EFTA00182418

10 
masturbate with his right hand, correct? 
11 
A. I refuse to answer. 
12 
Q. And then he would begin also grabbing the 
13 
breasts, buttocks, and vagina area of these underage 
14 
minor females, correct? 
15 
A. I refuse to answer. 
16 
MR. PIKE: Form. 
17 
Q. And his ritual was so specific that with each 
18 
of them he would demand that they pinch his nipples 
19 
very hard, right? 
20 
MR. PIKE: Form. 
21 
A. I refuse to answer. 
22 
Q. That's a fetish that you know that Jeffrey 
23 
Epstein has, right, he likes his nipples pinched very 
24 
hard? 
25 
MR. PIKE: Form. 
0049 
1 
A. I refuse to answer. 
2 
Q. And as he's masturbating with one hand and has 
3 
his other hand groping or inserting his fingers into 
4 
the underage minor's vagina he's also telling them to 
5 
pinch his nipples, correct? 
6 
MR. PIKE: Form. 
7 
A. I refuse to answer. 
8 
Q. And this continues -- and sometimes this 
9 
escalates to him using vibrators, correct? 
10 
MR. PIKE: Form. 
11 
A. I refuse to answer. 
12 
Q. And have you seen vibrators in the Palm Beach 
13 
mansion house? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. And other times he orders 
to 
17 
participate in these encounters with underage minor 
18 
females; is that correct? 
19 
A. I refuse to answer. 
20 
Q. Are you familiar with 
21 
strapping on dildos to have sex with these underage 
22 
minor females? 
23 
MR. PIKE: Form. 
24 
A. I refuse to answer. 
25 
Q. And when Miss Marcinkova would have sex with 
0050 
1 
the underage minor females Jeffrey Epstein would watch 
2 
and continue to ejac -- continue to masturbate, 
3 
correct? 
4 
MR. PIKE: Form. 
5 
A. I refuse to answer. 
6 
Q. Has he ever asked you to participate in these 
7 
threesomes with underage minor females? 
8 
A. I refuse to answer. 
9 
MR. PIKE: Form. 
10 
Q. Have you ever participated in sex with 
11 
underage minor females at the direction of Jeffrey 
12 
Epstein? 
13 
MR. PIKE: Form. 
14 
A. I refuse to answer. 
15 
Q. The -- this whole experience that I am 
16 
explaining right now is identical every single time 
17 
with these underage minor females; isn't that your 
18 
understanding? 
19 
MR. PIKE: Form. 
20 
A. I refuse to answer. 
EFTA00182438

21 
Q. And this whole experience is what he has 
22 
taught you and the other employees to call a "massage", 
23 
correct? 
24 
MR. PIKE: Form. 
25 
A. I refuse to answer. 
0051 
1 
Q. And it always ends with him ejaculating? 
2 
A. I refuse to answer. 
3 
MR. PIKE: Form. 
4 
Q. And then he offers 200 to $300 cash to the 
5 
underage minor female, correct? 
6 
MR. PIKE: Form. 
7 
A. I refuse to answer. 
8 
Q. And then he also gives them another 
another 
9 
option to make money which is each time you come to my 
10 
house and we engage in this sexual interaction I will 
11 
give you $200, but each female you bring me like you, 
12 
between the age range of 12 and 16, I will pay you $200 
13 
per person. 
14 
MR. PIKE: Form. 
15 
Q. Is that something you're familiar with? 
16 
A. I refuse to answer. 
17 
Q. And LM at that offer was one of the girls who 
18 
brought him 75 plus underage minor females, correct? 
19 
MR. PIKE: Form. 
20 
A. I refuse to answer. 
21 
Q. And so he's basically created a pyramid of 
22 
underage minor females where the computer system has a 
23 
thousand of these females ready to come over to work 
24 
for him? 
25 
MR. PIKE: Form. 
0052 
1 
A. I refuse to answer. 
2 
Q. Do you know what Jeffrey Epstein does for a 
3 
living? 
4 
A. 
5 
Q. 
aside from interacting 
6 
sexually 
females? 
7 
8 
A. 
9 
Q. 
his money 
10 
where he 
11 
A. 
12 
13 
14 
15 
16 
into 
17 
females? 
18 
A. I refuse to answer. 
19 
Q. Do you know Martin Nowak? 
20 
A. I refuse to answer. 
21 
Q. Is that also somebody that would interact 
22 
sexually with underage minor females? 
23 
A. I refuse to answer. 
24 
Q. Do you know Leslie Wexner? 
25 
A. I refuse to answer. 
0053 
1 
Q. Is that somebody you've met before? 
2 
A. I refuse to answer. 
3 
Q. Has Mr. Epstein himself interacted sexually 
I refuse to answer. 
Does he do anything 
with underage minor 
MR. PIKE: Form. 
I refuse to answer. 
Do you know how it is that he made 
is purported to be a billionaire? 
I refuse to answer. 
MR. PIKE: Form. 
Q. Do you know David Copperfield? 
A. I refuse to answer. 
Q. Is David Copperfield somebody that would come 
town and interact sexually with underage minor 
4 
with Leslie Wexner? 
5 
MR. PIKE: Form. 
EFTA00182439

