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Case 9:08-cv-80736-K,..4I Document 291-18 Entered on FL.....L.) Docket 01/21/2015 Page 11 of 
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Page 279 
1 
A. Two or three times. 
2 
Q. And did you have any knowledge of why he 
3 
was visiting there? 
4 
A. No, ma'am. 
5 
Q. You don't know whether or not he was a 
6 
lawyer -- acting as a lawyer or whether he was 
7 
there as a friend? 
8 
A. I believe as a friend. 
9 
Q. Were there also young ladies in the house 
10 at the time he was there? 
11 
MR. CRITTON: Form. 
12 
THE WITNESS: Yes, ma'am. 
13 
BY MS. EZELL: 
14 
Q. An 
a have Included for 
15 
instance, 
and 
16 
A. Yes, ma am. 
17 
Q. Were there other young ladles there when 
18 Mr. DershowItz was there? 
19 
MR. CRITTON: Form. 
20 
THE WITNESS: Yes, ma'am. 
21 BY MS. EZELL: 
22 
Q. Do you have any idea who those young 
23 
women were? 
24 
A. No, ma'am. 
25 
Q. Were any of those the young women that 
Page 281 
1 
Q. Can you tell me where those were? 
2 
A. One in the kitchen, and the one in the 
3 
formal -- the main entrance. And there was one 
4 
more added later on, but there is two when I was 
5 
working there. 
6 
Q. Could you just give me a rough sketch of 
7 
the house of where the main entrance was and where 
8 
the kitchen was? 
9 
A. I'm not an architect but It's something 
10 like this. This is the kitchen, this Is the main 
11 entrance. 
12 
Q. Will you mark the kitchen with a K, 
13 please, and the main entrance with ME? 
14 
A. This Is the pool. 
15 
Q. The pool? 
16 
A. Yes, ma'am. 
17 
Q. And In the upper left? 
18 
A. In the terrace, yeah, there was a balcony 
19 here. 
20 
Q. And where were the staircases? 
21 
A. This is one, the kitchen, one in the 
22 
foyer, and the pool. 
23 
Q. Okay. And would you Just put an F where 
24 
the foyer staircase began? And KS where the 
25 kitchen staircase began. 
Page 280 
1 you have said came to give massages? 
2 
A. Yes, ma'am. 
3 
Q. And do you have any Idea whether or not 
4 
Mr. Dershowitz was also receiving massages? 
5 
A. I don't know, Ma'am. 
6 
Q. I want to ask you to take this piece of 
7 
paper, please, and a pencil --
8 
MR. WILLITS: Can anybody hear me? 
9 
MS. EZELL: Yes. Can you hear me? 
10 
MR. WILLITS: I've heard nothing for 
11 
about a minute or so. 
12 
MR. CRITTON: Can you hear me now? 
13 
MR. WILLITS: Yes. 
14 
MS. EZELL: I'm asking questions, I'm 
15 
sorry. 
16 
MR. CRITTON: Why don't we go off the 
17 
record for a second. 
18 
(Thereupon, a discussion was held off the 
19 record.) 
20 
THE VIDEOGRAPHER: We're back on the 
21 
record. 
22 
BY MS. EZELL: 
23 
Q. Mr. Rodriguez, you indicated that there 
24 
were several staircases in the house? 
25 
A. Yes, ma'am. 
•••••••S. 
Page 282 
1 
And you said that later another staircase 
2 
was added? 
3 
A. Yeah, we rehabilitated this, you know, 
4 
but you asked me how many stairs there were, to 
5 
answer your question there were three. 
6 
Q. Three. So where was the third one? 
7 
A. The pool, this leads to the pool. 
8 
Through the outside master bedroom you could go 
9 
downstairs to the pool. 
10 
Q. Okay. A stairway then from the outside, 
11 from outside the master bedroom? 
12 
A. Yes, ma'am. 
13 
Q. Down to the pool? 
14 
A. Yes, ma'am. 
15 
Q. One of your duties was to answer the 
16 door. Is that correct? 
17 
A. Yes, ma'am. 
18 
Q. Which door would you answer? 
19 
A. Mainly the kitchen. 
20 
Q. And why was that, why would people mainly 
21 come to the kitchen? 
22 
A. I'll say it was for practicable reasons 
23 
because not to go to the main -- it was shorter 
24 
because the entrance was here, so this was the 
25 
driveway and we used to take into the back door of 
Kress Court Reporting, Inc. 305-866-7688 
7115 Rue Notre Dame, Miami Beach, FL 33141 
4 (Pages 279 to 282) 
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Case 9:08-cv-80736-K,..4 Document 291-18 Entered on FL—J Docket 01/21/2015 Page 12 of 
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Page 383 
1 you about having driven'. and you recalled 
2 
having had her In the Su rban specifically. 
3 
A. Yes. 
4 
Q. Do you remember any of the other girls, 
5 
women who came to give massages ever having driven 
6 
them, or is.. the only one that you remember? 
7 
MR. EDWARDS: Form. 
8 
THE WITNESS: I only remember M. right 
9 
now for the fact that I was driving by the 
10 
airport and I showed her Mr. Epstein's 
11 
plane. 
12 BY MR. CRITTON: 
13 
Q. All right. Which really takes me back to 
14 really where I started with this series of 
15 questions. 
16 
You saw the girls, the women who came In 
17 to give the massages, when they came in If you 
18 were advised or if you heard conversation and you 
19 saw them you would see them when they left? 
20 
A. Yes. 
21 
Q. And you saw M. because she was In the 
22 
Suburban on at least one occasion? 
23 
A. Yes. 
24 
Q. And, therefore, you never saw these 
25 girls, these women who gave the massages in the 
Page 385 
1 
Q. All right. Ms. Ezell asked you about Mr. 
2 
Dershowitz being present in Mr. Epstein's home, 
3 
and I think she asked -- and I think that you said 
4 
Mr. Epstein was a -- and he and Mr. Dershowitz 
5 
were friends? 
6 
A. Yes. 
7 
Q. She also I think asked was Mr. Dershowitz 
8 
ever there when one of the women who gave a 
9 
massage was present in the home? 
10 
A. I don't remember that. 
11 
Q. That's what I want to clear up. Is it 
12 
your testimony that Mr. Dershowitz was there when 
13 any of the women came to Mr. Epstein's home to 
14 
give a massage? 
15 
A. Yes. 
16 
MR. EDWARDS: Form. 
17 
BY MR. CRITTON: 
18 
Q. As to whether any of those women were 
19 ever associated with Mr. Dershowitz would it be a 
20 correct statement that you have absolutely no 
21 knowledge? 
