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Q 
am I mispronouncing? 
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A Yes, 
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Q How would you pronounce It? 
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A Gislaine. 
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Q Okay. 
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A I'm sorry, but today at least I have to 
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assert my rights under the Sixth, Fifth and 
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Fourteenth Amendment upon advice of counsel. 
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Q Sir, have you ever been an 
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owner/shareholder or director of the LAW 
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Plantation Management Corporation? 
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A I would like to answer every one of your 
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questions here today, Mr. Horowitz, with respect 
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to that one, as well as all the others, I have to 
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assert my rights under the Sixth, Fifth and 
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Fourteenth Amendment. 
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Q Sir, have you ever been an owner, 
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shareholder or director of a business entity 
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known as Epstein Interests? 
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A With respect to that question, as well 
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as all of your other questions here today, my 
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counsel advised me I may only answer the 
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questions by asserting my rights under the Sixth, 
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Fifth and Fourteenth Amendment. 
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Q Sir, have you ever been officer, 
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THE WITNESS: Take a quick.. 
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(Indicating counsel.) 
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711E VIDEOGRAPHER: Going off the video 
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record 1:53 a.m. 
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(Pause in the proceedings.) 
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THE VIDEOGRAPHER: Back on the record 
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I I:56 a.m. 
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(The record was read.) 
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A Yes. 
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Q Are you an owner of the Florida Science 
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Foundation? 
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A On advice of counsel, at least today, 
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sir, I have been instructed to assert my rights 
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under the Sixth, Fifth and Fourteenth Amendment. 
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Q Are you an employee of Florida Science 
16 
Foundation? 
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A Yes. 
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Q What do you do in your role as an 
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employee of Florida Science Foundation? 
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A Though 1 would like to answer all of 
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your questions here today, Mr. Horowitz, upon 
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advice of counsel, they've instructed me I must 
r 3 
assert my rights under the Sixth, Fifth and 
4 
Fourteenth Amendment. 
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Q What kind of work is the Florida Science 
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1 
director, shareholder or employee of the Wexner 
2 
Investment Group? 
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A I have to respond to that question as I 
have responded to all your other questions here 
5 
today, Mr. Horowitz. Upon advice of counsel 
6 
they've instructed me to assert my rights under 
7 
the Sixth, Fifth and Fourteenth Amendment. 
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Q Sir, have you ever been a shareholder or 
9 
owner of MC Squared Modeling? 
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A With respect to that question, as all 
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the other questions you've posed here today, my 
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counsel has advised me I must assert my rights 
13 
under the Sixth, Fifth and Fourteenth Amendment. 
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Q Sir, do you have an ownership or 
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beneficial interest in a business entity known as 
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JEGE? 
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A I'm going to have to respond to that 
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question as I responded to all of your other 
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questions here today, Mr. Horowitz, which is, on 
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advice of counsel they've asked me to assert my 
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rights under the Sixth, Fifth and Fourteenth 
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Amendment. 
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Q Sir, do you have an ownership or 
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beneficial interest or even an employee of an 
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entity known as the Florida Science Foundation? 
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Foundation involved in, if any? 
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MR. PIKE: Form. 
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A Though I would very much like to answer 
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all of your questions here today, Mr. Horowitz, 
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upon advice of counsel, they've instructed me to 
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assert my rights under the Sixth, Fifth and 
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Fourteenth Amendment. 
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Q Where do you work for the Florida 
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Science Foundation? 
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MR. PIKE: Form. 
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A At 250 South Australian. That's the 
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offices. 
Q Is that the City of West Palm Beach? 
A Yes, sir. 
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Q During what hours do you work at the 
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Florida Science Foundation? 
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instructed me to assert my rights under the 
Sixth, Fifth and Fourteenth Amendment. 
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Q How long have you been working at the 
Florida Science Foundation? 
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MR. PIKE: Form. 
A Upon advice of counsel, sir, they've 
A I would like to answer all of your 
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questions here today, Mr. Horowitz. However, 
upon advice of counsel, at least today, they've 
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instructed me to assert my rights under the 
Sixth, Fifth and Fourteenth Amendment. 
Q On what days do you work for the Florida 
Science Foundation? 
MR. PIKE: Forth. 
A Though I would like to answer each one 
of your questions hue today, my counsel has 
advised me that at least today I must assert my 
rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q Who else, if anyone, works for the 
Florida Science Foundation? 
MR. PIKE: Form. 
A Though I would like to --
MR. PIKE: You know that's standard 
Fifth Amendment, anyway. 
A Though I would like to answer each and 
every one of your questions today, Mr. Horowitz, 
my counsel has advised me with respect to that 
question, I must assert my rights under the 
Sixth, Fifth and Fourteenth Amendment 
Q is the Florida Science Foundation a 
for-profit or nonprofit corporation? 
A Upon advice of counsel, sir, with 
respect to that question, I'm going to have to 
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MR. PIKE: To the extent you can answer 
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that question without divulging my 
3 
communications with you, you can answer that 
4 
question. 
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ANo. 
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Q Did you review any materials, such as 
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depositions, police reports, anything else in 
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preparation for your deposition today? 
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ANo. 
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Q Did you review any notes or any 
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handwritten materials in preparation for your 
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deposition today? 
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A No. 
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Q You have notes on a piece of paper, art 
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those notes that you have made or reviewed in 
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preparation for your continuation of this 
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deposition here today? 
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A No. 
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Q In the past you've told me that some 
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time ago at another deposition, that you did not 
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like Jane Doe; is that right? 
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A I don't believe — I have no 
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recollection of that. 
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Q To be more specific, and hopefully to 
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Jog your memory, do you remember telling me you 
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assert my rights under the Sixth, Fifth and 
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Fourteenth Amendment. 
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MR. HOROWITZ: Sir, at this moment in 
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time, I don't have further questions. There 
may be some other questions that arise from 
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other people's questions. 
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THE WITNESS: All right. 
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MR. PIKE: Thank you, Mr. Horowitz. 
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MR. EDWARDS: Does anybody want to 
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address what we are going to do for lunch? 
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MR. HOROWITZ: You don't have to type 
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this. 
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(Discussion off the record.) 
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THE VIDEOGRAPHER: Off the video record 
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at 12:00 o'clock noon. 
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(Pause in the proceedings.) 
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THE VIDEOGRAPHER: Rack on the video 
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record 12:11 p.m. 
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MR. EDWARDS: Ready? 
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MR. PIKE: Yes, thank you. 
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THE WITNESS: Yes. 
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Q I represent Jane Doe inn case against 
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you and she is one of like ten representative 
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plaintiffs here today. Did you do anything to 
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prepare for your deposition today? 
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like L.M., but don't like my other two, one of 
those clients being Jane Doe; do you recall that? 
A I would like to answer every one of your 
questions, Mr. Edwards, but today at least, my 
counsel advised me I must assert my rights under 
the Sixth, Fifth and Fourteenth Amendment. 
Q Why don't you like Jane Doe? 
MR. PIKE: Form. 
A I would like to answer every one of your 
questions, Mr. Edwards. However, today my 
counsel has advised me that I measures assert my 
rights under the Sixth. Fifth and Fourteenth 
Amendment. 
Q Did you sexually molest Jane Doe when 
she was 14 and I5 years old? 
MR. PIKE: Form. 
A I would like to answer all of your 
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questions with respect to Jane Doe. However my 
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counsel here today advised me I may not and must 
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assert my rights under the Sixth, Fifth and 
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Fourteenth Amendment. 
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MR. EDWARDS: Move to strike as 
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nonresponsive. 
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Q When you say you would like to answer 
B 
the questions, but your counsel has instructed 
you that you must invoke your Fifth, Sixth and 
Fourteenth Amendment rights, are you saying that 
you disagree with the advice of your counsel? 
MR. PIKE: I instruct you not to answer 
that question. 
MR. EDWARDS: On what ground? 
MR. PIKE: I don't need to give you 
grounds. 
MR. EDWARDS: It is not a privilege, 
just something you're instructing him not to 
answer? 
MR. PIKE: Absolutely it is a 
privilege. You heard him, what he said. He 
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is invoking his Sixth, Fifth and Fourteenth 
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Amendment in and as a result of his advice 
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of counsel. Your question elicits 
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attorney/client communications as well as 
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Q Have you read the statute or been 
instructed upon the Florida statute related to 
lewd and lascivious molestation? 
MR. PIKE: Form, instruct you not to 
answer that question, attorney/client work 
product, as worded. 
Q Other than your attorney telling you 
about the statute, or reading that statute to 
you, I certainly do not want and am not entitled 
to communications between you and your attorney, 
but have you otherwise familiarized yourself, 
either by way of reading the statute or being 
told by somebody other than your attorneys, 
regarding the statute lewd and lascivious 
molestation? 
MR. PIKE: Form. 
A Though I would like to answer every one 
of you ever questions here today, Mr. Edwards, 
most of your questions I have to respond by 
asserting on advice of counsel my Sixth, Fifth 
and Fourteenth Amendment right. 
Q Lewd and lascivious molestation is 
defined in Florida as a person who intentionally 
touches In a lewd or lascivious manner, the 
breasts, genitals, general area, or buttocks, or 
422 
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work product. 
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Q So, attorney/client work product is the 
3 
basis for your objection? I understand. 
4 
MR. PIKE: Yeah. 
5 
Q Mr. Epstein, are you going to follow 
6 
your advice of counsel and invoke your Fifth 
7 
Amendment right against self-incritnination and 
not answer that question? 
A I'm going to follow my advice of 
counsel. 
Q Mr. Epstein, are you familiar with the 
laws in Florida on lewd and lascivious 
molestation? 
MR. PIKE: Form. 
A On advice of counsel I have to assert my 
rights with the Sixth. Fifth and Fourteenth 
Amendment. 
Q Do you understand my question in that 
I'm not asking you whether you committed any 
crimes related to the statute, only whether or 
not you are familiar with the Florida statute on 
lewd and lascivious molestation; do you 
understand that question? 
