EFTA01158522

6 
losing my 6th Amendment right to effective 
7 
representation. Accordingly, I assert my federal 
8 
constitutional rights as guaranteed by the 5th, 6th 
9 
and 14th Amendment to the US Constitution. 
10 
BY MR. KUVIN: 
11 
Q. 
Isn't it true that you've told 
to 
12 
avoid service of a witness subpoena in this case because 
13 
she has information that would incriminate you? 
14 
A. 
I fully intend to respond to all relevant 
15 
questions regarding this lawsuit; however, at the 
16 
present time, my attorneys have counseled me I cannot 
17 
provide answers to any questions relevant to this 
18 
lawsuit. I must accept this advice or risk losing my 
19 
6th Amendment right to effective representation. 
20 
MR. PIKE: In addition, the question is 
21 
argumentative; same objection as before. 
22 
BY MR. KUVIN: 
23 
Q. 
Isn't it true that you conspired with 
to obtain girls under the age of 18 to come to 
25 
your home, get naked and give you massages while you 
0064 
1 
masturbated? 
2 
MR. PIKE: Same objections, argumentative, 
3 
harassing. 
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 my 6th Amendment right to effective 
10 
representation. Accordingly, I assert my federal 
11 
constitutional rights as guaranteed by the 5th, 6th 
12 
and 14th Amendment to the US Constitution. 
13 
BY MR. KUVIN: 
14 
Q. 
Are you treating with a mental health 
15 
counselor currently? 
16 
A. 
No. 
17 
MR. PIKE: Work product. 
18 
BY MR. KUVIN: 
19 
Q. 
Did you go to the mental health counselor as 
20 
required by your plea of guilty? 
21 
A. 
I fully intend to respond to all relevant 
22 
questions regarding this lawsuit; however, at the 
23 
present time, my attorneys have counseled me I cannot 
24 
provide answers to any questions relevant to this 
25 
lawsuit. I must accept this advice or risk losing my 
0065 
1 
6th Amendment right to effective representation. 
2 
Accordingly, I assert my federal constitutional rights 
3 
as guaranteed by the 5th, 6th and 14th Amendment to the 
4 
US Constitution. 
5 
May we take a break? 
6 
MR. GOLDBERGER: Sure. 
7 
MR. PIKE: In addition to that, it's a 
8 
psychotherapist/patient privileged information. 
9 
THE VIDEOGRAPHER: We're off the record at 
10 
10:50. 
11 
(A brief recess was taken.) 
12 
THE VIDEOGRAPHER: Back on the record at 
13 
11:00. 
14 
MR. KUVIN: Thank you. 
15 
BY MR. KUVIN: 
16 
Q. 
Isn't it try, sir, that you've had under 
EFTA01158542

17 
girl -- underaged girls, under the age of 17, come to 
18 
your home, get naked and give you massages while you 
19 
masturbated? 
20 
MR. PIKE: Objection, form, argumentative, 
21 
harassing. 
22 
THE WITNESS: I fully intend to respond to all 
23 
relevant questions regarding this lawsuit; however, 
24 
at the present time, my attorneys have counseled me 
25 
I cannot provide answers to any questions relevant 
0066 
1 
2 
3 
4 
5 
6 
BY 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
BY 
23 
24 
25 
0067 
1 
MR. PIKE: Same objections. 
2 
THE WITNESS: I fully intend to respond to all 
3 
relevant questions regarding this lawsuit; however, 
4 
at the present time, my attorneys have counseled me 
5 
I cannot provide answers to any questions relevant 
6 
to this lawsuit. I must accept this advice or risk 
7 
losing my 6th Amendment right to effective 
8 
representation. Accordingly, I assert my federal 
9 
constitutional rights as guaranteed by the 5th, 6th 
10 
and 14th Amendment to the US Constitution. 
11 
May I see -- talk to my counsel for a second 
12 
outside? 
13 
MR. KUVIN: Sure. 
14 
MR. PIKE: Are we off? 
15 
MR. KUVIN: Not yet. 
16 
MR. PIKE: We're off the record. 
17 
MR. KUVIN: We're off that record. We're not 
18 
off that record until everybody leaves. 
19 
MR. PIKE: Stop the video. The video 
off 
20 
the record. 
21 
MR. KUVIN: I can't go off the record if it 
22 
has to do with the lawsuit. 
23 
MR. PIKE: We don't have anyone here. 
24 
THE VIDEOGRAPHER: You know that you both have 
25 
to agree for us to go off the record. 
0068 
1 
MR. PIKE: We don't have anyone here. 
to this lawsuit. I must accept this advice or risk 
losing my 6th Amendment right to effective 
representation. Accordingly, I must assert my 
federal constitutional rights as guaranteed by the 
5th, 6th and 14th Amendment to the US Constitution. 
MR. KUVIN: 
Q. 
Isn't it true, sir, that you've had underaged 
girls under the age of 16 come to your home, get naked 
and give you massages while you masturbated? 
MR. PIKE: For purposes of the record, I'm 
just going to say same objection relating back to 
the same objections. 
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. 
MR. KUVIN: 
Q. 
Isn't it true that you've had underaged girls 
under the age of 15 come to your home, get naked and 
give you massages while you masturbated? 
EFTA01158543

2 
MR. KUVIN: I understand that, but I am not 
3 
going off the record unless it's not pertaining to 
4 
the lawsuit. If it's not pertaining to the lawsuit 
5 
that we're here about today, I'll go off the 
6 
record, but if it pertains to the lawsuit, I cannot 
go off the record. 
MR. PIKE: I don't -- I don't understand. You 
don't have a witness in a chair and you're rolling 
tape. 
MR. KUVIN: Exactly. My tape is going to 
constantly roll with respect to the litigation. 
MR. PIKE: And the point? 
MR. KUVIN: The point is I don't want to miss 
anything, and I want to make sure there's no 
misrepresentations about what goes on with respect 
to the litigation. 
MR. PIKE: Then I'm instructing you to keep 
rolling tape, and for you to keep typing to 
everything that they say out loud in this room. 
MR. KUVIN: Not when everybody leaves. 
We're good now. He wants to go off and I want 
to go off now. 
THE VIDEOGRAPHER: We'll go off the record at 
11:03. 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0069 
1 
Does he, though? 
2 
MR. KUVIN: I don't know. It's a good 
3 
question. 
4 
MS. EZELL: Did you ask me if I'm on? 
5 
MR. KUVIN: Oh, no. 
6 
Hey, how are you? I keep forgetting you're 
7 
there, Katherine. 
8 
MS. EZELL: I'm there. Actually I was on the 
9 
phone, so I just missed what just happened. Are 
10 
you terminating or are you breaking or what? 
11 
MR. KUVIN: No, he wanted to step out of the 
12 
room. 
13 
MS. EZELL: Oh, okay. 
14 
MR. GOLDBERGER: Okay, thank you. 
15 
I had to discuss an issue with my client. I 
16 
appreciate the time. 
17 
MR. KUVIN: Anytime, Jack. 
18 
MR. GOLDBERGER: You know you don't like me 
19 
anymore. 
20 
MR. KUVIN: The secret is I never liked you. 
21 
THE WITNESS: That's no secret. 
22 
MR. KUVIN: There you go. 
23 
MR. PIKE: Move up the record for me so I can 
24 
see 
25 
MR. KUVIN: Are we ready? 
0070 
1 
MR. PIKE: No. 
2 
MR. GOLDBERGER: I'm sorry, you ready? 
3 
MR. PIKE: Okay. 
4 
MR. KUVIN: Are we ready now? 
5 
MR. GOLDBERGER: Yep. 
6 
MR. KUVIN: Rolling? 
7 
THE VIDEOGRAPHER: We're rolling at 11:05. 
8 
BY MR. KUVIN: 
9 
Q. 
Okay. Isn't it true, sir, that you've had 
10 
underaged girls under the age of 14 come to your home, 
11 
get naked and give you massages while you masturbated? 
12 
MR. PIKE: Argumentative, harassing, 
EFTA01158544

