EFTA01103326

vs. 
IN THE CIRCUIT COURT OF THE FIFTEENTH 
JUDICIAL CIRCUIT, IN AND FOR 
PALM BEACH COUNTY, FLORIDA 
Plaintiff; 
) 
)
) 
149. 
) 
EPSTEIN and 
) 
) 
Defendants. 
) 
West Palm Bach, Florida 
April 30th, 2009 
I008 o'clock A.M. 
VIDEOTAPED DEPOSITION 
OF 
JEFFREY EPSTEIN 
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INDEX 
Direct Examination by Mr. Edwards 
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EXHIBIT INDEX 
Plaintiffs Exhibit Hunter I marked for ID. 
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(Exhibit held by Attorney Edwards.) 
+++++++++ 
Deposition of JEFFREY EPSTEIN, a witness 
of lawful age, taken by the Plaintiff, for the 
purpose of discovery and for use as evidence in the 
above entitled cause, wherein: E.W. is the 
Plaintiff, and JEFFREY EPSTEIN and-
the Defendants, in the Circuit Court in and for Palm 
Beach County, Florida, pursuant to notice heretofore 
filed, before LINDA P. AUKAMP, a Registered 
Professional Reporter and Notary Public in and for 
the State of Florida at Large, at 250 Australian 
Avenue South, Suite 1400, West Patin Beach, Palm 
Beach County, Florida, on the 30th day of April, 
2009, commencing at 10:08 o'clock A.M. 
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APPEARANCES: 
2 
For The Plaintiff: 
3 
ROTHSTEIN, ROSENFELDT, ADLER 
401 East Las Olas Boulevard, Suite 1650 
4 
Fon Lauderdale, Florida, 33301.4252 
By BRADLEY JAMES EDWARD, ESQUIRE and 
5 
WILLIAM J. BERGER, ESQUIRE and 
RUSSELL ADLER, ESQUIRE 
6 
7 
For The Defendant 
BURMAN, CRITTON, LUTHER & COLEMAN 
S I5 North Plaster Drive, Suite 400 
9 
West Palm Beach, Florida 33401.4349 
By JOHN MICHAEL BURMAN, ESQUIRE 
10 
11 
Also for the Defendant 
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ATTER.BURY, GOLDBERGER & WEISS, P.A. 
250 Australian Ave. South, Suite 1400 
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West Palm Beach, Florida 33401 
By JACK A. GOLDBERGER, ESQUIRE 
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Also Present: 
16 
Jeff Abbott, Videographer, Visual Evidence 
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Page 
1 
THEREUPON, 
2 
THE VIDEOGRAPHEEt: This is the 30th day 
3 
April, 2009. The time is 10:08 a.m. This is 
4 
videotaped 
ition of Jeffrey Epstein in the 
5 
matter of... versus Epstein. This deposition 
6 
is being held at 250 Australian Avenue South, 
7 
West Palm Beach, Florida. My name is Jeff 
Abbott, lam the videographer representing 
9 
Visual Evidence, Incorporated. 
10 
Would the attorneys please announce their 
11 
appearances for the record. 
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MIt EDWARDS: Brad Edwards on behalf of 
3.3 
the plaint' 
"deposition was set in 
3.4 
the case of 
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THE VIDEOGRAPHER: Oh. 
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MR. EDWARDS: That is a separate client of 
17 
mine, but that's not the case 
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THE VIDEOGRAPHER: Okay, that's what I 
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had. Sorry. 
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MR. BERGER: And Pm William J. Berger, 
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for the plaintiff, also. 
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MR. GOLDBERGER: Jack Goldberger on behal 
2 3 
of Jeffrey Epstein. 
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MR. BURMAN: Michael Burman on behalf of 
25 
le 
in. 
I 
Mat' 
• -• 
• 
• 
mil.N 
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1 
THEREUPON, 
2 
JEFFREY EPSTEiN, 
3 
Being a witness in the notice heretofore 
4 
filed, being of lawful age, and being first duly 
5 
sworn in the above cause, testified on his oath as 
6 
follows: 
7 
THE WITNESS: Yes, I do. 
8 
DIRECT EXAMINATION 
9 
Q. (By Mr. Edwards) Can you tell us your 
10 
fidl name for the record? 
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A. Jeffrey Edward Epstein. 
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Q. And what's your date of birth? 
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A. January 20th, 1953. 
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Q. And your social security number? 
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A. 
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Q. And your current address in West Palm 
17 
Beach? 
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A. I intend to respond to all relevant 
19 
questions regarding this lawsuit. However, at the 
20 
present time my attorneys have counseled me that I 
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cannot provide answers to any questions relevant to 
22 
this lawsuit, and I must accept the advice or risk 
23 
losing my Sixth Ansadment right to effective 
24 
representation. 
25 
Accordingly, I assert my Fifth, Federal 
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3. 
Constitutional rights as guaranteed by the Fifth, 
2 
Sixth, and Fourteenth Amendments to the United 
3 
States Constitution. 
4 
Q. So you're unwilling to give us your 
5 
address of your house in Palm Beach Comity? 
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A. I intend to respond to all relevant 
7 
questions regarding this lawsuit. However, at the 
8 
present time my attorneys have counseled me that I 
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cannot provide answers to any questions relevant to 
10 
this lawsuit or risk losing my Sixth Amendment right 
11 
to effective representation. 
12 
MR. EDWARDS: Mr. Goldberger, can we enter 
13 
into an agreement so that we all know that he's 
14 
reading off of that piece of paper, we know 
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what the whole spiel is, but maybe he can just 
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say fifth or same answer or something like 
17 
that, so we can continue to move on, rather 
18 
than read that paper the entire time? We'll be 
19 
here for days. 
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MR. GOLDBERGER: I think out of an 
21 
abundance of caution ifs probably appropriate 
22 
that whatever we feel is the proper response 
23 
is, so that our invocation of our Fifth 
24 
Amendment privileges is properly protected, 
25 
so I think we're 
in to
no
 have to Ove the full 
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length -
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MR. BURMAN: Obviously we can't tell what 
3 
you're going to play to a jury without the 
4 
entire spiel, what questions you night play to 
5 
a jury if you decide to do that when this case 
6 
is tried, so we're going to go with the entire 
7 
spiel to every question you ask. If -- that's 
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Mr. Goldberger's representation, or 
9 
recommendation. 
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MR. EDWARDS: Okay. 
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MR. GOLDBERGER: We will go question by 
12 
question, and we may or may not invoke Fifth 
13 
Amendment privileges and there may be times 
14 
where I'm going to have to think about it, 
15 
discuss it with Mr. Burman whether we're going 
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to invoke on any particular question, but on 
17 
those questions that we do invoke Fifth 
18 
Amendment privileges, I think we have no choice 
19 
but, as you say, do the entire spiel. 
20 
Q. (By Mr. Edwards) Can you tell me the 
21 
addresses of other homes that you own outside of 
22 
West Palm Beach? 
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A. I intend to respond to all relevant 
24 
questions regarding this lawsuit. However, in the 
25 
present my attorneys have counseled me that I cannot 
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provide answers to any questions relevant to this 
lawsuit, and i must accept the advice or risk losing 
my Sixth Amendment right to effective 
representation. 
Q. Have you seen any —
MR. GOLDBERGER: And, excuse me, and your 
Fifth Anwhipeat privileges. 
THE WITNESS: Yes. 
Accordingly, i, excuse me, I assert my 
Federal Constitutional rights as guaranteed by 
the Fifth, Sixth and Fourteen Amendments of the 
United States Constitution. 
Q. (By Mr. Edwards) Have you seen any 
psychologists a psychiatrists in your life? 
MR. GOLDBERGER: Go ahead. 
THE WITNESS: 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 relevant to this lawsuit, and i 
must accept this advice or risk losing my Sixth 
Amendment right to effective representation. 
Accordingly. I assert my constitutional 
rights as guaranteed by the Fifth, Sixth and 
Fourteenth Amendment of that constitution. 
2 (Pages 5 to 8 
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Q. (By Mr. Edwards) Tell me the names of all 
2 
the businesses in which you are affiliated in any 
3 
way? 
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A. I intend to respond to all relevant 
5 
questions regarding this lawsuit. However, at the 
6 
present time my attorneys have counseled me that I 
7 
cannot provide answers to any questions relevant to 
8 
this lawsuit, and I must accept this advice or risk 
9 
losing my Sixth Amendment right to effective 
10 
representation. 
11 
I also assert my Federal Constitutional 
12 
Rights as guaranteed by the Fifth, Sixth, and 
13 
Fourteenth Amendments to the United States 
14 
Constitution. 
15 
Q. My understanding is you're currently 
16 
serving a 12-month jail sentence, is that correct? 
17 
MR. GOLDBERGER: You can answer, but --
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THE WITNESS: Na 
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Q. (By Mr. Edwards) You were currently, you 
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were initially sentenced to 18 months in jail, is 
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that correct? 
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MR. GOLDBERGER: Go ahead. 
23 
THE WITNESS: Yes. 
24 
Q. (By Mr. Edwards) And at the present 
25 
moment are you still under the supervision of that 
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A. Sorry, could you repeat the question? 
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Q. Sure. 
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I have a videotaped copy of the plea 
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colloquy —
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A. No, the question before that. That's 
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okay. 
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Q. The question is, where do you intend to 
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reside once you are released from jail? 
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A. I intend to respond to all relevant 
10 
questions regarding this lawsuit. However, at the 
11 
present time my attorneys have counseled me that I 
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cannot provide answers to any questions relevant to 
13 
this lawsuit, and I must accept their advice or risk 
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losing my Sixth Amendment right to effective 
15 
representation. 
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Accordingly, I assert my Federal 
17 
Constitutional right as guaranteed by the Fifth, 
18 
Sixth, and Fourteenth Amendment of the United States 
19 
Constitution. 
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Q. As you know, that question was asked to 
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you when you pled guilty last June in 2008, and you 
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responded to the judge that you planned to reside in 
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West Palm Beach, Florida. Is that no longer your 
24 
intent? 
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A. I intend to respond to all relevant 
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jail sentence? 
2 
A. Yes. 
3 
Q. Do you !mow what your release date will 
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be? 
S 
A. No. 
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Q. You have not been told the date of your 
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release? 
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A. Not yet. 
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Q. Where do you plan to reside when you're 
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released from jail? 
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A. I intend to respond to all relevant 
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questions regarding this lawsuit. However, at the 
13 
present time my attorneys have advised me that I 
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must accept the advice, advised me not to answer 
15 
those questions. I must accept their advice or risk 
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losing my Sixth Amendment right to effective 
17 
representation. 
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Accordingly, I assert my Federal 
19 
Constitutional right as guaranteed by the Fifth, 
20 
Sixth, and Fourteenth Amendment of the constitution. 
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Q. Mr. Epstein, I have a videotaped copy of 
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the plea colloquy where you pled guilty and told 
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that judge you would be residing in West Palm Beach, 
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Florida. Are you saying now that the statement you 
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made to that inlEn312longer true? 
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questions regarding this lawsuit However, at the 
2 
present time my attorneys have counseled me that I 
3 
cannot provide answers to any questions relevant to 
4 
this lawsuit, and I must accept this advice or risk 
5 
losing my Sixth Amendment right to effective 
6 
representation. 
