EFTA01076650.pdf

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380,08-80381,08-80994, 08-80993, 08-80811,08-80893,09-80469, 09-80591,09-80656,09-80802,09-81092. VIDEOTAPED DEPOSITION OF JEFFREY EDWARD EPSTEIN VOLUME (Pages 1 - 189) Monday, March 8, 2010 301 Clematis Street Suite 3000 West Palm Beach, Florida 33401 10:05 III. - 6:17 III. Reported By: Vicki L. Lima, Court Reporter Notary Public, State of Florida Universal Legal Re orting Phone - Job #92076-A UNIVERSAL COURT REPORTING MI) EFTA01076650  Page 2 Page 4 1 1 PROCEEDINGS 2 APPEARANCES.. 2 --- 4 On Wolf of die PhootIffs. heti Doe 2 through 8: ADAM MORONS= ESQUIRE 3 Videotaped deposition taken before Vicki L. Lima, Court 5 JESSICA D. ARBOUR. ESQUIRE a 4 Reporter, and Notary Public in and for the State of MERMELSTEN & HOROWITZ IM 6 18205 Dian Boulewd 5 Florida at Large, in the above cause. Seam 2218 6 7 Mimi, Flalda 33160 8 On behalf of de Plamtifts, Jane Doc 7 THE VIDEOGRAPHER: We are now on the record. BRAD EDWARDS. ESQUIRE 9 FANNER. JAFFE, MISSING. 8 This is the videotaped deposition of Jeffrey EDWARDS. P15105 & LEHRMAN.. 9 Epstein, taken in the matter of Jane Doe Number 2 10 425 Noah Andrews Avenue Suite 2 10 vs. Jeffrey Epstein, Case Number 08-CV-80119. 11 Fort Lauderdale. Florida 33301 11 We are here at 301 Clematis Street, Suite 3000, 12 On lx&Hofelio Phis011. Jane Deo 103: KATHERINE W. EZELL, ESQUIRE 12 West Palm Beach, Florida 33401. It is Monday, 13 PODHURST ORSECK City &sliced Bak Baling 13 Match 8th, 2010. The time is 10:05. The court 14 25 Wo41 Them &ma 14 reporter is Vicki Lima. The videographer is Alex Suite $00 IS Mimi. Florida 33130 15 Ayala. 16 On behalf of the Defendam and Wieneem 16 Will counsel please introduce themselves? MICHAEL I PIKE. ESQUIRE 17 BURMAN. CROTON, LUTHER & COLEMAN 17 MR. HOROWITZ: Sure. My name is Adam Horowitz 303 Dawn Boiderard 18 SIliN 400 18 from Mermeistein & Horowitz, counsel for Plaintiffs West Palm Beath Florida 33401 19 Jane Doe 2 through 8. And Just for record 19 JACK & GOLDBERGER, ESQUIRE 20 purpOses, the deposition is taken -- being taken in 20 ATTERBURY. GOLDBERGER & WEISS. 21 those cases as well. One Cleadoke Cute 21 250 Australian Ammue Smith 22 MR. PIKE: Please introduce yourself. Suite 1400 22 West Palm Beath. Florida 33401 23 MS. ARBOUR: Jessica Arbour, Mermelstein & 23 24 Horowitz. 24 ALSO PRESENT: 25 Ake Ayala. VideograpSer 25 MR. EDWARDS: Brad Edwards. 1represent Jane Page 3 Page 5 1 1 Doe. It's also been cross-noticed in that case as 2 VOLUME I 2 well, but I think it's styled in the Jane Doe 2 (Pages 1 -189) 3 case. 4 MS. EZELL: Katherine Ezell. I represent Jane 4 5 Doe 103. EXAMINATION INDEX 5 6 MR. PIKE: Michael Pike on behalf of Jeffrey O 7 Epstein. JEFFREY EDWARD EPSTEIN 8 THE VIDEOGRAPHER: Will the court reporter 7 DIRECT BY MR. HOROWITZ 5 9 please swear in the witness? 8 10 THE REPORTER: Raise your right hand, please. 9 11 10 12 THEREUPON: 11 12 13 JEFFREY EDWARD EPSTEIN 13 14 having been first duly sworn or affirmed, was examined 14 15 and testified as follows: 15 16 THE WITNESS: Yes, mat 16 NO EXHIBITS MARKED 17 DIRECT EXAMINATION 17 • 18 BY MR. HOROWITZ: 18 19 Q Please tell us your full name? 19 20 A Jeffrey Edward Epstein. 20 21 Q And is your date of birth January 20, 1953? 2/ 22 22 A Yes. 23 23 Q Okay. And I guess that makes you 57 years old 24 24 at the present time? 25 25 A Correct. 2 (Pages 2 to 5) UNIVERSAL COURT REPORTING ( ) EFTA01076651  Page 6 Page 8 1 Q And you are, sir, a registered sex offender in 1 THE WITNESS: I don't remember. 