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1 
in the county jail after that June 30th, 2008 plea 
2 
before you were granted work release? 
3 
MR. GOLDBERGER: If you know. 
4 
THE WITNESS: Couple of months. 
5 
Q. (By Mr. Edwards) Do you know if any of 
6 
your victims were informed of your petition for work 
7 
release? 
8 
A. I do not know. 
9 
Q. When NM the Florida Science Foundation 
10 
created? 
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 this advice or risk 
16 
losing my Sixth Amendment right to effective 
17 
representation. 
18 
Accordingly, I assert my Federal 
19 
Constitutional rights as guaranteed by the Fifth, 
20 
Sixth, and Fourteenth Amendment to the United States 
21 
Constitution. 
22 
Q. Isn't it true that you created the Florida 
23 
Science Foundation months before pleaing guilty 
24 
knowing that you would eventually be on work release 
25 
in an office right next to your attorney's office? 
Page 82 
1 
MR. BURMAN: Object to the form. 
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 rights as guaranteed by the 
11 
Filth, Sixth, and Fourteenth Amendment to the 
12 
constitution. 
13 
Q. (By Mr. Edwards) Since being sentenced in 
14 
June of 2008, have you had contact with any minors? 
15 
MR.. GOLDBERGER: You can answer that. 
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, and 
21 
must 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 
%Ow 
Page 83 
1 
constitution. 
2 
Q. (By Mr. Edwards) Do you currently have 
3 
access to a computer that you use? 
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 
8 
this lawsuit 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 rights as guaranteed by the Fifth, 
13 
Sixth, and Fourteenth Amendment to the constitution. 
14 
Q. What is e-mail address that you have been 
15 
using since being sentenced in 2008? 
16 
MR. GOLDBERGER: Object to the form, 
17 
assumes facts not in evidence. 
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 
Page 84 
1 
Constitutional rights as guaranteed by the 
2 
Fifth, Sixth, and Fourteenth Amendment to the 
3 
United States Constitution. 
4 
Q. (By Mr. Edwards) Do you intend to 
5 
communicate with any minors once you are released to 
6 
house arrest? 
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 I 
10 
cannot provided 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 
ivin 
dation. 
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. Is it true that you have been diagnosed by 
19 
a psychologist with a sexual disorder related to 
20 
your sexual appetite for minor girls? 
23. 
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 most acceptthis advice or risk 
21 (Pages 81 to 84) 
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losing my Sixth Amendment right to effective 
2 
representation. 
3 
Accordingly, I assert my Federal 
4 
Constitutional rights as guaranteed by the Fifth, 
5 
Sixth, and Fourteenth Amendment to the constitution. 
6 
Q. Isn't it true that you intend to continue 
7 
engaging in sex acts with minor girls once you are 
8 
released? 
9 
MR. BURMAN: Object to the form. 
10 
THE WITNESS: I intend to respond to all 
11 
relevant questions regarding this lawsuit. 
12 
However, at the present time my attomeys have 
13 
counseled me that I cannot provide answers to 
14 
any questions relevant to this lawsuit, and I 
15 
must accept this advice or risk losing my Sixth 
16 
Amendment right to effective representation. 
17 
Accordingly, I assert my Federal 
18 
Constitutional rights as guaranteed by the 
19 
Fifth, Sixth, and Fourteenth Amendment to the 
20 
United States Constitution. 
21 
Q. (By Mr. Edwards) Have you engaged in sex 
22 
or sex acts with minor girls outside of the United 
23 
States? 
24 
A. I intend to respond to all relevant 
25 
questions regarding this lawsuit. However, at the 
Page 86 
1 
present time my attorneys have counseled me that I 
2 
cannot provide answers to any questions relevant to 
3 
this lawsuit, and must accept this advice or risk 
4 
losing my Sixth Amendment right to effective 
5 
representation. 
6 
Accordingly, I assert my Federal 
7 
Constitutional rights as guaranteed by the Fifth, 
8 
Sixth, and Fourteenth Amendment to the United States 
9 
Constitution. 
10 
Q. Is it true that you have your own island? 
11 
MR. BURMAN: Object, also on the, on the 
12 
grounds that the punitive damages haven't been 
13 
allowed yet. Not relevant. 
14 
MR. EDWARDS: 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 rights under the Fifth, Sixth, 
24 
and Fourteenth Amendment to the United States 
25 
Constitution. 
Page 87 
1 
Q. (By Mr. Edwards) Have you engaged in sex 
2 
or sex acts with minors on the island of Little 
3 
St. Jeffs? 
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 relative to 
8 
this lawsuit, and must accept this advice or risk 
9 
losing my Sixth Amendment right to effective 
10 
representation. 
11 
Accordingly, I assert my Federal 
12 
Constitutional rights as guaranteed by the Fifth, 
13 
Sixth, and Fourteenth Amendment to the United States 
14 
Constitution. 
15 
Q. Isn't it true that you have engaged in 
16 
sexual acts or sex with girls as young as 12 years 
17 
old? 
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 
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 88 
1 
Constitutional tights as guaranteed by the Fifth, 
2 
Sixth, and Fourteenth Amendment to the United States 
3 
Constitution. 
4 
Q. What is the youngest girl that you have 
5 
engaged in sex or sex acts with in the last ten 
6 
years? 
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 I 
10 
cannot provide answers to any questions relevant to 
11 
this lawsuit, and must accept this advice or risk 
12 
losing my Sixth Amendment right to effective 
13 
representation. 
14 
Accordingly, I assert under the Federal 
15 
Constitutional rights as guaranteed by the Fifth, 
16 
Sixth and Fourteenth Amendment to the United States 
17 
Constitution. 
18 
Q. Have you discussed with any of your 
19 
friends the fact that you engage in sex or sex acts 
20 
with minors? 
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 
this advice or risk 
AISIoadal• 
22 (Pages 85 to 88 
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losing my Sixth Amendment right to effective 
2 
representation. 
3 
Accordingly, I assert my Federal 
4 
Constitutional rights as guaranteed by the Fifth, 
5 
Sixth, and Fourteenth Amendment to the United States 
6 
Constitution. 
7 
Q. Did you know that the girls that were 
8 
providing you massages were under the age of 18 at 
9 
the time they were doing so? 
10 
A. I intend to respond to all relevant 
11 
questions regarding this lawsuit. However, at the 
12 
present time my attorneys have counseled me that I 
13 
cannot provide answers to any questions relevant to 
14 
this lawsuit, and I must accept their advice or risk 
15 
losing my Sixth Amendment right to effective 
16 
representation. 
17 
Accordingly, I assert my Federal 
18 
Constitutional rights as guaranteed by the Fifth, 
19 
Sixth, and Fourteenth Amendment to the United States 
20 
Constitution. 
21 
Q. Isn't it true that the age group that you 
22 
enjoy to engage in sex with is between 12 and 16 
23 
yearsold? 
24 
MR. BURMAN: Object to form. 
25 
THE WITNESS: I intend to respond to all 
Page 91 
1 
Amendment right to effective representation. 
2 
Accordingly, I assert my Federal 
3 
Constitutional rights as guaranteed by the 
4 
Filth, Sixth, and Fourteenth Amendment to the 
5 
United States Constitution. 
6 
Q. (By Mr. Edwards) Isn't it true that you 
7 
devised a scheme or plan to engage in sex or sex 
8 
acts with multiple 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 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 must assert my Federal 
17 
Constitutional rights as guaranteed by the Fifth, 
18 
Sixth, and Fourteenth Amendment to the United States 
19 
Constitution. 
20 
THE WITNESS: Can I take a pee break? 
21 
THE VIDEOGRAPHER: We're off the record at 
22 
11:50. This will be the end of tape one. 
23 
(Thereupon, a brief break was taken.) 
24 
THE VIDEOGRAPHER: This is the beginning 
25 
of tape number two, and we're back on the 
Page 90 
3. 
relevant questions regarding this lawsuit. 
2 
However, at the present time my attorneys have 
3 
counseled me that I cannot provide answers to 
4 
any questions relevant to this lawsuit, and I 
5 
must accept this advice or risk losing my Sixth 
6 
Amendment right to effective representation. 
7 
Accordingly, I assert my Federal 
8 
Constitutional rights as guaranteed by the 
9 
Fifth, Sixth, and Fourteenth Amendment to the 
10 
constitution. 
11. 
Q. (By Mr. Edwards) Do you agree with the 
12 
laws that prohibit you from having sex or engaging 
13 
in sex acts with minors? 
14 
MR. BURMAN: Object to form. 
15 
THE WITNESS: Can you repeat the question? 
16 
Q. (By Mr. Edwards) Do you agree with the 
17 
laws that prohibit you from engaging in sex or sex 
18 
acts with minor girls? 
19 
MR. BURMAN: Object to the form. 
