EFTA01246511

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1 
the acts alleged by not objecting. and therefore her 
1 
page? 
2 
claims are barred or her damages are required to be 
2 
A. What page, sir? 
3 
reduced accordin 1 ? 
3 
Q. Page 6. It says, "As to Plaintiff's 
4 
MR. 
Once again I would assert 
4 
claim, Defendant reasonably, reasonably believed or 
S 
an attorney-client privilege as to -- this, 
5 
was told that the Plaintiff had attained the age of 
6 
this question that you have asked requires a 
6 
18 years old at the time of the alleged acts." 
/ 
legal conclusion which would require her to -- 
7 
Who told you that the Plaintiff was 18 at 
8 
MR. GARCIA: I'm not asking for the legal 
8 
the time of the acts involved in this case? 
9 
conclusion. I'm asking what facts she has to 
9 
MR. 
Again, I would instruct 
10 
support an affirmative defense which requires 
10 
the witness not to answer the question based on 
11 
you to put on evidence of what that defense is. 
11 
both the attorney-client privilege and her 
12 
MR. 
Right. But you're asking 
12 
Fifth Amendment privilege against 
13 
her what evidence she has of legal conclusions, 
13 
self-incrimination. 
14 
which is concepts such as consent, claims being 
14 
THE WITNESS: At my lawyer's instruction. 
15 
barred, damages required to be reduced 
15 
I must assert my Fifth Amendment right. 
16 
accordingly. those are legal concepts you're 
16 
BY MR. GARCIA: 
17 
asking her to make, a lay person to give a 
17 
Q. At the time that Jane Doe No. II was 
18 
statement as to what the factual evidence is 
18 
involved in some sort of a relationship, if you can 
19 
there to support a legal conclusion. The only 
19 
call it that, with Mr. Epstein, did you have 
20 
way she would know if they support the legal 
20 
counsel? Didyou have a lawyer representing 
21 
conclusion is based on conversations she's had 
21 
you? 
MR. 
Object to the form. 
22 
with counsel. 
22 
She -- the question assumes that them is any 
23 
MR. GARCIA: So, are you instructing her 
23 
knowledge of any relationship between Jane Doe 
24 
not to answer on that basis or -- 
24 
No. II and a person named Mr. Epstein. She's 
25 
MR. 
Yes, that's right, yeah. 
25 
not going to answer the question based on the 
Page 348 
Page 350 
1 
MR. GARCIA: -- the Fifth Amendment 
1 
Fifth Amendment. 
2 
privilege? 
2 
THE WITNESS: At the instruction of my 
3 
MR. 
On, on that basis only. 
3 
lawyer, I assert my Fifth Amendment right. 
4 
As to that question I am instructing her not to 
4 
BY MR. GARCIA: 
5 
answer on the basis of the attorney-client 
5 
Q. Did Jane Doe No. II ever tell you that she 
6 
privilege. 
6 
was 18 at the time of the alleged acts? 
7 
BY MR. GARCIA: 
7 
MR. 
Object to the form. 
8 
Q. Outside of your discussions with counsel. 
8 
Instruct the witness not to answer based on the 
9 
do you have any facts to support the third 
9 
Fifth Amendment. 
10 
affirmative defense based upon your discussions with 10 
THE WITNESS: On the instruction of my 
11 
Jane Doe No. II or discussions with any other person 11 
lawyer, I assert my Fifth Amendment right. 
12 
or review independently of your counsel of any 
12 
BY MR. GARCIA: 
13 
document that would support this third affirmative 
13 
Q. I think the Fifth Affirmative Defense is 
14 
defense? 
14 
pretty much similar, but it says, "As to Plaintiffs 
15 
MR. 
Object to the form to the 
15 
claim, Plaintiffs claims are barred as she said she 
16 
extent that it requires any acknowledgment of 
16 
was 18 years or older at the time," end quote. I 
17 
any knowledge of Jane Doe No. II, I would 
17 
assume that you're referring to yourself; she told 
18 
instruct her not to answer the question based 
18 
that she was 18 tears old at the time? 
19 
on the Fifth Amendment. 
1 9 
you 
MR. 
