EFTA01246832

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON 
JANE DOE, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, et al., 
Defendants. 
/ 
Related Cases: 
08-80119, 08-80232, 08-80380, 08-80381, 
08-80994, 08-80811, 08-80893, 09-80469, 
09-8-591, 09-80656, 09-80802, 09-81092 
VIDEOTAPED DEPOSITION OF 
TAKEN ON BEHALF OF THE PLAINTIFF 
DATE: April 13, 2010 
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April 13,2010 
INDEX 
WITNESS 
DIRECT CROSS REDIRECT RECROSS 
BY MR. EDWARDS 
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BY MR. HOROWITZ 
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BY MR. LANGINO 
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BY MS. EZELL 
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EXHIBITS 
PLAINTIFF'S 
FOR IDENTIFICATION 
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Message dated August 21, 2005. 
PAGE 
45 
APPEARANCES (CONTINUED) 
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LEOPOLD-KUVIN 
wilwiIfs 
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BY: ADAM J. LANGINO, ESQ. 
PODIRMST, ORSECK 
AllOmtp (calm Does I sad 3 
Hu& Building. Suite )38 
BY: KATHERINE W. EZELL, ESQ. 
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BURMAN. CROTON. LUTTIER & COLEMAN, III' 
pstein 
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BY: DAVID YAREMA, ESQ. 
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ROBERT CRITION. ESQ. 
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ATTERBURY, GOLDBERGER & WEISS 
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I for Defendants 
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BY: JACK A. GOLDBERGER. ESQ. 
ALSO PRESENT: 
JESSICA CADWEU. 
JOE ROVNER. Yid:n(40W 
(US. Legal) 
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i 
m
i. 
to
 deposition of 
in the above-entitled and numbered 
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cause, was taken before me, TERRI BECKER, a 
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Registered Professional Reporter and Notary 
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Public for the State of Florida at Large, at 444 
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West Railroad Avenue, in the City of West Palm 
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Beach. Palm Beach County, in the State of 
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Florida, beginning at the hour of 10:00 o'clock 
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a.m., pursuant to the Notice in said cause far 
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the taking of said deposition which is annexed to 
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the court file herein, on behalf of the PLAINTIFF 
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in the above-entitled action pending in the 
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above-named coon. 
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The appearances at said lime and place 
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were as follows: 
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FARMER, JAFFE, WEISSING, EDWARDS, 
FISTOS & LEHRMAN, PL 
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legs 
Plaintiffs Jane Does, 
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BY: BRADLEY J. EDWARDS, ESQ. 
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MERMELSTEIN & HOROWITZ P.A. 
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Attorneys for Plaintiffs Jane Does, 
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BY: ADAM D. HOROWITZ. ESQ. 
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THEREUPON. 
being by Terri Becker first duly sworn to tell 
the whole truth, as hereinafter certified, 
testified as follows: 
DIRECT EXAMINATION 
BY MR. EDWARDS: 
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Q Can you tell us your name. 
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A 
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Q What Is your dale of birth? 
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Q What Is your Social Security number? 
A Under advice of my counsel, 1 invoke my 
privileges under the Fifth and Sixth Amendments 
to the United States Constitution and 
respectfully decline to answer the question. 
Q Where were you born? 
A I'm sorry, though I would like to answer 
your question, l must invoke my Fifth and Sixth 
Amendment privileges and refuse to answer your 
questions. 
Q What is your current address? 
MR. GOLDBERGER: There is going to be a 
continued, obviously, you anticipate I'm 
sure, continued invocation of Fifth 
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Amendment privileges. If it is okay with 
all counsel, to shorten things, I'll simply 
have the witness say -Filth,. if that 
satisfies everyone's interest. 
MR. EDWARDS: That is fine with me. 
MR. GOLDBERGER: Okay, with that Cathy? 
MS. EZELL: Yes. 
MR. HOROWITZ: Yes. 
Q I'll reask the question, what's your 
current address? 
A Fifth. 
Q Are you currently living at 358 El 
SHIM Way with a man named Jeffrey Epstein? 
A The Fifth. 
Q Are you also familiar with an address in 
New York, 301 East 66th Street? 
A The Fifth. 
Q When Mr. Epstein was incarcerated In 
Jail, you went to visit him on numerous 
occasions; is that correct? 
MR. YAREMA: Objection. 
A The Fifth. 
Q When you went to visit him you indicated 
to jail personnel your address was 301 East 66th 
Street, apartment 8-D in New York City, New York; 
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A The Fifth. 
Q Do you know a lady by the name of 
Maritsa Vazques? 
A The Fifth. 
Q Is this somebody who helped to falsify a 
visa for you? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q Do you know Evelyn Velasaques? 
A The Fifth. 
Q Were you ever a working model hat ilw 
United States? 
A The Fifth. 
Q Can you tell us youi parents' names? 
A The Fifth. 
Q How is it that you have supported 
yourself financially, since you have been in this 
country? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q Have you supported yourself financially? 
A The Fifth. 
Q What Is the last grade you completed in 
school? 
A The Fifth, I take the Fifth Amendment. 
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Is that correct? 
MR. YAREMA: Objection. 
A Fifth. 
Q Isn't it true when Mr. Epstein was in 
jail, you visited him on more than 50 occasions? 
MR. YAREMA: Form objection. 
Q True? 
A The Fifth. 
Q How long have you been in the United 
States, 
A The Fifth. 
Q Who brought you to the United States? 
MR. YAREMA: Form objection. 
A The Fifth. 
Q What is your current status in this 
country? 
A The Fifth. 
MR. YAREMA: Form objection. 
MR. GOLDBERGER: Let me take a half a 
second. 
(Witness and her counsel confer.) 
Q Are you a U.S. citizen? 
A The Filth. 
Q What type of visa are you here on? 
MR. YAREMA: Form objection. 
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Q Are you in school now? 
A The Fifth. 
Q Have you ever attended any school in the 
United States? 
A The Fifth. 
Q Have you ever been employed since 
residing in the United States? 
A The Fifth. 
Q Is Jeffrey Epstein your sole means of 
financial support today? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q Since coming to this country, hasn't 
Jeffrey Epstein always been your sole means of 
financial support? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q How much does Jeffrey Epstein pay you 
today? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q What does every Epstein pay you for? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q Does he pay you specifically to be his 
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sex slave? 
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MR. YAREMA: Object to the form. 
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A The Fifth. 
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Q Are you aware that the reports about you 
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Indicate that you were brought to the United 
States by Jeffrey Epstein when you were roughly 
13 or 14 years old to be his 
lesbian 
sex slave? 
MR. YAREMA: Object to the form. 
A Thc Fifth. 
Q Is that true? 
MR, YAREMA: Object to the lomt 
A The Fifth. 
Q Have you performed any services for 
Jeffrey Epstein aside front being his sex slave? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q What is your sexual orientation? 
MR. YAREMA: Object to the Iona. 
MR. GOLDBERGER: I'm going to instruct 
the witness not to answer that question. It 
serves no purpose other than to harass or 
intimidate her, so in addition to Fifth 
Amendment privileges, I'm objecting on 
privacy grounds. 
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Epstein's sex slaves? 
MR. YAREMA: Object to the Ism 
A Fifth. 
Q What does it mean to be JelTrey 
Epstein's sex slave? 
MR. YAREMA: Object to the font. 
A Fifth. 
Q Are you aware that Jeffrey Epstein reads 
books on how to be a proper master to his sex 
slave? 
MR. YAREMA: Object to the Iona. 
A Fifth. 
Q What has Jeffrey Epstein done to train 
you to be his sex slave? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q What do your parents think about you 
being Jeffrey Epstein's sex slave? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q When did you first learn that Jeffrey 
Epstein had a sexual obsession for underage minor 
females? 
MR. YAREMA: Object to the form. 
A Fifth. 
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A I take the Fifth. 
Q I represent a lady named, a young female 
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named 
S
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you know who that is, right? 
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MIL YAREMA: Object to the form. 
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A The Fifth. 
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Q Jeffrey Epstein made you have sex with 
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 didn't he? 
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MR: YAREMA: Object to the form. 
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A The Fifth. 
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Q You did, In fact, engage in sexual 
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activity with M. when she was only 16 years 
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old; isn't that true? 
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MR. YAREMA: Object to the form. 
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A The Fifth. 
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Q Back to my original question: And I'll 
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ask you this way: Do you consider yourself 
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heterosexual, bl-sexual, or can you answer that 
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question? 
