EFTA00181769

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. 
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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 
U.S. Legal Support 
(561) 835-0220 
EFTA00181769

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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 
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PLAINTIFF'S 
FOR IDENTIFICATION 
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Message dated August 21,2005. 
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APPEARANCES (CONTINUED) 
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LEOPOLD-KUVIN 
Attorneys for Plaintiffs 
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II. B. and CI'. 
2925 PGA Boulevard, Suite 200 
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Palm Beach Garden, Florida 33410 
Tel: (561)515-1400 
BY: ADAM J. LANGINO, ESQ. 
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PODHURST, ORSECK 
Attorneys for Jane Does I and 3 
City National Bank Building, Suite 88 
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25 West Saida Street 
Miami, Florida 33130 
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Tel: (954)463-4346 
BY: KATHERINE W. EZELL, ESQ. 
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BURMAN. CIUTTON, LUTITER & COLEMAN, LIP 
Attorneys for Defendant Jeffrey Epstein 
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303 Banyon Boukvard. Suite 400 
West Palm Beach. Florida 33401 
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Tel: (561)842-2820 
BY: DAVID YAREMA, ESQ. 
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ROBERT turret'', ESQ. 
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AlTERBURY, GOLDBERGER & WEISS 
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Co-Counsel for Defendarus 
One Clearbke Court 
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Suite 1400 
West Palm Beach. Florida 33401 
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Tel: (561)659.8300 
BY: JACK A. GOLDBERGER. ESQ. 
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ALSO PRESENT: 
JESSICA CADWELL 
JOE ROVNER. Videographer 
(U.S. Legal) 
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The videotaped deposition of —
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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 for 
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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 court. 
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The appearances at said time and place 
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were as follows: 
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FARMER, JAFFE, WEISSING, EDWARDS, 
FISTOS & LEHRMAN, PL 
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Attorneys for Plaintiffs Jane Does, 
L.N. and E.W. 
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425 North Andrews Avenue 
Suite 2 
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Fort Lauderdale, Florida 33301 
Tel: (954) 524-2820 
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BY: BRADLEY J. EDWAltDS, ESQ. 
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MERMELSTEIN & HOROWITZ, P.A. 
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Attorneys for Plaintiffs Jane Does, 
numbers 2 through 8 
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18205 Biscayne Boulevard 
Suite 2218 
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Miami, Florida 33160 
Tel: (305) 931-2200 
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BY: ADAM D. HOROWITZ, ESQ. 
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THEREUPON, 
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being by Terri Becker lint duly sworn to tell 
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the whole truth, as hereinafter certified, 
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testified as follows: 
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DIRECT EXAMINATION 
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BY MR. EDWARDS: 
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Q Can you tell us your name. 
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Q What Is your date of birth? 
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A February 21, 1985. 
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Q What is your Social Security number? 
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A Under advice of my counsel, I invoke my 
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privileges under the Fifth and Sixth Amendments 
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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, I 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 "Fifth." 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. 
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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. 
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Q 
reask the question, what's your 
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Q Do you know Evelyn Velasaques? 
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current address? 
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A The Fifth. 
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A Fifth. 
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Q Were you ever a working model in the 
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Q Are you currently living at 358 El 
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United States? 
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Brillo Way with a man named Jeffrey Epstein? 
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A The Fifth. 
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A The Fifth. 
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Q Can you tell us your parents' names? 
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Q Are you also familiar with all address in 
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A The Fifth. 
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New York, 301 East 66th Street? 
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Q Flow is it that you have supported 
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A The Fifth. 
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yourself financially, since you have been in this 
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Q When Mr. Epstein was incarcerated in 
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country? 
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jail, you went to visit him on numerous 
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MR. YAREMA: Object to the fonn. 
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occasions; is that correct? 
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A The Fifth. 
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MR. YAREMA: Objection. 
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Q Have you supported yourself financially? 
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A Thc Fifth. 
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A The Fifth. 
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Q When you went to visit him you indicated 
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Q What is the last grade you completed in 
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to jail personnel your address was 301 East 66th 
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school? 
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Street, apartment 8-D in New York City, New York; 25 
A The Fifth, I take the Fifth Amendment. 
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Is that correct? 
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Q Are you in school now? 
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MR. YAREMA: Objection. 
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A The Fifth. 
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A Fifth. 
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Q Have you ever attended any school in the 
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Q Isn't it true when Mr. Epstein was In 
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United States? 
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jail, you visited him on more than 50 occasions? 
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A The Fifth. 
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MR. YARE•MA: Form objection. 
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Q Ilave you ever been employed since 
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Q True? 
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residing in the United States? 
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A The Fifth. 
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A The Fifth. 
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Q Flow long have you been in the United 
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Q Is Jeffrey Epstein your sole means of 
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States, Ms. 
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financial support today? 
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A The Fifth. 
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MR. YAREMA: Object to the form. 
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Q Who brought you to the United States? 
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A Thc Fifth. 
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MR. YAREMA: Form objection. 
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Q Since coming to this country, hasn't 
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A The Fifth. 
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Jeffrey Epstein always been your sole means of 
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Q What is your current status In this 
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financial support? 
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country? 
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MR. YAREMA: Object to the form. 
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A The Fifth. 
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A The Fifth. 
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MR. YAREMA: Form objection. 
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Q Flow much does Jeffrey Epstein pay you 
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MR. GOLDBERGER: Let me take a half a 
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today? 
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second. 
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MR. YAREMA: Object to the form. 
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(Witness and her counsel confer.) 
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A The Fifth. 
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Q Are you a U.S. citizen? 
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Q What does every Epstein pay you for? 
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A The Fifth. 
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MR. YAREMA: Object to the form. 
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Q What type of visa are you here on? 
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A The Fifth. 
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MR. YAREMA: Form objection. 
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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 
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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 Yugoslavian lesbian 
sex slave? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q Is that true? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q Have you performed any services for 
Jeffrey Epstein aside from being his sex slave? 
