EFTA00188608

Case 9:O8-cv-8O736-L 
A rthrlimpnt 7411-21 Pntprrari nn 
nnrkPt 0112112(115 PagP A of 7
1 
2 
3 
4 
5 
6 
7 
6 
Amendment privileges. If it is okay with 
all counsel, in shorten things, I'll simply 
have the witness say lift; if that 
satisfies everyone's interest. 
MR. EDWARDS: That is line with me. 
MR. GOLDBERGER: Okay, with that Cathy? 
MS. EZELL: Yes. 
1 
2 
3 
4 
5 
6 
7 
0 
A The Fifth. 
Q Do you know a lady by the name of 
Maritsa Vazques? 
A The Fifth. 
Q Is this somebody who helped to falsify a 
visa for you? 
MR. YAREMA: Object to the form. 
MR. HOROWITZ: Yes. 
8 
A The Fifth. 
9 
Q 
reask the question, what's your 
9 
Q Do you know Evelyn Velasaques? 
10 
current address? 
0 
A The Fifth. 
11 
A Fifth. 
11 
Q Were you ever a working model In the 
12 
Q Are you currently living at 358 El 
12 
United States? 
13 
Brill° Way with a man named Jeffrey Epstein? 
13 
A The Fifth. 
14 
A The Fifth. 
14 
Q Can you tell us yout: parents' names? 
15 
Q Arc you also familiar with all address In 
5 
A The Fifth. 
16 
New York,301 East 66th Street? 
6 
Q How Is It that you have supported 
17 
A The Fifth. 
7 
yourself financially, since you have been in this 
18 
Q When Mr. Epstein was Incarcerated in 
8 
country? 
19 
jail, you went to visit him on numerous 
9 
MR. YAREMA: Object to the form. 
20 
occasions; is that correct? 
0 
A The Fifth. 
21 
MR. YAREMA: Objection. 
1 
Q Have you supported yourself financially? 
22 
A The Fifth. 
2 
A The Fifth. 
23 
Q When you went to visit him you indicated 
3 
Q What Is the last grade you completed in 
24 
to jail personnel your address was 301 Enst 66th 
4 
school? 
25 
Street, apartment WO in New York City, New York; 
5 
A The Fifth, I take the Fifth Amendment. 
7 
is that correct? 
9 
Q Are you in school now? 
2 
MR. YAREMA: Objection. 
2 
A The Fifth. 
3 
A Fifth. 
3 
Q Have you ever attended any school in the 
4 
Q Isn't it true when Mr. Epstein was in 
4 
United States? 
5 
Jail, you visited him on more than 50 occasions? 
5 
A The Fifth. 
6 
MR. YAREMA: Form objection. 
6 
Q Have you ever been employed since 
7 
Q True? 
7 
residing in the United States? 
8 
A The Fifth. 
8 
A The Fifth. 
9 
Q How long have you been in the United 
9 
Q Is Jeffrey Epstein your sole means of 
10 
States, Ms. Marcinkova? 
10 
❑nancial support today? 
11 
A The Fifth. 
11 
MR. YAREMA: Object to the form. 
12 
Q Who brought you to the United States? 
12 
A The Fifth. 
13 
MR. YAREMA: Form objection. 
13 
Q Since coming to this country, hasn't 
14 
A The Fifth. 
14 
Jeffrey Epstein always been your sole means of 
15 
Q What is your current status in this 
15 
financial support? 
16 
country? 
16 
MR. YAREMA: Object to the form. 
17 
A The Fifth. 
7 
A The Fifth. 
18 
MR. YAREMA: Form objection. 
18 
Q Flow much does Jeffrey Epstein pay you 
19 
MR. GOLDBERGER: Lel me take a half a 
19 
today? 
20 
second. 
20 
MR. YAREMA: Object to the form. 
21 
(Witness and her counsel confer.) 
21 
A The Fifth. 
22 
Q Are you a U.S. citizen? 
22 
Q What does every Epstein pay you for? 
23 
A The Fifth. 
23 
MR. YAREMA: Object to the form. 
24 
Q What type of visa are you here on? 
24 
A The Fifth. 
25 
MR. YAREMA: Form objection. 
25 
Q Does he pay you specifically to be his 
3 (Pages 6 to 9) 
U.S. Legal Support 
(561) 835-0220 
EFTA00188948

