EFTA01087055

Page 172 
IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE No. 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
CONTINUED DEPOSITION OF JEFFREY EPSTEIN 
VOLUME III 
Thursday, October 8, 2009 
1:46 - 3:48 p.m. 
250 South Australian Avenue 
Suite 1400 
West Palm Beach/ Florida 33401 
Reported By: 
Jeana Ricciuti, RPR, FPR, CLR 
Notary Public, State of Florida 
Prose Court Reporting Agency, Inc. 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciuti 
Electronically signed by Joann Moduli 
WMMMAIO-496c-aVW099977073134 
EFTA01087055

1' ..:4c 17j 
Page 175 
70 
21 
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SPENCER T. KUYIN, ESQUIRE 
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ADANILANOINO, ESQUIRE 
LEOPORD KUV1N, PA 
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Florida 33410 
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ALSO P
DAN DOM( RY, VIDLOORAP2IER 
VISUAL EVIDISNCE,IXC. 
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PROCEEDINGS 
THE VIDEOGRAPHER: We're back on the record at 
1:46. 
CONTINUED DIRECT EXAMINATION 
BY MR. KUVIN: 
Q. Do you personally know John Mack, former CEO 
al Morgan Stanley? 
A. I'll have to answer that the same way I've 
answered most of your questions here today, Mr. Kuvin, 
NyhIch is, I intend to respond to all relevant questions 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled me I cannot provide answers to 
any questions relevant to this lawsuit. I must accept 
this advice or risk losing my Gth Amendment right to 
effective representation. Accordingly, I assert my 
federal constitutional rights as guaranteed by the 5th, 
6th and 14th Amendment to the United States 
Ccestitution. 
MR. KUVIN: Okay. Same deposition as shown 
before, different clip. I'm going to play it for 
counsel first. 
MR. PIKE: 'thank you. 
MR. KUVIN: Mr. V ideowapher, just let me know 
when you're ready. 
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- - - 
EXHIBITS 
- • • 
WITNESS: 
CONEDDIRECT 
JEFFREY EPSTEIN 
BY MR. KUVIN 
175 
EXHIBITS 
Page 174 
10 
NUMBER 
DESCRIPTION 
PAGI 
11 
PLAINTIFFS EX. 9 
PHOTOGRAPH OF GHISLA1NE 
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MAXWELL 
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PLAINTIFFS FM 10 PHOTOGRAPH OF 
191 
. 
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PLAINTWFS 
1 PHOTOORAPHOF 
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PIAINTWFS EX. 12 
PHOTOGRAPH 
19 
PLAINTIFFS EX 13 PHOTOGRAPH OF 
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PIAINT1FFS 
RAPH OF 
15
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PLAINTIFFS EX 16 PHOTOGRAPH OF 
• 
PtAtbnifFs E .Is PH 
RAPE! OF 
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111.11 
ANDREW 
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PLAINTIFFS EX. 17 LETTERTOB. KRISCHER FROM 203 
M. REITER 
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PLAINTIFFSEX. IS RECEIPT OF PURCHASES MADE 206 
FROM JAIL 
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PLAINTIFFS EX. 19 FAA REGISTRY 
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Page 176 
THE VIDEOGRAPHER: Whenever you are. 
2 
MR. KUVIN: Okay. 
3 
(Video played.) 
4 
VIDEO WITNESS: "What did I do to Jeffrey and 
5 
what did Jeffrey do to me? I went up there 
6 
multiple times; I can't count. And I would be on a 
7 
massage table, massaging his legs, he would turn 
8 
over, his penis would be hanging out. He would put 
9 
a vagina -- or a vibrator to my vagina, lie would 
10 
touch my vagina with his fingers. He would touch 
11 
my breasts. He would try to kiss my mouth. He 
12 
would bring my hands toward his penis." 
13 
(Video stopped.) 
14 
MR. KUVIN: Okay. 
MIL PIKE: I'm just going to object to the use 
16 
of the video as to relevance, predicate and 
17 
foundation. 
18 
BY MR- KUVIN: 
19 
Q. All right. Let me get it back to the same 
20 
location, 
21 
Sir, first of all, once again, just sol can 
22 
lay the foundation for this, do you recognize this girl? 
23 
A. I'm going to have to respond to that question 
24 
the same way I've responded to most of your other 
25 
questions hero today, which is, I intend to respond to 
2 (Pages 173 to 176) 
PROSE COURT REPORTING AGENCY, INC. 
• 
Electronically signed by Jeana Ricciuti 
- 
- 
Electronically signed by Jeana Ricclutl 
bleclerlf0410498e4244•099977073134 
EFTA01087056

Page 177 
1. 
all relevant cannot provide answers to any questions 
2 
relevant to this lawsuit; however, at the present time, 
3 
my attorneys have counseled me I cannot provide answers 
4 
to any questions relevant to the lawsuit. I must accept 
this advice or risk losing my 6th Amendment right to 
6 
effective representation. Accordingly, I assert my 
7 
federal constitutional rights as guaranteed by the 5th, 
8 
6th and 14th Amendment to the United States 
9 
Constitution. 
10 
Q. Did this girl brings to your home for a 
11 
naked massage? 
12 
A. Pm going to have to respond to that the same 
13 
way I've responded to most of your other questions here 
14 
today, which Is, I Intend to respond to all relevant 
15 
questions regarding this lawsuit; however, at the 
16 
present time, my attorneys have counseled me I cannot 
17 
provide answers to any questions that may be relevant to 
18 
the lawsuit. I must accept this advice or risk losing 
19 
my 6th Amendment right to effective representation. 
20 
Accordingly, I assert my federal constitutional rights 
21 
as guaranteed by the 5th, 6th end 14th Amendment to the 
22 
United States Constitution. 
23 
Q. I'd like to play this clip for you and then 
24 
Pm going to ask you a question. 
25 
MR. PIKE: The same clip you just played? 
Page 179 
1 
the United States Constitution. 
2 
BY MR. KUVIN: 
3 
Q. Did you do what that young lad 
d
e
s
c
r
i
b
e
d
 
just 
4 
now to hundreds of women, including 
M
.
 
?
 
5 
MR. PIKE: Form, argumentative, harassing, 
6 
lacks appropriate predicate, foundation, lacks 
identity. 
8 
THE WITNESS: Excuse me. Pm going to respond 
9 
to that the same way I've responded to most of your 
10 
other questions here today, which is, I intend to 
11 
respond to all relevant questions regarding this 
12 
lawsuit; however, at the present time, my attorneys 
13 
have counseled me that I cannot provide answers to 
14 
any questions relevant to the lawsuit. I must 
15 
accept their advice or risk losing my 6th Amendment 
16 
right to effective representation. Accordingly, I 
17 
must assert my federal constitutional rights as 
18 
guaranteed by the 5th, 6th and 14th Amendment to 
19 
the United States Constitution. 
20 
BY MR. KUVIN: 
21 
Q. While. was standing naked in your home, 
22 
specifically in your bathroom, did you tell her that you 
23 
could get her an interview as a model because of your 
24 
connections? 
25 
A. I'm going respond to that the same way I've 
Page 178 
1 
MR. KUVIN: Exactly. 
2 
MR. PIKE: Same objection. 
3 
(Video played.) 
4 
VIDEO WITNESS: "What did I do to Jeffrey and 
5 
what did Jeffrey do to me? I went out there 
6 
multiple times; I can't count. And I would be on a 
7 
massage table, massaging his legs. Ho would turn 
8 
over, his penis would be hanging out. He would put 
9 
a vagina -- or vibrator to my vagina. He would 
10 
touch my vagina with his fingers. He would touch 
11 
my breasts. He would try to kiss my mouth. He 
12 
would bring my hands toward his penis." 
13 
(Video stopped.) 
14 
BY MR. KUVIN: 
15 
Q. Did you do that with that girl? 
16 
MR. PIKE: Fenn. 
17 
THE WITNESS: I intend to respond to all 
18 
relevant questions regarding this lawsuit; however, 
19 
at the present time, my attorneys have counseled me 
20 
I cannot provide answers to any questions that may 
21 
be relevant to this lawsuit. I must accept this 
22 
advice or risk losing my 6th Amendment right to 
23 
effective representation. Accordingly, I must 
24 
assert my federal constitutional rights as 
25 
guaranteed by the 5th, 6th and 14th Amendment to 
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Page 180 
responded to most of your questions today, Spencer. I 
intend to respond to all relevant questions regarding 
this lawsuit; however, at the present time, my attorneys 
have counseled me I cannot provide answers to any 
questions that may be relevant to the lawsuit. I must 
accept this advice or risk losing my Gth Amendment right 
to effective representation. Accordingly, I must assert 
my federal constitutional right as guaranteed by the 
5th, 6th and 14th Amendment to the United States 
Constitution. 
MR. PIKE: Same objection to that line of 
questioning. 
BY MR. KUVIN: 
Q. As. 
was standing naked in your bathroom 
before you when she was 15, did you ask her to turn 
around so you could see her ass better? 
MR. PIKE: Form, argumentative, harassing. 
lacks appropriate predicate, foundation. 
THE WITNESS: ri1 respond to that as I 
responded to your last question, which is, I intend 
to respond to all relevant questions regarding this 
lawsuit; however, at the present time, my attorneys 
have counseled me I cannot provide answers to any 
questions that may be relevant to this lawsuit. I 
must accept their advice or risk losing my 6th 
3 (Pages 177 to 180) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciuti 
Electronically signed by Jeana RIccluti 
bl8d9df0-4fcb-496c-a244-099977073134 
EFTA01087057