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MR. YAREMA: Object to the form. 
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MR. GOLDBERGER: Same objection. Do not 
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answer the question. 
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A Fifth. 
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Q How did you meet Jeffrey Epstein? 
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A Fifth. 
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Q When did you become one of Jeffrey 
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Q How many times has Jeffrey Epstein made 
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you have sex with underage minor females? 
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MR. YAREMA: Object to the Porn. 
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A Filth. 
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Q Do you enjoy sex with underage minor 
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females? 
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MR. YAREMA: Object to the fort. 
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A Fifth. 
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Q What is the youngest child that Jeffrey 
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Epstein has forced you to have sex with? 
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MR. YAREMA: Object to the fonts. 
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A Fifth. 
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Q Does Jeffrey Epstein today still make 
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you have sex with underage minor females? 
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MR. YAREMA: Object to the form. 
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A Fifth. 
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Q How many underage minor females has 
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Jeffrey Epstein made you have sex with, since you 
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were over the age of 18? 
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MR. YAREMA: Object to the fonn. 
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A Thc Fifth. 
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Q Prior to turning 18, is it true that 
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Jeffrey Epstein made you have sex with many other 
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children in kid-type orgies? 
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MR. YAREMA: Object to the fonn. 
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A Filth. 
Q Has Jeffrey Epstein also made you 
perform sexually on his friends? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you know David Copperfield? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Have you ever been made to perform 
sexually on David Copperfieki? 
MR. YAIIEMA: Object to the form. 
A Fifth. 
Q Do you know Prince Andrew? 
A Fifth. 
Q Have you ever been made to perform 
sexually on Prince Andrew? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q When was the first time that you knew 
Jeffrey Epstein molested underage girls? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein molest you when you 
were underage? 
MR. YAREMA: Object to the form. 
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A Fifth. 
Q Have you read the nonprosecution 
agreement between the government and Jeffrey 
Epstein? 
A Fifth. 
Q Are you aware that inside that document 
you are labeled as a co-conspirator of his crimes 
against children? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Isn't it true that your role was to lure 
or procure underage minor females to Jeffrey 
Epstein for him to molest, correct? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q You also scheduled appointments for 
Jeffrey Epstein, so there would be designated 
times for Jeffrey Epstein to molest underage 
minor females, correct? 
MR. YAREMA: Object to the fonn. 
A The Fifth. 
Q As well, you participated in various sex 
acts with underage minor females, thus molesting 
them yourself; is that correct? 
MR. YAREMA: Object to the font 
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A Fifth. 
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Q I'm assuming you understand why you're 
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here today, correct? 
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MR. YAREMA: Object to the fonn. 
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A The Fifth. 
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Q For allegations related to Jeffrey 
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Epstein interacting sexually with numerous 
underage minor females; that's something you 
know, right? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q That's something In addition to the 
civil lawsuits, there were criminal cases 
involving the same conduct, correct? 
MR. YAREMA: Object to the feta 
A Fifth. 
Q You were a part of that CaMillai 
Investigation, in fact, you were a co-conspirator 
of Jeffrey Epstein's; is that right? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q What crimes did you conspire to commit 
with Jeffrey Epstein against underage minor 
females? 
MR. YAREMA: Object to the tom. 
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A Fifth. 
Q Do you understand that Jeffrey Epstein's 
interaction with underage minor females is 
Illegal? Do you understand that? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q Do you understand that the Lewd and 
Lascivious Molestation Statute In Florida 
indicates a person who Intentionally touches in a 
lewd or lascivious manner, the breasts, genital 
area or buttocks, or the clothing covering them, 
of a person less than 16 years of age, or forces 
or entices a person under 16 years of age, to so 
touch the perpetrator, commits lewd or lascivious 
molestation? Are you aware of that statute? 
A Fifth. 
Q That is a statute that you know Jeffrey 
Epstein to have violated; Is that true? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q That's a statute that you yourself have 
violated; is that true? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q You've observed Jeffrey Epstein violate 
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that statute on many underage minor females, 
true? 
MR. YAREMA: Object to the font 
A The Filth. 
Q (lave you ever discussed with Jeffrey 
Epstein that the fact that he is a child 
molester? 
MR. YAREMA: Object to the form. 
A Filth. 
Q Have you asked Jeffrey Epstein why he 
has made you interact with underage minor females 
in a sexual manner? 
MR. YAREMA: Object to the fon% 
A Filth. 
Q During the litigation of these civil 
cases, has Jeffrey Epstein indicated to you an 
intent to continue to molest children? 
MR. YAREMA: Object to the loon. 
A Fifth. 
Q Is it your intent to continue to commit 
sex crimes against minors? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q In addition to your being named as a 
co-conspirator of Jeffrey Epstein regarding his 
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co-conspirator in the non-prosecution agreement 
related to Jeffrey Epstein's crimes against 
minors? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you know 
or 
A Fifth. 
Q These are all people who also 
participated in Jeffrey Epstein's scheme to lure 
underage females to him for sex; is that true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q You and these other co-conspirators 
played various roles to make sure Jeffrey Epstein 
was able to engage In sexual contact or conduct, 
with underage minor females on an everyday basis; 
is that true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Since the time you first met Jeffrey 
Epstein, has his appetite for underage minor 
females always been the same? 
MR. YAREMA: Object to the form. 
A Fifth. 
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crimes against minors, there is also a person 
named 
listed as a co-conspirator. 
Do you know 
A Fifth. 
Q This Is somebody who lives with you and 
Jeffrey Epstein; Is that true? 
MR. YAREMA: Object to the four. 
A Filth. 
Q And 
is somebody who you 
know to be 
girlfriend; is that 
true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q She's spoken with 
about 
this case on numerous occasions; is that true? 
MR. YAREMA: Object to the form. 
A Fifth. 
conversations with= 
and your observations of them, you believe 
would implicate you in a crime and that's why 
you're able to take the Fifth as to that 
question? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Who is Lesley Groff, also listed as a 
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Q By that I mean, have you observed 
Jeffrey Epstein to interact sexually with 
underage minor females literally on a doily 
basis? 
MR. YAREMA: Object to the form 
A Fifth. 
Q Wasn't it one of your specific job 
duties to make sure that he had different 
underage minor females to molest on a daily 
basis? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q In addition to the improper sexual 
contact between Jeffrey Epstein and underage 
minor females at the West Palm Beach house, you 
have observed similar improper and illegal 
contact by Jeffrey Epstein in his New York 
mansion, as well, correct? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q In fact, he operates a very similar 
scheme up there, in that he schedules these 
appointments with underage minor females, under 
the guise that it is going to be a massage; is 
that correct? 
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MR. YAREMA: Object to the loon? 
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A Fifth. 
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Q When he is in New York, he has contact 
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with underage minor females for the purposes of 
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sexually molesting than as well; is that 
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correct? 
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MR. YAREMA: Object to the fonn. 
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A Fifth. 
Q When he is in his ranch in New Mexico, 
similarly, Jeffrey Epstein is engaging in sex 
with underage minor females from that local area 
as well, and that's something you've observed? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q On his island, particularly, he has 
flown underage minor females to the island for 
underage kid-type orgies; is that true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q You're shaking your head indicating, at 
least to me, indicating that you may not agree 
with what I'm saying, and I would love to give 
you the chance to explain it to us. 
MR. GOLDBERGER: I appreciate that, but 
don't — 
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when Jeffrey Epstein commits these crimes against 
children? 
MR. YAREMA: Object to the font 
A Fifth. 
Q Is there any way for you to escape being 
his sex slave? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Have you ever wanted to cooperate with 
the authorities, so that you could escape being 
his sex slave? 
MR. YAREMA: Object to the fonn 
A Fifth. 
Q Do you represent to others that you are 
his girlfriend or his sex slave, or sonic other 
designation? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Isn't it true that you recently 
represented to the Probation Officer that you 
were his live-In girlfriend? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q When Probation calls the house, are you 
told to tell Probation that he is in the swimming 
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MR. EDWARDS: Read too much into it? 
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MR. GOLDBERGER: Exactly. Don't go 
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there. Just ask the questions and we will 
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move right along. 
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MR. EDWARDS: I agree, Jack, I just know 
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if this is played for a jury, I don't want 
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the jury to interpret her shaking ha head 
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as a "No." and then her pleading the Fifth. 
