vs. IN THE CIRCUIT COURT OF THE FIFTEENTH

vs. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff; ) ) ) 149. ) EPSTEIN and ) ) Defendants. ) West Palm Bach, Florida April 30th, 2009 I008 o'clock A.M. VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Page 1 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX Direct Examination by Mr. Edwards 4 Page 3 EXHIBIT INDEX Plaintiffs Exhibit Hunter I marked for ID. 24 (Exhibit held by Attorney Edwards.) +++++++++ Deposition of JEFFREY EPSTEIN, a witness of lawful age, taken by the Plaintiff, for the purpose of discovery and for use as evidence in the above entitled cause, wherein: E.W. is the Plaintiff, and JEFFREY EPSTEIN and- the Defendants, in the Circuit Court in and for Palm Beach County, Florida, pursuant to notice heretofore filed, before LINDA P. AUKAMP, a Registered Professional Reporter and Notary Public in and for the State of Florida at Large, at 250 Australian Avenue South, Suite 1400, West Patin Beach, Palm Beach County, Florida, on the 30th day of April, 2009, commencing at 10:08 o'clock A.M. Page 2 1 APPEARANCES: 2 For The Plaintiff: 3 ROTHSTEIN, ROSENFELDT, ADLER 401 East Las Olas Boulevard, Suite 1650 4 Fon Lauderdale, Florida, 33301.4252 By BRADLEY JAMES EDWARD, ESQUIRE and 5 WILLIAM J. BERGER, ESQUIRE and RUSSELL ADLER, ESQUIRE 6 7 For The Defendant BURMAN, CRITTON, LUTHER & COLEMAN S I5 North Plaster Drive, Suite 400 9 West Palm Beach, Florida 33401.4349 By JOHN MICHAEL BURMAN, ESQUIRE 10 11 Also for the Defendant 12 ATTER.BURY, GOLDBERGER & WEISS, P.A. 250 Australian Ave. South, Suite 1400 13 West Palm Beach, Florida 33401 By JACK A. GOLDBERGER, ESQUIRE 14 15 Also Present: 16 Jeff Abbott, Videographer, Visual Evidence 17 18 19 20 21 22 23 24 25 Page 1 THEREUPON, 2 THE VIDEOGRAPHEEt: This is the 30th day 3 April, 2009. The time is 10:08 a.m. This is 4 videotaped ition of Jeffrey Epstein in the 5 matter of... versus Epstein. This deposition 6 is being held at 250 Australian Avenue South, 7 West Palm Beach, Florida. My name is Jeff Abbott, lam the videographer representing 9 Visual Evidence, Incorporated. 10 Would the attorneys please announce their 11 appearances for the record. 12 MIt EDWARDS: Brad Edwards on behalf of 3.3 the plaint' "deposition was set in 3.4 the case of 15 THE VIDEOGRAPHER: Oh. 16 MR. EDWARDS: That is a separate client of 17 mine, but that's not the case 18 THE VIDEOGRAPHER: Okay, that's what I 19 had. Sorry. 20 MR. BERGER: And Pm William J. Berger, 21 for the plaintiff, also. 22 MR. GOLDBERGER: Jack Goldberger on behal 2 3 of Jeffrey Epstein. 24 MR. BURMAN: Michael Burman on behalf of 25 le in. I Mat' • -• • • mil.N 1 (Pages 1 to 4) PALM BEACH REPORTING SERVICE, INC. EFTA01103326 Page 5 1 THEREUPON, 2 JEFFREY EPSTEiN, 3 Being a witness in the notice heretofore 4 filed, being of lawful age, and being first duly 5 sworn in the above cause, testified on his oath as 6 follows: 7 THE WITNESS: Yes, I do. 8 DIRECT EXAMINATION 9 Q. (By Mr. Edwards) Can you tell us your 10 fidl name for the record? 11 A. Jeffrey Edward Epstein. 12 Q. And what's your date of birth? 13 A. January 20th, 1953. 14 Q. And your social security number? 15 A. 16 Q. And your current address in West Palm 17 Beach? 18 A. I intend to respond to all relevant 19 questions regarding this lawsuit. However, at the 20 present time my attorneys have counseled me that I 21 cannot provide answers to any questions relevant to 22 this lawsuit, and I must accept the advice or risk 23 losing my Sixth Ansadment right to effective 24 representation. 25 Accordingly, I assert my Fifth, Federal Page 6 3. Constitutional rights as guaranteed by the Fifth, 2 Sixth, and Fourteenth Amendments to the United 3 States Constitution. 4 Q. So you're unwilling to give us your 5 address of your house in Palm Beach Comity? 6 A. I intend to respond to all relevant 7 questions regarding this lawsuit. However, at the 8 present time my attorneys have counseled me that I 9 cannot provide answers to any questions relevant to 10 this lawsuit or risk losing my Sixth Amendment right 11 to effective representation. 12 MR. EDWARDS: Mr. Goldberger, can we enter 13 into an agreement so that we all know that he's 14 reading off of that piece of paper, we know 15 what the whole spiel is, but maybe he can just 16 say fifth or same answer or something like 17 that, so we can continue to move on, rather 18 than read that paper the entire time? We'll be 19 here for days. 20 MR. GOLDBERGER: I think out of an 21 abundance of caution ifs probably appropriate 22 that whatever we feel is the proper response 23 is, so that our invocation of our Fifth 24 Amendment privileges is properly protected, 25 so I think we're intono have to Ove the full Page 7 1 length- 2 MR. BURMAN: Obviously we can't tell what 3 you're going to play to a jury without the 4 entire spiel, what questions you night play to 5 a jury if you decide to do that when this case 6 is tried, so we're going to go with the entire 7 spiel to every question you ask. If -- that's 8 Mr. Goldberger's representation, or 9 recommendation. 10 MR. EDWARDS: Okay. 11 MR. GOLDBERGER: We will go question by 12 question, and we may or may not invoke Fifth 13 Amendment privileges and there may be times 14 where I'm going to have to think about it, 15 discuss it with Mr. Burman whether we're going 16 to invoke on any particular question, but on 17 those questions that we do invoke Fifth 18 Amendment privileges, I think we have no choice 19 but, as you say, do the entire spiel. 20 Q. (By Mr. Edwards) Can you tell me the 21 addresses of other homes that you own outside of 22 West Palm Beach? 