EFTA01246511

Page 267 
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1 
fact, you and Jeffrey Epstein engaged in criminal 
1 
MR. 
Same instruction. 
2 
activity as it relates to Jane Doe No. 8? 
2 
THE WITNESS: Upon the instruction of my 
3 
MR. 
: Instruct the witness not 
3 
lawyer. I must invoke my Fifth Amendment right. 
4 
to answer the question. 
4 
BY MR. 
. 
5 
MR. HOROWITZ: Do you have the premarked 
5 
Q. And did you place at least some of the 
6 
7 
Exhibit 5, b an chance? 
MR. 
: I gave it back to 
6 
7 
calls reflected on that phone bill with an eye 
toward arranging for minor children under the age of 
8 
Mr. Kuvin. 
8 
18 to come to Jeffrey Epstein's home for his sexual 
9 
MR. HOROWITZ: I'll hand it back to you. 
9 
pleasure? 
10 
Sorry. 
10 
MR. 
Object to the form as 
11 
BY MR. HOROWITZ: 
11 
compound and a standing objection, and also 
12 
Q. Let me ask Ms. 
to take a look at 
12 
instruct the witness not to answer based on 
13 
what's been 'remarked as Exhibit 5. 
13 
Fifth Amendment. 
14 
MR. 
: Do you want us to look at 
14 
THE WITNESS: Upon the instruction of my 
15 
the whole thing? 
15 
lawyer, I must invoke my Fifth Amendment right. 
16 
MR. HOROWITZ: Well, if we're going to 
16 
BY MR. HOROWITZ: 
17 
take more than a -- yeah, we can go off record 
17 
Q. And with respect to the phone calls 
18 
19 
if she'sgoing to look at the whole thing. 
MR. 
: If you want to ask her 
19 
18 
reflected on the bill which you received, did you 
answer some of those phone calls with an eye toward 
20 
about every page, we'll look at every page. 
20 
arranging for procuring underage girls to come to 
21 
But if you want to just ask some general 
21 
Jeffrey Epstein's home for his sexual pleasure? 
22 
questions. perhaps then we can just -- 
22 
MR. 
: Object to the, object to 
23 
MR. HOROWITZ: Well, if you know that 
23 
the form. Instruct the witness not to answer, 
24 
you're goin to assert the Fifth Amendment -- 
24 
based on Fifth Amendment privilege. 
25 
MR. 
: I doubt we're answering 
25 
THE WITNESS: Upon the instruction of my 
Page 268 
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1 
any questions about it, but go on ahead. And 
1 
lawyer. I must invoke my Fifth Amendment right. 
2 
if we need to take a break, we'll take a break. 
2 
BY MR. HOROWITZ: 
3 
BY MR. HOROWITZ: 
3 
Q. Do, does the phone, does the premarked 
4 
Q. Okay. Have you had enough of a look at 
4 
Exhibit 5 reflect phone calls wherein you arranged 
5 
those records to determine whether those are the 
5 
for Jeffrey Epstein to meet children under the age 
6 
telephone records for the cellphone that you used 
6 
of 18 for his sexual • leasure? 
7 
during the time periods set forth on those phone 
7 
MR. 
: Objection to the form. 
8 
bills? 
8 
It's a compound question, instruct the witness 
9 
MR. 
Instruct the witness not 
9 
not to answer based on the Fifth Amendment. 
10 
to answer the question based on the Fifth 
10 
THE WITNESS: Upon the instruction of my 
11 
Amendment. 
11 
lawyer, I must invoke my Fifth Amendment right. 
12 
THE WITNESS: Upon the instruction of my 
12 
BY MR. HOROWITZ: 
13 
lawyer, I must invoke my Fifth Amendment right. 13 
Q. Would it be accurate to describe Jeffrey 
14 
BY MR. HOROWITZ: 
14 
Epstein's home between the years 2001 and 2006 as a 
15 
Q. Are the phone calls that the telephone 
15 
house of horrors? 
16 
bills reflect as having been made phone calls that 
16 
MR. 
: Object to the form of the 
17 
were 
b 
our 
17 
Instruct the witness not to answer. 
18 
placed 
MR. 
Same instruction. 
18 
question. 
BY MR. HOROWITZ:
19 
THE WITNESS: On the instruction of my 
19 
Q. Would you say that childhood sexual abuse 
20 
lawyer, I must invoke my Fifth Amendment right. 20 
was committed at Jeffrey Epstein's home every day 
21 
BY MR. HOROWITZ: 
21 
that he was in Palm Beach County between the years 
22 
Q. Okay. Are the phone calls that the phone 
22 
2001 and 2006? 
23 
bill reflects as having been received on that 
23 
MR. 
: Object to the form. It 
24 
telephone line phone calls that you, in fact. 
24 
assumes she knows anything about Jeffrey 
25 
received? 
25 
Epstein or his home or when he i. in Palm Beach 
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County, so instruct her not to answer the 
1 
compound and assumes facts not within the 
2 
question. 
2 
knowledge of this witness. Instruct the 
3 
THE WITNESS: Upon the instruction of my 
3 
witness not to answer based on the Fifth 
4 
lawyer. I choose to assert my Fifth Amendment 
4 
Amendment. 
5 
right. 
5 
THE WITNESS: Upon the instruction of my 
6 
MR. HOROWITZ: No other questions. 
6 
lawyer, I must invoke my Fifth Amendment right. 
7 
MR. 
Thank you. Who is next 
7 
BY MR. WEISSING: 
8 
up? 
8 
Q. Beginning in August of 2002, are you aware 
9 
MR. KUVIN: Next? Do you want to go next? 
9 
that M. was coerced by Jeffrey Epstein into sexual 
10 
MS. EZELL: Do you have a trial date? You 
10 
conduct? 
11 
may want to go because you have a trial date. 
11 
MR. 
: Objection to form. 
12 
MR. WEISSING: I do. 
12 
leading. Well. it's compound. Instruct the 
13 
MR. KUVIN: Yeah, you do. Whenever you're 
13 
witness not to answer based on the Fifth 
14 
ready. Go ahead. After you. 
14 
Amendment. The question is also ambiguous as 
15 
MR. 
• Whenever you're ready. Is 15 
to coercion. 
16 
our videographer ready. 
16 
THE WITNESS: Upon the instruction of my 
17 
THE VIDEOGRAPHER: Oh, yeah. Were all 
17 
lawyer, I must assert my Fifth Amendment right. 
18 
good. 
18 
MR. WEISSING: Are you aware that between 
19 
MR. 
We're all good? 
19 
August 2002 and September of 2005, 
had 
20 
THE VIDEOGRAPHER: We never went off the 20 
sexual conduct with Jeffrey Epstein? 
21 
record. 
21 
MR. 
: Object to the form, 
22 
CROSS t
22 
standing objection. Instruct the witness not 
23 
BY MR. WEISSING: 
23 
to answer. 
24 
Q. Ms.= 
Mau Weissing here. Do you 
24 
THE WITNESS: On the instruction of my 
25 
know..? 
25 
lawyer, I must invoke my Fifth Amendment right. 
Page 272 
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1 
MR. 
Instruct the witness not 
1 
BY MR. WEISSING: 
2 
to answer the question based on Fifth 
2 
Q. Okay. Are you aware that between August 
3 
Amendment. 
3 
2002 and September of 2005, Jeffrey Epstein engaged 
4 
THE WITNESS: On the instruction of my 
4 
in fondling and inappropriate illegal sexual 
5 
lawyer, I must invoke my Fifth Amendment right. 
5 
touching of 
? 
6 
BY MR. WEISSING: 
6 
MR. 
Objection to the form. 
7 
Q. Have ou ever met..? 
7 
standing objection and ambiguous as to 
8 
MR. 
Object to the form. I 
8 
terminology. Instruct the witness not to 
9 
believe that's been asked and answered several 
9 
answer. 
10 
times. Well, not answered several times. But 
10 
THE WITNESS: Upon the instruction of my 
11 
I'll instruct her once again not to answer the 
11 
lawyer, I must invoke my Fifth Amendment right. 
12 
question. 
12 
BY MR. WEISSING: 
13 
BY MR. WEISSING: 
13 
Q. Are you aware that during that same 
14 
Q. Are you aware that.. was 14 years of 
14 
period, that Jeffrey Epstein ensascl in oral sex or 
15 
age when she first came to Jeffrey Epstein's mansion 
10 
other sexual misconduct with M.? 
16 
in 2002? 
16 
MR. 
Same objection as the 
17 
MR. 
Object to the form. 
17 
previous question and same instruction to the 
18 
Instruct the witness not to answer. 
18 
witness. 
19 
THE WITNESS: On the instruction of my 
19 
THE WITNESS: On the instruction of my 
20 
lawyer, I must invoke my Fifth Amendment right. 20 
lawyer, I must invoke my Fifth Amendment right. 
21 
BY MR. WEISSING: 
21 
BY MR. WEISSING: 
22 
Q. Are you aware that at all times that -- 
22 
Q. Are you aware that in that same time 
23 
from 2002 to 2005, when 
came to his mansion. 
23 
period that Jeffrey Epstein masturbated in the 
24 
she was a minor child? 
24 
presence 
of. 
25 
MR. 
Object to the form. It's 
25 
MR.
Objection to the form. 
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standing objection and instruct the witness not 
1 
answer as well as compound. 
2 
to answer. 
2 
THE WITNESS: At the instruction of my 
3 
THE WITNESS: Upon the instruction of my 
3 
lawyer, I must invoke my Fifth Amendment right. 
4 
lawyer. I must invoke my Fifth Amendment right. 
4 
BY MR. WEISSING: 
5 
BY MR. WEISSING: 
5 
Q. At all times that.. was engaged with 
6 
Q. Are you aware that for all of her 
6 
the behaviors with Jeffrey Epstein, did he know that 
7 
behaviors with Jeffrey Epstein that.. was paid by 
7 
she was a minor child? 
8 
him? 
8 
MR. 
: Objection to the form, 
9 
MR. 
: Objection to the font 
9 
calls for speculations as to Mr. Epstein's 
10 
leading, as well as the standing objection, and 
10 
mindset, also assumes she knows Mr. Epstein. so 
11 
instruct the witness not to answer. 
11 
I would object as compound and instruct her not 
12 
THE WITNESS: Upon the instruction of my 
12 
to answer. 
13 
lawyer, I must invoke my Fifth Amendment right. 
13 
THE WITNESS: At the instruction of my 
14 
BY MR. WEISSING: 
14 
lawyer, I must invoke my Fifth Amendment right. 
15 
Q. Did you pay.. for any of her work for 
15 
BY MR. WEISSING: 
16 
Jeffrey Epstein? 
16 
Q. At all times during her interaction with 
17 
MR. 
: Objection to the form. 
17 
Jeffrey Epstein did Jeffrey Epstein tell you that 
18 
Instruct the witness not to answer. 
18 
he knew that 
was a minor child? 
19 
THE WITNESS: On the instruction of my 
19 
MR. 
Objection to form. 
20 
lawyer. I must invoke my Fifth Amendment right. 
20 
THE WITNESS: At the instruction of my 
21 
BY MR. WEISSING: 
21 
lawyer, I must invoke my Fifth Amendment right. 