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MR. GOLDBERGER: I appreciate that. 
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Don't take anything as to any head movements 
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or any body movements at all. Just ask the 
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questions and we will let the video speak 
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for itself. 
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Q How many of these — you know what an 
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orgy Is, don't you? 
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A Fifth. 
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Q And how many of these orgies, as I'm 
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calling them, where there are numerous underage 
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minors having sex with each other and with 
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Jeffrey Epstein, have you observed on Jeffrey 
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Epstein's island? 
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MR. YAREMA: Object to the form. 
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A Fifth. 
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Q Is part of your role as Jeffrey 
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Epstein's sex stave, to not tell the authorities 
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pool or doing some other activity that would not 
allow him to come to the telephone? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Isn't It true you're under strict orders 
to tell Probation that? 
MR. YAREMA: Object to the fonn. 
A Filth. 
Q Isn't it true you've heard Jeffrey 
Epstein tell you on numerous occasions, regarding 
the age of the girls that he wants to his house, 
for the purposes of sexually molesting, the 
phrase he uses is "the younger the better," 
true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q I asked you earlier about M. out of 
turn as a result of an objection related to your 
sexual orientation, but I'll talk specifically 
about.. right now. You know who that Is, 
right? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q That is somebody you observed Jeffrey 
Epstein to call for the purposes of getting her 
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to his house to sexually molest; Is that right? 
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minor females? 
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MIL YAREMA: Object to the font 
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MR. YAREMA: Object to the form. 
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A Fifth. 
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A Fifth. 
4 
Q The first time she went to Jeffrey 
4 
Q You have received oral sex front underage 
5 
Epstein's house was in 2002 when she was only 14 
5 
minor females? 
6 
years old; Is that true? 
6 
MR. YAREM A: Object to the fonn. 
7 
MR. YAREMA: Object to the font,. 
7 
A Fifth. 
A Fifth. 
8 
Q All of these sexual acts with minor 
9 
Q In fact in 2002 you were only 18 years 
9 
females involving you happened in the presence of 
10 
old or so yourself; is that right? 
10 
Jeffrey Epstein? 
11 
A Fifth. 
11 
MR. YAREM A: Object to the bona. 
12 
Q And M. is somebody you observed at 
12 
A Fifth. 
13 
Jeffrey Epstein's house on more than 100 
13 
Q During your interaction with underage 
14 
occasions between 2002 and 2005, a time period 
14 
minor females in a sexual manner, isn't it true 
15 
between 14 and 17 years of age for her; is that 
15 
that Jeffrey Epstein would participate in the 
16 
right? 
16 
sexual acts and the act would be over upon 
17 
MR. YAREMA: Object to the font,. 
17 
Jeffrey Epstein ejaculating, correct? 
18 
A Fifth. 
18 
MR. YAREMA: Object to the font,. 
19 
Q And each time M. was summoned to 
19 
A Filth. 
20 
Jeffrey Epstein's house, it was for the purposes 
20 
Q Did Jeffrey Epstein tell you, that when 
21 
of Jeffrey Epstein sexually molesting her, 
21 
M. was an underage minor female, he forced her 
22 
correct? 
22 
to give hint oral sex? 
23 
MR. YAREMA: Object to the form. 
23 
MR. YAREMA: Object to the font 
24 
A Fifth. 
24 
A Fifth. 
25 
Q If it was not Jeffrey Epstein personally 
25 
Q Do you remember 
coming over, • 
27 
29 
1 
calling 
., you observed 
to call 
1 
young girl, with braces on, and going up Into 
2 
S 
for the purposes of her coming over and 
2 
Jeffrey Epstein's bedroom on numerous occasions 
3 
pleasing Jeffrey Epstein sexually, correct? 
3 
to be sexually molested? 
4 
MR. YAREMA: Object to the form. 
4 
MR. YAREMA: Object to the tons 
5 
A Fifth. 
5 
A Fifth. 
6 
Q And do you remember the instance where 
6 
Q Do you know when it was that Jeffrey 
7 
Jeffrey Epstein instructed you to lay down naked 
and engage in a threesome with M. and Jeffrey 
7 
Epstein developed his plan or scheme to gain 
access to hundreds of underage minor females for 
9 
Epstein? 
9 
the purposes of his sexual gratification? 
10 
MR. YAREMA: Object to the fonn. 
10 
MR. YAREMA: Object to the font 
11 
A Fifth. 
11 
A Fifth. 
12 
Q Do you remember that that during that 
12 
Q Were you a part of the planning of that 
13 
threesome, Jeffrey Epstein demanded M. to 
3 
scheme of Jeffrey Epstein's to gain access to 
14 
straddle you and otherwise engage sexually with 
4 
underage minor females? 
15 
you while Jeffrey Epstein was using vibrators 
5 
MR. YAREMA: Object to the form 
16 
and/or dildos on you? 
6 
A Fifth. 
17 
MR. YAREMA: Object to the fonts 
7 
Q Do you know Ohislaine Maxwell? 
18 
A Fifth. 
A Fifth. 
19 
Q In addition to your sexual interactions 
9 
Q Is that somebody who helped Jeffrey 
20 
with M., isn't it true that you have used 
0 
Epstein to devise the scheme to allow hint access 
21 
strap-on dildos and vibrators on other underage 
1 
to various and a variety of underage minor 
22 
minors at Jeffrey Epstein's direction? 
2 
females? 
23 
MR. YAREMA: Object to the form. 
3 
MR. YAREMA: Object to the 
24 
A Fifth. 
4 
A Fifth. 
25 
Q You have given oral sex to underage 
5 
Q Is 
somebody that was also 
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Involved In the planning of this scheme to gain 
access to underage minor females? 
MR. YAREMA: Object to the fonn. 
A Filth. 
Q When Is the first time that you observed 
Jeffrey Epstein's method of enticing or inducing 
underage minor females into sexual acts with him 
inside his bedroom? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Isn't it trite that after an underage 
minor female was brought to Jeffrey Epstein's 
house, typically 
or 
or 
yourself would lead that underage minor female to 
Jeffrey Epstein's bedroom and leave them atone do 
the room; is that true? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Then Jeffrey Epstein would appear either 
naked or wearing a towel; is that true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q This Is his habit or method of 
operation, every single time, and that's 
something that he has told you about his sexual 
1 
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sex toys on you, correct? 
A Fifth. 
Q And he has instructed you to use sex 
toys and vibrators on other underage minor 
females, correct? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q You have observed Jeffrey Epstein 
digitally penetrate the vagina of underage minor 
females, Including •., 
correct? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q As pan of his plait to avoid detection 
by law enforcement, you have observed Jeffrey 
Epstein to pay these underage minor females to be 
quiet, correct? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q And this is something that he has told 
you he does, for the purposes of grooming these 
underage minor females, and avoiding law 
enforcement detection, correct? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Jeffrey Epstein has talked to you about 
31 
1 
interaction with underage minors; is that true? 
2 
MR. YAREMA: Object to the form. 
3 
A Fifth. 
4 
Q And he would direct or demand or 
5 
Instruct the underage minor female to remove her 
6 
clothing; is that true? 
7 
MR. YAREMA: Object to the form. 
8 
A Fifth. 
Q Then he would perform one or more lewd 
or lascivious or sexual acts on the underage 
minor female. Is that true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q And you have observed Jeffrey Epstein 
engage in sexual interaction with underage minor 
females on hundreds and hundreds of occasions, 
correct? 
MR. YAREMA: Object to the font 
A Fifth. 
Q And you have observed Jeffrey Epstein 
using vibrators and sexual toys on underage 
minors, true? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q In fact, he has also used vibrators and 
1 
2 
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33 
the psychology of brainwashing or grooming 
underage minor females to perform for him 
sexually, hasn't he? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q And 
has also spoken with 
you about the methodology behind gaining access 
to and grooming underage minor females for sex? 
MR. YAREMA: Object to form. 
A Fifth. 
Q Isn't it true that Ghislaine Maxwell and 
yourself and 
had access to a master 
Ilst of underage minor remain names and phone 
numbers so that they could be called? 
MR. GOLDBERGER: Time out. Are you 
talking to me, counsel? 
MR. HOROWITZ: Nodding my head, back at 
you. You were nodding at me. 
MR. GOLDBERGER: I wasn't nodding at 
you. I'm not talking to you, I'm not 
communicating with you.. I don't know what 
you think we arc doing here. You said "It 
is true," and I have no idea what you are 
talking about. Don't inlet-nn the 
deposition, okay? 