Instruct the witness not 
20 
THE WITNESS: Upon my lawyer's 
20 
to answer based on her Fifth Amendment 
21 
instruction, I choose to exert my Fifth 
21 
privilege. 
22 
Amendment right. 
22 
BY MR. GARCIA: 
23 
BY MR. GARCIA: 
23 
Q. Do you have any evidence to support that 
24 
Q. The fourth affirmative defense on Page 6 
24 
assertion; that is did you make any journal 
25 
of Exhibit 15. could >ou turn to that on the next 
25 
entries — by the way. do you keep any type of 
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journal or di 
? 
1 
BY MR. GARCIA: 
2 
MR. 
: Instruct the witness not 
2 
Q. I'm going to give you some dates here. If 
3 
to answer based on the Fifth Amendment. 
3 
you want to, I don't know if he wants to write them 
4 
BY MR. GARCIA: 
4 
down or take them one at a time: June 16th, 2003; 
5 
Q. Have ou ever ke t -- 
5 
July 2nd, 2003; April 9th, 2004; June 7th, 2004; 
6 
: 
MR. 
Hold on, please. Let her, 
6 
July 30th, 2004; August 30th, 2004; October 9th, 
7 
let her answer. 
7 
2004; October 12th, 2004; October 30th. 2004; and 
8 
THE WITNESS: On the instruction of my 
8 
November 9th, 2004. Do you recall soliciting Jane 
9 
lawyer, I assert my Fifth Amendment right. 
9 
Doe No. II to come to Jeffrey Epstein's home on any 
10 
BY MR. GARCIA: 
10 
of those dates? 
11 
Q. Have you ever kept a journal or diary in 
11 
MR. 
Objection to the form. 
12 
the past? 
12 
Standing objection as previously stated as to 
13 
MR. 
: Same instruction. 
13 
any knowledge of Jeffrey Epstein or Jane Doe 
14 
THE WITNESS: At the instruction of my 
14 
No. II, and instruct the witness not to answer. 
15 
lawyer. I assert my Fifth Amendment right. 
15 
THE WITNESS: On the instruction --
16 
BY MR. GARCIA: 
16 
MR. GARCIA: Okay. So your instruction is 
17 
Q. As to the sixth affirmative defense, what 
17 
not based on Fifth Amendment? 
18 
evidence do you have that Plaintiffs alleged 
18 
MR. 
It is. I am instructing 
19 
damages were caused in whole or in part by events 
19 
her not to answer based on Fifth Amendment. 
20 
and/or circumstances completely unrelated to the 
20 
THE WITNESS: On the instruction of my 
21 
incidents alle: ed in the complaint? 
21 
lawyer, I must exercise my Fifth Amendment 
22 
MR. 
: As to that, I would assert 22 
right. 
23 
an attorney-client privilege. 
23 
BY MR. GARCIA: 
24 
BY MR. GARCIA: 
24 
Q. Do you contest, in any way, that Jane Doe 
25 
Q. Well, do you have a witness that you can 
25 
No. II was solicited by you on each of these dates 
Page 352 
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1 
identify that will testif about this? 
1 
for the 
of 
Jeffrey Epstein with
2 
MR. 
Instruct the witness not 
2 
purposes 
providing 
sexual massa es and/or services.
3 
to answer that based on the Fifth Amendment 
3 
MR. 
Objection to form. It's a 
4 
privilege. She doesn't have to help you. 
4 
compound question. It assumes facts that she's 
5 
THE WITNESS: On the instruction of my 
5 
not acknowledged or admitted. It is therefore 
6 
lawyer, I exert my Fifth Amendment right. 
6 
compound and ambiguous. I would instruct her 
7 
MR. GARCIA: All right. So your position 
7 
not to answer based on her Fifth Amendment 
8 
is that you don't have to answer any questions 
8 
privilege. 
9 
about affirmative defenses, but yet you can 
9 
BY MR. GARCIA: 
30 
maintain them? 
10
Q. Where did ou live in 2003?
11 
MR. 
: That's not what I said. 
11 
MR. 
Instruct the witness not 
12 
You asked to identify a particular witness. If 
12 
to answer based on the Fifth Amendment. 
13 
identifying a witness could potentially lead to 
13 
THE WITNESS: At the instruction of my 
14 
putting herself in jeopardy for criminal 
14 
lawyer, I must exercise my Fifth Amendment 
15 
prosecution, she doesn't have to answer. 
