EFTA01087055.pdf

Page 172 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No. Plaintiff, -vs - JEFFREY EPSTEIN, Defendant. CONTINUED DEPOSITION OF JEFFREY EPSTEIN VOLUME III Thursday, October 8, 2009 1:46 - 3:48 p.m. 250 South Australian Avenue Suite 1400 West Palm Beach/ Florida 33401 Reported By: Jeana Ricciuti, RPR, FPR, CLR Notary Public, State of Florida Prose Court Reporting Agency, Inc. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Joann Moduli WMMMAIO-496c-aVW099977073134 EFTA01087055  1' ..:4c 17j Page 175 APPE3tRANCFS 2 On behaifotthe Mania 1 PROCEEDINGS SPENCER T. KUYIN, ESQUIRE 2 3 ADANILANOINO, ESQUIRE LEOPORD KUV1N, PA 3 THE VIDEOGRAPHER: We're back on the record at 4 2193 POA Manna Sufis 200 4 1:46. Palm Florida 33410 5 CONTINUED DIRECT EXAMINATION 6 6 BY MR. KUVIN: Salta tad ■ and Iwo Doe In Coo No. 1 7 Q. Do you personally know John Mack, former CEO CARA I. 110131FS, FSQUIRR 8 ROTHSTEIN, ROSEMEIDT CADLPIC 8 al Morgan Stanley? 401 Paµ Las Olaf Boenzad 9 Suite 1440 9 A. I'll have to answer that the same way I've 10 fat 33301 10 answered most of your questions here today, Mr. Kuvin, Phone air P near /one Doe la Case WIN and 11 is, I intend to respond to all relevant questions NyhIch wr 2 THERINII W. MERL, ESQUIRE 12 regarding this lawsuit; however, at the present time, my PODHURSTORSECR. PA •3 21 Weµ HaslerSerett 13 attorneys have counseled me I cannot provide answers to 14 any questions relevant to this lawsuit. I must accept Hone: S On behalfof the Defendant. 15 this advice or risk losing my Gth Amendment right to TACK CrOLDBEROUR, A I FOAL' :6 STORY ROM FS, PARAI FOAL 16 effective representation. Accordingly, I assert my Al'1E RBI IRV. 601.1aUEK(it 441; MS, P 250 Sac* Augrolien Avenue 17 federal constitutional rights as guaranteed by the 5th, Sway 1120 18 6th and 14th Amendment to the United States Wne Palialinkla 33401 /Sone: 19 Ccestitution. MICHAEL!. Ha ESQUIRE 20 MR. KUVIN: Okay. Same deposition as shown 70 BURMAN, aurrotc.T.U1TXRA COLEMAN, P 303 Beam houleverd 21 before, different clip. I'm going to play it for 21 Sake 400 Wert P 3 a 33101 22 counsel first. 22 hone. 23 MR. PIKE: 'thank you. 23 ALSO P 21 DAN DOM( RY, VIDLOORAP2IER 24 MR. KUVIN: Mr. V ideowapher, just let me know VISUAL EVIDISNCE,IXC. 25 25 when you're ready. Page 174 Page 176 1 --- THE VIDEOGRAPHER: Whenever you are. EXHIBITS 2 -•• 2 MR. KUVIN: Okay. 3 WITNESS: CONEDDIRECT 3 (Video played.) 4 JEFFREY EPSTEIN 4 VIDEO WITNESS: "What did I do to Jeffrey and BY MR. KUVIN 175 6 5 what did Jeffrey do to me? I went up there 6 multiple times; I can't count. And I would be on a 8 7 massage table, massaging his legs, he would turn EXHIBITS 9 8 over, his penis would be hanging out. He would put 10 NUMBER DESCRIPTION PAGI 9 a vagina -- or a vibrator to my vagina, lie would 11 PLAINTIFFS EX. 9 PHOTOGRAPH OF GHISLA1NE 182 MAXWELL 10 touch my vagina with his fingers. He would touch 12 PLAINTIFFS FM 10 PHOTOGRAPH OF 191 . 11 my breasts. He would try to kiss my mouth. He 13 PLAINTWFS 1 PHOTOORAPHOF 196 12 would bring my hands toward his penis." PIAINTWFS EX. 12 PHOTOGRAPH 13 (Video stopped.) 19 PLAINTIFFS EX 13 PHOTOGRAPH OF 199 14 MR. KUVIN: Okay. PIAINT1FFS RAPH OF 15 MIL PIKE: I'm just going to object to the use PtAtbnifFs E .Is PH RAPE! OF111.11 201 16 of the video as to relevance, predicate and 16 PLAINTIFFS EX 16 PHOTOGRAPH OF • ANDREW 17 foundation. 17 PLAINTIFFS EX. 17 LETTERTOB. KRISCHER FROM 203 18 BY MR- KUVIN: M. REITER 19 Q. All right. Let me get it back to the same 18 PLAINTIFFSEX. IS RECEIPT OF PURCHASES MADE 206 FROM JAIL 20 location, 19 PLAINTIFFS EX. 19 FAA REGISTRY 218 21 Sir, first of all, once again, just sol can 20 21 22 lay the foundation for this, do you recognize this girl? 22 23 A. I'm going to have to respond to that question 23 24 the same way I've responded to most of your other 24 25 25 questions hero today, which is, I intend to respond to 2 (Pages 173 to 176) PROSE COURT REPORTING AGENCY, INC. • Electronically signed by Jeana Ricciuti - - Electronically signed by Jeana Ricclutl bleclerlf0410498e4244•099977073134 EFTA01087056  Page 177 Page 179 1. all relevant cannot provide answers to any questions 1 the United States Constitution. 