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 losittgmiSixth 
Page 92 
3. 
record at 11:59. 
2 
Q. (By Mr. Edwards) Between 2001 and 2005 
3 
did you digitally penetrate the vaginas of more than 
4 
50 minor girls? 
5 
A. I intend to respond to all relevant 
6 
questions regarding this lawsuit. However, at the 
7 
present time my attorneys have counseled me that I 
8 
cannot provide answers to any questions relevant to 
9 
this lawsuit, and I must accept their advice or risk 
10 
losing my Sixth Amendment right to effective 
11 
representation. 
12 
Accordingly, I assert my Federal 
13 
Constitutional right as guaranteed by the Fifth, 
14 
Sixth and Fourteenth Amendment to the constitution. 
15 
Q. Between 2001 and 2005 did you masturbate 
16 
in front of more than 50 minor girls? 
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 any questions relevant to 
21 
this lawsuit, and I must accept this advice or risk 
22 
losing my Sixth Amendment right to effective 
23 
representation. 
24 
Accordingly, I assert my Federal 
2 5 
Constitutional riAtits as guaranteed by the Fifth. 
23 (Pages 89 to 92) 
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1 
Sixth and Fourteenth Amendment to the constitution. 
2 
Q. Between 2001 and 2005 did you ejaculate in 
3 
front of more than 50 minor girls? 
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 
8 
this 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 rights as guaranteed by the Fifth, 
13 
Sixth, and Fourteenth Amendment to the United States 
14 
Constitution. 
15 
Q. Does the body form of a 12 to 16 year old 
16 
girl sexually appeal to you? 
17 
MR. BURMAN: Object to the form. 
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, andl 
23 
must accept this advice or risk losing my Sixth 
24 
Amendment right to effective representation. 
25 
Accordingly, I assert my Federal 
Page 95 
1 
present time my attorneys have counseled ire that I 
2 
cannot provide answers to any questions relevant to 
3 
this lawsuit, and must accept this advice or risk 
4 
losing my Sixth Amendment right to effective 
5 
representation. 
6 
Accordingly, I assert my Federal 
7 
Constitutional rights as guaranteed by the Fifth, 
8 
Sixth, and Fourteenth Amendment to the United States 
9 
Constitution. 
10 
Q. During the criminal investigation there 
11 
were statements to the media that you believed the 
12 
girls to be 18. Which girls were you referring to? 
13 
A. I intend to 
14 
THE WITNESS: Excuse me one second. 
15 
(Thereupon, a discussion was had off 
16 
the record.) 
17 
MR. GOLDBERGER: Urrnt let me object to the 
18 
form as to vague. I don't know what statements 
19 
you're talking about. Are you talking about 
20 
statements that Mr. Epstein made? 
21 
MR. EDWARDS: Through attorneys. 
22 
MR. GOLDBE1tGER: Well, is that the 
23 
question? Why don't you rephrase the question, 
24 
why don't you rephrase the question so we 
25 
understand what it is. 
Page 94 
1 
Constitutional right as guaranteed by the 
2 
Fifth, Sixth, and Fourteenth Amendment to the 
3 
constitution. 
4 
Q. (By Mr. Edwards) Did you use your wealth, 
5 
power, and connections to impress or influence minor 
6 
girls into having sex with you? 
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 I 
10 
cannot provide answers to any questions relevant to 
11 
this lawsuit, and I must accept their 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 you intentionally target economically 
19 
deprived children for the purposes of having sex or 
20 
engaging in sex acts with? 
21 
A. Do you want to rephrase the question? 
22 
Q. Did you intentionally target economically 
23 
deprived children for the purposes of sex? 
24 
A. I intend to respond to all relevant 
25 
questions regarding this lawsuit. However, at the 
Page 96 
1 
Q. (By Mr. Edwards) Various attorneys of 
2 
yours made representations to the media that you 
3 
were of, under the belief that the girls that you 
4 
were engaging in sex acts with were 18 years of age. 
5 
Which girls were you, was that referring to? 
6 
MR. GOLDBERGER: Can you identify a 
7 
specific statement made by a specific attorney? 
8 
MR.. EDWARDS: We'll get there later on in 
9 
the deposition. 
10 
Q. (By Mr. Edwards) Have you ever, at any 
11 
time, made that statement, that you believed the 
12 
girls that you were engaging in sex acts with were 
13 
18 years of age or older? 
14 
MR. GOLDBERGER: To the media, are you 
15 
talking about? 
16 
Q. (By Mr. Edwards) Yourself or through 
17 
anyone else to anyone else. 
18 
MR. GOLDBERGER: Object to the —
19 
that's — 
20 
MR. BURMAN: Object to the form. 
21 
MR. GOLDBERGER: I have no idea what the 
22 
question is. Just ask the question, 
23 
happy to try and have the client answer it for 
24 
you. 
25 
9. SBA Mr. Edwards) Okay. rin not talking 
24 (Pages 93 to 96) 
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1 
about statements to your attorneys, that's 
2 
privileged. 
3 
Have you ever made the statement to anyone 
4 
else, other than your attorneys, that you believed 
5 
the girls that were giving you massages at your 
6 
house were ova the age of 18? 
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 I 
10 
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 Between 2001 and 2005 did you pay any 
19 
females for sex? 
20 
A. I intend to respond to all relevant 
21 
questions regarding this lawsuit. However, at the 
22 
present time my attorneys have counseled me that I 
23 
cannot provide answers to any questions relevant to 
24 
this lawsuit, and I must accept this advice or risk 
25 
losing my Sixth Amendment ri t to effective 
Page 99 
1 
that the alleged minor girls' last names 
2 
weren't provided. 
3 
THE WITNESS: I intend to respond to all 
4 
relevant questions regarding this lawsuit. 
5 
However, to the present time, at the present 
6 
time my attorneys have counseled me thatl 
7 
cannot provide answers to any questions 
B 
relevant to this lawsuit, and I must accept 
9 
this advice or risk losing my Sixth Amendment 
10 
right to effective representation. 
11 
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) How did the minor girls 
16 
previously named in this deposition arrive to your 
17 
mansion between 2001 and 2005? 
18 
MR. BURMAN: Objection, vague and 
19 
indefinite. 
20 
MR. GOLDBERGER: And it's, it's vague and 
21 
indefinite, but to assist in answering the 
22 
question, can you tell us what mansion you're 
23 
talking about? 
24 
MR. EDWARDS: Palm Beach mansion. 
25 
THE WITNESS: Can 
the 
estion? 
Page 98 
1 
representation. 
2 
Accordingly, I assert Federal 
3 
Constitutional rights under the Fifth, Sixth, and 
4 
Fourteenth Amendment to the United States 
5 
Constitution. 
6 
Q. Between 2001 and 2005 did you tell minor 
7 
female girls at your house that you prefer to engage 
8 
in sexual activities with minors? 
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, 1 assert my Federal 
17 
Constitutional rights as guaranteed by the Fifth, 
18 
Sixth, and Fourteenth Amendment to the United States 
19 
Constitution. 
20 
Q. Is it true that many of the 49 minor girls 
21 
previously named told you that they were under the 
22 
age of 15 at the time you were engaging in sex acts 
23 
with than? 
24 
ha. BURMAN: Object to fonn of the 
25 
• estion va 
and indefinite to the extent 
Page 100 
1 
Q. (By Mr. Edwards) How did they arrive at 
2 
your house? 
3 
A. "They" arrive? 
4 
Q. How did any of the minor girls whose names 
5 
I named previously in this deposition arrive to your 
6 
house? 
7 
MR. BURMAN: Object to the form of the 
8 
question, vague and indefinite to the extent 
9 
that the alleged minor girls' last names 
10 
weren't provided. 
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, that I 
16 
must accept this advice or risk losing my Sixth 
17 
Amendment tight 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 
constitution. 
22 
Q. (By Mr. Edwards) Many of the minor girls 
23 
named previously in this deposition did not drive a 
24 
car to your house or have a driver's license, isn't 
25 
that true? 
25 (Pages 97 to 100) 
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1 
MR. BURMAN: Object to form of the 
2 
question, vague and indefinite to the extent 
3 
that the alleged minor girls' last names 
4 
weren't provided. 
5 
THE WITNESS: You have to repeat the 
6 
question, again. Sony. 
7 
Q. (By Mr. Edwards) Isn't it true that many 
8 
of the minor girls previously named in this 
9 
deposition did not drive a car or have driver's 
10 
licenses? 
11 
MR. BURMAN: Same objection. 
12 
THE WITNESS: I intend to respond to all 
13 
relevant questions regarding this lawsuit. 
14 
However, at the present time my attorneys have 
15 
counseled me that I cannot provide answers to 
16 
any questions relevant to this lawsuit, and I 
17 
must accept this advice or risk losing my Sixth 
18 
Amendment right to effective representation. 