22 
A. I don't know, sir. 
23 
Q. You don't know? 
24 
A. I don't know, sir. 
25 
MS. EZELL: Form. 
Page 384 
1 dining room or the library. Would that be a fair 
2 
statement? 
3 
A. That's correct. 
4 
MR. EDWARDS: Form. 
5 
BY MR. CRITTON: 
6 
Q. All rig 
fore, the pictures 
7 
that you saw 
taking of girls, women, 
8 
either in the in ng room or library, those were 
9 other individuals other than those who may have 
10 given or who came for massages. Is that correct? 
11 
MS. EZELL: Form. 
12 
MR. EDWARDS: Form. 
13 
THE WITNESS: It's confusing, sir, 
14 
because there were a bunch of girls. I 
15 
don't know which one they were but I saw her 
16 
taking pictures of the groups. 
17 
BY MR. CRITTON: 
18 
Q. As to whether they were people who came 
19 In on the planes or there may have been a massage 
20 girl or more than one woman who gave a massage, 
21 you just don't know as you sit here, you'd just be 
22 speculating. Is that correct? 
23 
MR. EDWARDS: Form. 
24 
THE WITNESS: I don't know. 
25 
BY MR. CRITTON: 
Page 386 
1 BY MR. CRITTON: 
2 
Q. Okay. Were you in any way attempting in 
3 
your response to Ms. Ezell to imply that Mr. 
4 
Dershowitz had a massage by one of these young 
5 
ladies? 
6 
A. I don't know, sir. 
7 
Q. You have no knowledge? 
8 
A. No, sir. 
9 
Q. And you certainly weren't implying that 
10 that occurred, you just have no knowledge. 
11 Correct? 
12 
MR. EDWARDS: Form. 
13 
THE WITNESS: I don't know. 
14 
BY MR. CRITTON: 
15 
Q. Sorry? 
16 
A. I don't know. 
17 
Q. I think in response to one of Ms. Ezell's 
18 questions you responded that -- let me ask it this 
19 way. 
20 
You never saw Mr. Epstein ever take 
21 photographs of anyone. Would that be a correct 
22 
statement? 
23 
A. Yes. 
24 
Q. Would It be a correct statement you never 
25 
saw Mr. Epstein initiate a phone call to anyone? 
30 (Pages 383 to 386) 
Kress Court Reporting, Inc. 305-866-7688 
7115 Rue Notre Dame, Miami Beach, FL 33141 
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Case 9:08-cv-80736-K,-..vl Document 291-18 Entered on FL—‘) Docket 01/21/2015 Page 13 of 
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Page 423 
1 York house? 
2 
A. He will have massages. 
3 
MR. CRITTON: Form. 
4 
BY MR. EDWARDS: 
5 
Q. And are we still talking about a habit of 
6 
two a day? 
7 
MR. CRITTON: Form. 
8 
THE WITNESS: I don't know that. 
9 
BY MR. EDWARDS: 
10 
Q. Okay. So for the time period when you 
11 have been familiar with Mr. Epstein and known his 
12 habits, is it fair to say that he would have 
13 
roughly two girls a day in that same age group 
14 
wherever he was? 
15 
A. Yes. 
16 
MR. CRITTON: Form. 
17 
BY MR. EDWARDS: 
18 
Q. All right. And have you talked to 
19 anybody that has given you similar Information 
20 from his Island home? 
21 
A. No. 
22 
Q. Do you know any of the girls that have 
23 
been over to his Island? 
24 
A. Yes. 
25 
Q. And who are they? 
Page 425 
1 
Q. And is your understanding that Mr. 
2 
Epstein was intimate with any of those girls? 
3 
MR. CRITTON: Form. 
4 
THE WITNESS: Yes. 
5 
BY MR. EDWARDS: 
6 
Q. With all of them? 
7 
MR. CRMON: Form. 
8 
THE WITNESS: Yes. 
9 
BY MR. EDWARDS: 
10 
Q. With Sarah as well? 
11 
A. Yes. 
12 
MR. CRITTON: Form. 
13 
BY MR. EDWitit 
14 
Q. With 
? 
15 
A. Yes. 
16 
MR. CRITTON: Form. 
17 
BY MR. EDWARDS: 
18 
Q. And the girls who would come over on the 
19 
airplane? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: Yes. 
22 BY MR. EDWARDS: 
23 
Q. Did you ever have occasion to go into the 
24 bedroom and find the vibrators or back massagers 
25 out after Mr. Epstein was in the room with any of 
Page 424 
1 
A. 
the girls who used to stay at the 
2 
home in 
Brillo used to go over there to the 
3 
Island. 
4 
Q. When he would have these girls -- I guess 
5 
we've kind of categorized them as the girls who 
6 
would come over with him on an airplane and stay 
7 at the house. 
8 
A. Yes. 
9 
Q. When they would be staying at the house 
10 
would he also have the local Palm Beach girls 
11 coming over that you were told to call masseuses? 
12 
A. Yes. 
13 
Q. So these girls that came on the airplane 
14 
with him, were they also -- did they also have 
15 
knowledge that these young girls were coming over 
16 to give massages? 
17 
MR. CRITTON: Form. 
18 
THE WITNESS: Yes, sir. 
19 
BY MR. EDWARDS: 
20 
Q. Okay. Who Me 
girls from the 
21 airplane other than 
that you remember? 
22 
A. Sarah. There were so many, sir 
't 
23 
recall right now. But Sarah Is for sure, 
24 
was one of the main girlfriends, but I dont 
25 
remember that. 
Page 426 
1 the girls that came over on the plane? 
2 
MR. CRITTON: Form. 
3 
THE WITNESS: Yes. 
4 
BY MR. EDWARDS: 
5 
Q. So that's something that would be out 
6 
after the girls that came over on the plane or the 
7 
girls that came over for the massages? 
8 
A. Yes. 
9 
MR. CRITTON: Form. 
10 
8Y MR. EDWARDS: 
11 
Q. And at the time when you were house 
12 
manager you had a 15-year old daughter? 
13 
A. Yes. 
14 
Q. Did she live down here? 
15 
A. In New Jersey. 
16 
Q. Okay. When Alan Dershowit was at the 
17 house I understood you to say that these local 
18 
Palm Beach girls would come over to the house 
19 while he was there but you're not sure if he had a 
20 massage from any of those girls. 
21 
A. Exactly. 
22 
Q. And what would he do while those girls 
23 
were at the house? 
24 
MR. CRMON: Form. 
