EFTA01246511

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UNITED STATES DISTRICT COURT 
1 
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 
SOUTHERN DISTRICT OF FLORIDA 
IN AND FOR PALM BEACH COUNTY. FLORIDA 
2 
CASE NO. 502008CA028051XXXXIMB AB 
CASE NO. 08-CIV-80119-MARRA/JOHNSON 
3 
M. 
JANE DOE NO. 2. 
Plaintiff. 
Plaintiff. 
5 
-vs- 
VOLUME II OF III 
VOLUME II OF III 
JEFFREY EPSTEIN. 
6 
Defendant. 
JEFFREY EPSTEIN. 
/ 
7 
Defendant. 
Related cases: 
a 
/ 
0840232. 08-08380. 08-80381. 08-80994 
9 
08-80993. 08-80811. 08-80893. 09-80469 
10 
VIDEOTAPED DEPOSITION OF 
0940591. 09-80656. 09-80802. 09-81092 
11 
Wednesday. March 24.2010 
/ 
12 
10:37 - 6:51 p.m. 
13 
VILIMMISITION 
OF 
14 
15 
250 Australian Avenue South 
West Palm Beach. Florida 33401 
Wednesday. March 24.2010 
16 
10:37 - 6:51 p.m. 
17 
250 Australian Avenue South 
16 
Suite 1500 
19 
Reponed By: 
West Palm Beach. Florida 33401 
Cynthia Hopkins. RPR. FPR 
20 
Notary Public. State of Florida 
Prose Court Repotting 
Reported By: 
21 
Cynthia Hopkins. RPR. FPR 
22 
Notary Public. State of Florida 
23 
Prose Court Reporting 
24 
Job No.: 1484 
25 
Page 188 
Page 190 
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 
t•
a
4 
Plaintiff. 
Plaintiff. 
5 
5 
VOLUME II OF III 
VOLUME II OF III 
6 
1
7 
JEFFREY EPSTEIN. 
8 
AN
EFaillik 
Defendant. 
 Defendants. 
a 
9 
r 
9 
10 
DEPOSITION OF 
10
11 
12 
Wednesday. March 24. 2010 
11 
12 
V1tSMON 
OF 
10:37 - 6:51 p.m. 
13
13 
14 
Wednesday. March 24. X110 
10 
250 Australian Avenue South 
10:31- 6:5I p.m. 
West Palm Beach. Florida 33401 
15 
15 
16 
16 
17 
250 Australian Avenue South 
17 
Suite 1500 
18 
Reported By: 
16 
West Palm Beach. Florida 33401 
Cynthia Hopkins. RPR. FPR 
19 
19 
Notary Public. State of Florida 
20 
Prose Court Reporting 
21 
20 
22 
Reported By: 
21 
Cynthia Hopkins. RPR. FPR 
22 
23 
Notary Public. State of Florida 
23 
Prose Court Reporting Services 
20 
24 
Job No.: 1484 
25 
25 
(Pages 187 to 190) 
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APPEARANCES: 
1 
— — — 
2 
On behalf of the Plaintiffs. 
: 
SPENCER T. KUVIN. ESQUIRE 
2 
INDEX 
LEOPOLD KUVIN 
3 
2925 PGA Boulevard 
4 
_ _ _ 
Suite 201) 
S 
Palm Beach Garden. Florida 33410 
5 
EXAMINATION 
DIRECT CROSS REDIRECT 
Phone: 
6 
BY MR. KUVIN 
194 
6 
On behalf of the Mantas.... 
. and 
lane Doe: 
7 
BY MR. HOROWITZ 
214 
BY MR. WEISSING 
271 
g 
9 
MATTHEW WE1SSING. ESQUIRE 
8 
BY MR. GARCIA 
325 
FARMER.1AFTE WEISSING. EDWARDS 
9 
10 
ETSTOS & LEHRIMAN.P.L 
425 North Andrews Avenue 
10 
— — — 
11 
Suite 2 
11 
EXHIBITS 
Fon Lauderdale Florida 33301 
12 
 _ _ _ 
12 
13 
Phone: 
On behalf of Jane Does I through a: 
13
14 
ADAM D. HOROWITZ- ESQUIRE 
14 
EXHIBIT 
DESCRIPTION 
PAGE 
15 
MERMELSTEIN S HOROWITZ. P.A. 
IS205 Biscayne Boulevard 
15 
Suite 2215 
16 
PLAINTIFFS EX. 14 REQUEST FOR WARRANT 19-
16 
Miami. 
i 
PLAINTIFFS EX. 15 ANSWER AND 
342 
Phone: 
17 
Email: 
17 
AFFIRMATIVE DEFENSES 
IS 
On behalf of the Plunk'''. 101. 102 and 103: 
18 
19 
KATHERINE W. EMELL. ESQUIRE 
AMY JOSEFSBER(1 EDERI. ESQUIRE 
19 
20 
PODHURST ORSECK 
20 
21 
25 West Flatlet Street 
Suite S00 
21 
22
22 
23 
23 
24 
IVra telephone) 
29 
25 
25 
Page 192 
Page 194 
1 
Appearances continued... 
1 
PROCEEDINGS 
2 
On behalf of the Plaintiff. Jane Doe II: 
2 
* * * • * 
3 
1511)RO MANUEL GARCIA. ESQUIRE 
GARCIA. ELKINS & BOERRINGER 
3 
THE VIDEOGRAPHER: We're now back on the 
4 
224 Datum Avenue. Suite 900 
4 
record. It is 2:19 p.m. Starting Media Unit 
s 
West Palm Beach Fl ida 33401 
Phone: 
5 
No. 2. 
6 
6 
CONTINUED DIRECT EXAMINATION 
8 
On behalf of the Defendant: 
JACK ALAN GOLDBERGER. ESQUIRE 
7 
BY MR. KUVIN: 
ATTERBURY. GOLDBERGER & WEISS. P.A. 
8 
Q. All right. Did Jeffrey Epstein talk to 
9 
250 Australian Avenue South 
9 
you about whether or not he was going to be going to 
Suite 1400 
10 
West Pa
r ida 33401-5012 
10 
jail after he was arrested? 
Phone: 
11 
MR. 
Objection to the form. 
11 
12 
12 
standing objection. Instruct the witness not 
13 
On behalf of t • W' • • 
13 
to answer. 
1 4 
14 
THE WITNESS: On the instruction of my 
15 
lawyer. I must invoke my Fifth Amendment right. 
16 
BY MR. KUVIN: 
17 
Q. How did you first learn of the criminal 
17 
18 
investigation with respect to Mr. Epstein?
18 
19 
19 
MR. 
Objection to the form. 
20 
ALSO PRESENT: 
20 
standing objection. Instruct the witness not 
21 
Jessica Cadwell. Paralegal 
21 
to answer. 
22 
Burman. triton. Luther & Coleman. P.A. 
Joseph Kozak. Videographer 
22 
THE WITNESS: On the instruction of my 
Prose Court Reporting Services 
23 
lawyer. I must exercise my Fifth Amendment 
23 
24 
24 
right. 
25 
25 
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1 
BY MR. KUVIN: 
1 
not know about. 
2 
Q. Do you know who tipped off Jeffrey Epstein 
2 
But if you can answer, go ahead. 
3 
about an ongoing investigation against him back in 
3 
THE WITNESS: No. 
4 
2005? 
4 
BY MR. KUVIN: 
5 
MR. 
Same objection as 
5 
Q. Let me show what we'll mark as Exhibit 14. 
6 
previously stated to the last two questions and 
6 
which purports to be a request for a warrant for 
7 
same instruction. 
7 
your arrest. 
8 
THE WITNESS: On the instruction of my 
8 
MR. 
: Okay. 
9 
lawyer, I must invoke my Fifth Amendment right. 
9 
(Plaintiffs Exhibit No. 14 was marked for 
10 
BY MR. KUVIN: 
10 
identification.) 
11 
Q. Were you aware that there was a warrant 
11 
BY MR. KUVIN: 
12 
issued for your arrest in connection with 
12 
Q. Just yes or no; have you seen that request 
13 
Jeffrey Epstein? 
13 
for a warrant before? 
14 
MR. 
Objection to the form, 
14 
A. No. 
15 
standing objection, same instruction. 
15 
Q. All right. If you would turn to the 
16 
THE WITNESS: On the instruction of my 
16 
probable cause affidavit. If you would go ahead and 
17 
lawyer, I must invoke my Fifth Amendment right. 17 
turn to the -- keep turning, and again. There we 
18 
BY MR. KUVIN: 
18 
go. 
19 
Q. Have you seen the warrant that was issued 
19 
All right. There's a document attached to 
20 
for your arrest in connection with Jeffrey Epstein? 
20 
this exhibit entitled. Probable Cause Affidavit. 
21 
MR. 
Same objection and same 21 
Have you had a chance to read through this 22-page 
22 
instruction as the last question. 
22 
document in the . ast? 
23 
THE WITNESS: On the instruction of my 
23 
MR. 
: I'm sorry. Are you asking 
24 
lawyer, I must invoke my Fifth Amendment right. 24 
her if she's ever seen it before or if she's 
25 
25 
ever read it before? 
Page 196 
Page 198 
1 
BY MR. KUVIN: 
1 
MR. KUVIN: Good point. 
2 
Q. Have you seen the probable cause affidavit 
2 
BY MR. KUVIN: 
3 
with respect to the arrest warrant issued for your 
3 
Q. Let's ask first: Have ever seen it 
4 
5 
arrest on Ma 1.2006? 
MR. 
: Hang on one second. I 
4 
5 
before? 
A. I don't believe so. 
6 
will object to the form. Can you, can you 
6 
Q. Okay. If you would turn to -- keep it in 
7 
repeat the question just for the record? 
7 
front of you -- if we turn to Page 22, and we look 
8 
MR. KUVIN: Yes. 
8 
at the last paragraph. 
9 
BY MR. KUVIN: 
9 
Do you agree that Epstein in the years. 
10 
Q. Have you been made aware, or have you -- 
10 
2005. 2004 and 2005, did commit lewd and lascivious 
11 
let me clarify. Have you seen the probable cause 
11 
molestation on a 14- ear-old girl?
12 
affidavit that was attached to your warrant for 
12 
MR. 
Just if I can clarify, are 
13 
14 
arrest on Ma I. 2006? 
MR. 
: Object to the form. I 
13 
14 
you asking whether that's what the document 
says? 
15 
don't believe there ever was a warrant issued. 
15 
MR. KUVIN: No. fm asking whether she's 
16 
but go ahead and answer the question, if you 
16 
aware of it. 
17 
can. 
17 
MR. 
I'm going to object to the 
18 
THE WITNESS: No. 
18 
form. It calls for a legal conclusion that 
19 
BY MR. KUVIN: 
19 
she's not competent to make. That's ambiguous 
20 
Q. Have you seen the request for a warrant 
20 
in that regard. and also the standing objection 
21 
with the attached probable cause affidavit that was 
21 
and I will instruct her not to answer. 
22 
23 
issued on M a 1st. 2006? 
MR. 
: Object to the form. 
22 
23 
THE WITNESS: On the advice of my lawyer. 
I must to invoke my Fifth Amendment right. 
24 
Assumes her knowledge of something that she ma) 24 
BY MR. KUVIN: 
25 
not know. the existence of something ,he may 
25 
Q. Do you agree that in the years 2004 and 
3 (Pages 195 to 198) 
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1 
2005 Mr. Epstein molested hundreds of 14, IS, and 
1 
Jeffrey Epstein took nude photos of girls under the 
2 
3 
16-year-old irls? 