15 
right. 
16 
MR. GARCIA: This would be a witness that 16 
BY MR. GARCIA: 
17 
would support her defense, not, not cause her 
17 
Q. What cellphone number did you have in 
18 
criminal •rosecution. 
18 
2003? 
19 
MR. 
I, I understand your 
19 
MR. 
Same instruction. 
20 
point, and my point is if identifying such a 
20 
THE WITNESS: At the instruction of my 
21 
witness could also lead her potentially to 
21 
lawyer I must exert my Fifth Amendment right. 
22 
criminal prosecution by the Government, she 
22 
BY MR. GARCIA: 
23 
doesn't have to answer that question and she's 
23 
Q. Where did ou live in 2004?
24 
not going to. Witnesses can have many factual 
24 
MR. 
Same instruction. 
25 
purposes. 
25 
THE WITNESS: At the instruction of my 
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lawyer I must exercise my Fifth Amendment 
1 
BY MR. GARCIA: 
2 
right. 
2 
Q. There was some doctor that was -- you were 
3 
4 
BY MR. GARCIA: 
Q. What cellphone number did you have in 
3 
4 
asked about earlier toda . Do you recall his name? 
MR. 
: The name that was asked o 
5 
2004? 
5 
her? If you remember --
6 
MR. 
: Same instruction. 
6 
MR. KUVIN: It's Dr. —
7 
THE WITNESS: At the instruction of my 
7 
MR. GOLDBERGER: Feelgood? 
8 
lawyer I just exercise my Fifth Amendment 
8 
MR. KUVIN: No. that's your doctor. Jack. 
9 
right. 
9 
Dr. -- hang on. III get it for you. 
10 
BY MR. GARCIA: 
10 
MS. F7PI I : Bard, it was Bard. 
11 
Q. Where did you first recruit Jane Doe 
11 
MR. KUVIN: Bard. B-a-r-d, I believe. 
12 
No. II for soliciting her to provide sexual services 
12 
MR. GARCIA: Dr. Bard. I think that's 
13 
to Jeffrey E . stein? 
13 
right. 
14 
MR. 
: Objection to the form. 
14 
BY MR. GARCIA: 
15 
Standing objection previously stated. Instruct 
15 
Q. Do you know a Dr. Bard? 
16 
the witness not to answer based on her Fifth 
16 
THE WITNESS: At the instruction of my 
17 
Amendment. 
17 
lawyer, I choose to exercise my Fifth Amendment 
18 
THE WITNESS: At the instruction of my 
18 
right. 
19 
lawyer I must exercise my Fifth Amendment 
19 
BY MR. GARCIA: 
20 
right. 
20 
Q. Did Dr. Bard ever provide any type of 
21 
22 
BY MR. GARCIA: 
Q. Did you go to clubs where young women hung 
21 
22 
dental services 
MR. 
ces to ou? 
: Objection to the form. It 
23 
out and approach them in order to solicit them for 
23 
assumes facts that have not been established 
24 
Mr. Epstein? 
24 
that she's ever seen by Dr. Bard. So, once 
25 
MR. 
: Objection to the form. It 
25 
again, we assert a Fifth Amendment privilege. 
Page 356 
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1 
assumes knowledge of Mr. Epstein, therefore I 
1 
THE WITNESS: At the instruction of my 
2 
instruct the witness not to answer based on the 
2 
lawyer, I must exercise my Fifth Amendment 
3 
Fifth Amendment privilege. 
3 
right. 
4 
THE WITNESS: At the instruction of my 
4 
BY MR. GARCIA: 
5 
lawyer, I must exercise my Fifth Amendment 
5 
Q. Have you ever had any dental work done in 
6 
right. 
6 
the past ten years? And I don't mean cavities. fm 
7 
BY MR. GARCIA: 
7 
talking about cosmetic-type dental work. 
8 
Q. Did you ever pay Jane Doe No. II for 
8 
A. Yes, sir. 
9 
10 
sexual services and/or sexual massages provided to 
Mr. Epstein? 
9 
10 
Q. All ri ht. What state was it in? 
MR. 
One second. 
11 
MR. 