2 the State ofFlorida? 2 BY MR. HOROWITZ: 3 A Correct. 3 Q Is it the address that you reside in? 4 Q Okay. How long have you been a sex offender in 4 MR. PIKE: Form. 5 the State of Florida? 5 THE WITNESS: On advice of counsel, I am going 6 MR. PIKE: Foam 6 to assert my Fifth Amendment Right. 7 THE WITNESS: I registered on — in, I believe, 7 BY MR. HOROWITZ: 8 18, July of '08. 8 Q Okay. Did you review any documents in 9 BY MR. HOROWITZ: preparation for today's deposition? 10 Q Okay. Are you married? 10 A No. 11 A No. 11 Q Okay. Did you meet with your attorneys 12 Q Have you ever been married? 12 concerning this deposition at any time before it 13 A No. 13 started? 14 Q Are you engaged? 14 A At any time I've over the past couple of 15 A No. 15 months, but not specifically with this deposition. 16 Q Have you ever been engaged? 16 Q Okay. I'm asking about — concerning this 17 MR. PIKE: Form. 17 deposition? 18 THE WITNESS: On advice of counsel, I'm going 18 A No. 19 to assert my Fifth Amendment Right as to that. 19 Q Okay. In June of 2008, you pled guilty to two 20 BY MR. HOROWITZ: 20 felonies; is that correct? 21 Q Are you suffering from any physical illness or 21 A Correct. 22 injury today that would prevent you from sitting for a 22 Q Okay. One of those felonies involved procuring 23 full day of deposition? 23 a person under the age of 18 for prostitution, correct? 24 A No. 24 A Yes. 25 Q Your hearing is okay? 25 Q You pled guilty to that charge, correct? Page 7 Page 9 1 A %/hats that? Yes. 1 A That's correct. 2 Q Okay. No back or neck pain at the present 2 Q Okay. And you were represented by legal 3 time? 3 counsel at the time of your plea? 4 A No. 4 A That's correct 5 Q Do you have a girlfriend at the present time? 5 Q Okay. In that particular charge the person 6 MR. PIKE: Form. 6 under the age of 18 who you allegedly procured for 7 THE WITNESS: On advice of counsel, fm going 7 prostitution, was a female, correct? 8 to assert my Fifth Amendment Right 8 A On advice of cowisel, I am going to have to 9 BY MR HOROWITZ: 9 assert my Fifth Amendment, Sixth Amendment and 10 Q Do you have a driver's license in any state? 10 Fourteenth Amendment Right. 11 A Yes. 11 Q In June of 2008, you also pled guilty to a 12 Q In what state? 12 felony charge of solicitation of a prostitute, correct? 13 A The United States Virgin Islands. 13 A No, solicitation of prostitution, correct. 14 Q Okay. How long have you had a driver's license 14 Q Okay. And to make sure we're on the same page, 15 in the Virgin Islands? 15 in June of 2008, you pled guilty to a felony of 16 A I believe twelve years. 16 solicitation of prostitution, correct? 17 Q Okay. Have you ever had a driver's license in 17 A Yes. 18 the State of Florida? 18 Q Okay. And you were represented by counsel at 19 A Yes, sir. 19 the time of that guilty plea as well? 20 Q Okay. And during what years did you have a 20 A Yes, sir. 21 driver's license in the State of Florida? 21 Q Okay. And you were sentenced in Palm Beach 22 A I don't remember. 22 County for both of those felonies, correct? 23 Q Okay. What address appears on your driver's 23 A That's correct 24 license in the Virgin Islands? 24 Q Okay. You actually served your time in Palm 25 MR. PIKE: Form. 25 Beach County? 3 (Pages 6 to 9) UNIVERSAL COURT REPORTING EFTA01076652  Page 10 Page 12 1 A That's correct. 1 Q Do you tell any departments of the State of 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 I believe 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 7 MR. PIKE: Font 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: Fonn, same objection. 