6 
A. I refuse to answer. 
7 
Q. When Mr. Epstein was being investigated 
8 
criminally how did you first learn about that? 
9 
A. I refuse to answer. 
10 
Q. At some point in time he was tipped off that 
11 
his home -- that a search warrant was going to be 
12 
executed on his home, correct? 
13 
MR. PIKE: Form. 
14 
A. I refuse to answer. 
15 
Q. And just a month before the execution of that 
16 
search warrant -- less than a month before the 
17 
execution of that search warrant he ordered you to do 
18 
something with certain evidence, didn't he? 
19 
MR. PIKE: Form. 
20 
A. I refuse to answer. 
21 
Q. In fact, there were at least three very key 
22 
computers that contained a lot of the information that 
23 
I've been asking you about. You're familiar with those 
24 
computers that were in his house, correct? 
25 
MR. PIKE: Form. 
0054 
1 
A. I refuse to answer. 
2 
Q. And he ordered you to come over and take those 
3 
computers out of his house, correct? 
4 
A. I refuse to answer. 
5 
MR. PIKE: Form. 
6 
Q. And you could basically take the local 
7 
database that exposed this criminal enterprise that 
8 
I've been talking about dealing with sex with underage 
9 
minor vehicles -- underage minor females and you could 
10 
take the evidence from his home, correct? 
11 
MR. PIKE: Form. 
12 
A. I refuse to answer. 
13 
Q. And you've seen the material that's on those 
14 
computers, correct? 
15 
MR. PIKE: Form. 
16 
A. I refuse to answer. 
17 
Q. And if I were to look at those computers it 
18 
would display exactly what I've been describing to you 
19 
today, right? 
20 
MR. PIKE: Form. 
21 
A. I refuse to answer. 
22 
Q. And you went to his house with a male, 
23 
correct? 
24 
A. I refuse to answer. 
25 
MR. PIKE: Form. 
0055 
1 
Q. There was one other guy with you that helped 
2 
that assisted you to take these computers from his 
3 
home; is that right? 
4 
MR. PIKE: Form. 
5 
A. I refuse to answer. 
6 
Q. Where did you take those? 
7 
A. I refuse to answer. 
8 
Q. Did you take those -- was it Bill Reilly that 
9 
went to the home? 
10 
A. I refuse to answer. 
11 
Q. Do you know who Bill Reilly is? 
12 
A. I refuse to answer. 
13 
Q. He's one of the investigators hired by Roy 
14 
Black to represent Jeffrey Epstein? 
15 
A. I refuse to answer. 
16 
Q. Did you take those computers ever to your 
EFTA00182440

17 
house? 
18 
A. I refuse to answer. 
19 
Q. And I uess the house that I would be talking 
20 
about is the 
have those 
21 
computers ever been to that house? 
22 
MR. PIKE: Form. 
23 
A. I refuse to answer. 
24 
Q. Were you nervous about the fact that you were 
25 
taking these computers out of the home at a time when a 
0056 
1 
search warrant was imminent? 
2 
A. I refuse to answer. 
3 
Q. Did you ever question when you were directed 
4 
to take these computers from his home? 
5 
A. I refuse to answer. 
6 
Q. How much additional money or bonus were you 
7 
paid to take the computers that we're talking about out 
8 
of Jeffrey Epstein's house? 
9 
MR. PIKE: Form. 
10 
A. I refuse to answer. 
11 
Q. Would those computers reveal criminal activity 
12 
of only Jeffrey Epstein or of others? 
13 
MR. PIKE: Form. 
14 
A. I refuse to answer. 
15 
Q. Did you talk with 
about the 
16 
criminal investigation into Jeffrey Epstein and others? 
17 
A. I refuse to answer. 
18 
Q. Well, at some point in time what's been marked 
19 
as Defense Exhibit 1, you received a Grand Jury 
20 
investigation target letter, correct? 
21 
A. I refuse to answer. 
22 
Q. Well, we have it right here. I'm familiar 
23 
with it. I know you got the letter and I know that, 
24 
you know, the substance of it you're not going to tell 
25 
me about. But this letter is dated August 31st, 2007, 
0057 
1 
the search warrant was executed on his home back in 
2 
October of 2005. So during those two years leading up 
3 
to this target letter who did you talk to? 
4 
A. I refuse to answer. 
5 
Q. Did you --
6 
MR. ROSS: And privilege. Attorney-client 
7 
privilege. 
8 
Q. Okay. In addition to your attorney did you 
9 
talk to anybody else about the criminal investigation? 
10 
A. I refuse to answer. 
11 
Q. And Bruce Lyons was your initial computer --
12 
computer -- was your initial attorney in this case, 
13 
correct? 
14 
MR. ROSS: You can answer yes or no. 
15 
A. Yes. 
16 
Q. Okay. And that was an attorney that was hired 
17 
for you by Jeffrey Epstein? 
18 
MR. ROSS: Invoke. 
19 
A. I refuse to answer. 
20 
Q. Someone that was paid for by Jeffrey Epstein 
21 
to represent you? 
22 
MR. PIKE: Form. 
23 
A. I refuse to answer. 
24 
Q. So once he hired you a criminal attorney then 
25 
it seemed like you did something wrong? 
0058 
1 
MR. PIKE: Form. 
EFTA00182441

2 
A. I refuse to answer. 
3 
Q. You hadn't actually gone into any relationship 
4 
with Jeffrey Epstein with the intent to commit crimes, 
5 
did you? 
6 
A. I refuse to answer. 
7 
Q. You didn't know that he was a child molester 
8 
when you first met him, did you? 
9 
MR. PIKE: Form. 
10 
A. I refuse to answer. 
11 
Q. Were you impressed by his money and his 
12 
lifestyle? 
13 
A. I refuse to answer. 
14 
Q. Did you think that he could get you further in 
15 
life if you would just listen to what he said? 
16 
MR. PIKE: Form. 
17 
A. I refuse to answer. 
18 
Q. At this point in time you have no contact with 
19 
him as a child molester, do you? 
20 
MR. PIKE: Form. 
21 
A. I refuse to answer. 
22 
Q. Did Jeffrey Epstein assist in getting you a 
23 
visa? 
24 
A. I refuse to answer. 
25 
MR. PIKE: Form. 
0059 
1 
Q. Has he done any favors for your family? 
2 
A. I refuse to answer. 
3 
MR. PIKE: Form. 
4 
Q. Is he paying for your college? 
5 
A. I refuse to answer. 
6 
MR. PIKE: Form. 
7 
Q. Right now is he paying for your college? 
8 
MR. ROSS: Invoke. 
9 
A. I refuse to answer. 
10 
MR. PIKE: Form. 
11 
Q. Did Jeffrey Epstein ever talk to you about the 
12 
chances of him going to prison? 
13 
A. I refuse to answer. 
14 
MR. PIKE: Form. 
15 
Q. Did Jeffrey Epstein ever talk to you about 
16 
what he intended his defenses to be to the criminal 
17 
actions he committed against these underage minors? 
18 
A. I refuse to answer. 
19 
MR. PIKE: Form. 
20 
Q. Did he tell you that he would spend as much 
21 
money as possible to intimidate and harass these 
22 
underage minor victims? 
23 
A. I refuse to answer. 
24 
MR. PIKE: Form. 
25 
Q. Did he tell you that he would destroy their 
0060 
1 
credibility? 
2 
A. I refuse to answer. 
3 
Q. Did he tell you that he could scare them to go 
4 
away? 
5 
A. I refuse to answer. 
6 
MR. PIKE: Form and form to the last question. 
7 
MR. EDWARDS: All right. Let's see, what did 
8 
I say, I said this was --
9 
MR. ROSS: 1. 
10 
MR. EDWARDS: -- Plaintiff's 1 and we're going 
11 
to write on the back of it and then -- okay. 
12 
Q. Jeffrey Epstein kept message pads near all of 
EFTA00182442