Case 9:O8-cv-ff1716 6„ 
A nor' tmonf 797-71 Cott:triad na.a 
nnrket f11/91/7O15 Page 5 of 7 
54 
56 
1 
A Fifth. 
1 
Jeffrey Epstein specifically Dew to Palm Beach 
2 
Q Do you know Bill Clinton? 
2 
for the purposes of engaging in sex acts with 
3 
A Fifth. 
3 
Jane Doe? 
4 
Q You have been on Jeffrey Epstein's 
4 
MR. YAREMA: Object to the fonn. 
5 
airplane with Bill Clinton? 
S 
A Fifth. 
6 
MR. YAREMA: Object to the fonn. 
6 
Q Generally, isn't It true Jeffrey Epstein 
7 
A Filth. 
7 
would fly from place to place fur the purpose of 
8 
Q isn't take true you have been on Jeffrey 
8 
engaging In sexual activity with minors at his 
9 
Epstein's airplane with Dung Band, Bill Clinton's 
9 
destination? 
10 
'thalami man? 
10 
MR. YAREMA: Object to the fonn. 
11 
MR. YAREMA: Object to the fonn. 
11 
A Fifth. 
12 
A Fifth. 
12 
Q Isn't it true that he employed numerous 
13 
Q Have you witnessed Improper sexual 
13 
people for the sole purpose of scheduling 
14 
activity between Jeffrey Epstein and minors, 
14 
appointments with underage minor females at each 
15 
while he was in the presence of Bill Clinton? 
15 
destination he landed? 
16 
MR. YAltEMA: Object to the form. 
16 
MR. YAREMA: Object to the fonn. 
17 
A Fifth. 
17 
A Fifth. 
18 
Q How many limes have you ridden on the 
18 
Q Whnt is Jeffrey Epstein's relationship 
19 
airplane with Jean Luc Brunel? 
19 
with Sandy Berger? 
20 
MR. YAREMA: Object to the form. 
20 
MR. YAREMA: Object to the tbnn. 
21 
A Fifth. 
21 
A Fifth. 
22 
Q Each time that Jean Luc Brunel visits 
22 
Q Do you know what Jeffrey Epsteltes 
23 
Jeffrey Epstein's house, does he bring underage 
23 
relationship is with Alan Dershowitz? 
24 
minors to Jeffrey Epstein's house to engage in 
24 
MR. YAREMA: Object to the fonn. 
25 
sex with? 
25 
A Fifth. 
55 
57 
1 
MR. YAREMA: Object to the form. 
1 
Q That's somebody who you know to have 
2 
A Fifth. 
2 
stayed at Jeffrey Epstein's house on ninny 
3 
Q Do you know Glenn Dubin? 
3 
occasions, correct? 
4 
A Fifth. 
4 
MR. YAREMA: Object to the fonn. 
5 
Q Do you know I
lr? 
5 
A Fifth. 
6 
A Fifth. 
6 
Q And also somebody who you know to have 
7 
Q Is that somebody that was a sexual abuse 
7 
been at the house when M. was in Jeffrey 
8 
victim nt one point In time of Jeffrey Epstein 
8 
Epstein's bedroom getting sexually abused, 
9 
and Jean Luc Brunel? 
9 
correct? 
10 
MR. YAREMA: Object to the fonn. 
10 
MR. YAREMA: Object to the form. 
11 
A Fifth. 
11 
A Fitlh. 
12 
Q Between 2002 and 2005 when M. was 
12 
Q Alan Dershowitz Is also somebody that 
13 
abused by Jeffrey Epstein sexually, isn't It true 
13 
you also know to have been at the house wham.. 
14 
that Jeffrey Epstein took flights to Palm Bench 
14 
was being sexually abused in Jeffrey Epstein's 
15 
for the purposes of sexually abusing..? 
15 
bedroom, correct? 
16 
MR. YAREMA: Object to the !bon. 
16 
MR. YAREMA: Object to the tom. 
17 
A Fifth. 
17 
A Filth. 
18 
Q And between those same years of 2002 and 
18 
Q Generally, Alan Dershowitz is familiar 
19 
2005, Isn't It true that Jeffrey Epstein look 
19 
with Jeffrey Epstein's habit of engaging In 
20 
airplane flights to PnIni Beach from places 
20 
sexual acts with minors on a daily basis, 
21 
outside of the State, to engage in sexual nets 
21 
correct? 
22 
with M.? 
22 
MR. YAREMA: Object to the foram. 
23 
MR. YAREMA: Object to the form. 
23 
A Fifth. 
24 
A Fifth. 
24 
Q When Alnn Dershowitz was in town, 
25 
Q From 2003 through 2005, isn't It true 
25 
Jeffrey Epstein did not break Ids schedule for 
15 (Pages 54 to 57) 
U.S. Legal Support 
(561) 835-0220 
EFTA00188949