19 
Accordingly, I assert my Federal 
20 
Constitutional rights as guaranteed by the 
21 
Fifth, Sixth, and Fourteenth Amendment to the 
22 
United States Constitution. 
23 
Q. (By Mr. Edwards) Is it true that you 
24 
discussed with many of these girls the fact that 
25 
they were in middle school or high school at the 
Page 102 
1 
time they were engaging in sex acts with you at your 
2 
house? 
3 
MR BURMAN: Are you referring to the 
4 
previous 49? 
5 
MR. EDWARDS: Yes. 
6 
MR. BURMAN: Okay. Object to form of the 
7 
question, vague and indefinite to the extent 
8 
that the names, the last names of many of the 
9 
alleged minor girls weren't provided. 
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 
counseled me that 1 cannot provide answers to 
14 
any questions relevant to this lawsuit, and I 
15 
must accept this advice or risk losing my Sixth 
16 
Amendment right to effective rt.piesuitation. 
17 
Accordingly, I assert my Federal 
18 
Constitutional rights as guaranteed by the 
19 
Fifth, Sixth, and Fourteenth Amendment to the 
20 
United States Constitution. 
21 
Q. (By Mr. Edwards) Did any of the girls 
22 
that engaged in sex acts with you at your house 
23 
between 2001 and 2005 tell you that they were in 
24 
middle school or high school? 
25 
A. Soma repeat the question. 
Page 103 
1 
MR. BURMAN: Are you talking about the 497 
2 
MR. EDWARDS: No. 
3 
MR. BURMAN: No. 
4 
Q. (By Mr. Edwards) Did any minor girls that 
5 
engaged in sex or sex acts with you between the 
6 
years of 2001 and 2005 at your house tell you that 
7 
they vim in middle school or high school at the 
8 
time? 
9 
MR. BURMAN: Object to the form. 
10 
THE WITNESS: I intend to respond to all 
11 
relevant questions regarding this lawsuit. 
12 
However, at the present time my attomeys have 
13 
counseled me that I cannot provide answers to 
14 
any questions relevant to this lawsuit, and I 
15 
must accept this advice or risk losing my Sixth 
16 
Amendment right to effective representation. 
17 
Accordingly, lessen my Federal 
18 
Constitutional rights as guaranteed by the 
19 
Fifth, Sixth, and Fourteenth Anmaloient to the 
20 
constitution. 
21 
MR. EDWARDS: Okay. What time do you want 
22 
to break for lunch? 
23 
MR. GOLDBERGER 1:00. 
24 
THE WITNESS: 1:15? 
25 
MR GOLDBERGER: Yeah, 1:15. Is that 
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 104 
okay? 
MR. EDWARDS: Yeah, that's fine with me. 
What time do we have now? 
THE WITNESS: It will be another hour. 
(Thereupon, a discussion was had off 
the record.) 
Q. (By Mr. Edwards) Did you ever discuss 
with any minor girls at your house that you would 
pay them to bring you other minor girls for the 
purposes of sex? 
MR BURMAN: Object to the form. 
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) Did you tell any of the 
minor girls that were at your house for sex that you 
ftrefen'?!:lp,a. 
Is for sex? 
26 (Pages 101 to 104) 
PALM BEACH REPORTING SERVICE, INC. 
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Page 105 
1 
MR. BURMAN: Object to the form. 
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 I 
7 
must accept this advice or risk losing my Sixth 
8 
Amendment right to effective representation. 
9 
Accordingly, I assert my Federal 
10 
Constitutional rights as guaranteed by the 
11 
Fifth, Sixth, and Fourteenth Amendment to the 
12 
constitution. 
13 
Q. (By Mr. Edwards) Did you tell any of the 
14 
minor girls at your house between 2001 and 2005 that 
15 
you do not like girls that have tattoos? 
16 
MR. BURMAN: Object to the form. 
17 
THE WITNESS: I intend to respond to all 
18 
relevant questions regarding this lawsuit. 
19 
However, at the present time my attorneys have 
2o 
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 by the 
Page 106 
1 
Fifth, Sixth, and Fourteenth  
nc.nt of the 
2 
constitution. 
3 
Q. (By Mr. Edwards) Did you tell any of the 
4 
minor girls that were at your house not to bring you 
5 
any girls that were pregnant or had babies? 
6 
MR. BURMAN: Object to the form. 
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 right as guaranteed by the 
16 
Fifth, Sixth, and Fourteenth Amendment to the 
17 
constitution? 
18 
Q. (By Mr. Edwards) Did you specifically 
19 
instruct any of the minor girls not to bring you any 
20 
black girls? 
21 
MR. BURMAN: Object to the form. 
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 Erovide answers to 
Page 107 
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 
5 
Constitutional rights as guaranteed by the 
6 
Fifth, Sixth and Fourteenth Amendment of the 
7 
constitution. 
8 
Q. (By Mr. Edwards) Isn't it true that you 
9 
did not like to have sex or engage in sex acts with 
10 
black girls? 
11 
MR. BURMAN: Object to the form. 
12 
THE WITNESS: I intend to respond to all 
13 
relevant questions regarding this lawsuit. 
14 
However, at the present time my attorneys have 
15 
counseled me that I cannot provide answers to 
16 
any questions relevant to this lawsuit, and I 
17 
must accept this advice or risk losing my Sixth 
18 
Amendment right to effective representation. 
19 
Accordingly, I assert my Federal 
20 
Constitutional rights as guaranteed by the 
21 
Fifth, Sixth, and Fourteenth Amendment 
22 
Q. (By Mr. Edwards) Isn't it true that black 
23 
girls were brought to your house and you turned them 
24 
away at the door because you do not like black 
25 
girls? 
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 108 
MR. BURMAN: Object to the form. 
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 tight to effective representation. 
Accordingly, I assert my Federal 
Constitutional rights as guaranteed by the 
Fifth, Sixth and Fourteenth Amendment to the 
constitution. 
Q. (By Mr. Edwards) Isn't it true that you 
also turned away girls because they were 18 years or 
older and too old for you? 
MR. BURMAN: Object to the form. 
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 the advice or risk losing my Sixth 
Amendment right to effective representation. 
Accordingly, I assert Federal 
Constitutional ridits as guaranteedb the 
5 
27 (Pages 105 to 108) 
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Page 109 
1 
Fifth, Sixth and Fourteenth Amendment to the 
2 
United States Constitution. 
3 
Q. (By Mr. Edwards) Isn't it true that you 
4 
also turned away minor girls with tattoos because 
5 
you did not feel that they were pure? 
6 
MR. BURMAN: Object to the form. 
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 right as guaranteed by the 
16 
Fifth, Sixth, and Fourteenth Amendment to the 
17 
United States Constitution. 
18 
Q. (By Mr. Edwards) Is it true that your 
19 
specific instructions were, to these minor girls, to 
20 
bring you white girls between the ages of 12 and 17 
21 
that were not pregnant, did not have babies, and did 
22 
not have tattoos? 
23 
MR. BURMAN: Object to the form. 
24 
THE WITNESS: I intend to respond to all 
25 
relevant questions regarding this lawsuit. 
Page 111 
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 
5 
Constitutional rights as guaranteed by the 
6 
Fifth, Sixth, and Fourteenth Amendment to the 
7 
United States Constitution. 
8 
Q. (By Mr. Edwards) Why did you laugh about 
9 
that last question? 
10 
MR. BURMAN: Object to the form. 
11 
THE WITNESS: I have a stomachache at the 
12 
moment. I wasn't laughing. 
13 
Q. (By Mr. Edwards) Isn't it true that you 
14 
targeted young, economically deprived kids with 
15 
little or no parental guidance? 
16 
MR. BURMAN: Object to the form. 
17 
THE WITNESS: You have to repeat the 
18 
question. 
19 
Q. (By Mr. Edwards) Isn't it true that you 
20 
were targeting young, economically deprived minor 
21 
girls with little or no parental guidance? 
22 
MR. BURMAN: Object to the form. 
23 
Q. (By Mr. Edwards) For sex. 
24 
A. I intend to respond to all relevant 
25 
questions regarding this lawsuit. However, at the 
Page 110 
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 representation. 
6 
Accordingly, I assert my Federal 
7 
Constitutional right as guaranteed by the 
8 
Fifth, Sixth, and Fourteenth Amendment to the 
9 
constitution. 
10 
Q. (By Mr. Edwards) Is it true that you 
11 
offered each minor girl approximately $200 in cash 
12 
for sex? 
13 
MR. BURMAN: Object to the form. Are you 
14 
back on the 49, or is this generic? 
15 
MR. EDWARDS: No, generic. 
16 
THE WITNESS: Would you repeat the 
17 
question? 