2 relevant to this lawsuit; however, at the present time, 2 BY MR. KUVIN: 3 my attorneys have counseled me I cannot provide answers 3 Q. Did you do what that young lad just described 4 to any questions relevant to the lawsuit. I must accept 4 now to hundreds of women, including M. ? this advice or risk losing my 6th Amendment right to 5 MR. PIKE: Form, argumentative, harassing, 6 effective representation. Accordingly, I assert my 6 lacks appropriate predicate, foundation, lacks 7 federal constitutional rights as guaranteed by the 5th, identity. 8 6th and 14th Amendment to the United States 8 THE WITNESS: Excuse me. Pm going to respond 9 Constitution. 9 to that the same way I've responded to most of your 10 Q. Did this girl brings to your home for a 10 other questions here today, which is, I intend to 11 naked massage? 11 respond to all relevant questions regarding this 12 A. Pm going to have to respond to that the same 12 lawsuit; however, at the present time, my attorneys 13 way I've responded to most of your other questions here 13 have counseled me that I cannot provide answers to 14 today, which Is, I Intend to respond to all relevant 14 any questions relevant to the lawsuit. I must 15 questions regarding this lawsuit; however, at the 15 accept their advice or risk losing my 6th Amendment 16 present time, my attorneys have counseled me I cannot 16 right to effective representation. Accordingly, I 17 provide answers to any questions that may be relevant to 17 must assert my federal constitutional rights as 18 the lawsuit. I must accept this advice or risk losing 18 guaranteed by the 5th, 6th and 14th Amendment to 19 my 6th Amendment right to effective representation. 19 the United States Constitution. 20 Accordingly, I assert my federal constitutional rights 20 BY MR. KUVIN: 21 as guaranteed by the 5th, 6th end 14th Amendment to the 21 Q. While. was standing naked in your home, 22 United States Constitution. 22 specifically in your bathroom, did you tell her that you 23 Q. I'd like to play this clip for you and then 23 could get her an interview as a model because of your 24 Pm going to ask you a question. 24 connections? 25 MR. PIKE: The same clip you just played? 25 A. I'm going respond to that the same way I've Page 178 Page 180 1 MR. KUVIN: Exactly. 1 responded to most of your questions today, Spencer. I 2 MR. PIKE: Same objection. 2 intend to respond to all relevant questions regarding 3 (Video played.) 3 this lawsuit; however, at the present time, my attorneys 4 VIDEO WITNESS: "What did I do to Jeffrey and 4 have counseled me I cannot provide answers to any 5 what did Jeffrey do to me? I went out there 5 questions that may be relevant to the lawsuit. I must 6 multiple times; I can't count. And I would be on a 6 accept this advice or risk losing my Gth Amendment right 7 massage table, massaging his legs. Ho would turn 7 to effective representation. Accordingly, I must assert 8 over, his penis would be hanging out. He would put 8 my federal constitutional right as guaranteed by the 9 a vagina -- or vibrator to my vagina. He would 9 5th, 6th and 14th Amendment to the United States 10 touch my vagina with his fingers. He would touch 10 Constitution. 11 my breasts. He would try to kiss my mouth. He 11 MR. PIKE: Same objection to that line of 12 would bring my hands toward his penis." 12 questioning. 13 (Video stopped.) 13 BY MR. KUVIN: 14 BY MR. KUVIN: 14 Q. As. was standing naked in your bathroom 15 Q. Did you do that with that girl? 15 before you when she was 15, did you ask her to turn 16 MR. PIKE: Fenn. 16 around so you could see her ass better? 17 THE WITNESS: I intend to respond to all 17 MR. PIKE: Form, argumentative, harassing. 18 relevant questions regarding this lawsuit; however, 18 lacks appropriate predicate, foundation. 