Case 9:08-cv-§nTIR-k 
A nnri iment 2q1-21 PritPfPrI nn P 
nnrkrat n1 /21/2nic Page 6 of 7 
1 
2 
3 
4 
5 
6 
58 
Alan Dershowitx, meaning he continued to sexually 
abuse minors despite Alan Dershowitz being a 
guest In the house? 
MR. YAREMA: Object to the fonn. 
A Filth. 
Q Atnn Dershowitz never engaged in any 
1 
2 
3 
4 
6 
60 
Q What was the purpose of that flight? 
MR. YAREMA: Object to the fbrm. 
A Fifth. 
Q Did you sign a confidentiality agreement 
with Jeffrey Epstein? 
MR. YAREMA: Object to the font 
7 
sexual activity with these underage minors; isn't 
7 
A Fifth. 
8 
that true? 
8 
Q When is the last time that you observed 
9 
MR. YAREMA: Object to the fonn. 
Jeffrey Epstein have sex with n minor? 
10 
A Fifth. 
10 
MR. YAREMA: Object to the font 
11 
Q Have you been Inside to hove sex with 
11 
A Fifth. 
12 
Chislaine Maxwell? 
12 
Q Since being on probation, has Jeffrey 
13 
MR. YAREMA: Object to the fonn. 
13 
Epstein been able to, or has he flown to his 
19 
A Fifth. 
14 
Island? 
15 
Q Do you know 
15 
MR. YAREMA: Object to the fonn. 
16 
A Filth. 
16 
A Fifth, 
17 
Q Similar to you being Jeffrey Epstein's 
17 
Q To your knowledge, has Jeffrey Epstein 
18 
sex slave. is 
or was 
18 
flown to New York while on probation or community 
19 
Chislaine Maxwell's sex slave? 
19 
control? 
20 
MR. YAREMA: Object to the fonn. 
20 
MR. YAREMA: Object to the form. 
21 
A Fifth. 
21 
A Fifth. 
22 
Q Chislaine Maxwell is somebody who you 
22 
Q Isn't it true that he has flown both to 
23 
know to be bl-sexual, true? 
23 
New York and to his island, and you have 
24 
MR. YAREMA: Object to the fonn. 
24 
accompanied him on those trips, since he was on 
25 
A Fifth. 
25 
community control? 
59 
61 
1 
Q You know that Chislakte Maxwell engaged 
1 
MR. YAREMA: Object to the form. 
2 
in sexual acts with underage minor females, true? 
2 
A Fifth. 
3 
MR. YAREMA: Object to the form 
3 
Q Isn't it also true that Jeffrey Epstein 
A Fifth. 
4 
has indicated to you that he will always engage 
5 
Q This is yet another friend of Jeffrey 
5 
in sex acts with underage minor females? 
6 
Epstein's that is into the act of molesting 
6 
MR. YAREMA: Object to the fonn. 
7 
underage minor females, right? 
7 
A Fifth. 
8 
MR. YAREMA: Object to the feint 
Q In fact, that's something that he has 
9 
A Fifth. 
9 
told you, that he believes he is entitled to do; 
10 
Q Now, you are the next participant in 
10 
isn't that right? 
11 
that activity, meaning you have been groomed to 
11 
MR. YAREMA: Object to the fonn. 
12 
enjoy and appreciate the nets of sex with 
12 
A Fifth. 
13 
underage minors, true? 
13 
Q Isn't it true that Jeffrey Epstein 
14 
MR. YAREMA: Object to the form. 
19 
believes and has told you that if he doesn't 
15 
A Fifth. 
15 
physically force the underage minor female Into 
16 
Q Has Jeffrey Epstein instructed you to 
16 
any act, then he is entitled to engage in sex 
17 
lie to his Probation Officer in any way? 
17 
with any underage minor female despite the age? 
18 
MR. YAREMA: Object to the form. 
18 
MR. YAREMA: Object to the fonn. 
19 
A Fifth. 
19 
A Filth. 
20 
Q Mr. Visoski testified that you took a 
20 
Q What is the youngest female you have 
21 
helicopter flight within the last year with 
21 
witnessed or observed Jeffrey Epstein to engage 
22 
Jeffrey Epstein to Miami. Do you remember that 
22 
in sex with? 
23 
flight? 
23 
MR. YAREMA: Object to the form. 
24 
MR. YAREMA: Object to the form. 
24 
A Fifth. 
25 
A Fifth. 
25 
Q Do you have n bank account at Chase flank 
16 (Pages 58 to 61) 
U.S. Legal Support 
(561) 835-0220 
EFTA00188950

