EFTA01158522

0016 
1 
2 
IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
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4 
5 
=., 
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7 
8 
9 
10 
- vs-
CASE No. 502008CA037319XXXXMB AB 
Plaintiff, 
JEFFREY EPSTEIN, 
Defendant. 
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12 
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CONTINUED DEPOSITION OF JEFFREY EPSTEIN 
14 
VOLUME II 
15 
16 
Thursday, October 8, 2009 
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18 
10:07 - 1:03 p.m. 
19 
20 
250 South Australian Avenue 
Suite 1400 
21 
West Palm Beach,Florida 33401 
22 
23 
Reported By: 
Jeana Ricciuti, RPR, FPR, CLR 
24 
Notary Public, State of Florida 
Prose Court Reporting Agency, Inc. 
25 
0017 
1 
APPEARANCES: 
2 
On behalf of the Plaintiff: 
SPENCER T. KUVIN, ESQUIRE 
3 
ADAM LANGINO, ESQUIRE 
LEOPOLD KUVIN, P.A. 
4 
2295 PGA Boulevard 
Suite 200 
5 
Palm Beach Gardens, Florida 33410 
Phone: 
6 
On behalf of IIM. and III. and Jane Doe in Case No. 
7 
80893: 
CARA L. HOLMES, ESQUIRE 
8 
ROTHSTEIN, ROSENFELDT & ADLER 
401 East Las Olas Boulevard 
9 
Suite 1650 
Fort Lauderdale, Florida 33301 
10 
Phone: 
11 
On behalf of Plaintiff Jane Doe in Case No. 80591 and 
80656 via telephone: 
12 
KATHERINE W. EZELL, ESQUIRE 
PODHURST ORSECK, P.A. 
13 
25 West Flagler Street 
Miami, Florida 33130 
14 
Phone: 
15 
On behalf of the Defendant: 
JACK GOLDBERGER, ESQUIRE 
16 
STORY KOWLES, PARALEGAL 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
EFTA01158522

17 
250 South Australian Avenue 
18 
Suite 1400 
West Palm Beach, Florida 33401 
Phone: 
19 
MICHAEL J. PIKE, ESQUIRE 
20 
BURMAN, CRITTON, LUTTIER & COLEMAN, P.A. 
21 
303 Banyan Boulevard 
Suite 400 
22 
West Palm Beach, Florida 
Phone: 
33401 
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ALSO PRESENT: 
24 
DAN DOSKEY, VIDEOGRAPHER 
25 
VISUAL EVIDENCE, INC. 
0018 
1 
2 
INDEX 
3 
WITNESS: 
DIRECT 
CROSS 
REDIRECT 
RECROSS 
4 
JEFFREY EPSTEIN 
5 
BY MR. KUVIN 
21 
6 
7 
8 
EXHIBITS 
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10 
NUMBER 
DESCRIPTION 
PAGE 
11 
PLAINTIFF'S EX. 1 
FDLE SEXUAL 
24 
OFFENDER/PREDATOR FLYER 
12 
PLAINTIFF'S EX. 2 
STATEMENT 
25 
PLAINTIFF'S EX. 3 
PHOTOGRAPH OF HOME 
33 
13 
PLAINTIFF'S EX. 4 
BOTTLE OF JOY JELLY 
38 
PLAINTIFF'S EX. 5 
PHOTOGRAPH OF GIRL 
129 
14 
PLAINTIFF'S EX. 6 
PHOTOGRAPH OF GIRL 
129 
PLAINTIFF'S EX. 7 
PHOTOGRAPH OF GIRL 
131 
15 
PLAINTIFF'S EX. 8 
PHOTOGRAPH OF GIRL 
132 
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19 
20 
21 
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0019 
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PROCEEDINGS 
Deposition taken before Jeana Ricciuti, Registered 
Professional Reporter and Notary Public in and for the 
State of Florida at Large, in the above cause. 
THE VIDEOGRAPHER: We're on the video record. 
This is the 8th day of October, 2009, and the time 
it approximately 10:07 a.m. 
This is the continuation of the videotaped 
deposition of Jeffrey Epstein in the matter of 
versus Epstein. This deposition is being held at 
250 South Australian Avenue, No. 1400 in West Palm 
Beach, Florida. 
My name is Dan Doskey 
I'm the videographer 
EFTA01158523

16 
representing Visual Evidence, Incorporated. 
17 
Would the attorneys present please announce 
18 
their appearances for the record? 
19 
MR. KUVIN: Spencer Kuvin and Adam Langino on 
20 
behalf of the Plaintiff, §§§. 
21 
MS. HOLMES: Cara Holmes for III. 
22 
MR. PIKE: Michael Pike on behalf of 
23 
Jeffrey Epstein. 
24 
MR. GOLDBERGER: And Jack Goldberger on behalf 
25 
of Jeffrey Epstein. 
0020 
1 
Kathy, do you want to identify yourself? 
2 
Kathy, are you there? 
3 
MS. EZELL: Yes. 
4 
MR. PIKE: She puts it on mute every once in a 
5 
while. 
6 
MR. GOLDBERGER: Hey, Kathy, are you there? 
7 
MS. EZELL: Yes. 
8 
MR. GOLDBERGER: Just -- we're just 
9 
identifying everyone who's on this thing. Can you 
10 
just identify yourself? 
11 
MS. EZELL: Yes. It's Kathy Ezell. I'm 
12 
sorry, Kathy Ezell is here. 
13 
- - -
14 
Thereupon, 
15 
(JEFFREY EPSTEIN) 
16 
having been first duly sworn or affirmed, was examined 
17 
and testified as follows: 
18 
THE WITNESS: Yes, ma'am. 
19 
MR. PIKE: Pull that back, please. 
20 
MR. KUVIN: Back? 
21 
MR. PIKE: Yeah, not on the video. I want to 
22 
make sure it's not on the video. 
23 
MR. KUVIN: We're good? Thank you. 
24 
THE VIDEOGRAPHER: It's not. 
25 
DIRECT EXAMINATION 
0021 
1 
BY MR. KUVIN: 
2 
Q. 
Could you give us your name, sir, please. 
3 
A. 
Jeffrey Epstein. 
4 
MR. GOLDBERGER: Kathy, you've got to put it 
5 
on mute. Kath -- Kathy? 
6 
MS. EZELL: Give me one second. 
7 
MR. GOLDBERGER: Just put it on mute, please. 
8 
MR. KUVIN: You can probably turn the volume 
9 
down; it won't effect her mic, I would imagine. 
10 
MR. GOLDBERGER: Good idea. Okay. 
11 
BY MR. KUVIN: 
12 
Q. 
Mr. Epstein, is your date of birth, 
13 
14 
A. 
Yes. 
15 
Q. 
Race is White? 
16 
A. 
Yes. 
17 
Q. 
You are male? 
18 
A. 
Yes. 
19 
Q. 
Hair is gray? 
20 
A. 
Yes. 
21 
Q. 
Eyes are blue? 
22 
A. 
Yes. 
23 
Q. 
Height is 6-foot tall? 
24 
A. 
Correct. 
25 
Q. 
Weight is 180 pounds? 
0022 
EFTA01158524