25 
THE WITNESS: He will read a book with a 
40 (Pages 423 to 426 
Kress Court Reporting, Inc. 305-866-7688 
7115 Rue Notre Dame, Miami Beach, FL 33141 
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Case 9:08-cv-80736-k•A Document 291-18 Entered on FL..,D Docket 01/21/2015 Page 14 of 
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Page 427 
1 
glass of wine by the pool, stay inside. 
2 
BY MR. EDWARDS: 
3 
Q. Did he ever talk to any of the girls? 
4 
A. I don't know, sir. 
5 
Q. Certainly he knew that they were there? 
6 
MR. CRITTON: Form. 
7 
THE WITNESS: I don't know, sir. 
8 
BY MR. EDWARDS: 
9 
Q. Do you know how, 
knows Mr. 
10 
Epstein? 
11 
A. No, sir. 
12 
Q. Or how long she's known him? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: She was on board two years 
15 
or a year and a half before I came on board. 
16 BY MR. EDWARDS: 
17 
Q. Okay. 
18 
A. So it's probably 2003 or 2. 
19 
Q. All right. You mentioned this Ctrix 
20 system. 
21 
A. Yes. 
22 
Q. Is that a system that was used to operate 
23 the phones and the computers? 
24 
A. The computers mainly. 
25 
Q. All right. But you then also riPseribed 
Page 429 
1 usually it's Yahoo dot corn or at Bellsouth dot 
2 
net. 
3 
A. 
4 
sir. 
5 
Q. Did everybody in the -- I think you 
6 
called it the organization, did everybody have 
7 
e-mails? 
8 
A. Yes. 
9 
Q. Okay. Would that include? 
10 
A. Yes. 
11 
Q. All right. And did Mr. Epstein have an 
12 e-mail? 
13 
A. Yes. 
14 
Q. Did you ever correspond with Mr. Epstein 
15 
by e-mail? 
16 
A. Yes. 
17 
MR. EDWARDS: You can go ahead. 
18 
THE WITNESS: That's the only one that I 
19 
remember. 
20 
THE VIDEOGRAPHER: Okay, we're off the 
21 
record. 
22 
(Thereupon, a recess was had.) 
23 
THE VIDEOGRAPHER: We're back on the 
24 
record with tape number four. 
25 
BY MR. EDWARDS: 
It was very uncommon. I don't remember, 
Page 428 
1 some system where someone would call on the 
2 
telephone and that would be automatically 
3 
downloaded to the computer? 
4 
A. Yeah, you can retrieve who called in a 
5 
transcript written who called, what's the message, 
6 
the time so you have it on a piece of paper, you 
7 
can print it out. 
8 
Q. Is it your understanding that is also 
9 
part of the Citrix system? 
10 
A. Yes. 
11 
Q. All right. Did you have an e-mail? 
12 
A. Right now, yes. 
13 
Q. No, when you were working at --
14 
A. Yes, I did. 
15 
Q. -- Mr. E stein? 
16 
And did 
have an e-mail? 
17 
A. Yes. 
18 
Q. And did all of the e-mails end the same 
19 
way such as Epstein's house dot corn or something? 
20 
A. Yes. 
21 
Q. Okay. What was 
e-mail? 
22 
A. I don't remember. 
23 
Q. What was your e-mail? 
24 
A. Staff house -- I don't remember, sir. 
25 
Q. Do you recall how It ended? I mean 
Page 430 
1 
Q. Mr. Rodriguez, what was Mr. Epstein's 
2 
e-mail? 
3 
A. Jeep project at something -- Jeep 
4 
project -- I can't remember it right now. 
5 
Q. Okay. In the course of this next 10 or 
6 
15 minutes --
7 
A. I can recall. 
8 
Q. -- if it comes to you just tell me. So 
9 it was Jeep project --
10 
A. Like Jeep, the brand name Jeep, Jeep 
11 project at -- I can't remember. 
12 
Q. Okay. Was that his only e-mail to your 
13 
knowledge? 
14 
A. No. 
15 
Q. He had other e-mail addresses? 
16 
A. Yes. 
17 
Q. Do you know what any of his other e-mail 
18 
addresses were? 
19 
A. No, I don't remember. 
20 
Q. Do you know who the carriers were for the 
21 other e-mail addresses owned by Jeffrey Epstein? 
22 
A. No, sir. 
23 
Q. Whether it was Yahoo or hot mail or --
24 
A. No, none of those. 
25 
Q. Okay. Was this Jeep project e-mail run 
41 (Pages 427 to 430) 
Kress Court Reporting, Inc. 305-866-7688 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00188931

EFTA00188932

Case 9:08-cv-80736-KAm Document 291-19 Entered on FL .., Docket 01/21/2015 Page 1 of 2 
EXHIBIT 20 
EFTA00188933

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EFTA00188934

EFTA00188935

Case 9:08-cv-80736-Kmm Document 291-20 Entered on FL 
Docket 01/21/2015 Page 1 of 8 
EXHIBIT 21 
EFTA00188936

Case 9:08-cv-80736-Kmio Document 291-20 Entered on FL J Docket 01/21/2015 Page 2 of 8 
Page 1 
Page 3 
UNITED STATES DISTRICT COURT 
1 
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 
SOUTHERN DISTRICT OF FLORIDA 
2 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. 08-CIV-801 19-MARRA/JOHNSON 
3 
CASE NO. 502008CA028051XXXXMB AB 
4
JANE DOE NO. 2, 
Plaintiff, 
5 
Plaintiff, 
VOLUME I OF III 
6 
-vs- 
VOLUME I OF III 
JEFFREY EPSTEIN, 
7 
JEFFREY EPSTEIN, 
Defendant. 
8 
Defendant. 
/ 
/ 
9 
Related CUM 
10 
08-80232, 0848380, 08-8038 I, 08-80994 
11 
08-80993, 08-80811, 08-80893, 09-80469 
12 
VIDEOTAPED DEPOSITION OF 
09-80591, 09-80656, 09-80802, 09-81092 
13 
/ 
14 
VIDSMISITION 
OF 
15 
Wednesday, March 24, 2010 
10:37 • 6:51 p.m. 
16 
Wednesday, March 24, 2010 
17 
10:37 - 6:5I p.m. 
18 
I 
21. 
22 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Reported By: 
 23 
Notary Public, State of Florida 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting Services 
Prose Court Reporting Services 
2 4 
Job No.: 1484 
Job No.: 1484 
2 5 
Page 2 
Page 4 
1 
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 
1 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 
2 
CASE NO. 502008CA028058XXXXMB AD 
2 
CASE No.502008CA0373 19XX XXIAB AB 
3 
3 
4 n. 
