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Testimony · April 13, 2010

Deposition transcript in civil suit against Epstein, April 13, 2010

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON

JANE DOE,

Plaintiff,

vs.

JEFFREY EPSTEIN, et al.,

Defendants.

VIDEOTAPED DEPOSITION OF TAKEN ON BEHALF OF THE PLAINTIFF

Related Cases:
08-80119，08-80232，08-80380，08-80381，
08-80994，08-80811，08-80893，09-80469，
09-8-591，09-80656，09-80802，09-81092

DATE: April 13, 2010

U.S. Legal Support

(561) 835-0220

EFTA00181769

April 13, 2010

INDEX WITNESS DIRECT CROSS REDIRECT RECROSS

BY MR. EDWARDS 5 98 BY MR. HOROWITZ 65 BY MR. LANGINO 77 BY MS. EZELL 81

EXHIBITS PLAINTIFP’S FOR IDENTIFICATION PAGE

1 Message dated August 21, 2005. 45

The videotaped deposition of in the above-entitled and numbered cause, was taken before me, TERRI BECKER, A Registered Professional Reporter and Notary Public for the State of Florida at large, at 444 West Railroad Avenue, in the City of West Palm Beach, Pan. Beaches, in the State of Florida, beginning at the hour of 10:00 of clock a.m., pursuant to the Notice in said cause for the taking of said deposition which is annexed to the court file herein, on behalf of the PLAINTIFF in the above-entited action pending in the above-named court.

The appearances at said time and place were as follows:

FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL Attorneys for Plaintiffs Jane Does, L.N. and E.W. 453 North Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 BY: BRADLEY J. EDWARDS, ESQ.

MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs Jane Does, numbers 2 through 8 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 Tel: (305) 931-2200 BY: ADAM D. HOROWITZ, ESQ.

APPEARANCES (CONTINUED) LEOPOLD-KUVIN Attorneys for Plantiflifts Elkland, G.T. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 Tel: (351) 313-1400 BY: ADAM J. LANGINO, ESQ.

PODHURST, ORSECK Attorneys for Jane Does 1 and 3 City National Bank Building, Suite 88 25 West Flight Street, Miami, Florida 33130 Tel: (954) 463-4346 BY: KATHERINE W. EZELL, ESQ.

BURMAN, CRITTON, LUTTER & COLEMAN, LLP Attorneys for Defendant Jeffrey Epstein 301 Bayview Boulevard, Suite 400 West Palm Beach, Florida 33401 Tel: (561) 823-2820 BY: OVACH CARMA, ESQ. ROBERT CRITTON, ESQ.

ATTERBURY, GOLDBERGER & WEISS Co-Counsel for Defendants One Clearlake Centre Suite 400 West Palm Beach, Florida 33401 Tel: (561) 699-8300 BY: JACK A. GOLDBERGER, ESQ.

ALSO PRESENT: JESSICA CADWELL JOE KOVNER, Videographer (U.S. Legal)

THEREUPON.

being by Terri Becker first duly sworn to tell the whole truth, as herinfer certified, testified as follows:

DIRECT EXAMINATION BY MR. EDWARDS:

Q Can you tell your name. A

Q What is your date of birth? A February 21, 1985.

Q What is your Social Security number? A Under advice of my counsel, I invoke my privileges under the Fifth and Sixth Amendments to the United States Constitution and respectfully decline to answer the question.

Q Where were you born? A I’m sorry, though I would like to answer your question, I must invoke my Fifth and Sixth Amendment privileges and refuse to answer your questions.

Q What is your current address? MR. GOLDBERGER: There is going to be a continued, obviously, you anticipate I’m sure, continued invocation of Fifth

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Amendment privileges. If it is okay with all counsel, to shorten things, I’ll simply have the witness say “Fifth,” if that satisfies everyone’s interest.

MR. EDWARDS: That is fine with me. MR. GOLDBERGER: Okay, with that Cathy? MS. EZELL: Yes. MR. HOROWITZ: Yes.

Q I’ll reask the question, what’s your current address?

A Fifth.

Q Are you currently living at 358 El Brillo Way with a man named Jeffrey Epstein?

A The Fifth.

Q Are you also familiar with an address in New York, 301 East 66th Street?

A The Fifth.

Q When Mr. Epstein was incarcerated in jail, you went to visit him on numerous occasions; is that correct?

MR. YAREMA: Objection.

A The Fifth.

Q Isn’t it true when Mr. Epstein was in jail, you visited him on more than 50 occasions?

MR. YAREMA: Form objection.

Q True?

A The Fifth.

Q How long have you been in the United States, Ms. ___?

A The Fifth.

Q Who brought you to the United States?

MR. YAREMA: Form objection.

A The Fifth.

Q What is your current status in this country?

A The Fifth.

MR. YAREMA: Form objection.

MR. GOLDBERGER: Let me take a half a second.

(Witness and her counsel confer.)

Q Are you a U.S. citizen?

A The Fifth.

Q What type of visa are you here on?

MR. YAREMA: Form objection.

A The Fifth.

Q Do you know a lady by the name of Marita Vazques?

A The Fifth.

Q Is this somebody who helped to falsify a visa for you?

MR. YAREMA: Object to the form.

A The Fifth.

Q Do you know Evelyn Velasaques?

A The Fifth.

Q Were you ever a working model in the United States?

A The Fifth.

Q Can you tell us your parents’ names?

A The Fifth.

Q How is it that you have supported yourself financially, since you have been in this country?

MR. YAREMA: Object to the form.

A The Fifth.

Q Have you supported yourself financially?

A The Fifth.

Q What is the last grade you completed in school?

A The Fifth, I take the Fifth Amendment.

U.S. Legal Support

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sex slave?

MR. YAREMA: Object to the form.

A The Fifth.

Q Are you aware that the reports about you indicate that you were brought to the United States by Jeffrey Epstein when you were roughly 13 or 14 years old to be his Yugoslavian lesbian sex slave?

MR. YAREMA: Object to the form.

A The Fifth.

Q Is that true?

MR. YAREMA: Object to the form.

A The Fifth.

Q Have you performed any services for Jeffrey Epstein aside from being his sex slave?

MR. YAREMA: Object to the form.

A The Fifth.

Q What is your sexual orientation?

MR. YAREMA: Object to the form.

MR. GOLDBERGER: I’m going to instruct the witness not to answer that question. It serves no purpose other than to harass or intimidate her, so in addition to Fifth Amendment privileges, I’m objecting on privacy grounds.

11

1 A I take the Fifth.

Q I represent a lady named, a young female named E.W.; you know who that is, right?

MR. YAREMA: Object to the form.

A The Fifth.

Q Jeffrey Epstein made you have sex with E.W., didn’t he?

MR. YAREMA: Object to the form.

A The Fifth.

Q You did, in fact, engage in sexual activity with E.W. when she was only 16 years old; isn’t that true?

MR. YAREMA: Object to the form.

A The Fifth.

Q Back to my original question: And I’ll ask you this way: Do you consider yourself heterosexual, bi-sexual, or can you answer that question?

MR. YAREMA: Object to the form.

