EFTA01103326.pdf

Page 1 Page 3 IN THE CIRCUIT COURT OF THE FIFTEENTH 1 INDEX JUDICIAL CIRCUIT, IN AND FOR 2 Direct Examination by Mr. Edwards 4 PALM BEACH COUNTY, FLORIDA 3 4 EXHIBIT INDEX ) Plaintiffs Exhibit Hunter I marked for ID. 24 ) Plaintiff; 6 (Exhibit held by Attorney Edwards.) ) 7 vs. 149. +++++++++ ) 8 EPSTEIN and 9 ) 10 Deposition of JEFFREY EPSTEIN, a witness ) 11 of lawful age, taken by the Plaintiff, for the Defendants. ) 12 purpose of discovery and for use as evidence in the 13 above entitled cause, wherein: E.W. is the 14 Plaintiff, and JEFFREY EPSTEIN and- West Palm Bach, Florida 15 the Defendants, in the Circuit Court in and for Palm April 30th, 2009 16 Beach County, Florida, pursuant to notice heretofore I008 o'clock A.M. 17 filed, before LINDA P. AUKAMP, a Registered 18 Professional Reporter and Notary Public in and for 19 the State of Florida at Large, at 250 Australian VIDEOTAPED DEPOSITION 20 Avenue South, Suite 1400, West Patin Beach, Palm OF 21 Beach County, Florida, on the 30th day of April, JEFFREY EPSTEIN 22 23 2009, commencing at 10:08 o'clock A.M. I 24 25 Page 2 Page 1 APPEARANCES: 1 THEREUPON, 2 For The Plaintiff: 2 THE VIDEOGRAPHEEt: This is the 30th day 3 ROTHSTEIN, ROSENFELDT, ADLER 3 April, 2009. The time is 10:08 a.m. This is 401 East Las Olas Boulevard, Suite 1650 4 Fon Lauderdale, Florida, 33301.4252 4 videotaped ition of Jeffrey Epstein in the By BRADLEY JAMES EDWARD, ESQUIRE and 5 matter of... versus Epstein. This deposition 5 WILLIAM J. BERGER, ESQUIRE and 6 is being held at 250 Australian Avenue South, RUSSELL ADLER, ESQUIRE 6 7 West Palm Beach, Florida. My name is Jeff 7 For The Defendant Abbott, lam the videographer representing BURMAN, CRITTON, LUTHER & COLEMAN 9 Visual Evidence, Incorporated. S I5 North Plaster Drive, Suite 400 10 Would the attorneys please announce their 9 West Palm Beach, Florida 33401.4349 By JOHN MICHAEL BURMAN, ESQUIRE 11 appearances for the record. 10 12 MIt EDWARDS: Brad Edwards on behalf of 11 Also for the Defendant 3.3 the plaint' "deposition was set in 12 ATTER.BURY, GOLDBERGER & WEISS, P.A. the case of 3.4 250 Australian Ave. South, Suite 1400 13 West Palm Beach, Florida 33401 15 THE VIDEOGRAPHER: Oh. By JACK A. GOLDBERGER, ESQUIRE 16 MR. EDWARDS: That is a separate client of 14 17 mine, but that's not the case 15 Also Present: 16 Jeff Abbott, Videographer, Visual Evidence 18 THE VIDEOGRAPHER: Okay, that's what I 17 19 had. Sorry. 18 20 MR. BERGER: And Pm William J. Berger, 19 21 for the plaintiff, also. 20 21 22 MR. GOLDBERGER: Jack Goldberger on behal 22 23 of Jeffrey Epstein. 23 24 MR. BURMAN: Michael Burman on behalf of 24 25 25 le in. Mat'•-•••mil.N 1 (Pages 1 to 4) PALM BEACH REPORTING SERVICE, INC. EFTA01103326  Page 5 Page 7 1 THEREUPON, 1 length - 2 JEFFREY EPSTEiN, 2 MR. BURMAN: Obviously we can't tell what 3 Being a witness in the notice heretofore 3 you're going to play to a jury without the 4 filed, being of lawful age, and being first duly 4 entire spiel, what questions you night play to 5 sworn in the above cause, testified on his oath as 5 a jury if you decide to do that when this case 6 follows: 6 is tried, so we're going to go with the entire 7 THE WITNESS: Yes, I do. 7 spiel to every question you ask. If -- that's 8 DIRECT EXAMINATION 8 Mr. Goldberger's representation, or 9 Q. (By Mr. Edwards) Can you tell us your 9 recommendation. 10 fidl name for the record? 10 MR. EDWARDS: Okay. 11 A. Jeffrey Edward Epstein. 11 MR. GOLDBERGER: We will go question by 12 Q. And what's your date of birth? 12 question, and we may or may not invoke Fifth 13 A. January 20th, 1953. 13 Amendment privileges and there may be times 14 Q. And your social security number? 14 where I'm going to have to think about it, 15 A. 15 discuss it with Mr. Burman whether we're going 16 Q. And your current address in West Palm 16 to invoke on any particular question, but on 17 Beach? 17 those questions that we do invoke Fifth 18 A. I intend to respond to all relevant 18 Amendment privileges, I think we have no choice 19 questions regarding this lawsuit. However, at the 19 but, as you say, do the entire spiel. 