IN THE CIRCUIT COURT OF THE

1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA vs. JEFFREY EPSTEIN, CASE NO. 50-2008 -CA-028051 XXXX MB AB Plaintiff, Defendant. / VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN TAKEN ON BEHALF OF THE PLAINTIFF DATE: February 17, 2010 U.S. Legal Support EFTA01076251 1 February 17, 2010 2 INDEX 3 WITNESS DIRECTCROSS REDIRECT RECROSS 4 JEFFREY EPSTEIN 5 BY MR. EDWARDS 4 6 EXHIBITS 7 FOR IDENTIFICA PAGE 8 I Jane Doe numb usJeffrey Epstein complain 35 9 2 Document, Nonprosecution Agreement 135 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CER1 iFILO QUESTIONS Page Line 61 22 123 20 146 l4 148 153 5 159 13 162 3 3 1 The videotaped deposition of JEFFREY 2 EPSTEIN in the above-entitled and numbered cause, 3 was taken before me, TERRI BECKER, a Registered 4 Professional Reporter and Notary Public for the 5 State of Florida at Liege, at 444 West Railroad 6 Avenue, in the City of West Palm Beach, Palm 7 Beach County, in the State of Florida, beginning 8 at the hour of 5 eiclock a.m, pursuant to 9 the Notice in said cause for the taking of said 10 deposition which is annexed to the court file 11 herein, on behalf of the PLAINTIFF in the 12 above-entitled action pending in the above-named 13 court 14 The appearances at said time and place 15 were as follows: 16 FARMER, JAFFE, WEISSING, EDWARDS, F1STOS & LEHRMAN, P.L. 17 Attorneys for Plaintiff 425 North Andrews Avenue, Suite 2 18 Tel: 19 Fort 33301 BY: BRAD . WARDS STEVEN R. JAFFE, ESQ. BURMAN, CRITTON, LUTTIER & COLEMAN 21 Attorneys for Defendant 303 Banyan Boulevard, Suite 400 22 Wes orida 33401 Tel: 23 BY: MICHAEL PIKE, ESQ. 24 ALSO PRESENT: JOE ROVNER, Videographer 25 (U.S Legal Support) 20 1 THEREUPON, 2 JEFFREY EPSTEIN 3 being by Toni Becker first duly sworn to tell 4 the whole truth, as hereinafter certified. testified as follows: 6 DIRECT EXAMINATION 7 BY MR. EDWARDS: 8 Q Can you give us your name. 9 A Jeffrey Epstein. 10 Q Mr. Epstein, you made a comment when you 11 came in the room that you were appreciative of me 12 being respectful to your housekeeper yesterday 13 and I intend for that to be the same with you 14 today. 15 1 want to start by asking you, at this 16 point we've gone through a lot of discovery in 17 this ease. There aren't may disputed facts as 18 to what actually happened at your house. 19 Generally I think you would agree that you 20 derived a way for young females to come to your 21 house and engage In varying degrees of sexual 22 activity, some of the girls as young as 12, some 23 of them as old as seventeen or so, most in 24 between, but as of yet you haven't provided an 25 explanation. 1 1 want to provide you an opportunity to 2 tell the jury at this time why you did ft. 3 MR. PIKE: I'm going to object 4 Confusing, compound and irrelevant, as worded. 6 A You know, I would like to answer that 7 question, frankly. However, at this time, my 8 attorneys have told me that I can't and 1 must 9 invoke my Fifth, Sixth and Fourteenth Amendment 10 rights or I risk losing their counsel. 11 Accordingly, I therefore assert those rights. 12 Sorry. 13 MR. PIKE: In addition to that I'll move 14 to strike counsel's statement as a 15 narrative, as well. 16 MR. EDWARDS: I understand. I wanted to provide him an opportunity, if today was 18 going to be the day. 19 MR. PIKE: Same thing, move to strike. 20 Q Mr. Epstein, how long have you been 21 sexually attractive to underage minor females? 22 MR. PIKE: Objection, harassing, 23 argumentative. 24 A Are you kidding? 25 Q No, l mean, I don't feel Eke I'm 17 2 (Pages 2 to U.S. Legal Support EFTA01076252 8 1 divulging any secrets here, right? 2 MR. PIKE: Move to strike. 3 Q That's the question that's pending. 4 A I would like to answer that question as 5 well, as all your other questions today, however, 6 I have to follow my attorneys' advice. They have 7 told me I must invoke my Fifth, Sixth and 8 Fourteenth Amendment right to not answer those 9 questions today, or any questions relevant to 10 this lawsuit, so accordingly, I'm going to assert 11 those rights and under the constitution 12 guaranteed by the Fifth and Sixth, and Fourteenth 13 amendment. 14 Q Would you consider yourself addicted to 15 sex with minor females? 16 MR. PIKE: Same objections. 17 A You know, Mr. Edwards, again, I want to 18 be very respectful. As the current U.S. Attorney 19 has described your law firm as a criminal 20 enterprise and part of one of the largest frauds 21 in Florida's history, it has been reported that 22 your firm has fabricated multiple cases against 23 me in order to fleece unsuspecting investors out 24 of millions and millions of dollars, so 25 unfortunately at this time, although I would Ida 7 1 to answer that question, on advice of counsel I 2 will have to refrain and assert my Fifth, Sixth 3 and Fourteenth Amendment right. 4 Q Can you then provide an explanation for 5 what relevance that soliloquy of yours has to, 6 whether or not you engaged in sex acts with- 7 When she was a minor? 8 MR PIKE: Objection, no, he cannot 9 Argumentative. Compound, harassing. 10 MR. EDWARDS: Mr. Pike, with all due 11 respect, it was not my idea for him to give 12 this speech about a former ARA law firm I 13 was asking to elaborate on that. 14 MR. PIKE: Counsel, I'm working with 15 your follow-up question. 16 MR. EDWARDS: I understand. 17 MR. PIKE: I'm objecting, object to the 18 form and stating the reasons on the record 19 why the form is required to be objected to, 20 based upon your question. 21 MR. EDWARDS: Will he elaborate on the 22 relevance of that soliloquy to his touching 23 -when she was 13, 14 and 15 years old in 24 a sexual manna? 25 MR. PIKE: I'm going to object again, 1 argumentative, compound, harassing and 2 irrelevant. 3 Q You can answer. 4 A I would like to answer, however, I'm 5 going to have to assert my Fifth Amendment, Sixth 6 Amendment, Fourteenth Amendment right as advised 7 by my counsel, otherwise I risk losing their 8 advice. 9 Q Mr. Epstein, have you ever been 10 diagnosed with a sex addiction to minors by a 11 psychologist or other medical professional? 