7 
Accordingly, I assert my Federal 
8 
Constitutional right as guaranteed by the Fifth, 
9 
Sixth, and Fourteenth Amendment of the constitution. 
10 
Q. This deposition is not being taken in the 
11 
county jail, but rather in your attorney, Jack 
12 
Goldberger's office, so can you please inform the 
13 
jury as to your current schedule as it is exists 
14 
today? 
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MR GOLDBERGER: Let me hold off on that. 
16 
Okay. 
17 
THE WITNESS: I don't understand the 
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schedule, the question. 
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MR. GOLDBERGER: Yeah, if you can just, if 
2o 
you can rephrase the question, I think we can 
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answer it for you. 
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Q. (By Mr. Edwards) Okay. Currently you 
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described that you're under the supervision of the 
24 
jail sentence at this point in time, you're within 
25 
the 18 months of your,jail sentence. But this isn't 
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a jail setting, so obviously you're outside of the 
2 
jail setting. 
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I am asking you just to tell the jury your 
4 
current schedule; you wake up, are you released from 
5 jail at some time, do you have to report back to 
6 
jail on a daily basis? 
7 
A. Yes, I report back to jail at 8:00 p.m. 
8 
Q. Every single day? 
9 
A. Yes. 
10 
Q. And is it seven days a week that you're 
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out on work release? 
12 
A. No, sir. 
13 
Q. How many days a week are you out on work 
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release? 
15 
A. Six. 
16 
Q. And of those six days, how many hours per 
17 
day are you out on work release? 
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A. Twelve. 
19 
Q. And what are the hours that you're out on 
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work release versus the hours that you are confined 
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to the jail? 
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A. Repeat the question, please. 
23 
Q. What are the hours that you are out on 
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work release outside the jail versus the hours that 
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you are inside the jail, meaning if you report back 
Page 14 
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to the jail at 8:00 and stay there until 8:00 in the 
2 
morning, tell me that 
3 
A. I just did. 
4 
Q. And is that the schedule? 
5 
A. !just did. Yes, that's the schedule. 
6 
Q. Okay. So from 8:00 p.m. until 8:00 an. 
7 
you're in the jail? 
8 
A. Yes. 
9 
Q. And then from 8.00 a.m. to 8:00 p.m. 
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you're out on work release? 
11 
A. Is that a question? 
12 
Q. Yes. 
13 
A. Yes. 
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Q. And where do you, where do you work? 
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MR. GOLDBERGER Objection. 
16 
THE WITNESS: I intend to respond to all 
17 
relevant questions to this lawsuit. However, 
18 
at the present time my attorneys have counseled 
19 
me that I cannot provide answers to any 
20 
questions relevant to this lawsuit, and I must 
21 
accept this advice or risk losing my Sixth 
22 
Amendment right to effective representation. 
23 
Therefore, I assert my Federal 
24 
Constitutional right as guaranteed by the 
25 
Fifth, Sixths and Fourteenth Amendment of the 
Page 15 
1 
constitution. 
2 
Q. (By Mr. Edwards) Are you saying that 
3 
providing me an answer as to where you currently 
4 
work, would somehow incriminate you? 
5 
MR. GOLDBERGER: Let's not be 
6 
argumentative. He responded to the question on 
7 
advice of counsel, and if you think that was an 
8 
improper invocation, then you have a remedy, 
9 
but don't argue with the witness, which is what 
10 
we did. Okay. 
11 
Q. (By Mr. Edwards) Do you have any plans to 
12 
leave the country once you're released from jail? 
13 
A. I intend to respond to all relevant 
14 
questions regarding this lawsuit. However, at the 
15 
present time my attorneys have counseled me that I 
16 
cannot provide answers to any questions relevant to 
17 
this lawsuit, and must accept the advice or risk 
18 
losing my Sixth Amendment right to effective 
19 
representation. 
20 
Accordingly, I assert my Federal 
21 
Constitutional right as guaranteed by the Fifth, 
22 
Sixth, and Fourteenth Amendment of the constitution. 
23 
Q. Do you currently own any jets or 
24 
airplanes? 
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A. I intend to respond to all relevant 
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questions regarding this lawsuit. However, at the 
present time my attorneys have counseled me that I 
cannot provide answers to any questions relevant to 
this lawsuit, and must accept the advice or risk 
losing my Sixth Amendment right to effective 
representation. 
Accordingly, I assert my constitutional 
right as guaranteed by the Fifth, Sixth, and 
Fourteenth Amendment ofirnstitution 
MR. BURMAN: Is 
a state or federal 
case? 
MR. EDWARDS: State. 
MR BURMAN: Okay. I am going to, in 
addition to my client's assertion of his 
rights, also object on the grounds that 
punitive damages hasn't been allowed in this 
case yet. That's clearly a financial-type 
question and, therefore, we object on those 
grounds, as well. 
MR. EDWARDS: Thank you. 
Q. (By Mr. Edwards) Who are the pilots that 
are employed by you or work for you or fly your 
airplanes? 
A. I intend to respond to all relevant 
questions regarding this lawsuit. However at the 
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present time my attorneys have counseled me that I 
2 
cannot provide answers to any questions relevant to 
3 
this lawsuit, and must accept their advice or risk 
4 
losing my Sixth Amendment right to effective 
5 
representation. 
6 
Accordingly, I assert my Federal 
7 
Constitutional rights guaranteed by the Fifth, 
8 
Sixth, and Fourteenth Amendment to the United States 
9 
Constitution. 
10 
Q. What person or persons make your travel 
11 
arrangements when you travel? 
12 
A. I intend to respond to all relevant 
13 
questions regarding this lawsuit However, at the 
14 
present time my attorneys have advised me that I 
15 
cannot provide answers to any questions relevant to 
16 
this lawsuit, and must accept this advice or risk 
17 
losing my Sixth Amendment right to effective 
18 
representation. 
19 
Accordingly, I would have to assert my 
20 
Federal Constitutional right as guaranteed by the 
21 
Fifth, Sixth, and Fourteenth Amendment of the 
22 
constitution. 
23 
Q. Once you are released from jail, are you 
24 
under an obligation to report to probation? 
25 
A. Yes. 
Page 19 
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questions regarding this lawsuit However, at the 
2 
present time my attorneys have advised me that I 
3 
cannot provide answers to any questions currently. 
4 
Therefore, I must accept this advice or risk losing 
5 
my Sixth Amendment right to effective 
6 
representation. 
7 
Accordingly, ! assert my Federal 
8 
Constitutional right as guaranteed by the Fifth, 
9 
Sixth, and Fourteenth Amendment to the constitution. 
10 
Q. Are you currently working with the Florida 
11 
Science Foundation? 
12 
MR. GOLDBERGER: Umm, okay. 
13 
THE WITNESS: Yes. 
14 
Q. (By Mr. Edwards) And that is a, a 
15 
business that operates just next door to your 
16 
attorney, Jack Goldberger's office, is that correct? 
17 
A. No. 
18 
Q. The Florida Science Foundation does not 
19 
have an office on this floor right next door to your 
20 
attorney, Jack Goldberger's office? 
23. 
A. Is that a question? 
22 
Q. Yes. 
23 
A. You have to rephrase the question, please? 
24 
Q. Does the Florida Science Foundation have 
25 
an office right next door to your attorney, Jack 
Page 18 
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Q. Do you intend to do so? 
2 
A. Yes. 
3 
Q. And once you are released, do you, 
4 
according to your sentence, are you scheduled to 
5 
serve one year community control or house arrest? 
6 
MR. GOLDBERGER: That's a compound 
7 
question. Please rephrase it. 
8 
THE WITNESS: Yes. 
9 
Q. (By Mr. Edwards) When you're released 
10 
from jail, do you intend to serve one year community 
11 
control as a part of your sentence? 
12 
A. Yes. 
13 
Q. And under that provision, will you be able 
14 
to continue working or will you be strictly confined 
15 
to your house? 
16 
MR. GOLDBERGER: That calls for a legal 
17 
interpretation on the part of my client that 
18 
he's just not, he's just not competent to 
19 
answer. So, if you know, fine, but I can't 
20 
imagine you would know. 
23. 
THE WITNESS: I don't know. 
22 
Q. (By Mr. Edwards) Who are the people that 
23 
will be living or working in your house once you are 
24 
released from jail? 
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A. I intend to respond to all relevant 
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Goldbergees office? 
A. No. 
Q. What is your role with the Florida Science 
Foundation? 
A. I intend to respond to all relevant 
questions regarding this lawsuit. However, at the 
present time my attorneys have advised me that I 
cannot answer questions relevant to this lawsuit and 
must accept their advice, or risk losing my Sixth 
Amendment right to effective representstion. 
Therefore, I must assert my Federal 
Constitutional right under the Fifth, Sixth, and 
Fourteenth Amendment to the constitution. 
Q. What does the Florida Science Foundation 
do? 
A. I intend to respond to all relevant 
questions to this, regarding this lawsuit. However, 
at the present time my attorneys have counseled me 
that I cannot provide answers to any questions 
relevant to this lawsuit i must accept their 
advice or risk losing my Sixth Amendment right to 
effective representation. 
Accordingly, lessen my Federal 
Constitutional rights guaranteed by the Fifth, 
Sixth, and Fourteenth Amendment to that 
5 (Pages 17 to 20) 
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constitution. 
2 
Q. Have you procured minors for the purposes 
3 
of prostitution? 
4 
A. I intend to respond to all relevant 
5 
questions to this, regarding this lawsuit However, 
6 
at the present time my attorneys have counseled me 
7 
that I cannot provide answers to any questions 
8 
relevant to this lawsuit, and must accept their 
9 
advice or risk losing my Sixth Amendment right to 
10 
effective representation. 
13. 
Accordingly, I assert my Federal 
12 
Constitutional right as guaranteed by the Fifth, 
13 
Sixth and Fourteenth Amendment of the United States 
14 
Constitution. 
15 
Q. Isn't it true that you did plead guilty to 
16 
two felonies related to prostitution with minors? 
17 
MR. GOLDBERGER: Wait a minute, let me 
18 
just hold off a second. 
19 
(Thereupon, a discussion was had off 
20 
the record.) 
21 
MR. GOLDBERGER: You can answer the 
22 
question. 
23 
THE WITNESS: Could you repeat the 
24 
question? 
25 
Q. (By Mr. Edwards) Isn't it true that you 
Page 22 
1 
pled guilty to two felony counts related to 
2 
procurement of a minor for prostitution and/or 
3 
solicitation of a minor for prostitution? 
4 
A. No. 
5 
Q. What counts did you plead guilty to? 
6 
A. Procuring a minor for prostitution and 
7 
soliciting prostitution. 
8 
Q. Have you had sex with minor girls? 
9 
A I intend to respond to all relevant 
10 
questions regarding this lawsuit. However, at the 
11 
present time my attorneys have advised me that I 
12 
cannot provide answers to any questions relevant to 
13 
this lawsuit at the present time, and I must accept 
14 
that advice or risk losing my Sixth Amencirnent right 
15 
to effective representation. 
16 
Accordingly, I assert my Federal 
17 
Constitutional right under the Fifth, Sixth, and the 
18 
Fourteenth Amendment to the Constitution. 