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MIL HOROWITZ: I think you interrupted. 
MR. GOI.DBERGER: I didn't do a thing -- 
MR. EDWARDS: I don't know what's 
happened here. It has deteriorated here for 
no reason whatsoever and has nothing to do 
1 
2 
3 
4 
5 
36 
A Fifth. 
Q In addition to that system, isn't it 
true that Jeffrey Epstein traMcs underage minor 
females through a modeling agency? 
MR. YAREMA: Object to the form. 
6 
with mc or the witness. 
6 
A Fifth. 
7 
MR. GOLDBERGER: You're 100 percent 
7 
Q Is a modeling agency that he is Involved 
8 
correct 
0 
in with Jean Luc Brunel; you know who that is 
9 
MR. EDWARDS: Can we go back to it. 
9 
right? 
10 
MR. GOLDBERGER: Absolutely. 
10 
MR. YAREMA: Object to the form. 
11 
MR. EDWARDS: Perfect. 
11 
A Fifth. 
12 
The silent fight disrupted mc. I lost 
12 
Q Are you familiar with MC-2 or MC-Squared 
13 
where I am now. 
13 
Modeling Agency? 
14 
MR GOLDBERGER: Sony. 
14 
A Fifth. 
15 
MR EDWARDS: Can you read it back. 
15 
Q You know Jean Luc Brunel, right? 
16 
THE COURT REPORTER: Certainly. 
16 
MR. YAREMA: Object to the fonn. 
17 
(The record was read.) 
17 
A Fifth. 
18 
MR. EDWARDS: I'll rephrase the 
18 
Q Is Jean Luc Brunel somebody that you 
19 
question. 
19 
have been made to perform on sexually? 
20 
Q Isn't it true that yourself, Ghislaine 
20 
MR. YAREMA: Object to the form. 
21 
Maxwell and 
had access to a master 21 
A Fifth. 
22 
of list of underage minor females names and phone 22 
Q Jean Luc Brunel is somebody that you 
23 
numbers so they could be called for the purpose 
23 
know to also be a child molester, true? 
24 
of coming to Jeffrey Epstein's house to be 
24 
MR. YAREMA: Object to the fonn. 
25 
sexually molested? 
25 
A Filth. 
35 
37 
1 
MR. YAREMA: Object to the form. 
1 
Q Thls is somebody who for years the 
2 
A Fifth. 
2 
public has known of Jean Luc Brunel as a child 
3 
Q How many underage minor females are on 
3 
molester, true? 
4 
that master list? 
4 
MR. YAREMA: Object to the form 
S 
MR. YAREMA: Object to the form. 
5 
A Fifth. 
6 
A Fifth. 
6 
Q In fact, that is the only thing Jeffrey 
7 
Q Are there photographs of these underage 
7 
Epstein and Jean Luc Brunel have in common, is 
8 
minor females on that master list? 
8 
their obsession for underage minor females, 
9 
MR. YAREMA: Object to the form. 
9 
correct? 
10 
A Fifth. 
10 
MR. YAREMA: Object to the form. 
11 
Q Is that master list saved on a computer 
11 
A Fifth. 
12 
system, as has been testified to in the past? 
12 
Q And the modeling agency Is but one other 
13 
MR. YAREMA: Object to the form. 
13 
mechanism used by Jeffrey Epstein to gain access 
14 
A Fifth. 
14 
to underage minor females for sex, true? 
15 
Q Has Jeffrey Epstein talked to you about 
15 
MR. YAREMA: Object to the form. 
16 
the success of his scheme to procure underage 
16 
A Fifth. 
17 
minor females? 
17 
Q I read you the statute earlier on Lewd 
18 
MR. YAREMA: Object to the form. 
18 
and Lascivious Molestation, Chapter 800.04, and 
19 
A Fifth. 
19 
that's something that you have witnessed Jeffrey 
20 
Q By that, I mean, the method where he 
20 
Epstein violate on hundreds of occasions, 
21 
molests an underage minor female, then offers 
21 
correct? 
22 
them additional money if they will bring him 
22 
MR. YAREMA: Object to the form. 
23 
other underage minor females to molest; are you 
23 
A Fifth. 
24 
familiar with that system? 
24 
Q And something that you have witnessed 
25 
MR. YAREMA: Object to the forum 
25 
Jeffrey Epstein specifically violate, against 
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M., true? 
MR. YAREMA: Object to the font. 
A Filth. 
Q Also a statute you have witnessed 
Jeffrey Epstein violate against then minor, 
MR. YAREMA: Object to the font 
A Fifth. 
Q In fact M. was somebody that Jeffrey 
Epstein liked or likes; Isn't that true? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q In 
was somebody Jeffrey Epstein met 
when she was only 13 years old and began sexually 
molesting her the first day that he met her, 
true? 
MR. YAREMA: Object to the fonn. 
A Filth. 
Q 
was one of his main girls, as he 
would call them; Is that true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q 
procured for hint or brought for him 
to his house, over 50 girls between the ages of 
12 and 15 years old; is that true? 
1 
2 
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Epstein's house, and he is using all resources to 
try to intimidate and harass her; is that true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q In fact, has he talked to you about his 
tactic of Intimidating and harassing any victims 
that conic forward against hint, regarding the 
sexual abuse that they endured by hint? 
MR. YAREMA: Object to the fem. 
A Fifth. 
Q Would you agree that Jeffrey Epstein 
contributed to the delinquency of these various 
minors that he sexually abused? 
MR. YAREMA: Object to the form. 
A 
Q In addition to abusing them, he also 
encouraged them to return to hint to receive more 
sexual abuse and encouraged them into a life of 
prostitution, true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q How many underage minor females have you 
observed Jeffrey Epstein engage in sex acts with 
on any of his airplanes? 
MR. YAREMA: Object to the form. 
1 
2 
3 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
39 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Each of these girls, aged 12 to 15, you 
observed come into the house, go into Jeffrey 
Epstein's bedroom and leave the house after being 
sexually molested, true? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q And in addition to M. being sexually 
molested herself, she was enticed or coerced into 
bringing her friends over, to also be sexually 
molested, true? 
MR. YAREMA: Object to the Ions 
A Fifth. 
Q Has Jeffrey Epstein talked to you about 
an FBI statement that was given by •? 
A Fifth. 
Q He has also told you that that FBI 
statement that was favorable for him is 
completely false; isn't that true? 
MR. YAREMA: Object to the lona. 
A Fifth. 
Q Has he spoken to you about the fact that 
she is now telling the complete story and 
accurate account as to what happened at Jeffrey 
1 
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22 
23 
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41 
A Fifth. 
Q Have you engaged in sexual acts with any 
underage minor females on Jeffrey Epstein's 
airplanes? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q How many times has Jeffrey Epstein 
talked to you about the reasons why he sexually 
abuses minors? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Didn't he tell you that it is his intent 
to harm these minors in hopes of gaining 
psychological advantage over them? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Are you aware that Jeffrey Epstein pled 
guilty to two felonies related to his interaction 
with minors? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q And as a result he was incarcerated, and 
as we spoke about earlier, you visited hint in 
jail on more than 50 occasions, correct? 
MR. YAREMA: Object to the loan. 
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a 
9 
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A Fifth. 
Q Aren't your observations with Jeffrey 
Epstein's interactions with 
wouldn't you 
agree he coerced her into a life of prostitution? 
MR. YAREMA: Object to the loan. 
A Fifth. 
Q And based on your observations of 
Jeffrey Epstein's interactions with M., 
wouldn't you agree that Jeffrey Epstein coerced 
her Into a life of prostitution? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q And with respect to Jane Doe and M. 
and M., wouldn't you agree that Jeffrey Epstein 
forced these girls to be a prostitute for him? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Would you agree that Jeffrey Epstein's 
actions against M., S 
and Jane Doe, were 
intentional, deliberate and reckless? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Would you agree that that intentional, 
deliberate and reckless conduct by Jeffrey 
Epstein against •., `and 
Jane Doe was 
1 
Q Do you profit from sex trafficking of 
2 
children? 
3 
MR. YAREMA: Object to the form. 
4 
A Fifth. 
5 
Q Do you know Sergio Cordaro? 
6 
A Fifth. 
7 
Q Do you know Mike Sank*? 
