EFTA01246559

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-CIV-80119-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
VOLUME III OF III 
Related cases: 
08-80232, 08-08380, 08-80381, 08-80994 
08-80993, 08-80811, 08-80893, 09-80469 
09-80591, 09-80656, 09-80802, 09-81092 
VIDEOTAPED DEPOSITION OF 
Wednesday, March 24, 2010 
10:37 - 6:51 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Rachel W. Bridge, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting Services 
Job No.: 1484 
Electronically signed by Rachel Bridge 
PROSE COURT REPORTING AGENCY, INC. 
CONFIDENTIAL 
905d1499-0cd8-4599-a2a0-6d38827b68t6 
3501.125-027 
Page 1 of 21 
EFTA 00065413 
EFTA01246559

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. 502008CA028058XXXXMB AD 
• I 
Plaintiff, 
- vs-
VOLUME III OF III 
JEFFREY EPSTEIN, 
Defendant. 
VIDEOTAPED DEPOSITION OF 
Wednesday, March 24, 2010 
10:37 - 6:51 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Rachel W. Bridge, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting Services 
Job No.: 1484 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Rachel Bridge I 
CONFIDENTIAL 
905d1499-0cd8-4599-a2a0-6d38827b68t6 
3501.125-027 
Page 2 of 21 
EFTA 00065414 
EFTA01246560

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. 502008CA028051XXXXMB AB 
~•,
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
VOLUME III OF III 
VIDEOTAPED DEPOSITION OF 
Wednesday, March 24, 2010 
10:37 - 6:51 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Rachel W. Bridge, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting Services 
Job No.: 1484 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Rachel Bridge I 
CONFIDENTIAL 
905d1499-0cd8-4599•a2a8-6d38827b68c6 
3501.125-027 
Page 3 of 21 
EFTA _00065415 
EFTA01246561

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE No.502008CA037319XXXXMB AB 
Plaintiff, 
- vs-
VOLUME III OF III 
JEFFREY EPSTEIN
AND 
Defendants. 
VIDEOTAPED DEPOSITION OF 
Wednesday, March 24, 2010 
10:37 - 6:51 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Rachel W. Bridge, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting Services 
Job No.: 1484 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Rachel Bridge I 
CONFIDENTIAL 
905d1499-0cd8-0599•a2a8-6d38827b68c6 
3501.125-027 
Page 4 of 21 
EFTA 00065416 
EFTA01246562

Page 381 
Page 383 
APPEARANCES: 
1 
- - -
2
On behalf of the Plaintiff.: 
SPENCER T. KUVIN. ESQUIRE 
INDEX 
LEOPOLD KU WIN 
2 
- - - 
2925 PGA Boulevard 
suite No 
3 
WITNESS: 
DIRECT CROSS REDIRECT RECRO 
S 
Palm Beach Gardens. Florida 33410 
4 
6 
Phone: 561.515.1400 
5 
By Mr. Garcia 
383 
On behalf of the Plaintiffs. ..... 
and 
6 
By Ms. Ezell 
386 
lane Doe: 
7 
8 
9 
MATMEW WE1SSING. ESQUIRE 
8 
- - -
FARMER. JAFFE MUSSING. EDWARDS 
9 
EXHIBITS 
10 
F1STOS & LEIIRMAN. P.L 
425 North Andrews Avenue 
10 
- - -
11 
Suite 2 
11 
EXHIBIT 
PAGE 
Fort Lauderdale Florida 33301 
12 
Phone: 
12 
Exhibit 16 
389 
13 
On behalf gallant Does I through a: 
13 
14 
ADAM D. HOROWITZ. ESQUIRE 
MERMELSTEIN & HOROWITZ. P.A. 
14 
15 
18205 Biscayne Boulevard 
15 
16 
Suite 2218 
Miami. 
t 
i 
16 
Phone: 
17 
MI 
18 
On behalf ol the Plunk''
'
. 101. 102 and 103: 
 18 
19 
KATHERINE W. I,MELL. ESQUIRE 
19 
AMY JOSEFSBERG EDERI. ESQUIRE 
20 
20 
POIMURST OILSECK 
25 Wem Flatlet Sheet 
21 
21 
SWIG MO 
Miami.ii
iiii 
22 
22 
Phone: 
23 
21 
Wu telephone! 
24 
24 
25 
25 
Page 382 
Page 384 
I 
Appearances continued._ 
1 
PRODEEDINGS 
2 
On behalf of the Plaintiff. Jane Doe II: 
2 
- - - 
3 
ISIDRO MANUEL GARCIA. ESQUIRE 
GARCIA. ELKINS & BOERRINGER 
3 
THE VIDEOGRAPHER: We are now on the record 
4 
224 Daum Avenue. Suite 900 
4 
It is 5:42 .m. and I'm on media number three. 
5 
West Palm 
Fl 
Beach 
ida 33401 
Phone: 
5 
MR. 
If I could just put something 
6 
6 
quickly on the record before we start. 
7 
On behalf of the Defendant: 
7 
I know Mr. Garcia said he had a couple of 
8 
JACK ALAN GOLDBERGER. ESQUIRE 
ATTERBURY. GOLDBERGER & WEISS. P.A. 
8 
additional questions. which I have no objection to 
9 
250 Australian Avenue South 
9 
him asking. but it is 5:42 and we've been going 
Suite 1400 
lo 
West Pa 
Floridaida 33401-5012 
0 
almost seven hours with Ms. Kellen. 
Phone: 
11 
And I know Ms. Ezell has questions and she has 
11 
12 
got her one client she has to ask questions about. 
12 
13 
On behalf of t • W. • • 
13 
I understand that, but I hope we can focus on going 
1 4 
14 
forward to areas that have not already been covered 
15 
so we can actually get out of here tonight. because 
■ 
16 
17 
at some point we really do have to go. and I would 
like to get this over with today. 
17 
18 
So with that. Mr. Garcia. if you have some 
18 
19 
19 
additional questions. I have no objection to you 
20 
ALSO PRESENT: 
20 
asking that. 
21 
Jessica Cadwell. Paralegal 
21 
MR. GARCIA: Thank ou.
Burman. Critton. Lanier & Coleman. P.A.
22 
CROSS - continued 
22 
23 
Joseph Kozak. Videographer 
23 
BY MR. GARCIA: 
Prose Court Reporting Services 
24 
Q. Have you ever had a different hair color? 
24 
25 
25 
MR. 
. Asking it at any time in her 
Electronically signed by Rachel Bridge 
5 (Pages 381 to 38 4) 
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Page 385 
Page 387 
1 
life she's ever dyed her hair a different hair 
1 
Q. And you are sure that you only had it up for 
2 
color? 
2 
about ten minutes? 
3 
MR. GARCIA: Yes, or if she's dyed her hair 
3 
MR. 
Did you mean literally ten 
4 
now or if that's her natural color. Let's start 
4 
minutes or just for a brief period of time? 
5 
with that. 
5 
THE WITNESS: A very brief period of time. 
6 
BY MR. GARCIA: 
6 
MR. 
You can answer Mr. Garcia's 
7 
Q. Is that our natural color? 
7 
question. 
8 
MR. 
: Answer that. 
8 
BY MR. GARCIA: 
9 
THE WITNESS: Yes. 
9 
Q. Can you be more specific? Are we talking 
10 
BY MR. GARCIA: 
10 
about ten minutes for a day or ten minutes in a week or 
11 
Q. What is your natural color, so the transcript 
11 
a month? 
12 
will reflect it? 
12 
A. Maybe a day. Maybe two days. 
13 
MR. 
We have a video, so I think 
13 
Q. Okay. 
14 
it's 
clear. 
19 
MR. GARCIA: Oka that's all I have. Thanks. 
15 
pretty 
THE WITNESS: Brown. 
15 
. 
CROSS ( 
16 
BY MR. GARCIA: 
16 
BY MS. EZELL: 
17 
Q. Have you ever dyed your hair or colored your 
17 
Q. Ms. Kellen. my name is Katherine Ezell. I'm 
18 
hair blonde or any type of shade of light, lighter 
18 
here with Amy Josefsberg Merl. We represent Jane Doc 
19 
shade? 
19 
103. We also represent three clients who have not yet 
20 
MR. 
: You mean at any time in her 20 
filed. Some of the questions may be repetitive. but I 
21 
life has she done that? 
21 
believe we have the right to ask them with regard to our 
22 
MR. GARCIA: Yes, sir. 
22 
clients. So with that said. we'll move along as fast as 
23 
THE WITNESS: Yes. 
23 
we can. 
24 
BY MR. GARCIA: 
24 
Why did you take down your Facebook page? 
25 
Q. For what period of time? 
25 
A. I think it's a stupid site. I don't 
Page 386 
Page 388 
1 
A. I don't recall. 
1 
understand it. I don't understand the point of it. 
2 
Q. And how long have you gone back to your 
2 
Q. Do you have e-mail? 
3 
natural color brown? 
3 
A. Yes. 
4 
A. It's been a long time. I don't recall exactly 
4 
Q. And what is our e-mail address? 
5 
the dates. 
5 
MR. 