1 
A. 
Correct. 
2 
Q. 
Mr. Epstein, on January 30th of 2008, isn't it 
3 
true that you pled guilty to procuring a person under 
4 
the age of 18 for prostitution? 
5 
A. 
No. 
6 
Q. 
You did not plead guilty? 
7 
A. 
You asked me -- do you want to repeat it? 
8 
Q. 
Did you plead guilty to procuring a person 
9 
under the age of 18 for prostitution? 
10 
A. 
On what date? 
11 
Q. 
Regardless of the date, did you plead guilty 
12 
to procuring a person under the age of 18 for 
13 
prostitution? 
14 
MR. GOLDBERGER: Do you need to take a break? 
15 
MR. KUVIN: I'm sorry, what are we doing? 
16 
MR. GOLDBERGER: I'm taking a break to talk to 
17 
my client. 
18 
MR. KUVIN: For what reason? 
19 
MR. GOLDBERGER: Whether we have to invoke a 
20 
privilege or not. 
21 
MR. KUVIN: Okay. 
22 
THE VIDEOGRAPHER: Going off the record at 
23 
10:10. 
24 
(A brief recess was taken.) 
25 
THE VIDEOGRAPHER: We're back on the record at 
0023 
1 
10:12. 
2 
BY MR. KUVIN: 
3 
Q. 
Okay. Mr. Epstein, did you plead guilty to 
4 
procuring a person under the age of 18 for prostitution? 
5 
A. 
I pled guilty procuring a minor, I believe, 
6 
for prostitution. 
7 
Q. 
When did you plead guilty to that charge? 
8 
A. 
On June the 30th. 
9 
Q. 
And did you procure a minor for prostitution 
10 
in compliance with that charge? 
11 
A. 
I fully intend to respond to all relevant 
12 
questions regarding this lawsuit; however, at the 
13 
present time, my attorneys have counseled me I cannot 
14 
provide answers to any questions relevant to this 
15 
lawsuit. I must accept this advice or risk losing my 
16 
6th Amendment right to effective representation. 
17 
Accordingly, I assert my federal constitutional rights 
18 
as guaranteed by the 5th, 6th and 14th Amendment to the 
19 
US Constitution. 
20 
Q. 
Okay. I'd like to mark as Exhibit 1 the 
21 
Florida Department of Law Enforcement Sexual 
22 
Offender/Predator Flyer. 
23 
MR. KUVIN: For the record, let me show that 
24 
to Mr. -- well, let me show that to the camera, 
25 
first. 
0024 
1 
Okay. Let me know when you have it. 
2 
(Plaintiff's Exhibit No. 1 was marked for 
3 
identification.) 
4 
THE VIDEOGRAPHER: Okay. 
5 
MR. KUVIN: Okay? 
6 
BY MR. KUVIN: 
7 
Q. 
All right. Let me show you this sexual 
8 
offender/predator flyer. Is that you, sir? 
9 
A. 
It's a photograph of me, yes. 
10 
Q. 
Okay. Is that the predator flyer for you? 
11 
A. 
No, it is not. 
EFTA01158525

12 
Q. 
Who's it for? 
13 
A. 
It's a sexual offender flyer. 
14 
Q. 
I'm sorry, I was reading the title where it 
15 
says "Predator Flyer." Do you see that? 
16 
A. 
It actually said "Sexual Offender/Predator" 
17 
because it's used for both categories. And if you'll 
18 
notice, the designation says sexual offender, which is 
19 
extremely different than sexual predator. 
20 
Q. 
What's your understanding of the difference 
21 
between the two? 
22 
A. 
I'm not -- I know I'm a sex -- I've been 
23 
registered as a sexual offender. 
24 
Q. 
Why are you a sexual offender? 
25 
MR. GOLDBERGER: Jeff. 
0025 
1 
THE WITNESS: I fully intend to respond to all 
2 
relevant questions regarding this lawsuit; however, 
3 
at the present time, my attorneys have counseled me 
4 
I cannot provide answers to any questions relevant 
5 
to this lawsuit. I must accept this advice or risk 
6 
losing my 6th Amendment right to effective 
representation. Accordingly, I have to assert my 
federal constitutional rights as guaranteed by the 
5th, 6th and 14th Amendment to the US Constitution. 
MR. KUVIN: Let's go ahead and I'd like to 
mark what you're reading from here today as Exhibit 
2 to the deposition. 
(Plaintiff's Exhibit No. 2 was marked for 
identification.) 
BY MR. KUVIN: 
Q. 
Who prepared that document for you, sir? 
MR. GOLDBERGER: Don't answer that question, 
Jeffrey. It's attorney-client privileged and this 
is my work product, and we're not marking it, so... 
MR. KUVIN: I don't think you have the right 
to tell me what I can and can't --
MR. GOLDBERGER: You can mark it all you 
want --
MR. KUVIN: It's been marked. 
MR. GOLDBERGER: You can mark it all you want, 
7 
8 
9 
10 
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25 
0026 
1 
but it's not --
2 
MR. KUVIN: If you choose to --
3 
MR. GOLDBERGER: It's not -- it's not being 
4 
admitted into evidence. 
5 
MR. KUVIN: Sir, please don't interrupt me. 
6 
Are you --
7 
MR. GOLDBERGER: I'll interrupt you --
8 
MR. KUVIN: Are you representing Mr. Epstein 
9 
in this deposition or is Mr. Pike? Because I want 
10 
to be clear which one of you is going to be doing 
11 
the talking during the deposition. 
12 
MR. GOLDBERGER: We both are representing 
13 
Mr. Epstein. 
14 
MR. PIKE: Let's go off the record for a 
15 
second. 
16 
MR. KUVIN: No, we're not going off the 
17 
record. We're staying on the record and only one 
18 
attorney may speak at a time. 
19 
So right now, I'd like you all to choose. I 
20 
don't mind, either one of you can inject --
21 
MR. PIKE: Hold on a second. 
22 
MR. KUVIN: -- and represent Mr. Epstein. 
EFTA01158526

