EFTA00182418

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JANE DOE, 
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Plaintiff, 
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vs. 
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JEFFREY EPSTEIN, et al., 
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Defendants. 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-CV-80893-CIV-MARRA/JOHNSON 
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DEPOSITION OF 
Volume 1 of 1 
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Pages 1 through 138 
Videotaped 
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Monday, March 15, 2010 
10:13 a.m. - 12:42 p.m. 
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U.S. Legal Support 
515 East Las Olas Boulevard, 3rd Floor 
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Fort Lauderdale, Florida 33301 
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Stenographically Reported By: 
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Janet L. McKinney, RPR, FPR, CLR 
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Registered Professional Reporter 
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Florida Professional Reporter 
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Certified LiveNote Reporter 
0002 
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APPEARANCES: 
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ON BEHALF OF THE PLAINTIFF: 
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FARMER, JAFFE, WEISSING, EDWARDS, 
FISTOS & LEHRMAN 
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425 North Andrews Avenue 
Suite 2 
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Fort Lauderdale, Florida 33301-3268 
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BY: BRADLEY EDWARDS, ESQ. 
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ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN: 
BURMAN, CRITTON, LUTTIER & 
COLEMAN, LLP 
303 Banyan Boulevard 
Suite 400 
West Palm Beach, Florida 33401 
, ESQ. 
ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES: 
MERMELSTEIN & HOROWITZ, P.A. 
18205 Biscayne Boulevard 
Suite 2218 
Miami, Florida 33160 
EFTA00182418

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ROBBINS, TUNKEY, ROSS, AMSEL, 
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RABEN & WAXMAN, P.A. 
2250 Southwest Third Avenue 
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4th Floor 
Miami, Florida 33129 
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BY: STUART S. MERMELSTEIN, ESQ. 
ON BEHALF OF THE WITNESS: 
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BY: ALAN S. ROSS, ESQ. 
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Also Present: Sean McGuire, Videographer 
U.S. Legal Support 
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INDEX 
Page 
Direct Examination By Mr. Edwards 
7 
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Cross-Examination By Mr. Mermelstein 
111 
Redirect Examination By Mr. Edwards 
127 
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Recross-Examination By Mr. Mermelstein 
133 
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Certificate of Oath 
137 
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Certificate of Reporter 
138 
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EXHIBITS 
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PLF'S 
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No. 
Description 
Page 
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Jane Doe 102 v. Jeffrey Epstein 
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complaint 
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2A-2G Telephone messages 
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Handwritten notes 
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2H 
Telephone message 
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Gawker.com photo with story 
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WITNESS'S 
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No. 
Description 
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Target letter 
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Videotaped deposition taken before JANET L 
McKINNEY, Registered Professional Reporter, Florida 
Professional Reporter, Certified LiveNote Reporter and 
Notary Public in and for the State of Florida at Large 
in the above cause. 
(Whereupon, Witness's Exhibit 1 was marked for 
identification.) 
VIDEOGRAPHER: We are now on the video record. 
Today is Monday, the 15th day of March, 2010. The 
time is 9:13 a.m. (sic). We are here at 515 East 
Las Olas Boulevard, 3rd Floor, Fort Lauderdale, 
Florida, for the purpose of taking the videotape 
deposition of 
taken in Case Number 
08-CIV-80893, Jane Doe M. Jeffrey Epstein, et al. 
The court reporter is Janet McKinney; the 
videographer is Sean McGuire, both of U.S. Legal 
Support. 
Will counsel and all present please introduce 
yourself and the court reporter will swear the 
EFTA00182419

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witness. 
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MR. EDWARDS: Brad Edwards. I represent the 
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plaintiff, Jane Doe also "Jane Doe"; EW, "EW"; LM, 
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"LM" 
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MR. MERMELSTEIN: Stuart Mermelstein. I 
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represent Jane Doe Numbers 2 through 8. 
0005 
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MR. PIKE: Michael Pike on behalf of Jeffrey 
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Epstein. 
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MR. ROSS: And good morning, my name is Alan 
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Ross. I represent the witness, 
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THE REPORTER: Would you raise your right 
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hand, please. 
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Do you solemnly swear or affirm the testimony 
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you're about to give will be the truth, and nothing 
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but the truth, so help you God? 
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THE WITNESS: I do. 
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MR. ROSS: Before the deposition begins and in 
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an effort to streamline the process of getting 
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through this deposition on behalf of the witness we 
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have had marked as Witness Exhibit Number 1 an 
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August 31, 2007 letter from the 
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tates 
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Attorney's Office addressed to 
through 
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her then counsel, Bruce Lyons, which is called a 
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target letter identifying her as a target of a 
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federal Grand Jury investigation in the Southern 
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District of Florida and outlining a number of 
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offenses that were the subject matter of 
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investigation. 
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As a result of that, it is anticipated that 
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some of the questions that may be asked during the 
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course of this deposition she may invoke her Fifth 
0006 
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Amendment privilege against self-incrimination. 
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And in order to streamline this we've agreed prior 
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to beginning this that she will simply answer "I 
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refuse to answer." The parties will understand and 
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the record will reflect that she is invoking her 
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Fifth Amendment privilege against 
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self-incrimination. 
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If there is some other privilege, 
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attorney-client privilege or some other objection 
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that I may have to a question, I'll specifically 
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state it. But her answer "I refuse to answer" will 
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be on Fifth Amendment grounds if that's acceptable 
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to everyone. 
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MR. EDWARDS: It's acceptable. 
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MR. MERMELSTEIN: It's acceptable. 
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MR. PIKE: Acceptable. 
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MR. ROSS: Okay. Madam court reporter has 
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already marked the exhibit, and I'll leave that 
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with her. 
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MR. EDWARDS: Okay. 
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0007 
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THEREUPON: 
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having been first duly sworn or affirmed, was examined 
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and testified as follows: 
EFTA00182420