• Instruct the witness not to 
6 
Q. Do know somebody named Craig Greczyn. G-r-e-c. 
6 
answer based on Fifth Amendment privilege. 
7 
as in cat. z as in Zorro, y-n? 
7 
THE WITNESS: At the advice of counsel. I must 
a 
A. No. 
8 
invoke my Fifth Amendment right. 
9 
Q. He's a student at SUNY University, S-U-N-Y. in 
9 
BY MS. EZELL: 
10 
Courtland. 
10 
Q. Have ou. have ou done e-mail under the 
11 
A. No idea. 
11 
address
12 
Q. Do you know Kofi Sansculotte. K-o-f-i. 
12 
A. Can you repeat that? I'm sorry. 
13 
S-a-n-s-c-u-1-o-t-t-e? 
13 
. Have ou used e-mail with the address 
14 
15 
A. No. 
Q. And Michael Daley? 
14
15 
A. No. 
16 
A. No. 
16 
Q. Have ou used e-mail with the address 
17 
Q. I tried to see if I could Google your Facebook 
17 
. 
18 
it down 
18 
MR. 
• Hold on a second. I'm going tc 
page. and you thought you took 
after about ten 
19 
minutes. I did come up with three or four Sarah 
19 
instruct the witness not to answer any questions 
20 
Kellens. I'm not sure if it's the same one that you 
20 
about any e-mail addresses that she may or may not 
21 
are, but are you sure that you've taken it down? 
21 
have had in the past based on her Fifth Amendment 
22 
A. Yes. 
22 
privilege. 
23 
Q. And do you have any idea when you took it 
23 
THE WITNESS: At the advice of my counsel. I 
24 
down? 
24 
must invoke my Fifth Amendment right. 
25 
A. Maybe a year ago. 
25 
6 (Pages 385 to 388) 
Electronically signed by Rachel Bridge 
PROSE COURT REPORTING AGENCY, INC. 
CONFIDENTIAL 
905d1499-Occ18-4599-a2a0-8d38827b88c8 
3501.125-027 
Page 6 of 21 
EFTA_00065418 
EFTA01246564

Page 389 
Page 391 
1 
BY MS. F7Fit i . 
1 
THE VIDEOGRAPHER: Okay. 
2 
Q. With regard to the Facebook page again, why 
2 
MS. EZELL: This is the second page. 
3 
did you start it up if you thought it was a stupid site 
3 
THE VIDEOGRAPHER: Okay. 
4 
and didn't know how to use it? 
4 
MS. EZELL: And here's the third page. 
5 
A. I was just curious. 
5 
THE VIDEOGRAPHER: Okay. 
6 
Q. Did anyone help you do that? 
6 
MS. EZELL: And just for identification 
7 
A. No. 
7 
purposes. those are Bates stamped SAO 496 
a 
Q. Did anyone tell you to take it down? 
8 
through -- I'm sorry. 495 through 497. If you 
9 
A. No. 
9 
would pass that down, please. to the witness. 
10 
Q. You were asked about any licenses. Have you 
10 
BY MS. EZELL: 
11 
never held a real estate license? 
11 
Q. Doyou recognize this. Sorry? 
12 
A. Never. 
12 
MR. 
: Are you asking about all three 
13 
Q. Do you hold any licenses in any states other 
13 
pages simultaneously or one page at a time? 
14 
than Florida? 
14 
MS. EZELL: All three simultaneous. 
15 
MR. 
: When you say licenses, you mean 15 
MR. 
: Okay. 
16 
professional as opposed to a driver's license or 
16 
BY MS. EZELL: 
17 
some other sort of a license? 
17 
Q. This appears to be. the first page appears to 
18 
MS. EZELL: Yes. 
18 
indicate that this was obtained from the driver's 
19 
THE WITNESS: I don't have a license anywhere 
19 
license authority in 
20 
for anything. 
20 
MR. 
: The first page we have looks 
21 
BY MS. EZELL: 
21 
like it's a printed page. 
22 
Q. Do you have a driver's license? 
22 
MS. EZELL: Ri ht. 
23 
A. Yes. 
23 
MR. 
: From -- oh, I see. Okay. never 
24 
Q. And in what state? 
24 
mind. 
25 
MR. 
: I instruct her not to answer 
25 
Page 390 
Page 392 
1 
based on her Fifth Amendment privilege. 
1 
BY MS. EZELL: 
2 
THE WITNESS: At the advice of counsel. I must 
2 
Q. It's from the supervisor driver license clerk 
3 
invoke m Fifth Amendment privilege. 
3 
in the city and county of
Do you see that? 
4 
MR. 
You can roll your eyes all you 
4 
A. Yes.
5 
want. Mr. Horowitz. It's my client's right. 
5 
Q. Do you recognize that application. pages two 
6 
She'll invoke it if she needs to. 
6 
and three? 
7 
MR. HOROWITZ: I was shaking my head, not 
7 
MR. 
: Page two is a printout of what 
8 
rolling my eyes. The Fifth Amendment assertion as 
8 
appears to be a driver's license. Page three 
9 
to whether a person has a driver's license is 
9 
appears to be a fingerprint. 
10 
ridiculous. It is ridiculous. 
10 
Is that what you are asking her, if she 
11 
MR. 
You can have that opinion. am 11 
recognizes this? 
12 
if you want to bring that up to the judge, I'll be 
12 
MS. EZELL: Yes, uh huh. 
13 
happy to explain to the judge why it's a valid 
13 
MR. 
: I instruct her not to answer 
14 
invocation. I disagree with you. 
14 
those questions. 
15 
MS. EZELL: It is certainly a record that the 
15 
THE WITNESS: At the instruction of my lawyer, 
16 
government has and can be accessed. 
16 
I must invoke my Fifth Amendment right. 
17 
MR. 
That's true. 
17 
BY MS. EZELL: 
18 
(The document was marked Exhibit 16 for 
18 
Q. Even thou h this is a public record? 
19 
identification.) 
19 
MR. 
: Well, if it's a public record 
20 
BY MS. EZELL: 
20 
or not, she doesn't have to admit or authenticate 
21 
Q. I'm going to show you in a moment what I have 
21 
it for you. You can prove it some other way. She 
22 
premarked as Exhibit 16. 
22 
has a Constitutional right not to admit or 
23 
MS. EZELL: Actually, it's Composite 16. It's 
23 
authenticate the document for you. and that's what 
24 
three pages. I'll show it before I give it to the 
24 
she is invoking. 
25 
witness. 
25 
Electronically signed by Rachel Bridge 
7 (Pages 389 to 392) 
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EFTA01246565

Page 393 
Page 395 
1 
BY MS. F7Ft i • 
1 
BY MS. EZELL: 
2 
Q. Didyou ever hold a 
driver's license? 
2 
Q. Did you at one time hold 
3 
MR. 
Same instruction. It's been 
3 
in -- I won't pronounce it right, but 
? 
4 
asked and answered. 
4 
THE REPORTER: Could ou spell --
5 
THE WITNESS: At the instruction of my lawyer, 
5 
MS. EZELL: It's 
I believe. 
6 
I must invoke my Fifth Amendment right. 
6 
MR. 
: I instruct the witness not to 
7
BY MS. F7Ft t • 
7 
answer based on her Fifth Amendment privilege. 
8 
Q. Do you currently hold a 
driver's 
8 
THE WITNESS: At the instruction of my lawyer, 
9 
license? 
9 
I must invoke my Fifth Amendment right. 
10 
MR. 
It's been asked and answered. 
10 
BY MS. EZELL: 
11 
same instruction. 
11 
Q. Were ou born on 
? 
12 
THE WITNESS: At the instruction of my lawyer, 12 
MR. 
: Same instruction. 
13 
I must invoke my Fifth Amendment right. 
13 
THE WITNESS: At the instruction of my lawyer, 
14 
BY MS. EZELL: 
14 
I must invoke my Fifth Amendment right. 
15 
Q. Is that not your picture on the second page of 
15 
BY MS. EZELL: 
16 
that exhibit? 
16 
Q. Doyou see a sr nature there for 
17 
MR. 
Same instruction. 
17 
MR. 
: Just asking if she sees a 
18 
THE WITNESS: At the instruction of my lawyer, 18 
signature on the paper --
19 
I must invoke my Fifth Amendment right. 
19 
MS. EZELL: That says 
20 
BY MS. EZELL: 
20 
THE WITNESS: I see it. 
21 
Q. Do ou see the ran 
21 
BY MS. EZELL:
22 
MR. 
She's just asking if you see 
22 
Q. Is that our si attue?
23 
that on the document. 
23 
MR. 
: Instruct the witness not to 
24 
THE WITNESS: Yes. 
24 
answer based on her Fifth Amendment privilege. 
25 
25 
THE WITNESS: At the instruction of my lawyer, 
Page 394 
Page 396 
1 
BY MS. F7Ft i • 
1 
I must invoke my Fifth Amendment right. 
2 
Q. And haven't you testified today that that is 
2 
BY MS. EZELL: 
3 
your name? 
3 
Q. Do you drive an automobile in Palm Beach 
4 
MR. 
The testimony will speak for 
4 
County? 
5 
itself. Next question. 
5 
MR. 