MR. PIKE: Form. 
A What does "familiar" mean. 
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the clothing covering them, of a person less than 
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I6 years of age, or forces or entices a person 
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under 16 years of age to so touch the 
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perpetrator." 
5 
Having read that, isn't that a statute 
6 
that you violated on numerous occasions against 
7 
Jane Doe when she was a minor? 
8 
MR. PIKE: Form. 
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A I would -- have to assert my rights 
under the Sixth, Fifth and Fourteenth Amendment 
upon advice of counsel, Mr. Edwards. 
Q Subchapter six of that statute involves 
a crime of lewd and lascivious conduct that in 
Florida is defined as a person who intentionally 
touches a person under 16 years of age in a lewd 
6 
and lascivious manner, or a person who 
intentionally masturbates in the presence of a 
victim under 16 years of age." Those are also 
sections of that Florida statute that you 
violated against the then minor. Jane Doe; is 
that true? 
MR. PIKE: Form. 
A I would like to answer all of your 
questions with respect to Jane Doe, Mr. Edwards. 
However, today my counsel has advised me that I 
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am to assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
MR. EDWARDS: Move to strike the 
nonresponsive portion of that answer. 
MR. PIKE: What's nonresponsive? 
MR. EDWARDS: What you would like to do 
is not responsive to the question related to 
his course of conduct. "Did you molest 
ha," is either "yes" or "no" or "invoked." 
I don't really care and I don't think it is 
relevant, what he would like to do. That's 
the part I would move to strike. 
MR. PIKE: If that's the part you're 
moving to strike, it is duly noted in the 
record. 
MR. EDWARDS: Okay. 
MR. PIKE: I object to that. For the 
record, based upon your comment, there have 
been several depositions in these 
consolidated cases and there has been 
implied arguments from the plaintiffs side 
relative to the Fifth Amendment waiver and 
why Mr. Epstein is invoking the Sixth, Fifth 
and Fourteenth Amendment Constitutional 
privileges and there are various adverse 
1 
molestation statutes against Jane Doe? 
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MR. PIKE: Form. 
3 
A Upon advice of counsel, Mr. Edwards, I 
4 
have to respond to that question as I responded 
5 
to most of your other questions here today, by 
6 
asserting my rights under the Sixth, Fifth and 
7 
Fourteenth Amendment. 
8 
I prefer to, in fact, respond to your 
9 
partner who helped file this lawsuit, but he is 
10 
currently in jail. You might want to strike that 
11 
as nonresponsive, but the ladies and gentlemen of 
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the jury will eventually know that most of these 
13 
cases have been brought by your finn, your 
14 
partner who sits in a jail for fabricating cases 
15 
of sexual nature against people like me and 
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others. 
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Q Okay. Let's talk about that, then. 
18 
You're talking about Scott Rothstein? Is that 
19 
right? You're saying my former partner. Is that 
0 
who you're referring to that sits in jail? 
1 
A Correct. 
2 
Q Okay, what about anything that Scott 
3 
Rothstein did, affects your answer to my question 
4 
as to whether or not you molested Jane Doe back 
5 
in 2003 and 2004? 
426 
1 
inferences that I'm sure the plaintiffs will 
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attempt to gain. 
3 
There have been arguments made relative 
to the Fifth Amendment and I think that you 
5 
have, in particular, Mr. Edwards. have 
6 
attempted to balance what Mr. Epstein would 
7 
like to do, versus what if he did that, 
whether or not there would be a waiver of 
the Fifth, the Sixth and the Fourteenth. So, 
I understand your motion to strike and it is 
noted on the record, but I have to make 
clear for the record that there have been 
those arguments made and there is a balance 
as to what someone would like to do versus 
what someone can do, and the resulting 
consequences of that being waiver. 
Q Given what your attorney just said, my 
understanding that... You have been instructed 
that if you answer these questions, as you would 
0 
like to, that it would incriminate you? 
1 
MR. PIKE: Mischaracterizes my 
objection; and I instruct you not to 
answer. 
Q Why is it that you would like to answer 
questions about whether or not you violated 
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MR. PIKE: Form? 
2 
A I would like to answer that question 
3 
with respect to Scott Rothstein, his fabricated 
4 
cases and the reason he sits in jail. However, 
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today, at least today, my counsel has advised me 
6 
I must assert my rights under the Sixth, Fifth 
7 
and Fourteenth Amendment. 
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Q Yon say "at least today," but that's 
9 
something we have gone through with you day after 
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day, after day, and you say "at least today," and 
11 
we wait for the next deposition and again there 
12 
is assertion of a Firth Amendment right. Is 
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there ever going to be a day where you do answer 
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the questions? 
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MR. PIKE: Form. Move to strike. 
16 
A On advice of counsel, as I've answered 
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most of your other questions here today, be them 
18 
argumentative or not, meant for other purposes or 
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not, my answer is going to be that my counsel has 
20 
advised me that at least today I must Men my 
21 
rights under the Sixth, Fifth and Fourteenth 
22 
Amendment. 
23 
Q You indicated in your previous answer 
24 
that most of the eases were brought by me or my 
25 
former partner, Scott Rothstein. My 
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understanding is that there were more than 20 
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cases brought against you alleging you sexually 
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abused minors, and I have personally only filed 
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three. How many are you aware of in addition to 
the three that Scott Rothstein filed, or brought, 
as you say? 
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MR. PIKE: Form, mischaracterizcs the 
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witness's testimony. 
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MR. EDWARDS: Do you want the previous 
10 
answer read back related to that? 
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MR. PIKE: No, I think his answer will 
12 
be the same. 
13 
A At least today I have to respond to that 
14 
question as I've responded to most of your other 
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questions here today, Mr. Edwards, which is, at 
16 
least today I have to assert my rights under the 
17 
Fifth, Sixth and Fourteenth Amendment. 
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Q In a portion of your answer, you 
19 
indicated that Scott Rothstein fabricated cases. 
20 
Are you alleging that the case of Jane Doe 
21 
against Jeffrey Epstein Is a fabricated case? 
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MR. PIKE: Form. 
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A I would like to answer each one of your 
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questions here today, Mr. Edwards, especially 
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with respect to Jane Doe. However, my counsel 
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other questions, which is, that upon advice of 
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counsel, at least today, they've instructed me 
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that I must assert my rights under the Sixth. 
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Fifth and Fourteenth Amendment. 
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Q Isn't it also true that through the 
6 
years he has sent you as, quote, unquote, 
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"gifts," underage females, as young as I2 years 
8 
old for you to illegally engage in sex with? 
MR. PIKE: Fonn. 
A I'm going to respond to that question as 
I responded to most of your other questions, 
which is, upon advice ofcounsel, at least today, 
though I would like to answer the question, 
they've instructed me I must assert my rights 
under the Sixth. Fifth and Fourteenth Amendment. 
Q In fact, you know that we served Mr. 
Brunel for deposition In this case. Are you 
aware of that? 
MR. PIKE: Form. 
A I'm going to have to respond to that 
question as I respond to all your other questions 
here today, Mr. Edwards, which is by asserting my 
rights under the Sixth. Fifth and Fourteenth 
Amendment. 
Q He has been a house guest at your house 
430 
1 
has instructed me I must assert my rights under 
2 
the Sixth, Fifth and Fourteenth Amendment. 
3 
Q Mr. Epstein, do you know a gentleman 
4 
named Jean Luc Brunel and the last name is 
5 
spelled 13-r-u-n-e-l. 
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MR.. PIKE: Form. 
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A My counsel has advised meat least 
8 
today, Mr. Edwards, as I've responded to most of 
9 
your other questions, I have to assert my right 
under the Sixth, Fifth and Fourteenth Amendment. 
Q Mr. Brunel is somebody that you know to 
be a child molester; is that right? 
MR. PIKE: Form. 
A I would like to answer every one of your 
questions here today, Mr. Edwards. However, on 
advice of counsel, they've instructed me I must 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Mr. Brunel has been a close friend of 
yours for years and is still a close friend of 
yours today; is that right? 
MR. PIKE: Form. 
A Though I would like to answer every one 
of your questions posed here today, I have to 
answer that one as I've answered most of your 
432 
1 
on numerous occasions this year; isn't that 
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true? 
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MR. PIKE: Form. 
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A Though I would like to answer every one 
5 
of your questions here today, Mr. Edwards, I have 
6 
to respond to that question on advice of counsel 
7 
the same way as I've responded to all of your 
8 
other questions, which is, I must assert my 
9 
rights under the Sixth, Fifth and Fourteenth 
10 
Amendment. 
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Q I've asked you simply, if Mr. Brunel has 
12 
been a house guest of yours during the year 2010, 
13 
and you're choosing to invoke your Fifth 
14 
Amendment right against self-incrimination and 
15 
basing that on your counsel's advice. 
16 
Does your counsel know that you made 
17 
that representation to Probation already this 
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year? 
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MR. PIKE: Form. 
20 
Q Do you understand the question? 
21 
A Are you asking me what my counsel 
22 
knows? 
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Q No. 
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A I think you just asked what my counsel 
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knows. 
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MR. PIKE: That's exactly what 
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A You should ask my counsel. 
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Q Here is my point: You've indicated to 
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your Probation Officer this year, in fact, I'll 
5 
ask it this way: Have you indicated to your 
6 
Probation Officer that Jean Luc Brunel has bees a 
7 
house guest of yours during the year 2010? 
MR. PIKE: Form. 
A I have been insuumed by my counsel to 
answer that question, as I have been instructed 
to answer most of your other questions here 
today, which is by asserting my rights under the 
Sixth, Fifth and Fourteenth Amendment. 
Q Do you know an attorney named Tama 
Kudman? 
MR. PIKE: Form -- actually that's not 
"form." I withdraw that. 
A No. 
Q Did Mr. Brunel ten you that Tama Kudman 
was an attorney that was hired to repre)ent him 
in this ease? 