13 
irrelevant. Same objections as before. 
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. Accordingly, I assert my federal 
21 
constitutional rights as guaranteed by the 5th, 6th 
22 
and 14th Amendment to the US Constitution. 
23 
BY MR. KUVIN: 
24 
Q. 
Isn't it true, sir, that you've had underaged 
25 
girls under the age of 13 come to your home, get naked 
0071 
1 
and give you massages while you masturbated? 
2 
MR. PIKE: Same objections. In addition, 
3 
asked and answered. 
4 
MR. KUVIN: No, I changed from 14 to 13. 
5 
MR. PIKE: Same objections. 
6 
BY MR. KUVIN: 
7 
Q. 
You can answer. 
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 
MR. GOLDBERGER: Thank you, Michael. 
15 
THE WITNESS: Accordingly, I assert my federal 
16 
constitutional rights as guaranteed by the 5th, 6th 
17 
and 14th Amendment to the US Constitution. 
18 
Thank you. 
19 
BY MR. KUVIN: 
20 
Q. 
Isn't it true, sir, that you've had underage 
21 
girls under the age of 12 come to your home, get naked 
22 
and give you massages while you masturbated? 
23 
MR. PIKE: Same objections. 
24 
BY MR. KUVIN: 
25 
Q. 
I'm sorry, was there something funny about 
0072 
1 
that question? 
2 
A. 
Are we --
3 
MR. PIKE: Same objection, argumentative. 
4 
MR. GOLDBERGER: Don't even respond to that. 
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. Accordingly, I assert my federal 
12 
constitutional rights as guaranteed by the 5th, 6th 
13 
and 14th Amendment to the US Constitution. 
14 
BY MR. KUVIN: 
15 
Q. 
Isn't it true that you've engaged in sexual 
16 
activities with girls under the age of 17, including 
17 
touching their vaginas? 
18 
MR. PIKE: Same objections. 
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 
22 
I cannot provide answers to any questions relevant 
23 
to this lawsuit. I must accept this advice or risk 
EFTA01158545

24 
losing my 6th Amendment right to effective 
25 
representation. Accordingly, I assert my federal 
0073 
1 
constitutional rights as guaranteed by the 5th, 6th 
2 
and 14th Amendment to the US Constitution. 
3 
BY MR. KUVIN: 
4 
Q. 
Isn't it true that you've engaged in sexual 
5 
activities with girls under the age of 17, including 
6 
using vibrators on their vaginas? 
7 
MR. PIKE: Same objections. 
8 
THE WITNESS: I fully intend to respond to all 
9 
relevant questions regarding this lawsuit; however, 
10 
at the present time, my attorneys have counseled me 
11 
I cannot provide answers to any questions relevant 
12 
to this lawsuit. I must accept this advice or risk 
13 
losing my 6th Amendment right to effective 
14 
representation. Accordingly, I assert my federal 
15 
constitutional rights as guaranteed by the 5th, 6th 
16 
and 14th Amendment to the US Constitution. 
17 
BY MR. KUVIN: 
18 
Q. 
Do you agree that you maintain a home in New 
19 
York? 
20 
MR. PIKE: Objection, form. 
21 
THE WITNESS: I fully intend to respond to all 
22 
relevant questions regarding this lawsuit; however, 
23 
at the present time, my attorneys have counseled me 
24 
I cannot provide answers to any questions relevant 
25 
to this lawsuit. I must accept this advice or risk 
0074 
1 
losing my 6th Amendment right to effective 
2 
representation. Accordingly, I assert my federal 
3 
constitutional rights as guaranteed by the 5th, 6th 
4 
and 14th Amendment to the US Constitution. 
5 
BY MR. KUVIN: 
6 
Q. 
Your name is Jeffrey Epstein, correct? 
7 
A. 
Correct. 
8 
Q. 
I just wanted to see if I could get an answer. 
9 
MR. PIKE: I'm going to move to strike 
10 
counsel's last statement; it's not a question. 
11 
BY MR. KUVIN: 
12 
Q. 
Do you agree you maintain a home in New 
13 
Mexico? 
14 
A. 
I fully intend to respond to all relevant 
15 
questions regarding this lawsuit; however, at the 
16 
present time, my attorneys have counseled me I cannot 
17 
provide answers to any questions relevant to this 
18 
lawsuit. I must accept this advice or risk losing my 
19 
6th Amendment right to effective representation. 
20 
Accordingly, I assert my federal constitutional rights 
21 
as guaranteed by the 5th, 6th and 14th Amendment to the 
22 
US Constitution. 
23 
Q. 
Isn't it true that you've engaged in sexual 
24 
activities with girls under the age of 16, including 
25 
touching their vaginas? 
0075 
1 
MR. PIKE: Objection, harassing, 
2 
argumentative. 
3 
THE WITNESS: Didn't you ask the same question 
4 
before? 
5 
BY MR. KUVIN: 
6 
Q. 
No, it was 17 before; now I went to 16. 
7 
MR. PIKE: Same objection. 
8 
THE WITNESS: I fully intend to respond to all 
EFTA01158546