20 present time my attorneys have counseled me that I 20 Q. (By Mr. Edwards) Can you tell me the 21 cannot provide answers to any questions relevant to 21 addresses of other homes that you own outside of 22 this lawsuit, and I must accept the advice or risk 22 West Palm Beach? 23 losing my Sixth Ansadment right to effective 23 A. I intend to respond to all relevant 24 representation. 24 questions regarding this lawsuit. However, in the 25 Accordingly, I assert my Fifth, Federal 25 present my attorneys have counseled me that I cannot Page 6 Page 8 3. Constitutional rights as guaranteed by the Fifth, 1 provide answers to any questions relevant to this 2 Sixth, and Fourteenth Amendments to the United 2 lawsuit, and i must accept the advice or risk losing 3 States Constitution. 3 my Sixth Amendment right to effective 4 Q. So you're unwilling to give us your 4 representation. 5 address of your house in Palm Beach Comity? Q. Have you seen any — 6 A. I intend to respond to all relevant 6 MR. GOLDBERGER: And, excuse me, and your 7 questions regarding this lawsuit. However, at the 7 Fifth Anwhipeat privileges. 8 present time my attorneys have counseled me that I 8 THE WITNESS: Yes. 9 cannot provide answers to any questions relevant to 9 Accordingly, i, excuse me, I assert my 10 this lawsuit or risk losing my Sixth Amendment right 10 Federal Constitutional rights as guaranteed by 11 to effective representation. 11 the Fifth, Sixth and Fourteen Amendments of the 12 MR. EDWARDS: Mr. Goldberger, can we enter 12 United States Constitution. 13 into an agreement so that we all know that he's 13 Q. (By Mr. Edwards) Have you seen any 14 reading off of that piece of paper, we know 14 psychologists a psychiatrists in your life? 15 what the whole spiel is, but maybe he can just 15 MR. GOLDBERGER: Go ahead. 16 say fifth or same answer or something like 16 THE WITNESS: I intend to respond to all 17 that, so we can continue to move on, rather 17 relevant questions regarding this lawsuit. 18 than read that paper the entire time? We'll be 18 However, at the present time my attorneys have 19 here for days. 19 counseled me that I cannot provide answers to 20 MR. GOLDBERGER: I think out of an 20 any questions relevant to this lawsuit, and i 21 abundance of caution ifs probably appropriate 21 must accept this advice or risk losing my Sixth 22 that whatever we feel is the proper response 22 Amendment right to effective representation. 23 is, so that our invocation of our Fifth 23 Accordingly. I assert my constitutional 24 Amendment privileges is properly protected, 24 rights as guaranteed by the Fifth, Sixth and 25 so I think we're noin to have to Ove the full 25 Fourteenth Amendment of that constitution. 2 (Pages 5 to 8 PALM BEACH REPORTING SERVICE, INC. EFTA01103327  Page 9 Page 11 1 Q. (By Mr. Edwards) Tell me the names of all 1 A. Sorry, could you repeat the question? 2 the businesses in which you are affiliated in any 2 Q. Sure. 3 way? 3 I have a videotaped copy of the plea 4 A. I intend to respond to all relevant 4 colloquy — 5 questions regarding this lawsuit. However, at the 5 A. No, the question before that. That's 6 present time my attorneys have counseled me that I 6 okay. 7 cannot provide answers to any questions relevant to 7 Q. The question is, where do you intend to 8 this lawsuit, and I must accept this advice or risk 8 reside once you are released from jail? 9 losing my Sixth Amendment right to effective 9 A. I intend to respond to all relevant 10 representation. 10 questions regarding this lawsuit. However, at the 11 I also assert my Federal Constitutional 11 present time my attorneys have counseled me that I 12 Rights as guaranteed by the Fifth, Sixth, and 12 cannot provide answers to any questions relevant to 13 Fourteenth Amendments to the United States 13 this lawsuit, and I must accept their advice or risk 14 Constitution. 14 losing my Sixth Amendment right to effective 15 Q. My understanding is you're currently 15 representation. 16 serving a 12-month jail sentence, is that correct? 