EFTA01246464

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1 
obviously it's important because they are the 
1 
MR. KUVIN: The Epstein matter. 
2 
only ones that are answering questions in this 
2 
MR. 
: I instruct the witness not 
3 
case. 
3 
to answer. Objection to the form as compound 
4 
MR. 
Well, people have rights. 
4 
and assumes the existence of Mr. Epstein which, 
5 
People will assert their rights, and I am just 
5 
again, we are not acknowledging, and therefore 
6 
telling you, were getting close to a line 
6 
am instructing her not to answer. 
7 
here. 
7 
THE WITNESS: On the instruction of my 
8 
MR. KUVIN: I think I'm being 
8 
lawyer, I choose to assert my Fifth Amendment 
9 
respectful -- 
9 
right. 
10 
MR. 
You haven't crossed it yet 10 
BY MR. KUVIN: 
11 
because I'm still here, but I'm just warning 
11 
Q. Are you aware that Mr. Epstein negotiated 
12 
you. 
12 
for your immunity from prosecution in the 
13 
Instruct the witness not to answer 
13 
non-prosecution agreement that was entered into with 
14 
any question that presumes existence or 
14 
the United States Attorney's Office for the Southern 
15 
any knowledge of Jeffrey Epstein or any of 
15 
District of Florida? 
16 
his body pans. 
16 
MR. 
: Again, objection to the 
17 
MR. KUVIN: Okay. 
17 
form for the reasons previously stated as to 
18 
THE WITNESS: On the instruction of my 
18 
the standing objection and instruct her not to 
19 
lawyer, I must choose to assert my Fifth 
19 
answer. 
20 
Amendment right. 
20 
THE WITNESS: On the instruction of my 
21 
BY MR. KUVIN: 
21 
lawyer, I must choose to invoke my Fifth 
22 
Q. Do you know whether or not Mr. Epstein has 
22 
Amendment right. 
23 
any identifying characteristics to any of his 
23 
BY MR. KUVIN: 
24 
private genitalia? 
24 
Q. Do you agree with me that 
was 
25 
MR. 
Objection to the form for 
25 
emotionally traumatized as a result of the incidents 
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1 
the reason previously stated, because it 
1 
that occurred Jeffrey E stein's home in 2005? 
2 
presumes that she has any knowledge of who 
2 
MR. 
: Obj=ion to the form. It 
3 
Jeffrey Epstein is or what his body parts look 
3 
assumes any knowledge of M. or any incidents 
4 
like, and I would instruct her not to answer. 
4 
that would have occurred at a home purporting 
5 
THE WITNESS: On the instruction of my 
5 
to belong to a person by the name of Jeffrey 
6 
lawyer, I must choose to assert my Fifth 
6 
Epstein, and instruct her not to answer. 
7 
Amendment right. 
7 
THE WITNESS: Upon instruction from my 
8 
BY MR. KUVIN: 
8 
lawyer, I must choose to invoke my Fifth 
9 
Q. Have you heard anyone other than your 
9 
Amendment right. 
10 
lawyers that have described what any of 
10 
BY MR. KUVIN: 
11 
Mr. Epstein's bod 
arts look like? 
11 
Q. Do you agree with me that ■. was 
12 
MR. 
• Objection to the form. It 
12 
emotionally traumatized as a result of the incidents 
13 
is irrelevant what she's heard from other 
13 
that occurred at Jeffrey E stein's home? 
14 
people, and again, it presumes facts that she's 
14 
MR. 
: Same objection as to the 
15 
not acknowledged. It is compound, and it is 
15 
previous question, and instruct the witness not 
16 
harassing at this point. 
16 
to answer. 
17 
THE WITNESS: On instruction of my lawyer. 13 
THE WITNESS: On the instruction of my 
18 
I must choose to invoke my Fifth Amendment 
18 
lawyer, I must choose to invoke my Fifth 
19 
right. 
19 
Amendment privilege. 
20 
BY MR. KUVIN: 
20 
BY MR. KUVIN: 
21 
Q. Were you consulted with respect to the 
21 
Q. Do ou know Jane Doe No. 102? 
22 
non-prosecution agreement that was entered into with 22 
MR. 