8 
A Fifth. 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Q Would you consider Jeffrey Epstein's 
criminal enterprise that is designed to molest 
underage minor females, to be organized? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q is your role in that criminal 
arrangement to molest underage minor females, to 
help organize? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q As part of that organization, Isn't it 
true that you, as well as various staff members, 
took nietleulous messages regarding appointments 
and scheduling underage minor females to come 
over to be sexually molested? 
MR. YAREMA: Object to the form. 
A Fifth. 
43 
1 
likely to cause severe emotional distress? 
2 
MR. YAREMA: Object to the form. 
3 
A Fifth. 
4 
Q And isn't it a fact that Jeffrey Epstein 
5 
has specifically told you that it is his intent 
6 
to cause severe emotional distress, as it 
7 
weakened his victims? 
8 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Has Jeffrey Epstein talked to you about 
your role in what he calls a criminal enterprise? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Has he talked to you about his 
organization being a crIntinal enterprise, that 
you need to help protect? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q What does Jeffrey Epstein do for a 
living? 
A Fifth. 
Q Does he profit from international sex 
traMckIng of children? 
MR. YAREMA: Object to the form. 
A Fifth. 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
45 
1 
() These were message pads that had a 
2 
carbon copy that were positioned or stationed in 
3 
several places around Jeffrey Epstein's home near 
4 
the telephone; you're familiar with those, 
5 
right? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Since I'm assuming that you are going to 
lake the Fifth on each and every question related 
to any messages, I will show you only one, which 
will be marked, this one page, as Plaintiff's 
Exhibit 1. The date on the message that I will 
be showing you is 8/21, August 21,2005. 
(Message dated August 21, 2005 was 
marked as Plaintiff's Exhibit number 1 for 
identification, as of this date.) 
MR. EDWARDS: Do you want to see it 
first? 
MR. GOLDBERGER: (Counsel examines 
document and hands it to the witness.) 
Q Would you look at the exhibit, please, 
if you can see it? I don't know if you tan see 
it over your coffee. 
A I can see it. 
Q Okay. Do you recognize it? 
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A Fifth. 
Q That particular message indicates It Is 
1 
2 
48 
Chisiaine Maxwell's sexual interaction with Jane 
Doe-I02 when she was a minor? 
3 
from In 
You're the only'' 
in the 
3 
MR. YAREMA: Object to the Ponca. 
4 
house; is that correct? 
4 
Q This is one of many underage minor 
5 
MR. YAREMA: Object to the form. 
5 
females that was trafficked basically around the 
6 
A Fifth. 
6 
globe to be sexually exploited and abused; is 
7 
Q This is a call front you indicating that 
7 
that correct? 
8 
cannot work today and 
will be 
8 
MR. YAREMA: Object to the fonn. 
9 
here at 4:00 p.m.;" is that right? 
A Fifth. 
10 
MR. YAREMA: Object to the font? 
10 
Q Was that typical of Jeffrey Epstein and 
11 
A Fifth. 
11 
Chislaine Maxwell to sexually abuse minors on 
12 
Q Who Is' 
12 
Jeffrey Epstein's airplane? 
13 
A Fifth. 
13 
MR. YAREMA: Object to the font 
14 
MIL YAREMA: Object to the fonn. 
14 
A Fifth. 
15 
Q That's an underage minor female that was 
5 
Q And also typical of Chislaine Maxwell 
16 
scheduled to be molested at Jeffrey Epstein's 
6 
and Jeffrey Epstein to prostitute or pimp out 
17 
house? 
7 
underage minors to friends? 
18 
MR. YAREMA: Object to the form. 
8 
MR. YAREMA: Object to the form. 
19 
A Fifth. 
A Fifth. 
20 
Q You scheduled that act of molestation; 
0 
Q By "friends," I am talking specifically 
21 
is that right? 
1 
about people of royalty, politicians, 
22 
MR. YAREMA: Object to the fonn. 
2 
academicians, businessmen and other professional 
23 
A Fifth. 
3 
or personal acquaintances? 
24 
Q And 
will be at the house at 4:00 
4 
MR. YAREMA: Object to the fonn. 
25 
p.m. 
is another underage minor female; 
5 
A Fifth. 
47 
49 
1 
Is that correct? 
1 
Q Were you with Jeffrey Epstein on his 
2 
MR. YAREMA: Object to the form. 
2 
birthday when one of his friends sent to him 
3 
A Fifth. 
3 
12 — sorry, three 12-year olds for the purposes 
4 
Q That's somebody else that you were 
4 
of Jeffrey Epstein sexually abusing them? 
5 
scheduling to come to his house at 4:00 p.m. for 
5 
MR. YAREMA: Object to the form. 
6 
Jeffrey Epstein to engage In sexual acts with 
6 
A Fifth. 
7 
her, while she was an underage minor, true? 
7 
Q How ninny occasions have you observed 
8 
MR. YAREMA: Object to the form. 
8 
Jeffrey Epstein to receive as gifts from friends, 
9 
A Fifth. 
9 
underage minor females for the purposes of him 
10 
Q Do you know Les Wexner? 
10 
sexually abusing them? 
11 
A Fifth. 
11 
MR. YAREMA: Object to the form. 
12 
Q That's somebody that you know owns and 12 
A Fifth. 
13 
operates the Victoria's Secret, the Limited? 
13 
Q These three 12-year olds were from 
14 
MR. YAREMA: Object to the fonn. 
14 
France. Were they sent to him on his birthday by 
15 
A Is that a question? 
15 
Jean Luc Brunel or by somebody else? 
16 
Q Is that somebody that you know to own 
16 
MR. YAREMA: Object to form. 
17 
Victoria's Secret or operate Victoria's Secret? 
17 
A Fifth. 
18 
A Fifth. 
18 
Q Have you ever been made to engage in sex 
19 
Q Do you know If Jeffrey Epstein still 
19 
with 12-year olds? 
20 
talks with Leslie Wexner? 
20 
MR. YAREMA: Object to the form. 
21 
MR. YAREMA: Object to the form. 
21 
A Fifth. 
22 
A Fifth. 
22 
Q Is It true that Jeffrey Epstein makes 
23 
Q Do you know Jane Doe-102? 
23 
you dress up as a 12-year old? 
24 
A Fifth. 
24 
MR. YAltEMA: Object to the font. 
25 
Q Are you aware of Jeffrey Epstein and 
25 
A Fifth. 
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1 
Q As part of being Jeffrey Epstein's sex 
1 
A Fifth. 
2 
slave, isn't it true that he asks you or requests 
2 
Q Do you know Bill Riley? 
3 
of you to dress younger than 12 at times? 
3 
A Fifth. 
4 
MR. YAREMA: Object to the form. 
4 
Q Have you seen the flight logs front 
5 
A Fifth. 
5 
Jeffrey Epstein's private airplane flights? 
6 
Q Have you seen naked photographs of the 
6 
MR. YAREMA: Object to the form. 
7 
underage minor females with whom Jeffrey Epstein 7 
A Fifth. 
8 
has engaged in sex acts? 
8 
Q Are you aware that you're listed as a 
MR. YAREMA: Object to the form. 
9 
passenger on many flights, along with Jeffrey 
10 
A Fifth. 
10 
Epstein on his private airplane? 
11 
Q Are there hidden cameras in any of 
11 
MR. YAREMA: Object to the form 
12 
Jeffrey Epstein's homes, that you know to have 
12 
A Fifth. 
13 
taken surreptitious videos or photographs of 
13 
Q Certainly conies as no surprise to you, 
14 
underage minors? 
14 
since you were on his airplane on numerous 
15 
MR. YAREMA: Object to the Conn. 
15 
occasions, correct? 
16 
A Fifth. 
16 
MR. YAREMA: Object to the four. 
17 
Q Does Jeffrey Epstein still watch 
17 
A Fifth. 
18 
pornography to this day? 
18 
Q On September 22,2003, you were listed 
19 
MR. YAREMA: Object to the form. 
19 
as being on a flight with 
,,lelTrey 
20 
A Etta,. 
20 
Epstein, 
and ■. My question 
21 
Q Does Jeffrey Epstein watch homemade 
21 
is who is ■. and who Is..? 
22 
pornographic videos of underage minors engaging 22 
MR. YAREMA: Object to the funn. 
23 
in sex orgies on his island? 
23 
A Fifth. 
24 
MR. YAREMA: Object to the form. 
24 
() Do you know 
25 
A Fifth. 
25 
A Fifth. 