10 Q Okay. Your sentence included jail time; is 10 THE WITNESS: I don't recall. 11 that right? 11 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 If you know, are there locations that you 15 A I believe so. 15 cannot live in because of your status as a sex 16 Q 1.1h-huh. And was it at — as part of that 16 offender? 17 sentence, that you were designated as a sex offender? 17 A I believe I — 18 MR. PIKE: Fonn. 18 MR. PIKE: Form. 19 THE WITNESS: Asa result of that sentence. 19 THE WITNESS: — I believe I can livc 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. 24 2008 time frame? 24 Q If you know, are there places you cannot work 25 A I believe so. 25 because of your status as a sex offender? Page 11 Page 1 Q Okay. Do you register your home address as 1 MR. PIKE: Form. 2 part of your sex offender designation? 2 THE WITNESS: I don't believe so. 3 MR. PIKE: Form. 3 BY MR. HOROWITZ: 4 THE WITNESS: I believe so. 4 Q If you know, are there people that you cannot 5 BY MR- HOROWITZ: 5 come into contact with because of your status as a sex 6 Q Okay. What address do you provide as your home 6 offender? 7 address as part of your sex offender registration? 7 8 3 MR. PIKE: Form. THE VMNESS: On advice of counsel, I will have 8 9 MR. PIKE:. Form. THE WITNESS: I do not know. BY MR. HOROWITZ: I 10 to assert my Fifth Amendment, Sixth Amendment and 10 Q Okay. Since being sentenced — strike that 11 Fourteenth Amendment Right. 11 As part of your sentence, are you forbidden 12 BY MR. HOROWITZ: 12 from having sexual contact with minors? 13 Q Okay. Do you tell the State of Florida where 13 MR. PIKE: Form, argumentative. 14 you live as part of your sex offender registration? 14 THE WITNESS: I'm sorry? 15 A Do I tell the State of Florida? 15 BY MR. HOROWITZ: 16 Q My department within the State of Florida 16 Q As part of your sentence, are you forbidden 17 where you live as part of your sex offender 17 front having sexual contact with minors? 18 registration? 18 MR. PIKE: Same objection. 19 A I believe so. 19 THE WITNESS: I don't know I believe that 20 Q What address do you tell them that you live in? 20 sexual contact with minors is against the law, so I 21 MR. PIKE: Form, same objection. 21 would assume so. 22 THE WITNESS: And I am going to assert my Fifth 22 BY MR. HOROWITZ: 23 Amendment, Sixth Amendment and Fourteenth Amendment 23 Q Okay. As part of registering as a sex 24 Rights. 24 offender, do you have to provide the State of Florida 25 BY MR. HOROWITZ: 25 with your business address? A.,ra..,...b.)•05e• -•••••••••• 4 (Pages 10 to 13) UNIVERSAL COURT REPORTING ) EFTA01076653  Page 14 Page 16 1 A Yes, I believe so. 1 THE WITNESS: That's correct. 2 Q Okay. And what business address do you provide 2 BY MR. HOROWITZ: 3 the State ofFlorida -- 3 Q Are you still under community control? 4 MR. PIKE: Form. 4 A Yes, sir. 5 BY MR. HOROWITZ: 5 Q Okay. When does that end? 6 Q — as part of your registry with the -- as a 6 A JWy 21st — 7 sex offender? 7 Q 2010? 8 THE WITNESS: On advice of counsel, I am going 8 A July 10 — yes, 2010. 9 to assert my Fifth Amendment, Fourteen Amendment 9 Q July 21st, 2010, your conummity control 10 and Sixth Amendment Right. 10 ceases? 11 BY MR. HOROWITZ: 11 A That's correct. 12 13 Q How many vehicles do you tell the State of Florida that you own as part ofyour registration as a 12 13 Q Okay. Do you have a community control officer? 1 14 sex offender? 