09-22783 ## Original Transcript # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, vs. Case No. 08-80893- CIV-MARRA/JOHNSON JEFFREY EPSTEIN, Defendant. ## DEPOSITION OF MARK EPSTEIN September 21, 2009 11:30 a.m. One Penn Plaza, New York, New York Jacklyn Lisi | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | ESQUIRE an Alexander Gallo Company Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181510 EFTA00181511 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 1 JANE DOE, Plaintiff, vs. Case No. 08-80893- CIV-MARRA/JOHNSON JEFFREY EPSTEIN, Defendant. DEPOSITION of MARK EPSTEIN, taken by Defendants, at the offices of Esquire Deposition Solutions, One Penn Plaza, New York, New York 10119, on Monday, September 21, 2009, commencing at 11:30 a.m., before Jacklyn Lisi, a Shorthand Reporter and notary public, within and for the State of New York. | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181512 Mark Epstein September 21, 2009 A P P E A R A N C E S: ROTHSTEIN ROSENFELDT ADLER, ESQS. Attorneys for Plaintiffs, EW, LM and Jane Doe Las Olas City Centre, Suite 1650 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 BY: BRAD J. EDWARDS, ESQ. LEOPOLD KUVIN, ET AL Attorneys for Plaintiff, BB 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 BY: ADAM LANGINO, ESQ. (via telephone) COHEN & GRESSER, LLP Attorneys for the Witness, Mark Epstein 100 Park Avenue New York, New York 10017 BY: MARK S. COHEN, ESQ. ALEXIS G. STONE, ESQ. PODHURST ORSECK, et al Attorneys for Plaintiffs, Jane Does 101 and 102 25 West Flagler Street, Suite 800 Miami, Florida 33130 BY: KATHERINE EZELL, ESQ. (via telephone) MERMELSTEIN & HOROWITZ, ESQS. Attorneys for Plaintiffs, Jane Does 2 through 8 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 BY: ADAM H. HOROWITZ, ESQ. (via telephone) | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181513 Mark Epstein September 21, 2009 A P P E A R A N C E S (continued) RICHARD H. WILLITS, ESQ. Attorney for Plaintiff, 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 (via telephone) BURMAN, CRITTON, LUTTIER & COLEMAN, LLP Attorneys for the Defendant, Jeffrey Epstein 515 North Flagler Drive, Suite 400 West Palm Beach, Florida 33401 BY: ROBERT CRITTON, ESQ. (via telephone) Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181514 Mark Epstein September 21, 2009 4 STIPULATIONS IT IS HEREBY STIPULATED, by and between the attorneys for the respective parties hereto, that all rights provided by the C.P.L.R., and Part 221 of the Uniform Rules for the Conduct of Depositions, including the right to object to any question, except as to form, or to move to strike any testimony at this examination is reserved; and in addition, the failure to object to any question or to move to strike any testimony at this examination shall not be a bar or waiver to make such motion at, and is reserved to, the trial of this action. This deposition may be sworn to by the witness being examined before a Notary Public other than the Notary Public before whom this examination was begun, but the failure to do so or to return the original of this deposition to counsel, shall not be deemed a waiver of the rights provided by Rule 3116 of the C.P.L.R. and shall be controlled thereby. The filing of the original of this deposition is waived. Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181515 Mark Epstein September 21, 2009 M. Epstein THE REPORTER: Please state your name and address for the record? THE WITNESS: (Witness refused to give his address to the court reporter.) MR. COHEN: On the record. For the witness, Mark Epstein, Mark Cohen and Alexis Stone of Cohen & Gresser, 100 Park Avenue, New York, New York. MR. EDWARDS: Brad Edwards on behalf of EW, LM and Jane Doe. MR. CRITTON: Robert Critton on behalf of Jeffrey Epstein. MS. EZELL: Kathy Ezell on behalf of Jane Does 101 and 102. MR. HOROWITZ: Adam Horowitz on behalf of Plaintiffs, Jane Does 2 through 8. MR. WILLITS: Richard Willits on behalf of [blank]. MR. LANGINO: Adam Langino on behalf of Plaintiff, BB. MR. EDWARDS Okay. That's everybody. MR. COHEN: Okay. Before I start, this is Mark Cohen on behalf of Mark Epstein, I just want to put on the record the details | | | | :--- | :--- | | Toll Free: | 800.211.3376 | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181516 Mark Epstein September 21, 2009 ## M. Epstein of a conversation I've had with Mr. Edwards and make sure that all counsel is agreeable to this. My client, Mark Epstein, is very concerned about being videotaped and having his image recorded. He is concerned about possible future uses of his image. And so Mr. Edwards and I have agreed that this recording, the videotape of my client, will be confidential and will not be revealed in public unless and until there is an order by a court in one of the cases that are involved in these depositions that orders that the video be made public. We are prepared to proceed on that basis. As I understand, Mr. Edwards is prepared to proceed, but obviously we need the agreement of all counsel. MR. WILLITS: Richard Willits agrees. MR. CRITTON: Robert Critton agrees. MS. EZELL: Kathy Ezell agrees. MR. EDWARDS: Adam? MR. HOROWITZ: Adam Horowitz, that's | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181517 Mark Epstein September 21, 2009 ## M. Epstein fine. MR. LANGINO: The same with Adam Langino, that's fine. MR. EDWARDS And Sid Garcia is not in and he is not supposed to be in; right? I assume -- I don't know whether he was going to come or not, but I assume that everyone will also abide and not give Mr. Garcia a copy of the video until he also affirms in writing to Mr. Cohen that he's agreed to be bound by the same agreement. MR. EDWARDS: Okay. THE VIDEOGRAPHER: This is tape number one to the videotape deposition of Mark Epstein in the matter of Jane Doe versus Jeffrey Epstein being held before the United States District Court in the Southern District of Florida, case file number 08-80893. This deposition is being held at Esquire Deposition Solutions, One Penn Plaza, New York, New York on September 21, 2009. The time is 11:41 a.m. | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181518 Mark Epstein September 21, 2009 M. Epstein My name is Peter Ledwith. I'm the videographer. The court reporter is Jackie Lisi. Counsel, will you please introduce yourselves and who you represent? MR. EDWARDS: Brad Edwards. I represent EW, LM and Jane Doe. MR. COHEN: Mark Cohen and Ally Stone. I represent the witness, Mark Epstein. MR. CRITTON: Robert Critton on behalf of the defendant, Jeff Epstein. MR. WILLITS: Richard Willits on behalf of [blanked out]. MR. LANGINO: Adam Langino on behalf of Plaintiff BB. MR. HOROWITZ: Adam Horowitz on behalf of plaintiffs Jane Does numbers 2 through 8. THE VIDEOGRAPHER: Will the court reporter please swear in the witness? MARK EPSTEIN, having