22 
Q. Are you aware that Jeffrey Epstein. during 
22 
BY MR. WEISSING: 
23 
the period of August 2nd -- 2002 and September of 
23 
Q. Did Jeffrey Epstein tell you that he 
24 
2005 committed numerous criminal and sexual offenses 24 
engaged in numerous sexual activities with M. 
25 
against a minor child? 
25 
between the periods of August 2nd and September --
Page 276 
Page 278 
1 
MR. 
Objection to the form. 
1 
August 2002 and Se ember 2005? 
2 
Calls for a legal conclusion. It's compound 
2 
MR. 
: Objection to the form. 
3 
and ambiguous and instruct the witness not to 
3 
THE WITNESS: At the instruction of my 
4 
answer. 
4 
lawyer, I must invoke my Fifth Amendment right. 
5 
THE WITNESS: Upon the instruction of my 
5 
BY MR. WEISSING: 
6 
lawyer, I must invoke my Fifth Amendment right. 
6 
Q. Did Jeffrey E • stein tell ou that he had 
7 
BY MR. WEISSING: 
7 
sexual) ex loited 
8 
Q. Are you aware that due to the influence of 
I 
9 
Jeffre E stein's interaction with 
9 
MR. 
: Objection to form. It's 
■ 
10 
ambiguous. calls for legal conclusions, and 
11 
MR. 
Objection to the form, 
11 
it's compound. Instruct the witness not to 
12 
leading. Requires speculation. is ambiguous 
12 
answer based on Fifth Amendment privilege. 
13 
and compound, and instruct the witness not to 
13 
THE WITNESS: On the instruction of my 
14 
answer. 
14 
lawyer, I must assert my Fifth Amendment right. 
15 
THE WITNESS: On the instruction of my 
15 
BY MR. WEISSING: 
16 
lawyer, I must invoke my Fifth Amendment right. 16 
Q. Did Jeffrey Epstein ever tell you that he 
17 
BY MR. WEISSING: 
17 
was harmin 
intentional) 
..? 
18 
Q. At all times when ■. 
was engaged with 
18 
MR. 
: Objection to the form. It 
19 
Jeffrey Epstein. he knew that she was a minor child. 
19 
assumes knowledge of Jeffrey Epstein. Instruct 
20 
MR. 
Is that a question or a 
20 
her not to answer. 
21 
statement? 
21 
THE WITNESS: On the instruction of my 
22 
BY MR. WEISSING: 
22 
lawyer, I must exert my Fifth Amendment right. 
23 
Q. Correct? 
23 
BY MR. WEISSING: 
24 
MR. 
Objection to the form, 
24 
Q. Did you know that Jeffrey Epstein's 
25 
leading. I'll instruct the witness not to 
25 
behavior was causing injury. pain and suffering. and 
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emotional trauma to 
9 
1 
ambiguous as to "school children." Instruct 
2 
MR. 
Objection to the form, 
2 
the witness not to answer. 
3 
calls for speculation and is otherwise a 
3 
THE WITNESS: At the instruction of my 
4 
standing objection. 
4 
lawyer, I must invoke my Fifth Amendment right. 
5 
THE WITNESS: At the instruction of my 
5 
BY MR. WEISSING: 
6 
lawyer, I must invoke my Fifth Amendment right. 
6 
Q. With regard to the young girls who you 
7 
BY MR. WEISSING: 
7 
contacted to set up sexual encounters with 
8 
Q. Were you aware that Jeffrey Epstein was 
8 
Jeffrey Epstein, were they between the ages, school 
9 
using his wealth and the proximity of his mansion to 
9 
girls between the axes of 13 and 17 years of age? 
10 
lead young underage girls into having sexual 
10 
MR. 
: Objection to the form. 
11 
behaviors with him? 
11 
Its compound and instruct the witness not to 
12 
MR. 
Objection to form, 
12 
answer. 
13 
standing objection and ambiguous. 
13 
THE WITNESS: Upon the instruction of my 
14 
THE WITNESS: At the instruction of my 
14 
lawyer, I must invoke my Fifth Amendment right. 
15 
lawyer I must invoke my Fifth Amendment right. 
15 
BY MR. WEISSING: 
16 
BY MR. WEISSING: 
16 
Q. Now, do you believe that Jeffrey Epstein 
17 
Q. Were you
scheduling girls to 
17 
presents a clear danger to female children in this 
18 
meet with Jeffry E stein? 
18 
community? 
19 
MR. 
Objection to form, 
19 
MR. 
Objection to form, 
20 
standing objection. 
20 
standing objection. 
21 
THE WITNESS: At the instruction of my 
21 
THE WITNESS: On the instruction of my 
22 
lawyer, I must invoke my Fifth Amendment right. 22 
lawyer, I must invoke my Fifth Amendment right. 
23 
BY MR. WEISSING: 
23 
BY MR. WEISSING: 
24 
Q. In scheduling girls to meet with 
24 
Q. Did Jeffrey Epstein tell you that he was 
25 
Jeffrey Epstein, did you ever call any escort 
25 
intentionally engaging in sexual misconduct with 
Page 280 
Page 282 
1 
services? 
1 
.. 
in an effort to hun her? 
2 
MR. 
Objection to form. 
2 
MR. 
: Objection to the form, 
3 
standing objection. 
3 
standing objection and also ambiguous. 
4 
THE WITNESS: At the instruction of my 
4 
THE WITNESS: On the instruction of my 
5 
lawyer I must invoke my Fifth Amendment right 
5 
lawyer, I must invoke my Fifth Amendment right. 
6 
BY MR. WEISSING: 
6 
BY MR. WEISSING: 
7 
Q. In scheduling sexual encounters for 
7 
Q. Did Jeffrey Epstein tell
 that he knew 
8 
Jeffrey Epstein, did you ever contact any, any known 
8 
that his sexual behavior with MI. was, in fact, 
9 
prostitutes? 
9 
injuring her? 
10 
MR. 
Objection to form. 
10 
MR. 
: Objection to form. 
11 
THE WITNESS: At the instruction of my 
11 
THE WITNESS: At the instruction I must 
12 
lawyer, I must invoke my Fifth Amendment right. 12 
invoke my Fifth Amendment right. 
13 
BY MR. WEISSING: 
13 
BY MR. WEISSING: 
14 
Q. With regard to the girls who were 
14 
Q. Were you aware that Jeffrey Epstein 
15 
scheduled, these were basically school children, 
15 
touched.. with -- in her, in the intimate areas 
16 
correct? 
16 
of her body? 
17 
MR. 
Objection to form, 
17 
MR. 
Objection to the form, 
18 
leading, and also a standing objection. 
18 
both compound, standing objection and 
19 
THE WITNESS: At the instruction of my 
19 
ambiguous. 
20 
lawyer, I must invoke my Fifth Amendment right. 20 
THE WITNESS: On the instruction of my 
21 
BY MR. WEISSING: 
21 
lawyer, I must invoke my Fifth Amendment right. 
22 
Q. Were the girls who you contacted on behalf 
22 
BY MR. WEISSING: 
23 
of Jeffrey Epstein, school children in this 
23 
Q. Are ou aware that Jeffrey Epstein 
24 
community? 
24 
penetrated 
% va ina? 
25 
MR. 
Objection to form and 
25 
MR. 
: Obection to the form. 
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standing objection. 
1 
MR. 
Objection to the form in 
2 
THE WITNESS: At the instruction of my 
2 
that assumes knowledge of Jeffrey Epstein or 
3 
lawyer, I must invoke my Fifth Amendment right. 
3 
where his mansion is or what goes on in his 
4 
BY MR. WEISSING: 
4 
mansion, so instruct her not to answer it. 
5 
Are you aware that Jeffrey Epstein touched 
5 
THE WITNESS: On the instruction of my 
6 
in the intimate portions of her body on dozens 
6 
lawyer, I must invoke my Fifth Amendment right. 
7 
of occasions between August 2002 and September of 
7 
BY MR. WEISSING: 
8 
2005? 
8 
Q. Between August 2002 and S tember of 2005, 
9 
MR. 
Objection to the form, 
9 
did Jeffrey Epstein coerce or engage. in sexual 
10 
standing objection. 
10 
activity at his mansion? 
11 
THE WITNESS: At the instruction of my 
11 
MR. 
Objection to form and 
12 
lawyer, I must invoke my Fifth Amendment right. 12 
ambiguous as to "coercion." 
13 
BY MR. WEISSING: 
13 
THE WITNESS: On the instruction of my 
14 
Q. Did Jeffrey Epstein tell you that he had 
14 
lawyer, I must invoke my Fifth Amendment right. 
15 
touched 
in the intimate portions of her body 
15 
BY MR. WEISSING: 
16 
and penetrated her body with a design to injure her 
16 
Q. Between August 2002 and September 2005, 
17 
between Au ust 2002 and September of 2005? 
17 
did Jeffrey Epstein engage in sexual misconduct with 
18 
MR. 
Objection to the form as 
18 
19 
compound and instruct the witness not to 
19 
MR. 
Objection to the form and 
20 
answer. 
20 
ambiguous as to "sexual misconduct." 
21 
THE WITNESS: On the instruction of my 
21 
THE WITNESS: At the instruction of my 
22 
lawyer, I must invoke my Fifth Amendment right. 22 
lawyer. I must invoke my Fifth Amendment right. 
23 
BY MR. WEISSING: 
23 
BY MR. WEISSING: 
24 
Q. Do ou know who M. is? 
24 
Q. Between August 2002 and September of 2005 
25 
MR. 
Instruct the witness not 
25 
did Jeffrey Epstein engage in conduct with M. for 
Page 284 
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1 
2 
to answer based on the Fifth Amendment. 
THE WITNESS: On the instruction of my 
1 
2 
his sexual 
atification? 
MR. 
: Objection to form. 
3 
lawyer, I must invoke my Fifth Amendment right. 
3 
THE WITNESS: At the instruction of my 
4 
BY MR. WEISSING: 
4 
lawyer I must invoke my Fifth Amendment right. 
5 
Q. Were you aware when M. first came to 
5 
BY MR. WEISSING: 
6 
Jeffrey Epstein's mansion in 2002 that she was a. 
6 
Q. Were you aware that between August 2002 
7 
she was a 14- ear-old child? 
7 
and September of 2005. Jeffrey E
n engaged in 
8 
MR. 
• Objection to the form. 
8 
sexual, engaged in behavior with M. for his sexual 
9 
standing objection. 
9 
gratification? 
10 
THE WITNESS: At the instruction of my 
10 
MR. 
: Objection to the form. the 
11 
lawyer, I must invoke my Fifth Amendment right. 11 
standing objection previously stated and 
12 
BY MR. WEISSING: 
12 
ambiguous. 
13 
Q. How many minor female children have been 
13 
THE WITNESS: At the instruction of my 
14 
brought to Jeffrey Epstein's mansion for the 
14 
lawyer, I must invoke my Fifth Amendment right. 
15 
purposes of his sexual ratification? 
15 
BY MR. WEISSING: 
16 
MR. 
Objection to the form, 
16 
Q. Between August -- during that same period 
17 
ambiguous as to time period and standing 
17 
of time, did Jeffrey Epstein engage in oral sex or 
18 
objection. 
18 
other misconduct with 
9
19 
THE WITNESS: On the instruction of my 
19 
MR. 
: Standing objection to 
20 
lawyer, I must invoke my Fifth Amendment right. 20 
form. 