14 A Yes, sir. 15 A I don't know. I -- I don't know. I don't 15 Q What is his or her name? 16 recall. 16 A Miss Elkins, Officer Elkins. 17 Q With respect to those matters that you -- you 17 Q How often do you see Miss Elkins in person? 18 do know that you provide to the State of Florida -- 18 A At least twice a week. 19 A Yes. 19 Q Okay. How much time do you spend with Miss I 20 Q — who provides that information, meaning you 20 Elkins when you see her? 21 or someone on your behalf? 21 A It varies — 22 MR. PIKE: Form. 22 Q And — 23 THE WITNESS: 1do. 23 A — up to an hour each time. 24 BY MR. HOROWITZ: 24 Q Okay. And the typical occasion which you come 25 Q Okay. And where do you send in that 25 face-to-face with Miss Elkins, what -- what — what do Page 15 Page 17 1 information? 1 you do? 2 A Its done at the Stockade In Palm Beach County. 2 MR. PIKE: Form. 3 Q Okay. So since being released, you travel to 3 THE WITNESS: I talk to Miss Elkins. 4 the Stockade to provide that information? 4 BY MR. HOROWITZ: 5 A On advice ofcounsel, I am going to assert my 5 Q What do you talk about? 6 Fifth Amendment Fourteen Amendment and Sixth Amendment 6 A lf there's — my schedule. 1— I prepare a 7 Right. 7 schedule for Miss Elkins. THE VIDEOGRAPHER: Sorry to interrupt. 1 need 8 Q Okay. A written schedule? 9 to go off the record fora second because of 9 A Yes, sir. 10 sound. 10 Q Okay. And you do that every week, or twice a 11 MR. HOROWITZ: All right. 11 week? 12 THE VIDEOORAPHER: Time off the record 10:14. 12 A Every week. 13 (Thereupon, a short break was taken.) 13 Q Okay. When was the last time you provided Miss 14 THE VIDEOGRAPHER: lime on the record 10:15. 14 Elkins with a copy of your schedule? 15 BY MR. HOROWITZ: 15 A Last Monday. 16 Q Sir, as part of your sentence in 2008, you also 16 Q Okay. What is Miss Elkins' first name? 17 had to provide a DNA sample to the court; is that 17 A I don't know. 18 correct? 18 Q Okay. And so do you drive or get driven to the 19 MR. PIKE: Form. 19 Stockade to see Miss Elkins? 20 THE WITNESS: That's correct. 20 A Yes. 21 BY MR. HOROWITZ: 21 Q Okay. And has that been true since you were 22 Q And per the =twice in the summer of 2008, you 22 released from jail? 23 were to be under community control after your time in 23 MR. PIKE: Form. 24 Jail: is that correct? 24 THE WITNESS: No. 25 MR. PIKE: Form. 25 BY MR. HOROWITZ: 5 (Pages 14 to 17) UNIVERSAL COURT REPORTING EFTA01076654  Page 18 Page 20 1 Q Okay. For how long have you been seeing Miss 1 BY MR. HOROWITZ: 2 Elkins one to two times per week? 2 Q Okay. Is anyone within earshot such that they 3 A Miss Elkins was -- had replaced my former 3 can hear your conversation? 4 probation officer, which is Carmine Sloan (phonetic), 4 A I don't know. 5 about a month ago. 5 Q Okay. Do you travel to go see Miss Elkins or 6 Q Okay. Did you have a — another probation 6 Miss Sloan with anybody else? 7 officer before Carmine Sloan? 7 MR. PIKE: Form. 8 A No, sir. 8 THE WITNESS: On advice of counsel. I am going 9 Q Okay. And when Carmine Sloan was your 9 to assert my Fifth Amendment, Sixth Amendment and 10 probation officer, were you also seeing -- were you 10 Fourteenth Amendment Right. 11 seeing him one to two times a week? 11 BY MR. HOROWITZ: 12 A It's her, but yes. 12 Q Other than the probation officer, whether it be 13 Q Okay. And were you providing Miss Sloan with a 13 Miss Sloan or Miss Elkins, is there anyone else from 14 -- a written schedule? 