16 Accordingly, I assert my Federal 17 MR. GOLDBERGER: You can answer, but -- 17 Constitutional right as guaranteed by the Fifth, 18 THE WITNESS: Na 18 Sixth, and Fourteenth Amendment of the United States 19 Q. (By Mr. Edwards) You were currently, you 19 Constitution. 20 were initially sentenced to 18 months in jail, is 20 Q. As you know, that question was asked to 21 that correct? 21 you when you pled guilty last June in 2008, and you 22 MR. GOLDBERGER: Go ahead. 22 responded to the judge that you planned to reside in 23 THE WITNESS: Yes. 23 West Palm Beach, Florida. Is that no longer your 24 Q. (By Mr. Edwards) And at the present 24 intent? 25 moment are you still under the supervision of that 25 A. I intend to respond to all relevant Page 10 Page 12 1 jail sentence? 1 questions regarding this lawsuit However, at the 2 A. Yes. 2 present time my attorneys have counseled me that I 3 Q. Do you !mow what your release date will 3 cannot provide answers to any questions relevant to 4 be? 4 this lawsuit, and I must accept this advice or risk S A. No. 5 losing my Sixth Amendment right to effective 6 Q. You have not been told the date of your 6 representation. 7 release? 7 Accordingly, I assert my Federal 8 A. Not yet. 8 Constitutional right as guaranteed by the Fifth, 9 Q. Where do you plan to reside when you're 9 Sixth, and Fourteenth Amendment of the constitution. 10 released from jail? 10 Q. This deposition is not being taken in the 11 A. I intend to respond to all relevant 11 county jail, but rather in your attorney, Jack 12 questions regarding this lawsuit. However, at the 12 Goldberger's office, so can you please inform the 13 present time my attorneys have advised me that I 13 jury as to your current schedule as it is exists 14 must accept the advice, advised me not to answer 14 today? 15 those questions. I must accept their advice or risk 15 MR GOLDBERGER: Let me hold off on that. 16 losing my Sixth Amendment right to effective 16 Okay. 17 representation. 17 THE WITNESS: I don't understand the 18 Accordingly, I assert my Federal 18 schedule, the question. 19 Constitutional right as guaranteed by the Fifth, 19 MR. GOLDBERGER: Yeah, if you can just, if 20 Sixth, and Fourteenth Amendment of the constitution. 2o you can rephrase the question, I think we can 21 Q. Mr. Epstein, I have a videotaped copy of 21 answer it for you. 22 the plea colloquy where you pled guilty and told 22 Q. (By Mr. Edwards) Okay. Currently you 23 that judge you would be residing in West Palm Beach, 23 described that you're under the supervision of the 24 Florida. Are you saying now that the statement you 24 jail sentence at this point in time, you're within 25 made to that inlEn312longer true? 25 the 18 months of your,jail sentence. But this isn't 3 (Pages 9 to 12) PALM BEACH REPORTING SERVICE, INC. EFTA01103328  Page 13 Page 15 1 a jail setting, so obviously you're outside of the 1 constitution. 2 jail setting. 2 Q. (By Mr. Edwards) Are you saying that 3 I am asking you just to tell the jury your 3 providing me an answer as to where you currently 4 current schedule; you wake up, are you released from 4 work, would somehow incriminate you? 5 jail at some time, do you have to report back to 5 MR. GOLDBERGER: Let's not be 6 jail on a daily basis? 6 argumentative. He responded to the question on 7 A. Yes, I report back to jail at 8:00 p.m. 7 advice of counsel, and if you think that was an 8 Q. Every single day? 8 improper invocation, then you have a remedy, 9 A. Yes. 9 but don't argue with the witness, which is what 10 Q. And is it seven days a week that you're 10 we did. Okay. 11 out on work release? 11 Q. (By Mr. Edwards) Do you have any plans to 12 A. No, sir. 12 leave the country once you're released from jail? 13 Q. How many days a week are you out on work 13 A. I intend to respond to all relevant 14 release? 14 questions regarding this lawsuit. However, at the 15 A. Six. 15 present time my attorneys have counseled me that I 16 Q. And of those six days, how many hours per 16 cannot provide answers to any questions relevant to 17 day are you out on work release? 