On the instruction of my 
11 
ma?
12 
and a woman's va 
a?
12 
lawyer, I must invoke my Fifth Amendment 
MR. 
If you're instructing her 
13 
privilege. 
13 
that in the future she should assume that 
14 
BY MR. KUVIN: 
14 
that's what you mean by your question, that's 
15 
Q. Ma'am, isn't it true that you have had sex 
15 
fine. 
16 
with Jeffrey E stein on his plane? 
16 
MR. KUVIN: Oka .
17 
MR. 
: Instruct the witness not 
17 
MR. 
If that's what you mean, 
18 
to answer based on the Fifth Amendment 
18 
then that's understood. 
19 
privilege, also object to the form of the 
19 
MR. KUVIN: That's what I mean. 
20 
question as compound and ambiguous. 
20 
MR. 
Okay. 
21 
THE WITNESS: On the instruction of my 
21 
MR. KUVIN: All right. Let's go with that 
22 
lawyer, I must invoke my Fifth Amendment right. 22 
definition. And for the purposes of my 
23 
BY MR. KUVIN: 
23 
questions, "oral sex" will mean contact between 
24 
Q. Isn't it true that you've had sex with 
24 
an individual's mouth and a man's sexual organ, 
25 
Jeffrey Epstein on hi, plane on flights to Paris? 
25 
penis. Fair enough? 
15 (Pages 57 to 60) 
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1 
MR. 
: Understood. 
1 
Mr. Epstein's residence, as to her knowledge of 
2 
MR. KUVIN: Okay. 
2 
Mr. Epstein and other facts as to which she's 
3 
BY MR. KUVIN: 
3 
invoking her Fifth Amendment privilege. 
4 
Q. Working with those definitions if we 
4 
THE WITNESS: On the instruction of my 
5 
could, would you agree with me that you had sex with 
5 
lawyer, I must to invoke my Fifth Amendment 
6 
Jeffrey Epstein on his 'lane? 
6 
privilege. 
7 
MR. 
: Objection to the form. 
7 
MR. KUVIN: Let me show you what we'll 
8 
It's compound and instruct her not to answer 
8 
mark as Exhibit 6. And this one I'm going to 
9 
based on the Fifth Amendment privilege, because 
9 
show it to the camera real briefly, if I could. 
10 
to do so would implicitly admit that she's ever 
10 
Okay. 
11 
met Jeffrey Epstein in her life, and so as to 
11 
MR. 
: Let me see it. Thank you 
12 
that she's invoking the Fifth Amendment 
12 
(Plaintiffs Exhibit No. 6 was marked for 
13 
privilege. 
13 
identification.) 
14 
THE WITNESS: On the instruction of my 
14 
BY MR. KUVIN: 
15 
lawyer, I must invoke my Fifth Amendment 
15 
Q. Ma'am, do you recognize any of the girls 
16 
privilege. 
16 
shown in Exhibit 6? 
17 
BY MR. KUVIN: 
17 
MR. 
: I'll instruct the witness 
18 
Q. Would you agree with me that you have had 
18 
not to answer based on her Fifth Amendment 
19 
oral sex with Jeffrey Epstein on his plane? 
19 
privilege. 
20 
MR. 
: Same objection stated to 
20 
THE WITNESS: On the instruction of my 
21 
the previous question. It's compound and it 
21 
lawyer, I must invoke my Fifth Amendment right. 
22 
assumes facts that's not been established as to 
22 
BY MR. KUVIN: 
23 
which she is invoking her Fifth Amendment 
23 
Q. Would you agree with me that that is you 
24 
25 
privilege. 
THE WITNESS: On the instruction of my 
25 
24 
on the right in this hoto raph, the far right? 
MR. 
: I'll instruct the witness 
Page 62 
Page 64 
lawyer, I must invoke my Fifth Amendment 
1 
not to answer. 
2 
privilege. 
2 
THE WITNESS: On the instruction of my 
3 
BY MR. KUVIN: 
3 
lawyer, I must invoke my Fifth Amendment 
4 
Q. Would you agree with me that you have had 
4 
privilege. 