51 
53 
1 
() Prior to the search warrant being 
1 
Q That's somebody that you're familiar 
2 
executed, you are aware that at least three 
2 
with, because you have been to Jeffrey Epstein's 
3 
computers were taken at Jeffrey Epstein's 
3 
house on many occasions with 
4 
direction, from Jeffrey Epstein's house, to avoid 
4 
correct? 
5 
detection by law enforcement, correct? 
5 
MR. YAREMA: Object to the form 
6 
MR. YAREMA: Object to the form. 
6 
A Fifth. 
7 
A Correct. 
7 
Q In fact, do you remember there being a 
and some other person 
8 
burglary of Jeffrey Epstein's house where he 
9 
took those computers to avoid Jeffrey Epstein —
9 
actually called the police to investigate the 
10 
to avoid the authorities obtaining the evidence 
10 
burglary? 
11 
contained on those computers, correct? 
11 
MR. YAREMA: Object to the form. 
12 
MR. YAREMA: Object to the form. 
12 
A Fifth. 
13 
A Fifth. 
13 
Q And during the police investigation 
14 
Q Who are the persons along with 
14 
inside Jeffrey Epstein's house, you were speaking 
15 
took the computers front Jeffrey 
15 
with MEI 
both in person, at Jeffrey 
16 
Epstein's house prior to the execution of the 
16 
Epstein's house, correct? 
17 
search warrant? 
17 
MR. YAREMA: Object to tile form. 
18 
MR. YAREMA: Object to the form. 
18 
A Correct. 
19 
A Fifth. 
19 
Q Is this another person that Jeffrey 
20 
Q Where are those computers today? 
20 
Epstein, when she was a minor, violated 
21 
MR. YAREMA: Object to the form. 
21 
sexually? 
22 
A Fifth. 
22 
MR. YAREMA: Object to the form. 
23 
Q Were they taken by his investigator, 
23 
A Fifth. 
24 
Bill Riley? 
24 
Q Do you still speak with 
25 
MR. YAREMA: Object to the form. 
25 
MR. YAREMA: Object to the form. 
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A Fifth. 
1 
56 
Jeffrey Epstein specifically flew to Palm Beach 
2 
Q Do you know Bill Clinton? 
2 
for the purposes of engaging in sex acts with 
3 
A Fifth. 
3 
Jane Doe? 
4 
Q You have been on Jeffrey Epstein's 
4 
MR. YAREMA: Object to the toms. 
airplane with Bill Clinton? 
5 
A Fifth. 
6 
MR. YAREMA: Object to the fonn. 
6 
Q Generally, Isn't it true Jeffrey Epstein 
7 
A Fifth. 
7 
would fly front place to place for the purpose of 
8 
Q Isn't take true you have been on Jeffrey 
8 
engaging in sexual activity with minors at his 
9 
Epstein's airplane with Doug Band, Bill Clinton's 
9 
destination? 
10 
righthand man? 
10 
MR. YAREMA: Object to the form. 
11 
MR. YAREMA: Object to the fonn. 
11 
A Fifth. 
12 
A Fifth. 
12 
Q Isn't It true that he employed numerous 
13 
Q slave you witnessed Improper sexual 
13 
people for the sole purpose of scheduling 
14 
activity between Jeffrey Epstein and minors, 
14 
appointments with underage minor females at each 
15 
while he was in the presence of Bill Clinton? 
15 
destination he landed? 
16 
MR. YAREMA: Object to the form. 
16 
MR. YAREMA: Object to the form. 
17 
A Fifth. 
17 
A Fifth. 
18 
Q How many times have you ridden on the 
18 
Q What is Jeffrey Epstein's relationship 
19 
airplane with Jean Luc Brunel? 
19 
with Sandy Berger? 
20 
MR. YAREMA: Object to the font 
20 
MR. YAREMA: Object to the fonn. 
21 
A Fifth. 
21 
A Fifth. 
22 
Q Each time that Jean Luc Brunel visits 
22 
Q Do you know what Jeffrey Epstein's 
23 
Jeffrey Epstein's house, does he bring underage 
23 
relationship is with Alan Dershowitz? 
24 
minors to Jeffrey Epstein's house to engage in 
24 
MR. YAREMA: Object to the form. 
25 
sex with? 
25 
A Fifth. 
55 
57 
1 
MR. YAREMA: Object to the form. 
Q That's somebody who you know to have 
2 
A Fifth. 
2 
stayed at Jeffrey Epstein's house on many 
3 
Q Do you know Glenn Dubin? 
3 
occasions, correct? 
4 
A Fifth. 
4 
MR. YAREMA: Object to the form. 
5 
Q Do you know li
n? 
A Fifth. 
6 
A Fifth. 
6 
Q And also somebody who you know to have 
7 
Q Is that somebody that was a sexual abuse 
7 
been at the house when M. was In Jeffrey 
8 
victim at one point in time of Jeffrey Epstein 
8 
Epstein's bedroom getting sexually abused, 
9 
and Jean Luc Brunel? 
9 
correct? 
10 
MR. YAREMA: Object to the Conn. 
10 
MR. YAREMA: Object to the fonn. 
11 
A Fifth. 
11 
A Fifth. 
12 
Q Between 2002 and 2005 when M. was 
12 
Q Alan Dershowitz is also somebody that 
13 
abused by Jeffrey Epstein sexually, isn't it true 
13 
you also know to have been at the house when M. 
14 
that Jeffrey Epstein took flights to Palm Beach 
14 
was being sexually abused in Jeffrey Epstein's 
15 
for the purposes of sexually abusing M.? 
15 
bedroom, correct? 
16 
MR. YAREMA: Object to the form. 
16 
MR. YAREMA: Object to the fonn 
A Fifth. 
17 
A Fifth. 
Q And between those same years of 2002 and 
18 
Q Generally, Alan Dershowitz is familiar 
2005, Isn't it true that Jeffrey Epstein took 
19 
with Jeffrey Epstein's habit of engaging in 
airplane flights to Palm Beach front places 
20 
sexual acts with minors on a daily basis, 
outside of the State, to engage in sexual acts 
21 
correct? 
with M.? 
22 
MR. YAREMA: Object to the form. 
MR. YAREMA: Object to the form. 
23 
A Fifth. 
A Fifth. 
24 
Q When Alan Dershowltz was In town, 
5 
Q From 2003 through 2005, Isn't it true 
25 
Jeffrey Epstein did not break his schedule for 
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Alan Dershowitz, meaning he continued to sexually 1 
60 
Q Whnt was the purpose of that flight? 
2 
abuse minors despite Alan Dershowitz being a 
2 
MR. YAREMA: Object to the form. 
3 
guest In the house? 
3 
A Fifth. 
4 
MR. YAREMA: Object to the fonn. 
4 
Q Did you sign a confidentiality agreement 
5 
A Fifth. 
5 
with Jeffrey Epstein? 
6 
Q Alan Dershowitz never engaged in any 
6 
MR. YAREMA: Object to the tome 
sexual activity with these underage minors; isn't 
7 
A Fifth. 
8 
that true? 
8 
Q When is the last time that you observed 
9 
MR. YAREMA: Object to the fonn. 
9 
Jeffrey Epstein have sex with a minor? 
10 
A Fifth. 
10 
MR. YAREMA: Object to the form. 
1 
Q have you been made to have sex with 
11 
A Fifth. 
12 
Chislaine Maxwell? 
12 
Q Since being on probation, has Jeffrey 
13 
MR. YAREMA: Object to the lona. 
13 
Epstein been able to, or has he flown to his 
14 
A Fifth. 
14 
island? 
15 
Q Do you know 
15 
MR. YAREMA: Object to the Conn 
16 
A Fifth. 
16 
A Fifth. 
17 
Q Similar to you being Jeffrey Epstein's 
17 
Q To your knowledge, has Jeffrey Epstein 
18 
sex slave, is MEM, 
or was 
113 
flown to New York while on probation or community 
19 
Chislaine Maxwell's sex slave? 
19 
control? 
20 
MR. YAREMA: Object to the font 
20 
MR. YAREMA: Object to the fonn. 
21 
A Fifth. 
21 
A Filth. 
22 
Q Chislaine Maxwell is somebody who you 
22 
Q Isn't it true that he has flown both to 
23 
know to be IA-sexual, true? 
23 
New York and to his island, and you have 
24 
MR. YAREMA: Object to the form. 
24 
accompanied him on those trips, since he was on 
25 
A Fifth. 