19 
Q. Have you engaged in sex acts with girls 
20 
who at the time you engaged in those sex acts were 
21 
minors? 
22 
A. I intend to respond to all relevant 
23 
questions to this lawsuit. At the present time my 
24 
attorneys have counseled me that I cannot respond, 
25 
I'm som. provide answers to any uestions relevant 
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to this lawsuit, and I must accept that advice or 
risk losing their representation. 
Accordingly, I assert my Federal 
Constitutional right as guaranteed by the Fifth, 
Sixth, and Fourteenth Amendment. 
Did you intentionally touch my client, 
A. I don't understand the question, sorry. 
Q. For the purpose of this lawsuit, we have 
used the pseudonym to describe my client. Do you 
know who Pm talking about when I refer toMil 
A. I intend to respond to all relevant 
questions to those, this lawsuit. However, at the 
present time my attorneys have advised me that I 
cannot accept, answer any questions relevant to this 
lawsuit, and must accept their advice, or risk 
losing my Sixth Amendment right to effective 
rgrc istation. 
Q. Did you —
A. Accordingly -- excuse me -- I assert my 
Federal Constitutional right as guaranteed by the 
Fifth, Sixth, and Fourteenth Amendment to the United 
States Constitution. 
MR. BURMAN: We further object on the 
ground tha
name has not been disclosed 
Page 24 
and you've objected to that. 
MR. EDWARDS: Thanks. 
(By Mr. Edwards) Did you touch my client 
NM, against her will? 
A. We don't know who 
is. You haven't 
told me who 
is. 
Q. Okay. 
MR. EDWARDS: Do you have an exhibit 
slicker? 
(Thereupon, Plaintiffs Exhibit 
Number 1 was marked for Identification by 
Attorney Edwards.) 
Q. (By Mr. Edwards) Pm going to show you an 
exhibit that I have marked for identification 
purposes as Plaintiffs Exhibit 1. 
Do you recognize the girl on the left in 
the photograph? 
A. I intend to respond to all relevant 
questions regarding —
THE WITNESS: Excuse me one second. 
(Thereupon, a discussion was had off 
the record.) 
THE WITNESS: I intend to respond to all 
relevant questions regarding this lawsuit. 
Howeveriz2a
Jre,sent
the 
time 
atto 
have 
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1 
counseled me that I cannot provide answers to 
2 
any questions relevant to this lawsuit. I must 
3 
accept their advice or risk losing my Sixth 
4 
Amendment right to effective representation. 
5 
Accordingly, I assert my Federal 
6 
Constitutional right as given by the Fifth, 
7 
Sixth -- as provided by the Fifth, Sixth, and 
8 
Fourteenth Amendment to the constitution. 
9 
Q. (By Mr. Edwards Do you know somebody by 
10 
the name o
11 
A. I intend to respond to all relevant 
12 
questions regarding this lawsuit. However, at the 
13 
present time my attorneys have counseled me that I 
14 
cannot provide answers to any questions relevant to 
15 
this lawsuit, and must accept their advice or risk 
16 
losing my Sixth Amendment right to effective 
17 
representation. 
18 
Accordingly, I assert my Federal 
19 
Constitutional right as guaranteed by the Fifth, 
20 
Sixth and Fourteenth Amendment to the constitution. 
21 
Q. For the purposes of this deposition, when 
22 
I refer toM, I'm speaking of 
23 
Back to mthiitial questi . 
24 
touch my client,.., against her will? 
25 
A. I intend to respond to all relevant 
Page 27 
1 
A. I intend to respond to all relevant 
2 
questions regarding this lawsuit. However, at the 
3 
present time my attorneys have counseled me that 1 
4 
cannot provide answers to any questions relevant to 
5 
this lawsuit, and 1 must accept this advice or risk 
6 
losing my Sixth Amendment right to effective 
7 
representation. 
8 
Accordingly, I assert my Federal 
9 
Constitutional right as guaranteed by the Fifth, 
10 
Sixth, and Fourteenth Amendment to the United States 
11 
Constitution. 
12 
Q. Did you engage in sex or sex acts with a 
13 
female named 
(phonetic)? 
14 
A. I intend to respon to all relevant 
15 
questions regarding this lawsuit. However, at the 
16 
present time my attorneys have counseled me that I 
17 
cannot provide answers to any questions relevant to 
18 
this lawsuit, and I must accept this advice or risk 
19 
losing my Sixth Amendment right to effective 
20 
representation. 
21 
Accordingly, I assert my Federal 
22 
Constitutional right under the Fifth, Sixth, and 
23 
Fourteenth Amendment of the constitution. 
24 
Q. Between 2001 and 2005 did you en 
25 
sex or sex acts with a minor female named 
Page 26 
1 
questions regarding this lawsuit. However, at the 
2 
present time my attorneys have advised me that I 
3 
cannot provide answers to any questions relevant to 
4 
this lawsuit, and must accept their advice or risk 
5 
losing my Sixth Amendment right to effective 
6 
representation. 
7 
Accordingly, I assert my Fifth, Sixth, and 
8 
Fourteenth — Fifth, Sixth and Fourteenth Amendment 
9 
of the constitution. 
10 
Q. Did
 engage in sex or sex acts with my 
11 
clien
against her will? 
12 
A. I intend to respond to all relevant 
13 
questions regarding this lawsuit. However, at the 
14 
present time my attorneys have advised me that I 
15 
cannot provide any questions relevant to this 
16 
lawsuit, and must accept their advice or risk losing 
17 
my Sixth Amendment right to effective 
18 
representation. 
19 
Accordingly, I assert my Federal 
20 
Constitutional right as guaranteed by the Fifth, 
21 
Sixth, and Fourteenth Amendment to that 
22 
constitution. 
23 
Q. Isn't it true that when you touthec. 
24 
against her will, you knew her to be a minor at the 
25 
time? 
Page 28 
1 
(phonetic)? 
2 
A. I intend to respond to all relevant 
3 
questions regarding this lawsuit. However, at the 
4 
present time my attorneys have counseled me that I 
5 
cannot provide answers to any questions relevant to 
6 
this lawsuit, and I must accept this advice or risk 
7 
losing my Sixth Amendment right to effective 
8 
representation. 
9 
Accordingly, I assert my Federal 
10 
Constitutional rights as guaranteed by the Fifth, 
11 
Sixth, and Fourteenth Amendment to the United States 
12 
Constitution. 
13 
Q. Between 2001 and 2005 did vou engage in 
14 
sex or sex acts with a minor named Mphonetic)? 
15 
A. I intend to respond to all relevant 
16 
questions regarding this lawsuit. However, at the 
17 
present time my attorneys have counseled me that I 
18 
cannot provide answers to any questions relevant to 
19 
this lawsuit, and I must accept this advice or risk 
20 
losing my Sixth Amendment right to effective 
21 
representation. 
22 
Accordingly, I assert my Federal 
23 
Constitutional right as guaranteed by the Fifth, 
24 
Sixth, and Fourteenth Amendment to the United States 
25 
Constitution. 
7 (Pages 25 to 28) 
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Page 29 
1 
Q. Between 2001 and 2005 did you will 
2 
sex or sex acts with a minor female named 
3 int (phonetic)? 
4 
A. I intend to respond to all relevant 
5 
questions regarding this lawsuit. However, at the 
6 
present time my attorneys have counseled me that I 
7 
cannot provide answers to any questions relevant to 
a 
this lawsuit, and must accept their advice or risk 
9 
losing my Sixth Amendment right to effective 
10 
representation. 
11 
Accordingly, i assert my Federal 
12 
Constitutional right as guaranteed by the Fifth, 
13 
Sixth, and Fourteenth Amendment to the United States 
14 
Constitution. 
15 
MR. BURMAN: Mr. Edwards, can I inquire of 
16 
you one thing? Do you have a RICO count in 
17 
UN's case? 
18 
MR. EDWARDS: Yes. 
19 
MR. BURMAN: Okay. These other girls, are 
20 
any of than your clients, as well? 
23. 
MR. EDWARDS: Some may be. 
22 
MR. BURMAN: Okay. Thank you. 
23 
MR. EDWARDS: Some are not. 
24 
MR. BURMAN: Okay. 
25 
Q. (By Mr. Edwards) Between 2001 and 2005 
Page 31 
1 
Q. Between 2001 and 2005 did you eruriS 
2 
sex or sex acts with a minor female named 
3 
(phonetic)? 
4 
A. I intend to respond to all relevant 
5 
questions regarding this lawsuit. However, at this 
6 
time my attorneys have counseled me that I cannot 
7 
provide answers to any questions relevant to this 
8 
lawsuit, and I must accept this advice or risk 
9 
losing my Sixth Amendment right to effective 
10 
representation. 
11 
Accordingly, I assert my Federal 
12 
Constitutional right as guaranteed by the Fifth, 
13 
Sixth, and Fourteenth Amendment of the United States 
14 
Constitution. 
15 
Q. Between 2001 and 2005 did you ensi 
16 
sex or sex acts with a minor female named 
17 
(phonetic)? 
18 
A. I intend to respond to all relevant 
19 
questions regarding this lawsuit. However, at the 
20 
present time my attorneys have counseled me that I 
21 
cannot provide answers to any questions relevant to 
2 2 
this lawsuit, and must accept this advice or risk 
23 
losing my Sixth Amendment right to effective 
24 
representation. 
25 
Accordingly, I assert my Federal 
Page 30 
1 
did you engage in sex or sex acts with a minor 
2 
female named IMIMEliphonetic)? 
3 
A. I intend to respond to all relevant 
4 
questions regarding this lawsuit. However, at the 
5 
present time my attorneys have counseled me that I 
6 
cannot provide answers to any questions relevant to 
7 
this lawsuit, and must accept this advice or risk 
B 
losing my Sixth Amendment right to effective 
9 
representation. 
10 
Accordingly, I assert my Federal 
11 
Constitutional rights as guaranteed by the Fifth, 
12 
Sixth, and Fourteenth Amendment to the constitution. 
13 
Q. Between 2001 and 2005 did you engage in 
14 
sex or sex acts with a minor female named 
15 
(phonetic)? 
16 
A. I intend to respond to all relevant 
17 
questions regarding this lawsuit. However, at the 
18 
present time my attorneys have counseled me that I 
19 
cannot provide answers to any questions relevant to 
20 
this lawsuit, and I must accept this advice or risk 
21 
losing my Sixth Amendment right to effective 
22 
representation. 
23 
Accordingly, I assert my Federal 
24 
Constitutional right as guaranteed by the Fifth, 
25 
Sixth?. and Fourteenth Amendment to the constitution. 
Page 32 
1 
Constitutional rights as guaranteed by the Fifth, 
2 
Sixth, and Fourteenth Amendment to the United States 
3 
Constitution. 
4 
Q. Between 2001 and 2005 did you engage in 
5 
sex or sex acts with a minor female named -
6 
(phonetic)? 
7 
A. I intend to respond to all relevant 
a 
questions regarding this lawsuit. However, at the 
9 
present time my attorneys have counseled me that I 
10 
cannot provide answers to any questions relevant to 
11 
this lawsuit I must accept this advice or risk 
12 
losing my Sixth Amendment right to effective 
13 
representation. 