: Instruct the witness not 
23 
the United States Attorneys Office for the Southern 
23 
to answer based on Fifth Amendment privilege. 
24 
District of Florida as it relates to this case? 
24 
THE WITNESS: On instruction of my lawyer,) 
25 
MR. 
Which case? 
25 
I must choose to invoke my Fifth Amendment 
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right. 
1 
in New York? 
2 
BY MR. KUVIN: 
2 
MR. 
Instruct the witness not 
3 
Q. Have you known Jeffrey Epstein to keep 
3 
to answer based on the Fifth Amendment 
4 
underage, under the a e of IS, sex slaves? 
4 
privilege. 
5 
MR. 
: Objection to the form both 
5 
THE WITNESS: On the instruction of my 
6 
as to ambiguity as to what you mean by "sex 
6 
lawyer, I choose to invoke my Fifth Amendment 
7 
slaves," and "keep," also the standing 
7 
right. 
8 
objection as to any knowledge of Mr. Epstein 
8 
BY MR. KUVIN: 
9 
and instruct the witness not to answer. 
9 
Q. Are you aware that various underage girls 
10 
THE WITNESS: On the instruction of my 
10 
brought in from out of the country live at 301 East 
11 
lawyer, I must choose to invoke my Fifth 
11 
66th Street? 
12 
Amendment right. 
12 
MR. 
Objection to the form. 
13 
BY MR. KUVIN: 
13 
It's compound. and instruct the witness not to 
14 
Q. Where do most of the models come from that 
14 
answer. 
15 
are part of MC 
uared Modeling Agency? 
15 
THE WITNESS: On the instruction from my 
16 
MR. 
: Objection to the form. It 
16 
lawyer, I must choose to invoke my Fifth 
17 
assumes knowledge of an entity by the name of 
17 
Amendment right. 
18 
MC Squared Modeling which the witness has not 
18 
BY MR. KUVIN: 
19 
acknowledged and therefore I instruct her not 
19 
Q. You've stayed at that address before, have 
20 
to answer, and the question is compound. 
20 
you not? 
21 
THE WITNESS: On the instruction of my 
21 
MR. 
Instruct the witness not 
22 
lawyer, I must choose to invoke my Fifth 
22 
to answer. 
23 
Amendment privilege. 
23 
THE WITNESS: On the instruction of my 
24 
BY MR. KUVIN: 
24 
lawyer, I must choose to invoke my Fifth 
25 
Q. Who gets visas for the models at MC 
25 
Amendment right. 
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1 
Squared, if ou know? 
1 
BY MR. KUVIN: 
2 
MR. 
: Same, same objection as to 
2 
Q. You've stayed there hundreds of times, 
3 
the previous question, same instruction. 
3 
have you, hundreds of times have you not? 
4 
THE WITNESS: On the instruction of my 
4 
MR. 
Instruct the witness not 
5 
lawyer, I must choose to invoke my Fifth 
5 
to answer. 
6 
Amendment right. 
6 
THE WITNESS: On instruction from my 
7 
BY MR. KUVIN: 
7 
lawyer, I must choose to invoke my Fifth 
8 
Q. Do you work with Jeffrey Epstein to get 
8 
Amendment right. 
9 
visas for out-of-the-country models or models that 
9 
BY MR. KUVIN: 
10 
are -- strike that. 
10 
Q. Are you aware that Mr. Epstein obtains 
11 
Do you work with Jeffrey Epstein to 
11 
visas for girls from out of the country to work as 
12 
get visas for girls that are underage and bring them 
12 
models and then ostitutes them out? 
13 
into the United States so that they can work as 
13 
MR. 
Objection to the form of 
14 
models for MC S, uared? 
14 
the question in that it is ambiguous and it 
15 
MR. 
: Objection to the form and 
15 
assumes numerous facts that have not 
16 
assumes knowledge as to Mr. Epstein and as to 
16 
acknowledged that this witness has any 
17 
MC Squared and other matters that are not 
17 
knowledge of, and the term "prostitutes them 
18 
admitted or acknowledged by this witness. The 
18 
out" is ambiguous, so I would instruct her not 
19 
question is compound. I would instruct her not 
19 
to answer the question. 
20 
to answer. 