5 
6 
7 
sex with Jeffre 
tein in his home -- 
MR. 
: Object to the -- 
MR. KUVIN: -- here in West Palm, in West 
5 
6 
7 
BY MR. KUVIN: 
• 
Would ou agree with me that that is 
on the left in that photograph that 
8 
Palm Beach? 
8 
we marked as Exhibit 6? 
9 
MR. 
: I'll instruct the witness 
9 
MR. 
Same instruction. 
10 
not to answer based on her Fifth Amendment 
10 
THE WITNESS: On the instruction of my 
11 
privilege and same objection previously stated 
11 
lawyer, I must invoke my Fifth Amendment 
12 
to the last two questions. 
12 
privilege. 
13 
THE WITNESS: On the instruction of my 
13 
BY MR. KUVIN: 
14 
lawyer, I must invoke my Fifth Amendment 
14 
Q. How old areyou in this photograph?
15 
privilege. 
15 
MR. 
Same instruction. 
16 
BY MR. KUVIN: 
16 
THE WITNESS: On the instruction of my 
17 
Q. Would you agree with me that you have had 
17 
lawyer, I must invoke my Fifth Amendment 
18 
oral sex with Jeffrey Epstein in his home in West 
18 
privilege. 
19 
Palm Beach? 
19 
BY MR. KUVIN: 
20 
MR. GARCIA: Is it West, or Palm Beach? 
20 
Q. How old is 
in this 
21 
MR. KUVIN: Palm Beach Island. I think 
21 
if ou know?
22 
it's, because -- yeah, for clarity, his home on 
22 
photograph, 
MR. 
I'm going to object to the 
23 
Palm Beach. 
23 
form in that it assumes facts as to her 
24 
MR. 
: Object to the form. It 
24 
knowledge of anything about Ms. 
and 
25 
assumes facts as to her knowledge of 
25 
as to which she is in‘okino, her Fifth Amendment 
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1 
privilege. 
1 
THE WITNESS: On the instruction of my 
2 
THE WITNESS: On the instruction of my 
2 
lawyer, I must invoke my Fifth Amendment 
3 
lawyer. I must invoke my Fifth Amendment 
3 
privilege. 
4 
privilege. 
4 
BY MR. KUVIN: 
5 
MR. KUVIN: This is Exhibit 7. Let me 
5 
Q. Would you agree with me that 
6 
show you what well mark as Exhibit 7. 
6 
has been to Mr. Epstein's home on hundreds of 
7 
(Plaintiff's Exhibit No. 7 was marked for 
7 
occasions? 
8 
identification.) 
8 
MR. 
Object to the form as 
9 
BY MR. KUVIN: 
9 
compound and also assumes knowledge as this 
10 
Q. Do you recognize the girl that's shown in 
10 
witness has and instruct her to invoke her 
11 
Exhibit 7? 
11 
Fifth Amendment privilege relating to 
12 
MR. 
I need to consult with her 
12 
Ms. 
13 
one second. 
13 
THE WITNESS: On the instruction of my 
14 
MR. KUVIN: Sure. 
14 
lawyer, I must invoke my Fifth Amendment 
15 
THE VIDEOGRAPHER: Are we off the record? 15 
privilege. 
16 
MR. KUVIN: No. no. 
16 
BY MR. KUVIN: 
17 
MR. 
Instruct the witness to 
17 
Would you agree with me that you directed
18 
invoke her Fifth Amendment privilege as to 
18 . 
on hundreds of occasions to bring girls 
19 
Exhibit 7. 
19 
under the a e of 16 to Mr. Epstein's house?
20 
MR. KUVIN: She's clipped up. Okay. 
20 
MR. 
Object to the form of the 
21 
MR. 
Now you have to answer. 
21 
question as compound and ambiguous and assuming 
22 
THE WITNESS: On the advice of my lawyer, 
22 
facts as to which there is no factual basis 
23 
I must invoke my Fifth Amendment privilege. 