Let me understand the question. 
6 
BY MS. EZELL: 
6 
Are you asking if she ever drives a vehicle in the 
7 
Q. You ma answer. 
7 
county or if she drives a vehicle registered in the 
a 
MR. 
Next question. 
8 
county? 
9 
MS. EZELL You are instructing her not to 
9 
MS. EZELL: If she drives a vehicle in Palm 
10 
answer that uestion? 
10 
Beach Count . 
11 
MR. 
I am. 
11 
MR. 
You can answer that. In other 
12 
BY MS. EZELL: 
12 
words, did you drive a car here today? 
13 
Q. What was your address at the time that that. 
13 
THE WITNESS: Yes. 
14 
that you a lied for a license then? 
14 
BY MS. EZELL: 
15 
MR. 
Object to the form, assumes 
15 
Q. You were asked earlier if you have ever been 
16 
facts that she has not acknowledged. that she ever 
16 
to Palm Beach as opposed to West Palm Beach where we ar 
17 
applied for this license, and I'll instruct her not 
17 
today. and I believe you answered yes. 
18 
to answer. 
18 
A. Uh huh. 
19 
BY MS. EZELL: 
19 
Q. Where have you been in Palm Beach? 
20 
Q. Is thepost office box -- 
20 
MR. 
I instruct her not to answer 
21 
MR. 
Hold on. let her answer or not 
21 
based on her Fifth Amendment privilege. 
22 
answer. 
22 
THE WITNESS: At the instruction of my lawyer. 
23 
THE WITNESS: At the instruction of my lawyer. 23 
I must invoke my Fifth Amendment right. 
24 
I must invoke my Fifth Amendment right. 
24 
BY MS. F7In T - 
25 
25 
Q. When was the last time you were on Palm Beach 
Electronically signed by Rachel Bridge 
8 (Pages 393 to 3 9 6) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 397 
Page 399 
1 
island, if it's an island? 
1 
BY MS. F7F1 I • 
2 
MR. 
Objection, it's been asked 
2 
Q. Do ou know Glenn Dubin? 
3 
before, and I'll instruct her nor to answer for the 
3 
MR. 
: It's also asked and answered, 
4 
same reason. 
4 
but Inlet her answer it again. 
5 
THE WITNESS: At the instruction of my lawyer. 
5 
THE WITNESS: At the instruction of my lawyer, 
6 
I must invoke my Fifth Amendment right. 
6 
I must invoke my Fifth Amendment right. 
7 
BY MS. EZELL: 
7 
BY MS. F7FI 1 • 
8 
Q. Haveyou ever heard of Jeffrey Epstein? 
8 
Q. 
9 
MR. 
Objection, instruct the witness 
9 
MR. 
Same instruction, objection to 
10 
not to answer based on her Fifth Amendment 
10 
the form, assumes facts that she has not 
11 
privilege. 
11 
acknowledged. so there is no foundation for the 
12 
THE WITNESS: At the instruction of my lawyer, 12 
question. 
13 
I must invoke m Fifth Amendment right. 
13 
THE WITNESS: At the instruction of my lawyer. 
14 
MR. 
It's also been asked and 
14 
I must invoke my Fifth Amendment right.
15 
answered. 
15 
BY MS. F7Ft I • 
16 
BY MS. EZELL: 
16 
Q. 
17 
Q. Do you read the newspapers? 
18 
A. Na really. 
18 
MR. 
19 
Q. Have you read any newspapers in the last four 
19 
MS. EZELL: 
20 
years in Palm Beach County? 
20 
MR. 
Objection to form. Once again, 
21 
A. I'm sure I have. 
21 
assumes facts that she has not acknowledged. that 
22 
Q. Have you read the Palm Beach Post? 
22 
there is no foundation. Instruct her not to answer 
23 
A. No, I don't. 
23 
the question. 
24 
Q. What newspapers do you read? 
24 
THE WITNESS: At the instruction of my lawyer. 
25 
A. New York Times. New York Post. That's about 
25 
I must invoke my Fifth Amendment right. 
Page 398 
Page 400 
1 
it., on occasion. 
1 
BY MS. EZELL: 
2 
Q. And have you ever — do you watch the news on 
2 
Are
Q. 
 you an onl child? 
3 
TV. local news? 
MR. 
It's been asked and answered o 
4 
A. No. 
4 
responded to, and I'll instruct her once again to 
5 
Q. When you did your Facebook page. whose 
5 
respond. 
6 
computer did you use? 
6 
THE WITNESS: At the instruction of my lawyer. 
7 
A. My own. 
7 
I must invoke my Fifth Amendment right. 
8 
Q. What kind of computer do you own? 
8 
BY MS. EZELL: 
9 
A. An Apple computer. 
9 
Q. I believe you stated that you had changed your 
10 
Q. Is it a laptop? 
10 
hair color at some point in your life. 
11 
A. Yes. 
11 
Have you changed it in the last five years? 
12 
Q. How long have you had that computer? 
12 
A. I don't recall exact years and dates. 
13 
A. I don't recall. 
13 
Q. I'm sorry? 
14 
Q. Doyou know Eva Andersson? 
14 
A. I don't recall exact years and dates that I 
15 
MR. 
Objection, it's been asked and 
15 
have. 
16 
answered. 
16 
Q. Have you been a blonde at some point in the 
17 
MS. EZELL: I think it was asked whether or 
17 
last, in the last eight years? 
18 
not she had been on a plane with her. 
18 
A. Most likely. 
19 
MR. 
I believe she was asked if she 
19 
Q. At more than one time? In other words, have 
20 
knew who Eva Andersson was, but she can go ahead 
20 
you gone back and forth between being a brunette and a 
21 
and respond to the question. I instruct her not to 
21 
blonde or were you a blonde for a certain period of 
22 
answer. 
22 
time? 
23 
THE WITNESS: At the instruction of my lawyer. 23 
A. I think I went back and forth at one point. 
24 
I must invoke my Fifth Amendment right. 
24 
Q. Have you ever either had an office or worked 
25 
25 
at an office in thi. building. which is One Clearlake 
Electronically signed by Rachel Bridge 
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Centre? 
1 
BY MS. EZELL: 
2 
MR. 
Instruct the witness not to 
2 
Q. Do you consider yourself a citizen of the 
3 
answer based on her Fifth Amendment privilege. 
3 
United States? 
4 
THE WITNESS: At the advice of counsel. I must 
4 
MR. 
: You can answer that. 
5 
invoke my Fifth Amendment right. 
5 
THE WITNESS: Yes. 
6 
BY MS. EZELL: 
6 
BY MS. EZELL: 
7 
Q. Have you ever gone to that office on a daily 
7 
Q. And of what state do you consider yourself to 
8 
basis with Jeffrey E rein? 
8 
be a citizen? 
9 
MR. 
Objection to form. There is no 
9 
MR. 
That was just asked and 
10 
foundation, because she hasn't acknowledged going 
10 
answered. 
11 
to an office in this building. 
11 
MS. EZELL: I asked about residency. 
12 
Also objection as to the implied knowledge of 
12 
MR. 
: I apologize. 
13 
Mr. Epstein. Instruct her not to answer. 
13 
THE WITNESS: What's the difference? 
14 
THE WITNESS: At the instruction of my lawyer. 14 
MR. 
: Instruct the witness not to 
15 
I must invoke my Fifth Amendment right. 
15 
answer the question based on Fifth Amendment. 
16 
BY MS. EZELL: 
16 
THE WITNESS: At the instruction of my lawyer, 
17 
Q. Have you ever had anything to do with a 
17 
I must invoke my Fifth Amendment right. 
18 
company called the Florida Science Foundation? 
18 
BY MS. EZELL: 
19 
MR. 
Instruct the witness not to 
19 
Q. Have you changed your residency in the last 
20 
answer based on Fifth Amendment. 
20 
three years? 
21 
THE WITNESS: At the instruction of my lawyer, 21 
MR. 
Residency for which? I just 
22 
I must invoke my Fifth Amendment right. 
22 
want to be clear. Ms. Ezell. You mean legal 
23 
BY MS. EZELL: 
23 
residency or where she actually lives residency? 
24 
Q. Your middle name is 
:. is that correct? 
24 
MS. EZELL: Well, let's do both. 
25 
A. Correct. 
25 
Page 402 
Page 404 
1 
Q. 
1 
BY MS. EZELL: 
2 
MR. 
It's been asked and answered 
2 
Q. Have you changed your legal residency in the 
3 
twice. You can answer it a ain. 
3 
last five years?
4 
THE WITNESS: 
4 
A. I don't think so. 
5 
BY MS. F7Ft I • 
5 
Q. Have you changed the place you live in the 
6 
Q. Thank you. 
6 
last five years? 
7 
Where do you. of what state are you a 
7 
MR. 
Instruct her not to answer that 
8 
resident? 
8 
question based on Fifth Amendment. 
9 
MR. 
Instruct the witness not to 
9 
THE WITNESS: At the advice of counsel, I must 
10 
answer based on Fifth Amendment. 
10 
invoke my Fifth Amendment right. 
11 
THE WITNESS: At the instruction of my lawyer, 11 
BY MS. EZELL: 
12 
I must invoke my Fifth Amendment right. 