20 
THE WITNESS: On the instruction of my 
21 
THE WITNESS: On the instruction from my 
21 
lawyer, I must choose to invoke my Fifth 
22 
lawyer. I must choose to invoke my Fifth 
22 
Amendment right. 
23 
Amendment right. 
23 
BY MR. KUVIN: 
24 
BY MR. KUVIN: 
24 
Q. You know what Radar Online is. do you not? 
25 
Q. Do you know who owns 301 East 66th Street 
25 
MR. 
Instruct the witness not 
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to answer the question based on her Fifth 
1 
THE WITNESS: On the instruction from my 
2 
Amendment privilege. 
2 
lawyer, I choose to invoke my Fifth Amendment 
3 
THE WITNESS: On the instruction of my 
3 
right. 
4 
lawyer, I must choose to invoke my Fifth 
4 
BY MR. KUVIN: 
5 
Amendment right. 
5 
Q. Would you agree with me that Jeffrey 
6 
BY MR. KUVIN: 
6 
Epstein has a list of underage girls that live 
7 
Q. In fact, you were around when 
7 
within a close proximity to all of his different 
8 
Jeffrey Epstein bou ht Radar Online, were you not? 
8 
homes in eve 
different state? 
9 
MR. 
: Objection to the form, 
9 
MR. 
: Objection to the form in 
10 
standing objection as to any knowledge of 
10 
that it assumes Mr. Epstein has homes in every 
11 
Jeffrey Epstein or of Radar Online, and 
11 
single state and that she knows who Mr. Epstein 
12 
instruct the witness not to answer. 
12 
is, and therefore I instruct her not to answer. 
13 
THE WITNESS: On the instruction from my 13 
THE WITNESS: On advice of my lawyer. I 
14 
lawyer, I must choose to invoke my Fifth 
14 
must choose to invoke my Fifth Amendment right. 
15 
Amendment right. 
15 
BY MR. KUVIN: 
16 
BY MR. KUVIN: 
16 
Q. You're aware Mr. Epstein has a home in New 
17 
Q. Are you aware that Jeffrey Epstein 
17 
York. right? 
18 
accessed or obtained underage girls through his 
18 
MR. 
: Instruct the witness not 
19 
Radar connection? 
19 
to answer, and standing objection of knowledge 
20 
MR. 
: Same objection as 
20 
of Mr. Epstein. 
21 
previously stated to the last question and same 
21 
THE WITNESS: On the instruction of my 
22 
instruction. 
22 
lawyer, I must invoke my Fifth Amendment right. 
23 
THE WITNESS: On the instruction from my 23 
BY MR. KUVIN: 
24 
lawyer, I must choose to invoke my Fifth 
24 
Q. Are you aware that he has a home in New 
25 
Amendment privilege. 
25 
Mexico? 
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1 
BY MR. KUVIN: 
1 
MR. 
By he, you mean 
2 
Q. How many different properties does 
2 
Mr. Epstein? 
3 
Jeffrey Epstein own? 
3 
MR. KUVIN: Yeah. 
4 
MR. 
Objection to the form. 
4 
MR. 
Got to make sure the 
5 
standing objection. Instruct the witness not 
5 
question is clear. 
6 
to answer. 
6 
MR. KUVIN: Yes. 
7 
THE WITNESS: On the instruction of my 
7 
MR. 
Standing objection to the 
8 
lawyer, I must choose to invoke my Fifth 
8 
form and instruct the witness not to answer. 
9 
Amendment right. 
9 
THE WITNESS: On the instruction from my 
10 
BY MR. KUVIN: 
10 
lawyer, I must choose to invoke my Fifth 
11 
Q. You've been to all of Jeffrey Epstein's 
11 
Amendment privilege. 
12 
home, have ou not? 
12 
BY MR. KUVIN: 
13 
MR. 
Same objection as 
13 
Q. Are you aware he has a home in the U.S. 
14 
previously stated to the last question. Same 
14 
Virgin Islands? 
15 
instruction. 
15 
MR. 
Same instruction, same 
16 
THE WITNESS: On the instruction from my 
16 
objection. 
17 
lawyer, I must invoke my Fifth Amendment right. 17 
THE WITNESS: On the instruction of my 
18 
BY MR. KUVIN: 
18 
lawyer, I must choose to invoke my Fifth 
19 
Q. You agree with me that Jeffrey Epstein 
19 
Amendment right. 