18 
Q. (By Mr. Edwards) Between 2001 and 2005 
19 
isn't it true that you offered each minor girl that 
20 
came to your house for sex $200 for that sex? 
23. 
MR. BURMAN: Object to the form. 
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 urovide answers to 
Page 112
1 
present time my attorneys have counseled me that I 
2 
cannot provide answers to any questions relevant to 
3 
this lawsuit, and I 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 as guaranteed by the Fifth, 
8 
Sixth, and Fourteenth Amendment to the United States 
9 
Constitution. 
10 
Q. Have you ever told anybody that the girls 
11 
were over at your house because you just like 
12 
massages? 
13 
MR. BURMAN: Object to the form. 
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 
. 
 
it
Edwards 
true that none 
28 (Pages 109 to 112) 
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Page 113 
1 
of these minor girls that you engaged in sex acts 
2 
with at your house had any massage experience? 
3 
MR. BURMAN: Object to the form. 
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 
9 
must accept this advice or risk losing my Sixth 
10 
Amendment right to effective representation. 
11 
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) Between 2001 and 2005 
16 
did you ever have a professional masseuse give you a 
17 
massage at your house in Palm Beach? 
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 114 
1 
Constitutional rights as guaranteed by the Fifth, 
2 
Sixth, and Fourteenth Amendment of the United States 
3 
Constitution. 
4 
Q. In fact, when these minor girls would tell 
5 
you they had no massage experience, didn't you 
6 
respond by telling them that that is actually better 
7 
for you? 
8 
MR. BURMAN: Object to the form. 
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 I 
14 
must accept the 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) Did you tell these minor 
21 
girls to get naked and touch you so that you could 
22 
get off? 
23 
MR. BURMAN: Object to the form. 
24 
THE WITNESS: What? What's — repeat the 
25 
.
Lestion. 
Page 115 
1 
Q. (By Mr. Edwards) Did you tell these minor 
2 
girls between 2001 and 2005 at your Palm Beach 
3 
mansion to get naked and touch you so that you could 
4 
get off? 
5 
A. Get off? 
6 
MR. GOLDBERGER: Are you asking him if 
7 
that's a statement that was made? 
8 
MR. EDWARDS: Yes, to these girls. 
9 
MR. BURMAN: Object to the font 
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 
counseled me that I cannot provide answers to 
14 
any questions relevant to this lawsuit, and I 
15 
must 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) Will you agree that you 
22 
exchanged money for sexual gratification with at 
23 
least 50 girls at your Palm Beach mansion between 
24 
2001 and 2005? 
25 
MR. BURMAN: Object to the form. 
Page 116 
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 not to provide answers to any 
5 
questions relevant to this lawsuit, and I must 
6 
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) Between 2001 and 2005 
13 
you never ordered a professional escort to come to 
14 
your house for sex, did you? 
15 
A. Rephrase the question, please. 
16 
Q. Between 2001 and 2005 you never ordered 
17 
from an escort service in Palm Beach County for a 
18 
professional escort to come to your house for sex, 
19 
did you? 
20 
A. You never ordered? 
21 
THE WITNESS: Do I answer the question? 
22 
MR. GOLDBERGER: You don't understand. 
23 
Rephrase it. 
24 
Q. (By Mr. Edwards) Did you ever call an 
2 5 
escort service to have an escort sent to your house 
29 (Pages 113 to 116) 
PALM BEACH REPORTING SERVICE, INC. 
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Page 117 
Page 119 
1 
in Palm Beach for sex? 
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 right as guaranteed by the Fifth, 
11 
Sixth and Fourteenth Amendment to the United States 
12 
Constitution. 
13 
Q. You did not call a professional escort 
14 
because that would likely result in a girl over the 
15 
age of 18 coming to your house for sex, right? 
16 
MR. BURMAN: Object to the form. 
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 I 
22 
must accept this advice or risk losing my Sixth 
23 
Amendment right to effective representation. 
24 
Accordingly, I assert my Federal 
25 
Constitutional rights as guaranteed by the 
Page 118 
1. 
Fifth, Sixth, and Fourteenth Amendment of the 
2 
constitution. 
3 
Q. (By Mr. Edwards) Do you enjoy coercing 
4 
minors into sex acts with you? 
MR BURMAN: Object to the 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 I 
13. 
must accept this advice or risk losing my Sixth 
12 
Amendment right to effective repri..x.ntation. 
13 
Accordingly, I assert my Federal 
14 
Constitutional right as guaranteed by the 
15 
Fifth, Sixth, and Fourteenth Amendment to the 
16 
United States Constitution. 
II1By 
Mr. Edwards) Do you know-
19
 7 
intend to respond to all relevant 
2 0 
questions regarding this lawsuit However, at the 
21 
present time my attorneys have counseled me that I 
22 
cannot provide answers to any questions relevant to 
23 
this lawsuit, and I must accept this advice or risk 
24 
losing my Sixth Amendment right to effective 
25 
reuresentation. 
1 
Accordingly, I assert my Federal 
2 
Constitutional rights as guaranteed by the Fifth, 
3 
Sixth, and Fourteenth Amendment to the constitution. 
4 
Q. Did you instruct her to assist you in 
5 
gaining access to minor girls for sex? 
6 
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 
9 
cannot provide answers to any questions relevant to 
10 
this lawsuit, and I must accept this advice or risk 
11 
losing my Sixth Amendment right to effective 
12 
representation. 
13 
Accordingly, ! assert my constitutional 
14 
rights as guaranteed by the Fifth, Sixth, and 
15 
Fourteenth Amendment to the United States 
16 
Constitution. 
17 
Q. Did you instruct any other employees of 
18 
yours to assist you in pining access to minors for 
19 
sex? 
20 
A. I intend to respond to all relevant 
23. 
questions regarding this lawsuit. However, at the 
22 
present time my attorneys have counseled me that 
23 
cannot provide answers to any questions relevant to 
24 
this lawsuit, and I must accept this advice or risk 
25 
losing my Sixth Amendment right to effective 
Page 120 
1 
representation. 
2 
Accordingly, I assert my Federal 
3 
Constitutional rights as guaranteed by the Fifth, 
4 
Sixth, and Fourteenth Amendment to the United States 
5 
Constitution. 
6 
Q What people were living with you in your 
7 
Palm Beach mansion between 2001 and 2005? 
MR. GOLD13ERGER: Object to the form. 
9 
THE WITNESS: I intend to respond to all 
10 
relevant questions regarding this lawsuit. 
13. 
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 I 
14 
must 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) Did you meet with people 
23. 
employed by you to discuss a plan to gain access to 
22 
minor girls for the purposes of sex? 
23 
A. I intend to respond to all relevant 
24 
questions regarding this lawsuit. However, at the 
25 
,resent time my attomevs have counseled me that I 
30 (Pages 117 to 120) 
PALM BEACH REPORTING SERVICE, INC. 
EFTA01103355

Page 121 
1 
cannot provide answers to any questions relevant to 
2 
this lawsuit, and I must accept this advice or risk 
3 
losing my Sixth Amendment right to effective 
4 
representation. 
5 
Accordingly, I assert my Federal 
6 
Constitutional rights as guaranteed by the Fifth, 
7 
Sixth, and Fourteenth Amendment to the United States 
8 
Constitution. 
9 
Q. Which employees did you discuss your plan 
10 
to gain access to minor girls for the purposes of 
11 
sex? 
12 
A. I intend to respond to all relevant 
13 
questions regarding this lawsuit However, at the 
14 
present time my attorneys have counseled me that I 
15 
cannot provide answers to any questions relevant to 
16 
this lawsuit, and I must accept this advice or risk 
17 
losing my Sixth Amendment right to effective 
18 
representation. 
19 
Accordingly, I assert my Federal 
20 
Constitutional rights as guaranteed by the Fifth, 
21 
Sixth, and Fourteenth Amendment to the United States 
22 
Constitution. 
23 
Q. Is it true that you have many people 
24 
working in your house in Palm Beach County, or did, 
25 
between the years 2001 and 2005? 
Page 123 
1. 
representation. 
2 
Accordingly, lessen my Federal 
3 
Constitutional rights as guaranteed by the Fifth, 
4 
Sixth, and Fourteenth Amendment of the United States 
5 
Constitution. 
6 
Q. Did you ever personally procure a, or 
7 
sorry, strike that. 
a 
Did you ever personally go out and recruit 
9 
a minor girl to bring back to your house for sex? 
to 
THE WITNESS: Object to form, no? 
11 
MR. BURMAN: Object to form. 
12 
THE WITNESS: I intend to respond to all 
13 
relevant questions regarding —
14 
MR. EDWARDS: I'm sorry, is there 
15 
something you don't understand about the 
16 
question? If you don't, TII rephrase it. 
17 
MR. GOLDBERGER We objected to the form, 
18 
now you can answer. 