12 
Q. Have you changed your citizenship. your state 
13 
BY MS. EZELL: 
13 
citizenship in the last five years? 
14 
15 
Where 
vote? 
Q. 
 
do ou 
MR. 
Same instruction. 
14 
15 
MR. 
: Again, for purposes of voting 
and other things or just -- 
16 
THE WITNESS: At the instruction of my lawyer, 16 
MS. EZELL: Yes, whatever things citizenship 
17 
I must invoke my Fifth Amendment right. 
17 
entitles one to do. 
18 
BY MS. EZELL: 
18 
MR. 
If you understand the question 
19 
Q. Are ou registered to vote? 
19 
you can answer it.
20 
MR. 
It's been asked and answered. 
20 
THE WITNESS: I don't recall really ever 
21 
I'll instruct her not to answer again, or to answer 
21 
changing -- I didn't know that you could change 
22 
it, to respond to it. I should say. 
22 
your citizenship of a state. 
23 
THE WITNESS: At the instruction of my lawyer. 23 
BY MS. EZELL: 
24 
I must invoke my Fifth Amendment right. 
24 
Q. Well, if you move from one state to another. 
25 
25 
you might change your voter's registration. time you 
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done that? 
1 
THE WITNESS: At the advice of my lawyer, I 
2 
MR. 
You can answer. 
2 
must invoke my Fifth Amendment right. 
3 
THE WITNESS: No. 
3 
BY MS. EZELL: 
4 
BY MS. EZELL: 
4 
Q. 
5 
Q. Are you a resident of or citizen of the US 
6 
Virgin Islands currentl ? 
7 
MR. 
Do you understand? You can 
a 
answer it. 
8 
Q. Have you ever been involved in modeling for M 
9 
THE WITNESS: No. 
9 
Squared? 
10 
BY MS. EZELL: 
10 
MR. 
• Instruct the witness --
11 
Q. Do ou 
taxes in any state? 
11 
objection to the form, assumes knowledge of an
12 
MR. 
Answer that yes or no. 
12 
entity by the name of MC Squared which the witness 
13 
THE WITNESS: Yes. 
13 
has not acknowledged or have any knowledge of. so 
14 
BY MS. F7Ft I • 
19 
there is no foundation for the question. 
15 
Q. In what states do you pay taxes? 
15 
Ed instruct her not to answer based on her 
16 
MR. 
Instruct her not to answer that 
16 
Fifth Amendment privilege. 
17 
question based on Fifth Amendment. 
17 
THE WITNESS: At the instruction of my lawyer, 
18 
THE WITNESS: At the instruction of my lawyer, 18 
I must invoke my Fifth Amendment right. 
19 
I must invoke my Fifth Amendment right. 
19 
BY MS. EZELL: 
20 
BY MS. EZELL: 
20 
21 
Q. Doyou ownproperty in any state? 
22 
MR. 
It's a yes or no question. You 
23 
can answer that. 
24 
THE WITNESS: No. 
25 
Page 406 
Page 408 
1 
BY MS. EZELL: 
I 
2 
Q. Is that a no? 
3 
A. No. 
I 
4 
Q. Have you owned property in any state in the 
4 
BY MS. EZELL: 
5 
last five years? 
5 
Q. And what happened to those, where are those 
6 
A. No. 
6 
pictures? 
7 
Q. Are you taking any prescribed medication at 
7 
A. I have them. 
8 
this time? 
8 
Q. And who is your boyfriend? 
9 
MR. 
You can answer the question. 
9 
MR. 
: Hold on a second. 
10 
THE WITNESS: 
10 
Instruct the witness not to answer based on 
11 
BY MS. EZELL: 
11 
her Fifth Amendment privilege. 
12 
Q. I'm so 
12 
BY MS. EZELL: 
13 
A. 
13 
Q. Is that your current boyfriend who took the 
14 
Q. Anything else? 
14 
pictures? 
15 
A. No. 
15 
MR. 
• You can answer that. 
16 
Q. You didn't take anything before this 
16 
THE WITNESS: No. 
17 
deposition today? 
17 
BY MS. EZELL: 
18 
A. No. 
18 
Q-
19 
•. 
20 
MR. 
• At this point this is getting 
21 
into her privacy rights beyond the scope of 
22 
Q. And for what company or organization did you 
22 
anything I think that's relevant to this case. I'm 
23 
model at 18? 
23 
going to ask you to move on. 
MR. 
Instruct her not to answer the 
24 
MS. EZELL: Are you instructing her not to 
question based on her Fifth Amendment privilege. 
25 
answer? 
Electronically signed by Rachel Bridge 
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Page 409 
MR. 
I am. I am. 
BY MS. EZELL: 
Q. Do you have all copies of those pictures or 
have they been distributed? 
A. I hope I have all copies. 
Q. Would you please -- I have a little difficulty 
hearing you. 
A. So 
24 
Q. Who introduced you to Jeffrey Epstein? 
25 
MR. 
Instruct the witness not to 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 411 
THE WITNESS: I don't — I don't get it. It's 
vague. I don't understand the question. 
BY MS. EZELL: 
Q. Are you not aware of an organization that 
limits its membership to billionaires? 
A. No. I'm not. 
MR. 
: Instruct the witness not to 
answer based on her Fifth Amendment privilege, and 
that's also been asked and answered several times. 
THE WITNESS: At the instruction of my lawyer, 
I must invoke my Fifth Amendment right. 
BY MS. EZELL: 
Q. By whom are ou currently employed? 
MR. 
: Objection. also been asked ant 
answered several times. Instruct her not to 
answer. 
THE WITNESS: At the instruction of my lawyer, 
I must invoke my Fifth Amendment right. 
BY MS. EZELL: 
Q. Are you employed by an individual or by a 
corporation? 
MR. 
: Same instruction. 
THE WITNESS: At the instruction of my lawyer, 
Page 410 
1 
answer based on her Fifth Amendment privilege. 
2 
THE WITNESS: At the instruction of my lawyer. 
3 
I must invoke my Fifth Amendment right. 
4 
BY MS. EZELL: 
5 
Q. Have you ever been to a social event in New 
6 
York that is restricted to billionaires? 
7 
A. Sorry. can you repeat that? 
8 
Q. Yes. Have you ever been to a social event 
9 
that's held annually in New York restricted to 
10 
billionaires? 
11 
A. I've never heard of such an event, no. 
12 
Q. Have you ever been to such an organization in 
13 
California? 
14 
A. No. I, I have never heard of such an event 
15 
like that, so I don't know. 
16 
Q. Have you never seen your picture taken and 
17 
displayed in rint media at such an event? 
18 
MR. 
Objection to the form. It's 
19 
not established she has any idea what event or what 
20 
kind of event this would be. 
21 
BY MS. EZELL: 
22 
Q. An annual event involving millionaires 
23 
billionaires, excuse me. 
24 
MR. 
Objection to the form. There 
25 
is a lack of foundation for the question. 
Page 412 
1 
I must invoke my Fifth Amendment right. 
2 
BY MS. EZELL: 
3 
Q. Do ou receive a W2? 
4 
MR. 
: Same instruction. 
5 
THE WITNESS: At the instruction of my lawyer, 
6 
I must invoke my Fifth Amendment right. 
7 
BY MS. EZELL: 
8 
Q. Do ou receive a 1099? 
9 
MR. 
: Same instruction. 
10 
THE WITNESS: At the instruction of my lawyer, 
11 
I must invoke my Fifth Amendment right. 
12 
BY MS. EZELL: 
13 
Q. Does anyone claim you as a dependent on their 
14 
tax returns? 
15 
MR. 
Anyone other than herself? 
16 
MS. EZELL: Yes. 
17 
THE WITNESS: No. 
18 
BY MS. EZELL: 
19 
Q. Have you ever signed a confidentiality 
20 
agreement? 
21 
MR. 
: With anyone? 
22 
MS. EZELL: Yes. 
23 
MR. HOROWITZ: Instruct the witness not to 
24 
answer based on her Fifth Amendment privilege. 
25 
TI IL WITNESS: At the instruction of my lawyer, 
Electronically signed by Rachel Bridge 
12 
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409 to 
4 12) 
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1 
I must invoke my Fifth Amendment right. 
1 
implicitly. Instruct the witness not to answer. 
2 
BY MS. EZELL: 
2 
THE WITNESS: At the instruction of my lawyer, 
3 
3 
I must invoke my Fifth Amendment right. 
I 
4 
BY MS. EZELL: 
A. Have I what? I'm so 
5 
Q. Do you know Juan Alessi? 
6 
6 
THE WITNESS: At the instruction of my lawyer, 
7 
I must invoke my Fifth Amendment right. 
8 
A. I don't recall ever saying those words. 
8 
BY MS. EZELL: 
9 
Q. Is it true that you will do anything Jeffrey 
9 
Q. Doyou know Alfredo Rodriguez? 
10 
Epstein asks? 
10 
MR. 
: It's been asked and answered. 
11 
MR. 
: Objection to the form. compounc 11 
Go ahead and answer it again. 