MR. PIKE: I'm sorry, hold on. 
MR. EDWARDS: Did Mr. Brunel tell him. 
MR. PIKE: Dicey, tam. 
A I'm going to have to answer that 
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MR. EDWARDS: Agreed. 
MIL PIKE: His response is his verbal 
response. 
MR. EDWARDS: I understand that, but 
certainly if a witness is on the witness 
stand we both know they are allowed to 
observe the demeanor of the witness and part 
of that demeanor is the nodding or shaking 
of the head, which are common responses that 
is we all know and understand. I just want 
to make sure we are on the same page, the 
jury can ignore those body movements? 
MR. PIKE: Asa matter of fact, and as 
you know, since you tried several cases, 
there is a patterned jury instruction from 
the judge that says the jury can, in fact, 
take it into consideration. 
MR. HOROWITZ: That's the point. 
MR. PIKE: I cannot instruct the jury in 
this video deposition to ignore anything 
that occurs on this video. 
MR. EDWARDS: That's why I wanted to 
engage 
so I would make sure -- we are a 
little inconsistent obviously as to what the 
Jury should be observing, what they can, 
434 
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question as I've answered most of your other 
2 
questions here today, Mr. Edwards, which is by 
3 
asserting my rights under the Sixth, Fifth and 
4 
Fourteenth Amendment. 
5 
Q And did you or some entity that you own 
6 
or control pay for the services of Tama Kudman to 
represent Jean Luc Brunel, in this matter? 
8 
MR. PIKE: Form. 
9 
A ... I'm going to have to assert my rights 
10 
under the Sixth, Fifth and Fourteenth Amendment 
11 
upon advice of counsel. 
12 
Q I certainly don't want to get into this 
13 
too often during this deposition but it is 
14 
visibly noticed on the video that prior to the 
15 
invocation of the Fifth Amendment, there is a 
16 
shaking of the head which commonly indicates that 
17 
the answer Is "No," and I just want to make sure 
18 
we are all on the same page, that that was not 
19 
your indication and that we can ignore those 
20 
types of body movements, as Mr. Pike instructed 
21 
me that was the case last time. 
22 
MR. PIKE: I think that the record is 
23 
clear. The court reporter does not 
24 
understand nods of the head, shakes of the 
25 
head, "um-hum" --
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versus his response. I guess for this time 
we will get into it. 
Q In that last question that I asked you, 
related to you or some entity that you control 
paying for the services of Ms. Kudman, is the 
answer "no" or is the answer that you are 
invoking your Fifth Amendment right to remain 
silent? 
MR. PIKE: Form. 
A With respect to that question, as with 
respect to all your other questions here today, 
Mr. Edwards, upon advice of counsel I have to 
assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
Q Isn't it true that you have specifically 
instructed Mr. Brunel to avoid his deposition in 
this case? 
MR. PIKE: Form. 
A Upon advice of counsel, as with respect 
to most of your other questions here today, I'm 
going to answer that the same way by invoking my 
rights under the Sixth, Fifth and Fourteenth 
Amendment, sir. 
Q Mr. Epstein, can you describe for the 
jury your various schemes that you have devised 
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to access underage minor females for sex? 
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MR. PIKE: Form. 
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A Though I would like to respond to all 
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these questions that you've posed here today, Mr. 
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Edwards, I'm going to have to assert my rights 
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under advice of counsel under the Sixth, Fifth 
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and Fourteenth Amendment. 
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Q I think the video will reflect that 
9 
prior to your invocation at that time there was a 
smile that I would characterize as a smirk, prior 
to that answer, and I would like to understand, 
was there any intention on your part to convey a 
message by that smile, prior to your invocation? 
MR. PIKE: First of all, this line of 
questioning is not only argumentative, but 
it is harassing, okay? 
MR. EDWARDS: We can play the video for 
whether or not it is harassing. 
MR. PIKE: You can play the video, but 
if someone raises an eyebrow, blinks, does 
something, it is... it is... for you to 
follow up with a harassing question is not 
only improper, but it is a waste of time, of 
attorney resources as well as judicial 
resources. I'm going to let you proceed, I 
1 
of my counsel, he's instructcd me that 1 may 
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not. I must invoke my rights under the Sixth, 
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Fifth and Fourteenth Amendment. 
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Q Mr. Epstein, is it true that you have 
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sexually molested underage minors in every 
6 
community where you have homes or houses? 
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MR. PIKE: Form. 
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A Though I would like to answer each one 
9 
of your questions here today, Mr. Edwards, I 
10 
would like to answer that question, to you and 
11. 
your partner, who sits in jail for fabricating 
12 
cases of a sexual nature against people like me 
13 
and others in South Florida, but today, upon 
14 
advice of my counsel, they've instructed mel 
15 
must assert my rights under the Fifth, Sixth and 
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Fourteenth Amendment. 
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THE WITNESS: Before you go to the 
18 
bathroom? 
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MR. EDWARDS: Move to strike the portion 
0 
of the answer that was nonresponsive. 
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MR. PIKE: One second. 
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MR. EDWARDS: Move to strike the portion 
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of the answer nonresponsive. 
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MR. PIKE: Move to strike your motion to 
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strike. 
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mean, but... 
come on. 
MR. EDWARDS: With all due respect, I'm 
interpreting it as an intentional act 
designed to dilute the invocation of the 
Fifth Amendment and any adverse inference 
that we may be entitled to, and I think that 
you acknowledged previously that a jury will 
have or could have the ability to view this 
video, and I'm assuming a jury could make 
that same inference, so I want to make sure 
the record is just crystal clear. if the 
answer is one answer and there is no body 
movement, then I'll move on. If there is 
body movement, I'm probably going to address 
it. 
MR. PIKE: Fm going to move to strike 
your last narrative. 
MR. EDWARDS: Okay. 
Q What individuals other titan yourself 
helped you to devise your various schemes for 
accessing large numbers of minor females for 
sex? 
MR. PIKE: Form. 
A Though I would like to answer every one 
of your questions today, Mr. Edwards, upon advice 
440 
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MR. EDWARDS: Based on the fact that it 
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was responsive? You feel it was 
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responsive? 
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MR. PIKE: Absolute — listen --
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MR. EDWARDS: It is fine if you do. 
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MR. PIKE: You're harassing the witness, 
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you're talking about heads and nod shakes. 
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If you want to be clear for the record,1 
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think, and Fm 
I think -- I think the 
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witness is nodding and shaking his head in a 
1 
manner because your questions are 
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argumentative. 'Please tell me the scheme 
3 
that you devised? 
4 
"Please tell me who you molested," all 
S 
of these are argumentative questions --
6 
MR. EDWARDS: If it wasn't true, it 
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would be argumentative. 
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MR. PIKE: They are just not formed 
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right. You are sitting here subjecting the 
0 
witness to questions that -- that are just 
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argumentative. They are not structured 
2 
appropriately, and you're taking that and 
3 
you're implying something else for the jury 
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on the record, and quite frankly, I don't 
appreciate that. So, yes, to answer your 
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question, it 100 percent is responsive. He 
is invoking his Sixth, Fifth and 
Fourteenth. 
THE WITNESS: Bathroom break now? 
MR. EDWARD$: That's fine. 
THE VIDEOGRAPHER: Off the video record 
12:35 pm. 
(Pause in the proceedings.) 
MR. EDWARDS: twill be asking you to 
read back the lost question and answer, so 
you're ready. 
THE COURT REPORTER: Certainly. 
THE VIDEOGRAPHER: Back on the video 
record 1:16 p.m. 
MR. EDWARDS: Madam Court Reporter, if 
you could read back the last question, as 
well as the last answer which I have been 
• 
told was responsive. 
THE COURT REPORTER: Certainly. 
(The record was mad.) 
Q Mr. Epstein, why is it that you would 
like to tell Scott Rothstein whether you have 
sexually molested underage minors in the various 
communities where you have homes? 
MR. PIKE: Form. Mischaraaerizes the 
1 
that one, however, upon advice of counsel they've 
2 
instructed me that I must assert my rights under 
3 
the Sixth, Fifth and Fourteenth Amendment, and if 
4 
I don't do so, I risk losing that representation. 
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Q What is special about the question of 
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you molesting children on a daily basis for the 
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better part of two decades, that you would 
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especially like to answer that question? 
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MR. PIKE: I'm sorry? 
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MR. EDWARDS: His answer was that he 
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would especially like to answer that 
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previous question and the question posed to 
13 
him was... 
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Q Isn't it true for the better part of two 
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decades you have molested children on an every 
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day basis. And Pro asking now, what is it about 
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that question that makes you especially want to 
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respond to that one? 
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MR. PIKE: Form. 
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A Though I would like to answer that 
21 
question as well as your other questions here 
22 
today. Mr. Edwards, upon advice of counsel, 
23 
they've told me I must assert my rights under the 
24 
Sixth, Fifth and Fourteenth Amendment, or risk 
25 
losing my representation. 
442 
witness's testimony. 
2 
A I would like to answer that question, as 
3 
well as all of your other questions, Mr. Edwards, 
4 
however today my counsel has advised me) must 
5 
assert my rights under the Sixth, Fifth and 
6 
Fourteenth Amendment. 
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Q Can you tell the jury what, if anything, 
Scott Rothstein has to do with the allegations of 
you molesting underage children? 
MR. PIKE: Form. 
A Though I think the jury will find out 
what Scott Rothstein has to do with all these 
cases, I hope that's the case. I have been 
instructed by my counsel to respond to all of 
your questions, most of your questions here 
today, but I have to assert my Sixth, Fifth and 
Fourteenth Amendment. 
MR. EDWARDS: More to strike the portion 
of nonresponsive related to Scott Rothstein. 
Q Is it true for the better part of two 
decades you have interacted sexually with 
underage minors on a daily basis? 
MR. PIKE: Form. 