MR. GOLDBERGER: Same objection. Do not answer the question.

A Fifth.

Q How did you meet Jeffrey Epstein?

A Fifth.

Q When did you become one of Jeffrey Epstein’s sex slaves?

MR. YAREMA: Object to the form.

A Fifth.

Q What does it mean to be Jeffrey Epstein’s sex slave?

MR. YAREMA: Object to the form.

A Fifth.

Q Are you aware that Jeffrey Epstein reads books on how to be a proper master to his sex slave?

MR. YAREMA: Object to the form.

A Fifth.

Q What has Jeffrey Epstein done to train you to be his sex slave?

MR. YAREMA: Object to the form.

A Fifth.

Q What do your parents think about you being Jeffrey Epstein’s sex slave?

MR. YAREMA: Object to the form.

A Fifth.

Q When did you first learn that Jeffrey Epstein had a sexual obsession for underage minor females?

MR. YAREMA: Object to the form.

A Fifth.

1

1 Q How many times has Jeffrey Epstein made you have sex with underage minor females?

MR. YAREMA: Object to the form.

A Fifth.

Q Do you enjoy sex with underage minor females?

MR. YAREMA: Object to the form.

A Fifth.

Q What is the youngest child that Jeffrey Epstein has forced you to have sex with?

MR. YAREMA: Object to the form.

A Fifth.

Q Does Jeffrey Epstein today still make you have sex with underage minor females?

MR. YAREMA: Object to the form.

A Fifth.

Q How many underage minor females has Jeffrey Epstein made you have sex with, since you were over the age of 18?

MR. YAREMA: Object to the form.

A Fifth.

Q Prior to turning 18, is it true that Jeffrey Epstein made you have sex with many other children in kid-type orgies?

MR. YAREMA: Object to the form.

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A Fifth.

Q Has Jeffrey Epstein also made you perform sexually on his friends?

MR.YAREMA: Object to the form.

A Fifth.

Q Do you know David Copperfield?

MR.YAREMA: Object to the form.

A Fifth.

Q Have you ever been made to perform sexually on David Copperfield?

MR.YAREMA: Object to the form.

A Fifth.

Q Do you know Prince Andrew?

A Fifth.

Q Have you ever been made to perform sexually on Prince Andrew?

MR.YAREMA: Object to the form.

A Fifth.

Q When was the first time that you knew Jeffrey Epstein molested underage girl?

MR.YAREMA: Object to the form.

A Fifth.

Q Did Jeffrey Epstein molest you when you were underage?

MR.YAREMA: Object to the form.

A Fifth.

Q I’m assuming you understand why you’re here today, correct?

MR.YAREMA: Object to the form.

A The Fifth.

Q For allegations related to Jeffrey Epstein interacting sexually with numerous underage minor females; that’s something you know, right?

MR.YAREMA: Object to the form.

A The Fifth.

Q That’s something in addition to the civil lawsuits, there were criminal cases involving the same conduct, correct?

MR.YAREMA: Object to the form.

A Fifth.

Q You were a part of that criminal investigation, in fact, you were a co-conspirator of Jeffrey Epstein’s; is that right?

MR.YAREMA: Object to the form.

A Fifth.

Q What crimes did you conspire to commit with Jeffrey Epstein against underage minor females?

MR.YAREMA: Object to the form.

A Fifth.

Q Have you read the nonprosecution agreement between the government and Jeffrey Epstein?

A Fifth.

Q Are you aware that inside that document you are labeled as a co-conspirator of his crimes against children?

MR.YAREMA: Object to the form.

A Fifth.

Q Isn’t it true that your role was to lure or procure underage minor females to Jeffrey Epstein for him to molest, correct?

MR.YAREMA: Object to the form.

A Fifth.

Q You also scheduled appointments for Jeffrey Epstein, so there would be designated times for Jeffrey Epstein to molest underage minor females, correct?

MR.YAREMA: Object to the form.

A The Fifth.

Q As well, you participated in various sex acts with underage minor females, thus molesting them yourself, is that correct?

MR.YAREMA: Object to the form.

A Fifth.

Q Do you understand that the Lewd and Lascivious Molestation Statute in Florida indicates a person who intentionally touches in a lewd or lascivious manner, the breasts, genital area or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or entices a person under 16 years of age, to so touch the perpetrator, commits lewd or lascivious molestation? Are you aware of that statute?

A Fifth.

Q That is a statute that you know Jeffrey Epstein to have violated; is that true?

MR.YAREMA: Object to the form.

A The Fifth.

Q That’s a statute that you yourself have violated; is that true?

MR.YAREMA: Object to the form.

A The Fifth.

Q You’ve observed Jeffrey Epstein violate

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that statute on many underage minor females, true? Mr. YAREMA: Object to the form. A. The Fifth. Q Have you ever discussed with Jeffrey Epstein that the fact that he is a child molester? Mr. YAREMA: Object to the form. A. Fifth. Q Have you asked Jeffrey Epstein why he has made you interact with underage minor females in a sexual manner? Mr. YAREMA: Object to the form. A. Fifth. Q During the litigation of these civil cases, has Jeffrey Epstein indicated to you an intent to continue to molest children? Mr. YAREMA: Object to the form. A. Fifth. Q Is it your intent to continue to commit sex crimes against minors? Mr. YAREMA: Object to the form. A. Fifth. Q In addition to your being named as a co-conspirator of Jeffrey Epstein regarding his crimes against minors, there is also a person listed as a co-conspirator. Do you know? A. Fifth. Q This is somebody who lives with you and Jeffrey Epstein; is that true? Mr. YAREMA: Object to the form. A. Fifth. Q And is somebody who you know to be Story Cowles’s girlfriend; is that true? Mr. YAREMA: Object to the form. A. Fifth. Q She’s spoken with Story Cowles about this case on numerous occasions; is that true? Mr. YAREMA: Object to the form. A. Fifth. Q Conversations with Story Cowles and your observations of them, you believe would implicate you in a crime and that’s why you’re able to take the Fifth as to that question? Mr. YAREMA: Object to the form. A. Fifth. Q Who is Lesley Groff, also listed as a co-conspirator in the non-prosecution agreement related to Jeffrey Epstein’s crimes against minors? Mr. YAREMA: Object to the form. A. Fifth. Q Do you know? A. Fifth. Q These are all people who also participated in Jeffrey Epstein’s scheme to lure underage females to him for sex; is that true? Mr. YAREMA: Object to the form. A. Fifth. Q You and these other co-conspirators played various roles to make sure Jeffrey Epstein was able to engage in sexual contact or conduct, with underage minor females on an everyday basis; is that true? Mr. YAREMA: Object to the form. A. Fifth. Q Since the time you first met Jeffrey Epstein, has his appetite for underage minor females always been the same? Mr. YAREMA: Object to the form.