12 
question. Assumes knowledge of Jeffrey Epstein. so 
12 
THE WITNESS: At the instruction of my lawyer, 
13 
I instruct the witness not to answer. 
13 
I must invoke my Fifth Amendment right. 
14 
THE WITNESS: At the instruction of my lawyer. 
14 
BY MS. EZELL: 
15 
I must invoke my Fifth Amendment privilege. 
15 
Q. I think you also might have been asked if you 
16 
BY MS. EZELL: 
16 
know Januscz Banasiak. 
17 
Q. In 2005 and '6. did you have a designated 
17 
THE WITNESS: At the instruction of my lawyer, 
18 
computer in Mr. E rein's home on El Brillo Way? 
18 
I must invoke my Fifth Amendment right. 
19 
MR. 
: Objection to form. it's 
19 
BY MS. EZELL: 
20 
compound and assumes knowledge of Mr. Epstein and 
20 
Q. Are ou a hoto rapher?
21 
of a location on El Brillo Way. so I instruct the 
21 
MR. 
: Objection to the form, its 
22 
witness not to answer. 
22 
ambiguous. Amateur photographer? Professional 
23 
THE WITNESS: At the instruction of my lawyer. 
23 
photographer? Can you clarify? 
24 
I must invoke my Fifth Amendment right. 
24 
BY MS. EZELL: 
25 
25 
Q. Do you enjoy photography? 
Page 414 
Page 416 
1 
BY MS. EZELL: 
1 
A. Yes. 
2 
Q. Did you have on a computer at El Brillo Way a 
2 
Q. What kind of camera do you have? 
3 
list of contact information and pictures of numerous 
3 
MR. 
Instruct the witness not to 
4 
women? 
4 
answer the question. 
5 
MR. 
Objection to the form, it's 
5 
THE WITNESS: At the instruction of my lawyer. 
6 
compound and it is lack of foundation based on the 
6 
I must invoke my Fifth Amendment right. 
7 
prior question and answer. 
7 
BY MS. EZELL: 
8 
Instruct the witness not to answer. 
8 
Q. Do you know Maria Akssi? 
9 
THE WITNESS: At the instruction of my lawyer, 
9 
THE WITNESS: At the instruction of my lawyer. 
10 
I must invoke my Fifth Amendment right. 
10 
I must invoke my Fifth Amendment right. 
11 
BY MS. EZELL: 
11 
BY MS. F7PT 1 - 
12 
13 
Q. Did you and Ghislaine Maxwell share that 
information on both of our computers? 
12 
13 
Q. Have you ever known Jeffrey Epstein to give 
caniems to young women who come to his home to give hin 
14 
MR. 
Objection to form, assumes 
14 
massages? 
15 
knowledge of a person by the name of Ghislaine; 
15 
MR. 
Objection to the form. standing 
16 
Maxwell. 
16 
objection. lack of foundation as to Mr. Epstein and 
17 
Also lack of foundation based on the prior two 
17 
to his home. Instruct the witness not to answer. 
18 
answers. Instruct the witness not to answer. 
18 
THE WITNESS: At the instruction of my lawyer. 
19 
THE WITNESS: At the instruction of my lawyer, 19 
I must invoke my Fifth Amendment right. 
20 
I must invoke my Fifth Amendment privilege. 
20 
BY MS. F7Pr T - 
21 
BY MS. EZELL: 
21 
Q. Have you been encouraged in your pursuit of 
22 
22 
photograph • b Mr. E tein?
■ 
23 
MR. 
: Same objection previously 
24 
MR. 
Objection to form, lack of 
24 
stated. 
25 
foundation, assumes knowledge of Sir. Epstein 
25 
THE WITNESS: At the in‘truction of my lawyer. 
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1 
I must invoke my Fifth Amendment right. 
1 
THE WITNESS: At the instruction of my lawyer. 
2 
BY MS. EZELL: 
2 
I must invoke my Fifth Amendment right. 
3 
Q. Have you ever taken pictures of any of the 
3 
BY MS. EZELL: 
4 
young women who have visited the Epstein mansion to 
4 
Q. Have you. have you ever photographed any of 
5 
provide massa es? 
5 
the young women who visited or visit the Epstein home tc 
6 
MR. 
Objection to form, compound. 
6 
provide massy es to Mr. Epstein?
7 
lack of foundation. Instruct the witness not to 
7 
MR. 
Objection to form. its been 
8 
answer. 
8 
asked and answered. 
9 
THE WITNESS: At the instruction of my lawyer, 
9 
Also lack of foundation and standing 
10 
I must invoke my Fifth Amendment right. 
10 
objection. Same instruction. 
11 
BY MS. EZELL: 
11 
THE WITNESS: At the instruction of my lawyer. 
12 
Q. Are you aware of any hidden cameras on the 
12 
I must invoke my Fifth Amendment right. 
13 
premises? 
13 
BY MS. EZELL: 
14 
MR. 
Which premises? 
14 
Q. Have you ever photographed any minor girls who 
15 
MS. EZELL At the El Brillo Way address of 
15 
are either 
nude or nude? 
16 
Mr. Epstein. 
16 
partial) 
MR. 
That's also been asked and 
17 
MR. 
Objection to form, lack of 
17 
answered. I instruct her once again not to answer 
18 
foundation, compound. Instruct the witness not to 
18 
the question. 
19 
answer. 
19 
THE WITNESS: At the instruction of my lawyer. 
20 
THE WITNESS: At the instruction of my lawyer, 20 
I must invoke my Fifth Amendment right. 
21 
I must invoke my Fifth Amendment right. 
21 
BY MS. EZELL: 
22 
BY MS. EZELL: 
22 
Q. Have you ever been aware of something called 
23 
Q. Did you ever meet a young woman named M.? 
23 
the Edge Grou ? 
24 
A. At the instruction of my lawyer, I must invoke 
24 
MR. 
Consult. 
25 
my Fifth Amendment right. 
25 
THE WITNESS: At the advice of my lawyer, I 
Page 418 
Page 420 
1 
Q. Were you sometimes designated or requested by 
1 
must invoke the Fifth Amendment right. 
2 
Mr. Epstein to buy gifts for the young women who would 
2 
BY MS. EZELL: 
3 
come to the home to 
iv: 
him massages? 
3 
Q. Is that the name of a group that's, whose 
4 
MR. 
Objection to form, lack of 
4
e 
membershi is made u of billionaires? 
5 
foundation. Instruct the witness not no answer. 
5 
MR. 
: Objection to form. lack of 
6 
THE WITNESS: At the instruction of my lawyer. 
6 
foundation. Instruct the witness not to answer. 
7 
I must invoke my Fifth Amendment right. 
7 
THE WITNESS: At the instruction of my lawyer, 
8 
BY MS. F7Ft I • 
8 
I must invoke my Fifth Amendment right. 
9 
Q. Were you aware that Mr. Epstein gave .. 
a 
9 
BY MS. EZELL: 
10 
digital camera and encouraged her in her pursuit of 
10 
Q. Did you attend a function of the Edge Group in 
11 
photograph ? 
11 
February of 1902 -- I'm sorry. 2002? 
12 
MR. 
: Same objection stated to the 
12 
MR. 
: Object to form, there is a lack 
13 
previous question and same instruction. 
13 
of foundation. Instruct the witness not to answer. 
14 
THE WITNESS: At the instruction of my lawyer. 
14 
THE WITNESS: At the instruction of my lawyer, 
15 
I must invoke my Fifth Amendment right. 
15 
I must invoke my Fifth Amendment right. 
16 
BY MS. F7F1 f • 
16 
BY MS. EZELL: 
17 
Q. Have you ever met a young woman named 
? 17 
Q. Have you attended several functions since 2002 
18 
A. At the instruction of my lawyer. I must invoke 
18 
of the Edge Grou • ? 
19 
my Fifth Amendment right. 
19 
MR. 
: Objection to the form, because 
20 
Q. Were you ever aware that Mr. Epstein gave 
20 
there is no foundation for her having any knowledge 
21 
a regular camera and encouraged her in her pursuit of 
21 
of an entity called the Edge Group. so I'll 
22 
photograph ? 
22 
instruct her not to answer. 
23 
MR. 
: Objection to form, assumes 
23 
THE WITNESS: At the instruction of my lawyer, 
24 
certain facts, lack of foundation, compound. 
24 
I must invoke my Fifth Amendment right. 
25 
Instruct the witness not to answer. 
25 
Electronically signed by Rachel Bridge 
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1 
BY MS. F7IFI I • 
1 
is a lack of foundation of her having any 
2 
Q. Are you a member of the Edge Group or do you 
2 
interaction with anyone at any home owned by 
3 
go as the guest of Mr. E stein? 
3 
Mr. Epstein, whoever he may be. Instruct her not 
4 
MR. 
Again, there is no foundation 
4 
to answer. 
5 
for the question because there is no. there is no 
5 
THE WITNESS: At the instruction of my lawyer, 
6 
connection of her to this organization, and I'd 
6 
I must invoke my Fifth Amendment right. 
7 
instruct her not to answer. Form objection. 
7 
BY MS. EZELL: 
8 
THE WITNESS: At the instruction of my lawyer, 
8 
Q. Were you the one who routinely would get out 
9 
I must invoke my Fifth Amendment right. 