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DIRECT EXAMINATION 
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BY MR. EDWARDS: 
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Q. Can you tell us your full -- full name. 
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A. 
. 
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Q. At some point in time you were known as 
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; is that correct? 
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A. Correct. 
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Q. And when did that change? 
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A. Well, I got married and initially I stayed 
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with my name and then -- because immigration kind of 
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made a mistake of not changing my name when I first 
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came to this country. And at some point when I was 
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removing my conditional residency I made sure that this 
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mistake is corrected. I do not recall exact time when 
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that happened. 
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0008 
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A. I was invited by modeling agency on a business 
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visa. 
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Q. What modeling agency? 
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A. Elite Models. 
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Q. And who was the connection at Elite Models 
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that invited you? 
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A. Actually it was my husband. I met him in 
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Europe and at the time he -- he knew that agency and I 
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was modeling in Europe and he showed my pictures and 
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they invited me. 
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Q. How long have you been modeling? 
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A. Since about I was 16 years old. 
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Q. Since 16, so mid-90's? Late 90's? 
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A. Probably around '98, '99, I believe. 
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Q. Okay. And what agencies did you model for in 
Europe? 
A. I was with -- in Poland I was with Ricardo Guy 
that eventually change the name to J and B Models. I 
was also represented by Ricardo Guy in Milan. Then on 
my second trip to Milan an agency called Women. 
I was then represented in Japan by agency --
oh, that's -- you just mean Europe or --
Q. Well, you can continue. 
A. Yeah. I was represented in Japan by agency 
Zucca. I was in South Korea, I do not recall the name 
of the agency. I was represented in Taiwan by Fashion 
Management. 
Q. Okay. And these were all agencies that you 
worked for or worked with prior to coming to the United 
EFTA00182421

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States? 
A. Not all of them. Some of them I worked --
already been United States and traveling. 
Q. Okay. But sometime around 2002 you were 
invited by Elite Models to come to the United States to 
model? 
A. Correct. 
Q. And at the time -- well, where are you from? 
A. I'm Polish. 
Q. Okay. So at the time you were a Polish 
citizen? 
A. Yes. 
Q. So in order to come to the United States you 
needed to get a work visa? 
A. I was invited actually just to kind of get a 
feeling if I will be suitable. So I came on a business 
tourist visa which is, I believe, B1/B2. 
Q. Okay. And where did you first go when you 
came to the United States, what state? 
A. Florida. 
Q. And what city in Florida? 
A. Miami. 
Q. And what did you do for your two weeks when 
you first arrived in Miami, Florida? 
A. I do not recall. 
Q. Okay. But did you do any modeling? 
A. Well, like I would see some photographers, the 
agency would send me like on all calls to see 
photographers to kind of introduce me as a model. 
Q. And why did you make the decision to go with 
Elite Models in the United States when you already were 
modeling in --
A. Um-hum. 
Q. -- Europe? 
A. Well, you know, just to expand it was 
something that I did. And I decided to take a year off 
after I graduated from high school and -- you know, 
just to expand the modeling -- the modeling 
possibilities, opportunities. 
Q. Where did you graduate from high school? 
A. In Warsaw, Poland. 
Q. What year? 
A. 2002, I believe. 
Q. And do you have any college? Have you gone to 
college after that? 
A. I have an associate degree from Miami Dade 
College -- Miami Dade College, and I'm pursuing a 
bachelor degree right now. 
Q. When did you get your associate's degree from 
Miami Dade? 
A. 2008. Summer of 2008. 
Q. And you're pursuing a bachelor's degree right 
now? 
A. 
Q. 
A. 
Q. 
A. 
Q. 
program? 
Yes. 
From where? 
Florida International University. 
In what? 
Accounting. 
How long have you been in the accounting 
EFTA00182422

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A. Since fall 2008. 
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Q. And when do you expect to graduate? 
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A. Fall 2010. 
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Q. Are you a full-time student or part-time? 
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A. I'm a full-time student at this time. 
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Q. When you first arrived in Miami, Florida in 
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fall of 2002 did you decide during that two weeks that 
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you were going to stay permanently? 
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A. No. 
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Q. Okay. Did you go back to Poland? 
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A. Yes, I have. I have -- I went back for 
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Christmas. 
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Q. Okay. Poor question. Going back to 2002 I'm 
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trying to just understand how it was that -- you came 
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over here on a two-week business visa, but eventually 
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you ended up staying for a longer period of time, 
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correct? 
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A. Right. 
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Q. Okay. And how did that come about, just tell 
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me? 
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A. Well, I got romantically involved with my 
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current husband and so when -- you know, we just 
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started dating, we got engaged, and that's how, you 
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know, our relation evolved -- evolved, and eventually, 
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you know, I got married and -- and stayed. 
0013 
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Q. Okay. And since coming to the United States 
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have you always lived in Miami, Florida? 
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A. No. 
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Q. All right. Where else have you lived in the 
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United States? 
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A. New York. 
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Q. Where in New York? 
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A. Manhattan. 
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Q. What was the address in Manhattan where you 
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lived? 
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MR. ROSS: I'm going to advise you to invoke 
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privilege. 
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A. I refuse to answer. 
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Q. Okay. Have you -- are you familiar with an 
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address at 301 East 66th Street in New York? 
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A. I refuse to answer. 
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MR. PIKE: May we take a break for a second? 
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May I speak with you? 
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MR. ROSS: Sure. 
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VIDEOGRAPHER: Off the record, 10:22 a.m. 
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(Recess taken at 10:22 a.m.) 
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(Deposition resumed at 10:23 a.m.) 
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VIDEOGRAPHER: On the record, 10:23 a.m. 
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MR. ROSS: Brad, let me just interrupt for a 
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moment. 
0014 
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MR. EDWARDS: No problem. 
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MR. ROSS: Just to be sure, when the witness 
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answers "I refuse to answer" to be clear the full 
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statement that she's not saying for the sake of 
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saving time is that she's invoking her Fifth 
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Amendment right against self-incrimination. Just 
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to be clear. 
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MR. EDWARDS: That's what I've understood all 
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along. 
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MR. MERMELSTEIN: That's what I understood. 
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MR. ROSS: Okay, fine. Go ahead. 
EFTA00182423