Q By that I mean, have you observed Jeffrey Epstein to interact sexually with underage minor females literally on a daily basis? Mr. YAREMA: Object to the form. A. Fifth. Q Wasn’t it one of your specific job duties to make sure that he had different underage minor females to molest on a daily basis? Mr. YAREMA: Object to the form. Q In addition to the improper sexual contact between Jeffrey Epstein and underage minor females at the West Palm Beach house, you have observed similar improper and illegal contact by Jeffrey Epstein in his New York mansion, as well, correct? Mr. YAREMA: Object to the form. Q In fact, he operates a very similar scheme up there, in that he schedules these appointments with underage minor females, under the guise that it is going to be a massage; is that correct?

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MR. YAREMA: Object to the form? A Fifth. Q When he is in New York, he has contact with underage minor females for the purposes of sexually molesting them as well; is that correct? MR. YAREMA: Object to the form. A Fifth. Q When he is in his ranch in New Mexico, similarly, Jeffrey Epstein is engaging in sex with underage minor females from that local area as well, and that’s something you’ve observed? MR. YAREMA: Object to the form. A Fifth. Q On his island, particularly, he has flown underage minor females to the island for underage kid-type orgies; is that true? MR. YAREMA: Object to the form. A Fifth. Q You’re shaking your head indicating, at least to me, indicating that you may not agree with what I’m saying, and I would love to give you the chance to explain it to us. MR. GOLDBERGER: I appreciate that, but don’t —

MR. EDWARDS: Read too much into it? MR. GOLDBERGER: Exactly. Don’t go there. Just ask the questions and we will move right along. MR. EDWARDS: I agree, Jack, I just know if this is played for a jury, I don’t want the jury to interpret her shaking her head as a “No,” and then her pleading the Fifth. MR. GOLDBERGER: I appreciate that. Don’t take anything as to any head movements or any body movements at all. Just ask the questions and we will let the video speak for itself. Q How many of these — you know what an orgy is, don’t you? A Fifth. Q And how many of these orgies, as I am calling them, where there are numerous underage minors having sex with each other and with Jeffrey Epstein, have you observed on Jeffrey Epstein’s island? MR. YAREMA: Object to the form. A Fifth. Q Is part of your role as Jeffrey Epstein’s sex slave, not to tell the authorities

when Jeffrey Epstein commits these crimes against children? MR. YAREMA: Object to the form. A Fifth. Q Is there any way for you to escape being his sex slave? MR. YAREMA: Object to the form. A Fifth. Q Have you ever wanted to cooperate with the authorities, so that you could escape being his sex slave? MR. YAREMA: Object to the form. A Fifth. Q Do you represent to others that you are his girlfriend or his sex slave, or some other designation? MR. YAREMA: Object to the form. A Fifth. Q Isn’t it true that you recently represented to the Probation Officer that you were his live-in girlfriend? MR. YAREMA: Object to the form. A Fifth. Q When Probation calls the house, are you told to tell Probation that he is in the swimming pool or doing some other activity that would not allow him to come to the telephone? MR. YAREMA: Object to the form. A Fifth. Q Isn’t it true you’re under strict orders to tell Probation that? MR. YAREMA: Object to the form. A Fifth. Q Isn’t it true you’ve heard Jeffrey Epstein tell you on numerous occasions, regarding the age of the girls that he wants to his house, for the purposes of sexually molesting, the phrase he uses is “the younger the better,” true? MR. YAREMA: Object to the form. A Fifth. Q I asked you earlier about E.W. out of turn as a result of an objection related to your sexual orientation, but I’ll talk specifically about E.W. right now. Know who that is, right? MR. YAREMA: Object to the form. A Fifth. Q That is somebody you observed Jeffrey Epstein to call for the purposes of getting her

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to his house to sexually molest; is that right? MR. YAREMA: Object to the form. A Fifth.

Q The first time she went to Jeffrey Epstein’s house was in 2002 when she was only 14 years old; is that true? MR. YAREMA: Object to the form. A Fifth.

Q In fact in 2002 you were only 18 years old or so yourself; is that right? A Fifth.

Q And E.W, is somebody you observed at Jeffrey Epstein’s house on more than 100 occasions between 2002 and 2005, a time period between 14 and 17 years of age for her; is that right? MR. YAREMA: Object to the form. A Fifth.

Q And each time E.W. was summoned to Jeffrey Epstein’s house, it was for the purposes of Jeffrey Epstein sexually molesting her, correct? MR. YAREMA: Object to the form. A Fifth.

Q If it was not Jeffrey Epstein personally

calling E.W., you observed to call E.W. for the purposes of her coming over and pleasing Jeffrey Epstein sexually, correct? MR. YAREMA: Object to the form. A Fifth.

Q And do you remember the instance where Jeffrey Epstein instructed you to lay down naked and engage in a threasure with E.W. and Jeffrey Epstein? MR. YAREMA: Object to the form. A Fifth.

Q Do you remember that during that threasure, Jeffrey Epstein demanded E.W. to straddle you and otherwise engage sexually with you while Jeffrey Epstein was using vibrators and/or dildos on you? MR. YAREMA: Object to the form. A Fifth.

Q In addition to your sexual interactions with E.W., isn’t it true that you have used strap-on dildos and vibrators on other underage minors at Jeffrey Epstein’s direction? MR. YAREMA: Object to the form. A Fifth.

Q You have given oral sex to underage

young girl, with braces on, and going up into Jeffrey Epstein’s bedroom on numerous occasions to be sexually molested? MR. YAREMA: Object to the form. A Fifth.

Q Do you know when it was that Jeffrey Epstein developed his plan or scheme to gain access to hundreds of underage minor females for the purposes of his sexual gratification? MR. YAREMA: Object to the form. A Fifth.

Q Were you a part of the planning of that scheme of Jeffrey Epstein’s to gain access to underage minor females? MR. YAREMA: Object to the form. A Fifth.

Q Do you know Ghislaine Maxwell? A Fifth.

Q Is that somebody who helped Jeffrey Epstein to devise the scheme to allow him access to various and a variety of underage minor females? MR. YAREMA: Object to the form. A Fifth.

Q Is somebody that was also

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involved in the planning of this scheme to gain access to underage minor females? MR. YAREMA: Object to the form. A Fifth.

Q When is the first time that you observed Jeffrey Epstein’s method of enticing or inducing underage minor females into sexual acts with him inside his bedroom? MR. YAREMA: Object to the form. A Fifth.

Q Isn’t it true that after an underage minor female was brought to Jeffrey Epstein’s house, typically or Adriana or yourself would lead that underage minor female to Jeffrey Epstein’s bedroom and leave them alone in the room; is that true? MR. YAREMA: Object to the form. A Fifth.

Q Then Jeffrey Epstein would either naked or wearing a towel; is that true? MR. YAREMA: Object to the form. A Fifth.

Q This is his habit or method of operation, every single time, and that’s something that he has told you about his sexual interaction with underage minors; is that true? MR. YAREMA: Object to the form. A Fifth.

Q And he would direct or demand or instruct the underage minor female to remove her clothing; is that true? MR. YAREMA: Object to the form. A Fifth.

Q Then he would perform one or more lewd or lascivious or sexual acts on the underage minor female. Is that true? MR. YAREMA: Object to the form. A Fifth.