Objection to the form for 11 
MR. GOLDBERGER: Excuse me. 
12 
the reasons previously stated in the standing 
12 
MR. 
You can answer. You can 
13 
objection. Instruct the witness not to answer, 
13 
answer as to what state it occurred. 
14 
based on the Fifth Amendment. 
14 
THE WITNESS: In New York. 
15 
THE WITNESS: On the instruction of my 
15 
BY MR. GARCIA: 
16 
lawyer, I choose to exercise my Fifth Amendment 16 
Q. Was the dental work paid for by anyone 
17 
right. 
17 
other than yourself? 
18 
BY MR. GARCIA: 
18 
MR. 
Instruct the witness not 
19 
Q. Did ou a in U.S. currency? 
19 
to answer based on the Fifth Amendment 
20 
MR. 
Same objection, same 
20 
privilege. 
21 
instruction. 
21 
THE WITNESS: At the instruction of my 
22 
THE WITNESS: On the instruction of my 
22 
lawyer, I must assert my Fifth Amendment right. 
23 
lawyer, I choose to exercise my Fifth Amendment 23 
BY MR. GARCIA: 
24 
right. 
24 
Q. What was the name of the doctor that 
25 
25 
rovided the cosmetic dental services? 
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Page 359 
MR. 
You can answer. Sony, 
wait a minute. 
Instruct the witness not to answer the 
question based on the Fifth Amendment. 
BY MR. GARCIA: 
Q. Did Jeffre 
stein --
MR. 
: Hold on. You have to let 
1 
2 
3 
4 
6 
7 
Page 361 
any type of surgical procedure performed on his 
penis? 
MR. 
Objection to the form to 
the extent it assumes any knowledge of 
Mr. Epstein and instruct the witness not to 
answer. 
THE WITNESS: On the instruction of my 
8 
her assert her privilege. 
8 
lawyer, I must invoke my Fifth Amendment right. 
9 
THE WITNESS: At the instruction of my 
9 
BY MR. GARCIA: 
10 
lawyer, I must assert my Fifth Amendment right. 10 
Q. Has he ever told you that he's ever had a 
11 
BY MR. GARCIA: 
11 
penile implant added to his penis? 
12 
Q. Did Jeffrey Epstein suggest that you get 
12 
MR. 
Same instruction, same 
13 
the dental work done? 
13 
objection. 
14 
MR. 
: Instruct the witness not 
14 
THE WITNESS: On the instruction of my 
15 
to answer. Objection to the form, instruct the 
15 
lawyer, I must invoke my Fifth Amendment right. 
16 
witness not to answer. 
16 
BY MR. GARCIA: 
17 
THE WITNESS: On the instruction of my 
17 
Q. Has Mr. Epstein -- have you ever observed 
18 
lawyer, I must assert my Fifth Amendment right. 18 
Mr. Epstein or has he ever told you that he takes 
19 
BY MR. GARCIA: 
19 
Viagra or Cialis? 
20 
Q. Do ou know Kevin Spacey? 
20 
MR. 
Objection to the form. 
21 
MR. 
: Are you asking if she's 
21 
Standing objection. It assumes knowledge of 
22 
ever met Kevin Spacey? 
22 
Mr. Epstein, and therefore I would instruct the 
23 
MR. GARCIA: Yes, I'm sorry. 
23 
witness not to answer. 
24 
MR. KUVIN: Them you go. 
24 
THE WITNESS: On the instruction of my 
25 
MR. 
Instruct the witness not 
25 
lawyer, I must invoke my Fifth Amendment right. 
Page 360 
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1 
to answer the question. 
1 
BY MR. GARCIA: 
2 
THE WITNESS: At the instruction of my 
2 
Q. Did you ever meet Lewis or Dorothy 
3 
lawyer, I must invoke my Fifth Amendment right. 
3 
Cullman, C-u-1-1-m-a-n? 
4 
BY MR. GARCIA: 
4 
MR. GARCIA: I think the look means that 
5 
Q. Did ou ever met Chris Tucker? 
5 
she's goin to oliect. 
6 
MR. 
Same instruction. 
6 
MR. 
: Are you asking -- I just 
7 
THE WITNESS: At the instruction of my 
7 
want to clarify the question. Are you asking 
8 
lawyer I must invoke my Fifth Amendment 
8 
if she has ever met a person she knows to have 
9 
privilege. 