17 this lawsuit, and must accept the advice or risk 18 A. Twelve. 18 losing my Sixth Amendment right to effective 19 Q. And what are the hours that you're out on 19 representation. 20 work release versus the hours that you are confined 20 Accordingly, I assert my Federal 21 to the jail? 21 Constitutional right as guaranteed by the Fifth, 22 A. Repeat the question, please. 22 Sixth, and Fourteenth Amendment of the constitution. 23 Q. What are the hours that you are out on 23 Q. Do you currently own any jets or 24 work release outside the jail versus the hours that 24 airplanes? 25 you are inside the jail, meaning if you report back 25 A. I intend to respond to all relevant Page 14 Page 16 1 to the jail at 8:00 and stay there until 8:00 in the 1 questions regarding this lawsuit. However, at the 2 morning, tell me that 2 present time my attorneys have counseled me that I 3 A. I just did. 3 cannot provide answers to any questions relevant to 4 Q. And is that the schedule? 4 this lawsuit, and must accept the advice or risk 5 A. !just did. Yes, that's the schedule. 5 losing my Sixth Amendment right to effective 6 Q. Okay. So from 8:00 p.m. until 8:00 an. 6 representation. 7 you're in the jail? 7 Accordingly, I assert my constitutional 8 A. Yes. 8 right as guaranteed by the Fifth, Sixth, and 9 Q. And then from 8.00 a.m. to 8:00 p.m. 9 Fourteenth Amendment ofirnstitution 10 you're out on work release? 10 MR. BURMAN: Is a state or federal 11 A. Is that a question? 11 case? 12 Q. Yes. 12 MR. EDWARDS: State. 13 A. Yes. 13 MR BURMAN: Okay. I am going to, in 14 Q. And where do you, where do you work? 14 addition to my client's assertion of his 15 MR. GOLDBERGER Objection. 15 rights, also object on the grounds that 16 THE WITNESS: I intend to respond to all 16 punitive damages hasn't been allowed in this 17 relevant questions to this lawsuit. However, 17 case yet. That's clearly a financial-type 18 at the present time my attorneys have counseled 18 question and, therefore, we object on those 19 me that I cannot provide answers to any 19 grounds, as well. 20 questions relevant to this lawsuit, and I must 20 MR. EDWARDS: Thank you. 21 accept this advice or risk losing my Sixth 21 Q. (By Mr. Edwards) Who are the pilots that 22 Amendment right to effective representation. 22 are employed by you or work for you or fly your 23 Therefore, I assert my Federal 23 airplanes? 24 Constitutional right as guaranteed by the 24 A. I intend to respond to all relevant 25 Fifth, Sixths and Fourteenth Amendment of the 25 questions regarding this lawsuit. However at the 4 (Pages 13 to 16) PALM BEACH REPORTING SERVICE, INC. EFTA01103329  Page 17 Page 19 1 present time my attorneys have counseled me that I 1 questions regarding this lawsuit However, at the 2 cannot provide answers to any questions relevant to 2 present time my attorneys have advised me that I 3 this lawsuit, and must accept their advice or risk 3 cannot provide answers to any questions currently. 4 losing my Sixth Amendment right to effective 4 Therefore, I must accept this advice or risk losing 5 representation. 5 my Sixth Amendment right to effective 6 Accordingly, I assert my Federal 6 representation. 7 Constitutional rights guaranteed by the Fifth, 7 Accordingly, ! assert my Federal 8 Sixth, and Fourteenth Amendment to the United States 8 Constitutional right as guaranteed by the Fifth, 9 Constitution. 9 Sixth, and Fourteenth Amendment to the constitution. 10 Q. What person or persons make your travel 10 Q. Are you currently working with the Florida 11 arrangements when you travel? 11 Science Foundation? 12 A. I intend to respond to all relevant 12 MR. GOLDBERGER: Umm, okay. 13 questions regarding this lawsuit However, at the 13 THE WITNESS: Yes. 14 present time my attorneys have advised me that I 14 Q. (By Mr. Edwards) And that is a, a 15 cannot provide answers to any questions relevant to 15 business that operates just next door to your 16 this lawsuit, and must accept this advice or risk 16 attorney, Jack Goldberger's office, is that correct? 