9 
10 
11 
12 
13 
14 
15 
16 
17 
BY 
18 
19 
20 
21 
22 
23 
24 
25 
0076 
1 
MR. PIKE: Same objection, asked and answered. 
2 
BY MR. KUVIN: 
3 
Q. 
You can answer. 
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 must assert my federal constitutional 
11 
rights as guaranteed by the 5th, 6th and 14th Amendment 
12 
to the US Constitution. 
13 
Q. 
Have you requested girls under the age of 16 
14 
to spread their legs in front of you so that you could 
15 
see their vaginas? 
16 
MR. PIKE: Same objection. 
17 
THE WITNESS: I fully intend to respond to all 
18 
relevant questions regarding this lawsuit; however, 
19 
at the present time, my attorneys have counseled me 
20 
I cannot provide answers to any questions relevant 
21 
to this lawsuit. I must accept this advice or risk 
22 
losing my 6th Amendment right to effective 
23 
representation. Accordingly, I assert my federal 
24 
constitutional rights as guaranteed by the 5th, 6th 
25 
and 14th Amendment to the US Constitution. 
0077 
1 
BY MR. KUVIN: 
2 
Q. 
Do you agree that you maintain a home in the 
3 
US Virgin Islands? 
4 
A. 
As I've answered most of your questions today, 
5 
I'll answer this basically the same way, which is, I 
6 
fully intend to respond to all relevant questions 
7 
regarding this lawsuit; however, at the present time, my 
8 
attorneys have counseled me I cannot provide answers to 
9 
any questions relevant to this lawsuit. I must accept 
10 
this advice or risk losing my 6th Amendment right to 
11 
effective representation. Accordingly, I assert my 
12 
federal constitutional rights as guaranteed by the 5th, 
13 
6th and 14th Amendment to the US Constitution. 
14 
Q. 
Do you want to give answers? 
15 
MR. PIKE: Move to strike, argumentative, 
16 
harassing. 
17 
Mr. Kuvin, I have no reticence with regard to 
18 
getting in front of Judge Hafele once again, and 
19 
let me delineate for you what your comments and 
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. 
MR. KUVIN: 
Q. 
Isn't it true that you've engaged in sexual 
activities with girls under the age of 16, including 
using vibrators on their vaginas? 
MR. PIKE: Same objection, asked and answered. 
MR. KUVIN: Nope. The question before, and we 
can read it back, was whether he touched their 
vaginas, and this question is very specific asking 
whether he used vibrators on their vaginas. 
EFTA01158547

20 
some of your conduct here today is and has been: 
21 
Laughing, argumentative comments after your 
22 
questioning, interrupting the witness, snide 
23 
comments, as well as slamming doors in an office 
24 
that is not yours. 
25 
Now, if you continue to disrupt the discovery 
0078 
1 
process, we will once again terminate this 
2 
deposition. I am giving you a fair opportunity to 
3 
continue to use the discovery process in the manner 
4 
in which it is utilized; however, your 
5 
grandstanding, laughing in the background, and 
6 
snide comments and remarks are not appropriate 
7 
during the discovery process; therefore, this is my 
8 
one warning to you, Mr. Kuvin. 
9 
MR. KUVIN: I disagree. 
10 
MR. PIKE: I'm not asking you for an 
11 
agreement. Please proceed. 
12 
MR. KUVIN: I'm just making sure that the 
13 
record is clear. 
14 
And, by the way, you should fix the door, 
15 
Jack, because there's no spring on it, so when 
16 
somebody touches it, it goes very fast. So I 
17 
apologize if it did slam, and that's the only thing 
18 
I do agree with. 
19 
MR. GOLDBERGER: Okay. I appreciate the 
20 
apology. 
21 
As long as we're going to yak here, Spencer, 
22 
you made a comment that I should learn the rules of 
23 
civil procedure and learn how to conduct 
24 
depositions and so forth. I've been practicing 
25 
primarily criminal defense for 33 years, and do you 
0079 
1 
know what, we don't play these games; we get to the 
2 
issues, we ask questions, we don't laugh at 
3 
witnesses when they give answers in depositions. 
4 
We're not sarcastic. We simply ask the questions 
5 
and act professionally, and that's all I'm asking 
6 
you to do in this deposition, but apparently you're 
7 
incapable of doing that. 
8 
So you're creating this environment here, 
9 
you're creating this atmosphere. I'm trying to be 
10 
polite to you, but it's becoming more and more 
11 
difficult. So I'm asking you to just kind of act 
12 
professionally and we'll get along, and we'll get 
13 
through this, that's all. 
14 
MR. KUVIN: I've been acting professionally. 
15 
Frankly, I wasn't the one that told the other 
16 
attorney to shut up. I mean, those were your 
17 
words, not mine. I just wanted to make sure that I 
18 
understood what you were saying to me. 
19 
MR. GOLDBERGER: It was a reaction to your --
20 
MR. KUVIN: Sir --
21 
MR. GOLDBERGER: It was a reaction to your --
22 
MR. KUVIN: -- I would appreciate it if you 
23 
would let me finish. 
24 
MR. GOLDBERGER: It was a reaction to your 
25 
inappropriate comments and conduct. 
0080 
1 
MR. KUVIN: See, the problem is you keep 
2 
interrupting me. 
3 
MR. GOLDBERGER: You're the one that's 
4 
interrupting me, Spencer. 
EFTA01158548

5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0081 
1 
your apology. 
2 
I have -- I have a suggestion, because 
3 
apparently, for whatever reason, everyone's 
4 
grandstanding, we just can't seem -- wait a minute, 
5 
let me just finish. Let me finish. 
6 
MR. KUVIN: I'm not grandstanding. I want to 
7 
get through my questions. 
8 
MR. GOLDBERGER: We can't seem to get along. 
9 
MR. KUVIN: I just want to get through the 
10 
questions. 
11 
MR. GOLDBERGER: Do you want to have the 
12 
mediator sit in for this deposition? Is that what 
13 
you want to do? 
14 
MR. KUVIN: No, I don't think we need it. I'm 
15 
working through my questions. 
16 
MR. GOLDBERGER: Okay, then. Go ahead. 
17 
MR. PIKE: Let's proceed then. 
18 
MR. KUVIN: Okay, great. 
19 
MR. GOLDBERGER: You've been warned. 
20 
MR. KUVIN: I don't know what the warning is 
21 
supposed to mean. Nobody is a judge in this room. 
22 
I don't think I need a warning. 
23 
MR. GOLDBERGER: That's why I'm suggesting 
24 
that --
25 
MR. KUVIN: You've been warned as well, so now 
0082 
1 
we've both been warned. 
2 
MR. PIKE: Mr. Kuvin, you bring up a fabulous 
3 
point, a fabulous point, and I'm surprised --
4 
MR. KUVIN: It's amazing. I'm surprised that 
5 
I brought it up. 
6 
MR. PIKE: The next time you choose to laugh 
7 
at the witness, we'll call Judge Hafele and see 
8 
today what he has to say about that, okay? 
9 
MR. KUVIN: Perfectly fine. 
10 
MR. PIKE: It's a great idea. 
11 
MR. KUVIN: It sounds good to me. 
12 
MR. PIKE: So let's proceed with some relevant 
13 
questions. 
14 
And I would try to give you a hint: Keep in 
15 
mind the allegations in your complaint. 
MR. KUVIN: You want me to be courteous and 
let you speak, and then you continue to interrupt 
me when I want to respond to the nonsensical 
arguments that you're making, because I have been 
perfectly courteous here. I've been asking 
perfectly courteous questions, relevant questions 
to the case, pertinent questions to the issues in 
this case. 
So if you have a problem with the questions, 
then make a legal objection. You and I both know 
that a speaking, lengthy objection is an improper 
one; that objection to form is the only objection 
you should be making. And the only comment I made 
about you practicing in civil was just merely the 
fact that I didn't know whether you understood that 
objection to form covers everything. 
MR. GOLDBERGER: I have an --
MR. KUVIN: It certainly wasn't meant as an 
insult at all, and I'm sorry if you took it that 
way. 
MR. GOLDBERGER: I appreciate it. I accept 
EFTA01158549

