EFTA01249325

Mark Epstein 
September 21, 2009 
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M. Epstein 
elevator of 
Q. Other than at
 have you seen 
anywhere else? 
A. No. 
Q. Do you know of 
relationship 
with your brother? 
A. No. 
Q. I know I asked you about Jean Luc 
Brunel, I don't remember did I ask you whether 
you are familiar with the modeling company MC 
Squared? 
A. Yes, you did. 
MR. COHEN: You did. 
Q. Are you familiar with the modeling 
company Karin Models? 
A. No. 
Q. Have you ever attempted to ascertain 
who is staying in the various apartments that 
your brother rents at 
A. No. 
Q. Are they usually occupied? 
A. I have no idea. 
Q. What is your obligation to that 
property? What do you do? 
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Mark Epstein 
September 21, 2009 
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M. Epstein 
A. Nothing. 
Q. What does your company do for that 
property? 
A. We own most of it and manage it. 
Q. Well, in managing it, what does that 
entail? 
A. Leasing out spaces, paying the bills. 
Q. Something breaks, you fix it? 
A. Well, we have staff there that takes 
care of that, yes. 
Q. Who would the staff member be that 
would --
A. A guy named Andy is the head super. 
Q. Andy who? 
A. I don't know his last name. 
Q. This is the head supervisor for your 
company? 
A. For that building. He is the 
superintendent for that building. 
Q. Have you ever had that position of 
superintendent for that building? 
A. No. 
Q. Ever owned real estate with your 
brother? 
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Mark Epstein 
September 21, 2009 
61 
M. Epstein 
A. No. 
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Q•
Do you know of the name 
A. No. 
Q. Leslie Groff? 
A. No. 
Q. Did you talk to your brother about 
the criminal investigation when it began? 
MR. COHEN: Objection. 
Asked and answered. 
A. No. 
Q. I know you call now to check on his 
health. Did it concern you that he was being 
criminally investigated? 
MR. COHEN: Objection. 
A. Well, it concerned me, he is my 
brother. 
Q. So why is it you didn't have that 
conversation with him? 
A. If there was something he wanted to 
tell me, he would have told me. 
O. And that's not something he ever 
talked to you about? 
A. Right. 
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Mark Epstein 
September 21, 2009 
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M. Epstein 
Q. And even though the allegations --
you are familiar with the allegations; right? 
A. Some, I guess. 
Q. The allegations are that he was 
engaging in sex with under-age girls. 
That's not something that you wanted 
to take upon yourself to talk to your brother 
about? 
A. No. 
Q. It's not something that really 
bothers you? 
A. No --
MR. COHEN: Objection. 
A. -- no more than anybody else being 
accused of that. 
Q. If you found that to be true, 
hypothetically, you find that it's true that 
your brother is engaging in sex with 
under-aged girls; 13, 14, 15-year old girls, 
is that something that you would discuss with 
him? 
MR. COHEN: Objection. 
A. I'll use one of my mother's lines, 
I'll worry about that when the time comes. 
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Mark Epstein 
September 21, 2009 
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M. Epstein 
Q. You realize that he has plead guilty 
to that; right? 
A. Yes. 
Q. So hasn't the time come? 
A. No, not for me. I know it was a plea 
deal, so I don't know the details. 
Like I said, he pled guilty to some 
prostitution charge. So you are representing 
a bunch of prostitutes if I just go by what 
the law says. So, you know, I don't pay 
attention to that. 
Q. If the evidence in this case are that 
these girls are in middle school and high 
school, some of them are virgins and none of 
them have engaged in prostitution prior to 
meeting your brother, does that change? 
A. Your question started with an "if." 
I'm not going to speculate on anything. 
MR. COHEN: Mr. Edwards, can we take 
a short bathroom break? 
MR. EDWARDS: Sure. 
THE VIDEOGRAPHER: 12:33, off the 
record. 
(Discussion held off the record.) 
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Mark Epstein 
September 21, 2009 
64 
M. Epstein 
MR. COHEN: Let's go back on the 
record. Are all counsel who appeared by phone 
on the phone now? 
THE WITNESS: If anybody's not do 
speak up. Should we do another roll call? 