20 
keeps a list of girls in the nearby areas around all 
20 
BY MR. KUVIN: 
21 
of his homes and ro rties? 
21 
Q. And isn't it true that you kept a list of 
22 
MR. 
Objection to the form, for 22 
underage girls that could service, in other words, 
23 
the standing objection as well as ambiguous as 
23 
give Mr. Epstein naked massages in every place that 
24 
to "nearby." and "all of his properties," so I 
24 
he has one of those homes I just described? 
25 
instruct the witness not to answer. 
25 
MR. 
Same objection as 
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previously stated, the standing objection and 
1 
to Mr. Epstein's house on Palm Beach. you were aware 
2 
instruct her not to answer. 
2 
that they were brought so that Mr. Epstein could 
3 
THE WITNESS: On the instruction of my 
3 
molest them, correct? 
4 
lawyer, I must choose to invoke my Fifth 
4 
MR. 
: Objection to the form as 
5 
Amendment right. 
5 
to knowledge of Mr. Epstein, as to knowledge of 
6 
BY MR. KUVIN: 
6 
any home on Palm Beach. and ambiguous as to the 
7 
Q. Now, you're also aware, are you not, that 
7 
term "molest," and instruct the witness not to 
8 
Jeffrey Epstein would pay other girls to bring 
8 
answer. 
9 
additional underage girls to him for naked massages, 
9 
THE WITNESS: On the instruction from my 
10 
are you not? 
10 
lawyer. I must choose to invoke my Fifth 
11 
MR. 
: Standing objection and 
11 
Amendment right. 
12 
instruct the witness not to answer. 
12 
BY MR. KUVIN: 
13 
THE WITNESS: On the instruction from my 
13 
Q. You're aware that Mr. Epstein raped 
14 
lawyer, I must choose to invoke my Fifth 
14 
several undera e minors in his bedroom? 
15 
Amendment privilege. 
15 
MR. 
: Objection to the form as 
16 
BY MR. KUVIN: 
16 
to knowledge of Mr. Epstein. and also ambiguous 
17 
Q. And, in fact, you frequently would pay 
17 
as to the term "rape." 
18 
other girls to bring additional girls under the age 
18 
THE WITNESS: On the instruction of my 
19 
of 18 to Mr. Epstein for naked massages? 
19 
lawyer, I must choose to invoke my Fifth 
20 
MR. 
: Objection to the form, 
20 
Amendment rights. 
21 
standing objection as to Mr. Epstein. also as 
21 
BY MR. KUVIN: 
22 
to any knowledge of any naked massages by 
22 
Q. Do ou know what the term "rape" means? 
23 
anybody to anybody. Instruct the witness not 
23 
MR. 
: Not as you used it. If 
24 
to answer. 
24 
you want to tell us what you mean by when you 
25 
THE WITNESS: On the instruction of my 
25 
used it, we'll be happy to answer --
Page 174 
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lawyer, I choose to invoke my Fifth Amendment 
1 
MR. KUVIN: I want to know if --
2 
right. 
2 
MR. 
: -- or evaluate your 
3 
BY MR. KUVIN: 
3 
question. 
4 
Q. And there was a complete list of girls, 
4 
MR. KUVIN: I want to know if she has her 
5 
underage girls, that was stored on Mr. Epstein's 
5 
own definition of what the phrase or word 
6 
computer s stem: isn't that true? 
6 
"rape" means, so that we can use her definition 
7 
MR. 
: Objection to the form. 
7 
of that word. I want to make sure it's 
8 
It's ambiguous as to what a complete list is, 
8 
complete) unambi uous.
9 
and also a standing objection to any knowledge 
9 
MR. 
: Your asking the question. 
10 
of Mr. Epstein, and instruct the witness not to 
10 
If you want to define the term, she'll respond 
11 
answer. 
11 
to your question. 
12 
THE WITNESS: On the instruction from my 12 
BY MR. KUVIN: 
13 
lawyer, I must choose to invoke my Fifth 
13 
Q. Do you what the term or word "rape" means? 
14 
Amendment privilege. 