A I would like to answer every one of your 
questions here today, Mr. Edwards, especially 
444 
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Q Is it true that you have intentionally 
2 
preyed on vulnerable children as young as 12 
3 
years old on an every day basis, for sexual 
4 
purposes for the last decade? 
5 
MR. PIKE: Form. 
6 
A Though I would like to respond to that 
7 
question, as well as other questions posed by 
8 
you„ and I would prefer to respond to both you 
9 
and your partner, Scott Rothstein, who sits in 
10 
jail for fabricating questions of a sexual 
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nature, cases of a sexual nature against people 
12 
like me and others in South Florida. You were 
13 
part of a law firm that the U.S. Attorney refers 
14 
to as one of the largest criminal enterprises in 
15 
South Florida's history, so though I would like 
16 
to answer, and you will probably mark my question 
17 
as nonresponsive, my counsel has told me today I 
18 
must not answer that question and must assert my 
19 
Sixth, Fifth and Fourteenth Amendment right. 
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MR. EDWARDS: Move to strike the answer 
21 
as nonresponsive. All other portions 
22 
portion of the answer, all but the 
23 
invocation of the Fifth Amendment. 
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Q Please describe for the jury the plan or 
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scheme that you employed to access the underage 
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minor females of Palm Beach County, including 
Jane Doe. 
MR. PIKE: Form. 
A I would like to answer that question as 
would like to have answered most of your other 
questions here today, especially with respect to 
Jane Doe, as she is your client, but on advice of 
counsel they've instructed me that I must, must 
assert my Sixth Amendment, Fifth Amendment and 
Fourteenth Amendment right, so therefore that's 
what I'm going to do. 
Q Despite your preference you're going to 
listen to your counsel. 
MR. PIKE: Form, I'm going to Instruct 
you not to answer that question. 
MR. EDWARDS: As to whether or not he is 
going to listen to counsel? 
MR. PIKE: He's already invoked on 
advice of counsel. 
MR. EDWARDS: That last question was 
taken right out of Bob Critton's play book. 
MR. PIKE: Take it up with the Court. 
Bob Critton is not here, I am. 
Q Isn't it true as part of the plan to 
access young girls between 12 and 17 years old In 
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A Though I would like to answer that 
question, as well as all the other questions 
you've posed here today, Mr. Edwards, upon advice 
of counsel, they've instructed me i must assert 
my rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q With each and every underage minor 
female that arrived at your house under the idea 
they were to give you a massage, they were tint 
led up and left alone in your bedroom with you; 
is that correct? 
MR. PIKE: Form. 
A Again? Repeat the question. 
Q This is a scheme that you've employed 
for years and years, and years, and somehow 
you're having a hard time grasping how a scheme 
that you devised worked? 
MR. PIKE: No. Move to strike. You 
don't have a question on the table. 
Actually your previous question prior to 
what you just stated did not involve any 
word, quote, -seismic," end quote. If you 
want to repeat the question, go ahead. 
Q Isn't this how it worked, that an 
underage minor female would come to your house 
446 
Palm Beach County, that you would send a message 
2 
that you would be willing to pay those females 
3 
for them providing you a massage at your house? 
MR. PIKE: Form. 
5 
A You have to repeat the question. 
6 
Q Sure. The initiation, the manner in 
7 
which you gained access to underage girls between 
8 
the ages of 12 and 17 in Palm Beach, is that you 
9 
would initially have somebody tell them that they 
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could tome to your house and give you a massage 
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and you would pay them for their time. 
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MR. PIKE: Form. 
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THE WITNESS: It is not a question. 
14 
A You didn't ask me a question. You made 
15 
a statement. 
16 
THE WITNESS: Ifyou want to repeat it 
17 
back. 
18 
(Indicating the court reporter.) 
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Q I'll make it clearer for you. 
20 
A Thank you. 
21 
Q Did you send a message to various 
22 
underage minor females, that you would pay for 
23 
those underage minor females to provide you a 
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massage at your house? 
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MR. PIKE: NMI. 
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448 
1 
and you instructed or did you instruct 
2 
or one of your other assistants to lead 
3 
that minor female up to your bedroom to be left 
4 
alone with you? 
5 
MR. PIKE: Form. 
6 
A Though i would like to answer that 
7 
question as well as all the other questions 
8 
you've posed here today, Mr. Edwards, upon advice 
9 
of my counsel they've instructed me I must assert 
my rights under the Sixth. Fifth and Fourteenth 
Amendment. 
Q Once that underage minor female, 
normally between the ages.of 12 and 17 would 
arrive in your bedroom, you would then appear 
naked or wearing only a towel each time; is that 
correct? 
MR. PIKE: Form. 
A I would like to answer each one of your 
questions, Mr. Edwards. However, today my 
counsel has advised me that I must assert my 
rights under the Sixth, Fifth and Fourteenth 
Amendment, 
Q After appearing naked or wearing only a 
towel, then wouldn't you instruct the underage 
minor female to get naked herself? 
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MR. PIKE: Form. 
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A Though I would like to answer all of 
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your questions here today, I'm going to have to 
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respond to that question as I've responded to 
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most of your others here today, which is by my 
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counsel's instructing me that I must assert my 
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rights under the Fifth, Sixth and Fourteenth 
8 
Amendment. 
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Q Then, once the underage minor female was 
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naked, you would attempt various lewd or 
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lascivious improper sexual acts against that 
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underage minor female, correct? 
13 
MR. PIKE: Form. 
14 
A Though I would like to respond to all of 
75 
your questions, Mr. Edwards, I have to respond to 
16 
that as I responded to all of the other questions 
17 
here today that you've posed, which is that my 
18 
counsel, at kast today, has instructed me I must 
19 
assert my rights under the Sixth, Fifth and 
20 
Fourteenth Amendment. 
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Q And you would always pay cash money to 
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the underage minor female after you improperly 
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and/or illegally sexually abused that underage 
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minor female, correct? 
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rights under the Fifth, Sixth and Fourteenth 
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Amendment or, in fact, potentially lose my right 
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to representation. 
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Q What you're saying with that answer is 
5 
that your counsel will not represent you anymore 
if you choose to waive your Fifth Amendment 
rights and begin to answer these questions? 
MR. PIKE: No, not at all, On the 
advice of counsel, if you know what the 
Sixth Amendment is and how it reads, you 
would understand what the invocation is, in 
full. So move to strike your — 
MR. EDWARDS: Question? 
MR. PIKE: -- last question, and it 
mischaracterkes the witness's testimony. 
Do you know what the Sixth Amendment is, Mr. 
Edwards? 
MR. EDWARDS: Yes, and it is not my 
deposition and I'm not sure your client 
knows about the effective assistance of 
counsel or any amendment --
MR. PIKE: Do you know how due process 
clause affects the 6th Amendment? 
Never mind, just go ahead. I'm sorry. 
MR. EDWARDS: However, the statement was 
450 
A Though I would like to answer each and 
2 
every one of your questions here today, Mr. 
3 
Edwards, my counsel has advised me I must assert 
my rights under the Sixth, Fifth and Fourteenth 
5 
Amendment. 
6 
Q Each of these sessions or sexual 
7 
interactions between you and underage minor 
8 
females ended, when you had ejaculated, correct? 
MR. PIKE: Form. 
A I would like to answer that question, as 
I would like to answer all of your other 
questions here today. However, today at least. 
my counsel has instructed me that I must assert 
my rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q After paying the underage minor female 
for being sexually molested, you would ask the 
underage minor female to leave her telephone 
number with one of your assistants; is that 
correct? 
MR. PIKE: Form. 
A I would like to answer that question. I 
would like to answer most of your other questions 
here today; however, at least today my counsel 
has advised me that I may not, and must assert my 
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452 
1 
made if he answers the questions, as he 
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would prefer to do, which seems remarkable 
3 
and incredible, then he would be fired or 
4 
you would be fired from him, and I want to 
5 
understand what it... 
Q Why is it that your attorneys will no 
longer represent you if you choose to do what you 
want to do, which is answer these questions? 
MR. PIKE: Move to strike. 
Do you want to ask a question? Because 
I'm not quite sure he even testified to 
that. We have been through several 
depositions and you are implying something 
from the invocation of the Fifth, Sixth and 
Fourteenth that does not exist. There has 
been no mention of firing, there's been no 
mention of withdrawing, there's been no 
mention of anything of the sort. 
MR. EDWARDS: Can we go back to the 
question and response that ended with 
risk losing my..." 
THE COURT REPORTER: Certainly. 
MR. PIKE: Once again, do you know that 
the Sixth Amendment is? 
MR. EDWARDS: Yes. 
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MR. PIKE: Would you like to Google it? 
Because that Sixth Amendment --
MR. EDWARDS: She will have a hard time 
going back, if you continue talking. She 
has to type while you talk. 
MR. PIKE: The Sixth Amendment, as 
incorporated into the due process clause, 
which is the Fourteenth Amendment is the 
right to effective assistance of counsel. 
MR. EDWARDS: I understand. 
MR. PIKE: If you read it in full, it 
will kind of shed light and you can probably 
glean the invocation and the meaning of it 
from his response. 
Is there a question? 
MR. EDWARDS: Go back, please. 
(The record was read.) 
Q So your counsel told you that you must 
invoke your Fifth Amendment right to remain 
silent, otherwise you will lose your right to 
their representation; is that what you're 
saying? 
MR. PIKE: Move to strike. 
Mischaracterizes the witness's testimony, 
and invocation... misconstrues and 
1 
A Though I would like to answer that 
2 
question as well as all the other questions 
3 
you've posed here today, Mr. Edwards, I'm afraid 
4 
that upon advice of counsel they've instructed me 
5 
that I must assert my rights under the Sixth, 
6 
Fifth and Fourteenth Amendment. 
7 
Q And a separate offer was made to each 
8 
underage minor female as well. That is, if she 
9 
brings you other underage minor females so that 
10 
you can sexually abuse, then you would pay a 
11 
finder's fee for each underage minor female 
12 
brought to you; is that correct? 
13 
MR. PIKE: Form. 