25 
community control? 
59 
61 
Q You know that Chislaine Maxwell engaged 
1 
MR. YAREMA: Object to the form. 
2 
in sexual acts with underage minor females, true? 
2 
A Fifth. 
3 
MR. YAREMA: Object to the form. 
3 
Q Isn't it also true that Jeffrey Epstein 
4 
A Fifth. 
4 
has indicated to you that he will always engage 
5 
Q This is yet another friend of Jeffrey 
5 
in sex acts with underage minor females? 
6 
Epstein's that is into the act of molesting 
6 
MR. YAREMA: Object to the form. 
7 
underage minor females, right? 
7 
A Fifth. 
8 
MR. YAREMA: Object to the form. 
8 
Q In fact, that's something that he has 
9 
A Fifth. 
9 
told you, that he believes he is entitled to do; 
10 
Q Now, you are the next participant in 
10 
isn't that right? 
11 
that activity, meaning you have been groomed to 
11 
MR. YAREMA: Object to the fonn. 
12 
enjoy and appreciate the acts of sex with 
12 
A Filth. 
13 
underage minors, true? 
13 
Q Isn't It true that Jeffrey Epstein 
14 
MR. YAREMA: Object to the form. 
14 
believes and has told you that if he doesn't 
15 
A Fifth. 
15 
physically force the underage minor female into 
16 
Q Has Jeffrey Epstein instructed you to 
16 
any act, then he is entitled to engage in sex 
17 
Ile to his Probation Officer in any way? 
17 
with any underage minor female despite the age? 
18 
MR. YAREMA: Object to the form. 
18 
MR. YAREMA: Object to the form. 
A Fifth. 
19 
A Fifth. 
Q Mr. Visoski testified that you took a 
20 
Q What is the youngest female you have 
helicopter flight within the last year with 
21 
witnessed or observed Jeffrey Epstein to engage 
Jeffrey Epstein to Miami. Do you remember that 
22 
in sex with? 
flight? 
23 
MR. YAREMA: Object to the fonn. 
MR. YAREMA: Object to the form. 
24 
A Fifth. 
5 
A Fifth. 
25 
Q Do you have a bunk account at Chase Bank 
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2 
3 
4 
5 
6 
62 
In New York? 
A Fifth. 
Q And the money in that bank account under 
your name is money that was given to you by 
Jeffrey Epstein, correct? 
MR. YAREMA: Object to the fon. 
1 
2 
3 
4 
5 
6 
64 
Q That's somebody who these days refers to 
himself as Jeffrey Epstein's personal assistant, 
right? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q That's somebody who you know to work for 
7 
A Fifth. 
7 
or at the Florida Science Foundation, which is 
8 
Q For the passed ten or so years, you have 
8 
owned by Jeffrey Epstein, correct? 
9 
lived with Jeffrey Epstein under his control, 
9 
MR. YAREMA: Object to the form. 
10 
right? 
10 
A Fifth. 
11 
MR. YAREMA: Object to the form. 
11 
Q It is also somebody that you know to 
12 
A Fifth. 
12 
have stayed at Jeffrey Epstein's house with= 
13 
Q You get to lead the life of a 
13 
correct? 
14 
millionaire, and to lead that life, you were only 
14 
MR. YAREMA: Object to the fonn. 
15 
required to be Jeffrey Epstein's sex slave and to 
15 
A Fifth. 
16 
bring Jeffrey Epstein other slaves? 
16 
Q This is somebody that has been 
17 
MR. YAREMA: Object to the form. 
17 
Involved — 
is somebody who's been 
18 
A Fifth. 
18 
Involved sexually with 
for at least 
19 
Q Is this 301 East 66th Street apartment 
19 
a year, right? 
20 
still an apartment that you frequent today? 
20 
MR. YAREMA: Object to the tome. 
21 
MR. YAREMA: Object to the form. 
21 
A Fifth. 
22 
A Fifth. 
22 
Q In fact, you know that they took a trip 
23 
Q And you're familiar with the nine or ten 
23 
around the world together and during that trip 
24 
apartments that Jeffrey Epstein owns or controls 
24 
they discussed Jeffrey Epstein and his 
25 
up there at 301 East 66th Street, aren't you? 
25 
interaction with underage minor females, 
63 
65 
1 
MR. YAREMA: Object to the form. 
1 
correct? 
2 
A Fifth. 
2 
MR. YAREMA: Object to the form. 
3 
Q At any given time, there are between S 
3 
A Fifth. 
4 
and 16 underage minors living in or staying at 
4 
MR. EDWARDS: Done. I don't have 
S 
those apartments? 
5 
anything else. 
6 
MR. YAREMA: Object to the fonn. 
6 
MR. GOLDBERGER: Okay. 
7 
A Fifth. 
7 
MR. HOROWITZ: I do, why don't we take a 
8 
Q On the various passenger lists on 
8 
short break. 
9 
Jeffrey Epstein's airplane, where it will list, 
MR. GOLDBERGER: We are stopping at 
10 
for instance, Jeffrey Epstein, 
10 
11:50. 
11 
going from Florida to St. 
11 
MR. HOROWITZ: What? 
12 
Thomas, then generically, female, female; would 
12 
MR. GOLDBERGER: 11:50. 
13 
you know who those female, females are? 
13 
MR. HOROWITZ: I kind of remember that 
14 
MR. YAREMA: Object to the form. 
14 
e-mail. 
15 
A Fifth. 
15 
THE VIDEOGRAPHER: Off the video record. 
16 
Q Are those females listed generically 
16 
(Pause in the proceedings.) 
17 
rather than specifically because they are 
17 
THE V1DEOCRAPHER: We are back on the 
18 
underage minor females engaging in sex with you 
18 
video record at 11:18 a.m.) 
19 
or Jeffrey Epstein? 
19 
(At this time Robert Critton joined the 
20 
MR. YAREMA: Object to the fonn. 
20 
proceedings.) 
21 
A Fifth. 
21 
CROSS EXAMINATION 
22 
Q Is 
someone that you see on 
22 
BY MR. HOROWITZ: 
23 
■ regular basis at Jeffrey Epstein's house? 
23 
between 200t and 2006, 
24 
MR. YAREMA: Object to the fonn. 
24 
did Jeffrey Epstein instruct you to place 
25 
A Fifth. 
25 
telephone calls io arrange for girls under the 
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68 
2 
3 
4 
5 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
age of 18 to come to his home for his sexual 
gratification? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Between 2001 and 2006 did you, in fact, 
place telephone calls to arrange for girls under 
the age of Is to come to Jeffrey Epstein's home 
for his sexual gratification? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Are you personally aware that a girl 
named 
M
.
 
came to Jeffrey Epstein's Palm Beach 
home in late 2004? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein admit to you he 
sexually abused M.? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Isn't it true in late 2004 you made 
arrangements by telephone to bring S 
to 
Jeffrey Epstein's home? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Did Jeffrey Epstein instruct you to 
1 
2 
3 
4 
5 
6 
B 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
A Fifth. 
Q Did Jeffrey Epstein admit to you that he 
sexually abused 
in his Palm Beach home in 
2004? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did you ever instruct a girl named a 
to bring other underage girls to Jeffrey 
Epstein's home for Jeffrey Epstein's sexual 
pleasure? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q In 2004 did you communicate by telephone 
with 
for the purpose of bringing 
■. to Jeffrey Epstein's home for sexual 
activity MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Did Jeffrey Epstein instruct you to 
communicate with 
for the purpose of 
making arrangements for M. to come to his home? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein tell you it was his 
intent during the course of M.'s visit to his 
5 
home to persuade, induce or entice her to engage 
67 
communicate by telephone to arrange for M. to 
2 
come to his home for his sexual gratification? 
3 
MR. YAREMA: Object to the fonn. 
4 
A Fifth. 
5 
Q Did Jeffrey Epstein inform you that M. 
6 
would be giving him a massage that was sexual in 
7 
nature? 
MR. YAREMA: Object to the form. 
9 
A Fifth. 
10 
Q Did Jeffrey Epstein tell you it was his 
11 
intent during the course of M.'s visit to his 
12 
home to persuade, induce or entice her to engage 
13 
in sexual activity? 
14 
MR. YAREMA: Object to the fonn. 
15 
A Fifth. 
16 
Q Did Jeffrey Epstein tell you that, in 
17 
fact, he succeeded in persuading, Inducing or 
18 
enticing M. to engage in sexual activity with 
19 
hint? 