Page 181 
1 
Amendment right to effective representation; 
2 
therefore, I must assert my federal constitutional 
3 
rights as guaranteed by the 5th, 6th and 14th 
4 
Amendment to the United States Constitution. 
5 
BY MR. KUVIN: 
6 
Q. When M. was 15 years old and standing naked 
7 
in front of you in your bathroom, did you tell her that 
8 
you could help her become a model? 
9 
MR. PIKE: Same objections, including 
10 
foundation. 
11 
THE WITNESS: Is it different than the last 
12 
question? 
13 
MR. KUVIN: Uh-huh. 
14 
MR. GOLDBEftGER: Just go ahead. 
15 
THE WITNESS: Okay. I intend to respond to 
16 
all relevant questions pertaining to this lawsuit; 
17 
however, at the present time, my attorneys have 
18 
counseled me I cannot provide answers to any 
19 
questions that may be relevant to this lawsuit, so 
20 
I've answered most questions here today the same 
21 
way. I must expect that - accept their advice or 
22 
risk losing my 6th Amendment right to effective 
23 
representation. Accordingly, I assert my federal 
24 
constitutional rights as guaranteed by the 5th, Gth 
25 
and 14th Amendment to the United Slates 
Page 183 
1 
Q. And her father is Robert Maxwell? 
2 
A. Was Robert Maxwell. 
3 
Q. Pm sorry, he's passed, correct? 
4 
A. Correct. 
5 
Q. She is a close friend of yours, is she not? 
6 
A. Fm going to respond to that question the same 
7 
way I've responded to most of your other questions here 
8 
today, Mr. Kuvin, which is, I intend to respond to all 
9 
relevant questions regarding to this lawsuit; however, 
10 
at the present time, my attorneys have counseled me I 
11 
cannot provide answers to any questions that may be 
12 
relevant to this lawsuit. I must expect — accept their 
13 
advice or risk losing my 6th Amendment right to 
14 
effective representation. Accordingly, I must assert my 
15 
federal constitutional rights as guaranteed by the 5th, 
16 
6th and 14th Amendment to the United States 
17 
Constitution. 
18 
Q. Ghisluine Maxwell has accompanied you to 
19 
numerous social events in the last few years; isn't that 
20 
true? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: I'm going to respond to that 
23 
question the same way I've responded to most of 
24 
your questions here today, which is, I intend to 
25 
respond to all relevant questions regarding your 
Page 1.87 
1 
Constitution. 
2 
BY MR. KUVIN: 
3 
Q. Who is GhIslaine Maxwell? 
4 
A. I intend to respond to all relevant questions 
5 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled me that I cannot provide 
7 
answers to any questions relevant to this lawsuit. As I 
8 
have done to most of your other questions here today, I 
9 
must accept their advice or risk losing my 6th Amendment 
10 
right to effective representation. Accordingly, I 
11 
assert my federal constitutional rights as guaranteed by 
12 
the 5th, 6th and 14th Amendment to the United States 
13 
Constitution. 
14 
MR. KUVIN: Let me show the camera what we'll 
15 
mark as Exhibit 9 to this deposition. 
16 
THE VIDEOGRAPI-IER: Okay. 
17 
(Plaintiffs Exhibit No.9 was marked for 
18 
identification.) 
19 
BY MR. KUVIN: 
20 
Q. Let me show you what we've marked as Exhibit 9 
21 
to your deposition. Do you recognize Ghislaine Maxwell 
22 
in this photograph? 
23 
A. Yes. 
24 
Q. And who is she standing with? 
25 
A. Her father. 
Page 184 
1 
lawsuit; however, at the present time, my attorneys 
2 
have counseled me I cannot provide answers to any 
3 
questions that may be relevant to that lawsuit. I 
4 
must accept their advice or risk losing my 6th 
5 
Amendment right to effective representation. 
6 
Accordingly, I must assert my federal 
7 
constitutional right as guaranteed by the 5th, 6th 
8 
and 14th Amendment of the United States 
9 
Constitution. 
10 
BY MR. KUVIN: 
11 
Q. One of your houseboys that has been deposed in 
12 
this case testified that you were a rather nice 
13 
gentleman that used to talk to the staff, and that when 
14 
Ms. Maxwell came into the picture, that you stopped 
15 
talking to the staff and the staff had to communicate 
16 
through Ms. Maxwell. Do you agree or disagree with 
17 
that? 
18 
MR. PIKE: Form, foundation, predicate, 
19 
argumentative, assumes facts not in evidence. 
20 
THE WITNESS: I'm going to answer that the 
21 
same way I've answered most of your questions here 
22 
today, which is, I intend to respond to all 
23 
relevant questions regarding this lawsuit; however, 
24 
at the present time, my attorneys have counseled me 
25 
that I cannot provide answers to any questions that 
4 (Pages 181 to 184} 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Rican' (601-280.428.9381) 
Electronically signed by Jeana Flicciutl (601.280-428.9381) 
bf8d9O0-4(cb-496c-a244-09997 7073134 
EFTA01087058

Pogo 
1 
may be relevant to your lawsuit. I must accept 
2 
their advice or risk losing my 6th Amendment right 
3 
to effective representation. Accordingly, I assert 
4 
my federal constitutional rights as guaranteed by 
the 5th, 6th and 14th Amendment of the United 
6 
States Constitution. 
7 
BY MR. KUVIN: 
8 
Q. Ho also testified that he felt you were a 
9 
rather nomad guy until Ms. Maxwell came into the 
10 
picture, and that she led you into this life of 
11 
perversion, sexual perversion. Do you agree with that? 
12 
MR. PIKE: Same objections. 
13 
THE WITNESS: I'm going to respond to that the 
14 
same way I've responded to most of your questions 
15 
hem today, Mr. Kuvin, which is, I intend to 
16 
respond to all relevant questions regarding this 
17 
lawsuit; however, at the present time, my attorneys 
18 
have counseled me 1 cannot provide answers to any 
19 
questions relevant to this lawsuit. I must accept 
20 
their advice or risk losing my 6th Amendment --
21 
excuse me -- I must accept their advice or risk 
22 
losing my 6th Amendment right to effective 
23 
representation. Accordingly, I must assert my 
24 
federal constitutional rights as guaranteed by the 
25 
5th, 6th and 14th Amendment to the United States 
1 
3 
4 
5 
6 
1 
0 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
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Page 187 
to respond to all relevant questions regarding this 
lawsuit; however, at the present time, my attorneys 
have counseled me I cannot provide answers to any 
questions relevant to that lawsuit. I must accept 
their advice or risk losing my Gth Amendment right 
to effective representation. Therefore, I assert 
my federal constitutional rights as guaranteed by 
the 5th, 6th and 14th Amendments to the United 
Stales Constitution. 
BY MR. KUVIN: 
Q. Do you know where Donald Trump's Maralago 
estate is? 
A. Yes. 
Q. Have you been there? 
A. Yes. 
Q. Who with? 
A. Pm going to have to answer that question the 
same way I've answered most of your other questions here 
today. I intend to respond to all relevant questions 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled molcannot provide answers to 
any questions that may be relevant to the same lawsuit. 
I must accept their advice or risk losing my 6th 
Amendment right to effective representation. 
Accordingly, I must assert my federal constitutional 
Page 186 
1 
Constitution. 
2 
BY MR. KUVIN: 
3 
Q. Did Ms. Maxwell procure underaged girls for 
you to have sexual relationships with? 
5 
A. I'm going to answer that question the same way 
6 
I've answered most of your other questions today, 
7 
Mr. Kuvin, which is, I intend to respond to all relevant 
8 
questions regarding this lawsuit; however, at the 
9 
present time, my attorneys have counseled me I cannot 
10 
provide answers to any questions relevant to that 
11 
lawsuit. Excuse me. I must accept their advice or risk 
12 
losing my 6th Amendment right to effective 
13 
representation. Accordingly, I must assert my federal 
14 
constitutional rights as guaranteed -- guaranteed by the 
15 
5th, 6th and 14th Amendments to the United States 
16 
Constitution. 
17 
Q. Ms. Maxwell procured a particular underaged 
18 
girl who worked at Donald Trump's Maralago, for you to 
19 
have a sexual relationship with; isn't that true? 
20 
MR. PIKE: Form, argumentative, lacks 
21 
appropriate predicate, foundation, assumes facts 
22 
not in evidence. 
23 
THE WITNESS: I'm going to respond to that the 
24 
same way I've responded to most of your other 
25 
questions hero today, Mr. Kuvin, which is, I intend 
Page 188 
1 
rights as guaranteed by the 5th, 6th and 14th Amendment 
2 
to the United States Constitution. 
3 
Q. Have you seen the high school transcripts 
4 
grades of girls that you have had sexual relationships 
5 
with dating back to 2005? 
6 
MR. PIKE: Form, relevance, improper 
7 
hypothetical, lacks facts -- assumes facts not in 
8 
evidence, lacks appropriate predicate, foundation. 
9 
THE WITNESS: I'm going to answer that 
10 
question the same as I've answered most of your 
11 
other questions here today, Mr. Kuvin, which is, I 
12 
intend to respond to all relevant questions 
13 
regarding this lawsuit; however, at the present 
14 
time, my attorneys have counseled me that I cannot 
15 
provide answers to any questions that may be 
16 
relevant to this lawsuit. I must accept their 
17 
advice or risk losing my 6th Amendment right to 
18 
effective representation. Accordingly, I assert my 
19 
federal constitutional rights as guaranteed by the 
20 
5th, 6th and 14th Amendment to the United States 
21 
Constitution. 
22 
BY MR. KUVIN: 
23 
Q. Do you deny that the high school transcripts 
24 
which were found in your trash on Palm Beach that showed 
25 
the ages of some of the girls you were engaged with 
5 (Pages 185 to 188) 
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Electronically signed by Jeana Ricciuti 
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EFTA01087059