Q And you have observed Jeffrey Epstein engage in sexual interaction with underage minor females on hundreds and hundreds of occasions, correct? MR. YAREMA: Object to the form. A Fifth.

Q And you have observed Jeffrey Epstein using vibrators and sexual toys on underage minors, true? MR. YAREMA: Object to the form. A Fifth.

Q In fact, he has also used vibrators and sex toys on you, correct? A Fifth.

Q And he has instructed you to use sex toys and vibrators on other underage minor females, correct? MR. YAREMA: Object to the form. A Fifth.

Q You have observed Jeffrey Epstein digitally penetrate the vagina of underage minor females, including E.W., correct? MR. YAREMA: Object to the form. A Fifth.

Q As part of his plan to avoid detection by law enforcement, you have observed Jeffrey Epstein to pay these underage minor females to be quiet, correct? MR. YAREMA: Object to the form. A Fifth.

Q And this is something that he has told you he does, for the purposes of grooming these underage minor females, and avoiding law enforcement detection, correct? MR. YAREMA: Object to the form. A Fifth.

Q Jeffrey Epstein has talked to you about the psychology of brainwashing or grooming underage minor females to perform for him sexually hasn’t be? MR. YAREMA: Object to the form. A Fifth.

Q And Sarah Kellen has also spoken with you about the methodology behind gaining access to and grooming underage minor females for sex? MR. YAREMA: Object to the form. A Fifth.

Q Isn’t it true that Ghiblaine Maxwell and yourself had access to a master list of underage female names and phone numbers so that they could be called? MR. GOLDBERGER: Time out. Are you talking to me, counsel? MR. HOROWITZ: Nodding my head, back at you. You were nodding at me. MR. GOLDBERGER: I wasn’t nodding at you. I’m not communicating with you. I don’t know what you think we are doing here. You said “It is true,” and I have no idea what you are talking about. Don’t interrupt the deposition, okay?

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MR. HOROWITZ: I think you interrupted. MR. GOLDBERGER: I didn’t do a thing — MR. EDWARDS: I don’t know what’s happened here. It has deteriorated here for no reason whatsoever and has nothing to do with me or the witness. MR. GOLDBERGER: You’re 100 percent correct. MR. EDWARDS: Can we go back to it. MR. GOLDBERGER: Absolutely. MR. EDWARDS: Perfect. The silent fight disrupted me. I lost where I am now. MR. GOLDBERGER: Sorry. MR. EDWARDS: Can you read it back. THE COURT REPORTER: Certainly. (The record was read.) MR. EDWARDS: I’ll rephrase the question. Q Isn’t it true that yourself, Ghishaine Maxwell and had access to a master of list of underage minor females names and phone numbers so they could be called for the purpose of coming to Jeffrey Epstein’s house to be sexually molested?

MR. YAREMA: Object to the form. A Fifth. Q How many underage minor females are on that master list? MR. YAREMA: Object to the form. A Fifth. Q Are there photographs of these underage minor females on that master list? MR. YAREMA: Object to the form. A Fifth. Q Is that master list saved on a computer system, as has been testified to in the past? MR. YAREMA: Object to the form. A Fifth. Q Has Jeffrey Epstein talked to you about the success of his scheme to procure underage minor females? MR. YAREMA: Object to the form. A Fifth. Q By that, I mean, the method where he molests an underage minor female, then offers them additional money if they will bring him other underage minor females to molest; are you familiar with that system? MR. YAREMA: Object to the form.

Q In addition to that system, isn’t it true that Jeffrey Epstein traffics underage minor females through a modeling agency? MR. YAREMA: Object to the form. A Fifth. Q Is a modeling agency that he is involved in with Jean Luc Brunel; you know who that is right? MR. YAREMA: Object to the form. A Fifth. Q Are you familiar with MC-2 or MC-Squared Modeling Agency? A Fifth. Q You know Jean Luc Brunel, right? MR. YAREMA: Object to the form. A Fifth. Q Is Jean Luc Brunel somebody that you have been made to perform on sexually? MR. YAREMA: Object to the form. A Fifth. Q Jean Luc Brunel is somebody that you know to also be a child molester, true? MR. YAREMA: Object to the form. A Fifth.

Q This is somebody who for years the public has known of Jean Luc Brunel as a child molester, true? MR. YAREMA: Object to the form. A Fifth. Q In fact, that is the only thing Jeffrey Epstein and Jean Luc Brunel have in common, is their obsession for underage minor females, correct? MR. YAREMA: Object to the form. A Fifth. Q And the modeling agency is but one other mechanism used by Jeffrey Epstein to gain access to underage minor females for sex, true? MR. YAREMA: Object to the form. A Fifth. Q I read you the statute earlier on Lewd and Lascivole Molstation, Chapter 800.04, and that’s something that you have witnessed Jeffrey Epstein violate on hundreds of occasions, correct? MR. YAREMA: Object to the form. A Fifth. Q And something that you have witnessed Jeffrey Epstein specifically violate, against

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E.W., true?

MR. YAREMA: Object to the form.

A Fifth.

Q Also a statute you have witnessed Jeffrey Epstein violate against then minor, L.M.?

MR. YAREMA: Object to the form.

A Fifth.

Q In fact L.M. was somebody that Jeffrey Epstein liked or likes; isn’t that true?

MR. YAREMA: Object to the form.

A Fifth.

Q L.M. was somebody Jeffrey Epstein met when she was only 13 years old and began sexually molesting her the first day that he met her, true?

MR. YAREMA: Object to the form.

A Fifth.

Q L.M. was one of his main girls, as he would call them; is that true?

MR. YAREMA: Object to the form.

A Fifth.

Q L.M. procured for him or brought for him to his house, over 50 girls between the ages of 12 and 15 years old; is that true?

MR. YAREMA: Object to the form.

A Fifth.

Q And in addition to L.M. being sexually molested herself, she was enticed or coerced into bringing her friends over, to also be sexually molested, true?

MR. YAREMA: Object to the form.

A Fifth.

Q Has Jeffrey Epstein talked to you about an FBI statement that was given by L.M.?

A Fifth.

Q He has also told you that that FBI statement that was favorable for him is completely false; isn’t that true?

MR. YAREMA: Object to the form.

Q Has he spoken to you about the fact that she is now telling the complete story and accurate account as to what happened at Jeffrey

Epstein’s house, and he is using all resources to try to intimidate and harass her; is that true?

MR. YAREMA: Object to the form.

A Fifth.

Q In fact, has he talked to you about his tactic of intimidating and harassing any victims that come forward against him, regarding the sexual abuse that they endured by him?

MR. YAREMA: Object to the form.

A Fifth.

Q Would you agree that Jeffrey Epstein contributed to the delinquency of these various minors that he sexually abused?

MR. YAREMA: Object to the form.

A Fifth.

Q In addition to abusing them, he also encouraged them to return to him to receive more sexual abuse and encouraged them into a life of prostitution, true?

MR. YAREMA: Object to the form.

A Fifth.

Q How many underage minor females have you observed Jeffrey Epstein engage in sex acts with on any of his airplanes?

MR. YAREMA: Object to the form.