23 A. I intend to respond to all relevant 24 questions regarding this lawsuit. However, in the 25 present my attorneys have counseled me that I cannot 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25Page 8 provide answers to any questions relevant to this lawsuit, and i must accept the advice or risk losing my Sixth Amendment right to effective representation. Q. Have you seen any — MR. GOLDBERGER: And, excuse me, and your Fifth Anwhipeat privileges. THE WITNESS: Yes. Accordingly, i, excuse me, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteen Amendments of the United States Constitution. Q. (By Mr. Edwards) Have you seen any psychologists a psychiatrists in your life? MR. GOLDBERGER: Go ahead. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and i must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly. I assert my constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment of that constitution. 2 (Pages 5 to 8 PALM BEACH REPORTING SERVICE, INC. EFTA01103327 Page 9 1 Q. (By Mr. Edwards) Tell me the names of all 2 the businesses in which you are affiliated in any 3 way? 4 A. I intend to respond to all relevant 5 questions regarding this lawsuit. However, at the 6 present time my attorneys have counseled me that I 7 cannot provide answers to any questions relevant to 8 this lawsuit, and I must accept this advice or risk 9 losing my Sixth Amendment right to effective 10 representation. 11 I also assert my Federal Constitutional 12 Rights as guaranteed by the Fifth, Sixth, and 13 Fourteenth Amendments to the United States 14 Constitution. 15 Q. My understanding is you're currently 16 serving a 12-month jail sentence, is that correct? 17 MR. GOLDBERGER: You can answer, but -- 18 THE WITNESS: Na 19 Q. (By Mr. Edwards) You were currently, you 20 were initially sentenced to 18 months in jail, is 21 that correct? 22 MR. GOLDBERGER: Go ahead. 23 THE WITNESS: Yes. 24 Q. (By Mr. Edwards) And at the present 25 moment are you still under the supervision of that Page 11 1 A. Sorry, could you repeat the question? 2 Q. Sure. 3 I have a videotaped copy of the plea 4 colloquy — 5 A. No, the question before that. That's 6 okay. 7 Q. The question is, where do you intend to 8 reside once you are released from jail? 9 A. I intend to respond to all relevant 10 questions regarding this lawsuit. However, at the 11 present time my attorneys have counseled me that I 12 cannot provide answers to any questions relevant to 13 this lawsuit, and I must accept their advice or risk 14 losing my Sixth Amendment right to effective 15 representation. 16 Accordingly, I assert my Federal 17 Constitutional right as guaranteed by the Fifth, 18 Sixth, and Fourteenth Amendment of the United States 19 Constitution. 20 Q. As you know, that question was asked to 21 you when you pled guilty last June in 2008, and you 22 responded to the judge that you planned to reside in 23 West Palm Beach, Florida. Is that no longer your 24 intent? 25 A. I intend to respond to all relevant Page 10 1 jail sentence? 2 A. Yes. 3 Q. Do you !mow what your release date will 4 be? S A. No. 6 Q. You have not been told the date of your 7 release? 8 A. Not yet. 9 Q. Where do you plan to reside when you're 10 released from jail? 11 A. I intend to respond to all relevant 12 questions regarding this lawsuit. However, at the 13 present time my attorneys have advised me that I 14 must accept the advice, advised me not to answer 15 those questions. I must accept their advice or risk 16 losing my Sixth Amendment right to effective 17 representation. 18 Accordingly, I assert my Federal 19 Constitutional right as guaranteed by the Fifth, 20 Sixth, and Fourteenth Amendment of the constitution. 21 Q. Mr. Epstein, I have a videotaped copy of 22 the plea colloquy where you pled guilty and told 23 that judge you would be residing in West Palm Beach, 24 Florida. Are you saying now that the statement you 25 made to that inlEn312longer true? Page 12 1 questions regarding this lawsuit However, at the 2 present time my attorneys have counseled me that I 3 cannot provide answers to any questions relevant to 4 this lawsuit, and I must accept this advice or risk 5 losing my Sixth Amendment right to effective 6 representation. 7 Accordingly, I assert my Federal 8 Constitutional right as guaranteed by the Fifth, 9 Sixth, and Fourteenth Amendment of the constitution. 10 Q. This deposition is not being taken in the 11 county jail, but rather in your attorney, Jack 12 Goldberger's office, so can you please inform the 13 jury as to your current schedule as it is exists 14 today? 15 MR GOLDBERGER: Let me hold off on that. 16 Okay. 17 THE WITNESS: I don't understand the 18 schedule, the question. 19 MR. GOLDBERGER: Yeah, if you can just, if 2o you can rephrase the question, I think we can 21 answer it for you. 22 Q. (By Mr. Edwards) Okay. Currently you 23 described that you're under the supervision of the 24 jail sentence at this point in time, you're within 25 the 18 months of your,jail sentence. But this isn't 3 (Pages 9 to 12) PALM BEACH REPORTING SERVICE, INC. EFTA01103328 Page 13 1 a jail setting, so obviously you're outside of the 2 jail setting. 3 I am asking you just to tell the jury your 4 current schedule; you wake up, are you released from 5 jail at some time, do you have to report back to 6 jail on a daily basis? 7 A. Yes, I report back to jail at 8:00 p.m. 8 Q. Every single day? 9 A. Yes. 10 Q. And is it seven days a week that you're 11 out on work release? 12 A. No, sir. 13 Q. How many days a week are you out on work 14 release? 