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10. Hs 12. 13, 14, 16. 17. 19. Jeffrey Epstein v. Bradiey J. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG Attachments to Statement of Undisputed Facts . Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564-67, 568) Deposition of L.M. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition of E.W. taken May 6, 2010 (115, 116, 255, 205, 215-216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Epstein taken April 14, 2010 Deposition of Jeffrey Epstein taken February 17, 2010 Deposition of Alfredo Rodriguez taken July 29, 2009 (242-44, 223-28, 230-31, 278-280) Deposition of Nadia Marcinkova taken April 13, 2010 (11) Deposition of Jeffrey Epstein dated March 8, 2010 Deposition of Jeffrey Epstein dated October 8, 2009 Deposition of Jeffrey Epstein dated May 1, 2009 Deposition of Jeffrey Epstein dated May 7, 2009 Deposition of Sarah Keflen dated March 24, 2010 . Deposition of Adriana Mucinska Ross dated March 15, 2010 Deposition of Janusz Bansiak taken February 16, 2010 (14, 154-160, 172-175) Deposition of Louella Rabuyo taken October 20, 2009 (9) . Deposition of Larry Eugene Morrison taken October 6, 2009 (102-103) Deposition of Alfredo Rodriguez taken August 7, 2009 (302-306, 348)

20. Deposition of Mark Epstein taken September 21, 2009 (48-50) 21. Deposition of Larry Visoski taken October 15, 2009 22. Deposition of Bradley J. Edwards taken March 23, 2010 (110-116)

DEFENDANT BRADLEY J. EDWARDS’S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 22

Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2009CA040800XXXXMB AG Complex Litigation, Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, ~vs~ VOLUME I OF IT SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M. individually, Defendants. VIDEOTAPED DEPOSITION OF BRADLEY J. EDWARDS, ESQUIRE Tuesday, March 23, 20016 : 10:00 - 5:07 p.m. : 2139 Palm Beach Lakes, Boulevard West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1333 (561) 832- 7500 PROSE COURT REPORTING AGENCY, INC. (561) 832- 7506

Page 110 L that you were aware of; that is, hard copies? 2 A. I don't know. 3 Q. Okay. Could have been more, could have 4 been less; you just don’t know? 5 A. Correct, 6 Q. If I understood your testimony, Wi Mr. Rothstein, Mr. Rosenfeldt, any other attorney or 8 investigator could have accessed those files 9 depending or where they were within the firm, true? 10 A. I am not sure exactly who could have accessed 121 it. You asked me if the attorneys could and the 12 attorneys had swipe cards for various locked areas. 13 Each attorney I believe had access to any area where 14 those files were located. I believe so. 15 Q. Okay. Well, during the time you were 16 there did an individual by the name of Ken Jenne 17 work there? 18 A. Yes. 19 Q. Okay. Did an individual by the name of 20 Mike Fisten work for the firm -— 21 A. Yes. 22 Q. -- for RRA? Were they employees of the 23 firm or were they independent contractors? 24 A. I don't know. 25 Oy Okay. During the time they were there, RRM TT TR TIS TT A IT RT NTT TT TO (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 111 | i did they also have swipe cards so that they could 2 access different areas in the firm? 3 A. I believe so. 4 Q. With regard to when you joined RRA, did 5 you ever have any further meetings with 6 Mr. Rothstein; that is, from the day you started at 7 RRA, did you ever meet Mr. Rothstein again? 8 A. By meet him again -9 Q. Did you ever have a meeting with him again 10 regarding your position in the firm? 1i A. No. 42 ee Okay. Did you ever meet with him and a 13 number of other individuals with regards to firm q 14 business? | 15 A. No. 16 Q. Firm cases? : 17 A. I don't believe so. 18 Q. Was Mr. Rothstein ever present in any : 19 meeting where any of your cases were discussed? Let 20 me strike that. Was Mr. Rothstein ever present : 21 wherein at any meeting where any of the cases 22 against Jeffrey Epstein were discussed? Don't tell 23 me content; just was he ever present. 24 A. How would I know that? I don't know. He 25 could, he could be in a meeting right now where the case (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 112 | 1 could be discussed for all I know. 2 °. I'm sorry. Obviously, where you, where 3 you were present. Where you ever present at a 4 meeting where Mr. Rothstein was also present where 5 the Epstein cases were discussed? E 6 A. No. : 7 Q. Did he ever call you to communicate with 8 you, call you either by phone, video conference, in 9 any fashion to discuss any act aspect of the cases 10 that you had against Jeffrey Epstein? il MR. SCAROLA: You can answer that. 12 THE WITNESS: He has communicated about 13 various, about legal issues related to the case 14 as well as commented about the case to me on : 15 very few occasions but I would say less than 16 three times. 17 BY MR. CRITTON: : 18 Q. During the time that you, from April of 19 ‘09 through late October of '09, correct? 20 A. In that time period, where, is that when 21 these -~ 22 On. Correct. 23 A. -- things happened? 24 oO. Well, that's the time you were there; ; 25 that's what I am asking. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

10 1. 12 13 14 15 16 17 18 19 20 21 22 23 24 (561) Page 113 f A. When I was there. Q. And do you, can you remember the date, any specific date that you spoke with him? A. No. Q. Do you remember any specific month that you would have had one of the -- well, what did you say something less than five conversations? I don't want to misquote you. A. I said less than three conversations. Os All right. So, something less then three conversations you had with Mr. Rothstein regarding Epstein cases, either legal issue or a comment, some comment about the case to you, correct? A. Yes. Q. All right. The first time that he ever spoke to you, did he call you or did you call him? A. I, I never called Scott Rothstein about anything. Oh, take that back, About anything related to Jeffrey Epstein. Q. The first conversation that you can recall where either a legal issue or a comment was made about Jeffrey Epstein by Mr. Rothstein to you, he obviously initiated the call? A. It wasn't a call. What was it? 832-7500 PROSE COURT REPORTING AGENCY, INC. (S61) 832-7506

11 12 13 14 15 16 17 18 19 20 21 22 23 (561) 832-7500 PROSE Page 114 ff A. A comment in passing. And I believe I was sitting at a table in BOVA when he walked over to my table and commented about Jeffrey Epstein. QO. Okay. Who were you there with at the time? A. T don't remember. 0. Were you with some friends? Were you with other lawyers? A. All right. I am jogging my memory. I, I have no idea. Q. What did he say? MR. SCAROLA: To the extent that you can answer that question without disclosing any mental impressions with regard to the lawsuit or any attorney-client privileged communications, you can answer. To the extent that it might invade either the work-product or attorney-client privilege, you should not respond. THE WITNESS: Can I talk to you? MR. SCAROLA: Sure. (A brief recess was held.) MR. SCAROLA: Are we on? THE VIDEOGRAPHER: Yeah. MR. SCAROLA: The record should reflect (561) 832-7506 REPORTING AGENCY, INC. couRT

Page 115 | 1 that we have had an opportunity to consult and 2 I have advised Mr. Edwards that there is no 3 privilege protection for the particular 4 communications involved. 5 BY MR. CRITTON: 6 Oo What did he say? 7 A. He commented to me, I want you to get that 8 pedophile. 9 Q. And your response was what? 10 A. I didn't respond. 11 Ox All right. Second conversation that you 12 can remember, where were you? 13 A. I had just come out of the conference room on 14 the main floor after taking a deposition in another 15 case. And he walked by and said, did you get that F'ing 16 pedophile yet. 17 Q. And your response? : 18 A. Again. | 19 Q. No response. 20 A. Didn't respond. 21 Q. On the first occasion when he came over 22 and if I understand correctly, all he said was the i 23 comment that you referenced and then he left. You 24 didn't respond and then he just made the comment and ; 25 then left? : ) A (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 116 1 A. Right. He was walking by in his normal, loud, 2 ostentatious kind of way, greeting everybody in the 3 restaurant. Came over to my table and he feels, at 4 least my impression was obliged to say something to 5 everyone. And that's the comment he said to me. 6 And if youtve ever seen him, he is 7 basically always just skipping around and he hoped 8 on over somewhere else. So, yes, it was in, 9 literally in passing. 10 Q. Okay. How, how, how did he even know you LL had cases involving Mr. Epstein? 12 A. I don't know. : 13 Q. Because I think you testified earlier that 14 you had never discussed an Epstein case with : 15 Mr. Rothstein one-on-one, correct? 16 A. Absolutely, true. ; L7 Q. You never discussed an Epstein case or 18 either of your three clients with Mr. Rothstein even 19 with a group of people around, correct? | 20 A. Correct. 21 Q. All right. Do you remember a third 22 occasion that he spoke to you regarding Epstein : 23 related occasion, cases? 24 A. Anything else that he ever spoke with me about ! 25 related to Epstein related issues is attorney-client and i (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 TCM EIT

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 21

Larry Visoski October 15, 2009 ‘CTHE cIRcuET couke oF me serenity duotcraL cinciT | 1 wh ‘Te AND FOR PAIN BEACK COUNTY, (ASE NOS S02000CROZOOSIEIAEE AD 2 INDEX . Plaintiff, 5 WITNESS: DIRECT CROSS REDIRECT RECROSS ve a oeerReY EeSTEIS, LARRY VISOSKI Defendant. 7 BYMR. EDWARDS: 6 DEEGETTIGN OF CRAY VEGERT Gr EVAR CHITTON ae Thucgday, October 15, 7009 BY MR. EDWARDS: 200 . 3 BYMR. CRITTON: 224 518 NW, Flagler Orive 20. Suite £200 i Nest fale Beach, Florida 33401 42 aot 13 EXHIBITS Reported 3y: 14 Pes Hendy Death Anderson, RER, CRS, FPR worary Publics State of Florida 15, squire Deposition Services 16 NUMBER DESCRIPTION PAGE West Palm Seach Office Job #127542 STD BLAINTIEES OLA SLIGHT Ls BOOK (MARKED IN PREVIOUS DEPO} 18 19 PLAINTIFF'S EX. 2 MESSAGE PAD ne PLAINTIFF'S EX.3 MESSAGE PAD 119 20 PLAINTIFF'SEX.4 COMPLAINT 139 PLAINTIFF'S EX.S INMATEVISITORLOG 161 aL 22 23 24 25 —+ 2 4 1 APPEARANCES: 1 PROCEEDINGS 2 Onbehalf of the Piaintft: 2 ats 3 BRADLEY J, EDWARDS, ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 3 Deposition taken before Wendy Beath Anderson, 4 ee Olas Boulevard 4 Certified Realtime Reporter and Notary Public in and for s Fort Lauderdale, Florida 33394 5 the State of Florida at Large, in the above cause. 6 6 Bite 7 Onbehaif of the Defendant: . a ROBERT D. CRITTON, JR, ESQUIRE 7 MR. EDWARDS: We're going to put something on BURMAN, CRITTON 8 LUTTIER. 8 the record about -- well, we'll do it this way ~ 3 303 Banyan Boulevard, Suite : Wea vase tonch, Pon ano 9 MR. REINHART: Do it at the end, after we get 10 10 him -- whatever you want. {t's your show, 11 On behalf of the Witness: ; a 42” BRUCE REINHART, ESQUIRE i MR. EDWAROS: Okay. There were -- I dont 250 South Australian Avenue 12 even think Mr. Wilts is aware of this. There was 43 Suite 1400 13 a subpoena duces tecum for this witness, as well as Palm Beach, Florida 33401 ss aa Ween ei 14 the previous witness, which was another pifot, Dave 15 ALSO Miers secu: is Rogers, and that duces tecum was to bring the ae a 1 SLUNWT ETT Averes 16 _fiight logs related from 1998 through 2005, What 17 nnn is Dee SURE. aT was produced at the previous deposition were flight 18 Al HOROWITZ, ESQUI : NORE LATIN € HOROWITZ: PA: is logs from 2002 through 2008, and now Mr. Reinhart a9 18205 Biscayne Boulevard, Suite 2218 19 has agreed to produce the remainder of the flight os Miaml, Florida 33160 20 logs requested, those going from 1898 through 2002. RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE) 22 MR. REINHART: Correct. They're pilot fags, aa RICHARD H. WILLITS, PA. 22 not flight logs. There are other records we 2290 10th Avenue North, Suite 404 a 4 2 Lake Worth, Florida 33461 23 indicated are corporate records, and with those you 23 24 have to deal with Mr. Critton. a8 25 MR. CRITTON: However, with the proviso, too,

Larry Visoski i 5 October 15, 2009 7 ide that we're going to work out that these records are 1 the question and you need to wait until | finish asking 2 to be used within the confines of this litigation 2 the question. 3 and not to be spread to the press or anyone else, 3 A. So you're not allowed to interrupt me? 4 because they de contain confidential information as 4 Q. And you're not allowed to interrupt me. 5 to who may have been on the plane and other records 5 A. Like | just did? 6 of Mr. Ragers, which but for the subpoena would 6 Q. Right. a have been only available to the FAA or some other 7 MR. CRITTON: Cara just snickered when you 8 law enforcement agencies. 8 said you've been accused because she recognizes. 9 MR. EDWARDS: Okay. Is that ail you want to 9 it's true. 16 put on? 10 MR. EDWARDS: | don't know what the meaning ag MR. CRITTON: Yes. 11 her snickering was. 12 MR. EDWARDS: I'm not saying | necessarily 12. BY MR. EDWARDS: 13 agree or disagree with you. That's something that 13 Q. But for what it's worth, if you don't 14 we'll deal with some other day. 14 — understand the question or I've asked a bad question, t 15 MR. CRITTON: Bruce, you'd betier produce 15 — don’t want you to guess. Give me the best answer to the 16 these records, but there has to be some sort of 16 best of your knowledge and if you need me to rephrase iy understanding before — 17 sit, | will, 18 MR. REINHART: Correct. 18 A. Okay. 19 MR. EDWARDS: | won't do anything until you 19 Q. Okay. Tell me your current address. 20 file whatever you -- until we work whatever it is 20 A. 1131 Pine Point Road, Riviera Beach, Florida 22 out in court, "i say that on the record, that 21 33404. 22 #m not doing anything with the records outside of 22 Q. How long have you lived there? 23 mny office until same judge deals with it. 23 A. Approximately nine years. 24 MR. REINHART: And for the record, Fl adopt 24 Q. Okay. Who do you five there with? 28 what Mr. Critton said on this one limited occasion. 25 A. My wife and one child at this time. 6 8 + MR. EDWARDS: Aili right. 1 Q. Allright. How many children do you have? 2 Thereupon, 2 A. Two. 3 {LARRY VISOSKI) 3 Q. How old are they? 4 having been first duly sworn or affirmed, was examined 4 A, Fifteen and eighteen. 5 and testified as follows: 5 Q. Andis the 18-year-old, is not living with 6 THE WITNESS: Yes, { do. 6 you? 7 DIRECT EXAMINATION T A. She's off in school. 8 BY MR. EDWARDS: 8 Q. Okay. What school is that? 9 Q. Gan you tell us your name for the record. 9 A. Syracuse. 10 A. Lawrence Visoski, Jr. 10 Q. Who's your employer right now? a Q. And Mr. Visoski, have you ever had your il A. NES, LLC. 12 deposition taken before? 12 Q. How lang has NES, LLC been your employer? 43 A. No. 13 A. I'm guessing. I'd say back 1991. I have to 14 Q. Okay. Here's the process: I'm going to ask 14 do the math, but 17, 18 years. 15 you questions. You're going to give us answers. Tryto{ 15 Q. Has that been your only employer since 19917 16 give us answers that we all understand and that the 16 A. Yes. 17 court reporter can take down, such as yes, no, or some} 17 Q. And has that been your only source of income 18 other verbal answer that we can understand. [t's easy 18 ~~ since 19917 19 when we get in a casual conversation to nod or shake 19 A. Yes. 20 your head, and the court reporter is not writing 20 Q. And what is NES, LLC? 21 pictures or anything else. 21 A. | don't really know. | mean, it's the company 22 A. lunderstand, 22 that my check comes from. 23 Q. The other thing is, and {ve been accused of 23 Q. What do you do for NES, LLC that results in 24 _ this in other depositions — i don't know ff it's true 24 — them paying you? 25 or not -- but ! need to wait until you finish answering 25 A. lam chief pilot for the aircraft and

Larry Visoski October 15, 2009 9 ii 1 helicopters. 1 Q. What floor or suite number is NES, LLC in? 2 Q. And do you have a specific boss or somebody 2 A. Tbefieve -- well, | don't know that NES, LLC 3 you answer to at NES, LLC? 3 has an office there. { know that's where Leslie has the 4 A. Several people would call to schedule flights. 4 phone number where I call. So | don't know for a fact S from the office, being it either Mr. Epstein or, you Sif NES, LLC has an office there. 6 — know, | would just get a phone cail and they would 6 Q. And what suite number, then, would Leslie 7 ~~ schedule a trip. 7 Groff sit in to answer that telephone number at 8 Q. Okay. Aside from Mr. Epstein, who eise would 8 750-9895? 9 there be that would call to schedule flights? 9 A. think it's 10F. 10 A. Lesiie. 10 Q. And when you stay at 301 East 66th Street, il Q. Leslie who? 11 what suite number or what apartment number do you stay iz A. Leslie Gruff. 12 in? 13 Q. When's the last time you talked to Leslie 13 A. 120, 14° Graff? 14 Q. And how about Dave Rogers, where does he stay? 15 A. Probably two weeks ago, three weeks ago. 1s A. I'm guessing, because it's been some time 16 Q. And where is she currently? 16 since we've been there, 108, but dont quote me on it. 17 A. | believe in New York, is where 1 spoke to her i? Q. Who are the other peopte in that building that 18 on the phone last. 18 you know to stay there on a regular ~ fairly reguiar 19 Q. What's the telephone number you call to reach} 19 basis? 20 — Leslie Gruff? 20 A. lve seen people in the elevator that, you 21 A. {212}750-9895. 21 know, have been on the airplane. Case in point, maybe 22 Q. And what address is Leslie Gruff at? 22 Sarah Kellen, but | don't know for a fact that she fives 23 A. Do you mean where the office is located? 23 there, or anybody else for that matter. 24 Q. Correct. 24 Q. Okay. When you say you've seen Sarah Kellen 25 A. 301 East 66th Street. 25 — onthe elevator — 10 12 1 Q. And it's my understanding from other 1 A. Jonly assume she lives there. | don’t know 2 depositions that there are also apartments in that 301 2 fora fact. I'm trying to be honest and factual for 3 East 66th Street building? 3 you. So [ couldn't honestly say if 1 knew she lived 4 A. Yes, 4 there or not, 5 Q. And Mr. Epstein either owns or leases or rents 5 Q. Where do you think Sarah Kellen lives? 6 certain of those apartments. Is that your 6 A. {would think she lives there. 7 understanding? a Q. You don't have a better location? 8 MR. CRITTON: Form; specuiation. 8 A. I don't have another location. 9 THE WITNESS: I'm only specufating. | 9 Q. Anybody else? 10 don't ~ to my understanding, I don't know. 10 A. Not to my knowledge. | mean, I'd only be 11 BY MR. EDWARDS: 11 guessing that people live in that building that -- you 12 Q. Do you know other people that live in that 12 know, 1 don't have any facts to prove that they actually 13 building? 13 tive there. 1 mean, | don't think you want me to guess. 14 A. Well, it would be myself, Dave Rogers — well, 14 Q. Welt, NES, LLC, would you say that the owner 15 when you say “live,” explain. 15 or controller of that company is Jeffrey Epstein? 16 Q. When you're saying yourself and Dave Rogers; 16 MR. CRITTON: Form. v A. See, we don't live there. i mean, we have — 17 THE WITNESS: | don't know that for a fact. 8 we would stay there when we would have a trip. 18 BY MR, EDWARDS: 19 Q. Okay. When you would fly up to New York and j 19 Q. Jeffrey Epstein is somebody you've indicated 26 land in New York, the place where you would stay, is 20 that you've worked for for 17 or 18 years, right? 21 that 304 East 66th Street? 22 A. Yes. 22 A. Yes, that's correct. 22 Q. And over the 17 or 48 years you've become 23 Q. That's also a location you've indicated in 23 personally close with him as well, correct? 24 this deposition that is the office for NES, LLC? 24 MR. CRITTON: Form. 25 AL Yes. 25 THE WITNESS; | don't understand how you mean:

Larry Visoski October 15, 2009 13 15 1 “close.” Define that. 1 you know, televisions and such. 2 BY MR. EDWARDS: 2 Q. fs that another hobby or job or something of 3 Q. Well, more so than just a pilot that takes him 3 yours? 4 — from Point A to Point B? 4 A. Both. s A. That is my job, 5 Q. Does he pay you for that? 6 Q. Right. But you know him on a personai level 6 A. Not any more than my salary. 7 and that you've had personal conversations that don't 7 Q. What's your current salary? 8 necessarily deal with flying from Point A to Point B; 8 A. Atthis time, 180,000. 9 isn't that right? 3 Q. And what are you paid $480,000 to do? 10 MR. CRITTON: Form. 10 A. To manage his aircraft. qi THE WITNESS: More specific, meaning we talk; 11 Q. What does that entail? 12 about cars. 1 mean, does that make you a personal; 12 A. Scheduling maintenance. Anything that has to 43 friends? 13 dowith any flight, whether it be weather, flight 14 BY MR. EDWARDS: 14 planning, time and distance to and from a location, any 15 Q. Have you ever gone to his house to eat? 15 logistics involved in running an operation that has 16 AL No. 16 aircraft. i? Q. Have you been to his New York home? 17 Q. In addition to the 180,000, does he give you 18 A. Yes. 18 bonuses as well? as Q. How many occasions have you been to hisNew; 19 A. There have been Christmas bonuses. 20 York home? 20 Q. Over the years, you mean, there have been 21 MR. GRITTON: Object te form. 21 Christmas bonuses? 22 THE WITNESS: We normally pick up luggage in} 22 A. Yes. 23 the lobby, so it would probably be quite often. 23 Q. 1s 180,000 the mast he's ever paid you? Any time we depart out of New York, we stop by the} 24 A. No. house and pick up luggage and head te the aircraft. | 25 Q. Allright. Were you making — when was the 14 16 1 BYMR. EDWARDS: 2 last time that you were making an amount different than 2 Q. Other than picking up luggage, have you been 2 180,000? 3 to his home to visit or socialize with him? 3 A. Last year. 4 A. Not to socialize, no. 4 Q. That would be 2008? 5 Q. Have you been to his Paim Beach home? 5 A. That would be correct. Yeah, we all took a 6 A. To? 6 salary cut, I don't know the exact date. It might have 7 Q. To Mr. Epstein's Palm Beach house? 7 been 2008, last year. It was last Christmas we all took 8 A. Right. 8 a 10 percent salary cut. 9 Q. Have you been there? 9 Q. Do you know why? 10 A. Yes. 10 A. Economic reasons. 1 Q. Have you been inside? ll Q. And who told you that you were going to have 12 A. Yes. 12 to take the salary cut? 13 Q. And how many occasions have you been inside} 13 A. Darren indyke. 14 that home? 14 Q. And did you ask for an explanation? as A. The same, as far as picking up luggage, and 15 A. He explained it was due to economic reasons 16 that would be on a regular basis, you know, for 2 16 throughout the country. 17 ~~ departure. We wouldn't always go to the house to pick 7 Q. Okay. So in 2008, how much was — were you 28 up luggage, but it made it easier for joading the 18 — being paid by NES, LLC? = 19 aircraft, getting it done prior to departure. ag A. 200,000. 26 Q. {s that the only reason that you have ever 20 Q. And is 200,000 the most that you've ever made 21 gone to the Palm Beach home over the last 18 years, is) 21 from NES, LLC? 22 to pick up luggage? 22 A. Yes, sir. 23 A. No. 23 Q. And on top of that $200,000, did you get a 24 Q. What other reasons have you gone there? 24 bonus that year as well? 25 A. I've set up several home theater equipments, 25 MR. REINHART: Which year are you talking

Larry Visoski October 15, 2009 OMIA TEWNH aL 42 43 414 £5 16 a7 18 ig 20 2. 23 24 25 OMI H OB wNe 10 li 12 13 4 15 16 1? 18 19 20 21 22 23 24 17 19) about? 1 mypaycheck. So | don't even know what's written on the MR. EDWARDS: 2008. 2 topofit. THE WITNESS: That year, | think we skipped 3 Q. That would be something that only your wife Christmas bonuses that year. The last bonus right 4 would see, I'm assuming? have been 2007. 5 A. You're right, since she probably wouldn't know BY MR. EDWARDS: € the answer either, because she's looking at the right Q. If you ever got a bonus from Mr. Epstein ~ 7 goiumn and not the top column. and {'m only deriving this from you using the term 8 Q. Right. When is the first time that you had "Christmas bonus." 9 heard the name NES, LLC, that company? A. Holiday bonus. 10 A, Five, six years, and even questioned what it Q. ~am | correct to assume — sorry. Amt 11 stood for. And J think to this day | couldn't answer correct fo assume that if you got a bonus, there was. 12 that honestly, what it stands for. only one and it was at the end of the year, around the 13 Q. Okay. But it's your undersianding that the holidays? 14 — NES, LLC is paying you for the work that you do as a A Yes. 15 pilot or maintain the pianes for Jeffrey Epstein? Q. Okay. And how much was the 2007 holiday 16 A. Tomy understanding, yes. bonus? 17 Q. And back in 1991, do you know ifit was a A I'd have to ask my wife, to be honest. | 18 different company that was paying you or if it was. haven't seer my paycheck in 27 years, so | believe it 19 Jeffrey Epstein directly paying you? was $10,000. 20 A. fdon't remember. mean, | don't. Q. And in 2007 you also made $200,0007 21 Q. Okay. Throughout your career with — as a A. Yes. 22 pilot for Jeffrey Epstein, since 1991, has there ever Q. Okay. 23 been a time when you believe you were paid directly from A. With a question mark. I'm trying to be as 24 Jeffrey Epstein personally versus some company? accurate ag | can, but yes. 25 A. Not to my knowledge, no. 18 20 Q. Something pretty close to that? 1 Q. Okay. So whether it was NES, LLC or some A. Yes, sir. 2 — other company, it was all of a sudden a company name, to Q. Okay. So with the bonus it was 210,000, 3 the best of your knowledge? roughly? 4 A. Exactly. yes. A. Right. 5 Q. And back in 1991, do you remember Q. Okay. And how long were you making that 6 — approximately how much you were being paid that year? salary? ? A. Fifty-five or 60,000, is maybe what | started. A. Probably — he was very religious about giving 8 GQ. Okay. annual increases, so | would probably say 2006, you 9 A. You're going back a long ways. know, it was —- we would get increment ~ increases of 10 Q. Yes. five or $10,000 each year. So | would say 2006. So it a A. I'm trying. graduated, you know, progressive. 12 Q. Your relationship goes back that far. That's Q. Okay. Do you remember the progression if we 13 why I chose that year. start at 18917 Do you remember roughly what the 14 A. Right. progression was up through 2607/2008, when you were 15 Q. Okay. Did you get bonuses even back that far? making $200,0007 16 A. Yes, sir. A. No, | wouldn't know the progression, 47 Q. And do you remember what your bonuses were Q. Okay. Do you remember what you were making 18 — approximately? from -- and was NES, LLC the company paying you back in} 19 A. 5,000. | mean, that was kind of the — the 19917 20 starting point. A. Idon't know. | don't remember. Let me say 23 Q. Okay. In addition to monitary bonuses, were it that way. | don't remember. 22 there ever gifts or any other type of compensation that Q. Okay. When ~ how long do you remember NES, 23 NES, LLC or Jeffrey Epstein provided you? LLC being the payer of your check? 24 A. Yes, A. Personally, two years, because I've never seen 28 Q. And is that over the span of the 18 years?

Larry Visoski weatinueune 21 Yes. Okay. Teit me what some of those items are. ji remember one specifically was a poo! heater. Excuse me? A pool heater. When was that? 1995-ish. Okay. Why did you get that? . | had built a pool and | didn’t have a heater and he kind of laughed at me saying, “How can you have a; pool without a heater?” So he says, "You ought to get a heater.” Q. Where were you when you had that conversation? A. Inthe airplane, Q. How did he know that you had built a pool? A, dust in general conversation. Q. You were having a conversation with Jeffrey Epstein? A. Yes. Q. And this is something that was happening on the airplane, this conversation? A. During the flight. Yeah, It would have been fike on cruise or something. Q. Okay. When you say “during the flight,” does that >prpraro>r 22 A. Again, you're going back a long ways. Q. understand. We're talking about 1995 right now. A. Yes. Q. You're having a conversation with Jeffray Epstein. Wha is flying the airplane? A. The auto pilot and there's two crew. Q. Okay. So are you back in the back portion or is he up in the cockpit? A. Upin the cockpit. Q. Okay. Jeffrey Epstein sometimes comes up there? A. Just, yeah, in between the two pilot seats. Q. Allright. Is that something that was typical, to have conversations like that? A. Mm-hmm. Q. Yes? A. Yes. No nodding. Q. And would those conversations be directed mainly with you or with the other pilots as well? A. Mainly with me. Q. | mean, you've kind of been described as the main guy or the main pilot. Wouldn't you consider that! pretty much your role, right? A. Well, that's chief pilot. 1 2 a 4 5 6 A 8 9 10 11 12 13 i4 is 16 aT 18 19 20 1 2 3 4 + 6 7 8 9 10 aL 12 13 14 is 16 17 18 19 20 21 22 23 24 25 October 15, 2009 23 Q. But more so than that, if there's going to be a casual conversation about a pool or a pool heater or whatever, it's going to be with you most likely if he's. going to be talking to pilots, right? MR. CRITTON: Form. THE WITNESS: Right. BY MR. EDWARDS: Q, Okay. And you feel like over the years your relationship with Jeffrey Epstein has been pretty good? A. Yes. Q. And you have been closer to him over the years| a8 you've grown to know him? MR. CRITTON: Form. THE WITNESS: The sams throughout the same| year. We never got any closer than 1991 than tam with him now. 'm very professionat at what t do and know the line between being professional and thinking you're somebody's buddy. BY MR. EDWARDS: Q. Okay. Se that’s not something that you think you are? You don't think you're his buddy? A. No, sir, Q. Do you consider yourself his friend? A. i believe so. Q. Do you think he considers you his friend? 24 A. I think so. Q. Allright. What makes you think that? MR. CRITTON: Speculation. THE WITNESS: He's always been kind and respectful. BY MR. EDWARDS: Q. Ever invited you to dinner? A. No, sir, Q. Have you ever associated or socialized with him during the day at any of his homes? A. Only during a business reason. Q. Okay. What are the other -- are the places that you believe that Mr. Epstein owns? | know we've talked about this Manhattan -— the Manhattan house. I've read the articles about it, the Paim Beach mansion. But what other places are you familtar with that Mr. Epstein owns? MR. CRITTON: Form; predicate, speculation. THE WITNESS: To answer it honestly, | don’t know specifically that he owns any of the residences, to be honest. | would only assume that he owns. So if you want me to answer honestly, F don't know that he owns any of the other. BY MR. EDWARDS: Q. Okay. Well, what would be the basis for your

Larry Visoski October 15, 2009 25 27 1 assumption that he owns the home in Palm Beach? 1 Q. Are those private airports? 2 A. He goas there, but I don't assume -- you don't 2 A. Public. 3 have to own a house to go to it. 3 Q. Public, okay. Are there any private landing 4 Q. And not only does he go there, you're aware 4 places where you would land any airplanes in New Mexico4 5 that he spends the night there; he resides there s A. There are. 6 sometimes, correct? 6 Q. That you have landed -7 A. Yes. 7 A. That have, 8 Q. When he's in Palm Beach, that's where he -- 8 Q. ~ his airplane? 9 A. He sleeps. 9 A. Yes. 10 Q. - sleeps? Right. When he's in New York, do 10 Q. Where? 11 you know where he siseps? a2 A. We have a 4500-foot strip on the ranch. 12 A. No. 12 Q. When you say “we,” yourself and somebody? 13 Q. But you've been to a particular house in New 43 A. The company. 14 York that's a very large house that we've all read about 4 Q. What company? 15 that you picked up luggage at, right? 4s A. Well, { should say — t see where you're going 16 A. Yes, sir. 16 with that. The ranch owns — whoever owns the ranch, 17 MR. CRITTON: Form. 17 The ranch has a runway on it. 18 BY MR. EDWARDS: 18 Q. Okay. And you've landed an airplane on that 19 Q@. And that home, do you know that — | know that 19 runway? 20 you're saying that you haven't done a public record 26 A. That ranch, yes. 21° search to make sure that Jeffrey Epstein owns it. 21 Q. How many times do you think you've landed 22 A. Yeah. 22 there? 23 Q. But you assume that he does? 23 A. Ten. 24 A. Assuming. 24 Q. Allright, And have you been inside his as Q. That's where he sleeps when he's in New York?} 25 ranch? 26 28 1 MR. CRITTON: Form. L A. Yes. 2 THE WITNESS: | assume. 2 MR. CRITTON: Form to the last question. 3. BYMR. EDWARDS: 3 MR. REINHART: Can you clarify, the physical 4 Q. That's where his luggage is when you pick it 4 ranch or the residences or the structures on the Sup? a ranch? 6 A. Doesn't mean he owns it. 6 MR. EDWARDS: | don't have a good visual 7. Q. Right. But that's where it is? 7 appreciation for it. 8 A. Yes, sir. 8 BY MR. EDWARDS: ¥ Q. Do you know of anybody else who owns that hom 9 Q. Why don't you describe it in your words what 10 in New York? 10 this ranch that we are talking about looks like. And LL A. No. 11 Fve heard it referred to as the Zorro Ranch. Have you 12 Q. Okay. Have you been to his ranch in New 12 heard that? 13 Mexico? 13 A. [ve heard that. 14 A. Yes. 14 Q. That's the ranch we're ail familiar with, 15 MR. CRITTON: Form. 15 — we're talking about where the runway is and everything 16 BY MR. EDWARDS: 16 else? WwW Q. How many times have you been to his ranch in 17 A. Yes. 18 New Mexico? 18 Q. Describe it in your own words, the landscaping 1s MR. CRITTON: Form; predicate. 19 of this ranch. What do we have on it? 20 THE WITNESS: A guesstimate, fifty times, only 20 A. There is a house up on the hill, a large 2i due to the fact that we would fy there. 21 house. 22 BY MR. EDWARDS: 22 Q. How big? 23 Q. And where would you land? 23 A. Big. I've read 40,000 square feet in the 24 A. Depending upon the aircraft, ether 24 paper. 28 — Albuquerque or Santa Fe. 25 Q. Have you been to it?

Larry Visoski 29 A. Yes, Q. Does that seem like it's feasible, approximately 40,000 -A. | think $0, yes. Q. What else do we have on it? A. There is a compound that has kind of motel room type — they call it bunkhouse. Q. Where's the bunkhouse located? A. Atthe entrance to the ranch, Q. Okay. And what is that primarily used for? A. For the people that work on the ranch, they reside there. {t's alse a place where anybody that traveled on the airplane would stay. It's kind of like, you know, a hotel room. Q._ And how far is that from the first house that you described, the 40,000 square foot house? A. It's probably 4 miles. Q. Okay. So the Zorro Ranch is a rather jarge area of property? A. Yes. Q. And how many times ~ | know we just talked about how many times you've been in the house, but how} 22 Q. Why did he do that? many times have you been on that ranch in New Mexico, the Zorro Ranch? A. Thirty to fifty times over the years. That's 30 a quesstimate. Q. Is that over ~ when was the first time that you went to that ranch? A. A guess, | don’t know when it was, actually, our first trip, but 1995/94. Q. Okay. And do you believe Jeffrey Epstein and/or a corporation owned or controtled by him to be the sole owner of that ranch? A. I don't know any of those details. Q. Have you ever talked to Jeffrey Epstein about who owns that ranch? A. No. Q. Do you know of anybody else who may own thal] 13 you free and clear? ranch? A. Not to my knowledge. Q. Other than Jeffrey Epstein, do you know of anybody else who regularly stays there when they'te in New Mexico? A. Not to my knowledge. Q. Doas Jeffrey Epstein stay there when you're in New Mexico? A. He has. Q. And he has a key to the place? A. I don't know if there's a key. Q. One way or another, he gets in, right? October 15, 2009 31 A. Yes, sir. Q. And he sieeps there? A. Yes. Q. Okay. A. Lassume he does. Q. You assume he sleeps? A. Ido, I think, Q. Okay. MR. CRITTON: This is really 16 BY MR, EDWARDS: 11 Q. Other than the pool heater in 1995, have you 12 ever received any other gifts on top of the compensation’ 13. from Mr. Epstein? 14 A, did get land on the ranch to build a house. Sern Eewne 15 Q. What do you mean you got land on the ranch? 16 A. He deeded me land to build a home. 17 Q. When was that? 18 A, Ten years ago at least. 19 Q. Do you know if he's ever deeded anyone else in 20 this world land on the ranch to build a home? Zu A. Not to my knowledge. 23 A. We would vacation out there and my wife fell 24 in love with New Mexico and we were looking for property. 32 Q. And did you talk to him about that? A. Yes. He knew! -- he was aware | was looking for a home and he says, "Well, | have so much land, | could give you a spot to build a home on.” So | built a house. Q. So how long has a home actually been on that property? A, Nine years. Q. And that's a home that you own? 10 A. Yes, sir. 11 Q. And that's a home that was -- when | say “you 12 ownit,” is there a morigage on it or did he give it to COIR AWNE 14 A, No, no, | paid for the house. I made payments 15 onit. 16 Q. Albright. So what did he actually give you? 7 A. 40-acres of land. 18 Q. That you did not have to pay for? 19 A. You know, I'd have to go back and look. | 20 think itwas ~ | had to pay something for it. I don't 22 remember. 22 @. How often have you visited that piece — that 23 home that you own? 24 A, My wife would spend summers out there with the kids.

Larry Visoski 24 25 wovnauaune 10 il 12 13 14 1s 16 17 18 19 20 an 22 23 24 25 October 15, 2009 33 Q. Okay. But that's on the Zorro Ranch? A. Yes. Q. So in addition to the 50 or so times you've been to the Zorro Ranch, you've been to your property that's on the Zorro Ranch? A. Yes, which over the years, its once-a-year visits. So | mean, it is included in the 50 times that I've been there. Q. Okay. And did you have a conversation with him that led to him giving you or gifting you 40-acres of land? A. We talked about it because he knew f was looking for a home out there. Q. Okay. in gifting you that land, did you consider yourself at that point in time to be more than just his pilot, as more af a friend? A. No. You're using the word "gifting." { paid for the land. | don't recall what it was. But you use the word “friend.” | don’t know that a — sure, he was a friend. | mean... Q. Well, did he give Dave Rogers any land out on the New Mexico ranch? A. No. Q. Okay. When you say you paid for it, | thought that { asked that question, "Did you pay for the 34 40-acres? ¢ thought your answer was, “I don't know, ¥'d have to go back and took." Are you saying now that you did pay for that land? A. {don’t remember. Hf there was a sum of money, it was just for, you know, the legal purpose of a transfer of ownership of the fand. Q. Okay. if twas 2 substantial amount of money, that's something that you would have remembered? ‘A. Oh, exactly. No, it was not a substantial amount. Q. Okay. Do you remember approximately how much money you had to give Jeffrey Epstein for that tand? A. i would only be guessing. it might have been five dollars. To my knowledge, | don't remember. Q. Okay. So when I'm saying he gave you the land, he may have actually given you the land? A. Sure. Q. Okay. And to the best of your knowledge, he's never given anyone else land out there? A. Notto my knowledge. MR. CRITTON: Form, BY MR. EDWARDS: Q. Allright. How big is this house that you built on the ranch? 35 A, 1800 square feet. Q. Were you ever at that house at the same time when he's at his house that's on that Zorro Ranch? A. Yes. Q. Allright. We started back in 1991 with you making around $55,000 a year and that has progresser over time to a point where in 2007 you were making $200,000 a year. | don’t want to go through every single year, that would take a really long time, But the progression, was that on a yearly basis normally or after two years or three years? A. Yearly basis. Q. Okay. And would that normally be in increments of? A. $5,000, Q, Okay. You've talked about a couple other gifts that have been given to you from Jeffrey Epstein over the years; one is 2 poo! heater in 1995 and now some 40 acres of land on his New Mexico ranch. Any other gifts you can think about? A. No other gifts. Q. Okay. | don't want to split hairs with you. You obviously thought about that answer before giving it. What other items are you thinking about that he's given to you or cut you a discount on or otherwise that 36 you feel was compensation for you working for him? A. Idrive a company car. | mean... Q. Okay. What kind of car? A. AHummer. Q. You say “a company car." That's owned by NES, LLC? A. No, | think the registration has Zorro Development on it. Q. What is Zorro Development? A. | believe that's the ranch, or at least it has the name of the ranch. | don't know what the entity is. Q. And it's your understanding that that's a company vehicle? Yes. And where is that vehicie primarily garaged? At my home. . In West Paim Beach or in the Zorro Ranch? .. No, here in West Palm Beach. . Albright. And is there onty one company vehicle that you're issued? A. Yes, sir. Q. And is that something that was — that you did not have to pay for? A. No, it's Just something | drive, | mean, it's not titled to me or anything like that. It's just a car OProror

Larry Visoski October 15, 2009 37. 39 1 that I drive. 1 Q. And which airpiane was that? 2 Q. Allright. You've worked for him tor 18 2 A. The Hawker. 3 years. | don't even know how fong the Hummer would 3 Q. Does he still have the Hawker? 4 last, but presumably, that's not the car you've had over 4 A. No. 5 the entire 18 years. Have you always had a company car?} 5 How long did he have that plane? 6 A. No, (havent, no. 6 A. Five years, guesstimats; four or five years, 7 Q. When did you get the Hummer? 7 Q, So sometime in the mid ‘903? 8 A. Probably three years ago. 8 A. Yes. 3 Q. Do any other members of Mr. Epstein's piloting 9 Q. Did you keep any type of logs or documentetion 10 {eam have company cars? 10 as to who would have been flying on that airplane if you aL A. No. 11 vansported any individuals? 12 Q. Only you? 12 A, The same logs a6 you possess now are the 13 A. Yes, 13 flight logs. 14 Q. And do you know how that decision was made to 14 Q. Okay. 15 get you a company vehicte? is A. Thaf's the standard for the industry. 16 A. No. 46 Q. So that’s something that you kept, or that 17 Q. What do you use that vehicle for? 37 Dave Rogers kept? is A, To and frorn the airport. 18 A. Dave Rogers. 19 Q. Allright. Do you use it for personal reasons 19 Q. Okay. If there are any documents out there 20 also? 20 with names of passengers on any of the fights involving 24 A. fguess, yes. 21 planes owned or controlled by Jeffrey Epstein and/or his 22 Q. I mean, that's your primary vehicle? 22. companies, those would be documents in the possession of 23 A. Yes, or | drive my wife's car. 23 Dave Rogers and not yourself? 24 Q. Which is? 24 A. Oh, the corporation actualty, thay belong to. L 25 A. Type of car? 25 Q. Okay. 38 40 1 Q. Yes. 1 MR. REINHART: That was a compound question. 2 A. AMercedes. 2 You might want to split itin half. 3 Q. And is that something that was also a gift 3 MR. EDWARDS: Okay. 4 — from Mr. Epstein? 4 BY MR. EDWARDS: 5 A. No, sir. s Q. What documents do you believe exist that 6 Q. What type of Mercedes is that? 6 indicate names of individuals that have been passengers 7 A. AML 430, ten years ald. 7 on Mr. Epstein's airplanes? 8 Q. Albright. Are there any other items -- 8 MR. REINHART: Are we going back all the way 39 company cer, the land in New Mexico, the pool heater -- 9 from ‘91 to the present? 10 any other items that Mr. Epstein has given you over time 10 MR. EDWARDS: Sure. 11 aS compensation or reward or anything else? il THE WITNESS: You're talking about the Hawker? 12 A. No, sir. 12 BY MR. EDWARDS: 13 Q. And your only income is from Mr. Epstein or 13 Q. Any airplanes. What documents would there be? 14 his companies? 14 A. There would be the same: Flight logs and 4s A. Correct. 15 passenger manifests would exist, 16 Q. Okay. And it's been that way since 1991? 16 Q. And are either of those required? v7 A. Yes, sa A, The fight iog is required for the aircraft to 18 Q. How did you meet Mr. Epstein or become: 18 track times and landings. 13 — invoived with him in 1991? 12 Q. Ard in the flight log, is # required that you 20 A. We heard at the airport that Mr. Epstein was. 20 — designate the names of the passengers? 21° purchasing an airplane when Dave Rogers and myself wer¢ 21 A. No. 22 iiving in Columbus, and we had the opportunity to 22 Q, That's just something that Dave Rogers did on 23 interview with him, and we did and got the job. 23 his own? 24 Q. And this is before he owned the airplane? 24 A. Everybody does that. it's more for Internal 2s A. Yes. 25 Revenue.

Larry Visoski October 15, 2009 Ai * Q. Okay. if something happens, they know who is 2 2 onthe plane? : 2 3 A. Exactly, weight and balance. 3 4 Q. Have you ever kept any flight lags that have 4 5 names of people on the airpiane? 5 6 A. When you say *kept,” | have filled out flight 6 7 togs or the passenger manifest, yes. 7 8 Q. By "kept" f meant maintained to where they're 8 9 in your possession either on paper or computer? 9 19 A. We keep - 10 11 MR. REINHART: Can you differentiate a flight 4 12 tog from the pilot's log that we showed you 12 13 earlier? 13 14 MR. EDWARDS: Okay. 14 15 BY MR. EDWARDS: is 16 Q._ I'm talking about -- ! don't know that it's 16 17 cated a flight log, 2 pliot’s tog or any kind of log. a7 ie A. They are different, yes. 18 19 Q. Yeah. I'm asking about, have you kept or do 19 20 you have any documentation that would indicate the names 20 21 of passengers that have flown on any of Jeffrey 24 22 Epstein's planes? 22 23 A. No. 23 24 Q. Either in the form of paper or on a computer? 24 25 A. No. 25 42 1 Q. Makes that easy. 1 2 A. Okay. 2 3 Q. In 1991, were you the chief pilot? 3 4 AL No. 4 5 Q. Somebody else was the chief pilot? 5 6 A. Yes. € 7 2. Who's that? 7 8 A. Dave Rogers. 8 9 Q. Allright. At what point in time did you s 10 become chief pilot and switched with Dave Rogers? 10 11 A. Six years ago; five, six years ago. uz 12 Q. Why? Fra 13 A. Professionalism, technique. 13 14 Q. What do you mean by that? 14 15 A. The way Dave would operate an aircraft, 15 16 Jeffrey knew the difference when | was flying and when} 16 17 Dave was flying. 17 18 Q. How do you know he knew the difference? 18 19 A. Just ~ 19 20 Q. He told you? 20 aL A. Yes. He knew the difference that if he never 21 22 came up front, he knew whe was flying, who landed. 22 23 Q. And what was the conversation that he had with} 23 24 you that resutted in you becoming chief pilot, switching | 24 25 positions with Dave Rogers? 25 43 A. Jeffrey would always critique Dave's flying capabilities, and | tried to help Dave and expiain to him what Jeffrey likes and doesn't like, And Jeffrey's aiso conveyed these likes and dislikes. And Dave maintained continuing with certain piloting techniques that were just not comfortable to passengers. And this ‘went on through the years, and Jeffrey just got tired of it one day. Q. What specifically were Jeffrey Epstein's tikes and dislikes with respect to the flight of the plane? MR. GRITTON: Let me put in a form here. But | don't know what this has to do with anything in this case, MR. EDWARDS: | understand that, Bob. MR. CRITTON: | want to use this for some ‘other depositions where we -- we've gone beyond the ‘scope. THE WITNESS: The case in point, the last straw was there was a technique called quiet flying where you would retard the throtiles well short of the runway and pretty much glide the aisplane in. Well, if you doen't do that correctly, you have to ‘spool the engines up just prior to touching down that — because you're losing air speed and it's an uncomfortable sound and feeling for the passengers 44 thinking that you're nat going to make the runway. And it was a continuous practice of Dave doing that to be neighbor friendly as opposed to being passenger-comfort friendly. BY MR. EDWARDS: Q. Okay. A. Hence, the transfer of power. Q. Has he ever discussed with you where he wants you to be, whether that is "stay in the cockpit when | have people on the airpiane,” or don't intermingle with the passengers or anything else? A. He's never stated that to us. MR. REINHART: Could you clarify which "he” you're talking about? MR. EDWARDS: I'm taiking about Jeffrey Epstein. MR, REINHART: Okay. BY MR. EDWARDS: Q. You understood that? A. Yes. Q, It's my understanding that in the -- well, teit me other than the Hawker, what other airplanes har you flown for Jeffrey Epstein? A. AGuifstream. Q. Does he still have that plane?

Larry Visoski ee, October 15, 2009 45 47 1 A. Yes, sir. 1 and who was on the flights? 2 Q. How big of a plane is that? 2 A. One flight | believe we went to Sebring and 3 A. Large corporate jet. 3. another flight we went to Nassau, Bahamas. 4 Q. How long has he had it? 4 Q. And who did you go to Nassau, Bahamas with? 5 A, Fourteen years; 13, 14 years. 5 A. fd have to look at the flight log, but / 6 Q@. And other than the Gulfstream, what other 6 think it was Sarah, Story and Nadia, | believe. | think 7 airplanes does he have? 7 that was the three passengers, to the best of my a A. When you say "he," obviously, these are 8 knowledge. 9 company-owned — 2 Q. And it's my understanding that little 10 Q@. Jeffrey Epstein or his companies, 16 St. James is an istand that Jeffrey Epstein owns or a1 A. ABoeing 727. 11 controls? 12 Q. Weil, | know that's a very large airpiane, f 12 MR. CRITTON: Form. 13 _ think that's been described by other people, so fm not 13 THE WITNESS: 1 don't Know that he owns it. 14 going to have you do that. But there's partitions in 14 BY MR. EDWARDS: 15 that airplane ~ in the back rooms of that airplane, 15 Q. Has he ever been to an island called Little 16 right? 16 St. James? a7 A. Yes. 17 A. Yes. 18 Q. Several different partitions to where if the 18 Q. And have you been there with Jeffrey Epstein? 19 pilot comes out of the cockpit, you don't necessarily 19 A. I've been there when he was there. 20 see all the passengers? 20 Q. Have you flown on an airplane with him to that ay A Yes. 21 destination? 22 Q. That's true? 22 A. No. 23 A. Yes. 23 Q. Allright. When you say you've been there 24 Q. Okay. 24 when he was there, how did that come about? 25 MR. REINHART: Keep your voice up so she can} 25 A. We flew into St. Thomas and then we flew to 46 48 2 hear you. 1 Little St. James in a helicopter. 2 THE WITNESS: Oh. 2 Q. And do you fly the helicopter as well? 3 MR. REINHART: And so Mr. Willits can hear 3 A. Yes. 4 you, 4 Q, How many helicopters are owned or controlled 5 BY MR. EDWARDS: 5S by Jeffrey Epstein and/or corporations associated with 6 Q. Other than the Gulfstream and the Boeing and 6 him? . 7 the Hawker, what other airplanes has Jeffrey Epstein 7 MR. CRITTON: Form, 8 owned over the years? 8 THE WITNESS: Af this time, one. 9 A. That is it. 9 BY MR. EDWARDS: 10 . And currently still owns — or the companies 10 Q. And has that helicopter been flown in the last 11. associated with him own the Gulfstream and the Boeing?} 11 two years? 12 A. Yes. 12 A. Just for routine maintenance. 13 Q. And in the past two years, have you flown 13 Q. And when you and -- let's say when Sarah 14 those two airplanes? 14 Kellen and Story Cowells and Nadia flew to Nassau, do 15 A. Just for routine flights to keep them foose 15 you know the purpose of that trip? 16 or, you know ~ you know what mean. 16 A, No. a7 Q. Have those two airplanes been flown by anyone j 17 Q. How long did you stay? 18 else in the last two years? 18 A, Five hours. 19 A. No. 19 Q. Did you pick anybody up there? 20 Q. Have those two airpianes been flown in the 20 A, No, Meaning passengers? 21 —_Jast two years for any reason other than routine 22 Q. Yes. 22 maintenance-type flights? 22 A. No. 23 A. We've had one -- two flights | think in the 23 Q. What happened? You landed the airplane and 24 past two years. 24 then what? 25 Q, And what were the purposes of those flights. 25 A. The passengers left. Dave and ! went and had

Larry Visoski October 15, 2009 49 51 1 lunch. The passengers showed up and we came back. 1 tohis island?” We never landed on his island. We 2 Q. Have you ever stayed at the home that is on 2 fanded in St. Thomas. 3 Little St. James? 3 Q. Got it. 4 A. No. 4 A. Swas just trying to be exact. 5 Q. Have you known Jeffrey Epstein to stay at that 5 Q, Thank you, 6 home? 6 A. It's a small island. ? A. | don't know that for @ fact. 7 Q. Okay. So how is it that when Mr. Epstein 8 Q. Okay. Do you believe that he is the owner or 8 wants to go to Little St. James, what is the path that 9 controller or has some interest in the home or the 9 you take to get actually to the isiand of Little 10 istand of Little St, James? 10 St. James? iL MR. CRITTON: Form. il A. [don't understand the question. 42 THE WITNESS: i have no knowledge of that 12 ©, Weil, you just told me you fly the airplane to 43 being a fact. 13 St. Thomas? 44 BY MR, EDWARDS: 14 A. Right. is @, And you have no belief that that is a fact? 15 Q. And then wrat? 16 A. Bxactly, 16 A. Then sometimes | would go get the helicopter a7 Q. When you say you've been there when he was 17 or he could also take a boat to the island. But 18 there, how many times has that occurred? 18 normally the helicopter's located on St. Thomas. I'd as A. Estimating, a hundred times. 19 fire up the helicopter, come pick him up, drop him at 20 Q. Okay. 20 the island and § come back to St. Thomas. 24 A. Trying to give an honest answer. 21 Q. And when he stays on St. James, you drop him 22 Q. Okay. And in the approximate --I'm not going | 22 — offon St. James. | suppose you're going to tell me you 23 to hold you to a hundred times, but in the approximately! 23 don't know if he stays there or not? 24 ‘hundred times — 24 A. Exactly. 25 A. Sure. 28 Q. But do you stay — 50 52 1 Q. — for what period of time are we taiking 1 A. [don't | mean ~ 2 about? 2 Q. Well, he either stays there or someone else 3 A. During what period of time? 3 picks him up in a helicopter or he swims away? 4 Q. Right. 4 A. Correct. 5 A. Let's see, when‘ did all this happen? What, 5 Q. Okay. You stay on St. Thomas? 6 20077 So eight years prior to whenever he stopped 6 A. Yes. 7 flying. So... 7 Q. Okay. Is there a place that you've stayed on 8 Q. ‘98°99? 8 St James, ever? 9 A. Yeah, I guess, yes. 9 A. No, I've never. 10 Q. imean, that sounds like a right - 10 Q. So in the hundred or more times that you've 11 A. Sounds about right, yeah. Don’t hold me to it 11 been to the island, is it my understanding that each of 12 again. 12 those times you've been there to drop off Jeffrey 13 Q. All right. 13 Epstein and/or any passengers and you've immediately 14 A. You're going back a jong way. 14 left. and gone to St. Thomas? 15 Q. So from approximately the ‘98/99 time frame is A. Yes, sir. 16 when Jeffrey Epstein would fly to Littie St. James, 16 Q, You never been inside that home that's located 17 would you be the pilot? 17 on St. James? 18 A. Yes. i8 A. Yes, I've been inside the home. 19 Q. Okay. And you say that you've been there ~| 19 Q. How many times have you been inside the home? 20 thought that you just told me that you've been there the; 20 A. i mean, ten, fifteen times. 21 same time he was there, but then | thought the 22 Q. And for what occasion? 22 subsequent question was weil, were you on the fight 22 A, ve set up the theater system that's in the 23 with him, and | thought your answer was no. Maybe | 23 living room. 24 misunderstood that. 24 Q. Okay. 26 A. No, you said the question "Have you ever flown | 25 A. So it would be there to work to hook up a TV

Larry Visoski 53 ora stereo, Q. And do you know Les Wexler? A. No, I don't. Q. Have you ever met him before? A. Ihave met him. Q, Do you know of any relationship between Les Wexler and Jeffrey Epstein? A. | don't know what — to what extent they have a relationship, no, Q. Do you know if they know one another? A. | don't know that for a fact. They talk to one another, so would assume. But | don't know to -Q. How do you know they taik to one another? A. I've seen them speak to one another at the foot of the airplane. Q. Allright. Have you ever flown the airplane — any of the airplanes with Les Wexler as @ passenger? A. Ne. Q. Have you ever flown the airpianes with Sarah Kellen as a passenger? A. Yes. Q, And do you know Sarah Kellen? A. Yes. Q. And for how tong have you known Sarah Kellen? 54 A. I'm guessing, six years. | mean, don't hold me to it. |'m not the greatest on length of times, but six, seven years, | think. Q. How did you meet her? A. {guess | was introduced. She was on a flight of ours. Q. You were introduced to her by whom? A. She may have introduced herself. { mean, you're going back a ways. | don't know the official introduction, how it went, Q. And to your knowledge, what is her is she associated or affiliated in some way with Jeffrey Epstein? MR. CRITTON; Form. THE WITNESS; | would assume so. | don’t know to what level or what actually her job description is. BY MR. EDWARDS: Q. Alltight. Well, how many flights have you flown where she and Jeffrey Epstein Rave been passengers together on one of the airplanes that we've been discussing? A. d only be guessing again. Q. We're talking hundreds of flights, though? A. Sure, sure, a lot of flights. wWeranuneune 28 ‘somebody who has common sense. It seems ike someb: that knows Jeffrey Epstein? BY MR. EDWARDS: business relationship thers or a personal relationship there, from your observations? airplane, my focus is forward and flying safely. So! don't-- you know, I'd only be guessing at either one of those two. Kellen? have you spoken with her elsewhere? down the street in New York. I mean. yes. she calf you? Kellen? air her s a departure. A Q. A. Q A a A Qa v2 A. Was actually — actually, it was for the helicopter. Now that I'm thinking about if, the October 15, 2009 55 Q. itseems to be — i mean, you seem like MR. CRITTON: Form. Q. Correct, Sarah Kallen? A Yes. Q. Allright. And do you believe that there is a A, [only be speculating. When they get on the . Okay. Have you ever socialized with Sarah A. No. Q, Other than speaking with her on the airplane, A. Over the phone, in passing, | mean, walking Q. Why would you calf Sarah Kellen or why would A, She would call me to schedule the aireratt for 56 Q. And have you ever called her? A. Yes. Q. When's the last time you talked to Sarah A. Aweek ago. Q. What was the occasion? A. We were discussing carpet for one of the craft. And where was she when you were talking with] don't know. It was over the phone. Did she cail you or you call her? No, i cafled her on her cell. Okay. And that's a New York number? i don't know. if's on speed dial. Do you have your phone with you? Yes. Could you tell me what that number is? Sure, Thanks. Sure. (917)855-3363. Which airplane were you discussing carpeting pPPrOrre

Larry Visoski October 15, 2009 57 59 helicopter, 1 Q. How fong have you known Nadia Marcinkova? Q. In the last two years, did you tell me the 2 A. I don't know, five years. A guess again, helicopter has flown? 3 four, five years. A. Yes. 4 Q. Do you know what her relationship is, if any, Q. And where to? 5 with Jeffrey Epstein? A. | have flown the helicopter to Fort Lauderdale 6 A. Ido not know, on several occasions for maintenance. I've flown it to| of Q. Do you know if she knows Jeffrey Epstein? Miami. And | try to fly the helicopter at least every 8 A. would assume so. They talk. 1 would two weeks just either by myself to run it up to its 9 imagine she knows him. it's important that it keeps moving. 10 Q. And how many times has she been on the Q. Other than maintenance-type flights, have you; 11 airplane or the helicopter on fights at the same time flown the helicopter in the last couple of years? 12 as a passenger with Jeffrey Epstein? A Yes. 13 A. Many. I'd have to look at the fogs. Q. And who was on the helicopter? 14 Q, Hundreds of times? A. I flew to Miami with Mr. Epstein. 415 MR. CRITTON: Form, Q. When was that? 16 THE WITNESS: Sure. A, twas a couple weeks ago or a month ago, | 17 BY MR. EDWARDS: think. 18 Q. Ifyou were going to, as somebody who has beer} Q. For what? 18 Jeffrey Epstein's pilot for 18 years, tell me today who. A. Sorry? 20 the five closest people are to Jeffrey Epstein, would Q. For what occasion? 21 Nadia be one of them? A. | think he had a meeting with his attorneys in 22 MR. CRITTON: Form. Miami. 23 THE WITNESS: ''d only be guessing and Q. Teday is October the 15th. Is this during the 24 speculating. ! have no idea. month of October that you had this flight in the 25 58 60 helicopter with Mr. Epstein? 1 S8YMR. EDWARDS: A. I'd have to look at the book to be exact for 2 Q. Okay. Well, as his pilot and the person who you. 3 travels with Jeffrey Epstein on the majority of his Q. Okay. But it's either the end of Septernber or 4 flights, who are the people who travel most frequently the beginning of October? S with Jeffrey Epstein? A. Yeah. x 6 A. I'd have to look at the logs. Q. How do you know that he was meeting with his 7 MR. REINHART: Can we get a time period? attorneys? 8 BY MR. EDWARDS: A. believe that he had mentioned that he was. 9 Q. inthe last ten years, which people travel meeting his attomeys. 10 most frequently with him? Q. Did he tell you why? i A. ('d have to look at the flight jogs to give A. No. 12 you an accurate answer. Q. Why did he teil you he was meeting with his 13 Q. You can't give me one single name of somebody: attomeys? Did you ask him? 14 — who you would say is a frequent fiyer? A. No. é 5 A. Sarah. Q. Okay. That's just something that he said to 16 Q. Sarah Kellen? you in conversation? 7 A. Yes. A. Yes, sir. 18 Q. Anybody else? Q. Was there anyone else on the aimplane besides; 19 A. Nadia. you and Mr. Epstein? 20 Q. Nadia Marcinkova? A. Yes. 2h A. Yeah. Q. Who was that? 22 Q. Okay. Anybody else? A. Nadia. 23 A. Just mainly those two. Q. Nadia who? 24 Q. How about Ghislaine Maxwell? A. Nadia Marcinkova. 25 A. Not for some time,

Larry Visoski October 15, 2009 OIA eune © 11 12 13 14 as 16 1? is a9 20 21 22. 23 24 Oey AGEwrHe 10 al 12 13 14 is. 16 7 18 19. 20 au 22 23 24 61 63 Q. What's your understanding between the 1 Miami? relationship of Ghislaine Maxwell and Jeffrey Epstein? 2 A. Twenty-five minutes. A. [don't really know. 3 Q. And did they taik to one another during that Q. Allright. So when you say you're guessing 4 flight? that Nadia Marcinkova and Sarah Kellen know or are $ A. No. associated with Jeffrey Epstein, that guess is being 6 Q. They were both compietely sitent during that made on the ~ with the observation that they have been: 7 flight? frequent flyers with Jeffrey Epstein on more than 8 A. Yes. hundreds of flights on his private plane? 9 Q. Okay. is that typical when they are on A. Yes, that's what I'm basing it on. 10 flights together, especially with the helicopter, where Q, And do you know where Nadia Marcinkova is 11 you're in pretty close quarters, that they would absiain staying these days? 12 from speaking to one another? A, No. 13 MR. CRITTON: Form. Q. Do you know what car she's driving these days?; 14 THE WITNESS: Yeah, it would be typical. It's A. No, fdon't, iS very noisy and communicating in a helicopter is, Q. Okay. Do you know if she's living with 16 you know, not that comfortable, Jeffrey Epstein these days? 17 BY MR. EDWARDS: A. I don't know that. 18 Q. Over the last five or six years that you have Q. Do you know how Nadia Marcinkova met Jeffrey, 19 — known or been familiar with Nadia Marcinkova, have yot Epstein? 20 heard her and Jeffrey Epstein conversing with one A. tdon't. 21 another? Q. Were you on an international flight bringing 22 A. Ive heard them conversing, but if you ask me her into the country from some other country at any 23 what they had said, I could say it~ | wouldn't even time? 24 know what they had said to each other. I've seen them A. | don't know. 25 _ talking to each other. 62 64 MR. REINHART: Can we clarify? You mean with x Q. But you don’t remember a single specific Mr. Epstein or -- 2 conversation between Jeffrey Epstein and Nadia MR. EDWARDS: No. 3° Marcinkova? BY MR, EDWARDS: 4 A. An honest answer, no. Q. Did you ever bring Nadia Marcinkova from some 5 Q. Okay. And the same for Sarah Kellen; have you foreign country into the United States? 6 seen or -- have you seen Jeffrey Epstein speak with A. I'd have to took at the log books, honestly. 7 Sarah Kellen? Q. That's not something you remember? 8 A. I've seen him speak with her, yes. A. No. Imean, she ~ | think she's been on 9 Q. Can you tell me a single specific conversation Europe trips with us, and | think she's returned from 10 that you have overheard between Jeffrey Epstein and Europe with us, but 1 could not say that honestly. 11 Sarah Kellen? Q, On this recent helicopter flight with Nadia 12 A, One thing that comes to mind would be make Marcinkova and Jeffrey Epstein, did you talk with them 13 sure we have Oreo cookies on the airplane. it would be during that flight? 14 something completely nonchalant. A. No. 15 @. Okay. And do you know or have reason to know Q. Where did the flight go from? And obviously, 16 — of any employment relationship between Sarah Kellen and it landed in Miami, but where did you leave from? 1? Jeffrey Epstein? A, West Palm Beach. 1 A. Shave no knowledge of any of that. Q. And did Nadia and Jeffrey Epstein arrive 19 GQ. Do you know if Sarah Kellen works for Jeffrey together? 20 Epstein? A. You know, I don't remember. | was out at the 23 A. Ido not know. helicopter and | think they both started walking up. So | 22 Q. Do you know if Sarah Kellen schedules massages | den’t know if they came separately of not. | was 23 Sor Jeffrey Epstein? already at the helicopter. 24 A. Thave no idea, Q. How long is that flight from Paim Beach to Q. Has Jeffrey Epstein ever indicated to you that

Larry Visoski 65 he is fascinated or infatuated or appreciates or loves or likes massages? A. | have no knowledge of that. Q. Ali right. How about Ghislaine Maxwell, has she ever talked to you about massage therapy or have you: ever overheard her talking about that? A. No. Q. You certainly read the papers over the last couple of years, correct? A, Not on my top ten fist. 1 mean, I've read 2 couple articles, but I'm not one ta focus on that so much as some peopte would. Q. Okay. When the investigation about Jeffrey Epstein came about, the criminal investigation ~ youre aware that's what I'm talking about, right? A. Thatwas last year? Q. Well, it was a coupie years ago. A. Right, okay. Q, Did you speak with Jeffrey Epstein about that investigation? A. No. Q. Were you told not to speak with him about that investigation? A, | think we knew ourselves that we weren't — it wouldn't be proper to even bring it up. 66 Q. Allright. When you read in the newspapers the allegations that Mr. Epstein was involved with numerous underage girls for sexual reasons, were you} surprised? A. I didn't believe it. Q. Do you believe it today? A. t don't believe it. Q. You don't believe that Jeffrey Epstein was. invotved with underage girls in a sexual way? MR. CRITTON: Form. THE WITNESS: You're asking for my opinion, and | don’t think my opinion is relevant in that matter. BY MR. EOWARDS: Q. [think it's relevant. Can you just tell me whether today you believe that Jeffrey Epstein has engaged in sex with underage girls? MR. CRITTON: Form; speculation, irrelevant, always. THE WITNESS: It's irrefevant. BY MR. EDWARDS: Q. I need an answer. A. {don't believe he had sex with underage women, Q. Or engaged in any sexual acts with underage CRYHVSWNE October 15, 2009 oF women? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARDS: Q. You think that this is just a story that a bunch of underage women have made up? A. Speculation. MR. CRITTON: Objection, Now its argumentative. Who gives a darn what he thinks one ‘way or another? If he has personal knowledge -~ MR. EDWARDS: You'te objecting to the form? MR. CRITTON: it's argumentative. MR, EOWARDS: You're objecting to the form? MR. CRITTON: Yes. MR. EDWARDS: Okay. BY MR. EDWARDS: Q. [s that something that you believe that a burch of women — some of which know each other, som don't, some of which have been on the airpfane and some which haven't — made this up, that Jeffrey Epstein engaged in some sexual conduct with them? MR. CRITTON: Form. THE WITNESS: What | believe doesn't matter in this case, does it? 68 BY MR. EDWARDS: Q |need an answer. Do you believe it? Do you ‘believe these girls made this up? MR. CRITTON: Form. MR. REINHART: I'm going to instruct him not to answer. Move on. MR. EDWARDS: Is there a privilege that we're asserting? MR. REINHART: No, it's irrelevant. It's harassment and not likely to lead to discoverable evidence. MR. EDWARDS: I'm going to put on the record right now that it is -- we are allowed discovery into. a RICO count. We are also allowed discovery into the intent of Mr. Epstein in developing a ctiminai enterprise designed to sexually expicit and sexually abuse underage girls. We believe that in doing so, he associated intentionally with people of similar beliefs that sex with underage girls is okay, and that there have been many discussions with this witness, as well as many other witnesses with -— to insure his protection from law enforcement that they not answer these specific questions. And thus, the opinions and beliefs of all of these witnesses that we are

Larry Visoski 69 alleging associated with this criminal enterprise are certainly reasonably calculated to lead to the discovery of admissible evidence. And if you're still instructing the witness, based on that proffer, not to answer any of these questions, I'm going to continue to ask the questions and you can instruct him not to answer and we can go to the Court. MR. REINHART: My response is to his opinion whether people making allegations in this case are colluding or making up a story is irrelevant to what you just said. So | am going to instruct him not to answer any question that goes to his opinion of someone else's motivation or the truth of facts to which he has no knowledge. So yes, I'm instructing him not to answer. MR, CRITTON: Let me add in my part, is that | think -- you're certainly not only capable to ask questions with regard to what his personal knowledge is, and if he knows something or he has; reasonable basis for it; certainly you are entitled fo that information. | think you've asked those: questions and he’s given you straightforward answers as to what he knew or what he didn't kri under those circumstances, And as to what his 70 thoughts are on something which he has no factual basis or even an assumption to know one way or another is irrelevant. That's ultimately for a fact-finder in this case. ‘While it's interesting, it's argumentative and { don't think he's - 1 mean, do it on a question-by-question basis. if he has knowledge, that's great, but to argue your case with this witness or any other witness doesn't serve a purpose and | think is, you know — | think it's not a good use of our time, fil put it that way. But you know, you can go ahead and ask. MR. EDWARDS: | can ask the question and if the witness is being instructed not to answer, we'll let a judge decide whether he needs to answer the question and whether it's discoverable or not. MR. REINHART: Absolutely. Make your record. BY MR. EDWARDS: Q. Do you have any reason to believe that Jeffrey Epsiein engaged in sexual activity with underage women? A. thave no reason to befieve. Q. Okay. So as you sit here today, based on your 18 years of knowledge, experience and observation of Jeffrey Epstein, is it your belief that he has not hag sex or engaged in sexual activity with underage women? October 15, 2009 71 A. It's an opinion, and I believe that he has not. Q. Okay. Isn't it true that at some point in time you learned that Jeffrey Epstein has ~ strike that. MR. CRITTON: When you ultimately get to a good piace to break, will you let us know? MR. EDWARDS: Let's break now. (A break was had at 11:26 a.m.) BY MR. EDWARDS: Q. Allright. Eighteen years of being a pitot for Jeffrey Epstein and in terms of being able to name somebody that you would say you've observed with Jeffrey} Epstein and would classify that person as Jettrey Epstein's fiend, can you name anybody? A. Nadia, Sarah; just people that we see routinely on the airplane. Q. That's peopie you see routinely in the fast five to ten years, right? A. Yes. Q. Prior to that time, anybody that you've noticed as Jeffrey Epsiein's friend may be Ghislaine Maxwell? A. What time frame? Q. is that a person that at some point in time 72 you would classify as Jeffrey Epstein's friend? A. [would classify it. | don't know if it's true. Q. But that's only because they were on the airplane together? A. Yes. Q. Do you know what Jeffrey Epstein does for a Jiving in your 18 years of observing and talking with Jeffrey Epstein? A. No. Q. Noidea? A, No, |. Ever asked him? . No, actually. . Ever been curious? Sure. Ever done anything to satisfy that curiosity? .. if you mean Google it, not really, actually. I mean, | really have not, Q. Okay. So in 18 years of traveling and being the pitat and driving -- and taking this person, Jeffrey Epstein, from one property in New York to New Mexico ani Florida and around the world, you have no idea what he does in terms of how he makes money? A. No, sir. rPOPOPD

Larry Visoski Coy Hee wne 10 12 13 14 15 16 Wy 18 is 20 22 22 23 24 25 OMAHHRYHE —-+> October 15, 2009 73 75 Q. twas produced this flight log - tell me if 1 Q. But it’s evident that the plane is being used, I'm using the wrong term. What is this called, this 2 at least for this time period, January of 2002 through book that I've bean provided by Dave Rogers? 3 2005, on a fairly regular basis. | mean, we're looking A. I've never seen that book. 4 at January 6th, 11th, 13th, 13th, 14th, right? Q. fillet you see it. I don't know that it was 5 A. Ub-huh. always in a book, 80 maybe that's why you haven't seen 6 Q. | mean, is that something that you would say it. Tell me what we're looking at, 7 accurately refiscts the amount of use of Jeffrey A. Well, judging with the name at the bottom, | 8 — Epstein’s pianes? believe this is Dave's flight log, log book. 9 A. Yes. Q. didn't know if it was called a flight og. 10 Q. So he travels quite frequently? A. Pilot log book, how's that? That's the al A. Yes. appropriate name. 12 Q. And he travels with many different people, Q. ttwas marked as Composite Exhibit 1 in 13 right? Roger's deposition, as indicated by the exhibit sticker. 14 MR. CRITTON; Form. We'll mark it the same in your deposition as weil, as ‘THE WITNESS: Yes. MR. CRITTON: Why don't you refer to it as 16 MR. CRITTON: Can 1 ask one question? | was. his? 17 wondering what happened, who has possession of now MR. EDWARDS: Fine. 18 what's the original Exhibit No. 1 of Mr. Rogers’ BY MR. EDWARDS: 49 deposition? Did you retain it? Q. ifs the pilot iag book of Dave Rogers? 20 MR. REINHART: The actual book itself? A. Yes. at MR. EDWARDS: The court reporter tock it, Q. And the years provided in this book are 2002 22 right? through 2005; | can represent that to you. I'm goingto j 23 MR. CRITTON: The one marked as an exhibit, ask you about certain people that David Rogers wrote 24 did you keep that? down as being on the airplane and I want to ask you if 25 MR. REINHART: This is it. 74 76 you know who they are. This person right here is Cindy: 1 MR. EDWARDS: This is it? Lopez. It seems like she flew on numerous flights. Do 2 MR. CRITTON: Whe took it from the deposition you know who that is? 3 the other day? A. No. [heard the name, but I don't know who 4 MR. EDWARDS: | have this one right now. that is. s MR. REINHART: That's the only copy? Q. Allright. Is that somebody that you remember 6 MR. EDWARDS: Okay. seeing on any of the flights that you were on? 7 MR. CRITTON: So you took the original? A. What year are we talking about here? I don't 8 MR. EDWARDS: Apparently. it has the original remember. 9 sticker. Q. Well, this is January 2002, You'd probably 10 MR. CRITTON: When I say “the original,” the know how to read this book a little bit better than me, 41 original copy. Would you have someone recreate 0 1 don't know. 12 what you've got and send it to us so we have It? A. He keeps his a lot more current, so | know the 13 MR. EDWARDS: Sure. In fact, why don't | wait name. If she waiked in here right now, | would probabl: 14 until 1 get the whole thing and I'l copy alt the look right through her, to be honest. 15 pages and send it to you instead of piecemeal. Q. Do you know what affiliation or relationship 16 MR. HOROWITZ: You mean before the transcript} she had with Jeffrey Epstein? 17 comes? A, No, 18 MR. EDWARDS: We can copy it. Q. Okay. There are various -- each row i'm told 19 MR. CRITTON: If you give it to me, Tit copy by David Rogers is a different flight and it indicates 20 it and send it back to you, where it takes off from and where it lands, et cetera. 22 MR. REINHART: f have a copy. It just doesn't There's a iot of other information, especially over on 22 have the exhibit sticker on. this side of the page that Pm not familiar with, nor do 23 MR. EDWARDS: That's what was told to me the (need te be. 24 other day, that’s why I took it. A. Right. 25 MR, CRITTON: FE want something — | just con't

Larry Visoski oy 1 want to — if you give me a copy, I'll puta 1 2 sticker on it. 2 3 MR. REINHART: Or just copy the page that has} 3 A the exhibit sticker on it. 4 5 MR. CRITTON: Sorry. 5 6 BY MR. EDWARDS: 6 7 Q. Like on this flight, we have "JE." I'm 7 8 assuming that's Jeffrey Epstein, correct? 8 9 A. Yes, Mil assume. 3 10 Q. "GM," Ghislaine Maxwell, right? 10 iL A. Yes, al 42 Q. "SK," Sarah Kellen? 12 43 A. | wouid assume, 13 i4 Q, Imean-- okay. And then this name, do you 14 15 recognize that person, Alexia? 1s 16 A. Never heard it. 16 17 @. And then Cindy Lopez? 17 1s A. Yes, 18 19 Q. You've heard that name? 19 20 A. (Ve heard the name, 20 21 Q@. Not sure who that is, though? a1 22 A. No. 22 23 @. There's only one, two, three, four, five, six 23 24 people on that flight? 24 25 A. Ub-huh. 2s 78 2 Q_ That's pretty typical of the amount of x 2 passengers that you would have on a flight? 2 3 A. Itvaried, sure. 3 4 Q. Okay. But it varied between ~ if we look a 4 5 few lines down, Jeffrey Epstein and Ghislaine Maxwell) 5 6 were the only two passengers. Certainly there were 6 7 flights ike that as well, right? 7 8 A. Mm-hmm, 8 9 Q. And so it varied from having one or two people 2 10 to six or seven peaple, right? 10 qd A. Yes. il 12 Q. What's the most people that you remember 12 13 traveling on any of Jeffrey Epstein’s airpianes? pe 14 A. Twenty-five. 14 15 Q. Okay. That would be a rarity, wouidn't you 15 16 say? 16 17 A. Oh, yeah, 17 18 Q. Because I've looked through this log. | 18 12 haven't seen any place where there were 25, but there; 19 20 are lines that have maybe eight or nine peopie listed. | 20 21 A. Right 23 22 Q. Let's see. There's a fight from 22 23 © January 15th — sory, January 17th, January 20th and| 23 24 January 22nd of 2002 that all had Cindy Lopez. That 24 25 doesn't serve to refresh your recollection as to who 25 October 15, 2009 “79 that is, does it? A. No. Q. Okay. Do you know what the purpose of her being on the airplane flight aiong with Jeffrey Epstein, Ghislaine Maxweil and Sarah Kellen would be? A. No. Q. Okay. Do you know how it comes about that Cindy Lopez gets on that fight? How does she even know} there's a flight availabie? A. [don't know, Q. Allright. Well, let's go down io somebody that we may all know a little bit better, February oth, 2002, there's a flight that has Bill Clinton, four Secret Service agents and then instead of listing names oF initials or anything else, it's just listed as two males, one female, Jeffrey Epstein, Ghislaine Maxwell, ‘Sarah Kellen and | forget who Dave Rogers told me “AP™ is. Do you remember who that is? A, No. Q. Okay. Either way, how is It that someone like Bill Clinton gets on a Jeffrey Epstein flight? MR. CRITTON: Form. THE WITNESS: | don't know. BY MR. EDWARDS: Q. Do you know before the fight takes off that 80 Bill Clinton's going to be a passenger on the flight? A. Yes. Q. And how do you know? How do you get that information? A. The day before I'd get a phone cail from, say, Sarah saying we're leaving tomorrow going to wherever, and sometimes she'll say who's going, sometimes she won't. On a case where President Clinton wautd be on board, we would put a fittle extra catering on board or do that little extra TLC to the aircraft. Q.. Ifit's leaving ~ this says it's feaving from MIA and where is it landing? A, HPN | believe is White Plains. Q. Okay. Do you remember that flight? A. remember being on it. Q. Well, i mean, if you look through here, obviously you had Bill Clinton on the airpiane ten or twenty times, right? A. Yeah. He's my main focus. | remember him being on the aircraft, sure. Q. Bo you remember him being on the airplane with; younger girls? MR. CRITTON: Form. THE WITNESS: No.

Larry Visoski October 15, 2009 8l 83 BY MR. EDWARDS: 1 this time with Doug Band, three Secret Service agents, Q. Okay. Do you know what his relationship was 2 Jeffrey Epstein, Ghislaine Maxwell and Sarah Kellen. Do with Jeffrey Epstein? 3 you remember that fight? A. No. 4 A. Where did we go? Q. Do you know if they were friends? 5 Q. Starts in JFK. A. Assuming. 6 A. Right. Q. Butyou're assuming why? Just because he's on 7 Q. Where is that? his plane? 8 MR. CRITTON: Do you have a date? A. Yeah. e MR. EDWARDS: March 49th, 2002. Q. Okay. So you assume that the people that are 10 THE WITNESS: EGGW | belleve is Luton, listed on here are friends of Jeffrey Epstein's and 11 ‘England. that's why they are riding on his plane? 12. BY MR. EDWARDS: A. I'm speculating. 13 Q. Okay. Do you remember fying to England? Q._ I'm just not familiar with the — because I've 14 A. {do remember flying to England. | just don’t never been on a private flight — with the manner in 15 remember that trip. What airplane were we in? We were which you go about getting on one of these flights. | 16 in the Boeing. mean, you have to, | guess, know that Jeffrey Epstein 7 Q. Do you remember the purpose of the trip? has 2 plane, thet it's going from 2 destination that you 13 A. No. are at and want to go to, and that it's available and ig Q, De you know who Doug Band is? those Kind of things. Can you teil me, enlighten me — 20 A. Sheard he's Clinton's, how would you say, A. Well, it's not publicly offered, no. It would 21 assistant. | mean, ve seen that in ihe newspaper, be no different than you jumping in your car and knowing, 22 — seen iton CNN. you're going to the mail. 1 mean, it's not public 23 Q. Okay. Did you ever hear that Doug Band and information, you know, where planes are comingtoand | 24 Ghislaine Maxwell were together, even for a day or 4 fram, and you don't put your name out there te get 25 __night? 82 84 onboard a flight. 1 A. No. Q. Does Jeffrey Epstein charge these people as 2 Q. Did you ever hear that Doug Band and Ghislaine passengers? 3 ‘Maxwell were the people attributed to introducing Bill A. | don't know. 4 — Clinton and Jeffrey Epstein? Q. Okay. Are these people such as Bill Clinton, 5 MR. CRITTON: Form. does that mean that Bill Clinton called Sarah Kellen or 6 THE WITNESS: 1 don't know. somebody affiliated with Jeffrey Epstein to get on the 7 BY MR. EDWARDS: plane or that Jeffrey Epstein called Bill Clinton and 8 Q. Allright. There's another flight here on asked do you want a ride? 9 January ~ | can't read this upside down. Maybe it says MR. CRITTON: Form; predicate. 10° May~ THE WITNESS: | have no idea. 11 A. Looks like. BY MR, EDWARDS: 12 Q, ~ 22nd, 2002, Again, with President Bill Q. No idea? 13 Clinton, Janice, Jessica. Can you teil me who Janice A. No idea whatsoever. 14 and Jessica are? Q. Joe Pagano, do you know who that is? 15 A. i don't remember. A. Yes, 16 Q. Would you know them if you saw them? Q. What's his relationship with Jeffrey Epstein, 17 A. Probably not because the names don't even ring or what was it back in February ~ sorry, March 17th of 18 abel. 2002, when he and Sarah Kellen and Jeffrey Epstein and} 19 Q. Allright. And then there are plenty of ‘Todd and one female were on this flight? 20 flights, many of flights where Jetfrey Epstein, A. {don't know to what extent or what his 21 Ghislaine Maxweil and Sarah Kellen are the primary relationship is. He Just was a passenger on the 22 passengers, or at least are some of the passengers on airplane. 23 the flights, correct? Q. Okay. And the next day -- sorry, two days 24 A, Mm-hmm, yes. Jater on the 19th of March, Bil Clinton flies again, 25 Q. And still, as you sit here, you being the

Larry Visoski 85 1___ pilot of these flights, you're not sure what their 1 2 relationship is or whether any of them were socially 2 3 connected in any real way? 3 4 MR. CRITTON: Form. 4 5 THE WITNESS: No. When you're flying the 3 6 airplane, there's a lot more going on than 6 7 passengers’ relations. a 8 BY MR, EDWARDS: 8 9 Q. Allright. You remember this person, Virginia 9 10 Roberts, are you familiar with her at all? 16 ii A. remember the name, that's it un iz Q. What do you think her relationship is to 12 13 Jeffrey Epstein? 13 14 A. No idea. a4 is MR. CRITTON: What date are you on, Brad? is 16 MR. EDWARDS: Oh, sory. | am at June 21st, 16 17 2002. 17 18 BY MR. EDWARDS: 18 1g Q. That's not somebody that you specifically is 20 remember? 20 2h A Mm-mm, no. 22 22 Q. No? Is that somebody that you think was a 22 23 regular flyer for any period of time in Jeffrey 23 24 — Epstein's life? 24 25, A. Nota regular. 25 a 86 é 1 Q. Okay. Jean Luc Brunet. is that a name that 2 2 you know? 2 3 A. Yes. 3 4 Q. How do you know that name? 4 5 A. Only because It's 2 unique name and his attire 5 6 is very unique. So you remember certain things. So! 6 7 know he who that is. 1 8 Q. Do you know what he does? 8 9 A No. 9 10 Q. Do you know his association with Jeffrey 10 11 Epstein, if any? it 12 A. No, {don't know what the relationship is. 12 13 Q. Have you ever heard of him owning or running 13 14 ormanaging a modefing company? 14 15 A. | have seen that in the paper a few years 15 16 back. 16 v7 Q. Okay. Other than seeing it in the paper, have 17 18 — you ever talked fo Jean Luc Brunel or Jeffrey Epstein 18 19 about owning of running or managing a modeling company? } 19 20 A. No. 20 an Q. De you know if Jeffrey Epsteln's affiliated 21 22 with the modeling company that's owned, run or managed 22 23° by Jean Luc Brunet? 23 24 A. No, | have ne idea. 2a 28 Q. And sesing that this is a flight now, that 25 October 15, 2009 87 we're referring to the same flight on June 21st of 2002, that includes Jean Luc Brunel, Virginia Roberts, Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, those are the passengers of this flight, does that serve to jog your memory as to who Virginia Roberts is? A, No. i mean, you see how frequently we fly. 1 mesh, it's -- the passengers in the back are so far removed from an operation of commanding an airplane kd that, it's nothing that sticks in your head. Q, And you as the pilot, is there any way that you would know what's going on in the back of the airpiane? A. No. My concems are ait on the cockpit. MR, CRITTON: Brad, the last one that you mentioned, was that the same date, June 21st, 02? MR. EDWARDS: Yes. BY MR, EDWARDS: Q. There's another name here that | was going to ask you do you know. June 23rd, 2002, Jultana Barbosa, are you famitiar with that name? A. No. Q. Also on the same flight with Jean Luc Brunel. That doesn't help to jog your memory either, right? AL No. Q. That's somebody that you remember as 2 88 frequent passenger? A. Who are you referting to? Q. Juliana Barbesa? AL No. Q. Or. Jarecki, is that somebody that you remember flying? A. I know the name. He may have been on the airplane once or twice. I'm guessing only. Q. Do you remember meeting him? A, Yes, | have met him, Q. Do you remember his purpose for being on the airpiane? A. No, sir. Q. Amanda Venaro, do you remember her purpose for being on tke airplane? A. No. MR. REINHART: Can we get a date? MR. EDWARDS: | was asking him if he remembered Amanda Venaro, ? wasn't referring to 2 specific fight. BY MR. EDWARDS: Q. You don't remember her being on the fight? A. I don't remember the name. Q. Me showing you the flight isn't going to jog the memory?

Larry Visoski October 15, 2009 CO BIMAHROYNE 89 A. No. The name that would launch it first -MR. CRITTON; Could t ask you a question? You have the original exhibit marked at the deposition. It looks like it's been highlighted. MR. EDWARDS: | hightighted it MR. CRITTON: Oh, okay. So you've highlighted the original exhibit that's marked for the deposition? § just want the record to refiect that. MR. EDWARDS: Yeah. MR. CRITTON: Okay. Thank you. MR. EDWARDS: Ai the time | hightighted it didn't realize { was holding on to the original exhibit. | didn't reatize that until you just pointed that out. MR, CRITTON: I've noficed that. MR. EDWARDS: So now when | give it to you, {'m giving you my work product as well. i don't see how this works against you, but anyway. BY MR. EDWARDS: Q. Melissa Stall, is that a name that you remember? A. No. Q. Okay. And then Jean Luc Brunel is somebody who | noticed flew relatively frequently, so is that why 90 you — that name jogs your memory a little better than some of these other people? A. He dresses uniquely. Q. in what way? f A. Just loud clothes, so something that you would remember, that's all. Q. Do you know his role in Jeffrey's life? A. No. Q. Ever heard that he ia affiliated with Jeffrey Epstein because they both have a sexual attraction to underage giris? MR. CRITTON: Form. THE WITNESS: You're making an assumption on that. BY MR, EDWARDS: Q. Have you ever heard that? MR. REINHART: He's asked you if you ever heard that. BY MR. EDWARDS: Q. iFyour answer is no, it's no, A. I'm sorry, | thought you said they did, No, | have not. Q. Okay. [keep hightighting this name, Virginia Roberts, just because it looks like somebody that's reguiarly flying on the alrpiane. But the more that you 1 2 3 4 5 6 7 8 S 16 1L 12 13 14 15 16 i7 18 19 20 21 22 23 24 25 L 2 3 4 5 6 7 8 9 10 ii 12 13 14 is 16 17 18 19 20 aL 22 23 24 25 91 see her name, that doesn't change your opinion as to whether or not you remember her or what ~ A. remember the name, you know, that's all. Q. Do you remember about what age she was when} she was flying on the airplane? A. No. Q. This could be somebody who is 50 years old or ten years old, for ail you know? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. Okay. A. I mean, | would only be guessing at an age. Q. Yeah, but | mean, you don’t remember her at all. So you don't-A. Eremember the name, exactly. Q. Other than the name? A, Right, yes, sir. Q. But you can’t even come ciose to putting a face with that name? A, fmean, no. i mean, if you said draw her picture with - { couldn't come close to even getting it. Q. Okay. You remember this fight where President Clinton, Kevin Spacey and Chris Tucker, 92 Jeffrey Epstein, Ghislaine Maxwell? Yes. . From JFK to what is this, LPAZ? LPAZ, that is — South Africa or something? No, it's the Azores Islands, Santa Maria. |. Do you know the purpose of that trip? That was a fuel stop. Okay. And do you know why Chris Tucker and Kevin Spacey were on that airplane? A, No. Q. Did you talk to them? A. They came up in the cockpit and said helio. So they conversed, nothing more. Q. Another name that is on here a few times, I'm specifically referring right now to the dates of September 23rd and 24th of 2002, is Ron Burkle. Do yo know who that is, Ron Burkle? A. {know what that is, yes. | didn't realize he was on our airplane. Q. Right now that is the first time that you remember Ron Burkle being on your airplane? A. Yeah. @. You don't know the purpose for him being on that airplane? propre ro,

Larry Visoski COI AHSWHH 1 42 13 14 15 16 17 18 19 20 Qn 22 23 24 25 October 15, 2009 93 95 A. No. Granted, I'm seeing this for the first 2 BY MR. EDWARDS: time, so 'm trying to ~ 2 Q. Okay. You don't remember which flights it Q. Let me ask you that. Because this was given 3 would have been where there would have been girls under to me at a deposition of Dave Ragers, who | understand 4 ~~ the age of 187 was the chief pilot for Mr. Epstein, and now you're the 5 MR. CRITTON: Form. cheap pilot, but you always Kind of worked in tandem, 6 THE WITNESS: Weil, | would have to look at correct? 7 the fight logs. A. Sure; we complemented each other. 8 BY MR. EDWARDS: Q. And you both worked for the same company that 9 Q. It's not illegal to have somebody under the flies Jeffrey Epstein's airpianes, right? 10 age of 18 on a flight anyway, right? A. Yes. qi A. No, not at al. Q. Sol was of the presumption, which may have 12 Q. Were you ever aware that you, as pilot, were been — | may have been misled here, orl may have, you | 13 transporting giris under the age of 18 who were supposed knew, misunderstood the purpose behind this book ar h 14 tobe models? itwas created. f thought that you had probably seen 15 MR. CRITTON: Form. this before at some polnt in time? 16 THE WITNESS: | had no knowledge. A. Gh, no. 17 BY MR. EDWARDS: Q. Did you know that Dave Rogers was keeping this | 18 Q. Okay. You never knew who the peopie on the book? 19 —_alrplane were, what their purpose was, their role with A. No. iknow he keeps a pilot log book. 20 Jeffrey Epstein or Jean Luc Brunel? Q. Okay. But you didn't know he was keeping the 2i A, No. names of the people who were on the airplane? 22 Q. Alfright, Do you know Jutietle Bryant? A. No, It’s not required, so | mean, it's... 23 A. No, | don't remember that name. Q. So today is the first time that you are 24 Q. Andrea Metrovich? fearming that the names of the people that are on the 2s A. [remember the name. 94 96 airplane was kept by Dave Rogers? 1 Q. She flew frequently at least for a period of A. Yes, in his log book. 2 time. Do you remember that? Q. Okay. And it's my understanding when you fly 3 AL Yes. back into the country through Customs, you have to 4 Q. Is that somebody that you thought was farniliar report the people that are on the airplane, right? 5 — with the modeling industry or related to the modeling A. Yes. ° 6 industry? Q, And who would create that document or call 7 A. No. that information into Customs? 8 Q. Okay. And these people, did Jeffrey Epstein A. Whoever the captain was for the day. 9 ever tell you how he was associated with any of them? Q. Attimes would that be you? 10 A. No. A. Yes. 11 Q. Did you ever wonder how he was associated with Q. Okay, And at times when you would come into} 12 any of them? the country with passengers -- well, not at times. 13 A. No, never interested. Didn't you also have to report their date of birth? 4 Q. And on several of these - on most of these, A. Sure. 15 the names or initials of the people that are on the Q, At times weren't there also people that you 16 flight are listed. Do you know on the occasions where would bring in from other countries into the United 17 it lists generically twe females or three femates or six States that were under the age of 187 18 — fernales, do you know why that was done? A. Yes. 19 A. dust because we didn’t know our ~- the Q. And atsome times those were flights that 20 person's name. We tried to do the best we could to keep| included Jean Lue Brunel and girls that were under the) 21 the records, age of 18, right? 22 Q. When you say “we tried to do the best that we MR. GRITTON: Form. 23 could" ~ THE WITNESS: 1 don't remember those flights.; 24 A. Dave and |. 25 Q. Okay. But the first time that you feamed

Larry Visoski 1 2 3 4 5 6 7 8 9 16 ai 12 13 14 15 16 i? 18 19 20 22 22 23 24 25 WOIH RW 10 12 13 14 15 16 17 18 19 20 aL 22 23 24 25 97 that he kept anybody's names was today, right? A. Well, 1 didn't know he kept them in his log book. We would fili out the passenger manifest as we're ~ having passengers’ names in your pilot tog book, he’s probably the only parson in the world that does that. Q. Okay. A. So when you were mentioning putting the names down, when you said female or male, you know, | was seferring to the passenger manifest. Q. For each of these same flights, then, that we're referring to out of this log book that was marked as Composite Exhibit 1 in Dave Rogers’ deposition, am 1 understanding you correctly, then, there would also be a passenger manifest for each of these flights? A. Yes, Q. Now, where would [ find the passenger manifest? Who keeps that documentation? Corporate — our corporate office. Which is whom? Up in New York, Darren indyke. At what corporation is that, though? NES, LLC, I guess. MR. REINHART: Do you know for sure? THE WITNESS: ! don't know for sure. | mean, 98 POPROP when you say — we would just send them up to New York. BY MR. EDWARDS: Q. Did you ever keep a copy of them? A. No. Q. Why did you keep a passenger manifest? A. Just for tracking of — to have the times on there for -~ MR. REINHART: Can | confer with him on one thing before you ask a question? MR. EDWARDS: Yeah, yeah. (Off the record discussion.) MR. REINHART: Mr. Edwards, let him amend his prior answer. | think he misunderstood the question. MR. EDWARDS: | don't know what question we're, amounting the answer to, MR. REINHART: Let me clarify this way: As. the passenger manifests, they are corporate documents of either JEGE or Hyperion Air, whatever company owns the plane. Mr. Visoski has physical custody of them. He retains them but they're not his dacumants. They're the corporate documents. So they're not in New York. THE WITNESS: Those are the ones that i have October 15, 2009 39 1 at the airport office that | had tumed into 2 counsel that has the passenger names on them. 3 BYMR. EDWARDS: 4 Q. Okay. 5 A. it's called a passenger manifest. 6 Q, Okay. 7 MR, REINHART: Right. 8 BYMR. EDWARDS: 9 Q, The passenger manifest, just so | understand 10 exactly what that is, tell me. Tell me in your own 11 words. 12 A, Its departure time, the city, the landing 13 time exactly and the passengers that would have been on 14 that flight, 15 Q. And at times on that passenger manifest would 16 — you list also generically female or male? 17 A. Yes. That was the document | was referring to 18 stafing that if we didn't know a parson, we did not go 19° out of cur way to find out a name. We just put in to 20 account for how many people were on the aircraft at that as time. 22 Q. Who is currently in the custody or controt ~ 23. sorry. Who currently maintains or has possession of the 24 passenger manifest from 1998 through the present, 25 through today for those airplanes that you flew related 100 1 to Jeffrey Epstein? 2 A. (currently have, which counsel has now, 2005, 3 Ebelieve, until the present time. And the records 4 previous to that | believe were turned into counsel with 5 the previous investigation with Jack Goldberger's 6 office, | believe. | believe they maintain those 7 records. 8 Q. When you say "turned into counsel," there are 9 alot of counsel invoived here. 10 A. Jack Goldberger's office, | believe. 11 Q. When you say “the previous investigation,” 12 you're talking about the criminal investigation? 13 A. Exactly, yes, sir. 14 Q. And you're aware in that criminal 15 investigation, obviously, that Jeffrey Epstein pied 16 — gulity to certain charges, correct? 17 A. From what | read, yes. 18 Q. Well, you did visit him in jail, right? 19 A. Yes. We didn't tak about that. 20 QQ. Okay. You know in order to go to fait, 21 — though, you have to be convicted of some crime, right? 22 MR. CRITTON: Form; argumentative. 23 THE WITNESS: Yes. 24 BY MR. EDWARDS: 2s Q. Itwasn't like he was visiting the jail and

Larry Visoski 24 101 you were visiting and you happened to bump into each other. You actually went to see him while he was an inmate in jait? A, Right, yes. Q. Okay. So when we're talking about the criminat investigation, we're talking about the criminal investigation revolving around the allegations of Jeffrey Epstein engaging in sex acts with minors? MR, CRITTON: Form. BY MR. EDWARDS: Q. That's the criminal investigation you're talking about, right? MR. CRITTON: Form. THE WITNESS: 1 don’t know the fuil definition of really what happened there. 1 know that it was something to de with solicitation of prostitution. That's all i read. BY MR, EDWARDS: Q. Okay. Were you aware that the allegations tevolved around underage girts or girls under the age of 187 MR. CRITTON: Form. THE WITNESS: | was aware it revolved around it, yes. 102 BY MR. EDWARDS: Q. Who first made you aware of that? A. The newspaper. Q. Were you ever questioned by the police? A. {don't know who questioned me, actuaily. | did have a questioning session, but | don't even temember who questioned me. Q. Where did that take place? A. I don't remember. Q. Atyour house? A. No. I'm thinking it was Jack Goldberger's Office, or it may have been downtown at the Palm Beach: County Courthouse or something in that area there. Q. Okay. So it either happened at an attorney's office that represented — A. Exactly, yeah, | think so. Q. -- Jeffrey Epstein or the other side? A. Yeah. Q. And during that questioning, is that when you turned over the passenger manifest from prior to 2005? A. Yes. Q. And you turned those manifests directly over to Jack Geidberger? A. Yes. Actually, | believe Dave Rogers did that. I wasn't in possession of those records we oOIHMHHRUNne SIA RYNE October 15, 2009 303 Q. And for the passenger manifest prior to 2005, how far do those passenger manifests go back in time? A. They should go back, | guess, to 1991 or whenever we started existence. Q. And did you tum them over from 1991 ail the way through to 20057 A. idon't know. | didn't tum them in. Dave Rogers did. Q. Are you in possession of a copy of any of those materials? A. No. Q. | thought that, you know, ten minutes ago when we were talking about this you said you had them back at an office or —~ A. That was the office, the airpiane office, which Fve given to Bruce, which is the current log. He ig in possession of them now. | had possession of them. Q. Okay. What he's in possession of - just so know what documents are where, he's in possession of ihe: passenger manifests from 2005 through the present? A. Correct. Q. If want to obtain the passenger manifests from 1998 through 2008, that's something that | would request from whom? THE WITNESS: Help me out. That's -104 MR. REINHART: If you know. THE WITNESS: | don't know who possesses them right now. They were tumed into Jack Goldberger’s office a year and a half or two years ago. BY MR. EDWARDS: Q. You started out by indicating that you sent these passenger manifests, or a copy thereof, to Darren Indyke or someone at NES, LLC; is that correct? A. Correct. Q. iff requested them from NES, LLC, that's somebody at some point in time was in possession of ail the passenger manifests? A. Sure. Q. And NES, LLC's address is the one you gave me at 301 East 66th Street? A, [believe so, | don't know what address they're using for that. | know that — Q, But Darren indyke's the atfomey that ! would cali -—A Yes, sir. Q. --and he could probably steer me in the right direction? A. Yes. MR. CRITTON: Form.

Larry Visoski WOWARe wre 10 12 i3 14 is 16 7 16 19 20 21 22 23 28 25 October 15, 2009 105 107 BY MR. EDWARDS: 1 hello, Q. Do you know Amy Taylor? 2 Q. That's somebody who was on the airplane A. Yes, 3 multiple times? Q. How do you know her? 4 A. More than once. | mean, | have no account for A. She was on the airplane. Show many times. Q. How old is she? 6 Q. Well, I've asked you about a bunch of names, A. | have no idea. 7 most of which you don't really remember, but that's one Q. Age range? 8 name you do remember. A. Twenty-eight. 9 A. Yeah, | remember the name, yeah. Q. Now? 10 Q. Okay. And that’s somebody who you actually — A. Yeah, 28, or maybe if not older now. She was 11 -you would remember the face too? probably 28 probably, | guess. She was somebody in her| 12 A. I might remember Amy's face. late 208. 13 Q. Alfright. Do you remember why she would have Q. So we're tatking about 2003? That's what i'm 14 averbeen on your airplane? trying fo understand. is A. No idea. A. im guessing. 16 Q. President Andres Postrana, at the time | guess Q. We're talking 2009 new. We're saying 28. By 17 that was the president of Colombia back in February —~ that do you mean in 2003 she was 23 or 24 years old? 18 sorry, March 20th of 2003. Do you know who that is? A. You're having me guess on her age. is A. | don't remember him being on the airplane, Q. Yeah. 20 but | know who that is. A. \megan, | can't be accurate. 21 Q. Okay. He's on the airplane with Jeffrey Q. Somebody between 18 and 257 22 Epstein, Ghislaine Maxwell, Sarah Kellen and Jean Luc MR. CRITTON: Form. 23° Brunel? BY MR. EDWARDS: 24 A. Where did we go? Q. At the time you were seeing her back in — 25 Q. Milat you look at it. I'm talking about oon meee 106 108 A. Ifyou want me to guess — ‘1 this fine, PBI, left out of Palm Beach? Q. No, | don't want you to guess. 2 A. Paim Beach to Nassau. I'm sorry, | don't A. I don't know then. 3 remember that one. Q. Well, if | say between ten and fifty? 4 Q. When we're saying we're going down to Nassau, A. That's a range. 5 ig that a place that you frequently went to with the Q. If say between ten and fifty, you're not 6 airplane? guessing there anymore. You know she's in there, right? 7 A. No, not at all. A. She's in the middle there, yeah. 8 Q. And is that a route that you would take for Q. Okay. How can we narrow that down? We're 9 the ultimate destination to be Little St. James? taiking about somebody in her 208? 10 A. No. A. Inher 20s. 12 Q. Ifthe ultimate destination was Little Q. Atleast that's what you believed? 12 St. James ~ show me a flight where the ultimate A. Yes. 13 destination was Litile St. James. @. Altright. fs that somebody that you know to 4 A. Yeah, right here. TiST, that’s St. Thomas. be associated or friendly with Ghislaine Maxwell? is Q. Okay. So on that flight that you just pointed A. [don't know. 16 to, March 27th, 2003, we have Jeffrey Epstein, Sarah Q. Do you know what her relationship was to 17 Kellen, Cindy Lopez again, Brent Tyndall -- do you know; Jeffrey Epstein or Ghistaine Maxwell? 18 — who Brent Tyndall is? A. No. 19 A. Yes. Q. Doyou know where she is now? 20 Q. And who is that? A. No Idea. 22 A. lbetieve he was the chef. Q. When's the last time you talked to her? 22 Q. And Magale Blanchen (phonetic), is that A. idon't know, What date do you have on there? 23 somebody you know to be a made these days? Q. February 2003. 24 A, | have no idea, A. So, probably that long ago. | may have said 25 Q._ Do you remember that flight?

Larry Visoski Lenten 109 L A. No. a 2 Q. Do you remember Naomi:Campbell, picking her upp 2 3 from St. Thomas along with Jean Luc Brunel? 3 4 A. | remember her being on board, | don't 4 5 remember the flight. 5 6 Q. Do you know Joel Pashicow? 6 7 A. Yes. z 8 Q. How do you know him? 8 9 A, He was on the airplane. 9 10 Q. And is that somebody you knew at one point in 10 11 time to be a friend of Jeffrey Epstein's? a2 12 A. He was on the airpiane. I don’t know what the 12 13 telationship was. 13 14 Q. Do you know what the relationship is today? 44 15 A. No idea. 4s 16 Q. How about Todd Mister, de you know what that 16 17 felationship is or was today? 17 18 A. No. 18 19 Q. Do you remember him? 19 20 A. No. 20 2a Q. Not at ail? 21 22 A. Imean, | know the name. | den't know. 22 23 Q. Paula Epstein, do you knew whe that is? 23 24 A. Yes. 24 25 Q. Who is that? 28 110 1 A. That's Jeffrey's mom. 1 2 Q. She's passed away? 2 3 A. Yes. 3 4 Q. Atleast that's your understanding, right? 4 5 A. That's what 1 heard, yes, 5 6 Q. Okay. Tila Davies, do you know her? 6 7 A. Tila Davies, | know the name. 7 8 Q. Somebody who flew an the airplane with some 8 9 regularity? 9 10 A. Yes. 10 LL Q. And do you know her to be friends of Ghislaine} 11 12 Maxwell or Nadia Marcinkova or Jeffrey Epstein? 12 13 MR, CRITTON: Form, 13 14 THE WITNESS; F have no idea who she was 14 15 friends with. 18 16 BY MR. EDWARDS: 16 17 Q. Allright. Do you know what role she ever l7 18 played, if she piayed one, in Jeffrey Epstein's life? 18 19 A. No. 19 20 Q. Allright. Glenn Dubin, are you familiar with 20 21 him? 21 22 A. Yes, 22 23 @. How do you know Gienn Dubin? 23 24 A. I met him on the airplane. 24 25 Q. Outside of the airplane, have you ever seen 25 October 15, 2009 121 him around Jeffrey Epstein? A. No. Q. Allright, A. No. Q, Alina Webber, do you know that name? A. No. Q. She was on several flights. You don’t remember seeing her? A. No. Q. Alldight. And how about Alan Dershowitz, I'm ‘sure you know who that is? A, Sure. He's famous. Q. What was your understanding of Alan Dershowitz's relationship with Jeffrey Epstein? A. Never talked about it Q. Forrest Sawyer, do you know why he was on your| airplane? Never heard the name, actually. Really? No. Larry Summers? Lknow the name. I don't remember flying him. Have you ever talked to Joe Fontaneta? Yes. How do you know him? 112 A. He usually drops Jeffrey off at the airport. Q. In fact, you've called him directly before, PP OPOrp> A. Yes. Q. You still have his number? A. Vhaven't - yes, | think | still got it in my memory. Q. Okay. What is it? A. It's been a few years. (917)945-7500. It's kind of an easy one. MR. CRITTON: 917 is the first — THE WITNESS: Yes. MR. CRITTON: Who was this for? MR. REINHART; Joe, Joe Fontanela, MR. EDWARDS: Fontanela. BY MR. EDWARDS: Q. Do you know his address, where he resides? A. No, don't Q. Bo you know if he -- what his role is in Jeffrey Epstein's life? A. Not really. He just — he drove the car. Q. He drove what car? A. The car up in New York. Q. Okay. Do you know if he's a housekeeper up at that house up in New York?

Larry Visoski October 15, 2009 113 115 1 A. | don't know what his role is. 1 Q. Do you know -- did you teil me, do you know 2 Q. Have you ever worked for a company called aie 2 what Lestie Gruff does for Jeffrey Epstein? 3. Ghislaine? Do you know that company? 4 A. idon't know her exact title. 4 A Yes. 4 Q. You talked to all of these individuals at some 5 Q. Do you know what that cornpany does? 5 point in time, either on the phone or in person, right? 6 A No. 6 A. Yes. 7 Q. Have you ever been an employee of that 7 Q, And you don't know whether they play a role in 8 company? 8 Jeffrey Epstein's life, or if they do, what they do? 9 A. No. 8 A, Exactly. 10 Q. Do you know who runs that company? 10 Q, And how do you decide who you're going to cali iL A. No, 11 for what reason? 12 Q. Is Jeffrey Epstein associated with that 12 A. Forexample? Can you be more specific? 13. company? 13 Q. Ifyou're going to make a telephone cail and 14 A. | don't know. 14 you're going fo taik to let's say Leslie Gruff, why a5 Q. How have you heard of that company? 15 woukt you choose to calf her? 16 A. It's the company name that our registration 16 A. [don't know. You're having me make the phone 17 for the helicopters is under, Air Ghislaine. 17 afi. 1 don't know why | would caii her. 18 Q._\s that somebody who's ever paid you, & 18 Q. Have you ever called her? 19 company who's ever paid you? a9 A. Ethink, yes, I've called her, sure. 20 A. No, 20 Q. Why? What would be the reason that you would 24 Q. Do you know Igor Zinoviev? 21 cali her? Somebody toid you te calf her? Here, calt 22 A. Yes. 22 this number? 23 Q. How do you know him? 23 A. Smay have called her maybe to find out if we 24 A. Met him on the airplane. 24 had a departure time for any specific trip. | mean, 25 Q. What is your understanding of his affiliation 25 that would be... 114 116 1 with Jeffrey Epstein? 2% Q. Okay. So you're calling her related to 2 A. Idon’tknow. He doesn't talk much. 2 — Jeffrey Epstein? 3 Q. Okay. And Sandy Berger, do you know who that 3 A. Sure. 4 is? 4 Q. Okay. So you know that she plays some role in 5 A. [don't know. 5 some aspect of Jeffrey Epstein's life, whatever that is? 6 Q. Do you know any reason why you would have: 6 A. Right. 7 flown him on the airplane? an Q. Okay. So when I'm asking these questions a A. [don't even know the name, 8 about these people, and | feel like I'm getting answers 9 Q. Adrianna Muchinska? 9 that 'm not really not sure that these people have any 10 A. | know the name Adrianna. 10 role in their fife, that's not — that's not completely 12 Q. Somebody who fiew on the plane pretty 11 accurate, right? 12 regularly? 12 MR. CRITTON: Form; argumentative. 13 A. [would have to look at the fogs. | think 13. BY MR. EDWARDS: 14 ~~ we've had that name on several - it's a common first 14 Q. mean, you do know that these people are 15 name. I'm net famitiar really on who that is. 18 — semehow invoived with him, whether socially or 16 Q. What about Bella, do you know who Bella is? 16 —_ business-wise or otherwise, and during the course of 17 Is that a name you ever heard? 17 your years, you've made telephone caiis on his behalf or} 18 A. Yes. 18 to coordinate things with them right? 19 Q. Works up in the New York office or something? 19 A. Right. 20 A. Yes. 20 MR. CRITTON: Object to the form. You said 22 Q. Have you ever spoken with Bella personally? 21 “these peopie." 22 A. Yes. 22 BY MR. EDWARDS: 23 Q. Do you know what she does for Jeffrey Epstein, 23 Q. I'm talking about Sarah Kellen. That's 24 ~~ if anything? 24 — somebody you called before, right? 25 A. | don't know exactly what her role is. 2s A. Sure.

Larry Visoski October 15, 2009 117 Q. What would be a reason you called Sarah Kellen? MR. CRITTON: Object to form. Probably the same reasons he said two hours ago, for scheduling; purposes, But you've covered that. Go ahead and answer it again. THE WITNESS: For scheduling purposes, woul be my only reason to call her. BY MR. EDWARDS: Q. That's funny that you used the exact same words that Mr. Critton wants you to use. MR. CRITTON: it's what he said two hours ago. BY MR. EDWARDS: Q. What would be the reason why you would cali Ms. Maxwell, Ghislaine Maxwell? A. Same reason. Q. That's not somebody you call these days, though, right? A. Ehaven't seen her in some time, Q. What made you stop calling Ghislaine Maxwell where you thought at one point in time you thought she was 2 person te call related to your job? A. Just was no reason to. Q. ts that somebody who you think is stil affiliated or associated with Jeffrey Epstein or his —" 118 whatever he does? A. 1'd only can speculating. | don't know. Q. Allright. De you know the number (917)868-6145? MR. CRITTON: Could you say it slowly. 9177 MR. EDWARDS: 868-6145. Thank you. And just in case you didn't get it, I'm going to mark these as an exhibit so that we can read thern later. BY MR. EDWARDS: Q. Do you know that number? A. Yes. Q. What ts that number? A. That's my cell phone. Q. Okay. Is that stil your cell phone? A. Yes, sir. Q. Allright. i'm going to show you two documents here or pieces of paper. We'll mark them as Exhibit 2 and Exhibit 3, The first one is dated March Sth, 2005. Deo you remember making this telephone call? And just for the record, this looks like 2 message that's being taken relative to a phone call that you made. MR. REINHART: Se the question is does he remember making tha phone call? OCAIHAeweNe 10 i 12 13 14 15 16 17 18 19 20 21 22 23 24 119 BY MR. EDWARDS: Q. Do you remember making that phone call after reading the message? A. Let me jook at the date here. Okay. March. MR. REINHART: The question is, do you remember making the call? THE WITNESS; Okay, let me. “Person for the car will be here in 15 minutes fo drop off foam and papers.” | don't know. BY MR. EDWARDS: Q. That doesn’t mean anything to you? A. That doesn't — { mean, you're talking four years ago. | can't answer that accurately. 1 mean... MR. REINHART: So the answer is you don't recall? THE WITNESS: Yeah, i don't recall. BY MR. EDWARDS: Q. ifyou don't remember, that’s fine. (Plaintiff's Exhibit Nos. 2 AND 3 were marked for identification.) BY MR. EDWARDS: Q. So I" show you Exhibit 3, the same type of document, and | can make the representation that this was message pads provided by the state attorney's office) relative to the criminal investigation revolving around 120 Jeffrey Epstein. So that's how | have these documents. t'm not trying to pull out old documents. MR. CRITTON: What's the date? MR. EDWARDS: March 19th. MR. REINHART: The question is, do you remember the call? ‘THE WITNESS: "Tom from Midnight Express is at” — help me out -- “convention center with new boat. They are two points ~- two parts of this." BY MR. EDWARDS: Q. “Show? A. “Show up the water" -MR. REINHART: “On the water.” THE WITNESS: "On the water and at the center.” BY MR. EDWARDS: Q. Do you remember making that call? A. No. | mean, “Tom from Midnight Express is at convention center with sew boat. They are two parts of" -- | mean -Q. Butas Jeffrey Epstein's pilot, why would you be feaving such a message about Tom from Midnight Express relative to boats and a boat show? A. |help out with boat purchases or, you know, anything te do with, you know, that moves. So! mean,

Larry Visoski October 15, 2009 122 123 1 1 Q. And has he consulted with you on each of those 2 Q. Okay. When you say "you help out with boat 2 ~~ purchases? 3 purchases," what do you mean? 3 A. Not avery one of them, no. 4 A. Give my opinion, whether or not whether to buy 4 Q. Does he own any boats now that you're aware 5 acertain boat. It's just a hobby. | have knowledge on 5 of? 6 — boats. Not only just airplanes but, you know. 6 A. | don't know if he owns them or not. 7 Q. You give your opinion to whom? 7 Q. Okay. Do you know of any boats that he 8 A. To Jeffrey. & — controls or maintains? 9 Q. Okay. And Jeffrey Epstein obviously, at least 9 A. Himself or? 10 in your mind, you believe he wants your opinion? 10 Q. How about this — I'l ask you this way. 1 al A. Yes. 11 don't want to spiit hairs with you here: | know we've 12 Q. Okay. So boats is another thing that the two 12 been talking about corporations and things tike that. 13 of you have discussed? 13 A. Yes he. 4 A. Yes. 44 Q. Do you know of any boats that he is the person a5 Q. Allright. And so this a conversation or at 15 with the most controt over? 16 least some evidence that a conversation existed between} 16 A. Yes. 17 yourself and Jeffrey Epstein relative to a boat or a 17 Q. Okay. Where would those boats be located and 18 — boat show? 18 — what kind of boat are we talking about? 19 A. Correct. 19 A. St. Thomas is the location. Itwould be a 20 Q. Do you remember having that conversation? 20 34-foot inflatable boat. | know that one specifically. au A. We've had many conversations about boats and | 21 Q. Okay. Do you know when he made that purchase?| 22 different boat shows, If you're referring to this one 22 A. Bight years ago, seven years ago. itwas a 23 in 05, don't recall this one. 23 while ago. 24 Q. Okay. So aside from being a pilot ~ which 24 Q._ is that something you had had input in? 25 throughout this entire deposition | believe your 25 A. Not on that one specifically, no. i 122 124 1 testimony has been, you know, you're just the pilot for i Q. Is there any other boat that you know of 2 him ~ it looks like there's some other role that youre: 2. Jeffrey Epstein being the primary user of or the primary 3 playing here in his life. i'm not suggesting that you 3 controller of? 4 are or you are not. !'m just saying from the appearance! 4 A. | mean, there's boats in St. Thomas. | mean, 5 of this, it looks that way. 1s there anything else that 5 it's not part of my job, you know, what goes on with the 6 — you want to tell me or that you want to clarify in terms 6 boats or who controlled them. It's more of an opinion 7 of the role that you play in Jeffrey Epstein's life ‘7 ~~ of what horsepower should be on the back of the boat, 8 outside of being just his pilot? 8 — huli designs. it's out of my area. 9 MR. REINHART: Let me object to form. He also 9 Q. Sut your sole responsibility or your sole 10 told you he instails the audio and video equipment 10 obligation that you have ever had with Jeffrey Epstein 1 before. 11 relative to boats is just giving some opinions about the 12 MR. EDWARDS: Correct. 12 boat? 43 THE WITNESS: | have an interest in boats. 13 A, Mm-hmm. 14 You know, with the island, t don't think | bought 14 Q. Is that yes? a5: any boats, you know, for the company, but he 1s A. Yes, yes. 16 appreciates my opinion on boat purchases. 16 Q. Okay. All right. Has he ever given you his 17. BY MR, EDWARDS: 17 opinions about boats? 18 Q. Okay. 18 A. Sure. We've discussed it back and forth, a9 A, Having the knowledge of aviation and things 19 Q. Other than boat conversations, have you ever 20 that move quite fast. So 1 have consulted with him on 20 talked other conversations, such as ~ 21 boat items. 2h A. Cars. 22 Q. How many boat purchases are you aware of 22 Q. Okay. How about such as ~ have you ever 23. Jeffrey Epstein making in the time period that you've 23 known Jeffrey Epstein to have a girlfriend, somebody you 24 — known him? 24 consider a gittfriend? 25 A. Two or three. 25 A, No.

Larry Visoski October 15, 2009 warner wone 125 127 Q. In the 18 years and ail the travels you had 1 Q. Did he ever fly anywhere else with you either with hirn, do you know anything about Jeffrey Epstein's; 2 by helicopter or airplane in the last two years? sex life? 2 A. We flew one time to the Sikorsky plant. A No. 4 Q. What's the Sikorsky plant? Q. Do you know who he has sex with? 5 A. That's where they build the Sikorsky A. No. 6 helicopters. It's in Palm Beach County, Q@. Do you know if he has sex with anybody? 7 Q. And when was that? A, | don't know. 8 A. Probably a month ago, I'm guessing. Q, Do you know if he's ever had sex on the 9 Q. For what purpose? airplane while you've been piloting it? 10 A. They gave us a tour at a facility. A. (have no idea. il Q. Who's they? Q. That's something that you just wouldn't know: 12 A. Sikorsky. because you're up In the cockpit? 13 Q. And who requested the tour of the facility? A, Thatis correct. 14 A. They offered it to our flight department. THE WITNESS: Couid | take a tvo-minute 15 Q. And who went? bathroom break just to tose my coffee? 16 A. Jeffrey, myself, Nadia and Igor. MR. EDWARDS: Sure. Vv Q. And if | wanted documentation of either of (A break was had at 12:36 p.m.) 18 those trips, the trip to Miami or the trip te the BY MR, EDWARDS: 19 Sikorsky plant, who would have that documentation? Q. Allright. We're back on the record. Over 20 A. Iwould. i the years you've indicated that the ~ any gifts or 21 Q. Sol could request it from your attorney to other items or things given to you by Jeffrey Epstein 22 getit from you? exclusively are the poot heater, the 40-acres of land 23 MR. REINHART: Let me just check. and the -- 24 {Off the record discussion.) A. Use of a company — 25 MR. REINHART: Okay. He has custody of it, 126 128 Q. ~and the use of a company car? a but they're corporate documents. So you'd have to A. Yes. 2 request it from Mr. Critton, who | understand Q. That's it? 3 represents all the corporations. A. {Nodding.) 4 THE WITNESS: Yes. Q. Okay. 5 BY MR. EDWARDS: 7 A. Yes, I'm sorry, yes. 6 Q. What's the corporation that the document was Q. And the flight to Miami that was recently 7 prepared for? taken, other than Jeffrey Epstein and Nadia Marcinkova, 8 A. Meaning who -- what, like Air Ghislaine, the was there anybody else on that flight? 9 owner of the helicopter? Yes, Air Ghislaine. A. No, 10 Q. Air Ghisiaine? Q. How long -- did you also fly them back from il A. That's the helicopter. Miami to Palm Beach? 12 Q. And the name Ghislaine is obviously not that A. No. He drove back. 13 typical of a name. Is that reference or related to Q. When you say “he drove back," who drove back?} 14 Ghislaine Maxwell? A. Weil, |assume he drove back. | did not fly 15 A. |would assume, 1 have no knowledge. him back. 16 @. Nobody's ever told you that? Q. When's the next time you saw him again? 17 A. Nobody's brought it up. A. twould only be guessing. A week tater, 1 18 Q. Okay. And how long were you at the Sikorsky mean. 19 facility? Q. Okay. And was that in Palm Beach County whenj 26 A. Three hours, four hours. you saw him the next time? 21 Q. And what time of day was this? A. Yes, sir. 22 A. Nine in the moming. Nine, t think, and we Q. De you know of him leaving Palm Beach County 23 returned at one, something like that. in the last two years on any other occasion? 24 Q. And was the purpose to buy or purchase A. No. 25 anything?

Larry Visoski October 15, 2009 129 131 1 A. They have a new helicopter being developed 1 Q. Back in his office? 2 there, so they're trying to look for investors in it. 2 A. Yes, sir. 3 So they were just kind of pushing their product. 3 Q. What was that conversation? 4 Q. Do you know what Jeffrey Epstein does for a 4 A. Give me a time frame. i mean, I've been there 5 __ living for business today, these days? 5 several times. 6 A. No. 6 Q. Okay. How many fimes do you think you've been} 7 Q. Do you know ar have you ever been to the 7 tothe Florida Science Foundation? 8 Florida Science Foundation? 8 A. Twenty, thirty. | mean... 9 A. Yes, sir. 9 Q. Weil, the Florida Science Foundation's only 10 Q. And do you know what the Florida Science 10 been around since late 2007; is that right? 11 Foundation does? 11 MR. CRITTON: Form. 12 A. Not exactly. 12 BY MR. EDWARDS: i3 Q. Weill, generally? 13 Q. Something around that? 14 A. No, i don't. [ mean, really, i don’t, 14 A. idon't know exactly. 15 Q. Okay. fs it your understanding that Jeffrey is Q. Altright. So in the last 20 years ~ in the 16 — Epstein is somehow affiliated with the Florida Science} 16 — last couple of years you've been there 20 or 30 times, 17 Foundation? 17 approximately? 18 A. its my understanding that, yes. 18 A. Yes, sir. 19 Q. I mean, did you just by happenstance stumbie 13 Q. And during those times when you've been there, 20 _ into the Florida Science Foundation, or was it related 26 without having to go through each conversation, did you 21 to your relationship with Jeffrey Epstein? 21 ever talk to him about the fact that he was on probation 22 A. f've heard that's where his office was. | 22 orthat he was ~ 23° mean, { have no other -- 23 A, No. 24 Q. Why did you go there? 24 Q. any part of the criminal investigation? 25 A. Talk about airplanes. deli 25 A. No, not at all. 130 132 1 Q. Talk to who? 1 Q. What was the purpose of the conversation? 2 A. Jeffrey. 2 A. We were sometimes talking about TVs, you know, 3 Q. Jeffrey just happened to be at the Florida 3 the latest plasma that's out there, LCD, you know, 4 Science Foundation? 4 setting up a stereo systems, you know, in the Palm Beach 5 A. Yas. 5 house. That's usually the main thrust of our 6 Q. How did you know that he was gaing to be at 6 conversations these days. 7 the Florida Science Foundation? 7 Q. How wauid you know to go to the Florida 8 A. He called me and told me. 8 — Science Foundation on each of those occasions? Would he 9 Q. And he said come to the Florida Science 9 just cail you? 10 Foundation to talk to me about what? 10 A. Yeah, he would call me and say come on by or! iL A. Maintenance on the airplanes, upcoming. It's | 11 gota brochure on a new Samsung. 12. an ongoing. 12 Q. With each time you were at the Florida Science: 13 Q. And did he have an office there? 13 Foundation, how long would you stay typically? 14 A. Yes. 14 A. Ten, fifteen minutes, Not much more than 15 Q. So this is -- when you walked in, this is the 15 that. 16 place that's right next to Jack Goldberger's office? 16 Q. You would go there for fen or fifteen minutes, 7 MR. CRITTON: Form. 17 have a conversation about a TV and leave? 18 THE WITNESS: Yes. 18 A. Yes, sir, 19 8YMR. EDWARDS: 19 Q, Why couldn't you have that conversation over 20 Q. And you walk in and there's a reception desk 20 thephone? What was it about? 21 right there? 2h MR. CRITTON: Form. 22 A. Yes. 22 THE WITNESS: if il was pertaining toe TV and 23 Q. 1s that where you taiked or did you talk 23 I'd have a brochure, a picture of the TV -- one 24 somewhere behind that reception desk? 24 particular TV we looked at it was the size of a -A. Behind the reception area. 25 like five foot diagonal, so ! had a photo of myself

Larry Visoski October 15, 2009 133 135 1 standing next to it or the salesperson. Sof mean, i A. We've ianded in Paris. 2 there's a reason to visually show him something 2 Q. You're aware that he has some contro! over 3 reference to that. 3 another piece of property over there? 4 BY MR. EDWARDS: 4 A. know we've picked up luggage at 2 residence. 5 Q. Did you ever communicate with Jeffrey 5S — 1 don't know to what extent his ownership is, if any. 6 Epstein ~ you can send him an e-mail, right? You could 6 Q. All right. 7 have done that? 7 A. Right. 8 A. Yes. 8 Q. And are you aware that he has some employees 9 Q. To send him the picture or something like 9 that listen to what he says that work in that house? 10 that, that was an option? 10 MR. GRITTON: Form. aL A. Right. 1. THE WITNESS: in Paris, yes, there is one 412 Q. And what's Jeffrey Epstein's e-mail address 12 person there. 13 that you use? 13 BYMR. EDWARDS: 14 A. | have to do it on my computer, you know, 14 Q. What's his name? 15 with — I have to type in the prompts for it because 15 A. Volizan. Because | aways thought there was 16 ~~ it's a long e-mail address. 16 nobody thera. a7 @. Okay. How fong have you e-mail corresponded | 17 @. Vultzan Cauldron (phonetic)? 18 with Jeffrey Epstein? 18 A. I don't know exactly. 1 would have fo look it 19 A. Probably two years. A year to two years. | 19 up. 20 mean, it's fairly -- something we just started doing. | 20 Q. Have you talked to him before? 21 mean, we'd never done that in the past. 24 A. No. 22 Q. Well, in the past he was in jail or have some 22 Q. When you've been in Paris ~ 23 restrictions? 23 A. You're not going to ask why? 24 A. The restrictions, yes. 24 Q. Well, 'm assuming he doesn't speak English. 25 Q. Se you you'd see him on the airplane 25 A. There you go, okay. 134 136 1 frequently? z Q. Sol thought there was no need for that? 2 A. Exactly. 2 A. Okay. | Just wanted to see. 3 Q. So when you didn't see him on the airplane 3 Q. Where do you stay when Jeffrey Epstein is in 4 frequently, then some of your correspondence was by 4 Paris? 5 e-mail, other times by telephone? 5 A. Ahotel. 6 A. Mm-hmm. 6 Q. Okay, And in New Mexico, when you land there, 7 Q. And other times in person? 7 you stay on the ranch somewhere, but at your place? 8 A. Yes. 8 A. | stay at my piace. 9 Q. And what was your e-mail -- what was the 9 Q. And in New York, you have an apartment that he 10 substance of the e-mail correspondence that you would} 10 — sets you up at, right, the 301? 11 have with Jeffrey Epstein? li A. Yes, | have a place | could stay. 12 A. it would have to be related. | mean, you have 12 Q, And in St. Thomas? 13 to give me atopic. | mean, whether it be a car ~- 13 A, Hotel. 14 @_ Never about the criminal investigation? 14 Q. And in Paris you stay at a home? 15 A. Oh, no, no, never. 15 A, (Nodding.) 16 @. Do you know what his intention is or his plans 16 Q. Are there any other properties such as what we 17 are for when he is off probation? 17 were talking about today ~ I'm not saying Jeffrey 13 A, No idea. 18 Epstein is the sole owner or direct owner, but any other 19 Q. Or off community controi? 19 properties that you're familiar with that Jeffrey 20 A. 1 have no idea. 20 Epstein is — has direct access to and at least it gives 24a Q. Has he ever indicated to you he wants you to 21 the appearance to you that he is the owner or controller 22 fly him to some other location outside the United States; 22 — of that property? 23 to live permanently? 23 MR. CRITTON: Form. 24 A. Oh, no. 24 THE WITNESS: Name the list that you've Q. Have you ever flown to his place in Paris? 25 stated.

Larry Visoski CRIA RW 137 BY MR. EDWARDS: Q. The Manhattan house. A. Yes. Q. Mansion or whatever we want to caif it, the Zorro Ranch, the island of St. James, the Paim Beach house. A, Mm-hmm. Q. And the Paris piace. A. That's alt 'm aware of. Q. And have you ever at eny of those five places hung around him and stayed around him for -- during the daytime for the course of an entire day? A. No, Q. Ali tight, So do you know what he does during his days while he's there? A. No. Q. Are you aware of a list of underage girts that is kept to come over and service him each of those days?) MR. GRITTON: Form. THE WITNESS: Absolutely not. BY MR. EDWARDS: Q. I'm the first person te ever even imply that te you, right? A. Alist, yes, you are. Q. Okay. Have you ever been made aware that 138 Sarah Kellen keeps a list of underage girls to service Jeffrey Epstein for sexual purposes? A. 1am not aware of them. MR. CRITTON: Form to the last question. BY MR. EDWARDS: Q. Have you ever been made aware that Ghislaine Maxwell keeps a list of girls in the nearby areas of each of - at Jeffrey Epstein's residences to service him sexually? A. No. MR, CRITTON: Form. BY MR. EDWARDS: Q. Okay. Have you ever read some of the compiaints that have been fited against him in the various courts, whether state court or federal court, against Jeffrey Epstein? A. No, Ehave not. Q. Ali right. So this Jane Doe 102 versus Jeffrey Epstein, you're not familiar with who that person is? A. No idea. Q. Okay. I'm going to mark Jane Doe, one of the 22, versus Epstein as Exhibit No. 4 to this deposition. (Plaintiff's Exhibit No. 4 was marked for identification.) October 15, 2009 139 BY MR. EDWARDS: Q. And ask you about some of the allegations in here and see if you know anything about them. It indicates he owns a flight of aircraft that includes a Gulfstream, a helicopter, and a Boeing 727, True? MR. CRITTON: What's the question? THE WITNESS: Piease repeat. BY MR. EDWARDS: Q. Are you aware of him owning a Gulfstream IV aircraft, a helicopter and a Boeing 7277 | think we talked about it, right? A. Right. Q. Okay. And it indicates a fleet of motor vehicies? MR. CRITTON: Wait a minute. He said right, is that we talked about it, as distinct from him knowing one way or another. THE WITNESS: What's the question? BY MR. EDWARDS: Q. Do you know that he owns those things? A. | do not know that he owns them. . Do you believe that he owns those things? MR. CRITTON: Form. THE WITNESS: ! would be guessing, so... 140 BY MR. EDWARDS: Q. What does the company NES, LLC, do to your knowledge? A. thave no idea. Q. How does that company generate profit, if you know? A. Vhave no idea. . Q. That's the company that pays your paycheck, but you have absolutely no clue what they do to generate money? A. No, sir. Q. tfanything? A. Correct. Q. Have you ever heard that that company generates money through sex trafficking of young girls? MR. CRITTON: Form. THE WITNESS: Absolutely not. BY MR. EDWARDS: Q. Never, okay. Have you ever heard that Jeffrey Epstein has a sexual preference for underage girls? Other than what you've read in the newspaper, have you heard that from any other individuals before? A. No. Q. Ever heard that he has had sex or sexual relationships with many minor gitls, some as young as 12

Larry Visoski October 15, 2009 COI TAHeYNe 10 il 12 £3 14 is 16 aad 18 19 29 21 23 24 25 wedanvewne 14. y 143 years old? 1 about that? MR. CRITTON: Form. 2 MR. REINHART: Hoid on. The question is have THE WITNESS: No. 3 you ever been told that fact that he just read to BY MR. EDWARDS: 4 you? Q. Never? 5 BY MR. EDWARDS: A. Never. 6 Q. Right. Q. Have you ever seen any photographs in any of 7 A, | have never been toid that fact. his homes depicting young-looking girls engaging insexj 8 Q. Has anybody ever questioned you about your acts? $ possible involvement with helping to facilitate A. No. 10 Mr. Epstein have sex with underage girls? Q. Or reading directly from the compiaint, qi A, No. “engaged in lewd acts"? 12 Q, When you were questioned by either the police A. No, absolutely not. 13 or the — whoever the investigative resource that was Q. Have you looked around the wails of his 14 being used at the time? various homes when you're in there picking up luggage?} 15 A. Right. A, |mean, not any more than | walked in here and 16 Q. Do you remember who that person was that was net looking at the wails over there, | couldn't tell you 1? questioning you? what those are; so nothing specific. 18 A, No, i don’t remember. Q. Sometimes we're talking about a 50,000 square 19 Q. 1 know you don't know the focation where it foot house? 20 was, but do you remember who they were affliated with? A. Exactly. 21 A. No. Q. In Manhattan? 22 Q. Was it only one time? A. It's pretty big. 23 AL Yes. Q. Okay. Have you ever looked at any of his 24 Q. Did you also have to testify before a grand computers for any reason? 25 — jury proceeding? 142 144 A. No. 1 A. No, | did not. Q. 1 know that you helped set up some of the ~ 2 Q. Have you ever known Mr. Epstein to get a A. Computers are nat my expertise. 3 massage while on an alpplane? Q. Ailright. Have you ever been told that 4 PHONE ATTORNEY: This is everybody in Boone, Mr. Epstein committed sex acts against underage girs on! $ Charles and the witness is here and the court a literal daily basis, that's what he does? € reporter and the videographer. A. I've never been toid that. 7 MR. EDWARDS: Fantastic, but I think that you Q. Have you ever read the complaints against him 8 may have the wrong room, that indicate that's what he does on a daily basis? 9 PHONE ATTORNEY, ‘I was told to ask for 856. MR. GRITTON: Form. 10 MR, EDWARDS: Let's go off the record. THE WITNESS: No. ii {Off the record discussion.) BY MR. EDWARDS: 12 BY MR. EDWARDS: Q. Soin your mind, you never believed that you 13 Q. Allright. In the complaint, fm going to were transporting around somebody whose sole goal in 14 elt you what it alleges and I'm going fo ask if this life is to get -- have sex with [ittie girls? 15 helps to refresh your recollection about any of Jeffrey MR. CRITTON: Form. 16 Epstein’s activities. The defendant, Jeffrey Epstein, THE WITNESS: | never believed that, no, 17 transported the plaintiff to another state in order to. BY MR, EDWARDS: 18 — engage in sex acts with her. And this accurred when she Q. Okay, Have you ever been totd that he 19 was merely 18 years old. conspired with others, including assistants and/or his 20 ‘Do you remember transporting somebody that drivers and/or pitots and his friend Ghisiaine Maxwel, 21 looked like they were 15 years old on your airplane? to further these sex acts and to avoid police detection? 22 A. No, sir MR. GRITTON: Form. 23 Q, You never remember taking a 15-year-old, or BY MR, EDWARDS: 24 — somebody that icoks around that approximate age, on your Q. Have you ever — anybody ever questioned you airplane?

Larry Visoski October 15, 2009 145 147 A. Can you be more specific? 1 Q. To Santa Fe? Q. Well, | know that you've indicated earlier in 2 A. Yes, the deposition that you remember some girls under the 3 Q. ToLos Angeles? age of 18 on the airpiane. And so let me ask, before 4 A. Yes. get back into this, whether all those individuals you 5 Q. To San Francisco? were taiking about were accompanied by a parent or some 6 A. Yes. of those people were on the airplane for some other i Q. To St. Louis? purpose, modeling, or you don't knew why they were 8 A. Yes. there? ?'m going to let you elaborate on who these 9 Q. Allright. Continuing to internationat pecpie are that you befieve may have been under the age 10 destinations, including Europe, have you ever flown it of 18 and why you think they were on the airplane? 11 to Europe? MR. CRITTON: Form. 42 AL Yes. THE WITNESS: We've had younger people on the 13 Q. The Caribbean? airplane that have been, you know, with their 14 A. Yes. family members, like you said. 1 don't remember 15 Q. And Africa? transporting anybody that was of questionable age. 16 A. Yes. I'm not -- I'd only be guessing at somebody's age 17 Q. On those flights to those various places, is if | didn’t ID them at the foot of the airplane. 18 — ityour -- to the best of your knowledge, you were So | can't guess to their age. 19 unaware of Jeffrey Epstein engaging in sex with underag: BY MR. EDWARDS: 20 girls on his airplane? Q. Allright. “Mr. Epstein used his private jet 24 MR. CRITTON: Form, to transport the minor plaintiff to Manhattan where he 22 THE WITNESS: [have no knowledge of any of provided her spending money and accommodations with him} 23 that. at his mansion." 24 BY MR. EDWARDS: Do you have any idea who that might be 25 Q. "He provided accommodations with him in order 146 148 referring to? 1 to have her available to him at all times whenever he MR. CRITTON: Form. 2 wanted, including while transporting the minor plaintiff THE WITNESS: No, sir. 3 on his private jet.” BY MR. EDWARDS: 4 That's something that you had no knowledge of? Q. And you don’t remember being a pilot of an 5 A. (Witness shakes head.) airplane where he was transporting a 15-year-old to 6 Q. You have to a yes or no. Manhattan from Miami or Palm Beach? 7 A. I'm sorry, no. A. No. I'd be guessing at somebody's age and | 8 Q. "Each time they would travel to one of these can't guess. 9 destinations, the same pattarn of sexual abuse would Q. "Defendant transported plaintiff in his 10 occur, often with a vast array of aspiring models, private jet to locations that included Paim Beach, New} 11 actresses, celebrities, and/or other females, including York City, Santa Fe, Los Angeles, San Francisco, 12 minors from ail over the world.” St. Louis." 13 Again, that's something you have no personal Do you remember ever piloting his airpiane to 14 knowledge of? those destinations that | just mentioned? 15 A. No. MR. REINHART: Can we break them down? 16 Q. Has anybody ever indicated that if you did Objection; compound. 17 have personal knowledge of some of these things, then: MR. EDWARDS: Okay. 18 you could also have been implicated in some form of a BY MR, EDWARDS: 19 crime? Has any law enforcement or anybody ever Q. Have you ever flown his airplane to Palm 20 indicated that to you? Seach? 22 A. Ne. A. Yes, sit. 22 Q. Okay. 1s that something you've ever worried Q. Okay. Have you ever flown it to New York 23° about? Gity? 24 A. No. AL Yes. 25 Q. Allright. "Upon information and belief,

Republic before. Anywhere within that country, have you 28 a Larry Visoski October 15, 2009 149 151 1 defendant transported minor girls from Turkey." Did you 1 ever flown to or from in a Jeffrey Epstein airplane? 2 ever leave in one of his airplanes out of Turkey? 2 A. We have flown to Prague. 3 A. I'd have to look at the records. | don't 3 Q. Okay. Have you picked people up in Prague and 4 recall Turkey. 4 flown out of Prague? 5 Q. Do you ever remember taking any minor girls 5 A. | don't remember. 6 — out of Turkey? 6 Q. Im not saying no, you didn't, but -7 A. No, 1 don't remember, 7 A. Best of my knowledge. 8 Q. What records would you have to jook at to see 8 Q. - you don't remember? 9 if you took people out or left out of Turkey? 9 A. Exactly. Best of my knowledge, i don't 10 A. I'd have to look at the flight fogs, but t 10 = remember. 11 personally don't remember flying into Turkey. 11 Q. Do you remember the reason for going to Turkey; 12 Q. And would the flight jogs coming into the 12. orto Prague? 13 United States from Turkey indicate the names of the 13 A. No. 14 people on the plane? ia Q. This also says Asia. Have you ever flown to 15 A. They might, 15 or from Asia with Jeffrey Epstein? 16 Q. Okay. Where would | get those particular 16 A. Yes. 17 flight fogs that would have that information? 17 Q. Orona Jeffrey Epstein airpiane?: 18 A. Depended upon what year you're talking. 18 A. Yes. 19 Q. We're talking in this particular complaint 29 Q. Do you know the purpose of those flights to 20 between 1998 and 2002, 20 and from Asia? 21 A. tm not — I don't possess those passenger 21 A, No. 22 manifests. 22 Q. Did it ever occur to you that maybe it was to 23 Q. De you know who would possess those? 23 pick up minor giris for him to have sex with on the back 24 A. That would be | guess -~ 24 of the airplane? 25 MR. REINHART: Do you know who has them tosey4 25 MR, CRITTON: Form. | 150 152 2 THE WITNESS: | do not know who has them 1 THE WITNESS: Never occurred to me. 2 today. 2 BYMR. EDWARDS: 3 BYMR. EDWARDS: 3 Q. Did you ever hear that he maintained some of 4 Q. Who did you give them to? 4 these underage girls as sex slaves — 8 A. Actually, | didn’t give them to anybody. Dave 5 A. Never heard of such a thing. 6 Rogers was in possession of those logs. Solden'tknow 6 Q. -- from the age of 12 through the age of 167 7 where they are right now. 2 MR. CRITTON: Form. 8 Q. You're still thinking that the best evidence 8 THE WITNESS: No knowledge of that. 9 of that, any flight that may have left out of Turkey, 9 8YMR. EDWARDS: 10 would be in the flight fogs that's marked as Composite 10 Q. Ever picked up gitls that looked young, many 11 ‘Exhibit 1, or are we talking about the manifests that 11 of whom who spoke no English? Do you ever remember 12 we've been referring to? 12 that? 13 A. _| don't know how accurate that og book is or 13 A. Zero, do not. 14 even how accurate the passenger manifest is. 14 Q. Allright. The compiaint goes on to say, 1s Q. Okay. So there may be no actual documentation; 15 “Plaintiff was required to be sexually exploited by 16 indicating a flight leaving out of Turkey when, in fact, 16 = defendant's adult male peers, including royalty.” So 17 a flight may have left out of Turkey? 17 Fm going to talk, do you have any familiarity with 18 A. Correct. 18 Prince Andrew? 13 Q. Okay. The Czech Republic is the next place 19 A. iknow who he is. 20 — fisted. Is that a place you've flown to or from ina 20 Q. Was he ever on the airplane? 21 Jeffrey Epstein airplane? 21 A. He may have been on the airplane. 22 A, More specific, could you name the city? 22 Q. Do you remember him on the airpfane with young 23 Q. | can't name the city, at feast the complaint 23 gits? 24 — doesn't name the city. But I've been to the Czech 24 A. No, } do not. 25 Do you remember Jeffrey Epstein flying in to

Larry Visoski October 15, 2009 153 155 1 meet with Prince Andrew? 1 BY MR. EDWARDS: 2 A. | don't remember. | know that happened, but! 2 Q. Okay. Do you remember who else was on th 3 couldn't be accurate. 3 flight that left after 10 p.m.? 4 Q. Has Prince Andrew ever been on the airplane at 4 A, No, Ido not. 5 the same time as a young gitl, to the best of your 5 Q. Do you remember why it left after 10 p.m.? 6 memory and knowledge? 6 A. No, I do nat. 7 A. To the best of my knowledge, no. 7 Q. Do you remember Jeffrey Epstein instructing gs Q. This aiso says politicians, talking about 8 you to wait until after 10 p.m. to leave? 9 — focal or U.S. politicians. Do you remember certain 9 A. No. 10 politicians being on the airplane? 10 Q. Would you nave listened to him if he had told 4 A. No—1 mean yes, I do. 11 you ~ if he had instructed you to do that? 12 Q. What politicians would that be? 12 A. i don't understand the question. 13 A. President Clinton. 13 Q. Well, if he told you wait until after 10 p.m., 14 Q. Okay. Who else? 14 I realize there's going to be a fine, but wait untit 1s A. Former president of Israei -- help me out with 15 after 10 p.m. to leave, intentionally teaving 16 the name, Barak? 16 after 10 p.m., do you remember that instruction ever -~ WwW Q, Ehud Sarak? 17 A. No, I don't remember that instruction. 13 A. Yes, those are the bwo that | remember. 18 Q. Okay. 19 Q. How many times was Ehud Barak on the airplane) 19 A. {i mean, it just happened fo be departing 20 that you piloted for Mr. Epstein? 20 after 10 and there is a penalty for ieaving after 10 for 21 A, Maybe once. 21 noise. So there was no intention to... 22 Q. And where did that flight pick up and where 22 Q. Allright. This also talks about this 23 diditgo to, to the best of your memory? 23 particular person 15 years oki being sexually expioited 24 A. Best of my memory, it was Palm Beach to 24 by businessmen and/or other professional or personal 25 ‘Teterboro. 25 acquaintances. Are you aware of other personal or 154 156 a Q. Where fs Teterboro? 1 professional acquaintances of Jeffrey Epstein also 2 A. In New Jersey. 2 sexually abusing or exploiting tittle kids or underage 3 Q. And what was the purpose of that flight, do 3. girls on your airplane? 4 you know? 4 MR. CRITTON: Form. 5 A. i don't know. 5 THE WITNESS: No. 6 Q. Was Jeffrey Epstein on the flight? 6 BYMR. EDWARDS: x A. Id have to look at the flight logs to 7 Q. Ifyou had been aware that Mr. Epstein was — 8 guarantee. & and by this -- this Is more in the form of a 9 Q. Anything about that flight stick out in your 9 hypothetical, and that I'm not going to suggest to you 10s mind? 10 it's a fact that he was, But if you had been aware that a A. None. 11 every single day Jeffrey Epstein's goal was to locate 12 Q. Such as a fine needing to be paid because it 12 underage girls for the purposes of sex, and either have 13 left after 10:00 p.m.? 13 sex with them on the airplane or at some other 14 A. For that was the flight, yes. 14 — designation that you were destination that you were 1s Q. You remember that? 15 traveling him to, would you have continued to pilot 16 A. it's coming back to me. 16 = those planes? 17 Q. And do you remember young girls being on that} 17 MR. CRITTON: Form. 18 flight? i8 THE WITNESS: You said it was hypothetical? 13 A. No. 19 BY MR. EDWARDS: 20 Q. Ali right. 26 Q. Right, itis a hypothetical. a1 A. | remember the fine. 21 A. Why would | want to answer that? Because 22 Q. D0 you remember whe paid the fine? 22 you're being hypothetical. | mean, it would obviously 23 MR. CRITTON: Hold on. Let me object to form 23° be wrong. 24 of the question. "De you remember" it suggests 24 Q. Sure. Weil, a hypothetical question is a 25 that there were. Sa form, predicate. 25 legal question that I'm allowed to ask.

Larry Visoski October 15, 2009 157 159 MR, CRITTON: Form. 1 A. Okay. L THE WITNESS: Never heard of such a thing. 2 Q. And ['m just asking you if you did have 2 BYMR. EDWARDS: 3 knowledge that Jeffrey Epstein was having sex with 3 Q. Do you know of any friends that he has in 4 _ Sittle girls either on the plane or at a piace that you 4 France that would send him birthday -- a birthday 5 — were taking him to or from an a daily basis, that's what 5 present? 6 he did, would you have continued to be his pilot? 6 A. No. a MR. CRITTON: Lat me object. Object to the 7 Q. Do you know of him receiving any birthday 8 form. it's argumentative. thes no more value 8 gifts or birthday people from anyone? 9 than assuming he was chopping up bodies or anybod) 8 A. Never. 10 was chopping up bodies in the plane you're flying, 10 Q. This particular person that filed this iL What difference does it make? Form. 11 complaint, Jane Doe 102, indicates "Defendant and 12 MR. EDWARDS: What difference does it make in 12. Ghislaine Maxwell acknowledged and celebrated 13 a case about him having sex with littie giris? I'm 13 plaintiffs 16th birthday.” 14 noi going to argue with you about it, You've 14 Do you remember them celebrating somebody who] 15 stated your objection. 15 you flew on the airplane's 16th birthday? 16 MR. CRITTON: Exactly. ifs an argumentative 16 A. don't recall. 17 question. 47 Q. Any of this jog your memory as to who Virginia 18 MR. EDWARDS: I'm not going to argue with you 18 Roberts is? 1g about it. a9 A. No. 20 MR. CRITTON: You're arguing with him about 20 Q. “From the age of 15, plaintiff" — this Jane 24 now, 21 Doe 102 ~ “was sexually exploited and abused by 22 MR. EDWARDS: No, I'm asking him the 22 — defendant on a daily basis and often multiple times each 23 hypothetical. 23 day? 24 BY MR. EDWARDS: 24 ‘So going back, was there ever a day where you Q. Can you answer that? Would you have continued} 25 were with Jeffrey Epstein where you could observe hint 158 160 1 te bea pilot for somebody who's traveling to and from 1 and Virginia Roberts during an entire day? 2 destinations with the goat of having sex with underage 2 MR. CRITTON: Form. 3 girls? 3 THE WITNESS: I don't remember Virginia 4 MR. CRITTON: Form. 4 Roberts, so | couldn't answer the question. 5 THE WITNESS: It could be any person. it S BY MR. EDWARDS: 6 doesn't have to be Jeffrey Epstein, then, right? 6 Q. "in September 2002, Defendant Epstein 7 BY MR. EDWARDS: 7 purchased a commercial round-trip airline ticket and 8 Q. True. 8 provided a passport, U.S. currency and accommodations| 9 A. No, | wouldn't pilot an airplane if there was 9 for plaintiff to fly to Thailand." 10 ~— wrengdoing going on. 10 Do you remember him doing that for anybody a1 Q. That you knew about? 11 around that time period? 12 A. Thai | knew you about, sure. 12 A. No, sir. 13 Q. Me reading this complaint to you, is this the 13 MR. CRITTON: What was the date? 14 first time you've heard these allegations -- 14 MR. EDWARDS: September 2002. 45 A Yes. 15 MR. CRITTON: Okay, thanks, 16 Q. -- against Mr. Epstein? 16 MR. EDWARDS; / have here — and this is 17 AL Yes. 17 actually my only copy, so | don't mind marking it 18 Q. It goes on to say, "On one of Epsisin's 18 as a composite exhibit, but we'll either have to 19 birthdays, a friend of Epstein sent him three 19 copy this while thing or we'll have an agreement of 20 12-year-old girls from France who spoke no English fon 20 counsel. It's the visitor inmate log from when 21 the purpose of — for defendant to sexually exploit and aa ‘Mr. Epstein was in jail in Palm Beach. 22 abuse. After deing so, they were sent back to France | 22 MR. CRITTON: Well, before we get started, it 23 the next day." 23 is now 1:15. We started at 10:00. 24 Are you famitiar with that occasion? 24 MR. EDWARDS: We didn't really start at 10:00. MR. CRITTON: Shortly thereafter. | was here

Larry Visoski 161 pretty much after 10. But we've been here since 10:00. | want to take a lunch break. MR. EDWARDS: Let's do it, MR. CRITTON: For an hour? MR. EDWARDS: Sure. {A break was had at 1:15 p.m.) BY MR. EDWARDS: Q. Albright. | looked through the inmate log of the visitors who visited Jeffrey Epstein and your name appears one, two, three, four, five, six, seven, eight times. A. Okay. @. Seem to be accurate in terms of how many times. you went to visit him? A. thought six, but yes, that's... Q. |'llet you review the records and tell me if you dispute any of that record. And I'll go ahead and mark that as Composite Exhibit 5. {Piaintiff's Exhibit No. § was marked for identification.) MR. REINHART: It's two pages. MR. EDWARDS: Two pages, MR. REINHART: Okay. BY MR, EDWARDS: Q@. Seem accurate? 162 A. Yes. Q. Okay. Jeffrey Epstein's plea, | believe, was June 30th, 2008. | think that's when he was taken in custody from there. Your first visit is July 3rd, 2008. And the other name on that visit is Igor Zinoviev. Did you go with Igor to visit Jeffrey Epstein? A. Yes. Q. Why did you go with Igor? A. It just happened he wanted to see us both at the same time. There was no apparent reason. Q. How did you know that Jeffrey wanted to see you? A. [don't recall who called and told me that he wanted to see me. | couldn't give you an accurate name, whether it was, you know, his attorney, Darren. And actually, | would put a lot weight to | think it was Darren, his attorney. Q. That would have made 4 phone cail to you that said -~ A. Yeah, to go. Q. And what did you talk about with Jeffrey Epstein four days after he pled guilty to offenses that landed him in jait? A. [think the first visit was how disappointed or how scared he was, you know, being inside there. We: CRIHAHeYNHH October 15, 2003 163 just talked about general happenings that go on in there. Q. What did he say? A, it's terrible; it's cold; he can't sleep. They wake him up every two hours. You know, just item: like that, uncomfortable things. We talked about the airplanes a great deal. You know, we got major maintenance on the big airplane, so we discussed that a little bit, And then it was really just how uncomfortable he was there. Q. How jong did you visit with him on that first visit, July 3rd? A. [think we stayed the fuil hour. Q. Altright. Is that what the time aliofment was? A, tf believe itis, yeah, | don't think you could feave early, or 'm not aware that you could leave early, until later on we found out you could stay for five minutes or fonger. But | don't think any of us knew that was — once you got in there, you stayed there for the hour. Q. Okay. So you talked to him for an hour and for the most part it was just about the conditions and his disappointment with the conditions? A, Sure, yeah, absolutely. 164 Q. And did Igor talk to him as well? A. Briefly. | mean, not that much. You're going back a little ways again to remember exactly what was discussed. You know, he asked how his family was doing. i guess igor's got a son, | think he asked how his son was doing. You know, just general questions like that, Q. Did you ride to the jail that day with Igor? A. |} believe we did. | believe | met Igor probably at Jeffrey's house and picked him up, or if not, we may have met at the airport and drove together. But we did drive together on that occasion. Q. In what vehicte did you drive? A. The Hummer. Q. That's the vehicle you described eartier as the company vehicie? Yes, sir. . 1s that a vehicle paid for by Jeffrey Epstein? . Meaning? . Weil, is that a vehicle paid for by you? . What do you mean "paid for"? . Did you purchase the vehicle with your money? . didn't purchase that one, no. Q. Do you know If it was purchased by Jeffrey Epstein or a corporation of Jeffrey Epstein's? A. Probably 2 corporation. POPOPOP,R

Larry Visoski October 15, 2009 165 167 1 MR. CRITTON: Form; move to strike. Sounds 1 facility that was holding Jeffrey Epstein, they're 2 like a guess. 2 ~~ accurate, your name is the first one listed on the top 3 BY MR. EDWARDS: 3 of the sheet? 4 Q. To the best of your knowledge, that’s how most 4 A. Right. There may have been eartier dates. | 5 of the items that you've discussed -- that being the 5 have no idea, 6 Boeing and the Gulfstream - they were usually held in 6 Q. Weil, you know, the first date that he could 7 corporate names, to your knowledge? 7 have been in there it looks like was 7/1/08 and then, 8 A. To my knowledge, exactly, yes. 8 you know, so | guess somebody could have seen him 7/1 or 9 Q. And so when you're saying the — when you're 9 7/2, but those records were never provided to us. You 10 talking about the Hummer vehicie and you're stating that; 10 see we were provided a whole big stack. 11 it’s fkely @ corporate entity, is that just something al A. tunderstand. 12 that you're guessing about, os de you have knowledge? 12 Q. The next date I'm going to talk to you about 13 A. No, fm just guessing. 13 Is 7/12/08. 14 Q. Okay. 14 A, Ub-huh, 15 A. Thave no proof ~ 15 Q. itooks, again, like i's yourself and Igor 16 Q. —of ownership of who it's registered to or 16 © Zinoviev? 17 anything like that? 17 A. Mathmm. 18 A. Exactly. 18 @. And that's something we talked about in this, 19 Q. Is it registered to you? 19 deposition. ['m going to ask you again, I don't know 20 A. No, no, 20 that you elaborated last time, what is your 21 Q. So it’s registered to somebody other than you? 21 understanding of his relationship with Jeffrey Epstein? 22 A, Exactly. 22 Is thata friend of his? 23 Q. Okay. 23 A. I don't know his job description. | mean, 24 A. [just drive it, Eguess. 24 he's somebody that's around a lot, but | don't know his I 25, Q. Okay. So on July Sth, 2008, you go back to. 25 exact job description. His English is, fo say, not 166 168 1 see him in jail again, and again, Igor Zinoviev is. 1 100 percent, so conversation with somebody that doesn't 2 listed as a visitor. Did you go with him together on 2 fuy understand you, you know, you get lost in 3 that occasion’? 3 translation a little bit. So | don’t ~ 4 A. tI didn’t even realize it was two days after 4 Q. So on these three visits to the jail, the 5 the first visit. 5 first three that we're talking about that we've talked 6 Q. Wel, 1 mean, you see where this is going? 6 about so far, each of those times you traveled to and 7 A. Yeah, 1 do. It gets further apart, yeah. 7 from the jail with Igor? 8 Q. Do you remember what the discussion was on 8 A. Me-hmm. 9 715108? 9 Q. Yes? 10 A. No, because it’s probably similar to the first 10 A. Yes, yes. 11 one. I mean, we talked — actually, one of the visits 11 Q. And each of those time, is it fair to say you 12 we talked about fishing and just trying to — you know, 12 had some form of communication either on the way to nd 13 we were talking about things that would just occupy his} 13 — Jait or — 14 mind with intelligent conversation that he probably 14 A. Sure. 15 wasn't getting there. So for that hour of the day, | 1s Q. --to the jail? 16 tried to give my best of intelligent conversation to 16 A. Yeah. 17 him. ay Q. Since you're going to see an inmate in the 18 Q. Okay. On his visitor log you were the first 18 jail, is it a safe assumption a portion of that 19 one te go visit him. Did you know that? 19 conversation was about the person that you're going to 20 A. | did not know that. 1 wasn’t aware of that. 20 see and possibly the crime that was committed? 21 MR. CRITTON: Let me just object to form to 22 A. Yes, that would be 2 good assumption. 22 the last question, 22 Q. Okay. And what was the form — whal was the 23 BY MR. EDWARDS: 23 substance of that conversation that you can remember 24 Q. Well, at least if these racords are accurate, 24 — zelaled to Jeffrey Epstein and the location you were 25 which are the records that were provided to us by the 25 going to visit him?

Larry Visoski October 15, 2009 169 L171 L A. | think Igor and { discussed on trying to be 1 Q. And in the course of that conversation, again, 2 upbeat and not look at the position that he’s in sitting 2 the allegations and the unusual I'l cail it case 3 across the table from us, to be upbeat and uplift his 2 against him, that didn’t come up between you and 4 spirits. 4 Mr. Epstein? 5 Q. Did you and Igor discuss whether or not you 5 A. | never talked about it with him, 6 — were going to talk to him about his plea of guilty or 6 Q. And at that point in time, what were you aware 7 the fact that he’s not registered as a sex offender? 7 ofa terms of the number of girls that he was alleged 8 A. No. & — tohave had sexual — some sort of sexual relationship 9 Q. Orwhether you were going to stay away from 9 with him at his Palm Beach house? 10 those topics? 20 A. What was the question? How many girls? 11 MR. CRITTON: Form. uw Q. Yeah, how many girls were you — 12 THE WITNESS: We never -- we don't discuss 12 A. Aware of? 13 that amongst ourselves and/or with Jeffrey in any a3 Q, — aware of? 14 way, form. as A. None. Iwasn't aware of any, to be honest. 15 SY MR. EDWARDS: 1s Q. The next visit is on 7/17/08 and it's Igor 16 Q. Okay. But that's not -- | realize you didn't 16 — Zinoviev and somebody named Jean Rene and then yoursell 17 discuss that. You've told me that, 17 Do you know who Jean Rene is? 18 A. Right, but we didn't discuss that even prior 18 A. No. 19 te going in, as you asked. i? Q. Do you think that that visit, that you visited 20 Q. Okay. So your discussion was mainly hey, 20 him at the same time that Jean Rene visited? 21 let's be upbeat? a1 MR. CRITTON: What's the date? 22 A. Yes. 22 MR. EDWARDS: t's 7/47/08. 23 Q. And that was to, in essence, maintain his 23 THE WITNESS: No, f don't know a Jean Rene, 24 spirits or raise his spirits? 24 unless somebody came after. { mean, | don't ~t 25 A. Exactly. 25 don't know a Jean Rene. 170 172 L Q. Okay. And you were doing that as a friend of 1 =BYMR. EDWARDS: 2 his, not just his pilot, right? 2 Q. Okay. And then before you visited him again, 3 A. | felt honored that he asked me to come and 3 the visitors are listed as Nadia Marcinkova or Sarah 4 give support like that, because prior to him going away, 4 Kellen? 5S __ itwas known to us that there was going to be no 5 A. Mm-hmm. 6 visitors, because { had offered to him that t would be 6 Q. Mainly those two individuals. And they jist 7 happy to come and visit him if he deemed it necessary, 7 as addresses, 301 East 86th Street as their residence? 8 and he says no, i'm not going to have anybody, 8 A. Uh-huh. 9 Q. So- 9 Q. Given your previous testimony, does that 10 A. {guess it was so bad there, that he may have 10 surprise you that they list those -- that address as 11 changed his mind and wanted to have some visitors. 11 their residence? 12 Q. When did you have this conversation with him 12 MR. CRITTON: Form, 13. where he indicated he was not going to have visitors 13 THE WITNESS: I've seen them there, so i mean, 14 while he was in jail? 14 Fm not surprised. 15 A. {don't exactly remember. itmayhavebeenon ; 15 BY MR. EDWARDS: 16 the trip heading to Palm Beach, the last flight. 16 Q. Okay. Did you know that they were visiting 7 Q. From his isiand, from St. Thomas | guess it 17 him in jail? 18 would be from? 1e A. No, didn't know who was scheduled to see him 19 A. (forgot where it started from. f might have 19 orwhatever. 20 been New York or the isiand, one of the two. I don't 20 Q. Did Jeffrey talk to you at any point in time 21 remember the last flight. 21 about Nadia Marcinkova or Sarah Kellen? 22 Q. And I mean, did at least the fact come up that 22 A. No, not at all. 23 hey, this a person who you're — is going to be in jail 23 MR. REINHART: Can we get a time frame for 24 for some time? 24 that? Ever? A. Mm-hmm, yes. MR. EDWARDS: Oh, no, well, | was talking -

Larry Visoski 173 1 ('m sorry. 2 a 4 5 6 7 g 9 10 ii 12 43 4 1s 16 17 18 i3 20 21 22 23 24 26 weavauewne October 15, 2009 175 1 atthe house. BY MR. EDWARDS: 2 Q. Those are cars that Jeffrey Epstein owns, to Q. Iwas talking right now about in the 3 your knowledge? conversations that you had with him that we've discussed 4 A. | don't know who owns them. with you and him in the jail facility. Did he discuss 5 Q. What cars are there that -- | know with this with you Nadia Marcinkova or Sarah Kellen? 6 case we're dealing wilh a lot of corporations and it's A. No, no. 7 not like asking me, Hey, what car do you own? But what Q. Did he talk to you about whether or not you 8 cars are you aware that are -- that you believe are used should talk to anybody about his criminal investigation 3 primarily by Jeffrey Epstein? or possible litigation? 10 A, Used primarily by Jeffrey Epstein, a Mercedes A. No, not at ali. 11 $600 sedan. | don't remember the year on that one. Q. The next time you see him is on August 9th, 12 Q. Okay. 2008, at the jail. In that occasion it mentions as his 13 A. There's a Cadillac Escalade. visitors that day Nadia Marcinkova, Sarah Kellen and 14 Q. Okay. Larry Visoski. Did you go to the jail with Sarah and 45 A. Those are his two main cars that he would be Nadia that time? 16 driven in or — ‘A. No. Who was on there? Which one are you 7 Q. What are the other cars that you regularly see referring to? 18 parked at his Palm Beach mansion, if there are any? Q. The next one, | tried to highlight them just 19 A. ftwoutd be a whole array. Half the time the 80 that ~ 20 parking lot is full because of construction workers, A. Right, that one. 21 -yards Keepers. MR. REINHART: 8/9. 22 Q. Okay. Fair enough. What vehicle does Sarah BY MR. EDWARDS: 23 Kellen drive or Nadia Marcinkova drive when they're dow! Q. 8/9108? 24 here, ifyou know? A. One of those two we ail drove together. | 25 A. (mean, anybody has a choice to pick out a car 174 176 don't remember which one it was. It was either the 9 or 1 or whatever there. I've seen Nadia driving a Mercedes the 16, and then the other one } met everybody there, 2 convertible. So | can't be accurate on which time we al drove 3 Q. _[s that different than the Mercedes $500 together. 4 sedan? Q. How did you'coordinate driving together? 5 A. Yes, i think its different. A, | don't exactly remember now. [ mean, | think 6 Q. When you say they have basically a choice of Sarah and | may have conversed on the phone and said dq 7 oars to drive ~ you want to meet at Jeffrey's house and we ail drive gs A. Weil, there's cars in the lot there. together? Does it make sense to get together and drive 9 Q. Obviously, they can't get in one of the one car. 10 construction workers‘ cars? Q. |s that jail visit the result of Jeffrey al A, No. Epstein requesting your presence there, or is that the 12 MR. REINHART: Let him finish his question. result of you wanting to go see him as a friend in jait? 13. BYMR. EDWARDS: A. Acombination of both. i'm sure if | said, 14 Q. So that's kind of what I'm getting at. What Hey, I'd like to come to jali and visit you, that he 15 other cars do you think that Jeffrey Epstein has -would either say yea or nay. 16 — whether it's titled, I don't know ~~ Q. Okay. And you said at least on one of those 17 A. Right. occasions you rode to and from the jail with Sarah and 18 Q. ~ but he Is the person in control of that Nadia? 19 vehicle? A. Yes. 20 A. Right. Q, And during any of ~ obviously, when you're in 21 Q. What other vehicies do you think he's the car together — well, who's driving the car? 22 controlling in Palm Beach? A. twas driving, | believe. 23 A. In Palm Beach? Q. And that's the Hummer again? 24 Q. We've named the Mercedes S500 sedan, Cadillat A. Actually, | think we take one of the suburbans 25 Escalade?

Larry Visoski 177 _ Right. . And I've identified a Mercedes convertible? . Right. In addition to that, are there any others that you're aware of? A. That he's in control of? Q. Yes. A. No. Q. And does the conversation come up between Nadia and Sarah and yourself about the reason why Jeffrey Epstein is in jail? MR. REINHART: Can we get a time frame? MR. EDWARDS: At any time. BY MR. EDWARDS: Q. Atany time have you ever had that exact conversation ever come up? A. No, we didn't talk about that among ourselves really. Q. And have you ever been told that Nadia Marcinkova provides the role of @ sex slave to Jeffrey Epstein? That's just her role in life? MR. CRITTON: Form. MR. REINHART: That's just have you been told} that. THE WITNESS: No. 178 BY MR. EDWARDS: Q. Have you been led to belleve that by anybody? A. No. MR. GRITTON: Form. BY MR. EDWARDS: Q. Do you have any — based on your observations, do you have any other opinion as to what role she plays| in Jeffrey Epstein's life, if any? A. 1 don't have an opinion on what the role is. Q. Do you agree with the criminal statutes that are in place to protect young children from sexual predators? Do you agree with those statutes? MR. CRITTON: Form, MR. REINHART: I'm going to direct him not to answer the question. (t's irrelevant and it's not likely to lead to discoverable evidence what his opinion is on a iaw that's been passed by the legistature of Florida. MR. EDWARDS: Just so the record is clear, i don't know that we did this last time, but it's been alleged in the complaint -- it has been alleged in several complaints that Jeffrey Epstein particularly prays on vulnerable disadvantaged females, underage females, and that in order to gain access to the muttitude of underage females, October 15, 2009 179 he utilizes various paopie, schedulers, pilots, handlers and other associates and co-conspirators that have a similar mentality; that is, people that do not agree with laws related to sex abuse and abuse of children. And that's why this line of guestioning regarding whether or not this witness has a motive or a bias or was involved in conversations related to his motive or bias, to continue to work for Jeffrey Epstein or believed the same beliefs of Jeffrey Epstein, is at feast teasonably calculated to the iead the discovery of admissible evidence, and that is the argument at least along those lines being made to the judge regarding these questions. MR. CRITTON: Can we talk for just one minute?} Because maybe -- can | talk with — well, | know t can talk with Bruce. Let's just take a break. {A break was had at 2:45 p.m.) MR. EDWARDS: We're back on the record. Do you have the same position? MR. REINHART: Let me say this: He previoush said he would have never allowed anything on the plane to be done iegally. ff you want to ask if he agrees with the law applied by the legislature ~ do you agree the law passed by the 180 state of Florida should be compiled with? THE WITNESS: ! don't know what the law is. BY MR. EDWARDS: Q. Okay. The laws In piace to protect children under the age of 18 from baing sexually touched, fondled, molested by people over the age of 24, do you agree with those laves? A. Yes. Q. And you agree that persons who commit a violation of those laws should be prosecuted? A. Persons that do that. MR. CRITTON: Form, BY MR. EDWARDS; Q. Yes, persons that do that. A. Persons that do that, absolutely. Q. And if you were to receive confirmed ~ what you would perceive as confirmed information that Jeffrey Epstein was one of those persons, would you continue to be employed by or alongside of Jeffrey Epstein? MR. CRITTON: Form; specutation, THE WITNESS: You're assuming that there's guilt, BY MR. EDWARDS: Q. No. ?m saying, hypothetically, if you were convinced that Jeffrey Epstein was guilty of those acts

Larry Visoski WOAH RW 181 which he pled guilty to — MR. CRITTON: Form. MR. REINHART: Can we -- for purposes of your hypothetical, what facts do you want him to assume are true? You said the facts to which he pied guilty, but the witness already said he doesn't know what he pied guilty to. He knows the charge he doesn't know the facts. BY MR, EDWARDS: Q. Solicitation of prostitution of a minor, somebody under the age of 18, MR. EDWARDS: That's the charge, right, Solicitation of prostitution of a minor? MR. CRITTON: No. | think you've got it wrong. I'll object io the form. MR. EDWARDS: Okay. BY MR. EDWARDS: Q. Then weil handle the question this way: if you were to believe based on information and evidence that Mr. Epstein engaged in sex or some form of sex acts with people of the age range of 12, 13, 14, 15 years old, would you continue your employment with Mr. Epstein? MR. CRITTON: Form; specutation, THE WITNESS: | wouid certainly be speculating 182 and | have to discuss it with my wife long and hard. i don't think | could give you a correct and honest answer at this time. BY MR. EDWARDS: Q. Okay. Given the allegations that have been made in this case, is this something that you have discussed with anyone other than your attorney? A, No, not really. Only from the fact that they're allegations and there's still a lot more work, I'm sure, to be discovered. MR. CRITTON: Let me put on there, for the — if this deposition is not typed -~ and we request it ~ I'd like at least this portion where Mr. Edwards’ last question back about five pages worth, so just if you could mark if from this page back about five pages. If nobody requests the deposition, I'd just like those five pages. MR. EDWARDS: I'm going to request the deposition, so... MR. CRITTON: Okay. We'll mark this then, so you could tell me where itis, approximately. BY MR. EDWARDS: Q. ts there a reason why you have not discussed with Jeffrey Epstein the allegations that have been made} DIATE one © 11 12 13 44 is 16 17 18 19 20 24 22 23 24 28 October 15, 2009 183 against him and the allegations contained within many of these civil complaints on behalf of girs who were under the age of 18? Is there any reason why you haven't discussed that? MR. REINHART: If that's based on conversations you had with your lawyer, then don't disciose what you and your lawyer taiked about. BY MR. EDWARDS: Q. Correct. A. thave not spoken to Jeffrey about any of this, and it was my understanding that is illegal to have conversation about this, So I've never presented any questions to him reference this case or any others, Q. it was your understanding that it was illegal to talk to Jeffrey Epstein about the allegations made against Jeffrey Epstein? A. Yes, or anything to do with the case. That's why we never discussed any portions of it. Q, Okay. So A. i may be wrong in that assumption, but ! don't Q. So the reason why you haven't discussed this with Jeffrey Epstein is you believed it was illegal? A. Correct, yes. Q. Who led you te believe that it was illegal? 184 MR. REINHART: Again, if it was a discussion you had with any lawyer, then you can just give a name, don't give a discussion of the conversation you had. THE WITNESS: |t was my own assumption. | mean, just basic criminal knowledge of knowing you're not supposed to --.you know, if somebody's in trial or in a deposition or whatever, | don't — 1 didn't think it was appropriate to discuss the maiter with them. BY MR. EDWARDS: Q, Okay. So the next two visits and | think the last two visits we'll talk about are on 9/6/2008. Actually, it looks like you visited him twice in one day; is that right? A. I don't think that's possibie. | mean, that will show how accurate the court record is. There's no! way. Q. You woukin't have visited him twice in one day? A. No. | think there's only one visitation per day. Q. Okay. And it looks like the same visitors éach time, except that it says for period three and then} the next one’s for period four. So there are two

Larry Visoski COVA eR Whe 185 different periods. Was there ever a time when they allowed you to stay for more than an hour? A. No, not to my knowledge. Q. Okay. So again, it's Sarah Kellen and Nadia Marcinkova, same questions; Did you ever ask them theit involvernent with Jeffrey Epstein? A. Absolutely not. Q. And again, what was the discussion with Jeffrey Epstein along with Sarah Kellen and Nadia Marcinkova?: A. On the last visits, i was mainly airplane stuff and tater on in the visitations, we were advised that you could leave earty, so i would only stay for maybe 30 minutes and then, you know, Jeffrey would continue his conversations with them and then } would just wait outside. Q. Okay. A. So | would do my business with him tatking about airplanes or whatever | had coming up and then exit. Q. And then why did you stop visiting him in jait after that September Sth, 2008, visit? A. 1 was never called back to visit. Q. Okay. Well, shortly after that then he was on work release? 186 A. Well, that’s true. Q. Right? A, Yeah, Q. So the next times you would have gone to see him would have been at the Florida Science Foundation, where we talked about earlier? A. {ve seen him there, yes. Q. Okay. And in fact, I think you said you saw him 20 or 30 times — A. Sure. Q. - over the last two years, last year and a half or so? A. Yes. Q. And how long would you stay each time at the Florida Science Foundation and talk to him? A. Like my original answer, ten, fifteen minutes. Q. Okay. And how frequently would you talk to Jeffrey Epstein while he was at the Fiorida Science. Foundation? MR. REINHART: fm sorry, you're talking in person or all conversations? Because he testified he had phone conversations and personal visits. BY MR. EDWARDS: Q. | was actually talking about phone conversations. So when you would call him on the CMV AKRUDH 2009 October i5, 187 telephone, how frequently would you talk to him? How frequently during a given week? Yeah. More specific? Sure. Depends upon what's going on that week. . I mean, is it somebody you would talk to him every day? A. No. Q. Allright. Weil, at that point in time, he's going from the jaif fo the Florida Science Foundation and back, and if you're not going to see him in person, and you're not corresponding by e-mail, then would you correspond by telephone, that either being you caii him or he called you? A. Yes. Q. And, you know, in any given week, what was the typical week like? | mean ~ A. How many times? Q. Yes. A, Maybe once in a week, sometimes twice in a day. | mean, it would vary. There was no routine, Q. And what would the conversation be? A. Mosily we discussed audio and video, TVs, hom theaters. [t's a niche of his and we're constantly 188 looking at new items that are out there, you know, what's the biggest LCD flat screen out there. Q. Okay. And since he's been out of jail and on community control or house arrest or whatever it is, where he’s located at his home now, have you visited hi at his home? A. Ihave been to the home. | havent visited, but | have had work to de there. Q. And have you cailed him on the telephone thera? A. Once I think I've called the house. Normally he calls me because it's usually he needs me to do ‘something. Q. And what have those conversations been about since he's been out of jail? A. Let's put a stereo in the gym, let's put a TV in the fiving room, let's put a bigger stereo in the gym, let's put a bigger, bigger stereo in the gym, let's go redo what we've done. It's always audio. He's a very audio file person. Q. Do you know of any other modifications that he's made to the house at 358 E) Brillo since the tine that he went into jail? MR. CRITTON: Form; predicate. THE WITNESS: Meaning? Be more specific. >OPo>r Q

Larry Visoski October 15, 2009 189 191 1 BY MR. EDWARDS: 1 A. No, I don't. It's not my airpiane. 2 Q. Structurai modifications, architectural 2 Q. We still don't know whose airpiane it is yet. 3 modifications? 3 The time when you took Mr. Epstein to Miami in the fast 4 A, Starting what date? 4 — month, do you know which altorney he was going to see? 5 Q. June 36th, 2008. 5 A. No, } do not, 6 MR. REINHART: | think the question on the 6 Q. And do you know whether it was related to 7 table was have you observed any structural changes 7 civil cases or criminal cases or anything else? 8 to the house at El Brillo since Mr. Epstein went to 8 A, No idea, 9 jail? 9 Q. Do you know where the location was in Miami 10 THE WITNESS: Structurai changes? 10 that he was going to? 11 BY MR. EDWARDS: ih A. No, ido not. 12 Q. Structural, architectural, anything like that, 12 Q. Other than yourself visiting Mr. Epstein at 13 changes to the house, to the interior of the house since 13 the Florida Science Foundation, are you aware of any 14 he went to jail? 14 other visitors, people that visited him? 18 A. No. I mean, ifyou could be more specific, £ 15 A. No, Pm not. Just whoever was there during my 16 — mean, you're talking furniture or? 16 visit, ‘ uy Q. I've never been in the house, so | can't be 17 Q. Okay. Are you aware of a corporation named 18 much more specific. Have you noticed any changes from} 18 the Zorro Trust? 19 before he went fo jail to afer he went to jail, the 19 A, I've heard the name, 20 inside of the house, that you could be specific about? 20 Q. Ard is that something that you've heard 2b A. No, | can't be specific. 21 relative te your involvement with Jeffrey Epstein? 22 MR. REINHART: Can | talk to Me. Visoski fora 22 A. Yes. | mean, { don't even remember where | 23 second? 23 heard Zorro Trust. | have no definition of it, but { 24 MR. EDWARDS: Sure. 24 know the name is out there. 25 (Off the record discussion } 25 Q. Okay. Is that a company that you balieve is 190 - 192 - MR. REINHART: | think Mr. Visoski can expand 1 affiliated or related to Jeffrey Epstein in some way? 2 on his previous answer. Why don't you expand, 2 A. [have no definition. | don’t know whe it is. 3 THE WITNESS: Can we go back to that one? 3 Q. Do you know how you heard about it? 4 BY MR. EDWARDS: 4 A. Idon'tremember. That's going back in the 5 Q. Sure. The question dealt with the structural 5 early days of when Zorro existed. 6 architectural changes you're aware of. 6 Q. Who was at the Florida Science Foundation when] 7 A. There has been a kitchen extension, but when 7 ~~ you would meet with Jeffrey Epstein on these meetings? 8 you asked the question, i was unaware of when that 8 A. Sarah would be there. 9 actually took place. So to be accurately answering you! 9 Q. Anybody elise? 10 question, | know there’s been a kitchen extension. f 10 A. Story would be there on occasion. That's 11 don't exactly know when that transpired, but... 11 pretty much it. 12 Q. How do you know about the extension? Howdoj 12 Q. And would they de in the same room with 13 you know this happened? 13 yourself and Jeffrey Epstein when you had conversations 14 A. Eknew what the kitchen fooked like before and 14 with him? 15 after the extension and [ don't ~ | thought it was 15 A. No, not really. Not particularly, 16 during the hurricane season when they actually did that; 16 Q. They wouid just be at the tocation?: 17 extension. 17 A. Sure, yes. 41s Q. Who made you aware of it? 18 Q. Anybody else that worked there or was 19 A. Nobody. | just walked in the kitchen and 19 affifiated with the Florida Science Foundation that you 20 noticed a bigger room than what it was. 20 know of? 21 Q. Allright. Do you know who Martin Nowack is? | 21 A, Notte my knowledge. | mean, | do my business 22 A. No. 22 and getin and get out. 23 Q. Do you ever remember him being on your 23 Q. Can anybody ather than Jeffrey Epstein have an 24 airplane, or that name of somebody being on your 24 office at the Florida Science Foundation? airplane? A. Not that | know of.

Larry Visoski —— October 15, 2009 193 195 4 Q, Allright. And were you deeded the property 1 Q. Well, we've just described this wide array of 2 that we spoke about earlier on the New Mexico ranch? is 2 cars that Jeffrey had for people to use ~ 3 that deeded to you? 3 A. Well, you said for him to use. 4 A. Yes. 4 MR. CRITTON: Hold it. $ Q. And has it been since back in, I think you 5 BY MR. EDWARDS: 6 — said 1998 or 1999 or whenever it was? 6 Q. |s there a reason why? 7 A. Yes. 7 MR. CRITTON: Wait. You guys are both tafking a Q. Okay. And do you know — and did you build a 8 ‘over one another. You need to fet him wait and 9 house onit then? 9 finish his question because if | want to assert ar: 10 A. Yes, I did. 10 abjection, neither one of you gives me 4 chance, 11 Q. Okay. And that's a property that | think you ak which may be the plan. Form. 12 said you have a mortgage on it, that's a property that a2 MR. EDWARDS; Yeah, we have a conspiracy 13 you pay -- you mortgaged that property? 13 against you. 14 A, Yes, sir. a4 MR. CRITTON: | knew it. [ll take that as an 15 Q. Allright. And as well, the home you own 15 admission. 16 here, you have a mortgage on that property as weil? 16 BYMR. EDWARDS: 17 A. Thatis correct. i? Q. Is there any reason — did Jeffrey say that he 18 Q. Allright. Are you familiar with a vehicle, a 18 wanted that vehicte to use or to be parked at his house? 19 Chevy Suburban 1500, year 1999? 19 A. No. 20 A. Do you have a color? 20 Q. Then how did It come about that you started 21 Q. No. E can tell you the plate. | could tell 21 parking that vehicle at his home? 22 you the VIN. Chevy Suburban - Chevy Suburban 1500, 22 A. | think the origination of that came when 1 23 registered to Larry Visoski? 23 started using the Hummer, that the Suburban was parke: 24 A. That would be mine. That's a white one, then, 24 in my driveway and | wanted to get it out of my driveway 25 Q. Okay. When did you get it? 25 as an eyesore. So hence, | decided to let people at the 194 196 4 A. {mn guessing. It was probably two years old 1 house drive it as a grocery shapping car or something, 2 when tgotit. Maybe 99. Maybe '01, '02. 2 orjust as extra transportation, a Q. Something you still drive? 3 Q. Okay. But when you go te park the car at 4 A. Occasionally. Its kind of a beat up car now, 4 somebody else's house, you have to let them know, Hey, 5 soit's Kind of a knock around. 5 I'm giving you the keys? 6 Q. Best of your knowledge, it stays parked at 6 A. Mm-hmm. 7 your house? 7 Q. Who did you give the keys to? 8 A. Recently it's been in Jeffrey's driveway, 8 A. don't know if | gave the keys to anybody. 1 9 but... 9 may have just feft them on the counter there and told 10 Q. Why? 10 — Yanush this is an extra car if you guys needed it to run 11 A. Just for an extra car to use. 11. around because it was an eyesore at my drivaway. 42 Q. For Jeffrey to use? 12 Q. Are you familiar with a Mercedes-Benz SUV 13 A. No, Tmean, for anybody that would come to 13° 19997 14 the house to heip out. igor { think has driven the car 14 A. Say that again. 18 before. 15 Q. Mercedes SUV, 1999 registered in your name? 16 Q. How did it come about that you began to park 16 AL Yes. 17 __ the Chevy Suburban, the 1999 car that we're talking 17 Q. And what car is that? 18 about, at Jeffrey's house? 18 A. That's my car ~ my wife's car. 1s A. When there was more activity here in West Palm 19 Q. Does that stay at your house? 20 Beach. We were never usually coming here that often, 20 A. Yes. 22 and now with alf this going on, with Jeffrey being in zy Q. And that's the car that's parked at your house 22 town longer, we needed more cars and transportation. Sq 22 now? 22 my car was just sitting in the driveway at home while | 23 A. Yes, 24 was driving the Hummer. So | decided to let them use 24 Q. Are you familiar with a Land Rover, Range 25 the Hummer at the house. 25 Rover Sport 20087

Larry Visoski October 15, 2009 Oeranewne 10 il 12 13 14 > 16 a7 38 is 20 2u 22 23 24 1 2 3 4 = 6 1 8 9 10 11 12 13 14 is 16 17 138 13 20 21 22 23 24 25 Q. Okay. Are you aware of a Mercedes-Benz CLK 197 193 A. Yes. 1 2005 registered in your name? Q. Registered in your name? 2 A. Yes. A. Yes, 3 Q. And whose car Is that? Q. And whose car is that? 4 A. That car also is a Paim Beach house car to be A. That's another extra car for the household to 5 used at the house. use at Jeffrey's house, 6 Q, What does that mean, "a Palm Beach house car” Q. And when was that car purchased? 7 A, It's a car that we park in Jeffrey's driveway A. Last year. 8 for people to use. Anybody that comes to the house can Q. And who purchased that car? 3 select a car to go anywhere, | mean, run errands, go A. itwas purchased in my name. 10 shopping, do whatever they need to do. And that was. Q. By whom? Who purchased the car in yourname?? 11 purchased the same way. It was in my name. A. Well, | put the car in my name, but the funds 12 Q. And the funds came from Jeffrey Epstein? came -from -- they were wired to my account from New 13 A, They were wired to my account. | don't know York. 14 exactly whai account they came fram. Q. From whom, though? A mysterious source just 15 Q. Again, that's a conversation that has to take sent funds? We know that didn't happen, so I'm just 16 place before -- that you have to agree to put a car in trying to elaborate here. 17 your name? A. Jeffrey had paid for the car. 18 A. Yes, yes. Q. Okay. And why did Jeffrey pay for a car and 19 Q. Andis that a conversation between yourself put it in your name? 20 and Jeffrey Epstein that takes place? A. i don't know. 21 A. Yes. G. {mean, you had to agree for this te happen. 22 Q. And what is the substance of that conversation ‘So what was the conversation between you and Jeffrey | 23 that results ina Mercedes-Benz 2005 being placed in that resulted in Jeffrey paying for a Land Rover, a 2008 24 your name? 25 Land Rover and putting itin your name? 25___A._Hejust said we need a fun carforthe house | 198 200 A. I don't recall exactly how the conversation 1 in Palm Beach. came about. He just says we want to buy an ‘08 Land 2 Q. But why put itin your name? Rover and put it in my name. So we did. | didn't ask 3 A. I don’t know. any further questions. 4 Q. You didn't ask any questions about that? Q. Did this conversation happen when he was in 5 A. No, | didn't. jail or after he was out? 6 Q. Okay. Are you aware of a Jaguar X-Type 2005) A. Meaning out on house arrest? 7 registered in your name? Q, Right. 8 A. | forgot about that one, yes. A. When you say “out” | think of the Science 9 Q. Whose car is that? Foundation. On work release, so you have to be more. 10 A. That's a Palm Beach car. specific, il Q. What do you mean “a Palm Beach car"? Q. You tell me what happened, when the 12 A. It's the Palm Beach house car, another run conversation happened relative to where Jeffrey was at 13 around for people to use. the time. 14 Q. And again, that's a conversation that has to A. I'é only be guessing again. | would say this 15 take place that results in a car being placed — probably happened a year ago, maybe less than a year 16 registered in your name? ago. fd have to look. 1 don't remember exactly the —- 17 A. Yes. Q. So it was either at a time when he’s at the 18 Q. Okay. Now we're talking about several cars Florida Science Foundation or possibly on house arrest?] 19 here? A. Itwas — no, it was definitely before house 20 A Yes. arrest. itwas probably during the time of the Florida 24 Q. That are ail being placed In your name? Science Foundation, to be accurate. 22 A, Yes. Q. Okay. Are you aware -- 23 Q. You never at any time ask any questions to A. About eight or nine months ago. 24 Jeffrey Epstein why are you placing these cars in my name?

Larry Visoski October 15, 2009 201 203 a A. Idid not, 1 Q. Who drives that car, Ford F-250? 2 Q. So your suspicions were never -- your 2 A, That was shipped to St. Thomas. 3 curiosity was never piqued at all as to why these cars} 3 Q. For who to use and for what purpose? 4 — are being placed in your name? 4 A. Well, that car should have been put under LSJ, s A. My curiosity was piqued. 5 tbe. 6 Q. You never asked him the question, you just 6 Q. What's LSJ, LLC? 7 ~~ agreed to do it? a A. Little St. James. 8 A. That's correct 8 Q. And that's a corporation? 9 Q. That goes for the Jaguar X-Type? 9 A. Yes. 10 A. Yes. 10 Q. Your understanding is that's a corporation 11 Q. Are you familiar with a motorcycle, Big Dog 11 affiliated with Jeffrey Epstein? 12 Chopper Motoreycie, 2003? 12 A. | know it's a corporation. | don't know its 13 A. That is mine. 13 affiliation to Jeffrey. 14 Q, Yours? i4 Q. At this point in time, the way that this car as A. Yes. 15 comes about is through a conversation with yourself and} 16 Q. Registered in your name for a good purpose, 16 Jeffrey Epstein? 17 tight? 17 A. Yes, yes. 18 A. Yes, itis. 18 Q. So fo make some representation that this — 49 Q. Atyour house? 19 that this corporation LSJ, LLC, you're not sure if that 20 A. Yes. 20 has any affiliation with Jeffrey Epstein? 21 Q. You use it? 2u A. I don't have any facts to tie the two. 22 A. Absolutely. 22 together. 23 Q. Allright. Ford F-250, 2008, registered in 23 Q, Common sense would dictate? 24 your name, are you familiar with that? 24 A. Yes, 25 A. it's not registered in my name. 28 Q. Okay. 202 204 1 Q. Okay. So if that's registered in your name, 1 MR. CRITTON: Form. 2 that would be a shock to you? That would be a surprise 2 BYMR. EDWARDS: 3 toyou? 3 Q. Again, that's not a car that you use, the Ford 4 A. Yes, itwould be. 4 F260? 5 Q. There should be ne documentation from you 5 A. No, it’s not even here. 6 — where you would be the registered owner of the Ford 6 Q. And when you say on St, Thomas, is iton 7 F260? 7 actual St. Thomas, oris it on Little St. James? 8 A. What year? 8 A. Na, it's on St. Thomas. it's a work vehicle. 9 Q. 2008. 9 Q. For whom? 10 A. | remember buying that car. | just -- that 10 A. For the workers, for the island. 11 shouldn't be in my name. 12 MR. REINHART: 8e careful to answer his 12 @. What do you mean you remember buying that car4 12 question, | think his question is, is it on 13 A. [do alot—ido all the car purchases for 13 ‘St. Thomas or Little St. James island? Where 14 ~~ Mr. Epstein. 1'm a car fanatic, so for years i've been 14 physically is the car, if you know. 15 the car-shopper. ['m the car fanatic. 15 THE WITNESS: f don’t know for a fact. 16 Q. Okay. But these cars aren't classic vehicles. 16 BYMR. EDWARDS: 17 ~—- These are vehicles that are not being refurbished or i? Q. It's your understanding it's on St. Thomas? 28 anything, they're being driven around town? 18 A. Yes. 19 A. No, but theyre fun. The new Range Rover is a 19 Q. And when you say “the workers," what's going 20 niece car. 20 — onon St. Thomas to where there's workers that need an au Q. This Ford F250, that's a car also that's Patm 21 F-2807 22 Beach — as you would say a Palm Beach car? 22 A. Just moving sand. | don't know the exact 23 A No. 23 detail for it. 24 Q. That's a car that stays at your house? 24 Q. What were you told about the need for this car 25 A. No. 25 tobe on St. Thomas?

Larry Visoski October 15, 2009 205 | 207 1 A. They need a work truck. 1 Q. Okay. And by “Jeffrey's boat,” it was 2 Q. Todo what? 2 purchased with Jeffrey's money? 3 A. I don't know what the detail or the — you 3 A. That is correct. 4 know, what the job detail was for the truck. They just 4 Q. Do you know how much that cost? 5 needed a work truck. 5 A. {think it was 60,000. 6 Q. So Jeffrey Epstein tells you they need a work 6 Q. Do you know how much the Ford F-250 cost? 7 truck on St. Thomas and that's the only description that 7 A. Twenty-five, I'm guessing, batipark, 8 —-you'te given? 8 @. Do you mow how much the Jaguar X-Type cost’ 3 A. Yes, to go purchase and get the best deai | 9 A. 11,000. 10 can ona pickup truck, and that's what | did and for a9 Q. Do you know how much the Mercedes-Benz CLK] 11. some reason it got put in my name. iL cost? 12 (Of the record discussion.) 12 A. 35,000. 13° BYMR. EDWARDS: 13 Q. Do you know how much the Land Rover cost? 14 Q, Whose money was used to purchase the truck. 14 A. 68,000. 15 You say yots purchased the truck. | want the record to 15 Q. Do you know how much the Mercedes-Benz S| 16 be clear whether you're purchasing it with your money? 16 cost, that's yours, right? The Chevy Suburban is yours 17 A. No, this was wire-transferred. itwas a—! 17° aswell? 18 — don't remember how that -- | think it was a wire 18 A. Yes, ! remember how much those cost too. 49 transfer or a check was Fed&xed from the New York offieg 19 Q. is there another boat, 35-foot Donzi 20 te pay for that, That should not be in my name, is what 20 powerboat, 19997 21 7m getting at. [Ul certainly change that, but! 2. A. That's the one | thought you were talking 22 thought you were -- 22 about originally. 23 Q. | understand that. 23 Q. That's the same boat? 24 A, No, I'm being -- yeah, ! didn't. 24 A. That's the same boat, 25 MR. REINHART: There's no question. 25 Q. Is there any other boat that's registered in 206 208 4 BYMR. EDWARDS: 1 your name? 2 Q. 34-foot JVC Powerboat, 2000, owner LSJ, LLC. 2 A. No. 3 registered to Larry Visoski. Do you know that? 3 Q. Did you know that in -- let me ask you this: 4 A Yes. . 4 Do you have a 2003 Ferrari F75-M? 5 Q. You knew that that boat was registered in your 5 A. No. 6 neme? 6 Q. Any reason why the car is registered in your 7 A. Its registered to LSJ. It's Jeffrey's boat 7 name and the asking price is $189,000 being sold in New 8 that we keep here in West Palm Beach. 8 York? 9 Q. And do you keep it at your home? 9 A. That car is not registered in my name. 10 A. No. 10 Q. I fits registered 12 Q. Do you know that the registration is to your 11 A, The ad is in my name. 12 home? 12 Q. Whyis the ad in your name? 43 A. {ts used in my home adress, yes. 13 A. Because | was trying to sell it. 14 Q. Why was that done? 44 Q. Why were you trying to sell it? is A. We were eventually going to ship it out to is A. twas Jeffrey's car and we didn't want 16 — St. Thomas for it to live, but since Jeffrey's here, 16 anymore. 17 we're keeping it in Florida, and when we ship the boat 17 Q. Why would he put his pilot in charge of 18 over, we will change title to the Little St. James 18 selling his Ferran? 19 address. 19 A, Because | bought it. 20 Q. Whatdo you mean “since Jeffrey's here we're | 20 Q. How much did you buy it for? 21 keeping it in Florida"? What does Jeffrey being here al A. 79,000, Now, wher] say "| bought it," it 22 have to do with keeping a boat that's registered in your; 22 was his money. | was the one that negotiated it, to be 23 name and to your address — 23 clear. twas his car for use in New York. 24 A. Welt, | have access to use the boat, you know, 24 Q. Are you aware of the Zorro Trust winning an. here in Florida, but it's Jeffrey's boat. 25 86 million-dollar Power Ball lottery in 2008?

Larry Visoski OPRAH RWNe 209 . No. MR. GRITTON: Say that again. MR. EDWARDS: The Zorro Trust winning an 85 million-dollar — claiming the ticket for 85 miflion-dollar Power Bail ficket in 2008. THE WITNESS: No. BY MR. EDWARDS: Q. Have you ever listed your employer as Ghislaine Air in making political contriputions? A. Emay have. % Q. Did you know that you had made political contributions -A. Yes, have. Q. -- fisting your ~ A. tneeded a company name for that event, and | had put Air Ghisiaine. Q. And NES, LLC wouldn't do? A. ‘didn't think of it at the time. Q. Did somebody tell you to use Air Ghisiaine rather than the company that has been paying you? A, No. Q. You just chose to use an empioyer that isn’t actually your employer, nor have they ever been? A. Irepresent Air Ghislaine, JEGE and Hyperion as chief pilot, so [ consider those reaily the companies 210 that | work for and never really associated myself with NES, LLC as my realistic employer. So when | go toa convention, an aviation convention, and somebody says. who do you work for, | use the name JEGE because that's, the name of the Boeing company. Q. But when | sit here and ask you who you work for, you give me a different answer. A. You're asking for the absolute correct answer, which ig where my paycheck comes from, which is NES, LLC. | probably have used that twice in 17 or 18 years as my employer. Q. Do you know Dana Burns? A. | know the name, yes. Q. How do you know her? A, I've seen her on the airplane a coupie times. Q. Somebody that you know to be involved romantically or sexually with Jeffrey Epstein at any time? A. | don’t know that, Q. Are there any other cars, vehicles, items, other things that are registered in your name that are actually Jeffrey Epstein's? A. No. You've actually covered them ail and actually shed light on some that i did not realize, tike that Ford. October 15, 2009 MR. REINHART: Mr. Edwards, he needs to expand upon one earlier answer he gave when you asked him if he knew anybody else who worked at the Florida Science Foundation. BY MR. EDWARDS: Q. Okey. A, My wife worked there, When you used the words "worked there” -- or not referring to her as a past tense, but she worked there when it first opened answering the phones, What's your wife's name? Eileen. How does she spell that? EA-L-EE-N, Same last name as you? Yes. How jong did she work there? A month, maybe. And she was answering the phones for the Flerida Scienca Foundation? A. Yes. Q. Do you have a good relationship with your wife? A. I think so. Q. You still don't know what the Florida Science 212 prprerpre Foundation does? . No, because she doesn't. . She doesn't know what it does either? . We never talked about it. . You never talked to your wife about what she . No. MR. CRITTON: He knew she was answering phones. BY MR. EDWARDS: Q. Do you know of any other empioyees, friends, agents, relatives of Jefirey Epstein who he places his property in their names, registers them in his names or anybody etse? A. Notto my knowledge. | don't know, Q. To your knowledge, you're the only person? A. ['m the onty one f'm aware of. Q. And with respect to minor gitls being on the airplane, that being under the age of 18, how many times would you say that you have flown giris into the country, into the United States where you have given a date of birth to Customs of somebody on the airplane that is under the age of 18? A, Td have to look at Right records to verify or give you a correct answer. I don't know any to my

Larry Visoski October 15, 2009 213 1 knowledge at this point. 1 2 Q. What flight records would you have to look at? 2 3 A. The passenger manifests. 3 4 Q. Passenger manifests would have the date of 4 5 birth on it? 5 6 A. No. It would have a name, but | don't have -— 6 7 Q. But at some point in time you remember peopte, 7 8 minor date of births, coming inio the country and that 8 2 being tumed over to Customs? 9 ie MR. CRITTON: Form, 10 uz THE WITNESS; | don't remember anybody it 41z transporting on the alrpiane from the country back 12 13 Inte the U.S, that was a minor, to my knowledge, 13 14 BY MR, EDWARDS: 14 1s Q. Okay. Within the country, minors flying -- as 16 A. I don't know. 16 ay Q. -ona plane? a7 18 A, don't know dates of dirth. 18 is Q. And any people that you knew to be minors on 19 20 the airplane, were they always accompanied by parents or| 20 Zi were there minors on the airplane that you're aware of 2b 22 that were not accompanied by parents? 22 23 A. ‘didn't know either way. I mean, people 23 24 — would get on the airplane and get off the airplane. | 24 25 could telt you there were times people would get on that | 25 214 1 I didn’t even know were on the airplane. Cur focus is 1 2 upfront. 2 * Q. Was there a massage table on the airplane? 3 4 A. Which aircraft? 4 5 Q. On any of them? 5 6 A. The Boeing used to have a table on there, but 6 7 itstayed in the same spot and appeared to be never r 8 used. 8 9 Q. Okay. So to the best of your knowledge, you 9 10 have no knowledge of that massage tabie on the airplane} 10 11 ever being used? qi 12 A. Correct. 12 13 MR, EDWARDS: | don’t have anything else. 13 14 CROSS (LARRY VISOSKI) u 15 BY MR. CRITTON: 15 16 Q. Mr. Visoski, } have just a few questions. You 16 17 were just asked about a massage table on the — any of 7 28 = Mr, Epstein's airplanes and you said there was a massage 18 12 table on the Boeing? 19 20 A. Yes. 20 ai Q. Okay. Was there atways a massage table on the 21 22 Boeing or just for a period of time? 22 23 A. dust for a period of time. 23 24 Q. Alf right. And who's responsible for cleaning 24 25 up the aieplane after Mr. Epsiein and/or the guests 25 Ltt ret Poe anim jon anne nrunenntnrwrannarnnnnaen 215 leave? A. Us as the crew. Q. Okay. So if a massage tabie had ever been used, it would have been you and the crew who would have been responsible for either taking toweis or doing something with the massage table? A. Absotutaly. Q. And if | understood your testimony, you never ‘Saw a circumstance where it appeared to you that the massage table had been used in any manner; is that correct? A. Thatis correct. it stayed in the same location since the day it was put on there. Q. You were asked a bunch — a number of questions about Mr. Epstein, I'l use this — Mr. Epstein és the person who directed you generally urless one of — someone else who worked on his behalf calfed you and asked you to, say, set up a time to leave or pick up luggage, et cetara. My question to you is this: Have you flown in the past for other private individuals like Mr. Epstein, i.e., as distinct from a commercial? A. Yes, i have, Q. And approximately have you flown for four, ix other private individuals over the years? 216 A. Three. | had a short career as far as transferring of owners. Q. In temms of transferring to the other owners, ‘separate and apart from Mr. Epstein, again, every individual is different, but was your relationship really any differant with any of those other individuals? That is, you were in essence -- you were hired to perform a specific task: Fly an airplane to get from Point A to Point B and get the people there safely? A. My first job, corporate-wise, was for an owner in Miami and 1 was hired as a pilot, but yet, | would go to his house and maintain a boat that was in the back of his house above and beyond my cail of duty because | ad] an interest in boats. It's just something | like to do. But | always treated Mr. Epstein like any of the other ptior clients that | had as owners. 1 knew that | was not afraid to work for a living, and they understood that. Q. And it sounds like at least the first owner that you worked for asked you to do similar things that you've done for Mr. Epstein, such as take care of a boat ‘or purchase a boat or maintain the boat? A. Sure, absolutely. Q, So your relationship with Mr. Epstein with

Larry Visoski October 15, 2009 COV AK RW il 12 13 14 4s 16 17 18 ig 20 22 2 23 24 25: 247 219 regard to if you bought boats or you bought cars on his 1 LM? behalf, that's very similar to your prior experience 2 A. No, i have not. with working with another private individual? 3 Q. Did Mr. Edwards, in approximately four hours, A. That is correct. 4 little over four hours of questioning, ever ask you one Q. In terms of the records, the manner in which 5 question about L.M. that you can recall? you flew the plane or — i don't want to say flew the 6 A. Not that f recail. plane, but in which you operated and maintained the 7 @. Have you ever heard the name E.W.? Did you plane for Mr. Epstein are substantially the same you've: $ ever know someone named E.W.?7 done with other private individuals? 9 A. Never heard that name. A. Right, exactly the same. We wouldn't treat 10 Q. In approximately four-and-a-half hours of Mr. Epstein any different than any prior — previous 11 questioning by Mr. Edwards, did he ever ask you about jobs that | had. It's the same routine we carry over 120 EW? and that's why we're good at what we do, We take care} 13 A. No, he did not. of the airpianes to the best of our ability. 14 Q. In approximately the — are you familiar with Q. Is your focus as the pilot, as the captain of 15 an individual by the name of Jane Doe(S.R.)? both of the airplanes when you took over that 16 A. [never heard that name. responsibitity a number of years ago, is it your 7 Q. in approximately four-and-a-half hours of obligation fo get the passengers there safely-- onboard | 18 questioning by Mr. Edwards, did he ever ask you and safely to the destination and then retum? 19 questions about Jane Doe(S.R.)? A. Yes, that was always job number one. 20 A. No, he did not, Q, And most of us have had I'd say a much more 21 MR. CRITTON: That's all ! have, substantial experience in fiying commercial planes and|; 22 MR. EDWARDS: | only have two questions ba: tarely see — in fact, | can't remember the last tine 23 ‘on what your testimony just was to Mr. Critton. particularly after 2001 | saw the pilots coming back 24 into the cabin shaking hands and helping distribute the | 25 218 220 $nacks of liquids. Maybe I'm not on the same flights i REDIRECT (LARRY VISOSKI} that some of the other lawyers here are, but | assume 2 BYMR. EDWARDS: you fly commercial from time to time? 3 Q. You said you had three other peopte that A. Sure. 4 you've flown for? Q. Do you ever see the pilots interacting with 5 A. Three other previous jobs. |'m trying to be. the peaple who are in the back of the airplane? 6 asaccurate. A. No, notatall. They stay at their station up 7 Q. Those are private individuals? front. 8 A, Thatis correct. Q. You got - as the captain of the planes, when. 9 Q. And who are those people? you're flying, you have substantial responsibilities not 10 A. Herb Glimpsure in Columbus, Ohio, and Edward only to the people on the plane, but as well to the air 11 Seltzer in Miami. And then the other was Tom Boyd, and space which you're flying? 12 that was more of a Learjet charter, but he was the owner A Yes. 13 of five Learjets. Those are my only three jobs in my Q. Okay. By the way, we've been here about -- 14 life. for about an hour and fen -- we started about ten. it's is Q. Also weaithy individuals? now 3:30. Did you ever hear the name L.M.? Has 16 A. Big time. Mr. Edwards ever asked you one question about L.M.7} 17 Q. And did you know what they did for a living? MR. EDWARDS: Is the question have you ever; 13 A. Those | did, yes. heard of her or did | ask any questions about her, 19 Q. And did you ever go visit any of those peopie or did you ask both questions and give the same 20 in jail? answer? 21 MR. GRITTON: Form, MR, CRITTON: I'll break them down. 22 THE WITNESS: | know my first individual had MR. EDWARDS: it doesn't matter to me. 23 trouble with the law after | had left. don’t BY MR. CRITTON: 24 remember what it was pertaining to; but no, | never Q. Did you ever meet an individual by the name of! 25 visited any of them in jail, no, sir. ee

Larry Visoski October 15, 2009 224 BY MR. EDWARDS: Q. Even the one who had trouble with the law, you! didn't go visit him in jail? A. No, I did not, Q. And did any of them put vehicles or other boats or anything else in your name? A No. Q. Okay. Any of those people ever deed any property or acres or anything like that to you? A. No. Q. Did any of those people ever hire your wife for employment? A. No. Q. And your attorney, is that your attorney paid for by you, or is this somebody that's hired by Jeffrey Epstein? A. {tis somebody that is hired by Jeffrey Epstein. MR. EDWARDS: Okay. MR. GRITTON: One follow-up to your question. RECROSS (LARRY VISOSKI) BY MR. CRITTON: Q. With regard to the private individuals that you worked for prior to Mr. Epstein, what was the longest period of time that you worked for those? 222 A. The longest period of time was five years and the shortest being two years. MR. CRITTON: Thank you. MR. EDWARDS: Weill order. MR. REINHART: Weill read. MR. CRITTON: We'll take @ copy, front page, mini with index. (Witness excused.) (Deposition was concluded at 3:37 p.m.) 223 CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH |, the undersigned authority, certify that LARRY VISOSKI personally appeared before me and was dul sworn on the 15th day of October. 2009. Dated this 22nd day of October, 2009. Wendy Seath Anderson, RPR, CRR, FPR Notary Public State of Florida My Commission Expires: 9/20/2013 My Commission No.: DD 906647 Job #127542 224 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH |, Wendy Beath Anderson, Certified Realtime ‘Reporter and Notary Public in and for the State of Florida at large, do hereby certify that | was authorized to and did report said deposition in stenctype; and that the foregoing pages are a true and correct transcription of my shorthand notes of said deposition. further certify that sald deposition was taken atthe time and piace hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove eet out, {further certify that | am not attorney or counsel of any of the parties, nor am | @ relative or employee of any attorney or counsel of party connected ‘with the action, nor am | financially Interested in the action, The foregoing cerfification of this transcript does not apply to any reproduction of the same by any means unless under the direct control andor direction of the certifying reporter. E Cated this 22nd day of October, 2009. Wendy Beath Anderson, RPR, GRR, FPR dob #127542

Larry Visoski a uwew 18 wh 12 13 14 18 26 Do 18 19 20 an 22 23 2a 25, 225 DATE: October 22, 2009 70; LARRY VISOSKI Job #127542 fo Robert D. Gritton, dr via transcript IN RE: LM. vs, Epstein Please take notice that on Thursday, the 15th ‘9f October, 2008, you gave your daposition in tha above-referred matter. At that time, you did not waive signature, tis now neoessary thet you sign your deposition, ‘As previously egreed to, the tanscrigt wilt be furnished to you fhrcugh your counsel, Please read the following instructions carsfully: ‘At the end of the transcript you will find an. errata sheet. As you read your deposition, arty changes of corrections that you wish to make should be noted on the errata sheet, citing page and line number of said change. 00 NOT write on the transcript itself. Once you have read the transcript and noted any changes, be sure to sigh and date the errata sheet and retum these pages to me. Ir you do not read and sign tne deposition within 2 reasonable time (Le., 30 days unless otherwise directed) the criginel, which has already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. if you wish to waive your signature, sign your name in the blank at the bottom of this lefter and return itto us. Very tuly yours, ‘Wendy Beath Anderagn, RFR, CRR, FPR ESQUIRE DEPOSITION SERVICES, INC. 515 North Flagler Drive, P-200 ‘West Palm Beach, Florida $3401 | do hereby waive my signature. TARRY VISOSKT 10 ua 12 43 14 15 16 17 18 qs 20 an 22 23 24 2s 2009 October 15, 227 ERRATA SHEET IN RE: LW. VS. EPSTEIN. CR: WMB DEPOSITION OF: LARRY VISOSKI TAKEN: 10.15.08 JOB NO.: 127542 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE. PAGE # LINE CHANGE REASON Please forward the original signed errata sheet to this ‘office so that copies may be distributed to ail pasties. ‘Under penalty of perjury, | declare that i have read my cepostion and that tis tue and correct subject 0 ‘any changes in form or substance entered here. DATE: ‘SIGNATURE OF DEPONENT:, OVYnUeRWN 11 12 13 14 15 16 17 18 19 226 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH \ hereby certify that | have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of, 2009. LARRY VISOSKI dob #127542

DEFENDANT BRADLEY J. EDWARDS’S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 20

Certified Copy UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Plaintiff, Case No. 08-80893CIV-MARRA/JOHNSON JEFFREY EPSTEIN, Defendant. DEPOSITION OF MARK EPSTEIN September 21, 2009 11:30 a.m. One Penn Plaza, New York, New York Jacklyn Lisi Toll Free: 800.211.3376 Facsimile; 954.331.4418 Suite 1300 S15 East Las Olas Boulevard I 4 S | | R k Fort Lauderdale, FL 33301 , www.esquiresolutions.com an Alexander Gatto Company

Mark Epstein September 21, 2009" 48 M. Epstein Maxwell and knowing your brother, would that surprise you to hear that? MR. COHEN: Objection. A. I don't know Ghislaine Maxwell. TI mean I know her, but you can tell me anything, it's not going to surprise me. Q@. When you would see your brother and Ghislaine Maxwell, where would you be; at his house, at a function, out to dinner? A. Probably at his house more than anything. Which house would that be? More likely Florida. Do you know how he met her? No. Do you know where she is now? No. When is the last time you saw Ghislaine Maxwell? A. Probably around when my mother died, that's five and a half years ago. Q. Have you ever met Leslie Wexner? No. Have you ever met Donald Trump? ‘ Toll Free: 800.211.3376 <2 Facsimile: 954,331.4418 Suite 1300 E S Ul IRE 525 East Las Olas Boulevard Fort Lauderdale, FL 33301 an Alexander Gaile Company www,esquiresotutions.com

Mark Epstein September 21, 2009 49 M. Epstein Yes. Was that through your brother? Yes. Where was that? We flew up on my brother's plane from together. Donald was on the plane. When? Somewhere between 5 and 10 years ago. So we are talking about - Okay. It's either late '90's early 2000. Probably more like late '90's. Q. Was that the only time you've met Donald Trump? A. Q. brother's? Yes. Which plane was this of your A. Q. I don't remember. Was this one of the big planes, the 7272 A. No. It wasn't that one, no. Q. Okay. How many people were on this airplane? A. It was my brother, myself, Donald, othe pilot the co-pilot. I don't remember -- I Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 S | IRE 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 an Alexander Galle Company www.esqulresolutions.com

Mark Epstein September 21, 50 M. Epstein don't remember if anybody else was on the plane, Q. What was the purpose of Donald Trump riding on your brother's airplane? A, You'll have to ask Donald. I think he wanted a ride back to New York. Q. What was your understanding of the relationship of Donald Trump and your brother? A. They were friends. Q. Do you know how they met? A. No. Q. When you say "friends," how frequently did they associate? A. I have no idea. Q. What was your understanding -- did you -A. I had no understanding. They were friends. That was my understanding. Q. When they were in the airplane tegether, they talked as if they were friends? A. Yeah, I talked to him like he was my friend. I never met the guy. I ama friendly guy. Q. Were there girls on the plane? i Tolt Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300°~ ES UI I | ' 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 an Alexander Calta Company. www.esquiresolutions.com

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.;: 50 2009 CA 040800XXXXMBAG ATTACHMENT 19

ss, ~ BRONNRSSSGRRESNEScavauasune OBNAMAWNE FNUNNN Ree ee eee ee PAUSGNAPSGCHUAREOHES Page 299 A, Idon't remember, Ma'am. He came from 1 New Albany, Ohio. 2 Q. From New -- 3 A. New Albany, Ohio. 4 Q. New Albany, Ohio, Did he have his own 5 business? 6 A. No, he worked for Mr. Epstein, He will i. maintain ali the computers, 8 Q. Was he there everyday? 9 A. No, ma’am, 10 Q. Do you know whether at that time Mr. oey Epstein had an office in Paim Beach? 12 A. Not outside the house, no, 13 Q. Do you have any knowledge of whether or | 14 not the video equipment was -- and I don't know 45 the technical term, forgive me, but was it the 16 kind of equipment that would record for a certain 17 amount of time and then record over that film? i8 A. I don't know. 19 MR. CRITTON: Form. 20 BY MS. EZELL: 2i Q. You don't know? 22 A. No, ma'am, 23 MR. CRITTON: Just for clarification, I 24 may have misunderstood, but I thought he Page 300 said he didn’t even know the video equipment | 1 existed until he read the FBI report. 2 MS. EZELL: He said he didn't know that 3 it was upstairs and downstairs, I believe, 4 MR. CRITTON: I thought he said he didn’t 5 6 7 8 9 know that it even existed, MS. EZELL: I may be wrong. BY MS. EZELL: Q. Did you know it existed before you read the FBI report? 10 A. No, ma'am, il Q. I'm sorry, then I was wrong. 12 How did you know then that the young 13 technician from Ohio maintained the computers and | 14 the video equipment? 15 A, Because we used to request -- there were 16 always problems with the computers so he came to | 17 the house and he was the programmer. It was very | 18 sophisticated, MR. CRITTON: Form to the last question, move to strike the answer as nonresponsive, BY MS, EZELL: Q. How did you know then that he maintained the video equipment as weil? A. Because he was in charge of computers, Page 301 video, even phones, Q. Would he also repair the televisions if they needed work? A, No. Q. No. Did you have any kind of intercom system In the house? A. Yes, ma’am. Q. And what kind of system was that? A. Tt was standard office equipment, Lucid i Technologies maybe, but It was an Intercom like we ff using right now, MS. EZELL: Just let the record reflect that the witness pointed to the telephone on the tabie that has a speaker phone. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And did you use that in your work? A. Yes, ma'am, Q. And what did you use it for? A. Mr, Epstein used to page me when he needed me. Q. Did you have one of those phones in the kitchen? A. Yes, ma'am. Q. And was there one out in the staff house Page 302 as well? A. Yes, ma'am. Q. Do you know where others were in the house? A. Probably have like 15 phones. We used to have three in the staff house, one in the cabana, two In the master bedroom, one in each room, kitchen, dining room, Mrs. Maxwell's office, the garage, Q. Where was Mrs. Maxwell's office? A. Under the stairs next to the kitchen. Q. Can you give me some idea of what size space that was? A. It was probably -- we change the floor, ‘Twelve by five, something like that. Q. And was the computer equipment in that space? A, Yes, ma'am. Q. Do you know whether Ms, Maxwell kept the names and telephone numbers of the giris who came} to do massages? A. Yes, ma'am. MR. CRITTON: Form. BY MS. EZELL: Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141

1 names and phone numbers? 2 MR. CRITTON: Form, 3 THE WITNESS: Yes, ma'am, 4 BY MS, EZELL: 5 Q. Bo you know if she kept pictures of the 6 girls on the computer? 7 A. Yes, she did. 8 Q. And you know that as well because you 9 happen to see them? 10 A. Yes, ma'am. ul MR, CRITTON: Form to the last two 12 questions, 13) BY MS. EZELL; 14 Q. Were they similar to the pictures that 15 Ms, Kellen had on her computer? 16 MR. CRITTON: Form. i7 THE WITNESS: Yes, ma'am, 18 BY MS. EZELL: 19 Q. Did the pictures that they kept there 20 {ook like pictures that were posed? ai A. They were more casual. 22 Q. Did they took as though the person being 23 photographed knew that they were being 24 photographed? MR. CRITTON: Form. 1 THE WITNESS: No, ma'am. 2 BY MS. EZELL: 3 Q. And what can you tell me about that, what 4 lead you to draw that conclusion? 5 A. They were probably taken in parties in 6 big reception or banquet. 7 MR. CRITTON: Let me offer as a 8 suggestion, not that you have to accept or 9 that you would, you're using the term young 10 girls generically, he has probably seen li many, many young girls, there was no -12 you've used it interchangeably with just 13 young girls versus young girls who may have 14 come to -- purported to give a massage and, 15 therefore, that may be a different answer, 16 so that's part of my form objection. 17 MS. EZELL: Okay, thank you. 418 BY MS, EZELL: 20 she had a list of the girls and telephone numbers, 21 I think I asked about those girls that came to 22 give massages, but let me go back and just ask it 23 that way. 24 Did you notice that Ms. Kellen had a list 25 of the girls that came to give massages on her Page 304 19 Q. When 1 asked you about Ms. Kellen whether WONAUAUNE computer? MR, CRITTON: Form. THE WITNESS: Yes, ma'am, BY MS. EZELL: Q. And did she generaily have phone numbers for those girls? A. Yes, ma'am. Q. And were they generally pictures of the Girls? MR, CRITTON: Form. THE WITNESS: No, ma'am. BY MS. EZELL: Q. And did Ms. Maxwell have a list of the girls who came to give massages? MR. CRITTON: Form. THE WITNESS: Yes, ma'am, BY MS. EZELL: Q, Did she have telephone numbers generally? A. Yes, ma'am. MR. CRITTON: Form. BY MS. EZELL: Q. Were there pictures on her computer of the girls who came to give massages? MR. CRITTON: Form. BY MS. EZELL: Page 306 |{ Q. Ms. Maxwell I'm talking about, A. Yes, ma’am, Q. And were those pictures the more casual ones that you described when I asked whether or not the subject looked as though she knew she was being photographed? i MR. CRITTON: Form. THE WITNESS: I'm sorry, can you repeat? BY MS. EZELL: Q. Yeah. The pictures of the young girls | who came to the house to give massages that were #f on Ms, Maxwell's computer, did they appear to have jf been taken when the girls knew they were being photographed? MR, CRITTON: Form. THE WITNESS: I don't think they knew they were being photographed. BY MS, EZELL: Q. I believe you said they were more casual pictures, A. Yes, ma‘am, Q. Did you notice any nude photographs in those pictures? A. Yes, ma'am. Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141

NEGvenvauawne Page 347 F.E., and I think you told us that you had seen her, you recognized her photograph. A. Yes, I did. Q. On how many occasions did you ever see her at the Epstein home? A. More than three times. Q. More than three? A. Yes, sir. Q. That's as accurate as you can be? A. Yes, Q. More than three? A. More than three. Q. Whether it was four or five you don’t know, but more than three? A. More than three, sir, Q. In terms of F.E.'s age, did you ever ask her what her age was? A. No, sir. WON AUAWNHE Q. Did she appear to you to be someone at 19 least from seeing her and recalling her that she 20 appeared at least to you to be while a young woman | 21 appeared to be someone who was 18 or older? 22 A. No, sir. 23 Q. Okay. Well, did you ever say anything to the police or did you ever -- were you ever Page 348 concemed about that such that you told someone? A. No, sir. Q. Haven't you told the police, sir -- let me strike that, let me ask it this way. In your taped statement that you gave to the police did you not tell them that all of the girls appeared to you to be 18 or above? A. Sir, as far as when all these actions that were taking place I was under an environment that I thought I was going to be -- in other words, I was afraid of any reprisal Mr. Epstein li and Mrs. Maxwell if I say something that is any 12 idea of me because I have this confidentiality 13 agreement, What I saw that they were very young, but I cannot say that they were 18 and old. 15 Q. Right. Let me just take you back to my 16 question again and see if you can answer my 17 question. 18 MR. CRITTON: Could you please read it 19 back? 20 (Thereupon, a portion of the record was 21 read by the reporter.) 22 THE WITNESS: I think I told the police 23 Q. I'm sorry? A. Yes, I did, I told the police, Q. And at the time that you spoke with the police and gave them a statement, isn't ittrue, Mr. Rodriguez, that you were no longer employed by Mr. Epstein? A. Yes. Q. And you understood that you were required to tall the police officers the truth at that time? A. Yes, Q, And if f understood your testimony I believe from July 29th through today, you at no time asked any of these girls how old they were, True? A, No, Q. And as to whether the girls were under 18 or 18 or over 18, you really didn't know one way or the other at the time. Would that be a fair statement? A. Yes. MR, WILLITS: Object to the form of the question, BY MR. CRITTON: Q. On Exhibit 6 there is a person who's Page 350 covered, the lady that Ms. Ezell asked you about I belleve was on the right-hand side of the photograph. There is a young lady on the left-hand side with a black hat on. Do you recognize her at all? A. No, I don't recognize her. Q. Okay, Thank you. With regard to the photograph four that you saw that you think possibly might be A.H., I think you told us that you recall seeing that woman in the sauna at Mr. i Epstein's house on one occasion and she was naked. i A, Yes, Q. Was that near the end of your employment or the middie or the front end? A. Tsaw her on January 2005, sir, and I was terminated in March, so that was two months prior. Q. And did you ever tell anyone that you had seen her naked in the sauna? A. I told Loueila, Q. Okay. And what did Louella say? A. She was surprised, Q. Okay. Did you wake the young lady up in the sauna? A. No. Q. And do you know how old the young lady "21 (Pages 347 to 350) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 18

Original Transcript IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff, vs. Case No. 502008C.A028051 XXXXMB AD JEFFREY EPSTEIN, Defendant. DEPOSITION OF LARRY EUGENE MORRISON TAKEN ON BEHALF OF THE PLAINTIFF VOLUME I Pages 1 to 200 October 6, 2009 10:55 a.m. 515 N. Flagler Drive West Palm Beach, FL 33401-4321 Jennifer DiLorenzo, court reporter Toli Free: 800.211,3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard E Fort Lauderdale, FL 33301 www.esquiresolutions.com an Ale L Gallo Company

© mo 10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Larry Eugene Morrison - Volume I October 6 ES l JIR E 515 East Las Olas Boulev! Fort Lauderdale, FL 3330 102 Q. Would any of those girls look extremely youn to you? MR. PIKE: Form. A. Not -- Not that I thought. 0; Not back in 2001, we're talking about? A. Right, right. Q. No. What would Ghislaine Maxwell say to you, if anything? MR. PIKE: Form. A. She'd -- Mostly small talk, just -- She kind of did the business management part of it as far. as, you know, arranging cell phone - I was having cell phone problems with the company cell phone, she would handie things like that, but she would have minor inputs on the interior work. Q. What was your understanding back in 2001 st of the relationship between Ghislaine Maxwell and Jeffrey 18 Epstein? ig MR. PIKE: Form. 20 A. I veally didn't understand it. I thought 21 it was personal - personal and business. 22 Q. When you say "personal," did you think it was 23 sexual? 24 A. I thought maybe they were dating and, you 25 Toll Free: 800.211.3: Facsimile: 954.331.4 suite L an Alexander Catto Company www.esquiresoiutions.