MR. 
Same objection to the 
2 
3 
age of IS? 
MR. 
Objection to the form. 
4 
form, standing objection and also calls for a 
4 
standing objection, instruct the witness not to 
5 
legal conclusion and is ambiguous. Instruct 
5 
answer. 
6 
the witness not to answer. 
6 
THE WITNESS: On the instruction of my 
7 
THE WITNESS: On the instruction of my 
7 
lawyer, I must invoke my Fifth Amendment right. 
8 
lawyer, I must invoke my Fifth Amendment right. 
8 
BY MR. KUVIN: 
9 
BY MR. KUVIN: 
9 
Q. Have you taken any photographs of girls 
10 
Q. Do you agree that the facts contained 
10 
under the age of 18, nude photographs of girls under 
11 
within this probable cause affidavit are true and 
11 
the age of IS ourself'? 
12 
accurate? 
12 
MR. 
: Object to the form as 
13 
MR. 
Objection to the form. 
13 
ambiguous. Can we get a time period or any 
14 
You've never established that she's read it, so 
14 
sort of --
15 
how can she say whether it's true and accurate. 
15 
MR. KUVIN: Sure. 
16 
I instruct the witness not to answer the 
16 
MR. 
-- limitation of that? 
17 
question. Do you want to clarify your 
17 
MR. KUVIN: Absolutely. 
18 
question? 
18 
BY MR. KUVIN: 
19 
MR. KUVIN: No. 
19 
Q. In the years of 2004 to 2006. did you ever 
20 
BY MR. KUVIN: 
20 
taken any nude photographs of underage girls being 
21 
Q. Were you present at 358 El Brillo Way when 
21 
girls under the a e of 18? 
22 
the search warrant was issued for that home? 
22 
MR. 
: Object to the form as 
23 
MR. 
Objection to the form as 
23 
ambiguous. Instruct the witness not to answer. 
24 
to any knowledge of 358 El Brillo Way. Also 
24 
THE WITNESS: On the advice of my lawyer, 
25 
ambiguous. Are you asking about when the 
25 
I must exercise my Fifth Amendment right. 
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1 
warrant was issued or when the warrant was 
1 
MR. KUVIN: And just so we're clear, when 
2 
executed? 
2 
you say "instruct the witness not to answer." 
3 
MR. KUVIN: I don't know. You criminal 
3 
you mean for the Fifth Amendment grounds as 
4 
guys know the language. 
4 
opposed to --
5 
BY MR. KUVIN: 
5 
MR. 
: Well, technically that 
6 
Q. When the cops came into the house and 
6 
would be manufacturing child pornography, so if 
7 
searched the home at 358 El Brillo Way. were you 
7 
the truthful answer that question would be yes, 
8 
there? 
8 
she would be admitting to a crime. 
9 
MR. 
Objection to the form as 
9 
MR. KUVIN: No I understand that. 
10 
to compound, and assuming knowledge as to 
10 
MR. 
: So yes, I'm instructing 
11 
358 El Brillo Way or any search by the police. 
11 
her not to answer the question. 
12 
Instruct the witness not to answer. 
12 
MR. KUVIN: Because there have been some 
13 
THE WITNESS: On the instruction of my 
13 
questions that we've instructed her, you've 
14 
lawyer, I must exercise my Fifth Amendment 
14 
instructed her not to answer at all, and then 
15 
privilege. 
15 
others -- I ust wanted for clarify. 
16 
BY MR. KUVIN: 
16 
MR. 
Thank you. I was getting 
17 
Q. Are you aware of any covert cameras that 
17 
sloppy. I apologize. 
18 
exist in the home at 358 El Brillo Way? 
18 
MR. KUVIN: That's okay. 
19 
MR. 
Objection to the form. 
19 
BY MR. KUVIN: 
20 
Standing objection as it relates to El Brillo 
20 
Q. All right. Do you agree that you have --
21 
Way, and instruct the witness not to answer. 
21 
well, let me ask you this: Have you taken any video 
22 
THE WITNESS: On the instruction of my 
22 
of girls under the age of 18, nude girls under the 
23 
24 
lawyer, I must invoke my Fifth Amendment right. 
BY MR. KUVIN: 
23 
24 
age of 18 in the ears 2004 through 2006? 
MR. 
: Once again --
25 
Q. Are you aware or whether or not 
25 
MR. KUVIN: Go ahead. 
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1 
MR. 
Wait. Hold on a second. 
1 
Standing objection as to knowledge of 
2 
Let me go back to the prior question about 
2 
Mr. Epstein. Instruct the witness not to 
3 
still photographs. 
3 
answer based on the Fifth Amendment. 
4 
MR. KUVIN: Yes. 
4 
THE WITNESS: On the instruction of my 
5 
MR. 
Okay. And I think the 
5 
lawyer I must exercise my Fifth Amendment 
6 
question was whether she had taken between '04 
6 
right. 
7 
and '06 any still photographs of nude women 
7 
BY MR. KUVIN: 
8 
under the age of 18. 
8 
Q. Do you know whether or not an attempt to 
9 
MR. KUVIN: Yes. 
9 
give a $90,000 donation was an attempt to stop the 
10 
MR. 
Is that correct? I want 
10 
Palm Beach Police from investigating Mr. Epstein? 
11 
to go back to that question. 
11 
MR. 
: Objection to the form. 
12 
MR. KUVIN: Okay. You can go back to that 
12 
Standing objection as previously stated, and 
13 
question. 
13 
the same instructions as the previous question. 
14 
THE WITNESS: No. 
14 
THE WITNESS: At the instruction of my 
15 
BY MR. KUVIN: 
15 
lawyer, I must invoke my Fifth Amendment right. 
16 
Q. Have you taken any nude videotape of girls 
16 
MR. KUVIN: Hold on a second. Almost 
17 
under the age of 18 for the years 2004 through 2006? 17 
done. 
18 
A. No. 
18 
BY MR. KUVIN: 
19 
Q. Asking those same questions, have you 
19 
Q. Is your mother also named 
? 
20 
taken any nude photographs of girls under the age of 20 
A. No. 
21 
IS from 2004 through 2006? 
21 
Did ou ever live at 
22 
A. No. 
23 
Q. Have you taken any nude video of girls 
23 
MR. 
: Instruct the witness not 
24 
under the age of 18 from 2004 to 2006? 
24 
to answer based on the Fifth Amendment 
25 
A. No. 
25 
privilege against self-incrimination. 
Page 204 
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1 
Q. Do you know what the COUQ Foundation is? 
1 
THE WITNESS: On the instruction of my 
2 
A. Can you repeat that? 
2 
lawyer, I must invoke my Fifth Amendment right. 
3 
Q. Do ou know what the COUQ Foundation is? 
3 
BY MR. KUVIN: 
4 
MR. 
Mr. Kuvin, can I clarify? 
4 
Did ou ever live at 
5 
Are you asking if she's ever heard of such an 
I 
'n New York, New York? 
6 
entity or whether she actually knows what that 
6 
MR. 
: Same instruction as 
7 
entity is? 
7 
previous question. 
8 
MR. KUVIN: Let's start with if she's ever 
8 
THE WITNESS: On the instruction of my 
9 
heard over it, and then I will follow up with 
9 
lawyer, I must invoke my Fifth Amendment right. 
10 
the following question of whether she knows 
10 
BY MR. KUVIN: 
11 
what it is. 
11 
Have ou ever gone by the name of 
12 
MR. 
Okay. 
12 
/ 
13 
BY MR. KUVIN: 
13 
MR. 
: Same instruction as the 
14 
Q. Have you ever heard of this, about the 
14 
previous two questions. 
15 
COUQ Foundation before? 
15 
THE WITNESS: On the instruction of my 
16 
MR. 
• I instruct her not to 
16 
lawyer I must invoke my Fifth Amendment right. 
17 
answer based on her Fifth Amendment privilege. 
17 
BY MR. KUVIN: 
18 
THE WITNESS: On the advice of my lawyer, 
18 
Did ou change your name from 
19 
I must assert my Fifth Amendment right. 
19 
to 
9 
20 
BY MR. KUVIN: 
20 
MR. 
: Objection to the form and 
21 
Q. Were you aware that Mr. Epstein, through 
21 
it assumes a prior question that there was no 
22 
the COUQ Foundation, attempted to make a $90,000 
22 
answer to, and I would instruct the witness not 
23 
donation to the Palm Beach Police Department in 
23 
to answer. 
24 
2006? 
24 
THE WITNESS: Upon the instruction of my 
25 
MR. 
Objection to the form. 
25 
lawyer. I must invoke my Filth Amendment right. 
S (Pages 203 to 206) 
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1 
BY MR. KUVIN: 
1 
compound, instruct the witness not to answer. 
2 
Have you ever used the alias of 
2 
THE WITNESS: On the instruction of my
3 
i
i
3 
lawyer, I must invoke my Fifth Amendment right. 
4 
MR. 
Objection to the -- I'm 
4 
BY MR. KUVIN: 
5 
6 
sorry. Instruct the witness not to answer 
based on Fifth Amendment privileges. 
5 
6 • 
Haveyou ever used illegal drugs with 
7 
THE WITNESS: Upon the instruction of my 
7 
MR. 
: Same objection and 
8 
lawyer, I must invoke my Fifth Amendment right. 
8 
instruction as to the previous question. 
9 
BY MR. KUVIN: 
9 
THE WITNESS: On the instruction of my 
10 
Q. Do ourparents live in-'f
• 
10 
lawyer, I must invoke my Fifth Amendment right. 
11 
MR. 
Instruct the witness not 
11 
BY MR. KUVIN: 
12 
to answer the 
based on her Fifth 
12 
O. 
ever use the 
number of 
13 
question 
Amendment privilege. 
13 
you 
phone 
14 
THE WITNESS: On instruction of my lawyer 
14 
MR. 
: Instruct the witness not 
15 
I must invoke my Fifth Amendment right. 
15 
to answer based on her Fifth Amendment 
16 
BY MR. KUVIN: 
16 
privilege. 
17 
Q. Do ou have an brothers and sisters? 
17 
THE WITNESS: On the instruction of my 
18 
MR. 
Same instruction as the 
18 
lawyer, I must invoke my Fifth Amendment right. 
19 
previous question. 
19 
BY MR. KUVIN: 
20 
THE WITNESS: On the instruction of my 
20 
Have ou ever used the phone number 
21 
lawyer, I must invoke my Fifth Amendment right. 21 
22 
BY MR. KUVIN: 
22 
MR. 
: Thank you. 
23 
Q. Have ourparents met Jeffrey Epstein? 
23 
THE WITNESS: I don't recognize that 
24 
MR. 
Objection to the form. 
24 
number.
25 
Standing objection and also instruct the 
25 
Page 208 
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1 
witness not to answer based on her Fifth 
1 
BY MR. KUVIN: 
2 
Amendment privilege. 
2 
Q. Okay. When the police entered Jeffrey 
3 
THE WITNESS: On the instruction of my 
3 
Epstein's home, they took something that's called a 
4 
lawyer, I must invoke my Fifth Amendment right. 
4 
bottle of Peach Flavored Joy Jelly. Just a 
5 
BY MR. KUVIN: 
5 
foundation of what I'm about to ask you. 