23 
that this witness has any knowledge and 
24 
BY MR. KUVIN: 
24 
instruct the witness not to answer based on her 
25 
Q. Would you agree with me that the girl 
25 
Fifth Amendment privilege. 
Page 66 
Page 68 
1 
shown in Exhibit 7 is 
1 
THE WITNESS: On the instruction of my 
2 
MR. 
Instruct the witness not 
2 
lawyer, I must choose to invoke my Fifth 
3 
to answer based on the Fifth Amendment 
3 
Amendment right. 
4 
privilege. 
4 
BY MR. KUVIN: 
5 
THE WITNESS: On the instruction of my 
5 
Q. Would you agree with me that on hundreds 
6 
lawyer, I must invoke my Fifth Amendment 
6 
of occasions you directed 
to bring 
7 
privilege. 
7 
underage girls under the age of 16 to Mr. Epstein's 
8 
BY MR. KUVIN: 
8 
home for sex with Mr. E tein? 
9 
Q. Do you agree with me that 
was 
9
MR. 
: Object to the form. It's 
10 
under the age of 16 when she was first asked to go 
10 
compound and it assumes facts as to this --
11 
to Mr. Epstein's home? 
11 
that this witness has no personal knowledge. 
12 
MR. 
Objection to the form. It 
12 
and it's been established by this record, and 
13 
assumes any knowledge 
witness as to the 
13 
instruct her to invoke her Fifth Amendment 
14 
person you identified as 
It's 
las 
14 
privilege. 
15 
compound and I would instruct her not to answer 
15 
THE WITNESS: On the instruction of my 
16 
based on her Fifth Amendment privilege. 
16 
lawyer, I must invoke my Fifth Amendment 
17 
THE WITNESS: On the instruction of my 
17 
privilege. 
18 
lawyer, I must invoke my Fifth Amendment 
18 
MR. KUVIN: We'll mark this as Exhibit 8. 
19 
privilege. 
19 
(Plaintiff's Exhibit No. 8 was marked for 
20 
BY MR. KUVIN: 
20 
identification.) 
21 
Q. Would ou agree with me that you know 
21 
BY MR. KUVIN: 
22 
personally 
22 
Q. Ma'am. do you recognize the person that's 
23 
MR. 
Instruct the witness not 
23 
shown in Exhibit 8? 
24 
to answer based on the Fifth Amendment 
24 
MR. 
: Let me consult one second. 
25 
privilege. 
25 
MR. KUVIN: Sure. 
17 (Pages 
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1 
MR. 
: I instruct the witness not 
1 
MR. GARCIA: He didn't make a Fifth 
2 
to answer the question based on her Fifth 
2 
Amendment objection. So can we just rephrase 
3 
Amendment privilege. 
3 
the question? 
4 
THE WITNESS: Based on the instruction of 
4 
MR. 
: I would instruct the 
5 
my lawyer, I must invoke my Fifth Amendment 
5 
witness not to answer based on the Fifth 
6 
right. 
6 
Amendment privilege to clarify. 
7 
BY MR. KUVIN: 
7 
MR. KUVIN: Okay. Let's mark this as 
8 
Q. Would you agree with me that the person 
8 
Exhibit 9. 
9 
shown on Exhibit 8 is ou? 
9 
MR. 
: And for the record. the 
10 
MR. 
: Same instruction. 
10 
basis is that it assumes her knowledge of 
11 
THE WITNESS: On the instruction of my 
11 
anything relating to Jeffrey Epstein, the 
12 
lawyer, I must invoke my Fifth Amendment 
12 
question assumed that. 
13 
privilege. 
13 
(Plaintiffs Exhibit No. 9 was marked for 
14 
BY MR. KUVIN: 
14 
identification.) 
15 
Q. Would you agree with me that this is a 
15 
BY MR. KUVIN: 
16 
modeling shot of you that was taken through one of 16 
Q. Ma'am, do you recognize the girl shown in 
17 
Mr. Epstein's modelin a encies? 
17 
Exhibit 9?
18 
MR. 
: Object to the form of the 18 
MR. 