9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Case 9:08-cv-F979A-K 
A flnrument 991-71 Entered nn P 
98 
1 
2 
3 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A Fifth. 
Q Did you know that Jeffrey Epstein gave 
A.D. n digital camera? 
MR. YAREMA: Object to the form. 
A Fifth. 
MS. EZELL: I don't have any other 
questions. Thank you. 
MR. GOLDBERGER: You still hove your 
microphone on. You must have something on 
your mint, Bind. 
REDIRECT EXAMINATION 
BY MR. EDWARDS: 
Q Ms. 
through the whole day 
you've taken the Fifth on just about every single 
question. Is there any reason why we should not 
presume that the answer to these questions would 
Incriminate you? 
MR. YAREMA: Object to the form. 
A The Fifth. 
Q The reason that you have taken the Fifth 
Is because the questions you have been asked 
would have been answered In the affirmative and 
you're afraid of prosecution for your 
Involvement, true? 
MR. GOLDBERGER: Don't answer that 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
rinrkpt nt /91 OM c Pagp 7 of 7 
100 
1.11E STATE OF FLORIDA) 
COUNTY OF PALM BEACH) 
TEltRI DECKER, a Registered 
Professional Reporter and Notary Public for the 
State of Florida at Large, do hereby cenift, that 
I reported the videotaped deposition or 
the WITNESS, called by the PLAINTIFF 
in the above-entitled action; that the witness 
was duly sworn by Inc; that the foregoing pages, 
numbered from Ito 104, inclusive, constitute a 
true record of the deposition by said witness. 
I further comity that I am not attorney 
or counsel of any of the parties, nor a relative 
or employee of any attorney or counsel commit'', 
with the action, nor financially interested in 
the action. 
WITNESS MY HAND and official seal in the 
City of West Palm Beach, County of Palm Beach, 
State of Florida, this 19th day of April 38 W. 
rr—
'TERRI DECKER, Registered 
Professional Reporter and 
Notary Public, State of Florida 
at Large. My Commission expires 
March 13,2011. 
99 
1 
question. It interferes with the 
2 
attorney/client relationship that I have 
3 
with Ms. 
and any discussions she 
4 
and I may have had would come under that 
5 
privilege. 
6 
You can try and dance around that, but 
7 
I'm simply not going to allow her to answer 
8 
that question. If you want to bring it up 
with the Judge, you can. 
MR. EDWARDS: Thanks, Jack. 
MR. GOLDBERGER: Okay. 
THE VIDEOGRAPHER: Off the video record 
at I:41 p.m. 
THE COURT REPORTER: You're ordering 
this, Brad? 
MR. EDWARDS: Yes. Copies? 
MS. EZELL: Yes. 
MR. YAREMA: Yes: 
THE COURT REPORTER: And Adam wanted ik 
is that right? 
MR. EDWARDS: Yes. 
(Tune noted: 1:45 p.m.) 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
THE STATE OF FLORIDA) 
COUNTY OF PALM BEACH) 
The foregoing certificate was 
acknowledged before me this 
day of 
 
 
2010. 
101 
Notary Public, State of Florida. 
My conunission No. 
Expires March 13, 201 t. 
26 (Pages 98 to 101) 
U.S. Legal Support 
(561) 835-0220 
EFTA00188951

EFTA00188952

Case 9:08-cv-80736-K,..A Document 291-22 Entered on FL -3 Docket 01/21/2015 Page 2 of 7 
1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-CV-80893-CIV-MARRA/JOHNSON 
JANE DOE, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, et al., 
Defendants. 
DEPOSITION OF ADRIANA ROSS 
Volume 1 of 1 
Pages 1 through 138 
Videotaped 
Monday, March 15, 2010 
10:13 a.m. - 12:42 p.m. 
U.S. Legal Support 
515 East Las Olas Boulevard, 3rd Floor 
Fort Lauderdale, Florida 33301 
Stenographically Reported By: 
Janet L. McKinney, RPR, FPR, CLR 
Registered Professional Reporter 
Florida Professional Reporter 
Certified LiveNote Reporter 
U.S. Legal Support 
(954) 463-2933 
EFTA00188953