14 
A. Yes. 
15 
BY MR. KUVIN: 
15 
Q. Okay. What is your understanding of that 
16 
Q. In fact, you've seen the list of underage 
16 
word? 
17 
girls that exists on Mr. Epstein's computer, have 
13 
MR. 
: Now, we're not answering 
18 
you not? 
18 
that question. It's your term. It's your 
19 
MR. 
Objection to the form, 
19 
question. If you want to define it. you can go 
20 
standing objection. 
20 
ahead and define it. 
21 
THE WITNESS: On the instruction from my 21 
MR. KUVIN: Well, I beg --
22 
lawyer, I must choose to invoke my Fifth 
22 
MR. 
: If you want to give her 
23 
Amendment right. 
23 
specifics as to what she -- you can define it. 
24 
BY MR. KUVIN: 
24 
MR. KUVIN: I beg to differ with you. and 
25 
Q. When underage minor females were brought 25 
I don't know that that's a proper objection. 
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1 
I'm askin: her her understanding of the word. 
1 
or vaginal penetration or union with the sexual 
2 
MR. 
: And I am instructing her 
2 
organ of another, or oral, anal or vaginal 
3 
not to answer it because that question is not 
3 
penetration of another with any other object, 
4 
5 
likely to lead to discoverable evidence. It's 
simply meant to harass her. And you can define 
4 
5 
or with an object. Excuse me. All right? 
MR. 
Okay. 
6 
the term in your question. 
6 
BY MR. KUVIN: 
7 
MR. KUVIN: Well, with all due respect, 
7 
Q. Do you understand that definition as I 
8 
it's certainly not to harass if there have been 
8 
have explained it to you. or would you like me to 
9 
girls that were alle in that they were raped. 
9 
read it again? 
10 
MR. 
: Well, you define what you 10 
A. Read it again, please. 
11 
mean by when you say that they allege that they 
11 
Q. Absolutely. Florida law defines "rape" as 
12 
have been raped. and she will be happy to 
12 
oral, anal or vaginal penetration by, or union with 
13 
evaluate your question. 
13 
the sexual organ of another: or oral, anal or 
14 
MR. KUVIN: And that's what I'm trying to 
14 
vaginal penetration by another with any object. And 
15 
understand. 
15 
obviously that is without the other's consent. 
16 
MR. 
: She's not going to 
16 
A. You did not sot that.
17 
speculate on what you mean when you frame a 
17 
MR. 
Okay. 
18 
word in your question. 
18 
BY MR. KUVIN: 
19 
MR. KUVIN: That's exactly what I'm trying 
19 
Q. Adding without the other's consent, 
20 
to do. I'm trying to make sure that we are 
20 
obviously, to that definition. 
21 
using the same definition, so I would like to 
21 
Now, let's use that definition for 
22 
use her definition of the word. 
22 
"rape." because that's as it's defined by Florida 
23 
MR. 
: Right. She's not going to 
23 
law. Using that definition, are you aware, as you 
24 
answer it, so you can either move on we can 
24 
sit here today, that Jeffrey Epstein has raped 
25 
stop. 
25 
underage girls? 
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1 
MR. KUVIN: Okay. So you're instructing 
1 
MR. 
Standing objection to the 
2 
her not to answer the . uestion? 
2 
form of the question, and I would instruct the 
3 
MR. 
: I am instructing her not 
3 
witness not to answer. 
4 
to answer the question for the third time. 
4 
THE WITNESS: On the instruction of my 
5 
MR. KUVIN: Okay. I just want to be 
5 
lawyer, I must choose to invoke my Fifth 
6 
clear. 
6 
Amendment right. 
7 
MR. GARCIA: What's the legal objection? 
7 
BY MR. KUVIN: 
8 
MR. 
: I've already stated what 
8 
Q. Are you aware as ou sit here today that 
9 
my legal objection is. It's meant solely for 
9 
Jeffrey Epstein ra d 
? 
10 
harassment. It's not likely to lead to 
10 
MR. 
Objection to the form. 
11 
discoverable evidence. 
11 
The question assumes that he did, or that she 
12 
BY MR. KUVIN: 
12 
has any knowledge of whether he did, so I 
13 
Q. Okay. For the purpose of my question, I 
13 
instruct the witness not to answer. 