14 their office that is present when you meet with them? 15 A Yes. 15 MR. GOLDBERGER: From their office, did you 16 Q Okay. Other than providing Miss Sloan with a 16 say? 17 written schedule, what else -- what else do you talk 17 MR. HOROWITZ: Yes. 18 about? 18 THE WITNESS: Maybe a couple of times, maybe 19 A Just my daily activities. 19 another probation officer. 20 Q Well, what do you tell her about your daily 20 BY MR. HOROWITZ: 21 activities? 21 Q Okay. And who is that? 22 A Where I will be. Just my schedule. Where I 22 A I don't know. 23 will be. 23 Q Is there anything else, other than your written 24 Q Okay. Is that the subject matter each time 24 schedule, that you provide to Miss Elkins or Miss Sloan 25 that you go see ha? 25 during the course of your community control? Page 19 Page 21 1 A Basically, yes. 1 A Not that I can recalL 2 Q And that takes up to an hour? 2 Q Okay. What sort of things would we find on 3 A Yes. 3 that schedule? 4 Q Okay. Anything else that you talk about other 4 MR. PIKE: Form. 5 than your schedule with either Miss Sloan or your — 5 THE WITNESS: Where I intend to be. 0 your current -- Miss Elkins? 6 BY MR. HOROWITZ: 7 A Not that I can recall. 7 Q Okay. So it would have a physical location -- 8 Q And it takes an hour approximately to talk 8 MR. PIKE: Fonn. 9 about your schedule? BY MR. HOROWITZ: 10 MR. PIKE: Asked and answered. 10 Q — such as "office," or would it say an 11 THE WITNESS: Up to an hour. 11 address? 12 BY MR. HOROWITZ: 12 A It just might say "office." It might say an 13 Q Up to an hour? 13 address. 14 A Yes. 14 Q Okay. What addresses do you provide Miss Sloan 15 Q Up to an hour? 15 or Miss Elkins as your address when you are providing 16 A Yes. 16 your written schedule? • 17 Q Okay. Is anyone else with you when you meet -- 17 MR. PIKE: Form. 18 when you met with Miss Elkins or Miss Sloan? 18 MR. GOLDBERGER: Form. 19 MR. PIKE: Form. 19 THE WITNESS: On advice of counsel, I am going 20 THE WITNESS: Which time? 20 to have to assert my Fifth Amendment, Sixth 21 BY MR. HOROWITZ: 21 Amendment and Fourteenth Amendment Right. 22 Q Typically. It — do you go alone? 22 BY MR. HOROWITZ: 23 A It's — ifs — it's in the office. 23 Q Other than telling Miss Elkins and Miss Sloan 24 MR. PIKE: Same objection. 24 that you're at the office, where else do you tell them 25 THE WITNESS: It's at the probation office. 25 that you will be? ."..2.421.47:4 ••••• ,,, •UL 6 (Pages 18 to 21) UNIVERSAL COURT REPORTING EFTA01076655  Page 22 Page 24 1 MR. PIKE: Same objection. 1 THE WITNESS: I'm sorry, I don't understand the 2 THE WITNESS: I am going to Inge to assert my 2 question. 3 Fifth Amendment, Fourteenth Amendment and Sixth 3 BY MR. HOROWITZ: 4 Amendment Right. 4 Q Sure. At the time of your sentence -- we 5 BY MR. HOROWITZ: 5 talked about that a few times already, that was in 6 Q Does the schedule — written schedule that you 6 June/July of 2008? 7 provide to Miss Elkins and Miss Sloan simply say a 7 A Uh-huh. 8 location, or do you also describe your activities? 8 or.? My question is: Isn't it true you were ordered 9 A Just the location. 9 at that time to have no contact, direct or indirect. 10 Q Okay. Other than "office," what other 10 with various girls? 11 locations do you from time to time provide to Miss 11 MR. PIKE: Objection. 12 Elkins or Miss Sloan? 12 THE WITNESS: I don't recall. 13 MR. PIKE: Form. 13 BY MR. HOROWITZ*. 14 THE WITNESS: I'm going -- I am going to, on 14 Q Do you know — 15 advice of counsel, assert my Fifth Amendment, Sixth 15 A I don't recall. 16 Amendment and Fourteenth Amendment Right. 