14 
Accordingly, I assert my Federal 
15 
Constitutional right under the Fifth, Sixth, and 
16 
Fourteenth Amendment to the constitution. 
17 
Q. Between 2001 and 2005 did you 
e in 
18 
sex or sex acts with a minor female named 
19 
(phonetic)? 
2 0 
A. I intend to respond to all relevant 
21 
questions regarding this lawsuit However, at the 
2 2 
present time my attorneys have counseled me that I 
23 
cannot provide answers to any questions relevant to 
24 
this lawsuit, and must accept this advice or risk 
25 
Iosing my Sixth Amendment right to effective 
8 (Pages 29 to 32) 
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1 
representation. 
2 
Accordingly, I assert my Federal 
3 
Constitutional right as guaranteed by the Fifth, 
4 
Sixth, and Fourteenth Amendment to the United States 
5 
Constitution. 
6 
THE WITNESS: Can we take a break for, a 
7 
bathroom break, is that okay? 
8 
THE VIDEOGRAPHER: We're off the record at 
9 
10:39. 
10 
(Thereupon, a discussion was had off 
11 
the record.) 
12 
THE VIDEOGRAPHER: We're back on the 
13 
record at 10:44. 
14 
Q. (By Mr. Edwards) Between 2001 and 2005 
15 
did you engalii sex or sex acts with a minor 
16 
female name' 
(phonetic)? 
17 
A. I intend to respond to all relevant 
18 
questions regarding this lawsuit. However, at the 
19 
present time my attorneys have counseled me that I 
20 
cannot provide answers to questions relevant to this 
21 
lawsuit, and I must accept their advice or risk 
22 
losing my Sixth Amendment right to effective 
23 
representation. 
24 
Accordingly, I assert my Federal 
25 
Constitutional right as guaranteed by the Fifth, 
Page 34 
1 
Sixth and the Fourteenth Amendment to the United 
2 
States Constitution. 
3 
THE WITNESS: Can I see you a second, 
4 
Mike? 
5 
MIL BURMAN: Sure. 
6 
THE VIDEOORAPHER: We're off the record at 
7 
10:45. 
8 
(Thereupon, a brief break was taken.) 
9 
THE VIDEOGRAPHER: Back on the record at 
10 
10:46. 
11 
Q. (By Mr. Edwards) Between the year 2001 
12 
and 2005 did you eriy
in sex or sex acts with a 
13 
minor female named 
in
14 
MR. BURMAN: Object to form, form vague 
15 
and indefinite. Last name, please. 
16 
MR. EDWARDS: You can answer the question. 
17 
THE WITNESS: I intend to respond to all 
18 
relevant questions regarding this lawsuit 
19 
However, at the present time my attorneys have 
20 
counseled me that I cannot provide answers to 
21 
any questions relevant to this lawsuit, and 
22 
must accept this advice or risk losing my Sixth 
23 
Amendment right to effective representation. 
24 
Accordingly, I assert my Federal 
25 
Constitutional right as guaranteed b the 
Page 35 
1 
Fifth, Sixth, and Fourteenth Amendment to the 
2 
United States Constitution. 
3 
Q. (By Mr. Edwards) Between the year 2001 
4 
and 2005 did you en ge in sex or sex acts with a 
5 
minor female named 
honetic)? 
6 
MR. BURMAN: O ect to form, vague and 
7 
indefinite. Last name, please. 
8 
MR. EDWARDS: You can answer. 
9 
THE WITNESS: I intend to respond to all 
10 
relevant questions regarding this lawsuit. 
11 
However, at the present time my attorneys have 
12 
counseled me that I cannot provide answers to 
13 
any questions relevant to this lawsuit. I must 
14 
accept this advice or risk losing my Sixth 
15 
Amendment right to effective representation. 
16 
Accordingly, I assert my Federal 
17 
Constitutional rights as guaranteed by the 
18 
Fifth, Sixth and Fourteenth Amendment to the 
19 
United States Constitution. 
20 
Q. (By Mr. Edwards) Between 2001 and 2005 
21 
did you engage in sex or sex acts with a minor 
22 
female named 
(phonetic)? 
23 
MR. BURMAN: Object to form, vague and 
24 
indefinite. Last name, please. 
25 
MR. EDWARDS: You may answer. 
Page 36 
1 
THE WITNESS: I intend to respond to all 
2 
relevant questions regarding this lawsuit. 
3 
However, at the present time my attorneys have 
4 
counseled me that I cannot provide answers to 
5 
any questions relevant to this lawsuit, and 
6 
must accept this advice or risk losing my Sixth 
7 
Amendment right to effective representation. 
8 
Accordingly, I assert my Federal 
9 
Constitutional right as guaranteed by the 
10 
Fifth, Sixth and Fourteenth Amendment to the 
11 
United States constitution. 
12 
Q. (By Mr. Edwards) Between 2001 and 2005 
13 
did you engage in sex or sex acts with a minor 
14 
female named 
phonetic)? 
15 
MR. BURMAN: Object to the form, vague and 
16 
indefinite. Last name, please. 
17 
MR. EDWARDS: You can answer if -
18 
THE WITNESS: 1 intend to respond to all 
19 
relevant questions regarding this lawsuit. 
20 
However, at the present time my attorneys have 
21 
counseled me that I cannot provide answers to 
22 
any questions relevant to this lawsuit. I must 
23 
accept this advice or risk losing my Sixth 
24 
Amendment right to effective representation. 
25 
Accordinfy, I assert my Federal 
9 (Pa-es 33 to 36) 
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Page 37 
1 
Constitutional right as guaranteed by the 
2 
Fifth, Sixth and Fourteenth Amendment to the 
3 
United States Constitution. 
4 
Q. (By Mr. Edwards) Between 2001 and 2005 
did you engage in sex or sex acts with a minor 
6 
female named 
(phonetic)? 
7 
MR. BURMAN: Object to form, vague and 
8 
indefinite. Last name, please. 
9 
MR. EDWARDS: You can answer, if you know. 
10 
THE WITNESS: 1 intend to respond to all 
11 
relevant questions regarding this lawsuit. 
12 
However, at the present time my attorneys have 
13 
counseled me that I cannot provide answers to 
14 
any questions relevant to this lawsuit. I must 
15 
accept this advice or risk losing my Sixth 
16 
Amendment right to effective representation. 
17 
Accordingly, I assert my Federal 
18 
Constitutional right as guaranteed by the 
19 
Fifth, Sixth, and Fourteenth Amendment to the 
20 
United States Constitution. 
21 
Q. (By Mr. Edwards) Between 2001 and 2005 
22 
did you engaga in sex or sex acts with a minor 
23 
female named
(phonetic)? 
24 
MR. BURMAN: Object to form, vague and 
25 
indefinite. Last name, please. 
Page 38 
1 
MR. EDWARDS: You can answer. 
2 
THE WITNESS: I intend to respond to all 
3 
relevant questions regarding this lawsuit. 
4 
However at the present time my attorneys have 
5 
counseled me that I cannot provide answers to 
6 
any questions relevant to this lawsuit, and 
7 
must accept this advice or risk losing my Sixth 
8 
Amendment right to effective representation. 
9 
Accordingly, I assert my Federal 
10 
Constitutional right as guaranteed by the 
11 
Fifth, Sixth, and Fourteenth Amendment to the 
12 
United States Constitution. 
13 
Q. (By Mr. Edwards) Between 2001 and 2005 
14 
did you engage in sex or sex acts with a minor 
15 
female named 
(phonetic)? 
16 
MR. BURMAN: Object to form, vague and 
17 
indefinite. Last name, please. 
18 
MR. EDWARDS: You can answer. 
19 
THE WITNESS: i intend to respond to all 
20 
relevant questions regarding this lawsuit 
21 
However, at the present time my attorneys have 
22 
counseled me that I cannot provide answers to 
23 
any questions relevant to this lawsuit, and 
24 
must accept this advice or risk losing my Sixth 
25 
Amendment right to effective representation. 
1 
2 
3 
4 
S 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 39 
Accordingly, I assert my Federal 
Constitutional right as guaranteed by the 
Fifth, Sixth, and Fourteenth Amendment to the 
United States Constitution. 
Q. (By Mr. Edwards) Between 2001 and 2005 
did you engage in sex or sex acts with a minor 
female that you referred to as 
(phonetic)? 
MR. BURMAN: Object to form, vague and 
indefinite. Last name, please. 
MR. EDWARDS: You can answer. 
MR. BURMAN: Or flavor. 
THE WITNESS: 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 relevant to this lawsuit, and 
must accept this advice or risk losing my Sixth 
Amendment right to effective representation. 
Accordingly, I assert my Federal 
Constitutional right as guaranteed by the 
Fifth, Sixth, and Fourteenth Amendment to the 
constitution. 
Q. (By Mr. Edwards) Between 2001 and 2005 
did you engage in sex or sex acts with a minor 
Page 40 
1 
female named 
phonetic)? 
2 
MR. 13 
: Object to form, vague and 
3 
indefinite. Last name, please. 
4 
MR. EDWARDS: You can answer. 
5 
THE WITNESS: I intend to respond to all 
6 
relevant questions regarding this lawsuit 
7 
However, at the present time my attorneys have 
8 
counseled me that I cannot provide answers to 
9 
any questions relevant to this lawsuit, and 
10 
must accept this advice or risk losing my Sixth 
11 
Amendment right to effective representation. 
12 
Q. (By Mr. Edwards) Between --
13 
THE WITNESS: Sorry? 
14 
MR. EDWARDS: I didn't realize you weren't 
15 
finished. 
16 
THE WITNESS: Accordingly, I assert my 
17 
Federal Constitutional right as guaranteed by 
18 
the Fifth, Sixth and Fourteenth Amendment to 
19 
the United States Constitution. 
2 0 
Q. (By Mr. Edwards) Between 2001 and 2005 
21 
did you 
in sex or sex acts witha 12-year-old 
2 2 
girl named 
onetic)? 
23 
MR B 
: Object to form, vague and 
24 
indefinite. Last name, please. 
2 5 
MR. EDWARDS: You can answer. 
10 (Pages 37 to 4 0) 
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Page 41 
1 
THE WITNESS: I intend to respond to all 
2 
relevant questions regarding this lawsuit. 
3 
However, at the present time my attorneys have 
4 
counseled me that I cannot provide answers to 
5 
any questions relevant to this lawsuit, and 
6 
must accept this advice or risk losing my Sixth 
7 
Amendment right to effective representation. 
8 
Accordingly, I assert my Federal 
9 
Constitutional right as guaranteed by the 
10 
Fifth, Sixth, and Fourteenth Amendment to the 
11 
constitution. 
12 
Q. (By Mr. Edwards) Between 2001 and 2005 
13 
did you engage in sex or sex acts with a minor 
14 
female named 
(phonetic)? 
15 
MR. BURMAN: Object to form, vague and 
16 
indefinite. Last name, please. 
17 
MR. EDWARDS: You can answer. 
18 
THE WITNESS: I intend to respond to all 
19 
relevant questions regarding this lawsuit. 
20 
However, at the present time my attorneys have 
21 
counseled me that I cannot provide answers to 
22 
any questions relevant to this lawsuit. I must 
23 
accept their advice or risk losing my Sixth 
24 
Amendment right to effective representation. 