19 at the present time, my attorneys have counseled me 19 THE WITNESS: ri1respond to that as I 20 I cannot provide answers to any questions that may 20 responded to your last question, which is, I intend 21 be relevant to this lawsuit. I must accept this 21 to respond to all relevant questions regarding this 22 advice or risk losing my 6th Amendment right to 22 lawsuit; however, at the present time, my attorneys 23 effective representation. Accordingly, I must 23 have counseled me I cannot provide answers to any 24 assert my federal constitutional rights as 24 questions that may be relevant to this lawsuit. I 25 guaranteed by the 5th, 6th and 14th Amendment to 25 must accept their advice or risk losing my 6th 3 (Pages 177 to 180) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana RIccluti bl8d9df0-4fcb-496c-a244-099977073134 EFTA01087057  Page 181 Page 183 1 Amendment right to effective representation; 1 Q. And her father is Robert Maxwell? 2 therefore, I must assert my federal constitutional 2 A. Was Robert Maxwell. 3 rights as guaranteed by the 5th, 6th and 14th 3 Q. Pm sorry, he's passed, correct? 4 Amendment to the United States Constitution. 4 A. Correct. 5 BY MR. KUVIN: 5 Q. She is a close friend of yours, is she not? 6 Q. WhenM. was 15 years old and standing naked 6 A. Fm going to respond to that question the same 7 in front of you in your bathroom, did you tell her that 7 way I've responded to most of your other questions here 8 you could help her become a model? 8 today, Mr. Kuvin, which is, I intend to respond to all 9 MR. PIKE: Same objections, including 9 relevant questions regarding to this lawsuit; however, 10 foundation. 10 at the present time, my attorneys have counseled me I 11 THE WITNESS: Is it different than the last 11 cannot provide answers to any questions that may be 12 question? 12 relevant to this lawsuit. I must expect — accept their 13 MR. KUVIN: Uh-huh. 13 advice or risk losing my 6th Amendment right to 14 MR. GOLDBEftGER: Just go ahead. 14 effective representation. Accordingly, I must assert my 15 THE WITNESS: Okay. I intend to respond to 15 federal constitutional rights as guaranteed by the 5th, 16 all relevant questions pertaining to this lawsuit; 16 6th and 14th Amendment to the United States 17 however, at the present time, my attorneys have 17 Constitution. 18 counseled me I cannot provide answers to any 18 Q. Ghisluine Maxwell has accompanied you to 19 questions that may be relevant to this lawsuit, so 19 numerous social events in the last few years; isn't that 20 I've answered most questions here today the same 20 true? 21 way. I must expect that - accept their advice or 21 MR. PIKE: Form. 22 risk losing my 6th Amendment right to effective 22 THE WITNESS: I'm going to respond to that 23 representation. Accordingly, I assert my federal 23 question the same way I've responded to most of 24 constitutional rights as guaranteed by the 5th, Gth 24 your questions here today, which is, I intend to 25 and 14th Amendment to the United Slates 25 respond to all relevant questions regarding your Page 1.87 Page 184 1 Constitution. 1 lawsuit; however, at the present time, my attorneys 2 BY MR. KUVIN: 2 have counseled me I cannot provide answers to any 3 Q. Who is GhIslaine Maxwell? 3 questions that may be relevant to that lawsuit. I 4 A. I intend to respond to all relevant questions 4 must accept their advice or risk losing my 6th 5 regarding this lawsuit; however, at the present time, my 5 Amendment right to effective representation. attorneys have counseled me that I cannot provide 6 Accordingly, I must assert my federal 7 answers to any questions relevant to this lawsuit. As I 7 constitutional right as guaranteed by the 5th, 6th 8 have done to most of your other questions here today, I 8 and 14th Amendment of the United States 9 must accept their advice or risk losing my 6th Amendment 9 Constitution. 10 right to effective representation. Accordingly, I 10 BY MR. KUVIN: 11 assert my federal constitutional rights as guaranteed by 11 Q. One ofyour houseboys that has been deposed in 12 the 5th, 6th and 14th Amendment to the United States 12 this case testified that you were a rather nice 13 Constitution. 13 gentleman that used to talk to the staff, and that when 14 MR. KUVIN: Let me show the camera what we'll 14 Ms. Maxwell came into the picture, that you stopped 15 mark as Exhibit 9 to this deposition. 15 talking to the staff and the staffhad to communicate 16 THE VIDEOGRAPI-IER: Okay. 16 through Ms. Maxwell. Do you agree or disagree with 17 (Plaintiffs Exhibit No.9 was marked for 17 that? 18 identification.) 