Page 189 
sexual ads with at your home dune from your house? 
2 
MR. PUCE: Same objection in addition to 
3 
argumentative and harassing. 
4 
THE WITNESS: I intend to respond to all 
relevant questions regarding this lawsuit; however, 
6 
as I've done with most of your other questions 
today, at the present time my attorneys have 
8 
counseled me that I cannot provide answers to any 
9 
of those questions relevant to this lawsuit. I 
10 
must accept their advice or risk losing my 6th 
11 
Amendment right to effective representation. 
12 
Accordingly, I must used my federal 
13 
constitutional rights as guaranteed by the 5th, 6th 
14 
and 14th Amendments to the United States 
15 
Constitution. 
16 
BY MR. KUVIN: 
17 
Q. Did you have numerous photos of nude young 
18 
women, girls under the ago of 18, back in your home 
19 
in -- on Palm Beach Island in 2005 and 2006? 
20 
A. I'm going to have to respond to that question 
21 
tho same way I've responded to most of your questions 
22 
here today, which is, I intend to respond to all 
23 
relevant questions regarding this lawsuit; however, at 
24 
the present time, my attorneys have counseled 'no I 
25 
cannot provide answers to any questions relevant to the 
Page 191 
1 
MR. GOLDBERGER: Break time? 
2 
MR. KUVIN: No, not again. Please not. 
3 
lust let us know when you're good to go. 
4 
THE VIDEOGRAPHER: Were back on the record at 
5 
2:04. This will be the beginning of tape No. 3. 
6 
BY MR. KUVIN: 
7 
Q. Do you have security cameras throughout your 
8 
home on Palm Beach Island? 
9 
A. I'm going to answer that question the same way 
10 
I've answered most of your questions here today, 
11 
Mt Kuvin. I intend to respond to all relevant 
12 
questions regarding this lawsuit; however, at the 
13 
present time, my attorneys have counseled me I cannot 
14 
provide answers to any questions relevant to the 
15 
lawsuit I must accept their advice or risk losing my 
16 
6th Amendment right to effective representation. 
17 
Accordingly, I assert my federal constitutional rights 
18 
as guaranteed by the 5th, 6th and 14th Amendment to the 
19 
United States Constitution. 
20 
(Plaintiffs Exhibit No. 10 was marked for 
21 
identification.) 
22 
MR. KU VIN: ru show the camera a photograph 
23 
here. Okay? 
24 
THE VIDEOGRAPHER: LIR it up. Yeah, there 
25 
you go. Okay. 
Page 190 
1 
same lawsuit. I must accept their advice or risk losing 
2 
my 6th Amendment right to effective representation. 
Accordingly, I must assert my federal constitutional 
rights as guaranteed by the 5th, 6th and 14th Amendment. 
Q. Did you have photographs of girls under the 
6 
ago of ten who were nude, either partially or fully 
7 
nude, in your home on Palm Beach in 2005 and 2006? 
8 
MR. PIKE: Fenn. 
9 
THE WITNESS: I'm going to respond to that 
10 
question the same way I've responded to most of' 
11 
your other questions, which is, I intend to respond 
12 
to all relevant questions regarding this lawsuit; 
13 
however, at the present time, my attorneys have 
14 
counseled me I cannot provide answers to any 
15 
questions relevant to this lawsuit. I must accept 
16 
this advice or risk losing my 6th Amendment right 
17 
to effective representation. Accordingly, I assert 
18 
my federal constitutional rights as guaranteed by 
19 
the 5th, 6th and 14th Amendments of the United 
20 
States Constitution. 
21 
THE VIDEOGRAPHER: Mr. Kuvin, fin sorry I have 
22 
to change. 
23 
MR. KUVIN: Go ahead 
24 
THE VIDEOGRAPHER: well go off the record at 
25 
2:03. This will be the end of tape No.2. 
Page 192 - 
1 
MR. KUVIN: Okay? 
2 
BY MR. KUVIN: 
3 
Q. Let me show you what we marked as Plaintiffs 
4 
Exhibit 10. Do you recognize this young lady? 
5 
A. Yes. 
6 
Q. Who is sho? 
7 
A. Her name is 
8 
Q. And who is she? 
9 
A. I just -- her name is 
10 
Q. How do you recognize her? 
11 
A. I don't understand the question. 
12 
Q. Well, is she a friend of yours? Did she work 
13 
for you? Flow do you recognize her? 
14 
A. How do I recognize her? 
15 
Well, I'd like to respond to that question 
16 
but, however, my attorneys have told me that I can't 
17 
respond to any questions today that may -- excuse me. I 
18 
intend to respond to all relevant questions regarding 
19 
this lawsuit; however, at the present time, my attorneys 
20 
have counseled mo that I cannot provide answers to any 
21 
questions relevant to this lawsuit. I must accept their 
22 
advice or risk losing my 6th Amendment right to 
23 
effective representation. Accordingly, I assert my 
24 
federal constitutional rights as guaranteed by the 5th, 
25 
Gth and 14th Amendment to the United States 
(phonetic). 
6 (Pages 189 to 192) 
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Page 191 
1 
Constitution. 
2 
Q. Did you have sex with 
3 
A. I'm going to answer that question like I've 
4 
answered most of your questions here today, which is, 1 
5 
intend to respond to all relevant questions regarding 
6 
this lawsuit; however, at the present time, my attorneys 
7 
have counseled me I cannot provide answers to any 
8 
questions relevant to this lawsuit. I must accept their 
9 
advice or risk losing my 6th Amendment right to 
10 
effective representation. Accordingly, I assert my 
11 
federal constitutional rights as guaranteed by the 5th, 
12 
6th and 14th Amendment to the United States 
13 
Constitution. 
14 
Q. When did you first meet Prince Andrew? 
15 
And let mo make it a compound question so I 
16 
don't have to repeat it over and over. When did you 
17 
first meet Prince Andrew, under what conditions did you 
18 
meet him, and who was present at that list meeting? 
19 
A. I'm going to answer that question as I've done 
20 
most of your questions here today, Mr. Kuvin, which is, 
21 
I intend to respond to all relevant questions regarding 
22 
this lawsuit; however, at the present time, my attorneys 
23 
have counseled met cannot provide answers to any 
24 
questions relevant to that lawsuit. I must accept their 
25 
advice or risk losing my 6th Amendment right to 
IM? 
Page 195 
1 
THE WITNESS: Pm going to respond to that 
2 
question the same way I've responded to most of 
3 
your questions here today, Mr. Kuvin, which is, I 
4 
intend to respond to all relevant questions 
5 
regarding this lawsuit -- excuse me, however, at 
6 
the present time, my attorneys have counseled me I 
7 
cannot provide answers to any questions relevant to 
8 
the lawsuit, or might be relevant to the lawsuit. 
9 
I must accept their advice or risk losing my 6th 
10 
Amendment right to effective representation. 
11 
Accordingly, I assert my federal constitutional 
12 
rights as guaranteed by the 5th, 6th and 14th 
13 
Amendment of the United States Constitution. 
14 
BY MR. KUVIN: 
15 
Q. Did you fly with Prince Andrew on your plane, 
16 
or planes, with any underaged girls, girls under the age 
17 
of18? 
18 
A. I'm going to answer that question the same way 
19 
I've answered all the other questions here today, 
20 
virtually, which is, I intend to respond to all relevant 
21 
questions regarding this lawsuit; however, at the 
22 
present time, my attorneys have counseled me I cannot 
23 
provide answers to any questions relevant to the 
24 
lawsuit. I must accept their advice or risk losing my 
25 
6th Amendment right to effective representation. 
Page 194 
1 
effective representation. Accordingly, I must assert my 
2 
federal constitutional rights as guaranteed by the 5th, 
3 
6th and 14th Amendment to the United States 
4 
Constitution. 
5 
Mk PIKE: In addition, relevance. 
6 
BY MR. KUVIN: 
7 
Q. Do you pay Ms. Maxwell a salary? 
8 
MR. PIKE: Form. 
9 
BY MR. KUVIN: 
10 
Q. Ohislaine Maxwell, so we're clear. Do you pay 
11 
her a salary? 
12 
A. I'd like -- excuse me. I'm going to answer 
13 
that question the same way I've answered most of your 
14 
questions here today, which is, I intend to answer all 
15 
questions relevant to this lawsuit; however, at the 
16 
present time, my attorneys have counseled me I cannot 
17 
provide answers to any questions relevant to this 
18 
lawsuit. I must accept their advice or risk losing my 
19 
6th Amendment right to effective representation. 
20 
Accordingly, I assert my federal constitutional rights 
21 
as guaranteed by the 5th, 6th and 14th Amendment to the 
22 
United States Constitution. 
23 
Q. Did you provide any underaged girls for sex to 
24 
Prince Andrew? 
25 
MR. PIKE: FO1111 
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 
Page 196 
Accordingly, I must assert my federal constitutional 
rights as guaranteed by the 5th, 6th and 14th Amendments 
to the United States Constitution. 
Q. Do you 'mow 
MR. KUVIN: For the court reporter, it's 
THE WITNESS: I intend to respond to all 
relevant questions regarding this lawsuit; however, 
at the present thne, my attorneys have counseled me 
I cannot provide answers to any questions relevant 
to the lawsuit. I must accept this advice or risk 
losing my 61h Amendment right to effective 
representation. Accordingly, I assert my federal 
constitutional rights as guaranteed by the 5th, 6th 
and 14th Amendments to the United States 
Constitution. 
MR. KUVIN: Let me show the camera what we'll 
mark as Exhibit II. 
(Plaintiffs Exhibit No. 11 was marked for 
identification.) 
THE VIDEOORAPHER: Okay. 
MR. KUVIN: Okay? 
BY MR. KUVIN: 
Q. In Exhibit 11, sir, you're standing with a 
woman. Who Is that woman in that photograph? 
(.1) 
832-7500 
7 (Pages 193 to 196) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Juana Ricciuti 
Electronically signed by Arena RIcciull 
618d9dt04tcb-496c-a240-098977073134 
EFTA01087061

Page 1 9 / 
1 
A. 
(phonetic). 
2 
Q. Where were you? 
3 
A. I intend to respond to all relevant questions 
4 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled me Icannot provide answers to 
6 
any questions that may be relevant to this lawsuit. I 
must accept this advice or risk losing my 6th Amendment 
8 
right to effective representation. Accordingly, I must 
9 
assert my federal constitutional rights as guaranteed by 
10 
the 5th, 6th and 14th Amendments to the United States 
11 
Constitution. 
12 
MR. KUVIN: And just so the court reporter 
13 
knows, Ghislaine is spelled G-H-I-S-L-A-I-N-E. 
14 
BY MR. KUVIN: 
15 
Q. Who is 
,excirse 
16 
me? 
17 
A. I'm going to answer that question the same way 
18 
I've answered most of your questions here today, which 
19 
is, I intend to respond to all relevant questions 
20 
regarding this lawsuit; however, at the present time, my 
21 
attorneys have counseled me I cannot provide answers to 
22 
any questions relevant to the lawsuit. I must accept 
23 
their advice or risk losing my 6th Amendment right to 
24 
effective representation. Excuse me. Accordingly, I 
25 
must assert my federal constitutional rights as 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 199 
A. I intend to respond to all relevant questions 
regarding this lawsuit; however, as I've done to most of 
the questions at the present time, my attorneys have 
counseled me that I cannot provide answers to any of' 
those questions that may be relevant to the lawsuit. I 
must accept this advice or risk losing my Gth Amendment 
right to effective representation. Accordingly, 
asset my federal constitutional rights as guaranteed by 
the 5th, 6th and 14th Amendments of the United States 
Constitution. 
BY MR. KUVIN: 
Q. Fin going to show you what we'll mark as 
Exhibit 13. Let me show it to the camera, first. 
(Plaintiffs Exhibit No. 13 was marked for 
identification.) 
BY MR. KUVIN: 
Q. Sir, is It true that Exhibit 13 shows your 
personal assistant, 
A. I intend to respond to all relevant questions 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled me that I cannot provide 
answers to any questions that may be relevant to this 
lawsuit. I must accept their advice or risk losing my 
6th Amendment right to effective representation. 
Accordingly, I assert my federal constitutional rights 
Page 198 
1 
guarantee -- guaranteed by the 5th, 6th and 14th 
2 
Amendment tote United States Constitution. 
3 
(Plaintiffs Exhibit No. 12 was marked for 
,1 
identification.) 
5 
MR. KUVIN: Let me show to the camera what 
6 
we've marked as Exhibit 12. 
7 
BY MR. KUVIN: 
8 
Q. Let me show you what I've marked as Exhibit 
9 
12. Do you recognize any of the girls in that 
10 
photograph? 
11 
A. I'm going to answer that question the same way 
12 
I've answered most of your other questions here today, 
13 
Mr. Kuvin, which is, I intend to respond to all relevant 
14 
questions regarding this lawsuit; however, at the 
15 
present time, my attorneys have counseled me that 1 
16 
cannot provide answers to any questions that may be 
17 
relevant to the lawsuit. I must accept their advice or 
18 
risk losing my 6th Amendment right to effective 
19 
representation. Accordingly, I assert my federal 
20 
constitutional rights as guaranteed by the 5th, 6th and 
21 
14th Amendment to the United States Constitution. 
22 
Q. Sir, isn't it true that in what we've marked 
23 
as Plaintiff's Exhibit 12 the blond standing on the 
24 
left is 
and the blonde, dirty blonde 
25 
standing on the right is 
Page 200 
1 
as guaranteed by the 5th, 6th and 14th Amendment to the 
2 
United States Constitution. 
3 
Q. Let me show you what we'll mark as Exhibit 14. 
4 
(Plaintiffs Exhibit No. 14 was marked for 
5 
identification.) 
6 
BY MR. KUVIN: 
7 
Q. Sir, does Exhibit 14 show --,a 
8 
girl that you have had a sexual relationship with since 
9 
before she was 18 years old? 
10 
MR. PIKE: Fenn, argumentative, harassing, 
11 
assumes facts not in evidence, lacks appropriate 
12 . 
predicate and foundation. 
13 
THE WITNESS: I intend to respond to all 
14 
relevant questions regarding this lawsuit; however, 
15 
at the present time, my attorneys have counseled me 
16 
I cannot provide answers to any questions relevant 
17 
to this lawsuit. I must accept their advice or 
18 
risk losing my 6th Amendment right to effective 
19 
representation. Accordingly, I assert my federal 
20 • 
constitutional rights as guaranteed by the 5th, 6th 
21 
and 14th Amendment to the United States 
22 
Constitution. 
23 
BY MIL KUVIN: 
24 
Q. I'm going to show the camera what we'll mark 
25 
as Exhibit 15. 
8 (Pages 197 to 200) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana RIcchal 
Electronically signed by Jeana RIcclutl 
bred9W0-4fcb-496c-a244-099977073134 
EFTA01087062