been first duly affirmed, was examined and testified as follows: THE WITNESS: I am an atheist, but I | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181519 Mark Epstein September 21, 2009 9 ## M. Epstein will affirm I'll tell the truth. EXAMINATION BY MR. EDWARDS: Q. Can you tell us your name? A. Mark Epstein. THE VIDEOGRAPHER: Can you put the microphone on your shirt, please? THE WITNESS: Mark Epstein. Q. Okay. And your date of birth, please? A. July 14, 1954. Q. And what is your relationship with the defendant in this case, Jeffrey Epstein? A. He is my brother. Q. Are you currently married? A. No. Q. What is your current address? A. I'm not giving out my address. I'm concerned about my personal safety because of the nature of this case. You can use his address. You can use my attorney's address. Q. Please elaborate on that for me that you are concerned for your safety because of the nature of this case? | | | | :--- | :--- | | Toll Free: | 800.211.3376 | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181520 Mark Epstein September 21, 2009 ## M. Epstein 10 A. Because I've read -- well, I know that Jeffrey hired a detective or someone from the police when he went out on his days out. So obviously there is probably a concern for safety. I don't want anything to do with this case. I have nothing to do with this case. I don't want my identifying information on any kind of public record. MR. COHEN: If it will make it easier, Mr. Edwards, this is Mark Cohen speaking. Mr. Mark Epstein is authorizing my firm to accept service if there is a future subpoena or a need to contact him again. THE WITNESS: Before we go on, I want to make a statement. I want to say on the record that initially I was improperly served with a subpoena from Florida, it was supposed to come from New York. It also did not include the required documents giving me my rights and obligations under the Florida laws. So it's a breach of some kind of ethics. Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181521 Mark Epstein September 21, 2009 M. Epstein So in my book, you are either incompetent, devious or have no ethical compass. So you are not on my high list. Continue with your questions. I just wanted a record of that. MR. CRITTON: Brad, can you move the phone a little closer to Mr. Epstein? I heard you and I heard Mr. Cohen fine, but I'm having trouble with Mr. Epstein. MR. EDWARDS: All right. MR. CRITTON: Thank you. MR. EDWARDS: I apologize for your feelings about the subpoena. THE WITNESS: Not accepted. This is too serious of a matter. BY MR. EDWARDS: Q. You do realize that you are subpoenaed to testify today in cases that involve your brother having sex or engaging in sex acts with minors; correct? MR. CRITTON: Form? MR. COHEN: That's -- A. I know there is a case against my | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181522 Mark Epstein September 21, 2009 12 ## M. Epstein brother. I know that. Q. And you are aware that there are multiple attorneys on the phone that represent girls who were under-age when Mr. Epstein had sex with them? A. I know there are multiple attorneys on the phone. Q. Okay. Have you read the newspaper articles about your brother that detail your brother having sex with under-age girls? MR. CRITTON: Form. A. I've read some of the papers. Q. You agree that sex with minors is wrong? MR. CRITTON: Form. MR. COHEN: Objection. Q. You can answer. A. I have no opinion on that. Q. Okay. A. I'm not here to give opinions. I'm here for facts. So ask me questions about facts and I'll be glad to answer them. Q. Well, do you agree with the laws that protect under-age children from adult sexual | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181523 Mark Epstein September 21, 2009 13 ## M. Epstein ## predators? MR. COHEN: Objection. MR. CRITTON: Form. A. My information on the case is my brother I know had to spend sometime in jail for some prostitution charge. So I assume the attorneys are representing the prostitutes he was involved with, so I don't know what the ages of them are or were. I'm not involved with the case. I don't watch all the details about it. That's all. Q. Would it surprise you to learn that there were more than 30 girls between the ages of 12 and 15 that your brother engaged in sex acts with? MR. CRITTON: Form. A. I don't get surprised by very many things in this world. Q. But you and your brother are a year apart; right? A. 18 months. Q. And you grew up together? | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181524 Mark Epstein September 21, 2009 14 ## M. Epstein A. Sure. Q. You still talk to him? A. Occasionally, rarely. Q. So when I ask you, does it surprise you, you are saying that it doesn't surprise you that your older brother engaged in sex with more than 30 girls between 12 and 15 years old? MR. COHEN: Objection. MR. CRITTON: Form. A. I don't know how to answer that question. I don't know if it's true, and I don't know what the story is. It's not -- ask me a question about facts. I'm not going to give you opinions here, that's not what I'm here for. Q. Do you have children? A. Yes, I do. Q. How old? A. Seven and five. Q. Boys or girls? A. What does my children have to do with this? Leave my family out of this, please. Q. I think it's a fair question. | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181525 Mark Epstein September 21, 2009 ## M. Epstein A. I think it's a fair answer. Q. I need an answer. A. You got one. Q. Boys or girls? A. Next question. MR. EDWARDS: Counsel? MR. COHEN: I would suggest you move to an area that's likely to lead to you gathering relevant evidence. We can come back to this burning question maybe later. THE COURT REPORTER: I can't hear you. MR. CRITTON: Let me also add that I can only object to form, but I also want to put on the record, other than his name and he is related to Mr. Epstein, there is not one piece of evidence or -- MR. CRITTON: I'm sorry. I just want to note for the record that other than his name and his relationship to Mr. Epstein, to Jeffrey Epstein, there has been nothing of relevance or materiality that would lead to admissible evidence at the time of trial. Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181526 Mark Epstein September 21, 2009 16 This is being done to harass or humiliate Mr. Mark Epstein and/or my client. It certainly borders on that, but he is not an expert, his opinions are irrelevant in this case, and as is his own family situation but -- MR. EDWARDS: Mr. Critton, as you stated first, I think that your objection is limited to the form. Thanks. Can I mark this as an exhibit? (Plaintiff's Exhibit 1 was so marked for identification.) MR. COHEN: I will say that I join in Mr. Critton's objection for the record. BY MR. EDWARDS: Q. How frequently do you talk with your brother now? A. Maybe once every couple of weeks or so, but "now" being just the last month or two. Q. Okay. When you first learned of a criminal investigation into your brother, did you talk to him about the substance of those allegations? | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181527 Mark Epstein September 21, 2009 17 ## M. Epstein A. No. Q. Have you ever asked him or had a conversation with him about the allegations that he's had sex with numerous under-age kids? A. No. Q. Is there a reason why you wouldn't ask him questions about him engaging in sex with 13, 14-year old kids? A. We are not very close. We don't talk very often. MR. CRITTON: Form. Q. But when you do talk to him, that conversation doesn't come up? A. No. Q. He went to jail. Did he ever tell you why he went to jail? A. No. Q. Are you familiar with the property at 301 East 66th Street? A. Yes, I am. Q. Who owns that property? A. Dara Partners. Q. And what is Jeffrey Epstein's | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181528 Mark Epstein September 21, 2009 18 affiliation with that property? A. He rents some apartments in there. Q. How many apartments does Jeffrey Epstein rent at 301 East 66th Street? A. It's either 8 or 10, I am not sure. Q. Who are the residents of the apartments that Jeffrey Epstein rents at that location? A. I have no idea. MR. CRITTON: Brad, what was the answer to the last one? MR. COHEN: He has no idea. A. I know his pilots used to stay there, but I don't think he is using pilots any more. Q. Why does he rent so many places at the same location? A. I have no idea. Q. Have you ever had any affiliation with that location? A. Sure. Q. In what way? A. I'm one of the partners of Dara Partners. Q. So does your brother rent from you? | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181529 Mark Epstein September 21, 2009 19 ## M. Epstein A. No, he rents from Dara Partners. My partner handles that property, I don't know any of the tenants in that building other than one or two. Q. What are the names of the one or two that you do know? A. It is my ex, so I'm not going to give you her name. Q. Is that somebody who lives in one of the places rented by your brother Jeffrey Epstein? A. No. Q. Do you know any of the tenants that live in the places rented by your brother, Jeffrey Epstein? A. No. Q. Do you know ___? A. I know the name. I don't know her. Q. Do you know what her relationship is to your brother? A. I think she worked for him. Q. In what capacity? Q. Do you know if she lives in 301 East | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181530 Mark Epstein September 21, 2009 20 M. Epstein 66th Street? A. I don't know where she lives. Q. Would you know her if you saw her? A. No. Q. You've never seen her before? A. I might have seen her somewhere, I don't know. Q. Have you ever talked to her? A. I don't recall talking to her. Q. Do you know [___]? A. I know of her. Q. How do you know of her? A. In the papers. Q. What papers? A. Newspapers. I read some articles. Q. Newspapers about your brother? A. Relating to his case, yes. Q. Okay. And what is your understanding of her relationship with your brother? A. I don't have an understanding about it. MR. CRITTON: Form. A. My brother and I do not have a close relationship, so what he does is his business Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181531 Mark Epstein September 21, 2009 21 ## M. Epstein and what I do is my business. We don't communicate back and forth about our personal lives very often. I talk to him to find out if he is well. That's all I need to know. Q. Does he tell you that he is well these days? A. Yes. Q. Do you know what his future plans are in terms of where he intends to live once he is off probation or house arrest? A. I have no idea. Q. Is that a topic that you would ever talk to him about? A. No. Q. So what is it that you talk to him about when you call? A. See how he is doing, see if he is okay. Q. Does he call you as well? A. Sometimes. Q. What is his telephone number? Q. What are the telephone numbers that Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181532 Mark Epstein September 21, 2009 22 ## M. Epstein you reach him at? A. A lot of times I call his office and I have them tell him to call me. Q. What is his office number? Q. Who do you speak to at his office? A. Whoever answers the phone. Q. Do you know any of the people in his office that typically answer the phone? A. Some. Q. Who are you familiar with there? Q. Darren Indyke? A. Darren. An attorney, Darren. A. Yes. Q. So normally the way that you get in touch with your brother is to call his office and they forward you on to him? A. No, I tell them to have him call me. Well, sometimes, I mean I've called him directly too, but most of the time he is not there so it's easier just to leave a message to have him call me. Q. Well, these days now that he is on house arrest, normally if you called him he'd | | | | :--- | :--- | | Toll Free: | 800.211.3376 | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181533 Mark Epstein September 21, 2009 23 ## M. Epstein be there, right? A. I don't know the term house arrest. I don't know if he'd be there or not. And if I called there and sometimes he doesn't answer or the phone doesn't get answered, so I don't know where he is. Q. What's the number that you would call to reach him? Q. Is it your understanding that is a cell phone or is that the land line? A. I thought it was a land line. Q. And what is your telephone number? A. I'm not giving you any identifying information. MR. EDWARDS: We can come back to that? MR. COHEN: Why don't we come back to that. MR. EDWARDS: Okay. Q. Are you familiar with your brother's businesses? | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181534 Mark Epstein September 21, 2009 24 ## M. Epstein Jean Luc Brunel? A. No. Q. How often are you at the property at 301 East 66th Street? A. I pick up my children there sometimes. Maybe -- well, actually, they are in school now so I'm not there that often, because I pick them up at school. During the summers I would pick them up there once a week. Q. Is that where the subpoena was served on you? A. No, the subpoena was served on me in the street of New York. Q. Near that building? A. No. Q. No where near that building? A. It was in The City of New York, it depends on what you mean by "near." Q. Have you been to your brother's house in New York? A. Yes. Q. How many occasions? A. Under five. | | | | :--- | :--- | | Toll Free: | 800.211.3376 | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181535 Mark Epstein September 21, 2009 25 ## M. Epstein Q. Have you been to your brother's house in Palm Beach? A. When. Q. Ever? A. Yes. Q. How many occasions? A. Probably dozens. Q. When is the last time you were there? A. Probably about a decade ago. I was outside once more recently than that. During