14 
would like to, because your attorney won't allow you 14 
THE WITNESS: On the instruction of my 
15 
to define the word "rape," I would like you to use 
15 
lawyer, I must choose to invoke my Fifth 
16 
the word and understand the word "rape" to mean 
16 
Amendment privilege. 
17 
sexual contact with an individual, including 
17 
BY MR. KUVIN: 
18 
sexual -- well, let me clarify here. Hang on. You 
18 
Q. Are you aware as you sit here today, that 
19 
know what, if we're going to do it, let's do it 
19 
Jeffrey Epstein -- well, let me rephrase that. 
20 
21 
22 
right since we can't use our definition. 
MR. 
: You can use whatever 
definition you like, but you need to tell me 
20 
21 
22 
You are aware, are you not, a
sit here toda . that Jeffrey Epstein raped? 
MR. 
Objection to the form as 
23 
what it is. 
23 
leading, and also again assumes -- your 
24 
MR. KUVIN: Let's use the definition of 
24 
question assumes that she knows things that 
25 
"rape" as defined by Florida law as oral, anal 
25 
she's not acknowledoed that she knows or 
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doesn't know, and I instruct her not to answer. 
1 
MR. 
Same objection as 
2 
THE WITNESS: On the instruction of my 
2 
previously stated as to ambiguity and compound, 
3 
lawyer, I must choose to invoke my Fifth 
3 
and instruct the witness not to answer. 
4 
Amendment right. 
4 
THE WITNESS: On the instruction of my 
5 
BY MR. KUVIN: 
5 
lawyer, I must choose to invoke my Fifth 
6 
Q. Do you agree that Jeffrey Epstein has 
6 
Amendment right. 
7 
raped hundreds of irls under the age of 18? 
7 
BY MR. KUVIN: 
8 
MR. 
: Objection to the form, 
8 
Q. Have you ever had sexual contact in any 
9 
standing objection as to any knowledge of 
9 
manner with any underage girls that were brought to 
10 
Jeffrey Epstein. Instruct the witness not to 
10 
Mr. Epstein's home? 
11 
answer. 
11 
MR. 
Objection to the form. 
12 
THE WITNESS: On the instruction of my 
12 
Standing objection, compound, instruct the 
13 
lawyer, I must choose to invoke my Fifth 
13 
witness not to answer. 
14 
Amendment privilege. 
14 
THE WITNESS: On the instruction of my 
15 
BY MR. KUVIN: 
15 
lawyer, I must choose to invoke my Fifth 
16 
Q. You're aware, are you not, that 
16 
Amendment right. 
17 
Jeffrey Epstein has raped hundreds of girls under 
17 
BY MR. KUVIN: 
18 
the age of 17? 
18 
Q. Did you keep an appointment book for 
19 
MR. 
Objection to the form as 19 
Mr. Epstein? 
20 
leading. Instruct the witness not to answer 
20 
MR. 
Objection to the form. 
21 
for the reasons previously stated to the last 
21 
standing objection. Instruct the witness not 
22 
the question. 
22 
to answer. 
23 
THE WITNESS: On the instruction of my 
23 
THE WITNESS: On the instruction of my 
24 
lawyer, I must choose to assert my Fifth 
24 
lawyer, I must choose to invoke my Fifth 
25 
Amendment right. 
25 
Amendment right. 
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1 
BY MR. KUVIN: 
1 
BY MR. KUVIN: 
2 
Q. You're aware, as you sit here today, are 
2 
Q. Did you preserve a document that shows the 
3 
you not, that Jeffrey Epstein has raped hundreds of 
3 
appointments ke for Mr. Epstein in the years 2004?
4 
girls under the a e of 16? 
4 
MR. 
Objection to the form, the 
5 
MR. 
: Objection to the form. 
5 
standing objection, compound question and 
6 
Standing objection. It assumes numerous facts 
6 
instruct the witness not to answer. 
7 
mixed in a compound question, and therefore I 
7 
THE WITNESS: On the instruction of my 
8 
instruct the witness not to answer. 
8 
lawyer, I must choose to invoke my Fifth 
9 
THE WITNESS: On the instruction of my 
9 
Amendment right. 
10 
lawyer, I must choose to assert my Fifth 
10 
BY MR. KUVIN: 
11 
Amendment right. 