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MR. EDWARDS: This is just for the sake of 
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brevity --
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MR. ROSS: Exactly. 
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MR. EDWARDS: -- and let's move it on. 
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BY MR. EDWARDS: 
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Q. All right. So I'm going to ask the question 
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again, I don't remember whether you'd responded yet, 
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but are you familiar with the address in Manhattan 
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301 East 66th Street in New York? 
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A. I refuse to answer. 
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Q. Okay. How long did you live in -- well, what 
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was the first address that you lived in in Miami? 
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0015 
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Q. South Shore. Okay. 
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A. Um-hum. 
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Q. Have you ever had your deposition taken 
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before? 
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A. No. 
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Q. Okay. You're doing very well so far. There's 
a couple rules I didn't explain but mainly because 
you're doing very well. I just have to wait for you to 
finish your answer; you have to wait for me to finish 
my question. We have one court reporter. She can only 
take down one of us. Give us an answer that we all 
understand. Nodding of the head or shaking the head 
are easy to do and I get what you're saying, but she 
doesn't. Ah-ha or un-ah are things that are commonly 
said. They look the same on paper. 
If I ask a bad question which could happen, as 
already happened and probably will again, just tell me 
"I don't understand the question," I'll ask it again --
A. Okay. 
Q. -- all right? 
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I'm sorry, I don't understand your question. 
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e , since -- since 
came 
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always stayed there whether being in Miami traveling 
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back and forth, and I live currently at this address. 
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Q. Okay. What was the first time that you moved 
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from that address to live elsewhere? 
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A. I do not recall. 
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Q. Okay. I know that you told me you lived in 
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New York City and we're not going to discuss -- I'm 
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assuming you're not going to answer a lot of questions 
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about New York City, but at what time period did you 
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move there? Was it right after you got here two weeks, 
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a year later? I'm just trying to get a year as to when 
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you moved to New York? 
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MR. ROSS: I'm going to instruct you not to 
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answer. 
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A. I refuse to answer. 
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Q. Okay. Do you know a guy by the name of Jean 
A. 
Q. 
Correct. 
How long did you live at that address? 
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Luc Brunel? 
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A. I refuse to answer. 
EFTA00182424

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Q. Where are your parents? 
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A. They're in Warsaw, Poland. 
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Q. And since you've been in the United States 
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have they come to the United States? 
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A. Yes, they have visited me. 
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Q. Have they ever met Jeffrey Epstein? 
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A. I refuse to answer. 
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Q. Have they ever met Jean Luc Brunel? 
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A. I refuse to answer. 
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Q. Where are you currently employed? 
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A. I pursue -- I go to school full-time, I do not 
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work. 
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Q. Are you also still in the modeling business 
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though? 
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A. No, I'm not. 
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Q. And when was the last time you did any 
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modeling? 
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A. It would be late spring, early summer of 2006 
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I went on a trip to Taiwan. 
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Q. And why did you stop modeling at that time? 
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A. I wanted -- I always kind of knew that it's 
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something that I'm going to be doing and I just decided 
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to go and pursue a college degree. 
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Q. Okay. Is it something that you ever plan to 
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go back to, modeling? 
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A. No. 
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Q. Are you involved at all with the modeling 
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industry? 
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A. No. 
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Q. I mean, helping to recruit models, helping 
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others to recruit models, anything like that? 
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A. No. 
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Q. Do you ever -- do you currently talk to 
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Mr. Brunel? 
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A. I refuse to answer. 
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Q. When is the last time that you talked to 
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Jeffrey Epstein? 
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A. I refuse to answer. 
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Q. Do you know a woman by the name of Ghislaine 
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Maxwell? 
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A. I refuse to answer. 
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Q. Do you know someone by the name of 
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A. I refuse to answer. 
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Q. Do you know a person named 
? 
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A. I refuse to answer. 
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Q. Did Jeffrey Epstein have anything to do with 
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you moving to New York City? 
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A. I refuse to answer. 
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Q. Did you ever live in a place in New York City 
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owned or controlled by Jeffrey Epstein? 
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A. I refuse to answer. 
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Q. Are you familiar with the modeling agency MC 
0019 
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Squared? 
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A. I refuse to answer. 
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Q. Do you know of underage females being 
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transported into this country to work for the modeling 
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agency MC Squared? 
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A. I refuse to answer. 
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Q. Do you know of those underage females being 
EFTA00182425