9 
that name or if she's ever --
10 
BY MR. GARCIA: 
10 
MR. GARCIA: Yes. 
11 
Q. Did ou ever meet Bill Clinton? 
11 
MR. 
: You can answer the 
12 
MR. 
Same instruction. 
12 
question. 
13 
THE WITNESS: On the instruction of my 
13 
THE WITNESS: No. 
14 
lawyer, I must invoke my Fifth Amendment right. 14 
MR. GARCIA: There were two people, Lewis 
15 
BY MR. GARCIA: 
15 
L-e-w-i-s and Dorothy Cullman. 
16 
Q. Did you ever fly with these three 
16 
MR. 
: So it's split it in two 
17 
gentlemen and Jeffrey Epstein to Africa on Jeffrey 
17 
questions. Do Lewis first and Dorothy second. 
18 
Epstein's 727 ai lane? 
18 
Have you met Lewis? 
19 
MR. 
: Objection to the form. 
19 
THE WITNESS: No. 
20 
It's a compound question. Instruct the witness 
20 
MR. 
: Dorothy? 
21 
not to answer based on the Fifth Amendment. 
21 
THE WITNESS: No. 
22 
THE WITNESS: At the instruction of my 
22 
BY MR. GARCIA: 
23 
lawyer, I must invoke my Fifth Amendment right. 23 
Q. Have you had any other type of cosmetic 
24 
BY MR. GARCIA: 
24 
surgery other than the dental surgery that you 
25 
Q. Has Mr. Epstein ever told jou that he had 
25 
talked about? 
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MR. 
What -- we're getting. 
1 
Fifth Amendment on who this dentist was? 
2 
we're getting into personal privacy issues 
2 
MR. 
Yes, she did. 
3 
here. Can we, can we get a little foundation 
3 
BY MR. GARCIA: 
4 
for why that's relevant? 
4 
Q. Do you have a Facebook page? 
5 
MR. GARCIA: I don't think I have to 
5 
A. No. 
6 
reveal that to you, but I would proffer this. 
6 
Q. Have you ever had one? 
/ 
that if Mr. Epstein paid for it. it might lead 
7 
A. I may have started one, but I, for like ten 
8 
to perh s bias on the art of the witness. 
8 
minutes. 
9
MR. 
Well, why don't you ask it 
9 
Q. You started one for ten minutes. Did you 
10 
that way? She's ever had any surgery that was 
10 
turn it off after ten minutes? 
11 
paid for by Mr. Epstein or otherwise funded by 
11 
A. Yes. 
12 
Mr. Epstein. 
12 
Q. What year was this? 
13 
MR. KUVIN: On behalf of the other -- on 
13 
A. I don't remember. 
14 
behalf of the other Plaintiffs as well. I would 
14 
Q. What prompted you to turn it off after ten 
15 
say that for identification purposes it becomes 
15 
minutes? 
16 
imperative if some of the other girls have 
16 
A. I think it's a stupid site. 
17 
alleged. as the have in their complaints that 
17 
Q. How about a --is it called MyFace or 
18 
they saw Ms. M 
when they arrived at the 
18 
MySpace? Sony. MySpace. 
19 
home if she's changed her physical appearance, 
19 
MR. KUVIN: It's not YourFace, sorry. Sid. 
20 
at the date that we go to trial. I believe that 
20 
MR. GARCIA: Trust me, you don't want to 
21 
any cosmetic surgery she has might be relevant 
21 
get that on there. 
22 
to the case. 
22 
BY MR. GARCIA: 
23 
MR. 
• I understand. I 
23 
Q. How about a MySpace page, have you ever 
24 
understand. Hold on one second. No. You can 
24 
had one of those? 
25 
go ahead and ask. 
25 
A. No. 
Page 364 
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BY MR. GARCIA: 
1 
Q. No. what, what name did you use on the 
2 
Q. Okay. Have you ever had any other type of 
2 
Facebook page? 
3 
cosmetic sure that was financed by Mr. Epstein? 
3 
A. I don't remember. 
4 
MR. 