14 
A I would like to answer every one of the 
15 
questions you've posed here today, Mr. Edwards. 
16 
However, today at least, upon advice of counsel, 
17 
they have instructed me I must assert my rights 
18 
under the Sixth, Fifth and Fourteenth Amendment. 
19 
was a female that brought 
20 
you multiple underage minor females; is that 
21 
correct? 
22 
MR. PIKE: Form. 
23 
A Though I would like to answer every one 
24 
of your questions that you've posed here today, 
25 
my counsel has instructed me I must assert my 
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454 
misinterprets the Fifth, Sixth and 
Fourteenth Amendments. 
I'm going to instruct you not to answer 
that question, because I don't understand 
it. It was not your response, and 
because --
MR. EDWARDS: I wrote down the response. 
MR. PIKE: -- and because, ill 
understand, your question, you phrased it 
as, "So if I understand you, your attorney 
told you," so I'm going to instruct you not 
to answer that question because it will, 
apparently, it would disclose my 
communications with you, so there you go. 
MR. EDWARDS: In his answer he said, "My 
counsel said I can't respond," so he is 
telling me already what --
MR. PIKE: That's not what he said. He 
said "On the advice of counsel." 
MR. EDWARDS: All right. 
Q The offer was then made to each underage 
minor female that each time she returned to you■ 
home and you sexually molest her, she will then 
be paid cash; is that correct? 
MR. PIKE: Form. 
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456 
rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q -was 
an underage minor female that 
you first abused when she was 13 years old; Is 
that correct? 
MR. PIKE: Form. 
A Though I would like to answer every 
question you have regarding L.M. here today, my 
counsel has instructed me that I must assert my 
rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q While -was a minor, she brought you 
more than 50 underage minor females that you 
sexually abuse, correct? 
MR. PIKE: Form. 
A I would like to answer all the questions 
you have regarding L.M., here today. However, at 
least today my counsel has instructed me I may 
not. I must assert my right under my Sixth, 
Fifth and Fourteenth Amendment. 
Q One of the underage minor females 
brought to you b3=was Jane Doe, when .lane 
Doe was age 14; is that correct? 
MR. PIKE: Form. 
A I would like to answer the questions 
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regarding Jane Doe andn Mr. Edwards. 
However, at least today my counsel has instructed 
me I must assert my rights under the Sixth, Fifth 
and Fourteenth Amendment. 
Q Looking at the operative complaint in 
Jane Doe versus Jeffrey Epstein ease 80893, 
referring to the plaintiff Jane Doe, first 
indicates this is an action for damages in an 
amount in excess of 50 million dollars. 
Is that a number that you would agree 
would fairly compensate her, as well as punish 
you for the conduct you committed against Jane 
Doe? 
MR. PIKE: Form. 
A I would like to answer that question. 
would like to answer all of your other questions 
that you've posed here today, Mr. Edwards. 
However, at least today, on advice of counsel 
they've instructed me that I may not and have 
instructed me that I must assert my rights under 
the Sixth, Fifth and Fourteenth Amendment. 
Q One of the allegations Jane Doe makes is 
that Jeffrey Epstein demonstrated sexual 
preference and obsession for minor girls. Is it 
true that you have a sexual preference and 
1 
MR. EDWARDS: No, I'm asking if your 
2 
client agrees with the assertion that's 
3 
stated in the complaint, or if he has a 
4 
defense that is going to defeat such 
5 
assertion or evidence that is going to 
6 
defeat such assertion. So I'm simply asking 
7 
your client... 
8 
Q Is that a true statement? 
9 
MR. PIKE: Form. 
10 
A I would like to answer all of your 
11 
questions about Jane Doe and your other clients. 
12 
However, today my counsel has told me that I may 
13 
not. I must assert my rights under the Sixth, 
14 
Fifth and Fourteenth Amendment. 
15 
Q You did personally call Jane Doe on the 
16 
telephone on at least one occasion; isn't that 
17 
true? 
18 
MR. PIKE: Form. 
19 
A I would like to answer your questions 
20 
regarding calling Jane Doc, or contacting Jane 
21 
Doe. However, my counsel has instructed me that 
22 
today, at least, I may not. I must assert my 
23 
rights under the Sixth, Fifth and Fourteenth 
24 
Amendment. 
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Q And of the time when you contacted Jane 
458 
1 
obsession for minor girls? 
2 
MR. PIKE: Form. 
3 
A I would like to answer the question with 
4 
respect to what Jane Doe said, however, my 
5 
counsel today has instructed me that I must 
6 
assert my rights under the Sixth, Fifth and 
7 
Fourteenth Amendment 
8 
Q Another allegation is that defendant 
9 
Epstein's planned scheme and enterprise included 
10 
an elaborate system wherein the then minor 
11 
plaintiff and other minor iris were contacted by 
12 
telephone by Epstein 
or other 
13 
unknown employees or assistants working for 
14 
Epstein, and were then persuaded to come over to 
15 
Epstein's house for the purposes of engaging in 
16 
prostitution. 
17 
Is that a true statement? 
18 
MR. PIKE: First, I'm going to object to 
19 
the form and second, I believe you're 
20 
working from a portion of a complaint 
21 
especially with your reference to scheme and 
22 
the RICO allegations that were dismissed 
23 
with prejudice. So, I just want to be 
24 
clear, are you doing discovery on a count 
25 
that no longer exists? 
460 
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Doe, was the purpose to have ber come to your 
2 
house and interact with you sexually? 
3 
MR. PIKE. Form. 
4 
A Con you repeat the question? 
5 
Q Yes, the time that you called Jane Doe, 
6 
was the purpose of your call to have her come to 
7 
your house and interact with you sexually? 
8 
MR. PIKE Form. 
9 
A I would like to answer that question as 
10 
1 would like to answer all of your other 
11. 
questions with respect to Jane Doe, your client. 
12 
However, today at least, my counsel has 
13 
instructed me I must assert my rights under the 
14 
Sixth, Fifth and Fourteenth Amendment 
15 
MR. EDWARDS: Move to strike a portion 
16 
of the answer that's nonresponsive. 
17 
was one of your assistants 
18 
back in the years 2003, 2004 and 2005, correct? 
19 
A I would like to answer each one of your 
20 
questions, Mr. Edwards, here today; however, on 
21 
advice of counsel, at least today Pm going to 
22 
have to assert my rights under the Sixth, Fifth 
23 
and Fourteenth Amendment. 
24 
called by telephone Jane 
25 
Doe when Jane Doe was a minor child, on more than 
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463 
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15 occasions; isn't that true? 
1 
of your private airplane to Palm Beach for the 
2 
MR. PIKE: Form. 
2 
specific purpose of luring minor girls to your 
3 
A Mr. Edwards, I would like to answer 
3 
mansion for the purposes of sexually abusing 
4 
every one of your questions regarding Jane Doe 
4 
them? 
S 
that you've posed here today. However, at least 
5 
MR. PIKE: Form. 
6 
today, on advice of counsel I'm going to have to 
6 
A I would like to answer that question, 
7 
assert my rights under the Sixth, Fifth and 
7 
Mr. Edwards„ but today at least, on advice of 
8 
Fourteenth Amendment. 
8 
counsel, they've instructed me to assert my 
9 
Q The purpose or 
contacting 
9 
Sixth. Fifth and Fourteenth Amendment rights. 
10 
the minor child Jane Doe back in 2003,2004 and 
10 
Q Isn't it true that you conspired with 
11 
2005, was always to get her to come to your house 
11 
others to contact minor females including Jane 
12 
to interact with you sexually; is that correct? 
12 
Doe, for the purposes of sexually abusing Jane 
13 
MR. PIKE: Poem. 
13 
Doe? 
14 
A I would like to answer that question as 
14 
MR. PIKE: Form. 
15 
well as all your other questions you've posed 
15 
A I would like to answer that question, 
16 
here today regarding your client, Jane Doe. 
16 
Mr. Edwards, as well as every other question 
17 
However, at least today, my counsel has advised 
17 
you've posed here today. However, at least today 
18 
me I must assert my rights under the Sixth, Fifth 
18 
upon advice of counsel they've instructed me to 
19 
and Fourteenth Amendment. 
19 
assert my Sixth, Fifth and Fourteenth Amendment 
20 
Q Did you or 
or any of your 
20 
right 
21 
other assistants contact Jane Doe for some other 
21 
Q Isn't It true that your sexual 
22 
purpose than to have her come to your house for 
22 
interaction with Jane Doe occurred specifically 
23 
you to sexually molest her? 
23 
during the time period. February 2003 through 
24 
MR. PIKE: Form. 
24 
June 2005? 
25 
A Though I would like to answer every 
• 25 
MR. PIKE: Form. 
462 
4&1 
question that you've posed here today regarding 
1 
A I'm going to have to respond to that, 
2 
Jane Doe, Mr. Edwards, my counsel has advised me, 
2 
Mr. Edwards, as I've responded to all your other 
3 
3 
questions, which is that today at least on advice 
at least today, that I may not and must assert my 
4 
rights under the Fifth, Sixth and Fourteenth 
4 
of counsel I must assert my rights under the 
S 
Amendment. 
5 
Sixth, Fifth and Fourteenth Amendment. 
6 
Q Each call that was made by you or on 
6 
Q During the time Jane Doe was under the 
7 
your behalf to Jane Doe, was made at a time when 
7 
age of 16, isn't it true that you digitally 
8 
Jane Doe was a minor child, true? 
8 
penetrated her vagina? 
9 
MR. PIKE: Form. 
9 
MR. PIKE: Form. 
10 
A I would like to answer that question as 
10 
A I would like to answer that question, as 
11 
well as all your other questions with regard to 
11 
well as your other questions. However, at least 
12 
Jane Doe, Mr. Edwards. However, today my counsel 
2 
today my counsel has advised me I must assert my 
13 
has advised me I may not and must assert my 
13 
rights under the Sixth, Fifth and Fourteenth 
14 
rights under the Sixth. Fifth and Fourteenth 
14 
Amendment. 