Larry Eugene Morrison -~ Volume I October 6, 2009 if know, business relationship too. po po to make an A. A. in New York in the apartment that we stayed in that was -- You do, I read MgO” gee 2 103 Did you know who Ghislaine Maxwell was? Not right away, no, no. Not right away? Right. At some point in time you were curious enough attempt to find out. No, I -MR. PIKE: Form. -- heard about her and there was a book up know, you're sitting there with nothing to that. Do you remember the name of the book? It was just "Maxwell." Have anything to do with her father? Yeah, it was about him, that's what it was about. I mostly just flipped through looking at pictures, boats, and airplanes and stuff. Q. Back in 2001, the first time you had a real conversation with Ghislaine Maxwell -A. Q. MR. PIKE: Form. Yes. ~~ what did that conversation consist of, if you remember? 2) Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 | IRE 515 East Las Olas Boulevard Fort Lauderdate, FL 33301 ‘an Alexander Gaito Compsay. www.esquiresolutions.com

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et ai. Case No.: 56 2009 CA 040800XXXXMBAG ATTACHMENT 17

Certified Copy IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION Plaintiff, CASE No. 502008CA028051XXXXMB AB JEFFREY EPSTEIN, Defendant. DEPOSITION OF LOUELLA RABUYO VOLUME! October, 20, 2009 10:10 a.m. 515 N. Flagler Drive Suite 200-P West Palm Beach, Florida 33401 Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard E S I IRE Paim Beach Gardens, FL 33410 www.esquiresolutions.com sn Alexander Gallo Company

ober 20, 2 Louella Rabuyo - Volume I October 20, 2009 nO, you 2 més, 6 her 8 ion, 4 that 6 to work -& on taken !1 sporter, ‘4 your 5 "ee: 866.709.87 ile: 561.394.26 Suite 6 140 PGA Boule’ ES 4440 PGA Boulevard Sardens, FL 330" = Palm Beach Gardens, FL 33410 quiresolutions.6° 9 head or shake your head, and she can't take that down. A All right. Q It's also very easy to say uh-huh or huh-uh, but it kind of looks the same on paper, so you can't do that either. I'm going to wait until you finish your answer, and you have to wait until I finish my question, because if we talk over one another, then the court reporter can't get it down. A Okay. Yes, sir. Q All right. So if you don't understand the question, tell me you don't understand and I'll try to ask a better question. A Yes. Q Okay. So you were hired in November of 2004 to be the housekeeper for Mr. Epstein? A Yes. Q And when you were hired, who exactly hired you, who -- let me strike that. When you were hired to be the housekeeper for Mr. Epstein, who did you interview with? A Me. Maxwell. Q Is that Ghislaine Maxwell or just Laine Maxwell? A Ghislaine Maxwell. Q And where did the interview take place? Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ‘sa Alocander Gailo Company www.esquiresolutions.com

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 16

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO:502008CA028051XXXXMB AB Plaintiff, ~vs~JEFFREY EPSTEIN AND SARAH KELLEN, Defendants. DEPOSITION OF JANUSZ BANASIAK Tuesday, February 16, 2010 10:09 ~ 2:30 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1317 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-423-ae22-b5d3e7 182d1e (561) 832-7506

Page 14 ; 1 Q. Okay. So, I assume then that your wife [ 2 that you are separated from I guess at the time, she 3 didn't come down to Palm Beach? 4 A. No, no. 5 Q. And this is somebody who still lives 6 somewhere other than Florida? ‘t A. Correct. 8 QO. So, you came down in February 2005 and 9 began working. What did you, what did you first 10 start doing for Jeffrey Epstein? 11 A. First I doing? I don't remember nothing 12 special. 13 Q. Okay. Well, were you working -- I will 14 rephrase it. Were you working only for Jeffrey 15 Epstein or were you working also for Ghislaine 16 Maxwell, the other person who interviewed you, or 17 anybody else in the house? 18 A. I guess only for him because she was visiting 19 a few times house, but I am employed by him. 20 Q. Okay. What was your understanding at that 21 time as to the relationship between Ghislaine 22 Maxwell and Jeffrey Epstein? 23 A. They were like partners in business. 24 Q. Okay. What business was that, if you 25 know? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Etectronically signed by cynthia hopkins (607-051-976-2934} Etectronicaily signed by cynthia hopkins (601-051-976-2934) Etectronicaily signed by cynthia hopkins (601-051-976-2934) 2d73a91d-3eaa-42b3-ae22-bd3c7 182d 10

= WN ol 10 41 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 154 | A. No. MR. GOLDBERGER: Form. BY MR. EDWARDS: Q. And have you known, just based on your observations, Nadia to have girlfriends? And by girlfriends I mean girlfriends that she would be intimate with in addition to being the girlfriend of Jeffrey Epstein? A. No. Q. Do you know somebody by the name of Jean Luc Brunel? A. Yes. Q. How do you know him? A. He was in the house like, I guess, a few times. Q. When? A. When? Oi. When was the last time you saw him there? A. A week ago. Q. Today is, what, February 16th, and this is a Tuesday. So, when we are saying a week ago, are you saying it was last Tuesday, Wednesday, Thursday, Friday, do you remember? A. I don't remember the date but he stay maybe three days, I think, in the house. Electronically signed by cynthia hopkins (604-051-976-2034) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-bSd3c7 182d1e6

Page 155 ! 1 Q. So, if he arrived on Tuesday, he stayed 2 through Thursday or Friday and -3 A. Yes. 4 Q. Do you know what the occasion was for him 5 to come in town? 6 A. No. 7 Q. Where did he stay in the house last week? 8 A. One of the bedrooms upstairs. 9 Q. And was Mr. Epstein also staying in the 10 house? 11 A. Yes. 12 Q. All right. Did Mr. Brunel bring any 13 company with him? 14 A. No. 15 Q. It was him alone? 16 A. Yes. Cy Q. How did he get to the house? 18 A. I think he has been picked up by Igor at this point. Q. And where did he -- I assume he flew in from somewhere? A. Yes. Q. Picked up from the airport, safe assumption? He didn't just drive to the airport. (A discussion was held off the record.) (561) 832-7500 PROSE COURT REPORTING AGENCY, Electronicalty signed by cynthia hopkins (601-051-976-2934) Electronicatty signed by cynthia hopkins {601-051-976-2934) Electronically signed by cynthia hopkins {601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7 182d1e Inc. (561) 832-7506

Page 156 ; 1 BY MR. EDWARDS: 2 Q. So, do you know where it was that 3 Mr. Brunel flew in from? 4 A. No. 5 Q. Do you know where Mr. Brunel generally 6 lives? I mean is it New York, is it -~ a A. I know that he spends some time in Florida, in 8 Miami, but exactly where he is, I don't know. 9 Q. But obviously he wouldn't fly here to Palm 10 Beach from Miami, right, so he had to be coming from 11 somewhere else you would assume? £2 A. Yes, I assume. 13 Q. Were you told -- similar to the way that you have been describing throughout the deposition, you're told who is coming in town. Were you told he was going to be at the house? 17 A. Yeah. Usually he requires to be picked up, so I know that he is coming. Q. Okay. We'll go through some other instances where you had eccasion to pick him up or 21 break plans, but talking specifically about last 22 week: When were you first told that Mr. Brunel was going to be coming into town? 24 A. I think Igor toid me that he has to go and pick him up. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 20752a91d-3eaa-42h3-2e22-bid3e7182d Ie

Page 157 E A: iO’ How did he -2 A. It was my day off, I guess, because usually I 3 am the one who pick up people. So, I guess it was my days off and Igor was working, so he went to pick him § up. 6 Q. Okay. It wouldn't be Story Cowles picking at him up? 8 A. No, 9 Q. So, to the best of your recollection Igor 10 picked up Jean Luc Brunel sometime last week from a the airport and took him to the house? 12 A. Right. 13 Ox Do you know what car he took to pick him 14 up? LS A. I think Cadillac Escalade. 16 Q. The black Escalade? 17 A. Yes. 18 Q. And what did Mr. Brunel and Mr. Epstein do 19 for the three day stay when Mr. Brunel was staying 20 at Mr. Epstein's house last week? 21 MR. GOLDBERGER: Form. 22 THE WITNESS: I don't know. 23 BY MR. EDWARDS: 24 oO; Did you interact, communicate with 25 Mr. Brunel? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-a0ez2-b6d3e7 182010

Page 158 } 1 A. Yes. 2 Q. And what did he say as to why he was here? S MR. GOLDBERGER: Form. 4 THE WITNESS: Good morning. How are you? 5 Exchange handshake. And I saw him in the 6 kitchen and he was cooking something and that's 7 te 8 BY MR. EDWARDS: 3 Q. When you say he was cooking something, he 10 was personally cooking? 11 A. Yes. 12 Q. All right. So, this is a house that he is 13 familiar enough with and he is a regular enough 14 guest that he makes himself at home? 15 A. Yes, 16 Q. Okay. And last week do you remember 17 anything in the three-day period that Mr. Brunel was 18 staying at the house that Mr. Brunel did from the 19 time he woke up to the time that he went to sleep? 20 MR. GOLDBERGER: Form. Zi. BY MR, EDWARDS: 22 Q. I mean did go to the movies? Did he go to 23 the beach? Did they just hang out around the house 24 and walk? 25 A. Yeah. I think he walked outside to the beach. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronicaily signed by cynthia hopkins (601-051-976-2934) 2d75a91d-Seaa-42b3-aeZ2-bSd3e7 182die

Page 159 f 1 He was swimming in the pool, talking on the phone just 2 what I remember. 3 Q. Okay. During the three-day stay last 4 week, how often were -- I mean, I assuming that he 5 came in town to see Mr. Epstein; is that true? 6 A. Yes. ii. QO. And so the majority of his time during 8 that three days was spent hanging around with 9 Mr. Epstein? 10 A. Yes. 11 Q. All right. Did you see them talking with 12 one another? 13 A. Yes. 14 Q. Where were they talking with one another? 15 A. In the cabana, outside sitting next to the 16 pool. Ly Q. Ali right. And when you said that 18 Mr. Brunel walked to the beach, did Mr. Epstein walk 19 to the beach with him? 20 A. No. 2: Q. Mr. Brunel walked alone? 22 A. Yes. 23 Q. Who else was in the house last week while 24 Mr. Brunel was in the house? 25 A. Nadia, Sarah, and Story, I think. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (604-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d7$a91d-Jeaa-42h3-ae22-bSd3c7 182dte

1 Q. Sarah Kellen? 2 A. Yes. 3 Q. And Story Cowles? 4 A. Yes. 5 Q. Okay. Who else, Igor? 6 A. Igor. I guess that's it. 7 Q. Did you overhear any of the substance of 8 the conversations that Mr. Brunel was having with 9 Mr. Epstein? 10 A. No. 11 Q. All right. What is your understanding as 12 to the relationship between Mr. Brunel and 13 Mr. Epstein? 14 A. I guess they are friends. 15 Q. Okay. In addition to being friends -16 well, let me ask this question first: Do you know 17 when they became friends? 18 A. No. 19 Q. You don't know how long they have known 20 each other? 21 A. No. 22 Q. You don't know who introduced them? 23 A. No. 24 Q. They could have met since they were five 25 years old or they could have met five years ago for PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 (561) 832-7500 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42h3-2022-b5d3e7 182016

Page 172 } to Miami. Q. Okay. A. But how long he stay in Miami, how long he stays outside of Miami, I have no idea. Q. And when was that occasion where you know that. Jean Luc Brunel was in Miami or spending time in Miami? A. I think at one point I drove him to Miami. Q. And when was that? A. I think the time he was here in this month of January. I think I drove him back to Miami from, from the Palm Beach, Palm Beach house. Q. Okay. So, that time in January he flies into the Palm Beach airport from some undisclosed or unknown location, you take him to the Palm Beach house, right? A. Right. OQ. How long does he stay on that occasion? A. Maybe three days. Q. And during that three-day period were any other -- did any females accompany him to the Palm Beach house? A. No. I don't remember. I don't recall. Q. Well, maybe this will jog your memory: When you drove him to Miami, did you drive him (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (S61) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-302a-42b3-2022-b5d3c7 18201

A. Yes. 3 Q. ~~ or did you drive him with somebody 4 else? 5 A. Alone. 6 Q. Okay. And where did you take him to in ¥ Miami? 8 A. I don't know. He left -- he told me his car, 9 one of his friends somewhere in Miami Beach, so I 10 dropped him over there and he pick up his car over 11 there. 12 Q. And who is his friend, do you know? 13 A. I don't know. 14 Q. So, his car was in Miami? is A. Yes. 16 Q. What kind of car was that? 17 A. Mercedes. 18 Q. All right. And do you remember where it 19 was in Miami that his car was parked? 20 A. Some -- I don't remember the others, but 21 somewhere in Miami Beach. 22 Q. All right. At a condo, at an apartment, 23 on the side of the road, a house? 24 A. No. It was a private house. 25 Q. A private house on Miami Beach. Do you (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051 -976-2834) (561) 832-7506 2075a91d-3eaa~42h3-ae22-bSdse7182d1e

10 11 12 13 14 15 16 17 18 19: 20 21 22 23 24 25 (S61) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 174 know the name of the person that lived at that house? A. No. Q. All right. In talking about this person Jean Luc Brunel, would -- you said he came here last week. He came here in January. Stayed three or four days each time, two consecutive months. Since Mr. Epstein has been out on house arrest is Jean Luc Brunel one of the people that visits on a monthly basis? A. No. Q. Okay. A. There was no regular visit. It's just occasionally I would say. Q. Okay. So, prior to the January visit, when is the previous time that Jean Luc Brunel was at Mr. Epstein's house? A. I don't remember. I don't remember. Q. Is he one of the people who frequently calls Mr. Epstein? A. Yes. Q. And Mr. Epstein frequently calls him? A. I don't know. Q. Okay. Well, I guess you would only know the calls that come in and you take messages, right? Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601 -051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-Jeaa-42b3-ce22-b5d3¢7 18201 ¢

Page 175 A. Right. Q. How times would you estimate -- I know you told us two times in 2010. Let me ask it this way: In 2010 were there only those two occasions where Mr. Brunel was staying at Mr. Epstein's house in Palm Beach? A. Yes, as far as I remember. Q. Okay. How many occasions, in addition to those two, would you estimate that Mr. Brunel has stayed at the Palm Beach house since Mr. Epstein has been out on house arrest and also staying at that house? A. It's hard to tell. I would say maybe three times. Q. Three times in addition to the two times this year, five times total? A. No, three times total. Q. Okay. So, one time this month, one time last month, and then for the period of time from -I don't remember when he was on house arrest, maybe July. So from July to December you think that there was only one other occasion when Mr. Brunel was at the house? A. You know, it's hard to remember but I think so. He was maybe totally three times for the last few (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-081-976-2934) Eiectronicaily signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaaAZh3-ae22-b5d3c7 182d1¢

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 15

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

—-—— 2 4 APPEARANCES: Videotaped deposition taken before JANET L. ON BEHALF OF THE PLAINTIFF: : ‘ FARMER, JAFPE, WEISSING, EDWARDS, McKINNEY, Registered Professional Reporter, Florida EN Professional Reporter, Certified LiveNote Reporter and Suite 2 ic i i sie: baie aitaaes Notary Public in and for the State of Florida at Large ee 524.2820 tojustice.com oy BRADLEY EDWARDS, ESQ. (Whereupon, Witness’s Exhibit | was marked for ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN: identification.) BURMAN, CRITTON, LUTTIER & ‘COLEMAN, LLP 1 2 3 4 5 inthe above cause. 6 7 8 VIDEOGRAPHER: We are now on the video record, 9 T i i | i | { | Pp i i 303 Banyan Boulevard i ‘Today is Monday, the 15th day of March, 2010. The Tea a ea Haein 1 10 time is 9:13 a.m, (sic). We are kere at 515 East 361.842.2820 eee Las Olas Boulevard, 3rd Floor, Fort Lauderdale, Mpike@bclefaw.com i . i : BY: MICHAEL J. PIKE, ESQ. ' 12 Florida, for the purpose of taking the videotape ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES: , 3 deposition of Adriana Ross taken in Case Number MRSS TEN © HOROWTIZ, Eo [44 08-CIV-80893, Jane Doe v. Jefitey Epstein, et al. Suite 2218 j 4s The court reporter is Janet McKinney; the see one | 16 videographer is Sean McGuire, both of US. Legal Br STUARTS MERSCELSTEIN, ESQ. ju Support. i; 18 Will counsel and all present please introduce ON BEHALF OF THE WITNESS: i 2 } 19 yourself and the court reporter will swear the EABEN@ WOMEN PAT | 20 witness ai) socdcees toed Ate | 22 MR, EDWARDS: Brad Edwards. | represent the ‘Miami, Florida 33129 ; 22 plaintiff, Jane Doe also "Jane Doe"; EW, "EW", LM, BREE on Loge. an ce ase: jucigagiee 24 MR. MERMELSTEIN: Stuart Mennelstein. I US. Legal Support 125 int J 3| INDEX 1 MR. PIKE: Michael Pike on behalf of Jeffrey | 2 Epstein. ADRIANA ROSS Page | 3 MR. ROSS: And good morning, my name is Alan} . sh } 4 Ross. 1 represent the witness, Adriana Ross. Direct Examination By Mr. Edwards Tobe THE REPORTER: Would you raise your right Cross-Exemination By Mr. Mermeistein i i 6 hand, please. hee ra . An . oe ‘ i | 7 Do you solemnly swear or affirm the testimony eee eee et Be you're about to give will be the truth, and nothing Certificate of Oath 137 ! 9 but the truth, so help you God? Certificate of Reporter 138 | 10 ‘THE WITNESS: Ido. | a2 MR. ROSS: Sefore the deposition begins and in EXHIBITS ; 22 an effort to streamline the process of getting PLF'S a ; 13 through this deposition on behalf of the witness we Nos Desciiption Page 44 have had marked as Wimess Exhibit Number { an 1 Jane Doe 102 v, Jeffrey Epstein 33 ) 5 August 31, 2007 letter from the United States complaint | 16 Attorney's Office addressed to Miss Ross through 2A-2G Telephone messages 62 { 17 her then counsel, Bruce Lyons, which is called a 3 Handwritten notes 12 ; 18 target letter identifying her as a target of a 2H Telephone message 87 | 19 federal Grand Jury investigation in the Southern 4° Gawker.com photo with story 127 | 20 District of Flarida and outlining a number of baz offenses that were the subject matter of WITNESS'S j 22 investigation. No. Description Page | 23 As a result of that, it is anticipated that | 24 some of the questions that may be asked during the Target letter 4 | 25 course of this deposition she may invoke her Fifth 2 (Pages 2 to 5) U.S. Legal Support (954) 463-2933

ODIHRH AR WHE OW ONIHALWNH be ° PRR Pe RB Co2IAaORWRe ny 3 VNRNNN ae.aon-e i 6 8 Q. And whe are you married to? A. Duncan Ross. Q. Allright. And sometime after 2003 if understand you correctly you kept the name Mucinska. until you were able to formally change ft to Ross? A, Correct. Q. Okay. Were you married in this country? A. Correct. Q. When did you come to the United States? A. Fall of 2002. { do not recall exact month, Q. And why? A. Iwas invited by modeling agency on a business Q. What modeling agency? A. Elite Models, Q. And who was the connection at Elite Models that invited you? A. Actually it was my husband, I met him in Europe and at the time he -« he knew that agency and I was modeling in Burope and he showed my pictures and they invited me. Q. How long have you been modeling? A, Since about I was 16 years old. Q. Since 16, so mid-90's? Late 90's? A. Probably around '98, '99, I believe, Amendment privilege against self-incrimination, | 1 And in order to streamline this we've agreed prior t 2 to beginning this that she will simply answer"T. | 3 reflise to answer." The parties will understand and; 4 the record will reflect that she is invoking her i os Fifth Amendment privilege against | 6 self-incrimination. | 7 If there is some other privilege, {| 8 attorney-client privilege or some other objection | 9 that I may have to a question, I'll specifically | 10 state it. But her answer “l refuse to answer" will | 11 be on Fifth Amendment grounds if that's scent 12 to everyone, | a5 visa. MR. EDWARDS: It's acceptable. | 44 MR. MERMELSTEIN; It's acceptable, \ 15 MR. PIKE: Acceptable. } 16 MR. ROSS: Okay. Madam court reporter has \ 17 already marked the exhibit, and [ll leave that { 18 with her. , 19 MR. EDWARDS: Okay. 1 20 | a 22 | 2s i 24 | 25 | THEREUPON: lop t ADRIANA ROSS i 2 having been first duly sworn or affirmed, was examined} 3 and testified as follows: {4 DIRECT EXAMINATION 1 os BY MR. EDWARDS: ; 6 Q. Can you tell us your full — full name. | 7 A. Adriana Ross. 8 Q. Atsome point in time you were known as | 9 Adriana Mucinska; is that correct? i 10 A. Correct. joan Q. And when did that change? ; 12 A. Well, I got married and initially I stayed | 13 with my name and then -- because immigration kind of | 14 made a mistake of not changing my name when I first | 15 came to this country. And at some point when { was | 16 States? removing my conditional residency 1 made sure that this} 17 mistake is corrected. I do not recall exact time when {| 18 that happened. I 19 Q. When were you married? i 20 A, July 12th, 2003. i 21 model? Q. Okay. What's your date of birth? { 22 A. T of October 1983. 23 Q. 10/7/83? | 24 A. Yes. | 25 9 Q. Okay. And what agencies did you model for in Europe? A. Iwas with — in Poland I was with Ricardo Guy that eventually change the name to J and B Models. [ was also represented by Ricardo Guy in Milan. Then on my second trip to Milan an agency called Women. was then represented in Japan by agency -+ oh, that's ~- you just mean Europe or -Q. Well, you can continue. A. Yeah, Iwas represented in Japan by agency Zucca. I was in South Korea, I do not recall the name of the agency. Iwas represented in Taiwan by Fashion Management. Q. Okay. And these were all agencies that you worked for or worked with prior to coming to the United] A. Notall of them. Some of them I worked — already been United States and traveling. Q, Okay. But sometime around 2002 you were invited by Elite Models to come to the United States to A. Correct. Q. Aud at the time — well, where are you from? A. I'm Polish. Q. Okay. So at the time you were a Polish 3 (Pages 6 to 3) U.S. Legal Support (954) 463-2933

wer HKAVewne 10 citizen? A. Yes. Q. Soin order to come to the United States you needed to get a work visa? A. was invited actually just to kind of get a feeling if I will be suitable. So I came on a business tourist visa which is, { believe, B1/B2, Q. Okay. And where did you first go when you came to the United States, what state? A. Florida. Q. And what city in Florida? A. Miami. Q. And what did you do for your two weeks when you first arrived in Miami, Florida? A, Ido not recalf. Q. Okay, But did you do any modeling? A. Well, like I would see some photographers, the agency would send me like on all calls to see photographers to kind of introduce me as a model. Q. And why did you make the decision to go with Elite Models in the United States when you already = modeling in — A. Unm-hum, Q. ~ Europe? A. Well, you know, just to expand it was | | 1 | } | i i i : i | i i t | i i | | i i | i | | | 12 something that I did. And I decided to take a year off after I graduated from high school and -- you know, just to expand the modeting -- the modeling, possibilities, opportunities. Q. Where did you graduate from high school? A. In Warsaw, Poland. Q. What year? A, 2002, I believe. Q. And do you have any college? Have you gone to college after that? A. [have an associate degree from Miami Dade College ~ Miami Dade College, and Im pursuing a bachelor degree right now. Q. When did you get your associate's degree from Miausi Dade? A, 2008. Summer of 2008. Q. And you're pursuing a bachelor's degree right now? A, Yes. Q, From where? A. Florida International University. Q. In what? A. Accounting, Q. How long have you been in the accounting i | i i i i | | i | f | i | i | | i i | | i i i | t program? 2 2 3 4 a, 6 4 8 9 Cer naewne 1d ii 12 13 14 15 iy 18 i9 20 21 22 23 24 2s 12 A. Since fall 2008. Q. And when do you expect to graduate? A, Fall 2010. Q. Are you a fulltime student or part-time? A. I'ma full-time student at this time, ~ Q. When you first arrived in Miami, Florida in fall of 2002 did you decide during that two weeks that you were going to stay permanently? A. No. Q. Okay. Did you go back to Poland? A, Yes, [have. F have — I went back for ‘Christmas. Q. Okay. Poor question, Going back to 2002 I'm trying to just understand how it was that -- you came over here on a two-week business visa, buf eventually you ended up staying for a tonger period of time, correct? A. Right. Q. Okay. And how did that come about, just tell me? A. Well, I got romantically involved with my current husband and so when -- you know, we just started dating, we got engaged, and that's how, you know, our relation evolved -- evolved, and eventually, got marris a Q. Okay. And since coming to the United States have you always lived in Miami, Florida? A. No. hed Q. All right. Where else have you lived in the United States? A. New York. Q. Where in New York? A. Manhattan. Q. What was the address in Manhattan where you lived? MR. ROSS: I'm going to advise you to invoke privilege. A, [refuse to answer. Q. Okay, Have you - are you familiar with an address at 301 East 66th Street in New York? A. [refuse to answer. MR. PIKE: May we take a break for a second? May I speak with you? MR. ROSS: Sure. VIDEOGRAPHER: Off the record, 10:22 a.m. (Recess taken at 10:22 a.m.) (Deposition resumed at 10:23 am.) VIDEOGRAPHER; On the record, 10:23 am. MR. ROSS: Brad, let me just interrupt for a moment. 4 {Pages 10 to 13} U.S. Legal Support (954) 463-2933

— 14; 16 1 MR. EDWARDS: No problem. ; 2 A. I'msony, { don't understand your question, 2 MR. ROSS: Justto be sure, when the witness | 2 Q. How long did you live at the 1040 South Shore 3 answers "refuse to answer" to be clear the full | 3 Drive address that you moved into in the fall in 2002? 4 statement that she’s not saying for the sake of i 4 A, Well, since ~ since [ came | lived there, I 5 saving time is that she's invoking her Fifth | 5 elways stayed there whether being in Miami traveling 6 Amendment right against self-incrimination. Just. | 6 back and forth, and I live currently af this address. 7 to be clear. ed Q. Okay. What was the first time that you moved 8 MR. EDWARDS: That's what I've understood all | 8 from that address to live elsewhere? 9 along. | 9 A. Ido not recall, 10 MR. MERMELSTEIN: That's what [ understood. | 10 Q. Okay. I know that you told me you lived in a MR. ROSS: Okay, fine. Go ahead. | 21 New York City and we're not going to discuss ~ I'm 12 MR. EDWARDS: This is just forthe sake of | 12 assuming you're not going to answer a lot of questions 13 brevity — | 13 about New York City, but at what time period did you 14 MR. ROSS: Exactly, 14 move there? Was it right after you got here two weeks, us MR, EDWARDS: -- and Jet's move it on. | 15 year tater? I'm just trying te get a year as to when BY MR. EDWARDS: | 16 you moved to New York? Q. All right. So I'm going to ask the question i 17 MR. ROSS: I'm going to instruct you not fo again, [ don't remember whether you'd responded yet, 18 answer, but are you familiar with the address in Manhattan | 19 A. [refuse to answer, 301 East 66th Street in New York? i 20 Q. Okay. Do you know a guy by the name of Jean A. T refuse to answer. ban Luc Brunel? Q. Okay. How long did you live in well, what | 22 A. Lrefuse to answer. - nas the flest address that you lived in in Miami? } 23 Q. Where are your parents? ‘A, 1040 Sci Shore Drive, Miami Beach, Florida 2a A. They're in Warsawy, Poland, ida, | 2s Q. And sit in the United States balsa e eRe erin encanta 15} 1 Q. South Shore, Okay. | 1 have they come ta the United States? 2 A. Um-hum. 2 A. Yes, they have visited me. 3 Q. Haye you ever had your deposition taken fe 13 Q. Have they ever met Jeffrey Epstein? 4 before? i 4 A, [refuse to answer. 5 A. No. { 5 Q. Have they ever met Jean Luc Brunel? 6 Q Okay. You're doing very well so far, There's | 6 A, Lrefuse to answer. 7 geouple rules 1 didn't explain but mainly because = | 7 Q. Where are you carrently employed? 8 you're doing very well. I just have towaitfor youto | 8 A. [pursue — I go to school full-time, I do not 9 finish your answers you have to wait for metofinisk =| 9 work, 10 my question. We have one court reporter. She can only! 10 Q. Are you also still in the modeling business 14 take down one of us. Give us an answer that we all | 11 though? 12 understand, Nodding of the head or shaking thehead | 12 A. No, I'm not. 13 are easy to do and I get what you're saying, but she i 13 Q. And when was the last time you did any 14 doesn't. Ab-ha or un-ah are things thatare commonly | 14 modeling? 15 said. ‘They look the same on paper. | 15 A. it would be late spring, early summer of 2006 16 If Task a bad question which could happen,as = | 16 went on a trip to Taiwan. 17 already happened and probably witl again, just tell me | 17 Q. And why did you stop modeling at that time? 18 — "Iden't understand the question,” I'l ask it again — | 1. A. wanted ~ I always kind of knew that it's 1g A. Okay. | 19 something that fm going to be doing and I just decided 20 Q. —allright? | 20 to go and pursue a college degree. 21 And I'm assuming that's the address, 1040 ian Q. Okay. Is it something that you ever plan to 22 South Shore Drive, where yon began fivingin fallof { 22 go back to, modeling? 2320028 | 23 A. No. 24 A, Correct. | ss 4 Q. Are you inyolved at all with the modeling 25 Q. How Jong did you live at that address? 12 industry? 3 (Pages 14 to 17) U.S. Legal Support (954) 463-2933

20 1 A, No. 1 Q. And how did -- how did it come about that you 2 Q L mean, helping to recruit models, helping | 2 began working with Jeffrey Epstein? 3 others to reeruit models, anything like that? : 3 MR. PIKE: Form. 4 A. No. o 4 A, Lrefuse to answer. 5 Q. Do you ever ~ do you currently talk to 5 Q. What did Jeffrey Epstein pay you in salary? 6 Mr. Brunet? | 6 MR. PIKE: Form, 7 A. [refuse to answer. fog A. Erefuse to answer. 8 Q. When is the fast time that you talked to i 8 Q. What was the time period that you worked for 9 Jeffrey Epstein? | 9 him? 10 A. [refuse to answer. | 10 A. [refuse to answer. i Q. Do you know a woman by the name of Ghislaine | 11 Q. Why did you step working for him? 12 Maxwell? 12 MR. PIKE: Form. 13 A, Trefuse to answer. ; 13 A. Lrefuse to answer. 14 Q. Do you know someone by the name of Sarak | 14 Q. What initiatly were you hired to do? 18 Kellen? j 15 A. Lrefuse to answer, 16 A. [refuse to answer, | as MR. PIKE: Form. 17 Q. Do you know a person named Nadia Marcinkova?, 17 Q. Has Jeffrey Epstein ever paid you to stay 18 A. [refuse to answer. | 18 quiet or keep quiet about what went on in his house? 19 Q. Did Jeffrey Epstein have anything todo with =| 19 MR. PIKE: Form, 20 you moving to New York City? | 20 A. Trefluse to answer. au A. Lrefuse to answer. aa Q. Have you talked to Sarah Kellen or Nadia 22 Q. Did you ever ive ina place in New York City | 22 — Mareinkova abot the things that went on in Jeffrey 23 owned or controlled by Jeffrey Epstein? 1 23 Epstein's house? 24 A. Trefuse to answer. \ 24 MR. PIKE: Form. 25 ig agency MC 125 A, Trefuseto answer, et 191 au 1 Squared? ; 2 Q. Did you sign a confidentiality agreement with 2 A. [refuse fo answer, | 2 Jeffrey Epstein? 3 Q. Do you know of underage females being | 3 A, refuse to answer. 4 transported into this country to work for the modeling | 4 MR. PIKE: Form. S agency MC Squared? aes Q. Did that confidentiality agreement outline 6 A. Lrefuse to answer. | 6 what you should say to authorities should he be caught 7 Q. Do you know of those underage females being i 7 with underage females? a given work visas and staying at the 301 East 66th , 8 MR. PIKE: Fonn, 3 Street address? : i 9 A. Trefisse to answer. 10 A. [refxse to answer, | 10 Q. Is there another book or manual or written ii Q. Can you say whether you have observed | 11 memorialization of what you, as an employee of Jefire: 12 Mr. Brunel or Mr. Epstein engaging in sex with underage| 12 Epstein, should do if confronted by taw enforcement? 13 females? | 13 MR. PIKE: Form. 14 A. I refuse to answer. j 14 A. [refuse to answer. 15 Q. Do you know where Mr. Brunel lives? ; 15 Q. Are you invoking your Fifth Amendment right 16 A. Erefuse to answer. | 16 because you believe you could be prosecuted? uy Q. Isit true that Mr. Branel stays in the 301 {7 MR. ROSS: Invoke. 18 East 66th address frequently with underage femaies? 1g A. [refuse to answer. 19 A, refuse to answer. { 29 Q. Are you aise invoking because you're seared to 20 Q. Atwhat point were you hired to work for 20 testify against Jeffrey Epstein? 21 Mr. Epstein? , 22 MR. PIKE: Form. 22 MR, PIKE; Form. | 22 A. Lrefuse to answer. 23 MR. EDWARDS: You can still answer the | 23 Q. When did you first learn that Jeffrey Epstein 24 question. Mr, Pike is making a legal objection. i 24 had a sexual obsession for underage females? 25 A. I refuse to answer. | 25 A. [refuse to answer. 6 (Pages 18 to 21) U.S. Legal Support (954) 463-2933

wOInuhrwne 10 12 13 14 16 24 20 24 7 | MR. PIKE: Form, | 1 different than they are here, but are you familiar with Q. Isn't it true that you have seen Jeffrey rope the Florida Statutes that protect children against Epstein sexually interacting with females as young as | 3 —_sexual offenders or sexual predators? 12 years old? ia MR. ROSS: Invoke. A. [refuse to answer, i 5 A. Lrefuse to answer. MR. PIKE: Form, | 6 Q. Let me just read you the lewd or fascivious Q. Is it true that you have observed Jeffrey | 7 molestation statute and then I'm going to ask you some Epstein's sexual obsession to include the age range 12 i 8 questions about it, to17? | 9 It says: “A person whe intentionally touches MR. PIKE: Form. | 10 ima tewd or lascivious manner the breasts, genitals, A. Erefuse to answer. | 14 genital area or buttocks or the clothing covering them Q. Have you ever had sex with Jeffrey Epstein? | 12 ofa person less than 16 years of age or forces or A. lrefuse to answer. i 13 entices a person ander 16 years of age to so touch the MR. PIKE: Form, } 14 perpetrator, commits lewd or lascivious molestation, a Q. Have you ever been paid for sex with Jeffrey | 15 second degree felony.” Epstein? | 16 After hearing that statute isn't that MR. PIKE: Form, I i? something — isn't that a crime that you know A. [refuse to answer. i 18 Mr. Epstein to have committed on an everyday basis Q. Do you know if Nadia Marcinkova had sex with) 19 while you were working for him? Jeffrey Epstein when she was underage? | 20 MR. PIKE: Form. MR. PIKE: Form. | 22 A, Erefuse to answer, A. [refuse to answer. | 22 Q. And that’s a statute that he violated with Q. What have you been told about Jeffrey | 23 more than 100 underage females; is that true? Epsteia's sexual obsession with underage minor 24 MR. PIKE: Form children? 7 . {35 Set ate 2 23] 25 MR. PIKE: Form, it Q. When did you become aware that Mr. Epstein wa A. Trefuse to answer. ; 2 a child molester? Q. Isu'tit true that Jeffrey Epstein interacted =| 3 MR. PIKE: Form, sexually with underage minors on an everyday basis? i 4 A. refuse to answer. MR. PIKE: Form. foes Q. Have you ever seen him with a femafe under the A. [refuse to answer. | 6 age of 12? Q. And most of the time Mr. Epstein would he MR. PIKE: Form. interact with underage minors at least two times aday;| 8 A. [refuse to answer. is that true? los Q. Have you ever knowe Jeffrey Epstein to have MR. PIKE: Form. 10 sex with an adult? A. Trefuse to answer. a2 MR. PIKE: Form. Q. Can you expiain to the jury how Mr. Epstein | 12 A. frefuse to answer. Would access new underage minor females for sex every 13. Q. Does he — is he sexually attracted to adults? day? {14 MR. PIKE: Form. MR. PIKE: Form, i 18 A. [refuse to answer. A. Trefuse to answer. | 16 Q. When was the first time you learned of Q. How many assistants did Jeffrey Epstein hire | 7 Mr. Epstein getting a massage from an underage minor to bring him underage minor females for sex? | 18 female? A, Lrefuse to answer. | 19 MR. PIKE: Form, MR. PIKE: Form. 20 A. [refuse to answer, Q. Were you one of those assistants that helped =| 21 Q, Eveatize some of these questions may sound to bring him underage minor females? | 22 repetitive but during this case we've learned of key MR. PIKE: Form, \ 23 terms that different people on Mr. Epsicia's iet's say A. [refuse to answer, { 24 payroll or inner circte recognize or talk about, So Q. [know that the laws in Poland are probably i 25 when I talk about "massages", do you know what that Lace Rd 7 {Pages 22 to 25) U.S. Legal Support (954) 463-2933

Car nnr one 10 41 12 a3 14 41s 16 17 18 19 20 22 22 23 24 25 we eawanewne 16 a1 42 13 14 15 16 17 18 19 20 al 22. ae" 24 25 term means? MR. PIKE: Form. A. [refuse to answer. Q, isn’t "massage” the word chat was told by Jeffrey Epstein to all of his employees to refer to whatever acts he engages in with underage femates in his bedroom? MR. PIKE: Form, A. [refuse to answer. Q. Al this point — were you — were you ever in the bedroom witb him when he was engaging in sexual acts with underage females and calling them "massages"? MR. PIKE: Form. A. [refuse to answer, Q. Did you ever participate in any of the sexnal acts that Jeffrey Epstein was having with underage females? MR. PIKE: Form. A. [refuse to answer. Q. Now, just so that the record is clear there is not a single piece of evidence that ever indicates that you were involved with underage femates, I'm not even implying that and I realize that you invoking it may — may give the wrong light and that’s not— that’s not intention, ~ but were you ever aware of Nadia 27 Marcinkova participating in sex with underage femates?; A, Trefuse to answer, Q. Have you read the police reports related to the criminal investigation into Mr. Epstein? A. [refuse to answer. Q. And you're aware of this 87-page police report that details numerous females that indicate that they i : ' i i | | | } { | | were involved sexually with Mr. Epstein when they werd minors? A. [refuse to answer. MR. PIKE: Form. Q, Did anyone instruct you to use the code word "massage"? A. I refuse to answer. Q. And when referring to these underage minor females that would come over to Mr. Epstein's house did anybody also tell you to use the term "work"? A, [refuse to answer. MR. PIKE: Form, Q. Meaning whea somebody would call ta schedule one of these underage femaies for a massage isn't it ‘true that they would say "It's time to come to work” and schedule a specific appointment? MR. PIKE: Form. A. [refuse to answer. wOdIn He wone 25 es 28 Q. Is there a book or manual or is it written anywhere that the -- that sex with underage minors is to be referred to as a "massage"? A. Lrefuse to answer. MR. PIKE: Form, Q. Were there ever team meetings, for lack of a better word, where Jeffrey Epstein and possibly Ghislaine Maxwell, Sarah Kellen, yourself, would talk about this organization of obtaining underage girls for Jeffrey Epstein for sex? MR, PIKE: Form. A. Trefuse to answer. Q. What methods dees Jeffrey Epstein use to gain access to underage minor femates for sex? MR. PIKE: Form. A, Trefuse to answer. Q. What is your understanding of Jeffrey Epstein's involvement with the modeling industry? MR. PIKE: Form. A. Lrefuse to answer. Q. Have you ever medeted for MC Squared? MR. PIKE: Form. A. [refuse to answer. Q. Has Jeffrey Epstein ever promised you anything related to a modeling career? MR. PIKE: Form. A, [refuse to answer. Q. Have you ever tatked to Jean Luc Brunel about modeling? A. [refuse to answer. Q. Have you ever talked to Jean Lac Brunel about his desire to have sex with underage females? A. [refuse to answer. Q, Isn't it true that Jean Lac Brunel has been in trouble for years for having sex with underage minors in Europe? A. [refuse to answer, Q. Are you famitiar with The McIntyre Reports? A. Trefuse to answer. Q. Okay. Are you familiar with reports done on modeling agencies back in the 80's and 90's related to agency owners having sex with waderage minors? MR. ROSS: Answer the question. A. No, I'm not. Q. Okay. Did you ever hear of Jean Luc Brunel's reputation for having sex with underage girls? MR. ROSS: Invoke. A, [refuse to answer. Q. Do you know how Jean Luc Brunet knows Jeffrey] Epstein? 8 (Pages 26 to 29) U.S. Legal Support (954) 463-2933

30 L A. [refuse to answer. 2 MR. PHKE: Form, 3 Q. isn't their connection the obsession for 4 underage minor females? 5 MR. PIKE: Foon, 6 A. Trefuse to answer. 7 Q. Based on your observations of Jeffrey Epstein 8 would you categorize his obsession for underage minor 9 females as an addiction? 10 MR. PIKE: Form. 41 A. Lrefuse to answer. 12 Q. Isn't it true that Ghislaine Maxwell delivers 13 underage minor females to Jeffrey Epstein? 14 MR. PIKE: Form. 15 A. [refuse to answer. 16 Q. Have you ever had a sexual relationship with iy Ghislaine Maxwell? 18 A, Trefuse to answer. 19 Q. Do you know what Ghislaine Maxwell does in 20 general for Jeffrey Epstein? 2. MR. PIKE: Form, 22 A, Irefuse to answer. 23 Q. Have you seen photographs of underage minor 24 females in Jeffrey Epstein's patrol — controt or 1 MR, PIKE: Form. 2 A. Frefisse to answer. 3 Q. Were there surveillance cameras, hidden 4 surveillance cameras inside Jeffrey Epstein's home? 5 ‘MR, PIKE: Form. 6 A. Trefuse to answer. 7 Q. Did those surveillance cameras capture 8 underage minor females naked? 9 MR. PIKE: Form. 10 A. [refuse to answer, li Q, And didn't Jeffrey Epstein and Ghislaine 12 Maxwell watch those surreptitiously obtained videos of 13 underage minor femates? 14 MR. PIKE: Form. 15 A. T refuse to answer. 16 Q. And those videos and photographs of underage 18 im his house, right? 19 MR. PIKE: Form. 20 A. [refuse to answer. 24 Q. Have you seen those photographs and videos on 22 Jeffrey Epstein's computers? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. Who have you talked to related to the criminal 32 investigation into Jeffrey Epstein? A. Lrefusse to answer, MR. PIKE: Form MR. ROSS: In addition, attorney-client privilege. Q. And I certainly would ~ do not want to know anything you talked to your attorney about, [ apologize, A. (Nods.) Q. Why was it that you were named as 2 co-conspirator of Jeffrey Epstein's in the non-prosecution agreement? MR_ PIKE: Form. A, Lrefuse to answer. Q. Do you feel like a victim of Jeffrey Epstein's? MR. PIKE: Form. A. [refuse to answer. Q. Deo you feel like Jeffrey Epstein brainwashed you to some extent? MR. PIKE: Form. A. [refuse to answer. Q. De you feel any remorse for any rele that you may have played in having underage minor females at Jeffrey Epstein's house for him to molest then? 33 MR. PIKE: Form, A, refuse to answer, Q. Bave you known Ghislaine Maxwell and Jeffrey Epstein to keep sex slaves? A, Trefuse to answer. Q. De you know somebody named Virginia Roberts? A. [refuse to answer. Q. Have you met Virginia Roberts? A. Lrefase to answer. MR, EDWARDS: Allright Let me go ahead and mark a5 — as Plaintiffs Exhibit | a lawsuit that was filed by Bob Josefsberg on behalf of Jane Doe 102 v, Jeffrey Epstein just for the purposes of asking the witness some questions. MR. ROSS: I've seen it, (Whereupon, Plaintifts Exhibit 1 was marked for identification.) Q. Have you ever read the lawsuit Jane Doe 102 v. Jeffrey Epstein? A. Irefase to answer, Q. In the lawsuit it indicates the plaintiff was 15 years old when Ghislaine Maxwell and Jeffrey Epstein had a threesome with this underage minor female. Are you aware of that? ‘MR. PIKE: Form. 9 {Pages 36 to 33) U.S. Legal Support (954) 463-2933

COA R WHE 10 11 12 43 14 is. 16 Ww 18 19 20 21 22 23 24 25 —— scatterer becieeatate oe aes 34 T i A. [refuse to answer. i Q. And Jeffrey Epstein and/or Ghislaine Maxwell | obtained and purchased passports for 15-year-old Jane | Doe 102 to transport her to Paim Beach, New York City, Santa Fe, Los Angeles, San Francisco, St. Louis, as well as Europe, the Caribbean, and Africa; are you aware of that? A. Urefuse to answer, MR, PIKE: Form. Q. It's also alleged that Jeffrey Epstein in addition to molesting Jane Doe 102 along with Ghistaine' Maxwell forced her to have sex with other models, actresses, and celebrities? A, I refuse to answer, MR. PIKE: Form. Q. It also indicates that Jeffrey Epstein transported other minor girls from Turkey, the Czech Republic, Asia, and other countries, Are you aware of that? MR. PIKE: Form. A. [refuse to answer. Q. 1s Jeffrey Epstein involved in the international child sex trade? MR. PIKE: Form, A. Irefuuse to answer. Bene woarau 36 Q. Jane Doe 162 ultimately escaped from him and jeft to Australia, is that your understanding? A, refuse to answer. MR. PIKE: Form. Q. Have you ever spoken with Jane Doe 102? A. I refuse to answer. Q. On one of Epstein's birthdays a friend of Jeffrey Epstein sent to him 12 -- three 12-year-old girts from France who spoke no English for Epstein to sexualty exploit and abuse and after doing so he sent them back to France the next day. Are you familiar with that? MR, PIKE; Form. A, [refuse to answer, Q. Isn't that something that is fairly common for Mr. Epstein? A, [refuse fo answer, MR. PIKE: Form. Q. Whe are the friends that send to Jeffrey Epstein underage minor females for his birthday so that| he can abuse? A. [refuse to answer, MR. PIKE: Form. Q. Is one of those friends Jean Lue Brunel? A. refuge to answer. | Q. Is Jean Luc Bronel his partner in hat / international child sex (rade? | MR. PIKE: Form. | A. Lrefuse to answer. | Q. Are you aware that after - that Jeffrey | Epstein forced Jane Doe 102 to have sex with other | adult male peers ineluding royalty, politicians, | academicians, businessmen and/or other professional a 4 personal acquaintances of Jeffrey Epstein's? i MR. PIKE: Form. | A. [refuse to answer, Q. 1s that something that he did with girls other | than Jane Doe 102? i MR. PIKE: Form. | A. Lrefuse to answer, i Q. Aren't you familiar with Jeffrey Epstein's | practice of pimping out underage minor females to other| people that have the same sexual obsession with | underage minors? ' MR. PIKE: Form, | A. [refuse to answer. | Q. And doesn’t he benefit financially from that | sex trade? | MR. PIKE: Form. | A. [refuse to answer, j OR IHORWH io 11 12 13 14 15 16 1? 18 19 20 21 22 22. 24 25 37 Q, Have you ever met Prince Andrew? A, refuse to answer. Q. Has Prince Andrew been involved with underage) minor femates to your knowledge? A. Lrefuse to answer. Q. Have you ever met Alan Dershowitz? A. Irefuse to answer. Q. When Alan Dershowitz stays at Jeffrey Epstein's house isn't it true that he has been at the house when underage minor femaies have been in the bedroom with Joffrey Epstein? A. I refuse to answer. Q. Has ~ are you familiar with the media publication or online resource RadarOnline? A. Ltefuse to answer. Q. Is that something that you assisted Mr. Epstein with when he purchased RadarOnline? A. Trefuse to answer. Q. And do you know his business partner in that endeavor? A, [refuse to answer, Q. Isn't it alse true that he used RadarOnline as another way fo gain access to underage minor females for sex? MR. PIKE: Form. 10 (Pages 34 to 37) U.S. Legal Support (954) 463-2933

Pe POWAY AH H&S WNH BeBe Pee SOIAAHRHRYWN 20 ai 22 23 24 25 wo OIauewn ete 1d 12 13 14 15 16 17 18 1g 20 at 22 2 24 25 i A. [refuse to answer, | Q. Have you been to all of Jeffrey Epstein's | properties? | MR. PIKE: Form. ! A. Erefuse to answer. | Q. Certainly you've been to the property at 358 | E1 Brillo Way, correct? ' MR, PIKE: Form. \ A. [refuse to answer, i A. Trefuse to answer. | MR. PIKE: Form. { Q. And have you been to his island in—itwas |} Little St, James, I believe be calls it Little i St. Jeff's now? | MR. PIKE: Form. | A, [refuse to answer. i Q. And have you witnessed underage child sex | orgies on that istand? | MR. PIKE: Form, i A. Lrefuse to answer. | Q. Do you know a female named Jeletzia? | A. [refuse to answer. i Q. Do you know where Jeletzia lives these days? : A, Trefise to answer. ! Q. What is your understanding of Sarah Keen's | role in Jeffrey Epstein's life? | A. Lrefise to answer. I MR. PIKE: Form. / Q. Isn’'tit true that she gets paid just to bring | him underage minor females for sex? | MR. PIKE: Form. i A, Lrefuse to answer, | Q. And additionally, she schedules the | appointments for underage minor females for him to | molest? | A. Trefiase to answer, | MR. PIKE: Form, \ Q. You know Dana Burns? | A. Lrefuse to answer. i Q, Does she still work for Ghislaine Maxwell? | A, Lrefuse to answer. | Q. Was she an underage minor child victim of | Jeffrey Epstein's? | A. Lrefuse to answer. Q. Through discovery we've tatked to uumerous witnesses about, you kuow, Jeffrey Epstein and people that work for him. I don't know if you'll be able to answer any of these questions but i'll ask them anyway ‘one at a time. 23 24 25 Is Sarah Kellen somebody who travels with Jeffrey Epstein? MR. PIKE: Form, A. [refuse to answer. Q. And when Jeffrey Epstein is coming to town doesn't he call Sarah Kellen, his number one assistant? MR. PIKE: Form. A. [refuse to answer. Q, And at some point in time, if looks like in early 2005 ar tate 2004, you were also an assistant of Jeffrey Epstein's, correct? MR. PIKE: Form. A, Irefuuse to answer. Q. And how was it that you transitioned from being involved in modeling to being an employee of Jeffrey Epstein? MR, PIKE: Form. A. [refuse to answer. Q. Other than arranging for underage minor females to come to Jeffrey Epstein's house did you do anything else for Jeffrey Epstein? MR. PIKE: Form. A. I refuse to answer, Q. Did you ever fly on Jeffrey Epstein's A. [refuse to answer. Q. Did you witness Jeffrey Epstein abuse — sexually abusing underage minor females on his airplane? MR. PIKE: Foon. A. Trefuse to answer. Q. Did you know that it was illegal for Jeffrey Epstein to interact sexually with underage minor females? MR. PIKE: Form. A. Trefluse to answer. Q. Did you ever object to Jeffrey Epstein interacting sexually with underage minor females? MR, PIKE: Form. A, I refuse to answer, Q. Would Jeffrey Epstein get angry at you if you did not have an appointment set for him with an underage minor female? MR. PIKE: Formn. A, Lrefise to answer. Q. Has Jeffrey Epstein contacted yeu in the last year? A. Irefuse to answer. MR. PIKE: Form. Q. Has Sarah Kellen contacted you within the fast — 11 (Pages 38 to 41) U.S. Legal Support (954) 463-2933

COIHRY ROK 1 12 aa 14 is 16 17 18 19 20 aL 22 23 24 we Ovaeewne 10 li 12 i3 14 15 16 7 18 ig 20 2i 22 23 24 25 year? A, [refuse to answer. Q. Has anybody that is associated with Jeffrey Epstein's party contacted you in the last year? MR. PIKE: Form. A, Trefuse to answer. Q. By that I mean to include Ghislaine Maxwell, Lesley Groff, any of these people, have they contacted | you within the last year? MR. PIKE: Form. A. Frefuse to answer. Q. Are you familiar with the names of some of the underage minor females? A. Trefuse to answer. Q. Are you famitiar with LM? A. I refuse to answer. Q. Do you remember what LM looked fike? A. [refuse to answer. Q. Are you famifiar with EW? A. [refuse to answer. Q. De you remember what EW leoked like? A. [refuse to answer. Q. Are you familiar with Jane Doe? A, [refuse to answer. femaics that Jeffrey Epstein interacted with sexually during a time when you were working for him; isn'¢ that true? A, [refuse to answer. MR. PIKE: Form. Q. And LM was somebody that went ever to Jeffrey Epstein's house and was molested at a young age by him more than 106 times; is that true? MR. PIKE: Form. A. [refuse to answer, Q. And EW was also somebody who went over to Jeffrey Epstein's house when she was between 14 and 16 years old more than a hundred times; isn't that true? MR, PIKE: Form. A. refuse to answer, Q. And Jane Doe was somebody that went to Jeffrey Epstein's house more than 15 times to be molested by Jeffrey Epstein when she was 14 and 15 years old; is that true? MR. PIKE: Form. A. Trefuse to answer. Q, sit also true that LM brought to Jeffrey Epstein's house between 50 and 75 other underage minor, females for Jeffrey Epstein to molest? | OOIH Ye wWN NNNNNKRP EEE PP Pe ee Aewane seein oe wnro we OWaues wn 44 A, Lrefuse to answer, MR. ROSS: Form. Q. Are you aware of Jeffrey Epstein's for tack of a better word “ritual* with these underage minor females in his bedroom? MR. PIKE: Form. A. [refuse to answer. Q. Wouldn't it generally begin with Jeffrey Epstein placing a call to Sarak Kellen or yeurself and telling you that he's going to be in town at the Palm Beach mansion? MR. PIKE: Form. A. Trefuse to answer. Q. And then isn’t there a fist of underage minor females stored in the computer system? MR. PIKE: Form. A. Trefiuse to answer. Q. And that computer system is interconnected from his New York home, his New Mexico home, his island, his home in France, and West Palm Beach; is that correct? MR. PIKE: Form. A, [refuse to answer. Q. And have you seen that list of underage minor MR. PIKE: Form, A, [refuse to answer. Q. And isn't it true there are over a thousand girls at any given time between the age range of 12 and 17 all of which have been molested by Jeffrey Epstein? ‘MR. PIKE: Form. A. Trefuse to answer. Q. And when Mr. Epstein would call and tell you the time that he was going to be in town it would then be your job to get an underage minor female to his house and set a specific appointment for that persons is that correct? MR. PIKE: Form, A, refuse to answer. Q. And he would tell you the exact time of day that he wanted his two or three appointments to molest| underage minor females? MR. PIKE: Form, A. [refuse to answer. Q. And you would go into the computer system and call the person that he told yon he wanted to see for that day; is that correct? MR_ PIKE: Form. A, Lrefuse to answer. Q. And that may be Brittany or Tatum or Courtney] 12 (Pages 42 to 45) U.S. Legal Support (954) 463-2933

46 48 1 or somebody local that you would call on the telephone | 1 in time Jeffrey Epstein showed you exactly what hte does 2 amd tell them to come work at a specific time? | 2 with each of these girls in the bedroom, correct? 3 MR. PIKE: Form, | 3 MR. PIKE: Form. 4 A. [refuse to answer. | ¢ A. [refuse to answer. 5 Q. And didn't Mr. Epstein tell you that the way | 5 Q, So after about — he would order the underage 6 you need to tell these girls is that they are working | «=««6~——sminor female to begin massaging him, correct? a so that they do not feel chat they have the option to | 7 MR, PIKE: Form. 8 decline? ios A, Lrofuse to answer. 9 MR. PIKE: Form. | 9 Q. And then he would roll over and begin to 10 A. [refuse to answer. | 10 masturbate with his right hand, correct? qn Q. Tmean, the psychology of it all was explained =| 11 A. Lrefuse to answer. 12 im detail by Jeffrey Epstein; isn't that correct? ; 1 Q. And then he would begin also grabbing the 13 MR. PIKE: Form. | 13 breasts, buttocks, aud vagina area of these underage 14 A, [refuse to answer, | 24 minor fematks, correct? is Q, And once the girls were inside the bedroom ; a5: A. [refuse to answer, 16 Jeffrey Epstein said that he can take care of the rest, | 15 MR. PIKE: Form. 17 correct? a7 Q. And his ritual was so specific that with each 18 MR. PIKE: Form. | 18 of them he would demand that they pinch his nipples 1g A. [rofuse to answer. [19 very hard, right? 20 Q. And the underage minor female would show up att 20 MR. PIKE: Form. 21 the house and be greeted at the door by either , oak AL Lrefuge to answer. 22 yourself, the house manager, or Sarah Kellen, correct? | 22 Q. That's a fetish that you know that Jeffrey 23 MR. PIKE: Form, 23 Epstein has, right, he likes his nipples pinched very 24 A. Trefuse to answer. | 24 hara? 1¢ minor females including | 47) 1 my three clients, LM, EW, and Jane Doe youmet =| 1 A. Trefuse to answer, 2 personally, right? ; 2 Q. And as he's masturbating with one hand and has 3 A. Irefuse to answer, | 3 his other hand groping or inserting his fingers into 4 MR. PIKE: Form, {o4 the underage minor's vagina he's also telling them to 5 Q. And then you would lead thera upstairs to his | 5 pinch his nipples, correct? 6 bedroom and Leave him alone in the bedroom, leave my} 6 MR. PIKE: Form. 7 client alone in the bedroom? 17 A. [refuse to answer. 8 MR. PIKE: For. ; 8 Q. And this continues -— and sometimes this 9 A, [refuse to answer. | 9 escalates to him using vibrators, correct? 10 Q. Anditet’s take LM, and she went there many | 10 MR. PIKE: Form. 14 times between the ages of 13 and 16. Ifshe was taken | 11 A, [refisse to answer. 12 _up to his bedroom she would be feft atone in the 12 Q. And have you seen vibrators in the Paim Beach 13 bedroom until Jeffrey Epstein arrived, correct? | 13 mansion house? 14 MR. PIKE: Form. | 14 MR, PIKE: Form, 15 A. Trefuse to answer. | as A. Trefuse to answer, 16 Q. And Jeffrey Epstein would appear usually naked| 16 Q. And other times he orders Nadia Marcinkova to 17 and order for her to take her clothes off? | 17 partietpate in these encounters with underage miuor 18 A. Lrefuse to answer. | 18 females; is that correct? 19 MR. PIKE: Form. | ag A. [refuse to answer. 20 Q, And then Mr. Epstein would lay face down on ' 20 Q. Are you familiar with Nadia Mareinkova 21 the massage table would usually be the next step, | 21 strapping on dildos to have sex with these underage 22 correct? | 22 minor females? 23 MR. PIKE: Form. | 23 MR. PIKE: Form, 24 A. [refuse to answer. | 24 A. I refuse to answer. 25 Q, And you know this ritual because at some point 25 Q. And when Miss Marcinkova would have sex th 13 (Pages 46 to 49) U.S. Legal Support (954) 463-2933

CRA RAHRWNHE we ewtaoueuwne 10 12 12 13 14 is 16 17 18 19 20 22 22 2x 24 25 MR. PIKE: Form. 50} the underage minor females Jeffrey Epstein would watch) and continue €o ejac -- continue to masturbate, correct? MR. PIKE: Fonn. A, [refuse to answer. Q. Has he ever asked you to participate in these threesomes with underage minor females? A. Lrefuse to answer. MR. PIKE: Form, Q. Have you ever participated in sex with underage minor females at the direction of Jeffrey Epstein? MR. PIKE: Form. A. [refuse to answer. Q. The ~ this whole experience that fam explaining right now is identical every single time with these underage minor females; isn't that your understanding? MR, PIKE: Form. A. [refuse to answer. Q. And this whole experience is what he has taught you and the other employees to call a "massage", correct? MR. PIKE: Form. A, [refuse to answer, Q. And it always ends with bim ejaculating? | | | i i { | i i i A. [refuse to answer. MR, PIKE: Form. Q. And then he offers 200 to $300 cash to the underage minor female, correct? MR. PIKE: Form. A. Lrefise to answer. Q. And then he also gives them another — another option to make money whieh is each time you come to my ‘house and we engage in this sexual interaction I will give you $200, but each female you bring me like you, between the age range of 12 and 16, I will pay you $200 per person, MR. PIKE; Form. Q, Is that something you're familiar with? A. [refuse to answer. Q. And LM at that offer was one of the girls who brought him 75 plus underage minor females, correct? MR. PIKE: Form. A, Trefuse to answer, Q, And so he's basically created a pyramid of underage minor females where the computer system has a thousand of these femates ready to come over to work for him? ODIYAHRwWNHH COVA RW 10 11 12 13 14 15 16 17 18 19 20 22 22 23 24 25 52 A. [refuse to answer, Q. Do you know what Jeffrey Epstein does for a fiving? A. [refuse to answer, Q. Does he do anything aside from interacting sexually with underage minor females? MR. PIKE: Form. A. Lrefiuse to answer. Q. Do you know how it is that he made his money where he ts purported fo be a billionaire? A. Trefuse to answer. MR. PIKE: Form. Q. Do you know David Copperfield? A. [refuse to answer. Q. Is David Copperfield somebody that would come| info town and interact sexuaity with underage minor femates? A, [refuse to answer. Q. Do you know Martin Nowak? A. Trefuse to answer. Q. Is that also somebody that would interact sexually with underage minor females? A. Irefuseto answer,” Q. Do you know Leslie Wexner? A, [refuse to answer. 53 Q. Is that somebody you've met before? A. Trefuse to answer. Q. Has Mr. Epstein himself interacted sexually with Leslie Wexner? MR. PIKE: Form. A. [refuse to answer. Q. When Mr. Epstein was being investigated criminally how did you first learn about that? A. [refuse to answer. Q. Atsome point in time he was tipped off that his home — that a search warrant was going to be executed on his home, correct? MR. PIKE: Form. A, Trefiuse to answer. Q. And just a month before the execution of that search warrant -- less than a month before the execution of that search warrant he ordered you to de something with certain evidence, didn't he? MR. PIKE: Form. A. [refuse to answer, Q. In fact, there were at least three very key computers that contained a lot of the information that I've been asking you about. You're familiar with those computers that were in his house, correct? MR. PIKE: Form. 14 (Pages 50 to 53} U.S. Legal Support (954) 463-2933

COI HAY HW a1 12 13 14 15 2i 34 A. [refuse to answer. Q. And he ordered you to come over and take those computers out of his house, correct? e A, [refuse to answer. MR. PIKE: Form. Q. And you could basically take the tocat database that exposed this criminal enterprise that T've been talking about dealing with sex with underage minor vehicles -- underage minor females and you could take the evidence from his home, correct? MR. PIKE: Form. A. [refuse to answer. Q. And yea've seen the material that's on those computers, correct? MR, PIKE: Foem, A, [refuse to answer, Q. And if I were to look at those computers it would display exactly what I've been deseribing to you today, right? MR. PIKE: Form, A. [refuse to answer. Q. And you went to his house with a mate, correct? A. I refuse to answer. Q. There was one other guy with you that helped that assisted you to take these computers frou his home; is that right? MR. PIKE: Form A, [refuse to answer. Q. Where did you take those? A. Trefuse to answer. Q. Did you take those -- was it Bill Reilly that went to the home? A, [refuse to answer. Q. Do you know who Bill Reifly is? A. [refuse to answer. Q, He's one of the investigators hired by Roy Black to represent Jeffrey Epstein? A, Trefluse to answer. Q. Did you take those computers ever to your house? A, Trefuse to answer. Q. And I guess the house that I would be talking about is the 1640 South Shore Drive, have those computers ever been to that house? MR. PIKE: Form, A, [refuse to answer. Q. Were you nervous about the fact that you were | | | | | | | i | COIAH mM WNe 24 56 search warrant was imminent? A. [refuse to answer, Q. Did you ever question when you were directed to take these computers from his home? A. refuse to answer. Q. How much additional money or bonus were you paid to take the computers that we're talking about out| of Jeffrey Epstein’s house? MR. PIKE: Form, A. [refuse to answer. Q. Would those computers reveal criminal activity of only Jeffrey Epstein or of others? MR. PHKE: Form. A. Erefuse to answer. Q. Did you talk with Sarah Kelien about the criminal investigation into Jeffrey Epstein and others? A, Lrefuse to answer. Q. Well, at some point in time what's been marked as Defense Exhibit 1, you received a Grand Jury investigation target letter, correct? A. Irefuse to answer, Q. Welt, we have it right here. I'm familiar with it. I know you got the letter and 1 know that, you know, the substance of it you’re not going to tell 57 the search warrant was executed on his home back in October of 2005. So during those two years leading up to this target letter who did you talk to? A, [refuse to answer. Q. Did you-MR. ROSS: And privilege. Attorney-client privilege. Q. Okay. In addition to your attorney did you taik to anybody else about the criminal investigation? A, I refuse to answer. Q. And Brace Lyons was your initial computer — computer -- was your initial attorney in this case, correct? MR. ROSS: You can answer yes or no. A. Yes. Q. Okay. And that was an attorney that was hired for you by Jeffrey Epstein? MR. ROSS: Invoke. A. Lrefuse to answer, Q. Someone that was paid for by Jeffrey Epsteia to represent you? MR. PIKE: Form, A. Trefluse to answer. Q. So once he hired you a criminal attorney then [25 _ taking these computers out ofthe homeata time whens] 25 itseemed like you did something wrong? 15 (Pages 54 to 57) U.S. Legal Support (954) 463-2933

\ MR. PIKE: Form. | A. refuse to answer. | Q. You hadn't actually gone into any relationship | with Jeffrey Epstein with the intent to commit crimes, did you? A, Lreflse to answer, Q. You didn't know that ke was a child molester when you first met him, did you? MR. PIKE: Form. A. Trefuuse to answer, Q. Were you impressed by his money and his lifestyle? A, frefuse to answer. Q. Did you think that he could get you further in fife if you would just listen to what he said? MR. PIKE: Form. A. [refuse to answer. Q. At this point in time you have no contact with him as a child molester, do you? MR. PIKE: Form. A. [refuse to answer. Q. Did Jeffrey Epstein assist in getting you a visa? A. [refuse to answer. Q. Has he done any favors for your family? A. [refiuse to answer, MR. PIKE: Form. Q. Is he paying for your college? A, [refuse to answer. MR. PIKE: Form. Q. Right now is he paying for your college? MR. ROSS: Invoke. A. [refiuse to answer. MR. PIKE: Form. Q. Did Jeffrey Epstein ever tall to you about the chances of him going to prison? A, Lrefuuse to answer. MR. PIKE; Form, Q. Did Jeffrey Epstein ever talk to you about what he intended his defenses to be to the criminal actions he committed against these underage minors? A, [refuse to answer. MR. PIKE: Form. Q. Did he tell you that he would spend as much money as possible to intimidate and harass these underage ntinor victims? A, Trefiuse to answer. MR PIKE: Form. Q. Did he teil you that he would destroy their 60 1 credibility? 2 A. Lrefuse to answer. 3 Q. Did he tell you that he could scare them to go 4 away? 5 A. Lrefuse to aaswer. 6 MR. PIKE; Fonn and forn to the last question. 7 MR. EDWARDS: All right. Let's see, what did 8 Isay, f said this was -- 7 9 MR. ROSS: 1. A 10 MR. EDWARDS: -- Plaintiff's 1 and we're going, 11 to write on the back of it and then -- okay, 12 Q. Jeffrey Epstein kept message pads near all of 13 his phones in his home, right? 14 MR. PIKE: Form. ais A. I refuse to answer. 16 Q. And those are message pads that have a carbon 17 copy back side to them, you're farailiar with them? 18 MR, PIKE: Form. 19 A. Trefuse to answer. 20 Q. And this is for anybody who takes a message al they write it down that somebody called, the reason for| 22 calling, the time that they called? 23 MR. PIKE: Form. 24 A. Erefuse to answer. Q. And many a times anytime that Jeffrey Epstein 61 1 was in town there were at least two scheduied = “raassages” for lack of a better word, with Jeffrey 3 Epstein and these underage minor females, correct? 4 A. [refuse to answer. 5 MR. PIKE: Form. 6 Q. And do you have the -- and there was a ¥ particular scheduling book that contained these 8 appointments with - between Jeffrey Epstein and 9 underage minor females, correct? 10 MR. PIKE: Form. 41 A. Trefuse to answer. 12 Q. And it was your primary responsibility to 13 assist Sarah Kellen in setting these appointments up, 14 right? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. It took at least two or three full-time 18 employees to keep up with Jeffrey Epstein’s addiction 19 — tounderage minors, correct? 20 A. Trefise to answer. 21 MR. PIKE: Form. 22 Q. Lestey Groff did pretty much the same thing up| 23 in New York, right? 24 MR. PIKE: Form. 25 A. Irefuse to answer. 16 (Pages 58 to 61) U.S. Legal Support (954) 463-2933

wOwIanewne 62 Q. And you've familiar that there is this group of girls in New York that were summoned to his home for generally the exact same thing as the Palm Beach girls? A. | refluse to answer. Q. Allright. MR. PIKE: Form. Q. I'm going to show you an exhibit here, we'll mark it as — you know what, it's a buneh of message pads, I'm going to mark it as 2A, -B, -C, -D, whatever. So we'll say 2A. (Whereupon, Plaintiff's Exhibit 2A through 2. were marked for identification.) Q. Do you recognize it? A, Lrefuse (0 answer. Q. Okay. MR. PIKE; May I see that? MR, EDWARDS: Sure. Q. Do you recognize the handwriting on it? A. Lrefuse fo answer. Q. Ht indicates "Adriana hasn't confirmed Julie for 11 yet, so she is keeping Brittany on hold in case Tulie doesa't call back." What does that message mean? A. [refuse to answer. MR, PIKE: Form, Q. Sulie's an underage minor femate that Jeffrey Epstein was going fo molest at 11:00, correct? MR. PIKE: Form. A. [refuse to answer. Q. And if Julie wasn't available then you had another underage minor fervate named Brittany that could step in her place and fulfill that role for Jeffrey Epstein, correct? MR. PIKE: Form. A. Lrefuse to answer. | | | | i | | | { i } | | | | | | | | | | Q. All right. 2Bis another message pad and I'm going fo ~ we'll stop slipping the process of moving this on and I'ma assuming you're not going to be able to answer as to whether or not you -- you recognize that either, right? A. Frefuse to answer. Q. Okay. This is a message from 9/4/05, s0 September 4th, 2005, 7:25 p.m. saying "Adriana cancelled Julie. She would like to speak to you L believe about college," and a telephone number. And then a question from you, "Shaudd I schedule anyone else?" What did that message mean? MR PIKE: Form, A, Trefuse to answer. COIN ewne eC rmItIAvAHAeRwWwne 10 11 12 13 14 is 16 17 18 19 20 21 22 23 64 that he would promise these girls something in order to] get them to allow him to sexually abuse them? MR. PIKE: Form. A. [refuse to answer. Q. Because he certaialy did not want them to tell the police, correct? A. [refuse to answer. Q. And did you have many meetings about what to do if any of these girls told the police? A, Trefuse to answer. MR. PIKE: Form. Q. Was it always known that Jeffrey Epstein would hire everyone attorneys and tell everyone just met fo talk? MR, PIKE: Form, A. T refuse to answer. Q. And at the same time then he contd employ a bunch of investigators, dig up a bunch of dirt on these girls, and intimidate them and scare them to go away, correct? MR. PIKE: Form, A. [refuse to answer, Q. And Jeffrey Epstein doesn't like ~ he didn't fike any of these underage minor females, right? MR, PIKE: Form, 65 A. [refuse to answer. Q. In fact, it was the opposite, he liked to hurt them; isn't that true? MR, PIKE; Form. A. Trefuse to answer. Q. And after they came forward if they told the truth he was dead set on hurting them even more, correct? ‘MR, PIKE: Form. A, Lrefuse to answer. Q. And that's also a feeling that Ghislaine Maxwell shared as well, correct? A. [refuse to answer, Q. And that’s something that she also told yeu, “Don't worry. If we get caught we have it covered and we'll just attack these little girls," MR. PIKE: Form, A. refuse to answer. Q. Allright. There's another message from 9/10/05, "Adriana says Lauren confirmed for 4 p.m." Can you tell us what that message means? MR. PIKE: Form. A. I refuse to answer. Q. it’s another underage minor female that Jeffrey Epstein's going to molest at 4 p.m., correct? » a as 17 (Pages 62 to 65) U.S. Legal Support (954) 463-2933

66 A, [refuse to answer. Q. And when I say “nrolest", you know, he may say massage", [ mean, that's ~ that's something interchangeable, right? MR. PIKE: Form. A, Lrefuse to answer, Q. If's the routine that I described in detail that is identical with every single girl every single time, correct? A. Trefuse to answer. Q. And it's basically as far as be can get with this underage minor female without ker crying or screaming or running out of the house? MR, PIKE; Form. A. [refuse to answer, Q. Did you ever see any of the girls cry or scream or ran ont of the house? ‘MR. PIKE: Form. A. Trefuse to answer. Q. Did you have a personal relationship with any of these underage minor females? A, [refuse to answer. Q. There's another message here from 9/10/05, same day later in the day, 10 pm. saying “Julie will | be Brittany?" [ Do you know what that message means? MR. PIKE: Form. A. [refuse to answer. Q. What is this? ‘There's another message from 9/11/05 saying "I got a car for," and then the name is blotted out. The State Attorney's Office blotted the names of minors out| sometimes in their file, Sedo you do you know— | can you fill in that blank? | A. Erefuse to answer. | Q. Do you know if this was the car that he rented for Jane Doe 47 i A. [refuse to answer. i Q. All right. Or the car that he rented for AH? j A. Lrefuse to answer. MR. PIKE: Form. | Q. You're familiar with both of those people, ! right? ; A. Lrefuse to answer, ; Q. Infact, AH was somebody that was over at; Jeffrey Epstein’s house many times, correct? A. I refuse to answer, MR. PIKE: Form, Q. 9/5/2005. Message from Adriana saying "I left message for Ashley to confirm for 11 a.m. and Vanessa | | ' | i Ww OIA one oe a ) 10 a2 12 13 14 1s 16 a) 18 19 20 aL 22 23 24 25 68 for 4:36 p.m.” Do you remember leaving that message? A. Lrefuse to answer. Q. And this is ~ MR. PIKE: Form. Q. Ies his typical schedule where he schedules one underage minor female to molest in the moraing and one in the afternoon, correct? MR. PIKE: Form. A. Trefuse to answer, Q. Eimean, considering this is — have you ever worked anywhere else where there is somebody sexuaily| molesting anderage minor females on a daily basis tike this? MR. PIKE: Form, A. Trefiuse to answer, Q. At some point in time did you fell your parents that this was happening? MR. PIKE: Form. A. [refuse to answer, Q. Did you ever talk to anybody else in the house and say "Hey, look, this is aot right"? A. [refuse to answer. Q. Do you feel sorry for these girls? A. Trefuse to answer. Q. And you say you do or you do sot remember AH? A. [refuse to answer. Q. Okay. And do you know what happened up in the bedroom between AH as a minor and Jeffrey Epstein? MR. PIKE: Form. A. Lrefuse to answer, Q. Well, this is what she tells police: "She arrived at the house, went upstairs to the bedroom. She advised she immediately removed her clothing and Nadia Marcinkova and Epstein were already naked in the] bedroom, AH explained that Nadia Marcinkova and she had a sexual encounter that included kissing, touching, and oral sex. AH remembered that she climaxed and was removing herself from the massage table, Epstein then turned AH onto ber stomach on the massage fable and inserted his penis inte her vagina, AH stated Epstein began to pump his penis in her vagina. AH became upset! over this, She said her head was being held forcibly against the bed as he continued to pump inside her. She screamed 'No,' and Epstein stopped. He would normally pay ker $200, but for this ke apologized and paid her a thousand dollars for that visit.” Are you familiar with that encounter? A. [refuse to answer, MR. PIKE: Form. 18 (Pages 66 to 69) U.S. Legal Support (954) 463-2933

Q. Do you remember a time when AH asa 16-year-old I believe at this time left her house left the house visibly upset? MR. PIKE: Form. A. [refuse to answer, Q. She advised that ste was ripped and torn in her vagina area and had difficulty wathing to the car; do you remember that? MR. PIKE: Form. A. [refuse to answer, Q. These message pads were message pads that were taken from trash palls outside of Jeffrey Epstetn’s home and for the most ~ welt, there's so many messages here, but most of them are by somebody other than yourself. So my question is who are the other people that would take messages for Jeffrey Epstein for underage minor females to come to the house? MR, PIKE: Form. A, Trefiase to answer. Q. And the messages include CL, "Can I come work today?" What does “work" mean? A. [refuse to answer. MR, PIKE: Form. Jeffrey Epstein sexually molesting this person while she was underage; is that correct? A. Lrefuse to answer. MR. PIKE: Form. Q. And it was also pretty frequent that the girls would come in tandem, isn't that true, two at a time? MR. PIKE: Form. A. [refuse to answer. Q. And one being the girl that would bring the ‘new girl there, would wait downstairs while the new girl was upstairs getting molested but then getting paid? MR. PIKE: Form. A. [refuse to answer. Q. How did Jeffrey Epstein explain himself to you! as to why he did this? MR. PIKE: Form. A. Frefuse to answer. Q. Do you know when it is that he first became sexually obsessed with underage minor females? MR. PIKE: Asked and answered. A, Lrefuse to answer, MR. PIKE: Form. | Q. Did you know that he was a school teacher at i the Dalton School? | wow nnwe wre 25 72 A. [refuse to answer. Q. And at that point in time -- well, are you aware of him molesting underage minors while he was a teacher there? A, [refuse to answer. Q. There's another note that’s not a message pad which F guess I will — since it has your name on it will mark it as what are we on ~ 3 - wait, C~ MR. ROSS: 3. MR. EDWARDS: I messed up. MR. ROSS: 3. (Whereupon, Plaintiff's Exhibit 3 was marked for identification.) Q. Look at that while I fix what I've messed up over here. MR. ROSS: I'm going to show this to the witness, MR. EDWARDS: Yes. Yes. Q. Do you recognize that document? A. [refuse to answer. Q. There are a lot of different things on here that doa‘t necessarily relate to you. At least I can’t tell that they do. But it does indicate “Adriana’s parents are going to the embassy on the 23rd." Do you remember when that happened? 73 A. [refuse to answer. Q. Why did your parents go to the embassy? A, [refuse to answer. Q. More importantly why was Mr. Epstein concerned that your parents were going to the Embassy? MR. PIKB: Form. A. I refuse to answer. Q. Was — at that point in time was Mr. Epstein assisting your parents with anything? A. [refuse to answer, Q. Are your parents citizens of the United States? MR. ROSS: Form, A, Trefuse to answer. Q. Are you? A. No. Q. Has Mr. Epstein ever offered to get you a visa for the United States? A. Erefuse to answer. MR. PIKE: Form. Q. Do you know Raer Roshan? A. Trefuse to answer. Q. That was Jeffrey Epstein's partner in RadarOnline, correct? A, Trefuse to answer. 19 (Pages 70 to 73) U.S. Legal Support (954) 463-2933

ce ODIDRDeWNE RONRARE BPE EE RRR Ro GQekOESERSLVHIHAH RANE O Cert Hoewn er 10 12 13 14 15 16 417 13 19 20 21 22 23 24 25 74 Q. And if I showed you every single message pad here would you be able to answer any of the questions | about any of the messages that were left at Jeffrey Epstein's house? A, [refuse t answer. MR. EDWARDS: Okay. That saves us alot of time. MR. ROSS: It did. Q. Have you ever met Bill Clinton? A. refuse to answer. Q. Is Bill Clinton -- was Bill Clinton a friend of Jeffrey Epstein's? A. Lrefisse to answer. Q, {s Bill Clinton somebody who Jeffrey Epstein has ever procured underage minor femaies for? A, [refuse to answer. MR. PIKE: Form, Q. And just-- and just for, you know, the sake of what the evidence shows, there's no evidence that I have that indicates that that happened, but if yon were going to answer that question I'm willing to ask it. i i i i i | | j } Have you met him at Jeffrey Epstein's house in| Paim Beach County? MR, PIKE: Form. 75} | i | i | | i | | ! Q. You have flowa on Jeffrey Epstein's airplanes numerous times, correct? A. [refuse to answer. Q. As welt has Bill Clinton and you're aware of that, right? MR. PIKE: Form. A. [refuse to answer. Q. Have you ever seen the flight fogs from Jeffrey Epstein's airplanes? MR. PIKE: Form. A, Lrefise to answer. Q, And on many times it is Bil Clinton, Secret Service agents, Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, aud others. Have you — do you know about those flights? A. [refuse to answer. MR. PIKE: Form. Q. And have you ever witnessed sex on any of Jeffrey Epstein's flights? A. I refuse to answer. MR. PIKE: Form. Q. Do you know Emmy Taylor? A. [refuse to answer, Q. Is that somebody that is Ghislaine Maxwell's sex slave? 22 24 25 76 A. refuse to answer. Q. And isn’t it typical for Jeffrey Epstein to have a sex slave that flies with him on the airplane? A. I refuse to answer. MR, PIKE: Form, Q. And one of the qualifications is that the section slave be underage, correct? MR. PIKE: Form. A. [refuse to answer, Q. And if the sex slave is 15 years old isn't it your understanding and based on your observations that} he will even make them dress as if they’re Lk or 12? MR. PIKE, Form A, Trefuse to answer. MR, PIKE: Form. Q. Bo you know President Andres Pastrana? A, [refuse to answer. Q. Bo you know him as somebody who has had sex with underage minor females brought to him by Jeffrey Epstein? MR. PIKE: Form. A. I refuse to answer. Q. Have you ever heard of Ehud Burak? A. [refuse to answer. Q. Is that another person that Epstein — Jeffrey Epstein pracures underage minor females for? MR. PIKE: Form. A. [refuse to answer. Q. You've met Naomi Campbell I'm assuming? A. Lrefuse to answer. Q. Anytime separate and apart from any dealings with Jeffrey Epstein have yeu met her in the modeling] industry? That's a model, right? ‘MR. PIKE: Form. MR. ROSS: You can answer the question. A, No, Ihave aot. Q. Okay. Do you know Todd Meister? A, Lrefuse to answer, Q. Joel Pashcow? A. [refuse to answer. Q. You've been to their houses? A. Lrefuse to answer. Q. De you know Aline Weber? A. [refuse to answer. Q. Have you ever stayed at the 301 East 66th Street places with Aline Weber? MR. PIKE: Form. A. Trefuse to answer. Q. And typically aren't there at least 16 20 (Pages 74 to 77) U.S. Legal Support (954) 463-2933

COOIHRUHRWHH 10 12 43 14 18 16 17 18 wordranve wn underage minor females staying at those various condominiums located at 304 East 66th Street? A. [refuse to answer. Q. And those females get work visas to say that they're models, but actually they are prostituted out by Jeffrey Epstein and John Lac Brunel, correct? A, [refuse to answer. MR. PIKE: Form. Q. And various businessmen and politicians around | New York and Washington, D.C. go to those apartments! frequently to have sex with underage minors; is that | tenet | A, [refuse to answer. | Q. Do you remember a flight oa December 3rd, 2004: that you took with Jeffrey Epstein, Nadia Marcinkova, Sarah Kellen, and somebody with initials SH — i A. [refuse to answer. | Q. ~ from JFK to PBI? \ MR, PIKE: Form, | Q. Do you remember that? | A, Trefase to answer | Q. Who is SH? : A, [refuse to answer. ' 1 Q, Is that an underage minor? 713 Q. Do you remember a fight that you took December 27th with Nadia Marcinkova and Jeffrey Epstein? A. Lrefuse to answer. Q. What airport is this, TIST? A. Trefuse to answer. Q. De you know Doug Band? A. [refuse to answer. Q. Isn't that Bill Clinton's assistant? A, [refuse to answer. Q. You've been on the airplane with him before? A, Erefiise to answer. Q. Have you been on the airplane with Bill Clinton before? A. I refuse to answer. Q. Who is Tatiana? A. [refuse to answer. Q. That's somebody you've flown with on Jeffrey; Epstein's plane on numerous oceasions, correct? MR. PIKE: Form A. Trefisse to answer. Q. In fact, during the year 2005 you flew on Jeffrey Epstein's plane would you say more than 50 times? A. [refuse to answer. COOH TRWHe OC MRAIHRHRYWHE 1¢ ad. we: 13 14 as 16 17 19 20 aL 22 23 24 25 80 MR. PIKE: Form. Q. And you flew to his island, right? A. Erefuse to answer. MR, PIKE: Form, Q. You flew to New Mexico? A, [refuse to answer, MR, PIKE: Form, Q. You flew to New Jersey? MR. PIKE: Form. A. {refuse to answer. Q. Several of the flights are just yourself, Jeftrey Epstein, and Sarah Kellen, What did you do on] those flights? MR. PIKE: Form. A. [refuse to answer. Q. Who's Adam Perrylang? A. I refuse to answer. Q. Is that somebody that you were made to have sex with? A. [refuse to answer. Q. Did Joffrey Epstein ever make you have sex with any females? MR. PIKE: Form, A, Exefuse to answer, B81 friends? MR. PIKE: Form. A. [refuse to answer. Q. Who is Sandy Berger? A, [refuse to answer. Q. That's somebody else that was affiliated with Bill Clinton at one poiat in time, correct? A, Erefuse to answer. Q. A close friend of Jefttrey Epstein's? MR. PIKE: Form. A. [refuse to answer, Q. He called the house within three weeks of the search warrant being executed. Did he tip off Jeffre; Epstein? MR. PIKE: Form. A. [refuse to answer. Q. Is he somebody that's involved with underage minors? A. Trefuse to answer. Q. De you know Igor Zinoviev? A. refuse to answer, Q. Andrea Metrovich? A, Irefuse to answer. Q. Have you flown on the airplane with Alan Dershowitz before? 21 (Pages 78 to @1) U.S. Legal Support (954) 463-2933

82 MR, PIKE: Form. A. refuse to answer. Q, And Jean Luc Brunel is somebody who you have been on the airplane with several times, correct? A. Lrefuse to answer. MR. PIKE: Form, Q. And when Jean Luc Brunel is on this airplane there are underage minor -- minor females on the airplane with you, correct? MR. PIKB: Form. A. [refuse to answer. Q. Is there 2 back room to this airplane? Is there any sort of separation or is it all one big room? MR, PIKE: Form. A, Trefuse to answer. Q. So if Jeffrey Epstein and Jean Luc Brunel are engaged in sex acts with underage miners did you -~ A, [refuse ~ Q. Sorry ~did you observe any of those acts? A. [refuse to answer. MR. PIKE: Form. Q. And on aumerous of the flights the flight logs indicate someone's name then oftentimes initials, bat sometimes it would just say "three females", Do you A. Lrefuse to answer, MR. PIKE: Form. Q. Who's Claire Hazel? A, [refuse to answer, Q. Do you know JoJo and Lyan Fontanella? A. Erefuse to answer. Q. They're the house managers up at the mansion up in Manhattan, correct? MR. PIKE: Form. A, Lrefise to answer, Q. And they assist Mr. Epstein ia engaging in underage sex with minors in New York, correct? MR. PIKE: Foon. A. Trofuse to answer. Q. They also maintain a pretty close retationship with the police? A. Lrefuse to answer. Q. And that's a big component also, right, that Jeffrey Epstein has -- is friendly with the law enforcement, correct? MR. PIKE: Form. A, Erefuse to answer. Q. Like law enforcement would do favors for not only Jeffrey Epstein but his various assistants. If i you were speeding around the neighborhood they woalda't | OOIHRH® WN 10 11 12 13 14 45 16 17 18 19 20 21 22 23 24 WON UR Wn 10 lk 12 13 14 is 16 17 18 io 20 22 22 23 24 25 84 give you a ticket, correct? MR. PIKE: Form. A. [refuse to answer. Q. Was it ever your job to call the police departinent and ask if any police reports were on file or anybody complained about the activities at Jeffrey’ Epstein's house? MR. PIKE: Form, A. [refuse to answer. Q. Have you ever gone physically to the police department? A. [refuse to answer. Q. Was there a flight where you flew alone with Jean Luc Brunel? A. I refuse to answer. Q. Have you ever flown on the plane with Prince Andrew? MR. PIKE: Form. A, [refuse to answer. Q. Do you know Zinta Braukis? A. Erefuse to answer. Q. That's another model that Jeffrey Epstein knows, correct? A. Lrefixse to answer. 85 Q. Somebody that ite had engaged in sex with when she was underage? A, Irefuse to answer. Q. She actually got a modeling contract out of in? MR. PIKE: Form. A, Lrefuse to answer. Q. Why does Jean Luc Brunel and Jeffrey Epstein fly together so often? MR. PIKE: Form, A. Trefuse to answer. Q. And why does Ghislaine Maxwell also fly so often with Jeffrey Epstein and Jean Luc Brunel? A. Lrefase to answer. MR. PIKE: Form, Q. Isn't it true that all three of them are obsessed and addicted to sex with underage minors? MR. PIKE: Form. A. refuse to answer. MR. PIKE: Brad, how much longer do you have? MR. EDWARDS: How fong? You want to take a break? MR. PIKE: Yeah, MR. EDWARDS: Sure, It's going a fot faster than I thought it would. 22 {Pages 82 to 85) U.S. Legal Support (954) 463-2933

13 wavrnneone PEER Ee BON ro is 21 22 23 24 25 i VIDEOGRAPHER: Off the record, 11:33 am. 3 (Recess taken at 11:33 a.m.) | 2 (Deposition resumed at 11:43 a.m.) 1 3 VIDEOGRAPHER: On the record, 11:43 am. loa BY MR. EDWARDS: 5 Q, Allright. There's one more message that I ; 6 wanted to ask you about, As I mentioned, I'm not going! 7 to go through ail of the messages that [ have, but | 8 there's one from 9/4/2005, 9:08 a.m. from Adriana, "Is | 9 it okay for Tatum to stop by aud drop something?” | 10 A. [refuse to answer. ji MR. PIKE: Form, | a2 Q. So what were your hours working for Jeffrey | 13 Epstein? | 14 A. Lrefuse to answer. 1 15 Q. Imean, some of these messages are 9:00 in the 16 morning and others are as late as 8:30 or 9 at night, i 17 So what were your hours? | 1s A. Irefuse to answer. 19 Q. Another message from 9/4 also, same day, | 20 “Ashley," I think, “confirmed an 11 a.m., Vanessa isat | 21 4:30 p.m." | 22 MR. MERMELSTEIN: I think that's one you did. «| 23 MR. EDWARDS: Ob, yeah? Okay. | 24 Q. All right. Do you remember that message? } 25 87} A. [refuse to answer, | 1 MR. EDWARDS: Da you care how I attach it i 2 since it's « i 3 MR. ROSS: No. ; 4 MR, EDWARDS: I'l attach it as whatever it i, is. | 6 MR. ROSS: 4, | 4 MR. EDWARDS: 2-- well, [lljust go 2H since | 8 it's amessage, You don't have 2 problem with | 9 thar? 249 | 10 MR, ROSS: Whatever. Pu (Whereupon, Plaintiff's Exhibit 2H was marked 12 for identification.) | 43 Q. Do you still consider Jeffrey Epstein a | 44 friend? , as A, Trefuuse to answer. i 16 MR. PIKE: Form, {47 Q. Did you ever think of Jeffrey Epstein as a i 18 friend? p19 MR. PIKE: Fonn. 1 20 A, [refuse to answer, | al Q. Other than the people that I've mentioned | 22 of— you know, President Pastrana and Ehud Burak and) 23 Prince Andrew did you meet any other people of royalty, 24 being friends with Jeffrey Epstei | 2s 88 MR. PIKE: Form. A. I refuse to answer. Q. Can you tell us any of the other folks that Jeffrey Epstein would supply underage minor girls to? MR. PIKE: Form, A. Trefisse to answer. Q. Do you know a maa by the name of Glean Dubin? A. [refuse to answer. Q. Do you know his wife? A, refuse to answer. Q. His wife at some point in time was associated with Jeffrey Epstein; is that correct? A. [refuse to answer. Q. And her name's Eva Dubin; is that right? A. [refisse fo answer. Q. Either way, isn't it true that Jeffrey Epstein then started supplying anderage femates to Glenn Dubin? MR. PIKE: Form, A. [refuse to answer. Q. Do you know Johanna Sjoberg? A, Crefuse to answer. Q. Is that somebody who also worked for Jeffrey Epstein? A. [refuse to answer. MR. PIKE: Form. Q. Did Jeffrey Epstein ever get a legitimate massage from somebody that's a masseuse? MR. PIKE: Form, A, [refuse to answer. Q. The underage females that we've talked about particularly, LM, EW, and Jane Doe, those girls were not prostitutes, were they? A. Lrefase to answer. Q. These were just girls whe were in 8th, 9th, 10th grade in high school, right? A, Urefase to answer. Q. These were girls that you knew had never committed prostitution in the past, right? A. Erefuse to answer. Q. And that goes for all of these girls on the phone list of underage minors to call, these were not prostitutes, correct? A. Trefuse to answer. Q. You never called a prostitation or escort service for Jeffrey Epstein, did you? MR. PIKE: Form. A, [refuse to answer. Q. And as well you never called a legitimate massage parlor for Jeffrey Epstein, correct? refuse to answer. 23 (Pages 86 to 89) U.S. Legal Support (954) 463-2933

MR. PIKE: Form. Q. He devised this scheme of having underage minor girls bring him other underage minor girls so; that he could gain access to his target age group, 12 to 16 years old, correct? A, I refuse to answer. Q. Have you heard Jeffrey Epstein say "The younger the better?" A. [refuse to answer. | Q. And did Jeffrey Epstein tell you that it made him happy the younger the girl was? | A, [refuse to answer. MR. PIKE: Form. Q. The less developed the girl is the more excited Jeffrey Epstein gets; is that true? MR. PIKE: Form. A. [refuse fo answer, Q. Do you ever plan to talk to Jeffrey Epstein in | the future? A. Trefuse to answer. MR. PIKE: Form. Q. Would you ever work for bim again? A. Lrefuse to answer. Q. Why didn’t you stop working for him sooner? A, Trefuse to answer, MR. PIKE: Form. Q. Did you ~ well, you knew that it was illegal what he was doing at the time you were doing it, correct? A, [refuse to answer. Q. Did you know that you were part of a large child molestation ring? MR. PIKE: Form. A. [refuse to answer. Q, Did you ever tell aayone while you were working for hint that you wanted to stop? A, [refuse to answer. MR. PIKE: Form. Q. Did you continue working there because you were just scared to stop? A. Liefuse to answer. MR. PIKE: Form. your services for his child molestation ring? A. [refuse to answer. MR. PIKE: Form, Q. Did Jeffrey Epstein ever threaten you? A. Trefuse to answer. MR. PIKE: Form. Jeffrey Epstein might do to you if you quit performing, | | | | | 25 92 Q. Did Ghistaine Maxwell ever threaten you? A. Lrefiase to answer. Q. How was it decided who would call which girl? A. Erefuse to answer. Q. And by that, just so it’s clear, like I said, there's going to be many, many, many message pads, I have not counted them, but a lot created by either yourself or someone named Janusz Banaziak or Louclla Rabuyo, Alfredo Rodriguez, Nadia Marcinkova, Sarah Kellen, various people that we know to have been employed at Jeffrey Epstein’s home. And it seems that on one particular day Sarah may call several girls, you may call several girls, Nadia may call several girls. Whe is directing which — which of you, which of the assistants is going to call the underage minor to give them an appointment? A, Trefuse to answer, MR. PIKE: Form, Q. And what would happen on the occasions where Jeffrey Epstein says he's going to be in towa aud then he's ultimately not in towa but 2 girl shows ap anyway? MR. PIKE: Form. A. frefuse to answer. Q. Weren't you just toid just to pay her to keep her happy? 93 A. Exefuse to answer. Q. And isn't part of the whole scheme that these girls were typically told "Don't tell anybody what goe on inside this house,” right? MR. PIKE: Form. A. I refiuse to answer. Q. And did Jeffrey Epstein tell you that because these girls are young and they're poor and they're underprivileged type girls they're likely not geing to say anything anyway? Isn't that what he told you? MR. PIKE: Form. A. refuse to answer. Q. Did Ghistaine Maxwell talk to you about that as well? A. I refuse to answer. MR. PIXE: Form. Q. Have you seen Jeffrey Epstein angry? A. Trefuse to answer. Q. Isn't it true that he’s very nice and engaging as long as he gets his way and gets you te caoperate, right? A. Lrefuse to answer. Q. But if he doesn't get his way he gets very, very angry and mad and scary; isn’t that true? A. Lrefluse to answer. 24 (Pages 90 to 93) U.S. Legal Support (954) 463-2933"

Pr 16 944 Q. And you've seen both sides of him, right? A. [refuse to answer. Q. In fact, you know of girls whe were £3 years old and cooperated with everything he said because they} felt they had no choice up in that bedroom, right? A, Trefuse to answer. MR. PIKE: Form. Q. And you also know girls who resisted and were yelled at and told to grab their money and get out of there, right? A. [refuse to answer. Q. Wouldn't you agree that that house upstairs can be somewhat confusing in how it's — how it's laid out? A, [refuse to answer, Q. Io fact, there's a stairwell that starts from the kitchen, there's a door and it almost blends in in the kitchen with the other closets, correct? A. [refuse to answer. MR. PIKE: Form, Q. But you open that door and there's a stairway i i | i | | | | t | i | | | | | j | i : | i : | \ | that Ovists it seems to the left and there's another door at the top of that stairway, right? A. [refuse to answer. And then when you exit that stairway you take 95 } | a right and you head towards a little hallway that eventually leads into Mr. Epstein's bedroom, right? A. [refuse to answer. Q. And if it’s your first time in that bedroom as a 14-year-old girl and you don't like what's happened | up there would you agree that it's a tough way to find | i \ | yous’ — a place to find your way out of? 1 MR. PIKE: Form. A, [refuse to answer. Q, Did Jeffrey — didn’t Jeffrey Epstein tell you that he would act as a father-type figure fo these giris? A, [refuse to answer. MR. PIKE: Form. Q, And he would propose that what they are doing! for him or with him despite the law is okay? A. Lrefuse to answer. MR. PIKE: Form. Q. And they could continue to make a lot of money! ‘if they would come over and be his sex victims, right? ; MR. PIKE: Form. A. [refuse to answer. Q. And you were aware when my client, LM, was pregnant at 16 years old that Jeffrey Epstein bought everything on her baby registry, right? | ; | i i ' { i 4 COA KRHRON HE 96 A. [refiuse to answer, MR. PIKE: Form. Q. Was it you or Sarah Keller that took ail of the gifts over to her home? MR. PIKE: Form, A. Trefuse to answer. Q. Tbelieve it was Sarah Kellen in a -- did Jeffrey Epstein own a Mercedes? MR. PIKE: Form. A, [refuse to answer. Q. And do you remember when Sarah Kellen loaded: up the Mercedes with all the baby gifts and took it to my client's trailer? A, [refiuse to answer, Q. And that was so that while LM -- that was to thank her while she was pregnant she continued to bring him 13-, 14-, and 15-ycar-old girls to molest, correct? MR. PIKE: Form. A, Erefuse to answer, Q, Because LM would no longer qualify as somebod: he'd be sexually interacting with as she was pregnant, correct? MR. PIKE: Form. A. Erefuse to answer. interacting sexually with Mr. Epstein are if you have tattoos, right? A. [refuse to answer. Q, If you're African-American or black? A, Trefuse to answer. Q. You've never known him to interact with an African-American or black girl, have you? A, [refuse to answer, Q. Ef you've been pregnant? A, Lrefuse to answer. Q. Or if you are pregnant, correct? A, I refuse to answer. Q, But certainly he was not above having a pregnant 16-year-old girl bringing him underage minor females, correct? A. Lrefuse to answer. Q. In fact -MR. PIKE: Form. Qfavor in that be was giving her money for providing a was his belief that he was doing her a service, correct? MR. PIKE: Form. A. refuse to answer. Q. Is it Jeffrey Epstein's belief that he did these girts a favor? 25 (Pages 94 to 97) U.S. Legal Support (954) 463-2933

wot nnr Ne 25 A. Lrefuse to answer, Q. I mean, doesn't he think that these girls are lucky that be ever — that they ever — that he ever allowed them out of their trailer and into his mansion, correct? A. [refuse to answer. MR. PIKE: Form, Q. We've defined the molestation statute or at Jeast I read it to you earlier and now we've talked about this scheme of Jeffrey Epstein gaining access to this number of underage minor females. At the time when you were working for him did you recognize him ag a serial child molester? ! MR. PIKE: Form. j A. [refuse to answer, Q. Do you know of anybody that ever worked for him that quit working for him because of what he was doing? A. Lrefiuse to answer, MR. PIKE: Form. Q. Do you know Michael Friedman? A, Trefuse to answer. Q. Is that somebody you ever met there? A. [refuse to answer, bring underage minor fernates from? A. refuse to answer. Q. Do you know why he chooses the countries that! he chooses to import underage minor females from? A, [refuse to answer. MR. PIKE: Form. Q. Was Nadia -- do you know how old Nadia Mareinkova was when she came to this country? A, [refuse to answer. i Q. Have you had conversations with Nadia i Marcinkova about Jeffrey Epstein bringing her to this, country? | A. Erefuse to answer. | Q. She's been described by some as his | Yugoslavian lesbian sex slave. Is that something that | is an accurate description based on the observations | you have? | A. [refuse to answer. | MR. PIKE: Form, \ Q. Did you ever engage in any lesbian sex with | Nadia Marcinkova? | A, I refuse to answer. { Q. Has Sarah Kellen ever had sex with Jeffrey | Epstein? MR. PIKE: Form. 100 A. Lrefuse to answer, Q. Do you know how it is that Sarah Kellen met Jeffrey Epstein? A. Trefuse to answer, Q. Do you know Story Cowles? A, Trefuse to answer, Q. You know who Sergio Cordero is? A. [refuse to answer, Q. Well, that’s somebody who also assists Mr. Epstein in bringing him underage minor females for] sex, correct? A. Trefuse to answer. ‘MR, PIKE: Form. Q. And Khalid Monroe, you know who that is? A. [refuse to answer. Q, Also somebody that through MC Squared or some| affiliation with that modeling agency would help for Jeffrey Epstein to gain access to underage minor females for sex, correct? MR. PIKE: Form. A. [refuse to answer, Q. And do you know of trips that Mr. Cordero, Mr. Brunet, and Mr. Epstein took to Brazil specifically for the purposes of Mr, Epstein engaging in sex with 101 MR. PIKE: Form. A, Lrefuse to answer. Q. Are you -- you are aware that Jeffrey Epstein pled guilty to two felonies related to his sexual interactions, correct? A, I refuse to answer. Q. Okay. VIDEOGRAPHER: Excuse me, counsel. MR. ROSS: { object on privilege grounds -attorney-client privitege grounds. MR. EDWARDS: Okay, fine, { was trying fo get ‘imo an area we may get answers. VIDEOGRAPHER: Coutd 1 just get you to put your phone on the table? I'm starting to get interference, MR. ROSS: The phone? VIDEOGRAPHER: Yes, sir. MR. EDWARDS: You got a secret phone? VIDEOGRAPHER: It's anytime it receives any kind of information. MR. ROSS: Oh, okay, yeah, it's VIDEOGRAPHER: It's not that it's ringing. MR. ROSS: Right. It's not doing it now. VIDEOGRAPHER: I apologize for the interruption. eee a cde 2 ce RE SE eee Re 26 (Pages 98 to 101) U.S. Legal Support (954) 463-2933

wwe Oo OInn T T | | | i } { i i i | | | | | | | i 4 | | | | i | | | 102 Q. Allright. Eask you that question because there was also something called a non-prosecution agreement. Are you familiar with that document? A, [refuse to answer, MR. ROSS: Attomey-client privilege. Q. And that is also a document that included your mame as a co-conspirator; are you familiar with that? A. [refuse to answer. MR. ROSS: Attorney-client privilege, Q. And that is because of your invelvement with caiting on the telephone auderage minors to bring them to Jeffrey Epstein’s house, correct? A. [refitse to answer. Q. Or for your involvement in scheduling appointments in Jeffrey Epstein's appointment book for underage minor —,underage minor females to be involve: with Jeffrey Epstein sexuaily, correct? MR. PIKE: Form. A. I refuse to answer. Q. It is certainly not because you sought out this child molestation ring in hopes of rising to the top, correct? MR, PIKE: Form. A. Lrefisse to answer. Q. Dida't you do everything that you did that 103 | anybody could ever say is illegal at the direction of Jeffrey Epstein? i A, [refuse to answer. | Q. And if it wasn't at the direction of Jeffrey i Epstein it was at the direction of Ghislaine Maxwell or | Sarah Kellen, correct? | MR. PIKE: Form. | A. Trefiase to answer. | Q. Imean, those things were not things that you | Jeffrey Epstein; isn't that right? | MR. PIKE: Form, | A, [refuse to answer. | Q. And you continued to do these things either | out of fear or because you were just impressed with | Jeftrey Epstein's lifestyte? | A, refuse to answer. { Q. Aren't you angry for him involving you in this | criminal activity? I A, [refuse to answer. | MR. PIKE: Form. Q. Do you ever intend in the future to talk about what he did aud what he involved you in? ' MR. PIKE: Form, | A. refuse to answer. i OO IAH RWHP 12 — 104 Q. Wouldn't you like to separate yourself being the person that you are from this person who brought you inte this mess? MR. PIKE: Form. A. Lrefuse to answer. Q. Is Jeffrey Epstein paying for your attorney now? MR, PIKE: Form, A. refuse to answer. MR. ROSS: Well, actually you can answer. A. No, my parents help me, Q. Are you aware of Jeffrey Epstein's closest friends now? A Erefluse to answer. MR, PIKE: Form, Q. Who are the people that you believe are Jeffrey Epstein's enemies? MR, PIKE: Form. A. Trefuse to answer. Q. Did you ever find out that Jeffrey Epstein and Ghislaine Maxwell had been targeting and preying upon underage females for sex for more than a decade? MR. PIKE. Form. A. Lrefuse to answer. you know? A, Lrefase to answer, MR. PIKE: Form, Q. Since being on house arrest has Jeffrey Epstein continued to engage in sex with underage minor| females? MR. PIKE: Form. A. [refluse to answer. Q. Knowing that his habit was more than ~ was at least two underage minor females for sex every single day do you believe that he stopped? MR. PIKE: Form, A. Trefuse to answer, Q. Isn’e it your belief that he will continae to do that once ail of these cases are over? A. Trefase to answer. MR. PIKE: Form, Q. Isn't it true that Jeffrey Epstein believes that he is entitled to have sex with whomever he wants including 12-, 13-, 14-year-old girls? MR. PIKE: Form, A. [refuse to answer, Q. Do you know whether he continues -- do you imow whether he intends to continue to moiest underag minors within the United States? 27 (Pages 102 to 105) U.S. Legal Support (954) 463-2933

we OIA He wR 10 12 13 14 as 16 17 18 19 20 aL 22 23 24 eeowd}x,HVewWNeH 10 12 13 14 15 16 7 18 19 20 2a 22 wa 24 25 MR. PIKE: Form, A. [refase to answer. Q. Do you know Mike Sanka? A, [refuse to answer. Q. That's somebody else that assisted Jeffrey Epstein in gaining access to underage minor females that were foreigners, correct? A. Trefuse to answer. MR. PIKE: Form. Q. He's atso involved in the modeting ageacy, too, correct? MR, PIKE: Form. A, Lrefase to answer, Q. That's a friend of or former friend of Jean Luc Brunel's? A. I refuse to answer, Q. How many times has Jean Lue Brunel shown up al Jeffrey Epstein's house with anderage minor females? MR. PIKE: Form. A, [refuse to answer. Q. And when that would happen isn't it true that they would have orgies with these underage minor females? MR, PIKE: Form, Q. What was done ~- or let me ask it a different way. Strike that. Where is the scheduling book for the massage appointments for Jeffrey Epstein? MR. PIKE: Form. A. [refuse to answer. Q. Is that something else that was removed from the home prior to the search warrant being executed? | I | | | | | A, refuse to answer. MR, PIKE: Form. i Q. Do you know how it is that -- well, did | Jeffrey Epstein ever tell you that because of the | people he knew he would not be going to prison for the | crimes that he committed? i A. Trefuse to answer. MR. PIKE: Form. Q. And is it your understanding that Ken Starr had played a major role in devising the non-prosecutio: agreemeut or having the government agree not to prosecute Jeffrey Epstein for his crimes against minors? A. I refuse to answer. MR. PIKE: Form, Q. Is it also your understanding that Bill Clinton played somewhat of a role in helping Jeffrey Ice ag pS te woot anue ene 24 108 Epstein out of the trouble that he would have been in related to his sexeat interactions with minor females? A. Lrefuse to answer. MR. PIKE: Form, Q. Did Jeffrey Epstein tell you that you need fo cooperate if you want the protection that me and my connections can give you for this activity? MR. PIKE: Form. A. Lrefuse to answer, Q. You admit that you called LM on the telephone for her to come to Jeffrey Epstein's house to be molested by Jeffrey Epstein when she was an underage: femaie? A. Lrefuse to answer. M&. PIKE: Form. Asked and answered twice. Q. Do you agree that you called EW ow the telephone for the purposes of her coming to Jeffrey Epstein's house for him to sexually molest her? MR. PIKE: Same objection. A. [refuse to answer. Q. And do you agree that you called Jane Doe and told her to come to your house to work, meaning for Jeffrey Epstein to sexually molest her? MR. PIKE: Asked and answered. Q. The first trial that is set in these cases is in July of this year. Do you intend to be in the local area? MR. ROSS: You can answer. A. Yes. Q. Okay. And what address will yeu be at? MR. ROSS: You can answer. A. 1040 South Shore Drive. Q. That's Miami? A. Miami Beach, Florida. Q. And the ZIP is? A, 33141. Q. And I presume that if [ needed to find you or locate you or anything else I could go through your attorney? A. Yes, Q. Okay. Who do you live at that address with? MR. ROSS: You can answer. A. With my husband and my mom-in-law and his sister as well. Q, And your husband's name is Duncan? A. Duncan Ross. Q. And your mother-in-law’s name? A. Monica Ross. Q. And who else lives at the house with you, I'm 28 (Pages 106 to 109) U.S. Legal Support (954) 463-2933

1 2 3. 4 5 6 T, 8 9 19 25 110 sorry? A. His sister. Q. And her name is? A. Stella Erin Ross. Q. And have you told Monica or Stella your involvement with Jeffrey Epstein? A. Lrefuase to answer. Q. Have you told your parents? A. [refuse to answer. Q. Are your parents in the country now? MR. ROSS: You can answer. A. No. Q. Do they have plans to come back? MR. ROSS: You can answer. A. They may visit, I'm not sure. Q. But on 2 permanent basis they're in Poland? A. Yes. Q. Okay. What's the address where they are in Poland? A. Kuznicy Kollatajowskia 33, Warsaw, Poland. Q. She's great, I’m sure she got that. A. Weuld you like me to spell it out? K-U-Z-I-N-C-Y, second word, K-O-L-L-A-T-A-J-O-W-S-K-LA, Warsaw, Poland 02495. MR. EDWARDS: One way fo never find a witn lil | | | | / | ; i i is just move to Poland. There's no way. | MR. ROSS: Couldn't get anyone to type the i subpoena. * { MR. EDWARDS: Right, exactly. Alf right, [ i don't have any other questions for you. Thank you. | ‘THE WITNESS: Thank you. | CROSS-EXAMINATION \ BY MR. MERMELSTEIN: | Q. Okay. Mrs. Ross, I have some questions for | you. Your husband, Duncan Ross, what does he do for a living? A. He'sa Ph.D. student, Q. And what is he a Ph.D. in? A, He works on bone marrow transplant immunology. Q. Sois he a medical doctor? A. He's scientist, He's working on his Ph.D. degree. Q. And which schoot is he working on his Ph.D. at? A. University of Miami. Q. And how long has he been doing that? A. I cannot recall when he started but we were already married. Maybe one or two years into my marriage. 1 do not recall the exact time. | | | | { ] | 1 | | | | t Q. And I believe you testified that you met him COI nUeune DREHER Ee PE Re PSWOYTAHERWNHERO 22 24 25 ni] in Europe, correct? A. Correct. Q. And did he have a different employment or profession then? A. Yes. Q, What was he doing then? A, Well, at that time he was serving in the entertainment business. He was DJing and -- yeah. ‘When I met hima he came to Europe for a DJ event, DJing} event, Q. And where was that in Europe? A. He went to Spain and then [ was in Monaco at the time and he knew the people that | was there with and we were introduced, That's where we miet. Q. And did he have connections to modeling in the United States? A. Yes. Q. And how did he have those connections? A. I'm ~ you know, F'm not sure. 1 don't know at this time, but he knew agencies here and he was doing, I believe, some photographic work as well himself. Q. Se he was a DJ and a professional photograph — photographer? A. Yes. You may say so, yes. Q. And 2 scientist as well? A. Yes. Q. Did he de work for particular modeling agencies in the United States? A. [mean, do you +I don't understand your question. Do you mean like -Q. Well, did he perform work or services for particular modeling agencies in the United States? ‘A. Well, I believe he would hire models from. modeling agencies, yes. Q. He would hire models? A, Yes, for -- you know, that's how -- how it works. You hire a modet from a modeling agency fora particular job, a client that you may have. Q. So as a photographer he would hire models for] a particular modeling agency? MR. PIKE: Form. A. Yes. Q. And do you know which modeling agencies he typically worked with? A, Well, I presume Elite Models because, you know, he had connection and he invited me. I think just various Miami Beach - you know, Miami, South Beach modeling agencies. Q. Did he work for MC Squared? 29 (Pages 110 to 113) U.S. Legal Support {954) 463-2933

COIR HRWNE 10 ai 12 13 14 is 16 Weta eYOH ie a 12 13 14 15 16 17 18 1g 20 21 22 23 a4 14] 116 A, [refuse to answer, | 2 MR. PIKE: Form. Q. In 2004 and 2005 you were employed by Jeffrey | 2 A. 1 refuse to answer. Epstein, correct? 1 3 Q. And as young underage girls whe were MR. PIKE: Form, | 4 impressed, intimidated, and in awe of his wealth they A. refuse to answer. ' 5 would be unlikely to -- to complain fo authorities that Q. And as an employee of Jeffrey Epstein you were 6 he was engaging in sexual activity with them? under his instruction and supervision, correct? [oT A. [refuse to answer. MR. PIKE: Form. i 8 MR. PIKE: Form. A. [refuse to answer. i 9 Q. Okay. Did Jeffrey Epstein instruct you to MR. PIKE: Let's go off the record for a ; 10 call girls on the telephone to schedule appointments second. | 12 forthe to come to his Palm Beach house for massages| MR. MERMELSTEIN: Sure, | 12 which were, in faet, to be sexual activity? VIDEOGRAPHER: Off the record at 12:12pm. | 13 MR. PIKE: Form. (Discussion off the record.) ' 14 A. [refuse to answer. MR. MERMELSTEIN: Fil be briefon the general | 15 Q. Prior to May 2005 did you call Jane Doe 4 to questions, ; 16 schedule appointments for her to come to the Epstein VIDEOGRAPHER: On therecord, 12:14pm, | 17-—sthowse to engage in ~ to give Jeffrey Epstein a massage BY MR. MERMELSTEIN: | 18 which would, in fact, be sexual activity with Jeffrey Q. And as an employee of Jeffrey Epstein were you} 19 Epstein? also subject to the — to the instructions and } 20 MR. PIKE: Form. supervision of Ghislaine Maxwell? {an A. Lrefuse to answer. MR. PIKE: Form. | 22 Q. Okay. Prior te May 2005 while you were at the A. [refuse to answer. \ am. Epstein house in Palm Beach did you receive ealis from| Q, And as an employee of Jeffrey Epstein did you \ a4 Jane Doe 4 regarding the scheduling of an appointment} |_28__forlerto come tothe Epstein house to give Jeffrey _ | 11? primary assistant Sarah Kellen? i 1 Epstein a massage? MR. PIKE: Form. ; 2 MR. PIKE: Form, A. Lrefiuse to answer, {| 3 A. I refuse to answer. Q. Okay. Did Jeffrey Epstein tell you that — i 4 Q, When Jane Doc 7 ~ let me strike that. that he recruited from western Palm Beach County fo 5 Do you kuow Jane Doe 7? underage girls to come to his Palm Beach mansion for | 6 A. Irefuse to answer, sexual activity? | 4 Q. When Jane Doe 7 was a minor female did you MR PIKE: Form. | 8 call Jane Boe 7 to schedule appointments for her to A. f refuse to answer. 2 come to the Epstein house in Paim Beach to give Epstein Q. And did Jeffrey Epstein have a computer | 10 a massage? database at his Paim Beach mansion where he listed ik MR. PIKE: Form. underage high school girls in Paim Beach County and =| 12 A. [refuse to answer. their contact information so that he could have these i 13 Q. When Jane Doe 7 was a minor female did you underage minors come to his house for sexual activity? ! 14 receive calis from Jane Doe 7 while you were at the MR. PIKE: Form. | 15 Epstein house for her to come to the house by A. [refuse to answer, | 16 appointment and give Jeffrey Epstein a massage? Q. And did Jeffrey Epstein tell you that the [ou MR. PIKE: Form. reasom he brought in underage minors from western Paim, 18 A. [refuse to answer. Beach Couaty is because he anticipated they would be i 19 Q. The computer database that Jeffrey Epstein impressed, in awe, and intimidated by his wealth? 20 maintained girls from western Patm Beach County who MR, PIKE: Form, | 21 would come to the house in Palm Beach to give Epstein A. Erefuse to answer, | 22 massage, did that computer database include the name Q. And as young girls who were impressed and in | 23 and contact information for Jane Doe 2? awe and intimidated of his wealth they would do whathe| 24 MR. PIKE: Form. asked them to do? A. Lrefuse to answer. 30 (Pages 114 to 117) U.S. Legal Support (954) 463-2933

COI Te wnh 10 12 13 14 1S 16 3 18 19 20 21 22 23 24 25 CeIHORwWNe 10 42 13 14 15 16 17 18 15 20 22 22 23 24 25 118 Q. Do you know who Jane Doe 2 is? A. Irefuse to answer. Q. Do you know who Jane Doe 5 is? A. refuse fo answer. Q. Did the computer database that Epstein maintained on his computers in his home have the name and contact information for Jane Doe 5 so that Epstein | could contact her for — for massages in his Paim Beach} home? | MR. PIKE: Form. A. [refuse to answer. Q. Deo you know the name Jane Doe 6? A, F refuse to answer. Q, Did the computer database that Epstein mai ned in his home of underage girls who he would have come over for massages and sexual activity dtd that computer database include the name and contact information for Jane Doe 6? A. Trefuse to answer. Q. Do you know the name Jane Doe 3? | A. I refuse to answer. { Q. Did the computer database that Jeffrey Epstein | maintained in his home include the name and contact | information of Jane Doe 3 so that he could contact Jane Doe 3 to come massage which would become sexual activity? A, Trefuse to answer. Q. Did the computer database that Jeffrey Epstein maintained in his home include the name Jane Doe 4? MR. PIKE: Form. A. I refuse to answer. Q. Do you know Jane Doe 4? A. Lrefuse to answer. Q. Did the — did Jeffrey Epstein tell you that he maintained the contact information for Jane Doe 4 in his computer database in his home se that he could contact her to come to his Palm Beach mansion for massages? MR. PIKE: Form. A. [refuse to answer. Q. Did you know for a fact that the computer database included the name Jane Doe 4 so that Jeffrey Epstein could contact her and she would come to the Palm Beach mansion te give Jeffrey Epstein a massage? | MR. PIKE: Form, A. Lrefisse to answer, Q. Did you know that the computer database that Jeffrey Epstein maintained his home contained the nam and contact information of Jane Doe 7 A. refuse -- sorry. | | | t { | | i | | 4 | | | i : i i OC OYIHRH AWN HE 120 Q. I'm sorry -- so he would contact Jane Doe 7 and have her come to his house to give him a massage? A. Lrefuse to answer. Q. Are you aware that the computer database that Jeffrey Epstein maintained in his home contained the name Jane Doe 8 so that he could contact Jane Doe 8 and] have him come to the house in Palm Beach for purposes of giving hima a massage? MR. PIKE: Form. A. [refuse to answer. Q. You removed three computers from the Palm Beach house with another gentleman prior to the search warrant being issued by the Palm Beach police; isn't that correct? A. Freflase to answer, MR, PEKE: Form. Asked and answered. Q. And Jeffrey Epstein instructed you fo remove those computers; is that correct? MR. PIKE: Form, asked and answered. A. I refuse to answer, Q. And Jeffrey Epstein told you that the reason he was instructing you to remove the computers was to hide his sexual activities with underage minors from the authorities? 121 A. [refuse to answer, Q. As an employee of Jeffrey Epstein did you know Janusz Banaziak? A. [refuse to answer. MR. PIKE: Form. Q. Was Janusz Banaziak also auemployee of Jeffrey Epstein? MR. PIKE: Form. A. [refuse to answer. Q. When Janusz Banaziak testified that you and another gentleman removed the three compaters from Jeffrey Epstein's home he was telling the truth, correct? A. Trefiuse to answer. MR, PIKE: Form. Q. Did you observe Jeffrey Epstein persuading, inducing, or enticing underage girls to engage in sexual activities with him? A. [refuse to answer. Q. Did you~ strike that. Did you observe Jeffrey Epstein persuading, inducing, or enticing girls who came to his house for the purpose of giving him a massage fo engage in sexual activity with him? MR. PIKE: Form, 31 (Pages 118 to 121) U.S. Legal Support (954) 463-2933

122 | 124 i i A, [refuse to answer. bok A. [refuse to answer 2 Q. Did Jeffrey Epstein tell you that he induced, | 2 Q. Did Jeffrey Epstein admit to you on aumerous 3 persuaded, or enticed underage girls to engage in | 3 occasions when Jane Doe 4 was an underage minor that he 4 sexual activities with him when they came to his Palm 4 rabbed Jane Doe 4's vagina? 5 Beack mansion to give him 9 massage? | 5 A. [refuse to answer. 6 MR, PIKE: Form. ; ss MR. PIKE: Fertz. 7 A. Trefuse to answer. i 7 Q. Did Jeffrey Epstein admit to you that on 8 Q. Would you instruct ~ when you spoke to | 8 occasions prior to Jane Doe 4 turning the age of 18 you sp. | Bs 2 underage girls to schedule appointments for massage in| 9 that he performed oral sex on Jane Doe 4? 10 Epstein's home would you instract these girls to lie 16 MR. PIKE: Form. a1 about their ages and say they were 18 years old when i A. Lrefuse to answer. 12 —_-youknew that they were younger than 187 12 Q. Did Jeffrey Epstein admit to you that on 13 A, Lrefuse to answer. 13 numerons oceasions prior to Jane Doe 4 reaching the age a4 Q. Did Jeffrey Epstein instract you as to what to 14 of 18 he would place a vibrator oa Jane Dee 4's 24 numerous occasions when Jane Doe 4 was an underage 25 minor he touched and groped her buttocks? 24 occasions to contact Haley Robson for the purpose of 25 scheduling underage girts for appointments to come to | | | | as say to the girls who you contacted by telephone to make = 15 genitals? 16 appointmnents to schedule massages in Epstein’s home? i 16 MR. PIKE: Form. 17 A. Lrefisse to answer. | a7 A, [refuse to answer. 18 MR. PIKE: Form. | 18 Q. Did Jeffrey Epstein admit to you that prior to 19 Q. And would Jeffrey Epstein tell you to have the | 19 Jane Doe 4 becoming 18 years of age he would masturbate 20 girls who you contacted by the telephone to make | 20 inher presence? 21 appointments to come to the mansion to give Jeffrey | 21 A. [refuse to answer. 22 Epstein massages, that they should -- that these girls | 22 MR. PIKE: Form to the last question. 23. should lie about their ages to Jeffrey Epstein? | as MR, MERMELSTEIN: Hum? 24 MR, PIKE: Form, | 2g MR. PIKE: Form to the last question. 2 Ss A. Lrefuse to answer. | 25 Q., Did Jeffrey Epstein admit to you that prior te 123} 125 L Q. Prior to May 2005 are you aware that Jeffrey | yy Jane Doe 7 reaching the age of 18 years old he would 2 Epstein had numerous appointments with Jane Doe 4 for} 2 touch her breasts? 3 her to come to the mansion to come to give him a ; 3 MR. PIKE; Form. 4 massage? i 4 A. refuse to answer. 5 A. Lrefise to answer. } 5 Q. Did Jeffrey Epstein admit to you that prior to 6 MR, PIKE: Form. | 6 Jane Doe 7 reaching the age of 18 he would grope her — 7 Q. Prior to May 2005 are you aware that Jane Doc | 7 — grope Jane Doe 7's buttocks? 8 4 would come to the mansion fo give Jeffrey Epsteina | 8 MR. PIKE: Form. 9 massage on a frequent and regular basis? | 9 A. [refuse to answer. io A, Erefuse to answer. ' 10 Q. And did Jeffrey Epstein admit te you that 42 MR. PIKE: Form. | LL prior to Jane Doe 7 reaching the age of 18 he would rab 32 Q. Are you aware that prior to May 2005 Jeffrey | 12 Jane Doe 7's vagina? 13 Epstein engaged with - engaged in sexual activities = | 1 A, Lrefiuse to answer. 14 with Jane Doe 4 at the Palm Beach mansion 50 to a 14 MR. PIKE: Form, 15 hundred times? jus Q. Do you know who Haley Robson is? 16 A. [refuse to answer. ; 16 A. Lrefuse to answer. 17 MR. PIKE: Form. { 37 Q. Did Jeffrey Epstein instruct you to call Haley 18 Q. Did Jeffrey Epstein admit to you that on | 18 Robson on numerous occasions to recruit underage girls 19 _aamerous oceasions he ~ when Jane Doe 4 was an 1 19 te come to the Palm Beach Mansion to give Jeffrey 20 underage minor he touched her breasts? | 20 Epstein a massage? 21 MR, PIKE: Form. | 21 MR. PIKE: Form, 22 A, refuse to answer. 1 22 A. Lrefuse to answer. 23 Q. Did Jeffrey Epstein admit to you that on | 23 Q. Did Jeffrey Epstein instruct you on numerous ' | | i 32 (Pages 122 to 125) U.S. Legal Support (954) 463-2933

1 2 3 4 5 € 4 8 9 10 1 12 13 14 is 16 Ww 18 19 20 21 ae 23 a 12 13 14 1s 16 17 18 19 20 au 22 23 24 25 126| the Palm Beach mansion and give Jeffrey Epstein a massage? A. [refuse to answer. MR. PIKE: Form. Q, Did Jeffrey Epstein advise you that Hatey Robson was his contact in westera Palm Beach County high schools for the purpose of recruiting underage giris to come to the Paim Beach mansion where he woul then engage in sexual activity with them? | A. Frefirse to answer, | i ' | | i i | | | d MR, PIKE: Form, Q. Did Sarah Kellen instruct you on how to contact underage girls for the purpose of bringing them | to the Palm Beach mansion for massages and what to say to these young girls? MR. PIKE: Form. A. Erefuse to answer, Q. Did Sarah Kellen train you im how to contact girls and recruit them to come to the Palm Beach mansion and — and provide Jeffrey Epstein with massages? A. Lrefuse to answer. ! MR. PIKE: Form, | Q. Was one of your primary duties scheduling | i day, for Jeffrey 12 | | | | | | | I | { ay Epstein to have underage girls come to the mansion to give him a massage? MR. PIKE: Asked and answered, form. A. [refuse to answer, MR. MERMELSTEIN: Okay. That's all i have. MR. PIKE: C have no questions. MR. EDWARDS: [only have a couple. TH go ahead and mark this as Number 4, (Whereupon, Plaintiff's Exhibit 4 was marked for identification.) REDIRECT EXAMINATION BY MR, EDWARDS: Q. This photograph appears to be Jeffrey Epstein, yourself, and Maer Roshan in this photograph taken fro: an interuet newspaper. Can you tell me where that picture was taken? A, Trefuse to answer, MR. PIKE: May I see that, counsel? Q. Was this related — this event, was it related to MC Squared? _ A. Lrefuse to answer. Q, Allright What is —{ know that you told as that you're not employed now because you're in school. ‘What was your last empioyment? A. Lwas working at the focal CPA firm. pin Lana ia Pessoa sed eel thea bt hdc new ha Anda Godin aaa cia aciahaecon Aantal OOIHRHeWNHH Q. Excuse me? A. CPA firm. Q. Okay. What was the name of that CPA firm?| A. William Owens, CPA, P.A. Q. William Owens, And is that in Miami? A. Correct. Q, Where did you work prior to that? A. Tworked for maybe less than a month at a clothing store. Q. What clothing store? A. Club Monaco. Q. Where's that? A. South Beach. Q. Where in South Beach? A, It's on Collins Avenue and I believe maybe 6th and 8th, I'm not sure. Q. Okay. Why'd you leave there? A. The clothing store? Q. Correct, A. Because I got the accounting job. Q. And that's what you want to be you said? A. Yes, um-hum. Q. Okay. And I suppose that you left the accounting firm because you went to school to finish] your degree? A. Well, Iwas working part-time and going to school part-time and it just became too challenging. The accounting program is very demanding, so I wanted| 10 dedicate myself to study. Q. How long were you at this accounting firm Williams Owens ~ William Owens? A. Maybe two and a half years about maybe. Something like that. Q. Albright. So we're in ~ when was it that you left there? A. May of 2009. Q. Okay. May '09, so that brings us back to tafe 2006 or something when you started there? A. Yes. That would be about right, yes, Q. And then it was sometime earlier than that in 2006 when you were at the clothing store? A. Yes. Q. And you were there for about a month? A. About, yes. Q. Give or take— A. Yes. Q. —a week or so? ‘Where -- where did you work prior to the clothing store Ciub Monaco? A, Twas modeling. 33 (Pages 126 to 129) U.S. Legal Support (954) 463-2933

COrnuUe YOR ai 12 i3 14 as 16 17 18 19 20 24 22 wavaneune 10 aL 12 13 14 15 16 17 18 19 26 au 22 23 24 25 Q. And where were you modeling? A. In Miami. New York. Q. For what agency? A, In Miami | was with Elite Models. | was with Michele Pommier -Q. Who's that? A. Michele Pommier Agency. Q. Okay. How do you spell the last name? A. P-O-M-M-I-B-R. And then «Q. Okay. That was in Miami? A Yes. Q. And then what agency did you werk through in New York? A. iD Modeis. Q. Excuse me? A. D Models. Q. 1D? A. Yes. Q. Just in the letter I ~ A. Yes. Q. - letter D? And who was the person that got you hooked up at ED Models? A. My husband had that contact. A. Em trying to think, Ido not recall exact timeframe. Q. Allright. Well, if the clothing store was sometime Inte 2006 are we talking about earlier in the year 2006 when you were working with Elite in Miami and 0D Models in New York? MR. ROSS: I'm going to ask you to invoke. THE WITNESS. fm sorry? MR. ROSS: You should invoke with regard to this timeframe you're talking about now. MR, EDWARDS: Okay. A. Trefuse to answer. Q. Okay. Can you teil me about any job that you had medeling or otherwise prior to working at 1D Modeis or with Elite? A. Recall «« just name any — Q. Any -- what was your — what employment did you have just prior to working with Elite Models and ID Models? A, Lwas working as a model in Europe. 1 graduated from high schoo! in 2002 and I dedicated that ‘year to modeling and so I was modeling. Idid not have employment. Q. Allright. So just so I understand you were modeling im Kurope, you came over here in 2002. O2YKHH BH wWNHHE we aInnewnnm 132 A, Um-hum. Q. There's a period of time from 2002 through 2086 where -- you know, 2006 you start with [D Model and again with Elite. {know when you came over here in 2002 you were with Elite also, right? A, Tm sorry, you're confusing me with the timeframe, Q. I'm confusing myself, how about that. Let's start over. 2002 you come over to the United States, you're working at Elite? A. Yes, I've been invited by Elite. Q. Okay. And then if} understand you correctly over time you continue to work with or through Elite? A. Weil, I've been, you know, changing agencies throughout the period. Q. Okay. What are some of the other modeling agencies you have worked for or with? A. Trefuse to answer. Q. Okay. The only other names of modeling agencies that you can answer are ID Models and Elites that correct? THE WITNESS: Should 1? MR. ROSS: Well, she’s already answered also Michele Pommier. 133 MR. EDWARDS; But I thought that was somebody through Elite, like they're -MR. ROSS: No, no, no, Michele Pommier is a ~~ MR. EDWARDS: Different, okay. Q. Allright, Is there anybody else that you're able to ~ to tell me where you worked? MR. ROSS: Invoke as to any further information. THE WITNESS: I'm sorry? MR, ROSS: Invoke your privilege. A. Lrefuse to answer any questions. MR. EDWARDS: All right. That's all E got. MR, MERMELSTEIN: Can 1 just follow up a couple? RECROSS-EXAMINATION BY MR. MERMELSTEIN: Q. In what has been marked as Exhibit 2C is a phone message from you to Adri ~ from you to Jeffrey Epstein dated September 10th, 2005 at 1:15 p.m. And the message that you left was “Lauren confirmed 4 p.m.”, is that correct? A. [refuse to answer. Q, Is the Lauren referred to in this message Lauren Murphy? MR. PIKE: Form. 34 (Pages 130 to 133) U.S. Legal Support (954) 463-2933

134} 136 A. Trefuse to answer. | and no word index. ‘4. 1 2 Q. And did you schedule Lauren i 2 MR. MERMELSTEIN: I'll take a copy with a 3 MR. PIKE: Form. be 3 mini. 4 Q. — Lauren Murphy to come tothe Palm Beach | 4 (The deposition was concluded at 12:42 p.m.) 5 mansion as an underage female to give Jeffrey Epstein | 5 (Reading and signing of the deposition was 6 massages? | 6 waived by the witness and all parties.) 7 MR. PIKE: Form. 7 8 A. trefuse answer. j 8 9 Q. Also what has been marked as Exhibit2Fisa | = 9 10 phone message from you to Jeffrey Epstein dated 10 11 September Lith, 2005 at 9:15 a.m, And the message was] 11 12 that you got a car for a particular person. De you | 12 13 recall that? ; 13 14 MR. PIKE: Form. } 14 15 A. Trefuse to answer, 135 16 Q. Is the car that you obtained on i 16 a7: September 11th, 26005 for Jane Doe 47 } 17 18 MR, PIKE: Form. | 18 19 A, Trefuse to answer. | 19 20 Q, And Jane Doe 4 is.a girl who had been coming | 20 21 to the Palm Beach mansion to give Jeffrey Epstein a | 21 22 massage and engage in sexuat activities with him fora | 22 23 substantial period of times is that correct? 1 23 24 A. Lrefuse to answer. | 24 25 Q. And also what has been marked as Exhibit 2H - | 25 ee 135! 1 actually — 1 CERTIFICATE OF OATH 2 MR_ EDWARDS: fs that G? | 2 STATE OF FLORIDA. 3 MR. MERMELSTEIN: Are they similar? | : COUNTY OF BROWARD 4 MR. EDWARDS: Yeah, I guess they blocked out | ; i Sanat MCintiog, Repisered Probiselinal 2 names on one of them and they didn’t on the other. | Reporter, Florida Professional Reporter, Certified 6 MR. MERMELSTEIN: Right. Okay. 1 7 LiveNote Reporter, Notary Public, State of Florida, 7 Q. And what bas been marked as Exhibit2G isa | 8 certify that ADRIANA ROSS personally appeared before mt 8 message from you to Jeffrey Epstein dated i 9 on March 15, 2010 and was duly swom. 9 September 3rd, 2005 at $:50 p.m. And the message you! 2 Signed this 21st day of March, 2010. 10 left is, quete, "I left message for Ashley to confirm ' ov 11 for 11:00 a.m, and Vanessa for 4:30 p.m." 3 =e 32 Did you, in fact, leave that message? Gant A, Lehn 4 > 413 MR. PIKE; Fon. | a4 ‘vanet L.. McKinney 14 A. Trefuse fo answer. ' Registered Professional Reporter 25 Q, And this message that you left confirmedan | 15 Se enit hath Roe 16 appointment for Jane Doe 4 for 4:30 p.m., correct? | 16 Notary Public, State of Florida uv ‘AL Tresess fo mimics, | Commission No.: DDSS2183 18 MR. MERMELSTEIN: Alt right. That's all 1 | W7 Expires: June 2, 2010 1g have. 1 is 20 MR. ROSS: Waive. | 19 21 MR, MERMELSTEIN: Allright. (20) 22 VIDEOGRAPHER: Off the record, 12:42pm. | : : 23 ‘THE REPORTER; Are you ordering? | oa 24 MR. EDWARDS: Yes. | 24 25 MR. PIKE: I want a copy, a mini, no ASCii, } 28 i. 35 (Pages 134 to 137) U.S. Legal Support (954) 463-2933

i7 138 | CERTIFICATE OF REPORTER | STATE OF FLORIDA COUNTY OF BROWARD I, Janet McKinney, Registered Professional Reporter, Florida Professional Reporter, Certified | LiveNote Reporter, certify that I was authorized to and | did stenographically report the deposition of ADRIANA. ROSS, pages | through 138; that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes. I further certify that I not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties’ attorneys or counsel connected with the action, nor am 1 financially interested in the action. Dated this 21st day of March, 2010, Gast Ae Janet L. McKinney, RPR, EER Registered Professional Reporter Florida Professional Reporter Certified LiveNote Reporter I I | | I { ! | i | | fe a U.S. Legal Support (954) 463-2933 36 (Page 138)

35:8 acceptable 6:12,14,15 6:16 access 23:13 28:14 37:23 90:4 98:10 100:18 106:6 accounting 11:23,24 128:20,24 129:3,5 accurate 99:16 acquainta... 35:9 act 95:11 action 138:15,16 actions 59:17 activities 84:6 120:23 121:18 122:4 123:13 134322 activity 56:11 103:19 108;7 115:7 115;14 116:6,12,18 118:16 Ligsi 121:24 126:9 actresses 34:13 acts 26:6,12,16 82:17,19 adam 80:16 addicted 85:17 addiction 30:9 61:18 addition 32:4 34:11 57:8 additional 56:6 additionally 39:9 address 13:9,15 14:19,23 15:21,25 16:3,6,8 19:9,18 109:6,17 110:18 addressed 5:16 admit 108:10 123:18,23 124:2,7,12 124:18,25 125:5,10 adri 133:18 adriana B21 3:332 4:13 5:4 7:2,8,10 62:20 63:18 65:20 67:24 86:9 137:8 13833 adrianas 72:23 adult 25:10 35:7 adults 25:13 advise 13:11 126:5 advised 69:9 70:6 affiliated 81:6 affiliation 100:17 affirm 5:7 affirmed 733 africa 34:6 africanam... 9734,7 afternoon 68:8 age 22:8 24:12 24:13 25:6 43:7 45:4 51:12 90:4 124:8,13,19 125:1,6,11 agencies 9:1,14 29:16 112:20 113:4,8,10 113:19,24 132:15,18 132:21 agency $:12,14,19 9:6,7,10,12 10:18 18:25 19:5 29:17 100:17 106:10 113:13,16 130:3,7,12 agents 75:13 ages 47:11 122:11 122:23 agree 94:12 95:6 107:19 108:16,21 agreed 6:2 agreement 21:1,5 32:12 102:3 107:19 ah 67:14,20 69:1,4,11 69:13,15,16 69:17 70:1 ahead 14:11 33:10 127:8 ahha 15:14 airplane 40:25 41:4 76:3 79:11 79:13 81:24 82:4,7,9,12 airplanes 75:1,9 airport 79:5 al 1:8 4:14 alan 2:24 §:3 37:6,8 81:24 alfredo 9239 aline U.S. Legal Support (954) 463-2933 1393 77:19,22 alleged 34:10 allow 64:2 allowed 98:4 amendment 6:1,6,12 14:6 21:15 ansel 2:20 andrea 81:22 andres 76:16 andrew 37:1,3 84:17 87:24 andrews 2:4 angeles 34:5 angry 41:16 93:17 93:24 103:18 answer 6:3,4,11,11 13:13,16 14:3,21 15:9,11 16:12,18,19 16:22 17:4 17:6 18:7 18:10,13,16 18:18,21,24 19:2,6,10 19:14,16,19 19:23,25 20:4,7,10 20:13,15,20 20:25 21:3 21:9,14,18 21:22,25 22:5,11,13

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155 31:8,13,17 61:19 67:7 123:21 100:14 110:3 32:24 33:23] 72:3 78:11 130:4,14,16 | month 117:22 34:17 35:17 | 81:18 82:17 | 130:23,25 8:10 53:15 118:6,12,17 36:20 37:4 83:12 85:17 | 1341:6,14,18 | 53:16 128:8] 118:20,23 37:10, 23 89:16 131:19 129:18 119:4,17,23 39:6, 10,18 102:11 132:3,21 morning 120:6 128:3 40:19 41:3 105:25 molest 5:3 68:7 130:8 41:8,13,18 107221 32:25 39:11 86:17 131:16 42:13,25 115:14,18 43:25 45:16 | motherinlaws | named 43:24 44:4 420:23 63:2 65:25 | 109:23 18:17 32:10 44:14,24 mistake 66:2 68:7 move 33:6 38:22 45:10,17 7:15,18 96:17 14:15 16:14 63:6 92:8 46320,25 model 105:24 11i:1 names 48:6,14 9;1,21 10:19] 108:18,23 moved 42:12 67:7 49217, 22 77:9 $4:22 | molestation 16:3,7,16 88:14 $0:1,7,41 113313 24:7,14 91:7 | moving 132:20 O:17 51:5 131:20 91:20 98:8 | 18:20 63:12 135:5 51:18,22 modeled 102221 mpike naomi 52:6,16,22 28:21 molested 2:12 77:5 54:9,9 modeling 43:7,18 45:5 | mucinska near 59:22 61:3 | g:12,14,20 71:11 7:10 8:4 60:12 61:9 63:1,6 8:22 10:16 108:12 murphy necessarily 64:24 65:24 | 40:22 11:3 | molester 133224 13424 | 72:22 66:12,21 11:3.17:10 | 25:2 58:7,19 need 68:7,13 17:14,17,22 | 98:13 46:6 108:5 69:4 70:17 17:24 18:25 | molesting nadia needed 71:20 74:15 | 19:4 28:18 | 34:11 68:13 | 49:17 20:21 | 10:4 109:13 76:19 77:2 26:25 29:4 Wek 72:3 22:19 26:25 | neighborhood 7831, 24 29:16 40:15 | moment 49:16, 20 83:25 82:8,6 88:4) 77:8 85:4 | 13:25 69:10, 11 nervous aoe 100:17 mominlaw 78:15 79:2 | 55:24 decreas | tacts 209319 92:9,13 | never 9074 100101 coos monaco 99:7,7,10 | 89:12,19,23 c ; 413:3/8,10 | 112:12 99:21 97:6 110:25 teers 16 113:13,16 128:11 naked new 105:5, 10 Hise tered 129:24 31:8 47:16 | 13:6,7,15 Lee i222e2 monday 69:10 14:20 16:11 1S Sarees 130:1 1:17 4:9 name 16:13,16 lias | b2it24-22 | money $:3.7:7,14 18:20, 22 123:20,25 132:17,20 91:9 52:9 7:15 8:4 23:13 34:4 soa! sie! 56:6 58:11 9:4,11 44:19,19 minors Tne a eat. 59:21 94:9 | 16:20 18:11 | 61:23 62:2 2374,8 27:9 | grn0 oe 95:19 97:20] 18:14 67:6 71:10,10 pare 29:10 | 2g70 30'22 | monica 32:7 82:23 | 78:10 80:5 50619 seid | aes 109:24 110:5| 88:7 102:7 | 80:8 83:12 _ le 34:12 78:5 | monroe 109:21,23 130:2,13 49:4 59:17 113:9,11,15 131:6 U.S. Legal Support (954} 463-2933

156 newspaper 41:12 101:9 101:21 94:21 3:2,12,23 T2715 objection okay opportuni... | pages nice 6:9 19:24 6:17,20 7:22 | 11:4 1:14 138:9 93:19 108:19 8:7 9:1,14 opposite paid night observations 9:19,25 65:2 20:17 22:15 86:17 30:7 76:11 10;8,16 option 39:5 56:7 nipples 99:16 12:10,13,19 | 46:7 51:9 57:20 69:22 48:18,23 observe 13:1,14 oral 70:25 71:12 49:5 82:19 121:16 | 14:11,22 69:13 124:9 | palm nodding 121:21 15:1,6,19 order 2:11 34:4 15:12 observed 16:7,10,20 6:2 10:3 44:10,20 nods 19:11 22:7 17:21 29:15 | 47:17 48:5 49:12 62:3 32:9 obsessed ee eae 64:1 faces pets 7 7 = : ordered 26,11, Soe a ootet eee! 62:15 63:17 | 53:17 54:2 115:18 107118 «| 21:24 22:8 69:3 74:6 | ordering 116:11,23 11 22:24 30:3 T7313 86:10 | 435323 117:9,20,21 pric! 30:8 35:18 | 86:24 99:16 | Spaces 118:8,25 nee obtained 101:7,11,21 | gg.36 119:12,19 2:4 31:12 34:3 10936/17 organization | 120:7,11,13 notary 134:16 abOeee i 28:9 aa 4:4 137:7,16 | obtaining ee oot orgies iets 28:9 ‘ 38:19 106:22 note ; 127:5 128:3 ° 126:1,6,8 q2:6 occasions 128:17,23 outline 426:14,19 notes 79:19 92:19 129212 24:5 isac aod 3:17 136:41 | 123:19,24 130:8, 10,25 | ublining paper nowak 124:3,8,13 131:11,13 5:20 18:15 52:19 125:18,24 132:13,17 outside parants nunees, eer 132:20 10s12 16:23 68:18 4:13 5:14,20 | 7:23 57:2 133:4 135:6 | Owens 72:24 73:2 40:6 63:20 | offenders olas 128:4,5 73:5,9,11 98:11 127:8 | 24:3 1:18 4:11 129:6,6 104211 numbers offenses old owned 110:8, 10 4:25 S:2t 8:23 22:4 18:23 parlor numerous oreer 33:22 43:13 | owners 89:24 27:7 39:21 Si:17 43:19 76:10 | 29:17 part 75:2 79:19 | offered 80:5 94:4 3 916 93:2 $2:22 123:2 | 73:17 95:24 99:7 |—__*~____| participate 123:19,24 | offers 22:11 pad 26:15 49:17 124:2,13 51:4 125:1 63:11 72:6 50:6 125:18,23 office once W434 participated a 5:16 67:7 46:15 57:24 | pads 50:10 | Seeentines: 105:15 60:12, 16 participa... oath 82:23 online 62:9 70:11 27:1 3:7 13721 oh 37:14 70:11 92:6 | ei oular object 9:8 86:24 open page 61:7 92:12 U.S, Legal Support {954) 463-2933

157 113:3,8,14 112:13 60:13 31:19, 23 61:10,16,21 LV3316 perform photo 3233,43;179 61:24 62:6 134:12 113:7 3:19 32:21 33:1 62:16, 25 particularly | performed photograph 33:25 34:9 63:3,9,23 89:6 124:9 112:24 34:15,20,24 | 64:3,11,15 parties performing 127:13,14 35:3,10,14 64:21,25 6:4 136:6 91:19 photographer 35:20,24 65:34,9,47 138:13,14 period 112:24 36:4,13,18 63:22 66:5 partner 12:16 16:13 413:15 36:23 37:25 66:14,18 35:1 37:19 20:8 132:2 |photograp... 38:4,8,12 67:2,16,23 73:23 132:16 10:17,19 38:16,20 68:5,9,15 parttime 134323 photographic 39:4,7,13 68:19 69:5 12:4 129:1,2 | permanent 112:21 4033,7,12 69:25 70:4 party 10:16 photographs 40:17,22 70:9,18,24 42:4 pexmanently | 30:23 31:16 41:5,10,14 74:4,7,13 pashcow 12:8 31:21 41:19,24 FL:17, 21,23 77:15 perpetrator | physically ee i0 7336, 20 passports 24:14 84:10 aeesiaae a Ee 34:3 perrylang picture . o ene 44:12,16,22 | 75:21 76:5 pastrana 80:16 127:16 45:1,6,13 76:8,13,15 76:16 87:23 [person pictures 45118 33 16:21 25 pathtojus... | 18:17 24:9 8:20 eer Gaal g Os 2:6 24:12,13 piece 46318 23 7818.19. 218, :8, patrol 45:11,21 26:21 : : : 47:4,8,14 79:20 80:1 30:24 51:13 71:1 | pike 47319, 23 80:4,7,9,14 219, 24,759; pay 77:1 «104:2 2:12 5:1,1 2 ‘ 48:3,7,16 80:23 81:2 20:5 51:12 104:2 6:16 13:17 : : 48:20,25 81:10,15 69:21 92:24 | 130:22 19:22, 24 49:6,10,14 82:1,6,10 : 26,10, 21,6, paying Hotels 20:3, 6,12 49:23 50:4 | 62:14,21 59:4,7 104:6 | personal 20:16,19,24 | 59:9,13,19 83:2,9,13 payroll 3959 60220 21:4,8,13 50:24 51:3 | 83:21 84:2 25:24 personally 21:21 22:1 | 5136,14,19 | 84:8,18,25 pbi A122, 18738 22:6,10,14 | 51:25 52:7 | 95:6,10,15 78:18 persuaded 22:17,21 52:12 53:5 85:18, 20,23 peers 122:3 23:1,5,10 53:13,19,25 | 86:12 87:17 35:7 persuading 23:15, 20,23 :5,11,15 87:20 88:1 penis 121:16,21 24:20, 24 88:5,18,25 69:16,17 ph 25:3,7,11 89:3, 21 people 111:12,13,16 | 25:14,19 90:1,13,16 25:23 35:18 | 111:18 26:2,8,13 90:21 91:1 39:22 42:8 | phone 26:18 27:11 91:8,13,17 67:17 70:15 | 89:16 101:14 | 27:19,24 91:22,25 87:22,24 101:16,18 28:5,11,15 92:18, 22 92:10 133:18 28:19, 22 93:5,11,16 104:16 134:10 ete eae 94:7,20 107313 hones faa fee 60:23 61:5 95:8,14,18 = 31:1,5,9,14 f U.S. Legal Support (954) 463-2933

95:21 96:2 96:5,9,18 96:23 97:18 97:22 98:7 98:14,20 99:6,19,25 100:13,20 01:1 102:18,23 103:7,412,21 103:24 104:4,8,15 104:18,23 105:3,7,12 105:17,21 106:1,9,12 106:19,24 107:5,10,16 107:23 108:4,8,15 108:19,24 113:17 114:4,8,10 114:22 115:2,8,15 1i5:21 116:1,8,13 116:20 117:2,11,17 117:24 118:10 119:5,14,20 120:9,16,19 120:25 121:;5,8,15 221525 122:6,18,24 123:6,11,17 123:21 124:6,10,16 124:22,24 125:3,8,14 125;:21 126:4,11,16 126:23 127:3,6,18 133:25 134:3,7,14 134:18 139:13225: pimping 35:17 pinch 48:18 49:5 pinched 48:23 place 18:22 63:7 95:7 124:14 places 77:22 placing 44:9 plaintiff 1:6 2:2 4:22 33:21 plaintiffs 2:14 33:11 33:16 60:10 62:11 72:12 87:12 127:9 plan 17:21 90:18 plane 79:19,23 84:16 plans 110:13 played 32:24 107:18 107:25 please 4:18 5:6 pled 101:4 plis 3:11 ploy 63:25 plus 51:18 point 26:10 40:9 47:25 53:10 $6:18 58:18 68:17 72:2 73:8 81:7 88:11 poland 9:3 11:6 12:10 16:24 23325 110:16,19 110:20,24 L1l1:1 police 27:3,6 64:6 64:9 69:7 83:16 84:4 84:5,10 120:13 polish 9324,25 politicians 35:7 78:9 pommier 130:5,7,9 132325 133:3 poor 12:13 93:8 possession 30:25 possibili... 11:4 possible 59:21 possibly 28:7 practice 35:17 predators 24:3 pregnant 95:24 96:16 96:21 97:9 97:11,14 7:9,16 19:20 | Presence 124:20 present 2:25 4:18 president 76:16 87:23 presume 109:13 113:21 pretty 61:22 71:5 83:15 preying 104:21 primary 61:12 115:1 126:24 prince 37:1,3 84:16 87:24 prior 6:2 9:15 107:8 116:15,22 120:12 123:1,7,12 124:8,13,18 124:25 125:5,11 128:7 129:23 131:14,18 prison 59:12 107:13° privilege 6:1,6,8,9 13:12 32:5 57:6,7 101:9,10 102:5,9 133:10 probably 83:25 15:17 23:25 problem 14:1 87:9 process 158 §:12 63:12 procured 74315 procures 7732 profession 112:4 professionali 1:23,24 4:2 4:3 35:8 112:23 137:5,6,14 137:15 138:5,6,20 138:20 program 11:25 129:3 promise 64:1 promised 28:24 properties 38:3 property 38:6,10 propose 95:15 prosecute 107:20 prosecuted 21:16 prostituted 78:5 prostitutes 89:7,17 prostitution 89:13,19 protect 24:2 protection 108:6 provide 126:20 providing 97:20 psychology U.S. Legal Support (954) 463-2933

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DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v, Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 14

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, avs VOLUME LOF fi JEFFREY EPSTEIN, Defendant, Related cases: 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-8081 f, 08-8893, 09-80469 09-80591, 09-80656, 09-80802, 09-8 1092 VIDEOTAPED DEPOSITION OF SARAH KELLEN Wednesday, March 24, 2010 10:37 - 6:51 pam, 250 Austratian Avenue South Suite 1500 West Paim Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 Ne OIG Um w& 9 10 1. 12 13 14 15 16 17 18 19 20 22 22 23 [25 Page 3B IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 562008CA028051XXXXMB AB LM, Plaintiff, +¥8- VOLUME I OF IH JEFFREY EPSTERN, Defendant. VIDEOTAPED DEPOSITION OF SARAH KELLEN Wednesday, March 24, 2010 10:37 - 6:51 p.m. 250 Austratian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 YOAOe WN © Page 2 IN THE CIRCUIT COURT OF THE ISTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028058XXXXMB AD EW. Plaintiff, “v3 VOLUME I OF Itt JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF SARAH KELLEN Wednesday, March 24, 2010 10:37 - 6:51 p.m, 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. won Oe Page 4 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.502008CA0373 19XXXXMB AB BB. Plaintiff, ove VOLUME I OF Hil JEFFREY EPSTEIN AND SARAH KELLEN, Defendants, VIDEOTAPED DEPOSITION OF SARAH KELLEN Wednesday, March 24, 2010 10:37 - 6:51 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No. 1484 TR 1 (Pages 1 to 4) (561) 832-7506

Page 5 Page 75 1 APPEARANCES: 1 aS 2 —. Onbehalf of the Plaintifls, B.B.: 2 EX 3 ‘SPENCER T. KUVIN, ESQUIRE 3 LEOPOLD KUVIN 4 ae : Sue PGA Boulevard 5 EXAMINATION DIRECT CROSS REDIRECT é 5 Palm Beach Gardens, Florida 33410 Phone: 361.515.1400 puny (PARAN RELLEN 6 7 On behalf of the Plaintiff, .M,, B.W. and BYMR.KUVIN = 9 Jane Doe: ; a are 9 MATTHEW WEISSING, ESQUIRE 10 EXHIBITS FARMER, JAFFE, WEISSING, EDWARDS a nie 10 FISTOS & LEHRMAN, PL. 12 425 North Andrews Avenue 13 EXHIBIT DESCRIPTION PAGE a Suite 2 ° 14 Fort Lauderdale, Florida 33301 2 | ine sch ee a 13 On behalf of Jane Does 1 through 8: PASSENGER MANIEEST 14 ADAM D. HOROWITZ, ESQUIRE ‘Ke MERMELSTEIN & HOROWITZ, P.A. PLAINTIFF'S EX. 3 HYPERION AIR, INC., 18 48203 Biscayne Boulevard PASSENGER MANIFEST Suite 2218 17 PLAINTIEFSEX.6 PHOTO 63 16 Miami, Florida 33160 PLAINTIFFS EX.7 PHOTO 65 Phone: 305.931.2200 18 PLAINTIFFSEX.8 PHOTO 68 ay E-mait: Ahorowita@sexabuseattomey.com PLAINTIFF'S EX.9 PHOTO 71 18 On behalf af the Plaintiffs, 101, 102 and 103: 19 PLAINTIFFS EX.10 PHOTO 100 7 KATHERINE W. EZELL, ESQUIRE PLAINTIFFS EX. 11 PHOTO 101 a6 eee 20 PLAINTIFF'S EX 12 PHOTO _ 103 25 West Flagler Street PLAINTIFF'S EX. 4 PHONE MESSAGE PADS 24 Suite 800 2a PLAINTIFF'S EX. 5 CELLPHONE RECORDS Miami, Florida 33130 PLAINTIFFS EX. 13 PHOTO 144 22 Phone: 305.358.2800 22 23 (Via telephone) 23 24 24 25 25 Page 6 Page 8} 1 Appearances continued... 1 PROCEEDINGS 2 On behalf of the Plaintiff, Jane Doe Hi; 2 3 (SIDRO MANUEL GARCIA, ESQUIRE === + GARCIA, ELKINS & BOEHRINGER 3 THE VIDEOGRAPHER: We are now on video 4 224 Datura Avenue, Suite 900 4 |. This is Media No. 1 in the videotaped ‘West Palm Beach, Florida 33401 seco Valle Meee Nog Ht tle VesoeD 5 Phone: 561.832.8033 5 deposition of Sarah Kellen in the matter of . cs beautv ores Dolan? 6 Jane Doe versus Jeffrey Epstein, et al. Today mn of the Defendant: ‘ z 8 JACK ALAN GOLDBERGER, ESQUIRE st is Wednesday, March 24th, 2010. It is ATTERBURY, GOLDBERGER & WEISS, P.A, 8 10:36 am. We are here at Prose Court 3 Be cuinian Avenue South 9 Reporting, 250 South Australian Avenue, West ite 3 10 West Palm Beach, Florida 33401-5012 10 Palm Beach, Florida. Phone: 561.659.8300 11 My name is Joe Kozak. I'm the a 12 videographer. The reporter is Cindy 13 ‘On behalf of the Witness: 13 Hopkins from Prose Court Reporting Agency. 14 BRUCE E. REINHART, ESQUIRE 14 i ce LAW OFFICE OF BRUCE E, REINHART Would counsel please introdu 15 One Cleartake Center 45 yourselves, and then the court reporter 250 South Australian Avenue, Suite 1400 16 will swear in the witness. 16 West Palm Beach, Florida 33401 a " Hl Phone: 561.202.6360 17 MR. KUVIN: Good moming. Spencer Kuvin ay is on behalf of one of the Plaintiffs. i 35 19 MR. HOROWITZ: Adam Horowitz on behalf of f 20 ALSO PRESENT: 20 Jane Does 2 through 8. And just for the record 2. Jessica Cadwell, Pease Gah p 2i purposes, the deposition is also being taken in Burman, Critton, Lattier & Coleman, P.A. 4 . 22 Joseph Kozak, Videoarapler 22 the federal cases, I believe, case being Prose Court Reporting Services 23 Jane Doe 2 versus Jeffrey Epstein. 24 MR. WEISSING: Matt Weissing on behalf of 25 three of the Plaintiffs. SSM Ea oT wept 2 (Pages 5 to 8) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 9 1 MR. GARCIA: Sid Garcia for Jane Doe, i privilege. 2 Roman Numeral IL. 2 MR. KUVIN; [tl agree with that 3, MR. GOLDBERGER; Jack Goldberger on behalf| 3 procedure, 4 of Jeffrey Epstein, 4 MR. RHEINHART: Anyone object to that 5 MS. CADWELL: Jessica Cadwell, paralegal, 3 procedure? 6 on behalf of Jeffrey Epstein. 6 MR. GOLDBERGER: Actually | think if, in a MR. RHEINHART: Bruce Rheinhart on behalf 7 fact, this deposition is used in a trial, f 8 of the witness, Sarah Kellen. 8 think you would want ihe lengthier answer as 9 MR. KUVIN; Kathy, your turn. 9 being the answer that is played to the jury. 10 MS. EZELL: Okay, Kathy Bzell and Amy 10 So either you guys can agree that it gets cut Il Ederi on behalf of Plaintiff, Jane Doe 103. il in or she's going to have to -- I can't tell 12 Thereupon, 12 you what to do, but | would suggest that she 13 (SARAH KELLEN) 13 give the lengthier answer each time. 14 Having been first duly sworn or affirmed, was 14 But there's got to be a way that you 15 examined and testified as follows: 15 guys can reach an agreement though, that 16 DIRECT EXAMINATION 16 from a technology perspective, that the 17 BY MR, KUVIN; 17 lengthy answer that she just gave would be 18 Q. Good moming. 18 used during any trial testimony. Can that 19 A. Morning. i9 be done? 20 Q, Could you give us your full name, please. 20 MR. KUVIN: I don't know procedurally 21 A. Sarah Kellen. 21 whether it can be done. 22 Q. Do you have a middle name? 22 MR. GOLDBERGER: | think -23 A. Lynneile. 23 MR. KUVIN: I don't know that, well -- i 24 Q. Would you spell that for us? 24 MR. GOLDBERGER: And again, it's not my, [/ P25 A, Leyon-n-e-l-be. 25 it's not my deal. I'm just telling you how |, Page 10 Q. What's your current address? MR. RHEINHART: I'm going to instruct the witness not to answer that question on the basis of her Fifth and 14th Amendment privileges against self-incrimination. MR. KUVIN: Okay. We had spoken before with respect to there are likely going to be answers similar to that throughout this deposition. I have agreed to a procedure that we can do a shortened answer. However you want to handle that, I leave it up to you. But i do agree that whatever the shortened answer is, that it will satisfy the length, lengthy answer that she would like to give. So, do we want to do that with this question, or how do you want to handle that procedurally? MR. RHEINHART: Well, I think I have given the instruction. [ think she, will give her the same instruction in the future to the 2 extent that it's relevant, and I think that if 4 swe can all just agree that if she simply says i or I simply say "The Fifth Amendment," that will qualify as giving a sufficient answer to asa matter off ‘Taw, and will invoke that $663). 832-7500 PROSE COURT REPORTING AGENCY, Page 12]) 1 we've done it in the past. 2 MR. KUVIN: [hear you, and I have a 3 number of issues primary, primarily of which 4 that you're not here to represent anyone 5 currently. 6 7 8 3 MR. GOLDBERGER: Yeah, | am. I'm actually, I'm actually here representing Jeffrey Epstein, so... MR. KUVIN: Okay. With respect to all the 10 civil cases, though, you're not here to di represent anyone, so —12 MR. GOLDBERGER: Yes, Iam, 13 MR. KUVIN: With the exception -14 MR. GOLDBERGER: I represent - Iam —15 don't mean to interrupt you, but I am counsel 16 of record in the civil cases. 17 MR. KUVIN: Okay. Okay. 18 MR. RHEINHART: If we have a stipulation, 19 what's the problem? Are you -20 MR. KUVIN: There is none. 2. MR. RHEINHART: ~ worried about a waiver? 22 MR. GOLDBERGER: No, I'm not worried about £ 23 that at all. I'm worried about what is played d toa jury if this gets tried, MR. KUVIN: Okay. And i 3 (Pages 3 to 12) Inc. (561) 832-7506

Page 13 Page 158 1 coaching Bruce, but | think he can handle 1 I choose to invoke my Fifth Amendment right. 2 himself pretty adequately now ~ 2 BY MR. KUVIN: 3 MR. GOLDBERGER: I have -- 3 Q. Would you agree with me that you're 4 MR. KUVIN: So I leave it up to Bruce -- 4 approximately 5 feet, 8 inches tall? 5 MR. GOLDBERGER: I have all the confidence 5 MR. RHEINHART: Same instruction. 6 in Bruce, 6 THE WITNESS: On the advice of my lawyer, 7 MR. KUVIN: Mr. Rheinhart, with respect to 7 L must invoke my Fifth Amendment right. 8 how you want to handle it, I think we have an 8 BY MR. KUVIN: 9 agreement. 9 Q. Would you agree with me that your eyes are 10 MR. RHEINHART: I'm satisfied that we have 10 hazel? 11 a stipulation, and I assume if there is ever a ail MR. RHEINHART: Same instruction. b 12 trial, that would be played or produced to the i2 THE WITNESS: On the advice of my lawyer, 13 jury that simply by using shorthand, what she's 13 I choose to invoke my Fifth Amendment right. ff 14 really saying is the lengthier answer now. I'm 14 BY MR. KUVIN: l 15 satisfied with that. 15 Q. Would you agree with me that you were born ff 16 MR. KUVIN: And I agree with that. 16 in Hawaii? 17 BY MR. KUVIN: 17 MR. RHEINHART: Same instruction. L 18 Q. Okay. Ma'am, what is your current 18 THE WITNESS: On the advice of my lawyer, { 19 address? 19 I choose to invoke my Fifth Amendment right. 20 MR. RHEINHART: Again, | will instruct the 20 BY MR. KUVIN: 21 witness not to answer the question. 21 Q. What are the names of your parents? 22 THE WITNESS: On the instruction of my 22 MR. RHEINHART: Same instruction. i 23 lawyer, I choose to invoke my Fifth Amendment 23 THE WITNESS: On the advice of my lawyer, F 24 right. 24 I must invoke my Fifth Amendment right. 25 25 Page 14 Page 16} 1 BY MR. KUVIN: 1 BY MR, KUVIN: 2 Q. What is your current phone number? 2 Q. Are you married or single? 3 MR. RHEINHART: Same instruction. 3 MR. RHEINHART: Same instruction. 4 THE WITNESS: On the advice of my lawyer, 4 THE WITNESS: On the advice of my lawyer, 5 I choose to invoke my Fifth Amendment right. 5 I must to invoke my Fifth Amendment right. % 2. BY MR..KUVIN: : 6 ‘Plaintiff's Exhibit No. 1 was marked for Q.” What is your cellphone number? iH identification.) MR. RHEINHART: Same instruction - 8 MR. KUVIN: I'm going to show you what THE WITNESS: On the advice of my lawyer, 9 we'll mark as Plaintiff's Exhibit 1. I choose to invoke my Fifth Amendment right. 10 And I'll ask the videographer to zoom MR. RHEINHART: You have to let me speak | 11 in here for a second. before you answer in case there's an objection t2: BY MR. KUVIN: or any of the other lawyers have an objection. 13 Q. Okay. Ma'am, | am going to show youa BY MR. KUVIN: 14 photograph we've marked as Plaintiffs Exhibit | and Q. Lam going to show you a photograph. Oh, 15 ask you if you recognize this registered sex what is your date of birth? 16 offender, MR. RHEINHART: Same instruction. 17 MR. RHEINHART: First, object to the form THE WITNESS: On the advice of my lawyer, | 18 of the question. It assumes facts not before I choose to invoke my Fifth Amendment right. 19 the witness, and I'll give the witness the same MR. KUVIN: Let's make is easier. 20 instruction as to that question. i BY MR. KUVIN: 21 THE WITNESS: At the advice of my lawyer, Q. Ms. Kellen, would you agree with me that 22 I must invoke my Fifth Amendment right. your date of birth is May 25th, 1979? 23 BY MR. KUVIN: MR. RHEINHART: Same instruction. 24 Q. Would you agree with me that this (S61) THE WITNESS: On the advice of my lawyer, es 832-7500 PROSE COURT REPORTING AGENCY, _ registered sex offender's name is Jeffrey Epstein? : SSSI ET TTT 4 (Pages 13 to 16) Inc. (561) 832-7506

Page 17 Page 19% 1 MR. RHEINHART: Same instruction, same 1 question. It's ambiguous and compound, and I 2 objection. 2 will instruct the witness not to answer based 3 THE WITNESS: At the advice of my lawyer, 3 on her Fifth Amendment privilege. 4 I must invoke my Fifth Amendment right. 4 THE WITNESS: On the advice of my lawyer, 5 BY MR. KUVIN: 5 T must invoke my Fifth Amendment right. 6 Q. Would you agree with me that Jeffrey 6 BY MR. KUVIN: 2 Epstein is a sexual offender? 7 Q. And why did you do that? 8 MR. RHEINHART: Object to the form of the 8 MR. RHEINHART: Object to the form. It's 3 question and instruct the witness not to answer 9 ambiguous, in fact that what? 10 on her Fifth Amendment privilege. 10 BY MR. KUVIN: 1 THE WITNESS: On the advice of my lawyerij 11 Q. Why did you bring minor girls to 12 must invoke my Fifth Amendment right. 12 Jeffrey Epstein for him to have sex with? : 13 BY MR. KUVIN: 13 MR. RHEINHART: Same objection as to form 14 Q. Would you agree with me that 14 and instruct the witness not to answer. f 15 Jeffrey Epstein sexually abused you? 15 THE WITNESS: On the advice of my lawyer, 16 MR. RHEINHART: Objection to the form, 16 I must invoke my Fifth Amendment right. 17 both as to the form of the question as to 17 BY MR. KUVIN: 18 harassing and instruet the witness not to 18 Q. What do you currently do for a job? 19 answer, based on the Fifth Amendment privilege. | 19 MR, RHEINHART: Instruct the witness not 20 THE WITNESS: On the advice of my lawyer, | 20 to answer the question. 21 I must invoke my Fifth Amendment right. 21 THE WITNESS: On the advice of my lawyer, 22 BY MR. KUVIN: 22 I must invoke my Fifth Amendment right. 23 Q. Would you agree with me that you were a 23 BY MR. KUVIN: 24 minor when Jeffrey Epstein first had sexual 24 Q. Would you agree with me that you currently 2s relations with you? 25 work for Jeffrey Epstein? E Page 18 Page 20 K i MR. RHEINHART: Object to the form. It 1 MR. RHEINHART: Instruct the witness not 2 assumes facts not before the witness. It is a 2 to answer the question. 3 compound question and I would instruct the 3 THE WITNESS: On the advice of my lawyer, 4 witness not to answer based on her Fifth 4 I must invoke my Fifth Amendment right. i 5 Amendment privilege. 5 BY MR. KUVIN: 6 THE WITNESS: On the advice of my lawyer, 6 Q. How long have you worked for 7 [ must invoke my Fifth Amendment right. 7 Jeffrey Epstein? 8 BY MR. KUVIN: 8 MR. RHEINHART: Same instruction. f 9 Q. Would you agree with me that you have had 9 THE WITNESS: On the advice of my lawyer, [| 10 sex with Jeffrey Epstein? 10 { must invoke my Fifth Amendment right. 1 MR. RHEINHART: Same instruction. 11 BY MR. KUVIN: 12 THE WITNESS: On the advice of my lawyer, 12 Q. Would you agree with me that you've worked 13 I must invoke my Fifth Amendment right. 13 for Jeff, Jeffrey Epstein for over 20 years as his B 14 BY MR. KUVIN: 14 personal assistant? 15 Q. Would you agree with me that you first had 15 MR. RHEINHART: Instruct the witness not 16 sex with Jeffrey Epstein when you were under the age | 16 to answer the question. 17 of 187 17 THE WITNESS: On the instruction of my 18 MR. RHEINHART: Same instruction. 18 jJawyer, | must invoke my Fifth Amendment right. 19 THE WITNESS: On the advice of my lawyer, 19 BY MR. KUVIN: ) 20 I must invoke my Fifth Amendment right. 20 Q. Would you agree with me that when you 21 BY MR. KUVIN: 21 first were hired by Jeffrey Epstein as his personal 22 Q. Would you agree with me, ma'am, that you 22 assistant, you were under the age of 182 23 brought numerous underage girls to Jeffrey Epstein 23 MR. RHEINHART: Object to the form. It's 24 so that he could have sex with them? 24 compound and assumes facts not present before MR. RHEINHART: Object to the form of: ‘the the witness, and 1 instruct: the witness not fo 5 (Pages 7 to 20) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

—— (561) MR. RHEINHART: Object to the form. It assumes facts th that are. not present for the 832-7500 Page 21 Page 23 1 answer the question based on her Fifth L witness, and I will instruct the witness not to 2 Amendment privilege. 2 answer based on her Fifth Amendment privilege. 3 THE WITNESS: On the instruction of my 3 THE WITNESS: On the instruction of my 4 lawyer, | must invoke my Fifth Amendment right. 4 lawyer, I must invoke my Fifth Amendment right. § 5 BY MR. KUVIN: S BY MR. KUVIN: 6 Q. Who introduced you to Jeffrey Epstein the 6 Q. Would you agree with me that 7 first time that you met him? 7 Jeffrey Epstein owns numerous planes, private 8 MR. RHEINHART: Same instruction. 8 planes? 9 THE WITNESS: On the instruction of my 9 MR. RHEINHART: Instruct the witness not 10 lawyer, { must invoke my Fifth Amendment right. } 10 to answer. Li. BY MR. KUVIN: li THE WITNESS: On the instruction of my 4 12 Q. Did Ghislaine Maxwell introduce you to 12 lawyer, [ must invoke my Fifth Amendment right, F 13 Jeffrey Epstein for the first time? 13 BY MR. KUVIN: . 14 MR. RHEINHART: Same instruction. 14 Q. And you've been on every one of those 15 THE WITNESS: On the instruction of my 15 private planes; isn't that true? 16 lawyer, I must invoke my Fifth Amendment right. | 16 MR. RHEINHART: Object to the form. It 17 BY MR. KUVIN: 47 assumes facts not before the witness, and { 18 Q. When was the first time you were in 18 will instruct the witness not to answer based 19 Jeffrey Epstein's home located on El Brillo Way on 19 on her Fifth Amendment privilege. 20 Palm Beach Island? 20 THE WITNESS: On the instruction of my 21 MR. RHEINHART: Object to the form ofthe | 21 lawyer, I must invoke my Fifth Amendment right, |] 22 question as compound and assuming facts not 22 BY MR. KUVIN: 23 before the witness. And | instruct the witness 23 Q. Ma'am, isn't it true that you've seen the 24 not to answer based on her Fifth Amendment 24 passenger manifest for Jeffrey Epstein's plane? 25 privilege. 25 MR. RHEINHART: Object to the form. It Page 22 Page 24 i THE WITNESS; On the instruction of my A assumes facts that are not established as known. 2 lawyer, I must invoke my Fifth Amendment right. } 2 to this witness, and I instruct the witness not 3 BY MR. KUVIN: 3 to answer the question based on her Fifth 4 Q. Would you agree with me that 4 Amendment privilege. 5 Jeffrey Epstein owns a home at 358 El Brillo Way, 5 THE WITNESS: On the instruction of my 6 Palm Beach Island, Florida? 6 lawyer, I must invoke my Fifth Amendment right. 7 MR. RHEINHART: Instruct the witness not 7 MR. KUVIN: Let me show you what we'll 8 to answer based on her Fifth Amendment 8 mark as Exhibit 2. 9 privilege. 9 10 THE WITNESS: On instruction of my 10 (Plaintiff's Exhibit No. 2 was marked for di counsel, I must invoke my Fifth Amendment 1 identification.) 12 tight. 12 MR. KUVIN: Thank you. 13 BY MR. KUVIN: 13 MR. RHEINHART: Do you want to zoom in on 14 Q. Would you agree with me that you've been 14 it like you did the last time? 15 in that home numerous times? 15 MR. KUVIN: No, that's fine. 16 MR. RHEINHART: Instruct the witness not 16 MR. RHEINHART: Take your time. 7 to answer the question based on her Fifth 7 MR. KUVIN: And flip through, is Amendment privilege. 18 BY MR. KUVIN: 19 THE WITNESS: On instruction of my lawyer, | 19 Q. Allright. Ma'am, would you agree with me 20 I must invoke my Fifth Amendment right. 20 that this is a passenger manifest for one of” 21 BY MR. KUVIN: 21 Jeffrey Epstein's airplanes? 22 Q. Would you agree with me that you have gone | 22 MR. RHEINHART: Instruct the witness not 23 on Jeffrey Epstein’s plane numerous times? 23 to answer the question based on her Fifth PROSE COURT REPORTING AGENCY, Amendment privilege. THE WITNESS: On the instruction of my a 6 (Pages 21 to 24) Inc. (561) 832-7506

Page 25 Page 27 (561) 832-7500 this witness has any knowledge of and instruct the witness not to answer based on t her] Fifth 1 lawyer I must exercise my Fifth Amendment 1 Amendment privilege. 2 right. 2 THE WITNESS: On the instruction of my E 3 BY MR. KUVIN: 3 lawyer, I must invoke my Fifth Amendment right. }} 4 Q, And would you agree with me that you 4 BY MR. KUVIN: E 5 appear as a passenger on these flight manifests on $ Q. Would you also agree with me that the two 6 numerous occasions? 6 unknown females listed on the passenger manifest 7 MR. RHEINHART: Object to the form. It 7 marked as Exhibit 2 were underage girls, under the 8 assumes facts not established as known to this 8 age of 18? 9 witness, and I instruct the witness not to 3 MR. RHEINHART: Object to the form. It 10 answer the question. 10 calls for speculation. Also it's not been a1 THE WITNESS: On the instruction of my il established this witness has any knowledge of 12 lawyer, I must exercise my Fifth Amendment 12 this document and instruct her not to answer 13 right, 13 based on her Fifth Amendment privilege. 14 BY MR. KUVIN: 14 THE WITNESS: On the instruction of my 15 Q. Would you agree with me that your name 15 lawyer, I must invoke my Fifth Amendment right. }j 16 does, in fact, appear on the passenger manifest for 16 BY MR. KUVIN: f 17 these planes, for this plane? 17 Q. Would you agree with me that the girls 18 MR. RHEINHART: Same objection and same | 18 that are listed as females one, and the second 19 instruction. 19 female for this flight of January 11, 2005, from 20 THE WITNESS: On the advice of my lawyer, | 20 West Palm Beach to the U.S. Virgin Islands, that 21 {must invoke my Fifth Amendment right. 2i those two females were under the age of 17? 22 BY MR. KUVIN: 22 MR. RHEINHART: Same objection. It has 23 Q. Who are the two females that appear on the 23 not been established the witness has any 24 passenger manifest for January 11, 2005, on the 24 knowledge of this document. It calls for her 25 first page of Exhibit 2? 25 to speculate, and I instruct her not to answer Page 26 Page 28 f L MR. RHEINHART: I'll object to the form, di based on her Fifth Amendment privilege. 2 and it has not been established this witness 2 THE WITNESS: On the instruction of my 3 knows anything about this document, and I will 3 jawyer, I must invoke my Fifth Amendment right. 4 instruct her not to answer based on the Fifth 4 BY MR. KUVIN: 3 Amendment privilege. 5 Q. Would you agree with me that the two 6 THE WITNESS: On the instruction of my 6 females shown on the flight with you of January 11, 7 lawyer I must invoke my Fifth Amendment right. 7 2005 were under the age of 16? 8 BY MR. KUVIN: 8 MR. RHEINHART: Same objection as to form. § 9 Q. Do you agree with me that you took a 9 It has not been established this witness knows Ep 10 flight on Jeffrey Epstein's plane from West Palm 10 anything about whether there were these 14 Beach to the U.S. Virgin Islands, St. Thomas on aL witnesses, these females and who they are, so 12 January 11, 2005? 12 it's asking her to speculate, and I instruct 13 MR. RHEENHART: Instruct the witness not 13 her not to answer based on her Fifth Amendment 14 to answer the question based on her Fifth 14 privilege. 15 Amendment privilege. 15 THE WITNESS: On the instruction of my 16 THE WITNESS: On the instruction of my 16 lawyer, I must invoke my Fifth Amendment 17 lawyer I must invoke my Fifth Amendment right. i7 privilege. 18 BY MR. KUVIN: 18 BY MR. KUYVIN: 19 Q. Would you agree with me that on that 19 Q. Ma'am, you were on that flight of 20 flight were you, Jeffrey Epstein, Nadia Marcinkova 20 January 11, 2005, were you not? 21 and two unknown females? ai MR. RHEINHART: [ instruct the witness not 22 MR. RHEINHART: Object to the form. Again} 22 to answer based on her Fifth Amendment 23 assumes facts that have not been established 23 privilege. PROSE COURT REPORTING AGENCY, THE WITNESS: On the instruction of my lawyer 1 must invoke my Fifth Amendment right. I RTA A TR AORTA 7 (Pages 25 to 28) INC. (561) 832-7506

Page 29 Page 31 (561) 832-7500 ma BY MR. KUVIN: 10's Ghislaine Maxwell? PROSE COURT REPORTING AGENCY, 1 BY MR. KUVIN: 1 MR. RHEINHART: Same instruction. 2 Q. You also agree with me that the two girls 2 THE WITNESS: On the instruction of my 3 that are listed as on that flight with you of 3 __ lawyer, I must invoke my Fifth Amendment right. |} 4 January 11,2005, were under the age of 15 years 4 BY MR. KUVIN: 5 old? 5 Q. Who is Dana Burns? 6 MR. RHEINHART: Object to the form. It 6 MR. RHEINHART: Same instruction. Pe 7 calls for speculation, lack of personal 7 THE WITNESS: On the advice of my lawyer, 8 knowledge, and instruct the witness not to 8 I must invoke my Fifth Amendment right. 9 answer based on her Fifth Amendment privilege. 9 BY MR. KUVIN: 10 THE WITNESS: On the instruction of my 10 Q. Who is Mark Zeff. il lawyer, I must invoke my Fifth Amendment right. ; 11 MR. RHEINHART: Same instruction. 12 BY MR, KUVIN: 12 THE WITNESS: On the advice of my lawyer, # 13 Q. Would you agree with me that the two 13 I must invoke my Fifth Amendment right. 5 14 females listed as being on that flight with you of 14 BY MR. KUVIN: 15 January 11 of 2005 were under the age of 14 years 15 Q. Who is David Mullen? 16 old? 16 MR. RHEINHART: Same instruction. 17 MR. RHEINHART: Object to the form. It 17 THE WITNESS: On the advice of my lawyer, 18 calls for speculation. The witness has no 18 I must invoke my Fifth Amendment right. 19 personal knowledge and instruct the witness not 19 BY MR. KUVIN: 20 to answer based on her Fifth Amendment 20 Q. Who is Todd Meister? 21 privilege. 21 MR. RHEINHART: Same instruction. i 22 THE WITNESS: On the instruction of my 22 THE WITNESS: On the advice of my lawyer, 23 lawyer, I must invoke my Fifth Amendment right. | 23 I must invoke my Fifth Amendment right. 24 BY MR. KUVIN: 24 BY MR, KUVIN: 25 Q. Would you agree with me that the two 25 Q. Who is Jean-Luc Brunel? Page 30 Page 32, £ femates listed as being on the flight with you of i MR. RHEINHART: Same instruction. 2 January 11, 2605, from West Palm Beach to the U.S. 2 THE WITNESS: On ihe advice of my lawyer, 3 Virgin Islands, with Jeffrey Epstein as well, were 3 I must invoke my Fifth Amendment right. 4 4 under the age of 13 years old and you were aware of 4 BY MR. KUVIN: S that? 5 Q. Ma'am, would you agree with me that all of 6 MR. RHEINHART: Object to the form both as 6 the names I just recently mentioned where you 7 compound, it also assumes facts that it has not 7 invoked your Fifth Amendment, were involved in a 8 been established this witness has any knowledge 8 conspiracy to abuse underaged girls, girls under the 9 of, calls for her to speculate, and I instruct 9 age of 18 for sexual gain and pleasure? 10 her not to answer based on her Fifth Amendment 10 MR. RHEINHART: Object to the form of the 11 privilege. 14 question. It calls for a legal conclusion. It 12 THE WITNESS: On the instruction of my 12 is compound. It calls for her to speculate. 13 lawyer | must invoke my Fifth Amendment right. 13 ‘There is no basis for her to be able to give a 14 BY MR. KUVIN: 14 legal opinion as to what a conspiracy is, and 1 15 Q. Who is Adriana Musinska? 15 instruct her not to answer based on her Fifth 16 MR. RHEINHART: I'm sorry. Can you repeat | 16 Amendment privilege. E 17 the name? 17 THE WITNESS: On the advice of my lawyer, [j 18 MR. KUVIN: Musinska, M-u-s-i-n-s-k-a. is L must invoke my Fifth Amendment right. 19 MR. RHEINHART: I'll instruct the witness 19 BY MR. KUVIN: 20 not to answer based on her Fifth Amendment 20 Q. Would you agree with me that all of the ae privilege. 21 names I just mentioned were individuals that were 22 THE WITNESS: On instruction of my lawyer, | 22 working together for their own sexual gain and 23 I must invoke my Fifth Amendment right. 23 pleasure? MR. RHEINHART: Object to the form of the [/ question as ambiguous and compound. Linstruct f 8 (Pages 29 to 32) (561) 832-7506 INC.

Page 33 i her not to answer based on her Fifth Amendment i BY MR. KUVIN: 2 privilege. 2 Q. Would you agree with me that Jeffrey 3 THE WITNESS; On the advice of my lawyerI| 3 Epstein worked closely with Jean-Luc Brunel in order 4 must invoke my Fifth Amendment privilege. 4 to obtain girls from out of state and bring them to } 3 BY MR. KUVIN: 5 Florida for their own sexual pleasure? 6 Q. What is MC Squared? 6 MR. RHEINHART: Object to the form as 7 MR. RHEINHART: I instruct the witness not 7 ambiguous, whose own sexual pleasure, and 8 to answer based on her Fifth Amendment 8 insteuct the witness not to answer the question 9 privilege. 9 based on her Fifth Amendment privilege. 10 THE WITNESS: On the advice of my lawyerI} 10 MR. KUVIN: Perfectly good objection. She il must invoke my Fifth Amendment right. 11 doesn't have to answer the question. Let me 12 BY MR. KUVIN: 12 clarify. 13 Q. Would you agree with me that MC Squared is } 13 BY MR. KUVIN: 14 a modeling agency that was funded by 14 Q. Would you agree with me, ma'am, that both 15 Jeffrey Epstein? 15 Jean-Luc Brunel and Jeffrey Epstein worked together 16 MR. RHEINHART: I instruct the witness not | 16 to obtain underage girls from out of state and bring 17 to answer based on her Fifth Amendment 17 them to Florida for both of their own sexual 18 privilege. 18 pleasure? 19 THE WITNESS: The advice of my lawyer I 19 MR. RHEINHART: I'm going to object as 20 must invoke my Fifth Amendment right. 20 compound and instruct ~ I object to the form 21 BY MR. KUVIN: al as compound, and instruct the witness not to 22 Q. Would you agree with me that MC Squared 22 answer based on her Fifth Amendment privilege. 23 was wholly funded by Jeffrey Epstein? 23 THE WITNESS: On the instruction of my ‘ MR. RHEINHART: Object to the form ofthe | 24 lawyer I must invoke my Fifth Amendment right. question as to what "wholly funded" means, and 25 Page 34 Page 36 i E would instruct the witness not to answer the 1 BY MR. KUVIN: 2 question based on her Fifth Amendment 2 A. Would you agree with me that 3 privilege. 3 Ghislaine Maxwell, Jean-Luc Brunel, and Jeffrey Epstein}? 4 THE WITNESS: On the advice of my lawyer [ 4 worked together to obtain underage girls from out of i 5 must invoke my Fifth Amendment right. ° state and bring them into the State of Florida for their 6 BY MR. KUVIN: 6 own sexual pleasure? 7 Q. Would you agree with me that sf MR. RHEINHART: Object to the form of the 8 Jeffrey Epstein is the sole individual whose money 8 question as compound and ambiguous, and 9 was used to start the company, MC Squared? 9 instruct the witness not fo answer based on her 10 MR. RHEINHART: Instruct the witness not 10 Fifth Amendment privilege. dL to answer the question based on her Fifth dl THE WITNESS: On the instruction of my 12 Amendment privilege. 12 lawyer, I must invoke my Fifth Amendment right. 13 THE WITNESS: On the advice of my lawyer] 13 (Katherine Ezelf and Amy Edert 14 must invoke my Fifth Amendment right. 14 entered the deposition.) is BY MR. KUVIN: 15 MR. GOLDBERGER; That's why we're -16 Q. Would you agree with me that 16 MR. KUVIN: That's why we lost them. 17 Jean-Luc Brunel worked with Jeffrey Epstein to i? MR. RHEINHART: Do you want to take a 18 obtain underage girls for both of their sexual 18 one-minute break so we can -19 pleasure? 9: MR. KUVIN: Yeah, let's take a quick 20 MR. RHEINHART: Object to the form of the | 20 one-minute break. 21 question as ambiguous and instruct the witness 21 THE VIDEOGRAPHER: We're now off video 22 not to answer based on her Fifth Amendment 22 record. The time is 10:56 a.m. 23 privilege. 23 {A brief recess was held.) 24 THE WITNESS: On the advice of my lawyer!| 24 {Plaintiff's Exhibit No. 3 was marked for 25 must invoke my Fifth Amendment right. 25 identification.) 9 (Pages 33 to 36) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 37 Page 39 1 THE VIDEOGRAPHER: We're now on video 1 personal knowledge and instruct her not to 2 record at [1:01 a.m. 2 answer based on her Fifth Amendment privilege. 3 MR. KUVIN: Just for the video record and 3 {t's also compound. 4 for the written record Katherine Ezell and Amy 4 THE WITNESS: On the instruction of my 5 Ederi have now appeared and are present in 5 lawyer I must invoke my Fifth Amendment 6 person. 6 privilege. 7 MR. GOLDBERGER: Just one more matter for} 7 BY MR. KUVIN: 8 the record. Jack Goldberger, on behalf of 8 Q. The witness says that you may not have 9 Jeffrey Epstein. Rather than impose a form 3 knowledge or we don't know whether you have 10 objection to every question, I think we have 10 knowledge regarding this passenger manifest, so let = ad. reached an agreement that on behalf of LL me ask you, do you have any knowledge about this 12 Mr. Epstein, | am adopting the form objections 12 passenger manifest? 13 that Mr, Rheinhart is making on behalf of his 13 MR. RHEINHART: Object to the form of the f 14 client nunc pro tunc to the beginning of this 14 question as ambiguous as to this and what a AS} deposition. 15 manifest is, and also her knowledge, and { will 16 MR. KUVIN: No objection. 16 instruct her not to answer based on her Fifth 17 MR. GOLDBERGER: Okay. 17 Amendment privilege. 18 BY MR. KUVIN: 18 THE WITNESS: On the instruction of my 19 Q. Allright. Allright. Ms. Kellen, would 19 lawyer, I must invoke my Fifth Amendment 20 you agree with me that there was an agreement 20 privilege. 21 between Jeffrey Epstein, Ghislaine Maxwell, 21 BY MR. KUVIN: 22 Jean-Luc Brunel, yourself and Nadia Marcinkova to 22 Q. Based on the objection, do you know whata # 23 bring in girls from out of state that were underage? 23 manifest is? a 24 MR. RHEINHART: Object to the form of the 24 MR. RHEINHART: Object to the form of the}; 25 question as leading, as compound, and instruct 25 question as ambiguous and instruct her not to : Page 38 Page 40 1 the witness not to answer based on her Fifth 1 answer based on her Fifth Amendment privilege. } 2 Amendment privilege. 2 THE WITNESS: On the instruction of my 3 THE WITNESS: On the instruction of my 3 lawyer I must invoke my Fifth Amendment right. |; 4 lawyer f must invoke my Fifth Amendment right. ; 4 BY MR. KUVIN: lt 5 BY MR. KUVIN: 5 Q. Have you heard the word "manifest" before? }j 6 Q. Would you agree with me that there was an 6 MR. RHEINHART: I'll instruct the witness 7 agreement between Jeffrey Epstein, 7 not to answer based on her Fifth Amendment 8 Ghislaine Maxwell, Jean-Luc Brunel, yourself and 8 privilege. 9 Nadia Marcinkova to bring in girls that were 9 THE WITNESS: On the instruction of my 10 underage from out of state for sexual contact? 10 lawyer I must invoke my Fifth Amendment right. } 12 MR. RHEINHART: Object to the form ofthe} 12 BY MR. KUVIN: 12 question as leading and compound, and [ 12 Q. Would you agree with me, ma'am, that you. 13 instruct the witness not to answer based on her 13 have seen this passenger manifest, listed as 14 Fifth Amendment privilege. 14 Exhibit 3, in the past? 15 THE WITNESS: On the instruction of my 15 MR. RHEINHART: f'll instruct the witness 16 lawyer I must invoke my Fifth Amendment 16 not to answer based on her Fifth Amendment i? privilege. 17 privilege. 18 BY MR. KUVIN: 18 THE WITNESS; On the instruction of my ig Q. Allright. Let me show you what we've 19 lawyer ] must invoke my Fifth Amendment right. 20 premarked as Plaintiff's Exhibit 3. Do you 20 BY MR. KUVIN: 21 recognize this as the passenger manifest for one of 21 Q. Who is Zinta Broukis? ; 22 Jeffrey Epstein's planes? 22 MR. RHEINHART: I'll instruct the witness 23 MR. RHEINHART: I object to the form of 23 not to answer based on her Fifth Amendment i 24 the question. It assumes facts that this 24 privilege. (561) itness, evidence that this witness has ho 832-7500 PROSE COURT REPORTING AGENCY, THE WITNESS: On the j instruction of my 10 (Pages 37 to 40) (561) 832-7506 Inc.

Page 41 1 lawyer I must invoke my Fifth Amendment 2 privilege. 3 MR. KUVIN: Spelling for the court 4 reporter is Z-i-n-t-a, B-r-0-u-k-i-s. 5 BY MR. KUVIN: 6 Q. Who is Eva Andersson, with two S's? 7 MR. RHEINHART: I'll instruct the witness 8 not to answer based on her Fifth Amendment 2 privilege. 10 THE WITNESS; On the instruction of my i lawyer, I must invoke my Fifth Amendment right. 12 BY MR. KUVIN: 13 Q. Who is Sevina Dubin (phonetic)? 14 MR. RHEINHART: Same instruction. 15 THE WITNESS: On the instruction of my 16 lawyer, [ must invoke my Fifth Amendment right. 17 BY MR. KUVIN: 18 Q. Who is Mya Dubin (phonetic)? 19 MR. RHEINHART: Same instruction. 20 THE WITNESS: On the instruction of my 21 lawyer I must invoke my Fifth Amendment right. 22 BY MR. KUVIN: 23 Q, Who is Chris Valdez (phonetic)? 2 24 MR. RHEINHART: Same instruction. 25 THE WITNESS: On the instruction of my OYA UbUNne Page 43 listed in the passenger list to the left? | MR. RHEINHART: Object to the form, the question is leading and instruct the witness E not to answer based on the Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. ; BY MR. KUVIN: Q. Would you agree with me that you were on a plane with Jeffrey Epstein on April 27, 2005? E MR. RHEINHART: Same instruction. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that on that plane of April 27, 2005, from Teterboro, New Jersey, to West Palm Beach, was a female who was under the age of 167 : MR. RHEINHART: Object to the form. It assumes facts not established. Any personal A knowledge by this witness, and instruct her not to answer based on her Fifth Amendment privilege. It also calls for speculation. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment i Page 42 1 lawyer I must invoke my Fifth Amendment right. 2 BY MR. KUVIN: 3 Q. Who is James Stanley? 4 MR. RHEINHART: Same instruction. 3 THE WITNESS: On the instruction of my 6 lawyer, I must invoke my Fifth Amendment right, 7 BY MR. KUVIN: 8 Q. Who is Sophia Stanley? 9 MR. RHEINHART: Same instruction. 10 THE WITNESS: On the instruction of my ai jawyer I must invoke my Fifth Amendment right. 12 BY MR. KUVIN: 13 Q. Who is Alexis Stanley? 14 MR. RHEYNHART: Same instruction. as THE WITNESS: On the instruction of my 16 lawyer, I must invoke my Fifth Amendment right. i7 BY MR. KUVIN: i8 Q. Ma'am, if you would, in Exhibit 3, would 19 you turn to the date of April 27, 2005, for me? 20 It's about halfway through the packet. April 27, 21 ‘05. Are you there? 22 A. Uh-huh. 23 Q. Okay. On this particular date, will you agree with me that you flew from Teterboro, New Jersey to West Palm Beach | ona plane with people (501) 832-7500 PROSE COURT REPORTING AGENCY, Page 44 privilege. BY MR. KUVIN: Q. Would you agree with me that on the flight of April 27, 2005, from Teterboro, New Jersey to iH West Palm Beach was a female on the plane with you |} that was under the age of 157 MR. RHEINHART: Object to the form of the question. It requires speculation. It assumes facts not established before this witness. Tl instruct her not to answer based on her Fifth Amendment privilege. It's also ambiguous. THE WITNESS: On the instruction of my lawyer,! must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Will you turn to May 6, 2005, please. And this is, for the record, in Exhibit 3. On May 6th, 2005, ma'am, will you agree with me that you took a flight from Teterboro, New Jersey to West Palm Beach, with Jeffrey Epstein, Nadia Marcinkova, Andriana, Andrea Musinska, David Mullen, Larry Morrison and another female? MR. RHEINHART: Object to the form of the question as ‘compound, calling f for speculation. 11 (Pages 41 to 44) INC. (561) 832-7506

OWBIMRHeRWNHHE (561) Page 45 T instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Would you agree with me, ma'am, that on the flight of May 6th, 2005, that's shown in Exhibit 3, that the female identified in the passenger manifest was under the age of 16? MR. RHEINHART: Object to the form. It assumes facts not established that this witness has any personal knowledge. It calls for her to speculate, and I'll instruct her not to answer based on her Fifth Amendment privilege. THE WIINESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Would you agree with me that the female identified in the passenger manifest of May 6th, 2005, was under the age of 15? MR. RHEINHART: Same objection as the previous question, same instruction. THE WITNESS: On the instruction of my Page 46 lawyer I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Wouid you agree with me that the femaie listed in the passenger manifest of May 6th, 2005, was under the age, was under the age of 147 MR. RHEINHART: Same instruction as to the previous two questions and the same objection as to those two questions, THE WITNESS: On the instruction of my lawyer I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. If you would turn to the date of June 20 of 2005 for me, please. On the date of June 20, 2005, would you agree with me that you took a flight with Jeffrey Epstein from West Palm Beach to Teterboro, New Jersey? MR. RHEINHART: Object to the form as leading. I'll instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, | must invoke my Fifth Amendment privilege. 832-7500 PROSE COURT REPORTING AGENCY, Page 47 1 BY MR. KUVIN: 2 Q. Do you also agree with me on that flight 3 of June 20th, 2005, was an unidentified female, 4 according to the passenger manifest? 5 MR. RHEINHART: Object to the form — 6 excuse me -- as leading, and instruct the 7 witness not to answer based on her Fifth 8 Amendment privilege. 3 THE WITNESS: On the instruction of my 10 lawyer, I must choose to invoke my Fifth ai Amendment privilege. 12 BY MR. KUVIN: 13 Q. Would you agree with me that that female 14 listed on the flight of June 20, 2005, was under the 15 age of 16 years old? 16 MR. RHEINHART: Objection to the form as |} 17 leading and also requiring speculation. I'll 18 instruct the witness not to answer based on her 19 Fifth Amendment privilege. 20 THE WITNESS: On the instruction of my 21 lawyer, I must choose to invoke my Fifth 22 Amendment privilege. 23 BY MR. KUVIN: Q. Would you agree with me that the unidentified female on the passenger manifest of Page 48 |i 1 June 20, 2005, was under the age of 14? 2 MR. RHEINHART: Objection, calls for 3 speculation, instruct the witness not to answer 4 based on her Fifth Amendment privilege. 5 THE WITNESS: On the instruction of my 6 lawyer, I must invoke my Fifth Amendment 7 privilege. 8 BY MR. KUVIN: 9 Q. Turn to the date of June 30, if you would, 10 2005. Would you agree with me that you took a 11 flight from Teterboro, New Jersey, to West Palm 12 Beach on June 30, 2005, with Jeffrey Epstein? 13 MR. RHEINHART: Object to the form as 14 leading and compound, instruct the witness not 15 to answer based on her Fifth Amendment 16 privilege. 17 THE WITNESS: On the instruction of my 18 lawyer I must, I must invoke my Fifth Amendment |} 19 right. 20 BY MR. KUVIN: 21 Q. Wouid you agree with me that Dana Burns 22 was on that flight? 23 MR. RHEINHART: Same instruction. THE WITNESS: On the instruction of my lawyer I must invoke my Fi ifth Amendment 12 (Pages 45 to 48) Inc. (561) 832-7506

Page 49 Page 51 1 privilege. 1 THE WITNESS: On the instruction of my 2 BY MR. KUVIN: 2 lawyer I must invoke my Fifth Amendment 3 Q. Would you agree with me that there was 3 privilege. 4 also another female on that flight with you? 4 BY MR. KUVIN: 5 MR. RHEINHART: Same instruction. S$ Q. Would you agree with me that on both of 6 THE WITNESS: On the instruction of my 6 those flights were girls that were under the age of t lawyer, [ must invoke my Fifth Amendment 7 16? E 8 privilege. 8 MR. RHEINHART: Same form objection as to fj 9 BY MR. KUVIN: 9 compound, also ambiguous and requiring lH 10 Q. Would you agree with me that you had 19 speculation and instruct the witness not to il personal knowledge that that young female on that | 11 answer based on her Fifth Amendment privilege. § 12 flight with you of June 30, 2005, was under the age | 12 THE WITNESS: The instruction of my lawyer jj 13 of 167 13 { must invoke my Fifth Amendment privilege. 4 14 MR. RHEINHART: Object to the form as 14 BY MR. KUVIN: 1s compound and calling for speculation, and is Q. Would you agree with me, ma'am, that you 16 instruct the witness not to answer based on her 16 have flown on Jeffrey Epstein's plane from 17 Fifth Amendment privilege. 17 Teterboro, New Jersey, to West Palm Beach, on 18 THE WITNESS: On the instruction of my 18 numerous occasions where there were girls on the 19 lawyer, I must invoke my Fifth Amendment 19 plane under the age of 16? 29 privilege. 20 MR. RHEINHART: Object to the form as. 21 BY MR. KUVIN: ai compound and ambiguous as to what numerous 22 Q. Would you agree with me that you had 22 means. Instruct the witness not to answer 23 personal knowledge that that young female on the 23 based on her Fifth Amendment privilege. 24 flight of June 30, 2005, was under the age of 15? 24 THE WITNESS: On the instruction of my 25 MR. RHEINHART: Same instruction, calis | 25 lawyer I must invoke my Fifth Amendment Page 50 Page 52} i for speculation. i privilege. 2 THE WITNESS: On the instruction of my 2 BY MR. KUVIN: 3 lawyer, I must invoke my Fifth Amendment 3 Q. Would you agree with me that you have 4 privilege. 4 fiown on Jeffrey Epstein’s plane from Teterboro, New 5 BY MR. KUVIN: 5 Jersey, to West Palm Beach on at least 100 occasions 6 Q. Would you agree with me that you had 6 where there were girls on the plane with you under 7 personal knowledge that that young female on the 7 the age of 167 8 flight of June 30, 2005, with you was under the age 8 MR. RHEINHART: Object to the form as 9 of 142? 9 compound, requiring speculation and ambiguous, 10 MR. RHEINHART: Objection to form as to | 10 and instruct her not to answer based on her il compound and requiring speculation. I'll 12 Fifth Amendment privilege. 12 instruct the witness not to answer based on her 12 THE WITNESS: On the instruction of my 13 Fifth Amendment privilege. 13 lawyer I must invoke my Fifth Amendment 414 THE WITNESS: On the instruction of my 14 privilege. 15 lawyer [ must invoke my Fifth Amendment 15 BY MR. KUVIN: 16 privilege. 16 Q. Would you agree with me, ma'am, that you 17 BY MR. KUVIN: 47 have flown on Jeffrey Epstein’s plane at least 100 18 Q. Ma‘am, just so we can be quicker about 18 times from Teterboro, New Jersey to West Palm Beach, 19 this, there are flights of July Sth, July 15. It 19 Florida, where there were girls under the age of 15 20 looks like those are the last two. Would you agree | 29 on the plane with you? 21 with me that on July Sth and July 15, you took 21 MR. RHEINHART: Same objections as the 22 flights on Jeffrey Epstein's plane? 22 previous question, same instruction, 23 MR. RHEINHART: Object to the form as 23 THE WITNESS: On the instruction of my (561) 832-7500 compound and instruct the witness not to answer PROSE COURT REPORTING AGENCY, lawyer, I must invoke my Fifth Amendment privilege. 73 (Pages “49 to 52) (561) 832-7506 INC.

Page 53 1 BY MR. KUVIN: - oceasions where Jeffrey Epstein was flying with 2 Q. Would you agree with me that you have 2 young girls under the age of 16 from Teterboro, New |! a flown on Jeffrey Epstein's plane from Teterboro, New 3. Jersey, to Florida, West Palm Beach, Florida, with 4 Jersey to West Palm Beach on at least 100 occasions 4 girls under the age of 16, was doing so, so that he 5 where there were girls on the plane with you that 5 could have sexual contact with them? 6 were under the age of 14? 6 MR. RHEINHART: Object to the form. It's 7 MR. RHEINHART: Objection to the form. 7 compound and requires her to assume facts that 8 its compound and ambiguous, cails for 8 have not been established, and it's ambiguous, 9 speculation and instruct her not to answer 9 and instruct her not to answer based on the 10 based on her Fifth Amendment privilege. 10 Fifth Amendment privilege. il THE WITNESS: On the instruction of my 41 THE WITNESS: On the instruction of my 12 lawyer, { must invoke my Fifth Amendment 12 lawyer, I must assert my Fifth Amendment right. 13 privilege. 13 BY MR. KUVIN: 14 BY MR. KUVIN: 14 Q. Do you agree with me that on the flights a5 Q. Would you agree with me that you have been 1s from West Palm Beach to Paris, where you were 16 on the plane, one of Jeffrey Epstein's -- strike 16 present on the plane with Jeffrey Epstein, that 17 that. 17 there were girls under the age of 16 that 18 Would you agree with me that you have 18 Jeffrey Epstein was having sexual contact with on 19 been on Jeffrey Epstein's plane with him to Paris 19 that plane? 20 where there have been girls on the plane with you 20 MR. RHEINHART: Same objections as 21 under the age of 167 21 previously stated. It's compound, ambiguous, 22 MR. RHEINHART: Objection to the form as 22 and assumes facts that she has no knowledge, or 23 compound, assuming facts not established the 23 it has not been established that she has any 24 witness has any knowledge, and instruct the 24 knowledge of, and instruct her not to answer 25 witness not to answer based on her Fifth 25 based on the Fifth Amendment, and it's leading. fj Page 54 Page 56h 1 Amendment privilege. It's also leading. 1 THE WITNESS: On the instruction of my 2 THE WITNESS: On the instruction of my 2 lawyer I must invoke my Fifth Amendment right. 3 lawyer, I must invoke my Fifth Amendment 3 BY MR. KUVIN: 4 privilege. 4 Q. Ma'am, you've been on the plane, you've 5 BY MR. KUVIN: 5 been on a plane with Jeffrey Epstein in the past, 6 Q. Would you agree with me that you have been 6 have you not? : 7 on the plane with Jeffrey Epstein on flights to 1, MR. RHEINHART: Objection to the form as |} 8 Paris where there have been girls on the plane with 8 leading, and instruct her not to answer based [ 9 you under the age of 157 9 on the Fifth Amendment privilege. 10 MR. RHEINHART: Same objection and same | 10 THE WITNESS: On the instruction of my al instruction as the previous question. 11 lawyer, I must invoke my Fifth Amendment 12 THE WITNESS: On the instruction of my 12 privilege. 13 lawyer, I must invoke my Fifth Amendment 13 BY MR. KUVIN: 14 privilege. 14 Q. Have you been on a plane with 15 BY MR. RUVIN: 15 Jeffrey Epstein ever in your entire life? 16 Q. Would you agree with me that you have been 16 MR, RHEINHART: Instruct the witness not i7 on those same flights we have been discussing where | 17 to answer based on her Fifth Amendment right. 18 there have been girls under the age of 14? 18 THE WITNESS: On the instruction of my 19 MR. RHEINHART: Same instruction and same} 19 Jawyer | must invoke my Fifth Amendment 20 objection as the previous two questions. 20 privilege. 21 THE WITNESS: On the instruction of my 21; BY MR. KUVIN: 22 lawyer, I must invoke my Fifth Amendment 22 Q. Have you ever been on a plane with 23 privilege. 23 Jeffrey Epstein where there was a girl on the plane 24 BY MR. KUVIN: 24 with you under the age of [47 (561) 832-7500 PROSE COURT REPORTING AGENCY, 14 (Pages 53 to 56) INC. (561) 832-7506

Page 57 1 THE WITNESS: On the instruction of my 1 MR. RHEINHART: Same objection as stated 2 lawyer, I must invoke my Fifth Amendment 2 to the previous question; it's ambiguous and 3 privilege. 3 instruct her not to answer based on the Fifth 4 BY MR. KUVIN: 4 Amendment, 5 Q. Ma'am, isn't it true that you've seen 5 THE WITNESS: On the instruction of my 6 Jeffrey Epstein have sex with girls under the age of 6 lawyer, I must invoke my Fifth Amendment right. 7 14 on his plane? 7 MR. KUVIN: Just to clarify, is the 8 MR. RHEINHART: Objection to the form. It 8 ambiguity the word "sex"? 9 assumes facts that it's not been established 3 MR. RHEINHART: Sex and also assumes that 10 that she would have any knowledge of, and FH 10 she's ever met Jeffrey Epstein in her life. il instruct her not to answer based on her Fifth il MR. KUVIN: Any other words in there I 12 Amendment right. 12 need to clarify? 13 THE WITNESS: On the instruction of my 13 MR. RHEINHART: No. 14 lawyer, I must invoke my Fifth Amendment 14 BY MR. KUVIN: 15 privilege. 15 Q. Okay. Ma‘am, do you ~ what's your 16 BY MR. KUVIN: 16 definition of the word "sex"? 17 Q. Would you agree with me that you've seen 17 MR. RHEINHART: Object to the form of the 18 Jeffrey Epstein have sex with girls on his plane in 18 question and instruct the witness not to answer 19 your presence during flights to Paris? 19 based on her Fifth Amendment privilege. 20 MR. RHEINHART: Same objection previously | 20 THE WITNESS: On the instruction of my 21 stated, and it assumes facts that have not been a1 lawyer, I must invoke my Fifth Amendment right. 22 established and instruct her not to answer 22 BY MR. KUVIN: 23 based on her Fifth Amendment right. 23 Q. Would you agree with me that the word 24 THE WITNESS: On the instruction of my 24 “sex" means both vaginal intercourse as well as oral 2s lawyer, I must invoke my Fifth Amendment 25 sex? Would you agree with that definition? Page 58 Page 60% i privilege. 1 MR. RHEINHART: You can answer that. 2 BY MR, KUVIN: 2 THE WITNESS: No. 3 Q. Ma'am, isn't it true that you've seen 3 BY MR. KUVIN: 4 Jeffrey Epstein and Jean-Luc Brunel have sex with 4 Q. Okay. Would you agree with me that sex, 5 girls under the age of 14 on Mr. Epstein's plane on 5 for the purpose of our questions here today, will be 6 flights to Paris? 6 limited strictly to vaginal intercourse? a MR. RHEINHART: Objection to the form. 7 A. Sorry. Can you repeat that’? 8 It's compound, as to several answers all at the 8 Q. Yes. For the purpose of my questions here 9 same time and certain facts, and instruct her 9 today, will you agree that the word "sex" will be lo not to answer based on her Fifth Amendment. 10 limited to vaginal intercourse between a man's penis iL THE WITNESS: On the instruction of my 1. and a woman's vagina? 12 lawyer, I must invoke my Fifth Amendment 12 MR. RHEINHART: If you're instructing her |: 13 privilege. 13 that in the future she should assume that 14 BY MR. KUVIN: 14 that's what you mean by your question, that's 1s Q. Ma'am, isn't it true that you have had sex i5 fine. 16 with Jeffrey Epstein on his plane? 16 MR. KUVIN: Okay. 17 MR. RHEINHART: Instruct the witness not 17 MR. RHEINHART: If that's what you mean, | 18 to answer based on the Fifth Amendment 18 then that's understood. 19 privilege, also object to the form of the 19 MR. KUVIN: That's what I mean. 20 question as compound and ambiguous. 20 MR. RHEINHART: Okay. 21 THE WITNESS: On the instruction of my 21 MR. KUVIN: All right. Let's go with that 22 lawyer, I must invoke my Fifth Amendment right. | 22 definition. And for the purposes of my 23 BY MR. KUVIN: 23 questions, "oral sex” will mean contact between. 24 Q. Isn't it true that you've had sex with 24 an individual's mouth and a man's sexual organ, (561) 832-7500 Jeffrey E, is? PROSE COURT REPORTING AGENCY, is. Fi ough? 15 (Pages .57 to 60) (561) 832-7506 INC.

WOYMHAU WN (561) MR. RHEINHART: Understood. MR. KUVIN: Okay. BY MR. KUVIN: Q. Working with those definitions if we could, would you agree with me that you had sex with Jeffrey Epstein on his plane? MR. RHEINHART: Objection to the form. It's compound and instruct her not to answer based on the Fifth Amendment privilege, because to do so would implicitly admit that she’s ever met Jeffrey Epstein in her life, and se as to that she's invoking the Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Would you agree with me that you have had oral sex with Jeffrey Epstein on his plane? MR. RHEINHART: Same objection stated to the previous question. It's compound and it assumes facts that's not been established as to which she is invoking her Fifth Amendment privilege. THE WITNESS: On the instruction of my Page 62 lawyer, i must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Would you agree with me that you have had sex with Jeffrey Epstein in his home -MR. RHEINHART: Object to the -MR. KUVIN: -- here in West Palm, in West Palm Beach? MR. RHEINHART: I'll instruct the witness not to answer based on her Fifth Amendment privilege and same objection previously stated to the last two questions. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Would you agree with me that you have had oral sex with Jeffrey Epstein in his home in West Palm Beach? MR. GARCIA: Is it West, or Palm Beach? MR. KUVIN: Palm Beach Island, I think it's, because -- yeah, for clarity, his home on Palm Beach. MR. RHEINHART: Object to the form. It assumes facts as to her knowledge of. 832-7500 OOIWIHAUBWNHE PROSE COURT REPORTING AGENCY, Page 636 Mr. Epstein's residence, as to her knowledge of Mr. Epstein and other facts as to which she's invoking her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must to invoke my Fifth Amendment privilege. MR. KUVIN: Let me show you what we'll mark as Exhibit 6. And this one I'm going to show if to the camera real briefly, if I could. Okay. MR. RHEINHART: Let me see it. Thank you. (Plaintiff's Exhibit No. 6 was marked for f identification.) BY MR. KUVIN: Q. Ma‘am, do you recognize any of the girls shown in Exhibit 67 MR. RHEINHART: I'll instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that that is you on the right in this photograph, the far right? MR. RHEEFNHART: I'll instruct the witness Page 64 ff not to answer. THE WITNESS: On the instruction of my Jawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Would you agree with me that that is Nadia Marcinkova on the left in that photograph that we marked as Exhibit 6? MR. RHEINHART: Same instruction. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. How old are you in this photograph? MR. RHEINHART;: Same instruction. THE WITNESS: On the instruction of my lawyer, { must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. How old is Nadia Marcinkova in this photograph, if you know? MR. RHEINHART: I'm going to object to the form in that it assumes facts as to her |* knowledge of anything about Ms. Marcinkova, and as to which she i is invoking her Fifth Amendment LE 16 (Pages 61 to 64) (561) 832-7506 INC.

Page 65 Page 67h i privilege. 1 THE WITNESS: On the instruction of my 2 THE WITNESS: On the instruction of my 2 lawyer, I must invoke my Fifth Amendment 3 lawyer, | must invoke my Fifth Amendment 3 privilege. 4 privilege. 4 BY MR. KUVIN: 5 MR. KUVIN: This is Exhibit 7. Let me 5 Q. Would you agree with me that Haley Robson 6 show you what we'll mark as Exhibit 7. 6 has been to Mr, Epstein's home on hundreds of ih (Plaintiffs Exhibit No. 7 was marked for 4 occasions? 8 identification.) & MR. RHEINHART: Object to the form as 9 BY MR. KUVIN: 9 compound and also assumes knowledge as this 10 Q, Do you recognize the girl that's shown in 10 witness has and instruct her to invoke her a2 Exhibit 7? 42 Fifth Amendment privilege relating to 12 MR. RHEINHART: I need to consult with her 12 Ms. Robson. 13 one second, 13 THE WITNESS: On the instruction of my 14 MR. KUVIN: Sure. 14 lawyer, I must invoke my Fifth Amendment as THE VIDEOGRAPHER: Are we off the record?; 15 privilege, 16 MR. KUVIN: No, no. 16 BY MR. KUVIN: 17 MR. RHEINHART: instruct the witness to 17 Q. Would you agree with me that you directed 18 invoke her Fifth Amendment privilege as to 18 Haley Robson on hundreds of occasions to bring girls 19 Exhibit 7. 19 under the age of 16 to Mr. Epstein's house? 20 MR. KUVIN: She's clipped up. Okay. 20 MR. RHEINHART: Object to the form of the 21 MR. RHEINHART: Now you have to answer. 2i question as compound and ambiguous and assuming }} 22 THE WITNESS: On the advice of my lawyer, 22 facts as to which there is no factual basis 23 E must invoke my Fifth Amendment privilege. 23 that this witness has any knowledge and 24 BY MR. KUVIN: 24 instruct the witness not to answer based on her 25 Q. Would you agree with me that the girt 25 Fifth Amendment privilege. Page 66 Page 68 ff i shown in Exhibit 7 is Haley Robson? 1 THE WITNESS: On the instruction of my 2 MR. RHEINHART: Instruct the witness not 2 lawyer, [ must choose to invoke my Fifth 3 to answer based on the Fifth Amendment 3 Amendment right. 4 privilege. 4 BYMR.KUVIN: © 5 THE WITNESS: On the instruction of my 5 Q. Would you agree with me that on hundreds 6 lawyer, I must invoke my Fifth Amendinent 6 of occasions you directed Haley Robson to bring 7 privilege. 7 underage girls under the age of 16 to Mr. Epstein's 8 BY MR. KUVIN: 8 home for sex with Mr. Epstein? 9 Q. Do you agree with me that Haley Robson was 9 MR. RHEINHART: Object to the form. Its 10 under the age of 16 when she was first asked to go 10 compound and it assumes facts as to this — 11 to Mr. Epstein's home? 11 that this witness has no personal knowledge, 12 MR. RHEINHART: Objection to the form. It | 12 and it's been established by this record, and 13 assumes any knowledge by this witness as to the 13 instruct her to invoke her Fifth Amendment 14 person you identified as Haley Robson. it's 14 privilege. 15 compound and I would instruct her not to answer is THE WITNESS: On the instruction of my 16 based on her Fifth Amendment privilege. 16 lawyer, I must invoke my Fifth Amendment 17 THE WITNESS: On the instruction of my 17 privilege. 18 lawyer, I must invoke my Fifth Amendment 18 MR. KUVIN: We'll mark this as Exhibit 8. 19 privilege. 19 (Plaintiff's Exhibit No. 8 was marked for 20 BY MR. KUVIN: 20 identification.) 21 Q. Would you agree with me that you know al BY MR. KUVIN: 22 personally Haley Robson? 22 Q. Ma'am, do you recognize the person that's 23 MR. RHEINHART: Instruct the witness not 23 shown in Exhibit 87 (561) 832-7500 to answer based on the Fifth Amendment privilege. PROSE COURT REPORTING AGENCY, MR. RHEINHART: Let me consult one second. MR- KUVIN: Suré. B 17 (Pages 65 ‘to 68) INC. (561) 832-7506

DARN bwWre Page 69 MR. RHEINHART: I instruct the witness not to answer the question based on her Fifth Amendment privilege. THE WITNESS: Based on the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that the person shown on Exhibit 8 is you? MR. RHEINHART: Same instruction. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Would you agree with me that this is a modeling shot of you that was taken through one of Mr. Epstein's modeling agencies? MR. RHEINHART: Object to the form of the question as compound and assuming facts as to which there has been no basis that this witness has any personal knowledge, and she's going invoke her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. OMAK RWKE Page 71k MR. GARCIA: He didn't make a Fifth Amendment objection. So can we just rephrase the question? MR. RHEINHART: I would instruct the witness not to answer based on the Fifth Amendment privilege to clarify. MR. KUVIN: Okay. Let's mark this as Exhibit 9. MR. RHEINHART: And for the record, the basis is that it assumes her knowledge of anything relating to Jeffrey Epstein, the question assumed that. (Plaintiff's Exhibit No. 9 was marked for identification.) BY MR. KUVIN: Q. Ma'am, do you recognize the girl shown in Exhibit 9? MR. RHEINHART: I'll instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that the girl shown in Exhibit 9 is Nadia Marcinkova? (561) Page 70 BY MR. KUVIN: Q. Would you agree with me that you were under the age of 18 in this photograph we've marked as Exhibit 8? MR. RHEINHART: Same objection as to the previous question and same instruction. THE WITNESS: On the instruction of my jawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that you were under the age of 17 in this photograph that we've marked as Exhibit 87 MR. RHEINHART: Same objection as the previous two question and the same instruction. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that Jeffrey Epstein kept this photograph of you in his home, if you know. MR. RHEINHART: Object to the form of the question as compound and ambiguous, and I would instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must invoke e my E Fifth, Amendment right. Page 72 MR. RHEINHART: Same instruction. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. MR. KUVIN: I forgot to do one more thing. Tf you could give that back to me for just one second just for the record so we can see what we're talking about here. Okay. I will give you back Exhibit 9. MR. RHEINHART: Thank you. BY MR. KUVIN: Q. Would you agree with me that this photograph of Nadia Marcinkova was taken when she # was under the age of 187 MR. RHEINHART: Objection to the form. It assumes this witness has any knowledge that the person in the photograph is, in fact, Nadia Marcinkova. Therefore, it's ambiguous and compound, and I'll instruct her not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that the girl 18 (Pages 69 to 72) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 73 Page 75h 1 shown in that photograph -- strike that. 1 implicitly assumes that she does, I would. 2: Would you agree with me that this 2 instruct her not to answer it based on her 3 photograph was kept by Jeffrey Epstein in his home? 3 Fifth Amendment privilege. 4 MR. RHEINHART: Objection to the form as 4 THE WITNESS: Upon the instruction of my 5 to being compound in that it assumes that she 5 lawyer, I must invoke my Fifth Amendment 6 has any knowledge of Jeffrey Epstein or his 6 privilege. 7 home, and [ would instruct her not to answer 7 BY MR. KUVIN: 8 based on her Fifth Amendment. 8 Q. Ma'am, are you aware of the effect, the 9 THE WITNESS: On the instruction of my 9 emotional effect on the underage girls that have 10 lawyer, I must invoke my Fifth Amendment right. | 10 been abused by Jeffrey Epstein? Are you aware of ail BY MR. KUVIN: il the emotional effect that it's had on the underage 12 Q. Would you agree with me that 12 girls that have been abused by Jeffrey Epstein? 13 Nadia Marcinkova was under the age of 16 when this | 13 MR. RHEINHART: Objection to the form as 14 photograph was taken in Exhibit 97 14 to, again, the question assumes this witness TS MR. RHEINHART: Objection to the form as 15 has any knowledge, first, of Jeffrey Epstein, 16 compound and also assuming this witness has any | 16 second that Jeffrey Epstein has sexually abused 17 knowledge that the person in the photograph is, 17 anyone ever, and third, that anyone has been 18 in fact, Nadia Marcinkova. Therefore, | would 18 damaged by anything that Jeffrey Epstein has 19 instruct her to invoke her Fifth Amendment 19 done, and fourth, that she would somehow have 20 privilege. 20 any knowledge of these people's emotional 21 THE WITNESS: On the instruction of my 21 situations. For all those reasons, the q 22 lawyer, { must invoke my Fifth Amendment right. | 22 question is ambiguous and compound, and I would } 23 BY MR. KUVIN: 23 instruct her not to answer based on her Fifth 24 Q. Ma'am, is Jeffrey Epstein paying for your 24 Amendment. 25 attorney today? 25 THE WITNESS: Upon the instruction of my Page 74 Page 76 1 MR. RHEINHART: I'll instruct the witness 1 lawyer, I must invoke my Fifth Amendment right. 2 not to answer based on her Fifth Amendment 2 BY MR, KUVIN: E 3 privilege. 3 Q. Ma'am, do you have any regret for what 4 THE WITNESS: On the instruction of my 4 you've done? 5 tawyer, I must invoke my Fifth Amendment right. 5 MR. RHEINHART: Objection to the form. 6 BY MR. KUVIN: 6 That question is not designed to lead to 7 Q,. Ma'am, is Jeffrey Epstein paying for you 7 discoverable evidence. It's meant solely for 8 to keep quiet with respect to the things he has done 8 the purpose of harassment, and I would instruct 9 to underage girls? 9 her not to answer. 10 MR. RHEINHART: Objection to the formin {| 10 BY MR. KUVIN: iL that it's ambiguous and compound, also assumes aL Q. Ma'am, do you have any regrets for what 12 this witness has any knowledge at all of 12 Jeffrey Epstein has done through you in obtaining 43 Jeffrey Epstein, and therefore I am instructing 13 underage girls for sexual abuse? 14 her to invoke her Fifth Amendment privilege. 14 MR. RHEINHART: Same objection as the 15 THE WITNESS: On the instruction of my 15 previous question as well as that question is 16 lawyer, I must invoke my Fifth Amendment 16 now free to assume this witness has any At privilege. 17 knowledge at all of Jeffrey Epstein or 18 BY MR. KUVIN: 18 Jeffrey Epstein having abused any underage 19 Q. Ma'am, how much is Jeffrey Epstein paying 1g women or girls or anything else that 20 you to keep quiet with respect to things he's done 20 Jeffrey Epstein may ever have done. 21 to underage girls? 21 And therefore, since it assumes that 22 MR. RHEINHART: Object to the form as 22 fact, I would instruct her not to answer 23 multiple compound questions, and it's again 23 based on her Fifth Amendment. 24 assuming this witness has any knowledge at alt 24 BY MR. KUVIN: 25 of Jeffrey Epstein. Since the question 25 Q. Are you scared of Jeffrey Epstein? re RR TR ORS SS TET TTT PTT Ea TR TE TT CR TITS 19 (Pages 73 to 76) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 77 Page 798 1 MR. KUVIN: I'm sorry, you had to respond. a: lawyer, and I must invoke my Fifth Amendment 2 I cut you off. 2 privilege. 3 THE WITNESS: Upon the instruction of my 3 BY MR. KUVIN: 4 lawyer, | must invoke my Fifth Amendment right. 4 Q. Do you know who Les Wexner is? 5 BY MR. KUVIN: 5 MR. RHEINHART: I'll instruct the witness 6 Q. Are you scared of Jeffrey Epstein? 6 not to answer based on her Fifth Amendment ef MR. RHEINHART: Objection to the form in. 7 privilege. 8 that it assumes this witness has ever met 8 THE WITNESS: On the instruction of my 9 Jeffrey Epstein in her life, Because it 9 lawyer, I must invoke my Fifth Amendment 10 assumes that, I would instruct her not to 10 privilege. ai answer based on the Fifth Amendment. 11 BY MR. KUVIN: 12 THE WITNESS: On the instruction of my 12 Q. Do you know whether or not Mr. Epstein has 13 lawyer, I must invoke my Fifth Amendment right. | 13 had a homosexual relationship with Les Wexner in the ia BY MR, KUVIN: 14 past? i 1s Q. Are you aware of Jeffrey Epstein's sexual 15 MR, RHEINHART: Objection to the form in 16 obsession for children? 16 that it again assumes that this witness knows 17 MR. RHEINHART: Same instructions as the 17 anything at all about Jeffrey Epstein or has 18 previous question, also objection to the 18 ever met Jeffrey Epstein in her life, and 19 question. It's not designed to lead to any 19 therefore, I would instruct her not to answer 20 discoverable evidence at all. It's simply 20 based on her Fifth Amendment privilege, and the 24 meant for harassment. 21 question is compound and ambiguous. 22 THE WITNESS: On the instruction of my 22 THE WITNESS: On the instruction of my 23 lawyer, 1 must invoke my Fifth Amendment 23 Jawyer, { must invoke my Fifth Amendment 24 privilege. 24 privilege. 25 25 + H Page 78 Page 80 f i BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. At what point did you realize that 2 Q. Do you know the magician by the name 3 Jeffrey Epstein was sexually attracted to girls 3 David Copperfield? 4 under the age of 18? 4 MR. RHEINHART: I'll instruct the witness 5 MR. RHEINHART: Once again, the question 5 not to answer based on her Fifth Amendment 6 assumes this witness knows anything at ali 6 tight. 7 about Jeffrey Epstein, underage women, sexual 7 THE WITNESS: On the instruction of my 8 abuse of underage women, and she's not going fo 8 lawyer, I must invoke my Fifth Amendment 9: answer any questions that assume that as a 9 privilege. 10 predicate. They are objectionable as ambiguous 10 BY MR, KUVIN: Ly and compound, and I instruct her not to answer. Lf. Q. You are aware, are you not, that 12 THE WITNESS: On the instruction of my 12 David Copperfield has visited Jeffrey Epstein's home [ 13 lawyer, I must invoke my Fifth Amendment 13 in Palm Beach? 14 privilege. 14 MR. RHEINHART: Objection to the formas 15 BY MR. KUVIN: is it once again assumes she has some knowledge of § 16 Q. Are you aware whether or not 16 Jeffrey Epstein, or whether he has a home in 17 Jeffrey Epstein has had any homosexual relationships | 17 Palm Beach. Because those facts are implicit 18 in the past? 18 in the question, the question is ambiguous and 19 MR. RHEINHART: Same objection as the is compound. I would instruct her not to answer 20 previous question. The question as stated 20 based on her Fifth Amendment. 21 assumes this witness has some knowledge of 21 THE WITNESS: On the instruction of my 22 Jeffrey Epstein. And since it assumes that 22 lawyer, I must invoke my Fifth Amendment 23 fact, it is ambiguous and it's compound, and [ 23 privilege. 24 instruct her not to answer. 24 BY MR. KUVIN: 25 THE WITNESS: On the instruction of my 25 Q. You are aware, are you not, that TEST SST ST ES RTE SS TEE ETP TT EEE eS ET TTT TT ST PO ST (561) 832-7500 PROSE COURT REPORTING AGENCY, 20 (Pages 77 to 80) Inc. (561) 832-7506

Page 81 1 David Copperfield and Jeffrey Epstein used to share 2 for sexual -- for sex, girls under the age of 167 3 MR. RHEINHART: Same objection as 4 previously stated to the last I don't know how 5 many questions. This question again assumes 6 this witness knows Jeffrey Epstein, has any 7 knowledge of Jeffrey Epstein's life. And 8 because it assumes that fact, there is an 9 underlying predicate it is ambiguous and 10 compound. I would isstruct her not to answer. il THE WITNESS: On the instruction of my 12 lawyer, { must invoke my Fifth Amendment 13 privilege. 14 BY MR. KUVIN: is Q. From the time you met Mr. Epstein, isn't 16 it true that he would arrange for underage girls, 17 girls under the age of 18, to have sex with every 18 single day? 19 MR. RHEINHART: Let me try this again. 20 Objection to the form. Any question you're 21 going to ask her that assumes she knows 22 Jeffrey Epstein, she's ever met Jeffrey 23 Epstein, she's ever seen Jeffrey Epstein, knows where he lives, knows what he does, if it assumes that as part of the question, I will Page 82 1 deem the question to be ambiguous and compound, 2 because you're asking her to admit as a 3 predicate that she knows Mr. Epstein. As to 4 any question like that, 1 am going to instruct 5 her to take the Fifth Amendment on that basis. 6 So I would again instruct her to take the Fifth 7 Amendment as to that question. 8 THE WITNESS: On the instruction of my 9 lawyer, I must invoke my Fifth Amendment 10 privilege. 11 MR. KUVIN: [f you want to short circuit 12 that, anytime 1 mention Jeffrey Epstein you can 13 have a standing objection on that issue. I 14 have no problem. 15 MR. RHEINHART: Great. 16 BY MR. KUVIN: 17 Q. Can you explain, if you would, to a jury 18 how Mr, Epstein would access underage minor females 19 for sex every day? 20 MR. RHEINHART: The question is compound 24 in that it asks about Mr. Epstein every day, 22 underage females, and involves multiple 23 questions in the same question, and also based on the standing objection, I would instruct her hot to answer based on her Fifth Amendment (561) 832-7500 PROSE COURT REPORTING AGENCY, 1 privilege. 2 THE WITNESS: On the instruction of my 3 lawyer, I must invoke my Fifth Amendment 4 privilege. 5 BY MR, KUVIN: 6 Q. How many people did Jeffrey Epstein use to } ba help him bring minor females to his house in Palm 8 Beach for sex? ; 9 MR. RHEINHART: Same objection as the 10 previous question and I instruct her not to 1 answer. 12 THE WITNESS: On the instruction of my 13 lawyer, I must invoke my Fifth Amendment 14 privilege. 15 BY MR. KUVIN: 16 Q. Do you agree that Jeffrey Epstein is a 17 child molester? 18 MR. RHEINHART: That question is solely 19 intended to harass the witness and it's 20 ambiguous as to what a child molester means, 21 and you're asking for a legal conclusion and 22 instruct her not to answer. 23 BY MR. KUVIN: Q. in your own opinion. H MR. RHEINHART: I will again instruct her Page 84 fj alt not to answer based on her Fifth Amendment 2 privilege as well as the question having no 3 legitimate basis and will not fead to 4 discoverable evidence, 5 THE WITNESS: On the instruction of my 6 lawyer, I must invoke my Fifth Amendment 7 privilege. 8 BY MR. KUVIN: 9 Q. Would you agree that Jeffrey Epstein is 10 obsessed with underage fernales? 1. MR. RHEINHART: Objection to the form. 12 It's ambiguous as to what you mean by 13 "obsessed." I'll instruct the witness not to 14 answer based on her Fifth Amendment privilege, 5 15 because the question assumes knowledge of f 16 Jeffrey Epstein. 17 THE WITNESS: On the instruction of my 1s lawyer, I must invoke my Fifth Amendment 19 privilege. 20 BY MR. KUVIN: 21 Q. How would you define the word "obsessed"? |} 22 MR. RHEINHART: You can answer that, 23 THE WITNESS: I don't know. You like ita | lot. I don't know. (Pages 81 to 84) (561) 832-7506 21 INC.

Page 65 BY MR. KUVIN: Q. Okay. Using your definition of obsessed, would you agree with me that Jeffrey Epstein was obsessed with underage females? MR. RHEINHART: Same objection; same instruction. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. When was the first time that you learned Mr. Epstein was getting a massage from a girl under the age of 16? MR. RHEINHART: One second. MR. KUVIN: Sure. MR. RHEINHART: I want to make the standing objection for the reasons previously stated, the question is otherwise also compound. in that it assumes multiple facts and asks her to answer multiple questions at the same time. Til instruct her not to answer based on her Fifth Amendment. THE WITNESS: On the instruction of my lawyer, [ must invoke my Fifth Amendment privilege. ODI DAN SWOPE Page 87} lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Did you keep a journal with the names of girls in it in the year 2005? MR. RHEINHART: Objection to the form as ambiguous. What do you mean by "journal"? MR. KUVIN: I will define it. MR. RHEINHART: Please. BY MR. KUVIN: Q. Did you keep a pad of paper, either a fi ringed notebook or some other format with the names of girls and their phone numbers in it in 20057 MR. RHEINHART: I'll instruct the witness not to answer based on her Fifth Amendment privilege. Also the question remains ambiguous. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Would you agree with me that you kept a pad of paper or a journal, however you want to describe it, that contain the names of hundreds of underage girls and their phone numbers? Page 86 BY MR. KUVIN: Q._ Do you know who owns the home at 358 El Brillo Way? MR. RHEINHART: Same instructions as to the standing objection. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Have you been on Palm Beach Island before? MR. RHEINHART: [am sorry. Can you restate the question? MR. KUVIN: Sure. BY MR. KUVIN: Q. Have you been on the Island of Palm Beach before? MR. RHEINHART: You can answer that yes or no. THE WITNESS: Yes. BY MR. KUVIN: Q. How many times? MR. RHEINHART: I'll instruct her not to answer that question based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my Page 88; MR. RHEINHART: Object to the form of the Eo question. It's compound and asking her to answer multiple questions at the same time. It's also leading, and f would instruct her not to answer based on her Fifth Amendment. THE WITNESS: On the instruction of my lawyer, { must invoke my Fifth Amendment right. BY MR. KUVIN: fi Q. Would you agree with me that you kept a } pad of paper, notebook, or journal with the names of [ hundreds of girls under the age of 16 so that you t, could contact them and have them come to Jeffrey Epstein's home for sex with him? MR. RHEENHART: Objection to the form as compound and ambiguous, and I'll instruct her not to answer based on Fifth Amendment. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Do you know Alfredo Rodriguez? MR. RHEINHART: I'll instruct the witness not to answer based on her Fifth Amendment | privilege. } THE WITNESS: On the instruction ofmy _{] (561) 832-7500 TE TE RT TT TR TE RP TOR aa TERT TS ES TN A ESE PROSE COURT REPORTING AGENCY, 22 (Pages 85 to 88) INC. (561) 832-7506

(561) 832-7500 Page 89 lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Are you aware that Alftedo Rodriguez has pled guilty to federal charges for hiding a journal containing the names of women? MR. RHEINHART: Objection to the form as compound and instruct her not to answer. THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth Amendment privilege. BY MR, KUVIN: Q. Do you have a personal fear of criminal prosecution as you sit here today? MR. RHEINHART: I instruct the witness -object to the form. That's the whole basis why one would invoke the Fifth Amendment so clearly she's does. I am not going to have her answer the question. It's solely meant to harass. MR. KUVIN: So is she not going to answer that question? MR. RHEINHART: She's not going to answer that question. MR. KUVIN: I think what I need to establish is that she personally has a fear, Page 90 not her lawyer. So I would like to establish whether the witness has a personal fear. MR. RHEINHART: Well, first of all, under the Fifth Amendment you don't have to be in fear. You just have to believe that the government believes you can be prosecuted for something. She's been invoking the Fifth Amendment on her own. It is implicit in her invocation in what she fears. She's not going to answer that question. MR. KUVIN: Well, I tend to disagree. She hasn't been invoking it on her own. She's been invoking it after you have instructed her to invoke it. So | want to know her personal -MR. RHEINHART: You can take that up with the judge then. She's not answering the question. She's invoking her Fifth Amendment on her own accord based on the advice of her lawyer. And you can take it up somewhere else, but she's not answering that question. MR. KUVIN: Weil, then let me clarify the record. BY MR. KUVIN: Q. Ma'am, are you invoking your Fifth Amendment because you personally have a concern of SUYATeBWNP RNUNRANRE EEE Eee ASWWPFOLCMYANe&WNHROO WDIRNRWNME PROSE COURT REPORTING AGENCY, Page 91 prosecution by either the State or the federal government? MR. RHEINHART: She's not answering that question. She’s not required to answer the question. She's invoked her Fifth Amendment privilege. She will continue to do so as to that question. You can move on. BY MR. KUVIN: Q. Ma'am, are you invoking your Fifth Amendment because your lawyer is advising you to invoke your Fifth Amendment, or because you personally have a fear that you might be prosecuted by either the state or the federal government? MR. RHEINHART: We bave now been down this street four times. She's not going to answer the question. You can move along or we can leave. MR. KUVIN: Iam just clarifying the question, and I appreciate it, And you can object. [ just want to make sure that I have a clear record of every possible machination of the question so that I don't get hit later with you didn't ask the specific question you need to ask, So, I'm not doing it certainly to harass, I just want to make sure that the Page 92 record is very clear of my question. MR. RHEINHART: [| understand. Youcan § move on. BY MR. KUVIN: Q. Ma'am, have you had any direct communications with the State Attorney's office in the last two years? MR. RHEINHART: When you say "direct communications," can you clarify? MR. KUVIN: Yes. BY MR. KUVIN: Q. You, personally, have you spoken with anyone in the State Attorney's office in the last two years? MR. KUVIN: I can't imagine there would be a Fifth Amendment for that. MR. RHEINHART: Let me consult. If might. Okay? MR. KUVIN: Sure. MR. RHEINHART: It would all depend on what was said to her if she could consult with them now. For example, if they consulted and they told her they were about to prosecute, then there could be a Fifth Amendment claim, couldn't there? 23 (Pages 89 t (561) 832-7506 Inc. Chengespeepeeees © 92)

whether or not you ever were requested to give a statement by the State Attomey’s office for the 10 Palm Beach Police Department? Page 93 1 MR. KUVIN: No, not as to the statements 2 they told her. I mean, that's certainly not 3 Fifth Amendment. That's something that was 4 told to her. 5 MR. RHEINHART: We'll take that up 6 elsewhere if you need to. You can answer. 7 MR. KUVIN: Okay. 8 THE WITNESS: No, I have not. 9 BY MR. KUVIN: 10 Q. Allright. Ma‘am, have you had any 11 personal communications with anyone working for the 12 federal government in the last two years? 13 MR. RHEINHART: When you say “the federal 14 government” do you mean the postal service, the 15 entire federal government, or do you want to 16 clarify that? 17 MR. KUVIN: Well, I certainly could leave 18 it open-ended. If she’s talked to a post 19 office employee, that would be interesting, but 20 certainly not to this case. 21 BY MR. KUVIN: 22 Q. Let's talk about the U.S. Attomey's 23 Office or anyone working on behalf of the U.S. 24 Attorney's Office. 25 A. Have I personally ever spoken to anyone? Page 94 1 Q. Yes, ma'am, personally have you ever had 2 any conversations with anyone at the U.S. Attorney's 3 Office or one of their -- one -- a person. 4 representing to be from that office in the last two 5 years, 6 A. No. 7 Q. Okay. Do you know, as you sit here today, 8 9 11 MR. RHEINHART: May I consult? 12 MR. KUVIN: Yes. 13 MR. RHEINHART: You may answer. And for 14 the record, I was just determining whether the 15 answer to that question would be protected by 16 the attomey-client privilege. Lit MR. KUVIN: Understood. 18 THE WITNESS: No, I don't. [ don't know. 19 BY MR, KUVIN: 20 Q. Let me clarify the last two questions I 21 asked about the State Attorney's Office and the U.S. 22 Attorney's Office. Have you spoken with anybody 23 personally at the State Attorney's Office in the last five ee (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 1 Q. Have you spoken with anybody at the U.S. 2 Attomey's Office in the last five years? 3 A. No. 4 Q. Have you spoken with anyone at the FBI in 5 the last five years? 6 A. No. 7 Q. Have you spoken with anyone at the 8 Patm Beach Police Department in the last five years? 9 MR. RHEINHART: When you say, “the Palm 10 Beach Police,” for any purpose or as related to 11 this case? Again, for example, if there was 12 like a parking ticket -13 MR, KUVIN: Sure. 14 MR. RHEINHART: - or some other thing, I is want to clarify that. 16 BY MR. KUVIN: 17 Q. Let's, let's start with broad, and we can. 18 work to specific. Can you recall having any 19 conversations for any reason with the Palm Beach 20 Police Department in the last five years? al A. No. 22 Q. Okay. Do you have knowledge whether or H 23 not the Palm Beach Police Department ever requested |! for you to come in for an interview at any time in the last five years? Page 96 i MR. RHEINHART: If you know the answer to f 2 that question because that’s something your i 3 attorney toid you, you don't have to answer 4 that question. Otherwise, go ahead and answer. 3° THE WITNESS: No. 6 BY MR. KUVIN: 7 Q. Okay. When did you first retain an 8 attormey? What date did you first retain a -- 1 9 mean, let me clarify. What date did you first 10 retain a criminal attorney? aL MR. RHEINHART: I'll instruct her not to 12 answer based on the Fifth Amendment privilege. 13 THE WITNESS: On the instruction of my 14 Jawyer, I must invoke my Fifth Amendment 18 privilege. 16 BY MR. KUVIN: 17 Q. Did you first retain a criminal attorney 18 in the year 2005? 13 MR. RHEINHART: Same instruction. 20 THE WITNESS: On the instruction of my 21 lawyer, I must invoke my Fifth Amendment 22 privilege. 23 BY MR. KUVIN: 3 Did you retain a criminal attorney in Pages’ 93, to 96) (561) 832-7506 24

Page 97 Page 99 1 MR. RHEINHART: Same instruction. 1 assumes facts that have not been established 2 THE WITNESS: On the instruction of my 2 and it's compound. 3 lawyer, I must invoke my Fifth Amendment 3 THE WITNESS: On the instruction of my 4 privilege. 4 lawyer, I must invoke my Fifth Amendment 5 BY MR. KUVIN: 5 privilege. 6 Q. Have you ever worked as a professional 6 MR. RHEINHART: And to clarify the 7 model? 7 objection is that it assumes that she's ever 8 MR. RHEINHART: May I consult? 8 met or knows anything about Jean-Luc Brunel. 9 MR. KUVIN: Sure. 9 BY MR. KUVIN: 10 MR. RHEINHART: You can answer the 10 Q. Were you ever promised anything regarding al question. 1i your modeling career by Jeffrey Epstein? 12 THE WITNESS: Yes. 12 MR. RHEINHART: Same objection, instruct 13 BY MR. KUVIN: 13 the witness not to answer. 14 Q. When? 14 THE WITNESS: On the instruction of my 15 A. Idon't remember. I don't remember the dates. | 15 lawyer, 1 must invoke my Fifth Amendment 16 It was at least maybe ten years ago. 16 privilege, 17 Q. And you're how old now? 17 BY MR. KUVIN: 18 MR. RHEINHART: I'll instruct the witness 18 Q. You would agree with me that there is a 19 not to answer the question. Nice try. ig financial arrangement between Jean-Luc Brunel and 20 Instruct you not to answer based on 20 Jeffrey Epstein, do you not? 21 your Fifth Amendment privilege. 21 MR. RHEINHART: Objection. It assumes she 22 THE WITNESS: On the instruction of my 22 has any knowledge of either Mr. Epstein or 23 lawyer, I'm going to invoke my Fifth Amendment | 23 Mr. Brunel, and as to that she is going to 24 privilege. 24 invoke her Fifth Amendment privilege. The 25 MR. KUVIN: I'm just trying to find out. 25 question is compound and therefore ambiguous, Page 98 Page 100 L MR. RHEINHART: Like I said, good try. i THE WITNESS: On the instruction of my 2 Move on. 2 lawyer, I must invoke my Fifth Amendment 3 BY MR, KUVIN: 3 privilege. 4 Q. With respect to your work as a 4 BY MR. KUVIN: 5 professional model, what company did you work for?} 5 Q. Would you agree with me that 6 MR. RHEINHART: Instruct the witness not 6 Ghislaine Maxwell provides underage girls to 7 to answer based on the Fifth Amendment 7 Mr. Epstein for sex? i 8 privilege, 8 MR. RHEINHART: Objection to the form. It 9 THE WITNESS: On the instruction of my 9 assumes she knows anything at all about u 10 lawyer, I invoke my Fifth Amendment privilege. 10 Ghislaine Maxwell and asks her to assume that il BY MR. KUVIN: ii she does, and therefore it is compound and 12 Q. What is your understanding of 12 ambiguous, and I would instruct her not to 13 Mr. Epstein's involvement with the modeling 13 answer. 14 industry? 14 THE WITNESS: Upon the instruction of my is MR. RHEINHART: Standing objection, and i5 lawyer, I must invoke my Fifth Amendment 16 instruct the witness not to answer based on 16 privilege. 17 Fifth Amendment, on that basis. 17 MR. KUVIN: That's a good point. Take a 18 THE WITNESS: Upon the instruction ofmy | 18 look at what we'll mark as Exhibit 10. 19 lawyer, I must invoke my Fifth Amendment 19 (Plaintiff's Exhibit No. 10 was marked for 20 privilege. 20 identification.) 21 BY MR. KUVIN: 21 MR. KUVIN: All me to show it to the 22 Q. Were you ever promised anything regarding 22 camera first. 23 your modeling career by Jean-Luc Brunel? 23 MR. RHEINHART: Okay. 24 MR. RHEINHART: Instruct the witness not 24 MR. KUVIN: Okay. 25 to answer based on Fifth Amendment, also 25 THE WITNESS: Okay. TTT (561) 832-7500 SE TT TT A ST a RS RT SST TT TT aS TT RTC NO PROSE COURT REPORTING AGENCY, 25 INC. (Pages 97 to 100) (561) 832-7506

(561) is, and assumes she knows who Jeffrey Epstein i is the 832-7500 Page 101 Page 103 ue BY MR. KUVIN: 1 You're asking the witness three 2 Q. Take a took at what we marked as Exhibit 2 questions at the same time, and I would ) 10. Do you recognize the two people in that 3 instruct her not to answer based on the 4 photograph? 4 Fifth Amendment. 3 MR. RHEINHART: I'll instruct the witness 5 THE WITNESS: On the instruction of my 6 not to answer based on her Fifth Amendment 6 lawyer, I must invoke my Fifth Amendment 7 privilege. 7 privilege. 8 THE WITNESS: On the instruction of my 8 MR. KUVIN: Just so we're clear, had she 3 lawyer, I must invoke my Fifth Amendment 3 answered the first two questions, then 10 privilege. 10 obviously I wouldn't have to ask the third one 11 BY MR. KUVIN: li that has all of them in it but 12 Q. Wouid you agree with me that's 12 MR. RHEINHART: If you had accepted her }) 13 Ghislaine Maxwell on the right and Jeffrey Epstein | 13 answer, you would have known that she wasn't 14 on the left? 14 going to answer these, and we could have saved 15 MR. RHEINHART: Objection to the form. It} 15 a few minutes. 16 assumes that she knows who Ghislaine Maxwell | 16 MR. KUVIN: And as you well know, I must 17 and Jeffrey Epstein are, and therefore it's 17 ask the question in order to gain the inference 18 compound and ambiguous, and 1 would instruct 18 at trial. 19 her not to answer. 19 MR. RHEINHART: I understand. 20 THE WITNESS: On the instruction of my 20 MR. KUVIN: All right. 21 lawyer, I must invoke my Fifth Amendment 21 (Plaintiffs Exhibit No. 12 was marked for 22 privilege. 22 identification.) 23 MR. KUVIN: Okay. I will mark this as 23 BY MR. KUVIN: 24 Exhibit 11. 24 Q. Do you recognize the gentleman that is 25 25 shown -Page 102 Page 1048 sl (Plaintiff's Exhibit No. 11 was marked for 1 MR. RHEINHART: We'll have a job here. 2 identification.) 2 MR. KUVIN: That is true. 3 BY MR. KUVIN: 3 BY MR. KUVIN: 4 Q. Let me show you what we marked as 4 Q. ~ that is shown in Exhibit 127 5 Exhibit 11. Hang on one second, 5 MR. KUVIN: Let me hold this for the 6 MR. RHEINHART: Sure. 6 camera first. % BY MR. KUVIN: 7 MR. RHEINHART: I'm sorry. Is there a 8 Q. Do you recognize the young lady shown in 8 question pending? 9 Exhibit 11? 9 MR. KUVIN: Yes. 10 MR. RHEINHART; I'll instruct the witness 10 BY MR. KUVIN: iu LL not to answer based on her Fifth Amendment 11 Q. Do you recognize the gentleman shown in 12 privilege. 12 Exhibit 12? 413 THE WITNESS: On the instruction of my 13 MR. RHEINHART: I instruct her not to 14 lawyer, I must invoke my Fifth Amendment 14 answer based on the Fifth Amendment. 15 privilege. 15 THE WITNESS: On the instruction of my 16 BY MR, KUVIN: 16 lawyer, I must invoke my Fifth Amendment [ 17 Q. Do you agree with me that the young girl 17 privilege. 18 shown in Exhibit 11 was recruited by Ghislaine 18 BY MR. KUVIN: 19 Maxwell to, for sexual activity with 19 Q. Would you agree with me that that is 20 Jeffrey Epstein? 20 Prince Andrew shown in Exhibit 12? 21 MR. RHEINHART: Objection to the form. It 21 MR. RHEINHART: Same instruction. 22 assumes she knows who the person is in Exhibit 22 THE WITNESS: On the instruction of my 23 IL, and assumes she knows who Ghislaine Maxwell | 23 lawyer, I must invoke my Fifth Amendment PROSE COURT REPORTING AGENCY, privilege. 26 (Pages 101 to 104) INC, (561) 832-7506

Page 105 Page 107 1 BY MR. KUVIN: 1 break now. 2 Q. Would you agree with me that you have been 2 MR. KUVIN: Okay. E 3 present where Jeffrey Epstein and Prince Andrew have 3 THE VIDEOGRAPHER: We're now off video l 4 had sexual relations with underage girls? 4 record, The time is 11:57 a.m. $ MR. RHEINHART: Objection to the form, 5 (A luncheon recess was held.) 6 it's compound in that it assumes she knows who 6 (Plaintiffs Exhibit No’s 4 was marked for 7. the person is in Picture £2, she knows who 2 identification.) 8 Prince Andrew is, and she knows who Jefirey 8 (Plaintiffs Exhibit No. 5 was marked for 9 Epstein is. It's compound and ambiguous, and 9 identification.) ] 10 TIl instruct her not to ariswer based on her 410 * THE VIDEOGRAPHER: We're now on video al Fifth Amendment, 11 record. The time is 1:02 p.m. 12 THE WITNESS: On the instruction of my 12 MR. KUVIN: All right, counsel. I'm going 13 lawyer, | must invoke my Fifth Amendment 13 to ask a couple more general questions, and 14 privilege. 14 then when we get into the specifics of the is BY MR. KUVIN: 15 individual girls, I just want to make sure, 16 Q. Would you agree with me that Prince Andrew 16 once again, on the record, as we've done in 17 and Jeffrey Epstein used to share underaged girls 17 every deposition in this case, that we'll use 18 for sexual relations? 18 the Plaintiff's full name with the 19 MR. RHEINHART: Same objection previously | 19 understanding that the final transcript will 20 stated, requires her to also speculate who 20 only contain their initials, and there will be 21 Prince Andrew is. | instruct her not to answer 21 a key at the conclusion that's only provided to 22 based on the Fifth Amendment. 22 the parties in this case and their counsel to 23 THE WITNESS: On the instruction of my 23 be kept confidential going forward. But 24 lawyer, | must invoke my Fifth Amendment 24 obviously, for the purposes of this deposition, 25 privilege. 25 we will be using fail names. Page 106 Page 108 1 MR. RHEINHART: Also requires speculation at MR. RHEINHART: Agreed, 2 as to who Jeffrey Epstein is as well. 2 MR. KUVIN: Okay. Is there any 3 BY MR. KUVIN: 3 disagreement with that around the table? 4 Q. Do you know who Prince Andrew is? 4 MR. HOROWITZ: Agreed. 5 MR. RHEINHART: I'll instruct her not to 5 MR. WEISSING: Agreed. 6 answer based on the Fifth Amendment. 6 MS. EZELL: Agreed. 7 THE WITNESS: On the instruction of my 7 MR. KUVIN: Jack, do you agree to the -- i 8 lawyer, | must invoke my Fifth Amendment 8 MR. GOLDBERGER: I thought I'm not a part |} 9 privilege. 9 of it. 10 MR. KUVIN: It's almost 12:00, Do you 10 MR. KUVIN: Well, you've been playing a ait want to take a quick lunch? 1L part, so I want to make sure you agree. H 12 MR. RHEINHART: Sure. How much longer do| 12 MR. GOLDBERGER: Yeah, | agree. Lagree. [ 13 you think you will be, Mr. Kuvin, before we go 13 MR. RHEINHART: Hold on. Let me just 24 on to other counsel? 14 explain to her what we're talking about. 15 MR. KUVIN: Probably not that much longer. a5 MR. KUVIN: Please do. B 16 MR, RHEINHART: Okay. 16 MR. RHEINHART: But when the transcript is 17 MR. KUVIN: I have to get through a couple 17 typed up, it won't have her name it will just 18 of more generic stuff, and then get into the 18 have initials. But we'll get a code that 19 specifics of my cases and then -- 19 explains the name. So that way you would be 20 MR. RHEINHART: Okay. So, we, but just so 20 asked if you recognize the name not a set of 21 we have a sense of planning whether this is the 21 initials that you may not understand or a Jane 22 right time for a lunch break. You're not going 22 Doe number that you do not know. 23) to finish in the next 15 or 20 minutes? 23 MR. KUVIN: That's way too confusing. 24 MR. KUVIN: No, not even close. Okay? (561) 832-7500 MR. RHEINHART: Ts Okay. Let's ‘take a lunch PROSE COURT REPORTING AGENCY, MR. RHEINUART: Correct. 27 (Pages 105 ‘to 108) (561) 832-7506 INC.

Page 109 Page Lil 1 BY MR. KUVIN: 1 objection to the form. 2 Q. Let's take a look at what I've marked -- 2 THE WITNESS: At the instruction of my 3 premarked as Exhibit 4. It's a stack of documents, 3 lawyer, I must invoke my Fifth Amendment 4 just so you understand what this is and your 4 privilege. 5 attorney can object or agree or disagree as he sees 5 BY MR. KUVIN: 6 fit, but this is a stack of documents that was part 6 Q. Yes. Do you know Alex Hail? 7 of the trash pull from Jeffrey Epstein's home as 7 MR. RHEINHART: Instruct the witness not 8 part of the criminal investigation. Just so you're 8 to answer the question based on her Fifth 9 aware of what these are. 9 Amendment privilege. 10 MR. RHEINHART: That was retrieved, that 40 THE WITNESS: On the instruction of my 11 was retrieved by the Palm Beach Police il lawyer, | must exercise my Fifth Amendment 12 Department from the trash -- 12 privilege. 13 MR. KUVIN: That's correct. 13 BY MR. KUVIN: 14 MR. RHEINHART: ~ at the home of what is | 14 Q. Will you agree with me that on the first 15 known to be Mr. Epstein's home? is page of Exhibit 4, you were to arrange for roses to 16 MR. KUVIN: Correct. 16 be delivered to Jane Doe No. 103 at her high school 17 MR. RHEINHART: Okay. 17 performance? 18 MR. KUVIN: All right. And that's not a 18 MR. RHEINHART: Objection to the form. 19 question. I just wanted to kind of give you a 19 It's compound in that it assumes this is the 20 context for what I'm going to be asking you 20 witness's handwriting and assumes the witness 21 about. 21 knows a person by the name of Jane Doe No. 103 22 MR. RHEINHART: Thank you. 22 and the witness otherwise knows Jeffrey Epstein 23 BY MR. KUVIN: 23 whose name is at the bottom of the paper, and 24 Q. Allright. In taking a look at Exhibit 4, 24 therefore, it's compound and ambiguous, and 25 I'd like you to take a iook at the front page, the 25 instruct her not to answer. Page 110 Page 112 1 first page of those documents. 1 THE WITNESS: On the instruction of my 2 Is that your handwriting, ma'am? 2 lawyer, I must exercise my Fifth Amendment 3 MR. RHEINHART: Insiruct the witness not 3 right. 4 to answer based on the Fifth Amendment 4 MR. KUVIN: I forgot to mention this at 5: privilege. 5 the beginning, but objection to form usually 6 THE WITNESS: At the instruction of my 6 covers all that stuff like vague and compound, 7 lawyer, I must exercise my Fifth Amendment 4 and -8 right. 8 MR. RHEINHART: Okay. 9 BY MR, KUVIN: 9 MR. KUVIN: -- I'll leave it up to you, 10 Q. And, in fact, that is your handwriting on 10 but objection to form as far as the civil arena aL this notepad, is it not? act. context will cover all of those. 12 MR. RHEINHART: Same instruction. It's 12 MR. RHEINHART: Just figured I'd make the 13 the same question. 13 record clear in case we ever have an issue, or ls 14 THE WITNESS: On the instruction of my 14 in case you want to correct it based on what 1 15 lawyer, { must invoke my Fifth Amendment right. | 15 believe to be the improper form, I will give 16 BY MR, KUVIN: 16 you a chance to correct it. 17 Q. In this note do you agree that you i7 BY MR. KUVIN: 18 arranged for an extension of one month on the rental | 18 Q. No probiem. All right. On Page 2 of 19 car for a young lady under the age of 167 i9 Exhibit 4, if you'd take a look at that. Is that 20 MR. RHEINHART: Objection to the form. It | 20 your handwriting? 21 is compound. It assumes that this is her 21 MR. RHEINHART: Instruct the witness not 22 handwriting. It doesn't identify who the young 22 to answer based on the Fifth Amendment 23 lady might be, and it's otherwise ambiguous, so 23 privilege. 24 J instruct her not to answer on the Fifth 24 THE WITNESS: On the instruction of my 25 Amendment privilege in addition to the legal 25 lawyer, I choose to exercise my Fifth Amendment SLT ET HTT ACTA TOT RET SP STS RH RT TT OTR TR IS TI ON RT TT TE RRNA TST OTR STOTT RTI 28 (Pages 109 to 112) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 113 Page 115 1 tight, 1 MR. RHEINHART: Okay. I would be happy f 2 BY MR. KUVIN: 2 to. 3 Q. Do you know who Larry is, as referred to 3 MR. KUVIN: I just want to clarify, 4 in Page 2 of Exhibit 47 4 because I don't think -5 MR. RHEINHART: I'm sorry. Can you -- 5 MR. RHEINHART: Okay. 6 BY MR. KUVIN: 6 MR. KUVIN: I don't think this is a ue Q. Do you know who -- 7 problem, but I just want to clear it up. 8 MR. RHEINHART: -- restate the question? 8 MR. RHEINHART: Thank you, Mr. Kuvin. 9 BY MR. KUVIN: 9 Tl let her answer that question. 10 Q. Do you know who Larry is as referred to in 10 MR. KUVIN: Nota problem. i at Page 2 of Exhibit 4? 121 MR. RHEINHART: So the question pending } 12 MR. RHEINHART: So, just so i'm clear, 12 is, is that your handwriting? ; 13 what the question is, the document on its face 13 MR. KUVIN: Correct. 14 has the name Larry in it. You're just asking 14 BY MR. KUVIN; 15 this witness whether she knows who this person as Q. Is this your handwriting? Just yes or no. 16 Larry is? 16 A. No. i7 MR. KUVIN: Correct. 17 Q. Okay. Thank you. All right. Let's look 18 MR. RHEINHART: Instruct the witness not 18 at Page 4 of Exhibit 4. All right, This one's a 19 to answer based on her Fifth Amendment 19 little different. Is this your handwriting? 20 privilege. 20 MR. RHEINHART: Let me consult with her 21 THE WITNESS: On the instruction of my 2i again. 22 lawyer, { must invoke my Fifth Amendment right. | 22 Okay. That's fine. You can answer 23 BY MR. KUVIN: 23 the question consistent with the 24 Q. Do you know why Larry was recommending | 24 conversation we just had, 25 that Mr. Epstein leave? 25 THE WITNESS: No. Page 114 Page 11 1 MR. RHEINHART: Objection to the form and i BY MR. KUVIN: 2 instruct the witness not to answer based upon 2 Q. Do you know who Danielle is as referred to 3 her Fifth Amendment privilege. 3 in this note of Page 4 of Exhibit 4? 4 THE WITNESS: On the instruction of my 4 MR. RHEINHART: Instruct the witness not 3 Jawyer, I must invoke my Fifth Amendment right. 5 to answer based on her Fifth Amendment 6 BY MR. KUVIN: 6 privilege. 7 Q. Would you agree with me that Larry was TE THE WITNESS: On the instruction of my 8 calling to warn Mr. Epstein to leave town because he 8 lawyer, I must exercise my Fifth Amendment 9: ‘was going to be arrested? 9 right. 10 MR. RHEINHART: Objection to the form. 10 BY MR. KUVIN: iL The question assumes facts that are not before il Q. Allright. Let's look at Page 5, 12 her, and it requires her to speculate, and also 12 Exhibit 4. 13 implies that she knows anything at all about 13 Before we go to Page 5, rather, going i 14 Jeffrey Epstein, se 1 will instruct her not to 14 back to Page 4 for a minute. Will you agree with me } 15 answer. 15 that Danielle as referred to in Page 4 of Exhibit 4 t 16 THE WITNESS: On the instruction of my 16 is a girl that is under the age of 16? e 17 lawyer, { wish to exercise my Fifth Amendment 17 MR. RHEINHART: Object to the form. You 18 tight. 18 previously asked if she knew who Danielle was, 19 BY MR, KUVIN: 19 and she invoked her Fifth Amendment privilege. 20 Q. Take a look at Page 3 of Exhibit 4, 20 Since the new question presumes that she does 2i please. Is that your handwriting? 21 know who Danielle is she is going to invoke her 22 MR. RHEINHART: I'll instruct her not to 22 Fifth Amendment privilege upon my instruction. 23 answer based on the Fifth Amendment privilege. | 23 MR. KUVIN: All right. Let's look at 24 MR. KUVIN: Before we do that, would you 24 Page 5. consult with her? 25 (561) 832-7500 MR. RHEINHART: Let her answer. LSS SS TT TT FA TT TT TS TE PROSE COURT REPORTING AGENCY, SST NE A IS SEIT 29 (Pages 113 to 116) INC, (561) 832-7506

7 Page 117 Page 119} 1 MR. KUVIN: I'm sorry, go ahead. 1 that Page 5 of Exhibit 4 appears to be a receipt for 2 THE WITNESS: On the instruction of my 2 books ordered through Amazon.com? 3 lawyer, 1 must invoke my Fifth Amendment 3 MR. RHEINHART: You can answer that yes or 4 privilege. 4 no. 5 BY MR. KUVIN: 5 THE WITNESS: It looks like a receipt from 6 Q. Allright. Take a look at Page 5, if you 6 Amazon. z would. Have you ever ordered anything, anything 7 BY MR. KUVIN: 8 yourself from Amazon.com? 8 Q. Okay. And did you place this order for 9 MR. RHEINHART: You're asking for herself 9 Jeffrey Epstein? 10 or anyone else if she has ever placed an order id MR. RHEINHART: Instruct the witness not qi with Amazon.com for any reason? aL to answer the question in that the question 12 MR. KUVIN: [am asking whether she 12 presumes that she knows who Jeffrey Epstein is, 13 personally has ever placed an order with a 13 and therefore, I instruct her not to answer. 14 company called Amazon.com. 14 THE WITNESS: On advice of counsel, f must is MR. RHEINHART: Yes or no. Youcan answer} 15 invoke my Fifth Amendment privilege. 16 that. 16 BY MR. KUVIN: 17 THE WITNESS: Yes. 17 Q. Have you ever read the book identified in 18 BY MR. KUVIN: 18 Page 5 of Exhibit 4 called Slave Craft: Road Maps 19 Q. Okay. So you would agree with me that you 19 for Erotic Servitude - Principals, Skis and Tools? 20 know what Amazon.com is? 20 MR. RHEINHART: Instruct the witness not 21 A. Yes. 21 to answer based on her Fifth Amendment 22 Q. Okay. Now, have you ever placed an order 22 privilege. 23 through Amazon.com for things to be delivered at 23 THE WITNESS: On the instruction of my 24 358 El Brillo Way? 24 lawyer, I must choose to invoke my Fifth 25 MR. RHEINHART: Instruct the witness to 25 Amendment right. Page 118 Page 120f; 1 invoke her Fifth Amendment privilege as to that 1 BY MR. KUVIN: 2 question. 2 Q. Did you ever see that book I just 3 THE WITNESS: On the instruction of my 3 described at the home of Jeffrey Epstein on 4 lawyer, I must invoke my Fifth Amendment 4 358 Et Britlo Way? 5 privilege. 5 MR. RHEINHART: Objection to the form in 6 BY MR. KUVIN: 6 that it presumes she knows Jefirey Epstein and 7 Q. Wilf you agree with me -- E has ever been to 358 El Brillo Way. So, I 8 MR. RHEINHART: I'm sorry, Mr. Kuvin, for, 8 instruct her not to answer based on the Fifth 3 for the record, the page, pages of this exhibit 9 Amendment. 10 are not numbered, but the page we're looking at 10 THE WITNESS: On the instruction of my a. purports to be a receipt for an order from ay lawyer, I must choose to invoke my Fifth 12 Amazon.com; is that correct? 12 Amendment right. 13 MR. KUVIN: Correct. I just want her to 13. BY MR. KUVIN: 44 establish foundation before I got into 14 Q. Have you ever seen the book, Training With 15 specifics. is Miss Abernathy: A Workbook for Erotic Slaves and § 16 MR. RHEINHART: No, but you referred to it | 16 Their Owners, at the home of Jeffrey Epstein on E 17 as Page 5, but they are not numbered, so I just 17 358 El Brillo Way? H 18 wanted to make sure that we're looking at the 18 MR. RHEINHART; Same objection and same fj 19 same page on the exhibit. 19 instruction as the previous question. a 20 MR. KUVIN: That is true. I'm just trying 20 THE WITNESS: On the instruction of my 21 to establish foundation for the questions I'm 21 lawyer, I must choose to invoke my Fifth 22 about to ask her, 22 Amendment right, 23 MR. RHEINHART: Understood. 23 BY MR. KUVIN: 24 BY MR. KUVIN: 24 Q. Have you ever read that book that I just 25 Q. Allright. Ma'am, would you agree with me 25 described which is shown in Page - 5 of Exh i ETT TSA A STI TE RO I PS AR TA TT TAT TE TT OTTO = 30 (Pages 117 £0? 120) (S61) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 121 Page 123) a5 MR. RHEINHART: Same instruction. 1 BY MR. KUVIN: i 2 THE WITNESS: On the instruction of my 2 Q. This note, Page 9 of Exhibit 4, appears to 3 tawyer, I must choose to invoke my Fifth 3 state that Sarah is trying to move -- and then 4 Amendment right. 4 there's a blanked out name, for L1 then Brittany 5) BY MR. KUVIN: 5 could work at 6. Do you know anyone with the name 6 Q. Let's look at the sixth page of Exhibit 4, 6 Brittany? E 7 please. Is that your handwriting? 7 MR. RHEINHART: Ifshe knows anyone in the 8 A. No. 8 world by that name? 9 Q. Allright. Let's look at Page 7. Is that 9 MR. KUVIN: Yeah. We could start with 10 your handwriting? io that. 1i A. No. 11 MR. RHEINHART: I'm saying, in the 12 Q. Okay. Look at the next page which would | 12 context, are you asking in the context of this 13 be Page 8. Is that your handwriting? 13 note which you just read, or are you asking, 14 A, No. 14 generically, does she know anyone in the world 1i5 Q. Let's see how much quicker this goes. 15 by the name of Brittany? 16 Let's look at Page 9. Is that your handwriting? 16 MR. KUVIN: Why don't we first do it in 47 A. No. 17 the context of this note. 18 Q. Look at Page 9 again, if you would. 18 BY MR. KUVIN: 19 MR. RHEINHART: When you say Page 9,} 19 Q. Is this note referring to you when it 20 that's the page that purports to say 10:00. 20 says, "Sarah"? 21 MR. KUVIN: Dr. Bard. 21 MR. RHEINHART: Instruct the witness not 22 MR. RHEINHART: -- Dr. Bard at the top? } 22 to answer based on her Fifth Amendment 23 MR. KUVIN: Correct. 23 privilege. 24 MR. RHEINHART: Okay. 24 THE WITNESS: On the advice of counsel, I 29 25 must invoke my Fifth Amendment right. Page 122 Page 124], 1 BY MR, KUVIN: i BY MR. KUVIN: 2 Q. Do you know who Dr. Bard is? 2 Q. In the context of this note, do you know 3 MR. RHEINHART: Instruct the witness not 3 who Brittany is? 4 to answer based on the Fifth Amendment, because 4 MR. RHEINHART: Same instruction. 5 this sheet of paper has Jeffrey Epstein's name 5 THE WITNESS: On the advice of counsel, I 6 on the bottom, so the question implies that she 6 must invoke my Fifth Amendment right. 7 knows some connection between Dr. Bard and 7 BY MR. KUVIN: 8 Mr. Epstein. 8 Q. Allright. Let's look at Page 10. 9 MR. KUVIN: Hang on a minute. Based on 9 MR. RHEINHART; Mr. Kuvin, let me go back. [} 10 the objection, let me reword the question. 10 MR. KUVIN: Sure. 14 BY MR. KUVIN: il MR. RHEINHART: As to Page | of this 12 Q. Independent from this note and independent | 12 exhibit, I think you had asked the witness 13 from anyone who may or may not be known as 13 whether this was her handwriting, 14 Jeffrey Epstein, de you know anyone by the name of | 14 MR. KUVIN: Do you want to have her go 15 Dr. Bard? a5 back and answer? 16 A. I'msorty. Ask the question again. 16 MR. RHEINHART: Yes, I would. Having i7 Q. Yes. I don’t want you to assume anything 17 consulted with her further, I will have her go 18 from, the purpose of my question has anything todo | 18 back to this question. 19 with someone who may be known as Jeffrey Epstein. | 19 MR. KUVIN: Let's do that, Til, I'll go 20 All I'm asking you is, generaily, do 20 back and ask the question so that we can be 21 you know a person by the name of Dr. Bard? 21 clear. 22 MR. RHEINHART: Let me consult. 22 BY MR. KUVIN: 23 MR. KUVIN: Yes, yeah. 23 Q. On the Exhibit 4, the first page of 24 THE WITNESS: At the advice of counsel, I 24 Exhibit 4, ma'am, is that your handwriting? Yes or (561) must invoke my] Fifth Amendment right. 832-7500 PROSE COURT REPORTING AGENCY, 31 INC. (Pages: 121 to 124) (561) 832-7506

Page 125 Page 1278 1 A. No. 1 it in giving my advice, so thank you for 2 Q. Okay. Allright. Let's skip Page 10, 2 clarifying. 3 because I think that's just a duplicate, and go to 3 MR. KUVIN: Absolutely. 4 Page 11, if you would. 4 BY MR. KUVIN: 5 MR. RHEINHART: Page 11 is - 5 Q. Allright. In Page 11 of Exhibit 4, 6 MR. KUVIN: It looks like DTG Operations, 6 there's a reference in the top right-hand corner, a 7 d/b/a Dollar Rent a Car. 7 message to a Mr. Goldsmith. Do you see that? 8 MR. RHEINHART: Got it. It's a printed 8 A. Uh-huh. 9 sheet, not a handwritten sheet. 9 Q. Yes? 10 MR. KUVIN: Correct. 10 MR. RHEINHART: You have to say yes or no f 11 MR. RHEINHART: Okay. Thank you. il on the record. 12 BY MR. KUVIN: 12 THE WITNESS: Yes, I see it. 13 Q. Allright. Do you know a gentleman by the | 13 BY MR. KUVIN: 14 name of Janusz Banasiak, spelled J-a-n-u-s-z, 14 Q. Okay. Ail right. Do you know who 15 B-a-n-a-s-i-a-k? is Mr. Goldsmith is? 16 MR. RHEINHART: Instruct the witness not { 16 MR. RHEINHART: | instruct the witness 17 to answer based on her Fifth Amendment 17 not to answer based on her privilege against 18 privilege. 18 self-incrimination. 19 THE WITNESS: On the instruction of, my 19 THE WITNESS: At the advice of counsel, I 20 lawyer, I must invoke my Fifth Amendment 20 must invoke my Fifth Amendment privilege. 21 privilege. 21 BY MR. KUVIN: 22 BY MR. KUVIN: 22 Q. Is this your handwriting on exhibit -- on 23 Q. Ma’am, isn't it true that you rented cars 23 the messages shown in Exhibit 4, Page 11? 24 through Dollar Rent a Car for underage girls, girls | 24 MR. RHEINHART: Same instruction. 25 under the age of 18? 25 THE WITNESS: At the advice of counsel, I Page 126 Page 128 |} 1 MR. RHEINHART: Instruct the witness not L must invoke my Fifth Amendment privilege. 2 to answer based on the Fifth Amendment 2 MR. RHEINHART: Hoid on a second, Sarah. 3 privilege. 3 MR. KUVIN: Yeah, check. f 4 THE WITNESS: On the instruction of my 4 MR. RHEINHART: Okay. Can you repeat the f 5 lawyer, I must invoke the Fifth Amendment 5 question again? Maybe I misheard it, 6 privilege. 6 Mr, Kuvin, 7 BY MR. KUVIN: 7 MR. KUVIN: Yeah, nota problem. Let me 8 Q. Did you rent any cars from Dollar Rent a 8 lay a little foundation for it. 9 Car in West Palm Beach in the last five years? 9 MR. RHEINHART: That's okay. If you can 10 MR. RHEINHART: Same instruction. 10 just ask the question again. I think I just al THE WITNESS: On the instruction of my il misheard what you were asking. 12 lawyer, I must invoke my Fifth Amendment 12 BY MR. KUVIN: 13 privilege. 13 Q. Is this your handwriting shown on the i4 BY MR. KUVIN: 14 messages which is Page 11 of Exhibit 4? 15 Q. Let's take a look at Page 11. 4s A. No. 16 MR. RHEINHART: If we can just--letme | 16 Q. Okay. Is this handwriting that of 17 go back, Mr. Kuvin, to clarify the prior two 17 Ms, Sjoberg? 18 questions, When you say, “did you rent," did 18 MR. KUVIN: Johanna — I'm sorry, Sjoberg, 19 you mean did she personally pay for the rental, 19 Sjoberg? How do you pronounce it, Sjoberg? 20 or was she, in any way, involved in arranging 20 MS. CADWELL: Sjoberg? yan the rental? 21 MR. KUVIN: I knew somebody would know. 22 MR. KUVIN: The second part, in any way 22 MR. RHEINHART: Did we get a 23 involved in arranging for the rental of a 23 pronunciation, I'm sorry? vehicle. 24 MR. KUVIN: Yes. {561) __MR. RHEINHART: That's how | inter preted 832-7500 PROSE COURT REPORTING AGENCY, 32 (Pages 125 to 128) INC. (561) 832-7506

Page 129 Page 131 Hi 1 BY MR. KUVIN: 1 appear to be directed -- well, let me, fet me back 2 Q. Is this the handwriting of 2 up. 3 Johanna Sjoberg, if you know? 3 Page 11 of Exhibit 4 appears to be a 4 MR. RHEINHART: Hold on. Let me object to 4 message dated October 2nd, 2005, from Sarah. Do yo 3 the form in that it presumes she knows what 5 see that top left-hand corner? 6 Ms. Sjoberg's handwriting is like or that she's 6 A. Yes. 7 ever known Ms. Sjoberg. So before you ask the 7 Q. Okay. At 10:40 a.m. My question is: Did 8 question, try to clarify that. 8 you call and leave a message at 10:40 a.m. on 9 MR. KUVIN: Well, that’s what I'm trying 9 October 2, 2005, stating: Julia's sick and she 10 to find out. 10 can't come today? il BY MR. KUVIN: 11 MR. RHEINHART: Instruct the witness not 12 Q. Do you recognize this as the handwriting 12 to answer the question based on her Fifth 13 of Johanna Sjoberg? And it can be a yes or no. 13 Amendment privilege. 14 MR. RHEINHART: My, my objection to the 14 THE WITNESS: On the instruction of my 15 form is that you, you haven't asked her whether 15 lawyer I must exercise my Fifth Amendment 16 she actually knows who Johanna Sjoberg is, or 16 privilege, 17 whether she would recognize her handwriting if 17 BY MR. KUVIN: 18 she saw it. 18 Q. Upside down at the bottom of Page 11 is 19 MR. KUVIN: I would love to ask that 19 another phone message dated 10/1 of 2005. Appears 20 question if she'd answer it. 20 to be written to someone named Sarah. Do you see 21 MR. RHEINHART: Well, if she'll answer, 21 that? 22 that’s a different question. But I think you 22 A. Yes. 23 need to ask it first otherwise this question is 23 Q. Okay. Do you -24 ambiguous, 24 MR. RHEINHART: Is it written, I'm sorry, 25 MR. KUVIN: All right. 25 is it written to someone named Sarah or it j Page 130 Page 132] i BY MR. KUVIN: i appears to be a phone call from a person named 2 Q. Not, not to beat a dead horse on the 2 Sarah? F 3 point, do you know Johanna Sjoberg? 3 MR. KUVIN: From a person named Sarah. 4 MR. RHEINHART: | instruct the witness not 4 Thank you. 5 to answer. 5 BY MR. KUVIN: i 6 THE WITNESS: On advice of counsel, I must 6 Q. Did you call someone, anyone on October 1 f; 7 invoke my Fifth Amendment privilege. a of 2005 at 9:50 a.m., to confirm two people, one at 8 BY MR. KUVIN: 8 11:00 and one at 4:00 p.m.? 9 Q. Have you seen Johanna Sjoberg's 9 MR. RHEINHART: Instruct the witness not § 10 handwriting in the past? 10 to answer based on her Fifth Amendment Ta MR. RHEINHART: Objection to the formas | 11 privilege against self-incrimination since this 12 previously stated. I'll instruct the witness 12 document was seized from Mr. Epstein's home. 13 not to answer. 13 THE WITNESS: At the instruction of my 14 THE WITNESS: On advice of counsel, 1 must | 14 lawyer, I must invoke my Fifth Amendment 15 invoke my Fifth Amendment privilege. 15 privilege. 16 BY MR, KUVIN: 16 BY MR. KUVIN: 17 Q. Do you recognize Page EI in Exhibit 4 as Lt Q. Are you the Sarah that’s referred to in 18 the handwriting of Johanna Sjoberg? 18 these phone messages that we've been looking at? 19: MR. RHEINHART: Objection to the form for | 19 MR. RHEINHART: Instruct the witness not 20 the reasons previously stated many, many times, 20 to answer. 21 and I will instruct her not to answer. 21. THE WITNESS: On the instruction of my 22 THE WITNESS: At the advice of counsel, I 22 lawyer, I must invoke my Fifth Amendment 23 must invoke my Fifth Amendment privilege. 23. privilege. BY MR. KUVIN: BY MR. KUVIN: (561) 832-7500 PROSE COURT REPORTING AGENCY, ip P: ge 12 and go to Page 33 (Pages 129 to 132) (561) 832-7506 13 of STRATE INC.

Page 133 Page 1355 L this same exhibit, if you would. Okay. 1 Fifth Amendment right. 2 Is that your handwriting on Page 13 2 BY MR. KUVIN: 3 which happens to be a note stating "Johanna S. is 3 Q. Are you aware that Jeffrey Epstein would 4 coming"? 4 tefer to "work" as performing naked massages for 5 MR. RHEINHART: Okay. Holdon. Canyou!] 5 him? 6 just show me what page you're looking at? 6 MR. RHEINHART: Object to the form of the £ 7 Okay. We skipped a page. 7 question. It's compound and I instruct the 8 THE WITNESS: No. 8 witness not to answer. 9 BY MR. KUVIN: 9 THE WITNESS: On advice of counsel, { wish | 10 Q. Okay. Do you recognize whose it is? 10 to invoke my Fifth Amendment right. ii MR. RHEINHART: Let me talk to you again, | 11 BY MR. KUVIN: 12 BY MR. KUVIN: 12 Q. Let's take a look at the next page, Page i3 Q. fits a yes, you might want to talk to 13 16, All right. If we look at not the message, the 14 him; if it’s a no, it might be quick. 14 phone message, but the note next to that it says: 15 A. No, no. Sorry. i5 Haley on Saturday with Sage at 10:30. 16 Q. Let's look at Page 14, same exhibit. The 16 Do you know who Haley is as referred 17 note on the right-hand side states, "The girl from 17 to in this note? 18 St. Bart's got sick so she won't be able to come. 18 A. On the advice of counsel, { must invoke my 19 Sarah got message from her." First of all, just 19 Fifth Amendment right. 20 generally, do you see the note I'm referring to? 20 Q. Do you know who Sage is as referred to in 21 A. Yes, 2a this note? 22. Q. Okay. Do you know what that is walling 22 A. On the advice of counsel, I must invoke my 23 about? 23 Fifth Amendment right, 24 A. No. 24 MR. GARCIA: [haven't heard the counsel 25 Q. Is that your handwriting? 25 give any advice. : Page 134 Page 136 1 A, No. 1 MR. RHEINHART: You don't know what we've 2 Q. Did Mr. Epstein obtain girls under the age 2 talked about outside of the room so.., 3 of 16 from St. Bart's? 3 MR. GARCIA: Just changing the procedure 4 MR. RHEINHART: Instruct the witness not 4 is all? 5 to answer. Object to the form of the question 5 MR. RHEINHART: I'm changing the procedure 6 in that it presumes that she knows who 6 for Mr. Kuvin. 5 1 Mk. Epstein is. 7 MR. KUVIN: I'm all happy for speed. 8 THE WITNESS: On advice of counsel, I must 8 BY MR. KUVIN: 9 invoke my Fifth Amendment privilege. 9 Q. Allright. Let's look at Page 17 of 10 BY MR. KUVIN: 10 Exhibit 4, It appears to be a phone message at the 1a Q. All tight. Let's take a look at the next a1 bottom dated 9/1/05 to Jeffrey from Jean-Luc. Let 12 page. Appears to be a note, phone message of — I 12 me ask this: Do you recognize the phone number 13 can't read the date, 2005 to Jeffrey from 13 that's listed there of (646)286-70002 14 Melissa Hanes. Just generally, do you see what I'm 14 MR. RHEENHART: Instruct the witness not 15 talking about so we're on the same page here? 15 to answer based on her Fifth Amendment 16 A. Yes. 16 privilege and self-incrimination. 17 Q. Okay. Do you know who Melissa Hanes is? 17 THE WITNESS: On advice of counsel, | must 18 A. On the advice of counsel, I wish to invoke my; 18 invoke my Fifth Amendment right. 19 Fifth Amendment right. 19 MR. KUVIN: Let me show this one to the 20 Q. Allright. The note appears to say: She 20 camera if I could. ff you could focus on the 21 called again, if she could work any time Monday al bottom message for me. 22 through Friday. 22 THE VIDEOGRAPHER: I can't really read 23 Do you know what that message 23 that. pertains to? MR. KUVIN: Do I need to tilt it? (561) 832-7500 A. Onadvice of counsel, I wish to invoke my PROSE COURT REPORTING AGENCY, THE VIDEOGRAPHER: I think you need to 34 (Pages 133 to 136) (561) 832-7506 INC.