one of the hurricanes, he asked me to take a look at the property, but I did not go in. Q. Why not? A. There was no inside damage. I went to see the property just to see if there was damage to the property. I was in Florida at the time. Q. Why has it been more than 10 years since you've been to that property? A. My brother and I are not very close. Q. What is the reason why you are not very close? A. We just went our own ways. | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181536 Mark Epstein September 21, 2009 ## M. Epstein 26 Q. Does it have to do with the fact that he likes under-age girls and engages in that type of illegal activity? A. I'm not going to make that assumption, but it has nothing do with anything like that. We just went our own ways. Different interests, different things. Q. Knowing your brother, if when your children are 13, 14 years old, would you let them alone with him? MR. COHEN: Objection. MR. CRITTON: Form. A. Yes, I would. Q. Do you know anything about Jean Luc Brunel? A. I never heard the name before. You just mentioned it before. Q. Are you familiar with the modeling agency MC Squared? A. No. Q. Do you know if your brother has any involvement with that modeling agency? | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181537 Mark Epstein September 21, 2009 27 ## M. Epstein A. No. Q. It goes back to you not being that close with your brother? A. We don't talk about business. He doesn't tell me about his business and I don't ask. Q. Are you aware that your brother is friendly or friends with David Copperfield? A. No. The magician? Q. Right. A. I have no idea, no. Q. Do you know any common interest that he shares with David Copperfield? A. Magic? I have no idea. Q. Does your brother do magic? A. I have no idea. MR. CRITTON: Form. Q. There is evidence in this case that David Copperfield was at your brother's house on occasions with under-age girls. Were you ever there then? A. No. MR. CRITTON: Form. | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181538 Mark Epstein September 21, 2009 28 ## M. Epstein Q. There will also be evidence in this case that your brother and Jean Luc Brunel were involved sexually with minors in your brother's house. Were you ever there then? MR. CRITTON: Form. A. No. When? When did this take place? Q. Any of the times that your brother and Jean Luc Brunel were in the same house. A. What time period is that? Q. Between 2000 and 2005. A. I already told you I haven't been there for over a decade. So use your fucking head and realize that I wasn't there. Next question. Q. When was the last time you were in the New York house? A. When my mother was still alive. So it's got to be over five years ago, I think. Q. All right. I'm going to go back to a time that you are more familiar with your brother. Where did you grow up? | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181539 Mark Epstein September 21, 2009 29 ## M. Epstein A. Coney Island, Seagate, in Brooklyn. Q. And did you go to the same school as your brother then? A. Yes. Q. What schools were those? A. P.S. 188 for elementary school, Mark Twain Junior High School and Lafayette High School. Q. And at Lafayette High School, were you familiar with any of your brother's girlfriends? A. Probably. I don't remember who they were. I don't remember my own girlfriends from high school. Q. Did your brother ever have boyfriends at that age? MR. CRITTON: Form. A. What do you mean by boyfriends? You mean friends that were boys? Q. No, I mean was he sexually involved with boys in high school? A. No, not that I know of. MR. COHEN: Objection. MR. CRITTON: Form. | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181540 Mark Epstein September 21, 2009 ## M. Epstein 30 Q. Do you know of your brother to engage in homosexual sex? A. No, I don't. MR. CRITTON: Form. MR. COHEN: Objection. Q. Do you know Leslie Wexner? A. I never met him, but I knew of him. Q. How do you know him? A. He is a public figure. He owns The Limited. Q. Have you ever been told that your brother and Leslie Wexner have a long time sexual relationship? Q. That's not something your brother's ever told you? MR. CRITTON: Form. Q. I know you said that you and your brother don't talk about business much. Do you talk about his girlfriends, boyfriends, sex life, anything like that? Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181541 Mark Epstein September 21, 2009 31 M. Epstein A. No. Q. Have you ever worked with your brother? A. No. Q. After high school, where did your brother go? A. To school, you mean? Q. Sure. A. Cooper Union. Q. And do you know what he studied there? A. He majored in physics, I think. Q. Did he graduate? A. No. No. Q. After Cooper Union, where did he go? A. NYU, The Courant Institute. It's the math graduate program there. Q. Do you know what he studied there? A. It's the math graduate program there. He studied mathematics. Q. Did he graduate from NYU? A. Not that I know of. Q. Do you know where he went after NYU? A. Home. Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181542 Mark Epstein September 21, 2009 32 ## M. Epstein Q. For how long? A. What do you mean where did he go after? I don't understand your question. Q. Did he go to work? Did he stay in school; masters, doctorate program? A. He went to work. Q. Where did he go to work? A. He started teaching, I don't know if it was immediately after, but I know he was teaching for a while. Q. Where did he teach? A. Dalton. Q. Was that a high school? A. I'm not sure what year it starts. It might be K through 12. I don't know what Dalton is. Q. By this point in time in your brother's life, your life, were you already going your separate ways or were you still -- A. No, we were still close then. Q. You were close with your brother through high school and at least up to the point we are now at when your brother left NYU and he started working at Dalton? | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181543 Mark Epstein September 21, 2009 33 ## M. Epstein A. Yes. Q. What was he doing in terms of at Dalton, was he a math teacher, a piano teacher? A. Math teacher, I believe. Q. Did you ever know him to teach piano? A. No. At Dalton? Q. Right. A. I don't know. Q. Okay. A. He plays very well. I don't know if he taught it. Q. See we can only go off of what we read in the papers too. A. Okay. Q. How long was he at Dalton, to your knowledge? A. A couple of years or so. I don't know. Q. All right. And what was his next employment after Dalton? A. I think he went to Bear Stearns. Q. Do you know how he got that job at Bear Stearns? Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181544 Mark Epstein September 21, 2009 34 ## M. Epstein A. Yeah. He met, what's his name? Ace Greenberg, who was, I think the number 2 guy at Bear Stearns at the time. And my brother was hired to help them set up their options departments. They were just getting involved with options, as far as I remember. Q. All right. How long was he at Bear Stearns? A. A few years. Q. What year did your brother graduate high school? A. I got out in '71, so I guess he got out in '69, I think. Q. From Lafayette? A. Yes. Q. Do you know what year it was that he first started at Bear Stearns? A. Somewhere around '76. Q. Do you know why it is he left Bear Stearns? A. No. Q. Did you talk to him much while he was at Bear Stearns? Were you still close then? | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181545 Mark Epstein September 21, 2009 35 ## M. Epstein A. Pretty much, yes. Q. And, I'm sorry, did you know what year he left Bear Stearns? A. No. Around what year he left? No. Q. Do you know about how long he worked there, five years? A. A few years is the closest I can tell you. Q. I know you told us what he did when he started. Do you know what he was doing when he finished? A. No. Q. Were you aware of any problems that he had at Bear Stearns? A. No. Q. Were you aware of any insider-trading investigation involving -- or where your brother was a witness at Bear Stearns? A. No. Q. And do you know why it is that your brother left Bear Stearns? A. No. Q. Do you know where he went to work after he left Bear Stearns? | | | | :--- | :--- | | Toll Free: | 800.211.3376 | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181546 Mark Epstein September 21, 2009 36 ## M. Epstein A. I know for a while he was working on his own going after insider-trading, and also recouping money for people. Q. Okay. What does that mean? Just elaborate? A. Well, there were people who got burnt by brokers who were doing -- there were a lot of insider-trading things going on. And a lot of investors got burnt. And my brother was working with an attorney, and they were going after the brokers and trying to recoup money for the investors that got burnt. Q. Was he also working for the federal government to recover money for the government as well? A. I have no idea. Q. He never told you that? A. No. Q. Do you know what companies he was working for to recover money? A. I think he was working for himself. Q. Do you know what the company was called? | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181547 Mark Epstein September 21, 2009 37 ## M. Epstein A. No. Q. Do you know how long he had that company open? A. No. Q. Was it a successful company? A. I think so. Q. Where is the next place he went? A. I don't know if he ever worked for anybody else except for himself after that. Q. All right. What is the next endeavor that he pursued then? A. He was just -- had the company he had, I guess. Managing money, as far as I know. Q. Okay. But managing money is something different than being a money bounty hunter? A. Well, after the bounty hunter he was working managing money for people. That's all. Q. Do you know how he started that company? A. No, I don't. Q. Were you still close with him then? Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181548 Mark Epstein September 21, 2009 38 ## M. Epstein A. Not as, but we were still kind of close. We didn't talk business. I had my businesses, which kept me very busy, and he had his. And when we'd talk, a lot of our conversations had to do with our parents. We had our own group of friends. He lived uptown, I lived downtown. Different worlds. Q. At this point in time he was still living in New York? A. Yes, or he might have had a Florida house then, I'm not sure if he did at that point. I don't remember when he first got that place, but he's had it for a while. Q. That's the house at 358 Old Brillo Way in West Palm Beach? A. I don't know the number, but it's Old Brillo. Q. The same house in West Palm Beach, that's the house we are talking about? A. I believe so. Q. Has your brother ever discussed working for the government, either back in the Bear Stearns days, afterwards, up through the | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181549 Mark Epstein September 21, 2009 39 ## M. Epstein ## present? A. Not to me. Q. Has he ever indicated to you that he was to be a confidential informant for the government? A. No. Q. When is the first time that you remember your brother having some sort of an affiliation with Leslie Wexner? A. It's a while ago. I'm not sure exactly when, but at least 10 -- I'm trying to think where I was in my life. I don't know, maybe 20 years ago. I don't know how long he has been working with him, but he has been working with him for a while. Q. Do you know where they met? A. No. Q. Do you know what brought them together? A. Somebody introduced them. Somebody introduced them, somebody who was in the insurance business. Q. Do you remember who that was? | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181550 Mark Epstein September 21, 2009 40 ## M. Epstein A. No. Q. And what was your understanding of the relationship between your brother and Leslie Wexner? A. He manages money. Q. As far as you knew, that's all that there was? A. Yes. Q. Do you remember at any point in time your brother being sexually abused when he was younger? A. No. Q. Would you know it if it happened? A. By who? Q. Anybody. A. No. When we were kids I would have probably known about it. Q. Do you know of him ever seeing a psychologist in his lifetime? A. No. Q. So even through today's date, to the best of your knowledge, he hasn't seen one? A. I don't know. Q. When did you first learn that your Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181551 Mark Epstein September 21, 2009 41 M. Epstein brother, as an adult, was sexually attracted to young girls? MR. COHEN: Objection. A. I didn't learn that. I mean, I saw it in the newspapers, but that's newspapers. I never heard anything directly I didn't know. Q. The first time you ever knew it was the same way that we learned it, was through the newspapers? A. Yes. Q. Once he started working for Bear Stearns, did you hang out with your brother on a personal level? A. Not very often. THE WITNESS: Excuse me, one second. (Brief pause.) THE WITNESS: Sorry. BY MR. EDWARDS: Q. Has anyone ever asked you about his attraction to young girls? A. No. People made comments about the newspaper articles what they were hearing, but they didn't ask me. It was just more of letting me know that they knew what was going | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181552 Mark Epstein September 21, 2009 42 ## M. Epstein on. Q. Who would that have been? A. Friends, mutual acquaintances, people I knew. People started E-mailing me telling me my brother was in the newspaper. So I got, you know -- Q. When was that? A. Whenever the articles starting coming in. Q. But there were articles on your brother that precede the criminal investigation. And there are people that knew your brother and saw him around town