MR. CRITTON: This is Bob Critton. 
Let me just put on the record, I recognized 
about just before we took the break I must 
have bumped my microphone. 
So when I've been inserting 
objections, and based on what the court 
reporter indicated, she hadn't heard me for 
about 30 or 35 minutes. 
I just want to assert, any question 
that had either a leading, isn't it true, or a 
suggestion that Mr. Jeffrey Epstein had some 
sexual contact or contact with under-age 
girls, I would have objected to. 
I did object to, apparently it didn't 
come through; any leading guess, any questions 
for which there was no predicate, I have no 
objection to the actual questions with regard 
to who was on the plane, or if he saw his 
brother, what the discussions they had, but 
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Mark Epstein 
September 21, 2009 
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M. Epstein 
any other questions to suggest the answer or 
leading question, I would reserve that 
objection on form. 
MR. EDWARDS: Okay. 
MR. CRITTON: My microphone's on now. 
You'll have to hear me. 
MR. EDWARDS: That's unfortunate. 
MR. CRITTON: Thank you for your warm 
reception. 
THE VIDEOGRAPHER: It's 12:40. 
On the record. 
BY MR. EDWARDS: 
Q. When you were at your brother's house 
in Palm Beach, I know you said it was 10 years 
ago, how many computers would you estimate 
were in the house? 
A. I have no idea. 
Q. Did he ever talk to you after the 
criminal investigation about the computer 
evidence that there is in this case? 
A. No. 
Q. Did you ever go visit your brother 
when he was in jail? 
A. No. 
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Mark Epstein 
September 21, 2009 
66 
M. Epstein 
Q. Why not? 
A. I did not. 
Q. I'm sorry, I didn't hear you? 
A. I did not go. 
Q. Right. Why wouldn't you go visit 
your brother in jail? 
A. Timing, part of it. I have my own 
life up in New York. We'd speak occasionally, 
I knew he was okay. I don't see him that much 
when he was in New York, so... 
Q. Okay. What was done with the 
computers in your parents' house when your 
parents passed away? 
A. My mother had a computer. I think I 
took it for my kids. 
Q. Is that a computer that your brother 
ever worked on or used? 
A. I doubt it. 
Q. Did you ever know your brother to 
share images by way of computers of under-age 
girls or young looking girls? 
MR. CRITTON: Form. 
A. He rarely E-mailed, so I don't even 
know if he had any use for computers. 
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Mark Epstein 
September 21, 2009 
67 
M. Epstein 
Q. What was his E-mail address, or what 
is his E-mail address? 
MR. CRITTON: Form. 
A. I don't know it by heart. 
Q. Do you know who the server is, 
Hotmail, Gmail? 
A. No. 
Q. AOL? 
A. No, I don't know it by heart. 
Q. When you say he rarely E-mails --
A. Well, then. Then, I used to never 
get E-mails from him, but more recently I got 
a couple, some, but there is not a lot of 
E-mail communication back and forth. 
Q. Okay. In the last year and a half, 
how many E-mails have you received from your 
brother? 
A. I just had a spate of them, half a 
dozen or a dozen or so, because there is a 
reunion coming up for all the old Coney Island 
kids, so we've been talking about that. 
Q. Is your brother planning on 
attending? 
A. I don't think so. 
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Mark Epstein 
September 21, 2009 
68 
M. Epstein 
Q. When is it? 
A. In October. 
Q. So what has been the substance of the 
conversation if your brother's not planning on 
coming? 
A. Who is going, that kind of stuff. 
And just some funny pictures that came up on 
some of our old friends and what they look 
like today. It's kind of comical. 
Q. Do you know where your brother is 
working right now? 
A. No. 
Q. Have you heard of the Florida Science 
Foundation? 
A. Yes. 
Q. What is it? 
A. I have no idea. 
Q. How have you heard of it? 
A. That is where he was working on his 
work release. 
Q. How do you know that? 
A. He called me and I called there, and 
when they answered the phone they said Florida 
Science Foundation. 
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Mark Epstein 
September 21, 2009 
69 
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M. Epstein 
Q. Did you ever ask him what the Florida 
Science Foundation does? 