23 
MR. GOLDBERGER: Let -- let -- let him finish. 
24 
Let him finish. 
25 
MR. KUVIN: Let me finish, please. 
0027 
1 
Either one of you can represent Mr. Epstein, 
2 
but I don't want objections flying from both 
3 
chairs, both Mr. Epstein's criminal lawyer and his 
4 
civil lawyer. 
5 
So I'd ask you to please choose which one is 
6 
going to object, just like Judge Hafele has 
7 
required at hearings that only one attorney can 
8 
represent Mr. Epstein in an argument at a hearing. 
9 
MR. GOLDBERGER: Actually, we have two 
10 
different roles in this matter. I represent 
11 
Mr. Epstein on all criminal matters, so I'm going 
12 
to speak when I think it's relevant to any criminal 
13 
matters. And Mr. Pike represents Mr. Epstein on 
14 
any civil matters, and he will speak when it's 
15 
relevant to any civil matters. 
16 
BY MR. KUVIN: 
17 
Q. 
Okay. Sir, can I please have the paper back, 
18 
which has already been marked as Exhibit 2? 
19 
MR. KUVIN: Mr. Goldberger, if you choose that 
20 
this document is not to be produced in this case, I 
21 
have no objection to you sealing that document 
22 
until such time as Judge Hafele decides the issue 
23 
as to whether or not I'm allowed to mark something 
24 
that the witness is reading in a deposition. Is 
25 
that fair to you? 
0028 
1 
MR. GOLDBERGER: You can mark anything you 
2 
want to mark. Go ahead and mark it, and then we'll 
3 
go from there. 
4 
MR. KUVIN: Okay, sounds good. Thank you very 
5 
much. 
6 
BY MR. KUVIN: 
7 
Q. 
Okay, sir. What I've marked as Exhibit 2, did 
8 
you prepare that document? 
9 
MR. GOLDBERGER: Attorney-client. 
10 
THE WITNESS: Attorney-client privilege. 
11 
BY MR. KUVIN: 
12 
Q. 
Sir, you are reading from a document, are you 
13 
not, when I ask you certain questions? 
14 
MR. GOLDBERGER: Attorney-client. 
15 
BY MR. KUVIN: 
16 
Q. 
The document that you're reading from is 
17 
Exhibit 2 that's in front of you right now. 
18 
MR. GOLDBERGER: Attorney-client. 
19 
BY MR. KUVIN: 
20 
Q. 
Why do you feel a need to read from a document 
21 
with respect to the issues of whether or not you have a 
22 
5th Amendment right? 
23 
MR. GOLDBERGER: Attorney-client. 
24 
BY MR. KUVIN: 
25 
Q. 
Sir, with respect to the last questions I was 
0029 
1 
asking you about, the difference between a sexual 
2 
offender and a sexual predator, when Mr. Goldberg piped 
3 
up and said your --
4 
MR. GOLDBERGER: 
Goldberger. Goldberger. 
5 
BY MR. KUVIN: 
6 
Q. 
-- I'm sorry, Mr. Goldberger said your name in 
7 
order to clue you in to object on 5th Amendment 
EFTA01158527

8 
grounds --
9 
MR. GOLDBERGER: Form. 
10 
BY MR. KUVIN: 
11 
Q. 
-- did you feel a need to respond at that 
12 
point? 
13 
MR. PIKE: Object to the form. 
14 
MR. GOLDBERGER: The invocation of 5th 
15 
Amendment privileges is going to be decided by me, 
16 
as Mr. Epstein's criminal counsel. I will make 
17 
that decision. 
18 
MR. KUVIN: Okay. I would just like to note 
19 
for the record that that's improper. That's not 
20 
what the case law says, and we'll take that up --
21 
MR. GOLDBERGER: Fair enough. 
22 
MR. KUVIN: -- issue with Judge Hafele? 
23 
BY MR. KUVIN: 
24 
Q. 
All right, sir. Do you consider yourself a 
25 
sexual offender or a sexual predator, which one? 
0030 
1 
A. 
I fully intend to respond to all relevant 
2 
questions regarding this lawsuit; however, at the 
3 
present time, my attorneys have counseled me I cannot 
4 
provide answers to any questions relevant to this 
5 
lawsuit. I must accept this advice or risk losing my 
6 
6th Amendment right to effective representation. 
7 
Accordingly, I assert my federal constitutional rights 
8 
as guaranteed by the 5th, 6th and 14th Amendment to the 
9 
US Constitution. 
10 
Q. 
Sir, do you like having things inserted in 
11 
your anus for sexual gratification? 
12 
MR. PIKE: Objection, argumentative, 
13 
harassing. 
14 
THE WITNESS: I fully intend to respond to all 
15 
relevant questions regarding this lawsuit; however, 
16 
at the present time, my attorneys have counseled me 
17 
I cannot provide answers to any questions relevant 
18 
to this lawsuit. I must accept this advice or risk 
19 
losing my 6th Amendment right to effective 
20 
representation. 
21 
BY MR. KUVIN: 
22 
Q. 
Do you live at 35 --
23 
MR. GOLDBERGER: Hold on. 
24 
THE WITNESS: Excuse me, let me finish. Is 
25 
that fair. 
0031 
1 
BY MR. KUVIN: 
2 
Q. 
Absolutely. I certainly want you to finish. 
3 
A. 
Accordingly, I assert my federal 
4 
constitutional rights as guaranteed by the 5th, 6th and 
5 
14th Amendment to the US Constitution. 
6 
Q. 
Sir, do you live at 358 El Brillo Way, Palm 
7 
Beach, Florida? 
8 
A. 
I fully intend to respond to all relevant 
9 
questions regarding this lawsuit; however, at the 
10 
present time, my attorneys have counseled me I cannot 
11 
provide answers to any questions relevant to this 
12 
lawsuit. I must accept this advice or risk losing my 
13 
6th Amendment right to effective representation. 
14 
Accordingly, I assert my federal constitutional right as 
15 
guaranteed by the 5th, 6th and 14th Amendment to the US 
16 
Constitution. 
17 
Q. 
I noticed that Mr. Goldberger shook his head 
18 
when I asked you where you lived. Do you have a problem 
EFTA01158528

19 
letting us know where you live? 
20 
I'm trying to understand why that issue is 
21 
protected by the 5th Amendment, given the fact that 
22 
you're required to live at that address pursuant to the 
23 
sexual offender flyer and pursuant to the Court's order 
24 
convicting you based on your guilty plea. 
25 
MR. PIKE: Form, argumentative. 
0032 
1 
THE WITNESS: Do you want to repeat the 
2 
question? 
3 
BY MR. KUVIN: 
4 
Q. 
Sure. Did the Court require you to stay at 
5 
358 El Brillo Way on Palm Beach --
6 
(Interruption in the proceedings.) 
7 
BY MR. KUVIN: 
Q. 
Sir, did the Court require you to stay at 358 
El Brillo Way, Palm Beach, Florida subsequent to you 
being released from prison? 
MR. PIKE: Form. 
THE WITNESS: 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 any answers to questions relevant 
to this lawsuit. I must accept this advice or risk 
losing my 6th Amendment right to effective 
representation. Accordingly, I assert my federal 
constitutional rights as guaranteed by the 5th, 
6th and 14th Amendment to the US Constitution. 
MR. KUVIN: 
Q. 
Let's go ahead and mark as Exhibit 3 a nice 
photo of your home. 
(Plaintiff's Exhibit No. 3 was marked for 
identification.) 
8 
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18 
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20 
21 
BY 
22 
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25 
0033 
1 
BY MR. KUVIN: 
2 
Q. 
Okay. Let's get this for the camera, if I 
3 
could. Okay. 
4 
All right. I'm going to show you what I've 
5 
marked as Exhibit 3. Is that a photograph of your home, 
6 
sir, at 358 El Brillo Way? 
7 
A. 
I fully intend to respond to all relevant 
8 
questions regarding this lawsuit; however, at the 
9 
present time, my attorneys have counseled me I cannot 
10 
provide answers to any questions relevant to this 
11 
lawsuit. I must accept this advice or risk losing my 
12 
6th Amendment right to effective representation. 
13 
Accordingly, I assert my federal constitutional rights 
14 
as guaranteed by the 5th, 6th and 14th Amendment to the 
15 
US Constitution. 
16 
Q. 
I had asked you before whether or not you 
17 
liked things inserted in your anus for sexual 
18 
gratification, and I'd like to go back to that for a 
19 
moment, if I could. 
20 
Have you read the police report, incident 
21 
report, on your arrest? 
22 
MR. PIKE: Form, argumentative, harassing. 
23 
MR. GOLDBERGER: Attorney-client work product. 
24 
BY MR. KUVIN: 
25 
Q. 
Sir, according to the report, there was a 
0034 
1 
purple item retrieved from your trash at 358 El Brillo 
2 
Way that appeared to be a device known as a jelly anal 
3 
wand. Have you ever heard of something like that? 
EFTA01158529