4 S 
S 
Plaintiff, 
Plaintiff, 
6 
-vs- 
VOLUME 1 OF III 
5 
7 
6 
7
-vs- 
VOLUME I OF III 
JEFF... 
8 
JEFFREY EPSTEIN, 
AND 
Defendant. 
8 
9 
/ 
Defendants 
10 
9 
VI
ITION OF 
11 
12 
13 
VIDEOTAPED DEPOSITION OF 
10
11 
12 
14 
Wednesday, March 24, 2010 
13 
15 
10:37 -6:51 p.m 
14 
Wednesday, March 24, 2010 
10:37 - 6:51 p.m. 
16 
1 5
17 
I 
ill 
18 
19 
19 
20 
20 
21 
21 
22 
Reported By: 
22 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Cynthia Hopkins, RPR, FPR 
23 
Notary Public, State of Florida 
23 
Notary Public, State of Florida 
Prose Court Reporting Services 
Prose Court Reporting Services 
24 
Job No.: 1484 
24 
Job No.: 1484 
25 
25 
1 (Pages 1 to 4) 
PROSE COURT REPORTING AGENCY, INC. 
EFTA00188937

Case 9:08-cv-80736-KMIVI Document 291-20 Entered on FL.. 
Docket 01/21/2015 Page 3 of 8 
Page 5 
Page 7 
1 
APPEARANCES: 
1 
2 
On behalf of the Plaintiffs,t 
2 
IN-D-E X
3 
SPENCER t KUVIN, 
IRE 
3 
4 
LD K YIN 
4
I 
--- 
EXAMINATION 
DIRECT CROSS REDIRECT 
I 
6 
7 
7 
On behalf of the Plaintiffs, in. 
and 
BY MR. KUVIN 
9 
Jane Doe: 
8 
8 
9 
9 
MATTHEW WEISSING. ESQUIRE 
to 
EXHIBITS 
FARMER, JAFFE, WEISSING, EDWARDS 
10 
FISTOS & LEHRMAN P L
■
EXHIBIT 
DESCRIPTION 
PAGE 
PLAINTIFF'S EX. 1 PHOTO 
16 
0 
On behal of Jane 
s I through t 
1 ) 
PLAINTIFF'S EX. 2 JEGE, INC., 24 
ADAM D. HOROWITZ. ESQUIRE 
PASSENGER MANIFEST 
W1TZ. P A 
16 
PLAINTIFFS EX. 3 HYPERION AIR, INC., 
15 
PASSENGER MANIFEST 
■ 
PLAINTIFF'S EX. 6 PHOTO 
63 
I 
PLAINTIFF'S EX. 7 PHOTO 
65 
. 
PLAINTIFFS EX. 8 PHOTO 
68 
. 
9
PLAINTIFF'S EX. 
PHOTO 
71 
1 II 
On 
o 
e 
atm% s. 
. I 
19 
PLAINTIFFS EX. 1 0 PHOTO 
100 
19 
KATHERINE W. EZELL, ESQUIRE 
PLAINTIFF'S EX. II PHOTO 
101 
AMY JOSEFSBERG EDERI, ESQUIRE 
20 
PLAINTIFF'S EX. 12 PHOTO 
103 
20 
R 
PLAINTIFF'S EX. 4 PHONE MESSAGE PADS 
21 
PLAINTIFF'S EX. 5 CELLPHONE RECORDS 
PLAINTIFFS EX. 13 PHOTO 
144 
22 
one: 
22 
23 
(Via tekpbone) 
23 
24 
24 
25 
25 
Page 6 
Page 8 
I 
Appearances contimied... 
1 
PROCEEDINGS 
2 
On behalf of the Plaintiff. Jane Doe II: 
3 
ISIDRO MANUEL GARCIA, ESQUIRE 
2 
— — — 
GARCIA EI.K1NS & BOEHRINGER 
3 
THE VIDEOGRAPHER: We are now on video 
4 
I 
record. This is Media No. 1 in the videotaped 
5 
deposition of 
in the matter of
6 
Jane Doc versus Jeffrey Epstein, et al. Today 
7 
On behalf of the Defendant: 
8 
JACK ALAN GOLDBERGER, ESQUIRE 
7 
is Wednesday, March 24th, 2010. It is 
ATTERBURY GOLDBERGER & WEISS, P.A. 
8 
10:36 a.m. We are here at Prose Court 
9 
Reporting, 250 South Australian Avenue, West 
il 
Palm Beach, Florida. 
11 
My name is Joe Kozak. I'm the 
11 
12 
12 
videographer. The reporter is Cindy 
13 
On behalf of the Witness: 
13 
Hopkins from Prose Court Reporting Agency. 
14 
BRUCE E. REINHART. ESQUIRE 
14 
Would counsel please introduce 
LAW OFFICE OF BRUCE E. REINHART 
15 
yourselves, and then the court reporter 
will swear in the witness. 
17 
MR. KUVIN: Good morning. Spencer Kuvin 
1, 
18 
on behalf of one of the Plaintiffs. 
18 
19 
19 
MR. HOROWITZ: Adam Horowitz on behalf c 
20 
ALSO PRESENT: 
20 
Jane Does 2 through 8. And just for the record 
21 
Jessica Cadwell, Paralegal 
21 
purposes, the deposition is also being taken in 
Duman. Critton, Luther & Coleman, P.A. 
22 
Joseph Kozak, Videopapha 
22 
the federal cases, I believe, case being 
Prose Court Reponing Services 
23 
Jane Doe 2 versus Jeffrey Epstein. 
23 
24 
24 
MR. WEISSING: Man Weissing on behalf of 
25 
25 
three of the Plaintiffs. 
2 (Pages 5 to 8) 
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Docket 01/21/2015 Page 4 of 8 
Page 207 
1 
BY MR. KUVIN: 
2 
. Have you ever used the alias of 
3 
4 
MR. RHEINHART: Objection to the --I'm 
5 
sorry. Instruct the witness not to answer 
6 
based on Fifth Amendment privileges. 
7 
THE WITNESS: Upon the instruction of my 
8 
lawyer, I must invoke my Fifth Amendment right 
9 
BY MR. KUVIN: 
10 
Q. Do your parents live in North Carolina? 
11 
MR. RHEINHART: Instruct the witness not 
12 
to answer the question based on her Fifth 
13 
Amendment privilege. 
14 
THE WITNESS: On instruction of my lawyer 
15 
I must invoke my Fifth Amendment right. 
16 
BY MR. KUVIN: 
17 
Q. Do you have any brothers and sisters? 
18 
MR. RHEINHART: Same instruction as the 
19 
previous question. 