17 losing my Sixth Amendment right to effective 17 A. No. 18 representation. 18 Q. The Florida Science Foundation does not 19 Accordingly, I would have to assert my 19 have an office on this floor right next door to your 20 Federal Constitutional right as guaranteed by the 20 attorney, Jack Goldberger's office? 21 Fifth, Sixth, and Fourteenth Amendment of the 23. A. Is that a question? 22 constitution. 22 Q. Yes. 23 Q. Once you are released from jail, are you 23 A. You have to rephrase the question, please? 24 under an obligation to report to probation? 24 Q. Does the Florida Science Foundation have 25 A. Yes. 25 an office right next door to your attorney, Jack Page 18 Page 20 1 Q. Do you intend to do so? 1 Goldbergees office? 2 A. Yes. 2 A. No. 3 Q. And once you are released, do you, 3 Q. What is your role with the Florida Science 4 according to your sentence, are you scheduled to 4 Foundation? 5 serve one year community control or house arrest? A. I intend to respond to all relevant 6 MR. GOLDBERGER: That's a compound 6 questions regarding this lawsuit. However, at the 7 question. Please rephrase it. 7 present time my attorneys have advised me that I 8 THE WITNESS: Yes. 8 cannot answer questions relevant to this lawsuit and 9 Q. (By Mr. Edwards) When you're released 9 must accept their advice, or risk losing my Sixth 10 from jail, do you intend to serve one year community 10 Amendment right to effective representstion. 11 control as a part of your sentence? 11 Therefore, I must assert my Federal 12 A. Yes. 12 Constitutional right under the Fifth, Sixth, and 13 Q. And under that provision, will you be able 13 Fourteenth Amendment to the constitution. 14 to continue working or will you be strictly confined 14 Q. What does the Florida Science Foundation 15 to your house? 15 do? 16 MR. GOLDBERGER: That calls for a legal 16 A. I intend to respond to all relevant 17 interpretation on the part of my client that 17 questions to this, regarding this lawsuit. However, 18 he's just not, he's just not competent to 18 at the present time my attorneys have counseled me 19 answer. So, if you know, fine, but I can't 19 that I cannot provide answers to any questions 20 imagine you would know. 20 relevant to this lawsuit i must accept their 23. THE WITNESS: I don't know. 21 advice or risk losing my Sixth Amendment right to 22 Q. (By Mr. Edwards) Who are the people that 22 effective representation. 23 will be living or working in your house once you are 23 Accordingly, lessen my Federal 24 released from jail? 24 Constitutional rights guaranteed by the Fifth, 25 A. I intend to respond to all relevant 25 Sixth, and Fourteenth Amendment to that 5 (Pages 17 to 20) PALM BEACH REPORTING SERVICE, INC. EFTA01103330  Page 21 Page 23 1 constitution. 1 to this lawsuit, and I must accept that advice or 2 Q. Have you procured minors for the purposes 2 risk losing their representation. 3 of prostitution? 3 Accordingly, I assert my Federal 4 A. I intend to respond to all relevant 4 Constitutional right as guaranteed by the Fifth, 5 questions to this, regarding this lawsuit However, 5 Sixth, and Fourteenth Amendment. 6 at the present time my attorneys have counseled me 6 Did you intentionally touch my client, 7 that I cannot provide answers to any questions 7 8 relevant to this lawsuit, and must accept their 8 A. I don't understand the question, sorry. 9 advice or risk losing my Sixth Amendment right to 9 Q. For the purpose of this lawsuit, we have 10 effective representation. 10 used the pseudonym to describe my client. Do you 13. Accordingly, I assert my Federal 11 know who Pm talking about when I refer toMil 12 Constitutional right as guaranteed by the Fifth, 12 A. I intend to respond to all relevant 13 Sixth and Fourteenth Amendment of the United States 13 questions to those, this lawsuit. However, at the 14 Constitution. 14 present time my attorneys have advised me that I 15 Q. Isn't it true that you did plead guilty to 15 cannot accept, answer any questions relevant to this 16 two felonies related to prostitution with minors? 