MR. YAREMA: Object to the fonn. 
A The Fifth. 
Q What Is your sexual orientation? 
MR. YAREMA: Object to the form. 
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? 
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MR. YAREMA: Object to the Iona 
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A Fifth. 
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Q What does it mean to be Jeffrey 
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Epstein's sex slave? 
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MR. YAREMA: Object to the form. 
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A Fifth. 
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Q Are you aware that Jeffrey Epstein reads 
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books on how to be a proper master to his sex 
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slave? 
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MR. YAREMA: Object to the fonn. 
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A Fifth. 
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Q What has Jeffrey Epstein done to train 
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you to be his sex slave? 
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MR. YAREMA: Object to the fonn. 
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A Fifth. 
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Q What do your parents think about you 
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being Jeffrey Epstein's sex slave? 
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MR. YAREMA: Object to the fonn. 
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A Fifth. 
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Q When did you first learn that Jeffrey 
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Epstein had a sexual obsession for underage minor 
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females? 
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MR. YAREMA: Object to the form. 
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A Fifth. 
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A I take the Fifth. 
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Q I represent a lady named, a young female 
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named E.W.; you know who that is, right? 
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Ma. 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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E.W., didn't he? 
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MR: YAREMA: Object to die form. 
A The Fifth. 
Q You did, in fact, engage in sexual 
activity with E.W. when she was only 16 years 
old; isn't that true? 
MR. YAREMA: Object to the fonn. 
A The Fifth. 
Q Back to my original question: And I'll 
ask you this way: Do you consider yourself 
heterosexual, bi-sexual, or can you answer that 
question? 
MR. YAREMA: Object to the form. 
MR. GOLDBERGER: Seine objection. Do not 
answer the question. 
A Fifth. 
Q How did you meet Jeffrey Epstein? 
A Fifth. 
Q When did you become one of Jeffrey 
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Q How many times has Jeffrey Epstein made 
you have sex with underage minor females? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Do you enjoy sex with underage minor 
females? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q What is the youngest child that Jeffrey 
Epstein has forced you to have sex with? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Does Jeffrey Epstein today still make 
you have sex with underage minor females? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q How ninny underage minor females has 
Jeffrey Epstein made you have sex with, since you 
were over the age of 18? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q Prior to turning 18, Is it true that 
Jeffrey Epstein made you have sex with many other 
children in kid-type orgies? 
MR. YAREMA: Object to the form 
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A Fifth. 
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Q Has Jeffrey Epstein also made you 
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perform sexually on his friends? 
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MR. YAREMA: Object to the form. 
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A Fifth. 
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Q Do you know David Copperfield? 
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MR. YAREMA: Object to the form. 
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A Fifth. 
Q Have you ever been made to perform 
sexually on David Copperfield? 
MR. YAREMA: 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 form. 
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 fonn. 
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A Fifth. 
Q I'm assuming you understand why you're 
here today, correct? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q For allegations related to Jeffrey 
Epstein interacting sexually with numerous 
underage minor females; that's something you 
know, right? 
MR. YAREMA: Object to the fonn. 
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 form. 
A Fifth. 
Q You were n part of that criminal 
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 form. 
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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 fonn. 
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 tbnn. 
A The Fifth. 
Q Have you ever discussed with Jeffrey 
Epstein that the fact that he is a child 
molester? 
MR. YAREMA: Object to the form. 
A Fifth. 
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 form. 
A Fifth. 
Q During the litigation of these civil 
eases, has Jeffrey Epstein indicated to you an 
intent to continue to molest children? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Is it your intent to continue to commit 
sex crimes against minors? 
MR. YAREMA: Object to the font 
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 
IIIMP 
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? 
MIL 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 
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ram. 
listed as a co-conspirator. 
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Do you know IMM? 
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A Fifth. 
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Q This is somebody who lives with you and 
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Jeffrey Epstein; is that true? 
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MR. YAREMA: Object to the form. 
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A Fifth. 
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Q And 
is somebody who you 
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know to be Story Cowles's girlfriend; is that 
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true? 
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MR. YAREMA: Object to the fonts. 
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A Fifth. 
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Q She's spoken with Story Cowles about 
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this case on numerous occasions; is that true? 
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MR. YAREMA: Object to the form. 
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A Fifth. 
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conversations with Story 
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Cowles and your observations of them, you believe 
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would implicate you in a crime and that's why 
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you're able to take the Fifth as to that 
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question? 
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MR. YAREMA: Object to the form. 
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A Fifth. 
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Q Who is Lesley Croft, 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 daily 
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 Paint 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 form? 
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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 remain for the purposes of 
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sexually molesting them as well; is that 
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correct? 
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MR. YAREMA: Object to the form. 
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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 front that local area 
as well, and that's something you've observed? 
MR. YAREMA: Object to the form. 
A Filth. 
Q On his island, particularly, lie has 
flown underage minor females to the island for 
underage kid-type orgies; is that true? 
MR. YAREMA: Object to the fonn. 
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 font 
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 arc 
his girlfriend or his sex slave, or some other 
designation? 
MR. YAREMA: Object to the toms. 
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. 
MR. EDWARDS: I agree, Jack, I just know 
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if this is played for a jury, I don't went 
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the jury to interpret her shaking her 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 slave, 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 foam 
A Fifth. 
Q Isn't it true you're under strict orders 
to tell Probation that? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Isn't ft 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 fonn. 
A Fifth. 
Q I asked you earlier about E.W. out of 
turn as a result of an objection related to your 
sexual orientation, but I'll talk specifically 
about E.W. 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? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q The first time she went to Jeffrey 
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minor females? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q You have received oral sex from underage 
5 
Epstein's house was in 2002 when she was only 14 
minor females? 
6 
years old; is that true? 
6 
MR. YAREMA: Object to the form. 
7 
MR. YAREMA: Object to the form. 
7 
A Filth. 
8 
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. YAREMA: Object to the form. 
12 
Q And E.W. 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 form. 