: Objection to the form in 
4 
Q. Did Jeffrey Epstein suggest that wouldn't 
5 
that it assumes Mr. Epstein, any knowledge of 
5 
be such a good idea? 
6 
Mr. Epstein. But if you want to ask her -- go 
6 
MR. 
: Objection to the form. 
7 
ahead and ask her the general question, has she 
7 
Standing objection. Instruct the witness not 
8 
ever had it done by anybody, paid by anybody. 
8 
to answer based on Fifth Amendment. 
9 
MR. GARCIA: All right. 
9 
THE WITNESS: At the advice of my lawyer, 
10 
BY MR. GARCIA: 
10 
I must invoke my Fifth Amendment right. 
11 
Q. Have you ever had any other cosmetic 
11 
BY MR. GARCIA: 
12 
surgery? 
12 
Q. Where were you when you set up a Facebook 
13 
A. No. 
13 
page for about ten minutes? 
14 
Q. What type of dental procedure did you have 
14 
MR. 
: Objection to the form. 
15 
done? 
15 
Sony. Instruct the witness not to answer. 
16 
A. Invisalign. 
16 
based on the Fifth Amendment. 
17 
Q. And what is that? 
17 
THE WITNESS: At the instruction of my 
18 
A. Straightens your teeth. 
18 
lawyer, I must invoke my Fifth Amendment right. 
19 
Q. Is it something that you wear? 
19 
BY MR. GARCIA: 
20 
A. Sometimes. Not all the time. 
20 
Q. Do you know who Max Brockman, 
21 
Q. You're still wearing it today? 
21 
B-r-o-c-k-m-a-n is? 
22 
A. No. 
22 
MR. 
: Instruct the witness not 
23 
Q. And what year was the dental process done? 23 
to answer based on the Fifth Amendment. 
24 
A. Started two years ago. 
24 
THE WITNESS: At the instruction of my 
25 
MR. GARCIA: I'm sorry. Did you take the 
25 
lawyer. I must invoke my Filth Amendment right. 
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1 
BY MR. GARCIA: 
1 
lawyer, I must invoke my Fifth Amendment right. 
2 
Q. Doyou know who
is? 
2 
BY MR. GARCIA: 
3 
MR. 
Same instruction. 
3 
Q. Were you home schooled by your parents or 
4 
THE WITNESS: At the instruction of my 
4 
one of your parents, or someone else? 
5 
lawyer. I must invoke my Fifth Amendment right. 
5 
A. Myself. 
6 
BY MR. GARCIA: 
6 
Q. Do you know what the name of the program 
7 
Q. Do you hold any professional licenses 
7 
was that authorized ou to home school yourself? 
8 
issued by an . an state? 
8 
MR. 
: Instruct the witness not 
9 
• 
MR. 
Hold on a second. You can 
9 
to answer based on the Fifth Amendment.
10 
answer. 
10 
THE WITNESS: On the advice of my counsel, 
11 
THE WITNESS: No. 
11 
I must invoke my Fifth Amendment right. 
12 
BY MR. GARCIA: 
12 
BY MR. GARCIA: 
13 
Q. Have you ever held a professional license? 
13 
Q. Have you ever been a licensed masseuse? 
14 
A. No. 
14 
A. No. 
15 
Q. Do you have any degrees? 
15 
Q. Have you ever taken any courses to become 
16 
A. No. Well -- 
16 
a licensed masseuse? 
17 
Q. Well -- I'm sorry. go ahead. 
17 
A. No. 
18 
A. College degrees or... 
18 
Q. Have you applied for any licenses and been 
19 
Q. Any type of degree. high school, college. 
19 
turned down for same? 
20 
A. I have a high school degree. 
20 
A. No. 
21 
Q. And what year did you receive that degree? 
21 
Q. Do you have any facts to deny that 
22 
A. I'm really bad with years. I can't say for 
22 
Mr. Epstein digitally penetrated Jane Doe No. II on 
23 
sure. 
23 
each of the about ten occasions that I listed before 
24 
Q. Okay. And what high school did you 
24 
for you? 
25 
receive it from? 
25 
MR. 
: Objection to the form of 
Page 368 
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1 
MR. 
Instruct the witness not 
1 
the question in that it assumes knowledge of 
2 
to answer based on Fifth Amendment. 