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  1. likely to cause severe emotional distress?
  2. MR. YAREMA: Object to the form.
  3. A Fifth.
  4. Q And with respect to Jane Doe and E.W. and L.M., wouldn’t you agree that Jeffrey Epstein forced these girls to be a prostitute for him?
  5. MR. YAREMA: Object to the form.
  6. A Fifth.
  7. Q Would you agree that Jeffrey Epstein’s actions against E.W., L.M. and Jane Doe, were intentional, deliberate and reckless?
  8. A Fifth.
  9. Q Would you agree that that intentional, deliberate and reckless conduct by Jeffrey Epstein against L.M., E.W. and Jane Doe was
  10. likely to cause severe emotional distress?
  11. MR. YAREMA: Object to the form.
  12. A Fifth.
  13. Q And isn’t it a fact that Jeffrey Epstein has specifically told you that it is his intent to cause severe emotional distress, as it weakened his victims?
  14. MR. YAREMA: Object to the form.
  15. A Fifth.
  16. Q Has Jeffrey Epstein talked to you about your role in what he calls a criminal enterprise?
  17. MR. YAREMA: Object to the form.
  18. A Fifth.
  19. Q Has he talked to you about his organization being a criminal enterprise, that you need to help protect?
  20. MR. YAREMA: Object to the form.
  21. A Fifth.
  22. Q What does Jeffrey Epstein do for a living?
  23. A Fifth.
  24. Q Does he profit from international sex trafficking of children?
  25. MR. YAREMA: Object to the form.
  26. A Fifth.

Q Do you profit from sex trafficking of children? MR. YAREMA: Object to the form. A Fifth. Q Do you know Sergio Cordero? A Fifth. Q Do you know Mike Sanka? A Fifth. Q Would you consider Jeffrey Epstein’s criminal enterprise that is designed to molest underage minor females, to be organized? MR. YAREMA: Object to the form. A Fifth. Q Is your role in that criminal arrangement to molest underage minor females, to help organize? MR. YAREMA: Object to the form. A Fifth. Q As part of that organization, isn’t it true that you, as well as various staff members, took meticulous messages regarding appointments and scheduling underage minor females to come over to be sexually molested? MR. YAREMA: Object to the form. A Fifth.

Q These were message pads that had a carbon copy that were positioned or stationed in several places around Jeffrey Epstein’s home near the telephone; you’re familiar with those, right? MR. YAREMA: Object to the form. A Fifth. Q Since I’m assuming that you are going to take the Fifth on each and every question related to any messages, I will show you only one which will be marked, this one page, as Plaintiff’s Exhibit 1. The date on the message that I will be showing you is 821, August 21, 2005. (Message dated August 21, 2005 was marked as Plaintiff’s Exhibit number 1 for identification, as of this date.) MR. EDWARDS: Do you want to see it first? MR. GOLDBERGER: (Counsel examines document and hands it to the witness.) Q Would you look at the exhibit, please, if you can see it? I don’t know if you can see it over your coffee. A I can see it. Q Okay. Do you recognize it?

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A Fifth.

Q That particular message indicates it is from You’re the only one in the house; is that correct?

MR.YAREMA: Object to the form.

A Fifth.

Q This is a call from you indicating that cannot work today will be here at 4:00 p.m.; is that right?

MR.YAREMA: Object to the form?

A Fifth.

Q Who is?

A Fifth.

MR.YAREMA: Object to the form.

Q That’s an underage minor female that was scheduled to be molested at Jeffrey Epstein’s house?

MR.YAREMA: Object to the form.

A Fifth.

Q You scheduled that act of molestation; is that right?

MR.YAREMA: Object to the form.

A Fifth.

Q And Britney will be at the house at 4:00 p.m. Britney is another underage minor female;

is that correct?

MR.YAREMA: Object to the form.

A Fifth.

Q That’s somebody else that you were scheduling to come to his house at 4:00 p.m. for Jeffrey Epstein to engage in sexual acts with her, while she was an underage minor, true?

MR.YAREMA: Object to the form.

A Fifth.

Q Do you know Les Wexner?

A Fifth.

Q That’s somebody that you know owns and operates the Victoria’s Secret, the Limited?

MR.YAREMA: Object to the form.

A Is that a question?

Q Is that somebody that you know to own Victoria’s Secret or operate Victoria’s Secret?

A Fifth.

Q Do you know if Jeffrey Epstein still talks with Leslie Wexner?

MR.YAREMA: Object to the form.

A Fifth.

Q Do you know Jane Doe-1027?

A Fifth.

Q Are you aware of Jeffrey Epstein and

Ghislaine Maxwell’s sexual interaction with Jane Doe-102 when she was a minor?

MR.YAREMA: Object to the form.

Q This is one of many underage minor females that was trafficked basically around the globe to be sexually exploited and abused; is that correct?

MR.YAREMA: Object to the form.

A Fifth.

Q Was that typical of Jeffrey Epstein and Ghislaine Maxwell to sexually abuse minors on Jeffrey Epstein’s airplane?

MR.YAREMA: Object to the form.

A Fifth.

Q And also typical of Ghislaine Maxwell and Jeffrey Epstein to prostitute or pimp out underage minors to friends?

MR.YAREMA: Object to the form.

A Fifth.

Q By “friends,” I am talking specifically about people of royalty, politicians, academicians, businessmen and other professional or personal acquaintances?

MR.YAREMA: Object to the form.

A Fifth.

Q Were you with Jeffrey Epstein on his birthday when one of his friends sent to him 12 - sorry, three 12-year olds for the purposes of Jeffrey Epstein sexually abusing them?

MR.YAREMA: Object to the form.

A Fifth.

Q How many occasions have you observed Jeffrey Epstein to receive as gifts from friends, underage minor females for the purposes of him sexually abusing them?

MR.YAREMA: Object to the form.

A Fifth.

Q These three 12-year olds were from France. Were they sent to him on his birthday by Jean Lue Brunel or by somebody else?

MR.YAREMA: Object to the form.

A Fifth.

Q Have you ever been made to engage in sex with 12-year olds?

MR.YAREMA: Object to the form.

A Fifth.

Q Is it true that Jeffrey Epstein makes you dress up as a 12-year old?

MR.YAREMA: Object to the form.

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Q As part of being Jeffrey Epstein’s sex slave, isn’t it true that he asks you or requests of you to dress younger than 12 at times? MR. YAREMA: Object to the form. A Fifth.

Q Have you seen naked photographs of the underage minor females with whom Jeffrey Epstein has engaged in sex acts? MR. YAREMA: Object to the form. A Fifth.

Q Are there hidden cameras in any of Jeffrey Epstein’s homes, that you know to have taken surreptitious videos or photographs of underage minors? MR. YAREMA: Object to the form. A Fifth.

Q Does Jeffrey Epstein still watch pornography to this day? MR. YAREMA: Object to the form. A Fifth.

Q Does Jeffrey Epstein watch homemade pornographic videos of underage minors engaging in sex orgies on his island? MR. YAREMA: Object to the form. A Fifth.