25 
Accordingly, I assert my Federal 
Page 42 
1 
Constitutional right as guaranteed by the 
2 
Fifth, Sixth and the Fourteenth Amendment to 
3 
the constitution. 
4 
Q. (By Mr. Edwards) Between 2001 and 2005 
5 
did you engage in sex or sex acts with a minor 
6 
female named =phonetic)? 
7 
MR. BURMAN: Object to form, vague and 
8 
indefinite. Last name, please. 
9 
THE WITNESS: I intend to respond to all 
10 
relevant questions regarding this lawsuit. 
11 
However, at the present time my attorneys have 
12 
counseled me that I cannot provide answers to 
13 
any questions relevant to this lawsuit, and 
14 
must accept their advice or risk losing my 
15 
Sixth Amendment right to effective 
16 
representation. 
17 
Accordingly, I assert my Federal 
18 
Constitutional right as guaranteed by the 
19 
Fifth, Sixth, and Fourteenth Amendment to the 
20 
United States Constitution. 
21 
Q. (By Mr. Edwards) Between 2001 and 2005 
22 
did you 
e in sex or sex acts with a minor 
23 
female 
(phonetic)? 
24 
MR. BURMAN: Object to form, vague and 
25 
indefinite. Lastname,please. 
Page 43 
1 
MR. EDWARDS: You can answer. 
2 
THE WITNESS: I intend to respond to all 
3 
relevant questions regarding this lawsuit. 
4 
However, at the present time my attorneys have 
5 
counseled me that I cannot provide answers to 
6 
any questions relevant to this lawsuit, and 
7 
must accept this advice or risk losing my Sixth 
8 
Amendment right to effective representation. 
9 
Accordingly, I assert my Federal 
10 
Constitutional right as guaranteed by the 
11 
Fifth, Sixth, and Fourteenth Amendment to the 
12 
United States Constitution. 
13 
Q. (By Mr. Edwards) Between 2001 and 2005 
14 
did you engage in sex or sex acts with a minor 
15 
female namedM (phonetic)? 
16 
MR. BURMAN: Object to form, vague and 
17 
indefinite. Last name, please. 
18 
MR. EDWARDS: You may answer. 
19 
THE WITNESS: I intend to respond to all 
20 
relevant questions regarding this lawsuit. 
21 
However, at the present time my attorneys have 
22 
counseled me that I cannot provide answers to 
23 
any questions relevant to this lawsuit, and 
24 
must accept this advice or risk losing my Sixth 
25 
Amendment right to effective representation. 
Page 44 
1 
Accordingly, I assert my Federal 
2 
Constitutional right as guaranteed by the 
3 
Fifth, Sixth, and Fourteenth Amendment of the 
4 
United States Constitution. 
5 
Q. (By Mr. Edwards) Between 2001 and 2005 
6 
did you engagejash or sex acts with a minor 
7 
female named .MA (phonetic)? 
8 
MR. BURMAN: Object to form, vague and 
9 
indefinite. Last name, please. 
10 
MR. EDWARDS: You can answer. 
11 
THE WITNESS: I intend to iespund to all 
12 
relevant questions regarding this lawsuit. 
13 
However, at the present time my attorneys have 
14 
counseled me that I cannot provide answers to 
15 
any questions relevant to this lawsuit, and I 
16 
must accept this advice or risk losing my Sixth 
17 
Amendment right to effective representation. 
18 
Accordingly, I assert my Federal 
19 
Constitutional right as guaranteed by the 
20 
Fifth, Sixth, and Fourteenth Amendment to the 
21 
United States Constitution. 
22 
MR. GOLDBERGER: One moment 
23 
(Thereupon, a discussion was had off 
24 
the record.) 
25 
,.., 11Lao
heresAttorney Adler entered 
11 (Pages 41 to 44) 
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Page 45 
1 
the deposition room) 
2 
MR. EDWARDS: We're back on. 
3 
Q. (By Mr. Edwards) Between 2001 and 2005 
4 
did you enpgsm sex or sex acts with a minor 
5 
female named 
(phonetic)? 
6 
MR. BURMAN: Object to form, vague and 
7 
indefinite. Last name, please. 
8 
MR. EDWARDS: You can answer. 
9 
THE WITNESS: I intend to respond to all 
10 
relevant questions regarding this lawsuit. 
11 
However, at the present time my attorneys have 
12 
counseled me that I cannot provide answers to 
13 
any questions relevant to this lawsuit, and 
14 
must accept this advice or risk losing my Sixth 
15 
Amendment right to effective representation. 
16 
Accordingly, I assert my Federal 
17 
Constitutional right as guaranteed by the 
18 
Fifth, Sixth, and Fourteenth Amendment to the 
19 
constitution. 
20 
Q. (By Mr. Edwards) Between 2001 and 2005 
21 
did you engage in sex or sex acts with a minor 
22 
female named 
phonetic)? 
23 
MR. BURMAN: Object to form, vague and 
24 
indefinite. Last name, please. 
25 
MR. EDWARDS: You may answer. 
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 47 
Constitutional rights as guaranteed by the 
Fifth, Sixth, and Fourteenth Amendment to the 
United States Constitution. 
Q. (By Mr. Edwards) Between 2001 and 2005 
did you engage in sex or sex acts with a minor 
female named 
(phonetic)? 
MR. BURMAN: Object to the form, vague and 
indefinite. Last name, please. 
MR. EDWARDS: You can answer. 
THE WITNESS: 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 relevant to this lawsuit, and 
must accept this advice or risk losing my Sixth 
Amendment right to effective representation. 
Accordingly, I assert my Federal 
Constitutional right as guaranteed by the 
Fifth, Sixth, and Fourteenth Amendment to the 
United States Constitution. 
Q. (By Mr. Edwards) Between 2001 and 2005 
did you engage in sex or sex acts with a minor 
female named 111.111(phonetic)? 
MR. BURMAN: Object to form, vague and 
indefinite. Last name, please. 
Page 46 
1 
THE WITNESS: I intend to respond to all 
2 
relevant questions regarding this lawsuit. 
3 
However, at the present time my attorneys have 
4 
counseled me that I cannot provide answers to 
5 
any questions relevant to this lawsuit, and 
6 
must accept this advice or risk losing my Sixth 
7 
Amendment right to effective representation. 
8 
Accordingly, I assert my Federal 
9 
Constitutional rights as guaranteed by the 
10 
Fifth, Sixth, and the Fourteenth Amendment to 
11 
the United States Constitution. 
12 
Q. (By Mr. Edwards) Between 2001 and 2005 
13 
did you engage in sex or sex acts with a minor 
14 
female named 
phonetic)? 
15 
MR BURMAN: Object to form, vague and 
16 
indefinite. Last name, please. 
17 
MR. EDWARDS: You may answer. 
18 
THE WITNESS: I intend to respond to all 
19 
relevant questions regarding this lawsuit. 
20 
However, at the present time my attorneys have 
21 
counseled me that I cannot provide answers to 
22 
any questions relevant to this lawsuit, and I 
23 
must accept this advice or risk losing my Sixth 
24 
Amendment right to effective representation. 
25 
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 48 
MR. EDWARDS: You can answer. 
THE WITNESS: 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 relevant to this lawsuit, and 
must accept this advice or risk losing my Sixth 
Amendment right to effective representation. 
Accordingly, I assert my Federal 
Constitutional right as guaranteed by the 
Fifth, Sixth, and Fourteenth Amendment to the 
United States Constitution. 
Q. (By Mr. Edwards) Between 2001 and 2005 
did you engage in sex or sex acts with a minor 
female named 
phonetic)? 
MR. BURMAN Object to form, vague and 
indefinite. And last name, please? 
MR. GOLDBERGER: Is that 
or 
IIIIIIP 
MR. EDWARDS: — dra. 
THE WITNESS: 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 relevant to this lawsuit, and 
12 (Pages 45 to 48) 
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Page 49 
1 
must accept this advice or risk losing my Sixth 
2 
Amendment right to effective representation. 
3 
Accordingly, I assert my Federal 
4 
Constitutional right as guaranteed by the 
5 
Fifth, Sixth, and Fourteenth Amendment to the 
6 
United States Constitution. 
7 
Q. (By Mr. Edwards) Between 2001 and 2005 
8 
did you engage in sex or sex acts with a minor 
9 
female named 
(phonetic)? 
10 
MR. BURMAN: Object to form, vague and 
11 
indefinite. Last name, please. 
12 
MR. EDWARDS: You can answer. 
13 
THE WITNESS: I intend to respond to all 
14 
relevant questions regarding this lawsuit. 
15 
However, at the present time my attorneys have 
16 
counseled me that I cannot provide answers to 
17 
any questions relevant to this lawsuit, and I 
18 
must accept this advice or risk losing my Sixth 
19 
Amendment right to effective representation. 
2 0 
Accordingly, I assert my Federal 
21 
Constitutional rights as guaranteed by the 
22 
Fifth, Sixth, and Fourteenth Amendment to the 
23 
United States Constitution. 
24 
Q. (By Mr. Edwards) Between 2001 and 2005 
25 
did you engage in sex or sex acts with a minor 
Page 
50 
1 
female namedd
hbonetic)? 
2
MR. B
: 
jest to form, vague and 
3 
indefinite. Last name, please. 
4 
MR. EDWARDS: You can answer. 
5 
THE WITNESS: I intend to respond to all 
6 
relevant questions regarding this lawsuit. 
7 
However, 
at the present time my attorneys have 
8 
counseled me that I cannot provide answers to 
9 
any questions relevant to this lawsuit, and I 
10 
must accept this advice or risk losing my Sixth 
11 
Amendment right to effective representation. 
12 
Accordingly, I assert my Federal 
13 
Constitutional right as guaranteed by the 
14 
Fifth, Sixth, and Fourteenth Amendment to the 
15 
United States Constitution. 
16 
Q. (By Mr. Edwards) Between 2001 and 2005 
17 
did you engage in sex or sex acts with a minor 
18 
19 
female named 
bonetic)? 
MR. BURMAN: 
bject to form, vague and 
20 
indefinite. Last name, please. 
21 
MR. EDWARDS: You can answer. 
22 
THE WITNESS: I intend to respond to all 
23 
relevant questions regarding this lawsuit. 
24 
However, at the present time my attorneys have 
25 
counseled me that I cannot provide answers to 
Page 51 
1 
any questions relevant to this lawsuit, and 
2 
must accept this advice or risk losing my Sixth 
3 
Amendment right to effective representation. 
4 
Accordingly, I assert my Federal 
5 
Constitutional right as guaranteed by the 
6 
Fifth, Sixth, and Fourteenth Amendment to the 
7 
United States Constitution. 
8 
Q. (By Mr. Edwards) Between 2001 and 2005 
9 
did you engage in sex or sex acts with a minor 
10 
female named =phonetic)? 
11 
MR. BURMAN: Object to form, vague and 
12 
indefinite. Last name, please. 
13 
MR. EDWARDS: You can answer. 
14 
THE WITNESS: I intend to respond to all 
15 
relevant questions regarding this lawsuit 
16 
However, at the present time my attorneys have 
17 
counseled me that I cannot provide answers to 
18 
any questions relevant to this lawsuit, and I 
19 
must accept this advice or risk losing my Sixth 
20 
Amendment right to effective representation. 