6 
Q. Do your parents know what you've done with 
6 
Have you ever seen anything called Peach 
7 
Jeffrey Epstein as it relates to this case? 
7 
Flavored Joy Jelly ever anywhere, first of all? 
8 
MR. 
Objection to the form as 
8 
Have you ever seen that before anywhere? 
9 
stated to the previous question, and same 
9 
MR. 
Just so I am clear about 
10 
instruction. 
10 
your question --
11 
THE WITNESS: On the instruction of my 
11 
MR. KUVIN: Not necessarily in a home, 
12 
lawyer, I must invoke my Fifth Amendment right. 12 
just anywhere in her entire life has she ever 
13 
BY MR. KUVIN: 
13 
seen a bottle of something called Peach 
14 
Q. Have you ever used illegal drugs with 
14 
Flavored Joy Jelly. 
15 
Jeffrey Epstein? 
15 
THE WITNESS: No, I have not. 
16 
MR. 
Objection to the form. 
16 
BY MR. KUVIN: 
17 
Standing objection, instruct the witness not to 
17 
Q. Okay. Also taken from the home were, was 
18 
answer. 
18 
an adult sex toy called a Twin Torpedo which, 
19 
THE WITNESS: On the instruction of my 
19 
according to Detective Recarey during his deposition 
20 
lawyer, I must invoke my Fifth Amendment right. 20 
was a double-headed dildo. Not with respect to 
21 
BY MR. KUVIN: 
21 
Mr. Epstein, but in your life, have you ever seen 
22 
Q. Have you ever used illegal drugs with 
22 
something called a Twin Torpedo or double-headed 
23 
Ghislaine Maxwell? 
23 
dildo? 
24 
MR. 
. Objection to the form, 
24 
A. No. I have not. 
25 
assumes knowledge of Ghislaine Maxwell. It's 
25 
Q. Also confiscated from the home was soap in 
6 (Pages 207 to 210) 
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1 
the shape of a penis and vagina. Once again, not 
1 
THE WITNESS: On the instruction of my 
2 
necessarily with respect to Mr. Epstein's home, in 
2 
lawyer, I must invoke my Fifth Amendment right. 
3 
your entire life have you ever seen soap in the 
3 
BY MR. KUVIN: 
4 
shape of a penis and vagina? 
4 
Q. Do you agree that these corporations that 
5 
A. Not that I recall. 
5 
I just mentioned were utilized by Jeffrey Epstein in 
6 
Q. Doyou ever recall being in Ohio? 
6 
an attempt to have sexual relationships with 
7 
MR. 
: Ever in her life? 
7 
underage girls? 
8 
MR. KUVIN: The state, ever in her life. 
8 
MR. 
: Objection to the form as 
9 
BY MR. KUVIN: 
9 
to compound. and also assumes knowledge of 
10 
Q. Let's start there, recall being in the 
10 
Mr. Epstein, asks for more than one answer to 
11 
State of Ohio for any reason? 
11 
the question. I would instruct her not to 
12 
A. Maybe for a layover, but not that I 
12 
answer based on her Fifth Amendment privilege 
13 
specifically remember. 
13 
because the question assumes knowledge of 
14 
Q. Okay. Do you know an Ivan Robles? 
14 
Mr. Epstein. 
15 
A. No. 
15 
THE WITNESS: Upon instruction of my 
16 
Q. Have you seen a gentleman by the name of 16 
lawyer I must invoke my Fifth Amendment right. 
17 
Alan Dershowitz at the home of Jeffrey Epstein 
17 
MR. KUVIN: I think I am done. Hang on 
18 
before? 
18 
one second. 
19 
MR. 
: Objection to the form. 
19 
All right. I appreciate it. That's all 
20 
Standing objection, presumes knowledge of 
20 
the questions I have at this time. Reserve the 
21 
Jeffrey Epstein or his home. Instruct the 
21 
right to ask any follow-up questions if other 
22 
witness not to answer. 
22 
attorneys raise new and different issues by 
23 
THE WITNESS: On the instruction of my 
23 
theirquestionin:.
24 
lawyer, I must exercise my Fifth Amendment 
24 
MR. 
Understood. 
25 
right. 
25 
MR. KUVIN: Pass the witness at this time. 
Page 212 
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1 
BY MR. KUVIN: 
1 
Who wants to go? Mr. Horowitz, do you have a 
2 
Q. Have you ever heard of the El Zorro Ranch 
2 
microphone? 
3 
Corporation? 
3 
MR. HOROWITZ: I do. 
4 
MR. 
Instruct the witness not 
4 
CROSS (MI
) 
5 
to answer based on her Fifth Amendment 
5 
BY MR. HOROWITZ: 
6 
privilege. 
6 
Q. Ms. 
did ou use the telephone 
7 
THE WITNESS: On the instruction of my 
7 
number, the 
t any time between 2001 
8 
lawyer I must exercise my Fifth Amendment 
8 
and 2006? 
9 
right. 
9 
A. On the advice of my lawyer, I must exercise my 
10 
BY MR. KUVIN: 
10 
Fifth Amendment right. 
11 
Q. Have you ever heard of the New York 
11 
. Did ou use the telephone number 
12 
Strategy Grou ? 
12 
between 2001 and 2006 at Jeffrey 
13 
MR. 
Same instruction. 
13 
Epstein's ex nse? 
14 
THE WITNESS: On the instruction of my 
14 
MR. 
: Objection to the form in 
15 
lawyer, I must invoke my Fifth Amendment right. 15 
that it assumes knowledge of Jeffrey Epstein. 
16 
BY MR. KUVIN: 
16 
Standing objection as previously stated with 
17 
Q. Have you ever heard of the Ghislaine 
17 
Mr. Kuvin. Instruct the witness not to answer. 
18 
Corporation? 
18 
based on her Fifth Amendment right. 
19 
MR. 
Same instruction. 
19 
THE WITNESS: On the instruction of my 
20 
THE WITNESS: On the instruction of my 
20 
lawyer, I must exercise my Fifth Amendment 
21 
lawyer, I must invoke my Fifth Amendment right. 21 
right. 
22 
BY MR. KUVIN: 
22 
BY MR. HOROWITZ: 
23 
Q. Have you ever heard of the Financial 
23 
Did ou use the telephone number 
24 
Strategy Grou .? 
24 
at Jeffre Epstein's direction? 
25 
MR. 
• Same instruction. 
25 
MR. 
: Same objection as the 
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previous question and the same instruction. 
1 
lawyer, I must choose to exercise my Fifth 
2 
THE WITNESS: On the instruction of my 
2 
Amendment right. 
3 
lawyer, I must exercise my Fifth Amendment 
3 
BY MR. HOROWITZ: 
4 
right. 
4 
Q. Did Jeffrey Epstein ever admit to you that 
5 
BY MR. HOROWITZ. 
5 
between the years 2001 and 2006 he had sexual 
6 
Q. Was 
a telephone number from 
6 
contact with underage girls who came to• quote. work 
7 
which you placed telephone calls on behalf of 
7 
for him? 
8 
Jeffrey Epstein? 
8 
MR. 
: Objection to the form. 
9 
MR. 
Same objection as the 
9 
standing objection previously stated. Also 
10 
previous question and the same instruction. 
10 
ambiguous as to the term "work for him." 
11 
THE WITNESS: On the instruction of my 
11 
Instruct the witness not to answer based on her 
12 
lawyer, I must invoke my Fifth Amendment right. 12 
Fifth Amendment privilege. 
13 
BY MR. HOROWITZ: 
13 
THE WITNESS: On the instruction of my 
14 
Q. Between 2001 and 2006 
14 
lawyer, I must choose to exercise my Fifth 
15 
set up massa e tables for Jeffrey Epstein? 
15 
Amendment right. 
16 
MR. 
• Same objection as the 
16 
BY MR. HOROWITZ: 
17 
previous question, same instruction. 
17 
Q. Between the years 2001 and 2006. did 
18 
THE WITNESS: On the instruction of my 
18 
Jeffrey Epstein ever tell you that he masturbated in 
19 
lawyer, I must invoke my Fifth Amendment right. 19 
the presence of underage girls who came to. quote•
20 
BY MR. HOROWITZ: 
20 
work for him? 
21 
Q. Between 2001 and 2006, 
21 
MR. 
: Objection to the form. 
22 
arrange massage oils before Jeffrey Epstein's 
22 
Standing objection previously stated and 
23 
massages? 
23 
instruct the witness not to answer. 
24 
MR. 
Objection to the form. 
24 
THE WITNESS: On the instruction of my 
25 
It's compound and assumes facts not admitted to 
25 
lawyer, I must exercise my Fifth Amendment 
Page 216 
Page 218 
1 
be to the knowledge of this witness, and I 
1 
right. 
2 
instruct her not to answer based on her Fifth 
2 
BY MR. HOROWITZ: 
3 
Amendment privilege. 
3 
Q. Do you know a girl named -- or did you 
4 
THE WITNESS: On the instruction of my 
4 
know a girl named Jane Doe No. 2. (spells name), 
5 
lawyer, I must invoke my Fifth Amendment right. 
5 
when she was still under the age of 18? 
6 
BY MR. HOROWITZ: 
6 
A. On the instruction of my lawyer, I must choose 
7 
At any time between 2001 and 2006, 
7 
to invoke my Fifth Amendment right. 
I 
to place telephone calls to girls under the 
8 
Q. Do you acknowledge that Jane Doe No. 2 
9 
age of IS when Jeffrey Epstein was in Palm Beach to 
9 
came to Jeffrey Epstein's Palm Beach estate in late 
10 
see if the girls wanted to. quote/unquote, work? 
10 
2004? 
11 
MR. 
Objection to the form as 
11 
MR. 
Objection to the form. 
12 
compound and instruct the witness not to answer 
12 
Standing objection previously stated as to 
13 
based on her Fifth Amendment privilege. 
13 
compound and ambiguous, and I instruct the 
14 
THE WITNESS: On the instruction of my 
14 
witness not to answer based on her Fifth 
15 
lawyer, I must invoke my Fifth Amendment right. 15 
Amendment privilege, based on the prior, based 
16 
BY MR. HOROWITZ: 
16 
on the prior answer to the prior question. 
17 
Q. Between the years 2001 and 2006, did you 
17 
THE WITNESS: Sony. 
18 
and Jeffrey Epstein have an understanding between 
18 
MR. HOROWITZ: There was a question 
19 
the two of you that the term "work" referred to him 
19 
pending. 
20 
having sexual contact with girls under the age of 
20 
MR. 
There was a question 
21 
18? 
21 
pending. I have instructed you not to answer. 
22 
MR. 
Objection to the form, 
22 
THE WITNESS: Oh. then upon the 
23 
standing object, standing objection, and 
23 
instruction of my lawyer. I must invoke my 
24 
instruct the witness not to answer. 
24 
Fifth Amendment right. 
25 
THE WITNESS: On the instruction of m 
25 
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1 
BY MR. HOROWITZ: 
1 
THE WITNESS: On the instruction of my 
2 
Q. Between the years 2001 and 2006. did 
2 
lawyer, I must invoke my Fifth Amendment right. 
3 
Jeffrey, did Jeffrey Epstein instruct you to 
3 
BY MR. HOROWITZ: 
4 
communicate by telephone to arrange for girls under 
4 
Q. Did you tell Jeffrey Epstein that you had 
5 
the age of 18 to come to his house for his sexual 
5 
to confirm by telephone that Jane Doe No. 2 would be 
6 
gratification? 