15 
Amendment. 
15 
Q Immediately following that question, you 
16 
() In addition to your Palm Beach home, 
6 
clearly smiled and rolled your eyes. Is there 
17 
isn't it true that you own a, what has been 
7 
anything that we should read or the jury should 
18 
called a mansion in New York, a ranch in New 
18 
read into that body language? 
19 
Mexico, a home in France, as well as an island in 
19 
MR. PIKE: I'm going to instruct you not 
20 
the Virgin Islands? 
0 
to answer the question. 
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MR. PIKE: Font. 
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I move to strike it as harassing. 
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A I'm sorry, but today at least, on advice 
2 
MR. EDWARDS: Move to strike what as 
23 
of counsel I have to assert my rights to the 
3 
harassing? It is something that everybody 
24 
Sixth, Fifth and Fourteenth Amendment. 
4 
is going to be able to see and I want to 
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Q Isn't It true that you traveled by way 
5 
know what it means, if anything. 
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MR. PIKE: I'm instructing him not to 
answer. 
MR. EDWARDS: How are you instructing 
not to answer a question? 
MR. PIKE: Because I am. 
MR. EDWARDS: Based on what? 
MR. PIKE: Because it is harassing. 
MR. EDWARDS: I'm not harassing. I want 
to know why he did what he did. 
MR. PIKE: You are harassing him. I 
mean, it is an argumentative question --
MR. EDWARDS: He harassed my clients. 
MR. PIKE: — he has been here since 
10:00 o'clock. He's given several 
depositions. This is Volume III of a 
continuation, okay? He's sitting here 
waiting for your questions but not waiting 
to be harassed. 
Q There is a way to prevent those 
questions, and that's not do that type of rolling 
your eyes. 
MR. PIKE: You're not going to instruct 
the witness on how to 
the witness is here 
behaving professionally --
MR. EDWARDS: In your mind. 
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going to let it happen, not on my watch, not 
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today. You can take it up with the Court. 
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MR. EDWARDS: I will. 
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MR. PIKE: Mali( the record. If you 
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will. 
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MR. EDWARDS: It is marked. I'm just 
7 
wondering whether there is going to be a 
privilege asserted or it is just going to be 
a blanket, I'm telling the witness not to 
answer," related to something that the jury 
is going to view and should be entitled to 
know what it means. 
MR. PIKE: (Counsel shrugs.) 
MR. EDWARDS: You just don't like that 
your client is giving those body language 
responses. 
MR. PIKE: No. Move to strike. It has 
nothing do with that. It has to do with a 
significant fact, that on a legal basis 
you're attempting to badger and harass the 
witness, based upon what you believe are 
some sort of facial expressions and you're 
attempting to get an adverse inference from 
an answer. I'm not going to let him answer 
a harassing question, so you can then get an 
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MR. PIKE: — Answering your questions, 
invoking his Constitutional rights under the 
United States Constitution. And I'm sorry 
that that doesn't make you happy, but I'm 
not here —
MR. EDWARDS: It doesn't make him happy 
either, apparently. 
MR. PIKE: - I'm not here to dispute 
and debate with you what privileges are 
being invoked and whether you feel it is 
right or wrong. If you have a question, ask 
the witness a question. 
Q Why did you roll your eyes when I asked 
you If you digitally penetrated Jane Doe when she 
was 14 and 15 years old? 
MR. PIKE: I'm instructing you not to 
answer that question. 
MR. EDWARDS: Your reason for the 
instruction is based on some privilege? 
MR. PIKE: My reason for the instruction 
is that you are attempting to play fast and 
loose with the Fifth Amendment and adverse 
inference. 
MR. EDWARDS: I'm not. 
MR_ PIKE: Yes, you are, and I'm not 
468 
1 
adverse inference relative to some gesture. 
2 
MR. EDWARDS: We will take it up, fine. 
3 
MR. PIKE: Take it up. 
4 
Q Mr. Epstein, Isn't it also true that you 
5 
used a vibrator or vibrating device on Jane Doe's 
6 
vagina when she was under the age of 16? 
7 
MR. PIKE: Form. 
8 
A I would like to answer all of your 
9 
questions, Mr. Edwards. However, today on advice 
10 
of counsel, theyve advised me that I may not and 
11 
must assert my rights under the Sixth, Fifth and 
12 
Fourteenth Amendment. 
13 
Q Isn't it also true when Jane Doe was a 
14 
minor child, that you masturbated on multiple 
15 
occasions in her presence? 
16 
MR. PIKE: Form. 
17 
A I would like to answer all of your 
18 
questions regarding Jane Doe. However, today my 
19 
counsel has advised me that I may not, and have 
0 
instructed me to assort my rights under the 
1 
Sixth, Fifth and Fourteenth Amendment. 
2 
Q In June of 2008, isn't it true, sir, 
23 
that you entered pleas of guilty to various 
24 
felony -- to two felony charges in Palm Reach 
25 
County? 
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3. 
MR. PIKE: Asked and answered within 
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this deposition. 
3 
A Yes. 
4 
Q And as a result of those guilty pleas 
5 
you were sentenced to 18 months incarceration in 
6 
Palm Beach County jail; Is that correct? 
7 
MR. PIKE: Asked and answered. 
8 
A Yes. 
Q In addition to the sentence related to 
those felony charges, isn't It also true that you 
entered into an agreement known as the 
"Nonprosecution Agreement," with the federal 
government? 
MR. PIKE: I'm sorry, would you read 
that back, Madam Court Reporter? 
(The record was read.) 
MR. PIKE: Can you reword the question? 
MR. EDWARDS: Sure. 
Q Did you enter into an agreement with the 
federal government that is entitled 
"Nonprosecution Agreement"? 
A Yes. 
Q And that Nonprosecution Agreement at 
paragraph 7 Indicates that "The United States 
shall provide Epstein's attorneys with a list of 
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liability"? 
Are you familiar with that section of 
the agreement? 
MR. PIKE: Form, and the document speaks 
for itself. 
A The document speaks for itself. 
Q Are you familiar with that portion of 
the document? 
A I'm not sure what you mean by "familiar 
with," sir. 
Q Have you read it? 
A Yes. 
Q So, if Jane Doe were to bring a claim 
exclusively under 18 USC 2255, then you already 
contractually agreed to waive your right to 
contest liability to that claim; is that true? 
MR.. PIKE: Form, and calls for a legal 
conclusion. 
A Upon advice of counsel, though I would 
like to answer all of your questions here today, 
they've Instructed me I must assert my rights 
under the Sixth, Fifth and Fourteenth Amendment 
THE WITNESS: Five minutes? 
MR. EDWARDS: Whatever you need. 
THE WITNESS: Okay. 
470 
1 
individuals whom it has identified as victims, as 
2 
defined in 18 USC 2255, after Epstein has signed 
3 
this agreement, and been sentenced." Have you 
4 
seen the names of the identified victims that 
5 
were supplied by the U.S. Attorney's office? 
6 
A I would like to answer that question as 
7 
I would like to answer most of your other 
8 
questions here today, Mr. Edwards. However, upon 
9 
advice of counsel they've instructed me that I 
10 
must assert my rights under the Sixth, Fifth and 
11 
Fourteenth Amendment. 
12 
Q And isn't it true that Jane Doe was on 
13 
that list of victims that was supplied to you by 
14 
the United States? 
15 
A I would like to answer that question. 
16 
However, at least today my attorneys have advised 
17 
me that I must assert my rights under the Sixth, 
18 
Fifth and Fourteenth Amendment. 
19 
Q In paragraph eight of the Nonprosecution 
20 
Agreement between you, Mr. Epstein, and the 
21 
United States Attorney's Office, it Indicates, 
22 
"If any of the individuals, referred to In 
23 
paragraph 7," referring to the list of victims, 
24 
"elects to file a lawsuit pursuant to 18 USC 
25 
2255, Epstein waives his right to contest 
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472 
THE VIDEOGRAPHER: Going off the video 
record 1.51 pm. 
(Pause in the proceedings.) 
TFIE VIDEOGRAPHER: Back on the video 
record 1:57 p.m. 
Q The specific federal statute that is 
incorporated In the Nonprosecution Agreement, IS 
USC 2255. states -- rather than do it that way, 
let me just ask the question. 
Mr. Epstein, did you knowingly conspire 
with others to use a telephone to persuade, 
induce or entice minor females, including Jane 
Doe, to engage in prostitution? 
MR. PIKE: Foam 
A Though I would like to answer that 
question, as most of your other questions, I have 
to respond by telling you that my attorneys have 
told me, at least today, that I must assert my 
rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q Mr. Epstein, did you knowingly and 
willfully conspire with others to travel 
interstate for the purpose of engaging in illicit 
sexual conduct with minors, including Jane Doe? 
MR. PIKE: Form. 
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A Though I would like to answer that 
1 
exclusively under 18 USC 2255, that you waived 
2 
question, as well as most of your other questions 
2 
your right to contest liability? 
3 
3 
MR. PIKE Form. Also, could call for 
here today, Mr. Edwards, in fact, all of the 
4 
other questions here today, my counsel has 
4 
the disclosure of attorney/client 
5 
instructed me at least today, I must assert my 
5 
communications and work product, and is 
rights under the Fifth, Sixth and Fourteenth 
6 
protected under the Federal Rule of Evidence 
7 
Amendment. 
7 
502408, as well as 410? 
8 
Q Mr. Epstein, did you use a tekphone to 
8 
A Though I would like to answer that 
9 
knowingly persuade, induce or entice minor 
9 
question, Mr. Edwards, I have to invoke my rights 
10 
females, including Jane Doe, to engage In 
10 
under the Sixth, Fifth and Fourteenth Amendment. 
11 
prostitution? 
11 
Q In a recent motion for summary judgment 
12 
MR. PIKE: Form. 