4 
MR. PIKE: Form, argumentative, harassing. 
5 
Same objections, attorney-client work product. 
6 
THE WITNESS: I fully intend to respond to all 
7 
relevant questions regarding this lawsuit; however, 
8 
at the present time, my attorneys have counseled me 
9 
I cannot provide answers to any questions relevant 
10 
to this lawsuit. I must accept this advice or risk 
11 
losing my 6th Amendment right to effective 
12 
representation. Accordingly, I assert my federal 
13 
constitutional rights as guaranteed by the 5th, 6th 
14 
and 14th Amendment to the US Constitution. 
15 
BY MR. KUVIN: 
16 
Q. 
Outside of your home at 358 El Brillo Way was 
17 
also recovered a 3-inch purple-sized finger -- I'm 
18 
sorry, a 3-inch purple finger-sized object which had a 
19 
broken end, which is apparently a sexual toy similar --
20 
similar to a cyclone vibrator possibly used for rectal 
21 
gratification. 
22 
Do you know what a cyclone vibrator is? 
23 
A. 
No. 
24 
MR. PIKE: Form, harassing. 
25 
THE WITNESS: No, but I do know that that 
0035 
1 
MR. PIKE: Same objections. 
2 
THE WITNESS: -- broken purple object turned 
3 
out to be, later on, described as a salad fork from 
4 
the kitchen, strictly something that had been 
5 
broken in the dishwasher and then reported it in a 
6 
report obviously inaccurately. 
7 
BY MR. KUVIN: 
8 
Q. 
Okay. So the broken --
9 
A. 
Salad fork, nothing more than a broken salad 
10 
fork, correct. 
11 
Q. 
So the 3-inch purple finger-sized object was a 
12 
salad fork? 
13 
A. 
Was a broken handle of a salad fork. Yes, the 
14 
question has been asked and answered, I believe. 
15 
Q. 
Okay. When did you see that? 
16 
MR. PIKE: Form. 
17 
THE WITNESS: See what? 
18 
BY MR. KUVIN: 
19 
Q. 
Well, you called --
20 
A. 
See that. What's the that? 
21 
Q. 
You called it a salad fork. 
22 
When did you see the salad fork after the 
23 
police had taken it into custody? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: I did not see the salad fork, 
0036 
1 
nor did I represent that I did see the salad fork. 
2 
BY MR. KUVIN: 
3 
Q. 
Okay. So you have no idea what it was that 
4 
the police took out of the trash? 
5 
A. 
The police --
6 
MR. PIKE: Form. 
7 
THE WITNESS: -- filed a later report saying 
8 
it was a salad fork, I believe. 
9 
BY MR. KUVIN: 
10 
Q. 
You never saw that piece, did you? 
11 
A. 
No. 
12 
Q. 
You have no idea what it was that they took 
13 
out of there? 
14 
MR. PIKE: Form. 
EFTA01158530

15 
THE WITNESS: I just said the police said it 
16 
was a salad fork, a mere salad fork misrepresented 
17 
in that police report, as many things have been, it 
18 
seems. 
19 
BY MR. KUVIN: 
20 
Q. 
Did they misrepresent the jelly anal wand? 
21 
A. 
I've --
22 
MR. PIKE: Form. 
23 
THE WITNESS: -- never heard of that before. 
24 
BY MR. KUVIN: 
25 
Q. 
Have you used vibrators that you've placed in 
0037 
1 
your anus? 
2 
MR. PIKE: Form, objection, harassing. 
3 
THE WITNESS: No. 
4 
BY MR. KUVIN: 
5 
Q. 
You never placed anything like a vibrator in 
6 
your anus? 
7 
MR. PIKE: Same objections. 
8 
THE WITNESS: No. 
9 
BY MR. KUVIN: 
10 
Q. 
There was in a dresser of an armoire of your 
11 
home 
12 
MR. KUVIN: This is page 44, Counsel. I'd 
13 
like to reference it. 
14 
THE WITNESS: Is that marked as an exhibit? I 
15 
don't know what he's reading. 
16 
MR. PIKE: It's not marked as an exhibit. 
17 
THE WITNESS: The police report? 
18 
BY MR. KUVIN: 
19 
Q. 
No, it's not. It's my work product, much like 
20 
how Mr. Goldberger felt that your 5th Amendment was your 
21 
work product. 
22 
MR. KUVIN: So let's mark this as exhibit 
23 
what are we up to, 4? 
24 
COURT REPORTER: 4. 
25 
0038 
1 
(Plaintiff's Exhibit No. 4 was marked for 
2 
identification.) 
3 
MR. KUVIN: Okay. All right. If we could, 
4 
just get a shot of that for me. 
5 
Okay, thank you. 
6 
BY MR. KUVIN: 
7 
Q. 
According to the incident report, in a room of 
8 
your home --
9 
MR. PIKE: What page are you on, Counsel? 
10 
MR. KUVIN: Page 44. 
11 
MR. PIKE: What paragraph? 
12 
MR. KUVIN: Line 4. 
13 
BY MR. KUVIN: 
14 
Q. 
-- in a dresser armoire was located a bottle 
15 
of peach-flavored Joy Jelly, parenthetically a sexual 
16 
lubricant. 
17 
I have here something called Joy Jelly. I 
18 
even have peach. Do you know what that is? 
19 
MR. PIKE: Form objection, harassing. 
20 
MR. GOLDBERGER: Can you just clarify the 
21 
question as to where you got that? Did that come 
22 
from your home or from somewhere else, Mr. Kuvin? 
23 
MR. KUVIN: I don't think that's relevant. 
24 
MR. GOLDBERGER: Just curious as to what 
25 
you're -- you've made a big point to identify this, 
EFTA01158531