17 
Jeffrey Epstein ejaculating, correct? 
18 
A Fifth. 
18 
MR. YAREMA: Object to the form. 
19 
Q And each time E.W. was summoned to 
19 
A Fifth. 
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 
E.W. was an underage minor female, he forced her 
22 
correct? 
22 
to give him oral sex? 
23 
MR. YAREMA: Object to the fonn. 
23 
MR. YAREMA: Object to the form. 
24 
A Filth. 
24 
A Fifth. 
25 
Q If it was not Jeffrey Epstein personally 
25 
Q Do you remember E.W. coming over, a 
27 
29 
1 
calling E.W., you observed 
to call 
1 
young girl, with braces on, and going up into 
2 
E.W. 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 form. 
5 
A Fifth. 
S 
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 
7 
Epstein developed his plan or scheme to gain 
8 
and engage in a threesome with E.W. and Jeffrey 
8 
access to hundreds of underage minor females for 
9 
Epstein? 
9 
the purposes of his sexual gratification? 
10 
MR. YAREMA: Object to the form. 
10 
MR. YAREMA: Object to the form. 
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 E.W. to 
13 
scheme of Jeffrey Epstein's to gain Recess to 
14 
straddle you and otherwise engage sexually with 
14 
underage minor females? 
15 
you while Jeffrey Epstein was using vibrators 
15 
MR. YAREMA: Object to the fonn. 
16 
and/or dildos on you? 
16 
A Fifth. 
17 
MR. YAREMA: Object to the font 
17 
Q Do you know Ghislaine Maxwell? 
18 
A Fifth. 
18 
A Fifth. 
19 
Q in addition to your sexual interactions 
19 
Q Is that somebody who helped Jeffrey 
20 
with E.W., isn't it true that you have used 
20 
Epstein to devise the scheme to allow him access 
21 
strap-on dildos and vibrators on other underage 
21 
to various and n variety of underage minor 
22 
minors at Jeffrey Epstein's direction? 
22 
females? 
23 
MR. YAREMA: Object to the form. 
23 
MR. YAREMA: Object to the form. 
24 
A Fifth. 
24 
A Fifth. 
25 
Q You have given oral sex to underage 
25 
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. YAREM A: Object to the form. 
A Fifth. 
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 true that after an underage 
minor female was brought to Jeffrey F.pstein's 
house, typically 
or Adriana or 
yourself would lead that underage minor female to 
Jeffrey Epstein's bedroom and leave them alone in 
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 fonn. 
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 
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a 
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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 E.W., correct? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q As part of his plan to avoid detection 
by law enforcement, you have observed Jeffrey 
Epstein to pay these underage minor females to he 
quiet, correct? 
MR. YAREMA: Object to the fonn. 
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 fonn. 
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. 
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 fonn. 
A Fifth. 
Q And you have observed Jeffrey Epstein 
using vibrators and sexual toys on underage 
minors, true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q In fact, he has also used vibrators and 
33 
1 
the psychology of brainwashing or grooming 
2 
underage minor females to perform for him 
3 
sexually, hasn't he? 
4 
MR. YAREMA: Object to the form. 
5 
A Fifth. 
6 
Q And Sarah Kellen has also spoken with 
7 
you about the methodology behind gaining access 
8 
to and grooming underage minor females for sex? 
9 
MR. YAREMA: Object to form. 
10 
A Fifth. 
11 
Q Isn't it true that Chislaine Maxwell and 
12 
yourself and 
had access to a master 
13 
list of underage minor females names and phone 
14 
numbers so that they could be called? 
15 
MR. GOLDBERGER: Time out. Are you 
16 
talking to mc, counsel? 
17 
MR. HOROWITZ: Nodding my head, back at 
18 
you. You were nodding at me. 
19 
MR. GOLDBERGER: I wasn't nodding at 
20 
you. I'm not talking to you, I'm not 
21 
communicating with you.. I don't know what 
22 
you think we are doing here. You said "It 
23 
is true," and I have no idea what you are 
24 
talking about. Don't interrupt the 
25 
deposition, okay? 
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MR. HOROWITZ: I think you interrupted. 
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A Fifth. 
2 
MR. GOLDBERGER: I didn't do a thing --
2 
Q In addition to that system, isn't it 
3 
MR. EDWARDS: I don't know what's 
3 
true that Jeffrey Epstein traffics underage minor 
4 
happened here. It has deteriorated here for 
4 
females through a modeling agency? 
5 
no reason whatsoever and has nothing to do 
5 
MR. YAREMA: Object to the form. 
6 
with me 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. 
8 
in with Jean Luc Brunel; you know who that is 
MR. EDWARDS: Can we go back to it. 
9 
right? 
10 
MR. GOLDBERGER: Absolutely. 
10 
MR. YAREMA: Object to the loan. 
11 
MIL EDWARDS: Perfect. 
11 
A Fifth. 
12 
The silent fight disrupted me. I lost 
12 
Q Arc 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 form. 
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, Chislalne 
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 form. 
25 
sexually molested? 
25 
A Fifth. 
35 
37 
1 
MR. YAREMA: Object to the form. 
1 
Q This 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 fonn. 
5 
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, 
MR. YAREMA: Object to the form. 
9 
correct? 
10 
A Fifth. 
10 
MR. YAREMA: Object to the four. 
11 
Q Is that master list saved on a computer 
11 
A Fifth. 
12 
system, as has been testified to in the past? 
1.2 
Q And the modeling agency is but one other 
13 
MR. YAREMA: Object to the fonn. 
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 fonn. 
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? 
2 
them additional money if they will bring hint 
22 
MR. YAREMA: Object to the form. 
3 
other underage minor females to molest; are you 
23 
A Fifth. 
4 
familiar with that system? 
24 
Q And something that you have witnessed 
5 
MR. YAREMA: Object to the form. 
25 
Jeffrey Epstein specifically violate, against 
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E.W., true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Also a statute you have witnessed 
Jeffrey Epstein violate against then minor, 
LM.? 