16 lawsuit, and must accept their advice, or risk 17 MR. GOLDBERGER: Wait a minute, let me 17 losing my Sixth Amendment right to effective 18 just hold off a second. 18 rgrc istation. 19 (Thereupon, a discussion was had off 19 Q. Did you — 20 the record.) 20 A. Accordingly -- excuse me -- I assert my 21 MR. GOLDBERGER: You can answer the 21 Federal Constitutional right as guaranteed by the 22 question. 22 Fifth, Sixth, and Fourteenth Amendment to the United 23 THE WITNESS: Could you repeat the 23 States Constitution. 24 question? 24 MR. BURMAN: We further object on the 25 Q. (By Mr. Edwards) Isn't it true that you 25 ground tha name has not been disclosed Page 22 Page 24 1 pled guilty to two felony counts related to 1 and you've objected to that. 2 procurement of a minor for prostitution and/or 2 MR. EDWARDS: Thanks. 3 solicitation of a minor for prostitution? 3 (By Mr. Edwards) Did you touch my client 4 A. No. 4 NM, against her will? 5 Q. What counts did you plead guilty to? 5 A. We don't know who is. You haven't 6 A. Procuring a minor for prostitution and 6 told me who is. 7 soliciting prostitution. 7 Q. Okay. 8 Q. Have you had sex with minor girls? B MR. EDWARDS: Do you have an exhibit 9 A I intend to respond to all relevant slicker? 10 questions regarding this lawsuit. However, at the 10 (Thereupon, Plaintiffs Exhibit 11 present time my attorneys have advised me that I 11 Number 1 was marked for Identification by 12 cannot provide answers to any questions relevant to 12 Attorney Edwards.) 13 this lawsuit at the present time, and I must accept 13 Q. (By Mr. Edwards) Pm going to show you an 14 that advice or risk losing my Sixth Amencirnent right 14 exhibit that I have marked for identification 15 to effective representation. 15 purposes as Plaintiffs Exhibit 1. 16 Accordingly, I assert my Federal 16 Do you recognize the girl on the left in 17 Constitutional right under the Fifth, Sixth, and the 17 the photograph? 18 Fourteenth Amendment to the Constitution. 18 A. I intend to respond to all relevant 19 Q. Have you engaged in sex acts with girls 19 questions regarding — 20 who at the time you engaged in those sex acts were 20 THE WITNESS: Excuse me one second. 21 minors? 21 (Thereupon, a discussion was had off 22 A. I intend to respond to all relevant 22 the record.) 23 questions to this lawsuit. At the present time my 23 THE WITNESS: I intend to respond to all 24 attorneys have counseled me that I cannot respond, 24 relevant questions regarding this lawsuit. 25 I'm som. provide answers to any uestions relevant 25 Howeveriz2a theJre,sent time atto have 6 (Pages 21 to 24) PALM BEACH REPORTING SERVICE, INC. EFTA01103331  Page 25 Page 27 1 counseled me that I cannot provide answers to 1 A. I intend to respond to all relevant 2 any questions relevant to this lawsuit. I must 2 questions regarding this lawsuit. However, at the 3 accept their advice or risk losing my Sixth 3 present time my attorneys have counseled me that 1 4 Amendment right to effective representation. 4 cannot provide answers to any questions relevant to 5 Accordingly, I assert my Federal 5 this lawsuit, and 1 must accept this advice or risk 6 Constitutional right as given by the Fifth, 6 losing my Sixth Amendment right to effective 7 Sixth -- as provided by the Fifth, Sixth, and 7 representation. 8 Fourteenth Amendment to the constitution. 8 Accordingly, I assert my Federal 9 Q. (By Mr. Edwards Do you know somebody by 9 Constitutional right as guaranteed by the Fifth, 10 the name o 10 Sixth, and Fourteenth Amendment to the United States 11 A. I intend to respond to all relevant 11 Constitution. 12 questions regarding this lawsuit. However, at the 12 Q. Did you engage in sex or sex acts with a 13 present time my attorneys have counseled me that I 13 female named (phonetic)? 14 cannot provide answers to any questions relevant to 14 A. I intend to respon to all relevant 15 this lawsuit, and must accept their advice or risk 15 questions regarding this lawsuit. However, at the 16 losing my Sixth Amendment right to effective 16 present time my attorneys have counseled me that I 17 representation. 