16 
MR. KUVIN: Sounds good to me. 
17 
MR. PIKE: Let's move forward. 
18 
BY MR. KUVIN: 
19 
Q. 
Isn't it true, sir, that you've engaged in 
20 
sexual activities with girls under the age of 15, 
21 
including touching their vaginas? 
22 
A. 
I --
23 
MR. PIKE: Argumentative, harassing, same 
24 
objections. Sorry. 
25 
THE WITNESS: I fully intend to respond to all 
0083 
1 
2 
3 
4 
5 
6 
7 
8 
9 
BY 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0084 
1 
BY MR. KUVIN: 
2 
Q. 
Isn't it true that you've engaged in sexual 
3 
activities with girls under the age of 14 including 
4 
touching their vaginas? 
5 
MR. PIKE: Same objections. 
6 
THE WITNESS: As I've answered most of your 
7 
other questions today, I fully intend to respond to 
8 
all relevant questions regarding this lawsuit; 
9 
however, at the present time, my attorneys have 
10 
counseled me I cannot provide answers to any 
11 
questions relevant to this lawsuit. I must accept 
12 
this advice or risk losing my 6th Amendment right 
13 
to effective representation. Accordingly, I assert 
14 
my federal constitutional rights as guaranteed by 
15 
the 5th, 6th and 14th Amendment to the US 
16 
Constitution. 
17 
BY MR. KUVIN: 
18 
Q. 
Isn't it true that you've engaged in sexual 
19 
activities with girls under the age of 14, including 
20 
using vibrators on their vaginas? 
21 
MR. PIKE: Same objections. 
22 
THE WITNESS: I'll respond to this question in 
23 
the same way I've responded to some of your other 
24 
questions, which is, I fully intend to respond to 
25 
all relevant questions regarding this lawsuit; 
0085 
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. 
MR. KUVIN: 
Q. 
Isn't it true that you've engaged in sexual 
activities with girls under the age of 15, including 
using vibrators on their vaginas? 
MR. PIKE: Same objection. 
THE WITNESS: As I've answered your 
questions -- most of your questions today, I'll 
answer it the same way now, which 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 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. 
EFTA01158550

1 
2 
3 
4 
5 
6 
7 
8 
9 
BY 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0086 
1 
BY MR. KUVIN: 
2 
Q. 
What is the youngest girl that you've had sex 
3 
with? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: I'm going to answer that 
6 
question the same way I've answered most of your 
7 
other questions here today, which is, I fully 
8 
intend to respond to all relevant questions 
9 
regarding this lawsuit; however, at the present 
10 
time, my attorneys have counseled me I cannot 
11 
provide answers to any questions that may be 
12 
relevant to this lawsuit. I must accept this 
13 
advice or risk losing my 6th Amendment right to 
14 
effective representation. Accordingly, I assert my 
15 
federal constitutional rights as guaranteed by the 
16 
5th, 6th and 14th Amendment to the US Constitution. 
17 
BY MR. KUVIN: 
18 
Q. 
What is the youngest age of a girl that has 
19 
given you a naked massage? 
20 
MR. PIKE: Form, argumentative, harassing and 
21 
as worded, irrelevant. 
22 
THE WITNESS: I'm going to answer that 
23 
question the same way I've answered most of your 
24 
other questions here today, which is, I fully 
25 
intend to respond to all relevant questions 
0087 
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. 
MR. KUVIN: 
Q. 
Isn't it true that you've engaged in sexual 
activities with girls under the age of 14, which 
includes using vibrators on their vaginas? 
MR. PIKE: Same objections. 
THE WITNESS: I'll answer that question the 
same way I've answered most of your other questions 
here today, Mr. Kuvin, which 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 their advice or risk losing my 6th 
Amend -- 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. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
BY 
10 
11 
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 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. 
What is the youngest age of a girl you have 
masturbated in front of? 
EFTA01158551

12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0088 
1 
BY MR. KUVIN: 
2 
Q. 
What is the youngest age of a girl that you 
3 
have ejaculated in front of? 
4 
MR. PIKE: Same objections as before to this 
5 
same line of questioning incorporated. 
6 
THE WITNESS: What was the question before 
7 
that, sir? 
8 
BY MR. KUVIN: 
9 
Q. 
What is the youngest age -- the one before or 
10 
this one? I'm sorry. 
11 
A. 
The one before, I thought it was the same 
12 
question. 
13 
Q. 
No, the one before was masturbated, and this 
14 
one was ejaculated. I'll rephrase it. 
15 
What is the youngest age of a girl you have 
16 
ejaculated in front of? 
17 
MR. PIKE: Same objection, argumentative, 
18 
harassing. 
19 
THE WITNESS: I'm going to respond to that 
20 
question the same way I've responded to most of 
21 
your other questions here today, which is, I fully 
22 
intend to respond to all relevant questions 
23 
regarding this lawsuit; however, at the present 
24 
time, my attorneys have counseled me I cannot 
25 
provide answers to any questions that may be 
0089 
1 
relevant to this lawsuit. I must accept their 
2 
advice or risk losing my 6th Amendment right to 
3 
effective representation. Accordingly, I assert my 
4 
federal constitutional rights as guaranteed by the 
5 
5th, 6th and 14th Amendment to the US Constitution. 
6 
BY MR. KUVIN: 
7 
Q. 
Do you agree that you have a sexual preference 
8 
for underaged girls; in other words, girls under the age 
9 
of 18? 
10 
MR. PIKE: Same objections, in addition to 
11 
form. 
12 
THE WITNESS: I'm going to answer that 
13 
question the same way I've answered most of your 
14 
other questions here today, Mr. Kuvin, which is, I 
15 
fully intend to respond to all relevant questions 
16 
regarding this lawsuit; however, at the present 
17 
time, my attorneys have counseled me I cannot 
18 
provide answers to any questions that may be 
19 
relevant to this lawsuit. I must accept their 
20 
advice or risk losing my 6th Amendment right to 
21 
effective representation. Accordingly, I assert my 
22 
federal constitutional rights as guaranteed by the 
MR. PIKE: Same objections as before. 
THE WITNESS: I'm going to answer that 
question in the same way I've answered most of your 
other questions here today, Mr. Kuvin, which is, I 
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 right to 
effective representation. Accordingly, I assert my 
federal constitutional rights as guaranteed by the 
5th, 6th and 14th Amendments to the US 
Constitution. 
EFTA01158552