0039 
1 
this exhibit, and show it to the camera. So if my 
2 
client is going to answer the question, I'd like to 
3 
know whether it came from your home or from --
4 
whether you bought it or where it came from just so 
5 
he can -- just so he can accurately answer the 
6 
question should he choose to want to answer it. 
7 
MR. KUVIN: Well, he can make the choice 
8 
whether he wants to answer it or not. 
9 
MR. GOLDBERGER: All right. 
10 
BY MR. KUVIN: 
11 
Q. 
Do you know what that is? 
12 
MR. PIKE: Form objection, improper 
13 
hypothetical. 
14 
THE WITNESS: I don't understand the question. 
15 
BY MR. KUVIN: 
16 
Q. 
Do you know what Exhibit 4 is? 
17 
A. 
You've just described it. I have no knowledge 
18 
but what you've just described. 
19 
Q. 
You don't know what that's used for? 
20 
MR. PIKE: Form objection, harassing. 
21 
THE WITNESS: I've heard what you said it's 
22 
used for. I've never seen it before. 
23 
BY MR. KUVIN: 
24 
Q. 
Do you know what that, right there, Exhibit 4, 
25 
this peach-flavored --
0040 
1 
A. 
You've asked me that question already. 
2 
Q. 
-- Joy Jelly, do you know what it's used for? 
3 
MR. PIKE: Asked and answered. 
4 
BY MR. KUVIN: 
5 
Q. 
Not this bottle, but Joy Jelly, do you know 
6 
what it's used for? 
7 
MR. PIKE: Same objection, harassing, asked 
8 
and answered. 
9 
BY MR. KUVIN: 
10 
Q. 
You can answer. 
11 
A. 
I've already told you. 
12 
Q. 
You still haven't answered the question. 
13 
MR. PIKE: Counsel, he answered the question. 
14 
It's been asked and answered twice. 
15 
MR. GOLDBERGER: Let's get a read-back on 
16 
this. 
17 
MR. KUVIN: Sure. I'd like to hear the 
18 
answer. 
19 
MR. GOLDBERGER: From the start of the line of 
20 
questioning. 
21 
COURT REPORTER: From the first time it was 
22 
asked? 
23 
MR. GOLDBERGER: Yes, please. 
24 
(A portion of the record was read by the 
25 
reporter.) 
0041 
1 
MR. GOLDBERGER: That's all I need to hear, 
2 
thanks. 
3 
BY MR. KUVIN: 
4 
Q. 
Do you know what Joy Jelly is used for? 
5 
A. 
I've heard what you've just described. I have 
6 
no independent knowledge. 
7 
Q. 
You've never used Joy Jelly? 
8 
A. 
I fully intend to respond to all relevant 
9 
questions regarding this lawsuit; however, at the 
10 
present time, my attorneys have counseled me I cannot 
EFTA01158532

11 
provide an answer to any questions relevant to this 
12 
lawsuit. I must accept this advice or risk losing my 
13 
6th Amendment right to effective representation. 
14 
Accordingly, I assert my federal constitutional rights 
15 
as guaranteed by the 5th, 6th and 14th Amendment to the 
16 
US Constitution. 
17 
Q. 
You agree with me that Joy Jelly is a sexual 
18 
lubricant that's used on sexual devices like vibrators 
19 
and anal jelly wands? 
20 
MR. PIKE: Same objections. 
21 
THE WITNESS: I have no knowledge of that. 
22 
BY MR. KUVIN: 
23 
Q. 
Do you agree that Joy Jelly is a sexual 
24 
lubricant? 
25 
A. 
I have no knowledge of that. 
0042 
1 
MR. PIKE: Form, lack of predicate. 
2 
BY MR. KUVIN: 
3 
Q. 
Have you used it? 
4 
MR. PIKE: Same objection, lack of predicate, 
5 
no foundation, harassing. 
6 
THE WITNESS: I fully intend to respond to all 
7 
relevant questions regarding this lawsuit; however, 
8 
at this time, I cannot provide any questions [sic] 
9 
relevant to the lawsuit. I must accept counsels' 
10 
advice or risk losing my 6th Amendment right to 
11 
effective representation. Accordingly, I assert my 
12 
federal constitutional rights as guaranteed by the 
13 
5th, 6th and 14th Amendment to the US Constitution. 
14 
BY MR. KUVIN: 
15 
Q. 
Would you agree with the description that you 
16 
are a pervert? 
17 
MR. PIKE: Same objection, harassing, 
18 
argumentative. 
19 
BY MR. KUVIN: 
20 
Q. 
You can answer. It's either a simple yes or 
21 
no. 
22 
A. 
I fully intend to respond to all relevant 
23 
questions regarding this lawsuit; however, at the 
24 
present time, my attorneys have counseled me that I 
25 
cannot provide answers to any questions relevant to this 
0043 
1 
lawsuit. I must accept this advice or risk losing my 
2 
6th Amendment right to effective representation. 
3 
Accordingly, I must assert my federal constitutional 
4 
rights as guaranteed by the 5th, 6th and 14th Amendment 
5 
of the US Constitution. 
6 
Q. 
Have any mental health counselors diagnosed 
7 
you as a sexual deviant? 
8 
MR. PIKE: Again, form --
9 
THE WITNESS: I don't believe so. 
10 
MR. PIKE: -- work product. 
11 
BY MR. KUVIN: 
12 
Q. 
Do you believe you're a sexual deviant? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: No, I do not. 
15 
BY MR. KUVIN: 
16 
Q. 
Do you have sex with minors? 
17 
MR. PIKE: Same objection, form, 5th 
18 
Amendment. 
19 
THE WITNESS: I fully intend to respond to all 
20 
relevant questions regarding this lawsuit; however, 
21 
at the present time, my attorneys have counseled me 
EFTA01158533

22 
23 
24 
25 
0044 
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 
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 
25 
0046 
1 
2 
3 
4 
5 
6 
I cannot provide answers to any questions relevant 
to this lawsuit. I must accept this advice or risk 
losing my 6th Amendment right to effective 
representation. Accordingly, I assert my federal 
constitutional rights as guaranteed by the 5th, 6th 
and 14th Amendment to the US Constitution. 
BY MR. KUVIN: 
Q. 
Would you agree that you have a psychological 
disorder with respect to your sexual preferences? 
MR. PIKE: Same objection. 
THE WITNESS: 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 relevant 
to this lawsuit. I must accept this advice or risk 
losing my 6th Amendment right to effective 
representation. Accordingly, I assert my federal 
constitutional rights as guaranteed by the 5th, 
6th and 14th Amendment to the US Constitution. 
BY MR. KUVIN: 
Q. 
Have you had sex with transsexuals? 
MR. PIKE: Same objection. 
THE WITNESS: No. 
BY MR. KUVIN: 
Q. 
Do you know a Ms. Cordero? 
A. 
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 relevant to this 
lawsuit. I must accept this advice or risk losing my 
6th Amendment right to effective representation. 
Accordingly, I assert my federal constitutional rights 
as guaranteed by the 5th, 6th and 14th Amendments to the 
US Constitution. 
Q. 
Do you know a Ms. 
MR. PIKE: Same objection. 
THE WITNESS: 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 relevant 
to this lawsuit. I must accept this advice or risk 
losing my 6th Amendment right to effective 
representation. Accordingly, I assert my federal 
constitutional rights as guaranteed by the 5th, 
6th and 14th Amendment to the US Constitution. 
BY MR. KUVIN: 
Q. 
When do you intend to fully respond? 
MR. PIKE: Same objection. In addition, work 
product, attorney-client. 
BY MR. KUVIN: 
Q. 
I'm sorry, I misquoted you. You said I --
you've repeated now numerous times, "I fully intend to 
respond," so let me rephrase my question. 
When do you fully intend to respond? 
MR. PIKE: 
work product. 
MR. KUVIN: 
MR. PIKE: 
I'm instructing 
BY MR. KUVIN: 
Same objection, attorney-client, 
Are you telling him not to answer? 
It's attorney-client, work product. 
him not to answer. 
EFTA01158534