6 
coming to his home at a specific time to give him a 
7 
MR. 
: Objection to the form. 
7 
massage? 
8 
Standing objection previously stated, and also 
8 
MR. 
Objection to the form. 
9 
it's ambiguous. Instruct the witness not to 
9 
standing objection as previously stated, and 
10 
answer based on her Fifth Amendment privilege. 10 
the same instruction to the witness. 
11 
THE WITNESS: On the instruction of my 
11 
THE WITNESS: On the instruction of my 
12 
lawyer, I must exercise my Fifth Amendment 
12 
lawyer, I must invoke my Fifth Amendment right. 
13 
privilege. 
13 
BY MR. HOROWITZ: 
14 
BY MR. HOROWITZ: 
14 
Q. Did Jeffrey Epstein tell you that it was 
15 
Q. In late 2004, did you receive a telephone 
15 
his intent during the course of Jane Doe No. 2's 
16 
call wherein you were told that a girl named Jane 
16 
visit to his home to have sexual contact with her? 
17 
Doe No. 3 was bringing Jane Doe No. 2 to Jeffrey 
17 
MR. 
Objection to the form as 
18 
Epstein's home? 
18 
previously stated to the last question and same 
19 
MR. 
: Objection to form. 
19 
instruction to the witness. 
20 
Standing objection, compound, and instruct the 
20 
THE WITNESS: On the instruction of my 
21 
witness not to answer based upon her Fifth 
21 
lawyer, I must invoke my Fifth Amendment right. 
22 
Amendment privilege. 
22 
BY MR. HOROWITZ: 
23 
THE WITNESS: On the instruction of my 
23 
Q. At any point did Jane Doe No. 2 tell you 
24 
25 
lawyer, I must exercise my Fifth Amendment 
right. 
24 
25 
that she was I8 ears old or older? 
MR. 
Objection to the form, 
Page 220 
Page 222 
1 
BY MR. HOROWITZ: 
1 
assumes knowledge of a person by the name of 
2 
Q. Did Jeffrey Epstein observe you receive a 
2 
Jane Doe No. 2. It's a compound question and 
3 
telephone call wherein you were told that Jane Doe 
3 
instruct the witness not to answer. 
4 
No. 3 was brio in Jane Doe No. 2 to his home? 
4 
THE WITNESS: On the instruction of my 
5 
MR. 
Standing objection to the 
5 
lawyer, I must invoke my Fifth Amendment right. 
6 
form as stated to the previous question, same 
6 
BY MR. HOROWITZ: 
7 
instruction. 
7 
Q. In your own mind, is it. is it accurate to 
8 
THE WITNESS: On the instruction of my 
8 
say that you never believed that Jane Doe No. 2 was 
9 
lawyer, I must invoke my Fifth Amendment right. 
9 
18 or older correct? 
10 
BY MR. HOROWITZ: 
10 
MR. 
Objection to the form, 
11 
Q. Did Jeffrey Epstein instruct you to 
11 
same basis as the prior question, and the same 
12 
communicate by telephone to arrange for Jane Doe 
12 
instruction. 
13 
No. 2 to come to his home for his sexual 
13 
THE WITNESS: On the instruction of my 
14 
gratification? 
14 
lawyer, I must invoke my Fifth Amendment right. 
15 
MR. 
Standing objection as 
15 
BY MR. HOROWITZ: 
16 
previously stated, same instruction to the 
16 
Q. Did Jane Doe No. 2 tell ou that she 
17 
witness. 
17 
attended 
. 
18 
THE WITNESS: On the instruction of my 
18 
MR. 
Same objection as the 
19 
lawyer, I must invoke my Fifth Amendment right. 19 
previous question, same instruction. 
20 
BY MR. HOROWITZ: 
20 
THE WITNESS: On the instruction of my 
21 
Q. Did Jeffrey Epstein inform you that Jane 
21 
lawyer, I must invoke my Fifth Amendment right. 
22 
Doe No. 2 would be giving him a massage that was 
22 
BY MR. HOROWITZ: 
23 
sexual in nature? 
23 
Q. Are you aware -- did, did Jeffrey Epstein 
24 
MR. 
. Standing objection to the 
24 
tell you that he sexually abused Jane Doe No. 2 when 
25 
form and the same instruction to the witness. 
25 
she was a child? 
9 (Pages 219 to 222) 
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1 
MR. 
Objection to the form. 
1 
answer that. You can move on. 
2 
Standing objection relating to Jeffrey Epstein 
2 
MR. HOROWITZ: You're, you're directing 
3 
or any knowledge of Jeffrey Epstein. Also as 
3 
her not to answer that? 
4 
to Jane Doe No. 2, same instruction to the 
4 
MR. 
I'm directing her not to 
5 
witness. 
5 
answer that question because there are. there 
6 
THE WITNESS: On the instruction of my 
6 
are legal bases for the objections that 
7 
lawyer, I must invoke my Fifth Amendment right. 
7 
underlie the Fifth Amendment invocation, and at 
8 
BY MR. HOROWITZ: 
8 
some point presumably a judge will rule on 
9 
Q. Did Jeffrey Epstein instruct you to take 
9 
those before the jury ever hears this. 
10 
Jane Doe No. 2's name and telephone number for the 
10 
BY MR. HOROWITZ: 
11 
purpose of calling her to come to his house for more 
11 
Q. Ms. 
did you know a girl named Jane 
12 
13 
sexual activit ? 
MR. 
Objection to the form. 
13 
12 
Doe No. 3 when she was still a child? 
MR. 
Objection to the form as 
14 
Standing objection, same objection to the 
14 
to what you mean by when you say a child and 
15 
previous question, same instruction. 
15 
also assumes knowledge of a person, so I 
16 
THE WITNESS: On the instruction of my 
16 
instruct the witness not to answer. 
17 
lawyer, I must invoke my Fifth Amendment right. 17 
THE WITNESS: On the instruction of my 
18 
BY MR. HOROWITZ: 
18 
lawyer, I must invoke my Fifth Amendment right. 
19 
Q. Did Jeffrey Epstein instruct you to put 
19 
BY MR. HOROWITZ: 
20 
Jane Doe No. 2's name and telephone number into a 
20 
Q. Did, did Jeffrey Epstein instruct ou to
21 
master journal or log in which you and he archived 
21 
communicate by telephone with 
for the 
22 
the names and contact information of teenage girls? 
22 
purpose of arranging for underage girls to come to 
23 
MR. 
Objection to the form, 
23 
his house so that he. Jeffrey Epstein, could engage 
24 
standing objection, otherwise compound and 
24 
in sexual activit ? 
25 
instruct the witness not to answer. 
25 
MR. 
Objection to the form. 
Page 224 
Page 226 1
1 
THE WITNESS: On the instruction of my 
1 
Standing objection, compound and ambiguous. 
2 
lawyer, I must invoke my Fifth Amendment right. 
2 
Instruct the witness not to answer on Fifth 
3 
BY MR. HOROWITZ 
3 
Amendment grounds. 
4 
Q. Did you, in fact, place Jane Doe No. 2's 
4 
THE WITNESS: On the instruction of my 
5 
name and telephone number into a master journal or 
5 
lawyer, I must invoke my Fifth Amendment right. 
6 
log in which you and Jeffrey Epstein archived the 
6 
BY MR. HOROWITZ: 
7 
names and contact information for teenage girls? 
7 
Q. Did Jeffrey Epstein instruct you to 
8 
MR. 
Objection to the form, 
8 
communicate by telephone to arrange for Jane Doe No. 
9 
same as the previous question, ambiguous and 
9 
3 to give him a massy e? 
10 
compound, and I instruct the witness not to 
10 
MR. 
: Same objection as stated 
11 
answer. 
11 
to the previous question. and standing 
12 
THE WITNESS: On the instruction of my 
12 
objection. and instruct the witness not to 
13 
lawyer, I must invoke my Fifth Amendment right. 13 
answer. 
14 
BY MR. HOROWITZ: 
14 
THE WITNESS: On the instruction of my 
15 
Q. You have asserted a Fifth Amendment 
15 
lawyer, I must invoke my Fifth Amendment right. 
16 
objection as to a number of my questions relating to 
16 
BY MR. HOROWITZ: 
17 
Jane Doe No. 2. Is there any reason in your mind a 
17 
Q. Did Jeffrey Epstein inform you that the 
18 
jury should not infer from your responses today that 
18 
massage Jane Doe No. 3 was to give him would be 
19 
you did, in fact, assist Mr. Epstein in procuring 
19 
sexual in nature? 
20 
minors for sexual activi ? 
20 
MR. 
: Same standing objection 
21 
MR. 
Right. Objection to the 
21 
previously stated, and I instruct the witness 
22 
form. We're not going to answer that. That 
22 
not to answer. 
23 
calls for a legal conclusion, and for her to 
23 
THE WITNESS: On the instruction of my 
24 
speculate on legal objections that have been 
24 
lawyer, I must invoke my Fifth Amendment right. 
25 
made by her counsel. and were not going to 
25 
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Page 227 
BY MR. HOROWITZ: 
1 
Page 229 
MR. 
Same objection to the 
2 
Q. Did Jeffrey Epstein observe you speaking 
2 
previous question, same instruction. 
3 
with 
by telephone arranging for Jane 
3 
THE WITNESS: On the instruction of my 
i 
4 
Doe No. 3 to come to his home to give him a massage. 
4 
lawyer, I must invoke my Fifth Amendment right. 
5 
MR. 
Objection to the form. 
5 
BY MR. HOROWITZ: 
6 
Standing objection, otherwise compound and 
6 
•. Jane Doe No. 3 told you she attended-
7 
ambiguous and instruct the witness not to 
I 
correct? 
8 
answer. 
8 
MR. 
Instruct the witness not 
9 
THE WITNESS: On the instruction of my 
9 
to answer based on her Fifth Amendment 
10 
lawyer, I must invoke the Fifth Amendment 
10 
privilege. 
11 
right. 
11 
THE WITNESS: On the instruction of my 
12 
BY MR. HOROWITZ: 
12 
lawyer, I must invoke my Fifth Amendment right. 
13 
Q. Did you tell Jeffrey Epstein that you had 
13 
BY MR. HOROWITZ: 
14 
confirmed by telephone that Jane Doe No. 3 would be 
14 
Q. Did Jeffrey Epstein instruct you to take 
15 
coming to his home, his home at a specific time to 
15 
Jane Doe No. 3's name and telephone number for the 
16 
give him a massy e? 
16 
purpose of calling her to come back to his home for 
17 
MR. 
Same objection as stated 
17 
more sexual activit ? 
18 
to the previous question. Same instruction to 
18 
MR. 
Objection to the form. 
19 
the witness. 
19 
standing objection previously stated. Instruct 
20 
THE WITNESS: On the instruction of my 
20 
the witness not to answer. 
21 
lawyer, I must invoke my Fifth Amendment right. 
21 
THE WITNESS: On the instruction of my 
22 
BY MR. HOROWITZ: 
22 
lawyer I must invoke my Fifth Amendment right. 
23 
Q. Did Jeffrey Epstein tell you it was his 
23 
BY MR. HOROWITZ: 
24 
intent during the course of Jane Doe No. 3's visit 
24 
Q. Did you, in fact, after Jane Doe No. 3's 
25 
to his home to engage her in sexual activity? 
25 
first visit to Jeffrey Epstein's home, call her to 
Page 228 
Page 230 
1 
MR. 