prior to that investigation. Anybody tell you about his attraction to young girls back then or ask you about it? A. No. Most people that we know know that we are not that close and they don't talk to me about him and, you know, the only people that we know together are really people from the old days. Q. Okay. So is this really -- other than newspaper articles, this deposition, as we sit here today and my previous statements | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181553 Mark Epstein September 21, 2009 43 ## M. Epstein that he engaged in sex with under-age girls, is the first you are hearing of it? A. Well, other than the newspaper articles? Q. Right. A. Yes. I mean, I read some things in the papers about it. I don't understand your question. Q. Has anybody else ever talked to you about, you know, your brother is engaging in sex with under-age girls or targeting young girls for sex? A. No. Q. Do you now have any business relationship with your brother? A. No. Q. Have you ever? A. What do you mean by business relationship? When we were kids we used to lend each other money. So I don't want to say no and get caught for saying something like that, but we are not in business together. Our names have never appeared on any business | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181554 Mark Epstein September 21, 2009 44 ## M. Epstein document together. Q. And why is that? Obviously your brother is very successful, so why would you not be associated with him? A. I made my own success. Q. What is your brother's current net worth? A. I have no idea. Q. Do you know approximately what it is? A. I don't know my net worth. I don't know his. Q. What properties does he own that you know of? A. He has a house in Florida, a house in New York and a house in New Mexico. Q. Have you been to the ranch in New Mexico? A. I was only at the property once, before he built anything. After he bought it, I was in New Mexico. Q. How long were you there? A. I was in New Mexico three or four days. Q. With your brother? Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181555 Mark Epstein September 21, 2009 45 ## M. Epstein A. No. Q. How many times have you been at his Florida house the same time he was there? A. Not in the last decade ever. Q. Prior to the last decade, I think you told me a dozen times? A. 20 years ago, probably a couple dozen times. Q. And how long would you stay? Would you ever stay there overnight? A. Yes. Years ago, I would maybe for a couple of days, for a weekend. I was working then, so I'd only have weekends. Q. During that period of time, would he have girls coming over during the day? A. No, he had a girlfriend at the time most of the time. Q. Who was that? A. Early on there was this girl It was an old girlfriend. Q. Do you know where she is now? A. In New York. Q. Do you know her address? A. She is Uptown on the east side | Toll Free | 800.211.3376 | | :--- | :--- | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181556 Mark Epstein September 21, 2009 46 ## M. Epstein somewhere. Q. Do you know any of his other adult girlfriends? A. No. No. Well, I don't know how to characterize. I know some females that he knew from years back but, you know, I'm not sure if they were girlfriends. I don't know what their relationship was. Q. Who are those people? A. Well, there was a (Glynn) Ghislaine Maxwell. Q. How do you know Ghislaine Maxwell? A. I met her through my brother. Q. How many times have you been around or hung out with Ghislaine Maxwell? A. Maybe a dozen or so, but we met when -- about the time -- my father and her father died about the same time. My father died in 1991, so in that period of time almost 20 years ago, I used to see her more frequently. Q. How frequently would you see her? A. Then? | | | | :--- | :--- | | Toll Free: | 800.211.3376 | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181557 Mark Epstein September 21, 2009 47 ## M. Epstein Q. Yes. A. Monthly. Q. Would it always be with your brother? A. Yes. A. Yes. Q. What was your understanding of the relationship between Ghislaine Maxwell and your brother? A. Well, they were friends, and she worked for him. Q. Did she ever live with him? A. I don't know. I'm not sure. I think she always had her own place, so I don't know if she lived with him or not. Q. When you say that she worked for him, what did she do for him? A. I know she helped take care of the properties, like hiring the household help. Q. Did you ever hear that she helped to bring young girls to him for sex? A. I read that somewhere in one of the articles. Q. Is that something, knowing Ghislaine | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181558 Mark Epstein September 21, 2009 48 ## M. Epstein Maxwell and knowing your brother, would that surprise you to hear that? MR. COHEN: Objection. A. I don't know Ghislaine Maxwell. I mean I know her, but you can tell me anything, it's not going to surprise me. Q. When you would see your brother and Ghislaine Maxwell, where would you be; at his house, at a function, out to dinner? A. Probably at his house more than anything. Q. Which house would that be? A. More likely Florida. Q. Do you know how he met her? A. No. Q. Do you know where she is now? A. No. Q. When is the last time you saw Ghislaine Maxwell? A. Probably around when my mother died, that's five and a half years ago. Q. Have you ever met Leslie Wexner? Q. Have you ever met Donald Trump? Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181559 Mark Epstein September 21, 2009 49 M. Epstein A. Yes. Q. Was that through your brother? A. Yes. Q. Where was that? A. We flew up on my brother's plane from Florida together. Donald was on the plane. Q. When? A. Somewhere between 5 and 10 years ago. Q. Okay. So we are talking about -- A. It's either late '90's early 2000. Probably more like late '90's. Q. Was that the only time you've met Donald Trump? A. Yes. Q. Which plane was this of your brother's? A. I don't remember. Q. Was this one of the big planes, the 727? A. No. It wasn't that one, no. Q. Okay. How many people were on this airplane? A. It was my brother, myself, Donald, the pilot the co-pilot. I don't remember -- I | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181560 Mark Epstein September 21, 2009 50 ## M. Epstein don't remember if anybody else was on the plane. Q. What was the purpose of Donald Trump riding on your brother's airplane? A. You'll have to ask Donald. I think he wanted a ride back to New York. Q. What was your understanding of the relationship of Donald Trump and your brother? A. They were friends. Q. Do you know how they met? Q. When you say "friends," how frequently did they associate? A. I have no idea. Q. What was your understanding -- did you -- A. I had no understanding. They were friends. That was my understanding. Q. When they were in the airplane together, they talked as if they were friends? A. Yeah, I talked to him like he was my friend. I never met the guy. I am a friendly guy. Q. Were there girls on the plane? Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181561 Mark Epstein September 21, 2009 51 ## M. Epstein A. I don't remember who was on the plane. I don't remember if anybody else was on the plane. Q. Do you know if the pilot was? A. Yeah. He had a pilot and a co-pilot for a long time. The co-pilot's name was Larry. And the pilot's name -- I have his picture in my face -- into my head, but I don't remember his name. Q. Larry Kisofsky. Does that sound -- A. I don't know his last name. His name is Larry. Q. Is that somebody that still works for him? A. I have no idea. Q. When did your brother get his first airplane? A. Probably around 1990. Somewhere around there, because he had it when my father was in the hospital in '91. Q. You remember that? A. Yes. Q. Was your father ever on his airplane? A. I don't remember. Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181562 Mark Epstein September 21, 2009 52 ## M. Epstein Q. Okay. And how many times do you think that you've been on one of your brother's airplanes with your brother? A. Less than a dozen. Q. And any of the times that you were on the airplane, were there girls on the airplane with you? A. What do you mean girls? There were women on the plane. Q. Okay. Ever any under-age girls? A. I don't think so. Q. So they were young girls, you don't know if they were under-age? A. I'm not going to speculate on their ages. Q. Did you know these girls, or were these girls that were familiar with your brother? A. I didn't know them. I mean, unless it was Ghislaine or Eva years ago, but otherwise I didn't know them. Q. But the specific girls I'm talking about are the girls you are not going to speculate on their age. | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181563 Mark Epstein September 21, 2009 53 ## M. Epstein Were these girls your brother had on the plane because he knew them or did you know them, I guess that's my question? ## A. It wasn't me, no. No, once I flew down to Florida on his plane and I had a girlfriend with me, one of my girlfriends at the time. Q. Did you ever know of any sex or sex acts to go on on the airplane with your brother? A. Not when I was there. Q. When you would fly on his airplane, would this be from New York to Florida or vice versa? A. Yeah. And then there were a couple of times that I flew to or flew back to Cleveland. My father was in a Cleveland clinic for a few months, so I flew on the plane then. Q. And do you know -- did you ever meet David Copperfield? A. No. Q. Did you ever meet Alan Dershowitz? A. I might have met him once. | | | | :--- | :--- | | Toll Free: | 800.211.3376 | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181564 Mark Epstein September 21, 2009 54 ## M. Epstein Q. Where would that have been? A. In Florida. Q. What was the occasion? A. I went to Jeff's house for something and I think Alan was there and I think he introduced us. Q. How long ago was that? A. A long time ago. Q. '90's? A. It would have to be. Q. Have you ever met Bill Clinton? A. Yes. Q. Through your brother? A. No. Q. Have you ever been with your brother at a time when Bill Clinton was also around? A. I don't understand your question. Q. Did you ever go to your brother's house when Bill Clinton was also there? A. No. Q. Have you ever been on your brother's airplane with Bill Clinton? A. No. Q. Have you ever known Bill Clinton to | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181565 Mark Epstein September 21, 2009 55 ## M. Epstein fly on your brother's airplane? A. I read that he went to Africa on his plane. Q. Did you know of him to fly on your brother's airplane on any occasions other than when they went to Africa? A. No. Q. Have you ever met Kevin Spacey? A. No. Q. Chris Tucker? A. No. Q. Do you know what your brother's relationship is with Bill Clinton? A. He knew him, he flew him to Africa. I don't know how he met him. I don't know what their relationship is. Q. Other than the flight to Africa, has your brother ever talked to you about his relationship with Bill Clinton? A. He mentioned they were somewhere once, it might have been in Europe. And I think he mentioned something about Bill Clinton. I'm not sure, but I think there was someplace that he was and Clinton was there, Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181566 Mark Epstein September 21, 2009 56 ## M. Epstein and he mentioned that he was there and Clinton was there, but... Q. Has he ever mentioned to you that he provided girls to Bill Clinton? A. No. Q. Have you ever met Prince Andrew? A. No. Q. Has your brother ever discussed his relationship with Prince Andrew? A. I know he knew him, or he saw him. That's all. Q. What is your understanding as to how your brother made his money? A. I don't have an understanding of it. Q. He's never talked to you about that? A. No. He is an investor. He invested things. As far as I know, he invested money. Q. Do you know who his clients are? A. Other than Wexner, no. Q. Do you believe he has any other clients other than Wexner? A. I have no idea. I never questioned it. Q. How do you know Wexner was his Q. How do you know Wexner was his | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181567 Mark Epstein September 21, 2009 57 ## M. Epstein client? A. Wexner was his client really early on. He told me about it. Q. Was Wexner his only client that he ever talked about? A. Again, we don't talk business. I didn't tell him about many of my clients either. Q. Is it your understanding that Leslie Wexner is no longer your brother's client? A. I have no idea. A. I have no idea. Q. Do you know how your brother's business is doing now? Q. When you call Florida to make sure he is doing all right, isn't one of the main things your brother does is business; and aren't you asking essentially, is your business doing all right? A. No, I'm asking him how his health is. Q. So he responds that his health is fine, and that's basically the end of the telephone call? A. Yeah, or we'll tell each other a | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181568 Mark Epstein September 21, 2009 58 ## M. Epstein funny story about something, about some friends or whatever. Q. Do you know who his closest friends are these days? A. No. A. I don't think I saw . If I met her, it was a few years ago. Q. Where would that have been? A. Maybe 301. Q. And how many occasions have you ever seen ? A. Once or twice. I once saw her in the | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181569 Mark Epstein September 21, 2009 59 ## M. Epstein elevator of 301. Q. Other than at 301, have you seen anywhere else? Q. Do you know of relationship with your brother? A. No. Q. I know I asked