20 
THE WITNESS: On the instruction of my 
21 
lawyer, I must invoke my Fifth Amendment right 
22 
BY MR. KUVIN: 
23 
Q. Have your parents met Jeffrey Epstein? 
24 
MR. RHEINHART: Objection to the form. 
25 
Standing objection and also instruct the 
1 
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10 
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12 
13 
14 
15 
16 
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Page 209 
compound, instruct the witness not to answer. 
THE WITNESS: On the instruction of my 
lawyer, I must invoke my Fifth Amendment right 
BY MR. KUVIN: 
Q.Q. Have ou ever used illegal drugs with 
MR. RHEINHART: Same objection and 
instruction as to the previous question. 
THE WITNESS: On the instruction of my 
lawyer, I must invoke my Fifth Amendment right 
BY MR. KUVIN: 
Q. Did you ever use the phone number of 
MR. RHEINHART: Instruct the witness not 
to answer based on her Fifth Amendment 
privilege. 
THE WITNESS: On the instruction of my 
lawyer, I must invoke my Fifth Amendment right 
BY MR. KUVIN: 
Q. Have ou ever used the phone number 
MR. RHEINHART: Thank you. 
THE WITNESS: I don't recognize that 
number. 
1 
2 
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4 
5 
6 
7 
8 
9 
10 
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Page 208 
witness not to answer based on her Fifth 
Amendment privilege. 
THE WITNESS: On the instruction of my 
lawyer, I must invoke my Fifth Amendment right 
BY MR. KUVIN: 
Q. Do your parents know what you've done with 
Jeffrey Epstein as it relates to this case? 
MR. RHEINHART: Objection to the form as 
stated to the previous question, and same 
instruction. 
THE WITNESS: On the instruction of my 
lawyer, I must invoke my Fifth Amendment right 
BY MR. KUVIN: 
Q. Have you ever used illegal drugs with 
Jeffrey Epstein? 
MR. RHEINHART: Objection to the form. 
Standing objection, instruct the witness not to 
answer. 
THE WITNESS: On the instruction of my 
lawyer, I must invoke my Fifth Amendment right 
BY MR. KUVIN: 
Q. Have you ever used illegal drugs with 
Ghislaine Maxwell? 
MR. RHEINHART: Objection to the form, 
assumes knowledge of Ghislaine Maxwell. It's 
Page 210 
1 
BY MR. KUVIN: 
2 
Q. Okay. When the police entered Jeffrey 
3 
Epstein's home, they took something that's called a 
4 
bottle of Peach Flavored Joy Jelly. Just a 
5 
foundation of what I'm about to ask you. 
6 
Have you ever seen anything called Peach 
7 
Flavored Joy Jelly ever anywhere, first of all? 
8 
Have you ever seen that before anywhere? 
9 
MR. RHEINHART: Just so I am clear about 
10 
your question --
11 
MR. KUVIN: Not necessarily in a home, 
12 
just anywhere in her entire life has she ever 
13 
seen a bottle of something called Peach 
14 
Flavored Joy Jelly. 
15 
THE WITNESS: No, I have not. 
16 
BY MR. KUVIN: 
17 
Q. Okay. Also taken from the home were, was 
18 
an adult sex toy called a Twin Torpedo which, 
19 
according to Detective Recarey during his depositior 
20 
was a double-headed dildo. Not with respect to 
21 
Mr. Epstein, but in your life, have you ever seen 
22 
something called a Twin Torpedo or double-headed 
23 
dildo? 
24 
A. No, I have not 
25 
Q. Also confiscated from the home was soap in 
6 (Pages 207 to 210) 
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Case 9:08-cv-80736-1O-A Document 291-20 Entered on FL. i Docket 01/21/2015 Page 5 of 8 
Page 211 
Page 213 
1 
the shape of a penis and vagina. Once again, not 
1 
THE WITNESS: On the instruction of my 
2 
necessarily with respect to Mr. Epstein's home, in 
2 
lawyer, I must invoke my Fifth Amendment right 
3 
your entire life have you ever seen soap in the 
3 
BY MR. KUVIN: 
4 
shape of a penis and vagina? 
4 
Q. Do you agree that these corporations that 
5 
A. Not that I recall. 
5 
I just mentioned were utilized by Jeffrey Epstein in 
6 
Q. Do you ever recall being in Ohio? 
6 
an attempt to have sexual relationships with 
7 
MR. RHEINHART: Ever in her life? 
7 
underage girls? 
8 
MR. KUVIN: The slate, ever in her life. 
B 
MR. RHEINHART: Objection to the form as 
9 
BY MR. KUVIN: 
9 
to compound, and also assumes knowledge of 
10 
Q. Let's start there, recall being in the 
10 
Mr. Epstein, asks for more than one answer to 
11 
State of Ohio for any reason? 
11 
the question. I would instruct her not to 
12 
A. Maybe for a layover, but not that 1 
12 
answer based on her Fifth Amendment privilege 
13 
specifically remember. 
13 
because the question assumes knowledge of 
14 
Q. Okay. Do you know an Ivan Robles? 
14 
Mr. Epstein. 
15 
A. No. 
15 
THE WITNESS: Upon instruction of my 
16 
Q. Have you seen a gentleman by the name o ' 16 
lawyer I must invoke my Fifth Amendment right. 
17 
Alan Dershowitz at the home of Jeffrey Epstein 
17 
MR. KUVIN: I think I am done. Hang on 
18 
before? 
18 
one second. 
19 
MR. RHEINHART: Objection to the form. 19 
All right. I appreciate it. That's all 
20 
Standing objection, presumes knowledge of 
20 
the questions I have at this time. Reserve the 
21 
Jeffrey Epstein or his home. Instruct the 
21 
right to ask any follow-up questions if other 
22 
witness not to answer. 
22 
attorneys raise new and different issues by 
23 
THE WITNESS: On the instruction of my 
23 
their questioning. 
24 
lawyer, I must exercise my Fifth Amendment 
24 
MR. RHEINHART: Understood. 
25 
right. 
25 
MR. KUVIN: Pass the witness at this time. 
Page 
Page 214 
1 
BY MR. KUVIN: 
1 
Who wants to go? Mr. Horowitz, do you have a 
2 
Q. Have you ever heard of the El Zorro Ranch 
2 
microphone? 
3 
Corporation? 
3 
MR. HOROWITZ: I do. 
4 
MR. RHEINHART: Instruct the witness not 
4 
CROSS (
) 
5 
to answer based on her Fifth Amendment 
5 
BY MR. IIOROWITZ: 
6 
privilege. 