Q Prior to the search warrant being executed, you are aware that at least three computers were taken at Jeffrey Epstein’s direction, from Jeffrey Epstein’s house, to avoid detection by law enforcement, correct? MR. YAREMA: Object to the form. A Correct.

Q Adriana and some other person took those computers to avoid Jeffrey Epstein – to avoid the authorities obtaining the evidence contained on those computers, correct? MR. YAREMA: Object to the form. A Fifth.

Q Who are the persons along with Adriana took the computers from Jeffrey Epstein’s house prior to the execution of the search warrant? MR. YAREMA: Object to the form. A Fifth.

Q Where are those computers today? MR. YAREMA: Object to the form. A Fifth.

Q Were they taken by his investigator, Bill Riley? MR. YAREMA: Object to the form.

Q Do you know Bill Riley? A Fifth.

Q Have you seen the flight logs from Jeffrey Epstein’s private airplane flights? MR. YAREMA: Object to the form. A Fifth.

Q Are you aware that you’re listed as a passenger on many flights, along with Jeffrey Epstein on his private airplane? MR. YAREMA: Object to the form. A Fifth.

Q Certainly comes as no surprise to you, since you were on his airplane on numerous occasions, correct? MR. YAREMA: Object to the form. A Fifth.

Q On September 22, 2003, you were listed as being on a flight with Jeffrey Epstein, S.H. and B.T. My question is who is S.H. and who is B.T.? MR. YAREMA: Object to the form. A Fifth.

Q Do you know Jeffrey Epstein’s house on many occasions with correct? MR. YAREMA: Object to the form. A Fifth.

Q In fact, do you remember there being a burglary of Jeffrey Epstein’s house where he actually called the police to investigate the burglary? MR. YAREMA: Object to the form. A Fifth.

Q And during the police investigation inside Jeffrey Epstein’s house, you were speaking with both in person, at Jeffrey Epstein’s house, correct? MR. YAREMA: Object to the form. A Correct.

Q Is this another person that Jeffrey Epstein, when she was a minor, violated sexually? MR. YAREMA: Object to the form. A Fifth.

Q Do you still speak with Jeffrey Epstein?

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Jeffrey Epstein specifically flew to Palm Beach for the purposes of engaging in sex acts with Jane Doe?

  • A Fifth.
  • Q Do you know Bill Clinton?
  • A Fifth.
  • Q You have been on Jeffrey Epstein’s airplane with Bill Clinton?
    • MR.YAREMA: Object to the form.
  • A Fifth.
  • Q Isn’t take true you have been on Jeffrey Epstein’s airplane with Doug Band, Bill Clinton’s righthand man?
    • MR.YAREMA: Object to the form.
  • A Fifth.
  • Q Have you witnessed improper sexual activity between Jeffrey Epstein and minors, while he was in the presence of Bill Clinton?
    • MR.YAREMA: Object to the form.
  • A Fifth.
  • Q How many times have you ridden on the airplane with Jean Luc Brunel?
    • MR.YAREMA: Object to the form.
  • A Fifth.
  • Q Each time that Jean Luc Brunel visits Jeffrey Epstein’s house, does he bring underage minors to Jeffrey Epstein’s house to engage in sex with?
    • MR.YAREMA: Object to the form.

Jeffrey Epstein specifically flew to Palm Beach for the purposes of engaging in sex acts with Jane Doe?

  • MR.YAREMA: Object to the form.
  • A Fifth.
  • Q Generally, isn’t it true Jeffrey Epstein would fly from place to place for the purpose of engaging in sexual activity with minors at his destination?
    • MR.YAREMA: Object to the form.
  • A Fifth.
  • Q Isn’t it true that he employed numerous people for the sole purpose of scheduling appointments with underage minor females at each destination he landed?
    • MR.YAREMA: Object to the form.
  • A Fifth.
  • Q What is Jeffrey Epstein’s relationship with Sandy Berger?
    • MR.YAREMA: Object to the form.
  • A Fifth.
  • Q Do you know what Jeffrey Epstein’s relationship is with Alan Dershowitz?
    • MR.YAREMA: Object to the form.

Jeffrey Epstein specifically flew to Palm Beach for the purposes of engaging in sex acts with Jane Doe?

  • MR.YAREMA: Object to the form.
  • A Fifth.
  • Q That’s somebody who you know to have stayed at Jeffrey Epstein’s house on many occasions, correct?
    • MR.YAREMA: Object to the form.
  • Q And also somebody who you know to have been at the house when E.W. was in Jeffrey Epstein’s bedroom getting sexually abused, correct?
    • MR.YAREMA: Object to the form.
  • Q Alan Dershowitz is also somebody that you also know to have been at the house when L.M. was being sexually abused in Jeffrey Epstein’s bedroom, correct?
    • MR.YAREMA: Object to the form.
  • Q Generally, Alan Dershowitz is familiar with Jeffrey Epstein’s habit of engaging in sexual acts with minors on a daily basis, correct?
    • MR.YAREMA: Object to the form.
  • Q When Alan Dershowitz was in town, Jeffrey Epstein did not break his schedule for

54

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Alan Dershowitz, meaning he continued to sexually abuse minors despite Alan Dershowitz being a guest in the house?

MR.YAREMA: Object to the form. A Fifth.

Q Alan Dershowitz never engaged in any sexual activity with these underage minors; isn’t that true?

MR.YAREMA: Object to the form. A Fifth.

Q Have you been made to have sex with Ghislaine Maxwell?

MR.YAREMA: Object to the form. A Fifth.

Q Do you know Emmy Taylor?

A Fifth.

Q Similar to you being Jeffrey Epstein’s sex slave, is Emmy Taylor, or was Emmy Taylor Ghislaine Maxwell’s sex slave?

MR.YAREMA: Object to the form. A Fifth.

Q Ghislaine Maxwell is somebody who you know to be bi-sexual, true?

MR.YAREMA: Object to the form. A Fifth.

Q You know that Ghislaine Maxwell engaged in sexual acts with underage minor females, true?

MR.YAREMA: Object to the form. A Fifth.

Q This is yet another friend of Jeffrey Epstein’s that is into the act of molesting underage minor females, right?

MR.YAREMA: Object to the form. A Fifth.

Q Now, you are the next participant in that activity, meaning you have been groomed to enjoy and appreciate the acts of sex with underage minors, true?

MR.YAREMA: Object to the form. A Fifth.

Q Has Jeffrey Epstein instructed you to lie to his Probation Officer in any way?

MR.YAREMA: Object to the form. A Fifth.

Q Mr. Visoki testified that you took a helicopter flight within the last year with Jeffrey Epstein to Miami. Do you remember that flight?

MR.YAREMA: Object to the form. A Fifth.

Q What was the purpose of that flight?

MR.YAREMA: Object to the form. A Fifth.

Q Did you sign a confidentiality agreement with Jeffrey Epstein?

MR.YAREMA: Object to the form. A Fifth.

Q When is the last time that you observed Jeffrey Epstein have sex with a minor?

MR.YAREMA: Object to the form. A Fifth.

Q Since being on probation, has Jeffrey Epstein been able to, or has he flown to his island?

MR.YAREMA: Object to the form. A Fifth.