12 A I intend to respond to all of your 13 questions at some relevant time; however, today 14 at the present time, my attorneys have counseled 15 me that I cannot provide answers to any questions 16 relevant to this lawsuit and I must accept their 17 advice or risk losing my Sixth Amendment rights 18 to effective representation. 19 Accordingly, I assert my Fifth, 20 Federal — Fifth and Sixth and Fourteenth 21 Amendment rights, to the United States 22 Constitution. 23 MR. PIKE: In addition to that, Mr. 24 Edwards, as the Court has ruled on several 25 matters, Mr. Epstein's medical history is 9 1 not relevant at this time nor has he placed 2 same at issue in this case. 3 MR. EDWARDS: Understood. 4 Q Mr. Epstein, were you sexually abused as 5 a minor? 6 A Again? 7 Q Were you sexually abused, as a minor? 8 A You know, again, I would like to respond 9 to all -- if any questions seem to be relevant. 10 I would like to respond to any relevant question 11 at this time; however, my attorneys have 12 counseled me that I cannot provide answers to the 13 questions relevant to this lawsuit today. I must 14 accept their advice or risk losing my Sixth 15 Amendment right to effective representation. 16 Accordingly then, I assert my Fifth, Sixth and 17 Fourteenth Amendment right to the United States 18 Constitution. 19 Q Isn't it true that you have engaged in 20 some sexual interaction with hundreds of underage 21 minor females In die last ten years of your 22 life? Is that true? 23 MR. PIKE: Objection, relevance. 24 A Mr. Edwards, the current U.S. Attorney 25 has described your law firm as a criminal 3 (Pages 6 to 9) U.S. Legal Support EFTA01076253 10 12 1 enterprise and pan of the largest fraud in 2 Florida's history. It has been reported that 3 your firm fabricated multiple cases, many, many 4 multiple cases against me in order to fleece 5 unsuspecting investors out of millions and 6 millions of dollars. Unfortunately, at this time 7 in response to your question, my attorneys have 8 advised me that I must assert my Sixth Amendment, 9 Fifth Amendment, Fourteenth Amendment right. 10 Though, I believe, you know, that I would really 11 like to answer your questions today, but at this 12 moment i must assert those rights or risk having 13 my attorneys resign. 14 Q You're Invoking your Fifth Amendment 15 rights to each of these questions because you 16 know your answers will incriminate you and you 17 feel it will result in you being prosecuted for 18 your crimes; Isn't that right? 19 MR. PIKE: Objection, argumentative, 20 harassing. Calls fora legal conclusion. 21 Q You can answer. 22 A No, in fact, the Supreme Court recently 23 said the Fifth Amendment right is there to 24 protect the innocent, so, that's the way I would 25 like to answer that. 11 1 Q Are you actually telling the Jury that 2 you didn't commit the crimes that have been 3 alleged against you by the various females that 4 were under age when you engaged in sex with 5 them? Are you telling the jury that right now? 6 MR. PIKE: Objection, argumentative, 7 harassing. 8 A I would like to respond to that 9 question, as you know, however, at the present 10 time my attorneys have counseled me that I cannot 11 provide answers to any questions relevant to this 12 lawsuit and i must accept their advice or risk 13 losing my Sixth Amendment right to effective 14 representation. Accordingly, I assert my Fifth, 15 Sixth and Fourteenth Amendment right under the 16 United States Constitution. 17 Q Mr. Epstein, you understand that this is 19 aeo that will be playe ie Jury in 19 trial against you 1m wants answers. 20 The jury is going to want answers, so I know that 21 you're telling us that you're going to respond at 22 some time In the future; but the time is now. 23 Would you like this opportunity to explain why 24 you engaged In sexual activity with.. 25 beginning when she was 13 years old and you were 1 50 years old? 2 MR. PIKE: I'm going to object once 3 again. We are getting way too argumentative 4 with the questioning. The questioning is 5 compound It is speculative and it is also 6 harassing. Whether or not this deposition 7 video, thereof is played in front of a jury 8 is a question of fact, and it will be 9 determined by a judge pursuant to a motion 10 in limine, various portions thereof may or 11 may not be played, so hiving placed those 12 objections on the record I'm going to 13 insttuct Mr. Epstein not to answer that 14 question. 15 MR. EDWARDS: Mr. Pftce, I don't know if 16 you watehegai nia hours of harassing 17 questions tri=that she sometimes 18 invoked her Fifth Amendment rights, I 19 understand the adverse advice that would be 20 given and she was made to answer these 21 questions and these exact same questions 22 were asked of her, in fact, I'm using the 23 phraseology from Mr. Luttier. I'm not 24 trying to harass him. 25 Q I'm simply asking him to explain to the 13 1 jury. If you're saying it didn't happen, if 2 you're saying it did happen, explain to the jury 3 why you did it. That's all I want to hear. I'm 4 being respectful about this. 5 MR. PIKE: In an effort to keep a clean 6 record be respectful to the to the court 7 reporter rather than having a diatribe back 8 and forth between you and myself, I'll move 9 to strike your last statement as 10 irrelevant. Let's move on. 11 Q Is it true, Mr. Epstein, you were born 12 January 20,1953? 13 A Yes. 14 Q Where? 15 A New York. 16 Q Where in New York? 17 A Brooklyn. 18 Q Did you go to high school there? 19 A Yes, sir. 20 Q Where? 21 A Lafayette High School. 22 Q After high school did you attend 23 college? 24 A Yes. 25 Q Where was that? 4 (Pages 10 to 13) U.S. Legal Support EFTA01076254 14 16 1 A New York. 2 Q What college did you attend? 3 A Cooper Union. 4 Q Sorry, i didn't hear. 5 A Cooper Union. 6 Q Did you get a degree from Cooper Union? 7 A No, sir. 8 Q How many years were you in college? 9 A I believe, two. 10 Q What did you study? 11 A Physics. 12 Q Why did you leave college early? 