13 
his phones in his home, right? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. And those are message pads that have a carbon 
17 
copy back side to them, you're familiar with them? 
18 
MR. PIKE: Form. 
19 
A. I refuse to answer. 
20 
Q. And this is for anybody who takes a message 
21 
they write it down that somebody called, the reason for 
22 
calling, the time that they called? 
23 
MR. PIKE: Form. 
24 
A. I refuse to answer. 
25 
Q. And many a times anytime that Jeffrey Epstein 
0061 
1 
was in town there were at least two scheduled 
2 
"massages" for lack of a better word, with Jeffrey 
3 
Epstein and these underage minor females, correct? 
4 
A. I refuse to answer. 
5 
MR. PIKE: Form. 
6 
Q. And do you have the -- and there was a 
7 
particular scheduling book that contained these 
8 
appointments with -- between Jeffrey Epstein and 
9 
underage minor females, correct? 
10 
MR. PIKE: Form. 
11 
A. I refuse to answer. 
12 
Q. And it was your primary responsibility to 
13 
assist 
in setting these appointments up, 
14 
right? 
15 
A. I refuse to answer. 
16 
MR. PIKE: Form. 
17 
Q. It took at least two or three full-time 
18 
employees to keep up with Jeffrey Epstein's addiction 
19 
to underage minors, correct? 
20 
A. I refuse to answer. 
21 
MR. PIKE: Form. 
22 
Q. 
did pretty much the same thing up 
23 
in New York, right? 
24 
MR. PIKE: Form. 
25 
A. I refuse to answer. 
0062 
1 
Q. And you're familiar that there is this group 
2 
of girls in New York that were summoned to his home for 
3 
generally the exact same thing as the Palm Beach girls? 
4 
A. I refuse to answer. 
5 
Q. All right. 
6 
MR. PIKE: Form. 
7 
Q. I'm going to show you an exhibit here, we'll 
8 
mark it as -- you know what, it's a bunch of message 
9 
pads, I'm going to mark it as 2A, -B, -C, -D, whatever. 
10 
So we'll say 2A. 
11 
(Whereupon, Plaintiff's Exhibit 2A through 2H 
12 
were marked for identification.) 
13 
Q. Do you recognize it? 
14 
A. I refuse to answer. 
15 
Q. Okay. 
16 
MR. PIKE: May I see that? 
17 
MR. EDWARDS: Sure. 
18 
Q. Do you recognize the handwriting on it? 
19 
A. I refuse to answer. 
20 
Q. It indicates " 
hasn't confirmed 
21 
for 11 yet, so she is keeping 
on hold in case 
22 
doesn't call back." 
23 
What does that message mean? 
EFTA00182443

24 
A. I refuse to answer. 
25 
MR. PIKE: Form. 
0063 
1 
Q. 
an underage minor female that Jeffrey 
2 
Epstein was going to molest at 11:00, correct? 
3 
MR. PIKE: Form. 
4 
A. I refuse to answer. 
5 
Q. And if 
wasn't available then you had 
6 
another underage minor female named 
that could 
7 
step in her place and fulfill that role for Jeffrey 
8 
Epstein, correct? 
9 
MR. PIKE: Form. 
10 
A. I refuse to answer. 
11 
Q. All right. 2B is another message pad and I'm 
12 
going to -- we'll stop skipping the process of moving 
13 
this on and I'm assuming you're not going to be able to 
14 
answer as to whether or not you -- you recognize that 
15 
either, right? 
16 
A. I refuse to answer. 
17 
Q. Okay. This is a message from 9/4/05, so 
18 
September 4th, 2005, 7:25 p.m. saying "-
19 
cancelled 
. She would like to speak to you I 
20 
believe about college," and a telephone number. And 
21 
then a question from you, "Should I schedule anyone 
22 
else?" What did that message mean? 
23 
MR. PIKE: Form. 
24 
A. I refuse to answer. 
25 
Q. That another typical ploy of Mr. Epstein's, 
0064 
1 
that he would promise these girls something in order to 
2 
get them to allow him to sexually abuse them? 
3 
MR. PIKE: Form. 
4 
A. I refuse to answer. 
5 
Q. Because he certainly did not want them to tell 
6 
the police, correct? 
7 
A. I refuse to answer. 
8 
Q. And did you have many meetings about what to 
9 
do if any of these girls told the police? 
10 
A. I refuse to answer. 
11 
MR. PIKE: Form. 
12 
Q. Was it always known that Jeffrey Epstein would 
13 
hire everyone attorneys and tell everyone just not to 
14 
talk? 
15 
MR. PIKE: Form. 
16 
A. I refuse to answer. 
17 
Q. And at the same time then he could employ a 
18 
bunch of investigators, dig up a bunch of dirt on these 
19 
girls, and intimidate them and scare them to go away, 
20 
correct? 
21 
MR. PIKE: Form. 
22 
A. I refuse to answer. 
23 
Q. And Jeffrey Epstein doesn't like -- he didn't 
24 
like any of these underage minor females, right? 
25 
MR. PIKE: Form. 
0065 
1 
A. I refuse to answer. 
2 
Q. In fact, it was the opposite, he liked to hurt 
3 
them; isn't that true? 
4 
MR. PIKE: Form. 
5 
A. I refuse to answer. 
6 
Q. And after they came forward if they told the 
7 
truth he was dead set on hurting them even more, 
8 
correct? 
EFTA00182444