16 Q Do you know whether the Judge announced that in 17 BY MR. HOROWITZ: 17 Court to you on the date ofyour sentence? 18 Q Okay. Does your community control officer - 18 A I don't recall. 19 is that — is that the correct term, "community control 19 Q Do you recall a document saying that you were 20 officer? 20 directed to have no contact, direct or indirect, with 21 MR. PIKE: Form. 21 various girls as part of your criminal sentence? 22 THE WITNESS: I believe so. 22 MR. PIKE: Form. 23 BY MR. HOROWITZ: 23 THE WITNESS: I believe that was much later. 24 Q Okay. Does your community control officer ever 24 BY MR. HOROWITZ: 25 make unannounced visits to your home? 25 Q Okay. At some point — that happened later? Page 23 Page 25 1 A Yes. 1 A That's correct. 2 Q Well, where do they travel to to see you? 2 Q Okay. What do you understand to be the terms 3 MR. PIKE: Form. 3 of this no-contact order that you believe you were 4 THE WITNESS: On advice of counsel, lam going 4 provided at a later date? 5 to assert my Fifth Amendment, Sixth Amendment and 5 MR. PIKE: Form. 6. Fourteenth Amendment Right. 6 MR. GOLDBERGER: If you know. 7 BY MR. HOROWITZ: 7 THE WITNESS: Just to have no affirmative 8 Q Okay. Other than your own office, are there 8 contact — 9 any other locations where you have met Miss Sloan or MR. GOLDBERGER: Be specific. 10 Miss Elkins to discuss your schedule? 10 THE WITNESS: -- with — with -- with three 11 A My probation office. 11 specific girls. 12 Q Other than the probation office, are there any 12 MR. HOROWITZ: Let me just nip this in the 13 other locations where you've met them? 13 bud. A witness — 14 A On advice of counsel, I am going to assert my 14 MR. GOLDBERGER: 1— lam just trying to help 15 Sixth Amendment, Fourteenth Amendment and Fifth 15 you along here. 16 Amendment Right. 16 MR. HOROWITZ: Okay. 17 BY MR. HOROWITZ: 17 MR. GOLDBERGER: No problem. You can you 18 Q Okay. Do you anticipate that you'll be seeing 18 can ask the questions, and it will take an hour 19 Miss Elkins one to two times per week until your 19 later. I'm trying to get you an answer that you 20 community control expires? 20 want 21 A Yes. 21 MR. HOROWITZ: I appreciate that. III — and 22 Q You were also ordered at the time of your 22 if I'm having a hard time, that's my problem. Not 23 sentence to have no contact, direct or indirect, with 23 yours. 24 various girls; is that correct? 24 MR. CiOLDBERGERI Okay. 25 MR. PIKE: Form, confusing. 25 MR. HOROWITZ: But what I was addressing was •Siaislat•P••••.661( 7 (Pages 22 to 25) UNIVERSAL COURT REPORTING ( ) EFTA01076656  Page 26 Page 28 not your assistance, but the fact that you're 1 MR. GOLDBERGER: And youll — you're free to 2 speaking up, and you're familiar with the local 2 seek whatever relief you want. 3 rules. 3 MR. PIKE: And — and let me — let me put 4 MR. PIKE: Yeah, let me — 4 something on the record, since you chose to do so. 5 MR. HOROWITZ: No, no, no. 5 One, this is — this proceeding has a quasi- 6 MR. PIKE: I know. I understand. 6 criminal component to it, and your questions today, 7 MR. HOROWITZ: No, no -- 7 Mr. Horowitz, are interjected in a manner in an 8 MR. PIKE: Listen, we have got a — we've got a 8 attempt to cause Mr. Epstein to waive his Fifth 9 long day ahead of us, so let's move along. 9 Amendment Right, along with his Sixth and his 10 MR. HOROWITZ: This is -- this is in the 10 Fourteenth which are incorporated therein. So the 11 interest of efficiency. 