13 A I intend to respond to all relevant 14 questions regarding this lawsuit, however, at the 15 present time my attorneys have counseled me that 16 I cannot provide answers to questions that may be 17 relevant to this lawsuit, so accordingly I assert 18 my constitutional rights as guaranteed by the 19 Fifth, Sixth and Fourteenth Amendment. 20 Q Are you invoking your Fifth Amendment 21 rights as to why you left college, Is it safe 22 then to presume that that answer you believe 23 would incriminate you in some way? 24 MR. PIKE: I'm going to move to strike, 25 speculative, argumentative, harassing. 15 Calls for a legal conclusion, and 1 know 2 exactly what you're trying to do here, Mr. 3 Edwards, is lace the record with questions 4 that would ultimately give you an adverse 5 inference at any potential trial of this 6 matter, so having put that on the record, 7 I'm going to instruct him not to answer that 8 question, based upon his Fifth, Sixth and 9 Fourteenth Amendment rights to the United 10 States Constitution. 13. MR. EDWARDS: With all due respect you 12 cannot invoke his Fifth Amendment rights, 13 your attorneys instructed me in that fact -- 14 MR. PIKE: lie can. 15 MR. EDWARDS: 11M. Had to do it 16 herself, so, I would like to hear it from 17 Mr. Epstein. 18 Q Can we assume you're Invoking your Fifth 19 Amendment rights as to why you left college 20 early, that that answer you feel would 21 incriminate you? 22 MR. PIKE: Once again, move to strike 23 for the same reasons. 24 You can answer. 25 A I've already answered the question. 1 I'll restate the answer. I would like to 2 respond, intend to respond, and would like to 3 respond to all questions today. However, counsel 4 has advised me I must take the Fifth, Sixth and 5 Fourteenth Amendment right under the U.S. 6 Constitution. 7 Q After college where were you employed? 8 A You Imow, I would like to respond to all 9 your questions today, however, on advice of 10 counsel, I intend to take the Fifth, Sixth and 11 Fourteenth Amendment rights provided by the 12 United States Constitution or risk losing my 13 counsel's representation. 14 Q Isn't it true that you were a teacher at 15 the Dalton School in New York after college? 16 A Again, I would like to respond to all 17 your questions; however, my attorneys have 18 counseled me that i cannot provide answers to any 19 questions today regarding to this lawsuit so I 20 must accept their advice or risk losing my Sixth 21 Amendment right to effective representation. 22 Accordingly, I assert my Constitutional rights as 23 guaranteed by the Fifth, Sixth and Fourteenth 24 Amendment of the constitution. 25 Q Mr. Eistein, didrit have sex with any 17 1 underage students while teaching at the Dalton 2 School? 3 A Could you repeat that? 4 Q Yes. Did you have sex with any underage 5 students while teaching at the Dalton School in 6 New York? 7 A Mr. Edwards, your firm has been 8 described by the U.S. Attorney as one of the 9 largest — as a criminal enterprise, perpetrating 10 one of the largest frauds in Florida's history. 11 It has been reported that your firm fabricated 12 multiple cases against me and others in order to 13 fleece unsuspecting investors out of millions and 14 millions of dollars. 15 Unfortunately at this time in response 16 to your question, my attorneys have advised me I 17 must assert my Fifth Amendment, Sixth Amendment 18 and Fourteenth Amendment rights, though I believe 19 you know I would like -- really like to answer 20 your questions but at this time I must assert 21 those rights or have my attorneys resign. 22 MR. EDWARDS: Mr. Pike, I think you know 23 he has a couple of options here. He can 24 answer questions or he can invoke his Fifth 25 Amendment rights. This nonresponsive 5 (Pages 14 to 17) U.S. Legal Support EFTA01076255 18 20 1 verbiage regarding the RBA law firm is not 2 one of the options, it's inappropriate in 3 the deposition and I would ask you to 4 instruct your client not to obstruct this 5 process any further. I am not going to 6 terminate the deposition. I want it to 7 finish, but obviously this is going to be 8 the subject matter of some motion in the 9 °Duns and you know the judges will not 10 appreciate this. I would like to just move 11 this process along by eliminating that 12 portion of his answer. I understand what he 13 is saying. 'get it, but that's not 14 something responsive to any of the questions 15 and I think you know it is inappropriate. 16 MR. PIKE: I think the deponent is 17 answering the questions. If you believe the 18 responses are inappropriate and feel you can 19 take it up with the Court with the motion 20 you are speaking of, as you've done then you 21 can, as you've done several times before. 22 Q After leaving the Dalton School. is it 23 true that you began working as a money manager at 24 Bear Stearns? 25 A I intend to respond to all your 19 1 questions regarding this lawsuit at some relevant 2 time, however, at the present time my attorneys 3 have counseled me that I cannot provide answers 4 to any questions relevant to this lawsuit. Since 5 the U.S. Attorney has described your law firm as 6 a criminal enterprise, Mr. Edward; and a pan of 7 the largest fraud in Florida's history, I am 8 going to assert my Sixth Amendment, Fifth 9 Amendment and Fourteenth Amendment rights to the 10 U.S. Constitution. 11 Q Isn't It true that while you were 12 working at Bear Stearns you were already engaging 13 in sex with underage minors? 14 A Again, I believe you know the answers to 15 those questions, but -- 16 Q Yes. 17 A May I finish? 18 Q I do. 19 MR. PIKE: Move to strike. Let the 20 witness -- 21 Q Sure - 22 MR. PIKE: Let the witness answer your 23 question. 24 MR. EDWARDS: I would love for him to 25 finish the questions. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. PIKE Mr. Edwards, as you know there are serious Fifth, Sixth and Fourteenth Amendment constitutional rights at issue here, and the witness is attempting to answer your questions to the best of his ability, despite how laced they are with adverse inference presumptions. MR. EDWARDS: I don't want the adverse inferences. I want the answers, that's it. I don't want the adverse inferences. MR. PIKE: Having said that, please allow the witness to answer to answer the question. A Can you please repeat the question? Q Isn't it true while working at Bear Stearns you were already engaging in sex with underage minor females? A As your firm has been described by the U.S. Attorney, as a criminal enterprise, using some of the cases fabricated against me, personally, I would like to answer that question today; however, upon advice of counsel I must assert my Fifth, Sixth and Fourteenth Amendment rights under the U.S. Constitution or, in fact, risk losing their representation. 21 1 Q At some point in time while at Bear 2 Stearns you met and managed the money for a 3 fellow named Leslie Wexler, correct? 4 A Again, I would like to answer all 5 questions relevant to this lawsuit, but today I 6 must assert my Fifth Amendment, Sixth Amendment 7 and Fourteenth Amendment right to the U.S. 8 Constitution. 9 Q In fact, I read in another deposition of 10 yours that you do not consider yourself to be 11 homosexual, correct? 12 A (No response.) 13 Q You've answered that question before, 14 correct? 15 A Correct. 16 Q Do you consider yourself to be 17 bisexual? 18 A No. 19 Q In any event, you did develop a sexual 20 relationship with Leslie Wexler at some point In 21 time; Is that true? 22 A No. 23 Q Did you have a business relationship 24 with Mr. Wexler? 25 A I intend to respond to all relevant 6 (Pages 18 to 21) U.S. Legal Support EFTA01076256 22 24 1 questions. I would like to answer most of your 2 questions, Mr. Edwards, today, however, 3 especially since your firm has been described by 4 the United States Attorney in South Florida as a 5 criminal enterprise purported to -- purported to 6 have put — pulled off the largest fraud in 7 Florida's history, I would like to answer it, 8 however, my attorneys here today counseled me 1 9 must assert my Fifth, Sixth and Fourteenth 10 Amendment right under the U.S. Constitution, 11 therefore Pm going to do that. 12 Q Are you saying because Rothstein, 13 Rosenfeld, Adler was determined to be a criminal 14 enterprise or somebody was running a criminal 15 enterprise out of that law firm, that is the 16 reason why you are not going to answer these 17 questions today? You linked that together in 18 that answer. I just want to make sure I'm 19 understanding that right? 20 A I'm going to take the Fifth I intend 21 to respond to all relevant questions today. I 22 would like to respond; unfortunately my attorneys 23 have counseled me I can't, l must assert my 24 Fifth, Sixth and Fourteenth Amendment rights 25 under the U.S. Constitution. 1 Therefore l'Ilassert my Constitutional 2 rights under the Fifth, Sixth and Fourteenth 3 Amendment. 4 THE WITNESS: Excuse me, could we take a 5 break? 6 MR. EDWARDS: Already? 7 THE WITNESS: Restroom. 8 THE VIDEOGRAPHER: Going off the video 9 record 11:38 a.m. 10 THE WITNESS: Thank you. 11 (Pause in the proceedings.) 12 THE VIDEOGRAPHER: We're back on the 13 video record at 11:48 a.m. 14 Q How did you meet Chislalne Maxwell? 15 A I intend to respond to all relevant 16 questions to this lawsuit; however, at the 17 present time my attorneys have counseled me that 18 I cannot provide answers to any questions 19 relevant to this lawsuit, and must accept this 20 advice or risk losing effective -- my right to 21 effective representation. Accordingly, 22 therefore, I assert my Fifth, Sixth and 23 Fourteenth Amendment rights to the U.S. 24 Constitution. 25 Q You would agree, would you not, that 23 Q Because other law firms have asked very 2 similar questions and you haven't responded to 3 any of theirs either. I just want to understand 4 what the relationship between Rothstein, 5 Rosenfeld, Adler is to you invoking your Fifth 6 Amendment rights today, if you can articulate 7 that for me. 8 MR. PIKE: Form, compound, 9 argumentative. 10 A ROCIISICill, Rosenfeld, Adler has been 11 described by the U.S. Attorney as a criminal 12 enterprise and as part of the largest fraud in 13 Florida's history. It has been reported that 14 your faro fabricated multiple cases using me, and 15 against me in order to fleece unsuspecting 16 investors out of millions of dollars. 17 Q Another long time friend of yours is 18 Gliblaine Maxwell, right? 19 A I intend to respond to all relevant 20 questions. I would like to answer most of these 21 questions today, but I can't because my attorneys 22 have counseled me that I cannot provide answers 23 to any questions relevant to this lawsuit. I 24 must accept their advice or risk losing my Sixth 25 Amendment right to effective representation. 25 1 Ghislaine Maxwell shares your sexual obsession 2 for underage minor females? 3 MR. PIKE: Argumentative, speculation, 4 harassing. 5 A You know, Mr. Edwards, the current U.S. 6 Attorney has described your law firm as a 7 crininal enterprise, and as taking part in one of 8 the largest frauds in Florida's history. It has 9 been widely reported that your firm fabricated 10 multiple cases of a sexual nature against 11 people — other people and me, in order to fleece 12 unsuspecting investors out of millions of 13 dollars, so unfortunately at this time in 14 response to your questions, my attorneys have 15 advised mei must assert my Sixth Amendment, 16 Fifth Amendment and Fourteenth Amendment rights, 17 though 1 believe, as you know, I would really 18 like to answer these questions, but at this 19 moment, although at this time I have to assert 20 those rights or risk losing effective counsel. 21 Q Do you know 22 A I intend to respond to all relevant 23 questions regarding this lawsuit; however, at the 24 present time my counsel has advised me that I 25 cannot provide answers to any questions relevant 7 (Pages 22 to 25) U.S. Legal Support EFTA01076257 26 28 1 to this lawsuit. Your finn has been described as 2 a criminal enterprise, and is part of the largest 3 fraud in Florida's history fabricating sexual 4 cases against me and others. Therefore, 5 unfortunately, although I would like to answer 6 all of your questions today, I'm going to have to 7 assert my Fifth, Sixth and Fourteenth Amendment right. 