19 
MR. EDWARDS: I thought he objected to the 
20 
form, that's why I was --
21 
MR. GOLDBERGER: He asked -- I'm not —
22 
Brad, he asked his lawyer a question, that's 
23 
all. We objected to the form, that's fine. 
24 
MR. EDWARDS: Okay. 
25 
MR. GOLDBERCIER: Go ahead and answer. 
Page 122 
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 
this lawsuit, and I must accept this advice or risk 
6 
losing my Sixth Amendment right to effective 
7 
representation. 
a 
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. How many employees work in the various 
13 
houses that you own right now? 
14 
A. That's — that question is owned right 
15 
now? I don't understand the question. 
16 
Q. Well, it's my understanding that you own 
17 
numerous properties. I just want to know how many 
1 a 
people are actually paid by you or employed by you 
19 
that work and/or live in those homes? 
20 
A. I intend to respond to all relevant 
21 
questions regarding this lawsuit. However, at the 
22 
present time my attorneys have counseled me that I 
23 
cannot provide answers to any questions relevant to 
24 
this lawsuit, and I must accept this advice or risk 
25 
losin m Sixth Amendment Vitt° effective 
Page 124 
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 mo that I cannot provide answers to 
any questions relevant to this lawsuit, and I 
6 
must accept the advice or risk losing my Sixth 
7 
Amendment right to effective representation. 
8 
Accordingly, lessen my Federal 
9 
Constitutional right as guaranteed by the 
10 
Fifth, Sixth, and Fourteenth Amendments to the 
11 
United States Constitution. 
12 
Q. (By Mr. Edwards) Who is the first minor 
13 
girl that you brought to your house for sex? 
14 
MR. BURMAN: Object to the form. 
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 the advice or risk losing my Sixth 
21 
Amendment to effective representation. 
22 
Accordingly, I assert my Federal 
23 
Constitutional rights as guaranteed by the 
24 
Fifth, Sixth, and Fourteenth Amendment to the 
25 
United States Constitution. 
121 to 124 
PALM BEACH REPORTING SERVICE, INC. 
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Page 125 
Page 127 
1 
Q. (By Mr. Edwards) Have you had sex with 
1 
relevant questions regarding this lawsuit. 
2 
over 100 minor girls in the last ten years? 
2 
However, at the present time my attorneys have 
3 
MR. BURMAN: Object to the In 
3 
counseled me that I cannot provide answers to 
4 
THE WITNESS: I intend to respond to all 
4 
any questions relevant to this lawsuit, and I 
5 
relevant questions regarding this lawsuit. 
5 
must accept this advice or risk losing my Sixth 
6 
However, at the present time my attorneys have 
6 
Amendment right to effective representation. 
7 
counseled me that I cannot provide answers to 
7 
Accordingly, I assert my Federal 
8 
any questions relevant to this lawsuit, and I 
8 
Constitutional rights as guaranteed by the 
9 
must accept this advice or risk losing my Sixth 
9 
Fifth, Sixth, and Fourteenth Amendment to the 
10 
Amendment right to effective representation. 
10 
United States Constitution. 
13. 
Accordingly, I assert my Federal 
11 
Q. (By Mr. Edwards) Was the target age range 
12 
Constitutional rights as guaranteed by the 
12 
for your criminal enterprise always minors between 
13 
Fifth, Sixth, and Fourteenth Amendment to the 
13 
the ages of 12 and 16? 
14 
United States Constitution. 
14 
MR. BURMAN: Object to the form. 
15 
Q. (By Mr. Edwards) When did you devise your 15 
THE WITNESS: I intend to respond to all 
16 
plan to gain access to minor girls for sex? 
16 
relevant questions regarding this lawsuit. 
17 
MR. BURMAN: Object to the form. 
17 
However, at the present time my attorneys have 
18 
THE WITNESS: I intend to respond to all 
18 
counseled me that I cannot provide answers to 
19 
relevant questions regarding this lawsuit. 
19 
any questions relevant to this lawsuit, and I 
20 
However, at the present time my attorneys have 
20 
must accept this advice or risk losing my Sixth 
23. 
counseled me that I cannot provide answers to 
21 
Amendment right to effective representation. 
22 
any questions relevant to this lawsuit, and I 
22 
Accordingly, I assert my Federal 
23 
must accept this advice or risk losing my Sixth 
23 
Constitutional rights as guaranteed by the 
24 
Amendment right to effective representation. 
24 
Fifth, Sixth, and Fourteenth Amendments to the 
25 
Accordingly, I assert my Federal 
25 
United States Constitution. 
Page 126 
Page 128 
1 
Constitutional rights as guaranteed by the 
1 
Q. (By Mr. Edwards) What are the names of 
2 
Fifth, Sixth, and Fourteenth Amendment to the 
2 
all of the members of your criminal enterprise that 
3 
United States Constitution. 
3 
has the common goal of procuring minors for the 
4 
Q. (By Mr. Edwards) With whom did you meet 
4 
purposes of sex? 
5 
to discuss your plan to gain access to minor girls 
5 
MR BURMAN: Object to the form. 
6 
for sex? 
6 
THE WITNESS: I intend to respond to all 
7 
MR. BURMAN: Object to the form. 
7 
relevant questions regarding this lawsuit 
8 
THE WITNESS: I intend to respond to all 
8 
However, at the present time my attorneys have 
9 
relevant questions regarding this lawsuit 
9 
counseled me that I cannot provide answers to 
10 
However, at the present time my attorneys have 
3.0 
any questions relevant to this lawsuit, and I 
11 
counseled me that I cannot provide answers to 
11 
must accept this advice or risk losing my Sixth 
12 
any questions relevant to this lawsuit, and I 
12 
Amendment to effective representation. 
13 
must accept this advice or risk losing my Sixth 
13 
Accordingly, I assert my Federal 
14 
Amendment right to effective representation. 
14 
Constitutional tights as guaranteed by the 
15 
Accordingly, I assert my Federal 
15 
Fifth, Sixth, and Fourteenth Amendment to the 
16 
Constitutional right as guaranteed by the 
16 
United States Constitution. 
17 
Fifth, Sixth, and Fourteenth Amendment to the 
17 
Q. (By Mr. Edwards) In addition to paying 
18 
United States Constitution. 
18 
each of these minor girls approximately $200 for 
19 
Q. (By Mr. Edwards) Do you agree that you 
19 
sex, did you also provide transportation for them to 
20 
have a criminal enterprise that is comprised of at 
20 
and from your house? 
21 
the 
least, yourself,
and 
21 
MR. BURMAN: Are we generic, or are we 
22 
who have the common goal o 
nil 
22
going with the 49? 
23 
minors to you for the purposes of sex? 
23 
MR. EDWARDS: Generic. 
24 
MR. BURMAN: Object to the form. 
24 
MR. BURMAN: Generic? Okay. Object to 
25 
THE WITNESS: I intend to respond to all 
25 
the form. 
32 (Pages 125 to 128) 
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1 
THE WITNESS: You have to repeat the 
2 
question, Fin sorry. 
3 
Q. (By Mr. Edwards) In addition to paying 
4 
minor girls approximately $200 to engage in sex or 
5 
sex acts with them, did you also provide 
6 
transportation for these minor girls to and from 
7 
your house? 
8 
MIL BURMAN: Same objection. 
9 
THE WITNESS: I intend to respond to all 
10 
relevant questions regarding this lawsuit. 
13. 
However, at the present time my attorneys have 
12 
counseled me that I cannot provide any answers 
13 
relevant to this lawsuit, and I must accept the 
14 
advice or risk losing my Sixth Amendment right 
15 
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) Did you, one of your 
21 
employees, or someone within your enterprise have an 
22 
account with Yellow Cab for the purposes of 
23 
transporting minors to and from your house? 
24 
MR. BURMAN: Object to form. 
25 
MR. GOLDBERGER: Do you understand the 
Page 131 
1 
Accordingly, I assert my Federal 
2 
Constitutional right as guaranteed by the 
3 
Fifth, Sixth and Fourteenth Amendment to the 
4 
United States Constitution. 
5 
Sorry, can we take a break again? 
6 
Bathroom break. 
7 
MR. EDWARDS: Let's just break for lunch 
8 
then. 
9 
MR. GOLDBERGER: I can't, because I've 
10 
got — there's a reason why, I've got a 
11 
commitment at 1:15, so —
12 
THE VIDEOGRAPHER: Off the record at 
13 
12:40. 
14 
(Thereupon, a discussion was had off 
15 
the record.) 
16 
(Thereupon, a brief break was taken.) 
17 
THE VIDEOGRAPHER: Back on the record at 
18 
12:54. 
19 
Q. (By Mr. Edwards) Between 2001 and 2005 
20 
did you or any of your employees or assistants have 
21 
an account with Yellow Cab? 