Q To your knowledge, has Jeffrey Epstein flown to New York while on probation or community control?

MR.YAREMA: Object to the form. A Fifth.

Q Isn’t it true that he has flown both to New York and to his island, and you have accompanied him on those trips, since he was on community control?

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in New York?

A Fifth.

Q And the money in that bank account under your name is money that was given to you by Jeffrey Epstein, correct?

MR. YAREMA: Object to the form.

A Fifth.

Q For the passed ten or so years, you have lived with Jeffrey Epstein under his control, right?

MR. YAREMA: Object to the form.

A Fifth.

Q You get to lead the life of a millionaire, and to lead that life, you were only required to be Jeffrey Epstein’s sex slave and to bring Jeffrey Epstein other slaves?

MR. YAREMA: Object to the form.

A Fifth.

Q Is this 301 East 66th Street apartment still an apartment that you frequent today?

MR. YAREMA: Object to the form.

A Fifth.

Q And you’re familiar with the nine or ten apartments that Jeffrey Epstein owns or controls up there at 301 East 66th Street, aren’t you?

64

Thomas, then generically, female, female; would you know who those female, females are?

MR. YAREMA: Object to the form.

A Fifth.

Q Are those females listed generically rather than specifically because they are underage minor females engaging in sex with you or Jeffrey Epstein?

MR. YAREMA: Object to the form.

A Fifth.

Q Is Story Cowles someone that you see on a regular basis at Jeffrey Epstein’s house?

MR. YAREMA: Object to the form.

A Fifth.

Q That’s somebody who these days refers to himself as Jeffrey Epstein’s personal assistant, right?

MR. YAREMA: Object to the form.

A Fifth.

Q That’s somebody who you know to work for or at the Florida Science Foundation, which is owned by Jeffrey Epstein, correct?

MR. YAREMA: Object to the form.

A Fifth.

Q It is also somebody that you know to have stayed at Jeffrey Epstein’s house with , correct?

MR. YAREMA: Object to the form.

A Fifth.

Q This is somebody that has been involved — Story Cowles is somebody who’s been involved sexually with for at least a year, right?

MR. YAREMA: Object to the form.

A Fifth.

Q In fact, you know that they took a trip around the world together and during that trip they discussed Jeffrey Epstein and his interaction with underage minor females,

correct?

MR. YAREMA: Object to the form.

A Fifth.

MR. EDWARDS: Done. I don’t have anything else.

MR. GOLDBERGER: Okay.

MR. HOROWITZ: I do, why don’t we take a short break.

MR. GOLDBERGER: We are stopping at 11:50.

MR. HOROWITZ: What?

MR. GOLDBERGER: 11:50.

MR. HOROWITZ: I kind of remember that e-mail.

THE VIDEOGRAPHER: Off the video record.

(Pause in the proceedings.)

THE VIDEOGRAPHER: We are back on the video record at 11:18 a.m.)

(At this time Robert Critton joined the proceedings.)

CROSS EXAMINATION

BY MR. HOROWITZ:

Q Ms. , between 2001 and 2006, did Jeffrey Epstein instruct you to place telephone calls to arrange for girls under the

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age of 18 to come to his home for his sexual gratification? MR.YAREMA: Object to the form. A Fifth.

Q Between 2001 and 2006 did you, in fact, place telephone calls to arrange for girls under the age of 18 to come to Jeffrey Epstein’s home for his sexual gratification? MR.YAREMA: Object to the form. A Fifth.

Q Are you personally aware that a girl named M.L. came to Jeffrey Epstein’s Palm Beach home in late 2004? MR.YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein admit to you he sexually abused M.L.? MR.YAREMA: Object to the form. A Fifth.

Q Isn’t it true in late 2004 you made arrangements by telephone to bring M.L. to Jeffrey Epstein’s home? MR.YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein instruct you to communicate by telephone with the purpose of bringing Y.L. to Jeffrey Epstein’s home for sexual activity MR.YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein instruct you to communicate with the purpose of making arrangements for Y.L. to come to his home? MR.YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein tell you it was his intent during the course of M.L.’s visit to his home to persuade, induce or entice her to engage in sexual activity? MR.YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein tell you that, in fact, he succeeded in persuading, inducing or enticing M.L. to engage in sexual activity with him? MR.YAREMA: Object to the form. A Fifth.

Q Are you personally aware that a girl named Y.L. came to Jeffrey Epstein’s Palm Beach home on multiple occasions in 2004? MR.YAREMA: Object to the form.

A Fifth.

Q Did Jeffrey Epstein admit to you that he sexually abused Y.L. in his Palm Beach home in 2004? MR.YAREMA: Object to the form. A Fifth.

Q Did you ever instruct a girl named to bring other undergirlges to Jeffrey Epstein’s home for Jeffrey Epstein’s sexual pleasure? MR.YAREMA: Object to the form. A Fifth.

Q In 2004 did you communicate by telephone with the purpose of bringing Y.L. to Jeffrey Epstein’s home for sexual activity MR.YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein instruct you to communicate with the purpose of making arrangements for Y.L. to come to his home? MR.YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein tell you it was his intent during the course of Y.L.’s visit to his home to persuade, induce or entice her to engage in sexual activity with him? MR.YAREMA: Object to the form. A Fifth.

Q Are you personally aware that a teenage girl named Y.L. came to Jeffrey Epstein’s Palm Beach home on multiple occasions between 2003 and 2005? MR.YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein admit to you that he sexually abused Y.L.? MR.YAREMA: Object to the form. A Fifth.

Q At any time prior to May of 2005, did Jeffrey Epstein instruct you to place telephone calls to the purpose of arranging for her to come to his home and engage in sexual activity? MR.YAREMA: Object to the form.

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A Fifth. Q Did you, in fact, communicate by telephone with [ ] for the purpose of arranging for her to come to his home for sexual activity? MR. YAREMA: Object to the form. A Fifth. Q At any time prior to May of 2005, did you place a telephone call to [ ] wherein you arranged for [ ] to come to Jeffrey Epstein’s home for sexual activity? MR. YAREMA: Object to the form. A Fifth. Q Prior to May of 2005, did you ever observe [ ] speaking with [ ] by telephone to arrange for [ ] to come to Jeffrey Epstein’s home? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein tell you that it was his intention to sexually abuse [ ] during the course of her visit to his home? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein tell you that he succeeded in engaging [ ] in sexual activity

while she was still a minor, at his home? MR. YAREMA: Object to the form. A Fifth. Q Are you personally aware that a teenage girl named an A.G., came to Jeffrey Epstein’s Palm Beach home in approximately 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein admit to you that he sexually abused A.G. at his home while she was still a child? MR. YAREMA: Object to the form. A Fifth. Q In 2001 or 2002, did [ ] inform you that she received a telephone call in which she was referred to A.G., who would be willing to come to Jeffrey Epstein’s home for sexual activity? MR. YAREMA: Object to the form. A Fifth. (Whereapon, at this point in the proceedings, Robert Critton left the deposition room.) Q Did Jeffrey Epstein instruct you to call A.G. to come to his home and give him a massage

in either 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Did you, in fact, call A.G. to come to Jeffrey Epstein’s home and give him a massage in a sexual nature in 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Did you either observe or overhear [ ] speaking with A.G. on the telephone to arrange for A.G. to come to Jeffrey Epstein’s home for a massage of a sexual nature? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein tell you it was his intent during the course of A.G.’s visit to his home to persuade, induce or entice her to engage in sexual activity? MR. YAREMA: Object to the form. A Fifth. Q Didn’t Jeffrey Epstein admit to you that he succeeded in persuading, inducing or enticing A.G. to engage in sexual activity with him at his home while she was still a minor? MR. YAREMA: Object to the form.