9 Q Did you and Ghis sexually 10 assault at 'a house? 11 A i intend to respond to all relevant 12 questions regarding this lawsuit; however, at the 13 present time my attorneys have counseled me I 14 cannot provide answers to any questions relevant 15 to this lawsuit and must accept this right or 16 risk losing my Sixth Amendment rights to 17 effective presentation. Accordingly, I assert my 18 Constitutional rights as guaranteed by the Fifth, 19 Sixth and Fourteenth amendments to the U.S. 20 Constitution. 21 Q Stating Ghlslalne Maxwell and you had 22 devised several schemes to lure underage girls to 23 you for sex; isn't that correct? 24 MR. PIKE: Form, argumentative, 25 harassing? 1 present time my attorneys have counseled me that 2 I cannot provide answers to any questions 3 relevant to this lawsuit, no matter how much I 4 would like to. 5 Therefore, I must accept their advice or 6 risk losing my Sixth Amendment right to effective 7 representation; therefore, i have to assert my 8 Fifth, Sixth and Fourteenth Amendment right under 9 the U.S. Constitution. 10 Q Do you own a home in New Mexico? 11 A i intend to respond to all relevant 12 questions regarding this lawsuit and as I've had 13 to do with most of your questions here today, I'm 14 going to have to take my attorneys advice and 15 assert my Fifth, Sixth and Fourteenth Amendment 16 right under the U.S. Constitution or risk losing 17 effective representation. 18 Q Is it true that you have had underage 19 females, at each of those homes, for orgies with 20 you and Ghislaine Maxwell? 21 MR. PIKE: Form, argumentative, 22 speculation and harassing. 23 A I would like to answer that question. I 24 really would. However, as your firm has been 25 described by the U.S. Attorney as a criminal 27 1 A Mr. Edwards, your firm has fabricated 2 multiple cases of sexual harassment claims and 3 other types of sexual cases against me and others 4 in order to be pan of what the U.S. Attorney has described as the largest fraud, the largest fraud 6 in Florida's history. I would like to answer all 7 your questions; however, my attorneys have 8 counseled me that at least today, I must assert 9 my Fifth, Sixth and Fourteenth Amendment rights 10 under the U.S. Constitution. 11 Q Do you own a home in Manhattan? 12 A i intend to respond to all relevant 13 questions to this lawsuit; however, at the 14 present time my attorneys have counseled me that 15 I cannot provide answers to any questions 16 relevant to this lawsuit, and I must accept their 17 advice or risk losing my Sixth Amendment right to 18 effective representation. 19 Accordingly, therefore, I have to assert 20 my Fifth, Sixth and Fourteenth Amendment right 21 under the U.S. Constitution. 22 Q Do you own an island in the V.S. Virgin 23 Islands? 24 A !intend to respond to all relevant 25 questions regarding this lawsuit; however, at the 29 1 enterprise, which its principal purpose was 2 racketeering conspiracy to generate money for the 3 firm and its co-ccnspiritors through the 4 operation of enterprise and through various 5 activities including mail fraud, wire fraud and 6 money laundering, and fabricating multiple sex 7 cases against me and others, though I would like 8 to answer your question today, Mr. Edwards, my 9 courisel has advised me I must take the Fifth, 10 Sixth and Fourteenth Amendment right provided by 11 the U.S. Constitution. 12 Q Do you know somebody named 13 (phonetic)? 14 MR. PIKE: Can you spell that, for the 15 record? 16 MR. EDWARDS: No. 17 MR. PIKE: Or for the court reporter? 18 A No. 19 Q You don't know the name? 20 A No. Could you spell it? 21 Q (Witness shrugs.) 22 A Okay. 23 Q Did your sexual obsession with underage 24 minor females grow at some point in time to allow 25 you access to these underage minors every single 8 (Pages 26 to 29) U.S. Legal Support EFTA01076258 30 32 1 day for sex? 2 MR. PIKE: Overbroad. Speculation, 3 argumentative, compound, harassing and 4 confusing as well; as worded. Do you want 5 to break it down, Mr. Edwards? 6 Q Isn't It true that for the past ten 7 years you have found a way to engage in sexual 8 conduct with underage minors on an every day 9 bask? to MR. PIKE: Speculation. Argumentative. it A As your firm has been described as a 12 criminal enterprise by the United States Attorney 13 and is part of the scheme to defraud people in 14 South Florida of millions of dollars, you have 15 fabricated sexual cases and sexual claims against 16 people like me and others. Unfortunately at this 17 time although I would like to answer your 18 questions, Mr. Edwards, my counsel has advised me 19 I cannot They have advised me I must assert my 20 Fifth, Sixth and Fourteenth Amendment rights 21 under the U.S. Constitution. 22 Q isn't it true that you ►ave promised 23 underage minors money or other benefits to engage 24 in sexual conduct with you over the past ten 25 years? 31 1 A Again, as I've answered many of your 2 questions today, and unfortunately will probably 3 end up not answering most of your questions 4 today, as your firm has been described, the firm 5 bringing this lawsuit, I believe, if I'm wrong 6 please, correct me -- 7 Q You're wrong. 8 A This is the firm that didn't notice this 9 deposition? 10 Q Did not? 11 A Did not? 12 Q No. 13 A I apologize. Though your former firm 14 has been described, and the person you represent, 15 L.M., in this case was represented by the firm 16 that was described by the U.S. Attorney as 17 perpetrating one of the largest frauds in South 18 Florida's history, fabricating multiple sexual 19 cases against me and others in order to fleece 20 unsuspecting investors out of millions and 21. millions of dollars, so though unfortunately, I 22 would like to answer each one of your questions 23 today, my counsel has advised me I must assert my 24 Sixth Amendment, Fourteenth Amendment and Fifth 25 Amendment right, though I believe you know, I 1 2 3 4 5 6 7 a 9 10 11 12 13 10 15 A Can you spell it forme, please? 