23 
5th, 6th and 14th Amendment to the US Constitution. 
24 
BY MR. KUVIN: 
25 
Q. 
Do you agree that you have a sexual preference 
0090 
1 
for girls under the age of 17? 
2 
MR. PIKE: Same objections. 
3 
THE WITNESS: I'm going to answer that 
4 
question the same way I've answered most of your 
5 
other questions here today, Mr. Kuvin, which is, I 
6 
fully intend to respond to all relevant questions 
7 
regarding this lawsuit; however, at the present 
8 
time, my attorneys have counseled me I cannot 
9 
provide answers to any questions relevant to this 
10 
lawsuit. I must accept their advice or risk losing 
11 
my 6th Amendment right to effective representation. 
12 
BY MR. KUVIN: 
13 
Q. 
Do you agree that you --
14 
A. 
Accordingly --
15 
Q. 
Oh, I apologize. 
16 
A. 
Accordingly, I assert my federal 
17 
constitutional rights as guaranteed by the 5th, 6th and 
18 
14th Amendment to the US Constitution. 
19 
Q. 
I'm sorry, are you done? 
20 
A. 
Yes. 
21 
Q. 
Okay. I apologize for interrupting you. 
22 
Do you agree that you have a sexual preference 
23 
for girls under the age of 16? 
24 
MR. PIKE: Same objections, form. 
25 
THE WITNESS: I'm going to answer that 
0091 
1 
question the same way I've answered most of your 
2 
other questions here today. I fully intend to 
3 
respond to all relevant questions regarding this 
4 
lawsuit; however, at the present time, my attorneys 
5 
have counseled me I cannot provide answers to any 
6 
questions that may be relevant to this lawsuit. I 
7 
must accept their advice or risk losing my 6th 
8 
Amendment right to effective representation. 
9 
Accordingly, I assert my federal constitutional 
10 
rights as guaranteed by the 5th, 6th and 14th 
11 
Amendment of the US Constitution. 
12 
BY MR. KUVIN: 
13 
Q. 
Do you agree that you have a sexual preference 
14 
for girls under the age of 15? 
15 
MR. PIKE: Same objections. 
16 
THE WITNESS: I'm going to answer that 
17 
question the same way I've answered most of your 
18 
other questions here today, Mr. Kuvin, which is, I 
19 
fully intend to respond to all relevant questions 
20 
regarding this lawsuit; however, at the present 
21 
time, my attorneys have counseled me I cannot 
22 
provide answers to any questions relevant to this 
23 
lawsuit. I must accept their advice or risk losing 
24 
my 6th Amendment right to effective representation. 
25 
Accordingly, I assert my federal constitutional 
0092 
1 
rights as guaranteed by the 5th, 6th and 14th 
2 
Amendment to the US Constitution. 
3 
BY MR. KUVIN: 
4 
Q. 
Do you agree that you have a sexual preference 
5 
for girls under the age of 14? 
6 
MR. PIKE: Same objections. 
7 
THE WITNESS: I'm going to answer that 
EFTA01158553

8 
question the same way I've answered most of your 
9 
other questions here today, Mr. Kuvin, which is, I 
10 
fully intend to respond to all relevant questions 
11 
regarding this lawsuit; however, at the present 
12 
time, my attorneys have counseled me I cannot 
13 
provide answers to any questions relevant to this 
14 
lawsuit. I must accept their advice or risk losing 
15 
my 6th Amendment right to effective representation. 
16 
Accordingly, I assert my federal constitutional 
17 
rights as guaranteed by the 5th, 6th and 14th 
18 
Amendment to the US Constitution. 
19 
BY MR. KUVIN: 
20 
Q. 
Do you agree that you have a sexual preference 
21 
for girls under the age of 13? 
22 
MR. PIKE: Same objection. 
23 
THE WITNESS: I'm going to answer that 
24 
question the same way I've answered most of your 
25 
other questions today, which is, I fully intend to 
0093 
1 
respond to all relevant questions regarding this 
2 
lawsuit; however, at the present time, my attorneys 
3 
have counseled me I cannot provide answers to any 
4 
questions that may be relevant to this lawsuit. I 
5 
must accept this advice or risk losing my 6th 
6 
Amendment right to effective representation. 
7 
Accordingly, I assert my federal constitutional 
8 
rights as guaranteed by the 5th, 6th and 14th 
9 
Amendment to the US Constitution. 
10 
BY MR. KUVIN: 
11 
Q. 
Do you agree that you have a sexual preference 
12 
for girls under the age of 12? 
13 
MR. PIKE: Objection, harassing. In addition, 
14 
vague and indefinite, form. 
15 
THE WITNESS: I'm going to answer that 
16 
question the same way I've answered your other 
17 
questions here today, which is, I intend to respond 
18 
to all relevant questions regarding this lawsuit; 
19 
however, at the present time, my attorneys have 
20 
counseled me I cannot provide answers to any 
21 
questions relevant to this lawsuit. I must accept 
22 
this advice or risk losing my 6th Amendment right 
23 
to effective representation. Accordingly, I assert 
24 
my federal constitutional rights as guaranteed by 
25 
the 5th, 6th and 14th Amendment to the US 
0094 
1 
Constitution. 
2 
BY MR. KUVIN: 
3 
Q. 
Do you agree that you've been treating with a 
4 
psychologist for your sexual perversions? 
5 
MR. PIKE: Objection, vague, harassing, also 
6 
psychotherapist/patient privilege; in addition, 
7 
could call for their information resulting from 
8 
non-testifying consulting expert information. 
9 
I'm going to instruct the witness not to 
10 
answer. 
11 
BY MR. KUVIN: 
12 
Q. 
Do you agree that you've been treating with a 
13 
psychiatrist for your sexual perversions? 
14 
MR. PIKE: Same objection. 
15 
BY MR. KUVIN: 
16 
Q. 
Do you agree that according to your State 
17 
Court sentence, you are mandated to obtain mental health 
18 
counseling or therapy? 
EFTA01158554