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given work visas and staying at the 301 East 66th 
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Street address? 
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A. I refuse to answer. 
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Q. Can you say whether you have observed 
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Mr. Brunel or Mr. Epstein engaging in sex with underage 
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females? 
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A. I refuse to answer. 
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Q. Do you know where Mr. Brunel lives? 
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A. I refuse to answer. 
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Q. Is it true that Mr. Brunel stays in the 301 
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East 66th address frequently with underage females? 
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A. I refuse to answer. 
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Q. At what point were you hired to work for 
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Mr. Epstein? 
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MR. PIKE: Form. 
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MR. EDWARDS: You can still answer the 
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question. Mr. Pike is making a legal objection. 
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A. I refuse to answer. 
0020 
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Q. And how did -- how did it come about that you 
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began working with Jeffrey Epstein? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
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Q. What did Jeffrey Epstein pay you in salary? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
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Q. What was the time period that you worked for 
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him? 
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A. I refuse to answer. 
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Q. Why did you stop working for him? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
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Q. What initially were you hired to do? 
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A. I refuse to answer. 
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MR. PIKE: Form. 
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Q. Has Jeffrey Epstein ever paid you to stay 
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quiet or keep quiet about what went on in his house? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
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Q. Have you talked to 
or 
about the things that went on in Jeffrey 
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Epstein's house? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
0021 
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Q. Did you sign a confidentiality agreement with 
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Jeffrey Epstein? 
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A. I refuse to answer. 
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MR. PIKE: Form. 
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Q. Did that confidentiality agreement outline 
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what you should say to authorities should he be caught 
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with underage females? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
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Q. Is there another book or manual or written 
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memorialization of what you, as an employee of Jeffrey 
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Epstein, should do if confronted by law enforcement? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
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Q. Are you invoking your Fifth Amendment right 
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because you believe you could be prosecuted? 
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MR. ROSS: Invoke. 
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A. I refuse to answer. 
EFTA00182426

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Q. Are you also invoking because you're scared to 
testify against Jeffrey Epstein? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. When did you first learn that Jeffrey Epstein 
had a sexual obsession for underage females? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. Isn't it true that you have seen Jeffrey 
Epstein sexually interacting with females as young as 
12 years old? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. Is it true that you have observed Jeffrey 
Epstein's sexual obsession to include the age range 12 
to 17? 
A. 
Q. 
A. 
Q. 
Epstein? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Do you know if 
Jeffrey Epstein when she was underage? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. What have you been told about Jeffrey 
Epstein's sexual obsession with underage minor 
children? 
MR. PIKE: Form. 
I refuse to answer. 
Have you ever had sex with Jeffrey Epstein? 
I refuse to answer. 
MR. PIKE: Form. 
Have you ever been paid for sex with Jeffrey 
had sex with 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Isn't it true that Jeffrey Epstein interacted 
sexually with underage minors on an everyday basis? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And most of the time Mr. Epstein would 
interact with underage minors at least two times a day; 
is that true? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Can you explain to the jury how Mr. Epstein 
would access new underage minor females for sex every 
day? 
A. 
Q. 
to bring 
A. 
Q. 
to bring 
A. 
Q• 
MR. PIKE: Form. 
I refuse to answer. 
How many assistants did Jeffrey Epstein hire 
him underage minor females for sex? 
I refuse to answer. 
MR. PIKE: Form. 
Were you one of those assistants that helped 
him underage minor females? 
MR. PIKE: Form. 
I refuse to answer. 
I know that the laws in Poland are probably 
different than they are here, but are you familiar with 
the Florida Statutes that protect children against 
sexual offenders or sexual predators? 
EFTA00182427

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MR. ROSS: Invoke. 
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A. I refuse to answer. 
6 
Q. Let me just read you the lewd or lascivious 
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molestation statute and then I'm going to ask you some 
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questions about it. 
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It says: "A person who intentionally touches 
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in a lewd or lascivious manner the breasts, genitals, 
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genital area or buttocks or the clothing covering them 
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of a person less than 16 years of age or forces or 
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entices a person under 16 years of age to so touch the 
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perpetrator, commits lewd or lascivious molestation, a 
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second degree felony." 
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After hearing that statute isn't that 
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something -- isn't that a crime that you know 
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Mr. Epstein to have committed on an everyday basis 
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while you were working for him? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
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Q. And that's a statute that he violated with 
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more than 100 underage females; is that true? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
0025 
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Q. When did you become aware that Mr. Epstein was 
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a child molester? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
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Q. Have you ever seen him with a female under the 
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age of 12? 
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MR. PIKE: Form. 
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A. I refuse to answer. 
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Q. Have you ever known Jeffrey Epstein to have 
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sex with an adult? 
11 
MR. PIKE: Form. 
12 
A. I refuse to answer. 
13 
Q. Does he -- is he sexually attracted to adults? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. When was the first time you learned of 
17 
Mr. Epstein getting a massage from an underage minor 
18 
female? 
19 
MR. PIKE: Form. 
20 
A. I refuse to answer. 
21 
Q. I realize some of these questions may sound 
22 
repetitive but during this case we've learned of key 
23 
terms that different people on Mr. Epstein's let's say 
24 
payroll or inner circle recognize or talk about. So 
25 
when I talk about "massages", do you know what that 
0026 
1 
term means? 
2 
MR. PIKE: Form. 
3 
A. I refuse to answer. 
4 
Q. Isn't "massage" the word that was told by 
5 
Jeffrey Epstein to all of his employees to refer to 
6 
whatever acts he engages in with underage females in 
7 
his bedroom? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
10 
Q. At this point -- were you -- were you ever in 
11 
the bedroom with him when he was engaging in sexual 
12 
acts with underage females and calling them "massages"? 
13 
MR. PIKE: Form. 
14 
A. I refuse to answer. 
EFTA00182428