16 17 A What's the last name, how is it 18 spelled? 19 Q-Ibelieve. 20 A I intend to respond to all relevant 21 questions regarding this lawsuit; however, at the 22 present time my attorneys have counseled me that 23 I cannot provide answers to any questions that 24 may be relevant to this lawsuit and I must accept 25 this advice or risk losing my Sixth Amendment would like to answer those questions, though at this moment I must assert those rights or risk losing my attorneys. Q Sure, let's test that answer. A Okay. Let's talk about Jane DoMJane Doe who was represented bMI firm, had nothing to do with Rothstein, Rosenfeld, Adler. Do you know A Who? A Can you spelt it? Q Common spelling, 33 1 right to effective representation. Accordingly, 2 I assert my Constitutional rights as guaranteed 3 by the Fifth, Sixth and Fourteenth Amendment to 4 the Constitution. 5 Q Just for the record, I can only spell it 6 the way it was spelled in your flight logs from 7 your airplane. I don't know exactly how she 8 spells her name, only how your pilot would spell 9 her name. 10 MR. PIKE: Form, speculating. 11 Q If I misspell it — 12 MR. PIKE: Form, speculation, 13 argumentative, harassing. 14 MR. EDWARDS: That's harassing? 15 MR. PIKE: It assumes facts currently 16 not in evidence in this particular 17 deposition; therefore, I move to strike. 18 MR. EDWARDS: I was responding to his 19 question asking me how to spell her name. I 20 don't know how other than his own pilot. 21 MR. PIKE: Mr. Edwards, he asked you to 22 spell the name, you then spelled the name, 23 then went on with another narrative and 24 there wasn't a question posed, on the floor. 25 Q You would agree you Interacted with- 9 (Pages 30 to 33) U.S. Legal Support EFTA01076259 34 36 1 every day in a sexual way, when she was 15 years 2 old, right? 3 A Again, I'm softy? 4 Q Sure. You would agree that you 5 Interacted with. sexually on an every day 6 basis when she was 15 years old? 7 A You know, again, Mr. Edwards, I would 8 like to answer all your questions here today. My 9 attorneys have asked me — advised me that I must 10 assert my Sixth Amendment, Fourteenth Amendment 11 and Fifth Amendment rights provided by the U.S. 12 Constitution and the fact that the current U.S. 13 Attorney has described your law finn as a 14 criminal enterprise, is one of the largest frauds 15 in Florida's history for fabricating sexual -- 16 cases of a sexual nature against me and others. 17 Unfortunately, although I would like to answer 18 those questions, if I do I risk losing my 19 attorneys' counsel. Therefore, I must assert my 20 right. 21 MR. EDWARDS: Madam court reporter, Ill 22 as an exhibit, the Jane Doe number 23 crsus Jeffrey Epstein complaint, at 24 some point in time. It will be Exhibit 1, 25 as Pm going to go through some of the facts 35 1 as alleged in the complaint and as will be 2 testified to by the plaja. 3 (Jane Doe numberMversus Jeffrey 4 Epstein complaint was deemed marked as 5 Exhibit number 1 for identification, as of 6 this date.) 7 MR. PIKE: Counsel, do you have an extra copy of that for me? 9 MR. EDWARDS: No. 10 MR. PIKE: May I look at it real quick? 11 MR. EDWARDS: No. It has my notes on 12 it. 13 MR. PIKE: I understood, I saw the 14 highlights. 15 MR. EDWARDS: The notes are highlighted 16 so when we copy it, it will not show up. 17 MR. PIKE: Just for the record, that's a 18 current, operative pleading, correct? 19 MR. EDWARDS. Correct. 20 THE WITNESS: What does that mean? 21 MR. PIKE: There may have been some 22 amendments to a complaint and I want to make 23 sure that's the operative complaint at issue 24 that he is speaking of today. 25 THE WITNESS: Can I go off the record 1 for a second? 2 May I ask you a question? 3 MR. PIKE: Sure. Can we take a break 4 fora second? 5 MR. EDWARDS: Again? 6 THE WITNESS: Just a question. 7 MR. PIKE: He wants to speak with me for 8 a second. 9 THE VIDEOGRAPHER: Off the video record 10 12:01 p.m. 11 (Pause in the proceedings.) 12 THE VIDEOGRAPHER: We are back on the 13 video record at 12:02 p.m. 14 Q Is it true, Mr. Epstein, that you and 15 Ghislaine Maxwell forced■ to have sex with 16 you on a daily basis? 17 MR. PIKE: Form, argumentative, 18 harassing. 19 A Unfortunately at this time, though I 20 would really like to answer those questions, and 21 like I have dent for most of your questions here 22 today, Mr. Edwards, your firm was described as a 23 criminal enterprise, a serious criminal 24 enterprise by the current U.S. Attorney. Part of 25 that criminal enterprise was fabricating cases of 37 1 a sexual nature against me and others in order to 2 fleece unsuspecting investors out of millions of 3 dollars. Though, unfortunately at this time no 4 matter how I would like to respond to your 5 questions, I must assert my Sixth Amendment, 6 Fifth Amendment and Fourteenth Amendment rights 7 under the U.S. Constitution or risk having my 8 attorneys resign. 9 Q Isn't it true thaMwas yours and 10 Ghlslaine Maxwell's sex slave front the time she 11 was 15 through the time she escaped when she was 12 19? 13 MR. PIKE: Again objection, 14 argumentative, harassing. 15 A Mr. Edwards, your fimi has been 16 described as — excuse me, as a criminal 17 enterprise by the current U.S. Attorney and part 18 of the largest fraud in Florida's history. Part 19 of that fraud was fabricating multiple cases 20 against people like me and others, of a sexual 21 nature, in order to fleece unsuspecting investors 22 out of millions and millions of dollars, so 23 though I would like to answer that question, my 24 attorneys have told me today I must assert my 25 Sixth Amendment, Fourteenth Amendment and Fifth 10 (Pages 34 to 37) U.S. Legal Support EFTA01076260 38 40 1 Amendment right. 2 Q Isn't it true that you and Chisialne 3 Maxwell celebrated her 16th birthday with her and 4 had sex with her on that day? 5 MR. PIKE: Form. Compound, confusing, 6 argumentative, harassing. 