19 
MR. PIKE: Same objection. 
20 
BY MR. KUVIN: 
21 
Q. 
Who is that therapy with? 
22 
MR. PIKE: Let's take a break for one second. 
23 
We don't have to leave. 
24 
I'm going to maintain the same objections and 
25 
instructions. 
0095 
1 
BY MR. KUVIN: 
2 
Q. 
How often are you going to that mental health 
3 
counselor? 
4 
MR. PIKE: Same objection and instruction. 
5 
BY MR. KUVIN: 
6 
Q. 
What do you discuss with the therapist? 
7 
MR. PIKE: Definitely same objection and 
instruction. 
MR. KUVIN: 
Q. 
Have you violated your probation by not going 
to a mental health counselor or therapist? 
MR. PIKE: Same objection and instruction. 
BY MR. KUVIN: 
Q. 
Do you agree that while in Palm Beach you've 
preyed on girls who are generally troubled, under the 
age of 17 and economically disadvantaged because you can 
control them better? 
MR. PIKE: Objection, harassing, 
argumentative, vague and indefinite. 
THE WITNESS: I'm going to answer that 
question the same way I've answered most of your 
other questions here today, which 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 
8 
9 
BY 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0096 
1 
provide answers to any questions relevant to this 
2 
lawsuit. I must accept this advice or risk losing 
3 
my 6th Amendment right to effective representation. 
4 
Accordingly, I assert my federal constitutional 
5 
rights as guaranteed by the 5th, 6th and 14th 
6 
Amendment to the US Constitution. 
7 
BY MR. KUVIN: 
8 
Q. 
Do you agree that -- let me ask you this: Do 
9 
you see patterns in things? 
10 
MR. PIKE: Form, compound, confusing, vague. 
11 
THE WITNESS: I don't --
12 
BY MR. KUVIN: 
13 
Q. 
Do you understand the question? 
14 
A. 
No, I don't. 
15 
Q. 
Do you see patterns in numbers? 
16 
MR. PIKE: Same objection, lack of predicate, 
17 
foundation. 
18 
What are you talking about? 
19 
THE WITNESS: I don't understand the question. 
20 
BY MR. KUVIN: 
21 
Q. 
Do you recognize patterns in large numbers? 
22 
MR. PIKE: Same --
23 
MR. GOLDBERGER: You just asked the question 
24 
the same way. Just ask it a different way and 
25 
he'll try and answer it for you. 
0097 
1 
MR. KUVIN: I did. I tried to clarify it. 
2 
MR. GOLDBERGER: You made it -- you said large 
3 
numbers versus numbers. 
EFTA01158555

4 
THE WITNESS: I don't understand the question. 
5 
BY MR. KUVIN: 
6 
Q. 
Do you see patterns in any sequences of 
7 
numbers? 
8 
MR. PIKE: Same objection. 
9 
THE WITNESS: Do I see patterns? I don't 
10 
understand the question. 
11 
BY MR. KUVIN: 
12 
Q. 
Well, you developed a software to help make 
13 
money in the stock market, correct? 
14 
MR. PIKE: Objection as to relevance. 
15 
THE WITNESS: No, that's -- no, absolutely 
16 
not. 
17 
BY MR. KUVIN: 
18 
Q. 
It wasn't a software, a computer software, 
19 
that you helped to develop many years ago after leaving 
20 
your teaching job? 
21 
MR. PIKE: Same objection. 
22 
THE WITNESS: I don't know what you're talking 
23 
about. 
24 
BY MR. KUVIN: 
25 
Q. 
Let's go back. You took classes at Cooper 
0098 
1 
Union from 1969 to 1971, correct? 
2 
A. 
Correct. 
3 
Q. 
Okay. You were raised in Coney Island? 
4 
A. 
Correct. 
5 
Q. 
You attended Lafayette High School in 
6 
Brooklyn, New York? 
7 
A. 
Is that a question? 
8 
Q. 
Yes. Did you attend -- I'm sorry, did you 
9 
attend Lafayette High School in Brooklyn, New York? 
10 
A. 
Yes. 
11 
Q. 
And you took classes at -- oh, I asked that, 
12 
I'm sorry. 
13 
You went to Courant Institute of Mathematical 
14 
Sciences where you left without a degree, correct? 
15 
A. 
Correct. 
16 
Q. 
From '73 to '75, you taught calculus and 
17 
physics at The Dalton School? 
18 
A. 
I'm not sure those years are correct. 
19 
Q. 
What years were you at Dalton? 
20 
A. 
I believe it was '74 to '76. 
21 
Q. 
Okay. 
22 
A. 
I'm not certain. 
23 
Q. 
Okay. Now, Dalton School is a high school, 
24 
correct? 
25 
A. 
Correct. 
0099 
1 
Q. 
What were the ages of the children you were 
2 
teaching at that high school? 
3 
A. 
Mostly old -- mostly 17 and 18. 
4 
Q. 
Okay. So you were teaching seniors? 
5 
A. 
Yes. 
6 
Q. 
What were you teaching? 
7 
A. 
You just asked that question, mathematics and 
8 
physics. 
9 
Q. 
You're right, I apologize. 
10 
Were you teaching any girls that were under 
11 
the age of 17 at the time? 
12 
A. 
I don't know. 
13 
Q. 
Did you have any sexual contact with any of 
14 
the girls that you were teaching at Dalton? 
EFTA01158556