7 
Q. 
Okay. So despite the fact that you're reading 
8 
this canned statement over and over to my questions, you 
9 
don't want to answer any questions about the written 
10 
statement; isn't that true? 
11 
MR. PIKE: Same objection, attorney-client, 
12 
work product. I'm instructing the witness not to 
13 
answer. 
14 
BY MR. KUVIN: 
15 
Q. 
You don't ever fully intend to respond to 
16 
anything, do you? 
17 
MR. PIKE: Same objection. 
18 
BY MR. KUVIN: 
19 
Q. 
Or would you like to? 
20 
MR. PIKE: Same objection. Now we're getting 
21 
borderline harassing and argumentative. 
22 
I think you should move on to -- certainly you 
23 
didn't come here to be argumentative and harassing 
24 
all day, Mr. Kuvin, so I would hope that you would 
25 
move on to another topic. 
0047 
1 
THE WITNESS: Jack? 
2 
MR. KUVIN: I'm just looking. 
3 
MR. GOLDBERGER: He can look at it all he 
4 
wants. 
5 
Just ask for permission next time, if you want 
6 
to, because it is something that I gave to my 
7 
client. So when you want to look -- I've let you 
8 
mark it. If you want to look at it, just ask my 
9 
permission to do so, okay? 
10 
MR. KUVIN: Sure. 
11 
MR. GOLDBERGER: Is that all right with you? 
12 
MR. KUVIN: Perfectly fine. 
13 
MR. GOLDBERGER: Thanks. 
14 
BY MR. KUVIN: 
15 
Q. 
Your typed paper there says that you cannot 
16 
provide answers. Why not? 
17 
MR. PIKE: Attorney-client, work product. I'm 
18 
instructing him not to answer. It's my work 
19 
product. 
20 
MR. KUVIN: Are you stipulating that you 
21 
drafted the document we've marked as Exhibit 2? 
22 
MR. GOLDBERGER: No such stipulation. 
23 
MR. PIKE: No such stipulation. 
24 
MR. KUVIN: Well, if it's work product --
25 
MR. PIKE: It's attorney-client, work product. 
0048 
1 
MR. KUVIN: -- I just wanted to clarify. 
2 
BY MR. KUVIN: 
3 
Q. 
Did 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
BY 
16 
17 
you have a sexual relationship with 
when she still had a penis? 
MR. PIKE: Same objection. 5th Amendment. 
THE WITNESS: 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 relevant 
to this lawsuit. I must -- I must accept this 
advice or risk losing my 6th Amendment right to 
effective representation. Accordingly, I assert my 
federal constitutional rights as guaranteed by the 
5th, 6th and 14th Amendment to the US Constitution. 
MR. KUVIN: 
Q. 
Do you know 
A. 
I fully intend to respond to all relevant 
EFTA01158535

18 
questions regarding this lawsuit; however, at the 
19 
present time, my attorneys have counseled me I cannot 
20 
provide answers to any questions relevant to this 
21 
lawsuit. I must accept this advice or risk losing my 
22 
6th Amendment right to effective representation. 
23 
Accordingly, I assert my federal constitutional rights 
24 
as guaranteed by the 5th, 6th and 14th Amendment to the 
25 
US Constitution. 
0049 
1 
Q. 
You agree, do you not, that 
is, 
2 
or as least was, your personal assistant for many years? 
3 
MR. PIKE: Same objection. 
4 
THE WITNESS: I fully intend to respond to all 
5 
relevant questions regarding this lawsuit; however, 
6 
at the present time, my attorneys have counseled me 
7 
I cannot provide answers to any questions relevant 
8 
to this lawsuit. I must accept this advice or risk 
9 
losing --
10 
MR. GOLDBERGER: Why don't you -- why don't 
11 
you wait until he's listening, so he... 
12 
MR. KUVIN: Oh, I don't need to listen. I've 
13 
heard it many times. 
14 
MR. GOLDBERGER: No, we're going to wait. 
15 
We're going to wait. 
16 
MR. KUVIN: Oh, no, you don't have to wait. 
17 
MR. GOLDBERGER: Oh, no, we will. 
18 
BY MR. KUVIN: 
19 
Q. 
Okay. I'm sorry, are you done? 
20 
A. 
No. 
21 
Q. 
Oh, please finish. 
22 
A. 
I must accept this advice or risk losing my 
23 
6th Amendment right to effective representation. 
24 
Accordingly, I assert my federal constitutional rights 
25 
as guaranteed by the 5th... 
0050 
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 
0051 
1 
guaranteed by the 5th, 6th and 14th Amendment to the US 
2 
Constitution. 
Q. 
Okay. Go ahead. Don't wait for me. 
A. 
-- 5th, 6th and 14th Amendment to the US 
Constitution. 
Q. 
Okay. You agree, would you not, that 
is currently dating Story Kowles, the 
gentleman who is sitting here in the room working for 
Mr. Goldberger at your deposition? 
A. 
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 relevant to this 
lawsuit. I must accept their advice or risk losing my 
6th Amendment right to effective representation. 
Accordingly, I assert my federal constitutional rights 
as guaranteed by the 5th, 6th and 14th Amendment to the 
US Constitution. 
Q. 
Do you know how long 
has been 
dating Mr. Story Kowles? 
A. 
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 relevant to this 
lawsuit. I must accept this advice or risk losing my 
6th Amendment right to effective representation. 
Accordingly, I assert my federal constitutional right as 
EFTA01158536