7 A Mr. Edwards, I would like to answer that question. My attorneys have told me today, I 9 have to at least today assert my Fifth Amendment, 10 Sixth Amendment and Fourteenth Amendment rights 11 to the U.S. Constitution, especially my concern 12 is, that your firm has filed fraudulent lawsuits, 13 fabricated lawsuits, and the U.S. Attorney, the 14 current U.S. Attorney has described your firm as 15 a criminal enterprise that — whose main purpose 16 was to generate money for the finn and its 17 co-conspirators through the operation of various 18 criminal activities, including mail fraud, wire 19 fraud and money laundering. 20 mitAre you saying that the complaint of 21 gainst you, the allegation in that 22 complaint, are fake? 23 MR. PIKE: Form. Misinterprets the 24 witness's testimony. 25 Q Or saying k Is true? 1 the complaint filed byalagainst you, isn't it 2 true, sir, that a friend of yours sent you three, 3 12-year old females for you to sexually abuse on 4 one of your birthdays? 5 MR. PIKE: Form, argumentative, 6 harassing, and irrelevant to this lawsuit. 7 THE WITNESS: Excuse me. A Vetere saying it is part of the 9 lawsuit? 10 Q Yes, I'll read It. 11 "On one of the defendant Epstein's 12 birthdays, a friend of defendant sent him 13 2-year old girls fro ho spoke no 14 t for defendant to sexually exploit and 15 abuse? After doing so they were sent back to 16 next day." 17 sn't that true? 18 MR. PIKE: Once again, move to strike, 19 irrelevant, argumentative, harassing, and 20 for the record, the exhibit that's being 21 read from is a complaint that's unrelated to 22 the instant matter and not filed or 23 incorporated by the current plaintil 24 in this matter. 25 A I would like to answer that question, I 39 1 MR. PIKE: Same objection. 2 Q It is either true or false? 3 A I'll repeat myself, unfortunately, but 4 the current U.S. A has described your law 5 firm that filed that fil m—wm 6 involved in the filing o laim, 7 motions — I'm softy, do you want to tell me what 8 it was then? Would you like to tell me the 9 firm's involvement in this lawsuit, since we will 10 be here the rest of the day? 11 Q Answer the question. 12 A All right. 13 The U.S. Attorney has described that 14 firm as a criminal enterprise perpetrating one of 15 the largest frauds in Florida's history against 16 unsuspecting investors, fleecing them out of 17 millions of dollars by creating, crafting and 18 fabricating fellacious (sic) sexual claims 19 against people like me and others, so 20 unfortunately, though I would like to answer your 21 questions, Mr. Edwards, my counsel has advised me 22 that at least today I must assert my Sixth 23 Amendment, Fifth Amendment and Fourteenth 24 Amendment rights under the U.S. Constitution. 25 Q Isn't It true, sir, and I'm reading from 41 1 really would; however, today my attorneys have 2 told me I have to assert my Fifth Amendment, 3 Sixth Amendment and Fourteenth Amendment rights 4 of the US. Constitution, especially because your 5 firm involved in this lawsuit has fabricated, 6 widely reported, multiple cases of sexual 7 harassment cases against individuals like me and 8 others, perpetrating what the U.S. Attorney 9 called one of the largest frauds in Florida's 10 history, fleecing people out of millions of 11 dollars, so though 1 would like to answer that 12 question, today I have to assert those rights or 13 risk losing my attorneys' counsel. 14 Q Isn't it true that you Contd.as a 15 15-year old girl to have sex with numerous 16 friends of yours? 17 A Are you kidding? 18 Q Reading front a lawsuit. 19 A Sorry. Mr. Edwards. Though I would like 20 to answer that question as well, as I've answered 21 most of your other questions here today, I would 22 like to respond; however, my attorneys here today 23 have advised me I have to assert my Fifth 24 Amendment, Sixth Amendment and Fourteenth 25 Amendment rights under the U.S. Constitution, 11 (Pages 38 to 41) U.S. Legal Support EFTA01076261 42 44 1 especially as your firm has been accused by the 2 U.S. Attorney as being a criminal enterprise, and 3 part of the largest fraud in Florida's history. 4 Basically -- sorry, if I didn't read correctly, 5 um.... the operation of the enterprise through 6 various criminal activities including mail (mud, 7 wire fraud and money laundering, fabricating 8 sexual harassment cases against people like me 9 and others. 10 Q By the way — 11 A Yes, sir? 12 Q - didn't M r trip 13 ticket paid for by you toad she 14 ultimately did not get back on the plane but 15 instead escaped t.16 A I would like to answer that question, 17 but today I would have to assert my Sixth 18 Amendment fights, my Fifth Amendment tights and 19 my Fourteenth Amendment rights under the U.S. 20 Constitution, especially since your firm has been 21 described as perpetrating one of the largest 22 frauds in Florida's history, fleecing investors 23 out of millions of dollars, being described by 24 the U.S. Attorney of South Florida, as a criminal 25 enterprise engaged in various criminal activities 43 1 including mail fraud, wire fraud and money 7 laundering. 3 Q Do you know a man named Jean Luc 4 Brunel? 5 A Can you spell it? 6 Q He was at your house last week, does 7 that remind you? 8 MR. PIKE: Form, move to strike, 9 speculation, argumentative, harassing. 10 Is there a question on the table, Mr. 11 Edwards? 12 MR. EDWARDS: Yes. 13 Q Do you know him? 14 A Can you spell his name for me, please? 15 Q I don't need to spell his name. Do you 16 know who I'm talking about, Mr. Brunel? 17 A Sorry, Mr. what? 18 Q 19 A I would like to answer that question as 20 well, but my attorneys have counseled me today I 21 have to assert my Sixth Amendment rights, Fifth 22 Amendment rights and Fourteenth Amraultrent rights 23 under the U.S. Constitution or risk losing my 24 right to effective representation. 25 Q What's the purpose for you asking me to 1 spell his name? Are you acting like you don't 2 know him? 3 MR. PIKE: Form, move to strike, 4 argumentative and irrelevant as worded. 