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 provide answers to any questions relevant to 
Page 130 
1 
question when he says "enterprise"? Do you 
2 
have any idea what he means? 
3 
THE WITNESS: No. 
4 
MR. GOLDBERGER: Can you define 
5 
enterprise, so we can determine whether we need 
6 
to answer the question. 
7 
MR. EDWARDS: Pin talking about persons 
8 
involved with a common goal. We have defined 
9 
this earlier. 
10 
MR. GOLDBERGER: Pm sorry, I was out of 
11 
the room did you define it? 
12 
MR. EDWARDS: You were out of the room. 
13 
MR GOLDBERGER: Okay. 
14 
MR. EDWARDS: And persons we defined it 
15 
n, 
having the common 
17 
goo o ringing minors to an from the Palm 
18 
Beach house for the purposes of sex. 
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 I 
24 
must accept this advice or risk losing my Sixth 
25 
Amendment right to effective reresentation. 
Page 132 
1 
this lawsuit, and I must accept their advice or risk 
2 
losing my Sixth Amendment right to effective 
3 
representation. 
4 
Accordingly, I assert my Federal 
5 
Constitutional right as guaranteed by the Fifth, 
6 
Sixth, and Fourteenth Amendment to the United States 
7 
Constitution. 
8 
Q. Are you currently actually a billionaire? 
9 
MR. BURMAN: Objection. That goes to 
10 
punitive damages, and I object. 
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 right as guaranteed by the 
20 
Fifth, Sixth, and Fourteenth Amendment to the 
21 
United States Constitution. 
22 
MR. BURMAN: And I should add for the 
23 
record that I would instruct him not to answer 
24 
that question, even if he wasn't invoking the 
25 
Fifth. 
33 (Pages 129 to 132) 
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1 
Q. (By Mr. Edwards) Between 2001 and 2005 
2 
were you a billionaire? 
3 
MR. BURMAN: Objection, instruct you not 
4 
to answer that question based on the fact that 
5 
that's directed toward punitive damages, and 
6 
that has not been allowed to file, be filed, or 
7 
proceeded with in the state court action. 
8 
You should read that, as well. 
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 I 
14 
must accept their advice or risk losing my 
15 
Sixth Amendment right to effective 
16 
representation. 
17 
Accordingly, ! assert my Federal 
18 
Constitutional rights 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 
what types of cars did you have that you owned, 
23 
parked in your driveway at your Palm Beach mansion? 
24 
MIt BURMAN: Object, once again on the 
25 
grounds that punitive damages have not been 
Page 135 
1 
Q. (By Mr. Edwards) What is the square 
2 
footage of your house in Palm Beach? 
3 
MR. BURMAN: Object, on the grounds that 
4 
that question, in part, delves into his 
5 
financial situation, which has not been 
6 
approved to be explored in this case yet, 
7 
because punitive damages have not been approved 
8 
or allowed to be proceeded with here, and I 
9 
instruct him not to answer the question. 
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 
counseled me that I cannot provide answers to 
14 
any questions relevant to this lawsuit, and 
15 
must accept his advice or risk losing my Sixth 
16 
Amendment right to effective representation. 
17 
Accordingly, I assert my Federal 
18 
Constitutional rights as guaranteed by the 
19 
Fifth, Sixth and Fourteenth Amendment to the 
20 
United States Constitution. 
21 
Q. (By Mr. Edwards) Did you tell the minor 
22 
girls that were at your house that you were 
23 
extremely wealthy between 2001 and 2005? 
24 
MR. GOLDBERGER: Object to the form. 
25 
THE WITNESS: I intend to respond to all 
Page 134 
1 
approved yet in this case I instruct him not 
2 
to answer that question. 
3 
THE WITNESS: I intend to respond to all 
4 
relevant questions regarding this lawsuit. 
5 
However, at the present time my attorneys have 
6 
counseled me that I cannot provide answers to 
7 
any questions relevant to this lawsuit, and I 
8 
must accept this advice or risk losing my Sixth 
9 
Amendment right to effective representation. 
10 
Accordingly, I assert my Federal 
11 
Constitutional rights as guaranteed by the 
12 
Fifth, Sixth, and Fourteenth Amendment to the 
13 
United States Constitution. 
14 
Q. (By Mr. Edwards) Is your house in Palm 
15 
Beach located on the water? 
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, and I 
21 
must accept this advice or risk losing my Sixth 
22 
Amendment right to effective representation. 
23 
Accordingly, I assert my Federal 
24 
Constitutional rights under the Fifth, Sixth, 
25 
and Fourteenth Amendment to the constitution. 
Page 136 
1 
relevant questions regarding this lawsuit. 
2 
However, at the present time my attorneys have 
3 
counseled me that I cannot provide answers to 
4 
any questions relevant to this lawsuit, and I 
5 
must accept this advice or risk losing my Sixth 
6 
Amendment right to effective representation. 
7 
Accordingly, I assert my Federal 
8 
Constitutional rights as guaranteed by the 
9 
Fifth, Sixth and Fourteenth Amendment to the 
10 
United States Constitution. 
11 
Q. (13y Mr. Edwards) Did you talk to the 
12 
minor girls that were at your house between 2001 and 
13 
2005 about all of the houses and cars that you 
14 
owned? 
15 
MR. BURMAN: Object to the form. 
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, and 1 
21 
must 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 
34 (Pages 133 to 1 3 6) 
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Page 137 
Page 139 
1 
NIAWdStmesOmsituSom 
1 
THE WITNESS: I intend to respond to all 
2 
• Q. (By Mr. Edwards) Did you use your wealth 
2 
relevant questions regarding this lawsuit. 
3 
and the minors lack thereof to influence that minor 
3 
However, at the present time my attorneys have 
4 
to have sex with you? 
4 
counseled me that I cannot provide answers to 
5 
MR. BURMAN: Object to the form. 
5 
any questions relevant to this lawsuit, and I 
6 
THE WITNESS: I intend to respond to all 
6 
must accept the advice or risk losing my Sixth 
7 
relevant questions regarding this lawsuit 
7 
Amendment right to effective representation. 
8 
However, at the present time my attorneys have 
8 
Accordingly, I assert my Federal 
9 
counseled me that I cannot provide answers to 
9 
Constitutional rights as guaranteed by the 
10 
any questions relevant to this lawsuit, and 
10 
Fifth, Sixth, and Fourteenth Amendments to the 
11 
must accept advice or risk losing my Sixth 
11 
United States Constitution. 
12 
Amendment right to effective representation. 
12 
Q. (By Mr. Edwards) Was it part of your plan 
13 
Accordingly, I assert my Federal 
13 
to display your wealth and power in an effort to 
14 
Constitutional rights as guaranteed by the 
14 
gain sexual access to minor girls? 
15 
Fifth, Sixth, and Fourteenth Amendment to the 
15 
MR. BURMAN: Object to the form. 
16 
United States Constitution. 
16 
THE WITNESS: I intend to respond to all 
17 
Q. (By Mr. Edwards) After you ejaculated in 
17 
relevant questions regarding this lawsuit. 
18 
front of minor girls, did you tell each one of them 
18 
However, at the present time my attorneys have 
19 
that every time she came to your house for sex, you 
19 
counseled me that I cannot provide answers to 
20 
would pay her $200 cash? 
20 
any questions relevant to this lawsuit, and I 
21 
MR. BURMAN: Object to the form. 
21 
must accept the advice or risk losing my Sixth 
22 
THE WITNESS: I intend to respond to all 
22 
Amendment right to effective representation. 
23 
relevant questions regarding this lawsuit. 
23 
Accordingly, I assert my Federal 
24 
However, at the present time my attorneys have 
24 
Constitutional rights as guaranteed by the 
25 
counseled me that I cannot provide answers to 
25 
Fifth, Sixth, and Fourteenth Amendment to the 
Page 138 
Page 140 
1 
any questions relevant to this lawsuit, and I 
1 
United States Constitution. 
2 
must accept the advice or risk losing my Sixth 
2 
Q. (By Mr. Edwards) Did you intentionally 
3 
Amendment right to effective representation. 
3 
target very poor minor girls because you knew that 
4 
Accordingly, I assert my Federal 
4 
demographic would be the most impressed by your 
5 
Constitutional rights as guaranteed by the 
5 
wealth and likely listen to you? 
6 
Filth, Sixth, and Fourteenth Amendment to the 
6 
MR. BURMAN: Object to the form. 
7 
United States Constitution. 
7 
THE WITNESS: I intend to respond to all 
8 
Q. (By Mr. Edwards) Was it your plan to 
8 
relevant questions regarding this lawsuit. 
9 
groom each minor girl to be your personal sex slave? 
9 
However, at the present time my attorneys have 
10 
MR. BURMAN: Object to the form. 