15 A. Six. 16 Q. And of those six days, how many hours per 17 day are you out on work release? 18 A. Twelve. 19 Q. And what are the hours that you're out on 20 work release versus the hours that you are confined 21 to the jail? 22 A. Repeat the question, please. 23 Q. What are the hours that you are out on 24 work release outside the jail versus the hours that 25 you are inside the jail, meaning if you report back Page 14 1 to the jail at 8:00 and stay there until 8:00 in the 2 morning, tell me that 3 A. I just did. 4 Q. And is that the schedule? 5 A. !just did. Yes, that's the schedule. 6 Q. Okay. So from 8:00 p.m. until 8:00 an. 7 you're in the jail? 8 A. Yes. 9 Q. And then from 8.00 a.m. to 8:00 p.m. 10 you're out on work release? 11 A. Is that a question? 12 Q. Yes. 13 A. Yes. 14 Q. And where do you, where do you work? 15 MR. GOLDBERGER Objection. 16 THE WITNESS: I intend to respond to all 17 relevant questions to this lawsuit. However, 18 at the present time my attorneys have counseled 19 me that I cannot provide answers to any 20 questions relevant to this lawsuit, and I must 21 accept this advice or risk losing my Sixth 22 Amendment right to effective representation. 23 Therefore, I assert my Federal 24 Constitutional right as guaranteed by the 25 Fifth, Sixths and Fourteenth Amendment of the Page 15 1 constitution. 2 Q. (By Mr. Edwards) Are you saying that 3 providing me an answer as to where you currently 4 work, would somehow incriminate you? 5 MR. GOLDBERGER: Let's not be 6 argumentative. He responded to the question on 7 advice of counsel, and if you think that was an 8 improper invocation, then you have a remedy, 9 but don't argue with the witness, which is what 10 we did. Okay. 11 Q. (By Mr. Edwards) Do you have any plans to 12 leave the country once you're released from jail? 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 I 16 cannot provide answers to any questions relevant to 17 this lawsuit, and must accept the advice or risk 18 losing my Sixth Amendment right to effective 19 representation. 20 Accordingly, I assert my Federal 21 Constitutional right as guaranteed by the Fifth, 22 Sixth, and Fourteenth Amendment of the constitution. 23 Q. Do you currently own any jets or 24 airplanes? 25 A. I intend to respond to all relevant 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 Page 16 questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment ofirnstitution MR. BURMAN: Is a state or federal case? MR. EDWARDS: State. MR BURMAN: Okay. I am going to, in addition to my client's assertion of his rights, also object on the grounds that punitive damages hasn't been allowed in this case yet. That's clearly a financial-type question and, therefore, we object on those grounds, as well. MR. EDWARDS: Thank you. Q. (By Mr. Edwards) Who are the pilots that are employed by you or work for you or fly your airplanes? A. I intend to respond to all relevant questions regarding this lawsuit. However at the 4 (Pages 13 to 16) PALM BEACH REPORTING SERVICE, INC. EFTA01103329 Page 17 1 present time my attorneys have counseled me that I 2 cannot provide answers to any questions relevant to 3 this lawsuit, and must accept their advice or risk 4 losing my Sixth Amendment right to effective 5 representation. 6 Accordingly, I assert my Federal 7 Constitutional rights guaranteed by the Fifth, 8 Sixth, and Fourteenth Amendment to the United States 9 Constitution. 10 Q. What person or persons make your travel 11 arrangements when you travel? 12 A. I intend to respond to all relevant 13 questions regarding this lawsuit However, at the 14 present time my attorneys have advised me that I 15 cannot provide answers to any questions relevant to 16 this lawsuit, and must accept this advice or risk 17 losing my Sixth Amendment right to effective 18 representation. 19 Accordingly, I would have to assert my 20 Federal Constitutional right as guaranteed by the 21 Fifth, Sixth, and Fourteenth Amendment of the 22 constitution. 23 Q. Once you are released from jail, are you 24 under an obligation to report to probation? 25 A. Yes. Page 19 1 questions regarding this lawsuit However, at the 2 present time my attorneys have advised me that I 3 cannot provide answers to any questions currently. 4 Therefore, I must accept this advice or risk losing 5 my Sixth Amendment right to effective 6 representation. 7 Accordingly, ! assert my Federal 8 Constitutional right as guaranteed by the Fifth, 9 Sixth, and Fourteenth Amendment to the constitution. 10 Q. Are you currently working with the Florida 11 Science Foundation? 12 MR. GOLDBERGER: Umm, okay. 13 THE WITNESS: Yes. 14 Q. (By Mr. Edwards) And that is a, a 15 business that operates just next door to your 16 attorney, Jack Goldberger's office, is that correct? 17 A. No. 18 Q. The Florida Science Foundation does not 19 have an office on this floor right next door to your 20 attorney, Jack Goldberger's office? 23. A. Is that a question? 22 Q. Yes. 23 A. You have to rephrase the question, please? 24 Q. Does the Florida Science Foundation have 25 an office right next door to your attorney, Jack Page 18 1 Q. Do you intend to do so? 2 A. Yes. 3 Q. And once you are released, do you, 4 according to your sentence, are you scheduled to 5 serve one year community control or house arrest? 6 MR. GOLDBERGER: That's a compound 7 question. Please rephrase it. 8 THE WITNESS: Yes. 9 Q. (By Mr. Edwards) When you're released 10 from jail, do you intend to serve one year community 11 control as a part of your sentence? 