9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
Can you tell us what that message means? 
22 
MR. PIKE: Form. 
23 
A. I refuse to answer. 
24 
Q. It's another underage minor female that 
25 
Jeffrey Epstein's going to molest at 4 p.m., correct? 
0066 
1 
A. I refuse to answer. 
2 
Q. And when I say "molest", you know, he may say 
3 
"massage", I mean, that's -- that's something 
4 
interchangeable, right? 
5 
MR. PIKE: Form. 
6 
A. I refuse to answer. 
7 
Q. It's the routine that I described in detail 
8 
that is identical with every single girl every single 
9 
time, correct? 
10 
A. I refuse to answer. 
11 
Q. And it's basically as far as he can get with 
12 
this underage minor female without her crying or 
13 
screaming or running out of the house? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. Did you ever see any of the girls cry or 
17 
scream or run out of the house? 
18 
MR. PIKE: Form. 
19 
A. I refuse to answer. 
20 
Q. Did you have a personal relationship with any 
21 
of these underage minor females? 
22 
A. I refuse to answer. 
23 
Q. There's another message here from 9/10/05, 
24 
same day later in the day, 10 p.m. saying " 
will 
25 
be at 11. Do you want me to cancel 
ri 
0067 
1 
Do you know what that message means? 
2 
MR. PIKE: Form. 
3 
A. I refuse to answer. 
4 
Q. What is this? 
5 
There's another message from 9/11/05 saying "I 
6 
got a car for," and then the name is blotted out. The 
7 
State Attorney's Office blotted the names of minors out 
8 
sometimes in their file. So do you -- do you know --
9 
can you fill in that blank? 
10 
A. I refuse to answer. 
11 
Q. Do you know if this was the car that he rented 
12 
for Jane Doe 4? 
13 
A. I refuse to answer. 
14 
Q. All right. Or the car that he rented for AH? 
15 
A. I refuse to answer. 
16 
MR. PIKE: Form. 
17 
Q. You're familiar with both of those people, 
18 
right? 
19 
A. I refuse to answer. 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And that's also a feeling that Ghislaine 
Maxwell shared as well, correct? 
A. I refuse to answer. 
Q. And that's something that she also told you, 
"Don't worry. If we get caught we have it covered and 
we'll just attack these little girls." 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. All right. There's another message from 
9/10/05. 
n 
says Lauren confirmed for 4 p.m." 
EFTA00182445

20 
21 
22 
23 
24 
25 
0068 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0069 
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 
0070 
1 
2 
3 
4 
Q. 
Jeffrey 
A. 
4. 
message 
In fact, 
Epstein's 
I refuse 
MR. PIKE 
9/3/2005 
for 
AH was somebody that was over at 
house many times, correct? 
to answer. 
Form. 
. Message from 
saying "I left 
to confirm for 11 a.m. and 
for 4:30 p.m." 
Do you remember leaving that message? 
A. I refuse to answer. 
Q. And this is --
MR. PIKE: Form. 
Q. It's his typical schedule where he schedules 
one underage minor female to molest in the morning and 
one in the afternoon, correct? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. I mean, considering this is -- have you ever 
worked anywhere else where there is somebody sexually 
molesting underage minor females on a daily basis like 
this? 
A. 
Q. 
parents 
A. 
4. 
and say 
A. 
Q. 
A. 
MR. PIKE: Form. 
I refuse to answer. 
At some point in time did you tell your 
that this was happening? 
MR. PIKE: Form. 
I refuse to answer. 
Did you ever talk to anybody else in the house 
"Hey, look, this is not right"? 
I refuse to answer. 
Do you feel sorry for these girls? 
I refuse to answer. 
Q. And you say you do or you do not remember AH? 
A. I refuse to answer. 
Q. Okay. And do you know what happened up in the 
bedroom between AH as a minor and Jeffrey Epstein? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Well, this is what she tells police: "She 
arrived at the house, went upstairs to the bedroom. 
She advised she immediately removed her clothing and 
and Epstein were already naked in the 
bedroom. AH explained that 
and she 
had a sexual encounter that included kissing, touching, 
and oral sex. AH remembered that she climaxed and was 
removing herself from the massage table. Epstein then 
turned AH onto her stomach on the massage table and 
inserted his penis into her vagina. AH stated Epstein 
began to pump his penis in her vagina. AH became upset 
over this. She said her head was being held forcibly 
against the bed as he continued to pump inside her. 
She screamed 'No,' and Epstein stopped. He would 
normally pay her $200, but for this he apologized and 
paid her a thousand dollars for that visit." 
Are you familiar with that encounter? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. Do you remember a time when AH as a 
16-year-old I believe at this time left her house 
left the house visibly upset? 
MR. PIKE: Form. 
EFTA00182446

5 
A. I refuse to answer. 
6 
Q. She advised that she was ripped and torn in 
7 
her vagina area and had difficulty walking to the car; 
8 
do you remember that? 
9 
MR. PIKE: Form. 
10 
A. I refuse to answer. 
11 
Q. These message pads were message pads that were 
12 
taken from trash pulls outside of Jeffrey Epstein's 
13 
home and for the most -- well, there's so many messages 
14 
here, but most of them are by somebody other than 
15 
yourself. So my question is who are the other people 
16 
that would take messages for Jeffrey Epstein for 
17 
underage minor females to come to the house? 
18 
MR. PIKE: Form. 
19 
A. I refuse to answer. 
20 
Q. And the messages include CL, "Can I come work 
21 
today?" 
22 
What does "work" mean? 
23 
A. I refuse to answer. 
24 
MR. PIKE: Form. 
25 
Q. That means come to your house and get paid for 
0071 
1 
Jeffrey Epstein sexually molesting this person while 
2 
she was underage; is that correct? 
3 
A. I refuse to answer. 
4 
MR. PIKE: Form. 
5 
Q. And it was also pretty frequent that the girls 
6 
would come in tandem, isn't that true, two at a time? 
7 
MR. PIKE: Form. 
8 
A. I refuse to answer. 
9 
Q. And one being the girl that would bring the 
10 
new girl there, would wait downstairs while the new 
11 
girl was upstairs getting molested but then getting 
12 
paid? 
13 
MR. PIKE: Form. 
14 
A. I refuse to answer. 
15 
Q. How did Jeffrey Epstein explain himself to you 
16 
as to why he did this? 
17 
MR. PIKE: Form. 
18 
A. I refuse to answer. 
19 
Q. Do you know when it is that he first became 
20 
sexually obsessed with underage minor females? 
21 
MR. PIKE: Asked and answered. 
22 
A. I refuse to answer. 
23 
MR. PIKE: Form. 
24 
Q. Did you know that he was a school teacher at 
25 
the Dalton School? 
0072 
1 
A. I refuse to answer. 
2 
Q. And at that point in time -- well, are you 
3 
aware of him molesting underage minors while he was a 
4 
teacher there? 
5 
A. I refuse to answer. 
6 
Q. There's another note that's not a message pad 
7 
which I guess I will -- since it has your name on it I 
8 
will mark it as what are we on -- 3 -- wait, C 
9 
MR. ROSS: 3. 
10 
MR. EDWARDS: I messed up. 
11 
MR. ROSS: 3. 
12 
(Whereupon, Plaintiff's Exhibit 3 was marked 
13 
for identification.) 
14 
Q. Look at that while I fix what I've messed up 
15 
over here. 
EFTA00182447