Page 201 
(Plaintiffs Exhibit No. IS was marked for 
2 
identification.) 
3 
BY MR. KUVIN: 
4 
Q. Sir, does Exhibit I5 show S 
an 
5 
underaged girl that you were utilizing back in 2005 and 
6 
2006 to procure other underaged girls for sex and sexual 
/ 
contact at your home? 
8 
MR. PIKE: Same objections to Exhibit 15 as 
9 
were made to Exhibit 14. 
10 
THE WITNESS: I'm going to answer that the 
11 
same way I've answered most of your questions here 
12 
today, Mr. Kuvin, which is, I intend to respond to 
13 
all relevant questions regarding this lawsuit; 
14 
however, at the present time, my attorneys have 
15 
counseled me that I cannot provide answers to any 
16 
questions that may be relevant to the lawsuit. 
17 
must accept their advice or risk losing my 6th 
18 
Amendment right to effective representation. 
19 
Accordingly, I am going to assert my federal 
20 
constitutional rights as guaranteed by the 5th, 6th 
21 
and 14th Amendments to the United States 
22 
Constitution. 
23 
(Plaintiffs Exhibit No. 16 was marked for 
24 
identification.) 
25 
MR. KUVIN: Let me show the camera what we've 
Page 203 
1 
cannot provide answers to any questions relevant to this 
2 
lawsuit. I must accept their advice or risk losing my 
3 
6th Amendment right to effective representation. 
4 
Accordingly, I assert my federal constitutional rights 
5 
as guaranteed by the 5th, 6th and 14th Amendment to the 
6 
United States Constitution. 
7 
Q. I'm going to show you a document that we'll 
8 
mark as Exhibit 17. 
9 
MR. PIKE: Thank you. 
10 
(Plaintiffs Exhibit No. 17 was marked for 
11 
identification.) 
12 
BY MR. KUVIN: 
13 
Q. I'm going to give you a minute to take a look 
14 
at that document and just tell inc when you're ready to 
15 
answer any questions about it. 
16 
A. Okay. 
17 
Q. Okay. First of all, have you seen this letter 
18 
before? 
19 
MR. GOLDBERGER: Attorney-client privilege, 
20 
work product. 
21 
BY MR. KUVIN: 
22 
Q. Have you seen this letter before outside of 
23 
the relationship with your attorneys? 
24 
MR. GOLDBERGER: You can answer that question. 
25 
THE WITNESS: No. 
2 
3 
4 
5 
6 
7 
8 
9 
1.0 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 202 
marked as Exhibit 16. 
BY MR. KUVIN: 
Q. Do you recognize the ganleman in that 
photograph, 
MR. PIKE: Hold on for a second. 
MR. GOLDBERGER: Do you want to discuss it 
with me? 
MR. PIKE: Let's take a break for one minute. 
MR. KUVIN: All right. 
THE VIDEOGRAPHER: Off the record at 2:16. 
(A brief recess was taken.) 
THE VIDEOGRAPHER: We're back on the record at 
2:45. 
BY MR. KUVIN: 
Q. Okay. Do you recognize the person that's 
shown in Exhibit 16? 
A. Yes. 
Q. Who is that? 
A. Prince Andrew. 
Q. And how do you know Prince Andrew? 
A. I'm going to have to respond to that question 
the same way I've responded to most of your questions 
here today, Mr. Kuvin, which is, [intend to respond to 
all relevant questions regarding this lawsuit; however, 
at the present time, my attorneys have counseled me I 
Page 204 
1 
BY MR. KUVIN: 
2 
Q. Do you know Chief of Police Michael Reiter? 
3 
Do you know who he is? 
4 
A. I know who he is. 
Q. Do you know State Attorney Bony Krischer? 
6 
A. I know who he is. 
7 
Q. Did you ever speak with Chief of Police 
8 
Michael Reiter in the past? 
9 
A. I don't remember. 
10 
Q. Did you ever talk to anyone, either at the 
11 
State Attorney's office, yourself, or Michael Reiter 
12 
about the prosecution of yotir claim without the presence 
13 
of your attorneys? 
14 
A. No. 
15 
Q. Did you ever talk to any of the police that 
16 
worked for the Town of Palm Beach without the presence 
17 
of your attorneys? 
18 
A. Explain -
19 
MR. PIKE: Wait one second. 
20 
THE WITNESS: I'm sorry. 
21 
MR. PIKE: Can you state the question again? 
22 
MR. KUVIN: Sure. 
23 
BY MR. KUVIN: 
24 
Q. Did you ever speak to any of the police 
25 
officers that worked for the Town of Palm Beach without 
9 (Pages 201 to 204) 
PROSE COURT REPORTING AGENCY, INC. 
.Electrancaltystgand by
 RIctiutt 
Etactronleally signed by Jana Rleelutl 
blead104fcb-496c-a244.099977073134 
EFTA01087063

Page 205 
1 
the presence of your attorneys? 
2 
MR. GOLDBERGER: Is the question, have you 
3 
ever spoken to a Town of Palm Beach police officer? 
4 
Is that the — can we rephrase it like that? 
5 
MR. KUVIN: Sure. 
6 
MR. GOLDBERGER: Okay. 
7 
THE WITNESS: I've been stopped by the police 
8 
for traffic violations, if that's what you mean. 
9 
BY MR. KUVIN: 
10 
Q. Any other times that you had conversations 
11 
with any of the Town of Palm Beach —
12 
A. No. 
13 
Q. --police officers? 
14 
A. Not that I recall specific* 
15 
Q. Okay. Now, you were housed at the jail after 
16 
your plea of guilty that we had spoke about at the 
17 
beghming of your deposition; is that correct? 
18 
MR. PIKE: Form. 
19 
THE WITNESS: Say it again. 
20 
BY MR. KUVIN: 
21 
Q. Yes. You were housed at the local jail here 
22 
in Palm Beach County after your plea of guilty that we 
23 
spoke about at the beginning of your deposition? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: Yes. 
Page 20'r 
1 
BY MR. KUVIN: 
2 
Q. Did you purchase items from the jail? 
3 
MR. GOLDBERGER: Hang on a second. 
4 
MR. PIKE: Hold on one second. 
5 
THE WITNESS: It looks that way, yes, sir. 
6 
BY MR. KUVIN: 
7 
Q. Okay. 
8 
MR. PIKE: And the document speaks for itself, 
9 
the composite document speaks for itself. 
10 
BY MR. KUVIN: 
11 
Q. I'd like you to take a look at Exhibit 18. It 
12 
shows purchases well, does it show purchases by you? 
13 
MR. PIKE: Asked and answered. 
14 
THE WITNESS: Yes. 
15 
BY MR. KUVIN: 
16 
Q. Okay. And it appears those purchases took 
17 
place from 7/8/08 through 9/30/08 is the last one that I 
18 
have; is that correct? 
19 
MR. PIKE: The document speaks for itself. 
20 
BY MR. KUVIN: 
21 
Q. You can answer. 
22 
A. The document speaks for itself. 
23 
Q. Is that correct, the last date is 9/30/08? 
24 
A. The last date here is 9/30, yes. 
25 
MR. PIKE: With regard to what you provided to 
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 
Page 206 
BY MR. KUVIN: 
Q. How long were you there? 
A. 13 months, approximately. 
Q. All right. And of those 13 months, how many 
months were you there where you had to stay there 24 
hours a day? 
A. I don't recall specifically. 
Q. More than a month? 
A. Yes. 
Q. More than two months? 
A. Yes. 
Q. More than three months? 
A. Yes. 
Q. More than four? 
A. I think so,Idon't remember. 
Q. Do you recall when you were provided work 
release, when you were able to leave during the daylight 
hours? 
A. Not with specificity. 
Q. While you were there at the jail in Palm 
Beach -- I'm going to show you what we'll mark as 
Exhibit 18. 
(Plaintiffs Exhibit No. 18 was marked for 
identification.) 
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 
Page 208 
the witness. 
MR. KUVIN: Sure, absolutely. 
THE WITNESS: Okay. 
BY MR. KUVIN: 
Q. And just so we're clear, this composite 
exhibit that we've marked as Exhibit 18 contains 
purchases from 7/8/08, 7/15,7/22, 7/29, 8/5,8/12, 
8/21, W26,9/2, 9/9, 9/23 and 9/30, just so the record 
is clear; there is no question. 
A. Okay. 
Q. Okay? 
A. Uh-huh. 
Q. All right. These items that you purchased, 
did you utilize all of these items yourself? 
MR. PIKE: Form, relevance. 
THE WITNESS: I don't understand the question. 
BY MR. KUVIN: 
Q. Well, you purchased a number of items that are 
shown in this receipt. 
A. Yes. 
Q. The question is: Did you use them yourself? 
MR. PIKE: Same objection. 
THE WITNESS: I don't knots if I used all of 
them, so... 
10 (Pages 205 to 208) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciuti 
Electronically signed by Jeana Ricciuti 
bf8d9d10-4fcb-496c-a244.099977073134 
EFTA01087064

Page 209 
1 
BY MR. KUVIN: 
2 
Q. Well, what did you do with the items that you 
3 
purchased? 
4 
MR. PIKE: Form, overbroad. 
5 
BY MR. KUVIN: 
6 
Q. You can answer. 
7 
A. I used some, I threw away sane. 
8 
Q. Did you give any away? 
9 
A. Not that I remember. 
10 
MR. PIKE: Same objection. 
11 
BY MR. KUVIN: 
12 
Q. Did you provide any items that you purchased 
13 
to other inmates while you were there in jail? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: Not to the best of my 
16 
recollection. 
17 
BY MR. KUVIN: 
18 
Q. Okay. With respect to all of the items that 
19 
are listed in these receipts, is it a safe assumption 
20 
that you either used them yourself or threw them away? 
21 
MR. PIKE: Asked and answered. If you don't 
22 
know —if you know. 
23 
THE WITNESS: I don't know. 
24 
BY MR. KUVIN: 
25 
Q. I'm sorry? I didn't hear you. 
Page 211 
1 
the form you filled out, the infonnation or the product 
2 
that you put on that form actually was provided? 
3 
A. No, never. 
4 
Q. If we look at the items that are contained 
5 
within these receipts, I'd like you to go, if you would, 
6 
to the second invoice here dated 7/15/08. The third 
7 
item down is a Lubriderm lotion. 
8 
A. Yes. 
9 
Q. Do you see that? 
10 
A. Yes. 
11 
Q. Did you purchase that? 
12 
A. It appears so. 
13 
Q. Did you receive it? 
14 
A. I don't remember. 
15 
Q. Did you use the Lubriderm lotion that you 
16 
received or that you may have received in jail? 
17 
MR. PIKE: Form. 
18 
BY MR. KUVIN: 
19 
Q. Let me strike that and re-ask it. 
20 
A. Okay. 
21 
Q. Did you use the Lubridenn lotion which you had 
22 
purchased from the jail while you were there? 
23 
A. I might have. 
24 
Q. What for? 
25 
A. To moisturize my hands and face. 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 210 
MR. PIKE: Asked and answered. 
THE WITNESS: So should I answer? 
MR. PIKE: You can answer again. 
THB WITNESS: Ask the question again. 
BY MR. KUVIN: 
Q. So can we assume that all of the items that 
are shown in these receipts were either used by you or 
thrown away? 
A. I don't even know if I received some of those 
items, so I would assume I used most of them. 
Q. Okay. 
A. Okay? 
Q. Sure. Take a look, I just want to make surd, 
did you receive all these items? 
A. I don't know. 
MR. PIKE: Asked and answered. 
BY MR. KUVIN: 
Q. How did you purchase them? 
A. I filled out a form. 
Q. And how were they provided to you? 
MR. PIKE: Form. 
THE WITNESS: Sometimes they would come in a 
bag. 
BY MR. KUVIN: 
Q. Okay. And did you determine whether or not 
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 
Page 212 
Q. Okay. Did you use Lubriderm lotion while you 
were in jail to masturbate at all? 
A. No. 
MR. PIKE: Fonn objection, harassing. 
THE WITNESS: Absolutely not. 
BY MR. KUVIN: 
Q. It appears, if you would turn to 7/29/08, 
which is approximately two weeks later, and the second 
thing down is another bottle of Lubriderm lotion. Do 
you see that? 
A. Yes. 
Q. What did you use that for? 
MR. PIKE: Asked and answered. 
MR. KUVIN: It's a second bottle. 
MR. PIKE: It's the same question, Spencer. 
Can we got to something relevant? 
THE WITNESS: No problem. 
MR. PIKE: He can answer. 
THE WITNESS: My hands and my face. 
BY MR. KUVIN: 
Q. Okay. 
A. I believe the first bottle went missing. 
Q. If we turn to approximately one month later on 
821/08, do you have that one? 
A. Yes. 
t
,
 