A. No. 
Q. Have you known your brother to be 
into science? 
A. Yes, very much. 
Q. Since when? 
A. His whole life. 
Q. How many times have you talked to him 
since he was arrested? 
A. When was he arrested? 
Q. Back in 2005, 2006? 
A. Altogether, a couple of dozen times. 
Q. And what is the substance of that 
conversation, other than you asking if he is 
in good health? 
A. About friends, family stuff. 
Q. When is the first time that you know 
of your brother targeting young girls --
A. I don't know that. 
Q. -- For sex? 
MR. COHEN: Objection. 
MR. CRITTON: Form, last question. 
MR. COHEN: Also asked and answered. 
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Mark Epstein 
September 21, 2009 
70 
M. Epstein 
MR. CRITTON: About three times. 
Q. Have you known of your brother ever 
hiring prostitutes? 
A. No. 
Q. Has your brother ever discussed with 
you the manner in which he lures 13 or 14 or 
15-year old kids to the house? 
MR. CRITTON: Form. 
MR. COHEN: Objection. 
A. Yes. I'm not going to answer that 
question. It's a leading question. 
Q. Well, I'm asking you an open 
question. Has he ever talked to you about the 
manner --
A. That is assuming he does it. I'm not 
assuming he does anything. We don't talk 
about girls. We don't talk about young girls. 
MR. CRITTON: Objection to the last 
question. 
Q. On several occasions during this 
deposition you've referred to these girls as 
prostitutes. 
Do you know any of them? 
A. No. 
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Mark Epstein 
September 21, 2009 
71 
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M. Epstein 
Q. Do you know their parents? 
A. No. 
Q. Do you know who they were before they 
met your brother? 
A. Not a clue. 
Q• Do you know what your brother did 
with them? 
A. No. 
Q. Do you know who they are today? 
A. No. 
Q. So why is it that you call all of 
these girls prostitutes? 
A. Well, I said some of them. I mean 
the charge he pled guilty to, from what I 
understand, is something to do with 
prostitution. 
So if these are the girls involved in 
that, that by definition makes them 
prostitutes. The way I -- that, to me, is 
English. 
Q. So the basis for you referring to 
these girls as prostitutes, is that your 
brother pled guilty to a prostitution charge? 
A. Yeah. What else do I have to go by? 
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Mark Epstein 
September 21, 2009 
72 
M. Epstein 
I mean, you usually don't get charged for 
prostitution unless there is a prostitute. 
MR. COHEN: Let him ask the question. 
Q. Okay, but these are young girls that 
you are calling prostitutes that you don't 
know their family; right? 
A. I have no idea. I've already 
answered that. 
MR. CRITTON: Form. 
You asked him to speculate and now 
you are going after him. 
I think that is inappropriate. 
Q. In the conversations that you've had 
with your brother since his arrest, has he 
ever expressed to you the least bit of remorse 
for anything that he has done? 
MR. CRITTON: Form. Predicate. 
A. We didn't talk about what he's done. 
Q. So then the answer is no then; right? 
MR. CRITTON: Form. 
MR. COHEN: Same objection. 
A. The answer to what I said is no, the 
way I put it. 
MR. EDWARDS: I don't have anything 
CO 
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Mark Epstein 
September 21, 2009 
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M. Epstein 
right now. 
Anybody else? 
MR. COHEN: Okay. It sounds like no 
one has any questions. 
MR. LANGINO: Yeah, we have 
questions. I don't know who comes next. 
MS. EZELL: Go ahead, Richard. 
MR. COHEN: Sir, can you identify 
yourself? 
MR. WILLITS: Okay. Richard Willits 
here. I'm going to ask a few questions. 
EXAMINATION BY 
MR. WILLITS: 
Q. Mr. Epstein, approximately when were 
you served with a subpoena? 
A. A couple of weeks ago. I think it 
was -- no, a few weeks ago. I don't remember. 
Q. Since you -- at the time you got 
served with a subpoena, did you have any 
discussions with your brother about your 
upcoming deposition? 
A. No, I told him I was served with a 
subpoena. 