5 Mr. Edwards, you know that there are 6 various standing orders, if not in this 7 case, in various other cases, that 8 specifically describe the protections of the 9 Fifth Amendment. Federal Courts have 10 ordered that certain questions that you are 11 asking shall not be answered or Mr. Epstein 12 would risk losing his Fifth Amendment 13 right - le MR. EDWARDS: I understand that. He is 15 asking to spell people's names. 16 MR. PIKE: -- under the United States 17 Constitution. A lot of these questions here 18 today that you're asking have already been 19 ruled on by various Courts, that the Fifth 20 Amendment protects any response thereto, so 21 I would like -- Fm giving you some leeway 22 here with regard to the argumentative 23 questions. We've already -- and I'm not 24 obviously testifying for the witness, but 25 we've already handled a lot of these issues 45 1 in court and we have already adjourned one 2 deposition for being argumentative, and I 3 think you understand what the Court said 4 there, so having said that, and I understand 5 that you have ajob to do, but having said 6 that, I would like to caution you 7 professionally, if you continue with the 8 argumentative questions, I am going to have 9 to terminate this deposition — 10 MR. EDWARDS: I completely understand. 11 MR. PIKE: Okay. We are here today 12 13 MR.. EDWARDS: Mr. Brunel — 14 MR. PIKE: I want the Court to know we 15 are here today to allow you to ask your 16 questions, but the harassing and 17 argumentative tone is not going to be 18 tolerated. 19 MR. EDWARDS: We have a video. We can 20 show the Court the tone. It is obviously 21 not harassing. 22 MR. PIKE: That's fine. 23 Q Mr. Brunel is a long-term friend of 24 yours, right? 25 A I intend to respond to all relevant 12 (Pages 42 to 45) U.S. Legal Support EFTA01076262 46 48 1 questions of this lawsuit; however, today my 2 attorneys have counseled me I cannot provide 3 answers to any questions that may be relevant to 4 this lawsuit and I must accept their advice or 5 risk losing my Sixth Amendment right to effective 6 representation. 7 Q You know him as somebody who has been 8 caught engaging in sex with underage minors in 9 the past; Is that correct? 10 MR. PIKE: Form. 11 A You will have to repeat the question, 12 fm sorry. 13 Q You know Mr. Brunel as somebody who has 14 been caught engaging in sex with minors in the 15 past; is that correct? 16 MR. PiKE: Form. 17 A I intend to respond to all relevant 18 questions regarding this lawsuit; however, at the 19 present time my attorneys have counseled me that 20 I cannot provide answers to any questions 21 relevant to this lawsuit, and I must accept their 22 advice or risk losing my Sixth Amendment tight to 23 effective representation as your firm has been 24 described by the US. Attorney as a criminal 25 enterprise and part of one of the largest frauds 1 that I cannot provide answers to any questions 2 relevant to this lawsuit and I must accept their 3 advice or risk losing my Fifth, Sixth and 4 Fourteenth Amendment rights under the U.S. 5 Constitution. 6 Q When you were bein criminally 7 investigated and= was i is it 8 true that you made a personal telephone call to 9 her telling her not to come forward with any of 10 the information she knew? 11 MR. PiKE: Form. 12 A Again? 13 Q Putting a time frame on It, the time 14 frame where you were being criminally 15 investigated — 16 A What time frame is that? 17 Q In her complaint it is not specific, 18 but, let's just make it whenever. At some int 19 in time did you place a telephone call to in . 20 Meriting her not to come forward with 21 any information about you engaging In sex with 22 her while she was a minor? 23 MR. PiKE: Form. 24 A I intend to respond to all relevant 25 questions regarding this lawsuit; however, at the 47 1 in Florida's history specifically said you have 2 been fabricating -- the law firm has been 3 fabricating multiple cases of a sexual nature in 4 order to fleece unsuspecting investors out of 5 millions of dollars, including mail fraud, wire 6 fraud and money laundering, so unfortunately, 7 though i would like to answer all your questions 8 here today, I must assert my Sixth Amendment, 9 Fourteenth Amendment and Fifth Amendment right. 10 Q You were Involved in a modeling business 11 with him called M.C. Squared; is that correct? 12 A Again? 13 Q You were involved in a modeling agency 14 with — 15 A What do you mean 16 Q — with Mr. Brunel called M.C. Squared? 17 A "Involved" means what, what do you 18 mean? 19 Q You tell the jury your involvement with 20 the modeling agency. You can clarify for me, 21 Fillet you do that. 22 MR. PIKE: Object to the form. 23 A i intend to respond to all relevant 24 questions regarding this lawsuit. However, at 25 the present time my attorneys have counseled me 49 1 present time my attorneys have counseled me that 2 I cannot provide answers to any questions 3 relevant to this lawsuit and I must accept their 4 advice or risk losing my Sixth Amendment right to 5 effective representation. 6 Q With respect to underage females, isn't 7 it true that you have made the statement, in 8 quotes, "the younger the better"? 9 MR. PIKE: &WM. 10 A Again, as your firm has been described 11 by the current U.S. Attorney as a criminal 12 enterprise involved in mail fraud, wire fraud, 13 money laundering, and specifically crafting, 14 fabricating multiple cases of sexual — of a 15 sexual nature against people like me, and others, 16 in order to fleece many, many unsuspecting 17 investors out of millions of dollars; I would 18 like to answer your questions here today, Mr. 19 Edwards, but unfortunately, my attorneys have 20 counseled me that I must assert my Fifth, Sixth 21 and Fourteenth Amendment right or they will 22 resign. 23 Q Who are your current employees? 24 MR. PIKE: Form. 25 A Say that again. 13 (Pages 46 to 49) U.S. Legal Support EFTA01076263 50 52 1 Q Who are your current employees, people 2 who work for you, that you pay? 3 A I intend to respond to all relevant 4 questions regarding this lawsuit; however, at the 5 present time my attorneys have counseled me that 6 I cannot provide answers to any questions that 7 may be relevant to this lawsuit, or risk losing 8 my Sixth Amendment right to effec