Same objection stated to 
1 
arrange for her to come back to his house for more 
2 
the previous two questions and the same 
2 
sexual activi ? 
3 
instruction. 
3 
MR. 
Standing objection to the 
4 
THE WITNESS: On the instruction of my 
4 
form of the question. Instruct the witness not 
5 
lawyer, I must invoke my Fifth Amendment right. 
5 
to answer. 
6 
BY MR. HOROWITZ: 
6 
THE WITNESS: On the instruction of my 
7 
Q. Did Jeffrey Epstein tell you that during 
7 
lawyer I must invoke my Fifth Amendment right. 
8 
the course of Jane Doe No. 3's visit to his home. 
8 
BY MR. HOROWITZ: 
9 
that he did, in fact, persuade her to engage in 
9 
Q. Did Jeffrey Epstein instruct you to put 
10 
sexual activit ? 
10 
Jane Doe No. 3's name and telephone number into a 
11 
MR. 
: Objection to the form. 
11 
master journal or log in which you and he archived 
12 
Standing objection previously stated. Instruct 
12 
the names and contact information for underage 
13 
the witness not to answer. 
13 
girls? 
14 
THE WITNESS: On the instruction of my 
14 
MR. 
Objection to the form, 
15 
lawyer, I must invoke my Fifth Amendment right. 15 
standing objection. Otherwise compound and 
16 
BY MR. HOROWITZ: 
16 
ambiguous and instruct the witness not to 
17 
Q. At any point did Jane Doe No. 3 tell you 
17 
answer. 
18 
that she was 18 or older? 
18 
THE WITNESS: On the instruction of my 
19 
MR. 
Objection to the form and 19 
lawyer I must invoke the Fifth Amendment. 
20 
instruct the witness not to answer. 
20 
BY MR. HOROWITZ: 
21 
THE WITNESS: On the instruction of my 
21 
Q. Did you, in fact, put Jane Doe No. 3's 
22 
lawyer, I must invoke my Fifth Amendment right. 22 
name and telephone number into a master journal or 
23 
BY MR. HOROWITZ: 
23 
log, in which you and Jeffrey Epstein had archived 
24 
Q. In your mind you didn't believe that Jane 
24 
the names and information of teenage girls? 
25 
Doe No. 3 was 18 or older. correct? 
25 
MR. 
Objection to the font). 
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1 
standing objection and otherwise compound and 
1 
answer. 
2 
instruct the witness not to answer. 
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 exercise my Fifth Amendment 
4 
BY MR. HOROWITZ: 
5 
right. 
5 
. Did ou, in fact, communicate with 
6 
BY MR. HOROWITZ: 
6 
by telephone to arrange for Jane Doe 
7 
Q. Okay. You've asserted a Fifth Amendment 
7 
 to Jeffre 
No. 4 to come 
Epstein's home? 
8 
objection and assertion of the privilege as to my 
8 
MR. 
: Standing objection as 
9 
questions about Jane Doe No. 3. Is there any reason 
9 
previously stated. Instruct the witness not to 
10 
why a jury should not infer from your assertion of 
10 
answer. 
11 
the privilege that you did, in fact, assist 
11 
THE WITNESS: On the instruction of my 
12 
Jeffrey Epstein in procuring minors for his sexual 
12 
lawyer, I must invoke my Fifth Amendment right. 
13 
pleasure? 
13 
BY MR. HOROWITZ: 
14 
MR. 
: Same objection I stated 
14 
Q. Did Jeffrey Epstein inform you that the 
15 
the last time as to the other client. There 
15 
massage Jane Doe No. 4 was to give him would be 
16 
have been legal objections lodged to the 
16 
sexual in nature? 
17 
questions. If a judge rules as to the legality 
17 
MR. 
: Objection to the form. 
18 
of the questions and the propriety of the 
18 
Standing objection previously stated. Instruct 
19 
answers, then the jury can draw whatever 
19 
the witness not to answer. 
20 
inference the judge's instructs them to draw. 
20 
THE WITNESS: On the instruction of my 
21 
but until then we're not going to speculate on 
21 
lawyer, I must invoke my Fifth Amendment right. 
22 
what the jury ought to conclude based on 
22 
BY MR. HOROWITZ: 
23 
questions that haven't been ruled to be proper. 
23 
Q. Did Jeffre Epstein observe you speaking 
24 
MR. HOROWITZ: So were clear, you have 
24 
with 
to arrange for Jane Doe No. 4 to 
25 
instructed her not to answer? 
25 
come to his home for sexual activity? 
Page 232 
Page 234 
1 
MR. 
: I've instructed her not to 
1 
MR. 
: Objection to the form. 
2 
answer, yes. 
2 
Standing objection as previously stated, and 
3 
BY MR. HOROWITZ: 
3 
compound and ambiguous and instruct the witness 
4 
Q. Ms. 
did you know a girl named Jane 
4 
not to answer. 
5 
Doe No. 4 when she was still a child? 
5 
THE WITNESS: On the instruction of my 
6 
A. On the instruction of my lawyer, I must invoke 
6 
lawyer, I choose to invoke my Fifth Amendment 
7 
my Fifth Amendment right. 
7 
right. 
8 
Q. Did Jane Doe No. 4 come to 
8 
BY MR. HOROWITZ: 
9 
Jeffrey Epstein's Palm Beach home on multiple 
9 
Q. Prior to May of 2005, did you answer phone 
10 
occasions between 2003 and 2005? 
10 
calls at Jeffrey Epstein's home from Jane Doe No. 4 
11 
MR. 
: Objection to the form. 
11 
during which you arranged for Jane Doe No. 4 to come 
12 
standing objection. Otherwise compound and 
12 
to Jeffrey E• stein's home? 
13 
instruct the witness not to answer based on her 
13 
MR. 
: Objection to the form. 
14 
Fifth Amendment privilege. 
14 
Standing objection previously stated. It's 
15 
THE WITNESS: On the instruction of my 
15 
compound. and instruct the witness not to 
16 
lawyer, I must choose to invoke my Fifth 
16 
answer. 
17 
Amendment right. 
17 
THE WITNESS: At the instruction of my 
18 
BY MR. HOROWITZ: 
18 
lawyer, I must invoke my Fifth Amendment right. 
19 
Q. At any time prior to May of 2005 did 
19 
BY MR. HOROWITZ: 
20 
21 
Jeffre E stein instruct you to communicate with 
by telephone to arrange for Jane Doe 
20 
21 
Q. Prior to May of 2005, did Jeffrey Epstein 
observe you speaking with Jane Doe No. 4 by 
22 
No. 4 to come to his home? 
22 
telephone after your making arrangements for Jeff --
23 
MR. 
: Standing objection to the 
23 
for Jane Doe No. 4 to come to his home? 
24 
form of the question. Otherwise ambiguous and 
24 
MR. 
: Objection to the form. 
25 
compound. and instruct the witness not to 
25 
standing objection. and instruct the witness 
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not to answer. 
1 
Standing objection and instruct the witness not 
2 
THE WITNESS: On the instruction of my 
2 
to answer. 
3 
lawyer, I must invoke my Fifth Amendment right. 
3 
THE WITNESS: On the instruction of my 
4 
BY MR. HOROWITZ: 
4 
lawyer, I must invoke my Fifth Amendment right. 
5 
Q. Prior to May of 2005, did Jeffrey Epstein 
5 
BY MR. HOROWITZ: 
6 
instruct you to get Jane Doe No. 4's telephone 
6 
Q. Did Jane Doe No. 4 tell you and 
7 
number so that you could communicate with her for 
7 
Jeffrey Epstein that she attended Royal Palm Beach 
8 
the purpose of schedulin future massages? 
8 
High School? 
9 
MR. 
Objection to the form, 
9 
MR. 
Objection to the form. 
10 
standing objection, otherwise compound and 
10 
standing objection. instruct the witness not to 
11 
instruct the witness not to answer. 
11 
answer. 
12 
THE WITNESS: On the instruction of my 
12 
THE WITNESS: On the instruction of my 
13 
lawyer, I must invoke my Fifth Amendment 
13 
lawyer, I must invoke my Fifth Amendment right. 
14 
privilege. 
14 
BY MR. HOROWITZ: 
15 
BY MR. HOROWITZ: 
15 
Q. Did Jane Doe No. 4 re:ularl discuss her 
16 
Q. Did you on multiple occasions tell Jeffrey 
16 
life at 
with you in the 
17 
Epstein that you had confirmed by telephone that 
17 
presence of Jeffrey E tein? 
18 
Jane Doe No. 4 would be coming to his home for a -- 18 
MR. 
: Objection to form, 
19 
at a specific time to ive him a massage? 
19 
standing objection as well as ambiguous as to 
20 
MR. 
Objection to the form. 
20 
what "regularly" means. Instruct the witness 
21 
It's compound and standing objection as well. 
21 
not to answer. 
22 
and instruct the witness not to answer. 
22 
THE WITNESS: On the instruction of my 
23 
THE WITNESS: On the instruction of my 
23 
lawyer, I must invoke my Fifth Amendment right. 
24 
lawyer, I must invoke my Fifth Amendment 
24 
BY MR. HOROWITZ: 
25 
privilege. 
25 
Q. Did Jane Doe No. 4 come to Jeffrey 
Page 236 
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1 
BY MR. HOROWITZ: 
1 
Epstein's Palm Beach home on dozens of occasions 
2 
Q. Did Jeffrey Epstein tell you it was his 
2 
between 2003 and May of 2005, to give him massages 
3 
intent during the course of Jane Doe No. 4's visits 
3 
during which he en a ed her in sexual activity? 
4 
to his home to induce her to engage in sexual 
4 
MR. 
Objection to the form, 
5 
activity? 
5 
standing objection. It's also otherwise 
6 
MR. 
: Objection to the form. 
6 
compound and instruct the witness not to 
7 
standing objection and instruct the witness not 
7 
answer. 
8 
to answer. 
8 
THE WITNESS: On the instruction of my 
9 
THE WITNESS: On the instruction of my 
9 
lawyer, I must invoke my Fifth Amendment right. 
10 
lawyer. I must invoke my Fifth Amendment right. 
10 
BY MR. HOROWITZ: 
11 
11 
Q. Prior to May of 2005, did Jeffrey Epstein 
BY MR. HOROWITZ: 
12 
Q. Did Jeffrey Epstein tell you that, in 
12 
instruct you to communicate with Jane Doe No. 4. via 
13 
fact, during Jane Doe No. 4 -- 4's visits to his 
13 
telephone, to arrange for Jane Doe No. 4 to come to 
14 
home. he was able to induce her to engage in sexual 
14 
his Palm Beach home so he could engage Jane Doe 
15 
activity? 
15 
No. 4 in sexual activit ? 
16 
MR. 
Objection to the form. 
16 
MR. 
Objection to the form as 
17 
same objection as the previous questions. 
17 
stated in the previous question. Same 
18 
Instruct the witness not to answer. 
18 
instruction to the witness. 
19 
THE WITNESS: On the instruction of my 
19 
THE WITNESS: On the instruction of my 
20 
lawyer. I must invoke my Fifth Amendment right. 
20 
lawyer, I must invoke my Fifth Amendment right. 
21 
BY MR. HOROWITZ: 
21 
BY MR. HOROWITZ: 
22 
Q. Did both you and Jeffrey Epstein know that 
22 
Q. Did Jeffrey Epstein instruct you to tell 
23 
Jane Doe No. 4 was younger than 18 when she came to 23 
Jane Doe No. 4 to lie to police investigators during 
24 
Jeffrey Epstein's home in 2003 and 2004? 