16 
MR. ROSS: I'm going to show this to the 
17 
witness. 
18 
MR. EDWARDS: Yes. Yes. 
19 
Q. Do you recognize that document? 
20 
A. I refuse to answer. 
21 
Q. There are a lot of different things on here 
22 
that don't necessarily relate to you. At least I can't 
23 
tell that they do. But it does indicate "-
24 
parents are going to the embassy on the 23rd." 
25 
Do you remember when that happened? 
0073 
1 
A. I refuse to answer. 
2 
Q. Why did your parents go to the embassy? 
3 
A. I refuse to answer. 
4 
Q. More importantly why was Mr. Epstein concerned 
5 
that your parents were going to the Embassy? 
6 
MR. PIKE: Form. 
7 
A. I refuse to answer. 
8 
Q. Was -- at that point in time was Mr. Epstein 
9 
assisting your parents with anything? 
10 
A. I refuse to answer. 
11 
Q. Are your parents citizens of the United 
12 
States? 
13 
MR. ROSS: Form. 
14 
A. I refuse to answer. 
15 
Q. Are you? 
16 
A. No. 
17 
Q. Has Mr. Epstein ever offered to get you a visa 
18 
for the United States? 
19 
A. I refuse to answer. 
20 
MR. PIKE: Form. 
21 
Q. Do you know Raer Roshan? 
22 
A. I refuse to answer. 
23 
Q. That was Jeffrey Epstein's partner in 
24 
RadarOnline, correct? 
25 
A. I refuse to answer. 
0074 
1 
Q. And if I showed you every single message pad 
2 
here would you be able to answer any of the questions 
3 
about any of the messages that were left at Jeffrey 
4 
Epstein's house? 
5 
A. I refuse to answer. 
6 
MR. EDWARDS: Okay. That saves us a lot of 
7 
time. 
8 
MR. ROSS: It did. 
9 
Q. Have you ever met Bill Clinton? 
10 
A. I refuse to answer. 
11 
Q. Is Bill Clinton -- was Bill Clinton a friend 
12 
of Jeffrey Epstein's? 
13 
A. I refuse to answer. 
14 
Q. Is Bill Clinton somebody who Jeffrey Epstein 
15 
has ever procured underage minor females for? 
16 
A. I refuse to answer. 
17 
MR. PIKE: Form. 
18 
Q. And just -- and just for, you know, the sake 
19 
of what the evidence shows, there's no evidence that I 
20 
have that indicates that that happened, but if you were 
21 
going to answer that question I'm willing to ask it. 
22 
Have you met him at Jeffrey Epstein's house in 
23 
Palm Beach County? 
24 
MR. PIKE: Form. 
25 
A. I refuse to answer. 
0075 
EFTA00182448

1 
Q. You have flown on Jeffrey Epstein's airplanes 
2 
numerous times, correct? 
3 
A. I refuse to answer. 
4 
Q. As well has Bill Clinton and you're aware of 
5 
that, right? 
6 
MR. PIKE: Form. 
7 
A. I refuse to answer. 
8 
Q. Have you ever seen the flight logs from 
9 
Jeffrey Epstein's airplanes? 
10 
MR. PIKE: Form. 
11 
A. I refuse to answer. 
12 
Q. And on many times it is Bill Clinton, Secret 
13 
Service agents, Jeffrey Epstein, Ghislaine Maxwell, 
14 
, and others. Have you -- do you know 
15 
about those flights? 
16 
A. I refuse to answer. 
17 
MR. PIKE: Form. 
18 
Q. And have you ever witnessed sex on any of 
19 
Jeffrey Epstein's flights? 
20 
A. I refuse to answer. 
21 
MR. PIKE: Form. 
22 
Q. Do you know Emmy Taylor? 
23 
A. I refuse to answer. 
24 
Q. Is that somebody that is Ghislaine Maxwell's 
25 
sex slave? 
0076 
1 
A. I refuse to answer. 
2 
Q. And isn't it typical for Jeffrey Epstein to 
3 
have a sex slave that flies with him on the airplane? 
4 
A. I refuse to answer. 
5 
MR. PIKE: Form. 
6 
Q. And one of the qualifications is that the 
7 
section slave be underage, correct? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
10 
Q. And if the sex slave is 15 years old isn't it 
11 
your understanding and based on your observations that 
12 
he will even make them dress as if they're 11 or 12? 
13 
MR. PIKE: Form. 
14 
A. I refuse to answer. 
15 
MR. PIKE: Form. 
16 
Q. Do you know President Andres Pastrana? 
17 
A. I refuse to answer. 
18 
Q. Do you know him as somebody who has had sex 
19 
with underage minor females brought to him by Jeffrey 
20 
Epstein? 
21 
MR. PIKE: Form. 
22 
A. I refuse to answer. 
23 
Q. Have you ever heard of Ehud Burak? 
24 
A. I refuse to answer. 
25 
MR. PIKE: Form. 
0077 
1 
Q. Is that another person that Epstein -- Jeffrey 
2 
Epstein procures underage minor females for? 
3 
MR. PIKE: Form. 
4 
A. I refuse to answer. 
5 
Q. You've met Naomi Campbell I'm assuming? 
6 
A. I refuse to answer. 
7 
Q. Anytime separate and apart from any dealings 
8 
with Jeffrey Epstein have you met her in the modeling 
9 
industry? That's a model, right? 
10 
MR. PIKE: Form. 
11 
MR. ROSS: You can answer the question. 
EFTA00182449