18 MR. PIKE: Form, foundation, predicate, 19 BY MR. KUVIN: 19 argumentative, assumes facts not in evidence. 20 Q. Let me show you what we've marked as Exhibit 9 20 THE WITNESS: I'm going to answer that the 21 to your deposition. Do you recognize Ghislaine Maxwell 21 same way I've answered most ofyour questions here 22 in this photograph? 22 today, which is, I intend to respond to all 23 A. Yes. 23 relevant questions regarding this lawsuit; however, 24 Q. And who is she standing with? 24 at the present time, my attorneys have counseled me 25 A. Her father. 25 that I cannot provide answers to any questions that 4 (Pages 181 to 184} PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Rican' (601-280.428.9381) Electronically signed by Jeana Flicciutl (601.280-428.9381) bf8d9O0-4(cb-496c-a244-09997 7073134 EFTA01087058  Pogo 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 lawsuit; however, at the present time, my attorneys 3 to effective representation. Accordingly, I assert 3 have counseled me I cannot provide answers to any 4 my federal constitutional rights as guaranteed by 4 questions relevant to that lawsuit. I must accept the 5th, 6th and 14th Amendment of the United 5 their advice or risk losing my Gth Amendment right 6 States Constitution. 6 to effective representation. Therefore, I assert 7 BY MR. KUVIN: 1 my federal constitutional rights as guaranteed by 8 Q. Ho also testified that he felt you were a 0 the 5th, 6th and 14th Amendments to the United 9 rather nomad guy until Ms. Maxwell came into the Stales Constitution. 10 picture, and that she led you into this life of 10 BY MR. KUVIN: 11 perversion, sexual perversion. Do you agree with that? 11 Q. Do you know where Donald Trump's Maralago 12 MR. PIKE: Same objections. 12 estate is? 13 THE WITNESS: I'm going to respond to that the 13 A. Yes. 14 same way I've responded to most of your questions 14 Q. Have you been there? 15 hem today, Mr. Kuvin, which is, I intend to 15 A. Yes. 16 respond to all relevant questions regarding this 16 Q. Who with? 17 lawsuit; however, at the present time, my attorneys 17 A. Pm going to have to answer that question the 18 have counseled me 1cannot 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 19 today. I intend to respond to all relevant questions 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 molcannot 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 5th, 6th and 14th Amendment to the United States 25 Accordingly, I must assert my federal constitutional Page 186 Page 188 1 Constitution. 1 rights as guaranteed by the 5th, 6th and 14th Amendment 2 BY MR. KUVIN: 2 to the United States Constitution. 3 Q. Did Ms. Maxwell procure underaged girls for 3 Q. Have you seen the high school transcripts you to have sexual relationships with? 4 grades ofgirls that you have had sexual relationships 5 A. I'm going to answer that question the same way 5 with dating back to 2005? 6 I've answered most of your other questions today, 6 MR. PIKE: Form, relevance, improper 7 Mr. Kuvin, which is, I intend to respond to all relevant 7 hypothetical, lacks facts -- assumes facts not in 8 questions regarding this lawsuit; however, at the 8 evidence, lacks appropriate predicate, foundation. 9 present time, my attorneys have counseled me I cannot 9 THE WITNESS: I'm going to answer that 10 provide answers to any questions relevant to that 10 question the same as I've answered most of your 11 lawsuit. Excuse me. I must accept their advice or risk 11 other questions here today, Mr. Kuvin, which is, I 12 losing my 6th Amendment right to effective 12 intend to respond to all relevant questions 13 representation. Accordingly, I must assert my federal 13 regarding this lawsuit; however, at the present 14 constitutional rights as guaranteed -- guaranteed by the 14 time, my attorneys have counseled me that I cannot 15 5th, 6th and 14th Amendments to the United States 15 provide answers to any questions that may be 16 Constitution. 