21 
BY MR. WEISSING: 
21 
THE WITNESS: At the instruction of my 
22 
Q. Between the years of 2001 and 2005, were 
22 
lawyer, I must invoke my Fifth Amendment right. 
23 
more less or less than 1.000 underage female 
23 
BY MR. WEISSING: 
24 
children brought to Jeffrey Epstein's mansion for 
24 
Q. During that same period of time. did 
25 
his sexual eratification? 
25 
Jeffrey Epstein engage in masturbation and fondling 
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1 
of the minor child's sexual organs? 
1 
THE WITNESS: At the instruction of my 
2 
MR. 
: Can you, can you clarify 
2 
lawyer, I must invoke my Fifth Amendment right. 
3 
what you said, "the minor child"? 
3 
BY MR. WEISSING: 
4 
MR. WEISSING: Yes. Were talking about 
4 
Q. During that same period did Jeffrey 
5 
I. 
5 
Epstein tell you that he knew that ■. was a minor 
6 
MR. 
: I just want to make sure 
6 
child? 
7 
you're limiting the question to M. 
7 
MR. 
Objection to the form, the 
8 
MR. WEISSING: All right. 
8 
standing objection. 
9 
MR. 
: On that basis, we're 
9 
THE WITNESS: At the instruction of my 
10 
objecting to the form, and standing objection. 
10 
lawyer, I must invoke my Fifth Amendment right. 
11 
It assumes multiple facts this witness does not 
11 
BY MR. WEISSING: 
12 
acknowledge she does have information about, 
12 
Q. Did Jeffrey Enin tell you that he knew 
13 
and therefore the question is compound and 
13 
that he was injuring M. through numerous sexual 
14 
ambiguous. and I instruct her not to answer. 
14 
encounters with her between August 2002 and 
15 
THE WITNESS: On the instruction of my 
15 
September of 2005? 
16 
lawyer I must invoke my Fifth Amendment right. 16 
MR. 
Objection to the form. and 
17 
BY MR. WEISSING: 
17 
standing objection. Also compound question and 
18 
Q. You knew that during that period of time, 
18 
ambiguous, and instruct the witness not to 
19 
that Jeffrey Epstein was engaged in fondling and 
19 
answer the question. 
20 
penetrating the sexual organs of M.? 
20 
THE WITNESS: At the instruction of my 
21 
MR. 
: Objection to form, 
21 
lawyer, I must invoke my Fifth Amendment right. 
22 
leading, and also a standing objection. 
22 
BY MR. WEISSING: 
23 
THE WITNESS: At the instruction of my 
23 
Q. Did
 know that Jeffrey Epstein was 
24 
lawyer I must invoke my Fifth Amendment right. 24 
injuring M. through sexual contact with her during 
25 
25 
that period of time? 
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1 
BY MR. WEISSING: 
1 
MR. 
Objection to the form. It 
2 
Q. Did you know during that period of time 
2 
assumes knowledge of Jeffrey Epstein and a 
3 
that Jeffrey Epstein was engaging in sexual 
3 
and instruct the witness not to answer. 
4 
penetration of 
? 
4 
THE WITNESS: At the instruction of my 
5 
MR. 
Objection to the form, 
5 
lawyer, I must invoke my Fifth Amendment right. 
6 
standing objection previously stated. 
6 
BY MR. WEISSING: 
7 
THE WITNESS: At the instruction of my 
7 
Q. Did you know that the criminal conduct by 
8 
lawyer, I must invoke my Fifth Amendment right. 
8 
Jeffrey Epstein against 
was causing damage to 
9 
BY MR. WEISSING: 
9 
M.? 
10 
01
::ouring that period of time did you know 
10 
MR. 
Objection to the form. It 
11 
that M. was a minor child? 
11 
calls for a legal conclusion that the witness 
12 
MR. 
Objection to form, 
12 
is not competent to give. Also calls for 
13 
standing objection and assumes multiple facts 
13 
speculation as to harm, if any, to a person she 
14 
and therefore can't be answered without. 
14 
hasn't even acknowledged that she knows. so 
15 
because the question is too ambiguous. 
15 
it's an improper question. I instruct her not 
16 
Instruct the witness not to answer. 
16 
to answer based on the Fifth Amendment. 
17 
THE WITNESS: At the instruction of my 
17 
THE WITNESS: At the instruction of my 
18 
lawyer I must invoke my Fifth Amendment right. 
18 
lawyer I must invoke my Fifth Amendment right. 
19 
BY MR. WEISSING: 
19 
BY MR. WEISSING: 
20 
Q. From August 2002 to September 2005, did 
20 
Q. Are you aware that in the State of Florida 
21 
Jeffrey Epstein know that ■. was a minor child? 
21 
it is a crime to engage in sex, sexual activity with 
22 
MR. 
Objection to the form, 
22 
a minor child? 
23 
calls for speculation and also a standing 
23 
A. Can you repeat the question, please? 
24 
objection as assuming knowledge of Jeffrey 
24 
Q. Yes. Are you aware that in the State of 
25 
Epstein. Instruct the witness not to answer. 
25 
Florida it is against. it is a crime to engage in 
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sexual activit with a minor child? 
MR. 
Can -- I'd just ask you to 
clarify, when you say "sexual activity; are 
you using a legal term of art, or do you have a 
specific definition? 
MR. WEISSING: Sexual activity. 
MR. 
Okay. You mean by an 
adult with a minor child? 
MR. WEISSING: Yes. 
MR. 
Okay. Hold on one second. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
Page 293 
MR. 
Objection to the form to 
the extent it assumes knowledge of 
Jeffrey Epstein or M. 
THE WITNESS: At the instruction of my 
lawyer, I must invoke my Fifth Amendment right. 
BY MR. WEISSING: 
Q. At all times that Jeffrey Epstein was 
involved with S. she was a minor child, or was 
she a minor child? 
MR. 
Objection to the form. 
11 
I'm going to object. It calls for a legal 
11 
standing objection. It assumes facts that 
12 
conclusion. I'm going to instruct her not to 
12 
there has been no admission this witness knows 
13 
answer the question. 
13 
anything about. Instruct her not to answer. 
14 
MR. WEISSING: No — 
14 
THE WITNESS: At the instruction of my 
15 
MR. 
I'm instructing her not to 
15 
lawyer, I must invoke my Fifth Amendment right. 
16 
answer the question. It calls for a legal 
16 
BY MR. WEISSING: 
17 
conclusion. It's not a factual question that 
17 
Q. Did Jeffrey Epstein intentionally 
18 
is designed to lead to discoverable evidence. 
18 
penetrate M. during his, while she was at his 
19 
BY MR. WEISSING: 
19 
mansion? 
20 
Q. Did you know that M. was suffering 
20 
MR. 
Same objection to the 
21 
injury and emotional and psychological trauma as a 
21 
form. 
22 
result of the behavior engaged in with her by 
22 
THE WITNESS: At the instruction of my 
23 
Jeffrey Epstein? 
23 
lawyer, I must invoke my Fifth Amendment right. 
24 
MR. 
Objection to the form. 
24 
BY MR. WEISSING: 
25 
Assumes knowledge of the existence of a person 
25 
Q. Did Jeffrey Epstein engage in masturbation 
Page 292 
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1 
by the name of M. which has not been 
1 
in front of 
while she was a minor child at his 
2 
acknowledged. I instruct her not to answer. 
2 
mansion? 
3 
THE WITNESS: On the advice of counsel, I 
3 
MR. 
: Objection to the form. 
4 
must invoke my Fifth Amendment right. 
4 
THE WITNESS: At the instruction of my 
5 
BY MR. WEISSING: 
5 
lawyer, I must invoke my Fifth Amendment right. 
6 
. Were you at the mansion the first time 
6 
BY MR. WEISSING: 
7 
that 
. came to see Jeffrey Epstein? 
7 
Q. Did you know that Jeffrey Epstein was 
8 
MR. 
: Objection to the form. 
8 
engaging in sex his sexual gratification in the 
9 
Standing objection as to knowledge of 
9 
presence of 
9
10 
Jeffrey Epstein or any mansion. 
10 
MR. 
: Objection to the form. 
11 
THE WITNESS: On the advice of counsel, I 
11 
THE WITNESS: On the instruction of my 
12 
must invoke my Fifth Amendment right. 
12 
lawyer, I must invoke my Fifth Amendment right. 
13 
BY MR. WEISSING: 
13 
BY MR. WEISSING: 
14 
Q. Did Jeffrey
tein tell you that he 
14 
Q. Did you know that Epstein touched 5 
in 
15 
intended to injure M. by engaging her in sexual 
15 
the intimate portions of her body on numerous, 
16 
activity? 
16 
dozens of occasions between August of 2002 and 
17 
MR. 
: Object to the form. 
17 
September of 2005? 
18 
Assumes knowledge of Jeffrey Epstein and., 
18 
MR. 
: Object to the form. 
19 
Standing objection. 
19 
THE WITNESS: At the instruction of my 
20 
THE WITNESS: On the advice of my lawyer, 20 
lawyer, I must invoke my Fifth Amendment right. 
21 
I must invoke my Fifth Amendment right. 
21 
BY MR. WEISSING: 
22 
BY MR. WEISSING: 
22 
Q. Have you met Jane Doe? 
23 
Q. Did Jeffrey Epstein tell you that he 
23 
A. At the instruction of my lawyer. I must invoke 
24 
intended to cause severe emotional distress to 
24 
my Fifth Amendment ri ht. 
25 
by engaging her in sexual activity? 
25 
Q. 
would you set up the 
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massage table where minor children were escorted in 
1 
massage table and order them to take their clothes 
2 
Jeffrey Epstein's mansion? 
2 
off? 
3 
MR. 
: Objection to the form. 
3 
MR. 
Objection to form. 
4 
Ifs a compound question that assumes things 
4 
THE WITNESS: At the instruction of my 
5 
about her job and other things that are not 
5 
lawyer, I must invoke my Fifth Amendment right. 
6 
established and instruct her not to answer. 
6 
BY MR. WEISSING: 
7 
THE WITNESS: At the instruction of my 
7 
Q. After they disrobed, are you aware that he 
8 
lawyer. I must invoke my Fifth Amendment right. 
8 
would allow them to massage him? 
9 
BY MR. WEISSING: 
9 
MR. 
: Are we talking about a 
10 
I. Between 2001 and 2005 
10 
specific person on a specific date, or are you 
11 
asking a general practice and policy? 
12 
MR. 
Instruct the witness not 
12 
MR. WEISSING: General. 
13 
to answer based on Fifth Amendment privilege. 
13 
MR. 
: Object to the question as 
14 
THE WITNESS: At the instruction of my 
14 
ambiguous. open ended, and instruct the witness 
15 
lawyer. I must invoke my Fifth Amendment right. 
15 
not to answer. 
16 
BY MR. WEISSING: 
16 
THE WITNESS: On the instruction of my 
17 
Q. 
were you 
17 
lawyer, I must invoke my Fifth Amendment right. 
18 
responsible for setting up a massage table in the 
18 
BY MR. WEISSING: 
19 
mansion? 
19 
Q. Are you aware that Jeffrey Epstein 
20 
MR. 
: Objection to the form. 
20 
routinely would turn on. turn onto his back and ask 
21 
THE WITNESS: On the instruction of my 
21 
the 
to inch his ni les? 
22 
lawyer. I must invoke my Fifth Amendment right. 