11 fact that Mr. Goldberger is here making sure that 12 MR. PIKE: Okay. Let's go. 12 his client and my mutual client maintain and 13 MR. HOROWITZ: Per witness, one attorney, okay? 13 preserve those privileges that are afforded under 14 I don't care who It is, but it can only be one of 14 the United States Constitution, he will continue to 15 you. 15 do that today, okay? 16 MR. GOLDBERGER: Okay. So here's the deal: I 16 Now, we're here to answer your questions. 17 represent Mr. Epstein on his criminal cases If I 17 We're here to move forward with the depo. We'd 18 feel it is important for me to interject on issues 18 like to do that. If you'd like to adjourn to take 19 relevant to his criminal case, I'll do so. 19 this up with the Court today, we could do that as 20 Mr. Pike has taken the — the lead role in 20 well, but it was — ifs your choice. 21 representing Mr. Epstein civilly. 21 MR. HOROWITZ: Okay. 22 MR. HOROWITZ: Well — 22 MR. PIKE: Okay? 23 MR. GOLDBERGER: if there are issues relevant 23 BY MR. HOROWITZ: 24 to the criminal case, I'm going interject. 24 Q One girl that you were ordered to have no 25 As far as your concern about what just occurred 25 contact with is Jane Doe 2, correct? Page 27 Page 29 now, I'm just hying to help you along. 1 MR. PIKE: Form. 2 MR. HOROWITZ: I appreciate that. 2 THE WITNESS: I don't know. 3 MR. GOLDBERGER: That's the only reason I did 3 BY MR. HOROWITZ: 4 it. 4 Q Another girl that you were ordered to have no 5 MR. HOROWITZ: MI right. I'm going to put 5 contact with is Jane Doe 4, correct? 6 this on the record again. The local rules provide 6 MR. PIKE: Form. 7 that in a deposition in a civil case one witness, 7 THE WITNESS: No, I don't — you — you've 8 one attorney who can object, period. It doesn't 8 asked me a question regarding a criminal case? 9 say if there is also a criminal case, two attorneys 9 MR. HOROWITZ: Correct. 10 can speak. So if Mr. Epstein wanted to hire an 10 THE WITNESS: So regarding my criminal case, I 11 attorney familiar with his criminal case for his 11 believe the answers to the both of those questions 12 civil case, he could have done so. If he didn't, 12 are no. 13 that was at his own peril. So I'm just going to 13 BY MR. HOROWITZ: 14 ask you to refrain, and I'm just going to put you 14 Q Okay. I have some more questions about your 15 on notice that if you -- if you interject an 15 criminal case. 16 objection — 16 A Okay. 17 MR. GOLDBERGER: Uh-hub. 17 Q Another girl that you were ordered to have no 18 MR. HOROWITZ: — I'll seek the relief from the 18 contact with as a result of your -- following your 19 Court, and that's -- that's it, but -- 19 sentence is Jane Doe 6; is that correct? 20 MR. GOLDBERGER: That's fine. And Pm going to 20 MR. PIKE: Form. 21 continue to do so, and if you want to adjourn at 21 THE WITNESS: I don't believe so. 22 this point, we can do that. But ifI think ifs an 22 BY MR. HOROWITZ: 23 issue relevant to my representation ofhim on a 23 Q Okay. And another girl that you were ordered 24 pending criminal case, I'm going to do so, okay? 24 to have no contact with as a result of your criminal 25 MR. HOROWITZ: Okay. 25 case is Jane Doe 7, correct? 8 (Pages 26 to 29) UNIVERSAL COURT REPORTING ( ) EFTA01076657  Page 30 Page 32 1 A 1don't believe so. 1 BY MR. HOROWITZ: 2 Q Okay. Another girl that you were ordered to 2 Q Okay. Have you made any affirmative attempt to 3 have no contact with is Jane Doe 5? 3 have no contact with Jane Doe 5, Jane Doe 8, Jane Doe 6, 4 MR. PIKE: Form. 4 Jane Doe 2, Jane Doe 3, Jane Doe 4 or Jane Doe 7? 5 THE WITNESS: As far as my criminal case, I MR. PIKE: Form, lack of predicate and 6 don't believe so. 6 foundation. 