n 
(Pages 209 to 212) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Mocha' 
Electronically signed by Jeana Modell 
hf8d9df0.4fcb-496c•a244.099977073134 
EFTA01087065

Page 213 
1 
Q. All right. On that occasion, you bought two 
2 
bottles of hand lotion again. 
3 
A. Yes. 
4 
Q. What did you use those for? 
A. Nothing 
6 
Q. What did you do with them? 
7 
A. They were bought by accident. 
8 
Q. How did you buy them by accident? 
9 
A. Because you fill out a check form and 
10 
sometimes the forms don't make any sense, they just 
11 
deliver in other things. 
12 
Q. Sir, did you get those two bottles? 
13 
A. Yes. Yes. 
14 
Q. And you never used them? 
15 
A. No. I threw them away. 
16 
Q. Okay. If we turn to 9/9/08, do you see that 
17 
entry? 
18 
A. Yes. 
19 
Q. All right. And another invoice here, on that 
20 
date a bottle of hand lotion, do you see that? 
21 
A. Yes, I do. 
22 
Q. Did you get it? 
23 
A. I don't know. 
24 
Q. Do you know if you used it? 
25 
A. Definitely not. 
Page 215 
1 
A. No. 
2 
Q. Is it your testimony here today that you did 
3 
not use any of the bottles of hand lotion or Lubridenn 
4 
lotion that we had previously just gone through to 
5 
masturbate while you were in jail? 
6 
A. That's correct. 
7 
Q. Did Ghislainc Maxwell visit you in jail? 
8 
A. No. 
9 
Q. Did 
10 
in jail? 
11 
A. I intend to respond to all relevant questions 
12 
regarding this lawsuit; however, at the present time, my 
13 
attorneys have counseled me I cannot provide answers to 
14 
any questions relevant to this lawsuit. I must accept 
15 
this advice or risk losing my 6th Amendment right to 
16 
effective representation. Accordingly, I assert my 
17 
federal constitutional rights as guaranteed by the 5th, 
18 
6th and 14th Amendment to the United States 
19 
Constitution. 
20 
Q. Did you have sex with 
21 
you were housed at the Palm Bench jail facility? 
22 
MR. PIKE: Form. 
23 
THE WITNESS: I intend to respond to all 
24 
relevant questions regarding this lawsuit; however, 
25 
at the present time, my attorneys have counseled me 
visit you while you were 
while 
Page 214 
1 
Q. How do you know you definitely did not use it? 
2 
A. Because it was not — anything that said hand 
3 
lotion I did not use, I throw in the garbage. 
4 
Q. Why is that? 
A. Because it wasn't something that I had 
6 
ordered. 
7 
MR. PIKE: Can 1-- can I just have an 
8 
agreement that the objections to this line of 
9 
questioning is irrelevant, so I don't have to --
10 
MR. KUVIN: Sure. 
11 
MR. PIKE: — interrupt. 
12 
MR. KUVIN: Sure. 
13 
MR. PIKE: Agreed? 
14 
MR. KUVIN: Agreed. 
15 
BY MR. KUVIN: 
16 
Q. Let's turn again to 9/30/08, the last invoice 
17 
in there. 
18 
A. Yes. 
19 
Q. Do you see there is an entry for two snore 
20 
bottles of hand lotion. Do you see that? 
21 
A. Correct. 
22 
Q. What did you do with those? 
23 
A. To the best of my knowledge, I threw them 
24 
right away. 
25 
Q. You didn't use them for anything? 
Page 216 
1 
I cannot provide answers to any questions relevant 
2 
to this lawsuit. As I've answered most of your 
3 
question today, Mr. Kuvin, I must accept this 
4 
advice or risk losing my 6th Amendment right to 
5 
effective representation. Accordingly, I assert my 
6 
federal constitutional rights as guaranteed by the 
5th, 6th and 14th Amendments to the United States 
Constitution. 
9 
BY MR. KUVIN: 
10 
Q. Did you pay girls so that they would not 
11 
testify against you in the civil proceedings that have 
12 
been filed in both Federal and State Court? 
13 
MR. PIKE: Fenn. 
14 
THE WITNESS: Okay. Like most of your other 
15 
questions here today, Mr. Kuvin, I'm going to 
16 
respond by saying I intend to respond to all 
17 
relevant questions regarding this lawsuit; however, 
18 
at the present time, my attorneys have counseled me 
19 
I cannot provide answers to any questions relevant 
20 
to this lawsuit. I must accept this advice or risk 
21 
losing my 6th Amendment right to effective 
22 
representation. Accordingly, I must assert my 
23 
federal constitutional rights as guaranteed by the 
24 
5th, 6th and 14th Amendments to the United States 
25 
Constitution. 
12 (Pages 213 Lo 216 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciuti 
Electronically signed by Jeana RIcciuti 
bf8d9df0-4fcb-496c-a244-09997 7073134 
EFTA01087066

Page 217 
1 
BY MR. KUVIN: 
2 
Q. Did you have sex with 
when 
3 
she was under the age of 14? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: I intend to respond to all 
6 
relevant questions regarding this lawsuit; however, 
7 
at the present time, my attorneys have counseled me 
I cannot provide answers to any questions relevant 
9 
to this lawsuit. 1 must accept this advice or risk 
10 
losing my 6th Amendment right to effective 
11 
representation. Accordingly, I must assert my 
12 
federal constitutional rights as guaranteed by the 
13 
5th, 6th and 14th Amendment to the Constitution. 
14 
BY MR. KUVIN: 
15 
Q. Did you tell people that 
was 
16 
your sex slave? 
17 
MR. PIKE: Same objection. 
18 
THE WITNESS: I intend to respond to all 
19 
relevant questions regarding this lawsuit; however, 
20 
at the present time, my attorneys have counseled me 
21 
I cannot provide answers to any questions relevant 
22 
to this lawsuit. I must accept this advice or risk 
23 
losing my 6th Amendment right to effective 
24 
representation. Accordingly, I must assert my 
25 
federal constitutional rights as guaranteed by the 
Page 219 
1 
any questions relevant to this lawsuit. I must accept 
2 
this advice or risk losing my Gth Amendment right to 
3 
effective representation. Accordingly, as I've done 
4 
with most of your questions, I must assert my federal 
5 
constitutional rights as guaranteed by the 5th, 6th and 
6 
14th Amendment to the United States Constitution. 
7 
Q. Mr. Epstein, are you aware that after 
8 
September 11, 2001 that the Federal Government started 
9 
tracking all flights of all public and private aircraft? 
10 
MR. PIKE: Fenn, relevance. 
11 
BY MR. KUVIN: 
12 
Q. Are you aware of that? 
13 
A. No. 
14 
Q. Okay. Are you aware that the FAA keeps track 
15 
of all flights that are made both within the continental 
16 
US and from the continental US abroad? 
17 
MR. PIKE: Saint objection. 
18 
THE WITNESS: No. 
19 
BY MR. KUVIN: 
20 
Q. Do you know whether or not — let me ask it 
21 
this way: Have you ever seen the flight tracking 
22 
information for any planes that you may own? 
23 
A. 1 don't believe so. 
24 
Q. Is JEGE, Inc. a company that is owned by you? 
25 
A. l'Ilhave to answer that question the way I've 
Page 218 
1 
5th, 61h and 14th Amendment to the United States 
2 
Constitution. Excuse me. 
3 
MR. KUVIN: This is 19. 
4 
(Plaintiffs Exhibit No. 19 was marked for 
5 
identification.) 
6 
BY MR. KUVIN: 
7 
Q. I have an FAA registry for a Boeing 727, 
8 
manufacture year 1969, with — I'm just looking for the 
9 
tail number here. I'm sorry, I'm just hying to find 
10 
the tail number. 
11 
A. Not a problem. 
12 
Q. Let's do this, it's a Mode S Code 
13 
I'll show this to your counsel first. 
14 
Here it is,19n sorry, Tail No. N908JE. 
15 
There's no question pending just yet. 
16 
MR. PIKE: Thank you. 
17 
Okay. 
18 
BY MR. KUVIN: 
19 
Q. Let me show you what we marked as Exhibit 19. 
20 
III give you a minute to take a look at that. 
21 
A. Okay. 
22 
Q. What is .1A 
EGE, Inc.? 
23 
A. T intend to respond to all relevant questions 
24 
regarding this lawsuit; however, at the present time, my 
25 
attorneys have counseled me I cannot provide answers to 
Page 220 
1 
answered most of your other questions here today, which 
2 
is, 1 intend to respond to all relevant questions 
3 
regarding this lawsuit; however, at the present time, my 
4 
attorneys have counseled me I cannot provide answers to 
5 
any questions relevant to this lawsuit. 1 must accept 
6 
this advice or risk losing my 6th Amendment right to 
7 
effective representation. Accordingly, I assert my 
8 
federal constitutional rights as guaranteed by the 5th, 
9 
Gth and 14th Amendment to the United States 
10 
Constitution. 
11 
Q. The plane that is identified in the FAA 
12 
registry in the document marked Exhibit 19, just so 
13 
we're clear, because I don't think I asked it exactly, 
14 
but is this your plane? 
15 
A. I'm going to answer that question the same way 
16 
I've answered most of your questions today, Mr. Kuvin, 
17 
which is, I intend to respond to all relevant questions 
18 
regarding this lawsuit; however, at the present time, my 
19 
attorneys have counseled me I cannot provide answers to 
20 
any questions relevant to this lawsuit. I must accept 
21 
this advice or risk losing my 6th Amendment right to 
22 
effective representation. Accordingly, I assert my 
23 
federal constitutional rights as guaranteed by the 5th, 
24 
61h and 14th Amendment to the United States 
25 
Constitution. 
13 (Pages 217 to 220) 
PROSE COURT REPORTING AGENCY, INC. 
Elictronlcalltilonird-by TanaTBoefuif 
—
Electronically signed by Jenne Riceluti 
bf8d9d10.4feb-496c•a244-099977073134 
EFTA01087067