11 
Q. Same question with respect to any 
12 
BY MR. KUVIN: 
12 
appointments ke for Mr. Epstein in 2005.
13 
Q. Isn't it true that Mr. Epstein had at 
13 
MR. 
Same objection previously 
14 
least one or two scheduled appointments for sex with 14 
stated to the previous question. 
15 
underage girls every day while he was here in Palm 
15 
THE WITNESS: On the instruction of my 
16 
Beach Coun in the ear 2005? 
16 
lawyer, I must choose to invoke my Fifth 
17 
MR. 
Objection to the form. 
17 
Amendment right.
18 
It's compound, standing objection as well, and 
18 
BY MR. KUVIN: 
19 
instruct the witness not to answer. 
19 
Q. Same with respect to any appointments kept 
20 
THE WITNESS: On the instruction of my 
20 
for Mr. Epstein in 2006. 
21 
lawyer, I must choose to invoke my Fifth 
21 
MR. 
Same objection as 
22 
Amendment right. 
22 
previously stated to the last two questions. 
23 
BY MR. KUVIN: 
23 
THE WITNESS: On the instruction of my 
24 
Q. Did you actually locate underage girls in 
24 
lawyer. I must choose to invoke my Fifth 
25 
Palm Beach for Jeffrey Epstein to rape? 
25 
Amendment privilege. 
46 (Pages 181 to 1 8 4) 
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Page 185 
Page 187 
1 
BY MR. KUVIN: 
1 
MR. 
Yeah, whenever you get to 
2 
Q. Have you provided any appointment books to 
2 
a convenient point in your questioning. I think 
3 
anyone with respect to 
intments for Mr. Epstein? 
3 
we can use a break. If you're in the middle of 
4 
MR. 
Same standing objection as 
4 
something, I don't want to stop you. 
5 
to knowledge of Mr. Epstein. The question is 
5 
MR. KUVIN: No, this is fine. We can take 
6 
compound and instruct the witness not to 
6 
a quick break. Five minutes? 
7 
answer. 
7 
MR. 
: Yes, thank you. 
8 
THE WITNESS: On the instruction of my 
8 
THE VIDEOGRAPHER: We're now off the 
9 
lawyer. I must choose to invoke my Fifth 
9 
record. It is 2:08 p.m. 
10 
Amendment right. 
10 
(A brief recess was held.) 
11 
BY MR. KUVIN: 
11 
12 
Q. Would Ep -- Mr. Epstein pay the underage 
12 
13 
girls more money if they took off both their tops 
13 
14 
and their bottoms? 
14 
15 
MR. 
Objection to the form. 
15 
16 
standing objection. Instruct the witness not 
16 
17 
to answer. 
17 
18 
THE WITNESS: On the instruction of my 
18 
19 
lawyer, I must choose to invoke my Fifth 
19 
20 
Amendment right. 
20 
21 
BY MR. KUVIN: 
21 
22 
Q. Would Mr. Epstein pay the underage girls 
22 
23 
more if the would actually touch his penis? 
23 
24 
MR. 
Same instruction, same 
24 
25 
objection. 
25 
Page 186 
1 
THE WITNESS: On the instruction of my 
2 
lawyer, I must choose to assert my Fifth 
3 
Amendment right. 
4 
BY MR. KUVIN: 
S 
Q. Would Mr. Epstein pay the underage girls 
6 
more if he would allow them to have sex with them? 
7 
MR. 
Can you restate that 
8 
again? 
9 
MR. KUVIN: Yes. 
10 
BY MR. KUVIN: 
11 
Q. Would Mr. Epstein pay the underage girls 
12 
more money if they would allow him to have sex with 
13 
them? 
14 
MR. 
Objection to the form. 
15 
standing objection. Instruct the witness not 
16 
to answer. 
17 
THE WITNESS: On the instruction of my 
18 
lawyer, I must invoke my Fifth Amendment right. 
19 
MR. KUVIN: Hang on one second. You can 
20 
stop at an time I'll si n it. 
21 
MR. 
Mr. Kuvin, I don't know i 
22 
you're getting to a convenient breaking point 
23 
but --
24 
MR. KUVIN: Do you want to take a quick 
25 
one? 
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