Page 137 bring the whole paper up closer. MR. KUVIN: Towards you? THE VIDEOGRAPHER: Yes, towards the lens, MR. KUVIN: Just pass that up so we can get a good shot of the bottom message. THE VIDEOGRAPHER: Up a little higher, please. Let it focus. That's good. Go out. Okay. MR. KUVIN: Allright. Thank you very much, BY MR. KUVIN: Q, The message appears fo read: 9/1/2005 to Jeffrey, 8:08, Jean-Luc, telephone. He has a teacher for you to teach you how to speak Russian, She is two times eight years old, not blonde. Lessons are free and you can have first today if you call. Do you know what that message is referring to? MR. RHEINHART: Instruct the witness not to answer the question. Object to the form of the question because in that it presumes she has knowledge of either Jeffrey or Jean-Luc or that phone number. THE WITNESS: On the advice of counsel, I wish to invoke my Fifth Amendment right. COINHAOBWHE Page 139% Do you -- first of all, do you see that in front of you? Are we talking about the same thing here? A. Yes. Q. Okay. Do you knew who "Haley" is referring to in this note? MR. RHEINHART: Instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Does your handwriting appear anywhere on Page 19 here ~~ A. On the -Q. ~ on either note? A. On the advice of my lawyer, I must invoke my {! Fifth Amendment privilege. F Q. Is that your handwriting on the left in the note that I just read that says: Haley, 11:00 a.m.? MR. RHEINHART: Same instruction, THE WITNESS: On the instruction of my lawyer, 1 must invoke my Fifth Amendment (561) 632-7500 Page 138 BY MR. KUVIN: Q. Would you agree with me that this message is a message from Jean-Luc, that he's providing a 16-year-old girl to Jeffrey Epstein? MR. RHEINHART: Object to the form in that it calls for speculation and also assumes facts as to Mr. Jean-Luc and Mr. Epstein; therefore, 1 instruct her to invoke her Fifth Amendment privilege. THE WITNESS: On the instruction from my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Skip the next page if you would, and the following page will be Page 19 of Exhibit 4. It should be two messages. MR. RHEINHART: Show me what you're looking at. MR. KUVIN: And the top left one says, “Friday.” MR. RHEINHART: Thank you. BY MR. KUVIN: Q. The message on the left-hand side that appears to be, have a date of 4/8/05 and a number 7 written on it. It says: Haley, i: 00 a.m. PROSE COURT REPORTING AGENCY, Page 14 privilege. BY MR. KUVIN: Q. Allright. Let's take a look at the next page which is Page 20. Is that your handwriting on this paper? MR. RHEINHART: Let me talk to her. THE WITNESS: On the advice of my lawyer, I wish to invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Is this a list of girls that were being provided to Jeffrey Epstein for sex? MR. RHEINHART: Objection to the form, the standing objection previously stated. 1 will instruct the witness not to answer that question. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Did Jeffrey Epstein not like girls that had tattoos? MR. RHEINHART: Objection to the form based on the standing objection and the same instruction. THE WITNESS: On the i instruction of my 35 (Pages 137 to 140) (561) 832-7506 INC.

Page 141 Page 143 (561) 832-7500 that note? 1 lawyer, | must invoke my Fifth Amendment 1 MR. RHEINHART: Same instruction. 2 privilege. 2 THE WITNESS: On the advice of my lawyer, 3 BY MR. KUVIN: 3 I must choose to invoke my Fifth Amendment 4 Q. Did Jeffrey Epstein not like girls that 4 right. 5 had blonde hair? 5 BY MR. KUVIN: 6 MR. RHEINHART: Standing objection andthe} 6 Q. De you know who E.W. is? 7 same instruction. 7 MR. RHEINHART: Same instruction. 8 THE WITNESS: On the instruction of my g THE WITNESS: On the advice of my lawyer, 9 lawyer, I must invoke my Fifth Amendment 9 1 wish to invoke my Fifth Amendment privilege. 10 privilege. 10 BY MR. KUVIN: 11 BY MR. KUVIN: a1 Q. Do you know who L.M. is? 12 Q. Take a look at the next page, if you 412 MR. RHEINHART: Let me consult for a 13 would, This one. 13 second. 14 MR. RHEINHART: Thank you. 14 MR. KUVIN: Yep. 15 BY MR, KUVIN: 15 (A discussion was held off the record.) le 16 Q. Is that your handwriting? 16 MR. RHEINHART: Mr. Kuvin, I'm just asking a: A. On instruction of my lawyer, I must invoke my | 17 you to clarify. Are you asking if she's ever 18 Fifth Amendment privilege. 18 heard the name of these people or whether she's 19 Q._Is this an additional -- on Page 21, is 19 actually ever met someone she knows to have 20 this an additional list of girls that were being 20 that name? 21 provided to Jeffrey Epstein for sex? 21 MR. KUVIN: Second part, whether she knows |! 22 MR. RHEINHART: I'm sorry. Did we change | 22 someone personally by that name. I don't want 23 to a different page or the same page? 23 to know what somebody may have told her. 24 MR. KUVIN: The same page. 24 MR. RHEINHART: Sure. 25 25 MR. KUVIN: Certainly not attomeys or Page 142 Page 1445 a: BY MR. KUVIN: 1 anything like that. I want to know whether she 2 Q. Is this an additional list of girls that 2 has any personai knowledge of someone by the 3 were ~ 3 name of L.M. 4 MR. RHEINHART: Thank you. 4 MR. RHEINHART;: Okay. Based on our 5 BY MR. KUVIN: 5 conversation, she can answer or not answer the 6 Q. — being provided to Jeffrey Epstein for 6 question. a sex? 7 THE WITNESS: On the advice of my lawyer, 8 MR. RHEINHART: Objection to the form. 8 I choose to invoke my Fifth Amendment right. : 9 The same objection and the same instruction. 9 MR. KUVIN: Okay. It's like a 10 THE WITNESS: On the instruction of my 10 cough/sneeze. aL lawyer, | must invoke my Fifth Amendment di MR. GARCIA: I tried to stifle it, but -- a 12 privilege. 12 MR. GOLDBERGER: You got it all over me. & 13 BY MR. KUVIN: 13 Just kidding. 14 Q. Page 22. Note on the right appears to 14 MR. GARCIA: You don't want to get this. 15 say: Johanna has a friend, Andrea, that would like 15 T've had if for a couple of days. 16 to work tonight. Do you know who Johanna is refer, | 16 MR. KUVIN: What number are we on? 13. 17 referring to in that note? 17 That's why | always leave some with numbers i8 MR. RHEINHART:; Instruct the witness not 18 still on there to show the picture to the 19 to answer based on the privilege against 19 camera. 20 self-incrimination. 20 Exhibit 13 will be pursuant to 21 THE WITNESS: On the advice of my lawyer, | 21 confidentiality and the identities of the 22 I wish to assert my Fifth Amendment right. 22 girls involved in this case. 23 BY MR. KUVIN: 23 MR. RHEINHART: As I presume the prior Q. Do you know who Andrea is referring to in 24 questions were as well. PROSE COURT REPORTING AGENCY, LUVIN: ¥ bsolutely. This is 36 (Pages 141 to 144) INC. (561) 832-7506

CoOVWHAUBwYNE 23 24 25 (561) Page 145 different because it's an exhibit. MR. RHEINHART: Agreed. MR. KUVIN: Okay. (Plaintiff's Exhibit No. 13 was marked for identification.) MR. RHEINHART: We're moving off of Exhibit 127 MR. KUVIN: Yes. MR. RHEINHART: { was looking at the next exhibit. MR. KUVIN: We're done with the trash. MR. RHEINHART: Okay. BY MR. KUVIN: Q. Just take a look at Exhibit 13. Do you recognize the girl in that photograph? A. On the advice of my lawyer, I must choose to exercise my Fifth Amendment privilege. Q. Do you agree with me that that girl shown in that photograph is B.B.? MR. RHEINHART: Objection to the form for the reasons previously stated, causes her to speculate, and I instruct her not to answer based on her Fifth Amendment privilege. THE WITNESS: On the advice of my lawyer, I must choose to exercise my Fifth Amendment Page 146 privilege. BY MR. KUVIN: Q. Do you agree with me that you arranged to have the girl shown in Exhibit 13 be brought to Mr. Epstein's home for sex with Mr. Epstein? MR. RHEINHART: Objection to the form as compound, and also the standing objection, and instruct the witness not to answer. THE WITNESS: On the advice of my lawyer, I must choose to exercise my Fifth Amendment privilege. BY MR. KUVIN: Q. Would you agree with me that the girl shown in Exhibit 13 did, in fact, come to Mr. Epstein’s home in 2005? MR. RHEINHART: Same objection previously stated. It's compound as to the date, piace, person, and also presumes knowledge of Mr. Epstein, so I would instruct her not to answer. THE WITNESS: On the advice of my lawyer, I must choose to exercise my Fifth Amendment privilege. BY MR. KUVIN: Q. Do you agree with me that the girl shown 832-7500 OOYHDTRWH PROSE COURT REPORTING AGENCY, Page 147 in Exhibit 13 came to Mr. Epstein's home when she was only 15 years old? MR. RHEINHART: Objection to the form based on the standing objection, also speculation as to any age and instruct the witness not to answer. THE WITNESS: On the advice of my lawyer, I must choose to exercise my Fifth Amendment tight. BY MR. KUVIN: Q. Do you agree with me that when you arranged to have this girl come to Mr. Epstein's home, that you were aware that she was 15 years old? MR. RHEINHART: Objection to the form. It is compound. it assumes facts that are not admitted by this witness, and it's ambiguous in that regard, and therefore I instruct her not to answer. THE WITNESS: On the advice of my lawyer, I must choose to exercise my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree that when this girl was brought to Mr. Epstein's home, that she performed a massage on Mr. Epstein while he was naked? Page 148 MR. RHEINHART: Objection to the form, standing objection. The question assumes that this witness has any knowledge of Jeffrey Epstein or whether this person ever came to Mr. Epstein's home. It is therefore ambiguous, and I instruct her not to answer. THE WITNESS: On the instruction of my lawyer, { must choose to exercise my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree with me that this girl shown in Exhibit 13 was 15 years old at the time she was asked by Jeffrey Epstein to remove her clothes? MR. RHEINHART: Objection to the form. It requires speculation and assumes facts relating to Mr. Epstein and events that may have occurred which this witness has no knowledge and has not admitted any knowledge. And I instruct her not to answer. ! i | fi ti | f | | } Hi THE WITNESS: On advice of counsel I must |; choose to exercise my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree that you described for the girl as shown in Exhibit 13 — by the way, her name is B.B. -- that you described to B.B. how to set up 37 (Pages 145 to 148) INC. (561) 832-7506

wartAnswoaney (561) 832~7500 Page 149 the massage table in Jeffrey Epstein's bathroom? MR. RHEINHART: Objection to the form for the reasons previously stated, and instruct the witness not to answer. THE WITNESS: On the advice of counsel, I must choose to exercise my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree that you showed B.B. where the massage oils are kept in Jeffrey Epstein's bathroom in his home? MR. RHEINHART: Objection to the form in that it assumes knowledge of Jeffrey Epstein, knowledge that this person was ever at Jeffrey Epstein's home none of which is admitted or acknowledged by this witness, and instruct the witness not to answer. THE WITNESS: On advice of counsel I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree that you showed B.B., as shown in Exhibit 13, where Mr. Epstein kept the _ vibrators in his bathroom at his house? MR. RHEINHART: Same objection as stated to the previous question as to the form of the Page 150 question, and instruct the witness not to answer. THE WITNESS: On advice of counsel, I must choose to exercise my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree with me that in 2005 you knowingly provided B.B., a 15-year-old girl, to Mr. Epstein so that he could sexually abuse her? MR. RHEINHART: Objection to the form as to it calling for a legal conclusion as to assuming multiple facts, since therefore compound and instruct the witness not to answer. THE WITNESS: On advice of counsel, [ must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree with me that B.B. was given to Mr. Epstein to perform a naked massage of him white he touched B.B.? MR. RHEINHART; Objection to the form. Standing objection and other facts that are assumed in the question to which this witness does not admit, and therefore the witness is instructed not to answer the question. THE WITNESS: On the instruction of my 23 24 eee PROSE COURT REPORTING AGENCY, Page 151, counsel, [ must choose to invoke my Fifth [ Amendment right. l BY MR. KUVIN: Q. Do you agree with me that during the massage that B.B. was forced to give to Mr. Epstein, that he touched her between her legs? MR, RHEINHART: Objection to the form. It £ is ambiguous including the term “forced.” It assumes facts that this witness has not admitted or that this witness has not acknowledged any personal knowledge and instruct her not to answer. THE WITNESS: On the instruction of my lawyer, I must therefore invoke my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree with me that Mr. Epstein touched B.B. between her legs? MR. RHEINHART: Objection to the form and} the question presumes knowledge of Jeffrey Epstein. Instruct the witness not to answer, THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth i Amendment right. t Page 1525 BY MR. KUVIN: Q. Do you agree with me that B.B. told f Mr. Epstein to stop touching him there -- touching her there? MR. RHEINHART: Same objection previously § stated to the last question and instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. [{ BY MR. KUVIN: | Q. Do you agree with me that you have i personal knowledge that after telling Mr. Epstein to stop touching her between her legs, Mr. Epstein apologized and then touched her again between her legs? MR. RHEINHART: Objection to the form and the standing objection previously stated as well as the question is compound and instruct, and ambiguous, and J instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must choose to exercise my Fifth Amendment right. BY MR. KUVIN: 2 Do you agree with m me that Mr. Epstein 38 (Pages 149 to 152) INC. (561) 832-7506

Page 153 Page 155 specifically targeted young underage girls that were} 1 Mr. Epstein naked massages? [i economically disadvantaged for his own sexual 2 MR. RHEINHART: Object to the form. It's pleasure? 3 multiple layers of compound questioning, i MR. RHEINHART: Objection to the form. 4 includes terms like "enterprise" that are Several of the terms are ambiguous and it S ambiguous and may call for a legal conclusion assumes knowledge of Mr. Epstein and his 6 that this witness is not competent to give. I habits, and therefore, | instruct the witness 7 instruct the witness not to answer. not to answer the question. 8 THE WITNESS: On the instruction of my THE WITNESS: On the instruction of my 9 lawyer, I must choose to exercise my Fifth Jawyer, I must choose to exercise my Fifth io Amendment right. Amendment right. il BY MR, KUVIN: BY MR. KUVIN: i2 Q. Do you agree with me that there is a Q. Do you agree with me that Mr. Epstein 13 Staircase leading out of Mr. Epstein's kitchen in would pay these girls 2 to $300 for this sexual 14 his home on Palm Beach? massage? 15 MR. RHEINHART: Objection to the form, MR. RHEINHART: Objection to the form. 16 presumes knowledge of Mr. Epstein or his home }} Standing objection and assumes knowledge of 17 on Palm Beach. Instruct the witness not to Mr. Epstein and his practices, so therefore, I 18 answer. instruct the witness not to answer. 19 THE WITNESS: On the instruction of my THE WITNESS: On the instruction of my 20 lawyer, I must choose to invoke my Fifth lawyer, I must choose to invoke my Fifth 2i Amendment right. Amendment right. 22 BY MR. KUVIN: FE BY MR. KUVIN: 23 Q. Do you agree with me that when B.B. was li Q. Do you agree with me that you handed B.B. | 24 brought to Mr. Epstein's bathroom, that he walked P $2002 25 out of the shower wearing a towel? H Page 154 Page 156 [f MR. RHEINHART: Objection to the form, i MR. RHEINHART: Objection to the form in instruct the witness not to answer. 2 that it presumes knowledge of B.B., that Ms. THE WITNESS: On the instruction of my 3 B.B. was ever at Mr. Epstein's home, that this lawyer, I must choose to invoke my Fifth 4 witness knows anything about Mr. Epstein or his Amendment right. 5 home; therefore, the question is compound and BY MR. KUVIN: 6 ambiguous, and I instruct her not to answer, Q. And just so we're clear, do you agree with © THE WITNESS: On the instruction of my me that you handed B.B. in 2005, $200 after she was 8 lawyer, I must choose to assert my Fifth in the bathroom with Mr. Epstein at his home? 9 Amendment right. MR. RHEINHART: Objection to the form. 10 BY MR. KUVIN: The question presumes knowledge ofa person by | 11 Q. De you know C.L.? the name of B.B., therefore I instruct the Le: A. On the instruction of my lawyer, I must choose witness not to answer the question. 13 to assert my Fifth Amendment privilege. THE WITNESS: On the instruction of my 14 Q. Did you have C.L. — excuse me, strike lawyer, | must choose to invoke my Fifth 15 that. Did you tell C.L. to come over to Amendment right. 16 Mr. Epstein's home to give Mr. Epstein a massage? BY MR. KUVIN: 17 MR. RHEINHART: Objection to the form. Q. Do you agree with me that Mr. Epstein had 18 It's compound. Stand objection, standing a plan -- let me rephrase that. 19 objection, sorry. Instruct the witness not to Do you agree with me that Mr. Epstein 20 answer. had an enterprise, a sexual enterprise, established 21 THE WITNESS: On the instruction of my by which young girls would be brought to his home, | 22 lawyer, [ must choose to invoke my Fifth introduced to you, where you would then set up a 23 Amendment right, massage table, show them where the oils were, and 24 BY MR. KUVIN: have these young girls under the age of 18, give 25 Q. Did you introduce C.L. to Jeffrey Epstein? SAT HRS ETA TT TTR ET TSCA A TS IT CE SL TT LT TATE NL I TT TTR TT (561) 832-7500 PROSE COURT REPORTING AGENCY, 39 (Pages 153 to 156) INC. (561) 832-7506

Page 157 Page 159 i MR. RHEINHART: Objection to the forn, 1 BY MR. KUVIN: 2 standing objection, Instruct the witness not 2 Q. Would you agree with see that you visited 3 to answer. a aman by the name of Jeffrey Epstein while he was in 4 THE WITNESS: On the instruction from my 4 jail in Palm Beach County? 5 lawyer, [ must choose to invoke my Fifth 2: MR. RHEINHART: Objection to the form, 6 Amendment right. 6 standing objection. Assumes other facts that 7 BY MR. KUVIN: 7 this witness has not acknowledged, and instruct 8 Q. Deo you agree with me that Mr. Epstein 8 her not to answer. 9 threatened C.L. with physical violence? 9 THE WITNESS: Upon instruction from the 10 MR. RHEINHART: Objection to the form, the} 10 lawyer, I must choose to invoke my Fifth ll standing objection, as well as ambiguous as to 1 Amendment right. 12 the term “threaten.” Instruct the witness not 12 BY MR. KUVIN: 13 to answer. 13 Q. Do you agree that you arranged to have 14 THE WITNESS: Upon instruction from my 14 C.L. come to Jeffrey Epstein's home for a nude 15 lawyer, I must choose to invoke my Fifth 1s massage? 16 Amendment right. 16 MR. RHEINHART;: Objection to the form, 17 BY MR. KUVIN: 17 standing objection previously stated. 18 Q. Do you agree with me that Jeffrey Epstein 18 THE WITNESS: On the instruction of my 19 told CL. that if she talks to anyone about what had 19 lawyer, [ must choose to invoke my Fifth 20 occurred at his home, bad things would happen to 20 Amendment right. 2. her? aL BY MR. KUVIN: 22 MR. RHEINHART: Objection to the form, 22 Q. Do you agree that C.L. has been to 23 it's compound, and a standing objection. Also 23 358 El Brillo Way on at least two occasions? 24 assumes numerous other facts that this witness 24 MR. RHEINHART: Objection to the form. It 25 has not acknowledge nor admitted, and therefore | 25 assumes knowledge of C.L. and of 358 Ei Brillo Page 158 Page 160 1 1 instruct her not to answer. 1 Way, to which the wimess has not acknowledged, 2 THE WITNESS: On the instruction from my | 2 and instruct the witness not to answer. 3 lawyer, I must choose to invoke my Fifth 3 THE WITNESS: On the instruction of my 4 Amendment privilege. 4 lawyer, [ must choose to invoke my Fifth 5. BY MR. KUVIN: a Amendment right. 6 Q. Would you agree with me that in 2005 that 6 BY MR. KUVIN: 7 Jeffrey Epstein was between the ages of 45 and 55 7 Q. Do you agree that Mr. Epstein has an 8 years old? 8 odd-shaped penis? 9 MR. RHEINHART: Objection to the form. 9 MR. RHEINHART: Objection to the form of 10 Standing objection as to any knowledge of 10 the question. It assumes knowledge of 11 Jeffrey Epstein. Instruct the witness not to 11 Mr. Epstein. It assumes knowledge of 12 answer, 12 Mr. Epstein's body parts, and instruct the 13 THE WITNESS: The instruction of my 13 witness not to answer. 14 lawyer, f must choose to assert my Fifth 14 THE WITNESS: On advice -- on the 15 Amendment right. 15 instruction of my lawyer, I must choose to 16 BY MR. KUVIN: 16 invoke my Fifth Amendment right. aed Q. Would you agree with me that 17 BY MR. KUVIN: 18 Jeffrey Epstein has tremendous wealth? 18 Q. Have you seen Jefitey Epstein's penis? 19 MR. RHEINHART: Objection to the form as} 19 MR. RHEINHART: Objection to the form, and |} 20 stated in the previous question, and instruct 20 we're getting awfully close to a fine here, Mr, i 21 the witness not to answer. 21 Kuvin. 22 THE WITNESS: On the instruction from the | 22 MR. KUVIN: I think the identity of 23 lawyer, I must choose to invoke my Fifth 23 something that young 14 and 15-year-old girls 24 Amendment right. 24 have seen is directly relevant to the issues in 25 25 tis case. If they can describe it, then (561) 832-7500 PROSE COURT REPORTING AGENCY, A TS TTR RS TT A 40 (Pages 157 to 160) INC, (561) 832-7506 rena iret

Page 161 1 obviously it's important because they are the 2 only ones that are answering questions in this 3 case. 4 MR. RHEINHART: Well, people have rights. 5 People will assert their rights, and I am just 6 telling you, we're getting close to a line 7 here. 8 MR. KUVIN: I think I'm being 9 respectful -10 MR. RHEINHART: You haven't crossed it yet a1 because Pm still here, but I'm just warning 12 you. 13 Instruct the witness not to answer 14 any question that presumes existence or is any knowledge of Jeffrey Epstein or any of 16 his body parts. 17 MR. KUVIN: Okay. 18 THE WITNESS: On the instruction of my 19 lawyer, I must choose fo assert my Fifth 20 Amendment right. 21 BY MR. KUVIN: 22 Q. Do you know whether or not Mr. Epstein has 23 any identifying characteristics to any of his 24 private genitalia? 25 MR. RHEINHART: Objection to the form for Page 162 i the reason previously stated, because it 2 presumes that she has any knowledge of who 3 Jeffrey Epstein is or what his body parts look 4 like, and { would instruct her not to answer. 5 THE WITNESS: On the instruction of my 6 lawyer, I must choose to assert my Fifth 7: Amendment right. 8 BY MR. KUVIN: 9 Q. Have you heard anyone other than your 10 lawyers that have described what any of 11 Mr. Epstein's body parts look like? 12 MR. RHEINHART: Objection to the form. It 13 is irrelevant what she's heard from other 14 people, and again, it presumes facts that she's 15 not acknowledged. It is compound, and it is 16 harassing at this point. 17 THE WITNESS: On instruction of my lawyer, 18 IE must choose to invoke my Fifth Amendment Ag: right, 20 BY MR. KUVIN: 21 Q. Were you consulted with respect to the 22 non-prosecution agreement that was entered into with 23 the United States Attorney's Office for the Southern 24 District of Florida as it relates to this case? 25 MR. RHEINHART: Which case? {561) 832-7500 OOIHAVSUNH PROSE COURT REPORTING AGENCY, MR. KUVIN: The Epstein matter. MR. RHEINHART: | instruct the witness not to answer. Objection to the form as compound and assumes the existence of Mr. Epstein which, again, we are not acknowledging, and therefore am instructing her not to answer. THE WITNESS: On the instruction of my lawyer, I choose to assert my Fifth Amendment right. BY MR. KUVIN: Q. Are you aware that Mr. Epstein negotiated for your immunity from prosecution in the non-prosecution agreement that was entered into with the United States Attomey's Office for the Southern District of Florida? MR. RHEINHART: Again, objection to the form for the reasons previously stated as to the standing objection and instruct her not to answer. THE WITNESS: On the instruction of my lawyer, | must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree with me that B.B. was emotionally traumatized as a result of the incidents Page 164 that occurred Jeffrey Epstein's home in 2005? MR. RHEINHART: Objection to the form. it assumes any knowledge of B.B. or any incidents that would have occurred at a home purporting to belong to a person by the name of Jeffrey Epstein, and instruct her not to answer. THE WITNESS: Upon instruction from my lawyer, { must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree with me that C.L. was emotionally traumatized as a result of the incidents that occurred at Jeffrey Epstein's home? MR. RHEINHART: Same objection as to the previous question, and instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Do you know Jane Doe No. 102? MR. RHEINHART: Instruct the witness not to answer based on Fifth Amendment privilege. THE WITNESS: On instruction of my lawyer, L must choose to invoke my Fifth Amendment 41 (Pages 161 to 164} INC. (561) 832-7506

Q. Do you know who owns 301 East (S61) 832-7500 PROSE COURT REPORTING AGENCY, Page 165 Page 167% 1 right. i in New York? bi 2 BY MR. KUVIN: 2 MR. RHEINHART: Instruct the witness not 3 Q. Have you known Jeffrey Epstein to keep 3 to answer based on the Fifth Amendment a 4 underage, under the age of 18, sex slaves? 4 privilege. 8 MR. RHEINHART: Objection to the form both} 5 THE WITNESS: On the instruction of my |} 6 as to ambiguity as to what you mean by "sex 6 fawyer, I choose to invoke my Fifth Amendment [ of slaves," and "keep," also the standing 7 right. 8 objection as to any knowledge of Mr. Epstein 8 BY MR. KUVIN: 9 and instruct the witness not fo answer. 9 Q. Are you aware that various underage girls 10 THE WITNESS: On the instruction of my 19 brought in from out of the country live at 301 East 27 lawyer, | must chcose to invoke my Fifth qi 66th Street? 12 Amendment right, 12 MR. RHEINHART: Objection to the form. 13 BY MR. KUVIN: 13 It's compound, and instruct the witness not to 14 Q. Where do most of the models come from that 14 answer. 15 are part of MC Squared Modeling Agency? 15 THE WITNESS: On the instruction from my 16 MR. RHEINHART: Objection to the form. It | 16 lawyer, I must choose to invoke my Fifth i 17 assumes knowledge of an entity by the name of 17 Amendment right. 18 MC Squared Modeling which the witness has not | 18 BY MR. KUVIN: 19 acknowledged and therefore I instruct her not 19 Q. You've stayed at that address before, have 20 to answer, and the question is compound. 20 you not? E 21 THE WITNESS: On the instruction of my 21 MR. RHEINHART: Instruct the witness not § 22 lawyer, I must choose to invoke my Fifth 22 to answer. i 23 Amendment privilege. 23 THE WITNESS: On the instruction of my 24 BY MR, KUVIN: 24 lawyer, 1 must choose to invoke my Fifth 25 Q. Who gets visas for the models at MC 25 Amendment right. q Page 166 Page 168 1 Squared, if you know? 1 BY MR. KUVIN: 2 MR. RHEINHART: Same, same objection as to 2 Q. You've stayed there hundreds of times, 3 the previous question, same instruction. 3 have you, hundreds of times have you not? 4 THE WITNESS: On the instruction of my 4 MR. RHEINHART: Instruct the witness not 5 lawyer, T must choose to invoke my Fifth 5 to answer. 6 Amendment right. 6 THE WITNESS: On instruction from my 7 BY MR, KUVIN: 7 lawyer, I must choose to invoke my Fifth 8 Q. Do you work with Jeffrey Epstein to get 8 Amendment right. 9 visas for out-of-the-country models or models that 9 BY MR. KUVIN: 10 are -- strike that. 10 Q. Are you aware that Mr. Epstein obtains 11 Do you work with Jeffrey Epstein to iL visas for girls from out of the country to work as 12 get visas for girls that are underage and bring them 12 models and then prostitutes them out? 13 into the United States so that they can work as 1:3; MR. RHEINHART: Objection to the form of 14 models for MC Squared? 14 the question in that it is ambiguous and it as MR. RHEINHART: Objection to the form and 1s assumes numerous facts that have not 16 assumes knowledge as to Mr. Epstein and as to 16 acknowledged that this witness has any 17 MC Squared and other matters that are not 17 knowledge of, and the term “prostitutes them 18 admitted or acknowledged by this witness. The 18 out" is ambiguous, so I would instruct her not 19 question is compound. I would instruct her not 19 to answer the question. 20 to answer. 20 THE WITNESS: On the instruction of my 21 THE WITNESS: On the instruction from my 21 lawyer, I must choose to invoke my Fifth 22 lawyer, I must choose to invoke my Fifth 22 Amendment right. 23 Amendment right. 23 BY MR. KUVIN: lH BY MR. KUVIN: 24 Q. You know what Radar Online is, do you not? MR. RHEINHART: Instruct the witness not _[ 42 (Pages 165 to 168) (561) 832-7506 INC.

OMIKDDewWHE Page 169 Page 171% to answer the question based on her Fifth 1 THE WITNESS: On the instruction from my i Amendment privilege. 2 lawyer, I choose to invoke my Fifth Amendment THE WITNESS: On the instruction of my 3 right. lawyer, I must choose to invoke my Fifth 4 BY MR. KUVIN: Amendment right. i 5 Q. Would you agree with me that Jeffrey BY MR. KUVIN: 6 Epstein has a list of underage girls that live i Q. In fact, you were around when 7 within a close proximity to all of his different Jeffrey Epstein bought Radar Online, were you net?! 8 homes in every different state? i MR. RHEINHART: Objection to the form, 9 MR. RHEINHART: Objection to the form in standing objection as to any knowledge of 10 that it assumes Mr. Epstein has homes in every i Jeffrey Epstein or of Radar Online, and LL single state and that she knows who Mr. Epstein instruct the witness not to answer. 12 is, and therefore I instruct her not to answer. THE WITNESS: On the instruction from my ; 13 THE WITNESS: On advice of my lawyer, I H lawyer, 1 must choose to invoke my Fifth 14 must choose to invoke my Fifth Amendment right. Amendment right. is BY MR. KUVIN: BY MR. KUVIN: 16 Q. You're aware Mr. Epstein has a home in New Q. Are you aware that Jeffrey Epstein 17 York, right? accessed or obtained underage girls through his 18 MR. RHEINHART: Instruct the witness not Radar connection? 19 to answer, and standing objection of knowledge MR. RHEINHART: Same objection as 20 of Mr. Epstein. previously stated to the last question and same 21 THE WITNESS: On the instruction of my instruction. 22 lawyer, I must invoke my Fifth Amendment right. THE WITNESS: On the instruction from my | 23 BY MR. KUVIN: lawyer, I must choose to invoke my Fifth 24 Q. Are you aware that he has a home in New R Amendment privilege. 25 Mexico? | Page 170 Page 172 BY MR. KUVIN: 1 MR. RHEINHART: By he, you mean Q. How many different properties does 2 Mr. Epstein? Jeffrey Epstein own? 3 MR. KUVIN: Yeah. I MR. RHEINHART: Objection to the form, 4 MR. RHEINHART: Got to make sure the standing objection, Instruct the witness not 5 question is clear. Hy to answer, 6 MR. KUVIN: Yes. THE WITNESS: On the instruction of my 7 MR. RHEINHART: Standing objection to the fawyer, I must choose to invoke my Fifth 8 form and instruct the witness not to answer. | Amendment right. 9 THE WITNESS: On the instruction from my BY MR. KUVIN: 10 lawyer, { must choose to invoke my Fifth Q. You've been to all of Jeffrey Epstein's il Amendment privilege. home, have you not? 12 BY MR. KUVIN: MR. RHEINHART: Same objection as 13 Q. Are you aware he has a home in the U.S. previously stated to the last question. Same 14 Virgin Islands? instruction. 15 MR. RHEINHART: Same instruction, same THE WITNESS: On the instruction fom my } 16 objection. lawyer, I must invoke my Fifth Amendment right. | 17 THE WITNESS: On the instruction of my BY MR. KUVIN: 18 lawyer, I must choose to invoke my Fifth Q. You agree with me that Jeffrey Epstein 13 Amendment right. keeps a list-of girls in the nearby areas around all 20 BY MR. KUVIN: of his homes and properties? 2i Q. And isn't it true that you kept a list of MR. RHEINHART: Objection to the form, for| 22 underage girls that could service, in other words, the standing objection as well as ambiguous as 23 give Mr. Epstein naked massages in every place that to "nearby,” and “all of his properties," so I 24 he has one of those homes I just described? instruct the witness not to answer, 25 MR. RHEINHART: Same objection as (S61) 832-7500 ST ER ST ST TT ITE SOO SP RT TE TSE DATA PROSE COURT REPORTING AGENCY, Sa 43 (Pages 169 to 172) INC. (561) 832-7506

WOIHUAWNHE Page 173 previously stated, the standing objection and instruct her not to answer. THE WITNESS: On the instruction of my fawyer, I must choose to inyoke my Fifth Amendment right. BY MR. KUVIN: Q. Now, you're also aware, are you not, that Jeffrey Epstein would pay other girls to bring additional underage girls to him for naked massages, are you not? MR. RHEINHART: Standing objection and instruct the witness not to answer. THE WITNESS: On the instruction from my lawyer, I must choose to invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. And, in fact, you frequently would pay other girls to bring additional girls under the age of 18 to Mr. Epstein for naked massages? MR. RHEINHART: Objection to the form, standing objection as to Mr. Epstein, also as to any knowledge of any naked massages by anybody to anybody. Instruct the witness not to answer. THE WITNESS: On the instruction of my Page 174 Jawyer, I choose to invoke my Fifth Amendment right, BY MR. KUVIN: Q. And there was a complete list of girls, underage girls, that was stored on Mr. Epstein's computer system; isn't that true? MR. RHEINHART: Objection to the form. It's ambiguous as to what a complete list is, and also a standing objection to any knowledge of Mr. Epstein, and instruct the witness not to answer, THE WITNESS: On the instruction from my lawyer, I must choose to invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. In fact, you've seen the list of underage girls that exists on Mr. Epstein's computer, have you not? MR. RHEINHART: Objection to the form, standing objection. THE WITNESS: On the instruction from my lawyer, I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. When underage minor females were brought 12 Page 175 to Mr. Epstein's house on Paim Beach, you were aware that they were brought so that Mr. Epstein could molest them, correct? MR. RHEINHART: Objection to the form as to knowledge of Mr. Epstein, as to knowledge of any home on Palm Beach, and ambiguous as to the term “molest,” and instruct the witness not to answer. THE WITNESS: On the instruction from my lawyer, I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. You're aware that Mr. Epstein raped several underage minors in his bedroom? MR. RHEINHART: Objection to the form as to knowledge of Mr. Epstein, and also ambiguous as to the term "rape." THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth Amendment rights, BY MR. KUVIN: Q. Do you know what the term "rape" means? MR. RHEINHART: Not as you used it. if you want to tell us what you mean by when you used it, we'll be happy to answer — Page 176 E MR. KUVIN: | want to know if ~ MR. RHEINHART: -- or evaluate your question, MR. KUVIN: 1 want to know if she has her own definition of what the phrase or word “rape” means, so that we can use her definition of that word. I want to make sure it's completely unambiguous. H MR. RHEINHART: Your asking the question. Ifyou want to define the term, she'll respond to your question. BY MR. KUVIN: Q. Do you what the term or word "rape" means? A. Yes. Q. Okay. What is your understanding of that word? MR. RHEINHART: Now, we're not answering f that question. It's your term. It's your question. If you want to define it, you can go ahead and define it. MR. KUVIN: Well, I beg -MR. RHEINHART: If you want to give her specifics as to what she -- you can define it. MR, KUVIN: I beg to differ with you, and I don't know that that's & proper objection. (561) 832-7500 AAA HS A TT TT TT SR NEN RTT TT HRT EE ETT PROSE COURT REPORTING AGENCY, 44 (Pages 173 to 176) INc, {561) 832-7506

Page 177 Page 179 I'm asking her her understanding of the word. MR, RHEINHART: And I am instructing her not to answer it because that question is not likely to lead to discoverable evidence. It's simply meant to harass her. And you can define the term in your question. MR. KUVIN: Well, with all due respect, it's certainly not to harass if there have been girls that were alleging that they were raped. MR. RHEINHART: Well, you define what you | 10 mean by when you say that they allege that they 11 of vaginal penetration or union with the sexual organ of another, or oral, anal or vaginal penetration of another with any other object, or with any object. Excuse me. All right? MR. RHEINHART: Okay. BY MR. KUVIN: Q. Do you understand that definition as I have explained it to you, or would you like me to read it again? A. Read it again, please. Q. Absolutely. Florida law defines "rape" as OONIHURWNHE have been raped, and she will be happy to 12 oral, anal or vaginal penetration by, or union with evaluate your question, 13 the sexual organ of another; or oral, anal or MR. KUVIN; And that's what I'm trying to 14 vaginal penetration by another with any object. And |; understand. 15 obviously that is without the other's consent. MR. RHEINHART: She's not going to 16 A. You did not say that. speculate on what you mean when you frame a 17, MR. RHEINHART: Okay. word in your question. 18 BY MR. KUVIN: MR. KUVIN: That's exactly what I'm trying 19 Q. Adding without the other's consent, to do. I'm trying to make sure that we are 20 obviously, to that definition. using the same definition, so I would like to 21 Now, let's use that definition for use her definition of the word. 22 "rape," because that's as it's defined by Florida MR. RHEINHART: Right. She's not goingto | 23 law. Using that definition, are you aware, as you answer it, so you can either move on we can 24 sit here today, that Jeffrey Epstein has raped stop. 25 underage girls? Page 178 Page 180 MR. KUVIN: Okay. So you're instructing 1 MR. RHEINHART: Standing objection to the her not to answer the question? 2 form of the question, and I would instruct the MR. RHEINHART: [ am instructing her not 3 witness not to answer. to answer the question for the third time. 4 THE WITNESS: On the instruction of my MR. KUVIN: Okay. I just want to be 5 lawyer, I must choose to invoke my Fifth. clear, 6 Amendment right. MR. GARCIA: What's the legal objection? 7 BY MR. KUVIN: MR. RHEINHART: I've already stated what 8 Q. Are you aware as you sit here today that my legal objection is. It's meant solely for 9 Jeffrey Epstein raped B.B.? harassment. It's not likely to lead to 10 MR. RHEINHART: Objection to the form. discoverable evidence. 1 The question assumes that he did, or that she BY MR. KUVIN: 12 has any knowledge of whether he did, so I Q. Okay. For the purpose of my question, 1 13 instruct the witness not to answer. would like to, because your attorney won't allow you! 14 THE WITNESS: On the instruction of my to define the word "rape," I would like you to use is lawyer, I must choose to invoke my Fifth the word and understand the word “rape” to mean 16 Amendment privilege. sexual contact with an individual, including 17 BY MR. KUVIN: sexual -- well, let me clarify here, Hang on. You 18 Q. Are you aware as you sit here today, that know what, if we're going to do it, let's do it 19 Jeffrey Epstein -- well, let me rephrase that. right since we can't use your definition. 20 You are aware, are you not, as you MR. RHEINHART: You can use whatever 21 sit here today, that Jeffrey Epstein raped C.L.? fi definition you like, but you aeed to tell me 22 MR. RHEINHART: Objection to the formas what it is. 23 leading, and also again assumes -~ your ll MR. KUVIN: Let's use the definition of 24 question assumes that she knows things that "rape" as defined by Florida law as oral, anal 25 she's not acknowledged that she knows or (561) 832-7500 ST aT TRAE TT TT ARREST TS RT TORR SC TCS TE TT TI OO TTT PROSE COURT REPORTING AGENCY, INC. 45 (Pages 177 to 180) (561) 832-7506

OCOIKDUYEWHE (561) 832-7500 Page 181 Page 183k doesn't know, and I instruct her not to answer. i MR. RHEINHART: Same objection as i THE WITNESS: On the instruction of my 2 previously stated as to ambiguity and compound, | lawyer, I must choose to invoke my Fifth 3 and instruct the witness not to answer. Amendment right, 4 THE WITNESS: On the instruction of my BY MR. KUVIN: 5 lawyer, I must choose to invoke my Fifth Q. Do you agree that Jeffrey Epstein has 6 Amendment right. raped hundreds of girls under the age of 18? 7 BY MR. KUVIN: MR. RHEINHART: Objection to the form, 8 Q. Have you ever had sexual contact in any standing objection as to any knowledge of 9 manner with any underage girls that were brought to |! Jeffrey Epstein. Instruct the witness not to 10 Mr. Epstein's home? answer. 12 MR. RHEINHART: Objection to the form. THE WITNESS: On the instruction of my 12 Standing objection, compound, instruct the lawyer, I must choose to invoke my Fifth 13 witness not to answer. Amendment privilege. 14 THE WITNESS: On the instruction of my BY MR. KUVIN: 15 jawyer, I must choose to invoke my Fifth Q. You're aware, are you not, that 16 Amendment right. Jeffrey Epstein has raped hundreds of girls under 17 BY MR. KUVIN: the age of 17? 18 Q. Did you keep an appointment book for MR. RHEINHART: Objection to the form as} 19 Mr. Epstein? leading. Instruct the witness not to answer 20 MR. RHEINHART: Objection to the form, for the reasons previously stated to the last 21 standing objection. Instruct the witness not the question, 22 to answer. THE WITNESS: On the instruction of my 23 THE WITNESS: On the instruction of my lawyer, I must choose to assert my Fifth 24 lawyer, I must choose to invoke my Fifth _ Amendmefit right: 25 Amendment right. SS Page 182 Page 184} BY MR. KUVIN: i BY MR. KUVIN: Q. You're aware, as you sit here today, are 2 Q. Did you preserve a document that shows the you not, that Jeffrey Epstein has raped hundreds of 3 appointments kept for Mr. Epstein in the years 2004? girls under the age of 167 4 MR. RHEINHART: Objection to the form, the [ MR. RHEINHART: Objection to the form. 5 standing objection, compound question and Standing objection. It assumes numerous facts 6 instruct the witness not to answer. mixed in a compound question, and therefore I 7 THE WITNESS: On the instruction of my instruct the witness not to answer. 8 lawyer, I must choose to invoke my Fifth THE WITNESS: On the instruction of my 9 Amendment right. lawyer, | must choose to assert my Fifth 10 BY MR. KUVIN: Amendment right. 11 Q. Same question with respect to any BY MR. KUVIN: 12 appointments kept for Mr. Epstein in 2005. f Q. Isn't it true that Mr. Epstein had at 13 MR. RHEINHART: Same objection previously [/ least one or two scheduled appointments for sex with | 14 stated to the previous question. underage girls every day while he was here in Palm is THE WITNESS: On the instruction of my Beach County in the year 2005? 16 lawyer, I must choose to invoke my Fifth MR. RHEINHART: Objection to the form. 17 Amendment right, It's compound, standing objection as well, and 18 BY MR. KUVIN: instruct the witness not to answer. is Q. Same with respect to any appointments kept THE WITNESS: On the instruction of my 20 for Mr. Epstein in 2006. lawyer, I must choose to invoke my Fifth 21 MR. RHEINHART: Same objection as Amendment right. 22 previously stated to the last two questions. BY MR. KUVIN: 23 THE WITNESS: On the instruction of my Q. Did you actually locate underage girls in 24 Jawyer, | must choose to invoke my Fifth ? 25 Amendment privilege. in to Palm Beach for Jeffrey Epste' oe STN RST RT TRS RTT A TTT ERATE ART TT RTT PROSE COURT REPORTING AGENCY, 46 (Pages 181 to 184) Inc. (561) 832-7506

Page 185 1 BY MR. KUVIN: 2 Q. Have you provided any appointment books to 3 anyone with respect to appointments for Mr. Epstein? 4 MR. RHEINHART: Same standing objection as 5 to knowledge of Mr. Epstein. The question is 6 compound and instruct the witness not to 7 answer. 8 THE WITNESS: On the instruction of my 9 lawyer, I must choose to invoke my Fifth 10 Amendment right. il BY MR. KUVIN: 12 Q. Would Ep —- Mr. Epstein pay the underage 13 girls more money if they took off both their tops 14 and their bottoms? 15 MR. RHEINHART: Objection to the form, 16 standing objection. Instruct the witness not 7 to answer, 18 THE WITNESS: On the instruction of my 19 lawyer, I must choose to invoke my Fifth 20 Amendment right. 21 BY MR. KUVIN: 22 Q. Would Mr. Epstein pay the underage girls 23 more if they would actually touch his penis? 24 MR. RHEINHART: Same instruction, same 25 objection. Page 186 1 THE WITNESS: On the instruction of my 2 Jawyer, I must choose to assert my Fifth 3 Amendment right. 4 BY MR. KUVIN: 5 Q. Would Mr, Epstein pay the underage girls 6 more if he would allow them to have sex with them? 7 MR. RHEINHART; Can you restate that 8 again? 9 MR. KUVIN: Yes. 10 BY MR. KUVIN: 1. Q. Would Mr. Epstein pay the underage girls 12 more money if they would allow him to have sex with 13 them? 14 MR. RHEINHART: Objection to the form, 15 standing objection. Instruct the witness not 16 to answer. 17 THE WITNESS: On the instruction of my 18 lawyer, I must invoke my Fifth Amendment right, 19 MR. KUVIN: Hang on one second. You can 20 stop at any time I'll sign it. 21 MR. RHEINHART: Mr. Kuvin, I don't know if 22 you're getting to a convenient breaking point 23 but -(561) MR. KUVIN: Do you want to take a quick 832-7500 SIH RYN PROSE COURT REPORTING AGENCY, INC. Page 187} MR. RHEINHART: Yeah, whenever you get to aconvenient point in your questioning, I think we can use a break. If you're in the middle of something, I don't want to stop you. MR. KUVIN: No, this is fine. We can take aquick break. Five minutes? MR. RHEINHART: Yes, thank you. THE VIDEOGRAPHER: We're now off the record. It is 2:08 p.m. {A brief recess was held.) 47 (Pages 185 to 187) (561) 832-7506

Page 189} UNITED STATES DISTRICT COURT 2 INTHE CIRCUIT COURT OF THE ISTH JUDICIAL CIRCUIT SOUTHERN DISTRICT OF FLORIDA. IN AND FOR PALM BEACH COUNTY, FLORIDA 2 CASE NO. 502008CA028051XXXXMB AB CASE NO. 08-CIV-80119-MARRAJJOHNSON 2 eM , . JANE IDOE NO: 2, Plaintiff 5 5 vs ‘VOLUME I OF HE os. VOLUME 11 OF lil JEFFREY EPSTEIN, 6 Defendant. JEFFREY EPSTEIN, i. 7 Defendant. Related cases: 8 f 08-80232, 08-08380, 08-8038, 08-80994 2 08-8093, 08-8081 1, 08-8093, 09-80469 10 VIDEOTAPED DEPOSITION OF SARAH KELLEN 09-80591, 09-80656, 09-80802, 09-81092 ) i sadapay Mecskak200 12 10:37 - 651 p.m. 13 VIDEOTAPED DEPOSITION OF 14 SARAH KELLEN 15 250 Australian Avenue South ‘West Palm Beach, Florida 33401 Wednesday, March 24, 2010 16 10:37 - 6:51 p.m. 17 250 Australian Avenue South u Rate Suite 1500 PO! q West Pal Florida 334 Cyothia Hopkins, RPR, EPR est Palm Beach, Florida 33401 20 Notary Public, State of Florida Reported By: a Prose Court Reporting, Cynthia Hopkins, RPR, FPR 22 Notary Public, State of Florida 23 Prose Court Reporting 24 | aan Ob Now: 1484 123. F Page 188 Page 190} 1 IN THE CIRCUIT COURT OF THE ISTH JUDICIAL CIRCUIT. i IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL IN AND FOR PALM BEACH COUNTY, FLORIDA ‘CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 CASE NO. 502008CA028058KXXXMB AD 2 CASE No.502008CA037319XXXXMB AB 3 BW, BB. 4 4 Plaintiff, Plaintiff, 2 5 ars oe VOLUME ff OF Ift 6 “vs VOLUME f OF It 7 JEFFREY EPSTEIN 54, GESERENERSTERY, ‘AND SARAH KELLEN, 8 ’ ‘Defendant. i Defendants, 4 9 10 0 EPOSITION OF SARAH KELLEN Ht D CREARAH BE ia ‘VIDEOTAPED DEPOSITION OF 12 Wednesday, March 24, 2010 12 SARAH KELLEN 10:37 - 6:51 p.m. 13 13 14 ‘Wednesday, March 24, 2010 14 250 Australian Avenue South 10:37 - 6:51 pam. West Palm Beach, Florida 33401 15 15 16 16 17 250 Australian Avenue South 17 Suite 1500 18 Reported By: 18 West Palm Beach, Florida 33401 ‘Cynthia Hopkins, RPR, FPR, 19 as Notary Public, State of Florida 20 Prose Court Reporting 24 20 22 Reported By: 2h Cynthia Hopkins, RPR, FPR 22 23 Notary Public, State of Florida 23 Prose Court Reporting Services 26 24 — fobNo: 1484 28 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 1 (Pages 187 to 190) (561) 832-7506

Page 191 Page 193 1 APPEARANCES: 1 2. On behalfof the Plaintiffs, B.B. Se 3 SPENCER T. KUVIN, ESQUIRE 2 INDEX LEOPOLD KUVIN 3 foe 4 2925 PGA Boulevard Suite 200 4 $ Palm Beach Gardens, Florida 33410 5 EXAMINATION DIRECT CROSS REDIRECT : Phone: 361.515.1400 6 BYMR.KUVIN 194 7 On dedalf of the Plaintiffs, LM., EW. and 7 BY MR. HOROWITZ 214 Jane Doe: BY MR. WEISSING 271 g 9 MATTHEW WEISSING, ESQUIRE 8 BY MR. GARCIA 325 FARMER, JAFFE, WEISSING, EDWARDS 9 10 FISTOS & LEHRMAN, PLL. 40 noe E * {25 Ns Andrews Avenue 1 EXHIBITS i Fort Lauderdale, Florida 33301 12 12 Phone: 954,524 2820 3B SS 13 On behalf of Fane Does 1 through 8: 14 ADAM D, HOROWITZ, ESQUIRE 14 EXHIBIT DESCRIPTION PAGE MERMELSTEIN & HOROWITZ, P.A. 45 H 8 16205 Biscarne Ponleverd 16 PLAINTIFF'S BX. 14 REQUEST FOR WARRANT 197} 16 Miami, Elsie 3 3160 PLAINTIFF'S EX. 15 ANSWER AND 342 one: 305: y E-mail: Ahorowitz@sexabuseattomey.com af AFFIRMATIVE DEFENSES 18 On behalf of the Plaintiffs, 101, 102 and 103: 18 19 KATHERINE W. EZELL, ESQUIRE 19 AMY JOSEFSBERG EDERI, ESQUIRE 20 20 PODHURST ORSECK 25 West Flagler Street 21 2. Suite 800 20 Miami, Florida 33130 22 Phone: 305.358.2382 23 23 {Via telephone) 24 24 25 25 Page 192 Page 194} i Appearances continued... L PROCEEDINGS i 2 On behalf of the Plaintiff, Jane Doe It: 2 baeee 3 ISIDRO MANUEL GARCIA, ESQUIRE GARCIA, ELKINS & BOEHRINGER 3 THE VIDEOGRAPHER; We're now back on the i 4 224 Datura Avenue, Suite 900 is 2: i ia Unit West Paira Beach, Forids 33401 4 record. It is 2:19 p.m, Starting Media Unit 5 Phone: 561.832.8033 5 No. 2. : Bi beieeeasnesensy 6 CONTINUED DIRECT EXAMINATION ff alf of tt: 4 7 BY MR. KUVIN: a JACK ALAN GOLDBERGER, ESQUIRE i ATTERBURY, GOLDBERGER & WEISS, P.A, 8 Q. Allright. Did Jeffrey Epstein talk to | 8 oak an Avenue South 9 you about whether or not he was going to be going to 10 West Palm Beach, Florida 33401-5012 10 jail after he was arrested? Phone: 561.659.8300 11 MR. RHEINHART: Objection to the form, a5 12 standing objection. Instruct the witness not 13 On behalf of the Witness: 13 to answer. 5 a4 FAW OFEICE OF BRUCE D REMGARE 14 THE WITNESS: Qn the instruction of my a5 One Clearlake Center 15 lawyer, I must invoke my Fifth Amendment right. F 250 South Australian Avenue, Suite 1400 16 BY MR. KUVIN: a8 Seen ee 7 Q. How did you first learn of the criminal a7 18 investigation with respect to Mr. Epstein? 7 19 MR. RHEINKART: Objection to the form, 20 ALSO PRESENT: 20 standing objection. Instruct the witness not i 24 Jessica Cadwell, Paralegal 21 to answer. 50°), Kent Mee 22 THE WITNESS: On the instruction of my Prose Court Reporting Services 23 lawyer, I must exercise my Fifth Amendment 24 right. i 2 {Pages 191 to 194) {561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 195 Page 197 (561) 832-7500 not know, the 1 BY MR. KUVIN: i not know about. 2 Q. Do you knew who tipped off Jeffrey Epstein Zs But if you can answer, go ahead. 3 about an ongoing investigation against him back in 3 THE WITNESS: No. 4 2005? 4 BY MR. KUVIN: 5 MR. RHEINHART: Same objection as 5 Q. Let me show what we'll mark as Exhibit 14, 6 previously stated to the last two questions and 6 which purports to be a request for a warrant for a same instruction. 7 your atrest. 8 THE WITNESS: On the instruction of my 8 MR. RHEINHART: Okay. 9 lawyer, [ must invoke my Fifth Amendment right. 9 (Plaintiff's Exhibit No. 14 was marked for 190 BY MR. KUVIN: 190 identification.) 1a Q. Were you awate that there was a warrant 11 BY MR. KUVIN: 12 issued for your arrest in connection with 12 Q. Just yes or no; have you seen that request 13 Jeffrey Epstein? 13 for a warrant before? 14 MR. RHEINHART: Objection to the form, 14 A. No. is standing objection, same instruction. 15 Q. Allright. If you would tum to the i 16 THE WITNESS: On the instruction of my 16 probable cause affidavit. If you would go ahead and 17 lawyer, [ must invoke my Fifth Amendment right. | 17 turn to the -- keep turning, and again. There we f 18 BY MR. KUVIN: 18 go. 19 Q. Have you seen the warrant that was issued 19 All right. There's a document attached to 20 for your arrest in connection with Jeffrey Epstein? 20 this exhibit entitled, Probable Cause Affidavit. 21 MR. RHEINHART: Same objection and same | 21 Have you had a chance to read through this 22-page 22 instruction as the last question. 22 document in the past? : 23 THE WITNESS: On the instruction of my 23 MR. RHEINHART: I'm sorry. Are you asking 24 lawyer, must invoke my Fifth Amendment right. | 24 her if she's ever seen it before or if she's 25 25 ever read it before? Page 196 Page 198 1 BY MR. KUVIN: 1 MR. KUVIN: Goed point. 2 Q. Have you seen the probable cause affidavit 2 BY MR. KUVIN: 3 with respect to the arrest warrant issued for your iS Q. Let's ask first: Have ever seen it 4 arrest on May 1, 2006? 4 before? 5 MR. RHEINHART: Hang on one second. I 5 A. I don't believe so. 6 wiil object to the form. Can you, can you 6 Q. Okay. Ifyou would tum to —~ keep it in 7 repeat the question just for the record? 7 front of you -- if we tum to Page 22, and we look 8 MR. KUVIN: Yes. 8 at the last paragraph. 9 BY MR. KUVIN: 3 Do you agree that Epstein in the years, d 10 Q. Have you been made aware, or have you -- 10 2005, 2004 and 2005, did commit lewd and lascivious }} 11 let me clarify. Have you seen the probable cause am molestation on a 14-year-old girl? 12 affidavit that was attached to your warrant for 12 MR. RHEINHART: Just if I can clarify, are 13 arrest on May 1, 2006? 13 you asking whether that's what the document 44 MR. RHEINHART: Object to the form. I 14 says? L5 don't believe there ever was a warrant issued, 15 MR. KUVIN: No, I'm asking whether she's 16 but go ahead and answer the question, if you 16 aware of it. 7 can. 17 MR. RHEINHART: Im going to object to the 18 THE WITNESS: No. 18 form. [i calls for a legal conclusion that 19 BY MR. KUVIN: 19 she's not competent to make. That's ambiguous 20 Q. Have you seen the request for a warrant 20 in that regard, and also the standing objection 21 with the attached probable cause affidavit that was al and I will instruct her not to answer. 22 issued on May Ist, 20067 22 THE WITNESS: On the advice of my lawyer, 23 MR. RHEINHART: Object to the form. 23 I must to invoke my Fifth Amendment right. 24 Assumes her knowledge of something that she may | 24 BY MR. KUVIN: PROSE COURT REPORTING AGENCY, Q. Do you agree that in the years 2004 and RTS TTT 3 (Pages 195 to 198) INC. (561) 832-7506

Page 1991 1 2005 Mr. Epstein molested hundreds of 14, 15, and i Jeffrey Epstein took nude photos of girls under the 2 "16-year-old girls? 2 age of 18? 3 MR. RHEINHART: Same objection to the 3 MR. RHEINHART: Objection to the form, 4 form, standing objection and also calls for a 4 standing objection, instruct the witness not to 5 legal conclusion and is ambiguous. Instruct 5 answer. 6 the witness not to answer. € THE WITNESS: On the instruction of my : 7 THE WITNESS: On the instruction of my 7 lawyer, | must invoke my Fifth Amendment right. 8 lawyer, I must invoke my Fifth Amendment right. 8 BY MR. KUVIN: 9 BY MR. KUVIN: 9 Q. Have you taken any photographs of girls 10 Q. Do you agree that the facts contained 10 under the age of 18, nude photographs of girls under }; ii within this probable cause affidavit are true and. 11 the age of 18 yourself? E 12 accurate? 12 MR. RHEINHART: Object to the form as 13 MR. RHEINHART: Objection to the form. 13 ambiguous. Can we get a time period or any 14 You've never established that she's read it, so 14 sort of -is how can she say whether it's true and accurate. 15 MR. KUVIN: Sure. 16 J instruct the witness not to answer the 16 MR. RHEINHART: -- limitation of that? 17 question. Do you want to clarify your 17 MR. KUVIN: Absolutely. 18 question? 18 BY MR. KUVIN: 19 MR. KUVIN: No, 19 Q. Inthe years of 2004 to 2006, did you ever 20 BY MR. KUVIN: 20 taken any nude photographs of underage girls being 21 Q. Were you present at 358 El Brillo Way when | 21 girls under the age of 182 22 the search warrant was issued for that home? 22 MR. RHEINHART: Object to the form as 23: MR. RHEINHART: Objection to the formas | 23 ambiguous. Instruct the witness not to answer. : 24 to any knowledge of 358 El Brillo Way. Also 24 THE WITNESS: On the advice of my lawyer, |} 25 ambiguous. Are you asking about when the 25 I must exercise my Fifth Amendment right. : Page 200 1 warrant was issued or when the warrant was L MR. KUVIN: And just so we're clear, when 2 executed? 2 you say “instruct the witness not to answer,” 3 MR. KUVIN: I don't know. You criminal 3 you mean for the Fifth Amendment grounds as 4 guys know the language. 4 opposed to -5 BY MR. KUVIN: 5 MR. RHEINHART: Well, technically that fj 6 Q. When the cops came into the house and 6 would be manufacturing child pornography, so if |} 7 searched the home at 358 El Brillo Way, were you 7 the truthful answer that question would be yes, 8 there? 8 she would be admitting to a crime. 2 MR. RHEINHART: Objection to the form as 9 MR. KUVIN: No, I understand that. 10 to compound, and assuming knowledge as to 10 MR. RHEINHART: So yes, I'm instructing i 358 El Brillo Way or any search by the police. 11 her not to answer the question. 12 Instruct the witness not to answer. 12 MR. KUVIN: Because there have been some 13 THE WITNESS: On the instruction of my 13 questions that we've instructed her, you've 14 lawyer, I must exercise my Fifth Amendment 44 instructed her not to answer at all, and then a5 privilege. is others —- I just wanted for clarify. 16 BY MR. KUVIN: 16 MR. RHEINHART: Thank you. I was getting § i7 Q. Are you aware of any covert cameras that 7 sloppy. I apologize. 18 exist in the home at 358 EI Briflo Way? 18 MR. KUVIN: That's okay. 19 MR. RHEINHART: Objection to the form. 13 BY MR. KUVIN: 20 Standing objection as it relates to El Briilo 20 Q. Allright. Do you agree that you have — 21 Way, and instruct the witness not to answer. 21 well, let me ask you this: Have you taken any video 22 THE WITNESS: On the instruction of my 22 of girls under the age of 18, nude girls under the 23 lawyer, I must invoke my Fifth Amendment right. | 23 age of 18 in the years 2004 through 20067 (561) BY MR. KUVIN: 2. Are you aware or whether or not 832-7500 PROSE COURT REPORTING AGENCY, Page 202 MR. RHEINHART: Once again -MR. KUVIN: Go ahead. 4 (Pages 199 to 202) Inc. (561) 832-7506

Page 203 Page 205 te MR. RHEINHART: Wait. Hold ona second. - Standing objection as to knowledge of 2 Let me go back to the prior question about 2 Mr. Epstein. Instruct the witness not to 3 still photographs. 3 answer based on the Fifth Amendment. 4 MR. KUVIN: Yes. 4 THE WITNESS: On the instruction of my 5 MR. RHEINHART: Okay. And I think the S lawyer { must exercise my Fifth Amendment 6 question was whetlis had-taken between '04 6 right. 7 and '06 any still photographs of nude women 7 BY MR. KUVIN: 8 under the age of 18. 8 Q. Do you know whether or not an attempt to 9 MR. KUVIN: Yes. 9 give a $90,000 donation was an attempt to stop the 10 MR. RHEINHART: Is that correct? | want 10 Palm Beach Police from investigating Mr. Epstein? il to go back to that question. ii MR. RHEINHART: Objection to the form. 12 MR. KUVIN: Okay. You can go back to that | 12 Standing objection as previously stated, and 13 question. 13 the same instructions as the previous question. 14 THE WITNESS: No. 14 THE WITNESS: At the instruction of my 15 BY MR. KUVIN: is lawyer, I must invoke my Fifth Amendment right. |} 16 Q. Have you taken any nude videotape of girls 16 MR. KUVIN: Hold on a second. Almost 17 under the age of 18 for the years 2004 through 2006? | 17 done. 18 A. No, 18 BY MR. KUVIN: 19 Q. Asking those same questions, have you 19 Q. Is your mother also named Sarah Kellen? 20 taken any nude photographs of girls under the age of | 20 A. No. 21 18 from 2004 through 2006? au Q. Did you ever live at 2644 Peter Street, 22 A. No. 22 Honolulu, Hawaii? 23 Q. Have you taken any nude video of girls 23 MR. RHEINHART: Instruct the witness not 24 under the age of 18 from 2004 to 2006? 24 to answer based on the Fifth Amendment 25 A. No. 25 privilege against self-incrimination. Page 204 Page 206 i Q. Do you know what the COUQ Foundation is? 1 THE WITNESS: On the instruction of my : 2 A. Can you repeat that? 2 lawyer, 1 must invoke my Fifth Amendment right. |! 3 Q. Do you know what the COUQ Foundation is? 3 BY MR. KUVIN: 4 MR. RHEINHART: Mr. Kuvin, can I clarify? 4 Q. Did you ever live at 301 East 66th Street, 5 Are you asking if she's ever heard of such an 5 Apartment 10-N in New York, New York? 6 entity or whether she actually knows what that 6 MR. RHEINHART: Same instruction as t entity is? a. previous question. 8 MR. KUVIN: Let's start with if she’s ever 8 THE WITNESS: On the instruction of my 9 heard over it, and then I will follow up with 9 lawyer, | must invoke my Fifth Amendment right. 10 the following question of whether she knows 10 BY MR. KUVIN: 1i what it is. 11 Q. Have you ever gone by the name of Sarah 12 MR. RHEINHART: Okay. 12 Bonk, B-o-n-k? 13 BY MR. KUVIN: 13 MR. RHEINHART: Same instruction as the 14 Q. Have you ever heard of this, about the 14 previous two questions. 1s COUQ Foundation before? 15 THE WITNESS: On the insiruction of my 4 16 MR. RHEINHART: I instruct her not to 16 jawyer I must invoke my Fifth Amendment right. 7 answer based on her Fifth Amendment privilege. | 17 BY MR. KUVIN: i 18 THE WITNESS: On the advice of my lawyer, | 18 Q. Did you change your name from Sarah Bonk |} 19 I must assert my Fifth Amendment right. 19 to Sarah Kellen? i 20 BY MR. KUVIN: 20 MR. RHEINHART: Objection to the form and 21 Q. Were you aware that Mr. Epstein, through 21 it assumes a prior question that there was no E 22 the COUQ Foundation, attempted to make a $90,000 | 22 answer to, and [ would instruct the witness not 23 donation to the Palm Beach Police Department in 23 to answer. 24 2006? 24 THE WITNESS: Upon the instruction of my (561) 832-7500 PROSE COURT REPORTING AGENCY, invoke my Fifth Amendment right. 5 (Pages 203 to 206) Inc. (561) 832-7506

Page 207 Page 209k i BY MR. KUVIN: 1 compound, instruct the witness not to answer. 2 Q. Have you ever used the alias of 2 THE WITNESS: On the instruction of my 3 Sarah Bonk? 3 lawyer, I must invoke my Fifth Amendment right. } 4 MR. RHEINHART: Objection to the -- I'm 4 BY MR. KUVIN: 5 sorry. Instruct the witness not to answer S Q. Have you ever used illegal drugs with 6 based on Fifth Amendment privileges. 6 Nadia Marcinkova? 7 THE WITNESS: Upon the instruction of my 7 MR. RHEINHART: Same objection and 8 lawyer, I must invoke my Fifth Amendment right, | 8 instruction as to the previous question. 9 BY MR. KUVIN: 9 THE WITNESS: On the instruction of my H Lo Q. Do your parents live in North Carolina? 10 lawyer, I must invoke my Fifth Amendment right. 5 il MR. RHEINHART: Instruct the witness not il BY MR. KUVIN: f 12 to answer the question based on her Fifth 12 Q. Did you ever use the phone number of 13 Amendment privilege. 13 655-0995? 14 THE WITNESS: On instruction of my lawyer | 14 MR. RHEINHART: Instruct the witness not 15 I must invoke my Fifth Amendment right. 15 to answer based on her Fifth Amendment 16 BY MR. KUVIN: 16 privilege. 17 Q. Do you have any brothers and sisters? 17 THE WITNESS: On the instruction of my 18 MR. RHEINHART: Same instruction as the 18 lawyer, I must invoke my Fifth Amendment right. [ 19 previous question. 19 BY MR. KUVIN: 20 THE WITNESS: On the instruction of my 20 Q. Have you ever used the phone number 21 lawyer, | must invoke my Fifth Amendment right. | 21 881-8116, 881-8116. 22 BY MR. KUVIN: 22 MR. RHEINHART: Thank you. 23 Q. Have your parents met Jeffrey Epstein? 23 THE WITNESS: I don't recognize that 24 MR. RHEINHART; Objection to the form. 24 number, 25 Standing objection and also instruct the 25 Page 208 Page 210 1 witness not to answer based on her Fifth 1 BY MR. KUVIN: 2 Amendment privilege. 2 Q. Okay. When the police entered Jeffrey 3 THE WITNESS: On the instruction of my 3 Epstein’s home, they took something that's called a 4 lawyer, I must invoke my Fifth Amendment right. 4 bottle of Peach Flavored Joy Jeliy. Just a 5 BY MR. KUVIN: 5 foundation of what I'm about to ask you. 6 Q. Do your parents know what you've done with 6 Have you ever seen anything called Peach 7 Jeffrey Epstein as it relates to this case? 7 Flavored Joy Jelly ever anywhere, first of all? 8 MR. RHEINHART: Objection to the form as 8 Have you ever seen that before anywhere? 9 stated to the previous question, and same 9 MR. RHEINHART: Just so I am clear about 10 instruction. 10 your question «1. THE WITNESS: On the instruction of my 12 MR. KUVIN;: Not necessarily in a home, 12 lawyer, I must invoke my Fifth Amendment sight. | 12 just anywhere in her entire life has she ever 13 BY MR. KUVIN: 13 seen a bottle of something called Peach 14 Q. Have you ever used illegal drugs with 14 Flavored Joy Jelly. 15 Jeffrey Epstein? 15 THE WITNESS: No, I have not. 16 MR. RHEINHART: Objection to the form. 16 BY MR. KUVIN: 7 Standing objection, instruct the witness not to 17 Q. Okay. Also taken from the home were, was 18 answer. 18 an adult sex toy called a Twin Torpedo which, 19 THE WITNESS: On the instruction of my ig according to Detective Recarey during his deposition 20 lawyer, { must invoke my Fifth Amendment right. | 20 was a double-headed dildo. Not with respect to 21 BY MR. KUVIN: 21 Mr. Epstein, but in your life, have you ever seen 22 Q. Have you ever used illegal drugs with 22 something called a Twin Torpedo or double-headed 23 Ghislaine Maxwell? 23 dildo? 24 MR. RHEINHART: Objection to the form, 24 A. No, [have not. 25 assumes knowledge of Ghislaine Maxwell. It's 25 Qu Also confiscated from the home was soap in tT STS TT (561) 832-7500 a PROSE COURT REPORTING AGENCY, 6 (Pages 207 to 210) INc. (561) 832-7506

Page 211 Page 213 1 the shape of a penis and vagina. Once again, not i THE WITNESS: On the instruction of my 2 necessarily with respect to Mr. Epstein's home, in 2 lawyer, I must invoke my Fifth Amendment right. 3 your entire life have you ever seen soap in the 3 BY MR. KUVIN: 4 shape of a penis and vagina? 4 Q. Do you agree that these corporations that 5 A. Not that I recall. 5 I just mentioned were utilized by Jeffrey Epstein in 6 Q. Do you ever recall being in Ohio? 6 an attempt to have sexual relationships with 2 MR. RHEINHART: Ever in her life? 7 underage girls? 8 MR. KUVIN: The state, ever in her life. 8 MR. RHEINHART: Objection to the form as 9 BY MR. KUVIN: 9 to compound, and also assumes knowledge of 10 Q. Let's start there, recall being in the 10 Mr. Epstein, asks for more than one answer to ii State of Ohio for any reason? 11 the question. I would instruct her not to 12 A. Maybe for a layover, but not that I 12 answer based on her Fifth Amendment privilege 13 specifically remember. 13 because the question assumes knowledge of 14 Q. Okay. Do you know an Ivan Robles? 14 Mr. Epstein. 15 A. No, 15 THE WITNESS: Upon instruction of my 16 Q. Have you seen a gentleman by the name of | 16 lawyer I must invoke my Fifth Amendment right. 17 Alan Dershowitz at the home of Jeffrey Epstein 17 MR. KUVIN: I think I am done. Hang on 18 before? 18 one second. 19 MR. RHEINHART: Objection to the form. | 19 Allright. { appreciate it. That's all 20 Standing objection, presumes knowledge of 20 the questions I have at this time. Reserve the 2u Jeffrey Epstein or his home. Instruct the 2i tight to ask any follow-up questions if other 22 witness not to answer. 22 attorneys raise new and different issues by 23 THE WITNESS: On the instruction of my 23 their questioning. 24 lawyer, 1 must exercise my Fifth Amendment 24 MR. RHEINHART: Understood. 25 right. 25 MR. KUVIN: Pass the witness at this time. Page 212 Page 214 1 BY MR. KUVIN: 1 ‘Who wants to go? Mr. Horowitz, do you have a 2 Q. Have you ever heard of the El Zorro Ranch 2 microphone? 3 Corporation? 3 MR. HOROWITZ: I do. 4 MR. RHEINHART: Instruct the witness not 4 CROSS (SARAH KELLEN) 5 to answer based on her Fifth Amendment 5 BY MR. HOROWITZ: 6 privilege. 6 Q. Ms. Kellen, did you use the telephone 7 THE WITNESS: On the instruction of my 7 number, the (917)855-3363 at any time between 2001 8 lawyer I must exercise my Fifth Amendment 8 and 20067 9 tight. 9 A. On the advice of my lawyer, I must exercise my } 10 BY MR. KUVIN: 10 Fifth Amendment right. aL Q. Have you ever heard of the New York 121 Q. Did you use the telephone number 412 Strategy Group? 12 {917)855-3363 between 200! and 2006 at Jeffrey 13 MR. RHEINHART: Same instruction. 13 Epstein's expense? 14 THE WITNESS: On the instruction of my 14 MR. RHEINHART: Objection to the form in 15 lawyer, { must invoke my Fifth Amendment right. | 15 that it assumes knowledge of Jeffrey Epstein. 16 BYMR.KUVIN: 16 Standing objection as previously stated with 17 Q. Have you ever heard of the Ghislaine 17 Mr. Kuvin. Instruct the witness not to answer, 18 Corporation? 18 based on her Fifth Amendment right. ig MR. RHEINHART: Same instruction. 19 THE WITNESS: On the instruction of my 20 THE WITNESS: On the instruction of my 20 lawyer, I must exercise my Fifth Amendment 21 lawyer, I must invoke my Fifth Amendment right. | 21 Tight. 22 BY MR. KUVIN: 22 BY MR. HOROWITZ: 23 Q. Have you ever heard of the Financial 23 Q. Did you use the telephone number 24 Strategy Group? 24 (917)855-3363 at Jeffrey Epstein's direction? 25 _MR. - RHEINHART: Same instruction. 25 MR. RHEINHAR’ x Same objection as the i 7 (Pages 211 to 214) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 215 Page 21 1 previous question and the same instruction. 1 lawyer, I must choose to exercise my Fifth 2 THE WITNESS: On the instruction of my 2 Amendment right. 3 lawyer, I must exercise my Fifth Amendment 3 BY MR. HOROWITZ: 4 right. 4 Q. Did Jeffrey Epstein ever admit to you that S BY MR, HOROWITZ: 5 between the years 2001 and 2006 he had sexual 6 Q. Was (917)855-3363 a telephone number from| 6 contact with underage girls who came to, quote, work i 7 which you placed telephone calls on behalf of 7 for him? ! 8 Jeffrey Epstein? 8 MR. RHEINHART: Objection to the form, 9 MR. RHEINHART: Same objection as the 9 standing objection previously stated. Also 10 previous question and the same instruction, 10 ambiguous as to the term “work for hin." il THE WITNESS: On the instruction of my aL: Instruct the witness not to answer based on her 12 lawyer, I must invoke my Fifth Amendment right. | 12 Fifth Amendment privilege. 13 BY MR. HOROWITZ: 13 THE WITNESS: On the instruction of my 14 Q. Between 2001 and 2006, was it your job to 14 lawyer, I must choose to exercise my Fifth 15 set up massage tables for Jeffrey Epstein? 15 Amendment right. 16 MR. RHEINHART: Same objection as the 16 BY MR. HOROWITZ: 17 previous question, same instruction. 17 Q. Between the years 2001 and 2006, did 18 THE WITNESS; On the instruction of my 18 Jeffrey Epstein ever tell you that he masturbated in 19 lawyer, | must invoke my Fifth Amendment right. | 19 the presence of underage girls who came to, quote, 20 BY MR. HOROWITZ: 20 work for him? 21 Q. Between 2001 and 2006, was it your job to ai MR. RHEINHART: Objection to the form. 22 arrange massage oils before Jeffrey Epstein's 22 Standing objection previously stated and 23 massages? 23 instruct the witness not to answer. 24 MR. RHEINHART: Objection to the form. 24 THE WITNESS: On the instruction of my 25 it's compound and assumes facts not admitted to 25 lawyer, 1 must exercise my Fifth Amendment Page 216 Page 218 1 be to the knowledge of this witness, and [ 1 right. 2 instruct her not to answer based on her Fifth 2 BY MR. HOROWITZ: 3 Amendment privilege. 3 Q._ Do you know a girl named -- or did you 4 THE WITNESS: On the instruction of my 4 know a girl named Jane Doe No. 2, (spells name), 5 lawyer, I must invoke my Fifth Amendment right. 5 when she was still under the age of 187 ; 6 BY MR. HOROWITZ: 6 A. On the instruction of my lawyer, I must choose b Q. At any time between 2001 and 2006, was it 7 to invoke my Fifth Amendment right. 8 your job to place telephone calls to girls under the 8 Q. Do you acknowledge that Jane Doe No. 2 9 age of 18 when Jeffrey Epstein was in Palm Beachto| 9 came to Jeffrey Epstein's Palm Beach estate in late 10 see if the girls wanted to, quote/unquote, work? 10 2004? aL MR. RHEINHART: Objection to the form as 11 MR. RHEINHART: Objection to the form, 12 compound and instruct the witness not to answer | 12 Standing objection previously stated as to 13 based on her Fifth Amendment privilege. 13 compound and ambiguous, and I instruct the 14 THE WITNESS: On the instruction of my 14 witness not to answer based on her Fifth 15 lawyer, { must invoke my Fifth Amendment right. | 15 Amendment privilege, based on the prior, based 16 BY MR. HOROWITZ: 16 on the prior answer to the prior question, 17 Q. Between the years 2001 and 2006, did you 17 THE WITNESS: Sorry. 18 and Jeffrey Epstein have an understanding between 18 MR. HOROWITZ: There was a question 19 the two of you that the term "work" referred to him 19 pending. 20 having sexual contact with girls under the age of 20 MR. RHEINHART: There was a question 21 18? 21 pending. I have instructed you not to answer. 22 MR. RHEINHART: Objection to the form, 22 THE WITNESS: Oh, then upon the 23 standing object, standing objection, and 23 instruction of my lawyer, I must invoke my 24 instruct the witness not to answer. 24 Fifth Amendment right. 25 THE WITNESS: On the instruction of my 25 STS TT TT ERT TT SR ET REET TT SST TRIS STC TST RETR TAT TA TT AT ET EA TET ATS TT aS TTT 8 (Pages 215 to 218) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

(561) 832-7500 PROSE COURT REPORTING AGENCY, Page 219 Page 221 1 BY MR. HOROWITZ: i THE WITNESS: On the instruction of my E 28 Q. Between the years 2001 and 2006, did 2 lawyer, [ must invoke my Fifth Amendment right. | 3 Jeffrey, did Jeffrey Epstein instruct you to 3 BY MR. HOROWITZ: 4 communicate by telephone to arrange for girls under | 4 Q. Did you tell Jeffrey Epstein that you had S the age of 18 to come to his house for his sexual 5 to confirm by telephone that Jane Doe No. 2 would be f 6 gratification? 6 coming fo his home at a specific time to give him a 7 MR. RHEINHART: Objection to the form. 7 massage? E 8 Standing objection previously stated, and also 8 MR. RHEINHART: Objection to the form, 3 it's ambiguous. Instruct the witness not to 5 standing objection as previously stated, and H 10 answer based on her Fifth Amendment privilege. } 10 the same instruction to the witness. 12 THE WITNESS: On the instruction of my dbs THE WITNESS: On the instruction of my | 12 jawyer, [ must exercise my Fifth Amendment 12 lawyer, I must invoke my Fifth Amendment right. 13 privilege. 13 BY MR. HOROWITZ: 14 BY MR. HOROWITZ: 14 Q. Did Jeffrey Epstein tell you that it was is Q. in late 2004, did you receive a telephone is his intent during the course of Jane Doe No. 2's H 16 call wherein you were told that a girl named Jane 16 visit to his home to have sexual contact with her? i 17 Doe No. 3 was bringing Jane Doe No. 2 to Jeffrey 17 MR. RHEINHART: Objection to the form as 18 Epstein's home? 18 previously stated to the last question and same 19 MR. RHEINHART: Objection to form. 19 instruction to the witness. 20 Standing objection, compound, and instruct the 20 THE WITNESS: On the instruction of my 21 witness not to answer based upon her Fifth 21 tawyer, I must invoke my Fifth Amendment right. 22 Amendment privilege. 22 BY MR. HOROWITZ: 23 THE WITNESS: On the instruction of my 23 Q. Atany point did Jane Doe No. 2 tell you | 24 lawyer, I must exercise my Fifth Amendment 24 that she was 18 years old or older? 25 right. 25 MR. RHEINHART: Objection to the form, Page 220 Page 222 1 BY MR. HOROWITZ: L assumes knowledge of a person by the name of 2 Q. Did Jeffrey Epstein observe you receive a 2 Jane Doe No. 2. It's a compound question and E 3 telephone call wherein you were told that Jane Doe 3 instruct the witness not to answer. 4 No. 3 was bringing Jane Doe No. 2 to his home? 4 THE WITNESS: On the instruction of my 5 MR. RHEINHART: Standing objection to the 5 lawyer, I must invoke my Fifth Amendment right. 6 form as stated to the previous question, same 6 BY MR. HOROWITZ: 7 instruction. 7 Q. In your own mind, is it, is it accurate to 8 THE WITNESS: On the instruction of my 8 say that you never believed that Jane Doe No. 2 was 3 lawyer, [ must invoke my Fifth Amendment right. 9 18 or older, correct? 10 BY MR. HOROWITZ: 10 MR. RHEINHART: Objection to the form, 11 Q. Did Jeffrey Epstein instruct you to li same basis as the prior question, and the same 12 communicate by telephone to arrange for Jane Doe 12 instruction. 13 No. 2 to come to his home for his sexual 13 THE WITNESS: On the instruction of my 14 gratification? 14 lawyer, I must invoke my Fifth Amendment right. 15 MR. RHEINHART: Standing objection as LS. BY MR. HOROWITZ: 16 previously stated, same instruction to the 16 Q. Did Jane Doe No. 2 tell you that she 17 witness. 17 attended Royal Palm Beach High School? 18 THE WITNESS: On the instruction of my 18 MR. RHEINHART: Same objection as the Lg lawyer, I must invoke my Fifth Amendment right. |} 19 previous question, same instruction. 20 BY MR. HOROWITZ: 20 THE WITNESS: On the instruction of my 2i Q. Did Jeffrey Epstein inform you that Jane al lawyer, I must invoke my Fifth Amendment right. 22 Doe No. 2 would be giving him a massage that was 22 BY MR. HOROWITZ: 23 sexual in nature? 23 Q. Are you aware -- did, did Jeffrey Epstein MR. RHEINHART: Standing objection to the tell you that he sexually abused Jane Doe No. 2 when } form and the same instruction to the witness. she was a child? E 9 (Pages 219 to 222) INC. (561) 832-7506

Page 223 Page 2255 1 MR. RHEINHART: Objection to the form. 1 answer that. You can move on. 2 Standing objection relating to Jeffrey Epstein 2 MR. HOROWITZ: You're, you're directing 3 or any knowledge of Jeffrey Epstein. Also as 3 her not to answer that? 4 to Jane Doe No. 2, same instruction to the 4 MR. RHEINHART: I'm directing her not to 5 witness. 5 answer that question because there are, there 6 THE WITNESS: On the instruction of my 6 are legal bases for the objections that 7 lawyer, | must invoke my Fifth Amendment right. 7 underlie the Fifth Amendment invocation, and at 8 BY MR. HOROWITZ: 8 some point presumably a judge will rule on 9 Q. Did Jeffrey Epstein instruct you to take 3 those before the jury ever hears this. 10 Jane Doe No. 2's name and telephone number for the | 10 BY MR. HOROWITZ: iL purpose of calling her to come to his house for more | 11 Q. Ms. Kellen, did you know a girl named Jane 12 sexual activity? 12 Doe No. 3 when she was still a child? 13 MR. RHEINHART: Objection to the form. 13 MR. RHEINHART: Objection to the form as 14 Standing objection, same objection to the 14 to what you mean by when you say a child and 15 previous question, same instruction. 15 also assumes knowledge of a person, so I 16 THE WITNESS: On the instruction of my 16 instruct the witness not to answer. 17 lawyer, I must invoke my Fifth Amendment right. | 17 THE WITNESS: On the instruction of my 18 BY MR. HOROWITZ: 18 lawyer, | must invoke my Fifth Amendment right. 19 Q. Did Jeffrey Epstein instruct you to put 19 BY MR. HOROWITZ: 20 Jane Doe No. 2's name and telephone number intoa | 20 Q. Did, did Jeffrey Epstein instruct you to 21 master journal or log in which you and he archived 21 communicate by telephone with Haley Robson for the |! 22 the names and contact information of teenage girls? 22 purpose of arranging for underage girls to come to i 23 MR. RHEINHART: Objection to the form, 23 his house so that he, Jeffrey Epstein, could engage 24 standing objection, otherwise compound and 24 in sexual activity? 25 instruct the witness not to answer. 25 MR. RHEINHART: Objection to the form. Page 224 Page 2261 1 THE WITNESS: On the instruction of my i Standing objection, compound and ambiguous. 2 lawyer, I must invoke my Fifth Amendment right. } 2 Instruct the witness not to answer on Fifth = * 3 BY MR. HOROWITZ: 3 Amendment grounds. 4 Q. Did you, in fact, place Jane Dos No. 2's 4 THE WITNESS: On the instruction of my 5 name and telephone number into a master journal or 5 lawyer, 1 must invoke my Fifth Amendment right. 6 log in which you and Jeffrey Epstein archived the 6 BY MR. HOROWITZ: 7 names and contact information for teenage girls? 7. Q. Did Jeffrey Epstein instruct you to 8 MR. RHEINHART; Objection to the form, 8 communicate by telephone to arrange for Jane Doe No. 9 same as the previous question, ambiguous and 9 3 to give him a massage? 10 compound, and | instruct the witness not to 10 MR. RHEINHART: Same objection as stated 11 answer. 11 to the previous question, and standing 12 THE WITNESS: On the instruction of my 12 objection, and instruct the witness not to 13 Jawyer, | must invoke my Fifth Amendment right. | 13 answer. 14 BY MR. HOROWITZ: 14 THE WITNESS: On the instruction of my 15 Q. You have asserted a Fifth Amendment 15 lawyer, | must invoke my Fifth Amendment right. 16 objection as to a number of my questions relating to | 16 BY MR. HOROWITZ: 17 Jane Doe No. 2. Is there any reason in your mind a 17 Q. Did Jeffrey Epstein inform you that the 18 jury should not infer from your responses today that | 18 massage Jane Doe No. 3 was to give him would be 13 you did, in fact, assist Mr. Epstein in procuring 19 sexual in nature? 20 minors for sexual activity? 20 MR. RHEINHART: Same standing objection 21 MR. RHEINHART: Right. Objection to the 21 previously stated, and I instruct the witness 22 form. We're not going to answer that, That 22 not to answer. 23 calls for a legal conclusion, and for her to 23 THE WITNESS: On the instruction of my 24 speculate on legal objections that have been 24 lawyer, I must invoke my Fifth Amendment right. made by her counsel, and we're not going to 25 (561) 832-7500 SR HSS IAT RT NS SAT TE TET DT TA TE RT TTT PROSE COURT REPORTING AGENCY, 10 (Pages 223 to 226) INC. (561) 832-7506

Page 227 Page 229 i 1 BY MR. HOROWITZ: 1 MR. RHEINHART: Same objection to the 2 Q. Did Jeffrey Epstein observe you speaking 2 previous question, same instruction. 3 with Haley Robson by telephone arranging for Jane 3 THE WITNESS: On the instruction of my q 4 Doe No. 3 to come to his home to give him a massage? 4 lawyer, I must invoke my Fifth Amendment right. } 5 MR. RHEINHART: Objection to the form. 5 BY MR. HOROWITZ: l 6 Standing objection, otherwise compound and 6 Q. Jane Doe No. 3 told you she attended Royal 7 ambiguous and instruct the witness not to 7 Palm High School, correct? 8 answer, 8 MR. RHEINHART: Instruct the witness not 9 THE WITNESS: On the instruction of my 9 to answer based on her Fifth Amendment 10 lawyer, I must invoke the Fifth Amendment 10 privilege. 11 right. il THE WITNESS: On the instruction of my 12 BY MR. HOROWITZ; 42 lawyer, I must invoke my Fifth Amendment right. f 13 Q. Did you tell Jeffrey Epstein that you had 13 BY MR. HOROWITZ: 14 confirmed by telephone that Jane Doe No. 3 would be 14 Q. Did Jeffrey Epstein instruct you to take 15 coming to his home, his home at a specific time to is Jane Doe No. 3's name and telephone number for the 16 give him a massage? 16 purpose of calling her to come back to his home for {{ 17 MR. RHEINHART: Same objection as stated 17 more sexual activity? 18 to the previous question. Same instruction to 18 MR. RHEINHART: Objection to the form, 19 the witness. 19 standing objection previously stated. Instruct 20 THB WITNESS: On the instruction of my 20 the witness not to answer. 21 lawyer, I must invoke my Fifth Amendment right. 21 THE WITNESS: On the instruction of my i 22 BY MR. HOROWITZ: 22 lawyer I must invoke my Fifth Amendment right. 23 Q. Did Jeffrey Epstein tell you it was his 23 BY MR. HOROWITZ: 24 intent during the course of Jane Doe No. 3's visit 24 Q. Did you, in fact, after Jane Doe No. 3's 25 to his home to engage her in sexual activity? 25 first visit to Jeffrey Epstein's home, call her to Page 228 Page 230 1 MR. RHEINHART: Same objection stated to i arrange for her to come back to his house for more 2 the previous two questions and the same 2 sexual activity? i 3 instruction. 3 MR. RHEINHART: Standing objection to the 4 THE WITNESS: On the instruction of my 4 form of the question. Instruct the witness not 5 lawyer, I must invoke my Fifth Amendment right. 5 to answer. 6 BY MR. HOROWITZ: 6 THE WITNESS: On the instruction of my 7 Q. Did Jeffrey Epstein tell you that during 7 lawyer I must invoke my Fifth Amendment right. {! g the course of Jane Doe No. 3's visit to his home, 8 BY MR. HOROWITZ: 9 that he did, in fact, persuade her to engage in 9 Q. Did Jeffrey Epstein instruct you to put 10 sexual activity? 10 Jane Doe No. 3's name and telephone number into a 11 MR. RHEINHART: Objection to the form. i. master journal or leg in which you and he archived 12 Standing objection previously stated. Instruct 12 the names and contact information for underage LS the witness not to answer. 13 girls? 14 THE WITNESS: On the instruction of my 14 MR. RHEINHART: Objection to the form, 15 lawyer, | must invoke my Fifth Amendment right. | 15 standing objection. Otherwise compound and 16 BY MR, HOROWITZ: 16 ambiguous and instruct the witness not to 17 Q. At any point did Jane Doe No, 3 tefl you 17 answer. 18 that she was 18 or older? i8 THE WITNESS: On the instruction of my 19 MR. RHEINHART: Objection to the form and; 19 tawyer I must invoke the Fifth Amendment. 20 instruct the witness not to answer. 20 BY MR. HOROWITZ: 21 THE WITNESS: On the instruction of my 21 Q. Did you, in fact, put Jane Doe No. 3's i 22 lawyer, I must invoke my Fifth Amendment right. | 22 name and telephone number into a master journal or 23 BY MR. HOROWITZ: 23 log, in which you and Jeffrey Epstein had archived 24 Q. In your mind you didn't believe that Jane 24 the names and information of teenage girls? 25 Doe No. 3 was 18 or older; correct? 25 MR. RHEINHART: Objection to the form, RSTRNT a LS TSE TEE ATT (561) 832-7500 PROSE COURT. REPORTING AGENCY, TT TT TT TTR I RT TT RTT TT TA HTT ITT OTT TTT 11 (Pages 227 to 230) INC. (561) 832-7506

Page 231 Page 233 fi ds standing objection and otherwise compound and ee answer. 2 instruct the witness not to answer. 2, THE WITNESS: On the instruction of my 3. THE WITNESS: On the instruction of my 3 lawyer, | must invoke my Fifth Amendment right. 4 lawyer, [ must exercise my Fifth Amendment 4 BY MR. HOROWITZ: 5 Tight. 5 Q. Did you, in fact, communicate with 6 BY MR. HOROWITZ: 6 Haley Robson by telephone to arrange for Jane Doe 7 Q. Okay. You've asserted a Fifth Amendment 7 No. 4 to come to Jeffrey Epstein's home? 8 objection and assertion of the privilege as to my 8 MR. RHEINHART: Standing objection as 9 questions about Jane Doe No. 3. Is there any reason 9 previously stated, Instruct the witness not to 10 why a jury should not infer from your assertion of 10 answer. 11 the privilege that you did, in fact, assist aL THE WITNESS: On the instruction of my 12 Jeffrey Epstein in procuring minors for his sexual 12 lawyer, [ must invoke my Fifth Amendment right. |} 13 pleasure? 43 BY MR. HOROWITZ: lf 14 MR. RHEINHART: Same objection I stated | 14 Q. Did Jeffrey Epstein inform you that the 15 the last time as to the other client. There is massage Jane Doe No. 4 was to give him would be 16 have been legal objections lodged to the 16 sexual in nature? 17 questions. Ifa judge rules as to the legality 17 MR. RHEINHART: Objection to the form. 18 of the questions and the propriety of the 18 Standing objection previously stated. Instruct 19 answers, then the jury can draw whatever 19 the witness not to answer. 20 inference the judge's instructs them to draw, 20 THE WITNESS: On the instruction of my b 24 but until then we're not going to speculate on 21 lawyer, { must invoke my Fifth Amendment right. f 22 what the jury ought to conclude based on 22 BY MR. HOROWITZ: i 23 questions that haven't been ruled to be proper. 23 Q. Did Jeffrey Epstein observe you speaking E 24 MR. HOROWITZ: So we're clear, youhave | 24 with Haley Robson to arrange for Jane Doe No. 4to ff 25 instructed her not to answer? 25 come to his home for sexual activity? Page 232 Page 234]] 1 MR. RHEINHART: I've instructed her not to i MR. RHEINHART: Objection to the form. 2 answer, yes, . 2 Standing objection as previously stated, and 3 BY MR. HOROWITZ: 3 compound and ambiguous and instruct the witness 4 Q. Ms. Kellen, did you know a girl named Jane 4 hot to answer, 5 Doe No. 4 when she was still a child? 5 THE WITNESS: On the instruction of my 6 A. On the instruction of my lawyer, I must invoke € lawyer, I choose to invoke my Fifth Amendment 7 my Fifth Amendment right. t right. 8 Q. Did Jane Doe No. 4 come to 8 BY MR. HOROWITZ: 9 Jeffrey Epstein's Palm Beach home on multiple g Q. Prior to May of 2005, did you answer phone 10 occasions between 2003 and 2005? 10 calls at Jeffrey Epstein's home from Jane Doe No. 4 4a. MR. RHEINHART: Objection to the form, 1i during which you arranged for Jane Doe No. 4 to come Ff 12 standing objection. Otherwise compound and a2 to Jeffrey Epstein's home? 13 instruct the witness not to answer based on her 13 MR. RHEINHART: Objection to the form. 14 Fifth Amendment privilege. 14 Standing objection previously stated. It's 15 THE WITNESS: On the instruction of my is compound, and instruct the witness not to 16 lawyer, I must choose to invoke my Fifth 16 answer. 17 Amendment tight. 17 THE WITNESS: At the instruction of my 18 BY MR. HOROWITZ: 18 lawyer, I must invoke my Fifth Amendment right. 19 Q. Atany time prior to May of 2005 did 19 BY MR. HOROWITZ: 20 Jeffrey Epstein instruct you to communicate with 20 Q. Prior to May of 2005, did Jeffrey Epstein 21 Haley Robson by telephone to arrange for Jane Doe 21 observe you speaking with Jane Doe No. 4 by 22 No. 4 to come to his home? 22 telephone after your making arrangements for Jeff -23 MR. RHEINHART: Standing objection tothe | 23 for Jane Doe No. 4 to come to his home? compound, and instruct the witness. not to (561) form of the question. Otherwise ambiguous and 832-7500 PROSE COURT REPORTING AGENCY, MR. RHEINHART: Objection to the form, standing o objection, 2 and instruct the witness 12 (Pages 231 to 234) (561) 832-7506 INC.

Page 235 Page 2375 1 not to answer. 1 Standing objection and instruct the witness not 2 THE WITNESS: On the instruction of my 2 to answer. 3 lawyer, I must invoke my Fifth Amendment right. 3 THE WITNESS: On the instruction of my 4 BY MR. HOROWITZ: 4 lawyer, I must invoke my Fifth Amendment right. $ Q. Prior to May of 2005, did Jeffrey Epstein 5 BY MR. HOROWITZ: 6 instruct you to get Jane Doe No. 4's telephone 6 Q. Did Jane Doe No. 4 tell you and 7 number so that you could communicate with her for 7 Jeffrey Epstein that she attended Royal Palm Beach 8 the purpose of scheduling future massages? 8 High School? 9 MR. RHEINHART: Objection to the form, 3 MR. RHEINHART: Objection to the form, 10 standing objection, otherwise compound and 10 standing objection, instruct the witness not to a1 instruct the witness not to answer. il answer. 12 THE WITNESS: On the instruction of my 12 THE WITNESS: On the instruction of my 13 lawyer, I must invoke my Fifth Amendment 13 lawyer, I must invoke my Fifth Amendment right. 14 privilege. 14 BY MR. HOROWITZ: 15 BY MR. HOROWITZ: 15 Q. Did Jane Doe No. 4 regularly discuss her i 16 Q. Did you on multiple occasions tell Jeffrey 16 life at Royal Palm Beach High School with you in the 47 Epstein that you had confirmed by telephone that 1? presence of Jeffrey Epstein? 18 Jane Doe No. 4 would be coming to his home for a--| 18 MR. RHEINHART: Objection to form, 19 at a specific time to give him a massage? 19 standing objection as well as ambiguous as to 20 MR. RHEINHART: Objection to the form. 20 what "regularly" means. Instruct the witness 21 It's compound and standing objection as well, 21 not to answer. 22 and instruct the witness not to answer. 22 THE WITNESS: On the instruction of my 23 THE WITNESS: On the instruction of my 23 lawyer, I must invoke my Fifth Amendment right. 24 lawyer, { must invoke my Fifth Amendment 24 BY MR. HOROWITZ: 2s privilege. 25 Q. Did Jane Doe No. 4 come fo Jeffrey Page 236 Page 238 2 BY MR. HOROWITZ: . 1 Epstein's Palm Beach home on dozens of occasions 2 Q. Did Jeffrey Epstein teil you it was his 2 between 2003 and May of 2005, to give him massages 3 intent during the course of Jane Doe No. 4's visits 3 during which he engaged her in sexual activity? 4 to his home to induce her to engage in sexual 4 MR. RHEINHART: Objection to the form, 5 activity? 5 standing objection. It’s also otherwise 6 MR. RHEINHART: Objection to the form, 6 compound and instruct the witness not to ¢ standing objection and instruct the witness not 7 answer, 8 to answer. 8 THE WITNESS: On the instruction of my 3 THE WITNESS: On the instruction of my 9 lawyer, I must invoke my Fifth Amendment right. 10 lawyer, | must invoke my Fifth Amendment right. 10 BY MR. HOROWITZ: 121 BY MR. HOROWITZ: 11 Q. Prior to May of 2005, did Jeffrey Epstein 12 Q. Did Jeffrey Epstein tell you that, in 12 instruct you to communicate with Jane Doe No. 4, via 13 fact, during Jane Doe No. 4 -- 4's visits to his 13 telephone, to arrange for Jane Doe No. 4 to come to 14 home, he was able to induce her to engage in sexual 14 his Palm Beach home so he could engage Jane Doe 15 activity? 15 No.4 in sexual activity? 16 MR. RHEINHART: Objection to the form, 16 MR. RHEINHART: Objection to the form as 17 same objection as the previous questions. 17 stated in the previous question, Same 18 Instruct the witness not to answer. 18 instruction to the witness. 19 THE WITNESS: On the instruction of my 19 THE WITNESS: On the instruction of my 20 lawyer, I must invoke my Fifth Amendment right. 20 lawyer, I must invoke my Fifth Amendment right. 21 BY MR. HOROWITZ: al BY MR. HOROWITZ: 22 Q. Did both you and Jeffrey Epstein know that 22 Q. Did Jeffrey Epstein instruct you to tell 23 Jane Doe No. 4 was younger than 18 when she came to | 23 Jane Doe No. 4 to lie to police investigators during Jeffrey Epstein's home in 2003 and 20047 24 the course of their 2005 investigation? (561) MR. RHEINHART: Objection to the form. 832-7500 PROSE COURT REPORTING AGENCY, MR. RHEINHART: Objection to the form as SR TTT ETT TT SRT TTT TE 13 (Pages 235 to 238) (561) 832-7506 INC.

20 21 22 23 24 25 {561) Page 239 Page 241 stated to the last several questions and 1 MR, RHEINHART: Objection to the form. instruct the witness not to answer. 2 It's a compound question and standing objection THE WITNESS: On the instruction of my 3 as well. Instruct the witness not to answer. lawyer, I must invoke my Fifth Amendment right. 4 THE WITNESS: On the instruction of my BY MR. HOROWITZ: 5. lawyer, I must invoke my Fifth Amendment right. Q. Did you, in fact, tell Jane Doe No. 4 to 6 BY MR. HOROWITZ: lie to police invest, investigators during the 7 Q. Did you inform Jeffrey Epstein that you course of their 2005 investigation of Jeffrey 8 had been provided Jane Doe No. 5's telephone number? Epstein? 9 MR. RHEINHART: Same objection as the MR. RHEINHART: Object to the form because | 10 previous question, same instruction. it presumes knowledge of Jane Doe No. 4. 41 THE WITNESS: Upon instruction of my Instruct the witness not to answer. 42 lawyer, I must invoke my Fifth Amendment right. THE WITNESS: Upon the instruction of my 13 BY MR. HOROWITZ: lawyer, I must invoke my Fifth Amendment right. 14 Q. Did Jeffrey Epstein instruct you to call BY MR. RHEINHART: is Jane Doe No. 5 to come to his home and give him a Q, Okay. You've asserted a Fifth Amendment 16 massage in either 2001 or 20027 objection and privilege as to my questions about 17 MR. RHEINHART: Objection to the form, Jane Doe No. 4, yourself, and Jeffrey Epstein. Is 18 same objection as the previous questions and there any reason in your mind why a jury should not 19 same instruction to the witness. infer from your assertion of the privilege that you 20 THE WITNESS: On the instruction of my did, in fact, assist Mr. Epstein in committing 21 lawyer, I must invoke my Fifth Amendment right. sexual abuse upon Jane Doe No. 4? 22 BY MR. HOROWITZ: MR. RHEINHART: | am going to instruct the 23 Q. Did Jeffrey Epstein inform you that the witness not to answer the question for the 24 massage Jane Doe No. 5 was to give him would be reasons I stated at the last client that we 25 sexual in nature? Page 240 Page 242 discussed. The questions are legally not 1 MR. RHEINHART: Same objection previously proper in our view, and therefore the questions 2 stated, standing objection and instruct the and answers should not be held against her 3 witness not to answer. until a judge rules on the propriety of the 4 THE WITNESS: Upon the instruction of my questions. And we can address that another Ss fawyer, I must invoke my Fifth Amendment right. day. I'm instructing her not to answer, 6 BY MR. HOROWITZ: BY MR. HOROWITZ: 7 Q. Did Jeffrey Epsiein observe you speaking Q. Okay. Ms. Kellen, do you know a girl 8 with Jane Doe No. 5 on the telephone to arrange for named Jane Doe No. 5 when she was still a child 9 Jane Doe No. 5 to come to his home for a massage? fj under the age of 187 10 MR. RHEINHART: Same objection as previous A. At the instruction my lawyer, I must invoke my [| 11 questions and same, to the form of the f Fifth Amendment right, 12 question, and same instruction. Q. Dida child under the age of 18 named Jane 13 THE WITNESS: Upon the instruction of my Doe No. 5 come to Jeffrey Epstein's Palm Beach home | 14 lawyer, I must invoke my Fifth Amendment right. in approximately 2001 or 2002? 1s BY MR. HOROWITZ: MR. RHEINHART: Objection to the form. 16 Q. Did you tell Jeffrey Epstein that you had instruct the witness not to answer. 7 confirmed by telephone that Jane Doe No. 5 would be THE WITNESS: On the instruction of my 18 at his home at a specific time to give him a lawyer, | must invoke my Fifth Amendment right. 19 massage? BY MR. HOROWITZ: 20 MR. RHEINHART: Objection to the form and Q. In 2001 or 2002 did you inform 21 instruct the witness not to answer. Jeffrey Epstein that you received a telephone call 22 THE WITNESS: On the instruction of my in which you were referred to an underage girl named 23 lawyer, I must invoke my Fifth Amendment right. Jane Doe No. 5 who would be willing to come to his 24 BY MR. HOROWITZ: home to give him a massage for money? 25 Q. Did Jeffrey Epstein tell you that it was 832-7500 PROSE COURT REPORTING AGENCY, a 14 (Pages 239 to 242) Inc. (561) 832-7506

Page 243 Page 245 1 his intent, during the course of Jane Doe No. 5's L Amendment objection or privilege as to my questions 2 visit to his home, to persuade her to engage in 2 about Jane Doe No. 5. Is there any reason in your 3 sexual activity? 3 mind why a jury should not infer that the reason 4 MR. RHEINHART: Objection to the form, 4 you're asserting the Fifth Amendment is because you 5 standing objection. Instruct the witness not 5 and Jeffrey Epstein committed a crime in inducing 6 to answer based on Fifth Amendment. 6 and enticing Jane Doe No. 5 to come to his home for 7 THE WITNESS: On the instruction of my 7 sexual activity? 8 lawyer, | must invoke my Fifth Amendment right. 8 MR. RHEINHART: Once again, I instruct the 3 BY MR. HOROWITZ: 3 witness not to answer. Legal basis is the 10 Q. Did Jeffrey Epstein tell you that during 10 question is not reasonably calculated to tead il the course of Jane Doe No. 5's visit to his home in il to admissible evidence. It's not otherwise 12 either 2001 or 2002 that he succeeded in persuading 12 proper discovery. And for the reasons I stated 13 her to engage in sexual activity with him? 13 as to the prior witnesses, until the legality 14 MR. RHEINHART: Objection to the form, 14 and propriety of the questions is ruled upon by is standing objection. Otherwise compound and 15 the court, there should be no inference drawn. 16 instruct the witness not to answer based on the 16 BY MR. HOROWITZ: 17 Fifth Amendment. Ll? Q. Ms. Kellen -18 THE WITNESS: On the instruction by my 18 MR. RHEINHART: One second. Go ahead. 19 lawyer, I must invoke my Fifth Amendment right. 19 Im sorry. 20 BY MR. HOROWITZ: 20 MR. HOROWITZ: You're conferring about a 21 Q. Did Jeffrey Epstein instruct you to take 21 privilege I trust? 22 Jane Doe No. 5's name and telephone number down so} 22 MR. RHEINHART: Yes, privilege issue. 23 that you and he could call Jane Doe No. Sto cometo | 23 BY MR. HOROWITZ: 24 his home for more sexual activity? 24 Q. Ms. Kellen, do, did you know a girl named 25 MR. RHEINHART: Objection to the form. 25 Jane Doe No. 6 when she was still a child under the Page 244 Page 246} i Instruct the witness not to answer. 1 age of 18? © | 2 THE WITNESS: On the instruction of my 2 A. At the advice of counsel, I must invoke my 3 lawyer, { must invoke my Fifth Amendment right, 3 Fifth Amendment right. 4 BY MR. HOROWITZ: 4 Q. Ms. Kellen, did Jane Doe No. 6 come to ; 5 Q. After Jane Doe No. 5's first visit, did 5 Jeffrey Epstein's Palm Beach home in approximately [ 6 Jeffrey Epstein instruct you to call her on the 6 August of 2004 when she was still a child? i 7 telephone to arrange for her to come back for more 7 MR. RHEFNHART: Objection to the form, 8 sexual activity? 8 standing objection, and instruct the witness 9 MR. RHEINHART: Objection to the form as 9 not to answer. 10 previously stated, and form, standing objection 10 THE WITNESS: On the instruction of ad and instruct the witness not to answer. 11 counsel, I must invoke my Fifth Amendment 12 THE WITNESS: On the instruction of my 12. right. 13 lawyer, I must invoke my Fifth Amendment right. 13 BY MR. HOROWITZ: 14 BY MR. HOROWITZ: | 14 Q. Ms. Kellen, were you aware that Jane Doe 15 Q. Did you, in fact, call Jane Doe No. 5 on 15 No. 6 was just [3 years old when she came to Jeffrey 16 the telephone to arrange for her to come back to 16 Epsicin’s home in August of 2004? 17 Jeffrey Epstein's home for more sexual activity? 17 MR. RHEINHART: Objection to the form. It 18 MR. RHEINHART: Same objection previously | 18 assumes multiple facts. It's therefore i 19 stated, and standing objection, and instruct 19 compound. Instruct the witness not to answer. 20 the witness not to answer and objection to 20 THE WITNESS: On the advice of counsel, 1 21 form. ai must invoke my Fifth Amendment right. 22 THE WITNESS: On the instruction of my 22 BY MR. HOROWITZ: 23 lawyer, I must invoke my Fifth Amendment right. 23 Q. In 2004 did you receive a phone call from (561) BY MR. HOROWITZ: Q 832-7500 PROSE COURT REPORTING AGENCY, agirl named E.W. wherein she stated she was bringing Jane Doe No. 6 to Jefftey Epstein's home 15 (Pages 243 to 246) Inc. (561) 832-7506 Seo

Page 247 Page 249 1 for a massage? 1 THE WITNESS: On the instruction of my 2 MR. RHEINHART: Objection to the form. 2 lawyer, I must invoke my Fifth Amendment right. 3 Instruct the witness not to answer. 3 BY MR. HOROWITZ: 4 THE WITNESS: On the advice of counsel, I 4 Q. Did Jeffrey Epstein observe you speaking 5 must invoke my Fifth Amendment right. 5 with E.W. by telephone to arrange for Jane Doe No. 6 ff 6 BY MR. HOROWITZ: 6 to come to his home for a massage? 7 Q. Did Jeffrey Epstein instruct you to 7 MR. RHEFNHART: Objection to the form, 8 communicate by telephone with E.W. for the purpose{ 8 standing objection and otherwise compound 9 of under -- arranging for underage minor girls to 9 instruct the witness not to answer. 19 come to his home for a massage? 16 THE WITNESS: On the instruction of my £1, MR. RHEINHART: Objection to the form. al Jawyer, I must invoke my Fifth Amendment right. 12 its a compound question. Instruct the witness 12 BY MR. HOROWITZ: 13 not to answer, 13 Q. Did Jeffrey Epstein confirm with you that 14 THE WITNESS: On the advice of counsel, I 14 you had spoken with E.W. by telephone to confirm a 15 must invoke my Fifth Amendment right. 15 specific time that Jane Doe No. 6 would be at his 16 BY MR, HOROWITZ: 16 home? 17 Q. Did you, in fact, communicate by telephone 17 MR. RHEINHART: Objection to the form, 18 with E.W. for the purpose of arranging for underage | 18 standing objection. Instruct the witness not 19 minor girls to come to Jeffrey Epstein's home to 19 to answer. 20 give him a massage? 20 THE WITNESS: On the instruction of my 21 MR. RHEINHART: Same objection statedto | 21 lawyer, I choose to invoke my Fifth Amendment 22 the previous question. Same instruction to the 22 right. 23 witness, 23 BY MR. HOROWITZ: 24 THE WITNESS: On the instruction of my 24 Q. Did Jeffrey Epstein tell you that it was 25 lawyer, I must invoke my Fifth Amendment right. | 25 his intention during the course of Jane Doe No. 6's Page 248 Page 250] 1 BY MR. HOROWITZ: 1 visit to his home to persuade her to engage in 2 Q. In 2004 did Jeffrey Epstein instruct you 2 sexual activity with him? 3 to communicate with E.W. by telephone to arrange for} 3 MR. RHEINHART: Objection to the form, 4 Jane Doe No. 6 to give him, to give him a massage 4 standing objection. Instruct the witness not 5 for his own sexual gratification? 5 to answer. 6 MR. RHEINHART: Objection to the form for 6 THE WITNESS: At the instruction of my 7 the same reasons stated to the previous 7 lawyer, I must choose to invoke my Fifth & questions and instruct the witness not fo 8 Amendment right. 9 answer. 9 BY MR. HOROWITZ: 10 THE WITNESS: On the instruction of my 10 Q. Did Jefftey Epstein tell you that during a1 lawyer I must invoke my Fifth Amendment right. 22 the course of Jane Doe No. 6's visit to his home he 12 BY MR. HOROWITZ: 412 succeeded in persuading her to engage in sexual 13 Q. Did you, in fact, communicate with E.W. by 13 activity with him? 14 telephone to arrange for Jane Doe No. 6 to come to 14 MR. RHEINHART: Same objection as stated is Jeffrey Epstein's home for his sexual gratification? i5 to the previous question to form. Instruct the ié MR. RHEINHART: Objection to the form. 16 witness not to answer. 17 Instruct the witness not to answer. 17 THE WITNESS: On the instruction of my 18 THE WITNESS: On the instruction of my 18 lawyer, { must invoke my Fifth Amendment right. [! 19 lawyer, I must invoke my Fifth Amendment right. | 19 BY MR. HOROWITZ: 20 BY MR. HOROWITZ: 20 Q. Did Jeffrey Epstein instruct you to take F 2i Q. Did Jeffrey Epstein inform you that the 21 Jane Doe No. 6's name and telephone number to call 22 massage Jane Doe No. 6 was to give him would be 22 her to come to his home for more sexual activity li 23 sexual in nature? 23 with him? 24 MR. RHEINHART: Objection to the form. 24 MR. RHEINHART: Objection to the form. 25 Instruct the witness not to answer. 25 Instruct the witness not to answer, ST A TT TT TTT I RT RE TTR TE TT TE TT TR TT RA NAT AT at (561) 832-7500 PROSE COURT REPORTING AGENCY, 16 (Pages 247 to 250) INC. (561) 832-7506

BIAHeWrHe Page 251 THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. HOROWITZ: Q. Did you, in fact, take Jane Doe No. 6's name and telephone number down so that you could call her to come to Jeffrey Epstein's home for more sexual activity? MR. RHEINHART: Objection te form. Instruct the witness not to answer. THE WITNESS: At the instruction of my jawyer, I must invoke my Fifth Amendment right. BY MR. HOROWITZ: Q. Did Jeffrey Epstein instruct you to put Jane Doe No. 6's name and telephone number into a master journal or log in which he archived the names and contact information of teenage girls with whom he had sexual activity? MR. RHEINHART: Objection to the form. Instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, { must invoke my Fifth Amendment right. BY MR. HOROWITZ: Q. Did you, in fact, put Jane Dae No. 6's mame and telephone number into a master journal or log in which you and Jeffrey Epstein archived the OOIHRURWHHE Page 253 MR. RHEINHART: Instruct the witness not to answer the question for the legal reasons I previously stated. Also the Fifth Amendment is designed to protect both the innocent and the guilty, and I would just assert the same things I previously said, that until a judge rules on the propriety of the questions, there should be no negative inference drawn from the answer. BY MR. HOROWITZ: Q. Ms. Kellen, are, are you asserting your Fifth Amendment privilege today because you're an innocent person, or to conceal your criminal activity? f MR. RHEINHART: [am going to instruct her not to answer that question. That's not a proper question. She could invoke the Fifth Amendment for any reason. She doesn't have to explain why. Ifa judge wants to ask her that, she'll tell the judge. If you're going to move to, if you're take a five-minute break? MR. HOROWITZ: Sure. i MR. RHEINHART: -- before the next person, if you're done -- F (561) 832-7500 Page 252 names and contact information of teenage girls who would had sexual activity with Jeffrey Epstein? MR. RHEINHART: Objection to the form. Standing objection. It's compound. Instruct the witness not to answer. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right, BY MR. HOROWITZ: Q. Did Jeffrey Epstein instruct you to call E.W. on the telephone to arrange for Jane Doe No. 6 to come back and give him another massage for his sexual pleasure? MR. RHEINHART: Objection to the form, Instruct the witness not to auswer. THE WITNESS: At the instruction of my lawyer, { must invoke my Fifth Amendment right. BY MR. HOROWITZ: Q. Ms. Kellen, you have asserted a Fifth Amendment objection and privilege as to all my questions about Jane Doe No. 6 and Jeffrey Epstein. Is there any reason in your mind why a jury should not infer from your assertion of the privilege that, in fact, you and Jeffrey Epstein engaged in criminal conduct in inducing her te come to his home for his sexual pleasure? PROSE COURT REPORTING AGENCY, Page 254 MR. HOROWITZ: We've got lots more girls. MR. RHEINHART: Okay. That's fine. But now a good breaking point? MR. HOROWITZ: Sure, MR. RHEINHART: Thanks. THE VIDEOGRAPHER: We're now off video record. The time is 3:14 p.m. {A brief recess was held.) THE VIDEOGRAPHER: We're now oni the video}, record. The time is 3:24 p.m. i MR. HOROWITZ: I've been told I can start my questions without Jack Goldberger in the room. MR. RHEINHART: Absolutely. BY MR. HOROWITZ: Q. Ms. Kellen, did you know a, did you know a girl named Jane Doe No. 7 when she was still, still a child under the age of 187 A. At the instruction of my lawyer I must invoke my Fifth Amendment privilege. Q. Ms. Kellen, did a girl named Jane Doe No. 7 come to Jeffrey Epstein's Palm Beach home on multiple occasions between 2003 and May of 2005? MR. RHEENHART: Objection to the form. Instruct, instruct the sritness not te SONI 17 (Pages 251 to 254) (561) 832-7506 INC.

Page 255 Page 257 THE WITNESS: On the instruction of my 1 BY MR. HOROWITZ; lawyer, I must invoke my Fifth Amendment 2 Q. Sure. At any time prior to May of 2005, privilege. ic did Jeffrey Epstein confirm with you that you had i BY MR. HOROWITZ: 4 spoken to Jane Doe No. 7 by telephone and that Faith |] Q. Prior to May of 2005, did you receive a 5 would be coming to his home at a particular time to phone call from a girl named Haley Robson wherein | 6 give him a massage? she told you she was bringing Jane Doe No. 7 to 7 MR. RHEINHART: Object to form. Jeffrey Epstein's home to give him a massage? 8 THE WITNESS: On the instruction of my MR. RHEINHART: Objection to the form. 9 lawyer, | must invoke my Fifth Amendment THE WITNESS: At the instruction of my 10 privilege. lawyer, I must invoke my Fifth Amendment 11 BY MR. HOROWITZ: privilege. 12 Q. And did you, in fact, speak to Jane Doe MR. RHEINHART: We're trying to speed 13 No. 7 by telephone and confirm that Jane Doe No. 7 things along here. 14 would be coming to Jeffrey Epstein's home at a MR. HOROWITZ; Fine. 15 particular time to give him a massage? BY MR. HOROWITZ: 16 MR. RHEINHART; Object to the form. Q. Atany time prior to 2005, did LP: THE WITNESS: On the instruction of my Jeffrey Epstein instruct you to communicate with 18 lawyer, [ must invoke my Fifth Amendment Haley Robson by telephone to arrange for Jane Doe | 19 privilege. No. 7 to give him a massage? 20 BY MR, HOROWITZ: MR. RHEINHART: Objection to the form. 21 Q. Did Jeffrey Epstein tell you it was his THE WITNESS: At the instruction of my 22 intention during the course of Jane Doe Ne. 7's lawyer, I must invoke my Fifth Amendment 23 visits to his home to persuade or entice her to privilege. 24 engage in sexual activity? 25 MR. RHEINHART: Object to form. Page 256 Page 258 | BY MR. HOROWITZ; 1 THE WITNESS: At the instruction of my Q. Did Jeffrey Epstein inform you that the 2 lawyer I must invoke my Fifth Amendment massage Jane Doe No. 7 was to give him would be 3 privilege. sexual in nature? 4 BY MR. HOROWITZ: MR. RHEINHART: Objection to the form. Ss Q. Did Jeffrey Epstein ever tell you that THE WITNESS: At the instruction of my 6 during the course of Jane Doe No. 7's visits to his Hi lawyer, I must invoke my Fifth Amendment 7 home that he succeeded in persuading her or enticing [f privilege. 8 her to engage in sexual activity? BY MR. HOROWITZ: 9 MR. RHEINHART: Object to form. Q. Did Jeffrey Epstein observe you speaking 10 THE WITNESS: At the instruction of my with Haley Robson by telephone to arrange for Jane 11 lawyer I must invoke my Fifth Amendment Doe No. 7 to come to his home to give him a massage | 12 privilege. that was sexual in nature? 43 BY MR. HOROWITZ: MR. RHEINBART: Objection to the form. 14 Q. Ms. Kellen, did you ask Jane Doe No. Thow § THE WITNESS: At the instruction of my 18 old she was when she came to Jeffrey Epstein's home? lawyer, | must invoke my Fifth Amendment 16 MR. RHEINHART: Objection to form. F privilege. 17 THE WITNESS: At the instruction of my BY MR. HOROWITZ: 18 lawyer, I must invoke my Fifth Amendment Q. Atany time prior to May of 2005, did ig privilege. Jeffrey Epstein confirm with you that she (sic) had 20 BY MR. HOROWITZ: spoken to Jane Doe No. 7 by telephone and that Jane 21 Q. And Jane Doe No. 7 never told you that she Doe No. 7 would be coming to his home to give hima | 22 was 18 or older; is that correct? massage? 23 MR. RHEINHART: Objection to form. MR. RHEINHART: I'm sorry. Can you 24 THE WITNESS: On the instruction of my restate your question, Mr. Horowitz? 25 lawyer, I must invoke my Fifth Amendment TA TEA TH TR TT TE TT AT TT TT TERT RT RT LRT ST A TRA TT TE RT A TNT OSA (561) 832-7500 PROSE COURT REPORTING AGENCY, 18 (Pages 255 to 258) INC. (561) 832-7506

(561) Page 259 privilege. BY MR. HOROWITZ: Q. And when Jane Doe No. 7 came to Jeffrey Epstein’s home, she ay to you to look younger than 18, correct? ~ oe MR. RHEINI Jbject to form. THE WITNESS: At the instruction of my lawyer I must invoke my Fifth Amendment privilege. BY MR. HOROWITZ: Q. Did Jane Doe No. 7 tell you that she was a student at Royal Palm Beach High School? MR. RHEINHART: Object to form. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. HOROWITZ: Q. Did Jeffrey Epstein instruct you to take Jane Doe No. 7's name and telephone number down so you can call Jane Doe No. 7 to come to his home for more sexual activity? MR. RHEINHART: Object to form. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. Page 260 BY MR. HOROWITZ: Q. Did you, in fact, take Jane Doe No. 7's name and telephone number down so you could call Jane Doe No. 7 to come to Jeffrey Epstein's home for other sexual activity? MR. RHEINHART: Object to form. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR, HOROWITZ: Q. Did Jeffrey Epstein instruct you to put Jane Doe No. 7's name and telephone number into a master journal or log in which you and he archived the names of, and telephone numbers of teenage girls with whom he wanted to engage in sexual activity? MR. RHEINHART: Object to form, THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. HOROWITZ: Q. Did you, in fact, pat Jane Doe No. 7's name and telephone number into a master journal or log in which you archived the names of teenage girls with whom Jeffrey Epstein did engage in sexual activity? 832-7500 WOIH HY BwWNH PROSE COURT REPORTING AGENCY, Page 261 MR. RHEINHART: Object to form. THE WITNESS: At the instruction of my lawyer I must invoke my Fifth Amendment privilege. BY MR. HOROWITZ: Q. Did Jeffrey Epstein instruct you to call Jane Doe No. 7 to tell her to fie to police officers investigating his criminal activity? MR. RHEINHART: Object to form. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. HOROWITZ: Q. Did you, in fact, call Jane Doe No. 7 to tell her to lie to police officers investigating Jeffrey Epstein’s criminal activity? MR. RHEINHART: Object to form. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. HOROWITZ: TTT Q. Okay. You've asserted a Fifth Amendment # objection or privilege as to all of my questions concerning Jane Doe No. 7 and her visits to Jeffrey |; Epstein. Is there any reason that you can think of Page 262 that a jury should not infer that you are asserting the Fifth Amendment privilege to conceal the criminal activity of yourself and Jeffrey Epstein? MR. RHEINHART: As previously done, I will i instruct the witness not to answer that question. | believe it calls for a legal conclusion. it's also not designed to lead to discoverable evidence, and whether or not any inference should be drawn will be an issue for the jury after the judge rules on the objections to the questions. MR. HOROWITZ: So, did you say you were -- § MR. RHEINHART: I'm instracting her not to answer. MR. HOROWITZ: Thank you. BY MR. HOROWITZ: Q. Ms. Kelien, did you know a girl named Jane Doe No. 8 when she was still a child under the age of 18? A. Upon the instruction of my lawyer, I must invoke my Fifth Amendment right. Q Ms. Kellen, isn't it true that a girl named Jane Doe No. 8 came to Jeffrey Epstein's Palm i Beach home in approximately 2001 or 2002 when she was still a child under the age of 18? 19 (Pages 259 to 262) Inc. (561) 832-7506

Page 263 Page 265 1 MR. RHEINHART: Object to form. 1 BY MR. HOROWITZ: 2 THE WITNESS: On the instruction of my 2 Q. Did you tell Jeffrey Epstein that you had 3 lawyer, I must invoke my Fifth Amendment right. 3. confirmed by telephone that Jane Doe No. 8 would, in 4 BY MR. HOROWITZ: 4 fact, be coming to his home at a particular time to = Q. Ms. Kellen, did you receive a phone call 5 give him a massage? 6 from a girl named Carolyn Andriano that she was 6 MR. RHEINHART: Object to form. 7 bringing Jane Doe No. 8 to Jeffrey Epstein's home 7 THE WITNESS: On the instruction of my 8 for the purpose of giving him a massage? 8 lawyer, I must invoke my Fifth Amendment right. 9 MR. RHEINHART: Object to form. 3 BY MR. HOROWITZ: 10 THE WITNESS: On the instruction of my 10 Q. Did Jeffrey Epstein tell you that it was il lawyer, { must invoke my Fifth Amendment right. ; 11 his intention that, during the course of Jane Doe 12 BY MR. HOROWITZ: 12 No. 8's visit to his home, that he would persuade or 13 Q. Did Jeffrey Epstein instruct you to 13 induce her to engage in sexual activity with him? 14 communicate by telephone with Carolyn Andriano to} 14 MR. RHEENHART: Object to form. 15 arrange for Carolyn to bring underage girls to his 18 THE WITNESS: Upon the instruction of my 16 home for sexual activity? 16 lawyer, I must invoke my Fifth Amendment right. 1? MR. RHEINHART: Object to form. 17 BY MR. HOROWITZ: 18 THE WITNESS: On the instruction of my 18 Q. Did Jeffrey Epstein tell you that, in 19 lawyer, 1 must invoke my Fifth Amendment right. | 19 fact, during the course of Jane Doe No. 8's visit to E 20 BY MR. HOROWITZ: 20 his home, he succeeded in persuading or inducing her 2 21 Q. Did Jeffrey Epstein pay Carolyn Andriano 21 to engage in sexual activity? 22 to bring underage girls to his home for sexual 22 MR. RHEINHART: Object to the form. 23 activity? 23 THE WITNESS: Upon instruction of my 24 MR. RHEINHART: Object to form. 24 lawyer, I must invoke my Fifth Amendment 25 THE WITNESS: On the instruction of my 25 privilege, Page 264 Page 266) 1 lawyer, I must invoke my Fifth Amendment right. i BY MR. HOROWITZ: 2 BY MR. HOROWITZ: 2 Q. Jane Doe No. 8 never told you that she was 3 Q. Did Jeffrey Epstein instruct you to 3 18 years old or older; is that correct? 4 communicate with Carolyn Andriano by telephone to 4 MR. RHEINHART: Object to form. 5 arrange for Jane Doe No. 8 to give him a massage 5 THE WITNESS: Upon the instruction of my 6 that was to be sexual in nature? 6 lawyer, [ must invoke my Fifth Amendment right. | 7 MR. RHEINHART: Object to form. 7 BY MR. HOROWITZ: 8 THE WITNESS: On the instruction of my 8 Q. And when you saw Jane Doe No. 8, she 9 lawyer, I must invoke my Fifth Amendment right. 9 appeared to you to be less than 18; is that correct? 10 BY MR. HOROWITZ: 10 MR. RHEINHART: Object to the form. 11 Q. Did Jeffrey Epstein inform you that the 11 THE WITNESS: On the instruction of my is 12 massage that Jane Doe No. 8 was to give him would be | 12 lawyer, I must invoke nry Fifth Amendment right. [; 13 sexual in nature? 13 BY MR, HOROWITZ: 14 MR. RHEINHART: Object to form, 14 Q. Did Jeffrey Epstein instruct you to call is THE WITNESS: On the instruction of my is Carolyn Andriano on the telephone to arrange for 16 lawyer, I must invoke my Fifth Amendment right. 16 Jane Doe No. 8 to come back and give him another 17 BY MR, HOROWITZ: 17 massage that was to be sexual in nature? 18 Q. Did Jeffrey Epstein observe you speaking 18 MR, RHEINHART: Objection to the form, 19 with Carolyn Andriano by telephone making 19 THE WITNESS: On the instruction of my 20 arrangements for Jane Doe No. 8 to come to his home 20 lawyer, I must invoke my Fifth Amendment right. 21 to give him a massage? 21. BY MR. HOROWITZ: 22 MR. RHEINHART: Object to form. 22 Q. Ms. Kellen, you have asserted a Fifth 23 THE WITNESS: On the instruction of my 23 Amendment objection or privilege as to all of my (561) fawyer, I must invoke my Fifth Amendment right. 832-7500 PROSE COURT REPORTING AGENCY, INC. in your mind why a. jury should not infer that, i in questions about Jane Doe No. 8. Is there any reason [ 20 (Pages 263 to 266) (561) 832-7506

Page 267 Page 269h (561) 832-7500 1 fact, you and Jeffrey Epstein engaged in criminal 1 MR. RHEINHART: Same instruction. 2 activity as it relates to Jane Doe No. 8? 2 THE WITNESS: Upon the instruction of my ff 3 MR. RHEINHART: Instruct the wimess not 3 lawyer, [ must invoke my Fifth Amendment right. 4 to answer the question. 4 BY MR. RHEINHART: 5 MR. HOROWITZ: Do you have the premarked} 5 Q. And did you place at least some of the 6 Exhibit 5, by any chance? 6 calls reflected on that phone bill with an eye 7 MR, RHEINHART: I gave it back to 7 toward arranging for minor children under the age of {i 8 Mr. Kuvin, 8 18 to come to Jeffrey Epstein's home for his sexual 9 MR. HOROWITZ: I'll hand it back to you. 9 pleasure? 10 Sorry. 10 MR. RHEINHART: Object to the form as 12 BY MR. HOROWITZ: con compound and a standing objection, and also 12 Q, Let me ask Ms. Kelien to take a look at 12 instruct the witness not to answer based on 13 what's been premarked as Exhibit 5. 13 Fifth Amendment. 14 MR. RHEINHART: Do you want us to look at | 14 THE WITNESS: Upon the instruction of my 15 the whole thing? i5 lawyer, I must invoke my Fifth Amendment right. 16 MR. HOROWITZ: Well, if we're going to 16 BY MR. HOROWITZ: i 17 take more than a — yeah, we can go off record 17 Q. And with respect to the phone calls. 18 if she's going to look at the whole thing. 18 reflected on the bill which you received, did you 19 MR. RHEINHART: IE you want to ask her 19 answer some of those phone calls with an eye toward fi 20 about every page, we'll look at every page. 20 arranging for procuring underage girls to come to 21: But if you want to just ask some general 21 Jeffrey Epstein's home for his sexual pleasure? 22 questions, perhaps then we can just —- 22 MR. RHEINHART: Object to the, object to 23 MR. HOROWITZ: Well, if you know that 23 the form. Instruct the witness not to answer, 24 you're going to assert the Fifth Amendment -- 24 based on Fifth Amendment privilege. 25 MR. RHEINHART: I doubt we're answering 2 3 THE WITNESS: Upon the instruction of my Page 268 Page 270 1 any questions about it, but go on ahead. And 1 lawyer, I must invoke my Fifth Amendment right. 2 if we need to take a break, we'll take a break. 2 BY MR. HOROWITZ: 3 BY MR. HOROWITZ: 3 Q. Do, does the phone, does the premarked. 4 Q. Okay. Have you had enough of a look at 4 Exhibit 5 reflect phone calls wherein you arranged 5 those records to determine whether those are the 5 for Jeffrey Epstein to meet children under the age 6 telephone records for the cellphone that you used 6 of 18 for his sexual pleasure? 7 during the time periods set forth on those phone 7 MR. RHEINHART: Objection to the form. 8 bills? 8 It's a compound question, instruct the witness 9 MR. RHEINHART: Instruct the witness not 9 not to answer based on the Fifth Amendment. 10 to answer the question based on the Fifth 10 THE WITNESS: Upon the instruction of my 1i Amendiment. 11 lawyer, I must invoke my Fifth Amendment right. 12 THE WITNESS: Upon the instruction of my 12 BY MR. HOROWITZ: 13 lawyer, [ must invoke my Fifth Amendment right. | 13 Q. Would it be accurate to describe Jeffrey 14 BY MR. HOROWITZ: 14 Epstein's home between the years 2001 and 2006 asa f 15 Q. Are the phone calls that the telephone 15 house of horrors? 16 bilis reflect as having been made phone calls that 16 MR. RHEINHART: Object to the form of the 17 were placed by you? 17 question. instruct the witness not to answer. 18 MR. RHEINHART: Same instruction. 18 BY MR. HOROWITZ: 19 THE WITNESS: On the instruction of my 19 Q. Would you say that childhood sexual abuse 20 lawyer, I must invoke my Fifth Amendment right. | 20 was committed at Jeffrey Epstein’s home every day 21 BY MR. HOROWITZ: 21 that he was in Palm Beach County between the years 22 Q. Okay. Are the phone calls that the phone 22 2001 and 2006? 23 bill reflects as having been received on that 23 MR. RHEINHART: Object to the form. It telephone line phone calls that you, in fact, assumes she knows anything about Jeffrey received? Epstein or his home or or when ie is in Palm Beach PROSE COURT REPORTING AGENCY, INC. 21 (Pages 367 to 270) (561) 832-7506

Page 271 Page 273 b 1 County, so instruct her not to answer the 1 compound and assumes facts not within the 2 question. 2 knowledge of this witness. Instruct the 3 THE WITNESS: Upon the instruction of my 3 witness not to answer based on the Fifth 4 lawyer, | choose to assert my Fifth Amendment 4 Amendment. 3 right, 5 THE WITNESS: Upon the instruction of my 6 MR. HOROWITZ: No other questions. 6 lawyer, | must invoke my Fifth Amendment right. 7 MR. RHEINHART: Thank you. Who is next 7 BY MR. WEISSING: 8 up? 8 Q. Beginning in August of 2002, are you aware 9 MR. KUVIN: Next? Do you want to go next? 9 that E,W. was coerced by Jeffrey Epstein into sexual # 10 MS. EZELL: Do you have a trial date? You 10 conduct? 11 may want to go because you have a trial date, ded. MR. RHEINHART: Objection to form, 12 MR. WEISSING: I do, 12 leading. Weil, it's compound. Instruct the 13 MR. KUVIN: Yeah, you do. Whenever you're 13 witness not to answer based on the Fifth 14 ready. Go ahead, After you. 14 Amendment. The question is also ambiguous as 15 MR. RHEINHART: Whenever you're ready. Is | 15 to coercion. 16 our videographer ready. 16 THE WITNESS: Upon the instruction of my 17 THE VIDEOGRAPHER: Oh, yeah. We're all 17 lawyer, { must assert my Fifth Amendment right. 18 good. 18 MR. WEISSING: Are you aware that between i9 MR. RHEINHART: We'te all good? 19 August 2002 and September of 2005, E.W. had 20 THE VIDEOGRAPHER: We never went off the | 20 sexual conduct with Jeffrey Epstein? 21 record. 21 MR. RHEINHART: Object to the form, 22 CROSS (SARAH KELLEN) 22 standing objection. Instruct the witness not 23 BY MR. WEISSING: 23 to answer. 24 Q. Ms. Keilen, Matt Weissing here. Do you 24 THE WITNESS: On the instruction of my 25 know E.W.? 25 lawyer, [ must invoke my Fifth Amendment right. Page 272 Page 274 1 MR. RHEINHART: Instruct the witness not 1 BY MR. WEISSING: 2 to answer the question based on Fifth 2 Q. Okay. Are you aware that between August 3 Amendment. 3 2002 and September of 2005, Jeffrey Epstein engaged 4 THE WITNESS: On the instruction of my 4 in fondiing and inappropriate illegal sexual 5 lawyer, I must invoke my Fifth Amendment right. 5 touching of E.W.? 6 BY MR. WEISSING: 6 MR. RHESNHART: Objection to the form, 7 Q. Have you ever met E.W.? 7 standing objection and ambiguous as to 8 MR. RHEINHART: Object to the form. [ 8 terminology. Instruct the witness not to 9 believe that's been asked and answered several 9 answer, 10 times. Well, not answered several times. But 10 THE WITNESS: Upon the instruction of my Ll fH instruct her once again not to answer the 11 lawyer, I must invoke my Fifth Amendment right. 12 question. 12 BY MR. WEISSING: 13 BY MR. WEISSING: 13 Q. Are you aware that during that same 14 Q. Are you aware that E.W. was 14 years of 14 period, that Jeffrey Epstein engaged in oral sex or is age when she first came to Jeffrey Epstein's mansion | 15 other sexual misconduct with E.W.? 16 in 2002? 16 MR. RHEINHART: Same objection as the 17 MR. RHEINHART: Object to the form. 17 previous question and same instruction to the 18 Instruct the witness not to answer. 18 witness, 19 THE WITNESS: On the instruction of my r9 THE WITNESS: On the instruction of my 20 lawyer, I must invoke my Fifth Amendment right. | 20 lawyer, I must invoke my Fifth Amendment right. 21 BY MR. WEISSING: 21 BY MR. WEISSING: 22 Q. Are you aware that at all times that -- 22 Q. Are you aware that in that same time 23 from 2002 to 2005, when E.W. came to his mansion, | 23 period that Jeffrey Epstein masturbated in the 24 she was a minor child? 24 presence of E.W.? 25 (561) 832-7500 MR. RHEINHART: Object to the form. It's MR. RHEINHART: Objection to the form, 22 (Pages 271 to 274) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 275 Page 277 i standing objection and instruct the witness not 1 answer as well as compound. 2 to answer. 2 THE WITNESS: At the instruction of my 3 THE WITNESS: Upon the instruction of my 3 lawyer, J must invoke my Fifth Amendment right. 4 lawyer, I must invoke my Fifth Amendment right. 4 BY MR. WEISSING: 5 BY MR. WEISSING: 5 Q. Atall times that E.W. was engaged with 6 Q. Are you aware that for all of her 6 the behaviors with Jeffrey Epstein, did he know that |} 7 behaviors with Jeffrey Epstein that B.W. was paid by 7 she was a minor child? 8 him? 8 MR. RHEINHART: Objection to the form, 9 MR. RHEINHART: Objection to the form, 9 calls for speculations as to Mr. Epstein's 10 leading, as well as the standing objection, and 10 mindset, also assumes she knows Mr. Epstein, so al instruct the witness not to answer. 1i I would object as compound and instruct her not 12 THE WITNESS: Upon the instruction of my 12 to answer. 13 lawyer, I must invoke my Fifth Amendment righi. 13 THE WITNESS: At the instruction of my 14 BY MR. WEISSING: 14 lawyer, I must invoke my Fifth Amendment right. 15 Q. Did you pay E.W. for any of her work for 15 BY MR. WEISSING: 16 Jeffrey Epstein? 16 Q. Atall times during her interaction with 17 MR. RHEINHART: Objection to the form. ee. Jeffrey Epstein, did Jeffrey Epstein tell you that 18 Instruct the witness not to answer. 18 he knew that E.W. was a minor child? 19 THE WITNESS: On the instruction of my 19 MR. RHEINHART: Objection to form. 20 lawyer, I must invoke my Fifth Amendment right. 20 THE WITNESS: At the instruction of my 21 BY MR. WEISSING: 21 lawyer, I must invoke my Fifth Amendment right. f 22 Q. Are you aware that Jeffrey Epstein, during 22 BY MR. WEISSING: 23 the period of August 2nd -- 2002 and September of 23 Q. Did Jeffrey Epstein tell you that he 24 2005 committed numerous criminal and sexual offenses} 24 engaged in numerous sexual activities with E.W. 25 against a minor child? 25 between the periods of August 2nd and September -- |; Page 276 Page 278 [ 1 MR. RHEINHART: Objection to the form. 1 August 2002 and September 2005? 2 Calis for a legal conclusion. It's compound 2 MR. RHEINHART: Objection to the form. 3 and ambiguous and instruct the witness not to 3 THE WITNESS: At the instruction of my 4 answer. 4 lawyer, | must invoke my Fifth Amendment right. 5 THE WITNESS; Upon the instruction of my 5 BY MR. WEISSING: 6 lawyer, I must invoke my Fifth Amendment right. 6 Q. Did Jeffrey Epstein tell you that he had a BY MR. WEISSING: 7 sexually exploited E,W. and contributed to her 8 Q. Are you aware that due to the influence of 8 delinquency? 9 Jeffrey Epstein's interaction with E.W., that it led 9 MR. RHEINHART: Objection to form. It's 10 her to a delinquent lifestyle? 10 ambiguous, calls for legal conclusions, and 11 MR. RHEINHART: Objection to the form, ai it's compound. Instruct the witness not to 12 leading. Requires speculation, is ambiguous 12 answer based on Fifth Amendment privilege. 13 and compound, and instruct the witness not to 13 THE WITNESS: On the instruction of my 14 answer. 14 lawyer, | must assert my Fifth Amendment right. 1s THE WITNESS: On the instruction of my 1s BY MR. WEISSING: 16 lawyer, I must invoke my Fifth Amendment right. | 16 Q. Did Jeffrey Epstein ever teli you that he 17 BY MR. WEISSING: 17 intentionally was harming E.W.? 18 Q. Atali times when E.W. was engaged with 18 MR. RHEINHART: Objection to the form. It 19 Jeffrey Epstein, he knew that she was a minor child. | 19 assumes knowledge of Jeffrey Epstein. Instruct 20 MR. RHEINHART: Is that a question or a 20 her not to answer. 2i statement? 21 THE WITNESS: On the instruction of my 22 BY MR. WEISSING: 22 lawyer, I must exert my Fifth Amendment right. 23 Q. Correct? 23 BY MR. WEISSING: 24 MR. RHEINHART: Objection to the form, 24 Q. Did you know that Jeffrey Epstein's 25 (561) 832~7500 leading. J'll instruct the witness not to PROSE COURT REPORTING AGENCY, behavior was causing injury, pain and suffering, and 23 INC. (561} 832-7506 (Pages 275 to 278)

Page 279 Page 281} 1 emotional trauma to E.W.? 1 ambiguous as to "school children." Instruct | 2 MR. RHEINHART: Objection to the form, 2 the witness not to answer. 3 calls for speculation and is otherwise a 3 THE WITNESS: At the instruction of my E 4 standing objection. 4 lawyer, { must invoke my Fifth Amendment right. 8 THE WITNESS: At the instruction of my S BY MR. WEISSING: 6 lawyer, I must invoke my Fifth Amendment right. 6 Q. With regard to the young girls who you 7 BY MR. WEISSING: 7 contacted to set up sexual encounters with 8 Q. Were you aware that Jeffrey Epstein was 8 Jeffrey Epstein, were they between the ages, school 9 using his wealth and the proximity of his mansion to 9 girls between the ages of 13 and 17 years of age? 10 lead young underage girls into having sexual 16 MR. RHEINHART: Objection to the form. 11 behaviors with him? 1. It's compound and instruct the witness not to 12 MR. RHEINHART: Objection to form, 12 answer. 13 standing objection and ambiguous. 13 THE WITNESS: Upon the instruction of my ff 14 THE WITNESS: At the instruction of my 14 lawyer, I must invoke my Fifth Amendment right. 15 lawyer I must invoke my Fifth Amendment right. | 15 BY MR. WEISSING: 16 BY MR. WEISSING: 16 Q. Now, do you believe that Jeffrey Epstein 17 Q. Were you charged with scheduling girls to 17 presents a clear danger to female children in this 18 meet with Jeffrey Epstein? 18 community? 19 MR. RHEINHART: Objection to form, 19 MR. RHEINHART: Objection to form, 20 standing objection. 20 standing objection. 21 THE WITNESS: At the instruction of my 22 THE WITNESS: On the instruction of my 22 lawyer, I must invoke my Fifth Amendment right. | 22 lawyer, { must invoke my Fifth Amendment right. 23 BY MR, WEISSING: 23 BY MR. WEISSING: 24 Q. In scheduling girls to meet with 24 Q. Did Jeffrey Epstein tell you that he was 25 Jeffrey Epstein, did you ever call any escort 25 intentionally engaging in sexual misconduct with Page 280 Page 282} 1 services? 1 B.W. in an effort to hurt her? 2 MR. RHEINHART: Objection to form, 2 MR. RHEINHART: Objection to the form, 3 standing objection. 3 standing objection and also ambiguous. 4 THE WITNESS: At the instruction of my 4 THE WITNESS: On the instruction of my i 5 lawyer I must invoke my Fifth Amendment right. 5 lawyer, I must invoke my Fifth Amendment right. || 6 BY MR. WEISSING: 6 BY MR. WEISSING: 7 Q. Inscheduling sexual encounters for 7 Q. Did Jeffrey Epstein tell you that he knew 8 Jeffrey Epstein, did you ever contact any, any known 8 that his sexual behavior with E.W. was, in fact, Le} prostitutes? 9 injuring her? 10 MR. RHEINHART: Objection to form. 10 MR. RHEINHART: Objection to form. 11 THE WITNESS: At the instruction of my 11 THE WITNESS: At the instruction I must 12 lawyer, I must invoke my Fifth Amendment right, | 12 invoke my Fifth Amendment right. 13 BY MR. WEISSING: 13 BY MR. WEISSING: 44 Q. With regard to the girls who were 14 Q. Were you aware that Jeffrey Epstein 415 scheduled, these were basically school children, 15 touched £.W. with -- in her, in the intimate areas 16 correct? 16 of her body? sai MR. RHEINHART: Objection to form, 17 MR. RHEINHART: Objection to the form, 18 leading, and also a standing objection. 18 both compound, standing objection and 19 THE WITNESS: At the instruction of my 19 ambiguous. 20 lawyer, I must invoke my Fifth Amendment right. | 20 THE WITNESS: On the instruction of my 21 BY MR. WEISSING: 21 lawyer, | must invoke my Fifth Amendment right. 22 Q. Were the girls who you contacted on behalf 22 BY MR. WEISSING: Hl 23 of Jeffrey Epstein, school children in this 23 Q. Are you aware that Jeffrey Epstein 24 community? 24 penetrated E.W.'s vagina? (561) 832-7500 MR. RHEINHART: Objection to form an: PROSE COURT REPORTING AGENCY, : MR. RHEINHART: Objection to the form, 24 (Pages 279 to 282) INC. (561) 832-7506

Page 283 Page 285 1 standing objection. 1 MR. RHEINHART: Objection to the form in 2: THE WITNESS: At the instruction of my 2 that assumes knowledge of Jeffrey Epstein or 3 lawyer, I must invoke my Fifth Amendment right. 3 where his mansion is or what goes on in his 4 BY MR. WEISSING: 4 mansion, so instruct her not to answer it, 5 Q. Are you aware that Jeffrey Epstein touched 5 THE WITNESS: On the instruction of my 6 E.W. in the intimate portions of her body on dozens 6 lawyer, I must invoke my Fifth Amendment right. hs of occasions between August 2002 and September of | 7 BY MR. WEISSING: 8 20052 8 Q. Between August 2002 and September of 2005, f 9 MR. RHEINHART: Objection to the form, 9 did Jeffrey Epstein coerce or engage L.M. in sexual 10 standing objection. 10 activity at his mansion? 41 THE WITNESS: At the instruction of my 41 MR. RHEINHART: Objection to form and 12 lawyer, I must invoke my Fifth Amendment right. {| 12 ambiguous as fo “coercion.” 13 BY MR. WEISSING: 13 THE WITNESS: On the instruction of my 14 Q. Did Jeffrey Epstein tell you that he had 14 lawyer, [ must invoke my Fifth Amendment right. is touched E,W. in the intimate portions of her body 15 BY MR. WEISSING: 16 and penetrated her body with a design to injure her 16 Q. Between August 2002 and September 2005, 17 between August 2002 and September of 2005? 17 did Jeffrey Epstein engage in sexual misconduct with § 18 MR. RHEINHART: Objection to the formas {| 18 L.M.? 19 compound and instruct the witness not to 19 MR. RHEINHART: Objection to the form and 20 answer. 20 ambiguous as to "sexual misconduct." 21 THE WITNESS: On the instruction of my 21 THE WITNESS: At the instruction of my 22 lawyer, I must invoke my Fifth Amendment right. | 22 lawyer, [ must invoke my Fifth Amendment right. 23 BY MR. WEISSING: 23 BY MR. WEISSING: 24 Q. Do you know who L.M. is? 24 Q. Between August 2002 and September of 2005, jj 25 MR. RHEINHART: instruct the witness not 25 did Jeffrey Epstein engage in conduct with L.M. for [fj Page 284 Page 286 } 1 to answer based on the Fifth Amendment. 1 his sexual gratification? 2 THE WITNESS: On the instruction of my 2 MR. RHEINHART: Objection to form. 3 lawyer, { must invoke my Fifth Amendment right. | 3 THE WITNESS: At the instruction of my 4 BY MR. WEISSING: 4 lawyer I must invoke my Fifth Amendment right. 5 Q. Were you aware when L.M. first came to 5 BY MR. WEISSING: 6 Jeffrey Epstein's mansion in 2002 that she was a, 6 Q. Were you aware that between August 2002 7 she was a 14-year-old child? 7 and September of 2005, Jeffrey Epstein engaged in 8 MR. RHEINHART: Objection to the form, 8 sexual, engaged in behavior with L.M. for his sexual 9 Standing objection. 9 gratification? 10 THE WITNESS: At the instruction of my 10 MR. RHEINHART: Objection to the form, the £ li lawyer, I must invoke my Fifth Amendment right. | 11 standing objection previously stated and 12 BY MR. WEISSING: 12 ambiguous. 13 Q. How many minor female children have been 13 THE WITNESS: At the instruction of my 14 brought to Jeffrey Epstein's mansion for the 14 lawyer, I must invoke my Fifth Amendment right. 15 purposes of his sexual gratification? 15 BY MR. WEISSING: 16 MR. RHEINHART: Objection to the form, 16 Q. Between August -- during that same period 17 ambiguous as to time period and standing 17 of time, did Jeffrey Epstein engage in oral sex or 18 objection. 18 other misconduct with L.M.? 19 THE WITNESS: On the instruction of my 19 MR. RHEINHART: Standing objection to 20 lawyer, I must invoke my Fifth Amendment right. {| 20 form. 21 BY MR. WEISSING: 21 THE WITNESS: At the instruction of my 22 Q. Between the years of 2001 and 2005, were 22 lawyer, I must invoke my Fifth Amendment right. 23 more fess or less than 1,000 underage female 23 BY MR. WEISSING: 24 children brought to Jeffrey Epstein's mansion for 24 Q. During that same period of time, did (561) his sexual gratification? 832-7500 PROSE COURT REPORTING AGENCY, INC. Jeffrey Epstein engage in masturbation and fondling (Pages 283 to 286) (561) 832-7506

Page 287 of the minor child's sexual organs? MR. RHEINHART: Can you, can you clarify what you said, "the minor child"? MR. WEISSING: Yes. We're talking about LM. MR. RHEINHART: I just want to make sure you're limiting the question to L.M. MR. WEISSING: All right. MR. RHEINHART: On that basis, we're objecting to the form, and standing objection. it assumes multiple facts this witness does not acknowledge she does have information about, and therefore the question is compound and ambiguous, and I instruct her not to answer. THE WITNESS: On the instruction of my lawyer I must invoke my Fifth Amendment right. BY MR. WEISSING: Q. You knew that during that period of time, that Jeffrey Epstein was engaged in fondling and penetrating the sexual organs of L.M.? MR. RHEINHART: Objection to form, leading, and also a standing objection. THE WITNESS: At the instruction of my lawyer I must invoke my Fifth Amendment sight. COA ewHH Page 289 THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. WEISSING: Q. During that same period did Jeffrey Epstein tell you that he knew that L.M. was a minor child? B MR. RHEINHART: Objection to the form, the }! standing objection. THE WITNESS: At the instraction of my lawyer, I must invoke my Fifth Amendment right. BY MR. WEISSING: Q. Did Jeffrey Epstein tell you that he knew that he was injuring L.M. through numerous sexual encounters with her between August 2002 and September of 2005? li MR. RHEINHART: Objection to the form, and }} standing objection. Also compound question and |} ambiguous, and instruct the witness not to answer the question. THE WITNESS: At the instruction of my lawyer, { must invoke my Fifth Amendment right. BY MR. WEISSING: Q. Did you know that Jeffrey Epstein was injuring L.M. through sexual contact with her during that period of time? (561) Page 288 BY MR. WEISSING: Q. Did you know during that period of time that Jeffrey Epstein was engaging in sexual penetration of L.M.? MR. RHEINHART: Objection to the form, standing objection previously stated. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. WEISSING: Q. During that period of time did you know that L.M. was a minor child? MR. RHEINHART: Objection to form, standing objection and assumes multiple facts and therefore can't be answered without, because the question is too ambiguous. Instruct the witness not to answer, THE WITNESS: At the instruction of my lawyer I must invoke my Fifth Amendment right. BY MR. WEISSING: Q. From August 2002 to September 2005, did Jeffrey Epstein know that L.M. was a minor child? MR. RHEINHART: Objection to the form, calls for speculation and also a standing objection as assuming knowledge of Jeffrey Epstein. Instruct the witni 832-7500 PROSE COURT REPORTING AGENCY, Page 290 MR. RHEINHART; Objection to the form. It [ assumes knowledge of Jeffrey Epstein and L.M. f and instruct the witness not to answer. THE WITNESS: At the instruction of my F lawyer, must invoke my Fifth Amendment right. |} BY MR. WEISSING: i Q. Did you know that the criminal conduct by Jeffrey Epstein against L.M. was causing damage to L.M.? MR. RHEINHART; Objection to the form. It [ calls for a legal conclusion that the witness is not competent to give. Also calls for speculation as to harm, if any, to a person she hasn't even acknowledged that she knows, so it's an improper question. I instruct her not to answer based on the Fifth Amendment. THE WITNESS: At the instruction of my E lawyer I must invoke my Fifth Amendment right. BY MR. WEISSING: Q. Are you aware that in the State of Florida it is a crime to engage in sex, sexual activity with a minor child? A. Can you repeat the question, please? Q Yes. Are you aware that in the State of Fk against, iti is act crime to engage in 26 (Pages 287 to 290) (561) 832-7506 INC.

CS Be tee | CSTE ATTA TEN SSN Page 291 Page 293 1 sexual activity with a minor child? 1 MR. RHEINHART: Objection to the form to 2 MR. RHEINHART: Can -- I'd just ask you to 2 the extent it assumes knowledge of 3 clarify, when you say "sexual activity,” are 3 Jeffrey Epstein or L.M. 4 you using a legal term of art, or do you have a 4 THE WITNESS: At the instruction of my 5 specific definition? 5 lawyer, I must invoke my Fifth Amendment right. 6 MR. WEISSING: Sexual activity. 6 BY MR. WEISSING: 7 MR. RHEINHART: Okay. You mean by an 7 Q. Atall times that Jeffrey Epstein was 8 adult with a minor child? 8 involved with L.M., she was a minor child, or was 2 MR. WEISSING: Yes. 9 she a minor child? 10 MR. RHEINHART: Okay. Hold on one second.; 10 MR. RHEINHART: Objection to the form, a1 Tm going to object. it calls for a legal it standing objection. Jt assumes facts that 12 conclusion. I'm going to instruct her not to 12 there has been no admission this witness knows 13 answer the question. 13 anything about. Instruct her not to answer. 14 MR. WEISSING: No 14 THE WITNESS: At the instruction of my 15 MR. RHEINHART: I'm instructing her not to is lawyer, I must invoke my Fifth Amendment right, 16 answer the question. It calls for a tegal 16 BY MR. WEISSING: 17 conclusion. It's not a factual question that 17 Q. Did Jeffrey Epstein intentionally 18 is designed to lead to discoverable evidence. 18 penetrate L.M. during his, while she was at his 19 BY MR. WEISSING: 19 mansion? 20 Q. Did you know that L.M. was suffering 20 MR. RHEINHART: Same objection to the 21 injury and emotional and psychological trauma as a 21 form. 22 result of the behavior engaged in with her by 22 THE WITNESS: At the instruction of my H 23 Jeffrey Epstein? 23 fawyer, I must invoke my Fifth Amendment right. 24 MR. RHEINHART: Objection to the form, 24 BY MR. WEISSING: 25 Assumes knowledge of the existence of a person 25 Q. Did Jeffrey Epstein engage in masturbation Page 292 Page 294} 1 by the name of L.M. which has not been 1 in front of L.M. while she was a minor child at his 2 acknowledged. I instruct her not to answer. 2 mansion? 3 THE WITNESS: On the advice of counsel, I 3 MR. RHEINHART: Objection to the form. 4 must invoke my Fifth Amendment right. 4 THE WITNESS: At the instruction of my 5 BY MR. WEISSING: 5 lawyer, I must invoke my Fifth Amendment right, 6 Q. Were you at the mansion the first time 6 BY MR. WEISSING: 7 that L.M. came to see Jeffrey Epstein? 7 Q. Did you know that Jeffrey Epstein was 8 MR. RHEINHART: Objection to the form. 8 engaging in sex, his sexual gratification in the 9 Standing objection as to knowledge of 9 presence of L.M.? 10 Jeffrey Epstein or any mansion. 10 MR. RHEINHART: Objection to the form. a. THE WITNESS: On the advice of counsel, I 11 THE WITNESS: On the instruction of my 12 must invoke my Fifth Amendment right. 12 lawyer, | must invoke my Fifth Amendment right. 13 BY MR. WEISSING: 13 BY MR. WEISSING: 14 Q. Did Jeffrey Epstein tell you that he 14 Q. Did you know that Epstein touched L.M. in 15 intended to injure L.M. by engaging her in sexual 15 the intimate portions of her body on numerous, 16 activity? 16 dozens of occasions between August of 2002 and 17 MR. RHEINHART: Object to the form. 17 September of 2005? 18 Assumes knowledge of Jeffrey Epstein and L.M, { 18 MR. RHEINHART: Object to the form. 19 Standing objection. 19 THE WITNESS: At the instruction of my 20 THE WITNESS: On the advice of my lawyer, | 20 lawyer, I must invoke my Fifth Amendment right. 21 I must invoke my Fifth Amendment right. ai BY MR. WEISSING: 22 BY MR. WEISSING: 22 Q. Have you met Jane Doe? L 23 Q. Did Jeffrey Epstein tell you that he 23 A. At the instruction of my lawyer, I must invoke § 24 intended to cause severe emotional distress to L.M. 24 my Fifth Amendment right. 25 by engaging her in asexual activity? 25 Q._ As part of your job, would you set up the teeter (561) 832-7500 TT RTE TTT AT RT TAT SAT ET ST TST TT PROSE COURT REPORTING AGENCY, 27 (Pages 291 to 294) INC. (561) 832-7506

Page 295 Page 297 1 massage table where minor children were escorted in 1 massage table and order them to take their clothes 2 Jeffrey Epstein's mansion? 2 off? 3 MR. RHEINHART: Objection to the form. 3 MR, RHEINHART: Objection to form. 4 It's a compound question that assumes things 4 THE WITNESS: At the instruction of my 5 about her job and other things that are not 5 lawyer, I must invoke my Fifth Amendment right. 6 established and instruct her not to answer. 6 BY MR. WEISSING: 7 THE WITNESS: At the instruction of my 7 Q. After they disrobed, are you aware that he 8 lawyer, I must invoke my Fifth Amendment right. 8 would allow them to massage him? 9 BY MR. WEISSING: 9 MR. RHEINHART: Are we talking about a 10 Q. Between 2001 and 2005 were you an employee} 10 specific person on a specific date, or are you il of Jeffrey Epstein? tl asking a general practice and policy? 12 MR. RHEINHART: Instruct the witness not 12 MR. WEISSING: General. 13 to answer based on Fifth Amendment privilege. 13 MR. RHEINHART: Object to the question as ff 14 THE WITNESS; At the instruction of my 14 ambiguous, open ended, and instruct the witness 15 lawyer, I must invoke my Fifth Amendment right. 15 not to answer. 16 BY MR. WEISSING: 16 THE WITNESS: On the instruction of my i 17 Q. As part of your employment, were you 17 lawyer, I must invoke my Fifth Amendment right. 18 responsible for setting up a massage table in the 18 BY MR, WEISSING: 19 mansion? 19 Q. Are you aware that Jeffrey Epstein 20 MR. RHEINHART: Objection to the form. 20 routinely would turn on, turn onto his back and ask 21 THE WITNESS: On the instruction of my 2i the girls to pinch his nipples? 22 lawyer, [ must invoke my Fifth Amendment right. | 22 IR. RHEINHART: Objection to the form. 23 BY MR. WEISSING: 23 it's a compound question, 24 Q. As part of your employment for, with 24 THE WITNESS: At the instruction of my 25 Jeffrey Epstein, were you responsible for escorting 25 lawyer, 1 must invoke my Fifth Amendment right. Page 296 Page 29: 1 underage gitls to the massage table area in the i BY MR. WEISSING: 2 mansion? 2 Q. After exposing his naked body to these 3 MR. RHEINHART: Objection to form, 3 girls, are you aware that he would then masturbate 4 THE WITNESS: At the instruction of my 4 in their presence? 5 lawyer, I must invoke my Fifth Amendment right. | 5 MR. RHEINHART: Object to the form. You 6 BY MR. WEISSING: 6 keep asking questions about what 7 Q. After escorting underage girls to the 7 Jeffrey Epstein did. She's not acknowledged 8 massage area in the mansion, did you leave them 8 she even knowns a Jeffrey Epstein. You can ask 9 alone? 9 her if Jeffrey Epstein went to the moon; she's 10 MR. RHEINHART: Objection to form. 10 not going to answer the question, but you can 11 THE WITNESS: At the instruction of my iL keeping asking. 12 lawyer, | must invoke my Fifth Amendment right. } 12 THE WITNESS: On the instruction of my 13 BY MR. WEISSING: 413 lawyer, I must inveke my Fifth Amendment right. 14 Q. After the underage girls were left alone, 14 BY MR. WEISSING: 15 are you aware that Jeffrey Epstein appeared either as Q. The amount of, the amount of money given 16 naked or, or wrapped in a towel? 16 to these young girls was dependent upon the extent 17 MR. RHEINHART: Objection to form. Calls | 17 of behavior engaged in by Jeffrey Epstein; is that 18 for speculation and compound question. Assumes} 18 correct? i 19 facts that she's not acknowledged any personal 19 MR. RHEINHART: Objection to form, leading ff 20 knowledge of. 20 and otherwise objection to the form for the 21 THE WITNESS: On the instruction of my al reasons previously stated. 22 lawyer, I must invoke my Fifth Amendment right. | 22 THE WITNESS: On the instruction of my 23 BY MR. WEISSING: 23 lawyer, I must invoke my Fifth Amendment right. (561) Q. Are you aware that after appearing naked girls, he would lay down 832-7500 PROSE COURT REPORTING AGENCY, BY MR. WEISSING: paid more. if they used (Pages 295 to 298) (561) 832-7506 28 INC.

Page 299 Page 301 1 vibrators or sexual toys? 1 lawyer, I must invoke my Fifth Amendment right. |? 230° MR. RHEINHART: Objection to the form. 2 BY MR. WEISSING: 3 THE WITNESS: On the instruction of my 3 Q. Were you aware that during that period of 4 lawyer, I must invoke my Fifth Amendment right. 4 time that Jane Doe was a minor child? s BY MR. WEISSING: 5 MR. RHEINHART: Objection to the form. 6 Q. Regarding Jane Doe, when she was first 6 THE WITNESS: At the instruction of my 7 brought to Epstein's mansion in 2003, she was in 7 lawyer, I must invoke my Fifth Amendment right. 8 middie school, or was she in middle school? 8 BY MR. WEISSING: 4 9 MR. RHEINHART: Objection to form. 9 Q. Were you aware that during that period of 10 THE WITNESS: On the instruction of my 10 time that Jeffrey Epstein engaged in fondiing and iL lawyer, I must invoke my Fifth Amendment right. | 11 sexual touching of Jane Doe? 12 BY MR. WEISSING: 12 MR. RHEINHART: Form. 13 Q. Are you aware that in 2003 when Jane Doe 13 THE WITNESS: At the instruction of my 14 was brought to Epstein’s mansion, she was in middie | 14 lawyer, I must invoke my Fifth Amendment right. 1s school? 15 BY MR. WEISSING: ; 16 MR. RHEINHART: Objection to the form. 16 Q._ During that period of time, were you aware 17 Once again to answer the question, she would 17 that Jeffrey Epstein engaged in masturbation in the 18 have to implicitly admit that she knows Jeffrey 18 presence of Jane Doe? 19 Epstein or knows anything about Jeffrey Epstein 19 MR. RHEINHART: Objection to form. 20 which she is not going to do, so to go onto the 20 THE WITNESS: The instruction of my H 21 second half of the question, it's a compound 21 lawyer, | must invoke my Fifth Amendment right. # 22 question as to whatever happened with 22 BY MR. WEISSING: l 23 Mr. Epstein. But you keep asking her. She's 23 Q. During that period of time, are you aware 24 not going to answer them, So, they're compound | 24 that Jeffrey Epstein engaged in sexual penetration 25 and ambiguous. 25 of Jane Doe? Page 300 Page 3024 1 THE WITNESS: On the instruction of my L MR. RHEINHART: Objection to form. 2 lawyer, I must invoke my Fifth Amendment right. | 2 THE WITNESS: On the instruction of my A 3 BY MR, WEISSING: 3 lawyer, I must invoke my Fifth Amendment right. jj 4 Q. Are you aware that between February 2003 4 BY MR. WEISSING: i 5 and June of 2005 that Jane Doe engaged in sexual $ Q. During that period of time, are you aware 6 conduct with Jeffrey Epstein at his mansion? 6 that Jeffrey Epstein perpetuated that kind of 7 MR. RHEINHART: Objection to the form. 7 behavior upon Jane Doe on dozens of occasions? 8 THE WITNESS; At the instruction of my 8 MR. RHEINHART: Objection to the form. 9 lawyer, I must invoke my Fifth Amendment right. 9 It's ambiguous and otherwise standing 10 BY MR. WEISSING: 10 objection. 1. Q. In 2003 she was only — are you aware that a THE WITNESS: On the instruction of my 12 she was only 14 years of age when she first came to 412 Jawyer, I must invoke my Fifth Amendment right. 13 the mansion? 13 BY MR. WEISSING: 14 MR. RHEINHART: Objection to form. 14 Q. Are you aware that when he was engaging in 1S’ THE WITNESS: At the instruction of my 415 the sexual conduct with Jane Doe, that he wes doing [i 16 lawyer, I must invoke my Fifth Amendment right. | 16 so with the specific intent to cause her emotional : i7 BY MR. WEISSING: i7 and psychological injury and damage? 18 Q. Between February of 2003 and June 2005, 18 MR. RHEINHART: Objection to the form. 19 was Jeffrey Epstein aware that she was 14, 15, 16 19 Calls for a legal conclusion and is ambiguous 20 years of age? 20 and is compound. 21 MR. RHEINHART: Objection to form. Calls | 21 THE WITNESS: The instruction of my lawyer j} 22 for her to speculate on the state of mind of a 22 I must invoke my Fifth Amendment right. ; 23 person she's not admitting she has any 23 BY MR. WEISSING: 24 knowledge of. 24 Q. Did Jeffrey Epstein tell you that when he i I cond ith Jane Dor (561) : At the instruction of. 832-7500 PROSE COURT REPORTING AGENCY, would engage 29 (Pages 299 to 302) INC. (561) 832-7506

Page 303 that he was intentionally and deliberately attempting to cause her psychological and emotional pain and suffering? MR. RHEINHART: Objection to form for the reasons previously stated. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. WEISSING: Q. Did you see evidence that Jeffrey Epstein's sexual misconduct with her led to emotional distress on her behalf? MR. RHEINHART: Objection to the form. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. WEISSING: Q. Are you aware that all of Jeffrey Epstein's behavior with the minor children were violations of numerous criminal laws? MR. RHEINHART: Objection to the form. It calis for a legal conclusion. I will instruct her not to answer the question at all. BY MR. WEISSING: Q. Did you know that Jeffrey Epstein's behavior with these minor children was criminal in nature? Page 3055 going to instruct the witness not to answer it at all. BY MR. WEISSING: Q. Okay. Did you engage in an agreement with Jeffrey Epstein that you would seek out underage female children for his sexual gratification? MR. RHEINHART: Objection to the form. It's a compound question. Instruct the witness. not to answer. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. |; BY MR. WEISSING: Q. Are you aware that Jane Doe was injured as a result of sex trafficking committed against her? MR. RHEINHART: Objection to form. Uses ff legal terminology like "sex trafficking," and 1 presumes as part of the question that she knows a person by the name of Jane Doe, which she does not acknowledge. Therefore she's not going to answer the question in that form. I instruct her not to answer, based on Fifth Amendment because the answer would implicitly # acknowledge that she knows these people or that she knows Mr. Epstein, THE WITNESS: On the instruction of my (561) 832-7500 Page 304 MR. RHEINHART: Objection to the form. It assumes she has knowledge of whatever conduct Jeffrey Epstein, whoever that may be, may have engaged in. So it requires her to speculate as to a legal conclusion that she's not going to give. BY MR. WEISSING: Q, Through the course of your employment with Jeffrey Epstein, were you paid bonuses or any kind of additional monies for bringing minor children for his sexual gratification to him? MR. RHEINHART: Objection to form. Assumes facts such as that she ever worked for Jeffrey Epstein or has any immediate knowledge, is otherwise compound and ambiguous, and instruct her not to answer. THE WITNESS: At the instruction of my lawyer, I must exert my Fifth Amendment right. BY MR, WEISSING: Q. Did you conspire with Jeffrey Epstein to gain access to minor children for his sexual gratification? MR. RHEINHART: It's a question that calls for a legal conclusion, It doesn't in any way lead to any discoverable evidence, and [am Page 306 lawyer, { must invoke my Fifth Amendment right. p BY MR. WEISSING: Q. Are you aware that Jane, Jane Doe suffered emotional and psychological trauma and injury as a result of the behavior engaged with her by Jeffrey Epstein? MR. RHEINHART: Same objection as stated E to the previous question and instruct the [ witness not to answer, because to attempt to answer that question would implicitly admit that she knows Jeffrey Epstein or knows anything about Jane Doe. THE WITNESS: On the instruction of my lawyer, 1 must invoke my Fifth Amendment right. § BY MR. WEISSING: Q. With regard to these girls who were being procured for Jeffrey Epstein, did you arrange for their travel to the mansion? MR. RHEINHART: Objection to the form, ambiguous to the term "procurement," and for the reasons previously stated, and the standing objection, and instruct the witness not to answer the question. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. 30 (Pages 303 to 306) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 307 Page 309 1 BY MR. WEISSING: 1 BY MR. WEISSING: 2 Q. In your work for Jeffrey Epstein, did you 2 Q. Are you aware that Jeffrey Epstein engaged 3 coordinate efforts with others in bringing minor 3 in sexual misconduct with Jane Doe at least 20 times 4 female children to his mansion for his sexual 4 between February 2003 and June 2005 while she was a |} 5 gratification? . 5 minor child? 6 MR. RHEINHART: Objection to the form. 6 MR. RHEINHART: Objection to the form. 7 Same objection previously made to the standing 7 THE WITNESS: On the instruction of my 8 objection. 8 lawyer, I must invoke my Fifth Amendment right. S$ THE WITNESS: At the instruction of my 9 BY MR. WEISSING: 10 lawyer, I must invoke my Fifth Amendment right. 10 Q. In the scheduling of girls for il BY MR. WEISSING: 14 Jeffrey Epstein, did he have a particular interest 12 Q. Were you aware that many of the girls 12 in girls under the age of 14? 13 brought to Epstein's were minor -- Epstein mansion 13 MR. RHEINHART: Objection to the form. It 14 were minors, under at age of 14 years of age? 14 assumes she did scheduling for Jeffrey Epstein. 15 MR. RHEINHART: Object to the form. 15 In order to answer the question, she has to 16 Instruct the witness not to answer. 16 implicitly admit that which she's not 17 THE WITNESS: At the instruction of my 17 admitting, and therefore she's not answering 18 lawyer, I must invoke the Fifth Amendment 18 the question. 19 right, 19 THE WITNESS: At the instruction of my 20 BY MR. WEISSING: 20 lawyer, I must invoke my Fifth Amendment right. 21 Q. Did you coordinate with some of the girls 21 BY MR. WEISSING: 22 to bring other underage female children to Epstein 22 Q. In procuring girls for Jeffrey Epstein, 23 for his sexual gratification? 23 was he primarily interested in young, skinny and 24 MR, RHELNHART: Objection. Can we narrow | 24 attractive girls? 25 down “other girls” and who we are talking 25 MR. RHEINHART: Objection to the form and Page 308 Page 310}, i about? We already have questioning from i implicitly assumes that she procured girls for 2 Mr, Horowitz about his clients and Mr. Kuvin 2 Jeffrey Epstein, which she has not admitted to 3 about his clients. Can we narrow that down a 3 or is not admitting to, so therefore she can't 4 little bit? 4 fairly answer the question as it's been asked, 5 MR. WEISSING: I'm asking about whether or 5 so therefore, [ will instruct her not to answer 6 not she had someone she coordinated with to 6 it. 7 bring other girls. Okay? 7 THE WITNESS: On the instruction of my 8 MR. RHEINHART: And same form objection. 8 lawyer, I must invoke my Fifth Amendment right. 9 THE WITNESS: On the instruction of my 9 BY MR. WEISSING: 10 lawyer, I must invoke my Fifth Amendment 10 Q. With regard to the amount paid to the i. privilege. 1 girls for what they did with Jeffrey Epstein, would 12 BY MR. WEISSING: 12 the standard payment be several hundred dollars? 13 Q. When you scheduled these girls te come to 13 MR. RHEINHART: Objection to the form, 14 the mansion, you knew that they were coming for 14 standard objection. 15 Jeffrey Epstein's sexual gratification, did you not? 15 THE WITNESS: At the instruction of my 16 MR. RHEINHART: Objection to the form. 16 lawyer, [ must invoke my Fifth Amendment right. 17 It's a compound question that assumes she did 7 BY MR. WEISSING: 18 scheduling, assumes she brought them to the 18 Q. Did he have a standard escalation of the 19 mansion, assumes she knows what the mansion is, | 19 amount that he would pay depending upon the nature 20 and assumes she knows who Jeffrey Epstein is. 20 of the sexual acts that he performed with them? ! 21 So it's a compound question that she can't 21 MR. RHEINHART: Objection, objection. The [} 22 fairly answer without ~- in the form that it's 22 question has been asked and answered in i 23 asked and instruct ber not to answer. 23 different forms several times, and again THE WITNESS: At the instruction of my 24 standing objection as to the form of the (561) lawyer, [ must invoke my Fifth Amendment right. 832-7500 PROSE COURT REPORTING AGENCY, i (Pages 307 to 310) (561) 832-7506 31 INC.

DIARY BRWNHHE Page 311 THE WITNESS: At the instruction of my lawyer, | must invoke my Fifth Amendment right. BY MR. WEISSING: Q. The engaging in sexual practices with underage girls, was this something that went on for a substantial period of time? MR. RHEINHART: Objection to the form. It's ambiguous. It assumes facts that she's not conceding, and she can't fairly answer the question based on the assumptions that are made in it. I will therefore instruct her not to answer the question. THE WITNESS: At the instruction of my lawyer I must exercise my Fifth Amendment right. BY MR. WEISSING: Q. With regard to the payments made to the girls, would he make bigger payments to these minor girls depending upon the degree of force he used towards them? MR. RHEINHART: Objection to the form. It assumes numerous facts that have not been established nor that this witness is admitting, So, I instruct her not to answer. THE WITNESS: At the instruction of my OAD BWNE Page 313 happen? l MR. RHEINHART: Objection to the form for the same reasons previously stated. l THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. WEISSING: I Q. Are you aware that Epstein received sexual gratification from sexually abusing minor children? MR. RHEINHART: Object to the form. It calls for a legal conclusion and it's ambiguous, and the standing objection as to any knowledge of Jeffrey Epstein or any abuse of tmainor children. THE WITNESS: At the instruction of my i lawyer, I must invoke my Fifth Amendment right. | BY MR. WEISSING: Q. Did Jeffrey Epstein ever tell you that he received sexual gratification from sexually abusing minor children? E MR. RHEINHART: Objection to the form for the same reasons previously stated. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. } MR. RHEINHART: Folks, it's 4:20, We've been at this for a long, long time. This is (561) 832-7500 Page 312 lawyer, I must invoke my Fifth Amendment right. BY MR. WEISSING: Q, Along that line, would he make greater payments; larger payments to the girls if they ~ if he was more concerned about them reporting the crimes committed against him? MR. RHEINHART: Objection to the form. It calls for speculation. It calls for a legal conclusion, It assumes facts that have not been admitted. Standing objection to the form. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. Would you pay the girls more money because of the amount of force used by Jeffrey Epstein against them and feared that they would report the crimes committed against them? MR. RHEINHART: Objection to the form. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. WEISSING: Q. Are you aware that after having unlawful sex with these minor children, that Epstein would tell them hot to tell anyone or bad things would PROSE COURT REPORTING AGENCY, Page 314 now getting pointless, and we're terminating the deposition at 5:00. So I suggest you pick up the pace. You can ask a million questions about what Jeffrey Epstein knew, what Jeffrey Epstein did. She doesn't know. She's not going to say, so we've got 40 minute and we're out of here. MR. GARCIA: I haven't asked any questions. MR. EDWARDS: There others of us that have questions. MR. RHEINHART: You can take that up with the judge, We're done at 5:00. MS. EZELL: For the record, there are some filed cases who attomeys have not been able to ask questions, and we certainly assert our Tight to call Ms. Keilen again. a MR. RHEINHART: You can, you can certainly ff take that up, but Iam not, you know, how many, fl how many times do we have to ask the same question over and over and over again that it's clear is a compound question that asks her to assume facts that she's not admitted she knows anything about and it’s a hypothetical question not designed to get us anywhere. 32 (Pages 311 ‘to 314) {561} 832-7506 INC.

(561) Nadia Marcinkova at Jeffrey Epstein's mansion? MR. RHEINHART: Objection to the form. 832-7500 PROSE COURT REPORTING AGENCY, with underage Q. Did Jeffrey Epstein have sexual encounters ople while at that apartment? Page 315 Page 317 1 So can we focus on the specific questions 1 THE WITNESS: On the instruction of my 4 2 that she can answer or from which you can draw 2 lawyer, I must invoke my Fifth Amendment 3 an adverse inference if asked properly, and 3 privilege. 4 let's move it along. 4 BY MR. WEISSING: S MS. EZELL: Each young woman's case is an 5 Q. Do you know Alan Dershowitz? 6 individual case, and we have the right to ask, 6 MR. RHEINHART: The questicn was asked and }! 7 ask whatever questions that we need to with 7 answered about three-and-a-half hours ago. : 8 regard to each one. 8 THE WITNESS: On the instruction of my 9 MR, RHEINHART; I~ 3 lawyer, I must invoke my Fifth Amendment 10 MR. GOLDBERGER: Let's just go forward Lo privilege, il untit 5:06 and see where we're at. iL BY MR. WEISSING: : 12 BY MR. WEISSING: 12 Q. Do you know David Copperfield? i 13 Q. Did you know that Jeffrey Epstein received 13 MR. RHEINHART: That question was asked 14 sexual gratification from directing others to 14 about three-and-a-half-hours ago. is sexually abuse minor children? 15 THE WITNESS: On the instruction of my 16 MR. RHEINHART: Objection to the form. 16 lawyer, I must invoke my Fifth Amendment 17 THE WITNESS: On the instruction of my 17 privilege. 18 lawyer, | must invoke the Fifth Amendment 18 BY MR. WEISSING: 19 right. 19 Q. In addition to his place at, in Palm 20 BY MR. WEISSING: 20 Beach, are you aware that Jeffrey Epstein has an R 21 Q. Did you know that Jeffrey Epstein received 21 apartment located at 301 East 66th Street, Apartment 22 sexual gratification from directing Marcinkova to 22 14G through E in New York? 23 sexually abuse miner children? 23 MR. RHEINHART: That question was asked ; 24 MR. RHEINHART, Objection to the form, It 24 about four hours ago. It's been asked and 25 assumes knowledge of'a person named Marcinkova. | 25 answered. j Page 316 Page 318 1 It is otherwise compound and objectionable. 1 THE WITNESS: At the instruction of my 2 THE WITNESS: On the instruction of my 2 lawyer, I invoke my Fifth Amendment privilege. |} 3 lawyer, I must invoke my Fifth Amendment right. 3 BY MR. WEISSING: ‘I 4 MR. WEISSING: Let's go off the record for 4 Q. While in New York, have you procured ql 5 a moment. 5 underage minor children to engage in sexual acts 6 THE VIDEOGRAPHER: Are we all good with} 6 with Jeffrey Epstein at that location? 7 going off the record? 7 MR. RHEINHART: Object to the form. i 8 MR. RHEINHART: Yeah, that's fine. 8 THE WITNESS: On the instruction of my {i 9 MR. HOROWITZ: Yes. 9 lawyer, I must invoke my Fifth Amendment i 10 THE VIDEOGRAPHER: We're now off the 10 privilege. yo 11 record at 4:22 p.m. 11 BY MR. WEISSING: t 12 (A brief recess was held.) 12 Q. With regard to the minor children procured 13 THE VIDEOGRAPHER: We are now on the 13 for him at that location, were they schoo! children 14 record. ft is 4:24 p.m. 14 in the New York area? is BY MR. WEISSING: 15 MR. RHEINHART: The previous question, 16 Q. Do you know Nadia Marcinkova? 16 objection to the form. The same as all the ad MR. KUVIN: Marcinkova. 17 previous questions, it assumes a fact that's 18 THE WITNESS: On the instruction of my 18 not been established. It can't fairly be 19 lawyer, I must invoke my Fifth Amendment 19 answered. 20 privilege. 20 THE WITNESS: On the instruction of my 21 BY MR. WEISSING: 21 lawyer, I must invoke my Fifth Amendment 22 Q. Do you know -- have you procured minor 22 privilege. | 23 children to have sexual relations with 23 BY MR. WEISSING: 33 (Pages 315 to 318) INC. (561) 832-7506

MAHER WHE Page 319 MR. RHEINHART: Objection to the form. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. With regard to underage children that he had sexual encounters with in New York, were those school children in that area? MR, RHEINHART: Objection to the form. No factual basis for the question. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. Are you aware of another location that he has at 457 Madison Avenue, lower floor, New York? MR. RHEINHART: Objection to the form. THE WITNESS: At the instruction my lawyer I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. Are you aware of Jeffrey Epstein having sexual encounters with underage children at that location? MR. RHEINHART: No factual basis for the question. Objection to form. DIK WNH Page 321 privilege. BY MR. WEISSING: Q. Have you been to Jeffrey Epstein's property at 6100 Red Hook Quarters, Suite 3-B, in St. Thomas, the Virgin Islands? : A. On the instruction of my lawyer, I must invoke § my Fifth Amendment privilege. Q. Over what period of time have you been to that location? MR. RHEINHART: Objection to the form. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. Are you aware of Jeffrey Epstein engaging in sexual encounters with underage persons at that location? MR. RHEINHART: Objection to the form. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. With regard to the underage children he engaged in sexual activity with at that location, where were those children procured from? (561) Page 320 THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. Was it part of your employment to obtain underage children for sexual encounters with him at that location? MR. RHEINHART: Objection to the form. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. With regard to the underage children he had sex with at that location, were those school children from that area? MR. RHEINHART: Can I ask what the good faith basis is to ask the question if he actually had sex with someone at that location? Because I, I know no factual predicate that I have heard today for asking the questions, so I will instruct the witness not to answer it because it presumes that she knows Jeffrey Epstein. THE WITNESS: On the instruction of my lawyer, | must invoke my Fifth Amendment 832-7500 PROSE COURT REPORTING AGENCY, sexual encounters Page 322), MR. RHEINHART: Objection to the form. It ff assumes facts that there has not been any basis i to assume this witness has any knowledge of. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. Were you, were you engaged by Jeffrey Epstein to procure schoo! children from the Virgin Islands area for sexual behavior at that location? MR. RHEINHART: Objection to the form. Standing objection, it assumes knowledge of Jeffrey Epstein. THE WITNESS: At the instruction of my lawyer I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. Who is Story Cowles? MR. RHEINHART: Objection to the form. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. Did Mr. Cowles in your presence ever have 34 (Pages 319 to 322) INC. (561) 832-7506

ec Page 323 Page 3258 1 Mr. Epstein's properties? 1 MR. WEISSING: I have no other questions. 2 MR. RHEINHART: Objection to the form. It} 2 MR. RHEINHART: Okay. Ms. Ezell, 3 assumes knowledge of Mr. Epstein. 3 Mr. Garcia, do you want to go next? 4 THE WITNESS: At the instruction of my 4 MR. GARCIA: Is it okay if | go? 5 lawyer, I must invoke my Fifth Amendment 5 MS. EZELL: We were just discussing that. 6 privilege. 6 I'm going to go quite a while, and I believe 7 BY MR. WEISSING: 7 you think you can finish in 30 or 40 minutes, 8 Q. Were you, did you participate in procuring 8 50... 9 underage children for having sex with Mr. Cowles at} 9 MR. GARCIA: About 45. About 45 minutes. 10 Mr. Epstein's properties? 10 MS. EZELL: It makes sense for Mr. Garcia 11 MR. RHEINHART: Objection to the form. It} 11 to go first. 12 assumes knowledge of Mr. Epstein. 12 MR. RHEINHART: Your decision. Do you 13 THE WITNESS; At the instruction of my 13 need a break or are you okay? 14 lawyer, [ must invoke my Fifth Amendment 14 THE WITNESS: I'm okay. 15 privilege. 15 MR. RHEINHART: I'll slide over. 16 BY MR. WEISSING: 16 THE VIDEOGRAPHER: Are we ona break? |! 17 Q. Have you ever heard of Sarah Kensington? 17 MR. KUVIN: No, no breaks. i 18 MR. RHEINHART: Objection to the form. 18 CROSS (SARAH KELLEN) 19 THE WITNESS: On the instruction of my 19 BY MR. GARCIA: 20 lawyer, I must invoke my Fifth Amendment 20 Q. Ms. Kellen, I think you've already 21 privilege. al answered this question about your cell number. Are [/ 22 MR. WEISSING: Okay. Let's you objected 22 you able to tell me if you have a new cell number 23 to the form. 23 other than the one that was given to you which ! 24 MR. RHEINHART: I'm sorry. I didn't mean | 24 believe was (917}855-3363? 25 to object to form. That one I apologize. Just 25 MR. RHEINHART: Instruct the witness not Page 324 Page 326} i instruct the witness not to answer the i to answer the question based on her Fifth 2 question. 2 Amendment privilege. 3 BY MR. WEISSING: 3 THE WITNESS: At the instruction of my i 4 Q. Have you ever gone by the name 4 lawyer, I must invoke my Fifth Amendment right. [} 5 Sarah Kensington? 5 BY MR. GARCIA: E 6 A. At the instruction of my lawyer, I must invoke 6 Q. Allright. Can you tell me who pays for 7 my Fifth Amendment privilege. nd; that cell number? 8 Q. Have you ever been paid by Jeffrey Epstein 8 MR. RHEINHART: Same instruction. 9 to obtain underage children to have sex with 9 THE WITNESS: On the instruction of my 10 Jean-Luc Brunel? 10 lawyer, I must invoke my Fifth Amendment 11 MR. RHEINHART: Objection to the form. It | 11 privilege. 12 assumes knowledge of Jeffrey Epstein. 12 BY MR. GARCIA: 43 THE WITNESS: At the instruction of my 13 Q. Can you tell me how long you've had that 14 lawyer, I must invoke my Fifth Amendment 14 cell number? 15 privilege, 15 MR. RHEINHART: Just -— 16 BY MR. WEISSING: 16 THE WITNESS: On the instruction -17 Q. Other than the properties that we've 17 MR. RHEINHART: Just so I'm clear, when 18 discussed, are you aware of any other properties 18 you say "that" ceil number ~~ ig that Jeffrey Epstein owns? 19 MR. GARCIA: The (917)855-3363. 20 A. At the instruction of my lawyer, I must invoke | 20 MR. RHEINHART: Thank you. Instruct the 21 my Fifth Amendment privilege. ai witness not to answer based on Fifth Amendment. [) 22 Q. Are you aware of the financial assets of 22 THE WITNESS: At the instruction of my 23 Jeffrey Epstein? 23 lawyer, I must invoke my Fifth Amendment right. | A. On the instruction of my lawyer, I must mvoke | 24 BY MR. GARCIA: 3 25 my Fifth Amendment privilege. (561) 832-7500 a PROSE COURT REPORTING AGENCY, Q. Albright. Would you ha’ aay objection, 35 (Pages 323 to 326) INC. (561) 832-7506

Page 327 Page 329 [ i 2 to me dialing that number to see what the response 1 MR. RHEINHART: There's all sorts of facts 2 is? 2 that you may be able to prove from other places 3 MR. RHEINHART: Would she object to it? 3 that she’s doesn't have to admit to. ; 4 MR. GARCIA: Yeah. 4 MR. GARCIA: | am not asking her for other 5 MR. RHEINHART: You can do whatever you 5 facts. I'm asking her if she files income tax 6 want to do. 6 returns. 7 MR. GARCIA: Okay. 7 MR. RHEINHART: Correct. You asked her 8 MR. KUVIN: Just do it. 8 that. She's answered your question. 9 MR. GARCIA: Okay. Let's see if I can put 9 MR. GARCIA: Even though the Government 410 it on speaker. And J am dialing (917)855-3363. 10 has her income tax returns, if she files them, ai (Telephone call being made: Please leave li you are — you're still asserting a privilege 12 amessage. At the tone please record your 12 on information the Government already has? 13 message.) 13 MR. RHEINHART: Yes. 14 BY MR. GARCIA: 14 BY MR. GARCIA: 15 Q. Were you able to hear the voice that said, 15 Q. Does Mr. Epstein pay you in cash or by 16 “Please leave a message"? 16 check? 17 A. Well, I heard what it said. 17 MR. RHEINHART: Objection to the form o! 18 Q. Allright. Do you recognize that voice? 18 the question. Assumes Mr. Epstein. 19 A. My lawyer has instructed me to assert my Fifth | 19 THE WITNESS: On the instruction of my 20 Amendment right. 20 lawyer, | must assert my Fifth Amendment right. 2i Q. As to whether or not you recognize a 2i BY MR. GARCIA: 22 voice? 22 Q. What is your place of birth? 23 MR. RHEINHART: Yes. 23 MR. RHEINHART; Instruct the witness not 24 THE WITNESS: Yes, he has. 24 to answer the question. 25 THE VIDEOGRAPHER: And what's the 25 THE WITNESS: On the instruction of my Page 328 Page 330 1 good-faith basis for asserting that privilege? i lawyer, I must invoke my Fifth Amendment right. 2 MR. RHEINHART: I don't have to tell you 2 MR. GARCIA: How can that possibly 3 what the good-faith basis is. She's asserting 3 incriminate her? 4 a privilege as to whether she recognizes a 4 MR. RHEINHART: I will answer that 3 voice or not. If you can identify the voice, ° question when a judge asks it to me. 6 it could potentially lead back to other places 6 MR. GARCIA: Do you have any case law that 7 that could incriminate her in theory. So, she 7 supports that question as subject to a Fifth 8 has a good faith basis to invoke it. 8 Amendment objection? 9 BY MR. GARCIA: 9 MR. RHEINHART: I'll answer the question 10 Q. Do you have a job currently? 10 when a judge asks it of me. 11 MR. RHEINHART: Instruct the witness not ii BY MR. GARCIA: 12 to answer. 12 Q. Did you graduate from high school? 13 THE WITNESS: Or the instruction of my 13 MR. RHEINHART: Same objection, same 14 lawyer, I choose to assert my Fifth Amendment 14 instruction. 15 right, 15 THE WITNESS: On the advice of my lawyer, 16 BY MR. GARCIA: 16 I must invoke my Fifth Amendment right. 17 Q. Do you file income tax returns? 17 BY MR. GARCIA: 18 MR. RHEINHART: Same instruction. 18 Q. What states have you lived in other than 19 THE WITNESS: On the instruction of my 19 Florida and New York? 20 lawyer, I choose to assert my Fifth Amendment 20 MR. RHEINHART: Same instruction. 21 right. 21 THE WITNESS: On the instruction of my 22 MR. GARCIA: The Government, presumably, | 22 lawyer, I must invoke my Fifth Amendment right. 23 has her income tax returns, so what is the 23 BY MR. GARCIA: 24 basis for asserting a privilege against 24 Q. Did you attend college? 25 incrimination? 25 a instructi 36 (Pages 327 to 330) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 331 Page 1 THE WITNESS: On the instruction of my 1 MR. KUVIN: So it's really kind of 2 lawyer, I must invoke my Fifth Amendment right. 2 comical, so I apologize for my laughing, but 3: BY MR. GARCIA: 3 it's just bordering ~~ 4 Q. Have you ever been to New Mexico? 4 MR. RHEINHART: Your -5 MR. RHEINHART: Same instruction. 5 MR. KUVIN: -- on absurd. f 6 THE WITNESS: On the instruction of my 6 MR. RHEINHART: Look, I think most of the F a: lawyer, I must invoke my Fifth Amendment right. 7 questions that the rest of you-all asked today A 8 BY MR. GARCIA: 8 were absurd, and we've answered your questions 3 Q. Do you have a passport? 3 respectfully. We didn't laugh. We didn't make 10 MR. RHEINHART: Same instruction. 10 fun of you. It is unprofessional and il THE WITNESS: On the instruction of my il disrespectful of you to laugh at the witness 12 lawyer, [ must invoke my Fifth Amendment right. | 12 when she's asserting a Constitutional right. 13 MR. GARCIA: The Government has access to} 13 And don't walk away from me when I'm 14 her passport, and you're saying that's, you can 14 talking to you. is object to whether or not she has a passport? 15 MR. KUVIN: I'm not walking away, I'm 16 MR. RHEINHART: There's lots of things 16 listening, I'm not walking away at all. {'m 17 that there may be evidence of from other 17 just throwing away muy trash. | apologize if it 18 sources that she doesn't have to admit to. She 18 seemed like I was walking away. 19 has a Constitutional right not to admit to. 19 MR. RHEINHART: Ub-huh, which you were. |} 20 BY MR. GARCIA: 20 Mr. Garcia, if you want to ask your questions, 21 Q. Have you ever traveled to Mexico? 21 you may ask them. She will answer them. If 22 MR. RHEINHART: Same instruction. 22 you don't like the questions, you can certify 23 THE WITNESS: On the instruction of my 23 them to the judge and I will be happy to 24 lawyer, I must invoke my Fifth Amendment right. | 24 discuss with the judge whether or not there is 25 25 a good-faith basis, Page 332 Page 334 i BY MR. GARCIA: 1 MR. GARCIA: Certify all those questions. 2 Q. Do you have a driver's license? 2 BY MR. GARCIA: 3 MR. RHEINHART: Same instruction. 3 Q. Let me ask you, do you, do you deny that 4 THE WITNESS: On the instruction of my 4 you solicited a minor by the name of Jane Doe No. Il fj 5 lawyer, I must invoke my Fifth Amendment right. | 5 for the purposes of providing sexual services to i 6 BY MR. GARCIA: 6 Jeffrey Epstein? 7 Q. Do you have a driver’s license in New 7 MR. RHEINHART: Instruct the witness not 8 York? 8 to answer. 9 MR. RHEINHART: Same instruction. 9 THE WITNESS: At the instruction of my 10 THE WITNESS: On the instruction of my 10 lawyer, I must assert my Fifth Amendment right. 11 lawyer, { must invoke my Fifth Amendment right. | 11. BY MR. GARCIA: 12 BY MR. GARCIA; 12 Q. Do you deny that you solicited Jane Doe 13 Q. Are you registered to vote? 13 No. 2 on multiple oceasions by your cellphone in 14 MR. RHEINHART: Same instruction. 14 order for her to provide sexual services for pay to 15 THE WITNESS: On the instruction of my 15 Mr. Epstein? 16 lawyer, { must invoke my Fifth Amendment right. | 16 MR, RHEINHART: Same instruction, same i7 MR. RHEINHART: Mr. Kuvin, if you'd like 417 objection to the form previously stated. 18 to keep laughing, feel free. 18 THE WITNESS: At the instruction of my F 19 MR. KUVIN: I think it's absolutely absurd 19 lawyer, I must invoke my Fifth Amendment right. 20 that she's objecting to some of these questions 20 BY MR. GARCIA: 21 or taking the Fifth to some of these questions. 21 Q. Do you know why Jeffrey Epstein is only 22 imean, I want to Sid to ask her now if the sky 22 interested in minor girls? 23 is blue. I think she's going to take the Fifth 23 MR. RHEINHART: Objection to the form, 24 as to that question, as well, 24 standing objection. It assume she has some 25 MR. RHEINHART: Look, I, 1—- 25 knowledge of Jeffrey Epstein that's implicit in RAR AE ET AL TT TT SD ST SER TS A TR SAT SRT 37 (Pages 331 to 334) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Page 335 1 the question. a compelled by her parents to do anything. 2 THE WITNESS: On the instruction of my 2 Move on. I will debate the legal issues 3. lawyer, [ must invoke my Fifth Amendment right, 3 with the judge, not with you. 4 BY MR. GARCIA: 4 BY MR. GARCIA: 5 Q. Do your parents approve of your 3 Q. Do you have any siblings? 6 association with Mr. Epstein? 6 MR. RHEINHART: Instruct the witness not 7 MR. RHEINHART: Objection to the form. 7 to answer. That was also asked and answered 8 What's -- instruct the witness not to answer, 8 many hours ago. 3 THE WITNESS: On the instruction of my 9 THE WITNESS: On the instruction of my : 10 lawyer -- 10 lawyer, I must invoke my Fifth Amendment right. f: ii MR. GARCIA: To the form or is this some 11 BY MR. GARCIA: ; 12 constitutional issue that you're raising? 12 Q. Have you ever discussed your relationship 13 MR. RHEINHART: Object to the form of your | 13 with Mr. Epstein with your siblings, assuming you 14 question as assuming facts that have not been 14 have any? 15 established, and aise it's irrelevant to lead. is MR. RHEINHART: Instruct the witness not 16 to any admissible evidence. But to the extent 16 to answer the question. Objection to the form. 17 that you're asking any questions that could 17 THE WITNESS: At the instruction of my 18 relate to her parents, she is invoking the 18 lawyer, I must invoke my Fifth Amendment right. 8 19 Fifth Amendment as to that question. 19 BY MR. GARCIA: 20 THE WITNESS: At the instruction of my 20 Q. Do you have a fiance, boyfriend, or ai lawyer, I must invoke my Fifth Amendment right. ai significant other? 22 BY MR. GARCIA: 22 MR. RHEINHART: Objection to the form. 23 Q. How did you meet Mr. Epstein? 23 Instruct the witness not to answer as to the 24 MR. RHEINHART: Instruct the witness not 24 __ Fifth Amendment. 25 to answer, 25 THE WITNESS: On the instruction of my Page 336 Page 338 i THE WITNESS: At the instruction of my 1 jawyer, I must invoke my Fifth Amendment right. 2 lawyer, I must invoke my Fifth Amendment right. 2 BY MR. GARCIA: 3 BY MR. GARCIA: 3 Q. Have you discussed your relationship with 4 Q. Did your parents know Mr. Epstein? 4 Mr. Epstein with your boyfriend, fiance, or 5 MR. RHEINHART: That question I think was 5 significant other? 6 asked and answered several hours ago, and I'l! 6 MR. RHEINHART: Objection to the form, the |} 4 instruct the witness not to answer as to Fifth 7 standing objection, assumes knowledge of 8 Amendment privilege. 8 Mr. Epstein, and I will instruct her not to 9 THE WITNESS: On the instruction of my 9 answer. 10 lawyer, I must invoke my Fifth Amendment right. | 10 THE WITNESS: On the instruction of my il BY MR. GARCIA: 11 lawyer, [ must invoke my Fifth Amendment right. 12 Q. Have you ever discussed your relationship 12 BY MR. GARCIA: 13 with Mr, Epstein with your parents? i3 Q. Now, you were asked before if you visited 14 MR. RHEINHART: Objection to the form. 14 Mr. Epstein at the County jail; is that correct, 15 Instruct the witness not to answer, 15 here in Palm Beach County? Do you recail those 16 THE WITNESS: On the instruction of my 16 questions? 17 lawyer, I must invoke my Fifth Amendment right. | 17 A. [do recali being asked that. 18 MR. GARCIA: Wouldn't that be a waiver if 18 Q. Alfright. And did you have to fill out 19 she's discussed it with her parents? 19 any type of log when you visited the Palm Beach 20 MR. RHEINHART: Waiver of what? 20 County jail and provide identification to the 21 MR. GARCIA: A waiver of any imagined or 21 Government as to what your name was, and provide 22 real Fifth Amendment right against 22 your name to the Government and who you were 23 self-incrimination. 23 visiting? 24 MR. RHEINHART: It's only waived ifit was | 24 MR. RHEINHART: Objection to the form (561) 832-7500 com lied, and d you gid it anyway. She was 't PROSE COURT REPORTING AGENCY, INC. because it assumes she went to the Palm Beach. 4 38 {Pages 335 to 338) (561) 832-7506

Ved H ye wneP Page 339 County jail. When that question was asked before, she invoked her Fifth Amendment privilege, so she's not answering the question this time either. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. GARCIA: Q. Have you spoken to Jeffrey Epstein about this deposition that you're giving today? MR. RHEINHART: Instruct the witness not to answer the question. THE WITNESS: At the instruction of my lawyer, I invoke my Fifth Amendment right. BY MR. GARCIA: Q. When is the last time you spoke with Mr. Epstein? MR. RHEINHART: Instruct the witness not to answer the question. THE WITNESS: On the instruction of my lawyer, [ invoke my Fifth Amendment right. BY MR. GARCIA: Q. Was anybody else in the room when you spoke to Mr. Epstein besides the two of you? MR. RHEINHART: Instruct the witness not to answer the question. Object to the form VDBIDKUPWYE Page 3418 lawyer, | invoke my Fifth Amendment right. BY MR. GARCIA: Q. Why did you go see Jeffrey Epstein at the County jail? MR. RHEINHART: Objection to the form. It assumes facts that have not been acknowledged or admitted. Instruct the witness not to answer. THE WITNESS: At the instruction of my lawyer, I invoke my Fifth Amendment right. BY MR. GARCIA: Q. Were your conversations monitored by anyone? b MR. RHEINHART: Objection to the form. It § assumes facts that have not been admitted or acknowledged and instruct the witness not to answer. THE WITNESS: At the instruction of my lawyer, L invoke my Fifth Amendment right. BY MR. GARCIA: Q. Let me show you what's been filed on your behalf as an answer with affirmative defenses. I have some extra copies here. We'll mark her copy as | Exhibit ~ THE COURT REPORTER: 15. Yes, 15. Page 340 because it assumes any knowledge of Mr. Epstein. THE WITNESS: At the instruction of my lawyer, | invoke my Fifth Amendment right. BY MR. GARCIA: Q. Where are you currently staying? MR. RHEINHART: Instruct the witness not to answer. BY MR. GARCIA: Q. Are you currently engaged -~ MR. RHEINHART: Hold on. Hold on. Let her -- let her respond, THE WITNESS: At the instruction of my fawyer, I invoke my Fifth Amendment right. BY MR. GARCIA: Q. Are you currently engaged in any criminal activity at the, wherever it is that you're staying? MR. RHEINHART: Object to the form in that it requires a legal conclusion. Second of all, I believe it's meant more for harassment than to lead to any discoverable evidence. Third of all, she’s instructed not to answer the question based on her Fifth Amendment privilege. THE WITNESS: On the instruction ofn m 832-7500 PROSE COURT REPORTING AGENCY, INC. Page 34 MR. GARCIA: What is it, 15? THE COURT REPORTER: 15, yes. (Plaintiff's Exhibit No. 15 was marked for identification.) BY MR. GARCIA: Q. Could you please take a look at that document. A. Do you want me to read the whole thing? Q. No, just take a look at if so L.can ask you if you've ever seen it before, MR. RHEINHART: You can answer. THE WITNESS: No, no. BY MR. GARCIA: Q. Were you aware that you were a Defendant in a civil action filed by Jane Doe IL, in the United States District Court, Southem District of Florida? i MR. RHEINHART: You can answer that other [, than if it involves discussions, private bE discussions you had with your lawyers. THE WITNESS: 1 only would have if my lawyer told me. I don't know for sure. BY MR. GARCIA: Q. Okay. Take a look at Page 5. Do you see the section that begins with -Affirmative defenses"? _ 39 (Pages 339 to 342) (561) 832-7506

Page 343 Page 345 i 1 A, Ub-buh. Yes. 1 BY MR. GARCIA: 2 Q. Do you have any evidence to support the 2 Q. Did you have any conversations with 3 first affirmative defense, and I'll tell you for the 3 Jane Doe No. i at any time in which she toid you 4 record that Jane Doe II, is Jane Doe No. Il, was a 4 that she was a, she consented and was a willing 5 willing participant in the acts alleged, and 5 participant in the acts that are alleged in the 6 therefore her claims are barred or her damages are 6 complaint with Jeffrey Epstein? 4 required to be reduced accordingly? 7 MR. RHEINHART: Object to the form because |] 8 MR. RHEINHART: I'm sorry. Can you repeat} 8 it assumes knowledge of Jane Doe No. Il. And [ 9 the question that you're asking? 9 the witness is going to her invoke her Fifth 10 MR. GARCIA: Can you read it back? 10 Amendment privilege as to any evidence or any il (The requested portion of the record was 11 knowledge of Jane Doe No. IL 12 read by the reporter.) 12 THE WITNESS: At the instruction of my 13 BY MR. GARCIA: 13 lawyer, 1 must invoke my Fifth Amendment right. 14 Q. Do you have any evidence to support that 14 BY MR. GARCIA: is affirmative defense? 15 Q. The second affirmative defense on the same 16 A. Idon't understand the question. 16 page it says, "As to Plaintiffs claim, Plaintiff 17 Q. Okay. This affirmative defense alleges on 17 actually consented to and participated in conduct 18 your behalf by Mr. Rheinhart claims that Jane Doe 18 sitnilar and are identical to the acts alleged with 19 No. ff consented to and was a willing participant in 19 other persons which were the sole or contributing 20 the acts alleged, and therefore her claims were 20 cause of Plaintiff's alleged damages." 2i barred or her damages were required to be reduced, 21 Do you have any facts to support the 22 Do you have any factual basis for 22 second affirmative defense? 23 asserting that defense, and if so, what facts do you 23 MR. RHEINHART: And once again to the 24 have to support it? 24 extent that, the, the question -- object to the 25 MR. RHEINHART: Do you understand the 25 form to the extent the question requires her to | Page 344 Page 346), 1 question? 1 acknowledge any knowledge of Jane Doe No. II or | 2 THE WITNESS: Uh-uh. 2 Jane Doe No. Il's activities she would invoke : 3 THE COURT REPORTER: Is that a yes? 3 her Fifth Amendment privilege. I would 4 THE WITNESS: Yes, sorry. 4 instruct her to do so. 5 MR. RHEINHART: You can answer ifyoucan} 5 THE WITNESS: On the instruction of my 6 answer. 6 lawyer, I must invoke my Fifth Amendment right. 7 THE WITNESS: I'm sorry. Do | have any 7 BY MR. GARCIA: 8 facts. 8 Q. So I don't waste any time with the court 9 BY MR. GARCIA: 9 on these issues, can you tell me at least a yes or 10 Q. Right. What, what evidence do you have to 10 no as to whether or not you have any facts to 11 support the claim that Jane Doe No. II consented to ii support, without telling me what the facts are, 12 and was a willing participant with Jeffrey Epstein. 12 whether or not you have any facts to support the 13 in the acts described in the complaint? 13 defenses? 14 MR. RHEINHART: I am just consulting on 14 MR. RHEINHART: Whether she personally 15 what might be a privilege issue. 15 does? 16 (A discussion was heid off the record.) 16 MR. GARCIA: Yes, exactly, personally. : 17 MR. RHEINHART: A portion of the truth of 17 MR. RHEINHART: -- or has her defense team 18 that would require attorney-client privilege 18 acting on her behalf? f 19 information, so I am going to instruct her not 19 MR. GARCIA: No, just personally. 20 to answer that portion of it, and ask that -- 20 MR. RHEINHART: No, | am going to instruct }] 24 MR. GARCIA: Okay. 2. her not to answer based on her Fifth Amendment. 22 MR. RHEINHART: Hold it. Okay. Andasto | 22 BY MR. GARCIA: 23 the rest, [ll instruct her not to answer the 23 Q. Do you have any information to support 24 question based on her Fifth Amendment 24 the, any facts to support the third affirmative 25 ivil (961) 832-7500 PROSE COURT REPORTING AGENCY, that the Plaintiff impliedly consented to {Pages 343 to 346) INC. (561) 832-7506

Page 347 Page 349% 1 the acts alleged by not objecting, and therefore her 1 page? 2 claims are barred or her damages are required to be 2 A. What page, sir? 3 reduced accordingly? 3 Q. Page 6. It says, "As to Plaintiff's 4 MR. RHEINHART: Once again [ would assert} 4 claim, Defendant reasonably, reasonably believed or | S an attorney-client privilege as to -- this, 5 was told that the Plaintiff had attained the age of 6 this question that you have asked requires a 6 18 years old at the time of the alfeged acts.” 7 legal conclusion which would require her to -- 7 Who told you that the Plaintiff was 18 at 8 MR. GARCIA: I'm not asking for the legal 8 the time of the acts invoived in this case? 9 conclusion. I'm asking what facts she has to 9 MR. RHEINHART: Again, I would instruct 10 support an affirmative defense which requires 10 the witness not to answer the question based on. 11 you to put on evidence of what that defense is. 11 both the attorney-client privilege and her 12 MR. RHEINHART: Right. But you're asking | 12 Fifth Amendment privilege against 13 her what evidence she has of legal conclusions, 13 self-incrimination. 14 which is concepts such as consent, claims being 14 THE WITNESS: At my lawyer's instruction, 15 barred, damages required to be reduced is I must assert my Fifth Amendment right. 16 accordingly, those are legal concepts you're 16 BY MR. GARCIA: 17 asking her to make, a lay person to give a 1? Q. Atthe time that Jane Doe No. I was 18 statement as to what the factual evidence is 18 involved in some sort of a relationship, if you can 19 there to support a legal conclusion. The only 19 call it that, with Mr. Epstein, did you have 20 way she would know if they support the legal 20 counsel? Did you have a lawyer representing you? 21 conclusion is based on conversations she's had 21 MR. RHEINHART: Object to the form. 22 with counsel. 22 She -- the question assumes that there is any 23 MR. GARCIA: So, are you instructing her 23 knowledge of any relationship between Jane Doe f, 24 not to answer on that basis or -- 24 No. Hand a person named Mr. Epstein. She's 25 MR. RHEINHART: Yes, that's right, yeah. 25, not going to answer the question based on the Page 348 Page 3505 i MR. GARCIA: -- the Fifth Amendment 1 Fifth Amendment. 2 privilege? 2 THE WITNESS: At the instruction of my 3 MR. RHEINHART: On, on that basis only. 3: lawyer, I assert my Fifth Amendment right. 4 As to that question | am instructing her not to 4 BY MR. GARCIA: 5 answer on the basis of the attorney-client 5 Q. DidJane Doe No. H ever tell you that she 6 privilege. 6 was 18 at the time of the alleged acts? i, BY MR. GARCIA: a MR, RHEINHART: Object to the form. 8 Q. Outside of your discussions with counsel, 8 Instruct the witness not to answer based on the 9 do you have any facts to support the third 9. Fifth Amendment. 10 affirmative defense based upon your discussions with | 10 THE WITNESS: On the instruction of my at Jane Doe No. HI or discussions with any other person {| 11 lawyer, I assert my Fifth Amendment right. 12 or review independently of your counsel of any 12 BY MR. GARCIA: 13 document that would support this third affirmative 13 Q. I think the Fifth Affirmative Defense is 14 defense? 14 pretty much similar, but it says, "As to Plaintiff's 15 MR. RHEINHART: Object to the form to the 15 claim, Plaintiff's claims are barred as she said she 16 extent that it requires any acknowledgment of 16 was 18 years or older at the time,” end quote. I 17 any knowledge of Jane Doe No. I, I would 17 assume that you're referring to yourself; she told 18 instruct her not to answer the question based 18 you that she was 18 years old at the time? H 19 on the Fifth Amendment. 19 MR. RHEINHART: Instruct the witness not 20 THE WITNESS: Upon my lawyer's 20 to answer based on her Fifth Amendment : 21 instruction, I choose to exert my Fifth 21 privilege. 22 Amendment right. 22 BY MR. GARCIA: 23 BY MR. GARCIA: 23 Q. Do you have any evidence to support that (561) of Exhibit 15, could you turn to that on the next Q. The fourth affirmative defense on Page 6 832-7500 PROSE COURT REPORTING AGENCY, INC. assertion; that is did you make any journal (Pages 347 465 350) (561) 832-7506

Page 351 1 journal or diary? 1 BY MR. GARCIA: 2 MR. RHEINHART: Instruct the witness net 2 Q. Tm going to give you some dates here. If 3 to answer based on the Fifth Amendment. 3 you want to, I don't know if he wants to write them. 4 BY MR. GARCIA: 4 down or take them one at atime: June 16th, 2003; 5 Q. Have you ever kept — 5 July 2nd, 2003; April 9th, 2004; June 7th, 2004; 6 MR. RHEINHART: Hoid on, please. Let her, 6 July 30th, 2004; August 30th, 2004; October 9th, 7 let her answer, 7 2004; October 12th, 2004; October 30th, 2004; and 8 THE WITNESS: On the instruction of my 8 November 9th, 2004. Do you recail soliciting Jane g lawyer, I assert my Fifth Amendment right. 9 Doe No. II to come to Jeffrey Epstein'’s home on any 10 BY MR. GARCIA: 10 of those dates? ai Q. Have you ever kept a journal or diary in 1 MR. RHEINHART: Objection to the form, 12 the past? 12 Standing objection as previously stated as to 13 MR. RHEINHART: Same instruction. 13 any knowledge of Jeffrey Epstein or Jane Doe 14 THE WITNESS: At the instruction of my 14 No. Il, and instruct the witness not to answer. as lawyer, I assert my Fifth Amendment right. 15 THE WITNESS: On the instruction i 16 BY MR. GARCIA: 16 MR. GARCIA: Okay. So your instruction is ff 17 Q. As to the sixth affirmative defense, what 17 not based on Fifth Amendment? 18 evidence do you have that Plaintiff's alleged. 18 MR. RHEINHART: It is. { am instructing 19 damages were caused in whole or in part by events 19 her not to answer based on Fifth Amendment, 20 and/or circumstances completely unrelated to the 20 THE WITNESS: On the instruction of my 21 incidents alleged in the complaint? 21 lawyer, I must exercise my Fifth Amendment 22 MR. RHEINHART: As to that, f would assert | 22 right. 23 an attorney-client privilege. 23 BY MR. GARCIA: 24 BY MR. GARCIA: 24 Q. Do you contest, in any way, that Jane Doe 25 Q. Well, do you have a witness that you can 25 No. HI was solicited by you on each of these dates ki Page 352 Page 354 1 identify that will testify about this? 2 for the purposes of providing Jeffrey Epstein with 2 MR. RHEINHART: Instruct the witness not 2 sexual massages and/or services. 3 to answer that based on the Fifth Amendment 3 MR. RHEINHART: Objection to form. It's a 4 privilege. She doesn't have to help you. 4 compound question, It assumes facts that she's 5 THE WITNESS: On the instruction of my a not acknowledged or admitted. It is therefore 6 lawyer, | exert my Fifth Amendment right. 6 compound and ambiguous. I would instruct her 7 MR. GARCIA: All right. So your position 7 not fo answer based on her Fifth Amendment 8 is that you don't have to auswer any questions 8 privilege. 9 about affirmative defenses, but yet you can 3 BY MR. GARCIA: 10 maintain them? 10 Q. Where did you live in 2003? il MR. RHEINHART: That's not whatI said. | 11 MR. RHEINHART: Instruct the witness not 12 You asked to identify a particular witness. If 12 to answer based on the Fifth Amendment. 13 identifying a witness could potentially lead to 13 THE WITNESS: At the instruction of my 14 putting herself in jeopardy for criminal 14 lawyer, I must exercise my Fifth Amendment 15 prosecution, she doesn't have to answer. 15 right. 16 MR. GARCIA: This would be a witness that | 16 BY MR. GARCIA: 17 would support her defense, not, not cause her 17 Q. What cellphone number did you have in 18 criminal prosecution. 18 2003? 19 MR. RHEINHART: |, | understand your 19 MR. RHEINHART: Same instruction. 20 point, and my point is if identifying such a 20 THE WITNESS; At the instruction of my 21 witness could also lead her potentially to 21 lawyer I must exert my Fifth Amendment right. 22 criminal prosecution by the Government, she 22 BY MR. GARCIA: 23 doesn't have to answer that question and she's 23 Q. Where did you live in 2004? 24 not going to. Witnesses can have many factual | 24 MR. RHEINHART: Same instruction. E 25 purposes. 25 THE WITNESS: At the instruction of m; (561) 832~7500 PROSE COURT REPORTING AGENCY, 42 INC. (Pages 351 to 354} (561) 832-7506

Page 355 Page 357) 1 lawyer I must exercise my Fifth Amendment a BY MR. GARCIA: 2 right. 2 Q. There was some doctor that was -- you were 3 BY MR. GARCIA: 3 asked about earlier today. Do you recall his name? i 4 Q. What cellphone number did you have in 4 MR. RHEINHART: The name that was asked of 5 2004? 5 her? if you remember -- : 6 MR. RHEINHART: Same instruction. 6 MR. KUVIN: It's Dr. 7 THE WITNESS: At the instruction of my 7 MR. GOLDBERGER: Feelgood? 8 lawyer I just exercise my Fifth Amendment 8 MR. KUVIN: No, that’s your doctor, Jack. 9 right. 9 Dr. -- hang on. I'll get it for you. 10 BY MR. GARCIA: 10 MS. EZELL; Bard, it was Bard. ii Q. Where did you first recruit Jane Doe 11 MR. KUVIN: Bard, B-a-r-d, I believe, 12 No. Ui for soliciting her to provide sexual services 12 MR. GARCIA: Dr. Bard. I think that's 13 to Jeffrey Epstein? 13 tight. 14 MR. RHEINHART: Objection to the form, 14 BY MR. GARCIA: 15 Standing objection previously stated. Instruct 15 Q. Do you know 2 Dr. Bard? 16 the witness not to answer based on her Fifth 16 THE WITNESS: At the instruction of my 17 Amendment. 14 lawyer, I choose to exercise my Fifth Amendment 18 THE WITNESS: At the instruction of my is Tight. ig lawyer I must exercise my Fifth Amendment 19 BY MR. GARCIA: 20 right, 20 Q. Did Dr. Bard ever provide any type of 21 BY MR. GARCIA: 21 dental services to you? 22 Q. Did you go to clubs where young women hung | 22 MR. RHEINHART: Objection to the form. It 23 out and approach them in order to solicit them for 23 assumes facts that have not been established 24 Mr. Epstein? 24 that she's ever seen by Dr. Bard. So, once 25 MR. RHEINHART: Objection to the form. It | 25 again, we assert a Fifth Amendment privilege. Page 356 Page 358 1 assumes knowledge of Mr. Epstein, therefore 1 1 THE WITNESS: At the instruction of my 2 instruct the witness not to answer based on the 2 lawyer, I must exercise my Fifth Amendment 3 Fifth Amendment privilege. 3 right. 4 THE WITNESS: At the instruction of my 4 BY MR. GARCIA: 5 lawyer, I must exercise my Fifth Amendment 5 Q. Have you ever had any dental work done in 6 right. 6 the past ten years? And I don’t mean cavities. I'm 7 BY MR. GARCIA: 7 talking about cosmetic-type dental work. 8 Q. Did you ever pay Jane Doe No. II for 8 A. Yes, sir. 9 sexual services and/or sexual massages provided to 9 Q. Allright. What state was it in? 10 Mr. Epstein? 10 MR. RHEENHART: One second. ai MR. RHEINHART: Objection to the form for | 11 MR. GOLDBERGER: Excuse me. if 12 the reasons previously stated in the standing 12 MR. RHEINHART: You can answer. You can 13 objection. Instruct the witness not to answer, 13 answer as to what state it occurred. 14 based on the Fifth Amendment. 14 THE WITNESS: In New York, is THE WITNESS: On the instruction of my 15 BY MR. GARCIA: 16 lawyer, I choose to exercise my Fifth Amendment | 16 Q. Was the dental work paid for by anyone 17 right. 17 other than yourself? 18 BY MR. GARCIA: 18 MR. RHEINHART: Instruct the witness not 19 Q. Did you pay in U.S. currency? 19 to answer based on the Fifth Amendment 20 MR. RHEINHART: Same objection, same 20 privilege. 21 instruction. 21 THE WITNESS: At the instruction of my 22 THE WITNESS: On the instruction of my 22 lawyer, I must assert my Fifth Amendment right. 23 lawyer, I choose to exercise my Fifth Amendment | 23 BY MR. GARCIA: right. 24 Q. What was the name of the doctor that 25 provided the cosmetic dental services? 832-7500 PROSE COURT REPORTING AGENCY, 43 (Pages 355 to 358) INc. (561) 832-7506

OOIAKBWNHE (561) 832-7500 Page 359 Page 361 B MR. RHEINHART;: You can answer. Sorry, i any type of surgical procedure performed on his wait a minute. 2 penis? Tastruct the witness not to answer the 3 MR. RHEINHART: Objection to the form to question based on the Fifth Amendment. 4 the extent it assumes any knowledge of BY MR. GARCIA: 5 Mr. Epstein and instruct the witness not to Q. Did Jeffrey Epstein -- 6 answer, MR. RHEINHART: Hold on. You have tolet | 7 THE WITNESS: On the instruction of my — her assert her privilege. 8 lawyer, I must invoke my Fifth Amendment right. THE WITNESS: At the instruction of my 9 BY MR. GARCIA: E lawyer, [ must assert my Fifth Amendment right. | 10 Q. Has he ever told you that he's ever had a BY MR. GARCIA: 121 penile implant added to his penis? Q. Did Jeffrey Epstein suggest that you get 12 MR. RHEINHART: Same instruction, same the dental work done? 13 objection. MR. RHEINHART: Instruct the witness not 14 THE WITNESS: On the instruction of my to answer. Objection to the form, instruct the 18 lawyer, I must invoke my Fifth Amendment right. # witness not to answer. 16 BY MR. GARCIA: THE WITNESS: On the instruction of my 17 Q. Has Mr. Epstein ~ have you ever observed lawyer, i must assert my Fifth Amendment right. | 18 Mr. Epstein or has he ever told you that he takes BY MR. GARCIA: 19 Viagra or Cialis? Q. Do you know Kevin Spacey? 20 MR. RHEINHART: Objection to the form. MR. RHEINHART: Are you asking if she’s 21: Standing objection. It assumes knowledge of ever met Kevin Spacey? 22 Mr. Epstein, and therefore I would instruct the MR. GARCIA: Yes, I'm sorry. 23 witness not to answer. MR. KUVIN: There you go. 24 THE WITNESS: On the instruction of my MR. RHEINHART: Instruct the witness not 25 lawyer, I must invoke my Fifth Amendment right. Peet este H Page 360 Page 362 to answer the question, L BY MR. GARCIA: THE WITNESS: At the instruction of my 2 Q. Did you ever meet Lewis or Dorothy lawyer, I must invoke my Fifth Amendment right. 3 Cullman, C-u-l-l-m-a-n? BY MR. GARCIA: 4 MR. GARCIA: I think the look means that Q. Did you ever met Chris Tucker? 5 she's going to object. MR. RHEINHART: Same instruction. 6 MR. RHEJINHART: Are you asking -- J just THE WITNESS: At the instruction of my 7 want to clarify the question. Are you asking lawyer I must invoke my Fifth Amendment 8 if she has ever met a person she knows to have privilege. io that name or if she's ever -BY MR, GARCIA: 10 MR. GARCIA: Yes. Q, Did you ever meet Bill Clinton? li MR. RHEENHART: You can answer the MR. RHEINHART: Same instruction. 12 question, THE WITNESS: On the instruction of my 13 THE WITNESS: No. lawyer, { must invoke my Fifth Amendment right. | 14 MR. GARCIA: There were two people, Lewis, |} BY MR. GARCIA: is L-e-w-i-s, and Dorothy Cullman. Q. Did you ever fly with these three 16 MR. RHEINHART: So it's split it in two gentlemen and Jeffrey Epstein to Africa on Jeffrey 17 questions. Do Lewis first and Dorothy second. Epstein’s 727 airplane? 18 Have you met Lewis? MR. RHEINHART: Objection to the form. 19 THE WITNESS: No. It's a compound question. Instruct the witness 20 MR. RHEINHART: Dorothy? not to answer based on the Fifth Amendment. 21 THE WITNESS: No. THE WITNESS: At the instruction of my 22 BY MR. GARCIA: lawyer, I must invoke my Fifth Amendment right. | 23 Q. Have you had any other type of cosmetic PROSE COURT REPORTING AGENCY, INC. surgery other than the dental surgery that you 44 (Pages 359 to 362} (561) 832-7506

Page 363 Page 365 § x MR. RHEINHART: What -- we're getting, 1 Fifth Amendment on who this dentist was? 2 we're getting into personal privacy issues 2 MR. RHEINHART: Yes, she did. 3 here. Can we, can we get a little foundation 3 BY MR. GARCIA: 4 for why that's relevant? 4 Q. Do you have a Facebook page? 5 MR. GARCIA: [don't think I have to 5 A. No, 6 reveal that to you, but f would proffer this, 6 Q. Have you ever had one? ot that if Mr. Epstein paid for it, it might lead 7 A. I may have started one, but I, for like ten 8 to pethaps bias on the part of the witness. 8 minutes. 9 MR. RHEINHART: Well, why don't you ask it 9 Q. You started one for ten minutes. Did you 10 that way? She's ever had any surgery that was 10 turn it off after ten minutes? th paid for by Mr. Epstein or otherwise funded by ll A. Yes. 12 Me. Epstein. 12 Q. What year was this? 13 MR. KUVIN: On behalf of the other - on 13 A. [don't remember. 14 behalf of the other Plaintiffs as well, I would 14 Q. What prompted you to turn it off after ten 15 say that for identification purposes it becomes 15 minutes? 16 imperative if some of the other girls have 16 A. I think it's a stupid site. 17 alleged, as they have in their complaints that 17 Q. How about a — is it called MyFace or 18 they saw Ms. Kellen when they arrived at the 1s MySpace? Sorry. MySpace. 19 home if she’s changed her physical appearance, 19 MR. KUVIN: It's not YourFace, sorry, Sid. 20 at the date that we go to trial, I believe that 20 MR. GARCIA: Trust me, you don't want to 21 any cosmetic surgery she has might be relevant 21 get that on there. 22 to the case. 22 BY MR. GARCIA: 23 MR. RHEINHART: | understand. I 23 Q. How about a MySpace page, have you ever 24 understand, Hold on one second. No. You can 24 had one of those? 25 go ahead and ask. 25 A. No. Page 364 Page 366} 1 BY MR. GARCIA: 1 Q. No. what, what name did you use on the 2 Q. Okay. Have you ever had any other type of 2 Facebook page? 3 cosmetic surgery that was financed by Mr. Epstein? 3. A. I don't remember. 4 MR. RHEINHART: Objection to the formin| 4 Q. Did Jeffrey Epstein suggest that wouldn't 5 that it assumes Mr. Epstein, any knowledge of 5 be such a good idea? 6 Mr. Epstein. But if you want to ask her -- go 6 MR. RHEINHART: Objection to the form. 7 ahead and ask her the general question, has she 7 Standing objection. Instruct the witness not 8 ever had it done by anybody, paid by anybody. 8 to answer based on Fifth Amendment. 9. MR. GARCIA: All right. 9 THE WITNESS: At the advice of my lawyer, 10 BY MR. GARCIA: 16 I must invoke my Fifth Amendment right. i Q. Have you ever had any other cosmetic 11 BY MR. GARCIA: 12 surgery? 12 Q. Where were you when you set up a Facebook 13 A. No. 13 page for about ten minutes? 14 Q. What type of dental procedure did you have | 14 MR. RHEINHART: Objection to the form. 15 done? 15 Sorry. Instruct the witness not to answer, 16 A. Invisalign. 16 based on the Fifth Amendment. T?. Q. And what is that? 17 THE WITNESS: At the instruction of my 18 A. Straightens your teeth. 18 lawyer, I must invoke my Fifth Amendment right. 19 Q. Is it something that you wear? 19 BY MR. GARCIA: 20 A. Sometimes, Not ail the time. 20 Q. Do you know who Max Brockman, 2i Q. You're still wearing it today? al B-r-o-c-k-m-a-n, is? 22 A, No. 22 MR. RHEINHART: Instruct the witness not 23 Q. And what year was the dental process done? | 23 to answer based on the Fifth Amendment. 24 A. Started two years ago. 24 THE WITNESS: At the instruction of my . Did you take the (561) MR. GARCIA: Tm Or 832-7500 PROSE COURT REPORTING AGENCY, INC. lawyer, 1 must invoke my] Fifth. Amendment 45 (Pages 363 to 366) (561) 832-7506

Page 367 Page 369} L BY MR. GARCIA: 1 lawyer, | must invoke my Fifth Amendment right. 2 Q. Do you know who Cindy Lopez is? 2 BY MR. GARCIA: 3 MR. RHEINHART: Same instruction. 3 Q. Were you home schooled by your parents or 4 THE WITNESS: At the instruction of my 4 one of your parents, or someone else? 5 lawyer, I must invoke my Fifth Amendment right. 5 A. Myself. 6 BY MR. GARCIA: 6 Q. Do you know what the name of the program 7 Q. Do you hold any professional licenses a was that authorized you to home school yourself? 8 issued by any, any state? 8 MR. RHEINHART: Instruct the witness not ro} MR. RHEINHART: Hold on a second. vow can| 9 to answer based on the Fifth Amendment, E 10 answer. 10 THE WITNESS: On the advice of my counsel, [f 11 THE WITNESS: No. 11 I must invoke my Fifth Amendment right. 12 BY MR. GARCIA: 12 BY MR. GARCIA: 13 Q. Have you ever held 2 professional license? 13 Q. Have you ever been a licensed masseuse? 14 A. No. 14 A. No. 15 Q. Do you have any degrees? 15: Q. Have you ever taken any courses to become 16 A, No, Well -- 16 a licensed masseuse? 17 Q. Well -- Pm sorry, go ahead. 1? A. No, 18 A. College degrees or... 18 Q. Have you applied for any licenses and been 19 Q. Any type of degree, high school, college. 13 turned down for same? 20 A, Thave a high school degree. 20 A. No. 21 Q. And what year did you receive that degree? 21 Q. Do you have any facts to deny that 22 A. fm really bad with years. I can't say for 22 Mr. Epstein digitally penetrated Jane Doe No. IJ on 23 sure. 23 each of the about ten occasions that I listed before 24 Q. Okay. And what high school did you 24 for you? 25 receive it from? 25 MR. RHEINHART: Objection to the form of Page 368 Page 370 1 MR. RHEINHART: Instruct the witness not 1 the question in that it assumes knowledge of 2 to answer based on Fifth Amendment. 2 Mr. Epstein and Ms, Doe No. I. It's a 3 THE WITNESS: On the instruction of my 3 compound question. It's ambiguous. And I 4 lawyer, I must invoke my Fifth Amendment right. 4 instruct the witness not to answer based on the 5 BY MR. GARCIA: 5 Fifth Amendment. 6 Q. Were you associated with Mr, Epstein at 6 THE WITNESS: On the instruction of my I the time that you attended high school? 7 lawyer, I must exercise my Fifth Amendment 8 MR. RHEINHART: Objection to the form. 8 right. 9 Standing objection. Instruct the witness not 9 BY MR. GARCIA: 10 to answer. 10 Q. Did you know that Mr. Epstein would 11 THE WITNESS: At the instruction of my 11 digitally penetrate Jane Doe No. II prior to 12 lawyer, I must invoke my Fifth Amendment right. | 12 soliciting her for massages of Mr. Epstein? li 13 BY MR. GARCIA: 13 MR. RHEINHART: Same objection as stated. |} 14 Q. Was it a public or private high school? 14 to the previous question, the standing is MR. RHEINHART: You can answer that, as objection to form and instruct the witness not 16 THE WITNESS: It was home school. 16 to answer. 17 BY MR. GARCIA: 17 MR. GARCIA: Did you -18 Q. But you still got a degree from some 18 MR. RHEINHART: Hold on. 19 entity; is that correct? 19 THE WITNESS: On the instruction of my k 20 A. Yes. 20 lawyer, I must invoke my Fifth Amendment right. # 21 Q. What was the entity that issued you a 2a BY MR. GARCIA: 22 degree? 22 Q. Did you discuss what type of activities 23 MR. RHEINHART: Instruct the witness not 23 Mr. Epstein would engage in with Jane Doe No. I (561) to answer based on the Fifth Amendment. THE WITNESS: On. the instruction of my 832-7500 PROSE COURT REPORTING AGENCY, INC. prior to soliciting her for massages and sexual play 46 (Payee 367 to 370) (561) 832-7506

Page 371 Page 373} 1 MR. RHEINHART: Object to the form of the 1 lawyer, I invoke my Fifth Amendment right. 2 question as ambiguous and standing objection as 2 BY MR. GARCIA: 3 well. Instruct the witness not to answer, 3 Q. Do you own an automobile? 4 THE WITNESS: On the instruction of my 4 MR. RHEINHART: Same instruction. 5 lawyer, I must invoke my Fifth Amendment right. } 5 THE WITNESS: On the instruction of my 6 BY MR. GARCIA: 6 lawyer, I invoke my Fifth Amendment right. 7 Q. Did Mr. Epstein ever tell you that he had 7 BY MR. GARCIA: 8 sought out psychological or psychiatric treatment 8 Q. Who paid for your automobile? 9 for any reason? 9 MR. RHEINHART: Same instruction. 10 MR. RHEINHART: Instruct the witness not 10 THE WITNESS: On the instruction of my ii to answer based on the standing objection. 11 lawyer, | invoke my Fifth Amendment. 12 Objection to form. 12 BY MR. GARCIA: 13 THE WITNESS: On the instruction of my 13; Q. Has Jeffrey Epstein ever purchased an 14 lawyer, I must invoke my Fifth Amendment right. | 14 automobile for you? is BY MR. GARCIA: 15 MR. RHEINHART: Objection to the form 16 Q. Have you ever received any paychecks from | 16 based upon the standing objection and instruct § 1? any enterprise associated or controlled by Jeffrey 17 the witness not to answer. 18 Epstein? 18 THE WITNESS: On the instruction of my 19 MR. RHEINHART: Objection to the form, the} 19 lawyer, { invoke my Fifth Amendment right. 20 standing objection. Instruct the witness not 20 BY MR. GARCIA: li 21. to answer. 21 Q. What limousine service do you use in New 22 THE WITNESS: At the instruction of my 22 York when you move from place to place? 23 Jawyer, I must invoke my Fifth Amendment right. | 23 MR. RHEINHART: Same instruction. 24 BY MR. GARCIA: 24 THE WITNESS: On the instruction of my 25 Q. Do you own a home or some sortofacondo j-25 lawyer, I invoke my Fifth Amendment right. Page 372 Page 3745 1 or anything like that? 1 BY MR. GARCIA: 2 MR. RHEINHART: Instruct the witness not 2 Q. Who pays for your limousine service? 3 to answer based on the Fifth Amendment 3 MR. RHEINHART: Same instruction. 4 privilege. 4 THE WITNESS: On the instruction of my 5 THE WITNESS: On the instruction of my 5 lawyer, | invoke my Fifth Amendment right. 6 lawyer, | must invoke my Fifth Amendment right. | 6 BY MR. GARCIA: 7 BY MR. GARCIA: 7 Q. How do you spend your typical day in New 8 Q. Do you pay rent to any landlord? 8 York? 9 MR. RHEINHART;: Same instruction. 9 MR. RHEINHART: Instruct the witness not 10 THE WITNESS: On the instruction of my 10 to answer based on the Fifth Amendment. Also Li lawyer, I must invoke my Fifth Amendment right. ; 11 objection to the form as to what's a typical 12 BY MR, GARCIA: 12 day. 13 Q. The place where you live, who owns it? 13 BY MR. GARCIA: 14 MR. RHEINHART: Same instruction, 14 Q. Monday through Friday, typical work hours, 15 THE WITNESS: At the instruction of my is say 9:00 to 5:00, what do you typically do Monday 16 lawyer, I must invoke my Fifth Amendment right. | 16 through Friday, 9:00 to 5:00 p.m.? 17 BY MR. GARCIA: 17 MR. RHEINHART: Instruct the witness not 18 Q. Do you exit a building in New York where 18 to answer based on the Fifth Amendment. 19 you exit from a different building's parking garage; 19 THE WITNESS: At the instruction of my q 20 in other words, do you exit -- strike that. 20 lawyer, I must invoke my Fifth Amendment right. 21 Do you use a different parking garage to 21 BY MR. GARCIA: 22 exit the, from the building where you live? 22 Q. What is Financial Trust Company? 23: MR. RHEINHART: Instruct the witness not 23 MR. RHEINHART: fnstruct the witness not 24 to answer based on the Fifth Amendment. 24 to answer based on the Fifth Amendment. ($61) 832-7500 PROSE COURT REPORTING AGENCY, THE WITNESS: At the instruction of my 47 (Pages 371 to 374) Inc. (561) 832-7506

Page 375 a lawyer, I must invoke my Fifth Amendment right. 2 MR. GARCIA: I'm just asking what it is. 3 MR. RHEINHART: Understood. 4 BY MR. GARCIA: 5 Q. Well, let me not waste any time. Do you 6 know what it is, yes or no? 7 MR. RHEINHART: Instruct the witness not 8 to answer based on the Fifth Amendment. 9 THE WITNESS: At the instruction of my 10 lawyer, I invoke my Fifth Amendment right. 11 BY MR. GARCIA: 12 Q. Has Jeffrey Epstein ever told you that he 13 is a government witness, otherwise known as a 14 snitch, or confidential informant? 15 MR. RHEINHART: Objection to the form in 16 that it assumes knowledge of Mr. Epstein. 17 Instruct the witness not to answer. 18 THE WITNESS: On the instruction of my 19 lawyer, I invoke my Fifth Amendment right. 20 BY MR. GARCIA: 21 Q. Has he ever told you that he is involved 22 in a case involving, providing information 23 concerning money laundering? 24 MR. RHEINHART: Same objection and same (25 instruction. Page 376 1 THE WITNESS: At the instruction of my 2 lawyer, I must invoke my Fifth Amendment right. 3 MR. GARCIA: That's ali Ihave. Thank 4 you. 5 MR. RHEINHART: Great. Should we take a 6 break? { know you need to change the tape as 7 well. 8 THE VIDEOGRAPHER: Yes. We're now going 9 off the record. It is 5:18 p.m. LO (A brief recess was held.) Ae eR 48 (Pages 375 to 376 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/ JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME III OF IIT JEFFREY EPSTEIN, Defendant. / Related cases: 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-80811, 08-80893, 09-80469 09-80591, 09-80656, 09-80802, 09-81092 / VIDEOTAPED DEPOSITION OF SARAH KELLEN Wednesday, March 24, 2010 10:37 - 6:51 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rache! Sridge (201-272-817-4627) 905d1499-Gcd8-4509-a2a0-Gd38827b68C6

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028058XXXXMB AD E.W., Plaintiff, -vs- VOLUME III OF IIi JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF SARAH KELLEN Wednesday, March 24, 2010 10:37 - 6:51 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (S61) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) 905d1499-0cd8-4599-a2a0-6d38827bE8C6

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AB Plaintiff, -vs- VOLUME III OF III JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF SARAH KELLEN Wednesday, March 24, 2010 10:37 - 6:51 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) 905d1499-0cd8-4599-a2a0-6d38827b68c6

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.502008CA037319XXXXMB AB Plaintiff, -vs- VOLUME TII OF III JEFFREY EPSTEIN AND SARAH KELLEN, Defendants. VIDEOTAPED DEPOSITION OF SARAH KELLEN Wednesday, March 24, 2010 10:37 - 6:51 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC, (561) 832-750 Electronically signed by Rachet Bridge (204-272-617-4627) 905d1499-0cd8-4599-a2a0-6d38827h68C8

Page 381 Page 383 1 APPEARANCES: 1 ee | 2. On behalf of the Plaintiff, B.B.: 3 SPENCER T, KUVIN, ESQUIRE, INDEX LEOPOLD KUVIN 2 a . de alia 3 WITNESS: —-DIRECT_CROSS REDIRECT RECROSS S Palm Beach Gardens, Florida 33410 4 Sarah Kellen 5 Phone: 561.515.1400 5 By Mr. Garcia 383 7 On behalf of the Plaintifis, .M.,E.W. and 6 By Ms. Bzelt 386 Jane Doe: 7 8 9 MATTHEW WEISSING, ESQUIRE 8 --FARMER, JAFFE, WEISSING, EDWARDS 10 FISTOS & LEHRMAN, PLL. 3 BXEIBLTS 425 North Andrews Avenue 10 ere al Suite 2 aL EXHIBIT PAGE Fort Landerdale, Florida 33301 (ras a2 Phone: 954.524.2820 12 Exhibit 16 389 13 On behalf of Jane Does 1 through 8: 43 a4 ADAM D. HOROWITZ, ESQUIRE i4 MERMELSTEIN & HOROWITZ, P.A. 15 18205 Biscayne Boulevard 15 Suite 2218 16 16 Miami, Florida 33160 Phone: 305.931.2200 iy 17 E-mail: Ahorowitz@sexabuseattomey.com iB 18 On behalf of the Plaintiffs, 101, (02 and 103; 19 KATHERINE W. EZELL, ESQUIRE i9 AMY JOSEFSBERG EDERI, ESQUIRE 20 20 PODHURST ORSECK 25 West Flagler Street 21 22 Suite 800 22 Miami, Florida 33130 22 Phone: 303.358,2800 23 23 (Via telephone) 24 24 25 25 Page 382 Page 384 1 Appearances continued... 1 PRODEEDINGS 2 On behalf of the Plaintif®, Jane Doe HI: 2 : 3 ISIDRO MANUEL GARCIA, ESQUIRE ant GARCIA, BLKINS & BOEHRINGER 3 THE VIDEOGRAPHER: We are now on the record. 4 Wes ae pear hard eee 4 [tis 5:42 p.m, and I'm on media number three. 5 Phone: 561.832.8033 5 MR. REINHART: If I could just put something . Ovvudrsrbe 6 quickly on the record before we start. alf of the Defendant: Fa 8 JACK ALAN GOLDBERGER, ESQUIRE 7 [know Mr. Garcia said be had a couple of ATTERBURY, GOLDBERGER & WEISS, P.A. 8 additional questions, which I have no objection to 9 oe) hella Avenue South 3 him asking, but it is 5:42 and we've been going 10 West Palm Beach, Florida 33401-5012 10 almost seven hours with Ms. Kellen. Phone: 561.689.8300 12 And I know Ms. Ezell has questions and she has or 12 got her one client she has to ask questions about. 13 ‘On behalf of the Witness: 13 T understand that, but I hope we can focus on going 14 BRUCE £. REINHART, ESQUIRE 14 LAW OFFICE OF BRUCE E REINHART forward to areas that have not already been covered 1s One Clearlake Center is so we can actually get out of here tonight, because ag as0 pout foerient Avsrng, Ss 1400 16 at some point we really do have to go, and I would fest Palm Beach, Flori ‘ ‘ ‘ Pane 561000 36D 47 like to get this over with today. 17 18 So with that, Mr. Garcia, if you have some z 19 additional questions, I have no objection to you 20 ALSO PRESENT: 20 asking that. 2u Jessica Cadwell, Paralegal 21 MR. GARCIA: Thank you. us ‘Burman, Critton, Luttier & Coleman, P.A. 22 CROSS - continued (GARAH KELLEN) 23 Joseph Kozak, Videographer 23 BY MR. GARCIA: 33 Prose Court Reporting Services 24 Q. Have you ever had a different hair color? 25 MR. REINHART: Asking if at any time in her 5 (Pages 381 to 384) (961) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) 905d1499-0cd8-4699-a2a0-Gd38827b68c6

Page 385 Page 387 1 life she's ever dyed her hair a different hair 1 Q. And you are sure that you only had it up for 2 color? 2 about ten minutes? 3 MR. GARCIA: Yes, or if she's dyed her hair 3 MR. REINHART: Did you mean fiterally ten 4 now or if that’s her natural color. Let's start 4 minutes or just for a brief period of time? 5 with that. . 5 THE WITNESS: A very brief period of time. 6 BY MR. GARCIA: 6 MR. REINHART: You can answer Mr. Garcia's 7 Q, Is that your natural color? 7 question, 8 MR. REINHART: Answer that. 8 BY MR. GARCIA: 9 THE WITNESS: Yes. 9 Q. Can you be more specific? Are we talking 10 BY MR. GARCIA: 10 about ten minutes for a day or ten minutes in a week or a. Q. What is your natural color, so the transcript 11 a month? 12 will reflect it? 12 A. Maybe a day. Maybe two days. 13 MR. REINHART: We have a video, sol think | 13 Q. Okay. 14 it's pretty clear, 14 MR. GARCIA: Okay, that's all [ have. Thanks. 15 THE WITNESS: Brown. 15 CROSS (SARAH KELLEN) 16 BY MR. GARCIA: 16 BY MS. EZELL: 17 Q. Have you ever dyed your hair or colored your | 17 Q. Ms. Kellen, my name is Katherine Bzell. I'm 18 hair blonde or any type of shade of light, lighter 18 here with Amy Josefsberg Ederi, We represent Jane Doe | 19 shade? 19 103, We also represent three clients who have not yet 20 MR. REINHART: You mean at any time in her | 20 filed. Some of the questions may be repetitive, but I 2u life has she done that? 21 believe we have the right to ask them with regard to our 22 MR. GARCIA: Yes, sir. 22 clients. So with that said, we'll move along as fast as 23 THE WITNESS: Yes. 23 we can, 24 BY MR. GARCIA: 24 Why did you take down your Facebook page? 25 Q. For what period of time? 25 A. [think it's a stupid site. I don't Page 386 Page 3885 a A. Idon't recall. 1 understand it. I don't understand the point of it. 2 Q. And how long have you gone back to your 2 Q. Do you have e-mail? 3 natural color brown? 3 A. Yes. 4 A. It's been a long time. { don't recall exactly 4 Q. And what is your e-mail address? 5 the dates, . 5 MR. REINHART: Instruct the witness not to 6 Q. Do know somebody named Craig Greezyn, G-rec,| 6 answer based on Fifth Amendment privilege. F s as in cat, z as in Zorro, y-n? o THE WITNESS: At the advice of counsel, I must 38 A. No. 8 invoke my Fifth Amendment right. E 9 Q. He's a student at SUNY University, S-U-N-Y, in 9 BY MS. EZELL: 10 Courtland. 10 Q. Have you, have you done e-mail under the li A. No idea. li address JKetlens@Earthlink net? 12 Q. Do you know Kofi Sansculotte, K-o-f-i, 12 A. Can you repeat that? I'm sorry. 13 S-a-n-s-c-u-[-0-t-t-e? 1S) Q. Have you used e-mail with the address 14 A. No. 14 JKellens@Earthlink.net? 15 Q. And Michael Daley? 15 A. No. 16 A. No. 16 Q. Have you used e-mail with the address 17 Q. [tried to see if 1 could Google your Facebook 1? Kellens@Earthlink.net? 18 page, and you thought you took it down after about ten 18 MR. REINHART: Hold on a second, I'm going to 19 minutes, I did come up with three or four Sarah 19 instruct the witness not to answer any questions 1 20 Kellens. I'm not sure if it's the same one that you 20 about any e-mail addresses that she may or may not 21 are, but are you sure that you've taken it down? 21 have had in the past based on her Fifth Amendment 22 A. Yes. 22 privilege. 23 Q. And do you have any idea when you took it 23 THE WITNESS: At the advice of my counsel, I 24 down? 24 must invoke my Fifth Amendment right. (561) A. Maybe a year ago. 832-7500 PROSE COURT REPORTING AGENCY, Electronically signed by Rachel Bridge (204-272-617-4627) 6 (Pages 385 to 388) INC. (561) 832-7506 905d1499-0cd8-4599-a2a0-6d38827b68c6

22 23 24 25 OOIWATRWHH Pe RPP ee QewWNEO 16 (561) 832-7500 Electronically signed by Rachel Bridge (201-272-617-4627) Page 389 Page 391 BY MS. EZELL: 1 THE VIDEOGRAPHER; Okay. Q. With regard to the Facebook page again, why 2 MS. EZELL: This is the second page, did you start it up if you thought it was a stupid site 3 THE VIDEOGRAPHER: Okay. and didn't know how to use it? 4 MS. EZELL: And here's the third page. A. was just curious. 5 THE VIDEOGRAPHER: Okay. Q. Did anyone help you do that? 6 MS, EZELL: And just for identification A, No. 7 purposes, those are Bates stamped SAO 496 Q. Did anyone tell you to take it down? 8 through -- I'm sorry, 495 through 497. if you A, No. 9 would pass that down, please, to the witness. Q. You were asked about any licenses. Have you 10 BY MS. EZELL: never held a real estate license? 11 Q. Do you recognize this. Sorry? E A. Never. 12 MR. REINHART: Are you asking about all three f Q. Do you hold any licenses in any states other 13 pages simultaneously or one page at a time? than Florida? 14 MS. EZELL: All three sirnultaneous. MR. REINHART: When you say licenses, you mean | 15 MR. REINHART: Okay. professional as opposed to a driver's license or 16 BY MS. EZELL: some other sort of a license? 17 Q. This appears to be, the first page appears to MS. EZELL: Yes. 18 indicate that this was obtained from the driver's THE WITNESS; 1 don’t have a license anywhere 19) license authority in Hawaii. for anything. 20 MR, REINHART: The first page we have looks BY MS. EZELL: 21 like it's a printed page. Q. Do you have a driver's license? 22 MS. EZELL: Right. | A. Yes. 23 MR. REINHART: From - oh, I see. Okay, never jj Q. And in what state? 24 mind. MR, REINHART: | instruct her not to answer 25 Page 390 Page 392% based on her Fifth Amendment privilege. 1 BY MS. EZELL: THE WITNESS: At the advice of counsel, I must 2 Q. It's from the supervising driver license clerk invoke my Fifth Amendment privilege. 3 in the city and county of Honolulu. Do you see that? MR. REINHART: You can roll your eyes al! you 4 A. Yes. want, Mr, Horowitz. It's my client's right. 7 5 Q. Do you recognize that application, pages two She'll invoke it if she needs to, 6 and three? ; MR. HOROWITZ: I was shaking my head, not 7 MR. REINHART: Page two is a printout of what rolling my eyes. The Fifth Amendment assertion as 8 appears to be a driver's license. Page three E to whether a person has a driver's license is 9 appears to be a fingerprint. ridiculous. It is ridiculous. 10 Is that what you are asking her, if she MR. REINHART: You can have that opinion, and; 11 recognizes this? if you want to bring that up to the judge, I'll be 12 MS.EZELL: Yes, uh huh. happy to explain to the judge why its a valid 13 MR. REINHART: | instruct her sot to answer invocation. I disagree with you. 14 those questions. MS. EZELL: It is certainly a record that the 15 THE WITNESS: At the instruction of my lawyer, {i government has and can be accessed. 16 1 must invoke my Fifth Amendment right. i MR. REINHART: That's true. 17 BY MS. EZELL: (The document was marked Exhibit 16 for 18 Q. Even though this is a public record? identification.) 19 MR. REINHART: Well, if it's a public record BY MS. EZELL: 20 or not, she doesn't have to admit or authenticate Q. I'm going to show you in a moment what I have 21 it for you. You can prove it some other way. She premarked as Exhibit 16. 22 has a Constitutional right not to admit or MS. EZELL: Actuaily, it's Composite 16. It's 23 authenticate the document for you, and that's what three pages. I'll show it before I give it to the PROSE COURT REPORTING AGENCY, she is invoking. 7 (Pages 389 to 392) INC, (561) 832-7506 905d 1499-Ned8-4599-a2al-6d3B827b6Bcs

Page 393 Page 395 ij 1 BY MS. EZELL: L BY MS. EZELL: 2 Q. Did you ever hold a Hawaii driver's license? 2 Q. Did you at one time hold a post office Box 833 3 MR. REINHART: Same instruction. It's been 3 in — [won't pronounce it right, but Haliewa, Hawaii? 4 asked and answered. 4 THE REPORTER: Could you spell -5 THE WITNESS: At the instruction of my lawyer, 5 MS. EZELL: ft's H-a-l-i-e-w-a, I believe. 6 T must invoke my Fifth Amendment right. 6 MR. REINHART: I instruct the witness not to 7 BY MS. EZELL: 7 answer based on her Fifth Amendment privilege. i 8 Q. Do you currently hold a Hawaii driver's 8 THE WITNESS: At the instruction of my lawyer, |} 9 license? 9 I must invoke my Fifth Amendment right. i 10 MR. REINHART: It's been asked and answered, | 10 BY MS. EZELL: 11 sarne instruction. 11 Q. Were you bom on May 25, 1979? 12 THE WITNESS: At the instruction of my lawyer, | 12 MR. REINHART: Same instruction. 13 T must invoke my Fifth Amendment right. 13 ‘THE WITNESS: At the instruction of my lawyer, # 14 BY MS. EZELL: 14 I must invoke my Fifth Amendment right. 18 Q. Is that not your picture on the second page of 15 BY MS. EZELL: 16 that exhibit? 16 Q. Do you see a signature there for Sarah Kellen? 17 MR. REINHART: Same instruction. 17 MR. REINHART: Just asking if she sees a 18 THE WITNESS: At the instruction of my lawyer, } 18 signature on the paper —~ 19 I must invoke my Fifth Amendment right. ig MS. EZELL: That says Sarah Kelien. 20 BY MS. BZELL: 20 THE WITNESS: I see it. 21 Q. Do you see the name Kellen, Sarah Lynnelie? ai BY MS. EZELL: 22 MR. REINHART: She's just asking if you see 22 Q. Is that your signature? 23 that on the document. 23 MR. REINHART: Instruct the witness not to 24 THE WITNESS: Yes. ~ [24 answer based on her Fifth Amendment privilege. E 25 25 THE WITNESS: At the instruction of my lawyer, |} Page 394 Page 396} i. BY MS. EZELL: 1 [must invoke my Fifth Amendment right. i 2 Q. And haven't you testified today that that is 2 BY MS. EZELL: 3 your name? 3 Q. Do you drive an automobile in Palm Beach 4 MR. REINHART: The testimony will speak for 4 County? 5 itself. Next question. 5 MR. REINHART: Let me understand the question. 6 BY MS. EZELL: 6 Are you asking if she ever drives a vehicle in the Te Q. You may answer. 7 county or if she drives a vehicle registered in the 8 MR. REINHART: Next question. 8 county? 9 MS. EZELL; You are instructing her not to 2 MS, EZELL: If she drives a vehicle in Palm 190 answer that question? 10 Beach County. il MR. REINHART: Lam. ii MR. REINHART: You can answer that, In other 12 BY MS. EZELL: 12 words, did you drive a car here today? 13 Q. What was your address at the time that that, 13 THE WITNESS: Yes. 14 that you applied for a license then? 14 BY MS, EZELL: 15 MR. REINHART: Object to the form, assumes 15 Q. You were asked earlier if you have ever been 16 facts that she has not acknowledged, that she ever 16 to Palm Beach as opposed to West Palm Beach where we are|? 1? applied for this license, and I'll instruct her not 17 today, and I believe you answered yes. 18 to answer. 18 A. Uh huh. 19 BY MS. EZELL: 19 Q. Where have you been in Palm Beach? 20 Q. Is the post office box -- 20 MR. REINHART: | instruct her not to answer ai MR. REINHART: Hold on, let her answer or not | 21 based on her Fifth Amendment privilege. 22 answer. 22 THE WITNESS: At the instruction of my lawyer, 23 THE WITNESS: At the instruction of my lawyer,| 23 I must invoke my Fifth Amendment right. 24 I must invoke my Fifth Amendment right. 24 BY MS. EZELL: 25 8 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (261-272-617-4627) 905d1499-0cd8-4599-a2a0-6d38827b68C6

Page 397 Page 399} (561) 832-7500 Electronically signed by Rachel Bridge (201-272-617-4627) 1 island, if it's an island? 1 BY MS. EZELL: 2 MR. REINHART: Objection, it's been asked 2 Q. Do you know Glenn Dubin? 3 before, and I'l instruct her not to answer for the 3 MR, REINHART; It's also asked and answered, 4 same reason. 4 but I'll fet her answer it again. 5 THE WITNESS: At the instruction of my tawyer,| 5 THE WITNESS: At the instruction of my lawyer, 6 {I must invoke my Fifth Amendment right. 6 I must invoke my Fifth Amendment right, 7 BY MS. EZELL: 9. BY MS. EZELL: 8 Q. Have you ever heard of Jeffrey Epstein? 8 Q. Do you know that they have two daughters? 9 MR. REINHART: Objection, instruct the witness 9 MR. REINHART: Same instruction, objection to 10 not to answer based on her Fifth Amendment 10 the form, assumes facts that she has not lL privilege. 11 acknowledged, so there is no foundation for the 12 THE WITNESS: At the instruction of my lawyer, } 12 question. 13 Lmust invoke my Fifth Amendment right. 13 THE WITNESS: At the instruction of my lawyer, 14 MR. REINHART: It's also been asked and 14 I must invoke my Fifth Amendment right. 15 answered, 15 BY MS. EZBLL: 16 BY MS. EZELL: 16 Q. Have you ever seen pictures of the little 17 Q. Do you read the newspapers? 17 girls? 18 A. Not really. 18 MR. REINHART: Which little girls? 19 Q. Have you read any newspapers in the last four 19 MS, EZELL: The Dubins' children. 20 years in Palm Beach County? 20 MR. REINHART: Objection to form. Once again, 21 A. Tm sure I have. 2i assumes facts that she has not acknowledged, that 22 Q. Have you read the Palm Beach Post? 22 there is no foundation. Instruct her not to answer 23 A. No, I don't. 23 the question. 24 Q. What newspapers do you read? 24 THE WITNESS: At the instruction of my lawyer, 25 A. New York Times, New York Post. That's about | 25 I must invoke my Fifth Amendment right. Page 398 Page 400 rT it, on occasion, 1 BY MS. EZELL: 2 Q. And have you ever - do you watch the news on 2 Q. Ave you an only child? ie 3 TV, local news? 3 MR. REINHART: It's been asked and answered or! 4 A, No. 4 responded to, and I'll instruct her once again to § Q. When you did your Facebook page, whose 5 respond. 6 computer did you use? 6 THE WITNESS: At the instruction of my lawyer, {/ ef: A. My own, 7 I must invoke my Fifth Amendment right. 8 Q. What kind of computer do you own? 8 BY MS.EZELL: 9 A. An Apple computer. 3 Q. Lbelieve you stated that you had changed your 10 Q. Isita laptop? 10 hair color at some point in your life. 11 A. Yes. a1 Have you changed it in the last five years? 12 Q. How long have you had that computer? 12 A. I don't recall exact years and dates. 13 A. [don't recall. 13 Q. Fm sorry? 14 Q. Do you know Eva Andersson? 14 A. [don’t recall exact years and dates that I 15 MR. REINHART: Objection, it's been asked and | 15. have. 16 answered. 16 Q. Have you been a blonde at some point in the 17 MS. EZELL: I think it was asked whether or 17 last, in the last eight years? 18 not she had been on a plane with her. 18 A. Most likely. 19 MR. REINHART: I believe she was asked ifshe | 19 Q. Atmore than one time? In other words, have 20 knew who Eva Andersson was, but she can go ahead | 20 you gone back and forth between being a brunette and a 21 and respond to the question. 1 instruct her not to 21 blonde or were you a blonde for a certain period of 22 answer. 22 sime? 23 THE WITNESS: At the instruction of my lawyer,| 23 A. I think I went back and forth at one point. I must invoke my Fifth Amendment right. 24 Q. Have you ever either had an office or worked at an office i in n this building, which is One c PROSE COURT REPORTING AGENCY, 9 (Pages 397 to 5 400) INC. (561) 832-7506 905d1489-0cd8-4599-azal-6d38827b68C6

Page 401 Centre? MR. REINHART: Instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: At the advice of counsel, I must invoke my Fifth Amendment right. BY MS. EZELL: Q. Have you ever gone to that office on a daily basis with Jeffrey Epstein? MR. REINHART: Objection to form. There is no: foundation, because she hasn't acknowledged going to an office in this building. Also objection as to the implied knowledge of Mr. Epstein. Instruct her not to answer. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MS. EZELL: Q. Have you ever had anything to do with a company called the Florida Science Foundation? MR. REINHART: Instruct the witness not to answer based on Fifth Amendment, THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MS. EZELL; Q. Your middle name is Lynnetle; is that correct? A. Correct. OOIHNRWN PE Page 403} BY MS. EZELL: Q. Do you consider yourself a citizen of the United States? MR. REINHART: You can answer that. THE WITNESS: Yes. BY MS. EZELL: Q. And of what state do you consider yourself to bea citizen? MR, REINHART: That was just asked and answered, MS, EZELL: | asked about residency. MR. REINHART: | apologize. THE WITNESS: What's the difference? MR. REINHART: Instruct the witness not to answer the question based on Fifth Amendment. THE WITNESS: At the instruction of my lawyer, } I must invoke my Fifth Amendment right. BY MS. EZELL: Q. Have you changed your residency in the last three years? MR. REINHART: Residency for which? I just want to be clear, Ms. Ezell. You mean legal residency or where she actually lives residency? MS. EZELL: Well, let's do both. (561) 832-7500 Electronically signed by Rachet Bridge (201-272-617-4627} Page 402 Q. L-y-n-e-Ll-e? MR. REINHART: It's been asked and answered twice. You can answer it again. THE WITNESS: L-y-n-n-e-l-l-e. BY MS. EZELL: Q. Thank you. Where do you, of what siate are you a resident? MR. REINHART: Instruct the witness not to answer based on Fifth Amendment. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MS. EZELL: Q, Where do you vote? MR. REINHART: Same instruction. THE WITNESS: At the instruction of my lawyer, L must invoke my Fifth Amendment right. BY MS. EZELL: Q. Are you registered to vote? MR. REINHART: It’s been asked and answered. I'l instruct her not to answer again, or to answer it, to respond to it, I should say. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. PROSE COURT REPORTING AGENCY, Page 404 ff BY MS. EZELL: Q. Have you changed your legal residency in the last five years? A. I don't think so. Q. Have you changed the place you live in the last five years? I MR. REINHART: Instruct her not to answer that question based on Fifth Amendment. : THE WITNESS: At the advice of counsel, I must invoke my Fifth Amendment right. BY MS. EZELL: Q. Have you changed your citizenship, your state citizenship in the fast five years? MR. REINHART: Again, for purposes of voting and other things or just ~ MS. EZELL: Yes, whatever things citizenship entitles one to do. i MR. REINHART: Ifyou understand the question, ff you can answer it. THE WITNESS: I don't recall really ever changing -- I didn't know that you could change your citizenship of a state, BY MS. EZELL: Q. Well, if you move from one state to another, 's registration. Have you 10 (Pages 401 to 404) (561) 832-7506 906d1499-0cd8-4599-a2a0-6d38827b68C6 INC.