2 
Mr. Epstein and Ms. Doe No. II. It's a 
3 
THE WITNESS: On the instruction of my 
3 
compound question. It's ambiguous. And I 
4 
lawyer, I must invoke my Fifth Amendment right. 
4 
instruct the witness not to answer based on the 
5 
BY MR. GARCIA: 
5 
Fifth Amendment. 
6 
Q. Were you associated with Mr. Epstein at 
6 
THE WITNESS: On the instruction of my 
7 
8 
the time that ou attended high school? 
MR. 
Objection to the form. 
7 
8 
lawyer, I must exercise my Fifth Amendment 
right. 
9 
Standing objection. Instruct the witness not 
9 
BY MR. GARCIA: 
10 
to answer. 
10 
Q. Did you know that Mr. Epstein would 
11 
THE WITNESS: At the instruction of my 
11 
digitally penetrate Jane Doe No. ll prior to 
12 
lawyer, I must invoke my Fifth Amendment right. 12 
soliciting her for massy es of Mr. Epstein? 
13 
BY MR. GARCIA: 
13 
MR. 
: Same objection as stated 
14 
Q. Was it a 'ublic or . 'vale high school? 
14 
to the previous question, the standing 
15 
MR. 
You can answer that. 
15 
objection to form and instruct the witness not 
16 
THE WITNESS: 
16 
to answer. 
17 
BY MR. GARCIA: 
17 
MR. GARCIA: Did you --
18 
Q. But you still got a degree from some 
18 
MR. 
: Hold on. 
19 
entity; is that correct? 
19 
THE WITNESS: On the instruction of my 
20 
A. Yes. 
20 
lawyer, I must invoke my Fifth Amendment right. 
21 
Q. What was the entity that issued you a 
21 
BY MR. GARCIA: 
22 
degree? 
22 
Q. Did you discuss what type of activities 
23 
MR. 
Instruct the witness not 
23 
Mr. Epstein would engage in with Jane Doe No. II 
24 
to answer based on the Fifth Amendment. 
24 
prior to soliciting her for massages and sexual play 
25 
THE WITNESS: On the instruction of my 
25 
with Mr. Epstein? 
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Page 373 
1 
MR. 
Object to the form of the 
1 
lawyer, I invoke my Fifth Amendment right. 
2 
question as ambiguous and standing objection as 
2 
BY MR. GARCIA: 
3 
well. Instruct the witness not to answer. 
3 
Q. Do ou own an automobile?
4 
THE WITNESS: On the instruction of my 
4 
MR. 
Same instruction. 
5 
lawyer, I must invoke my Fifth Amendment right. 
5 
THE WITNESS: On the instruction of my 
6 
BY MR. GARCIA: 
6 
lawyer, I invoke my Fifth Amendment right. 
7 
Q. Did Mr. Epstein ever tell you that he had 
7 
BY MR. GARCIA: 
8 
9 
sought out psychological or psychiatric treatment 
for any reason? 
9 
8 
Q. Who aid for our automobile? 
MR. 
Same instruction. 
10 
MR. 
Instruct the witness not 
10 
THE WITNESS: On the instruction of my 
11 
to answer based on the standing objection. 
11 
lawyer, I invoke my Fifth Amendment. 
12 
Objection to form. 
12 
BY MR. GARCIA: 
13 
THE WITNESS: On the instruction of my 
13 
Q. Has Jeffrey Epstein ever purchased an 
14 
15 
lawyer, I must invoke my Fifth Amendment right. 
BY MR. GARCIA: 
14 
15 
automobile for ou? 
MR. 
Objection to the form 
16 
•. 
16 
based upon the standing objection and instruct 
17 
the witness not to answer. 
18 
THE WITNESS: On the instruction of my 
19 
MR. 
Objection to the form, the 19 
lawyer, I invoke my Fifth Amendment right. 
20 
standing objection. Instruct the witness not 
20 
BY MR. GARCIA: 
21 
to answer. 
21 
Q. What limousine service do you use in New 
22 
THE WITNESS: At the instruction of my 
22 
York when ou move from place to place?
23 
lawyer, I must invoke my Fifth Amendment right. 23 
MR. 
Same instruction. 