16 relevant to this lawsuit. I must accept their 17 Q. Ms. Maxwell procured a particular underaged 17 advice or risk losing my 6th Amendment right to 18 girl who worked at Donald Trump's Maralago, for you to 18 effective representation. Accordingly, I assert my 19 have a sexual relationship with; isn't that true? 19 federal constitutional rights as guaranteed by the 20 MR. PIKE: Form, argumentative, lacks 20 5th, 6th and 14th Amendment to the United States 21 appropriate predicate, foundation, assumes facts 21 Constitution. 22 not in evidence. 22 BY MR. KUVIN: 23 THE WITNESS: I'm going to respond to that the 23 Q. Do you deny that the high school transcripts 24 same way I've responded to most of your other 24 which were found in your trash on Palm Beach that showed 25 questions hero today, Mr. Kuvin, which is, I intend 25 the ages ofsome of the girls you were engaged with 5 (Pages 185 to 188) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana Ricciuti bted9dfOA(cb-496c-a244-099977073134 EFTA01087059  Page 189 Page 191 sexual ads with at your home dune from your house? 1 MR. GOLDBERGER: Break time? 2 MR. PUCE: Same objection in addition to 2 MR. KUVIN: No, not again. Please not. 3 argumentative and harassing. 3 lust let us know when you're good to go. 4 THE WITNESS: I intend to respond to all 4 THE VIDEOGRAPHER: Were back on the record at relevant questions regarding this lawsuit; however, 5 2:04. This will be the beginning of tape No. 3. 6 as I've done with most of your other questions 6 BY MR. KUVIN: 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 8 home on Palm Beach Island? 9 of those questions relevant to this lawsuit. I 9 A. I'm going to answer that question the same way 10 must accept their advice or risk losing my 6th 10 I've answered most of your questions here today, 11 Amendment right to effective representation. 11 Mt Kuvin. I intend to respond to all relevant 12 Accordingly, I must used my federal 12 questions regarding this lawsuit; however, at the 13 constitutional rights as guaranteed by the 5th, 6th 13 present time, my attorneys have counseled me I cannot 14 and 14th Amendments to the United States 14 provide answers to any questions relevant to the 15 Constitution. 15 lawsuit I must accept their advice or risk losing my 16 BY MR. KUVIN: 16 6th Amendment right to effective representation. 17 Q. Did you have numerous photos of nude young 17 Accordingly, I assert my federal constitutional rights 18 women, girls under the ago of 18, back in your home 18 as guaranteed by the 5th, 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 (Plaintiffs Exhibit No. 10 was marked for 21 tho same way I've responded to most of your questions 21 identification.) 22 here today, which is, I intend to respond to all 22 MR. KU VIN: ru show the camera a photograph 23 relevant questions regarding this lawsuit; however, at 23 here. Okay? 24 the present time, my attorneys have counseled 'no I 24 THE VIDEOGRAPHER: LIR it up. Yeah, there 25 cannot provide answers to any questions relevant to the 25 you go. Okay. Page 190 Page 192 - 1 same lawsuit. I must accept their advice or risk losing 1 MR. KUVIN: Okay? 2 my 6th Amendment right to effective representation. 2 BY MR. KUVIN: Accordingly, I must assert my federal constitutional 3 Q. Let me show you what we marked as Plaintiffs rights as guaranteed by the 5th, 6th and 14th Amendment. 4 Exhibit 10. Do you recognize this young lady? Q. Did you have photographs of girls under the 5 A. Yes. 6 ago of ten who were nude, either partially or fully 6 Q. Who is sho? 7 nude, in your home on Palm Beach in 2005 and 2006? 7 A. Her name is (phonetic). 8 MR. PIKE: Fenn. 8 Q. And who is she? 9 THE WITNESS: I'm going to respond to that 9 A. I just -- her name is 10 question the same way I've responded to most of' 10 Q. How do you recognize her? 11 your other questions, which is, I intend to respond 11 A. I don't understand the question. 12 to all relevant questions regarding this lawsuit; 12 Q. Well, is she a friend of yours? Did she work 13 however, at the present time, my attorneys have 13 for you? Flow do you recognize her? 14 counseled me I cannot provide answers to any 14 A. How do I recognize her? 15 questions relevant to this lawsuit. I must accept 15 Well, I'd like to respond to that question 16 this advice or risk losing my 6th Amendment right 16 but, however, my attorneys have told me that I can't 17 to effective representation. Accordingly, I assert 17 respond to any questions today that may -- excuse me. I 18 my federal constitutional rights as guaranteed by 18 intend to respond to all relevant questions regarding 19 the 5th, 6th and 14th Amendments of the United 19 this lawsuit; however, at the present time, my attorneys 20 States Constitution. 