24 
the course of their 2005 investigation? 
25 
MR. 
: Objection to the foi tn. 
25 
MR. 
Objection to the form as 
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stated to the last several questions and 
1 
MR. 
Objection to the form. 
2 
instruct the witness not to answer. 
2 
Its a compound question and standing objection 
3 
THE WITNESS: On the instruction of my 
3 
as well. Instruct the witness not to answer. 
4 
lawyer, I must invoke my Fifth Amendment right. 
4 
THE WITNESS: On the instruction of my 
5 
5 
lawyer. I must invoke my Fifth Amendment right. 
BY MR. HOROWITZ: 
6 
Q. Did you, in fact, tell Jane Doe No. 4 to 
6 
BY MR. HOROWITZ: 
7 
lie to police invest, investigators during the 
7 
Q. Did you inform Jeffrey Epstein that you 
8 
course of their 2005 investigation of Jeffrey 
8 
had been provided Jane Doe No. 5's telephone number? 
9 
Epstein? 
9 
MR. 
Same objection as the 
10 
MR. 
: Object to the form because 10 
previous question, same instruction. 
11 
it presumes knowledge of Jane Doe No. 4. 
11 
THE WITNESS: Upon instruction of my 
12 
Instruct the witness not to answer. 
12 
lawyer, I must invoke my Fifth Amendment right. 
13 
THE WITNESS: Upon the instruction of my 
13 
BY MR. HOROWITZ: 
14 
lawyer. I must invoke my Fifth Amendment right. 
14 
Q. Did Jeffrey Epstein instruct you to call 
15 
BY MR. 
: 
15 
Jane Doe No. 5 to come to his home and give him a 
16 
Q. Okay. You've asserted a Fifth Amendment 
16 
massage in either 2001 or 2002? 
17 
objection and privilege as to my questions about 
17 
MR. 
Objection to the form. 
18 
Jane Doe No. 4, yourself. and Jeffrey Epstein. Is 
18 
same objection as the previous questions and 
19 
there any reason in your mind why a jury should not 
19 
same instruction to the witness. 
20 
infer from your assertion of the privilege that you 
20 
THE WITNESS: On the instruction of my 
21 
did, in fact, assist Mr. Epstein in committing 
21 
lawyer, I must invoke my Fifth Amendment right. 
22 
sexual abuse u n Jane Doe No. 4? 
22 
BY MR. HOROWITZ:
23 
MR. 
: I am going to instruct the 
23 
Q. Did Jeffrey Epstein inform you that the 
24 
witness not to answer the question for the 
24 
massage Jane Doe No. 5 was to give him would be 
25 
reasons I stated at the last client that we 
25 
sexual in nature? 
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1 
discussed. The questions are legally not 
1 
MR. 
: Same objection previously 
2 
proper in our view, and therefore the questions 
2 
stated, standing objection and instruct the 
3 
and answers should not be held against her 
3 
witness not to answer. 
4 
until a judge rules on the propriety of the 
4 
THE WITNESS: Upon the instruction of my 
5 
questions. And we can address that another 
5 
lawyer, I must invoke my Fifth Amendment right. 
6 
day. I'm instructing her not to answer. 
6 
BY MR. HOROWITZ: 
7 
BY MR. HOROWITZ: 
7 
Q. Did Jeffrey Epstein observe you speaking 
8 
Q. Okay. Ms. 
do you know a girl 
8 
with Jane Doe No. 5 on the telephone to arrange for 
9 
named Jane Doe No. 5 when she was still a child 
9 
Jane Doe No. 5 to come to his home for a massage? 
10 
under the age of 18? 
10 
MR. 
: Same objection as previous 
11 
A. At the instruction my lawyer. I must invoke my 11 
questions and same, to the form of the 
12 
Fifth Amendment right. 
12 
question, and same instruction. 
13 
Q. Did a child under the age of 18 named Jane 
13 
THE WITNESS: Upon the instruction of my 
14 
Doe No. 5 come to Jeffrey Epstein's Palm Beach home 14 
lawyer, I must invoke my Fifth Amendment right. 
15 
in approximate) 2001 or 2002? 
15 
BY MR. HOROWITZ: 
16 
MR. 
Objection to the form. 
16 
Q. Did you tell Jeffrey Epstein that you had 
17 
Instruct the witness not to answer. 
17 
confirmed by telephone that Jane Doe No. 5 would be 
18 
THE WITNESS: On the instruction of my 
18 
at his home at a specific time to give him a 
19 
lawyer, I must invoke my Fifth Amendment right. 
19 
massage? 
20 
BY MR. HOROWITZ: 
20 
MR. 
: Objection to the form and 
21 
Q. In 2001 or 2002 did you inform 
21 
instruct the witness not to answer. 
22 
Jeffrey Epstein that you received a telephone call 
22 
THE WITNESS: On the instruction of my 
23 
in which you were referred to an underage girl named 
23 
lawyer, I must invoke my Fifth Amendment right. 
24 
Jane Doe No. 5 who would be willing to come to his 
24 
BY MR. HOROWITZ: 
25 
home to give him a massage for money? 
25 
Q. Did Jeffrey Epstein tell you that it was 
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his intent, during the course of Jane Doe No. 5's 
1 
Amendment objection or privilege as to my questions 
2 
visit to his home, to persuade her to engage in 
2 
about Jane Doe No. 5. Is there any reason in your 
3 
sexual activ it ? 
3 
mind why a jury should not infer that the reason 
4 
MR. 
: Objection to the form. 
4 
you're asserting the Fifth Amendment is because you 
5 
standing objection. Instruct the witness not 
5 
and Jeffrey Epstein committed a crime in inducing 
6 
to answer based on Fifth Amendment. 
6 
and enticing Jane Doe No. 5 to come to his home for 
7 
THE WITNESS: On the instruction of my 
7 
sexual activit ? 
8 
lawyer. I must invoke my Fifth Amendment right. 
8 
MR. 
: Once again. I instruct the 
9 
9 
witness not to answer. Legal basis is the 
BY MR. HOROWITZ: 
10 
Q. Did Jeffrey Epstein tell you that during 
10 
question is not reasonably calculated to lead 
11 
the course of Jane Doe No. 5's visit to his home in 
11 
to admissible evidence. It's not otherwise 
12 
either 2001 or 2002 that he succeeded in persuading 
12 
proper discovery. And for the reasons I stated 
13 
her to enga e in sexual activity with him? 
13 
as to the prior witnesses, until the legality 
14 
MR. 
: Objection to the form. 
14 
and propriety of the questions is ruled upon by 
15 
standing objection. Otherwise compound and 
15 
the court, there should be no inference drawn. 
16 
instruct the witness not to answer based on the 
16 
BY MR. HOROWITZ: 
17 
Fifth Amendment. 
17 
Q. Ms. 
--
18 
THE WITNESS: On the instruction by my 
18 
MR. 
: One second. Go ahead. 
19 
lawyer, I must invoke my Fifth Amendment right. 
19 
I'm sorry. 
20 
20 
MR. HOROWITZ: You're conferring about a 
BY MR. HOROWITZ: 
21 
Q. Did Jeffrey Epstein instruct you to take 
21 
privilege I trust? 
22 
Jane Doe No. 5's name and telephone number down so 22 
MR. 
: Yes, privilege issue. 
23 
that you and he could call Jane Doe No.5 to come to 
23 
BY MR. HOROWITZ: 
24 
his home for more sexual activity? 
24 
Q. Ms. 
, do, did you know a girl named 
25 
MR. 
Objection to the form. 
25 
Jane Doe No. 6 when she was still a child under the 
Page 244 
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1 
Instruct the witness not to answer. 
1 
age of 18? 
2 
THE WITNESS: On the instruction of my 
2 
A. At the advice of counsel, I must invoke my 
3 
lawyer, I must invoke my Fifth Amendment right. 
3 
Fifth Amendment right. 
4 
BY MR. HOROWITZ: 
4 
Q. Ms. 
. did Jane Doe No. 6 come to 
5 
Q. After Jane Doe No. 5's first visit, did 
5 
Jeffrey Epstein's Palm Beach home in approximately 
6 
Jeffrey Epstein instruct you to call her on the 
6 
August of 2004 when she was still a child? 
7 
telephone to arrange for her to come back for more 
7 
MR. 
: Objection to the form, 
8 
sexual activit ? 
8 
standing objection, and instruct the witness 
9 
MR. 
: Objection to the form as 
9 
not to answer. 
10 
previously stated, and form, standing objection 
10 
THE WITNESS: On the instruction of 
11 
and instruct the witness not to answer. 
11 
counsel, I must invoke my Fifth Amendment 
12 
THE WITNESS: On the instruction of my 
12 
right. 
13 
lawyer, I must invoke my Fifth Amendment right. 
13 
BY MR. HOROWITZ: 
14 
BY MR. HOROWITZ: 
14 
Q. Ms. =, 
were you aware that Jane Doe 
15 
Q. Did you, in fact, call Jane Doe No. 5 on 
15 
No. 6 was just 13 years old when she came to Jeffrey 
16 
the telephone to arrange for her to come back to 
16 
Epstein's home in Au ust of 2004? 
17 
Jeffrey Epstein's home for more sexual activity? 
17 
MR. 
: Objection to the form. It 
18 
MR. 
: Same objection previously 18 
assumes multiple facts. It's therefore 
19 
stated, and standing objection, and instruct 
19 
compound. Instruct the witness not to answer. 
20 
the witness not to answer and objection to 
20 
THE WITNESS: On the advice of counsel, I 
21 
form. 
21 
must invoke my Fifth Amendment right. 
22 
THE WITNESS: On the instruction of my 
22 
BY MR. HOROWITZ: 
23 
lawyer, I must invoke my Fifth Amendment right. 
23 
Q. In 2004 did you receive a phone call from 
24 
BY MR. HOROWITZ: 
24 
a girl named M. wherein she stated she was 
25 
Q. Ms.= 
you have asserted a Fifth 
25 
bringing Jane Doe No. 6 to Jeffrey Epstein, home 
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1 
2 
for a massa e? 
MR. 
Objection to the form. 
1 
2 
THE WITNESS: On the instruction of my 
lawyer, I must invoke my Fifth Amendment right. 
3 
Instruct the witness not to answer. 
3 
BY MR. HOROWITZ: 
4 
THE WITNESS: On the advice of counsel, I 
4 
Q. Did Jeffrey Epstein observe you speaking 
5 
must invoke my Fifth Amendment right. 
5 
with.. by telephone to arrange for Jane Doe No. 
6 
BY MR. HOROWITZ: 
6 
to come to his home for a massage? 
7 
Q. Did Jeffrey Epstein instruct
 ou to 
7 
MR. 
Objection to the for
8 
communicate by telephone with M. for the purpose 
8 
standing objection and otherwise compound 
9 
of under -- arranging for underage minor girls to 
9 
instruct the witness not to answer. 
10 
come to his home for a massage? 
10 
THE WITNESS: On the instruction of my 
11 
MR. 
: Objection to the form. 
11 
lawyer, I must invoke my Fifth Amendment right. 
12 
It's a compound question. Instruct the witness 
12 
BY MR. HOROWITZ: 
13 
not to answer. 