12 A. Yes. 13 Q. And under that provision, will you be able 14 to continue working or will you be strictly confined 15 to your house? 16 MR. GOLDBERGER: That calls for a legal 17 interpretation on the part of my client that 18 he's just not, he's just not competent to 19 answer. So, if you know, fine, but I can't 20 imagine you would know. 23. THE WITNESS: I don't know. 22 Q. (By Mr. Edwards) Who are the people that 23 will be living or working in your house once you are 24 released from jail? 25 A. I intend to respond to all relevant 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 20 Goldbergees office? A. No. Q. What is your role with the Florida Science Foundation? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have advised me that I cannot answer questions relevant to this lawsuit and must accept their advice, or risk losing my Sixth Amendment right to effective representstion. Therefore, I must assert my Federal Constitutional right under the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. What does the Florida Science Foundation do? A. I intend to respond to all relevant questions to this, regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit i must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, lessen my Federal Constitutional rights guaranteed by the Fifth, Sixth, and Fourteenth Amendment to that 5 (Pages 17 to 20) PALM BEACH REPORTING SERVICE, INC. EFTA01103330 Page 21 1 constitution. 2 Q. Have you procured minors for the purposes 3 of prostitution? 4 A. I intend to respond to all relevant 5 questions to this, regarding this lawsuit However, 6 at the present time my attorneys have counseled me 7 that I cannot provide answers to any questions 8 relevant to this lawsuit, and must accept their 9 advice or risk losing my Sixth Amendment right to 10 effective representation. 13. Accordingly, I assert my Federal 12 Constitutional right as guaranteed by the Fifth, 13 Sixth and Fourteenth Amendment of the United States 14 Constitution. 15 Q. Isn't it true that you did plead guilty to 16 two felonies related to prostitution with minors? 17 MR. GOLDBERGER: Wait a minute, let me 18 just hold off a second. 19 (Thereupon, a discussion was had off 20 the record.) 21 MR. GOLDBERGER: You can answer the 22 question. 23 THE WITNESS: Could you repeat the 24 question? 25 Q. (By Mr. Edwards) Isn't it true that you Page 22 1 pled guilty to two felony counts related to 2 procurement of a minor for prostitution and/or 3 solicitation of a minor for prostitution? 4 A. No. 5 Q. What counts did you plead guilty to? 6 A. Procuring a minor for prostitution and 7 soliciting prostitution. 8 Q. Have you had sex with minor girls? 9 A I intend to respond to all relevant 10 questions regarding this lawsuit. However, at the 11 present time my attorneys have advised me that I 12 cannot provide answers to any questions relevant to 13 this lawsuit at the present time, and I must accept 14 that advice or risk losing my Sixth Amencirnent right 15 to effective representation. 16 Accordingly, I assert my Federal 17 Constitutional right under the Fifth, Sixth, and the 18 Fourteenth Amendment to the Constitution. 19 Q. Have you engaged in sex acts with girls 20 who at the time you engaged in those sex acts were 21 minors? 22 A. I intend to respond to all relevant 23 questions to this lawsuit. At the present time my 24 attorneys have counseled me that I cannot respond, 25 I'm som. provide answers to any uestions relevant 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 1 2 3 4 5 6 7 B 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 23 to this lawsuit, and I must accept that advice or risk losing their representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment. Did you intentionally touch my client, A. I don't understand the question, sorry. Q. For the purpose of this lawsuit, we have used the pseudonym to describe my client. Do you know who Pm talking about when I refer toMil A. I intend to respond to all relevant questions to those, this lawsuit. However, at the present time my attorneys have advised me that I cannot accept, answer any questions relevant to this lawsuit, and must accept their advice, or risk losing my Sixth Amendment right to effective rgrc istation. Q. Did you — A. Accordingly -- excuse me -- I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. MR. BURMAN: We further object on the ground tha name has not been disclosed Page 24 and you've objected to that. MR. EDWARDS: Thanks. (By Mr. Edwards) Did you touch my client NM, against her will? A. We don't know who is. You haven't told me who is. Q. Okay. MR. EDWARDS: Do you have an exhibit slicker? (Thereupon, Plaintiffs Exhibit Number 1 was marked for Identification by Attorney Edwards.) Q. (By Mr. Edwards) Pm going to show you an exhibit that I have marked for identification purposes as Plaintiffs Exhibit 1. Do you recognize the girl on the left in the photograph? A. I intend to respond to all relevant questions regarding — THE WITNESS: Excuse me one second. (Thereupon, a discussion was had off the record.) THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. Howeveriz2aJre,sentthe time atto have 6 (Pages 21 to 24) PALM BEACH REPORTING SERVICE, INC. EFTA01103331 Page 25 1 counseled me that I cannot provide answers to 2 any questions relevant to this lawsuit. I must 3 accept their advice or risk losing my Sixth 4 Amendment right to effective representation. 5 Accordingly, I assert my Federal 6 Constitutional right as given by the Fifth, 7 Sixth -- as provided by the Fifth, Sixth, and 8 Fourteenth Amendment to the constitution. 