15 
A. 
Again? 
16 
Q. 
Did you have any sexual contact with the girls 
17 
that you were teaching at Dalton? 
18 
A. 
While I was a teacher? 
19 
Q. 
Well, let's start with that question, yes. 
20 
A. 
No. 
21 
Q. 
How about after? 
22 
A. 
Not that I remember. 
23 
Q. 
Did you date any girls that were previously 
24 
your student at Dalton? 
25 
A. 
I'm going to answer that question like every 
0100 
1 
other question I've answered today, which is, I intend 
2 
to respond to all relevant questions regarding this 
3 
lawsuit; however, at the present time, my attorneys have 
4 
counseled me I cannot provide answers to any questions 
5 
that may be relevant to this lawsuit. I must accept 
6 
this advice or risk losing my 6th Amendment right to 
7 
effective representation. Accordingly, I assert my 
8 
federal constitutional rights as guaranteed by the 5th, 
9 
6th and 14th Amendment to the US Constitution. 
10 
Q. 
You do not have a college degree, correct? 
11 
A. 
Correct. 
12 
Q. 
Regardless of that, you became a trader at 
13 
Bear Stearns at some point, correct? 
14 
MR. PIKE: Form. 
15 
BY MR. KUVIN: 
16 
Q. 
Let me ask it a different way if you're 
17 
confused. You look confused. 
18 
A. 
Yes. 
19 
Q. 
You became a trader at Bear Stearns without a 
20 
college degree; is that correct? 
21 
A. 
No. 
22 
Q. 
You had --
23 
A. 
I was never a trader. 
24 
Q. 
I'm sorry. What job did you hold at 
25 
Bear Stearns? 
0101 
1 
MR. PIKE: I'd like to take a break and speak 
2 
to my client. 
3 
MR. KUVIN: Okay. 
4 
THE VIDEOGRAPHER: Your mic is still on, 
5 
Mr. Pike. 
6 
MR. PIKE: Thank you. I appreciate that 
7 
reminder. 
8 
MR. GOLDBERGER: Okay. 
9 
MR. PIKE: Go ahead. 
10 
MR. KUVIN: Yes. As far as I'm concerned, you 
11 
can cut it. 
12 
THE VIDEOGRAPHER: Okay. We'll go off the 
13 
record at 11:33. 
14 
MR. KUVIN: As far as she is concerned, she's 
15 
got to keep going, so... 
16 
THE VIDEOGRAPHER: Well, I'm going to start 
17 
the recording again because I -- I'm in an awkward 
18 
position. I'm just going to keep it going. 
19 
MR. KUVIN: That's not a problem. 
20 
THE VIDEOGRAPHER: Okay. 
21 
MR. KUVIN: Can I make shadow animals in front 
22 
of you? 
23 
THE VIDEOGRAPHER: If you'd like. 
24 
MR. KUVIN: Jeana is the best court reporter I 
25 
have ever had in all of the hundreds of cases that 
EFTA01158557

0102 
1 
I've tried, can you believe that? 
2 
THE VIDEOGRAPHER: I do believe that. I do. 
3 
MR. KUVIN: Right. Oh, yeah, yeah, yeah. I 
4 
remember you mentioned that before, right, yeah. 
5 
THE WITNESS: Are we off the record? 
6 
MR. KUVIN: Unfortunately, Mr. Pike wanted us 
on permanently, so we're on permanently. 
MR. PIKE: Actually, no. The -- I wanted to 
go off the record in order to, you know, conserve 
on Jeana's time, as well as the videographer, but 
Mr. Kuvin, you stated you wanted to be on the 
record because you wanted to ensure that everything 
was on the record that had to deal with this case. 
So now we're seeing people coming in and out of 
doors after they use the restroom, which I really 
see as a complete waste of resources. 
Nonetheless --
MR. GOLDBERGER: Let's all be friends here and 
let's just do this depo. 
MR. KUVIN: I just wanted to stay on the 
record while --
MR. GOLDBERGER: That's fine. 
MR. KUVIN: -- the attorneys were still in the 
room, that's all. 
MR. GOLDBERGER: That's fine. 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0103 
1 
MR. KUVIN: When the attorneys leave the room, 
2 
I don't mind going off the record. That's no 
3 
problem with me. 
4 
MR. GOLDBERGER: Let's just get along and get 
5 
this stuff done and move on. 
6 
MR. KUVIN: I'm more than happy to do that. 
7 
MR. GOLDBERGER: Are we cool with that? 
8 
MR. KUVIN: Sure. 
9 
MR. GOLDBERGER: Sure. 
10 
THE VIDEOGRAPHER: Spencer, you have about 
11 
five minutes. 
12 
MR. KUVIN: Why don't you change tape so we 
13 
don't have to stop. 
14 
MR. GOLDBERGER: What time do you want to 
15 
stop, because I've just got some stuff that I need 
16 
to do at some point today. Do you want to take a 
17 
break or do you not --
18 
THE VIDEOGRAPHER: Let me go off the record. 
19 
We'll go off the record at 11:36. This will be the 
20 
end of videotape No. 1. 
21 
COURT REPORTER: Are we going off the paper 
22 
record, too? 
23 
MR. KUVIN: Sure. 
24 
MR. PIKE: Yeah. 
25 
(A brief recess was taken.) 
0104 
1 
THE VIDEOGRAPHER: We're back on the record at 
2 
11:39. This will be the beginning of tape No. 2. 
3 
BY MR. KUVIN: 
4 
Q. 
What job -- what job did you have at 
5 
Bear Stearns? 
6 
A. 
I fully intend to respond to all relevant 
7 
questions regarding this lawsuit; however, at the 
8 
present time, my attorneys have counseled me I cannot 
9 
provide answers to any questions that may be relevant to 
10 
this lawsuit. I must accept this advice or risk losing 
EFTA01158558

11 
my 6th Amendment right to effective representation. 
12 
Accordingly, I assert my federal constitutional rights 
13 
as guaranteed by the 5th, 6th and 14th Amendment to the 
14 
US Constitution. 
15 
MR. KUVIN: Obviously, I'm going to have to 
16 
take this up with Judge Hafele, but I'm trying to 
17 
understand, counsel, and, you know, I'm not going 
18 
to ask the witness obviously but how his job at 
19 
Bear Stearns is a potential 5th Amendment issue in 
20 
this case. 
21 
MR. PIKE: It's asked and answered. 
22 
MR. KUVIN: So there is no explanation? 
23 
MR. PIKE: You said you wanted to take it up 
24 
with the judge; you can take it up with the judge. 
25 
Number one, the relevancy of it is it's not 
0105 
1 
applicable to your lawsuit, that -- I mean, that's 
2 
the large part. 
3 
MR. KUVIN: Relevance we can argue about. 
4 
MR. PIKE: Anyway, but again, I don't need to 
5 
make your case for you. You can make your case to 
6 
Judge Hafele. The privilege has been asserted. 
7 
BY MR. KUVIN: 
8 
Q. 
Sir, isn't it true that you do not have a 
9 
college degree? 
10 
A. 
Yes, that's true. 
11 
Q. 
All right. Now, you have no post-secondary 
12 
degrees? 
13 
A. 
No, sir. 
14 
Q. 
How did you get the job at Bear Stearns 
15 
without a college degree or any post-secondary degrees? 
16 
A. 
You don't need a college degree to get a job 
17 
with Bear Stearns. 
18 
Q. 
Who gave you the job? 
19 
A. 
I fully intend to respond to all relevant 
20 
questions regarding this lawsuit; however, at the 
21 
present time, my attorneys have counseled me I cannot 
22 
provide answers to any questions relevant to this 
23 
lawsuit. I must accept their advice or risk losing my 
24 
6th Amendment right to effective representation. 
25 
Accordingly, I assert my federal constitutional rights 
0106 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
as guaranteed by the 5th, 6th and 14th Amendment to the 
US Constitution. 
Q. 
In 1982, you founded your own financial 
management firm called J. Epstein & Company; isn't that 
true? 
A. 
As I've answered most of your other questions 
today, Mr. Kuvin, I intend to fully 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. 
The company that you founded called J. Epstein 
& Company later changed its name to Financial Trust Co, 
and its headquarters are in the private islands of the 
US Virgin Islands; isn't that true? 
A. 
I fully intend to respond to all relevant 
questions regarding this lawsuit; however, at the 
EFTA01158559