MR. YAREMA: Object to the font 
1 
2 
3 
4 
5 
6 
7 
40 
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 come forward against him, regarding the 
8 
A Fifth. 
a 
sexual abuse that they endured by him? 
9 
Q In fact L.M. was somebody that Jeffrey 
9 
MR. YAREMA: Object to the font 
10 
Epstein liked or likes; isn't that true? 
10 
A Fifth. 
11 
MR. YAREMA: Object to the fonn. 
11 
Q Would you agree that Jeffrey Epstein 
12 
A Fifth. 
12 
contributed to the delinquency of these various 
13 
Q L.M. was somebody Jeffrey Epstein met 
13 
minors that he sexually abused? 
14 
when she was only 13 years old and began sexually 14 
MR. YAREMA: Object to the font 
15 
molesting her the first day that he met her, 
15 
A Fifth. 
16 
true? 
16 
Q in addition to abusing them, he also 
17 
MR. YAREMA: Object to the form. 
1.7 
encouraged them to return to him to receive more 
18 
A Fifth. 
18 
sexual abuse and encouraged them into a life of 
19 
Q L.M. was one of his main girls, as he 
19 
prostitution, true? 
20 
would call them; is that true? 
20 
MR. YAREMA: Object to the fonn. 
21 
MR. YAREMA: Object to the lone. 
21 
A Fifth. 
22 
A Fifth. 
22 
Q Flow many underage minor females have you 
23 
Q L.M. procured for him or brought for him 
23 
observed Jeffrey Epstein engage in sex acts with 
24 
to his house, over 50 girls between the ages of 
24 
on any of his airplanes? 
25 
12 and 15 years old; is that true? 
25 
MR. YAREMA: Object to the form. 
39 
41 
1 
MR. YAREMA: Object to the form. 
1 
A Fifth. 
2 
A Fifth. 
2 
Q Have you engaged in sexual acts with any 
3 
Q Each of these girls, aged 12 to 15, you 
3 
underage minor females on Jeffrey Epstein's 
4 
observed come into the house, go into Jeffrey 
4 
airplanes? 
5 
Epstein's bedroom and leave the house after being 
5 
MR. YAREMA: Object to the form. 
6 
sexually molested, true? 
6 
A Fifth. 
7 
MR. YAREMA: Object to the form. 
7 
Q How many tines has Jeffrey Epstein 
8 
A Fifth. 
8 
talked to you about the reasons why he sexually 
9 
Q And in addition to L.M. being sexually 
9 
abuses minors? 
10 
molested herself, she was enticed or coerced into 
10 
MR. YAREMA: Object to the form. 
11 
bringing her friends over, to also be sexually 
11 
A Fifth. 
12 
molested, true? 
12 
Q Didn't he tell you that it is his intent 
13 
MR. YAREMA: Object to the form. 
13 
to harm these minors in hopes of gaining 
14 
A Fifth. 
14 
psychological advantage over them? 
15 
Q Has Jeffrey Epstein talked to you about 
15 
MR. YAREMA: Object to the form. 
16 
an FBI statement that was given by L.M.? 
16 
A Fifth. 
17 
A Fifth. 
17 
Q Are you aware that Jeffrey Epstein pled 
18 
Q lie has also told you that that FBI 
18 
guilty to two felonies related to his Interaction 
19 
statement that was favorable for him is 
19 
with minors? 
20 
completely false; isn't that true? 
20 
MR. YAREMA: Object to the form. 
21 
MR. YAREMA: Object to the form. 
21 
A Fifth. 
22 
A Fifth. 
22 
Q And as a result he was incarcerated, and 
23 
Q Has he spoken to you about the fact that 
23 
as we spoke about earlier, you visited hint in 
24 
she is now telling the complete story and 
24 
jail on more than 50 occasions, correct? 
25 
accurate account as to what happened at Jeffrey 
25 
MR. YAREMA: Object to the form. 
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A Fifth. 
Q Aren't your observations with Jeffrey 
Epstein's interactions with E.W., wouldn't you 
agree he coerced her into a life of prostitution? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q And based on your observations of 
Jeffrey Epstein's interactions with L.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 E.W. 
and L.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 E.W., L.M. 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 L.M., E.W. and Jane Doe was 
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Q Do you profit from sex trafficking or 
children? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you know Sergio Cordero? 
A Fifth. 
Q 
A 
Q 
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 fonn. 
A Fifth. 
Q As part of that organization, isn't it 
true that you, as well as various staff members, 
took meticulous messages regarding appointments 
and scheduling underage minor females to come 
over to be sexually molested? 
MR. YAREMA: Object to the form. 
A Fifth. 
Do you know Mike Sanka? 
Fifth. 
Would you consider Jeffrey Epstein's 
43 
likely to cause severe emotional distress? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q And isn't it a fact that Jeffrey Epstein 
has specifically told you that it Is his intent 
to cause severe emotional distress, as it 
weakened his victims? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Ilas 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 lie talked to you about his 
organization being a criminal 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 
trafficking of children? 
MR. YAREMA: Object to the form. 
A Fifth. 
45 
1 
Q 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? 
6 
MR. YAREMA: Object to the form. 
7 
A Fifth. 
8 
Q Since I'm assuming that you are going to 
9 
take the Fifth on each and every question related 
10 
to any messages, I will show you only one, which 
11 
will be marked, this one page, as Plaintiff's 
12 
Exhibit 1. The date on the message that I will 
13 
be showing you is 8/21, August 21, 2005. 
14 
(Message dated August 21,2005 was 
15 
marked as Plaintiff's Exhibit number I for 
16 
identification, as of this date.) 
17 
MR. EDWARDS: Do you want to see it 
18 
first? 
19 
MR. GOLDBERGER: (Counsel examines 
20 
document and hands it to the witness.) 
21 
Q Would you look at the exhibit, please, 
22 
if you can see it? I don't know if you can see 
23 
it over your coffee. 
24 
A I can see it. 