21. 
Accordingly, I assert my Federal 
22 
Constitutional right as guaranteed by the 
23 
Fifth, Sixth, and Fourteenth Amendment to the 
24 
United States Constitution. 
25 
Q. (By Mr. Edwards) Between 2001 and 2005 
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 52 
did you engage in sex or sex acts with a minor 
female named 
(phonetic)? 
MR. BURMAN: Object to form, vague and 
indefinite. Last name, please. 
MR. EDWARDS: You can answer. 
THE WITNESS: 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 relevant to this lawsuit, and I 
must accept this advice or risk losing my Sixth 
Amendment right to effective representation. 
Accordingly, I assert my Federal 
Constitutional right as guaranteed by the 
Fifth, Sixth, and Fourteenth Amendment of the 
United States Constitution. 
Q. (By Mr. Edwards) Between 2001 and 2005 
did you engage in sex or sex acts with a minor 
female named
 (phonetic)? 
MR. BURMAN: Object to form, vague and 
indefinite. Last name, please. 
MR. EDWARDS: You can answer. 
THE WITNESS: I intend to respond to all 
relevant questions regarding this lawsuit. 
However at the present time myttome s have 
- 
13 (Pages 49 to 52) 
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Page 53 
1 
counseled me that I cannot provide answers to 
2 
any questions relevant to this lawsuit, and I 
3 
must accept this advice or risk losing my Sixth 
4 
Amendment right to effective representation. 
Accordingly, I assert my Federal 
6 
Constitutional right as guaranteed by the 
7 
Fifth, Sixth, and Fourteenth Amendment to the 
8 
United States Constitution 
9 
Q. (By Mr. Edwards) Between 2001 and 2005 
10 
did you engage in sex or sex acts with a minor 
11 
female named El==. 
12 
MR. BURMAN: Object to form, vague and 
13 
indefinite. Last name, please. 
14 
MR. EDWARDS: You can answer. 
15 
THE WITNESS: I intend to respond to all 
16 
relevant questions regarding this lawsuit. 
17 
However, at the present time my attorneys have 
18 
counseled me that I cannot provide answers to 
19 
any questions relevant to this lawsuit, and I 
20 
must accept this advice or risk losing my Sixth 
21 
Amendment right to effective representation. 
22 
Accordingly, I assert my Federal 
23 
Constitutional right as guaranteed by the 
24 
Fifth, Sixth, and Fourteenth Amendment to the 
25 
constitution. 
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 55 
any questions relevant to this lawsuit, and 
must accept this advice or risk losing my Sixth 
Amendment right to effective representation. 
Accordingly, I assert my Federal 
Constitutional right as guaranteed by the 
Fifth, Sixth, and Fourteenth Amendment to the 
United States Constitution. 
Q. (By Mr. Edwards) For the purposes of 
these next questions, when I refer to "the minor 
Its" I'm refeninc to 
S, 
my client, which is 
the plaintiff in this lawsuit. 
My question is --
MR. GOLDBERGER: You've identified that 
correct? 
MR. EDWARDS: Correct. 
Q. (By Mr. Edwards) With each of these 
girls, isn't it true that you paid somebody else to 
1 
Page 54 
1. 
Q. (By Mr. Edwards) Isn't it true that at 
2 
the time you engaged in sex or sex acts with each of 
3 
the people we have just discussed, you knew they 
4 
were minors? 
5 
MR. BURMAN: Object to form. 
6 
THE WITNESS: I intend to respond to all 
7 
relevant questions regarding this lawsuit. 
8 
However, at the present time my attorneys have 
9 
counseled me that I cannot provide answers to 
10 
any questions relevant to this lawsuit, and 
11 
must accept this advice or risk losing my Sixth 
12 
Amendment right to effective representation. 
13 
Accordingly, I assert my Federal 
14 
Constitutional right under the Fifth, Sixth, 
15 
and Fourteenth Amendment to the United States 
16 
Constitution. 
17 
Q. (By Mr. Edwards) With each of these 
18 
girls, isn't it hue that you used someone else to 
19 
recruit them to your house? 
20 
MR. BURMAN: Object to form, vague and 
23. 
indefinite. 
22 
THE WITNESS: I intend to respond to all 
23 
relevant questions regarding this lawsuit. 
24 
However, at the present time my attorneys have 
25 
counseled me that I cannot rovide answers to 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 56 
bring them to your house? 
MR. BURMAN: Object to the form, vague and 
indefinite. 
THE WITNESS: 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 relevant to this lawsuit, and 
must accept this advice or risk losing my Sixth 
Amendment right to effective representation. 
Accordingly, ! assert my Federal 
Constitutional right as guaranteed by the 
Fifth, Sixth, and Fourteenth Amendment to the 
United States Constitution. 
Q. (By Mr. Edwards) For each of these minor 
girls, isn't it true that you paid each of them for 
sex or sex acts? 
MR. BURMAN: Object to form, vague and 
indefinite. Further explaining that to the 
extent that no ►ast names have been identified 
for most of the girls. 
MR. EDWARDS: You can answer. 
THE WITNESS: I intend to respond to all 
relevant questions regarding this lawsuit. 
However at the .resent time 
attom 
have 
14 
Pa es 53 to 56) 
PALM BEACH REPORTING SERVICE, INC. 
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Page 57 
1 
counseled me that I cannot provide answers to 
2 
any questions relevant to this lawsuit, and 
3 
must accept this advice or risk losing my Sixth 
4 
Amendment right to effective representation. 
5 
Accordingly, I assert my Federal 
6 
Constitutional tight as guaranteed by the 
7 
Fifth, Sixth, and Fourteenth Amendment to the 
8 
United States Constitution. 
9 
Q. (By Mr. Edwards) Isn't it true that in 
10 
order to recruit each of these minor girls to your 
11 
house, you had someone tell them, "A rich guy in 
12 
Palm Beach will pay you cash to go to his house and 
13 
give him a massage"? 
14 
MR. BURMAN: Object to form, vague and 
15 
indefinite, to the extent last names of the 
16 
girls have not been identified. 
17 
THE WITNESS: I intend to respond to all 
18 
relevant questions regarding this lawsuit 
19 
However, at the present time my attorneys have 
20 
counseled me that I cannot provide answers to 
21 
any questions relevant to this lawsuit. I must 
22 
accept this advice or risk losing my Sixth 
23 
Amendment right to effective representation. 
24 
Accordingly, I assert my Federal 
25 
Constitutional right as guaranteed by the 
Page 58 
1 
Fifth, Sixth, and Fourteenth Amendment of the 
2 
United States Constitution. 
3 
Q. (By Mr. Edwards) Each of these minor 
4 
girls, when arriving at your house, was greeted at 
5 
the door by one of your employees at your mansion, 
6 
isn't that correct? 
7 
MR. BURMAN: Object to form, vague and 
8 
indefinite. No description of last names of 
9 
the alleged minor girls. 
10 
THE WITNESS: I intend to respond to all 
11 
relevant questions regarding this lawsuit 
12 
However, at the present time my attorneys have 
13 
advised me that I cannot provide answers to any 
14 
questions relevant to this lawsuit, and I must 
15 
accept this advice or risk losing my Sixth 
16 
Amendment right to effective representation. 
17 
Accordingly, I assert my Federal 
18 
Constitutional right as guaranteed by the 
19 
Fifth, Sixth, and Fourteenth Amendment to the 
20 
United States Constitution. 
21 
Q. (By Mr. Edwards) Each of these minor 
22 
girls was escorted up to your bedroom by one of your 
23 
employees, isn't that correct? 
24 
MR. BURMAN: Object to the form, vague and 
25 
indefinite. 
Page 59 
1 
THE WITNESS: I intend to respond to all 
2 
relevant questions regarding this lawsuit. 
3 
However, at the present tint my attorneys have 
4 
counseled me that I cannot provide answers to 
5 
any questions relevant to this lawsuit, and I 
6 
must accept this advice or risk losing my Sixth 
7 
Amendment right to effective representation. 
8 
Accordingly, I assert my Federal 
9 
Constitutional rights as guaranteed by the 
10 
Fifth, Sixth, and Fourteenth Amendment to the 
11 
United States Constitution. 
12 
May I just ask, step outside for a second, 
13 
I want to just ask a question. 
14 
MR. BURMAN: Sure. 
15 
THE VIDEOGRAPHER: Going off the record at 
16 
11:11. 
17 
(Thereupon, a brief break was taken.) 
18 
THE VIDEOGRAME12: Okay, we're back on the 
19 
record at 11:16. 
20 
Q. (By Mr. Edwards) Previously I named, or I 
21 
gave you the names of 49 minor girls. Isn't it true 
22 
that you engaged in sex or sex acts with each of 
23 
them? 
24 
MR. BURMAN: Object to the form, vague and 
25 
indefinite. Last names weren't provided for 
Page 60 
1 
most of them. 
2 
THE WITNESS: I intend to respond to all 
3 
relevant questions regarding this lawsuit 
4 
However, at the present time my attorneys have 
5 
counseled me that I cannot provide answers to 
6 
any questions relevant to this lawsuit, and 
7 
must accept that advice or risk losing my Sixth 
8 
Amendment right to effective representation. 
9 
Accordingly, I assert my Federal 
10 
Constitutional right as guaranteed by the 
11 
Fifth, Sixth, and Fourteenth Amendment to the 
12 
constitution. 
13 
Q. (By Mr. Edwards) With respect to each of 
14 
the minor girls that was taken into your bedroom by 
15 
one of your employees, isn't it true that you 
16 
entered the room wearing only a towel? 
17 
MR. BURMAN: Object to form, vague and 
18 
indefinite, last names of the alleged minor 
19 
girls weren't provided. 
20 
THE WITNESS: I intend to letwnd to all 
21 
relevant questions regarding this lawsuit 
22 
However, at the present time my attorneys have 
23 
counseled me that 1 cannot provide answers to 
24 
any questions relevant to this lawsuit, and 
25 
must accept this advice or risk losing my Sixth 
15 (Pages 57 to 60) 
PALM BEACH REPORTING SERVICE, INC. 
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Page 61 
1 
Amendment right to effective representation. 
2 
Accordingly, my federal, I have to assert 
3 
my Federal Constitutional rights as guaranteed 
4 
by the Fifth, Sixth, and Fourteenth Amendment 
to the United States Constitution. 
6 
Q. (By Mr. Edwards) With respect to each of 
7 
these minor girls, isn't it true that you ordered 
8 
each of them to get naked to give you a massage? 
9 
MR. BURMAN: Object to form, vague and 
10 
indefinite with regard to the alleged minor 
11 
girls, the names weren't provided. Last names 
12 
weren't provided. 
13 
MR. EDWARDS: You can answer. 
14 
THE WITNESS: I intend to respond to all 
15 
relevant questions regarding this lawsuit. 
16 
However, at the present time my attorneys have 
17 
counseled me that I cannot provide answers to 
18 
any questions relevant to this lawsuit, and I 
19 
must accept this advice or risk losing my Sixth 
20 
Amendment right to effective representation. 