17 cannot provide answers to any questions relevant to 18 Accordingly, I assert my Federal 18 this lawsuit, and I must accept this advice or risk 19 Constitutional right as guaranteed by the Fifth, 19 losing my Sixth Amendment right to effective 20 Sixth and Fourteenth Amendment to the constitution. 20 representation. 21 Q. For the purposes of this deposition, when 21 Accordingly, I assert my Federal 22 I refer toM, I'm speaking of 22 Constitutional right under the Fifth, Sixth, and 23 Back to mthiitial questi . 23 Fourteenth Amendment of the constitution. 24 touch my client,.., against her will? 24 Q. Between 2001 and 2005 did you en 25 A. I intend to respond to all relevant 25 sex or sex acts with a minor female named Page 26 Page 28 1 questions regarding this lawsuit. However, at the 1 (phonetic)? 2 present time my attorneys have advised me that I 2 A. I intend to respond to all relevant 3 cannot provide answers to any questions relevant to 3 questions regarding this lawsuit. However, at the 4 this lawsuit, and must accept their advice or risk 4 present time my attorneys have counseled me that I 5 losing my Sixth Amendment right to effective 5 cannot provide answers to any questions relevant to 6 representation. 6 this lawsuit, and I must accept this advice or risk 7 Accordingly, I assert my Fifth, Sixth, and 7 losing my Sixth Amendment right to effective 8 Fourteenth — Fifth, Sixth and Fourteenth Amendment 8 representation. 9 of the constitution. 9 Accordingly, I assert my Federal 10 Q. Did engage in sex or sex acts with my 10 Constitutional rights as guaranteed by the Fifth, 11 clien against her will? 11 Sixth, and Fourteenth Amendment to the United States 12 A. I intend to respond to all relevant 12 Constitution. 13 questions regarding this lawsuit. However, at the 13 Q. Between 2001 and 2005 did vou engage in 14 present time my attorneys have advised me that I 14 sex or sex acts with a minor named Mphonetic)? 15 cannot provide any questions relevant to this 15 A. I intend to respond to all relevant 16 lawsuit, and must accept their advice or risk losing 16 questions regarding this lawsuit. However, at the 17 my Sixth Amendment right to effective 17 present time my attorneys have counseled me that I 18 representation. 18 cannot provide answers to any questions relevant to 19 Accordingly, I assert my Federal 19 this lawsuit, and I must accept this advice or risk 20 Constitutional right as guaranteed by the Fifth, 20 losing my Sixth Amendment right to effective 21 Sixth, and Fourteenth Amendment to that 21 representation. 22 constitution. 22 Accordingly, I assert my Federal 23 Q. Isn't it true that when you touthec. 23 Constitutional right as guaranteed by the Fifth, 24 against her will, you knew her to be a minor at the 24 Sixth, and Fourteenth Amendment to the United States 25 time? 25 Constitution. 7 (Pages 25 to 28) PALM BEACH REPORTING SERVICE, INC. EFTA01103332  Page 29 Page 31 1 Q. Between 2001 and 2005 did you will 1 Q. Between 2001 and 2005 did you eruriS 2 sex or sex acts with a minor female named 2 sex or sex acts with a minor female named 3 int (phonetic)? 3 (phonetic)? 4 A. I intend to respond to all relevant 4 A. I intend to respond to all relevant 5 questions regarding this lawsuit. However, at the 5 questions regarding this lawsuit. However, at this 6 present time my attorneys have counseled me that I 6 time my attorneys have counseled me that I cannot 7 cannot provide answers to any questions relevant to 7 provide answers to any questions relevant to this a this lawsuit, and must accept their advice or risk 8 lawsuit, and I must accept this advice or risk 9 losing my Sixth Amendment right to effective 9 losing my Sixth Amendment right to effective 10 representation. 10 representation. 11 Accordingly, i assert my Federal 11 Accordingly, I assert my Federal 12 Constitutional right as guaranteed by the Fifth, 12 Constitutional right as guaranteed by the Fifth, 13 Sixth, and Fourteenth Amendment to the United States 13 Sixth, and Fourteenth Amendment of the United States 14 Constitution. 