9 Q. (By Mr. Edwards Do you know somebody by 10 the name o 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 that I 14 cannot provide answers to any questions relevant to 15 this lawsuit, and must accept their advice or risk 16 losing my Sixth Amendment right to effective 17 representation. 18 Accordingly, I assert my Federal 19 Constitutional right as guaranteed by the Fifth, 20 Sixth and Fourteenth Amendment to the constitution. 21 Q. For the purposes of this deposition, when 22 I refer toM, I'm speaking of 23 Back to mthiitial questi . 24 touch my client,.., against her will? 25 A. I intend to respond to all relevant Page 27 1 A. I intend to respond to all relevant 2 questions regarding this lawsuit. However, at the 3 present time my attorneys have counseled me that 1 4 cannot provide answers to any questions relevant to 5 this lawsuit, and 1 must accept this advice or risk 6 losing my Sixth Amendment right to effective 7 representation. 8 Accordingly, I assert my Federal 9 Constitutional right as guaranteed by the Fifth, 10 Sixth, and Fourteenth Amendment to the United States 11 Constitution. 12 Q. Did you engage in sex or sex acts with a 13 female named (phonetic)? 14 A. I intend to respon to all relevant 15 questions regarding this lawsuit. However, at the 16 present time my attorneys have counseled me that I 17 cannot provide answers to any questions relevant to 18 this lawsuit, and I must accept this advice or risk 19 losing my Sixth Amendment right to effective 20 representation. 21 Accordingly, I assert my Federal 22 Constitutional right under the Fifth, Sixth, and 23 Fourteenth Amendment of the constitution. 24 Q. Between 2001 and 2005 did you en 25 sex or sex acts with a minor female named Page 26 1 questions regarding this lawsuit. However, at the 2 present time my attorneys have advised me that I 3 cannot provide answers to any questions relevant to 4 this lawsuit, and must accept their advice or risk 5 losing my Sixth Amendment right to effective 6 representation. 7 Accordingly, I assert my Fifth, Sixth, and 8 Fourteenth — Fifth, Sixth and Fourteenth Amendment 9 of the constitution. 10 Q. Did engage in sex or sex acts with my 11 clien against her will? 12 A. I intend to respond to all relevant 13 questions regarding this lawsuit. However, at the 14 present time my attorneys have advised me that I 15 cannot provide any questions relevant to this 16 lawsuit, and must accept their advice or risk losing 17 my Sixth Amendment right to effective 18 representation. 19 Accordingly, I assert my Federal 20 Constitutional right as guaranteed by the Fifth, 21 Sixth, and Fourteenth Amendment to that 22 constitution. 23 Q. Isn't it true that when you touthec. 24 against her will, you knew her to be a minor at the 25 time? Page 28 1 (phonetic)? 2 A. I intend to respond to all relevant 3 questions regarding this lawsuit. However, at the 4 present time my attorneys have counseled me that I 5 cannot provide answers to any questions relevant to 6 this lawsuit, and I must accept this advice or risk 7 losing my Sixth Amendment right to effective 8 representation. 9 Accordingly, I assert my Federal 10 Constitutional rights as guaranteed by the Fifth, 11 Sixth, and Fourteenth Amendment to the United States 12 Constitution. 13 Q. Between 2001 and 2005 did vou engage in 14 sex or sex acts with a minor named Mphonetic)? 15 A. I intend to respond to all relevant 16 questions regarding this lawsuit. However, at the 17 present time my attorneys have counseled me that I 18 cannot provide answers to any questions relevant to 19 this lawsuit, and I must accept this advice or risk 20 losing my Sixth Amendment right to effective 21 representation. 22 Accordingly, I assert my Federal 23 Constitutional right as guaranteed by the Fifth, 24 Sixth, and Fourteenth Amendment to the United States 25 Constitution. 7 (Pages 25 to 28) PALM BEACH REPORTING SERVICE, INC. EFTA01103332 Page 29 1 Q. Between 2001 and 2005 did you will 2 sex or sex acts with a minor female named 3 int (phonetic)? 4 A. I intend to respond to all relevant 5 questions regarding this lawsuit. However, at the 6 present time my attorneys have counseled me that I 7 cannot provide answers to any questions relevant to a this lawsuit, and must accept their advice or risk 9 losing my Sixth Amendment right to effective 10 representation. 11 Accordingly, i assert my Federal 12 Constitutional right as guaranteed by the Fifth, 13 Sixth, and Fourteenth Amendment to the United States 14 Constitution. 15 MR. BURMAN: Mr. Edwards, can I inquire of 16 you one thing? Do you have a RICO count in 17 UN's case? 18 MR. EDWARDS: Yes. 19 MR. BURMAN: Okay. These other girls, are 20 any of than your clients, as well? 23. MR. EDWARDS: Some may be. 22 MR. BURMAN: Okay. Thank you. 23 MR. EDWARDS: Some are not. 24 MR. BURMAN: Okay. 25 Q. (By Mr. Edwards) Between 2001 and 2005 Page 31 1 Q. Between 2001 and 2005 did you eruriS 2 sex or sex acts with a minor female named 3 (phonetic)? 4 A. I intend to respond to all relevant 5 questions regarding this lawsuit. However, at this 6 time my attorneys have counseled me that I cannot 7 provide answers to any questions relevant to this 8 lawsuit, and I must accept this advice or risk 9 losing my Sixth Amendment right to effective 10 representation. 11 Accordingly, I assert my Federal 12 Constitutional right as guaranteed by the Fifth, 13 Sixth, and Fourteenth Amendment of the United States 14 Constitution. 15 Q. Between 2001 and 2005 did you ensi 16 sex or sex acts with a minor female named 17 (phonetic)? 