24 
BY MR. GARCIA: 
24 
THE WITNESS: On the instruction of my 
25 
Q. Do you own a home or some son of a condo 
25 
lawyer, I invoke my Fifth Amendment right. 
Page 372 
Page 374 
1 
or anything like that? 
1 
BY MR. GARCIA: 
2 
3 
MR. 
Instructthe witness not 
to answer based on the Fifth Amendment 
2 
3 
Q. Who a s for our limousine service? 
MR. 
: Same instruction. 
4 
privilege. 
4 
THE WITNESS: On the instruction of my 
5 
THE WITNESS: On the instruction of my 
5 
lawyer, I invoke my Fifth Amendment right. 
6 
lawyer, I must invoke my Fifth Amendment right. 
6 
BY MR. GARCIA: 
7 
BY MR. GARCIA: 
7 
Q. How do you spend your typical day in New 
8 
Q. Do ou a rent to any landlord? 
8 
York?
9 
MR. 
Same instruction. 
9 
MR. 
: Instruct the witness not 
10 
THE WITNESS: On the instruction of my 
10 
to answer based on the Fifth Amendment. Also 
11 
lawyer, I must invoke my Fifth Amendment right. 11 
objection to the form as to what's a typical 
12 
BY MR. GARCIA: 
12 
day. 
13 
Q. The lace where ou live, who owns it? 
13 
BY MR. GARCIA:
14 
MR. 
: Same instruction. 
14 
Q. Monday through Friday, typical work hours. 
15 
THE WITNESS: At the instruction of my 
15 
say 9:00 to 5:00, what do you typically do Monday 
16 
17 
lawyer, I must invoke my Fifth Amendment right. 
BY MR. GARCIA: 
16 
17 
through Frida . 9:00 to 5:00 p.m.? 
MR. 
: Instruct the witness not 
18 
Q. Do you exit a building in New York where 
18 
to answer based on the Fifth Amendment. 
19 
you exit from a different buildings parking garage: 
19 
THE WITNESS: At the instruction of my 
20 
in other words, do you exit -- strike that. 
20 
lawyer, I must invoke my Fifth Amendment right. 
21 
Do you use a different parking garage to 
21 
BY MR. GARCIA: 
22 
exit the, from the buildin where you live? 
22 
Q. What is Financial Trust Company?
23 
MR. 
Instruct the witness not 
23 
MR. 
: Instruct the witness not 
24 
to answer based on the Fifth Amendment. 
24 
to answer based on the Fifth Amendment. 
25 
THE WITNESS: On the instruction of my 
25 
THE WITNESS: At the instruction of my 
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lawyer, I must invoke my Fifth Amendment right. 
2 
MR. GARCIA: I'm just asking what it is. 
3 
MR. 
Understood. 
4 
BY MR. GARCIA: 
5 
Q. Well, let me not waste any time. Do you 
6 
know what it is, es or no? 
7 
MR. 
Instruct the witness not 
8 
to answer based on the Fifth Amendment. 
9 
THE WITNESS: At the instruction of my 
10 
lawyer, I invoke my Fifth Amendment right. 
11 
BY MR. GARCIA: 
12 
Q. Has Jeffrey Epstein ever told you that he 
13 
is a government witness, otherwise known as a 
14 
snitch, or confidential informant? 
15 
MR. 
Objection to the form in 
16 
that it assumes knowledge of Mr. Epstein. 
17 
Instruct the witness not to answer. 
18 
THE WITNESS: On the instruction of my 
19 
lawyer, I invoke my Fifth Amendment right. 
20 
BY MR. GARCIA: 
21 
Q. Has he ever told you that he is involved 
22 
in a case involving, providing information 
23 
concerning mone laundering? 
24 
MR. 
• Same objection and same 
25 
instruction. 
Page 376 
1 
THE WITNESS: At the instruction of my 
2 
lawyer, I must invoke my Fifth Amendment right. 
3 
MR. GARCIA: That's all I have. Thank 
4 
you. 
5 
MR. 
: Great. Should we take a 
6 
break? I know you need to change the tape as 
7 
well. 
8 
THE VIDEOGRAPHER: Yes. We're now going 
9 
off the record. It is 5:18 p.m. 
10 
(A brief recess was held.) 
11 
• * * * • 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
IIIIII--
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