EFTA01158522

4 
me, pinching his nipples. He's probably getting 
5 
hard right now." 
6 
(Video stopped.) 
7 
BY MR. KUVIN: 
8 
Q. 
Do you have a fetish where you like young 
9 
women to pinch your nipples? 
10 
A. 
I'm going to respond to that the same way I've 
11 
responded to most of your other questions here today, 
12 
which is, I intend to respond to all relevant questions 
13 
regarding this lawsuit; however, at the present time, my 
14 
attorneys have counseled me I cannot provide answers to 
15 
any questions relevant to this lawsuit. I must accept 
16 
their advice or risk losing my 6th Amendment right to 
17 
effective representation. Accordingly, I assert my 
18 
federal constitutional rights as guaranteed by the 5th, 
19 
6th and 14th Amendment to the United States 
20 
Constitution. 
21 
MR. PIKE: And I assume, Mr. Kuvin, you will 
22 
provide me with the number on the roll that 
23 
you're -- that you pretty much marked as an exhibit 
24 
here, where it starts numerically and where it ends 
25 
numerically so I can pull it and we can have an 
0161 
1 
exhibit made for purposes of this deposition. 
2 
MR. KUVIN: Oh, I don't intend to attach it as 
3 
an exhibit to this deposition. 
4 
MR. PIKE: Well, what were the -- where did it 
5 
start and where did it begin on the roll? 
6 
MR. KUVIN: I don't know. It's a clip that I 
7 
pulled from the master video. I can get it for you 
8 
though. I can certainly identify it in the 
9 
transcript. 
10 
MR. PIKE: So you'll provide that to me? 
11 
MR. KUVIN: Yeah, I'll find a place in the 
12 
transcript for you, that's not a problem. 
13 
BY MR. KUVIN: 
14 
Q. 
Do you like to have underaged girls massage 
15 
your legs, underaged being under the age of 18? 
16 
A. 
I'm going to respond to that question the same 
17 
way I've responded to most of your other questions here 
18 
today, which is, I intend to respond to all relevant 
19 
questions regarding this lawsuit; however, at the 
20 
present time, my attorneys have counseled me I cannot 
21 
provide answers to any questions relevant to this 
22 
lawsuit. I must accept their 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, 6th and 14th Amendment to the 
0162 
1 
United States Constitution. 
2 
Q. 
Have you had underaged girls, which include 
3 
...., in 2004, 2005 and 2006, massage your chest while 
4 
they were naked? 
5 
A. 
I intend to respond to all relevant questions 
6 
to this lawsuit; however, at the present time, my 
7 
attorneys have counseled me I cannot provide answers to 
8 
any questions that may be relevant to this lawsuit. As 
9 
I've done with most of your questions here today, I must 
10 
accept their advice or risk losing my 6th Amendment 
11 
right to effective representation. Accordingly, I 
12 
assert my federal constitutional rights as guaranteed by 
13 
the 5th, 6th and 14th Amendment to the United States 
14 
Constitution. 
EFTA01158582

15 
16 
for 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0163 
1 
advice or risk losing my 6th Amendment right to 
2 
effective representation. Accordingly, I assert my 
3 
federal constitutional rights as guaranteed by the 
4 
5th, 6th and 14th Amendment to the United States 
5 
Constitution. 
6 
BY MR. KUVIN: 
7 
Q. 
Did you pay 
$200 to come to your home in 
8 
2005? 
9 
MR. PIKE: Form. 
10 
MR. KUVIN: I'm sorry, what's the form 
11 
problem? 
12 
MR. PIKE: I don't need to provide you with a 
13 
speaking objection. The rules are the rules. 
14 
You've clearly stated to me today that you don't 
15 
want speaking objections, and I've abided by that; 
16 
therefore, the objection is form. 
17 
MR. KUVIN: I'm just asking for a 
18 
clarification so I can correct the question if I 
19 
need to. 
20 
MR. PIKE: Ask your question again, Mr. Kuvin. 
21 
MR. KUVIN: Can you read it back for me? 
22 
Thank you. 
23 
(A portion of the record was read by the 
24 
reporter.) 
25 
THE WITNESS: I'm going to respond to that 
0164 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
BY 
15 
16 
to 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Q. 
Does Mr. Wexner know of your sexual preference 
underaged girls, girls under the age of 17? 
MR. PIKE: Form, argumentative, harassing, 
assumes facts not in evidence. 
THE WITNESS: I'm going to have to answer that 
the same way I've answered most of your questions 
here today, 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 the lawsuit. I must accept their 
question in the same way I've responded to most of 
your other questions here today, 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 their 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 United States 
Constitution. 
MR. PIKE: Same objection. 
MR. KUVIN: 
Q. 
You knew III. was 15 years old when she came 
your home, didn't you? 
MR. PIKE: Form. 
THE WITNESS: I'm going to respond to that 
question the same way I've responded to most of 
your other questions here today, 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 relevant to this lawsuit. I must accept 
their advice or risk losing my 6th Amendment right 
EFTA01158583