15 
Q. Did you ever participate in any of the sexual 
16 
acts that Jeffrey Epstein was having with underage 
17 
females? 
18 
MR. PIKE: Form. 
19 
A. I refuse to answer. 
20 
Q. Now, just so that the record is clear there is 
21 
not a single piece of evidence that ever indicates that 
22 
you were involved with underage females, I'm not even 
23 
implying that and I realize that you invoking it may --
24 
may give the wrong light and that's not -- that's not 
25 
my intention, so -- but were you ever aware of 
participating in sex with underage females? 
2 
A. I refuse to answer. 
3 
Q. Have you read the police reports related to 
4 
the criminal investigation into Mr. Epstein? 
5 
A. I refuse to answer. 
6 
Q. And you're aware of this 87-page police report 
7 
that details numerous females that indicate that they 
8 
were involved sexually with Mr. Epstein when they were 
9 
minors? 
10 
A. I refuse to answer. 
11 
MR. PIKE: Form. 
12 
Q. Did anyone instruct you to use the code word 
13 
"massage"? 
14 
A. I refuse to answer. 
15 
Q. And when referring to these underage minor 
16 
females that would come over to Mr. Epstein's house did 
17 
anybody also tell you to use the term "work"? 
18 
A. I refuse to answer. 
19 
MR. PIKE: Form. 
20 
Q. Meaning when somebody would call to schedule 
21 
one of these underage females for a massage isn't it 
22 
true that they would say "It's time to come to work" 
23 
and schedule a specific appointment? 
24 
MR. PIKE: Form. 
25 
A. I refuse to answer. 
0028 
1 
Q. Is there a book or manual or is it written 
2 
anywhere that the -- that sex with underage minors is 
3 
to be referred to as a "massage"? 
4 
A. I refuse to answer. 
5 
MR. PIKE: Form. 
6 
Q. Were there ever team meetings, for lack of a 
7 
better word, where Jeffrey Epstein and possibly 
8 
Ghislaine Maxwell, 
, yourself, would talk 
9 
about this organization of obtaining underage girls for 
10 
Jeffrey Epstein for sex? 
11 
MR. PIKE: Form. 
12 
A. I refuse to answer. 
13 
Q. What methods does Jeffrey Epstein use to gain 
14 
access to underage minor females for sex? 
15 
MR. PIKE: Form. 
16 
A. I refuse to answer. 
17 
Q. What is your understanding of Jeffrey 
18 
Epstein's involvement with the modeling industry? 
19 
MR. PIKE: Form. 
20 
A. I refuse to answer. 
21 
Q. Have you ever modeled for MC Squared? 
22 
MR. PIKE: Form. 
23 
A. I refuse to answer. 
24 
Q. Has Jeffrey Epstein ever promised you anything 
25 
related to a modeling career? 
EFTA00182429

0029 
1 
MR. PIKE: Form. 
2 
A. I refuse to answer. 
3 
Q. Have you ever talked to Jean Luc Brunel about 
4 
modeling? 
5 
A. I refuse to answer. 
6 
Q. Have you ever talked to Jean Luc Brunel about 
7 
his desire to have sex with underage females? 
8 
A. I refuse to answer. 
9 
Q. Isn't it true that Jean Luc Brunel has been in 
10 
trouble for years for having sex with underage minors 
11 
in Europe? 
12 
A. I refuse to answer. 
13 
Q. Are you familiar with The McIntyre Reports? 
14 
A. I refuse to answer. 
15 
Q. Okay. Are you familiar with reports done on 
16 
modeling agencies back in the 80's and 90's related to 
17 
agency owners having sex with underage minors? 
18 
MR. ROSS: Answer the question. 
19 
A. No, I'm not. 
20 
Q. Okay. Did you ever hear of Jean Luc Brunel's 
21 
reputation for having sex with underage girls? 
22 
MR. ROSS: Invoke. 
23 
A. I refuse to answer. 
24 
Q. Do you know how Jean Luc Brunel knows Jeffrey 
25 
Epstein? 
0030 
1 
A. I refuse to answer. 
2 
MR. PIKE: Form. 
3 
Q. Isn't their connection the obsession for 
4 
underage minor females? 
5 
MR. PIKE: Form. 
6 
A. I refuse to answer. 
7 
Q. Based on your observations of Jeffrey Epstein 
8 
would you categorize his obsession for underage minor 
9 
females as an addiction? 
10 
MR. PIKE: Form. 
11 
A. I refuse to answer. 
12 
Q. Isn't it true that Ghislaine Maxwell delivers 
13 
underage minor females to Jeffrey Epstein? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. Have you ever had a sexual relationship with 
17 
Ghislaine Maxwell? 
18 
A. I refuse to answer. 
19 
Q. Do you know what Ghislaine Maxwell does in 
20 
general for Jeffrey Epstein? 
21 
MR. PIKE: Form. 
22 
A. I refuse to answer. 
23 
Q. Have you seen photographs of underage minor 
24 
females in Jeffrey Epstein's patrol -- control or 
25 
possession? 
0031 
1 
MR. PIKE: Form. 
2 
A. I refuse to answer. 
3 
Q. Were there surveillance cameras, hidden 
4 
surveillance cameras inside Jeffrey Epstein's home? 
5 
MR. PIKE: Form. 
6 
A. I refuse to answer. 
7 
Q. Did those surveillance cameras capture 
8 
underage minor females naked? 
9 
MR. PIKE: Form. 
10 
A. I refuse to answer. 
EFTA00182430