9 
the lotion, towels, and massage equipment once you 
10 
BY MS. F7IFI I • 
10 
arrived at the massy e room with the girl?
11 
Q. Do you know Ghislaine Maxwell's e-mail 
11 
MR. 
Same objection to the form. 
12 
address? 
12 
same objection stated to the previous question. 
13 
MR. 
Instruct the witness not to 
13 
It's been asked and answered as well. 
14 
answer, objection to form, lack of foundation as to 
14 
THE WITNESS: At the instruction of my lawyer, 
15 
her knowledge of anyone named Ghislaine Maxwell. 15 
I must invoke my Fifth Amendment right. 
16 
THE WITNESS: At the instruction of my lawyer. 16 
BY MS. EZELL: 
17 
I must invoke my Fifth Amendment right. 
17 
Q. Does Mr. Epstein particularly like any 
18 
19 
20
BY MS. F7IFI I • 
18 
19 
20 
particular massy e oils? 
MR. 
• Objection to the form. standar 
objection. no foundation as to her knowledge of 
? 
or 
a•Do 
you know a=I 
21 
A. At the instruction of my lawyer, I must invoke 
21 
anything relating to Jeffrey Epstein. Instruct her 
22 
my Fifth Amendment right. 
22 
not to answer. 
23 
Q. Did you participate in a sort of routine 
23 
THE WITNESS: At the instruction of my lawyer. 
24 
involving young women who would come to the house. 
24 
I must invoke my Fifth Amendment right. 
25 
Mr. Epstein's house on El Brillo Way to provide 
25 
Page 422 
Page 424 
1 
massages? 
1 
BY MS. EZELL: 
2 
MR. 
That's been asked and answered 
2 
Q. Was it your general practice to leave the girl 
3 
several times. object to the form, lack of 
3 
alone either just before or when Mr. Epstein would com 
4 
foundation as to any knowledge relating to Epstein 
4 
into the room? 
s 
or El Brillo Way. Instruct her not to answer. 
5 
MR. 
: Objection to the form, again 
6 
THE WITNESS: At the instruction of my lawyer. 
6 
assuming multiple facts and the same question. none 
7 
I must invoke my Fifth Amendment right. 
7 
of which have any foundation. Instruct her not to 
a 
BY MS. EZELL: 
8 
answer. 
9 
Q. Was it routine practice for you to come and 
9 
THE WITNESS: At the instruction of my lawyer 
10 
meet the girl after she arrived at El Brillo Way to 
10 
I must invoke my Fifth Amendment right. 
11 
provide a massage for the sexual gratification of 
11 
BY MS. EZELL: 
12 
Mr. Epstein? 
12 
Q. Who paid the girls who came to El Brillo Way 
13 
MR. 
: Objection to form, it's 
13 
to provide massages and other sexual favors for 
14 
compound. There is a lack of foundation. Instruct 
14 
Mr. Epstein? 
15 
the witness not to answer. It's been asked and 
15 
MR. 
: Same objection as to form as 
16 
answered several times. 
16 
previously stated to the last three or four 
17 
THE WITNESS: At the instruction of my lawyer. 
17 
questions. Same instruction to the witness. 
18 
I must invoke my Fifth Amendment right. 
18 
THE WITNESS: At the instruction of my lawyer 
19 
BY MS. EZELL: 
19 
I must invoke my Fifth Amendment right. 
20 
Q. Was it your practice to then lead the young 
20 
BY MS. EZELL: 
21 
woman who had come to give Mr. Epstein a massage up a 21 
Q. Who was responsible for keeping the supply of 
22 
stairway that is behind a door in the kitchen of the 
22 
cash in the house from which the girls were paid? 
23 
home on El Brillo Wa ? 
23 
MR. 
: Same objection as to form and 
24 
MR. 
: Objection to the form, it's 
24 
lack of foundation. Instruct the witness not to 
25 
compound. assuming many facts. It's not, and there 
25 
answer. 
Electronically signed by Rachel Bridge 
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1 
THE WITNESS: At the instruction of my lawyer 
1 
MR. 
Objection to the form, lack of 
2 
I must invoke my Fifth Amendment right. 
2 
foundation. Instruct the witness not to answer. 
3 
BY MS. EZELL: 
3 
THE WITNESS: At the instruction of my lawyer, 
4 
Q. Was it your practice or habit to get the 
4 
I must invoke my Fifth Amendment right. 
5 
telephone numbers and contact information of each girl 
5 
BY MS. EZELL: 
6 
before she left El Brillo Way? 
6 
Q. Did you ever text with Jane No. 103 about her 
7 
MR. 
Same objection as to form as 
7 
coming to Mr. E rein's house? 
8 
stated to the last series of questions. Same 
8 
MR. 
: Same instruction. same 
9 
instruction. 
9 
objection. 
10 
THE WITNESS: At the instruction of my lawyer 
10 
THE WITNESS: At the instruction of my lawyer, 
11 
I must invoke my Fifth Amendment right. 
11 
I must invoke my Fifth Amendment right. 
12 
BY MS. EZELL: 
12 
BY MS. EZELL: 
13 
Q. Going back to that stairway that led from the 
13 
Q. Were you aware that Jeffrey Epstein was 
14 
kitchen up to the massage room, was there a time when 
14 
helping Jane No. 103 with her college application? 
15 
there were photos of nude girls all the way up that 
15 
MR. 
: Objection to the form, lack of 
16 
stairway? 
16 
foundation as to any knowledge as to Jeffrey 
17 
MR. 
Same objection as to form an 
17 
Epstein. so therefore it's compound and ambiguous. 
18 
lack of foundation as to any basis to question this 
18 
Instruct you not to answer. 
19 
witness on anything having to do with a home own 
19 
THE WITNESS: At the instruction of my lawyer, 
20 
by Mr. Epstein or any staircase or any pictures on 
20 
I must invoke my Fifth Amendment right. 
21 
a staircase. So instruct her not to answer. 
21 
BY MS. EZELL: 
22 
THE WITNESS: At the instruction of my lawyer 
22 
Q. Did you ever hear Mr. Epstein tell Jane No. 
23 
I must invoke my Fifth Amendment right. 
23 
103 that he would help her even with the financing of 
24 
BY MS. F7Ft i • 
24 
her college, of her education? 
25 
Q. Do you recall a time when all those 
25 
MR. 
Same objection stated to the 
Page 426 
Page 428 
1 
photographs were removed? 
1 
previous question. Objection to form and lack of 
2 
MR. 
: Objection to the form. lack of 
2 
foundation. Instruct the witness not to answer. 
3 
foundation. same objection as the previous series 
3 
THE WITNESS: At the instruction of my lawyer, 
4 
of questions. Same instruction. 
4 
I must invoke my Fifth Amendment right. 
5 
THE WITNESS: At the instruction of my lawyer. 
5 
BY MS. EZELL: 
6 
I must invoke my Fifth Amendment right. 
6 
Q. Do you recall -- and I believe it's in 
7 
BY MS. FM I - 
7 
Exhibit 4, if we could pull Exhibit 4, please. If I 
a 
Q. Did you ever text girls about coming to 
8 
could just look at it for a moment, please. 
9 
provide massy es for Jeffrey Epstein? 
9 
MR. 
: Certainly. 
10 
MR. 
: Objection as to form, lack of 
10 
MS. EZELL: Thanks. Oh. good, it's on the 
11 
foundation as to any knowledge of Jeffrey Epstein. 
11 
front. 
12 
Instruct her not to answer. 
12 
BY MS. EZELL: 
13 
THE WITNESS: At the instruction of my lawyer. 
13 
Q. The first page of Exhibit 4, I'd ask you to 
14 
I must invoke my Fifth Amendment right. 
14 
look at that. Doyou recognize that handwriting? 
15 
BY MS. EZELL: 
15 
MR. 
: That was asked and answered 
16 
Q. Do you know how to text? 
16 
about six hours ago. She said no. 
17 
A. Yes. 
17 
You can answer it again. 
18 
Q. And how long have you been texting? 
18 
THE WITNESS: No. 
19 
A. Twelve years. 
19 
BY MS. EZELL: 
20 
Q. Twelve years? That's great. You are way 
20 
Q. Were you aware that Mr. Epstein ordered roses 
21 
ahead of me. I still don't know how. 
21 
to be delivered to Jane No. 103 at the stage of her high 
22 
Do you know a young woman named Jane No. 103? 
22 
school after a la ? 
23 
A. At the advice of my counsel. I must invoke my 
23 
MR. 
: Objection to the form, lack of 
24 
Fifth Amendment right. 
24 
foundation, standing objection. 
25 
Q. Did you ever drive Jane No. 103 anywhere? 
25 
TIM WITNESS: At the instruction of my lawyer, 
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I must exercise my Fifth Amendment right. 
1 
MR. 
: Same instruction. same 
2 
BY MS. EZELL: 
2 
objection. 
3 
Q. Do you recall telling — no, sorry. 
3 
THE WITNESS: At the instruction of my lawyer, 
4 
Did you and Jane No. 103 become friendly? 
4 
I must invoke my Fifth Amendment right. 