Page 405 done that? MR. REINHART: You can answer. THE WITNESS: No. BY MS. EZELL: Q. Are you a resident of or citizen of the US Virgin Islands currently? MR. REINHART: Do you understand? You can answer it. THE WITNESS: No. BY MS. BZELL: Q. Do you pay taxes in any state? MR. REINHART: Answer that yes or no. THE WITNESS: Yes. BY MS. BZELL: Q. In what states do you pay taxes? MR. REINHART: Instruct her not to answer that question based on Fifth Amendment. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MS. BZELL: Q. Do you own property in any state? MR. REINHART: It's a yes or no question. You can answer that. THE WITNESS: No. OOH ®wye Page 407 THE WITNESS: At the advice of my lawyer, I must invoke my Fifth Amendment right, BY MS. EZELL: Q. What kind of modeling did you do at 18? A. Very little. I did a job for Champion Sportswear, a couple of hair shows. That's about it teally. Q. Have you ever been involved in modeling for MC f, Squared? MR. REINHART: Instruct the witness -~ objection to the form, assumes knowledge of an entity by the name of MC Squared which the witness has not acknowledged or have any knowledge of, so there is no foundation for the question. I'd instruct her not to answer based on her Fifth Amendment privilege. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MS. EZELL: Q. Have you ever been photographed nude or partially nude? MR. REINHART: When you say partially nude, can you clarify? MS, EZELL: With either, without a top or without a bottom or with something draped across (561) Page 406 BY MS. EZELL: Q. is that a no? A, No. Q. Have you owned property in any state in the last five years? A. No. Q. Are you taking any prescribed medication at this time? MR. REINHART: You can answer the question. THE WITNESS: Yasmin. BY MS. BZELL: . I'm sorry? . Yasmin. It's a birth control pill. . Anything else? . No. . You didn't take anything before this deposition today? A. No. Q. At what age did you first model professionally? A. believe I was 18. Q. And for what company or organization did you model at 18? 832-7500 PROSE COURT REPORTING AGENCY, Electronically signed by Rachel Bridge (201-272-617-4627) Page 408 part of a body, but not all parts of her body. f THE WITNESS: My boyfriend took pictures of me one time. E BY MS. EZELL: Q. And what happened to those, where are those pictures? A. Thave them. Q. And who is your boyfriend? MR. REINHART: Hold on a second, Instruct the witness not to answer based on her Fifth Amendment privilege. BY MS, EZELL: Q._ Is that your current boyfriend who took the pictures? MR, REINHART: You can answer that, THE WITNESS: No. BY MS. EZELL: Q. In those pictures were you nude or partially nude? MR. REINHART: At this point this is getting into her privacy rights beyond the scope of anything | think that's relevant to this case. I'm going to ask you to move on. MS. EZELL: Are you instructing her not to answer? 405 to 408) ll (Pages (561) 832-7506 905d1499-0cd8-4598-a2a0-6d38627b68C6 INC,

WOIKHEERWNHE MR. REINHART: fam. Lam. BY MS. EZELL: Q. Do you have all copies of those pictures or have they been distributed? A. [hope I have afl copies. Q. Would you piease ~ i have a little difficulty hearing you. A. Sorry. Q. Would you please tell me again all the companies that you have modeled for? A. I don't remember their names. It was so long ago. . One was a sporting -. Oh, { got a job for Champion Sportswear. . And what did you model for Champion? . Athletic wear. . And then you said some hair shows? . Right. Just where they cut and color your hair in different styles and you do a little runway show. Q. Have you ever done a runway show for, for clothes, clothing? A. No. Q. Who introduced you to Jeffrey Epstein? MR. REINHART: Instruct the witness not to Page 411 THE WITNESS: I don't -- I don't get it, It's vague. I don't understand the question. BY MS, EZELL: Q. Are you not aware of an organization that limits its membership to billionaires? A. No, I'm not. Q. Atsome point did you become an employee of Jeffrey Epstein? MR. REINHART: Instruct the witness not to answer based on her Fifth Amendment privilege, and : that’s also been asked and answered several times. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right, BY MS. EZELL: Q. By whom are you currently employed? answered several times. Instruct her not to answer. B THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment right. : BY MS. EZELL: Q. Are you employed by an individual or by a corporation? MR. REINHART: Same instruction. THE WITNESS: At the instruction of my lawyer, |i (561) 832-7500 Electronically signed by Rachel Bridge (201-272-617-4627) Page 410 answer based on her Fifth Amendment privilege. THE WITNESS: At the instruction of my lawyer, IT must invoke my Fifth Amendment right. BY MS. EZELL: Q. Have you ever been to a social event in New York that is restricted to billionaires? A. Sorry, can you repeat that? Q. Yes. Have you ever been to a social event that's held annually in New York restricted to billionaires? A. I've never heard of such an event, no. Q. Have you ever been to such an organization in California? A. No. J, [have never heard of such an event like that, so I don't know, Q. Have you never seen your picture taken and displayed in print media at such an event? MR. REINHART: Objection to the form. It's not established she has any idea what event or what kind of event this would be. BY MS. EZBLL: Q. An annual event involving millionaires -billionaires, excuse me. MR. REINHART: Objection to the form. There DIANA WNHe NVNNOONER HEHE PERE ARON EBSODIYADAGDERWNHH OO PROSE COURT REPORTING A Page 412 I must invoke my Fifth Amendment right. BY MS. EZELL: Q. Do you receive a W2? MR. REINHART: Same instruction. THE WITNESS: At the instruction of my lawyer, f 1 must invoke my Fifth Amendment right. E BY MS. EZELL: Q. Do you receive a 1099? MR. REINHART: Same instruction. THE WITNESS: At the instruction of my lawyer, fF i must invoke my Fifth Amendment right. BY MS. EZELL: Q. Does anyone claim you as a dependent on their tax returns? MR, REINHART: Anyone other than herself? MS. EZELL: Yes. THE WITNESS: No. BY MS. EZELL: Q. Have you ever signed a confidentiality agreement? MR. REINHART: With anyone? MS. EZELL: Yes. MR. HOROWITZ: Instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: At the instruction of my lawyer, (Pages 409 to 412) (561) 832-7506 GENCY, INC. 905d4499-Ocd8-4599-a2a0-8d38827b68c6

Page 413 Page 415} 1 I must invoke my Fifth Amendment right, 1 implicitly. Instruct the witness not to answer. E 2 BY MS. EZELL: 2 THE WITNESS: At the instruction of my lawyer, 3 Q. Have you stated that you consider yourself a 3 i must invoke my Fifth Amendment right. ; 4 foyal employee? 4 BY MS. EZELL: 5 A. Have F what? I'm sorry. 5 Q. Do you know Juan Alessi? i 6 Q. Have you ever stated that you consider 6 THE WITNESS: At the instruction of my lawyer, ff 7 yourself a foyal employee? ? T must invoke my Fifth Amendment right. 8 A. I don't recall ever saying those words. 8 BY MS. EZELL; 9 Q. Is it true that you will do anything Jeffrey 2 Q. Do you know Alfredo Rodriguez? 10 Epstein asks? 10 MR. REINHART: It's been asked and answered. ai MR. REINHART: Objection to the form, compound} 11 Go ahead and answer it again. 12 question. Assumes knowledge of Jeffrey Epstein, so 12 THE WITNESS: At the instruction of my lawyer, 13 linstruct the witness not to answer. 13 I must invoke my Fifth Amendment right. 14 THE WITNESS: At the instruction of my lawyer, 14 BY MS. EZELL: 15 I must invoke my Fifth Amendment privilege. 4s Q. [think you also might have been asked if you 16 BY MS. EZELL: 16 know Januscz Banasiak. 17 Q. In 2005 and "6, did you have a designated 17, THE WITNESS: At the instruction of my lawyer, 2 18 computer in Mr. Epstein's home on El Brillo Way? 18 imust invoke my Fifth Amendment right. F 19 MR. REINHART: Objection to form, it's 19 BY MS. EZELL: 20 compound and assumes knowledge of Mr. Epsiein and | 20 Q. Are you a photographer? 21 of a focation on El Brillo Way, so I instruct the 21 MR, REINHART: Objection to the form, it's 22 witness not to answer. 22 ambiguous. Amateur photographer? Professional 23 THE WITNESS: At the instruction of my lawyer, 23 photographer? Can you clarify? 24 1 must invoke my Fifth Amendment right. 24 BY MS. EZELL: 25 25 Q. Do you enjoy photography? Page 414 Page 416% a BY MS. EZELL: 1 A. Yes, 2 Q. Did you have on a computer at El Brillo Way a 2 Q. What kind of camera do you have? 3 list of contact information and pictures of numerous 3 MR. REINHART: Instruct the witness not to 4 young women? 4 answer the question. 5 MR. REINHART: Objection to the form, it's § THE WITNESS: At the instruction of my lawyer, 6 compound and it is lack of foundation based on the 6 I must invoke my Fifth Amendment right. 2 prior question and answer. 7 BY MS. EZELL: 8 Instruct the witness not to answer. 8 Q. Do you know Maria Alessi? 9 THE WITNESS: At the instruction of my lawyer, 9 THE WITNESS: At the instruction of my lawyer, 16 imust invoke my Fifth Amendment right. 10 {must invoke my Fifth Amendment right. 11 BY MS. EZELL: 1i BY MS. EZELL; 12 Q. Did you and Ghislaine Maxwell share that 12 Q. Have you ever known Jeffrey Epstein to give 13 information on both of your computers? 13 cameras to young women who come to his home to give him E 14 MR. REINHART: Objection to form, assumes 14 massages? 15 knowledge of a person by the name of Ghislaine; is MR. REINHART: Objection to the form, standing 16 Maxwell, 16 objection, lack of foundation as to Mr. Epstein and 17 Also lack of foundation based on the prior two 17 to his home. Instruct the witness not to answer, 18 answers. Instruct the witness not to answer. 18 THE WITNESS: At the instruction of my lawyer, 19 THE WITNESS: At the instruction of my lawyer,| 19 i must invoke my Fifth Amendment right. 20 I must invoke my Fifth Amendment privilege. 20 BY MS. EZELL: 21 BY MS.BZELL: 21 Q. Have you been encouraged in your pursuit of 22 Q. Would you consider your role in the Epstein 22 photography by Mr. Epstein? 23 household to be that of assistant to Mr. Epstein? 23. MR. REINHART: Same objection previously 24 MR. REINHART: Objection to form, lack of 24 stated. foundation, assumes knowledge < of Mr. Epstein THE With ESS: At the instruction of: ny lawyer, 13 (Pages 4 13 to 416) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) 905d1499-Ocd8-4599-a2a0-Gd38827b68c6

Page 417 Page 419 L T must invoke my Fifth Amendment right. 1 THE WITNESS: At the instruction of my lawyer, . 2 BY MS. EZELL: 2. i must invoke my Fifth Amendment right, 3 Q. Have you ever taken pictures of any of the 3 BY MS. EZELL: 4 young women who have visited the Epstein mansion to 4 Q. Have you, have you ever photographed any of 5 provide massages? 5 the young women who visited or visit the Epstein home to | 6 MR. REINHART: Objection to form, compound, 6 provide massages to Mr. Epstein? 7 lack of foundation. Insteuct the witness not to 7 MR, REINHART: Objection to form, it's been 8 answer. 8 asked and answered. 9 THE WITNESS: At the instruction of my lawyer, g Also lack of foundation and standing 10 I must invoke my Fifth Amendment right. 10 objection. Same instruction. 11 BY MS. EZELL: 11 THE WITNESS; At the instruction of my lawyer, 12 Q. Are you aware of any hidden cameras on the 12 I must invoke my Fifth Amendment right, 13 premises? 13 BY MS. EZELL: 14 MR. REINHART: Which premises? 14 Q. Have you ever photographed any minor girls who TS: MS. EZELL: At the El Brillo Way address of 15 are either partially nude or nude? 16 Mr. Epstein. 16 MR. REINHART: That's also been asked and 17 MR. REINHART: Objection to form, lack of 17 answered. ! instruct her once again not to answer 18 foundation, compound. Instruct the witness notto | 18 the question. 19 answer, 19 THE WITNESS: At the instruction of my lawyer, 20 THE WITNESS: At the instruction of my lawyer, | 20 [ must invoke my Fifth Amendment right. 21 T must invoke my Fifth Amendment right. 21 BY MS. EZELL: 22 BY MS. EZELL: 22 Q. Have you ever been aware of something called 23 Q. Did you ever meet a young woman named A.D.? | 23 the Edge Group? 24 A.. At the instruction of my lawyer, I must invoke 24 MR. REINHART: Consult. 25 my Fifth Amendment right. 25 THE WITNESS: At the advice of my lawyer, I Page 418 Page 4202 L Q. Were you sometimes designated or requested by L must invoke the Fifth Amendment right. 2 Mr. Epstein to buy gifts for the young women who would 2 BY MS. EZELL: 3 come to the home to give him massages? 3 Q. Is that the name of a group that's, whose 4 MR. REINHART: Objection to form, lack of 4 membership is made up of billionaires? 8 foundation. Instruct the witness not no answer. 5: MR. REINHART: Objection to form, lack of 6 THE WITNESS: At the instruction of my lawyer, 6 foundation. Instruct the witness not to answer. e t I must invoke my Fifth Amendment right. T THE WITNESS: At the instruction of my lawyer, § 8 BY MS. EZELL: 8 I must invoke my Fifth Amendment right. 9 Q. Were you aware that Mr. Epstein gave A.D. a 3 BY MS. BZELL: 10 digital camera and encouraged her in her pursuit of 10 Q. Did you attend a function of the Edge Group in il photography? il February of 1902 -- i'm sorry, 2002? i 12 MR. REINHART: Same objection stated to the 12 MR. REINHART: Object to form, there is a lack 13 previous question and same instruction. 13 of foundation. Instruct the witness not to answer. id THE WITNESS: At the instruction of my lawyer, | 14 THE WITNESS: At the instruction of my lawyer, is I must invoke my Fifth Amendment right. 15 1 must invoke my Fifth Amendment right. i 16 BY MS. EZELL: 16 BY MS. EZELL: 17 Q. Have you ever met a young woman named M.D.? | 17 Q. Have you attended several fisnctions since 2002 18 A. At the instruction of my lawyer, I must invoke 18 of the Edge Group? i 19 my Fifth Amendment right. 19 MR. REINHART: Objection to the form, because |} 20 Q. Were you ever aware that Mr. Epstein gave M.D. | 20 there is no foundation for her having any knowledge 21 _ aregular camera and encouraged her in her pursuit of 21 of an entity called the Edge Group, so I'll 22 photography? 22 instruct her not to answer. 23 MR. REINHART: Objection to form, assumes 23 THE WITNESS: At the instruction of my fawyer, ¢ (561) 832-7500 Electronically signed by Rachel Bridge (201-272-617-4627) certain facts, lack of foundation, compound. Instruct the wit PROSE COURT REPORTING AGENCY, Tmust invoke my Fifth Amendment right. Inc. (561) 832-7506 905011499-0cd8-4599-a2a0-6d38827b68C8

Page 421 Page 423 t i ; 1 BY MS. EZELL: 1 is a lack of foundation of her having any G 2 Q. Are you a member of the Edge Group or do you 2 interaction with anyone at any home owned by : 3 go as the guest of Mr, Epstein? 3 Mr. Epstein, whoever he may be. Instruct her not 4 MR. REINHART: Again, there is no foundation 4 to answer. 5 for the question because there is no, there is no 5 THE WITNESS: At the instruction of my lawyer, 6 connection of her to this organization, and Fd 6 i must invoke my Fifth Amendment right, F 7 instruct her not to answer. Form objection. 7 BY MS. EZELL: i 8 THE WITNESS: At the instruction of my lawyer, 8 Q. Were you the one who routinely would get out 9 1 must invoke my Fifth Amendment right. 9 the lotion, towels, and massage equipment once you 10 BY MS. EZELL: 10 arrived at the massage room with the girl? 11 Q. Do you know Ghislaine Maxwell's e-mail iL MR. REINHART: Same objection to the form, 12 address? 12 same objection stated to the previous question. 13 MR. REINHART: Instruct the witness not to 13 It's been asked and answered as well. 14 answer, objection to form, lack of foundation as to 14 THE WITNESS: At the instruction of my lawyer, 15 her knowledge of anyone named Ghislaine Maxwell. | 15 I must invoke my Fifth Amendment right, 16 THE WITNESS: At the instruction of my fawyer,| 16 BY MS. EZELL: 17 [ mast invoke my Fifth Amendment right. 17 Q. Does Mr. Epstein particularly like any 18 BY MS. EZELL: 18 particular massage oils? 19 Q. Do you know a Nicole Hesse or Hesse, 19 MR. REINHART: Objection to the form, standard ¢ 20 H-e-s-s-e? 20 objection, no foundation as to her knowledge of 22 A, At the instruction of my lawyer, I must invoke 21 anything relating to Jeffrey Epstein. Instruct her 22 my Fifth Amendment right. 22 not to answer. 23 Q. Did you participate in a sort of routine 23 THE WITNESS: At the instruction of my lawyer, |] 24 involving young women who would come to the house, | 24 T must invoke my Fifth Amendment right. 25 Mr. Epstein's house on El Brillo Way to provide 25 Page 422 Page 424 ‘ 1 massages? 1 BY MS. EZELL: Ho 2 MR. REINHART: That's been asked and answered | = 2 Q. Was it your general practice to leave the girl 3 several times, object to the form, lack of 3 alone either just before or when Mr. Epstein would come 4 foundation as to any knowledge relating to Epstein 4 into the room? S or El Brillo Way. Instruct her not to answer. 5 MR. REINHART: Objection to the form, again 6 THE WITNESS: At the instruction of my lawyer, 6 assuming multiple facts and the same question, none 7 I must invoke my Fifth Amendment right. i of which have any foundation. Instruct her not to 8 BY MS. EZELL: 8 answer, 9 Q. Was it routine practice for you to come and 9 ‘THE WITNESS: At the instruction of my lawyer, {| 10 meet the girl after she arrived at El Brillo Way to 10 { must invoke my Fifth Amendment right. 11 provide a massage for the sexual gratification of il BY MS. EZELL: | 12 Mr. Epstein? 12 Q. Who paid the girls who came to El Brillo Way f 13 MR. REINHART: Objection to form, it's 13 to provide massages and other sexual favors for i 14 compound. There is a lack of foundation. Instruct 14 Mr. Epstein? 1s the witness not to answer. It's been asked and 15 MR. REINHART: Same objection as to form as 16 answered several times, 16 previously stated to the last three or four : 17 THE WITNESS: At the instruction of my lawyer, | 17 questions, Same instruction to the witness. Pp 18 I must invoke my Fifth Amendment right. 18 THE WITNESS: At the instruction of my lawyer, | 19 BY MS. EZELL: 19 T must invoke my Fifth Amendment right. 20 Q. Was it your practice to then lead the young 20 BY MS. EZELL: 21 woman who had come to give Mr. Epstein a massage up aj 21. Q. Who was responsible for keeping the supply of 22 stairway that is behind a door in the kitchen of the 22 cash in the house from which the girls were paid? 23 home on El Brille Way? 23 MR. REINHART: Same objection as to form and ! 24 MR. REINHART; Objection to the form, it's 24 lack of foundation. Instruct the witness not to 2 Se answer, i (561) Electronically signed by Rachel Bridge (201-272-617-4627) compound, assuming many facts. ets not, and there 832-7500 PROSE COURT REPORTING AGENCY, 15 (Pages 421 ‘to 124) INC. (561) 832-7506 905d1499-0cd8-4699-a2a0-Scd38827b68C6

Page 425 Page 427 xy THE WITNESS: At the instruction of my lawyer, 1 MR. REINHART: Objection to the form, lack of } 2 I must invoke my Fifth Amendment right. 2 foundation. Instruct the witness not to answer. a 3 BY MS. EZELL: 3 THE WITNESS: At the instruction of my lawyer, f: 4 Q. Was it your practice or habit to get the 4 I must invoke my Fifth Amendment right. F S telephone numbers and contact information of each girl 3 BY MS. EZELL: 6 before she left El Briilo Way? 6 Q. Did you ever text with Jane No. 103 about her 7 MR.REINHART: Same objection as to form as 7 coming to Mr. Epstein's house? 8 stated to the last series of questions. Same 8 MR. REINHART: Same instruction, same 9 instruction. 9 objection, 10 THE WITNESS: At the instruction of my lawyer, ; 10 THE WITNESS: At the instruction of my lawyer, il I must invoke my Fifth Amendment right. 11 I must invoke my Fifth Amendment right. Ee 12 BY MS. BZELL: 12 BY MS. EZELL: 13 Q. Going back to that stairway that led from the 13 Q. Were you aware that Jeffrey Epstein was 14 kitchen up to the massage room, was there atime when | 14 helping Jane No. 103 with her college application? E 1s there were photos of nude girls all the way up that 1s MR. REINHART: Objection to the form, lack of 16 stairway? 16 foundation as to any knowledge as to Jeffrey E 1? MR. REINHART: Same objection as to form and} 17 Epstein, so therefore it's compound and ambiguous. 18 lack of foundation as to any basis to question this 18 Instruct you not to answer. FE 19 witness on anything having to do with a home owned; 19 THE WITNESS: At the instruction of my lawyer, F 20 by Mr. Epstein or any staircase or any pictures on 20 I must invoke my Fifth Amendment right. 21 a staircase. So instruct her not to answer. 21 BY MS. EZELL: 22 THE WITNESS: At the instruction of my lawyer, | 22 Q. Did you ever hear Mr. Epstein tell Jane No. 23 T must invoke my Fifth Amendment right. 23 103 that he would help her even with the financing of 24 BY MS. BZELL: 24 her college, of her education? 25 Q. Do you recall a time when all those 25 MR. REINHART: Same objection stated to the Page 426 Page 428, 1 photographs were removed? 1 previous question. Objection to form and lack of 2 MR. REINHART: Objection to the form, lack of 2 foundation. Instruct the witness not to answer. f 3 foundation, same objection as the previous series 3 THE WITNESS: At the instruction of my lawyer, B 4 of questions. Same instruction. 4 I must invoke my Fifth Amendment right. 5 THE WITNESS: At the instruction of my lawyer, 5 BY MS. EZELL: 6 I must invoke my Fifth Amendment right. 6 Q. Do you recall -- and I believe it's in 7 BY MS. EZELL: e ? Exhibit 4, if we could pull Exhibit 4, please. If 1 8 Q. Did you ever text girls about coming to 8 could just look at it for a moment, please. 9 provide massages for Jeffrey Epstein? 2 MR, REINHART: Certainly, 10 MR. REINHART: Objection as to form, lack of 10 MS. EZELL: Thanks. Oh, good, it's on the a2 foundation as to any knowledge of Jeffrey Epstein, 11 front. 12 Instruct her not to answer, 12 BY MS. EZELL: a3, THE WITNESS; At the instruction of my lawyer, {3 Q. The first page of Exhibit 4, I'd ask you to 14 E must invoke my Fifth Amendment right. 14 look at that. Do you recognize that handwriting? 15 BY MS. EZELL: 15 MR. REINHART: That was asked and answered 16 Q. Do you know how to text? 16 about six hours ago. She said no. Es 17 A. Yes. A? You can answer it again. 18 Q. And how long have you been texting? 18 THE WITNESS: No. 19 A. Twelve years. 19 BY MS. EZELL: 20 Q. Twelve years? That's great. You are way 20 Q. Were you aware that Mr. Epstein ordered roses al ahead of me. 1 still don't know how. 21 to be delivered to Jane No. 103 at the stage of her high 22 Do you know a young woman named Jene No. 1037} 22 school after a play? 23 A. At the advice of my counsel, I must invoke my 23 MR. REINHART: Objection to the form, lack of 24 Fifth Amendment right, 24 foundation, standing objection. 25 THE WITNESS: At the instruction of my lawyer, Q._Did you ever drive Jane No. 103 anywhere? (561) 832-7500 PROSE COURT REPORTING AGENCY, Electronically signed by Rache! Bridge (201-272-617-4627) 16 (Pages 425 to 428) {561} 832-7506 905d1499-0cd8-4599-a2a0-6d38827b68c6 INC.

Page 429 Page 431p 1 { must exercise my Fifth Amendment right. 1 MR. REINHART: Same instruction, same 4 2 BY MS. EZELL: 2 objection. Q 3 Q. Do you recali telling ~ no, sorry. 3 THE WITNESS: At the instruction of my lawyers 4 Did you and Jane No. 103 become friendly? 4 {must invoke my Fifth Amendment right. 5 MR. REINHART: Object to the form, lack of $ BY MS. BZELL: 6 foundation as to any relationship with Jane No. 103 6 Q. Did, did you give yourself Jane No 103 any 7 or knowledge of a person named Jane No. 103. 7 gifts? i 8 {nstruct the witness not to answer. 8 MR. REINHART: I'm sorry, can you rephrase? 9 THE WITNESS: At the instruction of my lawyer, 9 BY MS. EZELL: i 10 I must invoke my Fifth Amendment right. 10 Q. Did you yourself give Jane No 103 any gifts? 11 BY MS. EZELL; ii MR. REINHART: Objection to the form. } 12 Q. Do you remember that Jane No. 103 came to 12 Instruct the witness not to answer the question. i 13 Mr. Epstein's home on or about July 23rd, 2004? 13 THE WITNESS: At the instruction of my lawyer, |! 14 MR. REINHART: Object to the form, leading, as} 14 I must invoke my Fifth Amendment right, [ as well as previously stated objection to the last 15 BY MS. EZBLL: lH 16 question. 16 Q. Did you ever buy gifts for Jeffrey Epstein to E 17 BY MS. EZELL: 17 give to Jane No 103? E 18 Q. And do you remember ~ 18 MR, REINHART: Objection to form. L 19 MR. REINHART; Hold on. 19 THE WITNESS: At the instruction of my lawyer, b 20 MS. EZELL: Sorry. 20 T must invoke my Fifth Amendment right. i 21 ‘THE WITNESS: At the instruction of my lawyer,| 21 BY M8, EZELL: : 22 I wish to invoke my Fifth Amendment right. 22 Q. Did you ever receive massages at the El Brillo 23 BY MS. EZELL: 23 Way house? 24 Q. Do you remember that Jane No. 103 continued to} 24 MR. REINHART: Objection to form, lack of 25 come to Mr. Epstein's house and indeed came over 100 | 25 foundation. Same instruction. Page 430 Page 4325 1 times over about a year and a half? 1 THE WITNESS: At the instruction of my lawyer, 2 MR. REINHART: Object to the form for reasons 2 I mast invoke my Fifth Amendment right, be 3 previously stated in the last several questions. 3 BY MS. EZELL: E 4 Instruct her not to answer. 4 -Q. Did you receive massages given by Johanna i 5 THE WITNESS: At the instruction of my lawyer, $ Sjoberg? i 6 I must invoke my Fifth Amendment right. 6 MR. REINHART: Objection to the form, lack of {| 7 BY MS. EZELL: £ foundation as to any knowledge of a person named i 8 Q. Do you remember calling to tell Jane No. 103 8 Johanna Sjoberg. Lack of knowledge as to any, lack 9 that Mr. Epstein would be coming in town and would like; 9 of foundation as to any connection to El Brillo 10 to see her? 10 Way. Instruct the witness not to answer. il MR. REINHART: Objection to form, instruct the | 11 THE WITNESS: At the instruction of my lawyer, 12 witness not to answer. 12 I must invoke my Fifth Amendment right. i 13 THE WITNESS: At the instruction of my lawyer, | 13 BY MS. EZELL: if 14 I must invoke my Fifth Amendment right. 14 Q. Did you go to an Edge Science dinner on i 15 BY MS. EZELL: is February 27, 2003, in Monterey, California? 16 Q. Did you overhear Mr. Epstein himself call Jane 16 MR, REINHART: It's been asked and answered, 17 ‘No. 103 at her home? 17 objection to form. li 18 MR. REINHART: Objection to the form, lack of 18 MS. EZELL: No, I didn’t ask about Monterey, LE 19 foundation as to any knowledge of Jeffrey Epstein. 19 California, Hi 20 Instruct her not to answer. 20 MR. REINHART: You asked about any Edge Group E 21 ‘THE WITNESS: At the instruction of my lawyer, | 21 meetings in California, and she said she has no [ 22 I must invoke my Fifth Amendment right. 22 idea what the Edge Group is. 23 BY MS. EZELL: 23 MR. GARCIA: I thought she took the Fifth on 24 Q. Did you and Jane No. 103 ever go shopping 24 that. l 25 together? 25 MR. REINHART: I thought she said she didn't 17 {Pages 429 to 432) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachet Bridge (201-272-617-4627) 905d1499-0cd8-4699-a2a0-6d38827b68C6

Page 433 Page 435 k 1 know what the Edge Group was, but whatever, you can 1 BY MS. EZELL: 2 answer the question. 2 Q. Do you want to respond? I didn’t give you 3 THE WITNESS: At the instruction of my lawyer, 3 time. 4 I must choose to invoke my Fifth Amendment right. 4 MR. REINHART: I've instructed her not to 5 BY MS. EZELL: D: answer the question. Let's move on. é Q. Do you know Max Brockman? 6 BY MS. EZELL: Tt MR. REINHART: I'm sorry, can you repeat? 7 Q. Do you recall a dinner at El Brillo Way & BY MS. EZELL: 8 attended by David Copperfield where Jane No. 103 was a}j 9 Q. Do you know a Max Brockman? 9 guest? | 10 MR. REINHART: { believe that was asked and 10 MR. REINHART: Objection to the form, lack of a1 answered already, but -- 11 foundation, and a standing objection as to her 12 THE WITNESS: At the instruction of my lawyer, 12 knowledge of anything involving El Brillo Way or 13 I must invoke my Fifth Amendment right. 13 Jeffrey Epstein. Instruct her not to answer. 14 BY MS. EZELL: 14 THE WITNESS: At the instruction of my lawyer, 15 Q. Have you ever been photographed with Max 15 I must invoke my Fifth Amendment right. 16 Brockman at an Edge Science dinner? 16 BY MS. EZELL: 17 A. Atthe instruction of my lawyer, I must invoke 17 Q. What is the relationship between Jeffrey 18 my Fifth Amendment right. 18 Epstein and David Copperfield? 19 MR. REINHART: You should let me ~ { need to 19 MR, REINHART: Objection to form, lack of 20 object to the form of the question first, but go 20 foundation as to her knowledge of either one of 21 ahead. I know we all want to get out of here. Go 21 those people. instruct her not to answer, 22 ahead, 22 THE WITNESS: At the instruction of my lawyer, 23 THE WITNESS: Say it again. 23 I must invoke my Fifth Amendment right, 24 MR. REINHART: No, you are okay. Go ahead, 24 BY MS. EZELL: 25 Ms. Ezell. Thank you, 25 Q. To your knowledge, do they recruit girls for E Page 434 Page 4366 1 BY MS. BZELL: 1 one another? i 2 Q. Do you know whether Jeffrey Epstein attended 2 MR. REINHART: Object to the form, compound, 3 the Edge Science dinner in Monterey, California? 3 and again, lack of foundation. Instruct her not to 4 MR. REINHART: Objection to the form, lack of 4 answer. . E 5 foundation. Instruct the witness not to answer. 5 THE WITNESS: At the instruction of my lawyer, f 6 THE WITNESS: At the instruction of my lawyer, 6 imust invoke my Fifth Amendment right. : ea I must invoke my Fifth Amendment right. 7 BY MS. EZELL: 8 BY MS. EZELL: 8 Q. To your knowledge, are they involved in any 3 Q. You testified a moment ago that you were 9 sexual trafficking of young women? 10 photographed nude by your boyfriend or a former 10 MR. REINHART: Object to the form for the 11 boyfriend and that you hoped there are no photographs {| 11 reasons previously stated. Also calis fora legal 12 disseminated elsewhere. 12 conclusion as to what sexual trafficking is. 13 At what age were those photographs taken? 13 Instruct her not to answer. i 14 MR. REINHART: I'm going to instruct her not 14 THE WITNESS: At the instruction of my lawyer, 15 to answer that. It has nothing to do with 15 I must invoke my Fifth Amendment right. 16 anything. It's not reasonably calculated to lead 16 BY MS. BZELL: 17 to discoverable evidence. We can move on. 17 Q. [believe you asked about Allen Dershowitz 18 BY MS. EZELL: 18 earlier. 19 Q. Were you in any way damaged by that 19 MR. REINHART: Twice. 20 experience? 20 BY MS. EZELL: 241 MR. REINHART: Same instruction. Let's move | 21 Q. And were instructed not to answer. 22 on. 22 MR. REINHART: Twice. 23 BY MS. EZELL: 23 BY MS. BZELL: 24 Q. Do you have any regrets? 24 Q. Allright, I'm going to ask again on behalf 25 MR. REINHART: Same instruction. Move on. 25 of my client. Are you aware of the friendship between (S61) 832-7500 Electronically signed by Rachel Bridge (201-272-617-4627) PROSE COURT REPORTING AGENCY, 18 (Pages 433 to 436) INC. (561) 832-7506 905c11499-Ocd8-4599-a2a0-Gd38827b6868

- ale Page 437 Page 439 1 Allen Dershowitz and Jeffrey Epstein? 1 BY MS, EZELL: 2 MR. REINHART: And for the third time, (‘If 2 Q. Do you know that when David Copperfield is in 3 object to the form and instruct her not to answer 3 town, he gives Jeffrey Epstein tickets and Jeffrey gives 4 the question, 4 some to young women to attend those shows? 5 THE WITNESS: For the third time, | take the 5 MR. REINHART: Object to the form, multiple, 6 advice of my lawyer and invoke my Fifth Amendment 6 compound question, and a complete lack of 7 tight, 7 foundation. Instruct the witness not to answer. 8 BY MS. BZELL: 8 THE WITNESS: At the instruction of my lawyer, 9 Q. When Allen Dershowitz comes to Palm Beach, he 9 I must invoke my Fifth Amendment right. 10 stays at the El Britlo mansion, doesn't he? 10 BY MS. EZELL: 11 MR. REINHART: Objection to the form. There a Q. And do you know that those girls are invited 12 ts no foundation for her having any knowledge of 12 back stage after the show? 13 anything having to do with a person by the name of 13 MR. REINHART: Same objection, complete lack 14 Allen Dershowitz. I instruct her not to answer. 14 of foundation, and standing objection previously 15 THE WITNESS: At the instruction of my lawyer, 15 stated. 16 [ must invoke my Fifth Amendment right. 16 THE WITNESS: At the instruction of my lawyer, 7 BY MS. EZELL: a7 I must invoke my Fifth Amendment right. 18 Q. When Allen Dershowitz, or has Allen Dershowitz | 18 BY MS. EZELL: 19 ever been there when young ladies came to give massages?} 19 Q. Do you remember on or about, in or about March 20 MR. REINHART: Same objection stated to the 20 of 2005 having conversations with one of the young women; ai previous question. Same instruction. 21 who came to the house to give massages about her 22. THE WITNESS: At the instruction of my lawyer, 22 conversations with Jane No. 1037 23 I must invoke my Fifth Amendment right. 23 MR. REINHART: Objection to the form, standing 24 BY MS. EZELL: 24 objection, lack of foundation. Instruct the 25 Q. Has Ailen Dershowitz ever been the beneficiary 25 witness not to answer, because the question implies Page 438 Page 440 1 of those massages? 1 that she has any knowledge at all of El Brillo Way. 2 MR. REINHART: Same objection and same 2 BY MS. EZELL: 3 instruction. 3 Q. Same question -- sorry. 4 THE WITNESS: At the instruction of my lawyer, 4 A. At the instruction of my lawyer, I must choose 8 { must invoke my Fifth Amendment right. 5 to invoke my Fifth Amendment privilege. 6 BY MS. BZELL: 6 Q. Same question as to March of 2006. 7: Q. Do you know John Casablanca? 7 MR. REINHART: Same objection and same 8 A. Never heard that name before. 8 instruction. g Q. Have you ever heard of 2 world-famous 3 THE WITNESS; At the insiruction of my lawyer, 10 illusionist whose stage name is David Copperficid? 10 I must choose to invoke my Fifth Amendment 11 MR. REINHART: That's also been asked at least | 12 privilege. 12 three times, TH instruct her again not to answer 12 BY MS. EZELL: 13 the question. 13 Q. Do you have any recollection of a conversation 14 THE WITNESS: At the instruction of my lawyer, } 14 in which one of the young women told Jane No. 103 that 15 1 must invoke my Fifth Amendment right. is those girls who, those girls who would help Jeffrey in 16 BY MS. EZELL: 16 regard to the investigation would be compensated and 17 Q. Have you ever gone to one of David 17 those who would not or who would hurt him in the 18 Copperfield's shows? 18 investigation would be dealt with? 19 MR. REINHART: Objection to form, lack of 19 MR. REINHART: Objection to the form, lack of 20 foundation as to knowledge of any person by the 20 foundation, compound question. Instruct the 21 name of David Copperfield. Instruct her not to 21 witness not to answer, because the question implies 22 answer. 22 some knowledge of anything relating to a person by 23 THE WITNESS: At the instruction of my lawyer, | 23 the name of Jeffrey Epstein. : 24 I must invoke my Fifth Amendment right. 24 THE WITNESS: At the instruction of my lawyer, 25: 2a; I must invoke my Fifth Amendment right, (561) 832-7500 Electronically signed by Rachel Bridge (201-272-617-4627) PROSE COURT REPORTING AGENCY, 19 (Pages 437 to 440) Inc. (561) 832-7506 905d1499-Ocd8-4599-a2a0-6d38827b68c6

Page 441 Page 443 1 BY MS. EZELL: 1 BY MS. EZELL: 2 Q. Do you know John Brockman? 2 Q. Did you escort those underage girls to the 3 A. At the instruction of my lawyer, | must invoke 3 massage room where the defendant would enter and urge f 4 my Fifth Amendment right. 4 the girls to remove their clothes? 5 Q. Do you know of someone named Brockman being} 5 MR. REINHART: Objection to the form, asks a 6 the editor and publisher of a publication of the Edge 6 compound question, several questions within one. 7 Foundation? 7 Also assumes knowledge of a person by the name 8 MR. REINHART: Object to the form. There is 8 of Jeffrey Epstein and a massage room, so there is h 9 no foundation that she has any knowledge of any 3 no foundation. Instruct the witness not to answer, 10 entity by the name of the Edge Foundation, and I 10 THE WITNESS: At the instruction of my lawyer, 11 would instruct her not to answer the question based iL J must invoke my Fifth Amendment right. 12 on her Fifth Amendment privilege. 12 BY MS. EZELL: 13 THE WITNESS: At the instruction of my lawyer, | 13 Q. Did you ever tel! the girls to remove their 14 U must invoke my Fifth Amendment right. 14 clothes? i as BY MS, EZELL: 15 MR. REINHART: Same objection and the same § 16 Q. Did you participate in a scheme by Jeffrey 16 instruction. i i7 Epstein to recruit undetage girls to come to his 17 THE WITNESS: At the instruction of my lawyer, # 18 residence to provide massages? 18 1 must invoke my Fifth Amendment right. 19 MR. REINHART: Objection to the form, calls 19 BY MS. EZELL: 20 for a legal conclusion. Also has no foundation as 20 Q. And did you sometimes deliver cash from the 21 to any knowledge of a person by the name of Jeffrey al defendant to the underage girls after they performed the | 22 Epstein, and because it calls for a legal 22 massage? 23 conclusion, I'll simply instruct her not to answer 23 MR. REINHART: That's been asked at least 24 the question at ali, Move on. 24 three or four other times. 25 25 MS. BZELL: I'm asking on behalf of my client. Page 442 Page 444 1 BY MS. EZELL: 2 1 MR. REINHART: I understand, but we've been. 2 Q. Did you assist, support, and facilitate 2 here for over an hour, and we can't just keep going 3 Jeffrey Epstein's child exploitation enterprise? 3 over. [fthey have been asked in the deposition, 4 MR. REINHART: Once again, objection the 4 your clients can have the benefit of the answer, 5 question, calls for a legal conclusion as to what 5 but we've been here now for almost eight hours and 6 is an enterprise, which is a term of art in the 6 you still -7 criminal law about which this witness has no 7 THE WITNESS: At the instruction of my lawyer, F 8 knowledge, and it’s a legal conclusion not likely 3 I must invoke my Fifth Amendment right. 9 to ead to discoverable evidence. So I would 9 BY MS. EZELL: i 10 instruct her not to answer the question at all. 10 Q. Did you ever take part in delivering cash from fi 211i BY MS. EZELL: 11 the defendant to the procurers of the underage girls who. 12 Q. Did you arrange times for underage girls to 12 came for the massage appointments? 13 come to Jeffrey Epstein's residence? 13 MR. REINHART: Objection to the form. The 14 MR. REINHART: Objection to form, standing 14 term procure is a legal term of art, and I'll 15 objection previously stated. 15 instruct the witness not to respond to the question 16 THE WITNESS: At the instruction of my lawyer, | 16 at all. 17 I must invoke my Fifth Amendment privilege. 17 BY MS. EZELL: 18 BY MS. EZELL: 18 Q. Did you, did you by using the telephone assist 19 Q. Did you arrange, transport, or yourself’ 19 Jeffrey Epstein in enabling himself to commit sexual 20 transport underage girls to or from Jeffrey Epstein's 20 battery on, and acts of lewdness in the presence of rat residence? 21 young women? i 22 MR. REINHART: Same objection, same 22 MR. REINHART: Same as the previous i 23 instruction as the last question, 22 instruction. Instruct the witness not to answer : 24 THE WITNESS: At the instruction of my lawyer, | 24 the question at ali, because it results in a legal iF 25 I must invoke my Fifth Amendment privilege. 25 question, not a factual question, so it's not 20 (Pages 441 to 444) (S61) 832-7506 905d1499-Ocd8-4599-a2a0-6d38627b58c5 (561) 832-7500 PROSE COURT REPORTING AGENCY, Electronically signed by Rachel Bridge (201-272-617-4827) INC.

Page 445 Page 447 fy 1 reasonably designed to lead to discoverable 1 deposition or you may waive reading and allow the z evidence. 2 court reporter to simply type it up and distribute 3 BY MS. EZELL: 3 it to the lawyers who order it. 4 Q, Did you facilitate these acts as well as 4 Do you choose to read or waive? 5 assisting Mr. Epstein in avoiding police detection? 3 THE WITNESS: Waive, 6 MR. REINHART: Same instruction. 6 MS. EZELL: Thank you. 7 BY MS. EZELL: 7 MR. REINHART: Thank you. 8 Q. Do you know when and by whom the computers 8 THE VIDEOGRAPHER: Okay, this concludes ff i) were removed from the El Brillo mansion? 9 today's videotape deposition of Sarah Kellen. The |; 10 MR, REINHART: Objection to the form, lack of | 10 time is 18:51. 1 foundation, and it also assumes knowledge of a 12 (Witness excused.) 12 place known as the El Brillo mansion. So instruct 12 (Deposition was concluded.) 13 the witness not to answer the question based on the 13 14 Fifth Amendment. 14 15 THE WITNESS: At the instruction of my lawyer, ; 15 16 I must invoke my Fifth Amendment right. 16 17 BY MS. EZELL: 17 18 Q. Was Jane No. 103 invited to just come and hang | 18 19 out at the El Brilio mansion? 19 20 MR. REINHART: Objection to the form, same as} 20 Zi. the previous question. It assumes knowledge of a ai 22 place known as the Ei Brilto mansion and a person 22 23 by the name of Jane No. 103. It is compound and 23 24 lacking in foundation. 24 25 THE WITNESS: at the instruction of my lawyer, | 25 Page 446 Page 448 1 I must invoke my Fifth Amendment right. 3 ae samo . as re TE 2 ‘BY MS. EZELL: 3 COUNTY OF PALM BEACH 3 Q. Have you called any girls under the age of 18 s Riad Wi eles Hagiaved alee 4 in Palm Beach or West Palm Beach in the last six years? 2 i ee 5 MR. REINHART: For any purpose? 6 Publi van] ior the Sure of Flntiotlnge do? 6 MS. BZELL: Yes. hereby certify that I was authorized to and did report 7 ‘THE WITNESS: Can you repeat the question? ToS ette td eae 8 BY MS. EZELL: 8 shorthand notes of said deposition. 9 ; Q. Have you called any gitls under the age of 18 2 hie tis wal ak eres oh ‘ad 10 in Palm Beach or West Palm Beach in the last six years?} 19 that the taking of said deposition was commenced and il MR. REINHART: You can answer that yes or no, completed as hereinabove set out, ie if you know. cs L further certify that {am not attomey or 13 THE WITNESS: I don't think so. 12 counsel of any of the parties, nor am I a relative or 14 MS. EZELL: I don't have any other questions. 43 See san atan cle or party come is Thank you. action. oa SHE VIDEOGRAPHER: All st? zs The foregoing certification of this transcript 17 MR. REINHART: Yes. 15 does ene pe reproduction of the same by any 18 THE VIDEOGRAPHER: This concludes today's means unless under the direct control and/or direction 19 videotape deposition of Sarah Kellen. 28 of tie Dante oda of April, 24 x 20 MR. REINHART: Hold on, I'm sorry, one last 18 21 thing. Since you're the last defense person or 13 22 plaintiff's lawyer standing, I guess you need to 2 23 advise her she has the right to read or waive on 22 24 the record. 2a 25 MS. EZELL: You do have the right to read this 2s ca oT SEES TIT 21 (Pages 445 a6 448) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) 905d1499-0cd8-4509-a2a0-6d38827b68¢6

DEFENDANT BRADLEY J. EDWARDS’S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 13

DEPO. EPSTEIN IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.:50 2008 CA020614XxxxMBAF JANE DOE, II Plaintiff, vs. JEFFREY EPSTEIN, and SARAH KELLEN Defendant. i DEPOSITION OF THE WITNESS JEFFREY EPSTEIN TAKEN BY THE Plaintiff ON May 7, 2009 APPEARANCES : ON BEHALF OF THE PLAINTIFF GARCIA LAW FIRM 224 Datura Street, St. 900 West Palm Beach, FL 33401 BY: ISIDRO M. GARCIA TARA A. FINNIGAN, P.A. 224 Datura Street, Suite 990 west Palm Beach, FL 33401 ON BEHALF OF THE DEFENDANT ATTERBURY GOLDBERGER & WEISS, P.A. 250 Australian Ave, South West Palm Beach, FL 33401 BY: JACK A, GOLDBERGER, ESQ, BURMAN, CRITTON, et al. 515 North Flagler Dr., St. 400 west Palm Beach, FL 33401 BY: J. MICHAEL BURMAN INDEX WITNESS EXAMINATION PAGE Page 1

DEPO. EPSTEIN JEFFREY EPSTEIN Direct by Mr. Garcia 4 QUESTIONS MARKED FOR CERTIFICATION , (identified with an asterisk on the following pages.) PAGE NO. LINE NO. 46 20 49 21 50 13 54 1 56 11, 20, 25 57 69 22 77 17 Deposition of JEFFREY EPSTEIN, a witness herein, taken on behalf of the Plaintiff herein, for the purpose of discovery and for use as evidence in the above-entitled cause, before JULIE ANDOLPHO, Court Reporter and Notary Public in and for the State of Florida at Large, at 250 Australian Avenue, West Palm Beach, State of Florida, on May 7, 2009, commencing at or about 10:00 a.m.. whereupon: i ; _JEFFREY EPSTEIN, . a witness herein bei ng of lawful age, and being first duly sworn in the above cause, testified on his cath as follows: Page 2

DEPO. EPSTEIN DIRECT EXAMINATION BY MR. GARCIA: Please state your full name. jeffrey Edward Epstein. Where do you live, Sir? united states virgin Islands. what is your home address? I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rPOPOPO provided any questions relevant to this lawsuit. I must accept this advise 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 of the United States Constitution. Q Does that mean you are not going to answer my question about your home address? MR. GOLDBERGER: He just answered it, Sid. MR. GARCIA: To all questions -~ I mean MR. GOLDBERGER: -- let's go off the record a second. MR. GARCIA: Let's put it on the record -we can go off, I guess. Go ahead. (whereupon there is a discussion off the record.) f BY MR. GARCIA: (CONT'D) Q Do you have a home that you own in Palm Beach, the Town of Palm Beach? A As T have said in my previous questions and I will repeat it. 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 rejevant to this lawsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert federal constitutional rights as guaranteed by the Sth, 6th and 14th amendment of the united states constitution. MR. GOLDBERGER: Can we go off the record one second? MR. GARCIA: Let me ask on the record. Can we have a stipulation that his answer would be the same to each question I pose? MR. GOLDBERGER: It's okay that the question be asked, but rather than you read that. THE WITNESS: I'll read it. MR. GOLDBERGER: All right. we'll read it to you. Q Do you know Dainya Nida? A AS I've said in response to all questions asked of me so far, I intend to respond to al? 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 advise or risk losing my 6th amendment right to effective Page 3

OV@NTuMAWNE ay DEPO. EPSTEIN representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the United states + Constitution. Q who is Sarah Kellen? A AS I've said in response to all questions previously asked of me, 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 advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the united States Constitution. Q Did you ever -- strike that. Did Dainya Nida ever come to your house in the Town of Palm Beach for any reason? A As I've said previously to questions asked of me, 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 advise 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 of the United States Constitution. Q when Dainya Nida came to your house, did she ever -- did you ever ask her to engage in sexual acts with you? F A Can you repeat the question? . Q Yes, Did you ever, when Dainya Nida came to your house, did you ever ask her to engage in any sexual acts with you? A As I've said in response to your other questions I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me 1 cannot rovide answers to any questions relevant to this awsuit. = must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, ZI assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the united States Constitution. Q Mr. Epstein, I note for the record you're reading from a script, are you reading from a script? A As T've said in response to all questions asked of me, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the united States Constitution. MR. GARCIA: All right. well, for the Page 4

DEPO. EPSTEIN record, since he is reading from the script I'm entitled to have a copy of what he's readin from and make it a deposition exhibit so I' like to make that document, at some point, exhibit 1. I see handwriting on it also, I don't know if you claim that to be an attorney client communication, I just want a copy of the script he's reading From. MR. GOLDBERGER: The whole document is attorney client privilege and we're not giving it to you. If you want to file a motion, we'll have a hearing on it. MR. GARCIA: I will. DIRECT BY MR. GARCIA: (CONT'D) Q what is your present age? A 56. Q what is your date of birth? A January 20, 1953. Q Did you know the age of Dainya_ Nida when she came to your house in the Town of Palm Beach? A can you repeat the question? Q Did you know the age of Dainya Nida when she came to your house in the Town of Palm Beach? A As I've said in response to your other questions, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. accordingly, It assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Q Did you ever pay Daiyna Nida any money for any services that she rendered to you? A AS I've said in response to your other questions, 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 Jawsuit. I must accept this advise 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 of the United states Constitution. g In the answer in affirmative defenses that were filed on your behalf in the case of Jane Doe, It_vs. Jeffrey Epstein and Sarah Kellen, case number 502008CA20614xXxxXMBAB pending before Judge Hafele you claim as your second affirmative defense the Following, quote, "As to all counts alleged, plaintiff consented to and participated in conduct similar and/or identical to the acts alleged with other persons which was the sole and contributing cause of plaintiff's alleged damages." what evidence if any do you have plaintiff consented to or participated in conduct similar and/or identical to the acts alleged with other persons and who are the other persons? A Can you repeat that question? MR. GARCIA: Before you read it back, let Page 5

DEPG. EPSTEIN me put this on the record, that question can in no way invoke a 5th or 6th amendment privilege because it’s not asking about his contact it’s asking about what evidence he has that she engaged in acts with other persons of a similar nature. MR. GOLDBERGER: It could lead to incriminating evidence and, therefore, the question, once it's read back, I anticipate the question not being answered. MR. GARCIA: why would it lead -MR. GOLDBERGER: ~~ T'm not going to engage in that, I'm telling you I have a good faith basis invoking the 5th amendment. MR. GARCIA: Untess he alleged that he participated with the third persons. Anyway, read it back to him. (whereupon the Tast question is read back.) A AS I've said in response to your other questions, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Q where were you born? A Excuse me, I didn't finish. Q I'm sorry. A Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the United States constitution. where were you born? In New York. What part? Brooklyn. what neighborhood in Brooklyn? I don't understand the question. Canarsie, Bay Shore? where was I born? Yeah. Where did you grow up in Brooklyn, did you grow up in Brooklyn? A Yes. Q what part of Brookim did you grow up in -- Jet_me ask you this, what high school did you attend? A Lafayette. And where did you live through -- in high school, was there a particular neighborhood name? A As I've said in response to all questions asked of me so far, I intend to respond to all relevant questions regarding this lawsuit, however ro DPrOSrO ra Q ~-- let me withdraw that question. Did you attend college? A Yes. Q where did you attend college? A AS I've said in response to your other questions, I intend to respond to all relevant questions regarding this lawsuit, however, at the Page 6

DEPO. EPSTEIN present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th amendment of the united States Constitution. MR. GOLDBERGER: Go off the record a second. (Discussion off the record.) DIRECT BY MR. GARCIA: (CONT'D) Q Let me ask this, did you graduate from college? A No. 9 All right. Can you tell me what years you attended college, if you did attend? A As I've said in response to your other questions, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. All right, accordingly --- I'm sorry. : Should I ge back to the beginning? You paused, I thought you were done. I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. POPOPrS Q Did you graduate from Lafayette High school? A Yes. ; Q and what year did you graduate? A : Q Were you in the military service at any point? A No. Q As to the third affirmative defense raised in the answer to affirmative defenses to this pars cular case you allege, or your lawyer on your ehalf alleges; quote, "As to all counts, defendant reasonably believed the plaintiff had attained the age of 18 years old at the time of the alleged — acts.“ End quote. what made you reasonably believe that the plaintiff had alleged 18 years of age at the time of the alleged acts? A As I’ve said in response to your other questions, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit, I must accept this advise 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 of the United States Constitution. what_states, besides the State of Florida, do you presently own a home in, if any? A As t've said in response to your other Page 7

DEPO. EPSTEIN questions, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the united states Constitution. Q Are you currently residing in the Palm Beach County Jail? A Yes. Q Are you scheduled to be released at some future date from the palm Beach County Jail? A Yes. . Q Do you know when that date is? A No. Q Are you on some sort of furlough or home release program, I don't know what it's called exactly, where you get to leave the Palm Beach county jail every morning and return at night? MR. GOLDBERGER: You have to rephrase the question. If you're asking if he's on house arrest the answer is no, Q rE don't know what it's called -MR. GOLDBERGER: -- ask him if he's on work release. Q Are you on work release? A Yes. what time do you Teave the Palm Beach County Jail each morning? 8 a.m. what time are you required to be back? A Q A 8 p.m. Q where do you work during these hours? AS I've said in response to your other questions, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, £ assert my federal constitutional rights aS guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. can we take a restroom break? Q sure. (whereupon a break is taken.) DIRECT BY MR. GARCIA: (CONT'D) Q Can you tell me what days you are participating in this work release program, whether wonday through Friday or is it every day of the wee! A Monday through Saturday. Q Do you have an office somewhere for your business that is separate from your home? A AS I've said in response to your other questions, I intend to respond to all relevant > questions regarding this lawsuit, however, at the present time my attorneys have counseled me IT cannot Page 8

DEPO. EPSTEIN rovide answers to any questions relevant to_this awsuit. I must accept this advise 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 of the United States Constitution. Q Have you ever been charged with a criminal offense? MR. GOLDBERGER: You can answer that. A yes. Q And where were you charged with a criminal offense? A Palm Beach. Q And was it a charge brought by the state or the federal prosecutor? State. Do you know what the charged crime was? Yes. what was it? soliciting prostitutes. Did you take a plea in that case? BPrPOoOrearoe> Yes. And what did you plead guilty to -- or did you plead guilty? : A I already answered that question. Q You did plead guilty? A Yes. Q Did you plead guilty to that specific crime? Yes. Q And what sentence -- was there a sentence that was agreed upon or was it imposed by the court without agreement? A It was agreed. Q And what was the sentence? A Twelve months in the county jail. Q Any other conditions? A No. Q And was work release part of the agreement? A No. Q You applied for work release after you started serving time in the county jail? A Yes, Sir. And was that agreed to by the state prosecutors office? A I don't know. Q Any other conditions besides 12 months in the county jail? MR. GOLDBERGER: As the question is phrased that was a sentence to the solicitation. Q I'm sorry? A That was the sentence to the solicitation of prostitution. Q And was it a single count or multiple counts? ‘ A Single. Q who was the alleged victim? A As I've said in response to your other questions, I intend to respond to all relevant Page 9

DEPO. EPSTEIN questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the United States Constitution. Q were you, if you know, were you indicted by a grand jury or was the charge direct filed by the state attorney? A Indicted by a grand jury. Q Did the grand jury, if you know, consider any other charges? A I don't know, Q Did you testify before the grand jury? MR, GOLDBERGER: Go ahead and answer that. A No. Q were you asked to testify -- let me ask this, were you offered the opportunity to testify? I don't know. . : when is the first time that you met Daiyna QP Nida? A AS I've said in response to your other guestions, I intend to respond to all relevant guestions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to_this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, 1 assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th amendment of the United states Constitution. Have you ever been charged in any other court of the United States or abroad for any crime? MR. GOLDBERGER: You have to rephrase the question. Other than solicitation for prostitution? MR. GARCIA: Other than this one case that he talked about in Palm Beach County. MR. GOLDBERGER: What one case are you talking about? MR. GARCIA: where he said the grand jury indicted him for solicitation of prostitution, A could you repeat the question? Q Have you ever been charged of a crime in any other court in the united States or abroad besides the charge that you discussed solicitation of prostitution? A I don't understand the question. what's a crime, is that a traffic ticket? Q No. A Is it since I'm 18? Q Yeah, since you're 18. MR. GOLDBERGER: Condense the question. If want to make sure he answers the question accurately so ask the question one more time and then we'll get an answer. Q Ever been charged with a misdemeanor or a felony jevel criminal offense in any court in the United States or abroad besides the one you've Page 10

WOMAV PWN ES DEPO. EPSTEIN already discussed? A Not that I remember. MR. GOLDBERGER: He's going to clarify that answer. A Another charge in Palm Beach. Q what was the other charge? A Procuring minors for prostitution. And what agency or what prosecutors office charged you with that crime? A State attorney. Q Did you plead guilty to that as well? A Yes. Q So did you plead guilty to two separate offenses? A yes. Q Is that with a single minor or multiple minors in terms of what you plead ui Tey to? A I intend to respond to all retevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to_this awsuit. I must accept this advise 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 of the United States Constitution. Q Are you a registered sex offender? A Yes. Q Was that part of the plea agreement that you made with the State Attorneys Office? MR. GOLDBERGER: If you know. A Yes. Q I had asked you before if there were any other conditions of your plea, you didn't mention that, is that -- is there anything else that you haven't mentioned that's part of your plea agreement? MR. GOLDBERGER: You_asked him what the conditions were of the solicitation of the prost/tution charge that he pled guilty to and @ answered that question. MR. GARCIA: I see. He hadn't revealed he pled guilty to a different charge which is procuring the minor for prostitution. MR. GOLDBERGER: You didn’t ask him that. DIRECT BY MR. GARCIA: (CONT'D) Q Are there any other conditions for either crime that you apparently pled guilty to in Palm Beach County, any other conditions besides the 12 months or whatever period of time you mentioned in the county jail and being a registered sex offender? ne A An additional six months in the county ail. d Q An additional six months? A yes, Q the total sentence is 18 months, yes? A That's 12 plus 6. Q Okay. And what else? A One year of community control. Q Community contro? in Palm Beach County or Page 11

0029 ORNAMAWNE DEPO. EPSTEIN somewhere else? A Community control. Q Are you allowed to leave the county during that one year? A I don’t know. ; q Have you made any. agreement with the United States Attorneys Office concerning a deferred prosecution or pretria! intervention-type of program? MR. GOLDBERGER: You know, I'm kind of -~Mike is feeling the same way I am -- I'm kind of giving you leeway to_ask some questions here that may be arguably relevant but we're getting into areas that are not relevant and it appears to me that you're just asking the questions to embarrass Mr. Epstein so I'm going to give you a little more leeway but at some point I'm joing to cut it off if you go too far. £'11 et him answer that. MR. GARCIA: I'm just asking about any agreements he made if he made an agreement. Have you made any agreements with the u.s. Attorneys Office to avoid being prosecuted for any federal offenses? MR. GOLDBERGER: The way that question was phrased, Sid -MR. GARCIA: -- let's go back to the previous question, there was no objection to it. Read that back. (whereupon the following question is read back: 3 Have you made any agreement with the United States Attorneys office concerning a deferred prosecution or pretrial intervention~type of program?” A Yes. Q And do you know what the agreement is? A Yes. Q what does the agreement cal? for? A The agreement states what it states. Q well, can you summarize it for me? A No. MR. BURMAN: Object to the form. Q Do you have an understanding of the agreement? MR. BURMAN: Object to the form. Q What is your understanding of the agreement? MR. BURMAN: Object to the form of the question. Q You can answer it. MR. GOLDBERGER: Can you give me a hint as to why you think that’s arguably relevant? MR. GARCIA: We may move to seek to enforce the agreement. We may add a count for just a third party beneficiary of that agreement for breach of contract claim. The possibilities are endless here. . MR. GOLDBERGER: That's fine, if you want to do that you can do that but Mr. Epstein's understanding of what the agreement is -legally you can do what you can ~~ Page 12

DEPO, EPSTEIN MR. GARCIA: ~~ he's a party of the agreement, his understanding of what the agreement is is crucial to whether or not there is a agreement and what the agreement and terms are. DIRECT BY MR. GARCIA: (CONT'D) Q Unless they instruct you not to answer, you have to answer the question and that question does not violate anybody's privilege against self-incrimination. MR. GOLDBERGER: Go ahead and answer. A Repeat the question. Q Sure. What is your understanding of the agreement made with the U.S. Attorneys Office? A That if I abide by al]_the terms and conditions of the agreement I will not be prosecuted. Q 61 right. Oid you sign that agreement? es, Q Did you have a opportuni ty to reflect on the terms of the agreement before you signed it? A Yes. Did you have advice of counsel before you signed it? A yes. Q All right. Was the agreement ever modi fied? A Yes. why was it modified, if you know? Q A (Nodding) . Q You don't know? You're shaking your head, but I don't know what that means. MR. GOLDBERGER: I think that would call for mr, Epstein to kind of reveal attorney client privilege so 1'11 advise him not to answer the question. MR. GARCIA: All right. Q who is Gerald Lefcourt, L-E-F-C-O-U-R-T? MR. GOLDBERGER: It would involve attorney client privilege. He's not answering that question, : MR. GARCIA: 1 just want to know who he TS. MR. GOLDBERGER: He's a lawyer, Q _ Did he represent you in these negotiations? THE WITNESS: How does he have a copy of that agreement? MR. GOLDBERGER: I don't know. MR. GARCIA: Is he not going to answer who Gerald Lefcourt is? MR. GOLDBERGER: Correct. Q who is Lilliann Sanchez? MR. GOLDBERGER: He's not going to answer any questions that would involve revealing attorney client privilege. THE WITNESS: can I have a second with you? MR. GARCIA: Just to save some time, © Page 13

0033 DEPO. EPSTEIN signed the nondisclosure agreement that's why I have this, if that's what his question is. MR. GOLDBERGER: what nondisclosure agreement? MR. GARCIA: Apparently there is something the U.S. Attorney requires before turning over this document, you have to sign some sort of agreement not to disclose, if that’s his concern. MR, GOLDBERGER: It is of concern so let me clarify this. You signed some sort of nondisclosure agreement with the U.S. Attorney? MR. GARCIA: Yes. MR. GOLDBERGER: What U.S. Attorney? MR. GARCIA: whoever is handling this case. MR. GOLDBERGER: who would that be? MR. GARCIA: I believe it's -- she's the one who signed the agreement. There is some sort of protective order, if I understand, that was entered by Judge Mara requiring any party who is given this agreement to sign the agreement not to disclose it to anyone, marie Veafona (phonetic). MR. GOLDBERGER: So you contacted Ms. veafona and she had you sign a nondisclosure agreement? MR. GARCIA: That's why I don't want to make it an exhibit to this deposition because I don't want the court reporter to see it. I want to show it to the witness so he can identify it for me -MR. GOLDBERGER: -- let me see what you're going to show him? (Handing) MR. GARCIA: Its got the addendum, too. MR. GOLDBERGER: So what's your question? MR. GARCIA: My question is did he sign the original agreement, did he sign the addendum to it and what dates did he sign those. I believe they're dated. MR. GOLOBERGER: I don't know how you can ask questions about a document that is not to be produced and make it part of a deposition without violating the non -MR. GARCIA: ~~ well, I assume it can be produced to him and to his Tawyers. MR. GOLDBERGER: By acknowledging the existence of a agreement it violates the terms of the secrecy of the document, correct? MR. GARCIA: TI don't think so. MR. GOLDBERGER: I think it does. MR. GARCIA: I think it restricts disclosures to third parties. MR. GOLDBERGER: I'm going to instruct him not to answer any questions about the agreement. If you want to see the judge on this, we can, if you're right, you're right; if you're not, you're not. Out of an abundance of caution I'm not going to have him answer any questions about jit right now. Page 14

DEPO. EPSTEIN BY MR. GARCIA: (CONT'D) can you give me an exemplar of how you sign your name? A’- (No response). MR. GARCIA: Come on, that doesn't incriminate him. MR. GOLDBERGER: Yes -~ MR. GARCIA: -- for a crime, his signature? A 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 awsuit. I must accept this advise 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 of the United States Constitution. Q Do you have a preference for women under the age of 187 A AS I've said in response to al] questions previously asked of me, I intend to respond to all relevant questions regarding this Tawsuit, 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 advise or risk Tosing my 6th amendment right to effective representation. Accordingly, tf assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the united States Constitution. , Q Have you ever been married? A NO Q Have you ever been engaged? MR. BURMAN: Go ahead and answer it. No. A Q Do you have any employees? A Excuse me? Q Do you have any employees? A Employees? Q Yes. A I intend to respond to ail relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the united States Constitution. Q Do you have a company that is incorporated anywhere? MR. GOLDBERGER: That's kind of a vague question. Q Do you own -- are you involved in any business, any type of enterprise where your business is incorporated in any state? A AS I've said in response to al] questions previously asked of me, I intend to respond to all relevant questions regarding this tawsuit, however, Page 15

DEPO. EPSTEIN at the present time my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the United States constitution. Q when you are on work release Monday | through Saturday pursuant to your agreement with either the Sheriff's office and/or the Prosecutor's office here locally, do you actually do any work? MR. GOLDBERGER: We're not going to answer that question. Bring that to the judge. MR. GARCIA: why? MR. GOLDBERGER: [t's just to embarrass him. what's the possiBle purpose of that relevant to your lawsuit, it just really serves no purpose, Mr. Garcia. pa ae MR. GARCIA: why would working embarrass yim? MR. GOLDBERGER: TI don't know the : relevance of it. I'm really going be flexible and allow you to ask any questions even marginally relevant -MR. GARCIA: -- I just want to know how he's spending him time out of jail. e MR. GOLDBERGER: Why is that of issue to you? MR. GARCIA: It may lead to the discovery of admissible evidence, A Then that's an easy answer. As I've said in response to all questions previously asked of me, 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 advise 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 of the united States Constitution. Q where does Sarah Kellen presently live? A As I've said in response to some of your other questions, 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 advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th amendment of the United States Constitution. Q Has Sarah Kellen visited you during your stay at the Palm Beach County Jaii? Yes, How many times? I don't know. Do you know when she visited you last? DPOPrAP No. what did you discuss with her? Page 16

DEPO, EPSTEIN A As I've said in response to all questions previously asked of me, 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 advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the united States Constitution. Q Have you -A -- one second -- can you grab my IPhone? Q Have you discussed with Ms, Kellen providing, at your expense, legal representation for any claims made against her? MR. GOLDBERGER: Go ahead. A As I've said in response to all questions previously asked of me, 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 advise 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 of the United States Constitution. . 7 : 2 Q Did you hire David Spicer at one time to represent you in this case? MR. GOLDBERGER: You can answer that. A Yes. Q Is he -~ : i A -- what was the question again, sorry? (Whereupon there is a ringing sound.) : THE WITNESS: I have to take this outside. {whereupon a break is taken.) DIRECT BY MR. GARCIA: (CONT'D) Q David Spicer, I think I was asking you about him, is he representing you now? A No, he's not. Q Do you know why he represented you at least for a brief time in this case? A I considered hiring him and decided not to. Q Did you hire him for any other case besides this case? A This case meaning what? . ‘cl Q The case that we're here on today Dainya Nida. MR, GOLDBERGER: I think during the discussions there would have been an attorney client relationship. MR. GARCIA: No -~ let me ask it this way. Did he file an appearance in any other case other than this case involving Dainya Nida? A I don't know. Q But he's no longer representing you? A correct. were you ever interviewed by the Town of Palm Beach Police Department concerning any alleged Page 17

a DEPO, EPSTEIN criminal wrongdoing on your part? A (No response). MR. GARCIA: I just want to know if he was interviewed, not the contents of the interview at this point. A Please rephrase the question, you talk about only in certain -- traffic tickets again? Q No, No. Forget the traffic tickets, just these cases involving the alleged sexual misconduct on your part. A No. were you ever interviewed by the Federal Bureau of investigation in any of these cases? A No. Q Do you own a home at 358 E] Brillo way in Palm Beach, Florida? MR. BURMAN: In addition to what he's going to read, I'm going to object on the grounds that this deposition is being taken in a state case and that there's been no approval of a claim for pur! tive damages and that sues tion would be directed towards financial worth. MR. GARCIA: I'm trying to find out if -that is alleged to be the scene of the events, I'm trying to establish whether or net it was or it wasn't. A was it the scene of the events in question? Q No. I think my question -~ I was explaining to your lawyer why I'm asking the question. The question is ~- let me ask this_way. Have you ever resided at a home at 358 £1 Brillo way? THE COURT REPORTER: i need to go off the record due to computer difficulties. MR. GARCIA: Sure. (whereupon a break is taken.) MR. GARCIA: Back on the record. DIRECT BY MR. GARCIA: (CONT'D) Q Did you keep any sex toys at that home? A AS I've said in response to some of your other questions, I intend to respond to al? relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the United States Constitution. Q Did you ever penetrate Dainya Nida's vagina using your fingers? A I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. accordingly, Tf assert my federal constitutional Page 18

DEPO. EPSTEIN rights as guaranteed by the Sth, 6th and 14th amendment of the United States Constitution. Q when do you intend to answer these questions? A I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the United States Constitution. Did you ever tell Dainya Nida that she should be a model? A I intend to respond to al] relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the United States Constitution, Q Did you ever offer Dainya Nida help in becoming a model? MR. GARCIA: For the record, the witness has been shaking his head and smiling in response to the last few questions, MR. GOLDBERGER: I disagree with that assertion that that is what is happening, but you can say what you want for the record. MR, BURMAN: I didn't see it. A I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the United States Constitution. Q Did_you ever tell Dainya Nida you could not wait until she was 18 so you could fly her to Paris? A AS L've said in response to some of the questions previously asked of me, 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 advise 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 of the united States Constitution. Did you always pay the same amount for sexual services for Dainya Nida? MR, GOLDBERGER: Form. A I intend to respond to al] relevant questions regarding this lawsuit, however, at the Page 19

DEPO, EPSTEIN present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, £ assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Q Did you ever offer Dpainya Nida additional monies if she had sexual intercourse with you? A I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th amendment of the united States Constitution. Let me explain and put on the record this is about MR. GARCIA: Let me explain and put on the record that this is about the second conference during the deposition. in a civil case if a witness confers during a deposition with his counsel T'm entitled to find out what that discussion was about. *I'm going to go ahead and ask what did you just discuss with your counsel? MR. BURMAN: I disagree with that, it's attorney client privilege and I instruct him not to answer that. MR. GARCIA: Okay. Certify that question and print it up right away. _ a pid you ever give Dainya Nida any gifts besides cash? MR. GOLDBERGER: Object to the form. Q You can answer. A As I've said in response to some of your other questions previously asked of me, I intend to respond to all relevant questions regarding this Jawsuit, 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 advise 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 of the United States constitution. Q Do you know a Detective Silvestri? A No. Q Do you know any officer with the Town of Palm Beach either through a traffic citation they may have written for you or maybe you called them out for some issue at your home? A Not that I recall. Q Has the Town of Palm Beach Police ever been to your home on Brillo way? A I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me T cannot provide answers to any questions relevant to this Page 20

DEPO. EPSTEIN Yawsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Atcordingly, X assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. May we take a break? Q Absolutely. I want to put on the record that any discussion had with counsel during a break in the deposition -~ . . A -- he's not coming with me. Q Okay. MR. GOLDBERGER: I'm going to check my messages, you want to send a monitor with me? MR. GARCIA: No. (whereupon a break is taken.) DIRECT BY MR. GARCIA: (CONT'D) Q Do you have any escort from the Palm Beach county Sheriff's office when you go on your work release program? A I don't understand the question. Q Does anybody from the Sheriff's office transport you when you're on work release? A No. Q No. So you travel on your own? A No. Q How do you get to wherever you go when you're released for work? A As I've said in response to many of your questions asked of me, I intend to respond to al] 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. = must accept this advise 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 of the united States constitution. Q Are you housed at the Palm Beach County stockade or at the main jail on Gun Club Road? A Housed, stockade. Q *are you with the general population? MR. GOLDBERGER: I'm just not going to answer any more questions about where he's living at the Palm Beach County stockade, it's got zero relevance. I respect your rights to ask the questions, if you want a judge to tell us he's got to answer them I'd be happy to but honestly, Mr, Garcia, it's irrelevant to anything you're doing. MR. GARCIA: All right, certify the question. MR. GOLDBERGER: Okay. MR. GARCIA: Your basis is relevance? MR. GOLDBERGER: No, it's -- the purpose of this is to embarrass Mr. Epstein and to ‘humiliate him. DIRECT BY MR. GARCIA: (CONT'D) Q *Do you have a written agreement concerning your work release program in_terms of where you can go, what time you get to leave, what Page 21

DEPO. EPSTEIN time you get to come back? MR. BURMAN: Tell him not to answer. Object to the form. Don't answer it. MR. GARCIA: Certify that question. MR. BURMAN: we'll assert his privilege to privacy. . Q who is Robert Josephsberg? A He's an attorney. Q what was his role in terms of, if any -did he have any role in terms of the agreement between the U.S. Attorney's Office and yourself? MR. GOLDBERGER: Object to the form. A what's his -MR. GOLDBERGER: ~-- object to the form and invoke attorney client privilege on behalf of Mr. Epstein. MR. GARCIA: I'm not asking him to disclose what he discussed with you or any other attorneys. MR. GOLDBERGER: ‘That's the only way he can answer that. MR. GARCIA: That's a speaking objection MR. GOLDBERGER: ~~ I don't want to -you're right. MR. GARCIA: I want to know if he has an understanding on his own without your interpretation of the understanding as to what Mr. Josephsberg’s role was or is in terms of your agreement with the U.S. Attorney's office. A I'm unclear. Q Okay. Are you able to testify in terms of how many times Ms. Nida came to your house in the Town of Palm Beach? MR. GOLDBERGER: Object to the form. A As I have responded to some of your previous questions, 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 advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the united States Constitution. Q At any point did any Jaw enforcement authorities seize your home and/or business computers? A I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to_this awsuit. I must accept this advise 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 of the United States Constitution. Q I note for the record you have some sort of telephone device and you've been receiving phone Page 22

WONauaAWwNe RPOCONOMAWNR Be DEPO.EPSTEIN calls and -4 -- IT have not received any phone calls. Q Or messages. : A No, I haven't received an’ hing. Q You haven't received anything during the deposition? A No, Sir, Are you allowed to have -- is it a telephone? A Yes. Q All right. Are you allowed to have this telephone during your work release hours? A I've been using it as a clock, Sir. Q Okay. I want to know if you -- if you're fancies to have a telephone during work release jours? A Yes. Q Is this a telephone, is it a smart phone? A I'm sorry, I don't know what that means. Q Is ita Blackberry? A r'm not very familiar with these things. sorry. Q what's the brand of it? MR. GOLDBERGER: Don't answer this. THE WITNESS: Okay. Q *Do you have access to the internet on that phone? MR. GOLDBERGER: Don't answer. MR. GARCIA: On what grounds? MR. GOLDBERGER: On grounds that it's none of your business. MR. GARCIA: You can't do that in a civil case, you can't say it's none of your business, it's not a legat objection. MR. BURMAN: He's correct. I'm telling him not to answer on the grounds it's a privacy privilege. MR. GARCIA: Certify the question. DIRECT BY MR. GARCIA: (CONT'D) Q Are you allowed to have this device, whatever it may be, in jail? A No. MR. BURMAN: Same objection. Don't answer, it's privacy privilege. MR. GARCIA: Okay. ___,Are you able to receive emai] transmissions on the phone? MR. BURMAN: Same objection. Don't answer it, privilege, privacy. Q Have you received any emai] communications from Sarah Kellen in the past -- let me ask this, when were you first incarcerated at the palm Beach county Jail, when was -A -- June 30. Q June 30 of what year? A This year, sorry, 08. Q Have you received any emai] transmissions from Sarah Kellen since June 30 of 2008? MR. BURMAN: Same objection. Don't answer on the basis of privilege of privacy he has under the Florida Constitution. Page 23

DEPO. EPSTEIN A I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the united States Constitution. Q who is your service provider for that phone? . “ _ ,MR. BURMAN: Same objection, privacy, privilege. Don't answer it, MR. GOLDBERGER: Also form. Q All right. You can answer, F MR. BURMAN: Could I just inquire for the record, is there some allegation that Mr. Epstein has tried to make contact with your client? MR. GARCIA: No. MR. BURMAI Okay. Thank you. BY MR. GARCIA: (CONT'D) e Q You can answer the question. A I don't know. Q *you don't know who your service provider is? , MR. GOLDBERGER: You just invoked privacy -MR, GARCIA: -- he didn't instruct him not to answer. MR. BURMAN: I’m telling him now, Thanks for reminding me. MR, GARCIA: Certify the question. *what's the phone number associated with this particular phone? 7 MR. BURMAN: Same objection, privacy privilege. pon't answer. MR. GARCIA: Certify the question. Q *How long have you had this particular phone? MR. BURMAN: Same objection, privilege of privacy. Don't answer. *How long have you had this particular phone number? MR. BURMAN: Same objection, privacy, privilege. Don't answer, MR. GARCIA: Certify all those questions as well. Did you ever tel] Dainya Nida that you wanted the encounter with her to be like a, quote, “a porn video," end quote? MR. GOLDBERGER: Object to the form. A As I have previously responded to many of your other questions, I intend to respond to atl relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me = cannot provide answers to any questions relevant to this lawsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert federal constitutional rights as guaranteed by the 5th, 6th Page 24

@NNN CON AW AWNROUBY eo NOUBWN DEPO.EPSTEIN and 14th amendment of the united states Constitution. Q You can answer. A As I've said in response to some of your other questions asked of me, 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 advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th amendment of the United States Constitution. Q Have you been involved in any other personal litigation where you are a party to a awsuit aside from these cases, and I'm including Dainya Nida and the other cases that have made similar allegations, have you ever been a party to any other type of lawsuit personally? Yes. Q All right. Any in Palm Beach County? A Maybe. Q There's something in the paper about a contractor suing you for building a dock or something, are you familiar with that case? A Somewhat, not very much. Q Anything besides that, any other cases in Palm Beach County besides the unpaid dock case? A Not that I recall. Q How about in New York? A You have to rephrase the question. Q Have you ever been sued individually as a person as opposed to your corporate entity, if you ave one which we don't know because you haven't answered that question, in your personal capacity individually in the State of New York? Ever? Yes. I believe so. You believe so. How many times? I have no idea. You know what the nature of the claim was, was it a breach of ~~ MR. GOLDBERGER: ~~ object to the form. MR. BURMAN: Object to the form. MR. GOLDBERGER: Let me just ~- we’ve gone almost two hours now, I'd like to stop at 12 for lunch if we can. THE WITNESS: Can we stop at one for lunch? MR. GARCIA: 1 think we'll be done before that, before 1:00 for sure. PPrPOroYp MR. GOLDBERGER: Okay. DIRECT BY MR. GARCIA: (CONT'D! Q What was your answer? A You have to repeat the question. (whereupon the following question is read back:) 'Q you know what the nature of the claim was, was it a breach of -~” Page 25

DEPO. EPSTEIN MR. GOLDBERGER: Object to the form. Q In other words, what_kind of lawsuit was it in New York, or lawsuits, plural, that was filed against you in New York? A I don't understand the question. Q You cannot answer the question? A I don't understand the question. Q I asked you if you had ever been sued in the State of New York, I think your answer was yes, and now I'm asking for what kind of a lawsuit was it that was filed against you? A Again, I don't understand the question. If I was sued over the past 20 years in ten different cases -- I'm not sure of what case you're referring to. Q I'm not referring to any particular case. T'm asking you to tel] me what kind of suit was brought against you. In other words, at some point in time you were served with a lawsuit, presumably you opened it up and had taken a look at it and possibly given depositions in the suit just like you are giving your deposition today, so I'm asking you do you know what kind of lawsuit was filed against you, or lawsuits, were filed against you in the State of New York? A No, I don't. Q You don't know? A No. Q Have you ever given a deposition before today? A Yes. Q In what type of case? MR. GOLDBERGER: AS best as you can recall, A securities case, I believe. Q Okay. And were you sued or were you suing someone? Both. who brought the suit originally you --- I don't know. Where was the deposition taken? My best recollection is New York. And what year was this lawsuit? I don't remember. Ten years ago. More than ten years, less than ten years? Ten years, maybe more than ten years. _ And was that the only deposition you've ever given? n A That I recall. Have you ever given a deposition in any of these cases involving allegations such as were made yee WR BURMAN: Object to the form 7 A what are the allegations made by Dainya Nida? Q well, I'm talking about the cases where you took a deferred plea agreement with the U.S. Attorney's office, the six or seven young women that you allegedly performed sexual acts with. A That's not the case. Q what's that? DPOb HPOrPOY Page 26

DEPO. EPSTEIN MR, GOLDBERGER: -- I have no idea what the question is but out of an abundance of caution, please -Q I'm just asking if you've given a deposition in any of these cases? MR. GOLDBERGER: What cases? MR. GARCIA: You want me to read the names of the alleged victims? MR. GOLDBERGER: Sure. Sure. well, I can't find my list, I do have a list somewhere but I'm talking about these cases where it is alleged that you solicited or had others solicit for you young women under the age of 18 to come to your house on 8rillo way and for them and you to perform certain sexual acts, and I realize that you have every right to contest whether any of that occurred, but my question js have you given a deposition involving those issues in any of those cases that have been brought against you? MR, GOLDBERGER: The form of the question is -- I want him to answer the question but the form makes it very difficult. MR. GARCIA: why? MR. GOLDBERGER: Because you're suggesting MR. GARCIA: ~-- I am not suggesting anything. I'm asking him has he given a deposition in any of the cases involving similar allegations. MR. GOLDBERGER: I need you to ask a specific case and then we will be happy ta -MR. GARCIA: -~ I'm not going to be able to give you a specific case. He can answer the question, MR. GOLDBERGER: Under the circumstances, I need you to invoke your privileges. A I intend ta respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit, I must accept this advise 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 of the United States Constitution. Q All right. Have you given a deposition in the past two years? Yes. In what case? MR. GOLDBERGER: You can answer that. Eww. E.W? Yes. what are the allegations in that case against you? A I don't know. You were never served with a complaint? QP OPL>Y I'm sure I was. f Did you read the complaint? No. POP Page 27

DEPO, EPSTEIN Q , who is the attorney that took your deposition? MR. GOLDBERGER: Do you know? THE WITNESS: No. Q where did the deposition take place? A Here. Q At this office? A Yes. Q Did you ever ask Dainya Nida to bring other young women to your home on Brillo way? A As I've said in response to some of your other questions, I intend to respond to all relevant questions regarding this Tawsuit, however, at the present time my attorneys have counseled me I cannot provide answers to any questions relevant to this awsuit. I must accept this advise 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 of the United States Constitution. Q In the past three years, have you destroyed any computer files of computers that you used or controlled? A As I've said in response to all questions -- many of the questions asked of me, 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 advise 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 of the United states constitution, | Q who is Adriana Ross? A As I’ve said in response to many of your questions asked of me, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me £ cannot provide answers to any questions relevant to this lawsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the united States Constitution. Q who is Leslie Groff (phonetic)? A AS I've said in response to the questions asked of me, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the United States Constitution. Q who is Nadia Marcinkova? MR. GOLDBERGER: Here's the problem, Mr. Garcia, to the extent that you are reviewing this agreement that was not to be Page 28

DEPO.EPSTEIN made public, one of the main reasons why it was net to be made public is so that the names are not revealed and you are violating the spirit of the non-disclosure agreement by asking questions that_come off the document that you have for very limited purposes. You can ask, go ahead, but I caution you that you very, very well may be violating the nondisclosure provision of the agreement and ft note when you showed me the agreement you had received earlier from the U.S. Attorney there's an email attachment to that that very, very carefully cautions you that it's a privileged document and for your use only and not to be published anywhere. MR. GARCIA: Okay. DIRECT BY MR. GARCIA: (CONT'D) Q Answer my question, Sir. A I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the United States Constitution. Have you ever asked Sarah Kellen, Adriana Ross, Leslie Groff or Nadia mMarcinkova to Find and solicit on your behalf young women to provide prostitution services for you? MR. BURMAN: Object to the form. Q You can answer. A AS I've said in response to some of your other questions, I intend to respond to al] relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the United States Constitution. Qa I may have asked you this already, I apologize if I'm being a Tittle bit repetitive, has sarah Kellen, Adriana Ross, Leslie Groff or Nadia Marcinkova ever been employed by you or any other business entity you own or control? A I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the United States Constitution. Q *For the record, this is the second conference you've had with counsel which I can't hear so t'm going to ask you again the last two conferences during this period of questioning tell Page 29

DEPO. EPSTEIN 0071 i me what you discussed with counsel. 2 MR. BURMAN: Object, attorney client 3 privilege also work product privilege and 4 instruct him not to answer. 5 MR. GARCIA: Certify those questions. 6 MR. GOLDBERGER: And I have no obligation ? to tell you based on those privileges being 8 invoked. 9 MR. GARCIA: You're wrong. I can tell you 10 there’s case law right on point and I'd be 11 happy to show it to you. 12 MR. GOLDBERGER: we can deal with that at 13 another time but if you really must_know the 14 concern is that you continue to violate the 15 nondisclosure provisions of the non-prosecution 16 agreement in direct contravention of what the ie agreement was as to what use you can make of it. 19 MR. GARCIA: He's not.a third party, he's 20 an actual party to the agreement and my client 21 is a third party beneficiary to the agreement 22 and I have not provided the agreement to any 23 third party in accordance with my agreement 24 with the U.S, Attorney's office. aa Let me have a couple of minutes, i'm 07 2 1 almost wrapped up I just have to find 2 somethi ng. it will be a couple of minutes. 3 (whereupon a break is taken.) 4 DIRECT BY MR. GARCIA: (CONT'D) 5 Q Did you ever solicit or have someone 6 solicit on your behalf a young woman named Britt to 7 perform sexual services for you at your home on 8 Brillo way in Palm Beach? 9 MR. GOLDBERGER: Object to form. 10 A As I've said in response to some of your 11 other questions, I 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 rovide answers to any questions relevant to this 15 awsuit. I must accept this advise or risk losing 16 my 6th amendment right to effective representation. 17 Accordingly, I assert my federal constitutional 18 rights as guaranteed by the 5th, 6th and 14th 19 amendment of the United States Constitution. 20 Q Did you ever solicit or have someone 21 solicit on your behalf a young woman whose first 22 name is Alexis for the purposes of performing 23 prostitution services for you in your home on Brillo 24 Way in Palm Beach? MR. BURMAN: Object to the form. A As I've said in response to some of your other questions, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise 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 of the United States Constitution. Page 30 COONAUAWN a

DEPO.EPSTEIN Alt right. Did you ever solicit or have someone solicit on your behalf a young woman by the name of Rhianin (phonetic) to perform prostitution services for you in your home on Brillo way in Palm Beach? MR. BURMAN: Object to the form. A As t've said in response to other questions of a similar nature, E intend te respond to al] 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 advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th amendment of the United States Constitution. MR. GARCIA: I'1] just note for the record Mr, Epstein just passed a note that he wrote while answering the question to his defense counsel which again I consider to be communications during the deposition, I would ask you to tel] me what you wrote in that note. MR. GOLDBERGER: Will we be able to have lunch at 1:00. MR. GARCIA: Okay. DIRECT BY MR. GARCIA: (CONT'D) Q I was up to Rhianin, let me move on to Sherry. Did you ever solicit or have someone solicit on your behalf a young woman by the name of Sherry, spelled with an s, to provide prostitution services for you at your home on Brillo way in Palm Beach? : MR. BURMAN: Object to the form. MR. GOLDBERGER: Object to the form and for clarification purposes do you have a last name? MR. GARCIA: No. A I intend to respond to all] relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert my federal constitutional rights aS guaranteed by the Sth, 6th and 14th amendment of the United States Constitution. Q I'm going to assume, and you tell me if I'm wrong, your answers would be the same for Nicole, Hailey and Joanna if I asked you the same question? MR. BURMAN: I would object to the form, if you specified each person, because you're not giving us last names, object to form and I thin you can probably stipulate his answer would be the same. MR. GOLDBERGER: That's correct. Is that okay with you? MR. GARCIA: Yes. DIRECT BY MR. GARCIA: (CONT'D) Q Do you know someone named Hailey Robson? Page 31

0076 WONAUAWN ES DEPO. EPSTEIN A As I've said in response to some of your other questions, Mr. Garcia, 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 advise 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 of the united States Constitution. Q Do you know someone by the name of ~~ I'17 read the same names again, not with the question about whether or not_you solicited them for prostitution at_Brillo way, I want to know if you now these people and if you're going to assert the same might maybe we can have the same stipulation. Do you Know any young women by the name of Britt, Alexis, Rhianin, Sherry, Nicole, Hailey or Joanna? MR. BURMAN: My objection is the same. If you are referring to a different person other than Hailey Robson, I really can’t object on form because you did give a last name. Is the Hailey you're referring to in this question a different individual or the same individual? MR. GARCIA: I assume the same individual, it's the same article which I produced to your firm which is available on a public site. MR. BURMAN: To the extent you have asked this question with regard to -- and not specified a last name, I would object to form and we would -~ Mr. Epstein would answer the question in the same fashion invoking his constitutional privileges and if we can have that stipulation it will save us some time. MR. GARCIA: That's fine. Agreed? MR. GOLDBERGER: Yes, that's fine. DIRECT BY MR. GARCIA: (CONT'D) Q Do you have any agreement with the u.s. Attorney's office to preserve your computer records? Yes. Q All right. Have you abided by that agreement? MR. GOLDBERGER: I'm going to invoke attorney client oc vilege on that question. Q can you tell me who has control or who has the actual equipment? MR. GOLDBERGER: Attorney client. Q who is Alexander Lian, L-I~A-N? A rt don't know. Q who is Palm Beach Marine? MR. BURMAN: Is that a person? MR. GARCIA: No, it's a company. You know who they are? No. I believe it's the lawsuit -~~ is that the name of the company? t don't really know. Is that case still pending? I don't really know. who is Douglas Shottle, S-H-O-T-T-L-E? Page 32 OPLPrOPS ©

DEPO. EPSTEIN A As I've said in response to some of your other questions, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th amendment of the United States Constitution. | Q *Do you have any close personal friends? MR. BURMAN: Object to the form and also assert his privilege as far as privacy, instruct him not to answer. MR. GARCIA: Certify the question. Q Have you discussed any of your alleged sexual encounters with Dainya Nida with any close personal friends? MR. GOLDBERGER: Object to the form, the same privilege as Mr. Burman invoked as far as peivacy and then I'd ask you to invoke the Fifth. A As I've said in response to some of your other questions, 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 Jawsuit. I must accept this advise 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 of the United States Constitution. Q Al? right. Just to refresh your recollection, he is, according to a published article, not involved in these cases, he allegedly jis the person who represented you when you signed a contract for having a dock put into your home. MR. GOLDBERGER: Who are you talking about? MR. GARCIA: Douglas Shottle. Q Does that refresh your recollection as to who he might be? A Z intend to vespond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me I cannot rovide answers to any questions relevant to this awsuit. I must accept this advise or risk losing my 6th amendment right to effective representation. accordingly, I assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th amendment of the united states Constitution. Q Okay. That's all I have. A Great. Thank you. MR. GOLDBERGER: Thanks for coming over. (whereupon the gepos ition. ts concluded at 12:20 p.m. Page 33

DEPO. EPSTEIN THE STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that the aforementioned witness personally appeared before me and was duly sworn. WITNESS my hand and official seal this 12th day of May, 2009. JULIE ANDOLPHO, COURT REPORTER Notary Public State of Florida My Commission Expires:12/14/09 My Commission # 00499509 CERTIFICATE THE STATE OF FLORIDA, COUNTY OF PALM BEACH I, Julie Andolpho, Professional Reporter, do hereby certify that I was authorized to and did report said deposition in stenotype; and the forgoing pages numbered 1 to » inclusive, area true and correct transcription of my shorthand notes of said deposition. I further certify that I am not an attorney or counsel of any of the parties, nor am Tf a relative or gmp lovee of any attorney or counsel of party connected with the action, nor am T financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter. IN WITNESS WHEREOF, I have hereunto set my hand this 12th day of May, 2009. JULIE ANDOLPHO, COURT REPORTER Notary Public in and for the STATE OF FLORIDA My Commission Expires:12/14/09, # 0D499509 Page 34

DEPO. EPSTEIN Page 35

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 12

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff, No. 502008CA028058XXXXMBAD JEFFREY EPSTEIN and SARAH West Palm Beach, Florida April 30th, 2009 10:08 o'clock A.M. VIDEOTAPED DEPOSITION or JEFFREY EPSTEIN Palm Beach Reporting Service, Inc. (561)471-2995

APPEARANCES: For The Plaintiff: ROTHSTEIN, ROSENFELDT, ADLER 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida, 33301-4252 By BRADLEY JAMES EDWARD, ESQUIRE and WILLIAM J. BERGER, ESQUIRE and RUSSELL ADLER, ESQUIRE For The Defendant: BURMAN, CRITTON, LUTTIER & COLEMAN 515 North Plagler Drive, Suite 400 West Palm Beach, Florida 33401-4349 By JOHN MICHAEL BURMAN, ESQUIRE Also for the Defendant: ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Ave. South, Suite 1400 West Palm Beach, Florida 33401 By JACK A. GOLDBERGER, ESQUIRE Also Present: Jeff Abbott, Videographer, Visual Evidence Paim Beach Reporting Service, Inc. (561) 471~2995

ZNDEX Direct Examination by Mr. Edwards EXHIBIT INDEX Plaintiff's Exhibit Number 1 marked for I.D. (Exhibit held by Attorney Edwards.) teh e epee ee Deposition of JEFFREY EPSTEIN, a witness of lawful age, taken by the Plaintiff, for the purpose of discovery and for use as evidence in the above entitled cause, wherein: #.W. is the Plaintiff, and JEFFREY EPSTEIN and SARAH KELLEN are the Defendants, in the Circuit Court in and for Palm Beach County, Florida, pursuant to notice heretofore filed, before LINDA P. AUKAMP, a Registered Professional Reporter and Notary Public in and for the State of Florida at Large, at 250 Australian Avenue South, Suite 1400, West Palm Beach, Palm Beach County, Florida, on the 30th day of April, 2009, commencing at 10:08 o'clock A.M. Palm Beach Reporting Service, Inc. (561)471-2995

‘wat THEREUPON, THE VIDEOGRAPHER: This is the 30th day of April, 2009. The time is 10:08 a.m. This is videotaped deposition of Jeffrey Epstein in the matter of L.M. versus Epstein. This deposition is being held at 250 Australian Avenue South, West Palm Beach, Florida. My name is Jeff Abbott, I am the videographer representing Visual Evidence, Incorporated. Would the attorneys please announce their appearances for the record. MR. EDWARDS: Brad Edwards on behalf of the plaintiff. And this deposition was set in the case of E.W., not L.M. THE VIDEOGRAPHER: Oh. MR. EDWARDS: That is a separate client of mine, but that's not the case. THE VIDEOGRAPHER: Okay, that's what I had. Sorry. MR. BERGER: And I'm William J. Berger, for the plaintiff, also. MR. GOLDBERGER: Jack Goldberger on behalf of Jeffrey Epstein. MR. BURMAN: Michael Burman on behalf of Jeffrey Epstein. Palm Beach Reporting Service, Inc. (561)471-2995

ty JEFFREY EPSTEIN, Being a witness in the notice heretofore filed, being of lawful age, and being first duly sworn in the above cause, testified on his oath as follows: THE WITNESS: Yes, I do. DIRECT EXAMINATION Q. {By Mr. Edwards) Can you tell us your full name for the record? A. Jeffrey Edward Epstein. Q. And what's your date of birth? January 20th, 1953. And your social security number? 090-44-3348. And your current address in West Palm Beach? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Fifth, Federal Palm Beach Reporting Service, Inc. (561)471-2995

Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution. Q. So you're unwilling to give us your address of your house in Palm Beach County? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit or risk losing my Sixth Amendment right to effective representation. MR. EDWARDS: Mr. Goldberger, can we enter into an agreement so that we all know that he's reading off of that piece of paper, we know what the whole spiel is, but maybe he can just say fifth or same answer or something like that, so we can continue to move on, rather than read that paper the entire time? We'll be here for days. MR. GOLDBERGER: I think out of an abundance of caution it's probably appropriate that whatever we feel is the proper response is, so that our invocation of our Fifth Amendment privileges is properly protected, so I think we're going to have to give the full Palm Beach Reporting Service, Inc, (561)471-2995

length -MR. BURMAN: Obviously we can't tell what you're going to play to a jury without the entire spiel, what questions you might play to a jury if you decide to do that when this case is tried, so we're going to go with the entire spiel to every question you ask. If -- that's Mr. Goldberger's representation, or recommendation, MR. EDWARDS: Okay. MR. GOLDBERGER: We will go question by question, and we may or may not invoke Fifth Amendment privileges and there may be times where I'm going to have to think about it, discuss it with Mr, Burman whether we're going to invoke on any particular question, but on those questions that we do invoke Fifth Amendment privileges, I think we have no choice but, as you say, do the entire spiel. Q. (By Mr. Edwards) Can you tell me the addresses of other homes that you own outside of West Palm Beach? A. I intend to respond to all relevant questions regarding this lawsuit. However, in the present my attorneys have counseled me that I cannot Palm Beach Reporting Service, Inc. (561)471-2995

provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Q. Have you seen any -MR, GOLDBERGER: And, excuse me, and your Fifth Amendment privileges. THE WITNESS: Yes. Accordingly, I, excuse me, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteen Amendments of the United States Constitution. Q. (By Mr. Edwards) Have you seen any psychologists or psychiatrists in your life? MR. GOLDBERGER: Go ahead. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and TI must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment of that constitution, Palm Beach Reporting Service, Inc. (561)471-2995

Q. (By Mr. Edwards) Tell me the names of all the businesses in which you are affiliated in any way? A, I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. I also assert my Federal Constitutional Rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution. Q. My understanding is you're currently serving a 12-month jail sentence, is that correct? MR. GOLDBERGER: You can answer, but -THE WITNESS: No. Q. (By Mr. Edwards) You were currently, you were initially sentenced to 18 months in jail, is that correct? MR. GOLDBERGER: Go ahead. THS WITNESS: Yes. Q. {By Mr. Edwards) And at the present moment are you still under the supervision of that Palm Beach Reporting Service, Inc. (561)471-2995

2 10 jail sentence? A. Yes. Q. Do you know what your release date will No. You have not been told the date of your release? A. Not yet. Q. Where do you plan to reside when you're released from jail? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have advised me that I must accept the advice, advised me not to answer those questions. I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. Mr. Epstein, I have a videotaped copy of the plea colloquy where you pled guilty and told that judge you would be residing in West Palm Beach, Florida. Are you saying now that the statement you made to that judge is no longer true? Palm Beach Reporting Service, Inc. (561)471-2995

iL A. Sorry, could you repeat the question? Q. Sure. I have a videotaped copy of the plea colloquy -A. No, the question before that, That's -okay. Q. The question is, where do you intend to reside once you are released from jail? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Constitution. Q. As you know, that question was asked to you when you pled guilty last June in 2008, and you responded to the judge that you planned to reside in West Palm Beach, Florida. Is that no longer your intent? A. I intend to respond to all relevant Palm Beach Reporting Service, Inc. (561)471-2995

12 questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Pederal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. This deposition is not being taken in the county jail, but rather in your attorney, Jack Goldberger's office, so can you please inform the jury as to your current schedule as it is exists today? MR. GOLDBERGER: Let me hold off on that. Okay. THE WITNESS: I don't understand the schedule, the question. MR. GOLDBERGER: Yeah, if you can just, if you can rephrase the question, I think we can answer it for you. Q. (By Mr. Edwards) Okay. Currently you described that you're under the supervision of the } jail sentence at this point in time, you're within the 18 months of your jail sentence. But this isn't Palm Beach Reporting Service, Inc. (561)471-2995

13 a jail setting, so obviously you're outside of the jail setting. I am asking you just to tell the jury your current schedule; you wake up, are you released from jail at some time, do you have to report back to jail on a daily basis? A. Yes, I report back to jail at 8:00 p.m, Every single day? Yes. Q. And is it seven days a week that you're out on work release? A. No, sir. Q. How many days a week are you out on work release? Six, And of those six days, how many hours per day are you out on work release? A, Twelve. Q. And what are the hours that you're out on work release versus the hours that you are confined to the jail? A. Repeat the question, please. Q. What are the hours that you are out on work release outside the jail versus the hours that you are inside the jail, meaning if you report back Palm Beach Reporting Service, Inc. (561)471-2995

14 to the jail at 8:00 and stay there until 8:00 in the morning, tell me that. A. I just did. Q. Bnd is that the schedule? A. I just did. Yes, that's the schedule. Q. Okay. So from 8:00 p.m. until 8:00 a.m. you're in the jail? A. Yes. Q. And then from 8:00 a.m. to 8:00 p.m. you're out on work release? A. Is that a question? Yes. Yes. And where do you, where do you work? MR. GOLDBERGER: Objection. THB WITNESS: I intend to respond to all relevant questions to this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Therefore, I assert my Federal a Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the Palm Beach Reporting Service, Inc. (561)471-2995

is constitution. Q. (By Mr. Edwards) Are you saying that providing me an answer as to where you currently work, would somehow incriminate you? MR. GOLDBERGER: Let's not be argumentative. He responded to the question on advice of counsel, and if you think that was an improper invocation, then you have a remedy, but don't argue with the witness, which is what we did. Okay. Q. (By Mr. Edwards) Do you have any plans to leave the country once you're released from jail? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept the advice or risk losing my Sixth Amendment right te effective representation. Accordingly, I assert my Federal Constitutional right as quaranteed by the Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. Do you currently own any jets or airplanes? A. I intend to respond to all relevant Palm Beach Reporting Service, Inc. (861)471-2995

16 G questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the constitution. MR. BURMAN: Is A.W. a state or federal case? MR. EDWARDS: State. MR. BURMAN: Okay. I am going to, in addition to my client's assertion of his rights, also object on the grounds that punitive damages hasn't been allowed in this case yet. That's clearly a financial-type question and, therefore, we object on those grounds, as well. MR. EDWARDS: Thank you. Q. (By Mr. Edwards) Who are the pilots that are employed by you or work for you or fly your airplanes? ao A. I intend to respond to all relevant questions regarding this lawsuit. However, at the Palm Beach Reporting Service, Inc. (561)471-2995

~ 17 present time my attorneys have counseled me that TI cannot provide answers to any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. What person or persons make your travel arrangements when you travel? A. it intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have advised me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk lesing my Sixth Amendment right to effective representation. Accordingly, I would have to assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. Once you are released from jail, are you under an obligation to report to probation? A. Palm Beach Reporting Service, Inc. (561)471-2995

18 wN Q. Do you intend to do so? A. Yes. Q. And once you are released, do you, according to your sentence, are you scheduled to serve one year commmity control or house arrest? MR. GOLDBERGER: That's a compound question. Please rephrase it. THE WITNESS: Yes. Q. (By Mr. Edwards} When you're released from jail, do you intend to serve one year community control as a part of your sentence? A. Yes. Q. And under that provision, will you be able to continue working or will you be strictly confined to your house? KR. GOLDBERGER: That calls for a legal interpretation on the part of my client that he's just not, he's just not competent to answer. So, if you know, fine, but I can’t imagine you would know. THE WITNESS: I don't know. Q. (By Mr. Edwards) Who are the people that will be living or working in your house once you are om released from jail? A. I intend to respond to all relevant Palm Beach Reporting Service, Inc. (561)471-2995

19 questions regarding this lawsuit. However, at the present time my attorneys have advised me that I cannot provide answers to any questions currently. Therefore, I must accept this advice or risk losing my Sixth Amendment right to effective representation, Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. Are you currently working with the Florida Science Foundation? MR. GOLDBERGER: Umm, okay. THE WITNESS: Yes. Q. (By Mr. Rdwards) And that is a, a business that operates just next door to your attorney, Jack Goldberger's office, is that correct? Ae No. Q. The Florida Science Foundation does not have an office on this floor right next door to your attorney, Jack Goldberger's office? A. Is that a question? Yes. You have to rephrase the question, please? Q. Does the Florida Science Foundation have an office right next door to your attorney, Jack Palm Beach Reporting Service, Inc. (561)471~2995

20 Goldberger's office? A. No, Q. What is your role with the Florida Science Foundation? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have advised me that I cannot answer questions relevant to this lawsuit and must accept their advice, or risk losing my Sixth Amendment right to effective representation. Therefore, I must assert my Federal Constitutional right under the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. What does the Florida Science Foundation A; I intend to respond to all relevant questions to this, regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights guaranteed by the Fifth, Sixth, and Fourteenth Amendment to that Palm Beach Reporting Service, Inc. (561)471-2995

21 constitution. Q- Have you procured minors for the purposes o£ prostitution? A. I intend to respond to all relevant questions to this, regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions xvelevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment of the United States Constitution. Q. Isn't it true that you did plead guilty to two felonies related to prostitution with minors? MR. GOLDBERGER: Wait a minute, let me just hold off a second. (Thereupon, a discussion was had off the record.) MR. GOLDBERGER: You can answer the question. THE WITNESS: Could you repeat the question? Q. (By Mr. Edwards) Isn't it true that you Palm Beach Reporting Service, Inc. (561)471-2995

22 pled guilty to two felony counts related to procurement of a minor for prostitution and/or solicitation of a minor for prostitution? A. No. What counts did you plead guilty to? Procuring a minor for prostitution and soliciting prostitution. Q. Have you had sex with minor girls? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have advised me that I cannot provide answers to any questions relevant to this lawsuit at the present time, and I must accept that advice or risk losing my Sixth Amendment. right to effective representation. Accordingly, I assert my Federal Constitutional right under the Fifth, Sixth, and the Fourteenth Amendment to the Constitution. Q. Have you engaged in sex acts with girls who at the time you engaged in those sex acts were minors? A. I intend to respond to all relevant questions to this lawsuit. At the present time my attorneys have counseled me that I cannot respond, I'm sorry, provide answers to any questions relevant Palm Beach Reporting Service, Inc. (561)471-2995

wet 23 to this lawsuit, and I must accept that advice or risk losing their representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment. Q. Did you intentionally touch my client, I don't understand the question, sorry. For the purpose of this lawsuit, we have used the pseudonym to describe my client. Do you know who I'm talking about when I refer to #.W.? A. I intend to respond to all relevant questions to those, this lawsuit. However, at the present time my attorneys have advised me that I cannot accept, answer any questions relevant to this lawsuit, and must accept their advice, or risk losing my Sixth Amendment right to effective representation. Q. Did you -A. Accordingly -- excuse me -- I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. MR. BURMAN: We further object on the ground that E.W.'s name has not been disclosed Palm Beach Reporting Service, Inc. (561)471-2995

ote 24 and you've objected to that. MR. EDWARDS: Thanks. Q. (By Mr. Edwards) Did you touch my client, E.W., against her will? aA, We don't know who E.W. is. You haven't told me who B.W. is. Q. Okay. MR. EDWARDS: Do you have an exhibit sticker? (Thereupon, Plaintiff's Exhibit Number 1 was marked for Identification by Attorney Edwards.) Q. (By Mr. Edwards) I'm going to show you an exhibit that I have marked for identification purposes as Plaintiff's Exhibit 1. Do you recognize the girl on the left in the photograph? A. I intend to respond to all relevant questions regarding -THE WITNESS: Excuse me one second. (Thereupon, a discussion was had off the record. ) THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have Palm Beach Reporting Service, Inc. (561)471-2995

28 counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as given by the Fifth, Sixth -- as provided by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Do you know somebody by the name of Courtney Wild? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the constitution. Q. For the purposes of this deposition, when I refer to B.W., I'm speaking of Courtney Wild. Back to my initial question. Did you touch my client, E.W., against her will? aA. I intend to respond to all relevant Palm Beach Reporting Service, Inc. (561)471-2995

26 questions regarding this lawsuit. However, at the present time my attorneys have advised me that I cannot provide answers to any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Fifth, Sixth, and Fourteenth -- Fifth, Sixth and Fourteenth Amendment of the constitution. Q. Did you engage in sex or sex acts with my client, E.W., against her will? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have advised me that I cannot provide any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as. guaranteed by the Fifth, Sixth, and Fourteenth Amendment to that constitution. Q. Isn't it true that when you touched E.W. against her will, you knew her to be a minor at the time? Palm Beach Reporting Service, Inc. (561)471-2995

os 27 A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as quaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Did you engage in sex or sex acts with a female named Hailey Robson, (phonetic)? A. I intend to respond to all relevant questions regarding this lawsuit, However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right under the Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Brittney, Palm Beach Reporting Service, Inc. (561)471-2995

28 (phonetic) ? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor named Sage (phonetic)? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Palm Beach Reporting Service, Inc. (561)471-2995

29 Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Carolyn Casey (phonetic) ? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. MR. BURMAN: Mr. Edwards, can I inquire of you one thing? Do you have a RICO count in E.W.'s case? MR. EDWARDS: Yes. MR. BURMAN: Okay. These other girls, are any of them your clients, as well? MR. EDWARDS: Some may he, MR. BURMAN: Okay. Thank you. MR. EDWARDS: Some are not. MR, BURMAN: Okay. (By Mr. Edwards) Between 2001 and 2005 Palm Beach Reporting Service, Inc. (561)471-2995

mo, 390 did you engage in sex or sex acts with a minor female named Carolyn Adriamo (phonetic)? A. IT intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. Between 2001 and 2005 did you engage in sex ox sex acts with a minor female named Amy {phonetic}? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation, Accordingly, I assert my Federal 5 Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Palm Beach Reporting Service, Inc. (561)471-2995

31 Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Melissa {phonetic) ? A. I intend to respond to all relevant questions regarding this lawsuit. However, at this time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I asgert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Constitution. Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Dara (phonetic) ? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective xepresentation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471-2995

32 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Janine (phonetic) ? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right under the Fifth, Sixth, and Fourteenth Amendment to the constitution. e. Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Amanda {phonetic)? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective Palm Beach Reporting Service, inc, (561)471-2995

Neal 33 representation, Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. THE WITNESS: Can we take a break for, a bathroom break, is that okay? THE VIDEOGRAPHER: We're off the record at 10:39. (Thereupon, a discussion was had off the record.) THE VIDEOGRAPHER: We're back on the record at 10:44, Q. {By Mr. Edwards) Between 2002 and 2005 did you engage in sex or sex acts with a minor female named Holly (phonetic)? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Palm Beach Reporting Service, Inc. (561)471-2995

34 ¢ Sixth and the Fourteenth Amendment to the United States Constitution, THE WITNESS: Can I see you a second, Mike? MR. BURMAN: Sure. THE VIDEOGRAPHER: We're off the record at 10:45. (Thereupon, a brief break was taken.) THE VIDEOGRAPHER: Back on the record at 10:46. Q. (By Mr. Edwards) Between the year 2001 and 2005 did you engage in sex or sex acts with a minor female named Eva (phonetic)? MR. BURMAN: Object to form, form vague and indefinite. Last name, please. MR. EDWARDS: You can answer the question. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. fit, a) Accordingly, I assert my Federal Constitutional right as guaranteed by the Palm Beach Reporting Service, Inc. (561)471-2995

35 Fifth, Sixth, and Fourteenth Amendment to the United States Constitution, Q. (By Mr. Edwards) Between the year 2001 and 2005 did you engage in sex or sex acts with a minor female named Riannen (phonetic) ? MR. BURMAN: Object to form, vaque and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my Sixth Amendment right to effective representation, Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Nicole (phonetic)? MR. BURMAN: Object to form, vague and = indefinite. Last name, please, MR. EDWARDS: You may answer. Palm Beach Reporting Service, Inc. (861)471-2995

C 36 THE WITNESS: I intend to respond to ali relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must. accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Tatum (phonetic)? MR. BURMAN; Object to the form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer if -THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my Sixth } Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471-2995

37 Constitutional right as guaranteed by the C Pifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Shawna (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer, if you know. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mx. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Vivian (phonetic)? / 3 MR. BURMAN: Object to form, vague and indefinite. Last name, please. Palm Beach Reporting Service, Inc. (561)471-2995

38 CH. MR. BDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. {By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Danielle (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and ay must accept this advice or risk losing my Sixth Amendment right to effective representation. Palm Beach Reporting Service, Inc. (561)471-2995

i A 39 Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female that you referred to ag Courtney Ice Cream, (phonetic) ? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. MR. BURMAN: Or flavor. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and Must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q- (By Mx. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor Palm Beach Reporting Service, Inc. (561)471-2995

=~, Net 40 female named Tamika (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Q. (By Mr. Edwards) Between -THE WITNESS: Sorry? MR. EDWARDS: I didn't realize you weren't finished. THE WITNESS: Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards} Between 2001 and 2005 did you engage in sex or sex acts with a 12-year-old girl named Virginia (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. Palm Beach Reporting Service, Inc. (561)471-2995

41 THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mx. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Alisha (phonetic)? MR. BURMAN: Object to form, vague and indefinite, Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471-2995

42 Constitutional right as guaranteed by the Fifth, Sixth and the Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Cara (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr, Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Mary (phonetic)? oe MR. BURMAN: Object to form, vague and indefinite. Last name, please. Palm Beach Reporting Service, Inc. (561)471-2995

4 43 MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Pifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Shelby (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You may answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Palm Beach Reporting Service, Inc. (561)471-2995

44 Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Ashley (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to alli relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. MR. GOLDBERGER: One moment. (Thereupon, a discussion was had off the record.) (Thereupon, Attorney Adler entered Palm Beach Reporting Service, Inc. (561)471-2995

45 the deposition room.) MR. EDWARDS: We're back on. Q. (By Mr. Edwards} Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Sherry (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend ta respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Colleen (phonetic) ? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You may answer. Palm Beach Reporting Service, Imc. (561)471-2995

“~ 46 THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and the Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Julie (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You may answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471-2995

47 oe Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Vanessa (phonetic)? MR. BURMAN: Object to the form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. {By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named April (phonetic)? oo MR, BURMAN: Object to form, vague and indefinite. Last name, please. Palm Beach Reporting Service, Inc. (561) 471-2995

48 MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Co Q. (By Mr, Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Alexandra (phonetic)? MR. BURMAN: Object to form, vague and indefinite. And last name, please? MR. GOLDBERGER: Is that Alexander or Alexandra? MR. EDWARDS: -- dra. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have Ay counseled me that I cannot provide answers to any questions relevant te this lawsuit, and Palm Beach Reporting Service, Inc. (561)471-2995

49 must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. {By Mr. Edwards) Between 2001 and 2005 aid you engage in sex or sex acts with a minor female named Michelle (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor Palm Beach Reporting Service, Inc. (561) 471-2995

50 female named Yolanda (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Angelique (phonetic)? MR. BURMAN: Object to form, vague and indefinite, Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to Palm Beach Reporting Service, Inc. (561)471-2995

wi 51 any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Faith (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond te all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mx. Edwards) Between 2001 and 2005 Palm Beach Reporting Service, Inc. (561)471-~2995

XY 52 did you engage in sex or sex acts with a minor female named Molly (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: ‘I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Felicia (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer, THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have Palm Beach Reporting Service, Inc. (561)471-2995

53 counseled me that I cannet provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Leigh, L-E-1I-G-H? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. TRE WITNESS: I intend to respond to all velevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I Must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Palm Beach Reporting Service, Inc. (561}471-2995

54 Coe Q. (By Mr. Edwards) Isn't it true that at the time you engaged in sex or sex acts with each of the people we have just discussed, you knew they were minors? MR. BURMAN: Object to form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right under the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) With each of these girls, isn't it true that you used someone else to recruit them to your house? MR. BURMAN: Object to form, vague and indefinite. THE WITNESS: I intend to respond to ail relevant questions regarding this lawsuit. ‘y However, at the present time my attorneys have counseled me that I cannot provide answers to Palm Beach Reporting Service, Inc. (561)471-2995

55 any#questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) For the purposes of these next. questions, when I refer to "the minor girls" I'm referring to Hailey Robson, Brittney, Sage, Carolyn Casey, Carolyn Adriamo, Amy, Melissa, Dara, Janine, Amanda, Holly, Eva, Riannen, Nicole, Tatum, Shawna, Tamika, Vivian, Danielle, Jennifer, Virginia, Alisha, Alexandra, Sarah, Courtney Ice Cream, Lauren, Melissa, Dana, April, Cara, Mary, Shelby, Ashley, Sherry, Colleen, Julie, Vanessa, Michelle, Yolanda, Angelique, Faith, Molly, Felicia, Leigh or Leigh, and Courtney, my client, which is the plaintiff in this lawsuit. My question is -MR. GOLDBERGER: You've identified that Courtney as Courtney Wild, correct? MR. EDWARDS: Correct. Q. (By Mr. Edwards) With each of these girls, isn't it true that you paid somebody else to Palm Beach Reporting Service, Inc. (561)471-2995

56 bring them to your house? MR. BURMAN: Object to the form, vague and indefinite. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mx. Edwards) For each of these minor girls, isn't it true that you paid each of them for sex or sex acts? MR. BURMAN: Object to form, vague and indefinite. Further explaining that to the extent that no last names have been identified for most of the girls. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawauit. However, at the present time my attorneys have Palm Beach Reporting Service, Inc. {§61) 472-2995

57 counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must. accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn't it true that in order to recruit each of these minor girls to your house, you had someone tell them, "A rich guy in Palm Beach will pay you cash to go to his house and give him a massage"? MR. BURMAN: Object to ferm, vague and indefinite, to the extent last names of the girls have not been identified. THE WITNESS: I intend to respond to ail relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my Sixth Amendment right to effective representation. e Accordingly, I assert my Federal Constitutional right as guaranteed by the Palm Beach Reporting Service, Inc, (561)471-2995

58 Pifth, Sixth, and Fourteenth Amendment of the United States Constitution. Q. (By Mr. Edwards) Each of these minor girls, when arriving at your house, was greeted at the door by one of your employees at your mansion, isn't that correct? MR. BURMAN: Object to form, vague and indefinite. No description of last names of the alleged minor girls. URE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. Rowever, at the present time my attorneys have advised me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mx. Edwards) Hach of these minor girls was escorted up to your bedroom by one of your employees, isn't that correct? MR. BURMAN: Object to the form, vague and indefinite. Palm Beach Reporting Service, Inc. (561)471-2995

59 THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. May I just ask, step outside for a second, I want to just ask a question. MR. BURMAN: Sure. THE VIDBOGRAPHER: Going off the record at L1:i1. (Thereupon, a brief break was taken.) THE VIDEOGRAPHER: Okay, we're back on the record at 11:16, Q. (By Mr. Edwards) Previously I named, or I gave you the names of 49 minor girls. Isn't it true that you engaged in sex or sex acts with each of them? Ry MR. BURMAN: Object to the form, vague and indefinite. Last names weren't provided for Palm Beach Reporting Service, Inc. (561)471-2995

60 most of them. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept that advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution, Oe Q. (By Mr. Edwards) With respect to each of the minor girls that was taken into your bedroom by one of your employees, isn't it true that you entered the room wearing only a towel? MR. BURMAN: Object to form, vague and indefinite, last names of the alleged minor girls weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to omy any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Palm Beach Reporting Service, Inc. (561)471~-2995

61 ( Amendment right to effective representation. Accordingly, my federal, I have to assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q- {By Mr. Edwards} With respect to each of these minor girls, isn't it true that you ordered each of them to get naked to give you a massage? MR. BURMAN: Object to form, vague and indefinite with regard to the alleged minor girls, the names weren't provided. Last names weren't provided. MR. EDWARDS: You can answer. THR WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the a United States Constitution. Q. (By Mr. Edwards) With respect to each of Palm Beach Reporting Service, Inc. (561})471-2995

62 the 49 named minor girls, isn't it true that you masturbated in front of each of them? MR. BURMAN: Object to the form, vague and indefinite with regard to the alleged minor girls, their last names weren't provided. THR WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attoxneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn't it true that you asked each of the minor girls to do similar things to you, such as rub your nipples? MR. BURMAN: Object to the form, vague and indefinite with regard to the alleged minor girls, the last names weren't provided. wie, THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. Palm Beach Reporting Service, Inc. (561)471-2995

63 However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. {By Mr. Edwards) With respect to all of the named 49 minor girls, isn't it true that you tried to touch each of them in a sexual way? MR. BURMAN: Object to form, vaque and indefinite with regard to the alleged minor girls, last names weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the Palm Beach Reporting Service, Inc. (561)471-2995

64 United States Constitution. Q. (By Mr. Edwards) With respect to each of the 49 minor girls, isn't it true that you touched their bare breasts? MR. BURMAN: Object to form, vague and indefinite with regard to the alleged minor girls, last names weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. And I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) With respect to each of these 49 minor girls, isn't it true that you inserted your fingers into their vaginas? MR. BURMAN: Object to form of the question, vague and indefinite with regard to the alleged minor girls, last names weren't provided. Palm Beach Reporting Service, Inc. (561)471-2995

65 THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) With respect to the 49 named minor giris, isn't it true that you attempted to use vibrators on each of them? MR. BURMAN: Object to the form of the question, vague and indefinite with regard to the alleged minor girls, last names weren't provided. MR. EDWARDS: You can answer. THE WITNESS: JI intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Palm Beach Reporting Service, Inc. (561)471-2995

66 Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Pifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 20012 and 2005 did you have a woman named Nadia Marcinkova Living at your Palm Beach house with you? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Is it true that you considered Nadia Marcinkova your Yugoslavian lesbian sex slave? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to Palm Beach Reporting Service, Inc. (561)472-2995

\. 67 this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Can you tell me why it is that you just smiled when I asked you the last question about Nadia Marcinkova? MR. GOLDBERGER: Don't answer that. Q. (By Mr. Edwards) Did you think the question was funny? MR. BURMAN: Object to form. MR, GOLDBERGER: You can answer. TRE WITNESS: No. Q. (By Mr. Edwards) Do you know Nadia Marcinkova? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Palm Beach Reporting Service, Inc. (561)471-2995

68 Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Isn't it true that you brought Nadia into the room to have threesome sex with you and many of these minor female girls? MR. BURMAN: Object to the form of the question, vague and indefinite with regard to the word "may" and with regard to the fact that last names haven't been described, or disclosed. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert Federal Constitutional rights as guaranteed by the Pifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn't it true that you ejaculated in front of each of these minor girls? Palm Beach Reporting Service, Inc. (561)471-2995

69 MR. BURMAN: Object to form, vague and indefinite. Last names were not provided of the alleged minor girls. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) With respect to each of these 49 minor girls, isn't it true that you paid each of them for sex? MR. BURMAN: Object to the form, vague and indefinite. Last names of the many of the minor girls were not provided, alleged minor girls. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have Nes! counseled me that I cannot provide answers to Palm Beach Reporting Service, Inc. (561)471-2995

70 any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mx. Edwards) Isn't it true that you offered each of the 49 minor girls money if she would bring you more minor girls for you to engage in sex or sex acts with? MR. BURMAN: Object to the form, vague and indefinite. Last names of many of the alleged minor gixls weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the Palm Beach Reporting Service, Inc. (561) 471-2995

71 C United States Constitution. Q- (By Mr. Edwards) With respect to each of the 49 named minor girls, isn't it true that the sex or sex acts occurred in your bedroom? MR. BURMAN: Object to form of the question, vague and indefinite with regard to the alleged minor girls, the last names weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have c counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) With respect to each of these minor girls, isn't it true that certain other employees of yours played a role in furthering your sexual contact with these minors? MR. BURMAN: Object to the form of the ) question, vague and indefinite with regard to Palm Beach Reporting Service, Inc. (561)471-2995

72 the alleged minors, last names weren't provided. THE WITNESS: Could you repeat the question? Sorry. Q. (By Mr. Edwards) Sure. With respect to the 49 minor girls whose names I provided, isn't it true that certain employees of yours played a role in furthering sexual contact between you and these minors? MR. BURMAN: Same objection. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mx. Edwards) Some of your employees were delegated the responsibility of cleaning your sex toys after you engaged in sex with minor girls, isn't that true? Palm Beach Reporting Service, Inc. (561)471-2995

73 C MR. BURMAN: Are you referring to the 49 alleged minors that you just identified, or is this a generic question? MR. EDWARDS: Yes, the 49, that -THE WITNESS: Can you repeat the question please? MR. EDWARDS: ~~ are known to us. MR. BURMAN: Okay. Object to the form, vague and indefinite with regard to the alleged minors, last names weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn't it true that you hired employees to work for you for the sole purpose } J of scheduling minor girls to come to your house for sex? Palm Beach Reporting Service, Inc. (561) 471-2995

on Need? 74 MR. BURMAN: Once again, are you referring to the 49 you identified, or just generic? MR. EDWARDS: General question. MR. BURMAN: General question? MR. EDWARDS: Right. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I aasert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn't it true that you hired employees that were delegated responsibilities in order to assist you in avoiding detection of your actions by law enforcement? THE WITNESS: What's the question? MR. BURMAN: Object to the form, vague and indefinite. THE WITNESS: Could you repeat it again? MR. EDWARDS: Sure, I'll clean it up. Palm Beach Reporting Service, Inc. (562)471-2995

75 Q. (By Mr. Edwards) Isn't it true that you had employees working for you with a purpose of helping you to avoid detection of your criminal activities by law enforcement? MR. BURMAN: Object to form, vague an indefinite. THE WITNESS: I intend to respond to ali relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. {By Mr, Edwards) Did you have operable surveillance equipment inside your house from 2001 through 2006 in your Palm Beach house? MR. BURMAN: Objection, vague and indefinite. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at this present time my attorney has Palm Beach Reporting Service, Inc. (561) 471-2995

76 counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you destroy or tamper with evidence, including computer images, computer equipment, surveillance equipment, photos, notes, diaries, or photocopy records as a result of the criminal investigation of you between 2001 and 2006? MR, GOLDBERGER: Let me object on the form, Are you asking, are you suggesting that there is a criminal investigation that went on between 2001 and 2006? Is that the question? MR. EDWARDS: Well, at some time, at some point in time there was, since he pled guilty. MR. GOLDBERGER: But what's the purpose of the 2001 to 2006? Maybe you can rephrase the question. ny MR. EDWARDS: Okay. Q. (By Mx. Edwards) How about this. Have Palm Beach Reporting Service, Inc. (561) 471-2995

as a you ever at any time destroyed or tampered with any evidence of your involvement with minor girls? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot answer questions with respect to this lawsuit, and mst accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional Rights as guaranteed by the Pifth, Sixth, and Fourteenth Amendments to the United States Constitution. Q. Have you ever destroyed computer images or computer equipment because of a fear it would be used against you in a prosecution for your sexual involvement with minor girls? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Ime. (561)471~2995 77

78 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Did you ever, at any time, destroy photographs, notes, or diaries in an effort to avoid detection by law enforcement? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective xvepresentation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Did other people hired by you destroy or tamper with evidence in an effort to avoid detection of criminal activities or prosecution? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk Palm Beach Reporting Service, Inc. (561)471-2995

rc \. oat Neaatl 79 losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Was your house at some point in time in Palm Beach burglarized by a former housekeeper named Juan Allessee (phonetic)? A. Yes. Q. In relation to that burglary, did you provide the Palm Beach Police Department with surveillance video from the inside of your house? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. At the time your house was burglarized, Palm Beach Reporting Service, Inc. (561)471-2995

80 how many operable surveillance cameras were inside your house? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. How long have you been on work release? MR. GOLDBERGER: Hang on. Yeah, he can -that's fine. THE WITNESS: A little over six months. Q. (By Mr. Edwards) You know the date that you started work release? A. No. Q. If the court records indicate that your guilty plea occurred on June 30th, 2008, is that something you'd quarrel with? AY No. Q. How long did you, do you believe you were Palm Beach Reporting Service, Inc. (561)471-2995

81 in the county jail after that June 30th, 2008 plea before you were granted work release? MR. GOLDBERGER: If you know. THE WITNESS: Couple of months. Q. (By Mx. Edwards} Do you know if any of your victims were informed of your petition for work release? A. I do not know. Q. When was the Florida Science Foundation created? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Isn't it true that you created the Florida Science Foundation months before pleaing guilty knowing that you would eventually be on work release in an office right next to your attorney's office? Palm Beach Reporting Service, Inc. (561)471-2995

oy ah 82 MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mx, Edwards) Since being sentenced in of 2008, have you had contact with any minors? MR. GOLDBERGER: You can answer that. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the Palm Beach Reporting Service, Inc. (561)471-2995

~ Nae’ 83 constitution. Q. (By Mr. Edwards) Do you currently have access to a computer that you use? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my Sixth Amendment right to effective representation, Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. What is e-mail address that you have been using since being sentenced in 2008? MR. GOLDBERGER: Object to the form, assumes facts not in evidence. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561) 471-2995

ro 84 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mx. Edwards) Do you intend to communicate with any minors once you are released to house arrest? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provided answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Is it true that you have been diagnosed by a psychologist with a sexual disorder related to your sexual appetite for minor girls? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk Palm Beach Reporting Service, Inc. (561) 471-2995

85 losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. Isn't it true that you intend to continue engaging in sex acts with minor girls once you are released? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Have you engaged in sex or sex acts with minor girls outside of the United States? A. I intend to respond to all relevant v questions regarding this lawsuit. However, at the Palm Beach Reporting Service, Inc. (561) 471~2995

86 present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Is it true that you have your own island? MR. BURMAN: Object, also on the, on the grounds that the punitive damages haven't been ob & allowed yet. Not relevant. MR. EDWARDS: Answer. THE WETNESS: J. intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights under the Fifth, Sixth, e 23 and Fourteenth Amendment to the United States Constitution, Palm Beach Reporting Service, Inc. (561)471-2995

87 Q. (By Mr. Edwards) Have you engaged in sex or sex acts with minors on the island of Little St. Jeff's? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relative to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Isn't it true that you have engaged in sexual acts or sex with girls as young as 12 years old? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471-2995

88 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. What is the youngest girl that you have engaged in sex or sex acts with in the last ten years? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert under the Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. Have you discussed with any of your friends the fact that you engage in sex or sex acts with minors? aA. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk Palm Beach Reporting Service, Inc. (561)471-2995

89 losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Did you know that the girls that were providing you massages were under the age of 18 at the time they were doing so? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution, Q. Isn't it true that the age group that you enjoy to engage in sex with is between 12 and 16 years old? MR. BURMAN: Object to form. THE WITNESS: I intend to respond to all Palm Beach Reporting Service, Inc. (561)471-~2995

30 relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution, Q. (By Mr. Edwards) Do you agree with the laws that prohibit you from having sex or engaging in sex acts with minors? MR. BURMAN: Object to form. THE WITNESS: Can you repeat the question? Q. (By Mr. Edwards) Do you agree with the laws that prohibit you from engaging in sex or sex acts with minor girls? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Palm Beach Reporting Service, Inc. (561)471-2995

91 Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Ien't it true that you devised a scheme or plan to engage in sex or sex acts with multiple minor girls? A. i intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I must assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. THE WITNESS: Can I take a pee break? THE VIDEOGRAPHER: We're off the record at 11:50. This will be the end of tape one. (Thereupon, a brief break was taken.) THE VIDEOGRAPHER: This is the beginning of tape number two, and we're back on the Palm Beach Reporting Service, Inc. (561) 471-2995

92 record at 11:59. Q. (By Mr. Edwards) Between 2001 and 2005 did you digitally penetrate the vaginas of more than 50 minor girls? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk lesing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the constitution. Q. Between 2001 and 2005 did you masturbate in front of more than $0 minor girls? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Palm Beach Reporting Service, Inc. (561)471-2995

= 3 93 Sixth and Fourteenth Amendment to the constitution. Q. Between 2001 and 2005 did you ejaculate in front of more than 50 minor girls? A. Tt intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Does the body form of a 12 to 16 year old girl sexually appeal to you? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all xelevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471-2995

cat 94 Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Did you use your wealth, power, and connections to impress or influence minor girls into having sex with you? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Did you intentionally target economically deprived children for the purposes of having sex or engaging in sex acts with? A. Do you want to rephrase the question? Q. Did you intentionally target economically deprived children for the purposes of sex? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the Palm Beach Reporting Service, Inc. (561)471-2995

95 present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. During the criminal investigation there were statements to the media that you believed the girls to be 18. Which girls were you referring to? A. I intend to -THE WITNESS: Excuse me one second. (Thereupon, a discussion was had off the record.) MR. GOLDBERGER: Umm, let me object to the form as to vague. I don't know what statements you're talking about. Are you talking about statements that Mr. Epstein made? MR. EDWARDS: Through attorneys. MR. GOLDBERGER: Well, is that the question? Why don't you rephrase the question, why don't you rephrase the question so we understand what it is. Palm Beach Reporting Service, Inc. (561)471-2995

om Q- {By Mr. Edwards) Various attorneys of yours made representations to the media that you were of, under the belief that the girls that you were engaging in sex acts with were 18 years of age. Which girls were you, was that referring to? MR. GOLDBERGER: Can you identify a specific statement made by a specific attorney? MR. EDWARDS: We'll get there later on in the deposition. Q. (By Mx. Edwards) Have you ever, at any time, made that statement, that you believed the girls that you were engaging in sex acts with were 18 years of age or older? MR. GOLDBERGER: To the media, are you talking about? Q. (By Mr. Edwards) Yourself or through anyone else to anyone else. MR. GOLDBERGER: Object to the -that's -MR. BURMAN: Object to the form. MR. GOLDBERGER: I have no idea what the question is. Just ask the question, I'll be happy to try and have the client answer it for you. Q. (By Mr. Edwards) Okay. I'm not talking Palm Beach Reporting Service, Inc. (561)471~2995 96

rs about statements to your attorneys, that's privileged. Have you ever made the statement to anyone else, other than your attorneys, that you believed the girls that were giving you massages at your house were over the age of 187 aA. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Between 2001 and 2005 did you pay any females for sex? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective Palm Beach Reporting Service, Inc. (561) 471-2995 97

38 representation. Accordingly, I assert Federal Constitutional rights under the Pifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Between 2001 and 2005 did you tell minor female girls at your house that you prefer to engage in sexual activities with minors? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Is it true that many of the 49 minor giris previously named told you that they were under the age of 15 at the time you were engaging in sex acts with them? MR. BURMAN: Object to form of the question, vague and indefinite to the extent Palm Beach Reporting Service, Inc. (561)471-2995

939 that the alleged minor girls' last names weren't provided. YHE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, to the present time, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice er risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mx. Edwards) How did the minor girls previously named in this deposition arrive to your mansion between 2001 and 2005? MR. BURMAN: Objection, vague and indefinite. MR. GOLDBERGER: And it's, it's vague and indefinite, but to assist in answering the question, can you tell us what mansion you're talking about? os MR. EDWARDS: Paim Beach mansion. THE WITNESS: Can you repeat the question? Palm Beach Reporting Service, Inc. (S61)471-2995

100 Q. (By Mr. Edwards) How did they arrive at your house? A. "They" arrive? Q. How did any of the minor girls whose names I named previously in this deposition arrive to your house? MR. BURMAN: Object to the form of the question, vague and indefinite to the extent that the alleged minor girls' last names weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, that I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Many of the minor girls named previously in this deposition did not drive a car to your house or have a driver's license, isn't that true? Palm Beach Reporting Service, Inc. (561)471-2995

101 MR. BURMAN: Object to form of the question, vague and indefinite to the extent ‘ that the alleged minor girls' last names weren't provided. THE WITNESS: You have to repeat the question, again. Sorry. Q. (By Mr. Edwards) Isn't it true that many of the minor girls previously named in this deposition did not drive a car or have driver's licenses? MR. BURMAN: Same objection. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and fT must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Is it true that you discussed with many of these girls the fact that they were in middle school or high school at the Palm Beach Reporting Service, Inc. (561)471-2995

time they were engaging in sex acts with you at your house? MR. BURMAN: Are you referring to the previous 49? MR. EDWARDS: Yes. MR. BURMAN: Okay. Object to form of the question, vague and indefinite to the extent that the names, the last names of many of the alleged minor girls weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. Rowever, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr, Edwards) Did any of the girls that engaged in sex acts with you at your house between 2001 and 2005 tell you that they were in middle school or high school? A. Sorry, repeat the question. Palm Beach Reporting Service, Inc. (561)471~2995 102

103 BURMAN: Are you talking about the 49? EDWARDS: No. BURMAN: No. Q. (By Mr. Edwards) Did any minor girls that engaged in sex or sex acts with you between the years of 2002 and 2005 at your house tell you that they were in middle school or high school at the time? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. MR. EDWARDS: Okay. What time do you want to break for lunch? MR. GOLDBERGER: 1:00. WITNESS: 1:15? GOLDBERGER: Yeah, 1:15. Palm Beach Reporting Service, Inc. (561)471-2995

okay? MR. EDWARDS: Yeah, that's fine with me. What time do we have now? THE WITNESS: It will be another hour. (Thereupon, a discussion was had off the record.) Q. {By Mr. Edwards) Did you ever discuss with any minor girls at your house that you would pay them to bring you other minor girls for the purposes of sex? MR. BURMAN: Object to the form. fs THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q- (By Mr. Edwards) Did you tell any of the 3 minor girls that were at your house for sex that you preferred pure, young girls for sex? Palm Beach Reporting Service, Inc. (561)471-2995 104

x g 105 MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. {By Mr. Edwards) Did you tell any of the minor girls at your house between 2001 and 2005 that you do not like girls that have tattoos? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Palm Beach Reporting Service, Inc. (561)471-2995

106 Fifth, Sixth, and Fourteenth Amendment of the constitution, Q. (By Mr. Edwards) Did you tell any of the minor girls that were at your house not to bring you any girls that were pregnant or had babies? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Pourteenth Amendment to the constitution? Q. (By Mr. Edwards) Did you specifically instruct any of the minor girls not to bring you any black girls? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to Palm Beach Reporting Service, Inc. (561}471-2995

107 any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment of the constitution. Q. {By Mr. Edwards) Isn't it true that you did not like to have sex or engage in sex acts with black girls? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to ail relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that. I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment. Q. (By Mr. Edwards) Isn't it true that black girls were brought to your house and you turned them away at the door because you do not like black girls? Palm Beach Reporting Service, Inc. (561)471-2995

eS 108 MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the constitution, Q. (By Mr. Edwards) Isn't it true that you also turned away girls because they were 18 years or older and too old for you? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert. Federal Constitutional rights as guaranteed by the Palm Beach Reporting Service, Inc. (561)471-2995

109 Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn't it true that you also turned away minor girls with tattoos because you did not feel that they were pure? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Is it true that your specific instructions were, to these minor girls, to bring you white girls between the ages of 12 and 17 that were not pregnant, did not have babies, and did not have tattoos? MR. BURMAN: Object to the form. a D THE WITNESS: f intend to respond to all relevant questions regarding this lawsuit. Palm Beach Reporting Service, Inc. (561)471-2995

110 However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Is it true that you offered each minor girl approximately $200 in cash for sex? MR. BURMAN: Object to the form. Are you back on the 49, or is this generic? MR. EDWARDS: No, generic. THE WITNESS: Would you repeat the question? Q. {By Mr. Edwards) Between 2001 and 2005 isn't it true that you offered each minor girl that came to your house for sex $200 for that sex? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to Palm Beach Reporting Service, Inc. (561)471-2995

J 122 any questions relevant to this lawsuit, and I must. accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution, Q. (By Mr. Edwards) Why did you laugh about last question? 10 MR. BURMAN: Object to the form. I have a stomachache at the 11 THE WITNESS: 12 moment. I wasn't laughing. 13 Q. (By Mr. Edwards) Isn't it true that you 14 targeted young, economically deprived kids with 15 little or no parental guidance? 16 MR. BURMAN: Object to the form. THE WITNESS: You have to repeat the 17 18 question. 19 Q. (By Mr. Edwards) Isn't it true that you 20} were targeting young, economically deprived minor 21} girls with little or no parental guidance? 22 MR. BURMAN: Object to the form, 23 (By Mx. Edwards) For sex. Q. 24 A. I intend to respond to all relevant 2s questions regarding this lawsuit. However, at the Palm Beach Reporting Service, Inc. (561)471-2995

112 present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Have you ever told anybody that the girls were over at your house because you just like massages? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannet provide answers to any questions relevant te this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn't it true that none Palm Beach Reporting Service, Inc. (561)471-2995

113 of these minor girls that you engaged in sex acts with at your house had any massage experience? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all velevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you ever have a professional masseuse give you a massage at your house in Palm Beach? A. t intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective xepresentation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471-2995

114 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Constitution. Qo. In fact, when these minor girls would tell you they had no massage experience, didn't you respond by telling them that that is actually better for you? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I mist accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Did you tell these minor girls to get naked and touch you so that you could get off? MR. BURMAN: Object to the form. THE WITNESS: What? What's -- repeat the question. Palm Beach Reporting Service, Inc. (561) 471-2995

115 Neg Q. (8y Mr. Edwards) Did you tell these minor girls between 2001 and 2005 at your Palm Beach mansion to get naked and touch you so that you could get off? off? GOLDBERGER: Are you asking him if statement that was made? EDWARDS: Yes, to these giris. BURMAN: Object to the form. WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and T must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as quaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Bdwards) Will you agree that you exchanged money for sexual gratification with at least 50 girls at your Palm Beach mansion between 2001 and 2005? MR. BURMAN: Object to the form. Palm Beach Reporting Service, Inc. (561)471~2995

116 THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me not to provide answers to any questions relevant to this lawsuit, and I must aceept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Bdwards) Between 2001 and 2005 you never ordered a professional escort to come to your house for sex, did you? A. Rephrase the question, please. Q. Between 2001 and 2005 you never ordered from an escort service in Palm Beach County for a professional escort to come to your house for sex, did you? A. You never ordered? THE WITNESS: Do I answer the question? MR. GOLDBERGER: You don't understand. Rephrase it. ) Q. (By Mr. Edwards) Did you ever call an escort service to have an escort sent to your house Palm Beach Reporting Service, Inc. (561)471-2995

117 in Palm Beach for sex? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I camot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. You did not call a professional escort because that would likely result in a girl over the age of 18 coming to your house for sex, right? MR. BURMAN; Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Palm Beach Reporting Service, Inc. (561)471-2995

\ecce# 118 Fifth, Sixth, and Fourteenth Amendment of the constitution. : Q. (By Mr. Edwards) Do you enjoy coercing minors into sex acts with you? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Do you know Sarah Kellen? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Palm Beach Reporting Service, Inc. (561)471-2995

oo MO 119 Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. Did you instruct her to assist you in gaining access to minor girls for sex? aA. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Did you instruct any other employees of yours to assist you in gaining access to minors for Bex? aA. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective Palm Beach Reporting Service, Inc. (561)471-2995

“ 120 representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, sixth, and Fourteenth Amendment to the United States Constitution. Q. What people were living with you in your Palm Beach mansion between 2001 and 2005? MR. GOLDBERGER: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you meet with people employed by you to discuss a plan to gain access to minor girls for the purposes of sex? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I Palm Beach Reporting Service, Inc. (561)471-2995

c \ Sy? 121 cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Which employees did you discuss your plan to gain access to minor girls for the purposes of sex? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth; and Fourteenth Amendment to the United States Constitution. Q. Is it true that you have many people working in your house in Palm Beach County, or did, between the years 2001 and 2005? Palm Beach Reporting Service, Inc. (561)471-2995

122 A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk lesing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution, Q. How many employees work in the various houses that you own right now? A. That's -- that question is owned right now? I don't understand the question. Q. Well, it's my understanding that you own mumerous properties. I just want to know how many people are actually paid by you or employed by you that work and/or live in those homes? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective Palm Beach Reporting Service, Inc. (561)471-2995

123 representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Constitution. Q. Did you ever personally procure a, or sorry, strike that. Did you ever personally go out and recruit a minor girl to bring back to your house for sex? THE WITNESS: Object to form, no? MR. BURMAN: Object to form. THE WITNESS: I intend to respond to all relevant questions regarding -MR. EDWARDS: I'm sorry, is there something you don't understand about the question? If you don't, I'11 rephrase it. MR. GOLDBERGER: We objected to the form, now you can answer. MR. EDWARDS: I thought he objected to the form, that's why I was -MR. GOLDBERGER: He asked -- I'm not -Brad, he asked his lawyer a question, that's all. We objected to the form, that's fine. BDWARDS: Okay. GOLDBERGER: Go ahead and answer. Palm Beach Reporting Service, Inc. (561)471-2995

Se. 124 THE WITNESS: JI intend to respond to ail relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution. Q. (By Mr. Edwards) Who is the first minor that you brought to your house for sex? MR. BURMAN: Object to the form. TRE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Pourteenth Amendment to the United States Constitution. Palm Beach Reporting Service, Inc. (561)471-2995

wd 125 Q. {By Mr. Edwards) Have you had sex with 100 minor girls in the last ten years? MR. BURMAN: Object to the form. HE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation, Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwardes) When did you devise your to gain access to minor girls for sex? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and TI Must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471-2995

126 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) With whom did you meet to discuss your plan to gain access to minor girls for sex? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Do you agree that you have a criminal enterprise that is comprised of, at the very least, yourself, Sarah Kellen, and Nadia Marcinkova who have the common goal of bringing minors to you for the purposes of sex? eg MR. BURMAN: Object to the form. THE WITNESS: I intend to respond te all Palm Beach Reporting Service, Inc. (561) 471-2995

127 . N a relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I Must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. {By Mr. Edwards) Was the target age range for your criminal enterprise always minors between the ages of 12 and 16? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the () Fifth, Sixth, and Fourteenth Amendments to the United States Constitution. Palm Beach Reporting Service, Inc. (561) 471-2995

128 Q. (By Mr. Edwards) What are the names of all of the members of your criminal enterprise that has the common goal of procuring minors for the purposes of sex? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment to effective representation. wed! Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) In addition to paying each of these minor girls approximately $200 for sex, did you also provide transportation for them to and from your house? MR. BURMAN: Are we generic, going with the 49? MR. EDWARDS: Generic. 3 MR. BURMAN: Generic? Okay. Object to Palm Beach Reporting Service, Inc. (561}471-2995

129 THE WITNESS: You have to repeat the question, I'm sorry. Q. (By Mr. Edwards) In addition to paying minor girls approximately $200 to engage in sex or sex acts with them, did you also provide transportation for these minor girls to and from your house? MR. BURMAN: Same objection. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide any answers relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Aecordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you, one of your employees, or someone within your enterprise have an account with Yellow Cab for the purposes of transporting minors to and from your house? } MR. BURMAN: Object to form. MR. GOLDBERGER: Do you understand the Palm Beach Reporting Service, Inc. (561) 471-2995

130 question when he says "enterprise"? Do you have any idea what he means? THE WITNESS: No. MR. GOLDBERGER: Can you define enterprise, so we can determine whether we need to answer the question. MR. EDWARDS; .I‘m talking about persons involved with a common goal. We have defined this earlier. MR. GOLDBERGER: I'm sorry, I was out of the room did you define it? EDWARDS: You were out of the room. GOLDBERGER; Okay. EDWARDS: And persons, we defined it as, at the very least, Mr. Epstein, Sarah Kellen and Nadia Marcinkova having the common goal of bringing minors to and from the Palm Beach house for the purposes of sex. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and f must accept this advice or risk losing my Sixth Amendment right to effective representation. Palm Beach Reporting Service, Inc. (561)471~2995

131 Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution, Sorry, can we take a break again? Bathroom break. MR. EDWARDS: Let's just break for lunch then. MR. GOLDBERGER: I can't, because I've got -- there's a reason why, I've got a commitment at 1:15, so -THE VIDEOGRAPHER: Off the record at 12:40. (Thereupon, a discussion was had off the record.) (Thereupon, a brief break was taken.) THE VIDEOGRAPHER: Back on the record at 12:54. Q. (By Mr. Edwards) Between 2001 and 2005 did you or any of your employees or assistants have an account with Yellow Cab? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the i) present time my attorneys have counseled me that f cannot provide answers to any questions relevant to Palm Beach Reporting Service, Inc. (561)471-2995

132 this lawsuit, and I must accept their advice or cvisk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Are you currently actually a billionaire? MR. BURMAN; Objection. That goes to punitive damages, and I object. THE WITNESS: 1 intend to respond to all relevant questions regarding this lawsuit. a However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to thig lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. MR. BURMAN: And I should add for the record that I would instruct him not to answer that question, even if he wasn't invoking the Fifth. Palm Beach Reporting Service, Inc. (561)471-2995

133 ey Q. (By Mr. Edwards) Between 2001 and 2005 you a billionaire? MR. BURMAN: Objection, instruct you not to answer that question based on the fact that that's directed toward punitive damages, and that has not been allowed to file, be filed, or proceeded with in the state court action. You should read that, as well. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. {By Mr. Edwards) Between 2001 and 2005 what types of cars did you have that you owned, parked in your driveway at your Palm Beach mansion? MR. BURMAN: Object, once again on the Neal grounds that punitive damages have not been Palm Beach Reporting Service, Inc. (561)471-2995

134 a approved yet in this case. JI instruct him not to answer that question. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Is your house in Palm Beach located on the water? THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights under the Fifth, Sixth, ‘2 and Fourteenth Amendment to the constitution. Paim Beach Reporting Service, Inc. (561) 471-2995

135 Q. (By Mr. Edwards) What is the square footage of youx house in Palm Beach? MR. BURMAN: Object, on the grounds that that question, in part, delves into his financial situation, which has not been approved to be explored in this case yet, because punitive damages have not been approved or allowed to be proceeded with here, and I instruct him not to answer the question. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept his advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mx. Edwards) Did you tell the minor girls that were at your house that you were extremely wealthy between 2001 and 2005? i J MR. GOLDBERGER: Object to the form. THE WITNESS: I intend to respond to all Palm Beach Reporting Service, Inc. (561)471-2995

136 relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you talk to the minor girls that were at your house between 2001 and 2005 about all of the houses and cars that you owned? MR. BURMAN: Object to the form. YHE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the Palm Beach Reporting Service, Inc. (561)471-2995

137 United States Constitution. Q. (By Mr. Edwards) Did you use your wealth and the minors lack thereof to influence that minor to have sex with you? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. {By Mr. Edwards) After you ejaculated in front of minor girls, did you tell each one of them that every time she came to your house for sex, you would pay her $200 cash? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to Palm Beach Reporting Service, Inc. (561)471-2995

138 ( : any questions relevant to this lawsuit, and I mast accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Was it your plan to groom each minor girl to be your personal sex slave? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this right or risk losing my Sixth Amendment right to effective representation? Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you impress upon each minor girl that what she was doing with you f ¥ sexually was morally right? MR. BURMAN: Object to the form. Palm Beach Reporting Service, Inc. (561)471-2995

139 THE WITNESS: I intend to respond to ail relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the 10 Pifth, Sixth, and Fourteenth Amendments to the 11 United States Constitution. 12 Q. (By Mz. Edwards) Was it part of your plan 413 to display your wealth and power in an effort to 14] gain sexual access to minor girls? 15 MR. BURMAN: Object to the form. 16 THE WITNESS: I intend to respond to all 1? relevant questions regarding this lawsuit. 18 However, at the present time my attorneys have 19 counseled me that I cannot provide answers to 20 any questions relevant to this lawsuit, and I 21 must accept the advice or risk losing my Sixth 22 Amendment right to effective representation. 23 Accordingly, I assert my Federal 24 Constitutional rights as guaranteed by the 25 Fifth, Sixth, and Fourteenth Amendment to the Palm Beach Reporting Service, Inc. (561)471-2995

i 140 United States Constitution. Q. (By Mr. Edwards) Did you intentionally target very poor minor girls because you knew that demographic would be the most impressed by your wealth and likely listen to you? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mx. Edwards) None of the minor girls that you engaged in sex or sex acts with had ever engaged in prostitution prior to meeting you, isn't that correct? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have Palm Beach Reporting Service, Inc. (561) 471-2995

141 counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. {By Mr. Edwards) Isn't it true that you corrupted and injured minor girls for your own sexual gratification? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn't it true that you Nad typically engaged in sex or sex acts with minor Palm Beach Reporting Service, Inc. (561)471-2995

142 girls three or four times each day at your Palm Beach mansion? MR. BURMAN: Object to the form. {HE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn't it true that you in, that you coerced minor girls into prostitution? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471-2995

( 143 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment in the United States Constitution. Q. (By Mr. Edwards) Isn't it true that you and your employees, including Sarah Kellen, called these minor girls to encourage them to bring more minor girls to you for sex. By called I mean on the telephone? MR. BURMAN: Object to the form. THE WITNESS: Can you repeat the question? Q. (By Mr. Edwards) Isn't it true that you and your assistants or employees, including Sarah Kellen, called minor girls on the telephone to encourage them or command that they bring you other minor girls for sex? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Palm Beach Reporting Service, Inc. (561)471-2995

144 Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) What are all the telephone numbers assigned to you or your Palm Beach mansion between 2001 and 2005? A. Again? Q. What were all of the telephone numbers assigned to you or your Palm Beach mansion between 2001 and 2005? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Who scheduled your massage appointments between 2002 and 2005? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I Palm Beach Reporting Service, Inc. (561)471-2995

145 cannot provide answers to any questions relevant to a 3 this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. THE WITNESS: Excuse me? Accordingly I assert my Federal Constitutional rights as guaranteed by the Pifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. {By Mr. Edwards) Is it true that you were ejaculating in front of three or four minor girls per day between 2002 and 2005 at your Palm Beach mansion? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Palm Beach Reporting Service, Inc. (561)471-2995

2 146 Q. (By Mr. Edwards) Have you ever treated with any doctors or physicians and discussed sexual issues with them? THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you and your assistants or employees use the word work, W-O-R-K, to describe you engaging in sex acts with minors at your house? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Palm Beach Reporting Service, Inc. (561)471-2995

147 Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Did you rely on Sarah Kellen and your other assistants to properly schedule these minor girls in a way so that they would not come in contact with one another? MR. BURMAN: Object to form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any guestions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment Right to effective representation. So, accordingly, I assert my Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendments to the United States Constitution. MR. EDWARDS: Ready to break? MR. GOLDBERGER: He wants to eat. i 5 THE VIDEOGRAPHER: We're off the record at Palm Beach Reporting Service, Inc. (561)471-2995

148 (Thereupon, a lunch break was taken from 1:12 to 2:32 p.m.) THE VIDEOGRAPHER: We're back on record at MR. EDWARDS: Ready? MR. GOLDBERGER: Sure. Q. (By Mr. Edwards) Mr. Epstein, did you ever care about any of the feelings of the minor girls that you were engaging in sex with? MR. BURMAN: Object to the form. THE WITNESS: JI intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit at this time, so I must accept their advice or I lose potential -- I risk losing my Sixth Amendment right to effective representation. And accordingly, I have to assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did it ever occur to you that any of these girls were somebody's daughter -MR. BURMAN: Object to the form. Palm Beach Reporting Service, Inc. (561)471-2995

Py 149 Q. (By Mr. Edwards) -- when you were engaging in sex with them? MR. BURMAN: Object to the form of the question. THE VIDEOGRAPHER: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to these questions, as I have to accept their 10 advice or risk losing my Sixth Amendment right il to effective representation, Brad. THE WITNESS: Is it okay if I call you 12 13 Brad? You can continue. MR. EDWARDS: 14 15 {THE WITNESS: And, accordingly, I assert 16 my Federal Constitutional rights as guaranteed 17 by the Fifth, Sixth and Fourteenth Amendment to 18 the United States Constitution. 19 Q. (By Mx. Edwards) When you were digitally 20} penetrating these minor girls, did you care about 21} the fact that you were emotionally or 22] psychologically hurting them? 23 MR, BURMAN: Object to the form of the 24 question. 25 THE WITNESS: I intend to respond to alli Paim Beach Reporting Service, Inc. (561)471-2995

150 relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution. Q. (By Mr. Edwards) We have heard over and over again that you intend to respond to this. When do you intend to respond to these questions? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time on advice of counsel I cannot provide answers to those questions at this time. I must accept advice of my counsel or risk losing my Sixth Amendment vight to effective representation. Accordingly, I'1] have to assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Palm Beach Reporting Service, Inc. (561)471-2995

151 Q. (By Mr. Edwards) Isn't it true that at the time that you were sexually battering these minor girls, you didn't care what happened to them and only cared about your only personal sexual gratification? MR. BURMAN: Object to the form. We need to talk outside. THE WITNESS: Me, too? THE VIDEOGRAPHER: We're off the record at 2:35. (Thereupon, a brief break was taken.) THE VIDEOGRAPHER: We're back on the record at 2:36. MR. BURMAN: For the purposes of the record, I will tell you that this line of questioning, in my view, is way beyond the bounds of permissible discovery-type questions, and nothing but pure argument, and if you continue in this vein, I will stop the deposition and we will seek instruction from Judge Hafele about what's permissible and what's not. Q. {By Mr. Edwards) Isn't it true that at 4 the time you were inserting your fingers into the vagina of these little kids, all you cared about was Palm Beach Reporting Service, Inc. (561)471-2995

152 your own sexual gratification? MR. BURMAN: The deposition is over. THE VIDEOGRAPHER: Conclude at 2:37, end of tape 2 of 2. MR. BERGER: We're going to order instant copy, and we want the tape, also, Mr. Videographer. MR. BURMAN: We want this as soon as they get theirs, we want ours. (Thereupon, the deposition was adjourned at 2:38 p.m.) Neos Palm Beach Reporting Service, Inc. (561)471-2995

153 CERTIFICATE OF OATH STATE OF PLORIDA } i : SS COUNTY OF PALM BEACH } I, the undersigned authority, certify that WinssS oS personally appeared before me and was duly sworn. WITNESS my hand and official seal this SOR day of WORKER, 2009. LINDA P. AUKAMP, RPR Commission No.: DD 499271 Notary Public - State of Florida My Commission Expires: 12-26-09 Palm Beach Reporting Service, Inc. (561)471-2995

154 REPORTER'S DEPOSITION CERTIFICATE STATE OF FLORIDA ) : SS ) COUNTY OF PALM BEACH I, LINDA P. AUKAMP, a Registered Professional Reporter, certify that I was authorized to and did stenographically report the deposition of WORRESS A i; that a review of the transcript was requested; and that the transcript is a true and complete record of my stenographic notes. I FURTHER CERTIFY that on the “59% day of I notified q ‘ “2 that the deposition of GUENESS Cote eNt was ready for reading and signing by the witness. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 2 is 4 Palm Beach Reporting Service, Inc, (561)471-2995

155 ; { LINDA P. AUKAMP, RPR Palm Beach Reporting Service, Inc. (561)471-2995

153 CERTIFICATE OF OATH STATE OF FLORIDA ) : SS COUNTY OF PALM BEACH )} I, the undersigned authority, certify that JEFFREY EPSTEIN personally appeared before me and was duly sworn. WITNESS my hand and official seal this 1st day of May, 2009. Prrdea. Polia_p LINDA P. AUKAMP, RPR Commission No.: DD 499271 Notary Public - State of Florida My Commission Expires: 12-26-09 oS E AORN rents ese Cornmission # DD 499271 forded By Nations! ‘Notary Assn. Palm Beach Reporting Service, Inc. (561)471~-2995

154 REPORTER'S DEPOSITION CERTIFICATE STATE OF FLORIDA ) : SS COUNTY OF PALM BEACH ) I, LINDA P. AUKAMP, a Registered Professional Reporter, certify that I was authorized to and did stenographically report the deposition of JEFFREY EPSTEIN; that a review of the transcript was requested; and that the transcript is a true and complete record of my stenographic notes. I FURTHER CERTIFY that on the 1st day of May, 2009, I notified JOHN MICHAEL BURMAN, ESQUIRE that the deposition of JEFFREY EPSTEIN was ready for reading and signing by the witness. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this ist day of May, 2009. Ards. Pole p LINDA P. AUKAMP, RPR Palm Beach Reporting Service, Inc. (561)471-2995

-™~, 155 JEFFREY EPSTEIN c/o JOHN MICHAEL BURMAN, ESQUIRE 515 North Flagler Drive, Suite 400 West Palm Beach, Florida 33401 RE: E.W. vs. JEFFREY EPSTEIN and SARAH KELLEN At the conclusion of your deposition given in the above-styled cause you indicated you wished to read and sign the transcript. This letter is to advise you that your deposition is ready, and we ask that you call our office at (561) 471-2995 at your earliest convenience for an appointment to come in. If you are a party in this action and your attorney has ordered a copy of this transcript, you may wish to read his copy and forward to us a photostatic copy of your signed correction sheet. It is necessary that you do this as soon as possible, since the transcript cannot be held beyond two weeks from the date of this letter. If you have any reason which you would like for me to place on your deposition as to your failure to sign the same, please advise. Thank you for your prompt attention. Very truly yours, PALM BEACH REPORTING SERVICE, INC. 1665 Palm Beach Lakes Blvd., Suite 1001 West Palm Beach, Florida 33401 BY: LINDA P. AUKAMP, RPR Date: May lst, 2009 Palm Beach Reporting Service, Inc. (561)471-2995

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 11

Page 16 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT --IN AND FOR PALM BEACH COUNTY, FLORIDA INDEX CASE No. 562008CA037319XXXXMB AB WITNESS: DIRECT CROSS REDIRECT RECROSS JEFFREY EPSTEIN BY MR. KUVIN 2b BB, Plaintiff, vee ‘ EXHIBITS JEFFREY EPSTEIN, NUMBER DESCRIPTION Defendant. PLAINTIFF'S EX,1_ FDLE SEXUAL OFFENDER/PREDATOR FLYER PLAINTIFF'S EX.2. STATEMENT 25 PI EX.3. PHOTOGRAPH HOME 33 CONTINUED DEPOSITION OF JEFFREY EPSTEIN ee Te ROUTE ORIGVAETLY: 38 NE PLAINTIFF'S EX.5 PHOTOGRAPH OF GIRL — 129 PLAINTIFF'S EX.6 PHOTOGRAPH OF GIRL — 129 Thimeday, Ocipber 8, 2009 PLAINTIFF'S EX.7 PHOTOGRAPHOFGIRL = 131 10:07 « 1:08 pan. PLAINTIFF'S EX.8 PHOTOGRAPH OF GIRL 132 250 South Australian Avenue Suite 1400 ‘West Palin Beach, Florida 33401 Reported By: Jeana Ricciuti, RPR, FPR, CLR. Notary Public, State of Florida Prose Court Reporting Agency, Inc. Page 19 Oba he Plante PROCEEDINGS ‘SPENCER T. KUVIN, ESQUIRE wee ADAM LANGINO, ESQUIRE a ee LEOPOLD KUVIN, Pe Deposition taken before Jeana Ricciuti, Registered 2 Raw Boulevard Professional Reporter and Notary Public in and for the par pcp ig Florida 33410 State of Florida at Large, in the above cause. foe ee ee THE VIDEOGRAPHER: We're on the video record. ET ey ADLER This is the 8th day of October, 2009, and the time OLB Lee Ol Pouleeeet it approximately 10:07 a.m. foe Lauderdale Flin 33301 This is the continuation of the videotaped ‘On behalf of Plaintiff Jane Dee in Case No. 80591 and. deposition of Jeffrey Epstein in the matter of B.B. ae InN W, EZELL, ESQUIRE versus Epstein, This deposition is being held at Comeea 250 South Australian Avenue, No. 1400 in West Palm Miami, Florida 33430 Beach, Florida. Con beni othe Defoe My name is Dan Doskey. I'm the videographer amen representing Visual Evidence, Incorporated. AISERBURY, COLOBRGER & WEISS, P. ‘ RY, PA 250 South Austalion Avenue Would the attorneys present please announce Suite 1400 i ‘West Patty Beach, Florida 33401 their appearances for the record? : Phone: 561 659.9300 MR. KUVIN: Spencer Kuvin and Adam Langino on MICHARL J, PIKE, ESQUIRE behalf of the Plaintiff, B.B. BURMAN, CRITTON, LUTTIER & COLEMAN, P.A. 4 303 Boryan Bouleverd MS. HOLMES: Cara Holmes for L.M. Suite 400 . MR. PIKE: Michaet Pike on behatf of ‘West Palm Beach, Posida 33401 : Rone: o6l 342.2820 Jeficey Epstein. SAN DOSREY, VIDEOORAPHER MR, GOLDBERGER: And Jack Goldberger on behalf VISUAL EVIDENCE, INC. of Jeff Epstein. 1 (Pages 16 to 19) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Riccluti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) adtcaced-2433-45cb-bh$a2-c0B425262f79

Page 20 Page 22 1 Kathy, do you want to identify yourself? i A. Correct. 2 Kathy, are you there? 2 Q. Mr. Epstein, on January 30th of 2008, isn't it 3 MS, EZELL: Yes. 3 true that you pled guilty to procuring a person under E 4 MR. PIKE: She puts it on mute every once ina 4 the age of 18 for prostitution? 5 while, 5 A. No, 6 MR. GOLDBERGER: Hey, Kathy, are you there?! 6 Q. You did not plead guilty? e 7 MS. EZELL: Yes. 7 A. You asked me -- do you want to repeat it? 8 MR. GOLDBERGER: Just ~ we're just 8 Q. Did you plead guilty to procuring a person. 9 identifying everyone who's on this thing. Can you 2 under the age of 18 for prostitution? } 10 just identify yourself? 10 A. On what date? iL MS. EZELL: Yes. It's Kathy Bzeil. I'm ii Q. Regardless of the date, did you plead guilty sorry, Kathy Ezell is here. 12 to procuring a person under the age of 18 for --e 13 prostitution? : 14 Thereupon, 14 MR. GOLDBERGER: Do you need to take a break? 15 (JEFFREY EPSTEIN) 15 MR. KUVIN: Pm sorry, what are we doing? 16 having been first duly sworn or affirmed, was examined | 16 MR. GOLDBERGER: I'm taking a break to talkto ff 17 and testified as follows: 17 my client, i 18 THE WITNESS: Yes, ma'am. 18 MR. KUVIN: For what reason? th 19 MR. PIKE: Pull that back, please. 19 MR. GOLDBERGER: Whether we have to invoke a 20 MR. KUVIN: Back? 20 privilege or not. 21 MR. PIKE: Yeah, not on the video. I want to 21 MR. KUVIN: Okay, E 22 make sure it's not on the video. 22 THE VIDEOGRAPHER: Going off the record at 4 23 MR. KUVIN: We're good? Thank you. 23 10:10. 24 THE VIDEOGRAPHER: It's not. 24 {A brief recess was taken.) 25 DIRECT EXAMINATION 25 THE VIDEOGRAPHER: We're back on the record at L Page 21 Page 23 I BY MR. KUVIN: 1 10:12. 2 Q. Could you give us your name, sir, please. 2, BY MR. KUVIN: 3 A. Jeffrey Epstein. 3 Q. Okay. Mr. Epstein, did you plead guilty to 4 MR. GOLDBERGER: Kathy, you've got to put it 4 procuring a person under the age of 18 for prostitution? 5 on mute. Kath -- Kathy? 5 A, pled guilty procuring a minor, I believe, 6 MS. EZELL: Give me one second, 6 for prostitution. 7 MR. GOLDBERGER: Just put it on mute, please.| 7 Q. When did you plead guilty to that charge? 8 MR. KUVIN: You can probably turn the volume 8 A. On June the 30th. 9 down; it won't effect her mic, | would imagine. 9 Q. And did you procure a miner for prostitution 10 MR. GOLDBERGER: Good idea. Okay. 10 in compliance with that charge? a1 BY MR. KUVIN: il A. I fully intend to respond to all relevant 12 Q. Mr. Epstein, is your date of birth, 12 questions regarding this lawsuit; however, at the January 20, 1953? 13 present time, my attorneys have counseled me ! cannot A. Yes. 14 provide answers to any questions relevant to this Q, Race is White? is lawsuit. I must accept this advice or risk losing my A. Yes. 16 6th Amendment right to effective representation. Q. You are male? L? Accordingly, I assert my federal constitutional rights a A. Yes. 18 as guaranteed by the Sth, 6th and [4th Amendment to the § Q. Hair is gray? 19 US Constitution. . A. Yes. 20 Q. Okay. I'd like to mark as Exhibit 1 the Q. Eyes are blue? 21 Florida Department of Law Enforcement Sexual A. Yes, 22 Offender/Predator Flyer, Q. Height is 6-foot tall? 23 MR. KUVIN: For the record, let me show that A. Correct. to Mr. -- well, let me show that to the camera, Q. Weight is 180 pounds? (561) 832-7500 PROSE COURT REPORTING AGENCY, Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) INC. (561) 832-7506 adtcaced-2433-45ch-hBa2-c08425252f79

Page 24 1 Okay. Let me know when you have it. 2 (Plaintiff's Exhibit No. | was marked for 3 identification.) 4 THE VIDEOGRAPHER: Okay. 3 MR. KUVIN: Okay? 6 BY MR. KUVIN: 7 Q. Allright. Let me show you this sexual 8 offender/predator flyer. {s that you, sir? 9 A. It's a photograph of me, yes. 10 Q. Okay. Is that the predator flyer for you? 11 A. Na, it is not. 12 Q. Who's it for? 13 A. Iisa sexual offender flyer. 14 Q. I'm sorry, I was reading the title where it 415 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 13 extremely different than sexual predator, 20 Q. What's your understanding of the difference 21 between the two? 22 A. Tm not -- I know I'm a sex -- I've been 23 registered as a sexual offender. 24 Q. Why are you a sexual offender? MR. GOLDBERGER: Jeff. WRAAGARWHPE Page 26 but it's not MR. KUYIN: Ifyou choose to~ MR. GOLDBERGER: It's not -- it's not being admitted into evidence. MR. KUVIN: Sir, please don't interrupt me. Are you -MR. GOLDBERGER: I'l] interrupt you -MR. KUVIN: Are you representing Mr. Epstein in this deposition or is Mr. Pike? Because I want to be clear which one of you is going to be doing the talking during the deposition. 5 MR. GOLDBERGER: We both are representing Mr. Epstein. MR. PIKE: Let's go off the record for a second. MR. KUVIN: No, we're not going off the record, We're staying on the record and only one attomey may speak at a time. So right now, I'd like you all to choose. I don't mind, either one of you can inject -MR. PIKE; Hold on a second. MR. KUVIN: -- and represent Mr. Epstein. i MR. GOLDBERGER: Let -- tet -- let him finish. Let him finish, MR. KUVIN: Let me finish, please. Page 25 1 THE WITNESS; | 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 a representation. Accordingly, I have to assert my 8 federal constitutional rights as guaranteed by the 9 Sth, 6th and 14th Amendment to the US Constitution. 1¢ MR. KUVIN: Let's go ahead and I'd like to 11 mark what you're reading from here today as Exhibit 12 2 to the deposition. 13 (Plaintiff's Exhibit No. 2 was marked for i4 identification.) 15 BY MR. KUVIN: 16 Q. Who prepared that document for you, sir? 17 MR. GOLDBERGER: Don't answer that question, 18 Jeffrey, It's attorney-client privileged and this i9 is my work product, and we're not marking it, so... 20 MR. KUVIN: I don't think you have the right 21 to tell me what I can and can't ~~ 22 MR. GOLDBERGER: You can mark it all you 23 want -MR. KUVIN; It's been marked. (561) 832-7500 Electronically signed by Jeana Ricciutt (601-280-428-9381) Electronicatly signed by Jeana Ricciuti (601-280-428-9381) MR. GOLDBERGER: Fou, can an marr don you want, PROSE COURT REPORTING AGENCY, Page 27 Either one of you can represent Mr. Epstein, but I don't want objections flying from both chairs, both Mr. Epstein's criminal lawyer and his civil lawyer, So I'd ask you to please choose which one is going to object, just like Judge Hafele has required at hearings that only one attorney can represent Mr. Epstein in an argument at a hearing. MR. GOLDBERGER: Actually, we have two different roles in this matter, [ represent Mr. Epstein on all criminal matters, so I'm going to speak when I think it's relevant to any criminal matters. And Mr. Pike represents Mr. Epstein on any civil matters, and he will speak when it's relevant to any civil matters, BY MR. KUVIN: Q. Okay. Sir, can I please have the paper back, which has already been marked as Exhibit 2? MR. KUVIN: Mr. Goldberger, if you choose that this document is not to be produced in this case, I have no objection to you sealing that document until such time as Judge Hafele decides the issue as to whether or not I'm allowed to mark something that the witness is reading in a deposition. Is that fair i you? 3 (Pages 24 to 27) {561} 832-7506 INC. ad1caccd-2433-46ch-b§a2-c08425252179

Page 28 MR. GOLDBERGER: You can mark anything you want to mark. Go ahead and mark it, and then we'l! go from there. MR. KUVIN: Okay, sounds good. Thank you very much, BY MR. KUVIN: Q. Okay, sir. What I've marked as Exhibit 2, did you prepare that document? MR. GOLDBERGER: Attorney-client. THE WITNESS: Attorney-client privilege. BY MR. KUVIN: Q. Sir, you are reading from a document, are you not, when I ask you certain questions? MR. GOLDBERGER: Attorney-client. BY MR. KUVIN; Q. The document that you're reading from is Exhibit 2 that's in front of you right now. MR. GOLDBERGER: Attorney-client. BY MR. KUVIN: Q, Why do you feel a need to read from a document with respect to the issues of whether or not you have a Sth Amendment right? MR. GOLDBERGER: Attorney-client. BY MR. KUVIN: Q. Sir, with respect to the last questions [ was 9 10 il 12 13 14 is 16 17 18 ig 20 24 22 23 24 25 A. | 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. 1 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, E Q. Sir, do you like having things inserted in your anus for sexual gratification? MR. PIKE: Objection, argumentative, harassing. THE WITNESS: | fully intend to respond to alt 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. BY MR. KUVIN: Q. Do you live at 35 ~~ MR. GOLDBERGER: Hold on. THE WITNESS; Excuse me, let me finish. Is that fair. Page 29 asking you about, the difference between a sexual offender and a sexual predator, when Mr. Goldberg piped up and said your -MR. GOLDBERGER: Goldberger. Goldberger. BY MR. KUVIN: Q. --I'm sorry, Mr. Goldberger said your name in order to clue you in to object on Sth Amendment grounds -~ MR. GOLDBERGER: Form, BY MR. KUVIN: Q. -- did you feel a need to respond at that point? MR. PIKE: Object to the form. MR. GOLDBERGER: The invocation of Sth Amendment privileges is going to be decided by me, as Mr. Epstein's criminal counsel. I will make that decision. MR. KUVIN: Okay. I would just like to note for the record that that's improper. That's not what the case law says, and we'll take that up -MR. GOLDBERGER: Fair enough. MR. KUVIN: -- issue with Judge Hafele? BY MR, KUVIN: Q. Allright, sir. Do you consider yourself a sexual offender or a sexual fern Page 31 F BY MR. KUVIN: Q. Absolutely. I certainly want you to finish. A. Accordingly, | assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the US Constitution. Q. Sir, do you live at 358 E! Brillo Way, Palm Beach, Florida? A. I fully intend to respond to ail relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me J 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 guaranteed by the Sth, 6th and 14th Amendment to the US Constitution. Q, Inoticed that Mr. Goldberger shook his head when I asked you where you lived. Do you have a problem ff letting us know where you five? I'm trying to understand why that issue is protected by the Sth Amendment, given the fact that you're required to live at that address pursuant to the sexual offender flyer and pursuant to the Court's order convicting you based on your guilty plea. 4 (Pages 28 to 31) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricctutl (601-280-428-9381) adi caccd-2433-45cb-bhSa2-c08425252f79

Page 32 THE WITNESS: Do you want to repeat the question? BY MR. KUVIN: Q. Sure. Did the Court require you to stay at 358 El Brillo Way on Palm Beach ~ (Interruption in the proceedings.) BY MR. KUVIN: Q. Sir, did the Court require you to stay at 358. El Briilo 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 attomeys 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 Sth, 6th and 14th Amendment to the US Constitution. BY 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.) Page 34} purple item retrieved from your trash at 358 El Brillo |} Way that appeared to be a device known as a jelly anal |i wand. Have you ever heard of something like that? MR. PIKE: Form, argumentative, harassing. Same objections, attorney-client work product. THE WITNESS: I fully intend to respond to all [& relevant questions regarding this Jawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers fo any questions relevant to this lawsuit. | 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 Sth, 6th and 14th Amendment to the US Constitution. BY MR, KUVIN: Q. Outside of your home at 358 El Brillo Way was fj also recovered 2 3-inch purple-sized finger -- I'm 3 sorry, a 3-inch purple finger-sized object which had a broken end, which is apparently a sexual toy similar ~ similar to a cyclone vibrator possibly used for rectal gratification. Do you know what a cyclone vibrator is? A. No. MR. PIKE: Form, harassing. THE WITNESS: No, but I do know that that - Page 33 BY MR. KUVIN: Q. Okay. Let's get this for the camera, if I could. Okay. Allright. I'm going to show you what I've marked as Exhibit 3. Is that a photograph of your home, sir, at 358 EL Brillo Way? A. | fully intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me { 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, | assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the US Constitution. Q. Thad asked you before whether or not you liked things inserted in your anus for sexual gratification, and I'd like to go back to that fora moment, if I could, Have you read the police report, incident report, on your arrest? MR. PIKE: Form, argumentative, harassing. MR. GOLDBERGER: Attorney-client work product. Page 35/5 MR. PIKE: Same objections. THE WITNESS: -- broken purple object turned f out to be, later on, described as a salad fork from the kitchen, strictly something that had been broken in the dishwasher and then reported it ina report obviously inaccurately. BY MR. KUVIN: Q. Okay. So the broken -A. Salad fork, nothing more than a broken salad fork, correct, Q. So the 3-inch purple finger-sized object was a salad fork? H A. Wasa broken handle of a salad fork. Yes, the question has been asked and answered, | believe. l Q. Okay. When did you see that? MR. PIKE: Form. THE WITNESS: See what? BY MR. KUVIN: Q. Well, you called ~ A. See that. What's the that? Q. You calied it a salad fork, When did you see the salad fork after the police had taken it into custody? BY MR, KUVIN: MR. PIKE: Form. 1 did not see the salad fork, ; 5 (Pages 32 to 35) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. ($61) 832-7506 Electronically signed by Jeana Riccluti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381} adi caccd-2433-45ch-bSa2-c08425252179

(561) 832-7500 COURT REPORTER: 4. Etectronicatly signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Riccluti (601-280-428-9381) Page 36 Page 38k 1 nor did I represent that I did see the salad fork. 1 (Plaintiff's Exhibit No. 4 was marked for 2 BY MR. KUVIN: 2 identification.) 3 Q. Okay. So you have no idea what it was that 3 MR. KUVIN: Okay. All right. If we could, 4 the police took out of the trash? 4 just get a shot of that for me. 5 A. The police -- 5 Okay, thank you. 6 MR. PIKE: Form. 6 BY MR. KUVIN: 7 THE WITNESS: -- filed a later report saying 7 Q. According to the incident report, in a room of 8 it was a salad fork, I believe. 8 your home =~ 9 BY MR. KUVIN: 9 MR. PIKE: What page are you on, Counsel? 10 Q. You never saw that piece, did you? 10 MR. KUVIN: Page 44. 12 A. No. 1. MR. PIKE: What paragraph? 12 Q. You have no idea what it was that they took 12 MR. KUVIN: Line 4. 13 out of there? 13 BY MR. KUVIN: 14 MR. PIKE: Form. 14 Q. ~ ina dresser armoire was located a bottle 15 THE WITNESS: I just said the police said it is of peach-flavored Joy Jelly, parenthetically a sexual ié was a salad fork, a mere salad fork misrepresented} 16 lubricant. 7 in that police report, as many things have been, it | 17 Ehave here something called Joy Jelly. I 18 seems. 18 even have peach, Do you know what that is? 19 BY MR. KUVIN: 19 MR. PIKE: Form objection, harassing, 20 Q. Did they misrepresent the jelly anal wand? 20 MR. GOLDBERGER: Can you just clarify the 21 A. I've~ 21 question as to where you got that? Did that come 22 MR. PIKE: Form. 22 from your home or from somewhere else, Mr. Kuvin? |} 23 THE WITNESS: -- never heard of that before. | 23 MR. KUVIN: I don't think that's relevant. 24 BY MR. KUVIN: 24 MR. GOLDBERGER: Just curious as to what 25 Q. Have you used vibrators that you've placed in | 25 you're ~ you've made a big point to identify this, Page 37 Page 39} 1 your anus? 1 this exhibit, and show it to the camera, So if my 2 MR. PIKE: Form, objection, harassing. 2 client is going to answer the question, I'd like to 3 THE WITNESS: No. 3 know whether it came from your home or from -- l 4 BY MR. KUVIN: 4 whether you bought it or where it came from just so 5 Q. You never placed anything like a vibrator in 5 he can -- just so he can accurately answer the 6 your anus? 6 question should he choose to want to answer it, 7 MR. PIKE: Same objections. 7 MR. KUVIN: Well, he can make the choice 8 THE WITNESS: No. 8 whether he wants to answer it or not. 9 BY MR. KUVIN: 9 MR. GOLDBERGER: All right. 10 Q. There was in a dresser of an armoire of your 10 BY MR. KUVIN: 41 home -- 11 Q. Do you know what that is? 12 MR. KUVIN: This is page 44, Counsel. I'd 12 MR. PIKE: Form objection, improper 13 like to reference it 13 hypothetical. 14 THE WITNESS: Is that marked as an exhibit? 1 14 THE WITNESS: I don't understand the question. 45 don't know what he's reading. as BY MR. KUVIN: 16 MR, PIKE: It's not marked as an exhibit. 16 Q. Do you know what Exhibit 4 is? LT THE WITNESS: The police report? 17 A, You've just described it. I have no knowledge 18 BY MR. KUVIN: 18 but what you've just described. 19 Q. No, it's not. It's my work product, much fike 19 Q, You don't know what that's used for? 20 how Mr. Goldberger feit that your Sth Amendment was your, 20 MR. PIKE: Form objection, harassing. 21 work product. 21 THE WITNESS: I've heard what you said it's 22 MR. KUVIN: So let's mark this as exhibit -- 22 used for. I've never seen it before. 23 what are we up to, 47 23 BY MR. KUVIN: PROSE COURT REPORTING AGENCY, Q. Do you know what that, right there, Exhibit 4, 6 (Pages 36. to 39) (561) 832-7506 INC. adicaccd-2433-46ch-b5a2-c08425252179

Page 40 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, iL A. I've already told you. 12 Q. You still haven't answered the question. 13 MR. PIKE: Counsei, he answered the question. 14 It's been asked and answered twice, 15 MR. GOLDBERGER: Let's get a read-back on 16 this. i7 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 reporter.) BIKHswWNHE VNOVNNVE RH Re ee BOVE GCODIUATDEWNROYW 25 MR. PIKE: Form, lack of predicate. BY MR. KUVIN: Q. Have you used it? MR. PIKE: Same objection, lack of predicate, no foundation, harassing. THE WITNESS: I fully intend to respond to all relevant questions regarding this lawsuit; however, at this time, I cannot provide any questions [sic] televant to the lawsuit. I must accept counsels’ 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 f4th Amendment to the US Constitution. BY MR: KUVIN: Q. Would you agree with the description that you are a pervert? MR. PIKE; Same objection, harassing, argumentative. BY MR. KUVIN: Q. You can answer, It's either a simple yes or no. A. I fully intend to respond to alt relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me that I cannot provide answers to any questions relevant to this Page 41 MR. GOLDBERGER: That's all I need to hear, thanks. BY MR. KUVIN: Q. Do you know what Joy Jelly is used for? A. I've heard what you've just described. I have no independent knowledge. Q. You've never used Joy Jelly? A. | fully intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide an answer 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 Sth, 6th and [4th Amendment to the US Constitution. Q. You agree with me that Joy Jelly is a sexual lubricant that's used on sexual devices like vibrators and anal jelly wands? MR. PIKE: Same objections. THE WITNESS: I have no knowledge of that. BY MR. KUVIN: Q. Do you agree that Joy Jelly is a sexual lubricant? A. [have no knowledge of that. Page 43 | lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I must assert my federal constitutional a rights as guaranteed by the Sth, 6th and 4th Amendment of the US Constitution. B Q. Have any mental health counselors diagnosed you as a sexual deviant? MR. PIKE: Again, form -THE WITNESS: I don't believe so. MR. PIKE: ~ work product. BY MR. KUVIN: Q. De you believe you're a sexual deviant? MR. PIKE: Form, THE WITNESS: No, I do not, BY MR. KUVIN: Q. Do you have sex with minors? MR. PIKE: Same objection, form, 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 accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal 7 (Pages 40 to 43) (561) Etectronically signed by Jeana Ricciuti (601-280-428-9381} Electronically signed by Jeana Ricciutl (601-280-428-9381} 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 adi caced-2433-46cb-bba2-c08425262f79

Page 44 Page 46 1 constitutional rights as guaranteed by the Sth, 6th 1 MR. PIKE: Same objection, attorney-client, 2 and 14th Amendment to the US Constitution. 2 work product. 3 BY MR. KUVIN: 3 MR. KUVIN: Are you telling him not to answer? 4 Q. Would you agree that you have a psychological | 4 MR. PIKE: It's attorney-client, work product. 5 disorder with respect to your sexual preferences? 5 I'm instructing him not to answer. 6 MR. PIKE: Same objection. 6 BY MR. KUVIN: 7 THE WITNESS: I fully intend to respond to all 7 Q. Okay. So despite the fact that you're reading 8 relevant questions regarding this lawsuit; however 8 this canned statement over and over to my questions, you 9 at the present time, my attorneys have counseled me 9 don't want to answer any questions about the written 10 ] cannot provide answers to any questions relevant 10 statement; isn't that true? il to this tawsuit. I must accept this advice or risk it MR, PIKE: Same objection, attomey-client, 12 losing my 6th Amendment right to effective 12 work product. I'm instructing the witness not to 13 representation. Accordingly, I assert my federal 13 answer. 14 constitutional rights as guaranteed by the Sth, 14 BY MR. KUVIN: 15 6th and 14th Amendment to the US Constitution. 15 Q. You don't ever fuily intend to respond to 16 BY MR. KUVIN: 16 anything, do you? 17 Q. Have you had sex with transsexuals? 17 MR. PIKE: Same objection. 18 MR. PIKE: Same objection. 18 BY MR. KUVIN: 19 THE WITNESS: No. 19 Q. Or would you like to? BY MR. KUVIN: 20 MR. PIKE: Same objection. Now we're getting Q. Do you know a Ms. Cordero? 21 borderline harassing and argumentative. A. I fully intend to respond to all relevant 22 I think you should move on to -- certainly you i questions regarding this lawsuit; however, at the 23 didn't come here to be argumentative and harassing present time, my attorneys have counseled me I cannot | 24 all day, Mr. Kuvin, so I would hope that you would q provide answers to any questions relevant to this 25 move on to another topic. E Page 45 Page 47 : 1 lawsuit, I must accept this advice or risk losing my 1 THE WITNESS: Jack? E e 6th Amendment right to effective representation. 2. MR. KUVIN: I'm just looking. E 3 Accordingly, | assert my federal constitutional rights 3 MR. GOLDBERGER: He can look at it aillhe § 4 as guaranteed by the Sth, 6th and 14th Amendments to the| 4 wants. E 5 US Constitution. 5 Just ask for permission next time, if you want 6 Q. Do you know a Ms. Maximilia Cordero? 6 to, because it is something that I gave to my 7 MR. PIKE: Same objection. 7 client. So when you want to look -- I've let you i 8 THE WITNESS: I fully intend to respond to alt 8 mark it. Ifyou want to look at it, just ask my H 9 relevant questions regarding this lawsuit; however, 9 permission to do so, okay? at the present time, my attorneys have counseled me 10 MR, KUVIN: Sure. ! | cannot provide answers to any questions relevant aa MR. GOLDBERGER; Is that all right with you? f to this lawsuit. | must accept this advice or risk 12 MR. KUVIN: Perfectly fine. q losing my 6th Amendment right to effective 13 MR. GOLDBERGER: Thanks. iH representation. Accordingly, ( assert my federal 14 BY MR. KUVIN: E constitutional rights as guaranteed by the Sth, 15 Q. Your typed paper there says that you cannot F 6th and 14th Amendment to the US Constitution. 16 provide answers. Why not? i BY MR. KUVIN: 17 MR. PIKE: Attorney-client, work product, I'm Q. When do you intend to fully respond? 18 instructing him not to answer. It's my work / MR, PIKE: Same objection. In addition, work 19 product. B product, attorney-client. 20 MR. KUVIN: Are you stipulating that you a BY MR, KUVIN: al drafted the document we've marked as Exhibit 2? q Q. I'm sorry, I misquoted you. You said [ -- 22 MR. GOLDBERGER: No such stipulation. E you've repeated now numerous times, "I fully intend to 23 MR. PIKE: No such stipulation. i respond,” so let me rephrase my question. 24 MR. KUVIN: Well, if it's work product ~ E When do you fully intend to respond? 25 MR. PIKE: It's attorney-client, work product. sptpbiipmmasaimmadaeas eT RTECS rt RANA DS SSA TS ROTI 8 (Pages 44 to 47) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciutl (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) a4icaccd-2433-48cb-bSa2-cO8425252179

Page 48 Page 50 1 MR. KUVIN: -- I just wanted to clarify. 1 Q. Okay. Go ahead, Don't wait for me. 2 BY MR. KUVIN: 2 A. =» 5th, 6th and 14th Amendment to the US 3 Q. Did you have a sexual relationship with 3 Constitution. 4 Maximilia Cordero when she still had a penis? 4 Q. Okay. You agree, would you not, that 5 MR. PIKE: Same objection. Sth Amendment. 5 Sarah Kellen is currently dating Story Kowles, the 6 THE WITNESS: | fully intend to respond to all 6 gentleman who is sitting here in the room working for 7 relevant questions regarding this lawsuit, however, 7 Mr. Goldberger at your deposition? 8 at the present time, my attorneys have counseled me 8 A. I fully intend to respond to all relevant _ 9 I cannot provide answers to any questions relevant 9 questions regarding this lawsuit; however, at the 10 to this lawsuit, I must -- [ must accept this 10 present time, my attorneys have counseled me I cannot a1 advice or risk losing my 6th Amendment right to ai provide answers to any questions relevant to this 12 effective representation. Accordingly, J assert my 12 fawsuit. I must aocept their advice or risk losing my 13 federal constitutional rights as guaranteed by the i3 6th Amendment right to effective representation. 14 Sth, 6th and 14th Amendment to the US Constitution. | 14 Accordingly, | assert my federal constitutional rights : 15 BY MR. KUVIN: 45 as guaranteed by the 5th, 6th and 14th Amendment to the 16 Q. Do you know Sarah Kellen? 16 US Constitution. i7 A, [fully intend to respond to all relevant 17 Q. Do you know how long Sarah Kellen has been 18 questions regarding this lawsuit; however, at the 18 dating Mr. Story Kowles? 19 present time, my attorneys have counseled me I cannot 19 A. I fully intend to respond to all relevant 20 provide answers to any questions relevant to this 20 questions regarding this lawsuit; however, at the 21 lawsuit. T must accept this advice or risk losing my al present time, my attorneys have counseled me I cannot 22 6th Amendment right to effective representation. 22 provide answers to any questions relevant to this 23 Accordingly, I assert my federal constitutional rights 23 lawsuit. I must accept this advice or risk tosing my 24 as guaranteed by the Sth, 6th and 14th Amendment to the} 24 6th Amendment right to effective representation. 25 US Constitution. 25 Accordingly, f assert my federal constitutional right as Page 49 Page 51 1 Q. You agree, do you not, that Sarah Kellen is, 1 guaranteed by the Sth, 6th and 14th Amendment to the US 2 or as least was, your personal assistant for many years? 2 Constitution. 3 MR. PIKE: Same objection. 3 Q. Did you introduce Ms. Kellen to Story Kowles? 4 THE WITNESS: I fully intend to respond to all 4 A. I fully intend to respond to all relevant 5 relevant questions regarding this lawsuit; however, 5 questions regarding this lawsuit; however, at the 6 at the present time, my attorneys have counseled me 6 present time, my attorneys have counseled me I cannot 7 I cannot provide answers to any questions relevant 7 provide answers to any questions relevant to this 8 to this lawsuit. 1 must accept this advice or risk 8 lawsuit. I must accept this advice or risk losing my 9 losing -- 9. 6th Amendment right to effective representation. 10 MR. GOLDBERGER: Why don't you -- why don't; 10 Accordingly, | assert my federal constitutional rights aL you wait until he's listening, so he... al as guaranteed by the Sth, 6th and 14th Amendment to the 12 MR. KUVIN: Oh, I don't need to listen. I've 12 US Constitution. 13 heard it many times. 13 Q. Are you aware that one of the State ia MR. GOLDBERGER: No, we're going to wait. 14 prosecutors, Dahlia Weiss, who was working on your 1s We're going to wait. 15 criminal case, was also married to a lawyer working for 16 MR. KUVIN: Oh, no, you don't have to wait. 16 Mr. Goldberger here? 17 MR. GOLDBERGER: Oh, no, we will. ay MR. GOLDBERGER: Attorney-client, work 18 BY MR. KUVIN: 18 product. 19 Q. Okay. I'm sorry, are you done? 19 Don't answer. 20 A. No. 20 MR. KUVIN: ['m sorry, work product? 21 Q. Oh, please finish. 21 Somebody's marriage? 22 A. I must accept this advice or risk losing my 22 MR. GOLDBERGER: Uh-huh. Don't answer it. 23 6th Amendment right to effective representation, 23 MR. KUVIN: I'd like an explanation as to how Accordingly, 1 assert my federal constitutional rights 24 someone's marriage is work product on the record so as guaranteed by the Sth... 25 I-can be clear to determine whether | need to briny; TTT A CL TT OT as = eT (561) 832-7500 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9384) PROSE COURT REPORTING AGENCY, 9 (Pages 48 to 51) INC. (561) 832-7506 adtcaced-2433-46cb-b6a2-c08425252679

(561) Page 52 that question up in front of Judge Hafele. MR. PIKE: The rules do not require for speaking objections, and we're going to limit ourself to form and the appropriate objections thereafter, which have been asserted. So there does not need to be anything in the record. Should you wish to file a motion, you can do so. MR. KUVIN: Well, before I file such motion, I think the rules also dictate that I can request an explanation, which I'm doing. MR. PIKE: We've already objected. MR. KUVIN: Okay. BY MR. KUVIN: Q. Do you know Dahtia Weiss? 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, MR. GOLDBERGER: Actually, Til let you answer the question as asked, as to do you know Dahlia Weiss. THE WITNESS: No, I do not. Page 53 BY MR. KUVIN: Q. With respect to Mr. Goldberger, your criminal attorney, did you buy him a brand new BMW? MR. GOLDBERGER: Don't. 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. [ must accept this advice or risk losing my 6th Amendment right to effective representation. MR. GOLDBERGER: It's also attorney-client and work product as to my fees. THE WITNESS: Accordingly, I assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the US Constitution, MR. GOLDBERGER: I'm sorry, it’s also attorney-client work product as to my fees. BY MR. KUVIN: Q. Have you bought any new cars for your civil attorneys, like Mr. Critton? MR. PIKE: Objection, relevance. BY MR. KUVIN: Q. Robert Critton. Page 54 reasonably calculated to lead to admissible evidence in this case. ‘THE WITNESS: No. BY MR. KUVIN: Q. It's ashame. MR. GOLDBERGER: What was that? ‘THE WITNESS: Shame, he said. BY MR. KUVIN: Q. Why not? MR. PIKE: Objection, relevance, I'm going to instruct him not to answer the question. It's argumentative. BY MR. KUVIN: Q. Is there anyone else that you know that is dating staff at Mr. Goldberger's office other than Ms. Kellen and Ms. Wife - Ms. Weiss? MR. PIKE: Objection, form. ; MR. GOLDBERGER: Whoa, whoa, whoa. First of} all, let's get the question right. Ms. Kellen and Ms, Weiss are dating each other; is that the question? MR. KUVIN: No, Fill clarify. MR. GOLDBERGER: Thank you. BY MR. KUVIN: Q. Is there anyone else that you know that's Page 555 dating staff at Mr. Goldberger's office other than Ms. Kellen, or married to staff working for Mr. Goldberger other than Ms. Weiss? MR. GOLDBERGER: There are people ~ MR. PIKE: Objection, form, multiple, compound, vague, irrelevant, not reasonably calculated to lead to admissible evidence. MR. GOLDBERGER: Do you understand the question? The question as asked: Do you know anyone who dates anyone at my office? THE WITNESS: This is why -- this is why we're here? MR. GOLDBERGER: I mean, do you know ~ the § question is: Do you know if anyone in my office : dates anybody? THE WITNESS; No, I do not. MR. GOLDBERGER: Okay. BY MR. KUVIN: Q. That's a good point. I'm glad you made it. No, you know why we're here? We're here to ask you whether or not you had any sexual contact with B.B. Did you? 4. Who? Q. With a young girl that was 14 years old. A. What was her name? 10 (Pages 52 to 55) 832-7500 PROSE COURT REPORTING AGENCY, Electronically signed by Jeana Ricclutl (601-280-428-9381)} Electronically signed by Jeana Ricciuti (601-280-428-9381} INC. (564) 832-7506 adtcaced-2433-46ch-b§a2-408425252179

Page 56 Q BB. MR. KUVIN: [I just wanted to make sure. A. Can you refresh my recollection who she -- do you have anything to show me, something that might -Q. Ido, and | will pursuant to the MR. KUVIN: I don't want to argue. You asked confidentiality that we've previously discussed in this me if { was clear ~case, MR. GOLDBERGER: Let me — let me finish Page 58k into an argument with you. I want you to act A. So tell me who it is that you're representing? Q. EF will do that, Have you had sex with numerous girls underage? A. You've asked me if this -- which question -MR, GOLDBERGER: Wait, the question was -MR. KUVIN: Tl strike the question and rephrase. MR. GOLDBERGER: Which question are you striking? MR. KUVIN: [will strike ail 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 B.B.? MR. KUVIN: Right. MR. GOLDBERGER: That's question one? what + MR. KUVIN: -- and ! just wanted to be clear, E MR. GOLDBERGER: Are you -- are you going to let me finish what I'm saying? MR. KUVIN: I just wanted to know if | was clear, You're trying to tell me to keep my mouth shut, MR. GOLDBERGER: All right. MR. KUVIN: So I wanted to make sure that the record was patently clear what you're asking me to do. MR. GOLDBERGER: Are you done? MR. KUVIN: I'm done. MR. GOLDBERGER: Okay. So the response to your question is, I want you to allow my client -let me finish -- allow my client to finish his answers, If you want to interrupt while he's. asking ~ while he's answering a question, I'm not going to allow you to do that, If you want to Page 57 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 mea favor. After you ask the question, he's going to answer it, Keep your mouth shut and Jet 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;: Fm sorry, t just want to be clear, did you just fell 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 { heard. Page 59 respond to a question that he answers by being argumentative, you can do so, and the appropriate objection will be entered. My only point of my response to you was that I do not want you interfering while he is answering a question, that's it, okay? I just want you to act ethically, honorably and fair. MR. KUVIN: | would ask you to do the same ~ MR. GOLDBERGER; I'm trying. MR. KUVIN; -- and to stop your speaking objections. MR, GOLDBERGER: I'm trying. MR. KUVIN: Objection to form usually works, according to our lecal rules. MR. GOLDBERGER; Okay. MR. KUVIN: Okay? Thank you. Maybe when you get into the civil arena, you'd understand. MR. PIKE: Let's move on, MR. KUVIN: But I just want to make sure that you're on the same page. MR. GOLDBERGER: Spencer ~~ MR. PIKE: Let's move on, MR. KUVEN: | appreciate it. MR. GOLDBERGER: Let's move on. 11 (Pages 56 to 59) (561) 832-7500 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciut! (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 a4tcaccd-2433-48cb-b6a2-c08426252f79

(561) Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Riccluti (601-280-428-9381) 832-7500 Page 60 Page 625 1 BY MR. KUVIN: 1 I cannot provide answers to any questions relevant 2 ° Q. Doyou have sex with underaged girls, that's 2 to this lawsuit. [ must accept this advice or risk 3 the reason we're here, is it not, Mr. Epstein, to answer 3 losing my 6th Amendment right to effective 4 that question? 4 representation. Accordingly, I assert my federal 5 MR, PIKE: Form, 5 constitutional rights as guaranteed by the Sth, 6th 6 BY MR. KUVIN: 6 and 14th Amendment to the US Constitution. a Q. Do you want to answer that question for us 7 BY MR. KUVIN: 8 today? 8 Q. Isn't true that you've sexually molested girls 9 MR. PIKE: Multiple, compound, 9 under the age of 18? 10 THE WITNESS: What's the question? 10 MR. PIKE: Same objection. i aa BY MR. KUVIN: a1 THE WITNESS: I fully intend to respond to all — 12 Q, Do you have sex with underaged girls? 12 relevant questions regarding this lawsuit; however, 13 A. I fully intend to respond to all relevant 43 at the present time, my attorneys have counseled me 14 questions regarding this lawsuit; however, at the 14 I cannot provide answers to any questions relevant 15 present time, my attorneys have counseled me I cannot as to this lawsuit, | must accept this advice or risk 16 provide answers to any questions relevant to this 16 losing my 6th Amendment right to effective a7 lawsuit. I must accept this advice or risk losing my 17 representation. Accordingly, I assert my federal 13 6th Amendment right to effective representation. 18 constitutional rights as guaranteed by the 5th, 6th 19 Accordingly, I assert my federal constitutional rights 19 and 14th Amendment to the US Constitution, 20 as guaranteed by the Sth, 6th and 14th Amendments to the; 20 BY MR. KUVIN: 21 US Constitution, a1 Q. Isn't it true that you've asked numerous, [ 22 Q. Isn't it true that you like to have sex with 22 possibly hundreds, of underaged girls to have sex with 23 little girls? 23 you? 24 MR, PIKE: Same objection, 24 MR. PIKE: Same objection, argumentative, 25 =e 5 harassing. Page 61 Page 63 1 BY MR. KUVIN: 1 THE WITNESS: I fully intend to respond to all 2 Q. Girls under the age of 18? 2 relevant questions regarding this lawsuit; however, [ 3 MR. PIKE: Argumentative, harassing. 3 at the present time, my attorneys have counseled me [F 4 THE WITNESS: One question or two? 4 I cannot provide answers to any questions relevant 5 BY MR. KUVIN: S to this lawsuit, I must accept this advice or risk 6 Q. Isn't it true that you like to have sex with 6 losing my 6th Amendment right to effective 7 little girls who are under the age of 18? 7 representation. Accordingly, | assert my federal 8 MR, PIKE: Argumentative, harassing. & constitutional rights as guaranteed by the 5th, 6th 3 THE WITNESS: | fully intend to respond to all 9 and 14th Amendment to the US Constitution. 10 relevant questions regarding this lawsuit; however, 10 BY MR. KUVIN: 11 at the present time, my attorneys have counseled me | 11 Q. Isn't it true that you've told Sarah Kellen to 12 I cannot provide answers to any questions relevant | 12 avoid service of a witness subpoena in this case because 13 to this lawsuit. I must accept this advice or risk 13 she has information that would incriminate you? 14 losing my 6th Amendment right to effective 14 A. fully intend to respond to all relevant 15 representation. Accordingly, I assert my federal 15 questions regarding this lawsuit; however, at the 16 constitutional rights as guaranteed by the Sth, 6th 16 present time, my attomeys have counseled me I cannot a7 and 14th Amendment to the US Constitution. 17 provide answers to any questions relevant to this 18 BY MR. KUVIN: 18 lawsuit. I must accept this advice or risk losing my 19 Q. Isn't it true that you've asked little girts 19 6th Amendment right to effective representation. 20 under the age of 18 to see their vaginas? 20 MR. PIKE: In addition, the question is 21 MR. PIKE; Same objection, argumentative, 21 argumentative; same objection as before. 22 harassing. 22 BY MR. KUVIN: 23 THE WITNESS: I fully intend to respond to all | 23 Q. Isn't it true that you conspired with Sarah relevant questions regarding this lawsuit; however, | 24 Kellen to obtain girls under the age of 18 to come to E af the present time, my attorneys have counseled me | 25 your home, get naked and give you massages while you PROSE COURT REPORTING AGENCY, 12 (Pages 60 to 63) INC. (561) 832-7506 adtcaced-2433-45ch-bGa2-c08426262f79

Page 64 masturbated? MR. PIKE: Same objections, argumentative, harassing. THE WITNESS: | 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. } must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, | assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the US Constitution. BY MR. KOVIN: Q. Are you treating with a mental health counselor currently? A. No. MR. PIKE: Work product. BY MR. KUVIN: Q. Did you go to the mental health counselor as required by your plea of guilty? 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 Word dA BewYnHe Page 66 to this lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation, Accordingly, { must assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the US Constitution. 1 BY 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, ['m just going to say same objection relating back to the same objections. THE WITNESS: | fully intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me T cannot provide answers to any questions relevant to this iawsuit. I must accept this advice or risk losing my 6th Amendmeni right to effective representation. Accordingly, J assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the US Constitution. BY 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? Page 65 6th Amendment right to effective representation. Accordingly, | assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the US Constitution. May we take a break? MR. GOLDBERGER: Sure. MR. PIKE: In addition to that, it's a psychotherapist/patient privileged information. THE VIDEOGRAPHER: We're off the record at 10:50, (A brief recess was taken.) THE VIDEOGRAPHER: Back on the record at 1:00. MR. KUVIN: Thank you. BY MR. KUVIN: Q. Isn't it try, sir, that you've had under girl -- underaged girls, under the age of 17, come to your home, get naked and give you massages while you masturbated? MR. PIKE: Objection, form, argumentative, harassing. THE WITNESS: I fully intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me 1 cannot provide answers Page 67 MR. PIKE: 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, | must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, | assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the US Constitution. May I see -- talk to my counsel for a second outside? MR. KUVIN: Sure. MR. PIKE: Are we off? MR. KUVIN: Not yet. MR, PIKE: We're off the record, MR. KUVIN: We're off that record. We're not off that record until everybody leaves. MR, PIKE: Stop the video. The video -- off the record. MR. KUVIN: I can't go off the record if it has to do with the lawsuit, MR. PIKE: We don't have anyone here. THE VIDEOGRAPHER: You know that you both have}? to agree for us to go off the record. 13 (Pages 64 to 67) (561) 832-7500 PROSE COURT REPORTING AGENCY, (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricclutt (601-280-428-9381) INC. a4icaccd-2433-48chb-b§a2-c08425252179

Page 68 Page 70 1 MR. PIKE: We don't have anyone here. 1 MR. PIKE: No. 2 MR. KUVIN: I understand that, but am not 2 MR. GOLDBERGER: I'm sorry, you ready? 3 going off the record unless it's not pertaining to 3 MR. PIKE: Okay. 4 the lawsuit. If it’s not pertaining to the lawsuit 4 MR. KUVIN: Are we ready now? 5 that we're here about today, I'll go off the 5 MR. GOLDBERGER: Yep. 6 record, but if it pertains to the lawsuit, I cannot 6 MR. KUVIN: Rolling? 7 go off the record. af THE VIDEOGRAPHER: We're rolling at 11:05, 8 MR. PIKE; I don't -- don't understand. You 8 BY MR. KUVIN: 9 don't have a witness in a chair and you're rolling 9 Q. Okay. Isn't it true, sir, that you've had 10 fape, 10 underaged girls under the age of 14 come to your home, il MR. KUVIN: Exactly. My tape is going to 11 get naked and give you massages while you masturbated? 12 constantly ro}l with respect to the litigation. 12 MR. PIKE: Argumentative, harassing, 13 MR. PIKE: And the point? 13 irrelevant. Same objections as before. 14 MR. KUVIN: The point is I don't want to miss 14 THE WITNESS: 1 fully intend to respond to all is anything, and [ want to make sure there's no ais relevant questions regarding this lawsuit; however, 16 misrepresentations about what goes on with respect 16 at the present time, my attorneys have counseled me 17 to the fitigation. 17 I cannot provide answers to any questions relevant 18 MR. PIKE: Then I'm instructing you to keep 18 to this lawsuit. I must accept this advice or risk 19 rolling tape, and for you to keep typing to 19 losing my 6th Amendment ight to effective 20 everything that they say out loud in this room, 20 representation. Accordingly, 1 assert my federal 21 MR. KUVIN: Not when everybody leaves, 2h constitutional rights as guaranteed by the Sth, 6th 22 We're good now, He wants to go off and I want 22 and 14th Amendment to the US Constitution. 23 to go off now. 23 BY MR. KUVIN: 24 THE VIDEOGRAPHER: We'll go off the record at} 24 Q. Isn't it true, sir, that you've had underaged 25 11:03. 25 girls under the age of 13 come to your home, get naked Page 69 Page 71 1 Does he, though? 1 and give you massages while you masturbated? 2 MR. KUVIN: I don't know. It's a good 2 MR. PIKE: Same objections. In addition, 3 question. 3 asked and answered, 4 MS. EZELL: Did you ask me if I'm on? 4 MR. KUVIN: No, I changed from 14 te 13. 5 MR. KUVIN: Oh, no. 5 MR. PIKE: Same objections. 6 Hey, how are you? I keep forgetting you're 6 BY MR. KUVIN: 7 there, Katherine. ? Q. You can answer. 8 MS. EZELL: I'm there. Actually 1 was on the 8 A, I fully intend to respond to all relevant 9 phone, so I just missed what just happened. Are 9 questions regarding this lawsuit; however, at the 10 you terminating or are you breaking or what? 10 present time, my attorneys have counseled me I cannot il MR. KUVIN: No, he wanted to step out of the 1. provide answers to any questions relevant to this 12 room. 12 lawsuit. I must accept this advice or risk losing my 13 MS. EZELL: Oh, okay. 13 6th Amendment right to effective representation. 14 MR. GOLDBERGER: Okay, thank you. 14 MR. GOLDBERGER: Thank you, Micheel. E 15 Thad to discuss an issue with my client. I 15 THE WITNESS: Accordingly, | assert my federal 16 appreciate the time. ; 16 constitutional rights as guaranteed by the Sth, 6th i7 MR. KUVIN: Anytime, Jack, 1? and 14th Amendment to the US Constitution. 18 MR. GOLDBERGER: You know you don't likeme | 18 Thank you, 19 anymore, i9 BY MR. KUVIN: 20 MR. KUVIN: The secret is J never liked you. 20 Q. Isn't it true, sir, that you've had underage E 21 THE WITNESS: That's no secret, 2l girls under the age of 12 come to your home, get naked 22 MR. KUVIN: There you go. 22 and give you massages while you masturbated? 23 MR. PIKE: Move up the record for me so I can 23 MR. PIKE: Same objections. (561) Electronicalty signed by Jeana Riccluti (601-280-428-9384) Electronically signed by Jeana Ricciuti (601-280-428-9381) BY MR, KUVIN: MR. KUVIN: Are we ready? Q. I'm sorry, was there something funny about 14 (Pages 68 to 71) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 adicaccd-2433-45ch-b5a2-c08426252179

(561) 832-7500 Page 72 Page 74 that question? 1 losing my 6th Amendment right to effective A. Are we-- b 2 representation. Accordingly, I assert my federal MR. PIKE: Same objection, argumentative. Si constitutional rights as guaranteed by the Sth, 6th MR. GOLDBERGER: Don't even respond to that. 4 and 14th Amendment to the US Constitution. THE WITNESS: I fully intend to respond to all 5 BY MR. KUVIN: relevant questions regarding this lawsuit; however, 6 Q. Your name is Jeffrey Epstein, correct? at the present time, my attorneys have counseled me a A. Correct, Lcannot provide answers to any questions relevant 8 Q. [just wanted to see if | could get an answer. to this lawsuit. | must accept this advice or risk 9 MR. PIKE: I'm going to move to strike losing my 6th Amendment right to effective 10 counsel's last statement; it's not a question. representation. Accordingly, I assert my federal 11 BY MR, KUYVIN: constitutional rights as guaranteed by the Sth, 6th 12 Q. Do you agree you maintain a home in New and 14th Amendment to the US Constitution. 13 Mexico? BY MR. KUVIN: 14 A. [fully intend to respond to all relevant Q. Isn't it true that you've engaged in sexual is questions regarding this lawsuit; however, at the activities with girls under the age of 17, including 16 present time, my attorneys have counseled me I cannot touching their vaginas? 17 provide answers to any questions relevant to this MR, PIKE: Same objections. 18 lawsuit. I must accept this advice or risk losing my THE WITNESS: I fully intend to respond to all 19 6th Amendment right to effective representation. relevant questions regarding this lawsuit; however, 20 Accordingly, I assert my federal constitutional rights at the present time, my attorneys have counseled me | 21 as guaranteed by the 5th, 6th and 14th Amendment to the I cannot provide answers to any questions relevant 22 US Constitution. to this lawsuit. I must accept this advice or risk 23 Q. Isn't it true that you've engaged in sexual losing my 6th Amendment right to effective 24 activities with girls under the age of 16, including representation. Accordingly, I assert my federal 25 touching their vaginas? Page 73 Page 75 constitutional rights as guaranteed by the Sth, 6th 1 MR. PIKE: Objection, harassing, and 14th'Amendment to the US Constitution. 2 argumentative. BY MR. KUVIN: 3 THE WITNESS: Didn't you ask the same question Q. Isn't it true that you've engaged in sexual 4 before? activities with girls under the age of 17, including 3 BY MR. KUVIN: using vibrators on their vaginas? 6 Q._ No, it was 17 before; now I went to 16. MR. PIKE: Same objections. 7 MR. PIKE: Same objection. THE WITNESS: | fully intend to respond to all 8 THE WITNESS: | fully intend to respond to all relevant questions regarding this lawsuit; however, 9 relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me | 10 at the present time, my attorneys have counseled me T cannot provide answers to any questions relevant 11 J cannot provide answers to any questions relevant to this lawsuit. 1 must accept this advice or risk L2: to this lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective 13 losing my 6th Amendment right to effective E representation. Accordingly, | assert my federal 14 representation. Accordingly, I assert my federal constitutional rights as guaranteed by the Sth, 6th 15 constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the US Constitution. 16 and 14th Amendment to the US Constitution. BY MR. KUVIN: 1? BY MR. KUVIN: Q. Do you agree that you maintain a home in New | 18 Q. Isn't it true that you've engaged in sexual York? 19 activities with girls under the age of 16, including MR. PIKE: Objection, form. 20 using vibrators on their vaginas? THE WITNESS: I fully intend to respond to ali | 22 MR, PIKE: Same objection, asked and answered, relevant questions regarding this iawsuit; however, 22 MR. KUVIN: Nope. The question before, and we fi at the present time, my attorneys have counseled me | 23 can read it back, was whether he touched their I cannot provide answers to any questions relevant to this lawsuit. I must ect this advice or risk Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, TT NO TTT RE vaginas, and this question is very specific asking whether he wee vibrators oa their voginas. 15, (Pages 72 LG 75) INC. (561) 832-7506 a4icaccd-2433-48eb-b§a2-c08425252f79

Page 76 Page 78 1 MR. PIKE: Same objection, asked and answered. 1 process, we will once again terminate this 2 BY MR. KUVIN: 2 deposition. I am giving you a fair opportunity to 3 Q. You can answer. 3 continue to use the discovery process in the manner 4 A. [fully intend to respond to all relevant 4 in which it is utilized; however, your 5 questions regarding this lawsuit; however, at the 5 grandstanding, laughing in the background, and 6 present time, my attorneys have counseled me I cannot 6 snide comments and remarks are not appropriate 7 provide answers to any questions relevant to this ? during the discovery process; therefore, this is my 8 lawsuit. I must accept this advice or risk losing my 8 one warming to you, Mr. Kuvin. 9 6th Amendment right to effective representation. 9 MR. KUVIN: I disagree. 10 Accordingly, I must assert my federal constitutional 10 MR. PIKE: I'm not asking you for an 11 tights as guaranteed by the Sth, 6th and 14th Amendment} 11 agreement. Please proceed. 12 to the US Constitution. 12 MR. KUVIN: I'm just making sure that the 13 Q. Have you requested girls under the age of 16 13 record is clear. 14 to spread their legs in front of you so that you could 14 And, by the way, you should fix the door, is see their vaginas? 15 Jack, because there's no spring on it, so when 16 MR. PIKE; Same objection. 16 somebody touches it, it goes very fast. So 1 17 THE WITNESS: I fully intend to respond to all i7 apologize if it did slam, and that's the only thing 18 relevant questions regarding this lawsuit; however, 18 Ido agree with. 19 at the present time, my attorneys have counseled me 19 MR. GOLDBERGER: Okay. I appreciate the 20 cannot provide answers to any questions relevant 20 apology. ai to this lawsuit, 1 must accept this advice or risk 21 As long as we're going to yak here, Spencer, i 22 losing my 6th Amendment right to effective 22 you made a comment that I should learn the rules of l 23 representation, Accordingly, I assert my federal 23 civil procedure and learn how to conduct [ 24 constitutional rights as guaranteed by the Sth, 6th 24 depositions and so forth. I've been practicing and 14th Amendment to the US Constitution. 25 primarily criminal defense for 33 years, and do you Page 77 Page 79 BY MR. KUVIN: Q. Do you agree that you maintain a home in the US Virgin Islands? A. As I've answered most of your questions today, L know what, we don't play these games; we get to the 2 3 4 5 I'll answer this basically the same way, which is, I 6 4 8 1 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, fully intend to respond te all relevant questions regarding this lawsuit; however, at the present time, my attomeys have counseled me J cannot provide answers to TT CT I RST TTT IT SCOT OS SI TOE 8 any questions relevant to this lawsuit. 1 must accept 9 you're creating this atmosphere. I'm trying to be 10 this advice or risk losing my 6th Amendment right to 20 polite to you, but it's becoming more and more 12 effective representation. Accordingly, I assert my 41 difficult. So I'm asking you to just kind of act 12 federal constitutional rights as guaranteed by the Sth, 12 professionally and we'll get along, and we'll get 13 6th and 14th Amendment to the US Constitution. 13 through this, that's all. 14 Q. Do you want to give answers? 14 MR. KUVIN; I've been acting professionally. 15 MR. PIKE: Move to strike, argumentative, 15. Frankly, 1 wasn't the one that told the other 16 harassing. 16 attorney to shut up. I mean, those were your 17 Mr. Kuvin, I have no reticence with regard to 1? words, not mine. I just wanted to make sure that I 18 getting in front of Judge Hafele once again, and 18 understood what you were saying to me, 19 fet me delineate for you what your comments and 19 MR. GOLDBERGER: It was a reaction to your -20 some of your conduct here today is and has been: 20 MR. KUVIN: Sir -- E 21 Laughing, argumentative comments after your 21 MR. GOLDBERGER: It was a reaction to your -- | 22 questioning, interrupting the witness, snide 22 MR. KUVIN: -- I would appreciate it if you 23 comments, as well as slamming doors in an office 23 would let me finish. that is not yours. 24 MR. GOLDBERGER: It was a reaction to your inappropriate comments and conduct. to disrupt the discovery 16 (Pages 76 to 79) {561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Etectronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) adtcaccd-2433-45ch-b6a2-c08425252f79

Page 80 Page 82 1 MR. KUVIN: See, the problem is you keep 1. we've both been wamed. 2 interrupting me. 2 MR. PIKE: Mr. Kuvin, you bring up a fabulous 3 MR. GOLDBERGER: You're the one that's 3 point, a fabulous point, and I'm surprised ~ 4 interrupting me, Spencer. 4 MR. KUVIN: It's amazing. I'm surprised that 5 MR. KUVIN: You want me to be courteous and 5 I brought it up. E 6 lef you speak, and then you continue to interrupt 6 MR. PIKE: The next time you choose to laugh — 7 mie when I want to respond to the nonsensical 7 at the witness, we'll call Judge Hafele and see 8 arguments that you're making, because I have been. 8 today what he has to say about that, okay? 9 perfectly courteous here. I've been asking 9 MR. KUVIN: Perfectly fine. 10 perfectly courteous questions, relevant questions 10 MR. PIKE: It's a great idea. 11 to the case, pertinent questions to the issues in il MR. KUVIN: It sounds good to me. : 12 this case. 12 MR. PIKE: So let’s proceed with some relevant f} 13 So if you have a problem with the questions, i3 questions. R 14 then make a legal objection. You and I both know 14 And I would try to give you a hint: Keep in 1s that a speaking, lengthy objection is an improper 15 mind the allegations in your complaint. 16 ‘one; that objection to form is the only objection 16 MR. KUVIN: Sounds good to me. 17 you should be making. And the only comment! made} 17 MR. PIKE: Let's move forward. 18 about you practicing in civil was just merely the 18 BY MR. KUVIN: 19 fact that I didn't know whether you understood that 19 Q. Isn't it true, sir, that you've engaged in. 20 objection to form covers everything. 20 sexual activities with girls under the age of 15, 21 MR. GOLDBERGER: Thave an ~ 2a including touching their vaginas? 22 MR. KUVIN: it certainly wasn't meant as an. 22 A, I23 insult at all, and I'm sorry if you took it that 23 MR. PIKE: Argumentative, harassing, same 24 way. 24 objections. Sorry. fh 25 MR. GOLDBERGER: [ appreciate it. I accept 25 THE WITNESS: [ fully intend to respond to ail Page 81 Page 83 1 your apology, 1 relevant questions regarding this lawsuit; however, 2 Thave ~ [have a suggestion, because 2 at the present time, my attorneys have counseled me 3 apparently, for whatever reason, everyone's 3 I cannot provide answers to any questions relevant | 4 grandstanding, we just can't seem -- wait a minute, 4 to this lawsuit. [ must accept this advice or risk 5 let me just finish, Let me finish. 5 losing my 6th Amendment right to effective 6 MR. KUVIN: I'm not grandstanding. 1 want to 6 representation. Accordingly, I assert my federal 7 get through my questions. 7 constitutional rights as guaranteed by the Sth, 6th 8 MR. GOLDBERGER: We can't seem to get along. 8 and 14th Amendment to the US Constitution. 9 MR. KUVIN: 1 just want to get through the 9 BY MR, KUVIN: 10 questions. 10 Q. Isn't it true that you've engaged in sexual 11 MR. GOLDBERGER: Do you want to have the Lt activities with girls under the age of 15, including 12 mediator sit in for this deposition? Is that what 12 using vibrators on their vaginas? 13 you want to do? 13 MR, PIKE: Same objection. 14 MR. KUVIN: No, I don’t think we need it. I'm 14 THE WITNESS: As I've answered your 15 working through my questions. 15 questions -- most of your questions today, F'l} 16 MR. GOLDBERGER: Okay, then. Go ahead. 16 answer it the same way now, which is, I fuily 17 MR. PIKE: Let's proceed then. 17 intend to respond to all relevant questions 18 MR, KUVIN: Okay, great. 18 regarding this lawsuit; however, at the present 19 MR. GOLDBERGER: You've been warned, 19 time, my attorneys have counseled me I cannot 20 MR. KUVIN: J don't know what the warning is 20 provide answers to any questions relevant to this a. supposed to mean. Nobody is a judge in this room. 21 lawsuit. I must accept this advice or risk fosing 22 I don't think I need a warning. 22 my 6th Amendment right to effective representation. 23 MR. GOLDBERGER: That's why I'm suggesting | 23 Accordingly, I assert my federal constitutional that -~ 24 rights as guaranteed by the Sth, 6th and 14th ‘ou've been wari Amendment to the US Constitution. 17 (Pages 80 to 33) (561) 832-7500 Electronically signed by Jeana Ricciuti Electronically signed by Jeana Ricciuti PROSE COURT REPORTING AGENCY, (601-280-428-9381) (601-280-428-9381) INC. (561) 832-7506 aM caced-2433-45cb-b5a2-c0B426252f79

(561) Page 84 Page 86 1 BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. Isn't it true that you've engaged in sexual 2 Q. What is the youngest girl that you've had sex 3 activities with girls under the age of 14 including 3 with? 4 touching their vaginas? 4 MR. PIKE: Form. 5 MR. PIKE: Same objections. 5S THE WITNESS: I'm going to answer that 6 THE WITNESS: As I've answered most of your 6 question the same way I've answered most of your 7 other questions today, I fully intend to respond to 7 other questions here today, which is, I fully 8 all relevant questions regarding this lawsuit; 8 intend to respond to all relevant questions 9 however, at the present time, my attorneys have 9 regarding this lawsuit; however, at the present 10 counseled me ] cannot provide answers to any 10 time, my attorneys have counseled me I cannot 41 questions relevant to this lawsuit, { must accept TE provide answers to any questions that may be 12 this advice or risk losing my 6th Amendment right 12 relevant to this lawsuit. I must accept this 13 to effective representation. Accordingly, | assert 13 advice or risk losing my 6th Amendment right to 14 my federal constitutional rights as guaranteed by 14 effective representation. Accordingly, } assert my 15 the 5th, 6th and 14th Amendment to the US 15 federal constitutional rights as guaranteed by the 16 Constitution. 16 Sth, 6th and 14th Amendment to the US Constitution. 17 BY MR. KUVIN: 17 BY MR. KUVIN: 18 Q. Isn't it true that you've engaged in sexual 18 Q. What is the youngest age of a girl that has 19 activities with girls under the age of 14, including 19 given you a naked massage? 20 using vibrators on their vaginas? 20 MR. PIKE: Form, argumentative, harassing and 21 MR. PIKE: Same objections. 21 as worded, irrelevant, 22 THE WITNESS: I'll respond to this question in | 22 THE WITNESS: i'm going to answer that 23 the same way I've responded to some of your other | 23 question the same way I've answered most of your questions, which is, I fully intend to respond to 24 other questions here today, which is, I fully all relevant questions regarding this lawsuit; 25 intend to respond to all relevant questions Page 85 Page 87 iL. however, at the present time, my attomeys have 1 regarding this lawsuit; however, at the present 2 counseled me I cannot provide answers to any 2 time, my attorneys have counseled me ¥ cannot 3 questions relevant to this lawsuit. I must accept 3 provide answers to any questions that may be 4 this advice or risk losing my 6th Amendment right 4 relevant to this lawsuit. I must accept this 5 to effective representation. Accordingly, ] assert 5 advice or risk losing my 6th Amendment right to 6 my federal constitutional rights as guaranteed by 6 effective representation. Accordingly, I assert my 7 the Sth, 6th and 14th Amendment to the US 7 federal constitutional rights as guaranteed by the 8 Constitution. 8 5th, 6th and 14th Amendment to the US Constitution. fj 9 BY MR. KUVIN: 9 BY MR. KUVIN: 10 Q. Isn't it true that you've engaged in sexual 10 Q. What is the youngest age of a girl you have a. activities with girls under the age of 14, which 11 masturbated in front of? 12 includes using vibrators on their vaginas? 12 MR. PIKE: Same objections as before. 13 MR. PIKE: Same objections. 13 THE WITNESS: I'm going to answer that 14 THE WITNESS: I'l answer that question the 14 question in the same way I've answered most of your 15 same way I've answered most of your other questions} 15 other questions here today, Mr. Kuvin, which is, I 16 here today, Mr. Kuvin, which is, I fully intend to 16 intend to respond to all relevant questions 17 respond fo ai] relevant questions regarding this 17 regarding this Jawsuit; however, at the present 18 lawsuit; however, at the present time, my attorneys 18 time, my attorneys have counseled me | cannot 19 have counseled me I cannot provide answers to any ig provide answers to any questions that may be 20 questions that may be relevant to this lawsuit. I 20 relevant to this lawsuit. I must accept this 21 must accept their advice or risk losing my 6th 22 advice or risk losing my 6th Amendment right to 22 Amend -- Amendment right to effective 22 effective representation. Accordingly, I assert my 23 representation. Accordingly, I assert my federal 23 federal constitutional rights as guaranteed by the 24 constitutional rights as guaranteed by the Sth, 6th 24 5th, 6th and [4th Amendments to the US 25 and 14th Amendment to the US Constitutio ' 25 Constitution. 18 (Pages 84 to 87) 832-7500 PROSE COURT REPORTING AGENCY, Electronically signed by Jeana Ricclut! (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) INC. (561) 832-7506 a41caccd-2433-45cb-b5a2-cO8425262179

Page 88 Page 9 oF 1 BY MR. KUVIN: 1 for girls under the age of 17? E 2 Q. What is the youngest age of a girl that you 2 MR. PIKE: Same objections. 3 have ejaculated in front of? 3 THE WITNESS; {'m going to answer that 4 MR. PIKE: Same objections as before to this 4 question the same way I've answered most of your 5 same line of questioning incorporated. 5 other questions here today, Mr. Kuvin, which is, ] 6 THE WITNESS: What was the question before 6 fully intend to respond to all relevant questions lt 7 that, sir? 7, regarding this lawsuit; however, at the present E 8 BY MR. KUVIN: 8 time, my attorneys have counseled me I cannot ; 9 Q. What is the youngest age -- the one before or 9 provide answers to any questions relevant tothis ff 10 this one? I'm sorry. 10 lawsuit. I must accept their advice or risk losing li A. The one before, I thought it was the same 121 my 6th Amendment right to effective representation. jy 12 question. 12 BY MR, KUVIN: 13 Q. No, the one before was masturbated, and this 13 Q. Do you agree that you ~ 14 one was ejaculated. T'll rephrase it. 14 A, Accordingly —~ 15 What is the youngest age ofa girl you have 15 Q. Oh, L apologize. 16 ejaculated in front of? 16 A. Accordingly, I assert my federal 17 MR. PIKE: Same objection, argumentative, 17 constitutional rights as guaranteed by the Sth, 6th and I 18 harassing. 18 14th Amendment to the US Constitution. f 19 THE WITNESS: I'm going to respond to that 19 Q. I'm sorry, are you done? i 20 question the same way I've responded to most of 20 A, Yes. 21 your other questions here today, which is, ] fully 21 Q. Okay. I apologize for interrupting you. i 22 intend to respond to all relevant questions 22 Do you agree that you have a sexual preference | 23 regarding this lawsuit; however, at the present 23 for girls under the age of 16? 24 time, my attorneys have counseled me I cannot 24 MR. PIKE: Same objections, form. ; 25 provide answers to any questions that may be 25 THE WITNESS: I'm going to answer that E Page 89 Page 91f 1 relevant to this lawsuit. | must accept their question the same way I've answered most of your 2 advice or risk losing my 6th Amendment right to other questions here today. I fully intend to 3 effective representation, Accordingly, I assert my respond to all relevant questions regarding this 4 federal constitutional rights as guaranteed by the lawsuit; however, at the present time, my attorneys 5 Sth, 6th and 14th Amendment to the US Constitution. have counseled me J cannot provide answers to any 6 BY MR. KUVIN: questions that may be relevant to this lawsuit. 1 7 Q. Do you agree that you have a sexual preference must accept their advice or risk losing my 6th 8 for underaged girls; in other words, girls under the age Amendment right to effective representation. 9 of 187 Accordingly, I assert my federal constitutional 10 MR. PIKE: Same objections, in addition to 10 rights as guaranteed by the Sth, 6th and 14th ik form, il Amendment of the US Constitution, 12 THE WITNESS: I'm going to answer that 12 BY MR, KUVIN: 13 question the same way I've answered most of your 43 Q, Do you agree that you have a sexual preference |: 14 other questions here today, Mr. Kuvin, which is, I 14 for girls under the age of 157 15 fully intend to respond to ali relevant questions 15 MR. PIKE: Same objections. E 16 regarding this lawsuit; however, at the present 16 THE WITNESS: !'m going to answer that 17 time, my attorneys have counseled me f cannot 17 question the same way I've answered most of your | 18 provide answers to any questions that may be 18 other questions here today, Mr. Kuvin, which is, I i 19 releyant to this lawsuit. 1 must accept their 19 fully intend to respond to all relevant questions 20 advice or risk losing my 6th Amendment right to 20 regarding this lawsuit; however, at the present 21 effective representation. Accordingly, I assert my 21 time, my attorneys have counseled me I cannot k 22 federal constitutional rights as guaranteed by the 22 provide answers to any questions relevant to this 23 Sth, 6th and 14th Amendment to the US Constitution.| 23 lawsuit. I must accept their advice or risk losing 24 BY MR. KUVIN: 24 my 6th Amendment right to effective representation. 25 a Do you agree | that you have a sexual preference _| 25 Accordingly, I assert my f a const tional 19 (Pages 88 to 91) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC, (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) a41¢accd-2433-45ch-bSa2-c08425252179

Page 92 Q. Do you agree that you've been treating with a MR. PIKE: Objection, vague, harassing, also psychotherapist/patient privilege; in addition, could call for their information resulting from non-testifying consulting expert information. I'm going to instruct the witness not to Q. Do you agree that you've been treating with a Q. Do you agree that according to your State MR. PIKE: Let's take a break for one second. I'm going to maintain the same objections and Page 94 are mandated to obtain mental health 1 rights as guaranteed by the Sth, 6th and 14th 1 Constitution. 2 Amendment to the US Constitution. 2 BY MR. KUVIN: 3 BY MR. KUVIN: 3 4 Q. Do you agree that you have a sexual preference 4 psychologist for your sexual perversions? 5 for girls under the age of 147 5 6 MR. PIKE: Same cbjections. 6 t THE WITNESS: I'm going to answer that AL 8 question the same way I've answered most of your 8 9 other questions here today, Mr. Kuvin, which is, I 9 10 fully intend to respond to all relevant questions 10 answer, di regarding this lawsuit; however, at the present 11 BY MR. KUVIN: 12 time, my attorneys have counseled me I cannot 12 13 provide answers to any questions relevant to this 13 psychiatrist for your sexual perversions? 14 lawsuit. { must accept their advice or risk losing 14 MR. PIKE: Same objection. 15 my 6th Amendment right to effective representation. | 15 BY MR. KUVIN: 16 Accordingly, I assert my federal constitutional 16 17 rights as guaranteed by the Sth, 6th and 14th i7 Court sentence, you 18 Amendment to the US Constitution. 18 counseling or therapy? 19 BY MR. KUVIN: 19 MR. PIKE: Same objection. 20 Q. Do you agree that you have a sexual preference | 20 BY MR. KUVIN: 21 for girls under the age of 137 2a Q. Who is that therapy with? 22 MR. PIKE: Same objection. 22 23 THE WITNESS: I'm going to answer that 23 We don't have to leave. 24 question the same way I've answered most of your 24 25 other questions today, which is, I fully intend to 25 instructions, Page 93 1 respond to all relevant questions regarding this 1 BY MR. KUVIN: 2 lawsuit; however, at the present time, my attorneys 2 3 have counseled me | cannot provide answers to any 3 counselor? 4 questions that may be relevant to this lawsuit. T 4 5 must accept this advice or risk losing my 6th § BY MR. KUVIN: 6 Amendment right to effective representation. 6 Q. What do you discuss with the therapist? ae Accordingly, | assert my federal constitutional 7 8 rights as guaranteed by the Sth, 6th and 14th 8 instruction. 9 Amendment to the US Constitution. 9 BY MR. KUVIN: 10 BY MR. KUVIN: 10 14 Q. Do you agree that you have a sexual preference | 11 to a mental health counselor or therapist? 12 for girls under the age of 12? 12 13 MR. PIKE: Objection, harassing. In addition, 13 BY MR. KUVIN: 14 vague and indefinite, form. i4 15 THE WITNESS: I'm going to answer that 45 16 question the same way I've answered your other 16 17 questions here today, which is, I intend to respond 17 control them better? 18 to ail relevant questions regarding this lawsuit; 18 MR. PIKE: Objection, harassing, 19 however, at the present time, my attorneys have ig argumentative, vague and indefinite. 20 counseled me T cannot provide answers to any 20 ai questions relevant to this lawsuit. I must accept 21 question the same 22 this advice or risk losing my 6th Amendment right 22 other questions here today, which is, I fulty 23 to effective representation. Accordingly, I assert 23 intend to respond to all refevant questions 24 my federal constitutional rights as guaranteed by (561) 832-7500 Electronically signed by Jeana Riccfuti (601-280-428-9381) Electronically signed by Jeana Ricciutl (601-280-428-9381) the 5th, 6 6th and 14th Amendment to the us Q. How often are you going to that mental health MR. PIKE: Same objection and instruction. MR. PIKE: Definitely same objection and Q. Have you violated your probation by not going MR. PIKE: Same objection and instruction. 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 | THE WITNESS: I'm going to answer that regarding this lawsuit; however, at the present time, my attorneys ave counseled me I cannot PROSE COURT REPORTING AGENCY, INC. Page 95 RTE LASER TS RTS RT SS AAT FR TTR AT OR TT I TT TT way I've answered most of your 20 (Pages 92 to 95) (561) 832-7506 a4tcaced-2433-46cb-b6a2-c08425262179

Page 96 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, T assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the US Constitution. BY MR. KUVIN: Q. Do you agree that -- let me ask you this: Do you see patterns in things? MR. PIKE; Form, compound, confusing, vague. THE WITNESS: I don't -BY MR. KUVIN: Q. Do you understand the question? A, No, Idon't. Q. Do you see patterns in numbers? MR. PIKE: Same objection, lack of predicate, foundation, What are you talking about? THE WITNESS: I don't understand the question. BY MR. KUVIN: Q. Do you recognize patterns in large numbers? MR. PIKE: Same -MR. GOLDBERGER: You just asked the question the same way. Just ask it a different way and he'll try and answer it for you. OOBAIHN WHE Union from 1969 to 1971, correct? A. Correct. Q. Okay. You were raised in Coney Island? A. Correct. Q. You attended Lafayette High School in Brooklyn, New York? A. Is that a question? Q. Yes. Did you attend -- I'm sorry, did you attend Lafayette High School in Brooklyn, New York? #3 A. Yes. : Q. And you took classes at -- oh, I asked that, T'm sorry. You went to Courant Institute of Mathematical Sciences where you left without a degree, correct? A. Correct, Q. From ‘73 to'75, you taught calculus and physics at The Dalton School? . Tm not sure those years are correct. Q. What years were you at Dalton? A. [believe it was '74 to '76, Q. Okay. A, I'm not certain. Q. Okay. Now, Dalton School is a high school, correct? A. Correct. Page 97 MR. KUVIN: I did. I tried to clarify it. MR. GOLDBERGER: You made it -- you said large numbers versus numbers, THE WITNESS: I don't understand the question. BY MR. KUVIN: Q. Do you see patterns in any sequences of numbers? MR. PIKE: Same objection, THE WITNESS: Do I see patterns? { don't understand the question. BY MR, KUVIN: Q. Well, you developed a software to help make money in the stock market, correct? MR. PIKE: Objection as to relevance. THE WITNESS: No, that's -- no, absolutely not, BY MR. KUVIN: Q. It wasn't a software, a computer software, that you helped to develop many years ago after leaving your teaching job? MR. PIKE: Same objection. THE WITNESS: | don't know what you're talking about, BY MR. KUVIN; Q Lets BoD back. You took oleae at Cooper Page 99f Q. What were the ages of the children you were peeking at that high school? Mostly old -- mostly 17 and 18. a Okay. So you were teaching seniors? A. Yes. Q. What were you teaching? li A. You just asked that question, mathematics and [} physics. Q. You're right, [ apologize. Were you teaching any girls that were under the age of 17 at the time? A. I don't know. Q. Did you have any sexual contact with any of the girls that you were teaching at Dalton? A. Again? Q. Did you have any sexual contact with the girls f that you were teaching at Dalton? : . While I was @ teacher? . Well, let's start with that question, yes. . No, . How about after? . Not that I remember. Did you date any girls that were previously your student at Dalton? A. qT ‘im Boing to answer that question like every 21 (Pages 96 to 99) (561) 832-7500 Electronically signed by Jeana Ricclut! (604-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 ad caced-2433-45ch-b6a2-c08425252179

Page 100 Page 1028 L other question I've answered today, which is, I intend 1 Tve tried, can you believe that? fi 2 to respond to all relevant questions regarding this 2 THE VIDEOGRAPHER: 1 do believe that. Ido. ff 3 lawsuit; however, at the present time, my attorneys have 3 MR. KUVIN: Right. Oh, yeah, yeah, yeah. 1 E 4 counseled me I-cannot provide answers to any questions 4 remember you mentioned that before, right, yeah, i a that may be relevant to this lawsuit. I must accept $ THE WITNESS: Are we off the record? 6 this advice or risk losing my 6th Amendment right to 6 MR. KUVIN: Unfortunately, Mr. Pike wanted us 7 effective representation. Accordingly, | assert my ? on permanently, so we're on permanently. B 8 federal constitutional rights as guaranteed by the Sth, 8 MR, PIKE: Actually, no. The - I wanted to E 9 6th and 14th Amendment to the US Constitution. 9 go off the record in order to, you know, conserve l 10 Q. You do not have a college degree, correct? 10 on Jeana’s time, as well as the videographer, but 1i A. Correct. il Mr. Kuvin, you stated you wanted to be on the lf 12 Q. Regardless of that, you became a trader at 12 record because you wanted to ensure that everything E 13 Bear Steams at some point, correct? 13 was on the record that had to deal with this case, bi 14 MR. PIKE: Form. 14 So now we're secing peopie coming in and out of E 15 BY MR. KUVIN: 15 doors after they use the restroom, which J really E 16 Q. Let me ask if a different way if you're 16 see as a complete waste of resources. 17 confused. You look confused. i7 Nonetheless -18 A. Yes. 18 MR. GOLDBERGER: Let's all be friends here and ff 19 Q. You became a trader at Bear Stearns without a 19 let's just do this depo. i 20 college degree; is that correct? 20 MR. KUYVIN: I just wanted to stay on the E 21 A. No. 21 record while — i 22 Q. You had ~ 22 MR. GOLDBERGER: That's fine. i 23 A. 1 was never a trader. 23 MR. KUVIN: -- the attorneys were still in the ; 24 Q. I'm sorry. What job did you hold at 24 room, that's all. H 25 Bear Stearns? 25 MR. GOLDBERGER: That's fine. ; Page 102 Page 103) 1 MR. PIKE: I'd like to take a break and speak 1 MR. KUVIN: When the attorneys leave the room, E 2 to my client, 2 T don't mind going off the record. That's no A 3 MR. KUVIN: Olay. 3 problem with me, i 4 THE VIDEOGRAPHER: Your mic is still on, 4 MR. GOLDBERGER: Let's just get along and get 5 Mr. Pike. 5 this stuff done and move on. 6 MR, PIKE: Thank you. | appreciate that 6 MR. KUVIN: I'm more than happy to do that. Hy 7 reminder. 7 MR. GOLDBERGER: Are we cool with that? l 8 MR. GOLDBERGER: Okay. & MR. KUVIN: Sure. E 9 MR. PIKE: Go ahead. 9 MR. GOLDBERGER: Sure. 10 MR. KUVIN: Yes. As far as I'm concerned, you 10 THE VIDEOGRAPHER: Spencer, you have about AL can cut it, 11 five minutes. : 12 THE VIDEOGRAPHER: Okay. We'll go off the | 12 MR. KUVIN: Why don't you change tape so we 13 record at 11:33, 13 don't have to stop. E 14 MR. KUVIN: As far as she is concerned, she's 14 MR. GOLDBERGER: What time do you want to 15: got fo keep going, so... a5 stop, because I've just got some stuff that | need 16 THE VIDEOGRAPHER: Well, I'm going to start | 16 to do at some point today. Do you want to take a i7 the recording again because T -- I'm in an awkward 17 break or do you not -18 position. I'm just going to keep it going. 18 THE VIDEOGRAPHER: Let me go off the record. 19 MR, KUVIN; That's not a problem. 19 We'll go off the record at 11:36. This will be the E 20 THE VIDEOGRAPHER: Okay. 20 end of videotape No. 1. k 2i MR. KUVIN: Can I make shadow animals in front} 21 COURT REPORTER: Ave we going off the paper [j 22 of you? 22 record, too? [ 23 THE VIDEOGRAPHER: If you'd like. 23 MR. KUVIN: Sure, Is 24 MR. KUVIN: Jeana is the best court reporter T 24 MR, PIKE: Yeah. 25 have ever had in all of the hundreds of cases that 25 (A brief recess was taken.) 22 (Pages 100 to 103) (561) 832-7500 PROSE COURT REPORTING AGENCY, Electronicaily signed by Jeana Rieciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Inc. (561) 832-7506 a4icaced-2433-45cb-b6a2-c08425252179

f E (561) 832-7500 Electronically signed by Jeana Ricciutl (601-280-428-9381) Electronically signed by Jeana Ricciuti (604 -280-428-9381) Page 104 Page 106 1 THE VIDEOGRAPHER: We're back on the record at} 1. as guaranteed by the Sth, 6th and 14th Amendment to the 2 11:39. This will be the beginning of tape No. 2. 2 US Constitution. 3 BY MR. KUVIN: 3 Q. In 1982, you founded your own financial 4 Q. What job -- what job did you have at 4 management firm called J. Epstein & Company; isn't that & 5 Bear Stearns? 5 truc? ‘ 6 A. 1 fully intend to respond to ail relevant 6 A. As I've answered most of your other questions 7 questions regarding this lawsuit; however, at the 7 today, Mr. Kuvin, | intend to fully respond to all 8 present time, my attorneys have counseled me I cannot 8 relevant questions regarding this lawsuit; however, at 9 provide answers to any questions that may be relevant to 9 the present time, my attorneys have counseled me I 10 this lawsuit. 1 must accept this advice or risk losing, 10 cannot provide answers to any questions relevant to this 11 ray 6th Amendment right to effective representation, 12 lawsuit. I must accept their advice or risk losing my 12 Accordingly, I assert my federal constitutional rights 12 6th Amendment right to effective representation, 13 as guaranteed by the Sth, 6th and 14th Amendment to the 13 Accordingly, | assert my federal constitutional rights F 14 US Constitution. 14 as guaranteed by the Sth, 6th and 14th Amendment to the 15 MR. KUVIN: Obviously, I'm going to have to 15 US Constitution. A 16 take this up with Judge Hafele, but I'm trying to 16 Q. The company that you founded called J. Epstein 1? understand, counsel, and, you know, I’m not going 17 & Company later changed its name to Financial Trust Co, 18 to ask the witness obviously but how his job at 18 and its headquarters are in the private islands of the 19 Bear Stearns is a potential Sth Amendment issue in 19 US Virgin Islands; isn't that true? 20 this case, 20 A. I fully intend to respond to all relevant 21 MR. PIKE: It's asked and answered. ai questions regarding this lawsuit; however, at the 22 MR. KUVIN: So there is no explanation? 22 present time, my attorneys have counseled me I cannot 23 MR. PIKE: You said you wanted to take it up 23 provide answers to any questions relevant to this 24 with the judge; you can take it up with the judge. 24 lawsuit. I must accept their advice or risk losing my 25 ‘Number one, the relevancy of it is it's not 25 6th Amendinent right to effective representation, Page 105 Page 107 1 applicable to your lawsuit, that -- 1 mean, that's 1 Accordingly, I assert my federal constitutional rights 2 the large part. 2 as guaranteed by the Sth, 6th and 14th Amendments to the 3 MR, KUVIN: Relevance we can argue about. 3 United States Constitution. 4 MR. PIKE: Anyway, but again, I don't need to 4 Q. Do you socialize with Leonard Sustein 5 make your case for you. You can make your case to 5 (phonetic)? 6 Judge Hafele. The privilege has been asserted. 6 A. I'm going to answer that question the way I've 7 BY MR. KUVIN: # answered most of your other questions here today, 8 Q. Sir, isn't it true that you do not have a 8 Mr. Kuvin, which is, | intend to respond to all relevant 9 college degree? 9 questions regarding this Jawsuit; however, at the 10 A. Yes, that's true. 10 present time, my attorneys have counseled me £ cannot. 1L Q. Allright. Now, you have no post-secondary 14 provide answers to any questions relevant to this 12 degrees? 12 lawsuit, I must accept their advice or risk losing my 13 A. No, sir, 13 6th Amendment right to effective representation. 14 Q. How did you get the job at Bear Stearns 14 Accordingly, I assert my federal constitutional rights 15 without a college degree or any post-secondary degrees? } 15 as guaranteed by the Sth, 6th and 14th Amendment to the 16 A. You don't need a college degree to get a job 16 US Constitution. 17 with Bear Stearns. a7 Q. Have you socialized with Richard Axie 18 Q. Who gave you the job? 18 {phonetic}? 19 A. [fully intend to respond to all relevant ig A. I'm going to answer that question the same way 20 questions regarding this lawsuit; however, at the 20 I've answered most of your other questions here today, 21 present time, my attorneys have counseled mel cannot { 24 which is, I fully intend to respond to ail relevant 22 provide answers to any questions relevant to this 22 questions regarding this lawsuit; however, at the 23 lawsuit. I must accept their advice or risk losing my 23 present time, my attorneys have counseled me I cannot 24 6th Amendment right to effective representation. 24 provide answers fo any questions relevant to this 25 Accordingly, I assert my federal constitutional rights 25 lawsuit. I must accept their advice or risk losing my PROSE COURT REPORTING AGENCY, (Pages 104 to 107) INC. (561) 832-7506 adicaced-2433-46ch-b6a2-c08426252179