25 
Q Okay. Do you recognize it? 
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A Filth. 
Q That particular message indicates it is 
from 
You're the only 
In the 
house; is that correct? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q This is a call from you indicating that 
'1= 
cannot work today 
be 
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2 
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48 
Ghisiaine Maxwell's sexual interaction with Jane 
Doe-102 when she was a minor? 
MR. YAREMA: Object to the fonn. 
Q This is one of many underage minor 
females that was trafficked basically around the 
globe to be sexually exploited and abused; is 
that correct? 
MR. YAREMA: Object to the fonn. 
here at 4:00 p.m.;" Is that right? 
9 
A Fifth. 
10 
MR. YAREMA: Object to the form? 
10 
Q Was that typical of Jeffrey Epstein and 
11 
A Fifth. 
11 
Ghisiaine Maxwell to sexually abuse minors on 
12 
Q Who Is =? 
12 
Jeffrey Epstein's airplane? 
13 
A Fifth. 
13 
MR. YAREMA: Object to the form. 
14 
MR. YAREMA: Object to the form. 
14 
A Fifth. 
15 
Q That's an underage minor female that was 
15 
Q And also typical of Ghislaine Maxwell 
16 
scheduled to be molested at Jeffrey Epstein's 
16 
and Jeffrey Epstein to prostitute or pimp out 
17 
house? 
17 
underage minors to friends? 
18 
MR. YAREMA: Object to the Iona. 
18 
MR. YAREMA: Object to the form. 
19 
A Fifth. 
19 
A Fifth. 
20 
Q You scheduled that act of molestation; 
20 
Q By "friends," lent talking specifically 
21 
is that right? 
21 
about people of royalty, politicians, 
22 
MR. YAREMA: Object to the form. 
22 
academicians, businessmen and other professional 
23 
A Fifth. 
23 
or personal acquaintances? 
24 
Q And Britney will be at the house at 4:00 
24 
MR. YAREMA: Object to the fonn. 
25 
pan. Britney is another underage minor female; 
25 
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 many occasions have you observed 
8 
MR. YAREMA: Object to the form. 
8 
Jeffrey Epstein to receive as gifts front friends, 
9 
A Fifth. 
underage minor females for the purposes of hint 
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 form. 
14 
France. Were they sent to hint 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. YAREMA: Object to the form. 
25 
Q Are you aware of Jeffrey Epstein and 
25 
A Fifth. 
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22 
23 
24 
25 
Q As part of being Jeffrey Epstein's sex 
slave, isn't it true that he asks you or requests 
of you to dress younger than 12 at times? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Have you seen naked photographs of the 
underage minor females with whom Jeffrey Epstein 
has engaged in sex acts? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Are there hidden cameras in any of 
Jeffrey Epstein's homes, that you know to have 
taken surreptitious videos or photographs of 
underage minors? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Does Jeffrey Epstein still watch 
pornography to this day? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Does Jeffrey Epstein watch homemade 
pornographic videos of underage minors engaging 
in sex orgies on his island? 
MR. YAREMA: Object to the form. 
A Fifth. 
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25 
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1 
A Fifth. 
2 
Q Do you know Bill Riley? 
3 
A Fifth. 
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Q Have you seen the flight logs front 
5 
Jeffrey Epstein's private airplane flights? 
6 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Are you aware that you're listed as a 
passenger on many flights, along with Jeffrey 
Epstein on his private airplane? 
MR. YAREMA: Object to the form. 
2 
A Fifth. 
Q Certainly comes as no surprise to you, 
since you were on his airplane on numerous 
occasions, correct? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q On September 22,2003, you were listed 
as being on a flight with Ma 
Jeffrey 
0 
Epstein, 
S.H. and B.T. My question 
is who is S.H. and who is B.T.? 
MR. YAREMA: Object to the font. 
A Fifth. 
Q Do you know 
A Fifth. 
51 
1 
Q Prior to the search warrant being 
2 
executed, you are aware that at least three 
3 
computers were taken at Jeffrey Epstein's 
direction, from Jeffrey Epstein's house, to avoid 
5 
detection by law enforcement, correct? 
6 
MR. YAREMA: Object to the form. 
7 
A Correct. 
8 
Q Adriana 
and some other person 
took those computers to avoid Jeffrey Epstein —
to avoid the authorities obtaining the evidence 
contained on those computers, correct? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Who are the persons along with Adriana 
took the computers front Jeffrey 
Epstein's house prior to the execution of the 
search warrant? 
YAREMA: Object to the form. 
A Fifth. 
Q Where are those computers today? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Were they taken by his investigator, 
BM Riley? 
MR. YAREMA: Object to the form. 
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Q That's somebody that you're familiar 
with, because you have been to Jeffrey Epstein's 
house on many occasions with 
correct? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q In fact, do you remember there being a 
burglary of Jeffrey Epstein's house where he 
actually called the police to investigate the 
burglary? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q And during the police investigation 
inside Jeffrey Epstein's house, you were speaking 
with 
both in person, at Jeffrey 
Epstein's house, correct? 
MR. YAREMA: Object to the fonn. 
A Correct. 
Q Is this another person that Jeffrey 
Epstein, when she was a minor, violated 
sexually? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you still speak withl
? 
MR. YAREMA: Object to the form. 
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A Fifth. 
Q Do you know Bill Clinton? 
A Fifth. 
Q You have been on Jeffrey Epstein's 
airplane with Bill Clinton? 
MR. YAREMA: Object to the fonn. 
1 
2 
3 
4 
5 
6 
56 
Jeffrey Epstein specifically flew to Palm Beach 
for the purposes of engaging in sex acts with 
Jane Doe? 
MR. YAREMA: Object to the form. 
A Fifth. 
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 
Epstein's airplane with Doug Band, Bill Clinton's 
8 
engaging in sexual activity with minors at his 
destination? 
10 
righthand man? 
10 
MR. YAREMA: Object to the form. 
1/. 