21 
Accordingly, I assert my Federal 
22 
Constitutional right as guaranteed by the 
23 
Fifth, Sixth, and Fourteenth Amendment to the 
24 
United States Constitution. 
25 
Q. (By Mr. Edwards) With rebind to each of 
Page 62 
1 
the 49 named minor girls, isn't it true that you 
2 
masturbated in front of each of them? 
3 
MR. BURMAN: Object to the form, vague and 
4 
indefinite with regard to the alleged minor 
5 
girls, their last names weren't provided. 
6 
THE WITNESS: I intend to respond to all 
7 
relevant questions regarding this lawsuit 
8 
However, at the present time my attorneys have 
9 
counseled me that i cannot provide answers to 
1 o 
any questions relevant to this lawsuit, and I 
11 
must accept their advice or risk losing my 
12 
Sixth Amaidment right to effective 
13 
representation. 
14 
Accordingly, lessen my Federal 
15 
Constitutional rights as guaranteed by the 
16 
Fifth, Sixth, and Fourteenth Amendment to the 
17 
United States Constitution. 
18 
Q. (By Mr. Edwards) Isn't it true that you 
19 
asked each of the minor girls to do similar things 
20 
to you, such as rub your nipples? 
21 
MR. BURMAN: Object to the form, vague and 
22 
indefinite with regard to the alleged minor 
23 
girls, the last names weren't provided. 
24 
THE WITNESS: I intend to respond to all 
25 
relevant uestions re anii 
this lawsuit. 
Page 63 
1. 
However, at the present time my attorneys have 
2 
counseled me that I cannot provide answers to 
3 
any questions relevant to this lawsuit, and I 
4 
must accept this advice or risk losing my Sixth 
5 
Amendment right to effective reptw‘ntation. 
6 
Accordingly, I assert my Federal 
7 
Constitutional rights as guaranteed by the 
8 
Fifth, Sixth, and Fourteenth Amendment to the 
9 
United States Constitution. 
10 
Q. (By Mr. Edwards) With respect to all of 
11 
the named 49 minor girls, isn't it true that you 
12 
tried to touch each of them in a sexual way? 
13 
Wt. BURMAN: Object to font vague and 
14 
indefinite with regard to the alleged minor 
15 
girls, last names weren't provided. 
16 
THE WITNESS: I intend to respond to all 
17 
relevant questions regarding this lawsuit 
18 
However, at the present time my attorneys have 
19 
counseled me that I cannot provide answers to 
20 
any questions relevant to this lawsuit. I must 
21 
accept this advice or risk losing my Sixth 
22 
Amendment right to effective representation. 
23 
Accordingly, I assert my Federal 
24 
Constitutional rights as guaranteed by the 
25 
Fifth, Sixth, and Fourteenth Amendment to the 
1 
2 
3 
4 
5 
6 
8 
7 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 64 
United States Constitution. 
Q. (By Mr. Edwards) With respect to each of 
the 49 minor girls, isn't it true that you touched 
their bare breasts? 
MR. BURMAN: Object to form, vague and 
indefinite with regard to the alleged minor 
girls, last names weren't provided. 
THE WITNESS: 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 relevant to this lawsuit. And I 
must accept this advice or risk losing my Sixth 
Amendment right to effective representation. 
Accordingly, I assert my Federal 
Constitutional right as guaranteed by the 
Fifth, Sixth, and Fourteenth Amendment to the 
United States Constitution. 
Q. (By Mr. Edwards) With respect to each of 
these 49 minor girls, isn't it true that you 
inserted your fingers into their vaginas? 
MR. BURMAN: Object to form of the 
question, vague and indefinite with regard to 
the alleged minor girls, last names weren't 
vided. 
e...“...-Seawaottamar 
aaa•••••••eassaa..........vawaserwarirsesearsaw. 
16 (Pages 61 to 64) 
PALM BEACH REPORTING SERVICE, INC. 
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Page 65 
i. 
THE WITNESS: I intend to respond to all 
2 
relevant questions regarding this lawsuit. 
3 
However, at the present time my attorneys have 
4 
counseled me that I cannot provide answers to 
5 
any questions relevant to this lawsuit, and I 
6 
must accept this advice or risk losing my Sixth 
7 
Amendment right to effective representation. 
8 
Accordingly, I assert my Federal 
9 
Constitutional rights as guaranteed by the 
10 
Fifth, Sixth, and Fourteenth Amendment to the 
11 
United States Constitution. 
12 
Q. (By Mr. Edwards) With respect to the 49 
13 
named minor girls, isn't it true that you attempted 
14 
to use vibrators on each of them? 
15 
MR. BURMAN: Object to the form of the 
16 
question, vague and indefinite with regard to 
17 
the alleged minor girls, last names weren't 
18 
provided. 
19 
MR. EDWARDS: You can answer. 
20 
THE WITNESS: I intend to respond to all 
21 
relevant questions regarding this lawsuit. 
22 
However, at the present time my attorneys have 
23 
counseled me that I cannot provide answers to 
24 
any questions relevant to this lawsuit, and I 
25 
must accept this advice or risk losing my Sixth 
Page 66 
1 
Amendment right to effective representation. 
2 
Accordingly, I assert my Federal 
3 
Constitutional rights as guaranteed by the 
4 
Fifth, Sixth, and Fourteenth Amendment to the 
5 
United States Constitution. 
7 
Q. (By Mr. Edwards) Be 
001 and 2005 
did you have a woman named 
living 
6 
8 
at your Palm Beach house with you? 
9 
A. I intend to respond to all relevant 
10 
questions regarding this lawsuit. However, at the 
11 
present time my attorneys have counseled me that I 
12 
cannot provide answers to any questions relevant to 
13 
this lawsuit, and I must accept this advice or risk 
14 
losing my Sixth Amendment right to effective 
15 
representation. 
16 
Accordingly, I assert my Federal 
17 
Constitutional right as guaranteed by the Fifth, 
18 
Sixth, and Fourteenth Amendment to the United States 
19 
Constitution. 
your Yugoslavian Ide sbituaa
ex s ve? 
20 
rue that you consi 
21 
22 
A. I intend to respond to all relevant 
23 
questions regarding this lawsuit. However, at the 
24 
present time my attorneys have counseled me that I 
25 
cannot 
vide answers to an 
uestions relevant 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 67 
this lawsuit, and I must accept this advice or risk 
losing my Sixth Amendment right to effective 
representation. 
Accordingly, I assert my Federal 
Constitutional rights as guaranteed by the Fifth, 
Sixth, and Fourteenth Amendment to the United States 
Constitution. 
Q. Can you tell me why it is that you just 
I asked you the last question about 
MR. GOLDBERGER: Don't answer that. 
Q. (By Mr. Edwards) Did you think the 
question was ninny? 
MR. BURMAN: Object to form. 
MR. GOLDBERGER: You can answer. 
THE WITNESS: No. 
B Mr. Edwards) Do you know 
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 relevant to 
this lawsuit, and I must accept this advice or risk 
losing my Sixth Amendment right to effective 
representation. 
Page 68 
1 
Accordingly, I assert my Federal 
2 
Constitutional rights as guaranteed by the Fifth, 
3 
Sixth, and Fourteenth Amendment to the United States 
4 
Constitution. 
5 
Q. Isn't it true that you brought Minn) 
6 
the room to have threesome sex with you and many of 
7 
these minor female girls? 
8 
MR BURMAN: Object to the form of the 
9 
question, vague and indefinite with regard to 
to 
the word "may" and with regard to the fact that 
11 
last names haven't been described, or 
12 
disclosed. 
13 
THE WITNESS: I intend to respond to all 
14 
relevant questions regarding this lawsuit. 
15 
However, at the present time my attorneys have 
16 
counseled me that I cannot provide answers to 
17 
any questions relevant to this lawsuit, and I 
18 
mist accept this advice or risk losing my Sixth 
19 
Amendment right to effective representation. 
20 
Accordingly, i assert Federal 
21 
Constitutional rights as guaranteed by the 
22 
Fifth, Sixth, and Fourteenth Amendment to the 
23 
United States Constitution. 
24 
Q. (By Mr. Edwards) Isn't it true that you 
25 
'aculated in front of each of these minor a ls? 
17 (Pages 65 to 68) 
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Page 69 
1 
MR. BURMAN: Object to form, vague and 
2 
indefinite. Last names were not provided of 
3 
the alleged minor girls. 
4 
THE WITNESS: I intend to respond to all 
5 
relevant questions regarding this lawsuit. 
6 
However, at the present time my attorneys have 
7 
counseled me that I cannot provide answers to 
8 
any questions relevant to this lawsuit, and I 
9 
must accept this advice or risk losing my Sixth 
10 
Amendment right to effective representation. 
13. 
Accordingly, I assert my Federal 
12 
Constitutional rights as guaranteed by the 
13 
Fifth, Sixth, and Fourteenth Amendment to the 
14 
United States Constitution. 
15 
Q. (By Mr. Edwards) With respect to each of 
16 
these 49 minor girls, isn't it true that you paid 
17 
each of them for sex? 
18 
MR. BURMAN: Object to the form, vague and 
19 
indefinite. Last names of the many of the 
20 
minor girls were not provided, alleged minor 
21 
girls. 
22 
THE WITNESS: I intend to respond to all 
23 
relevant questions regarding this lawsuit. 
24 
However, at the present time my attorneys have 
25 
counseled me that I cannotprovide answers to 
Page 70 
1 
any questions relevant to this lawsuit, and I 
2 
must accept this advice or risk losing my Sixth 
3 
Amendment right to effective representation. 
4 
Accordingly, I assert my Federal 
Constitutional rights as guaranteed by the 
6 
Fifth, Sixth, and Fourteenth Amendment to the 
7 
United States Constitution. 
8 
Q. (By Mr. Edwards) Isn't it true that you 
9 
offered each of the 49 minor girls money if she 
10 
would bring you more minor girls for you to engage 
11 
in sex or sex acts with? 
12 
MR. BURMAN: Object to the fan, vague and 
13 
indefinite. Last names of many of the alleged 
14 
minor girls weren't provided. 
15 
THE WITNESS: I intend to respond to all 
3.6 
relevant questions regarding this lawsuit. 
17 
However, at the present time my attorneys have 
18 
counseled me that I cannot provide answers to 
19 
any questions relevant to this lawsuit, and 
20 
must accept their advice or risk losing my 
21 
Sixth Amendment right to effective 
22 
representatiOn. 
23 
Accordingly, I assort my Federal 
24 
Constitutional rights as guaranteed by the 
25 
Fifth,Sixth and Fourteenth Amendment to the 
Page 71 
1 
United States Constitution. 
2 
Q. (By Mr. Edwards) With respect to each of 
3 
the 49 named minor girls, isn't it true that the sex 
4 
or sex acts occurred in your bedroom? 
5 
MR. BURMAN: Object to form of the 
6 
question, vague and indefinite with regard to 
7 
the alleged minor girls, the last names weren't 
8 
provided. 
9 
THE WITNESS: I intend to respond to all 
10 
relevant questions regarding this lawsuit. 
11 
However, at the present time my attorneys have 
12 
counseled me that I cannot provide answers to 
13 
any questions relevant to this lawsuit, and 
14 
must accept this advice or risk losing my Sixth 
15 
Amendment right to effective representation. 