Page 108 Page 1105 1 6th Amendment right to effective representation. 1 | fully intend to respond to all relevant questions 2 Accordingly, I assert my federal constitutional rights 2 regarding this lawsuit; however, at the present time, my 3 as guaranteed by the 5th, 6th and 14th Amendment to the 3 attorneys have counseled me I cannot provide answers to 4 US Constitution. 4 any questions relevant to this lawsuit. 1 must accept 5 MR. PIKE: And in addition, the question lacks 5 this advice or risk losing my 6th Amendment right to 6 predicate and it's vague and ambiguous. It's 6 effective representation. Accordingly, ¥ assert my 7 overly broad. 7 federal constitutional rights as guaranteed by the Sth, 8 BY MR. KUVIN: 8 6th and 14th Amendment to the US Constitution. 9 Q. Do you know Gerald Edelman? 9 Q. Do you know a politician, George Mitchell? 10 A, I'm going to answer that question the same way 10 A. Fim going to answer that question the same way 1 T've answered most of your other questions here today, 4a P've answered most of your other questions here today, 12 Mr. Kuvin, which is, ¥ fully intend to respond to all 12 which is, I fully intend to respond to all relevant 13 relevant questions regarding this lawsuit; however, at 13 questions regarding this lawsuit; however, at the i4 the present time, my attorneys have counseled me that 1 14 present time, my attorneys have counseled me I cannot 15 cannot provide answers to any questions that may be 15 provide answers to any questions relevant to this. 16 relevant to this lawsuit. [ must accept this advice or 16 fawsuit. I must accept their advice or risk losing my 17 risk losing my 6th Amendment right to effective i? 6th Amendment right -- another yawn? 18 representation. Accordingly, I assert my federal 18 Q. Fm sorry, I can't help yawning. It seems to 19 constitutional rights as guaranteed by the 5th, 6th and 19 be a function of the day. 20 14th Amendment to the US Constitution. 20 MR. PIKE: Move to strike. 21 Q. Do you know Murray Gelman? 21 BY MR. KUVIN: 22 A. I'm going to answer that question the same way 22 Q. Lapologize. | tried to keep my mouth shut 23 T've answered most of your other questions here today, 23 for that one, so -- but I can't heip it. [ apologize. 24 which is, I fully intend to respond to all relevant 24 MR. PIKE: Move to strike. 25 questions regarding this lawsuit; however, at the 25 Page 109 te. : # . Page 111} 1 present time, my attorneys have counseled me I cannot 1 sefistitutional rights as guaranteed by the Sth, 6th 2 provide answers to any questions that may be relevant to 2 and 14th Amendment to the US Constitution. 3 this lawsuit, 1 must accept this advice or risk losing 3 BY MR. KUVIN: 4 my 6th Amendment right to effective representation. 4 Q. Do you know President Bill Clinton? 5 Accordingly, I assert my federal constitutional rights 5 A. I'm going to respond to that question the same 6 as guaranteed by the 5th, 6th and 14th Amendment to the 6 way I've responded to most of your other questions here 7 US Constitution. 7 today, which is, I intend to respond to all relevant 8 Q. Do you know Ben Goertzel, spelled 8 questions regarding this lawsuit; however, at the 9 G-O-E-R-T-Z-E-L? 9 present time, my attorneys have counseled me that I 10 A. I'm going to answer that question the same way 10 cannot provide any answers to questions that may be aL I've answered most of your other questions here today, 11 relevant to this lawsuit. I must accept this advice or 12 which is, ] fully intend to respond to all relevant 12 risk losing my 6th Amendment right to effective 43 questions regarding this lawsuit; however, at the 13 representation. Accordingly, | assert my federal 14 present time, my attorneys have counseled me I cannot 14 constitutional rights as guaranteed by the Sth, 6th and 15 provide answers to any questions relevant -- was that 15 14th Amendment to the US Constitution. 16 just a yawn? 16 Q. Do you know Actor Kevin Spacey? a7 Q. i'm sorry, yes, that was just a yawn. 17 A. I'm going to answer that question the same way 18 A, Imust accept this advice or risk losing my 18 I've answered most of your other questions here today ~ 19 6th Amendment right to effective representation. 19 MR. PIKE: Excuse me for a minute, 20 Accordingly, I assert my federal constitutional rights 20 ‘Mr. Epstein. 21 as guaranteed by the Sth, 6th and 14th Amendment to the | 22 Obviously, your line of questioning is 22 US Constitution, 22 personal not does -- does Mr. Epstein -- does IE 23 Q. Do you know Marvin Minsky, M-I-N-S-K-Y? 23 Mr. Epstein know who President Clinton is by virtue 24 A. Tm going to answer that question the same way 24 of him being the President of the United States, 25 T've answered most of your other questions b 25 he personaily know him, correct? 24 (Pages 108 to 111) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciut! (601-280-428-9381) a41caccd-2433-45cb-b5a2-c08425252179

Page 112 1 MR. KUVIN: Absolutely. Thank you for the 2 clarification, and I'll clarify. Next time I can 3 rephrase, do you know them personally. I don't 4 want to have go back to every question. Do we have 5 the understanding that my questions before -6 MR, PIKE: Yes. 7 MR. KUVIN: -- dealt with whether or not 8 Mr. Epstein knew these gentleman, I was asking, 9 personally? 10 MR. PIKE: Yes, I want the record to be 12 clear. I don't want you to later say that how 12 could Mr. Epsteia not know who President Clinton is 13 by virtue of him being the President of the United 14 States at some point in time, and vice versa with is Kevin Spacey and whoever else you -- so, yes, we 16 have that agreement on a personal basis. 17 MR. KUVIN; Okay, perfectly fine. 18 BY MR. KUVIN: 19 Q. Do you know Actor Kevin Spacey personally? 20 A. I'm going to answer that question the same way 21 I've answered most of your other questions here today, 22 which is, intend to respond fo ali relevant questions 23 regarding this lawsuit; however, at the present time, I 24 cannot provide questions fo any questions relevant to this lawsuit. I must accept this advice or risk losing i9 THE WITNESS: I'm going to ~ MR. KUVIN: Hang on. THE WITNESS: Excuse me, MR. KUVIN: I'm sorry, what's the form objection? MR. PIKE: It's a form objection and relevance followed thereafter. MR. KUVIN: I just wanted to correct the form if there was something wrong with the form. Is there anything particular with the form I need to correct? MR. PIKE: Form, relevance. BY MR. KUVIN: Q. Do you own a Boeing 727? A. I'm going to answer that — (Interruption in the proceedings.) UNIDENTIFIED WOMAN: Cail, is here for, Mr. Kuvin. MR. KUVIN: Who? ‘ UNIDENTIFIED WOMAN; He said he was. expecting him. E MR. KUVIN: Please let him know we're going to be taking a break at 12:00, and if he could wait. Thank you. BY MR. KUVIN: Page 113 a my 6th Amendment right to effective representation. 2 Accordingly, | assert my federal constitutional rights 3 88 guaranteed by the Sth, 6th and 14th Amendment to the 4 US Constitution. S Another yawn? That's pretty good, Try to -~ 6 Q. That was just a breath, actually, a deep 7 breath, that’s all. Thank you for paying attention. 8 Do you know Actor Chris Tucker personally? 9 A. I'm going to answer that question the same way 10 F've answered most of your other questions here today, iL which is, { intend to respond to aff relevant questions 12 regarding this tawsuit; however, at the present time, my 13 attommeys have counseled me | cannot provide answers to 14 any questions that may be relevant to this lawsuit. £ 15 must accept their advice or risk losing my 6th Amendment 16 Tight to effective representation. Accordingly, 1 17 assert my federal constitutional rights as guaranteed by 18 the 5th, 6th and 14th Amendment to the US Constitution. 19 Q. Do you own = de you own a Boeing 727? 20 MR. PIKE: I'm sorry, Spencer, 1 didn't hear 21 you, Can you repeat the question? 22 MR. KUVIN: Sure. 23 BY MR, KUVIN: Q. Do you own a Boeing 727? MR. PIKE: Form objection, relevance, (561) 832-7500 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, Page 1155 Q. lL apologize for the interruption. A. No problem. T'm going to answer that question the same way T've answered most of your other questions here today, which is, [ fully intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me | 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 Sth, 6th and 14th Amendment to the |! US Constitution. Q. Have you ever referred to your Boeing 727 plane as “Air Fuck One"? MR. PIKE: Form, argumentative, harassing. THE WITNESS: I'll have to answer that the same way I've answered 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 T cannot provide answers to any questions that may be relevant to this Jawsuit. I must accept their advice or risk losing my 6th Amendment right to ffective representation. Accordingly, I assert my 25 (Pages 112 to 115) (561) INC. 832-7506 a41caccod-2433-46ch-b5a2-c08425262f79

Page 116 Page 118 NL TTT EST TTT A. I'm going fo answer that question the same way Ive. answered mort of your other questions here today, (S61) Electronicatly signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Riccluti (601-280-428-9381) 832-7500 federal constitutional rights as guaranteed by the 1 which is, I fully intend to respond to all relevant Sth, 6th and 14th Amendment to the US Constitution, 2 questions regarding this lawsuit; however, at the BY MR. KUVIN: 3 present time, my attorneys have counseled me I cannot Q. Have you ever taken any underaged girls, girls 4 provide answers to any questions that may be relevant to under the age of 18, on your Boeing 727? 5 this lawsuit. I must accept their advice or risk losing A. I'm going to answer that question the same way 6 my 6th Amendment right to effective representation, I've answered most of your other questions here today, 7 Accordingly, I assert my federal constitutional sights Mr. Kuvin, which is, | intend to fully respond to all 8 as guaranteed by the 5th, 6th and 14th Amendment to the relevant questions regarding this lawsuit; however, at 9 US Constitution. E 10 this time, I cannot provide any answers to questions 10 Q. Isn't it true that you funded Mr. Nowak's TL relevant to this lawsuit as my attorneys have counseled 11 research at the Institute For Advanced Study in 12 me. I must accept their advice or risk losing my 6th 12 Princeton? 13 Amendment right to effective representation, 13 A. I'm going to answer that question the same way 14 Accordingly, I assert my federal constitutional rights 14 Hve answered most of your other questions here today, 15 as guaranteed by the Sth, 6th and 14th Amendment to the} 15 Mr. Kuvin, which is, I fully intend to respond to all 16 US Constitution. 16 relevant questions regarding this lawsuit; however, at 17 Q, Are youa confidential informant for the 17 the present time, my attorneys have counseled me I 18 prosecution of Bear Stearns? 18 cannot provide answers to any questions relevant to this 19 MR, PIKE: Form, relevance, 19 lawsuit, I must accept their advice or risk losing my 20 THE WITNESS: I'm going to answer that 20 6th Amendment right to effective representation. 21 question the same way I've answered most of your 21 Accordingly, I assert my federal constitutional rights 22 questions here today, which is, 1 fully intend to 22 as guaranteed by the Sth, 6th and 14th Amendment of the 23 respond to ail relevant questions regarding this 23 US Constitution. | 24 lawsuit; however, at the present time, my attomeys 24 MR. PIKE: Can we go off the record for a have counseled me I cannot provide answers to any 25 second? Page 117 Page 119 questions that may be relevant to the lawsuit, I 1 MR. KUVIN: Sure. must accept their advice or risk losing my 6th 2 THE VIDEOGRAPHER: Off the record at Amendment right to effective representation. 3 11:55 am. Accordingly, I assert my federal constitutional 4 MR. GOLDBERGER: Here's my issue. Actually, rights as guaranteed by the Sth, 6th and 14th 5 we probably should be on the record on this one. Amendment to the US Constitution. 6 MR. KUVIN: Are we going on? BY MR. KUVIN: 7 MR. GOLDBERGER: Yeah, let's go on. Q. Did you trade information with the Federal 8 MR. KUVIN: Sure. authorities in order to get a lighter sentence with 9 THE VIDEOGRAPHER: Back on the record at respect to the charges brought against you in Palm Beach | 10 11:55. y County by the US Attorney's Office? 11 MR. GOLDBERGER: We were just off the record A. I'm going to answer that question the same way 12 and talked about taking a break, and I hate to I've answered most of your other questions here today, 13 inject personal problems into a scheduling, but 1 which is, | fully intend to respond to all relevant 14 am suffering from some ~ actually some nerve questions regarding this lawsuit; however, at the 5 neurological problem. I'm on a fairly heavy present time, my attorneys have counseled me I cannot 16 steroid right now and it's causing me some issues. provide answers to any questions refevant to this 17 I didn't want to try and reset this deposition lawsuit. I must accept their advice or risk losing my 18 because I know, Mr. Kuvin, you wanted to take the 6th Amendment right to effective representation. i9 deposition, but given the medications I'm on, f'd Accordingly, I assert my federal constitutional rights 20 just assume keep going unless that's a huge problem as guaranteed by the Sth, 6th and 14th Amendment tothe} 21 for you. US Constitution. 22 MR. KUVIN: Not a problem for me at all. Do Q. Do you know, personally, Martin Nowak? 23 you want to go straight through iunch? PROSE COURT REPORTING AGENCY, INC. TE RETESET MR. GOLDBERGER: I think so, 1 mean, if you've ever x taken 34 steroids before, they c can ~ they 26 (Pages 116 to 119) (561) 832-7506 aM caccd-2433-45eb-b6a2-cOBR425262f79

Page 120 Page 122 | 1 can mess with you pretty good, so I'd prefer to 1 attorneys have counseled me I cannot provide answers to |} 2 keep going. 2: any questions relevant to this lawsuit. 1 must accept 3 MR. KUVIN: Fine with me. 3 this advice or risk Josing my 6th Amendment right to 4 MR, PIKE: May we go off the record? 4 effective representation. Accordingly, I assert my 5 MR. KUVIN: Sure, 5 federal constitutional rights as guaranteed by the Sth, 6 THE VIDEOGRAPHER: We'll go off the record at 6 6th and 14th Amendment to the US Constitution. 7 11:56. o Q. And isn't it true also that you have retained 8 (A brief recess was taken.} 8 Alan Dershowitz to defend you in the criminal charges 9: THE VIDEOGRAPHER: We're back on the record at} 9 that were brought against you in Palm Beach? 10 12:12, 10 MR. GOLDBERGER: Attorney-client, 11 BY MR. KUVIN: Th. MR. PIKE; Attorney-ctient, work product. 212 Q. Sir, isn't it true that you pledged 12 BY MR. KUVIN: 13 $30 million to Harvard University in 2003? 13 Q. Isn't it also true that Alan Dershowitz works 14 A. I'm going to answer that question the same way 14 on staff at Harvard University as a professor? I mean, i5 f've answered most of your other questions here today, 15 if you know. 16 which is, } intend to respond to all relevant questions 16 A. I'm going to answer that question like I've 17 regarding this lawsuit; however, at the present time, my 17 answered most of your other questions here today, which 18 attorneys have counseled me I cannot provide answers to 18 is, I fully intend to respond to all relevant questions 19 any questions relevant to this Jawsuit. I must accept 19 regarding this lawsuit; however, at the present time, my 20 their advice or risk losing my 6th Amendment right to 20 attorneys have counseled me I cannot provide answers to 21 effective representation. Accordingly, 1 assert my 21 any questions that may be relevant to this lawsuit. I 4 22 federal constitutional rights as guaranteed by the 5th, 22 must accept this advice or risk losing my 6th Amendment |r 23 6th and 14th Amendment to the US Constitution. 23 right to effective representation. Accordingly, | 24 Q. Isn't it true that that $30 million pledge to 24 assert my federal constitutional rights as guaranteed by & 25 Harvard was shortly before you were arrested with 25 the 5th, 6th and 14th Amendment to the US Constitution. Page 121 Page 1235 1 respect to the charges brought against you in Palm Beach 1 Q. Isn't it true that you own a 50,000 square 2 for having sex with underaged girls and soliciting 2 foot home in Manhattan that was formerly owned by Lex 3 underaged girls for prostitution? 3 Wexner? 4 Cinterruption in the proceedings.) 4 A. I'm going to answer that question as I've 5 MR. GOLDBERGER: Thank you. 5 answered most of your other questions here today, 6 Hey Kathy, it's Jack Goldberger. You're back 6 Mr. Kuvin, which is, I fully intend to respond to all 7 on. 7 relevant questions regarding this lawsuit; however, at 8 MS. EZELL: Okay, good, Thanks, Jack. 8 the present time, my attorneys have counseled me 1 9 MR. GOLDBERGER: Okay. 9 cannot provide answers to any questions that may be 10 MS. EZELL: I'm putting the mute on. 10 relevant to this lawsuit. I must accept this advice or aL MR. GOLDBERGER: Okay. 1. risk losing my 6th Amendment right to effective 12 THE WITNESS: Can you read me the question? 12 representation. Accordingly, | assert my federal 13 MR. KUVIN: Sure. Could you read it back, 13 constitutional rights as guaranteed by the 5th, 6th and 14 please? 14 14th Amendment to the US Constitution. 15 (A portion of the record was read by the 15 Q. Isn't it true that one of your only clients is 16 reporter.) 16 2 financial advisor with Lex Wexner? 17 THE WITNESS: No. 17 A, I’m going to respond to that question the same 18 BY MR. KUVIN: 18 way I've responded to most of your other questions here 13 Q. Isn't it true that you pledged $30 million to 19 today, which is, I fully intend to respond to all 20 Harvard University in 2003, which is shortly before 20 relevant questions regarding this lawsuit, however, at 21 charges were brought against you in Palm Beach? 21 the present time, my attorneys have counseled me I 22 A. [ll answer that question the same way I've 22 cannot provide answers to any questions relevant to this 23 answered most of your other questions here today, which | 23 lawsuit. [ must accept their advice or risk losing my is, I fully intend to respond to all relevant questions 24 6th Amendment right to effective representation. {561) regarding. this lawsuit; however, at at the pr ent 832-7500 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Riccluti (601-280-428-9381) PROSE COURT REPORTING AGENCY, Accordingly, 1 Tassert my federal oonstitut rights 27 (Pages "120 to 123). (561) 832-7506 INC. adicaccd-2433-46cb-bSa2-c08425252179

Page 124 Page 126 1 as guaranteed by the Sth, 6th and 14th Amendment to the 1 Q. Did Mr. Wexner replace you with Dennis Hersch? 2 US Constitution. 2 A. I'm going to answer that question like I've 3 Q. Isn't it true that Lex Wexner has since fired 3 answered most of your other questions here today, which 4 you after charges were brought against you in Palm Beach! 4 is, | fully intend to respond to all relevant questions 5 County for soliciting underaged girls for sex? 5 regarding this lawsuit; however, at the present time, my 6 A. I'm going to respond to that question the same 6 attorneys have counseled me I cannot provide answers to 7 way I've responded to most of your other questions here 7 any questions relevant to this lawsuit. 1 must accept 8 today, which is, | intend to respond to all relevant 8 their advice or risk losing my 6th Amendment right to 9 questions regarding this lawsuit; however, at the 9 effective representation. Accordingly, | assert my 10 present time, my attorneys have counseled me I cannot 10 federal constitutional rights as guaranteed by the Sth, a provide answers fo any questions relevant to this ail 6th and 14th Amendment to the US Constitution. 12 lawsuit. I must accept their advice or risk losing my 12 Q. Would you agree that Mr. Wexner was your only 13 6th Amendment right to effective representation. 13 client when you were a financial advisor? 14 Accordingly, I assert my federal constitutional rights 14 A. {'m going to answer that question like I've 15 as guaranteed by the Sth, 6th and 14th Amendment tothe | 15 answered most of your other questions here today, 16 United States Constitution. 16 Spencer -- Mr. Kuvin -17 Q. Are you a homosexual? 17 Q. Thank you. 18 A, No, 18 A. -- which is, I fully intend to respond to all 19 Q. Have you had homosexual relationships with 19 relevant questions regarding this lawsuit; however, at 20 Mr. Wexner? 20 the present time, my attorneys have counseled me I 21 A. I'm going to answer that question the way I've 21 cannot provide answers to any questions relative to this 22 answered all your other questions here today, basically, 22 lawsuit. | must accept their advice or risk losing my 23 which is, ] intend to respond to all relevant questions 23 6th Amendment right to effective representation. 24 regarding this lawsuit; however, at the present time, my 24 Accordingly, I assert my federal constitutional rights 25 attorneys have counseled me I cannot provide answers to | 25 as guaranteed by the Sth, 6th and 14th Amendment to the Page 125 Page 127 1 any questions relevant to this lawsuit. I must accept 1 US Constitution. 2 this advice or risk losing my 6th Amendment right to 2 MR. KUVIN; Allright. With the understanding 3 effective representation. Accordingly, I assert my 3 that -- see, now he's yawning. You don't pick on 4 federal constitutional rights as guaranteed by the 5th, 4 him when he yawns. 5 6th and 14th Amendment to the US Constitution. 5 With the -6 Q. Have you ever touched Mr. Wexner's penis? 6 MR. PIKE: Move to strike. ¥ MR. PIKE: Objection, harassing, irrelevant, 7 MR. KUVIN: With the understanding that 1 8 argumentative. 8 understand you all object and you've moved to 9 MR. GOLDBERGER: Object. 9 disclose the identity of B.B., who's been 10 THE WITNESS; No. 10 identified in this case, obviously the same al BY MR. KUVIN: a1 proceedings would go with respect to this 12 Q, Have you ever had anal sex with Mr. Wexner? 12 deposition that have gone with every other 13 A. No. 13 deposition regarding the identity of the unknown 14 Q. Have you ever threatened Mr. Wexner that you 14 B.B. So I'm going to ask questions, obviously, 15 would disclose private information about him if he 15 utilizing full names and using the same procedure 16 testified against you in the civil proceedings which 16 we've used in all other depositions in this case. 17 have been brought against you here in Palm Beach County? } 17 MR. PIKE: I don't think that there's been an 18 MR. GOLDBERGER: Can you -- I'm sorry, can you | 18 agreement in that regard. | think that there’s 19 repeat the question? 19 been a motion to seal that had been subsequently 20 MR. KUVIN: Sure. Go ahead and repeat it 20 filed by, I believe it was, Brad Edwards' office 21 back, please, a1 after a particular depo occurred. So if you want 22 (A portion of the record was read by the 22 to address it by -- by that, then that would be“ 23 reporter.) 23 fine. 24 THE WITNESS: No. 24 If there was an order entered that that 25 (561) BY MR, KUVIN: 832-7500 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC, deposition shall not be disclosed to the media 28 (561) 832-7506 ad1caccd-2433-45ch-b5a2-c08425262179 ly E E ST TT TTT TCT STAT (Pages 124 to 127)

Page i128 earlier this morning, in that regard, I'm not quite sure what -- what you're asking, Mr. Kuvin. MR. KUVIN: Well, I just want to make sure that when Jeana types up the transcript, that it's done the same exact way that they've all been done, which is, that the girls would be utilized by initial that will have the same -MR, PIKE: Pseudonym. MR. KUVIN: -- pseudonym -- that will have the same attachment to the deposition as we always have, which is confidential. MR. PIKE: That's fine, MR. KUVIN: Ifyou chose to obviously challenge the confidentiality and want to disclose my client's name for some reason, then we'll address that with the Court at some later time. MR. PIKE: That's fine. MR. KUVIN: Okay. Good enough. Ali right. MR. PIKE: Pending the Court's ruling on that. MR. KUVIN: Obviously pending the Court's ruling. All right. You got your camera? Good to go? BY MR. KUVIN; Q. I'm going to show you what we'll mark as Exhibit 5. Page 130 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 ff provide answers to any questions that may be relevant to [ this lawsuit, 1 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 Sth, 6th and 14th Amendment to the | US Constitution. Q. I'm going to show you what I've marked as Exhibit 7, and I've blacked out the name -- or the face of a girl that is shown in this photograph before I mark it to the deposition. {'m going to draw an arrow with a star to the girl that I'd like you to identify. MR. PIKE: First, I'm going to object to the use of this exhibit. It's -- it's not an original any longer, and it was not provided to me prior to your marking out the face of the other individual in this photograph; therefore, I don’t -- I object to it and would fike to know the basis for which you've marked out this individual's face. MR. KUVIN: To protect her privacy. MR. PIKE: Third party privacy right? MR. KUVIN: She has a right to privacy. I certainly don't want to breach any potential right (561) Page 129 (Plaintiff's Exhibit No. 5 was marked for identification.) MR. KUVIN: Okay? BY MR. KUVIN: Q. Do you recognize this young girl? A. I'm going to answer that question the same way I've answered most of your other questions, which is, I intend to respond to all relevant questions regarding this lawsuit, however, at the present time, my attorneys have questioned -- excuse me, my attorneys have counseled me I cannot provide answers to any questions relevant to this lawsuit. 1 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 United States Constitution. Q. T'lishow you what we're marking as Exhibit 6, Okay? (Plaintiff's Exhibit No. 6 was marked for identification.) BY MR. KUVIN: Q. Do you recognize this young girl that I've marked as Exhibit 6? A. I'm going to respond to that the same way I've responded to! moat of. your a uestions here foday, 832-7500 Electronically signed by .Jeana Ricciuti (601-280-428-9361) Electronically signed by Jeana Ricciuti (601-280-428-8381) PROSE COURT REPORTING AGENCY, INC. Page 131) to privacy she may have because I haven't asked her whether or not it's okay to show her photograph, which is why I blacked her out. MR. PIKE: Okay. But having said that, that -- that theory and objection is duly noted. T'll go ahead and allow the wimess to be questioned on Exhibit 7. (Plaintiffs Exhibit No. 7 was marked for identification.) BY MR. KUVIN: Q. I'd like you to take a ook -MR. KUVIN: I'm sorry, let me show this to the camera, first. THE VIDEOGRAPHER: Okay. BY MR. KUVIN: Q. Okay. Do you recognize the girl on the left in Photograph Exhibit 7? A. T'm going to respond to that question the same way I've responded to most of your other questions here today, Mr. Kuvin, which is, J intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attomeys have counseled me I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my ; 6th betta Tight to stfective Tepreseniatan 29 (Pages 128 to 131) (561) 832-7506 ad1caccd-2433-45eh-ba2-008425252¢79

Page 132 Page 134 {561} 832-7500 Q. Do you agree that while she was giving you 6th and 14th Amendment to the US Constitution. Electronically signed by Jeana Ricclutl (601-280-428-9381) Electronically signed by Jeana Riccluti (601-280-428-9381) 1 Q. Excuse me. 1 this massage, you were masturbating? 2 A. Accordingly, I assert my federal 2 A. "She" being B.B.? I'm sorry. She -~- what was 3 constitutional rights as guaranteed by the Sth, 6th and 3 the question? 4 14th Amendment to the US Constitution. 4 Q. Yes, all these questions refer to the same 5 (Photograph shown to the camera.) 5 child, B.B. You can make that assumption for all my 6 (Plaintiffs Exhibit No. 8 was marked for 6 questions. F identification.) 7 A. Okay. 8 BY MR. KUVIN: 8 MR. PIKE: Objection to form, argumentative, 9 Q. Okay. Do you recognize the girl shown in 9 move to strike. 10 Exhibit 8? 10 BY MR. KUVIN: a1 A. I'm going to answer that question the same way il Q. Do you agree that while she was giving you 12 T've answered most of the other questions here today, 12 this massage, you were masturbating? 13 which is, I fully intend to respond to all relevant 13 MR. PIKE: Form, argumentative, harassing. 14 questions regarding this lawsuit; however, at the 14 THE WITNESS: I'm going to respond to that is present time, my attorneys haye counseled me I cannot 15 question the same way I've responded to most of 16 provide answers to any questions relevant to this 16 your other questions here today, which is, I intend 17 lawsuit. I must accept this advice or risk losing my 17 to respond to alf relevant questions regarding this 18 6th Amendment right to effective representation. 18 lawsuit; however, at the present time, my attorneys 19 Accordingly, [ assert my federal constitutional rights 19 have counseled me I cannot provide answers to any 20 as guaranteed by the Sth, 6th and i4th Amendment of the; 20 questions relevant to this lawsuit. 1 must accept 21 United States Constitution, 21 their advice or risk losing my 6th Amendment right 22 Can we take a break for a second? 22 to effective representation. Accordingly, | assert 23 Q. Sure. 23 wy federal constitutional rights as guaranteed by 24 MR. PIKE: Sure, 24 the Sth, 6th and 14th Amendment to the US 25 THE VIDEOGRAPHER: Going off the record at | 25 Constitution. Page 133 Page 135 1 12:27. 1 BY MR. KUVIN: 2 (A brief recess was taken.) 2 Q. Do you agree that while she was giving you 3 THE VIDEOGRAPHER: Back on the record at 3 this naked massage, she told you she was 167 4 12:29. 4 MR. PIKE: Form, argumentative, harassing, 5 BY MR. KUVIN: 5 assumes facts not in evidence. 6 Q. Sir, do you agree that in 2005, you had B.B. 6 THE WITNESS: I'm going to have to respond to 7 come to your house, get naked and give you a massage 7 that question the same way I've responded to most & while you had nothing on but a washcloth over your 8 of your other questions here today, which is, 9 genitals? 9 intend to respond to all relevant questions 10 MR. PIKE: Objection form, argumentative. 10 regarding this lawsuit; however, at the present ai THE WITNESS: Is that B.B.; is that who you. iL time, my attorneys have counseled me ] cannot 12 said? Can you spell that for me? 12 provide answers to any questions that may be 13 BY MR. KUVIN: aS relevant to this lawsuit. 1 must accept their 14 Q. It’s in the record. 14 advice or risk losing my 6th Amendment right to 15 A. I'm going to answer that question the same way 15 effective representation. Accordingly, | assert my 16 T've answered most of your other questions here today, 16 federal constitutional rights as guaranteed by the 17 which is, 1 intend to respond to all relevant questions 17 Sth, 6th and 14th Amendment to the US Constitution. 18 regarding this lawsuit; however, at the present time, my i3 BY MR. KUVIN: 19 attorneys have counseled me I cannot provide answers to | 19 Q. Do you agree that white she was giving you 20 any questions relevant to this lawsuit. I must accept 20 this naked massage, she told you that she was 157 21 this advice or risk losing my 6th Amendment right to 21 MR. PIKE: Same objections as before. 22 effective representation, Accordingly, I assert my 22 THE WITNESS: I'm going to answer that 23 federal constitutional rights as guaranteed by the Sth, 23 question the same way I've answered most of your PROSE COURT REPORTING AGENCY, ESA SS ST TT a LE eT TTT TIT other questions here today, which is, J intend to respond t to all relevant questions regarding this 30 (Pages 132 to 135) INC. {561) 832-7506 a4tcaccd-2433-46ch-b6a2-c08426262175

Page 136 Page 138 1 lawsuit; however, at the present time, my attorneys 1 you a naked massage while you were naked, that you also 2 have counseled me | cannot provide answers to any 2 touched her vagina? 3 questions that may be relevant to this lawsuit. I 3 MR. PIKE: Same objections as before. 4 must accept this advice or risk losing my 6th 4 THE WITNESS: I'm going to respond to that 5 Amendment right to effective representation. 5 question the same way I've responded to most of 6 Accordingly, I assert my federal constitutional 6 your other questions here today, Mr. Kuvin, which 7 rights as guaranteed by the Sth, 6th and 14th 7 is, | fully intend to respond to all relevant 8 Amendment to the US Constitution. 8 questions regarding this lawsuit; however, at the 9 MR, PIKE: Mr. Kuvin, I've been incorporating 9 present time, my attorneys have counseled me I 10 and asserting the same objections, by saying same 10 cannot provide answers to any questions that may be 1i objection as before, are you okay with that? 11 relevant to this lawsuit. | must accept this 12 MR, KUVIN: Perfectly fine. 12 advice or risk losing my 6th Amendment right to 13 MR, PIKE: Okay. 13 effective representation. Accordingly, 1 must 14 BY MR. KUVIN: 14 assert my federal constitutional rights as 15 Q. Do you agree that while B.B. was in your home,} 15 guaranteed by the Sth, 6th and 14th Amendment to 16 you asked her to get completely naked? 16 the United States Constitution. 17 MR, PIKE: Same objection. 17 BY MR. KUVIN: 18 THE WITNESS: I'm going to respond to that 18 Q. Do you agree that during this naked massage 19 question the way I've responded to most of your i9 with B.B., that you asked her whether she wanted you to [i 20 other questions here today, which is, I intend to 20 stop touching her vagina, and she said yes. 21 respond to all relevant questions regarding this ai MR. PIKE: Same objections. 22 lawsuit; however, at the present time, my attorneys | 22 THE WITNESS: I'm going to respond to that 23 have counseled me I cannot provide answers to any | 23 question the same way I've responded to most of 24 questions relevant to this lawsuit. T must accept 24 your other questions here today, Mr. Kuvin, which 25 their advice or risk losing my 6th Amendment right | 25 is, 1 intend to respond to all relevant questions Page 137 Page 139 1 to effective representation. Accordingly, I assert 1 regarding this lawsuit; however, at the present q 2 my federal constitutional rights as guaranteed by 2 time my attorneys have counseled me I cannot q 3 the Sth, 6th and 14th Amendment to the United 3 provide answers to any questions relevant to this : 4 States Constitution. 4 lawsuit. 1 must accept their advice or risk losing 5 BY MR. KUVIN: 5 my 6th Amendment right to effective representation. ; 6 Q. Do you agree that after B.B. got naked in your 6 Accordingly, I assert my federal constitutional 7 home, that you asked her to massage you while you werei 7 rights as guaranteed by the 5th, 6th and 14th i 8 naked? 8 Amendment of the United States Constitution. : 9 MR. PIKE: Form, lacks predicate, 9 BY MR. KUVIN: 10 argumentative, harassing, assumes facts not in 10 Q. Do you agree that regardless of B.B. telling ; al evidence. 11 you to stop touching her vagina, you nonetheless F 12 THE WITNESS: !'m going to respond to that 12 disregarded her and touched her there again? ie 13 question the same way I've responded to most of 13 MR. PIKE: Same objections as before. : 14 your other questions here today, Mr. Kuvin, which 14 THE WITNESS; I'm going to respond that 4 15 is, | intend to respond to all relevant questions a5 question the same way I've responded to most of : 16 regarding this lawsuit, however, at the present 16 your other questions here today, which is, | intend H 17 time, my attorneys have counseled me that [ cannot 17 to respond to all relevant questions regarding this 18 provide answers to any questions that may be 18 lawsuit; however, at the present time. My 19 relevant to this lawsuit. I must accept their 1g attomeys have counseled me that I cannot provide 20 advice or risk losing my 6th Amendment right to 20 answers to any questions relevant to this lawsuit. 21 effective representation. Accordingly, I assert my 2a I must accept their advice or risk losing my 6th 22 federal constitutional rights as guaranteed by the 22 Amendment right to effective representation. 23 Sth, 6th and 14th Amendment to the US Constitution.| 23 Accordingly, I must assert my federal 24 BY MR. KUVIN: 24 constitutional rights as guaranteed by the Sth, 6th 25 Q. Do you agree that while B.B. was ie and giving and 14th pineudatent 03 the United States TTT a rE 31 (Pages 136 to 139) (561} 832-7500 PROSE COURT REPORTING AGENCY, INC, {561) 832-7506 Electronically signed by Jeana Riccluti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) a41caced-2433-45cb-b5a2-c08425262179

DBUIYMKHARwWHE Page 140 Constitution. ~ BY MR. KUVIN: Q. You penetrated B.B.'s vagina with your finger and a vibrator, did you not? MR. PIKE: Same objections. 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 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 must assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the United States Constitution. BY MR. KUVIN: Q. And it is also true that you've paid hundreds of girls under the age of 17 for similar encounters where you've asked them to get naked, you've laid ona table naked, masturbated and then touched them in their vagina at your Palm Beach home; isn't that true? MR. PIKE: Form, argumentative, harassing, -.: Page 142} Sarah Kellen, you had another underaged girl, Haley Robson, working to obtain other underaged girls to come ff to your house with sexual encounters -- for sexual encounters with you? MR. PIKE: Same objections. THE WITNESS: Could you repeat the question? BY MR, KUVIN: Q. Sure. Isn't it true that in addition to Sarah Kellen, you had another girl who, at the time was underage, Haley Robson, working to obtain underaged girls fo come to your house for sexual encounters with you? MR. PIKE: Same objections. THE WITNESS: I'm going to have to respond to that question the same way I've responded to 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 that 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 must assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to Page 141 multiple, compound, it's confusing, vague, it lacks proper predicate and foundation, MR. KUVIN: Let me back up. BY MR, KUVIN: Q. Because of the compound, I'm going to have to break it down a little, Isn't it true, sir, that you've paid hundreds of girls under the age of 17 to come to your home and give you naked massages? MR. PIKE: Same objection, plural. 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. 1 must accept their advice or risk losing my 6th Amendment right to effective representation. Accordingly, | assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the United States Constitution, BY MR, KUVIN: Page 143] the United States Constitution. BY MR. KUVIN: Q. And when these young girls were recruited to come to your home, you told Kellen and Robson to tell them that it would be a platonic massage with no sexual contact; isn't that trae? MR. PIKE: Same objections. THE WITNESS: I'm going to respond to that question the way I've responded to most of your other questions here today, Mr. Kuvin, which is, 1 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 fo 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 Sth, 6th and 14th Amendment to the United States Constitution. BY MR. KUVIN: Q. It was only after the girls arrived at your home that they learned that they would have to get naked and you would be fondling them sexually, isn't that Q. Isn't it true, sir, that in addition to true? 32 (Pages 140 to 143) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (S61) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381} Electronically signed by Jeana Ricciut! (601-280-428-9381) a41 caccd-2433-45ch-b6a2-c08425252179

Page 144 Page 146 ! 1 MR. PIKE: Form, argumentative, lacks 1 statement. 2 predicate, improper foundation, argumentative and 2 MR. KUVIN: He was asking me a question, 3 harassing. 3 that's the only reason why I responded. I 4 THE WITNESS: I'm going to respond to that 4 apologize. 5 question the same way I responded to most of your 5 MR. PIKE: Once again, move to strike. 6 other questions here today, which is, ] intend to 6 THE WITNESS: I intend to respond to all 7 respond to all relevant questions regarding this oz: relevant questions regarding this lawsuit; however, 8 Jawsuit; however, at the present time, my attorneys 8 at the present time, my attorneys have counseled me 9 have counseled me I cannot provide any answers to 9 I cannot provide answers to any questions relevant 10 question that may be relevant to this lawsuit. I 10 to this lawsuit. I must accept this advice or risk 12 must accept their advice or risk losing my 6th 11 losing my 6th Amendment right to effective 12 Amendment right to effective representation. 12 representation. Accordingly, I assert my federal 13 Accordingly, I must assert my federal 13 constitutional rights as guaranteed by the Sth, 6th 14 constitutional rights as guaranteed by the Sth, 6th 14 and 14th Amendment to the United States 15 and 14th Amendment to the United States 15 Constitution. 16 Constitution. 16 BY MR. KUVIN: 17 BY MR. KUVIN: 17 Q. Do you have a massage table in your Palm Beach }; 18 Q. Isn't it true that you had numerous girls 18 home? 19 under the age of 17 brought to your home by taxi? 19 A. I'm going to answer that question, Mr. Kuvin, 20 MR. PIKE: Form, argumentative, overbroad, 20 the same way I've answered most of your other questions fj 21 lacks appropriate foundation. al here today, which is, | intend to respond to all E 22 BY MR. KUVIN: 22 relevant questions regarding this lawsuit; however, at 23 Q. And let me clarify. From the years 2004 23 the present time, my attorneys have counseled me that I 24 through 2006. 24 cannot provide answers to any questions relevant to this 25 MR. PIKE: Same objections, minus overbroad. | 22 lawsuit. { must accept their advice or risk losing my Page 145 Page 147 1 THE WITNESS: I'm going to have to answer that 1 6th Amendment right to effective representation, 2 question the same way I've answered most of your 2 Accordingly, I must assert my federal constitutional i 3 other questions here today, which is, I intend to 3 rights as guaranteed by the 5th, 6th and 14th Amendment 4 respond to al] relevant questions regarding this 4 to the United States Constitution. E 5 fawsuit; however, at the present time, my attorneys 5 Q. Did you have a massage table at your home in 6 have counseled me I cannot provide answers to any 6 2005? 7 questions that may be relevant to this lawsuit. I 7 MR. PIKE: Lacks appropriate foundation. 8 must accept their advice or risk losing my 6th 8 MR. KUVIN: I'm sorry, what's the objection to 9 Amendment right to effective representation. 9 that one? 10 Accordingly, I assert my federal constitutional 10 MR. PIKE: Lacks appropriate foundation, iL rights as guaranteed by the Sth, 6th and 14th 11 MR. KUVIN: Foundation? 12 Amendment to the United States Constitution. 12 MR. PIKE: Yes, it does. 13 BY MR. KUVIN: 13 BY MR. KUVIN: 14 Q. Isn't it true that you paid a taxi to have 14 Q. Did you have a home in 2005? 15 girls, underaged girls like B.B., brought to your home 15 Tim sorry, I'm just trying to lay the 16 from the years 2004 to 2006? 16 foundation, and [ apologize for laughing, | just don't 1? A. I'm going to respond to that question the way 17 understand the objection. I'm trying fo understand the 18 I've responded to most of your other questions here 18 foundation question of did you have a massage table at 19 today, which js, I intend to respond fo all relevant 19 your home in 2005. I want to fix my question, if - if 20 questions regarding this lawsuit; however, at the 20 Tean. 21 present time, my attomeys have counseled me that I 21 MR. PIKE; if you can. 22 cannot -- I'm sorry, should I start again? Do you 22 MR. KUVIN: Ail right. 23 want -- 23 BY MR. KUVIN: 24 Q. No, please, don't start again. 24 Q. Did you have a home in 2005? 25 MR. PIKE: pMove to strike counsel's | last 25 A, I'm going to res] ne to that uestion the ss same 33 (Pages 144 to “147) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381} a4tcaccd-2433-45cb-b5a2-c08425252179

Page 148 way I've responded to 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 that I cannot provide answers to any of your questions that may be relevant to this lawsuit. 1 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 Sth, 6th and 14th Amendment to the United States Constitution. Q. Do you know what a massage table is? A, I'm going to have to answer that question the same way I've answered most of your other questions here today, Mr. Kuvin, which is, 1 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. 1 must accept this advice or tisk losing my 6th Amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and I4th Amendment to the United States Constitution. Q. Do you know what a table is? MR, PIKE: Objection, harassing -~ MR. KUVIN: I'm just trying Page 149 MR. PIKE: -- argumentative. MR. KUVIN: | apologize. I'm just trying to lay the foundation. I want to make sure that there's no problem with the foundation for the question of, did you have a massage table in your home in 2005. So I've asked him whether he had a home, I'm asking him whether he knows what a massage table is -MR. GOLDBERGER: | have no problem with him answering what a table is. Just ask him the question. BY MR. KUVIN: Q. Do you know what a table is? A. Yes. Q. Okay. Did you have a massage table in your home back in 2005? MR. PIKE: Same objection. THE WITNESS: I've already answered -MR. KUVIN: Wait. Wait. Same objection ~ MR. PIKE: Asked and answered. MR. KUVIN: -- means what? MR. PIKE: It's asked and answered, MR. KUVIN: Is that the only objection? MR. PIKE: And it still lacks the appropriate foundation. Page 150 BY MR. KUVIN: Q. Do you know what the word "massage" is? Do you know what that word means? A. I'm going to respond to that question the same way I've responded to most of your other questions here today, which is, | 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 that may be relevant to |; this lawsuit. I must accept their advice or risk losing my 6th Amendment right to effective representation. Accordingly, ! assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the # United States Constitution, f Q. Do you understand what I mean when I ask you about the year 2005? MR. PIKE: Form, vague and confusing. BY MR. KUVIN: Q. You can answer. A, I don't understand the question. Q. Do you understand what I mean by the year 20057 MR. GOLDBERGER: You just asked the same question. He said he didn't understand it. Just rephrase the quest Page 151 BY MR. KUVIN: Q. Do you understand dates? A. Like going on a date? Q. No. Like years, dates. 2001, 2000, do you know what that means? A. Yes. MR. KUVIN: Okay. So I just want to make sure. We've objected to the word "massage," Sth Amendment, he knows what a table is, he knows what dates and years are and he’s objected to his house. MR. GOLDBERGER: The question, Spencer, okay? Don't do that, please. MR. KUVIN: I'm trying to make sure that T have it all right here. MR. GOLDBERGER: All right, but don't verbalize your thoughts. Just ask a question, MR. KUVIN: Okay. MR. PIKE: I'm also going to move to strike counsel's last statement from the record. BY MR. KUVIN: Q. Did you have a massage table at your home in 2008? MR. PIKE: Same objection, lacks foundation, improper predicate. THE WITNESS: Tm going to prespond i to D that 34 (Pages 148 ‘to 151) {561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Etectronically signed by Jeana Ricciuti (601-280-428-9381) a4 caccd-2433-45cb-b6a2-c08426252179

ee SOESIAGK HEWN Page 152 Page 154 question the same way I've responded to most of 1 MR. PIKE: There was not a compound. your other questions here today, which is, I intend 2 MR. KUVIN: Okay. to respond to all relevant questions regarding this 3 MR. PIKE: The objection was foundation and lawsuit; however, at the present time, my attorneys 4 predicate. have counseled me J cannot provide answers to any 5 BY MR. KUVIN: questions that may be relevant to the lawsuit. I 6 Q. Okay. You can answer. must accept their advice or risk losing my 6th 7 A. I'm going to answer that question the way I've Amendment right to effective representation. 8 answered mest of your other questions here today. | Excuse me? 9 intend to respond to all relevant questions regarding BY MR. KUVIN: 10 this lawsuit; however, at the present time, my attorneys Q. I'm sorry, [just had a nasal problem, aa have counseled me J cannot provide answers to any A. Let me start from the beginning again. 12 questions that may be relevant to the lawsuit. { must Q. Whatever you'd like to do. 13 accept their advice or risk losing my 6th Amendment A. [intend to respond to all relevant questions 14 right to effective representation. Accordingly, I regarding this lawsuit. 1 should start again. 15 assert my federal constitutional rights as guaranteed by Q. Okay, Whatever you're comfortable doing. I 16 the 5th, 6th and 14th Amendment to the United States have all day. 17 Constitution. A. Lintend to respond to all relevant questions 18 Q. I'm going to show you a clip of a deposition regarding this lawsuit; however, at the present time, my 19 that was taken in this case and, first of all, ask attorneys have counseled me I cannot provide answers to} 20 you -- this is the deposition of L.M. that had been any questions relevant to this lawsuit. [must accept 21 previously taken in this case. their advice or risk losing my 6th Amendment right to 22 MR, PIKE: Wait a minute. effective representation. Accordingly, I must assert my 23 MR. KUVIN: You're welcome to watch. federai constitutional rights as guaranteed by the Sth, 24 MR. PIKE: I might -- 1 want it played to the 6th and 14th Amendment to the United States 25 video first. Page 153 Page 155 Constitution. 1 MR. KUVIN: Okay, J can do that. Q. Did you have a massage table in your upstairs 2 MR. PIKE: Okay. So let's play it to the bathroom in 20057 3 video first and then we'll determine what's next. MR. PIKE: Foundation, lacks appropriate 4 MR. KUVIN: Well, I'm going to ask him a predicate. 5 couple of questions first before | hit play. THE WITNESS: I'm going to respond to that 6 MR. PIKE: I need to see it first. question the same way I've responded to most of 7 MR. KUVIN: Come around and look. 1 want him your other questions here today, Mr. Kuvin, which 8 to see it at the same time, is, | intend to respond to all relevant questions 9 MR. PIKE: That's fine. [ want it played to regarding this lawsuit; however, at the present 10 the camera first. time, my attorneys have counseled me I cannot 11 MR. KUVIN: Oh, no. I'm not going to do your provide answers to any questions that may be 12 order, I'm going to just ask him first -relevant to the lawsuit. I must accept their 13 MR. PIKE: You need to -- you're asking the advice or risk losing my 6th Amendment right to 14 witness about an exhibit technically that is going effective representation. Accordingly, I assert my 15 to be utilized in this deposition that you have not federal constitutional rights as guaranteed by the 16 provided me first. So just like you would Sth, 6th and 14th Amendment to the United States a7 professionally provide me a document first, I'm Constitution. 18 asking that you provide me the video first, play it BY MR. KUVIN: 19 to the camera, or you and I can step outside and Q. Did you keep various massage oils, lotions, 20 you can play it to me and then you can ask the sexual devices and sexual toys in your upstairs bathroom} 21. witness, The witness wil] remain in here. You and in 2005? 22 1 can go into a different room, Then he's not MR. PIKE: Same objection, 23 going to answer any questions with regard to the MR. KUVIN: Wait aminute, is there a compound) 24 video, then I ask that it not -- you're not giving wu separate t them out. mea Soe that you're guestioning the suisse 35 a (Pages 152 to 155) (S61) 832-7500 Electronically signed by Jeana Riectutl (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 a@1caced-2433-45ch-b6a2-c0B425262179

Tee See Page 156 Page 158 on. It doesn't work that way. 1 lawsuit. I must accept this advice or risk losing my MR. KUVIN: Let me speak. You were provided] 2 6th Amendment right to effective representation. the deposition of L.M. Someone from your office 3 Accordingly, | assert my federal constitutional rights a was present and actually asking the questions. 4 as guaranteed by the Sth, 6th and 14th Amendment of the — This is not an exhibit that you do not have or did $ United States Constitution, fi not have previous. You've had this ever since the 6 Q. Did you watch her deposition as she was giving deposition was taken. So I'm not surprising you 7 it? with any new document or testimony or anything of 8 MR. GOLDBERGER; Attorney-client. the like, This is the exact same testimony of a 9 BY MR. KUVIN: witness who had been previously taken in this case 10 Q. Were you present and watching L.M.'s testimony and I'm not going to play it, I just want to see a it by closed-circuit camera as she gave her testimony in couple of questions first. I will agree with your 12 this case? procedure to play it to the camera first, and then 13 MR. PIKE: Attorney-client, work product. I will ask him questions after I've played it to 14 MR. GOLDBERGER: Attomey-client, work the camera about what I just played. i5 product. MR. PIKE: As long as -- 16 MR. PIKE: I'm going to instruct the witness MR. KUVIN: But I want some identification 17 hot to answer both of those questions. issues first, and that's alt. 18 MR. KUVIN: I'm going to piay one of the MR. PIKE: Let me clear something up. 1 was 19 clips. Teli me if you can get a clear shot of not at the deposition of L.M. Bob Critton and Mark} 20 this, |: Luttier -- 21 THE VIDEOGRAPHER: Is this going to be played| [ MR. KUVIN: Correct. 22 with audio? [i MR. PIKE: -- were at that deposition. 23 MR.KUVIN: Yes, and I'll put my mic so you F MR. KUVIN: Both attorneys at your office. 24 can pick it up. MR. PIKE: I have not seen this video. 25 MR. PIKE: And for purposes of the record, I Page 157 Page 1595 MR. KUVIN: Both attorneys at your office. 1 ‘want it to -- this camera to zero out from the Ee MR. PIKE: It doesn't matter. It doesn't 2 current deponent onto that. [ do not want my matter. 3 client in the background of this videotape. Is So as long as you agree to play the video 4 that understood? first to the camera -- 5 THE VIDEOGRAPHER: I've asked to get a shot of [? MR. KUVIN: Sure, 6 the computer screen and that's what I have, ei MR. PIKE: -- then you can proceed with your 7 MR. PIKE: Let me see what your shot is. questioning, 8 THE VIDEOGRAPHER: You're welcome to do so. MR. KUVIN: Sure. 9 MR. KUVIN: You got a clean shot? i MR. PIKE: And then you can play it to the 10 THE VIDEOGRAPHER: If he sticks his face in witness, but I want to see it first. 11 front of the computer, I can't do anything about MR, KUVIN: That's fine. That's fine. 12 it, but I've been asked to give a shot of the BY MR. KUVIN: 13 computer. That’s what I have. Q. Allright. I have a photograph here or a 14 MR, PIKE: Let's go. video clip showing a young lady who's been identified in | 15 MR. KUVIN: Okay, are we good? Clean shot? this case as L.M. Her deposition was given in this 16 (Video being played.) case. 17 VIDEO WITNESS: "And his little fetish with And just to lay some foundation, first, do you 18 me, pinching his nipples. He's probably getting recognize this girl? 19 hard right now." A. I'm going to respond to that question the way 20 (Video stopped.) 2%, I've responded to most of your other questions here 24 BY MR. KUVIN: 22 today, which is, I intend to respond to all relevant 22 Q. Okay. That’s ail. All right? Okay. 23 questions regarding this lawsuit; however, at the 23 Let me make sure that { have that. I'm going 24 present time, my attorneys have counseled me I cannot to play a clip for you that I just played for your 25 SSS ST ISI provide answers to any questions relevant to this oom = = 36 (Pages. 156 to 159) (561) 832-7500 Electronically signed by Jeana Riccluti (601-280-428-8381) Electronically signed by Jeana Ricciuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC. {561) 832-7506 a41caccd-2433-45ch-h6a2-c08425252179

Page 160 Page 162 1 it. 1 United States Constitution. 2 (Video being played.) 2 Q. Have you had underaged girls, which include E 3 VIDEO WITNESS: “And his little fetish with 3 B.B., in 2004, 2005 and 2006, massage your chest while |} 4 me, pinching his nipples. He's probably getting 4 they were naked? 4 $ hard right now." 5 A. Lintend to respond to all relevant questions 6 (Video stopped.) 6 to this lawsuit; however, at the present time, my 7 BY MR. KUVIN: 7 attorneys have counseled me I cannot provide answers to 8 Q. Do you have a fetish where you like young 8 any questions that may be relevant to this lawsuit. As & 9 women to pinch your nipples? 9 T've done with most of your questions here today, I must 10 A. I'm going to respond to that the same way i've 10 accept their advice or risk losing my 6th Amendment 11 responded to most of your other questions here today, 11 right to effective representation. Accordingly, I 12 which is, I intend to respond to all relevant questions 12 assert my federal constitutional rights as guaranteed by ff 13 regarding this lawsuit; however, at the present time, my 13 the 5th, 6th and 14th Amendment to the United States & 14 attorneys have counseled me I cannot provide answers to | 14 Constitution. 15 any questions relevant to this lawsuit. I must accept 15 Q. Does Mr. Wexner know of your sexual preference; 16 their advice or risk losing my 6th Amendment right to 16 for underaged girls, girls under the age of 172 17 effective representation. Accordingly, I assert my 17 MR. PIKE: Form, argumentative, harassing, 18 federal constitutional rights as guaranteed by the Sth, 18 assumes facts not in evidence. 19 6th and t4th Amendment to the United States 19 THE WITNESS: I’m going to have to answer that 20 Constitution. 20 the same way I've answered most of your questions aL MR. PIKE: And I assume, Mr. Kuvin, you will 21 here today, which is, I intend to respond to all Ee 22 provide me with the number on the roll that 22 relevant questions regarding this lawsuit; however, i 23 you're -- that you pretty much marked as an exhibit 23 at the present time, my attorneys have counseled me 24 here, where if starts numerically and where it ends 24 I cannot provide answers to any questions that may ff 25 numerically so I can pull it and we can have an 25 be relevant to the lawsuit. | must accept their | Page 161 Page I 1 exhibit made for purposes of this deposition. 1 advice or risk losing my 6th Amendment right to 2 2 MR. KUVIN: Oh, | don't intend to attach it as 2 effective representation. Accordingly, f assert my | 3 an exhibit to this deposition. 3 federal constitutional rights as guaranteed by the 4 MR, PIKE: Well, what were the -- where did it 4 Sth, 6th and 14th Amendment to the United States FE 5 start and where did it begin on the roll? 3 Constitution. 6 MR. KUVIN: I don't know, It’s a clip that I 6 BY MR. KUVIN: | 7 pulled from the master video. I can get it for you F Q. Did you pay B.B. $200 to come to your home in P 8 though. Ican certainly identify it in the 8 2008? E 9 transcript. 9 MR, PIKE: Form. E 10 MR, PIKE: So you'll provide that to me? 10 MR. KUVIN: I'm sorry, what's the form an MR. KUVIN: Yeah, I'll find a place in the al problem? 12 transcript for you, that's not 2 problem, 12 MR. PIKE: | don't need to provide you with a 13 BY MR. KUVIN: 13 speaking objection. The rules are the rules. 14 Q. Do you like to have underaged girls massage 14 You've clearly stated to me today that you don't 15 your legs, underaged being under the age of 18? 15 want speaking objections, and I've abided by that; 16 A, I'm going to respond to that question the same 16 therefore, the objection is form. 17 way I've responded to most of your other questions here j 17 MR. KUYVIN: I'm just asking for a 18 today, which is, I intend to respond to ail relevant 18 clarification so I can correct the question iff 19 questions regarding this lawsuit; however, at the i9 need to. 20 present time, my attorneys have counseled me I cannot 20 MR. PIKE: Ask your question again, Mr. Kuvin. 21 provide answers to any questions relevant to this 21 MR. KUVIN: Can you read it back for me? it 22 lawsuit. I must accept their advice or risk losing my 22 Thank you. a 23 6th Amendment tight to effective representation, 23 {A portion of the record was read by the E Accordingly, I assert my federal constitutional rights fe as guaranteed by the 5th, 6th and 14th Amendmet I'm going to respond to that i 37 (Pages 160 to 163) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Joana Ricciuti (601-280-428-9381) Electronically signed by Jeana Riccluti (601-280-428-9381) ad1caccd-2433-45cb-b5a2-c08425252079

Page 164 Page 166} (561) 832-7500 1 question in the same way I've responded to most of 1 and 14th Amendment to the United States 2 your other questions here today, which is, I intend 2 Constitution, 3 to respond to all relevant questions regarding this 3 THE VIDEOGRAPHER: Spencer, can we take a 4 lawsuit; however, at the present time, my attorneys 4 quick break? 5 have counseled me I cannot provide answers to any 5 MR. KUVIN: Change tape? 6 questions that may be relevant to this lawsuit. I 6 THE VIDEOGRAPHER: No, a problem with your |] 7 must accept their advice or risk losing my 6th 7 mic. I just want to go off for a second and see if 8 Amendment right to effective representation, 8 we can fix it. 9 Accordingly, | must assert my federal 9 MR. KUVIN: Sure. 10 constitutional rights as guaranteed by the 5th, 6th 10 THE VIDEOGRAPHER: We're off the record at 11 and 14th Amendment to the United States ah 1:03 p.m. 12 Constitution. 12 (A brief recess was taken.) 13 MR. PIKE: Same objection. 13 14 BY MR. KUVIN: 44 15 Q. You knew B.B. was 15 years old when she came | 15 16 to your home, didn't you? 16 17 MR. PIKE: Form. 17 18 THE WITNESS: I'm going to respond to that 18 19 question the same way I've responded to most of 19 20 your other questions here today, which is, I intend 20 21 to respond to all relevant questions regarding this 21 22 lawsuit; however, at the present time, my attomeys 22 23 have counseled me I cannot provide answers to any | 23 24 questions relevant to this fawsuit. 1 must accept 24 25 their advice or risk losing my 6th Amendment right 25 Page 165 Page 167 1 to effective representation. Accordingly, I assert 1 CERTIFICATE OF OATH 2 my federal constitutional rights as guaranteed by 2 THE STATE OF FLORIDA 3 the Sth, 6th and L4th Amendment to the United 3 COUNTY OF PALM BEACH 4 States Constitution. : p> (PY MERUVIN: 6 I, the undersigned authority, certify that 6 Q. What is the Wexner Children's Trust, the 7 JERFREY EPSTEIN Can ee before me and was ? second? 8 duly sworn on the 8th day of October, 2009. 8 MR. PIKE: Can you restate your question 9 9 again? 10 Dated this 8th day of October, 2009. 10 BY MR. KUVIN: 1. ql Q. Yes. What is the Wexner's Children's - I'm 12 12 sorry, Wexner, singular, Children’s Trust II, or the 13 14 13 second? 14 MR, GOLDBERGER: Okay. 15 15 THE WITNESS: I'm going to have to respond to Jeana Ricciuti, RPR, FPR, CLR 16 that question the same way I've responded to most 16 Notary Public - State of Florida 17 of your other questions here today, Mr. Kuvin, My Conunission Expires: 2/17/2013 18 which is, I intend to respond to all relevant 17 My Commission No.: DD 854778 19 questions regarding this lawsuit; however, at the 18 20 present time, my attorneys have counseled me I OG 21 cannot provide answers to any questions relevant to | 54 22 this lawsuit. I must accept this advice or risk 22 23 losing my 6th Amendment right to effective 23 representation. Accordingly, I assert my federai 24 constitutional Tights as guaranteed by the Sth, Sth 25 38 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciut! (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) (Pages 164 to 167) {561) 832-7506 a41 caced-2433-45ch-b5a2-c08425252179

CERTIFICATE THE STATE OF FLORIDA. COUNTY OF PALM BEACH 1, Jeana Ricciuti, Registered Professional Reporter and Notary Public in and for the State of Florida at large, do hereby certify that I was authorized to and did report said deposition in stenotype, and thet the foregoing pages are a true and correct transcription of my shorthand notes of said deposition. J fusther certify that said deposition was. taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out. farther certify that I ama not attomey or counsel of any of the parties, nor am I a relative or employce of any attorney or counsel of party connected with the action, nor am i financially interested in the action. “The foregoing certification of this transcript does not apply to any reproduction of the samme by any means unless under the dizect control and/or direction of the certifying reporter. Dated this 8th day of October, 2009. Page 168 WOIKRTERWNE CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH {hereby certify that [ have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of 2009, JEFFREY EPSTEIN DATE: October 22, 2009 TO: | SEFFREY EPSTEIN lo Michae! J Pike BURMAN, CRITTON, LUTTIER & COLEMAN, P.A. 308 Banyan Boulevard Suite 400 ‘West Pal Beach, Flerida 33401 INRE: 8, v, EPSTEDN Pleate take notice that on Thursday, the St of Ontober, 2009, you gave your deposition i the bove-referred matter, At that time, you did tot waive signature, His now necessary thai you sign your deposition. As proviously agreed to, the Iransciipt will bo furnished to you through your counsel. Plaaye read the following isiractione carefully ‘Atthe end ofthe transeipt you will find an crram theet, As yoo tead your deposition, any changes or corrections that you with to make stould be noted on the errata shee, citing page and line muraber of said shasge. DO NOT write on the transerptitselt, Ones you have read the transcript and noted any changes, be sure w sign and date the oreia sheet aad return these pages 19 me, SF you do not read and sign the deposition within a reasonable time {(-e. 30 days unless otherwise dicected) the orginal, which has already been forwarded to the ocdesing atomey, inay be filed with the Clerk of tho Court Hf you with to waive your signeture, sig ‘your name in the blank at the bottom ofthis lll ard fetom ittous Very traly yours, Jeane Riocint, RFR, EPR, CLR, Prono Court Reporting Agency, INC. 2508, Auatialian Avenve, Slo 1500 West Palm Beach, Floviéa 3240t {do hereby veive my signature (561) 832-7500 Etectronically signed by Jeana Riccluti (601-280-428-9384) Electronically signed by Jeana Ricciuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, ERRATA SHEET IN RE: BB. v, EPSTEIN CR: JEANA RICCIUTI DEPOSITION OF; JEFFREY EPSTEIN TAKEN; October 8, 2009 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGE# LINE# CHANGE Please forward the original signed errata sheet to this, office so that copies may be distributed to all parties. Under penalty of perjury, I declare that I heve read iy. deposition and that it is true and correct subject to any changes in form or substance entered here. DATE: SIGNATURE OF DEPONEN’ (Pages 168 to 171) (561) 832-7506 39 INC. a41caccd-2433-45cb-b6a2-c08425262179

E E E NS TST TTT TTT TTT TT TA TT TL LT TI Page 172 Page 174 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT | 1 --IN AND FOR PALM BEACH COUNTY, FLORIDA 5 EXHIBITS CASE No, $02008CA037319XXXXMB AB eS ae 5 BYMR.KUVIN. 175 6 BB., ? Plaintiff, 8 Baie EXHIBITS vs 2 aie 10 NUMBER DESCRIPTION PAGE JEFFREY EPSTEIN, 22° PLAINTIFFS EC 9. / PHOTOGRAPH OF GHIBLAINE. 182 Defendant. : 12 PLAINTIFFS EX. 10 PHOTOGRAPH OF JOANNA 191 SHOGERT 13 PLAINTIFFS EX. 11 PHOTOGRAPH OF EULA MAXWELL 196 PLAINTIFF'S EX, 12 PHOTOGRAPH 198 CONTINUED DEPOSITION OF JEFFREY EPSTEIN 14 PLAINTIFFS EX. 13. PHOTOGRAPH OF SARAH KELLEN 199 VOLUME Hil PLAINTIFFS EX. 14 PHOTOGRAPH OF NADIA 200 1s MARCINKOVA Thursday, October & 2009 PLAINTIFFS EX. 15 PHOTOGRAPH OF HALEY ROBSON 201 16 PLAINTIFFS BX. 16 PHOTOGRAPH OF PRINCE — 201 1:46 - 3:48 pan. ANDREW 17 PLAINTIFFS EX. 17 LETTER TOB. KRISCHER FROM 203 250 South Australian A\ M. REITER eee ae 18 PLAINTIFFS EX. 18 RECEIPT OF PURCHASES MADE 206 : FROM JAIL ‘West Fal Resch Plonde. 3340! 19 PLAINTIFFS EX, 19 FAA REGISTRY 218 20 Reported By: 21 Jeana Ricciuti, RPR, FPR, CLR. 22 Notary Public, State of Florida 23 Prose Court Reporting Agency, Inc. 24 25 173 Page 175} r 5 2 Onbetlttiie Maite ; PROCEEDINGS 3 ADAM LANGINO, ESCUIRE ae LEOPOLD KUYIN, P.A. 3 THE VIDEOGRAPHER: We're back on the record at 4 22SFOA Boulos 4 146. : ite 46. 5 Palm Beach Gardens, Florida 33410 alm Beas arden, Hoss 5 CONTINUED DIRECT EXAMINATION s On behalf of LM, and BW. and Jane Doc in Case Ni $ BY. MR-RUVIN: ¢ ime ee ee 7 Q, Do you personally know John Mack, former CEO 8 ROTMSTUN ROSENRELDT @ ADLER 8 at Morgan Stanley? 5 Bast Las Ole Boulevard 9 A. I'llhave to answer that the same way I've a Fost Lander, Flite 33901 10 answered most of your questions here today, Mr. Kuvin, ai ‘On behalf of Pisintift fan Doe in Caze No. 8059) and ll which is, } intend to respond to al] relevant questions 12 eee wiamlaphooe ESQUIRE 12 regarding this lawsuit; however, at the present time, my ia Sean PA. 13 attorneys have counseled me I cannot provide answers to Mean aie 33 130 14 any questions relevant to this lawsuit. 1 must accept 15 On behalf of the Defendant: 15 this advice or tisk losing my 6th Amendment right to i“ TORY RoWUn PaRaeGaL 16 effective representation. Accordingly, 1 assert my to BUTERBURY, GOLDBERGER & WEL, Pa 17 federal constitutional rights as guaranteed by the Sth, Suite 1400 18 6th and 14th Amendment to the United States 13 ‘West Palm Bosch, Florida 3340) ER Phone: 561.689.8300 19 Constitution. 19 yarast 1. ee, squiRe 20 MR. KUVIN: Okay. Same deposition as shown 20 pepe petted aaa 21 before, different clip. Fm going to play it for i Sale 400 - 22 counsel first. ‘West Palm Beach, Florida 33401 22 Phone: $61.842.2820 23 MR. PIKE: Thank you. 23 ALSO PRESENT: n . tH DIN DOSER VIDRGORAPIIBE’ 24 MR. KUVIN: Mr. Videographer, just tet me know bs VISUAL EVIDENCE, 190. 25 when you're ready. 2S SS aE (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Riccititi (601-280-428-938t) Electronically signed by Jeana Ricciuti (601-280-428-9381) 1 (Pages 172 to 175) (661) 832-7506 bfBd9df0-4icb-496c-a244-0999770731 34

Page 176 THE VIDEOGRAPHER: Whenever you are. MR. KUVIN: Okay. {Video played.) VIDEO WITNESS: "What did I do to Jeffrey and what did Jeffrey do to me? I went up there multiple times; I can't count. And I would be on a massage table, massaging his legs, he would turn over, his penis would be hanging out. He would put a vagina -- or a vibrator to my vagina. He would touch my vagina with his fingers. He would touch my breasts. He would try to kiss my mouth. He would bring my hands toward his penis.” (Video stopped.) MR. KUVIN: Okay. MR. PIKE; I'm just going to object to the use of the video as to relevance, predicate and foundation. MR. KUVIN: Exactly. MR. PIKE: Same objection. (Video played.) VIDEO WITNESS: "What did I do to Jeffrey and what did Jeffrey do to me? I went out there multiple times; | can't count. And I would be ona massage table, massaging his legs. He wouldtum = over, his penis would be hanging out. He would put ff a vagina -- or vibrator to my vagina, He would touch my vagina with his fingers. He would touch my breasts. He would try to kiss my mouth. He would bring my hands toward his penis." (Video stopped.) BY MR. KUVIN: Q. Did you do that with that girl? MR, PIKE: Form. THE WITNESS: 1 intend to respond to all OSIM BwWNHE BY MR. KUVIN: Q. Allright. Let me get it back to the same location. Sir, first of all, once again, just so T can lay the foundation for this, do you recognize this girl? A, I'm going to have 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 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. 1 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 Sth, 6th and 14th Amendment to Page 177 all relevant cannot provide answers to any questions relevant to this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions relevant to the lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, | assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the United States Constitution. Q. Did this girl bring B.B. to your home for a naked massage? A. I'm going to have to respond to that 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 the lawsuit. 1 must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, | assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the United States Constitution. Q. I'd like to play this clip for you and then T'm going to ask you a question. MR. PIKE: The same clip you just played? (561) 832-7500 Electronically signed by Jeana Riccluti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 179] the United States Constitution. BY MR. KUVIN: Q. Did you do what that young lady described just now to hundreds of women, including B.B.? MR. PIKE: Form, argumentative, harassing, lacks appropriate predicate, foundation, lacks identity. E THE WITNESS: Excuse me. I'm going to respond f to that 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 that I cannot provide answers to any questions relevant to the lawsuit. 1 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 Sth, 6th and 14th Amendment to the United States Constitution. BY MR. KUVIN: Q. While B.B. was standing naked in your home, specifically in your bathroom, did you teil her that you couid get her an interview as a model because of your connections? 2 (Pages 176 to 179) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 bfBd9df0-4fcb-496c-a244-099977073134

Page 180 responded to most of your questions today, Spencer. 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 this advice or tisk losing my 6th Amendment right to effective representation. Accordingly, | must assert my federal constitutional right as guaranteed by the Sth, 6th and 14th Amendment to the United States Constitution. MR. PIKE: Same objection to that line of questioning. BY MR. KUVIN: Q. As B.B. was standing naked in your bathroom before you when she was 15, did you ask her to turn around so you could see her ass better? MR. PIKE: Form, argumentative, harassing, jacks appropriate predicate, foundation. THE WITNESS: fil respond to that as [ responded to your fast question, 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 wWOIAEeswne Constitution. BY MR. KUVIN: Q. Who is Ghislaine Maxwell? A. [intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. As! have done to most of your other questions here today, 1 must accept their advice or risk losing my 6th Amendment E right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the United States Constitution. MR. KUVIN: Let me show the camera what we'll mark as Exhibit 9 to this deposition. THE VIDEOGRAPHER: Okay. (Plaintiff's Exhibit No. 9 was marked for identification.) BY MR. KUVIN: Q. Let me show you what we've marked as Exhibit 9 to your deposition, Do you recognize Ghislaine Maxwell in this photograph? A, Yes. Q. And who is she standing with? A. Her father, Page 181 Amendment right to effective representation; therefore, I must assert my federal constitutional rights as guaranteed by the Sth, 6th and L4th Amendment to the United States Constitution. BY MR. KUVIN: Q. When B.B, was 15 years old and standing naked in front of you in your bathroom, did you tell her that you could help her become a model? MR. PIKE: Same objections, including foundation. THE WITNESS: Is it different than the last question? MR. KUVIN: Ub-huh. MR. GOLDBERGER: Just go ahead. THE WITNESS: Okay. | intend to respond to alt relevant questions pertaining to 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, so I've answered most questions here today the same way. I must expect that —~ accept their advice or risk losing my 6th Amendment right to effective representation. Accordingly, | assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Smenaieent to the United States (561) 832-7500 Etectronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC. Page 183 . And her father is Robert Maxwell? . Was Robert Maxwell. . I'm sorry, he's passed, correct? . Correct. . She is a close friend of yours, is she not? I'm going to respond to that question the same way Ive responded to most of your other questions here {) today, Mr. Kuvin, which is, ] intend to respond to all relevant questions regarding to this lawsuit; however, at the present time, my attorneys have counseled me | cannot provide answers to any questions that may be relevant to this lawsuit, 1 must expect -- accept their advice or risk losing my 6th Amendment right to I effective representation, Accordingly, I must assert my [i federal constitutional rights as guaranteed by the Sth, 6th and L4th Amendment to the United States Constitution. Q. Ghislaine Maxwell has accompanied you to numerous social events in the last few years; isn't that true? MR. PIKE: Form. THE WITNESS: I'm going to respond to that question the same way I've responded to most of your questions here today, which is, 1 intend to a to all relevant questions regardi ing y 3 (Pages 180 to 183) (561) 832-7506 bfBd9df0-4fcl-496¢-a244-0999770731 34

Page 184 Page 186 B 1 lawsuit; however, at the present time, my attorneys 1 Constitution. k 2 have counseled me 1 cannot provide answers to any 2 BY MR. KUVIN: a 3 questions that may be relevant to that lawsuit. I 3 Q. Did Ms. Maxwell procure underaged girls for E 4 must accept their advice or risk losing my 6th 4 you to have sexual relationships with? 5 Amendment right to effective representation. 3 A. I'm going to answer that question the same way 6 Accordingly, I must assert my federal 6 T've answered most of your other questions today, 7 constitutional right as guaranteed by the Sth, 6th 7 Mr. Kuvin, which is, I intend to respond to all relevant 8 and 14th Amendment of the United States 8 questions regarding this lawsuit; however, at the 9 Constitution. 2 present time, my attorneys have counseled me I cannot 10 BY MR. KUVIN: 10 provide answers to any questions relevant to that E 1i Q. One of your houseboys that has been deposed inj 11 lawsuit. Excuse me. I must accept their advice or risk 12 this case testified that you were a rather nice 12 losing my 6th Amendmeni right to effective i3 gentleman that used to talk to the staff, and that when 13 representation. Accordingly, | must assert my federal 14 Ms. Maxwell came into the picture, that you stopped 14 constitutional rights as guaranteed -- guaranteed by the ff 15 talking to the staff and the staff had to communicate 15 Sth, 6th and f4th Amendments to the United States 16 through Ms. Maxwell. Do you agree or disagree with 16 Constitution. l 17 that? 17 Q. Ms. Maxwell procured a particular underaged =f 18 MR, PIKE: Form, foundation, predicate, 18 girl who worked at Donaid Trump's Maralago, for you to § 19 argumentative, assumes facts not in evidence. 19 have a sexual relationship with; isn't that true? [ 20 THE WITNESS: I'm going to answer that the 20 MR, PIKE: Form, argumentative, lacks i 21 same way I've answered most of your questions here} 21 appropriate predicate, foundation, assumes facts [ 22 today, which is, I intend to respond to all 22 not in evidence. li 23 relevant questions regarding this lawsuit; however, 23 THE WITNESS: I'm going to respond to that the |, 24 at the present time, my attorneys have counseled me | 24 same way I've responded to most of your other [: 25 that I cannot provide answers to any questions that 2s questions here today, Mr. Kuvin, which is, intend ff Page 185 Page 187 1 may be relevant to your lawsuit. I must accept 1 to respond to all relevant questions regarding this 2 their advice or risk losing my 6th Amendment right 2 lawsuit; however, at the present time, my attorneys [i 3 to effective representation. Accordingly, J assert 3 have counseled me cannot provide answers to any [ 4 my federal constitutional rights as guaranteed by 4 questions relevant to that lawsuit. J must accept E 5 the 5th, 6th and 14th Amendment of the United 5 their advice or risk losing my 6th Amendment right E 6 States Constitution. 6 to effective representation. Therefore, I assert L he BY MR. KUVIN: 1 my federal constitutional rights as guaranteed by i 8 Q. He also testified that he felt you were a 8 the Sth, 6th and 14th Amendments to the United i 9 rather normal guy until Ms. Maxwell came into the 9 States Constitution. B 10 picture, and that she led you into this life of 10 BY MR. KUVIN: fe il perversion, sexual perversion. Do you agree with that? | 11 Q, Do you know where Donald Trump's Maralago E 12 MR. PIKE: Same objections. 12 estate is? E 13 THE WITNESS: I'm going to respond to thatthe} 13 A. Yes. Ee 14 same way I've responded to most of your questions | 14 Q. Have you been there? E 15 here today, Mr. Kuvin, which is, I intend to 15 A. Yes. E 16 respond to all relevant questions regarding this 16 Q. Who with? E 17. Tawsuit; however, at the present time, my attorneys 17 A. I'm going to have to answer that question the 18 have counseled me { cannot provide answers to any ; 18 same way I've answered most of your other questions here | 19 questions relevant to this lawsuit, I must accept 13 today. I intend to respond to all relevant questions E 20 their advice or risk losing my 6th Amendment -- 20 regarding this lawsuit; however, at the present time, my — 21 excuse me ~ I must accept their advice or risk 21 attorneys have counseled me I cannot provide answers to |} 22 losing my 6th Amendment right to effective 22 any questions that may be relevant to the same lawsuit, 23 representation. Accordingly, I must assert my 23 I must accept their advice or risk losing my 6th [; 24 federal constitutional rights as guaranteed by the 24 Amendment right to effective representation. 25 3th, 6th and 14th Amendment to the United States 25 Accordingly, | 1 mnust assert my federal Constitutional 4 (Pages 184 to 187) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuiti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) bfBd9df0-4fch-496c-a244-09997 7073134

Page 188 Page 190} 1 rights as guaranteed by the Sth, 6th and 14th Amendment 1 same lawsuit, I must accept their advice or risk losing f 2 to the United States Constitution. 2 my 6th Amendment right to effective representation. 3 Q. Have you seen the high school transcripts 3 Accordingly, I must assert my federal constitutional 4 grades of girls that you have had sexual relationships 4 rights as guaranteed by the 5th, 6th and 14th Amendment, F 5 with dating back to 2005? 5 Q. Did you have photographs of girls under the i 6 MR. PIKE: Form, relevance, improper 6 age of ten who were nude, either partially or fully i 7 hypothetical, lacks facts -- assumes facts not in o nude, in your home on Palm Beach in 2005 and 2006? 8 evidence, lacks appropriate predicate, foundation. 8 MR, PIKE: Form. 9 THE WITNESS: I'm going to answer that 2 THE WITNESS: I'm going to respond to that 10 question the same as I've answered most of your 10 question the same way I've responded to most of ai other questions here today, Mr. Kuvin, which is, I a your other questions, which is, I intend to respond 12 intend to respond to ail relevant questions 12 to all relevant questions regarding this lawsuit; 13 regarding this lawsuit; however, at the present 13 however, at the present time, my attorneys have E 14 time, my attorneys have counseled me that I cannot 14 counseled me | cannot provide answers to any L 15 provide answers to any questions that may be 15 questions relevant to this lawsuit, I must accept E 16 relevant to this lawsuit. I must accept their 16 this advice or risk losing my 6th Amendment right 17 advice or risk losing my 6th Amendment right to 1? to effective representation, Accordingly, I assert i 18 effective representation. Accordingly, I assert my 18 my federal constitutional rights as guaranteed by E 19 federal constitutional rights as guaranteed by the 19 the 5th, 6th and I4th Amendments of the United i 20 Sth, 6th and 14th Amendment to the United States 20 States Constitution, ; 21 Constitution. 21 THE VIDEOGRAPHER: Mr. Kuvin, I'm sorry I have 22 BY MR. KUVIN: 22 to change. 23 Q. Do you deny that the high school transcripts 23 MR. KUVIN: Go ahead. 24 which were found in your trash on Palm Beach that showed | 24 THE VIDEOGRAPHER: We'll go off the record at 25 the ages of some of the girls you were engaged with 25 2:03. This will be the end of tape No. 2. Page 189 Page 191 1 sexual acts with at your home came from your house? 1 MR. GOLDBERGER: Break time? F 2 MR. PIKE: Same objection in addition to 2 MR. KUVIN: No, not again. Please not. 3 argumentative and harassing, 3 Just let us know when you're good to go. 4 THE WITNESS: | intend to respond to all 4 THE VIDEOGRAPHER: We're back on the record at E 5 relevant questions regarding this lawsuit; however, 5 2,04. This will be the beginning of tape No, 3. A 6 as I've done with most of your other questions 6 BY MR. KUVIN: F 7 today, at the present time my attorneys have 7 Q. Do you have security cameras throughout your [ 8 counseled me that I cannot provide answers to any & home on Palm Beach Island? E 9 of those questions relevant to this lawsuit. I 9 A. I'm going to answer that question the same way f 10 must accept their advice or risk losing my 6th 10 I've answered most of your questions here today, LE 21 Amendment right to effective representation. il Mr. Kuvin. [intend to respond to ali relevant 12 Accordingly, I must assert my federal 12 questions regarding this lawsuit; however, at the E 13 constitutional rights as guaranteed by the 5th, 6th 13 present time, my attorneys have counseled me I cannot fe 14 and 14th Amendments to the United States 14 provide answers to any questions relevant to the L as Constitution. 15 lawsuit. I must accept their advice or risk losing my ) 16 BY MR. KUVIN: 16 6th Amendment right to effective representation, B 17 Q. Did you have numerous photos of nude young | 17 Accordingly, | assert my federal constitutional rights E 18 women, girls under the age of 18, back in your home 18 as guaranteed by the Sth, 6th and 14th Amendment to the 19 in - on Palm Beach Island in 2005 and 2006? 19 United States Constitution. 20 A. I'm going to have to respond to that question 20 (Plaintiff's Exhibit No. 10 was maiked for 21 the same way Fve responded to most of your questions | 21 identification.) 22 here today, which is, 1 intend to respond to all 22 MR, KUVIN: fH show the camera a photograph 23 relevant questions regarding this lawsuit; however, at 23 here. Okay? 24 the present time, my attorneys have counseled me I 24 THE VIDEOGRAPHER: Liftit up. Yeah, there 25 cannot provide westions relevant to the | 25 u go. Okay. 5 (Pages 188 to 191) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) bf8d9df0-4fch-496c-a244-099977073134

Page 192 Page 194 (561) 832-7500 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9361) 1 MR. KUVIN: Okay? 1 effective representation. Accordingly, I must assert my 2 BY MR. KUVIN: 2 federal constitutional rights as guaranteed by the 5th, 3 Q. Let me show you what we marked as Plaintiff's 3 6th and 14th Amendment to the United States 4 Exhibit 10. Do you recognize this young lady? 4 Constitution. 5 A. Yes, 5 MR. PIKE: In addition, relevance. 6 Q. Who is she? 6 BY MR. KUVIN: 7 A. Her name is Joanna Shogert (phonetic). 7 Q. Do you pay Ms. Maxwell a salary? 8 Q. And who is she? a MR. PIKE: Form. 9 A. Ijust -- her name is Joanna Shogert. 9 BY MR. KUVIN: 10 Q. How do you recognize her? 10 Q. Ghislaine Maxwell, so we're clear. Do you pay iL A. Idon't understand the question. 11 her a salary? 12 Q. Well, is she a friend of yours? Did she work 12 I'd like -- excuse me. I'm going to answer 13 for you? How do you recognize her? 13 that question the same way I've answered most of your 14 A. How do I recognize her? 14 questions here today, which is, I intend to answer all 415 Well, I'd like to respond to that question as questions relevant to this lawsuit; however, at the 16 but, however, my attorneys have told me that I can't 16 present time, my attorneys have counseled me I cannot a7 respond to any questions today that may -- excuse me, T} 17 provide answers to any questions relevant to this 18 intend to respond to ail relevant questions regarding 18 Jawsuit. 1 must accept their advice or risk losing my 19 this lawsuit; however, at the present time, my attorneys | 19 6th Amendment right to effective representation. 20 have counseied me that I cannot provide answers to any | 20 Accordingly, I assert my federal constitutional rights 21 questions relevant to this lawsuit, 1 must accept their 2i as guaranteed by the 5th, 6th and 14th Amendment to the 22 advice or risk losing my 6th Amendment right to 22 United States Constitution. 23 effective representation, Accordingly, I assert my 23 Q. Did you provide any underaged girls for sex to 24 federal constitutional rights as guaranteed by the Sth, 24 Prince Andrew? 25 6th and 14th Amendment to the United States 25 MR. PIKE: Form. E Page 193 Page 195 1 Constitution. 1 THE WITNESS: I'm going to respond to that 2 Q. Did you have sex with Joanna Shogert? 2 question the same way I've responded to most of 3 A. I'm going to answer that question like I've 3 your questions here today, Mr, Kuvin, which is, 1 4 answered most of your questions here today, which is, 1 4 intend to respond to all relevant questions 5 intend to respond to all relevant questions regarding 5 regarding this lawsuit -- excuse me, however, at 6 this lawsuit; however, at the present time, my attorneys 6 the present time, my attorneys have counseled me I h have counseled me | cannot provide answers to any 7 cannot provide answers to any questions relevant to 8 questions relevant to this lawsuit. I must accept their 8 the lawsuit, or might be relevant to the lawsuit, F 9 advice or risk losing my 6th Amendment right to 9 I must accept their advice or risk losing my 6th 10 effective representation. Accordingly, I assert my 10 Amendment right to effective representation. 11 federal constitutional rights as guaranteed by the Sth, 1. Accordingly, I assert my federal constitutional 12 6th and 14th Amendment to the United States 12 rights as guaranteed by the Sth, 6th and 14th 13 Constitution. 13 Amendment of the United States Constitution. 14 Q. When did you first meet Prince Andrew? 14 BY MR. KUVIN: E 1s And let me make it a compound question so I 15 Q. Did you fly with Prince Andrew on your plane, F 16 don't have to repeat it over and over. When did you 16 or planes, with any underaged girls, girls under the age f 17 first meet Prince Andrew, under what conditions did you} 17 of 18? E 18 meet him, and who was present at that first meeting? 18 A, I'm going to answer that question the same way # 19 A. I'm going to answer that question as I've done 19 I've answered all the other questions here today, 20 most of your questions here today, Mr. Kuvin, which is, | 20 virtually, which is, I intend to respond to all relevant 21 intend to respond to all relevant questions regarding ai questions regarding this lawsuit; however, at the 22 this lawsuit; however, at the present time, my attorneys | 22 present time, my attorneys have counseled me I cannot § 23 have counseled me { cannot provide answers to any 23 provide answers to any questions relevant to the 24 questions relevant to that lawsuit. [ must accept their 24 fawsuit. I must accept their advice or risk losing my advice or risk i 25 6th Amendment Tight tos effective representation, PROSE COURT REPORTING AGENCY, 6 (Pages 192 to 195) INC. (561) 832-7506 biad9df0-4fch-496c-a244-099677073134

Page 196 Page 198 H 1 Accordingly, | must assert my federal constitutional 1 guarantee -- guaranteed by the Sth, 6th and 14th 2 rights as guaranteed by the Sth, 6th and 14th Amendments} 2 Amendment to the United States Constitution. [3 3 to the United States Constitution. 3 (Plaintiff's Exhibit No. 12 was marked for i 4 Q. Do you know Christine Drangsholt? 4 identification.) L 5 MR, KUVIN: For the court reporter, it's 5 MR. KUVIN: Let me show to the camera what 6 D-R-A-N-G-S-H-O-L-T. 6 we've marked as Exhibit 12. fe t THE WITNESS: J intend to respond to all 7 BY MR. KUVIN: E 8 relevant questions regarding this lawsuit; however, 8 Q, Let me show you what I've marked as Exhibit 9 at the present time, my attorneys have counseled me 9 12. Do you recognize any of the girls in that E 10 } cannot provide answers to any questions relevant 10 photograph? f 12 to the lawsuit, 1 must accept this advice or risk 1i A. I'm going to answer that question the same way E 12 losing my 6th Amendment right to effective 12 I've answered most of your other questions here today, | 13 representation, Accordingly, I assert my federal 13 Mr. Kuvin, which is, I intend fo respond to all relevant 14 constitutional rights as guaranteed by the 5th, 6th 14 questions regarding this lawsuit, however, at the E 15 and 14th Amendments to the United States 15 present time, my attorneys have counseled me that I 16 Constitution. 16 cannot provide answers to any questions that may be 17 MR. KUVIN: Let me show the camera what we'll | 17 relevant to the lawsuit. I must accept their advice or 18 mark as Exhibit 11. 18 risk losing my 6th Amendment right to effective 19 (Plaintiff's Exhibit No. 11 was marked for 19 representation. Accordingly, I assert my federal 20 identification.) 20 constitutional rights as guaranteed by the 5th, 6th and fj 21 THE VIDEOGRAPHER: Okay. 21 14th Amendment to the United States Constitution. f 22 MR. KUVIN; Okay? 22 Q.. Sir, isn't it ue that in what we've marked [ 23 BY MR. KUVIN: 23 as Plaintiff's Exhibit 12, the blond standing on the [: 24 Q. In Exhibit 11, sir, you're standing with a 24 left is Nadia Marcinkova, and the blonde, dirty blonde | 25 woman. Who is that woman in that photograph? 25 standing on the right is Sarah Kellen? Page 197 Page 199% 1 A. Eula Maxwell (phonetic). 1 A. [intend to respond to ali relevant questions 2 Q. Where were you? 2 regarding this lawsuit; however, as I've done to most of E 3 A. Lintend to respond to all relevant questions 3 the questions at the present time, my attorneys have : 4 regarding this lawsuit; however, at the present time, my 4 counseled me that I cannot provide answers to any of 5 attorneys have counseled me I cannot provide answers to 5 those questions that may be relevant to the lawsuit. I q 6 any questions that may be relevant to this lawsuit. I 6 must accept this advice or risk losing my 6th Amendment i 2 must accept this advice or risk losing my 6th Amendment af. right to effective representation. Accordingly, I 8 right to effective representation. Accordingly, I must 8 assert my federal constitutional rights as guaranteed by 9 assert my federal constitutional rights as guaranteed by g the Sth, 6th and 14th Amendments of the United States i 10 the Sth, 6th and 14th Amendments to the United States 10 Constitution. lz 11 Constitution. 12 BY MR. KUVIN: : 12 MR. KUVIN: And just so the court reporter 12 Q. I'm going to show you what we'll mark as B 13 knows, Ghislaine is spelled G-H-I-S-L-A-I-N-E. 13 Exhibit 13. Let me show it to the camera, first. B 14 BY MR. KUVIN: 14 (Plaintiff's Exhibit No. 13 was marked for r 15 Q. Who is Nadia Marinkova -- Marcinkova, excuse 15 identification.) E 16 me? 16 BY MR. KUVIN: 17 A. Tm going to answer that question the same way | 17 Q. Sir, is it true that Exhibit 13 shows your 18 I've answered most of your questions here today, which | 18 personal assistant, Sarah Kellen? : 19 is, I intend to respond to all relevant questions 19 A. intend to respond to all relevant questions 20 regarding this lawsuit, however, at the present time, my 20 regarding this lawsuit; however, at the present time, my 21 attorneys have counseled me I cannot provide answers to | 22 attorneys have counseled me that 1 cannot provide 22 any questions relevant to the lawsuit. | must accept 22 answers to any questions that may be relevant to this 23 their advice or risk losing my 6th Amendment right to 23 jawsuit, 1 must accept their advice or risk losing my 24 effective representation, Excuse me. Accordingly, I 24 6th Amendment right to effective representation. le 25 must assert my federal constitutional rights as Accordingly, } assert my federal constitutional rights 7 (Pages .196 to 199) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (S61) Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Riccluti (601-280-428-9381) 832-7506 bfBd9dt0-4fcb-496c-a244-099977073134

Page 200 Page 202 1. as guaranteed by the 5th, 6th and 14th Amendment to the 1 marked as Exhibit 16. 2 United States Constitution. 2 BY MR. KUVIN: 3 Q. Let me show you what we'll mark as Exhibit 14. 3 Q. Do you recognize the gentleman in that 4 (Plaintiff's Exhibit No. 14 was marked for 4 photograph, sit? 5 identification.) S MR. PIKE: Hold on for a second. 6 BY MR. KUVIN: 6 MR. GOLDBERGER: Do you want to discuss it q Q. Sir, does Exhibit 14 show Nadia Marcinkova, a 7 with me? 8 girl that you have had a sexual relationship with since 8 MR, PIKE: Let's take a break for one minute. 9 before she was 18 years old? 9 MR, KUVIN: Alf right. 10 MR. PIKE; Form, argumentative, harassing, 10 THE VIDEOGRAPHER: Off the record at 2:16. 11 assumes facts not in evidence, lacks appropriate il (A brief recess was taken.) 12 predicate and foundation. 12 THE VIDEOGRAPHER: We're back on the record at 13 THE WITNESS: { intend to respond to all 13 2:45. ' 14 relevant questions regarding this lawsuit; however, 14 BY MR. KUVIN: 15 at the present time, my attorneys have counseled me 15 Q. Okay. Do you recognize the person that's 16 T cannot provide answers to any questions relevant 16 shown in Exhibit 16? 17 to this lawsuit. [ must accept their advice or 17 A. Yes. 18 risk losing my 6th Amendment right to effective 18 Q. Who is that? 19 representation. Accordingly, I assert my federal 19 A. Prince Andrew, 20 constitutional rights as guaranteed by the Sth, 6th 20 Q. And how do you know Prince Andrew? 21 and 14th Amendment to the United States 21 A. I'm going to have to respond to that question 22 Constitution. 22 the same way I've responded to most of your questions 23 BY MR. KUVIN: 23 here today, Mr. Kuvin, which is, 1 intend to respond to 24 Q, I'm going to show the camera what we'll mark 24 all relevant questions regarding this lawsuit; however, as Exhibit 15. 25 at the present time, my attorneys have counseled me I Page 201 Page 203 L (Plaintiff's Exhibit No. 15 was marked for 1 cannot provide answers to any questions relevant to this 2 identification.) 2 lawsuit. I must accept their advice or risk losing my 3 BY MR. KUVIN: 3 6th Amendment right to effective representation, 4 Q. Sir, does Exhibit 15 show Haley Robson, an 4 Accordingly, I assert my federal constitutional rights 5 underaged girl that you were utilizing back in 2005 and 5 as guaranteed by the Sth, 6th and 14th Amendment to the 6 2006 to procure other underaged girls for sex and sexual 6 United States Constitution. 7 contact at your home? 7 Q. I'm going to show you a document that we'll a MR. PIKE: Same objections to Exhibit 15 as 8 mark as Exhibit 17. 9 were made to Exhibit 14. 9 MR. PIKE: Thank you. 10 THE WITNESS: I'm going to answer that the 10 (Plaintiff's Exhibit No. 17 was marked for il same way I've answered most of your questions here 11 identification.) 12 today, Mr. Kuvin, which is, 1 intend to respond to 12 BY MR. KUVIN: 13 all relevant questions regarding this lawsuit; 13 Q. I'm going to give you a minute to take a look 14 however, at the present time, my attorneys have 14 at that document and just tell me when you're ready to 15: counseled me that | cannot provide answers to any 15 answer any questions about it. 16 questions that may be relevant to the lawsuit, I 16 A. Okay. 17 must accept their advice or risk losing my 6th 17 Q. Okay. First ofall, have you seen this letter 18 Amendment right to effective representation. 18 before? 13 Accordingly, I am going to assert my federal 19 MR. GOLDBERGER: Attorney-client privilege, 20 constitutional rights as guaranteed by the Sth, 6th 20 work product. ai and 14th Amendments to the United States 2. BY MR. KUVIN: 22 Constitution. 22 Q. Have you seen this letter before outside of 23 (Plaintiff's Exhibit No. 16 was marked for 23 the relationship with your attorneys? i 24 identification.) 24 MR. GOLDBERGER: You can answer that question. MR. KUVIN: Let me show the camera what we've} 25 THE WITNESS: No. 8 (Pages 200 to 203) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronicatly signed by Jeana Ricciutl (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) bfSd9df0-4fcb-496¢-a244-099977073134

Page 204 1 BY MR. KUVIN: 2 Q. Do you know Chief of Police Michael Reiter? 3 Do you know who he is? 4 A. Iknow who he is. 5 Q. Do you know State Attorney Barry Krischer? 6 A. [know who he is. 7 Q. Did you ever speak with Chief of Police 8 Michael Reiter in the past? 9 A. Idon't remember. 10 Q. Did you ever talk to anyone, either at the aL State Attorney's office, yourself, or Michael Reiter 12 about the prosecution of your claim without the presence 13 of your attorneys? 14 A. No, a5 Q. Did you ever taik to any of the police that 16 worked for the Town of Palm Beach without the presence 17 of your attorneys? 18 A. Explain -19 MR. PIKE: Wait one second. 20 THE WITNESS: I'm sorry. 21 MR. PIKE: Can you state the question again? 22 MR. KUVIN: Sure. 23 BY MR. KUVIN: 24 Q. Did you ever speak to any of the police 25 officers that worked for the Town of Palm Beach without COIAYeeWNHH Page 206 BY MR. KUVIN: Q. How long were you there? A. 13 months, approximately. Q. Allright. And of those 13 months, how many months were you there where you had to stay there 24 hours a day? I don't recall specifically. More than a month? Yes. More than two months? Yes. More than three months? Yes, More than four? I think so, J don't remember. Do you recall when you were provided work release, when you were able to leave during the daylight [ hours? E A. Not with specificity. Q. While you were there at the jail in Palm Beach -- I'm going to show you what we'll mark as Exhibit 18. (Plaintiffs Exhibit No. 18 was marked for identification.) DPOPOPOP OE Page 205 = the presence of your attorneys? 2 MR. GOLDBERGER: Is the question, have you 3 ever spoken to a Town of Palm Beach police officer? 4 Is that the ~ can we rephrase it like that? 5 MR. KUVIN: Sure. 6 MR. GOLDBERGER: Okay. 7 THE WITNESS: fve been stopped by the police 8 for traffic violations, if that's what you mean. 2 BY MR. KUVIN: 10 Q. Any other times that you had conversations ai with any of the Town of Palm Beach -12 A. No. 13 Q. -- police officers? 14 A. Not that I reeall specifically. ais Q. Okay, Now, you were housed at the jail after 16 your plea of guilty that we had spoke about at the 1? beginning of your deposition; is that correct? 18 MR. PIKE: Form. 19 THE WITNESS: Say it again. 20 BY MR. KUVIN: 21 Q. Yes, You were housed at the local jail here 22 in Palm Beach County after your plea of guilty that we 23 spoke about at the beginning of your deposition? MR. PIKE: Form, THE WITNESS: Yes. (561) 832-7500 Electronically signed by Jeana Ricciutt (604-280-428-9381) Electronically signed by Jeana Ricciutl (601-280-428-9381) PROSE COURT REPORTING AGENCY, Page 207 BY MR. KUVIN; Q. Did you purchase items from the jail? MR. GOLDBERGER: Hang on a second, MR. PIKE; Hold on one second. THE WITNESS: It looks that way, yes, sir. BY MR. KUVIN: Q. Okay. MR. PIKE: And the document speaks for itself, the composite document speaks for itself. BY MR. KUVIN: Q. I'd like you to take a look at Exhibit 18. It shows purchases -- well, does it show purchases by you?| MR. PIKE: Asked and answered. THE WITNESS: Yes. BY MR. KUVIN: Q. Okay. And it appears those purchases took place from 7/8/08 through 9/30/08 is the Jast one that 1 have; is that correct? MR. PIKE: The document speaks for itself. BY MR, KUVIN: Q. You can answer, A, The document speaks for itself. Q. Is that correct, the last date is 9/30/08? A. The last date here is 9/30, yes. 9 tages 204 to 207) INC. (561) 832-7506 biBd9df0-4ich-496c-a244-09997 7073134

Page 208 the witness. MR. KUVIN: Sure, absolutely. THE WITNESS: Okay. BY MR. KUVIN: ‘Q. And just so we're clear, this composite exhibit that we've marked as Exhibit 18 contains purchases from 7/8/08, 7/15, 7/22, 7/29, 8/5, 8/12, 8/21, 8/26, 9/2, 9/9, 9/23 and 9/30, just so the record is clear; there is no question. A. Okay. Q. Okay? A. Ub-huh. Q, Allright. These items that you purchased, did you utilize all of these items yourself? MR. PIKE: Form, relevance. THE WITNESS: I don't understand the question. BY MR. KUVIN: Q. Well, you purchased a number of items that are shown in this receipt. A. Yes. Q. The question is; Did you use them yourself? MR. PIKE; Same objection. THE WITNESS: I don't know if T used all of them, so... Page 210 MR. PIKE: Asked and answered, THE WITNESS: So should [ answer? MR. PIKE: You can answer again, THE WITNESS: Ask the question again. BY MR. KUVIN: Q. Socan we assume that all of the items that are shown in these receipts were either used by you or thrown away? A. [don't even know if I received some of those items, so ] would assume I used most of them, Q. Okay. A. Okay? Q. Sure. Take a look, J just want to make sure, did you receive all these items? A. I don't know. MR. PIKE: Asked and answered. BY MR. KUVIN: Q. How did you purchase them? A. I filled out a form. Q. And how were they provided to you? MR. PIKE: Form. THE WITNESS: Sometimes they would come in bag. BY MR. KUVIN: Q. Okay. And did you determine whether or not Page 209 BY MR. KUVIN: Q. Well, what did you do with the items that you purchased? MR, PIKE: Form, overbroad. _ BY MR. KUVIN: Q. You can answer. A, lused some, I threw away some. Q. Did you give any away? A. Not that { remember. MR. PIKE: Same objection. BY MR. KUVIN: Q. Did you provide any items that you purchased to other inmates while you were there in jail? MR. PIKE: Form. THE WITNESS: Not to the best of my recollection. BY MR. KUVIN: Q. Okay. With respect to all of the items that are fisted in these receipts, is it a safe assumption. that you either used them yourself or threw them away? MR. PIKE: Asked and answered. If you don't know -- if you know. THE WITNESS: I don't know, BY MR. KUVIN: Q. I'msorry? I didn't hear you. Page 211 the form you filled out, the information or the product that you put on that form actually was provided? A. No, never. Q. If we look at the items that are contained within these receipts, I'd like you to go, if you would, to the second invoice here dated 7/15/08. The third item down is a Lubriderm lotion, . Yes. . Do you see that? . Yes. . Did you purchase that? . Ttappears so, , Did you receive it? . don't remember. . Did you use the Lubriderm lotion that you received or that you may have received in jail? MR. PIKE: Form. BY MR. KUVIN: Q. Let me strike that and re-ask it. A. Okay. Q. Did you use the Lubriderm lotion which you had purchased from the jai) white you were there? A. I might have, Q. What for? A. To moisturize my hands and face. 10 (Pages 208 to 211 ) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (S61) 832-7506 Electronically signed by Jeana Ricciuti (601-280-628-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) bfBdSd0-4fcb-496¢-a244-099977073134

Page 212 Page 2145 1 Q. Okay. Did you use Lubriderm lotion while you 1 Q. How do you know you definitely did not use it? E 2 ° were in jail to masturbate at all? 2 A. Because it was not -- anything that said hand =f} 3 A. No. 3 lotion I did not use, I threw in the garbage. 4 MR. PIKE: Form objection, harassing. 4 Q. Why is that? 5 THE WITNESS: Absolutely not. 5 A. Because it wasn't something that I had 6 BY MR. KUVIN: 6 ordered. 7 Q. It appears, if you would tum to 7/29/08, T MR. PIKE: Can | -- can I just have an 8 which is approximately two weeks later, and the second} 8 agreement that the objections to this line of 9 thing down is another bottle of Lubriderm lotion. Do 3 questioning is irrelevant, so 1 don’t have to ~ 10 you see that? 10 MR. KUVIN: Sure. li A. Yes. a1 MR. PIKE: -- interrupt. 12 Q, What did you use that for? 12 MR. KUYVIN: Sure. 13 MR. PIKE: Asked and answered. 13 MR. PIKE: Agreed? 14 MR. KUVIN: It's a second bottle. 14 MR. KUVIN: Agreed. 15 MR, PIKE: It's the same question, Spencer. 15 BY MR. KUVIN: E 16 Can we get to something relevant? 16 Q. Let's turn again to 9/30/08, the last invoice 3 17 THE WITNESS: No problem. 17 in there. ; 18 MR. PIKE: He can answer, 18 A, Yes. F 19 THE WITNESS: My hands and my face. 19 Q. Do you see there is an entry for two more : 20 BY MR. KUVIN: 20 bottles of hand totion. Do you see that? 21 Q. Okay. 21 A. Correct. 22 A. I believe the first bottle went missing. 22 Q. What did you do with those? 23 Q. Ifwe turn to approximately one month later on | 23 A. To the best of my knowledge, I threw them 24 8/21/08, do you have that one? 24 right away. 25 A. Yes. 25 Q. You didn't use them for anything? Page 213 Page 2155 1 Q. Allright. On that occasion, you bought two 1 A, No. 2 bottles of hand lotion again. 2 Q. Is it your testimony here today that you did 3 A. Yes. 3 not use any of the bottles of hand lotion or Lubriderm 4 Q. What did you use those for? 4 fotion that we had previously just gone through to 5 A. Nothing. § masturbate while you were in jail? 6 Q. What did you do with them? 6 A. That's correct. of A. They were bought by accident. 7 Q. Did Ghislaine Maxwell visit you in jail? 8 Q. How did you buy them by accident? 8 A, No. 9 A. Because you fill out a check form and 9 Q. Did Nadia Marcinkova visit you while you were 10 sometimes the forms don't make any sense, they just | 10 in jail? at deliver in other things. 11 A. | intend to respond to all relevant questions 12 Q. Sir, did you get those two bottles? 12 regarding this lawsuit; however, at the present time, my 13 A. Yes. Yes. 13 attorneys have counseled me I cannot provide answers to 14 Q. And you never used them? 14 any questions relevant to this lawsuit. I must accept 15 A. No. i threw them away. 15 this advice or risk losing my 6th Amendment right to 16 Q. Okay. If we tarn to 9/9/08, do you see that 16 effective representation. Accordingly, L assert my 17 entry? 1? federal constitutional rights as guaranteed by the 5th, 18 A. Yes. 18 6th and 14th Amendment to the United States 19 Q. Allright. And another invoice here, on that | 19 Constitution. 20 date a bottle of hand lotion, do you see that? 20 Q. Did you have sex with Nadia Marcinkova while 21 A. Yes, Ido. 21 you were housed at the Palm Beach jail facility? Q. Did you get it? 22 MR. PIKE: Form. A. I don't know. THE WITNESS: | intend to respond to all Q. Do you know if you used it? relevant questions regarding this lawsuit; however, A. Definitely not. at the present t time, my a attomeys have counseled me (561) 832-7500 Electronically signed by Jeana Ricciutl (601-280-428-9381) Electronically signed by Jeana Ricclutl (601-280-426-9381) PROSE COURT REPORTING AGENCY, 11 (Pages 212 to 215) INC. (561) 832-7506 bf8d9di0-4fcb-496c-a244-099977073134

— Page 216 Page 2185 1 I cannot provide answers to any questions relevant 1 Sth, 6th and 14th Amendment to the United States 2 to this lawsuit. As I've answered most of your 2 Constitution. Excuse me, 3 question today, Mr. Kuvin, I must accept this 3 MR. KUVIN;: This is 19. 4 advice or risk losing my 6th Amendment right to 4 (Plaintiff's Exhibit No. 19 was marked for 5 effective representation. Accordingly, I assert my 5 identification.) 6 federal constitutional rights as guaranteed by the 6 BY MR. KUVIN: 7 5th, 6th and 14th Amendments to the United States 7 Q. Lhave an FAA registry for a Boeing 727, 8 Constitution. 8 manufacture year 1969, with -- I'm just looking for the 9 BY MR. KOVIN: 9 tail number here. I'm sorry, I'm just trying to find 10 Q. Did you pay girls so that they would not 10 the tail number. 12 testify against you in the civil proceedings that have 11 A. Nota problem. 12 been filed in both Federal and State Court? 12 Q. Let's do this, it's a Mode S Code 53106661. 13 MR. PIKE: Form. 13 I'l show this to your counsel first. 14 THE WITNESS: Okay. Like most of your other! 14 Here it is, I'm sorry, Tail No. N908JE. 15 questions here today, Mr. Kuvin, I'm going to 15 There's no question pending just yet. 16 respond by saying I intend to respond to all 16 MR. PIKE: Thank you. 1? relevant questions regarding this lawsuit; however, | 17 Okay. 18 at the present time, my attorneys have counseled me | 18 BY MR. KUVIN: 19 I cannot provide answers to any questions relevant 19 Q. Let me show you what we marked as Exhibit 19. 20 to this lawsuit. I must accept this advice or risk 20 Til give you a minute to take a look at that. 21 losing my 6th Amendment right to effective 21 A. Okay. 22 representation. Accordingly, I must assert my 22 Q. What is JA - EGE, Inc.? 23 federal constitutional rights as guaranteed by the 23 A, intend to respond to alt relevant questions 24 4th, 6th and 14th Amendments to the United States | 24 regarding this lawsuit; however, at the present time, my 25 Constitution. 25 attorneys have counseled me I cannot provide answers to Page 217 Page 219} 1 BY MR. KUVIN: 1 any questions relevant to this lawsuit, { must accept 2 Q. Did you have sex with Nadia Marcinkova when 2 this advice or risk losing my 6th Amendment right to 3 she was under the age of 147 3 effective representation. Accordingly, as I've done 4 MR. PIKE: Form. 4 with most of your questions, I must assert my federal 5 THE WITNESS: | intend to respond to all 5 constitutional rights as guaranteed by the Sth, 6th and 6 relevant questions regarding this lawsuit, however, 6 14th Amendment to the United States Constitution. 7 at the present time, my attorneys have counseled me he Q. Mr. Epstein, are you aware that after 8 IL cannot provide answers to any questions relevant 8 September 11, 2001 that the Federal Government started. 9 to this lawsuit. I must accept this advice or risk 9 tracking all flights of all public and private aircraft? i 10 losing my 6th Amendment right to effective 10 MR. PIKE: Form, relevance. il representation. Accordingly, J must assert my i BY MR. KUVIN: 12 federal constitutional rights as guaranteed by the 12 Q. Are you aware of that? 13 Sth, 6th and 14th Amendment to the Constitution. 13 A. No. 14 BY MR. KUVIN: 14 Q. Okay. Are you aware that the FAA keeps track 15 Q. Did you tell people that Nadia Marcinkova was | 15 of all flights that are made both within the continental 16 your sex slave? 16 US and from the continental US abroad? 17 MR, PIKE: Same objection. 7 MR. PIKE: Same objection. 18 THE WITNESS: | intend to respond to all 18 THE WITNESS: No. 19 relevant questions regarding this lawsuit; however, | 19 BY MR. KUVIN: 20 at the present time, my attorneys have counseled me | 20 Q. Do you know whether or not ~ let me ask it 21 i cannot provide answers to any questions relevant 21 this way: Have you ever seen the flight tracking 22 to this lawsuit. J must accept this advice or risk 22 information for any planes that you may own? 23 losing my 6th Amendment right to effective 23 A, [don't believe so. representation. Accordingly, { must assert my 24 Q. Is JEGE, Inc. a company that is owned by you? A. Tt bave to: answer that question the way I've (561) 832-7500 federal constitutional rights & as ss guaranteed by i Electronically signed by Jeana Ricoluti (601-280-428-9381) Electronically signed by Jeana Riccluti (601-280-428-9381) PROSE COURT REPORTING AGENCY, 12 tpages 216 to 219) INC. (561) 832-7506 bfBdodf0-4fcb-496c-a244-099977073134

Page 220 Page 222} 1 answered most of your other questions here today, which 1 federal constitutional rights as guaranteed by the 2 is, 1 intend to respond to all relevant questions 2 Sth, 6th and 14th Amendment to the United States 3 regarding this lawsuit; however, at the present time, my 3 Constitution, 4 attorneys have counseled me I cannot provide answers to 4 BY MR. KUVIN: 5 any questions relevant to this lawsuit. I must accept 5 Q. Isn't it true that you went to Thailand in 6 this advice or risk losing my 6th Amendment right to 6 2001 so that you could engage in sexual relations with ce effective representation. Accordingly, I assert my 7 girls under the age of 16 with Prince Andrew without any 8 federal constitutional rights as guaranteed by the 5th, 8 fear of any legal recourse? 9 6th and 14th Amendment to the United States 9 MR. PIKE: Same objection. In addition, 10 Constitution. 10 improper hypothetical, lack of predicate, al Q. The plane that is identified in the FAA 11 foundation, argumentative, harassing. 12 registry in the document marked Exhibit 19, just so 12 THE WITNESS: | intend to respond to all 43 we're clear, because I don't think I asked it exactly, 13 relevant questions regarding this lawsuit; however, 14 but is this your plane? 14 at the present time, my attorneys have counseled me 45 A. I'm going to answer that question the same way is T cannot provide answers to any questions relevant 16 I've answered most of your questions today, Mr. Kuvin, 16 to this lawsuit, I must accept this advice or risk 17 which is, I intend to respond to ail relevant questions 17 losing my 6th Amendment right to effective 18 regarding this tawsuit, however, at the present time, my 18 representation, Accordingly, F must assert my ig attorneys have counseled me I cannot provide answers to | 19 federal constitutional rights as guaranteed by the 20 any questions relevant to this lawsuit. I must accept 20 5th, 6th and 14th Amendment to the United States 2t this advice or risk losing my 6th Amendment right to 21 Constitution, 22 effective representation. Accordingly, I assert my 22 BY MR. KUVIN: 23 federal constitutional rights as guaranteed by the Sth, 23 Q. Have you seen the photographs of you and 24 6th and 14th Amendment to the United States Prince Andrew while you were in Thailand with half naked fi 25 Constitution. women, some of which were under the age of 16? ; Page 221 Page 223 i 1 Q. Isn't is true, sir, that you flew to Thailand 1 MR. PIKE: Same objections. 2 in 20017 2 THE WITNESS: | intend -3 MR. PIKE: Form. 3 MR. PIKE: Relevance as well, excuse me. I'm fi 4 THE WITNESS: I intend to respond to al) 4 sorry. . 5 relevant questions regarding this lawsuit; however, 5 THE WITNESS: | intend to respond to all i 6 at the present time, my attorneys have counseled me 6 relevant questions regarding this lawsuit; however, |} 7 T cannot provide answers to any questions relevant a, at the present time, my attorneys have counseled me lf 8 to this lawsuit. I must accept this advice or risk 8 { cannot provide answers to any questions relevant 9 losing my 6th Amendment right to effective 9 to this lawsuit. I must accept this advice or risk 10 representation. Accordingly, I assert my federal 10 losing my 6th Amendment right to effective ; ii constitutional rights as guaranteed by the 5th, 6th at representation, Accordingly, ! assert my federal 12 and 14th Amendment to the United States 12 constitutional rights as guaranteed by the Sth, 6th i 13 Constitution. 13 and {4th Amendments to the United States 14 BY MR. KUVIN: 14 Constitution. 2 15 Q, 1s it true that you went to Thailand in 2001 15 BY MR. KUVIN: E 16 with Prince Andrew? 16 Q. Did you bring any young women on the plane & 17 MR. PIKE: Form. 17 with you when you went to Thailand in 2001? 18 THE WITNESS: | intend to respond to alt 18 MR. PIKE: Same objection, 19 relevant questions regarding this lawsuit, however, 19 THE WITNESS: | intend to respond to all 20 at the present time, my attorneys have counseled me ; 20 relevant questions regarding this lawsuit; however, 21 I cannot provide answers to any questions relevant 21 at the present time, my attorneys have counseled me 22 to this lawsuit, and as I've done for most of all 22 I cannot provide answers to any questions relevant 23 your questions today, Mr, Kuvin, [ must accept this | 23 to this lawsuit. I must accept this advice or risk 24 advice or risk losing my 6th Amendment right to 24 losing my 6th Amendment right to effective effective representation. Accordingly, I assert my 25 representation. Accordingly, I assert my federal 13 (Pages 220 to 223) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricctuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) bfBd9df0-4fcb-496¢-a244-099877073134

Page 224 Page 226 1 constitutional rights as guaranteed by the Sth, 6th 1 Q. Yeah. Capital M, capital C, number 2; sound 2 and 14th Amendments to the United States 2 familiar at all? [ 3 Constitution. 3 A. No. L 4 BY MR. KUVIN: 4 Q. Okay. Are you part owner in a teen modeling E 5 Q. Have you bragged to people before that you 8 agency? } 6 bought ~ brought Nadia Marcinkova to the United States 6 A. No. : 7 to be your Yugoslavian sex slave? 7 Q. Do you own any interest in any modeling E 8 A. Lintend to respond to all relevant questions 8 agencies currently? L 9 regarding this lawsuit; however, at the present time, my 9 A. Lintend to respond to all relevant questions E 10 attorneys have counseled me J cannot provide answers to 10 regarding this lawsuit; however, at the present time, my E lL any questions relevant to this lawsuit. I must accept 1. attorneys have counseled me J cannot provide answers to & 12 their advice or risk losing my 6th Amendment right to 22 any questions retevant to this lawsuit, | must accept 13: effective representation. Accordingly, I must assert my 13 this advice or risk losing my 6th Amendment right to 14 federal constitutional rights as guaranteed by the Sth, 14 effective representation, Accordingly, | assert my 15 6th and 14th Amendments to the United States 15 federai constitutional rights as guaranteed by the 5th, IS 16 Constitution. 16 6th and 14th Amendments to the United States q 1? Q. Have you had -- iy Constitution. E 18 MR. GOLDBERGER: You raised the same objection} 18 Q. Do you know what a sexual device caileda Twin jf 19 to that question, right? 19 Torpedo is? ; 20 MR. PIKE: Yeah, I did. 20 MR. PIKE: Same objections, irrelevant as 21 BY MR. KUVIN: 24 worded, 22 Q. Have you had sex with numerous girls under the 22 THE WITNESS: Would you like to ask me a bunch 23 age of 18 in the presence of Nadia Marcinkova? 23 of questions or are we going to -- do you want to E 24 MR. PIKE: Same objections, 24 individual answers to these? Do you want a i 25 THE WITNESS: I'm going to answer that the 25 compound question? E Page 225 Page 227 a same way I've answered most of your questions here i BY MR. KUVIN: 2 today, Mr. Kuvin, which is, I intend to respond to 2 Q. Ican do it that way, it doesn't matter to me. lj 3 all relevant questions regarding this lawsuit; 3 THE WITNESS: It's up to you. i 4 however, at the present time, my attorneys have 4 MR. KUVIN: It's up to you guys. E 5 counseled me I cannot provide answers to any 5 MR. PIKE: As I've said, Mr. Kuvin, if you E 6 questions relevant to the lawsuit. I must accept 6 want to limit the time that we spend here today and 7 their advice or risk losing my 6th Amendment right 7 ask a compound question if you're going to list 8 to effective representation. Accordingly, | assert 8 various items or list individuals by name and ask Fi 9 my federal constitutional rights as guaranteed by 9. questions, I won't have a compound objection to [ 10 the Sth, 6th and 14th Amendments to the United 10 that type of inquiry if it’s in light of attempting E 11 States Constitution. 11 to save time. 12 BY MR. KUVIN: 12 MR. KUYIN: Sure, 13 Q. What is MC2? 13 BY MR. KUVIN: 14 MR. PIKE: Same objection. 14 Q. All righty. a a5 JHE WITNESS: I don't understand the question, | 15 MR. PIKE: But that's limited to the compound {i 16 BY MR. KUVIN: 16 objection, 2 17 Q. MC and then a number 2, what is that? 17 MR. KUVIN: Oh, no, that's fine. H 18 MR. PIKE; Lack of predicate, foundation. 18 BY MR. KUVIN: ; 19 THE WITNESS: What is that? 19 Q. Allright. Did you purchase something called E 20 MR. PIKE: Irrelevant. 20 a Twin Torpedo, a soap made in the shape of a penis, and}? 2h BY MR. KUVIN: 21 a soap in the shape of a vagina? E 22 Q. Do you know what it is? 22 A. I'm going to answer that question like I've E 23 A. No. 23 answered most of your questions here today, which is,1_ 24 Q. You've never heard of that before? 24 intend to respond to all relevant questions regarding E 25 A. MC2? 25 i: it, however, at the present time, my attorneys (561) 832-7500 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) 14 (Pages 224 to 227) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 bfBdOdfO-4fch-496¢-0244-099977073134

Page 228 have counseled me that 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 Sth, 6th and 14th Amendment to the United States Constitution. MR. PIKE: Additionally, just for the Court's record, you're questioning the witness on Exhibit No. what? MR. KUYVIN: It's not an exhibit, It's the Town of Palm Beach Incident Report with respect to Jeffrey Epstein, of which | gave you a copy before. And that was referencing, just so the record is clear, page 46. MR, PIKE: Then I would add additional privileges and objections in addition to what Mp. Epstein has already raised underneath Florida Rule of Criminal Procedure 3.220 and work product. Not necessarily the document in front of you, but the questions and the answer you're aftempting to elicit. BY MR, KUVIN: Q. Whose mobile wireless number is (561)317-21437 A. intend to respond to ail relevant questions Page 230 A. Tintend fo 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 the lawsuit. I must accept b this advice or risk losing my 6th Amendment right to effective representation. Accordingly, | must assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendments to the Constitution. Q. Do you have an egg-shaped penis? A. 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, must assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the United States Constitution. Q. Do you have any identifying marks on your penis? A. Lintend to respond to ali relevant questions regarding this lawsuit; however, at the present time, my attomeys have counseled me I cannot provide answers to {; any questions relevant to the lawsuit. I must accept their advice or risk losing my 6th Amendment right to Page 229 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 hereby assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. Q. I'm going to read you, for speed's sake, three separate phone numbers, and it's the same question for each, Do you recognize the following phone numbers? They all have Area Code 561. The first one is 832-4117, the second is 317-2143, and the third is 383-7542. A. [intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me [ cannot provide answers to any questions relevant to this lawsuit. | 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 Sth, 6th and 14th Amendments to the United States Constitution. Q. Did Sarah Kellen have the phone number 655-0995 or 881-8116 or 655 -- I'm sorry, same number again. So tw bers: Either 655-0995 or 881-8116? Page 231 effective representation. Accordingly, I hereby assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendments to the United States Constitution. MR. PIKE: In addition, same objection and privilege whict regard to the Florida Rule of E Procedure 3.220 and work product. Not necessarily the document you're talking or speaking from, but the testimony. MR. KUVIN: I was just reading this. I wasn’t asking questions from this at the moment. BY MR. KUVIN: Q. Does your penis have any deformities? MR. PIKE: Form. THE WITNESS: | intend to respond to all relevant questions regarding this lawsuit; however, £ at the present time, my attorneys have counseled me I cannot provide answers the any questions relevant to the lawsuit, T 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 Sth, 6th and 14th Amendment to the Constitution, as I've done with most of your questions here today. 15 (Pages 228 to 231 (561) 832-7500 Electronically signed by Jeana Ricciutl (601-280-428-0381) Electronically signed by Jeana Ricciuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 bf8d9df0-4fch-496c-a244-099977073194

Page 232 Page 234} BY MR. KUVIN: 1 Marcinkova, Sarah Kellen or Ghislaine Maxwell from the Q. Did you ever utilize Dollar-Rent-a-Car to rent 2 years 2005 to 2006? cars while you were here in Palm Beach at any time? 3 MR. PIKE: Relevance. A. 1 intend to respond to all relevant questions, 4 THE WITNESS: I intend to respond to all Mr. Kuvin, regarding this lawsuit; however, at the 5 televant questions regarding this lawsuit. As I've present time, my attorneys have counseled me I cannot 6 answered most of your questions the same way today, provide answers to any questions that may prove relevant if Mr. Kuvin, at the present time, my attorneys have to this lawsuit, [ must accept this advice or risk 8 counseled me I cannot provide answers to any of josing my 6th Amendment right to effective 9 your questions that may be relevant to this representation. Accordingly, I must assert my federal 10 lawsuit. | must accept this advice or risk losing constitutional rights as guaranteed by the Sth, 6th and iL my 6th Amendment right to effective representation. 14th Amendment to the United States Constitution, 12 Therefore, accordingly, I assert my federal Q, What was your personal cell phone carrier back 13 constitutional rights as guaranteed by the Sth, 6th in 20042 14 and 14th Amendment to the United States A, lintend to respond to all relevant questions is Constitution. regarding this lawsuit. 16 May we take a break, please? Q. Let me make this quicker. I'm sorry for i? MR. KUVIN: Sure, interrupting you, I apologize. Let’s say, what was your 18 MR. PIKE: Yes. cel! phone carrier back from 2004 through 2006. 19 MR. GOLDBERGER: Yes. MR, PIKE: And I'm not objecting to compound; 20 ,THE VIDEOGRAPHER: Going off the record at however, there are various allegations in your 21 3: 21. complaint regarding a time frame. So therefore, 22 {A brief recess was taken.) 3 with regard to the allegations in your complaint, 23 THE VIDEOGRAPHER: We're back on the record at relative to your question, I'm not objecting to the 24 3:30, compound, I'm saying it's overbroad. 25 Page 233 Page 2355 MR. KUVIN: 2004 to 20067 1 BY MR. KUVIN: MR. PIKE; QOverbroad and irrelevant based uport 2 Q. Here, let me move this out of the way. the allegations that you've alleged. 3 A. You can take your Joy Jelly home now. MR. KUVIN: Allright. Well, let me clarify 4 Q. It's actually an exhibit to your deposition. the question then. 5 A. Sorty. BY MR. KUVIN: 6 Q. Have you read the police department's, the Q. What was your cell phone carrier from 2004 to 7 Palm Beach Police Department's, probable cause 20052 8 affidavit? Have you ever read it? MR. PIKE: Same objections. 9 MR. PIKE: Attorey-client, work privilege. BY MR. KUVIN: 10 BY MR. KUVIN: Q. Well, let me try and fix it again. What was aL Q. Have you ever read the police department, Palm your cell phone carrier from 2005 to 2006? 12 Beach Police Department's incident report regarding you? f MR, PIKE: Relevance. 13 MR, PIKE: Same objection, E THE WITNESS: I intend to respond to all 14 MR. GOLDBERGER: Same objection. iE relevant questions regarding this lawsuit; however, 15 MR. PEE: And instruction, I'm sorry. i at the present time, my attorneys have counseled me | 16 BY MR. KUVIN: le I cannot provide answers to any questions relevant | 17 Q. Are you circumcised? ; to this lawsuit. I must accept their advice or 18 MR. PIKE: Objection, relevance. le tisk losing my 6th Amendment right to effective 19 THE WITNESS: | intend to respond to all : representation; therefore, | must assert my federal 20 relevant questions regarding this lawsuit; however, E constitutional rights as guaranteed by the Sth, 6th 2h at the present time, my attorneys have counseled me and 14th Amendments to the United States 22 I cannot provide answers to any questions relevant Constitution. 23 to this lawsuit. I must accept this advice or risk BY MR. KUVIN: 24 losing my 6th Amendment right to effective i Q. What were the a phone carriers of Nadia 25 representation. Accordingly, 1 Lassert my federal ig STS TI EY s a en EE H 16 (Pages 232 to 235) (561) 832-7500 Electronically signed by Joana Ricciuti (601-280-428-9381) Electronically signed by Jeana Riccluti (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 bfBd9df0-4fcb-496c-a244-09997707 3134

Page 236 Page 238 f 1 constitutional rights as guaranteed by the Sth, 6th 1 correct? [ 2 and 14th Amendments to the United States 2 A. You asked that before. i 3 Constitution. 3 Yes, correct. E 4 BY MR. KUVIN: 4 Q. Okay, I'm sorry. 5 Q. Was a search warrant performed and executed at 5 Do you own a -- or did you own -- let me | 6 your home on Palm Beach Island? 6 clarify. 7 MR. GOLDBERGER: Attorney-client, work 7 A. Do you want to do compound again? iN 8 privilege. 8 Q. Yeah. Did you or do you currently own a 2008 H 9 T'll instruct you not to answer. 9 black Cadillac Escalade ESV, bearing Florida license tag fj 10 BY MR. KUVIN: 10 —-Q29.9GT? I 11 Q. Do you know Zara Bailey, spelled Z-A-R-A, 1k A. lintend to respond to all relevant questions iE 12 B-A-L-L-E-Y; Daniel Estes, spelled E-S-T-E-8; or Douglas}. 12 regarding this lawsuit; however, at the present time, my 13 Schoettle, S~C-H-O-E-T-T-L-E? 13 attommeys have counseled me | cannot provide answers to E 14 A. intend to respond to all relevant questions 14 any questions that may be relevant to the lawsuit. I fe 15 regarding this lawsuit; however, at the present time, my is must accept their advice or risk losing my 6th Amendment 16 attorneys have counseled me I cannot provide answers to 16 right to effective representation. Accordingly, 1 E 17 any questions relevant to this lawsuit. And as I've i? assert my federal constitutional rights as guaranteed by k: i8 answered most of your questions today, Mr. Kuvin, | must | 18 the Sth, 6th and 14th Amendment to the United States E 19 accept this advice and risk losing -- or risk losing my 19 Constitution. 20 6th Amendment right to effective representation. 20 Q. Have you hired attorneys for cither F 21 Accordingly, I assert my federal constitutional rights 24 Sarah Kellen, Ghislaine Maxwell, Nadia Marcinkova or any F 22 as guaranteed by the Sth, 6th and [4th Amendments to the | 22 other «= E 23 United States Constitution. 23 MR. GOLDBERGER: Attorney-client, work E 24 Q. Did you have a chef working for you at your 24 product. 25 Paim Beach home back in 2005? 25 Are you done? i'm sorry, E Page 237 Page 239 1 A. [intend to respond to all refevant questions 1 BY MR. KUVIN: E 2 regarding this lawsuit; however, at the present time, my 2 Q. -- or any other women in this case? fi 3 attorneys have counseled me I cannot provide answers to 3 MR. GOLDBERGER: Okay. Now attorney-client, E 4 any questions relevant to this lawsuit at this time. I 4 work product. f 5 must accept their advice or risk losing my 6th Amendment 3 I direct you not to answer. [: 6 right to effective representation. Accordingly, I must 6 BY MR. KUVIN: i 7 assert my federal constitutional rights as guaranteed by 7 Q. De you know the name of the girl that was with 8 the Sth, 6th and 14th Amendment to the United States 8 B.B. when she was brought to your home? 9 Constitution. 9 MR. PIKE: Form, lack of predicate, | 10 MR. PIKE: Additionally, predicate and 10 foundation. B 12 foundation. 11 THE WITNESS: Like I've done to many of your 12 BY MR. KUVIN: 12 other questions and responded to many of your other 13 Q. Did you own or do you currently own a 2004 13 questions today, Mr. Kuvin, that question -- | must F 14 black Chevy Suburban, bearing Florida tag X99-EGL? 14 answer that, | intend to answer all relevant e 15 A. [intend to respond to all relevant questions 15 questions regarding this lawsuit; however, at the : 16 regarding this lawsuit; however, at the present time, my 16 present time, my attorneys have counseled me I i 1? attorneys have counseled me [ cannot provide answers to 17 cannot provide answers to any questions that may be i 18 any questions that may be relevant to the lawsuit. I 18 relevant, I must accept this advice or risk losing 19 must accept their advice or risk losing my 6th Amendment} 19 my 6th Amendment right to effective representation; 20 right to effective representation; therefore, | assert 20 therefore, I assert my federal constitutional l: 21 my federal constitutional rights as guaranteed by the 21 rights as guaranteed by the Sth, 6th and 14th E 22 Sth, 6th and 14th Amendment to the United States 22 Amendment to the Constitution. 23 Constitution. 23 BY MR. KUVIN: E 24 Q. think I asked this before, and I apologize 24 Q. Did you, in fact, give B.B. $200 for a~ for 5 25 25 (561) if E did, but your date of birth is January 20, 1953, 832-7500 Electronically signed by Jeana Riccluti (601-280-428-9381) Electronically signed by Jeana Ricchuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC. her to get naked and give you a massage while you were — 17 (Pages 236 to 239) (561) 832-7506 bf8dadi0-4fcb-496¢-a244-099977073134

Page 240 naked and, in addition, touch her in her vagina without her permission in 20057 MR. PIKE: Predicate, foundation —THE WITNESS: 1 believe that's been asked and answered. MR. PIKE: Harassing. And J believe as worded, that question has been asked and answered in sub parts. I believe you've asked those questions initially at the beginning of this deposition, The same objections would, therefore, apply and be incorporated. MR. KUVIN: I disagree, but... THE WITNESS: Like most of your other questions here today, 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. J must accept this advice or risk fosing my 6th Amendment privilege. Accordingly, 1 assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendment to the US Constitution. BY MR, KUVIN: Q. Do you agree, sir, that your conduct, with respect to B.B., caused her severe emotional distress? Q. Have you told young ladies -- girls under the age of 18, when they came to your house and got naked to |; give you a massage, quote, the more you do, the more you & get paid? f MR. PIKE: Objection, form, predicate, foundation, improper hypothetical and assumes facts not in evidence, relevance. THE WITNESS: Like most of your questions, Mr. Kuvin, today, } 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. 1 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 Sth, 6th and 14th Amendment to the United States Constitution. BY MR. KUYIN: Q. Do you have any tattoos? A. [intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me | cannot provide answers to any questions relevant to this lawsuit, 1 must accept this advice or risk losing my 6th Amendment right to (561) Page 241 MR. PIKE: Same objection. In addition, it's argumentative, harassing and calls for a conclusion, THE WITNESS; I'm going to have fo answer that the same way I've answered most of your questions 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 the lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation, Accordingly, 1 must assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment. BY MR. KUVIN: Q. Do you have gray chest hair? A. [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 of those questions that may be relevant. | 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 Sth, 6th and 14th Amendments to the United States 832-7500 PROSE COURT REPORTING AGENCY, INC. effective representation, Accordingly, | must assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th Amendments to the United States Constitution. E Q. Do you have a steam room in your home on Palm Beach Island? MR. PIKE: Same objections. THE WITNESS: I'm going to answer that question 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 that I cannot provide answers to any questions relevant to the lawsuit. I must accept this advice or risk losing my 6th Amendment right to effective representation. Accordingly, ] must assert my constitutional rights as guaranteed by the Sth -- Sth, 6th and [4th Amendments to the United States Constitution, BY MR. KUVIN: Q. Did you provide payments to underaged girls by utilizing cash and wire transfers through Western Union in 2004 or 2005? MR. PIKE: Same objections as raised to the previous lest three questions incorporated here. 18 (Pages 240 to 243) (561) 832-7506 Electronically signed by Jeana Riccluti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) biBdBdf0-4tcb-4960-2244-089977073134

Page 244 1 THE WITNESS: | intend to respond to all 1 2 relevant questions regarding this lawsuit; however, 2 3 at the present time, my attorneys have counseled me 3 4 I cannot provide answers to any questions relevant 4 5 to the lawsuit. I must accept this advice or risk 5 6 losing my 6th Amendment right to effective 6 7 representation. Accordingly, I assert my federal 7 8 constitutional rights as guaranteed by the Sth, 6th 8 9 and 14th Amendment to the United States 9 10 Constitution. 10 11 BY MR. KUVIN: 1d 12 Q. Did you -- excuse me. Did you take any 12 13 videotapes of girls that were under the age of 18 in 13 14 your home on Palm Beach istand? 14 15 MR. PIKE: Same objections incorporated, 15 16 THE WITNESS: As I have with most of your 16 17 questions today, I'm going to have to answer that, 17 18 | intend to respond to ail relevant questions 18 19 regarding this lawsuit; however, at the present 19 20 time, my attorneys have counseled me I cannot 20 21 provide answers to any questions that may be 21 22 relevant to this lawsuit. I must accept this 22 23 advice or risk losing my 6th Amendment right to 23 effective representation. Accordingly, I assert my 24 federal constitutional rights as guaranteed by the 25 at the present time, my attorneys have counseled me that I cannot provide answers to any questions relevant to the 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 Sth, 6th and 14th Amendment to the United States Constitution. BY MR. KUVIN: Q. Hold ona second. 1 may be done. Do you know a Dr, Kaku, K-A-K-U? A. Lintend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me ¥ cannot provide answers to any questions that may be relevant. | must accept this advice or risk losing my 6th right to effective representation, Accordingly, ] assert my federal constitutional rights as guaranteed by the Sth, 6th and 14th Amendment to the United States Constitution, MR. PIKE: Can you hold on one second? MR. KUVIN: I'm almost done. MR. PIKE: No, no. We're not going anywhere. MR, KUVIN: Okay. MR, PIKE: Okay. Page 245 1 Sth, 6th and 14th Amendment to the United States 1 2 Constitution. 2 3 BY MR. KUVIN: 3 4 Q. Have you ever provided a dozen roses to a 4 5 young girl under the age of 18 who came to your house to} 5 6 give you a massage? 6 7 MR. PIKE: Form, vague, ambiguous, assumes 7 8 facts not in evidence. 8 9 THE WITNESS: | intend to respond to all 9 10 relevant questions regarding this lawsuit; however, 10 il at the present time, my attomeys have counseled me a. 12 that I cannot provide answers to any questions that 12 13 may be relevant. | must accept their advice or 13 14 tisk losing my 6th Amendment right to effective 14 45 representation. Accordingly, | must assert my 15 16 federal constitutional rights as guaranteed by the 16 17 Sth, 6th and 14th Amendment. iy ig BY MR. KUVIN: 18 19 Q. Did you ever instruct anyone to deliver a 19 20 bucket of roses after a high school drama performance to | 20 21 an underaged girl? 24 22 MR. PIKE: Same objection. In addition, lacks 22 23 predicate and foundation. It's overbroad as well. 23 THE WITNESS: I fully intend to respond to all relevant questions regarding this lawsuit; however, (S61) 832-7500 Electronically signed by Jeana Riccluti (601-280-428-9381) Electronically signed by Jeana Riccluti (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC. Page 2475 MR. KUVIN: Okay. All right, I appreciate your patience. That's all the questions that I have right now. [ know that Mr. Goldberger needs to deal with an issue right now with Ms, Ezell regarding any further questions, MR. GOLDBERGER: I think we clarified that. Ms. Ezell, are you there? MS. BZELL: I'm here. E MR. GOLDBERGER: Yeeh. You had a discussion f} with Bob Critton already concerning the question i you raised with me earlier, right? MS. EZELL: Yes, J did, and I don't have any questions. MR. PIKE: Ms. Ezell, this is Michael Pike. 1 don't know what your conversation was with Bob, but did you cross notice this deposition? MS. EZELL: No, I did not. MR. PIKE: So what is your purpose of being here? My position is that these are closed proceedings and your client, your client did not cross notice this deposition and/or your clients. So what is your purpose of sitting in on this deposition? MS. EZELL: Weil, [ received a notice of it, 19 (Pages 244 to 247) {561) 832~7506 bfBdsdf0-4fab-496c-a244-099977073134

Page 248 1 and { just thought I would listen to it while 1 was 1 CERTIFICATE OF OATH 2 doing some other work, And I don't know why it 2 THE STATE OF FLORIDA 3 would be a closed proceeding. 3 COUNTY OF PALM BEACH 4 MR. PIKE: Discovery proceedings are closed if 2 5 it's a pre-trial discovery, ma'am, it's not a court é 1, the undersigned authority, certify that . proceeding. 7 JEFFREY EPSTEIN personally appeared before me and was! 7 Nonetheless, do you have any questions for the 8 duly sworn on the 8th day of October, 2009. 8 witness? 9 MS. EZELL: No, I don't. 10 Dated this 8th day of October, 2009. 10 MR. PIKE: And Ms. Holmes, who are you here on 1h behalf of? Which clients? 12 MS. HOLMES: L.M. and E,W. 13 MR, PIKE: Are you also here on behalf of Jane 14 Doe in the case 80893? 1s MS. HOLMBS: I believe so, yes. Jeana Riociuti, RPR, FPR, C 16 MR, PIKE: Do you have any questions for the 16 Notary Public - State of Florida 17 witness? My Commission Expires: 2/17/2013 18 MS. HOLMES: No, Ido not. 17 My Commission No.: DD 854778, 19 MR. GOLDBERGER: Katherine, we're going to 20 end. Do you want me to disconnect you now? 2i MS. EZELL: Yes, thanks. 22 MR. GOLDBERGER: Okay. 23 THE VIDEOGRAPHER: Conclude the deposition and 24 go off the record at 3:00 ~ MR, PIKE: Wait one second. Page 249 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH 1 MR. KUVIN: Ob, wait. 2 MR. GOLDBERGER: He's just going to read. 3 MR. PIKE: You didn't give the witness a 4 chance to read or waive and he'll read, 5 6 7 8 I, Jeana Riociuti, Registered Professional Reporter and Notary Public in and for the State of Florida at large, do hereby certify that | wag 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 } farther 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, THE VIDEOGRAPHER: Conclude the deposition and go off the record at 3:48, This will be the end of tape No. 3. 9 (Witness excused.) (Deposition was concluded.) [ farther certify that | am not attorney or 12 counsel of any of the parties, nor am [a relative or employee of any attomey or counsel of party connected 13 with the action, nor am 1 financially interested in the action. The foregoing certification of this transcript 15 does nat apply to any reproduction of the same by any means unless under the direct control and/or direction 16 of the certifying reporter. Dated this 8th day of October, 2009 20 (Pages 248 to 251) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Riccluti (601-280-428-9381) Etectronically signed by Jeana Ricciuti (601-280-428-9381) bfSdSdfO-4fch-496c-a244-0999770731 34

Page 252 DATE: October 22, 2009 ‘TO: JBEFREY EPSTEIN fo Michael J. Pike BURMAN, CRITTON, LUTTIER & COLEMAN, PA, 303 Banyan Boulevard ‘Suite 400 ‘Wast Palm Beach, Florida 13401 INRE, BB. v, EPSTEIN Please take notice thet on Thursday, the Sth ‘of October, 2009, you xave your deposition in the above referred walter. At that time, you did not waive tgnature, [1s now necessary ther you sgn your deposition. ‘As previously ngreed to the transcript wi ‘bo fumished to you through your counsel. Please read tie fotiowcing invtrictions carey: ‘At the end of the transcrigt you wil find an ‘errata sheet, As you reéd your deposition, any changes co corrections that you wis to make should be noted on ‘tho errata shee, cing page and fine number of said change. DO NOT write on the transcript itself. Once ‘you have read the transcript and sioted any changes, be sure fo sign and date the errata sheet and reum these pages to me. Wyou do not reed and sign the deposition ‘within 2 reasonable time (ie, 30 days unless otherwise irectod) the original, which has already been forwarded to the oxdering atiocnes, may be filed with the Clerk oF the Court, Ifyou wish to waive your signature, sign ‘your namie the Blank at the bottom of tis Helier and totum 10 us ‘Very tnily yours, Joma Riccia, RPR, FPR, CLR Prose Cour Roparting Agency, INC. 2508, Australian Avene, Ste 1500 ‘Weal Palm Beach, Florida 33401 1 do hereby waive my signature SERFREY EPSTEIN CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH Thereby certify that 1 have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of 2009. JEFFREY EPSTEIN (561) 832-7500 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) ERRATA SHEET INRE: BB. v. EPSTEIN CR: JEANA RICCIUTT DEPOSITION OF: JEFFREY EPSTEIN ‘TAKEN; October 8, 2009 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE REASON PAGE # LINE# CHANGE Pleate forward the original signed errata sheet to this office so that copies may be distributed to all parties. ‘Under penalty of perjury, | declare that J have read my deposition and that itis rue and correct sabject 10 any changes in form or substance entered here. DATE: SIGNATURE OF DEPONEN’ er PROSE COURT REPORTING AGENCY, INC. (Pages 252 to 254) (561) 832-7506 bf8d9df0-4icb-496c-a244-099977073134

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 10

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. VOLUME I (Pages 1 - 189) CASE NO; 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, es EXAMINATION INDEX. JEFFREY EPSTEIN, 5 i Defendant, 6 ; nae JEFFREY EDWARD EPSTEIN i 08-80232, 08-80380,08-3038 |,08-80994, a DIRECT BY MR. HOROWITZ......- 5 E 08-80993, 08-8081 1 08-80893,09-80469, 8 i 09-8058 ,09-80656,09-80802,09-81092. 9 ; 10 11 F VIDEOTAPED DEPOSITION OF JEFFREY EDWARD EPSTEIN 12 VOLUME [ 13 (Pages 5 - 189) Fe : Monday, March 8, 2010 15 ae B 01 Clematis Steet 16 NO EXHIBITS MARKED F Suite 3000 a E ‘West Palm Beach, Florida 33401 ree A 10:05 am, - 6:17 pm. 18 i 19 le 20 I Reported By: 21. i Vicki E. Lima, Court Reporter 22 E Notary Public, State of Florida 03 H Universal Legal Reporting oa i Phone - (954) 712-2600 Job #92076-4, Page 4 } L B 2 APPEARANCES: PROCEEDINGS B 3 Ben 4 — On behalf of the Plaintiffs, Jane Doo 2 through 8: Videotaped deposition taken before Vicki L. Lima, Court Reporter, and Notary Public in and for the State of 1 2 ADAM HOROWITZ, ESQUIRE : 5 Florida at Large, in the above cause. 6 7 8 JESSICA ND. ARBOUR, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. ‘6 1£205 Biscayne Boulevard Suite 2218 o 7 Miarai, Plorida 33160 & — Onbehalf of the Plaintiffs, Jone Doe, LM. and E.W.: BRAD EDWARDS, ESQUIRE 2 FARMER, JAFPE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PLL. 10425 Nowth Andrews Avenue Suite 2 11 Fort Lauderdale, Florida 3330] 12 On behalf of the Plaintiff, Jans Doe 103: XATHBRINB W. BZELL, ESQUIRE 13 PODHURST ORSECK City Notional Bank Building 14-25 West Flagler Street Suite 800 15 Misti, Plorida 33130 16 — On behalf of the Defendant and Witness: MICHAEL 5. PIKE, ESQUIRE uy BURMAN, CRITTON, LUTTIER & COLEMAN 303 Banyan Boulevard 18 Suite 400 Wert Palm Beach, Florida 33401 THE VIDEOGRAPHER: We are now on the record. This is the videotaped deposition of Jeffrey 9 Epstein, taken in the matter of Jane Doe Number 2 10 vs. Jefitey Epstein, Case Number 08-CV-80119. aL We are here at 301 Clematis Street, Suite 3000, 12 West Palm Beach, Florida 33401, It is Monday, 13 March 8th, 2010, The time is 10:05. The court 14 reporter is Vicki Lima. The videographer is Alex 15 Ayala. 16 Will counsel please introduce themselves? é 17 MR. HOROWITZ: Sure. My name is Adam Horowitz 18 from Mermelstein & Horowitz, counsel for Plaintiffs 19 Jane Doe 2 through 8. And just for record 20 purpOses, the deposition is taken -- being taken in a1 those cases as well. JACK A, GOLDBERGER, ESQUIRE 20 ATTERBURY, GOLDBERGER & WEISS, P.A 22 Dab acon veobe Bom 22 MR. PIKE: Please introduce yourself. Suite 1400 23 MS. ARBOUR: Jessica Arbour, Mermelstein & ‘West Palm Beach, Florida 33401 x 24 Horowitz. 25 MR. EDWARDS: Brad Edwards. I represent Jan ALSO PRESENT: ale, 1 (Pages 1 to 4) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 5 Doe. It's also been cross-noticed in that case as well, but | think it's styled in the Jane Doe 2 case, MS. EZELL: Katherine Ezetl. I represent Jane Doe 103. MR. PIKE: Michael Pike on behalf of Jeffrey Epstein. THE VIDEOGRAPHER: Will the court reporter please swear in the witness? THE REPORTER: Raise your right hand, please. THEREUPON: JEFFREY EDWARD EPSTEIN having been first duly sworn or affirmed, was examined and testified as follows: THE WITNESS: Yes, ma'am. DIRECT EXAMINATION BY MR. HOROWITZ: Please tell us your full name? Jeffrey Edward Epstein. And is your date of birth January 20, 1953? Yes. Okay. And J guess that makes you 57 years old at the present time? A_ Correct, Page 7 A What's that? Yes. Q Okay. No back or neck pain at the present time? A No. Q Doyou have a girlfriend at the present time? MR. PIKE; Form. |: THE WITNESS: On advice of counsel, I'm goin; to assert my Fifth Amendment Right. BY MR. HOROWITZ: Q Do you have a driver's license in any state? A Yes, Q_ In what state? A The United States Virgin Islands, J Q Okay. How long have you had a driver's license F in the Virgin Islands? A [believe twelve years. Q Okay. Have you ever had a driver's license in the State of Florida? A Yes, sir. Q Okay. And during what years did you have a driver's license in the State of Florida? A I don't remember. Q Okay. What address appears on your driver's license in the Virgin Islands? MR. PIKE: Form. Page 6 Q And you are, sir, a registered sex offender in the State of Florida? A Correct. Q Okay. How long have you been a sex offender it the State of Florida? MR. PIKE: Form. THE WITNESS: I registered on -- in, I believe, '08, July of 08. BY MR. HOROWITZ: Okay. Are you married? No. Have you ever been married? No. Are you engaged? No. Have you ever been engaged? MR. PIKE: Form. THE WITNESS: On advice of counsel, I'm going to assert my Fifth Amendment Right as to that. BY MR. HOROWITZ: Q > Are you suffering from any physical illness or injury today that would prevent you from sitting for a full day of deposition? A No. Your hearing i: Page 8 F THE WITNESS: 1 don't remember. BY MR. HOROWITZ: Q Is it the address that you reside in? MR. PIKE: Form. THE WITNESS: On advice of counsel, [ am goin; to assert my Fifth Amendment Right. BY MR. HOROWITZ: Q Okay. Did you review any documents in preparation for today's deposition? A No. Q Okay. Did you meet with your attomeys concerning this deposition at any time before it started? A Atany time I've -- over the past couple of months, but not specifically with this deposition. Q Okay. I'm asking about -- concerning this deposition? A No, Q Okay. In June of 2008, you pled guilty to two felonies; is that correct? A Correct. b Q Okay. One of those felonies involved procuring a person under the age of 18 for prostitution, correct? UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 9 1 A That's correct. 1 Q Okay. Do you register your home address as 2 Q Okay. And you were represented by legal 2 part of your sex offender designation? 4 3 counsel at the time of your plea? 3 MR. PIKE: Form. i 4 A That's correct. 4 THE WITNESS: I believe so. i 5 Q Okay. In that particular charge the person 5 BYMR. HOROWITZ: i 6 under the age of 18 who you allegedly procured for 6 Q Okay. What address do you provide as your home 7 prostitution, was a female, correct? 7 address as part of your sex offender registration? 8 A On advice of counsel, | am going to have to 8 MR. PIKE: Form. 9 assert my Fifth Amendment, Sixth Amendment and 9 THE WITNESS: On advice of counsel, | will have iE 10 Fourteenth Amendment Right. 10 to assert my Fifth Amendment, Sixth Amendment and aL Q In June of 2008, you also pled guilty toa ai Fourteenth Amendment Right, 12 felony charge of solicitation of a prostitute, correct? 12 BY MR. HOROWITZ; 13 A No, solicitation of prostitution, correct. 13 Q Okay. Do you tell the State of Florida where i 14 Q Okay. And to make sure we're on the same pagey 14 you live as part of your sex offender registration? i 15 in June of 2008, you pled guilty to a felony of 15 A_ Do I tell the State of Florida? E 16 solicitation of prostitution, correct? 16 Q Any department within the State of Florida i 17 A Yes. 17 where you live as part of your sex offender 18 Q Okay. And you were represented by counsel at | 18 — registration? 19 the time of that guilty plea as well? 19 A [believe so. q 20 A Yes, sir. 20 Q What address do you tell them that you live in? fe 21 Q Okay. And you were sentenced in Palm Beach | 21 MR. PIKE: Form, same objection. 22 County for both of those felonies, correct? 22 THE WITNESS: And I am going to assert my Fifth iE 23 A That's correct. 23 Amendment, Sixth Amendment and Fourteenth Amendment 24 Q Okay. You actually served your time in Palm 24 Rights, Le 25 Beach County? 25 BY MR. HOROWITZ: L Page 10 Page 12 1 A. That's correct. 1 Q Do you tell any departments of the State of E 2 Q Okay, And at the time of your sentence, did 2 Florida what vessels or vehicles you own as part of your: 3 the Judge advise you as to what your sentence would be’ 3 sex offender registration? 4 A Tbelieve so. 4 A My sex offender registration will speak for 5 Q You were there when the Judge entered the 5 itself, but I believe so. I don't remember. 6 — sentence? 6 Q Okay. What vehicles or vessels do you inform a. MR. PIKE: Form. 7 the State of Florida that you own or have an interest in 8 THE WITNESS: Yes. 8 as part of your sex offender registry? 9 BY MR. HOROWITZ: 9 MR. PIKE: Form, same objection. 10 Q Okay. Your sentence included jail time; is 10 THE WITNESS: I don't recall. 11 that right? aL THE REPORTER: What did you say? 12 A. That's correct. 12 THE WITNESS: I don't recall. 13 Q Okay. And the sentence you received was twelve] 13. BY MR. HOROWITZ: 14 months, followed by six months; is that correct? 14 Q_ ifyou know, are there Jocations that you 15 A [believe so. 15 cannot live in because of your status as a sex 16 Q Uh-huh. And was it at -- as part of that 16 — offender? 17 sentence, that you were designated as a sex offender? 17 A Lbdelieve I -18 MR. PIKE: Form, 18 MR. PIKE: Form. 19 THE WITNESS: As a result of that sentence. 19 THE WITNESS: -- I believe I can live in any 20 BY MR. HOROWITZ: 20 location. 21 Q You were designated as a sex offender? 21 BY MR. HOROWITZ: 22 A That's correct. 22 Q. Any location? 23 Q Okay. So that would have been that June/July 23 A Yes, sir. 2008 time frame? 24 Q_ Ifyou know, ate there places you cannot work I believe so. UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO because of your status as a sex offender? 3 (Pages 9 to 12) (3376)

COUNAMHBWHE MR. PEKE: Form. THE WITNESS: 1 don't believe so. BY MR. HOROWITZ: Q Ifyou know, are there people that you cannot come into contact with because of your status as a sex) offender? MR. PIKE: Form. THE WITNESS: I do not know. BY MR. HOROWITZ: Q Okay. Since being sentenced — strike that. As patt of your sentence, are you forbidden from having sexual contact with minors? MR. PIKE: Form, argumentative. THE WITNESS: I'm sorry? BY MR. HOROWITZ: Q As part of your sentence, are you forbidden from having sexual contact with minors? MR. PIKE: Same objection. THE WITNESS: I don't know ~ I believe that sexual contact with minors is against the law, so 1 would assume so. BY MR. HOROWITZ: Q Okay. As part of registering as a sex offender, do you have to provide the State of Florida with your business address? Page 15} information? A. It’s done at the Stockade in Palm Beach County. Q Okay. So since being released, you travel to the Stockade to provide that information? A On advice of counsel, | am going to assert my Fifth Amendment, Fourteen Amendment and Sixth Amendment Right. THE VIDEOGRAPHER: Sorry to interrupt. 1 need to go off the record for a second because of sound, MR, HOROWITZ: All right. THE VIDEOGRAPHER: Time off the record 10:14. (Thereupon, 2 short break was taken.) THE VIDEOGRAPHER: Time on the record 10:15. BY MR. HOROWITZ: Q Sir, as part of your sentence in 2008, you also had to provide a DNA sample to the court; is that correct? MR. PIKE: Form. THE WITNESS: That's correct. BY MR. HOROWITZ: Q And per the sentence in the summer of 2008, you were to be under community control after your time in jail; is that correct? MR, PIKE: Form. Page 14 A Yes, I believe so. Q Okay. And what business address do you provid the State of Florida MR. PIKE: Form. BY MR. HOROWITZ: Q --as part of your registry with the -- as a sex offender? THE WITNESS: On advice of counsel, I am going to assert my Fifth Amendment, Fourteen Amendment and Sixth Amendment Right. BY MR. HOROWITZ: Q How many vehicles do you tell the State of Florida that you own as part of your registration as a sex offender? A Idon't know. I -- I don't know. I don't recall. Q With respect to those matters that you -- you do know that you provide to the State of Florida ~ A Yes, Q ~~ who provides that information, meaning you or someone on your behalf? MR. PIKE: Form. THE WITNESS: Ido. BY MR. HOROWITZ: Q Okay. And where do you send in that face-to-face with Miss Elkins, what -- what Page 168 THE WITNESS: That's correct, BY MR. HOROWITZ: Are you still under community control? Yes, sir, Okay. When does that end? Suly 21st -20107 -- July 10 -- yes, 2010. July 21st, 2010, your community control ceases? A_ That's correct. Q Okay. Do you have a community control officer? Yes, sir. What is his or her name? Miss Elkins, Officer Etkins. How often do you see Miss Elkins in person? At least twice a week. F Okay. How much time do you spend with Miss Elkins when you see her? A_ It varies -Q And-A ~~ up to an hour each time. Q Okay. And the typical occasion which you coms what do RPOPOPO DQDPOPOY ~ them 4 (Pages 13 to 16 UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

you do? MR. PIKE: Form. THE WITNESS: I talk to Miss Elkins. BY MR. HOROWITZ: Q > What do you talk about? A. If there's -- my schedule. 1--] prepare a schedule for Miss Elkins. Q Okay. A written schedule? A Yes, sir. Q Okay. And you do that every week, or twice a week? A_ Every week. Q Okay, When was the last time you provided Miss Elkins with a copy of your schedule? A. Last Monday. Q Okay. What is Miss Elkins' first name? A’ ft don't know. Q Okay. And so do you drive or get driven to the Stockade to see Miss Elkins? A Yes. Q > Okay. And has that been true since you were released from jail? MR. PIKE: Form. THE WITNESS: No. BY MR. HOROWITZ: COIUHATewWNHH Basically, yes. And that takes up to an hour? Yes. Okay. Anything else that you talk about other than your schedule with either Miss Sloan or your —your current -- Miss Elkins? A Not that I can recall. Q And it takes an hour approximately to talk about your schedule? MR. PIKE: Asked and answered. THE WITNESS: Up to an hour. BY MR. HOROWITZ: Q > Uptoan hour? A Yes. Q Upto an hour? A Yes, Q Okay. Is anyone else with you when you meet when you met with Miss Elkins or Miss Sloan? MR. PIKE: Form. THE WITNESS: Which time? BY MR. HOROWITZ: Q Typically. It - do you go alone? A. It's - it's -- it's in the office. MR. PIKE: Same objection. THE WITNESS: It's at the probation office. Page 18 Q Okay. For how long have you been seeing Miss Elkins one to two times per week? A Miss Elkins was -- had replaced my former probation officer, which is Carmine Sloan (phonetic), about a month ago. Q Okay. Did you have a - another probation officer before Carmine Sloan? A No, sir. Q > Okay. And when Carmine Sloan was your probation officer, were you also seeing -- were you seeing him one to two times a week? A it's her, but yes. Q Okay. And were you providing Miss Sloan with g ~- a written schedule? A Yes. Q > Okay. Other than providing Miss Sloan with a written schedule, what else - what else do you talk about? A Just my daily activities. Q_ Well, what do you tell her about your daily activities? A. Where I will be. Just my schedule. Where I will be. Q Okay. Is that the subject matter each time that you g BY MR. HOROWITZ: Q Okay. Is anyone within earshot such that they can hear your conversation? A [don't know. Q Okay. Do you travel to go see Miss Elkins or Miss Sloan with anybody else? MR. PIKE: Forn. THE WITNESS: On advice of counsel, I am going, to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Right. BY MR. HOROWITZ: Q Other than the probation officer, whether it be Miss Sloan or Miss Elkins, is there anyone else from their office that is present when you meet with them? = £ MR. GOLDBERGER: From their office, did you | say? E MR. HOROWITZ: Yes. THE WITNESS: Maybe a couple of times, mayb another probation officer. BY MR. HOROWITZ: Q. Okay. And who is that? A idon'tknow. Q Is there anything else, other than your written schedule, that you provide to Miss Elkins or Miss Sloan }} during the course of your community control? E 5 (Pages 17 to 20) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 21 A Not that I can recall. 1 Q Okay. What sort of things would we find on 2 that schedule? 3 MR. PIKE: Form. 4 THE WITNESS: Where I intend to be. 5 BY MR. HOROWITZ: 6 Q Okay. So it would have a physical location — a MR. PIKE: Form. 8 BY MR. HOROWITZ: 9 Q_ --such as "office," or would it say an 10 address? 14 A It just might say "office." It might say an 12 address, 13 Q Okay. What addresses do you provide Miss Sloar, 24 or Miss Elkins as your address when you are providing | 15 your written schedule? 16 MR. PIKE: Form. 17 MR. GOLDBERGER: Form. 18 THE WITNESS: On advice of counsel, Iam going) 19 to have to assert my Fifth Amendment, Sixth 20 Amendment and Fourteenth Amendment Right. ai BY MR. HOROWITZ: ‘, 22 Q Other than telling Miss Elkins and Miss Sloan 23 that you're at the office, where else do you tel! them 24 that you will be? Page 23 A Yes. Q Well, where do they travel to to see you? MR. PIKE: Form. THE WITNESS: On advice of counsel, I am going# to assert my Fifth Amendment, Sixth Amendment and, Fourteenth Amendment Right. BY MR. HOROWITZ: Q Okay. Other than your own office, are there any other locations where you have met Miss Sloan or Miss Elkins to discuss your schedule? A My probation office. Q Other than the probation office, are there any other locations where you've met them? A. On advice of counsel, I am going to assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment Right. BY MR. HOROWITZ: Q_ Okay. Do you anticipate that you'll be seeing Miss Elkins one to two times per week until your community control expires? A Yes. Q You were also ordered at the time of your sentence to have no contact, direct or indirect, with various girls; is that correct? MR. PIKE: Fonn, confusing. Page 22 MR. PIKE: Same objection. 1 THE WITNESS: | am going to have to assert my 2 Fifth Amendment, Fourteenth Amendment and Sixth} 3 Amendment Right. 4 BY MR. HOROWITZ: 5 Q Does the schedule -- written schedule that you 6 provide to Miss Elkins and Miss Sloan simply say a 7 location, or do you also describe your activities? 8 A Just the location. 9 Q Okay. Other than "office," what other 10 focations do you from time to time provide to Miss 11 Elkins or Miss Sloan? 12 MR. PIKE: Form. 13 THE WITNESS: I'm going -- I am going to, on 14 advice of counsel, assert my Fifth Amendment, Sixth? 15 Amendment and Fourteenth Amendment Right. 16 BY MR. HOROWITZ: 17 Q Okay. Does your community control officer ~ 18 is that -- is that the correct term, “community control 19 officer"? 20 MR. PIKE: Form. 21 THE WITNESS: I believe so. 22 BY MR. HOROWITZ: 23 Q Okay. Does your community control officer ever} 24 nounced ake unan visits to your home? UNIVERSAL COURT (954) 712-2600 Page 245 THE WITNESS: I'm sorry, I don't understand the question. BY MR. HOROWITZ: Q Sure. At the time of your sentence -- we talked about that a few times already, that was in Sune/July of 2008? A Uh-huh. Q My question is: Isn't it true you were ordered at that time to have no contact, direct or indirect, with various girls? MR. PIKE: Objection. THE WITNESS: I don't recall, BY MR. HOROWITZ; Q Do you know -A_ [don't recall. E Q Do you know whether the Judge announced that inf} Court to you on the date of your sentence? p A Idon't recall. Q Do you recall a document saying that you were directed to have no contact, direct or indirect, with various girls as part of your criminal sentence? MR. PIKE: Form. THE WITNESS: I believe that was much later. BY MR. HOROWITZ: Q Okay. At some int -- that happened later? 6 (Pages 21 to 24) REPORTING (877) 291-DEPO (3376)

Page 25 A That's correct. Q Okay. What do you understand to be the terms of this no-contact order that you believe you were provided at a later date? MR. PIKE: Form. MR. GOLDBERGER: If you know, THE WITNESS: Just to have no affirmative contact -MR. GOLDBERGER: Be specific. THE WITNESS: -- with -- with -- with three specific girls. MR. HOROWITZ: Let me just nip this in the bud. A witness -~ MR. GOLDBERGER: I~ I am just trying to help you along here, MR. HOROWITZ: Okay. MR. GOLDBERGER: No problem. You can -- you can ask the questions, and it will take an hour later. T'm trying to get you an answer that you want, MR. HOROWITZ: I appreciate that. If 1 -- and if I'm having a hard time, that's my problem. Not yours, MR. GOLDBERGER: Okay. MR. HOROWITZ: But what I was addressing was Page 27 li now, I'm just trying to help you along. MR. HOROWITZ: | appreciate that. it. MR. HOROWITZ: Allright. I'm going to put this on the record again. The local rules provide that in a deposition in a civil case one witness, one attorney who can object, period. It doesn't say if there is also a criminal case, two attorneys can speak. So if Mr. Epstein wanted to hire an attorney familiar with his criminal case for his civil case, he could have done so. If he didn't, that was at his own peril, So I'm just going to ask you to refrain, and I'm just going to put you on notice that if you -- if you interject an objection ~ MR. GOLDBERGER: Uh-huh, MR. HOROWITZ: -~- I'll seek the relief from the Court, and that's -- that's it, but - MR. GOLDBERGER: That's fine. And I'm going tdi continue to do so, and if you want to adjourn at this point, we can do that. But if | think it's an issue relevant to my representation of him on a pending criminal case, I'm going to do so, okay? MR. HOROWITZ: Okay. Page 26 not your assistance, but the fact that you're speaking up, and you're familiar with the local rules. MR. PIKE: Yeah, let me -MR. HOROWITZ: No, no, no. MR. PIKE: J know, I understand. MR. HOROWITZ: No, no ~~ MR. PIKE: Listen, we have got a -- we've got a jong day ahead of us, so fet's move along. MR. HOROWITZ; This is -- this is in the interest of efficiency. MR. PIKE: Okay. Let's go. MR. HOROWITZ: Per witness, one attorney, okay? I don't care who it is, but it can only be one of you. MR. GOLDBERGER: Okay. So here's the deal: 1 represent Mr. Epstein on his criminal cases. If T feel it is important for me to interject on issues relevant to his criminal case, I'll do so. Mr. Pike has taken the -- the lead role in representing Mr. Epstein civilly. MR. HOROWITZ: Well -MR. GOLDBERGER: If there are issues relevant to the criminal case, I'm going interject. As far as your concern about what just occurred MR. GOLDBERGER: And you'll -- you're free to| seek whatever relief you want. MR. PIKE: And -- and let me -- let me put something on the record, since you chose to do so. One, this is -- this proceeding has a quasiMR. GOLDBERGER: That's the only reason I did. criminal component to it, and your questions today, f Mr. Horowitz, are interjected in a manner in an attempt to cause Mr. Epstein to waive his Fifth Amendment Right, along with his Sixth and his Fourteenth which are incorporated therein. So the fact that Mr. Goldberger is here making sure that his client and my mutual client maintain and preserve those privileges that are afforded under the United States Constitution, he will continue to do that today, okay? Now, we're here to answer your questions. We're here to move forward with the depo. We'd like to do that. If you'd like to adjourn to take this up with the Court today, we could do that as well, but it was -- it's your choice. MR. HOROWITZ: Okay. MR. PIKE: Okay? BY MR. HOROWITZ: Q One girl that you were ordered to have no contact with is Jane Doe 2, correct? 7 (Pages 25 to 28) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

MR. PIKE: Form. THE WITNESS: I don't know, BY MR. HOROWITZ: Q Another girl that you were ordered to have no contact with is Jane Doe 4, correct? MR. PIKE: Form. THE WITNESS: No, I don't -- you -~ you've asked me @ question regarding a criminal case? MR. HOROWITZ: Correct. THE WITNESS: So regarding my criminal case, believe the answers to the both of those questions are no. BY MR, HOROWITZ: Q Okay. [have some more questions about your criminal case. A Okay. Q Another girl that you were ordered to have no contact with as a result of your -- following your sentence is Jane Doe 6; is that correct? MR. PIKE: Form. THE WITNESS: | don't believe so. BY MR. HOROWITZ: Q Okay. And another girl that you were ordered to have no contact with as a result of your criminal case is Jane Doe 7, correct? Page 30 A [don't believe so. Q Okay. Another girl that you were ordered to have no contact with is Jane Doe 5? MR. PIKE: Form. THE WITNESS: As far as my criminal case, I don't believe so. BY MR. HOROWITZ: Q Okay. Another girl you were ordered to have no contact with is Jane Doe 8, correct? MR. PIKE: Form. THE WITNESS: I'm sorry, who? MR. HOROWITZ: Jane Doe 8. THE WITNESS: I don't believe so. BY MR. HOROWITZ: Q Okay. Another girl you were ordered to have no contact with is Jane Doe 3, correct? MR. PIKE: Same objection. THE WITNESS: I don't believe so. BY MR, HOROWITZ: Q Okay. Are you aware of the names of any girls who you were ordered to have no contact with as part of your criminal case? MR. PIKE: Fonn. THE WITNESS: On the advice of counsel, I am going t to assert my Fifth J Amendment, Sixth Amendment Page 31 and Fourteenth Amendment Right. MR. HOROWITZ: Okay. I mentioned seven girls’ names. I'll just put them on the record so you know what seven girls I'm talking about, THE WITNESS: Okay. MR. HOROWITZ; Jane Doe 5, Jane Doe 8, Jane Dog 6, Jane Doe 2, Jane Doe 3, Jane Doe 7. b BY MR, HOROWITZ: Q Isit your testimony today that you were not ordered as a result of'a criminal case to have no contact with them? MR. PIKE: Form, THE WITNESS: That's my best recollection. BY MR. HOROWITZ: Q Okay. And, therefore, since you have no recollection of being ordered, you've made no affirmative attempt to have no coniact with them; is that correct? MR. PIKE: Form, asked and answered. I am. going to instruct him not to answer that question. Ifyou want to rephrase it, go ahead. MR. HOROWITZ: Are you going to accept accept his advice? MR. PIKE: Yeah. THE WITNESS: Yes. BY MR. HOROWITZ: Q Okay. Have you made any affirmative attempt to have no contact with Jane Doe 5, Jane Doe 8, Jane Doe 6, Jane Doe 2, Jane Doe 3, Jane Doe 4 or Jane Doe 7? MR. PIKE: Form, lack of predicate and foundation. THE WITNESS: And on the advice of counsel, I am going to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Right. BY MR. HOROWITZ: Q Have you at any time known the names of the girls that you were directed to have no contact with — MR. PIKE: Same objection. BY MR. HOROWITZ: Q_ -- in the criminal case? A Known the names? Q. Known, known. A [was told that in fact some of your -- the cases that were filed against me by your firm, a firm whose partner was disbarred for his conduct, and in fact Mr. Edwards sitting there with his firm who is called by the U.S. Attorney to be the largest fraud in South Florida's history — I believe these girls have always been -- and I believe the ladies and gentlemen of the juyy will eventually be aware that these girls have 8 (Pages 29 to 32) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 33 Page 35 1 filed the claim many years after they alleged and even 1 Q Are you suggesting that somehow the Plaintiffs} 2 associated with firms whose partners have been disbarred 2 fabricated their allegations because of their 3 and is part -- one of his partners is currently in jail, 3. association with these lawyers? 4 yes. 4 MR. PIKE: Form. 5 Q Okay. Are you suggesting that a partner of 5 THE WITNESS: In fact, according to the E 6 mine was disbarred? Is that your testimony? 6 newspapers, the attorney who's -- who is currently a MR. PIKE: Form. 7 sitting in jail, Mr. Edwards' partner, was accused 8 THE WITNESS: Yes, that's — I believe that's 8 of fabricating many cases not only against people 9 my understanding. 9 like me, but others, of the sexual nature, very 10 BY MR. HOROWITZ: 10 similar to the ones you've filed. 1 Q Okay. Are you suggesting that my clients 11 BY MR. HOROWITZ: H 12 fabricated their claims against you after coming into 12 Q Okay. As to my clients -- I'm not asking about 13 contact with an attorney who you believe was 13 anybody else's clients. As to my client, are you 14 disciplined? 14 — suggesting that they fabricated any aspect of their 15 MR. PIKE: Form. 15 dealings with you as a result of their dealings with 16 THE WITNESS: You know, I'd really like to 16 their attorney, or some remote dealings with 17 answer that question, and hopefully some day I 17 Mr. Rothstein? Is that — is that your testimony? 18 will. I think the answer is pretty obvious to you 18 A [think that answer -19 and the other people in this room, but, however, 19 MR. PIKE: Form, predicate, foundations, sorry. 20 today, Mr. Horowitz, Lam going to, on the advice 20 THE WITNESS: I think that answer is pretty ff 21 of counsel, have to assert my Fifth Amendment, 21 obvious. But, however, on advice of counsel, I 22 Sixth Amendment and Fourteenth Amendment Right, | 22 cannot answer any questions today that are relevant 23 though I would like to -- and I'm sure you and the 23 to this law -- to these lawsuits. I would like 24 ladies and gentlemen understand, I'd like to answer 24 to. I'm sure everybody knows that I would like 25 that question. 25 to. You know ! would like to. But today, on the Page 3a 1 BY MR. HOROWITZ: 1 advice of counsel, I am going to have to assert my |; 2 Q > Well, you mentioned an attorney who you believ 2 Fifth Amendment, Sixteenth -- sorry — Sixth 3 was disciplined, and you mentioned an attorney who you 3 Amendment and Fourteenth Amendment Rights as ff 4 believe -- 4 guaranteed by the Constitution. : 5 A. [don't believe I said "disciplined." I think 5 And if] don't follow their advice and J prefer 6 you -- I said "disbarred." 6 -- | would actually prefer to answer the question, 7 Q Disbarred, okay. 7 but if I don't follow their advice, I am going to 8 A Is that correct? 8 risk losing my counsel, which is a violation. So 1 9 Q No, it's wrong, but that was your words. 9 am going to have to assert those rights today. 10 A He was not disbarred? 10 MR. PIKE: Okay. And just for the record -ad Q I'm not allowed to testify to those -- 11 MR. HOROWITZ: Move to strike the 12 A Oh, I'm sorry. 12 non-responsive portion. 13 Q Ididn't create these rules. 13 MR. PIKE: Just for the record, let's try to go 14 A I thought he was disbarred. I think the paper 14 -- take turns for the court reporter's benefit. 15 said he was disbarred. 15 Finish your answer -16 Q Okay. You mentioned that an attorney was 16 THE WITNESS: Okay. ; 17 disbarred, and another attorney -- 17 MR. PIKE: -- finish your question, before both 18 A Your partner was disbarred. Not an attorney, 18 of you continue to talk to -- over each other, 19 correct? 19 thanks. 20 Q You mentioned that my partner was disbarred, 20 BY MR. HOROWITZ: 21 and that's your testimony? Q Mr. Epstein, if 1 heard you right, you said 22 A Yes. 23 Q And you mentioned that another attorney committed fraud? Page 36} Fifth, Sixth and Fourteenth Amendment; is that right?{ a PIKE: Form. am going to instruct him 9 (Pages 33 to 36) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 37 not to answer that question because the way it's phrased attempts to elicit attorney-client communications, BY MR. HOROWITZ: Q Did I paraphrase you correctly? A No, you did not. Q Okay. Well, sir, are you -- are you testifying that Jane Doe 2 falsified a lawsuit because of her association with a lawyer? MR, PIKE: Form, predicate, foundation. THE WITNESS: I would really like to answer that question, but today, and just today at least on the advice of counsel, | cannot, because they have advised me that if do, I risk losing their counsel, but as I think it is going to be pretty obvious, I would like to answer that question, but on the advice of counsel, | am going to assert my Fifth, Sixth and Fourteenth Amendment Right as provided by the U.S. Constitution. BY MR. HOROWITZ: Q > Well, Mr. Epstein, if you continue to laugh at any of my questions, shake your head, nod, it's my intention te inform the Court and file a motion that you've waived your Fifth Amendment Right. MR. PIKE: All right. First of all, that's -Page 39 just said about his Constitutional Rights. He said he would be losing his Sixth Amendment Right to effective representation. Do you understand -- is that what you said, sir? MR, PIKE: Form, THE WITNESS: Correct. BY MR. HOROWITZ: Q Okay. Okay. When you say your Sixth Amendment Right to effective representation, who — representation f by who? Who -- who are you talking about? MR. PIKE: Form. !'m going to instruct him not to answer that question. BY MR. HOROWITZ: Q Are you suggesting that your attorneys would not represent you if -- if you didn't assert your Sixth Amendment Right? MR. PIKE: Same objection. I'm going to instruct him not to answer that question, altorneyclient. BY MR. HOROWITZ: Q How do you ensure that you have no contact with the various girls you've been ordered to have no contact with? MR. PIKE: Form, predicate, foundation. THE WITNESS: On advice of counsel, 1 am going Page 38 that’s argumentative and it's harassing, and you don't have a question on the table, so let's -let's -MR. HOROWITZ: Why are you interrupting me? MR. PIKE: Because -- because this deposition is not going to be utilized as a -- as a means to harass my client. Ask your questions, you'll get your answers, and let's move forward. BY MR. HOROWITZ: Q_ I'm going to ask that you not shake your head, nod or laugh at my questions. Because if you do, it will be at your own peril, because ['m -- I will file a motion to have your Fifth Amendment Rights waived. MR. PIKE: I'm going to move to strike -MR. HOROWITZ: Okay. MR. PIKE: -- your two last statements, Mr. Horowitz. Let's get on with the deposition. BY MR. HOROWITZ: Q When you said that you must accept the advice of your attorney or risk waiving your Constitutional Rights, what advice were you talking about? MR. PIKE: Form. I'm going to instruct him not to answer that question. He's asserting his Constitutional Rights. MR. HOROWITZ: And I want to explore what Page 40 L to have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights as guaranteed by the U.S. Constitution, though I would like to answer that question, BY MR. HOROWITZ: Q_ With respect to those girls whom you've been ordered to have no contact with, have you had any contact, direct or indirect, with them since receiving that order? MR. PIKE: Same objection; form, predicate and foundation. THE WITNESS: I would like to answer that question, however, today my -- I have been informed that I cannot answer any questions that may be relevant to your lawsuit. So I'm going to assert my Fifth Amendment, Sixth Amendment and Fourteentli Amendment Right. Excuse me, could | use the restroom? MR. HOROWITZ: Yes. Ee THE VIDEOGRAPHER: Time off the record 10: 354 te (Thereupon, a short break was taken.) F THE VIDEOGRAPHER: Time on the record 10:42, BY MR. HOROWITZ: Q_ Asaresult of your criminal sentence, how many _sirls were YOU ¢ ordered to have no contact with? 10 (Pages 37 to 40) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

MR. PIKE: Form. THE WITNESS: Three. BY MR. HOROWITZ: Q > Okay, And what are their names? MR. PIKE: Form. THE WITNESS: I believe it was Jane Doe 103, A.D. and 8.G, MR. HOROWITZ: Can you read that back? THE REPORTER: A.H. -MR. HOROWITZ: No, I don't think that's right. That's not what he said. (The pending answer was read back by the court reporter.) MR. HOROWITZ: Thank you. BY MR. HOROWITZ: Q Is it your testimony, sir, that those are the only three girls who, as a result of a criminal case against you, you've been ordered to have no contact with? MR. PIKE: Form. THE WITNESS: That's correct, BY MR. HOROWITZ: Q Okay. With respect to $.G., do you acknowledge that she has been to your home? MR. PIKE: Form. Page 43% THE WITNESS: Again, I would like to answer |; that question, and I'm sure you know | would like to answer that question. I'm sure your partner that was disbarred while he represented S.G., I believe, or her parents, or he claimed he represented one parent, and the other parent sued him or tried to bring a lawsuit against your partner -- I would like to answer any questions with respect to S.G., but today on advice of counsel, I'm not going to be able to do that because they've advised me J must assert my Fifth, & Sixth and Fourteenth Amendment Right -MR. HOROWITZ: Okay. THE WITNESS: -- so therefore -- excuse me, [ am going -- should I finish? MR. PIKE: Yes. | THE WITNESS: So, therefore -- though I would} like to answer that question and --Iam goingto & have to assert those rights. MR. HOROWITZ: Okay. Move to strike the non-responsive -- the non-responsive portion of the answer. E BY MR. HOROWITZ: Q Do you acknowledge, sir, that with respect to S.G. during her childhood, you paid her for sexual Page 42 THE WITNESS: Sorry? BY MR. HOROWITZ: Q With respect to S.G., do you acknowledge she has been to your home? MR. PIKE: Same objection. THE WITNESS: On advice of counsel -- I would like to answer al] your questions today, Mr. Horowitz. I'm sorry your partner that was disbarred is not here, because I would like to answer his questions because I believe he was the one who represented S.G. So 1 would like to see Mr. Herman at some point when he gets -potentially gets his license back. But, though I would like to answer your questions in more detail, on advice of counsel, | am going to have to assert my Fifth, Sixth and Fourteenth Amendment Rights under the U.S, Constitution. 1 would like to answer the question, but my counsel has told me that J risk losing their representation if I do, so, therefore, I'm going to have to assert those rights. BY MR. HOROWITZ: Q With respect to S.G., do you acknowledge that she has -- she went to your home when she was a child? MR. PIKE: Form. Page 44§ contact? MR. PIKE: Form. bE THE WITNESS: Again, I would like to answer that question, but as most of your other questions here today, and 1 -- I understand that your partner who represented this S.G. was disbarred, but at some point in future I would like to answer that. Today, unfortunately, 1 am going to have to assert [; my Fifth, Sixth and Fourteenth Amendment Rights } under the U.S. Constitution because my counsel has| advise me that, though I would like to answer that question, I cannot today. BY MR. HOROWITZ: Q Are you suggesting, sir, that S.G. fabricated or embellished her allegations because of her association with a disbarred attomey? MR. PIKE: Form, move to strike, mischaracterizes the witness’ testimony. THE WITNESS: Can you repeat the question? [ BY MR. HOROWITZ: Q Are you suggesting that S.G. either fabricated or embellished her — her allegations because of any association she had with an attorney who's been disbarred? MR. PIKE: Same objection. 11 (Pages 41 to 44} UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 45 THE WITNESS: It's not an attorney who's been disbarred. { believe J said it's your partner that was disbarred when -- after representing S.G., and L would like -- though I would like to answer those questions in detail, today I have been advised by counsel that I cannot answer any questions that may be relevant to your lawsuits -MR. HOROWITZ: All right. THE WITNESS: -- and —- excuse me. MR. HOROWITZ: Go ahead, finish. THE WITNESS: Thank you. And, though I would like to answer the questions, and [ know you keep trying to strike my answer with respect to $.G.'s representation by your former partner, Jeffrey Herman, who was disbarred, who held press conferences to try to make a big -- so he tried to embarrass me as best as he could, I'm -- I would like to answer those questions, but I cannot on advice of counse). BY MR. HOROWITZ: Q Okay. And do you fee! that because my partner, Jeffrey Herman, was an attomey involved in S.G.'s case, } that somehow the allegations she’s made against you are fabricated or embellished? A I'd let -- the ladies and gentlemen of the jury Page 47 because Jeffrey Herman was involved in the representation of S.G., that her allegations of abuse by you are fabricated or embellished? MR. PIKE: Form, predicate, foundation. THE WITNESS: J would very much like to answer the question regarding $.G. -- which embellishments, as you've described them, or fabrications -- at the same time she met your partner that was later disbarred. However, as of today, though I would like to answer those questions -- and I think those answers are pretty obvious -- | am going to have to assert my Fifth ki Amendment, Sixth Amendment and Fourteenth Amendment Rights under the U.S. Constitution. And, though | think again those -- that answer is obvious, and will be obvious to most people here on the jury, my attorneys have advised me I cannot answer that question today. BY MR. HOROWITZ: Q Okay. You told us that in addition to S.G., you were also ordered to have no contact with Jane Doe 103 and A.D.; is that correct? A Excuse me, yes. Q And when did you receive such an order? MR. PIKE: Form. Page 46 will make that decision, I'm sure. J can't -- | would like to answer those questions. [ would really like to answer -- | think those answers are obvious, frankly. But today, on advice of counsel, I'm not going to be able to answer those questions. ] am going -Q Well-A> Mr. Horowitz, I would like to finish my answer, please. Is that okay? Q Well, you keep repeating yourself. THE WITNESS: Mr. Pike? MR. PIKE: Go ahead and finish. Please allow -- allow the witness to finish his answer. THE WITNESS: So let's start -- should -- could you repeat the question, please? MR. HOROWITZ: Yes. {The pending question was read back by the court reporter.) MR. HOROWITZ: That wasn't exactly the question, but I'l] ~- let me ask it again. Maybe it will be smoother, and just try and follow what it is I'm asking. THE WITNESS: I'm trying my best. BY MR. HOROWITZ: Do jeve, ag we sit here tod: THE WITNESS: I don't recall. BY MR. HOROWITZ: Q Okay. Was it~ if I heard you correctly, it was in association with your criminal case? A That's correct. Q Okay. And with respect to Jane Doe 103, do you acknowledge that she has been to your home? MR. PIKE: Form. THE WITNESS: Again, I would like to answer most of your questions. However, today, as I've answered most -- almost all of your questions and wil] continue to answer, on advice of counsel, [ believe, this question, I have to assert my Fifth Amendment, Fourteenth Amendment and Sixth Amendment Rights under the U.S. Constitution. BY MR. HOROWITZ: Q. Okay. And -- are you done? A (No verbal response). Q Do you acknowledge that Jane Doe 103 came to your home for sexual contact during her childhood, and that you paid her for those services? MR. PIKE: Form, predicate, foundation, argumentative, THE WITNESS: I'd — | would like to answer that question. I think those questions will all 12 (Pages 45 to 48) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 49 Page 51 Mr. Ep tein was requ ji ed fo provide us the names of | 1 have obvious answers and not ~ however, today, [ 4: his doctors and as well as his prescriptions, 2 am going to have to assert my Fifth Amendment, 2 correct? You're aware of that? 3 Sixth Amendment and Fourteenth Amendment Rights 3 MR. PIKE: I recail that order, but I don't 4 under the U.S. Constitution, because, though I 4 recall -- I don't recall -- if you have the -- if 5 would like to answer that question, my attorneys. 5 you have the answers, then you can provide them to 6 have advised me that I cannot -- today cannot 6 me, and maybe I would be better situated to allow 7 answer any questions that may be relevant to this 7 the client to answer or not answer the questions. 8 lawsuit, 8 L saw your associate reaching for something. So E 9 BY MR. HOROWITZ: 9 maybe -- maybe you do have them, you can refresh my 10 Q Okay. You also told us ~ provided this name 10 recollection. 11 of A.D, Do you acknowledge that A.D. was paid by you {| 11 MR. HOROWITZ: Well, I'm just going to ask the 12 for sexual contact during her childhood? 12 witness -- I'm not here to refresh his E 13 MR. PIKE; Form, predicate, foundation, 13 recollection. I want his -14 argument. 14 MR. PIKE: Or mine, 18 THE WITNESS: | would like to answer that 15 MR. HOROWITZ: Or yours. 16 question, as 1 would like to answer most of your 16 MR. PIKE: Right. E 17 other questions bere today, but J, unfortunately, i7 MR. HOROWITZ: | want his testimony on today's E 18 am going to have to answer that one, as I've 18 date as to the truth. f 19 answered most of your other questions, which is 19 MR. PIKE: Okay. Well, I'm going to instruct 20 unfortunately today, | cannot answer any question 20 him not to answer that question right now. Let's 2. that may be relevant to this lawsuit on advice of 21 22 counsel. I must assert my Fifth Amendment, Sixth 22 MR. HOROWITZ: You guys want to talk among 23 Amendment and Fourteenth Amendment Right under thd 23 yourselves? 24 U.S. Constitution. 24 MR. PIKE: Sure. I'm still going to maintain BY MR, HOROWITZ: 25 the objection it's also attorney-client and work Page 50] Page 525 1 Q > When in the future do you presently intend to 1 product. 2 — stop asserting your Fifth, Sixth and Fourteenth 2 BY MR. HOROWITZ: 3 Amendment Rights, if any, and intend to start answering} 3 Q What -- are -- are you under the care of any 4 these questions? 4 physicians at the present time other than Dr. Alexander? 5 MR. PIKE: Form. | am going to instruct him 5 MR. PIKE: Form, predicate, foundation and 6 not to answer that question, attomey-client. 6 mischaracterizes, I believe, my objection. 7 BY MR. HOROWITZ: 7 THE WITNESS: 1 would tike to answer that 8 Q Do you intend at trial to start answering these 8 question, as I would like to answer most of your 9 questions? 9 other questions here today, but today I am going to 10 MR. PIKE: Same objection. I am going to 10 have to assert my Fifth Amendment, Sixth Amendment aL instruct him not to answer, attorney-client. 11: and Fourteenth Amendment Rights under the advice -12. BY MR. HOROWITZ: 12 on advice of counsel. 13 Q At the time of your sentence you told us -- 13 BY MR. HOROWITZ: 14 — which was in the summer of 2008, did you have a privat¢ 14 Q Allright. What doctors have you been under 15 psychologist -- 15 _ the care of in the past five years? 16 MR. PIKE: Form. 16 MR. PIKE: Form. 17 BY MR. HOROWITZ: 7 THE WITNESS: { am going to have to assert my 18 Q ~ named Dr. Alexander? 18 Fifth Amendment, Sixth Amendment and Fourteenth 19 MR. PIKE: Form. | am going to instruct him 19 Amendment Rights on advice of counsel, though I 20 not to answer that question as well because the 20 would like to answer these questions. 21 Judge has already ruled that Mr. Epstein's medical 21 MR. HOROWITZ: Okay. I mean, you -- you coul 22 history is not an element in any of these cases. 22 — you can tell your client to do what you want, 23 MR. HOROWITZ: Well, despite -- you -- you-- | 23 but, I mean, we have a specific court order. you're aware we have a court order in which 24 MR. PIKE: Do you have a copy of it with you? 28 MR. HOROWITZ: Durin; the break Hl get ou a ae 13 (Pages 49 to 52) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 53 Page 55 f5 2 Other than Lipitor, are the there any ¢ other 25 1 copy. 1 medications that you have been prescribed or have taken : 2 MR. PIKE: I mean, if you have a copy of an 2 inthe past five years? 3 order, and you want to refresh my recollection ~ 3 A On advice of counsel, | am going to have to 4 since the Fifth Amendment and the Sixth Amendmeng 4 assert my Fifth Amendment, Sixth Amendment and 5 and the Fourteenth Amendment are highly technical 5 Fourteenth Amendment Rights, though I would like to 6 Constitutional Amendments, if you wish to ask my 6 — answer that question. % client questions based upon an order, 1 would ask 7 Q Okay. Is it true, sir, that a - a girl named 8 that you simply provide me with the order 8 — Jane Doe 2 came to your Palm Beach home in late 2004 9 beforehand, and then we can make this a much easier] 9 A Is she someone you represent? 10 process, We're here for you, Adam. 10 Q Do you -- do you — do you not know the answ: il MR. HOROWITZ; Thanks. I'm pretty sure the al A Edo not know the name. 12 Court gave you a copy of the order, but -- but it's 12 Q Okay. Do you know we're here on a case called 13 okay. We can move on. During the break we'll 13 Jane Doe 2 vs. Jeffrey Epstein? 14 address it. a4 MR: PIKE: Form. is MR. PIKE; No -- well, wait a second ~ as THE WITNESS: Yes. 16 MR. HOROWITZ: During the break we'll addresd| 16 BY MR. HOROWITZ: i 17 it. 17 Q And you've seen that on the deposition notice? 1a MR. PIKE: -- I am not going to banter with 18 A Yes. E ig you, and nor am | going to accept this type of 19 Q Are you suggesting that you — you do not know i 20 laughing from the corner show over there 20 who Jane Doe 2 is? E 21 (indicating). Listen, the fact remains is this: 21 MR. PIKE: Form. Hi 22 There have been several orders. That of which I 22 THE WITNESS: I've seen it on the allegation ~- : 23 was the initial author of the -- of the motions 23 on your complaint today, 24 that resulted in the positive orders, reflective of 24 BY MR. HOROWITZ: i 25 the Fifth, Sixth and Fourteenth Amendment, So it | 25 Q Okay. So we have the answer to that question? Page 54 Page 56] L is: If you have some of those orders, which are 1 MR. PIKE: Form. : 2 probably ten plus, bring them to me, and I will 2 THE WITNESS: I see it's on the complaint. 3 read them, and we will make this deposition go 3 BY MR. HOROWITZ: 4 forward a lot easier. 4 Q You've been a Defendant in that lawsuit for the 2 5 BY MR. HOROWITZ: 5 past two years? : 6 Q Allright. Are you -- have you been prescribed} 6 A I} don't know the time. i 7 any medications in the past five years? 7 Q Do you know who the Plaintiff is, Jane Doe 2? : 8 MR. PIKE: Form. 8 MR. PIKE: Form. E 9 THE WITNESS: It's the same answer. [would| 9 ‘THE WITNESS: I read the complaint. E 10 like to answer that question, as I would like to 10 BY MR. HOROWITZ: E 1. answer most of your other questions here today. aL Q Okay. Allright. My -- my earlier question to ff 12 However, I've been advised by counsel that at least} 12 you was: Isn't it true that a girl named Jane Doe 2 -- ; 13 today I cannot answer those questions, and I must | 13 A’ Uh-huh. E 14 assert my Fifth Amendment, Sixth Amendment and} 14 Q_ ~ came to your Palm Beach home in -- in late [f 15 Fourteenth Amendment Right. 15 20042 E 16 BY MR. HOROWITZ: 16 A 1~ again, I understand that Jane Doe 2 was a 17 Q So you -- you told us ina sworn interrogatory | 17 represented by your partner, Jeffrey Herman, who was | 18 answer that you were prescribed Lipitor, and that you} 18 — disbarred by The Florida Bar Association. | believe shai 19 take -- you take Lipitor. Are there other medications | 19 was represented by Mr. Herman prior to his disbarment} 20 that you receive, for instance, to treat you for a 20 I believe he represented her in a -- in some type of 21 sexual disorder? 21. press conference in association with other firms later 22 MR. PIKE: Form. I am going to instruct him 22 where other partners have gone to jail for representing [ 23 not to answer that question as phrased. 23 claims of a sexual nature against people like me and BY MR. HOROWITZ: 24 — others, and the U.S. Attorney called one of the other firms involved i in this the largest fraud ii in Florida -- “= UNIVERSAL COURT (954} 712-2600 (877) (Pages 53 to 56) REPORTING 291-DEPO (3376)

Page 57 in South Florida's history. But separate from that, unfortunately today, | am going to have to assert my Fifth Amendment, Fourteen Amendment and Sixth Amendment Rights on the advice of counsel. MR. HOROWITZ: Okay, Move to strike that. BY MR. HOROWITZ: Q Do you believe that Jane Doe 2's lawsuit against you was either fabricated, falsified or embellished due to any association she had with an aitorney who was suspended or disbarred, as you say? MR. PIKE: Form. THE WITNESS; Again? BY MR. HOROWITZ: Q Do you believe that Jane Doe 2's lawsuit was either fabricated or embellished because of her association with any attorney? MR. PIKE: Form, THE WITNESS: I would like to tell you my beliefs. 1 would like to give you an answer to that question. I would like to -- I'm sure the jury is going to want to explain -- understand that she was represented by an attorney that was disbarred at the time when this lawsuit, I believe, got filed. Later he was disbarred. Today I would ike to answer that question, but however, today on. home? MR. PIKE: Form. THE WITNESS: Can you tell me who those peopld are? Are those two of your clients? MR. HOROWITZ: Yes, two of the three people 1 mentioned are my clients. BY MR. HOROWITZ: Q. Are -- are -- are -- are -- are you denying that those girls were in your home? A I'm asking you for clarification. Q Okay. Do you want me to repeat the question? A Do understand the question that two of your clients have suggested one of your clients brought the other client? Q Okay. Let me back up. A Sorry. Is that -- is that -Q My questions aren't suggesting anything. They're asking a question. Do you understand that? A understand that. Q Okay. My question is: Is it true that in late 2004 ~ A Yes, Q_ --S.K. received a telephone call wherein she was told that Jane Doe 3 was bringing Jane Doe 2 to your| home? Page 58 advice of counsel! I cannot, and I am going to have to assert on their advice my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights under the U.S. Constitution or risk losing their counsel. MR. PIKE: Let me take a break really quick. I need a 60-second break. THE VIDEOGRAPHER: Time off the record 10:59, (Thereupon, a short break was taken.) THE VIDEOGRAPHER: Time on the record 11:06, BY MR. HOROWITZ: Q Sir, between 2001 and 2006 did you instruct S.K. to place telephone calls to arrange for girls under the age of 18 to come to your home for your sexual gratification? MR. PIKE: Form, THE WITNESS: Though ! would like to answer that question, today, on advice of counsel, fam going to have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights under thd US. Constitution. And, though I'd really much like to answer that question, today, I cannot. BY MR. HOROWITZ: Q Isittrue, sir, that in Jate 2004 S.K received a telephone call wherein she was told that a girl named Jane Doe 3 was bringing a girl named Jane Doe 2 to your MR. PIKE: Form. THE WITNESS: I'd like to answer that question, but unfortunately, today, at least, I am going to have to answer that like I've answered many of your other questions. Unfortunately, I have to answer ~ on advice of counsel, 1 am going to have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights under the U.S, Constitution because I've been told that [ cannot answer any questions that may be relevant to any of your lawsuits, or -- and if I do, I risk losing my representation. BY MR. HOROWITZ: Q Okay. Did you instruct S.K. to communicate by § telephone to arrange for Jane Doe 2 to come to your home: for your own sexual gratification? E MR. PIKE: Form. THE WITNESS: Who? I'm sorry, what was the name again? BY MR. HOROWITZ: Q_ This is about the fifth time | mentioned her name. Her name is Jane Doe 2. A’ Uh-huh, MR, PIKE: Same objection. : I'd like to answer thi 15 (Pages 57 to 60) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 61 as I would like to answer most of your other questions here today, Mt, Horowitz, However, on advice of counsel, they have instructed me that I cannot answer any questions that may be relevant to any of your multiple lawsuits. So, though I would like to answer it today, I am going to have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights as provided by the U.S. Constitution. BY MR. HOROWITZ: Q_ Tam going to stick with the line of questions involving Jane Dos 2, so I'm just going to ask that you keep that name in your head, okay? Jane Doe 2; you got that? A Ul try. Q Okay. Thank you. Did you inform S.K. that Jane Doe 2 would be giving you a massage that was sexual in nature? MR. PIKE: Form. THE WITNESS: | have -- I'm going to have to answer that question ~ though I would like to answer that question today, I am going to have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights, because on advice of counsel f cannot answer that question no matter how Page 62 much I actually want to today. So, unfortunately, Flt have to assert those rights. BY MR. HOROWITZ: Q_ Did you observe S.K. speaking by telephone to atrange for Jane Doe 2 to come to your home to give you a sexual massage? MR. PIKE: Form. THE WITNESS: Again, I'm going to have to answer that the way I've answered your other questions, Mr. Horowitz, which is, though I would like to answer that question today, on advice of counsel, [ cannot answer any questions that may be relevant to any of your lawsuits. Therefore, | must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights as provided by the U.S. Constitution. And if I don't answer that way, I tisk losing my counsel's representation. BY MR. HOROWITZ: Q Did $.K. tell you that she confirmed by telephone that Jane Doe 2 would be coming to your home at a specific time to give you a massage? MR. PIKE: Form. THE WITNESS: Though I would like to answer all of your questions here today, and 1 would like to answer that i ing to Page 63 have to respond the same way I've responded te most of your other questions here today, which is on advice of my counsel, | am going to have to assert my Fifth Amendment, Sixth Amendment and Fourteentlt Amendment Rights as provided by the U.S, Constitution. And, though | would like to answer that question, if! do so, J risk losing my counsel's representation, BY MR. HOROWITZ: Q > Was it your intent during the course of Jane Doe 2's visit to your home, that you would persuade, induce of entice her to engage in sexual activity? MR. PIKE: Form. THE WITNESS: Again, [ would like to answer that question, as I would like to answer most of your other questions here today. However, on advice of my counsel, 1 cannot answer those questions today, so 1 am going to have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights as provided by the U.S. Constitution, And, though | would like to answer it, and J think -- ] am going to have to assert those rights, BY MR. HOROWITZ: Q Okay. During the course of Jane Doe 2's visit I Page 645 to your home, did you, in fact, persuade, induce or entice her to engage in sexual activity with you? MR. PIKE: Form. THE WITNESS: Though J would like to answer that question, as I would like to answer most of your other questions here today, on advice of counsel, [ am not going to be able to answer those questions here today. They've advised me [ must assert my Fourth -- excuse me -- Fifth -» excuse me —~ Sixth and Fourteenth Amendment Rights as provided by the U.S. Constitution. And if] don't do so, I potentially risk losing their representation, so though I'd like to answer it, I must not. BY MR. HOROWITZ: Q Okay. Atno point did Jane Doe 2 tell you that she was 18 or older, correct? MR. PIKE: Form. THE WITNESS: Again, I would like to answer -Td really like to answer that question. However, T cannot, because on advice of counsel, I've been advised that I must assert my Fifth Amendment, Fourteenth Amendment and Sixth Amendment Rights agi provided by the U.S. constitution. And if! don't do so, I potential i 16 (Pages 61 to 64) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 65 representation, though I would like to answer that question. BY MR. HOROWITZ: Q In your own mind, you didn't believe that when Jane Dee 2 came to your home that she was 18 or older, correct? MR. PIKE: Form. THE WITNESS: I'd really like to answer that question. I'd really like to answer most of your other questions here today. But however, on the advice of counsel, they've advised me [ must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights as provided by the Constitution, and have asked me or instructed me, not to answer any questions that may be relevant to this lawsuit. So, though I would like to answer it, T cannot. BY MR. HOROWITZ: Q Okay. Jane Doe 2 told you that she attended Royal Palm Beach High Schoo! when she came to your homé correct? MR. PIKE: Forn. THE WITNESS: | would like to answer that question, as I would like to answer every one of your questions here today. However, on advice of MR. PIKE: Form. THE WITNESS: I'd like to answer that question. } would like to answer that question, as I've had -- | would like to answer most of your other questions here today. However, upon advice of counsel, ! have been instructed that | must assert my Pifth Amendment, Sixth Amendment and Fourteenth Amendment Rights as provided by the U.S. constitution. And though I would like to answer that question, I cannot. BY MR. HOROWITZ: Q During Jane Doe 2's visit to your home in 2004, did you instruct Jane Doe 2 to pinch your nipples and rub your chest? MR, PIKE: Form. THE WITNESS: 1d like to answer that question here today, like I'd like to answer most of your other questions here today, but, unfortunately, [ am going to respond, as I've responded to virtually all of your questions, which is on advice of Counsel! today, at feast today, I cannot answer those questions, but must assert my Fifth E Amendment, Sixth Amendment and Fourteenth Amendment, Right as provided by the U.S. Constitution, And E therefore, though 1 would like to answer it, lam Page 66 counsel, { cannot. And, though | would like to, | must assert my Fifth Amendment, the Sixth Amendmen and Fourteenth Amendment Rights as provided by the U.S. Constitution. And if I don't do so, I risk losing their representation. Though I would like to answer, but today I cannot. BY MR. HOROWITZ: Q During Jane Doe 2's visit to your home in 2004, you were nude in front of her, isn't that right, sir? MR. PIKE: Form. THE WITNESS: I would like to answer that question, as | would like to answer most of your other questions here today. But my answer is going to be virtually the same as ['ve had to answer most of your other questions, which is on advice of counsel, | cannot answer those questions. I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights as provided by the U.S. Constitution. And if] don't do so, I've been told 1 lose risking -- excuse me -- I risk losing their representation, and so therefore, I cannot answer that question. BY MR. HOROWITZ: Q During Jane Doe 2's visit to your home in 2004, did you instruct her to remove all of her clothing? Page 68 going to be required by my counsel not to. BY MR. HOROWITZ: d Q During Jane Doe 2's visit to your home in 2004, did you ask her questions about her sexual experiences |} and preferences? MR. PIKE: Form. l THE WITNESS: Though I would like to answer |} like to answer most of your other questions here today, my counsel has advised me I must assert my § Sixth Amendment, Fourteenth Amendment and Fifth Amendment Rights. And if 1 don't follow their advice, I risk losing their representation, so therefore, I'd going to have to assert those rights, though I prefer to answer the question. BY MR. HOROWITZ: Q_ During Jane Doe 2's visit to your home in 2004, did you unfasten her bra and rub her breasts? MR. PIKE: Form. THE WITNESS: Though I'd like to answer that question -- 1 would like to answer all your questions here today, I'm going to have to respond as I've done to mostly all your other questions here today, Mr. Horowitz, which is on advice of my th ii m y Sixth f 17 (Pages 65 to 68) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 69 Amendment Rights, my Fifth Amendment Rights and m Fourteenth Amendment Rights under the U.S. Constitution. And if] don't do so, and I answer your question, which J weuld like to do, I risk losing their representation, so, therefore, | must just simply assert those rights. THE VIDEOGRAPHER: Three minutes of tape remaining. MR. HOROWITZ: Okay. Thanks. BY MR. HOROWITZ: Q During Jane Doe 2's visit to your home in 2004, did you mb Jane Doe 2's vagina? MR. PIKE? Form. THE WITNESS; I'd like to answer that question, however, today, at least today, my counsel has advised me that I cannot answer any questions that may be relevant to your lawsuits -BY MR. HOROWITZ: During -and Sorry. Excuse me. Go ahead. And, though I would Jike to answer each and every one of your questions, I am going to have to Page 71 THE VIDEOGRAPHER: Time on the record 11:29. This is Tape 2. BY MR. HOROWITZ: Q Sir, during Jane Doe 2's visit to your home in 2004, did you masturbate in front of her? MR. PIKE: Form. : THE WITNESS: Mr. Horowitz, 1 would like to answer every one of your questions here today. 1 specifically would like to answer that question. However, on advice counsel, they've advised me I am going to have to assert my Fifth Amendment, Sixth E Amendment and Fourteenth Rights as provided by the U.S. Constitution. And if] don't follow their advice, I risk losing their representation, so therefore, I am going to have to assert those rights BY MR. HOROWITZ: Q During Jane Doe 2's visit to your home in 2004, did you ejaculate in front of her? MR. PIKE: Form. THE WITNESS: I'd like to answer that question. I'd like to answer most of your other questions here today, but J am going to have to respond, as I've responded to most of your other questions here today, which is my counsel has Page 70 respond as I've responded to most of your other questions here today, Mr. Horowitz, which is ] am going to have to assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment Rights as provided by the U.S. Constitution. I've been advised by counsel that if I don't do so, I risk losing their representation. Though [ would like to answer, I cannot. Q During Jane Doe 2's visit to your home in 2004, did you insert your fingers into Jane Dee 2's vagina? MR. PIKE: Form. THE WITNESS: I would Jike to answer that question. 1 would like to answer all your questions here today. However, on advice of counsel, they've advised me I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendme Rights as provided by the U.S. Constitution. And, though I would like to answer that question, I cannot here today -THE VIDEOGRAPHER: I need to = THE WITNESS: «= sorry -- but. MR. PIKE: If you need to finish, go ahead. THE WITNESS: -- based on my counsel's advice, THE VIDEOGRAPHER: Time off the record 11:59 ~~ T1sf9, reupon, a short break ws Page 72 ; advised me at least today -- excuse me -~- I cannot answer any questions that may be relevant to this lawsuit. And I -- if] do not follow their advice, I risk losing their representation. Therefore, I am going to have to assert those rights and not respond today. BY MR. HOROWITZ: Q During Jane Doe 2's visit to your home in 2004, did you tell her that she had a very hard clit as you were rubbing it? A What? MR. PIKE: Form. BY MR. HOROWITZ: Q Ahard clit. MR. PIKE: Same objection. THE WITNESS: | would like to respond to that question. I would like to answer that question. However, I am going to have to respond, as I've responded to most of your other questions here today, because my -- on advice of my counsel, they've advised me I must assert my Sixth Amendment [; Rights, my Fifth Amendment Rights and my Fourteenthy Amendment rights as provided by the Constitution. E And if 1 don't do so, and 1 answer that question, I ion. So therefore, 18 (Pages 69 to 72) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 73 Page 75 answer, and because -- if | answer, they've advised me I risk losing their representation. BY MR. HOROWITZ: Q You never asked Jane Doe 2 for permission to unfortunately, Mr. Horowitz, though I would like to 1 2 3 4 5 touch her breasts and genitals, correct? 6 7 8 1 2 answer it, I cannot today. 3. BY MR. HOROWITZ: 4 Q Did you have sexual contact with Jane Doe 2 at 5 6 7 8 your Palm Beach home in late 2004? MR, PIKE: Form, predicate, foundation. THE WITNESS; I'd very much like to answer that question, as 1 would like to answer most of your MR. PIKE: Form. THE WITNESS: I would like to answer each one of your questions today, each one. However, on my 9 other questions here today. However, just like 9 advice of my counsel, they've advised me [ cannot 10 T've answered for most of your other questions, on 10 answer any questions that may be relevant to your 1 advice of my counsel today, they've advised me that 1 lawsuit, or her lawsuit, or the lawsuit -- [ guess 12 I must assert my Sixth Amendment, Fifth Amendment! 12 it's the lawsuit brought by the same -~ one of your 13 and Fourteenth Amendment Rights as provided by the} 13 partners originally whose become disbarred. 1 14 U.S Constitution. And, though I would like to 14 would like to answer it; however, I cannot. On the 1s answer it, if 1 do so, I risk losing their 15 advice of counsel, J must assert my Sixth 16 representation; therefore, | must not respond, 16 Amendment, Fourteenth Amendment and Fifth Amend 17 Thank you. 17 Rights as provided by the Constitution, because b 18 BY MR. HOROWITZ: 18 they've advised me that if] answer those i 19 Q During Jane Doe 2's visit to your home in 2004, 19 questions, 1 risk losing their representation. E 20 — did you pay her $200 after you had sexual contact with 20 MR. HOROWITZ: Okay. Move to strike. E 21 her? 21 BY MR. HOROWITZ: a 22 MR. PIKE: Form. 22 Q And isn't it true that Jane Doe 2 indicated to E 23 THE WITNESS: Could you repeat the question for, 23 — you that she did not want you to touch her? E me? A. twould like to answer -- FE BY MR. HOROWITZ: MR, PIKE: Form. : Page 74 Page 76 i 1 Q During Jane Doe 2's visit to your home in 2004, 1 THE WITNESS: Excuse me? ; 2 did you pay her $200 after you had sexual contact with 2 MR, PIKE: Go ahead, a 3 her? 3 THE WITNESS: I'm sorry. } would like to 4 MR, PIKE; Form. 4 answer every one of your questions today, every 5 THE WITNESS: I would like to answer that 5 one. However, on advice of my counsel, I cannot i 6 question -~ is she saying I paid her $200? Is that 6 answer any questions that may be relevant to any of E 7 in the allegation? 7 your lawsuits, And so today, on advice of counsel, ie 8 MR. HOROWITZ: I'm just asking the questions. 8 I must assert my Sixth Amendment, Fifth Amendment I 9 THE WITNESS: I know. I'm asking you to 3 and Fourteenth Amendment Rights as provided by the = B 10 clarify. Is that -- is it -- is it in the -- in 10 Constitution, because if 1 answer these questions, E 11 the complaint? il I risk ~ they tell me, I risk losing their E 12 MR. HOROWITZ: I'm not allowed to answer youg 12 representation. l 13 questions today. 13 BY MR. HOROWITZ: BE 14 THE WITNESS: I'm sorry. 14 Q Allright. tsn't it true that you touched Jane 15 MR. HOROWITZ: I wish } could. 15 Doe 2's breasts and genitals after she indicated she did 16 THE WITNESS: I'm sorry. I wish you could 16 © not want you to touch her? 17 too. I'm sure the jury would like you to answer 17 MR. PIKE: Form. 18 some of my questions, but today, I'll answer that 18 THE WITNESS: I would like to answer that 19 question -- unfortunately, I would like to respond 19 question, as well as each and every question you've 20 to every one of your questions, every single one, 20 asked me here today regarding each and one of your 21 however, today, on advice of counsel, I cannot. 21 lawsuits. However, today, on the advice of 22 counsel, I am going to have fo assert my Sixth And, though I would like to answer each one of your [: Amendment, Fifth Amendment and Fourteenth Amendmeng, questions, on the advice of my counsel, [ am going to have to assert my Sixth Amendment, Fifth Amendment and Fou Amendment Ri; ) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 77 the other questions today, 1 am going to have to assert those rights because I've been advised that not doing so, I might risk losing their counsei. BY MR. HOROWITZ: Q Did you try to persuade Jane Doe 2 that it was okay for to you touch her breasts and genitals? MR. PIKE: Form, THE WITNESS: I'd like to answer every one of your questions here today, every one. However, on advice of counsel, they've advised me that ] cannot answer any questions that may be relevant to any of your lawsuits. Therefore, | am going to have to assert my Sixth Amendment, Fourteenth Amendment ang Fifth Amendment Rights as provided by the Constitution because, though I would like to answer those questions -- that question, as well as all the other questions you've asked me here today, [ cannot do so on advice of counsel. BY MR. HOROWITZ: Q Sir, you don't deny that you sexually abused Jane Doe 2, do you? MR. PIKE: Form. THE WITNESS: | would like to answer that question. I'd really like to answer that question. However, | cannot on advice of counsel, Page 79 Q Put out of your mind anything else you may register, Focus on my question to you, A Lam going to try. Q_ Did you pay Jane Doe 3 for bringing Jane Doe 2 to your home in late 2004? MR. PIKE: Form. THE WITNESS: Did 1 pay Jane Doe 3, Jane Doe 2's friend? Is that — I'm sorry. Is that -BY MR, HOROWITZ: Q Do you know them to be friends? A I'masking you, sorry. Q Imnot allowed -A You're not allowed to testify. You can't testify that they're friends, okay. I'm sorry. I would like to answer those questions, Mr. Horowitz. I'm sure the ladies and gentlemen of the jury ~ these questions ~- these answers are pretty obvious. However, on advice F of counsel, I'm not going to be able to answer those E questions today. And, though I would like to, I'm going E to have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights as provided by the Constitutions because my counsel has told me that if 1 don't do so, I risk losing their -- potentially risk losing their representation. So, though I would like to answer that question, as I understand it, I cannot. Page 78 because they told me that I cannot answer any questions that may be relevant to any of your lawsuits here today. And if] do so, I risk losing. their representation, so, unfortunately, Mr. Horowitz, 1 am going to have to assert those rights. BY MR. HOROWITZ: Q_ Did you pay Jane Doe 3 for bringing Jane Doe 2 to your home in late 20047 MR. PIKE: Form. THE WITNESS: Who? MR. HOROWITZ: Jane Doe 3. I may ask you a fe more questions about her name, so just kind of hold that name in your head. THE WITNESS: So it's now not Jane Doe 2? MR. HOROWITZ: Well -THE WITNESS: Are these two friends? I mean, these are two friends here supposedly? MR. HOROWITZ: I'm not allowed to answer. THE WITNESS: Oh, you can't, sorry. ] guess one friend supposedly brought the other acquaintance -BY MR. HOROWITZ: Q > My question -- my question -Okay. What's your questi UNIVERSAL COURT (954) 712-2600 (877) Page 80 E BY MR. HOROWITZ: Q Okay. Did you instruct $.K. to take Jane Doe 2's name and number for the purpose of calling her to come to your house for more sexual activity? MR. PIKE: Form. f THE WITNESS: I'd like to answer that question, B as I'd like to answer most of your other questions & that you've asked me here today. However, based onk advice of counsel, they've advised me I cannot answer any questions that may become relevant to any of your lawsuits. So, though I would like to E answer the question, Mr. Horowitz, I cannot because f my counsel has advised me that if I do, I risk losing their representation. So, unfortunately, today 1 cannot answer that question. BY MR. HOROWITZ: Q Okay. So you've asserted the Fifth Amendment as to -- privilege as to my questions about Jane Doe 2. fi Is there any reason a jury should not infer from your response that you sexually abused Jane Doe 2? MR. PIKE: Object to the form of that question, and I'm going to instruct him not to answer simply because the way the question is worded, it could get into attomey-client communications and ial product. I' ‘m not quite sure 20 (Pages 77 to 80) REPORTING 291~-DEPO (3376)

Page 81 understand the question. So if you'd rephrase it, possibly, if you can. BY MR. HOROWITZ: Q You've asserted a Fifth Amendment privilege to various questions I've asked you about Jane Doe 2. My question is: Is there any reason in your mind, absent anything you've spoken to with your attorney about, wh the jury should not infer from your assertion of the Fifth Amendment privilege, that you in fact sexually abused Jane Doe 2? MR. PIKE: Form. THE WITNESS: Well, I believe, Mr. Horowitz, the Fifth Amendment is by the Supreme Court's ruling. It's, in fact, used to protect the innocent, as well as certain people that might be not guilty. So in response to that question, with the fact that Jane Doe 2 -- the jury will understand that Jane Doe 2's lawsuit brought by a partner of yours who's been disbarred, constant -after, in fact, he brought the lawsuit, well -- the jury, I have a strange feeling will -- sorry —- the jury, J believe, will understand that my taking the Fifth Amendment is only as a result of my counsel advising me today that I must do so, because if I don't do so, I risk losing their representation, Page representation, BY MR. HOROWITZ: Q Okay. Iam going to be asking you some questions about Jane Doe 3. She's the Plaintiff in -identified as Jane Doe Number 3. | just want you to keep her name in your head so -- for this series of questions, okay? A Yes, Q Shr, isn't it true that a girl named Jane Doe 3 came to your Palm Beach home on multiple occasions in 2004? MR. PIKE: Form. THE WITNESS: I understand that Jane Doe 3 was f) the girl you mentioned before who was friendly with Jane Doe 2. So the two friends, | believe, you're just suggesting -- now, there was a question -- oh, T'm asking you to testify. I'd like to answer the questions about Jane Doe 3. I'd like to answer the questions about your former other client you talked about, Jane Doe 2, the two friends, but I cannot based on my advice of counsel just today at least. Though I would like fo respond in detail, 1 am going to have to assert on their opinion -- their advice, the Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights as provided by the U.S, Page 82 though I'd like to answer each and every one of your questions. BY MR. HOROWITZ: Q In this case are you asserting the Fifth Amendment privilege because you are in fact innocent? MR. PIKE: Form. THE WITNESS: Do you want me to answer that question? MR. PIKE: Form. It's -- it's the same objection. THE WITNESS: | would like to answer that question. As | said before, your partner who's been disbarred after filing this lawsuit, Mt. Edwards who's sitting there whose partner, in fact, is sitting in jail for filing lawsuits of a sexual nature against people like me and others. Though I would like to answer every one of your questions, every single one, my counsel has advised me at least today that any question that may be relevant to this lawsuit, I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendmen; Rights, and, though 1 would like to answer that question, as well as every other question you've asked here today, J am going to have to assert those rights, or lose -- risk losi it Page 84 Constitution. And, though I would like to answer each and every one of your questions, I cannot do so here today. BY MR. HOROWITZ; Q Did you ever instruct a girl named H.R. to bring underage girls to your home for your sexual pleasure? MR. PIKE: Form. THE WITNESS: [4 like to answer each and everyfi one of your questions here today, Mr. Horowitz, regarding these lawsuits that you and your disbarred partner -- your partner who's been disbarred after bringing these lawsuits has brought. However, though Id like to answer that question, as you probably understand, my counsel who has advised me at least today, that I cannot answer any questions that may become relevant or may be relevant to this lawsuit, and they've 3 advised me | must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights asf provided by the U.S. Constitution, or risk losing their representation, so unfortunately, [ must respond that way. to bring you other 21 (Pages 81 to 84) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291~DEPO (3376)

Page 85 underage girls for your sexual pleasure? MR. PIKE: Form. THE WITNESS; Can you give me the question again? I'm sorry. BY MR. HOROWITZ: Q_ HLR., the — in your mind, do you know whe that is? A I'm listening. Q Well, that's my question -- it was a question. A I'm sorry, what was the question? Q_ Do you know who H.R. -- I mean, in your mind, you can picture who that is, right? MR. PIKE: Form, move to strike. THE WITNESS: I'm going up -MR. HOROWITZ: It’s a question. MR. PIKE: What is the question? BY MR. HOROWITZ: Q Do you ~ in your mind, can you picture -- when say “H.R.", do you know who I'm talking about? MR. PIKE: Form. THE WITNESS: I would like to answer each and every one of your questions brought here today under these lawsuits filed by you and your partner that was disbarred, but on advice of counsel here . today, Mr. Horowitz, I'm going to have to assert my Page 87 as before, who's the friend of alf of the girls you keep talking about; is that what you're saying? BY MR, HOROWITZ: Q Is that your testimony? A This is your testimony — {'m sorry -- this is your -- I'm trying to understand the question. Unfortunately, I would like to answer that question. However, on advice of counsel here today, they've informed me that I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendmen| Rights. ‘Though I would like to answer each and every one of your questions, | am going to have to respond to that question the same way I've responded to mostly each one of your other questions here today and refuse to testify. BY MR, HOROWITZ: Q In 2004 did you receive a phone call from H.R. In which she informed you that she was bringing Jane Doe 3 to your home for you to engage in sexual activity? B MR. PIKE: Form. THE WITNESS; Did I receive a call? MR. HOROWITZ: That's my question, THE WITNESS: { would like to answer that question, however, on advice of counsel, I cannot Page 86 Sixth Amendment, Fourteenth Amendment and Fifth Amendment Rights. Though I would like to answer each and every one of your questions, I cannot do so today. BY MR. HOROWITZ: Q_ Did you ever pay H.R. to bring you underage girls for your sexual pleasure? MR. PIKE: Form. THE WITNESS: 1 would like to answer each one of your questions that you've been posing to me today, Unfortunately, my counsel has advised me that today I must assert any of my rights under the Sixth Amendment, Fifth Amendment and Fourteenth Amendment to any questions that may become relevant to this lawsuit brought by you and your firm and your partner who's been disbarred. But I would like to answer that question, However, today f cannot, BY MR. HOROWITZ: Q Between 2000 -- strike that. In 2004 and 2005, did you pay Jane Doe 3 to bring other minor girls to your home for your own sexual gratification? MR. PIKE: Form. Page 88 because they've told me I must assert my Sixth b Amendment, Fourteenth Amendment and Fifth Amendment Rights to any question that may become relevant to E one of your lawsuits. So, though f would like to answer that question, as the other questions you've asked, ] must assert those rights here today. BY MR. HOROWITZ: Q Sir, if you shake your head after J ask a question, should we infer that you're saying "no" to my question? MR. PIKE: Form. [ am going to instruct him not to answer that question. It -- f'm -- I'm not quite sure that you -- what you're trying to do. here is you're asking a -- a question. His -- his answer is his answer, and it's a verbal answer, and you know the rules of deposition where nods of the head, shakes of the head, um-hum and un-huns are not understood by the court reporter. So his answer is his verbal response, and no such gesture should be interpreted in an manner that would benefit your case, Mr, Horowitz, MR. HOROWITZ: Okay. Well, the video will -will -- will be played, and persons who view the video will -- will determine from themselves ~ for mselves ~~ 22 (Pages 85 to 88) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 89 MR. PIKE: Absolutely. MR. HOROWITZ: ~ what to infer from nodding -MR. PIKE: But he's not — ‘THE REPORTER: Wait -MR, HOROWITZ: -- or shaking of the head. MR. PIKE: I'm sorry. Correct, but he's not going to answer that question. MR. HOROWITZ: Okay. BY MR, HOROWITZ: Q Did you instruct $.K. to communicate by telephone with H.R. for the purpose of arranging for underage girls to come to your home to engage in sexual activity? MR. PIKE: Form. THE WITNESS: | would like to answer each and every one of your questions posed today about the various lawsuits brought by you and your disbarred partner -- your partner who was disbarred after they filed these lawsuits. However, on advice of counsel, they've told me I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendmeny Rights as provided by the U.S. Constitution, or if I testify I risk tosing their representation. So, though I would like to answer each one of your questions, Mr, Horowitz, I cannot do so today. they've advised that 1 must assert my Sixth Amendment Rights, my Fourteenth Amendment Rights and my Fifth Amendment rights as provided by the U.S. Constitution. And, though { would like to answer these questions brought by you -- you, your disbarred partner, or Mr. Edwards’ firm whose. partner sits in jail for -~ for what the U.S. Attorney calls a criminal enterprise, I would like nothing more than to answer that question, but today | am going to have to assert those rights. BY MR. HOROWITZ: Q Did you observe S.K. speaking with H.R. by telephone and arranging for Jane Doe 3 to come to your home for a massage? MR. PIKE: Form, predicate, foundation. THE WITNESS: I wil] much -- Pd very much like to answer that question, like most of your other questions here today; however, upon advice of counsel, they've advised me I must assert my Sixth E Amendment, Fifth Amendment and Fourteenth Amendment Rights as provided by the U.S. Constitution. And, : though I would like to answer each and every one of your questions brought by you, your firm, your partner that was disbarred after bringing these claims, Mr. Edwards’ firm that's been accused of Page 90 BY MR, HOROWITZ: Q Did you call -- did you instruct $.K. to call Jane Doe 3 by telephone to arrange for you to get a massage? MR. PIKE: Form. THE WITNESS: Mr. Horowitz, I'd like to answer each and every one of your questions, but | am going to have to respond today like I've responded to most of your other questions asked here today, 1 am going -- by -- on the advice of counsel, | am going to have to assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights no} to answer any questions brought by you, your firm, your partner that was disbarred from the Florida Bar after bringing these lawsuits, and 1 am going to have to refuse to answer that question, I'm sorry. BY MR. HOROWITZ: Q Did you inform S.K. that the massage Jane Doe 3 was to give you would be sexual in nature? MR. PIKE: Form. THE WITNESS: I would like to answer that question, but unfortunately, | am going to have to answer that question as I've answered most of your ‘ice of counsel, creating and fabricating cases of a sexual nature against me and other people, I cannot answer that question today. BY MR, HOROWITZ: Q Did S.K. tell you that she confirmed by telephone that Jane Doe 3 would be coming to your home} at a specific time to give you a massage? MR. PIKE: Form. THE WITNESS: I'd like to answer that question Mr. Horowitz, as I'd like to answer most of your other questions posed here today, but as I've responded to mostly all your questions here today, on advice of counsel, they've advised me I must assert my Sixth Amendment, Fiflh Amendment and Fourteenth Amendment Rights provided by the U.S. Constitution. MR. HOROWITZ: Uh-huh. THE WITNESS: And if I don't do so, I risk losing their representation. And, though your firm and its partner that was disbarred after bringing these cases, Mr. Edwards's firm, his partner sits in the jail accused of -- of the largest fraud in South Florida's history, I would like nothing more than to answer that question, but 1 must follow the advice of counsel, or they've told me I risk losing 23 (Pages 89 to 92) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 93 their representation. BY MR. HOROWITZ: Q_ Since you've mentioned my parmer who you describe as disbarred and you also mentioned Mr. Rothstein's involvement, are you suggesting that Jane Doe 3 fabricated her allegations of abuse after coming into contact with one of these attorneys? A Lwant MR. PIKE: Form. THE WITNESS: | believe the jury will decide that. I believe the jury will decide that Mr. Rothstein, Mr. Edwards’ partner who sits in jail, accused by the U.S. Attorney of the largest fraud in South Florida's history for crafting cases of a sexual nature, crafting, fabricating -- it's not my words -- it's words in the paper -- against people like me and others, to try to get as much money as they could according to the newspapers. I'm sorry, but J would like to answer that question asked to me before, but I cannot under advice of counsel, who've told me I must in response to any questions that may be relevant to your lawsuit, today at least, to assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment Rights under the U.S. Constitution, May I take a break or Page 95 would like to answer every one of your questions; & however, my counsel has told me I cannot today, so 1 must assert those rights, or risk losing their representation. BY MR. HOROWITZ: Q_ Sir, are you testifying that my partner was sued by a -- a former client? A I don't remember -- { don't recall ~ I believe the -- $.G.'s parents, who the first was initially —this is according to the newspapers -- your ~ Mr. Herman's clients, | believe. The other ~ the parent-the person who he represented said that in fact he neverF represented her, but I don't have the full details. E BY MR. HOROWITZ: Q But are you - are you suggesting that he was sued by her -- by a former client? A Idid not. Q Pardon me? A No, I did not. Q Okay. During the course of Jane Doe 3's first visit to your home, did you in fact persuade, induce or entice her to engage in sexual activity with you? A J just answered that question, didn't I? MR. PIKE: Form. THE WITNESS: Wasn't that the question I just Page 94 a rest? MR. HOROWITZ: Yes. THE WITNESS: Okay. Thank you. THE VIDEOGRAPHER: Time off the record 11:52. (Thereupon, a short break was taken.) ‘THE VIDEOGRAPHER: Time on the record 12:00. BY MR. HOROWITZ: Q Sir, we have been discussing Jane Doe 3. Was it your intent during the course of Jane Doe 3's first visit to your home that you would persuade, induce or entice her te engage in sexual activity? MR. PIKE: Form. THE WITNESS: I'd like to answer that question, as I'd like to answer every one of your questions here today, Mr. Horowitz; however, on advice of counsel, I've been informed I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendmen} Rights as provided by the U.S. Constitution. And, though I'd like to answer the questions provide -asked by you, unfortunately, your ~ the person who: filed the Lawsuits on your firm's behalf, your partner, Jefftey Herman, who's been disbarred after they filed this lawsuit, sued by one of your other clients -- one of the girls’ parents because he brought a lawsuit -- some ~ some crazines: Page 965 answered? BY MR. HOROWITZ: Q No, My earlier question was: Was it your intent to engage in sexual activity. My question now, it's a very specific one — A Okay. Q_ -- during the course of Jane Doe 3's first visit to your home, did you in fact persuade, induce or entice her to engage in sexual activity? A_ I'd like to answer that question. I'd like to answer every one of your questions here today, Mr. Horowitz, and | think the answer is pretty obvious, however, I cannot, because under advice of counsel, they've advised me I must assert Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights as provided b the Constitution. And if [ choose to answer, I risk 4 Josing that representation no matter how much I'd like to answer that question. Q Atno time did Jane Doe 3 tell you that she was 18 or older, correct? MR. PIKE: Form. THE WITNESS: Id like to answer every one of your questions. I'd like to answer that question specifically. However, sitting here today, I've ised by my counsel that I cannot answer any 24 (Pages 93 to 96) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 97 Page 99k questions that may be relevant to your -- one of 1 was disbarred? |: your lawsuits. And, though it was brought, I 2 MR. PIKE: Form. E believe, your partner that was later disbarred and 3 THE WITNESS: | would let the jury decide that had some association with Mr. Bdwards who's sitting 4 fact. My suggestions -- I'd like to answer every [ there with his partner who sits in jail accused of § one of your questions here today. I'd like to i one of the largest frauds in South Florida's 6 respond regarding the -- her attorney that was. ; history. The U.S. Attorney accused his firm while 7 disbarred. I'd like to answer questions with E he's sitting there accused of being a criminal 8 respect to Mr. Edwards’ partner who sits in jail E enterprise, I'd like to answer each one of your 9 for crafting cases of a sexual nature, making le questions; however, my counsel has advised me today! 10 allegations against people like me and others; F that I must assert my Sixth Amendment, Fourteenth 11 however today, on advice of counsel, Mr. Horowitz, i Amendment and Fifth Amendment Rights, so 12 I am going to have to assert my -- under -- under E unfortunately, I cannot. 13 advice of counsel, I am going to have assert my BY MR. HOROWITZ: 14 Sixth Amendment, Fourteenth Amendment and Fifth Q Okay. In your own mind, when Jane Doe 3 was af! 15 Amendment Rights, and I'm told that if I choose to & your home, you didn't believe that she was 18 or older, 16 auswer that question, J risk losing their did you? 17 representation, so unfortunately, | cannot answer MR. PIKE: Form. 18 that today. B THE WITNESS: I'd like to answer each one of 19 BY MR. HOROWITZ: E your questions, Mr. Horowitz, here today, but 20 Q Is it your contention today that Scott E unfortunately I'm going to have to respond to that 21 Rothstein fabricated Jane Doe 3's lawsuit? E question, as I've responded to most of your other 22 MR. PIKE: Form. f questions here today, which is that at least for 23 MR. HOROWITZ: I would like to answer that ; today, my counsel has advised me that 1 cannot 24 question, 1 would like to answer -- I believe your answer any questions that may be relevant to any 25 partner, Mr. Herman, was disbarred after filing the F Page 98 Page 100 one of your lawsuits brought by your firm and your 1 lawsuit. I'd like to answer every one of your partner whose -- who was disbarred after they 2 questions here today; however, on advice of my brought these lawsuits, or the questions Mr. 3 counsel, I'm told that { must assert my Sixth 3 Edwards might pose via his parmer sitting in jail, a Amendment, Fourteenth Amendment and Fifth Amendmenk, or a new jail according to the newspapers, accused 5 Rights, and if 1 choose to answer that question, 1 i of the largest fraud in South Florida's history for 6 risk losing their representation. So, though I } orafling cases of sexual nature against people like 7 would like to answer that question, as you probably E me and others. So, though I'd like to answer that 8 understand, I cannot do so today. le question, as your other questions, unfortunately, I 9 BY MR. HOROWITZ: am going to have to assert my Fifth Amendment, 10 Q When Jane Doe 3 was at your home, she told you Sixth Amendment and Fourteenth Amendment Rights ag 11 — she attended Royal Palm Beach High School, didn't she? provided by the U.S. Constitution. 12 MR. PIKE: Form. BY MR, HOROWITZ: 13 THE WITNESS: f'd like to answer every one of Q Do you base your assertion of the Fifth 14 your questions here today, Mr. -- Horowitz, right, Amendment privilege on the fact that Jane Doe 3's 18 Horowitz? attorney was supposedly disbarred? 16 MR. HOROWITZ: (Nods head). E THE REPORTER: "Jane Doe 3's attorney was" ~ 17 THE WITNESS: However, on advice of counsel, I R MR. HOROWITZ: “Supposedly disbarred." 18 cannot answer those questions. They've asked me to MR. PIKE: [ am going to object. That could 19 assert my Sixth Amendment, Fourteenth Amendment and get into attorney-client work product information. 20 Fifth Amendment Rights. And if I choose to answer, Tam going to instruct him not to answer that 21 I risk losing their representation. Though your question, Mr, Horowitz. 22 partner after filing this lawsuit was disbarred e BY MR. HOROWITZ: 23 from the Florida Bar, the -- your -- the man. Q Are you -- are you suggesting that Jane Doe 3 24 sitting to your right, his partner sits in jail is lying because, in your min an attorney who used of the Jargest fraud in South Florida's ET 25 (Pages 37 to 100) UNIVERSAL COURT REPORTING {954) 712-2600 {877) 291-DEPO (3376)

Page 101 history for crafting ~ MR. HOROWITZ: Ub-huh, THE WITNESS: -- cases of a sexual nature against me and people like me. I would like to answer those questions, but unfortunately today, 1 cannot do so. BY MR. HOROWITZ: Q > You were nude in front of Jane Doe 3 in 2004, ‘weren't you? MR. PIKE: Form. MR. HOROWITZ: Td like to answer each and every one of your questions here today, Mr. Horowitz; however, on the advice of my counsel, I cannot. They've advised me I must assert my Sixth Amendment Rights, Sixth Amendment, Fourteenth Amendment and Fifth Amendment Rights, so that to] any question that might be relevant to any of your lawsuits crafted by your partner, who I believe has been disbarred since filing the lawsuits, and Mr, Edwards sitting there with his partner, Mr. Rothstein, who's currently sitting in jai! for crafting cases of a sexual nature against people like me and othets, I'd like to answer each and every one of your questions; however today, my -on advice of counsel, I cannot do so. BY MR. HOROWITZ: Q_ In.2004 did you instruct Jane Doe 3 to pinch your nipples and rub your chest? MR. PIKE: Form. THE WITNESS; I'd like to answer that question. I'd like to answer that question very much, However, on advice of counsel, they've instructed me that I cannot answer any questions today that may be relevant to any of your lawsuits filed by you, your partner, Jeffrey Herman, that was disbarred by the Florida Bar Association after filing these lawsuits, questions posed by Mr. Edwards and his firm whose partner sits in jail accused by the U.S. Attomey of perpetrating the largest fraud in U.S. history by fabricating -totally fabricating cases against people like me and others. Though I would like to answer those questions, I am going to have to assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendmen| Rights as advice of -- upon advice of counsel, BY MR. HOROWITZ: Q In 2004 did you ask Jane Doe 3 questions about her sexua] experience and preferences? MR. PIKE: Form. THE WITNESS: I'd tike to answer that Page 102 BY MR. HOROWITZ: Q In2004 did you instruct Jane Doe 3 to remove her clothing? MR. PIKE: Form. MR. HOROWITZ: Can you repeat the question? BY MR. HOROWITZ: Q Remember we -- we have been talking about Jane Doe 3. A I'mdoing my best. Q In 2004 did you instruct Jane Doe 3 to remove her clothing? MR. PIKE: Form. THE WITNESS: | would like to answer that question. I would like to answer each and every one of your other questions here today. However, upon advice of my counsel, they've advised me I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment Rights. So, thoug! T'd like to answer these questions posed by you -your partner who's been disbarred, Mr. Edwards’ partner who sits in jail for crafting lawsuits of a sexual nature against people like me and others ~ so, though | would like to answer those questions with great specificity, 1 cannot under the advice of counsel, so there! question. I'd like to answer every question you've asked here today. However, upon advice of counsel, they've advised me I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendmet Rights -~ so that cases brought by attorneys like you and your partner, Jeffrey Herman, who held a press conference on the streets outside Palm Beach, he was brought -- then later disbarred by the Florida Bar Association -- I'd like to answer every one of your questions. However, today, on advice of counsel, I cannot. BY MR. HOROWITZ: Q_ In 2004 did you touch Jane Doe 3's breasts for your own sexual gratification? MR. PIKE: Form. THE WITNESS: I'd like to answer each and every one of your questions posed today, Mr. Horowitz. However, at least today upon advice of counsel, I - [cannot answer those questions, and 1 ~ and J must assert, on advice of my counsel, my Sixth E Amendment, Fifth Amendment and Fourteenth Amendment, Rights under the U.S. Constitution. And though bi this lawsuit brought by you and your partner who's been disbarred by the Florida Bar Association after bringing thi it, sitting next to Mr. Edwards 26 (Pages 101 to 104) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376}

Page 105 whose partner sits in jail for bringing cases of a sexual nature, fabricated cases of a sexual nature, and fleecing investors out of millions of dollars in South Florida, I'd like to answer each and every one of your questions. However today, | cannot do so upon advice of counsel. BY MR, HOROWITZ: Q_ In 2004 did you touch Jane Doe 3's buttocks for| your own sexual gratification? MR. PIKE: Form. THE WITNESS: 1'¢ like to answer that question. I'd very much like to answer that question, like all the other questions you've asked here today, questions posed by your firm, your partner, Jeffrey Herman, whose been disbarred by the Florida Bar Association after bringing this case, Mr. Edwasds' partner, Scott Rothstein, whose purpose was -- according to the U.S. Attorney, ran with Mr. Edwards and part of the firm, the largest fraud -- one of the largest frauds in South Florida's history for fabricating cases, misleading investors, fleecing unsuspecting investors out of tnillions of dollars by fabricating cases of a sexual nature against people like me and others. However, my counsel today has advised me that I Page 107} li Q {n 2004 did you try to insert your fingers into Jane Doe 3's vagina? MR. PIKE: Form. THE WITNESS: I'd like to answer that question. I'd like to answer every one of your questions here today; however, my counsel has advised me that I cannot answer any questions that may be relevant to any of your lawsuits brought by you and your disbarred partner, Jeffrey Herman, or the questions by Mr. Edwards’ partner, Scott -- his firm, Scott Rothstein's firm, who -- Scott Rothstein sits in jail for fabricating cases of a sexual nature -- excuse me —MR. HOROWITZ: Continue. THE WITNESS: So, though I'd like to answer that question, as I'd like to answer each and every one of your questions today, I cannot do so on ~~ upon advice of counsel. BY MR. HOROWITZ: E Q In 2004 did you masturbate in front of Jane Doe 3? MR. PIKE: Form. : THE WITNESS: I'd like to answer each and every} one of your questions, especially that one today; however, my counsel has advised me that I must Page i06 cannot answer those questions -- any questions that may be relevant to any of your lawsuits. So, though I would like to answer that question today, Lam going to have to rely on my counsel's advice. BY MR. HOROWITZ: Q In 2004 did you rub Jane Doe 3's vagina? MR. PIKE: Form. THE WITNESS: Excuse me. I'd like to answer that question, as 1 would like to answer mostly every question you've asked me here today; however, upon advice of counsel, I cannot answer that question. They've advised me I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights against self -- excuse me, against -- under the U.S. Constitution. And though your partner, Jeffrey Herman, was disbarred after filing this lawsuit, Mr. Edwards' partner sits in jail for fabricating cases of a sexual nature, fleecing unsuspecting Florida investors and others out of millions of dollars for cases of a sexual nature with -- I'd like to answer your questions; however, if] ~ I'm told that if I do so, I risk losing my counsel's representation; therefore, | must accept their advise. BY MR. HOROWITZ: Page 108F assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment Rights, not to answer that question. I'd like to answer it, though your pattner who brought this lawsuit has been disbarred after bringing the lawsuit. Mr. Edwards' partner who sits next to you, his partner sits in jail for fabricating cases of a sexual nature against people like me, fleecing people out of millions of dollars because this is about -- about -» of money. Just a money, money case. I'd like to answer those questions, Mr, Horowitz. However, my counsel today has said, I cannot answer any questions today that may be relevant to this lawsuit, and I must accept their advice, or risk losing their representation. BY MR. HOROWITZ: Q In 2004 did you ejaculate in front of Jane Doe 3? MR. PIKE: Form. THE WITNESS: I'd like to answer that question. However, today my counsel has advised me that [ cannot answer any questions that may be relevant to your lawsuits, and I'm going to have to answer that question as I've answered most of your other questions here today. This is no different than the other questions re had to answer where. re my. 27 (Pages 105 to 108) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 109} counsel has advised me that | have to take these rights, but I prefer to answer, but if] do so, J risk losing their representation, And, thoy, posed by you and your partner, Jeffrey Her: was disbarred after filing these lawsuits, sitting next to Mr. Edwards, whose partner sits in jail accused of the largest -- perpetrating the largest -- one of the largest frauds in South Florida's history, accused by the U.S, Attorney of being a -his firm of being a criminat enterprise, I'd like to answer each and every one of your questions; however, today under the advice of counsel, I cannot. BY MR. HOROWITZ: Q Did you have sexual contact with Jane Doe 3 during a massage in 2004? MR. PIKE: Form. THE WITNESS: I'd like to answer that question, as I'd like to answer each and every one of your other questions here today. However, upon the advice of counsel, I cannot, And they've asked me that -- they've required me to assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendmen Rights as provided by the U.S. Constitution. ‘Though your firm's partner sits disbarred -fabricating and falsely creating cases of a sexual nature against people like me and others in order to simply gain money. So, though I'd like to answer your questions, Mr. Horowitz, I am going to have to answer this question, as I've answered most of your questions here today, which is on the advice of counsel I cannot answer. BY MR. HOROWITZ: Q You never asked Jane Doe 3 for permission to touch her breasts and genitals, did you? MR. PIKE: Form, asked and answered. THE WITNESS: I'd like to answer that question, as | would like to answer most of your other questions here today. However, upon advice of my counsel -- excuse me — they've instructed me that I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment Rights of -- provided! by the U.S. Constitution. And, though you, your partner, Jeffrey Herman -- excuse me -- whe was disbarred by the Florida Bar Association after filing this case and your other cases, or Mr. Edwards’ partner who sits in jail — sits in jail, accused of perpetrating one of the largest frauds in Florida's history by maliciously fabricating cases of a sexual nature against me and other Page 110 Jeffrey Herman is disbarred after he brought this case, Mr. Edwards' partner sits in jail accused by the 1 Attorney of perpetrating the largest fraud in US. or south Florida's history for fabricating cases of a sexually charged nature against me and people like me. So, though I would like to answer your questions with specificity, Mr. Horowitz, I cannot do so here today upon advice of counsel. BY MR. HOROWITZ: Q During her first visit in 2004 to your home, did you pay $200 to Jane Doe 3 after you had sexual contact with her? MR. PIKE: Form. THE WITNESS: I'd like to answer that question. I'd really like to answer that question. I cannot do so, however, because my counsel has told me that I cannot answer any questions relevant -- that may be relevant to any of your lawsuits filed by you and your partner, Jeffrey Herman, who was disbarred -- disbarred by the Florida Bar Association after filing these lawsuits, or Mr. Edwards’ partner who sits in jail accused of perpetrating one of the largest frauds people like me. So as you might imagine, | would like to answer these questions, but like the other questions I've asked -- I've answered here today, I am going to have to accept my attorney's counsel or risk losing their representation. BY MR. HOROWITZ: Q In fact, sir, Jane Doe 3 indicated to you that she did not want you to touch her breasts; isn't that correct? MR. PIKE: Form. THE WITNESS: I'd like to answer all your questions here today, Mr. Horowitz. I would really like to answer that question specifically. However, as I sit here today, my counsel has advised me that I must assert ny Sixth Amendment Rights, my Fourteenth Amendment Rights and my Fit Amendment Rights as provided by the U.S. Constitution. So, though you and your partner, Jeffrey Herman, who filed this Jawsuit, held a press conference in Palm Beach months before he became disbarred -- disbarred -- he's no longer an attorney is my understanding now, but he was disbarred by the Florida -~ the Florida Bar UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376) 28 (Pages 109 to 112)

Page 113 money from Florida investors, from Florida people, I'd like to answer each and every one of your questions, Mr. Horowitz, but today, on advice of counsel, I cannot. BY MR. HOROWITZ: Q_ Sir, you touched Jane Doe 3's breasts, buttocks and genitals while she was still a minor after she told you she did not want you to touch her; isn't that right? MR. PIKE: Form, asked and answered. THE WITNESS: I'd like to answer each and every one of your questions today, Mr. Horowitz, however, upon advice of my counsel } cannot. They've asked me -- they've required me fo assert my Sixth Amendment, Fourteenth Amendment and Fifll Amendment Rights as provided by the U.S. Constitution to any questions that may be relevant, or may become relevant to this lawsuit, So, though your partner was disbarred after you filed this claim, or your firm filed this claim, Mr. Edwards who sits next to you, his partner sits in jail, so Fd like to answer each one of these questions. However, today, on the advice of counsel, I cannot. BY MR. HOROWITZ: Q Did you try to persuade Jane Doe 3 that it was okay for you to touch her breasts and genitals? Page 115 q like in response to most of your other questions here today, I cannot. On the advice of counsel, they've told me I must accept their advice or risk josing their representation. They've advised me that [ must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights. So, though your partner, Jeffrey Herman, was disbarred after filing these cases, disbarred, no longer an attorney, Mr. Edwards' partner who sits to your right, his partner sits in, I believe, Saint Lucie Jail according to today -- today's newspaper, accused of perpetrating the largest fraud in South Florida history against people like me, crafting, fabricating, malicious sexually charged —~ cases of a sexually charged nature in order to fleece investors, I would like to answer that question. However today, I must accept my client's + attorney's advice. BY MR. HOROWITZ: Q Mr. Epstein, did you instruct S.K. to take Jane Doe 3's name and telephone number for the purpose of calling her home -- strike that. Did you instruct S.K. to take Jane Doe 3's name and telephone number for the purpose of calling Jane Doe 3 to come to your home for sexual activity? Page 114 MR. PIKE: Form. THE WITNESS: I would like to answer each and every one of your questions here today, Mr. Horowitz, however, upon advice of counsel, I’m -» they've required me to assert my Fourteenth Amendment, Sixth Amendment and Fifth Amendmen’ Rights as provided by the U.S. Constitution. So, although I would like to answer that question, and respond to questions posed by you, for, I guess, your partner, Mr. Herman, who has been disbarred by the Florida Bar Association after filing these cases, disbarred, or Mr. Edwards' partner who sits next to you, has filed other cases where his partner sits in jail for fabricating cases, trying to get money from Florida investors, I'd like to answer each one of your questions here today Mr. Horowitz, but upon advice of counsel, they've advised me that if I do so, I risk losing their representation, so | must accept their advice. BY MR. HOROWITZ: Q Mr. Epstein, you don't deny that you sexually abused Jane Doe 3 when she was a child, do you? MR. PIKE: Form. THE WITNESS: I would like to answer every ont sof, ur g juestions here today, Mr. Horowitz, but Page 116 MR. PIKE: Form, asked and answered. THE WITNESS: I would like to answer every one of your questions, Mr. Horowitz, posed here today. Unfortunately, | guess, your -- your other partner who filed these lawsuits has been disbarred in the interim by the Florida Bar Association, so he's not here today. However, I'd like to answer those questions, but my counsel has told me that I have L to assert my Sixth Amendment, Fifth Amendment and [2 Fourteenth Amendment Rights as provided by the U.S. constitution. So, though I would like to answer your questions, Mr. Edwards' questions whose partner sits in jail for perpetrating one of the largest frauds in South Florida's history, accused by the U.S. Attorney -- his firm accused by the U.S. Attorney is now -- the firm is bankrupt by perpetrating the -~ one of the largest frauds in South Florida's history and being called a criminal enterprise by the current South Florida's U.S, Attorney, I would like to answer every one of your question, very much so, however, my -- on advice of counsel, I cannot do so here today. BY MR. HOROWITZ: Q Sir, is there any reason in your mind that a j hould not infer i e Fifth 29 (Pages 113 to 116) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 117 Amendment privilege, that you sexually abused Jane Doe 31 when she was a child? 2 MR. PIKE: Form, speculation, calls for a egal 3 conclusion. 4 THE WITNESS: The Supreme Court has said that i} the Fifth Amendment should be used by people who 6 are innocent, Mr. Horowitz. That's one of the 7 benefits of the Fifth Amendment. My counsel has 8 advised me ] cannot answer your questions here 9 today, though I'd like to. I'm sure this -- these 10 sort of embarrassing questions posed for the jury 12 where your partner has been disbarred since filing 12 this claim, or Mr. Edwards’ partner who sits in 13 jail probably for the rest of his life for crafting 14 cases of a sexual nature to fleece people for -- of 15 money, just money, money, money. His firm is 16 bankrupt. So, yes, I'd like to answer these 17 questions, and all your questions here today, but 18 unfortunately, on advice of counsel, | cannot. 19 BY MR. HOROWITZ: 20 Q_ Sir, are you asserting your Fifth, Sixth and 21 Fourteenth Amendment privileges because you're 22 innocent? 1s that what you're telling us? 23 MR. PIKE: Form. THE WITNESS: [ would like to answer every one Page 118 of your questions posed by you, your partner, Mr. 4 Herman, who's been disbarred by the Florida Bar 2 after filing this claim, Mr. Edwards’ partner who 3 sits in jail, his firm accused by the U.S. Attorney 4 — accused by the U.S. Attorney of being a criminal 3 enterprise, for fleecing South Florida investors 6 out of millions of dollars by crafting, malicious, iF fabricated cases of a sexual nature against people 8 -- other people -- me and others, I would like to 9 answer each and every one of your questions. 10 However today, on advice of counsel, } cannot 11 answer any of your questions that may be relevant 12 to this lawsuit. 13 BY MR. HOROWITZ: 14 Q_ Sir, you know | also represent Jane Doe Number} 15 4, do you understand that? 16 MR. PIKE: Form. a7 THE WITNESS: Yes. 18 BY MR. HOROWITZ: 19 Q Okay. Isn't it true, sir, that a girl named 20 Jane Doe 4 came to your Palm Beach home on multiplg 21 occasions between 2003 and 2005? 22 A_ Could we take a break? Is that it? 23 Q I would like you to answer that question. __d like to answer that question. I'd Page 119 like to answer every question you've posed here today about you -- about these girls you say came to my house. However, on advice of counsel, I cannot answer that question today. I have to assert, on the ailvice ~ my Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights, Td like to answer that question about Jane Doe 4, and I believe she was represented by your partner, Jeffrey Herman, who after representing her was disbarred by the Florida Bar Association. Mr. Rothstein -- or Mr. Edwards! partner, Mr, Rothstein, who sits in jail accused by the Florida U.S. Attomey of running a criminal enterprise in Mr. Edwards' firm, fabricating malicious cases to fleece investors out of millions of dollars, fabricating cases [ of a sexual nature, I would like to answer every one of your questions here today. However, on advice of counsel, I cannot do so. B MR. HOROWITZ: Did you want that break now? [ THE WITNESS: Yes, please. MR. PIKE: No, actually before we take a break -MR. HOROWITZ: Okay. MR. PIKE: -- my understanding was, is that you wanted to take a break around 12:30 or 12:45 for Page 120 Junch. It is 12:35 right now. If you want to keep going for another 10 minutes, we'll go for another 10 minutes, or if you want to just break now for 30 minutes, go grab something to eat, and then come back, MR. HOROWITZ: Yeah. I mean, this line of questioning is going to be more than 10 minutes, so 1 would suggest we take our break now. MR. PIKE: You want to take lunch right now? MR. HOROWITZ: Yeah. MR. PIKE: Okay. THE WITNESS: All right. Thank you. THE VIDEOGRAPHER: Time off the record 12:30 (Thereupon, a funch break was taken.) JHE VIDEOGRAPHER: Time on the record 1:11. This is Tape 3. BY MR. HOROWITZ: Q > Mr. Epstein, did you pay H.R. $200 to bring a girl named Jane Doe 4 to your home so that you could engage Jane Doe 4 in sexual activity? MR. PIKE: Form. THE WITNESS: Mr. Horowitz, I'd like to answer that. Lam going to have to answer that question, as I've answered most of your questions here today, which is upon advice of counsel, I am going to have 30 (Pages 117 to 120) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO {3376)