10 
counseled me that I cannot provide answers to 
11 
THE WITNESS: I intend to respond to all 
13. 
any questions relevant to this lawsuit, and 
12 
relevant questions regarding this lawsuit. 
12 
must accept this advice or risk losing my Sixth 
13 
However, at the present time my attorneys have 
13 
Amendment right to effective representation. 
14 
counseled me that I cannot provide answers to 
14 
Accordingly, I assert my Federal 
15 
any questions relevant to this lawsuit, and I 
15 
Constitutional right as guaranteed by the 
16 
must accept this right or risk losing my Sixth 
16 
Fifth, Sixth, and Fourteenth Amendment to the 
17 
Amendment right to effective representation? 
17 
United States Constitution. 
18 
Accordingly, I assert my Federal 
18 
Q. (By Mr. Edwards) None of the minor girls 
19 
Constitutional rights as guaranteed by the 
19 
that you engaged in sex or sex acts with had ever 
2 0 
Fifth, Sixth, and Fourteenth Amendment to the 
20 
engaged in prostitution prior to meeting you, isn't 
23. 
United States Constitution. 
21 
that comet? 
22 
Q. (By Mr. Edwards) Did you impress upon 
22 
MR. BURMAN: Object to the form. 
23 
each minor girl that what she was doing with you 
23 
THE WITNESS: I intend to respond to all 
24 
sexually was morally right? 
24 
relevant questions regarding this lawsuit. 
25 
MR. BURMAN: Object to the form. 
25 
However at the present time m attorn 
have 
1 
35 (Pa es 137 to 140) 
PALM BEACH REPORTING SERVICE, INC. 
EFTA01103360

Page 141 
1 
counseled me that I cannot provide answers to 
2 
any questions relevant to this lawsuit, and I 
3 
must accept the advice or risk losing my Sixth 
Amendment right to effective representation. 
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) Isn't it true that you 
10 
corrupted and injured minor girls for your own 
11 
sexual gratification? 
12 
MR. BURMAN: Object to the form. 
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 ivpiebentation. 
20 
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) Isn't it true that you 
25 
typically engaged in sex or sex acts with minor 
Page 142 
1 
girls three or four times each day at your Palm 
2 
Beach mansion? 
3 
MR. BURMAN: Object to the form. 
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. 
11 
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) Isn't it true that you 
16 
in, that you coerced minor girls into prostitution? 
17 
MR. BURMAN: Object to the form. 
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 
Accordin0v I assert m Federal 
Page 143 
1 
Constitutional rights as guaranteed by the 
2 
Fifth, Sixth, and Fourteenth Amendment in the 
3 
United States Constitution. 
4 
Q. (By Mr. Edwards) Isn't it true that 
5 
and your employees, including 
called 
6 
these minor girls to encourage them to bring more 
7 
minor girls to you for sex. By called I =an on the 
8 
telephone? 
9 
MR. BURMAN: Object to the form. 
10 
THE WITNESS: Can you repeat the question? 
11 
Q. (By Mr. Edwards) Isn't it true that you 
12 lam
a 
MI
assistants or employees, including 
13 
called minor girls on the telephone to 
14 
encourage them or command that they bring you other 
15 
minor girls for sex? 
16 
MR. BURMAN: Object to the form. 
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 I 
22 
must accept this advice or risk losing my Sixth 
23 
Amendment right to effective representation. 
24 
Accordingly, I assert my Federal 
25 
Constitutional rights as guaranteed by the 
Page 144 
1 
Fifth, Sixth, and Fourteenth Amendment to the 
2 
United States Constitution. 
3 
Q. (By Mr. Edwards) What are all the 
4 
telephone numbers assigned to you or your Palm Beach 
5 
mansion between 2001 and 2005? 
6 
A. Again? 
7 
Q. What were all of the telephone numbers 
8 
assigned to you or your Palm Beach mansion between 
9 
2001 and 2005? 
10 
A. I intend to respond to all relevant 
11 
questions regarding this lawsuit. However, at the 
12 
present time my attorneys have counseled me that I 
13 
cannot provide answers to any questions relevant to 
14 
this lawsuit, and I must accept this advice or risk 
15 
losing my Sixth Amendment right to effective 
16 
representation. 
17 
Accordingly, i assert Federal 
18 
Constitutional rights as guaranteed by the Fifth, 
19 
Sixth, and Fourteenth Amendment to the United States 
20 
Constitution. 
21 
Q. Who scheduled your massage appointments 
22 
between 2001 and 2005? 
23 
A. I intend to respond to all relevant 
24 
questions regarding this lawsuit. However, at the 
2 5
rifeSent time mcaltylneis have counseled me that I 
36 (Pages 141 to 144) 
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Page 145 
Page 147 
1 
cannot provide answers to any questions relevant to 
1 
Accordingly,lassert my Federal 
2 
this lawsuit, and I must accept this advice or risk 
2 
Constitutional lights as guaranteed by the Fifth, 
3 
3 
Sixth, and Fourteenth Amendment to the United States 
losing my Sixth AnietaInwat right to effective 
4 
representation. 
4 
Constitution. 
5 
THE WITNESS: Excuse me? 
5 
Q. Did you rely on 
and your 
6 
Accordingly I assert my Federal 
6 
other assistants to 
y sc 
u e these minor 
7 
Constitutional rights as guaranteed by the 
7 
girls in a way so that they would not come in 
8 
Fifth, Sixth, and Fourteenth Amendment to the 
8 
contact with one another? 
9 
United States Constitution. 
9 
MR. BURMAN: Object to form. 
10 
Q. (By Mr. Edwards) Is it true that you were 
10 
THE WITNESS: I intend to respond to all 
11 
ejaculating in front of three or four minor girls 
11. 
relevant questions regarding this lawsuit. 
12 
per day between 2002 and 2005 at your Palm Beach 
12 
However, at the present time my alio' nays have 
13 
mansion? 
13 
counseled me that I cannot provide answers to 
14 
MR. BURMAN: Object to the form. 
14 
any questions relevant to this lawsuit, and I 
15 
THE WITNESS: I intend to respond to all 
15 
must accept their advice or risk losing my 
16 
relevant questions regarding this lawsuit 
16 
Sixth Amendment Right to effective 
17 
17 
representation. 
However, at the piesent time my attorneys have 
18 
counseled me that I cannot provide answers to 
18 
So, accordingly, l assert my 
19 
any questions relevant to this lawsuit, and I 
19 
Constitutional rights as guaranteed by the 
20 
must accept the advice or risk losing my Sixth 
20 
Fifth, Sixth and Fourteenth Amendments to the 
21 
Amendment tight to effective representation. 
21 
United States Constitution. 
22 
Accordingly, I assert my Federal 
22 
MR. EDWARDS: Ready to break? 
23 
Constitutional rights as guaranteed by the 
23 
MR. GOLDBERGER: He wants to eat. 
24 
Fifth, Sixth, and Fourteenth Amendment to the 
24 
THE VIDEOORAPHER: We're off the record at 
25 
United States Constitution. 
25 
1:12. 
Page 146 
Page 148 
1 
Q. (By Mr. Edwards) Have you ever treated 
3. 
(Thereupon, a lunch break was taken 
2 
with any doctors or physicians and discussed sexual 
2 
from 1:12 to 2:32 p.m.) 
3 
issues with them? 
3 
THE VTDEOGRAPHER: Were back on record at 
4 
THE WITNESS: I intend to respond to all 
4 
2:32. 
5 
relevant questions regarding this lawsuit 
5 
MR. EDWARDS: Ready? 
6 
However, at the present time my attorneys have 
6 
MR. GOLDI3ERGER: Sure. 
7 
counseled me that 1cannot provide answers to 
7 
Q. (By Mr. Edwards) Mr. Epstein, did you 
8 
any questions relevant to this lawsuit, and I 
8 
ever care about any of the feelings of the minor 
9 
must accept this advice or risk losing my Sixth 
9 
girls that you were engaging in sex with? 
10 
Amendment right to effective representation. 
10 
MR. BURMAN: Object to the form. 
11 
Accordingly, I assert my Federal 
11 
THE WITNESS: I intend to respond to all 
12 
Constitutional rights as guaranteed by the 
12 
relevant questions regarding this lawsuit. 
13 
Fifth, Sixth, and Fourteenth Amendment to the 
13 
However, at the present time my attorneys have 
14 
United States Constitution. 
14 
counseled me that I cannot provide answers to 
15 
Q. (By Mr. Edwards) Did you and your 
15 
any questions relevant to this lawsuit at this 
16 
assistants or employees use the word work, W-O-R-K, 16 
time, so I must accept their advice or I lose 
17 
to describe you engaging in sex acts with minors at 
17 
potential -- I risk losing my Sixth Amendment 
18 
your house? 