12 
A. No, I have not. 
13 
Q. Okay. Do you know Todd Meister? 
14 
A. I refuse to answer. 
15 
Q. Joel Pashcow? 
16 
A. I refuse to answer. 
17 
Q. You've been to their houses? 
18 
A. I refuse to answer. 
19 
Q. Do you know Aline Weber? 
20 
A. I refuse to answer. 
21 
Q. Have you ever stayed at the 301 East 66th 
22 
Street places with Aline Weber? 
23 
MR. PIKE: Form. 
24 
A. I refuse to answer. 
25 
Q. And typically aren't there at least 16 
0078 
1 
underage minor females staying at those various 
2 
condominiums located at 301 East 66th Street? 
3 
A. I refuse to answer. 
4 
Q. And those females get work visas to say that 
5 
they're models, but actually they are prostituted out 
6 
by Jeffrey Epstein and John Luc Brunel, correct? 
7 
A. I refuse to answer. 
8 
MR. PIKE: Form. 
9 
Q. And various businessmen and politicians around 
10 
New York and Washington, D.C. go to those apartments 
11 
frequently to have sex with underage minors; is that 
12 
true? 
13 
A. I refuse to answer. 
14 
Q. Do you remember a flight on December 3rd, 2004 
15 
that you took with Jeffrey Epstein, 
16 
, and somebody with initials SH 
17 
A. I refuse to answer. 
18 
Q. -- from JFK to PBI? 
19 
MR. PIKE: Form. 
20 
Q. Do you remember that? 
21 
A. I refuse to answer. 
22 
Q. Who is SH? 
23 
A. I refuse to answer. 
24 
Q. Is that an underage minor? 
25 
A. I refuse to answer. 
0079 
1 
Q. Do you remember a flight that you took 
2 
December 27th with 
and Jeffrey 
3 
Epstein? 
4 
A. I refuse to answer. 
5 
Q. What airport is this, TIST? 
6 
A. I refuse to answer. 
7 
Q. Do you know Doug Band? 
8 
A. I refuse to answer. 
9 
Q. Isn't that Bill Clinton's assistant? 
10 
A. I refuse to answer. 
11 
Q. You've been on the airplane with him before? 
12 
A. I refuse to answer. 
13 
Q. Have you been on the airplane with Bill 
14 
Clinton before? 
15 
A. I refuse to answer. 
16 
Q. Who is 
? 
17 
A. I refuse to answer. 
18 
Q. That's somebody you've flown with on Jeffrey 
19 
Epstein's plane on numerous occasions, correct? 
20 
MR. PIKE: Form. 
21 
A. I refuse to answer. 
22 
Q. In fact, during the year 2005 you flew on 
EFTA00182450

9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0082 
1 
2 
3 
4 
5 
6 
7 
23 
24 
25 
0080 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0081 
1 
2 
3 
4 
5 
6 
Jeffrey Epstein's plane would you say more than 50 
times? 
A. I refuse to answer. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
Jeffrey 
MR. PIKE: Form. 
And you flew to his 
I refuse to answer. 
MR. PIKE: Form. 
You flew to New Mexico? 
I refuse to answer. 
MR. PIKE: Form. 
You flew to New Jersey? 
MR. PIKE: Form. 
I refuse to answer. 
Several of the flights 
Epstein, and 
those flights? 
MR. PIKE: Form. 
I refuse to answer. 
Who's Adam Perrylang? 
I refuse to answer. 
Is that somebody that 
with? 
A. 
Q. 
with any 
A. 
Q. 
sex 
A. 
Q. 
A. 
Q. 
island, right? 
are just yourself, 
. What did you do on 
you were made to have 
I refuse to answer. 
Did Jeffrey Epstein ever make you have sex 
females? 
MR. PIKE: Form. 
I refuse to answer. 
Did he ever make you have sex with any of his 
friends? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Who is Sandy Berger? 
A. I refuse to answer. 
Q. That's somebody else that was affiliated with 
7 
Bill Clinton at one point in time, correct? 
8 
A. I refuse to answer. 
Q. A close friend of Jeffrey Epstein's? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. He called the house within three weeks of the 
search warrant being executed. Did he tip off Jeffrey 
Epstein? 
A. 
Q. 
minors? 
A. 
Q. 
A. 
Q. 
A. 
Q. Have you flown on the airplane with Alan 
Dershowitz before? 
MR. PIKE: Form. 
I refuse to answer. 
Is he somebody that's involved with underage 
I refuse to answer. 
Do you know Igor Zinoviev? 
I refuse to answer. 
Andrea Metrovich? 
I refuse to answer. 
A. 
Q. 
been on 
A. 
Q. 
MR. PIKE: Form. 
I refuse to answer. 
And Jean Luc Brunel is somebody who you have 
the airplane with several times, correct? 
I refuse to answer. 
MR. PIKE: Form. 
And when Jean Luc Brunel is on this airplane 
EFTA00182451

8 
there are underage minor -- minor females on the 
airplane with you, correct? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Is there a back room to this airplane? Is 
there any sort of separation or is it all one big room? 
MR. PIKE: Form. 
I refuse to answer. 
So if Jeffrey Epstein and Jean Luc Brunel are 
in sex acts with underage minors did you --
I refuse --
Sorry -- did you observe any of those acts? 
I refuse to answer. 
MR. PIKE: Form. 
Q. And on numerous of the flights the flight logs 
indicate someone's name then oftentimes initials, but 
sometimes it would just say "three females". Do you 
know why? 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0084 
1 
2 
3 
4 
5 
6 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0083 
1 
2 
3 
4 
5 
6 
A. 
Q. 
engaged 
A. 
Q. 
A. 
A. 
Q. 
A. 
Q. Do you know Jo-Jo and Lynn Fontanella? 
A. I refuse to answer. 
7 
Q. They're the house managers up at the mansion 
8 
up in Manhattan, correct? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And they assist Mr. Epstein in engaging in 
underage sex with minors in New York, correct? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. They also maintain a pretty close relationship 
with the police? 
A. I refuse to answer. 
Q. And that's a big component also, right, that 
Jeffrey Epstein has -- is friendly with the law 
enforcement, correct? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Like law enforcement would do favors for not 
only Jeffrey Epstein but his various assistants. If 
you were speeding around the neighborhood they wouldn't 
give you a ticket, correct? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Was it ever your job to call the police 
department and ask if any police reports were on file 
or anybody complained about the activities at Jeffrey 
7 
Epstein's house? 
8 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Have you ever gone physically to the police 
department? 
A. I refuse to answer. 
Q. Was there a flight where you flew alone with 
Jean Luc 
A. 
Q. 
Andrew? 
I refuse to answer. 
MR. PIKE: Form. 
Who's 
? 
I refuse to answer. 
Brunel? 
I refuse 
Have you 
to answer. 
ever flown on the plane with Prince 
MR. PIKE: Form. 
EFTA00182452