Page 121 fo assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment Right, though I'd like to answer that question. Td also like to correct some of the ~ a. previous statement I made regarding your partner that he had been disbarred. { understand he wasn't disbarred, but he was simply suspended for improper behavior, suspended by the Florida Bar. So I would like to make the correction that he's not totally disbarred, but he’s no longer practicing for the time being, So -- but on advice of counsel, at least with respect to this question, or any question that may be relevant to this lawsuit, my counsel has told me I must assert those rights. BY MR. HOROWITZ: Q Okay. And if I'm hearing you correct, your testimony that Mr. Herman was disbarred is -- was erroneous; is that right? MR. PIKE: Form, THE WITNESS: My testimony that your partner who filed these lawsuits was disbarred seems to be incorrect. He was -- according to what I was told, he has only been disbarred for his greatly improper behavior, but -- and so he ~ one day he will, in fact, be practicing law again in South Florida ~ Page 123, Q Mr. Epstein, at any time before May 2005, did you receive a phone call from H.R. that she was bringin; Jane Doe 4 to your home so that Jane Doe 4 could give you a massage? MR. PIKE: Form. THE WITNESS: I'd like to answer that question, but unfortunately, I am going to have to answer that question as I've answered most of your questions here today, Mr. Horowitz, which is upon advice of counsel, they've told me I cannot answer your questions no matter how much I want to, They told me I have to assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights. Though you're currently suspended -- | keep saying "disbarred," but I'm not a lawyer, so I don't really understand the difference between disbarred and suspended ~ he seems to be only suspended by the Florida Bar, } -- I cannot answer that question today upon advice of counsel. BY MR. HOROWITZ: Q Okay. Sir, at any time before May 2005, did you instruct S.K. to place a telephone call to H.R., so that H.R. could arrange for Jane Doe 4 to come to your home for sexual activity with you? MR. PIKE: Form. Page 122 MR. HOROWITZ: Okay. THE WITNESS: -- unlike Mr. Edwards’ parmer who currently sits in jail for perpetrating one of the largest frauds in South Florida's history. BY MR. HOROWITZ: Q Okay. I'm glad we got that squared away. Did you pay Jane Doe 4 to bring other minor girls to your home for your own sexual gratification? MR. PIKE: Form. THE WITNESS: That question | believe would is -- is -- [ would like to answer that question. Unfortunately, my counsel has advised me that I cannot answer any questions today that may become relevant to any of your lawsuits filed by you and your currently suspended partner, suspended by the Florida Bar, or answer questions relevant to Mr. Edwards who is sitting on your right, his firm's partner who's sitting in jail for fabricating cases of a sexual nature against people like me and others. I'd like to answer -- as you might imagine, I'd like to answer these questions, but I risk losing my counsel if you do so, so | must accept their advice today. BY MR. HOROWITZ: Page 1245 THE WITNESS: I'd like to answer that question. I'd like to answer every specific -- E every question you've asked me here today, but lam ff going to have to respond as I've done with most of £ your questions here today, Mr. Horowitz, which is that upon advice of counsel, J am going to have to assert my Sixth Amendment Rights, my Fourteenth Amendment Rights and my Fifth Amendment RightsE Though I'd like to answer the question, though I'm sure the jury will understand your partner has been suspended from practicing law in the State of Florida, Mr. Edwards’ partmer is in jail for fabricating cases of a sexual nature, so, though Td like to answer that question as your other questions today with specificity, my counsel has advised me that if T do so, | risk losing their representation, so { must decline to answer. BY MR. HOROWITZ: f Q_ Did you inform S.K. that the massage Jane Doe 4 was to give you would be sexual in nature? E MR. PIKE: Form. j THE WITNESS: I'd like to answer that question, E just like I'd like to answer each and every one of your questions here today, Mr. Horowitz. E Unfortunately, my counsel has advised me I cannot 31 (Pages 121 to 124) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 125 answer any questions that may become relevant to 1 this lawsuit, or any of the lawsuits filed by you, 2 or your partner that's been suspended by the 3 Florida Bar from practicing law in the State of 4 Florida after he’s had conferences, held public 5 conferences accusing me of things, of Mr. Edwards! 6 partner who sits in jail probably for the rest of 7 his life for fabricating cases against people like 8 me and others. So, though I'd like to answer that 9 question, I'm going to have to answer that question 10 as I've answered most of your questions here today, LL which is upon advice of counsel, 1 must refrain 12 from answering. 13 BY MR. HOROWITZ: 14 Q Did you either observe or overhear S.K. 15 speaking with H.R. making arrangements for Jane Doe 4 tq 16 come to your home for sexual activity? LY: MR, PIKE: Form. 18 THE WITNESS: I'd like to answer that 19 question, I'd really like to answer that 20 question. However, today, my counsel has advised 24 me that J cannot. And they've advised me I must 22 assert my rights under the Sixth Amendment, 23 Fourteenth Amendment and Fifth Amendment of the U.S. constitution. So, though I'd like to answer Page 127 Rights. So, though I'd would like to answer questions posed by you, your partner who has been suspended by the Florida Bar, Mr. Edwards' partner, Scott Rothstein, that many people have read about, has perpetrated the largest fraud in Florida history, specifically for fabricating such cases of @ sexual nature, fabricating malicious cases in order to get money, money, money from people here in South Florida. !'d like to answer each and every one of your questions, however, upon advice of my counsel, they've advised me today 1 cannot do $0. BY MR. HOROWITZ; Q Prior to May 2005 did you ever observe $.K. speaking with Jane Doe 4 by telephone to arrange for Jane Doe 4 to come to your home so that Jane Doe 4 cor give you a massage? E THE WITNESS: May I -- excuse me, may I have a moment with my attorney? MR, HOROWITZ: Yes, E THE VIDEOGRAPHER: Time off the record 1:20. B (Thereupon, a short break was taken.) [: THE VIDEOGRAPHER: Time on the record 1:23. BY MR. HOROWITZ: Q Mr. Epstein, you had a moment to speak with Page 126 questions posed by you, your partner that's been 1 suspended by the Florida Bar after filing these 2 types of cases, cases against me, Mr, Edwards who 3 sits next to you, his partner in jail for filing 4 cases, fabricating cases of a sexually charged 3 nature against me and others. The U.S. Attorney 6 has accused his firm, his former firm, the firm he 7 left now because the finn went bankrupt, for being 8 acriminal enterprise, perpetrated one of the 9 largest frauds in South Florida's history, fleecing 10 investors out of millions and millions of dollars. 11 Td like to answer each and every one of your 12 questions, but my counsel has advised me today that 13 T cannot. 14 BY MR. HOROWITZ: 45 Q Prior to May 2005 didn't you instruct Jane Doe 16 4 to place phone calls to you on your home phone in ly order to schedule visits to your home? 18 MR. PIKE: Form. 19 THE WITNESS: I'd Jike to answer each one of 20 your questions here today, Mr. Horowitz, that 21 question specifically. However, my counsel has 22 advised me that today I cannot, and he advised me 1 23 must assert my Sixth Amendment Rights, my 24 25 Page 1285 counsel. Do you need me to repeat that question to refresh your recollection? A Yes, please, Q Prior to May 2005 did you ever observe S.K. speaking with Jane Doe 4 by telephone to arrange for Jane Doe 4 to come to your home to give you a massage? A I would like to answer that question ~ [ assume this is the Jane Doe 4 who in her testimony wrote a note to me that said "for a good time, call Jane Doe 4." | assume that's the same Jane Doe 4. Unfortunately, I'd like to answer all your questions with specificity today, Mr. Horowitz. However, on advice of counsel, J cannot, Q "Good time" ~A Excuse me? Q Continue, please. A So, therefore, the -- and L represent ~~ I understand you represent Jane Doe 4, 1 understand your partner that's been suspended by the Florida Bar who represented Jane Doe 4 in this case -- I'd like to answer each one of your questions with respect to Jane Doe 4. However, I cannot based on advice of counsel, and I must assert at their request my Sixth Amendment, | Fifth Amendment and Fourteenth Amendment Rights undef Fourteenth Amendment Rights and my Fifth Amendmer UNIVERSAL COURT (954) 712-2600 (877) TS TAS the U.S. Constitution. 32 TOT TTT mone (Pages 125 to 128) REPORTING 291-DEPO (3376)

Page 129 1 Q > When is it that you believe Jane Doe 4 wrote 1 2 you the message you just referred to? 2 3 MR. PIKE: Form. 3 4 THE WITNESS: You know, I'd like to answer ally 4 5 those questions with respect to the note that she 5 6 testified to that she wrote saying "for a good time 6 7 call Jane Doe 4." However, on advice of counsel, I 7 8 cannot answer any questions that may be relevant to 8 9 this lawsuit. !'d like to answer each one of your 3 10 questions, but as I've done with most of your other 10 1. questions here today, or those to be posed by 11 12 Mr. Edwards whose partner sits in jail probably for | 12 13 the rest of his life to try to get money from 13 14 residents of South Florida, and the biggest fraud 14 1s in South Florida's history, called by the U.S. 15 16 attorney a criminal -- the firm is called a 16 17 criminal enterprise, and I'd like -- so I'd surely 17 18 like to answer your question, Mr. Horowitz, 18 419 regarding Jane Doe 4, and -- however, on advice of | 19 20 counsel at least today, I cannot. 20 21 BY MR. HOROWITZ: 21 22 Q Sir, you said that Jane Doe 4 testified that 22 23 — she had written a note to you. Is -- was that truthful 23 24 testimony? You acknowledge that she did write such a note? Page 131 U.S. Constitution. So in response to that question, as in response to most of your other questions here today, no matter how much I would like to answer those questions, answer those questions specifically with respect to Jane Doe 4 and the -- your former partner -- wait - asa current partner, you won't tell me -- but your E partner who brought the lawsuit who the Florida Bar suspended for improper behavior, Mr. Edwards' partner who sits in jail for fabricating cases, stealing millions of dollars from unsuspecting Florida investors, I'd like to answer every one of your questions. However, my counsel told me today that I cannot answer any questions that may be relevant to the lawsuit. BY MR. HOROWITZ: Q Prior to May 2005 did you instruct S.K. to get Jane Doe 4's phone number, so that S.K. could communicate with Jane Doe 4 to schedule Jane Doe 4 fori massages with you? MR. PIKE: Form. THE WITNESS: I'd like to answer that question. I would like to answer your other questions posed here today. However, my -- on advice of counsel, they've instructed me that I Page 130 1 MR. PIKE; Form. 1 2 THE WITNESS: Me. Horowitz, I'd like to answer 2 3 each and every one of your questions, However, on 3 4 the advice of counsel, I can't answer any of your 4 5 questions with respect to the note that she 5 6 testified she wrote. I can't answer any questions 6 7 separate from -- that may be relevant to your 7 8 lawsuit. I can’t answer any questions posed by 8 9 you, the attorney sitting next to you whose partner 9 10 sits in jail, your former partner suspended or -- 10 LL for improper behavior after filing this lawsuit, aL 12 and suspended by the Florida Bar. I'd like to 12 13 answer every question you ask. However today, 13 14 Me. Horowitz, ] cannot because my counsel is 14 15 telling me if I -- if | do, I risk losing their 15 16 representation. 16 17 BY MR. HOROWITZ: 17 18 Q You've read the deposition transcript of Jane 18 19 Doe 4; is that correct? 19 20 MR. PIKE: Form. 20 21 THE WITNESS: You know, again, Mr. Horowitz, I 21 22 would like to answer every one of your questions; 22 23 however, my counsel has told me I cannot. They 23 24 told me 1 must assert my Fifth Amendment, Sixth 24 25 Amendment and Fourteenth Amendment Rights under th¢ Page 1325 must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment Rights. So then my -- I would like to answer questions posed by you, [ I know your partner could not be here since he was suspended by the Florida Bar after filing these cases, after holding press conferences he was suspended by the Florida Bar. Mr. Edwards, who sits on your right, his partner is sitting in jail, I'd like to answer every one of your questions. However, my counsel said at least today, 1 cannot. So I must accept their advice or risk losing their representation, BY MR. HOROWITZ: Q_ Did S.K. tell you that she confirmed by telephone that Jane Doe 4 would be coming to your hom: ata specific time to give you a massage? MR. PIKE: Form, THE WITNESS: Again. I'm sorry, could you repeat the question? BY MR. HOROWITZ: Q Did SK. tell you that she had confirmed by telephone with Jane Doe 4 that Jane Doe 4 would be coming to your home at a particular time to receive a massage? MR. PIKE: Form. 33 (Pages 129 to 132) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 133 Page 135 of counsel, the done for mostly all of your other questions, on advice ‘ve told me I cannot answer those 1 THE WITNESS: [ assume'when you say "Jane Doe} 1 questions. I'd love to answer the questions directly to 2 4," this is Jane Doe 4, a girl who testified that 2 you. 3 she wrote a note to me that said "for a good time, 3 T'd like to answer the questions to your 4 call Jane Doe 4." E assume that's the same Jane 4 partner, Jeffrey Herman. Jeffrey Herman who was ~ 5 Doe 4. I'd like to answer al! questions about Jane 5 after he filed this Jane Doe 4 case against me — was 6 Doe 4, her notes, anything that she said. However, 6 — suspended by the Florida Bar for improper behavior, or § 7 my attomeys told me I cannot, and they advised me 7 Mr. Edwards’ partner who sits in jail. [much prefer to [ 8 T mast assert my rights under the Sixth Amendment, 8 be talking to them. However, I cannot answer questions} 9 Fourteenth Amendment and Fifth Amendment, though 9 to you, and on advice of counsel, I must assert my 10 your partner whe filed the lawsuit was suspended by 10 rights, or risk losing their representation. al the Florida Bar after filing the lawsuit, holding 11 BY MR. HOROWITZ: 12 press conferences, Mr. Edwards' partner sits in 12 Q You knew that Jane Doe 4 was younger than 18 13 jail for fabricating cases of a sexual nature 13 when she came to your home in 2003 and 2004, correct? 14 against me and others. So, though I would like to 14 MR. PIKE: Form. a5 answer those questions, as you might imagine, 15 THE WITNESS: I'd like to answer that 16 Mr. Horowitz, is I'd like to answer -- 16 question. I'd like to answer each and every one of 17 unfortunately, as I've had to answer most of your 17 your questions. However, on advice of counsel, 18 questions here today, I cannot under advice of 18 they've instructed me that I cannot answer any 19 counsel. 19 questions that may be relevant to any of your 20 BY MR. HOROWITZ: 20 lawsuits brought by either you, your partner that's 21 Q Was it your intent during the course of Jane 21 been suspended by the Florida Bar for improper 22 Doe 4's visits to your home that you would persuade, 22 behavior, Mr. Edwards, who sits to your right, 23 induce or entice her to engage in sexual activity with 23 whose partner sits in jail for bringing fabricated you? 24 cases of a sexual nature against people like me and MR. PIKE: Form. 25 others, called -- his firm called a criminal Page 134 Page 136 | L THE WITNESS: Well, [ assume this the Jane Dog = 1 enterprise by the U.S. attorney for stealing 2 4 who wrote a note to me, according to her 2 millions of dollars from South Florida residents. 3 testimony that said, “for a good time, cal] Jane 3 I'd like to answer every one of your questions. 4 Doe 4." I assume that's the same Jane Doe 4 you're 4 However, today, under advice of counsel, I cannot. 5 referring to. 5 BY MR, HOROWITZ; 6 Unfortunately, your partner couldn't be here 6 Q_ Jane Doe 4 told you that she attended Royal 7 referring to it because he's been suspended by the 7 Palm Beach High School when she was in your home; is} 8 Florida Bar after filing Jane Doe 4's case. 8 that right? 9 Mr. Edwards' partner can't be here because he's 9 MR. PIKE: Form. 10 in jail for filing cases of a malicious nature, of 10 THE WITNESS: I'd like to answer that 14 sexual cases, fabricated cases. The U.S. Attorney 11 question. I'd like to answer every question you've 12 Has referred to the entire firm as a criminal 12 asked me here today. However, upon advice of 13 enterprise, a criminal enterprise of the large -- 13 counsel at least today, I cannot, according to 14 purporting to have the largest fraud in South 14 their advice, answer any questions that may be 15 Florida's history. So, though I would like to 15 relevant to this lawsuit -- excuse me -- | would 16 answer each one of your questions, on advice of 16 prefer to have had your partner, Jeffrey Herman, 17 Counsel today, I cannot. 17 who -- who J actually believe filed the suit, but 18 BY MR. HOROWITZ: 18 be's been disbarred in the interim -- I'm sorry, 19 Q During the course of Jane Doe 4's visits to 19 not disbarred. He's been suspended. I'm not 20 your home, did you in fact persuade, induce or entice 20 really sure what the difference is, but he's been 21 her to engage in sexual activity with you? 21 suspended from practicing law, while Mr. Edwards! 22 A I'd very much like to answer each one of your 22 partner sits in jail for fabricating cases of a 23 questions here today, Mr. Horowitz. However, as T've | 23 sexual nature against people like me and others. So, though I would like fo answer that question, as you, probably understand, on the advice of ‘counsel 34 (Pages 133 to 136) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 137 today, I cannot. BY MR. HOROWITZ: Q Isn't it true, sir, that on multiple occasions Jane Doe 4 discussed her activities at Royal Palm Beach High School with you? MR. PIKE: Form. THE WITNESS: Again? BY MR. HOROWITZ: Q Esn't it true, sir, that on multiple occasions Jane Doe 4 discussed her activities at Royal Palm Beach High School with you? MR. PIKE: Form. THE WITNESS: Royal Palm Beach High School wit me? MR. HOROWITZ: Yes. THE WITNESS: I don't understand the question. BY MR, HOROWITZ: Q Okay. You know, in your mind, who Jane Doe 4 is, correct? MR. PIKE: Form. THE WITNESS: Jane Doe 4 is the one girl you told -- I believe was the one who testified that she wrote a note to me that said "for a good time, call Jane Doe 4." [s that the Jane Doe 4 -- you can't testify, ’m sorry. Yes, I believe that's BY MR. HOROWITZ: Q Jane Doe 4 told you she could not travel with you over -- overseas because she was not yet 18; isn't that true? MR. PIKE: Form. THE WITNESS: Id like to answer that question. I'd like to answer every one of your questions. However, my attomeys today have instructed me, at least for today, | can't answer any questions that may become relevant to your -one of your lawsuits brought by your firm and at -your partner that's been suspended by the Florida Bar. BY MR. HOROWITZ: Q Between 2003 and May 2005, were you ever nudez in front of Jane Doe 4? MR. PIKE: Form. THE WITNESS: I would like to answer that question, I'd like to answer every one of your questions here today. However, my attorneys, who have advised me, that I cannot answer any questions that may be relevant to this or any of your other lawsuits brought by you and your partner that was suspended from the practice of the law in Florida, so ] must respectfully decline. Page 138 correct. BY MR. HOROWITZ: Q. Is it your testimony that Jane Doe 4 did not write such a note after a massage at your house? MR. PIKE: Form. THE WITNESS: Which question would you like mq to answer, the first one or -MR. HOROWITZ: The one { just asked. THE WITNESS: I'd like to answer every question with respect to everything with respect to Jane Doe 4, every single thing. However, my attorneys today told me that ] cannot, and they instructed me to assert the Sixth Amendment, Fourteenth and Fifth Amendment. BY MR. HOROWITZ: Q Isn't it true that Jane Doe 4 regularly discussed with you her activities at Royal Palm Beach High School? MR. PIKE: Form, THE WITNESS: My attorneys told me that, though T'd like to answer that question, as I'd like to answer all your other questions, | have to answer it the same way I've answered the others, which is asserting my Sixth Amendment, Fourteenth Amendmen! and Fifth Amendment Rights. Page 140 BY MR. HOROWITZ: Q Between 2003 and May 2005, did you ever instruct Jane Doe 4 to remove her clothing? MR. PIKE: Form. THE WITNESS: Again, | would like to answer every one of your questions, every one, every specific one, but my attorneys have advised me that today at least, I cannot answer any questions relevant, or may be relevant to your lawsuit. They've instructed me that ] must assert my Sixth E Amendment, Fourteenth Amendment and Fifth Amendmel Rights, So, though I'd like to answer the E question, Mr. Horowitz, 1 cannot do so, BY MR. HOROWITZ: Q Between 2003 and May 2005, did you instruct Jane Doe 4 to pinch your nippies -MR. PIKE: For. BY MR. HOROWITZ: Q_> --and rub your chest? MR. PIKE: Same objection. THE WITNESS: Is it -~ is it one or the other? MR. HOROWITZ: It's both. THE WITNESS: I see. No. I would -BY MR. HOROWITZ: 35 (Pages 137 to 140) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 141 Page 143 1 A. Esaid -- I'm sorry, I couldn't hear. 2 BY MR, HOROWITZ: 2 Q E thought you said "no" to my question? 2 Q Prior to June 2005 did you perform oral sex on. 3 A No. Pll--1'll tell when my -- I said no. 3 Jane Doe 47 4 Pd like to answer that question. I'd like to answer 4 MR, PIKE: Form. 5 every one of your questions. I'd like to answer each 5 A_Pdlike to answer that question, I'd very 6 and every one, However, my counsel today told me I 6 — much like to answer that question, but I cannot today, 7 cannot. They told me I have to assert my Sixth 7 because on advice of my counsel, they have told me that 8 Amendment, Fourteenth and Fifth Amendment Rights. And 8 I must assert my Sixth Amendment, Fourteenth Amendment? 9 iff didn't, and if 1 chose to answer the question, 1 9 and Fifth Amendment Rights. And if I chose to answer, 10 would risk losing their representation. So at least for 10 if] did answer that question, I risk losing their 11 today, I have to assert those rights. 14 representation, so at least for that -- for today, I 12. BY MR. HOROWITZ: 12 must respectfully dectine, sir. 13 Q Prior to June of 2005, did you ask Jane Doe 4 13. BY MR, HOROWITZ: 14 questions about her sexual experience and preferences? 14 Q Prior to June 2005 did you place your mouth on is MR. PIKE: Form, 1S — Jane Doe 4's genitals? 16 THE WITNESS: | would be bappy to answer that 16 MR. PIKE: Form. 17 question, if 1 could. My attorneys have told me I 1? THE WITNESS: You know, I'd like to answer that 18 can't. They've instructed me that I have to assert 18 question. J would have preferred hat either your 19 my Sixth Amendment, Fourteenth Amendment and Fifth} 19 partner, who was here, would have been here, the 20 Amendment Rights. I would like to answer the 20 one who filed the lawsuit, who is suspended by the b 21 question. However, they told me that if { do, 1 al Florida Bar, or Mr. Edwards' partner, Scott E 22 tisk losing their representation. 22 Rothstein, who sits in jail, was to be here. 1 / 23> BY MR. HOROWITZ: 23 would prefer to respond to them. However, today, [ IB 24 Q Prior to June 2005 did you touch Jane Doe 4's 24 cannot answer those questions based on advice of E breasts? 25 counsel, so | must respectfully decline. ; Page 142 Page 144 1 MR. PIKE: Form. 1 BY MR. HOROWITZ: 2 THE WITNESS: I'd like to answer that 2 Q Prior to June 2005 did you place a vibrator on i 3 question. I'd like to answer all your other 3 Jane Doe 4's genitals? i 4 questions here today. However, my counsel has told 4 MR. PIKE: Form, 5 me, at least today, | cannot. | have -- they've s THE WITNESS: I'd like to answer that 6 instructed me to assert my Fourteenth Amendment, my 6 question. I'd Jike to answer every question you've 4 iz Sixth Amendment and my Fifth Amendment Right. And = 7 asked here today. I'd like to respond to you — to i 8 they told me that if I chose to answer, I would 8 your partner who's been suspended. I apologize, iE 9 risk losing their representation, so therefore, I 9 before I said he was disbarred, but -- for improper i 10 must respectfully decline to answer them. 10 behavior after filing this lawsuit, On advice of i 11 BY MR. HOROWITZ: 11 counsel, they've instructed me that I must assert E 12 Q Prior to June 2005 did you rub Jane Doe 4's 12 my Fourteenth Amendment, Fifth Amendment and Sith 13 vagina? 13 Amendment Rights to any question that may become ff 14 MR. PIKE: Form. 14 relevant to this lawsuit or risk losing their FE 15 THE WITNESS: | would like to answer that 18 representation, therefore, | would have to ls 16 question with specificity. However, my attorneys 16 respectfully, respectfully decline. 17 have told me at least today that [ must 17. BY MR, HOROWITZ: 18 respectfully decline and assert my Fifth Amendment, 18 Q Prior to June 2005 did you give lingerie to 19 Sixth Amendment and Fourteenth Amendment Right. 1] 19 Jane Doe 4 to wear for you? 20 would have preferred that your partner, who after 20 MR. PIKE: Form. 21 he filed the lawsuit, was suspended by the Florida 21 THE WITNESS: I would like to answer that 22 Bar for improper practice, or Mr. Edwards’ partner, 22 question. I would like to answer all your 23 who sits in jail, to have been here to at least ask 23 questions. However, I am going to have to respond some of the questions, but my attomeys have told 24 to that question, as I responded to all your other 25 Mr. Horowitz, which i ison me 1 cannot answer those questions today, sir. rz z SIE REET arate questions here today, 36 (Pages 141 to 144) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 145 advice of counsel, they've instructed me { must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment Rights. And if] chose to answer, which | prefer to do, that question, [ risk losing their representation, BY MR. HOROWITZ: Q Prior to June 2005 wes Jane Doe 4 ever nude in front of you at your request? A. V'd like to answer that question. I'd very much like to answer that question. However, my attorneys have counseled me that | cannot answer that question or any question today that may be relevant to one of the lawsuits that you've brought, or your partner who has brought -- your partner who is suspended from practice in Florida. So, though I would like to answer the question, Mr. Horowitz, today under the advice of counsel, I cannot. Q Prior to June 2005 did you coerce Jane Doe 4 into putting her hands on your penis? A Again, I'm sorry? Q If--if--if~ ifyour attorney passing you notes is -- is causing you to be distracted from listening to my questions, 1 am -- | am going to ask that you not do it. A_L~Lunderstand. Page 147§ As you are well aware we have hyper-technical Constitutional privileges at issue here. If1 choose to communicate with my client regarding those privileges, [ will communicate with him. If you'd like me to take breaks, I will do so. But once again, we're here to answer your questions, and I would like to just move forward. BY MR, HOROWITZ: Q Prior to June 2005 did you coerce Jane Doe 4 into putting her hands on your penis? MR. PIKE: Form. THE WITNESS: I'd like to answer that question. | cannot answer that question on advice of counsel, but I'd like to answer that question. My counsel has advised me that | must assertmy = & Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights. And if I choose to answer that question, | risk waiving those rights, and risk losing their representation. BY MR. HOROWITZ: Q Prior to June 2005 did you insert your fingers into Jane Doe 4's vagina? MR. PIKE; Form. THE WITNESS: I'd like to answer that question about Jane Doe 4, and all the other girls you've 4 Page 146 MR. PIKE: Fine. THE WITNESS: It was just the fact -- it wasn't that. It was, in fact, I had put my glasses on. BY MR. HOROWITZ: | Q Your glasses were preventing you from hearing me? A Yes. MR. PIKE: First of all, you're not going to tell me how to communicate with my client. I'm trying not to take a break again, so that, you know, we don't -- we can keep going forward. If you'd like me to take a break, I can take another break right now. MR. HOROWITZ: Well, I'm not here to tell you’ how to do your job, but the Rules of Civil Procedure do, and what they say ~- let me finish -is that "if you interrupt an examination to communicate with your clients, you can be sanctioned for it." MR. PIKE: Okay. Well, first of all, Mr. Horowitz, I didn't interrupt any examination. You interrupted the examination. I didn't say a word. So, let's just go ahead and proceed forward. The witness asked you to repeat the question, okay? cannot answer any questions that may be relevant to [f the lawsuit. I'd like to answer that question directly to you, Mr. Edwards. Mr. Edwards‘ partner, unfortunately, is in jail, so I can'ttalk to him directly. Your partner has been suspended after filing a lawsuit against me, But, though I'd like to answer those questions, I risk losing their representation and waiving those rights, if I do 80. BY MR. HOROWITZ: Q Prior to June 2005 did you masturbate in front of Jane Doe 4? MR. PIKE: Form. THE WITNESS: I'd like to answer that question. I'd like to answer afl your other questions posed here today; however, I cannot do so on the advice of counsel. And they told me thatif I do answer the questions, | may waive those rights, or risk losing their representation. BY MR. HOROWITZ: Q Prior to June 2005 did you ejaculate in front of Jane Doe 4? MR. PIKE: Form. THE WITNESS: I would like to answer that 37 (Pages 145 to 148) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Paga 149 Page 151} okay that you were touching her breasts and genitals while she was still a child? MR. PIKE: Form. THE WITNESS: I'd like to answer that question about Jane Doe 4, the git] who wrote “for 1 2 3 4 8 question. T'd like to answer every question you've 6 . 8 9 4 2 a good time, call" -- | -- from her testimony, “for 3 a good time, call Jane Doe 4" or “call Jane Doe 4 4." I'm not actually sure. You maybe could clue 5 me in. However, my counsel has told me today that 6 7 8 L-- I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment Rights as provided by the U.S. constitution. And, though | would like to asked here today, every question. However, my counsel] has instructed me at least today, I cannot answer those questions, and they've instructed me 9 answer each and every one of your questions, I that I must assert my Fourteenth Amendment, Sixth E 10 cannot do so. | risk waive -- risk losing or 10 Amendment and Fifth Amendment Rights as provided by. 1 waiving those rights and losing their 1a the Constitution. And by not doing so, | may waive 12 representation. 12 those rights or risk losing their representation. 13. BY MR. HOROWITZ: 14 Q Did Jane Doe 4 come to your Palm Beach home on | 14 Q Prior to June 2005 did you instruct S.K. to 15 multiple occasions between 2003 and May 2005 to give yoy 15 communicate with Jane Doe 4 by telephone to schedule 16 — massages during which you engaged her in sexual 16 Jane Doe 4 to come to your Palm Beach home for sexual 17 activity? 17 activity? 13. BY MR. HOROWITZ: 18 MR, PIKE: Form. 18 MR. PIKE: Form. 19 THE WITNESS: I'd like to answer each and every 19 THE WITNESS: I'd like to answer that 20 ‘one of your questions posed here today. I would 20 question, I'd like to answer all your questions. 21 like to answer that question, and all the other 21 I wish your partner that had been suspended from 22 questions you've asked about Jane Doe 4. However, 22 practice after he filed Jane Doe 4's lawsuit, or 23 upon advice of my counsel, they've instructed me to 23 Mr. Edwards’ who's -- who sits next to you, whose 24 assert my Fourteenth Amendment Rights, my Sixth 24 partner sits in jail, I would like nothing more 25 Amendment Rights and my Fifth Amendment Rights as | 25 than to answer these questions today, but upon Page 150 Page 1525 provided by the constitution. So, though I'd like to answer, I don't. I've been instructed that I E 1 advice of my counsel, they've told me that ] must 2 2 assert my Fourteenth Amendment Rights, my Sixth 3 risk waiving those rights and losing their 3 Amendment Rights and my Fifth Amendment Rights. 4 representation. 4 And by not doing so, I may waive those rights or 5 BY MR. HOROWITZ: 5 tisk losing their representation. Adam, may ] take 6 Q Prior to May of 2005 did you pay Jane Doe 4 6 a quick five minutes? 7 $200 after having had sexual contact with her? 7 MR. HOROWITZ: Sure. 8 MR. PIKE: Form. 8 THE VIDEOGRAPHER: Time off the record 1:50, 9 THE WITNESS: Again? 9 (Thereupon, a short break was taken.) 10 BY MR. HOROWITZ: 10 THE VIDEOGRAPHER: Time on the record 2:00. 11 Q Prior to May 2005 did you ever pay Jane Doe 4 11 BY MR. HOROWITZ: 12 $200 after having had sexual contact with her? 12 Q Prior to June 2005 you instructed Jane Doe 4 to 13 MR. PIKE; Form. 13 call you at your Palm Beach home to confirm the specific 14 THE WITNESS: I'd like to answer that 14 dates and times you wanted her to come over for sexual 15: question. I'd like to answer every one of your 15 activity, correct? 16 questions posed here today. However, according to 16 MR. PIKE: Form. 17 my counsel, he’s asked me to assert my rights under vv THE WITNESS: I'd fike to answer that 18 the Fourteenth Amendment, the Sixth Amendment, the 18 question. I'd like to answer every question you've 19 Fifth Amendment of the U.S. Constitution, and he's 19 asked me here today, but I'm going to have to 20 instructed me that no matter how much I'd like to 20 respond the same way I've responded to most of your 21 answer these questions, that if I do so, I may 24 questions, Mr. Horowitz, which is on advice of 22 waive those rights and risk losing his 22 counsel, I'm going to have to assert the Sixth 23 representation. 23 Amendment, Fourteenth Amendment and Fifth Amendm BY MR. HOROWITZ: 24 Rights, Though I'd like to answer that question, id you try to ) persuade Jane D Doe 4 that i it was. as all your other questions, Im informed that if] 38 (Pages 149 to 152) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 1 do so, I risk waiving those rights and losing my representation. BY MR. HOROWITZ: Q Did you instruct Jane Doe 4 to lie to police investigators during their 2005 investigation into your, criminal activities? MR. PIKE: Form, THE WITNESS: Did | instruct Jane Doe 4 to lie? MR. HOROWITZ: That's my question, yes. THE WITNESS: I'd like to answer that question. I'd like to answer every one of your questions here today. 1'd like to answer questions of -- unfortunately, the -- I guess your partner that filed this lawsuit was suspended by the Florida Bar. I'd like to answer. However, my counsel has advised me at least today that I must assert my rights under the Fourteenth Amendment, Sixth Amendment and Fifth Amendment. And if! choose to answer that question, which I prefer to do, I risk losing their representation and waiving those rights, so 1 must respectfully decline. Sorry, Mr. Horowitz. BY MR. HOROWITZ: Q Are you suggesting that you have some 53 Page 155 1 that-2 A Yeah. 3 Q —his suspension had anything to do with you 4 or the lawsuits against you? 5 MR. PIKE; Form. 6 7 8 THE WITNESS: I'd like to answer that question, but my counsel bas advised me I cannot today. | must assert the Fourteenth Amendment, Sixth 9 Amendment and Fifth Amendment Rights, though 10 obviously, I'd like to answer that question. 41 BY MR. HOROWITZ: 12 Q Did you instruct $.K. to tell Jane Doe 4 to lie 13 to police investigators during their 2005 investigation 14 into your criminal activity? 15: MR. PIKE: Form. 16 THE WITNESS: I'd very much like to answer thi 17 question. I'd very much like to answer all your 18 questions here today, but as I've done with most of 19 those questions, on advice of my counsel -- it's 20 been a long day so far -- am going to have to 21 refrain from answering, at least today, to any 22 questions that may be relevant to any of your 23 lawsuits brought by you, your suspended partner, Mr. Edwards and his partner who's in jail. So, though I'd like to answer those questions, I risk Page 1 information that Jeffrey Herman was suspended from practice of law because he made false staternents in a lawsuit against you? MR. PIKE: Form. THE WITNESS: Jeffrey Herman was your partner. Are you asking me why he was suspended? I'm sorry, are you asking me -BY MR. HOROWITZ: Q > I'm asking you why -THE REPORTER: Wait a second. THE WITNESS: Sorry. Are you asking why your partner was suspended from the practice of law in South Florida? BY MR. HOROWITZ: Q I'masking you whether you have any information or you're suggesting here today that his suspension of practice of law had anything to do with you or the lawsuits against you? MR. PIKE: Form. THE WITNESS: Asm I suggesting that his disbarment -- I'm sorry -- his suspension or -- I'm sorry == car you do it again? Was he disbarred or suspended? BY MR. HOROWITZ: Q Are you suggesting today in your testimony STE TTT 54 the Page 156 E 1 losing or waiving my rights and my counsel's 2 representation, so I must respectfully decline 3 today. 4 BY MR. HOROWITZ: 5 Q Did you instruct J.B. to rent a car for Jane 6 Doe 4? 7 MR. PIKE: Form. E 8 THE WITNESS: I'd like to answer that question ff 9 + Jane Doe 4 ~ have we moved from a different person, I'm sorry? 11 MR. HOROWITZ: We're on Jane Doe 4. 12 THE WITNESS: Okay. I'd like to answer that 13 question. I'd like to answer every one of your 14 questions. However, my counsel has advised me, at 15 least today, that | cannot do so. | must assertmy — 16 Fourteenth Amendment, Fifth Amendment and Sixth 17 Amendment Rights. 18 BY MR. HOROWITZ: 19 Q Did you intend for Jane Doe 4 to use the car 20 that you rented for her, for her to come to your home tof 21 give you sexual massages? E 22 MR. PIKE: Fonn. 23 THE WITNESS: Did | intend a car that was. rented for Jane Doe 4 -~ could you do the question again? rt SSE SST 39 (Pages 153 to 156) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 157 BY MR. HOROWITZ; Q Sure. Did you intend for Jane Doe 4 to use the ear you rented for her to come to your home to give you sexual massages? MR. PIKE: Form. THE WITNESS: You said I rented a car? MR. HOROWITZ: I'm just asking the questions. My -THE WITNESS: I'm sorry, you have to ask the question again, BY MR. HOROWITZ: Q Sure. Previously | asked you if you rented a car, and you asserted the Fifth -A. I don't believe you did, Q > Okay. Allright. Did you -A You asked me if instructed somebody -Q > That's right. You're correct. The car that you instructed J.B. to rent for Jane Doe 4. I'm talking about that -- that vehicle, okay? Did you intend for Jans Doe 4 to use that car to come to your home and give you sexual massages? MR. PIKE: Form. THE WITNESS: I'd like to answer that guestion. I'd like to answer every question about Jane Doe 4 that you asked me here today. My Page 159 +- a videotape of her and her boyfriend having sex? MR. HOROWITZ: Yes. THE WITNESS: Okay. I'd like to answer that question, but my counsel has instructed me that 1 must assert my Fourteenth Amendment, Sixth Amendment and Fifth Amendment Rights. And, thoug it's obvious I'd like to answer that question, my attorneys have counseled me that ! ~ by doing so, I waive those rights, or risk losing their representation, May I get some -- a cup? Is this yours? MR. HOROWITZ: No. THE WITNESS: Okay. MR. HOROWITZ: It's mine. BY MR, HOROWITZ: Q Sir, you don't deny that you sexually abused Sane Doe 4, do you? MR. PIKE: Form, argumentative. THE WITNESS: I'd like to answer that question very much so. However, my counsel has advised me today that | must assert -- at least today, I must assert Sixth Amendment, Fourteenth Amendment and [; Fifth Amendment Rights. And by choosing to answer, |; I may waive those rights or risk losing their [ representation. Page 158 counsel has advised me that I may not. And they've instructed me that ] am to assert my Fourteenth Amendment, Sixth Amendment, Fifth Amendment Rights. And, though I'd like to answer each one of your questions, my counsel has advised me that if] choose to do so, which is my preference, I risk waiving those rights and/or losing their representation, BY MR. HOROWITZ: Q Isn't it true that you and Jane Doe 4 watched a videotape of Jane Doe 4 and her boyfriend having sexual intercourse? MR. PIKE: Form. THE WITNESS: Can you describe this videotape to me? BY MR. HOROWITZ: Q Would that refresh your recollection? A I don't know. Would you want to tell me about it? Q My question for you is: Isn't it true that you and Jane Doe 4 watched a videotape of Jane Doe 4 and hed boyfriend having intercourse? Does that reftesh your recollection? MR. PIKE: Same objection, form. Page 160} So, though your partner after he filed that Jane Doe 4 lawsuit was suspended from the practice of Jaw by the Florida Bar, or some of these other cases brought by Mr. Edwards' firm who is sitting next to you, whose partner sits in jail for bringing cases of a sexual nature, accusing people fallaciously, maliciously, simply to get money, I'd like to answer each one of your questions, but today, unfortunately, | must respectfully decline, BY MR. HOROWITZ: Q_ Sir, are you asserting your Fifth Amendment, Sixth Amendment and Fourteenth Amendment Rights to protect your innocence, or conceal your guilt? MR. PIKE: Form. I'm going to instruct him not to answer that question. BY MR. HOROWITZ: Q {Is there any reason that the jury should not infer that you did in fact have sexual contact with Jane Doe 4 when she was a child, given that you've asserted the Fifth Amendment? MR. PIKE: Form. THE WITNESS: The Fifth Amendment has been us many times to protect the innocent, especially people who've been falsely accused by people like Mr. Edwards’ partner, Scott t Rothstein, who 40 (Pages 157 to 160) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 161 our Palm Beach estate in approximately 2001 or__| UNIVERSAL COURT (954) 712-2600 (877) I--1 don't understand the (Pages 161 to 164 REPORTING 291-DEPO (3376) a sits in jail accused by the U.S, Attorney of 1 2002? 2 running the biggest fraudulent scheme in South 2 MR. PIKE: Form. 3 Florida's history, stealing miilions of doilars 3 THE WITNESS: I'd like to answer that question 4 from South Florida residents. The U.S. Attorney 4 with respect to Miss Jane Doe 5. 5 called his enterprise a criminal - his firm, 5 Q Lasked you the right -- 1 know you did write 6 Mr. Edwards' finn, sitting next to you -- another 6 it down. 7 one of the lawsuits, a criminal enterprise, 7 A Eknow. But how did you pronounce it? 8 I'd like to answer that question very 8 Q Jane Doe 5. 9 specifically. However, my attorneys have counseled 9 A Okay. However, my attorneys have counseled mq 10 me that today I may not, and [ may risk losing my 10 that at least today I cannot answer questions that may in rights, my waiver - excuse me - my rights, and 11 become relevant to any of your lawsuits that you have 12 risk losing my representation, if f choose to 12 filed with respect to these girls, or your partner filed 13 answer that question. 13 before he became suspended by the Florida Bar for 14 BY MR. HOROWITZ: 14 improper behavior. 15 Q > Okay. 1 don't want to know why other people 18 So, though I'd like to answer that question, 16 assert the Fifth Amendment. I want to know why you're) 16 Mr. Horowitz, as | would like to answer every one of 17 ~~ asserting it. Are you asserting it because you're an 17 your questions, at least today, [am going to have to 48 — innocent man, or because you're a guilty man? 18 assert the rights dictated to me by my counsel, either 19 MR. PIKE: Form. 19 the Sixth Amendment, Fourteenth and ~ or Fifth 20 THE WITNESS: I'd love to answer that 20 Amendment, or all of the above. 2L question. However, my attorneys have counseled me} 21 I mean, I would like to answer each and every 22 that I cannot and must assert my rights under the 22 one of your questions. If | do so, I'm told that I risk 23 Sixth Amendment, Fourteenth and Fifth, even to that} 23 waiving those rights, or losing their representation. 24 question, Though I would be more than happy to 24 BY MR. HOROWITZ: 25 answer it, my attorneys have counseled me that by Q Allright. Page 162 1 doing so, I may waive those rights and risk losing 1 A Excuse me. 2 their representation. 2 Q In either 2001 or 2002, did S.K. inform you 3 BY MR. HOROWITZ: 3 that she had received a telephone call in which she was 4 Q Okay. Sir, I'm going te ask you a few 4 referred to an underage girl named Jane Doe 5 who would: 5 questions about a young woman named Jane Doe 5. 5 be willing to come to your home and give you a massage 6 A Yes. Okay. 6 for money? 7 Q First name is Jane Doe 5. 7 MR. PIKE: Form. 8 MR. PIKE: You said her last name was Jane Dod 8 THE WITNESS: I'd like to answer that question, 9 5? 9 as I'd like to answer mostly every one of your 10 MR. HOROWITZ: Yes. 10 questions here today. These questions, my 11 BY MR. HOROWITZ: 1. attomeys have counseled me, I cannot answer today 12 Q So you know her as Jane Doe 57 12 because -- as they may be relevant to the lawsuit. 13 MR. PIKE: Form, mischaracterizes the witness’ | 13 They have instructed me that I must assert my 14 testimony, move to strike. Let's not play with 14 Sixth Amendment, Fourteenth Amendment and Fifth 15 words. 15 Amendment Rights, though I'd very much like to 16 BY MR. HOROWITZ: 16 answer that question, 17 Q Do you recognize her name as A.G. or Jane Doe} 17 = BY MR. HOROWITZ: 18 52 18 Q Did S.K. inform you that she was provided with 19 A_ {don't recognize her name. 19 Jane Doe 5's telephone number? 20 Q Okay. Well, for the moment I would like you to} 20 MR. PIKB: Form. 21 hold onto that name, so -- because I'll be asking youa | 21 THE WITNESS: Again? 22 _ series of questions about it, okay? 22 BY MR. HOROWITZ; 23 A Okay. 23 Q Did S.K. inform you that she was provided with Q Isn't it true that a girl named Jane Doe 5 came 24 — Jane Doe 5's telephone number? )

Page 165 question. 1 MR. PIKE: Form to that, And I know you're 2 going to ask it again. 3 THE WITNESS: Yes, he is. 4 BY MR. HOROWITZ: S Q Did - Pl try and ask it as fundamentally as 6 Tcan. 7 A Okay, & Q Did S.K. inform you that she had Jane Doe 5's 9 telephone number? 10 A I'd like to answer that question. I've been aL have -- I'd like to answer every question you've asked 412 here today. However, on advice of counsel, they've 13 instructed me that I cannot answer that question today 14 because it may be relevant to one of your lawsuits filed | 15 by either you, Mr. Edwards -- Mr. Edwards' partner whol 16 sits in jail, your partner who's been suspended from the | 17 Florida Bar. 18 So, though I'd like to answer that question, at 19 least today, my counsel said I risk waiving those rights | 20 under the Sixth, Fourteenth and Fifth, or risk losing 21 their representation. 22 Q Did you instruct S.K. to call Jane Doe 5 to 23 come to your home and give you a massage in 2001 or 2002? Page 1675 Amendment rights. And if I choose not to do so, I risk waiving those rights, or losing their representation. So, though I'd like to answer that question, 1 cannot. BY MR. HOROWITZ; Q Did you observe S.K. speaking with Jane Doe 5 on the telephone to arrange for Jane Doe 5 to come to your home for a massage? MR. PIKE: Form. THE WITNESS: I'd like to answer each one of your questions, Mr. Horowitz, each and every one that you've posed here today, but I am going to have to answer that question, as I've answered most of your other questions here today, which is my counse! has advised me, at least today, at least today, that I cannot answer those questions and yi must assert my Fourteenth Amendment Rights, Sixth { Amendment Rights and Fifth Amendment Rights or BY MR. HOROWITZ: Q Did-A I'm sorry. Q_ I'm sorry, go ahead. A --orrisk waiving those rights, or losing their representation. Q Did S.K. tell you that she had confirmed by Page 166 MR. PIKE: Form. 1 THE WITNESS: This is the same Jane Doe 5 -- 2 whatever her name is? 3 MR. HOROWITZ: Yes, keep that same person inj 4 your head. 5 THE WITNESS: It's a little bit tough. I'd 6 like to answer that question. I'd like to answer 7 all your questions. However, today, my counsel has 8 advised me that I cannot answer any questions that 9 may be relevant to the lawsuit, and they've 10 instructed me that [ must assert my Fourteenth, 11 Fifth and Sixth Amendment Rights. 12 And by answering those questions, that | choose 13 ~~ that prefer to do so today, they've instructed 14 me that I may waive those rights, or risk losing 15 their representation. 16 BY MR. HOROWITZ: 17 Q Did you inform S.K. that the massage Jane Doe 5} 18 was to give you would be sexual in nature? 19 MR. PIKE: Form. 20 THE WITNESS: I'd like to answer each and every, 21 one of your questions. My counsel has advised me 22 -- my counsel has advised me that ! cannot today, 23 and they've instructed me that I should assert my 24 Fourteenth Amendment, Sixth Amendment and Fifth “UNIVERSAL COURT (954) 712-2600 (877) Page 168 telephone that Jane Doe 5 would be at your home at a specific time to give you a massage? MR. PIKE: Form, THE WITNESS: I'd like to answer that question. I'd like to answer every one of your questions posed here today, Mr. Horowitz. However, on advice of counsel, they've instructed me that I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Right. BY MR. HOROWITZ: Q. Was it your intent during the course of Jane Doe 5's visit to your home in either 2001 or 2002, that you would persuade, induce or entice her to engage in sexual activity? MR. PIKE: Form, THE WITNESS: It would give me great pleasure to be able to answer that question to you, as it -as all the other questions you've asked about these girls here today. My counsel has told me that I cannot answer those questions that may be relevant to any of the lawsuits brought by you, your partner that's been suspended or disbarred -- I'm not really sure what the difference is -- or My. Edwards’ partner who sits in a Florida jail for fleecing people out of millions of dollars by 42 (Pages 165 to 168) REPORTING 291-DEPO (3376)

Page 169 Florida. I'd like to answer every question you've asked me here today, Mr. Horowitz, but my counsel has instructed me that I may not. crafting cases of a sexual nature against people 1 2 3 4 5 BY MR. HOROWITZ: 6 7 8 1 2 like me and others, and those are -- though I'd 3 like to answer those questions, my counsel has 4 advised me, at feast today, that I cannot. 5 BY MR. HOROWITZ: 6 7 8 Q During the course of Jane Doe 5's visit to your home in 2001 or 2002, did you, in fact, persuade, induce Q > When Jane Doe 5 came to your home in either 2001 or 2002, she appeared to you to be under the age off or entice her to engage in sexual activity with you? 18; isn't that right? 9 MR. PIKE: Form. 9 MR, PIKE: Form. 19 THE WITNESS: Though I'd like to answer that | 10 THE WITNESS: I'd like to answer all your E 11 question, as well as every other question you've 11 questions. I'd like to answer each and every one 12 asked me here today, | am going to respond ina 12 of your questions. However, my counsel has i 13 similar fashion, which is my counsel, at least 13 instructed me that I may not answer any questions ; 14 today, has told me I may not, may not respond, and | 14 that may be relevant to this lawsuit, or any of i 15 must assert my rights under the Fourteenth, Sixth 4s your lawsuits brought by your firm, your suspended 16 and Fifth Amendment. 16 partner or Mr. Edwards' firm, his partner who sits E 7 Though I'd like to respond to each question, my | 17 in jail - excuse me. i 18 counsel has told me that if I choose to do so, 1 18 So, though I'd like to answer those questions, lf 19 risk waiving those rights and losing their 19 I was told that -- by my counsel that if I choose lf 20 representation. 20 to do so, I risk waive - risk waiving my rightand 21 BY MR. HOROWITZ: 2a tisk losing their representation. q 22 Q Did you pay for Jane Doe 5 to take a taxi to 22 BY MR, HOROWITZ: : 23° your home in either 2001 or 20027 23 Q During Jane Doe 5's visit to your home in 2001 & 24 MR. PIKE: Form. 24 and 2002, she told you she attended Wellington High i 25 THE WITNESS: I'd like to answer each question | 25 School; isn't that right? Page 170 Page 172] 1 you've asked me here today. However, on advice of 1 MR. PIKE: Form. F 2 counsel, they've asked — they've instructed me to 2 THE WITNESS: Fd like to answer that E 3 assert my Fifth Amendment, Sixth Amendment and 3 question. I'd like to answer every question you've = 4 Fourteenth Amendment Rights under the U.S. 4 posed here today, but unfortunately, | am going to I 5 Constitution. 5 have to respond the same way I've responded to most! H 6 Though I'd like to answer each question, I have 6 of these other questions, which is my counsel has 7 to respond, unfortunately, the same way I've 7 advised me that at least today, I cannot answer H 8 responded to mostly every one of your questions 8 those questions. And if I choose to do so, I may y 9 here today, and assert those rights on counsel's 10 advice, or risk waiving those rights and losing 1. their representation. 12. BY MR. HOROWITZ: 13 Q During Jane Doe 5's visit to your home in 14 either 2001 or 2002, Jane Doe 5 told you she was under! 9 waive my rights, but [ -- so I must assert them 10 under the Sixth, Fourteenth and Fifth Amendment. 11 BY MR. HOROWITZ: 12 Q During Jane Doe 5's visit to your home in 2001 13 or 2002, were you nude in front of Jane Doe 5? 14 A_ I'd like to answer - 15 18, didn't she? 15 MR. PIKE: Form. 16 MR. PIKE: Form. 16 THE WITNESS: -- that question. I'd like to 7 THE WITNESS: I'd like to answer that 17 answer every question you've asked me here today. 18 question. I'd like to answer every question you've 18 But my counsel has advised me that 1 may not answer 19 asked me here today. I'd like to answer the 19 any questions that may be relevant to your lawsuit, 20 questions posed by you, Mr. Edwards, your partner, | 20 Mr. Edwards' lawsuit, his partner's lawsuit who 24 Mr. Herman, who unfortunately was suspended after} 21. sits -- his partner who sits in jail, and my 22 he filed these cases, Mr. Edwards's partner who's 22 counsel has advised me that, though his partner 23 sitting ~ sitting in a jail for fabricating cases 23 sits in jail for bringing fabricated cases of a of a sexual nature against people like me and sexual nature against people like me and others, _that 1 still have to assert myt rights under the E 43 (Pages 169 to 172) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291~DEPO (3376)

Page 173 Sixth Amendment, Fifth -- Fourteenth Amendment ang Fifth Amendment; otherwise, I risk waiving those rights, or losing their representation, BY MR. HOROWITZ: Q During the course of Jane Doe 5's visit to your home in either 2001 or 2002, did you instruct Jane Doe S| to remove ail of her clothing? MR. PIKE: Form. THE WITNESS: I'd like to answer that question. I'd like to answer every question you've asked me here today with specificity. However, my counsel has told me that I may not answer any questions that may be relevant to this lawsuit, must assert my rights under the Fourteenth, Sixth and Fifth Amendment, so I must respectfully decline, Mr. Horowitz. BY MR. HOROWITZ: Q During the course of Jane Doe 5's visit to your home in 2001 or 2002, did you instract Jane Dee 5 to pinch your nipples and rub your chest? MR. PIKE: Form. THE WITNESS: Like all the other questions -questions you've asked me here today, I'd love to answer that question. I'd love to answer each and every one of your questions here today, but my Page 174 counsel has told me I cannot. They've instructed me that I have to assert my Fourteenth, Fifth and Sixth Amendment Rights. And, though I'd like to answer -- prefer to answer, that by doing so, [may waive those rights, and risk -- and/or risk losing their representation. BY MR. HOROWITZ; Q Okay. During the course of Jane Doe 5's visit to your home in 2001 or 2002, isn't it true you asked Jane Doe 5 questions about her sexual experience and preferences? MR. PIKE: Form. THE WITNESS: I'd like to answer each and eve one of your question about Jane Doe 5 -- Jane Doe 5 and her claims. However, my attorneys have told me I cannot, at least today, answer any of those questions that may be relevant to the lawsuit that you have filed, your suspended partner has filed, Mr. Edwards has filed, his partner in jail has filed. Unfortunately, there's lots of things [ cannot answer questions to, My partner -- my counsel has told me that I risk waiving my rights and losing their representations, if I choose to do so. BY MR. HOROWITZ: Page 175 Q During the course of Jane Doe 5's visit to your FE home in 2001 and 2002, did you remove Jane Doe 5's bra and rub her breasts? MR. PIKE: Form. THE WITNESS: The answer is: I'd like to answer that question. I believe Jane Doe 5 testified that that was not the case, or you're asking me a question that she testified to something else? But, though I cannot answer those questions, my counsel has advised me that I have to assert my rights under the Fifth, Fourteenth and Sixth Amendment. So, though I'd like to answer that question, I may not. BY MR. HOROWITZ: Q Well, which version of events is true, that you did touch her breasts, or that you did not touch her breasts? A. Are you asking me whether she tells the truth or not in her deposition? Is that the question? Q > My question is: Which version of events is true, that she touched your breasts -- that you touched her breasts, or that you did not touch her breasts? MR. PIKE: Form. THE WITNESS: ¥'d like to answer that question, As you might imagine I'd like to answer Page 176 that question very much. However, my counsel has advised me I may not, today anyway, and [ must assert my right under the Sixth, Fourteenth or -and/or Fifth Amendment. And, though I'd like to answer that question specifically ~- I'd like to answer it to you, I'd like to answer it to your partner who's not here because he's been suspended from the practice of law in South Florida after he filed this lawsuit. Tid like to answer that question specifically to Mr. Edwards’ partner who remains in jail for perpetrating a fraud on people in South Florida, stealing money from them. Unfortunately, under -- my counsel has told me that I must respectfully decline and assert my rights, or risk waiving those rights and fosing their representation. THE WITNESS: I'm going to have to take a break. THE VIDEOGRAPHER; Going off the record. Timez off the record 2:25. | (Thereupon, a short break was taken.) THE VIDEOGRAPHER: Time on the record 2:37. This is Tape 4, 44 (Pages 173 to 176) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 177 Q Okay. We've been discussing Jane Doe 5 for some time now. Okay. I'm going to ask you a few more questions about her. During the course of Jane Doe S's visit to your home in 2001 and 2002, did you rub Jane Doe 5's vagina over her underwear? MR. PIKE: Form, and assumes facts not in evidence. THE WITNESS: I'd like to answer that question. Fd like to answer every question you've asked me here today, But on advice of counsel, they've instructed me, { must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendmen} Rights. BY MR. HOROWITZ: Q During the course of Jane Doe 5's visit to your home in 2001 and 2002, did you rub her vagina under her underwear? MR. PIKE: Form. THE WITNESS: I'm afraid it's the same answer as most of the other answers I've given here today. Though I would like to answer these questions with specificity, especially that question, my counsel has advised me that I may not, and must assert my rights under the Sixth Amendment, Fourteenth and Fifth Amendment. Page 179 BY MR. HOROWITZ: Q During the course of Jane Doe 5's visit to your home in 2001 or 2002, did you place a vibrator on her vagina? MR. PIKE: Form. THE WITNESS: I'd like to answer that l THE VIDEOGRAPHER: Hold on. There's major static. Time off the record 2:40. (Thereupon, a short break was taken.) lj THE VIDEOGRAPHER: Time on the record 2:414) MR. HOROWITZ: Back on the record. Idon't know that we did or did not get an answer to this question, so I'm going to repeat it. And if you have to repeat your answer, I apologize. MR, PIKE: Thank you. BY MR. HOROWITZ: Q During the course of Jane Doe S's visit to your home in 2001 or 2002, did you place a vibrator on her vagina? MR. PIKE: Form. THE WITNESS: I'd Jike to answer the questions about Jane Doe 5. However, my attorneys have told me that I may not answer any questions regarding anything that may be relevant to any of the lawsuits brought by you, your firm, your partner Page 178 And if I chose to answer, which I prefer to do, they've advised me I may waive those rights, or risk losing their representation. BY MR. HOROWITZ: Q During the course of Jane Doe 5's visit to your home in 2001 and 2002, did ~ did you insert your fingers into her vagina? MR. PIKE: Form. THE WITNESS: I'd very much like to answer that question as well, Mr. Horowitz, but my attorneys have advised me today that | cannot, and I must assert my rights under the Sixth, Fifth and Fourteenth Amendments. Though it would -- I'd prefer to answer the question, they told me that if I choose to do so, I risk waiving those rights. I would prefer to have that conversation with your partner that was suspended or disbarred from the Florida Bar after filing the lawsuit on Jane Doe 5's behalf. I'd prefer to talk to Mr. Edwards' partner, if he was able to be here, except he's in jail for fabricating cases of a sexual nature against people like me. So, believe me, !'d like to answer those questions, but today my attorneys have told me I Page 190 that was suspended or disbarred after he brought these lawsuits. So, though I'd like to answer the question, Mr. Horowitz, my attorneys have advised me, at least today, that 1 must assert my rights under the Sixth, Fourteenth and Fifteen -- Fifth Amendment, and I respectfully have to decline. BY MR, HOROWITZ: Q_ During the course of Jane Doe 5's visit to your home in 2001 or 2002, did you masturbate in her presence? MR. PIKE: Form. THE WITNESS: I'd very much like to answer every question, every single question regarding Jane Doe $ and her claims. However, my attorneys have advised me, at least today, that I may not do s0, and must assert my rights under the Sixth Amendment, Fourteenth and Fifth Amendment. And, though i would prefer to answer, they have advised me that if I choose to do so, I risk waiving those rights and risk losing their representation. BY MR. HOROWITZ: Q During the course of Jane Doe 5's visit to your home in 2001 or 2002, did you ejaculate in her presences MR. PIKE: Form. 45 (Pages 177 to 180) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 181 THE WITNESS: Did I ejaculate in Miss Jane Doe 1 5's presence? I'd like to answer that question and 2 that all her claims -- however, today, my attorneys 3 have counseled me that | may not. 4 They've instructed me that ] have to assert my 5 Sixth Amendment, Fourteenth Amendment and Fifth 6 Amendment Rights. Though I'd like to answer that 7 question, } am going to have to respond as I've & answered most of your other questions here today, 9 which is by asserting those rights, 10 BY MR. HOROWITZ: 11 Q Did you have sexual contact with Jane Doe 5 in 12 your Palm Beach home in either 2001 or 20022 13 MR. PIKE: Form. 14 THE WITNESS: "Sexual contact"? 15 MR. HOROWITZ: Yes. 16 THE WITNESS: Can you tell me what you mean by 17 that? 18 BY MR. HOROWITZ: 19 Q Contact, sexual -- of a sexual nature. Do you 20 understand -~ do you understand what that means? 21 A. i've asked you -- 22 Q Have you had sexual contact? 23 A I've asked you to clarify what you mean, please. Page 183 of Miss Jane Doe S's complaints or claims. My attorneys have told me that, at least today, that I may not do so today, and must assert my rights under the Sixth Amendment, Fifth Amendment and Fourteenth, and | have to respond the same way I've| responded to most of your -- my -- your other questions posed here today, BY MR. HOROWITZ: Q Did you pay Jane Doe 5 $200 after you had sexual contact with her in your home? MR. PIKE: Form. THE WITNESS: !'d like to respond to every one of Jane Doe 5's claims, but my attorneys have advised me that at least today I must assert my rights under the Fifth, Sixth and Fourteenth Amendment. Though I'd like to answer that question, 1 am going to have to respond similarly that I've answered most of your other questions here today. This is no different. And I -- though J would -- I've been advised by my attorneys, if | choose to answer, | risk waiving my rights and/or risk losing their representation. BY MR. HOROWITZ: [ Q You never asked Jane Doe 5 for permission to touch either her breasts or genitals, correct? Page 182 Q Well, I'm going to use a broad definition, L okay? 2 A Yes, 3 Q_ That would involve touching someone's sexual 4 organs, someone else touching your sexual organs, having = 5 sexual contact together, such as intercourse or oral sex 6 ot anal sex. Did you have any of those activities of a 7 sexual nature with Jane Doe 5? a MR. PIKE: Form. 9 THE WITNESS: I'd like to respond to every one 10 of Jane Doe 5's claims. However, today, my counsel a. has advised me that | may not. So ] am going to 12 have -- under their instructions have to assert my 13 Sixth Amendment, Fourteenth Amendment and Fifth } 14 Amendment Rights. Though I'd like to answer that is question, I've been told that if I choose to do so, 16 Lrisks losing their representation and waiving 17 those rights. 18 BY MR. HOROWITZ: 19 Q During the course of Jane Doe 5's visit to your 20 home in 2001 or 2002, did you also touch another 21 underage girl in a sexual manner in the presence of Jane | 22 Doe 5? 23 MR. PIKE: Form. THE WITNESS: Id like to respond to every one UNIVERSAL COURT (954) 712-2600 (877) Page 1846 MR, PIKE: Form. 3 THE WITNESS: I would like to respond to every £ single one of your client's claims. My attorneys if have advised me at least today, I cannot answer any questions that may be relevant to those claims. And, though your partner who filed this lawsuiton ff Miss Jane Doe 5's behalf was disbarred -- suspended E by the Florida Bar -- suspended by the Florida Bar after filing this claim, or Mr. Edwards’, who filed similar claims, partner who sits in jail, I'd like to answer every single question. However, today, my attorneys told me that if I do so, choose to do so, I risk waiving my rights and risk losing their Tepresentation. BY MR. HOROWITZ: Q Mt. Epstein, Jane Doe $ told you when she was in your home that she did not want you to touch her body, isn’t that true? MR. PIKE: Form. E THE WITNESS: I would very much like to answem every question regarding Jane Doe $'s claims, but today my attormeys have informed me that I may not answer, and must assert my rights under the Sixth, Fifth and Fourteenth Amendment. So, though I wouk like to answer those questions, ] -- my attorneys 46 (Pages 181 to 184) REPORTING 291-DEPO (3376)

Page 185 have informed me that if | choose to do so, which is my preference, I would risk losing their representation and waiving my rights. BY MR. HOROWITZ: Q = Mr. Epstein, you made sexual contact with Jane Doe 5 after she indicated to you that she did not want to be touched by you, isn't that right? MR. PIKE: Form. THE WITNESS: I'd like to answer each and every one of your questions regarding Miss Jane Doe 5's claims. However, my attorneys have advised me that today at least, | may not answer those claims, and must assert my tights under the Fourteenth Amendment, Sixth Amendment and Fifth Amendment! And, though as you might imagine, 1 would like to answer those claims with -- questions with specificity, my counsel has told me that if1 choose to do so, | waive - IT might risk losing their representation and waive -- waiving some of my rights. BY MR. HOROWITZ: Q Did you try to persuade Jane Doe 5 that it was okay for you to touch her breasts and genitals while she was still a child? (Videotaped deposition continued in Volume II.) CERTIFICATE STATEOR FLORA} COUNTY OF BROWARD} J, Vicki L. Lima, Court Reporter, Notary Public in and for the Stato of Florida at Large, do hereby authorized ¢o and did report said deposition in stenotype; and that the Poregoing pages are a true and correct transcription of my shorthand notes of said deposition, further certify thar the said deposition was taken at the time and plece hereinabove set forth and that the taking of seid deposition was commenced and completed as hereinabove set out. 1 father cenify thet [ am not an attomey or counsel of any of the parties, nor am 1a relative or employee of any attorney or counsel of ary party connected with this action, aot am [ interested in the action. ‘The foregoing certification of this trmsoript does pot epply to any reproduction of the same by any ‘menns unless under te direct control and/or direction of the certifying reporter. IN WITNESS WHEREOF, | have hereunto set may hand this 22nd day of Merch, 2010. Vicki Cima, Court Reporter ‘Notary Publi¢ » State of Florida ‘Commission No: DD 882608 Expiration Date: May 26, 2013 Job #92076-A, STATE OF FLORIDA ) COUNTY OF BROWARD ) I, the undersigned authority, certify that Jeffrey Edward Epstein personally appeared before me ang was duly sworn. WITNESS my hand and official seal this 22nd day of March, 2010. Vicki L. Cima, Court Reporter Notary Public - State of Florida Commission No: DD 882608 Expiration Date: May 26, 2013 Job #92076-A UNIVERSAL LEGAL REPORTING 888 EAST LAS OLAS BOULEVARD, SUITE 508 FORT LAUDERDALE, FLORIDA 33301 "954} 712-2600 March 22,2010 Sob 2076-4 Volume Jey Edvard Epstein witness Michae! J, Pike, Esquire 308 Banyan Boulevard, Suite 400 ‘West Palm Beach, Ford 33401 RE: Jane Dow No.2 ve, Jelltoy Epstein ‘CASE NO: 98-CV-80119-MARRA/JOBNSON Dear Mr, Epsteia: Plosse take notice that on Mitch 8, 2008, you gave your deposition in the sboveroferred matter, At that time, you did not waive your sgreture. Tt is aow necessary that you siga your deposition, ‘As previously agreed f, the transctipt will be forsishes!1e you through your counsel, Please ead the following initrastions: you vil find an evata sheet. AS you ead yor depcrticn, ey changes or ores Tryout ake shoed be goed onthe enata sheet, ting page aid line numberof sid change, DO NOT oritecn the tanseript itself. Once you have ted ‘he tranecrint nnd noted any changes, be eure to sign see dae th erotssheat and return tbese pages 1 US athe addees listed above. You need not return the cenlire anscrpt, Ifyou do not read and sign the deposition within itty (30) days, tho original, which has alrendy been forwarded 0 the ordering atomey, may be filed withthe Clerk of the Court. If you wish to waive your eigneture, sign your name inthe blank atthe bottom of ‘his lett and retom itt us. Very truly yours, Univereal Legal Ropocting, Vicki Lima ‘Court Reporter - Notary Pubic {bani wale igs a7 (pages 185 to 188) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

ERRATA SHEET IN RE: Jane Doe No. 2 vs. Jeffrey Edward Bpstoin dward Epstein, Volume t DEPOSITION OP: Jeffrey £: TAKEN: March 8, 2010 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGE LINE# CHANGE REASON Plena forward the original signed errata sheet to This ‘office 50 that copies may be distributed to all parties, Under penalty of perjury, I declare that | have read my deposition and that itis rue and correct subject to any changes in fonin or substance entered hese, DATE:, SIGNATURE OF DEPONENT, Jeb 3076-0 UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA, CASE NO: 08-CV-80119-MARRAJOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related Cases: 08-30232, 08-80380,08-80381,08-80994, 08-80993, 08-8081 !,08-80893,09-80469, 09-80591 ,09-80656,09-80802,09-8 2092. VIDEOTAPED DEPOSITION OF JEFFREY EDWARD EPSTEIN VOLUME II (Pages 190 - 335) Monday, March 8, 2010 301 Clematis Street Suite 3000 West Paim Beach, Florida 33401 10:05am. -6:17 pm. Reported By: Vicki L. Lima, Court Reporter Notary Public, State of Florida. Universal Legal Reporting Phone - (954) 712-2600 Job #92076-B APPEARANCES: ‘On behalf of the Plaintiffs, Jane Doe 2 through 8: ‘ADAM HOROWITZ, ESQUIRE. JESSICA D. ARBOUR, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 18208 Biscayne Boulevard Suite 2218 Miami, Florida 33 160 On behalf of the Plaintifis, Jane Doe, LM. and E.W.: BRAD EDWARDS, ESQUIRE FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PLL. 425 North Andrews Avenue: Suite2 Fort Lauderdale, Ftorida 33301 On behalf of the Plaintiff, Jane Doe 103: KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK City National Bank Building 25 West Flagler Stroet Suite 800 Miami, Florida 35130 On behaif of the Defendant and Witness: MICHAEL J, PIKE, ESQUIRE BURMAN, CRITTON, LUTTIBR & COLEMAN 303 Banyan Boulevard Suite 400 ‘West Palm Beach, Florida 33401 JACK A. GOLDBERGER, ESQUIRE. ATTERBURY, GOLDBERGER & WEISS, P.A. One Cleartake Centre, 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 ASO PRESE! Alex Aya Page 192 VOLUME I (Pages 190 - 335) EXAMINATION INDEX JEFFREY EDWARD EPSTEIN CONTINUED DIRECT BY MR. HOROWITZ....... 193 [i EXHIBIT INDEX MAR EXHIBIT 1 VEHICLE AND VESSEL INFORMATION Page 193 (Beginning of Volume II.) MR. PIKE: Form. THE WITNESS: I'd like to answer every question that you posed here today, Mr. Horowitz, regarding any of your clients, and especially Miss Jane Doe 5's claims. However, my attorneys have advised me that at least today, I must assert my rights under the Sixth, Fourteenth and Fifth Amendment, or risk losing those rights or the -- and/or their representation. BY MR. HOROWITZ: Q Did you tell Jane Doe 5 "to relax" and quote, just let it -- let it happen, end quote, when she resisted your sexual advances? MR. PIKE: Form. THE WITNESS: It would give me great pleasure to be able to answer Jane Doe 5's claims. However, my attorneys have advised me today, at least today, that I must assert my rights under the Sixth -~ excuse me -- Fourteenth and Fifth Amendment. And, though I'd very much like to answer those questions, that question, and the other questions you've posed here today, I am going to have to assert those rights and respectfully decline. 1 (Pages 190 to 193) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 194 Q Did you instruct $.K. to take Jane Doe 5's telephone number so you can call Jane Doe 5 to come to your home for more sexual activity? MR. PIKE: Form. THE WITNESS: I'd like to answer each one of your questions, these claims made by Jane Doe 5. However, today at least, my attorneys have advised me that I may not answer any questions that may be relevant to any of the lawsuits brought by you, your partner who's been suspended after he filed Miss Jane Doe 5's claim. He was suspended for improper behavior by the Florida Bar. | may not answer the questions of Mr. Edwards regarding his ~- or his partner, Mr. Scott Rothstein, who was accused of the largest fraud by fabricating cases of 2 sexual nature of against people, me and others, in order to steal millions of dollars from unsuspecting people. So, although I would like to answer those questions, my attorneys have advised me that if I do so, | risk losing their representation and waiving my rights. BY MR. HOROWITZ: Q After Jane Doe 5 visited your home, did you instruct S.K. to call Jane Doe 5 on the telephone to arrange for her to come back for more sexual activity? Page 196 However, my attorneys have counseled me that ] may net. And if I choose to do so, contrary to their advice, 1 risk losing their representation and waiving those rights. BY MR. HOROWITZ: Q Okay. With respect to Jane Doe 5 and the questions that you have asserted your Fifth Amendment privilege, have you been asserting your Fifth Amendment} privilege to protect your innocence, or to conceal your guilt? MR. PIKE: Form. THE WITNESS: That's a question obviously designed to try to embarrass me. {i -- what -- I'd like to answer that question. However, my counsel has advised me that since your firm, your partner who was suspended for improper behavior since he filed this claim, Mr, Edwards’ partner who sits in jail, the Supreme Court has said that people can claim the Fifth Amendment, and should claim the Fifth Amendment who are innocent. 1 respectfully decline to answer, based on my counsel's advice, because they've told me if [ choose to answer, I may waive those rights, but I'd like to answer. BY MR. HOROWITZ: Q Sir, is there any reason you can think of as to Page 195 MR. PIKE: Form. THE WITNESS: I'd like to answer each one of Miss Jane Doe S's claims. I'd like to answer each one with specificity, However, my attorneys have advised me today, that ] must assert my rights under the Fourteenth, Sixth and Fifth Amendment. And if I choose to answer, which is my preference, Trisk losing their representation and waiving those specific rights. BY MR. HOROWITZ: Q Isn't it true, sir, that you sexually abused Jane Doe 5 when she was a child? MR. PIKE: Form. THE WITNESS: I'd very much like to answer that question, as I'd like to answer some of the others, that question in particular, it's been clear that your firm, your partner who's been suspended after filing such 2 claim of sexual abuse, Mr. Edwards’ partner who's in jail for probably the rest of his life, probably the rest of his life for filing just those types of claims, sexual abuse claims, and sexual claims of -- claims of a sexual! nature against people, me and others, to steal money, just -+ it's about money from people in South Florida, so I'd like to answer those questions today. Page 197 why the jury should not infer from your testimony today that you did, in fact, sexually abuse Jane Doe 5 when she was a child? MR. PIKE: Form. THE WITNESS: | believe the jury will be able to see what your firm, Mr. Edwards’ firm, and what the newspapers have referred to as part of the largest fraud in South Florida's history by crafting cases of a sexual nature against people like me and others, simply to get money. His partner sits in jail. Your partner has been suspended. I'd rather -- the jury will make its own decision. BY MR, HOROWITZ: Q > Great. The next individual }'d like to talk to you about is Jane Doe 6, and if you either write that down, or get that name in your head so that you remembe it when I ask you some questions about her, | would appreciate it, okay -THE WITNESS: Mr. Pike -BY MR, HOROWITZ: Q_ -- Jane Doe 6, okay? MR. PIKE: Proceed. BY MR. HOROWITZ: - You don't. that Jane Doe 6 came _ fi 2 (Pages 194 to 197) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 198 to your home in Palm Beach County in August 2004, do you? MR, PIKE: Form. THE WITNESS: I would very much like to ans’ every claim made by your client, Jane Doe 6. However, today, my attorneys have advised that ¥ may not. I must assert my rights under the Sixth, Fourteenth and Fifth Amendment. BY MR, HOROWITZ: Q Now, Jane Doe 6 was only 13 years old when she came to your home; is that right? MR. PIKE: Form. THE WITNESS: Again, it would -- I would prefer to answer every single one of your client's -- Jane Doe 6's claims regarding this case, your claim against me. However, my attorneys have advised me I may not do so today. I must assert my rights under the Fourteenth, Fifth, and Sixth Amendment. Though I would like to answer each one of your questions, Mr. Horowitz, today, I must respectfully decline to do so. BY MR. HOROWITZ: Q Mr. Epstein, you paid for a taxi to bring 13-year-old Jane Doe 6 to your home in 2004; isn't that right? Page 200 today have told me I may not, and must assert my tights, or waive -- potentially waive them, or risk losing their representation -BY MR. HOROWITZ: Q Okay. A -so, unfortunately, ] must respectfully decline to answer that question. Q Did you instruct $.K. to communicate by telephone with E.W. For the purpose of arranging for underage girls to come to your home to give youa ff massage? MR. PIKE: Form. THE WITNESS: I'd like to answer each one of your claims here today with specificity. E.W. represented by Mr. Edwards sitting next to you, represented by the man who's currently sitting in jail for the perpetrating of the largest fraud in Florida's history, for creating fictitious, 4 malicious cases of a sexual nature against wealthy people in order to steal money, steal money. The U.S. Attorney called E.W.'s attorneys a criminal enterprise. So, though I'd like to answer that question, as all your other questions here today, my attorneys have instructed me I may not do so. BY MR. HOROWITZ: NNVONNNE RE RRP REE Re APWYEPOCHBIDAASWNHEOWDIYAUSWNHE Page 199 MR. PIKE: Form. THE WITNESS: I'm sure, Mr. Horowitz, you're aware that I'd like to answer these questions with specificity. I'm sure you're aware that I would like to answer each one of these sexually charged questions, questions similar to the ones you've asked before. | have to respond in a similar way, which unfortunately, my counsel has advised me I must take their advice, which is to claim the Sixth, Fifth and Fourteenth Amendment Rights, because by not doing so, I may waive those rights, or risk losing their representation. BY MR. HOROWITZ: Q_ In 2004 did you receive a phone call from a girl named E.W, in which she told she was bringing Janq Doe 6 to your home for a massage? MR. PIKE: Form. THE WITNESS: E.W,? I believe E,W. is represented by the man sitting next to you, Mr. Edwards, though Mr. Edwards' partner, the one who's in jail for bringing cases of a sexual nature, sexually charged nature against people like me and others, so, though I'd like to answer all your questions regarding E.W., and like Miss Jane 25 THE WITNESS: Okay. I would like fo answer the E Page 2018 Q Mr. Epstein, you paid E.W. to bring underage girls to your home so you could engage in sexual activity with these girls; isn't that right? MR. PIKE: Form, THE WITNESS: Again, E.W. represented by Mr. Edwards’ firm, and former -- her former attorney, Mr. Scott Rothstein, sits in a county jail probably for the rest -- weil, at least a 9 federal jail for the rest of his life for SIH FEWne 10 fabricating cases of a sexual nature against a. wealthy people in South Florida in order to steal 12 money from unsuspecting investors. It would give 13 me pleasure to be answer -- to be able to answer 14 your questions today with specificity. However, my 15 attorneys have counseled me that at least today, I 16 may not do so -- excuse me -- without waiving my 7 tights and risking their representation -~ risk 18 losing their representation. 19 BY MR. HOROWITZ: 20 Q Mr. Epstein, in 2004 did you instruct S.K. to could be made for Jane Doe 6 to come to your home for 23 your sexual gratification? i 24 MR. PIKE: Form. [i 3 (Pages 198 to 201) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 202 claims of Jane Doe 6. I would very much like to answer the claims of your -- Mr. Edwards' E.W. It would be nicer if Mr. ~ or I would appreciate it -- unfortunately -- but Mr, Edwards's partner who represented E,W. along with him is in jail for misrepresenting -- or the U.S. Attorney has called his firm a criminal enterprise, the one representing -- previously representing E.W. You represent Jane Doe 6. I'd like to answer her claims, but today my attorneys have counseled me that I must respectfully decline and assert my rights under the Fourteenth, Sixth and Fifth Amendment. BY MR. HOROWITZ: Q Did you inform S.K. that the massage that Jane Doe 6 was to give you would be sexual in nature? MR. PIKE: Form. THE WITNESS: Unfortunately, I] am going to have to respond to that question the way I've responded to most of your questions and claims here today regarding Jane Doe 6 and some of your other clients that you filed suits for, post filing the suit your partner was suspended by the Florida Bar, post filing the suit Mr. Edwards' partner finds himself in jail. Page 203 So, though I'd very much like to answer those questions, my attorneys have counseled me today that I cannot answer, at least today, any questions relevant to these lawsuits. And if] decide or choose to answer the questions, I risk losing their representation and waiving those rights, Excuse me, Adam, five? THE WITNESS: Yeah, if you need it. THE VIDEOGRAPHER: Time off the record 3:02. (Thereupon, a short break was taken.) BY MR, HOROWITZ: Q DidyouTHE VIDEOGRAPHER: Time on the record 3:12. BY MR. HOROWITZ: Q Mr. Epstein, we're still talking about Jane Doe 6, okay? A Yes, Q Mr. Epstein, did you observe S.K. speaking with E.W. by telephone and making arrangements for Jane Doe 6 to come to your home to give you a massage? 4. I'd like to answer that question. I'd like to answer all your questions here today. I believe Miss E.W. is represented by Mr. Edwards, who's partner is in jail for his wrongdoing, for creating cases of sexually charged natures. You're as i Page 204 Dee 6's claim, which I would like to answer, but today, under advice of counsel, they have instructed me that I may not, and | should claim my Sixth Amendment, Fourteenth Amendment and Fifth Amendment Right. BY MR. HOROWITZ: Q > Did you confirm with S.K. that she did, in fact, speak with E,W. by telephone to confirm a specific time that Jane Doe 6 would be at your house? MR. PIKE: Form. | THE WITNESS: I'd like to answer each and every one of your questions, Mr. Horowitz, regarding the claims of these - of Jane Doe 6 and E.W. However, today, on advice of counsel, I am going to have to simply claim the Fifth, Sixth and Fourteenth Amendment Right. BY MR. HOROWITZ: Q > Was it your intent during the course of Jane Doe 6's visit to your home that you would persuade, induce or entice her to engage in sexual activity? A I'd like to answer every question you've asked me here today, every single question, especially with respect to Jane Doe 6's claims. However, my attorneys have instructed me that I must assert my rights under E the Sixth, Fourteenth and Fifth Amendment. Though thes# claims of a sexual nature are not that surprising since sits in jail for perpetrating what the U.S. Attomey called the largest fraud in South Florida's history, stealing millions of dollars from unsuspecting local investors. I'd very much like to answer each and every one of your questions, but my attorney has told me that if | choose to do so, | risk waiving my rights and risk losing their representation. MR. PIKE: I-THE WITNESS: Sorry. MR. PIKE: -- object to form to that question. BY MR. HOROWITZ: Q During the course of Jane Doe 6's visit to your home, did you succeed in persuading, inducing or enticing her to engage in sexual activity with you? MR. PIKE: Form. E THE WITNESS: | would very much like to answer every single question and claim of Jane Doe 6. L However, today, my attorneys have advised me that I may not. { must assert my rights under the Sixth, Fourteenth and Fifth Amendment. Now, | prefer to answer. They've told me that if choose to do so, } risk losing their representation and waiving those rights. BY MR. HOROWITZ: 4 (Pages 202 to 205) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 206 Q Allright. Did S.K. tell you that she spoke to anyone on the phone who arranged for Jane Doe 6 to coma to your house? MR, PIKE: Form. THE WITNESS: Again? I'm sorry, Mr. Horowitz. BY MR. HOROWITZ: Q Did S.K. tell you she spoke to anyone on the phone -- on the phone to make arrangements for Jane Doe 6 to come to your home? MR, PIKE: Same objection. THE WITNESS; I'd very much like to answer every question regarding these claims here today. However, my attorneys have advised me that at least today, 1 must assert my rights under the Fourteenth, Sixth and Fifth Amendment. And though I prefer to answer the question, if 1 choose to do so, | risk losing those tights and their representation. BY MR. HOROWITZ: Q Okay. You asked Jane Doe 6 how old she was when she came to your home; is that right? MR. PIKE: Form. THE WITNESS: Again, like the other questions you've asked me regarding your claims of Jane Doe 6, I'd like to answer each one. However, today, my Page 208 BY MR. HOROWITZ: E Q. Sir, when Jane Doe 6 came to your home in 2004 when she was 13 years old, you didn't, in your own mind, believe her to be 18 years old or older, did you? MR. PIKE: Form. ‘THE WITNESS: Repeat the question, please? BY MR. HOROWITZ: Q Sure. When you looked at Jane Doe 6 at age 13 and she was in your home, you didn't believe her to be 18 years old or older, did you? THE WITNESS: I'd like to answer each one of your -MR. PIKE: Same objection. l: THE WITNESS: -- excuse me. I'd like to answer |, each one of your claims today, However, my attomeys have counseled me that I may not. They have instructed me to assert my rights under the Fourteenth, Sixth and Fifth Amendment. ‘Though I'd like to answer each one of those questions, I'd like to answer that question directly to your partner, Jeffrey Herman, that in fact brought this claim, but he has been suspended by the Florida Bar, or the claims directly to Mr. Edwards' partner who sits in jail for fabricating cases of a sexual nature against Page 207 attorneys have advised me that I may not. I must assert my rights under the Sixth, Fourteenth and Fifth Amendment. Though I prefer to answer that question, 1 prefer to answer that question directly to the -- your partner that brought this claim, but I guess he's been suspended or disbarred by the Florida Bar, or I'd like to answer it to Mr. Edwards' partner who sits in a jail for crafting, fabricating malicious claims simply to get money. I'd very -- as you probably recognize, I'd like to answer those questions today, but I -under the instructions of counsel, | must respectfully decline. BY MR. HOROWITZ: Q_ Sir, there was never a point in time when Jane Doe 6 told you that she was 18 years old or older; isn't that right? MR. PIKE: Form. THE WITNESS: Like all your other questions regarding Jane Doe 6 and her claims, I'd very much like to answer each and every one, However, today, my counsel has advised me that I may not, and must: assert my rights under the Fourteenth, Fifth and Sixth Amendment. And if I choose to never, Trisk dosing their < counsel and wai Page 209 wealthy people in South Florida. T'd very much like to answer, but according to my counsel I may not answer those, or I may waive my rights or risk losing their representation. BY MR. HOROWITZ: Q During the course of Jane Doe 6's visit to your home in 2004, were you nude in her presence? MR. PIKE: Form. THE WITNESS: I'd very much would like to answer each and every question regarding Jane Doe 6's claims. However, my attorneys have told me today that | may not. I must assert my rights under the Fourteenth, Sixth and Fifth Amendment, Though I prefer to answer, I'm told that if I choose to do so, | risk losing their representation and waiving those rights. BY MR. HOROWITZ: Q During the course of Jane Doe 6's visit to your home in 2004, did you instruct Jane Doe 6 to remove her: clothing? [: MR. PIKE: Form. THE WITNESS: I'd like to answer each and ever one of your questions here today and the claims of £ Jane Doe 6. However, my attorneys have advised mei at least today, that 1 must assert ny | rights u under 5 (Pages 206 to 209) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

she made attempts to walk away from you during her visit Page 210 Page 212] 1 the Fourteenth, Sixth and Fifteenth -- and Fifth 1 MR. PIKE: Form. 2 Amendments of the U.S, Constitution. Though I 2 THE WITNESS: I'd very much like to answer each| 3: prefer to answer, they've instructed me that if I 3 and every one of Jane Doe 6's claims. However, my 4 choose to do so, I risk waiving those rights and 4 attorneys today have instructed me that I may not 5 losing their representation. 5 answer today, and that I must assert my rights 6 BY MR. HOROWITZ: 6 under the Sixth, Fourteenth and Fifth Amendment. if 7 Q During the course of Jane Doe 6's visit to your 7 ‘Though I'd like to answer the question, they've E 8 home in 2004, did you instruct Jane Doe 6 to pinch your! 8 —_ instructed me that if do, I risk losing their 9 nipples and rub your chest? 9 representation and waiving those rights. 10 MR. PIKE: Form. 10 BY MR. HOROWITZ: 11 THE WITNESS: As I've answered most of your | 11 Q_ In 2004 did you rub Jane Doe 6's vagina? 12 other questions here today, Mr. Horowitz, it would 12 MR. PIKE: Form, E 13 give me great pleasure to be able to answer these 13 THE WITNESS: That question, like most of your 14 claims of Jane Doe 6. However, my attorneys have 14 other questions here today, I would prefer to 15: instructed me that 1 may not, and that I must 1s answer. I'd like to answer. I'd like to answer 16 assert my rights under the Fourteenth, Sixth and 16 directly to your partner who is no longer here q 17 Fifth Amendment because they told me that if I do 17 because he's been suspended after he filed this 18 so, 1 risk losing their representation and waiving 18 claim, suspended by the Florida Bar for filing -- iE 19 those rights. 19 not for filing, but after he filed the claim. I 20 BY MR. HOROWITZ: 20 prefer to answer directly to Mr. Edwards' partner 21 Q During the course of Jane Doe 6's visit to your 21 who sits in jail for the rest of his life, for the L 22 home in 2004, did you ask Jane Doe 6 about her sexual | 22 rest of his life, for filing and misleading -- a 23 experience and preferences? 23 filing malicious claims, make -- fabricating claims — / 24 MR. PIKE: Form. 24 against people like me and others in South Florida, ; 25 THE WITNESS: It would give me great pleasure | 25 stealing money — millions of dollars from ql Page 211 Page 213} 1 to answer each one of your questions and Jane Doe di investors. So I would like to answer each one of 2 6's claims. However, my attorneys have instructed 2 your questions with specificity. However, my 3 me today that 1 may not, and that 1 must assert my 3 attorneys have advised me today that I may not. 4 rights under the Sixth -- excuse me --Fifth and 4 BY MR. HOROWITZ: 5 Fourteenth Amendment. Though I would prefer to 5 Q In 2004 -- in 2004 did you masturbate by 6 choose to answer those questions, my attorneys have 6 stroking your penis in front of Jane Doe 6? 7 advised me that if I do so, I risk losing their 7 MR. PIKE: Form. E 8 representation and waiving those rights. 8 THE WITNESS: I'd like to answer each one of 9 BY MR. HOROWITZ: 9 your questions regarding Jane Doe 6's claims. E 10 Q In 2004 did you touch Jane Doe 6's breasts? 10 However, my attorneys have advised me that today Ik 1. MR. PIKE: Form, iL may not. And though your partner has been R 12 THE WITNESS: Like many of your other questions 12 suspended after he filed this claim, Mr. Edwards' 13 here today, there be -- I'd very much prefer to 13 partner sits in jail, my attorneys have advised me ff 14 answer that question, as your other questions with 14 still that I must assert my rights under the q 15 specificity. However, my counsel has advised me 15 Fourteenth, Sixth and Fifth Amendment. And if] 16 that F may not. 1 must assert my rights under the 16 choose to answer, which is my preference, that I E 1? Fourteenth, Sixth and Fifth amendment. So though L 17 tisk losing their representation and/or waiving R 18 choose ~ would choose to answer that, my attorneys 18 those rights. 19 told me that if I do, I risk losing their 19 BY MR. HOROWITZ: 20 representation and potentially waiving those 20 Q 2004 did you ejaculate after stroking the at tights. 21 shaft of your penis in front of Jane Doe 67 i 22 BY MR. HOROWITZ: 22 MR. PIKE: Form. E 23 Q Did you touch Jane Doe 6's breasts even after 23 THE WITNESS: I'd like to answer each one of [f Jane Doe 6's claims, and all the questions -- each UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 214 Page 216 1 like to answer it directly to your partner. 1 as well as every other question you've asked me 2 However, he's been suspended by the Florida Bar 2 here today, but I'm going to have to respond in a 3 after he filed this claim. I'd like to answer it 3 similar manner to the other questions, which is 4 directly to Mr. Edwards’ partner who sits in jail 4 though I'd like to answer the question, my counsel 5 for fabricating cases of a sexual nature against 5 here has advised me that I may not, and must assert 6 wealthy people in South Florida, in jail 6 the rights under the Sixth, Fourteenth and Fifth 7 potentially for the rest of his life. So though 7 Amendment; otherwise, risk losing their 8 I'd like to answer those questions, my attomeys 8 representation and/or waiving those rights. 9 have counseled that I may not. | must assert those 9 BY MR. HOROWITZ: 10 rights or risk losing their representation and/or 10 Q Did you ever ask Jane Doe 6 for permission to a1 waiving those rights. 11 touch her breasts? 12. BY MR. HOROWITZ: 12 MR. PIKE: Form. i 13 Q In 2004 did you walk across the room naked and} 13 THE WITNESS: These claims of Jane Doe 6 would: 14 — enter a shower in front of Jane Doe 6? 14 give me great pleasure to answer, especially with b 15 MR. PIKE: Form. 15 specificity with Jane Doe 6, your client. It's 16 THE WITNESS: Again, as I've answered most of 16 unfortunate that your partner couldn't be here to 17 your questions here today, it would give me great 17 hear some of these responses since he's been 18 pleasure, in fact, to answer the claims of Jane Doe 18 disbarred - no, not disbarred -- you've corrected 19 6. However, my attomeys have advised me that I 49 me -- he's only been suspended by the Florida Bar 20 may not, and must assert my rights under the Sixth, | 20 for improper behavior after he filed this case. 21 Fourteenth and Fifth Amendment. Though I prefer td 21 Mr. Edwards's partner sits in jail. Though 'd 22 answer those questions, my attomeys have told me {| 22 like to answer -- as you might imagine, I'd like to 23 that if I choose to de so, I risk losing their 23 answer these questions. My counsel has advised me 24 representation. And J would prefer to tell your 24 that if I do so, [ risk losing his representation. 25 partner directly who filed this claim, who's 25 BY MR. HOROWITZ: Page 215 Page 217 a subsequently suspended by the Florida Bar. I would 1 Q Isn't it true, sir, that Jane Doe 6 indicated 2 prefer to tell Mr. Edwards’ partners, but he's in 2 to you that she did not want you to touch her body? 3 jail with now -- I guess most of his other -- many 3 MR. PIKE: Form. 4 of his other partners are on their way for filing 4 THE WITNESS: It would give me great pleasure} 5 malicious claims. So though I'd like to answer 5 to answer each question and claim of Jane Doe 6 and| 6 that question, Mr. Horowitz, here today, I must 6 your client. However -- excuse me -- however, my 7 respectfully decline to do so. 7 counselors advised me today that ] may not, and 8 BY MR. HOROWITZ: 8 must assert my rights under Sixth, Fourteenth and g Q Did you have sexual contact with Jane Doe 6 at 9 Fifth Amendment. 10 -your Palm Beach home in 2004? 10 BY MR. HOROWITZ: 11 MR. PIKE: Form. 1L Q Isn't it true, sir, that you touched Jane Doe 12 THE WITNESS: I would like to answer each and| 12 _ 6's breasts after she indicated to you that you did not 13 every claim of Jane Doe 6 and all your other 13 -- that she not want you to touch her? 14 clients. It would be -~ give me pleasure to be 14 MR. PIKE: Form. 1s able to answer those questions directly to your 15 MR. HOROWITZ: Lam going to clean up that 16 partner, but he's been suspended after he filed 16 question. I probably didn't ask it right. 17 these claims. I must assert those rights, even 17 BY MR, HOROWITZ: 18 though | would prefer to answer the question, or 18 Q Isn't it true, sir, that you touched Jane Doe 19 tisk losing the representation of my counsel and 19 — 6's breast after she indicated she did not want you to 20 inadvertently waiving those rights. 20 touch her? 21 BY MR. HOROWITZ: 21 MR. PIKE: Form. 22 Q Did you pay $200 to Jane Doe 6 after having had} 22 THE WITNESS: I'd like to answer that question, |i 23 sexual activity with her? 23 like every other question you've asked me here E MR. PIKE: Form. today, mostly every question. It's unfortunate I THE WITNESS: Id like to answer that question, UNIVERSAL COURT (954) 712-2600 (877) can't make that answer directly to your partner who [ 7 (Pages 214 to 217) REPORTING 291-DEPO (3376)

Page 218 Page 220} was suspended by the Florida Bar, or Mr, Edwards’ 1 prostitute, and an admitted prostitute of partner who sits in jail. But though I'd like to 2 Mr. Edwards! who sits there while his partner stays answer those questions, my counsel has advised me I} 3 in jail -- yes, he finds it, I guess, very funny. must assert my rights under the Sixth, Fourteenth 4 I don't find it that funny, and Fifth amendment, So though I'd like to answer; 5 Well, I'd like to answer each one of the it would be my preference to answer. He's told me 6 questions about Miss E.W. and Miss Jane Doe 6. that if { do so, I risk losing his representation 7 However, my attorneys have told me today that I mayj and/or waiving those rights. 8 not, and that I must assert my rights under the ki BY MR, HOROWITZ: 9 Sixth, Fourteenth and Fifth Amendment. So, though £ Q Mr, Epstein, did you try to persuade 13-year- 10 I'd like to answer all the questions regarding ways & old Jane Doe 6 that it was okay for you to touch her 1 that these girls are trying to get money, be it breast and masturbate by stroking your penis in front of} 12 from me, or from Mr. Rothstein's other victims, I her? 13 must assert those rights, or, in fact, according to MR. PIKE: Form. 14 my counsel, lose ~ risk losing his representation THE WITNESS: Mr. Horowitz, it would give me} 15 and waiving those rights. great pleasure to answer every one of Jane Doe 6's 16 MR. PIKE: All right. Now, that -- now, that claims, every one. However, my counsel has advised; 17 Mr. Epstein is done answering that particular me I may not do so today, and that I must assert 18 question and responding, do we -- do we need a those rights. I would much prefer to answer it to 19 break, because I'm -- !'m not comfortable with the your partner who filed this claim, Mr. Jeffrey 20 way in which the laughing is going forward and Herman, but he's been suspended by the Florida Bar | 21 things of that sort? after he filed this claim for improper behavior, or 22 MR. EDWARDS: Okay. Weil, I-- I found that Mr. Edwards’ partner who sits in jail after he 23 answer pretty funny, and I want to make sure that I filed their claims. So though I'd prefer -- 1 24 understand the answer so that I know if I have to would like to answer, my counsel has advised me 25 take any legal action whatsoever. What I Page 219 Page 221} that if 1 choose to do so, | risk losing his 1 understand the answer to be was that Mr. Epstein is [ representation and/or waiving those rights. 2 making the accusation now that E.W. is my BY MR. HOROWITZ: 3 prostitute. That's -Q Okay. Sir, you don't deny that you sexually 4 THE WITNESS: Ob, no, that's not correct. abused Jane Doe 6 when she was a child, do you? 5 MR. EDWARDS: -- that's what I heard, right? MR. PIKE: Form. 6 That's what everybody in the room heard. THE WITNESS: The question about sexually 7 MS. EZELL: That's -- that's -- that's what I abusing, which was in fact one of the cases that 8 beard. Mr. Rothstein's -- I mean, Scott Rothstein's -- 9 MR. PIKE: Okay. First of all ~ Mr. Edwards sits there - Mr. Rothstein sits in 10 MR. HOROWITZ: That's what I heard. jail for his accusing people of sexual harassment, al MR. EDWARDS: That is not true. sexual abuse, and in order to steal money from 12 MR. PIKE: -- I'll tetl you what, we're going local Florida investors. I'd like to answer every 13 to take a break -- we're going to take a break question about Jane Doe 6's claim of sexual abuse. 14 now. That is not the way that | interpreted the However, my counsel today has informed me that 1-4 15 response. The response was that she made a -I may not answer today. And though as you might 16 she's an admitted prostitute, and that she was a guess, I'd like to answer those questions, he's 17 client of yours. If we're going to be playing informed me if 1 choose to do so, I risk losing his is games with semantics, then we will do that at representation and/or waiving those rights. 19 another date by motion practice, but we're not BY MR. HOROWITZ: 20 going to -- this is not the form in which to do Q_ Sir, did you pay E.W. for bringing Jane Doe 6 21 this, laughing, playing games with words. to your home in 2004? 22 Everybody in this room knew exactly what the i MR. PIKE: Form. 23 response was. And remember something, this is -THE WITNESS: I -- if E.W. -- so I'm clear, 1 believe E.W. has filed a claim as an admitted | MR. EDWARDS: Right, it is -MR. PIKE: Remember something this is a case, 8 (Pages 218 to 221) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

worwouswne Page 222 and you represent someone, and as a result, no 1 matter which way you interpret some response, there | 2 are various privileges that attach to litigation, 3 If you want to threaten legal action here in 4 this form, then you can go ahead and do so on 5 record. So is that what you were doing? 6 MR. EDWARDS: Well ~ 7 MR. PIKE: Were you threatening -- were you a threatening -- want to be clear -- 9 MR. EDWARDS: If-- 10 MR. PIKE: -- in this deposition right now, 11 were 12 MR. EDWARDS: Oh, I'll be very clear. 413 MR. PIKE: -- were with threatening Mr. Epstein | 14 with legal action? 45 MR. EDWARDS: If the accusation is that E.W. is| 16 a prostitute of mine, then I want to know that that 17 is the —- the allegation, and that is clearly his 18 position, so that if fegal action is to be taken, 19 it can be, but I was giving him a chance to clarify 20 that or correct that, if that was not the correct 21 interpretation, but that's what everybody in the 22 room heard. That's what's going to be very clear 23 onthe record, Ms. Ezell is nodding her head. 24 Everybody heard ~~ 25 Page 224 ~ if I misspoke, I apologize. Your client is an admitted prostitute, and that's what I meant to say. MR. HOROWITZ: Okay. Move to strike. Okay. MR. PIKE: Wait, wait. Hold on one second. MR. HOROWITZ: -- 1 know you want to take a break, but -MR. PIKE: No, I -- [~ I don't want to take a -- you just moved to strike something that we just spent seven minutes going back and forth with pursuant to Mr. Edwards’ request. Do you want to withdraw that? MR. HOROWITZ: No. But if you want to -- no. MR. PIKE: Okay. All right. Next question. BY MR. HOROWITZ: Q Mr. Epstein, we've been -- we've been talking i about Jane Doe 6 a bit, and you've mentioned names like Jeffrey Herman and Scott Rothstein. Are you suggesting |f that in any way her allegations of sexual abuse were fabricated or embellished by virtue of her attorney or -- or somehow through Mr. Rothstein's dealings? MR. PIKE: Form. THE WITNESS: It's been validly reported that Mr. Rothstein crafted, fabricated malicious Page 223 MR. PIKE: Listen -- 1 MR. EDWARDS: -- that statement or sentence. 2 MR. PIKE: -- this -- 3 MR. HOROWITZ: Can we -- can we move on? 4 MR, PIKE: No, we can't. Once again -- 5 MR. HOROWITZ: It's not your deposition. 6 THE REPORTER: Wait a second. 7 MR. PIKE: Once again, this is not -- 8 MR. EDWARDS: Let's read it back. 9 MR. PIKE: No, we're not going to reread it. 10 We're not going to go back and reread it, iL Mr. Epstein not only answered the question, but | 12 then he also corrected you and said that was not 13 the appropriate response. 14 MR, HOROWITZ: Okay. 15 MR. PIKE: Now, if you would —- 16 MR. HOROWITZ; That's fine. 17 MR. PIKE: Now, if you would, you can rephrase} 18 your response briefly to -~ 19 THE WITNESS: Mr. Edwards represents an 20 admitted prostitute, E.W. These claims are made by} 21 admitted prostitutes. They filed claims under a 22 section of the Florida's law of admitted prostitutes. So the claims here that -- it was his client as op posed to his prostitute, and] --ifl = Page 225 lawsuits of a sexual nature in order to steal millions of dollars from local Florida investors, With respect to any question with -- that may be relevant to this lawsuit. However, my attorneys have advised me today that I must respond by taki the Sixth, Fourteenth and Fifth Amendment. Though I choose to -- I would prefer to answer the questions, Mr. Horowitz, that you've asked me regarding your claims -- your client's claims, my attomeys have told me that if I choose to do so, 1 risk losing their representation and waiving those rights. BY MR. HOROWITZ: Q Allright. Are -- 1 want to be clear about this one. Are you — A Okay. Q_ -- suggesting that Miss Jane Doe 6 in any way fabricated or embellished her claim after retaining an attorney? MR. PIKE: Form, asked and answered. E THE WITNESS: The partner of -- your partner fF; has been suspended from the practice of -~ Florida} Bar practice after he filed Jane Doe 6's claim. Mr. Edwards’ partner, Scott Rothstein, sits in 1 probably for the rest of his life for [ 9 (Pages 222 to 225) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291~DEPO (3376)

Page 226 Page 228 [i THE WITNESS: I think -- 1 -- Mr. Horowitz, to assume simply that I'm asserting my Fifth Amendm ont 1 fabricating malicious claims of a sexual nature L privilege as anything but the rights of an 2 against wealthy people in South Florida. 2 American, to assert rights under the Constitution, 3 I'd like to answer your questions with more 3 I find disturbing. I find it disturbing that your 4 specificity. However, my attorneys have counseled 4 partner who's been suspended, the claims of your 5 me that I may not today; I must assert my rights 5 clients, Mr. Edwards' client -- whose partner and 6 under the Fourteenth, Sixth, Fifth Amendment. And 6 his law firm -- his partner in jail and his law E 7 1 -- though I choose -- prefer to answer those 7 firm that's been called by the U.S. Attorney as the i 8 questions, Mr, Horowitz, my attorney said that ifT 8 largest criminal enterprise, or the largest fraud H 9 choose to do so, I risk losing their representation 9 in South Florida's history. 1 -- I find it q 10 and waiving those rights, 10 disturbing that you'd question the reasons | would / 11 BY MR. HOROWITZ: aL assert my Constitutional rights. le 12 Q > Given that you have asserted your Fifth 12 BY MR. HOROWITZ: ; 13 Amendment privilege, is there any reason a jury should] 13 Q_ Okay. And you're -- but you're -- you're l 14 not infer from your testimony that you did in fact 14 — refusing to tell us why you're asserting the Fifth 15 sexually abuse Jane Doe 6 when she was just a 13-year} 15 Amendment; is that right? 16 old girl? 16 A I've answered your question. d 17 MR, PIKE: Form. 17 MR, PIKE: It's attorney-client work product. E 18 THE WITNESS: The Fifth Amendment, of my 18 MR. HOROWITZ: How much time left on the tape’ 19 understanding, is to be used as well to protect 19 THE VIDEOGRAPHER: Nine minutes on this tapel! 20 innocent people from claims, from malicious claims, 20 MR. HOROWITZ: Nine minutes. Do you want to } 21 from malicious false claims, including those made ai change tapes? i 22 by Mr. Edwards' partner, Scott Rothstein, who sits 22 MR. PIKE: Yes. E 23 in jail at the moment probably for the rest of his 23 MR. HOROWITZ; Let's change tapes because -- ; 24 life for crafting these malicious false claims. 24 THE VIDEOGRAPHER: Time off the record 3:41. 25 The U.S Attorney called his firm one of the largest { 25 MR. HOROWITZ: Great. E Page 227 Page 229 1 criminal enterprises in South Florida's history. I 1 (Thereupon, a short break was taken.) i 2 will be -- my -- I would prefer to answer your 2 THE VIDEOGRAPHER: Time on the record 3:47, 4 3 questions with specificity, but my counsel today 3 This is Tape 5. Is 4 has told me that I may not, and I must -- excuse me 4 BY MR, HOROWITZ: fe 5 ~~ assert my rights under the Sixth, Fourteenth and 5 Q Mr. Epstein, my next series of questions 6 Fifth Amendment, Though I prefer to answer those 6 involves a -- one of our clients by the name of Janc Doe 5 7 questions, he's advised me that if I choose to do 7 7. You may know her as Jane Doe 7 as well. So if you H 8 so, I risk losing those rights and losing his 8 can either write that name down or keep it in your mind 9 representation. 9 so we're on the same page as to who -- who we're talking. 10 BY MR.HOROWITZ: 10 — about, I would appreciate it, okay? al Q_ In this case are you asserting the Fifth a1 A_ (Witness complying). 12 Amendment in order to protect your innocence or to 12 Q Isn't it true that a girl named Jane Doe 7 came 13 conceal your guilt? 13 to your home on multiple occasions between 2003 and Mayfi 14 MR. PIKE: Iam going to instruct him not to 14 of 20057 5 15 answer that question. It’s attorney-client work 15 MR. PIKE: Form. 16 product. 16 THE WITNESS: I'd like to answer your -- those 17. BY MR. HOROWITZ: 17 questions ~~ excuse me -- Mr. Horowitz, but today 18 Q Isn't it true, sir, that you're asserting the 18 my attorney has counseled me that I must assert my 19 Fifth Amendment privilege here to conceal your own 19 Sixth Amendment, Fourteenth Amendment and Fifth 20 wrongdoing? 20 Amendment Right. 21 MR. PIKE: Same objection. 21 BY MR, HOROWITZ: 22 THE WITNESS: May I answer? 22 Q Prior to May of 2005 did you receive a phone 23 MR. PIKE: This one, yeah. 23 call from a girl named H.R. advising you that she was bringing Jane Doe 7 to your home to give you a massage? |; UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 230 THE WITNESS: I'd like to answer every one of the claims of your clients today. However, my attorneys have counseled me that today at least, that 1 must simply assert my Fifth, Sixth and Fourteenth Amendment Right. BY MR. HOROWITZ: Q At any time prior to 2005 did you instruct $.K. -- strike that. At any time prior to 2005 did you instruct $.K. to communicate with H.R. by telephone to arrange for Jane Doe 7 to come to your home for a massage in which} you would pay her money? MR. PIKE: Form. THE WITNESS: I would very much like to answet each and every question you've asked me here today, but like many of your other questions, I am going, to have te assert my Fourteenth -- excuse me -Fourteenth, Fifth and Sixth Amendment Rights as advised by my counsel. Though | choose and prefer to answer that question, my attomey said that if 1 do so, Erisk losing their counsel and waiving those rights. BY MR. HOROWITZ: Q Did you inform $.K. that the massage Jane Doe 7 was to give you would be sexual in nature? wOvwaReawne . BY MR. HOROWITZ: Page 232, Q Atany time prior to May 2005 did you confirm — with S.K, that she had spoken to Jane Doe 7 by telephone [: and that Jane Doe 7 would be coming to your home to gi you a massage? MR. PIKE: Form. THE WITNESS: I'd very much like to answer every one of Jane Doe 7's claims with specificity, but unfortunately, like many of your other questions today, Mr. Horowitz, my attorneys have counseled me that ] may not answer any questions that may be relevant to a lawsuit, or any of your lawsuits. Unfortunately, your partner after he filed this lawsuit was suspended by the Florida Bar, so he's not here, Mr. Edwards's partner, who sits in jail, is not here. So these claims of a sexual nature would give me great pleasure to be able to answer with specificity, but I'm told that if I choose to do so today, my -- I risk losing the representation of my counsel and waiving my rights. BY MR. HOROWITZ: Q Was it your intent during the course of Jane Doe 7's visit to your home, that you would either persuade, induce or entice her to engage in sexual Page 231 MR. PIKE: Form. THE WITNESS: I'm sure the claims of sexual ~ the claims -- the sexual claims made by your client, Jane Doe 7, that would give me great pleasure to answer with specificity. However, today, I may -- J cannot do so on advice of my counsel who's instructed me to assert my Fifth, Sixth and Fourteenth Amendment Right. He told me that if I choose to answer those questions, which is my preference, that | would risk losing his representation and waiving those rights. BY MR. HOROWITZ: Q Did you observe S.K. speaking with H.R. by telephone while making arrangements for Jane Doe 7 to come to your home for a massage? MR. PIKE: Form. THE WITNESS: [ would very much like to answe: each and every one of your questions today especially with respect to Jane Doe 7 and her claims. However, today, on advise of my counsel, they've asked me to assert my Fourteenth, Sixth and Fifth Amendment Rights. So, though I'd prefer to answer those questions, I'm toid that if I choose to do so, I risk losing their representation and waiving those rights. Page 233; activity with you? MR. PIKE: Form. THE WITNESS: I'd very much like to answer every one of Jane Doe 7's claims with respect to any sexual nature of any of her claims. However, my attorneys have counseled me that today at least, I may not, and must assert my rights under the f Fifth, Fourteenth and Sixth Amendment. And thought I'd prefer to answer those questions, they've told li me that if 1 choose to do so, I risk losing those rights and their representation. BY MR. HOROWITZ: Q During the course of Jane Doe 7's visits to your home, did you succeed in persuading, inducing or enticing her to engage in sexual activity with you? MR. PIKE: Form. THE WITNESS: Mr. Horowitz, I'd like to answet each and every one of your questions posed here, today, but like most of the other questions, ] am going to have to answer the same way because my attorneys have counseled me that I must assert my Fifth, Sixth and Fourteenth Amendment Rights. Though I prefer to answer those questions, and I'd be ~ much prefer the fact to answer it to your partner who filed this claim agai 11 (Pages 230 to 233) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 234 been suspended since filing a claim by the Florida bar. I would also like to speak directly to Mr. Edwards' partner, but he's in jail for falsifying claims of a sexual nature against wealthy people, stealing investors' monies and from people in South Florida, and Mr. Edwards’ firm being accused by the U.S. Attorney of being a criminal enterprise, and perpetrating one of the largest frauds in South Florida histories by just these types of cases. BY MR, HOROWITZ: Q Mr. Epstein, you asked Jane Doe 7 how old she was in 2003; isn't that right? MR. PIKE: Form. THE WITNESS: I would tike to answer each and every one of your questions, Mr. Horowitz. However, today, my attorneys have counseled me that} I may not answer any questions that may be relevant to any of your lawsuits, so | must assert my Fifth, Sixth and Fourteenth Amendment Rights. And thougl I would prefer to answer those questions, each question, my attorneys have told me that if 1 choose to do so, [risk losing their representation and waiving those rights. Page 236% BY MR. HOROWITZ: Q Jane Doe 7 told you she was in school at Royal Palm Beach High School; isn't that true? MR. PIKE: Form. THE WITNESS: As most of your other questions !! here today, Mr, Horowitz, I'd like to answer all of those questions, each question, especially with respect to Jane Doe 7. However, my attorneys have counseled me that at least today, [ must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Because though J prefer to answer the [f questions, they have told me that if I choose to do so, I risk losing their representation and/or waiving those rights. BY MR. HOROWITZ: Q Prior to May of 2005 were you ever nude in front of Jane Doe 7? MR. PIKE: Form. THE WITNESS: Id like to answer each one of Jane Doe 7's claims, each one specifically. However, today, my attorneys have counseled me tha I may not, and that I must assert my Fourteenth -my Fourteenth, Sixth and Fifth Amendment Rights as provided by the Constitution. They've told me that I choose to answer that question, which is my Page 235 BY MR. HOROWITZ: Q Mr. Epstein, Jane Doe 7 never told you she was 18 years old or older; isn’t that true? MR. PIKE: Form, THE WITNESS: It would give me great pleasure to be able to answer every one of Jane Doe 7's claims here today. However, my attorneys have advised me that I must assert my Fourteenth, Sixth and Fifth Amendment Rights, because if 1 choose to answer those questions, I risk losing their representation and/or waiving those rights. BY MR. HOROWITZ: Q When Jane Doe 7 came to your home between 2003 and May of 2005, she appeared to you ~- to you to be younger than 18 years old; isn't that right? MR, PIKE: Form. THE WITNESS: I'd like to answer each and every one of your questions here today, Mr. Horowitz. However, my attorneys have counseled me that I may not; I must assert my Fifth Amendment, Fourteenth Amendment and Sixth Amendment Rights. And thougl I'd rather -- and 1 prefer to answer each one of Jane Doe 7's claims, my attorneys told me that if 1 Page 237 preference, I risk losing their representation and/or waiving those rights. BY MR. HOROWITZ: Q Prior to May of 2005 did you instruct Jane Doe 7 to remove her clothing during your massage? MR. PIKE: Form. THE WITNESS: It would give me great pleasure to answer every one of Jane Doe 7's claims, each one, with specificity. However, today, my attorneys have counseled me that I may not, and they've instructed me that I must assert my Fifth Amendment, Fourteenth Amendment and Sixth Amendmenf} Rights under the U.S. Constitution, Though I'd Ei like to answer the question, they told me that if T do so, T risk losing their representation and waiving those rights. BY MR. HOROWITZ: Q Prior to May of 2005 did you instruct Jane Doe 7 to pinch your nipples and rub your chest? MR, PIKE: Form. THE WITNESS: I'd like to answer each one of Jane Doe 7's claims with specificity. However, today my attorneys have counseled me that I may not, and that [ must assert my rights under the Fourteenth, Sixth and Fifth Amendment. Though I'd UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

1 prefer to answer the question, my attorneys have 2 counseled me that if I choose to do so, I risk 3 losing their representation and waiving those 4 rights. 5 BY MR. HOROWITZ: 6 Q Did you prior to May 2005 ask Jane Doe 7 7 8 MR. PIKE: Form. 10 probably know, I'd like -- I'd like to answer each 11 one of your questions today, especially Jane Doe 12 7s claims. However, my counsel has advised me 13 that I must assert my rights under the Fourteenth, 14 Fifth and Sixth Amendment. And though I would 15 prefer to answer that question, he has counseled me 16 that if I choose to do so, I risk losing his 17 representation and waiving those rights. 18 BY MR. HOROWITZ: 20 Jane Doe 7's breasts? 21 MR, PIKE: Form. 23 each one of your questions posed here today, but J your questions here today, the same exact way, Page 238 questions about her sexual experience and preferences? 9 THE WITNESS: Mr. Horowitz, as you probably -. 19 Q > Mr. Epstein, prior to May of 2005 did you touch 22 THE WITNESS: Mr. Horowitz, I'd like to answer am going to have to respond as I've done to most of Page 240 Q Prior to May 2005 did you touch Jane Doe 7's breasts, even after she made repeated attempts to stop you? MR. PIKE: [ apologize, form. THE WITNESS: It would give me great pleasure to answer each and every one of Jane Doe 7's claims, each and every one. However, today, my counsel has advised that 1 may not. I must assert my rights under the Fourteenth, Sixth and Fifth Amendment. And though I prefer to answer, my counsel has told me that if] choose to do so, I risk losing his representation and/or waiving those tights. BY MR. HOROWITZ: Q > Mr. Epstein, prior to May 2005 did you rub Jane Doe 7's vagina? MR. PIKE: Form. THE WITNESS: It would give me great pleasure to answer the questions and claims of Jane Doe ?, your questions, It would give me great pleasure to answer the questions of your partner, Jeffrey Herman, who filed Jane Doe 7's lawsuit before he was suspended by the Florida Bar. It would give me great pleasure to, in fact, answer the questions posed by Mr. Edwards' partner, Scott Rothstein, who| a which is unfortunately my counsel has told me that 2 IT may not answer any questions that may be relevant 3 to any one of the lawsuits filed by you or your 4 partner that -- or your partner who was suspended 5 from the -- by the Florida Bar, or Mr. Edwards's -6 ? 8 Edwards' clients -- excuse me -- Mr. Edwards’ partner, Scott Rothstein, who sits in jail. They said, "I'm sorry, you can't -- you have to assert 9 your rights under the Fourteenth, Sixth and Fifth aL the question, I've been advised I risk losing their 12 representation and/or waiving those rights. 13. BY MR. HOROWITZ: 15 bra off-- remove a bra off of Jane Doe 7? 16 MR. PHKE: Form. 18 to the claims made by Jane Doe 7 with specificity. 19 However, today, my counsel has advised me that I 20 must assert my rights under the Fourteenth, Sixth 21 and Fifth Amendment. And though I'd prefer to 22 answer those questions, I -- if I do so, I'm told 23 that I risk losing their representation and/or waiving those rights. BY MR. HOROWITZ: Page 239 10 Amendment." And though | would choose to answer 14 Q. Prior to May 2005 did you attempt to remove the 17 THE WITNESS: | would very much like to respond Page 241 sits in jail. His other partner is on the way to jail for fabricating cases of a sexual nature against wealthy people. However, my attorneys have counseled me here today, 1 have to assert my Fourteenth, Sixth and Fifth Amendment Rights. And though I'd very much like to answer those questions, he's informed me that if 1 choose to do so, I risk losing his representation and/or waiving those rights. BY MR. HOROWITZ: Q Prior to May of 2005 did you rub Jane Doe 7's buttocks? MR, PIKE: Form, THE WITNESS: Again? BY MR. HOROWITZ; Q Prior to May ef 2005 did you rub Jane Doe 7's buttocks? MR. PIKE: Form. THE WITNESS: It would give me great pleasure to be able to answer each one of Jane Doe 7's claims here today with specificity. However, my counsel has advised me that J must assert my Fourteenth, Sixth and Fifth Amendment Right, so I =m o respectfully re: fuse to answer. 13 (Pages 238 to 241) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

wOIAM®eWNe Q_ Mr. Epstein, Page 242 BY MR. HOROWITZ: 1 Q Prior to May 2005 did you masturbate by 2 stroking your penis in front of Jane Doe 7? 3 MR. PIKE: Form. 4 THE WITNESS: I'd like to answer each one of | 5 your sexually charged questions, Mr. Horowitz. 1 6 would -- I would -- it would give me pleasure tobe | 7 able to respond directly to your other partner -- 8 at least in this question -- who's now been 9 unfortunately suspended from practicing law in the | 10 State of Florida after he filed this claim, or the 1 partner of Mr. Edwards who sits in jail for filing 12 claims of a sexual nature against wealthy people in | 13 Florida in order to fleece unsuspecting South 14 Floridians, his firm accused of filing and 15 fabricating sexual cases, called by the U.S. 16 Attorney a criminal enterprise. So, though I'd 17 like to answer each one of your questions, my 18 attorneys have said if I do so, I risk losing their 19 representation and/or waiving those rights. 20 BY MR. HOROWITZ: 21 Q Prior to May of 2005 did you ejaculate after 22 masturbating, stroking your penis in front of Jane Doe} 23 7? 24 MR. PIKE: Form. Page 244; questions about Jane Doe 7, okay? A Thank you. Q Prior to May 2005 did you walk across the room naked and enter a shower in front of Jane Doe 7? E MR. PIKE: Form. THE WITNESS; I would greatly like to -- 1 would actually like to answer each one of your questions today, Mr. Horowitz, especially all the claims made by Jane Doe 7. However, at least today, my counsel has advised me that [ must assert my rights under the Fifth, Sixth and Fourteenth rE Amendment. Though I prefer to answer the question, he's informed me that if | choose to do so, I risk losing his representation and/or waiving those rights, BY MR. HOROWITZ: Q Mr. Epstein, did you have sex -- sexual contact with Jane Doe 7 at your Palm Beach home on multiple | occasions between 2003 and 2005? MR. PIKE: Form. THE WITNESS: Mr. Horowitz, these claims of a sexual nature I'd very much like to answer, especially with respect to Jane Doe 7. I'd like to answer those questions, if your partner was here who filed the claim, but he's been suspended by the Page 243 THE WITNESS: Again, your questions of a 1 sexually charged nature in — in order to either 2 embarrass me -- I would greatly like to answer 3 those questions. I'd like to answer it to your 4 partner who has been disbarred -- sorry, not 5 disbarred -- you've told me he's been suspended and 6 not disbarred -- I keep getting it confused -- T after he filed this Jane Doe 7's claims, or similar 8 claims filed by Mr. Edwards and his partner, Scott 9 Rothstein, but his partner, Scott Rothstein, sits 10 in jail, So, though I'd like to answer each one of @L these claims, my counsel has told me that at least 12 today, at Jeast today, I must assert my rights 13 under the Fourteenth, Sixth and Fifth Amendment. 14 And if I choose to answer, I risk losing his is representation and/or waiving those rights. I'm 16 going to need five minutes. 17 BY MR. HOROWITZ: 18 Q Prior -- do you need five minutes now? 19 THE WITNESS: Sure, 20 THE VIDEOGRAPHER: Time off the record 4:05] 21 (Thereupon, a short break was taken.) 22 THE VIDEOGRAPHER: Time on the record 4:14.) 23 BY MR. HOROWITZ: Tam going pik wp with the Page 245 Florida Bar for improper behavior. I'd like to answer those questions to Mr, Edwards’ partner, but ff he sits in jail for crafting cases -- and if 1 misspoke before, it's crafting cases where he told people that he had settled cases against me and others. Not filed cases, but crafted total fictitious cases of a sexual nature in order to convince and fleece people of thousands and millions of dollars in South Florida. So those I'd like -- though I'd like to answer these questions of a sexually charged nature, my counsel has advised me that today at least, 1 must assert my rights under the Sixth, Fifth and Fourteenth Amendment. And though I'd prefer to answer those [/ questions, he has told me that if I choose to do so -- if I choose to so, I risk losing his representation and/or waiving those rights. BY MR. HOROWITZ: Q_ Did you pay $200 to Jane Doe 7 after each occasion in which you had sexual contact with her -MR. PIKE: Form. BY MR. HOROWITZ: Q_ -- between 2003 and 2000 -- and May 20057 MR. PIKE: Form, THE WITNESS: I'd like to 14 ans swer that questi (Pages 242 to 245) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 246 as I'd like to answer each and every question regarding Jane Doe 7 and her claims, However, my counsel has advised me that at least today, | may not answer any questions relevant to this lawsuit or any other lawsuits, so that | must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Though I'd prefer to answer, he's told me that if I choose to do so, L risk losing his representation and potentially waiving those rights, BY MR. HOROWITZ: Q Did you ask Jane Doe 7 for permission to touch either her breasts or vagina of both? A. Again, Mr. Horowitz, as I've answered most of your questions here today, I'd very much like to answer the claims of Jane Doe 7 and your firm and your partner, | Jeffrey Herman, who was suspended by the Florida Bar after he filed these claims on behalf of Jane Doe 7. However, my counsel at least today has advised me that must assert my rights under the Fourteenth, Fifth and Sixth amendment. And though I prefer to answer those questions, he's told me that if 1 choose to do so, I risk losing his representation and/or waiving those rights. MR. PIKE: Form to that question as well. Page 248 she indicated she did not want you to touch her? MR. PIKE: Form. THE WITNESS: Mr. Horowitz, I'd like to answer! each one of Jane Doe 7's claims. However, today, ff my counsel has advised me that I must assert my tights under the Fourteenth, Sixth and Fifth Amendment. Though I'd prefer to answer these questions directly to your partner that was suspended or disbarred or -- I keep getting it confused ~- since he filed these claims of Jane Doe 7, or Mr. Edwards’ partner who sits in jail for fabricating malicious claims of a sexual nature -I'm ~ I'm - I'm sorry, if you find this very funny. I don't. However, my attorneys have counseled me, I -- | must not answer that question today, and if I choose to do so, I risk losing his representation and/or waiving those rights. BY MR. HOROWITZ: Q > When Jane Doe 7 was under the age of 18, did you try to persuade her that it was okay for you to touch her breasts and vagina and to masturbate in front of her? MR. PIKE: Form. THE WITNESS: Are you serious? Is -- can hear that question again? Page 247 BY MR. HOROWITZ; Q When Jane Doe 7 was still a minor, she indicated to you that she did not want you to touch her body; isn't that true? MR. PIKE: Form. THE WITNESS: It would give me -- I would like fo answer those questions and claims of Jane Doe 7. However, today, my attorneys have counseled me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Though I would prefer tq give the answers directly to the -- your pariner who filed this claim on behalf of Jane Doe 7, but the Florida Bar has suspended his license for improper behavior after he filed this claim. I'd prefer to give it to Mr. Edwards' partner, but he sits in jail, and his other partner is on the way to jail from -- for basically fabricating malicious claims of a sexual nature against people in South Florida. So, though I'd like to answer that question, I'd prefer to answer that question, I'm told that if I do so, I risk losing my counsel's representation and/or waiving those rights. BY MR. HOROWITZ: Isn't it true, sir, you touched Jane Doe 7's \d genitals when she was still a child after BY MR. HOROWITZ: Q Doyou deny that when she was stili a child -~ A Can I-- I need to hear the question again, sorry. Q Oh, I thought you said your hearing was okay. MR. PIKE: Let's just go forward with the question -BY MR. HOROWITZ: Q > When Jane Doe 7 was still -MR. PIKE; -- and stop harassing the witness, BY MR. HOROWITZ: Q When -MR. HOROWITZ: Harassing? MR. PIKE: Yes. E MR. HOROWITZ: Is that what I'm doing, or is -~ or is harassing pinching -- p MR. PIKE: Let's move to strike. MR. HOROWITZ: -- the ~ the -MR. PIKE; All right. Let 's is 80. what's - ~ which is harassing, BY MR. HOROWITZ: Q Okay, When Jane Doe 7 was still a child, did you try to persuade her that it was okay for you to agina, breasts, and to masturbate? 15 (Pages 246 to 249) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 250 1 MR. PIKE: Form, 1 2 THE WITNESS: I would very much like to answer = 2 3 the claims of Jane Doe 7 and your firm, but your -- 3 4 unfortunately your partner has -- is not here 4 5 because he's been suspended by the Florida Bar for 5 6 improper behavior. I'd prefer to answer that 6 7 question of a sexually charged nature to 7 8 Mr. Edwards' partner, who unfortunately couldn't be 8 9 here because he's in jail for potentially the rest 9 10 of his life for fabricating cases of a sexual 10 1 nature against people in South Florida, stealing a 12 investors’ monies, fleecing people out of millions 12 13 of dollars, creating sexually charged cases in 13 14 order to sort of fleece people. However, my 14 15 attorneys have told me that today | must assert my 15 16 rights under the Sixth, Fifth and fourteenth 16 17 Amendment. And if I choose to answer those 17 18 questions, which is my preference, | risk losing 18 19 his counsel and waiving those rights. 19 20 BY MR. HOROWITZ: 20 21 Q Did you pay H.R. to bring Jane Doe 7 to your 21 22 home for sexual activity? 22 23 MR. PIKE: Form. 23 THE WITNESS: I would very much like to answer all questions regarding H.R. and Jane Doe 7's Page 252 BY MR. HOROWITZ: Q Did you instruct S.K, to cal! Jane Doe 7 strike that. Did you instruct $.K. to tell Jane Doe 7 to mislead the police with regard to their investigation into your criminal activity? MR. PIKE: Form. THE WITNESS: [Id like to answer every one of your questions that you've posed here today regarding Jane Doe 7 and her claims. However, my attomeys have advised me at least today, I may not do so, and I must assert my privileges under the E Sixth, Fifth and Fourteenth Amendment. Though I'd prefer to answer those questions, I'm told that if I choose to do so, J risk losing his representation and potentially waiving those rights. BY MR. HOROWITZ: Q Mr. Epstein, is the telephone number [917-855-3363 a telephone number that $.K. used at yout: expense in 2005? E MR. PIKE: Form. THE WITNESS: | don't recall. BY MR. HOROWITZ: Q What telephone numbers did you use, or did you B pay to be used between 2001 and 20067 Page 251 1 claims regarding H.R. However, today, my counsel 1 2 has advised me that I must assert my rights under 2 3 the Fifth, Fourteenth and Sixth Amendment, 3 4 BY MR. HOROWITZ: 4 5 Q Did you instruct $.K. to write down Jane Doe’ 5 6 7's name and telephone number so that you could call 6 7 Jane Doe 7 to come to your home for more sexual ? 8 activity? 8 9 MR. PIKE: Form. 9 10 THE WITNESS: Again, these charges of a sexual. 10 11 nature that you and your firm have lodged against 11 12 me, it would give me great pleasure to specifically 12 13 answer those questions with respect to Jane Doe 7's | 13 14 claims. I would like to answer it directly to your 14 15 partner, Mr. Herman, who filed the claim, but he's 1s been suspended or disbarred by the Florida Bar. I'd like to respond to these sexually charged questions to Mr. Edwards' partner, Scott Rothstein, 19 but he's in jail for fabricating malicious cases of 19 20 a sexual nature against wealthy people in South 20 21 Florida. So, though I would like to answer these 21 22 questions, I have been informed by my attorneys 22 23 that I must assert my privileges. And if] choose 23 to answer, which is my preference, I risk losing his representation and/or waiving my tii UNIVERSAL COURT (954) 712-2600 (877) Page 253, A I~ MR, PIKE: Form. THE WITNESS: I don't recall. BY MR. HOROWITZ: BE Q Okay. Can you think of any telephone number that you either used from your home, or paid someonefi else to use between 2001 and 2006? |: A_ I'd like to answer that question, but on advice of counsel J am going to have to claim my privilege under the Sixth, Fourteenth and Fifth Amendment. Q Sir, you don't deny that you sexually abused Jane Doe 7 when she was still a child, do you? MR. PIKE: Form. THE WITNESS: 1'm sure these questions ofa sexually charged nature, Mr. Horowitz, are going to be obvious to the jury. I'd like to answer each I'd like to answer it to your partner, Mr. Jeffrey Herman, but he can't be here because he's been suspended or disbarred by the Florida Bar for improper behavior after he filed these claims of sexual abuse. I'd like to make -- respond to the sexual abuse claims made by Mr. Edwards’ partner, Scott Rothstein, but he’s in jail for the rest of his life, and his other partner is on the way to f 16 (Pages 250 to 253) REPORTING 291-DEPO (3376)

SCT ST Page 254 Page 256 i jail for fictitiously fabricating malicious claims 1 losing his representation and waiving those rights. 2 of asexual nature. So, though I'd like to answer 2 BY MR. HOROWITZ: 3 those questions, my attorneys have counseled me 3 Q > Mr. Epstein, is there any reason why the jury 4 that I may not today. And he's told me that if I 4 should not infer from your testimony today that, in 5 do so, I risk losing his representation and/or 5 fact, you did sexually abuse Jane Doe 7? 6 waiving those rights. 6 MR. PIKE: Form. 7 BY MR. HOROWITZ: z THE WITNESS: Again, these questions of a 8 Q Isn't it true, sir, that you are asserting the 8 sexually charged nature regarding my right to take 9 Fifth Amendment privilege with regard to my questions 9 the Fifth Amendment under the advise of counsel, I 10 about Jane Doe 7 because you did, in fact, sexually 10 find disturbing. Not -- not so much disturbing 12 abuse Jane Doe 7 when she was 2 child? 11 than your partner who's been disbarred or suspended 12 MR. PIKE: Form. 12 by the Florida Bar since he filed the claim here by 13 THE WITNESS: The polar trick of asking someong 13 these girls, or Mr. Edwards’ partner who sits in. 14 why they're asserting their Fifth Amendment Right, 14 jail potentially for the rest of his life, with his 15 T'm -- I'm - J'm surprised, Mr. Horowitz. The 1s other partners on the way to jail for fictitious, 16 Supreme Court has made it very clear that the Fifth 16 melicious claims of a sexual nature. I'd like to 17 Amendment is a right of every American who -- 17 answer your questions with great specificity, 18 innocent American to use to protect themselves from 18 Mr. Horowitz, but my counsel has advised me that at 19 people making malicious false claims, similar to 19 least today, I may not. And if I do so, which is 20 the one that the U.S. Attorneys have put 20 my preference, I risk losing their representation 21 Mr. Edwards" partner in jail for, for the rest -—- 21 and/or waiving those rights, 22 potentially the rest of bis life for making 22 BY MR. HOROWITZ: 23 malicious claims against innocent people, making 23 Q_ Mr. Epstein, you're not suggesting that Jane : 24 fictitious claims. Your partner has been suspended 24 Doe 7 fabricated or embellished her allegations of abuse 25 since filing this claim of a sexual nature, So, 25 _ in light of anything done by Jeffrey Herman or Scott Page 255 Page 257]; 1 though I'd like to answer that question, my 1 Rothstein, are you? 2 attorneys have advised me | may not. 2 MR. PIKE: Form, 3. BY MR. HOROWITZ: 3 THE WITNESS: I think the jury is going to 4 Q Are you asserting the Fifth Amendment because 4 decide that Jeffrey Herman who's been disbarred or [ 5 you're an innocent man, or because you're a guilty man? 5 suspended by the Florida Bar for improper behavior |, 6 MR. PIKE: Form. 6 after filing this claim, or Mr. Edwards’ partner [ 7 THE WITNESS: I'd like to answer that question 7 who sits in jail potentially for the rest of his 8 as well. The Fifth Amendment is the right of an 8 life, Mr. Horowitz, for the rest of his life, for 9 American to protect themselves from charges ~ 9 fabricating cases specifically of a sexual nature 10 false charges. It's a right that the Supreme Court 10 -- I think the jury will decide whether these are iL says protects the innocent, Mr, Horowitz, the 11 fabricated or embellished. I'd like to answer with 12 innocent. It's a Supreme Court case. It's the -- 12 great specificity today; however, my attorneys have 13 you're the lawyer. 13 advised that at Jeast today, I must respond by LE 14 I woutd like to ~- the jury to know that your 14 taking -- asserting my Fifth Amendment, Fourteenth 15 partner has been suspended for improper behavior 15 and Sixth Amendment privilege. And though I woul 16 since he filed these sexual abuse claims, 16 very much like to respond to that question, he's 17 Mr. Edwards' partner sits in jail for potentially 17 told me that if I do so, 1 risk losing his. 18 the rest of his life for fabricating malicious 18 representation and/or waiving those rights. 19 claims of a sexual nature against wealthy people in 19 BY MR. HOROWITZ: 20 South Florida. 1 would like to answer your 20 Q Well, what is it that you'd like the jury to 21 questions more specifically, but my attorneys will 21 infer exactly from the fact that Jane Doe 7 had Jeffrey 22 not allow me to. They told me I must assert my 22 Herman as an attorney? 23 rights under the Sixth, Fifth and Fourteenth 23 MR. PIKE: Form. Amendment. Though I would very much like to answer that question, THE WITNESS: Jeffrey Herman went -- was suspended after he filed a claim on behalf of Jane _ a 17 (Pages 254 to 257) UNIVERSAL COURT REPORTING (954) 712-2600 . (877) 291-DEPO (3376)

Page 258 Doe 7 and your other girls. Scott Rothstein went to jail for filing fictitious, malicious claims of a sexual nature in order to simply get money, steal money, fleece people for money. I'd like to answer every one of your questions today, Mr. Horowitz, However, my attorneys have counseled me that today at least I may not, and must assert my rights. And if I choose to answer the question, which is my preference, | potentially might lose his representation and/or waive those rights. BY MR. HOROWITZ: Q > Okay. Mr. Epstein, so we're on the same page, my next series of questions will involve Jane Doe Numbeq 8, okay? Have you got that name locked into your head? A S'do my best. Q Okay. Isn't it true, sir, that a girl named Jane Doe 8 came to your Palm Beach estate in approximately 2001 or 2002? MR. PIKE: Form. A 1 would very much like to enswer the claims of aJane Doe 8. However, my attorneys have counseled me that I must assert my rights under the Fifth, Fourteenth and Sixth Amendment. I'd like to answer these claims of a Jane Doe 8, but they told me if] were to do so, I would risk losing their representation and/or waiving Page 259 those rights, BY MR. HOROWITZ: Q Did you receive a phone cali from a girl named C.M.A., wherein she told you she was bringing Jane Doe 8} to your home for the purpose of giving you a massage? A_ 1 would very much like to answer any question regarding C.M.A., I believe, an admitted prostitute. Her claims of bringing a Jane Doe 8 -- a girl named Jane Doe 8; is that right -- to my house. However, my attorneys have counseled with respect to all questions. today, all questions, | must assert my rights under the Fifth, Sixth and Fourteenth Amendment. Though I'd like to answer these questions with specificity, my counsel has told me that if I choose to do so, | risk losing his representation ~ excuse me -- or my ~- and/or my ~ waiving my rights. Q_ Did you instruct S.K, to place a telephone call C.M.A. to arrange for C.M.A. to bring underage girls to your home for sexual activity? MR. PIKE; Form. THE WITNESS: | would like to answer each and every one of your questions regarding a C.M.A., who I believe is an admitted prostitute, and a Jane Doe 8, but my attorneys have advised me at least today, ifth, Fourteenth Page 2608 and Sixth Amendment. Though I'd very much like t answer those questions, I'm told that if { choose to do so, I risk losing his representation and/or waiving those rights, BY MR, HOROWITZ: Q Was -- was C.M.A. your prostitute? MR. PIKE: Form. THE WITNESS: Again, I'm sure these -- these questions you find very clever, Mr. Horowitz. So it's — it's questions of a sexually charged nature brought by Mr. Edwards’ firm, his partner sitting in jai! for bringing cases of a sexually charged nature against wealthy people in South Florida, sitting in jail for the rest of his life. Your partner being suspended by the Florida Bar for improper behavior after filing of cases on behalf your Jane Doe 8. So though I'd like to answer each ft one of your questions here today, my counsel has advised me that [ may not. And -- excuse me -BY MR. HOROWITZ: Q Go ahead. A and though I would much prefer to do so, he's told me that if 1 do so, I risk losing his representation and or waiving those rights. I've got to take five minutes, sorry. i Page 261 THE VIDEOGRAPHER: Tine off the record 4:35. (Thereupon, a short break was taken.) BY MR. HOROWITZ: Q Mr. Epstein, we're still ~ THE VIDEOGRAPHER: Time on the record 4:42. MR. HOROWITZ: Sorry. BY MR, HOROWITZ: Q Mr. Epstein, we're still going to talk about Jane Doe 8 a little bit more, okay? Did you instruct C.M.A. to bring underage girls to your home to engage in sexual activity with you? MR. PIKE: Form. THE WITNESS: I'd like to answer each question being posed here today about now C.M.A., | believe, an admitted prostitute and drug addict, and her claims of bringing a Jane Doe 8 ~- I believe you said her name was -- to my house. However, at the ~~ in the -- at the insistence of my attorney, his response -- he's required me to assert my Fifth [: Amendment, Sixth Amendment and Fourteenth Amendment, Right, Though I'd like to answer each and every question about your Jane Doe 8, | unfortunately could not do so today. BY MR. HOROWITZ: Q_ Mr. Epstein, you're not suggesting that 18 (Pages 258 to 261) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 262 Page 264 given it to your partner, Jeffrey Herman, testified 1 C.M.A's status as either a prostitute or drug user 1 brought this claim on behalf of Jane Dee 8, I 2. diminishes the credibility of Jane Doe 8's sexual abuse} 2 believe. But since that claim was brought, he was 3 claim against you, are you? 3 suspended by the Florida Bar. | prefer to bring it 4 A [Het the- 4 whose -- Mr. Edwards’ partner, who's sitting next 5 MR. PIKE: Form. 5 to you, but he's in jail for the rest of his life 6 THE WITNESS: -- jury decide that. 6 for bringing fictitious claims of a sexual nature 7 BY MR. HOROWITZ: 7 against wealthy people in Florida in order to get 8 Q Okay. Well, ] want to know what -- what -- 8 as much money as he could. He was accused -- and 9 what you're trying to convey to the jury? 9 Mr. Edwards' firm was accused by the U.S. Attorn 10 MR. PIKE: Form. 10 of being -- and perpetrating the largest fraud in a: THE WITNESS: I'd like to answer that question,! 11 South Florida's history being a criminal 12 Mr. Horowitz, like I'd like to answer every one of 12 enterprise. And I'm -- so I'm sorry | can't answer 13 your questions, but I think it’s going to be 13 these questions with specificity today, 14 obvious about what C.M.A. and Jane Doe 8 are 14 Mr. Horowitz. But on advice of counsel, he's told 15 attempting to do. However, though I'd like to 1s me that if I choose to answer, I risk losing his 16 answer with more specificity, my attorneys have 16 representation and/or waiving my rights. iy advise me I may not today, and I must assert my 1? BY MR. HOROWITZ: 18 rights under the Fifth, Sixth and Fourteenth 18 Q Mr. Epstein, is it your sworn testimony that 19 Amendment. Though I'd like -- I'd like to answer 19 Jane Doe 8 retained Jeffrey Herman, and that he was 20 the question, my attorneys have counseled me today; 20 — suspended after he was retained? i 21 that if 1 choose te do so, I risk losing their 21 MR. PIKE: Form. i 22 representation and/or waiving those rights. 22 THE WITNESS: I'm sorry, it's -- again? E 23 BY MR. HOROWITZ: 23. BY MR. HOROWITZ: E 24 Q Did you instruct $.K. to communicate with. 24 Q My question is -- well, I'll break itup intwo 25 C.M.A, by telephone in order to arrange for Jane Doe 8} 25 questions. Is it your swom testimony that Jane Doe 8 : Page 263 Page 265 1 to give you a massage? 1 hired Jeffrey Herman to be her attorney? 2 MR. PIKE: Form. 2 A. Lonly know that -- my only knowledge is that E 3 THE WITNESS: I would like to answer every 3 Jane Doe 8 is represented by the firm where Jeffrey E 4 question about your Jane Doe 8 claim. I'd like to 4 Herman was -- used to be a partner. i 5 answer every question about your C.M.A. connection, 5 Q Okay. And you're not suggesting to anyone that 6 whoever, to Jane Doe 8. However, my attorneys have 6 Jeffrey Herman was suspended after Jane Doe 8 decided tdi ee advised me that ! may not answer those questions 7 file a lawsuit, are you? } 8 today. I must assert my rights under the 8 MR. PIKE: Form. E 9 Fourteenth Amendment, Sixth Amendment and Fifth 9 THE WITNESS: [ do not know when Jane Doe 8 10 Amendment. Though I think the -- I'd like to 10 decided to file a lawsuit. If you'd like to tell 1 answer those questions, my attorney has told me 1. me, I'd be able to answer that question. E 12 that if choose to do so, 1 risk losing his 12 BY MR. HOROWITZ: E 13 representation and/or waiving those rights. 13 Q Okay. i 14 BY MR. HOROWITZ: 14 A Would you like to tell me? q 15 Q Mr. Epstein, did you inform §.K. that the 1s Q Did S.K. tell you that she confirmed by q 16 massage that Jane Doe 8 was to give you would be sexuali 16 telephone that Jane Doe 8 would be coming to your home : 17 in nature? 17 ata specific time to give you a massage? E 18 MR. PIKE: Form. 18 MR. PIKE: Form. E 19 THE WITNESS: I'd like to answer every one of 19 THE WITNESS: I'd like to respond to every i 20 your questions regarding the claims of your Jane 20 question regarding Jane Doe 8 and her claims; i 21 Doe 8. However, my attorneys have counseled that I 21 however, my attorney has counseled me today that I E 22 may not answer any questions that may be relevant 22 may not answer those questions today, Mr. Horowitz. 23 to any of your lawsuits. I would prefer to have 23 [ must assert my rights under the Fifth, Fourteenth in front of your partner, Jeffrey Herman, who =a its and Sixth Amendment. | would like to -- I'd like to, in fact, know whether Mr. Herman's firm -19 (Pages 262 to 265) UNIVERSAL COURT REPORTING (954) 712-2600 {877} 291~DEPO (3376)

Page 266 Me. Herman who's been disbarred, or you firm or your partner, Mr. Herman, who was -- who was suspended -- sorry, not disbarred — you keep correcting me. I'm not really sure of the difference -- or Mr. Edwards’ partner who's in jail for crafting all these fictitious lawsuits, and fleecing people out of thousands of millions of dollars. I'd like to do that, however, my attorneys have counseled me that I may not do that today. And if I choose to answer those questions, which I prefer to do, | risk losing their representation and/or waiving those rights. BY MR, HOROWITZ: Q Was it your intent during the course of Jane Doe $'s visit to your home, that you would persuade, induce or entice her to engage in sexual activity with you? MR. PIKE: Form. I didn't know if you were finished. MR. HOROWITZ: I'm finished. THE WITNESS: I'd like to answer every question} with respect to your Jane Doe 8 claim, every one. However, today, my counse] has advised me that 1 may not, and must assert my Sixth, Fifth and Fourteenth Amendment Right. And though I'd prefer Page 268 years old or older, did she? MR. PIKE: Form. THE WITNESS: I'd like to answer each and every} question about your Jane Doe 8 claim. However, today, my attorneys have counseled me that I may not, and I must assert my rights under the Sixth, Fourteenth and Fifth Amendment. Though I'd like to answer every question about Jane Doe 8 -- your Jane |; Doe 8 claim, my attorneys have counseled -- said to me that if I choose to answer those questions, 1 tisk losing their representation and/or waiving those rights. BY MR. HOROWITZ: Q > When ~ when you met Jane Doe 8, she appeared | to you to be younger than 18 years old; isn't that right? MR. PIKE: Form. THE WITNESS: Again, I'd like to answer every question I could possibly answer regarding your Jane Doe 8 claim, and every -- and the claims regarding your other people that you've brought up today, but I must respond the same way I've responded to most of your other questions here today, Mr. Horowitz, which is on advice of my counsel, I could not answer today, though I'd like Page 267 to answer the questions, he's told me that if | choose to do so, | risk losing his representation and/or waiving those rights. BY MR. HOROWITZ: Q During the course of Jane Doe 8's visit to your home, did you succeed in persuading her, inducing her, or enticing her to engage in sexual activity with you? MR. PIKE: Form. THE WITNESS: | would like to answer every question about your Jane Doe 8 -- Jane Doe 8 or Jane Doe 8 claim. However, my attorneys have counseled me that I may not answer any questions that may be relevant to any one of your lawsuits brought by you or your partner, Jeffrey Herman, but he's been suspended by the Florida Bar since he filed money -- many of your claims of a similar nature, or Mr. Edwards's partner who sits in jail for the rest of his life for crafting malicious fabricated sexual natured-type claims -- sexually charged claims against wealthy people in Florida in order to fleece investors out of millions of dollars. So though I'd like to answer those questions, Mr. Horowitz, today I cannot. BY MR. HOROWITZ: Jane Doe 8 never told ‘ou she was 18 Page 269) to. They've instructed me that I must assert my rights under the Fourteenth, Sixth and Fifth Amendment. And if I choose to answer the questions, which is my preference, they tell me that I would risk losing their representation and/or waiving my rights. BY MR. HOROWITZ: Q Were you nude in front of Jane Doe 8 when she was still a child under the age of 187 MR. PIKE: Form. p THE WITNESS: Mr. Horowitz, I'm going to have; to answer that question the way I've answered most of your questions here today. It would give me pleasure to answer the claims of Jane Doe 8. E However, my counsel has advised me that I may not f answer any questions relevant -- that may be relevant to any of the lawsuits that you've brought, or your partner that was subsequently suspended from the practice of law in Florida has brought. And though I'd like to answer those questions specifically, my counset has told me that if I do so, I risk losing his representation and/or waiving those rights. BY MR. HOROWITZ: Q pid you instruct Jane Doe | 8 to remove her 20 (Pages 266 to 269) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

SAT Page 270 Page 2724 1 clothing when she was still a child? 2 BY MR. HOROWITZ: 2 MR, PHKE: Form. 2 Q During the course of her visit to your home, 3 THE WITNESS: I'd like to answer each one of 3 did you touch Jane Doe 8's breasts? 4 the questions you've posed about your Jane Doe 8 4 MR. PIKE: Form. 5 claim; howeéver, my attorneys have counseled me that] 5 THE WITNESS: Unfortunately my attomeys have! 6 I may not today -- excuse me -- | must assert my 6 counseled me that today, though I'd like to answer 7 rights under the Fourteenth, Fifth and Sixth 7 every one of your questions specifically, I'd have 8 Amendment. Although I'd prefer to answer the 8 to answer this question like I've answered most of 9 question, my attorneys have counseled me that [ may 9 the other questions with respect to Jane Doe 8 and 10 not. 10 the Jane Doe 8 claims, which is I'd have to assert 11. BY MR. HOROWITZ: 11 my rights under the Sixth, Fourteenth and Fifth 12 Q When Jane Doe 8 was still a child, did you 12 Amendment. Because if 1 don't do so, and I choose 13 instruct her to pinch your nipples and rub your chest? 13 to answer, which is my preference, my counsel has 14 MR. PIKE: Form. 14 advised me I am in risk of losing their 15 THE WITNESS: It would give me pleasure to be | 15 representation and waiving those rights. 16 able to answer the questions regarding your Jane 16 BY MR. HOROWITZ: 7 Doe 8 claims. However, my attorneys have counsel 17 Q During the course of her visit to your home, 18 me that today | may not answer any question that 18 did you rub Jane Doe 8's vagina? 19 may be relevant to any of the lawsuits brought by 19 MR. PIKE: Form, 20 your firm, your firm, including your partner, 20 THE WITNESS: Again? 21 Jeffrey Herman, who was subsequently suspended or | 21 BY MR. HOROWITZ: 22 disbarred by the Florida legal — by the Florida 22 Q During the course of Jane Doe 8's visit to your 23 Bar after bringing some of these claims, or 23 home, did you rub her vagina? 24 Mr. Edwards’ partner that sits in jail for the rest 24 MR. PIKE: Form. 25 of his life for crafting and trying to convince 125 THE WITNESS: I'd like to answer every one of Page 271 Page 273 1 other people that these claims were real, T 1 your Jane Doe 8 claims, especially your Jane Doe 8 2 believe, claims -- claims like this were real, and. 2 claims with respect to the details of what -- these Ei 3 fleeced investors out of millions of dollars. His 3 questions. However, my attorneys have counseled md; 4 firm, Mr. Edwards' firm, of being accused by the 4 that today, I cannot answer those questions, at $ U.S. Attorney of being a criminal enterprise, 5 least today, and 1 must assert my rights under the 6 perpetrating one of the Jargest frauds in South 6 Fousteenth, Fifth and Sixth Amendment. And though) 7 Florida's history against south Floridians. So 7 I'd prefer to answer those questions, especially a though I'd like to answer each one of your 8 the questions of a sexually charged nature, similar 9 questions with great specificity, my counsel has 9 to the ones where Mr. Edwards, who's sitting next 10 told me today at least, I may not. And if I do so, 10 to you, whose partner is in jail for -- for aL I risk losing their representation and/or waiving 11 crafting malicious claims of a sexual nature, or 12 those rights, 12 your partner who you smile about while you think 13. BY MR. HOROWITZ: 13 he's been disbarred or suspended. It's okay. I'd 14 Q_ During the course of her visit, did you ask 14 like to answer those questions, but today, I 15 Jane Doe 8 questions about her sexual experience and 15 cannot, because though I choose to do so my ~ 1 -16 preferences? 16 if I choose to do so, my counsel said I risk Josing 17 MR. PIKE: Porm. 17 his representation and/or waiving those rights. 18 THE WITNESS; I would very much like to answer 18 BY MR. HOROWITZ: 19 every question regarding the claims of your Jane 19 Q > When Jane Doe 8 was at your home, did you 20 Doe 8 ~ your Jane Doe 8 claim. However, today,my | 20 masturbate in her presence? 21 attorneys have counseled me that I may not, and I 21 MR. PIKE: Form. 22 must assert my rights under my Fourteenth, Sixth 22 THE WITNESS: I'd like to answer that Jane Doe 23 and Fifth Amendment. Though I'd like to answer 23 8 question as much as -- it's Jane Doe 8, right - each claim, today I am going to respectfully a AT TT TG Jane Doe 8 question, as well as every other Jane Doe 8 claim th that you've put on the table | here 21 (Pages 270 to 273) UNIVERSAL COURT REPORTING (954) 712-2600. (877) 291-DEPO (3376)

BY MR. HOROWITZ: Page 274 today, Mr. Horowitz. However, on the advice of my counsel, | am going to have to assert my rights under the Fourteenth Amendment, Sixth Amendment and Fifth Amendment. Though -- because I'd like to answer that question, I'm told by my counsel that if T choose to do so, I risk losing his representation and/or waiving those rights. Q When Jane Doe 8 was still a child under the age of 18, isn't it true, sir, you masturbated to the point 10 of ejaculation in front of her? 12 MR. PIKE: Form. 12 THE WITNESS: I'm sure these questions of a 13 sexually charged nature, that hopefully the jury 14 will be able to see through them, Mr. Horowitz. 15 ¥'d like to answer all those questions, However, 16 my counsel today has told me that | must respond by 17 asserting my rights under the Sixth, Fifth and 18 Fourteenth Amendment. 19 Sexually charged cases, similar to the ones 20 where Mr. Roth -- excuse me -- which Scott 21 Rothstein had fictitiously fabricated, who's -- he 22 is Mr. Edwards’ partner, who's in jail, 23 Mr. Edwards’ partners are on the way to jail for simply fabricating — trying to steal money from Page 276 would prefer to answer those questions, today | may not because I've been told that if] do so, I risk losing his representation and/or waiving my rights. BY MR. HOROWITZ: Q Mr. Epstein, when Jane Doe 8 was at your home and was still a child, did you tell her that you wanted her to give you oral sex, otherwise known as a blow job? MR. PIKE: Form. THE WITNESS: Mr, Horowitz, I'd like to answer — answer every question and claim made by your Jane Doe 8. However, my attorneys have counseled me that at Jeast today, | have to assert my rights B under the Fourteenth Amendment, the Sixth Amendment and the Fifth Amendment. I'm told that though I'd E like to answer those questions, if | choose to do 80, I tisk losing his representation and/or waiving my rights. I prefer to answer questions like this -- ofa -- sexually charged nature to your partner, Jeffrey Herman, but he's been suspended by the Florida Bar for improper behavior after filing many of your claims. T'd prefer to answer those questions to Mr. Edwards' partner, Scott Rothstein, but he’s in Page 275 investors in South Florida. 2 Your partner after he filed this -- or sometime 2 during these claims has been suspended by the 3 Florida Bar. So, though I'd like to answer these 4 questions with great specificity, my attorneys have 5 told me if do so, I risk losing their 6 representation and/or waiving those rights. 7 BY MR. HOROWITZ: 8 Q When Jane Doe 8 was still a child and she was 9 in your home, did you tell her that you wanted her to 10 touch your penis? 12: MR. PIKE: Form. 12 THE WITNESS: Again, | would like to answer 13 every question about your Jane Doe 8 claims with 14 great specificity, and I'm sure the ladies and is gentlemen of the jury will understand that these 16 sexually charged cases, similar to the ones where 17 Mr. Edwards' parmer has gone to jail for 18 fabricating cases, trying to steal money from 19 people in South Florida, your partner after filing 20 some of these cases has been suspended, will see 21 through it. And though I'd like to be able to 22 answer with great specificity, my counsel has told 23 me I may not and must assert my rights under the 24 Page 277); jail for the rest of his life ~~ it appears the rest of his life. Many of Mr. Edwards’ partners are on the way to jail for the rest of their life for crafting cases of a sexually charged nature, fictitious cases, in order to steal millions of dollars form local investors. So though I'd like to answer that question, I'm told that if] do so, (risk losing the representation of my counsel and waiving those rights. BY MR. HOROWITZ: Q Mr. Epstein, did you engage in sexual activity with Jane Doe 8 during the course of a massage at your Palm Beach home in 2001 or 2002? MR. PIKE: Form. THE WITNESS: When? MR. HOROWITZ: Let me start over. THE REPORTER: 2001, 2002 you said. MR. HOROWITZ: I'll -- I'll -- V'll ask the question again, so that the record is a little bit clearer. BY MR. HOROWITZ: Q Did you engage in sexual activity with Jane Doe | 8 during the course of a massage at your Palm Beach home! in 2001 and 2002? MR. PIKE: Form. ( UNIVERSAL COURT (954) 712-2600 (877) ETT TET 22 (Pages 274 to 277) REPORTING 291-DEPO (3376)

Page 278 THE WITNESS: I'd like answer that question. I'd like to answer all the questions with respect to your Jane Doe 8 claims. However, my counsel has advised me today that I must, at least today, assert my rights under the Fifth, Sixth and Fourteenth Amendment. So though I'd like to answer those questions, I'm told that if] do so, I risk losing his representation and/or waiving those rights. BY MR. HOROWITZ: Q Didyou— THE VIDEOGRAPHER: Three minutes -MR. HOROWITZ: I'm sorry? THE VIDEOGRAPHER: I'm sorry, three minutes of tape remaining. MR. HOROWITZ: Okay. BY MR. HOROWITZ: Q Did you ask Jane Doe 8 for permission to touch her in a sexual manner when she was still a child? MR. PIKE: Form, THE WITNESS: I'd like to answer every one of your questions, but unfortunately I am going to have to answer the same way I've answered most of those here today, which is my counsel has advised me that 1 must assert my rights under the MR. PIKE: Form. THE WITNESS: In 2001, 2002 -- I'd like to answer every one of your questions regarding your Jane Doe 8 claims. However, my attorneys have counseled me today that I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment Right. Though I'd prefer to answer every one of ; your questions regarding Jane Doe 8, today I'm going to have to refuse to do so. BY MR. HOROWITZ: Q You touched Jane Doe 8's breasts, you touched her genitals, and you did that after she indicated to you that she did not want to be touched by you; isn’t that right? MR. PIKE: Form. THE WITNESS: I'd prefer -- excuse me -- if T ~ if | understood, in fact, when your partner, Jeffrey Herman, filed most of his cases against me, because I know he was disbarred or suspended after he filed these cases of a sexual nature. I'm not sure of the time frame, or when Mr. Edwards' partner got involved who's now in jail for filing ~- for fabricating -- sorry -- for fabricating malicious cases of a sexual nature against many people in South Florida, called by the U.S. Page 279 Fourteenth Amendment, the Sixth Amendment and Fift Amendment. However, I'd like to answer those questions, but he's told me that if I do so, Lrisk losing his representation. I'd like answering those questions to your partner, Jeffrey Herman, but he's not here because he's been suspended for improper behavior after he filed these cases, after he had a press conference in Palm Beach, in the streets of Palm Beach, called the media. T'd like to express the same answer to Mr. Edwards' partner, but he’s in jail for the rest of his life for creating fictitious cases. So, Mr. Horowitz, though I'd like to answer the question today, F must deny -- I must refrain from doing so at the advice of counsel, MR. HOROWITZ: Let's change tapes. THE VIDEOGRAPHER: Time off the record 5:01. (Thereupon, a short break was taken.) THE VIDEOGRAPHER: Time on the record 5:09. This is Tape 6. BY MR. HOROWITZ: Q Mr. Epstein, in 2001 and 2002, Jane Doe 8 indicated to you that she did not want you fo touch her body; isn't that tight? Page 2815 Attomey -- his firm called by the U.S. Attorney, a criminal enterprise. His partner is in jail for the rest of his life. Many of his parmers are on the way to jail for the rest of their lives potentially, So though I'd like to answer every question with respect to your Jane Doe 8 sexual claim -- your Jane Doe 8 claims of a sexual nature, Ive been advised by my counsel at least today that I may not do so. And if I choose to do so, which is my preference, I risk losing their representation or waiving those rights. BY MR. HOROWITZ: Q Mr. Epstein, is it your testimony that Jane Doe 8 has in any way fabricated or embellished her allegations that you sexually abused her during her childhood? MR. PIKE: Form. fh THE WITNESS: I believe the jury will make that}; decision, Mr. Horowitz. I believe that they will E understand that many of these claims put together ‘by your partner who was suspended for improper practice in the State of Florida, who could no longer practice law at least temporarily ~ I understand that Mr. Edwards’ partner who's in jail potentially the rest of his I life for 23 (Pages 278 to 281) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291~DEPO (3376)

OCOIAHSWNH MR. HOROWITZ: Page 282 Page 284 fabricating cases of a sexual nature. Many of 1 Q > Mr. Epstein, you don't deny that you sexually Mr. Edwards' partners on their way to jail for the 2 abused -rest of their life for fabricating cases of a 3 A Huh? . sexual nature, I'd like to answer each one of your 4 Q Mr. Epstein, you don't deny that you sexually questions regarding Jane Doe 8 and your other 5 abused Jane Doe 8, do you? women, however, on advice of counsel today, I 6 MR. PIKE: Form. cannot, And I am told that if | choose to do so, 7 THE WITNESS: Mr. Horowitz, these sexually --[} and not assert my rights under the Sixth, Fifth and 8 this sexual abuse types of questions, which T'dbe Fourteenth Amendment, I risk waiving those rights 9 more than happy to answer, had it not been for my and losing his representation. 10 attorneys instructing me that I must assert my LE BY MR. HOROWITZ: 11 Fourteenth Amendment, Sixth Amendment and Fifth) Q Mr. Epstein, did you pay C.MLA. to bring Jane | 12 Amendment Rights, 1 -- I wish 1 could answer the Doe 8 to your home? 13 question because Mr. Edwards' partner, Scott MR. PIKE: Form. 14 Rothstein, who's in jail for fabricating cases of a THE WITNESS: 1 believe -- again, | would like | 15 sexual nature against wealthy individuals in South to answer all questions regarding C.M.A., I 16 Florida -- it's no secret. Most of the people -believe, an admitted prostitute, drug addict and 17 many of the people here, I'm sure, know that his her -- and anything to do with your Jane Doe 8 18 partners are -- many of them are in jail, many are claims. However, today, my counsel has advised me| 19 on the way to jail, Though -- though -- so though that I must, at least today, assert my rights under 20 T would like to answer the questions regarding the Fifth, Sixth and Fourteenth Amendment. And 21 questions of a sexual nature, my attorneys at least though I would prefer to answer each one of your 22 for today, at least for today, have said I may questions, Mr. Horowitz, he’s told me that if [ 23 not. And if I choose to do so, which they know is choose to do so, | risk losing his representation 24 my preference, they have told me I risk losing and/or waiving my rights. 25 their represent and/or waiving my rights, Page 283 BY MR. HOROWITZ: 1 BY MR. HOROWITZ: Q = Mr. Epstein, did you instruct S.K. to call 2 Q Isn'tit true, sit, that you are asserting your | C.M.A. on the telephone to arrange for Jane Doe 8 to 3 Fifth Amendment privilege today with regard to questions [: come back and give you another massage? 4 — about Jane Doe 8 because you did in fact sexually abuse MR. PIKE: Form. 5 Jane Doe 8 during her childhood? THE WITNESS: To give me -- excuse me? 6 MR. PIKE: Form. BY MR, HOROWITZ: 7 THE WITNESS: I'm asserting my Fifth Amendment] Q One more time. Did you instruct S.K, to call 8 Sixth Amendment and Fourteenth Amendment Right as C.M.A. on the telephone to make arrangements for Jane 9 advised by my counsel, as a right of every American Doe 8 to come back to your home for more sexual 10 to protect themselves from malicious, false claims, activity? AL similar to the ones that your colleague here, MR. PIKE: Form. 12 Mr. Edwards‘ pariner is in jail for, fabricating by THE WITNESS: I'd like to answer every question | 13 sexual -- cases of a sexual nature, called by the that you posed today regarding your Jane Doe 8 14 U.S. Attorney the Jargest fraud in South Florida's claims, of her relationship with C.M.A. However, 15 history, his firm of 70 partners considered a my attorneys have counseled me that at least today 16 criminal enterprise for basically fabricating case J must assert my Fourteenth Amendment, Sixth 17 -- cases of a sexual nature ~~ sexually charged Amendment and Fifth Amendment Rights. Though I'd 18 nature, So though I would like nothing more than prefer to answer each one of the questions, my 19 to answer the questions that you've posed here attorneys told me that if I choose to do so, I risk 20 today regarding your cases, Mr. Horowitz, I've been losing his representation and/or waiving those 21 told that if | choose to answer those questions, I rights. 22 risk losing my counsel's representation and waiving T believe the air conditioning has just gone 23 those rights. off. Page 285 BY MR. HOROWITZ: your mind, (Pages 282 to 285) why shouldn't UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 286 the jury infer from your testimony today that you did, in fact, sexually abuse Jane Doe 8 when she was a child given that you've been asserting a Fifth Amendment privilege? MR. PIKE: Form, THE WITNESS: I --{ believe the jury sill see through your meager attempt that simply Suggesting that my asserting a Fifth Amendment privilege that's used to protect innocent people from malicious sexually charged cases similar to the ones where Mr. Edwards' partner is in jail for the rest of his life, with many of his other partners on the way to spend the rest of their life in jail for the cases of a -- for fabricating a malicious case and stealing money from local Floridians. So I'd like to answer each and every one of the questions posed by you here today, Mr. Horowitz. However, my attorneys have instructed me that | must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Right. So though I'd prefer to answer the question, my counsel has told me that if | do so, I risk Josing his representation and potentially waiving those rights. BY MR. HOROWITZ: Q Mr. Epstein, your counsel indicated to me that Page 288 an answer. He never gave an answer. MR. HOROWITZ: Okay. Are you withdrawing tha: objection? MR. PIKE: I am going to let him respond to your question. MR. HOROWITZ: So are you withdrawing the objection? ‘MR. PIKE: There's no reason to withdraw the objection prior to, You're asking the question again, I'm allowing him to answer. MR. HOROW!TZ:; I'll ask the question -- just to be -- have a clear record, I am going to ask the question again. MR. PIKE: Yes. BY MR. HOROWITZ: Q Mr. Epstein, identify all of your health care providers for the past ten years, including, without limitation, psychologists, psychiatrists, mental health counselors, physicians, hospitals and treatment facilities? MR. PIKE: With respect to the order -- I believe the order said psychiatrists and psychologists. I don't think it went on -- I think it actually limited, and if you recall, the additional hospitals and providers. So having Page 287 you wanted to possibly change an answer that you had given me earlier concerning your health care providers that you've kad in the past ten years. My question for you is -MR. PIKE: Well ~ MR. HOROWITZ: Let me finish the question, then| you could -MR. PIKE: Go ahead. BY MR. HOROWITZ; Q_ -- identify for us your health care providers for -- in the past ten years, including without limitation, psychologists, psychiatrists, mental health counselors, physicians, medica! doctors, hospitals and treatment facilities? MR, PIKE: Wait a second, let me be clear. 1 did not teil you that Mr. Epstein wanted to change his answer. Basically { objected and instructed. him not to answer a particular question because you did not have the order or the interrogatory or the request for production that you were referencing. Ata break you had showed me those particular documents ~~ two of them, Not the order itself. And as a result, I agreed to allow you to ask Mr. Epstein the question so we didn't have to come a courtesy. So J didn't tell him to Page 289 [ stated that, Mr. Epstein can identify for you the psychologist and/or psychiatrist that he has been seen by within the Jast ten years, but he will not elaborate on his answer if it would invade attorney-client work product, ‘MR. HOROWITZ: Okay. So you answer ~~ as toa portion of the question, you're instructing him not to answer; is that right? MR. PIKE: Consistent with the order. MR. HOROWITZ: That's your version of the order, MR. PIKE: Do you have the order. MR. HOROWITZ: You do. It was mailed to you. MR. PIKE: Do you have the order here today’? MR. HOROWITZ: No. MR. PIKE: Okay. MR. HOROWITZ: ! know what it says, though. Can -- can we -- can we just get a question -- an answer to the question? MR, PIKE: Sure. MR. HOROWITZ: Did you understand the question? THE WITNESS: Dr, Steve Alexander and Dr. Steven Strumwasser. BY MR. HOROWITZ: Steven Alexander, what is hi 25 (Pages 286 to 289) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

area of practice? A. Psychology. Q And where does he practice? A In Palm Beach. Q And between what period of time -- during what period of time did you receive a -- either treatment or a consultation from him? MR. PIKE: I'm going to instruct him not to answer because that's attorney-client work product. MR. HOROWITZ: Okay. It’s attorney-client as to MR. PIKE: And work product. MR. HOROWITZ: Okay. All right. MR. PIKE: You didn't ask him who hired those individuals, MR, HOROWITZ: Okay. 1 don't need to know that. MR. PIKE: Sure, if-- you're raising your eyebrows as if you're concerned with regard to the objection. That shows -- -MR. HOROWITZ: I'm not going to deal with it today with you -THE REPORTER: One ata time. MR. PIKE: -- that shows some sort of bewilderment as to why I'm raising the objection. Q Do you go to his office ~ A Ne. Q > - or does he come to you? A I've~ MR. PIKE: I'm going to instruct him not to answer that question. BY MR. HOROWITZ: EE Q Does Doctor -- do you see Dr. Alexander at his office — MR, PIKE: Fim going to instruct him ~ BY MR. HOROWITZ: Q -- or does he come see you? MR. PIKE: I'm going to instruct him not to answer that question, also overbroad. BY MR. HOROWITZ: . Q Okay. Between 2001 and 2006, using those twok years as sort of a bookmark, did your sexual interests include looking at girls under the age of 18 while they F were undressed? MR. PIKE: Form. MR. HOROWITZ: Fd like to answer each and every one of your questions here today, Mr. Horowitz. I'm going to answer that question like I've answered mostly all your other questions, which is on advice of counsel, they've asked me to Page 291 So what I'm doing is, just allowing you the opportunity to ask the appropriate question so you understand the objection, that's ail. BY MR. HOROWITZ: Q Okay. Were you under the care of Steven Alexander before any investigation into criminal activity began? MR. PIKE: I'm going to instruct him not to answer that question. BY MR. HOROWITZ: Q Were you under the other doctor -- am I saying this right, Strumwasser? Yes, sir. What is his area of specialty? Psychology. Does he have a subspecialty? I don't know, Were you under his care or treatment before any| investigation into a criminal activity occurred? MR. PIKE: Again, I'm going to instruct him not answer, work product. BY MR. HOROWITZ; Q > Okay. And where is Dr, Strumwasser's office located? A Somewhere i in Florida. Page 293 assert my Fourteenth Amendment Right, my Sixth Amendment Right, my Fifth Amendment Right. So though I'd like to answer each and every one of your questions, I'm going to have to assert those rights today. BY MR. HOROWITZ: Q Between 2001 and 2006 did your sexual interests include looking at the breasts and vaginal area of girls between the ages of 12 and 17? MR, PIKE: Form. THE WITNESS: I'm going to answer that question like I've answered any -- most of your other questions here today, which is on advice of counsel, I'm going to have to assert my rights ; under the Fourteenth Amendment, the Sixth Amendmen} and Fifth Amendment. BY MR. HOROWITZ: Q Between 2001 and 2006 did your sexual interests include digitally penetrating the vaginas of girls between the ages of 12 and 17? MR. PIKE: Form. THE WITNESS: I find these questions -~ I'd like to answer every one of those questions. However, my counsel has told me I may not today, 1 wish I could answer those questions | with respe 26 (Pages 290 ‘to 5 293) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 294 or directly to your partner that filed most of these lawsuits, however, he's been suspended from the Florida Bar, Td like to answer these questions to Mr. Edwards' partner, but he's in jail for fabricating cases of a sexually charged nature against wealthy people and stealing millions of dollars from local South Floridians. So though 1 would prefer to answer these question, I've been told by my counsel that if 1 choose to do so, 1 risk losing his representation and waiving my rights, BY MR. HOROWITZ: Q Between 200! and 2006 did your sexual interests include masturbating on a massage table in the presence of girls under the age of 187 MR. PIKE: Form. And -- and ~ and let me -let me interject here for a second. I -- I noticed that the tenor of the questions has changed since we've been in deposition for over seven hours, and I noticed that you have a list of questions toward the back of your outline there (indicating) that seems to be not really detailed or relevant to your clients, Nov MR. HOROWITZ; I don't know what outline you're, e CYBRIAHHVeWdhE Page 296 MR. PIKE: Form. THE WITNESS: I'd like to answer every one of your questions here today regarding all your claims of these girls, however, my attorneys have E counseled me today that I must assert my Fourteenth [f Amendment, Sixth Amendment and Fifth Amendmen@ Right. So though I would like to answer the E question, I'm told that if I do so, I risk losing his representation and/or waiving those rights. BY MR. HOROWITZ: Q Mr. Epstein, between 2001 and 2006 did your interest include paying girls under the age of 18 for massages of a sexual nature? MR. PIKE: Form. THE WITNESS: I would really like to answer every one of your questions here today, Mr. Horowitz. Unfortunately I am going to have to answer that question like I've answered many of your other questions, on advice of my counsel who's suggested that { must assert my rights under the Fourteenth, Fifth Amendment and Sixth Amendment. Though } would greatly prefer to answer these [: questions, my attorneys told me that if { choose to do so, I risk losing his representation and waiving my rights. Page 295 looking at. Are you looking at my outline? MR. PIKE: -- I'm not finished -~ MR. HOROWITZ: Continue. MR. PIKE: -- I just want to make a clean record, okay? Mr. Edwards is very -- is very well aware, and I'm very well aware, that no matter what your understanding as of -- as of this case and what you're trying to prove and what burden you're trying to meet, cannot use this deposition as a means to harass Mr. Epstein or any other client. His sexual interests in general, as you're asking them, is argumentative and it's harassing, and I'm only going to let it go on for a little bit longer, okay? MR. HOROWITZ: Okay. MR. PIKE: So if you would, try to rephrase your question -MR. HOROWITZ: Okay. MR. PIKE: -- because we've been here a long time, and -- and -- and 1 know what you're trying to do here. BY MR. HOROWITZ: Q Between 2001 and 2006, Mr. Epstein, would it arouse you to nave, underage girls talk about their sex life while the BY MR. HOROWITZ: Q Between 2001 and 2006 did you have a room in your home in Palm Beach County where you received massages? MR. PIKE: -Form. THE WITNESS: I am going to have to answer tha question the same way I've answered most of your other questions here today, Mr. Horowitz, which is on advice of my counsel I'm told that J must assert my rights under the Sixth Amendment, Fourteenth Amendment and Fifth Amendment. And though I'd prefer to answer those questions, my attorneys told me that if I choose to do so, I risk losing their representation or waiving my rights. BY MR, HOROWITZ: Q Between 200] and 2006, at your home in Palm Beach, did you have sexual contact with over 30 girls under the age of 18 in your massage room? MR. PIKE: Form. i THE WITNESS: I would like to answer each one |; of your claims today, Mr. Horowitz. However, my attorneys have counseled me that I may not answer any questions that may be relevant to any of your lawsuits brought by you, your partner who's been suspended from the practice of Jawi in South 27 (Pages 294 to 297) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 298 order to steal millions of dollars from local Floridians. The. U.S. Attome; called some of these 1 Florida, Mr. Edwards' partner, Scott Rothstein, who} = 1 fictitious cases part of the perpetration of the 2 sits -- spending the rest of his life in jail for 2 largest fraud in South Florida's history, calling 3 fabricating cases. I'd like to answer every one of 3 Mr, Edwaeds' firm a criminal enterprise. 4 your questions, but today, my attorney told me 1 4 Your partner is not here today because he's 5 cannot, at least today. And if | choose to do so, 5 been suspended after he filed these cases. So 6 Trisk losing his representation and/or waive my 6 though I'd like to answer each and every one of 7 rights. 7 your questions, my counsel has advised me that £ 8 BY MR. HOROWITZ: 8 may not today, And though I'd prefer to do so, he 9 Q Isn't it true, sir, that between 2000 -- isn't 9 said if I choose to do so, I would risk losing his 10 it true, sir, that between 2001 and 2006, you hada very; 10 representation and/or waiving my rights. 11 specific method for sexually abusing girls between the} 11 BY MR. HOROWITZ: 12 ages of {2 and 13 in your Palm Beach County home? | 12 Q Mr. Epstein, between 2001 and 2006 you paid 13; A You continue to use -- 13 people to recruit and solicit girls to come to your home 14 MR. PIKE: Form. 14 who were between the ages of 13 and 17, whereupon yor 15 THE WITNESS: -- hub. Again, these questions; 15 would engage in sexual activity with them; isn't that 16 I believe the jury is going to see through, 16 ~~ right? 17 Mr. Horowitz. These are questions similar to the 17 MR. PIKE: Form, 18 ones that people have suggested Mr. Edwards! 18 MR. HOROWITZ: Again, I'm sure, Mr. Horowitz, 19 partner, Scott Rothstein, who's spending the rest 19 the jury will be able to see through your questions 20 of his life in jail for fabricating cases of a 20 of a sexually charged nature. I'd like to answer 21 sexually charged nature, has tried to convince 21 each one of your questions. However, my attorneys 22 investors in South Florida, that he stole millions 22 have counseled me that today at least, I may not. 23 of dollars based on sexually charged cases similar 23 I must assert my rights under the Fourteenth, Sixth 24 to these claims that you've made. I'd like to 24 and Fifth Amendment. The questions of a sexually 25 answer each one of your questions today. However,] 25 charged nature don't surprise me. They're similar Page 299 Page 301 L my attorneys have counseled me that ] may not 1 in nature to the sexually charged cases that 2 answer any questions that may be relevant fo any of 2 Mr. Edwards’ partner currently sits in jail for ~~ 3 your lawsuits. 3 for the rest of his life. 4 BY MR. HOROWITZ: 4 A 70-man law firm filed bankruptcy, called by 5 Q Between 2000 -- 5 the U.S. Attorney a criminal enterprise, 6 A Excuse me. 6 perpetrating one of the largest frauds in South 7 Q Go ahead. 7 Florida history by crafting cases of a sexually 8 A And though I'd prefer to answer the question, 8 charged nature in order to fleece local Floridians 9 my attorneys have counseled me that if I do so, I ask -- 9 of thousands and thousands of dollars. So though 10 excuse me -- bless you -- | risk losing their 10 I'd like to answer each one of your questions, 11 representation and/or waiving my rights. a. today at the advice of counsel, I cannot. And 12. BY MR. HOROWITZ: 12 though I'd like to answer it, my counsel has told 13 Q Between 2001 and 2006 you targeted a specific 13 me that if I choose to do so, I risk losing his 14 age of girls between 13 and 17 for sexual abuse in your | 14 representation and/or waiving my rights. 15 home; isn't that right? 15 BY MR. HOROWITZ: 16 MR. PIKE: Form. 16 Q Mr. Epstein, between 2001, 2006 you paid 17 THE WITNESS: These type of questions, sexually, 17 someone to schedule appointments by telephone for girlg: 18 charged questions, I believe the jury will be able 18 between the ages of 13 and 17 to come to your home forf? 19 to see through, Mr. Horowitz. They're similar to 19 sexual activity with you; isn't that right? E 20 the claims and charges and that Mr, Roth — 20 MR. PIKE: Form. 2. Mr. Edwards' partner, Scott Rothstein, sits 21 THE WITNESS: These claims of a sexually 22 currently in jail for the rest of his life, 22 charged nature I would very much like to answer 23 fabricating cases of a sexual nature simply in 23 today with great specificity, But as most of your TERI ST I RET AAT SC TR I STAI Te AO CCRT ET questions have been answered today, I, on the advice of. counsel, have had to invoke my Sixth “28 (Pages 298 to 301) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291~DEPO (3376)

Page 302 Page 304 girls. However, today, my counsel has informed me that I must assert my rights under the Fourteenth, and Fifth Amendment to iestion that may 1 Amendment, Fourteenth Amendment and Fifth Amendment 1 be relevant to any of the lawsuits brought by you, 2 Rights, Though I'd prefer to speak to your partner 2 your partner of your firm who's been found after he 3 who's not here because he's been suspended from the 3 filed these claims to have committed improper acts 4 practice of law in South Florida after he's filed 4 and has been suspended from the practice of law in 5 these cases, held a big press conference, 5 South Florida, or the cases brought by Mr. Edwards! 6 Mr. Edwards' partner who's in jail for the rest 6 whose those firm has been described by the U.S. 7 of his life it appears for fabricating fictitious 7 Attorney as a criminal enterprise of a -- of 70 8 cases of a sexually charged nature. So though I'd 8 attorneys, where his senior partner is spending the 3 like to answer every one of your questions with 9 rest of his life in jail for fabricating cases of a 10 great specificity, I've been told by my counsel if 10 sexually charged nature against people in South 5 12 I choose to do so, I risk losing his representation 1. Florida, wealthy people, in order to fleece : 12 and waiving those rights. Five minutes? 12 unsuspecting investors out of their life savings. 13 MR. HOROWITZ: If that's what you need. 13 So though I'd like to answer that question, : 14 THE WITNESS: Is that okay? Is that okay? 14 Mr. Horowitz, very much so like to answer that E 1s MR. EDWARDS: Break. is question, I've been informed that if 1 chose to do B 16 THE WITNESS: Five minutes? 16 50, [ risk losing the representation of my counsel B 7 MR. EDWARDS: Break as long as you want, 17 and waiving my rights. FE 18 THE VIDEOGRAPHER: Okay. Time off the record 18 BY MR. HOROWITZ: B 19 5:33. 19 Q Okay. And with regard to the underage girls ; 20 (Thereupon, a short break was taken.) 20 — who you had sexual contact with at your home between E 21 THE VIDEOGRAPHER: Back on the record 5:41. 21 2001 and 2006, you had a common scheme of paying then} 22 BY MR. HOROWITZ: 22 between 2 to $300 each, each time they came; is that E 23 Q Mr. Epstein, with regard to the girls who were 23 right? 24 at your Palm Beach County home between 2001 and 2006 24 MR. PIKE: Form. H with whom you had sexual activity, nearly all of these 25 THE WITNESS: I would very much like to answer E Page 303 Page 305 i 1 girls were high school students in Palm Beach County; 1 all the questions about the claims -- the so-called L 2 — isn't that right? 2 claims of all your girls, of all your young women, 3 MR. PIKE: Form. 3 represented by your firm, represented initially by q 4 THE WITNESS: I'd fike to answer all of your 4 your partner who was suspended by the Florida Bar |: 5 questions here today, Mr. Horowitz, about all the 5 for improper behavior, He's not here because of 6 claims made by the girls you represent. However, 6 that -- excuse me -- the claims of Mr. Edwards’ : 7 on advice of my counsel at least today, they've 7 clients, some admitted prostitutes. His partner is q 8 instructed me to assert my Fourteenth Amendment 8 in jail for the rest of his life for fabricating E 9 Right, my Sixth Amendment Right and my Fifth 9 cases of a sexually charged nature against people 10 Amendment Right. So though I would prefer to 10 in South Florida in it -- in order to fleece some 1 answer the questions, if | choose to do so, I'm 11 of the people out of their life savings. Yes, I'd iE 12 informed that I risk losing my counsel's 12 very much like to answer each and every one of your}! 13 representation and/or waiving my rights. 13 questions, however, today, on advice of counsel, | i 14 BY MR. HOROWITZ: 14 cannot. E 1s Q > And with regard to the girls under the age of 15 BY MR. HOROWITZ: ; 16 18 who came to your home in 2001 through 2006, your 16 Q With regard to the underage girls who came to |: 17 purpose in having them come to your home was for sexual 17 your home between 2001 and 2006 -- le 18 activity, but they were told they were coming to your 18 A Would you let me finish? Would you mind if 1 ; home to give a massage; isn't that right? 19 finish. I'm sorry. I choose -- 1 would -- I haven't ib MR. PIKE: Form. 20 finished. LE THE WITNESS: I'd like to answer each and every | 21 Q You have not finished. Would you like to lr one of your questions about the claims of your 22 finish? } i i A Yes, if { could. (Pages 302 to 305) 29 UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

each of them to undress in your presence while giving you a mnassage, ak that Fight? Page 306 1 questions, my counse! has told me that if1 do so, 1 1 MR. PIKE: Form. 2 risk losing his representation and potentially waiving 2 THE WITNESS: I'd like to answer that question, |, 3 my rights. Sorry, Go ahead. 3 like I'd like to answer most of your other E 4 Q > With régard to the girls who came to your home 4 questions here today with respect to the claims of 5 between 2001 through 2006 who were under the age of 18) 5 all these girls. However, my attomeys have told B 6 you knew that each of them was not a trained masseuse, 6 me I may not answer those questions today and must; 7 correct? 7 assert my rights under the Fourteenth, Fifth and 8 MR. PIKE: Form. 8 Sixth Amendment. 9 THE WITNESS: I would like to answer each one 9 So though your partner can't be here -- the 10 of the claims brought by your various girls. 10 partner that filed most of your cases -- because 1h However, today, my counsel has told me that J must aL he's been suspended from practicing law by the 12 hot answer any questions that may be relevant to 22. Florida Bar, or Mr. Edwards' partner who sits to 13 any of the lawsuits brought by your firm, or Mr. 13 your right can't be here because he's in jail for 14 Edwards' firm whose partner sits in jail accused by 14 fleecing people out of their entire life savings by 15 the U.S. Attorney of South Florida of his firm 15 crafting cases of a sexually charged nature. As [ 16 being a criminal enterprise, his partner being in 16 you might imagine, | would like to answer each and |; 17 jail for the rest of his life accused by the United 17 every one of your questions, but at least today, I 18 States Government of fabricating cases of a 18 cannot, because if] choose to do so, I'm told by 419 sexually chasge nature in order to fleece local 19 my counsel that I risk losing their representation 20 investors out of their life savings. So though I'd 20 and waiving my rights. 21 like to answer those questions, Mr. Horowitz -- 21 BY MR.HOROWITZ: 22 very much so, in fact, my attorneys have told me 22 Q With regard to all of the underage girls who 23 that if I choose to do so, | risk losing their 23 came to your home between 2001 and 2006, isn't it true} 24 representation and waiving my rights. 24 that you touched all of them on either their breasts, 25 BY MR. HOROWITZ: 25 vagina, buttocks, or some combination of those three Page 307 Page 309 a Q Okay. With regard to all of the underage girls 1 parts? 2. who came to your home between 2001 and 2006, you kney 2 MR. PIKE: Form. 3 each them was under the age of 18; is that right? 3 THE WITNESS: I'd like to answer every one of 4 MR. PIKE: Form. 4 those questions with great specificity, however, 5 THE WITNESS: [ am going to have to respond to 5 today, my attorneys have advised me that any 6 that question the way I've responded to most of 6 question that may be relevant to any of the 7% your questions here today. I'd like to respond to 7 lawsuits filed by your firm, your firm whose 8 every one of your questions with respect fo all 8 partner has been suspended by the Florida Bar for 9 these claims made by your clients, claims filed by 9 improper behavior, cases filed by Mr. Edwards' firm 10 your partner who's not here because he’s been 10 whose partner sits in jail for the rest of his 1 suspended from practicing law in the State of 11 life, accused and pled guilty, [ believe, to 12 Florida -- in fact, practicing law anywhere, or 12 fleecing investors out of some of their life 13 Mr, Edwards' partner who's in jail for the rest of 13 savings and like crafting cases of a sexually 14 his life for fleecing local investors out of their 14 charged nature. I'd like to answer every one of 15 life savings by crafting cases of a sexually 15 your questions with great specificity. However, 16 charged nature, I'd like to answer every one of 16 I'm told by my counsel if I choose to do so, | risk 17 your questions, but my counsel has advised me ] may a7 josing his representation and waiving my rights. 18 not today. And if I choose to do so, which is my 18 BY MR. HOROWITZ: 19 preference, I risk losing his representation and/or 19 Q Between 2001 and 2006 did you keep sexual toys 20 waiving my right. 20 for your own use in your Palm Beach County home? 24 BY MR. HOROWITZ: 2i MR. PIKE: Form. 22 Q And with regard to all of the underage girls 22 THE WITNESS: I'd like to answer that 23 who came to your home between 2001 and 2006, you asked 23 question. I'd like to answer the questions of all your claims regarding your girls that you're 2 Unfortunately y your -parner can tt BS 30 (Pages 306 to 309) UNIVERSAL COURT REPORTING 712-2600 (954) (877) 291-DEPO (3376)

Page 310 here because he's been suspended from practicing law. So though I'd like to answer your questions, I've been advised by my counsel that I cannot today. I must assert my rights under the Fourteenth, Sixth and Fifth Amendment. And though} T'd like to answer each one of these questions with great specificity, I'm told that if I choose to do so, I risk losing his representation and waiving my rights. BY MR. HOROWITZ: Q Between 2001 and 2006, isn't it true that you used sexual toys on underage girls in Palm Beach County? MR. PIKE: Form. THE WITNESS: { would like to answer every one, of your questions regarding these claims by your girls, but on advice of counsel today, I've been told that I must assert my rights under the Fifth, Sixth and Fourteenth Amendment, I'd prefer to, in fact, assert those rights to your partner who has been suspended by the Florida Bar since filing these sexually charged cases, or Mr. Edwards’ partner who sits next to you, for his partner who's now sitting -- spending the rest of his life in. jail accused of stealing the life savings of many wed Fs Hew Page 312 assert the Fifth — MR. PIKE: Well, you want — you want to be here asking the same question —~ let me -- let me get this straight. Despite the fact that the Court has -- because I'm working on time, all right? So despite the fact that the Court has already made a ruling on a number of issues covered by the Fifth Amendment, you still want to ask those questions again while you're here at deposition just to have Mr. Epstein invoke the Fifth Amendment, correct? MR. HOROWITZ: Well, you don't know what questions I intend to ask. 1 have some very specific questions about his net worth that have not been addressed by any Court. BY MR. HOROWITZ: Q Okay. Is your net worth over one billion dollars, sir? THE WITNESS: On advise of counsel, I am goi to have to invoke the Fifth Amendment, Sixth Amendment and Fourteenth Amendment. BY MR. HOROWITZ: Q_ Doyov either own or have a beneficial interest in the property located at 358 Brillo (phonetic) Way in Palm Beach, Florida? A I'mgoing to have to invoke my Fifth Amendment}i Page 311 Floridians by crafting sexually -- cases of a sexually charged nature. So though I would like to answer each and every one of your questions, Mr. Horowitz, today, I'm told if I choose to do so, Trisk losing the representation of my counsel and waiving my rights. BY MR. HOROWITZ: Q > What is your net worth at the present time? MR. PIKE: Form. I'm going to instruct him not to answer that question. There's no -- the Court has already ruled on that. Pursuant to the Court's order, your order, and Mr. Edwards' order. MR. HOROWITZ: Are you instructing him not to answer? MR. EDWARDS: My order? MR. PIKE: Yeah. MR. HOROWITZ: Are you instructing him not to answer? MR. PIKE: It's already -- it's already been tuled on by the Court that Mr. Epstein does not have to answer any net worth information, That order just came out, What's the purpose in -MR. HOROWITZ: I believe what the Court said is that it sustained his Fifth Amendment privilege, so he’s i UNIVERSAL COURT (954) 712-2600 (877) Page 313 q Sixth Amendment and Fourteenth Amendment Right. Q Do you either own or have a beneficial interest in the property located at 9 East 71st Street in New York, New York? A Qn advice of my counsel, | am going to have to invoke my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Right. Q Do you either own or have a beneficial interest in the property located at 49 Zorro (phonetic) Ranch Road in Stanley, New Mexico? A On advice of my counsel, Mr. Horowitz, though I'd like to answer these questions, my counsel has advised me that I must invoke my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Right. Q Do you either own or have a beneficial interest in a property located at 301 East 66th Street in New York, New York? A Again, Mr. Horowitz, I'll have to answer that question, as I've answered mostly all your other questions here today, though I'd like to answer each one with specificity, my counsel has advised me that I must invoke my -- excuse me -- my Sixth Amendment Right, my Fifth Amendment Right and Fourteenth Amendment Right, s on the ~ if [+ though I'd prefer to answer these that if choose to do so, 1 isk 31 (Pages 310 to “313) REPORTING 291~DEPO (3376)

Page 314 losing the representation of my counsel and waiving those rights. MR. PIKE: Before -- before you start another question there, I just want to be clear for the record that you said on the record that these questions that you had prepared were going to be specifically detailed, and that they were not addressed by the Court, but, in fact, you've gone on with seven to eight questions, and all of which have been directly addressed by the Court, Now, I'm here. I'm here. I'm here. I've unbuttoned my tie. I've -- my button -- I've pulled my tie out. I'm here for the nights for you, but are you really going to waste our time with questions that the Court has already ruled on? MR. HOROWITZ: Allright. I'm not here for the entire night with you, okay? I've got places to be. I've got a plane to catch. I'm going to try to get through as much as I can, but there's a point in time where I've got to go, okay? MR. PIKE: Okay. I understand. MR. HOROWITZ: I'm not going to get into a banter with you right now. We're going to continue with these questions. We're going to get done with Page 315 as much as we can. MR. PIKE: That's fine. | just want to bring it up with the Court that you've gone on and you've asked a ton of questions here today that have already been covered by the Court's order that -that of which you and I have spent a fot of time on with regard to motion practice. BY MR. HOROWITZ: Q Okay. Do you either own or have a beneficial interest in the property located at 457 Madison Avenue, Fourth Floor? A Though I'd like to answer each and every one of your questions with respect to these issues, on advice of counsel, I'm going to have to invoke my Fourteenth Amendment, Sixth Amendment and Fifth Amendment Right Q Do you either own or have a beneficial interest in the property located at 14 Wall Street? A As] said before, I'm going to -- as I've answered most of these other questions, I'm going to have to invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment Right, though I'd prefer to answer these questions. Q Do you either own or have a beneficial interest in the property located at 8000 Walton Parkway in New Albany, Ohio? UNIVERSAL COURT (877) 291-DEPO (3376) (954) 712-2600 Page 316 MR. PIKE: Form to all these net worth questions. Are we in agreement there? | MR. HOROWITZ: No, I -- I think you waived it when you didn't answer -- assert those before. MR. PIKE: That's fine. THE WITNESS: I'd like to answer each one of those questions, but today, under advice of counsel, I'm going to have to assert my Fourteenth = ff Amendment, Fifth Amendment and Sixth Amendment! Right, Mr. Horowitz. i BY MR. HOROWITZ: Q Do you either own or have a beneficial interest in -- in islands known as Little St. James in the U.S. Virgin Islands? MR. PIKE: Form, and for the record I can't waive Fifth, Go ahead. that question, but on advice of counsel, I'm going to assert my Fifth Amendment, Sixth Amendment and} Fourteenth Amendment Right. BY MR. HOROWITZ: Q Do you either own or have a beneficial interest in the property located -- in a property located in the Westminster neighborhood in London, England? MR. PIKE: Form. Page 317 THE WITNESS: On advice of counsel, I'm going to invoke my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Right. BY MR, HOROWITZ: Q Do you either own or have a beneficial interest in the property located -- at a -- strike that. Do you either own or have a beneficial interest in any property located on Avenue Folk (phonetic) in Paris, France? MR. PIKE: Form. THE WITNESS: I'm going to answer that question, as I've answered all your other questions with respect to these issues, which is I am going to have to invoke my Fifth Amendment, Sixth Amendment and Fourteenth Amendment Right. BY MR. HOROWITZ: Q Sir, 1 am going to hand you a document -- we'll mark it as Exhibit 1 -- it's -- it's -- it's from the Florida Department of Law Enforcement Sexual Offender’ $i and Predator’s Flyer bearing your name, and on top it says, “Vehicle and Vessel information." You can take a look af it for a moment with your ~~ you and counsel. My question is simply going to be: Is this an accurate list of the vehicles and vessels that you own as of 32 “(Pages 314 to 317) REPORTING

[ E Page 318 Page 320 1 A. Jam going to respond to that question, i MR. PIKE: Form. 2 Mr. Horowitz, as I've responded to every other question 2 THE WITNESS: I would like to answer that 3 teday virtually, which is 1 am going to have to invoke 3 question, but I am going'to have to answer the same 4 — my Fifth Amendment, Sixth Amendment and Fourteenth 4 way I've answered most of your other questions 5 Amendment Right. 5 today, which is my counse] has informed me that any i 6 MR. HOROWITZ: Okay, 6 questions relevant to these lawsuits, | must invoke 7 MR. PIKE: Form. 7 my Sixth Amendment, Fifth Amendment and Fourteenti{ 8 BY MR. HOROWITZ: 8 Amendment Right. 9 Q With respect to the vehicles and vessels listed 9 BYMR. HOROWITZ: 10 — on Document | -- Exhibit 1, are there any vehicles on 10 Q Since the first lawsuit was filed agains! you 12 that list that you do not own or have a beneficial 11 alleging childhood sexual abuse, isn't it true that your 12 interest in at the present time? 12 efforts to conceal your assets have included placing 13 MR. PIKE: Form, 13 money in the accounts of corporations in which you have 14 THE WITNESS: I'm going to assert my Fifth 14 abeneficial interest? 15 Amendment, Sixth Amendment and Fourteenth Amendment 15 MR. PIKE: Form. 16 Rights. 16 THE WITNESS: Mr. Horowitz, I'm going to answer? 1? BY MR. HOROWITZ: 1? that question, as I've answered most of your other 18 Q And with respect to the vehicles and vessels on 18 questions here today. My counsel has informed me 19 Exhibit 1, are there any other vehicles or vessels not 19 that | cannot answer any questions that may be 20 on that list which you -- which you own? 20 relevant to your lawsuits, so therefore, | must 21 MR. PIKE: Forto. 21 invoke my Fourteenth Amendment Rights, my sixth 22 THE WITNESS: I'm going to answer that 22 Amendment Rights and my Fifth Amendment Rights. 23 question, as I've answered most of your other 23 BY MR. HOROWITZ: 24 questions here today, which is I am going to have 24 Q Since the filing of the first lawsuit against 25 to invoke my Fifth Amendment, Sixth Amendment and 25 you in which it was alleged that you committed sexual Page 319 Page 3215 1 Fourteenth Amendment Right. 1 abuse -2 BY MR. HOROWITZ: 2 THE REPORTER: Committed -- I'm sorry? 3 Q And in the past two years isn't it true, sir, 3 MR. HOROWITZ: I'm sorry, I'll slow down a 4 that you have transferred vehicles and ~ vehicles, 4 little bit. 5 vessels or aircrafts out of your own name to other 5 BY MR. HOROWITZ: . 6 parties in an effort to defraud potential creditors? 6 Q Since the filing of the first lawsuit against 7 MR. PIKE: Form. 7 you in which it was alleged that you committed childhood? 8 THE WITNESS: Unfortunately I'd like to answer 8 — sexual abuse, have you expended money to pay forthe § 9 all of those questions, but on the advice of 9 — lawyers of witnesses in -- in the lawsuit? 10 counsel here today, I cannot answer any questions 10 MR. PIKE: Form. 11 that may be relevant to any of the lawsuits. 11 THE WITNESS: Mr. Horowitz, I'm going to answei} 12. BY MR. HOROWITZ: 12 that question the way I've answered most of your i 13 Q Allright. Since the first civil lawsuit was 13 other questions here today, which is though I'd 14 filed against you alleging childhood sexual abuse, have | 14 like to answer those questions, I've been advised 15 you been taking steps to hide and conceal your assets? 15 by my counsel that I may not. And if] choose to 16 MR. PIKE: Form. 16 do so, and not invoke my Fourteenth, Sixth and 17 THE WITNESS: I would like to answer that 17 Fifth Amendment Rights which [ am hereby doing, ; 18 question with specificity, however, my counsel has 18 that if | answer those questions | lose -19 advised me that { must invoke my Fourieenth 19 potentially lose his representation and/or waive my E 20 Amendment, Sixth Amendment and Fifth Amendment 20 rights. li 21 Right. 21 BY MR. HOROWITZ: 22 BY MR. HOROWITZ: 22 Q Did you have surveillance cameras in either the k 23 Q Isn't it true, sir, that your efforts to 23 _ interior or exterior of your home on ~- at Brillo Way Ee 24 — conceal your assets have included placing money in 24 — between 2001 and 2006? 25 7 s accounts of other (Pages 318 to 321) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 322 1 THE WITNESS: Mr. Horowitz, I'm going to answer 2 that question the same way I've answered most of 3 your other questions here today. I'd like to 4 answer each one of your questions regarding your 5 claims with great specificity, however, my counsel 6 has advised me that 1 may not today, and thereby 7 have to invoke my Pourteenth Amendment Rights, my 8 Sixth Amendment Rights and Fifth Amendment Rights 9 as provided by the U.S, Constitution. So though 10 Fd like to answer those questions, I've been iL informed that if I do so, I risk losing his 12 representation and/or waive my rights. 13 BY MR. HOROWITZ: 14 Q Sit, have you had sexual contact with girls 15 under the age of 18 in New York State in the past ten 16 years? 17 MR. PIKE: Form. 18 THE WITNESS: I'm sorry? 19 BY MR. HOROWITZ: 20 Q Have you, Jeffrey Epstein, had sexual contact 21 — with girls under the age of 18 in New York State within 22 the past ten years? 23 MR. PIKE: Form. 24 THE WITNESS: Mr. Horowitz, I'd like to answer 25 every one of your questions here today about the Page 324 questions of a sexual nature, I would refer to, in fact, direct it to your partner who's been suspended after he filed some of these cases from practicing law -- he got suspended from filing -practicing law in Florida. Mr. Edwards' partner who's in jail for crafting cases of a sexual nature, defrauding investors, local people, out of their life savings by fabricating malicious sexually charged cases. So though I would like to answer each and every one of your questions, today I cannot do so. And I'm told that iff choose to do so, | risk losing the representation of my counsel. BY MR. HOROWITZ: Q Was it your practice between 2001 and 2006 to use your power to infhience minor girls into having sexual contact with you? MR. PIKE: Form. THE WITNESS: I would like to answer each and] every one of your questions. However, my counsel has told me I may not. And though I would prefer to answer, he's told me that if ] choose to, I ~if -- potentially will lose his representation or waive my rights, therefore, I must invoke the rights as protected -- under the Constitution of. 1 claims made by all your girls. However, on advice 2 of my counsel, I've been told that } must invoke my 3 Fourteenth Amendment, Sixth Amendment and Fifth 4 Amendment Rights. Though { would like to answer 5 those questions, I've been told if | choose to do 6 so, I risk losing my counsel's representation 7, and/or waive those rights. 8 BY MR. HOROWITZ: 9 Q Have you had sexual contact with girls under 10 the age of 18 in the State of New Mexico in the past ten 11 years? 12 MR. PIKE: Form, 13 THE WITNESS: Mr. Horowitz, I'm going to answer 14 ‘that question the same way I've answered virtually 15 all of your questions here today. On advice of my 16 counsel -- though | would like to answer those 17 questions -- he's informed me that I must invoke my 18 Sixth Amendment, Fifth Amendment and Fourteenth 19 Amendment Right under the U.S. Constitution. 20 BY MR.HOROWITZ: 21 Q Sir, between 2001 and 2006 was it your practice 22 to use your wealth to influence minor girls to have 23 sexual contact with you? 24 MR. PIKE: Form. IE WI Page 323 Page 325 the Fourteenth Amendment, Sixth Amendment and Fifth} Amendment. BY MR. HOROWITZ: Q Isn't it true, sir, that the real reason that you brought underage girls to your home in Palm Beach County between 2001 to 2006, was that you could get sexual satisfaction? MR. PIKE: Form. THE WITNESS: Mr. Horowitz, I would like to answer each and every one of your questions that you've raised here today. Unfortunately my counsel has advised me that I cannot, and they have instructed me to assert my rights as the -- as under the Fourteenth Amendment, Sixth Amendment an Fifth Amendment of the U.S. constitution. I would prefer to answer those questions. I'd really prefer to answer those questions, but my attorney has told me ] may not. But if { choose to do so, I will risk losing his representation and/or waiving those rights. Five minutes? MR. HOROWITZ: Sure. THE VIDEOGRAPHER: Time off the record 6:05 (Thereupon, a short break was taken.) MR. HOROWITZ: All right. Let me just -THE VIDEOGRAPHER: Time on the record 6: 34 (Pages 322 to 325) RATT TA SR TT TATA TT POSE TT TITRE I TT IT UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 326 MR. HOROWITZ: Allright, Let me just get this} 1 on the record. It's now 6:11 p.m. We've been 2 working all day, as best we can, plowing through so 3 far the claims of my seven clients, and though I 4 have done my very best on my part to get through as 5 much material as I can, I simply cannot finish 6 today, number one, because we've already been 7 working an eight-hour day, and two, maybe more 8 importantly, [ have a plane to catch in about a 9 Jittle bit over an hour. So with that said, I 10 cannot complete today. You know, you can file what! 11 you need to, and I'll file what J need to, but -- 12 MR. EDWARDS: Well -- 13 MR. HOROWITZ: Do you want to say anything?} 14 MR. EDWARDS: Yeah. For the purposes of the} 15 record, I'd just like to make the record in that 16 the deposition was set in nine cases today, I 17 believe. I was unable to ask any questions today, 18 and I think the record is going to be clear as to 19 the reason why that happened, both the video and 20 the transcript, in a case like this where the 21 options are answer questions, or take the Fifth, 22 and the election for the most part was take the 23 Fifth, it should be a short abbreviated deposition. Instead the types of answers that we Page 328 to put that on the record, so that it's clear why we're not finishing, at least from my vantage point. MS. EZELL: And I'd to add that I had crossnoticed on behalf of our client in the one filed case we have. We also represent three other clients, and we do not yet have filed cases. We certainly want a chance to ask our questions as well. 1 do think we wasted a great deal of time today in very self-serving answers that did nothing to advance the discovery in this matter. MR. PIKE: Is everybody done? MR. HOROWITZ: Yes. MR. EDWARDS: IH just join in on the comments by defense counsel. MR. PIKE: Okay. I'm just going to move to strike for purposes of the trial. I understand that everybody is trying to make a record for any future motion, but I move to strike everybody's comments for purpose -- purposes of the trial in this matter. We're here right now, Mr. Edwards, for you to begin and finish your deposition, We're here right now for you, Mrs. Ezell, to begin and finish your deposition of Mr. Epstein, And Mr, Horowitz, this and cause us not to finish today. Page 327 received were obstructionist in nature. I think 1 that that's -- that's going to be something that 2 the Court is going to rule upon, but that’s going 3 to be our position, And that after every -- nearly 4 every question, there was some injection into the Ss record by Mr. Epstein about Jeffrey Herman and somq = 6 discipline that he had with the Florida Bar, as 7” well as Scott Rothstein and his being in jail, as 8 well as something to do with other partners going 9 to jail, despite the fact that I haven't asked a 10 single question, nor have any questions been asked 11 about my clients, 12 In addition to the mockery that was made of 13 this deposition by Mr. Epstein and of the overall 14 discovery process today because of the way he chose | 15 to answer questions and that his counsel did not 16 instruct him to do otherwise, and instead seemed to wy encourage those types of responses, we're unable to 18 finish today. It's going to take another day. 19 And one other thing that I think is going to be 20 clear, but I want to put on the record, is that we 21 probably took fifteen — no exaggeration -- breaks, 22 each one of them initiated by Mr. Epstein, which 23 just also served only to obstruct the deposition So I just want Page 329; case has been -- this deposition has been set for some time, and, you know, whether or not you have a flight plan, or whether or not it was prearranged, I do not know. But we are here right now to finish your deposition for your clients. So I see that everybody is standing, with the exception of Ms. Ezell. I'm sitting, and I'm ready to finish this deposition and let you guys commence, MS. EZELL: We've been going for eight hours and fifteen minutes, The facility we're in is all closed down. The lights are off everywhere. We can't get in and out of doors, I think to suggest we proceed for what would be another eight hours at this point is just not workable. MR. EDWARDS: And I probably have five hours of questions, and that's assuming that the answers that we receive were less elongated than the ones we received already. So given the circumstances and the nature of the responses and how Jong it takes to respond, we would not finish until next Thursday at this pace so J just don't think it would be fruitful to continue. MR. PIKE: I understand your statement. MR. EDWARDS: Right. MR. PIKE: The facility here we have arranged 35 (Pages 326 to 329) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

Page 330 to have it after hours, Our particular area is -is -- area is not closed down, so if you'd like to go forth with the deposition, we are here, as I've said. MR. HOROWITZ: Let me say this. You know, nv -~ nearly all of my clients have had two days of depositions, despite the fact that they're parties to only one case. Mr. Epstein is a party to a dozen cases just for ~ on the lawyers who are here today. So given the practice of parties’ appearing for two days of depositions in the past, it makes sense particularly in the case of Mr. Epstein who's a party in multiple cases to do at least two days of depositions for the same reasons. There's just a lot of material to cover. MR. PIKE: I think everybody has said their piece, MR. EDWARDS: Yep. MR. PIKE: Are we going off the record? MR. HOROWITZ: Yes, we can go off the record. THE VIDEOGRAPHER: Time off the record 6:17, (Videotaped deposition was concluded.) (Thereupon, Exhibit No, | was marked for identification.) THE REPORTER: Do you want to order this, STATE OF FLORIDA) COUNTY, OF BROWARD) I, the undersigned authority, certify that was duly sworn. WITNESS my hand and official seal this 22nd day of March, 2010. Vicki L, Lima, Court Reporter Notary Public - State of Florida Commission No: DD 882608 Expiration Date: May 26, 2013 Job #92076-B Page 331 Mr. Horowitz? MR. HOROWITZ: Yes. MS. EZELL: We'll take a copy. MR. PIKE: We'll take a copy. MR. EDWARDS: Copy, please, (Proceedings were concluded.) CERTIPICATE STATE OF FLORIDA) COUNTY OF BROWARD ) 1, Vicki L. Lima, Court Reporter, Notary Public in and for the State of Florida at Large, do hereby ‘certify that the aforementioned witness was by me first duly swom to testify to the whole truth; that I was authorized to and did report said deposition in stonotype; and that the foregoing pages are a true and correct transcription of my shorthand notes of said. deposition. | further certify that the said deposition was taken at the time and plece horeinabove set forth and that the taking of sald dopeition was commenced and ‘completed as hersinabove set out. | forther certify that Iam not an attorney or counsel of any of the parties, nor am {a relative or employee of any attorney or counsel of any party connected with this action, nor am I interested in the action. The foregoing certification oF this transcript docs not apply to any reproduction of the sume by any means unless under the direct control and/or direction of the certifying reporter, IN WITNESS WHEREOF, 1 have hereunto set my hand this 22nd day of March, 2030, ‘Vig L. Lima, Court Reporter Notary Public = State of Florida ‘Commission No: DD 882608 Expiration Date: May 26, 2013 Job 492076-B 36 (Pages 330 to 333) UNIVERSAL COURT REPORTING (954) 712-2600 (877) 291-DEPO (3376)

UNIVERSAL LEGAL REPORTING 850 EAST LAS OLAS BOULEVARD, SUITE S08 FORT LAUDERDALE, FLORIDA 39301 (654) 712-2600 March 22, 2010 Jelirey Edward Epstein, witness Michael J. Pike, Esquire 303 Banyee Bovlevard, Suite 400 ‘West Palm Beach, Florida 33401 RE, Jene Dow No. 2 v3, Joffray Epaicin CASE NO; 08.CV-301 19- MARRAHOHNSON Job A92076-B Volume HL Dear Mr. Epstein: Please take notice that on March 8, 200%, you ‘gave your deposition in the sbove-refered mater. At ‘hal time, you did not waive your signature, I is now neveseary thal you sign your deposition, ‘As previously agreed f, the truncript will be Furnished to you through your cownsel. Prease read the following instructions ‘At Page 335, you will fod an erata sheet. As you ceed your deposition, any changes ot corrections ‘a you wish to make should be noted on the errata heal cling page and line numberof said change. DO [NOT varie on the transcript itself, Onoe you have read ‘he trenseript and noted any changes, be sure to eign ed date the errata sheet and retomn these pages to us atthe address listed above. You need not refuin the entire transesipt, "yon do sot toad snd sign the deposition ‘within shiny (30) days the origina, which has already been forwarded to the ordering attomey, may be filed ‘with the Clek of the Court fF you wish to salvo your sigperore, sign your aame ia tha blank atthe borom of ‘his letter and cetum it us Very uly yours, ‘Universal Legal Reporting, Vicki L. Lima (Court Reporter - Notacy Public 1 do hereby waive my signature Page 334 ERRATA SHEET IN RE: Jane Doe No, 2 vs, Jeffrey Edward Epstein DEPOSITION OF: Joffrey Edward Epstein, Volume it TAKEN: March 8, 2010 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGE # LINE # CLLANGE REASON Please forward the orginal signed erate sheet to 0 office 60 that copies may be distibuied to all pasties. Under penalty of perjury, # declare thet | have sead my eposition and that # is true and correct subject to any changes in form or substance entered here, DATE; SIGNATURE OF DEPONENT, Jeb wooOTE (954) Page 335 UNIVERSAL COURT 712-2600 (877) 37 (Pages 334 REPORTING 291-DEPO (3376) to 33 EE I EST ST RT OR SRR PT TT CT RTT Ta CT 5}

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et.al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 9

JANE DOE, vs. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON JEFFREY EPSTEIN, et al., CIAL x. Plaintiff, “Se Defendants. / Related Cases: 08-80119, 08-80994, 09-8-591, 08-80232, 08-80380, 08-80381, 08-80811, 08-80893, 09-80463, 63-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF NADIA MARCINKOVA TAKEN ON BEHALF OF THE PLAINTIFF DATE: April 13, 2010 U.S. Legal Support (561) 835-0220

Te A I take the Fifth. Q I represent a lady named, a young female named E.W.; you know who that is, right? MR. YAREMA: Object to the form, A The Fifth. Q Jeffrey Epstein made you have sex with E.W., didn't he? MR. YAREMA: Object to the form. A The Fifth. Q You did, in fact, engage in sexual activity with E.W. when she was only 16 years old; isn't that true? MR. YAREMA: Object to the form. A The Fifth. Q Back to my original question: And I'll ask you this way: Do you consider yourself heterosexual, bi~sexual, or can you answer that question? MR. YAREMA: Object to the form. MR. GOLDBERGER: Same objection. Do not answer the question. A Fifth. Q How did you meet Jeffrey Epstein? A Fifth. Q When did you become one of Jeffrey U.S. Legal Support (561) 835-0220

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 8

“~ AN UW BF WN io 1i 12 13 14 1s 16 17 18 19 20 21 22 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOR NO. 2, CASE NO; 08-CV-80119 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO, 3, CASE NO: 08-CV-80232 Plaintiff, ve. CONDENSED JEFFREY EPSTEIN, Defendant. / JANE DOE NO. 4, CASE NO: 08-CV-80380 Plaintife£, Vs. JEFFREY EPSTEIN, Defendant. / JANE DOR NO. 5, CASE NO: 08-CV-80381 Plaintiff, Vs JEFFREY EPSTEIN, Defendant. / Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL. 33141 Page 270

“on © 8 Nm uaune — S a 42 13 14 1S 16 JANE DOE NO. 6, CASE NO: 08-CV-80994 Pail, Vs, JEFFREY EPSTEIN, Defendant, — JANE DOE NO. 7, CASE NO: 08-CV-80993 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. CMA, CASE NO: 08-CV-80811 Plaintiff, vs. JEFFREY EPSTEIN, Defendant. seen JANE DOE, CASE NO: 08-CV-80893 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. ey. JANE DOE NO. Tf, CASE NO: 08-Cy¥-80469 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant, ee JANE DOE NO, 101 CASE NO: 08-CV-80591 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 102, CASE NO: 08-CV-80656 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant, JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 1032 Ives Dalry Road Suite 228 North Miami, Florida August 7, 2009 1:15 p.m. to 5:30 p.m. CONTINUED VIDEOTAPED DEPOSITION of ALFREDO RODRIGUEZ taken on behalf of the Plaintiffs pursuant to a Re-Notice of Taking Continued Videotaped Deposition (Duces Tecum) APPEARANCES: ‘MERMELSTEIN & HOROWITZ, P.A. BY: ADAM HOROWITZ, ESQ. 18205 Biscayne Boulevard Sulte 2218 Miami, Florida 33260 Attomey for Jone Doe 2, 3, 4, 5, 7 ROTHSTEIN ROSENFELDT ADLER SY: BRAD J, EDWARDS, ESQ., and CARA HOLMES, €5Q. Las Olas City Centre ‘SuRe 1650 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 Attorney for Jane Ooe and EW. and LM. PODHURST ORSECK BY: KATHERINE W, EZELt, ESQ, 25 West Flogter Street Suite 800 Miam}, Flosida 33130 Attorney for Jane Doe 101 and 102, ‘LEOPOLD-KUVIN ‘BY: ADAM . LANGINO, ESQ. 2925 PGA Boulevard Sulte 200 Palm Seach Gardens, Florida 33410 Attorney for B.B. Kress Court Reporting, Inc, 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 IN THE CIRCUIT COURT OF THE 18TH CASE NO. S02008CA037319XXXXMB AB

1 2 3 4 Now APPEARANCES; RICHARD WILLITS, ESQ, 2290 10th AVenue North ‘Suite 404 Lake Worth, Florida 33461 Attorney for C.M.A, Appeared via telephone. BURMAN, CRITTON, LUTTTER & COLEMAN, LLP BY: ROBERT CRITTON, ESQ. 525 North Flagler Drive Suite 400 West Palm Beach, Florida 33401 Attorney for Jeffrey Epstein, JOE LANGSAM, VIDEOGRAPHER, CONTINUED INDEX OF EXAMINATION WITNESS DIRECT CROSS REDIRECT RECROSS ALFREDO RODRIGUEZ {By Ms, Eze) 278 441, 467 (By Mr. Willits) 334 453, 469 (By Mr. Critton) 338 464 (By Mr. Edwards) 419, 454, 468 (By Mr. Langino) 452 CONTINUED INDEX OF EXHIBITS PLAINTIFF'S PAGE 3 Drawing 315 4 Photograph 327 5 Photograph 331 6 Photograph 332 7 Photograph 331 8 Photograph 331 9 Report 446 {Exhibits ¢, 5, 6, 7, and 8 were retained by Ms, Exell.) OaAnanawne that you were there was Mr, Dershowltz there? Page 277 i Deposition taken before MICHELLE PAYNE, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause, THE VIDEOGRAPHER: This Is 2 continuation of the deposition of Alfredo Rodriguez, Today Is Friday, August the 7th, the year 2009, starting time approximately 1:15 p.m. Will the court reporter please swear in the witness? Thereupon, ALFREDO RODRIGUEZ, having been first duly sworn or affirmed, was examined and testified as follows: MR. CRITTON: Before we get started just with regard to Ms. Ezell represents Jane Doe 101 and 102, the alleged time of her incidents as of least have been plead In the complaint for 101 is '99 -- I'm sorry, '98 through 2002, with Jane Doe 102 the Spring of -- Spring/Summer of 2003. Mr. Rodriguez never even began employment until '04 and ‘0S. I think her questioning I think -- I can't say she doesn't have standing based on the court order, but I would say it's Page 278 completely irrelevant and immaterial and has no probative vaiue with regard to this particular witness based upon the two clients at jeast that are in suit at this point in time. MS. EZELL: As Mr, Critton well knows I represent a number of other clients whose cases have not been filed and I believe we do have standing to ask questions, and I do intend to do that today. EXAMINATION BY MS, EZELL; Q. Mr, Rodriguez, you stated last time that there were guests at the house, frequent guests, friends from Harvard. Do you remember that testimony? A, Yes, ma‘am. Q._ And was there a lawyer from Harvard named | Alan Dershowitz? i A. Yes, ma'am. Q. And are you familiar with the fact that he's a famous author and famous lawyer? A. Yes, ma'am, Q, How often during the six months or so 3 (Pages 275 to 278) Kress Court Reporting, Inc, 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL. 33141

RSwavauawne was visiting there? there as a friend? at the time he was there? Page 279 A. Two or three times. Q. And did you have any knowledge of why he A. No, ma'am, Q. You don't know whether or not he was a lawyer -- acting as a lawyer or whether he was A. I believe as a friend. Q. Were there also young ladies in the house OOO DWN MR. CRITTON: Form, Page 281 f Q. Can you tell me where those were? A. One in the kitchen, and the one in the formal -- the main entrance. And there was one more added later on, but there is two when I was ~ working there, Q. Could you just give me a rough sketch of the house of where the main entrance was and where the kitchen was? A. I'm not an architect but it's something like this, This is the kitchen, this is the main entrance, 12 THE WITNESS: Yes, ma'am, 12 Q. Will you mark the kitchen with a K, 13. BY MS. EZELL: 13 please, and the main entrance with ME? 14 Q. And would those have included, for 14 A, This is the pool. 15 instance, Sarah Kellen and Nadia Marcenacova? 15 Q. The pool? 16 A. Yes, ma'am. 16 A. Yes, ma'am. 17 Q. Were there other young ladles there when 17 Q. And In the upper left? 18 Mr. Dershowitz was there? 18 A, In the terrace, yeah, there was a balcony 19 MR. CRITTON: Form. 19 here. 20 THE WITNESS: Yes, ma'am, 20 Q. And where were the staircases? 21 BY MS, EZELL: ai A, This is one, the kitchen, one in the 22 Q. Do you have any idea who those young 22 foyer, and the pool. 23° women were? 23 Q. Okay. And would you just put an F where 24 A, No, ma'am, 24 the foyer staircase began? And KS where the 25 Q. Were any of those the young women that kitchen staircase began. 3| Page 280 Page 282 1 you have said came to give massages? 1 And you said that later another staircase t 2 A. Yes, ma'am, 2 was added? 3 Q. And do you have any idea whether or not 3 A. Yeah, we rehabilitated this, you know, 4 Mr. Dershowitz was also receiving massages? 4 but you asked me how many stairs there were, to 5 A. I don't know, Ma'am. 5S answer your question there were three, 6 Q. I want to ask you to take this piece of 6 Q. Three. So where was the third one? 7 paper, please, and a pencil ~ 7 A. The pool, this feads to the pool, 8 MR. WILLITS: Can anybody hear me? 8 Through the outside master bedroom you could go 9 MS, EZELL: Yes, Can you hear me? 9 downstairs to the pool, 10 MR. WILLITS: I've heard nothing for 10 Q. Okay. A stairway then from the outside, 11 about a minute or so, 11 from outside the master bedroom? 12 MR. CRITTON: Can you hear me now? 12 A. Yes, ma'am. 13 MR. WILLITS: Yes, 13 Q. Down to the pool? 14 MS. EZELL: I'm asking questions, I'm 14 A. Yes, ma'am. 15 sorry. 15 Q. One of your duties was to answer the 16 MR. CRITTON: Why don't we go off the 16 door. Is that correct? 17 record for a second. 17 A. Yes, ma'am. 18 (Thereupon, a discussion was held off the 18 Q. Which door would you answer? 19 record.) 19 A, Mainly the kitchen. if 20 THE VIDEOGRAPHER: We're back on the 20 Q. And why was that, why would peopie mainly 21 record, 21 come to the kitchen? 22 BY MS, EZELL: 22 A, il say it was for practicable reasons 23 Q. Mr, Rodriguez, you indicated that there 23 because not to go to the main -- it was shorter 24 ~were several staircases in the house? 24 because the entrance was here, so this was the Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141

WONAUMEWNHe Page 242 engaging in sex acts with these young girls? MR. CRITTON: Form. THE WITNESS: No, I don't know. BY MR. EDWARDS: Q. No one ever told you that? A. No. Q. Well, since you've been keeping up with what's been written in the newspapers, at some point in time you've read that Nadia Marcenacova joined in some of these sex acts with some of these girls. Right? MR. CRITTON: Form. THE WITNESS: I believe so. BY MR, EDWARDS: Q. I'm not the first person telling you that? A. No, no, no, I read it in the newspaper. MR. CRITTON: He read your press release. MR. EDWARDS: Long before I ever had anything to do with this case. BY MR. EDWARDS: Q. Were you surprised when you read that? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARDS: Page 243 Q. Were you surprised when the story started coming out that these girls that were coming over to the house were under the age of 18 and Mr. Epstein was engaging in sex acts with them? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARDS: Q. When was the first time that you knew for sure 100 percent that -- weil, let me say it this way. When was the first time that you read that information? A. Underage? Q. Yes. A. When this scandal broke out when the Palm Beach Police Department -Q. Contacted you? A. Yeah, MR. CRITTON: Why don't you let him finish his answer instead of suggesting or giving him the answer. THE WITNESS: The West Palm Beach Police Department got involved. BY MR. EDWARDS: Q. Skipping to the second paragraph WONAUAWHe Page 244 fi page 72, Rodriguez stated the amount of girls that [i came to the house was approximately 15. That's the estimate that you gave back -A. All the girls that I saw coming in and out. Q. Weil, when I read this, you can tell me what it actually means, when I read this T interpreted that as because they were talking about masseuses I interpreted that as the number of girls of the Palm Beach area that came over and you labeled masseuses. Is that correct? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. Okay. Could you name ~Imean,I know ff that we've named T. and C., could you name any of the other -A. C. comes all the time, you know, I remember her. Q. Okay. No other names pop out though? A. To be honest with you, no. Q. A? A. Yeah, because I remember because the car. Q. Allright. It goes on to say, when asked to identify these girls, so somebody else asked Page 245 E you the same question I just did, Rodriguez stated he could not at the moment but knew he wrote their [ with Mr. Epstein. Is that true? A. Yes. MR. CRITTON: Form. BY MR. EDWARDS: Q. Did you ever find that journal? A. Probably has some pages at home. Q. Because later on it seems like you met up with the police officer and produced a green folder that contained documents, but that's not the same thing as the journal. Right? A. No, this is my writings. Q. Okay. So if we want to obtain that journal from you what's the best way to go about getting It? A. I probably have to look In my house. Q. Okay, Well, it looks like we're going to come back for a second part of this, so by next time maybe you could find it. Right? A. Okay. Q. Allright. Mr. Mermelstein asked you if t anybody had contacted you about this case that was either an -- that was an investigator with Mr. Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141

WONANAWNHE Page 222 Epstein's investigators that you felt there was more going on in the bedroom than just massages? MR. CRITTON: Form. THE WITNESS: Because they were more interested in how much I know, they didn’t ask me anything else, and I told them exactly what I knew and what I was doing. BY MR. EDWARDS: Q. Okay. You were asked by Mr. Mermelstein when he was asking you about the meeting with Mr. Epstein's investigators he said, did they make any threat or did they threaten you, and you paused and said I don’t believe so. A. Yeah, I think they didn't tell me anything that I will feel -- they told me that they want to know what I know and if I need an attorney. Q. Okay. Did you find that strange at ail that they offered you an attorney? A. Lwent to have dinner at my house and I told this to my wife and she told me, Alfredo, you don't need an attorney, so I called him the next day ‘and that was it. Q. You called the investigators? A. Yes. I declined, I don't need an Page 223 attorney. Q. If we want to know the exact names of the investigators that you met at Don Shula's and at your house, how would we get that information, do you have it somewhere? A. Probably I have it in the house. Q. So if we do have to come back here and finish this up, the next time would you be able to bring that? A. I think so, Q. Okay. Do you know where in your house that you have it, I mean, have you kept it In a certain place? A. Thave to look. Q. Allright. After the sentence that we left off it says, he, speaking of Mr. Rodriguez, would clean Mr, Epstein's bedroom after the alleged massages and would discover massagers slash vibrators and sex toys scattered on the floor. Can you tell us what types of sex toys that you found scattered on the floor after the massages with these young girls? MR. CRITTON: Form. THE WITNESS: Like I explain, there was a Page 224 ff massage with a handle with two rubber things — that you can do massage yourself, this was always on the floor, maybe one or two. BY MR. EDWARDS: Q. Okay. When you say this Is always on the floor, do you mean 24 hours a day it's on the floor? A. No, no, no, after each massage. Because Tassume the masseuses or anybody they were doing, they were taken out of the closet wherever they belong and they would leave there. So Louella and myself, we always find this on the floor. Q. And this is a massager that belongs to or is owned by Mr. Epstein? A. Yes. Q. This isn't something that these girls would bring over to the house? A, No, no, it’s in the house, it's part of the inventory. Q. And that statement is a few statements after you felt that there was a lot more going on than just massages, is there something about that object being left on the ground and the type of object that it was that also lead you to believe that there is something more going on here than just massages? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: ‘ Q. What about it, just tell us? MR. CRITTON: Form. THE WITNESS: I thought they were having a good time, I never thought it was something done against anybody's will, but of course, you know that it’s more than massage. BY MR. EDWARDS: Q. Right, I'm just asking you to explain how you know that. MR. CRITTON: Let me just move to strike his last answer as speculation. Form as to your statement. THE WITNESS: You're 50 years old and it's -~ you're an old -- you know, it's just instinct. MR. CRITTON: Move to strike. BY MR. EDWARDS: Q. It was obvious to you? A. Yes. MR. CRITTON: Form. Kress Court Reporting, Inc, 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141,

BY MR. EDWARDS: Q. He also said he would wipe down the vibrators and sex toys and put them away in the armoire, MR. CRITTON: Form, THE WITNESS: These things have a tip, they have the cream, they have all kinds of cream for giving massage. BY MR, EDWARDS: Q. How many of these massagers or vibrators 11. would you wipe down? MR. CRITTON: Form. THE WITNESS: This big one all the time. BY MR. EDWARDS: Q. Right. Other than the big one all the time did you wipe down at any time any of the other sex toys or vibrators? A, No. MR. CRITTON: Form. BY MR. EDWARDS: Q. So if there were any other sex toys or vibrators or I believe you used the term dildo earlier that were ever used, those are items that you did not find on the floor and were put away in the armoire? WDNDMNAWNE i MR. CRITTON: Form. 2 THE WITNESS: Louella told me I did this, 3 I did that. 4 BY MR, EDWARDS: 5 Q. So tell us what did Louella tell you? 6 A. She find toys on the floors, she have to 7 dean them, 8 Q. Did she tell you when she found the toys 9 on the floor? A. After his massages, you know. 11 Q. With the young girls that we're talking about? A. Yes. Q, Okay. And when did Louella tell you that? A. Almost every other time when she found it, you know, Affredo I found this thing again because she despised to clean this, she had to put the gloves or whatever, Q. Okay. So it sounds like you had an actual conversation about this where she's describing she doesn't want to clean it. A. Because I told her to tell me up to date on things that are not normal, so she told me, you acai I found this, I found that, or some Page 226 Page 227 Page 228 fF underwear she brought it to the laundry and we used to label it. Q. Just so that the record is clear as to what we're talking about with this and that, I want you to tell us what Louella would tell you specificaily, I found this and then would she show you what it was? A. No, she didn't show me, she said 1 cleaned this and I put it away, it was a vibrator. Q. Did she describe the vibrator for you so that you knew which one she was talking about? 12 A. The vibrator that a female would use for personal use. Q. Not the same long one that you've been describing? 16 A. No. Q. One that is a penis shaped vibrator. MR. CRITTON: Form. THE WITNESS: Yes. BY MR, EDWARDS: Q. That's what she was talking about? A. Yes. Q. And did she tell you on how many occasions after these -A. Several times, WONANARWNE Page 229 ‘LD Q. And can you explain to us why it is that 2. -- and maybe it's just I don't understand the 3 process of cleaning the room who went in first and 4 second and whatever, but my question is why is it 5 that she would always be the one to encounter the 6 penis shaped vibrators and you would encounter 7 this other longer vibrator? 8 MR. CRITTON: Form. 9 THE WITNESS: Because it was her job to clean the room. When she was busy she will ask me, Alfredo, can you help me carry, I have a lot of towels, because there were mountains because being an older woman 1 help her carry to the -- and put the towels downstairs, take It to the laundry. But she told me I found these things, I clean it, 1 put it in that armoire, they're over there. So she will give me -- we used to communicate all those little details, but it was her job to be in the room first. BY MR. EDWARDS: Q. And what did she say about liking or disliking the fact that she had to clean these vibrators? A. She didn't like to clean those. ATLA TREE TA ER CTPA A RAT CE LT LT TTT TAT RTT I 58 (Pages 226 to 229) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141

OONAUNAWNE Page 230 Q. Did she teil you why? A. Because, you know, she knew what they were for and probably she despised to clean objects. Q. Did she ever make any comments about how young the girls were that were in the room with Mr. Epstein just before she had to go in and clean these vibrators? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARDS: Q. Is the age of the girls that were coming over and going behind closed doors with Mr. Epstein a subject that ever came up between you and Louella? A. Sometimes. Q. And what would the conversation consist A. She will be surprised and say some of the girls are too young, and I said -- we just wonder, you know, but we comment each other. Q. Did it ever -- as a father did it ever occur to you that maybe I should say something or I shouldn't be here or I shouldn't be apart of this considering how young they are and how old he WAONDNBWNHH Page 232 a lack of respect. So, you know, she was. shocked. So obviously she needed a job but she expressed her -MR. WILLITS: I'm sorry, I did not hear that, could the witness repeat that? THE WITNESS: I was just talking about Louella, deeply religious staff member that worked with me and she told me one occasion that she was crying because the picture of the Pope was next to a naked girl. MR. WILLITS: Okay. BY MR, EDWARDS: Q. Okay. Besides Louella did you ever have a conversation with anybody else that works in the house about the young age of the girls and Mr. Epstein being in the bedroom and the fact that there are sex toys on the floor afterwards being wrong? MR. CRITTON: Form. THE WITNESS: Nobody else inside the house was allowed except just the two of us, so I never commented on this with anybody. BY MR. EDWARDS: Q. Allright. The next sentence starts a new paragraph, Epstein ordered Rodriguez to go to |; is? MR. CRITTON: Form, THE WITNESS: Yes. BY MR. EDWARDS: Q. Is that something that on more than one occasion you thought to yourself this is just wrong?. MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. And did you ever have a conversation with Louella about the fact that that's not right? A. We had. Q. And Louella stayed there and she's still employed there? A. I believe she was. Q. And did she ever mention to you that she thought that the situation was wrong and that she was contemplating -A. She was a deeply religious -MR. CRITTON: Form to the last question. THE WITNESS: -- Catholic Filipino girt ~~ lady, and one day she came crying because she found a picture of the Pope next to naked girl, both pictures, and she said it's Page 233 the Dollar Rent a Car and rent a car for the same girl he brought the roses to. I guess we're talking about A. So that she could drive herself to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Are those statements you agree with? MR. CRITTON: Form. THE WITNESS: I took her a few times to her house. BY MR, EDWARDS: Q. You took A. to and from her house? A. In Royal Paim Beach. Q. Okay. Did she say anything in the car to you about what was going on in the bedroom with Mr. Epstein? A. Lalways try to keep the conversation to : @ minimum when I was with them because it was my job, you know, I didn't want to talk so the conversation was minimal. Q. And these are girs that you're talking to that are roughly the same age as a daughter that you have? Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 7

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50-2008-CA-~-028051 XXXX MB AB L.M., Plaintiff, vs. JEFFREY EPSTEIN, Defendant. VIDECTAPED DEPOSITION OF JEFFREY EPSTEIN TAKEN ON BEHALF OF THE PLAINTIFF DATE: February 17, 2010 U.S. Legal Support (561) 835-0220

The videotaped deposition of JEFFREY 1 February 17, 2010 ; 1 THEREUPON, : WITNESS A IRECT CROSS REDIRECT RECROSS 2 a5e ER BY EPSTEIN 4 JEFFREY EPSTEIN i 3 being by Terri Becker first duly sworn to tell 5 BYMR.EDWARDS 4 4 the whole truth, as hereinafter certified, § eaters 5 testified as follows: 7 FOR IDENTIFICATION PAGE 6 DIRECT EXAMINATION 8 1 Jane Doe number 102 versus Jeffrey | 7 BY MR, EDWARDS: 7 Epstein complaint, a 8 Q Can you give us your name. 2 Document, Nonproseoution Agreement. 135 9 A Jeffrey Epstein. it 10 Q Mr. Epstein, you made a comment when yo} CERTIFIED QUESTIONS 11 came in the room that you were appreciative of m 12 | 12 being respectful to your housekeeper yesterday a Page Line 13 and Lintend for that to be the same with you 6 22 14 today. 14 13 (20 15 T want to start by asking you, at this 4% HH i 16 point we've gone through a lot of discovery in 1h S 17 this case. There aren't many disputed facts as 16 9913 18 to what actually happened at your house. 12 3 19 — Generally [ think you wonld agree that you 20 — derived a way for young females to come to your 21 ~~ house and engage in varying degrees of sexual 22 activity, some of the girls as young as 12, some 23 of them as old as seventeen or so, most in 24 — between, but as of yet you haven't provided an explanation, T want to provide you an opportunity to 1 2 EPSTEIN in the above-entitled and numbered cause, was taken before me, TERRI BECKER, a Registered Professional Reporter and Notary Public for the State of Florida at Large, at 444 West Railroad i a 2 tell the jury at this time why you did it. 4 3 8 4 6 — Avenue, in the City of West Palm Beach, Palm 5 7 8 6 2 8 9 MR. PIKE: I’m going to object. Confusing, compound and irrelevant, as worded, A You know, I would like to answer that question, frankly. However, at this time, my attorneys have told me that I can't and I must invoke my Fifth, Sixth and Fourteenth Amendment Beach County, in the State of Florida, beginning at the hour of 11:15 o'clock a.m., pursuant to 9 the Notice in said cause for the taking of said deposition which is annexed to the court file herein, on behalf of the PLAINTIFF in the above-entitled action pending in the above-named 13° court. 5 \ 10 rights or I risk losing their counsel. 34 The appearances at said time and place | 41 Accordingly, I therefore assert those rights. 15 were as follows: bab 6 16 FARMER, JAFFE, WEISSING, j orry. EDWARDS, FISTOS & LEHRMAN, P.L. 13 MR. PIKE: In addition to that I'll move 7 Attomeys for Plaintiff } 44 i : 425 North Andrews Avenue, Suite 2 : Ge e oe ahaa Statement 68 & 18 Fort Lauderdate, Florida 33301 i narrative, as well. Tel: (954) 524-2820 16 MR. EDWARDS: I understand. | wanted to 19 BY: BRADEEY Hl owen 17 provide him an opportunity, if today was ae STEVEN 8: TAFERIESO: 1 18 going to be the day. BURMAN, CRITTON, LUTTIER & COLEMAN | 19 MR. PIKE: Same thing, move to strike, 24 tomers for ee iis a0 20 Q Mr. Epstein, how long have you been 22 Wen pila boch Ponds 33401 21 sexually attractive es wnderage: minor females? Tel: (561) 842-2820 22 MR. PIKE: Objection, harassing, 23 BY: MICHAEL PIRE, ESQ. 23 argumentative. a AE ROVING: Videographer 24 A Are you kidding? 25 (U.S. Legal Support) 25 Q No, L mean, I don't feel like I'm 2 (Pages 2 to 5) U.S. Legal Support (561) 835-0220

divulging any secrets here, right? MR. PIKE: Move to strike. Q That's the question that's pending, A. | would like to answer that question as well, as all your other questions today, however, | Thave to follow my attorneys’ advice. They have! told me I must invoke my Fifth, Sixth and Fourteenth Amendment right to not answer those questions today, or any questions relevant to this lawsuit, so accordingly, I'm going to assert those rights and -- under the constitution guaranteed by the Fifth and Sixth, and Fourteenti amendment. Q Would you consider yourself addicted to sex with minor females? MR. PIKE: Same objections. A’ You know, Mr. Edwards, again, I want to be very respectful. As the current U.S. Attorney has described your law firm as a criminal enterprise and part of one of the largest frauds in Florida's history, it has been reported that your firm has fabricated multiple cases against ime in order to fleece unsuspecting investors out of millions and millions of dollars, so unfortunately at this time, although I would like 7 to answer that question, on advice of counsel f will have to reftain and assert my Fifth, Sixth and Fourteenth Amendment right, Q Can you then provide an explanation for what relevance that soliloquy of yours has to, whether or not you engaged in sex acts with L.M. When she was a minor? MR. PIKE: Objection, no, he cannot. Argumentative. Compound, harassing, MR. EDWARDS: Mr. Pike, with all due respect, it was not my idea for him to give this speech about a former RRA law firm I was asking to elaborate on that. MR. PIKE: Counsel, I'm working with your follow-up question. MR. EDWARDS: J understand. MR. PIKE: I'm objecting, object to the form and stating the reasons on the record why the form is required to be objected to, based upon your question. MR. EDWARDS: Will he elaborate on the relevance of that soliloquy to kis touching L.M. when she was 13, 14 and 15 years old in asexual manner? MR. PIKE: I'm going to object again, argumentative, compound, harassing and irrelevant. Q You can answer. A_ I would like to answer, however, I'm going to have to assert my Fifth Amendment, Sixth Amendment, Fourteenth Amendment right as advise: by my counsel, otherwise I risk losing their advice. Q Mr, Epstein, have you ever been diagnosed with a sex addiction te minors by a psychologist or other medical professional? A_ intend to respond to all of your questions at some relevant time; however, today at the present time, my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and { must accept their advice or risk losing my Sixth Amendment rights to effective representation. Accordingly, I assert my Fifth, Federal -» Fifth and Sixth and Fourteenth Amendment rights, to the United States Constitution, MR. PIKE: In addition to that, Mr. Edwards, as the Court has ruled on several matters, Mr. Epstein’s medical history is not relevant at this time nor has he placed same at issue in this case. MR. EDWARDS: Understood. Q Mr. Epstein, were you sexually abused as aminor? A Again? Q Were you sexually abused, as a minor? A You know, again, I would like to respond to all -- if any questions seem to be relevant, T would like to respond to any relevant question at this time; however, my attorneys have counseled me that 1 cannot provide answers to the questions relevant to this lawsuit today. I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly then, J assert my Fifth, Sixth and Fourteenth Amendment right to the United States Constitution. Q isn't it true that you have engaged in some sexual interaction with hundreds of undera: prinor femates in the last ten years of your life? Es that true? MR. PIKE: Objection, relevance. A Mr. Edwards, the current U.S. Attorney has described your law firm as a criminal 3 (Pages 6 to 9} U.S. Legal Support (561) 835-0220

10] enterprise and part of the largest fraud in Florida's history. It has been reported that your firm fabricated multiple cases, many, many multiple cases against me in order to fleece unsuspecting investors out of millions and millions of dollars. Unfortunately, at this time in response to your question, my attorneys have advised me that I must assert my Sixth Amendment, Fifth Amendment, Fourteenth Amendment right, Though, I betieve, you know, that I would really like to answer your questions today, but at this moment I must assert those rights or risk having my attorneys resign. Q You're invoking your Fifth Amendment rights to each of these questions because you know your answers will incriminate you and you. feel it will result in you being prosecuted for your crimes; isn't that right? MR. PIKE: Objection, argumentative, harassing, Calls for a legal conclusion. Q You can answer. A No, in fact, the Supreme Court recently said the Fifth Amendment right is there to protect the innocent, so, that's the way 1 would like to answer that. LL Q Are you actually telling the jary that you didn’t commit the crimes that have been alleged against you by the various females that were under age when you engaged in sex with them? Are you telling the jury that right now? MR. PIKE: Objection, argumentative, harassing, A_ I would like to respond to that question, as you know, however, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Fifth, Sixth and Fourteenth Amendment right under the United States Constitution. Q Mr. Epstein, you understand that this is the video that will be played to the jury in 1L.M.'s trial against you and LM, wants answers. The jury is going to want answers, se I know that you're felling us that you're going to respond at some time in the future; but the time is now. Would you like this opportunity te explain why you engaged in sexual activity with L.M. beginning when she was 13 years old and you we i | 2 2 3 4 5 6 7 8 9 10 11 12 13 14 18 16 17 18 19 20 21 22 23 24 25 Sy AUERWwne 9 10 ai | 12 13 14 15 16 17 18 19 20 21 22 23 24 25 50 years old? MR. PIKE: I'm going to object once again. We are getting way too argumentative with the questioning. The questioning is compound. It is speculative and it is also harassing. Whether or not this deposition video, thereof is played in front of a jury is a question of fact, and it will be determined by a judge pursuant to a motion in timine, various portions thereof may or may not be played, so having placed those objections on the record I'm going to instruct Mr. Epstein not to answer that question, MR. EDWARDS: Mr. Pike, I don't know i you watched the 13 hours of harassing questions to L.M., that she sometimes invoked her Fifth Amendment rights, I understand the adverse advice that would be given and she was made to answer these questions and these exact same questions were asked of her, in fact, I'm using the phraseology from Mr. Luttier, I'm not trying to harass him, Q Pm simply asking him to explain to the 13 jury. If you're saying it didn't happen, if you're saying it did happen, explain to the ju why you did it. That's all I want te hear. I'm being respectful about this. MR, PIKE: In an effort to keep a clean record be respectful to the to the court reporter rather than having a diatribe back and forth between you and myself, I'll move to strike your Jast statement as irrelevant. Let's move on. Q Isit true, Mr. Epstein, you were born January 20, 19537 Yes. Where? New York, Where in New York? Brooklyn. Did you go to high school there? Yes, sir. Where? Lafayette High School. After high schoo! did you attend college? A Yes, Q Where was that? 4 (Pages 10 to 13) OPOroreror U.S. Legal Support (561) 835-0220

25 13 14 15 16 17 18 19 20 21 22 23 24 25 New York. What college did you attend? Cooper Union. Sorry, I didn’t hear. Cooper Union. } Did you get a degree from Cooper Union4 No, sir. | How many years were you in college? T believe, two. What did you study? Physics. Why did you leave college carly? T intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me that I cannot provide answers to questions that may be rOPHOH Pr OPrPOPr Oro i relevant to this lawsuit, so accordingly I assert | i my constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment. Q Are you invoking your Fifth Amendment rights as to why you left college, is it safe then to presume that that answer you believe would incriminate you in some way? MR. PIKE: I'm going to move to strike, | speculative, argumentative, harassing, Calis for a legat conclusion, and 1 know exactly what you're trying to do here, Mr. Edwards, is lace the record with questions that would ultimately give you an adverse inference at any potential trial of this matter, so having put that on the record, I'm going to instruct him not to answer that question, based upon his Fifth, Sixth and Fourteenth Amendment rights to the United States Constitution, MR. EDWARDS: With all due respect you | cannot invoke his Fifth Amendment rights, | your attorneys instructed me in that fact -- | MR. PIKE: He can, i MR. EDWARDS: That L.M. Hadtodoit — | herself, so, I would like to hear it from | Mr, Epstein, Q Cam we assume you're invoking your Fifth: Amendment rights as to why you left college early, that that answer you feel would ineriminate you? MR, PIKE: Once again, move to strike i for the same reasons. You can answer, A. I've already answered the question. SAAR RWNE I'll restate the answer. { would like to respond, intend to respond, and would like to respond to all questions today. However, counsel has advised me ] must take the Fifth, Sixth and Fourteenth Amendment right under the U.S. Constitution, Q After college where were you employed? A You know, I would like to respond to all your questions today, however, on advice of counsel, I intend to take the Fifth, Sixth and Fourteenth Amendment rights provided by the United States Constitution or risk losing my counsel's representation. Q Isn't it true that you were a teacher at the Dalton School in New York after college? A Again, I would like to respond to all your questions; however, my attorneys have counseled me that I cannot provide answers to any| questions today regarding to this lawsuit so I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment of the constitution. Q Mr. Epstein, did you have sex with any 17 underage students while teaching at the Dalton Scheol? i A. Could you repeat that? Q Yes. Did you have sex with any underage students while teaching at the Dalton School in New York? A Mr, Edwards, your firm has been described by the U.S. Attorney as one of the largest -- as a criminal enterprise, perpetrating one of the largest frauds in Florida's history, It has been reported that your firm fabricated multiple cases against me and others in order to fleece unsuspecting investors out of millions and millions of dollars. Unfortunately at this time in response to your question, my attorneys have advised me I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights, though I believe you know [ would like -- really like to answer your questions but at this time ] must assert those rights or have my attorneys resign. MR. EDWARDS: Mr. Pike, I think you know he has a couple of options here. He can answer questions or he can invoke his Fifth Amendment rights. This nonresponsive 5 (Pages 14 to 17) U.S. Legal Support (561) 835-0220

OOH WHE as verbiage regarding the RRA law firm is not one of the options, it's inappropriate in the deposition and I would ask you to instruct your client not to obstruct this process any further. I am not going to terminate the deposition, F want it to finish, but obviously this is going to be the subject matter of some motion in the courts and you know the judges will not appreciate this. I would like to just move this process along by eliminating that portion of his answer. I understand what he is saying. I get it, but that's not something responsive to any of the questions and I think you know it is inappropriate. MR. PIKE: I think the deponent is answering the questions. If you believe the responses are inappropriate and feel you can take it up with the Court with the motion you are speaking of, as you've done then you can, as you've done several times before. Q After leaving the Dalton School, Is it true that you began working as a money manager at Bear Stearns? A intend to respond to all your questions regarding this lawsuit at some relevant time, however, at the present time my attomeys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. Since the U.S. Attorney has described your law firm as a criminal enterprise, Mr. Edwards, and a part of the largest fraud in Florida's history, 1am going to assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights to the U.S. Constitution, Q Isn't it true that while you were working at Bear Stearns you were already engagi in sex with underage minors? A. Again, { believe you know the answers to those questions, but -~ Q Yes. A May I finish? Q Ido. MR. PIKE: Move to strike. Let the witness —Q Sure-MR. PIKE: Let the witness answer your question. MR. EDWARDS: I wouid love for him to finish the questions. } Cw eSWIHNUewUne CRIHHARWNE 10 12 13 14 15 16 17 18 19 20 21 22 23 24 20 MR. PIKE: Mr. Edwards, as you know there are serious Fifth, Sixth and Fourteenth Amendment constitutional rights at issue here, and the witness js attempting to answer your questions to the best of his ability, despite how laced they are with adverse inference presumptions. MR. EDWARDS: I don’t want the adverse inferences. I want the answers, that's it. I don't want the adverse inferences. MR. PIKE: Having said that, please allow the witness to answer to answer the question, A_ Car you please repeat the question? Q Isn't it true while working at Bear Stearns you were already engaging in sex with underage minor females? A As your firm has been described by the U.S. Attomey, as a criminal enterprise, using some of the cases fabricated against me, personally, I would like to answer that question today; however, upon advice of counsel 1 must assert my Fifth, Sixth and Fourteenth Amendment] rights under the U.S. Constitution or, in fact, risk losing their representation: Q Atsome point in time while at Bear Stearns you met and managed the money for a fellow named Leslie Wexler, correct? A Again, 1 would like to answer all questions relevant to this lawsuit, but today I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment right to the U.S. Constitution. Q In fact, I read in another deposition of yours that you do not consider yourself to be homosexual, correct? A_ (No response.) Q You've answered that question before, correct? A Correct. Q Do you consider yourself to be bisexual? A No. Q Inany event, you did develop a sexual relationship with Leslie Wexler at seme point in time; is that true? A No. Q Did you have a business relationship with Mr. Wexler? A. intend to respond to ail relevant 6 (Pages 18 to 21) U.S. Legal Support (561) 835-0220

ve eS DBI AH sw 22 questions. 1 would like to answer most of your questions, Mr. Edwards, today, however, | especially since your firm has been described by the United States Attorney in South Florida as a criminal enterprise purported to -- purported to have put -- pulled off the largest fraud in Florida's history, I would like to answer it, however, my attorneys here today counseled me T must assert my Fifth, Sixth and Fourteenth Amendment right under the U.S, Constitution, therefore I'm going to do that. Q Are you saying because Rothstein, Rosenfeld, Adier was determined to be a criminal enterprise or somebedy was running a criminal enterprise out of that law firm, that is the reason why you are not going to answer these questions teday? You linked that together in that answer. I just want to make sure I'm understanding that right? A_ I'm going to take the Fifth -- ] intend 1 to respond fo all relevant questions today, { would fike to respond; unfortunately my attorneys have counseled me I can't, | must assert my Fifth, Sixth and Fourteenth Amendment rights } under the U.S, Constitution. | Q Because other law firms have asked very similar questions and you haven't responded td any of theirs either. I just want to understand ; what the relationship between Rothstein, Rosenfeld, Adler is to you invoking your Fifth Amendment rights today, if you can articulate that for me. MR. PIKE: Form, compound, argumentative. A Rothstein, Rosenfeld, Adier has been described by the U.S. Attorney as a criminal enterprise and as part of the largest fraud in Florida's history, It has been reported that your firm fabricated multiple cases using me, and. against me in order to fleece unsuspecting i investors out of millions of dollars. | Q Another long time friend of yours is | | | | ! | Ghistaine Maxwell, right? A J intend to respond to all relevant. questions. 1 would like to answer most of these questions today, but J can't because my attomeys | have counseled me that { cannot provide answers to any questions relevant to this lawsuit, 1 must accept their advice or risk losing my Sixth Amendment right to effective representation. U.S. ‘Therefore I'll assert my Constitutional rights under the Fifth, Sixth and Fourteenth Amendment. ‘THE WITNESS: Excuse me, could we take a break? MR, EDWARDS: Already? THE WITNESS: Restroom. THE VIDEOGRAPHER: Going off the video} record 11:38 a.m. THE WITNESS: Thank you. (Pause in the proceedings.) THE VIDEOGRAPHER: We're back on the video record at 11:48 a.m. Q How did you meet Ghislaine Maxwell? A Lintend to respond to all relevant questions to this lawsuit; however, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing effective -- my right to effective representation. Accordingly, therefore, | assert my Fifth, Sixth and Fourteenth Amendment rights to the U.S. Constitution, Q You would agree, would you not, that Ghislaine Maxwell shares your sexual obsession for underage minor females? MR. PIKE: Argumentative, speculation, harassing, A You know, Mr. Edwards, the current U.S. Attorney has described your law firm asa criminal enterprise, and as taking part in one of the largest frauds in Florida's history. It has been widely reported that your firm fabricated multiple cases of a sexual nature against people -- other people and me, in order to fleece unsuspecting investors out of millions of dollars, so unfortunately at this time in response to your questions, my attorneys have advised me [ must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right though I believe, as you know, I would really like to answer these questions, but at this moment, although at this time [ have to assert those rights or risk losing effective counsel, Q Do you know Annie Farmer? A. Lintend to respond to all relevant questions regarding this lawsuit; however, at the present time my counsel has advised me that I cannot provide answers to any questions relevant 7 (Pages 22 to 25) Legal Support (561) 835-0220