MR. YAREMA: Object to the fonn. 
11 
A Fifth. 
12 
A Filth. 
12 
Q Isn't it true that he employed numerous 
13 
Q Have 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 fowl. 
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 form. 
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 fonn. 
25 
sex with? 
25 
A Fifth. 
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57 
1 
MR. YAREMA: Object to the form. 
1 
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 Aline Weber? 
5 
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 E.W. was in Jeffrey 
victim at one point In time of Jeffrey Epstein 
8 
Epstein's bedroom getting sexually abused, 
9 
and Jean Luc Brunei? 
9 
correct? 
10 
MR. YAREMA: Object to the form. 
10 
MR. YAREMA: Object to the form. 
11 
A Fifth. 
11 
A Fifth. 
12 
Q Between 2002 and 2005 when E.W. 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 L.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 E.W.? 
15 
bedroom, correct? 
16 
MR. YAREMA: Object to the fonn. 
16 
MR. YAREMA: Object to the form. 
17 
A Fifth. 
17 
A Fifth. 
18 
Q And between those same years of 2002 and 
18 
Q Generally, Alan Dershowitz is familiar 
19 
2005, Isn't It true that Jeffrey Epstein took 
19 
with Jeffrey Epstein's habit of engaging in 
20 
airplane flights to Palm Beach front places 
20 
sexual acts with minors on a daily basis, 
21 
outside of the State, to engage in sexual acts 
21 
correct? 
22 
with L.M.? 
22 
MR. YAREMA: Object to the form. 
23 
MR. YAREMA: Object to the form. 
23 
A Fifth. 
24 
A Fifth. 
24 
Q When Alan Dershowitz was in town, 
25 
Q From 2003 through 2005, isn't it true 
25 
Jeffrey Epstein did not break his schedule for 
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Alan Dershowit, meaning he continued to sexually 
abuse minors despite Alan Dershowitz being a 
guest in the house? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Alan Dershowitz never engaged in any 
sexual activity with these underage minors; isn't 
that true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Have you been made to have sex with 
Ghislaine Maxwell? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you know Emmy Taylor? 
A Fifth. 
Q Similar to you being Jeffrey Epstein's 
sex slave, is Emmy Taylor, or was Emmy Taylor 
Ghislaine Maxwell's sex slave? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Ghislaine Maxwell is somebody who you 
know to be bi-sexual, true? 
MR. YAREMA: Object to the form. 
A Fifth. 
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Q What was the purpose of that flight? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did you sign a confidentiality agreement 
with Jeffrey Epstein? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q When is the last time that you observed 
Jeffrey Epstein have sex with a minor? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Since being on probation, has Jeffrey 
Epstein been able to, or has he flown to his 
Island? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q To your knowledge, has Jeffrey Epstein 
flown to New York while on probation or community 
control? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Isn't it true that he has flown both to 
New York and to his island, and you have 
accompanied hint on those trips, since he was on 
community control? 
59 
1 
Q You know that Ghislaine Maxwell engaged 
2 
in sexual acts with underage minor females, true? 
3 
MR. YAREMA: Object to the fonn. 
4 
A Fifth. 
5 
Q This is yet another friend of Jeffrey 
6 
Epstein's that is into the act of molesting 
underage minor females, right? 
8 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Nov, you are the next participant In 
that activity, meaning you have been groomed to 
enjoy and appreciate the acts of sex with 
underage minors, true? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Has Jeffrey Epstein instructed you to 
lie to his Probation Officer in any way? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Mr. Visoskl testified that you took a 
helicopter flight within the last year with 
Jeffrey Epstein to Miami. Do you remember that 
flight? 
MR. YAREMA: Object to the form. 
A Fifth. 
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MR. YAREMA: Object to the form. 
A Fifth. 
Q Isn't It also true that Jeffrey Epstein 
has Indicated to you that he will always engage 
in sex acts with underage minor females? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q In fact, that's something that he has 
told you, that he believes he Is entitled to do; 
isn't that right? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Isn't It true that Jeffrey Epstein 
believes and has told you that if he doesn't 
physically force the underage minor female into 
any act, then he is entitled to engage in sex 
with any underage minor female despite the age? 
MR. YAREMA: Object to the lone. 
A Fifth. 
Q What is the youngest female you have 
witnessed or observed Jeffrey Epstein to engage 
in sex with? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Do you have a bank account at Chase Bank 
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in New York? 
2 
A Fifth. 
3 
Q And the money In that bank account under 
4 
your name is money that was given to you by 
5 
Jeffrey Epstein, correct? 
6 
MR. YAREMA: Object to the form. 
7 
A Fifth. 
8 
Q For the passed ten or so years, you have 
9 
lived with Jeffrey Epstein under his control, 
10 
right? 
11 
MR. YAREMA: Object to the font 
12 
A Fifth. 
13 
Q You get to lead the life of a 
14 
millionaire, and to lead that life, you were only 
15 
required to be Jeffrey Epstein's sex slave and to 
16 
bring Jeffrey Epstein other slaves? 
17 
MR. YAREMA: Object to the font 
18 
A Fifth. 
19 
Q Is this 301 East 66th Street apartment 
20 
still an apartment that you frequent today? 
21 
MR_ YAREMA: Object to the form. 
22 
A Fifth. 
23 
Q And you're familiar with the nine or ten 
24 
apartments that Jeffrey Epstein owns or controls 
25 
up there at 301 East 66th Street, aren't you? 
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Q That's somebody who these days refers to 
himself as Jeffrey Epstein's personal assistant, 
right? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q That's somebody who you know to work for 
or at the Florida Science Foundation, which is 
owned by Jeffrey Epstein, correct? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q It Is also somebody that you know to 
have stayed at Jeffrey Epstein's house with 
correct? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q This is somebody that has been 
involved — Story Cowles is somebody who's been 
involved sexually with 
for at least 
a year, right? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q In fact, you know that they took a trip 
around the world together and during that trip 
they discussed Jeffrey Epstein and his 
interaction with underage minor females, 
63 
1 
MR. YAREMA: Object to the font 
2 
A Fifth. 