11 
Q. And didn't Jeffrey Epstein and Ghislaine 
12 
Maxwell watch those surreptitiously obtained videos of 
13 
underage minor females? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. And those videos and photographs of underage 
17 
minor females were saved on Jeffrey Epstein's computers 
18 
in his house, right? 
19 
MR. PIKE: Form. 
20 
A. I refuse to answer. 
21 
Q. Have you seen those photographs and videos on 
22 
Jeffrey Epstein's computers? 
23 
MR. PIKE: Form. 
24 
A. I refuse to answer. 
25 
Q. Who have you talked to related to the criminal 
0032 
1 
investigation into Jeffrey Epstein? 
2 
A. I refuse to answer. 
3 
MR. PIKE: Form. 
4 
MR. ROSS: In addition, attorney-client 
5 
privilege. 
6 
Q. And I certainly would -- do not want to know 
7 
anything you talked to your attorney about, I 
8 
apologize. 
9 
A. (Nods.) 
10 
Q. Why was it that you were named as a 
11 
co-conspirator of Jeffrey Epstein's in the 
12 
non-prosecution agreement? 
13 
MR. PIKE: Form. 
14 
A. I refuse to answer. 
15 
Q. Do you feel like a victim of Jeffrey 
16 
Epstein's? 
17 
MR. PIKE: Form. 
18 
A. I refuse to answer. 
19 
Q. Do you feel like Jeffrey Epstein brainwashed 
20 
you to some extent? 
21 
MR. PIKE: Form. 
22 
A. I refuse to answer. 
23 
Q. Do you feel any remorse for any role that you 
24 
may have played in having underage minor females at 
25 
Jeffrey Epstein's house for him to molest them? 
0033 
1 
MR. PIKE: Form. 
2 
A. I refuse to answer. 
3 
Q. Have you known Ghislaine Maxwell and Jeffrey 
4 
Epstein to keep sex slaves? 
5 
A. I refuse to answer. 
6 
Q. Do you know somebody named 
? 
7 
A. I refuse to answer. 
8 
Q. Have you met 
? 
9 
A. I refuse to answer. 
10 
MR. EDWARDS: All right. Let me go ahead and 
11 
mark as -- as Plaintiff's Exhibit 1 a lawsuit that 
12 
was filed by Bob Josefsberg on behalf of Jane Doe 
13 
102 v. Jeffrey Epstein just for the purposes of 
14 
asking the witness some questions. 
15 
MR. ROSS: I've seen it. 
16 
(Whereupon, Plaintiff's Exhibit 1 was marked 
17 
for identification.) 
18 
Q. Have you ever read the lawsuit Jane Doe 102 M. 
19 
Jeffrey Epstein? 
20 
A. I refuse to answer. 
21 
Q. In the lawsuit it indicates the plaintiff was 
EFTA00182431

22 
15 years old when Ghislaine Maxwell and Jeffrey Epstein 
23 
had a threesome with this underage minor female. Are 
24 
you aware of that? 
25 
MR. PIKE: Form. 
0034 
1 
A. I refuse to answer. 
2 
Q. And Jeffrey Epstein and/or Ghislaine Maxwell 
3 
obtained and purchased passports for 15-year-old Jane 
4 
Doe 102 to transport her to Palm Beach, New York City, 
5 
Santa Fe, Los Angeles, San Francisco, St. Louis, as 
6 
well as Europe, the Caribbean, and Africa; are you 
7 
aware of that? 
8 
A. I refuse to answer. 
9 
MR. PIKE: Form. 
10 
Q. It's also alleged that Jeffrey Epstein in 
11 
addition to molesting Jane Doe 102 along with Ghislaine 
12 
Maxwell forced her to have sex with other models, 
13 
actresses, and celebrities? 
14 
A. I refuse to answer. 
15 
MR. PIKE: Form. 
16 
Q. It also indicates that Jeffrey Epstein 
17 
transported other minor girls from Turkey, the Czech 
18 
Republic, Asia, and other countries. Are you aware of 
19 
that? 
20 
MR. PIKE: Form. 
21 
A. I refuse to answer. 
22 
Q. Is Jeffrey Epstein involved in the 
23 
international child sex trade? 
24 
MR. PIKE: Form. 
25 
A. I refuse to answer. 
0035 
1 
Q. Is Jean Luc Brunel his partner in that 
2 
international child sex trade? 
3 
MR. PIKE: Form. 
4 
A. I refuse to answer. 
5 
Q. Are you aware that after -- that Jeffrey 
6 
Epstein forced Jane Doe 102 to have sex with other 
7 
adult male peers including royalty, politicians, 
8 
academicians, businessmen and/or other professional and 
9 
personal acquaintances of Jeffrey Epstein's? 
10 
MR. PIKE: Form. 
11 
A. I refuse to answer. 
12 
Q. Is that something that he did with girls other 
13 
than Jane Doe 102? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. Aren't you familiar with Jeffrey Epstein's 
17 
practice of pimping out underage minor females to other 
18 
people that have the same sexual obsession with 
19 
underage minors? 
20 
MR. PIKE: Form. 
21 
A. I refuse to answer. 
22 
Q. And doesn't he benefit financially from that 
23 
sex trade? 
24 
MR. PIKE: Form. 
25 
A. I refuse to answer. 
0036 
1 
Q. Jane Doe 102 ultimately escaped from him and 
2 
left to Australia, is that your understanding? 
3 
A. I refuse to answer. 
4 
MR. PIKE: Form. 
5 
Q. Have you ever spoken with Jane Doe 102? 
6 
A. I refuse to answer. 
EFTA00182432