26 to this lawsuit. Your firm has been described as acriminal enterprise, and is part of the largest fraud in Florida's history fabricating sexual cases against me and others. Therefore, unfortunately, although I would like to answer all of your questions today, I'm going to have to assert my Fifth, Sixth and Fourteenth Amendment right. Q Did you and Ghislaine Maxwell sexually assault Annie Farmer at Leslie Wexler's house? A J intend to respond to all relevant questions regarding this lawsuit; however, at the present time my attorneys have counseled me 1 cannot provide answers to any questions relevant | to this lawsuit and must accept this right or risk losing my Sixth Amendment rights to effective presentation. Accordingly, I assert my Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth amendments to the U.S. Constitution. Q Stating Ghislaine Maxweil and you had | devised several schemes to lure underage girls to you for sex; isn't that correct? 7 MR. PIKE: Form, argumentative, harassing? 27| A Mr. Edwards, your firm has fabricated multiple cases of sexual harassment claims and = other types of sexual cases against me and others in order to be part of what the U.S. Attomey has | described as the largest fraud, the largest fraud in Florida's history, 1 would like to answer all your questions; however, my attorneys have counseled me that at least today, I must assert my Fifth, Sixth and Fourteenth Amendment rights under the U.S. Constitution, Q Do you own a home in Manhattan? A Lintend to respond to all relevant questions to this lawsuit; however, at the present time my attomeys have counseled me that E cannot provide answers to any questions t relevant to this lawsuit, and | must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, therefore, 1 have to assert my Fifth, Sixth and Fourteenth Amendment right under the U.S. Constitution. Q Do you own an island in the U.S. Virgin ' Ustands? A Tintend to respond to all relevant questions regarding this lawsuit; however, at the | | | 1 | | | i | 9 10 il 12 13 14 1s 16 17 18 19 20 24 22 23 24 25 28 present time my attorneys have counseled me that J cannot provide answers to any questions relevant to this lawsuit, no matter how much I would like to. Therefore, I must accept their advice or risk losing my Sixth Amendment right to effective representation; therefore, { have to assert my Fifth, Sixth and Fourteenth Amendment right unde} the U.S. Constitution. Q Do you own a home in New Mexico? A. Lintend to respond to all relevant questions regarding this lawsuit and as I've had to do with most of your questions here today, I'm going to have to take my attorneys’ advice and assert my Fifth, Sixth and Fourteenth Amendment right under the U.S. Constitution or risk losing effective representation. Q Is it true that you have had underage females, at each of those homes, for orgies with you and Ghistaine Maxwell? MR. PIKE: Form, argumentative, speculation and harassing. A 1 would like to answer that question. I really would. However, as your firm has been described by: the U. Attomey 3 asa a criminal 29 enterprise, which its principal purpose was racketeering conspiracy to generate money for the firm and its co-conspiritors through the operation of enterprise and through various activities including mail fraud, wire fraud and money Jaundering, and fabricating multiple sex cases against me and others, though I would like to answer your question today, Mr, Edwards, my counsel has advised me I must take the Fifth, Sixth and Fourteenth Amendment right provided by the U.S, Constitution, Q Do you know somebody named Galitsea (phonetic)? MR. PIKE: Can you spell that, for the record? MR. EDWARDS: No. MR. PIKE: Or for the court reporter? A No. Q You don't know the name? A No. Could you spell it? Q (Witness shrugs.) A Okay. Q Did your sexnai obsession with underage minor females grow at some point in time to allo you access to these underage minors every single 8 (Pages 26 to 29) U.S. Legal Support (561) 835-0220

years? day for sex? MR. PIKE: Overbroad. Speculation, argumentative, compound, harassing end confusing as well; as worded. Do you want to break it down, Mr. Edwards? Q Isn't it true that for the past ten years you have found a way to engage in sexual conduct with underage minors on an every day basis? MR. PIKE: Speculation, Argumentative, A. As your firm bas been described as a criminal enterprise by the United States Attorney and is part of the scheme to defraud people in South Florida of millions of dollars, you have fabricated sexual cases and sexual claims against people like me and others. Unfortunately at this time although I would like to answer your questions, Mr. Edwards, my counsel has advised me Tcannot. They have advised me I must assert my Fifth, Sixth and Fourteenth Amendment rights under the U.S, Constitution, Q Isn't it true that you have premised underage minors money or other benefits to engner in sexual conduct with you over the past ten A. Again, as I've answered many of your questions today, and unfortunately will probably end up not answering most of your questions. today, as your firm has been described, the firm bringing this lawsuit, I believe, if I'm wrong please, correct me -Q You're wrong, A. This is the firm that didn't notice this deposition? Q Did not? A Did not? Q No. A Japologize. Though your former firm has been described, and the person you represent, L.M., in this case was represented by the firm that was described by the U.S. Attorney as perpetrating one of the largest frauds in South Florida's history, fabricating multiple sexual cases against me and others in order to fleece unsuspecting investors out of millions and millions of dollars, so though unfortunately, | would like to answer each one of your questions today, my counsel has advised me | must assert my Sixth Amendment, Fourteenth Amendment and Fift Amendment right, though I believe you know, I 1 | i 1 ' i | OORYHAM ELUNE 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SUF Yew 10 li 12 13 14 15 16 17 18 19 20 24 22 23 32 would like to answer those questions, though at this moment I must assert those rights or risk losing my attorneys. Q Sure, let's test that answer. A Okay, Q Let's talk about Jane Doe 102, Jane Doe 102, V.R., whe was represented by Bob Josephberg's firm, had nothing te do with Rothstein, Rosenfeld, Adier. Do you know V.R. A Who? Q VR A Can you spell it? Q Common spelling like the State — A Can you spell it for me, please? Q A What's the last name, how is it spelled? believe. A [intend to respond to all relevant questions regarding this lawsuit; however, at the present time my attomeys have counseled me that {cannot provide answers to any questions that may be relevant to this lawsuit and 1 must accept this advice or risk losing my Sixth Amendment 33 right to effective representation. Accordingly, assert my Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the Constitution. > Q Just for the record, E can ouly spell it the way it was spelled in your flight logs from your airplane. I don’t know exactly how she spells her name, only how your pilot would spell her name. MR. PIKE: Form, speculating. Q If] misspell it -MR. PIKE: Form, speculation, argumentative, harassing. MR. EDWARDS: That's harassing? MR. PIKE; It assumes facts currently not in evidence in this particular deposition; therefore, I move to strike. MR. EDWARDS: I was responding to his question asking me how to spell her name. { don't know how other than his own pilot. MR. PIKE: Mr. Edwards, he asked you to spell the name, you then spelled the name, then went on with another narrative and there wasn't a question posed, on the floor. Q You would agree you interacted with V. 9 (Pages 30 to 33) U.S. Legal Support (561) 835-0220

34 every day in a sexual way, when she was 15 years old, right? A Again, I'm sorry? Q Sure. You would agree that you interacted with V.R. sexually on an every day basis when she was 15 years old? A. You know, again, Mr. Edwards, 1 would like to answer all your questions here today. My attorneys have asked me -- advised me that 1 must assert my Sixth Amendment, Fourteenth Aaah 10 aad Fifth Amendment rights provided by the U.S. Constitution and the fact that the current U.S, Attorney has described your law firm as a criminal enterprise, is one of the largest frauds in Florida's history for fabricating sexual -cases of a sexual nature against me and others. Unfortunately, although | would like to answer those questions, if I do I risk losing my attorneys’ counsel. Therefore, I must assert my right. MR. EDWARDS: Madam court reporter, I'll attach as an exhibit, the Jane Doe number 102 versus Jeffrey Epstein complaint, at some point in time. It will be Exhibit 1, as I'm going to go through some of the facts 35 as alleged in the complaint and as will be testified to by the plaintiff. (Jane Doe number 102 versus Jeffrey Epstein complaint was deemed marked as Exhibit number 1 for identification, as of this date.) MR. PIKE: Counsel, do you have an extra copy of that for me? MR. EDWARDS: No. MR. PIKE: May I fook at it real quick? MR. EDWARDS: No. It has my notes on 1 i | | it. | MR, PIKE: J understood, I saw the | highlights. i MR. EDWARDS: The notes are highlighted so when we copy it, it will not show up. | MR. PIKE: Just for the record, that's 2 | current, operative pleading, correct? MR. EDWARDS: Correct. ‘THE WITNESS: What does that mean? MR. PIKE: There may have been some amendments to a complaint and I want to make sure that’s the operative complaint at issue that he is speaking of today. THE WIINESS: Can I go off the record il 12 13 14 15 16 17 18 19 20 21 22 23 24 for a second? May I ask you a question? MR. PIKE: Sure. Can we take a break for a second? MR. EDWARDS: Again? ‘THE WITNESS: Just a question. MR. PIKE: He wants to speak with me for @ second, THE VIDEOGRAPHER; Off the video recor: 12:01 p.m. (Pause in the proceedings.) THE VIDEOGRAPHER: We are back on the video record at 12:02 p.m. Q Is it true, Mr. Epstein, that you and Ghislaine Maxwell forced V.R. to have sex with you on a daily basis? MR. PIKE; Form, argumentative, harassing, A Unfortunately at this time, though T would really like to answer those questions, and like I have done for most of your questions here today, Mr. Edwards, your firm was described as a ctiminal enterprise, a serious criminal enterprise by the current U.S. Attorney. Part of that criminal enterprise was fabricating cases of 37 a sexual nature against me and others in order to fleece unsuspecting investors out of millions of dollars. Though, unfortunately at this time no matter how E would like to respond to your questions, I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right under the U.S. Constitution or risk having my attorneys resign. Q Isn't it true that V.R. was yours and Ghistaine Maxwell's sex slave from the time she was 15 through the time she escaped when she w 19? MR. PIKE: Again objection, argumentative, harassing. A Mr. Edwards, your firm has been described as -- excuse me, as a criminal enterprise by the current U.S. Atomey and part of the largest fraud in Florida's history. Part of that fraud was fabricating multiple cases against people like me and others, of a sexual nature, in order to fleece unsuspecting investors out of millions and millions of dollars, so though I would like to answer that question, my attorneys have told me today I must assert my Sixth Amendment, Fourteenth Amendment and Fi: 10 (Pages 34 to 37) U.S. Legal Support (561) 835-0220

Amendment right. Q Isn't it true that you and Ghislaine Maxwell celebrated her 16th birthday with her ani had sex with her on that day? MR, PIKE: Form. Compound, confusing, argumentative, harassing. A Mr. Edwards, I would like to answer that question. My attorneys have told me today, I have to at least today assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights fo the U.S. Constitution, especially my concern is, that your firm has filed fraudulent lawsuits, fabricated lawsuits, and the U.S. Attorney, the current U.S. Attorney has described your firm as a criminal enterprise that ~ whose main purpose was to generate money for the firm and its co-conspirators through the operation of various criminal activities, including mail fraud, wire fraud and money laundering. Q Are you saying that the complaint of L.M. against you, the allegation in that complaint, are false? MR. PIKE: Form, Misinterprets the witness's testimony, Q Or saying it is true? MR, PIKE: Same objection, Q Its either true or false? A I'lbrepeat myself, unfortunately, but the current U.S. Attorney has described your law firm that filed that filed L.M.'s claim -- was involved in the filing of L.M.'s claim, motions -- I'm sorry, do you want to tefl me what it was then? Would you like to tell me the firm's involvement in this lawsuit, since we will be here the rest of the day? Q Answer the question. A. Allright. The U.S. Attorney has described that firm as a criminal enterprise perpetrating one of the largest frauds in Florida's history against unsuspecting investors, fleecing them out of millions of dollars by creating, crafting and fabricating fellacious (sic) sexual claims against people like me and others, so unfortunately, though I would like to answer your questions, Mr. Edwards, my counsel has advised me) that at least today I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution. Q Isn't it true, sir, and i'm reading from 21 22 an 24 25 40 the complaint filed by V.R. against you, isn’t it true, sir, that a friend of yours sent you three, 12-year old femates for you to sexually abuse on one of your birthdays? MR. PIKE: Form, argumentative, harassing, and irrelevant to this lawsuit. THE WITNESS: Excuse me. A You're saying it is part of the Jawsuit? Q Yes, ('8 read it. “On one of the defendant Epstein’s birthdays, a friend of defendant Epstein sent him three, 12-year ofd girls from France who spoke nq English for defendant to sexually exploit and abuse? After doing so they were sent back to France the next day.” Isn't that true? MR. PIKE: Once again, move to strike, irrelevant, argumentative, harassing, and for the record, the exhibit that's being read from is a complaint that's unrelated to the instant matter and not filed or incorporated by the current plaintiff, L.M., in this matter. A_ I would like to answer that question, I really would; however, today my attorneys have told me I have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment right of the U.S. Constitution, especially because your firm involved in this lawsuit has fabricated, widely reported, multiple cases of sexual harassment cases against individuals like me and others, perpetrating what the U.S. Attorney called one of the largest frauds in Florida's history, fleecing people out of millions of dojlars, so though I would like to answer that question, today I have to assert those rights or tisk fosing my attorneys' counsel, Q Isn't it true that you forced V.R. as a 15-year old girl to have sex with numerous friends of yours? A Are you kidding? Q Reading from a lawsuit. A Sorry, Mr. Edwards. Though I would like to answer that question as well, as I've answered most of your other questions here today, I would like to respond; however, my attorneys here today have advised me | have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution, 11 (Pages 38 to 41) U.S. Legai Support (561) 835-0220

42 enterprise engaged in various criminal acti 1 including mai} fraud, wire fraud and money. 2 laundering. 3 Q Do you know a man named Jean Lac 4 Brunel? 5 A Can you spell #? 6 Q He was at your house last week, does 7 ~~ that remind you? 8 MR. PIKE: Form, move to strike, 9 speculation, argumentative, harassing, 10 Is there a question on the table, Mr. 11 Edwards? 12 MR. EDWARDS: Yes. 13 Q Do you know him? 14 A Can you spell his name for me, please? 1S Q I don't need to spell his name. Do you 16 know who I'm talking about, Mr, Branel? 17 A Sorry, Mr. what? 18 Q Berne, 19 A {would like to answer that question as 20 well, but my attorneys have counseled me today I 21 have to asserl my Sixth Amendment rights, Fifth 22 Amendment rights and Fourteenth Amendment right 23° under the U.S. Constitution or risk losing my right to effective representation, Q What's the purpose for you asking me to 1 especially as your firm has been accused by the | 2 U.S. Attorney as being a criminal enterprise, and | 3 part of the largest fraud in Florida's history. } 4 Basically -- sorry, if l didn't read correctly, S um... the operation of the enterprise through 6 various criminal activities including mail fraud, 7 wire fraud and money laundering, fabricating | 8 sexual harassment cases against people like me 2 and others, 10 Q By the way LL A Yes, sir? 12 Q —didn't V.R, receive 2 round trip 13 ticket paid for by you to Thailand, and she 14 ultimately did not get back on the plane but 15 — instead escaped to Australia? 16 A I would Jike to answer that question, 17 but today 1 would have to assert my Sixth 18 Amendment tights, my Fifth Amendment rights and) 19 my Fourteenth Amendment rights under the U.S. 20 Constitution, especially since your firm has been 21 described as perpetrating one of the largest 22 frauds in Florida's history, fleecing investors 23 out of millions of dollars, being described by 24 the U.S. Attorney of South Florida, as a criminal 44 1 spell his name? Are you acting like you don’t 2 know him? 3 MR. PIKE: Form, move to strike, 4 argumentative and irrelevant as worded. 5 Mr. Edwards, you know that there are 6 various standing orders, if not in this 7 ease, in various other cases, that 8 specifically describe the protections of the 9 Fifth Amendment. Federal Courts have 10 ordered that certain questions that you are 11 asking shali not be answered or Mr. Epstein 12 would risk losing his Fifth Amendment 13 right -~ 14 MR. EDWARDS: I understand that. He is| 15 asking to spei] people's names. 16 MR. PIKE: -- under the United States 17 Constitution. A lot of these questions here 18 today that you're asking have already been 19 ruled on by various Courts, that the Fifth 20 Amendment protects any response thereto, so 21 T would like -- I'm giving you some leeway 22 here with regard to the argumentative 23 questions. We've already -- and I'm not 24 obviously testifying for the witness, but we've already handled a lot of these issues 4s 1 in court and we have already adjourned one 2 deposition for being argumentative, and 1 3 think you understand what the Court said 4 there, so having said that, and [ understand 3 that you have a job to do, but having said 6 that, 1 would like to caution you: 7 professionally, if you continue with the 8 argumentative questions, I am going to have 9 to terminate this deposition -10 MR, EDWARDS: I completely understand. al MR. PIKE: Okay. We are here today 12 to-13 MR. EDWARDS: Mr. Brunel -14 MR. PIKE: | want the Court to know we 13 are here today to allow you to ask your 16 questions, but the harassing and 17 argumentative tone is not going to be 18 tolerated. 19 MR. EDWARDS: We have a video. We can} 20 show the Court the tone. It is obviously 21 not harassing. 22 MR. PIKE: That's fine. 23 Q@ Mr. Brunel is 2 long-term friend of yours, right? A Lintend to respond to ali relevant 12 (Pages 42 to 45) U.S. Legal Support (561) 835-0220

46 1 questions of this lawsuit; however, today my | 2 attorneys have counseled me I cannot provide 3 answers to any questions that may be relevant to 4 this lawsuit and I must accept their advice or 5 risk losing my Sixth Amendment right to effective 6 — representation, 7 Q You know him as somebody who has been 8 — canght engaging in sex with underage minors in 9 the past; is that correct? 10 MR. PIKE: Form, 11 A You will have to repeat the question, 12 Tm sorry. 13 Q You know Mr. Brunel as somebody who has 14 been caught engaging in sex with minors in the 15 past; is that correct? 16 MR. PIKE: Fonn. 17 A [intend to respond to all relevant 18 — questions regarding this Jawsuit; however, at the 19 present time my attorneys have counseled me that 20 J cannot provide answers to any questions 21 relevant to this Jawsuit, and I must accept their 22 advice or risk losing my Sixth Amendment right to 23 effective representation as your firm has been 24 ~~ described by the U.S. Attorney as a criminal 25 _ enterprise and part of one of the largest frauds 1 in Florida's history specifically said you have 2 been fabricating — the law firm has been 3 fabricating multiple cases of a sexual nature in 4 — order to fleece unsuspecting investors out of 5 millions of doliars, including mati fraud, wire 6 fraud and money laundering, so unfortunately, | 7 though F would like to answer all your questions 8 here today, I must assert my Sixth Amendment, 9 Fourteenth Amendment and Fifth Amendment right, 10 Q You were involved in a modeling business | 11 with him called M.C. Squared; is that correct? | 12 A Again? i 13 Q You were involved in a modeling agency | 14 with | 15 A What do you mean -- | i | | 16 Q with Mr. Brunel called M.C, Squared? 47 A “Involved" means what, what do you 18 mean? 19 Q You tell the jury your involvement with 20 the modeling agency. You can clarify for me, 21 Wet you do that. 22 MR. PIKE: Object to the fom, 23 A Fintend to respond to all relevant 24 questions regarding this lawsuit. However, at 25 the present time my attorneys have counseled me WO nTewne 48 that I cannot provide answers fo any questions relevant to this lawsuit and | must accept their advice or risk losing my Fifth, Sixth and Fourteenth Amendment rights under the U.S. Constitution. Q When you were being criminally investigated and V.R. was in Australia, is it true that you made a personal telephone call to her telling her not to come forward with any of the information she knew? MR. PIKE: Form, A Again? Q Putting a time frame on it, the time frame where you were being criminally investigated -~ A What time frame is that? Q In her compiaint it is not specific, but, let's just make it whenever, At some point in time did you place a telephone cail to V.R. in Australia warning her not to come forward wit! any information about you engaging in sex with her while she was 2 minor? MR. PIKE: Fonn. A_ Lintend to respond to all relevant questions regarding this lawsuit; however, at the 49 present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept their advice or risk losing my Sixth Amendment right t effective representation. Q With respect te underage fema}es, isn't it true that you haye made the statement, in quotes, “the younger the better"? MR. PIKE: Form. A Again, as your firm has been described by the current U.S. Attorney as a criminal enterprise involved in mail fraud, wire fraud, money laundering, and specifically crafting, fabricating multiple cases of sexual -- of a sexual nature against people like me, and others, in order to fleece many, many unsuspecting investors out of millions of dollars; | would like to answer your questions here today, Mr. Edwards, but unfortunately, my attorneys have counseled me that { must assert my Fifth, Sixth and Fourteenth Amendment right or they will resign. Q Who are your current employees? MR. PIKE: Form. A. Say that again. 13 (Pages 46 to 49) U.S. Legal Support (561) 835-0220

22 23 24 25 © OIA WN 10 1a 12 13 14 15 16 17 18 19 20 21 22 23 24 50 Q Who are your current employees, people who work for you, that you pay? A Jintend to respond to all relevant questions regarding this lawsuit; however, at the present time my attorneys have counseled me that I cannot provide answers to any questions that may be relevant to this lawsuit, or risk losing my Sixth Amendment right to effective representation. Accordingly, therefore, I must assert my Sixth Amendment, Sixth Amendment and Fourteenth Amendment rights as provided by the U.S, Constitution, Q Isn't it true you pay your employees to bring you underage minor females for sex? 1 MR, PIKE: Form, argumentative, speculation, harassing. A Mr. Edwards, your firm has been described the current U.S. Attorney as a criminal enterprise, a criminal enterprise, part of the { largest fraud in South Florida's history; but | part of that fraud was fabricating, um, | fictitious cases against me -- excuse me, against people like me, of a sexual nature, in order to fleece unsuspecting investors out of mitlions of Unfortunately at this time, though, I would like to answer every one of your questions. My attorney has advised me I must assert my Sixth Amendment, Fourteenth Amendment] and Fifth Amendment rights or risk losing them as my attorneys, Q Isn't it true when underage females were brought to you, you would engage in sex with them and pay them? MR. PIKE: Form, argumentative, harassing. A (Witness shakes head.) Q Are you shaking your head to say "no" — | A Excuse me, Q Are you shaking your head tosay"no,f | don't know how to interpret that answer?" A. I didn’t realize I was shaking my head. MR. EDWARDS: | thought he was actually answering 2 question. MR. PIKE: We'll just strike. The rules are well-known to every lawyer who practices in the State of Florida, that it is clear that a nod of the head or shake of the head is not understood by the record, so therefore Mr. Epstein wes clearly not 25 CoOIKHRWHY 10 12 13 14 is 16 17 18 19 20 22 22 23 24 ORI HHeune 10 12 13 14a is 16 at 18 19 20 21 22 23 24 52 responding to one of your questions and you know that, Mr. Edwards. MR. EDWARDS; This is on the video. MR. PIKE: Nonetheless you know the rules. Nonetheless, If we have a question on the table, would you please repeat it so [can recall it and Mr. Epstein can endeavor to answer it, MR. EDWARDS: Sure, and if it was only the court reporter, I would agree, but the jury is going to see a video and everybody knows commonly, if somebody shakes their head, they are saying “no," and if that was the answer, | wanted to give him a chance to elaborate on it, that's it. Q Isn't it true that when underage females would come to your house, you would engage in sexual activity with them and then pay them? MR. PIKE: Same objections. A Unfortunately | would fike to answer that question today, but my attorneys have counseled me that I must assert my Sixth Amendment right, my Fifth Amendment right and m Fourteenth Amendment right under the U.S. The fact that your firm hes been described as a criminat enterprise and part of one of the fargest frauds in Porida’s -- South Florida’s history, part of that fraud has been described as fabricating cases of sexual nature against me and others in order to fleece unsuspecting investors out of millions of dollars, I would like to answer that question, Mr. Edwards; however, today, I must assert my Fifth, Sixth and Fourteenth Amendment right. Q In addition to paying these underage females for sexual activity, you also paid them to bring their underage friends to you, to also engage in sexual activity with them? MR. PIKE: Form. Q Is that correct? A. Lintend to respond to all relevant questions regarding this lawsuit; however, at the present time my attorneys have counseled me that I may not, and § orust assert -- they have advised me I must assert my Sixth Amendment right, my Fifth Amendment right and my Fourteenth Amendme! rights under the U.S. Constitution. Q You would pay underage females 200 to $300 for engaging in sexual activity with you or 14 (Pages 50 to 53) U.S. Legal Support (561) 835-0220

Co PIHHeRuNnH 23 was devised to coerce underage girls into 54 for procuring another underage female to ane in sexual activity with you; is that correct? MR. PIKE: Form, move to strike. Assumes facts not in evidence and calls for a legal conclusion as well, argumentative. A Lintend to respond to all relevant questions regarding this lawsuit; however, at the present time my attomeys have counseled me that L cannot provide answers to any questions that | may be relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, therefore, I must assert my constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the U.S. Constitution. Q Would you agree that your scheme was devised to coerce these underage minors to bring! you as many other underage minors, as were available for you to engage in sexual activity with? MR, PIKE: Form. A Can you repeat the question? Q Yes. Would you agree that your scheme 55 bringing as many other underage girls to you, as were available for sexual purposes? MR. PIKE: Form. A Did you say “for sexual purposes"? Q Yes, for sexual purposes. A. I'm not surprised. Since your firm was described as perpetrating one of the largest frauds in Florida's history by crafting, fabricated sexual harassment cases against people like me and others in order to fleece unsuspecting investors out of millions of doflars, | would like to answer that question. However, today my attorneys have advised me ! must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right under the U.S. Constitution, and if | don't do so, I risk losing -- uh... losing effective representation. Q Utilizing this method of using underage miners to bring you other underage minors, you | were able to engage in sex with hundreds of underage minor females, Is that true? MR. PIKE: Form, argumentative, harassing and calls for speculation. | A. Since, Mz. Edwards, your firm has been | described as a criminal enterprise by the U.S. | sexual activity with underage minors on an every| 56 Attorney, and as part of the largest fraud in South Florida's history, and as part of the fraud fabricating malicious cases of sexual harassment and other cases of sexual nature against people like me and others, although I would like to answer that question today, my attorneys have advised me I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment right of the U.S. Constitution. Although I believe you know I would really lke to answer your questions, but at this moment if I don't assert those rights, I risk having my attomeys resign. Q Isn't it true with this method you were able to interact sexually with underage giris every single day? MR. PIKE: Form, asked and answered. Same objections. Q Go ahead. A Oh, I'm sorry. Can you repeat it? Q Sure. With this method of -A “This method" being what, sorry? Q Your method of using underage minors to briag you other underage minors for sex; isn't it true that that method resulted in you engaging in| 57 day basis? MR. PIKE: Same objections, A Your firm has been described by the current U.S. Attorney as a criminal enterprise engaged in one of the largest frauds in South Florida's history, and as part of that fraud, creating, fabricating, malicious cases of sexual nature against people like me and others, so unfortunately, though I would like to answer that question today, I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment righ’ to my counsel's advisement to do, although f believe you know I would really like to answer those questions today, I must assert those rights or risk losing my attorney's representation. Q To keep track of all these underage minors, you stored their names and telephone numbers in your home computer; isn't that correct? MR. PIKE: Form, argumentative, speculation, A. Again? Sorry. Q Are you going to answer the question or just read? If you are going to answer the question, of course, I'll keep reading it as many 15 (Pages 54 to 57} U.S. Legal Support (561) 835-0220

times. A Excuse me? MR. PIKE: The witness is attempting to answer your question. He asked you to repeat the question. MR. EDWARDS: He is? MR, PIKE: He asked you to repeat the | question. MR. EDWARDS: I don't mind going throug that, Mike, because I do want answers, but if I'm going to repeat the question multiple times and get the same answer, we are wasting time. I want to stop us wasting time repeating questions if I'm getting the same nonresponsive answer. MR. PIKE: | understand your intention here. MR. EDWARDS: Yeah. MR. PIKE: -- however, these questions are similar in nature, if not identical to various questions that you've asked in other indications, so you coming here today is of no surprise that Mr. Epstein ts required to invoke his Fifth, Sixth and Fourteenth Amendment rights under the United States 59 Constitution ~ MR. EDWARDS: J understand that. MR, PIKE: -- ifyou came here today thinking you were going to pull a rabbit out of a habit, and Mr. Epstein was going to waive his Fifth, Sixth and Fourteenth Amendment rights to the U.S, Constitution, at least not today, That will not be occurring. Q Isn't it true that to keep track of the names and phone numbers of these underage min females, to interact with sexually, you stored those names and phone numbers in your home computer? now. It didn't surprise -- again, I've now heard the question and the fact that your firm hes been described as a criminal enterprise by the current U.S. Attomey in South Florida, and part of one of the largest frauds in Florida's history, it is reported that your firm fabricated malicious cases Of a sexual nature against people and against me, in order to fleece unsuspecting investors out of millions of doftars. Unfortunately, though T would like to. I { | A. Thank you. I've heard the question {3 | I | | 60 answer each one of your questions today, Mr. Edwards, my attorneys have advised me that ] must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution. So although I would like to answer, I must assert those rights or risk having my attorneys resign. Q Do you know Sarah Kellen? A Tintend to respond to alf relevant questions regarding this lawsuit; however, at the present time my attomeys have counseled me that T cannot provide answers to any questions relevant to this lawsuit and must accept their advice or risk losing my Sixth Amendment right to effective representation. Q Isn't it true you employed Sarah Kellen to contact underage minor females and make then) appointments to be at your house? A. Sorry, again? Q Isn't it true you employed Sarah Kellen for the purposes of contacting underage minor females and scheduling them appointments to be a) your house? A The current U.S. Attorney has described your law firm, Mr. Edwards, as a criminal 61 enterprise engaged in one of the largest frauds in South Floride's history. It has been reported that your firm fabricated multiple cases of a sexual nature against me and others, in order to fleece unsuspecting investors out of millions and miltions of dollars, so, though unfortunately I would like to answer every onc of your questions today my attorneys have counseled me that today I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution. Though I believe you know I would like to answer those questions, although today I must assert those rights or risk having my attorneys resign. Q Tell the jury how you know Nadia Marcinkova. MR. PIKE: Form move to strike. MR. EDWARDS: Move to strike my question? MR. PIKE: (Nods.) MR. EDWARDS: What basis? ** MR. PIKE: Do F have to state a basis? Usually I'm just required to state “form.” MR. EDWARDS: You have done more than 16 (Pages 58 to 61) U.S. Legal Support (561) 835-0220

62 1 that today. 2 MR. PIKE: If} went on a diatribe of | 3 explaining, you know, what's confusing, 4 compound and relevant, then you would blame 5 for testifying for the witness. So | just 6 move to strike the question, 7 MR. EDWARDS: Make sure you mark that 8 somewhere on this transcript, somehow. 9 Q Tell the jury how you know Nadia 10 Marcinkeva? 11 MR. PIKE: Move to strike, 12 A. [intend to respond to all relevant 13 questions regarding this lawsuit. However, at | 14 the present time my attorneys have counseled me | 15 that I cannot provide answers to any questions 16 relevant to this lawsuit and must accept their 17 advice or risk losing my Sixth Amendment right to 18 effective representation. Accordingly, I assert { 19 my Fifth Amendment, Sixth Amendment and 20 Fourteenth Amendment right under the U.S. 21 — Constitution. 22 Q Isn't it true that you breught her te 23 this country when she was underage and made he 24 your sex slave, and you've bragged about this? 25 MR. PIKE: Form, argumentative, compound, harassing and calls for speculation, A J intend to respond to all relevant questions regarding this lawsuit; however, at the present time my attomeys have counseled me that I camnot provide answers to any questions relative to this lawsuit and { must accept this advice or tisk losing my Sixth Amendment right to effective representation, However, I would like, 10 so F'm clear, the question was, did I bring her 11 here? Specifically -OnawAnewne 12 Q Your answer is fine. 1 13° A Okay. | 14 Q Is it true that you demanded numerous 15 underage minor females to have sex with Nadia =| 16 Marcinkoya inside your home while you watched, 17° masturbating? j 18 MR. PIKE: Same objections, j 19 A You have to repeat the question. 20 Q Isn't it true that you have ordered 21. several underage minor females to have sex with | 22 Nadia Mareinkova in your home while you watched, 23 masturbating? MR. PIKE: Same objections. A The current U.S. Attomey has described Ceartrauneauwne 16 64 your firm, Mr. Edwards, as a criminal enterprise involved in mail fraud, wire fraud, money laundering and, in fact, fabricating multiple cases of a sexual nature against me, others, in order to fleece unsuspecting investors in South Florida out of millions and millions of dollars. Unfortunately, though | would like to answer each one of your questions here today, my attorneys have advised me I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment right under the U.S, Constitution, although 1 believe you know I would like to answer your questions, but at this moment I must assert those rights or risk having my attorneys resign. Q Isn't it true that with each of these underage minor females that were brought to you house, your method of sexually exploiting them ‘was nearly identical; is that correct? MR. PIKE: Objection, argumentative, confusing, overbroad and vague. A I don't even understand the question. Q Okay. When a 14 or 15-year old would be led inte your bedroom, you would appear from th shower first, usually naked; is that correct? 65 MR. PIKE: Objection, argumentative, assumes facts not in evidence, and ‘harassing. A. Tintend to respond to all relevant questions regarding this lawsuit; however, today my attorneys have advised me that 1 cannot provide answers to any questions relevant to this lawsuit and must accept their advice or risk fosing my Sixth Amendment right to effective representation. Accordingly, therefore, | must assert my Constitutional rights -- the Fifth Amendment, Sixth Amendment and Fourteenth Amendments to the U.S, Constitution. MR. PIKE: Can we go off the record for asecond? MR. EDWARDS: If it is necessary. MR. PIKE: Yes, let's go off the recotd, THE VIDEOGRAPHER: Going off the vid record at 12:35 p.m. (Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video record 12:44 p.m. MR. EDWARDS: Can you tell me what my last question is? 17 (Pages 62 to 65) U.S. Legal Support (561) 835-0220

THE COURT REPORTER: Certainly. (The record was read.) Q After appearing from the shower naked, | you would order the underage minor female to disrebe; isn't that true? MR. PIKE: Same objections. Form. A. [intend to respond to al! relevant questions regarding this lawsuit; however, at the present time my attorneys have counseled me F cannot provide answers to any questions retevant to this lawsuit and must accept their advice or risk losing my Sixth Amendment right to effective | representation. i Q You would then order them to, or order her to begin providing you a massage; is that correct? MR. PIKE: Form. A. [intend to respond to all relevant questions regarding this fawsuit and 1 would fike to answer each and every one of your questions today, Mr. Edwards; however, my attorneys have told me that cannot do that today unless and I must assert my Sixth Amendment, Fifth Ampadmes and Fourteenth Amendment rights under the U.S. Constitution or risk losing my counsel. Therefore, I'm going to assert those rights as guaranteed by the Fifth Amendment, Sixth Amendment and Fourteenth Amendment. Q You would then roll over and continue with masturbating; is that correct? MR. PIKE: Form. A | intend to respond to ali relevant questions regarding this lawsuit. It is -- it is my understanding that the current U.S, Attorney has described your law firm as a criminal enterprise, yours and Mr, Jaffe’s firm, as a criminal enterprise and part of the largest fraud in Florida's history, fabricating malicious cases of a sexual nature against me and others, in order to fleece investors out of millions of dollars, through bogus schemes including conspiracy to -- excuse me - to commit mail fraud, wire fraud and money laundering, so though I would like to answer each and every one of your questions here today, my attorneys have counseled: me I cannot, and must assert my Fifth, Sixth and Fourteenth Amendment rights under the U.S. Constitution. Q You would then rub the underage minor female's vagina and/or insert your fingers into her vagina; is that correct? MR. PIKE: Form. A Lintend to respond to all relevant questions regarding this lawsuit. Unfortunately, today my attorneys have advised me I cannot, must assert my rights under the U.S. Constitution, under the Fifth Amendment and Sixth amendment an: Fourteenth amendments of the U-S. Constitution, especially since your firm has been described as acriminal enterprise by the current U.S. Attorney perpetrating one of the largest frauds in South Florida's history, fleecing investors out of millions of dollars by fabricating malicious cases, malicious cases of a sexual nature against people like me and others. Q With many of these underage minors you would use vibrators on them; is that correct? MR. PIKE: Form. A. Twould like to respond to that question as] would like to respond to all your other questions today. However, my attorneys have counseled me that | must assert my Sixth Amendment rights, my Fifth Amendment rights and my Fourteenth Amendment rights under the U.S. Constitution. 69 Q And with many of these underage minors, you would give and/or receive oral sex from them] is that correct? MR. PIKE: Form, . A. J intend to respond to all relevant questions regarding this lawsuit, and I would like to answer each and every one of your questions; however, my attorneys have counseled me that today | must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right under the U.S, Constitution, especially since your firm has been described by the current U.S. Attorney as perpetrating one of the largest frauds in Florida -~- in Florida's history, by fabricating malicious cases of a sexual nature against me and others. Q In June of 2008 you pled guilty to a couple of felonies, right? MR. PIKE: Form, vague and confusing. A Again? Q In June of 2008, you pled guilty to twe felonies; is that correct? MR. PIKE: Same objection, A Yes. Q And what were those felonies that you 18 (Pages 66 to 69) U.S. Legal Support (561) 835-0220

ORO RWNe 22 23 24 70 pled guilty to? 1 A Solicitation of prostitutes, not 2 underage prostitutes but simply prostitutes. ; 3 Solicitation of prostitutes and one count of 4 procuring a minor for underage sex. § Q You have taken the Fifth as to questions 6 related to many of these underage minors, but the 7 underage minors that were the victims in the 8 cases where you pled guilty, were A.H.; is that 9 one of them? 10 MR. PIKE: Form, mischaracterizes the il witness's testimony. Calls for a legal 12 conclusion? I 13 A Again. i 14 Q What was the name of the any of the {1s underage minors that were the subject of the 16 criminal charges to which you pled guilty? 17 A don't know. 18 Q So, tell me about those charges. What 19 were the allegations of those charges? | 20 MR. PERE: Form. 21 A. Solicitation of prostitution, not 22 underage prostitution... Prostitution, 23 Q Were the victims or the prostitutes, as 24 ou would say, were they minors? MR, PIKE; Form. i. A. Ipled guilty to soticitation of 2 prostitution. 3 Q Okay, so tell me what those cases were 4 about, What happened? 5 MR. PIKE: Form again. 6 A_ I... (Witness shrugs.) I can't tell you 7 any more than that, 8 Q You don't know what you pied guilty to? 9 A. I just told you ~ } 10 MR. PIKE: Object to the form, asked and 1. answered. 12 Q Do you know what you pled guilty to, the 13 facts? 14 A. Solicitation of prostitution, 15 Q Tunderstand that that's the charge. 16 ‘What were the underlying facts? What did you dé, Le did you pull up in a car, talk to the person, did | 18 they come over to your house, how did you get. | 19 them, those kinds of things. Tell the jury what 20 were the underlying facts about the charges you | 22 pled guilty to? 22 MR, PIKE: Object to the form, Move to | 23 strike. | 24 A_ I don't know, ; 25 72 Q You don't know what you pled guilty to? A. I pled guilty to solicitation of prostitution, not underage prostitution, but prostitution. Q My understanding from reading the cou files that one of these females was A.H. Do you know who that is? A. I intend to respond to all relevant questions in this lawsuit, However, at the. present time my attorneys have counseled me that 1 cannot provide answers to any of these questions today. So accordingly, | must assert my constitutional rights under the Fifth, Sixth and Fourteenth Amendments of the U.S. Constitution. Q You're aware A.H. is somebody that alleges she was at your house on more than 100 occasions; is that true? MR. PIKE: Form. A Can you repeat the question, sic? Q Are you aware that A.H. is a female that alleges that when she was underage, she was at your house on more than 100 occasions? MR. PIKE: Form, predicate. A lintend to respond to all relevant questions to this lawsuit, Mr. Edwards. However, today my attorneys have counseled me that F must respond by invoking my Fifth Amendment right, my Sixth Amendment right and my Fourteenth Amendment fight under the U.S. Constitution or risk losing them as my attorneys, so therefore ! must assert those rights, Q You understand that her complaint was that Epstein turned H. on to her stomach on the massage bed and inserted his penis in to her vagina, H. Stated Epstein began to pump his penis in her vagina and, she became upset over this. She said her head was being held against the bed forcibly as he continued to pump inside of her while she screamed "no," Are you aware of those allegations? MR. PLICE: Form, predicate. A. I'msorry, did you say there is a complaint? Q In the incident report that led toa charging document, that led to a charge that you have pled guilty to. Are you aware of that information coming from A.H.? MR. PEKE: I'm sorry, Mr, Edwards; what are you reading from? 19 (Pages 70 to 73) U.S. Legal Support (561) 835-0220

eooInnewne 74 MR. EDWARDS: The 87-page Palm Beach Police Department incident report where there are numerous underage females describing their interaction with Mr. Epstein at his house, f'm reading specifically from page 41 related to AH, who was one of the victims he pled guilty | to. | MR. PIKE: is that the same document that you're seeking production of, in this | same exact case? | MR. EDWARDS: I don't know what you're; talking about. This is something from the i Siate Attorney's file. | MR. PIKE: Okay. Sorry. What’s the | question? | Q Are you aware of that allegation? What i T just read to you. | A L would like to answer that question, | but, however, today my attorneys have advised me | T must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. {| Constitution. Q Assuming your attorneys have advised you but because of Res Judicata, double jeopardy, you | cannot be charged for any crimes that you have | already pled guilty to relating to A.H., so E | would like you to explain to the jury, in your = | words, or your version of the story, what was your interaction with A.H. at your house when sh: was a minor? MR, PIKE: Object to the form as worded. Couid disclose attorney/client i communications, | A. Lintend to respond to all relevant i questions regarding this lawsuit. I would like | to answer each of your questions today, however, | my attorneys have counseled me that I may not. | They've advised me that I must assert my Fifth | Amendment, Sixth Amendment and Fourteenth | Amendment rights under the U.S. Constitution. i Therefore, if 1 don't, I risk losing their counset. Therefore, I must assert those rights here today, Mr. Edwards. Q Ave you aware that A.H. Advised police that she was ripped and torn in her vagina area and had difficulty walking to the car after this episode where you forcibly inserted your penis into her vagina? MR, PIKE: Objection, relevance, OYA ee wre 2% 12 13 14 15 16 1? 18 19 20 a1 23 76 argumentative, compound, harassing. A This was who? Q The question is, are you aware A.H,? A AH. The current U.S. Attorney, since he has described your firm as a criminal enterprise and part of one of the largest frauds in Florida's history by fabricating, fabricating, malicious cases of a sexual nature against people like me and others, aad fleecing investors out of millions of dollars by using means described in the complaint against your firm, including mail fraud, wire fraud, money Jaundering; I'm afraid today, though I wouid like to answer each one of your questions, my attorneys have counseled me that I must not, F must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution, and I believe you know I would like to answer those questions. I must assert those rights or risk losing my attorney's representation. Q Do you know S.G.? A. Spell it, please. @ don't know how to spell her name, but do you know a S. have ever spetled her name for you. MR. PIKE; Form, move to strike, Q Her name is "S.G." A_ Lintend to respond to ail relevant questions regarding this lawsuit. However, at the present time my attormeys have counseled me} that I may not provide answers today, though I wouid like to, and I must, in fact, take their advice or risk losing their representation, so therefore, I must assert those rights under the US. Constitution. Q Do you know the names of any of the females that you allegedly solicited for prostitution and pled guilty to? MR. PIKE: Relevance. A Sitting here today, no, I do not. Q You asked me to spell S.G.'s name. That's somebody that your attorneys took her deposition about a year and a half ago. Does that help to refresh your recollection as to whi S.G. is? A_ I would like to answer that question but today, according to my attorneys, I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. 20 (Pages 74 to 77) U.S. Legal Support (561) 835-0220

rights. ee 78) Constitution. I must accept their advice or risk losing my Sixth Amendment right to effective representation, Mr, Edwards, so though | would like to answer the question, today 1 must assert those rights, Q There is another victim, her name is A.D., that was listed as one of the females at your house and you pled guilty to the solicitation of, I would like to ask you if you remember her? MR. PIKE: Form, confusing, compound. A AD.? Q Edon't know her first time, initial "A" jast name is "D." MR. PIKE: Same objection. A. J intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me! that I cannot provide answers to any questions relevant to this lawsuit, and 1 must accept their advice or risk losing my right to effective representation. Therefore, though I would like to answer the questions, | must assert those 79 Q With each case that results ina charge — THE WITNESS: Excuse me, is there some water? THE VIDEOGRAPHER: Off the record? MR. EDWARDS: Stopping again? THE WITNESS: Can 1 get some water? Mr. Jaffe, can you pass some water? THE VIDEOGRAPHER: There is no water here. THE WITNESS: Sorry. Q With each conviction, charge, or with each charge that Jeads to a conviction, there are facts and circumstances that lead up to that plea of guilty. MR, PIKE: Form, Q What are the facts and circumstances that led to you pleading guilty to the two felonies that you've described? MR, PIKE: Form, overbroad, compound, confusing, calls for a legal conclusion. A. | would like to respond to that question. I would tike to respond to that question, but today my attorneys have advised me I must assert my Fifth Amendment, Sixth Amendmen) COOH He wne io 12 13 14 15 16 17 18 19 20 21 22 23 24 25 80 and Fourteenth Amendment rights to the U.S. Constitution or risk losing effective representation. Accordingly, | must assert my rights as guaranteed by the Constitution. Q Just so you are clear, since your attorney made it an objection that it was unclear, then you invoked your Fifth Amendme rights — A Sorry. Q Fm talking about the cases where you already pied guilty and yon can't be charged again, What were the facts and circumstances that led up te you pleading guilty to these felonies? A I've answered the question. MR. PIKE: Same objection, asked and answered. THE VIDEOGRAPHER: Counsel. (Indicating five minutes Jefi on tape.) MR. EDWARDS: Okay. Q Just so the jury understands, these three females that were the subject of the guilty pleas in State Court, were procured by your method of having underage minor females locate other underage minor females and bring them to] 81 your house; isn't that correct? MR. PIKE: Objection, argumentative, compound, harassing, assumes facts not in evidence, I move to strike. A You have to repeat the question. Q Okay, A.H., A.D,, S.G. are all people that were, at the time you engaged in sexual activity with them, were underage and were brought by other underage minor femaies; is that true? MR, PIKE: Same objections incorporated as well as motion to strike, A I don't understand -- I'm sorry, [ don't understand the question. Q Isn't it true that you used underage minor females to bring other underage minor females to your house for sex? MR. PIKE: Asked and answered. A (Witness shrugs.) MR, PIKE: Way earlier on. MR. EDWARDS: He doesn't understand the question -MR, PIKE: You can answer the question, Q 1m going through the progression. MR. PIKE: You can answet, but it is 21 (Pages 78 to 81) U.S. Legal Support (561) 835-0220

82 asked and answered. 4 As your firm, Mr. Edwards and Mr. Jaffe’s has been described by the U.S. Attorney as perpetrating one of the largest frauds in I South Florida's history by crafting malicious cases of a sexual nature against people like me and others, in order to fleece, using bogus schemes, in the U.S. Attorney's words, investment schemes. Unfortunately, though I would like to | answer every one of your questions if I'm able, my attorneys have advised me I must assert my | Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights under the U.S. Constitution. Therefore, at the moment I cannot answer that question, Q The acts related to your guilty plea occurred at your Palm Beach house; is that correct? MR. PIKE: Form. A Again, sorry. Q Ifyou were soliciting prostitutes, it wasn't out on the street, it wasn't at a hotel. These were girls that you solicited to be prostitutes at your house in Palm Beach, correct? 83 MR. PIKE: Objection, relevance, argumentative, Calls for speculation as worded and assumes facts not in evidence. A Though I would like to answer that question, my attorneys today have advised me I cannot answer you today, and they've advised me I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S, Constitution. Otherwise I risk losing their representation. So, accordingly I must assert those rights, Mr. Edwards, and Mr. Jaffe. Q In what county did you plead guilty to these felony offenses? A Palm Beach County. Q These were crimes that occurred here in Palm Beach County? MR. PIKE: Form. | Q Is that correct? i A ... [pled guilty in Palm Beach County. | Q Isn't it true that you kept a calendar | or schedule -THE VIDEOGRAPHER: I have to change the tape. MR. EDWARDS: Change it. THE VIDEOGRAPHER: Off the video record ! | i 84 1 1:05 p.m. 2 (Pause in the proceedings.) 3 THE VIDEOGRAPHER: Back on the video! 4 record 1:15 p.m. 5: Q Mr. Epstein, as it relates to the 6 charges you pled guilty to, are you saying teday| 7 that those females that you interacted with 8 sexually, were prostitutes prior te meeting you?| 9 A I'm saying I pled guilty to the 10 solicitation of prostitution. il Q Right, and you would certainly agree 12 that that would require yourself and one other 13 individual for that act of prostitution, 14 correct? 15 MR. PIKE: Form. Also calls for a legal 16 conclusion. 17 A I pled guilty to solicitation of 18 prostitution. 19 Q@ Are you saying that those females that 20 were the victims, at least listed as victims by 21 the State, were prostitutes prior to meeting 22 you? 23 MR. PIKE: Form. Vague. Irrelevant? 24 A. [pled guilty to solicitation of 25 prostitution. 85 1 Q Do you have any remorse for your 2 actions -3 MR. PIKE: Form. 4 Q ~ against these victims that led to 5 your plea of guilty? 6 MR. PIKE: Form, argumentative. 4 A. I pled guilty to solicitation of 8 prostitution, not underage prostitution, simply, 9 prostitution. 10 Q Are you saying now that the subjects of 11 that, which were called victims, were not 12 underage when you engaged in sex with them?| 13 MR. PIKE: Form, argumentative, 14 speculation, assumes facts not in evidence, 15 as well as mischaracterizes the witness's 16 testimony. 17 A I pled guilty to solicitation of 18 prostitution, not underage prostitution, 19 solicitation of prostitution. 20 Q Iwas under the impression you pled 21 guilty to a second degree felony, that being 22. procuring a minor for the purposes of 23 prostitution. 24 A That's correct. 25 Q Soa minor is somebody under the age of 22 (Pages 82 to 85) U.S. Legal Support (561) 835-0220

24 25 18, and I'm asking for the guilty plea related to that count; are you at all remorseful for your interactions with that minor? MR. PIKE: Same objections. A What minor? Q The charge is procuring a minor. You tell me. Who was that minor? A I don't know. Q You were never told during the State Attorney's prosecution of yor, whe this person was? A No, Q Why did you plead guilty to a felony charge that resulted in you going te jail, without even knowing who the victim was? MR. PIKE: Form. That question calls for attorney/client information, and therefore, I'm going to instruct him not to answer that. Q [fit has anything to do with any conversations with your attorney, I don't want to know. I'm just going off of the plea colloquy between yon and the Judge, where you understoo! O©DIH HAWN E 10 li i2 i3 14 15 16 17 18 19 20 21 23 the charges and haye been advised and apprised df 24 the charges and you pled guilty te the charges. I'm taking now that you're saying, you don't even know what those charges were about? MR, PIKE: What was the question? £ don’t know the question on the table now. Q Who was the minor? A I don't know. Q You were never told the name or initials of that minor victim by the State Attorney's Office or the prosecutor? A Not that I recall. Q Just so the jury understands, this you other underage minor females for sex, is something that you do in New York, and New i Mexico, Florida, everywhere, not just West Palm | Beach; isn't that right? MR. PIKE: Again, form, compound, again assumes facts not in evidence, Argumentative and harassing, and moreover, we have already been down this road before in separate related questions that have already been asked and answered. A. I would like to respond to each one of your questions; however, today my attorneys have i | | j | i | | method of paying underage minor females to bring | i i i I { | a8 advised me I cannot and they've advised me J must assert my Sixth Amendment right, my Fifth Amendment right and my Fourteenth Amendment rig! under the U.S. Constitution, therefore, that's what I'm going te do. Q Where is the calendar or schedule of your underage sex appointments? MR. PIKE: Form, speculation, A You said where is... MR. PIKE: "Again." Q Where is the calendar or schedale that Sarah Ketien kept for you for your appointments for sex with underage females? MR. PIKE: Same objection. Q if there is not one, you can telf me there is not one. A I would like to answer each one of your questions today. However, I have been advised by counsel that ¥ must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution or risk losing their representation. Therefore, I'm going to have to assert-those constitutional rights, though [ would fike to answer that question. Q Are you still in possession of the 89 computers that were taken from your house prior te the execution of the search warrant? A Again, Am I stilh..? Q Are you still in possession of the computers that were removed from your house ju: prior to the execution of the search warrant? A intend to respond to ali relevant questions regarding this lawsuit, However, at the present time my attorneys haye counseled me I cannot respond to any questions that may be relevant to this lawsuit, no matter how much I might want to. [| must accept this advice or risk losing my Sixth Amendment right to representation. Therefore, I must assert my rights under the Fifth, Sixth and Fourteenth Amendments of the U.S. Constitution. Q Who is it that removed those computers from your house prior to the execution of the search warrant? MR. PIKB: Objection, predicate. A E intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions that may be relevant to this lawsuit, no matter 23 (Pages 86 to 89) U.S. Legal Support (561) 835-0220

90} 1 how much I would like to, and I must accept their 1 2 advice or risk losing their representation. 2 3 Accordingly, therefore, | would have to assert 3 4 those rights, Mr. Edwards, 4 5 Q itis my understanding, through 5 6 6 7 7 8 Bg 3 9 information aad belief, it is my understanding that this computer system contained the complete list of names of underage minor females with whom you engaged in sexual activity; is that correct? 10 A You're 10 LY, MR. PIKE: Objection. | a 12 A ~ you're asking for my understanding? ; 12 13 Q No-- 13 14 A_ Are you asking me to tell you what your 14 15 — understanding is? 15 16 Q Did the computers that were removed from | 16 17 your home just prior to the execution of the 7 18 search warrant contain the complete list of 18 19 underage minor females with whom you engaged in 19 20 sexual activity? } 20 a1 MR. PIKE: Form. | 21 22 A Though I would like to answer that | 22 23 question, like all your other questions here 23 24 — today, unfortunately my attorneys have counseled 24 me that I'm going to have to assert my Sixth 1 Amendment, Fifth Amendment and Fourteenth 1 2 Amendment rights under the U.S. Constitution. 2 3 point-- excuse me. { would point out that your 3 4 firm wes described by the current U.S. Attorney | 4 5 asacriminal enterprise involved in money 8 6 laundering, creating and fabricating malicious 6 7 cases of'a sexual nature against people like me ; 7 8 and others, in order to fleece local investors ios 9 out of millions of dollars. 9 10 I believe the senior partner of that 10 11 firm currently sits in jail. Unfortunately j il 12 though I would like to answer afl of your 12 13 questions, today my attorneys have counseled me I 13 15 Fourteenth Amendment and Fifth Amendment of the 16 U.S. Constitution. 17 Q Isn't it true, you and Sarah Kellen and 18 Ghislaine Maxwell and Nadia Marcinkoya operated 18 1 14 — must assert my rights under the Sixth Amendment, i 14 i i 1 19 as an organized criminal enterprise designed to | 19 20 sexually exploit minor? | 20 21 MR. PIKE: Objection, argumentative, i au 22 speculation, calls for a legal conclusion | 22 23 and continues to assume facts not in 23 24 evidence. 24 | 25 A Though I would like to answer that 92 question, Mr, Edwards, like most of your other questions here today... and hopefully will get to do so at some point, my lawyers have advised me 1 must today assert my constitutional rights under the Sixth Amendment, Fifth Amendment and Fourteenth Amendment of the U.S. Constitution and I must accept their advice or risk losing effective representation. Q And as part of that organization you developed code terms such as "Work" or "Massage' as opposed to engage in sex with minors; is that true? MR, PIKE: Form, argumentative, speculation, harassing, assumes facts not in evidence. A Can you... you...? Q You developed code terms such a3 you ~~ A "You" me? Q Yes, you, would ask these girls if they would like to give you a massage or work for you, rather than asking them to do what was going to be done, which is engage in sexual activity with you; isn't that ¢rue? MR. PIKE: Same objections. A Ase you asking if] developed code words? Is that the question? Q Right. Code words. A [would like to respond to that question, but unfortunately today my attorneys told me I have to respond by taking -- invoking my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights of the U.S. Constitution, or risk losing my amendment right to effective representation. Accordingly I assert my Constitutional rights as guaranteed by those amendments. Q What did it mean within your organization when someone, some underage minor female was coming over to work for you? MR. PIKE: Form. A What did it mean? Q Right, what did it mean? What did it mean to you was going to happen when an underage minor female would either call to work or Sarah Kellen would tell you this person was coming to work for you at a specific time? MR. PIKE: Objection, vague, speculative, assumes facts not in evidence, A. would like to answer that question, as most of your other questions today. However, 24 (Pages 90 to 93) U.S. Legal Support (561) 835-0220

94 i 1 today my attorneys have counseled me that I must | 2 invoke my Sixth Amendment, Fourteenth Amendment 3 and Fifth Amendment right, or risk -- and if 4 don't, I risk losing them as my attorneys so, 5 therefore, I must assert those rights. 6 Q You're laughing as if my questions are 7 tudicrous right now but you're aware that there 8 were trash pulls from your home where there were; 9 — message pads, messages taken by various mere 10 of yours, where these terms, “Massage,” “Work” 11 were used in conjunction with underage minor 12 femates coming over to your house, weren't you? 13 MR. PIKE: Same objections, form, as 14 well, Move to strike, and also assumes 15 facts not in evidence. Lack predicates. 16 Q You're aware of the trash pull and the 17 message pads, correct? 18 MR. PIKE: Same objections. 19 Do you have any documents with you here 20 today that you speak of? aL MR. EDWARDS: No, but at this point in 22 time in the trial, they will already about. 23 in evidence. 24 A I'm aware of a trash pull? What's a 25 © “trash pull"? I'm sorry. Q Are you aware of -- I'l ask it of you this way: When Sarah Kellen would take a phone message for you, what did she write it down with? MR. PIKE: Form. A. The question makes no sense to me, sorry. Q Ifanother employee of yours were to answer the telephone, be it your housekeeper, 10 housemanager, would answer the phone, take a 11 message for you and write it down so that you 12 ~~ could read it later, what would that message be 13 written on? 14 A Most likely paper. 15 Q Okay, is that paper typically in the 16 ~~ form of a message pad that has a carbon copy 17 sheet to the back? 18 A No. 19 Q You're unfamiliar with the documents 20 that I'm talking about, that being a message pad 21 that informs you as to who called, the time they 22 called and the purpose for calling? | 23 MR. PIKE: For purposes of the question 24 you're specifically talking about a message 25 pad, nothing related to what you're defining 1 2 3 4 5 6 7 8 9 as a trash pull, just what someone takes as a message at Mr. Epstein's home and -‘A. Dol know what a message pad is? Q No. In your home, do you typically have your housekeeper, housemanager, or somebody elsd when they take a message for you, write ona specific pad that informs you as to who is calling, the time they are calling and the purpose for their catling, and there is a carbon copy sheet evidencing that message? MR, PIKE: Objection, asked and. answered. Q You know what I'm talking about? A_ Tknow what a message pad is. Q Do you use them commonly in your home or did you back prior to your arrest? A_ I would like to answer that question, but today my attorneys have advised me } have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution, so therefore, I'm going to do that or | risk losing their representation. Q Is my question to you confusing? De you know what Fm talking about? MR. PIKE: Form. A Not specifically, no. Q Okay. The information -A. Is there something you have to show me, 30 1 know what you're talking about? Q I don't have it ¢ show you today, but if the information and evidence that I have learned through this process is accurate and correct, it would seem a foregone conclusion that you and I would be on the same page, at least about this document, so -A Okay. Q -ifwe are going to get to a point you tell me “This document doesn't exist" or "E don’t know what you're talking about," okay, that's fine, but that’s something we can hash out. Here is my question: When a housekeeper/housermanager would take a message fo you from any caller, is there a specific message pad that has a carbon copy located near your telephone, for them to write down the aame of the caller, the purpose for the call and the time called? MR, PIKE; Form. Q Is that something you're familiar with? 25 (Pages 94 to 97) U.S. Legal Support (561) 835-0220

we Rinne wne 98 AE would like to respond to that question, Today my attorneys have counseled me [ must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right under the U.S. Constitution. Q You're invoking your Fifth Amendment right is not that you understand the question. You understand my question and are electing to invoke your Fifth Amendment rights; is that correct? A Yes. Q When Sarah Kellen or a housekeeper or housemanager, whoever happencd to be employed at the time, would take messages, what form would | you normaily or typically receive them in? A (Witness shrugs.) MR. PIKE: Same objections. A. I don't understand the question. Q When a caller would call the home, housemanager or housekeeper or Sarah Kellen, I don't know what you would call her, assistant, | would answer the phone, and take a message for you so that you would know who called, what would they typically write down the message on so that | you would have it? MR. PIKE: Objection. Object to the t form, Jacks predicate. You have not established anything here today relative to a housekeeper or housemanager or the like. Um... And i'm trying to understand the question. But -MR. EDWARDS: Really? MR. PIKE: -- it lacks predicate, MR, EDWARDS: This will play well. | A_ Piece of paper. | | Q Normally they would write it down on a piece of paper and give It to you? A Jdidn't say that. Q Have you ever been given a message that! is ripped out of a message pad that has a carbon copy to it? A Oh, | see, Okay. I intend ~ 1 would like to answer that question, but today my attorneys have advised me | must respond by invoking my Sixth Amendment right, my Fifth Amendment right and my Fourteenth Amendment tights under the U.S. Constitution. Though 1 would like to answer these questions, accordingly I must assert those rights or I risk losing my representation here today. | i i | | | Mie Cat annew 10 11 13 14 15 1? 18 19 20 21 22 23 24 100 Q Between the years 2002 and 2005, who was} your house manager? A (No response.) Q Ef there is more than one, tell us that. A. The question is unclear. I'm sorry. Q Okay, let me start with between 2002 and 2005, did you employ a housemanager? MR. PIKE: Form. A Where? Q Atyour Palm Beach home, A Tintend to respond to all relevant questions here today, Mr. Edwards. Hopefully we will get some, But my attorneys have advised me that today I must invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment righ under the U.S. Constitution; or risk losing them. as counsel, So today I have to assert those privileges. Q Do you keow L.M.? A. [intend to respond to all relevant questions regarding this lawsuit. However, at the present time no matter how much I would like to answer that question, I cannot, because my counsel -- the attorneys have told me that I have 101 to invoke my Sixth Amendment, Fifth Amendment ani Fourteenth Amendment or, in fact, risk losing their representation. Therefore, I'm going to have to assert my rights under those. Q LM. is a female that was born in July of 1988. A. is that @ question? Q Not yet. When is the first time that you met her? MR, PIKE: Objection, speculation. MR. EDWARDS: That assumes that he did meet her; is that what you're saying? MR. PIKE: Your question assumes «+ MR. EDWARDS: He met her? MR. PIKE: -- exactly what he just said which hasn't been established on the record yet pursuant to the appropriate Florida. Rules of Civil Procedure and the Evidence Code. Lacks predicate. A. That being said, | would like to answer that question, but today my attorneys have counseled me that I cannot, and they've advised me I must assert my Sixth Amendment right, my Fourteenth Amendment right, and my Fifth Amendment right under the U.S, Constitution, 26 (Pages 98 to 101) U.S. Legal Support (561) 835-0220

102 THE WITNESS: Can you throw me one of the suckey candies, please Thank you. MR. EDWARDS: (Handing candy.) THE WITNESS: Appreciate it. Q Isn't it true you met L.M. for the first time in July or August of 2002 just before her fourteenth birthday? MR. PIKE: Same objections. A You know, your firm has been accused by the U.S, Attorney of perpetrating one of the largest frauds in South Florida history by crafting sexually charged lawsuits against people like me and others in order to fleece unsuspecting investors here in South Florida out of millions of doflars. The firm of you and Mr. Jaffe. The U.S. Attorney described it as bogus schemes contrived by your firm. I would like to answer every one of your questions here today; however, my attorneys have counseled me that I may not, and have advised me | that I have to invoke my Sixth Amendment, Fifth | Amendment and Fourteenth Amendment rights undex the U.S. Constitution. Therefore, that's what will do, otherwise J risk fosing their representation. Q Isn't it true L.M. as a 13 or 14-year old girl was taken to your house by another underage minor female, that being Carolyn Andriano? MR. PIKE: Form. THE WITNESS: Tissue, please. MR. EDWARDS: (Handing tissue.) A [would like to answer that question like all the other questions you've asked me here today, but today my attorneys have counseled me that I have to invoke my Sixth Amendment right, Z| my Fifth Amendment right and Fourteenth Amend rights under the U.S, Constitution; therefore that's what I will do. Q Do you know who Carolyn Andriano is, right, she had a lawsuit against you previously? MR. PIKE: Form, A. Again the last name? Q Carolyn Andriano. A Could you spell it for me? Q Well, the pseudonyat that she used in her lawsuit against you alleging similar facts to those alleged in L.M. versus Jeffrey Epstein was C.M.A, versus Jeffrey Epstein, 104 A. And now the question? Q You know whe she is, correct? MR. PIKE: Form. A_ I would like to answer that question here, Mr, Edwards, but unfortunately today my attorneys have counseled me { must invoke my Fifth Amendment, Sixth Amendment and Fourteent Amendment rights under the U.S. Constitution, and if { dont, } risk losing their representation, therefore ] must assert those rights, Q When I asked you about L.M. or Carolyn Andriano, you sat there for a while thinking har about whether or not you knew them. Do you remember either L.M. or Carolyn Andriano? MR. PIKE: I move to strike counsel's statement because the statement as worded assumes facts certainly not in evidence. It is argumentative, speculates as to what is “thinking hard," and, counsel, I don't understand the question on the table, combined with your narrative. If you could repeat the question? MR. EDWARDS: Sure. Q I'm asking if during this questioning process, has it refreshed your recollection as to 105 who L.M. is or do you really have no idea who that is? MR. PIKE: Form. Asked and answered. Q Do you remember L.M.? A Are you going to ask one question? Which question would you like answered first? Q Do you remember £.M.? A_ I would like to answer that question. 1 would like to answer that question today; however my attorneys today have advised me that | must assert my Fourteenth Amendment, Fifth Amendmen! and Sixth Amendment rights under the U.S. Constitution, no matter how much I would like to answer these questions. So unfortunately, I'm going to assert those rights. Q When you first met L.M., isn't it true that she was just about to begin her ninth grade year in high schoo!? MR. PIKE: Same objections. Form. A_ I believe her testimony in front of the FBI, in a sworn deposition says something else, but I don't recall exactly what. | don't have any recollection. Q OfL.M. MR. PIKE: Form. 27 (Pages 102 to 105) U.S. Legal Support (561) 835-0220

21 14 15 16 106 A You asked the question when I met her, I think, if T met her, Q You have no recollection as to when you met her? A [don't have recollection if I ever met her. I just told you, I did read her FBI statement, so ] know what she has said and it is not what you've just represented to me. Q Your only knowledge of any interaction you may have had with L.M. is derived from an FB: statement that she gave; is that true? A believe what you just represented she said was not what she had sworn to. Q I'm not asking what she said. I'm asking do you independently remember if she was entering into ber ninth grade year of high school when you met her? Independent of anything you've read. MR. PIKE: All right, let me just move to strike the... Diatribe between Mr. Edwards and Mr. Epstein. I'm confused as to what question is on the table now, MR. EDWARDS: Okay. Q Independent of anything you've ever read — A Okay. Q = do you remember meeting L.M., just before she entered into her ninth grade year in high sekool? A [would like to answer that question, however my attorneys today have advised me that though her own statements are contradictory to what you just said, her sworn statements to the FBI contradict what you just said. | have to invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights to the U.S. Constitution, Q Just a few minutes ago when you asked when you met her, you said, "J don't know if T'vel ever met her,” so is that your testimony, that you don't know if you ever met L.M.? A My testimony is very clear. [ must assert the rights my attorneys have asked me to assert today, though her testimony under oath to the FBI is not what you represented it to be, to me, and the ladies and gentlemen of the jury who are watching this, hopefully. MR. PIKE: Form. Q We will get into that, A Okay. 108 1 Q When you first came into the room today, 2 didn't you look at me and say "TI like L.M." Isn' 3 that the statement that you made to me? ; 4 MR. PIKE: Form. Move to strike. 5 A I don't believe | said that. 6 Q What is it that you believe you did say 7 ~~ referencing L.M. when you sat down in that seat 8 prior to the cameras rolling? 9 MR, PIKE: Form, ‘Counsel, | was here 10 during that whole time and { don't recali 1 any such statement, i 12 MR. EDWARDS: You weren't in the room. j is A [don't remember. I don't know, 14 Sony. 15 Q Sois it your testimony right now that 16 you did not say to me "I like L.M."? 17 A That's ~18 MR, PIKE: Objection, 1 19 A ~ that’s correct. 20 Q Deo you like L.M.? 2. MR. PIKE: Form, predicate, and 22 relevance. 23 A. [ would like to answer all your 24 questions here as I've... tried to do my best, 25 however, my aftomeys have advised me that ] must 109 1 assert my Sixth Amendment, Fourteenth Amendment. 2 and Fifth Amendment rights under the U.S. | 3 Constitution. ; 4 Q When you first met L.M., isn't it true 5 that you knew she was an economically 6 disadvantaged girl that needed money? 7 MR. PIKE: Objection, speculation, 8 assumes facts not in evidence, and it is 9 argumentative as worded, 10 A I would like to answer all your 11. questions here today, Mr. Edwards, and Mr. j 12 Jaffe. However, on advice of counsel I have to 13 assert my Sixth Amendment, Fifth Amendment and 14 ~~ Fourteenth Amendment rights under the U.S. | 15 Constitution, or risk losing my right to | 16 effective representation. So accordingly [ must 17 assert those rights as guaranteed by the Sixth, 18 Fifth and Fourteenth amendments. 19 Q When she was a 14-year ald girl, she was | 20 taken into your bedroom and you ordered her to 21 take her clothes off; is that correct? | 22 MR. PIKE: Objection, vague, confusing. 23 As to "her," I'm not quite sure who you... Q When L.M, was a 14-year old girl, she was taken up to your bedroom and you ordered he} 28 (Pages 106 to 109) U.S. Legal Support (561) 835-0220

110) 112 1 te take her clothes off; isn't that true? 1 THE VIDEOGRAPHER: Going off the video) 2 MR. PIKE: Objection, speculation, and 2 record 1:49 p.m. 3 assumes facts not inevidence. Lacks , 3 THE WITNESS: Thank you. 4 predicate, 4 (Pause in the proceedings.) 5 A Though once again what you've just 5 THE VIDEOGRAPHER: Back on the video 6 represented to me is a total contradiction to the 6 record 2:04 p.m. 7 FBI sworn statement that I read of L.M., I must b Q Mr. Epstein, when L.M. was a 4-year old 8 unfortunately respond by asserting the rights 8 — girl, isn't it true that while you were naked on 9 demanded by my attorneys today, which is my Sixthh 9 the massage table, you ordered L.M. to take off 10 Amendment, Fifth Amendment and Fourteenth 10 ~~ her clothes and provide you a massage? il Amendment right against -- sorry, given by the 12 A. I believe I've answered that question, 12 U.S, Constitution, though her testimony is 12 didn'tI? 13. exactly -- does not purport in any way to what 13 Q I don't remember where we left off, 14 you've just said. 14 ‘that's why. 15 Q And when L.M. was 14 years old, you is MR. PIKE: Form, argumentative, 16 ordered she begin to give you a massage while she 16 speculation. It is compound and assumes 17 was naked and you were naked; isn't that true? {| 17 facts not in evidence and has been asked and 18 MR. PIKE: Same objections. 18 answered. But we did take a break, so you 19 A. Sorry, you have to repeat the question 19 can respond. 20 forme, 20 (Counsel addressing Mr. Epstein.) 24 Q When L.M. was a 14-year old girl ~ a. A. The current U.S. Attorney has described 22 A Right. Yes? 22 your law firm as a criminal enterprise involved 23 Q - you laughed and said, "right" about 23 _ in fabricating sexually charged cases against 24 what? 24 — people like me in order to fleece unsuspecting A_ | didn't hear the first part of your 25 investors out of millions of dollars. He used 411 1 question. Now I understood it. 1 words like "bogus schemes.” 2 Q When L.M, was a 14-year old girl, wasn't = 2 Unfortunately at this time in response 3 it true that you received a massage from her 3 to your questions, though 1 would like to answer 4 while she was naked and you were naked? 4 each and every one, I'm going to have to, on 5 MR. PIKE: Objection, speculation, 5 advice of counsel, assert my Sixth Amendment, 6 assumes facts not in evidence, lacks 6 Fifth Amendment and Fourteenth Amendment rights 7 predicate. 7 under the U.S. Constitution, though 1 would like 8 A. understand that your firm has been 8 to answer those questions. 9 accused by the U.S. Attorney of South Florida, 9 Q While LM, was a naked 14-year old girl 10 _ perpetrating one of the largest frauds in 10 ~~ providing you a massage, you ordered her to pincl 11 Florida's history, by crafting malicious, 11 your nipples during that massage; isn’t that 12 sexually charged allegations against people like 12 ~~ true? 13 me, J understand L.M.'s testimony is not what 13 MR. PIKE: Same objections, 14 you've just described, though she swore to the 14 argumentative, speculation, harassing, 15 PBI... under oath. Though [ would like to answer | 15 assumes facts not in evidence and lacks 16 your questions here today, my attorneys have 16 predicate. 17 advised me I may not. I must assert my Sixth, 17 A_ Lasked her to pinch her nipples? 18 Pifth and Fourteenth Amendment rights under the | 18 Q Pinch your nipples? 19 U.S. Constitution or risk losing their 19 A Ihbelieve her own sworn testimony 20 representation. | 20 contradicts that statement. However, I would 21 THE WITNESS: Restroom break. 21 like to answer all your questions here today, but 22 MR. EDWARDS: Excuse me? 22 my attorneys advised me, at least today, Mr. 23 THE WITNESS: Restroom break. 23° Edwards, { must take my constitutional privileges 24 MR. EDWARDS: Stopping again? 24 — of the Sixth Amendment, Fifth Amendment and 25 THE WITNESS: Yeah, | 25 Fourteenth Amendment, keeping in mind that your 292 (Pages 110 to 113) U.S. Legal Support (561) 835-0220

21 firm, of you, Mr. Edwards, and Mr. Jaffe's firm has been accused by the U.S. Attorney of perpetrating one of the largest frauds in Florida's history by crafting sexually charged | lawsuits against people like me, te fleece from | local people millions of dollars. Q And during this massage by L.M., you began to masturbate in front of her; isn't that true? MR. PIKE: Same objections? | A Unfortunately, though 1 would like to answer each one of your questions here today, my attorneys have counseled me today at least, 1 i have to assert my Fifth Amendment, Sixth j OOH ARWNE 14 Amendment and Fourteenth Amendment rights under 15 the U.S. Constitution, otherwise I risk losing their effective representation, and the fact that your firm has been accused of fabricating these malicious lawsuits to fleece investors out of millions of dollars, as described by the U.S. Attorney here in South Florida as a criminal enterprise involved in mail fraud, money laundering... Unfortunately I would like to answer each question, but I can’t today. it true that while you were 115 | masturbating you inserted your fingers into her 14-year old vagina? | MR. PIKE: Objection, argumentative. Speculation. It is harassing. It assumes facts not in evidence. The question continues fo lack predicate, and [ also | believe the question has been asked and answered sometime ago. A Though J would like to answer each one of your questions today, Mr. Edwards, my counsel has told me [ cannot answer any questions that may be relevant to this lawsuit. The fact that your firm has been accused of major fraud, the largest fraud in South Plorida history, by the USS. Attormey calling your firm a criminal enterprise involved in money laundering ~ I believe it is racketeering, but 1 could be wrong... Monetary transactions via fraud, mail fraud, conspiracy -- sorry -- | would like to answer your questions but today on advice of counsel, I am going to have to assert my rights. i Q Isn't it true also that while L.M. wasa | 14-year old female, you masturbated to the poin of ejaculating while inserting your fingers into L.M.'s vagina? 16 17 18 19 20 al 22 23 24 23 116 MR. PIKE: Same objections incorporated? A’ Again, the question? Q Isn't it erue that during this sexual massage, while you were — that you masturbated to the point of ejaculating while you were inserting your fingers into L.M.'s vagina? MR, PIKE: Objection, argumentative, speculation. It is compound. It is vague. Et assumes facts not in evidence and lacks predicate, A Though I would like to answer that question with specificity and detail today, no matter how much I would like to, my attorneys have advised me I cannot. They advised me I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution or potentially fose effective representation, so therefore, I will assert those rights. Q Isn't it true that the ritual that I'm describing occurred with L.M., approximately 10 times when she was between the ages of 13 and 16: MR. PIKE: Same objections, with the additional objection of vague and confusing, A Since your firm has been involved -according to the U.S. Attorney in crafting these fraudulent lawsuits in order to fleece local investors, and the fact that I believe in L.M.'s sworn statements, that's what you've just alleged at least is totally contradicted by your client's own sworn statements, though I would like to answer these questions today, my attorneys have advised me I may not and advised me I must assert my Fifth, Sixth and Fourteenth Amendment rights under the U.S. Constitution or potentially risk. losing effective representation, Q In addition to the sexual abuse directed against L.M. that I've just described, isn't it true that you also paid her money to bring you more than 50 other underage minor females for yor to similarly abuse? MR. PIKE: Same objections. A Though { believe in her own sworn testimony to the U.S. government that she contradicts those assertions, and I'm sure maybe you'll have some explanation at trial, but the ladies and gentlemen of the jury should know about your firm being accused by the U.S. Attorney of perpetrating one of the largest 30 (Pages 114 to 117) U.S. Legal Support (561) 835-0220

wt noewne 16 di 12 13 14 1s 16 17 18 19 20 21 22 23 24 25 18 19 20 21 22 23 24 25 118 | | frauds in US. history by crafting malicious | lawsuits of a sexual nature in order to fleece } investors out of millions of dollars, local t investors; and though I would like to answer your {| questions in detail today, Mr. Edwards, and Mr. | Jaffe, my counsel says I may not and have asked | me to assert those rights, which | must : unfortunately. | Q You keep bringing up this fraud of the | former faw firm known as Rothstein, Rosenfeld; Adler in response to my questions, so 1 would like you fo tell the jury at this time which | allegation are you now saying is fraudulent or | untrue, that's been made by L.M.? | MR. PIKE: Form, confusing, compound, | and irrelevant, | MR. EDWARDS: Only made irrelevant by his answers. MR. PIKE: Same objections. Q Do you understand the question? A No. Q You made reference to — in response to my questions about what you did sexually to L.M. -A Yes, sir? Q —you have responded with these fraud altegations against the firm of Rothstein, Rosenfeld, Adler. I want you to tell the jury which allegations that L.M. is making against you are you disputing at this time or calling a fraud or calling untrue? MR. PIKE: Confusing, compound and -- if the court reporter would read back Mr. | Epstein’s response, I think you will see the way you just phrased the question mischaracterizes bis testimony. Because -weil, I'll keep it there unless you want me to go further. You want me to go further? | MR. EDWARDS: No, | want him to go further. | MR. PIKE: Mischaracterizes the | witness's testimony. A L.M.'s own statements contradict every one of your allegations that you've made to me today, as a hypothetical. In her own words. And you -- and the potential reasons this concems me is the fact that the law firm that represented L.M. and two others have been accused by the U.S, Attorney of fraudulently producing cases against me and others, to fleece investors in what he’s i | | 120 described as one of the largest frauds in South Florida's history. So, it concems me. It is a factor in the way I'm thinking about answering. Sorry, Q Each time that you digitally penetrated LM. or otherwise foudled her sexually, you paid her $200; is that correct? MR. PIKE: Objection, argumentative, speculative, harassing. It assumes facts not in evidence, and with regard to this line of questioning, the Court has already ruled that the demeanor in which you're presenting this question is improper, and harassing, so if you would -MR. EDWARDS: I'm very comfortable with| the demeanor right now, Mr. Pike. These are Just the facts of the lawsuit. The facts are outrageous and f understand that, but they have to be asked. MR. PIKE: Maybe the demeanor and tone of your question is Jaced in a manner that itis proper for the video, bat the content of the question is the same exact harassing question that was deemed by the Judge to be atgumentative. I'm not saying that he’s not 121 going to answer your question. MR, EDWARDS: Okay. MR. PIKE: Or that you don't know what his answer will be, but what I'm saying is: could you rephrase the question? Q Answer that question. I'll work on rephrasing it for you at some point, A Sony, I forgot what the question is by now. Q Isn't it true that each time that you interacted with L.M. sexually, meaning digitally penetrated her or fondied her in some other way] that you paid her $200 each time? MR. PIKE: Form. THE WITNESS: Sorry? MR. PIKE: Form. Go ahead. A_ I would like to answer each one of your questions here today. However, my attorneys have counseled me that today | have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S, Constitution and I'm cognizant of the fact that your fiem has crafted these malicious lawsuits, it has been reported that the lawsuits are of a sexual nature, in order to fleece investors, so though I 31 (Pages 118 to 121) U.S. Legal Support (561) 835-0220

would like to answer those questions, Mr, | Edwards, and Mr. Jaffe, today 1 must keep my [ counsel's advice, i Q Isn't it true that for each underage | minor that LM. brought to you for the purposes | of you engaging in sexual activity, you paid her | $200? | MR. PIKE: Objection, speculation, Compound question, and it assumes facts not in evidence. Therefore lacks predicate. A Though I would like to answer that question, as most of your other questions here today, Mr. Edwards, I intend to respond, hopefully at some point to all of your questions, but today my attorneys have advised me I must invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right under the U.S. Constitution. Q Over the course of relatively a roughly three years, isn't it true that you touched or fondled L.M. in a sexual manner on more than SO occasions? MR. PIKE: Objection, argumentative. Calls for speculation, It is overbroad, confusing and vague, and it assumes facts I not in evidence. A. Could you repeat the question for me? T'm sorry, Mr, Edwards, Q Yes. The three-year period between 2002 and 2005 when you were engaging in sexual conduct with L.M., isn't it true that that conduct took place on more than 50 occasions? | MR. PIKE: Same objections. A {believe if you read your own client's FBI statements, what her statement -- it changed ' dramatically after she decided to file a different lawsuit, at the request of you and your | firm, with one of your firms -- there have been. | many firms it seems, was accused of major fraud. | Since the testimony has changed dramatically, I i would like to answer those questions, but today [ my attorneys have advised me J must assert my | Sixth Amendment right, my Fifth Amendment right and my Fourteenth Amendment right. i | Q ** Your answers are not going to incriminate you if the answer is "no," it is only if the answer is "yes" that it will incriminate you, so aren't you telling the jury every single thing I've asked you is not part of a fraud, just happens to be true, isn’t it? 124 MR. PIKE: Objection, argumentative, irrelevant and move to strike. I'm simply going to instruct the witness not to answer that question because... I don't understand it. I don't know what to say about that question, A (Gesturing.) Q Allof the things that I've told you or 9 that I've asked you about, you touching her whi ON How 10 she was underage, you paying her for sexual 11 conduct, those are all things that really 12 happened, there is nothing about that, that 13 anybody has fabricated or made up, is there? 14 MR. PIKE: Objection, argumentative, is speculative, it assumes facts not in 16 evidence, it certainly mischaracterizes the 17 witness's testimony all day, since I have 18 been here, and I have been here the whole 19 time. It assumes facts not in evidence. It 20 is also overbroad and substantially compound 21 because you're attempting to incorporate all 22 of your questions today into one question. 23 MR. EDWARDS: | think you know, Mr. 24 Pike, your objection should be limited to 25 the form. Ifyou object to the form, it is 1 fine. 2 MR. PIKE: I'm sorry, that's ~ 3 MR. EDWARDS: You -4 MR. PIKE: You've asked me several times 5 today fo tell you why. I thought I was 6 helping. I'm sorry. I certainly will keep 7 objecting to 8 MR. EDWARDS: Appreciate it. 9 MR. PIKE: - the form. 10 MR. EDWARDS: Thank you. 1 Q And your answer is? 12 A_ Repeat the question. 13 Q Every single allegation that L.M. has 14 ~~ made and £ have now questioned you about in term} 15 of your sexual involvement with L.M., they are 16 al true; isn't that correct? There is nothing 17 fabricated about any of these allegations, 18 correct? 19 MR. PIKE: Objection, argumentative, 20 speculative, compound, It is vague, 2h overbroad -22 MR. EDWARDS: You're objecting to form? 7 MR. PIKE; Yes, assumes facts not in 24 evidence and lacks predicate. That is 25 form. 32 (Pages 122 to 125) U.S. Legal Support (561) 835-0220

126| A And I would like to answer that question } specifically today, however, on advice of counsel they've suggested I take the Sixth amendment ~ i assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution, keeping well aware of your firm's responsibility in the largest fraud in Florida's history by crafting sexually charged lawsuits against people like me and others. 1 believe in addition, since her allegations, as you've phrased them, have changed dramatically since her sworn statement, until in fact, after she joined this firm charged with this major fraud and most of her statements have changed, I believe, so... } Q You remember when L.M. became pick when she was 16 years old, don't you? MR. PIKE: Form, relevance, move to | strike? | A_ I would like to answer each one of your questions here today, Mr. Edwards; each and every one of your questions. However, today my counsel | i has told me I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights under the U.S. Constitution. Q Isn't it true that when L.M. was 14 years old, 15 years old and 16 years old, you i touched her genitals? A Separate from the fact that in her own testimony, her own sworn testimony under oath } before she decided to file a tawsuit for money, there was never any discussion about anything like that. T would like to answer that question, j but my attorneys have advised me, at Jeast today, that I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights unde; the U.S. Constitution. Q Isn't it true when she became pregnant at age 16, you no longer interacted with her sexually but still demanded that she bring you other underage minor females for you to sexually exploit? MR. PIKE: Objection, speculation. Compound. Harassing, and assumes facts not in evidence. A I believe her testimony changed dramatically from her sworn statements to the FBI ~ Q That's not a responsive —MR. PIKE: Excuse me — ; 12 | 25 128 1 MR. EDWARDS: It is not a responsive 2 answer so I won't allow -3 MR. PIKE: That -4 MR. EDWARDS: We'll move to strike it. 5 Let's have an answer to the question. 6 MR. PIKE: The witness is trying. If 7 there is a legal basis for your moving to 8 strike, it would be taken up with the Court 9 and you can move to strike, 10 You can continue, iL MR. EDWARDS: Strike it, it is nonresponsive? 13 A Your allegations that you keep throwing. 14 — at me, relate to the fact that L.M. testimony, 15 after giving a sworn statement to the FBI, 16 changed dramatically after she decided to file a 17 lawsuit for money, joining your firm that's been 18 accused by the U.S, Attorney of one of the 19 largest frauds in Florida's history. 1 would 20 like to answer those questions; however, on 21 advice of counsel today I must assert my Fifth 22 Amendment, Sixth Amendment and Fourteenth 23 Amendment rights under the U.S. Constitution. 24 Q When L.M, was a pregnant 16 year-ol she brought you at least ten underage 1 females during her pregnancy; isn't that true?! 2 MR. PIKE: Objection, argumentative, 3 speculation. It is vague and assumes facts 4 not in evidence and lacks predicate: 5 A 1-~1-- unfortunately would like to & — answer that question as well as every other 7 question you've asked me here today, but my 8 attommeys have advised my I must assert my Fifth’ 9 Amendment, Sixth Amendment and Fourteenth 10 Amendment rights under the U.S. Constitution. 12 @ After L.M. had her son at 16 years old, 12 and you were being criminally investigated fo 13 some of the conduct that we've discussed here 14 today; isn't it true that you personally hired 15 and retained and paid for an attorney to 16 represent L.M.? 17 MR. PIKE: Objection, speculation -18 MR. EDWARDS: Object to the form, Mr. 19 Pike. 20 MR. PIKE: 1 will not. Iam allowed to 21. assert the basis for my objections, I am not 22 limited to just saying "form." I'm able to 23 assert the basis as to why, so I don't waive 24 that basis. 25 MR. EDWARDS: it is just more of this 33 (Pages 126 to 129) U.S. Legal Support (561) 835-0220

J: 2 3 4 S 6 7 8 g 14 130] obstructionist MR. PIKE: It’s not obstructionist, it is objecting to form. What is obstructionist is what we are doing now. } will be finished within four seconds. So I am going to object to form, it's argumentative, speculative and it assumes facts not in evidence and it lacks | predicate. That's it, A I'm sorry. (Witness shrugs.) Again? Q. The response to the question, A I don't know the question. Q You don't remember the question? Did you hire L.M. an attorney at some point in time? Do you remember that? MR. PIKE: Same objection. A Not to the best of my recollection. Q Do you know James Eisenberg? A .. Dol know James Eisenberg? I don't believe I've ever met James Bisenberg. Q Isit your testimony today then that you never paid for an attorney to represent L.M.? A (Witness shakes head,)... On advice of my counsel, f would like to answer that question, but on advice of counsel I'm going to have to 131) assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights against — exouse me, Sixth Amendment rights of the U.S. Constitution, Q And that attorney that was paid for by you, informed L.M. that if she were to tell the FBI exactly what happened at your house, that het son could be taken from her. You're aware of that, correct? MR, PIKE: Same objections. A Lrecognize, | believe she made one of 1 the statements at her deposition after she \ decided to sue me for a bunch of money and your | firm has represented a number of... cases of a i sexually charged nature that tumed out to be | I | | fraudulent in order to fleece loca! investors. The U.S. Attorney described your firm and these cases as a bogus scheme, and I'm aware of that, and would like fo answer your question in more detail today, Mr. Edwards, however my attorneys advised me that at least today, I must assert my tights under the Sixth Amendment, Fourteenth Amendment and Fifth Amendment. MR. PIKE: Itis the food. MR. JAFFE: I didn't want him in the room in mid answer, OS O~A HAW 132 THE WITNESS: Ready? Thank you. THE VIDEOGRAPHER: Going off the video record 2:29 p.m, (Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video record 2:50 p.m. Q Isn't it true, Mr. Epstein, that you gave L.M. money to coerce her into interacting with you sexually? A Mr. Edwards, I would like to answer each and every one of your questions here today, but unfortunately, like I've done with mostly all of your other questions, I'm going to have to assert my rights, Sixth Amendment, Fourteenth Amendmen} and Fifth Amendment on advice of counsel. Although I would like to answer, if | don't follow my counsel's advice, I risk losing representation. Q While committing these sexual acts against L.ML when she was just a minor, you tne it would psychologically damage her; isn't that true? MR. PIKE: Form, tacks predicate, speculation. A. Lintend to respond at some point to - 1 would like to respond to each and every one of your questions, but today on advice of. my counsel they've required me to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment right under the U.S. Constitution, though I would like to answer each of these questions. Q In fact, you deliberately and intentionally caused severe emotionally distress to underage minor females, including L.M.; iso't that true? MR, PIKE: Objection, argumentative, speculation, it is compound. And it assumes. facts not in evidence. MR. EDWARDS: Okay. A I would like to answer that question, as I would like to answer all of your other questions today regarding L.M, However, my attorneys today have advised me that | must assert my Sixth Amendment right to effective representation and my Fifth Amendment right and my Fourteenth Amendment right. Though I would like to answer that with specificity, ] must follow my attorney's advice. Q Will you admit for the jury that you were investigated federally for your illegal 34 (Pages 130 to 133) U.S. Legal Support (561) 835-0220

C©OIHH BW E 10 iL 12 13 14 15 16 17 18 19 20 ae 22 23 134 activities with underage minors? MR. PIKE: Same objections. A. | would like to answer that question, as well as all the other questions you've asked me here today, especially since your firm has been accused by the federal, I guess, the federal government,... being considered a criminal -- you firm has been considered and investigated as being a criminal enterprise using sexually fabricated, sexual cases... fabricated cases, to fleece investors out of millions of dollars, but I would like to answer your questions; however my attorneys have demanded that I assert my rights under the Sixth Amendment, Fifth Amendment and Fourteenth Amendment. Q In fact, as a result of that investigation, you, as well as the United States Attorney's Office entered into what has now been known and referred to as the nonprosecution agreement; isn't that correct? MR. PIKE: Same objection. The document speaks for itself? A You have to repeat the question. Q Asaresult of the criminal investigation into your activities with minor 135 females, you reached a resolution with the United States Attorney's Office, in what has now been: described as the nonprosecution agreement; is that correct? MR. PIKE: I'm going to object, Vague, confusing, misrepresents the agreement and the document is the best evidence. Will you mark it? MR, EDWARDS: I can mark it. We will copy it at the end and mark it as Exhibit 2. (Document, Nonprosecution Agreement, was deemed marked as Exhibit number 2 for identification, as of this date.) A Yes. Q In that agreement, there are listed co-conspirators of Jeffrey Epstein, those being Sarah Kellen, Adriana Ross, Leslie Graff (phonetic) and Nadia Marcinkova, Can you explaii to the jury what those individuals did for you related to the crimes that were investigated by the federal government? A Co-conspirators? Q Yes, it says "criminal charges against any co-conspirators of Epstein including but not limited to Sarah Ketfen, Adriana Ross, Leslie i | i " wOI hh wRE 24 25 13 25 136 Graff or Nadia Marcinkova." Can you explain the jury what each of those four individuals did for you or conspired with you to do? MR. PIKE: Object to the form of the question? A. I would like to answer that question, however, today my attomeys advise me that | must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution, Q Isn't it fair to say that you, as well as the co-conspirators, operated as an organized criminal enterprise designed to sexually exploit underage minors? MR. PIKE: Object to argumentative, speculation, It is vague and it assumes facts not in evidence. A Are you suggesting it was a criminal enterprise? Is that the words? Q Yes. A Though J would like to answer that question today, J think the only criminal enterprise that | have been reading about today was your firm, that’s been accused of being a criminal enterprise involved in defrauding. people, using mail fraud, wire fraud, money laundering, the operation of the enterprise -this is by the U.S. Attorney (indicating), but though I would like to answer your questions with specificity today, on advice of counsel, though I would like to answer it, they demanded I assert my Sixth Amendment, Fourteenth Amendment and. Fifth Amendment right or I risk losing their representation. Q Did you care about any of the underage minor females at the time when you were engagin; in sexual conduct with them? MR. PIKE: Objection, argumentative. Harassing, already been ruled upon by the Court relative to this exact question. MR. EDWARDS: | feel comfortable with the question. It goes to punitive damages. The issue related to the Court was a repetitive question on that topic or around that general subject matter. I'm just asking for Mr. Epstein to telf the jury how he felt about these girls, whether he cared about them, when he was engaging in illegal sexual conduct with them, MR. PIKE: Counsel, I'm going to 35 (Pages 134 to 137) U.S. Legal Support (561) 835-0220

COTA HWE Lo iL 12 13 4 15 16 17 18 19 20 au 22 23 138} instruct him not to answer the question. i You can certify it to the Court, if you | like. You know what the answer is going to | be; however you're attempting to lace this video. You know the Court has already ordered that these types of questions are not permitted because they are argumentative and harassing. In fact, other questions bordered but this question is on exact point with the Court's order, If you want to withdraw the question, that's fine. MR, EDWARDS: I don't want to withdraw { the question, | MR, PIKE: Then I instruct him not to answer, MR. EDWARDS: Mark that somehow, that | page, so we can find it in the record, relative to the hearing that will be had on | that question and others similar. | Q At the time when you were engaging in sexual conduct with underage females, you knew, that exposing them to this, was not beneficial or | good for these girls; isn't that true? : MR, PIKE: Objection, argumentative, | speculation, assumes facts not in evidence, | 139 Lacks predicate. A. Though I would like to answer that question, like most of your other questions here 1 today, on advice of counsel J must assert my ! Fourteenth Amendment, Fifth Amendment and Sixi Amendment rights. Though I would like to answer, if T do so, { risk losing my effective i representation of counsel. Q Isn'ti¢ trae, Mr. Epstein, that the i only thing that you cared about was accessing as many underage females as possible, for the purposes of sex? MR. PIKE: Argumentative, speculation, harassing, A What's the question? MR. PIKE: And assumes facts not in evidence, Q Isn't it true that the only thing that you cared abent when you were interacting with these underage females in a sexual manner, was ejaculating or your own personal gratification? MR. PIKE: Form, same exact objections. t A Though I would like to answer that question, and to the ladies and gentlemen of the jury, 1 would very much like to answer that 1 2 3 4 5 6 7 8 © li 12 13 14 as 16 17 18 19 20 21 22 23 140 question; however, today my attorneys have advised me I must take -- assert my rights under the Fourteenth, Sixth and Fifth Amendments of th U.S. Constitution, or else | risk losing their representation. MR. PIKE: And Mr, Edwards, just so we don't have to come back on the question that Linstructed him not to answer, if you would go ahead and repeat that question, I will be more than happy to let him respond. MR. EDWARDS: I don't remember the question we will take it up with the Court and we'll get a ruling on it. MR. PIKE: It was whether or not he cared about these -- I believe you quoted it as underage minors, but I would fike the court reporter to read back the question just to conserve judicial resources and not go back. So if she can reread the question that would be good. MR. EDWARDS: If you can find the question. THE COURT REPORTER: Certainly. MR. EDWARDS: J think I know it. minor females that you were engaging in sex with| at the time when you were engaging in these sexual activities? MR. PIKE: Same objections, as before. A Though I would like to answer that question as well as most of your other questions, if not all of your other questions here today, on advice of counsel I will have to assert my Fourteenth Amendment right, my Sixth Amendment] right and my Fifth Amendment right, because no matter how much I actually want to answer that question, if I do so E risk losing my counsel's representation. Q At the time you were engaging in sexual activity with these underage minors, including L.M., you kuew that this conduct was illegal, didn't you? MR. PIKE; Same objections. Form. A. I would like to answer that question, as well as most of your other questions here today; however, today my counsel has instructed me to assert my Fourteenth Amendment, Sixth Amendme: and Fifth Amendment right, and if I do not, and if, in fact, I answer that question -- if [ can answer that question, I potentially risk losing 36 (Pages 138 to 141) U.S. Legal Support (561) 835-0220

1 2 3 4 5 6 7 a 9 10 iL 12 13 14 15 16 iz 18 19 20 24 22 23 24 1 2 3. 4 5 € ¥ 8 9 10 12 12 13 14 1s 16 17 18 19 20 2h 22 23 24 25 142 i my effective counsel's representation. Q In fact, you told many of these underage minor females not to tell anybody what happened with you in the house, or else they would bein = | trouble; isn't that tree? MR. PIKE: Form. A I would like to answer that question, as well as the other questions; however, my counsel has advised me that today 1 must assert my Fourteenth Amendment, Sixth Amendment and Fifth Amendment rights under the U.S, Constitution. Q The underage minor females that have come forward with information about your sexual interactions with them have been investigated, harassed, humiliated in an effort for you to intimidate them to go away. Is that true? MR. PIKE; Objection. Argumentative, | speculative, compound. It is overbroad, and assumes facts not in evidence, A Can you repeat the question? Q Sure. Any underage minor female that you engaged in sexual activity with, that has now ; pursued a lawsuit against you, isn't it true that i you've spent a lot of money and a lot of j vestigating them in an effort to { 143 intimidate them and hopefully make them go away? MR. PIKE: Same objections. A [believe your client's testimony changed dramatically when she joined up with you and your law firm, accused of fraud, when she decided to change her testimony, at least from what the statements said, both to the police and to the FBI, and decided to seek money. However, anything above that or beyond that, I'm going to have to, in fact, assert my Fifth Amendment, t Sixth Amendment and Fourteenth Amendment rights | as directed by my competent counsel, Unfortunately, they have told me if i don't, 1 risk losing their representation. | Q All right, I'll give you a chance here I since you keep bringing up her statement tothe — | FBI as opposed to her sworn testimony for 13 | hours under oath in this case. Are you saying that the sworn testimony to the FBI was, in fact, | the truth? | & What I'm saying is, it seems her i testimony has changed dramatically after she | joined your firm, that’s all. Q Okay. Irrespective of her testimony, you've read her testimony and you read her wer onewnr 24 testimony -- to the FBI. You watched her deposition when it was being taken. Which -A You're making assumptions, I'm sorry. MR. PIKE: Let him finish the question. THE WITNESS: Sorry. A My fault, MR. PIKE: Then I'l! object and you'll respond. Q Which are you saying is the truthful testimony, her statement fo the FBI or the videotaped deposition that you watched? MR. PIKE: Object to the form. A What I've said, and J think Til repeat myself is until she joined your firm and started to seek money, her testimony was different. That's my understanding. Q Are you denying any sexual involvement with 1.M, at this time? MR, PIKE: Form. A. L would like to answer that question. T would like to answer it as with most of your questions here today; however, my attorneys have advised me that I must take that -- assert my rights under the Sixth Amendment, Fourteenth Amendment and Fifth Amendment, no matter how mut 145 IT would like to answer that question, or potentially risk losing my counsel. Q Isn't your game plan with all of these civil lawsuits that have been filed against you, | to spend as much money as you can to Investigate, and harass these young women inte hopefully dropping the lawsuits against you? MR. PIKE: Objection, Relevance. Move to strike. It is argumentative and harassing. A_ I would like to answer that question. 1 think you know the answer to that question. Q Yes. A (Witness nods.) However, today my attorneys have advised me J must assert my Sixth Amendment rights, my Fourteenth Amendment right: and my Fifth Amendment rights. Q You don't have any remorse for the sexual abuse that you committed against L.M., do you? MR. PIKE: Objection. It is argumentative, It is harassing. Itis, 1 believe, confined under the Judge's order and it assumes facts not in evidence? A. That being said, | would like to answer 37 (Pages 142 to 145) U.S. Legal Support (561) 835-0220

WMI HAU ewe 10 a 12 13 14 us 16 17 18 19 20 al 22 23 24 25 146) i | that question today, but my attorneys have advised me that [ must assert my Fourteenth Amendment rights, my Fifth Amendment rights and) my Sixth Amendment rights. | Q Infact, you recently sued L.M., didn't | you? A Yes, and you and your firm that's been accused of the largest fraud in Plorida's 1 history, described by the U.S. Attomey as a criminal enterprise invoived in money laundering, | conspiracy fo commit one crime -- excuse me, mail fraud, commit conspiracy to commit wire fraud, | Yes, I sued you, your firm and L.M. Q ** Tell the jury ~~ A Yes. | Q -- the basis for the evidence that you have to support the allegations in the complaint | against L.M. | MR. PIKE: I'm going to instruct the witness not to answer that question in this medium, as it is wholly irrelevant currently, as were it, to this particular lawsuit. MR. EDWARDS: Just so you can rethink that position, the lack of remorse goes to i i | | | er ren cone 147) punitive damages, that is an aspect of the i case that L.M. has against Mr. Epstein. i MR. PIKE: This lawsuit, the current one | Mr. Epstein is noticed for, and the lawsuit { in which Mr, Epstein has filed against the | former Rothstein, Rosenfeld, Adler, L.M. and [ Mr, Brad Edwards, is not proper for this | medium -MR. EDWARDS: | understand your | position. | MR. PIKE: -- in that regard, I'm going i to instruct him not to answer any questions { relative to that lawsuit because of that } objection, as well as, it is my i understanding that Mr, Scarola has set Mr. | Epstein's deposition, I believe, either | early next week or mid-March, on the case of { Epstein versus RRA, Rothstein, Rosenfeld and | Adler, Mr. Edwards, as well as L.M. { Therefore when that time approaches, that i would be the appropriate time for those type of questions, related to that lawsuit, MR. EDWARDS: | understand your positio: completely, Mr. Pike. MR. PIKE; Thank you. ORI nvneuwne 10 1 12 13 14 is 16 1? 18 13 20 22 22 23 25 148 Q ** But as it relates to, obviously L.M. sued you making the allegations that you sexually molested her from when she was 13 years old to when she was 16 years old and now you've sued he| in something that is seemingly related to that case, and 1 just want to understand what your factual basis is, or what evidence you're using to support your lawsuit against L.M., so that the jury can he valuate whether that is evidence of lack of remorse that would go to punitive damages| claims that L.M. has against you. MR. PIKE: | would instruct him not to answer that question, for the same reasons stated. MR. EDWARDS: Let's mark that. Q Is it your feeling that because you are wealthy and these children are poor, that you are entitled to sexually abuse them? MR. PIKE: Argumentative. Q In speaking about these children, and including L.M. MR. PIKE: Argumentative, speculation, compound, it's vague, and it assumes facts not in evidence, A In keeping with your firm's propensity 149 for filing fellactous (sic), manufactured, sexually charged cases, based on nothing but thin air, accused by the U.S. Attorney of the largest fraud in South Florida's history, by manufacturing sexual cases, F would like to answer each and every one of your questions, including why I sued you, but today I'm not going to be able to, [have to simply listen to my counsel and assert my Sixth Amendment, Fourteent! Amendment and Fifth Amendment right. Q This answer that you keep reciting, about the Rothstein, Rosenfeld, Adler firm -A_ You do know who they are, right? Q -- you are aware, obviously, that all of the lawsuits that were filed against you, including L.M.'s, were filed at least a year before, or approximately a year before Rothstein, Rosenfeld, Adler had any of these cases; you're aware of that, right? MR. PIKE: Form. A_ Edo not know when Rothstein Adler got involved in these cases. I do know that the moment that they did surface, and, in fact, 1 understand you shared information with all the other attorneys that you so -- that the jury 38 (Pages 146 to 149) U.S. Legal Support (561) 835-0220

150] as should understand that the information gathered -- according to the U.S, Attorney, by illegal means, has been shared with all the other attorneys that you keep representing have filed cases against me; yes, I'm aware of that. Q I don't understand that answer. Stever, do you -MR, PIKE: Do you have a question? MR. EDWARDS: | want to understand whal his answer was. As in all depositions, if you don't understand the answer, clarify the answer. MR, PIKE: No, you have to ask a question. MR. EDWARDS: I did. And he's MR. PIKE; The witness has answered the question. Do you have another question to clarify his answer? MR. EDWARDS: Yes. Q Please clarify your answer. i MR. PIKE: I will instruct him not to answer. It's vague and confusing, it’s narrative. MR, EDWARDS: Me saying " 151 answer" is narrative? | MR. PIKE: What do you mean by "clarify | your answer? MR. EDWARDS: i didn’t hear whathe = | said, Say it again so I can hear it. MR. PIKE: Would you please read back what Mr, Epstein just testified to, madam | court reporter. {The record was read.) MR. BDWARDS: Okay. MR. PIKE: It was an answer, a i question -- | MR. EDWARDS: I understand -- 1 mean 7 don't understand the answer, but now I know the answer. MR. PIKE: Okay. Q At this point in time, please tell the jury what is your defense of the claims being asserted against you in this lawsuit by L.M.2 MR. PIKE: I'm going to object. Calls for a legal conclusion. A What are the claims? So since you're representing L.M., can you tell me what the claims are? Q Yes, we've gone through it. She went to| responding to it. | i jatify your | i i 152 your house when she was 15, 14, 15, 16 years. old — A Is that a claim? Q -she was in your bedroom. You instructed her to get naked. You inserted your fingers into her vagina. You used a vibrator on her. You coerced her into recruiting other underage minor females, roughly 50 or so more, ‘These are all claims that have amounted to various counts, coercion, prostitution, intentional infliction of emotional distress, battery, committing various crimes against her. What are your defenses to that? Normal defenses are “E didn't do it," "E did it, but it didn't hurt her,” we are trying to understand so we kno" how to previde this case to the jury, what are your defenses to these allegations? MR. PIKE: I'm going to object to this tine of questioning. It is compound; as worded it could call for disclosure of attorney/client information as well as work product. I believe in this particular case there is a document filed, answer in affirmative defenses, and the affirmative defenses are set forth there and the document there speaks for itself. MR. EDWARDS: Okay. Q Respond. A The document speaks for itself. Q ** So you agree with the affirmative defenses that were filed in your case? If you were te testify, we could expect that fo be your testimony? MR. PIKE: That's not what the witness testified. The witness testified that the document speaks for itself, and again, I'm going to object to attorney/client, work product and instruct the witness not to answer. Q I'm not asking what your legal defense is. I'm asking: What is your response to the claims? MR. PIKE: Same objection. Q What is your personal response? A I would like to respond to that question. | would like to respond today te that question; however, today my attorneys have told me that ] cannot respond. They've asked me to assert my Fourteenth Amendment, Sixth Amendm and Fifth Amendment rights of the U.S. 39 (Pages 150 to 153) U.S. Legal Support (561) 835-0220

1 2 3 4 5 6 + 8 3 15 16 a 154] Constitution, though I would really like to tespond. They are telling me if] did so, { will lose risking their representation. Q I know you've invoked your Fifth Amendment rights related to many of these questions, but isn't it true you recently contacted George Rash at The New York Daily News and spoke to him about L.M.'s case as well as several of the other girls, who have claims against you? A Who? Q George Rush, New York Daily News. A Can you repeat the question? Q Dida’t you recently, within the last year, contact George Rush of The New York Daily News and discuss these cases that have been filed against you and the allegations made by these various females? MR. PIKE: Form. A. I would like to answer that question, but unfortunately today my attorneys have advised me Leannot. They've advised me ] must assert my Sixteenth -- excuse me, my Fourteenth Amendment, Sixth Amendment and Fifth Amendment right, so therefore, I wilt do so. 155 Q Why is it that you will talk te George Rush about this but you will mot talk to the jary about this? MR. PIKE: Form. Argumentative, speculation. Misstates the witness's testimony. It assumes facts -~ the question assumes facts not in evidence and now lacks predicate, A. So who is George Rush again? Q George Rush, reporter with The New York Daily News. Did you not talk to him? If you didn't talk to him, tell me that, That's fine. MR. PIKE: Same objections. A I would like to tell you answers to each one of your questions, however today my attorneys have demanded that J respond by asserting my Fourteenth Amendment, Sixth Amendment, Fifth Amendment privilege, though f would like to respond, but they said if} do so, I risk losing their representation, Q Didn't you tell George Rush these underage minors were not victims at all and that; regardiess of their age, you did not personally consider them victims? MR. PIKE: Same objection. Braue wne 10 11 12 13 14 15 16 i? 18 19 20 21 oe as 24 2 156 A (Laughter.)... Did | tell... | would like to answer that question, but today on advice of my counsel, | must -- as | have done with mostly each one of your questions, I have to assert my Fifth Amendment, Sixth Amendment and. Fourteenth Amendment rights under the U.S. Constitution. Q You were $1 when L.M. was 14, and you were interacting with her sexually. Is it your testimony that despite the disparity in age you de not consider L.M. to be a victim? MR. PIKE: Argumentative, speculation, assumes facts not in evidence. Compound, lacks predicate, A Not only does it contradict your own client's statements to the FBI under sworn testimony, I would like to answer that question. Hopefully one day I can answer that question, but today my attorneys have said I cannot. They advised me I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right: Q In the last ten years, what is the youngest underage minor female that you have interacted with sexually? assumes facts not in evidence, A The answer to that question is -- I would like fo give you an answer to that today, but my attorneys have advised me | must assert my Fourteenth Amendment rights, my Sixth Amendment rights and Fifth Amendment rights. Q Do you know Michael Friedman? A_ Doesn't ring a bell, Q Former housekeeper/employee of yours, worked at the Palm Beach house? A ... Could. Don't know. Q So you would be unable to answer what Michael Friedman did for you? A Yes, Q Are you aware that our investigator spoke with Michael Friedman, former housekeepe! for you, or housemanager for you, out in California? A No. Q Any reason why when asked about the activity that occurred in your house, he would tear up and say, "I was hoping to forget everything I saw"? MR. PIKE: Objection, argumentative. Specuiative. Assumes facts not in 40 (Pages 154 to 157) U.S. Legal Support (561) 835-0220

evidence. A Again, the question? Q Is there any reason that when asked -A I don't know who he is. MR. PIKE: Also, hearsay. THE VIDEOGRAPHER: Counsel? MR. EDWARDS; Go ahead. THE VIDEOGRAPHER: Going off the video record 3:23 p.m. | {Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video record 3:30 p.m. Q This person that I asked you about, Michael Friedman, is that somebody who has contacted you within the last six months? A No. Q In taking a break and thinking about some of these questions, have you remembered whd 18 that person is, or still no real memory of him at i 19 all? | 20 A No real memory. 21. Q To the best of your knowledge, he never 22 worked fer you? 23 MR. PIKE: Form. 1 24 A Not that I can recall, but there are 25 159 lots of people who work for me, $0... Q Can you tell the jury who the various people are that work for you now? A Lbelieve } answered that question already. Q In that you invoked your Fifth Amendment, correct? A That's correct, Sixth Amendment and Fourteenth Amendment. Q Eigthteen and twenty-first? A (Witness shrugs.) MR. PIKE: Move to strike. Q ** Have you, during this litigation, and by "this litigation,” [ don’t only mean L.M.'s case, but the various other lawsuits that have been filed against you by other females alleging sexual misconduct by you against them, Who hav; you retained attorneys for, what witnesses have you retained attorneys for? MR. PIKE: Object to the form. MR, EDWARDS: Okay. MR. PIKE: I'll instruct him not to answer because I don't understand the question. Okay? MR, EDWARDS: All tight. Q During this civil discovery and litigation -A Um-hum? Q ~have you paid for, and/or retained an attorney for any other witnesses? A Any other witnesses? Q Yes, like I'll give you an example that you may, just to refresh your recollection or tell you what I'm talking about, Lowella Rabuyo; you know who that is, right? A Yes. Q She is someone to works for you now, she's a housekeeper. We took her deposition already, At least that's what her testimony was, MR. PIKE: Form. A I would like to answer that question but Thave to assert my Sixth Amendment, Fourteenth and Fifth. Q That somebody who has informed us that you paid for and obtained an attorney by the namy of Bruce Reinhart to represent her during this process, Is that -MR. PIKE: Form. A. Thave to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment, right, Q Other people that have indicated that you retained and paid for an attorney to represent them are Michael Friedman, Louella Rabuyo, Janusz Banaziak, Nadia Marcinkova, Ghislaine Maxwell, your brother, Mark Epstein, Naley Robson, Sarah Keilen, Larry Visoski, Lam Morrson, David Rogers, Igor Zinoview. Have ¥ missed anybody else that during this litigation you've paid for or retained attorneys? MR. PIKE: Form, same objection. A fm not clear. Are you suggesting I've paid for attorneys for all these people? Q Yes, A (Laughter,) ] would like to answer those questions today, but on the advice of counsel 1 have to invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right. Q Ifyou have not, tell me which of those on that list that you have not paid for or retained attorneys for? MR. PIKE: Same objection. A Same answer. Q You're invoking your Fifth Amendment, right? 41 (Pages 158 to 161) U.S. Legal Support (561) 835-0220

OAYHNERWN HE 2 10 11 12 13 14 15 16 17 18 19 20 21 22 23 1 2 3 4 5 6 a 8 9 10 11 12 13 14 15 16 1? 18 19. 20 aL 22 23 24 25 162} A And Sixth Amendment and Fourteenth | Amendment... and Fifth Amendment, Q ** Is ita company or is it you, i personally, that is paying for the attorneys' | fees related to your representation? | MR. PIKE: I'm going to object to the form. I'm going to instruct him not to answer that question based on relevance; and it is vague also. Q Who is writing the check to your attorneys for your representation in this | lawsuit? | A_ (No response.) j Q Who is paying the bill? | A believe Lam. | Q And is it you, personally, or is this | one of your corporations or companies? i MR. PIKE: Form, speculation. | A I'm not sure. i Q As you sit here today, you're not really sure whether it is coming from one of the other 21 corporations that we've discovered during discovery or it is coming from you, personally? fs that correct? A. I believe -- I would like to answer but Thave to invoke my Sixth, Fourteenth and Fifth Amendment rights, Q As it relates to any of the other i witnesses who have had attorneys retained for | them, is it also your response to invoke your Fifth Amendment rights, rather than to provide me with an answer, as to who is paying the bill for [ those attorneys? A_ I would like to answer those questions, but today my attorneys have asked me not to respond to any questions that may be relevant to this lawsuit, so [ must follow their advice and invoke the Sixth Amendment, Fifth Amendment and Fourteenth Amendment, right. | Q Have you interacted sexually with any underage minors in the last year, while on house | arrest or work release from jail? | { MR. PIKE: Objection. Argumentative and compound and lacks predicate, A_ I would like to answer that question, but on advice of counsel, at least today, they've advised me I must invoke my Sixth Amendment, Fourteenth and Fifth Amendment right. MR. PIKE: It is also overbroad. 164 Q ifme narrowing down will help you to respond, I will, Is there any need for that? A (Witness shakes head.) MR. EDWARDS: Okay. THE WITNESS: Sorry. Q Sit your intent to interact sexually with minors in the future? MR. PIKE: Same objection. A_ | would like to answer that question, but today my counsel has advised me I must invoke the rights of the Sixth Amendment, the Fourteenth Amendment and the Fifth Amendment of the U.S. Constitution. Q Are you currently treating with a psychologist related to any sex addiction that you have with minors? A_ I would like to answer that question, as well, as most of the other... questions you've asked me today; however, on advice of counsel they've asked me to invoke my Sixth Amendment, Fourteenth Amendment and Fifth Amendment right therefore, though I would iike to answer that question, as well as the other ones, I risk josing the representation if I do so, MR. PIKE: Moreover I'm going to object 165 to relevance as I have in the past since Mr. Epstein's medical history is not at issue in this case; under the legal terms, Q You would agree, wouldn't you, that you targeted these underage girls including L.M. because of their young age? MR. PIKE: Argumeniative, speculative, harassing. Assumes facts not in evidence. A_ I would like to answer that question, as well as most of the other questions you've asked me here today. My counsel has advised me that I must assert my Fourteenth Amendment, Sixth Amendment and Fifth Amendment right. Though I would like to answer those questions today... if I do so, I risk losing their representation. Q You would also agree, wouldn't you, that you targeted these underage females for sex, inelnding L.M., because they were poor? MR. PIKE: Same objections. A_ IT would like to answer that question, I would really like to answer that question, as well 4s the other questions you've asked me here today, however, on advice of my counsel they've demanded that J assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights. If} 42 (Pages 162 to 165) U.S. Legal Support (561) 835-0220

166) answer that question, I risk losing their representation. Q You would agree, wouldn't you, that you sexually molested L.M. for three years? MR. PIKE: Same objection. A [think you've asked me that question before. 1 assert the same rights as before. Q That's the Fifth, Sixth and Fourteenth amendments, just so the record is clear? A Yes. Q You would agree, wouldn't you, that you coerced L.M. into prostitution? MR. PIKE; Same objections, Af believe her own testimony reflects, at least the sworn statement to the FBI, reflects that that is not the case; and though I would like to answer that question in great detail, I cannot do so today on advice of counsel, that have asked me to assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights. If1/ 20 do $0, I risk losing their representation. 21 Q You would agree with me that you groomed 22 L.M. into becoming a prostitute? 1 23 MR, PIKE: I'm going to object. 24 Argumentative, speculative. Certainly lacks 25 L 1 L 13 14 45 16 17 18 19 167) | predicate and assumes facts not in ' evidence, A You know I would like to answer that question, but I can't today, Under advice of counsel I have to assert my Fourteenth Amendment, | Sixth Amendment and Fifth Amendment rights. IfT | answer the question, I risk losing their | counsel, Q You would agree, wouldn't you, that you | brainwashed L.M. into believing that this lifestyle of prostitution was right? MR. PIKE; Same objections. A_ I would like to answer that question, as most of your other questions here today, Mr. Edwards. On advice of counsel today, I'm going, to have to assert my Fifth Amendment, Sixth Amendment, Fourteenth Amendment rights. If | answer that question, J risk losing their representation. Q Would you agree that your interaction 20 with L.M. when she was a minor, was degrading t@ 24 her? 22 MR. PIKE: Same objections. 23 AT would fike to answer that question. I 24 woutd like to answer all of your questions here 25 1 2 3 4 5 6 7 8 | 9 10 i 42 13 14 I | 168 today; however, my counsel has advised me that I must assert my Fourteenth Amendment rights, my Sixth Amendment rights and my Fifth Amendment tights, and though | would like to answer those questions, if I do so J risk losing their representation. THE WITNESS: Can we take a ten-minute break for some air? MR. EDWARDS: We have 15 minutes and we're done. THE WITNESS: Continue then? MR. EDWARDS: Okay. Q Would you agree that you intentionally indoctrinated L.M. into this very deviant sexual lifestyle? MR. PIKE: Okay, I'm going to object. It is argumentative. It is confusing. It is speculative, vague, lacks predicate and assumes facts not in evidence. A And on top of that, | would like to answer that question, but my counsel has advised me J must assert my Fourteenth Amendment, Sixth] Amendment and Fifth Amendment rights under the U.S. Constitution. Although | would like to answer al! your questions today, I cannot do so 169 risking losing their representation. Q Would you agree that you were personally responsible for destroying her life? MR. PIKE: Same act objections. A Her lite? Q L.M.'s? A_ I would like to answer that question, and I understand how your firm has been accused of fabricated sexually charged jawsuits in order to fleece investors locally in South Fiorida. The U.S. Attorney has called your law firm a criminal enterprise based on filing fellacious (sic) sexually charged cases. Although | would like to answer that question today, Mr. Edwards, and Mr. Jaffe, my counsel has told me that I have to assert my rights under the Sixth Amendment, Fifth Amendment and Fourteenth Amendment, and if 1 don't do so, I risk losing their representation. Q We have a factual basis for asking every question and making every allegation. 1 want to provide you with a last opportunity to tell the jury which of these allegations, if any, being made by L.M., are false or fabricated in any way? 43 (Pages 166 to 169) U.S. Legal Support (561) 8350220

170} MR, PIKE: Same objections. Mr. | Edwards, you know the tenor of that question cannot be answered without waiver of Fifth, Sixth and Fourteenth. | appreciate the question and the semantics of it, but it is... It is -- can you rephrase it? MR, EDWARDS: Yes. Q Many times — you know the allegations now, we've gone through them, L.M.'s allegations| and assertion of facts as to what happened between you and her when she was 13, 14 and 15 years old and you were 50, 51, 52 years old. Several times you responded saying something | about Rothstein, Rosenfeld & Adier, something about her FBI statement, what have you; I want tp give you a chance to tell the jury, which of her allegations, if any, that you believe now are false or fabricated in any way. MR. PIKE: Same objections. A Lwould like to respond to that question, the fact that her firm, the law firm representing her has been accused by the U.S. Attorney of being a criminal enterprise, manufacturing, fabricating, out of thin air, 171 allegations in order to simply fleece locat investors out of millions of dollars, so 1 would very much like to answer that question regarding. the truthfulness of L.M.'s allegations; however today my counsel has told me that J must assert my Fifth Amendment rights, Sixth Amendment right and Fourteenth Amendment rights under the U.S. Constitution, though I would very much like to answer that questions but if I do f risk tosing their representation, Q Would you agree you owe L.M. at least $15,000,000 to compensate her for the damage which you have caused? MR. PIKE: Objection. | move to strike. Argumentative. Compound, Lacks substantial predicate. Assumes... facts... not in evidence. A As you might imagine, though your law firm has been accused of perpetrating a fraud involving millions and millions of dollars, on unsuspecting investors here in South Florida, millions of dollars by fabricating simitar ailegations, convincing people to give money to the firm that helped bring this lawsuit, I'm afraid I would like to answer those questions but 172 no matter how much | would like to answer those questions, | an going to have to decline based on my counsel's advice to invoke, at least today, my Fifth Amendment, Sixth Amendment and Fourteent! Amendment rights under the U.S. Constitution; because if] don’t, I risk losing their representation. Q Is it true that you're currently worth more than one billion dollars personally? A_ I would like to answer that question, as I would like to answer most of your other questions. { know that’s a lot of money -actually the amount of money that the U.S. attorneys accused your firm of trying to steal from the people of South Florida. It was 1.2 billion dollars, the U.S, Attorney claimed your firm perpetrated the largest fraud in South Florida's history by steating that sum of money from local investors, based on false allegations of sexually charged claims, and although I would like to answer these questions with specificity, under advice of counsel today, I'm going to have to refuse, based on my Sixth Amendment, Fourteenth Amendment and Fifth Amendment right, and though I would like to answer the question, I 173 have been told if] do so I risk losing their representation, Mr. Edwards, Q I'm simply asking: What is your personal net worth at this time? MR. PIKE: Form. A I think I've answered the question, but... Q What is your personal net worth at this time? So the answer should be a number or should be you invoking your Fifth Amendment rights. Seemed like the opposite. MR. PIKE: Asked and answered, he did. invoke his Fifth, Sixth and Fourteenth. MR. EDWARDS: His answer included something about Rothstein, Rosenfeld and Adler stealing some certain amount of money, which obviously is nonresponsive, | move to strike it and ask that he actually responds to the question with something that's responsive. He can answer the question, invoke Fifth Amendment rights, and we will get out of here. Q We will start over again. Can you please tell the jury what your current personal net worth is currently? 44 (Pages 170 to 173) U.S. Legal Support (561) 835-0220

won wne 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 OIRO UTR WN 1L 12 13 14 15 16 17 18 19 20 21 22 23 A J would like to do that today, however, | I'm sure that one of the reasons, sinoe your firm has been accused of stealing millions of dollars from focal investors based on fabricated, totally I fabricated claims, this is not by me but the U.S, Attomey, has called your firm a criminal enterprise charged with stealing hundreds of millions of dollars frankly, from local investors, based on false claims of sexually charged nature, I would like to answer that question in detail. However, my attorneys have advised me I cannot answer any questions that may | be relevant to this lawsuit and by doing so, I must invoke my Sixth Amendment, Fifth Amendment) Fourteenth Amendment right and by answering the question, [ risk losing their representation. Q Is it true you're worth 1.8 billion dollars? MR. PIKE: Same objection. A Same answer. Q Put the answer. MR, PIKE: For the record. A. I'm sure that's an interesting question ' and | would like to answer that question for you. I'm sure you would like to know as your 175] firm has been charged with stealing over a billion dotlars from local investors and your senior partner of both you and Mr. Jaffe sitting + there shaking his head, sits in jail accused of fleecing focal and foreign investors based on false sexual claims from people. And although I j would like to answer that question, like I would | answer most of your other questions, my counsel has advised me today, ladies and gentlemen of the jury, I cannot answer that question. Maybe IT can in the future. However, if I do so today, I risk losing their representation, so I must assert those rights under the Sixth, Fifth and Fourteenth amendments. Q You would agree, would you not, that it | would take a jury award of at least 45 million | dollars in punitive damages to punish you for { doing what you did to L.M.? ] MR, PIKE: Same objections. | A 1 would like to answer that question, as I would like to answer all your other and Mr. Jaffe's questions today. However, while he sits shaking his head I'm going to have to respond | to -- my counsel has advised me I cannot answer that question today, though I would like to. WOIHAHeRWNK PRE ERP H RRR ee BP OVCRYAHRANH OS 22 23 176 Though I would like to answer with specificity, however if I do so, I risk losing their representation so | must assert my rights under Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, Mr, Epstein, that as long as you have the money to do it, you will continu to engage in sex with minors? MR. PIKE: Again, extremely argumentative, speculative. I'm allowing the question to give leeway, so we don't haye to come back here again. It is harassing. A And with that, I'm sure this -- fadies and gentiemen of the jury, will... be able to see you and your partner, who your firm has been accused of massive fraud in South Florida trying to steal hundreds of millions of dollars from local investors, from creating, fabricating malicious, sexually charged claims, called by the U.S. Attorney a criminal enterprise charged with money laundering, conspiracy to commit other -federal violations, so though 1 would like to answer that question, Mr. Edwards, and Mr. Jaffe, today, { cannot. I must invoke my Sixth, Fifth and Fourteenth Amendment rights, on advice of Lv7 counsel or risk losing their representation. Q Am I correct in my understanding that you have invoked your Fifth Amendment rights because your answers would incriminate you and| lead to your prosecution? MR. PIKE: I'm going to~ MR. EDWARDS; Exactly as phrased by Mr, Luttier to L.M, I did not say anything but allow her to answer the question. MR. PIKE: Object to the form. A In fact, since you are a lawyer I’m sure you're aware the Supreme Court has said the Fifth Amendment is used more often to protect innocent people. So that's -- but today on advice of counsel I've taken that right, MR. EDWARDS: (Gesturing.) MR. PIKE: I have no questions. We will read. MR. EDWARDS: No further questions. THE VIDEOGRAPHER: Off the video recor 3:52 pm. THE COURT REPORTER: Can he read your: copy Mr. Pike? MR. PIKE: Yes. THE COURT REPORTER: Thank you all. 45 (Pages 174 to 177) U.S. Legal Support (561) 835-0220

COSIHYSWHE 10 il 12 13 15 16 i? 18 19 20 a1 22 23 24 25 178] MR, PIKE: On the record, I don't want a word index. THE COURT REPORTER: Okay. (Discussion off the record.) MR. PIKE: { would like this tomorrow, please. Let's go regular but definitely before that -- before Tuesday, if possible, THE COURT REPORTER: Sute, that will 50 percent expedite? MR, PIKE: That's fine, THE COURT REPORTER: My pleasure. (Time noted: 4:00 o'clock p.m.) 179 THE STATE OF FLORIDA) COUNTY OF PALM BEACH) 1, TERRI BECKER, a Registered Professional Reporter and Notary Public for the State of Florida at Large, do hereby certify that Treported the videotaped deposition of JEFFREY EPSTEIN, the DEFENDANT, called by the PLAINTIFF in the above-entitled action; that the witness | was duly sworn by me; that the foregoing pages, | numbered from 1 to 183, inclusive, constitute a true record of the deposition by said witness, f further certify that } am not attorney or counsel of any of the parties, nor a relative or employee of aty attorney or counsel connected with the action, nor financially interested in the action. WITNESS MY HAND and official seat in the City of West Palm Beach, County of Palm Beach, State of Florida, this 22nd day of February 2010. | i ‘TERRI BECKER, Registered | Professional Reporter and Notary Public, State of Florida at Large. My Commission expires March 13, 2011. OINF awe 10 ail 12 13 14 15 16 LT 1g 19 20 24 22 23 24 25 THE STATE OF FLORIDA) COUNTY OF PALM BEACH) The foregoing certificate was acknowledged before me this dayof_____— C2009, by TERRI BECKER, who is personally known to me. Notary Public, State of Florida. My commission No. Expires March 13, 2011. 181 ], JEFFREY EPSTEIN, do hereby certify that I have read the foregoing transcript of my deposition given on February 17, 2010; that together with the correction page attached hereto noting changes in form or substance, if any, it is true and correct. JEFFREY EPSTEIN T do hereby certify that the deposition. of JEFFREY EPSTEIN was submitted to the witn for reading and signing; that after he had stated to the undersigned Notary Public that he had read and examined her deposition, he signed the same in the presence of the undersigned authority on the___ day of. 2010. 46 (Pages 178 to 181) U.S. Legal Support (561) 835-0220

182 1 BRRATA SHEET j 2 inRe: LM, V. EPSTEIN 3 DO NOT WRITE ON TRANSCRIPT ENTER CHANGES HERE: 4 5 PAGE LINE CHANGB REASON 6 1 1 8 9 10 i 2, 12 \ 13 L 14 i. 15 JEFFREY EPSTEIN | 16 Az } 18 ‘THE STATE OF FLORIDA) 19 COUNTY OF PALM BEACH) 20 1DO HEREBY CERTIFY THAT JEFFREY EPSTEIN appeared before me and stated that he has read 21 his deposition; further, that this Errata Sheet was signed in my presence onthis_____ day 22 of, 2010. 23 2 US. LEGAL SUPPORT Registered Professional Reporters 2 444 West Railroad avenue Suite 300 3 ‘West Palin Beach, Florida 33407 {561)835-0220 4 February 22, 2010 5 § BURMAN, CRITTON, LUTTIER & COLEMAN 303 Banyon Boulevard Suite 400 West Palm Beach, Florida 33401 t ATTENTION: MICHAEL PIKE, ESQ. | In Re: LM. V, EPSTEIN Deposition off JEFFREY EPSTEIN 10 Boy 2 Deer Mr. Pike: 3 Since counsel have agreed that you may 14 have the wimess read and sign your copy of the deposition, for your convenience, onctosed 15 herewith you will find an Errata Sheet for the witness’ use in entering any changes to the 16 deposition. vv “Thank you for your prompt attention. 1B Cordially yours, U.S. LEGAL SUPPORT 19 20 TERR BECKER, Registered 2 Professional Reporter, Notary Public, State of Florida at 22 Large. My commission expires March 13, 2011, 23 CC: Bradley Edwards, Esq. 47 (Pages 182 to 183) U.S. Legal Support (561) 835-0220

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DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 6

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CV-80893-CIV-MARRA/ JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-8-591, 09-80656, 0939-80802, 09-81092 VOLUME IIT CONTINUED VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN TAKEN ON BEHALF OF THE PLAINTIFF DATE: April 14, 2010 U.S. Legal Support (561) 835-0220

10 aL 12 43 a4 15 16 Ww 13 ag 17 18 a9 20 21 22 23 24 337 Aprit 14, 2010 INDEX WITNESS JEFFREY EPSTEIN BY MR. HOROWITZ 340 BY MR. EDWARDS 418 BY MS. EZELL 331 EXHIBITS PLAINTIFF'S FOR IDENTIFICATION PAGE 2 Multi-page document. 341 3 Multispage document. 349 4 Multi-page document. 359 5 Multi-page document. 369 6 — Muttispage document, 378 7 Multi-page document. 384 8 Multi-page document. 391 9 — Osder form from Amazon.com, listing three books, $07 338 The continued videotaped deposition of JEFFREY EPSTEIN in the above-entitled and numbered cause, was taken before me, TERRT BECKER, a Registered Professional Reporter and Notary Public for the State of Florida at Large, at 444 West Railroad Avenue, in the City of West Palm Beach, Palm Beach County, in the State of Florida, beginning at the hour of 10:22 o'clock a.m., pursuant to the Notice and Adjournment in said cause for the taking of said deposition, on behalf of the PLAINTIFF in the above-entitled action pending in the above-named court, The appearances at said time and place were as follows: FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL Attomeys for Plaintiffs Sane Does, LN. and E.W. 425 North Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 BY: BRADLEY J. EDWARDS, ESQ. MERMELSTEIN & HOROWITZ, ?.A. Attomeys for Plaintiffs Jane Does, numbers 2 through 8 {8205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 Tel: (305) 931-2200 BY: ADAM D. HOROWITZ, ESQ. | DIRECT CROSS REDIRECT RECROSS 10 an 12 13 14 APPEARANCES (CONTINUED) PODHURST, ORSECK Attorneys for Jane Does 1 and 3 City National Bank Building, Suite 88 25 West Flagler Street Miami, Florida 33130 Tel: (954) 463-4346 BY: KATHERINE W. EZELL, ESQ. BURMAN, CRITTON, LUTTIER & COLEMAN, Attorneys for Defendant Jeffrey Epstein 303 Banyon Boulevard, Suite 400 ‘West Palm Beach, Florida 33401 Tel: ($61) 842-2820 BY: MICHAEL PIKE, ESQ, ALSO PRESENT: JOE ROVNER, Videographer (US. Legal) 340 THEREUPON, JEFFREY EPSTEIN being by Terti Becker first duly sworn to tell the whole truth, as hereinafter certified, testified as follows; CONTINUED DIRECT EXAMINATION BY MR. HOROWITZ: Q Mr. Epstein, you understand we are continuing your deposition from Part One whiel was taken on March 8, 2010? A Yes. Q When we were together on March 8th, yi told us at that time that you were on probation in the State of Florida. Is that still the case? A Yes. Q L[helieve you also told us part of the term of your sentence was that you were not allowed unsupervised contact with anyone und the age of 18, Is that still the case? A Yes. Q At that time, you told us that you're restricted from possessing pornographic material, Is that still the case? A Yes. 2 (Pages 337 to 340) U.S. Legal Support (561) 835-0220

OI HM mR wr io al 12 13 14 15 16 17 18 19 20 21 22 23 24 25 341 Q At that time you told ns you were a registered sex offender in the State of Florida. Is that still the case? ! A Yes. | Q At that time you told us you lived at 358 E} Brillo Way. Is that still the case? A. Onadvice of counsel, sir, I'm going to have to invoke my Sixth, Fifth and Fourteenth Amendment rights. Q I'm going to hand you a document which we will mark as Exhibit 2, We had marked Exhib 1 at our first session, (Multi-page document was marked as Plaintiff's Exhibit aumber 2 for identification, as of this date.) Q (Handing.) I'm going to ask you to please turn to page 6. Turn to where it says “Affirmative Defenses." Do you see where we are? A Yes. Q Paragraph one, under the words "Affirmative Defenses" says "As to all connts, plaintiff actually consented to and was a willing participant in the acts alleged, and therefore her claims are barred or her damages are require 342 te be reduced accordingly." This I'll tell you was filed in the case of M.L.; do you understand: that? A Yes, Q Have you seen this document before? A Not to my recollection, 20. { Q This statement that plaintiff M.L. i actually consented to and was a willing participant in the acts alleged; is that a true statement? A Sir, at least today F would like to answer each one of your questions, but I'm going. to have to, on advice of counsel, invoke my rights of the Sixth, Fifth and Fourteenth Amendment. i Q What facts do you have to support this contention here that plaintiff M.L. actually | consented to and was a willing participant in the acts alleged? MR. PIKE; Form. A. Though I would like to answer each and every one of your questions here today, Mr. Horowitz, unfortunately today on the advice of counsel, F will have to refuse to answer and invoke my rights under the Sixth, Fourteenth and Cea ae Oe TAH AwWKHE 343 Fifth Amendment. Q Isn't it try neither you or anyone you know has facts te support your contention that MLL. consented te and was 2 willing participant in the acts alleged? MR, PIKE: Form, A As you know I would really like answer that question, but at least today, T cannot. 1 am going to have to invoke my rights on advice of counsel under the Fifth, Fourteenth and Sixth Amendment, Q Okay, moving down to paragraph two, it says, in part, “as to all counts alleged plaintiff M.L. actually consented to and participated in conduct similar and/or identical to the acts alleged with other persons, which were the sole or contributing cause of plaintiff's alleged damages.” My qaestion for you is, what facts are you aware of to support your contention that M.| consented to and participated in conduct similar te and/or identical to the acts alleged in this lawsnit? MR, PIKE; Form. A_ Unfortunately T would like to answer 344 each of your questions here today, Mr. Horowitz, but on advice of counsel, at least today, | have to assert my rights under the Fourth, Fifth and Sixth Amendment. Q Isn't it true, sir, that you that this contention that M.L. consented to or participa’ in conduct similar to the acts alleged in this lawsuit with other persons? That's a faise statement; isn’t that true? MR. PIKE: Form, A Mr. Horowitz, | believe you already know the answer to most of these questions. [ would like to give them, but however, at least today on. advice of my counsel I have to assert my rights under the Sixth, Fourteenth and Fifth Amendment. Q Isn't it true, sir, you're not aware of who has facts anyone to support the statement that MLL. consented to and participated in similar or identical acts with other persons? MR. PIKE: Form. A Though I would fike to answer that. question, as I would like te answer all of your questions, at least today my counsel has advised me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendments. 3 (Pages 341 to 344) U.S. Legal Support (561) 835-0220

345} 347 1 Q Sir, please turn to paragraph three of 1 2 defendant Epstein's first Amended Answer and 2 3 Affirmative Defenses. ; 3 4 A Same page? 4 5 Q Yes, paragraph three, 5 6 A Okay. 6 7 Q Do you see it says "As to all counts 7 8 plaintiff impliedly consented to the acts alleged = & 9 hy not obj 9 10 My question for you is, what factsdo =| 10 qn you have to support your contention that =| 11. 12 plaintiff M.L. impliediy consented to the acts | 22 13 alleged by not objecting? 13 14 MR, PIKE: Form. And ail of these 14 15 questions call for a tegal conclusion, as 15 16 well. 16 17 A Though I would like to answer that 17 18 question, as I would like to answer all of your is 19 questions here today, on advice of my counsel, 49 20 I'm going to have to assert my rights today of 20 aL the Sixth, Fifth and Fourteenth Amendment. 1 22 22 Q Isn't it true, sir, that you're not 22 23 aware of any facts to support your contention | 23 24 that the plaintiff, M.L., consented tothe acts | 24 25 __alleged by not objecting; isn't chat true, sir? | 346] 1 MR. PIKE: Form? | 1 me A Can you repeat the question, I'm sorry? 2 3 Q Isn't it true you're not aware of any 3 4 facts to support this contention that MLL, 4 5 consented to the acts alleged by not objecting? 5 6 MR, PIKE: Form. 6 7 A Atleast today, Mr. Horowitz, I'm going 7 8 to have to assert my rights under the Sixth, 8 9 Fifth and Fourteenth Amendment not to answer tt 3 10 question, though I would {ike to. 10 aL Q Isn't it true, sir, you're not aware of 1. 12 anyone who has facts to support the contention ; 12 13 that MLL. consented to the acts alleged by not | 13 14 objecting? | 14 15 MR. PIKE: Form. } 15 16 A Mr. Horowitz, F would like to answer 16 uy your question but at Jeast today, under advice of | 17 18 counsel, I have to assert my rights under the 18 19 Sixth, Pifth and Fourteenth Amendment. 19 20 Q Turning to paragraph four, immediately | 20 2k following the paragraph... It says "Defendant | 21 22 reasonably believed or was told that plaintiff 22 23 had attained the age of 18 years old at the time | 23 24 of the alleged acts"? Isn't it true, sir, that's 24 25 not a true statement, is it? You knew that M.L. L 25 2 was not 18 years old at the time of the alleged acts? MR. PIKE: Form. A. Though I would like to answer that question, as I would like to answer every one of your questions here today, on advice of counsel I'm going to have to assert my rights under the Sixth, Fifth and Fourteenth Amendment, sir, Q Mr. Epstein, what facts are you aware of to support your contention that MLL. had attain the age of 18 years old at the fime of the alleged acts? MR. PIKE: Same objection. A Though I would like to answer that question, Mr. Horowitz, I'm going to have to respond the same way I've responded to all of your questions here today; by asserting my rights on advice of counsel under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it rue, sir, you had no reason to believe that M.L. was 18 or older at the time of the acts alleged? MR. PIKE: Form. A. Unfortunately, though I would like to 348 answer that question, Mr, Horowitz, on advice of my counsel I'm going to have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Turning to paragraph five of your Amended Answer to M.L.’s lawsuit, it says: "As! to all counts, plaintiff's claims are barred, as she said she was 18 years or older at the time." Now, Mr. Epstein, that's not a true statement, is it? MR. PIKE: Form, A_ I would like to answer every one of your questions with respect to M.L., however, at least today, Mr. Horowitz, I'm going to have to assert my rights under the Sixth, Fifth and Fourteenth Amendment on advice of my counsel. Q Mr. Epstein, M.L. never told you she was 18 years of age or older; isn't that true? MR. PIKE: Form. A. Though I would like to answer every question regarding M.L., at least today I have te assert my rights under the Sixth, Fifth and Fourteenth Amendment, sir, under advice of counsel. Q Mr. Epstein, you've had a chance now to review the Affirmative Defenses one through fiva, 4 (Pages 345 to 348) U.S. Legal Support (561) 835-0220

az 23 24 25 349 which were filed on your behalf in this lawsuit. Do you have any facts to support the contentions in any of those Affirmative Defenses? MR. PIKE: Form. A. At least today I'm going to have to respond by asserting my rights under the Sixth, Fifth and Fourteenth Amendment, on advice of counsel, Q [will take back Exhibit 1 -- pardon me, Exhibit 2, and I'm going to band you what we will mark as Exhibit 3. (Multi-page document was marked as Plaintiff's Exhibit number 3 for identification, as of this date.) Q I'm going to hand you and your attorney -~ MR. HOROWITZ: I have extras. Q ~~ defendant Epstein's First Amended Answer and the Affirmative Defenses to plaintiff's Second Amended Complaint. Do you s that in front of you? A Yes, sir. Q Have you seen that before? A No, sir, Q I'm going to ask you to turn to page 6, 350 the page numbers are at the top, and do you seb the words " Affirmative Defenses"? A Yes, sir. Q Paragraph one includes the following statements — MR. PIKE; Can we -- it appears that paragraphs one through five are the same, Would that be correct, as the ones you just previously read? MR, HOROWITZ: Yes. MR. PIKE: Do you want to stipulate that the answers would be the same and the invocations of the Fifth, Sixth and Fourteenth would be the same, as well as my form objections? MR. HOROWITZ: Well, I need to ask the questions as to each client. MR. PIKE: So, you do not want to stipulate to that? MR. HOROWITZ: I'll stipulate that you have a standing objection, but I need to ask the questions and get them on record. MR. PIKE: All right, we will just go through it. Okay. Q As to Jane Doe 3, do you see in ' I | “ | i | \ Cer Aeawne aod paragraph one it says, "As to all counts, plaintiff actually consented to and was a willing participant in the acts alleged." Do you see that portion of paragraph one? A Yes, sir. Q The statement here that the plaintiff, Jane Doe number 3 consented to and was a willia| participant in the nets alleged; that’s not a true statement, is it? MR, PIKE: Form. A Who is Jane Doe 37 Q You don't know who Jane Doe 3 is? A_ Ido not. Don't you? Q Ido, I'll pull up the list here. There are a number of cases, as you're aware. Off the record for a second.) THE VIDEOGRAPHER: Off the video recor at 10:35 am, (Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video record 10:40 a.m, Q Mr. Epstein, Y.L. is Jane Doe 3. You have in front of you the Amended Answer and Affirmative Defenses filed in response to Jane Doe 3's lawsuit? 352 A Yes, sir. Q We marked that as Exhibit 3. Turning to affirmative defense paragraph number one, do yor seo where it says “Plaintiff actually consented to and was a willing participant in the acts alleged" in paragraph one; do you see that? MR. PIKE: Form. The document speaks for itself. Q Do you see where I'm pointing you fo? 1 want to make sure we are on the same page. A. Yes, [ do. Q The statement that Jane Doe number 3, Y.L., consented to and was a willing participant in the acts alleged; is that a true statement? MR. PIKE: Form, A Mr. Horowitz, I would like to answer every question about Y.L. here today, however on advice of counsel they've instructed me to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Mr. Epstein, what facts do you know of to support the statements that Y.L. actually consented to and was 2 willing participant in the facts alleged? MR. PIKE: Form, 5 (Pages 349 to 352) U.S. Legal Support (561) 835-0220

24 Q The acts alleged. MR. PIKE: Form, A. EF would like to answer every question. about Y.L., however, at least today on advice of counsel, they've instructed me that I must assert | my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, you are not aware of anyone who has facts to support the statement that Y.L, consented to and was a willing participant in the acts alleged? MR. PIKE: Porm. A. [would like to answer every question i about Y.L., however, today under advice of counsel, | cannot. They've instructed me to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Turning to paragraph two, it says: "Plaintiff, Y.L., actually consented to and participated to conduct similar and/or identica: to acts alleged with other persons, which were the sole or contributing cause of plaintiff's i alleged damages." Sir, that's not a true statement, is it? MR. PIKE: Form. 354 A [would like to answer every question about Y.L, today, Mr. Horowitz, however, on advice of counsel, they've instructed me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Mr. Epstein, what facts do you know of | to support the statement that Y.L, actually | consented to and participated in conduct simital and/or identical to the acts alleged with other persons? MR, PIKE: Form, and once again this line of questioning calls for a legal | conclusions, as well as work product information. A_ Though I would like to answer each and every question about Y.L., today unfortunately my! counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it rue, sir, you're not aware of q anyone who has facts to support the contention | that Y.L, consented to and participated in i conduct similar and/or identical to the acts alleged with other persons? MR, PIKE: Form. A. Though I would like to answer every ne wed aware 355 question you have here today, Mr. Horowitz, regarding your client, Y.L., on advise of my counsel, at least today | must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Turning to paragraph three of your Affirmative Defenses, it says "Plaintiff ¥.L., impliedly consented to the acts alleged by not objecting." Da you see that? A Yes. Q The first part of that sentence? A Yes, sir, Q That's not true statement, is it, six? MR. PIKE: Form. A_ Though I would like to answer every question about Y.L,, every single question, unfortunately today my counsel has advised me that f must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, what facts do you have to support your contention that Y.L. impliedly consented the acts alleged by not objecting? MR. PIKE: Form. A. Though I would like to answer every question about Y.L. that you pose here today, Mr. 356 Horowitz, at least today, unfortunately my counsel advised me that | must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Isn'tit true, sir, you're not aware of anyone who has facts to support your statement that Y.L. Impliedly consented to the acts alleg by not objecting? MR. PIKE: Form? A Mr. Horowitz, I would ike to answer every question about Y.L., i really would, However, today my counsel has advised me that I must assert my Sixth, Fifth and Fourteenth Amendment rights. Q Turning to paragraph four of your Affirmative Defenses, Mr. Epstein, it says "As t all counts, defendant reasonably believed or wa! told that the plaintiff had attained the age of 18 years old at the time of the alleged acts."" That's not a true statement, is it, sir? MR. PIKE: Form. A I would like to answer every question about YL. that you've posed here today. However, on advice of my counsel, I must assert my tights under the Sixth, Fifth and Fourteenth Amendment, at Jeast today. 6 (Pages 353 to 356) U.S. Legal Support (561) 835-0220

1 2 3 4 5 6 7 8 9 20 23 357} Q Isn't it true, sir, isn't it true that | you knew that Y.L. was under the age of 18 wheh she came to your home; isn't that true, sir? + MR. PIKE: Form. A_ | would like to answer every question. about Y.L. However, at least today my counsel has advised me | must assert my tights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, that you had no reason to believe that Y.L. was under 18? MR. PIKE: Form. A Can you repeat that question? Q Glad you asked. Isn't it true, sir, you had no reason to believe that Y.L. was 18 years. old or older? MR. PIKE: Form. A. I would like to answer every question about Y.L., and her -- the question you just asked, however at least today, my counsel has advised me that [ must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, that Y.L., never told you that she was under the age of 18? A Form. MR. PIKE: Form. MR, HOROWITZ: Strike that. Q Isn't it true, sir, Y.L. never told you she was 18 years or older? Isn't that true, sir? A I would like to answer every question you have today regarding ¥.L. and what she told me, However, today my counsel has advised me 1 must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Okay, paragraph five says the plaintiff's claims are barred as she said she was 18 years or older at the time. j Sir, that’s not a true statement, is i it? MR. PIKE: Form, A I would like to tel] you exactly what Y.L. said, however, my counsel has advised me to say that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. MR. PIKE: I wrote on your exhibit, page 3, MR. HOROWITZ: We will substitute a. different one. MR. PIKE: Yes, it is just checkmarks. (Clean copy was substituted for the page 25 COIK ARON 12 12 13 14 is 16 17 18 19 20 21 22 23 24 Orne ewe 10 al 12 13 14 15 16 17 18 19 20 24 22 23 359 containing markings in Exhibit number 3.) Q I'm going to hand te you the answer and Affirmative Defenses, Amended Answer and Affirmative Defenses that you filed in the lawsuit filed by V.Z.; do you have that in front of you? Jane Doe number 4, A Yes, sir. Q Flask you to turn to page 6 where you'll see the words “Affirmative Defenses” nea: the top of the page? MR, PIKE: This is Exhibit 4? MR. HOROWITZ: Correct, Exhibit 4. (Multi-page document was marked as Plaintiff's Exhibit number 4 for identification, as of this date.) THE WITNESS: Can we take a two-second break?? MR. HOROWITZ: Sure. THE VIDEOGRAPHER: Off the video reco at 10:48 a.m. (Pause in the proceedings.) MR. HOROWITZ: Back on the record, THE VIDEOGRAPHER: Back on the video record 10:49 a.m, Q De you have the Affirmative Defenses in 360 front of you, and the answer you filed in the V.Z. case, correct? A That's correct. Q Paragraph one includes the folowing statement: "As to all counts, plaintiff V.Z. actually consented to and was a willing participant in the acts alleged." That's not 2 true statement, is it, sir? MR. PIKE: Form. A. I believe her deposition of V.Z. speaks to this issue, Q Do you agree with V.Z,'s testimony that she was at your home? MR. PIKE: Form. A Unfortunately today, Mr. Horowitz, though I would like to answer every question about V.Z., { think her deposition speaks quite a well with some of those issues, but at least, with respect to my answering these questions today with regard to V.Z. and these issues, my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendments. Q Are you telling us that V.Z., in your opinion, was truthful in her deposition? 7 (Pages 357 to 360) U.S. Legal Support (561) 835-0220

ONIN ewWrNe 2s OMI HHHWNHE 10 12 13 14 15 16 17 18 19 20 ah 22 23 24 25 361| MR. PIKE: Form, misconstrues the witness's testimony. Move to strike. A [ believe, sir, that ~- though 1 would like to answer that question with respect to Ms. V.Z.'s deposition, my counsel has advised me at jeast today I must assert my rights under the Sixth, Fifth and Fourteenth Amendments, Q Sir, what did you mean when you said "V,Z.'s testimony speaks to this issue"? MR. PIKE: Asked and answered. A [believe E said “deposition testimony.“ Q Yes, what did you mean by that, when 7 { 1 said “Her deposition testimony speaks to the issue"*? MR. PIKE; Asked and answered, form, A_ On advice of counsel, I have to assert my rights under the Sixth, Fifth and Fourteenth Amendment, sir. Q What facts do you know of to support the WON ewe 18 19 statement that V.Z. actually consented to and was 20 a willing participant in the acts alleged? MR. PIKE: Form. A. [believe her deposition spoke to that directly, but however, myself, I'm going to have to assert my Sixth, Fifth and Fourteenth. Amendment rights under advice of counsel, sir. Q You read her deposition, correct? A No. Q You have not read her deposition? A No. Q But you believe her deposition testimony correctly speaks to the issue of the fact that she was 2 willing participant in the acts alleged with you? A. That's not what I said. | Q Why don't you tell me what you meant when you said, "Her deposition testimony speak; to the issue.” A. The deposition speaks for itself. Any other questions I'm sorry, Mr. Horowitz, but today I have to assert my rights under the Sixth, Fifth and Fourteenth Amendments. Q Isn't it true, sir, that you are not aware of anyone who has facts that support the | statement that V.Z. consented to and was a i willing participant in the acts alleged in her lawsuit? MR, PIKE: Form, A My understanding of her own testimony in her deposition speaks to that matter, but, 21 22 23 24 25 363 however, with respect to my own issues today, I am going to have to assert my rights on the advice of counsel, under the Sixth, Fifth and Fourteenth Amendments. Q Paragraph two in the Affirmative Defenses says, "As to all counts alleged plaintiff, V.Z., actually consented to and participated in similar conduct and/or identical fo the acts alleged with other persons which wer the sole or contributing cause to plai damages."" Sir, you know that's not correct; is that correct? MR. PIKE: Form. A I believe her deposition, in her own. words speaks to this issue, but as far as today my to that question answer unfortunately will have to be that I assert my rights under the Sixth, Fifth and Fourteenth Amendment on advice of counsel. Q Sir, isn't it true you're not aware of any facts to support your contention in this answer to the amended complaint that V.Z.. consented to and participated in conduct simila and/or identical to the acts alleged with other 364 persons? MR, PIKE: Form? A [believe her deposition in het own words speaks fo this exact question, but however, with respect to my answers today, unfortunately with respect to V.Z., though I would like to answer every question with respect to V.Z., on advice of counsel I have to assert my rights under the Fourteenth, Sixth and Fifth Amendment, Q Sir, my question was: What facts do you know to be true? Clarify for me. Are you sayin; that you are adopting what V.Z. says as true? MR. PIKE: Form, misconstrues the witness's testimony, and that is not exactly what your last question was, so I'm going to move + MR. HOROWITZ: Just to form + MR. PIKE: No, no, I'm not going to fet the witness answer a question that's going to potentially waive any Constitutional privileges here, so it will not be just “form.” Now, having said that, if you can repeat the question -MR. HOROWITZ: Can you repeat the 8 (Pages 361 to 364) U.S. Legal Support (561) 835-0220

365 | 1 question? | 2 (Discussion off the record.) | 3 Q Are you suggesting to us you are 4 adopting what V.Z. says is true in her 5 deposition? 6 MR. PIKE: Form. 7 A. Sir, I would like to answer every 8 question with respect to V.Z. However, today on 9 advice of counsel, 1 have to assert my rights 10 under the Fourteenth, Sixth and Fifth Amendment, 11 Q In paragraph three of your Affirmative 12 Defenses, it says “As to all counts, plaintiff | 13 V.Z. impliedly consented to the acts alleged by | 14 not objecting." | 15 Sir, that's not true, is it? 16 MR. PIKE: Form, 17 A [believe her own testimony in her 18 deposition speaks to that, however, at least 19 today, Mr. Horowitz, I have to assert my rights 20 under the Sixth, Fifth and Fourteenth Amendment ai Q What information do you have to support 22 your assertion that plaintiff V.Z. impliedly 23 consented to the acts alleged by not objecting? 24 MR. PIKE: Form. 25 A Information separate from her own. 366 1. testimony? I ~ with respect to any other 2 question, I'm going to have to assert my rights 3 under the Sixth, Fifth and Fourteenth Amendment; 4 upon advice of counsel, 5 Q Let's make sure we are on the same rae 6 then. 7 A Please. 8 Q Separate from her deposition { a testimony ~ | 10 A Yes? 1. Q —my question is: Do you have any 12 facts to support your assertion that V.Z. 13 impliedly consented to the acts alleged by not 14 objecting? 15 MR. PIKE: Form. 16 A. Separate from her own testimony with 1? respect to her consenting, at least today, though 18 I would like to answer that question, I'm going 19 to have to assert my tights under the Sixth, 20 Fifth and Fourteenth Amendment upon advice of 24 counsel, sir, i 22 Q Okay, paragraph four of the Affirmative 23 Defenses says, "As to all counts, defendant 24 reasonably believed or was told that plaintiff 2s had attained the age of 18 years old." Did I 14 15 16 ue 18 19 20 21 22 23 24 25 367 read that correctly? MR. PIKE: Fonn. I'm going to instruct. him not to answer that question. Did you read that correctly? Q Do you see where f am? Do you see whe Tam, paragraph four? MR. PIKE: You can answer that question as to whether or not you see where he is identifying paragraph four in the document tn front of you. A don't think you read it completely, did you? Q “As to ali counts defendant reasonably believed or was told the plaintiff had attained the age of 18 years old at the time of the alleged acts." Did I read that correctly now? MR. PIKE: 1 instruct you not to answer that question. It is not formed right, Did you read it correctly connotates an implied potential waiver, did you read it correctly, is it correct? Q Did f accurately read the statement in your Affirmative Defenses? MR. PIKE: That is -- you can answer that question, 368 A Yes. Q Okay. Isn't it true, sir, that you knew, you knew, that V.Z. was not 18 years old before May of 2005; isn't that true? MR. PIKE: Form. A Though I would like to answer every question regarding V.Z. and what she said, at least today upon advice of counsel, I have to assert my rights under the Sixth, Fifth and Fourteenth Amendment, sir, Q isn’t it true, sir, you had no reason to believe up until May 2005 that V.Z. was 18 yea: ald or older? MR. PIKE: Form. A. Separate and apart from her own testimony I believe on the subject, at least with respect to today, to answer these questions I'm going to have to assert my rights under the Sixth, Fifth and Fourteenth Amendment on advice of counsel. Q Isn't it true, sir, that prior to May of 2005, V.Z. never told you she was 18 years old o| older? MR. PIKE: Form, A Though I would like to answer that 9 (Pages 365 to 368) U.S. Legal Support (561) 835-0220

ed nue wre 9 10 1. 12 13 14 15 16 17 18 19 20 2a 22 23 24 25 oN wre 10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 369 question with respect to what V.Z. told me, at | least today ]'m going to have to assert my rights under the Fourteenth, Sixth and Fifth Amendment; upon advice of counsel. Q As to paragraph five, states the ' following: "Plaintiff's claims are barred as she; said she was 18 years or older at the time," Sir, you know that's not true. That never happened before May of 2005; isn't that : correct? | MR. PIKE: Form, | A_ Though I would like to answer every question with respect to what V.Z. said and did, I, unfortunately today, have to assert my rights under the Sixth, Fifth and Fourteenth Amendment! upon advice of counsel, Q I'm going to hand you what will be marked as Exhibit 5, Defendant Epstein's First; Amended Answer in the Affirmative Defenses to Plaintiff's Second Amended Complaint in the lawsuit filed by A.C. (Handing,) (Multi-page document was marked as Plaintiff's Exhibit number 5 for identification, as of this date.) 370 Q I'm going to ask you again to turn to page 6 where it says “Affirmative Defenses." Do you see where it says “Affirmative | Defenses"? A Um-hum. | Q Paragraph one includes the following statements: "As to all counts plaintiff actually consented to and was a willing participant in the acts alleged, and therefore her claims are barre or her damages are required to be reduced accordingly." Sir, this statement that A.C. consented to and was a willing participant in the acts alleged; that's not true, is it? MR. PIKE: Form. A I believe her own deposition speaks to that exact question, but at least as far as my answers ate concemed today, Mr. Horowitz, } unfortunately upon advice of my own counsel, I have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. i Q Do you agree with A.C.'s statements with; regard to her activity at your home as stated in her deposition testimony? MR, PIKE: Form, misconstrues the | 371 1 witness's testimony? 2 A_ 1 would like to answer every single 3 question regarding A.C.'s claims, every single 4 one, however, today, upon advice of counsel, at 5 least today, they've instructed me to assert my 6 rights under the Sixth, Fifth and Fourteenth ” Amendment, 8 Q Sir, what facts do you know of to 9 support the statement that A.C. consented to an 10 was a willing participant in the acts alleged? id MR. PIKE: Form. 12 A_ Separate and apart from her own 13 deposition testimony, I'm sorry, but I would like 44 to answer every question with respect to her 15 behavior -- can you repeat the question, sir? 16 Q Sure. What facts do you know of to a7 support the statement that plaintiff, A.C., 18 consented to, and was a willing participant in 19 the acts alleged? 20 MR. PIKE: Form. 21 A. Separate and apart from her own 22 testimony on the subject, | cannot answer today 23 that question, though I would fike to. And upon 24 advice of counsel, I must assert my rights under 25 the Sixth, Fifth and Fourteenth Amendment. 372 1 Q Isn't it true, sir, you're not aware of 2 anyone who has facts to support the statement 3 that A.C. consented to and was a willing 4 participant in the acts alleged? 5 MR. PIKE: Form. 6 A Unfortunately ~- I would like to answer 7 every question about A.C.'s alleged participation 8 in any event. However, today, upon advice of 9 counsel I have been instructed that I must assert 10 my rights under the Sixth, Fifth and Fourteenth a1 Amendment, 12 Q Sir, paragraph two of the Affirmative 13 Defenses says: "As to all counts alleged 14 plaintiff actually consented to and participated 18 in conduct similar and/or identical to the acts 16 alleged with other persons which were the sole ot 17 contributing cause to plaintiff's alleged 18 damages.” 19 Now, sir, that's not a true statement 20 that plaintiff consented to and participated in 21 similar acts with other persons, is it? 22 MR. PIKE: Form. 23 A. I would love fo respond to every 24 question with respect to simifar acts performed 25 by A.C. with other people, However, at least U.S. Legal 10 (Pages 369 to 372) Support (561) 835-0220

373] 1 today upon advice of counsel I must assert my 2 rights under the Sixth, Fifth and Fourteenth 3 Amendment, 4 Q Sir, what facts do you have to support 5 the assertion that A.C, participated in conduct 6 similar and/or identical te the acts alleged in 7 her lawsuit against you, with other people? 8 MR, PIKE: Form. 9 A. Separate and apart from her own ' 10 deposition, her own testimony, | would like to 14 give all the facts with respect to A.C.'s 12 behavior with other people. However, today my i 13 counsel has advised me that [ must assert my | 44 rights under the Sixth, Fifth and Fourteenth i 15 Amendment, | 16 Q Have you read her deposition testimon 47 MR. PIKE: Form. i 18 A No. 19 Q Have you listened to her deposition 20 testimony? 21 A [don't recall. 22 Q Am [accurate then, whatever you know} 23 about her lawsuit is something your attorneys 24 have shared with you? L Q Or do you have it from another source? 2 MIR, PIKE: One second. 3 MR, HOROWITZ: You have to wait for th 4 question ~ 5 MR. PIKE: No. i 6 MR, HOROWITZ: That's the way the rutes! 7 worked, 8 MR. PIKE; You'te asking a question, 9 then you're pausing to elicit a response to 10 waive attomey/client privilege, okay? Then 1 you're jumping into another question. If 12 you would like me to sit in your chair and 13 teach you how to ask the questions, 1 will | 14 be happy to do so. i 1s MR. HOROWITZ: You couldn't teach me 4 16 single thing. } 17 MR, PIKE: However, today we're here for | 18 you. We're hete for you to ask your 19 questions, If you would fike to break up. 20 your questions, you can do so. But as to aL that fast question, I'm going to instruct 22 you not to answer, because, as you know, it | 23 is attorney/client information. Ifyou want =| to try again, we're here all day. | | Q Sir, is it accurate te say that all Seaeinwerwne 375 information you have about A.C.'s testimony cam} from your lawyers, er did you hear here it from some other source? MR. PIKE: Form. T'm going to instruct you not to answer that question. Q Have you heard from any source other than your attorneys what A.C. testified about? MR, PIKE: You can answer that question. A No. Q Sir, paragraph three of your Affirmative Defenses to A.C.'s lawsuit says, “As to alll counts plaintiff impliedly consented to the acts alleged by not objecting,” Do you sce that? A Yes, sit. Q Sir, you know that's not a true statement, isn't it? MR. PIKE: Form. A [would fike to answer every question with respect to A.C, and what she did or alleged to have done, However, today I have to assert my Tights under the, Sixth, Fifth and Fourteenth Amendment, upon advice of counsel, Q Sir, what facts do you have to support 376 your assertion that A.C. consented to the acts alleged by not objecting? MR. PIKE: Form. A Unfortunately any facts I might have, my attorneys have counsefed me I must assert my rights under the Sixth, Fourteenth and Fifth Amendment, so | must assert those rights today, sir, Q Sir, isn't it true you're not aware of anyone who has facts to support the statement that A.C. consented to the acts alleged by not objecting? MR. PIKE: Form. A_ Though | would like to answer those questions with respect to the facts about A.C., at least today my counse! has advised me [ must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Turning to paragraph four of the Affirmative Defenses, isn’t it true, sir, that you knew that A.C. was 18 years, was under 1 years old when she came to your home? MR. PIKE: Form? A_ Though I would like to answer every question about Ms, A.C., I cannot, on advice of 11 (Pages 373 to 376) U.S. Legal Support (561) 835-0220

al 377| counsel today, and they've asked me to assert my rights under the Sixth, Fifth and Fourteenth. Amendment. Q Isn't it true, sir, that you had no reason to believe that A.C. was 18 years or older when she was at your home? MR. PIKE: Form, A Though { would like to answer every question about A.C, today, Mr. Horowitz,, my counsel has advised me I must at least today j assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, A.C, never told you she was 18 years old or older? MR. PIKE: Form. | A. Though I would like to answer that question regarding what Ms. A.C. told me, my counse] has advised me that today I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, no one ever told you that A.C. was 18 years old or older when she Mi at your home? i MR. PIKE: Form. A. Though I would like to answer that question, with respect to what people told me how old she was or what she told me how old she was, sorry, but my counsel advised me today I must assert my rights under Sixth, Fifth and Fourteenth Amendment. Q Okay. (Multi-page document was marked as i Plaintiff's Exhibit number 6 for identification, as of this date.) Q Moving on to Exhibit 6, Epstein’s First | Amended Answer in Affirmative Defense is to mak his First Amended Complaint in the Jane Doc number 6 case, and I'll hand you a copy of that and represent to you that Jane Doe 6 is V. okay? ask you to turn to page 6 ~[ see you've already done that, of the Affirmative Defenses, What facts do you have to support the contention in paragraph one that V.A. consented to and was a willing participant in the acts alleged? MR. PIKE: Form? A Though I would like to answee the question regarding what V.A. consented to and how she was a participant in the events, my counsel sat Coane wne 379 today advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, there are no facts that you're aware of to support the statement that V.A. consented to and was 2 willing participant in the acts alleged? MR. PIKE: Form. A Though, the question of whether she was a willing participant in the acts alleged, 1 would really like to answer those questions with respect to V.A. However, at least today my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Turning to paragraph two of the Affirmative Defenses, what facts do you have to support your assertion that V.A. consented to an participated in conduct similar and/or identical to the acts alleged with other persons? MR. PIKE: Form. A Though | would like to answer the question about the acts that she’s performed with other persons similar to the ones alleged here, at least today under advice of counsel, L have been instructed to assert my rights under the Sixth, Fifth and Fourteenth Amendment. 380 Q Sir, you know that V.A. never consented to or participated in similar or identical acts with other persons; isn’t that right? MR. PIKE: Form. A. I would very much like to answer that question, very much. However, sir, at least today my counsel has advised me I must assert m: tights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, isn’t it true you're not aware of anyone who has facts to support your assertion] that V.A. consented to or participated in similaj or identical acts with other persons? MR. PIKE: Form, A I'm sorry, can you read that question back? Q Sir, isn't it true you're not aware of anyone who has facts to support your assertion| that V.A. consented to and participated to similar or identical acts with ether people? MR. PIKE: Form. A Though I would like to answer that question regarding docs anyone cise have information with respec to V.A. participating with other people in similar acts as your 12 (Pages 377 to 380) U.S. Legal Support (561) 835-0220

25 COVA Awe 10 12 13 14 15 16 17 18 19 20 21 22 23 24a question posed, unfortunately, today, sir, I'm. going to have to assert my rights upon advice of counsel under the Sixth, Fifth and Fourteenth Amendment, Q Turning te paragraph three of your Affirmative Defenses, sir, it is not a true statement that V.A. impliedly consented to the acts alleged by not objecting, is it, sir? MR, PIKE: Form. A. The question regarding V.A. implied consent that you've just posed, I would fike to answer that question. | would like to answer all the questions with respect to V.A. that you've { posed here today. However, upon advice of i counsel I have to assert my rights under the i Sixth, Fifth and Fourteenth Amendment. | Q Sir, what facts do you have to support | your coutention that V.A., consented to the acts alleged by not objecting? MR. PIKE: Form. A. Though I would like to answer that i question regarding the facts that I have regarding V.A.'s consent, my attorneys have advised me that today [ have to assert -- at feast today, I have to assert my rights under the 382 | Sixth, Fifth and Fourteenth Amendment. Q Sure, turning to paragraph four, it says "As to all counts" -- strike that. isn’t it true, sir, that you knew when V.A. was at your home that she was not 18 years old? MR. PIKE: Form. A J would like to answer the question about V.A., every question about V.A. here today that you've posed. However, upon advice of my counsel they've advised me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. | Q Isn't it true, sir, you had no reason to believe that V.A. was 18 years of age or older? MR. PIKE: Form. | A. The question regarding my reason to | believe V.A, was 18 or over? I would really fike | to answer that question, but however, today my counsel has advised me } must assert my rights under the Fifth, Sixth and Fourteenth Amendment, | sir, Q Isn't # true V.A. never told you she was 18 or older? A Though [ would very much like to respond 1 Q Sir, I'm going to hand you what we will 383 to the question of what V.A. told me, I would like to respond to every question regarding V.A..,| my counsel has advised me that today at least, 1 must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, that you could plainly tell by leoking at V.A. that she was not! 18 years old? MR. PIKE: Form. A. Sir, I woutd like to answer that question, as I would like to answer every other question regarding your plaintiff, V.A. However today on advice of counsel, they've instructed m IT must assert my rights under the Sixth, Fifth and Fourteenth Amendment. MR, PIKE; Form. A Isn't it true, sir, no one told you V.A. was 18 years old or older. MR. PIKE: Form, A Though I would like to answer every question of what people told me regarding V.A., allegedly, my counsel has instructed me { must respond by asserting my Sixth, Fifth and Fourteenth Amendment rights, sir. 384 mark as Exhibit 7. It is Defendant Epstein's First Amended Answer and Affirmative Defenses ff Plaintiff's First Amended Complaint in Jane Doe 7} case filed by F.P. (Multi-page document was marked as Plaintiff's Exhibit number 7 for identification, as of this date.) Q Task you to take a look at that, please, and turn to page 6, of the Affirmative Defenses. THE WITNESS: Take a five-minute break? MR. HOROWITZ: Sure. THE VIDEOGRAPHER; Off the record at 1h13 am, (Pause in the proceedings.) THE VIDEOGRAPHER; Back on the video record 1:2bam. Q Mr. Epstein, do you have in front of you the Affirmative Defenses filed in your behalf in F.P.'s lawswit? A Yes. Q What facts do you have to support your contention that F.P, consented to and was a willing participant in the acts alleged? MR. PIKE: Form, 13 (Pages 381 to 384) U.S. Legal Support (561) 835-0220

385 A. Separate and apart from her own statements with regard to these issues, I would like to answer every question here today with i respect to FP. However upon advice of counsel, at least today, I have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q And is it your position that, well, tell us if it is your position that F.P, admitted to consenting to and being a willing participant in the acts alleged, MR. PIKE: Form. A. Can you repeat the question? Q Isit your position that F.P. Admitted in her deposition testimony to having consented to, and having been a willing participant in the acts alleged? A. I think her deposition speaks for itself, but anything beyond that, at least today, Mr. Horowitz, I'm going to have to assert my rights upon advice of counsel under the Sixth, Fifth and Fourteenth Amendment. Q Do you believe that F.P, was accurate when she, according to you, testified that she consented to and was a willing participant in thy acts alleged? i | i MR, PIKE: Form. A 1 would fike nothing more than to respond to everything F_P, has to say. However, at least today, upon advice of my counsel, I'm going to have to assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Mr. Epstein, you know the statement thay F.P. consented to and was a willing participant in the acts alleged if not a true statement; isn't that right? MR, PIKE: Form. A_ I would very much like to respond to whether F.P. was a willing participant in any alleged act. However, at least today, Mr. Horowitz, my counsel has advised me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, what facts de you know of to support the statement that F.P. consented to and was a willing participant in the acts alleged? MR. PIKE: Form, A. Though E would like to respond to every question regarding the facts regarding F.P. and what she consented to and what she did not consent to, I'm afraid that at least today my 387 counsel has advised me 1 must assert my rights under the Fifth, Sixth and Fourteenth Amendment, Q Turning to paragraph two of your Affirmative Defenses, what facts are you aware o} to support your contention that F.P., consented te and participated in similar or identical acts with other persons? MR, PIKE: Form. A. Though I would very much Hike to respond to similar acts that F.P. participated in with tespect to your question, sir, at ieast today my counsel has advised me that I must assert my tights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, you know of no facts to support your contention in the Affirmative Defenses that F.P. participated in similar or identical acts with other persons? MR, PIKE; Form. A As I said previously, | would like to testify, f would like to answer your questions with respect to F.P. However, today my counsel has advised me that at least today I would have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. 388 Q Isn't it true, sir, you're not aware of anyone who has facts to support the contention that K.P. participated or consented to similar or identical acts with other peopte? MR. PIKE: Form. A The issue of whether F.P. participated with other people in similar alleged acts, 1 would very much like to answer. However, today m counsel has advised me 1 may not, and have advised me f must assert my Sixth, Fifth and Fourteenth Amendment rights. Q Turning to paragraph three, what facts do you have to support your contention that F.P. consented to the acts alleged by not objecting? MR, PIKE: Form, A Though I would like to answer every question here today regarding F.P., my counsel has advised me that at least today I have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, you know of no facts to support your contention that F.P. consented to the acts alleged by not objecting? MR, PIKE; Form. A. Though I would like to answer every 14 (Pages 385 to 388) U.S. Legal Support (561) 835-0220

©oOIH Ee RW 369} question you pose regarding F.P., Mr. Horowitz, at least today my counsel has advised me I must assert my rights to the Sixth, Fifth and Fourteenth Amendment. Q Is it true, sir, you're not aware of anyone who has facts to support the statement that F.P. consented to the acts alleged by not objecting? MR, PIKE: Form, A_ I would like to answer the question with respect to F.P.’s consent or not consent. However, today my counsel has advised me I must} assert my rights under the Sixth, Fifth and Fourteenth Amendment, though I would very mu like to answer that question. Q Turning to paragraph four of the Affirmative Defenses, sir, you did not believe in your own mind that F.P. was 18 years or older before May of 2005; isn’t that true? MR. PIKE: Form. A Would you repeat the question, Mr. Horowitz? Q You didn’t believe prior to May 2005 in your mind that F.P. was 18 years old or older; isn't that true? i \ | | i i { MR. PIKE: Form. A. What I believed in my mind, unfortunately | would like to answer every question with regard to F.P. that you posed here { today, very much would like to answer every question with respect to F.P. However, at least today I have to assert my rights on advice of counsel under the Sixth, Fifth and Fourteenth Amendment, Q Sir, before May of 2005, you knew that F.P. was under the age of 18; isn't that right? MR. PIKE: Form. A Sir, I would like to answer every question with respect to F.P., that you've posed here today, However, my counsel has advised md that at least today | may not, and must assert my | rights under the Sixth, Fifth and Fourteenth Amendment. Q Shr, prior to May 2005 FP. never told you she was 18 or older; isn't that true? MR. PIKE; Form? A I would very much like to answer those questions, every question with respect to F.P. that you've posed here today, Mr. Horowitz. However, upon advice of my counsel, they've { i Or A Hew re 9 10 11 12 13 14 15, 16 iL? 18 19 20 21 22 23 24 25 391 advised me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Prior to May 2005, no one told you that E.P, was under the age of 18; isn't that right? MR. PIKE: Form. A_ | would very much like to answer every guestion with respect to what F.P. and what everyone ~- other people said about F.P. However, at least today my counsel advised me that F may not. They've advised me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. (Multi-page document was marked as Plaintiff's Exhibit number 8 for identification, as of this date.) Q Sir, I've just handed you defendant Jeffrey Epstein's Answer and Affirmative Defense} to plaintiff's Amended Complaints in the Jane Does number 8 lawsuit, filed by J.M. Do you hav. that in front of you? A Yes. Q [ilask you to turn, please, to page 6, which is the Affirmative Defenses. With regard te paragraph one, what facts do you have to support your contention that J.M. 392 consented to and was a willing participant in th acts alleged? MR, PIKE: Forn. A. Ewould like to answer every question about J.M, here today. However, my counsei has advised me that at least today -- 1 must assert my rights under the Sixth, Fifth and Fourteenth Amendment, though I would very much like to answer every question regarding J.M. Q Sir, what facts do you know of to support the statement that J.M, consented to an: was a willing participant in the acts alleged? MR, PIKE: Form. A Though I would like to answer every question about any alleged incident with J.M., my counsel has advised me that at least today [ must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Isn't it true, sir, you're not aware of anyone who has facts to support your assertion that J.M, consented to and was a willing participant in the acts alleged? MR. PIKE: Form. A_ [would like to answer every question regarding J.M., and her claims, and these alleged 15 (Pages 389 to 392) U.S. Legal Support (561) 835-0220

aL ae. 23 24 a5 incidents. However, today, at least today, my counsel has advised me that I must assert my tights under the Sixth, Fifth and Fourteenth Amendment. i Q Okay, turning to paragraph two, what | facts are you aware of fo support your contention that J.M. consented to and participated in similar or identical acts with other people? MR. PIKE: Form. A With respect to acts with similar other people, I would very much like to answer that question. However, at least today my counsel has | advised me that 1 must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Isn't it true, sir, that this assertion that J.M. consented to and participated in similar or identical acts with other persons; | that's not a true statement, is it? | MR. PIKE: Form. A J would very much like to answer every single question with respect to J.M. and her alleged claims of alleged incidents, However, | today, my counsel has advised me I must assert my | rights under the Sixth, Fifth and Fourteenth “| | i Q Isn't it true, sir, you're not aware of anyone who has facts to support your assertion that J.M. consented to and participated in | similar or identical acts with other people? MR. PIKE: Form. A_ [would like to answer every question with respect to J.M., her alfeged claims and alleged incidents. However, today my counsel has advised me that { must assert my rights under the Sixth, Fifth and Fourteenth Amendmeat, sir. Q Turning to paragraph three, what facts do you have ¢o support your assertion that J.M.} consented to the acts alleged by not objecting? { MR. PIKE: Form. | A. [would like to answer every question with respect to J.M.'s claims and alleged incidents. However, today my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, you're not aware of j anyone who has facts to suppert your assertion that J.M. consented to the facts alleged by not objecting? MR, PIKE: Form. A _ 1 would very much like to answer every SeMIHHeRWdHe 12 13 14 15 16 17 18 219 20 21 22 2 24 25 395 question that you've posed regarding your client, 4M. However, my counsel here today has advised me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment, at least today. Q Turning to paragraph four of the Affirmative Defenses, it is on the following page if you want to follow along; what facts do you have to support your contention that you believe: J.M. attained the age of 18 at the time of the alleged acts? MR. PIKE: Form. A T would very much like to answer every question with respect to J.M. and her claims. However, today, at least today, my attorneys have advised me that 1 must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, you knew that JM. was under the age of 18 at the time of the alleged acts? MR, PIKE: Form. A Iwould very much like to answer every question with respect to J.M.'s claims. However, my counsel today has advised me I must assert my tights under the Sixth, Fifa and Fourteenth 396 Q Isn't it true, sir, you had no reason to believe that J.M. was 18 years old or older at the time of the alleged acts? MR. PIKE: Form. A. I would like to answer every single question regarding J.M.'s claims, sir. However, at least today my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, sir, 1.M. never told you she was 18 or older? MR. PIKE: Form. A. T would very much like to answer every question regarding J.M.'s claims. However, today my counsel has advised me that ] must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Isn't it true, sir, no one ever tald you that J.M. was 18 or older? MR. PIKE: Form. A | would like to answer every question with respect to M.'s claims. However, at least today my counsel has advised me that I may not, and though f would like to, they told me I must assert my rights under the Sixth, Fifth and 16 (Pages 393 to 396) U.S. Legal Support (561) 835-0220

woawnneawne 16 12 13 14 1s 16 iy 18 19 20 21 22 23 24 25 OMAHA WHhHE 10 11 12 13 14 15 16 17 18 Le: 20 21 22 zt 24 26 39 Fourteenth Amendment, Q Sir, did you ever pay for atelephone = | number (407) 665-3144, pay the phone bill? A. I would have to assert my rights under the Sixth, Fifth and Fourteenth Amendment, sir. Q Between 2061 and 2006, did you use the telephone number (407) 655-3144, to get kids to: come to your home for your sexual pleasure? MR. PIKE: Form. A. Though I would like to answer all these questions regarding phone numbers, I'm sorry but IE may not on advice of counsel, so I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Did you direct one or more people to use the telephone number (407) 655-3144 in order te get kids, girls, to come to your home for your sexual pleasure? MR. PIKE: Form. A Though I would like to answer every one of your questions today regarding phone numbers, on advice of counsel, I may not, because it may be relevant to other lawsuits or this lawsuit, | and they've instructed me that I must assert my rights under the Sixth, Fifth and Fourteenth 398 Amendment, @ Have you ever cither paid or had registered to you the telephone number (561) 373-2262? MR. PIKE: Form. A. I would like to answer every question regarding phone numbers, Mr. Horowitz. My attorneys have asked me to respond to most of your questions here today by asserting my rights under the Sixth, Fifth and Fourteenth Amendment I will bave to do so with respect to that question. Q Between the years 2001 and 2006, did you use the telephone number (561) 373-2262, in orde} to arrange for girls under the age of 18 to come to your home for your sexual pleasure? MR. PIKE: Form. A_ I would like to answer every one of your questions regarding phone numbers here today, Mr. Horowitz, However, on advice of counsel, at least today, they've instructed me that] must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Between 2001 and 2606, did you direct one or more people to use the telephone number (861) 373-2262, in order to get girls under the 12 ar ane ene 10 il 12 13 14 15 16 17 18 19 20 ea 22 23 24 25 399 age of 18 to come to your home for your sexual pleasure? MR. PIKE: Form. A_ F would like to answer every one of your questions regarding these phone numbers and. allegations. However, today, my counsel! has advised me that | may not and must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Have you ever paid the telephone bill or had registered in your name the phone number (561) 655-4590? MR. PIKE; Form, A Mr. Horowitz, I would like to answer each one of your questions regarding phone numbers here today, but on advice of counsel they've told me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Is (561) 655-4590 a telephone number you used between 2001 and 2006 to get girls under thd age of L8 to come to your home for your sexual pleasure? MR, PIKE: Form. A. Though I would like to answer every one of your questions regarding telephone numbers, my counsel has advised me that at least today | may not, becauise it may be relevant to this lawsuit or another lawsuit, and they've instructed me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q 1s (561) 655-4950 a telephone number that you directed to other people to use in order to get kids to come to your home for your sexual pleasure? MR. PIKE; Form. A_ I would like to answer every one of your questions regarding phone numbers allegedly used for these types of purposes. However, my counsel today has advised me { may not and have instructed me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, have you ever paid the phone bill or had registered in your name the phone numbe| (561) 762-2741? MR. PIKE: Form. A Though I would like to answer that question as { would like to answer every one of your questions here today, my counsel has advised me that at least today, I must assert my rights under the Sixth, Fifth and Fourtsenth Amendment, 17 (Pages 397 to 400) U.S. Legal Support (561) 835-0220

wOMIaANnewWrNe 10 11 12 13 14 1s 16 17 18 19 20 ai 22 23 401 sir. Q Is the telephone number (S61) 762-2741, a telephone number you used between 2001 and 2006 in order to get girls under the age of 18 to come to your home for your sexual pleasure? MR. PIKE: Form. A. I would like to answer every one of your questions with respect to these telephone numbers. However, my counsel today has advised me that I must assert, at least today, my rights under the Fifth, Sixth and Fourteenth Amendment, Q Sir, is (561) 762-2741 a telephone number that you directed other people to use in order fo get girls under the age of 18 to come to your home for your sexual pleasure? MR. PIKE: Form. A I would like to answer every question 1 regarding these telephone numbers, However, my counsel has advised me that at least today, that I may not and they've instructed me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, have you ever registered in your 1 name or paid the phone bill for telephone number | {S61} 655-7629 402 MR, PIKE: Form. | A. Lwould like to answer each one of your questions today, Mr. Horowitz, regarding these telephone numbers. My counsel has advised me | that at least today I may not, and must assert my tights under the Sixth, Fifth and Fourteenth Amendment. Q Is (561) 655-7629 a telephone number you used between 2001 and 2006 to get girls under th age of 18 to come to your home for your sexual pleasure? MR. PIKE: Form. A Though ! would very much like to answer every question regarding -- that you've posed. here today regarding phone numbers, on advice of counsel, | may not. They've instructed me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Is (561) 655-7629 a telephone number you directed other people to use in order to get girls under the age of 18 to come to your home for your sexual pleasure? MR. PIKE: Form. A Twould like to answer every one of your questions posed here today regarding various Sn Cou sA re wre 10 12 13 14 15 16 a7 13 19 29 21 22 23 24 2 Ce OAKaAewne 10 12 13 14a is 16 17 18 is 20 24 22 ae 24 phone numbers. However, upon advice of my counsel, they've instructed me that | must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, have you ever paid the phone bill or had the phone number (561) 820-8790 registered in your name? MR. PIKE: Form. A. [would very much like to answer every question regarding phone numbers that you've posed here today, Mr. Horowitz. However, my counsel has advised me that at least today | must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Sir, is the telephone number (561) 820-8790 a telephone number you used between and 2006 to get underage girls to come to your home for your sexual pleasure? MR. PIKE: Form. A Twould very much like to answer every one of your questions posed here today with regard to telephone numbers or anything else. However, my counsel has advised me at least today that ] may not, and must assert my rights under the Sixth, Fifth and Fourteenth Amendment. 404 Q Sir, is the telephone number (561) 820-8790 a telephone number yor directed others to use in order te get underage girls to come to your home for your sexual pleasure? MR. PIKE: Form, A I would like to answer every one of your questions regarding phone numbers, Mr. Horowitz, However, today my counsel has advised me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, have you ever paid the phone bill or had the phone aumber (561) 832-2104 register in your name? MR. PIKE; Form, A. Sir, l would like to answer every one of your questions regarding phone numbers. However, my counsel has advised me that at least today I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Is the telephone number (561) $32-2104 a telephone number that you used between 2003 ai 2606 in order to get kids to come to your home for your sexual pleasure? MR, PIKE: Form. A Though | would like to answer every one 18 (Pages 401 to 404) U.S. Legal Support (561) 835-0220

2 23 12 13 14 15 16 1? 13 19 21 22 23 24 25. 405! of your questions regarding phone numbers here | today, Mr. Horowitz, my counsel has advised me | that [ may not and must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, is telephone number (561) 832-2104 a telephone number that you directed others to; use in order to get underage girls to come to your home for your sexual pleasure? MR. PIKE: Form. ‘A. Though I would tike to answer every one of your questions regarding phone numbers, Mr. Horowitz, the various phone numbers you've now put on the table, my counsel has advised me at least today I may not, T must assert my rights under the Sixth, Fifth and Fourteenth Amendment Q Sir, have you ever paid the phone bill | or had registered in your name the telephone number (212) 517-7580? MR. PIKE: Forn, A Mr. Horowitz, 1 would like to answer every one of your questions regarding phone nurnbers that you've posed here today. However, upon advice of counsel, they've instructed me must assert my rights under the Sixth, Fifth and | Fourteenth Amendment. 406 Q Is (212) 517-7580, a telephone number that you used between 2001 and 2006 in order to get girls under the age of {8 to come to your j home for your sexual pleasnre? MR. PIKE: Form, A Mr. Horowitz, 1 would very much like to answer every one of your questions regarding various numbers you've thrown out here today. T have to answer that question like I've answered ail your other questions here today, which is on advice of counsel I may not answer these questions as they may not be relevant to another lawsuit — Q Sir — go ahead, sorry. A ~ though ! would like to, I ar going to have to assert my rights as instructed by counsel, under the Sixth, Fifth and Fourteenth Amendment. i Q Sir, is the telephone number (212) 517-7580 a telephone number that you directed others to use in order to bring girls to your home for your sexual pleasure? MR. PIKE: Form. A Though I would like to answer each and every one of your questions, Mr. Horowitz, 407 regarding these various phone numbers you've thrown out today, my counsel have advised me that I may not, and must assert my rights under the Sixth, Fifth and Fourteenth Amendinent. Q Sir, have you ever paid the phone bill for telephone number (917) 855-3363? MR. PIKE: Form. A Mr. Horowitz, ! would very much like to answer aff your questions regarding afl the various phone numbers you've thrown out here today. However, on advice of counsel they've asked me to assert my Sixth, Fifth and Fourteenth Amendment right, Q Sir, is the telephone number (917) 855-2262 a telephone number that you used betwee: 2601 and 2006 in order to get underage girls to come to your home for your sexual pleasure? MR. PIKE: Form. A Mr. Horowitz, with respect to ail these phone numbers you keep throwing out, I have to unfortunately answer the question the same way as T've answered all your other questions here today, which is I'm going to have to assert my rights upon the advice of counsel under the Sixth, Fifth and Fourteenth Amendment. Q Sir, is (917) 855-3363 2 telephone number that you directed ather people to use in order to get girls to come to your home for your sexual pleasure? MR. PIKE: Form, A. Although I would like to answer every one of your questions regarding the various phone numbers that you've thrown out today, at least today, upon advice of counsel, I have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Have you ever paid the phone bill for telephone number (561) 308-0282? MR. PIKE: Form? A With respect to all the phone numbers you've thrown out here today and asked questions with regard to today, my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Is the telephone number (561) 308-0282 a telephone number you directed other people to in order to bring girls under the age of 18 to your home for your sexual pleasure? MR. PIKE: Form. A. Thave to answer that question as I've 19 (Pages 405 to 408) U.S. Legal Support (561) 835-0220

w Owns one 10 12 12 13 14 45 16 7 1s 19 20 ai a2 23 24 25 COTA Rw 10 12 13 14 45 16 17 18 19 20 2. 22 23 24 2s 409 answered most of your other questions here today, Mr. Horowitz, which is upon advice of counsel I have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, have you ever paid the phone bill for telephone number (561) 655-4870? MR. PIKE: Form. A You've asked me many telephone numbers here today, Mr. Horowitz. I'm going to have to respond to that telephone number as I have to each and every one of your other phone numbers you've thrown out today, which is upon advice of counsel, they've instructed me to assert my rights under the Sixth, Fifth and Fourteenth Amendment although I would like to answer every; 15 one of your questions, Q Isthe number (561) 685-4870, a telephone number that you directed other peop! to use in order to bring underage girls to your home for your sexual pleasure? MR. PIKE: Form. A Though I would like to answer every question regarding phone numbers that you've posed here today, Mr. Horowitz, unfortunately my 410 the Sixth, Fifth and Fourteenth Amendment. Q Sir, have you ever owned or had a beneficial interest in a corporation known as Nine East 7ist Street Corporation? A_ I would like to answer every one of your questions here today, Mr. Horowitz, but on advice of counsel, at least today, i'm going to have to assert my rights under the Sixth, Fifth and. Fourteenth Amendment. Q Sir, have you ever owned or hada beneficial interest in J. Epstein & Company? A Sir, at least today with respect to most of your questions, like -- I've answered almost all of your questions here today, upon advice of counsel, they've asked me to assert my rights under the Sixth, Fifth and Fourteenth Amendment.| 16 Q Have you ever owned or had a beneficial interest or been an officer of Zorro Development 18 Corporation? A. E would like to answer every one of your questions here today, Mr. Horowitz. However, upon advice of counse} at least today, they've asked me to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Have you ever owned or had a beneficial; 25 411 1 interest in a business entity known as Zorro 2 Ranch? 3 A. Though I would like to answer every one : 4 of your questions, | would have to answer that a) one as {'ve answered all your other questions | 6 here today, which is upon advice of counsel toda; 7 they've asked me -+ instructed me to assert my 8 tights under the Sixth, Fifth and Fourteenth 9 Amendment. 10 Q Sir, have you ever owned or had a ql beneficial interest, been a director or officer \ j 12 of New York Strategy Group, LLC? | 13 A Mr. Horowitz, I would like to answer all \ 14 of your questions here today, but unfortunately my counsel has asked me -- instructed me to 16 assert my rights under the Sixth, Fifth and 17 Fourteenth Amendment. 18 Q Have you ever owned or had a beneficial 19 interest in or been an officer or director or 1 20 founder of the COUQ Foundation? | 21 A Though I would like to answer every one | 22 of your questions, Mr. Horowitz, | have to | 23 respond to that question as I have responded to 24 almost all of your other questions here today, which is that upon advice of counsel, they've 412 1 instructed me I must assert my rights under the 2 Sixth, Fifth and Fourteenth Amendment. 3 Q Have you ever been an owner, shareholde! 4 or had a beneficial interest in Financial $ Strategy Group, Inc.? 6 A I would like to answer that question, as 7 well as every other question you've posed here 8 today. However, my counsel has advised me that 9 at least today I must assert my rights under the o Sixth, Fifth and Fourteenth Amendment. 1 Q Have you ever owned or had a beneficial 2 interest or been a sharcholder in Financial 3 Trustees, Ine.? i4 A Though I would like to answer every one 15 of your questions here, that you've posed here today, Mr. Horowitz, I have to unfortunately 17 answer that question the same way as I've answered almost all of your other questions here 19 today. Upon advice of my counsel they've | 20 instructed me to assert my Sixth, Fifth and. an Fourteenth Amendment right. 22 Q Sir, have you ever been an owner, 23 shareholder, officer or director of the Gislaine 24 Corporation? A. Can you spell that? 20 (Pages 409 to 412) U.S. Legal Support (561) 835-0220

24 25 413 G-i-s-l-a-i-n-e, am } mispronouncing? Yes. How would you pronounce it? Gislaine. Okay. I'm sorry, but today at least I have to assert my rights under the Sixth, Fifth and Fourteenth Amendment upon advice of counsel. Q Sir, have you ever been an owner/shareholder or director of the LAW = | Plantation Management Corporation? ! A_ I would like to answer every one of your questions here today, Mr. Horowitz, with respect} to that one, as well as all the others, I have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, have you ever been an owner, shareholder or director of a business entity known as Epstein Interests? A. With respect to that question, as well as all of your other questions here today, my counsel advised me | may only answer the questions by asserting my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, have yeu ever been officer, FOProOre director, shareholder or employee of the wee Investment Group? A {have to respond to that question as I have responded to all your other questions here today, Mr. Horowitz. Upon advice of counsel they've instructed me to assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Sir, have you ever been a shareholder or ; owner of MC Squared Modeling? { A. With respect to that question, as aif the other questions you've posed here today, my | counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sir, do you have an ownership or beneficial interest in a business entity known as JEGE? A. I'm going to have to respond to that question as I responded to all of your other questions here today, Mr. Horowitz, which is, on advice of counsel they've asked me to assert my rights under the Sixth, Fifth and Fourteenth Amendment. @ Sir, do you have an ownership or beneficial interest or even an employee of an entity known as the Florida Science Foundation? OYA FeawWnHE 41s THE WITNESS: Take a quick... (Indicating counsel.) THE VIDEOGRAPHER: Going off the vide record 11:53 a.m. (Pause in the proceedings.) THE VIDEOGRAPHER: Back on the recor: ikS6am, (Phe record was read.) A Yes. @ Are you an owner of the Florida Science Foundation? A On advice of counsel, at feast today, sir, I have been instructed to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Are you an employee of Florida Science Foundation? A Yes, Q What do you do in your role as an employee of Florida Science Foundation? A. Though I would like to answer all of your questions here today, Mr. Horowitz, upon advice of counsel, they've instructed me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q What kind of work is the Florida Science Foundation involved in, if any? MR. PIKE: Form. A_ Though I would very much like to answer} all of your questions here today, Mr. Horowitz, upon advice of counsel, they've instructed me to assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Where do you work for the Florida Science Foundation? MR. PIKE: Form, A At 250 South Australian. That's the offices. Q Is that the City of West Palm Beach? A Yes, sir, Q During what hours do you work at the Florida Science Foundation? A Upon advice of counsel, sir, they've instructed me to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q How long have you been working at the Florida Science Foundation? MR. PIKE: Form. A. I would like to answer al] of your questions here today, Mr. Horowitz. However, upon advice of counsel, at least today, they've 21 (Pages 413 to 416) U.S. Legal Support (561) 835-0220

a 2 3 4 5 6 4 & 2g 16 il 12 13 14 is 16 17 18 19 20 21 22 23 24 25 instructed me to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q On what days do you work for the Florid4 Science Foundation? MR. PIKE: Form. A Though I would like to answer each one of your questions here today, my counsel has advised me that at least today I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Who else, if anyone, works for the Florida Science Foundation? MR. PIKE: Form. A Though I would like to MR. PIKE: You know that's standard Fifth Amendment, anyway. A. Though I would like to answer each and every one of your questions today, Mr. Horowitz, my counsel has advised me with respect to that question, I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Is the Florida Science Foundation a for-profit or sonprofit corporation? A Upon advice of counsel, sir, with respect to that question, I’m going to have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. MR. HOROWITZ: Sir, at this moment in time, 1 don't have further questions. There may be some other questions that arise from other people's questions. THE WITNESS: Allright. MR, PIKE: Thank you, Mr. Horowitz. MR, EDWARDS: Does anybody want to address what we are going to do for hunch? MR. HOROWITZ: You don't have to type this. (Discussion off the record.) ' | 10 j tl is 13 THE VIDEOGRAPHER: Off the video record 14 at 12:00 o'clock noon. (Pause in the proceedings.) i is 16 THE VIDEOGRAPHER: Back on the video | 17 record 12:11 p.m. MR. EDWARDS: Ready? MR. PIKE: Yes, thank you, THE WITNESS: Yes, Q I represent Jane Doe in a case against you and she is one of like ten representative plaintiffs here today. Did you do anything to prepare for your deposition today? | ae | 19 20 ad, 22 23 24 25 419 MR. PIKE: To the extent you can answer that question without divulging my communications with you, you can answer that question. A No. Q Did you review any materials, such as depositions, police reports, anything else in preparation for your deposition today? A No. Q Did you review any notes or any handwritten materials in preparation for your deposition today? A No, Q Vou have notes on a piece of paper, are those notes that you have made or reviewed in preparation for your continuation of this deposition here today? A No. Q In the past you've told me that some time ago at another deposition, that you did not like Jane Doe; is that right? A I don't believe -- I have no. recollection of that, Q To be more specific, and hopefully to jog your memory, do you remember telling me y 420 like L.M., but don't like my other two, one of those clients being Jane Doe; do you recall that} A. I would like to answer every one of your questions, Mr. Edwards, but today at feast, my counsel advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Why don't you like Jane Doe? MR. PIKE: Form, A_ would like to answer every one of your questions, Mr, Edwards. However, today my counsel has advised me that f measures assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Did you sexually molest Jane Doe when she was 14 and 15 years old? MR. PIKE: Form. A I would like to answer all of your 22 (Pages 417 to 420) U.S. Legal Support (561) 835-0220

oot nneune 24 25 421 | questions with respect to Jane Doe. However my counsel here today advised me I may not and must | assert my tights under the Sixth, Fifth and Fourteenth Amendment. MR. EDWARDS: Move to strike as nontesponsive. Q When you say you woutd like fo answer the questions, but your counsel has instructed you that you must invoke your Fifth, Sixth and LC OaIK He Wd BE Fourteenth Amendment rights, are you saying that 10 MR. PIKE: [ instruct you not to answer that question. MR. EDWARDS: On what ground? MR. PIKE: I don't need to give you | grounds, MR. EDWARDS: It is not a privilege, just something you're instructing him not to answer? MR. PIKE: Absolutely it is a privilege. You heard him, what he said. He is invoking his Sixth, Fifth and Fourteenth Amendment in and as a result of his advice of counsel. Your question elicits attorney/client communications as well as you disagree with the advice of your counsel? | 422 work product, Q So, attorney/client work product is the basis for your objection? [ understand. MR. PIKE: Yeah. Q Mr. Epstein, are you going to follow your advice of counsel and invoke your Fifth Amendment right against self-incrimination and not answer that question? A_ I'm going to follow my advice of counsel, Q Mr. Epstein, are you familiar with the laws in Florida on lewd and lascivious molestation? MR. PIKE: Form. A On advice of counsel I have to agsert my rights with the Sixth, Fifth and Fourteenth | Amendment. Q Do you understand my question in that I'm not asking you whether you committed any crimes related to the statute, only whether or not you are familiar with the Florida statute on lewd and lascivious molestation; do you understand that question? | MR. PIKE: Form. A What does "familiar" mean. 25 ©artauawne is 2 Pee ONG 20 423 Q Have you read the statute or been instructed upon the Florida statute related to lewd and lascivious molestation? MR, PIKE: Form, instruct you not to answer that question, attorney/client work product, as worded, Q Other than your attorney telling you about the statute, or reading that statute to you, I certainly de not want and am aot entitled to communications between you and your attorne: but have you otherwise familiarized yourself, either by way of reading the statute or being told by somebody other than your attorneys, regarding the statute lewd and lascivious molestation? MR. PIKE: Form. A Though I would like to answer every one of you ever questions here today, Mr, Edwards, most of your questions I have to respond by asserting on advice of counsel my Sixth, Fifth and Fourteenth Amendment right. Q Lewd and lascivious molestation is defined in Florida as a person who intentionally touches in a lewd or lascivious manner, the breasts, genitals, general area, or buttocks, or the clothing covering them, of a person less tha 16 years of age, or forces or entices a person under 16 years of age to so touch the perpetrator.”” Having read that, isn't that a statute that you violated on numerous occasions agains Jane Doe when she was a minor? MR. PIKE: Form, A I would -- have to assert my rights under the Sixth, Fifth and Fourteenth Amendment upon advice of counsel, Mr. Edwards. Q Subchapter six of that statute involves a crime of lewd and lascivious conduct that in Florida is defined as a person who intentionally! touches a person under 16 years of age in a te and lascivious manner, or a person who intentionally masturbates in the presence of a victim under 16 years of age." Those are also sections of that Florida statute that you violated against the then minor, Jane Doe; is that trae? MR. PIKE: Form. A_ I would tike to answer all of your questions with respect to Jane Doe, Mr. Edwards. However, today my counsel has advised me that I 23 (Pages 421 to 424) U.S. Legal Support {561) 835-0220

425 | 427 1 am to assert my rights under the Sixth, Pifth and | 1 molestation statutes against Jane Doe? 2 Fourteenth Amendment. | 2 MR. PIKE; Form. 3 MR. EDWARDS: Move to strike the 3 & Upon advice of counsel, Mr. Edwards, 1 4 nonresponsive portion of that answer. 4 have to respond to that question as I responded 5 MR, PIKE: What's nonresponsive? 5 to most of your other questions here today, by 6 MR. EDWARDS: What you would like to di 6 asserting my rights under the Sixth, Fifth and 7 is not responsive fo the question related to 7 Fourteenth Amendment. 8 his course of conduct. “Did you molest 8 I prefer to, in fact, respond to your 9 her," is either "yes" or "no" or "invoked." 9 partner who helped file this lawsuit, but he is 10 I don't really care and I don’t think it is 10 currently in jail, You might want to strike that ii relevant, what he would like to do. That's a1 as nonresponsive, but the ladies and gentlemen of 12 the part I would move to strike. 12 the jury will eventually know that most of these 13 ‘MR. PIKE: If that's the part you're | 13 cases have been brought by your firm, your 14 moving to strike, it is duly noted in the i 14 partner who sits in a jail for fabricating cases a5 record, pos of sexual nature against people like me and 16 MR. EDWARDS: Okay. i 16 others. 17 MR. PIKE: I object to that, For the \ 17 Q Okay, Let's talk about that, then. 18 record, based upon your comment, there have ; 18 You're talking about Scott Rothstein? Is that 19 been several depositions in these 19 right? You're saying my former partner. Is tha’ 20 consolidated cases and there has been | 20 who you're referring to that sits in jail? 21 iroplied arguments from the plaintiff's side } 21 A Correct. 22 relative to the Fifth Amendment waiver and | 22 Q Okay, what about anything that Scott 23 why Mr. Epstein is invoking the Sixth, Fith | 23 Rothstein did, affects your answer to my questioi 24 and Fourteenth Amendment Constitutional i 24 as to whether or not you molested Jane Doe bac! 25 28 in 2003 and 20047 ae 428 L inferences that I'm sure the plaintiffs will i 1 MR. PIKE: Form? 2 attempt to gain. } 2 A. [would like to answer that question 3 There have been arguments made relative [3 with respect to Scott Rothstein, his fabricated 4 to the Fifth Amendment and I think that you 4 cases and the reason he sits in jail. However, 5 have, in particular, Mr. Edwards, have 5 today, at least today, my counsel has advised me 6 attempted to balance what Mr. Epstein would 6 { must assert my rights under the Sixth, Fifth if like to do, versus what if he did that, | 7 and Fourteenth Amendment. 3 whether or not there would be a waiver of , 8 Q You say “at least today," but that's 9 the Fifth, the Sixth and the Fourteenth, So, | 9 something we have gone through with you day aftdr 10 Lunderstand your motion to strike and it is | 10 day, after day, and you say "at least today," and iL noted on the record, but I have to make jut we wait for the next deposition and again there 12 clear for the record that there have been | 12 is assertion of a Fifth Amendment right. Is 13 those arguments made and there isa balance | 13 there ever going to be a day where you do answer 14 as to what someone would like to do versus 14 the questions? 15 what someone can do, and the resulting 1s MR. PIKE; Form. Move to strike. 16 consequences of that being waiver. 16 A On advice of counsel, as I've answered 17 Q Given what your attorney just said, my | 17 most of your other questions here today, be them 1g understanding that... You have been instructed] 16 argumentative or not, meant for other purposes or 19 that if you answer these questions, as you would 19 not, my answer is going to be that my counsel has 20 like to, that it would incriminate you? | 20 advised me that at least today ] must assert my 21 MR. PIKE: Mischaracterizes my 21 rights under the Sixth, Fifth and Fourteenth 22 objection; and I instruct you not to 22 Amendment. 23 answer, 1 23 Q You indicated in your previous answer Q Why is it that you would like to answer questions about whether or not you violated that most of the cases were brought by me or my former pariner, Scott Rothstein. My 24 (Pages 425 to 428) U.S. Legal Support (561) 835-0220

WOAH KWH 10 12 13 14 1s 16 17 18 ig 20 21 22 23 24 429 understanding is that there were more than 20 cases brought against you alleging you sexually abused minors, and [ have personally only filed | three. How many are you aware of in addition to the three that Scott Rothstein filed, or brought, as you say? MR. PIKE; Form, mischaracterizes the © witness's testimony. MR. EDWARDS; Do you want the previous answer read back related to that? MR, PIKE: No, | think his answer will | be the same. A At least today I have to respond to that question as I've responded to most of your other questions here today, Mr. Edwards, which is, at least today I have to assert my rights under the Fifth, Sixth and Fourteenth Amendment, Q Ina portion of your answer, you indicated that Scott Rothstein fabricated cases. Are you alleging that the case of Jane Doe against Jeffrey Epstein is a fabricated case? MR. PIKE: Form. j A Lwould like to answer each one of your questions here today, Mr. Edwards, especially with respect to Jane Doe. However, my counsel 430 has Instructed me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Mr. Epstein, do you know a gentleman named Jean Luc Brunel and the last name is spelled B-r-u-n-e-1. j MR. PIKE: Form. A My counsel has advised me at least today, Mr, Edwards, as I've responded to most of your other questions, [ have to assert my right under the Sixth, Fifth and Fourteenth Amendment Q Mr. Brunel is somebody that you know to 11. be a child molester; is that right? MR. PIKE: Form. A_ would like to answer every one of your questions here today, Mr. Edwards. However, on | advice of counsel, they've instructed me J must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Mr. Brunel has been a close friend of yours for years and is still a close friend of yours today; is that right? MR. PIKE; Form. A Though | would like to answer every one of your questions posed here today, I have to answer that one as I've answered most of your | 431 1 other questions, which is, that upon advice of 2 counsel, at least today, they've instructed me 3 that I must assert my rights under the Sixth, 4 Fifth and Fourteenth Amendment. 5 Q fsn't it also true that through the 6 7 8 years he has sent you as, quote, unquote, "gifts," underage females, as young as 12 years old for you to illegally engage in sex with? g MR, PHKE: Form. 10 A_ I'm going to respond to that question as. il I responded to most of your other questions, 12 which is, upon advice of counsel, at least today, 13 though I would like to answer the question, 14 they've instructed me I must assert my rights 15 under the Sixth, Fifth and Fourteenth Amendment, 16 Q In fact, you know that we served Mr. 17 Brunel for deposition in this case. Are you 18 aware of that? 19 MR. PIKE: Form. 20 A I'm going to have to respond to that 21 question as [ respond to all your other questions 22 here today, Mr. Edwards, which is by asserting m 23 rights under the Sixth, Fifth and Fourteenth 24 Amendment. a0: Q He has been a house guest at your house 432 1 on numerous oceasions this year; isn't that 2 true? 3 MR. PIKE: Ferm. 4 A Though I would like to answer every one 5 of your questions here today, Mr. Edwards, { have 6 to respond to that question on advice of counsel ? the same way as I've responded to all of your 8 other questions, which is, I must assert my 9 rights under the Sixth, Fifth and Fourteenth 10 Amendment. Q F've asked you simply, if Mr. Brunel has 12 been a house guest of yours during the year 201 13 and you're choosing to invoke your Fifth 14 Amendment right against self-incrimination and] 15 basing that on your counsel's advice. 16 Does your counsel know that you made 17 that representation to Probation already this 18 year? i9 MR. PIKE: Form. 20 Q Do you understand the question? 24 A Are you asking me what my counset 22 knows? 23 Q No, 24 A I think you just asked what my counsel 25 knows. 25 (Pages 429 to 432) U.S. Legal Support (561) 835-0220

MR. PIKE: ‘That's exactly what «A You should ask my counsel. Q Here is my point: You've indicated to your Probation Officer this year, in fact, I'll ask it this way: Have you indicated to your | Probation Officer that Jean Luc Brunel has beea house guest of yours during the year 2010? MR. PIKE: Form. A [have been instructed by my counsel to answer that question, as I have been instructed to answer most of your other questions here today, which is by asserting my rights under the Sixth, Fifth and Fourteenth Amendment. Q Do you know an attorney named Tama Kudman? MR. PIKE: Form - actually that’s not "form." I withdraw that. A No. Q Did Mr. Brunel tell you that Tama Kudmah was an attorney that was hired to represent him | in this case? MR. PIKE: I'm sorry, hold on. MR. EDWARDS: Did Mr. Brunel tell him. { MR. PIKE: Okay, form. | A. I'm going to have to answer that ! 434 question as I’ve answered most of your other questions here today, Mr, Edwards, which is by asserting my rights under the Sixth, Fifth and Fourteenth Amendment. @ And did you or some entity that you own or control pay for the services of Tama Kudman ty represent Jean Luc Brunel, in this matter? MR. PIKE; Form. A ... I'm going to have to assert my rights under the Sixth, Fifth and Fourteenth Amendment | upon advice of counsel. Q Tcertainly don't want to get into this too often during this deposition but it is visibly noticed on the video that prior ta the i invecation of the Fifth Amendment, there is a shaking of the head which commonly indicates thal the answer is “No,” and I just want to make sure we are ail on the same page, that that was not your indication and that we can ignore those types of body movements, as Mr, Pike instructed me that was the case last time, MR. PIKE: I think that the record is clear, The court reporter does not understand nods of the head, shakes of the head, “um-hum" -i i 435 MR. EDWARDS: Agreed. MR. PIKE: His response is his verbal tesponse. MR. EDWARDS: | understand that, but certainly if witness is on the witness stand we both know they are allowed to observe the demeanor of the witness and part of that demeanor is the nodding or shaking of the head, which are common responses that is we all know and understand, { just want to make sure we are on the same page, the jury can ignore those body movements? MR. PIKE: As a matter of fact, and as you know, since you tried several cases, there is a pattemed jury instruction from the judge that says the jury can, in fact, take it into consideration. MR. HOROWITZ: That's the point. MR. PIKE: I cannot instruct the jury in this video deposition to ignore anything that occurs on this video. MR. EDWARDS: That's why I wanted to engage -- so 1 would make sure -- we are a little inconsistent obviously as to what the jury should be observing, what they can 436 yersus his response. | guess for this time we will get into it. Q In that last question that I asked you, related to you or some entity that you contro! paying for the services of Ms. Kudman, is the answer "no" or is the answer that you are invekiag your Fifth Amendment right to remal silent? MR. PIKE: Form. A. With respect to that question, as with respect to all your other questions here today, Mr. Edwards, upon advice of counsel I have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q isn't it true that you have specifically instructed Mr. Brunel to avoid his deposition in this case? MR. PIKE: Form. A. Upon advice of counsel, as with respect to most of your other questions here today, I'm going to answer that the same way by invoking my! rights under the Sixth, Fifth and Fourteenth Amendment, sir. Q Mr. Epstein, can you describe for the Jury your various schemes that you have devised 26 (Pages 433 to 436) U.S. Legal Support (561) 835-0220

18 20 aL 22 23 24 Veta on 2 wr 10 1 12 13 14 15 16 417 18 a9 20 21 22 23 24 25 25 437 to access underage minor females for sex? MR. PIKE: Form. A Though { would like to respond to afl these questions that you've posed here today, Mr. Edwards, I'm going to have to assert my rights under advice of counsel under the Sixth, Fifth and Fourteenth Amendment. Q I think the video will reflect that prior to your invocation at that time there was smile that I would characterize as 2 smirk, prio: to that answer, and I would like to understand, | | Ronin er SOY HAERwWHE 10 ql was there any intention on your part to convey a 12 message by that smile, prior to your invocation’ > MR. PIKE: First of all, this tine of questioning is not only argumentative, but itis harassing, okay? i | 13 14 15 16 MR. EDWARDS: We can play the video for 17 whether or not it is harassing. MR. PIKE: You can play the video, but if someone raises an eyebrow, blinks, does. something, it is... itis... for you to follow up with a harassing question is not only improper, but it is a waste of time, of attorney resources as well as judicial resources. I'm going to let you proceed, I 438 tnean, but... -- come on. MR. EDWARDS: With all due respect, I'm interpreting it as an intentional act designed to dilute the invocation of the Fifth Amendment and any adverse inference that we may be entitied to, and I think that you acknowledged previously that 4 jury will have or could have the ability to view this video, and I'm assuming a jury could make that same inference, so I want to make sure the record is just crystal clear. If the answer is one answer and there is no body movement, then I'll move on. If there is ! | ' 1 { 18 19 20 21 22 23 a4 25 O2AKKEONE body movement, I'm probably going to address tua it. MR. PIKE: I'm going to move to strike your last narrative. MR. EDWARDS: Okay. Q What individuals other than yourself helped you to devise your various schemes for accessing large numbers of minor females for sex? MR. PIKE; Form. A Though I would like to answer every one of your questions today, Mr. Edwards, upon advice} 1s 16 17 18 19 20 ab i 22 23 24 25 439 ofmy counsel, he’s instructed me that I may not. 1 must invoke my rights under the Sixth, Fifth and Fourteenth Amendment. Q Mr. Epstein, is it true that you have sexually molested underage minors in every community where you have komes or houses? MR. PIKE: Form. A Though J wouid like to answer each one of your questions here today, Mr, Edwards, I would like to answer that question, to you and your partner, who sits in jail for fabricating cases of a sexual nature against people like me and others in South Florida, but today, upon advice of my counsel, they've instructed me I must assert my rights under the Fifth, Sixth and Fourteenth Amendment. THE WITNESS: Before you go to the bathroom? MR. EDWARDS: Move to strike the portion] of the answer that was nonresponsive. MR, PIKE: One second. MR, EDWARDS: Move to strike the portion] of the answer nonresponsive, MR. PIKE: Move to strike your motion to strike. MR. EDWARDS: Based on the fact that if ‘was responsive? You feel it was responsive? * MR. PIKE: Absolute -- listen -MR. EDWARDS: it is fine if you do. MR. PIKE: You're harassing the witness, you're talking about heads and nod shakes. If you want to be clear for the record, 1 think, and I'm -- I think -- I think the witness is nodding and shaking his head in a manner because your questions are argumentative, “Please tell me the scheme that you devised.” “Please tell me who you molested,” al] of these are argumentative questions -MR. EDWARDS: If it wasn't true, it would be argumentative, MR. PIKE: They are just not formed right. You are sitting here subjecting the witness to questions that -- that are just argumentative. They are not structured appropriately, and you're taking that and you're implying something else for the jury on the record, and quite frankly, I don't appreciate that. So, yes, to answer your 27 (Pages 437 to 440) U.S. Legal Support (561) 835-0220

COINH UNE 444 question, it 100 percent is responsive. He is invoking his Sixth, Fifth and Fourteenth. j THE WITNESS: Bathroom break now? MR. EDWARDS; That's fine, | THE VIDEOGRAPHER; Off the video recor! 12:35 p.m. (Pause in the proceedings.) MR, EDWARDS: | will be asking you to read back the last question and answer, so you'te ready, THE COURT REPORTER: Certainly. THE VIDEOGRAPHER: Back on the video record 1:16 p.m. MR. EDWARDS: Madam Court Reporter, if you could read back the last question, as well as the last answer which I have been told was responsive. THE COURT REPORTER: Certainly. (The record was read.) Q Mr. Epstein, why is it that you would like to tell Scott Rothstein whether you have | sexually molested underage minors in the various communities where you have homes? MR. PIKE: Form. Mischaracterizes the \ } { | { | | 442 witness's testimony. A_ I would like to answer that question, as well as alt of your other questions, Mr. Edwards, however today my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Can you tell the jury what, if anything, Seott Rothstein has to do with the allegations off you molesting underage children? MR. PIKE: Form, A Though I think the jury will find out what Scott Rothstein has to do with all these cases, 1 hope that's the case. T have been | instructed by my counsel to respond to all of your questions, most of your questions here today, but { have to assert my Sixth, Fifth and Fourteenth Amendment. MR. EDWARDS: More to strike the portion, of nonresponsive related to Scott Rothstein. Q is it true for the better part of two decades you have interacted sexually with i underage minors on a daily basis? | I i MR. PIKE: Form. A_ I would like to answer every one of your questions here today, Mr. Edwards, especially | we Coot neew 443 that one, however, upon advice of counsel they've: instructed me that | must assert iny rights under the Sixth, Fifth and Fourteenth Amendment, and i I don't do so, I risk losing that representation. Q What is special about the question of you molesting children on a daily basis for the better part of two decades, that you would especially like to answer that question? MR. PIKE: I'm sorry? MR, EDWARDS: His answer was that he would especially like to answer that previous question and the question posed to him was... Q Isn't if true for the better part of two decades you have molested children on an ever day basis. And I'm asking now, what is it about that question that makes you especially want to} respond to that one? MR. PIKE: Form. A. Though | would like to answer that question as well as your other questious here today, Mr. Edwards, upon advice of counsel, they've told me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment, or risk losing my representation, Q Is it true that you have intentionally preyed on vatnerable children as young as 12 years old on an every day basis, for sexual purposes for the last decade? MR. PIKE: Form. A Though I would like to respond to that question, as weil as other questions posed by you,, and f would prefer to respond to both you and your partner, Scott Rothstein, who sits in jail for fabricating questions of a sexual nature, cases of a sexual nature against people like me and others in South Florida. You were part of a law firm that the U.S. Attorney refers fo as one of the largest criminal enterprises in South Florida’s history, so though I would like to answer, and you will probably mark my question] as nonresponsive, my counsel has told me today I must not answer that question and must assert my Sixth, Fifth and Fourteenth Amendment right. MR. EDWARDS: Move to strike the answer as nonresponsive. All other portions portion of the answer, all but the invocation of the Fifth Amendment, Q Please describe for the jury the plan or scheme that you employed to access the underag, 28 (Pages 441 to 444) U.S. Legal Support (561) 835-0220

445 25 minor females of Palm Beach County, including Fane Doe. MR. PIKE: Form, | A I would fike to answer that question as I would like to have answered most of your other | questions here today, especially with respectto | Jane Doe, as she is your client, but on advice of counsel they've instructed me that } must, must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right, so therefore that's what I'm going to do. Q Despite your preference you're going to listen to your counsel, | MR, PIKE: Form, I'm going to instruct you not to answer that question. MR. EDWARDS: As to whether or not he is going to listen to counsel? 1 MR. PIKE: He's already invoked on advice of counsel. | MR. EDWARDS: That last question was | taken right out of Bob Critton's play book. | MR, PIKE: Take it up with the Court. Bob Critton is not here, J am. Q Isn't it true as part of the plan to access young girls between 12 and 17 years old Palm Beach County, that you would send a message that you would be willing to pay those females for them providing you a massage at your house? MR. PIKE: Form. A Youhave to repeat the question. Q Sure. The initiation, the manner in which you gained access to underage girls between, the ages of 12 and 17 in Palm Beach, is that you would initially have somebody tell them that they could come to your house and give you a massage and you would pay them for their time, MR, PIKE: Form. THE WITNESS: It is not a question. A. You didn't ask me a question. You made a statement, | THE WITNESS: If you want to repeat it back. dicating the court reporter.) Q I'll make it clearer for you. A. Thank you. Q Did you send a message to various underage minor females, that you would pay for those underage minor females to provide you a massage at your house? | MR. PIKE; Form. i 25. ORI wWH 10 12 43 14 1S 16 17 18 13 20 21 22 23 24 25 A Though J would like to answer that question, as well as all the other questions you've posed here today, Mr. Edwards, upon advice of counsel, they've instructed me | must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q With each and every underage minor female that arrived at your house under the idea they were to give you a massage, they were first led up and left alone in your bedroom with you; is that correct? MR. PIKE: Form. A Again? Repeat the question, Q This is a scheme that you've employed for years and years, and years, and somehow you're having a hard time grasping how a schema that you devised worked? MR. PIKE: No. Move to strike. You don't have a question on the table. Actually your previous question prior to what you just stated did not involve any word, quote, "scheme," end quote. Ifyou ‘want to repeat the question, go ahead. Q Isn't this how it worked, that an underage minor female would come fo your hous and you instructed or did you instruct Sarah Kellen or one of your other assistants to lead that minor female up to your bedroom to be left] alone with you? MR. PIKE: Form. A Though I would like to answer that question as well as afl the other questions you've posed here today, Mr. Edwards, upon advi of my counsel they've instructed me f must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Once that underage minor female, normally between the ages of 12 and 17 would arrive in your bedroom, you would then appear| naked or wearing only a towel each time; is that] correct? MR. PIKE: Form. A. I would like to answer each one of your questions, Mr. Edwards, However, today my counsel has advised me that I must assert my tights under the Sixth, Fifth and Fourteenth Amendment, Q After appearing naked or wearing only a towel, then wouldn't you instruct the underage minor female to get naked herself? 29 (Pages 445 to 448) U.S. Legal Support (561) 835-0220

MR. PIKE: Form, A. Though I would like to answer all of your questions here today, I'm going to have to respond to that question as I've responded to most of your others here today, which is by my counsel's instructing me that F must assert my rights under the Fifth, Sixth and Fourteenth Amendment. Q Then, once the underage minor female wat naked, you would attempt various lewd or lascivious improper sexual acts against that underage minor female, correct? MR. PIKE: Form, A. Though I would like to respond to all of your questions, Mr. Edwards, | have to respond to that as | responded to all of the other questions here today that you've posed, which is that my counsel, at least today, has instructed me I must | assert my rights under the Sixth, Fifth and Fourteenth Amendment. | Q And you would always pay cash money to; the underage minor female after you improperly] and/or illegally sexually abused that underage | minor female, correct? MR. PIKE; Form. 450 A. Though J would like to answer each and every one of your questions here today, Mr. Edwards, my counsel has advised me 1 must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Each of these sessions or sexual interactions between you and underage minor i females ended, when you had ejaculated, correct? MR, PIKE: Form, j A_ I would like to answer that question, as [ would like to answer all of your other questions here today. However, today at least, my counsel has instructed me that f must assert my rights under the Sixth, Fifth and Fourteenth Amendment. | Q After paying the underage minor female { for being sexually molested, you would ask the i underage minor female fo leave her telephone number with one of your assistants; is that correct? MR. PIKE: Fonn, A. I would like to answer that question. 1 would like to answer most of your other questions here today; however, at least today my counsel has advised me that I may not, and must assert my 451 tights under the Fifth, Sixth and Fourteenth. Amendment os, in fact, potentially lose my right to representation. Q What you're saying with that answer is that your counsel will not represent you anymord if you choose to waive your Fifth Amendment rights and begin to answer these questions? MR. PIKE: No, not at all. On the advice of counsel, if you know what the Sixth Amendment is and how it reads, you would understand what the invocation is, in full. So move to strike your ~ MR. EDWARDS; Question? MR. PIKE; -- last question, and it mischaracterizes the witness's testimony. Do you know what the Sixth Amendment is, Mr, Edwards? MR. EDWARDS: Yes, and it is not my deposition and I'm not sure your client knows about the effective assistance of counsel or any amendment ~ MR. PIKE: Do you know how due process clause affects the 6th Amendment? Never mind, just go ahead. I'm sorry. MR. EDWARDS: However, the statement 452 made if he answers the questions, as he would prefer to do, which seems remarkable and incredible, then he would be fired or you would be fired from him, and I want to understand what it... Q Why is it that your attorneys will no longer represent you if you choose to do what yo want to do, which is answer these questions? MR, PIKE: Move to strike. Do you want to ask a question? Because T'm not quite sure he even testified to that. We have been through several depositions and you are implying something from the invocation of the Fifth, Sixth and Fourteenth that does not exist. There has been no mention of firing, there's been no mention of withdrawing, there's been no. mention of anything of the sort. MR. EDWARDS: Can we go back to the question and response that ended with "l risk losing my...” THE COURT REPORTER: Certainly. MR. PIKE: Once again, do you know that the Sixth Amendment is? MR. EDWARDS: Yes. 30 (Pages 449 to 452) U.S. Legal Support (561) 835-0220

453 1 MR. PIKE: Would you like to Google it? 2 Because that Sixth Amendment -3 MR. EDWARDS: She will have a hard timé 4 going back, if you continue talking, She 5 has to type while you talk. 6 MR, PIKE: The Sixth Amendment, as 7 incorporated into the due process clause, 8 which is the Fourteenth Amendment is the 9 tight to effective assistance of counsel. 10 MR. EDWARDS: I understand, | iL MR. PIKE: Ifyou read it in full, it 12 will kind of shed light and you can probably 13 glean the invocation and the meaning of it 14 from his response, 15 Is there a question? i 16 MR. EDWARDS: Go back, please. | 17 (The record was read.) 18 Q So your counse! told you that you must 19 invoke your Fifth Amendment right to remain 20 silent, otherwise you will lose your right to aL their representation; is that what you're 22 saying? 23 MR. PIKE: Move to strike. 24 Mischaracterizes the witness's testimony, 25 and invocation... misconstrues and 2 misinterprets the Fifth, Sixth and 2 Fourteenth Amendments, 3 I'm going to instruct you not to answer 4 that question, because [ don't understand | 5 it. It was not your response, and 6 because -a MR, EDWARDS: I wrote down the response 8 MR. PIKE: -- and because, if t 9 understand, your question, you phrased it 0 1 as, "So if] understand you, your attorney iL told you," so I'm going to instruct you not a2 to answer that question because it will, 13 apparently, it would disclose my 14 communications with you, so there you go. 1s MR. EDWARDS: In his answer he said, “M; 16 counsel said | can't respond,” so he is WW telling me already what -— 18 MR. PIKE: That's not what he said. He 19 said "On the advice of counsel." 20 MR. EDWARDS: All right, | 21 Q The offer was then made to each underay 22 minor female that each time she returned to you! 23 home and you sexually molest her, she will then 24 be paid cash; is that correct? 25 MR. PIKE: Form. 25 may counsel has instructed me I must assert my A Though I would like to answer that question as well as all the other questions you've posed here today, Mr. Edwards, !'m afraid that upon advice of counsel they've instructed me that I must assert my tights under the Sixth, Fifth and Fourteenth Amendment. Q Anda separate offer was made to each underage minor female as well. That is, if she brings you other underage minor femaies so thal you can sexually abuse, then you would pay a finder’s fee for each underage minor female brought to you; is that correct? MR. PIKE: Form, A_ I would like to answer every one of the questions you've posed here today, Mr. Edwards. However, today at least, upon advice of counsel, they have instructed me ] must assert my rights under the Sixth, Pifth and Fourteenth Amendment. Q Haley Robson was a female that brought you multiple underage minor females; is that correct? MR. PIKE: Form, A Though I woutd like to answer every one of your questions that you've posed here today, 456 rights under the Sixth, Fifth and Fourteenth Amendment, Q LM. was an underage minor female that you first abused when she was 13 years old; is that correct? MR. PIKE: Form, A Though I would like to answer every question you have regarding L.M. here today, my counsel has instructed me that I must assert my tights under the Sixth, Fifth and Fourteenth Amendment. Q While L.M. was a minor, she brought you more than 50 underage minor females that you sexually abuse, correct? MR. PIKE: For. A_ I would like to answer all the questions ‘you have regarding L.M., here today. However, at least taday my counsel has instructed me I may not, I must assert my right under my Sixth, Fifth and Fourteenth Amendment. Q One of the underage minor females brought to you by L.M. was Jane Doe, when Jan: Doe was age 14; is that correct? MR. PIKE: Form. A_ I would like to answer the questions 31 (Pages 453 to 456) U.S. Legal Support (561) 835-0220

regarding Jane Doe and L.M.; Mr. Edwards. However, at least today my counsel has instructed| me { must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Looking at the operative complaint in Jane Doe versus Jeffrey Epstein case 80893, referring to the plaintiff Jane Doe, first indicates this is an action for damages in an amount in excess of 50 million dollars. Is that a number that you would agree would fairly compensate her, as well as punish you for the conduct you committed against Jan Doe? MR. PIKE: Form. A I would like to answer that question. T would like to answer all of your other questions that you've posed here today, Mr. Edwards, However, at least today, on advice of counsel they've instructed me that I may not and have instructed me that ] must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q One of the allegations Jane Doe makes is, that Jeffrey Epstein demonstrated sexual preference and obsession for minor girls. Is it true that you have a sexual preference and 458 obsession for minor girls? MR. PIKE: Form. A I would like to answer the question with respect to what Jane Doe said, however, my counsel today has instructed me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Another allegation is that defendant Epstein's planned scheme and enterprise include: an elaborate system wherein the then minor plaintiff and other minor girls were contacted by} telephone by Epstein, Sarah Kellen or other | unknown employees or assistants working for | Epstein, and were then persuaded to come rid Epstein's house for the purposes of engaging in prostitution. Is that a true statement? | MR. PIKE: First, I'm going to object to i the form and second, I believe you're | working from a portion of a complaint especially with your reference to scheme and | the RICO allegations that were dismissed with prejudice, So, I just want to be clear, are you doing discovery on a count that no longer exists’? 459 MR. EDWARDS: No, !'m asking if your client agrees with the assertion that's stated in the complaint, or if he has a defense that is going to defeat such assertion or evidence that is going to defeat such assertion. So I'm simply asking your client... Q Is that a true statement? MR, PIKE: Form. A_ I would fike to answer all of your questions about Jane Doe and your other clients. However, today my counsel has told me that I may not, | must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q You did personally call Jane Doe on the telephone on at least one occasion; isn't that true? MR. PIKE: Form. A_ I would like to answer your questions regarding calling Jane Doe, or contacting Jane Doe. However, my counsel has instructed me the today, at least, | may not. 1 must assert my tights under the Sixth, Fifth and Fourteenth Amendment. Q And at the time when you contacted Jang 460 Doe, was the purpose to have her come fo your house and interact with you sexually? MR. PIKE: Fonn. A Can you repeat the question? Q Yes, the time that you called Jane Doe, was the purpose of your call fo have her come to your house and interact with you sexually? MR, PIKE: Form. A_ [would like to answer that question as T would like to answer all of yous other questions with respect to Jane Doe, your client. However, today at least, my counsel has instructed me [ must assert my rights under the Sixth, Fifth and Fourteenth Amendment. MR. EDWARDS: Move to strike a portion of the answer that's nonresponsive. @ Sarah Kellen was one of your assistants back in the years 2003, 2004 and 2005, correct? A. [would like to answer each one of your questions, Mr. Edwards, here today; however, on advice of counsel, at least today I'm going to. have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Sarah Kellen called by telephone Janc Doe when Jane Doe was a minor child, on more thap 32 (Pages 457 to 460) U.S. Legal Support (561) 835-0220

OR INAH RW 10 11 12 13 14 15 16 7 18 19 20 2. 22 23 24 25 OO IHW BW 10 1. 12 13 14 15 16 17 18 19 20 2 22 23 24 25 15 occasions; isn't that true? | MR. PIKE: Form. | A. Mr, Edwards, I would like to answer | cvety one of your questions regarding Jane Doe | that you've posed here today. However, at least | today, on advice of counsel I'm going tohave to | assert my tights under the Sixth, Fifth and i Fourteenth Amendment. ij Q The purpose of Sarah Kellen contacting | the minor child Jane Doe back in 2003, 2004 and 2005, was always to get her to come to your hous? to interact with you sexually; is that correct? MR. PIKE: Form. AT would like to answer that question as well as all your other questions you've posed here today regarding your client, Jane Doe. However, at least today, my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Did you or Sarah Kellen or any of your other assistants contact Jane Doe for some other purpose than to have her come to your house for you to sexually molest her? MR. PIKE: Form. A. Though [ would like to answer every 462 question that you've posed here today regarding Jane Doe, Mr. Edwards, my counsel has advised me, at least today, that I may not and must assert my rights under the Fifth, Sixth and Fourteenth Amendment, Q Each cail that was made by you or on your behalf to Jane Doe, was made at a time when Jane Doe was a minor child, true? MR. PIKE: Form. A_ I would like to answer that question as well as all your other questions with regard to Jane Doe, Mr. Edwards, However, today my counsel has advised me 1 may not and must assert my t rights under the Sixth, Fifth and Fourteenth Amendment. Q In addition to your Palm Beach home, isn't it true that you own a, what has been called a mansion in New York, a ranch in New Mexico, a home in France, as well as an island in the Virgin Islands? MR. PIKE: Form, A I'm sorry, but today at least, on advice of counsel I have to assert my rights to the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true that you traveled by way i i | i | | { | Snr aAHnone 10 ai 12 13 14 15 16 17 18 19 20 21 22 23 24 25 OI ge ewne 9 10 a1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 163 of your private airplane to Palm Beach for the specific parpose of luring minor girls to your mansion for the purposes of sexually abusing them? MR. PIKE: Form. A I would like to answer that question, Mr. Edwards,, but today at least, on advice of counsel, they've instructed me to assert my Sixth, Fifth and Fourteenth Amendment rights. Q Isn't it true that you conspired with others fo contact minor females including Jan: Doe, for the purposes of sexually abusing Jane Doe? MR. PIKE: Form. A. I would like to answer that question, Mr. Edwards, as well as every other question you've posed here today. However, at least today upon advice of counsel they've instructed me to assert my Sixth, Fifth and Fourteenth Amendment right. Q Isn't it true that your sexual interaction with Jane Doe occurred specificall during the time period, February 2003 throug! June 2005? 464 A I'm going to have to respond to that, ‘Mr, Edwards, as I've responded to all your other questions, which is that today at least on advice of counsel I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q During the time Jane Doe was under thef age of 16, isn't it true that you digitally penetrated her vagina? MR. PIKE: Form. A_ I would like to answer that question, as well as your other questions. However, at least today my counsel has advised me I must assert im rights under the Sixth, Fifth and Fourteenth Amendment. Q Immediately following that question, you clearly smiled and rolled your eyes. Is there anything that we should read or the jury shou! read into that body language? MR. PIKE: I'm going to instruct you not to answer the question. T move to strike it as harassing. MR. EDWARDS: Move to strike what as harassing? It is something that everybody is going to be able to see and I want to know what it means, if anything. 33 (Pages 461 to 464) U.S. Legal Support (561) 835-0220

MR. PIKE: I'm instructing him not to answer. MR. EDWARDS: How are you instructing not to answer a question? MR, PIKE: Because I am. MR, EDWARDS: Based on what? MR. PIKE: Because it is harassing. MR. EDWARDS; I'm not harassing, 1 want to know why he did what he did, MR. PIKE: You are harassing him. 1 mean, it is an argumentative question -~ { MR. EDWARDS: He harassed my clients. MR, PIKE: -- he has been hete since | 10:00 o'clock. He's given several depositions. This is Volume III of a continuation, okay? He's sitting here waiting for your questions but not waiting to be harassed. Q There is a way to prevent those questions, and that's not de that type of rolling! your eyes, MR, PIKE: You're not going to instruct the witness on how to -- the witness is here behaving professionally — MR. PIKE: -- Answering your questions, invoking his Constitutional rights under the United States Constitution. And I'm sorry that that doesn't make you happy, but f'm not here -= MR. EDWARDS; It doesn't make him happy either, apparently. MR. PIKE: -- I'm not here to dispute and debate with you what privileges are being invoked and whether you feel it is } right or wrong. If you have a question, ask t the witness a question. { Q Why did you roll your eyes when f asked | you if you digitally penetrated Jane Doe when shb was 14 and 15 years old? } MR. PIKE: I'm instructing you not to ! answer that question. MR. EDWARDS: Your reason for the instruction is based on some privilege? MR. PIKE: My reason for the instruction is that you are attempting to play fast and loose with the Fifth Amendment and adverse inference. i MR. EDWARDS: I'm not. MR. PIKE: Yes, you are, and I'm not i WORIHUAWNHE 467 going to let it happen, not on my watch, not today. You can take it up with the Court. MR. EDWARDS: | will. MR. PIKE: Mark the record. Ifyou will, MR. EDWARDS: It is marked. I'm just wondering whether there is going to be a privilege asserted or it is just going to be a blanket, "I'm telling the witness not to answer,” related to something that the jury is going to view and should be entitled to know what it means, MR, PIKE: (Counsel shrugs.) MR. EDWARDS: You just don't like th: your client is giving those body language responses. MR. PIKE: No. Move to strike. It has nothing do with that. It has to do witha significant fact, that on a legal basis you're attempting to badger and harass the witness, based upon what you believe are some sort of facial expressions and you're attempting to get an adverse inference from an answer. I'm not going to let him answer 468 adverse inference relative to some gesture. MR, EDWARDS: We will take it up, fine. MR. PIKE: ‘Take it up. Q Mr. Epstein, isn’t it also true that you used a vibrator or vibrating device on Jane Doc’ vagina when she was under the age of 167 MR. PIKE: Form. A Ewould like to answer all of your questions, Mr. Edwards. However, today on advi of counsel, they've advised me that I may not and must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it also true when Jane Doe was a tinor child, that you masturbated on multiple occasions in her presence? MR, PIKE: Form, A I would like to answer all of your questions regarding Jane Doe. However, today my counsel has advised me that I may not, and have instructed me to assert my rights under the Siath, Fifth and Fourteenth Amendment, Q In June of 2008, isn't it true, sir, that you entered pleas of guilty to various felony ~ to two felony charges in Palm Beach County? 34 (Pages 465 to 468} U.S. Legal Support (561) 835-0220

15 16 17 18 19 20 21 10 1. 12 13 14 1s 16 7 18 19 20 21 22 23 24 25 469) MR. PIKE: Asked and answered within this deposition. A Yes. Q And as a result of those guilty pleas you were sentenced to 18 months incarceration in Palm Beach County jail; is that correct? i MR. PIKE: Asked and answered. A Yes. : Q In addition to the sentence related to those felony charges, isn't it also true that you entered into an agreement known as the “Nonprosecution Agreement,” with the federal government? MR. PIKE: I'm sorry, would you read that back, Madam Court Reporter? (The record was read.) MR. PIKE: Can you reword the question? MR. EDWARDS: Sure. | Q Did you enter into an agreement with the | federal government that is entitled | "“Nonprosecution Agreement"? | A Yes, | Q And that Nonprosccution Agreement at | paragraph 7 indicates that "The United States | Epstein's attorneys with a list of 470 individuals whom it has identified as victims, as | defined in 18 USC 2255, after Epstein has signed this agreement, and been sentenced.” Have you seen the names of the identified victims that were supplied by the U.S, Attorney's office? A_ I would like i answer that question as TE would like to answer most of your other questions here today, Mr. Edwards. However, pop advice of counsel they've instructed me that 1 must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q And isn't it true that Jane Doe was on that list of victims that was supplied to you by the United States? A_ I would like to answer that question, 1 However, at least today my attorneys have advised me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q In paragraph eight of the Nonprosecution Agreement between you, Mr. Epstein, and the United States Attorney's Office, it indicates, “If any of the individuals, referred to in paragraph 7,” referring to the list of victims, “elects to file a lawsuit pursuant io 18 USC 2235, Epstein waives his right to contest i COI anneune 25 U.S. ability"? Are you familiar with that section of the agreement? MR. PIKE: Form, and the document speaks for itself. A The document speaks for itself. Q Are you familiar with that portion of the document? A. I'm not sure what you mean by “familiar with," sir, Q Have you read it? A Yes. Q So, if Jane Doe were to bring a claim exclusively under 18 USC 2255, then you alrea contractually agreed to waive your right to contest liability to that claim; is that true? MR. PIKE: Form, and calls for a legal conclusion. A_ Upon advice of counsel, though | would like to answer all of your questions here today, they've instructed me I must assert my rights. under the Sixth, Fifth and Fourteenth Amendment. THE WITNESS: Five minutes? MR. EDWARDS: Whatever you need. 472 THE VIDEOGRAPHER: Going off the video record 1:51 p.m. {Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video record 1:57 p.m, Q The specific federal statute that is incorporated in the Nonprosecution Agreement, 1: USC 2255, states -- rather than do it that way, let me just ask the question. Mr, Epstein, did you knowingly conspire with others to use a telephone to persuade, induce or entice minor females, including Jane Doe, to engage in prostitution? MR. PIKE: Form, A_ Though I would like to answer that question, as most of your other questions, [ have to respond by telling you that my attomeys have told me, at least today, that } must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Mr. Epstein, did you knowingly and willfally conspire with others to travel interstate for the purpose of engaging in illicit, sexual conduct with minors, including Jane Doe? MR. PIKE: Form. 35 (Pages 469 to 472) Legal Support (561) 835-0220

Ww OIHN HM hRwne ORAHRE WHE 10 aL ae 13 14 15 16 aT 18 19 20 21 22 23 73) A Though I would like to answer that “i question, as well as most of your other questions here today, Mr. Bdwards, in fact, all of the | other questions here today, my counsel! has | instructed me at least today, F must assert my tights under the Fifth, Sixth and Fourteenth Amendment. Q Mr. Epstein, did you use a telephone to knowingly persuade, induce or entice minor females, including Jane Doe, to engage in prostitution? MR. PIKE: Form, A Though I would like to answer that question, as wel] as your other questions today, Mr, Edwards, at least today, my counsel has | instructed me that I must assert my rights under | the Sixth, Fifth and Fourteenth Amendment. | Q Mr. Epstein, did you travel, interstate { commerce for the purpose of engaging in illicit sexual conduct with minor females, including Jai Doe? MR. PEE: Form, A_ Though I would like to answer that question, as well as the other questions youve counsel has instructed me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn't it true that you agreed with the federal government that if Jane Doe brought claims exclusively alleging those sections of 18 j USC 2255 that I've read in the preceding, four | paragraphs, that you would admit liability unto j | her as an identified victim? MR. PIKE: Form. A. I don't believe that's what the document says, Q The document says, “if any of the | individuals referred to in paragraph 7 elects to file suit pursuant to 18 USC 2255, Epstein waives his right to contest liability, and also waives | his right to contest damages up to an amount as | agreed to between the identified individual and | Epstein, so long as the identified individual elects to proceed exclusively under 18 USC i 2255." That's the provision. I'l ask you then the question: Didn't you agree with the federal | government that if Jane Doe, an identified victim, proceeds in a case against you, i wor AKneune 10 12 13 14 15 16 at 18 19 20 475 exclusively under 18 USC 2258, that you waived your right to contest liability? MR. PIKE: Form. Also, could call for the disclosure of attorney/client communications and work product, and is protected under the Federal Rule of Evidence 502408, as well as 410? A Though I would like to answer that question, Mr. Edwards, I have to invoke my rights under the Sixth, Fifth and Fourteenth Amendment. Q Ina recent motion for summary judgment filed on your behalf, 2 statement is made, "Epstein never using a facility or means of interstate commerce, knowingly persuaded, indnes or enticed Jane Doe when she was under the age of 18 years, to engage in prostitution or sexual activity for which any person can be charged with a criminal offense or attempted to do so." That is a false statement, true? MR. PIKE: Form. A. Though I would like to answer that question, on advice of counsel I have been instructed to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q The statement was also made on your 476 behalf, "Epstein never attempted to or conspired to knowingly transport Jane Doe in interstate or foreign commerce or in any Commonwealth territ or possession of the United States, with intent that Jane Dee engage in prostitution or in any sexual activity for which any person can be charged with a criminal offense.” That is also a false statement; isn’t that right? MR. PIKE: Form. A. You said “Jane Doe.” Q Jane Doe is Jane Boe in this case, MR, PIKE; Form, A. believe her deposition speaks to that. With respect to anything else, | have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q You betieve that Jane Doe's deposition speaks to whether you attempted or conspired to knowingly transfer Jane Doe in interstate commerce, correct? MR. PIKE: Fonn, Q You believe her deposition speaks to that? A That's my belief, yes. 36 (Pages 473 to 476) U.S. Legal Support (561) 835-0220

477 Q And then would you adopt her deposition testimony as true and as your support for that assertion? MR. PIKE: Form. A You're asking her entire deposition. testimony? Q The deposition as it relates to whether or not you knowingly transported her in interstate commerce, A Well, | would like to answer that question, but on advice of counsel, at least today, I have been instructed to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q A statement that Epstein never attempted te or conspired to travel in interstate commerce| or travel into the United States or travel in foreign commerce for the purpose of engaging in illicit sexual conduct with Jane Doe," is also a false statement, isn't it? MR. PIKE: Form? A_ lL would like to answer that question as well as your other questions, Mr. Edwards. However, today my counsel has instructed me that I must assert my Fifth, Sixth and Fourteenth Amendment right. 478 Q The statement that Epstein never attempted to or conspired to travel in foreign commerce and engage in any illicit sexual conduct with Jane Doe, is also a false statement; isn't that right? MR. PIKE: Form, A T would like to that question as well as the other questions posed today, Mr. Edwards. However, on the advice of counsel they've instructed me fo assert my Sixth, Fifth and Fourteenth Amendment right. Q In fact, you did contact Jane Doe when she was a minor child as well as conspired to use a telephone to contact Jane Doe when she was a minor child, specifically for the purposes of engaging in illicit sexual conduct with Jane Doe, true? MR. PIKE: Form. A Though I would like to answer that question as well as your other questions posed here today, Mr. Edwards, I have been instructed by my counsel thet I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Did you intentionally touch Jane Doe on her person and against ber will or without her legal consent? MR, PIKE: One second... Form. A Without her legal consent? Q Yes. A Can you tell me what that means? Q Ia order to answer that question, I need te explain to you what legal consent means? A Yes, sir. Q Let's start with this question -A Can you explain it to me? Q Do you believe that a 14-year old child can legally consent to sexual interaction with a} man like you that was over the age of 50? MR. PIKE: Form, THE WITNESS: Asking for a legal... MR. PIKE: Go ahead and invoke? A I would like to answer that question, if L understood it correctly. However, my attorneys have advised me today at least to invoke my Sixth, Fifth and Fourteenth Amendment right, MR. PIKE: And J think you skipped over a question because you went from the first question, and the witness was ~MR. EDWARDS: Asking for a definition? MR. PIKE: Asking for a definition, so 480 he could properly interpret your question and attempt to answer it. Q I'm understanding that, based on your answer, that my question, “Did you intentional touch Jane Doe without her legal consent?" And your response, depends on the definition of “legal consent;" is that true? MR, PIKE: | think that the witness -as people regularly do as deponents, ask for clarification of a question, and Mr. Epstein asked you to clarify what, “legal consent" was. [fyou wish to do that, then I guess he could potentially understand your question. However, if you don’t want to do that, then I guess we can just move on, Q This will provide the answer: How old was Jane Doe when you touched her? MR. PIKE: Form. Assumes facts not in evidence. A [-- 1-1 don't know how to answer that question. I'll have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment right. Q Tell me why you're having trouble answering the question and F'll clarify the 37 (Pages 477 to 480) U.S. Legal Support (561) 835-0220

OR taAHewWne 16 il 12 43 14 15 16 uy 18 is 20 od 22 23 24 25 481 question for you so it will be easier for you to answer. MR. PIKE: You've answered the question. MR. EDWARDS: His response was he doesn't know how to answer the question, 1 want to help him. I want to make sure that | the jury understands the question and the i answer, | MR. PIKE: He invoked the Fifth, Sixth and Fourteenth. Q Mr. Epstein, did you touch Jane Doe in intimate areas of her body when she was a minor child? MR. PIKE: Form. A. I would like to answer that question, all your questions with respect to Jane Doe, Mr. i Edwards, However, today at least, my counsel has advised me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q In fact, didn't you touch Jane Doe in intimate areas of her body, including her vagina, her breasts, and her buttocks on dozens of aceasions between February 2003 and June 2003! MR, PIKE: Form. i t | 482 A. Though I would like to answer every question about Jane Doe that you've posed here today, Mr. Edwards, upon advice of counsel, at jeast today, they've instructed me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Do you agree that the inappropriate sexual conduct, that your inappropriate sexual conduct towards Jane Doe, was both extreme and outrageous? MR. PIKE: Form, A_ | would Jike to answer all of your questions with respect to Jane Doe that you've posed here today, Mr. Edwards. However, upon | advice of counsel, they've instructed me that f must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Do you also agree that your sexual interaction with Jane Doe when she was a minor child was outrageous and so extreme in degree | that it should not be tolerated in a civilized community? i MR. PIKE: Form, A_ I would like to respond to all your questions with respect to your client, Jane Doe, 483 However, at least today, my counse] has instructed me | must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Do you see yourself, Mr. Epstein, as a danger to the middle school and high schoo! children in the Palm Beach community? MR. PIKE: Form. A Though I would fike to answer that question, as well as the other questions that you've posed here today, Mr. Edwards, my counsel: has instructed me { must respond by asserting my rights under the Sixth, Fifth and Fourteenth Amendment, Q When you engaged in illegal sexual conduct with Jane Doe, was it your intent to cause her severe emotional distress? MR. PIKE: Form. A Though | would like to answer every question with respect to Jane Doe, Mr. Edwards,, at least today my counsel has advised me that [ must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q When you engaged in sexual conduct witl Jane Doe when she was @ minor child, age 14, 1: 16 and 17, would you agree that you showed 484 reckless disregard with the high probability of causing severe emotional distress to Jane Doe? MR. PIKE: Form. A. Though [ would like to answer aff your questions that you've posed here today regarding Jane Doe, on advice of counsel, at least today, they've instructed me I nrust assert my rights under the Sixth, Fifth and Fourteenth Amendment! Q Mr. Epstein, did you coerce Jane Doe into prostitution? A ... Again? Q Did you coerce Jane Doe into prostitution? A Can you tell me what you mean by “coerce,” please? Q Tellme, baw did you — A I've asked you a simple question. Can you telf me what "coerce" means, please? Q The definition of the word "coerce" will allow to you answer that question? A_ i'm trying to understand the question. MR. PIKE: You're using -- for the record, you're using i¢gal terms. "Consent," "coerce." Those are the terms you're utilizing in your question. Mr. 38 (Pages 481 to 484) U.S. Legal Support (561) 835-0220