22 
girls 
MR. 
: Objection to the form. 
23 
BY MR. WEISSING: 
23 
It's a compound question. 
24 
Q. 
for, with 
24 
THE WITNESS: At the instruction of my 
25 
Jeffrey Epstein, were you responsible for escorting 
25 
lawyer, I must invoke my Fifth Amendment right. 
Page 296 
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1 
underage girls to the massage table area in the 
1 
BY MR. WEISSING: 
2 
mansion? 
2 
Q. After exposing his naked body to these 
3 
MR. 
Objection to form. 
3 
girls, are you aware that he would then masturbate 
4 
THE WITNESS: At the instruction of my 
4 
in their presence? 
5 
lawyer, I must invoke my Fifth Amendment right. 
5 
MR. 
Object to the form. You 
6 
BY MR. WEISSING: 
6 
keep asking questions about what 
7 
Q. After escorting underage girls to the 
7 
Jeffrey Epstein did. She's not acknowledged 
8 
massage area in the mansion, did you leave them 
8 
she even knowns a Jeffrey Epstein. You can ask 
9 
alone? 
9 
her if Jeffrey Epstein went to the moon: she's 
10 
MR. 
• Objection to fonn. 
10 
not going to answer the question. but you can 
11 
THE WITNESS: At the instruction of my 
11 
keeping asking. 
12 
lawyer, I must invoke my Fifth Amendment right. 12 
THE WITNESS: On the instruction of my 
13 
BY MR. WEISSING: 
13 
lawyer. I must invoke my Fifth Amendment right. 
14 
Q. After the underage girls were left alone. 
14 
BY MR. WEISSING: 
15 
are you aware that Jeffrey Epstein appeared either 
15 
Q. The amount of, the amount of money given 
16 
naked or, or wrapped in a towel? 
16 
to these 
was dependent upon the extent 
17 
MR. 
Objection to form. Calls 
17 
young girls 
of behavior engaged in by Jeffrey Epstein: is that 
18 
for speculation and compound question. Assumes 18 
correct? 
19 
facts that she's not acknowledged any personal 
19 
MR. 
Objection to form. leading 
20 
knowledge of. 
20 
and otherwise objection to the form for the 
21 
THE WITNESS: On the instruction of my 
21 
reasons previously stated. 
22 
lawyer, I must invoke my Fifth Amendment right. 22 
THE WITNESS: On the instruction of my 
23 
BY MR. WEISSING: 
23 
lawyer, I must invoke my Fifth Amendment right. 
24 
Q. Are you aware that after appearing naked 
24 
BY MR. WEISSING: 
25 
in front of underage girls. he would lay down on the 
25 
Q. Were the girls paid more if they used 
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vibrators or sexual to s? 
1 
lawyer, I must invoke my Fifth Amendment right. 
2 
MR. 
Objection to the form. 
2 
BY MR. WEISSING: 
3 
THE WITNESS: On the instruction of my 
3 
Q. Were you aware that during that period of 
4 
lawyer, I must invoke my Fifth Amendment right. 
4 
time that Jane Doe was a minor child? 
5 
BY MR. WEISSING: 
5 
MR. 
: Objection to the form. 
6 
Q. Regarding Jane Doe, when she was first 
6 
THE WITNESS: At the instruction of my 
7 
brought to Epstein's mansion in 2003, she was in 
7 
lawyer, I must invoke my Fifth Amendment right. 
8 
middle school, or was she in middle school? 
8 
BY MR. WEISSING: 
9 
MR. 
Objection to form. 
9 
Q. Were you aware that during that period of 
10 
THE WITNESS: On the instruction of my 
10 
time that Jeffrey Epstein engaged in fondling and 
11 
lawyer, I must invoke my Fifth Amendment right. 11 
sexual touchin of Jane Doe? 
12 
BY MR. WEISSING: 
12 
MR. 
Form. 
13 
Q. Are you aware that in 2003 when Jane Doe 
13 
THE WITNESS: At the instruction of my 
14 
was brought to Epstein's mansion, she was in middle 
14 
lawyer, I must invoke my Fifth Amendment right. 
15 
school? 
15 
BY MR. WEISSING: 
16 
MR. 
Objection to the form. 
16 
Q. During that period of time, were you aware 
17 
Once again to answer the question, she would 
17 
that Jeffrey Epstein engaged in masturbation in the 
18 
have to implicitly admit that she knows Jeffrey 
18 
presence of Jane Doe? 
19 
Epstein or knows anything about Jeffrey Epstein 
19 
MR. 
Objection to form. 
20 
which she is not going to do, so to go onto the 
20 
THE WITNESS: The instruction of my 
21 
second half of the question, it's a compound 
21 
lawyer, I must invoke my Fifth Amendment right. 
22 
question as to whatever happened with 
22 
BY MR. WEISSING: 
23 
Mr. Epstein. But you keep asking her. She's 
23 
Q. During that period of time, are you aware 
24 
not going to answer them. So, they're compound 
24 
that Jeffrey Epstein engaged in sexual penetration 
25 
and ambiguous. 
25 
of Jane Doe? 
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1 
THE WITNESS: On the instruction of my 
1 
MR. 
: Objection to form. 
2 
lawyer, I must invoke my Fifth Amendment right. 
2 
THE WITNESS: On the instruction of my 
3 
BY MR. WEISSING: 
3 
lawyer, I must invoke my Fifth Amendment right. 
4 
Q. Are you aware that between February 2003 
4 
BY MR. WEISSING: 
5 
and June of 2005 that Jane Doe engaged in sexual 
5 
Q. During that period of time, are you aware 
6 
7 
conduct with Jeffrey Epstein at his mansion? 
MR. 
Objection to the form. 
6 
7 
that Jeffrey Epstein perpetuated that kind of 
behavior upon Jane Doe on dozens of occasions? 
8 
THE WITNESS: At the instruction of my 
8 
MR. 
: Objection to the form. 
9 
lawyer, I must invoke my Fifth Amendment right. 
9 
It's ambiguous and otherwise standing 
10 
BY MR. WEISSING: 
10 
objection. 
11 
Q. In 2003 she was only -- are you aware that 
11 
THE WITNESS: On the instruction of my 
12 
she was only 14 years of age when she first came to 
12 
lawyer, I must invoke my Fifth Amendment right. 
13 
the mansion? 
13 
BY MR. WEISSING: 
14 
MR. 
Objection to form. 
14 
Q. Are you aware that when he was engaging in 
15 
THE WITNESS: At the instruction of my 
15 
the sexual conduct with Jane Doe, that he was doing 
16 
lawyer, I must invoke my Fifth Amendment right. 16 
so with the specific intent to cause her emotional 
17 
18 
BY MR. WEISSING: 
Q. Between February of 2003 and June 2005, 
17 
18 
and psycholo ical in 
and damage? 
MR. 
: Objection to the form. 
19 
was Jeffrey Epstein aware that she was 14, 15, 16 
19 
Calls for a legal conclusion and is ambiguous 
20 
years of age? 
20 
and is compound. 
21 
MR. 
Objection to form. Calls 
21 
THE WITNESS: The instruction of my lawyer 
22 
for her to speculate on the state of mind of a 
22 
I must invoke my Fifth Amendment right. 
23 
person she's not admitting she has any 
23 
BY MR. WEISSING: 
24 
knowledge of. 
24 
Q. Did Jeffrey Epstein tell you that when he 
25 
THE WITNESS: At the instruction of my 
25 
would engage in the sexual conduct with Jane Doe. 
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that he was intentionally and deliberately 
1 
going to instruct the witness not to answer it 
2 
attempting to cause her psychological and emotional 
2 
at all. 
3 
pain and sufferin 
3 
BY MR. WEISSING: 
4 
Objection to form for the 
4 
Q. Okay. Did you engage in an agreement with 
5 
reasons previously stated. 
5 
Jeffrey Epstein that you would seek out underage 
6 
THE WITNESS: At the instruction of my 
6 
female children for his sexual gratification? 
7 
lawyer, I must invoke my Fifth Amendment right. 
7 
MR. 
: Objection to the form. 
8 
BY MR. WEISSING: 
8 
It's a compound question. Instruct the witness 
9 
Q. Did you see evidence that Jeffrey 
9 
not to answer. 
10 
Epstein's sexual misconduct with her led to 
10 
THE WITNESS: On the instruction of my 
11 
emotional distress on her behalf? 
11 
lawyer, I must invoke my Fifth Amendment right. 
12 
MR. 
• Objection to the form. 
12 
BY MR. WEISSING: 
13 
THE WITNESS: At the instruction of my 
13 
Q. Are you aware that Jane Doe was injured as 
14 
lawyer, I must invoke my Fifth Amendment right. 14 
a result of sex traffickin: committed against her? 
15 
BY MR. WEISSING: 
15 
MR. 
: Objection to form. Uses 
16 
Q. Are you aware that all of Jeffrey 
16 
legal terminology like "sex trafficking." and 
17 
Epstein's behavior with the minor children were 
17 
presumes as part of the question that she knows 
18 
violations of numerous criminal laws? 
18 
a person by the name of Jane Doe, which she 
19 
MR. 
Objection to the form. It 19 
does not acknowledge. Therefore she's not 
20 
calls for a legal conclusion. I will instruct 
20 
going to answer the question in that form. I 
21 
her not to answer the question at all. 
21 
instruct her not to answer, based on Fifth 
22 
BY MR. WEISSING: 
22 
Amendment because the answer would implicitly 
23 
Q. Did you know that Jeffrey Epstein's 
23 
acknowledge that she knows these people or that 
24 
behavior with these minor children was criminal in 
24 
she knows Mr. Epstein. 
25 
nature? 
25 
THE WITNESS: On the instruction of my 
Page 304 
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1 
MR. 
Objection to the form. It 
1 
lawyer, I must invoke my Fifth Amendment right. 
2 
assumes she has knowledge of whatever conduct 
2 
BY MR. WEISSING: 
3 
Jeffrey Epstein, whoever that may be, may have 
3 
Q. Are you aware that Jane, Jane Doe suffered 
4 
engaged in. So it requires her to speculate as 
4 
emotional and psychological trauma and injury as a 
5 
to a legal conclusion that she's not going to 
5 
result of the behavior engaged with her by 
6 
give. 
6 
Jeffrey Epstein? 
7 
BY MR. WEISSING: 
7 
MR. 
Same objection as stated 
8 
I.
8 
to the previous question and instruct the 
I
were you paid bonuses or any kind 
9 
witness not to answer, because to attempt to 
10 
of additional monies for bringing minor children for 
10 
answer that question would implicitly admit 
11 
his sexual ratification to him? 
11 
that she knows Jeffrey Epstein or knows 
12 
MR. 
: Objection to form. 
12 
anything about Jane Doe. 
13 
Assumes facts such as that she ever worked for 
13 
THE WITNESS: On the instruction of my 
14 
Jeffrey Epstein or has any immediate knowledge, 14 
lawyer, I must invoke my Fifth Amendment right. 
15 
is otherwise compound and ambiguous, and 
15 
BY MR. WEISSING: 
16 
instruct her not to answer. 
16 
Q. With regard to these girls who were being 
17 
THE WITNESS: At the instruction of my 
17 
procured for Jeffrey Epstein, did you arrange for 
18 
lawyer, I must exert my Fifth Amendment right. 
18 
their travel to the mansion? 