Page 221 
1 
Q. Isn't is true, sir, that you flew to Thailand 
2 
in 2001? 
3 
MR. PIKE: Form. 
4 
THE WITNESS: I intend to respond to all 
S 
relevant questions regarding this lawsuit; however, 
6 
at the present time, my attorneys have counseled me 
7 
I cannot provide answers to any questions relevant 
8 
to this lawsuit. 1 must accept this advice or risk 
9 
losing my 6th Amendment right to effective 
10 
representation. Accordingly, I assert my federal 
11 
constitutional rights as guaranteed by the 5th, Gth 
12 
and 14th Amendment to the United States 
13 
Constitution. 
14 
BY MR. KUVIN: 
15 
Q. Is it true that you went to Thailand in 2001 
16 
with Prince Andrew? 
17 
MR. PIKE: Porn 
18 
THE WITNESS: I intend to respond to all 
19 
relevant questions regarding this lawsuit; however, 
20 
at the present time, my attorneys have counseled me 
21 
I cannot provide answers to any questions relevant 
22 
to this lawsuit, and as I've done for most of all 
23 
your questions today, Mr. Kuvin, I must accept this 
24 
advice or risk losing my 6th Amendment right to 
25 
effective representation. Accordingly, I assert my 
Page 223 
1 
MR. PIKE: Same objections. 
2 
THE WITNESS: I intend --
3 
MR. PIKE: Relevance as well, excuse me. I'm 
4 
sorry. 
5 
THE WITNESS: I intend to respond to all 
6 
relevant questions regarding this lawsuit; however, 
7 
at the present time, my attorneys have counseled me 
8 
I cannot provide answers to any questions relevant 
9 
to this lawsuit. I must accept this advice or risk 
10 
losing my 6th Amendment right to effective 
11 
representation. Accordingly, lessen my federal 
12 
constitutional rights as guaranteed by the 5th, Gth 
13 
and 14th Amendments to the United States 
14 
Constiltdion. 
15 
BY MR. KUVIN: 
16 
Q. Did you bring any young women on the plane 
17 
with you when you went to Thailand in 2001? 
18 
h4R. PIKE: Same objection. 
19 
THE WITNESS: I intend to respond to all 
20 
relevant questions regarding this lawsuit; however, 
21 
at the present time, my attorneys have counseled me 
22 
I cannot provide answers to any questions relevant 
23 
to this lawsuit. I must accept this advice or risk 
24 
losing my 6th Amendment right to effective 
25 
representation. Accordingly, I assert my federal 
Page 222 
1 
federal constitutional rights as guaranteed by the 
2 
Sth, 6th and 14th Amendment to the United States 
3 
Constitution. 
4 
BY MR. KUVIN: 
5 
Q. Isn't it true that you went to Thailand in 
6 
2001 so that you could engage in sexual relations with 
7 
girls under the age of 16 with Prince Andrew without any 
8 
fear of any legal recourse? 
9 
MR. PIKE: Same objection. In addition, 
10 
improper hypothetical, lack of predicate, 
11 
foundation, argumentative, harassing. 
12 
THE WITNESS: I intend to respond to all 
13 
relevant questions regarding this lawsuit; however, 
14 
at the present time, my attorneys have counseled me 
15 
I cannot provide answers to any questions relevant 
16 
to this lawsuit. I must accept this advice or risk 
17 
losing my 6th Amendment right to effective 
18 
representation. Actordingly,1 must assert my 
19 
federal constitutional rights as guaranteed by the 
20 
5th, 6th and 14th Amendment to the United States 
21 
Constitution. 
22 
BY MR. KUVIN: 
23 
Q. Have you seen the photographs of you and 
24 
Prince Andrew while you were in Thailand with half naked 
25 
women, some of which were under the age of 16? 
Page 224 
1 
constitutional rights as guaranteed by the 5th, 6th 
2 
and 14th Amendments to the United States 
3 
Constitution. 
4 
BY MR. KUVIN: 
5 
Q. Have you brodtaabefore that you 
6 
bought -- brought 
to the United States 
7 
to be your Yugoslavian sex slave? 
8 
A. I intend to respond to all relevant questions 
9 
regarding this lawsuit; however, at the present time, my 
10 
nttorneys have counseled me I cannot provide answers to 
11 
any questions relevant to this lawsuit. I must accept 
12 
their advice or risk losing my 6th Amendment right to 
13 
effective representation. Accordingly, I must assert my 
14 
federal constitutional rights as guaranteed by the 5th, 
15 
6th and 14th Amendments to the United States 
16 
Constitution. 
17 
Q. Have you had —
18 
MR. GOLDBERGER: You raised the same objection 
19 
to that question, right? 
20 
MR. PIKE: Yeah, I did. 
21 
BY MR. KUVIN: 
22 
Q. Have you had sex with numerousgirls under the 
23 
age of 18 in the presence of= 
24 
MR. PIKE: Same objections. 
25 
THE WITNESS: I'm going to answer that the 
14 (Pages 221 to 224) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeans Rledull 
fascfronleeig signed by Joan. RlccMl 
bilided10-4fcb-496c-a244-09997 7073134 
EFTA01087068

Page 225 
1 
same way I've answered most of your questions here 
2 
today, Mr. Kuvin, which is, I intend to respond to 
3 
all relevant questions regarding this lawsuit; 
4 
however, at the present time, my attorneys have 
5 
counseled me I cannot provide answers to any 
6 
questions relevant to the lawsuit. I must accept 
7 
their advice or risk losing my 6th Amendment right 
8 
to effective representation. Accordingly, I assert 
9 
my federal constitutional rights as guaranteed by 
10 
the 5th, 6th and 14th Amendments to the United 
11 
States Constitution. 
12 
BY MR. KUVIN: 
13 
Q. What is MC2? 
14 
MR. PIKE: Same objection. 
15 
MB WITNESS: I don't understand the question. 
16 
BY MR. KUVIN: 
17 
Q. MC and then a number 2, what is that? 
18 
MR. PIKE: Lack of predicate, foundation. 
19 
THE WITNESS: What is that? 
20 
MR. PIKE: Irrelevant. 
21 
BY MR. KUVIN: 
22 
Q. Do you know what it is? 
23 
A. No. 
24 
Q. You've never heard of that before? 
25 
A. MC2? 
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 
Page 227 
BY MR. KUVIN: 
Q. I can do it that way, it doesn't matter to me. 
THE WITNESS: It's up to you. 
MR. KUVIN: It's up to you guys. 
MR. PIKE: As I've said, Mr. Kuvin, if you 
want to limit the time that we spend here today and 
ask a compound question if you're going to list 
various items or list Individuals by name and ask 
questions, I won't have a compound objection to 
that type of inquiry if it's in light of attempting 
to save time. 
MR. KUVIN: Sure. 
BY MR. KUVIN: 
Q. All righty. 
MR. PIKE: But that's limited to the compound 
objection. 
MR. KUVIN: Oh, no, that's fine. 
BY MR. KUVIN: 
Q. All right. Did you purchase something called 
a Twin Torpedo, a soap made in the shape of a penis, and 
a soap in the shape of a vagina? 
A. I'm going to answer that question like I've 
answered most of your questions here today, which is, I 
intend to respond to all relevant questions regarding 
this lawsuit; however, at the present time, my attorneys 
Page 226 
Q. Yeah. Capital M, capital C, number 2; sound 
2 
familiar at all? 
A. Na 
Q. Okay. Are you part owner in a teen modeling 
5 
agency? 
6 
A. Na 
7 
Q. Do you own any interest in any modeling 
8 
agencies currently? 
9 
A. I intend to respond to all relevant questions 
10 
regarding this lawsuit; however, nt the present time, my 
11 
attorneys have counseled me I cannot provide answers to 
12 
any questions relevant to this lawsuit. I must accept 
13 
this advice or risk losing my Gth Amendment right to 
14 
effective representation. Accordingly, I assert my 
15 
federal constitutional rights as guaranteed by the 5th, 
16 
6th and 14th Amendments to the United States 
17 
Constitution. 
18 
Q. Do you know what a sexual device called a Twin 
19 
Torpedo is? 
20 
MR. PIKE: Same objections, irrelevant as 
21 
worded. 
22 
THE WITNESS: Would you like to ask me a bunch 
23 
of questions or are we going to -- do you want to 
24 
individual answers to these? Do you want a 
25 
compound question? 
Page 228 
1 
have counseled me that I cannot provide answers to any 
2 
questions relevant to this lawsuit. I must accept this 
3 
advice or risk losing my 6th Amendment right to 
4 
effective representation. Accordingly, I assert my 
5 
federal constitutional rights as guaranteed by the 5th, 
6 
6th and 14th Amendment to the United States 
7 
Constitution. 
8 
MR. PIKE: Additionally, just for the Courts 
9 
record, you re questioning the witness on Exhibit 
10 
No. what? 
11 
MR. KUVIN: It's not an exhibit. It's the 
12 
Town of Palm Beach Incident Repoli with respect to 
13 
Jeffrey Epstein, of which I gave you a copy before. 
14 
And that was referencing, just so the record is 
15 
clear, page 46. 
16 
MR. PIKE: Then I would add additional 
17 
privileges and objections in addition to what 
18 
Mr. Epstein has already raised underneath Florida 
19 
Rule of Criminal Procedure 3.220 and work product. 
20 
Not necessarily the document in front of you, but 
21 
the questions and the answer you're attempting to 
22 
23 
BY MR. KUVIN: 
24 
Q. Whose mobile wireless number is 
25 
A. I Intend to respond to all relevant questions 
lizacsrnai,a,mrazwax, 
15 (Pages 225 to 228) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Facelift' 
----------------- 
Electronically signed 
bt8d9dI0-41cb-496c-a244-099977073134 
EFTA01087069