: I'll instruct the witness 
19 
question as compound and assuming facts as to 
19 
not to answer based on her Fifth Amendment 
20 
which there has been no basis that this witness 
20 
privilege. 
21 
has any personal knowledge, and she's going 
21 
THE WITNESS: On the instruction of my 
22 
invoke her Fifth Amendment privilege. 
22 
lawyer, I must invoke my Fifth Amendment right. 
23 
THE WITNESS: On the instruction of my 
23 
BY MR. KUVIN: 
24 
lawyer, I must invoke my Fifth Amendment 
24 
Q. Would you agree with me that the girl 
25 
privilege. 
25 
shown in Exhibit 9 is 
? 
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1 
BY MR. KUVIN: 
1 
MR. 
Same instruction. 
2 
Q. Would you agree with me that you were 
2 
THE WITNESS: On the instruction of my 
3 
under the age of 18 in this photograph we've marked 
3 
lawyer, I must invoke my Fifth Amendment 
4 
as Exhibit 8? 
4 
privilege. 
5 
MR. 
: Same objection as to the 
5 
MR. KUVIN: I forgot to do one more thing. 
6 
previous question and same instruction. 
6 
If you could give that back to me for just one 
7 
THE WITNESS: On the instruction of my 
7 
second just for the record so we can see what 
8 
lawyer, I must invoke my Fifth Amendment right. 
8 
we're talking about here. 
9 
BY MR. KUVIN: 
9 
Okay. I will give you back Exhibit 
10 
Q. Would you agree with me that you were 
10 
9. 
11 
under the age of 17 in this photograph that we've 
11 
MR. 
Thank you. 
12 
marked as Exhibit 8? 
12 
BY MR. KUVIN: 
13 
MR. 
: Same objection as the 
13 
Q. Wouldyou agree with me that this 
14 
previous two question and the same instruction. 
14 
photograph of 
was taken when she 
15 
THE WITNESS: On the instruction of my 
15 
was under the a e of 18?
16 
lawyer, I must invoke my Fifth Amendment right. 
16 
MR. 
Objection to the form. It 
17 
18 
BY MR. KUVIN: 
Q. Would you agree with me that Jeffrey 
17 
18 
assumes this witness has any knowleifihat the 
n in the photograph is, in fact. 
19 
Epstein kept this photograph of you in his home, if 
19
Therefore,it's ambiguous and 
20 
you know. 
20 
compound. and I'll instruct her not to answer 
21 
MR. 
: Object to the form of the 
21 
based on her Fifth Amendment privilege. 
22 
question as compound and ambiguous, and I would 22 
THE WITNESS: On the instruction of my 
23 
instruct the witness not to answer. 
23 
lawyer, I must invoke my Fifth Amendment right. 
24 
THE WITNESS: On the instruction of my 
24 
BY MR. KUVIN: 
25 
lawyer, I must invoke my Fifth Amendment right. 
25 
Q. Would you agree with me that the gill 
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1 
shown in that photograph -- strike that. 
1 
implicitly assumes that she does. I would 
2 
Would you agree with me that this 
2 
instruct her not to answer it based on her 
3 
photograph was ke t b Jeffrey Epstein in his home? 
3 
Fifth Amendment privilege. 
4 
MR. 
Objection to the form as 
4 
THE WITNESS: Upon the instruction of my 
5 
to being compound in that it assumes that she 
5 
lawyer, I must invoke my Fifth Amendment 
6 
has any knowledge of Jeffrey Epstein or his 
6 
privilege. 
7 
home, and I would instruct her not to answer 
7 
BY MR. KUVIN: 
8 
based on her Fifth Amendment. 
8 
Q. Ma'am. are you aware of the effect, the 
9 
THE WITNESS: On the instruction of my 
9 
emotional effect on the underage girls that have 
10 
lawyer, I must invoke my Fifth Amendment right. 10 
been abused by Jeffrey Epstein? Are you aware of 
11 
BY MR. KUVIN: 
11 
the emotional effect that it's had on the underage 
12 
Would you agree with me that 
12 
that have been abused by Jeffrey Epstein?