20 have counseled mo that I cannot provide answers to any 21 THE VIDEOGRAPHER: Mr. Kuvin, fin sorry I have 21 questions relevant to this lawsuit. I must accept their 22 to change. 22 advice or risk losing my 6th Amendment right to 23 MR. KUVIN: Go ahead 23 effective representation. Accordingly, I assert my 24 THE VIDEOGRAPHER: well go off the record at 24 federal constitutional rights as guaranteed by the 5th, 25 2:03. This will be the end of tape No.2. 25 Gth and 14th Amendment to the United States 6 (Pages 189 to 192) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Rletiutl Electronically signed by Jeana Riccardi bf8d9tlf041cb-496c-a244-09997 7073134 EFTA01087060  Page 191 Page 195 1 Constitution. 1 THE WITNESS: Pm going to respond to that 2 Q. Did you have sex with IM? 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, I 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 7 have counseled me I 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. 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 5th, 11 Accordingly, I assert my federal constitutional 12 6th and 14th Amendment to the United States 12 rights as guaranteed by the 5th, 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: 15 And let mo make it a compound question so I 15 Q. Did you fly with Prince Andrew on your plane, 16 don't have to repeat it over and over. When did you 16 or planes, with any underaged girls, girls under the age 17 first meet Prince Andrew, under what conditions did you 17 of18? 18 meet him, and who was present at that list 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 I intend to respond to all relevant questions regarding 21 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 met cannot provide answers to any 23 provide answers to any questions relevant to the 24 questions relevant to that lawsuit. I must accept their 24 lawsuit. I must accept their advice or risk losing my 25 advice or risk losing my 6th Amendment right to 25 6th Amendment right to effective representation. Page 194 Page 196 1 effective representation. Accordingly, I must assert my 1 Accordingly, I must assert my federal constitutional 2 federal constitutional rights as guaranteed by the 5th, 2 rights as guaranteed by the 5th, 6th and 14th Amendments 3 6th and 14th Amendment to the United States 3 to the United States Constitution. 4 Constitution. 4 Q. Do you 'mow 5 Mk PIKE: In addition, relevance. 5 MR. KUVIN: For the court reporter, it's 6 BY MR. KUVIN: 6 7 Q. Do you pay Ms. Maxwell a salary? 7 THE WITNESS: I intend to respond to all 8 MR. PIKE: Form. 8 relevant questions regarding this lawsuit; however, 9 BY MR. KUVIN: 9 at the present thne, my attorneys have counseled me 10 Q. Ohislaine Maxwell, so we're clear. Do you pay 10 I cannot provide answers to any questions relevant 11 her a salary? 11 to the lawsuit. I must accept this advice or risk 12 A. I'd like -- excuse me. I'm going to answer 12 losing my 61h Amendment right to effective 13 that question the same way I've answered most of your 13 representation. Accordingly, I assert my federal 14 questions here today, which is, I intend to answer all 14 constitutional rights as guaranteed by the 5th, 6th 15 questions relevant to this lawsuit; however, at the 15 and 14th Amendments to the United States 16 present time, my attorneys have counseled me I cannot 16 Constitution. 17 provide answers to any questions relevant to this 17 MR. KUVIN: Let me show the camera what we'll 18 lawsuit. I must accept their advice or risk losing my 18 mark as Exhibit II. 19 6th Amendment right to effective representation. 19 (Plaintiffs Exhibit No. 11 was marked for 20 Accordingly, I assert my federal constitutional rights 20 identification.) 21 as guaranteed by the 5th, 6th and 14th Amendment to the 21 THE VIDEOORAPHER: Okay. 22 United States Constitution. 