12 
filed on your behalf, a statement is made, 
13 
A Though I would like to answer that 
13 
"Epstein never using a facility or means of 
14 
question, as well as your other questions today, 
14 
interstate commerce, knowingly persuaded, induced 
15 
Mr. Edwards, at least today, my counsel has 
15 
or enticed Jane Doe when she was under the age of 
16 
instructed me that I must assert my rights under 
16 
18 years, to engage in prostitution or sexual 
17 
the Sixth, Fifth and Fourteenth Amendment. 
17 
activity for whkh any person can be charged with 
18 
Q Mr. Epstein, did you travel, interstate 
18 
a criminal offense or attempted to do so." That 
19 
commerce for the purpose of engaging in illicit 
19 
is a false statement, true? 
20 
sexual conduct with minor females, including Jane 
20 
MR. PIKE: Form. 
21 
Doe? 
21 
A Though I would like to answer that 
22 
MR. PIKE: Form. 
22 
question, on advice of counsel I have been 
23 
A Though I would like to answer that 
23 
instructed to assert my rights under the Sixth, 
24 
question, as well as the other questions you've 
24 
Fifth and Fourteenth Amendment. 
25 
posed hoe today, Mr. Edwards, fen afraid that my 
25 
Q The statement was also made on your 
474 
476 
1 
counsel has instructed me that I must assert my 
1 
behalf, "Epstein never attempted to or conspired 
2 
rights under the Sixth, Fifth and Fourteenth 
2 
to knowingly transport Jane Doe in interstate or 
3 
Amendment. 
3 
foreign commerce or In any Commonwealth territory 
1 
Q Isn't It true that you agreed with the 
4 
or possession of the United Stales, with Intent 
5 
federal government that if Jane Doe brought 
S 
that Jane Doe engage in prostitution or in any 
5 
claims exclusively alleging those sections of I8 
6 
sexual activity for which any person can be 
7 
USC 2255 that I've read in the preceding, four 
7 
charged with a criminal offense." 
a 
paragraphs, that you would admit liability unto 
8 
That is also a false statement; isn't 
9 
her as an identified victim? 
9 
that right? 
10 
MR. PIKE: Form. 
10 
MR. PIKE: Fonn. 
11 
A I don't believe that's what the document 
11 
A You said "lime Doc." 
12 
says. 
12 
Q Jane Doe is Jane Doe in this case. 
13 
Q The document says, "If any of the 
13 
MR. PIKE: Form. 
14 
Individuals referred to In paragraph 7 elects to 
19 
A I believe her deposition speaks to 
15 
file suit pursuant to IS USC 2255, Epstein waives 
15 
that. With respect to anything else, I have to 
16 
his right to contest liability, and also waives 
16 
assert my rights under the Sixth, Fifth and 
17 
his right to contest damages up to an amount as 
17
Fourteenth Amendment. 
18 
agreed to between the identified individual and 
18 
Q You believe that Jane Doe's deposition 
19 
Epstein, so long as the identified individual 
19 
speaks to whether you attempted or conspired to 
20 
elects to proceed exclusively under 18 USC 
20 
knowingly transfer Jane Doe in interstate 
21 
2255." 
21 
commerce, correct? 
22 
That's the provision. I'll ask you then 
22 
MR. PIKE: Form. 
23 
the question: Didn't you agree with the federal 
23 
Q You believe her deposition speaks to 
24 
government that if Jane Doe, an identified 
24 
that? 
25 
victim, proceeds in a case against you, 
25 
A That's my belief, yes. 
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Q And then would you adopt her deposition 
2 
testimony as true and as your support for that 
3 
assertion? 
4 
MR. PIKE: Form. 
5 
A You're asking her entire deposition 
6 
testimony? 
7 
Q The deposition as it relates to whether 
8 
or not you knowingly transported her in 
interstate commerce. 
A Well, I would like to answer that 
question, but on advice of counsel, at least 
today, I have been instructed to assert my rights 
under the Sixth, Fifth and Fourteenth Amendment. 
Q A statement that Epstein never attempted 
to or conspired to travel in interstate commerce 
or travel into the United States or travel in 
foreign commerce for the purpose of engaging In 
illicit sexual conduct with Jane Doe," is also a 
false statement, isn't it? 
MR. PIKE: Form? 
A I would like to answer that question ns 
well as your other questions, Mr. Edwards. 
However, today my counsel has instructed me that 
I must assert my Fifth, Sixth and Fourteenth 
Amendment right. 
478 
Q The statement that Epstein never 
2 
attempted to or conspired to travel in foreign 
3 
commerce and engage in any illicit sexual conduct 
4 
with Jane Doe, is also a fake statement; isn't 
that right? 
MR. PIKE: Form. 
A I would like to that question as well as 
9 
the other questions posed today, Mr. Edwards. 
9 
However, on the advice of counsel they've 
10 
instructed me to assert my Sixth. Fifth and 
11. 
Fourteenth Amendment right. 
12 
Q In fact, you did contact Jane Doe when 
13 
she was a minor child as well as conspired to use 
14 
a telephone to contact Jane Doe when she was a 
15 
minor child, specifically for the purposes of 
16 
engaging in illicit sexual conduct with Jane Doe, 
17 
true? 
18 
MR. PIKE: Form. 
19 
A Though I would like to answer that 
20 
question as well as your other questions posed 
21 
here today, Mr. Edwards, l have been instructed 
22 
by my counsel that I must assert my rights under 
23 
the Sixth, Fifth and Fourteenth Amendment. 
24 
Q Did you intentionally touch Jane Doe on 
25 
her person and against her will or without her 
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legal consent? 
2 
MR. PIKE: One second... Form. 
3 
A Without her legal consent? 
4 
Q Yes. 
5 
A Can you tell me what that means? 
6 
Q In order to answer that question, I need 
7 
to explain to you what legal consent means? 
8 
A Yes, sir. 
Q Let's start with this question —
A Can you explain it to me? 
Q Do you believe that a 14-year old child 
can legally consent to sexual interaction with a 
man like you that was over the age of 50? 
MR. PIKE: Form. 
THE WITNESS: Asking for a legal... 
MR. PIKE: Go ahead and invoke? 
A I would like to answer that question, if 
I understood it correctly. However, my attorneys 
have advised me today at least to invoke my 
Sixth, Fifth and Fourteenth Amendment right. 
MR. PIKE: And I think you skipped over 
a question because you went from the first 
question, and the witness was —
MR. EDWARDS: Asking for a definition? 
MR. PIKE: Asking for a definition, so 
480 
1 
he could properly interpret your question 
2 
and attempt to answer it. 
3 
Q I'm understanding that, based on your 
4 
answer, that my question, "Did you intentionally.
5 
touch Jane Doe without her legal consent?" And 
6 
your response, depends on the definition of 
7 
"legal consent:" Is that true? 
8 
MR. PIKE: I think that the witness --
as people regularly do as deponents, ask for 
clarification of a question, and Mr. Epstein 
asked you to clarify what, legal consent' 
was. If you wish to do that, then I guess 
he could potentially understand your 
question. However, if you don't want to do 
that, then I guess we can just move on. 
Q This will provide the answer: How old 
was Jane Doe when you touched her? 
MR. PIKE: Form. Assumes facts not in 
evidence. 
A I — I -- I don't know how to answer 
that question. I'll have to assert my Fifth 
Amendment, Sixth Amendment and Fourteenth 
Amendment right. 
Q Tell me why you're having trouble 
answering the question and I'll clarify the 
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question for you so it will be easier for you to 
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answer. 
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question. 
S 
MR. EDWARDS: His response was he 
6 
doesn't know how to answer the question. I 
7 
want to help him. I want to make sure that 
8 
the jury understands the question and the 
answer. 
MR. PIKE: He invoked the Fifth, Sixth 
and Fourteenth. 
Q Mr. Epstein, did you touch Jane Doe in 
intimate areas of her body when she was a minor 
child? 
MR. PIKE: Form. 
A I would like to answer that question, 
all your questions with respect to Jane Doe, Mr. 
Edwards. However, today at least, my counsel has 
advised me that I must assert my rights under the 
Sixth, Fifth and Fourteenth Amendment. 
Q In fact, didn't you touch Jane Doe in 
intimate areas of her body, including her vagina, 
her breasts, and her buttocks on dozens of 
occasions between February 2003 and June 2005? 
MR. PIKE: Form. 
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However, at least today, my counsel has 
2 . 
instructed melmust assert my rights under the 
3 
Sixth, Fifth and Fourteenth Amendment. 
4 
Q Do you see yourself, Mr. Epstein, as a 
5 
danger to the middle school and high school 
6 
children in the Palm Beach community? 
7 
MR. PIKE: Form. 
B 
A Though I would like to answer that 
question, as well as the other questions that 
you've posed here today, Mr. Edwards, my counsel 
has instructed me I must respond by asserting my 
rights under the Sixth, Fifth and Fourteenth 
Amendment. 
Q When you engaged in illegal sexual 
conduct with Jane Doe, was it your intent to 
cause her severe emotional distress? 
MR. PIKE: Form. 
A Though I would like to answer every 
question with respect to Jane Doe, Mr. Edwards„ 
at least today my counsel has advised me that I 
MUM assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
(..? When you engaged in sexual conduct with 
Jane Doe when she was a minor child, age 14, 15, 
16 and 17, would you agree that you showed 
482 
1 
A Though I would like to answer every 
2 
question about Jane Doe that you've posed here 
3 
today, Mr. Edwards, upon advice of counsel, at 
4 
least today, they've instructed me I must assert 
5 
my rights under the Sixth. Fifth and Fourteenth 
6 
Amendment 
7 
Q Do you agree that the inappropriate 
8 
sexual conduct, that your inappropriate sexual 
9 
conduct towards Jane Doe, was both extreme and 
outrageous? 
MR. PIKE: Form. 