16 
Accordingly, I assert my Federal 
17 
Constitutional right as guaranteed by the 
18 
Fifth, Sixth, and Fourteenth Amendment to the 
19 
United States Constitution. 
20 
Q. (By Mr. Edwards) With respect to each of 
21 
these minor girls, isn't it true that certain other 
22 
employees of yours played a role in authoring your 
23 
sexual contact with these minors? 
24 
MR. BURMAN: Object to the form of the 
25 
question, vague and indefinite with regard to 
Page 72 
1 
the alleged minors, last names weren't 
2 
provided. 
3 
THE WITNESS: Could you repeat the 
4 
question? Sorry. 
5 
Q. (By Mr. Edwards) Sure. 
6 
With respect to the 49 minor girls whose 
7 
names i provided, isn't it true that certain 
8 
employees of yours played a role in furthering 
9 
sexual contact between you and these minors? 
10 
MR. BURMAN: Same objection. 
11 
THE WITNESS: I intend to respond to all 
12 
relevant questions regarding this lawsuit. 
13 
However, at the present time my attorneys have 
14 
counseled me that I cannot provide answers to 
15 
any questions relevant to this lawsuit, and I 
16 
must accept this advice or risk losing my Sixth 
17 
Amendment right to effective representation. 
18 
Accordingly, I assert my Federal 
19 
Constitutional rights as guaranteed by the 
20 
Fifth, Sixth, and Fourteenth Amendment to the 
21 
United States Constitution. 
22 
Q. (By Mr. Edwards) Some of your employees 
23 
were delegated the responsibility of cleaning your 
24 
sex toys after you engaged in sex with minor girls, 
25 
isn't that true? 
18 (Paces 69 to 72) 
PALM BEACH REPORTING SERVICE, INC. 
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Page 73 
3. 
MR BURMAN: Are you referring to the 49 
2 
alleged minors that you just identified, or is 
3 
this a generic question? 
4 
MR. EDWARDS: Yes, the 49, that --
5 
THE WITNESS: Can you repeat the question 
6 
please? 
7 
MR. EDWARDS: — are known to us. 
8 
MR. BURMAN: Okay. Object to the form, 
9 
vague and indefinite with regard to the alleged 
10 
minors, last names weren't provided. 
13. 
THE WITNESS: I intend to imp und to all 
12 
relevant questions regarding this lawsuit 
13 
However, at the present time my attorneys have 
14 
counseled me that I cannot provide answers to 
15 
any questions relevant to this lawsuit, and I 
16 
must accept this advice or risk losing my Sixth 
17 
Amendment right to effective representation. 
18 
Accordingly, I assert my Federal 
19 
Constitutional right as guaranteed by the 
20 
Fifth, Sixth, and Fourteenth Amendment to the 
21 
United States Constitution. 
22 
Q. (By Mr. Edwards) Isn't it true that you 
23 
hired employees to work for you for the sole purpose 
24 
of scheduling minor girls to come to your house for 
25 
sex? 
Page 74 
1 
MR. BURMAN: Once again, are you referring 
2 
to the 49 you identified, or just generic? 
3 
MR. EDWARDS: General question. 
4 
MR. BURMAN: General question? 
5 
MR. EDWARDS: Right. 
6 
THE WITNESS: I intend to respond to all 
7 
relevant questions regarding this lawsuit. 
8 
However, at the present time my attorneys have 
9 
counseled me that I cannot provide answers to 
10 
any questions relevant to this lawsuit, and I 
11 
must accept this advice or risk losing my Sixth 
12 
Amendment right to effective representation. 
13 
Accordingly, I assert my Federal 
14 
Constitutional rights as guaranteed by the 
15 
Fifth, Sixth, and Fourteenth Amendment to the 
16 
United States Constitution. 
17 
Q. (By Mr. Edwards) Isn't it true that you 
18 
hired employees that were delegated responsibilities 
19 
in order to assist you in avoiding detection of your 
20 
actions by law enforcement? 
21 
THE WITNESS: What's the question? 
22 
MR.. BURMAN: Object to the form, vague and 
23 
indefinite. 
24 
THE WITNESS: Could you repeat it again? 
25 
MR. EDWARDS: Sure, ni clean it, 
Page 75 
1 
Q. (By Mr. Edwards) Isn't it true that you 
2 
had employees working for you with a purpose of 
3 
helping you to avoid detection of your criminal 
4 
activities by law enforcement? 
5 
MR. BURMAN: Object to form, vague an 
6 
indefinite. 
7 
THE WITNESS: I intend to respond to all 
8 
relevant questions regarding this lawsuit. 
9 
However, at the present time my attorneys have 
10 
counseled me that I cannot provide answers to 
11 
any questions relevant to this lawsuit, and I 
12 
must accept this advice or risk losing my Sixth 
13 
Amendment right to effective representation. 
14 
Accordingly, I assert my Federal 
15 
Constitutional rights as guaranteed by the 
16 
Filth, Sixth, and Fourteenth Amendment to the 
17 
united States Constitution. 
18 
Q. (By Mr. Edwards) Did you have operable 
3.9 
surveillance equipment inside your house from 2001 
20 
through 2006 in your Palm Beach house? 
21 
MR. BURMAN: Objection, vague and 
22 
indefinite. 
23 
THE WITNESS: I intend to respond to all 
24 
relevant questions regarding this lawsuit. 
25 
However, at this present time my attorney has 
Page 76 
1 
counseled me that I cannot provide answers to 
2 
any questions relevant to this lawsuit, and I 
3 
must accept this advice or risk losing my Sixth 
4 
Amendment tight to effective representation. 
5 
Accordingly, I assert my Federal 
6 
Constitutional rights as guaranteed by the 
7 
Fifth, Sixth, and Fourteenth Amendment to the 
8 
United States Constitution. 
9 
Q. (By Mr. Edwards) Did you destroy or 
10 
tamper with evidence, including computer images, 
11 
computer equipment, surveillance equipment, photos, 
12 
notes, diaries, or photocopy records as a result of 
13 
the criminal investigation of you between 2001 and 
14 
2006? 
15 
MR. GOLDBERGER: Let me object on the 
16 
form. Are you asking, are you suggesting that 
3.7 
there is a criminal investigation that went on 
18 
between 2001 and 2006? Is that the question? 
19 
MR. EDWARDS: Well, at some time, at some 
20 
point in time there was, since he pled guilty. 
21 
MR GOLDBERGER: But what's the purpose of 
22 
the 2001 to 2006? Maybe you can rephrase the 
23 
question. 
24 
MR. EDWARDS: Okay. 
25 
(B Mr. Edwards) How about this. Have 
19 
Pa es 73 to 76 
PALM BEACH REPORTING SERVICE, INC. 
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Page 77 
1 
you ever at any time destroyed or tampered with any 
2 
evidence of your involvement with minor girls? 
3 
A. I intend to respond to an relevant 
4 
questions regarding this lawsuit. However, at the 
5 
present time my attorneys have counseled me that 
6 
cannot answer questions with respect to this 
7 
lawsuit, and must accept their advice or risk losing 
8 
my Sixth Amendment right to effective 
9 
representation. 
10 
Accordingly, I assert my Federal 
11 
Constitutional Rights as guaranteed by the Fifth, 
12 
Sixth, and Fourteenth Amendments to the United 
13 
States Constitution. 
14 
Q. Have you ever destroyed computer images or 
15 
computer equipment because of a fear it would be 
16 
used against you in a prosecution for your sexual 
17 
involvement with minor girls? 
18 
A. I intend to respond to all relevant 
19 
questions regarding this lawsuit However, at the 
20 
present time my attorneys have counseled me that 1 
21 
cannot provide answers to any questions relevant to 
22 
this lawsuit, and I must accept this advice or risk 
23 
losing my Sixth Amendment right to effective 
24 
representation. 
25 
Accordingly, i assert my Federal 
Page 78 
3. 
Constitutional rights as guaranteed by the Fifth, 
2 
Sixth, and Fourteenth Amendment to the United States 
3 
Constitution. 
4 
Q. Did you ever, at any time, destroy 
5 
photographs, notes, or diaries in an effort to avoid 
6 
detection by law enforcement? 
7 
A. I intend to respond to all relevant 
8 
questions regarding this lawsuit. However, at the 
9 
present time my attorneys have counseled me that 
1 o 
cannot provide answers to any questions relevant to 
11 
this lawsuit, and I must accept this advice or risk 
12 
losing my Sixth Amendment right to effective 
13 
representation. 
14 
Accordingly, I assert my Federal 
15 
Constitutional rights as guaranteed by the Fifth, 
16 
Sixth, and Fourteenth Amendment to the United States 
17 
Constitution. 
18 
Q. Did other people hired by you destroy or 
19 
tamper with evidence in an effort to avoid detection 
20 
of criminal activities or prosecution? 
21 
A. I intend to respond to all relevant 
22 
questions regarding this lawsuit. However, at the 
23 
present time my attorneys have counseled me that I 
24 
cannot provide answers to any questions relevant to 
25 
this lawsuit and I must accept this advice or risk 
Page 79 
1 
losing my Sixth Amendment right to effective 
2 
representation. 
3 
Accordingly, lessen my Federal 
4 
Constitutional rights as guaranteed by the Fifth, 
5 
Sixth, and Fourteenth Amendment to the United States 
6 
Constitution. 
7 
Q. Was your house at some point in time in 
8 
Palm Beach burglarized by a former housekeeper named 
9 
Juan Allessee (phonetic)? 
10 
A. Yes. 
11 
Q. In relation to that burglary, did you 
12 
provide the Palm Beach Police Department with 
13 
surveillance video from the inside of your house? 
14 
A. I intend to respond to all relevant 
15 
questions regarding this lawsuit However, at the 
16 
present tint my attorneys have counseled me that I 
17 
cannot provide answers to any questions relevant to 
18 
this lawsuit, and I must accept this advice or risk 
19 
losing my Sixth Amendment right to effective 
20 
representation. 
21 
Accordingly, I assert my Federal 
22 
Constitutional rights as guaranteed by the Fifth, 
23 
Sixth, and Fourteenth Amendment to the United States 
24 
Constitution. 
25 
Q. At the time your house was burglarized, ' 
Page 80 
1 
how many operable surveillance cameras were inside 
2 
your house? 
3 
A. I intend to respond to all relevant 
4 
questions regarding this lawsuit. However, at the 
5 
present time my attorneys have counseled me that I 
6 
cannot provide answers to any questions relevant to 
7 
this lawsuit, and I must accept this advice or risk 
8 
losing my Sixth Amendment right to effective 
9 
representation 
22
 assert 
deral 
25 
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23 
something you'd quarrel with? 
24 
A. No. 
10 
11 
Constitutional rights as guaranteed by the Fifth, 
12 
Sixth, and Fourteenth Amendment to the United States 
13 
Constitution. 
14 
Q. How long have you been on work release? 
3.5 
MR. GOLDBERGER: Hang on. Yeah, he can --
16 
that's fine. 
17 
THE WITNESS: A little over six months. 
18 
Q. (By Mr. Edwards) You know the date that 
19 
you started work release? 
20 
A. No. 
21 
20 (Pages 77 to 80) 
PALM BEACH REPORTING SERVICE, INC. 
EFTA01103345