7 BY MR. HOROWITZ: 7 THE WITNESS: And on the advice of counsel, I 8 Q Okay. Another girl you were ordered to have no 8 am going to assert my Fifth Amendment, Sixth 9 contact with is Jane Doe 8, correct? 9 Amendment and Fourteenth Amendment Right 10 MR. PIKE: Form. 10 BY MR. HOROWITZ: 11 THE WITNESS: I'm sorry, who? 11 Q Have you at any time known the names of the 12 MR. HOROWITZ: Jane Doe 8. 12 girls that you were directed to have no contact with -- 13 THE WITNESS: I don't believe so. 13 MR. PIKE: Same objection. 14 BY MR. HOROWITZ: 14 BY MR. HOROWITZ: 15 Q Okay. Another girl you were ordered to have no 15 Q — in the criminal case? 16 contact with is Jane Doe 3, correct? 16 A Known the names? 17 MR. PIKE: Same objection. 17 Q Known, known. 18 THE WITNESS: I don't believe so. 18 A I was told that in fact some of your — the 19 BY MR. HOROWITZ: 19 cases that were filed against me by your firm, a firm 20 Q Okay. Are you smut of the names of any girls 20 whose partner was disbarred for his conduct, and in fact 21 who you were ordered to have no contact with as part of 21 Mr. Edwards sitting there with his firm who is called by 22 your criminal case? 22 the U.S. Attorney to be the largest fraud in South 23 MR. PIKE: Font 23 Florida's history — I believe these girls have always 24 THE WITNESS: On the advice ofcounsel, I am 24 been -- and I believe the ladies and gentlemen of the 25 going to assert my Fifth Amendment, Sixth Amendment 25 jury will eventually be aware that these girls have Page 31 Page 33 1 and Fourteenth Amendment Right. 1 filed the claim many years after they alleged and even 2 MR. HOROWITZ: Okay. I mentioned seven girls' 2 associated with firms whose partners have been disbarred 3 names. I'll just put them on the record so you 3 and is part one of his partners is currently in jail, 4 know what seven girls I'm talking about. 4 yes. 5 THE WITNESS: Okay. 5 Q Okay. Are you suggesting that a partner of 6 MR. HOROWITZ: Jane Doe 5, Jane Doe 8, Jane Doe 6 mine was disbarred? Is that your testimony? 7 6, Jane Doe 2, Jane Doe 3, Jane Doe 7. 7 MR. PIKE: Form. 8 BY MR. HOROWITZ: THE WITNESS: Yes, that's — I believe that's 9 Q Is it your testimony today that you were not 9 my understanding. 10 ordered as a result of a criminal case to have no 10 BY MR. HOROWITZ: 11 contact with them? 11 Q Okay. Are you suggesting that my clients 12 MR. PIKE: Form. 12 fabricated their claims against you after coming into 13 THE WITNESS: That's my best recollection. 13 contact with an attorney who you believe was 14 BY MR_ HOROWITZ: 14 disciplined? 15 Q Okay. And, therefore, since you have no 15 MR. PIKE: Fonn. 16 recollection of being ordered, you've made no 16 THE WITNESS: You know, I'd really like to 17 affirmative attempt to have no contact with them; is 17 answer that question, and hopefully some day I 18 that correct? 18 will. I think the answer is pretty obvious to you 19 MR. PIKE: Form, asked and answered. I am 19 and the other people in this room, but, however, 20 going to instruct him not to answer that question. 20 today, Mr. Horowitz, I am going to, on the advice 21 If you want to rephrase it, go ahead. 21 of counsel, have to assert my Fifth Amendment, 22 MR. HOROWITZ: Are you going to accept — 22 Sixth Amendment and Fourteenth Amendment Right, 23 accept his advice? 23 though I would like to — and I'm sure you and the 24 MR. PIKE: Yeah. 24 ladies and gentlemen understand, I'd like to answer 25 THE WITNESS: Yes. 25 that question.