14 Constitution. 15 MR. BURMAN: Mr. Edwards, can I inquire of 15 Q. Between 2001 and 2005 did you ensi 16 you one thing? Do you have a RICO count in 16 sex or sex acts with a minor female named 17 UN's case? 17 (phonetic)? 18 MR. EDWARDS: Yes. 18 A. I intend to respond to all relevant 19 MR. BURMAN: Okay. These other girls, are 19 questions regarding this lawsuit. However, at the 20 any of than your clients, as well? 20 present time my attorneys have counseled me that I 23. MR. EDWARDS: Some may be. 21 cannot provide answers to any questions relevant to 22 MR. BURMAN: Okay. Thank you. 2 2 this lawsuit, and must accept this advice or risk 23 MR. EDWARDS: Some are not. 23 losing my Sixth Amendment right to effective 24 MR. BURMAN: Okay. 24 representation. 25 Q. (By Mr. Edwards) Between 2001 and 2005 25 Accordingly, I assert my Federal Page 30 Page 32 1 did you engage in sex or sex acts with a minor 1 Constitutional rights as guaranteed by the Fifth, 2 female named IMIMEliphonetic)? 2 Sixth, and Fourteenth Amendment to the United States 3 A. I intend to respond to all relevant 3 Constitution. 4 questions regarding this lawsuit. However, at the 4 Q. Between 2001 and 2005 did you engage in 5 present time my attorneys have counseled me that I 5 sex or sex acts with a minor female named - 6 cannot provide answers to any questions relevant to 6 (phonetic)? 7 this lawsuit, and must accept this advice or risk 7 A. I intend to respond to all relevant B losing my Sixth Amendment right to effective a questions regarding this lawsuit. However, at the 9 representation. 9 present time my attorneys have counseled me that I 10 Accordingly, I assert my Federal 10 cannot provide answers to any questions relevant to 11 Constitutional rights as guaranteed by the Fifth, 11 this lawsuit I must accept this advice or risk 12 Sixth, and Fourteenth Amendment to the constitution. 12 losing my Sixth Amendment right to effective 13 Q. Between 2001 and 2005 did you engage in 13 representation. 14 sex or sex acts with a minor female named 14 Accordingly, I assert my Federal 15 (phonetic)? 15 Constitutional right under the Fifth, Sixth, and 16 A. I intend to respond to all relevant 16 Fourteenth Amendment to the constitution. 17 questions regarding this lawsuit. However, at the 17 Q. Between 2001 and 2005 did you e in 18 present time my attorneys have counseled me that I 18 sex or sex acts with a minor female named 19 cannot provide answers to any questions relevant to 19 (phonetic)? 20 this lawsuit, and I must accept this advice or risk 20 A. I intend to respond to all relevant 21 losing my Sixth Amendment right to effective 21 questions regarding this lawsuit However, at the 22 representation. 22 present time my attorneys have counseled me that I 23 Accordingly, I assert my Federal 23 cannot provide answers to any questions relevant to 24 Constitutional right as guaranteed by the Fifth, 24 this lawsuit, and must accept this advice or risk 25 Sixth ?. and Fourteenth Amendment to the constitution. 25 Iosing my Sixth Amendment right to effective 8 (Pages 29 to 32) PALM BEACH REPORTING SERVICE, INC. EFTA01103333  Page 33 Page 35 1 representation. 1 Fifth, Sixth, and Fourteenth Amendment to the 2 Accordingly, I assert my Federal 2 United States Constitution. 3 Constitutional right as guaranteed by the Fifth, 3 Q. (By Mr. Edwards) Between the year 2001 4 Sixth, and Fourteenth Amendment to the United States 4 and 2005 did you en ge in sex or sex acts with a 5 Constitution. 5 minor female named honetic)? 6 THE WITNESS: Can we take a break for, a 6 MR. BURMAN: O ect to form, vague and 7 bathroom break, is that okay? 7 indefinite. Last name, please. 8 THE VIDEOGRAPHER: We're off the record at 8 MR. EDWARDS: You can answer. 9 10:39. 9 THE WITNESS: I intend to respond to all 10 (Thereupon, a discussion was had off 10 relevant questions regarding this lawsuit. 11 the record.) 11 However, at the present time my attorneys have 12 THE VIDEOGRAPHER: We're back on the 12 counseled me that I cannot provide a