18 
right to effective lepon.entation. 
19 
A. I intend to respond to all relevant 
19 
And accordingly, I have to assert my 
20 
questions regarding this lawsuit. However, at the 
20 
Federal Constitutional rights as guaranteed by 
21 
present time my attorneys have counseled me that I 
21 
the Fifth, Sixth and Fourteenth Amendment to 
22 
cannot provide answers to any questions relevant to 
22 
the United States Constitution. 
23 
this lawsuit, and I must accept their advice or risk 
23 
Q. (By Mr. Edwards) Did it ever occur to you 
24 
losing my Sixth Amendment right to effective 
24 
that any of these girls were somebody's daughter --
25 
representation. 
25 
MR. BURMAN: Object to the form. 
37 (Pages 145 to 148) 
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Page 149 
1 
Q. (By Mr. Edwards) — when you were 
2 
engaging in sex with them? 
3 
MR. BURMAN: Object to the form of the 
4 
question. 
5 
THE VIDEOGRAPHER: I intend to respond to 
6 
all relevant questions regarding this lawsuit. 
7 
However, at the present time my attorneys have 
8 
counseled me that I cannot provide answers to 
9 
these questions, as I have to accept their 
10 
advice or risk losing my Sixth Amendment right 
11 
to effective representation, Brad. 
12 
THE WITNESS: Is it okay if I call you 
13 
Brad? 
14 
MR EDWARDS: You can continue. 
15 
THE WITNESS: And, accordingly, I assert 
16 
my Federal Constitutional rights as guaranteed 
17 
by the Fifth, Sixth and Fourteenth Amendment to 
18 
the United States Constitution. 
19 
Q. (By Mr. Edwards) When you were digitally 
20 
penetrating these minor girls, did you care about 
21 
the fact that you were emotionally or 
22 
psychologically hurting them? 
23 
MR. BURMAN: Object to the form of the 
24 
question. 
25 
THE WITNESS: I intend to respond to all 
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 151 
Q. (By Mr. Edwards) Isn't it true that at 
the time that you were sexually battering these 
minor girls, you didn't care what happened to them 
and only cared about your only personal sexual 
gratification? 
MR. BURMAN: Object to the form. We need 
to talk outside. 
THE WITNESS: Me, too? 
THE VIDEOGRAPHER: We're off the record at 
2:35. 
(Thereupon, a brief break was taken.) 
THE VIDEOGRAPHER: We're back on the 
record at 2:36. 
MR. BURMAN: For the purposes of the 
record, I will toll you that this line of 
questioning, in my view, is way beyond the 
bounds of permissible discovery-type questions, 
and nothing but pure argument, and if you 
continue in this vein, I will stop the 
deposition and we will seek instruction from 
Judge Hafele about what's permissible and 
what's not. 
Q. (By Mr. Edwards) Isn't it true that at 
the time you were inserting your fingers into the 
vagina of these little kids, all you cared about was 
Page 150 
1 
relevant questions regarding this lawsuit. 
2 
However, at the present time my attorneys have 
3 
counseled me that I cannot provide answers to 
4 
any questions relevant to this lawsuit, and I 
5 
must accept this advice or risk losing my Sixth 
6 
Amendment right to effective representation. 
7 
Accordingly, I assert my Federal 
8 
Constitutional rights as guaranteed by the 
9 
Fifth, Sixth, and Fourteenth Amendments to the 
10 
United States Constitution. 
11 
Q. (By Mr. Edwards) We have heard over and 
12 
over again that you intend to respond to this. When 
13 
do you intend to respond to these questions? 
14 
MR. BURMAN: Object to the form. 
5 
THE WITNESS: I intend to respond to all 
16 
relevant questions regarding this lawsuit. 
17 
However, at the present time on advice of 
18 
counsel I cannot provide answers to those 
19 
questions at this time. I must accept advice 
20 
of my counsel or risk losing my Sixth Amendment 
21 
right to effective representation. 
22 
Accordingly, I'll have to assert my 
23 
Federal Constitutional rights as guaranteed by 
24 
the Fifth, Sixth, and Fourteenth Amendment to 
25 
the United States Constitution. 
1 
2 
3 
4 
6 
7 
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10 
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Page 152 
your own sexual gratification? 
MR. BURMAN: The deposition is over. 
THE VIDEOGRAPHER: Conclude at 2:37, end 
of tape 2 of 2. 
MR. BERGER: We're going to order instant 
copy, and we want the tape, also, 
Mr. Videographer. 
MR. BURMAN: We want this as soon as they 
get theirs, we want ours. 
(Thereupon, the deposition was 
adjourned at 2:38 p.m.) 
38 (Pages 149 to 1 5 2) 
PALM BEACH REPORTING SERVICE, INC. 
EFTA01103363

1 
2 
3 
Page 153 
CERTIFICATE OF OATH 
STATE OF FLORIDA 
) 
: SS 
COUNTY OF PALM BEACH ) 
1 
2 
3 
4 
s 
Page 
TO I MILEY EPSTEIN 
elo 
MENA& URMAN. ESQUIRE 
515 N
JOHN
onb Fluke DriveBrStile 400 
Nest Peen Beach, Florida 33401 
air. 
vs. 7117FREY EPSTEIN and 
155 
4 
6 
Al tht conclusion of your depositien gives 
5 
I, the undersigned authority, certify that 
7 
In the abovutylod cute too Indicated you withod 
6 
JEFFREY EPS1EIN personally appeared before the and 
8
I' astir he analla 
7 
was duly sworn. 
TS Meer Is b advise you that you 
8 
WITNESS my hand and official seal this 1st 
9 
depositioa is ready. end re ask eat you anger 
oaks ni (Sal) 4713995 Myour maw 
9 
day of May, 2009. 
is 
conuenithes for at appointment tourer in. 
11 
If you ere path a
 °akin se
tter 
10 
attar has endued a copy of Ode trensaipt, rat 
11 
12 
aterideb to read lin copy and Ithward to us 2 
photostatic othy Oyu: tired cethectke sheet 
LINDA P. AUKAMP, RPR 
12 
13 
13 
Commission No.: DD 499271 
14 
it is secunty dist toedo 
 
Elite icon 
u mt
. since dm inmalth mum be hold 
14 
Notary Public- State of Florida 
1S
brood months handy date of this Wier. 
15 
My Commission Expires: 12-26-09 
If rya have sat/reason which you would 
16 
16 
like Par nth to pact on thedeposition as to re 
haws to I* *tuna. ukase advise. 
17 
17 
18 
18 
Tank you for you prompt attetthou. 
19 
velytnavyvvn. 
19 
PALM BEACH READRTNG SERVICE. D40. 
20 
1665 Pain Bach Lakes Ellud. 
21 
20 
Saito 1001 
West Palm Beach. Fkeicla 33401 
22 
n 
23
22 
23 
BY: LINDA P. AUKAMP.RPR 
24 
Dale Ntay 1st. 2029 
25 
2 
245 
Page 154 
Page 156 
1 
REPORTER'S DEPOSITION CERTIFICATE 
1 
CORRECTION SHEET: 
2 
2 
NAME: JEFFREY EPSTEIN 
3 
STATE OF FLORIDA ) 
I
RE: E.W. vs. JEFFREY EPSTEIN and 
4 
COUNTY OF PALM BEACH ) 
4 
5 
I, LINDA P. AUKAMP, a Registered 
The following corrections, additions or 
6 
7 
Professional Reporter, certify that I was authorized 
to and did stenographically report the depositim of 
5 
6 
deletions were noted on the transcript of the 
testimony which I gave in the above-captioned matter 
held on April 30th, 2009: 
8 
JEFFREY EPSTEIN; that a review of the transcript was 
7 
PAGE(S) 
LINE(S) SHOULD READ 
9 
requested; and that the transcript is a true and 
8
10 
complete record of my stenographic notes. 
9 
11 
I FURTHER CERTIFY that on the 1st day of 
10 
12 
May, 2009,1notified JOHN MICHAEL BURMAN, ESQUIRE 11 
13 
that the deposition of JEFFREY EPSTEIN was ready fa 
12 
14 
reading and signing by the witness. 
13 
15 
I fitrther certify that I am not a 
14 
16 
relative, employee, attorney, or counsel of any of 
15 
17 
the parties, nor am I a relative or employee of any 
16 
18 
of the parties' attorney or counsel connected with 
17 
19 
the action, nor am I financially interested in the 
18 
2O 
action. 
19 
20 
21 
Dated this 1st day of May, 2009. 
21 
22 
22 
SIGNATURE: 
23 
23 
DATE: 
24 
LINDA P. AUKAMP, RPR 
24 
25 
25 
39 (Pages 153 to 156) 
PALM BEACH REPORTING SERVICE, INC. 
EFTA01103364