3 
Q At any given time, there are between 8 
4 
and 16 underage minors living in or staying at 
5 
those apartments? 
6 
MR. YAREMA: Object to the form. 
7 
A Fifth. 
8 
Q On the various passenger lists on 
9 
Jeffrey Epstein's airplane, where it will list, 
10 
for instance, Jeffrey Epstein, 
11 
12 
13 
14 
15 
16 
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18 
19 
20 
21 
22 
23 
24 
5 
going from Florida to St. 
Thomas, then generically, female, female; would 
you know who those female, females are? 
MR_ YAREMA: Object to the fonn. 
A Fifth. 
Q Are those females listed generically 
rather than specifically because they are 
underage minor females engaging in sex with you 
or Jeffrey Epstein? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Is Story Cowles someone that you see on 
a regular basis at Jeffrey Epstein's house? 
MR. YAREMA: Object to the font 
A Fifth. 
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65 
correct? 
MR. YAREMA: Object to the font 
A Fifth. 
MR. EDWARDS: Done. I don't have 
anything else. 
MR. GOLDBERGER: Okay. 
MR. HOROWITZ: I do, why don't we take a 
short break. 
MR. GOLDBERGER: We are stopping at 
I I:50. 
MR. HOROWITZ: What? 
MR. GOLDBERGER: 11:50. 
MR. HOROWITZ: I kind of remember that 
e-mail. 
THE VIDEOGRAPHER: Off the video record. 
(Pause in the proceedings.) 
THE VIDEOGRAPHER: We are back on the 
video reconl at 11:18 a.m.) 
(At this time Robert Critton joined the 
proceedings.) 
CROSS EXAMINATION 
BY MR. HOROWITZ: 
Q Ms.
 between 2001 and 2006, 
did Jeffrey Epstein instruct you to place 
telephone calls to arrange for girls under the 
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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, 
1 
2 
3 
4 
5 
68 
A Fifth. 
Q Did Jeffrey Epstein admit to you that he 
sexually abused Y.L. in his Palm Beach home in 
2004? 
MR. YAREMA: Object to the form. 
6 
place telephone calls to arrange for girls under 
A Fifth. 
7 
the age of 18 to come to Jeffrey Epstein's home 
7 
Q Did you ever instruct a girl named 
8 
for his sexual gratification? 
a 
to bring other underage girls to Jeffrey
9 
MR. YAREMA: Object to the form. 
9 
Epstein's home for Jeffrey Epstein's sexual 
10 
A Fifth. 
10 
pleasure? 
11 
Q Are you personally aware that a girl 
11 
MR. YAREMA: Object to the form. 
12 
named M.L. came to Jeffrey Epstein's Palm Beach 12 
A Filth. 
13 
home in late 2004? 
13 
Q In 2004 did you communicate by telephone 
14 
YAREMA: Object to the form. 
14 
with nor 
the purpose of bringing 
15 
A Fifth. 
15 
V.1.. to Jeffrey Epstein's home for sexual 
16 
Q Did Jeffrey Epstein admit to you he 
16 
activity MR. YAREMA: Object to the fora. 
17 
sexually abused M.L.? 
17 
A Fifth. 
18 
MR. YAREMA: Object to the form. 
18 
Q Did Jeffrey Epstein instruct you to 
19 
A Fifth. 
19 
communicate with 
for the purpose of 
20 
Q Isn't It true in late 2004 you made 
20 
making arrangements for Y.L. to come to his home? 
21 
arrangements by telephone to bring M.L. to 
21 
MR. YAREMA: Object to the form. 
22 
Jeffrey Epstein's home? 
22 
A Fifth. 
23 
MIL YAREMA: Object to the form. 
23 
Q Did Jeffrey Epstein tell you it was his 
24 
A Fifth. 
24 
intent during the course of Y.L.'s visit to his 
25 
Q Did Jeffrey Epstein instruct you to 
25 
home to persuade, induce or entice her to engage 
67 
69 
1 
communicate by telephone to arrange for M.L. to 
1 
in sexual activity with him? 
2 
come to his home for his sexual gratification? 
2 
MR. YAREMA: Object to the form. 
3 
ML YAREMA: Object to the form. 
3 
A Fifth. 
4 
A Fifth. 
4 
Q Did Jeffrey Epstein admit to you that he 
5 
Q Did Jeffrey Epstein inform you that M.L. 
5 
had succeeded in, in fact, persuading, inducing 
6 
would be giving him a massage that was sexual in 
6 
or enticing Y.L. to engage in sexual activity 
7 
nature? 
7 
with hint? 
8 
MR. YAREMA: Object to the form. 
8 
MR. YAREMA: Object to the form. 
A Fifth. 
9 
A Fifth. 
10 
Q Did Jeffrey Epstein tell you it was his 
10 
Q Are you personally aware that a teenage 
11 
intent during the course of M.L.'s visit to his 
11 
girl named 
came to Jeffrey Epstein's Palm 
12 
home to persuade, induce or entice her to engage 
12 
Beach home on multiple occasions between 2003 and 
13 
in sexual activity? 
13 
2005? 
14 
MR. YAREMA: Object to the fount 
14 
MR. YAREMA: Object to the form. 
15 
A Fifth. 
15 
A Fifth. 
16 
Q Did Jeffrey Epstein tell you that, in 
16 
Q Did Jeffrey Epstein admit to you that he 
17 
fact, he succeeded in persuading, inducing or 
17 
sexually abused 
18 
enticing M.L. to engage in sexual activity with 
18 
MR. YAREMA: Object to the form. 
19 
him? 
19 
A Fifth. 
20 
MR.. YAREMA: Object to the form. 
20 
Q At any time prior to May of 2005, did 
21 
A Fifth. 