A I would like to answer all of your 
questions with respect to Jane Doe that you've 
posed here today, Mr. Edwards. However, upon 
advice of counsel, they've instructed me that I 
must assert my rights under the Sixth, Fifth and 
Fourteenth Amendment 
Q Do you also agree that your sexual 
interaction with Jane Doe when she was a minor 
child was outrageous and so extreme in degree 
that it should not be tolerated In a civilized 
community? 
MR. PIKE: Form. 
A I would like to respond to all your 
questions with respect to your client, Jane Doe. 
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484 
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reckless disregard with the high probability of 
2 
causing severe emotional distress to Jane Doe? 
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MR. PIKE: Form. 
4 
A Though I would like to answer all your 
5 
questions that you've posed here today regarding 
6 
Jane Doe, on advice of counsel, at least today, 
they've instructed me I must assert my rights 
under the Sixth, Fifth and Fourteenth Amendment. 
Q Mr. Epstein, did you coerce Jane Doe 
into prostitution? 
A ... Again? 
Q Did you coerce Jane Doe into 
prostitution? 
A Can you tell me what you mean by 
"coerce," please? 
Q Tell me, how did you --
A I've asked you a simple question. Can 
you tell me what "coerce" means, please? 
Q The definition or the word "coerce" will 
allow to you answer that question? 
A I'm trying to understand the question. 
MR. PIKE: You're using.. for the 
record, you're using legal terms. 
-Consent," 'coerce." Those are the terms 
you're utilizing in your question. Mr. 
38 (Pages 481 to 484) 
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485 
487 
1 
Epstein is simply asking you what those 
1 
MR. PIKE: Form. 
2 
terms mean in order to facilitate a response 
2 
A I would like to answer every one of your 
3 
or a response coupled with the invocations. 
3 
questions with respect to Jane Doc, Mr. Edwards. 
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He doesn't — he is not a lawyer. He 
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However, today, my counsel has instructed me that 
5 
doesn't understand these legal terms, and he 
S 
I must assert my rights under the Sixth, Fifth 
6 
is asking you for clarification. If you 
6 
and Fourteenth Amendment. 
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want to take those legal terms out of your 
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Q If you answer that question for me, then 
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questions and simplify them, then go ahead 
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I can tell you whether that falls under the 
9 
and do that, but it is fair that he ask what 
9 
definition of coercing her into prostitution. 
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certain words mean. 
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A Is that a question? 
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MR. EDWARDS: I absolutely agree and 
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Q Sure. Can you provide an answer to the 
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want to make sure before I give him the 
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previous question, so I can categorize that as 
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definition, that this question is being 
13 
coercion or noncoercion? 
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asked because the definition will help him 
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MR. PIKE: No, he cannot, because I 
15 
to accurately answer the question, assuming 
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don't know what question is on the table, 
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that would be the only reason he would ask 
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and it is as simple as that. I don't know 
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me a question. 
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what question is on the table. 
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MR. PIKE: As his lawyer, I think that 
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MR. EDWARDS: Sure. 
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the definition of the word would assist him 
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Q Didn't you interact with Jane Doe in a 
20 
in understanding the question a little bit 
0 
sexual manner when she was under the age of 18? 
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better, because, as you know, "coerce" and 
1 
MR. PIKE: Object to the form. This 
22 
"consent" have several meanings, whether or 
2 
question has been asked no less than twice 
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not it be in State court, under the Florida 
3 
during your deposition — 
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State statutes or under federal statutes 
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MR. EDWARDS: I'll agree with that. 
25 
under 2255. I think that any sort of 
5 
MR. PIKE: -- relative to lane Doe and 
486 
488 
1 
response could, you know... tiptoe into the 
1 
I'll object to the form. 
2 
Fifth, Sixth and Fourteenth, and I think Mr. 
2 
A I would like to answer all of your 
3 
Epstein is attempting to... understand your 
3 
questions, Mr. Edwards, especially that 
4 
questions. 
4 
question. However, today, my counsel has advised 
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MR. EDWARDS: I appreciate that. I feel 
5 
me that I must assert my rights under the Sixth, 
6 
like we're getting closer to an answer than 
6 
Fifth and Fourteenth Amendment. 
7 
we have received during this entire 
7 
Q Did you persuade, induce or entke Jane 
8 
litigation, so Fm certainly going to help 
8 
Doe to engage in prostitution when she was an 
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him out here. 
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underage minor child? 
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Q Mr. Epstein, do you then at least agree 
10 
MR. PIKE: Form. 
11 
that you paid Jane Doe money in exchange for 
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A I would like to answer that question but 
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sexual services when she was under the age of 
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my counsel has advised me I must respond by 
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18? 
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invoking my Sixth, Fifth and Fourteenth Amendment 
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MR. PIKE: Form, mischaniezenzes the 
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right 
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witness's testimony, and move to strike. 
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Q Can you tell the jury how it is that 
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A Unfortunately I have to answer that 
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Jane Doe engaged in an act of prostitution with 
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question as I've answered most of your other 
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you? 
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questions here today, Mr. Edwards, which is that 
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MR. PIKE: Form. 
19 
my attorneys, at least today, have advised me 
19 
A On advice of counsel. I'm going to have 
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that I must assert my rights under the Sixth, 
20 
to invoke my Sixth, Fifth and Fourteenth 
21 
Fifth and Fourteenth Amendment. 
21 
Amendment right 
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Q Mr. Epstein, how did you, meaning what 
22 
Q While you were interacting with Jane Doe 
23 
process did you go through, to get Jane Doe to 
23 
in a sexual manner when she was 14 and IS years 
24 
exchange your money for her sexual services when 
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old, did you consider that molestation? 
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she was under the age of 18? 
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MR. PIKE: RCM 
39 (Pages 485 to 4881 
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489 
491 
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1 
A I would like to answer all of your 
2 
questions, Mr. Edwards, with respect to Jane Doe 
3 
and her complaint. However, at least today my 
4 
counsel has advised me that I must assert my 
5 
rights under the Sixth, Fifth and Fourteenth 
6 
Amendment. 
7 
Q While, at the same time you were 
8 
molesting Jane Doe, didn't you tell her that you 
liked the way her young body looked? 
MR. PIKE: Form. 
A I would like to respond to all your 
questions regarding Jane Doe, is the point, Mr. 
Edwards. However today at least my counsel has 
advised me I must assert my rights under the 
Sixth, Fifth and Fourteenth Amendment. 
THE VIDEOGRAPHER: Counsel. 
(Indicating five minutes left on tape.) 
MR. EDWARDS: Okay. 
Q Mr. Epstein do you know George Rush? 
MR. PIKE: Form — I'll withdraw the 
form. Pm sorry. It is not a proper form 
objection. 
A I'm sorry, on advice of counsel I have 
to assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
1 
MR. PIKE: One second... Form. 
2 
A On advice of counsel, I'm going to have 
3 
to respectfully assert my Sixth, Fifth and 
4 
Fourteenth Amendment right. 
5 
Q During that conversation that you had 
6 
with George Rush from The New York Daily News, 
7 
didn't you express to him that you felt you were 
8 
punished criminally for no reason? 
9 
MR. PIKE: Form. 
10 
A Though I would like to answer all of 
11 
your questions, Mr. Edwards, my counsel has 
12 
advised me I must assert my rights under the 
13 
Sixth, Fifth and Fourteenth Amendment. 
14 
Q Didn't you also telt George Rush that a 
15 
more appropriate punishment for your actions with 
16 
these underage minor children would have been a 
17 
100 or 5200 fine? 
18 
MR. PIKE: Form. 
19 
A On advice of counsel I have to assert my 
20 
rights under the Sixth, Filth and Fourteenth 
21 
Amendment. 
2 
Q Tell the jury what you feel would be an 
3 
appropriate penalty for you, for the acts that 
24 
you committed against Jane Doe. 
25 
MR. PIKE Form. 
490 
Q Did you talk to George Rush in the year 
2 
2009 about the allegations of improper sexual 
3 
conduct between you and underage minor children? 
4 
MR. PIKE: Can you repeat the question, 
5 
for me, Madam Court Reporter/ 
6 
MR. EDWARDS: Ian ask it again. 
7 
MR. PIKE: Sure-
8 
Q Did you speak with George Rush in 2009 
9 
specifically about allegations of your 
10 
Interaction with underage minor children in a 
11 
sexual manner? 
12 
A On advice of counsel. I'm going to have 
13 
to assert my rights under the Sixth, Fifth and 
14 
Fourteenth Amendment. 
15 
Q Did you know that the conversation 
16 
between you and New York Daily News reporter 
17 
George Rush was recorded? 
18 
MR. PIKE: Form. 
19 
A On advice of counsel, I'm going to have 
20 
to assert my right under the Sixth. Fifth and 
21 
Fourteenth Amendment 
22 
Q At the time when you spoke with George 
23 
Rush from The New York Daily News in 2009, did he 
24 
tell you that he was recording your statements to 
25 
him? 
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492 
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A Though I would like to very much answer 
2 
that question, on advice of my counsel today, Mr. 
3 
Edwards, I have to Invoke my Sixth, Fifth and 
4 
Fourteenth Amendment right. 
5 
Q In your Affirmative Defenses in the 
6 
complaint of Jane Doe versus Jeffrey Epstein, 
7 
which b Jane Doe, affirmative defense number one 
8 
indicates that Jane Doe consented to and was a 
willing participant in the acts alleged. 
What evidence did you have that Jane Doe 
consented to or was a willing participant in the 
acts that were alleged by Jane Doe against you? 
MR. PIKE: Form. 
A Though I would like to describe the 
evidence that Jane Doc was a willing participant, 
on advice of counsel today, they've instructed me 
I must assert my rights under the Sixth, Fifth 
and Fourteenth Amendment. 
Q At that point in time you're at least 
admitting that there was an interaction between 
you and Jane Doe, correct? 
MR. PIKE Form. Move to strike. 
A On advice of counsel, Pm going to have 
to assert my rights under the Sixth, Fifth and 
Fourteenth Amendment. 
40 (Pages 489 to 492) 
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