Case 9:08-cv-80736-k. .A Document 291-22 Entered on FL J Docket 01/21/2015 Page 3 of 7 
2 
APPEARANCES: 
ON BEHALF OF THE PLAINTIFF: 
FARMER, JAFFE, WEISSING, EDWARDS, 
FISTOS & LEHRMAN 
BY: BRADLEY EDWARDS, ESQ. 
ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN: 
BURMAN, CRITTON, LUTTIER & 
COLEMAN, LLP 
BY: MICHAEL J. PIKE, ESQ. 
ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES: 
MERMELSTEIN & HOROWITZ, P.A. 
305.931.2200 
Ssm@sexabuseattorney.com 
BY: STUART S. MERMELSTEIN, ESQ. 
ON BEHALF OF THE WITNESS: 
ROBBINS, TUNKEY, ROSS, AMSEL, 
RABEN & WAXMAN, P.A. 
BY: ALAN S. ROSS, ESQ. 
Also Present: Sean McGuire, Videographer 
U.S. Legal Support 
U.S. Legal Support 
(954) 463-2933 
EFTA00188954

Case 9:08-cv-80736-k. 
Document 291-22 Entered on FL J Docket 01/21/2015 Page 4 of 7 
36 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Q. Jane Doe 102 ultimately escaped from him and 
left to 
, is that your understanding? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. Have you ever spoken with Jane Doe 102? 
A. I refuse to answer. 
Q. On one of Epstein's birthdays a friend of 
Jeffrey Epstein sent to him 12 -- three 12-year-old 
girls from France who spoke no English for Epstein to 
sexually exploit and abuse and after doing so he sent 
them back to France the next day. Are you familiar 
with that? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Isn't that something that is fairly common for 
Mr. Epstein? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. Who are the friends that send to Jeffrey 
Epstein underage minor females for his birthday so that 
he can abuse? 
A. I refuse to answer. 
MR. PIKE: Form. 
Is one of those friends Jean Luc Brunel? 
Q• 
A. I refuse to answer. 
U.S. Legal Support 
(954) 463-2933 
EFTA00188955

Case 9:08-cv-80736-k, ..A Document 291-22 Entered on FL-) Docket 01/21/2015 Page 5 of 7 
37 
1 
2 
3 
4 
5 
6 
7 
9 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Q. Have you ever met Prince Andrew? 
A. I refuse to answer. 
Q. Has Prince Andrew been involved with underage 
minor females to your knowledge? 
A. I refuse to answer. 
Q. Have you ever met Alan Dershowitz? 
A. I refuse to answer. 
Q. When Alan Dershowitz stays at Jeffrey 
Epstein's house isn't it true that he has been at the 
house when underage minor females have been in the 
bedroom with Jeffrey Epstein? 
A. I refuse to answer. 
Q. Has -- are you familiar with the media 
publication or online resource RadarOnline? 
A. I refuse to answer. 
Q. Is that something that you assisted 
Mr. Epstein with when he purchased RadarOnline? 
A. I refuse to answer. 
Q. And do you know his business partner in that 
endeavor? 
A. I refuse to answer. 
Q. Isn't it also true that he used RadarOnline as 
another way to gain access to underage minor females 
for sex? 
MR. PIKE: Form. 
U.S. Legal Support 
(954) 463-2933 
EFTA00188956

Case 9:08-cv-80736-K. 
Document 291-22 Entered on FL 
Docket 01/21/2015 Page 6 of 7 
81 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
friends? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q• Who is Sandy Berger? 
A. I refuse to answer. 
Q. That's somebody else that was affiliated with 
Bill Clinton at one point in time, correct? 
A. I refuse to answer. 
Q. A close friend of Jeffrey Epstein's? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. He called the house within three weeks of the 
search warrant being executed. Did he tip off Jeffrey 
Epstein? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Is he somebody that's involved with underage 
minors? 
A. I refuse to answer. 
Q. Do you know Igor Zinoviev? 
A. I refuse to answer. 
Q. 
A. I refuse to answer. 
Q. Have you flown on the airplane with Alan 
Dershowitz before? 
U.S. Legal Support 
(954) 463-2933 
EFTA00188957