13 
• 
was under the age of 16 when this 13 
girls 
MR. 
Objection to the form as 
14 
photograph was taken in Exhibit 9? 
14 
to. again, the question assumes this wimess 
15 
MR. 
: Objection to the form as 
15 
has any knowledge, first, of Jeffrey Epstein, 
16 
compound and also assuming this witness has any 16 
second that Jeffrey Epstein has sexually abused 
17 
18 
knowledge that the 
rson in the photograph is, 
in fact, 
Therefore. I would 
17 
18 
anyone ever, and third, that anyone has been 
damaged by anything that Jeffrey Epstein has 
19 
instruct her to invoke her Fifth Amendment 
19 
done, and fourth, that she would somehow have 
20 
privilege. 
20 
any knowledge of these people's emotional 
21 
THE WITNESS: On the instruction of my 
21 
situations. For all those reasons, the 
22 
lawyer, I must invoke my Fifth Amendment right. 22 
question is ambiguous and compound. and I would 
23 
BY MR. KUVIN: 
23 
instruct her not to answer based on her Fifth 
24 
Q. Ma'am, is Jeffrey Epstein paying for your 
24 
Amendment. 
25 
attorney today? 
25 
THE WITNESS: Upon the instruction of my 
Page 74 
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1 
MR. 
I'll instruct the witness 
1 
lawyer, I must invoke my Fifth Amendment right. 
2 
not to answer based on her Fifth Amendment 
2 
BY MR. KUVIN: 
3 
privilege. 
3 
Q. Ma'am, do you have any regret for what 
4 
THE WITNESS: On the instruction of my 
4 
you've done? 
5 
lawyer, I must invoke my Fifth Amendment right. 
5 
MR. 
: Objection to the form. 
6 
BY MR. KUVIN: 
6 
That question is not designed to lead to 
7 
Q. Ma'am, is Jeffrey Epstein paying for you 
7 
discoverable evidence. It's meant solely for 
8 
to keep quiet with respect to the things he has done 
8 
the purpose of harassment, and I would instruct 
9 
to underage iris? 
9 
her not to answer.
10 
MR. 
Objection to the form in 
10 
BY MR. KUVIN: 
11 
that it's ambiguous and compound, also assumes 
11 
Q. Ma'am, do you have any regrets for what 
12 
this witness has any knowledge at all of 
12 
Jeffrey Epstein has done through you in obtaining 
13 
Jeffrey Epstein, and therefore I am instructing 
13 
underage girls for sexual abuse? 
14 
her to invoke her Fifth Amendment privilege. 
14 
MR. 
: Same objection as the 
15 
THE WITNESS: On the instruction of my 
15 
previous question as well as that question is 
16 
lawyer, I must invoke my Fifth Amendment 
16 
now free to assume this witness has any 
17 
privilege. 
17 
knowledge at all of Jeffrey Epstein or 
18 
BY MR. KUVIN: 
18 
Jeffrey Epstein having abused any underage 
19 
Q. Ma'am, how much is Jeffrey Epstein paying 
19 
women or girls or anything else that 
20 
you to keep quiet with respect to things he's done 
20 
Jeffrey Epstein may ever have done. 
21 
to underage irls? 
21 
And therefore, since it assumes that 
22 
MR. 
Object to the form as 
22 
fact, I would instruct her not to answer 
23 
multiple compound questions, and it's again 
23 
based on her Fifth Amendment. 
24 
assuming this witness has any knowledge at all 
24 
BY MR. KUVIN: 
25 
of Jeffrey Epstein. Since the question 
25 
Q. Are you scared of Jeffrey Epstein? 
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1 
MR. KUV1N: I'm sorry, you had to respond. 
1 
lawyer, and I must invoke my Fifth Amendment 
2 
I cut you off. 
2 
privilege. 
3 
THE WITNESS: Upon the instruction of my 
3 
BY MR. KUVIN: 
4 
lawyer, I must invoke my Fifth Amendment right. 
4 
Q. Do ou know who Les Wexner is? 
5 
BY MR. KUVIN: 
5 
MR. 