7 
Q. On one of Epstein's birthdays a friend of 
8 
Jeffrey Epstein sent to him 12 -- three 12-year-old 
9 
girls from France who spoke no English for Epstein to 
10 
sexually exploit and abuse and after doing so he sent 
11 
them back to France the next day. Are you familiar 
12 
with that? 
13 
MR. PIKE: Form. 
14 
A. I refuse to answer. 
15 
Q. Isn't that something that is fairly common for 
16 
Mr. Epstein? 
17 
A. I refuse to answer. 
18 
MR. PIKE: Form. 
19 
Q. Who are the friends that send to Jeffrey 
20 
Epstein underage minor females for his birthday so that 
21 
he can abuse? 
22 
A. I refuse to answer. 
23 
MR. PIKE: Form. 
24 
Q. Is one of those friends Jean Luc Brunel? 
25 
A. I refuse to answer. 
0037 
1 
Q. Have you ever met Prince Andrew? 
2 
A. I refuse to answer. 
3 
Q. Has Prince Andrew been involved with underage 
4 
minor females to your knowledge? 
5 
A. I refuse to answer. 
6 
Q. Have you ever met Alan Dershowitz? 
7 
A. I refuse to answer. 
8 
Q. When Alan Dershowitz stays at Jeffrey 
9 
Epstein's house isn't it true that he has been at the 
10 
house when underage minor females have been in the 
11 
bedroom with Jeffrey Epstein? 
12 
A. I refuse to answer. 
13 
Q. Has -- are you familiar with the media 
14 
publication or online resource RadarOnline? 
15 
A. I refuse to answer. 
16 
Q. Is that something that you assisted 
17 
Mr. Epstein with when he purchased RadarOnline? 
18 
A. I refuse to answer. 
19 
Q. And do you know his business partner in that 
20 
endeavor? 
21 
A. I refuse to answer. 
22 
Q. Isn't it also true that he used RadarOnline as 
23 
another way to gain access to underage minor females 
24 
for sex? 
25 
MR. PIKE: Form. 
0038 
1 
A. I refuse to answer. 
2 
Q. Have you been to all of Jeffrey Epstein's 
3 
properties? 
4 
MR. PIKE: Form. 
5 
A. I refuse to answer. 
6 
Q. Certainly you've been to the property at 358 
7 
El Brillo Way, correct? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
10 
Q. Have you been to his property in Manhattan? 
11 
A. I refuse to answer. 
12 
MR. PIKE: Form. 
13 
Q. And have you been to his island in -- it was 
14 
Little St. James, I believe he calls it Little 
15 
St. Jeff's now? 
16 
MR. PIKE: Form. 
17 
A. I refuse to answer. 
EFTA00182433

9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0040 
1 
2 
3 
4 
5 
6 
7 
a 
A. 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0041 
1 
2 
18 
19 
20 
21 
22 
23 
24 
25 
0039 
1 
2 
3 
4 
5 
6 
7 
Q. And have you witnessed underage child sex 
orgies on that island? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Do you know a female named Jeletzia? 
A. I refuse to answer. 
Q. Do you know where Jeletzia lives these days? 
A. I refuse to answer. 
Q. What is your understanding of 
role in Jeffrey Epstein's life? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. Isn't it true that she gets paid just to bring 
him underage minor females for sex? 
MR. PIKE: Form. 
8 
A. I refuse to answer. 
Q. And additionally, she schedules the 
appointments for underage minor females for him to 
molest? 
A. I refuse to answer. 
MR. PIKE: Form. 
You know 
I refuse to answer. 
Does she still work 
I refuse to answer. 
Was she an underage 
Epstein's? 
I refuse to answer. 
Q. 
A. 
Q. 
A. 
Q. 
Jeffrey 
A. 
Q. Through discovery we've talked to 
witnesses about, you know, Jeffrey Epstein 
that work for him. I don't know if you'll 
answer any of these questions but I'll ask 
one at a time. 
? 
for Ghislaine Maxwell? 
minor child victim of 
numerous 
and people 
be able to 
them anyway 
Is 
somebody who travels with 
Jeffrey Epstein? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And when Jeffrey Epstein is coming to town 
doesn't he call 
his number one assistant? 
MR. PIKE: Form. 
I refuse to answer. 
Q. And at some point in time, it looks like in 
early 2005 or late 2004, you were also an assistant of 
Jeffrey Epstein's, correct? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And how was it that you transitioned from 
being involved in modeling to being an employee of 
Jeffrey Epstein? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Other than arranging for underage minor 
females to come to Jeffrey Epstein's house did you do 
anything else for Jeffrey Epstein? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Did you ever fly on Jeffrey Epstein's 
airplane? 
A. I refuse to answer. 
Q. Did you witness Jeffrey Epstein abuse --
EFTA00182434

