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- only area that the witness was precluded
- from talking about in the first
- deposition. So that’s where we’re at.
- MR. BOIES: I think that directly misreads the judge’s order, including where it says: Defendant is ordered to answer questions relating to defendant’s own sexual activity with or involving Jeffrey Epstein, with or involving plaintiff, with or involving underage females, involving or including massage with individuals defendant knew to be or believed might become known to Epstein.
- MR. PAGLIUCA: All of it is preceded by the word sexual activity.
- MR. BOIES: I think your point of view is an interesting one, but we will see what the judge rules on it.
BY MR. BOIES:¶
- Q. The women that you have described as joining you and Mr. Epstein in three-way sexual activities, were these people who you believed were professional masseuses?
- MR. PAGLIUCA: Objection to form
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| 2 | and foundation. |
| 3 | A. No. |
| 4 | Q. Did any of the women that you have said engaged with you and Mr. Epstein in three-way sexual activities give Mr. Epstein massages? |
| 5 | MR. PAGLIUCA: Objection to form and foundation. |
| 6 | A. I don't know. |
| 7 | Q. Did any of them give you massages? |
| 8 | A. No. |
| 9 | Q. Did you engage in any sexual activities with either of these two people that you've identified as the blond and the brunette in the Virgin Islands? |
| 10 | MR. PAGLIUCA: Objection to form and foundation. Asked and answered. |
| 11 | A. No. |
| 12 | Q. Were they ever in the Virgin Islands? |
| 13 | MR. PAGLIUCA: Objection to form and foundation. |
| 14 | A. No. |
| 15 | Q. Did you ever see any of the women |
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| 2 | with whom you and Mr. Epstein engaged in three-way sexual activities outside of Mr. Epstein's Palm Beach home? |
| 3 | A. Not that I recall. |
| 4 | Q. Had you met either of them prior to the time that you and Mr. Epstein engaged in the three-way sexual activities with them? |
| 5 | A. I don't recall. |
| 6 | Q. Had you met them before the date, is what I'm asking you? |
| 7 | MR. PAGLIUCA: You already asked that and she answered it. |
| 8 | A. I don't recall. |
| 9 | Q. When you and Mr. Epstein were engaged in sexual activity that included these other women, were any devices or sex toys used as part of the sexual activity? |
| 10 | A. No. |
| 11 | Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? |
| 12 | MR. PAGLIUCA: Objection to form and foundation. |
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| A. | No. |
| Q. | Were you ever involved in sexual activities in any of Mr. Epstein's properties other than Palm Beach that included the use of sex toys or any kind of mechanical or other device? |
| A. | No. |
| Q. | Were you aware of the presence of sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house? |
| MR. PAGLIUCA: Objection to form and foundation. | |
| A. | No, not that I recall. |
| Q. | Were you aware that there were sex toys or devices used in sexual activities in Mr. Epstein's New York house? |
| A. | No. |
| Q. | Were you aware that there were sex toys or devices used in sexual activities in Mr. Epstein's property in the Virgin Islands? |
| MR. PAGLIUCA: Objection to form and foundation. | |
| A. | No. |
| Q. | Were you aware whether or not there |
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were sex toys or devices used in sexual activities in Mr. Epstein’s property in the Virgin Islands?¶
MR. PAGLIUCA: Objection to form and foundation.¶
A. No.¶
Q. Do you know whether Mr. Epstein possessed sex toys or devices used in sexual activities?¶
MR. PAGLIUCA: Objection to form and foundation.¶
A. No.¶
Q. Did you ever assist Mr. Epstein in obtaining sex toys or devices used in sexual activities?¶
MR. PAGLIUCA: Objection to form and foundation.¶
A. No.¶
Q. In the 1990s and 2000s, did you ever have possession of or use sex toys or devices used in sexual activities?¶
A. No.¶
Q. Did you, in the 1990s and 2000s, engage in sexual activities other than¶
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intercourse with women other than what you have testified to already?¶
MR. PAGLIUCA: First of all, I object to the form and foundation and it’s also outside of the court’s order because it’s unclear as you question, and I specifically direct you to the last line of the court’s order: Sexual activity of third parties who bear no knowledge or relation to key events, individuals or locations in this case.¶
MR. BOIES: This simply asks yes or no, and I think that it is an appropriate question given some of the witness’ prior answers, but there is no point in debating it, because if you instruct her not to answer, the judge will decide whether it’s appropriate.¶
MR. PAGLIUCA: I’m just telling you if you tie it to something in this case, I will let her answer.¶