I'll instruct the witness 
6 
Q. Are ou scared of Jeffrey Epstein? 
6 
not to answer based on her Fifth Amendment 
7 
MR. 
Objection to the form in 
7 
privilege. 
8 
that it assumes this witness has ever met 
8 
THE WITNESS: On the instruction of my 
9 
Jeffrey Epstein in her life. Because it 
9 
lawyer, I must invoke my Fifth Amendment 
10 
assumes that, I would instruct her not to 
10 
privilege. 
11 
answer based on the Fifth Amendment. 
11 
BY MR. KUV1N: 
12 
THE WITNESS: On the instruction of my 
12 
Q. Do you know whether or not Mr. Epstein has 
13 
lawyer, I must invoke my Fifth Amendment right. 13 
had a homosexual relationship with Les Wexner in the 
14 
BY MR. KUV1N: 
14 
past? 
15 
Q. Are you aware of Jeffrey Epstein's sexual 
15 
MR. 
Objection to the form in 
16 
obsession for children? 
16 
that it again assumes that this witness knows 
17 
MR. 
Same instructions as the 
17 
anything at all about Jeffrey Epstein or has 
18 
previous question. also objection to the 
18 
ever met Jeffrey Epstein in her life, and 
19 
question. It's not designed to lead to any 
19 
therefore. I would instruct her not to answer 
20 
discoverable evidence at all. It's simply 
20 
based on her Fifth Amendment privilege, and the 
21 
meant for harassment. 
21 
question is compound and ambiguous. 
22 
THE WITNESS: On the instruction of my 
22 
THE WITNESS: On the instruction of my 
23 
lawyer, I must invoke my Fifth Amendment 
23 
lawyer, I must invoke my Fifth Amendment 
24 
privilege. 
24 
privilege. 
25 
25 
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1 
BY MR. KUVIN: 
1 
BY MR. KUVIN: 
2 
Q. At what point did you realize that 
2 
Q. Do you know the magician by the name 
3 
Jeffrey Epstein was sexually attracted to girls 
3 
David Cop. erfield? 
4 
under the a e of 18? 
4 
MR. 
: I'll instruct the witness 
5 
MR. 
Once again, the question 
5 
not to answer based on her Fifth Amendment 
6 
assumes this witness knows anything at all 
6 
right. 
7 
about Jeffrey Epstein, underage women, sexual 
7 
THE WITNESS: On the instruction of my 
8 
abuse of underage women, and she's not going to 
8 
lawyer, I must invoke my Fifth Amendment 
9 
answer any questions that assume that as a 
9 
privilege. 
10 
predicate. They are objectionable as ambiguous 
10 
BY MR. KUVIN: 
11 
and compound, and I instruct her not to answer. 
11 
Q. You are aware, are you not, that 
12 
THE WITNESS: On the instruction of my 
12 
David Copperfield has visited Jeffrey Epstein's home 
13 
lawyer, I must invoke my Fifth Amendment 
13 
in Palm Beach? 
14 
privilege. 
14 
MR. 
: Objection to the form as 
15 
BY MR. KUV1N: 
15 
it once again assumes she has some knowledge of 
16 
Q. Are you aware whether or not 
16 
Jeffrey Epstein, or whether he has a home in 
17 
Jeffrey Epstein has had any homosexual relationships 17 
Palm Beach. Because those facts are implicit 
18 
in the past? 
18 
in the question, the question is ambiguous and 
19 
MR. 
Same objection as the 
19 
compound. I would instruct her not to answer 
20 
previous question. The question as stated 
20 
based on her Fifth Amendment. 
21 
assumes this witness has some knowledge of 
21 
THE WITNESS: On the instruction of my 
22 
Jeffrey Epstein. And since it assumes that 
22 
lawyer, I must invoke my Fifth Amendment 
23 
fact, it is ambiguous and it's compound. and I 
23 
privilege. 
24 
instruct her not to answer. 
24 
BY MR. KUVIN: 
25 
THE WITNESS: On the instruction of my 
25 
•. You are aware. are you not. that 
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