6 
Q. Ms. 
did ou use the telephone 
7 
TIIE WITNESS: On the instruction of my 
7 
number, the 
at any time between 2001 
8 
lawyer I must exercise my Fifth Amendment 
B 
and 2006? 
9 
right. 
9 
A. On the advice of my lawyer, I must exercise m 
10 
BY MR. KUVIN: 
10 
Fifth Amendment right 
11 
12 
Q. Have you ever heard of the New York 
Strategy Group? 
11 
12 
. Didyou use the telephone number 
between 2001 and 2006 at Jeffrey 
13 
MR. RHEINHART: Same instruction. 
13 
Epstein's expense? 
14 
THE WITNESS: On the instruction of my 
14 
MR. RHEINHART: Objection to the form in 
15 
lawyer, I must invoke my Fifth Amendment right 15 
that it assumes knowledge of Jeffrey Epstein. 
16 
BY MR. KUVIN: 
16 
Standing objection as previously stated with 
17 
Q. Have you ever heard of the Ghislaine 
17 
Mr. Kuvin. Instruct the witness not to answer, 
18 
Corporation? 
18 
based on her Fifth Amendment right. 
19 
MR. RHEINHART: Same instruction. 
19 
THE WITNESS: On the instruction of my 
20 
THE WITNESS: On the instruction of my 
20 
lawyer, I must exercise my Fifth Amendment 
21 
lawyer, I must invoke my Fifth Amendment right 21 
right. 
22 
BY MR. KUVIN: 
22 
BY MR. HOROWITZ: 
23 
24 
Q. Have you ever heard of the Financial 
Strategy Group? 
23 
24 
. Didyou use the telephone number 
at Jeffrey Epstein's direction? 
25 
MR. RHEINHART: Same instruction. 
25 
MR. RHEINHART: Same objection as the 
7 (Pages 211 to 214) 
PROSE COURT REPORTING AGENCY, INC. 
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Case 9:08-cv-80736-Krwil Document 291-20 Entered on FL_J Docket 01/21/2015 Page 6 of 8 
Page 315 
So can we focus on the specific questions 
2 
that she can answer or from which you can draw 
3 
an adverse inference if asked properly, and 
4 
let's move it along. 
5 
MS. EZELL: Each young woman's case is an 
6 
individual case, and we have the right to ask, 
7 
ask whatever questions that we need to with 
8 
regard to each one. 
9 
MR. RHEINHART: I --
10 
MR. GOLDBERGER: Let's just go forward 
11 
until 5:00 and see where we're at. 
12 
BY MR. WEISSING: 
13 
Q. Did you know that Jeffrey Epstein received 
14 
sexual gratification from directing others to 
15 
sexually abuse minor children? 
16 
MR. RHEINHART: Objection to the form. 
17 
THE WITNESS: On the instruction of my 
18 
lawyer, l must invoke the Fifth Amendment 
19 
right. 
20 
BY MR. WEISSING: 
21 
Q. Did you know that Jeffrey E stein received 
22 
sexual gratification from directing 
to 
23 
sexually abuse minor children? 
24 
MR. RHEINHART: Objection to the form. It 
25 
assumes knowledge of a person named 
Page 317 
1 
THE WITNESS: On the instruction of my 
2 
lawyer, I must invoke my Fifth Amendment 
3 
privilege. 
4 
BY MR. WEISSING: 
5 
Q. Do you know Alan Dershowitz? 
6 
MR. RHEINHART: The question was asked and 
7 
answered about three-and-a-half hours ago. 
8 
THE WITNESS: On the instruction of my 
9 
lawyer, I must invoke my Fifth Amendment 
10 
privilege. 
11 
BY MR. WEISSING: 
12 
Q. Do you know David Copperfield? 
13 
MR. RHEINHART: That question was asked 
14 
about three-and-a-half-hours ago. 
15 
THE WITNESS: On the instruction of my 
16 
lawyer, I must invoke my Fifth Amendment 
17 
privilege. 
18 
BY MR. WEISSING: 
19 
Q. In addition to his place at, in Palm 
20 
Beach, are you aware that Jeffrey Epstein has an 
21 
apartment located at 301 East 66th Street, Apartment 
22 
14O through E in New York? 
23 
MR. RHEINHART: That question was asked 
24 
about four hours ago. It's been asked and 
25 
answered. 
Page 316 
1 
It is otherwise compound and objectionable. 
1 
2 
THE WITNESS: On the instruction of my 
2 
3 
lawyer, I must invoke my Fifth Amendment right. 
3 
4 
MR. WEISSING: Let's go off the record for 
4 
5 
a moment. 
5 
6 
THE VIDEOGRAPHER: Arc we all good with 6 
7 
going off the record? 
7 
MR. RHEINHART: Yeah, that's fine. 
8 
9 
MR. HOROWITZ: Yes. 
9 
10 
THE VIDEOGRAPHER: We're now off the 
10 
11 
record at 4:22 p.m. 
11 
12 
(A brief recess was held.) 
12 
13 
THE VIDEOGRAPHER: We are now on the 
13 
14 
record. It is 4:24 p.m. 
14 
15 
BY MR. WEISSING: 
15 
16 
Q. Do you know 
16 
17 
MR. KUVIN: 
17 
18 
THE WITNESS: On the instruction of my 
18 
19 
lawyer, I must invoke my Fifth Amendment 
19 
20 
privilege. 
20 
21 
BY MR. WEISSING: 
21 
22 
Q. Do you know -- have you procured minor 
22 
23 
children to have sexual relations with 
23 
29 
at Jeffrey Epstein's mansion? 
24 
25 
MR. RHEINHART: Objection to the form. 
25 
Page 318 
THE WITNESS: At the instruction of my 
lawyer, I invoke my Fifth Amendment privilege 
BY MR. WEISSING: 
Q. While in New York, have you procured 
underage minor children to engage in sexual acts 
with Jeffrey Epstein at that location? 
MR. RHEINHART: Object to the form. 
THE WITNESS: On the instruction of my 
lawyer, I must invoke my Fifth Amendment 
privilege. 
BY MR. WEISSING: 
Q. With regard to the minor children procured 
for him at that location, were they school children 
in the New York area? 
MR. RHEINHART: The previous question, 
objection to the form. The same as all the 
previous questions, it assumes a fact that's 
not been established. It can't fairly be 
answered. 
THE WITNESS: On the instruction of my 
lawyer, I must invoke my Fifth Amendment 
privilege. 
BY MR. WEISSING: 
Q. Did Jeffrey Epstein have sexual encounters 
with underage people while at that apartment? 