3 
Q. 
Did you introduce 
to Story Kowles? 
4 
A. 
I fully intend to respond to all relevant 
5 
questions regarding this lawsuit; however, at the 
6 
present time, my attorneys have counseled me I cannot 
7 
provide answers to any questions relevant to this 
8 
lawsuit. I must accept this advice or risk losing my 
9 
6th Amendment right to effective representation. 
10 
Accordingly, I assert my federal constitutional rights 
11 
as guaranteed by the 5th, 6th and 14th Amendment to the 
12 
US Constitution. 
13 
Q. 
Are you aware that one of the State 
14 
prosecutors, Dahlia Weiss, who was working on your 
15 
criminal case, was also married to a lawyer working for 
16 
Mr. Goldberger here? 
17 
MR. GOLDBERGER: Attorney-client, work 
18 
product. 
19 
Don't answer. 
20 
MR. KUVIN: I'm sorry, work product? 
21 
Somebody's marriage? 
22 
MR. GOLDBERGER: Uh-huh. Don't answer it. 
23 
MR. KUVIN: I'd like an explanation as to how 
24 
someone's marriage is work product on the record so 
25 
I can be clear to determine whether I need to bring 
0052 
1 
that question up in front of Judge Hafele. 
2 
MR. PIKE: The rules do not require for 
3 
speaking objections, and we're going to limit 
4 
ourself to form and the appropriate objections 
5 
thereafter, which have been asserted. So there 
6 
does not need to be anything in the record. Should 
7 
you wish to file a motion, you can do so. 
8 
MR. KUVIN: Well, before I file such motion, I 
9 
think the rules also dictate that I can request an 
10 
explanation, which I'm doing. 
11 
MR. PIKE: We've already objected. 
12 
MR. KUVIN: Okay. 
13 
BY MR. KUVIN: 
14 
Q. 
Do you know Dahlia Weiss? 
15 
A. 
I fully intend to respond to all relevant 
16 
questions regarding this lawsuit; however, at the 
17 
present time, my attorneys have counseled me I cannot 
18 
provide answers to any questions relevant to this 
19 
lawsuit. I must accept this advice or risk losing my 
20 
6th Amendment right to effective representation. 
21 
MR. GOLDBERGER: Actually, I'll let you answer 
22 
the question as asked, as to do you know Dahlia 
23 
Weiss. 
24 
THE WITNESS: No, I do not. 
25 
0053 
1 
BY MR. KUVIN: 
2 
Q. 
With respect to Mr. Goldberger, your criminal 
3 
attorney, did you buy him a brand new BMW? 
4 
MR. GOLDBERGER: Don't. 
5 
THE WITNESS: I fully intend to respond to all 
6 
relevant questions regarding this lawsuit; however, 
7 
at the present time, my attorneys have counseled me 
8 
I cannot provide answers to any questions relevant 
9 
to this lawsuit. I must accept this advice or risk 
10 
losing my 6th Amendment right to effective 
11 
representation. 
12 
MR. GOLDBERGER: It's also attorney-client and 
13 
work product as to my fees. 
EFTA01158537

14 
15 
16 
17 
18 
19 
BY 
20 
21 
22 
23 
BY 
24 
25 
0054 
1 
reasonably calculated to lead to admissible 
2 
evidence in this case. 
3 
THE WITNESS: No. 
4 
BY MR. KUVIN: 
5 
Q. 
It's a shame. 
6 
MR. GOLDBERGER: What was that? 
7 
THE WITNESS: Shame, he said. 
8 
BY MR. KUVIN: 
9 
Q. 
Why not? 
10 
MR. PIKE: Objection, relevance. I'm going to 
11 
instruct him not to answer the question. It's 
12 
argumentative. 
13 
BY MR. KUVIN: 
14 
Q. 
Is there anyone else that you know that is 
15 
dating staff at Mr. Goldberger's office other than 
16 
and Ms. Wife -- Ms. Weiss? 
17 
MR. PIKE: Objection, form. 
18 
MR. GOLDBERGER: Whoa, whoa, whoa. First of 
19 
all, let's get the question right. 
and 
20 
Ms. Weiss are dating each other; is that the 
21 
question? 
22 
MR. KUVIN: No, I'll clarify. 
23 
MR. GOLDBERGER: Thank you. 
24 
BY MR. KUVIN: 
25 
Q. 
Is there anyone else that you know that's 
0055 
1 
dating staff at Mr. Goldberger's office other than 
2 
, or married to staff working for 
3 
Mr. Goldberger other than Ms. Weiss? 
4 
MR. GOLDBERGER: There are people --
5 
MR. PIKE: Objection, form, multiple, 
6 
compound, vague, irrelevant, not reasonably 
7 
calculated to lead to admissible evidence. 
8 
MR. GOLDBERGER: Do you understand the 
9 
question? The question as asked: Do you know 
10 
anyone who dates anyone at my office? 
11 
THE WITNESS: This is why -- this is why we're 
12 
here? 
13 
MR. GOLDBERGER: I mean, do you know -- the 
14 
question is: Do you know if anyone in my office 
15 
dates anybody? 
16 
THE WITNESS: No, I do not. 
17 
MR. GOLDBERGER: Okay. 
18 
BY MR. KUVIN: 
19 
Q. 
That's a good point. I'm glad you made it. 
20 
No, you know why we're here? We're here to 
21 
ask you whether or not you had any sexual contact with 
22 
III. Did you? 
23 
A. 
Who? 
24 
Q. 
With a young girl that was 14 years old. 
THE WITNESS: Accordingly, I assert my federal 
constitutional rights as guaranteed by the 5th, 6th 
and 14th Amendment to the US Constitution. 
MR. GOLDBERGER: I'm sorry, it's also 
attorney-client work product as to my fees. 
MR. KUVIN: 
Q. 
Have you bought any new cars for your civil 
attorneys, like Mr. Critton? 
MR. PIKE: Objection, relevance. 
MR. KUVIN: 
Q. 
Robert Critton. 
MR. PIKE: Argumentative, harassing, not 
EFTA01158538

25 
0056 
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 
0057 
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 
0058 
1 
2 
3 
4 
5 
6 
7 
a 
9 
A. 
What was her name? 
Q. 
ION. 
A. 
Can you refresh my recollection who she -- do 
you have anything to show me, something that might --
Q. 
I do, and I will pursuant to the 
confidentiality that we've previously discussed in this 
case. 
A. 
Q. 
A. 
So tell me who it is that you're representing? 
I will do that. 
Have you had sex with numerous girls underage? 
You've asked me if this -- which question --
MR. GOLDBERGER: Wait, the question was --
MR. KUVIN: I'll strike the question and 
rephrase. 
MR. GOLDBERGER: Which question are you 
striking? 
MR. KUVIN: I will strike all of them and 
rephrase. 
BY MR. KUVIN: 
Q. 
Did you have sex with underaged --
MR. GOLDBERGER: Sorry, wait a minute. Wait a 
minute. Let me just clarify. The question that 
you're striking is, did you have sex with a woman 
by the name of ill.? 
MR. KUVIN: Right. 
MR. GOLDBERGER: That's question one? 
And the second question you're striking is? 
MR. KUVIN: I'm moving on. 
BY MR. KUVIN: 
Q. 
Do you have sex with underaged girls? 
A. 
I fully intend to respond to all relevant 
questions regarding this lawsuit --
MR. GOLDBERGER: Let -- do me a favor. After 
you ask the question, he's going to answer it. 
Keep your mouth shut and let him answer the 
question, and don't editorialize while the question 
is being answered. If you want to editorialize 
afterwards in the form of another question, go 
ahead, but while he's answering the question, do 
not say anything. Are we -- are we clear on that? 
MR. KUVIN: I'm sorry, I just want to be 
clear, did you just tell me to keep my mouth shut? 
MR. GOLDBERGER: While my client is answering 
a question. 
MR. KUVIN: So you're telling me I need to 
keep my mouth shut? 
MR. GOLDBERGER: No, no. I'm telling 
you to --
MR. KUVIN: Is that -- I'm sorry, I thought 
that's what I heard. 
MR. GOLDBERGER: Spencer, I'm not 
MR 
MR 
into an 
MR 
me if I 
MR 
what 
. KUVIN: I just wanted to make 
. GOLDBERGER: Spencer, I'm not 
argument with you. I want you 
. KUVIN: I don't want to argue. 
was clear --
. GOLDBERGER: Let me -- let me 
sure. 
going to get 
to act --
You asked 
finish 
MR. KUVIN: -- and I just wanted to be clear. 
MR. GOLDBERGER: Are you -- are you going to 
EFTA01158539