Page 229 
1 
regarding this lawsuit; however, at the present time, my 
2 
attorneys have counseled me I cannot provide answers to 
3 
any questions relevant to this lawsuit. I must accept 
4 
this advice or risk losing my 6th Amendment right to 
5 
effective representation. Accordingly, I hereby assert 
6 
my federal constitutional rights as guaranteed by the 
7 
5th, 6th and 14th Amendments to the United States 
8 
Constitution. 
9 
Q. Pm going to read you, for speed's sake, three 
10 
separate phone numbers, and it's the same question for 
11 
each. Do you recognize the following phone numbers? 
12 
They all have Area Code M. The first one is 
13 
the second is 
and the third is 
14 
A. I intend to respond to all relevant questions 
15 
regarding this lawsuit; however, at the present time, my 
16 
attorneys have counseled melcannot provide answers to 
17 
any questions relevant to this lawsuit. 1 must accept 
18 
this advice or risk losing my 6th Amendment right to 
19 
effective representation. Accordingly, I must assert my 
20 
federal constitutional rights as guaranteed by the 5th, 
21 
6th and 14th Amendments to the United States 
22 
Constitution. 
23 
Did 
or 
have the phone number 
24 
or El -- Pr
25 
again. So two numbers: Either 
ins 
same number
, 
on 
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 
Page 231 
effective representation. Accordingly, I hereby assert 
my federal constitutional rights as guaranteed by the 
5th, 6th and 14th Amendments to the United States 
Constitution. 
MR. PIKE: In addition, same objection and 
privilege which regard to the Florida Rule of 
Procedure 3.220 and work product. Not necessarily 
the document you're talking or speaking from, but 
the testimony. 
MR. KUVIN: I was just reading this. I wasn't 
asking questions from this at the moment. 
BY MR. KUVIN: 
Q. Does your penis have any deformities? 
MR. PIKE: Form. 
THE WITNESS: I intend to respond to all 
relevant questions regarding this lawsuit; however, 
at the present time, my attorneys have counseled me 
I cannot provide answers the any questions relevant 
to the lawsuit. I must accept this advice or risk 
losing my 6th Amendment right to effective 
representation. Accordingly, I assert my federal 
constitutional rights as guaranteed by the 5th, 6th 
and 14th Amendment to the Constitution, as I've 
done with most of your questions hero today. 
Page 230 
1 
A. I intend to respond to all relevant questions 
2 
regarding this lawsuit; however, at the present time, my 
3 
attorneys have counseled me I cannot provide answers to 
4 
any questions relevant to the lawsuit. I must accept 
this advice or risk losing my 6th Amendment right to 
6 
effective representation. Accordingly, I must assert my 
7 
federal constitutional rights as guaranteed by the 5th, 
8 
6th and 14th Amendments to the Constitution. 
9 
Q. Do you have an egg-shaped penis? 
10 
A. I intend to respond to all relevant questions 
11 
regarding this lawsuit; however, at the present time, my 
12 
attorneys have counseled me I cannot provide answers to 
13 
any questions that may be relevant to this lawsuit. I 
14 
must accept this advice or risk losing my 6th Amendment 
15 
right to effective representation. Accordingly, I must 
16 
assert my federal constitutional rights as guaranteed by 
17 
the Sth, 6th and 14th Amendment to the United States 
18 
Constitution. 
19 
Q. Do you have any identifying marks on your 
20 
penis? 
21 
A. I intend to respond to all relevant questions 
22 
regarding this lawsuit; however, at the present time, my 
23 
attorneys have counseled mot I cannot provide answers to 
24 
any questions relevant to the lawsuit. 1 must accept 
25 
their advice or risk losing my 6th Amendment right to 
Page 232 
1 
BY MR. KUVIN: 
2 
Q. Did you ever utilize Dollar-Rent-a-Car to rent 
3 
cars while you were hero in Palm Beach at any time? 
4 
A. I intend to respond to all relevant questions, 
5 
Mr. Kuvin, regarding this lawsuit; however, at the 
6 
present time, my attorneys have counseled me I cannot 
7 
provide answers to any questions that may prove relevant 
8 
to this lawsuit. I must accept this advice or risk 
9 
losing my 6th Amendment right to effective 
10 
representation. Accordingly, I must assert my federal 
11 
constitutional rights as guaranteed by the 5th, 6th and 
12 
14th Amendment to the United States Constitution. 
13 
Q. What was your personal cell phone carrier back 
14 
in 2004? 
15 
A. I intend to respond to all relevant questions 
16 
regarding this lawsuit. 
17 
Q. Let me make this quicker. I'm sorry for 
16 
interrupting you, I apologize. Let's say, what was your 
19 
cell phone carrier back from 2004 through 2006. 
20 
MR. PIKE: And I'm not objecting to compound; 
21 
however, there are various allegations in your 
22 
complaint regarding a time frame. So therefore, 
23 
with regard to the allegations in your complaint, 
24 
relative to your question, I'm not objecting to the 
25 
compound, I'm saying it's overbroad. 
16 (Pages 229 to 232) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciull 
Electronically signed by Jeana RIcciull 
bf8d9df0-4fcb.496e-a244-09997 7073134 
EFTA01087070

Page 233 
1 
MR. KUVIN: 2004 to 2006? 
2 
MR. PIKE: Overbroad and irrelevant based upon 
3 
the allegations that you've alleged. 
4 
MR. KUVIN: All right. Well, let me clarify 
5 
the question then. 
6 
BY ME. KUVIN: 
7 
Q. What was your cell phone carrier from 2004 to 
8 
2005? 
9 
MR. PIKE: Same objections. 
10 
BY MR. KUV1N: 
11 
Q. Well, lel me try and fix it again. What was 
12 
your cell phone carrier from 2005 to 2006? 
13 
MR. PIKE: Relevance. 
14 
THE WITNESS: I intend to respond to all 
15 
relevant questions regarding this lawsuit; however, 
16 
at the present time, my attorneys have counseled me 
17 
I cannot provide answers to any questions relevant 
18 
to this lawsuit. I must accept their advice or 
19 
risk losing my 6th Amendment right to effective 
20 
representation; therefore, I must assert my federal 
21 
constitutional rights as guaranteed by the 5th, 6th 
22 
and 14th Amendments to the United States 
23 
Constitution. 
24 
BY MR. KUVIN: 
25 
Q. What were the cell phone carriers of 
Page 235 
1 
BY MR. KUVIN: 
2 
Q. Here, let me move this out of the way. 
3 
A. You can take your Joy Jelly home now. 
4 
Q. Its actually an exhibit to your deposition. 
S 
A. Sorry. 
6 
Q. Have you read the police department's, the 
7 
Palm Beach Police Departments, probable cause 
8 
affidavit? Have you ever read it? 
9 
MR. PIKE: Attorney-client, work privilege. 
10 
BY MR. KUVIN: 
11 
Q. Have you over read the police department, Palm 
12 
Beach Police Departments incident report regarding you? 
13 
MR. MICE: Same objection. 
14 
MR. GOLDBERGER: Same objection. 
15 
MR. PIKE: And instruction, I'm sorry. 
16 
BY MR. KUVIN: 
17 
Q. Are you circumcised? 
18 
MR. PIKE.• Objection, relevance. 
19 
THE WITNESS: I intend to respond to all 
20 
relevant questions regarding this lawsuit; however, 
21 
at the present time, my attorneys have counseled me 
22 
I cannot provide answers to any questions relevant 
23 
to this lawsuit. I must accept this advice or risk 
24 
losing my 6th Amendment right to effective 
25 
representation. Accordingly, I assert my federal 
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 
Page 234 
or Chislaine Maxwell from the 
years 2005 to 2006? 
MR. PIKE: Relevance. 
THE WITNESS: I intend to respond to all 
relevant questions regarding this lawsuit. As I've 
answered most of your questions the saute way today, 
Mr. Kuvin, at the present time, my attorneys have 
counseled me I cannot provide answers to any of 
your questions that may be relevant to this 
lawsuit. I must accept this advice or risk losing 
my 6th Amendment right to effective representation. 
Therefore, accordingly, I assert my federal 
constitutional rights as guaranteed by the 5th, Gth 
and 14th Amendment to the United States 
Constitution. 
May wo take a break, please? 
MR. KUVIN: Sure. 
MR. PIKE: Yes. 
MR. GOLDBERGER: Yes. 
THE VIDEOGRAPHER: Going off the record at 
3:21. 
(A brief recess was taken.) 
THE VIDEOGRAPHER: Were back on the record at 
3:30. 
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 
Page 236 
constitutional rights as guaranteed by the 5th, 6th 
and 14th Amendments to the United States 
Constitution. 
BY MR. KUVIN: 
Q. Was a search warrant performed and executed at 
your home on Palm Beach Island? 
MR. GOLDBERGER: Attorney-client, work 
privilege. 
Ill instruct you not to answer. 
BY MR. KUVIN: 
Do n know 
spelled 
s 
led 
• or 
A. I intend to respond to all relevant questions 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled me I cannot provide answers to 
any questions relevant to this lawsuit. And as I've 
answered most of your questions today, Mr. Kuvin, I must 
accept this advice and risk losing -- or risk losing my 
Gth Amendment right to effective representation. 
Accordingly, I assert my federal constitutional rights 
as guaranteed by the 5th, 6th and 14th Amendments to the 
United States Constitution. 
Q. Did you have a chef working for you at your 
Palm Beach home back in 2005? 
17 (Pages 233 to 236) 
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Page 237 
A. I intend to respond to all relevant questions 
2 
regarding this lawsuit; however, at the present time, my 
3 
attorneys have counseled me I cannot provide answers to 
4 
any questions relevant to this lawsuit at this time. I 
5 
must accept their advice or risk losing my 6th Amendment 
6 
right to effective representation. Accordingly, I must 
7 
assert my federal constitutional rights as guaranteed by 
0 
the 5th, 6th and 14th Amendment to the United Slates 
9 
Constitution. 
10 
MR. PIKE: Additionally, predicate and 
11 
foundation. 
12 
BY MR. KUVIN: 
13 
Q. Did you own or do you currently own a 2004 
14 
black Chevy Suburban, bearing Florida tag 
15 
A. I intend to respond to all relevant questions 
16 
regarding this lawsuit; however, at the present time, my 
17 
attorneys have counseled me I cannot provide answers to 
18 
any questions that may be relevant to the lawsuit. I 
19 
must accept their advice or risk losing my 6th Amendment 
20 
right to effective representation; therefore, I assert 
21 
my federal constitutional rights as guaranteed by the 
22 
5th, 6th and 14th Amendment to the United States 
23 
Constitution. 
24 
Q. I think I asked this before, and I apologize 
25 
if I did, but your date of birth is January 20, 1953, 
Page 239 
1 
BY MR. KUV1N: 
2 
Q. -- or any other women in this case? 
3 
MR. GOLDBERGER: Okay. Now attorney-client, 
4 
work product. 
5 
I direct you not to answer. 
6 
BY MR. KUVIN: 
7 
Q. Do you know the name of the girl that was with 
8 
when she was brought to your home? 
9 
MR. PIKE: Form, lack of predicate, 
10 
foundation. 
11 
THE WITNESS: Like I've done to many of your 
12 
other questions and responded to many of your other 
13 
questions today, Mr. Kuvin, that question -- I must 
14 
answer that, I intend to answer all relevant 
15 
questions regarding this lawsuit; however, at the 
16 
present time, my attorneys have counseled meI 
17 
cannot provide answers to any questions that may be 
18 
relevant. I must accept this advice or risk losing 
19 
my 6th Amendment right to effective representation; 
20 
therefore, I assert my federal constitutional 
21 
rights as guaranteed by the 5th, 6th and I 4lb 
22 
Amendment to the Constitution. 
23 
BY MR. KUVIN: 
24 
Q. Did you, in fact, give M. 5200 for a -- for 
25 
her to get naked and give you a massage while you were 
Page 238 
1 
correct? 
2 
A. You asked that before. 
3 
Yes, correct. 
4 
Q. Okay, Pm sorry. 
Do you own a -- or did you own -- let me 
clarify. 
A. Do you want to do compound again? 
Q. Yeah. Did you or do you currently own a 2005 
9 
black Cadillac Escalade ESV, bearing Florida license tag 
10 
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A. I intend to respond to all relevant questions 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled me 1 cannot provide answers to 
any questions that may be relevant to the lawsuit. I 
must accept their advice or risk losing my 6th Amendment 
right to effective representation. Accordingly, 
assert my federal constitutional rights as guaranteed by 
the 5th, 6th and 14th Amendment to the United States 
Constitution. 
. Have you hired attorneys for either 
Ghislaine Maxwell, 
other - 
MR. GOLDBEROER: Attorney-client, work 
product. 
Arc you done? l'm sorry. 
Cr any 
Page 240 1
1 
naked and, in addition, touch her in her vagina without 
2 
her permission in 2005? 
3 
MR. PIKE: Predicate, foundation --
4 
THE WITNESS: I believe that's been asked and 
5 
answered. 
6 
MR. PIKE: Harassing. And I believe as 
I 
worded, that question has been asked and answered 
8 
in sub parts. I believe you've asked those 
9 
questions initially at the beginning of this 
a 
deposition. The same objections would, therefore, 
11 
apply and be incorporated. 
12 
MR. KUVIN: I disagree, but... 
13 
THE WITNESS: Like most of your other 
14 
questions here today, I intend to respond to all 
15 
relevant questions regarding this lawsuit; however, 
16 
at the present time, my attorneys have counseled mo 
17 
I cannot provide answers to any questions that may 
18 
be relevant. I must accept this advice or risk 
19 
losing my 6th Amendment privilege. Accordingly, I 
20 
assert my federal constitutional rights as 
21 
guaranteed by the 5th, 6th and 14th Amendment to 
22 
the US Constitution. 
23 
BY MR. KUVIN: 
24 
Q. Do ou agree, sir, that your conduct, with 
25 
respect to M., caused her severe emotional distress? 
18 (Pages 237 to 240) 
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Page 241 
MR. PIKE: Same objection. In addition, it's 
2 
argumentative, harassing and calls for a 
3 
conclusion. 
4 
THE WITNESS: Yin going to have to answer that 
the same way I've answered most of your questions 
6 
today, Mr. Kuvin, which is, I intend to respond to 
7 
all relevant questions regarding this lawsuit; 
8 
however, at the present time, my attorneys have 
9 
counseled me I cannot provide answers to any 
10 
questions relevant to the lawsuit. I must accept 
11 
this advice or risk losing my 6th Amendment right 
12 
to effective representation. Accordingly, I must 
13 
assert my federal constitutional rights as 
14 
guaranteed by the 5th, 6th and 14th Amendment. 
15 
BY MR. KUVIN: 
16 
Q. Do you have gray chest hair? 
17 
A. I intend to respond to all relevant questions 
18 
regarding this lawsuit; however, at the present time, my 
19 
attorneys have counseled me I cannot provide answers to 
20 
any of those questions that may be relevant. I must 
21 
accept this advice or risk losing my 6th Amendment right 
22 
to effective representation. Accordingly, I assert my 
23 
federal constitutional rights as guaranteed by the 5th, 
24 
6th and 14th Amendments to the United States 
25 
Constitution. 
Page 243 
1 
effective representation. Accordingly, I must assert my 
2 
federal constitutional rights as guaranteed by the 5th, 
3 
6th and 14th Amendments to the United States 
4 
Constitution. 
5 
Q. Do you have a steam room in your home on Palm 
6 
Beach Island? 
7 
MR. PIKE: Same objections. 
8 
THE WITNESS: I'm going to answer that 
9 
question the same way I've answered most of your 
10 
questions here today, which is, I intend to respond 
11 
to all relevant questions regarding this lawsuit; 
12 
however, at the present time, my attorneys have 
13 
counseled me that 1 cannot provide answers to any 
14 
questions relevant to the lawsuit. I must accept 
15 
this advice or risk losing my 6th Amendment right 
16 
to effective representation. Accordingly, I must 
17 
assert my constitutional rights as guaranteed by 
18 
the 5th — 5th, 6th and 14th Amendments to the 
19 
United States Constitution. 
20 
BY MR. KUVIN: 
21 
Q. Did you provide payments to underaged girls by 
22 
utilizing cash and wire transfers through Western Union 
23 
in 2004 or 20057 
24 
MR. PIKE: Same objections as raised to the 
25 
previous last three questions incorporated here. 
Page 242 
1 
Q. Have you told young ladies -- girls under the 
2 
age of 18, when they came to your house and got naked to 
3 
give you a massage, quote, the more you do, the more you 
get paid? 
MR. PIKE: Objection, form, predicate, 
foundation, improper hypothetical and assumes facts 
not in evidence, relevance. 
8 
THE WITNESS: Lilco most of your questions, 
9 
Mr. Kuvin, today,1 intend to respond to all 
10 
relevant questions regarding this lawsuit; however, 
11 
at the present time, my attorneys have counseled me 
12 
1 cannot provide answers to any questions relevant 
13 
to this lawsuit. I must accept this advice or risk 
14 
losing my 6th Amendment right to effective 
15 
representation. Accordingly, I assert my federal 
16 
constitutional rights as guaranteed by the 5th, Gth 
17 
and 14th Amendment to the United States 
18 
Constitution. 
19 
BY MR. Kt./VIN: 
20 
Q. Do you have any tattoos? 
21 
A. I intend to respond to all relevant questions 
22 
regarding this lawsuit; however, at the present time, my 
23 
attorneys have counseled mel cannot provide answers to 
24 
any questions relevant to this lawsuit. I must accept 
25 
this advice or risk losing my 6th Amendment right to 
Page 244 
1 
THE WITNESS: I intend to respond to all 
2 
relevant questions regarding this lawsuit; however, 
3 
at the present time, my attorneys have counseled me 
4 
I cannot provide answers to any questions relevant 
5 
to the lawsuit. I must accept this advice or risk 
6 
losing my Gth Amendment right to effective 
7 
representation. Accordingly, I assert my federal 
8 
constitutional rights as guaranteed by the 5th, 6th 
9 
and 14th Amendment to the United States 
10 
Constitution. 
11 
BY MR. KUVIN: 
12 
Q. Did you -- excuse me. Did you take any 
13 
videotapes of girls that were under the ago of 18 in 
14 
your home on Palm Beach Island? 
15 
MR. PIKE: Same objections incorporated. 
16 
THE WITNESS: As I have with most of your 
17 
questions today, Pm going to have to answer that, 
18 
I intend to respond to all relevant questions 
19 
regarding this lawsuit; however, at the present 
20 
time, my attorneys have counseled me I cannot 
21 
provide answers to any questions that may be 
22 
relevant to this lawsuit. I must accept this 
23 
advice or risk losing my 6th Amendment right to 
24 
effective representation. Accordingly, I assert my 
25 
federal constitutional rights as guaranteed by the 
19 (Pages 241 to 244) 
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Electronically signed by Jeana Ricciuti 
Electronically signed by Jeana Meting 
bffidadlOsifeb-49k-a244-099977073134 
EFTA01087073