21 
Jeffrey Epstein instruct you to place telephone 
22 
Q Are you personally aware that a girl 
22 
calls to 
for the purpose of arranging for 
23 
named Y.L. came to Jeffrey Epstein's Palm Beach 23 
her to come to his home and engage in sexual 
24 
home on multiple occasions in 2004? 
24 
activity? 
25 
MR. YAREMA: Object to the form. 
25 
MR. YAREMA: Object to the form. 
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1 
A Fifth. 
2 
Q Did you, in fact, communicate by 
3 
telephone with 
for the purpose of arranging 
4 
for her to come to his home for sexual activity? 
5 
MR. YAREMA: Object to the form. 
6 
A Fifth. 
7 
Q At any time prior to May of 2005, did 
8 
you place a telephone call to 
wherein you arranged for M. to come to Jeffrey 
Epstein's home for sexual activity? 
MR. YAREMA: Object to the fonn. 
A Fifth. 
Q Prior to May of 2005, did you ever 
observe 
speaking with 
by 
telephone to arrange for N. 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 M. 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 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
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9 
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15 
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17 
18 
19 
20 
21 
22 
23 
24 
25 
in either 2001 or 2002? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did you, in fact, call A.G. to come to 
Jeffrey Epstein's home and give him a massage in 
a sexual nature in 2001 or 2002? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Dld you either observe or overhear-
-
speaking with A.C. on the telephone to 
arrange for A.C. to conic to Jeffrey Epstein's 
home for a massage of a sexual nature? 
MR. YAREMA: Object to the Iona. 
A Fifth. 
Q Did Jeffrey Epstein tell you it was his 
intent during the course of A.G.'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 
A.G. to engage in sexual activity with him at his 
home while she was still a minor? 
MR. YAREMA: Object to the form. 
71 
while she was still a minor, at his home? 
MR. YAREMA: Object to the loon. 
A Fifth. 
Q Are you personally aware that n teenage 
girl named an A.C., 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 A.C.. at his home while she was 
still a child? 
MR. YAREMA: Object to die fonn. 
A Fifth. 
Q In 2001 or 2002, did 
inform 
you that she received a telephone call in which 
she was referred to A.C., who would be willing to 
tome to Jeffrey Epstein's home for sexual 
activity? 
MR. YAREMA: Object to the form. 
A Fifth. 
(Whereupon, at this point in the 
proceedings, Robert Griffon left the 
deposition room.) 
Q Did Jeffrey Epstein instruct you to call 
A.C. to come to his home and give him a massage 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
73 
A Fifth. 
Q Are you personally aware that a girl 
named M. came to Jeffrey Epstein's home in 
approximately August 2004? 
MR. YAREMA: Object to the font 
A Fifth. 
Q Did Jeffrey Epstein admit to you that he 
had sexually abused 
when she was only 13 
years old? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q In 2004 did you participate In a 
telephone call wherein you arranged for M. to 
come to Jeffrey Epsteln'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 arrangements 
for M. to come to his home for sexual activity 
while she was still a child? 
MR. YAREMA: Object to the form. 
A Fifth. 
Q Did Jeffrey Epstein tell you it was his 
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intention during the course of M.'s Ash to 
1 
76 
MR. YAREMA: Object to the (ben. 
2 
his home to persuade, induce or entice her to 
2 
A Fifth. 
3 
engage in sexual activity with him? 
3 
Q Did you participate in a telephone call 
4 
MR. YAREMA: Object to the form. 
4 
wherein you arranged for J.M. to come to Jeffrey 
5 
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 SUCCCC(iCli in persuading, inducing and 
7 
A Fifth. 
a 
enticing M. to engage In sexual activity with 
8 
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 J.M. to come to his home for 
11 
A Fifth. 
11 
sexual activity? 
12 
Q Are you personally aware that a girl 
12 
MR. YAREMA: Object to the form. 
13 
named F.P. came to Jeffrey Epstein's boost 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 ofJ.M.'s visit 
16 
MR. YAREMA: Object to the form. 
16 
to his home, to engage her in sexual activity 
17 
A Fifth. 
17 
while she was still a child? 
16 
Q Did Jeffrey Epstein admit to you that he 
18 
MR. YAREMA: Object to the form. 
19 
sexually abused F.P. 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 J.M. 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 from a girl named 
wherein 24 
MR. YAREMA: Object to the form. 
25 
she told you she ,vas bringing F.P. to Jeffrey 
25 
A Fifth. 
75 
77 
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 I= 
5 
MR. GOLDBERGER: Fine, that will bring 
6 
by telephone to make arrangements for F.P. 
6 
us right to the break. 
7 
to conic to his home? 
7 
CROSS EXAMINATION 
8 
MR. YAREMA: Object to the form. 
BY MR. LANGINO: 
A Fifth. 
9 
Q I'm Adam Langino and I represent B.R. 
10 
Q Prior to F.P.'s visits to Jeffrey 
10 
and C.L. 
11 
Epstein's home, did Jeffrey Epstein tell you it 
11 
Do you know an individual named B.B.? 
12 
was his intention to induce, entice and engage 
12 
A Fifth. 
13 
F.P., to engage in sexual activity with him? 
13 
Q Do you know an individual named C.L.? 
14 
MR. YAREMA: Object to the form. 
14 
A Fifth. 
15 
A Fifth. 
15 
Q Have you seen B.B. at the defendant's 
16 
Q After F.P.'s 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 
F.P. to engage in sexual activity with him while 
19 
Q Have you seen C.L. at the defendant's 
20 
she was still a child? 
20 
Palm Beach property? 
21 
MR. YAREMA: Object to the form. 
21 
MR. YAREMA: Object to the form. 
22 
A Fifth. 
22 
A Fifth. 
23 
Q Arc you personally aware that n teenage 
23 
Q Have you ever engaged in a sexual act 
24 
girl named J.M. came to Jeffrey Epstein's Paint 
4 
with B.B.... B.B.? 
25 
Beach home in approximately 2001 or 2002? 
5 
MR. YAREMA: Object to the form. 
20 (Pages 74 to 77) 
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