Case 9:08-cv-80736-K, 
Document 291-22 Entered on FL J Docket 01/21/2015 Page 7 of 7 
82 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
MR. PIKE: 
Form. 
A. I refuse to answer. 
Q. And Jean Luc Brunel is somebody who you have 
been on the airplane with several times, correct? 
A. I refuse to answer. 
MR. PIKE: Form. 
And when Jean Luc Brunel is on this airplane 
Q. 
there are underage minor 
minor females on the 
airplane with you, correct? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Is there a back room to this airplane? Is 
there any sort of separation or is it all one big room? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. So if Jeffrey Epstein and Jean Luc Brunel are 
engaged in sex acts with underage minors did you --
A. I refuse --
Q. Sorry -- did you observe any of those acts? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. And on numerous of the flights the flight logs 
indicate someone's name then oftentimes initials, but 
sometimes it would just say "three females". Do you 
know why? 
U.S. Legal Support 
(954) 463-2933 
EFTA00188958

EFTA00188959

Case 9:08-cv-80736-r.AM Document 291-23 Entered on i _SD Docket 01/21/2015 Page 1 of 6 
EXHIBIT 24 
EFTA00188960

Case 9:08-cv-80736-I.AM Document 291-23 Entered on I _SD Docket 01/21/2015 Page 2 of 6 
Page 1 
IN THECIRCUITCOURT OF TIIE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM DEACFI COUNTY, FLORIDA 
CASE No.502009CA040800XXXXMBAG 
JEFFREY EPSTEIN, 
Plaintiff , 
SCOTT ROTHSTEIN, individually, 
BRADLEY J. EDWARDS, individually, and 
, individually, 
Defendants. 
1 
2 
3 
4 
5 
6 
7
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 3 
_ 
_ _ 
EXHIBITS 
. . - 
NUMBER 
DESCRIPTION 
PAGE 
Exhibit number I 
Eyeglasses 
133 
VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN 
Wednesday. March 17, 2010 
RE I7a.m.- 1:27 p.m. 
Reported By: 
Sandra W. Townsend, FPR 
Notary Public, State of Florida 
West Palm Beach Office Job #1358 
Page 2 
Page 4 
1 
APPEARANCES: 
1 
PROCEEDINGS 
2 
1 
On behalf of the Plaintiff: 
MICHAEL PIKE, ESQUIRE. 
2 
- - - 
BURMAN CRiTTON LUTTIER & COLEMAN, LLP 
3 
Deposition taken before Sandra W. Townsend, Court 
4 
4 
Reporter and Notary Public in and for the Stale of 
5 
5 
Florida at Large, in the above cause. 
6 
6 
_ _ - 
7 
e 
On behalf of the Defendant Bradley Edwards: 
JACK SCAROLA, ESQUIRE 
7 
VIDEOGRAPHER: We are now on video record. 
SEARCY DENNEY SCAROLA BARNHART& SHIPLEY 
B 
This is media number one in the videotaped 
9 
9 
deposition of Jeffrey Epstein in the matter of 
io 
10 
Jeffrey Epstein versus Scott Rothstein, Bradley 
11 
On I:chalk:if the Defendant 
r 
11 
Edwards and ■. 
12 
BRADLEY EDWARDS: ESQUIRE 
FARMER, JAFFE, WEISSING: EDWARDS, FISTOS, 
12 
Today is Wednesday, March 17,2010 at
13 
13 
10:17 a.m. 
14 
14 
We arc at the law offices of Burman, 
15 
Critton
 n -- of Burman Critton on 
15 
16 
16 
Also Present: 
17 
STEVEN JAFFE, ESQUIRE 
17 
FARMER, JAFFE, WEISSING. EDWARDS, FISTOS. 
18 
The court reporter is Sandra Townsend from Prose 
18 
19 
Court Reporting Agency. 
19 
20 
Would Counsel please introduce yourselves and 
21 
then the court reporter will swear in the witness. 
21 
20 
22 
MR. SCAROLA: My name is Jack Scarola. I am 
22 
23 
Counsel on behalf of Brad Edwards in his capacity, 
23 
24 
24 
both as Defendant and Counter-Plaintiff in this 
25 
25 
action. Mr. Edwards is present with me. 
1 
(Pages 1 to 4) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401.377.676.2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
1ddctb84-b324-4437-a670-765e29067145 
EFTA00188961