18 A. I intend to respond to all relevant 19 questions regarding this lawsuit. However, at the 20 present time my attorneys have counseled me that I 21 cannot provide answers to any questions relevant to 2 2 this lawsuit, and must accept this advice or risk 23 losing my Sixth Amendment right to effective 24 representation. 25 Accordingly, I assert my Federal Page 30 1 did you engage in sex or sex acts with a minor 2 female named IMIMEliphonetic)? 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 I 6 cannot provide answers to any questions relevant to 7 this lawsuit, and must accept this advice or risk B losing my Sixth Amendment right to effective 9 representation. 10 Accordingly, I assert my Federal 11 Constitutional rights as guaranteed by the Fifth, 12 Sixth, and Fourteenth Amendment to the constitution. 13 Q. Between 2001 and 2005 did you engage in 14 sex or sex acts with a minor female named 15 (phonetic)? 16 A. I intend to respond to all relevant 17 questions regarding this lawsuit. However, at the 18 present time my attorneys have counseled me that I 19 cannot provide answers to any questions relevant to 20 this lawsuit, and I must accept this advice or risk 21 losing my Sixth Amendment right to effective 22 representation. 23 Accordingly, I assert my Federal 24 Constitutional right as guaranteed by the Fifth, 25 Sixth?. and Fourteenth Amendment to the constitution. Page 32 1 Constitutional rights as guaranteed by the Fifth, 2 Sixth, and Fourteenth Amendment to the United States 3 Constitution. 4 Q. Between 2001 and 2005 did you engage in 5 sex or sex acts with a minor female named - 6 (phonetic)? 7 A. I intend to respond to all relevant a questions regarding this lawsuit. However, at the 9 present time my attorneys have counseled me that I 10 cannot provide answers to any questions relevant to 11 this lawsuit I must accept this advice or risk 12 losing my Sixth Amendment right to effective 13 representation. 14 Accordingly, I assert my Federal 15 Constitutional right under the Fifth, Sixth, and 16 Fourteenth Amendment to the constitution. 17 Q. Between 2001 and 2005 did you e in 18 sex or sex acts with a minor female named 19 (phonetic)? 2 0 A. I intend to respond to all relevant 21 questions regarding this lawsuit However, at the 2 2 present time my attorneys have counseled me that I 23 cannot provide answers to any questions relevant to 24 this lawsuit, and must accept this advice or risk 25 Iosing my Sixth Amendment right to effective 8 (Pages 29 to 32) PALM BEACH REPORTING SERVICE, INC. EFTA01103333 Page 33 1 representation. 2 Accordingly, I assert my Federal 3 Constitutional right as guaranteed by the Fifth, 4 Sixth, and Fourteenth Amendment to the United States 5 Constitution. 6 THE WITNESS: Can we take a break for, a 7 bathroom break, is that okay? 8 THE VIDEOGRAPHER: We're off the record at 9 10:39. 10 (Thereupon, a discussion was had off 11 the record.) 12 THE VIDEOGRAPHER: We're back on the 13 record at 10:44. 14 Q. (By Mr. Edwards) Between 2001 and 2005 15 did you engalii sex or sex acts with a minor 16 female name' (phonetic)? 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 I 20 cannot provide answers to questions relevant to this 21 lawsuit, and I must accept their advice or risk 22 losing my Sixth Amendment right to effective 23 representation. 24 Accordingly, I assert my Federal 25 Constitutional right as guaranteed by the Fifth, Page 34 1 Sixth and the Fourteenth Amendment to the United 2 States Constitution. 3 THE WITNESS: Can I see you a second, 4 Mike? 5 MIL BURMAN: Sure. 6 THE VIDEOORAPHER: We're off the record at 7 10:45. 8 (Thereupon, a brief break was taken.) 9 THE VIDEOGRAPHER: Back on the record at 10 10:46. 11 Q. (By Mr. Edwards) Between the year 2001 12 and 2005 did you eriyin sex or sex acts with a 13 minor female named in 14 MR. BURMAN: Object to form, form vague 15 and indefinite. Last name, please. 16 MR. EDWARDS: You can answer the question. 17 THE WITNESS: I intend to respond to all 18 relevant questions regarding this lawsuit 19 However, at the present time my attorneys have 20 counseled me that I cannot provide answers to 21 any questions relevant to this lawsuit, and 22 must accept this advice or risk losing my Sixth 23 Amendment right to effective representation. 24 Accordingly, I assert my Federal 25 Constitutional right as guaranteed b the Page 35 1 Fifth, Sixth, and Fourteenth Amendment to the 2 United States Constitution. 3 Q. (By Mr. Edwards) Between the year 2001 4 and 2005 did you en ge in sex or sex acts with a 5 minor female named honetic)? 6 MR. BURMAN: O ect to form, vague and 7 indefinite. Last name, please. 8 MR. EDWARDS: You can answer. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit. 11 However, at the present time my attorneys have 12 counseled me that I cannot provide answers to 13 any questions relevant to this lawsuit. I must 14 accept this advice or risk losing my Sixth 15 Amendment right to effective representation. 16 Accordingly, I assert my Federal 17 Constitutional rights as guaranteed by the 18 Fifth, Sixth and Fourteenth Amendment to the 19 United States Constitution. 20 Q. (By Mr. Edwards) Between 2001 and 2005 21 did you engage in sex or sex acts with a minor 22 female named (phonetic)? 23 MR. BURMAN: Object to form, vague and 24 indefinite. Last name, please. 25 MR. EDWARDS: You may answer. Page 36 1 THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit. 3 However, at the present time my attorneys have 4 counseled me that I cannot provide answers to 5 any questions relevant to this lawsuit, and 6 must accept this advice or risk losing my Sixth 7 Amendment right to effective representation. 