19 
BY MR. WEISSING: 
19 
MR. 
: Objection to the form. 
20 
Q. Did you conspire with Jeffrey Epstein to 
20 
ambiguous to the term "procurement," and for 
21 
gain access to minor children for his sexual 
21 
the reasons previously stated, and the standing 
22 
gratification? 
22 
objection, and instruct the witness not to 
23 
MR. 
It's a question that calls 
23 
answer the question. 
24 
for a legal conclusion. It doesn't in any way 
24 
THE WITNESS: At the instruction of my 
25 
lead to any discoverable evidence. and I ant 
25 
lawyer. I must invoke my Filth Amendment right. 
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BY MR. WEISSING: 
1 
BY MR. WEISSING: 
2 
Q. 
did you 
2 
Q. Are you aware that Jeffrey Epstein engaged 
3 
coordinate efforts with others in bringing minor 
3 
in sexual misconduct with Jane Doe at least 20 times 
4 
female children to his mansion for his sexual 
4 
between February 2003 and June 2005 while she was a 
5 
gratification? 
5 
minor child? 
6 
MR. 
Objection to the form. 
6 
MR. 
: Objection to the form. 
7 
Same objection previously made to the standing 
7 
THE WITNESS: On the instruction of my 
8 
objection. 
8 
lawyer, I must invoke my Fifth Amendment right. 
9 
THE WITNESS: At the instruction of my 
9 
BY MR. WEISSING: 
10 
lawyer. I must invoke my Fifth Amendment right. 
10 
Q. In the scheduling of girls for 
11 
BY MR. WEISSING: 
11 
Jeffrey Epstein. did he have a particular interest 
12 
Q. Were you aware that many of the girls 
12 
in girls under the a:e of 14? 
13 
brought to Epstein's were minor -- Epstein mansion 
13 
MR. 
: Objection to the form. It 
14 
were minors. under at a:e of 14 years of age? 
14 
assumes she did scheduling for Jeffrey Epstein. 
15 
MR. 
: Object to the form. 
15 
In order to answer the question. she has to 
16 
Instruct the witness not to answer. 
16 
implicitly admit that %%filch she's not 
17 
THE WITNESS: At the instruction of my 
17 
admitting. and therefore she's not answering 
18 
lawyer. I must invoke the Fifth Amendment 
18 
the question. 
19 
right. 
19 
THE WITNESS: At the instruction of my 
20 
BY MR. WEISSING: 
20 
lawyer, I must invoke my Fifth Amendment right. 
21 
Q. Did you coordinate with some of the girls 
21 
BY MR. WEISSING: 
22 
to bring other underage female children to Epstein 
22 
Q. In procuring girls for Jeffrey Epstein, 
23 
for his sexual ratification? 
23 
was he primarily interested in young, skinny and 
24 
MR. 
: Objection. Can we narrow 24 
attractive girls? 
25 
down "other girls" and who we are talking 
25 
MR. 
: Objection to the form and 
Page 308 
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1 
about? We already have questioning from 
1 
implicitly assumes that she procured girls for 
2 
Mr. Horowitz about his clients and Mr. Kuvin 
2 
Jeffrey Epstein, which she has not admitted to 
3 
about his clients. Can we narrow that down a 
3 
or is not admitting to. so therefore she can't 
4 
little bit? 
4 
fairly answer the question as it's been asked. 
S 
MR. WEISSING: I'm asking about whether or 
5 
so therefore. I will instruct her not to answer 
6 
not she had someone she coordinated with to 
6 
it. 
7 
bring other irls. Oka ? 
7 
THE WITNESS: On the instruction of my 
8 
MR. 
And same form objection. 
8 
lawyer, I must invoke my Fifth Amendment right. 
9 
THE WITNESS: On the instruction of my 
9 
BY MR. WEISSING: 
10 
lawyer. I must invoke my Fifth Amendment 
10 
Q. With regard to the amount paid to the 
11 
privilege. 
11 
girls for what they did with Jeffrey Epstein, would 
12 
BY MR. WEISSING: 
12 
the standard a ment be several hundred dollars? 
13 
Q. When you scheduled these girls to come to 
13 
MR. 
: Objection to the form. 
14 
the mansion, you knew that they were coming for 
14 
standard objection. 
15 
Jeffrey Epstein's sexual ratification, did you not? 
15 
THE WITNESS: At the instruction of my 
16 
MR. 
Objection to the form. 
16 
lawyer, I must invoke my Fifth Amendment right. 
17 
It's a compound question that assumes she did 
17 
BY MR. WEISSING: 
18 
scheduling, assumes she brought them to the 
18 
Q. Did he have a standard escalation of the 
19 
mansion, assumes she knows what the mansion is, 19 
amount that he would pay depending upon the nature 
20 
and assumes she knows who Jeffrey Epstein is. 
20 
of the sexual acts that he 
rformed with them? 
21 
So it's a compound question that she can't 
21 
MR. 
: Objection. objection. The 
22 
fairly answer without -- in the form that it's 
22 
question has been asked and answered in 
23 
asked and instruct her not to answer. 
23 
different forms several times, and again 
24 
THE WITNESS: At the instruction of my 
24 
standing objection as to the form of the 
25 
law er. I must invoke my Fifth Amendment right. 
__.. 
25 
question. 
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THE WITNESS: At the instruction of my 
1 
happen? 
2 
lawyer, I must invoke my Fifth Amendment right. 
2 
MR. 
Objection to the form for 
3 
BY MR. WEISSING: 
3 
the same reasons previously stated. 
4 
Q. The engaging in sexual practices with 
4 
THE WITNESS: At the instruction of my 
5 
underage girls, was this something that went on for 
5 
lawyer, I must invoke my Fifth Amendment right. 
6 
a substantialperiod of time? 
6 
BY MR. WEISSING:
7 
MR. 
: Objection to the form. 
7 
Q. Are you aware that Epstein received sexual 
8 
9 
It's ambiguous. It assumes facts that she's 
not conceding. and she can't fairly answer the 
8 
9 
gratification from sexual) abusing minor children? 
MR. 
: Object to the form. It 
10 
question based on the assumptions that are made 
10 
calls for a legal conclusion and it's 
11 
in it. I will therefore instruct her not to 
11 
ambiguous, and the standing objection as to any 
12 
answer the question. 
12 
knowledge of Jeffrey Epstein or any abuse of 
13 
THE WITNESS: At the instruction of my 
13 
minor children. 
14 
lawyer I must exercise my Fifth Amendment 
14 
THE WITNESS: At the instruction of my 
15 
right. 
15 
lawyer, I must invoke my Fifth Amendment right. 
16 
BY MR. WEISSING: 
16 
BY MR. WEISSING: 
17 
Q. With regard to the payments made to the 
17 
Q. Did Jeffrey Epstein ever tell you that he 
18 
girls, would he make bigger payments to these minor 18 
received sexual gratification from sexually abusing 
19 
girls depending upon the degree of force he used 
19 
minor children? 
20 
towards them? 
20 
MR. 
: Objection to the form for 
21 
MR. 
: Objection to the form. It 21 
the same reasons previously stated. 
22 
assumes numerous facts that have not been 
22 
THE WITNESS: At the instruction of my 
23 
established nor that this witness is admitting. 
23 
lawyer, I must invoke my Fifth Amendment right. 
24 
So, I instruct her not to answer. 
24 
MR. 
: Folks, it's 4:20. We've 
25 
THE WITNESS: At the instruction of my 
25 
been at this for a long, long time. This is 
Page 312 
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1 
lawyer, I must invoke my Fifth Amendment right. 
1 
now getting pointless, and we're terminating 
2 
BY MR. WEISSING: 
2 
the deposition at 5:00. So I suggest you pick 
3 
Q. Along that line, would he make greater 
3 
up the pace. 
4 
payments, larger payments to the girls if they -- if 
4 
You can ask a million questions about what 
5 
he was more concerned about them reporting the 
5 
Jeffrey Epstein knew, what Jeffrey Epstein did. 
6 
crimes committed a ainst him? 
6 
She doesn't know. She's not going to say, so
7 
MR. 
Objection to the form. It 
7 
we've got 40 minute and we're out of here. 
8 
calls for speculation. It calls for a legal 
8 
MR. GARCIA: I haven't asked any 
9 
conclusion. It assumes facts that have not 
9 
questions. 
10 
been admitted. Standing objection to the form. 
10 
MR. EDWARDS: There others of us that have 
11 
THE WITNESS: At the instruction of my 
11 
questions. 
12 
lawyer, I must invoke my Fifth Amendment 
12 
MR. 
You can take that up with 
13 
privilege. 
13 
the judge. We're done at 5:00. 
14 
BY MR. WEISSING: 
14 
MS. EZELL: For the record, there are some 
15 
Q. Would you pay the girls more money because 15 
filed cases who attorneys have not been able to 
16 
of the amount of force used by Jeffrey Epstein 
16 
ask questions, and we certainly assert our 
17 
against them and feared that they would report the 
17 
right to call Ms. 
again. 
18 
crimes committed a ainst them? 
18 
MR. 
You can, you can certainly 
19 
MR. 
Objection to the form. 
19 
take that up. but I am not, you know, how many. 
20 
THE WITNESS: On the instruction of my 
20 
how many times do we have to ask the same 
21 
lawyer, I must invoke my Fifth Amendment right. 21 
question over and over and over again that it's 
22 
BY MR. WEISSING: 
22 
clear is a compound question that asks her to 
23 
Q. Are you aware that after having unlawful 
23 
assume facts that she's not admitted she knows 
24 
sex with these minor children, that Epstein would 
24 
anything about and it's a hypothetical question 
25 
tell them not to tell any one or had things would 
25 
not designed to get us anywhere. 
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So can we focus on the specific questions 
1 
THE WITNESS: On the instruction of my 
2 
that she can answer or from which you can draw 
2 
lawyer, I must invoke my Fifth Amendment 
3 
an adverse inference if asked properly, and 
3 
privilege. 
4 
let's move it along. 
4 
BY MR. WEISSING: 
5 
MS. F7Ft i • Each young woman's case is an 
s 
Q. Do ou know Alan Dershowitz? 
6 
individual case, and we have the right to ask. 
6 
MR. 
The question was asked and 
7 
ask whatever questions that we need to with 
7 
answered about three-and-a-half hours ago. 
8 
regard to each one. 
8 
THE WITNESS: On the instruction of my 
9 
MR. 
9 
lawyer. I must invoke my Fifth Amendment 
10 
MR. GOLDBERGER: Let's just go forward 
10 
privilege. 
11 
until 5:00 and see where were at. 
11 
BY MR. WEISSING: 
12 
BY MR. WEISSING: 
12 
Q. Do ou know David Copperfield? 
13 
Q. Did you know that Jeffrey Epstein received 
13 
MR. 
That question was asked 
14 
sexual gratification from directing others to 
14 
about three-and-a-half-hours ago. 
15 
sexually abuse minor children? 
15 
THE WITNESS: On the instruction of my 
16 
MR. 
Objection to the form. 
16 
lawyer, I must invoke my Fifth Amendment 
17 
THE WITNESS: On the instruction of my 
17 
privilege. 
18 
lawyer. I must invoke the Fifth Amendment 
18 
BY MR. WEISSING: 
19 
right. 