19 
A. I refuse to answer. 
20 
Q. Do you know 
21 
A. I refuse to answer. 
22 
Q. That's another model that Jeffrey Epstein 
23 
knows, correct? 
24 
A. I refuse to answer. 
25 
MR. PIKE: Form. 
0085 
1 
Q. Somebody that he had engaged in sex with when 
2 
she was underage? 
3 
A. I refuse to answer. 
4 
Q. She actually got a modeling contract out of 
5 
it? 
6 
MR. PIKE: Form. 
7 
A. I refuse to answer. 
8 
Q. Why does Jean Luc Brunel and Jeffrey Epstein 
9 
fly together so often? 
10 
MR. PIKE: Form. 
11 
A. I refuse to answer. 
12 
Q. And why does Ghislaine Maxwell also fly so 
13 
often with Jeffrey Epstein and Jean Luc Brunel? 
14 
A. I refuse to answer. 
15 
MR. PIKE: Form. 
16 
Q. Isn't it true that all three of them are 
17 
obsessed and addicted to sex with underage minors? 
18 
MR. PIKE: Form. 
19 
A. I refuse to answer. 
20 
MR. PIKE: Brad, how much longer do you have? 
21 
MR. EDWARDS: How long? You want to take a 
22 
break? 
23 
MR. PIKE: Yeah. 
24 
MR. EDWARDS: Sure. It's going a lot faster 
25 
than I thought it would. 
0086 
1 
VIDEOGRAPHER: Off the record, 11:33 a.m. 
2 
(Recess taken at 11:33 a.m.) 
3 
(Deposition resumed at 11:43 a.m.) 
4 
VIDEOGRAPHER: On the record, 11:43 a.m. 
5 
BY MR. EDWARDS: 
6 
Q. All right. There's one more message that I 
7 
wanted to ask you about. As I mentioned, I'm not going 
8 
to go through all of the messages that I have, but 
9 
there's one from 9/4/2005, 9:08 a.m. from 
. "Is 
10 
it okay for 
to stop by and drop something?" 
11 
A. I refuse to answer. 
12 
MR. PIKE: Form. 
13 
Q. So what were your hours working for Jeffrey 
14 
Epstein? 
15 
A. I refuse to answer. 
16 
Q. I mean, some of these messages are 9:00 in the 
17 
morning and others are as late as 8:30 or 9 at night. 
18 
So what were your hours? 
19 
A. I refuse to answer. 
20 
Q. Another message from 9/4 also, same day, 
21 
," I think, "confirmed an 11 a.m., 
is at 
22 
4:30 p.m." 
23 
MR. MERMELSTEIN: I think that's one you did. 
24 
MR. EDWARDS: Oh, yeah? Okay. 
25 
Q. All right. Do you remember that message? 
0087 
1 
A. I refuse to answer. 
2 
MR. EDWARDS: Do you care how I attach it 
3 
since it's --
EFTA00182453

4 
MR. ROSS: No. 
5 
MR. EDWARDS: I'll attach it as whatever it 
6 
is. 
7 
MR. ROSS: 4. 
8 
MR. EDWARDS: 2 -- well, I'll just go 2H since 
9 
it's a message. You don't have a problem with 
10 
that? 2H? 
11 
MR. ROSS: Whatever. 
12 
(Whereupon, Plaintiff's Exhibit 2H was marked 
13 
for identification.) 
14 
Q. Do you still consider Jeffrey Epstein a 
15 
friend? 
16 
A. I refuse to answer. 
17 
MR. PIKE: Form. 
18 
Q. Did you ever think of Jeffrey Epstein as a 
19 
friend? 
20 
MR. PIKE: Form. 
21 
A. I refuse to answer. 
22 
Q. Other than the people that I've mentioned 
23 
of -- you know, President Pastrana and Ehud Burak and 
24 
Prince Andrew did you meet any other people of royalty 
25 
being friends with Jeffrey Epstein? 
0088 
1 
MR. PIKE: Form. 
2 
A. I refuse to answer. 
3 
Q. Can you tell us any of the other folks that 
4 
Jeffrey Epstein would supply underage minor girls to? 
5 
MR. PIKE: Form. 
6 
A. I refuse to answer. 
7 
Q. Do you know a man by the name of Glenn Dubin? 
8 
A. I refuse to answer. 
9 
Q. Do you know his wife? 
10 
A. I refuse to answer. 
11 
Q. His wife at some point in time was associated 
12 
with Jeffrey Epstein; is that correct? 
13 
A. I refuse to answer. 
14 
Q. And her name's Eva Dubin; is that right? 
15 
A. I refuse to answer. 
16 
17 
18 
19 
20 
Q. Do you know 
? 
21 
A. I refuse to answer. 
22 
Q. Is that somebody who also worked for Jeffrey 
23 
Epstein? 
24 
A. I refuse to answer. 
25 
MR. PIKE: Form. 
0089 
1 
Q. Did Jeffrey Epstein ever get a legitimate 
2 
massage from somebody that's a masseuse? 
3 
MR. PIKE: Form. 
4 
A. I refuse to answer. 
5 
Q. The underage females that we've talked about 
6 
particularly, LM, EW, and Jane Doe, those girls were 
7 
not prostitutes, were they? 
8 
A. I refuse to answer. 
9 
Q. These were just girls who were in 8th, 9th, 
10 
10th grade in high school, right? 
11 
A. I refuse to answer. 
12 
Q. These were girls that you knew had never 
13 
committed prostitution in the past, right? 
14 
A. I refuse to answer. 
EFTA00182454