5 
MR. 
Object to the form, lack of 
5 
BY MS. EZELL: 
6 
foundation as to any relationship with Jane No. 103 
6 
Q. Did, did you give yourself Jane No 103 any 
7 
or knowledge of a person named Jane No. 103. 
7 
gifts? 
a 
Instruct the witness not to answer. 
8 
MR. 
: I'm sorry. can you rephrase? 
9 
THE WITNESS: At the instruction of my lawyer, 
9 
BY MS. EZELL: 
10 
I must invoke my Fifth Amendment right. 
10 
Q. Didyou ourself give Jane No 103 any gifts? 
11 
BY MS. F7Fil I • 
11 
MR. 
: Objection to the form. 
12 
Q. Do you remember that Jane No. 103 came to 
12 
Instruct the witness not to answer the question. 
13 
Mr. Epstein's home on or about July 23rd. 2004? 
13 
THE WITNESS: At the instruction of my lawyer, 
14 
MR. 
Object to the form, leading. as 
14 
I must invoke my Fifth Amendment right. 
15 
well as previously stated objection to the last 
15 
BY MS. EZELL: 
16 
question. 
16 
Q. Did you ever buy gifts for Jeffrey Epstein to 
17 
BY MS. EZELL: 
17 
give to Jane No 103? 
18 
re 
Q. And do ou member -- 
18 
MR. 
: Objection to form. 
19 
MR. 
Hold on. 
19 
THE WITNESS: At the instruction of my lawyer, 
20 
MS. EZELL Sorry. 
20 
I must invoke my Fifth Amendment right. 
21 
THE WITNESS: At the instruction of my lawyer. 21 
BY MS. EZELL: 
22 
I wish to invoke my Fifth Amendment right. 
22 
Q. Did you ever receive massages at the El Brillo 
23 
BY MS. F7Ft I • 
23 
Way house? 
24 
Q. Do you remember that Jane No. 103 continued tc 24 
MR. 
: Objection to form, lack of 
25 
come to Mr. Epstein's house and indeed came over 100 
25 
foundation. Same instruction. 
Page 430 
Page 432 
1 
times over about a •ear and a half? 
1 
THE WITNESS: At the instruction of my lawyer, 
2 
MR. 
: Object to the form for reasons 
2 
I must invoke my Fifth Amendment right. 
3 
previously stated in the last several questions. 
3 
BY MS. EZELL: 
4 
Instruct her not to answer. 
4 
Q. Did you receive massages given by 
5 
THE WITNESS: At the instruction of my lawyer, 
5 
? 
6 
I must invoke my Fifth Amendment right. 
6 
MR. 
Objection to the form. lack of 
7 
BY MS. F7FI I • 
7 
foundation as to any knowledge of a person named 
8 
Q. Do you remember calling to tell Jane No. 103 
8 
Lack of knowkdge as to any. lack 
9 
that Mr. Epstein would be coming in town and would like 
9 
of foundation as to any connection to EA Brillo 
10 
to see her? 
10 
Way. Instruct the witness not to answer. 
11 
MR. 
• Objection to form, instruct the 
11 
THE WITNESS: At the instruction of my lawyer. 
12 
witness not to answer. 
12 
I must invoke my Fifth Amendment right. 
13 
THE WITNESS: At the instruction of my lawyer. 
13 
BY MS. EZELL: 
14 
I must invoke my Fifth Amendment right. 
14 
Q. 
15 
BY MS. F7FII 1 : 
16 
Q. Did you overhear Mr. Epstein himself call Jane 
16 
MR. 
It's been asked and answered. 
17 
No. 103 at her home? 
17 
objection to form. 
18 
MR. 
: Objection to the form, lack of 
18 
MS. P7PI T • No. I didn't ask about Monterey. 
19 
foundation as to any knowledge of Jeffrey Epstein. 
19 
California 
20 
Instruct her not to answer. 
20 
MR. 
You asked about any Edge Group 
21 
THE WITNESS: At the instruction of my lawyer, 
21 
meetings in California. and she said she has no 
22 
I must invoke my Fifth Amendment right. 
22 
idea what the Edge Group is. 
23 
BY MS. F7Ft 1 • 
23 
MR. GARCIA: I thought she took the Fifth on 
24 
Q. Did you and Jane No. 103 ever go shopping 
24 
that. 
25 
together? 
25 
MR. 
I thought she said she didn't 
Electronically signed by Rachel Bridge 
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know what the Edge Group was, but whatever. you car 
1 
BY MS. F7FI I • 
2 
answer the question. 
2 
Q. Do you want to respond? I didn't give you 
3 
THE WITNESS: At the instruction of my lawyer. 
3 
time. 
4 
I must choose to invoke my Fifth Amendment right. 
4 
MR. 
: I've instructed her not to 
5 
BY MS. EZELL: 
5 
answer the question. Let's move on. 
6 
Q. Do ou know Max Brockman? 
6 
BY MS. EZELL: 
7 
MR. 
: I'm sorry. can you repeat? 
7 
Q. Do you recall a dinner at El Brillo Way 
8 
BY MS. EZELL: 
8 
attended by David Copperfield where Jane No. 103 was a 
9 
Q. Do ou know a Max Brockman? 
9 
guest? 
10 
MR. 
: I believe that was asked and 
10 
MR. 
: Objection to the form, lack of 
11 
answered already. but -- 
11 
foundation, and a standing objection as to her 
12 
THE WITNESS: At the instruction of my lawyer. 
12 
knowledge of anything involving El Brillo Way or 
13 
I must invoke my Fifth Amendment right. 
13 
Jeffrey Epstein. Instruct her not to answer. 
14 
BY MS. EZELL: 
14 
THE WITNESS: At the instruction of my lawyer. 
15 
Q. Have you ever been photographed with Max 
15 
I must invoke my Fifth Amendment right. 
16 
Brockman at an Edge Science dinner? 
16 
BY MS. F7FI I • 
17 
A. At the instruction of my lawyer. I must invoke 
17 
Q. What is the relationship between Jeffrey 
18 
my Fifth Amendment ri ht. 
18 
Epstein and David Co 
rfield? 
19 
MR. 
: You should let me -- I need to 
19 
MR. 
: Objection to form, lack of 
20 
object to the form of the question first, but go 
20 
foundation as to her knowledge of either one of 
21 
ahead. I know we all want to get out of here. Go 
21 
those people. Instruct her not to answer. 
22 
ahead. 
22 
THE WITNESS: At the instruction of my lawyer. 
23 
THE WITNESS: Say it again. 
23 
I must invoke my Fifth Amendment right. 
24 
MR. 
: No. you are okay. Go ahead, 
24 
BY MS. F7FI I • 
25 
Ms. Ezell. Thank you. 
25 
Q. To your knowledge, do they recruit girls for 
Page 434 
Page 436 
1 
BY MS. EZELL: 
1 
one another? 
2 
Q. Do you know whether Jeffrey Epstein attended 
2 
MR. 
: Object to the form. compound 
3 
the Edge Science dinner in Monterey, California? 
3 
and again, lack of foundation. Instruct her not to 
4 
MR. 
Objection to the form, lack of 
4 
answer. 
5 
foundation. Instruct the witness not to answer. 
5 
THE WITNESS: At the instruction of my lawyer, 
6 
THE WITNESS: At the instruction of my lawyer, 
6 
I must invoke my Fifth Amendment right. 
7 
I must invoke my Fifth Amendment right. 
7 
BY MS. EZELL: 
8 
BY MS. F7Ft I • 
8 
Q. To your knowledge. are they involved in any 
9 
0 
9 
sexual traffickin of oung women? 
10 
MR. 
: Object to the form for the 
11 
reasons previously stated. Also calls for a legal 
12 
conclusion as to what sexual trafficking is. 
13 
At what a e were those photographs taken? 
13 
Instruct her not to answer. 
14 
MR. 
I'm going to instruct her not 
14 
THE WITNESS: At the instruction of my lawyer, 
15 
to answer that. It has nothing to do with 
15 
I must invoke my Fifth Amendment right. 
16 
anything. It's not reasonably calculated to lead 
16 
BY MS. EZELL: 
17 
to discoverable evidence. We can move on. 
17 
Q. I believe you asked about Allen Dershowitz 
18 
BY MS. EZELL: 
18 
earlier. 
19 
Q. Were you in any way damaged by that 
19 
MR. 
: Twice. 
20 
experience? 
20 
BY MS. EZELL: 
21 
MR. 
Same instruction. Let's move 
21 
Q. And were instructed not to answer. 
22 
on. 
22 
MR. 
: Twice. 
23 
BY MS. EZELL: 
23 
BY MS. EZELL: 
24 
Q. Do ou have an regrets? 
24 
Q. All right. I'm going to ask again on behalf 
25 
MR. 
. Same instruction. Move on. 
25 
of my client. Are you aware or the friendship betw cell 
Electronically signed by Rachel Bridge 
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1 
Allen Dershowitz and Jeffrey Epstein? 
1 
BY MS. EZELL: 
2 
MR. 
: And for the third time. I'll 
2 
Q. Do you know that when David Coppetheld is in 
3 
object to the form and instruct her not to answer 
3 
town. he gives Jeffrey Epstein tickets and Jeffrey gives 
4 
the question. 