19 
Q. In addition to his place at. in Palm 
20 
BY MR. WEISSING: 
20 
Beach. are you aware that Jeffrey Epstein has an 
21 
Q. Did you know that JeffreyEpstein received 
21 
apartment located at 301 East 66th Stmt. Apartment 
22 
sexual gratification from directing 
to 
22 
I4G throw 
E in New York? 
23 
sexually abuse minor children? 
23 
MR. 
That question was asked 
24 
MR. 
Objection to the form. It 
24 
about four hours ago. It's been asked and 
25 
assumes knowledge of a person named 
25 
answered. 
Page 316 
Page 318 
1 
It is otherwise compound and objectionable. 
1 
THE WITNESS: At the instruction of my 
2 
THE WITNESS: On the instruction of my 
2 
lawyer, I invoke my Fifth Amendment privilege. 
3 
lawyer, I must invoke my Fifth Amendment right. 
3 
BY MR. WEISSING: 
4 
MR. WEISSING: Let's go off the record for 
4 
Q. While in New York, have you procured 
5 
a moment. 
5 
underage minor children to engage in sexual acts 
6 
THE VIDEOGRAPHER: Are we all good wit 
6 
with Jeffre 
tein at that location? 
7 
going off the record? 
7 
MR. 
Object to the form. 
8 
MR. 
Yeah, that's fine. 
8 
THE WITNESS: On the instruction of my 
9 
MR. HOROWITZ: Yes. 
9 
lawyer, I must invoke my Fifth Amendment 
10 
THE VIDEOGRAPHER: Were now off the 
10 
privilege. 
11 
record at 4:22 p.m. 
11 
BY MR. WEISSING: 
12 
(A brief recess was held.) 
12 
Q. With regard to the minor children procured 
13 
THE VIDEOGRAPHER: We are now on the 
13 
for him at that location, were they school children 
14 
record. It is 4:24 p.m. 
14 
in the New York area? 
15 
BY MR. WEISSING: 
15 
MR. 
The previous question, 
16 
Q. Do you know 
? 
16 
objection to the form. The same as all the 
17 
MR. KUVIN: 
17 
previous questions, it assumes a fact that's 
18 
THE WITNESS: On the instruction of my 
18 
not been established. It can't fairly be 
19 
lawyer, I must invoke my Fifth Amendment 
19 
answered. 
20 
privilege. 
20 
THE WITNESS: On the instruction of my 
21 
BY MR. WEISSING: 
21 
lawyer, I must invoke my Fifth Amendment 
22 
Q. Do you know -- have you procured minor 
22 
privilege. 
23 
children to have sexual relations with 
23 
BY MR. WEISSING: 
24 
at Jeffrey Epstein's mansion? 
24 
Q. Did Jeffrey Epstein have sexual encounters 
25 
MR. 
Objection to the form. 
25 
with underage people while at that apartment? 
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1 
MR. 
: Objection to the form. 
1 
privilege. 
2 
THE WITNESS: On the instruction of my 
2 
BY MR. WEISSING: 
3 
lawyer, I must invoke my Fifth Amendment 
3 
Q. Have you been to Jeffrey Epstein's 
4 
privilege. 
4 
property at 6100 Red Hook Quarters, Suite 3-B, in 
5 
BY MR. WEISSING: 
5 
St. Thomas. the Virgin Islands? 
6 
Q. With regard to underage children that he 
6 
A. On the instruction of my lawyer, I must invoke 
7 
had sexual encounters with in New York. were those 
7 
my Fifth Amendment privilege. 
8 
school children in that area? 
8 
Q. Over what period of time have you been to 
9 
MR. 
: Objection to the form. No 
9 
that location? 
10 
factual basis for the question. 
10 
MR. 
Objection to the form. 
11 
THE WITNESS: On the instruction of my 
11 
THE WITNESS: On the instruction of my 
12 
lawyer, I must invoke my Fifth Amendment 
12 
lawyer, I must invoke my Fifth Amendment 
13 
privilege. 
13 
privilege. 
14 
BY MR. WEISSING: 
14 
BY MR. WEISSING: 
15 
Q. Are you aware of another location that he 
15 
Q. Are you aware of Jeffrey Epstein engaging 
16 
has at 457 Madison Avenue. lower floor, New York? 
16 
in sexual encounters with underage persons at that 
17 
MR. 
: Objection to the form. 
17 
location? 
18 
THE WITNESS: At the instruction my lawyer 
18 
MR. 
Objection to the form. 
19 
I must invoke my Fifth Amendment privilege. 
19 
THE WITNESS: On the instruction of my 
20 
BY MR. WEISSING: 
20 
lawyer, I must invoke my Fifth Amendment 
21 
Q. Are you aware of Jeffrey Epstein having 
21 
privilege. 
22 
sexual encounters with underage children at that 
22 
BY MR. WEISSING: 
23 
location? 
23 
Q. With regard to the underage children he 
24 
MR. 
: No factual basis for the 
24 
engaged in sexual activity with at that location, 
25 
question. Objection to form. 
25 
where were those children procured from? 
Page 320 
Page 322 
THE WITNESS: On the instruction of my 
1 
MR. 
Objection to the form. It 
2 
lawyer, I must invoke my Fifth Amendment 
2 
assumes facts that there has not been any basis 
3 
privilege. 
3 
to assume this witness has any knowledge of. 
4 
BY MR. WEISSING: 
4 
THE WITNESS: On the instruction of my 
5 
Q. Was it part of your employment to obtain 
5 
lawyer, I must invoke my Fifth Amendment 
6 
underage children for sexual encounters with him at 
6 
privilege. 
7 
that location? 
7 
BY MR. WEISSING: 
8 
MR. 
Objection to the form. 
8 
Q. Were you, were you engaged by Jeffrey 
9 
THE WITNESS: At the instruction of my 
9 
Epstein to procure school children from the Virgin 
10 
lawyer, I must invoke my Fifth Amendment 
10 
Islands area for sexual behavior at that location? 
11 
privilege. 
11 
MR. 
Objection to the form. 
12 
BY MR. WEISSING: 
12 
Standing objection, it assumes knowledge of 
13 
Q. With regard to the underage children he 
13 
Jeffrey Epstein. 
14 
had sex with at that location, were those school 
14 
THE WITNESS: At the instruction of my 
15 
children from that area? 
15 
lawyer I must invoke my Fifth Amendment 
16 
MR. 
Can I ask what the good 16 
privilege. 
17 
faith basis is to ask the question if he 
17 
BY MR. WEISSING: 
18 
actually had sex with someone at that location? 
18 
Q. Who is Sto Cowles?
19 
Because I, I know no factual predicate that I 
19 
MR. 
Objection to the form. 
20 
have heard today for asking the questions, so I 
20 
THE WITNESS: At the instruction of my 
21 
will instruct the witness not to answer it 
21 
lawyer, I must invoke my Fifth Amendment 
22 
because it presumes that she knows Jeffrey 
22 
privilege. 
23 
Epstein. 
23 
BY MR. WEISSING: 
24 
THE WITNESS: On the instruction of my 
24 
Q. Did Mr. Cowles in your presence ever have 
25 
lawyer. I must invoke my Fifth Amendment 
25 
sexual encounters with underage persons at any of 
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Mr. Epstein's ro rties? 
1 
MR. WEISSING: I have no other questions. 
2 
MR. 
: Objection to the form. It 
2 
MR. 
Okay. Ms. Ezell, 
3 
assumes knowledge of Mr. Epstein. 
3 
Mr. Garcia, do you want to go next? 
4 
THE WITNESS: At the instruction of my 
4 
MR. GARCIA: Is it okay if I go? 
5 
lawyer, I must invoke my Fifth Amendment 
5 
MS. EZELL: We were just discussing that. 
6 
privilege. 
6 
I'm going to go quite a while, and I believe 
7 
BY MR. WEISSING: 
7 
you think you can finish in 30 or 40 minutes, 
8 
Q. Were you, did you participate in procuring 
8 
9 
underage children for having sex with Mr. Cowles at 
9 
MR. GARCIA: About 45. About 45 minutes. 
10 
11 
Mr. Epstein's ro rties? 
MR. 
: Objection to the form. It 
10 
11 
MS. EZELL: It makes sense for Mr. Garcia
to go first. 
12 
assumes knowledge of Mr. Epstein. 
12 
MR. 
Your decision. Do you 
13 
THE WITNESS: At the instruction of my 
13 
need a break or are you okay? 
14 
lawyer, I must invoke my Fifth Amendment 
14 
THE WITNESS: I'm okay. 
15 
privilege. 
15 
MR. 
I'll slide over. 
16 
BY MR. WEISSING: 
16 
THE VIDEOGRAPHER: Are we on a break? 
17 
Q. Haveyou ever heard of 
17
MR. KUVIN: No no breaks 
18 
MR. 
: Objection to the form. 
18 
CROSS i 
19 
THE WITNESS: On the instruction of my 
19 
BY MR. GARCIA: 
20 
lawyer, I must invoke my Fifth Amendment 
20 
Q. Ms. 
, I think you've already 
21 
privilege. 
21 
answered this question about your cell number. Are 
22 
MR. WEISSING: Okay. Let's you objected 
22 
you able to tell me if you have a new cell number 
23 
to the form. 
23 
other than the one that was given to you which I 
24 
MR. 
: I'm sorry. I didn't mean 
24 
believe was 
25 
to object to form. That one I apologize. Just 
25 
MR. 
Instruct the witness not 
Page 324 
Page 326 
1 
instruct the witness not to answer the 
1 
to answer the question based on her Fifth 
2 
question. 
2 
Amendment privilege. 
3 
BY MR. WEISSING: 
3 
THE WITNESS: At the instruction of my 
4 
5
Haveyou ever gone by the name 
. 
4 
5 
lawyer. I must invoke my Fifth Amendment right. 
BY MR. GARCIA: 
6 
A. At the instruction of my lawyer, I must invoke 
6 
Q. All right. Can you tell me who pays for 
7 
my Fifth Amendment privilege. 
7 
that cell number? 
8 
Q. Have you ever been paid by Jeffrey Epstein 
8 
MR. 
: Same instruction. 
9 
to obtain underage children to have sex with 
9 
THE WITNESS: On the instruction of my 
10 
Jean-Luc Brunel? 
10 
lawyer, I must invoke my Fifth Amendment 
11 
MR. 
: Objection to the form. It 
11 
privilege. 
12 
assumes knowledge of Jeffrey Epstein. 
12 
BY MR. GARCIA: 
13 
THE WITNESS: At the instruction of my 
13 
Q. Can you tell me how long you've had that 
14 
lawyer, I must invoke my Fifth Amendment 
14 
cell number? 
15 
privilege. 
15 
MR. 
Just --
16 
BY MR. WEISSING: 
16 
THE WITNESS: On the instruction --
17 
Q. Other than the properties that we've 
17 
MR. 
: Just so I'm clear, when 
18 
discussed, are you aware of any other properties 
18 
you say "that" cell number --
19 
that Jeffrey Epstein owns? 
19 
MR. GARCIA: The 
20 
A. At the instruction of my lawyer, I must invoke 20 
MR. 
Thank you. Instruct the 
21 
my Fifth Amendment privilege. 
21 
witness not to answer based on Fifth Amendment. 
22 
Q. Are you aware of the financial assets of 
22 
THE WITNESS: At the instruction of my 
23 
Jeffrey Epstein? 