485 Epstein is simply asking you what those terms mean in order to facilitate a response | or 4 response coupled with the invocations. | He doesn't -- he is not a lawyer. He doesn't understand these legal terms, and he is asking you for clarification. If you want to take those legal terms out of your questions and simplify them, then go ahead and do that, but it is fair that he ask what certain words mean, MR. EDWARDS: | absolutely agree and want to make sure before | give him the ' definition, that this question is being asked because the definition will help him to accurately answer the question, assuming that would be the only reason he would ask me a question. MR. PIKE: As his lawyer, I think that the definition of the word would assist him in understanding the question a little bit better, because, as you know, "coerce" and "consent" have several meanings, whether on not it be in State court, under the Florida State statutes or under federal statutes under 2255. | think that any sort of | 4186 response could, you know... tiptoe into the Fifth, Sixth and Fourteenth, and 1 think Mr. Epstein is attempting to... understand your questions. MR. EDWARDS: 1 appreciate that. I feel like we're getting closer to an answer than we have received during this entire litigation, so I'm certainly going to help him out here. Q Mr. Epstein, do you then at least agree that you paid Jane Doe money in exchange for sexual services when she was under the age of 18? MR. PIKE: Form, mischaracterizes the witness's testimony, and move to strike. A. Unfortunately I have to answer that question as I've answered most of your other questions here today, Mr. Edwards, which is that + my attorneys, at least today, have advised me that J must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Mr, Epstein, how did you, meaning what process did you go through, to get Jane Doe to exchange your money for her sexual services when she was under the age of 18? wOrnaoeune 1 2 3 4 & 6 7 & 487 MR. PIKE: Form. A | would like to answer every one of your questions with respect to Jane Doe, Mr, Edwards. However, today, my counsel has instructed me that I must assert my tights under the Sixth, Pifth and Fourteenth Amendment. Q Ifyou answer that question for me, then Lean tell you whether that fails under the definition of coercing her into prostitution. A Is that a question? Q Sure. Can you provide an answer to the previous question, so [ can categorize that as coercion or noncoercion? MR. PIKE: No, he cannot, because I don't know what question is on the table, and it is as simple as that. [ don't know what question is on the table. MR. EDWARDS: Sure. Q Didn't you interact with Jane Dee ina sexual manner when she was under the age of 18' MR. PIKE: Object to the form. This question has been asked no less than twice during your deposition MR. EDWARDS: F'll agree with that. MR. PIKE: -- relative to Jane Doe and 488 Tl object to the form. A_ I would like to answer all of your questions, Mr. Edwards, especially that question, However, today, my counsel has advised me that | must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Did you persuade, induce or entice Jane Doe to engage in prostitution when she was an underage minor child? MR. PIKE: Form. A [would like to answer that question but my counsel has advised me I must respond by invoking my Sixth, Fifth and Fourteenth Amendmedt tight, Q Can you tell the jury how itis that Jane Doe engaged in an act of prostitution with. you? MR. PIKE: Form. A On advice of counsel, I'm going to have to invoke my Sixth, Fifth and Fourteenth Amendment right. Q While you were interacting with Jane Doe in a sexual manner when she was 14 and 15 yea old, did you consider that molestation? MR. PIKE: Form. 39 (Pages 485 to 488) U.S. Legal Support (561) 835-0220

489) A I would like to answer al] of your questions, Mr. Edwards, with respect to Jane Doe and her complaint. However, at least today my + counsel has advised me that I must assert my tights under the Sixth, Fifth and Fourteenth Amendment. Q While, at the same time you were molestiag Jane Doe, didn't you tell her that yo liked the way her young body looked? MR, PIKE: Form. A_ I wouid like to respond to all your questions regarding Jane Doe, is the point, Mr. Edwards. However today at least my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. THE VIDEOGRAPHER: Counsel. (Indicating five minutes feft on tape.) | MR. EDWARDS: Okay. i Q Mr. Epstein do you know George Rush? MR, PIKE: Form -- I'll withdraw the form. I'm sorry. [t is not a proper form objection. A. I'm sorry, on advice of counsel I have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. 490 @ Did you talk to George Rush in the year 2009 about the allegations of improper sexual conduct between you and underage minor children MR. PIKE: Can you repeat the question, | for me, Madam Court Reporter? | MR. EDWARDS: I can ask it again. MR. PIKE: Sure. Q Did you speak with George Rush in 2009 specifically about allegations of your interaction with underage minor children in a sexual manner? A On advice of counsel, I'm going to have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Did you know that the conversation between you and New York Daily News reporter George Rush was recorded? MR. PIKE: Form. A On advice of counsel, I'm going to have to assert my right under the Sixth, Fifth and Fourteenth Amendment. Q At the time when you spoke with George Rush from The New York Daily News in 2009, did he tell you that he was recording your statements to him? MR. PIKE: One second... Form. A_ On advice of counsel, I'm going to have to respectfully assert my Sixth, Fifth and Fourteenth Amendment right. Q During that conversation that you had with George Rusk from The New York Daily New: didn't you express to him that you felt you were punished criminally for no reason? MR, PIKE: Form. A Though I would like to answer all of your questions, Mr. Edwards, my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Didn't you also tell George Rush that a more appropriate punishment for your actions wi these underage minor children would have been a 100 or $200 fine? MR. PIKE: Form. A On advice of counsel J have to assert my tights under the Sixth, Fifth and Fourteenth Amendment, Q Tell the jury what you feel would be an appropriate penalty for you, for the acts that you committed against Jane Doe. MR. PIKE: Form. 492 A. Though I would like to very much answer that question, on advice of my counsel today, Mr. Edwards, | have to invoke my Sixth, Fifth and Fourteenth Amendment right. Q In your Affirmative Defenses in the complaint of Jane Doe versus Jeffrey Epstein, which is Jane Doe, affirmative defense number on indicates that Jane Doe consented to and was a willing participant in the acts alleged. What evidence did you have that Jane Doe consented to or was a willing participant in the acts that were alleged by Jane Doe against you? MR. PIKE: Form. A Though I would like to describe the evidence that Jane Doc was a willing participant, on advice of counsel today, they've instructed me 1 must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q At that point in time you're at least admitting that there was an interaction between you and Jane Doe, correct? MR. PIKE: Form. Move to strike. A On advice of counsel, I'm going to have to assert my rights under the Sixth, Fifth and Fourteenth Amendment, 40 (Pages 489 to 492) U.S. Legal Support (561) 835-0220

10 aw 12 aa 14 15 16 W 18 13 20 21 22 23 2a 25 493 Q Two answers ago I believe that you just told us that you would like to tell the jury about the evidence that exists, that shows that | Jane Doe consented to or was a willing participant in the acts alleged. So, is there any evidence that you're aware of in existence in| this world that shows that Jane Doe consented te the acts she alleged against you? MR. PIKE: Form. Also calls for work product information? A Unfortunately today I have to respond by asserting my rights of Sixth, Fifth and Fourteenth Amendment, THE VIDEOGRAPHER: Counsel? MR. EDWARDS: Okay. THE VIDEOGRAPHER: Going off the is record 2:34 p.m. (Pause in the proceedings.) (The deposition of Jeffrey Epstein is continued in Volume FV.) 1 UNITED STATES DISTRICT COURT ‘SOUTHERN DISTRICT OF FLORIDA CASE NO, 08-CV-80893-CIV-MARRA/JOHNSON JANE DOE, Plaintiff, ws. JEFFREY EPSTEIN, et al, Defendants, Related Cases: i 08-801 19, 08-80232, 08-80380, 08-80381, } 08-8094, 08-8081 1, 08-80893, 09-80469, | 09-8-591, 09-80656, 09-80802, 09-81092 ; VOLUME IV | CONTINUED VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN TAKEN ON BEHALF OF THE PLAINTIFF DATE: Apdil 14, 2010 Sewminnewne L ii 12 13 14 15 16 17 18 19 20 21 22 23 24 14 18 16 17 18 19 20 24 22 22 24 25 495 THE VIDEOGRAPHER: Back on the video record 2:30 p.m. CROSS EXAMINATION (CONTINUED) BY MR. EDWARDS: Q Mr. Epstein, are you ready? A Yes. Q The second affirmative defense indicates br says that Jane Doe “actually consented to and participated in conduct similar and/or identical to the acts alleged with other persons, which were the sole or contributing cause of Jane Doe's alleged damages.” What facts or information do you have to support that affirmative defense? MR. PIKE: Form, May also call for work product information. A Though I would like to answer all your questions, Mr. Edwards, at least today counsel advised me must assert my tights under the Sixth, Fifth and Fourteenth Amendment. Q And when you say as an affirmative defense Jane Dee consented to and participated i conduct similar and/or identical to the acts alleged, are you saying that at some other time Jane Doe was sexually molested by somebody of 496 similar or identical age to yourself? MR. PYKE: Form, A I would like to answer all of your questions with respect to Jane Doe and her complaints, However, at least today my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q The second part of that affirmative defense indicates that that simitar or identical conduct that Jane Doe allegedly participated in, was the sole or contributing cause of Jane Doe' alleged damages. Are you acknowledging that that conduct is likely to cause damages to a minor child such as Jane Doe? MR. PIKE: Form. A_ I would like to answer all of your questions with respect to Jane Doe and her complaints... complaint. However, at least today my counsel has advised me I must assert my rights] under the Sixth, Fifth and Fourteenth Amendment] Q Are you taking the position that Jane Doe's alleged damages were actually caused by separate or other child molester? MR. PIKE: One second... object to the 41 (Pages 493 to 496) U.S. Legal Support (561) 835-0220

Ww ON wWde 10 11 12 13 14 15 16 7 18 19 20 aL 22 23 24 as Senaraannawne 11 13 14 15 16 1? 18 Fig form. | think you need to reword the question. MR. BDWARDS: Okay, I'll ask it again. Q 1s it your position, or do you have facts or information that Jane Doe was molested by a separate or different child molester? | MR. PIKE; Form, AL would like to answer ail your questions that you posed here today, Mr, Edwards, every last one of them. However, at least today under advice of counsel, I have been instructed I must assert my rights under the Sixth, Fifth and | Fourteenth Amendment. Q The next affirmative defense indicates that Jane Doe impliedly consented to the acts alleged by not objecting. What do you mean by that affirmative ' defense? MR. PIKE: Form, | A_ IT would tike it answer all your questions regarding Jane Doe, and her complaint. However, today my attorneys have advised me that Y must assert my rights under the Sixth, Fifth and Fourteenth Amendment. 498 MR. PIKE: May also call for work. product information, Sorry. Q Do you mean that, for instance, when you would insert your fingers into her vagina when she was 14 or 15 years old, that because she didn't object that she impliedly consented to | that conduct? MR. PIKE: Form. A What's the question? Q Do you mean by -- I'll read your affirmative defense that you have stated. "Plaintiff Jane Doe impliedly consented | to the acts alleged by not objecting,” and I'm asking: By that, do you mean that when you inserted your fingers into her vagina when she was age 14 or 15, that by her not verbally objecting, then in your mind she consented? MR. PIKE: Form. A l would like to answer all your questions Mr, Edwards. However, at least today, at least today, my counsel instructed me ] must assert my rights under the Sixth, Fifth and ! Fourteenth Amendment. Q Your next affirmative defense states that "Defendant," that being you, “reasonably Q Do you mean — i aL 13 is 499 believed or was told that the plaintiff, Jane Doe, had attained the age of 18 years old at the time of the alleged acts." That is a false statement, isn't it, Mr. Epstein? MR, PIKE; Form. A. Lwould like to answer every question you posed today, Mr. Edwards, about Jane Doe ani her complaint. Hewever, at least today my attorneys have advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q What gave you the reasonable belief that Jane Doe was 18 years of age or older when you touched her in a sexual manner? MR. PIKE: Form, A_ lwould like to answer all of your questions with respect to Jane Doe, Mr. Edwards, every one of them. However, today, as you're aware, my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Didn't Jane Doe tell you when you asked her age that she was 15 years old? MR. PIKE: Form. A_ I would like to answer that question ‘because I've answered most of your other 500 questions here today. Unfortunately my counsel here today said I must invoke my rights under the Sixth, Fifth and Fourteenth Amendment. Q The second portion of that affirmative defense is that you reasonably believed or you were told that Jane Doe attained the age of 18. Tell the jury, who told you that Jane Doe had attained the age of 18 years old when yor engaged in sexual conduct with her? MR. PIKE: A Though I would fike very much to answer that question, as most of your other questions here today, as you're aware my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q In fact, if you learned that she had attained the age of 18 ycars old, you would not have engaged in sexual conduct with ker, would you? MR. PIKE: Form. A fwould like to answer all of your questions with respect to Jane Doe, Mr, Edwards, However, at least today, my counsel advised me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Form. 42 (Pages 497 to 500} U.S. Legal Support (561) 835-0220

501 | Q in fact, there were several times when girls were brought to you by other underage minor females and these girls were over the age of 18 | and you turned them away, as being too old for | you; isn't that true? MR. PIKE: Form. A Again, I would like to answer all your questions here today. I would like to answer that question. However, my counsel has advised me that at least today T may not and must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q In fact, your target age group for sexual activity is between 12 and 17 years old; is that true? MR. PIKE: Form. A Mr. Edwards, T would like to answer that question, as well as your other questions here: today. However, my counsel has advised me that I must not, may not, must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q You know a person named V.R., don't you? A Though £ would like to answer all of your questions Mr. Edwards, on advice of counsel 502] today at least, they've instructed me that I must respond by asserting my rights under the Sixth, Fifth and Fourteenth Amendment. Q V.R. is somebody who served as your sex slave when she was between the ages of 15 and 18) years old; isn't that true? MR. PIKE; Form, A_ I would like to respond to all of your questions with respect to V.R, However, on advice of counsel today at least, they've instructed me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Deo you know Emmy Taylor? A Though I would like to respond to all of your questions here today, Mr. Edwards, under advice of counsel I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Is that somebody who served as the sex | slave for Gislaine Maxwell at the same time or about the same time that V.R. was your sex slave? MR. PHKE: Form. A I would like to answer al} of your questions, Mr. Edwards, However today my counse! has advised me 1 must assert my rights under the Sixth, Fifth and Fourteenth Amendment. 1 2 2 4 & 6 7 8 9 10 li 12 13 14 15 16 17 18 19 20 ad. ae. 23 24 25 eesti 503 Q Isn't it true during that period of time when V.R. was your underage sex slave, that she observed you to have sexual intercourse and sexual activity with several females, as young as 12 years old? MR. PIKE: Form. A_ I would like to respond to all of these questions, And I prefer that your partner, Scott Rothstein, who currently sits it fabricating cases of a sexual nature against people like me and others, were here to hear some of these answers, However, with respect to any other question, at least today, my counsel has advised me that I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Why would you prefer that Scott Rothstein bear an answer from you about whethe| or not you had sex with multiple 12 year olds? MR. PIKE: Form. Move to strike, and mischaracterizes the witness's testimony. A At least today, Mr. Edwards, my counsel has advised me that | must respond to these questions by asserting my rights under the Sixth, Fifth and Fourteenth Amendment, Q V.R. is somebody who has filed a lawsuit against you under the pseudonym Jane Doe numbed 102; isn't that correct? MR. PIKE: I'm sorry. Can you repeat Ww MR, EDWARDS; Sure, Q V.R. is somebody that filed a lawsuit against you under the pseudonym Jane Doe numbeq 1627 A. Though I would like to respond to your questions today, Mr, Edwards, with respect to these lawsuits, my counsel has advised me that I may not, and must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q In that complaint, the allegation is made that a friend of Jeffrey Epstein sent him three 12-year old girls from France, who spoke no English, for defendant Epstein to sexually exploit and abuse. After doing so, they were sent back to France the next day, ‘That's 2 true statement, isn't i? MR. PIKE: Fonn, A_ I would like to respond to all of these questions... However, at least today, my counsel has advised me that I must assert my rights under the Sixth, Fifth and Fourtecath Amendment, 43 (Pages 501 to 504) U.S. Legal Support (561) 835-0220

oI aAne wre 10 i 12 13 14 16 505 Q In the complaint filed on behalf of Jane Dee number 102 also known as V.R,, was filed by) an attorney named Bob Josefsberg with Podhurst, Orseck; isn’t that right? | MR. PIKE: Can you reread that specific question for me? THE COURT REPORTER: Sure. (The record was read.) MR. PIKE: To the extent you know the answer to that question, you can answer, A I think - I'm going to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q And when I asked you a few questions back about your sexual interaction and intercourse with 12-year old girls and derived that from this complaint, your answer -- into your answer was injected some response related } Seott Rothstein, and so my question is, whatdo | you believe, if anything, Scott Rothstein had to do with the complaints or assertions that are made in the Jane Doe 102 versus Epstein complaint? MR. PIKE: Form, move to strike. Mischaracterizes the witness's testimony. A. E would like to answer that question. However, at least today they have instructed me I must respond to that question by asserting my Sixth, Fifth and Fourteenth Amendment right. Q Mr. Epstein, for at least the passed decade you have consistently kept at least one sex slave at all times, Is that true? MR. PIKE: Form, A_ I would like to respond to these sexually charged questions. However, upon advice of counsel, I must respond simply by asserting my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right. i Q And you have an Amazon.com account, right? 1 MR, PIKE: Form, | A Upon advice of counsel, I'm going to | have to assert my right fo the Sixth Amendment, | Fifth Amendment and Fourteenth Amendment. Q On or about September 4, 2005 you ordered and received -- and later received three books from Amazon.com; is that true? j MR. PIKE: Form. Um.., Books? ] +» Form. A. Onadvice of counsel { have to assert my Sixth Amendment, Fifth Amendment and Fourteent} au Ne aane 9 10 11 12 13 14 15 16 17 18 19 20 24 25 307 Amendment right. MR. EDWARDS: Mark this. {Order form from Amazon.com, listing three books, was marked as Plaintiff's Exhibit number 9 for identification, as of this date.) MR. PIKE: (Handing to the witness.) Q Do you recognize that document that's been marked for identification purposes as Exhibie 9? A No. Ido not. Q Did you indeed order the three books from Amazon.com that are listed on that order form that's been marked as Exhibit 9? A No. Q Have you read the three books that are on that order form, Exhibit number 9? A No. Q Do you know why it is, can you explain how that document came to exist? A No. Q Do you know where that document that you're holding marked as Exhibit number 9 cam} from? Q Would you be surprised if it was taker from your trash by police or law enforcement? A Would i be surprised? I don't understand the question. Q Would it surprise you if the police pulled that from your trash, outside your hou: in 20057 MR. PIKE: Object to the form. There, because... quite frankly, f don’t know where this document came from. There has been no predicate laid as to its origination, Now you're talking about a question relative to, would it surprise you if the police pulled it... | don't think that you've laid the proper foundation, so I'm going to abject to the form. MR. EDWARDS: Okay. At trial I'l enter it in through another witness. I just want him to deny him ever seeing it before I do that. It is fine, Pll lay the predicate -MR. PIKE: He's already said that, I believe, he's never -- you asked him if he recognized the document and he said “No.” MR. EDWARDS: | appreciate that, Q Would it surprise you if that was 44 (Pages 505 to 508) U.S. Legal Support (561) 835-0220

obtained from a trash pull at your house? A You're asking me 8 hypothetical question. I have no idea. Q What is the name and address of the purported purchaser of those books? According # Exhibit number 9? A_ I don't know. MR, PIKE: Form, Q Looking at that document you cannot telE what address those books were shipped to? A. It says "billing address." Q What's the billing address? A It says what the document says. Q What is that? A. Itsays Jeffrey Epstein. Q What's the address? A 358 El Brillo Way. That address at 358 El Brillo Way is your address, correct? MR. PIKE: Form. A. Onadvice of counsel, I'm going to have to assert my Fifth Amendment, Sixth Amendment are Fourteenth Amendment right. Q Jeffrey Epstein, that's your name, correct? A Correct. Q Can I see the document? A. (Handing to counsel.) Q Mr, Epstein, the person whose deposition was taken yesterday and has been widely rr in the newspapers as your sex slave, Nadia Marcinkeva, is she indeed your sex slave? MR, PIKE: Form, A On advice of counsel, I'm going to respond by asserting my Sixth Amendment, Fifth Amendinent and Fourteenth Amendinent right. Q Does anybody other than yourself have access to your Amazon.com account? MR. PIKE: Form. A [don't know. Q You have never read "Slave Craft, Roadmaps for Erotic Servitude, Principles, Skills} and Tools"? MR. PIKE: Asked and answered, He was already asked these questions ~- I'm sorry, answered, A. I've answered the question "No." Q Why was it ordered to your house, the shipping address and billing address both being | 358 El Britio Way? i { A I don't know. Q Is there anybody else that lives in your} house, besides yourself, that has sex slaves? MR. PIKE: I'm sorry... Mr. Horowitz, I believe, interrupted you, | think he gave you another exhibit, | think it's Exhibit 9, which I think he wants you to follow up wit a question. MR. EDWARDS: It is just placed on the table. I'm waiting for an answer. MR. PIKE: I'm not being smarter, I'm just saying, are you going to follow through with the question that's currently on the table or the one that -MR. EDWARDS: 1 asked a question and many waiting for an answer. MR. PIKE: Seriously, I'm not trying to be rude or smart. You put an exhibit in front of him and -MR, HOROWITZ: | wanted to give the court reporter the exhibits. She gets the exhibits, MR. PIKE: I've got to know what question is on the table, that's all, MR. HOROWF didn't int did I? MR. EDWARDS: No, it {s asked on -asked a question, it is stil! on the table. A Ask the question. Q Anybody else in your house have sex slaves? MR. PIKE: Form. A Thave to respond to that question as [ did to most of your other questions today, which is I have to assert my rights to the Sixth, Fifth and Fourteenth Amendment. Q Are you familiar with the various messages that are -- that were taken from your home at 358 El} Brillo Way? MR. PIKE: Form. A. I'm going to have to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Have you read the messages that were taken and placed in the State Attorney's Office file related to the criminal charges against you? MR. PIKE: Form. A IT don't recall. : Q Why is it that underage minor femaies were calling your home in 2004 and 2005 for, it 45 (Pages 509 to 512) U.S. Legal Support (561) 835-0220

23 513 quotes, "work"? MR. PIKE: Waitasecond. Form, lacks | predicate, foundation, and for the record, you're referring to a stack of documents | that have not been marked -~ ; MR. EDWARDS; Not referring to anything, | just so that your objection is clear, MR. PIKE: You're referring to what I see as a stack of documents that look like message pads. You're clarifying and... making a prelude into your question as to i why were underage girls calling your home for work? MR. EDWARDS: Right. MR. PIKE: You're not allowing the witness to see the exhibits to which you | refer, and I think itis an improper | question and lacks predicate and foundation. | MR, EDWARDS: No matter what I show thé witness, any answer he gives is going to incriminate him, so he is going to invoke i his Fifth Amendment rights, which is why | right now, he is not going to see these. At trial he will see all of these things. MR. PIKE: I'm glad you said that. 1 think that's a false statement. I move to strike it. Mr. Edwards, you provided a. document to Mr, Epstcin not two minutes ago and he answered questions without invoking the Fifth Amendinent right. MR. EDWARDS: And it incriminated him. MR. PIKE: If the Fifth Amendment comes into play. MR. EDWARDS: It should have. MR. PIKE: Thank you. If the Fifth Amendment comes into play, he will invoke the Fifth. He does not know certain information. Not knowing something, my friend, is not a waiver. Follow? So he is trying to -MR. EDWARDS: It is ~ MR. PIKE: -- trying to actually work with you on your questions. Maybe if you show him what you're talking about, he can answer your question, Q Why were underage minor femaies cating your honse to, quote, unquote, “work”? MR, PIKE: Form. A Unfortunately, I have to answer that 20 515 question, as I've answered most of your other questions here today, Mr. Bdwards, which is that my attorneys advised me to assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right. Q Do you knew Adriana Mucinska or Adria Ross? A. As!'ve answered most of your other questions here today, I'm going to have to respond that my attorneys have instructed me io assert my rights to the Sixth, Fifth and Fourteenth Amendment. Q That's somebody who is listed in the agreement between yourself and the United States of America as a co-conspirator of yours. Does that help refresh your recollection as to who Ms. Ross ts? MR. PIKE: Form. A I'm going to bave to respond by asserting my rights to the Sixth, Fifth and Fourteenth Amendment. Q Do you remember receiving messages from Adriana that would read something like, "Hlefta message for Ashley to confirm for 11:00 o'clock and Vanessa for 4:30, many messages like that? MR, PIKE: Fm sorry, but before he answers, I'm just curious, you're again referring to a stack of documents that's about an inch thick. Do you want to mark anything as an exhibit? MR. EDWARDS: No, I really don't, Mike, but appreciate all the help you're providing. Thanks. MR. PIKE: Yeah. You're welcome. Do you know where these documents came from’ MR. EDWARDS: Yes. MR. PIKE: Where did you obtain that them from? MR. EDWARDS; It is not my deposition. You had that chance already. MR. PIKE: No, | asked the right -- no, that's not really part of my case over there. Critton took your depesition, not me. That's a case separate and distinct from these cases, so my question to you is: I'm just curious, you have a stack of documents, I think you said earlier they came from the State Attorney's Office file? MR. EDWARDS: It is not my deposition. I'm asking questions. Your client is going 46 (Pages 513 to 516) U.S. Legal Support (561) 835-0220

wenn ewan 16 11 iz 13 14 15 16 17 18 19 20 22 22 23 24 25 CMAN RWHP io 41 12 13 14 1S 16 17 18 19 20 aL 22 23 a St a Sc ie aac saeco orate to give answers or not give answers. MR. PIKE: Okay, MR. EDWARDS: These will come in with the appropriate person at trial, period. MR. PIKE: Okay. A Question? Sorry. Q Sure. Do you remember receiving a message fro: Adriana Ross or Adriana Mucinska, such as, "| left message for Ashley to confirm for 11:00 o'clock and Vanessa for 4:30"? A I don't recall, i Q And when a message such as that is left, is that indicating Ashley is going to come to | your house for you to molest her at 11:00 and Vanessa will come for you to molest her at 4:30? MR. PIKE: Form. A. I'm going to have to respond by asserting my rights under the Sixth, Fifth and Fourteenth Amendment. Q Why would underage minor females call your home and leave messages like, "I have 2 gi for him." Do you know? MR. PIKE: Form. A On advice of my counsel, today at least, ec 518 they've advised me | must assert my right under the Sixth, Fifth and Fourteenth Amendment, Q Did you ever employ any underage minor females for any legitimate purpose at your home, 358 El Brillo Way? MR. PIKE: Form. A. At least today, Mr. Edwards, though I would fike to answer every one of your... questions, my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Isn'tit true, Mr. Epstein, that each underage minor female that contacted — that called your home or was called from your home, was called for the purposes of coming to your house to satisfy you sexually? ! MR. PIKE: Form. THE WITNESS: | think I've answered that question before. I A. Iwill answer it unfortunately the same | way, which is although } would like to answer each and every one of the questions you've posed | here today, on advice of my counsel they've instructed me { must assert my rights under the Sixth, Fifth and Fourteenth Amendment, 25 519 Q Ina newspaper article dated October 30, 2006 entitled, "The Return Of A," in quotes, "Very Passionate’ end quote, "Jeffrey Epstein," there is a quote from somebody that is called in this article "A Friend," and the quote is: "Speaking about Jeffrey Epstein, his life is about making money and living an eroti his escape isn't alcohol or drugs, it is sex." Is that a true statement? MR. PIKE: Form. A Is ita true statement that that's what the article says? Q No, is it a true statement that your life is about making money and living an erotic life and your escape is not alcohol or drugs, it is sex? MR. PIKE: Form. A Though I would like to answer that question, as well as all your other questions posed here today, Mr. Edwards, on advice of my counsel, he has instructed me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Another article entitled "The Fanaticist," from New York Magazine dated life a December 10, 2087, a quote or several quotes are attributed to you, and it reads: "I told Epstein," this is the author “and Rubenstein the sort ef story New York Magazine wanted to do, a Epstein seemed to find ironic delight in every word, A secretive genius, I said,” a statement from the author. "She indicates you corrected her saying "Not secretive, private,” and the next quote, which I will ask you about, is that you stated "And if] was a genius, I wouldn't be sitting kere, a guy with sex issues;" do you remember saying that? MR. PIKE: Form. Q - to areporter in New York? MR, PIKE: Form. Move to strike. A_ Though J would like to answer every question you've posed here today, Mr. Edwards, on. advice of counsel J have to essert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right. MR. PIKE: Mr. Edwards, if you would, I know you THE WITNESS: Take a break? MR, PIKE: Actually one second, You provided the title of the second 47 (Pages 517 to 520} U.S. Legal Support (561) 835-0220

521 article that you just questioned him, Could you please, for the record, provide the title to the first article. MR. EDWARDS: I did. MR. PIKE: I didn't hear it. MR. EDWARDS: I will do it again. "A Return Of A "Very Passionate’ Jeffrey Epstein." MR. PEKE: Thank you. MR, EDWARDS: “Very passionate” is in quotes, as I said the first time. MR, PIKE; Thank you. THE VIDEOGRAPHER: Going off the video record 3:02 p.m, (Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video record at 3:15 p.m. Q In the same articte, "The Fanaticist," there is @ quote by "Michael Wolff." Do you =" Michael Wolff, the columnist? A Ihave to respond the same way I've responded fo most of your questions here today, which is, | must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Mr Wolff says i ina | guote i in this article, “He has never," speaking about Mr. Epstein, "been secretive about the girls. Atone | point when his troubles began he was talking to me and said, ‘What can I say? I like young girls,'" Is that a comment or statement that you made to Michael Wolff? MR. PIKE: Form. A. Unfortunately I have to respond to that question as f did to most of your questions today, which is I must assert my rights under advice of counsel, under the Sixth, Fifth and | Fourteenth Amendment. | Q On several occasions your attorney or | one of your attorneys, Jack Goldberger, has made the statement "Jeffrey Epstein has never denied that the girls came to the house." Are you admitting that the girly that are now plaintiffs, at least came to your house? MR. PIKE: Form. A. I would like to answer that question you've just quoted an attorney's statement? Q Right, Jack Geldberger’s statement. A So what's the question? MR. PIKE: You can't -- hold on right there. This is ridiculous, This is getting to be ridiculous. You can't read -MR. EDWARDS: What -MR. PIKE: You can't read someone else's quote and say "Are you admitting something from someone else's quote." He didn't make the quote, so how can it be an admission, despite who it is. MR. HOROWITZ: That's a form objection, MR. PIKE: You're right, form. Q Your attorney, Jack Goldberger, made ¢ statement, "Jeffrey Epstein never denied the girls came to the house." This was related to the criminal investigation of you. Do you admit that the girls, specifically Jane Doe, came to your house? A Mr. Edwards, J would like to respond to that question as I responded to most of the other questions today, but unfortunately my counsel has advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Mr. Epstein, can you tell the jury who Sarah Kellen is? MR. PIKE: Form. A Unfortunately, Mr. Edwards, I have to Tespond to that question as I responded to most 524 of your other questions today, because on advice of counsel they've instructed me to assert my tights under the Sixth, Fifth and Fourteenth Amendment, Q You're aware that she is somebody sted as a co-conspirator of yours related to your criminal activity in the Nonprosecution Agreement, correct? MR. PIKE: Form. A With respect to that question as most of your other questions here today, on advice of counsel I have been instructed to assert my rights under the Sixth, Fifth and Fourteenth Amendment, Q Isn't it érue that you paid her to have underage minor femafes brought to your house, specific times, as you directed? MR. PIKE: Form, asked and answered. A As I've answered most of your questions here today, unfortunately my counsel has advised. me that 1 must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Another co-conspirator of yours, as she is labeled in the Nonprosecution Agreement, is Lesley Groff. What role did she play or what did] 48 (Pages 521 to 524) U.S. Legal Support (561) 835-0220

CDV anewne 10 11 12 13 14 as: 16 Ww 18 ig 20 2} 22 23 525) she conspire with you to do? MR. PIKE: Form. A Mr. Edwards, I have to respond to that question as I did to most of your other questions here today, which is, on advice of counsel, they've instructed me to assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Today what role does Story Cowles play in your life? MR. PIKE: Form. A Twould like to answer all your questions, Mr. Edwards. However, at least today,: ty counsel has advised me that I must assert my rights under the Sixth, Fifth and Fourteenth i Amendment. | Q Is Story Cowles your personal assistant? MR. PIKE: Form. A Mr. Edwards, J would like to answer all | your questions here today. However, upon advice of counsel, they've instructed me that I must | assert my Fifth, Sixth and Fourteenth Amendment rights to that question. | Q And Story Cowles, in addition to being | your personal assistant, is Sarah Kellen's i 526] boyfriend; is that true? MR. PIKE: Form. A Though I would like to answer all your questions, Mr. Edwards, on advice of counsel they've instructed me that I must assert my tights under the Sixth, Fifth and Fourteenth Amendment. I Q Prior to the police executing, the Palm Beach police executing a search warrant on your | house in October of 2005, did you direct Adriana Mucinska to remove at least three computers from your home? | MR. PIKE: Form, A Though I would like to answer all your questions, Mr. Edwards, my attorneys at least today have advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendment. Q Where are those computers today? MR, PIKE: Form. A. Though I would like to answer all your questions, my attorneys have advised me I must assert my rights under the Sixth, Fifth and Fourteenth Amendinent. Q Isn’t it rue that those computers contain the names and telephone numbers of 1 underage minor females in the communities 2 surrounding each of your homes? 3 MR. PIKE; Form. 4 A. Though I would like to answer each and 5 every one of your questions, Mr. Edwards, my 6 attomeys have advised me at feast today, at 7 least today, that I may not. 1 must assert my 8 rights as provided by the Sixth, Fifth and 9 Fourteenth Amendment. id Q Isn't it true that within that computer in system were the names and telephone numbers 12 hundreds of underage minor females that you 13 sexually motested? : 14 MR, PIKE: Form. 15 A_I would like to answer every one of your 16 questions today, Mr. Edwards. However, upon 7 advice of counsel I must assert my rights as 18 protected by the Sixth, Fifth and Fourteenth 19 Amendment, 20 Q Can you explain to the jury what 21 Gistaine Maxwell's role was in helping you to 22 access underage minors? 23 MR. PIKE: Form, assumes facts not in 24 evidence. 25 aA RW we © 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 527 A. You know | would like to answer each and 528 every one of your questions posed here today, Mr. Edwards. Unfortunately | have te answer that question on advice of counsel by invoking my tights under the Sixth, Fifth and Fourteenth Amendment. Q Do you have any remorse for sexually molesting Jane Doe? MR. PIKE: Form, argumentative. A. Lwould like to answer every one of your questions regarding Jane Doe. However, at least today, my counsel has instructed me to assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment, Q When is the last time that you visited your island, Little St. James? MR. PIKE: Ferm. A. Though I would like to answer all your questions, Mr. Edwards, my counsel advised me & must assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment. Q Has any court given you permission to to your island or the Virgin Islands while you have been on house arrest? MR. PIKE: Form, A Mr. Edwards, though 1 would like to 49 (Pages 525 to 528) U.S. Legal Support (561) 835-0220

525| answer all your questions, my counsel has advised me that 1 must assert my rights protected by the Sixth, Fifth and Fourteeath Amendment. Q Have you interacted sexually with underage minors since beginning your house arrest ‘or community contral? MR. PIKE: Form. A Though 1 would fike to answer each and every one of your questions posed here today, my counsel has advised me that [ must assert my tights protected by the Sixth, Fifth and Fourteenth Amendment. Q Mr. Epstein, is it your intention to testify in the trial of Jane Doe versus Jeffrey Dpstein? MR. PIKE: Object to the form, It may disclose attorney/client work product information. | instruct him not to answer. Q Does Story Cowles work for you at Florida Science Foundation? MR, PIKE: Form. A Though I would tike to answer each and every one of your questions, Mr. Edwards, at least today my counse! has advised me E must assert my rights as protected by the Sixth, Fifth 530 and Fourteenth Amendment. Q is it your intent in the future to engage in sexual activity with underage minor children? MR. PIKE: Form. A_ I would like to answer each one of those questions, Mr. Edwards. However, today my | counsel has advised me I must assert my rights | protected by the Sixth, Fifth and Fourteenth: Amendment, Q When you give that answer, that you would like to respond to each one of my questions, would it then be your preference to! explain to the jury why it ts that you feel entitled to sexually molest underage minor children? MR, PIKE: Form, move to strike. Mischaracterizes the witness's testimony. A Unfortunately I would like to answer that question as well, but my counsel has advised, me that I must assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment, MR. EDWARDS: | don't have anything further, MR, PIKE: Ms. Ezell? a1 13 14 15 16 17 18 19 20 21 531 MS. EZELL: Okay. 1 can begin. Are we ending at 4:00? MR. PIKE: Yes, we are ending at 4:00. CROSS EXAMINATION BY MS. EZELL: MS. EZBLL: Let the record reflect that Thave 3:22 right now. Q Mr. Epstein, geod afternoon, & Good afternoon. Q You were previously deposed by Mr. Horowitz on Monday, March 8th of this year, You were asked with respect to Jane Doe 103, "Do you acknowledge that she’s been to your home?" Therq was a form objection and your answer was, "Again I woutd like to answer most of your questions. However, today as I've answered most, almost all of your questions and will continue fo answer on advice of counsel, } believe, this question, I have to assert my Fifth Amendment, Fourteenth Aniendment and Sixth Amendment rights under the U.S. Constitution." If you were asked the same question today, what would your answer be? That question wast "Do you acknowledge that Jane Dee 103 has been to your ome"? A. Please tell me who Jane Doe 103 is. Q Fane Doe 103 is Jane Doe 103. A. I would like to answer the question so the answer would be the same. MR. PIKE: By “answering that question,” you're invoking Fifth, Sixth and Fourteenth? THE WITNESS: Yes. MR, PIKE: Please do so. A I'm invoking my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right. Q You were then asked "Do you acknowledge that Jane Doe 103 came to your home for sexual contact during her childhood and that you paid her for those services?" Mr. Pike said "Form, predicate, foundation, argumentative,” and your response wah “I would like to answer that question. I think those questions will all have obvious answers, and not -- however, foday I'm going to have to assert my Fifth Amendment, Sixth Amendment an Fourteenth Amendment rights under the U.S, Constitation, because I would like to answer that question, my attorneys have advised me that I cannot today, cannot answer any question that ma: 50 (Pages 529 to 532) U.S. Legal Support (561) 835-0220

533 535 1 he relevant to this lawsuit." 1 could answer those questions." 2 Ifyou were asked that same question 2 can you answer that question today? 3 today, would your answer be the same? , 3 MR, PIKE: Form. 4 MR. PIKE: I'm going to object. Form, , 4 A Ma‘am, unfortunately I'm going to have 5 and J instruct you if your answer is the | 5 to invoke my Sixth Amendment, Fifth and 6 same, please tell Ms, Ezell that. | 6 Fourteenth Amendment right to that question, 7 A. My answer is the same, invoking my right 7 Q Then you were asked ~ 8 under the Sixth, Fifth and Fourteenth Amendment. 8 THE WITNESS: Can we go off the record 3 Q So, it wasn't just that that day you 9 for a second? 10 were instructed not to answer the question, but 10 THE VIDEOGRAPHER: Off the video reco: 1 here, five weeks later, today, you also, today, 11 3:32 pm. 12 can't answer those questions, correct? 12 THE WITNESS; Just two minutes. 13 MR. PIKE: Asked and answered. 13 MR. EDWARDS: For what? We are all 14 A_ I'm going to, on advice of counsel, Ms. 14 going to have a discussion off the record? 15 Ezell, respectfully assert my rights as protected | 15 MR. PIKE: I think my client wants to 16 by the Sixth, Fifth end Fourteenth Amendment, 16 speak with me. 17 Q Later Mr. Horowitz said, "Sir, are you 17 MR. EDWARDS: Okay. 13 asserting your Sixth, Fifth and Fourteenth 18 MR. PIKE: Are you okay with that Ms. 19 Amendment privileges because you're innocent? Ts 19 Ezeli? 20 that what you're telling us?" 20 MS, EZELL: Yes. au You said "Today on advice of counsel I 21 MR. PIKE: Off the record, 22 cannot answer your questions, any of your 22 (Pause in the proceedings.) 23 questions that may be relevant to this lawsuit." 23 THE VIDEOGRAPHER: + MR. PIKE: Form. 24 THE WITNESS; Sony, go ahead, Q What would your answer he today to that 25 ‘THE VIDEOGRAPHE] ack on the video 534 536 question? record 3:33 p.m. MR. PIKE: Same objection. Q Later in that same deposition, Mr. A On advice of counsel, with respect to Horowitz asked "Did you have surveillance cameras that question, I'm going to have to assert my in either the interior or exterior of your home rights as protected by the Sixth, Fifth and at E} Brillo Way between 2001 and 20062" Fourteenth Amendment. You answered, "Mr. Horowitz, I'm going Q So again, your answer wasn't just that to answer that question the same way as I've answer then, five weeks ago, but today, you again answered most of your other questions here cannot answer on advice of counsel, correct? today, I would like to answer each one of your MR. PIKE: Move to strike, questions regarding your clients with great Mischaracterization. Plaintiff has specificity, however my counsel has advised me invoked — sorry, defendant has invoked 12 that I may not today, and therefore have to Fifth, Sixth and Fourteenth. That's his f 43 invoke my Fourteenth Amendment rights, my Sixth answer, j 14 Amendment rights and my Fifth Amendment rights MS. EZELL: So he invokes them today,as {| 15 provided by the U.S. Constitution." well? 16 So what about today? Can you answer MR. PIKE: Yes, ma'am, iv that question for us today? Q Mr. Horowitz asked "Between 2005 and 18 MR, PIKE: Object to the form. 2006, did your sexual interesis include digitally 19 A Unfortunately, Ms. Ezell -- Mrs. Bzell, penetrating the vaginas of girls between the ages | 20 fm sorry. of 12 and 172" 21 Q Ms. is fine. Mr. Pike objected "Form," and you said, 22 A Okay, Ms. Ezelt. Unfortunately on "T find these questions -- I would like to 23 advise of counsel, I have to assert my rights as answer every onc of those questions, However, my) protected by the Sixth, Fifth and Fourteenth counsel has toid me I may not today, I wish I 25 Amendment. 51 (Pages 533 to 536) U.S. Legal Support (561) 835-0220

15 16 17 18 19 20 21 22 23 an 537 MR. PIKE: And Ms. Ezell, let me caution you that I've listened to several of your questions. The first one being a repetition of Mr. Horowitz's question approximately four weeks ago dealing with your client 103, so | did not have a problem with that background information being repeated. However, it seems that the questions that you're discussing now and going over are just a repetition of Mr. Horowitz's background information, which has already been established and really has no relation, in my opinion, to your particular clients. Given the fact we are here today, Mr. Horowitz has taken the liberty of concluding) his deposition, obviously with rebuttal available, same with Mr. Edwards, J would | ask, rather than to have to seek assistance of the Court, that your questions be tailored toward your client. MS. EZELL: Mr. Pike, I would beg to differ with you. Questions regarding his sexual interests, including digitally penetrating vaginas of girls between ages of MR. PIKE: Ms. Ezell, you were at that deposition. You cross-noticed that deposition and these cases have been consolidated for discovery, and you have not formed, with the exception of one question, since you commenced your portion of the depo, you have not formed one question relative to your particular client, You just asked a general question that had already been asked by Mr. Horowitz who commenced the Volume | of this Volume III o TV continuation of the deposition. If you want to tailor these questions to your client, | have no problem with that, but to ask the same exact question Mr. Horowitz asked who commenced the deposition is a waste of time, MS. EZELL: That may be your opinion, Mr. Pike, but I believe I have, particularly in the way these questions were answered five weeks ago, that today, that day he was. unable to answer because of advice of counsel. I certainly have the right to ask his whether this day, five weeks later, he can answer that question. ORIHRHEWHHE 1° 10 f li 12 13 14 15 16 1? 18 19 20 21 22 23 24 2s 539 MR. HOROWITZ: I join in Ms. Ezell's comments. MR. EDWARDS: Agreed. MR. PIKE: Thank you, Three against one. Nonetheless, again, 1 hold steadfast the same argument. It is repetitious and whether or not -- he is not going to waive Fifth, Sixth and Fourteenth yesterday and he| is not going to waive it today, so... MS. EZELL: That's fine. My objection to that is that it is misleading for him to say that “Today I have been instructed not to answer it,” because then I come here hoping five weeks later I may get an answer, and unfortunately that's not been the case. We have had the same invocation of the privileges today, only today, just for today. MR. PIKE: Well, I MS. EZELL: I'm done with that line of questioning. MR. PIKE: Okay. MS. EZELL: But I think { had the right to ask. MR. PIKE: Thank you, 540 MS, BZELL: Thank you. Q Mr. Epstein, are you a citizen of the United States? A Yes. Q And are you a citizen of the United States Virgin Istands? A_ I don't know what that means. Q Ofwhat State or territory of the United States are you a citizen? A I'ma citizen of the United States, Q And of what State or territory in the United States do you claim to be a citizen? A I'm acitizen of the United States, Q Where do you vote? A Lyvote in the Virgin Islands. Q Where do you pay your taxes? MR. PIKE: Form. A Ont advice of counsel, I'm going to have to assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment. Q And 1 would just note that your tax returns are public documents available to the government, and there is no -- no risk of incriminating yourself with such a document. D you still maintain the same objection? 52 (Pages 537 to 540) U.S. Legal Support (561) 835-0220

is 16 17 18 19 20 2. 22 23 24 25 12 13 14 45 16 1? 18 19 20 aL 22 23 24 25 541 MR. PIKE: He does, and that calls for a legal conclusion, which currently is, 1 think, under -- it was under appeal and now it is back under appeal. Q Before serving your jail time in Patm Beach County, followed by your community contrel time, was your principal place of residence the dwelling in Manhattan? A The what? Q Your mansion ia Manhattan? MR. PIKE: Form, A I'm sorry, but at least today, F would like to answer all your questions, Ms. Ezell. However, on advice of counsel I will have to respond by invoking my Sixth, Fifth and Fourteenth Amendment. Q lL won't repeat the same questions regarding the plan or scheme. I'll try not to, that have already been covered today. To the extent that they didn't just apply to that one plaintiff, in most instances, I believe that Mr. Edwards said, "young women" or "young girls li or including Jane Doe," but there were a few additional questions in that area | wanted to ask, 542 ‘Within that arrangement whereby girls i would come or be brought to your home to provide massages and other sexual gratification fer you, | were they often brought by taxis that were paid for by you or by someone on your behalf? MR. PIKE: Form. A Though I would like to answer ali your questions today, Ms. Ezell, I'm going to have to respond fo that question as I've responded to most of your other questions, which is, on advice of counsel, at feast today, they've instructed me to assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment. Q Also, within that same scheme, were these girls sometimes fransported to or from your | house by the current houseman employed by you at} that time? MR. PIKE: Form. A Though I would like to answer all your questions, Ms. Ezell, that question as weil as the others, | must unfortunately at least today, on advice of counsel, invoke my Sixth Amendment, | Fifth Amendment and Fourteenth Amendment right. Q And again following with that plan as discussed previously, were these same young womel 543 who came to your home to provide massages and other sexual gratification for you, were they often transported by Sarah Kellen or other assistants that you employed? MR. PIKE: Form. A Though I would like to answer each and every one of your questions, Ms. Ezell, I respectfully must decline. On advice of counsel they've instructed me I must assert my rights protected by the Sixth, Fifth and Fourteenth Amendment. Q Would you acknowledge, Mr. Epstein, that once the girls were there, beginning with their first experience, their first visit, there was a sort of a ritual that was followed in regard to how they were treated, what they were asked to di and what occurred? MR. PIKE: I'm sorry, I didn't know if that was the question. MS. EZELL: It is a question. THE WITNESS: What's the question? MR. PIKE: What is the question? Q From the first visit a girl might make to your home, was there a ritual or routine that was followed with regard te what happened durin 544 that visit? MR. PIKE: Form. A Ms. Ezell, 1 would like it answer all your questions that you posed here today, but I wilt have to respond unfortunately, as I've responded to most of the others which is, my counsel advised me I must respond by invoking my Sixth, Fifth and Fourteenth Amendment. Q For instance, in addition to the other things that Mr. Edwards and Mr. Horowitz ask about, within the same area, would Ms. Kelten or} one of your other assistants usually go up and Jay out the towels and particular massage olls that you like? MR. PIKE: Form. A Ms. Ezell, unfortunately I have to answer that question as I've answered most of your other questions here today, respectfully decline to answer on advice of counsel who's asked me to invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right. Q Was it more or less routine that when a girt would come for the first time, that she would be accompanied to the massage area by another woman or girl? 53 (Pages 541 to 544) U.S. Legal Support (561) 835-0220

MR. PIKE: Form, A Ms. Ezell, | have to answer that question as I answered most of your other questions today, which is on advice of counsel, I have to assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment. Q Did it occur quite often that Sarah Kellen would lead the girl up and introduce you to her and then quietly leave? MR. PIKE: Form. A Me’am, I'm going to respectfully have to decline to answer that question today on advice of counsel, They've asked me to assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment. I would like to answer each and every one of your questions. Q Did it aiso occur sometime that the girl | would be accompanied by the girl who brought het, and the girl who brought her would go up to your bedroom and massage area with her, on her initial visit? MR. PIKE: Form. A Again? Can you -- what's the question? Q I'm asking about whether or not there was 8 sort of routine that was followed when the girls would come to your home to provide the massages and other sexual gratification for you, I'm asking whether or not part of that routine was that they would be accompanied by the girl who brought them? MR. PIKE: Form. A. I'm going to have to, on advice of counsel, answer that question by asserting my rights as protected by the Sixth, Fifth and Fourteenth Amendment. Q Ifthey were accompanied by the girl who’ brought them, would it be your usual practice td allow them to start the massage and then excuse’ the girl who had brought the second girl for her! first visit? | MR. PIKE: Form. A. I'm going to do my best to respond to these questions, but my counsel has advisedme =| that I must assert my rights as protected by the ‘Sixth, Fifth and Fourteenth Amendment, Ms. Ezell. so J respectfully must decline. Q Did you have 2 routine way that you liked the massage itself to be conducted? MR. PIKE: Form, A Ms. Ezeil, I'm going to have to 547 respectfully decline to answer that question, on advice of counsel, they've asked me to assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment. Q Did either Ms. Kellen, or you, or the gir] who perhaps had been there before instruct] the new girl to begin by massaging the back of your legs and your hack? MR. PIKE: Form. A. I would like to respond to all your questions, but unfortunately at least today, my counsel has advised me I must assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment, Q And did you or Ms. Kellen generally ask the girls or instruct the girls to remove their clothing? MR, PIKE: Form. A. Unfortunately, Ms. Ezell I have to respectfully decline to answer that question today. On advice of counsel, they've asked me to assert my Sixth Amendment, Fifth Amendment Fourteenth Amendment right. Q After having the back of your legs — the feet, the back of your legs and your back massaged, would you then typically turn over, exposing yourself, laying on your back? MR. PIKE: Form. A Ms. Ezell, I'm going to respectfully have to decline to answer that question today, because my counsel has asked me to assert my Sixth Amendment, Fifth Amendment and Fourteer Amendment right, though I would like to answer every one of your questions. Q Would it be your practice at that point, depending on the skittishness of the girl to begin trying to fondle her breasts or rob her vagina? MR. PIKE: Form. A Ma’am, | respectfully have to dectine to answer that today, though I would like to answer each one of these questions. My counsel has instructed me to assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right. Q Assuming the girl was ill at ease, would it be your practice to then talk with her to try fo elicit from her, her interests, her goals, the things that were important to her in her life? MR. PHSE: Form, Q Was that part of your routine? 54 (Pages 545 to 548) U.S. Legal Support (561) 835-0220

MR. PIKE: Sorry. Form. A Ma‘am, though I would like to answer every one of your questions today, unfortunately my counsel has advised me 1 must assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment, Q Would it generally be your practice, if the girl was skittish, fo perhaps wait until the second visit to introduce a vibrator inte the { ‘ 5 routine? ‘MR. PIKE: Form. A. Ms, Ezell, unfortunately I have to answer that question the sane way as I've answered every one of your questions today, which is, I would have to assert my rights protected by the Sixth, Fifth and Fourteenth Amendment on advice of counsel. Q Would you try to calm the girl by telling her to relax, that there was nothing wrong with what was going on? MR. PIKE: Form. A Ma'am, unfortunately I have to respond to that question as I've responded to most of 23 your other questions here today, which is by 24 invoking my Sixth Amendment, Fifth Amendment and 25 550) Fourteenth Amendment right. i Q Assuming that the girl made it through the first session, would you generally wait until you had reached climax before dismissing her? | MR. PIKE: Form, THE WITNESS: Earthquake? MR. PIKE: Frain. For the record a train is going by. A Ms. Ezell, unfortunately T have to respond to that question as I've responded to mest of the other questions here today, which is T must assert my rights protected by the Sixth, Fifth and Fourteenth Amendment on advice of my counsel. Q Would you generally pay the new girl $200 for the massage, either by telling her that the money was on the counter or by telling her that Ms. Kellen would pay her downstairs? MR. PIKE: Form. A Unfortunately, Ms. Ezell, today I have to respond to that question the same way I've 21 responded to all your other questions, which is 22 by invoking my Sixth Amendment, Fifth Amendmer}t 23 and Fourteenth Amendment right. 24 Q And if that girl had been brought by 25 14 15 16 17 18 19 20 551 another girl, was it your practice to pay the procuring girl at least $200 for bringing the new girl? MR. PIKE: Form, A Again? Sorry. Can you repeat the question? Q Sure, Maybe I can state it a little better. Did you tell the girls that you would pay them $200 every time they brought a new girl? MR. PIKE: Form. A Unfortunately, Ms. Bzeli, 'm going to have to respond to that question the same way as. Fve responded to most of your other questions today. On advice of counsel, they've instructed me to assert my Sixth Amendment, Fifth Amendm and Fourteenth Amendment right, Q And indeed, did you keep that promise and cither pay them directly or have Ms. Kellen. pay the procurer $200 for each new girl that she brought? MR. PIKE: Form. A. Unfortunately, Ms. Ezell, I have to respond to that question respectfully the same as 552 responded to most of your other questions here today, My counsel has advised me I must assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment, THE WITNESS: Can we take a two-minute break? THE VIDEOGRAPHER: Going off the vick record 3:54 p.m. (Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video record 3:56 p.m, Q Did you let the girts know that the more they let you do, the more they would be paid? MR. PIKE: Form. Again, I'm really trying to work with you, Ms. Ezelf, but that is an exact question that Mr. Horowitz asked at the commencement of the deposition. We are back in generalities again, and it is repetitious. If you could, Ict's try to narrow it to your client. MS. EZELL: I'm certainly entitled to see how my client fits into the big picture or my clients, and whether this was part of @ pattern and whether they indeed were ‘treated according to a pattern or scheme or 55 (Pages 549 to 552) U.S. Legal Support (561) 835-0220

1 2 3 4 § 6 7 8 9 a 10 12 13 14 15 16 17 18 19 20 21 22 23 24 today. Respectfully, I'm going to have to 553 | routine, MR, PIKE: Okay. I just don't hear any questions regarding your clients. That's i what I'm saying. Q Do you recall that the first time A.H. came to provide you a massage, you told her to take off her clothing, which she refused to do? | MR, PIKE: Form, A AH. -- can we use names so there is no confusion here? Q AHL Is "A..." She is Jane Doe 103. A. I'm going to have to respond to that i question, as 1 responded to all your other questions, Ms. Ezell, respectfully, and on advice of counsel I have to assert my rights as protected by the Sixth, Fifth and Fourteenth Amendment, Q And when she did refuse to do that, did you begin to try to touch her and paw at her and remove some of her clothing? MR. PIKE: Form. A Ma'am, | would respectfully -- I would like to answer that question, as I would like to answer most of the questions you've posed here ( decline on advice of counse! and invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right. Q Over the approximately 17 months that | A.H. came to your home, did you or your agents | frequently call her at her home number or her cell number arranging for encounters, arrangin for her to come to your home to provide the massage and sexual favors, sometimes as much aj twice a day? MR. PIKE: Form. Q Let's break it up. During the 17 months that she came to | your home, did it frequently happen that you or | one of your agents would call ahead of time to | tell her that you would be coming to town? | MR. PIKE: Form, | A Matam, I'm going to respectfully have to | decline to answer that question on advice of counsel. They've instructed me to assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right. MR. PIKE: Ms. Ezell, as you know we've discussed this at the commencement of today's deposition, that we had a COrHeeoUNH 23 24 555 pre-existing obligation beginning at 4:00 o'clock. Hold on a second, guys. So this deposition will be continued consistent with various court orders. MS. EZELL: Okay, thank you. THE VIDEOGRAPHER: Going off the vidi record 4:00 p.m. THE COURT REPORTER: Thank you all. Same orders as yesterday? MR. EDWARDS: Yes. MR. HOROWITZ: Yes. MR. PIKE: Yes, MS. EZELL: Yes, please. THE COURT REPORTER: Thank you all. (Whereupon, the deposition was adjourned. at 4:05 o'clock, p.m., sine die.) THE STATE OF FLORIDA) COUNTY OF PALM BEACH) 1, TERRI BECKER, a Registered Professional Reporter and Notary Public for the State of Florida at Large, do hereby certify that L reported the videotaped continued deposition of JEFFREY EPSTEIN, the DEFENDANT, called by fle PLAINTIFF in the above-cntitled action; that the ‘witness was duly sworn by me; that the foregoing. pages, numbered from 336 to 560, inclusive, constitute a true record of the deposition by said witness. 1 further certify that I am not attorney or counsel of any of the parties, nor a relative or employee of any attorney or counsel conriected with the action, nor financially interested in the action. WITNESS MY HAND and official seal in the City of West Palm Beach, County of Palm Beach, State of Florida, this 19th day of April 2010, cS _ : i Pret Qe done) TERRI BECKER, Register Professional Reporter and Notary Public, State of Florida at Large. My Commission expires March 13, 2011, 56 (Pages 553 to 556) U.S. Legal Support (561) 835-0220

557 ‘THE STATE OF FLORIDA) 1 ERRATA SHEBT COUNTY OF PALM BEACH) 2 Ta Re: JANE DOE Y. EPSTEIN 1; 3 DO NOT WRITE ON TRANSCRIPT ENTER CHANGES HERE: 4 The foregoing certificate was 5 PAGE LINE CHANGE — RBASON acknowledged before me this 6 day of, 2010, 7 8 8 10 ay | 22 13 14 18 Notary Public, State of Fiorida. IBPFREY SPSTBIN My commission No. i Expires March 13, 2011. te ‘THE STATE OF FLORIDA) 19 COUNTY OF PALM BEACH) 20 [DOHEREBY CERTIFY THAT JEFFREY SPSTEIN | appeared before me and stated that he has read 2a his deposition, further, that this Errata Sheet ‘was signed in my presence on this day 22 of 2010 23 558 1 I, JEFFREY EPSTEIN, do hereby 2 certify that ] have read the foregoing transcript 3 of my deposition given on April 14, 2010; that 4 together with the correction page attached hereto § noting changes in form or substance, if any, it 6 is true and correct. 7 8 JEFFREY EPSTEIN > 10 a 22 13 14 ido hereby certify that the deposition 1s of JEFFREY EPSTEIN was submitted to the witne: 16 for reading and signing; that after he had stated 17 to the undersigned Notary Public that he had read 18 and examined his deposition, he signed the seme 19 in the presence of the undersigned authority on 20 the ___ day of. 2010, a1 22 23 24 25 U.S. Lega | ‘ 1 10 ut 12 1a ua 15 16 18 19 20 22 22 23 2a U.S. LEGAL SUPPORT Registered Professional Reporters 444 West Railroad Avenue Suite 300 West Paim Beach, Florida 33401 (561)835-0220 Apsit 19, 2030 BURMAN, CRITTON, LUTTIER & COLEMAN: 303 Banyon Boulevard Suite 490 ‘West Palm Beach, Florida 33401 ATTENTION: MICBAEL PIKE, ESQ In Re: JANE DOE V. EPSTEIN Deposition of; JEFFREY BPSTERN Dear Mr. Pike: Since counsel have agceod that you may have the wimess read and sign your copy of the eposition, for your convenience, enclosed hhorewith you will find an Erveta Sheet for the ‘witness use ia entering any changes to the deposition. Thank you for your prompt ateation. Cordially yours, US, LEGAL SUPPORT TERRi BECKER, Registered Professional Reporter, Notary Public, Stave of Florida at Large. My commission expices Mare (3, 2011 CC: Adam Rorowitz, Esq. ‘Bradley Edwards, Esq. Katherine Ezell, Beg. 57 (Pages 557 to 560) Support (561) 835-0220

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 5

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/ JORNSON JANE DOE NO. 2, Plaintiff, ~vs- VOLUME T OF IIT JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 f VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE NO. 4 Tuesday, October 27, 2009 11:11 - 6:05 p.m. 250 Australian Avenue South Suite 115 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

WONTDMAWNE Page 30 A. It means he was in my face. We were arguing, argument. Q. You mean he was lose a A. Yes. Q. -- his face was close in proximity to yours? . A. Yeah. Q. And he bit your finger? A. Uh-huh. Q. Was that -MR. HOROWITZ: Instead of uh-huh just say yes. THE WITNESS: Yes. BY MR. LUTTIER: Q. Lassume that while that event was transpiring it was a significant event to you. Yeah, when it happened. Did it scare you? Uh-huh, Did it -- did it cause -. Yes. MR. HOROWITZ: Thank you. THE WITNESS: Sorry. BY MR. LUTTIER: Q. Did it cause you to have fear? Yeah. . Fear of him, I] would assume, Yeah. Has -- up to that point in time, how did it compare to any other event that had happened in your life in terms of the shock to you and the trauma it caused you? A. It was shocking, but it made me strong, and I've moved on from that. Q. At the point in time that this interaction happened that you've described between you and Mr. Vinyard where he bit your finger and he was in your face -A. Uh-huh. Q. -- was that the most traumatic thing that had ever happened to you in your life as of that point in time? A. No, Q. Had you had other boyfriends do the same thing to you? A. No. Q. What was a more traumatic event that had happened to you at that point in time than the event where your ex-boyfriend was in your face and bit your finger? Page 32 MR, HOROWITZ: Object to the form. THE WITNESS: What is a more traumatic time? BY MR, LUTTIER: Q. Yeah. What was more traumatic than that [} that had happened to you in your life as of that point in time? A. Meeting Jeffrey Epstein. Q. Meeting Mr. Epstein. Do you mean physically being introduced to the man? A. No, being sexually abused by Mr. Epstein. |} Q. Okay, And what do you mean by sexually } abused? MR. HOROWITZ: Take your time. THE WITNESS: Being fingered by him, i having him use a vibrator on me, grabbing my nipples, smelling my butt, jerking off in front =f of me, licking my clit, several times. BY MR. LUTTIER: Q. What several times, licking your clit several times? A. Fingering me severa! times. Q. So, licking your clit was not several times? MR. HOROWITZ: Object to the form. THE WITNESS: No, BY MR, LUTTIER: > Q. Now, when did this -- anything else? A. (Witness shakes head.) Q. is the answer, no? A. Yes, it’s no. MR. HOROWITZ: Object to the form. I don't think she even understands what the last question was. BY MR. LUTTIER: Q_ I said anything else. A. No. Q. Now, when was the date that this event occurred where the police were summoned with Mr. Vinyard? A. With Mr.-- when what? i Q. With Preston Vinyard, when you say he was in your face and he bit your finger. A. Yeah. Q. When did that happen? A. I don't remember. Q. What year? A. Maybe ‘06, or no, I-- sorry. I graduated ‘05 -- '03 maybe, '04. Q. Had you met Mr. Epstein at the time that (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 9 (Pages 30 to 33) (561) 832-7506

WPONANAWNE Page 34 this event that you've described with Mr. Vinyard occurred where he was in your face and bit your finger? A. Idon’'t remember, Yeah, because I met Mr. Epstein before or around the same time that I met Preston. Q. Well -A. Imet him before I hung -- started, before I was serious with Preston, so yeah. WODNAMAWNHHE Q. Welt, do you know when you first met 10 Mr. Epstein? i A. Yeah, when I was 15 years old. 12 Q. And how do you know that’s when you first | 13 met him? 14 A. Because it was the middle of my sophomore | 15 year. I was 15 years old my sophomore year. 16 Q. And how do you know it was the middle of | 17 your sophomore year? 18 A. Because that's when I was in class with 19 Haley Robson and that's how I knew her and that’s | 20 who brought me there. ai Q. Do you have any record of when you first met Mr. Epstein; that is any written record anywhere? A. Any written record? Page 35 Q Yep. i A. On paper? 2 @. Whether it's -- examples, but I don't mean 3 to limit my question, examples could be you made a 4 note somewhere, you noted it on a calendar, you 5 wrote it down someplace, 6 A. No. 7 Q. Is there any record to the best of your 8 knowledge anywhere in the world that establishes the | 9 first date upon which you met Mr, Epstein? 10 A. No. il Q. So, the sole basis for you to have -- for 12 you claiming that you met Mr. Epstein in the middie =| 13 of your sophomore year -- 14 A. Idid. 15 Q. -- is your recollection; is that right? 16 A. Yes. 7 Q. Have you ever told anyone in the world 18 that you met Mr. Epstein for the first time at some 19 other time? 20 A. No, 21 Q. Are you sure? A. From what I can recall, yeah, I don't -I mean, I don't recail, but I don't see why I wouldn't teil the truth, like tell them that's when (561) 832-7500 PROSE COURT REPORTING AGENCY, INC, Page 36 T met him when I did. Q. Well, we're going to come back to why you would tell people something that is not true, but I'll get to that later. MR. HOROWITZ: Move to strike, argumentative. BY MR. LUTTIER: Q. Now, you say you first met Mr, Epstein when you were 15 in the middle of your sophomore year, and you said somebody, Haley Robson, you mentioned ~~ A. Yes. Q. - she introduced you to him? A. Uh-huh. Q. What do you mean she introduced you to him? A. She brought me to his house. Q. What do you mean she brought you to his house? A. She drove me to her -- his house. Q. Had you had some sort of discussion with Haley Robson about going to Mr. Epstein's before she drove you to his house for the first occasion? A. Yeah. Q, Had you had more than one discussion with Page 37 F Haley Robson about going to Mr. Epstein’s house E before she drove you there for the first time? A. More than one conversation about going there? Q. Yep. A. Yeah, Q. And how many conversations did you have with Haley Robson about going to Mr. Epstein’s house before you went there for the first time? : A. Probably two, once on the phone and once on the way there. Q. And how, how long was it or approximately how tong was it before you went there that you had your conversations with Haley Robson about going to Mr. Epstein's house before you went there for the first time? A. Ask that one more time, piease. Q. Do you know what the word prior means? It means before -A. Before it happened. Q. Okay. Prior to you going to Mr, Epstein's house for the first time, how ‘ong was it before that that you had this conversation with Haley } Robson? Was it like a month beforehand, two months |i beforehand, six months beforehand? 10 (Pages 34 to 37) (561) 832-7506

OONAMSBUYNeE Mr, Epstein's? A. Probably a few times. Q. How many? A. Before I took -- I don't remember when I took Lauren, so I can't tell you how many times I had been there before I took her. Q. What's your best estimate? A. I don't know when I took her, so f don’t know how to answer that question. Q. Well, do you know if it was more than three times? A. Lam sure. Q. Was -- how old was Lauren when you took her there? A. I don't know how old Lauren was when I took her there, I think she was 18. Q. So, Lauren was out of high school by then? A. She might have been a senior in high school or she could have been out of high school. Q. And she was one year ahead of you? 4. Yeah. Q. So, that would have meant that you were taking her -A. She could have been her senior year in high school, or she, I could have been a senior year Page 135 in high school. Q. So, it could have been in your junior or senior year of high school? A. Yeah. Q. And you said you first went in the middle of your sophomore year, right? A. Uh-huh. Q. So, under your recollection of events would it be a fair characterization that at the point in time that you took Lauren to Mr. Epstein's, you had been to Mr. Epstein's on several occasions? A. Yeah. Q. At the point -- as of the point in time that you took Lauren there, had you -- had all the massages that you performed for Mr. Epstein been conducted in the same manner as what you have described in the first three visits? MR. HOROWITZ: Object to the form. THE WITNESS: I don't know when I brought her there, so I don't know -- you're asking me the same question. BY MR, LUTTIER: Q. At the point in time that you brought her, had all the massages that you had performed for Mr, Epstein been like the first three? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Page 136 |} A. I don’t remember when I saw her there, so I don't know, fike, if they were the same. Q. Okay. Well -A. What are you, like, I ~ Q. Did there come a point in time after the third massage that the way you performed massages on }; Mr. Epstein changed? i A. It progressively got worse, yes, but T don't recall. Q. When you say worse, what do you mean by worse? A. He would get more, like, aggressive, like, he would be more friendly. Like after, like, going there a couple of times, then he would ask me, oh, will you take your top off, and then the next time when I would get up and go to leave, he goes, take your bra off or, you know, next time you go can you take your pants off, or it progressively got worse, and then next time it was like, he like used a vibrator on me, and then the next time he used a vibrator and fingering me, and then the next time he would do that and then licking my clit, and then before that, grabbing my nipples and at last, I mean it progressively got worse. Q. When you say the next time, you mean there Page 137 was one visit, and then literally the next visit he E said, take your top off, and it was literally the next visit that he said something else, and literally the next visit he said something else -A Yeah, Q_ -- or were there more than one visit -A, It progressively got worse. i Q. Was there more than one time you performed [i massages between these events? MR. HOROWITZ: Object to the form. THE WITNESS: Ask that again. What do you -- you talk lke. BY MR. LUTTIER: Q. Let's take the fourth visit, what happened ‘on the fourth visit? A. Got a massage, takes my shirt off, take my underwear, like 1 just said. Q. Well, I'm asking you about the fourth visit now, First of ali, can you teil me when the fourth visit happened? A. It happened after the third visit. Q. Okay. Probably happened before the fifth visit, too, right? A Yeah. } MR, HOROWITZ: Argumentative. Can we take |; "35 (Pages 134 to 137) (561) 832-7506

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein y, Edwards, et al. Case No,: 50 2009 CA 040800XXXXMBAG ATTACHMENT 4

Page 1 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No. S02008CA028058XXXXMB AD Plaintiff, JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF E.W. VOLUME I Thursday, May 6, 2010 12:31 - 3:39 p.m. 250 South Australian Avenue Suitei500 West Palm Beach, Florida 33401 Reported By: Jeana Ricciuti, RPR, FPR, CLR Notary Public, State of Florida Prose Court Reporting Agency, Inc. 832-7500 ronically signed by Jeana Ricciutl (601-280-428-9381) ronically signed by Jeana Ricciuti {601-280-428-9381) 3423¢265-fedd-4b5d-9b63-48d7777dcc88 p61 PROSE COURT REPORTING AGENCY,

Page 114 Page 116) A. No. 1 $200 and her $200 for me to take her there, and that he Q. Did L.M. ever ask Melissa to go? 2 wanted young girls, as she was such; with no tattoos, ag i A. 1 don't know. 3 she was such; to massage, give him a massage, take off E Q._ Did any other of your friends ask Melissa to 4 your clothes, and then I would leave the room. And E g0 fo Mr. Epstein's home? 5 whenever ] went -- when | was taken there and whoever 1 A. Idon't know, 6 was taken there by left the room, he would -- you know, Q. Was Melissa the same age as you were? 7 want me to either get -- leave my bottoms on or get A. No. 8 fully naked, and he would want me to stand on the side Q. Older or younger? 9 of him as he touched my breasts. He wanted me to touch A. Younger, 10 his nipples, lick his nipples, you know, various things, Q. When you told -- when you asked Melissa ifshe {11 As he grabbed my butt, as he grabbed my breasts, as he q would go, you had already been to Mr. Epstein's house, | 12 touched my vagina, you know, and as he ejaculated, 1 was correct? 13 doing those things. A. Correct, 14 Q. Allright. And you told Melissa this? F Q. . Okay. How many times had you been to 15 A. Yeah. i Mr. Epstein's house when you asked Melissa to go? 16 Q. And when you said, do you want to come to his } A. I would say over five to ten times, somewhere 17 house, do you want to go to his house — E in between there. 18 A. Would you like to go to his house to make (i Q. And were ~ i9 $200. f A. It varies, I don't know. 20 Q. And she said? f Q. Was Melissa aware that you were going there? {21 A. No, he's a pedophile. : A. Yes. 22 Q. And what did you say to that? E Q. And did she ever ask you what happened at 23 A. Okay, I understand, Mr. Epstein's home? 24 Q. Allright. And did you -- did you think that li A. Yes, 25 Mr. Epstein -- did you think he had problems? Well, let [ Page 115 Page 117} Q. Okay. And did you tell her? 1 me ask it this way. | A. Yes, 2 A. Yeah. E Q. And what was her -- what did you tell her 3 Q. Did you know what Mr. Epstein was doing at the e happened those five or ten times? 4 time? That is, the first time that you went, did you E A. Itold her that] -- = perceive and think this is wrong? E Q. Before -- tet me -- let me just withdraw that 6 A. Of course, E question. 7 Q Allright. And so every time that you went to E Before -- 8 Mr. Epstein's house from the first time -- i A. You're not done? 9 A. Iwas aware. Q. ‘Before you asked Melissa to go to 10 Q. ~ you were aware that what ~ from your Mr. Epstein's home, if J understand it cotrectly, you 4h opinion, that what he was doing was inappropriate and may have been at Mr. Epstein's home five, ten times; is 12 wrong? fF that correct? 13 A. Correct, A. To the best of my knowledge, 14 Q. Okay. And did you understand that -- that is, : Q. Allright. And you would tell Melissa what 1s you understood that, your mind understood that? You : ‘Went on at Mr, Epstein's home? 16 knew it but you still voluntarily returned each time? A. Yes. 1? A. Iwas homeless. Q Okay. 18 MR. EDWARDS: Form. A. When 1 asked her to go, J fold her it's - you 19 THE WITNESS: I was homeless when I went to li know, pretty plain and obvious that I would tell her 20 his house, okay? Do you understand? Have you ever |} why. 21 been homeless? I’m sorry. I'm sorry. I'll Q. And did you — when you told her what had gone [22 withdraw that question because I know I'm not the [ On at Mr. Epstein's home and you asked her if she wanted |23 one asking the questions here. ] was homeless. I to go, what did you tell her? 24 Was a young child, okay? When J went to his house, 25 yes, I knew it was wrong. Yes, I knew he was.a-~ A. Ltold her that, you know, he would pay me 281) 832-7500 ally signed by Jeana Ricciuti (601-280-428-9381) ally signed by Jeana Ricciuti (801-280-428-9381} PROSE COURT REPORTING AGENCY, 30 (Pages 114 to 117): INC. (561) 832-7506 34230265-fcdd-4b5d-9b63-48d7777dc06B

Page 255 ‘A. I just went through ~ J calied Yellow Cab and {had Yellow Cab pick me up and then I had Yellow Cab ‘drive me to her house, pick her up, and then we went to ffrey's, and Jeffrey paid for it. Q, How many people had you taken to Mr. Epstein's house prior to Jane Doe 6? 1 mean, the least, like 1 said earlier, 20 to girls at + at least. Q.: How many girls did you take after Jane Doe 67 ‘A. I'm sory, repeat that first question. My first question was, is: How many females know, I don’t know how many people I've taken fore Jane Doe 6. Q. Do you know how many females you took after Doe 6? ‘A.J could tell you altogether it was about 20 to females at the least I took to his house, Q. Did you consider yourself to be a pimp? Page 257} Q. So she was acting as a pimp for you? MR. EDWARDS: Form, THE WITNESS; Right. BY MR. CRITTON: Because she made money off taking you there? Correct. i‘ Okay. Did you consider yourself'a prostitute? Have you ever considered yourself to be a prostitute? A. With Jeffrey Epstein, yes. Q. With anyone else? A. No. Q. So you considered yourself to be a prostitute with Mr, Epstein and you knew what you were doing — A. Was wrong. Q. -- was wrong? A. Yes. Q. And so you participated, and I know your view, but you participated in whatever wrongful activity was occurring at the same time, true? A. True, as a 15-year-old juvenile, true, 14-year-old, 15-year-old juvenile, true. Q. Let me ask you about Jane Doe. How many of Jane Doe's -- well, let me strike that. Page 256 ‘MR. CRITTON: Q. Why not? You were ~ you were taking females ‘Mr. Epstein's house for them giving themselves — ving their body for sexual activity for hire, true? “MR. EDWARDS: Form. ‘THE WITNESS: Yeah, true, but I just never Jooked at myself as a pimp or anything like that. Thonestly -- honestly had a conscience about what Iwas doing. I wasn't proud of it by any means. Q. Well, but you -- you know what a pimp is, It you? ‘A. Yes, ‘Q. And you knew what a pimp was at the time, <A, I'm not ~- 1 can't answer that honestly. I ‘hight not have known what a pimp was at that time. Looking back, do you understand that you were as a pimp? “MR. EDWARDS: Form. .. THE WITNESS: I -- sure, you know, MR. CRITTON: Q. And L.M., when she took you, she received money for taking you? A, 832-7500 ‘Signed by Jeana Ricclutl (601-280-428-9381) ally signed by Joana Ricchutl (601-280-428-9381) PROSE COURT REPORTING Page 2588 When you knew Jane Doe, before she went to Mr. Epstein's, were you -- were you aware of -- well, I think you said you were aware that she wouid smoke pot, she would drink with you, trae? A. True, Q. Were you aware of boyfriends that she had before she went to Mr. Epsiein's home; that is, what her relationship history was? A. No, I really didn't know much about her other than she was Melissa's friend. Q. And you -- you said you had met Batu (phonetic), correct? A. Correct, Q. When did you say the last time was that you spoke with Jane Doe? A. When she had her baby, Q. Do you know what year that was? A. No, I don't. Q. If] was to suggest it was in ‘08, would that meet with your recollection? A. Iwas going to say somewhere around there. Q. Did you ever tell Jane Doe that you had filed a lawsuit against Mr. Epstein? A. Yes, Idid. Q. And how did — how did the subject come uy 17 (Pages 255 to 258) AGENCY, INC. (561) 832-7506 9317 a9f6-1d08-4ae5-a354-0b880e5B4a2c

Q. Did she -- and did she ever tell you that Mr, Epstein had ever used any physical force directed to her in any way? A. No. Q. And in fact, Mr. Epstein never used any physical force or coercion to you, did he? MR. EDWARDS: Form. THE WITNESS: Other than masturbating in front of me and, you know, totally taking advantage of my home -- living situation and my whole situation in general, my innocence and everything else. 1 mean, if you don't call that taking advantage of me physically, I don't know what -- what - what you do call taking advantage of somebody physically. MR. CRITTON: Move to strike as. non-responsive, BY MR. CRITTON: Q Let me ask you this question: Did Mr. Epstein ever physically threaten you at any time? MR. EDWARDS: Form. THE WITNESS: As in, what, like put his hands on me? BY MR. CRITTON: Q. No, physically threaten you. MR. EDWARDS; Form. Page 204 THE WITNESS: Like, I'm going to hurt you? BY MR. CRITTON: Q. Yes, ma'am. A. No, he never said he was going to hurt me. Q. He was never violent with you, was he? MR. EDWARDS: Form. THE WITNESS: I guess -- what do you consider violent so I can answer this — BY MR. CRITTON: Q. Physically violent with you. MR. EDWARDS: Form. THE WITNESS: Physically violent, as in I'm going to hurt you, basically? BY MR. CRITTON: Q. Yes, ma'am. A. No, he never said he was going to hurt me. Q. ‘You never felt threatened by Mr. Epstein, did é you? : A. Yes. By his authority, definitely. : Q. Did you feel physically -- did you feel -- you say threatened by his authority, was that every time you ! were there? ) A. Of course. ' Q. Did he ever try to restrain you in any way? ; A. Yes. (561) 832-7500 tronically signed by Jeana Ricciuti (604-280-428-8381) ‘ctronically signed by Jeana Ricciuti (601-280-428-6381) Page 203 SYM eUne PROSE COURT REPORTING AGENCY, girlfriends, you know. Sono, I never laid out a : Page 205 Q. In what way? } A. There was times where he's put - inserted his H fingers in my vagina and I didn't wanthim to. Afterit ff was done and I tried pulling away, and he did not release his fingers from my vagina. So that's being a little bit physical with somebody. Q._ Let me ask you this; When L.M. told you that she had been going to Mr. Epstein’s house, what did she tell you? I mean, other -- she told you that you could make $200 if you go to his house, or if you bring another girl you could make $200, correct? A. Yes. L.M. really wasn't up front with me, She didn't tell me that he was going to masturbate in ; front of me. She told me it was a massage for $200, and |] basically that you did have to ~ you could get ; undressed or you didn't have to get undressed and massage him for $200. Q. Prior to the time that -- well, let me strike that, When. L.M. told you about Mr, Epstein, did she ask you if you wanted to go? A. Excuse me? Q When L.M. told you about Mr. Epstein, did she tell you -- or ask you if you wanted to g0? A. Not right away, no. Page 206 Q. She just told you about him? A. Yes. Q. Atsome point, did she ask you if you wanted to go? A. Yes. Q. And did you say, sure? A. Yes, after she told me that ail J would have to do is massage him and I didn't have to take my clothes off, I had the choice to take my clothes off if I 1 didn't have to, and you know that -- yeah, he had é a great mansion and he had a chef and we could go there [ and, you know, get food cooked for us and hang out ina ff wonderful house and get paid $200 for just giving E somebody a massage, you know, yeah. Q. Had you ever -- had you ever given someone a massage before? A. No. Q. Did -- did you tell her that you had never given.anyone a massage, her meaning L.M.? A. Well, no, I never — no, I didn't say L.M., 1 never gave anybody a massage, no. Q So basically, she -A. Imean, besides -- | mean, actually me and L.M. would, like, massage each other, but we were 4 (Pages 203 to 206) INC. (561): 832-7506 9317a9f6-1d08~4ae5-a354-Db880e584azc

m W N ow OO NY DH 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Page 215 A, Sure. Oz And she told you that you didn't have to get naked if you didn't want to, true? A. True. Q. So you get to the home the first time. What happens next? A. I get to the -~ we get there, we enter through the door. We go through another door, and now we're in his kitchen. We go through another door that looked like it would be a closet. We walked ~~ which is actually a stairwell. We walk up the winding stairwell. We open up the door, and now we're in, it looks like a hallway. We enter -- we have to -- we go to the right, we open up another door, which leads into another door. We open up that door, and now we're in his bedroom. We walk around his bed, which would be curving to the left. We open up a door, and now we're in his bathroom. She opens up a closest, shows me where the massage table is. She telis me, okay, help me pretty much set up the massage table. We get the massage table, she shows me where all the lotions are, all Bath bE ; l & Body Works lotions. She asked me to pick out a lotion, whichever ones I want, whatever one I want, set it on the table, make sure that my jewelry was off my hands, and then we had to sit on the couch and wait for (661) 832-7508 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) 9317aSf6-1d08-4ae5-a364-0b880e584a2c

Page 216 1 him to come in. 2 And he comes in, I introduce myself to him and 3 he takes off his robe and is completely nude underneath 4 his robe. He lays on the -- on the table, he puts like 5 a towel like where his butt would be so he’s not 6 completely nude. He has a towel over his butt, and we 7 give him a massage for about 30 to 45 minutes as he's 8 talking on the phone, and it seems -- what seemed to me 9 like he was handling business. 10 Q. Let me stop you there for a minute. Can you 11 give me a date that you went the first time? 12 A. No. 13 Q. An approximate date? 14 A. August of 2002. 15 Q. And what makes you believe it's August of 16 2002? 17 A. Because I know it was like kind of right 18 before the ninth grade -- ninth grade, you know, going 19 into the ninth grade. 20 Q. Were you living with L.M. at the time? 21 A. Yes. 22 Q. Was L.M.'s dad aware she had been going over 23 there? 24 A. No. 25 Q. Did L.M. tell you how far -- many times she I aerial aaiene ree eaaiaonet (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) 931 7a9f6-1d08-4ae5-a354-Db880e58sa2c

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 3

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 502008CA028051XXXXMB AB Plaintiff, ~Vvs- VOLUME I OF IT JEFFREY EPSTEIN, Defendant. VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF L.M. Thursday, September 24, 2009 9:40 ~ 5:52 p.m. 250 Australian Avenue South : Suite 115 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida 5 Prose Court Reporting ,o* ye ws Ce {561) 832-7500 PROSE COURT REPORTING AGENCY,. INC. (561) 832-7506

Page 73 THE WITNESS: What did I do to Jeffrey and what did Jeffrey do to me? I went up there T can't count. And I would be on multiple times. a massage table massaging his legs. He would turn over. His penis would be hanging out. He would put a vagina or a vibrator to my vagina. He would touch He would touch my vagina with his fingers. He would try to kiss my mouth. He my breasts. He would would bring my hands towards his penis. ask the little girls that I was with, hey, can I can I just see it, I know, but let me just see your vagina, even if they would say no. Can I, oh, Let me just see it. Sick mother just see it. fucker. I would like him in this room. BY MR. LUTTIER: Q. Any sexual act that you performed with Jeff? A. Is that not a sexual act when you put a ibrator to your wife's pussy; is that not a sexual act? Q. Any act that you performed with Mr. Epstein hat you haven't described thus far? A. Let me see. I went there multiple times. here was multiple things that I have done with Jeffrey nd Jeffrey has done with me. Did you perform any act ‘My question stands. _® INC. (561) 832-7506 PROSE COURT REPORTING AGENCY,

Page 74 with Mr. Epstein other than what you have described thus far? A. Besides standing there with my legs wide open “and his little fetish with me pinching his nipples -- he is probably getting hard right now -~ with my little ‘12-year-old girlfriend standing next to me, both naked, no, I can't think of any other sexual acts I have done with Jeffrey. Q. And, and did you say that you went there multiple times? A. Yeah. QO. How many times would you say you went? A. More than, more than 50 times. Q. Did you keep a record of the number of times you went? A. Unfortunately I didn't. Ox And were there occasions when you contacted either Mr. Epstein or people on his behalf asking that you be allowed to come over? A. They would call me most of the time, but, yes, there was multiple times I would call them. Q. And for, and who did you call? A. I called the house phone, 655-7273. I don't know. There was multiple house numbers. I would talk to Sarah. I would talk to the one -PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

MR. EDWARDS: Object to the form. MR. LUTTIER: .Is that right? THE WITNESS: When I performed sexual favors for him? MR. LUTTIER: Massages or whatever you did. THE WITNESS: Yes. BY MR. LUTTIER: Q. The first time you went was sometime in the summer of ‘02, according to you; is that right? A. Yes. Oy And between the summer of '02 and October cf ‘04, you can't tell us how many times you went, right? A. Oh, I can definitely tell you it was over -I, I personally went over 50, over 60, over 70 times. Q. Weli, which is it 50, 60, or 70? A. I would say 70. QO. All right. And what's that based on? A. That's based on the girls that I brought. I know that I brought over 70 girls. Q. It's now 70 girls that you brought. Have you ever -A. T have brought many, many, many girls. Q. Have you looked at your answers to interrogatories to see what you said under oath about 832-7500 PROSE COURT REPORTING AGENCY, INC. {561} 832-7506

: ; i ; i Page 603 Page 605 MR. LUTTIER: That's exactly what | am £ all that you said | don't want to do this and Jeff asking her. 2 said you had to do it anyway? MR. EDWARDS: Okay. Let's ask it that way | 3 A. Yeah. [told him that at times I did not want because it doesn't sound like that. 4 to bring girls, and he says, yes, I want you to do it BY MR. LUTTIER: 5 anyway; you need to do it anyway. Q. Doyou know of any information that these 6 Q._ And did you tell all the girls that you witnesses have based on your communications with 7 brought that Jeffrey would respect their wishes, and them? 8 if they were uncomfortable doing anything, that they A. Excuse me? 9 shouid just tell him that, and he wouldn't ask them Q. Do you know any information that any of 10 to do anything that they weren't comfortable doing? these witnesses have about this case based on your il A. Yes, because I was scared. personal contact with them? 12 Q. And that’s, in fact, how he treated you, A. What witnesses? 13 tight? Q. That are listed in the Answers to 14 A. Yes, Interrogatory 5, 15 Q. You previously earned a degree as an MR. EDWARDS: Just answer his question, 16 esthetician; is that right? yes or no. 17 A. Yes, THE WITNESS: No. I don't know these 18 Q. And you now eamed a degree since going to people, 19 Mr. Epstein in massage therapy, correct? BY MR. LUTTIER: 20 A. Yes, E Q. On any visit that you went to see Jeffrey 21 Q. And you earned both of those from the same Epstein, did he ever ask you to do anything that you [22 school located on Northlake Boulevard? said you did not want to do? 23 A. Yes. : A. Yes. 24 Q._ And you could pursue a profession as an : Q._What did he ask you to do that you said 25 esthetician, a massage therapist if you so chose, Page 604 Page 606 you didn't want to do? 1 could you not? A. At one occasion he wanted to stick his fingers | 2 A. No, not as a massage therapist, 4 like all the way inside of me and I said no? 3 Q. Why not? Q. And what did he then do when you said no. 4 A. Because I've told you once before I need to A. He said okay. So then he just penetrated my 5 take the nationals. vagina with his fingers, 6 Q. But no one has prevented you from taking Q. What did he, did he - when you said you 7 test, right? didn't want him to do that, did he respect your 8 A. Thave to wait to take the test, It only wishes and not do it? 9 happens twice a year. A. No, Actually he, he pushed it. He tried to 10 Q. And has -- did you pass the first do it and he said, okay, no, it’s going to be okay. 11 opportunity you had? E It's going to be okay. And I backed off and I saidno. {12 A. No. 7 Q. And then he stopped? 13 Q. Okay, So, when's, when's the test coming E A. Then he decided to respect my wishes. 14 up? | Q. Okay. Any other -- and this is on one 15 A. Ina few months. ; occasion? 16 Q. And are you going to take it? : A. Many occasions. l7 A. Yes. Q. Well, on -- so on many occasions he would 18 Q. And you could have been working as an say he wanted to penetrate your vagina. You would {19 esthetician ever since you went to Jeffrey Say you didn't want -- well, actually what you said 20 Epstein's? was he wanted to penetrate your vagina deeply I 21 A. And I did work as an esthetician. think. And, and you said no and he respected your 22 Q. No one has prevented you from doing that, wishes and didn't do it? 23 correct? A. Correct, 1) 832-7500 ‘catty signed by cynthia hopkins (601-051-976-2934) ‘cally signed by cynthia hopkins (601-081-976-2934) {cally signed by cynthia hopkins (601-051-976-2934) PROSE COURT REPORTING AGENCY, INC. A. No, 27 { Pages 603 to 606) (561) 832-7506 b5542fef-d299-4e4f-9ba6-85aad27#4405

Page 141 ne MR. EDWARDS: Okay. 2 THE WITNESS: From what I recall, Maybe I 3 told her I was making money. Maybe I didn't. 4 BY MR. LUTTIER: 5 Q. Which was it? 6 A. Idon't know. I forgot. 7 Q. It would be an, an event that you would 8 remember since it was one of your best friends that youl 3 were doing this with, right? 10 MR. EDWARDS: Object as to the form, 11 argumentative. 12 THE WITNESS: I brought every girl I could 13 find because it was an extra $200. 14 BY MR. LUTTIER: 15 Q. And you didn't think there was anything wrong 16 _withit, right? 7 A. Oh, I knew there was definitely something 18 wrong with it. 19 Q Allright. So, you consciously knew that you 20 shouldn't be doing what you were doing; is that a 21 correct statement? 22 A. Correct, 23 Q. You did it anyway, right? A. Correct, Obviously just like all these other girls did, isn't that funny. Page 142 1 Q. It was your free choice though? 2 A. Yeah, free choice. 3 MR. EDWARDS: Objection. 4 BY MR. LUTTIER: 5 Q. And it was E.W.'s free choice to do it? 6: A. Yeah. 7 Q. And she did it wide open because you told her 8 exactly what was going to happen? 9 A. Oh, yeah, it was so easy, let me tell you. 10 Q. And it was, it was -- and you did it for the aL money; is that right? 412 A. At that time, yes, I did, after walking into a3 his mansion, And after my dad, he had to only buy m 14 Dollar Store clothes, you damn right ! did it for the 15 money. 16 Q. Did you share with Carolyn or E.W. any of the 17 money that you got paid by Jeff Epsiein for bringing 18 her? 19 A. No, not that I recall. 20 Q. So, you just kept that money. What did you do 21 with the money that you got from Jeffrey Epstein to 22 bring E.W.? 23 A. Lactually saved a lot of it. I would save a lot of it, and I would buy clothes, clothes that I didn't have. I would bu: shoe fai (561) 832-7500 PROSE COURT REPORTING AGENCY, Page 143) couldn't afford, the new things that were out, you know 2 so I conid be the cool kid. 1 would buy whatever was, was cool that day. Q. And where did you bank? Where did you put this money that you saved? A. Ina hiding place in my house. Q. So, you didn't put it in a bank? A. Iwas 13 years old. No, I didn't put it ina damn bank. Q. And when you say a hiding place in your house, F which house are you referring to? E A. Inmy trailer. Q. At your father's? A. Yeah. Q. And did you tell your dad about it? A. No, not at the beginning. I told my dad that T was cleaning houses later on. Q. And was that a true statement? A. No. Q. So you lied to your father? A. Yeah. Q. Did you tell E.W. anything else before you took her to Mr. Epstein's house the first time? A. Not that I recall. I said we're going to go there in a taxi. Bverything will be paid for. Page 1449 Everything would be taken care of. Don't worry. It's a b quick 30 minutes. We will be in and out. We're going to make $200. Q. Each? A. Each. Q. Right. And did you tell her anything about, anything she should say about her age? A. Not that f recall. I said just don't say anything. ‘What do you mean? I don't understand what youg ie: E I said don't say anything. . Don't say anything about what? . Don't say anything about your age. E . Oh, so you did say something to her about age? — Yes. : . All right. Teil me as best as you can recall what you told -A. [said E.W. —Q. Wait a minute. Let me finish my question -what you told C.W. with respect to any questions asked ff about age? A. I said E.W., don't say anything about your age. >aPerseo Q why 36 (Pages 141 to 144) INC. (561) 832-7506

Page 416 advantage of a person who doesn't want to be taken advantage of. Q. So, when you say you were raped by Jeffrey Epstein, that's the definition you're using? A. Correct. Q. Jeffrey Epstein never had sexual intercourse with you, right?. . Nope. . Never penetrated an orifice of your body? . Yes, he did. . What orifice did he penetrate? . He, he penetrated my vagina. . With what? . With his fingers, with a vibrator. With, with a vibrator. Tell -- describe this vibrator that you say he penetrated your orifice? A. It was about a foot long and the head of it was about the size of a small plate, pretty big, pretty powerful right onto my vagina. Q. Did you say onto or did you say he penetrated your vagina? A. He penetrated my vagina with his fingers. He! also penetrated my vagina with the vibrator, Q. So, the vibrator you just described you Page 417 said had this big head, that was inserted into your vagina? A. Itwas not inserted. It was -Q. Placed on the outside of your vagina? A. Yes. Q. Did you achieve an organism when this happened? A. Nope. Q. And then you say he inserted his fingers into your vagina? A. Yes. Q. And on how many occasions did that happen? A. I've been to Jeffrey Epstein's house so many times, I can't recall how many times he's inserted his fingers into my vagina. Q. Was -- had you had intercourse, or excuse me, had you had any type of sexual contact with a male before your first sexual encounter with a female? A. Excuse me? Q. Had you had any sexual encounter with a male before your first sexual encounter with a female? A. Ihave had an encounter sexually with a man oy OMOIKDNAEWNHH Page 418 B woman. E Q. Okay. And do you remember the first time} you. had sex with a male? ( . Excuse me. Yes. . When was that? . was probably just turning, just ~ 1, I was | . Just turning 14? . Twas 14. Do you know -- you started by saying "just tuming, " If I remember correctly -- 1 can look up § your birthday here. Let's see. Your birthday is July 26, 19887 A. Correct. Q. So, with whom did you have this first sexual encounter with a male? . His name was Dustin. . And what sexual encounter did you have? . Sexual intercourse. . Just straight sexual intercourse? . Llost my virginity. . Okay. This is, and is this guy's last name 2 Lange? A. Yes. Q. And was that before Jeffrey Epstein? Page 419} . No. . Are you sure? . Was that before Jeffrey Epstein, no. . Are you sure of that? . Positive. Okay. And at the time who was Dustin Lange (phonetic) to you? A. Boyfriend. Q. Had you been dating him for some period of time or just somebody you happened upon? A, Yeah, we were dating. Q. And what specific acts did you and he engage in, just sexual intercourse? . Yes, . Did you ever perform oral sex on him? . Yeah, . And did he perform oral sex on you? . 1-- probably. And do you have any idea how long it was between the time you had your first sex with Dustin } Lange and when you had your first encounter with a| female? A. No. Q. But by the time you were 15 you had had 7 with a boy before Thad any type of sexual acts with al 25 s 832-7500 PROSE COURT REPORTING AGENCY, 21 (Pages 416 to 419) Inc, (561) 832-7506

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 2

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119~MARRA/ JOHNSON JANE DOE NO. 2, Plaintiff, -vsJEFFREY EPSTEIN, Defendant. VOLUME III Related cases: 08-80232, 08-08380, 08-80993, 08-80811, 09-80591, 09~-80656, 08-80381, 08-80893, 0609-80802, 08-80994, 09~-80463, 09-801092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE Wednesday, September 30, 2009 9:37 a.m. - 6:10 p.m. One Clearlake Centre 250 South Australian Avenue, 1st Floor West Palm Beach, Florida 33401 Reported By: Pamela J. Sullivan, RPR, Prose Reporting Agency, FPR, Inc. CLR (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) (561) 832-7506 92ef5b62-38a5-4202-a350-6633a5c681 3b

Q. You said he touched you. How did he touch (561) 832-7500 Electronically signed oy Pamela Sullivan (501-333-772-1852) Electronically signed by Pamela Sullivan (501-333-772-1552} Page 377 Page 379} 1 ever did he ever touch you? L touch you on any of the visits? 2 A. Yes. 2 A. He always -3 Q. Okay, On how many accasions? 3 Q. Is that what you said, about the sixth time? 4 A. He always did, but he just got more 4 A. He always touched me. 5 aggressive about it, And, eventually, he wanted to use 5 Q. Where? 6 like sex toys on me. 6 A. He touched my breasts. He touched my vagina, 7 Q. Did he -- did he ever physically touch you on 7 He always touched me, 8 any occasion? 8 Q. Did you ever tell him -- well, let me strike 9 MR. EDWARDS: Object to the form. Asked and 9 that. 10 answered, 10 He couldn't touch you, unless you allowed him [f 1 THE WITNESS: What do you mean? 1. to touch you; correct? [i 12 BY MR. CRITTON: 12 MR. EDWARDS: Form. 13 Q. Did he ever touch you? You -- you were 13 BY MR. CRITTON: 14 touching him, because you were giving him a massage; | 14 Q. You had to voluntarily allow him to touch 1s right? 18 you? 16 A. Yes. 16 MR. EDWARDS: Form. E 17 Q. And that's something that you were doing 17 THE WITNESS: I don't know what you mean. {} 18 voluntarily? 18 BY MR. CRITTON: 19 MR. EDWARDS: Form. 19 Q. Well, the very first time you were there, I 20 THE WITNESS: That was something that he told 20 think you said he didn’t touch you; correct? 21: me to do, yes. 21 A. No, I did not say that. 22 BY MR. CRITTON: 22 Q. Okay. Did he touch you the very first time 23 Q. But you had to get to the house. There's no 23 you were there? ‘way you could give him a massage, unless you made the} 24 A. Yes. decision to go to his house; correct? Q. Okay. Where? Page 378 a MR. EDWARDS: Form. 1 A. My vagina. i 2 THE WITNESS: Yes. 2 Q. And when he touched you there, did he -- did 3 BY MR. CRITTON: 3 he -- was there any type of penetration, or did he just 4 Q. Okay. Because he couldn't force you to do 4 touch you? $ anything, unless you were at the home. Andevenifyouj 5 MR. EDWARDS: Form. 6 were at the home, all you had to do was to say, no; 6 THE WITNESS: 1 don't remember. 7 correct? 7 BY MR. CRITTON: 8 MR. EDWARDS: Form. 8 Q. Okay. When he touched your vagina -- with 9 THE WITNESS: 1 didn’t feel that way, no, 9 his hand? 10 BY MR. CRITTON: 10 A. Yes. li Q. Well, if you did — if you didn't feel that 1a Q. What did you say to him? 12 way, that is that you didn’t have a choice, your choice | 12 A. I didn't say anything. B 13 was then I'm not going to Jeffrey Epstein's home ever 13 Q. Okay. Had anyone ever touched your vagina § 14 again; true? 14 before? Had a male ever touched your vagina before} as A. No. 15 A, No. 16 Q. Okay. Did you take money every time you wen Q. And when he touched your vagina, did you 17 to Mr. Epstein's home? say -- and your -- when you say your vagina, on the 18 A. Yes, exterior of your body; right? 19 Q. Did you ever say, Mr. Epstein, i don't want A. Yes. 20 your money, I don't want to come back again? Q. Did you say, please don't do that? 24 A, No. A. I didn't say anything. 22 Q. You could have, though; couldn't you? Q. You could have. You just didn't; tue? 23 A, [didn't know that I could have. MR. EDWARDS: Form. PROSE COURT REPORTING AGENCY, Page 380 THE WITNESS: I didn’t know what to say. 31 (Pages 377 to 380) INC. (561) 832-7506 92efSb62-38a5-4202-a350-6633a5c6313b

Pagé 436 | Fa UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME IV of IV JEFFREY EPSTEIN, Defendant. / Related cases: 08-80232, 08-08380, O8-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 / CONTINUED VIDEOTAPED DEPOSITION OF JANE DOE Thursday, March 11, 2010 1:11 - 4:28 p.m. 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1431 61) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 ically signed by cynthia hopkins (601-051-976-2934) PAlcally signed by cynthia hopkins (604-061-976-2934) ‘ally signed by cynthia hopkins (601-061-976-2934} 831330d-3380-4b69-a7ce-a6b7480dd7 12

ODYHDAUSWNE Page 525 . Do you have friends on your Facebook? Yes. . Is E.W. on your Facebook? . No. }. Is Jane Doe No. 6? No. Did you ever do any type of a journal or keep any records -A. No. Q. Maybe it would be helpful if I finished the question. A. I didn't, so... Q. Younever kept a journal or records for anything? A. No. Q. Your whole life? A. No-- yes, my whole life, yes. I have never kept a journal for my entire life, that is true. Q. Allright. Have you -- did you ever keep any record of any dates that you went to Mr. Epstein's home? A. No. Q. How do you know when the last time is that you went to Mr. Epstein's home? A. [just know how old I was, that's ail. (561) 832-7500 Page 526 Q. Okay. And you were how old? A. Seventeen. Q. Do you remember whether you had just turned 17? A. Ijust turned 17. Q. Which would have been in mid June of 2005, correct? A. Idon't know. Q. Well, ‘88 and 17 would be 2005, right? MR. EDWARDS: Form. THE WITNESS: I don't know. BY MR. CRITTON: Q. Since your last deposition -- in fact, let me ask you as of today: How many times do you believe you went to Mr. Epstein’s home now having, thought about it? A. Idon't know. Q. Was it more than once? A. Yes. Q. Was it more or less than ten times, or do you not know? A. T'm pretty sure it was more than ten times. Q. Was it more or less than 12 times? A. Yeah, I'm pretty sure it was more than that, t ir best estimi as to how ma Electronically signed by cynthia hopkins (601-051-976-2934) Electronicalty signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins {601-051-976-2934) WLOIDRAEwWHE PROSE COURT REPORTING AGENCY, Page 527k times you went to Mr. Epstein’s home? A. Idon't know. Like 17. Q. Arid I think you testified you never took anyone to Mr, Epstein's home, correct? A. Yes. Q. That's correct? A. Yes. Q. Lasked you a little bit, 1 asked you at your last deposition what occurred at the first time that you went to Mr. Epstein's home. And whatever you said will be obviously on the record, so it will be there. But I want to bring you back to that time so I can ask some follow-up questions. It's my recollection, correct me if I'm wrong, please, is that when you went to Mr. Epstein's home L.M. was the one who took you, correct? A. Yes, Q. And it was your testimony that when you, at some point during the time you were in Mr. Epstein's home the first time, you took off your clothes in conjunction — A. Yes. Q. — with LM, correct? A. Yes. Page 528 Q. And you understood that you were going to receive money for basically providing a, a massage to Mr. Epstein in the nude, correct? A. No. Q. Okay. You understood that you would be receiving money for what? A. Going with L.M. Q. And did you even, even understand what you ‘were supposed to do? A. No. Q. Just you were going with to, to a person's house in Palm Beach and you were, or someplace, and you were going to receive $2007 A. No, Q. Teli me again then, refresh my recoliection, please. A. Iwas going somewhere with Tatum for some money. Q. And you had no idea how much? A. No. Q. That's correct? I'm sorry, I asked a double negative. That's my fault. You had no idea how much money at the time, correct? A. Yes. 24 (Pages 525 to 528) INC. (561) 832-7506 $9831330d-3380-4b69-a7ce-abb7480dd7 12

A. No. Q. That's true? MR. EDWARDS: Form. THE WITNESS: I don't know. BY MR. CRITTON: Q. Tcan't hear you, ma'am. A. Isaid now I'm confused again. Q. Okay. Well, you said on the first occasion you did not recall whether he ever penetrated into your vaginal, into your vagina, true? A. Yes. Q. Okay. On the second occasion, would the same be true? You said the same thing happened every time. So would it be true that you don't know whether he penetrated your vagina on the second occasion? A. I don't remember. Q. And would that be true for all those visits; you don't remember whether he ever penetrated your vagina? A. [know that he did at some point, but I cannot] tell you that it was on the seventh visit. Q. Can you tell me any visit that he penetrated your vagina? A. What? Q. Can you identify any visit; that is, whether it was the third or the fifth or the seventh or the tenth? A. Ican't, I, 1 don’t know how many times I went there, I can't identify a specific visit. I just know that at some point, yeah, he did do that. . Okay. And he did that on one occasion? A. No. . More than one occasion. . Yes, . On how many occasions? . Tdon't know. . On the occasions -- was it more than twice that he penetrated your vagina? A. What? Q. Did Mr, Epstein on more than one occasion penetrate your vagina? A. Yes. Q. Okay. And you don't know whether it was, it could have been two, it could have been three, you just don't know, correct? A. Yeah. Q. On the other occasions when you went to ey . Page 5668 your vagina and your breasts, after the first visit did you ever tell him no, I don't want you to do that? A. No. Q. Okay. Did you ever move away from him and say, I don't -- move away from him so that he couldn't touch you? A. I don't know. Q. You returned to his house a number of times before, at least you claim, that he ever penetrated your vagina, true? A. No. % MR. CRITTON: Would you read my question [f back to me, please, or let me just see it and i see if I can see that far. (A portion of the transcript was read back by the reporter.) BY MR. CRITTON: Q. Let me rephrase the question again. Just a minute ago you told me, I don't know when he penetrated my vagina; I just know he did; that is, 1 don't know whether it was on the seventh visit or the fourth or the tenth, or, because you don't know how many times you were there, true? Page 567} A. Yeah. Q. Allright. So, you were at least at his house on a number of occasions before, at least you claim, that he penetrated your vagina with his fingers? MR. EDWARDS: Form. BY MR. CRITTON: Q. True? MR. EDWARDS: Form. It misstates the witness's testimony. THE WETNESS: No, he -- it was, I don't know, probably like the first or second time he had started to put his fingers inside me. BY MR. CRITTON: Q. Okay. Well, } just asked you about 20 minutes ago whether he penetrated you on the first occasion, and you said you don't remember — A. Well, because ~ Q. ~ did not remember, A. -- I don't remember. But I can't obviously teli you I don't remember because you're going to force me to come up with a fucking number that is impossible, I don't bave a number, I can't say the second or the 4 first or the third or the fourth. I don't know. I 33 (Pages 564 to 567) (561) $32~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) b831330d-3380-4b69-a7ce-a6b7480dd712

Page 565 A, What? Q. Can you identify any visit; that is, whether it was the third or the fifth or the seventh or the tenth? A. Fcan't, I, don't know how many times I went there. 1 can't identify a specific visit. I just know that at some point, yeah, he did do that. . Okay. And he did that on one occasion? . No. }. More than one occasion. . Yes, . On how many occasions? . I don't know. Q. On the occasions -- was it more than twice that he penetrated your vagina? A. What? Q. Did Mr. Epstein on more than one occasion penetrate your vagina? A, Yes. Q, Okay. And you don't know whether it was, it could have been two, it could have been three, you just don't know, correct? A, Yeah, Q. On the other occasions when you went to Mr, Epstein’s home and he touched the exterior of Page 566 your vagina and your breasts, after the first visit did you ever tell him no, I don't want you to do that? A. No. Q. Okay. Did you ever move away from him and say, I don't -- move away from him so that he couldn't touch you? A. I don't know. Q. You returned to his house a number of times before, at least you claim, that he ever penetrated your vagina, true? A. No. MR. CRITTON: Would you read my question back to me, please, or lef me just see it and see if I can see that far, (A portion of the transcript was read back by the reporter.) BY MR. CRITTON: Q. Let me rephrase the question again. Just @ minute ago you told me, I don't know when he penetrated my vagina; I just know he did; that is, ] don't know whether it was on the seventh visit or the fourth or the tenth, or, because you don't know how many times you were Page 567 A. Yeah. Q. Allright. So, you were at feast at his house on a number of occasions before, at least you claim, that he penetrated your vagina with his fingers? MR. EDWARDS: Form. BY MR. CRITTON: Q. True? MR. EDWARDS: Form. It misstates the witness's testimony. THE WITNESS: No, he -- it was, I don't know, probably like the first or second time he had started to put his fingers inside me. BY MR. CRITTON: Q. Okay. Well, 1 just asked you about 20 minutes ago whether he penetrated you on the first occasion, and you said you don't remember ~~ A, Weil, because -Q. —did not remember, A, —Idon't remember, But I can't obviously tell you I don't remember because you're going to force me to come up with a fucking number that is impossible, I don't have a number. I can't say the second or the first or the third or the fourth. I don't know. [ don't know. Page 568 § Q. Okay, But he didn't do it every time, did he? A, Pretty much every time, yeah, he did. Q. Did he ever use anything other than his finger? A. Yes, he did. Q. Okay. What did he use other than a finger? A.. He used a massager, Q. Okay. What did the massager look like? A. Idon't know. Q. Did you see it? A. Yes. Q. What did it look like? What color was it? A. It was white, Q. And what size was it? A. Idon't know. Q. And was it like a back massager? A. Tdon't know. Q. And what did he do with it? A. He used it on me. Q. In what way? A. He put it on my vagina. Q. He put it on your vagina? A, Yeah. = — 34 (paces 565 to 568) {561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthla hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) b831930d-3380-4b69-a?ce-a6b7480dd712

DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No.: 50 2009 CA 040800XXXXMBAG ATTACHMENT 1

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50-2008-CA-028051 XXXX MB AB L.M., Plaintiff, vs. JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN TAKEN ON BEHALF OF THE PLAINTIFF DATE: February 17, 2010 U.S. Legal Support (561) 835-0220

9 10 iL 12 13 14 22 23 24 25 February 17,2010 INDEX WITNESS DIRECT CROSS REDIRECT RECROSS JEFFREY EPSTEIN BYMR.EDWARDS 4 EXHIBITS FOR IDENTIFICATION PAGE 1 Jane Doe number 102 versus Jeffrey Epstein complaint. 35 2 Document, Nonprosecution Agreement. 135 CERTIFIED QUESTIONS Page Line 6h 22 123 20 146 «14 1481 153 5 18913, 162 3 The videotaped deposition of JEFFREY EPSTEIN in the above-entitled and numbered cause, was taken before me, TERRI BECKER, a Registered Professional Reporter and Notary Public for the State of Florida at Large, at 444 West Railroad Avenue, in the City of West Palm Beach, Palm Beach County, in the State of Florida, beginning at the hour of 11:15 o'clock a.m., pursuant to. the Notice in said cause for the taking of said deposition which is annexed to the court file berein, on behalf of the PLAINTIFF in the above-entitled action pending in the above-named court, The appearances at said time and place were as follows: FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Attorneys for Plaintiff 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 BY: BRADLEY J. EDWARDS STEVEN R. JAFFE, ESQ. BURMAN, CRITTON, LUTTIER & COLEMAN Attomeys for Defendant 303 Banyon Boulevard, Suite 400 West Palm Beach, Florida 33401 Tel: (561) 842-2820 BY: MICHAEL PIKE, ESQ. ALSO PRESENT: JOE ROVNER, Videographer (U.S. Legal Support) explanation. THEREUPON, JEFFREY EPSTEIN being by Terri Becker first duly sworn to tell the whole truth, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MR. EDWARDS: Q Can you give us your name, A Jeffrey Epstein. Q Mr. Epstein, you made a comment when you came in the room that you were appreciative of me being respectful to your housekeeper yesterday and | intend for that to be the same with you today. J want to start by asking you, at this point we've gone through a lot of discovery in this case. There aren't many disputed facts as to what actually happened at your house, Generally I think you would agree that you derived a way for young females to come to your house and engage in varying degrees of sexual activity, some of the girls as young as 12, some of them as old as seventeen or so, most in between, but as of yet you haven't provided an I want to provide you an opportunity to tell the jury at this time why you did it. MR. PIKE: I'm going to object. Confusing, compound and irrelevant, as worded. A You know, I would Jike to answer that question, frankly. However, at this time, my attorneys have told me that I can't and [ must invoke my Fifth, Sixth and Fourteenth Amendment tights or 1 risk losing their counse). Accordingly, I therefore assert those rights. Sorry. MR. PIKE; In addition to that I'll move to strike counsel's statement as a narrative, as well. MR. EDWARDS: I understand. I wanted to provide him an opportunity, if today was going to be the day. MR. PIKE: Same thing, move to strike, Q Mr. Epstein, how long have you been sexually attractive to underage minor females? MR. PIKE: Objection, harassing, argumentative. A Are you kidding? Q No, I mean, I don't feel like I'm 2 (Pages 2 to 5) U.S. Legal Support (561) 835-0220

SYA BRWNe 10 ll 12 13 14 15 16 17 18 19 20 21 22 23 24 divulging any secrets here, right? MR. PIKE: Move to strike. Q That's the question that's pending. A_ [would like to answer that question as well, as all your other questions today, however, I have to follow my attorneys' advice. They have told me J must invoke my Fifth, Sixth and Fourteenth Amendment right to not answer those questions today, or any questions relevant to this lawsuit, so accordingly, I'm going to assert those rights and -- under the constitution guaranteed by the Fifth and Sixth, and Fourteenth atnendment. Q Would you consider yourself addicted to sex with minor females? MR, PIKE: Same objections. A You know, Mr. Edwards, again, I want to be very respectful. As the current U.S. Attorney has described your law firm as a criminal enterprise and part of one of the largest frauds in Florida's history, it has been reported that your firm has fabricated multiple cases against me in order to fleece unsuspecting investors out of millions and millions of dollars, so _ unfortunately at this time, although I would like _ to answer that question, on advice of counsel 1 will have to refrain and assert my Fifth, Sixth and Fourteenth Amendment right, Q Can you then provide an explanation for what relevance that soliloquy of yours has fo, whether or not you engaged in sex acts with L.M. ‘When she was a minor? MR. PIKE: Objection, no, he cannot. Argumentative. Compound, harassing. MR. EDWARDS: Mr. Pike, with all due respect, it was not my idea for him to give this speech about a former RRA law firm L was asking to elaborate on that. MR. PIKE; Counsel, I'm working with your follow-up question. MR. EDWARDS; [ understand. MR. PIKE: I'm objecting, object to the form and stating the reasons on the record why the form is required to be objected to, based upon your question. MR. EDWARDS: Will he elaborate on the relevance of that soliloquy to his touching L.M. when she was 13, 14 and 15 years old in asexual manner? MR, PIKE: I'm going to object again, SYA whe o 10 1. 12 13 14 15 16 LT 18 ig 20 21 22 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 argumentative, compound, harassing and irrelevant. Q You cau answer, A Twould like to answer, however, f'm going to have to assert my Fifth Amendment, Sixth Amendment, Fourteenth Amendment right as advised by my counsel, otherwise I risk losing their advice. Q Mr. Epstein, have you ever been diagnosed with a sex addiction to minors by a psychologist or other medical professional? A Lintend to respond to all of your questions at some relevant time; however, today at the present time, my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I nist accept their advice or tisk losing my Sixth Amendment rights to effective representation, Accordingly, I assert my Fifth, Federal -- Fifth and Sixth and Fourteenth Amendinent rights, to the United States Constitution. MR. PIKE: In addition to that, Mr. Edwards, as the Court has ruled on several ___ matters, Mr, Epstein's medical bistory is not relevant at this time nor has he placed same at issue in this case. MR. EDWARDS: Understood, Q Mr, Epstein, were you sexually abused as a minor? A Again? Q Were you sexually abused, as a minor? A You know, again, I would like to respond to all -- if any questions seem to be relevant. T would like to respond to any relevant question at this time; however, my attorneys have counseled me that [ cannot provide answers to the questions relevant to this lawsuit today. I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly then, I assert my Fifth, Sixth and Fourteenth Amendment right to the United States Constitution. Q Isn't it true that you have engaged in some sexual interaction with hundreds of underage minor females in the last ten years of your life? Is that true? MR. PIKE: Objection, relevance, A Mr. Edwards, the current U.S. Attorney has described your law firm a3 a criminal 3 {Pages 6 to 9) U.S. Legal Support (561) 835-0220

enterprise and part of the largest fraud in Florida's bistory. It has been reported that your firm fabricated multiple cases, many, many multiple cases against me in order to fleece unsuspecting investors out of millions and millions of dollars. Unfortunately, at this time in response to your question, my attorneys have advised me that I must assert my Sixth Amendment, Fifth Amendment, Fourteenth Amendment right. Though, i believe, you know, that I would really like to answer your questions today, but at this moment I must assert those rights or risk having my attorneys resign. Q You're invoking your Fifth Amendment rights to each of these questions because you know your answers will incriminate you and you feel it will result in you being prosecuted for your crimes; isn't that right? MR. PIKE: Objection, argumentative, harassing. Calls for a legal conclusion. Q You can answer. A No, in fact, the Supreme Court recently said the Fifth Amendment right is there to protect the innocent, so, that’s the way 1 would Like bo answer that Q Are you actuaily telling the jury that you didn't commit the crimes that have been alleged against you by the various females that were under age when you engaged in sex with them? Are you telling the jury that right now? MR. PIKE: Objection, argumentative, harassing. A. I would like to respond to that question, as you know, however, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, | assert my Fifth, Sixth and Fourteenth Amendment right under the United States Constitution. Q Mr. Epstein, you understand that this is the video that will be played to the jury in L.M.'s trial against you and L.M. wants answers. ‘The jury is going to want answers, so I know that your're telling us that you're going to respond at some time in the fature; but the time is now. Would you like this opportunity ¢o explain why you engaged in sexual activity with L.M. beginning when she was 13 years old and you were) 50 years old? MR. PIKE: I'm going to object once again. We are getting way too argumentative with the questioning. The questioning is compound. It is speculative and it is also harassing. Whether or not this deposition video, thereof is played in front of a jury is a question of fact, and it will be determined by a judge pursuant to a motion in Jimine, various portions thereof may or may not be played, so having placed those objections on the record I'm going to instruct Mr. Epstein not to answer that question. MR. EDWARDS: Mr. Pike, I don't know if you watched the 13 hours of harassing questions to L.M., that she sometimes invoked her Fifth Amendment rights, I understand the adverse advice that would be given and she was made to answer these questions and these exact same questions were asked of her, in fact, I'm using the phraseology from Mr, Luttier. I'm not trying to harass him. Q_Fm simply asking him to explain to the_ 13 jury. If you're saying it didn't happen, if you're saying it did happen, explain to the jury why you did it. That's ail I want to hear, I'm being respectful about this. MR. PIKE: In an effort to keep a clean record be respectful to the to the court reporter rather than having a diatribe back and forth between you and myself, I'll move to strike your last statement as irrelevant. Let's move on. Q Is it true, Mr. Epstein, you were born January 20, 1953? A Yes. Q Where? A New York. Q Where in New York? A Brooklyn. Q Did you go to high school there? A Yes, sir. Q Where? A_ Lafayette High School. Q After high scheol did you attend college? A Yes. @ Where was that? 4 (Pages 10 to 13) U.S. Legal Support (561) 835-0220

14d | New York. What college did you attend? Cooper Union. Sorry, I didn't hear, Cooper Union. No, sir. How many years were you in college? I believe, two. What did you study? Physics. Why did you leave college early? ] intend to respond to all relevant questions regarding this lawsuit, however, at the present time my attorneys have counseled me that J cannot provide answers to questions that may be relevant to this lawsuit, so accordingly I assert my constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment. Q Are you invoking your Fifth Amendment rights as to why you left college, is it safe then to presume that that answer you believe would incriminate you in some way? MR. PIKE: I'm going to move to strike, Speculative, argumentative, harassing. FOPrPOFrFOrPOrO > O> Calls for a legal conclusion, and I know exactly what you're trying to do here, Mr. Edwards, is lace the record with questions that would ultimately give you an adverse inference at any potential trial of this matter, so having put that on the record, I'm going to instruct him not to answer that question, based upon his Fifth, Sixth and Fourteenth Amendment rights to the United States Constitution, MR. EDWARDS: With all due respect you cannot invoke his Fifth Amendment rights, your attorneys instructed me in that fact -MR. PIKE: He can. MR. EDWARDS: That L.M. Had to do it herself, so, [ would fike to hear it from Mr. Epstein. Q Can we assume you're invoking your Fifth Amendment rights as to why you left college early, that that answer you fee! would incriminate you? MR. PIKE: Once again, move to strike for the same reasons, ‘You can answer. A I've already answered the question, Did you get a degree from Cooper Union? | i i OyYAORwWNe 18 19 20 21 22 23 24 1¢ I'll restate the answer. 1 would like to respond, intend to respond, and would like to respond to all questions today. However, counsel has advised me I must take the Fifth, Sixth and Fourteenth Amendment right under the U.S, Constitution. Q After college where were you employed? A_ You know, I would like to respond fo all your questions today, however, on advice of counsel, [ intend to take the Fifth, Sixth and Fourteenth Amendment rights provided by the United States Constitution or risk losing my counsel's representation, Q Isn't it true that you were a teacher at the Dalton School in New York after college? A. Again, I would like to respond to all your questions; however, my attorneys have counseled me that J cannot provide answers to any questions today regarding to this lawsuit so [ must accept their advice or risk losing my Sixth Amendment tight to effective representation. Accordingly, I assert my Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment of the constitution. 2M, Epstein, did you haye sex with any 17 underage students while teaching at the Dalton School? A Could you repeat that? Q Yes, Did you have sex with any underage students while teaching at the Dalton School in New York? A. Mr. Edwards, your firm has been described by the U.S. Attorney as one of the largest -- as a criminal enterprise, perpetrating one of the largest frauds in Florida's history. It has been reported that your firm fabricated multiple cases against me and others in order to fleece unsuspecting investors out of millions and millions of doilars. Unfortunately at this time in response. to your question, my attorneys have advised me 1 must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights, though I believe you know I would like -- really like to answer your questions but at this time ] must assert those rights or have my attorneys resign. MR. EDWARDS: Mr. Pike, I think you know he has a couple of options here. He can answer questions or he can invoke his Fifth Amendment rights. This nonresponsive. 5 (Pages 14 to 17} U.S. Legal Support (561) 835-0220

verbiage regarding the RRA law firm is not one of the options, it’s inappropriate in the deposition and I would ask you to instruct your client not to obstruct this process any further. | am not going to terminate the deposition. I want it to finish, but obviously this is going to be the subject matter of some motion in the courts and you know the judges will not appreciate this. 1 would like to just move this process along by eliminating that portion of his answer. I understand what he is saying. | get it, but that's not something responsive to any of the questions and J think you know it is inappropriate. MR. PIKE: | think the deponent is answering the questions, If you believe the responses are inappropriate and feel you can take it up with the Court with the motion you are speaking of, as you've done then you can, as you've done several times before. Q After leaving the Dalton School, is it true that you began working as a money manager at Bear Stearns? A | intend to respond to all your questions regarding this lawsuit at some relevant time, however, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. Since the U.S. Attorney has described your law firm as acriminal enterprise, Mr. Edwards, and a part of the largest fraud in Florida's history, | am going to assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights to the U.S. Constitution. Q Isn't it true that while you were working at Bear Stearns you were already engaging in sex with underage minors? A. Again, 1 believe you know the answers to those questions, but ~ Q Yes, A. May I finish? Q Ido, MR. PIKE: Moye to strike, Let the witness — Q Sure— MR. PIKE: Let the witness answer your question. MR. EDWARDS: | would love for him to finish the questions, 20 MR. PIKE: Mr, Edwards, as you know there are serious Fifth, Sixth and Fourteenth Amendment constitutional rights at issue here, and the witness is attempting to answer your questions to the best of his ability, despite how laced they are with adverse inference presumptions. MR. EDWARDS: 1 don't want the adverse inferences. | want the answers, that’s it, I don’t want the adverse inferences. MR. PIKE: Having said that, please allow the witness to answer to answer the question. A Can you please repeat the question? Q Isn't it tree while working at Bear Stearns you were already engaging in sex with underage minor females? A. As your firm has been described by the U.S. Attorney, as a criminal enterprise, using some of the cases fabricated against me, personally, 1 would like to answet that question today; however, upon advice of counsel I must assert my Fifth, Sixth and Fourteenth Amendment rights under the U.S. Constitution or, in fact, risk losing their representation. 21 Q At some point in time while at Bear Stearns you met and managed the money for a fellow named Leslie Wexler, correct? A Again, I would like to answer all questions relevant to this lawsuit, but today I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment right to the U.S. Constitution. Q 1% fact, I read in another deposition of yours that you de not consider yourself to be homosexual, correct? A_ (No response.) Q You've answered that question before, correct? A Correct. Q Do you consider yourself to be bisexual? A No. Q Inany event, you did develop a sexual relationship with Leslie Wexler at some point in time; is that true? A No, Q Did you have a business relationship with Mr. Wexter? A Jintend to respond to all relevant 6 (Pages 18 to 21) U.S. Legal Support (561) 835-0220

questions, I would like to answer most of your questions, Mr. Edwards, today, however, especially since your firm has been described by the United States Attorney in South Florida as a criminal enterprise purported to -- purported to have put -- pulled off the largest fraud in Florida's history, 1 would like to answer it, however, my attomeys here today counseled me I must assert my Fifth, Sixth and Fourteenth Amendment right under the U.S. Constitution, therefore I'm going to do that. Q Are you saying because Rothstein, Rosenfeld, Adler was determined fo be a criminal enterprise or somebody was running @ criminal | enterprise out of that law firm, that is the i reason why you are not going to answer these | questions today? You linked that together in \ that answer. I just want to make sure I'm understanding that right? A I'm going to take the Fifth -- [ intend to respond to all relevant questions today. I would like to respond; unfortunately my attorneys have counseled me I can't, | must assert my Fifth, Sixth and Fourteenth Amendment rights under the U.S. Constitution. 23 Q Because other Jaw firms have asked very similar questions and you haven't responded to any of theirs either. I just want to understand what the relationship between Rothstein, Rosenfeld, Adler is to you invoking your Fifth Amendment rights today, if you can articulate that for me. MR. PIKE: Form, compound, argumentative. | A Rothstein, Rosenfeld, Adler has been ! described by the U.S. Attorney as a criminal | enterprise and as part of the largest fraud in | Florida's history. It has been reported that | your firm fabricated multipie cases using me, and | i against me in order to fleece unsuspecting investors out of millions of dollars. Q Another long time friend of yours is Ghislaine Maxwell, right? A intend to respond to all relevant questions. I would like to answer most of these questions today, but I can't because my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept their advice or risk losing my Sixth Amendment right to effective representation, 257, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Therefore I'll assert my Constitutional rights under the Fifth, Sixth and Fourteenth Amendment, THE WITNESS: Excuse me, could we take a break? MR. EDWARDS: Already? THE WITNESS: Restroom. THE VIDBOGRAPHER: Going off the video record 11:38 a.m. THE WITNESS: Thank you. (Pause in the proceedings.) THE VIDEOGRAPHER: We're back on the video record at 11:48 a.m. Q How did you meet Ghislaine Maxwell? A [intend to respond to all relevant questions to this lawsuit; however, at the present time my attorneys have counseled me that J cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing effective -- my right to effective representation. Accordingly, therefore, I assert my Fifth, Sixth and Fourteenth Amendment rights to the U.S. Constitution. -Q_ You would agree, would you not, that __ 25 Ghislaine Maxwell shares your sexual obsession for underage minor females? MR. PIKE; Argumentative, speculation, harassing. A You know, Mr, Edwards, the current U.S, Attorney has described your law firm as a criminal enterprise, and as taking patt in one of the largest frauds in Florida's history. It has been widely reported that your firm fabricated multiple cases of a sexual nature against people -- other people and me, in order to fleece unsuspecting investors out of millions of dollars, so unfortunately at this time in Tesponse to your questions, my attorneys have advised me 1 must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights, though 1 believe, as you know, 1 would really like to answer these questions, but at this moment, although at this time I have to assert those rights or risk losing effective counsel. Q Do you know Annie Farmer? A Tintend to respond to all relevant questions regarding this lawsuit; however, at the present time my counsel has advised me that J cannot provide answers to any questions relevant 7 (Pages 22 to 25) U.S. Legal Support (561) 835-0220

1 2 3 4 5 6 7 8 26 to this lawsuit. Your firm has been described as acriminal enterprise, and is part of the largest fraud in Florida's history fabricating sexual cases against me and others. Therefore, unfortunately, although I would like to answer all of your questions today, I'm going to have to agsert my Fifth, Sixth and Fourteenth Amendment right, Q Did you and Ghislaine Maxwell sexually assault Annie Farmer at Leslie Wexler's house? A. Jintend 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 and must accept this right or tisk losing my Sixth Amendment rights to effective presentation. Accordingly, T assert my Constitutional rights as guaranteed by the Fifth, ‘Sixth and Fourteenth amendments to the U.S, Constitution. Q Stating Ghislaine Maxwell and you had devised several schemes to lure underage girls to you for sex; isn’t that correct? MR. PIKE: Form, argumentative, harassing? Sram 27 A Mr. Edwards, your firm has fabricated multiple cases of sexual harassment claims and other types of sexual cases against me and others in order to be part of what the U.S. Attorney has described as the largest fraud, the largest fraud in Florida's history. I would like to answer all your questions; however, my attomeys have counseled me that at feast today, [ must assert my Fifth, Sixth and Fourteenth Amendment rights under the U.S, Constitution. Q De you own 2 home in Manhattan? A Tintend to respond to all relevant questions to this lawsuit, however, at the present time my attorneys have counseled me that T cannot provide answers to any questions relevant to this lawsuit, and [ must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, therefore, I have to assert my Fifth, Sixth and Fourteenth Amendment right under the U.S, Constitution. Q Do you own an island in the U.S. Virgin Islands? A [intend to respond to all relevant questions regarding this lawsuit, however, at the 1 a: 3 4 5 6 . 8 9 | 10 11 12 1 13 14 15 16 17 18 19 20 21 22 23 24 25 ad | | OAD ew 9 10 11 12 | 13 | 24 45 j 16 7 18 19 | al 22 23 24 25 28 present time my attorneys have counseled me that 1 cannot provide answers to any questions relevant to this lawsuit, no matter how much I would like to, Therefore, ¥ must accept their advice or risk losing my Sixth Amendment right to effective representation; therefore, | have to assert my Fifth, Sixth and Fourteenth Amendment right under the U.S. Constitution. Q Do you own a home in New Mexico? A. | intend to respond to ail relevant questions regarding this lawsuit and as I've had to do with most of your questions here today, I'm going to have to take my attorneys' advice and assert my Fifth, Sixth and Fourteenth Amendment right under the U.S. Constitution or risk losing effective representation. Q Isit true that you have had underage females, at each of those homes, for orgies with you and Ghislaine Maxwell? MR. PIKE: Form, argumentative, speculation and harassing. A_ | would like to answer that question. I really would. However, as your firm has been __Seserfbed by the U.8: Attortiey a a ortiinal enterprise, which its principal purpose was, racketeering conspiracy to generate money for the firm and its co-conspiritors through the operation of enterprise and through various activities including mail fraud, wire fraud and money laundering, and fabricating multiple sex cases against me and others, though I would like to answer your question today, Mr. Bdwards, my counsel has advised me I must take the Fifth, Sixth and Fourteenth Amendment right provided by the U.S, Constitution, Q De you know somebody named Galitsea (phonetic)? MR. PIKE: Can you spell that, for the record? MR. EDWARDS: No. MR. PIKE: Or for the court reporter? A No. Q You don't know the name? A No. Could you spell it? Q (Witness shrugs.) A Okay. Q Did your sexual ebsession with underage minor females grow at some point in time to allow you access to these underage minors every single 8 (Pages 26 to 29) U.S. Legal Support (561) 835-0220

1 day for sex? 1. would like to answer those questions, though at 2 MR. PIKE: Overbroad. Speculation, \ 2 this moment | must assert those rights or risk 3 argumentative, compound, harassing and | 3 tosing my attorneys, 4 confusing as well; as worded, Do you want | 4 Q Sure, let's test that answer, 5 to break it down, Mr. Edwards? 5. A Okay. 6 Q isn't it true that for the past ten 6 Q Let's talk about Jane Doe 102, Jane Doe 7 years you Nave found a way to engage in sexual 7 102, V.R., who was represented by Bob 8 conduct with underage minors on an every day 8 — Josephberg's firm, had nothing to do with 9 basis? 2 Rothstein, Rosenfeld, Adier, Do you know V.R.? 10 MR. PIKE: Speculation. Argumentative. 10 A Who? 11 A As your firm has been described as a 121 Q V.R. 12 criminal enterprise by the United States Atomey 12 A Can you spell it? 13 and is part of the scheme to defraud people in | 13 Q Common spelling, QF like the 14 — South Florida of millions of dollars, you have | 14 State ~ 15 fabricated sexual cases and sexual claims against 15 A Can you spell it for me, please? 16 people like me and others, Unfortunately at this 16 o =: 17 time although J would like to answer your 17 A What's the last name, how is it 18 — questions, Mr, Edwards, my counsel has advised me. 18 spelled? 19 = Fcannot. They have advised me I must assert my 19 Q oe believe. 20 — Fifth, Sixth and Fourteenth Amendment rights 20 A. intend to respond to all relevant 21 under the U.S, Constitution, 21 questions regarding this lawsuit; however, at the 22 Q Isn't it ruc that you have promised 22 present time my attorneys have counseled me that 23 + uaderage minors money or other benefits to engage} 23 | cannot provide answers te any questions that 24 — insexual conduct with you over the past ten 24 may be relevant to this lawsuit and I must accept years? this advice or risk Josing my Sixth Amendment 31 1 A Again, as I've answered many of your 2 — questions today, and unfortunately will probably 3 end up not answering most of your questions 4 today, as your firm has been described, the firm 3 bringing this lawsuit, I believe, if I'm wrong 6 please, correct me -7 Q You're wrong. 8 A. This is the firm that didn't notice this 9 — deposition? 10 Q Did not? 11 A Did not? 12 Q No. 13 A Lapologize. Though your former firm 14 has been described, and the person you represent, 15 L.M,, in this case was represented by the firm 16 _ that was described by the U.S. Attorney as 17 perpetrating one of the largest frauds in South 18 Florida's history, fabricating multiple sexual 19 cases against me and others in order to fleece 20 unsuspecting investors out of millions and 21 millions of dollars, so though unfortunately, 1 22 would like to answer each one of your questions 23 today, my counse! has advised me | must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment right, though I believe you know, I 33 1 tight to effective representation. Accordingly, j 2 Lassert my Constitutional rights as guaranteed 3 by the Fifth, Sixth and Fourteenth Amendment to 4 — the Constitution. 5 Q Just for the record, } can only spell it 6 the way it was spelled in your flight logs from 7 your airplane. I don't know exactly how she & — spelis her name, only how your pilot would spell 9 her name. 10 MR. PIKE: Form, speculating. iL Q If I misspell it ~ ; 12 MR. PIKE: Form, speculation, ; 13 argumentative, harassing. 14 MR, EDWARDS: That's harassing? {15 MR. PIKE; It assumes facts currently | 16 notin evidence in this particular | 17 deposition; therefore, I move to strike. 18 MR. EDWARDS: I was responding to his 19 question asking me how to spell her name. I 20 don't know how other than his own pilot. 24. MR. PIKE: Mr. Edwards, he asked you to 22 spell the name, you then spelled the name, 23 then went on with another narrative and there wasn't a question posed, on the floor. Q You would agree you interacted with V.R. 9 (Pages 30 to 33) U.S. Legal Support (561) 835-0220

34) every day in a sexual way, when she was 15 years | old, right? | A. Again, I'm sorry? Q Sure. You would agree that you interacted with V.R. sexually on an every day basis when she was 15 years old? A You know, again, Mr. Edwards, I would like to answer ali your questions here today. My attorneys have asked me -- advised me that I must assert my Sixth Amendment, Fourteenth Amendment} and Fifth Amendment rights provided by the U.S. Constitution and the fact that the current U.S. Attorney has described your law firm as a criminal enterprise, is one of the largest frauds in Florida's history for fabricating sexual -cases of a sexual nature against me and others. Unfortunately, although would like to answer those questions, if 1 do I risk losing my attorneys’ counsel. Therefore, T must assert my right. MR. EDWARDS: Madam court reporter, Il | attach as an exhibit, the Jane Doe number | 102 versus Jeffrey Epstein complaint, at i some point in time. It will be Exhibit 1, | as I'm going to go through some of the facts 35 “aK as alleged in the complaint and as will be testified to by the plaintiff. af (Jane Doe number 102 versus Jeffrey Epstein complaint was deemed marked ‘as Exhibit number i for identification, as of this date.) | MR. PIKE: Counsel, do you have an extra copy of that for me? MR. EDWARDS: No. MR, PIKE: May I look at it real quick? MR. EDWARDS: No. Ithas my noteson | it, MR, PIKE: [ understood, I saw the i highlights. MR. EDWARDS: The notes are highlighted | so when we copy it, it will not show up. MR. PIKE: Just for the record, that's a current, operative pleading, correct? MR. EDWARDS: Correct. THE WITNESS: What does that mean? MR, PIKE: There may have been some amendments to a complaint and I want to make sure that’s the operative complaint at issue that he is speaking of today. THE WITNESS: Can I go off the record i { | Oynnewne 9 10 ai 12 13 14 15 16 47 18 19 20 al 36 for a second? May 1 ask you a question? MR. PIKE: Sure. Can we take a break for a second? MR. EDWARDS: Again? THE WITNESS: Just a question. MR. PIKE: He wants to speak with me for a second. THE VIDEOGRAPHER: Off the video record 12:01 p.m. (Pause in the proceedings.) THE VIDEOGRAPHER: We are back on the video record at 12:02 p.m. Q Ist true, Mr. Epstein, that you and Ghislaine Maxwell forced V.R. to have sex with you on a daily basis? MR. PIKE; Form, argumentative, harassing, A Unfortunately at this time, though 1 would really like to answer those questions, and like I have done for most of your questions here ‘today, Mr. Edwards, your firm was described as a. criminal enterprise, a serious criminal enterprise by the current U.S, Attorney. Part of that criminal enterprise was fabricating cases sof = 37 a sexual nature against me and others in order to fleece unsuspecting investors out of millions of dollars, Though, unfortunately at this time no matter how I would like to respond to your questions, I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S, Constitution or risk having my attorneys resign. Q Isn't it true that V.R. was yours and Ghislaine Maxwell's sex slave from the time she was 15 through the time she escaped when she was 197 MR. PIKE: Again objection, argumentative, harassing. A Mr, Edwards, your firm has been described as - excuse me, as a criminal enterprise by the current U.S. Attorney and part of the largest fraud in Florida's history. Part of that fraud was fabricating multiple cases against people like me and others, of a sexual nature, in order to fleece unsuspecting investors out of millions and millions of dollars, so though I would like to answer that question, my attorneys have told me today I must assert my Sixth Amendment, Fourteenth Amendment and Fifth 10 (Pages 34 to 37) U.S. hegal Support (561) 835-0220

DBYAKHSUYNE © Amendment right. Q Isn't it true that you and Ghislaine Maxwell celebrated her 16th birthday with her and had sex with her on that day? MR. PEKE: Form. Compound, confusing, argumentative, harassing, A Mr, Edwards, [ would like to answer that question. My attorneys have told me today, I have to at least today assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights to the U.S. Constitution, especially my concern is, thet your firm has filed fraudulent lawsuits, fabricated lawsuits, and the U.S. Attorney, the current U.S, Attorney has described your firm as acriminal enterprise that -- whose main purpose was to generate money for the firm and its co-conspirators through the operation of various criminal activities, including mail fraud, wire fraud and money laundering. Q Are you saying that the complaint of L.M. against you, the allegation in that complaint, are false? MR. PIKE: Form. Misinterprets the witness's testimony. gitis true? MR, PIKE: Same objection. Q Itis either true or false? A_ TH repeat myself, unfortunately, but the current U.S. Attorney has described your law firm that filed that filed L.M.‘s claim -- was involved in the filing of L.M.'s claim, motions — I'm sorry, do you want to tell me what it was then? Would you like to tell me the firm's involvement in this lawsuit, since we will be here the rest of the day? Q Answer the question, A Allright. The U.S. Attorney has described that firm as a criminal enterprise perpetrating one of the largest frauds in Florida's history against unsuspecting investors, fleecing them out of millions of dollars by creating, crafting and fabricating fellacious (sic) sexual claims against people like me and others, so unfortunately, though I would like to answer your questions, Mr. Edwards, my counse! has advised me that at least today | must assert my Sixth Amendment, Fifth Amendment and Fourteenth. Amendment rights under the U.S, Constitution. Q Isn't it true, sir, and I'm reading from ' 40 the complaint filed by V.R. against you, isn't it true, sir, that a friend of yours sent you three, 12-year old females for you to sexually abuse on one of your birthdays? MR. PIKE: Form, argumentative, harassing, and irrelevant to this lawsuit. ‘THE WITNESS: Excuse me. A You're saying it is part of the lawsuit? Q Yes, Fl read it, "On one of the defendant Epstein's birthdays, a friend of defendant Epstein sent him three, 12-year old girls from France who spoke no English for defendant to sexually exploit and abuse? After doing so they were sent back to France the next day.” Isn't that trae? MR. PIKE: Once again, move to strike, irrelevant, argumentative, harassing, and for the record, the exhibit that's being read ftom is a complaint that’s unrelated to the instant matter and not filed or incorporated by the current plaintiff, L_M., in this matter. Ad would like to answer that question, I 41 really would; however, today my attomeys have told me I have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights] ~ of the U.S. Constitution, especially because your firm involved in this lawsuit has fabricated, widely reported, muitiple cases of sexual harassment cases against individuals like me and others, perpetrating what the U.S. Attorney called one of the largest frauds in Florida's history, fleecing people out of millions of dollars, so though } would like to answer that question, today I have to assert those rights or risk losing my attorneys" counsel. Q Isn't it true that you forced V.R. as 2 15-year old girl to have sex with numerous friends of yours? A Are you kidding? Q Reading from a lawsuit. A_ Sorry, Mr. Edwards, Though I would like to answer that question as well, as I've answered most of your other questions here today, 1 would like to respond; however, my attorneys here today have advised me I have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution, 11 (Pages 38 to 41) U.S. Legal Support (561) 835-0220

42 especially as your firm has been accused by the US. Attomey as being a criminal enterprise, and part of the largest fraud in Florida's history, Basically -- sorry, if] didn't read correctly, um.... the operation of the enterprise through various criminal activities including mail fraud, wire fraud and money laundering, fabricating sexual harassment cases against people like me and others. Q By the way -A Yes, sir? Q -- didn’t V.R. receive a round trip ticket paid for by you to Thailand, and she ultimately did not get back on the plane but instead escaped to Australia? A I would like to answer that question, but today I would have to assert my Sixth Amendment rights, my Fifth Amendment rights and my Fourteenth Amendment rights under the U.S. Constitution, especially since your firm has been described as perpetrating one of the largest frauds in Florida's history, fleecing investors out of millions of dollars, being described by the U.S. Attorney of South Florida, as a criminal enterprise engaged in various criminal activities 43 including mai! fraud, wire fraud and money Jaundering. Q_ Do you know a man named Jean Luc Brunel? A Can you spell it? Q_ He was at your house last week, does that remind you? MR. PIKE: Form, move to strike, speculation, argumentative, harassing. Is there a question on the table, Mr. Edwards? MR. EDWARDS: Yes. Q De you know him? A Can you spell his name for me, please? Q [don't need to spell his name. Do you knew who I'm talking about, Mr. Brunel? A. Sorry, Mr, what? Q Br-u-n-e-L A_ IT would like to answer that question as well, but my attorneys have counseled me today I have to assert my Sixth Amendment rights, Fifth Amendment rights and Fourteenth Amendment rights under the U.S, Constitution or risk losing my right to effective representation. Q What's the purpose for you asking me to 44 spell his name? Are you acting like you don't know him? MR. PIKE: Form, move to strike, argumentative and irrelevant as worded, Mr. Edwards, you know that there are various standing orders, if not in this case, in various other cases, that specifically describe the protections of the Fifth Amendment, Federal Courts have ordered that certain questions that you are asking shall not be answered or Mr. Epstein would risk losing his Fifth Amendment right -MR. EDWARDS: I understand that. He is asking to spell people's names, MR. PIKE: -- under the United States Constitution. A lot of these questions here today that you're asking have already been ruled on by various Courts, that the Fifth Amendment protects any response thereto, so 1 would like -- I'm giving you some leeway here with regard to the argumentative questions. We've already -- and I'm not obviously testifying for the witness, but we've already handled a fot of these issues. 45 in court and we have already adjourned one deposition for being argumentative, and I think you understand what the Court said there, so having said that, and I understand that you have a job to do, but having said that, I would like to caution you professionaliy, if you continue with the argumentative questions, I am going to have to terminate this deposition ~ MR. EDWARDS: | completely understand. MR. PIKE: Okay. We are here today to~ MR, EDWARDS: Mr. Brunel -MR. PIKE; I want the Court to know we are here today to allow you to ask your questions, but the harassing and argumentative tone is not going to be tolerated. MR. EDWARDS: We have a video. We can show the Court the tone. It is obviously not harassing. MR. PIKE: That's fine. Q Mr. Brunel is a long-term friend of yours, right? A_ intend to respond to all relevant 12 (Pages 42 to 45} U.S. Legal Support (561) 835-0220

questions of this lawsuit; however, today my attorneys have counseled me I cannot provide answers to any questions that may be relevant to this fawsuit and | must accept their advice or tisk losing my Sixth Amendment right to effective representation. Q You know him as somebody who has been caught engaging in sex with underage minors in the past; is that correct? MR. PIKE: Form. A You will have to repeat the question, I'm sorry. | Q You know Mr, Brune! as somebody who has been caught engaging in sex with minors in the past; is that correct? MR. PIKE: Form. A. intend to respond to all relevant questions regarding this lawsuit; however, at the present time my attorneys have counseled me that T cannot provide answers to any questions relevant to this fawsuit, and I must accept their advice or risk losing my Sixth Amendment tight to effective representation as your firm has been described by the U.S, Attorney as a criminal enterprise and part of one of the largest frauds in Florida's history specifically said you have been fabricating -- the law firm has been fabricating multiple cases of a sexual nature in. order to fleece unsuspecting investors out of millions of dollars, including mail fraud, wire fraud and money laundering, so unfortunately, though I would like to answer all your questions here today, I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment right. | Q You were involved in 2 modeling business | with him called M.C. Squared; is that correct? A Again? Q You were involved in a modeling agency with -A What do you mean -- i Q -- with Mr. Brunel called M.C. Squared? A "Involved" means what, what do you mean? Q You tell the jury your involvement with the modeling agency. You can clarify for me, I'l et you do that, MR. PIKE: Object to the form. A Lintend to respond to alll relevant questions regarding this fawsuit. However, at the present time my attorneys have counseled me il 12 13 14 15 16 17 i8 19 20 21 22 23 24 25 that 1 cannot provide answers to any questions relevant to this lawsuit and I must accept their advice or risk losing my Fifth, Sixth and Fourteenth Amendment rights under the U.S. Constitution. Q When you were being criminally investigated and V.R, was in Australia, is it true that you made a personal telephone call to her telling her not to come forward with any of the information she knew? MR. PIKE: Form. A Again? Q Putting a time frame on if, the time frame where you were being criminally investigated — A What time frame is that? Q Inher complaint it is not specific, but, let's just make it whenever. At some point in time did you place a telephone cail to V.R. in Australia warning her not to come forward with any information about you engaging in sex with her while she was a minor? MR. PIKE: Form. A Tintend to respond to all relevant questions regarding this lawsuit; however, at the 49 present time my attorneys have counseled me that T cannot provide answers to any questions relevant to this lawsuit and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Q With respect to underage females, isn't it true that you have made the statement, in quotes, “the younger the better"? MR. PIKE: Form. A. Again, as your firm has been described by the current U.S. Attomey as a criminal enterprise involved in mail fraud, wire fraud, money laundering, and specifically crafting, fabricating multiple cases of sexual -- of a sexual nature against people like me, and others, in order to fleece many, many unsuspecting investors out of millions of dollars; I would like to answer your questions here today, Mr. Edwards, but unfortunately, my attorneys have counseled me that I must assert my Fifth, Sixth and Fourteenth Amendment right or they will resign. Q Who are your current employees? MR. PIKE: Form. A. Say that again. 13 (Pages 46 to 49) U.S. Legal Support (561) 835-0220

17 18 19 20 21 22 23 24 25 dollars. 50 Q Who are your current employees, people who work for you, that you pay? A intend to respond to all relevant questions regarding this lawsuit; however, at the present time my attorneys have counseled me that T cannot provide answers to any questions that may be relevant to this lawsuit, or risk losing, my Sixth Amendment right to effective representation, Accordingly, therefore, I must assert my Sixth Amendment, Sixth Amendment and Fourteenth Amendment rights as provided by the USS. Constitution. Q Isn't it true you pay your employees to bring you underage minor females for sex? MR. PIKE: Porm, argumentative, speculation, harassing, A Mr. Edwards, your firm has been described the current U.S. Attomey as a criminal enterprise, a criminal enterprise, part of the largest fraud in South Florida's history; but part of that fraud was fabricating, um, fictitious cases against me ~ excuse me, against people like me, of 2 sexual nature, in order to fleece unsuspecting investors out of millions of Unfortunately at this time, though, 1 would like to answer every one of your questions, My attorney has advised me I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights or risk Josing them as my attorneys. Q Isn't it trac when underage females were brought to you, you would engage in sex with them and pay them? MR. PIKE: Form, argumentative, harassing. A (Witness shakes head.) Q Are you shaking your head fo say “no” — A Excuse me. Q Are you shaking your head to say “no, I don't know how to interpret that answer?" A I didn't realize I was shaking my head. MR. EDWARDS: I thought he was actually answering a question, MR. PIKE: We'll just strike. The rules ate well-known to every lawyer who practices in the State of Florida, that it is clear that a nod of the head or shake of the head is not understood by the record, so therefore Mr. Epstein was clearly not Sx32FoRUne Constitution. responding to one of your questions and you know that, Mr, Edwards. MR. EDWARDS: This is on the video. MR. PIKE: Nonetheless you know the rules. Nonetheless. If we have a question ‘on the table, would you please repeat it so can recall it and Mr, Epstein can endeavor to answer it, MR. EDWARDS: Sure, and if it was only the court reporter, E would agree, but the jury is going to see a video and everybody knows commonly, if somebody shakes their head, they are saying “no," and if that was the answer, I wanted to give him a chance to elaborate on it, that's it. Q Isn't it rue that when underage females would come to your house, you would engage in sexual activity with them and then pay them? MR, PIKE: Same objections. A_ Unfortunately I woutd fike to answer that question today, but my attorneys have counseled me that I must assert my Sixth Amendment right, my Fifth Amendment right and my Fourteenth Amendment right under the U.S. The fact that your firm has been described as a criminal enterprise and part of one of the largest frauds in Florida's -- South Florida's history, part of that fraud has been described as fabricating cases of sexual nature against me and others in order to fleece unsuspecting investors out of millions of dollars, I would like to answer that question, Mr. Edwards; however, today, I must assert my Fifth, Sixth and Fourteenth Amendment right. Q Imaddition to paying these underage females for sexual activity, you also paid them to bring their underage friends to you, to also engage in sexual activity with them? MR. PIKE: Form, Q Is that correct? A Tintend to respond to all relevant questions regarding this lawsuit; however, at the present time my attorneys have counseled me that I may not, and I must assert -- they have advised me J must assert my Sixth Amendment right, my Fifth Amendment right and my Fourteenth Amendment) rights under the U.S, Constitution. Q You would pay underage females 200 to $300 for engaging in sexual activity with you or 14 (Pages 50 to §3) U.S. Legal Support (561) 835-0220

54 for procuring another underage female to engage in sexual activity with you; is that correct? MR. PIKE: Form, move to strike, 1 Assumes facts not in evidence and calls for | a legal conclusion as well, argumentative. A. Tintend to respond to ali relevant questions regarding:this lawsuit; however, at the present time my attorneys have counseled me that { cannot provide answers to any questions that may be relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, therefore, [ must assert my } constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the U.S. Constitution. Q Would you agree that your scheme was devised to coerce these underage minors to bring you as many other underage minors, as were available for you to engage in sexual activity with? | MR. PIKE: Form. A Can you repeat the question? Q Yes, Would you agree that your scheme _.was devised to coeree undernge girls into 55 | bringing as many other underage girts to you, as were available for sexual purposes? MR. PIKE: Form. A_ Did you say "for sexual purposes"? Q Yes, for sexual purposes. A I'm not surprised. Since your firm was described as perpetrating one of the largest ' frauds in Florida's history by crafting, fabricated sexual harassment cases against people like me and others in order to fleece unsuspecting investors out of millions of dollars, I would like to answer that question. } However, today my attorneys have advised mel | must assert my Sixth Amendment, Fifth Amendment | and Fourteenth Amendment right under the U.S. Constitution, and if I don't do so, I risk losing -- uh... losing effective representation. Q Utilizing this method of using underage minors to bring you other underage minors, you were able to engage in sex with hundreds of wnderage minor females. Is that true? MR, PIKE: Form, argumentative, harassing and calls for speculation. A. Since, Mr. Edwards, your firm has been described as a criminal enterprise by the U.S. sexual activity with underage 56 Attorney, and as part of the largest fraud in South Florida’s history, and as part of the fraud fabricating malicious cases of sexual harassment and other cases of sexual nature against people like me and others, although I would like to answer that question today, my attorneys have advised me I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights of the U.S. Constitution. Although I believe you know I would really like to answer your questions, but at this moment if I don't assert those rights, I risk having my attorneys resign. Q Isn't it true with this method you were able to interact sexually with underage giris every single day? MR. PIKE: Form, asked and answered, Same objections. Q Go abead. A Oh, I'm sorry. Can you repeat it? Q Sure. With this method of -A "This method" being what, sorry? Q Your method of using underage minors to bring you other underage minors for sex; isn't it true that that method resulted in you engaging in Ors on al every 57 day basis? . MR. PIKE: Same“objections, A Your firm has been described by the current U.S. Attorney as a criminal enterprise engaged in one of the largest frauds in South Florida's history, and as part of that fraud, creating, fabricating, malicious cases of sexual nature against people like me and others, so unfortunately, though I would like to answer that question today, I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights to my counsel’s advisement io do, although I believe you know I would reaily like to answer those questions today, I must assert those rights or risk losing my attorney's representation. Q To keep track of all these underage minors, you stored their names and telephone numbers in your home computer; isn't that correct? MR. PIKE: Form, argumentative, speculation. A Again? Sony. Q Are you going to answer the question or just read? If you are going to answer the question, of course, I'li keep reading it as many 15 (Pages 54 to 57) U.S. Legal Support (561) 835-0220

times. A Excuse me? MR. PIKE: The witness is attempting to answer your question. He asked you to repeat the question. MR, EDWARDS: He is? MR. PIKE: He asked you to repeat the question. MR. EDWARDS: I don’t mind going through that, Mike, because I do want answers, but if Pm going to repeat the question multiple times and get the same answer, we are wasting time. I want to stop us wasting time repeating questions if I'm getting the same nonresponsive answer. MR. PIKE: £ understand your intention here. MR. EDWARDS: Yeah. MR. PIKE: -- however, these questions are similar in nature, if not identical to various questions that you've asked in other indications, so you coming here today is of no surprise that Mr. Epstein is required to invoke his Fifth, Sixth and Fourteenth _Amendment rights under the United States =. | 59 Constitution, — MR. EDWARDS: I understand that. MR. PIKE: -- if you came here today thinking you were going to pull a rabbit out of a habit, and Mr. Epstein was going to waive his Fifth, Sixth and Fourteenth Amendment rights to the U.S. Constitution, at least not today. That will not be occurring. Q Isn't it true that to keep track of the names and phone numbers of these underage minor females, to interact with sexually, you stored those names and phone numbers in your home computer? A Thank you. I've heard the question now. It didn't surprise -- again, I've now heard the question and the fact that your firm has been described as a criminal enterprise by the current U.S. Attorney in South Florida, and part of one of the largest frauds in Florida's history, it is reported that your firm fabricated malicious cases of a sexual nature against people and against me, in order to fleece unsuspecting investors out of millions of dollars. Unfortunately, though I would tike to 60 answer each one of your questions today, Mr. Edwards, my attorneys have advised me that | must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution. So although I would like to answer, I must assert those rights or risk having ty attorneys resign. Q Do you know Sarah Kellen? A _ [intend to respond to all relevant questions regarding this lawsuit; however, at the present time my attorneys have counseled me that T cannot provide answers to any questions relevant to this lawsuit and must accept their advice or risk losing my Sixth Amendment right to effective representation. Q Isn't it true you employed Sarah Kellen to contact underage minor femates and make them appointments to be at your house? A Sorry, again? Q isn't it true you employed Sarah Kellen for the purposes of contacting underage minor females and scheduling them appointments to be at your house? A The current U.S, Attomey has described your law firm, Mr. Edwards, as a criminal enterprise engaged in one of the largest frauds in South Florida's history. It has been reported that your firm fabricated multiple cases of a sexual nature against me and others, in order to fleece unsuspecting investors out of miflions and miltions of dollars, so, though unfortunately I would like to answer every one of your questions today my attorneys have counseled me that today T must assert my Sixth Amendment, Fifth Amendment. and Fourteenth Amendment rights under the U.S. Constitution. Though | believe you know I would like to answer those questions, although today 1 must assert those rights or risk having my attomeys resign. Q Tell the jury how you know Nadia Marcinkova, MR. PIKE: Form move to strike, MR. EDWARDS: Move to strike my question? MR. PIKE: (Nods.) MR. EDWARDS: What basis? ** MR. PIKE: Do I have to state a basis? Usually I'm just required to state "form." MR. EDWARDS: You have done more than, 16 (Pages 58 to 61) U.S. Legal Support , (561) 835-0220

e@uyuAveune 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CevH Hewne 10 iL 12 13 14 15 16 17 18 19 20 21 22 23 24 25 62; that today. MR. PIKE: If] went on a diatribe of explaining, you know, what's confusing, compound and relevant, then you would blame for testifying for the witness. So I just move to strike the question. MR. EDWARDS: Make sure you mark that | somewhere on this transcript, somehow. Q Tell the jury how you know Nadia Marcinkova? MR. PIKE: Move to strike. A [intend to respond to all relevant. questions regarding this lawsuit. However, at the present time my attorneys have counseled me that ] cannot provide answers to any questions relevant to this lawsuit and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment right under the U.S. Constitution. Q Isn't it true that you brought her to this country when she was underage and made her your sex slave, and you've bragged about this? MR. PIKE: Form, argumentative, compound, harassing and calls for speculation. A Lintend to respond to all relevant questions regarding this lawsuit; however, at the present time my attorneys have counseled me that T cannot provide answers to any questions relative to this lawsuit and | must accept this | advice or risk losing my Sixth Amendment right to effective representation. However, I would like, so I'm clear, the question was, did | bring her here? Specifically -Q Your answer is fine. A Okay. | Q Is it true that you demanded numerous underage minor females to have sex with Nadia Marcinkova inside your home while you watched, masturbating? MR. PIKE: Same objections. | A You have to repeat the question. Q Isn't it true that you have ordered several underage minor females to have sex with Nadia Marcinkova in your home while you watched, masturbating? MR, PIKE: Same objections. A The current U.S, Attorney has described 64 your firm, Mr. Edwards, as a criminal enterprise involved in mail fraud, wire fraud, money laundering and, in fact, fabricating multiple order to fleece unsuspecting investors in South Florida out of millions and millions of dollars. Unfortunately, though I would like to answer each one of your questions here today, my 9 attorneys have advised me I must assert my Sixth 1 2 3 4 cases of a sexual nature against me, others, in 5. 6 7 8 10 Amendment, Fourteenth Amendment and Fifth 11 Amendment right under the U.S. Constitution, 12 although I believe you know I would like to 13 answer your questions, but at this moment J must 14 assert those rights or risk having my attorneys 15 resign. 16 Q [sa't it true that with each of these 17s underage minor females that were brought to your 18 house, your method of sexually exploiting them 19 was nearly identical; is that correct? 20 MR. PIKE; Objection, argumentative, 21 confusing, overbroad and vague. 22 A_ I don't even understand the question. 23 Q Okay. When a 14 or 15-year old would be 24 — led into your bedroom, you would appear from the 25 — shewer first, usually naked; is that correct? 1 MR. PIKE: Objection, argumentative, 2 assumes facts not in evidence, and 3 harassing, 4 A intend to respond to all relevant 5 questions regarding this lawsuit; however, today 6 my attorneys have advised me that I cannot 7 provide answers to any questions relevant to this 8 — lawsuit and must accept their advice or risk 9 losing my Sixth Amendment right to effective 10 representation. Accordingly, therefore, | must 11 assert my Constitutional rights -- the Fifth 12 Amendment, Sixth Amendment and Fourteenth 13 Amendments to the U.S, Constitution. 14 MR. PIKE: Can we go off the record for 15 a second? 16 MR. EDWARDS: If it is necessary. 17 MR. PIKE: Yes, let's go off the 18 record, 19 THE VIDEOGRAPHER: Going off the video} 20 record at 12:35 p.m. 21 (Pause in the proceedings.) 22 THE VIDEOGRAPHER: Back on the video 23 record 12:44 pam. 24 MR. EDWARDS: Can you tell me what my 25 last question is? 17 (Pages 62 to 65) U.S. Legal Support (561) 835-0220

THE COURT REPORTER: Certainly. } (The record was read.) Q After appearing from the shower naked, you would order the underage minor female to disrobe; isn't that true? MR. PIKE: Same objections. Form. A Lintend to respond to all relevant questions regarding this lawsuit; however, at the present time my attorneys have counseled me 1 | cannot provide answers to any questions relevant to this lawsuit and must accept their advice or risk losing my Sixth Amendment right to effective representation. Q You would then order them to, or order her to begin providing you a massage; is that correct? MR. PIKE; Form. A [intend to respond to all relevant questions regarding this lawsuit and I would like to answer each and every one of your questions | today, Mr. Edwards; however, my attorneys have told me that I cannot do that today unless and I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution or risk losing my counsel Therefore, I'm going to assert those rights as guaranteed by the Fifth Amendment, Sixth Amendment and Fourteenth Amendment. Q You would then roll over and continue with masturbating; is that correct? MR. PIKE: Form. A [intend to respond to all relevant questions regarding this lawsuit. It is -- it is my understanding that the current U.S. Attorney has described your law firm as a criminal enterprise, yours and Mr. Jaffe's firm, as a criminal enterprise and part of the largest fraud in Florida's history, fabricating malicious cases { of a sexual nature against me and others, in | order to fleece investors out of millions of dollars, through bogus schemes including conspiracy to -- excuse me - to commit mail fraud, wire fraud and money laundering, so though I would like to answer each and every one of your questions here today, my attorneys have counseled me I cannot, and must assert my Fifth, Sixth and Fourteenth Amendment rights under the U.S. Constitution. Q You would then rub the underage minor | female's vagina and/or insert your fingers into | DAKAR WHE 23 24 25 68 her vagina; is that correct? MR. PIKE: Form. A_ | intend to respond to all relevant questions regarding this lawsuit. Unfortunately, today my attorneys have advised me I cannot, must assert my rights under the U,S, Constitution, under the Fifth Amendment and Sixth amendment and Fourteenth amendments of the U.S. Constitution, especially since your firm has been described as a criminal enterprise by the current U.S, Attorney perpetrating one of the largest frauds in South Florida's history, fleecing investors out of millions of dollars by fabricating. malicious cases, malicious cases of a sexual nature against people like me and others, Q With many of these underage minors you would use vibrators on them; is that correct? MR, PIKE: Form, A. I would like to respond to that question ag I would like to respond to all your other questions today. However, my attorneys have counseled me that I must assert my Sixth Amendment rights, my Fifth Amendment rights and my Fourteenth Amendment rights under the U.S, Constitution. Q And with many of these underage minors, you would give and/or receive oral sex from them; is that correct? MR. PIKE: Form, A [intend to respond to all refevant questions regarding this lawsuit, and I would like to answer each and every one of your questions; however, my attorneys have counseled me that today | must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights. under the U.S, Constitution, especially since your firm has been described by the current U.S. Attorney as perpetrating one of the largest frauds in Florida -- in Florida's history, by fabricating malicious cases of a sexual nature against me and others. Q In June of 2008 you pled guilty to a couple of felonies, right? MR. PIKE: Form, vague and confusing. A Again? Q In June of 2008, you pled guilty to two felonies; is that correct? MR. PIKE: Same objection, A Yes, Q And what were those felonies that you 18 (Pages 66 to 69) U.S. Legal Support (561) 835-0220

16 17 18 19 20 21 22 you would say, were they minors? 10 al 12 13 14 15 16 17 18 19 20 21 22 23 24 25 pled guilty to? A. Solicitation of prostitutes, not underage prostitutes but simply prostitutes, Solicitation of prostitutes and one count of procuring a minor for underage sex. Q You have taken the Fifth as to questions related to many of these underage minors, but the; underage minors that were the victims in the cases where you pled guilty, were A.H.; is that one of them? MR, PIKE: Form, mischaracterizes the witness's testimony. Calls for a legal conclusion? A Again. Q > What was the name of the any of the underage minors that were the subject of the criminal charges to which you pled guilty? A [don't know. Q So, tell me about those charges. What were the allegations of those charges? MR. PIKE: Form. A. Solicitation of prostitution, not underage prostitution... Prostitution. Q Were the victims or the prostitutes, as MR. PIKE: Form. A. [pled guilty to solicitation of prostitution. Q Okay, so tell me what those cases were about, What happened? MR. PIKE: Form again, A. I... (Witness shrugs.) I can't tell you any more than that. Q You don't know what you pled guilty to? A. 1 just teld you -MR. PIKE: Object to the form, asked and answered, Q Do you know what you pled guilty ta, the facts? A Solicitation of prostitution. Q Tunderstand that that's the charge. What were the underlying facts? What did you do, did you pull up in a car, talk to the person, did they come over to your house, how did you get them, those kinds of things. Tell the jury what were the underlying faets about the charges you pled guilty te? MR, PIKE: Object to the form. Move to strike. A idon't know. 21 23 24 25 72 Q You don't know what you pled guilty to? A I pled guilty to solicitation of prostitution, not underage prostitution, but prostitution. Q My understanding from reading the court files that one of these females was A.H. Do you know who that is? A Lintend to respond to ali relevant questions in this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any of these questions today. So accordingly, I must assert my constitutional rights under the Fifth, Sixth and Fourteenth Amendments of the U.S. Constitution. Q You're aware A.H. is somebody that alieges she was at your hotse on more than 100 occasions; is that true? MR. PIKE: Form. A Can you repeat the question, sir? Q Are you aware that AH. is a female that alleges that when she was underage, she was at your house on more than 100 occasions? MR. PIKE: Form, predicate. A._T intend to respond fo all relevant questions to this lawsuit, Mr. Edwards, today my attorneys have counseled me that I must respond by invoking my Fifth Amendment right, my Sixth Amendment right and my Fourteenth Amendment right under the U.S, Constitution or risk losing them as my attorneys, so therefore I must assert those rights. Q You understand that her complaint was that Epstein turned H. on to her stomach on the massage bed and inserted his penis in to her vagina, H. Stated Epstein began to pump his penis in her vagina and, she became upset over this. She said her head was being held against the bed forcibly as he continued to pump inside of her while she screamed "no." Are you aware of those allegations? MR. PIKE: Form, predicate. A I'msorry, did you say there is a complaint? Q In the incident report that led toa charging document, that led to a charge that you have pled guilty te. Are you aware of that information coming from A.H.? MR. PIKE: I'm sorry, Mr. Edwards; what are you reading from? However, 19 (Pages 70 to 73) U.S. Legal Support (561) 835-0220

74) MR. EDWARDS: The 87-page Paim Beach Police Department incident report where there are numetous underage females describing their interaction with Mr. Epstein at his house. I'm reading, specifically from page 41 related to A.H., who was one of the victims he pled guilty to. MR. PIKE: Is that the same document that you're seeking production of, in this same exact case? MR, EDWARDS: J don't know what you're talking about. This is something from the State Attomey's file. MR. PIKE: Okay. Sorry. What's the question? Q Are you aware of that allegation? What FT just read to you. A_ I would like to answer that question, but, however, today my attorneys have advised me { must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution, Q Assuming your attorneys have advised you Dut because of Res Judicata, double Jeopardy, you | 75 cannot be charged for any crimes that yon have already pled guilty to relating to A.H., so 1 would like you to explain to the jury, in your words, or your version of the story, what was your interaction with A.H. at your house when she | was a niinor? MR. PIKE: Object to the form as worded, Could disclose attorney/cliont communications. A J intend to respond to all relevant questions regarding this lawsuit. I would like to answer cach of your questions today, however, my attorneys have counseled me that | may aot, They've advised me that I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution, Therefore, if 1 don't, I risk losing their counsel, Therefore, { must assert those rights here today, Mr. Edwards. Q Are you aware that A.H. Advised police that she was ripped and torn in her vagina area and had difficulty walking to the car after this episode where you forcibly inserted your penis into her vagina? MR. PIKE: Objection, relevance, SOI3snATe wre DIRT hwWhe NNNANNNERP RPE RRP Ree AeUNRPACBIAERWNEOLO argumentative, compound, harassing. A This was who? Q The question is, are you aware A.H.? A AH. The current U.S. Attorney, since he has described your firm as a criminal enterprise and part of one of the largest frauds in Florida's history by fabricating, fabricating, malicious cases of a sexual nature against people like me and others, and fleecing investors out of millions of dollars by using means described in the complaint against your firm, including mail fraud, wire fraud, money laundering; I'm afraid today, though I would like to answer each one of your questions, my attorneys have counseled me. that | must not, { must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution, and I believe you know 1] would like to answer those questions. I must assert those rights or risk losing my attorney's representation. Q Do you know S.G.? A. Spell it, please. Q I don't know how to spell her name, but 77 have ever spelled her name for you. MR, PIKE: Form, move to strike. Q Her name is "S.G." A. [intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I may not provide answers today, though 1 would like to, and I must, in fact, take their advice or risk losing their representation, so therefore, I must assert those rights under the U.S, Constitution. Q De you know the names of any of the femaies that you allegedly solicited for prostitution and pied guilty to? MR. PIKE: Relevance. A. Sitting here today, no, I do not, Q You asked me to speil S.G.'s name. That's somebody that your attorneys took her deposition about a year and a half ago. Does that help to refresh your recollection as to who S.G. is? A I would like to answer that question but today, according to my attorneys, I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. 20 {Pages 74 to 77) U.S. Legal Support (561) 835-0220

QAAnewne 738 Constitution. I must accept their advice or risk losing my Sixth Amendment right to effective representation, Mr. Edwards, so though I would | like to answer the question, today I must assert | those rights. Q There is another victim, her name is A.D., that was listed as one of the females at your house and you pled guilty to the solicitation of. I would like to ask you if you remember her? MR. PIKE: Form, confusing, compound. A AD? Q I don't know her first time, initial "A" last name is “D." MR, PIKE: Same objection. A intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant t0 this lawsuit, and I must accept their advice or risk losing my right to effective representation. Therefore, though [ would like to answer the questions, I must assert those rights Q With each case that results in a charge — ‘THE WITNESS: Excuse me, is there some water? THE VIDEOGRAPHER: Off the record? MR. EDWARDS: Stopping again? THE WITNESS: Can I get some water? Mr. Jaffe, can you pass some water? THE VIDEOGRAPHER: There is no water here. THE WITNESS: Sorry. Q With each conviction, charge, or with each charge that leads te a conviction, there are facts and circumstances that lead up to that plea of guilty. MR. PIKE: Form. Q What are the facts and circumstances that led to you pleading guilty to the two felonies that you've described? MR. PIKE: Form, overbroad, compound, confusing, calls for a fegal conclusion. A. I would like to respond to that question. I would like to respond to that question, but today my attorneys have advised me IT must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights to the U.S. Constitution or risk losing effective representation, Accordingly, | must assert my rights as guaranteed by the Constitution. Q Just so you are clear, since your attorney made it an objection that it was unclear, then you invoked your Fifth Amendment Tights ~ A Sorry. Q I'm talking about the cases where you already pled guilty and you can't be charged again. What were the facts and circumstances that fed up to you pleading guilty to these felonies? A I've answered the question. MR. PIKE: Same objection, asked and answered, THE VIDEOGRAPHER: Counsel. (Indicating five minutes left on tape.) MR. EDWARDS: Okay. Q Just so the jury understands, these three females that were the subject of the guilty pleas in State Court, were procured by your method of having underage miner females locate __other underage minor femates and bring them to 81 your house; isn't that correct? MR, PIKE: Objection, argumentative, compound, harassing, assumes facts not in evidence. | move to strike. A You have to repeat the question, Q Okay, A.H., A.D., S.G. are ail people that were, at the time you engaged in sexual activity with them, were underage and were brought by other underage minor females; is that true? MR. PIKE: Same objections incorporated as well as motion to strike. A. I don't understand -« I'm sorry, J don’t understand the question. Q Isn't it true that you used underage minor females to bring other underage minor females to your house for sex? MR. PIKE: Asked and answered. A’ (Witness shrugs.) MR. PIKE: Way earlier on. MR. EDWARDS: He doesn't understand the question -MR. PIKE: You can answer the question. Q Fm going through the progression. MR. PIKE: You can answer, but it is 21 (Pages 78 to 81) U.S. Legal Support (561) 835-0220

asked and answered, A As your firm, Mr. Edwards and Mr. Jaffe's has been described by the U.S. Attorney as perpetrating one of the largest frauds in South Florida's history by crafting malicious cases of a sexual nature against people like me and others, in order to fleece, using bogus schemes, in the U.S. Attorney's words, investment schemes. Unfortunately, though I would like to answer every one of your questions if I'm able, my attorneys have advised me I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights under the U.S. Constitution. Therefore, at the moment I cannot answer that question. Q The acts related to your guilty plea occurred at your Paim Beach house; is that correct? MR. PIKE: Form. A Again, sorry. Q Ifyou were soliciting prostitutes, it wasn't out on the street, it wasn't at a hotel. These were girls that you solicited to be prestitutes at your house in Palm Beach, MR. PIKE: Objection, relevance, argumentative. Calls for speculation as worded and assumes facts not in evidence, A Though I would like to answer that question, my attorneys today have advised me 1 cannot answer you today, and they've advised me IT must assert my Sixth Amendment, Fifth Amendment | and Fourteenth Amendment rights under the U.S. Constitution, Otherwise I risk losing their representation. So, accordingly I must assert those rights, Mr. Edwards, and Mr. Jaffe. Q In what county did you plead guilty to these felony offenses? A Palm Beach County. Q These were crimes that occurred here in Palm Beach County? MR. PIKE: Form. Q Is that correct? A. ... [pled guilty in Palm Beach County. Q Isn't it true that you kept a calendar or schedule ~ THE VIDEOGRAPHER: I have to change the tape. MR. EDWARDS: Change it. THE VIDEOGRAPHER: Off the video record i { i j ; | | i SYA Whe NNN ee Be ee ee OVP GeHBUuDATFRWNESL prostitution. 1:05 p.m. (Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video record 1:15 pam. Q Mr. Epstein, as it relates to the charges you pled guilty to, are you saying today that those fenraies that you interacted with sexually, were prostitutes prior fo meeting you? A I'm saying I pled guilty to the solicitation of prostitution. Q Right, and you would certainly agree that that would require yourself and one other individual for that act of prostitution, correct? MR. PIKE: Form. Also calls fora legal conclusion. A I pled guilty to solicitation of prostitution. Q Are you saying that those females that were the victims, at least listed as victims by the State, were prostitutes prior to mecting you? MR. PIKE: Form. Vague. Irrelevant? A_ [pled guilty to solicitation of 85 Q Do you have any remorse fer your actions -MR, PIKE: Form. Q -- against these victims that led to your plea of guilty? MR. PIKE: Form, argumentative. A I pled guilty to solicitation of prostitution, not underage prostitution, simply, prostitution. Q Are you saying now that the subjects of that, which were called victims, were not underage when you engaged in sex with them? MR. PIKE: Form, argumentative, speculation, assumes facts not in evidence, as well as mischaracterizes the witness's testimony. A I pled guilty to solicitation of prostitution, not underage prostitution, solicitation of prostitution. Q Iwas under the impression you pled guilty to a second degree felony, that being procuring a minor for the purposes of prostitution. A. That's correct. Q Soa minor is somebody under the age of 22 (Pages 82 to $5) U.S. Legal Support (561) 835-0220

86) 1 18, and I'm asking for the guilty plea related to 1 2 that count; are you at all remorseful for your 2 3 interactions with that minor? 3 4 MR. PIKE: Same objections. 4 5 A What minor? 5 6 Q The charge is procuring a minor. You i 6 7 tell me. Whe was that minor? 7 8 A Tdon't know. 8 9 Q You were never told during the State 9 10 ~~ Attorney's prosecation of you, whe this person 10 11 was? 11 12 A No, 12 13 Q Why did you plead guilty to a felony 13 14 charge that resulted in you going to jail, j i 15 without even knowing who the victim was? 15 16 MR. PIKE: Form. That question calls j 16 17 for attorney/ctient information, and 17 18 therefore, I'm going to instruct him not to 18 19 answer that. 19 20 Q If it has anything to do with any 20 21 conversations with your attorney, | don't want to 21 22 know. I'm just going off of the plea colloquy 22 23 between you and the Judge, where you understood) 23 24 — the charges and have been advised and apprised of} 24 250, the charges and you stil yilingty, willy) 222 87 1 pled guilty to the charges. I'm taking now that 1 2 you're saying, you don't even know what those 2 3 charges were about? 3 4 MR. PIKE: What was the question? 1 4 5 don't know the question on the table now. 5 6 Q Who was the minor? 6 7 A I don't know, 7 8 Q You were never told the name or initials 8 9 of that minor victim by the State Attorney's 9 10 Office or the prosecutor? 10 aa A Not that I recall, a1 12 Q Just so the jury understands, this 12 13 method of paying anderage minor females to bring} 13 14 you other underage minor females for sex, is : 14 15 something that you do in New York, and New ; 15 16 Mexico, Florida, everywhere, not just West Palm 16 17 ~~ Beach; isn’t that right? 17 18 MR. PIKE: Again, form, compound, again 18 19 assumes facts not in evidence. 19 20 Argumentative and harassing, and moreover, 20 21 we have already been down this road before ; 21 22 in separate related questions that have 22 23 already been asked and answered, 23. 24 A_ I would like to respond to each one of 24 25 your questions; however, today my attorneys have | 25 88 advised me I cannot and they've advised me F must assert my Sixth Amendment right, my Fifth Amendment right and my Fourteenth Amendment right under the U.S, Constitution, therefore, that's what I'm going to do. Q Where is the calendar or schedule of your underage sex appointments? MR. PIKE: Form, speculation. A_ You said where is... MR. PIKE: "Again." Q Where is the calendar or schedule that Sarah Kellen kept for you for your appointments for sex with underage females? MR, PIKE: Same objection. Q there is not one, you can tell me there is not one. AE would like to answer each one of your questions today. However, ] have been advised by counsel that I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S, Constitution or risk losing their representation. Therefore, I'm going to have to assert those constitutional rights, though I would like to answer that question. Q _Are you still in possession of the 89 computers that were taken from your house prior to the execution of the search warrant? A Again. Am| still...? Q Are you still in possession of the computers that were removed from your house just| prior to the execution of the search warrant? A intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attomeys have counseled me I cannot respond to any questions that may be relevant to this lawsuit, no matter how much I might want to. 1 must accept this advice or risk losing my Sixth Amendment right to representation. Therefore, I must assert my rights under the Fifth, Sixth and Fourteenth Amendments of the U.S, Constitution. Q Who is it that removed those computers from your house prior to the execution of the search warrant? MR. PIKE; Objection, predicate, A. [intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions that may be relevant to this lawsuit, no matter 23 (Pages 86 to 89) U.S. Legal Support (561) 835-0220

30 ' how much I would like to, and I must accept their advice or risk losing their representation. Accordingly, therefore, I would have to assert those rights, Mr. Edwards, Q Itis my understanding, through information and belief, it is my understanding | that this computer system contained the complete list of names of underage minor females with whom you engaged in sexual activity; is that correct? A You're -MR. PIKE: Objection. A - you're asking for my understanding? Q NoA. Are you asking me to tell you what your understanding is? Q Did the computers that were removed from your home just prior to the execution of the search warrant contain the complete list of | underage minor females with whom you engaged in sexual activity? MR. PIKE: Form. A Though I would tike to answer that question, like all your other questions here today, unfortunately my attomeys have counseled me that I'm got 91 Amendment, Fifth Amendment and Fourteenth | Amendment rights under the U.S. Constitution. I point -- excuse me. 1 would point out that your firma wes described by the current U.S, Attorney as a criminal enterprise involved in money laundering, creating and fabricating malicious cases of a sexual nature against people fike me j and others, in order to fleece local investors out of millions of dollars. { believe the senior partner of that firm currently sits ip jail. Unfortunately though I would like to answer all of your | questions, today my attorneys have counseled me I i ust assert my rights under the Sixth Amendment, ] Fourteenth Amendment and Fifth Amendment of the | US. Constitution. Q Isn't it true, you and Sarah Kellen and Ghislaine Maxwell and Nadia Marcinkova operated as an organized criminal enterprise designed to sexually exploit minor? MR. PIKE: Objection, argumentative, i speculation, calls for a legal conclusion and continues to assume facts not in evidence, A. Though } would like to answer that OYaanwne 92 question, Mr, Edwards, like most of your other questions here today... and hopefully will get to do so at some point, my lawyers have advised me I must today assert my constitutional rights under the Sixth Amendment, Fifth Amendment and Fourteenth Amendment of the U.S. Constitution and must accept their advice or risk losing effective representation, Q And as part of that organization you developed code terms such as "Work" or "Massage" as opposed to engage in sex with minors; is that true? MR. PIKE: Form, argumentative, speculation, harassing, assumes facts not in evidence, A Can you... you...? Q You developed code terms such as you ~ A "You" me? Q Yes, you, would ask these girts if they would like to give you a massage or work for you, rather than asking them to do what was going to be done, which is engage in sexual activity with you; isn't that true? MR. PIKE: Same objections, A Are you asking if I developed code 93 words? Is that the question? Q Right. Code words. A. Lwould like to respond to that question, but unfortunately today my attorneys told me I have to respond by taking -- invoking my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights of the U.S. Constitution, or risk losing my amendment right to effective representation. Accordingly I assert my Constitutional rights as guaranteed by those amendments. Q What did it mean within your organization when someone, some underage minor female was coming over to work for you? MR, PIXE: Form. A What did it mean? Q Right, what did it mean? What did it mean to you was going to happen when an underage minor female would either call to work or Sarah Kellen would tell you this person was coming to work for you at a specific time? MR. PIKE: Objection, vague, speculative, assumes facts not in evidence. A. T would like to answer that question, as most of your other questions today. However, 24 (Pages 90 to 93) U.S. Legal Support (561) 835-0220

94; today my attorneys have counseled me that { must invoke my Sixth Amendment, Fourteenth Amendment and Fifth Amendment right, or risk -- and if L don't, I risk fosing them as my attorneys so, therefore, I must assert those rights. Q You're laughing as if my questions are fudicrous right now but you're aware that there were trash pulls from your home where there were message pads, messages taken by various employees of yours, where these terms, "Massage," "Work" were used in conjunction with underage minor females coming over to your house, weren't you? MR. PIKE: Same objections, form, as well. Move to strike, and also assumes facts not in evidence. Lack predicates. Q You're aware of the trash pull and the message pads, correct? MR. PIKE: Same objections, Do you have any documents with you here today that you speak of? MR. EDWARDS: No, but at this point in time in the trial, they will already about in evidence. A I'm aware of a trash pull? What's a ‘trash pull"? I'm son Q Are you aware of -- I'll ask it of you this way: When Sarah Kelien would take a phene message for you, what did she write it down with? MR. PIKE: Form, A. The question makes no sense to me, sorry. Q Ifanother employee of yours were to auswer the telephone, be it your housekeeper, housemanager, would answer the phone, take a message for you and write it down so that you could read it later, what would that message be written on? A. Most likely paper. Q Okay, is that paper typically in the form of a message pad that has 2 carbon copy sheet to the back? A No. Q You're unfamiliar with the documents that I'm talking about, that being a message pad that informs you as to who called, the time they called and the purpose for calling? MR. PHKE: For purposes of the question you're specifically talking about a message pad, nothing related to what you're defining as a trash pull, just what someone takes as a message at Mr. Epstein's home and -A Do know what a message pad is? Q Ne. In your home, do you typically have your housekeeper, housemanager, or somebody else, when they take a message for you, write ona specific pad that informs you as to who is calling, the time they are calling and the purpose for their calling, and there is a carbon copy sheet evidencing that message? MR. PIKE: Objection, asked and answered, Q You know what I'm talking about? A. {know what a message pad is. Q Do you use them commonly in your home or did you back prior to your arrest? AF would like to answer that question, but today my attorneys have advised me I have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution, so therefore, I'm going to do that or I risk losing their representation. Q Is my question to you confusing? Do you know what I'm talking about? =, MR. PIKE: Form, : 97 A. Not specifically, no. Q Okay. The information — A. Is there something you have to show me, so I know what you're talking about? Q I don't have it to show you today, but if the information and evidence that [ have learned through this process is accurate and correct, it would seem a foregone conclusion that you and I would be on the same page, at least about this document, so -A Okay, Q ~if we are going to get toa point you tell me "This document doesn't exist" or “I don't know what you're talking about," okay, that's fine, but that's something we can hash out, Here is my question: When a housekeeper/housemanager would take a message for’ you from any caller, is there a specific message pad that has a carbon copy located near your telephone, for them to write down the name of the caller, the purpose for the call and the time calied? MR. PIKE: Form. Q [Es that something you're familiar with? 25 (Pages 94 to 97} U.S. Legal Support (561) 835-0220

1 2 3 4 5 é 7 8 9 10 11 12 13 14 is 16 17 18 19 20 aL 22 23 24 25 BIRGER WNHE rr} 10 1d 12 13 14 15 16 ‘17. 18 19 20 21 22 23 24 25 A_ I would like to respond to that question. Today my attorneys have counseled me I must assert my Sixth Amendment, Fifth Amendment | and Fourteenth Amendment right under the U.S, } Constitution. Q You're invoking your Fifth Amendment right is not that you understand the question. You understand my question and are electing to invoke your Fifth Amendment rights; is that correct? A Yes. Q When Sarah Kellen or a housekeeper or housemanager, whoever happened to be employed at) the time, would take messages, what form would you normally or typically receive them in? A (Witness shrugs.) MR. PIKE: Same objections. A Tdon't understand the question. Q When a caller would call the home, housemanager or housekeeper or Sarah Kellen, I don't know what you would call her, assistant, would answer the phone, and take a message for =| you so that you would know who called, what would | they typically write down the message on so that you would have it? : i MR. PIKE: Objection. Object to the form, lacks predicate. You have not established anything here today relative to a housekeeper or housemanager or the like. Um... And I'm trying to understand the question, But -MR. EDWARDS: Really? MR. PIKE: ~ it lacks predicate. MR. EDWARDS: This will play well. A Piece of paper. Q Normally they would write it down ona piece of paper and give it to you? A. I didn't say that, Q Have you ever been given a message that is ripped out of a message pad that has a carbon { copy to it? } A Oh, I see. Okay. I intend -- | would like to answer that question, but today my attorneys have advised me J must respond by invoking my Sixth Amendment right, my Fifth Amendment right and my Fourteenth Amendment rights under the U.S, Constitution. Though I would like to answer these questions, accordingly JT must assert those rights or I risk losing my representation here today. 100 Q Between the years 2002 and 2005, who was your house manager? A. (No response.) Q If there is more than one, tell us that, A The question is unclear. I'm sorry. Q Okay, let me start with between 2002 and 2005, did you empioy a housemanager? MR. PIKE: Form. A Where? Q Atyour Palm Beach home. A. intend to respond to all relevant questions here today, Mr. Edwards. Hopefully we will get some, But my attorneys have advised me that today I must invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution; or risk losing them as counsel. So today I have to assert those privileges. Q De you know L.M.? A_ Lintend to respond to all relevant questions regarding this lawsuit. However, at the present time no matter how much I would like to answer that question, ] cannot, because my counsel -- the attorneys have told me that I have 101 to invoke my Sixth Amendment, Fifth Amendment and. Fourteenth Amendmient or, in fact, risk losing their representation, Therefore, I'm going to have to assert my rights under those, Q LM. is a female that was born in July of 1988, A {Is that a question? Q Not yet. When is the first time that you met her? MR. PIKE: Objection, speculation. MR. EDWARDS: That assumes that he did meet her; is that what you're saying? MR. PIKE: Your question assumes ~ MR. EDWARDS: He met her? MR. PIKE: - exactly what he just said which hasn't been established on the record yet pursuant to the appropriate Florida Rules of Civil Procedure and the Evidence Code. Lacks predicate. A That being said, I would like to answer that question, but today my attorneys have counseled me that I cannot, and they've advised me I must assert my Sixth Amendment right, my Fourteenth Amendment right, and my Fifth Amendment right under the U.S, Constitution. 26 (Pages 98 to 101) U.S. Legal Support (561) 835-0220

102 THE WITNESS: Can you throw me one of the suckey candies, please Thank you. MR. EDWARDS: (Handing candy.) THE WITNESS: Appreciate it. Q Isn‘t it true you met L.M. for the first time in Jaly or Angust of 2002 just before her fourteenth birthday? MR. PIKE: Same objections. A. You know, your firm has been accused by the U.S. Attorney of perpetrating one of the targest frauds in South Florida history by crafting sexually charged lawsuits against people fike me and others in order to fleece unsuspecting investors here in South Florida out of millions of dollars, The firm of you and Mr. Jaffe. The U.S. Attorney described it as bogus schemes contrived by your firm. 1 would like to answer every one of your questions here today; however, my attorneys have counseled me that I may not, and have advised me that I have to invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution. Therefore, that's what 1 fe will do, otherwise Trisk losing their representation. Q Isn't it true L.M. asa 13 or 14-year old girl was taken to your house by another underage minor female, that being Carolyn Andriano? MR. PIKE: Form. THE WITNESS: Tissue, please. MR. EDWARDS: (Handing tissue.) A. I would like to answer that question like all the other questions you've asked me here today, but today my attorneys have counseled me that I have to invoke my Sixth Amendment right, my Fifth Amendment right and Fourteenth Amendment rights under the U.S. Constitution; therefore that’s what I will do, Q Do you know who Carolyn Andriano is, right, she had a lawsuit against you previously? MR. PIKE: Form. A. Again the last name? Q Carolyn Andriano. A Could you spell it for me? Q Well, the pseudonym that she used in her lawsuit against you alleging similar facts to those alleged in L.M. verses Jeffrey Epstein was C.M.A. versus Jeffrey Epstein. A And now the question? Q You know who she is, correct? MR. PIKE; Form. A_ [would like to answer that question here, Mr. Edwards, but unfortunately today my attomeys have counseled me I must invoke my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution, and if 1 don't, I risk iosing their representation, therefore I must assert those rights. Q When I asked you about L.M. or Carolyn Andriano, you sat there for a while thinking hard about whether or not you knew them. Do you remember either L.M. or Carolyn Andriano? MR. PIKE: I move to strike counsel's statement because the statement as worded assumes facts certainly not in evidence, It is argumentative, speculates as to what is "thinking hard,” and, counsel, I don't understand the question on the table, combined with your narrative, If you could repeat the question? MR. EDWARDS: Sure. Q Fm asking if during this questioning Gs process, has it refreshed your recollection as to 105 who L.M. is or do you really have no idea who that is? MR. PIKE: Form. Asked and answered. Q Do you remember L.M.? A Are you going to ask one question? Which question would you like answered first? Q Do you remember L.M.? A_ | would like to answer that question. 1 would like to answer that question today; however my attorneys today have advised me that J must assert my Fourteenth Amendment, Fifth Amendment and Sixth Amendment rights under the U.S. Constitution, no matter how much I would like to answer these questions, So unfortunately, I'm going to assert those righis. Q When you first met L.M., isn't i¢ true that she was just about to begin her ninth grade year in high school? MR. PIKE: Same objections. Form. A 1 believe her testimony in front of the FBI, in a swom deposition says something else, but I don't recall exactly what. I don't have any recollection, Q OfL.M. MR, PIKE: Fonn. 27 (Pages 102 to 105) U.S. Legal Support (561) 835-0220

23 24 25 106} A You asked the question when I met her, I think, if | met her. Q You have no recollection as to when you met her? A I don't have recollection if | ever met her. I just told you, I did read her FBY statement, so T know what she has said and it is not what you've just represented to me. Q Your only knowledge of any interaction you may have had with L.M. is derived from an FBI Statement that she gave; is that true? A [believe what you just represented she said was not what she had sworn to. Q I'm not asking what she said, I'm asking do you independently remember if she was entering into her ninth grade year of high school | when you met her? Independent of anything you've | read, MR. PIKE: All right, let me just move to strike the... Diatribe between Mr. Edwards and Mr. Epstein. I'm confused as to what question is on the table now. MR. EDWARDS: Okay. Q Independent of anything you've ever read — 107 | A Okay. 1 Q -- do you remember meeting L.M., just before she entered into her ninth grade year in high school? A_ I wouid like to answer that question, however my attorneys today have advised me that though her own statements are contradictory to ‘what you just said, her sworn statements to the FBI contradict what you just said. I have to invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights to the U.S. Constitution. Q Just a few minutes ago when you asked when you met her, you said, “I don’t know if I've j ever met her," so is that your testimony, that i you don't know if you ever met L.M.? A My testimony is very clear. I must assert the rights my attorneys have asked me to assert today, though her testimony under oath to the FBI is not what you represented {t to be, to me, and the ladies and gentlemen of the jury who are watching this, hopefully. ‘MR. PIKE: Form. | Q We will get into that. i A Okay. | 16 17 18 19 20 21 22 23 24 25 108 Q When you first came into the room today, didn't you look at me and say "I like L.M." Isn't that the statement that you made to me? MR. PIKE: Form. Move to strike. A don't believe I said that, Q What is it that you believe you did say referencing L.M. when you sat down in that seat prior to the cameras rolling? MR. PIKE: Form. Counsel, I was here during that whole time and I don't recall any such statement. MR. EDWARDS: You weren't in the room. A I don't remember. I don't know, Sorry. Q So is it your testimony right now that you did not say to me "I like L.M."? A. That's MR. PIKE: Objection. A ~ that's correct. Q Do you like L.M.? MR. PIKE: Form, predicate, and relevance, A Lwould like to answer al] your questions here as I've... tried to do my best, however, my attorneys have advised me that I must 109 assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights under the U.S, Constitution. Q When you first met L.M., isn't it true that you knew she was an economically disadvaniaged girl that needed money? MR. PIKE: Objection, speculation, assumes facts not in evidence, and it is argumentative as worded. A I would like to answer all your questions here today, Mr. Edwards, and Mr. Jaffe. However, on advice of counsel | have to assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution, or risk losing my right to effective representation. So accordingly I must assert those rights as guaranteed by the Sixth, Fifth and Fourteenth amendments. Q When she was a 14-year old girl, she was taken into your bedroom and you ordered her to take her clothes off; is that correct? _ MR. PIKE: Objection, vague, confusing. As to "her," I'm not quite sure who you... Q When L.M. was a 14-year old girl, she was taken up to your bedroom and you ordered her 28 (Pages 106 to 109) U.S. Legal Support (561) 835-0220

20 2. 22 23 24 25 110: to take her clothes off; isn't that true? MR. PIKE: Objection, speculation, and assumes facts not in evidence. Lacks predicate. A Though once again what you've just represented to me is a totat contradiction to the FBI sworn statement that I read of L.M., | must unfortunately respond by asserting the rights demanded by my attorneys today, which is my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right against -- sorry, given by the U.S. Constitution, though her testimony is exactly ~- does not purport in any way to what you've just said. Q And when L.M. was 14 years old, you ordered she begin to give you a massage while she was naked and you were naked; isn't that true? MR. PIKE: Same objections. A_ Sorry, you have to repeat the question for me. Q When L.M. was a 14-year old girl -A Right. Yes? Q --you laughed and said, "right" about what? A ldidn't hear | the first, part of your 111 question. Now I understood it. Q When L.M. was a 14-year old girl, wasn't it true that you received a massage from her while she was naked and you were naked? MR. PIKE: Objection, speculation, assumes facts not in evidence, lacks predicate. A Lunderstand that your firm has been accused by the U.S. Attorney of South Florida, perpetrating one of the largest frauds in Florida's history, by crafting malicious, sexually charged allegations against people like me. I understand L.M.'s testimony is not what you've just described, though she swore to the FBI... under oath, Though I would like to answer your questions here today, my attorneys have advised me I may not. I must assert my Sixth, Fifth and Fourteenth Amendment rights under the U.S. Constitution or risk losing their representation. THE WITNESS: Restroom break. MR. EDWARDS: Excuse me? THE WITNESS: Restroom break. MR. EDWARDS: Stopping again? THE WITNESS: Yeah. 1 2 3 4 5 6 7 8 ° ii 12 13 14 15 16 17 18 19 20 2. 22 23 24 25 112 THE VIDEOGRAPHER: Going off the video record 1:49 p.m. THE WITNESS: Thank you. {Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video record 2:04 p.m. Q Mr. Epstein, when L.M. was a 14-year old girl, isn't it true that while you were naked on the massage table, you ordered L.M. to take off her clothes and provide you a massage? A. [believe I've answered that question, didn't I? Q don't remember where we left off, that's why. MR. PIKE: Form, argumentative, speculation. It is compound and assumes facts not in evidence and has been asked and answered, But we did take a break, so you can respond, (Counsel addressing Mr. Epstein.) A. The current U.S, Attorney has described your law firm as a criminal enterprise involved in fabricating sexually charged cases against people like me in order to fleece unsuspecting investors out of millions of dollars. He used 113 words like "bogus schemes,” Unfortunately at this time in response to your questions, though I would like to answer each and every one, I'm going to have to, on advice of counsel, assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution, though f would like: to answer those questions. Q While L.M. was a naked 14-year old girl providing you a massage, you ordered her to pinch your nipples during that massage; isn't that true? MR. PIKE: Same objections, argumentative, speculation, harassing, assumes facts not in evidence and lacks predicate. A. Lasked her to pinch her nipples? Q Pinch your nippies? A. Lbelieve her own swom testimony contradicts that statement. However, I would like to answer all your questions here today, but my attorneys advised me, at least today, Mr. Edwards, I must take my constitutional privileges of the Sixth Amendment, Fifth Amendment and Fourteenth Amendment, keeping in mind that your 29 (Pages 110 to 113) U.S. Legal Support (561) 835-0220

1 2 3 4 3 & 7 8 9 10 a1 12 13 14 15 16 17 18 19 20 21 22 23 24 10 11 12 43 14 15 16 17 18 19 20 21 22 23 24 25 114 firm, of you, Mr. Edwards, and Mr. Jaffe's firm. has been accused by the U.S. Attorney of perpetrating one of the largest frauds in Florida's history by crafting sexually charged. lawsuits against people like me, to fleece from focal people millions of dollars. Q And during this massage by L.M., you began to masturbate in front of her; isn't that true? MR. PIKE: Same objections? A Unfortunately, though I would fike to answer each one of your questions here today, my attorneys have counseled me today at least, 1 have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S, Constitution, otherwise { risk losing their effective representation, and the fact that your firm has been accused of fabricating these malicious lawsuits to fleece investors out of millions of dollars, as described by the U.S, Attorney here in South Florida as a criminal enterprise involved in mai] fraud, money laundering... Unfortunately | would like to answer each question, but I can't today. true that while you were 115 masturbating you inserted your fingers into her 14-year old vagina? MR. PIKE: Objection, argumentative, Speculation. It is harassing. It assumes facts not in evidence. The question continues to lack predicate, and I also believe the question has been asked and answered sometime ago. A Though I would like to answer each one of your questions today, Mr. Edwards, my counsel has told me I cannot answer any questions that may be relevant to this lawsuit. The fact that your firm has been accused of major fraud, the jargest fraud in South Florida history, by the U.S. Attorney calling your firm a criminal enterprise involved in money laundering -- I believe it is racketeering, but I could be wrong... Monetary transactions via fraud, mail fraud, conspiracy -- sorry «- I would like to answer your questions but today on advice of counsel, 1 am going to have to assert my rights. Q Isn't it true also that while L.M. was a 14-year oid female, you masturbated to the point of ejaculating while inserting your fingers into L.M.'s vagina? 4 | OAIRAewWne 116 MR. PIKE: Same objections incorporated? A Again, the question? Q Isn't it true that during this sexual massage, while you were — that you masterbated to the point of ejaculating while you were inserting your fingers into L.M.’s vagina? MR. PIKE: Objection, argumentative, speculation. It is compound. It is vague. Tt assumes facts not in evidence and tacks predicate. A Though I would like to answer that question with specificity and detail today, no matter how much I would like to, my attorneys have advised me I cannot. They advised me I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution or potentially lose effective representation, so therefore, } will assert those rights. Q Isn't it true that the ritual that I'm describing occurred with L.M., approximately 100 times when she was between the ages of 13 and 16? MR. PIKE: Same objections, with the additional objection of vague and confusing. 117 A Since your firm has been involved ~ according to the U.S. Attorney in crafting these fraudulent lawsuits in order to fleece local investors, and. the fact that I believe in L.M.’s sworn statements, that's what you've just alleged at feast is totally contradicted by your client's own sworn statements, though I would like to answer these questions today, my attorneys have advised me ] may not and advised me I must assert my Fifth, Sixth and Fourteenth Amendment rights under the U.S. Constitution or potentially risk losing effective representation. Q In addition to the sexual abuse directed against L.M. that I've just described, isn't it true that you also paid her money to bring you more than 50 other underage minor females for you to similarly abuse? MR. PIKE: Same objections. A_ Though J believe in her own swom testimony to the U.S, government that she contradicts those assertions, and I'm sure maybe you'll have some explanation at trial, but the ladies and gentlemen of the jury should know about your firm being accused by the U.S. Attorney of perpetrating one of the largest 30 (Pages 114 to 117) U.S. Legal Support (561) 835-0220

118 j | frauds in U.S. history by crafting malicious | lawsuits of a sexual nature in order to fleece | investors out of millions of dollars, local investors; and though I would like to answer your | questions in detail today, Mr. Edwards, and Mr. | Jaffe, my counsel says | may not and have asked me to assert those rights, which I must unfortunately, Q You keep bringing up this fraud of the former law firm known as Rothstein, Rosenfeld, Adler in response to my questions, so I would like you to tell the jury at this time which allegation are you now saying is fraudulent or untrue, that's been made by L.M.? MR. PIKE: Form, confusing, compound, | and irrelevant, MR. EDWARDS: Only made irrelevant by his answers. MR. PIKE: Same objections. Q Do you understand the question? A No. } Q You made reference to -- in response to my questions about what you did sexually to LM. ~~ A_ Yes, sir? Q --you have responded with these fraud allegations against the firm of Rothstein, Rosenfeld, Adler, I want you fo tell the jury which allegations that L.M. is making against you are you disputing at this time or calling a fraud or calfing untrue? MR. PIKE: Confusing, compound and -- if the court reporter would read back Mr. Epstein's response, I think you will see the way you just phrased the question. mischaracterizes his testimony. Because -well, !'H keep it there unless you want me to go further. You want me to go further? MR. EDWARDS: No, I want him to go further. MR. PIKE: Mischaracterizes the witness's testimony. { A_1.M.'s own statements contradict every one of your allegations that you've made to me today, as a hypothetical. In her own words. And you -- and the potential reasons this concerns me is the fact that the law firm that represented L.M. and two others have been accused by the U.S. Attorney of fraudulently producing cases against me and others, to fleece investors in what he's i 21 24 25 120 described as one of the largest frauds in South Florida's history. So, it concerns me. {tis a factor in the way !'m thinking about answering. Sorry. Q Each time that you digitally penetrated L.M. or otherwise fondled her sexually, you paid her $260; is that correct? MR. PIKE: Objection, argumentative, speculative, harassing. It assumes facts not in evidence, and with regard to this line of questioning, the Court has. already ruled that the demeanor in which you're presenting this question is improper, and harassing, so if you would ~~ MR. EDWARDS: I'm very comfortable with the demeanor right now, Mr. Pike. These are just the facts of the lawsuit. The facts are outrageous and | understand that, but they have to be asked, MR. PIKE: Maybe the demeanor and tone of your question is laced in a manner that itis proper for the video, but the content of the question is the same exact harassing question that was deemed by the Judge to be argumentative. Tm not saying that he's not 121 going to answer your question. MR. EDWARDS: Okay. MR. PIKE: Or that you don't know what his answer will be, but what I'm saying is: could you rephrase the question? Q Answer that question. I'll work on rephrasing it for you at some point. A Sorry, J forgot what the question is by now. Q Isn't it true that each time that you interacted with L.M. sexually, meaning digitally penetrated her or fondled her in some other way, that you paid her $200 each time? MR, PIKE: Form. THE WITNESS: Sorry? MR. PIKE: Form. Go ahead. A. I would like to answer cach one of your questions here today. However, my attorneys have counseled me that today { have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution and I'm cognizant of the fact that your firm has crafted these malicious Jawsuits, it has been reported that the lawsuits are of a sexual nature, in order to fleece investors, so though F 31 (Pages 118 to 121) U.S. Legal Support (561) 835-0220

122 would like to answer those questions, Mr. Edwards, and Mr. Jaffe, today I must keep my counsel's advice. Q Isn't it true that for each underage minor that L.M. brought to you for the purposes of you engaging in sexual activity, you paid her $2602 MR. PIKE: Objection, speculation. Compound question, and it assumes facts not in evidence, Therefore lacks predicate. A. Though I would like to answer that question, as most of your other questions here today, Mr. Edwards, I intend to respond, hopefilly at some point to all of your questions, but today my attorneys have advised me f must invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right under the U.S. Constitution, Q Over the course of relatively a roughly three years, isn't it true that you touched or fondled L.M. in a sexual manner on more than 50 occasions? MR. PIKE: Objection, argumentative. Calls for speculation. It is overbroad, confusing : and vague, and itassumes facts 12. not in evidence. A Could you repeat the question for me? Tim sorry, Mr. Edwards. Q Yes. The three-year period between 2002 and 2005 when you were engaging in sexual conduct with L.M., isn't it true that that conduct took place on more than 50 occasions? MR. PIKE: Same objections. A. J believe if you read your own client's FBI statements, what her statement -- it changed dramatically after she decided to file a different lawsuit, at the request of you and your firm, with one of your firms ~ there have been many firms it seems, was accused of major fraud. ‘Since the testimony has changed dramatically, T would like to answer those questions, but today my attorneys have advised me I must assert my Sixth Amendment right, my Fifth Amendment right and my Fourteenth Amendinent right. Q ** Your answers are not going to incriminate you if the answer is "no," it is only if the answer is "yes" that it will incriminate ‘you, so aren't you telling the jury every single thing I've asked you is not part of a fraud, just happens to be true, isn't it? { i i { | 21 24 124 MR. PIKE: Objection, argumentative, irrelevant and move to strike. I'm simply going to instruct the witness not to answer that question because... I don't understand it. I don't know what to say about that question. A (Gesturing.) Q Af of the things that I’ve told you or that I've asked you about, you touching her while she was underage, you paying her for sexual conduct, those are all things that really happened, there is nothing about that, that anybody has fabricated or made up, is there? MR. PIKE: Objection, argumentative, speculative, it assumes facts not in evidence, it certainly mischaracterizes the witness's testimony all day, since I have been here, and I have been here the whole time. It assumes facts not in evidence. It is also overbroad and substantially compound because you're attempting to incorporate all of your questions today into one question. MR. EDWARDS: | think you know, Mr. Pike, your objection should be limited to _the form. [f you object to the form, it is . 125 fine. MR. PIKE: I'm sorry, that's -MR. EDWARDS: You —MR. PIKE: You've asked me several times today fo teil you why. I thought | was helping. I'm sorry. I certainly will keep objecting to -MR. EDWARDS: Appreciate it. MR. PIKE; -- the form, MR. EDWARDS: Thank you. Q And your answer is? A Repeat the question, Q Every single allegation that L.M. has made and I have now questioned you about in terms of your sexual involvement with L.M., they are all true; isn't that correct? There is nothing fabricated about any of these allegations, correct? MR. PIKE; Objection, argumentative, speculative, compound, It is vague, overbroad ~ MR. EDWARDS: You're objecting to form? MR. PIKE: Yes, assumes facts not in evidence and facks predicate. That is form. 32 (Pages 122 to 125) U.S. Legal Support (561) 835-0220

A And I would like to answer that question specifically today, however, on advice of counsel they've suggested | take the Sixth amendment -assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution, keeping well aware of your firm's responsibifity in the largest fraud in Florida’s history by crafting sexually charged lawsuits against people like me and others. 1 believe in addition, since her allegations, as you've phrased them, have changed dramatically since her sworn statement, until in fact, after she joined this firm charged with this major fraud and most of her statements have changed, | believe, so... Q You remember when L.M. becante pregnant when she was 16 years old, don't you? MR. PIKE: Form, relevance, move to strike? A J would like to answer each one of your questions here today, Mr. Edwards; each and every one of your questions. However, today my counsel has told me I must assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment rights under the U.S. Constitution. 127 Q Isn't it true that when E.M. was 14 years old,.t5 years old and 46 years old, you touched her genitals? A Separate from the fact that in her own testimony, her own sworn testimony under oath before she decided to file a lawsuit for money, there was never any discussion about anything Jike that. 1 would like to answer that question, but my attorneys have advised me, at feast today, that | must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution. Q Isn't it true when she became pregnant at age 16, you no fonger interacted with her sexually but still demanded that she bring you other underage minor females for you to sexually exploit? MR. PIKE: Objection, speculation. Compound, Harassing, and assumes facts not in evidence. A_ I betieve her testimony changed dramatically from her sworn statements to the FBIQ That's not a responsive -~ MR. PIKE: Excuse me -~ SIAM ewWwne 128 MR. EDWARDS: It is not a responsive answer so I won't allow -MR. PIKE: That -MR. EDWARDS: We'll move to strike it, Let's have an answer to the question. MR. PIKE: The witness is trying. If there is a legal basis for your moving to strike, it would be taken up with the Court and you can move to strike. You can continue. MR. EDWARDS: Strike it, it is nonresponsive? A Your allegations that you keep throwing at me, relate to the fact that L.M. testimony, after giving a sworn statement to the FBI, changed dramatically after she decided to file a lawsuit for money, joining your firm that's been accused by the U.S. Attorney of one of the largest frauds in Florida's history. 1 would like to answer those questions; however, on advice of counsel today I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S, Constitution. Q When L.M. was a pregnant 16 year-old, she brought you at feast ten underage minor__ 129 females during her pregnancy; isn’t that true? MR. PIKE: Objection, argumentative, speculation. It is vague and assumes facts not in evidence and lacks predicate, A l--T-~ Lunfortunately would like to answer that question as well as every other question you've asked me here today, but my attorneys have advised my I must assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution. Q After L.M. had her son at 16 years old, and you were being criminally investigated for some of the conduct that we've discussed here today; isn't it true that you personally hired and retained and paid for an attorney to represent L,M.? MR, PIKE; Objection, speculation -MR. EDWARDS: Object to the form, Mr. Pike, MR. PIKE: I will not. [am allowed to assert the basis for my objections, I am not limited to just saying "form." I'm able to assert the basis as to why, so I don't waive that basis, MR. EDWARDS: It is just more of this 33 (Pages 126 to 129) U.S. Legal Support (561) 835-0220

130 obstructionist -= MR. PIKE: It's not obstructionist, it is objecting to form. What is | obstructionist is what we are doing now. I will be finished within four seconds, SoI am going to object to form, it's argumentative, speculative and it assumes facts not in evidence and it lacks predicate. That’s it. A I'm sorry. (Witness shrugs.) Again? Q The response to the question. A I don't know the question. Q You don't remember the question? Did you hire L.M. an attorney at some point in time? | Do you remember that? MR. PIKE; Same objection. A_ Not to the best of my recollection. Q Do you know James Eisenberg? A ... DoT know James Eisenberg? I don't believe I've ever met James Eisenberg. Q Isit your testimony today then that you never paid for an attorney to represent L.M.? A (Witness shakes head.)... On advice of my counsel, I would Jike to answer that question, but on advice of. counsel Im going to have to assert my Sixth Amendment, Fourteenth Amendment | and Fifth Amendment rights against -- excuse me, | Sixth Amendment rights of the U.S. Constitution. Q And that attorney that was paid for by you, informed L.M. that if she were to fell the FBI exactly what happened at your house, that her son could be taken from her. You're aware of that, correct? ! MR. PIKE: Same objections. A. J recognize, | believe she made one of the statements at her deposition after she decided to sue me for a bunch of money and your | firm has represented a number of... cases of a sexually charged nature that turned out to be fraudulent in order to fleece local investors. The U.S. Attorney described your firm and these cases as a bogus scheme, and I'm aware of that, and would like to answer your question in more detail today, Mr. Edwards; however my attorneys advised me that at least today, I must assert my rights under the Sixth Amendment, Fourteenth Amendment and Fifth Amendment. MR. PIKE: It is the food. MR. JAFFE: I didn’t want him in the room in mid answer. | a 2 3 4 5 6 7 8 9 10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 132 THE WITNESS: Ready? Thank you. THE VIDEOGRAPHER: Going off the video record 2:29 p.m, (Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video record 2:50 pn. Q Isn't it true, Mr. Epstein, that you gave L.M. money to coerce her into interacting with you sexually? A Mr. Edwards, I would like to answer cach and every one of your questions here today, but unfortunately, Jike I've done with mostly ail of your other questions, I'm going to have to assert my rights, Sixth Amendment, Fourteenth Amendment and Fifth Amendment on advice of counsel, Although I would like to answer, if] don't follow my counsel's advice, I risk losing representation. Q While committing these sexual acts against L.M. when she was just a minor, you knew it would psychologically damage her; isn't that true? MR. PIKE: Form, lacks predicate, speculation, A_lintend to respond at some point to — 133 I would like to respond to each and every one of your questions, but today on advice of my counsel they've required me to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights| under the U.S, Constitution, though { would like to answer cach of these questions. Q In fact, you deliberately and intentionally caused severe emotionally distress to underage minor females, including L.M.; isn't that true? MR. PIKE: Objection, argumentative, speculation, it is compound. And it assumes facts not in evidence. MR. EDWARDS: Okay, A I would like to answer that question, as I would like to answer ali of your other questions today regarding L.M, However, my attorneys today have advised me that J must assert my Sixth Amendment right to effective representation and my Fifth Amendment sight and my Fourteenth Amendment right. Though I would like to answer that with specificity, ] must follow my attorney's advice. Q Will you admit for the jury that you were investigated federally for your illegal 34 (Pages 130 to 133) U.S. Legal Support (561) 835-0220

134 activities with underage minors? MR. PIKE: Same objections. A I would like to answer that question, as | weil as all the other questions you've asked me here today, especially since your firm has been accused by the federal, 1 guess, the federal government,... being considered a criminal -- you firm has been considered and investigated as being a criminal enterprise using sexually fabricated, sexual cases... fabricated cases, to fleece investors out of millions of dollars, but { would like to answer your questions; however my attorneys have demanded that I assert my rights under the Sixth Amendment, Fifth Amendment and | Fourteenth Amendment, Q In fact, as a result of that investigation, you, as well as the United States Attorney's Office entered into what has now been known and referred to as the nonprosecution agreement; isn't that correct? MR. PIKE: Same objection. The document | speaks for itself? A. You have to repeat the question. Q Asa result of the criminal vestigation into your activities with minor | 135 females, you reached a resolution with the United States Attorney's Office, in what has now been Gescribed as the nonprosecution agreement; is j that correct? MR. PIKE: I'm going to object. Vague, confusing, misrepresents the agreement and the document is the best evidence, Will you mark it? MR. EDWARDS: [ can mark it, We will copy it at the end and mark it as Exhibit 2. (Document, Nonprosecution Agreement, was deemed marked as Exhibit number 2 for identification, as of this date.) A Yes. Q in that agreement, there are listed co-conspirators of Jeffrey Epstein, those being Sarah Kellen, Adriana Ross, Leslie Graff (phonetic) and Nadia Marcinkova. Can you explain | to the jury what those individuals did for you related to the crimes that were investigated by the federal government? A Co-conspirators? Q Yes, it says “criminal charges against any co-conspirators of Epstein inelnding but not | limited to Sarah Kellen, Adriana Ross, Leslie | 17 18 19 20 aL 22 23 24 25 CIA A ewe 9 10 1. 12 13 14 is 17 18 19 20 aL 22 23% 24 25 136 Graff or Nadia Marcinkova." Can you explain to the jury what each of those four individuals did for you or conspired with you to do? MR. PIKE: Object to the form of the question? A_ I would like to answer that question, however, today my attorneys advise me that [ must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights under the U.S. Constitution. Q Isn't it fair to say that you, as well as the co-conspirators, operated as an organized criminal enterprise designed to sexually exploit underage minors? MR. PIKE: Object to argumentative, speculation. It is vague and it assumes facts not in evidence. A Are you suggesting it was a criminal enterprise? Is that the words? Q Yes. A_ Though I would like to answer that question today, I think the only criminal enterprise that I have been reading about today was your firm, that's been accused of being a <ciminal caterpeize involved ial defrauding. 137 people, using mail fraud, wire fraud, money laundering, the operation of the enterprise ~ this is by the U.S, Attomney (indicating), but though I would tike to answer your questions with specificity today, on advice of counsel, though I would like to answer it, they demanded I assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment right or I risk losing their representation, Q Did you care about any of the underage minor femaies at the time when you were engaging] in sexual conduct with them? MR. PIKE: Objection, argumentative. Harassing, already been ruled upon by the Court relative to this exact question, MR. EDWARDS: I feel comfortable with the question, [t goes to punitive damages. The issue related to the Court was a repetitive question on that topic or around that general subject matter. I'm just asking for Mr. Epsiein to tell the jury how he felt about these girls, whether he cared about them, when he was engaging in illegal sexual conduct with them, MR. PIKE: Counsel, i'm going to 35 (Pages 134 to 137) U.S. Legal Support (561) 835-0220

i instruct him not to answer the question. ! You can certify it to the Court, if you like. You know what the answer is going to be; however you're attempting to lace this video. You know the Court has already ordered that these types of questions are not permitted because they are argumentative and harassing. In fact, other questions bordered but this question is on exact point with the Court's order. If you want to withdraw the question, that’s fine. MR. EDWARDS: I don't want to withdraw the question. MR. PIKE: Then I instruct him not to answer. MR. EDWARDS: Mark that somehow, that | page, so we can find it in the record, relative to the hearing that will be had on that question and others similar. Q At the time when you were engaging in sexual conduet with underage females, you knew that exposing them to this, was not beneficial or good for these girls; isn't that true? MR, PIKE: Objection, argumentative, speciation, ssciimed facts nok iy evident. 139 Lacks predicate. A. Though I would Hike to answer that question, like most of your other questions here today, on advice of counsel 1 must assert my i Fourteenth Amendment, Fifth Amendmerit and Sixth | Amendment rights. Though I would like to answer, if I do so, I risk losing my effective representation of counsel. Q Isn't it true, Mr. Epstein, that the only thing that you cared about was accessing as many underage females as possible, for the purposes of sex? MR. PIKE: Argumentative, speculation, | harassing. i A’ What's the question? i MR. PIKE: And assumes facts not in evidence. Q Isn't it true that the only thing that you cared about when you were interacting with i these underage females in a sexual manner, was ejaculating or your own personal gratification? MR, PIKE: Form, same exact objections. A Though I would like to answer that question, and to the ladies and gentlemen of the jury, I would very much Jike to answer that 19 20 21 22 23 24 25 _-~.2_ Did you care about any of these underage 140 question; however, today my attorneys have advised me I must take -- assert my rights under the Fourteenth, Sixth and Fifth Amendments of the U.S. Constitution, or else J risk losing their representation. MR. PIKE: And Mr. Edwards, just so we don't have to come back on the question that J instructed him not to answer, if you would go ahead and repeat that question, I will be more than happy to let him respond. MR. EDWARDS: I don't remember the question we will take it up with the Court and we'll get a ruling on it. MR. PIKE; It was whether or not he cared about these -- I believe you quoted it as underage minors, but I would like the court reporter to read back the question just to conserve judicial resources and not go back. So if she can reread the question that would be good. MR, EDWARDS: Ifyou can find the question, THE COURT REPORTER: Certainly. MR. EDWARDS: I think i know it. 141 minor females that you were engaging in sex with, at the time when you were engaging in these sexual activities? MR. PIKE: Same objections, as before. A. Though I would like to answer that question as well as most of your other questions, if not all of your other questions here today, on advice of counsel | will have to assert my Fourteenth Amendment sight, my Sixth Amendment right and my Fifth Amendment right, because no matter how much J actually want to answer that question, if 1 do so | risk losing my counsel's representation. Q At the time you were engaging in sexual activity with these underage minors, including L.M., you knew that this conduct was illegal, didn't you? MR. PIKE: Same objections, Form. A [would like to answer that question, as. well as most of your other questions here today; however, today my counsel has instructed me to assert my Fourteenth Amendment, Sixth Amendment and Fifth Amendment right, and if I de not, and if, in fact, IT answer that question — if I can answer that question, | potentiaily risk losing 36 (Pages 138 to 141) U.S. Legal Support (561) 835-0220

142 my effective counsel's representation, Q In fact, you told many of these underage minor females not to tell anybody what happened with you in the honse, or else they would be in trouble; isn't that true? MR. PIKE: Form. A_T would fike to answer that question, as ; well as the other questions; however, my counsel has advised me that today I must assert my Fourteenth Amendment, Sixth Amendment and Fifth Amendment rights under the U.S. Constitution. Q The underage minor females that have come forward with information about your sexual interactions with them have been investigated, harassed, humiliated in an effort for you to intimidate them to go away. Is that true? MR. PIKE: Objection. Argumentative, speculative, compound. It is overbroad, and assumes facts not in evidence. A Can you repeat the question? Q Sure. Any underage minor female that you engaged in sexual activity with, that has now | pursued a lawsuit against you, isn't it true that | you've spent a lot of money and a lot of resources investigating them in an effort to 143 intimidate them and hopefully make them go away? | MR. PIKE: Same objections. j A I believe your client's testimony changed dramatically when she joined up with you and your law firm, accused of fraud, when she decided to change her testimony, at least from what the statements said, both to the police and to the FBI, and decided to seek money. However, anything above that or beyond that, I'm going to have to, in fact, assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights as directed by my competent counsel. } Unfortunately, they have told me if E don't, 1 tisk losing their representation, Q Allright, IM give you a chance here since you keep bringing up her statement to the i FBI as opposed to her sworn testimony for 13 hours under oath in this case. Are you saying that the sworn testimony to the FBI was, in fact, the truth? A. What I'm saying is, it seems her testimony has changed dramatically after she joined your firm, that's all. Q Okay. Irrespective of her testimony, you've read her testimony and you read her iL 13 14 15 16 17 18 19 20 a1 22 23 24 25 WRI HVBUWNnE 10 at 12 13 14 15 16 17 18 19 20 21 22 23 24 25 testimony ~ to the FBL. You watched her deposition when it was being taken. Which -A. You'te meking assumptions; Pm sorry. MR. PIKE: Let him finish the question. THE WITNESS: Sorry. A My fant, MR. PIKE: Then Fil object and you'll respond, Q Which are you saying is the truthful testimony, her statement to the FBI or the videotaped deposition that you watched? MR. PIKE: Object to the form. A What I've said, and I think I'll repeat myself is until she joined your firm and started to seek money, her testimony was different. That's my understanding, Q Are you denying any sexual involvement with L.M. at this time? MR. PIKE: Form. AT would like to answer that question. | would like to answer it as with most of your questions here today, however, my attorneys have advised me that } must take that -- assert my rights under the Sixth Amendment, Fourteenth Amendment and Fifth Amendment, no matter how much 145 T would like to answer that question, or potentially risk losing my counsel. Q Isn't your game plan with al of these civil lawsuits that have been filed against you, to spend as much money as you can te investigate, and harass these young women into hopefaily dropping the lawsuits against you? MR. PIKE: Objection, Relevance. Move to strike. It is argumentative and harassing. A_ I would like to answer that question. 1 think you know the answer to that question. Q Yes. A. (Witness nods.) However, today my attorneys have advised me | must assert my Sixth Amendment rights, my Fourteenth Amendment rights and my Fifth Amendment rights, Q You don't have any remorse for the sexua} abuse that you committed against L.M., do you? MR. PIKE: Objection. It is argumentative, It is harassing. It is, I believe, confined under the Judge's order and it assumes facts not in evidence? A. That being said, I would like to answer 37 (Pages 142 to 145) U.S. Legal Support (561) 835-0220

eywdsAy TFT ewe that question today, but my attorneys have advised me that I must assert my Fourteenth Amendment rights, my Fifth Amendment rights and my Sixth Amendment rights. Q In fact, yon recently sued L.M., didn't you? z A Yes, and you and your firm that's been accused of the largest fraud in Florida's history, described by the U.S. Attorney as a criminal enterprise involved in money laundering, conspiracy to commit one crime -- excuse me, mail fraud, commit conspiracy to commit wire fraud, Yes, I sued you, your firm and L.M. Q ** Tell the jury — A Yes, i Q ~ the basis for the evidence that you i have to support the allegations in the complaint against L.M. MR. PIKE: I'm going to instruct the witness not to answer that question in this medium, as it is wholly irrelevant currently, as were it, to this particular lawsuit, MR. EDWARDS: Just so you can rethink that position, the lack of remorse goes to 147 punitive damages, that is an aspect of the case that L.M. has against Mr. Epstein. MR, PIKE: This lawsuit, the current one Mr. Epstein is noticed for, and the lawsuit in which Mr. Epstein has filed against the former Rothstein, Rosenfeld, Adier, L.M. and Mr. Brad Edwards, is not proper for this medium ~ MR. EDWARDS: J understand your position. MR. PIKE: ~ in that regard, I'm going | to instruct him not to answer any questions | relative to that lawsuit because of that i objection, as well as, it is my | understanding that Mr. Scarola has set Mr. | Epstein's deposition, I believe, either early next week or mid-March, on the case of Epstein versus RRA, Rothstein, Rosenfeld and Adler, Mr. Edwards, as well as L.M. ‘Therefore when that time approaches, that would be the appropriate time for those type of questions, related to that lawsuit. MR. EDWARDS: | understand your position; completely, Mr. Pike. MR. PIKE: Thank you. Orv naurwnare © 121 12 13 14 15 16 17 18 19 20 21 22 148 Q ** But as it relates to, obviously L.M. sued you making the allegations that you sexually molested her from when she was 13 years old to when she was 16 years old and now you've sued her in something that is seemingly retated to that case, and ¥ just want to understand what your factual basis is, or what evidence you're using to support your lawsuit against L.M., so that the jury can he valuate whether that is evidence of lack of remorse that would go to punitive damages claims that L.M. has against you. MR, PIKE: I would instruct him not to answer that question, for the same reasons stated. MR. EDWARDS: Let's mark that. Q Is it your feeling that because you are wealthy and these children are poor, that you are entitied to sexually abuse them? MR. PIKE: Argumentative. Q In speaking abont these children, and including L.M. MR. PIKE: Argumentative, speculation, compound, it’s vague, and it assumes facts not in evidence. A Inkeeping with your firm's propensity 149 for filing fellacious (sic), manufactured, sexually charged cases, based on nothing but thin air, accused by the U.S, Attorney of the largest fraud in South Florida's history, by manufacturing sexual cases, I would like to answer each and every one of your questions, including why I sued you, but today I'm not going to be able to. | have to simply listen to my counsel and assert my Sixth Amendment, Fourteenth Amendment and Fifth Amendment right. Q This answer that you keep reciting, about the Rothstein, Rosenfeld, Adler firm -A You do know who they are, right? Q - you are aware, obviously, that all of the lawsuits that were filed against you, including L.M.'s, were filed at least a year before, or approximately a year before Rothstein, Rosenfeld, Adler had any of these cases; you're aware of that, right? MR. PIKE: Form. A Ido not know when Rothstein Adler got involved in these cases, I do know that the moment that they did surface, and, in fact, I understand you shared information with all the other attorneys that you so -- that the jury 38 (Pages 146 to 149} U.S. Legal Support (561) 835-0220

150) should understand that the information gathered -- according to the U.S. Attomey, by illegal means, has been shared with all the other attorneys that you keep representing have filed cases against me; yes, I'm aware of that. Q don't understand that answer. Steven, do you -MR. PIKE: Do you have a question? MR. EDWARDS: I want to understand what his answer was. As in all depositions, if you don't understand the answer, clarify the answer. MR. PIKE: No, you have to ask a question. i MR, EDWARDS: I did. And he's responding to it. MR. PIKE: The witness has answered the question. Do you have another question to clarify his answer? MR. EDWARDS: Yes. Q Please clarify your answer. MR. PIKE: | will instruct him not to { answer. It's vague and confusing, it's narrative. _MR. EDWARDS: Me sayin answer" is narrative? MR. PIKE: What do you mean by "clarify your answer? MR. EDWARDS: | didn't hear what he | said. Say it again so I can hear it, MR. PIKE: Would you please read back what Mr. Epstein just testified to, madam court reporter. (The record was read.) MR. EDWARDS: Okay. } MR. PIKE: It was an answer, a | question -- | MR. EDWARDS: I understand -~- 1 mean I don’t understand the answer, but now I know the answer. MR. PIKE: Okay. | Q At this point in time, please tell the | jury what is your defense of the claims being asserted against you in this lawsuit by L.M.? MR. PIKE: I'm going to object. Calls for a legal conclusion. A What are the claims? So since you're representing L.M., can you tell me what the claims are? Q Yes, we've gone through it. She went to SAR ewWHE 152 your house when she was 13, 14, 15, 16 years ald -A Is that aclaim? Q —she was in your bedroom. You instructed her to get naked. You inserted your fingers into her vagina. You used a vibrator on her. You coerced her into recruiting other underage minor females, roughly 58 or so more. These are all claims that have amounted to various counts, coercion, prostitution, intentional infliction of emotional distress, battery, committing various crimes against her. What are your defenses to that? Nermal defenses are "I didn't do it," "E did it, but it didn't hart her,” we are trying to understand so we know hew 0 provide this case to the jury, what are your defenses to these allegations? MR. PIKE: I'm going to object to this line of questioning. It is compound; as worded it could call for disclosure of attorney/client information as well as work product. I believe in this particular case there is a document filed, answer in affirmative defenses, and the affirmative defenses are set forth there and the document there speaks for itself. MR. EDWARDS: Okay. Q Respond, A. The document speaks for itself. Q ** So you agree with the affirmative defenses that were filed in your case? If you were to testify, we could expect that to be your testimony? MR. PIKE: That's not what the witness testified. The witness testified that the document speaks for itself, and again, }'m going to object to attorney/client, work product and instruct the witness not to answer. Q I'm not asking what your legal defense is. I'm asking: What is your response to the claims? MR. PIKE: Same objection. Q What is your personal response? A I would like to respond to that question. I would like to respond today to that question; however, today my attorneys have told me that I cannot respond. They've asked me to assert my Fourteenth Amendment, Sixth Amendment and Fifth Amendment rights of the U.S. 39 (Pages 150 to 153) U.S. Legal Support (561) 835-0220

Constitution, though I would really like to respond. They are telling me if] did so, I will Jose risking their representation. Q Tknow you've invoked your Fifth Amendment rights related to many of these questions, but isn't it true you recently contacted George Rush at The New York Daily News and spoke to him about L.M.'s case as well as several of the other girls, who have claims against you? A Who? Q George Rush, New York Daily News. A Can you repeat the question? Q Didn't you recently, within the last year, contact George Rush of The New York Daily News and discuss these cases that have been filed against you and the allegations made by these varions females? MR. PIKE: Form. A_ [would like to answer that question, but unfortunately today my attorneys have advised me cannot. They've advised me I must assert my Sixteenth -- excuse me, my Fourteenth Amendment, Sixth Amendment and Fifth Amendment right, so therefore, I will do so, 155 Q Why is it that you will talk to George Rush about this but you will not talk to the jury about this? MR. PIKE: Form. Argumentative, speculation. Misstates the witness's testimony, It assumes facts -- the question. assumes facts not in evidence and now lacks predicate. A. So who is George Rush again? 19 20 21 22 23 24 25 Q George Rush, reporter with The New York! 10 Daily News. Did you not talk to him? If you didn't talk to him, tell me that. That's fine. MR, PIKE: Same objections, A_ I would like to teil you answers to each one of your questions, however today my attorneys have demanded that I respond by asserting my Fourteenth Amendment, Sixth Amendment, Fifth Amendment privilege, though I would like to respond, but they said if I do so, I risk losing, their representation. Q Didn't you tell George Rush these underage minors were not victims at ali and that regardless of their age, you did not personally consider them victims? MR. PIKE: Same objection. | i i 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A (Laughter.)... Did I tell... I would like to answer that question, but today on advice of my counsel, J must -- as I have done with mostly each one of your questions, ] have to assert my Fiflh Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution. Q You were $i when L.M. was 14, and you were interacting with her sexually, is Ht your testimony that despite the disparity in age you do not consider L.M. to be a victim? MR, PIKE: Argumentative, speculation, assumes facts not in evidence. Compound, lacks predicate, A Not only does it contradict your own. ctient's statements to the FBI under sworn testimony, I would like to answer that question. Hopefully one day J can answer that question, but today my attorneys have said I cannot. They advised me I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment rights. Q Inthe last ten years, what is the youngest underage minor femate that you have interacted with sexually? MR, PIKE: Argumentative, speculation, assumes facts not in evidence, A The answer to that question is -- | would like to give you an answer to that today, but my attorneys have advised me { must assert my Fourteenth Amendment rights, my Sixth Amendment rights and Fiflh Amendment rights. Q Do you know Michael Friedman? A_ Doesn't ing a bell. Q Former housekeeper/employee of yours, worked at the Palm Beach house? A ... Could, Don't know. Q Se you would be unable to answer what Michael Friedman did for you? A Yes. Q Are you aware that our investigator spoke with Michael Friedman, former housekeeper for you, or housemanager for you, out in California? A No, Q Any reason why when asked about the activity that occurred ia your house, he would tear up and say, "I was hoping to forget everything I saw"? MR. PIKE: Objection, argumentative. Speculative. Assumes facts not in 40 (Pages 154 to 157) U.S. Legal Support (561) 835-0220

evidence, A Again, the question? Q Is there any reason that when asked — A_ {don't know who he is. MR. PIKE: Also, hearsay. THE VIDEOGRAPHER: Counsel? MR. EDWARDS: Go ahead. THE VIDEOGRAPHER: Going off the video record 3:23 p.m, (Pause in the proceedings.) THE VIDEOGRAPHER: Back on the video record 3:30 p.m. Q This person that I asked you about, Michael Friedman, is that somebody whe has contacted you within the last six months? A ... No. Q In taking a break and thinking about some of these questions, have you remembered who! that person is, or still1no real memory ofhimat = { all? A. No seal memory. Q To the best of your knowledge, he never worked for you? MR. PIKE: Form. A Not that I can recall, but there are 159 lots of people who work for me, 30... Q Can you tell the jury who the various people are that work for you now? A [believe I answered that question already. Q In that you invoked your Fifth Amendment, correct? A. That's correct, Sixth Amendment and Fourteenth Amendment. Q Eigthteen and twenty-first? A. (Witness shrugs.) MR. PIKE: Move to strike. Q ** Have you, during this litigation, and by “this litigation,” I don't only mean L.M.'s case, but the various other lawsuits that have been filed against you by other females alleging sexual misconduct by you against them. Who have you retained attorneys for, what witnesses have you retained attorneys for? MR. PIKE: Object to the form. MR. EDWARDS; Okay. MR. PIKE: I'll instruct him not to answer because ] don't understand the question. Okay? MR. EDWARDS: All right. 18 19 20 2. 22 23 24 Q During this civil discovery and litigation -A Um-hum? Q --have you paid for, and/er retained an attorney for any other witnesses? A Any other witnesses? Q Yes, like I'll give you an example that you may, just to refresh your recollection or tell you what I'm talking about, Lowella Rabuyo; you know who that is, right? A Yes. Q She is someone to works for you now, she's a housekeeper. We took her depesition already. At least that's what her testimony was. MR. PIKE: Form. A_ I would like to answer that question but Thave to assert my Sixth Amendment, Fourteenth and Fifth. Q That somebody who has informed us that you paid for and obtained an attorney by the name of Bruce Reinhart to represent her during this process. Is that — MR. PIKE: Form. A_[have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment, right. Q Other people that have indicated that you retained and paid for an attorney to represent them are Michael Friedman, Louella Rabuyo, Janusz Banaziak, Nadia Marcinkova, Ghislaine Maxwell, your brother, Mark Epstein, Naley Robson, Sarah Kellen, Larry Visoski, Larry Morrson, David Rogers, Igor Zinoview. Have I missed anybody else that during this litigation you've paid for or retained attorneys? MR. PIKE: Form, same objection. A I'mnotclear. Are you suggesting I've paid for attorneys for all these people? Q Yes. A {Laughier,) I would like to answer those questions today, but on the advice of counsel I have to invoke my Sixth Amendment, Fifth Amendment and Fourteenth Amendment right. Q Ifyou have not, tell me which of those on that list that you have not paid for or retained attorneys for? MR. PIKE: Same objection, A Same answer. Q You're invoking your Fifth Amendment, right? 41 (Pages 158 to 161) U.S. Legal Support (561) 835-0220

162 A And Sixth Amendment and Fourteenth Amendment... and Fifth Amendment. Q ** Is ita company or is it you, personally, that is paying for the attorneys‘ fees related to your representation? MR. PIKE: I'm going to object to the form. I'm going to instruct him not to answer that question based on relevance; and it is vague also. Q Who is writing the check to your attorneys for your representation in this lawsuit? A (No response.) Q Who is paying the bill? A Ibelieve Lam. Q And is it you, personally, or is this one of your corporations or companies? MR. PIKE: Form, speculation. A I'm not sure. Q As you sit here today, you're not really sure whether it is coming from one of the other corporations that we've discovered during discovery or it is coming from you, personally? Is that correct? MR. PIKE: Asked and answered. 163 A_ 1 believe -- ] would like to answer but Thave to invoke my Sixth, Fourteenth and Fifth Amendment rights. Q Asit relates to any of the other witnesses who have had attorneys retained for them, is it also your response to invoke your Fifth Amendment rights, rather than to provide me with an answer, as to who is paying the bill for those attorneys? A I would like to answer those questions, but today my attorneys have asked me not to respond to any questions that may be relevant to this lawsuit, so I must follow their advice and invoke the Sixth Amendment, Fifth Amendment and Fourteenth Amendment, right. Q Have you interacted sexually with any underage minors in the Jast year, while on house arrest or work release from jail? MR. PIKE: Objection. Argumentative and compound and lacks predicate. A. I would like to answer that question, but on advice of counsel, at least today, they've advised me | must invoke my Sixth Amendment, Fourteenth and Fifth Amendment right. MR. PIKE: It is also overbroad. OyInueswnoe il 12 13 14 15 16 17 18 is 20 21 22 23 24 OIA TG ewWNHe o AL 12 13 14 15 16 7 18 19 20 21 22 23 24 25 164 Q Ifme narrowing down will help you to respond, I will. Is there any need for that? A. (Witness shakes head.) MR. EDWARDS: Okay, THE WITNESS: Sorry. Q Isit your intent to interact sexually with minors in the future? MR. PIKE: Same objection. A. | would like to answer that question, but today my counsel has advised me I must invoke the rights of the Sixth Amendment, the Fourteenth Amendment and the Fifth Amendment of the U.S. Constitution. Q Are you currently treating with a psychologist related to any sex addiction that you have with minors? A. I would like to answer that question, as well, as most of the other... questions you've asked me today; however, on advice of counsel they've asked me to invoke my Sixth Amendment, Fourteenth Amendment and Fifth Amendment right, therefore, though I would tike to answer that question, as well as the other ones, I risk losing the representation if 1 do so. MR. PIKE: Moreover I'm going to object 165 to relevance as | have in the past since Mr. Epstein's medical history is not at issue in this case; under the legal terms. Q You would agree, wouldn't you, that you targeted these underage girls including L.M. because of their young age? MR. PIKE: Argumentative, speculative, harassing. Assumes facts not in evidence. A Il would like to answer that question, as well as most of the other questions you've asked me here today. My counsel has advised me that ] must assert my Fourteenth Amendment, Sixth Amendment and Fifth Amendment right. Though I would like to answer those questions today... if I do so, I risk losing their representation. Q You would also agree, wouldn't you, that you targeted these underage females for sex, including L.M., because they were poor? MR. PIKE: Same objections. A_ I would like to answer that question. 1 would really like to answer that question, as well as the other questions you've asked me here today, however, on advice of my counsel they've demanded that | assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights. HI 42 (Pages 162 to 165) U.S. Legal Support (561) 835-0220

answer that question, | risk losing their 1 representation. 2 Q You would agree, wouldn't you, that you | 3 sexually molested L.M. for three years? | 4 MR, PIKE: Same objection. 5 A I think you've asked me that question 6 before. 1 assert the same rights as before, Ne Q That's the Fifth, Sixth and Fourteenth 8 amendments, just so the record is clear? } 3 A Yes. 10 Q You would agree, wouldn't you, that you il coerced L,M. into prostitution? 12 MR. PIKE: Same objections. 13 A [believe her own testimony reflects, at 14 feast the sworn statement to the FBI, reflects 115 that that is not the case; and though I would. 16 like to answer that question in great detail, T 17 cannot do so today on advice of counsel, that 18 have asked me to assert my Sixth Amendment, Fifth 19 Amendment and Fourteenth Amendment rights. IfT 20 do so, I risk losing their representation. i 21 Q You would agree with me that you groomed! 22 L.M. into becoming a prostitute? 23 MR. PIKE: I'm going to object. 24 Argumentative, speculative. Certainly lacks . 25 167 predicate and assumes facts not in L evidence. 2 A You know I would like to answer that 3 question, but I can't today. Under advice of 4 counsel J have fo assert my Fourteenth Amendment, > Sixth Amendment and Fifth Amendment rights. If] 6 answer the question, I risk losing their 7 counsel, 8 Q You would agree, wouldn't you, that you =| 9 brainwashed L.M. inte believing that this | 10 lifestyle of prostitution was right? a1 MR. PIKE: Same objections. 12 A I would like to answer that question, as 13 most of your other questions here today, Mr. ; 14 Edwards. On advice of counsel today, I'm going ; 15 to have to assert my Fifth Amendment, Sixth i 16 Amendment, Fourteenth Amendment rights. If] 17 answer that question, J risk losing their 18 representation. 19 Q Would you agree that your interaction | 20 with L.M. when she was a minor, was degrading to| 21 her? 22 MR. PIKE: Same objections. 23 A I would like to answer that question, I would like to answer all of your questions here 168 today; however, my counsel has advised me that 1 must assert my Fourteenth Amendment rights, my Sixth Amendment rights and my Fifth Amendment rights, and though I would like to answer those questions, if I do so I risk losing their representation. THE WITNESS: Can we take a ten-minute break for some air? MR. EDWARDS: We have 15 minutes and we're done. THE WITNESS: Continue then? MR. EDWARDS: Okay. Q Would you agree that you intentionally indoctrinated L.M. into this very deviant sexual Hfestyle? MR. PIKE: Okay, !'m going to object. It is argumentative. It is confusing. It is speculative, vague, lacks predicate and assumes facts not in evidence. A. And on top of that, I would like to answer that question, but my counsel has advised me I must assert my Fourteenth Amendment, Sixth Amendment and Fifth Amendment rights under the US. Constitution. Although I would like to answer all your questions today, Icannot do so 169 risking losing their representation. Q Would you agree that you were personally responsible for destroying her life? MR. PIKE; Same act objections. A. Her life? Q L.M.'s? A. I would like to answer that question, and J understand how your firm has been accused of fabricated sexually charged lawsuits in order to fleece investors locally in South Florida. ‘The U.S. Attorney has called your law firm a criminal enterprise based on filing fellacious {sic) sexually charged cases. Although I would like to answer that question today, Mr. Edwards, and Mr. Jaffe, my counsel has told me that I have to assert my rights under the Sixth Amendment, Fifth Amendment and Fourteenth Amendment, and if. I don't do so, I risk losing their representation. Q We have a factual basis for asking every question and making every allegation. I want to provide you with a last opportunity to tell the jury which of these allegations, if any, being made by L.M., are false or fabricated in any way? 43 (Pages 166 to 163) U.S. Legal Support (561) 835-0. 220

SAYRE WH © 10 1a 12 13 14 15 16 a7 18 19 20 21 22 23 24 170 MR. PIKE: Same objections, Mr. Edwards, you know the tenor of that question | cannot be answered without waiver of Fifth, Sixth end Fourteenth, | appreciate the question and the semantics of it, but it is... It is -- can you rephrase it? MR, EDWARDS: Yes. Q Many times -- you know the aliegations now, we've gone through them, L.M.'s allegations and assertion of facts as to what happened between you and her when she was 13, 14 and 15 years old and you were 50, $1, 52 years old. Several times you responded saying something about Rothstein, Rosenfeld & Adler, something about her FBI statement, what have you; I want to give you a chance to tell the jury, which of her allegations, if any, that you believe now are false or fabricated in any way. MR. PIKE: Same objections. A. I would like to respond to that question, the fact that her firm, the law firm representing her has been accused by the U.S. Attomey of being a criminal enterprise, manufacturing, fabricating, out of thin air, cases involving sexual allegations, sexual allegations in order to simply fleece local investors out of millions of dollars, so I would very much like to answer that question regarding, the truthfulness of L.M.'s allegations; however today my counsel has told me that I must assert my Fifth Amendment rights, Sixth Amendment rights and Fourteenth Amendment rights under the U.S, Constitution, though I would very much like to answer that questions but if I do I risk losing their representation. Q Would you agree you owe L.M. atleast =| $15,000,800 to compensate her for the damage = * which you have caused? i MR. PIKE: Objection. I move to strike. Argumentative. Compound. Lacks substantia! predicate, Assumes... facts... not in evidence. A AS you might imagine, though your law firm has been accused of perpetrating a fraud involving millions and millions of dollars, on. unsuspecting investors here in South Florida, millions of dollars by fabricating similar allegations, convincing people to give money to the firm that helped bring this lawsuit, I'm afraid 1 would like to answer those questions but 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15: 16 17 18 19 20 21 22 23 24 ae ne RAKKAwW 9 190 LL 12 13 14 i5 16 17 18 19 20 21 22 23 24 25 172 no matter how much I would like to answer those questions, | am going to have to decline based on my counsel's advice to invoke, at least today, my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S, Constitution; because if] don't, E risk losing their representation, Q Is it true that you're currently worth more than one billion dollars personally? AT would like to answer that question, as I would like to answer most of your other questions. 1 know that's a lot of money -actually the amount of money that the U.S, attorneys accused your firm of trying to steal from the people of South Florida. It was 1.2 billion dollars, the U.S. Attorney claimed your firm perpetrated the largest fraud in South Florida's history by stealing that sum of money from local investors, based on false allegations of sexually charged claims, and although | would like to answer these questions with specificity, under advice of counsel today, I'm going to have to refuse, based on my Sixth Amendment, Fourteenth Amendment and Fifth Amendment right, and though 1 ould ke to answer the question, L 173 have been told if I de so I risk losing their representation, Mr. Edwards. Q I'm simply asking: What is your personal net worth at this time? MR. PIKE: Form. A [think I've answered the question, but... Q What is your personal net worth at this time? So the answer should be a namber or should be you invoking your Fifth Amendment rights, Seemed like the opposite. MR. PIKE: Asked and answered, he did invoke his Fifth, Sixth and Fourteenth. MR. EDWARDS: His answer included something about Rothstein, Rosenfeld and Adler stealing some certain amount of money, which obviously is nonresponsive, F move to strike it and ask that he actually responds to the question with something that’s responsive. He can answer the question, invoke Fifth Amendment rights, and we will get out of here. Q We will start over again. Can you please tell the jury what your current personal net worth is currently? 44 (Pages 170 to 173) U.S. Legal Support (561) 835-0220

174 AT would fike to do that today, however, I'm sure that one of the reasons, since your firm has been accused of stealing millions of dollars from local investors based on fabricated, totally fabricated claims, this is not by me but the U.S, Attorney, has called your firm a criminal enterprise charged with stealing hundreds of mitlions of dollars frankly, from local investors, based on faise claims of sexually charged nature, I would like to answer that question in detail. However, my attorneys have advised me I cannot answer any questions that may be relevant to this lawsuit and by doing so, I must invoke my Sixth Amendment, Fifth Amendment, Fourteenth Amendment right and by answering the question, I risk fosing their representation. Q Is it true you're worth 1.8 billion dollars? MR. PIKE: Same objection. A Same answer. Q Put the answer. MR. PIKE: For the record. A i'm sure that's an interesting question and I would like to answer that question for you. Tm; sure you would like to know as your 175 firm has been charged with stealing over a diflion dollars from local investors and your senior partner of both you and Mr, Jaffe sitting there shaking his head, sits in jail accused of fleecing local and foreign investors based on false sexual claims from people. And although I would like to answer that question, like 1 would answer most of your other questions, my counsel has advised me today, ladies and gentlemen of the jury, I cannot answer that question. Maybe I can in the future. However, if I do so today, I risk losing their representation, so I must assert those rights under the Sixth, Fifth and Fourteenth amendments. Q You would agree, would you not, that it would take a jury award of at feast 45 million doliars in punitive damages to punish you for doing what you did to L.M.? MR. PIKE: Same objections. A. I would like to answer that question, as 1 would like to answer all your other and Mr. Jaffe's questions today. However, while he sits shaking his head I'm going to have to respond to -- my counsel has advised me I cannot answer that question today, though I would like to. OMARGA WHE | 116 | 19 20 21 22 23 24 | 25 176 Though I would like to answer with specificity, however if! do so, I risk losing their representation so I must assert my rights under Sixth, Fifth and Fourteenth Amendment. Q Isn't it true, Mr. Epstein, that as long as you have the money te do it, you will continue to engage in sex with minors? MR. PIKE: Again, extremely argumentative, speculative. I'm allowing the question to give leeway, so we don't have to come back here again. It is harassing. A And with that, I'm sure this — ladies and gentlemen of the jury, will... be able to see you and your partner, who your firm has been accused of massive fraud in South Florida trying to steal hundreds of millions of dotlars from local investors, from creating, fabricating malicious, sexually charged claims, called by the US. Attorney a criminal enterprise charged with money laundering, conspiracy to commit other -federal violations, so though I would like to answer that question, Mr, Edwards, and Mr. Jaffe, today, cannot. J] must invoke my Sixth, Fifth and Fourteenth Amendment rights, on advice of | 177 counsel or risk losing their representation. @ Am I correct in my understanding that you have invoked your Fifth Amendment rights because your answers would incriminate you and lead to your prosecution? MR. PIKE: I'm going to — MR. EDWARDS: Exactly as phrased by Mr. Luttier to L.M. 1 did not say anything but allow her to answer the question, MR. PIKE: Object to the fonn. A. In fact, since you are a lawyer I'm sure you're aware the Supreme Court has said the Fifth Amendment is used more often to protect innocent people. So that’s — but today on advice of counsel I've taken that right. MR, EDWARDS: (Gesturing.) MR. PIKE: [have no questions. We will read. MR. EDWARDS: No further questions. THE VIDEOGRAPHER: Off the video record, 3:52 p.m, THE COURT REPORTER: Can he read your copy Mr. Pike? MR. PIKE: Yes. THE COURT REPORTER: Thank you ail. 45 (Pages 174 to 177) U.S. Legal Support (561) 835-0220

178 MR. PIKE: On the record, I don't want a word index. THE COURT REPORTER: Okay. (Discussion off the record.) MR. PIKE: I would like this tomorrow, please. Let's go regular but definitely before that -- before Tuesday, if possible. THE COURT REPORTER: Sure, that will be; 50 percent expedite? MR. PIKE: That's fine. THE COURT REPORTER: My pleasure. (Time noted: 4:00 o'clock p.m.) THE STATE OF FLORIDA) COUNTY OF PALM BEACH) I, TERRI BECKER, a Registered. Professional Reporter and Notary Public for the State of Florida at Large, do hereby certify that I reported the videotaped deposition of JEFFREY EPSTEIN, the DEFENDANT, called by the PLAINTIFF | in the above-entitled action; that the witness | was duly sworn by me; that the foregoing pages, numbered from 1 to 183, inclusive, constitute a true record of the deposition by said witness. I further certify that I am not attorney or counsel of any of the parties, nor a relative or employee of any attorney or counsel connected with the action, nor financially interested in the action. WITNESS MY HAND and official seal in the City of West Palm Beach, County of Palm Beach, State of Florida, this 22nd day of February 2010. TERRI BECKER, Registered Professional Reporter and Notary Public, State of Florida at Large. My Conunission expires March 13, 2011. ODBUIHTSwWNheE THE STATE OF FLORIDA) COUNTY OF PALM BEACH) The foregoing certificate was acknowledged before me this day of. 2009, by TERRI BECKER, who is personally known to me. Notary Public, State of Florida. My commission No. Expires March 13, 2011. 181 I, JEFFREY EPSTEIN, do hereby certify that I have read the foregoing transcript of my deposition given on February 17, 2010; that together with the correction page attached hereto hoting changes in form or substance, if any, it is true and correct. JEFFREY EPSTEIN I do hereby certify that the deposition of JEFFREY EPSTEIN was submitted to the witness for reading and signing; that after he had stated to the undersigned Notary Public that he had read and examined her deposition, he signed the same in the presence of the undersigned authority on thes day of 2040, 46 (Pages 178 to 181) U.S. Legal Support (561) 835-0220

1 ERRATA SHEET { In Re: LM. V, EPSTEIN { 3 DO NOT WRITE ON TRANSCRIPT ENTER CHANGES HERE: 4 5 PAGER LINE CHANGE REASON 6 7 { 8 9 10 | ‘13: L 12 13 cr | 15 JEFFREY EPSTEIN 16 17 18 THE STATE OF FLORIDA) 19 COUNTY OF PALM BEACH) 20 1 DO HEREBY CERTIFY THAT JEFFREY EPSTEIN appeared before me and stated that he has read 21. his deposition; further, that this Ecrate Sheet | ‘was signed in my presence on this day | 22 oof, 2010. & | 24 25 183 < US. LEGAL SUPPORT Registered Professional Reporters 2 444 West Railroad Avenue Suite 300 3 ‘West Paim Beach, Florida 33401 4 56 1)835-0220 : February 22, 2010 6 BURMAN, CRITTON, LUTTIER & COLEMAN 303 Banyon Boulevard ? ‘Suite 400 ¢ ‘West Palm Beach, Florida 33401 9 ATTENTION: MICHAEL PIKE, ESQ. Es Tn Re: LM, V. EPSTEIN e Deposition of: JEFFREY EPSTEIN i wz Dear Mr, Pike: Since counsel have agreed that you may 1d have the wimess read and sign your copy of the: deposition, for your convenience, enclosed 15 herewith you will find an Errata Sheet for the witness! ase in entering any changes to the 16 deposition 17 “Thanic you for your prompt sttention. 18 Cexdially yours, US, LEGAL SUPPORT 19 20 TERRI BECKER, Regiatered 21 Professional Reporter, Notary Public, State of Florida at 22 Lange. My commission expires Maret 13, 2011. 23 CC: Bradley Bawards, Esq, i 24 25 47 (Pages 182 to 183) U.S. Legal Support (561) 835-0220