15 
Q. And that goes for all of these girls on the 
16 
phone list of underage minors to call, these were not 
17 
prostitutes, correct? 
18 
A. I refuse to answer. 
19 
Q. You never called a prostitution or escort 
20 
service for Jeffrey Epstein, did you? 
21 
MR. PIKE: Form. 
22 
A. I refuse to answer. 
23 
Q. And as well you never called a legitimate 
24 
massage parlor for Jeffrey Epstein, correct? 
25 
A. I refuse to answer. 
0090 
1 
MR. PIKE: Form. 
2 
Q. He devised this scheme of having underage 
3 
minor girls bring him other underage minor girls so 
4 
that he could gain access to his target age group, 12 
5 
to 16 years old, correct? 
6 
A. I refuse to answer. 
7 
Q. Have you heard Jeffrey Epstein say "The 
8 
younger the better?" 
9 
A. I refuse to answer. 
10 
Q. And did Jeffrey Epstein tell you that it made 
11 
him happy the younger the girl was? 
12 
A. I refuse to answer. 
13 
MR. PIKE: Form. 
14 
Q. The less developed the girl is the more 
15 
excited Jeffrey Epstein gets; is that true? 
16 
MR. PIKE: Form. 
17 
A. I refuse to answer. 
18 
Q. Do you ever plan to talk to Jeffrey Epstein in 
19 
the future? 
20 
A. I refuse to answer. 
21 
MR. PIKE: Form. 
22 
Q. Would you ever work for him again? 
23 
A. I refuse to answer. 
24 
Q. Why didn't you stop working for him sooner? 
25 
A. I refuse to answer. 
0091 
1 
MR. PIKE: Form. 
2 
Q. Did you -- well, you knew that it was illegal 
3 
what he was doing at the time you were doing it, 
4 
correct? 
5 
A. I refuse to answer. 
6 
Q. Did you know that you were part of a large 
7 
child molestation ring? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
10 
Q. Did you ever tell anyone while you were 
11 
working for him that you wanted to stop? 
12 
A. I refuse to answer. 
13 
MR. PIKE: Form. 
14 
Q. Did you continue working there because you 
15 
were just scared to stop? 
16 
A. I refuse to answer. 
17 
MR. PIKE: Form. 
18 
Q. Were you in fear of what Ghislaine Maxwell or 
19 
Jeffrey Epstein might do to you if you quit performing 
20 
your services for his child molestation ring? 
21 
A. I refuse to answer. 
22 
MR. PIKE: Form. 
23 
Q. Did Jeffrey Epstein ever threaten you? 
24 
A. I refuse to answer. 
25 
MR. PIKE: Form. 
EFTA00182455

0092 
1 
2 
3 
4 
5 
6 
7 
a 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0093 
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 
0094 
1 
2 
3 
4 
5 
6 
Q. Did Ghislaine Maxwell ever threaten you? 
A. I refuse to answer. 
Q. How was it decided who would call which girl? 
A. I refuse to answer. 
Q. And by that, just so it's clear, like I said, 
there's going to be many, many, many message pads, I 
have not counted them, but a lot created by either 
yourself or someone named Janusz Banaziak or 
, Alfredo Rodriguez, 
, 
, various people that we know to have been 
employed at Jeffrey Epstein's home. And it seems that 
on one particular day 
may call several girls, you 
may call several girls, 
may call several girls. 
Who is directing which -- which of you, which of the 
assistants is going to call the underage minor to give 
them an appointment? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. And what would happen on the occasions where 
Jeffrey Epstein says he's going to be in town and then 
he's ultimately not in town but a girl shows up anyway? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Weren't you just told just to pay her to keep 
her happy? 
A. I refuse to answer. 
Q. And isn't part of the whole scheme that these 
girls were typically told "Don't tell anybody what goes 
on inside this house," right? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And did Jeffrey Epstein tell you that because 
these girls are young and they're poor and they're 
underprivileged type girls they're likely not going to 
say anything anyway? Isn't that what he told you? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Did Ghislaine Maxwell talk to you about that 
as well? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. Have you seen Jeffrey Epstein angry? 
A. I refuse to answer. 
Q. Isn't it true that he's very nice and engaging 
as long as he gets his way and gets you to cooperate, 
right? 
A. I refuse to answer. 
Q. But if he doesn't get his way he gets very, 
very angry and mad and scary; isn't that true? 
A. I refuse to answer. 
Q. And you've seen both sides of him, right? 
A. I refuse to answer. 
Q. In fact, you know of girls who were 13 years 
old and cooperated with everything he said because they 
felt they had no choice up in that bedroom, right? 
A. I refuse to answer. 
7 
MR. PIKE: Form. 
8 
Q. And you also know girls who resisted and were 
9 
yelled at and told to grab their money and get out of 
10 
there, right? 
EFTA00182456

11 
A. I refuse to answer. 
12 
Q. Wouldn't you agree that that house upstairs 
13 
can be somewhat confusing in how it's -- how it's laid 
14 
out? 
15 
A. I refuse to answer. 
16 
Q. In fact, there's a stairwell that starts from 
17 
the kitchen, there's a door and it almost blends in in 
18 
the kitchen with the other closets, correct? 
19 
A. I refuse to answer. 
20 
MR. PIKE: Form. 
21 
Q. But you open that door and there's a stairway 
22 
that twists it seems to the left and there's another 
23 
door at the top of that stairway, right? 
24 
A. I refuse to answer. 
25 
Q. And then when you exit that stairway you take 
0095 
1 
a right and you head towards a little hallway that 
2 
eventually leads into Mr. Epstein's bedroom, right? 
3 
A. I refuse to answer. 
4 
Q. And if it's your first time in that bedroom as 
5 
a 14-year-old girl and you don't like what's happened 
6 
up there would you agree that it's a tough way to find 
7 
your -- a place to find your way out of? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
10 
Q. Did Jeffrey -- didn't Jeffrey Epstein tell you 
11 
that he would act as a father-type figure to these 
12 
girls? 
13 
A. I refuse to answer. 
14 
MR. PIKE: Form. 
15 
Q. And he would propose that what they are doing 
16 
for him or with him despite the law is okay? 
17 
A. I refuse to answer. 
18 
MR. PIKE: Form. 
19 
Q. And they could continue to make a lot of money 
20 
if they would come over and be his sex victims, right? 
21 
MR. PIKE: Form. 
22 
A. I refuse to answer. 
23 
Q. And you were aware when my client, LM, was 
24 
pregnant at 16 years old that Jeffrey Epstein bought 
25 
everything on her baby registry, right? 
0096 
1 
A. I refuse to answer. 
2 
MR. PIKE: Form. 
3 
Q. Was it you or 
that took all of 
4 
the gifts over to her home? 
5 
MR. PIKE: Form. 
6 
A. I refuse to answer. 
7 
Q. I believe it was 
in a -- did 
8 
Jeffrey Epstein own a Mercedes? 
9 
MR. PIKE: Form. 
10 
A. I refuse to answer. 
11 
Q. And do you remember when 
loaded 
12 
up the Mercedes with all the baby gifts and took it to 
13 
my client's trailer? 
14 
A. I refuse to answer. 
15 
Q. And that was so that while LM -- that was to 
16 
thank her while she was pregnant she continued to bring 
17 
him 13-, 14-, and 15-year-old girls to molest, correct? 
18 
MR. PIKE: Form. 
19 
A. I refuse to answer. 
20 
Q. Because LM would no longer qualify as somebody 
21 
he'd be sexually interacting with as she was pregnant, 
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