22 MR. KUVIN: Okay? 23 Q. Did you provide any underaged girls for sex to 23 BY MR. KUVIN: 24 Prince Andrew? 24 Q. In Exhibit 11, sir, you're standing with a 25 MR. PIKE: FO1111 25 woman. Who Is that woman in that photograph? 7 (Pages 193 to 196) (.1) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Juana Ricciuti Electronically signed by Arena RIcciull 618d9dt04tcb-496c-a240-098977073134 EFTA01087061  Page 19 / Page 199 1 A. (phonetic). A. I intend to respond to all relevant questions 2 Q. Where were you? 2 regarding this lawsuit; however, as I've done to most of 3 A. I intend 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' attorneys have counseled me Icannot provide answers to 5 those questions that may be relevant to the lawsuit. I 6 any questions that may be relevant to this lawsuit. I 6 must accept this advice or risk losing my Gth Amendment must accept this advice or risk losing my 6th Amendment 7 right to effective representation. Accordingly, 8 right to effective representation. Accordingly, I must 8 asset my federal constitutional rights as guaranteed by 9 assert my federal constitutional rights as guaranteed by 9 the 5th, 6th and 14th Amendments of the United States 10 the 5th, 6th and 14th Amendments to the United States 10 Constitution. 11 Constitution. 11 BY MR. KUVIN: 12 MR. KUVIN: And just so the court reporter 12 Q. Fin going to show you what we'll mark as 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. 14 BY MR. KUVIN: 14 (Plaintiffs Exhibit No. 13 was marked for 15 Q. Who is ,excirse 15 identification.) 16 me? 16 BY MR. KUVIN: 17 A. I'm 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, 19 is, I intend to respond to all relevant questions 19 A. I 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 21 attorneys have counseled me that I cannot provide 22 any questions relevant to the lawsuit. I 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 lawsuit. I must accept their advice or risk losing my 24 effective representation. Excuse me. Accordingly, I 24 6th Amendment right to effective representation. 25 must assert my federal constitutional rights as 25 Accordingly, I assert my federal constitutional rights Page 198 Page 200 1 guarantee -- guaranteed by the 5th, 6th and 14th 1 as guaranteed by the 5th, 6th and 14th Amendment to the 2 Amendment tote United States Constitution. 2 United States Constitution. 3 (Plaintiffs Exhibit No. 12 was marked for 3 Q. Let me show you what we'll mark as Exhibit 14. ,1 identification.) 4 (Plaintiffs Exhibit No. 14 was marked for 5 MR. KUVIN: Let me show to the camera what 5 identification.) 6 we've marked as Exhibit 12. 6 BY MR. KUVIN: 7 BY MR. KUVIN: 7 Q. Sir, does Exhibit 14 show --,a 8 Q. Let me show you what I've marked as Exhibit 8 girl that you have had a sexual relationship with since 9 12. Do you recognize any of the girls in that 9 before she was 18 years old? 10 photograph? 10 MR. PIKE: Fenn, argumentative, harassing, 11 A. I'm going to answer that question the same way 11 assumes facts not in evidence, lacks appropriate 12 I've answered most of your other questions here today, 12 . predicate and foundation. 13 Mr. Kuvin, which is, I intend to respond to all relevant 13 THE WITNESS: I intend to respond to all 14 questions regarding this lawsuit; however, at the 14 relevant questions regarding this lawsuit; however, 15 present time, my attorneys have counseled me that 1 15 at the present time, my attorneys have counseled me 16 cannot provide answers to any questions that may be 16 I cannot provide answers to any questions relevant 17 relevant to the lawsuit. I must accept their advice or 17 to this lawsuit. I must accept their advice or 18 risk losing my 6th Amendment right to effective 18 risk losing my 6th Amendment right to effective 19 representation. Accordingly, I assert my federal 19 representation. Accordingly, I assert my federal 20 constitutional rights as guaranteed by the 5th, 6th and 20 • constitutional rights as guaranteed by the 5th, 6th 21 14th Amendment to the United States Constitution. 21 and 14th Amendment to the United States 22 Q. Sir, isn't it true that in what we've marked 22 Constitution. 23 as Plaintiff's Exhibit 12 the blond standing on the 2