10 
let me finish what I'm saying? 
11 
MR. KUVIN: I just wanted to know if I was 
12 
clear. You're trying to tell me to keep my mouth 
13 
shut. 
14 
MR. GOLDBERGER: All right. 
15 
MR. KUVIN: So I wanted to make sure that the 
16 
record was patently clear what you're asking me to 
17 
do. 
18 
MR. GOLDBERGER: Are you done? 
19 
MR. KUVIN: I'm done. 
20 
MR. GOLDBERGER: Okay. So the response to 
21 
your question is, I want you to allow my client 
22 
let me finish -- allow my client to finish his 
23 
answers. If you want to interrupt while he's 
24 
asking -- while he's answering a question, I'm not 
25 
going to allow you to do that. If you want to 
0059 
1 
respond to a question that he answers by being 
2 
argumentative, you can do so, and the appropriate 
3 
objection will be entered. 
4 
My only point of my response to you was that I 
5 
do not want you interfering while he is answering a 
6 
question, that's it, okay? I just want you to act 
7 
ethically, honorably and fair. 
8 
MR. KUVIN: I would ask you to do the same 
9 
MR. GOLDBERGER: I'm trying. 
10 
MR. KUVIN: -- and to stop your speaking 
11 
objections. 
12 
MR. GOLDBERGER: I'm trying. 
13 
MR. KUVIN: Objection to form usually works, 
14 
according to our local rules. 
15 
MR. GOLDBERGER: Okay. 
16 
MR. KUVIN: Okay? Thank you. 
17 
Maybe when you get into the civil arena, you'd 
18 
understand. 
19 
MR. PIKE: Let's move on. 
20 
MR. KUVIN: But I just want to make sure that 
21 
you're on the same page. 
22 
MR. GOLDBERGER: Spencer 
23 
MR. PIKE: Let's move on. 
24 
MR. KUVIN: I appreciate it. 
25 
MR. GOLDBERGER: Let's move on. 
0060 
1 
BY MR. KUVIN: 
2 
Q. 
Do you have sex with underaged girls, that's 
3 
the reason we're here, is it not, Mr. Epstein, to answer 
4 
that question? 
5 
MR. PIKE: Form. 
6 
BY MR. KUVIN: 
7 
Q. 
Do you want to answer that question for us 
8 
today? 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
MR. PIKE: Multiple, compound. 
THE WITNESS: What's the question? 
BY MR. KUVIN: 
Q. 
Do you have sex with underaged girls? 
A. 
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 relevant to this 
lawsuit. I must accept this advice or risk losing my 
6th Amendment right to effective representation. 
Accordingly, I assert my federal constitutional rights 
as guaranteed by the 5th, 6th and 14th Amendments to the 
EFTA01158540

21 
US Constitution. 
22 
Q. 
Isn't it true that you like to have sex with 
23 
little girls? 
24 
MR. PIKE: Same objection. 
25 
0061 
1 
BY MR. KUVIN: 
2 
Q. 
Girls under the age of 18? 
3 
MR. PIKE: Argumentative, harassing. 
4 
THE WITNESS: One question or two? 
5 
BY MR. KUVIN: 
6 
Q. 
Isn't it true that you like to have sex with 
7 
little girls who are under the age of 18? 
8 
MR. PIKE: Argumentative, harassing. 
9 
THE WITNESS: I fully intend to respond to all 
10 
relevant questions regarding this lawsuit; however, 
11 
at the present time, my attorneys have counseled me 
12 
I cannot provide answers to any questions relevant 
13 
to this lawsuit. I must accept this advice or risk 
14 
losing my 6th Amendment right to effective 
15 
representation. Accordingly, I assert my federal 
16 
constitutional rights as guaranteed by the 5th, 6th 
17 
and 14th Amendment to the US Constitution. 
18 
BY MR. KUVIN: 
19 
Q. 
Isn't it true that you've asked little girls 
20 
under the age of 18 to see their vaginas? 
21 
MR. PIKE: Same objection, argumentative, 
22 
harassing. 
23 
THE WITNESS: I fully intend to respond to all 
24 
relevant questions regarding this lawsuit; however, 
25 
at the present time, my attorneys have counseled me 
0062 
1 
I cannot provide answers to any questions relevant 
2 
to this lawsuit. I must accept this advice or risk 
3 
losing my 6th Amendment right to effective 
4 
representation. Accordingly, I assert my federal 
5 
constitutional rights as guaranteed by the 5th, 6th 
6 
and 14th Amendment to the US Constitution. 
7 
BY MR. KUVIN: 
8 
Q. 
Isn't true that you've sexually molested girls 
9 
under the age of 18? 
10 
MR. PIKE: Same objection. 
11 
THE WITNESS: I fully intend to respond to all 
12 
relevant questions regarding this lawsuit; however, 
13 
at the present time, my attorneys have counseled me 
14 
I cannot provide answers to any questions relevant 
15 
to this lawsuit. I must accept this advice or risk 
16 
losing my 6th Amendment right to effective 
17 
representation. Accordingly, I assert my federal 
18 
constitutional rights as guaranteed by the 5th, 6th 
19 
and 14th Amendment to the US Constitution. 
20 
BY MR. KUVIN: 
21 
Q. 
Isn't it true that you've asked numerous, 
22 
possibly hundreds, of underaged girls to have sex with 
23 
you? 
24 
MR. PIKE: Same objection, argumentative, 
25 
harassing. 
0063 
1 
THE WITNESS: I fully intend to respond to all 
2 
relevant questions regarding this lawsuit; however, 
3 
at the present time, my attorneys have counseled me 
4 
I cannot provide answers to any questions relevant 
5 
to this lawsuit. I must accept this advice or risk 
EFTA01158541