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Page 245 
1 
5th, 6th and 14th Amendment to the United States 
2 
Constitution. 
3 
BY MR. KUVIN: 
4 
Q. Have you ever provided a dozen roses to a 
young girl under the age of 18 who came to your house to 
6 
give you a massage? 
MR. PIKE: Form, vague, ambiguous, assumes 
8 
facts not In evidence. 
9 
THE WITNESS: I intend to respond to all 
10 
relevant questions regarding this lawsuit; however, 
11 
at the present time, my attorneys have counseled me 
12 
that I cannot provide answers to any questions that 
13 
may be relevant. I must accept their advice or 
14 
risk losing my 6th Amendment right to effective 
15 
representation. Accordingly, I must assert my 
16 
federal constitutional rights as guaranteed by the 
17 
5th, 6th and 14th Amendment. 
18 
BY MR. KUVIN: 
19 
Q. Did you ever instruct anyone to deliver a 
20 
bucket of roses after a high school drama perforinanct to 
21 
an underaged girl? 
22 
MR. PIKE: Same objection. in addition, lacks 
23 
predicate and foundation. It's overbroad as well. 
24 
THE WITNESS: I fully intend to respond to all 
25 
relevant questions regarding this lawsuit; however, 
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Page 247 
MR. KUVIN: Okay. All right, 1 appreciate 
your patience. That's all the questions that 1 
have right now. I know that Mr. Goldberger needs 
to deal with an issue right now with Ms. Ezell 
regarding any further questions. 
MR. GOLDBERGER: I think we clarified that. 
Ms. Ezell, are you there? 
MS. EZELL: Fm here. 
MR. GOLDBERGER: Yeah. You had a discussion 
with Bob Critton already concerning the question 
you raised with me earlier, right? 
MS. EZELL: Yes, I did, and I don't have any 
questions. 
MR. PIKE: Ms. Ezell, this is Michael Pike. I 
don't know what your conversation was with Bob, but 
did you cross notice this deposition? 
MS. EZELL: No, I did not. 
MR. PIKE: So what is your purpose of being 
here? 
My position is that those arc closed 
proceedings and your client, your client did not 
cross notice this deposition and/or your clients. 
So what is your purpose of sitting in on this 
deposition? 
MS. EZELL: Well, I received a notice of it, 
Page 246 
at the present time, my attorneys have counseled me 
2 
that I cannot provide answers to any questions 
3 
relevant to the lawsuit. 1 must accept their 
advice or risk losing my 6th Amendment right to 
effective representation. Accordingly, I assert my 
federal constitutional rights as guaranteed by the 
5th, 6th and 14th Amendment to the United States 
Constitution. 
BY MR. KUVIN: 
Q. Hold on a second. 1 ma be done. 
Do you know a Dr. 
A. I intend to respond to all relevant questions 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled me I cannot provide answers to 
any questions that may be relevant. I must accept this 
advice or risk losing my 6th right to effective 
representation. Accordingly, I assert my federal 
constitutional rights as guaranteed by the 5th, 6th and 
14th Amendment to the United States Constitution. 
MR. PIKE: Can you hold on one second? 
MR. KUVIN: I'm almost done. 
MR. PIKE: No, no. We're not going anywhere. 
MR. KUV1N: Okay. 
MR. PIKE: Okay. 
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Page 218 
and I just thought I would listen to it while I was 
doing some other work. And I don't know why it 
would be a closed proceeding. 
MR. PIKE: Discovery proceedings arc closed if 
It's a pre-trial discovery, ma'am, it's not a court 
proceeding. 
Nonetheless, do you have any questions for the 
witness? 
MS. EZELL: No, I don't. 
MR. PIKE: And Ms. Holmes, who am you here on 
behalf of? Which clients? 
MS. HOLMES: M. and M. 
MR. PIKE: Arai also here on behalf of lane 
Doe in the case 
MS. HOLMES: 1 believe so, yes. 
MR. PIKE: Do you have any questions for the 
witness? 
MS. HOLMES: No, I do not. 
MR. GOLDBERGER: Katherine, we're going to 
end. Do you want me to disconnect you now? 
MS. FM t  • Yes, thanks. 
MR. GOLDBERGER: Okay. 
THE VIDEOGRAPHER: Conclude the deposition and 
go off the record at 3:00--
MR. PIKE: Wait one second. 
20 (Pages 245 to 248 
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Bectronicatry signed by Jeans Ricclud 
bfildedtO4fcb-496c-a244.099977073134 
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