Q. And what did he tell you? 
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Mark Epstein 
September 21, 2009 
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M. Epstein 
A. He said he is sorry that I had to get 
dragged into this. 
Q. Did you have any other discussions 
about the deposition? 
A. No. 
Q. Do you have a lawyer there 
representing you today? 
A. Yes. 
Q. Are you paying for that lawyer? 
A. Is this pertinent? 
MR. COHEN: You can answer. It's 
okay. 
THE WITNESS: What was your question? 
Q. Are you personally paying for the 
lawyer who is there representing you today? 
A. No. 
Q. Who is paying? 
A. Jeffrey. 
MR. WILLITS: I don't have any other 
questions. 
THE COURT REPORTER: Who is next? 
Identify yourself, please? 
MS. EZELL: I have just a couple of 
questions, Mr. Epstein. 
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Mark Epstein 
September 21, 
75 
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M. Epstein 
THE WITNESS: Go ahead. 
EXAMINATION BY 
MS. EZELL: 
Q. -- And in New York, and I didn't 
quite catch the address? 
A. I'm sorry, you were breaking up. 
Could you repeat the question? 
Q. I'm going to ask you about the 
apartment building in New York where you said 
your ex-wife lives. 
A. Yeah. 
Q. I didn't catch the name of the 
partnership that owns that? 
A. D-a-r-a, Dara. 
Q. And you are a partner in that? 
A. Yes. 
Q. Jeffrey Epstein? 
A. Excuse me? 
Q. Jeffrey Epstein is also a partner in 
that? 
A. No. 
Q. Do you --
MR. EDWARDS: Kathy, we can't hear 
you. 
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Mark Epstein 
September 21, 2009 
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M. Epstein 
MS. EZELL: Can you hear me now? 
MR. COHEN: You just faded back in. 
BY MS. EZELL: 
Q. Your brother has the capacity to make 
people believe that he is interested in them? 
MR. COHEN: Can we have the question 
again? 
THE WITNESS: I didn't get that. 
MR. COHEN: I'm sorry, could you 
repeat that, you were fading in and out? 
BY MS. EZELL: 
Q. Do you agree that your brother has a 
rather extraordinary capacity to make people 
believe that he is interested in them and 
their well-being? 
MR. COHEN: Objection. 
MR. CRITTON: Form. 
A. I have no idea. 
Q. You've known your brother, have 
you -- people --
MR. COHEN: I'm sorry, you faded out 
again. 
MR. EDWARDS: Kathy, we are only 
catching every second or third word. You may 
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Mark Epstein 
September 21, 2009 
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M. Epstein 
want to pick up your receiver. 
MS. EZELL: Thank you. I can do 
that. Is this better? 
MR. COHEN: Much better. 
THE WITNESS: Much better. 
BY MS. EZELL: 
Q. Okay, sorry. 
In all the years you've known your 
brother, have you known him to be a master 
manipulator? 
MR. COHEN: Objection. 
MR. CRITTON: Form. 
A. No. I mean, I don't know what you 
mean by that. 
Q. Have you known him to be very good at 
manipulating people to get them to do what he 
wants? 
A. I have no idea 
MR. COHEN: Objection. 
MR. CRITTON: Form. 
Q. You have no idea, was that your 
answer? 
A. Yes. I have no idea. I don't see 
him with many people. 
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Mark Epstein 
September 21, 2009 
78 
M. Epstein 
Q. Did he have that capacity when you 
were growing up? 
MR. COHEN: Objection. 
MR. CRITTON: Form. 
A. I don't know what -- I don't know how 
to answer that question. 
Q. When you were growing up, did you 
notice that he developed the capacity to deal 
with people in a way that made them think he 
was very interested in their welfare? 
MR. COHEN: Objection. 
MR. CRITTON: Form. 
MS. EZELL: I couldn't hear the 
answer. 
A. The answer is, I don't know what you 
are talking about. We grew up. We were kids 
growing up in Brooklyn, you know. 
Capacity? He had a good capacity for 
mathematics, I can say that. 
Q. Right. Right. So I'm asking you if 
he had a good capacity for dealing with 
people? 
MR. COHEN: Objection. 
MR. CRITTON: Form. 
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