4 
some to your women to attend those shows? 
5
THE WITNESS: For the third time. I take the 
5 
MR. 
Object to the form, multiple. 
6 
advice of my lawyer and invoke my Fifth Amendment 
6 
compound question. and a complete lack of 
7 
right. 
7 
foundation. Instruct the witness not to answer. 
8 
BY MS. EZELL: 
8 
THE WITNESS: At the instruction of my lawyer. 
9 
Q. When Allen Dershowitz comes to Palm Beach. he 
9 
I must invoke my Fifth Amendment right. 
10 
stays at the El Brillo mansion, doesn't he? 
10 
BY MS. EZELL: 
11 
MR. 
: Objection to the form. There 
11 
Q. And do you know that those girls are invited 
12 
is no foundation for her having any knowledge of 
12 
back stage after the show? 
13 
anything having to do with a person by the name of 
13 
MR. 
. Same objection. complete lack 
14 
Allen Dershowitz. I instruct her not to answer. 
14 
of foundation, and standing objection previously 
15 
THE WITNESS: At the instruction of my lawyer. 
15 
stated. 
16 
I must invoke my Fifth Amendment right. 
16 
THE WITNESS: At the instruction of my lawyer. 
17 
BY MS. EZELL: 
17 
I must invoke my Fifth Amendment right. 
18 
Q. When Allen Dershowitz. or has Allen Dershowitz 
18 
BY MS. EZELL: 
19 
ever been there when oung ladies came to give massages' 
19 
Q. Do you remember on or about, in or about March 
20 
MR. 
: Same objection stated to the 
20 
of 2005 having conversations with one of the young women 
21 
previous question. Same instruction. 
21 
who came to the house to give massages about her 
22 
THE WITNESS: At the instruction of my lawyer. 
22 
conversations with Jane No. 103? 
23 
I must invoke my Fifth Amendment right. 
23 
MR. 
Objection to the form, standing 
24 
BY MS. F7F/ i - 
24 
objection. lack of foundation. Instruct the 
25 
Q. Has Allen Dershowitz ever been the beneficiary 
25 
witness not to answer, because the question implies 
Page 438 
Page 440 
1 
of those masse es? 
1 
that she has any knowledge at all of El Brillo Way. 
2 
MR. 
Same objection and same 
2 
BY MS. EZELL: 
3 
instruction. 
3 
Q. Same question -- sorry. 
4 
THE WITNESS: At the instruction of my lawyer, 
4 
A. At the instruction of my lawyer. I must choose 
5 
I must invoke my Fifth Amendment right. 
5 
to invoke my Fifth Amendment privilege. 
6 
BY MS. EZELL: 
6 
Q. Same • uestion as to March of 2006. 
7 
Q. Do you know John Casablanca? 
7 
MR. 
Same objection and same 
8 
A. Never heard that name before. 
8 
instruction. 
9 
Q. Have you ever heard of a world-famous 
9 
THE WITNESS: At the instruction of my lawyer, 
10 
illusionist whose stage name is David Copperfield? 
10 
I must choose to invoke my Fifth Amendment 
11 
MR. 
That's also been asked at least 
11 
privilege. 
12 
three times. I'll instruct her again not to answer 
12 
BY MS. EZELL: 
13 
the question. 
13 
Q. Do you have an
 of a conversation 
14 
THE WITNESS: At the instruction of my lawyer, 19 
in which one of the = 
women told Jane No. 103 that 
15 
I must invoke my Fifth Amendment right. 
15 
those girls who, those girls who would help Jeffrey in 
16 
BY MS. EZELL: 
16 
regard to the investigation would be compensated and 
17 
Q. Have you ever gone to one of David 
17 
those who would not or who would hurt him in the 
18 
Copperfield's shows? 
18 
investigation would be dealt with? 
19 
MR. 
Objection to form, lack of 
19 
MR. 
: Objection to the form, lack of 
20 
foundation as to knowledge of any person by the 
20 
foundation, compound question. Instruct the 
21 
name of David Copperfield. Instruct her not to 
21 
witness not to answer, because the question implies 
22 
answer. 
22 
some knowledge of anything relating to a person by 
23 
THE WITNESS: At the instruction of my lawyer. 23 
the name of Jeffrey Epstein. 
24 
I must invoke my Fifth Amendment right. 
24 
THE WITNESS: At the instruction of my lawyer, 
25 
25 
I must invoke my Fifth Amendment right. 
Electronically signed by Rachel Bridge 
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1 
By MS. F7Fil I: 
1 
BY MS. EZELL: 
2 
Q. Do you know John Brockman? 
2 
Q. Did you escort those underage girls to the 
3 
A. At the instruction of my lawyer. I must invoke 
3 
massage room where the defendant would enter and urg 
4 
my Fifth Amendment right. 
4 
the girls to remove their clothes? 
5 
Q. Do you know of someone named Brockman being 
5 
MR. 
: Objection to the form, asks a 
6 
the editor and publisher of a publication of the Edge 
6 
compound question. several questions within one. 
7 
Foundation? 
7 
Also assumes knowledge of a person by the name 
8 
MR. 
: Object to the form. There is 
8 
of Jeffrey Epstein and a massage room, so there is 
9 
no foundation that she has any knowledge of any 
9 
no foundation. Instruct the witness not to answer. 
10 
entity by the name of the Edge Foundation, and I 
10 
THE WITNESS: At the instruction of my lawyer, 
11 
would instruct her not to answer the question based 
11 
I must invoke my Fifth Amendment right. 
12 
on her Fifth Amendment privilege. 
12 
BY MS. EZELL: 
13 
THE WITNESS: At the instruction of my lawyer. 13 
Q. Did you ever tell the girls to remove their 
14 
I must invoke my Fifth Amendment right. 
14 
clothes? 
15 
BY MS. F7F11 • 
15 
MR. 
: Same objection and the same 
16 
Q. Did you participate in a scheme by Jeffrey 
16 
instruction. 
17 
Epstein to recruit underage girls to come to his 
17 
THE WITNESS: At the instruction of my lawyer, 
18 
residence to .rovide massages? 
18 
I must invoke my Fifth Amendment right. 
19 
MR. 
: Objection to the form, calls 
19 
BY MS. EZELL: 
20 
for a legal conclusion. Also has no foundation as 
20 
Q. And did you sometimes deliver cash from the 
21 
to any knowledge of a person by the name of Jeffrey 
21 
defendant to the underage girls after they performed the 
22 
Epstein. and because it calls for a legal 
22 
massage? 
23 
conclusion. I'll simply instruct her not to answer 
23 
MR. 
: That's been asked at least 
24 
the question at all. Move on. 
24 
three or four other times. 
25 
25 
MS. EZELL: I'm asking on behalf of my client. 
Page 442 
Page 444 
1 
BY MS. F7Ft I • 
1 
MR. 
I understand, but we've been 
2 
Q. Did you assist, support. and facilitate 
2 
here for over an hour. and we can't just keep going 
3 
Jeffrey Epstein's child exploitation enterprise? 
3 
over. If they have been asked in the deposition. 
4 
MR. 
Once again, objection the 
4 
your clients can have the benefit of the answer, 
5 
question. calls for a legal conclusion as to what 
5 
but we've been here now for almost eight hours and 
6 
is an enterprise, which is a term of art in the 
6 
you still --
7 
criminal law about which this witness has no 
7 
THE WITNESS: At the instruction of my lawyer, 
8 
knowledge. and it's a legal conclusion not likely 
8 
I must invoke my Fifth Amendment right. 
9 
to lead to discoverable evidence. So I would 
9 
BY MS. EZELL: 
10 
instruct her not to answer the question at all. 
10 
Q. Did you ever take pan in delivering cash from 
11 
BY MS. EZELL: 
11 
the defendant to the procurers of the underage girls who 
12 
Q. Did 
arrange times for underage 
to 
12 
came for the massy e a 
intments? 
13 
14 
you 
girls 
come to Jerrie 
tein's residence? 
MR. 
Objection to form, standing 
13 
14 
MR. 
: Objection to the form. The 
term procure is a legal term of art, and I'll 
15 
objection previously stated. 
15 
instruct the witness not to respond to the question 
16 
THE WITNESS: At the instruction of my lawyer, 16 
at all. 
17 
I must invoke my Fifth Amendment privilege. 
17 
BY MS. EZELL: 
18 
BY MS. EZELL: 
18 
Q. Did you. did you by using the telephone assist 
19 
Q. Did you arrange. transport, or yourself 
19 
Jeffrey Epstein in enabling himself to commit sexual 
20 
transport underage girls to or from Jeffrey Epstein's 
20 
on, and acts of lewdness in the presence of 
21 
residence? 
21 a 
women? 
22 
MR. 
Same objection. same 
22 
MR. 
: Same as the previous 
23 
instruction as the last question. 
23 
instruction. Instruct the witness not to answer 
24 
THE WITNESS: At the instruction of my lawyer. 24 
the question at all, because it results in a legal 
25 
I must invoke my Fifth Amendment privilege. 
25 
question. not a factual question. so it's not 
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