0165 
1 
to effective representation. Accordingly, I assert 
2 
my federal constitutional rights as guaranteed by 
3 
the 5th, 6th and 14th Amendment to the United 
4 
States Constitution. 
5 
BY MR. KUVIN: 
6 
Q. 
What is the Wexner Children's Trust, the 
7 
second? 
8 
MR. PIKE: Can you restate your question 
9 
again? 
10 
BY MR. KUVIN: 
11 
Q. 
Yes. What is the Wexner's Children's -- I'm 
12 
sorry, Wexner, singular, Children's Trust II, or the 
13 
second? 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0166 
1 
and 14th Amendment to the United States 
2 
Constitution. 
3 
THE VIDEOGRAPHER: Spencer, can we take a 
4 
quick break? 
5 
MR. KUVIN: Change tape? 
6 
THE VIDEOGRAPHER: No, a problem with your 
7 
mic. I just want to go off for a second and see if 
8 
we can fix it. 
9 
MR. KUVIN: Sure. 
10 
THE VIDEOGRAPHER: We're off the record at 
11 
1:03 p.m. 
12 
(A brief recess was taken.) 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0167 
1 
CERTIFICATE OF OATH 
2 
THE STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
5 
6 
I, the undersigned authority, certify that 
7 
JEFFREY EPSTEIN personally appeared before me and was 
8 
duly sworn on the 8th day of October, 2009. 
9 
10 
Dated this 8th day of October, 2009. 
MR. GOLDBERGER: Okay. 
THE WITNESS: I'm going to have to respond to 
that question the same way I've responded to 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 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 
EFTA01158584

11 
12 
13 
14 
15 
Jeana Ricciuti, RPR, FPR, CLR 
16 
Notary Public - State of Florida 
My Commission Expires: 2/17/2013 
17 
My Commission No.: DD 854778 
18 
19 
20 
21 
22 
23 
24 
25 
0168 
1 
CERTIFICATE 
2 
THE STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
5 
I, Jeana Ricciuti, Registered Professional 
Reporter and Notary Public in and for the State of 
6 
Florida at large, do hereby certify that I was 
authorized to and did report said deposition in 
7 
stenotype; and that the foregoing pages are a true and 
correct transcription of my shorthand notes of said 
8 
deposition. 
9 
I further certify that said deposition was 
taken at the time and place hereinabove set forth and 
10 
that the taking of said deposition was commenced and 
completed as hereinabove set out. 
11 
I further certify that I am not attorney or 
12 
counsel of any of the parties, nor am I a relative or 
employee of any attorney or counsel of party connected 
13 
with the action, nor am I financially interested in the 
action. 
14 
The foregoing certification of this transcript 
15 
does not apply to any reproduction of the same by any 
means unless under the direct control and/or direction 
16 
of the certifying reporter. 
17 
Dated this 8th day of October, 2009. 
18 
19 
20 
21 
Jeana Ricciuti, RPR, FPR, CLR 
22 
23 
24 
25 
0169 
1 
2 
3 
4 
DATE: 
TO: 
October 22, 2009 
JEFFREY EPSTEIN 
c/o Michael J. Pike 
BURMAN, CRITTON, LUTTIER & COLEMAN, P.A. 
303 Banyan Boulevard 
Suite 400 
West Palm Beach, Florida 33401 
EFTA01158585

5 
IN RE: =. v. EPSTEIN 
6 
Please take notice that on Thursday, the 8th 
7 
of October, 2009, you gave your deposition in the 
above-referred matter. At that time, you did not waive 
8 
signature. It is now necessary that you sign your 
deposition. 
9 
As previously agreed to, the transcript will 
be furnished to you through your counsel. Please read 
10 
the following instructions carefully: 
At the end of the transcript you will find an 
11 
errata sheet. As you read your deposition, any changes 
or corrections that you wish to make should be noted on 
12 
the errata sheet, citing page and line number of said 
change. DO NOT write on the transcript itself. Once 
13 
you have read the transcript and noted any changes, be 
sure to sign and date the errata sheet and return these 
14 
pages to me. 
If you do not read and sign the deposition 
15 
within a reasonable time (i.e., 30 days unless otherwise 
directed) the original, which has already been forwarded 
16 
to the ordering attorney, may be filed with the Clerk of 
the Court. If you wish to waive your signature, sign 
17 
your name in the blank at the bottom of this letter and 
return it to us. 
18 
Very truly yours, 
19 
20 
Jeana Ricciuti, RPR, FPR, CLR 
21 
Prose Court Reporting Agency, INC. 
250 S. Australian Avenue, Ste 1500 
22 
West Palm Beach, Florida 33401 
23 
I do hereby waive my signature. 
24 
25 
JEFFREY EPSTEIN 
0170 
1 
CERTIFICATE 
2 
3 
THE STATE OF FLORIDA 
4 
COUNTY OF PALM BEACH 
5 
I hereby certify that I have read the 
6 
foregoing deposition by me given, and that the 
7 
statements contained herein are true and correct to the 
8 
best of my knowledge and belief, with the exception of 
9 
any corrections or notations made on the errata sheet, 
10 
if one was executed. 
11 
12 
Dated this 
day of  
13 
2009. 
14 
15 
16 
17 
18 
19 
JEFFREY EPSTEIN 
20 
21 
22 
23 
24 
EFTA01158586

25 
0171 
1 
ERRATA 
SHEET 
2 
IN RE: III. v. EPSTEIN CR: JEANA RICCIUTI 
3 
DEPOSITION OF: JEFFREY EPSTEIN 
4 
TAKEN: October 8, 2009 
5 
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 
6 
PAGE # LINE # 
CHANGE 
REASON 
7 
8 
9 
10 
11 
12 
13 
14 
15 
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18 
Under penalty of perjury, I declare that I have read my 
19 
deposition and that it is true and correct subject to 
any changes in form or substance entered here. 
20 
21 
22 
23 
24 
25 
Please forward the original signed errata sheet to this 
office so that copies may be distributed to all parties. 
DATE:  
SIGNATURE OF DEPONENT: 
EFTA01158587