23 
lawyer. I must invoke my Fifth Amendment right. 
24 
A. On the instruction of my lawyer, I must invoke 24 
BY MR. GARCIA: 
25 
my Fifth Amendment privilege. 
25 
Q. All right. Would you have any objection 
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1 
to me dialing that number to see what the response 
1 
MR. 
There's all sorts of facts 
2 
is? 
2 
that you may be able to prove from other places 
3 
MR. 
Would she object to it? 
3 
that she's doesn't have to admit to. 
4 
MR. GARCIA: Yeah. 
4 
MR. GARCIA: I am not asking her for other 
5 
MR. 
You can do whatever you 
5 
facts. I'm asking her if she files income tax 
6 
want to do. 
6 
returns. 
7 
MR. GARCIA: Okay. 
7 
MR. 
Correct. You asked her 
8 
MR. KUVIN: lust do it. 
8 
that. She's answered your question. 
9 
MR. GARCIA: Okay. Let's see if I can 'ut 
9 
MR. GARCIA: Even though the Government 
10 
it on speaker. And I am dialing 
10 
has her income tax returns, if she files them. 
11 
(Telephone call being made: Please leave 
11 
you are -- you're still asserting a privilege 
12 
a message. At the tone please record your 
12 
on information the Government already has? 
13 
message.) 
13 
MR. 
Yes. 
14 
BY MR. GARCIA: 
14 
BY MR. GARCIA. 
15 
Q. Were you able to hear the voice that said. 
15 
16 
"Please leave a message"? 
a
17 
A. Well, I heard what it said. 
17 
MR. 
Objection to the form of 
18 
Q. All right. Do you recognize that voice? 
18 
the question. Assumes Mr. Epstein. 
19 
A. My lawyer has instructed me to assert my Fifth 19 
THE WITNESS: On the instruction of my 
20 
Amendment right. 
20 
lawyer, I must assert my Fifth Amendment right. 
21 
Q. As to whether or not you recognize a 
21 
BY MR. GARCIA: 
22 
voice? 
22 
Q. What is our lace of birth? 
23 
MR. 
: Yes. 
23 
MR. 
Instruct the witness not 
24 
THE WITNESS: Yes, he has. 
24 
to answer the question. 
25 
THE VIDEOGRAPHER: And what's the 
25 
THE WITNESS: On the instruction of my 
Page 328 
Page 330 
1 
good-faith basis for asserting that privilege? 
1 
lawyer, I must invoke my Fifth Amendment right. 
2 
MR. 
I don't have to tell you 
2 
MR. GARCIA: How can that possibly 
3 
what the good-faith basis is. She's asserting 
3 
incriminate her? 
4 
a privilege as to whether she recognizes a 
4 
MR. 
: I will answer that 
5 
voice or not. If you can identify the voice, 
5 
question when a judge asks it to me. 
6 
it could potentially lead back to other places 
6 
MR. GARCIA: Do you have any case law that 
7 
that could incriminate her in theory. So, she 
7 
supports that question as subject to a Fifth 
8 
has a good faith basis to invoke it. 
8 
Amendment objection? 
9 
BY MR. GARCIA: 
9 
MR. 
: I'll answer the question 
10 
Q. Do ou have a 'ob currently? 
10 
when a judge asks it of me. 
11 
MR. 
Instruct the witness not 
11 
BY MR. GARCIA: 
12 
to answer. 
12 
Q. Did ou raduate from high school? 
13 
THE WITNESS: On the instruction of my 
13 
MR. 
: Same objection, same 
14 
lawyer, I choose to assert my Fifth Amendment 
14 
instruction. 
15 
right. 
15 
THE WITNESS: On the advice of my lawyer, 
16 
BY MR. GARCIA: 
16 
I must invoke my Fifth Amendment right. 
17 
Q. Do ou file income tax returns? 
17 
BY MR. GARCIA: 
18 
MR. 
Same instruction. 
18 
. What states have you lived in other than 
19 
THE WITNESS: On the instruction of my 
19 
an 
20 
lawyer, I choose to assert my Fifth Amendment 
20 
MR. 
: Same instruction. 
21 
right. 
21 
THE WITNESS: On the instruction of my 
22 
MR. GARCIA: The Government. presumably, 22 
lawyer, I must invoke my Fifth Amendment right. 
23 
has her income tax returns, so what is the 
23 
BY MR. GARCIA: 
24 
basis for asserting a privilege against 
24 
Q. Did ou attend college? 
25 
self-incrimination? 
25 
MR. 
: Same instruction. 
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1 
THE WITNESS: On the instruction of my 
1 
MR. KUVIN: So it's really kind of 
2 
lawyer, I must invoke my Fifth Amendment right. 
2 
comical, so I apologize for my laughing, but 
3 
BY MR. GARCIA: 
3 
it's just borderin: --
4 
Q. Have ou ever been to New Mexico? 
4 
MR. 
: Your --
5 
MR. 
Same instruction. 
5 
MR. KUVIN: -- on absurd. 
6 
THE WITNESS: On the instruction of my 
6 
MR. 
: Look, I think most of the 
7 
lawyer, I must invoke my Fifth Amendment right. 
7 
questions that the rest of you-all asked today 
8 
BY MR. GARCIA: 
8 
were absurd, and we've answered your questions 
9 
Q. Do ou have a assport? 
9 
respectfully. We didn't laugh. We didn't make 
10 
MR. 
Same instruction. 
10 
fun of you. It is unprofessional and 
11 
THE WITNESS: On the instruction of my 
11 
disrespectful of you to laugh at the witness 
12 
lawyer, I must invoke my Fifth Amendment right. 12 
when she's asserting a Constitutional right. 
13 
MR. GARCIA: The Government has access to 13 
And don't walk away from me when I'm 
14 
her passport, and you're saying that's, you can 
14 
talking to you. 
15 
object to whether or not she has a passport? 
15 
MR. KUVIN: I'm not walking away, I'm 
16 
MR. 
There's lots of things 
16 
listening. I'm not walking away at all. I'm 
17 
that there may be evidence of from other 
17 
just throwing away my trash. I apologize if it 
18 
sources that she doesn't have to admit to. She 
18 
seemed like I was walking away. 
19 
has a Constitutional right not to admit to. 
19 
MR. 
: Uh-huh, which you were. 
20 
BY MR. GARCIA: 
20 
Mr. Garcia. if you want to ask your questions, 
21 
Q. Have ou ever traveled to Mexico? 
21 
you may ask them. She will answer them. If 
22 
MR. 
Same instruction. 
22 
you don't like the questions, you can certify 
23 
THE WITNESS: On the instruction of my 
23 
them to the judge and I will be happy to 
24 
lawyer, I must invoke my Fifth Amendment right. 24 
discuss with the judge whether or not there is 
25 
25 
a good-faith basis. 
Page 332 
Page 334 
1 
BY MR. GARCIA: 
1 
MR. GARCIA: Certify all those questions. 
2 
Q. Do ou have a driver's license? 
2 
BY MR. GARCIA: 
3 
MR. 
Same instruction. 
3 
Q. Let me ask you, do you, do you deny that 
4 
THE WITNESS: On the instruction of my 
4 
you solicited a minor by the name of Jane Doe No. II 
5 
lawyer, I must invoke my Fifth Amendment right. 
5 
for the purposes of providing sexual services to 
6 
BY MR. GARCIA: 
6 
Jeffrey Epstein? 
7 
Q. Do you have a driver's license in New 
7 
MR. 
Instruct the witness not 
8 
York? 
8 
to answer. 
9 
MR. 
Same instruction. 
9 
THE WITNESS: At the instruction of my 
10 
THE WITNESS: On the instruction of my 
10 
lawyer, I must assert my Fifth Amendment right. 
11 
lawyer, I must invoke my Fifth Amendment right. 11 
BY MR. GARCIA: 
12 
BY MR. GARCIA: 
12 
Q. Do you deny that you solicited Jane Doe 
13 
Q. Are ou registered to vote? 
13 
No. 2 on multiple occasions by your cellphone in 
14 
MR. 
Same instruction. 
14 
order for her to provide sexual services for pay to 
15 
THE WITNESS: On the instruction of my 
15 
Mr. Epstein? 
16 
lawyer, I must invoke my Fifth Amendment right. 16 
MR. 
: Same instruction, same 
17 
MR. 
: Mr. Kuvin, if you'd like 
17 
objection to the form previously stated. 
18 
to keep laughing, feel free. 
18 
THE WITNESS: At the instruction of my 
19 
MR. KUVIN: I think it's absolutely absurd 
19 
lawyer, I must invoke my Fifth Amendment right. 
20 
that she's objecting to some of these questions 
20 
BY MR. GARCIA: 
21 
or taking the Fifth to some of these questions. 
21 
Q. Do you know why Jeffrey Epstein is only 
22 
I mean. I want to Sid to ask her now if the sky 
22 
interested in minor irls? 
23 
is blue. I think she's going to take the Fifth 
23 
MR. 
: Objection to the form, 
24 
as to that . uestion, as well. 
24 
standing objection. It assume she has some 
25 
MR. 
Look, I. I -- 
25 
knowledge of Jeffrey Epstein that', implicit in 
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1 
the question. 
1 
compelled by her parents to do anything. 
2 
THE WITNESS: On the instruction of my 
2 
Move on. I will debate the legal issues 
3 
lawyer. I must invoke my Fifth Amendment right. 
3 
with the judge, not with you. 
4 
BY MR. GARCIA: 
4 
BY MR. GARCIA: 
S 
6 
Q. Do your parents approve of your 
association with Mr. E 'stein? 
5 
6 
Q. Doyou have an siblings? 
MR. 
: Instruct the witness not 
/ 
MR. 
Objection to the form. 
7 
to answer. That was also asked and answered 
8 
What's -- instruct the witness not to answer. 
8 
many hours ago. 
9 
THE WITNESS: On the instruction of my 
9 
THE WITNESS: On the instruction of my 
10 
lawyer -- 
10 
lawyer, I must invoke my Fifth Amendment right. 
11 
MR. GARCIA: To the form or is this some 
11 
BY MR. GARCIA: 
12 
constitutional issue that you're raising? 
12 
Q. Have you ever discussed your relationship 
13 
MR. 
Object to the form of your 13 
with Mr. Epstein with your siblings, assuming you 
14 
question as assuming facts that have not been 
14 
have any? 
15 
established, and also it's irrelevant to lead 
15 
MR. 
: Instruct the witness not 
16 
to any admissible evidence. But to the extent 
16 
to answer the question. Objection to the form. 
17 
that you're asking any questions that could 
17 
THE WITNESS: At the instruction of my 
18 
relate to her parents, she is invoking the 
18 
lawyer, I must invoke my Fifth Amendment right. 
19 
Fifth Amendment as to that question. 
19 
BY MR. GARCIA: 
20 
THE WITNESS: At the instruction of my 
20 
Q. Do you have a fiance, boyfriend, or 
21 
lawyer, I must invoke my Fifth Amendment right. 
21 
significant other? 
22 
BY MR. GARCIA: 
22 
MR. 
: Objection to the form. 
23 
Q. How did ou meet Mr. Epstein? 
23 
Instruct the witness not to answer as to the
24 
MR. 
Instruct the witness not 
24 
Fifth Amendment. 
25 
to answer. 