Case 9:08-cv-80736-.AM Document 291-23 Entered on . ._SD Docket 01/21/2015 Page 3 of 6 
Page 89 
Page 91 
1 
Amendment Rights as provided by the U.S. 
1 
about. The one in which your deposition is being taken 
2 
Constitution. 
2 
today. 
3 
BY MR. SCAROI.A: 
3 
Do you know who brought those persons' names 
4 
Q. Does a flight log kept for a private jet used 
4 
into this lawsuit? 
5 
by you contain the names of celebrities, dignitaries or 
5 
A. As a reaction, and only as a reaction to total 
6 
International figures? 
6 
misbehavior on Mr. Edwards' part, and the Complaint we, 
7 
A. At least today, sir. I'm going to have to 
7 
obviously written by my attorneys, sir. 
8 
respectfully decline to answer based on my Fifth, Sixth 
8 
Q. So you know that those names are in your 
9 
and 14th Amendment Right, though I'd like to answer that 
9 
Complaint, right? 
10 
question. 
10 
A. Yes, sir. 
11 
Q. Have you ever had a personal relationship with 
11 
Q. Okay. So because those names are in your 
12 
Donald Trump? 
12 
Complaint, I'm asking you about the people you named. 
13 
A. What do you mean by *personal relationship," 
13 
Have you had a social relationship with Tommy 
14 
sir? 
14 
Mottola? 
15 
Q. Have you socialized with him? 
15 
A. The names in my Complaint are strictly as a 
16 
A. Yes, sir. 
16 
reaction to the abusive discovery process by 
17 
Q. Yes? 
17 
Mr. Edwards, his partners, Scott Rothstein, who sits in 
18 
A. Yes, sir. 
18 
jail, in an attempt to imperil my friendships. 
19 
Q. Have you ever socialized with Donald Trump in 
19 
But, yes, I have socialized with Mr. Mottola. 
20 
the presence of females under the age of 18? 
20 
Q. Have you ever socialized with Mr. Mottola in 
21 
A. Though I'd like to answer that question, at 
21 
the presence of females under the age of 18? 
22 
least today I'm going to have to assert my Fifth, Sixth 
22 
MR. PIKE: Form. 
23 
and 14th Amendment Right, sir. 
23 
TIIE WITNESS: At least today, the typical to 
24 
Q. Have you socialized with Alan Dershowitz? 
24 
the Edwards contention of bringing cases of a 
25 
A. Yes, sir. He's my attorney, as well as a 
25 
malicious nature where his partner sits in jail for 
Page 90 
Page 92 
1 
friend. 
1 
this --just this type of behavior, the answer is, 
2 
Q. Have you ever socialized with Alan Dershowitz 
2 
today, at least, I must assert my Fifth, Sixth and 
3 
in the presence of females under the age of 18? 
3 
14th Amendment Right, though I'd like to answer 
4 
MR. PIKE: Form. 
4 
each and every one of your questions, Mr. Scarola. 
5 
THE WITNESS: Sir, at least here today, I'm 
5 
BY MR. SCAROLA: 
6 
going to have to assert my Fifth Amendment, Sixth 
6 
Q. Have you had a social relationship with David 
7 
Amendment and 14th Amendment Rights. 
7 
Copperfield? 
8 
BY MR. SCAROLA: 
8 
A. As a reaction to, once again, the abusive 
9 
Q. Have you ever socialized with Tommy Mottola`. 
9 
discovery process of bringing in names of people that 
10 
A. This is the type of questions where people who 
10 
have absolutely nothing to do with any of Mr. Edwards', 
11 
have nothing to do with this case whatsoever have been 11 
Mr. Rothstein's or their clients' claims, by bringing in 
12 
brought into the case by Mr. Edwards in an attempt to 
12 
the names of friends of mine strictly in an attempt to 
13 
simply imperil my relationships with social friends and 
13 
stress my relationships, imperil my business 
14 
serves as an example of why this case has been brought 14 
relationships, I'm going to say, yes, I do know 
15 
against Mr. Edwards and his firm, sir. 
15 
Mr. Copperfield. 
16 
MR. PIKE: Form as well. 
16 
Q. Have you ever socialized with David 
17 
BY MR. SCAROLA: 
17 
Copperficld? 
18 
Q. Well, do you know who brought those persons' 
18 
A. Again, as --
19 
names into this lawsuit? 
19 
MR. PIKE: Form. 
20 
MR. PIKE: Form. 
20 
THE WITNESS: Sorry. 
21 
And just to be clear, what Mr. Scarola, I 
21 
It's a typical Edwards/Rothstein strategy of 
22 
believe, talking about this lawsuit, Epstein versus 
22 
trying to involve well-known people in maliciously 
23 
RRA? 
23 
fabricated cases in order to fleece investors out 
24 
BY MR. SCAROLA: 
24 
of millions of dollars. They brought up names in 
25 
Q. Yes, sir, that's the lawsuit I'm talking 
25 
attempts at abuse of discovery process to try and 
23 (Pages 89 to 92) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401477476.2895) 
Electronically signed by Sandra Townsend (401.317.676.2895) 
lddctb84-b324-4437-a670-765e29067145 
EFTA00188962