13 
Q. Did Jeffrey E stein confirm with you that 
14 
THE WITNESS: On the advice of counsel, I 
14 
you had spoken with M. by telephone to confirm a 
15 
must invoke my Fifth Amendment right. 
15 
specific time that Jane Doe No. 6 would be at his 
16 
BY MR. HOROWITZ: 
16 
home? 
17 
Q. Did you, in fact, communicate by telephone 
17 
MR. 
Objection to the form, 
18 
with M. for the purpose of arranging for underage 
18 
standing objection. Instruct the witness not 
19 
minor girls to come to Jeffrey Epstein's home to 
19 
to answer. 
20 
give him a masse e? 
20 
THE WITNESS: On the instruction of my 
21 
MR. 
Same objection stated to 
21 
lawyer, I choose to invoke my Fifth Amendment 
22 
the previous question. Same instruction to the 
22 
right. 
23 
witness. 
23 
BY MR. HOROWITZ: 
24 
THE WITNESS: On the instruction of my 
24 
Q. Did Jeffrey Epstein tell you that it was 
25 
lawyer, I must invoke my Fifth Amendment right. 25 
his intention during the course of Jane Doe No. 6's 
Page 248 
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1 
BY MR. HOROWITZ: 
1 
visit to his home to persuade her to engage in 
2 
Q. In 2004 did JefLrey Epstein instruct you 
2 
sexual activi 
with him? 
3 
to communicate with M. by telephone to arrange for 
3 
MR. 
: Objection to the form, 
4 
Jane Doe No. 6 to give him, to give him a massage 
4 
standing objection. Instruct the witness not 
5 
6 
for his own sexual ratification? 
MR. 
: Objection to the form for 
5 
6 
to answer. 
THE WITNESS: At the instruction of my 
7 
the same reasons stated to the previous 
7 
lawyer, I must choose to invoke my Fifth 
8 
questions and instruct the witness not to 
8 
Amendment right. 
9 
answer. 
9 
BY MR. HOROWITZ: 
10 
THE WITNESS: On the instruction of my 
10 
Q. Did Jeffrey Epstein tell you that during 
11 
lawyer I must invoke my Fifth Amendment right. 
11 
the course of Jane Doe No. 6's visit to his home he 
12 
12 
succeeded in persuading her to engage in sexual 
BY MR. HOROWITZ: 
13 
Q. Did you, in fact, communicate with M. by 
13 
activity with him? 
14 
telephone to arrange for Jane Doe No. 6 to come to 
14 
MR. 
: Same objection as stated 
15 
Jeffrey Epstein's home for his sexual gratification? 
15 
to the previous question to form. Instruct the 
16 
MR. 
: Objection to the form. 
16 
witness not to answer. 
17 
Instruct the witness not to answer. 
17 
THE WITNESS: On the instruction of my 
18 
THE WITNESS: On the instruction of my 
18 
lawyer, I must invoke my Fifth Amendment right. 
19 
lawyer, I must invoke my Fifth Amendment right. 
19 
BY MR. HOROWITZ: 
20 
20 
Q. Did Jeffrey Epstein instruct you to take 
BY MR. HOROWITZ: 
21 
Q. Did Jeffrey Epstein inform you that the 
21 
Jane Doe No. 6's name and telephone number to call 
22 
massage Jane Doe No. 6 was to give him would be 
22 
her to come to his home for more sexual activity 
23 
sexual in nature? 
23 
with him? 
24 
MR. 
: Objection to the form. 
24 
MR. 
: Objection to the form. 
25 
Instruct the witness not to answer. 
25 
Instruct the %tiness not to answer. 
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1 
THE WITNESS: On the instruction of my 
1 
MR. 
Instruct the witness not 
2 
lawyer, I must invoke my Fifth Amendment right. 
2 
to answer the question for the legal reasons I 
3 
BY MR. HOROWITZ: 
3 
previously stated. Also the Fifth Amendment is 
4 
Q. Did you, in fact, take Jane Doe No. 6's 
4 
designed to protect both the innocent and the 
5 
name and telephone number down so that you could 
5 
guilty, and I would just assert the same things 
6 
call her to come to Jeffrey Epstein's home for more 
6 
I previously said, that until a judge rules on 
7 
sexual activit ? 
7 
the propriety of the questions, there should be 
8 
MR. 
Objection to form. 
8 
no negative inference drawn from the answer. 
9 
Instruct the witness not to answer. 
9 
BY MR. HOROWITZ: 
10 
THE WITNESS: At the instruction of my 
10 
Q. Ms. M
 are, are you asserting your 
11 
lawyer, I must invoke my Fifth Amendment right. 11 
Fifth Amendment privilege today because you're an 
12 
BY MR. HOROWITZ: 
12 
innocent person, or to conceal your criminal 
13 
Q. Did Jeffrey Epstein instruct you to put 
13 
activity? 
14 
Jane Doe No. 6's name and telephone number into a 
14 
MR. 
: I am going to instruct her 
15 
master journal or log in which he archived the names 15 
not to answer that question. That's not a 
16 
and contact information of teenage girls with whom 
16 
proper question. She could invoke the Fifth 
17 
18 
he had sexual activit ? 
MR. 
Objection to the form. 
17 
18 
Amendment for any reason. She doesn't have to 
explain why. If a judge wants to ask her that. 
19 
Instruct the witness not to answer. 
19 
she'll tell the judge. 
20 
THE WITNESS: On the instruction of my 
20 
If you're going to move to, if you're 
21 
lawyer, I must invoke my Fifth Amendment right. 21 
going to move to another person, could we maybe 
22 
BY MR. HOROWITZ: 
22 
take a five-minute break? 
23 
Q. Did you, in fact, put Jane Doe No. 6's 
23 
MR. HOROWITZ. Sure. 
24 
name and telephone number into a master journal or 
24 
MR. 
-- before the next person, 
25 
log in which you and Jeffrey Epstein archived the 
25 
if you're done --
Page 252 
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1 
names and contact information of teenage girls who 
1 
MR. HOROWITZ: We've got lots more girls. 
2 
would had sexual activi with Jeffrey Epstein? 
2 
MR. 
: Okay. That's fine. But 
3 
MR. 
Objection to the form. 
3 
now a good breaking point? 
4 
Standing objection. It's compound. Instruct 
4 
MR. HOROWITZ: Sure. 
5 
the witness not to answer. 
5 
MR. 
: Thanks. 
6 
THE WITNESS: At the instruction of my 
6 
THE VIDEOGRAPHER: We're now off video 
7 
lawyer, I must invoke my Fifth Amendment right. 
7 
record. The time is 3:14 p.m. 
8 
BY MR. HOROWITZ: 
8 
(A brief recess was held.) 
9 
tir. Did Jeffrey Epstein instruct you to call 
9 
THE VIDEOGRAPHER: We're now on the videc 
10 
M
.
 
on the telephone to arrange for Jane Doe No. 6 
10 
record. The time is 3:24 p.m. 
11 
to come back and give him another massage for his 
11 
MR. HOROWITZ: I've been told I can start 
12 
sexual pleasure? 
12 
my questions without Jack Goldberger in the 
13 
MR. 
Objection to the form, 
13 
room. 
14 
Instruct the witness not to answer. 
14 
MR. 
: Absolutely. 
15 
THE WITNESS: At the instruction of my 
15 
BY MR. HOROWITZ: 
16 
lawyer, I must invoke my Fifth Amendment right. 16 
Q. Ms. =, 
did you know a. did you know a 
17 
BY MR. HOROWITZ: 
17 
girl named Jane Doe No. 7 when she was still, still 
18 
Q. Ms. 
you have asserted a Fifth 
18 
a child under the age of 18? 
19 
Amendment objection and privilege as to all my 
19 
A. At the instruction of my lawyer I must invoke 
20 
questions about Jane Doe No. 6 and Jeffrey Epstein. 
20 
my Fifth Amendment privilege. 
21 
Is there any reason in your mind why a jury should 
21 
Q. Ms. =, 
did a girl named Jane Doe 
22 
not infer from your assertion of the privilege that, 
22 
No. 7 come to Jeffrey Epstein's Palm Beach home on 
23 
in fact, you and Jeffrey Epstein engaged in criminal 
23 
multiple occasions between 2003 and May of 2005? 
24 
conduct in inducing her to come to his home for his 
24 
MR. 
: Objection to the form. 
25 
sexual pleasure'? 
25 
Instruct. instruct the witness not to answer. 
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THE WITNESS: On the instruction of my 
1 
BY MR. HOROWITZ: 
2 
lawyer, I must invoke my Fifth Amendment 
2 
Q. Sure. At any time prior to May of 2005, 
3 
privilege. 
3 
did Jeffrey Epstein confirm with you that you had 
4 
BY MR. HOROWITZ: 
4 
spoken to Jane Doe No. 7 by telephone and that Faith 
5 
Q. Prior to May of 2005, did ou receive a 
5 
would be coming to his home at a particular time to 
6 
phone call from a girl named 
wherein 
6 
give him a massage? 
7 
she told you she was bringing Jane Doe No. 7 to 
7 
MR. 
: Object to form. 
8 
Jeffrey Epstein's home togive him a massage? 
8 
THE WITNESS: On the instruction of my 
9 
MR_ 
: Objection to the form. 
9 
lawyer, I must invoke my Fifth Amendment 
10 
THE WITNESS: At the instruction of my 
10 
privilege. 
11 
lawyer, I must invoke my Fifth Amendment 
11 
BY MR. HOROWITZ: 
12 
privilege. 
12 
Q. And did you, in fact, speak to Jane Doe 
13 
MR. 
: We're trying to speed 
13 
No. 7 by telephone and confirm that Jane Doe No. 7 
14 
things along here. 
14 
would be coming to Jeffrey Epstein's home at a 
15 
MR HOROWITZ: Fine. 
15 
particular time to ive him a massage? 
16 
BY MR. HOROWITZ: 
16 
MR. 
: Object to the form. 
17 
Q. At any time prior to 2005, did 
17 
THE WITNESS: On the instruction of my 
18 
Jeffrey E stein instruct you to communicate with 
18 
lawyer, I must invoke my Fifth Amendment
19 
by telephone to arrange for Jane Doe 19 
privilege. 
20 
No. 7 to give him a massage? 
20 
BY MR. HOROWITZ: 
21 
MR. 
: Objection to the form. 
21 
Q. Did Jeffrey Epstein tell you it was his 
22 
THE WITNESS: At the instruction of my 
22 
intention during the course of Jane Doe No. 7's 
23 
lawyer, I must invoke my Fifth Amendment 
23 
visits to his home to persuade or entice her to 
24 
25 
privilege. 
24 
25 
engage in sexual activit ? 
MR. 
: Object to form. 
Page 256 
Page 258 
1 
BY MR. HOROWITZ: 
1 
THE WITNESS: At the instruction of my 
2 
Q. Did Jeffrey Epstein inform you that the 
2 
lawyer I must invoke my Fifth Amendment 
3 
massage Jane Doe No. 7 was to give him would be 
3 
privilege. 
4 
sexual in nature? 
4 
BY MR. HOROWITZ: 
5 
MR. 
: Objection to the form. 
5 
Q. Did Jeffrey Epstein ever tell you that 
6 
THE WITNESS: At the instruction of my 
6 
during the course of Jane Doe No. 7's visits to his 
7 
lawyer, I must invoke my Fifth Amendment 
7 
home that he succeeded in persuading her or enticing 
8 
9 
privilege. 
BY MR. HOROWITZ: 
8 
9 
her to engage in sexual activity? 