MR. BOIES: Are you instructing her not to answer?¶
MR. PAGLIUCA: Yes, unless you tie¶
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it to something in the case.¶
MR. BOIES: I think it’s tied, but if you instruct her not to answer, it goes into the —¶
MR. PAGLIUCA: Meat grinder.¶
BY MR. BOIES:¶
Q. At any time in any of Mr. Epstein’s properties, did you engage in sexual activities with any woman other than when you had three-way sexual activities with Mr. Epstein?¶
MR. PAGLIUCA: Object to the form.¶
A. Can you repeat the question?¶
Q. At any time, in any of Mr. Epstein’s properties, did you engage in sexual activities with any woman other than when you had three-way sexual activities with Mr. Epstein?¶
MR. PAGLIUCA: Same objection.¶
A. No.¶
Q. Other than yourself and the blond and brunette that you have identified as having been involved in three-way sexual activities, with whom did Mr. Epstein have¶
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sexual activities?¶
MR. PAGLIUCA: Objection to form and foundation.¶
A. I wasn’t aware that he was having sexual activities with anyone when I was with him other than myself.¶
Q. I want to be sure that I’m clear.¶
Is it your testimony that in the 1990s and 2000s, you were not aware that Mr. Epstein was having sexual activities with anyone other than yourself and the blond and brunette on those few occasions when they were involved with you?¶
A. That is my testimony, that is correct.¶
Q. Do you remember testifying earlier today that Mr. Epstein had, on a number of occasions, tried to have you join in three-way sexual activities with women other than the blond and brunette that you identified?¶
MR. PAGLIUCA: Objection to form and foundation.¶
A. I don’t know who he was wanting me¶
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to have a three-way with. It was in general he wanted to have a three-way. It was nothing specific talked about.¶
Q. Is it your testimony that other than the blond and brunette that you have referred to, you don’t know of any particular person with whom he wanted you and he to have sex with?¶
A. Correct.¶
Q. But he talked to you generally about wanting to do that?¶
A. Correct.¶
Q. And it is your testimony that you believed that you were the only person that he was having sex with or engaging in sexual activities with other than on these few occasions, this blond and brunette, is that correct?¶
MR. PAGLIUCA: Object to the form.¶
Asked and answered.¶
A. That’s what I said.¶
Q. Is that still what you say?¶
A. Yeah, that is still what I say.¶
Q. Do you know the reporter by the¶
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| 2 | ever see |
| 3 | A. I don't recall ever seeing her. |
| 4 | Q. Did ever engage in any sexual activity with you? |
| 5 | A. No. |
| 6 | Q. Did ever engage in any sexual activity with Mr. Epstein? |
| 7 | A. I wouldn't know. I would assume not, but I don't know. |
| 8 | Q. Do you have any reason to believe that Mr. Epstein engaged in any sexual activity with |
| 9 | MR. PAGLIUCA: Objection to form and foundation. |
| 10 | A. I wouldn't know. |
| 11 | Q. Did you ever give a massage to anyone other than Mr. Epstein at any of Mr. Epstein's properties? |
| 12 | A. First of all, I never said I gave Mr. Epstein a massage. |
| 13 | Q. I will ask that question if you want, but I was focusing on people other than Mr. Epstein right now. |
| 14 | A. I don't give massages. |
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Q. Let’s just tie that down. It is your testimony that you’ve never given anybody a massage?¶
A. I have not given anyone a massage.¶
Q. You never gave Mr. Epstein a massage, is that your testimony?¶
A. That is my testimony.¶
Q. You never gave a massage is your testimony?¶
A. I never gave a massage.¶
Q. Did you, or to your knowledge, Mr. Epstein pay for to go to Thailand?¶
MR. PAGLIUCA: Objection to form and foundation.¶
A. I am not aware.¶
Q. Do you know whether went to Thailand?¶
A. I have no knowledge of anything like that.¶
Q. Did you ever give anyone instructions as to how to give a massage?¶
MR. PAGLIUCA: Objection to form¶
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closed.¶
If there are questions that I have instructed the witness not to answer and it later turns out the judge disagrees with my characterization, we will be back to revisit it, but we are done as far as I’m concerned.¶
MR. BOIES: The deposition is not closed. There are a number of instructions not to answer. I think it is a fair point that if the court were to conclude that none of the questions that have been instructed need to be answered, we’re not going to be continuing the deposition, barring some additional information coming to light.¶
MR. PAGLIUCA: I think we agree then.¶
THE VIDEOGRAPHER: The time is 2:51 p.m., and we are going off the record.¶
(Time noted: 2:51 p.m.)¶
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