Case 9:08-cv-80736-.AM Document 291-23 Entered on -SD Docket 01/21/2015 Page 4 of 6 
Page 16 
IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE No. 502008CA037319XXXXMB AB 
M. s 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
CONTINUED DEPOSITION OF JEFFREY EPSTEIN 
VOLUME II 
Thursday, October 8, 2009 
10:07 - 1:03 p.m. 
Reported By: 
Jeana Ricciuti, RPR, FPR, CLR 
Notary Public, State of Florida 
Prose Court Reporting Agency, Inc. 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Riccluti (601-280-428-9381) 
Electronically signed by Joana RIccluti (601.280.428.9381) 
aalcaccd-2433-45cb-b5a2-c08425252119 
EFTA00188963

Case 9:08-cv-80736.. AM Document 291-23 Entered on . -SD Docket 01/21/2015 Page 5 of 6 
Page 121 
1 
respect to the charges brought against you in Palm Beach 
2 
for having sex with underaged girls and soliciting 
3 
underaged girls for prostitution? 
4 
(Interruption in the proceedings.) 
5 
MR. GOLDBERGER: Thank you. 
6 
Hey Kathy, it's Jack Goldberger. You're back 
7 
on. 
8 
MS. EZELL: Okay, good. Thanks, Jack. 
9 
MR. GOLDBERGER: Okay. 
10 
MS. EZELL: I'm putting the mute on. 
11 
MR. GOLDBERGER: Okay. 
12 
THE WITNESS: Can you read me the question? 
13 
MR. KUVIN: Sure. Could you read it back, 
14 
please? 
15 
(A portion of the record was read by the 
16 
reporter.) 
17 
THE WITNESS: No. 
18 
BY MR. KUVIN: 
19 
Q. 
Isn't it true that you pledged $30 million to 
20 
Harvard University in 2003, which is shortly before 
21 
charges were brought against you in Palm Beach? 
22 
A. 
I'll answer that question the same way I've 
23 
answered most of your other questions here today, which 
24 
is, I fully intend to respond to all relevant questions 
25 
regarding this lawsuit; however, at the present time, my 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Joana Iticcluti (601-280-428-9381) 
Electronically signed by Jeana Riccluti (601.280-428-9381) 
a41caccd•2433-45cb-b5a2-c08425252179 
EFTA00188964

Case 9:08-cv-80736 .,AM Document 291-23 Entered on . _SD Docket 01/21/2015 Page 6 of 6 
Page 122 
1 
attorneys have counseled me I cannot provide answers to 
2 
any questions relevant to this lawsuit. I must accept 
3 
this advice or risk losing my 6th Amendment right to 
4 
effective representation. Accordingly, I assert my 
5 
federal constitutional rights as guaranteed by the 5th, 
6 
6th and 14th Amendment to the US Constitution. 
7 
Q. 
And isn't it true also that you have retained 
8 
Alan Dershowitz to defend you in the criminal charges 
9 
that were brought against you in Palm Beach? 
10 
MR. GOLDBERGER: Attorney-client. 
11 
MR. PIKE: Attorney-client, work product. 
12 
BY MR. KUVIN: 
13 
Q. 
Isn't it also true that Alan Dershowitz works 
14 
on staff at Harvard University as a professor? I mean, 
15 
if you know. 
16 
A. 
I'm going to answer that question like I've 
17 
answered most of your other questions here today, which 
18 
19 
20 
21 
22 
23 
right to effective representation. Accordingly, I 
24 
assert my federal constitutional rights as guaranteed by 
25 
the 5th, 6th and 14th Amendment to the US Constitution. 
is, I fully intend to respond to all relevant questions 
regarding this lawsuit; however, at the present time, my 
attorneys have counseled me I cannot provide answers to 
any questions that may be relevant to this lawsuit. I 
must accept this advice or risk losing my 6th Amendment 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Joana Ricoh:9 (601-280-428-9381) 
Electronically signed by Jeana Riccluti (601.280.428.9381) 
a41caccd-2433-45cb-b6a2-c08425262f79 
EFTA00188965

! 
i 
EFTA00188966

Case 9:08-cv-80736 ..AM Document 291-24 Entered on . -SD Docket 01/21/2015 Page 1 of 3 
EXHIBIT 25 
EFTA00188967