MR. 
Object to form. 
10 
Q. Did Jeffrey Epstein observe you speaking 
10 
THE WITNESS: At the instruction of my 
11 
with 
by telephone to arrange for Jane 
11 
lawyer I must invoke my Fifth Amendment
12 
Doe No. 7 to come to his home to give him a massage 12 
privilege. 
13 
that was sexual in nature? 
13 
BY MR. HOROWITZ: 
14 
MR. 
: Objection to the form. 
14 
Q. Ms. 
. did you ask Jane Doe No. 7 how 
15 
THE WITNESS: At the instruction of my 
15 
old she was when she came to Jeffrey Epstein's home: 
16 
lawyer, I must invoke my Fifth Amendment 
16 
MR. 
Objection to form. 
17 
privilege. 
17 
THE WITNESS: At the instruction of my 
18 
BY MR. HOROWITZ: 
18 
lawyer, I must invoke my Fifth Amendment 
19 
Q. At any time prior to May of 2005, did 
19 
privilege. 
20 
Jeffrey Epstein confirm with you that she (sic) had 
20 
BY MR. HOROWITZ: 
21 
spoken to Jane Doe No. 7 by telephone and that Jane 
21 
Q. And Jane Doe No. 7 never told you that she 
22 
Doe No. 7 would be coming to his home to give him a 22 
was IS or older: is that correct? 
23 
massage? 
23 
MR. 
Objection to form. 
24 
MR. 
: I'm sony. Can you 
24 
THE WITNESS: On the instruction of my 
25 
restate your question. Mr. Horowitz? 
25 
lawyer. I must invoke my Filth Amendment 
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1 
privilege. 
1 
MR. 
Object to form. 
2 
BY MR. HOROWITZ: 
2 
THE WITNESS: At the instruction of my 
3 
Q. And when Jane Doe No. 7 came to Jeffrey 
3 
lawyer I must invoke my Fifth Amendment 
4 
Epstein's home, she appeared to you to look younger 
4 
privilege. 
5 
than I8, correct? 
5 
BY MR. HOROWITZ: 
6 
MR. 
: Object to form. 
6 
Q. Did Jeffrey Epstein instruct you to call 
7 
THE WITNESS: At the instruction of my 
7 
Jane Doe No. 7 to tell her to lie to police officers 
8 
lawyer I must invoke my Fifth Amendment 
8 
investigatin his criminal activity? 
9 
privilege. 
9 
MR. 
: Object to form. 
10 
BY MR. HOROWITZ: 
10 
THE WITNESS: On the instruction of my 
11 
Q. Did Jane Doe No. 7 tell ou that she was a 
11 
lawyer, I must invoke my Fifth Amendment 
12 
student at 
12 
privilege. 
13 
MR. 
: Object to form. 
13 
BY MR. HOROWITZ: 
14 
THE WITNESS: At the instruction of my 
14 
Q. Did you, in fact, call Jane Doe No. 7 to 
15 
lawyer, I must invoke my Fifth Amendment 
15 
tell her to lie to police officers investigating 
16 
privilege. 
16 
Jeffrey Epstein's criminal activity? 
17 
BY MR. HOROWITZ: 
17 
MR. 
: Object to form. 
18 
Q. Did Jeffrey Epstein instruct you to take 
18 
THE WITNESS: At the instruction of my 
19 
Jane Doe No. 7's name and telephone number down so 19 
lawyer, I must invoke my Fifth Amendment 
20 
you can call Jane Doe No. 7 to come to his home for 
20 
privilege. 
21 
more sexual activi ? 
21 
BY MR. HOROWITZ: 
22 
MR. 
: Object to form. 
22 
Q. Okay. You've asserted a Fifth Amendment 
23 
THE WITNESS: On the instruction of my 
23 
objection or privilege as to all of my questions 
24 
lawyer, I must invoke my Fifth Amendment 
24 
concerning Jane Doe No. 7 and her visits to Jeffrey 
25 
privilege. 
25 
Epstein. Is there any reason that you can think of 
Page 260 
Page 262 
1 
BY MR. HOROWITZ: 
1 
that a jury should not infer that you are asserting 
2 
Q. Did you, in fact, take Jane Doe No. 7's 
2 
the Fifth Amendment privilege to conceal the 
3 
name and telephone number down so you could call 
3 
criminal activi of ourself and Jeffrey Epstein?
4 
Jane Doe No. 7 to come to Jeffrey Epstein's home for 
4 
MR. 
As previously done. I will 
5 
6 
other sexual activi ? 
MR. 
Object to form. 
5 
6 
instruct the witness not to answer that 
question. I believe it calls for a legal 
7 
THE WITNESS: On the instruction of my 
7 
conclusion. It's also not designed to lead to 
8 
lawyer, I must invoke my Fifth Amendment 
8 
discoverable evidence, and whether or not any 
9 
privilege. 
9 
inference should be drawn will be an issue for 
10 
BY MR. HOROWITZ: 
10 
the jury after the judge rules on the 
11 
Q. Did Jeffrey Epstein instruct you to put 
11 
objections to the questions. 
12 
Jane Doe No. 7's name and telephone number into a 
12 
MR. HOROWITZ: So, did you say you were --
13 
master journal or log in which you and he archived 
13 
MR. 
I'm instructing her not to 
14 
the names of, and telephone numbers of teenage girls 14 
answer. 
15 
with whom he wanted to engage in sexual activity? 
15 
MR. HOROWITZ: Thank you. 
16 
MR. 
Object to form. 
16 
BY MR. HOROWITZ: 
17 
THE WITNESS: At the instruction of my 
17 
Q. Ms. 
did you know a girl named Jane 
18 
lawyer, I must invoke my Fifth Amendment 
18 
Doe No. S when she was still a child under the age 
19 
privilege. 
19 
of 18? 
20 
BY MR. HOROWITZ: 
20 
A. Upon the instruction of my lawyer, I must 
21 
Q. Did you, in fact, put Jane Doe No. 7's 
21 
invoke my Fifth Amendment right. 
22 
name and telephone number into a master journal or 
22 
Q. Ms. IM, 
isn't it true that a girl 
23 
log in which you archived the names of teenage girls 
23 
named Jane Doe No. 8 came to Jeffrey Epstein's Palm 
24 
with whom Jeffrey Epstein did engage in sexual 
24 
Beach home in approximately 2001 or 2002 when she 
25 
activity? 
25 
was still a child under the age of IR? 
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1 
Page 263 
MR. 
Object to form. 
1 
Page 265 
BY MR. HOROWITZ: 
2 
THE WITNESS: On the instruction of my 
2 
Q. Did you tell Jeffrey Epstein that you had 
3 
lawyer, I must invoke my Fifth Amendment right. 
3 
confirmed by telephone that Jane Doe No. 8 would, in 
4 
BY MR. HOROWITZ: 
4 
fact, be coming to his home at a particular time to 
5 
Q. Ms. 
did ou receive a phone call 
5 
give him a massa e? 
6 
from a girl named 
that she was 
6 
MR. 
Object to form. 
7 
bringing Jane Doe No. 8 to Jeffrey Epstein's home 
7 
THE WITNESS: On the instruction of my 
8 
for the purpose of ivin him a massage? 
8 
lawyer, I must invoke my Fifth Amendment right. 
9 
MR. 
Object to form. 
9 
BY MR. HOROWITZ: 
10 
THE WITNESS: On the instruction of my 
10 
Q. Did Jeffrey Epstein tell you that it was 
11 
lawyer, I must invoke my Fifth Amendment right. 11 
his intention that, during the course of Jane Doe 
12 
BY MR. HOROWITZ: 
12 
No. 8's visit to his home, that he would persuade or 
13 
Q. Did Jeffrey Epstein instruct ou to 
13 
induce her to en a e in sexual activity with him? 
14 
communicate by telephone with 
to 14 
MR. 
Object to form. 
15 
arrange for Carolyn to bring underage girls to his 
15 
THE WITNESS: Upon the instruction of my 
16 
home for sexual activi ? 
16 
lawyer, I must invoke my Fifth Amendment right. 
17 
MR. 
Object to form. 
17 
BY MR. HOROWITZ: 
18 
THE WITNESS: On the instruction of my 
18 
Q. Did Jeffrey Epstein tell you that, in 
19 
lawyer, I must invoke my Fifth Amendment right. 19 
fact, during the course of Jane Doe No. S's visit to 
20 
BY MR. HOROWITZ: 
20 
his home, he succeeded in persuading or inducing her 
21 
Q. Did Jeffrey Epstein pay 
21 
to engage in sexual activity? 
22 
to bring underage girls to his home for sexual 
22 
MR. 
Object to the form. 
23 
activity? 
23 
THE WITNESS: Upon instruction of my 
24 
MR. 
Object to form. 
24 
lawyer, I must invoke my Fifth Amendment 
25 
THE WITNESS: On the instruction of my 
25 
privilege. 
Page 264 
Page 266 
1 
lawyer. I must invoke my Fifth Amendment right. 
1 
BY MR. HOROWITZ: 
2 
2 
Q. Jane Doe No. 8 never told you that she was 
BY MR. HOROWITZ: 
3 
Q. Did Jeffrey E stein instruct ou to 
3 
18 years old or older: is that correct? 
4 
communicate with 
by telephone to 
4 
MR. 
: Object to form. 
5 
arrange for Jane Doe No. 8 to give him a massage 
5 
THE WITNESS: Upon the instruction of my 
6 
that was to be sexual in nature? 
6 
lawyer, I must invoke my Fifth Amendment right. 
7 
MR. 
Object to form. 
7 
BY MR. HOROWITZ: 
8 
THE WITNESS: On the instruction of my 
8 
Q. And when you saw Jane Doe No. 8, she 
9 
lawyer. I must invoke my Fifth Amendment right. 
9 
appeared to ou to be less than 18; is that correct? 
10 
10 
MR. 
: Object to the form. 
BY MR. HOROWITZ: 
11 
Q. Did Jeffrey Epstein inform you that the 
11 
THE WITNESS: On the instruction of my 
12 
massage that Jane Doe No. 8 was to give him would be 12 
lawyer, I must invoke my Fifth Amendment right. 
13 
sexual in nature? 
13 
BY MR. HOROWITZ: 
14 
MR. 
Object to form. 
14 
. Did Jeffrey Epstein instruct you to call 
15 
THE WITNESS: On the instruction of my 
15 
on the telephone to arrange for 
16 
lawyer. I must invoke my Fifth Amendment right. 
16 
Jane Doe No. 8 to come back and give him another 
17 
BY MR. HOROWITZ: 
17 
massage that was to be sexual in nature? 
18 
Q. Did Jeffrey E stein observe you speaking 
18 
MR. 
: Objection to the form. 
19 
with 
by telephone making 
19 
THE WITNESS: On the instruction of my 
20 
arrangements for Jane Doe No. 8 to come to his home 
20 
lawyer, I must invoke my Fifth Amendment right. 
21 
to give him a massy e? 
21 
BY MR. HOROWITZ: 
22 
MR. 
Object to form. 
22 
Q. Ms. =, 
you have asserted a Fifth 
23 
THE WITNESS: On the instruction of my 
23 
Amendment objection or privilege as to all of my 
24 
lawyer. I must invoke my Fifth Amendment right. 
24 
questions about Jane Doe No. 8. Is there any reason 
25 
25 
in your mind why jury should not infer that. in 
20 (Pages 263 to 266) 
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