25 
THE WITNESS: On the instruction of my
Page 336 
Page 338 1
1 
THE WITNESS: At the instruction of my 
1 
lawyer, I must invoke my Fifth Amendment right. 
2 
lawyer, I must invoke my Fifth Amendment right. 
2 
BY MR. GARCIA: 
3 
BY MR. GARCIA: 
3 
Q. Have you discussed your relationship with 
4 
Q. Did ourparents know Mr. Epstein? 
4 
Mr. Epstein with your boyfriend, fiance, or 
5 
MR. 
• That question I think was 
5 
significant other? 
6 
asked and answered several hours ago, and I'll 
6 
MR. 
: Objection to the form, the 
7 
instruct the witness not to answer as to Fifth 
7 
standing objection, assumes knowledge of 
8 
Amendment privilege. 
8 
Mr. Epstein, and I will instruct her not to 
9 
THE WITNESS: On the instruction of my 
9 
answer. 
10 
lawyer, I must invoke my Fifth Amendment right. 10 
THE WITNESS: On the instruction of my 
11 
BY MR. GARCIA: 
11 
lawyer, I must invoke my Fifth Amendment right. 
12 
Q. Have you ever discussed your relationship 
12 
BY MR. GARCIA: 
13 
14 
with Mr. E 
ou
tein with 
r parents?
MR. 
Objection to the form. 
13 
14 
Q. Now, you were asked before if you visited 
Mr. Epstein at the County jail; is that correct, 
15 
Instruct the witness not to answer. 
15 
here in Palm Beach County? Do you recall those 
16 
THE WITNESS: On the instruction of my 
16 
questions? 
17 
lawyer, I must invoke my Fifth Amendment right. 17 
A. I do recall being asked that. 
18 
MR. GARCIA: Wouldn't that be a waiver if 
18 
Q. All right. And did you have to fill out 
19 
she's discussed it with her parents? 
19 
any type of log when you visited the Palm Beach 
20 
MR. 
Waiver of what? 
20 
County jail and provide identification to the 
21 
MR. GARCIA: A waiver of any imagined or 
21 
Government as to what your name was, and provide 
22 
real Fifth Amendment right against 
22 
your name to the Government and who you were 
23 
self-incrimination. 
23 
visiting? 
24 
MR. 
• It's only waived if it was 
24 
MR. 
: Objection to the form
25 
compelled and you did it anyway. She %wait 
25 
because it assume, she went to the Palm Beach 
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1 
County jail. When that question was asked 
1 
lawyer, I invoke my Fifth Amendment right. 
2 
before, she invoked her Fifth Amendment 
2 
BY MR. GARCIA: 
3 
privilege, so she's not answering the question 
3 
Q. Why did you go see Jeffrey Epstein at the 
4 
this time either. 
4 
County jail? 
5 
THE WITNESS: At the instruction of my 
5 
MR. 
: Objection to the form. It 
6 
lawyer, I must invoke my Fifth Amendment right. 
6 
assumes facts that have not been acknowledged 
7 
BY MR. GARCIA: 
7 
or admitted. Instruct the witness not to 
8 
Q. Have you spoken to Jeffrey Epstein about 
8 
answer. 
9 
this deposition that ou're giving today? 
9 
THE WITNESS: At the instruction of my 
10 
MR. 
• Instruct the witness not 
10 
lawyer, I invoke my Fifth Amendment right. 
11 
to answer the question. 
11 
BY MR. GARCIA: 
12 
THE WITNESS: At the instruction of my 
12 
Q. Were your conversations monitored by 
13 
lawyer, I invoke my Fifth Amendment right. 
13 
anyone? 
14 
BY MR. GARCIA: 
14 
MR. 
: Objection to the form. It 
15 
Q. When is the last time you spoke with 
15 
assumes facts that have not been admitted or 
16 
Mr. Epstein? 
16 
acknowledged and instruct the witness not to 
17 
MR. 
Instruct the witness not 
17 
answer. 
18 
to answer the question. 
18 
THE WITNESS: At the instruction of my 
19 
THE WITNESS: On the instruction of my 
19 
lawyer, I invoke my Fifth Amendment right. 
20 
lawyer, I invoke my Fifth Amendment right. 
20 
BY MR. GARCIA: 
21 
BY MR. GARCIA: 
21 
Q. Let me show you what's been filed on your 
22 
Q. Was anybody else in the room when you 
22 
behalf as an answer with affirmative defenses. I 
23 
spoke to Mr. E stein besides the two of you? 
23 
have some extra copies here. We'll mark her copy as 
24 
MR. 
Instruct the witness not 
24 
Exhibit --
25 
to answer the question. Object to the form 
25 
THE COURT REPORTER: 15. Yes, 15.
Page 340 
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1 
because it assumes any knowledge of 
1 
MR. GARCIA: What is it, 15? 
2 
Mr. Epstein. 
2 
THE COURT REPORTER: 15. yes. 
3 
THE WITNESS: At the instruction of my 
3 
(Plaintiffs Exhibit No. 15 was marked for 
4 
lawyer, I invoke my Fifth Amendment right. 
4 
identification.) 
5 
BY MR. GARCIA: 
5 
BY MR. GARCIA: 
6 
Q. Where are ou currently staying? 
6 
Q. Could you please take a look at that 
7 
MR. 
: Instruct the witness not 
7 
document. 
8 
to answer. 
8 
A. Do you want me to read the whole thing? 
9 
BY MR. GARCIA: 
9 
Q. No, just take a look at it so I can ask 
10 
Q. Are ou current) engaged -- 
10 
you if you've ever seen it before. 
11 
MR. 
: Hold on. Hold on. Let 
11 
MR. 
: You can answer. 
12 
her -- let her respond. 
12 
THE WITNESS: No. no. 
13 
THE WITNESS: At the instruction of my 
13 
BY MR. GARCIA: 
14 
lawyer, I invoke my Fifth Amendment right. 
14 
Q. Were you aware that you were a Defendant 
15 
BY MR. GARCIA: 
15 
in a civil action filed by Jane Doe II, in the 
16 
Q. Are you currently engaged in any criminal 
16 
United States District Court Southern District of 
17 
activity at the wherever it is that you're staying? 
17 
Florida? 
18 
MR. 
: Object to the form in that 18 
MR. 
: You can answer that other 
19 
it requires a legal conclusion. Second of all, 
19 
than if it involves discussions, private 
20 
I believe it's meant more for harassment than 
20 
discussions you had with your lawyers. 
21 
to lead to any discoverable evidence. Third of 
21 
THE WITNESS: I only would have if my 
22 
all, she's instructed not to answer the 
22 
lawyer told me. I don't know for sure. 
23 
question based on her Fifth Amendment 
23 
BY MR. GARCIA: 
24 
privilege. 
24 
Q. Okay. Take a look at Page 5. Do you see 
25 
THE WITNESS: On the instruction of my 
25 
the section that begins with "Affirmative defenses"? 
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1 
A. Uh-huh. Yes. 
1 
BY MR. GARCIA: 
2 
Q. Do you have any evidence to support the 
2 
Q. Did you have any conversations with 
3 
first affirmative defense, and I'll tell you for the 
3 
Jane Doe No. II at any time in which she told you 
4 
record that Jane Doe II, is Jane Doe No. II. was a 
4 
that she was a, she consented and was a willing 
S 
willing participant in the acts alleged. and 
5 
participant in the acts that are alleged in the 
6 
7 
therefore her claims are barred or her damages are 
required to be reduced accordingly? 
6 
7 
complaint with Jeffre . 
rein?
MR. 
: Object to the form because 
8 
MR. 
I'm sony. Can you repeat 
8 
it assumes knowledge of Jane Doe No. II. And 
9 
the question that you're asking? 
9 
the witness is going to her invoke her Fifth 
10 
MR. GARCIA: Can you read it back? 
10 
Amendment privilege as to any evidence or any 
11 
(The requested portion of the record was 
11 
knowledge of Jane Doe No. II. 
12 
read by the reporter.) 
12 
THE WITNESS: At the instruction of my 
13 
BY MR. GARCIA: 
13 
lawyer, I must invoke my Fifth Amendment right. 
14 
Q. Do you have any evidence to support that 
14 
BY MR. GARCIA: 
15 
affirmative defense? 
15 
Q. The second affirmative defense on the same 
16 
A. I don't understand the question. 
16 
page it says, "As to Plaintiffs claim, Plaintiff 
17 
Q. Okay. This affirmative defense alleges on 
1'i 
actually consented to and participated in conduct 
18 
your behalf by Mr. 
claims that Jane Doe 
18 
similar and are identical to the acts alleged with 
19 
No. II consented to and was a willing participant in 
19 
other persons which were the sole or contributing 
20 
the acts alleged, and therefore her claims were 
20 
cause of Plaintiffs alleged damages." 
21 
barred or her damages were required to be reduced. 
21 
Do you have any facts to support the 
22 
Do you have any factual basis for 
22 
second affirmative defense? 
23 
asserting that defense, and if so. what facts do you 
23 
MR. 
: And once again to the 
24 
have to sup ion it? 
24 
extent that, the. the question -- object to the 
25 
MR. 
Do you understand the 
25 
form to the extent the question requires her to 
Page 344 
Page 346 
1 
question? 
1 
acknowledge any knowledge of Jane Doe No. II or 
2 
THE WITNESS: Uh-uh. 
2 
Jane Doe No. II's activities she would invoke 
3 
THE COURT REPORTER: Is that a yes? 
3 
her Fifth Amendment privilege. I would 
4 
THE WITNESS: Yes, sony. 
4 
instruct her to do so. 
5 
MR. 
: You can answer if you can 
5 
THE WITNESS: On the instruction of my 
6 
answer. 
6 
lawyer, I must invoke my Fifth Amendment right. 
7 
THE WITNESS: I'm sorry. Do I have any 
7 
BY MR. GARCIA: 
8 
facts. 
8 
Q. So I don't waste any time with the court 
9 
BY MR. GARCIA: 
9 
on these issues, can you tell me at least a yes or 
10 
Q. Right. What, what evidence do you have to 
10 
no as to whether or not you have any facts to 
11 
support the claim that Jane Doe No. II consented to 
11 
support. without telling me what the facts are, 
12 
and was a willing participant with Jeffrey Epstein 
12 
whether or not you have any facts to support the 
13 
in the acts described in the complaint? 
13 
defenses? 
14 
MR. 
: I am just consulting on 
14 
MR. 
Whether she personally 
15 
what might be a privilege issue. 
15 
does? 
16 
(A discussion was held off the record.) 
16 
MR. GARCIA: Yes, exactly. personally. 
17 
MR. 
: A portion of the truth of 
17 
MR. 
-- or has her defense team 
18 
that would require attorney-client privilege 
18 
acting on her behalf? 
19 
information, so I am going to instruct her not 
19 
MR. GARCIA: No, just personally. 
20 
to answer that portion of it, and ask that -- 
20 
MR. 
No, I am going to instruct 
21 
MR. GARCIA: Okay. 
21 
her not to answer based on her Fifth Amendment. 
22 
MR. 
: Hold it. Okay. And as to 
22 
BY MR. GARCIA: 
23 
the rest. I'll instruct her not to answer the 
23 
Q. Do you have any information to support 
24 
question based on her Fifth Amendment 
24 
the, any facts to support the third affirmative 
25 
privilege. 
25 
defense that the Plaintiff impliectly consented to 
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