3 
sexually abusing underage minor females on his 
4 
airplane? 
5 
MR. PIKE: Form. 
6 
A. I refuse to answer. 
7 
Q. Did you know that it was illegal for Jeffrey 
8 
Epstein to interact sexually with underage minor 
9 
females? 
10 
MR. PIKE: Form. 
11 
A. I refuse to answer. 
12 
Q. Did you ever object to Jeffrey Epstein 
13 
interacting sexually with underage minor females? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. Would Jeffrey Epstein get angry at you if you 
17 
did not have an appointment set for him with an 
18 
underage minor female? 
19 
MR. PIKE: Form. 
20 
A. I refuse to answer. 
21 
Q. Has Jeffrey Epstein contacted you in the last 
22 
year? 
23 
A. I refuse to answer. 
24 
MR. PIKE: Form. 
25 
Q. Has 
contacted you within the last 
0042 
1 
year? 
2 
A. I refuse to answer. 
3 
Q. Has anybody that is associated with Jeffrey 
4 
Epstein's party contacted you in the last year? 
5 
MR. PIKE: Form. 
6 
A. I refuse to answer. 
7 
Q. By that I mean to include Ghislaine Maxwell, 
8 
, any of these people, have they contacted 
9 
you within the last year? 
10 
MR. PIKE: Form. 
11 
A. I refuse to answer. 
12 
Q. Are you familiar with the names of some of the 
13 
underage minor females? 
14 
A. I refuse to answer. 
15 
Q. Are you familiar with LM? 
16 
A. I refuse to answer. 
17 
Q. Do you remember what LM looked like? 
18 
A. I refuse to answer. 
19 
Q. Are you familiar with EW? 
20 
A. I refuse to answer. 
21 
Q. Do you remember what EW looked like? 
22 
A. I refuse to answer. 
23 
Q. Are you familiar with Jane Doe? 
24 
A. I refuse to answer. 
25 
Q. These are all females that were underage minor 
0043 
1 
females that Jeffrey Epstein interacted with sexually 
2 
during a time when you were working for him; isn't that 
3 
true? 
4 
A. I refuse to answer. 
5 
MR. PIKE: Form. 
6 
Q. And LM was somebody that went over to Jeffrey 
7 
Epstein's house and was molested at a young age by him 
8 
more than 100 times; is that true? 
9 
MR. PIKE: Form. 
10 
A. I refuse to answer. 
11 
Q. And EW was also somebody who went over to 
12 
Jeffrey Epstein's house when she was between 14 and 
13 
16 years old more than a hundred times; isn't that 
EFTA00182435

14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0044 
1 
2 
3 
4 
5 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0045 
1 
2 
3 
4 
5 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
true? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And Jane Doe was somebody that went to Jeffrey 
Epstein's house more than 15 times to be molested by 
Jeffrey Epstein when she was 14 and 15 years old; is 
that true? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Is it also true that LM brought to Jeffrey 
Epstein's house between 50 and 75 other underage minor 
females for Jeffrey Epstein to molest? 
A. I refuse to answer. 
MR. ROSS: Form. 
Q. Are you aware of Jeffrey Epstein's for lack of 
a better word "ritual" with these underage minor 
females in his bedroom? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Wouldn't it generally begin with Jeffrey 
Epstein placing a call to 
or yourself and 
telling you that he's going to be in town at the Palm 
Beach mansion? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And then isn't there a list of underage minor 
females stored in the computer system? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And that computer system is interconnected 
from his New York home, his New Mexico home, his 
island, his home in France, and West Palm Beach; is 
that correct? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And have you seen that list of underage minor 
females stored in the computer system? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And isn't it true there are over a thousand 
girls at any given time between the age range of 12 and 
17 all of which have been molested by Jeffrey Epstein? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And when Mr. Epstein would call and tell you 
the time that he was going to be in town it would then 
be your job to get an underage minor female to his 
house and set a specific appointment for that person; 
is that correct? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And he would tell you the exact time of day 
that he wanted his two or three appointments to molest 
underage minor females? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. And you would go into the computer system and 
call the person that he told you he wanted to see for 
that day; is that correct? 
MR. PIKE: Form. 
A. I refuse to answer. 
EFTA00182436

25 
Q. And that may be 
0046 
1 
or somebody local that you would call on the telephone 
2 
and tell them to come work at a specific time? 
3 
MR. PIKE: Form. 
4 
A. I refuse to answer. 
5 
Q. And didn't Mr. Epstein tell you that the way 
6 
you need to tell these girls is that they are working 
7 
so that they do not feel that they have the option to 
8 
decline? 
9 
MR. PIKE: Form. 
10 
A. I refuse to answer. 
11 
Q. I mean, the psychology of it all was explained 
12 
in detail by Jeffrey Epstein; isn't that correct? 
13 
MR. PIKE: Form. 
14 
A. I refuse to answer. 
15 
Q. And once the girls were inside the bedroom 
16 
Jeffrey Epstein said that he can take care of the rest, 
17 
correct? 
18 
MR. PIKE: Form. 
19 
A. I refuse to answer. 
20 
Q. And the underage minor female would show up at 
21 
the house and be greeted at the door by either 
22 
yourself, the house manager, or 
correct? 
23 
MR. PIKE: Form. 
24 
A. I refuse to answer. 
25 
Q. Many of these underage minor females including 
0047 
1 
my three clients, LM, EW, and Jane Doe you met 
2 
personally, right? 
3 
A. I refuse to answer. 
4 
MR. PIKE: Form. 
5 
Q. And then you would lead them upstairs to his 
6 
bedroom and leave him alone in the bedroom, leave my 
7 
client alone in the bedroom? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
10 
Q. And let's take LM, and she went there many 
11 
times between the ages of 13 and 16. If she was taken 
12 
up to his bedroom she would be left alone in the 
13 
bedroom until Jeffrey Epstein arrived, correct? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. And Jeffrey Epstein would appear usually naked 
17 
and order for her to take her clothes off? 
18 
A. I refuse to answer. 
19 
MR. PIKE: Form. 
20 
Q. And then Mr. Epstein would lay face down on 
21 
the massage table would usually be the next step, 
22 
correct? 
23 
MR. PIKE: Form. 
24 
A. I refuse to answer. 
25 
Q. And you know this ritual because at some point 
0048 
1 
in time Jeffrey Epstein showed you exactly what he does 
2 
with each of these girls in the bedroom, correct? 
3 
MR. PIKE: Form. 
4 
A. I refuse to answer. 
5 
Q. So after about -- he would order the underage 
6 
minor female to begin massaging him, correct? 
7 
MR. PIKE: Form. 
8 
A. I refuse to answer. 
9 
Q. And then he would roll over and begin to 
EFTA00182437