33 (Pages 315 to 318) 
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Page 433 
1 
know what the Edge Group was, but whatever, you car 
2 
answer the question. 
3 
THE WITNESS: At the instruction of my lawyer, 
4 
I must choose to invoke my Fifth Amendment right. 
S 
BY MS. EZELL: 
6 
Q. Do you know Max Brockman? 
7 
MR. REINHART: Pm sorry, can you repeat? 
8 
BY MS. EZELL: 
9 
Q. Do you know a Max Brockman? 
10 
MR. REINHART: I believe that was asked and 
11 
answered already, but --
12 
THE WITNESS: At the instruction of my lawyer, 
13 
I must invoke my Fifth Amendment right. 
14 
BY MS. EZELL: 
15 
Q. Have you ever been photographed with Max 
16 
Brockman at an Edge Science dinner? 
17 
A. At the instruction of my lawyer, I must invoke 
18 
my Fifth Amendment right. 
19 
MR. REINHART: You should let me -- I need to 
20 
object to the form of the question first, but go 
21 
ahead. I know we all want to get out of here. Go 
22 
ahead. 
23 
THE WITNESS: Say it again. 
24 
MR. REINHART: No, you arc okay. Go ahead, 
25 
Ms. Ezell. Thank you. 
Page 435 
1 
BY MS. EZELL: 
2 
Q. Do you want to respond? I didn't give you 
3 
time. 
4 
MR. REINHART: I've instructed her not to 
5 
answer the question. Let's move on. 
6 
BY MS. EZELL: 
7 
Q. Do you recall a dinner at El Brillo Way 
8 
attended by David Copperfield where Jane No. 103 was 
9 
guest? 
10 
MR. REINHART: Objection to the fomi, lack of 
11 
foundation, and a standing objection as to her 
12 
knowledge of anything involving El Brillo Way or 
13 
Jeffrey Epstein. Instruct her not to answer. 
14 
THE WITNESS: At the instruction of my lawyer, 
15 
I must invoke my Fifth Amendment right. 
16 
BY MS. EZELL: 
17 
Q. What is the relationship between Jeffrey 
18 
Epstein and David Copperfield? 
19 
MR. REINHART: Objection to form, lack of 
20 
foundation as to her knowledge of either one of 
21 
those people. Instruct her not to answer. 
22 
THE WITNESS: At the instruction of my lawyer, 
23 
I must invoke my Fifth Amendment right. 
24 
BY MS. EZELL: 
25 
Q. To your knowledge, do they recruit girls for 
1 
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18 
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Page 434 
BY MS. EZELL: 
Q. Do you know whether Jeffrey Epstein attended 
the Edge Science dinner in Monterey, California? 
MR. REINHART: Objection to the form, lack o 
foundation. Instruct the witness not to answer. 
THE WITNESS: At the instruction of my lawye 
I must invoke my Fifth Amendment right. 
BY MS. EZELL: 
Q. You testified a moment ago that you were 
photographed nude by your boyfriend or a former 
boyfriend and that you hoped there are no photographs 
disseminated elsewhere. 
At what age were those photographs taken? 
MR. REINHART: I'm going to instruct her not 
to answer that. It has nothing to do with 
anything. It's not reasonably calculated to lead 
to discoverable evidence. We can move on. 
BY MS. EZELL: 
Q. Were you in any way damaged by that 
experience? 
MR. REINHART: Same instruction. Let's move 
on. 
BY MS. EZELL: 
Q. Do you have any regrets? 
MR. REINHART: Same instruction. Move on. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
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Page 436 
one another? 
MR. REINHART: Object to the form, compoun 
and again, lack of foundation. Instruct her not to 
answer. 
THE WITNESS: At the instruction of my lawye-, 
I must invoke my Fifth Amendment right. 
BY MS. EZELL: 
Q. To your knowledge, are they involved in any 
sexual trafficking of young women? 
MR. REINHART: Object to the form for the 
reasons previously stated. Also calls for a legal 
conclusion as to what sexual trafficking is. 
Instruct her not to answer. 
THE WITNESS: At the instruction of my lawye-
I must invoke my Fifth Amendment right. 
BY MS. EZELL: 
Q. I believe you asked about Allen Dershowitz 
earlier. 
MR. REINHART: Twice. 
BY MS. EZELL: 
Q. And were instructed not to answer. 
MR. REINHART: Twice. 
BY MS. EZELL: 
Q. All right. I'm going to ask again on behalf 
of my client. Are you aware of the friendship between 
18 (Pages 433 to 436) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Rachel Bridge (201.272417.4627) 
905d1499-0cd8-46994280-6d3a827b68c6 
EFTA00188942

Case 9:08-cv-80736-K...v1 Document 291-20 Entered on FL_ J Docket 01/21/2015 Page 8 of 8 
Page 437 
Page 439 
1 
Allen Dershowitz and Jeffrey Epstein? 
1 
BY MS. EZELL: 
2 
MR. REINHART: And for the third time, I'll 
2 
Q. Do you know that when David Copperfield is in 
3 
object to the form and instruct her not to answer 
3 
town, he gives Jeffrey Epstein tickets and Jeffrey gives 
4 
the question. 
4 
some to young women to attend those shows? 
5 
THE WITNESS: For the third time, I take the 
5 
MR. REINHART: Object to the form, multiple, 
6 
advice of my lawyer and invoke my Fifth Amendment 
6 
compound question, and a complete lack of 
7 
right. 
7 
foundation. Instruct the witness not to answer. 
8 
BY MS. EZELL: 
B 
THE WITNESS: At the instruction of my lawyer, 
9 
Q. When Allen Dershowitz comes to Palm Beach, he 
9 
I must invoke my Fifth Amendment right. 
10 
stays at the El Brillo mansion, doesn't he? 
10 
BY MS. EZELL: 
11 
MR. REINHART: Objection to the form. There 
11 
Q. And do you know that those girls are invited 
12 
is no foundation for her having any knowledge of 
12 
back stage after the show? 
13 
anything having to do with a person by the name of 
13 
MR. REINIIART: Same objection, complete lack 
14 
Allen Dershowitz. I instruct her not to answer. 
14 
of foundation, and standing objection previously 
15 
THE WITNESS: At the instruction of my lawyer, 
15 
stated. 
16 
I must invoke my Fifth Amendment right. 
16 
THE WITNESS: At the instruction of my lawyer. 
17 
BY MS. EZELL: 
17 
I must invoke my Fifth Amendment right. 