22 
present time, my attorneys have counseled me I cannot 
23 
provide answers to any questions relevant to this 
24 
lawsuit. I must accept their advice or risk losing my 
25 
6th Amendment right to effective representation. 
0107 
1 
Accordingly, I assert my federal constitutional rights 
2 
as guaranteed by the 5th, 6th and 14th Amendments to the 
3 
United States Constitution. 
4 
Q. 
Do you socialize with Leonard Sustein 
5 
(phonetic)? 
6 
A. 
I'm going to answer that question the way I've 
7 
answered most of your other questions here today, 
8 
Mr. Kuvin, which is, I 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 their 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. 
Have you socialized with Richard Axle 
18 
(phonetic)? 
19 
A. 
I'm going to answer that question the same way 
20 
I've answered most of your other questions here today, 
21 
which is, I fully intend to respond to all relevant 
22 
questions regarding this lawsuit; however, at the 
23 
present time, my attorneys have counseled me I cannot 
24 
provide answers to any questions relevant to this 
25 
lawsuit. I must accept their advice or risk losing my 
0108 
1 
6th Amendment right to effective representation. 
2 
Accordingly, I assert my federal constitutional rights 
3 
as guaranteed by the 5th, 6th and 14th Amendment to the 
4 
US Constitution. 
5 
MR. PIKE: And in addition, the question lacks 
6 
predicate and it's vague and ambiguous. It's 
7 
overly broad. 
8 
BY MR. KUVIN: 
9 
Q. 
Do you know Gerald Edelman? 
10 
A. 
I'm going to answer that question the same way 
11 
I've answered most of your other questions here today, 
12 
Mr. Kuvin, which is, I fully intend to respond to all 
13 
relevant questions regarding this lawsuit; however, at 
14 
the present time, my attorneys have counseled me that I 
15 
cannot provide answers to any questions that may be 
16 
relevant to this lawsuit. I must accept this advice or 
17 
risk losing my 6th Amendment right to effective 
18 
representation. Accordingly, I assert my federal 
19 
constitutional rights as guaranteed by the 5th, 6th and 
20 
14th Amendment to the US Constitution. 
21 
Q. 
Do you know Murray Gelman? 
22 
A. 
I'm going to answer that question the same way 
23 
I've answered most of your other questions here today, 
24 
which is, I fully intend to respond to all relevant 
25 
questions regarding this lawsuit; however, at the 
0109 
1 
present time, my attorneys have counseled me I cannot 
2 
provide answers to any questions that may be relevant to 
3 
this lawsuit. I must accept this advice or risk losing 
4 
my 6th Amendment right to effective representation. 
5 
Accordingly, I assert my federal constitutional rights 
6 
as guaranteed by the 5th, 6th and 14th Amendment to the 
EFTA01158560

7 
US Constitution. 
8 
Q. 
Do you know Ben Goertzel, spelled 
9 
G-O-E-R-T-Z-E-L? 
10 
A. 
I'm going to answer that question the same way 
11 
I've answered most of your other questions here today, 
12 
which is, I fully intend to respond to all relevant 
13 
questions regarding this lawsuit; however, at the 
14 
present time, my attorneys have counseled me I cannot 
15 
provide answers to any questions relevant -- was that 
16 
just a yawn? 
17 
Q. 
I'm sorry, yes, that was just a yawn. 
18 
A. 
I must accept this advice or risk losing my 
19 
6th Amendment right to effective representation. 
20 
Accordingly, I assert my federal constitutional rights 
21 
as guaranteed by the 5th, 6th and 14th Amendment to the 
22 
US Constitution. 
23 
Q. 
Do you know Marvin Minsky, M-I-N-S-K-Y? 
24 
A. 
I'm going to answer that question the same way 
25 
I've answered most of your other questions here today. 
0110 
1 
I fully intend to respond to all relevant questions 
2 
regarding this lawsuit; however, at the present time, my 
3 
attorneys have counseled me I cannot provide answers to 
4 
any questions relevant to this lawsuit. I must accept 
5 
this advice or risk losing my 6th Amendment right to 
6 
effective representation. Accordingly, I assert my 
7 
federal constitutional rights as guaranteed by the 5th, 
8 
6th and 14th Amendment to the US Constitution. 
9 
Q. 
Do you know a politician, George Mitchell? 
10 
A. 
I'm going to answer that question the same way 
11 
I've answered most of your other questions here today, 
12 
which is, I fully intend to respond to all relevant 
13 
questions regarding this lawsuit; however, at the 
14 
present time, my attorneys have counseled me I cannot 
15 
provide answers to any questions relevant to this 
16 
lawsuit. I must accept their advice or risk losing my 
17 
6th Amendment right -- another yawn? 
18 
Q. 
I'm sorry, I can't help yawning. It seems to 
19 
be a function of the day. 
20 
MR. PIKE: Move to strike. 
21 
BY MR. KUVIN: 
22 
Q. 
I apologize. I tried to keep my mouth shut 
23 
for that one, so -- but I can't help it. I apologize. 
24 
MR. PIKE: Move to strike. 
25 
THE WITNESS: Accordingly, I assert my federal 
0111 
1 
constitutional rights as guaranteed by the 5th, 6th 
2 
and 14th Amendment to the US Constitution. 
3 
BY MR. KUVIN: 
4 
Q. 
Do you know President Bill Clinton? 
5 
A. 
I'm going to respond to that question the same 
6 
way I've responded to most of your other questions here 
7 
today, which is, I intend to respond to all relevant 
8 
questions regarding this lawsuit; however, at the 
9 
present time, my attorneys have counseled me that I 
10 
cannot provide any answers to questions that may be 
11 
relevant to this lawsuit. I must accept this advice or 
12 
risk losing my 6th Amendment right to effective 
13 
representation. Accordingly, I assert my federal 
14 
constitutional rights as guaranteed by the 5th, 6th and 
15 
14th Amendment to the US Constitution. 
16 
Q. 
Do you know Actor Kevin Spacey? 
17 
A. 
I'm going to answer that question the same way 
EFTA01158561