8 Accordingly, I assert my Federal 9 Constitutional right as guaranteed by the 10 Fifth, Sixth and Fourteenth Amendment to the 11 United States constitution. 12 Q. (By Mr. Edwards) Between 2001 and 2005 13 did you engage in sex or sex acts with a minor 14 female named phonetic)? 15 MR. BURMAN: Object to the form, vague and 16 indefinite. Last name, please. 17 MR. EDWARDS: You can answer if - 18 THE WITNESS: 1 intend to respond to all 19 relevant questions regarding this lawsuit. 20 However, at the present time my attorneys have 21 counseled me that I cannot provide answers to 22 any questions relevant to this lawsuit. I must 23 accept this advice or risk losing my Sixth 24 Amendment right to effective representation. 25 Accordinfy, I assert my Federal 9 (Pa-es 33 to 36) PALM BEACH REPORTING SERVICE, INC. EFTA01103334 Page 37 1 Constitutional right as guaranteed by the 2 Fifth, Sixth and Fourteenth Amendment to the 3 United States Constitution. 4 Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor 6 female named (phonetic)? 7 MR. BURMAN: Object to form, vague and 8 indefinite. Last name, please. 9 MR. EDWARDS: You can answer, if you know. 10 THE WITNESS: 1 intend to respond to all 11 relevant questions regarding this lawsuit. 12 However, at the present time my attorneys have 13 counseled me that I cannot provide answers to 14 any questions relevant to this lawsuit. I must 15 accept this advice or risk losing my Sixth 16 Amendment right to effective representation. 17 Accordingly, I assert my Federal 18 Constitutional right as guaranteed by the 19 Fifth, Sixth, and Fourteenth Amendment to the 20 United States Constitution. 21 Q. (By Mr. Edwards) Between 2001 and 2005 22 did you engaga in sex or sex acts with a minor 23 female named (phonetic)? 24 MR. BURMAN: Object to form, vague and 25 indefinite. Last name, please. Page 38 1 MR. EDWARDS: You can answer. 2 THE WITNESS: I intend to respond to all 3 relevant questions regarding this lawsuit. 4 However at the present time my attorneys have 5 counseled me that I cannot provide answers to 6 any questions relevant to this lawsuit, and 7 must accept this advice or risk losing my Sixth 8 Amendment right to effective representation. 9 Accordingly, I assert my Federal 10 Constitutional right as guaranteed by the 11 Fifth, Sixth, and Fourteenth Amendment to the 12 United States Constitution. 13 Q. (By Mr. Edwards) Between 2001 and 2005 14 did you engage in sex or sex acts with a minor 15 female named (phonetic)? 16 MR. BURMAN: Object to form, vague and 17 indefinite. Last name, please. 18 MR. EDWARDS: You can answer. 19 THE WITNESS: i intend to respond to all 20 relevant questions regarding this lawsuit 21 However, at the present time my attorneys have 22 counseled me that I cannot provide answers to 23 any questions relevant to this lawsuit, and 24 must accept this advice or risk losing my Sixth 25 Amendment right to effective representation. 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 39 Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female that you referred to as (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. MR. BURMAN: Or flavor. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor Page 40 1 female named phonetic)? 2 MR. 13 : Object to form, vague and 3 indefinite. Last name, please. 4 MR. EDWARDS: You can answer. 5 THE WITNESS: I intend to respond to all 6 relevant questions regarding this lawsuit 7 However, at the present time my attorneys have 8 counseled me that I cannot provide answers to 9 any questions relevant to this lawsuit, and 10 must accept this advice or risk losing my Sixth 11 Amendment right to effective representation. 12 Q. (By Mr. Edwards) Between -- 13 THE WITNESS: Sorry? 14 MR. EDWARDS: I didn't realize you weren't 15 finished. 16 THE WITNESS: Accordingly, I assert my 17 Federal Constitutional right as guaranteed by 18 the Fifth, Sixth and Fourteenth Amendment to 19 the United States Constitution. 2 0 Q. (By Mr. Edwards) Between 2001 and 2005 21 did you in sex or sex acts witha 12-year-old 2 2 girl named onetic)? 23 MR B : Object to form, vague and 24 indefinite. Last name, please. 2 5 MR. EDWARDS: You can answer. 10 (Pages 37 to 4 0) PALM BEACH REPORTING SERVICE, INC. EFTA01103335 Page 41 1 THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit. 3 However, at the present time my attorneys have 4 counseled me that I cannot provide answers to 5 any questions relevant to this lawsuit, and 6 must accept this advice or risk losing my Sixth 7 Amendment right to effective representation. 8 Accordingly, I assert my Federal 9 Constitutional right as guaranteed by the 10 Fifth, Sixth, and Fourteenth Amendment to the 11 constitution. 12 Q. (By Mr. Edwards) Between 2001 and 2005 13 did you engage in sex or sex acts with a minor 14 female named (phonetic)? 15 MR. BURMAN: Object to form, vague and 16 indefinite. Last name, please. 17 MR. EDWARDS: You can answer. 18 THE WITNESS: I intend to respond to all 19 relevant questions regarding this lawsuit. 20 However, at the present time my attorneys have 21 counseled me that I cannot provide answers to 22 any questions relevant to this lawsuit. I must 23 accept their advice or risk losing my Sixth 24 Amendment right to effective representation. 25 Accordingly, I assert my Federal Page 42 1 Constitutional right as guaranteed by the 2 Fifth, Sixth and the Fourteenth Amendment to 3 the constitution. 4 Q. (By Mr. Edwards) Between 2001 and 2005 5 did you engage in sex or sex acts with a minor 6 female named =phonetic)? 7 MR. BURMAN: Object to form, vague and 8 indefinite. Last name, please. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit. 11 However, at the present time my attorneys have 12 counseled me that I cannot provide answers to 13 any questions relevant to this lawsuit, and 14 must accept their advice or risk losing my 15 Sixth Amendment right to effective 16 representation. 17 Accordingly, I assert my Federal 18 Constitutional right as guaranteed by the 19 Fifth, Sixth, and Fourteenth Amendment to the 20 United States Constitution. 21 Q. (By Mr. Edwards) Between 2001 and 2005 22 did you e in sex or sex acts with a minor 23 female (phonetic)? 24 MR. BURMAN: Object to form, vague and 25 indefinite. Lastname,please. Page 43 1 MR. EDWARDS: You can answer. 2 THE WITNESS: I intend to respond to all 3 relevant questions regarding this lawsuit. 4 However, at the present time my attorneys have 5 counseled me that I cannot provide answers to 6 any questions relevant to this lawsuit, and 7 must accept this advice or risk losing my Sixth 8 Amendment right to effective representation. 9 Accordingly, I assert my Federal 10 Constitutional right as guaranteed by the 11 Fifth, Sixth, and Fourteenth Amendment to the 12 United States Constitution. 13 Q. (By Mr. Edwards) Between 2001 and 2005 14 did you engage in sex or sex acts with a minor 15 female namedM (phonetic)? 16 MR. BURMAN: Object to form, vague and 17 indefinite. Last name, please. 18 MR. EDWARDS: You may answer. 19 THE WITNESS: I intend to respond to all 20 relevant questions regarding this lawsuit. 21 However, at the present time my attorneys have 22 counseled me that I cannot provide answers to 23 any questions relevant to this lawsuit, and 24 must accept this advice or risk losing my Sixth 25 Amendment right to effective representation. Page 44 1 Accordingly, I assert my Federal 2 Constitutional right as guaranteed by the 3 Fifth, Sixth, and Fourteenth Amendment of the 4 United States Constitution. 5 Q. (By Mr. Edwards) Between 2001 and 2005 6 did you engagejash or sex acts with a minor 7 female named .MA (phonetic)? 8 MR. BURMAN: Object to form, vague and 9 indefinite. Last name, please. 10 MR. EDWARDS: You can answer. 11 THE WITNESS: I intend to iespund to all 12 relevant questions regarding this lawsuit. 13 However, at the present time my attorneys have 14 counseled me that I cannot provide answers to 15 any questions relevant to this lawsuit, and I 16 must accept this advice or risk losing my Sixth 17 Amendment right to effective representation. 18 Accordingly, I assert my Federal 19 Constitutional right as guaranteed by the 20 Fifth, Sixth, and Fourteenth Amendment to the 21 United States Constitution. 22 MR. GOLDBERGER: One moment 23 (Thereupon, a discussion was had off 24 the record.) 25 ,..,11LaoheresAttorney Adler entered 11 (Pages 41 to 44) PALM BEACH REPORTING SERVICE, INC. EFTA01103336 Page 45 1 the deposition room) 2 MR. EDWARDS: We're back on. 3 Q. (By Mr. Edwards) Between 2001 and 2005 4 did you enpgsm sex or sex acts with a minor 5 female named (phonetic)? 6 MR. BURMAN: Object to form, vague and 7 indefinite. Last name, please. 8 MR. EDWARDS: You can answer. 9 THE WITNESS: I intend to respond to all 10 relevant questions regarding this lawsuit. 11 However, at the present time my attorneys have 12 counseled me that I cannot provide answers to 13 any questions relevant to this lawsuit, and 14 must accept this advice or risk losing my Sixth 15 Amendment right to effective representation. 16 Accordingly, I assert my Federal 17 Constitutional right as guaranteed by the 18 Fifth, Sixth, and Fourteenth Amendment to the 19 constitution. 20 Q. (By Mr. Edwards) Between 2001 and 2005 21 did you engage in sex or sex acts with a minor 22 female named phonetic)? 23 MR. BURMAN: Object to form, vague and 24 indefinite. Last name, please. 25 MR. EDWARDS: You may answer. 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 Page 47 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named (phonetic)? MR. BURMAN: Object to the form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named 111.111(phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. Page 46 1 THE WITNESS: I intend to respond to all 2 relevant questions regarding this lawsuit. 3 However, at the present time my attorneys have 4 counseled me that I cannot provide answers to 5 any questions relevant to this lawsuit, and 6 must accept this advice or risk losing my Sixth 7 Amendment right to effective representation. 8 Accordingly, I assert my Federal 9 Constitutional rights as guaranteed by the 10 Fifth, Sixth, and the Fourteenth Amendment to 11 the United States Constitution. 12 Q. (By Mr. Edwards) Between 2001 and 2005 13 did you engage in sex or sex acts with a minor 14 female named phonetic)? 15 MR BURMAN: Object to form, vague and 16 indefinite. Last name, please. 17 MR. EDWARDS: You may answer. 18 THE WITNESS: I intend to respond to all 19 relevant questions regarding this lawsuit. 20 However, at the present time my attorneys have 21 counseled me that I cannot provide answers to 22 any questions relevant to this lawsuit, and I 23 must accept this advice or risk losing my Sixth 24 Amendment right to effective representation. 25 Accordingly. I assert my Federal 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 Page 48 MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named phonetic)? MR. BURMAN Object to form, vague and indefinite. And last name, please? MR. GOLDBERGER: Is that or IIIIIIP MR. EDWARDS: — dra. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and 12 (Pages 45 to 48) PALM BEACH REPORTING SERVICE, INC. EFTA01103337 P