18 
Q. When Allen Dershowitz, or has Allen Dershowitz 
18 
BY MS. EZELL: 
19 
ever been there when young ladies came to give massages'? 19 
Q. Do you remember on or about, in or about March 
20 
MR. REINHART: Same objection stated to the 
20 
of 2005 having conversations with one of the young wome 
21 
previous question. Same instruction. 
21 
who came to the house to give massages about her 
22 
THE WITNESS: At the instruction of my lawyer, 
22 
conversations with Jane No. 103? 
23 
I must invoke my Fifth Amendment right. 
23 
MR. REINHART: Objection to the form, standing 
24 
BY MS. EZELL: 
24 
objection, lack of foundation. Instruct the 
25 
Q. Has Allen Dershowitz ever been the beneficiary 
25 
witness not to answer, because the question implies 
Page 438 
Page 440 
1 
of those massages? 
1 
that she has any knowledge at all of El Brillo Way. 
2 
MR. REINHART: Same objection and same 
2 
BY MS. EZELL: 
3 
instruction. 
3 
Q. Same question — sorry. 
4 
THE WITNESS: At the instruction of my lawyr, 
4 
A. At the instruction of my lawyer, I must choose 
5 
I must invoke my Fifth Amendment right. 
5 
to invoke my Fifth Amendment privilege. 
6 
BY MS. EZELL: 
6 
Q. Same question as to March of 2006. 
7 
Q. Do you know John Casablanca? 
7 
MR. REINHART: Same objection and same 
8 
A. Never heard that name before. 
8 
instruction. 
9 
Q. Have you ever heard of a world-famous 
9 
THE WITNESS: At the instruction of my lawyer, 
10 
illusionist whose stage name is David Copperfield? 
10 
I must choose to invoke my Fifth Amendment 
11 
MR. REINHART: That's also been asked at leas 11 
privilege. 
12 
three times. I'll instruct her again not to answer 
12 
BY MS. EZELL: 
13 
the question. 
13 
Q. Do you have any recollection of a conversation 
14 
THE WITNESS: At the instruction of my lawyc, 14 
in which one of the young women told Jane No. 103 tha 
15 
I must invoke my Fifth Amendment right. 
15 
those girls who, those girls who would help Jeffrey in 
16 
BY MS. EZELL: 
1.6 
regard to the investigation would be compensated and 
17 
Q. Have you ever gone to one of David 
17 
those who would not or who would hurt him in the 
18 
Copperfield's shows? 
18 
investigation would be dealt with? 
19 
MR. REINHART: Objection to form, lack of 
19 
MR. REINHART: Objection to the form, lack of 
20 
foundation as to knowledge of any person by the 
20 
foundation, compound question. Instruct the 
21 
name of David Copperfield. Instruct her not to 
21 
witness not to answer, because the question implies 
22 
answer. 
22 
some knowledge of anything relating to a person by 
23 
THE WITNESS: At the instruction of my lavge-, 23 
the name of Jeffrey Epstein. 
24 
1 must invoke my Fifth Amendment right. 
24 
THE WITNESS: At the instruction of my lawyer 
25 
25 
1 must invoke my Fifth Amendment right. 
19 (Pages 437 to 440) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Rachel Bridge (201-272-8174627) 
906d1409-0cd8-4599-a2a0-6d38827b680 
EFTA00188943

I
EFTA00188944

Case 9:08-cv-80736-i 
,%/1 Document 291-21 Entered on F 
.D Docket 01/21/2015 Page 1 of 7 
EXHIBIT 22 
EFTA00188945

Case 9:08-cv-807364, 0.1 Document 291-21 Entered on F D Docket 01/21/2015 Page 2 of 7 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON 
JANE DOE, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, et al., 
Defendants. 
Related Cases: 
08-80119, 08-80232, 08-80380, 08-80381, 
08-80994, 08-80811, 08-80893, 09-80469, 
09-8-591, 09-80656, 09-80802, 09-81092 
VIDEOTAPED DEPOSITION OF 
TAKEN ON BEHALF OF THE PLAINTIFF 
DATE: April 13, 2010 
U.S. Legal Support 
(561) 835-0220 
EFTA00188946

Case 9:08-cv-RIITze-t 
l 
Donnrnent 291-21 Entered on F 
iD Docket 01/21/2015 Page 3 of 7 
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April 13,2010 
INDEX 
WITNESS 
DIRECT CROSS REDIRECT RECROSS 
3 
BY MR. EDWARDS 
5 
98 
BY MR. HOROWITZ 
65 
BY MR. LANGINO 
77 
BY MS. EZELL 
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EXHIBITS 
PLAINTIFF'S 
FOR IDENTIFICATION 
I 
Message elated August 21,2005. 
PAGE 
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ft 
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APPEARANCIES (CONTINUED) 
LEOPOLD-KUVIN 
Altai ncys (or 
and CE 
fst) 
BY: ADAM J. LANGINO, ESQ, 
PODIIURST.ORSECK 
Attorneys for Jane Doss I awl 3 
Cit Nainmel Bank Building. Suite 88 
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i.
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: . EZELL ESQ. 
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BURMAN, CRIITON, to
 & COLEMAN. LIP 
Alaaneys rot Defendant Jemn Epstein 
BY: DAVID YARC14A. ESQ. 
ROBERT CRIT ION, ESQ. 
ATIERBURY. GOLDBERGER & WEISS 
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Co Conrad for Defendants 
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ACK A. GOLOUEROCR,ESQ• 
ALSO PRESEPIC 
JESSICA CADWELL 
JOE ROVNER, Videographee 
(U.S. Legal) 
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The videotaped deposition of 
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in the above-entil.numbcred 
cause, was to en 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 lime and place 
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were as follows: 
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FARMER, JAFFE, WEISSING, EDWARDS, 
FISTOS & LEHRMAN, PL. 
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Attorneys for PinintilTs June Does, 
L.N. and 
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• 
c: 
524-2820 
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BY: BRADLEY J. EDWARDS, ESQ. 
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MERMELSTEIN & HOROWITZ, P.A. 
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Attorneys for Plaintiffs Jane Does, 
numbers 2 throu I 
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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 first duly sworn to tell 
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the whole truth, as hereinafter certified, 
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testified as follows: 
DIRECT EXAMINATION 
BY MR. EDWARDS: 
Q Can you tell us your name. 
A 
Q What is your date of birth? 
A 
Q What is your Social Security number? 
A Under advice of my counsel, I invoke my 
privileges under the Fifth and Sixth Amendments 
to the United States Constitution and 
respectfully decline to answer the question. 
Q Where were you bona 
A I'm sorry, though I would like to unmetr 
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 
continual, obviously, you anticipate I'm 
sure, continued invocation of Fifth 
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