you about Jean Luc Brunel, I don't remember did I ask you whether you are familiar with the modeling company MC Squared? A. Yes, you did. MR. COHEN: You did. Q. Are you familiar with the modeling company Karin Models? Q. Have you ever attempted to ascertain who is staying in the various apartments that your brother rents at 301? A. No. Q. Are they usually occupied? A. I have no idea. Q. What is your obligation to that property? What do you do? | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181570 Mark Epstein September 21, 2009 60 ## M. Epstein Q. What does your company do for that property? Q. Well, in managing it, what does that entail? A. Well, we have staff there that takes care of that, yes. Q. Who would the staff member be that would -- Q. This is the head supervisor for your company? A. For that building. He is the superintendent for that building. Q. Have you ever had that position of superintendent for that building? | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181571 Mark Epstein September 21, 2009 ## M. Epstein A. No. Q. Do you know of the name A. No. A. No. Q. Did you talk to your brother about the criminal investigation when it began? MR. COHEN: Objection. Asked and answered. A. No. Q. I know you call now to check on his health. Did it concern you that he was being criminally investigated? MR. COHEN: Objection. A. Well, it concerned me, he is my brother. Q. So why is it you didn't have that conversation with him? A. If there was something he wanted to tell me, he would have told me. Q. And that's not something he ever talked to you about? A. Right. | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181572 Mark Epstein September 21, 2009 62 ## M. Epstein Q. And even though the allegations -- you are familiar with the allegations; right? A. Some, I guess. Q. The allegations are that he was engaging in sex with under-age girls. That's not something that you wanted to take upon yourself to talk to your brother about? A. No. Q. It's not something that really bothers you? A. No -- MR. COHEN: Objection. A. -- no more than anybody else being accused of that. Q. If you found that to be true, hypothetically, you find that it's true that your brother is engaging in sex with under-aged girls; 13, 14, 15-year old girls, is that something that you would discuss with him? MR. COHEN: Objection. A. I'll use one of my mother's lines, I'll worry about that when the time comes. Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181573 Mark Epstein September 21, 2009 63 ## M. Epstein Q. You realize that he has plead guilty to that; right? A. Yes. Q. So hasn't the time come? A. No, not for me. I know it was a plea deal, so I don't know the details. Like I said, he pled guilty to some prostitution charge. So you are representing a bunch of prostitutes if I just go by what the law says. So, you know, I don't pay attention to that. Q. If the evidence in this case are that these girls are in middle school and high school, some of them are virgins and none of them have engaged in prostitution prior to meeting your brother, does that change? A. Your question started with an "if." I'm not going to speculate on anything. MR. COHEN: Mr. Edwards, can we take a short bathroom break? MR. EDWARDS: Sure. THE VIDEOGRAPHER: 12:33, off the record. (Discussion held off the record.) | | | | :--- | :--- | | Toll Free | 800.211.3376 | | Facsimile | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181574 Mark Epstein September 21, 2009 64 MR. COHEN: Let's go back on the record. Are all counsel who appeared by phone on the phone now? THE WITNESS: If anybody's not do speak up. Should we do another roll call? MR. CRITTON: This is Bob Critton. Let me just put on the record, I recognized about just before we took the break I must have bumped my microphone. So when I've been inserting objections, and based on what the court reporter indicated, she hadn't heard me for about 30 or 35 minutes. I just want to assert, any question that had either a leading, isn't it true, or a suggestion that Mr. Jeffrey Epstein had some sexual contact or contact with under-age girls, I would have objected to. I did object to, apparently it didn't come through; any leading guess, any questions for which there was no predicate, I have no objection to the actual questions with regard to who was on the plane, or if he saw his brother, what the discussions they had, but | Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181613 Mark Epstein September 21, 2009
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181614 Mark Epstein September 21, 2009 102
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| Toll Free: | 800.211.3376 | | :--- | :--- | | Facsimile: | 954.331.4418 | Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181615 Mark Epstein September 21, 2009 103
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181616 Mark Epstein September 21, 2009 104
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 ESQUIRE an Alexander Gallo Company Suite 1300 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181617 Mark Epstein September 21, 2009
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 ESQUIRE an Alexander Gallo Company Suite 1300 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181618 Mark Epstein September 21, 2009
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181619 Mark Epstein September 21, 2009 107
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181620 Mark Epstein September 21, 2009 108
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 ESQUIRE an Alexander Gallo Company 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181621 Mark Epstein September 21, 2009 109
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 ESQUIRE an Alexander Gallo Company Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181622 Mark Epstein September 21, 2009 110
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181623 Mark Epstein September 21, 2009
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 ESQUIRE an Alexander Gallo Company 515 East Las Olas Boulevard EFTA00181624 Mark Epstein September 21, 2009 112
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 ESQUIRE an Alexander Gallo Company Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181625 Mark Epstein September 21, 2009 113
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 ESQUIRE an Alexander Gallo Company Suite 1300 | **Suite 1900** | | :--- | 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181626 Mark Epstein September 21, 2009 114
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181627 Mark Epstein September 21, 2009
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Toll Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 Suite 1300 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 www.esquiresolutions.com EFTA00181628 EFTA00181629