20 
MR. YAREMA: Object to the form. 
21 
A Fifth 
22 
Q Are you personally aware that a girl 
23 
named 
M
.
 
came to Jeffrey Epstein's Palm Beach 
24 
home on multiple occasions in 2004? 
25 
MR. YAREMA: Object to the form. 
1 
2 
3 
4 
S 
6 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
69 
In sexual activity with him? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein admit to you that he 
had succeeded in, in fact, persuading, inducing 
or enticing M. to engage in sexual activity 
with him? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Are you personally aware that a teenage 
girl named 
came to Jeffrey Epstein's Palm 
Beach home on multiple occasions between 2003 and 
2005? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein admit to you that he 
sexually abused St 
MR. YAREMA: Object to the form 
A Fifth. 
Q At any time prior to May of 2005, did 
Jeffrey Epstein instruct you to place telephone 
calls to M. for the purpose of arranging for 
her to come to his home and engage in sexual 
activity? 
MR. YAREMA: Object to the form. 
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1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A Filth. 
Q Did you, in fact, communicate by 
telephone with • 
for the purpose of arranging 
for her to come to his home for sexual activity? 
MR. YAREMA: Object to the tom. 
A Fifth. 
Q At any lime prior to May of 2005, did 
you place a telephone call to I= 
wherein you arranged fore to come to Jeffrey 
Epstein's home for sexual activity? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Prior to May of 2005, did you ever 
observe 
speaking with M. by 
telephone to arrange for M. to come to Jeffrey 
Epstein's home? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein tell you that it was 
his intention to sexually abuse ■. during the 
course of her visits to his home? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein tell you that he 
succeeded in engaging `In 
sexual activity 
1. 
2 
3 
4 
S 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
3 
24 
25 
in either 2001 or 2002? 
MR. YAREMA: Object to the form.
A Fifth. 
Q Did you, in fact, call M. to come to 
Jeffrey Epstein's home and give him a massage in 
sexual nature in 2001 or 2002? 
MR. YAREMA: Object to the tom. 
A Fifth. 
Q Did you either observe or overhear 
speaking with M. on the telephone to 
arrange for M. to conic to Jeffrey Epstein's 
home for a massage of a sexual nature? 
MR. YAREMA: Object to the form. 
A Filth. 
Q Did Jeffrey Epstein tell you it was his 
intent during the course of M.'s visit to his 
home to persuade, induce or entice her to engage 
In sexual activity? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Didn't Jeffrey Epstein admit to you that 
he succeeded in persuading, inducing or enticing 
M. to engage in sexual activity with him nt his 
home while she was still a minor? 
MR. YAREMA: Object to the form. 
1 
2 
3 
4 
5 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
71 
while she was still a minor, at his home? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Are you personally aware that a teenage 
girl named an 
came to Jeffrey Epstein's 
Palm Beach home in approximately 2001 or 2002? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein admit to you that he 
sexually abused 
M
.
 
at his home while she was 
sun a child? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q In 2001 or 2002, did 
inform 
you that she received a telephone call in which 
she was referred to M., who would be willing to 
come to Jeffrey Epstein's home for sexual 
activity? 
MR. YAREMA: Object to the form. 
A Fifth. 
(Whereupon, at this point in the 
proceedings, Robert Critton leit the 
deposition room.) 
Q Did Jeffrey Epstein instruct you to call 
M. to come to his home and give him a massage 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1.3 
A Fifth. 
Q Are you personally aware that a girl 
named 
came to Jeffrey Epstein's home in 
approximately August 2004? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein admit to you that he 
had sexually abused M. when she was only 13 
years old? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q In 2004 did you participate in a 
telephone call wherein you arranged for ■. to 
come to Jeffrey Epstein's home for the purpose of 
giving him a massage that was to be sexual In 
nature? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein instruct you to 
communicate by telephone and make arrangement 
for M. to conic to his home for sexual activity 
while she was still a child? 
MR. YAREMA: Object to the foam 
A Fifth. 
Q Did Jeffrey Epstein tell you it was his 
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intention during the course of M.'s visit to 
his home to persuade, Induce or entice her to 
engage in sexual activity with him? 
1 
2 
3 
76 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Dld you participate in a telephone call 
4 
MR. YAREMA: Object to the font. 
4 
wherein you arranged for M. to tome to Jeffrey 
A Fifth. 
5 
Epstein's home for a massage? 
6 
Q Did Jeffrey Epstein tell you that, In 
6 
MR. YAREMA: Object to the form. 
7 
fact, he succeeded in persuading, inducing and 
7 
A Fifth. 
8 
enticing. to engage in sexual activity with 
Q Did Jeffrey Epstein instruct you to 
9 
him while she was still a child at his home? 
9 
participate in a telephone call wherein you were 
10 
MR. YAREMA: Object to the form. 
10 
to arrange for 
to come to Ids home for 
11 
A Fifth. 
11 
sexual activity? 
12 
Q Are you personally aware that a girl 
12 
MR. YAREMA: Object to the fonn. 
13 
named e 
came to Jeffrey Epstein's home in Palm 
13 
A Fifth. 
14 
Beach on multiple occasions between 2003 and May 14 
Q Did Jeffrey Epstein admit to you It was 
15 
of 2005? 
15 
his intention during the course of 
visit 
16 
MR. YAREMA: Object to the fonn. 
16 
to his home, to engage her in sexual activity 
17 
A Fifth. 
17 
while she was still a child? 
18 
Q Did Jeffrey Epstein admit to you that he 
18 
MR. YAREMA: Object to the form. 
19 
sexually abused. at his home between 2003 and 
19 
A Fifth. 
20 
May of 2005? 
20 
Q Did Jeffrey Epstein admit to you he had, 
21 
MR. YAREMA: Object to the form. 
21 
In fact, persuaded, enticed and engaged 
in 
22 
A Fifth. 
22 
sexual activity at his home while she was still a 
23 
Q Prior to May of 2005, did you receive a 
23 
child? 
24 
phone call front a girl named 
wherein 24 
MR. YAREMA: Object to the form. 
25 
she told you she was bringing e 
to Jeffrey 
25 
A Fifth. 
75 
77 
1 
Epstein's home to give him a massage? 
1 
MR. HOROWITZ: No other questions at 
2 
MR. YAREMA: Object to the form. 
2 
this point. 
3 
A Fifth. 
3 
MR. LANGINO: I have less than ten 
4 
Q At any time prior to 2005, did Jeffrey 
4 
minutes of questioning. 
5 
Epstein instruct you to communicate with MI 
5 
MR. GOLDBERGER: Fine, that will bring 
6 
by telephone to make arrangements for. 
6 
us right to the break. 
7 
to come to his home? 
7 
CROSS EXAMINATION 
8 
MR. YAREMA: Object to the Fenn. 
8 
BY MR. LANGINO: 
9 
A Fifth. 
9 
Q I'm Adam Langino and I represent.. 
10 
Q Prior to M.'s visits to Jeffrey 
10 
and.. 
11 
Epstein's home, did Jeffrey Epstein tell you it 
11 
Do you know an individual named M? 
12 
was his intention to induce, entice and engage 
12 
A Fifth. 
13 
N., to engage in sexual activity with him? 
13 
Q Do you know an individual named M.? 
14 
MR. YAREMA: Object to the fonn. 
14 
A Fifth. 
15 
A Fifth. 
15 
Q Have you seen 
at the defendant's 
16 
Q After 
visits to Jeffrey Epstein's 
16 
Palm Beach property? 
17 
home, did Jeffrey Epstein tell you that he 
17 
MR. YAREMA: Object to the form. 
18 
succeeded in enticing, engaging and persuading 
18 
A Fifth. 
19 
to engage in sexual activity with him while 
19 
Q (lave you seen.. al the defendant's 
20 
she was still a child? 
20 
Palm Beach property? 
21 
MR. YAREMA: Object to the fonn. 
21 
MR. YAREMA: Object to the form. 
22 
A Fifth. 
22 
A Fifth. 
23 
Q Are you personally aware that a teenage 
23 
Q Have you ever engaged in a sexual act 
24 
girl minted 
came to Jeffrey Epstein's Palm 
24 
with 
25 
Beach home in approximately 2001 or 2002? 
25 
MR. YAREMA: Object to the fonn. 
20 (Pages 74 to 77) 
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