A Fifth. Q Are you personally aware that a girl named [ ] came to Jeffrey Epstein’s home in approximately August 2004? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein admit to you that he had sexually abused [ ] when she was only 13 years old? MR. YAREMA: Object to the form. A Fifth. Q In 2004 did you participate in a telephone call wherein you arranged for [ ] to come to Jeffrey Epstein’s home for the purpose of giving him a massage that was to be sexual in nature? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein instruct you to communicate by telephone and make arrangement for [ ] to come to his home for sexual activity while she was still a child? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein tell you it was his

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intention during the course of J.M.’s visit to his home to persuade, induce or entice her to engage in sexual activity with him? MR. YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein tell you that, in fact, he succeeded in persuading, inducing and enticing J.M. to engage in sexual activity with him while she was still a child at his home?* MR. YAREMA: Object to the form. A Fifth.

Q Are you personally aware that a girl named F.P. came to Jeffrey Epstein’s home in Palm Beach on multiple occasions between 2003 and May 2005? MR. YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein admit to you that he sexually abused F.P. at his home between 2003 and May 2005? MR. YAREMA: Object to the form. A Fifth.

Q Prior to May of 2005, did you receive a phone call from a girl named J.M. wherein she told you she was bringing F.P. to Jeffrey*

Epstein’s home to give him a massage? MR. YAREMA: Object to the form. A Fifth.

Q At any time prior to 2005, did Jeffrey Epstein instruct you to communicate with J.M. by telephone to make arrangements for F.P. to come to his home?* MR. YAREMA: Object to the form. A Fifth.

Q Prior to F.P.’s visits to Jeffrey Epstein’s home, did Jeffrey Epstein tell you it was his intention to induce, entice and engage F.P., to engage in sexual activity with him? MR. YAREMA: Object to the form. A Fifth.

Q After F.P.’s visits to Jeffrey Epstein’s home, did Jeffrey Epstein tell you that he succeeded in enticing, engaging and persuading F.P. to engage in sexual activity with him while she was still a child? MR. YAREMA: Object to the form. A Fifth.

Q Are you personally aware that a teenage girl named J.M. came to Jeffrey Epstein’s Palm Beach home in approximately 2001 or 2002?

MR. YAREMA: Object to the form. A Fifth.

Q Did you participate in a telephone call wherein you arranged for J.M. to come to Jeffrey Epstein’s home for a massage? MR. YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein instruct you to participate in a telephone call wherein you were to arrange for J.M. to come to his home for sexual activity? MR. YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein admit to you it was his intention during the course of J.M.’s visit to his home, to engage her in sexual activity while she was still a child? MR. YAREMA: Object to the form. A Fifth.

Q Did Jeffrey Epstein admit to you he had, in fact, persuaded, enticed and engaged J.M. in sexual activity at his home while she was still a child? MR. YAREMA: Object to the form. A Fifth.

MR. HOROWITZ: No other questions at this point. MR. LANGINO: I have less than ten minutes of questioning. MR. GOLDBERGER: Fine, that will bring us right to the break. CROSS EXAMINATION BY MR. LANGINO: Q I’m Adam Langino and I represent B.B. and C.L. Do you know an individual named B.B.? A Fifth. Q Do you know an individual named C.L.? A Fifth. Q Have you seen B.B. at the defendant’s Palm Beach property? MR. YAREMA: Object to the form. A Fifth. Q Have you seen C.L. at the defendant’s Palm Beach property? MR. YAREMA: Object to the form. A Fifth. Q Have you ever engaged in a sexual act with B.B…B.B.? MR. YAREMA: Object to the form.

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  1. A Fifth.
  2. Q Have you ever engaged in a sexual act with C.L… C.L.?
  3. MR.YAREMA: Object to the form.
  4. A Fifth.
  5. Q Did you ever observe the defendant, Jeffrey Epstein, with B.B.?
  6. MR.YAREMA: Object to the form.
  7. A Fifth.
  8. Q Did you ever observe the defendant, Jeffrey Epstein, with C.L.?
  9. MR.YAREMA: Object to the form?
  10. A Fifth.
  11. Q Have you ever physically touched B.B.?
  12. MR.YAREMA: Object to the form.
  13. A Fifth.
  14. Q Have you ever physically touched C.L.?
  15. MR.YAREMA: Object to the form.
  16. A Fifth.
  17. Q Has the defendant ever made a statement to you about B.B.?
  18. MR.YAREMA: Object to the form.
  19. A Fifth.
  20. Q Has the defendant ever made a statement to you about C.L.?
  21. MR.YAREMA: Object to the form.
  22. MR.YAREMA: Object to the form.
  23. A Fifth.
  24. Q Has the defendant ever made a statement to you about C.L.?

79

  1. MR.YAREMA: Object to the form.
  2. A Fifth.
  3. Q Has ever made a statement to you about B.B.?
  4. MR.YAREMA: Object to the form.
  5. A Fifth.
  6. Q Has ever made a statement to you about C.L.?
  7. MR.YAREMA: Object to the form.
  8. A Fifth.
  9. Q Have you ever communicated with B.B.?
  10. MR.YAREMA: Object to the form.
  11. A Fifth.
  12. Q Have you ever communicated with C.L.?
  13. MR.YAREMA: Object to the form.
  14. A Fifth.
  15. Q Have you ever communicated with C.L.?
  16. MR.YAREMA: Object to the form.
  17. A Fifth.
  18. Q Did you know that B.B., B.B. was a minor at the time of sexual abuse?
  19. MR.YAREMA: Object to the form.
  20. A Fifth.
  21. Q Did you know C.L… C.L. was a minor at the time of sexual abuse?
  22. MR.YAREMA: Object to the form.
  23. A Fifth.
  24. Q Do you know if B.B.’s sexual activity

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  1. with the defendant was consensual?
  2. MR.YAREMA: Object to the form.
  3. A Fifth.
  4. Q Do you know if C.L.’s sexual activity with the defendant was consensual?
  5. MR.YAREMA: Object to the form.
  6. A Fifth.
  7. Q When you participated in sexual acts with each minor, how did you feel?
  8. MR.YAREMA: Object to the form.
  9. A Fifth.
  10. Q In your heart, did you know it was wrong?
  11. MR.YAREMA: Object to the form, and in addition this is irrelevant and has already been addressed by Judge Hafele as an inappropriate question. That’s my objection.
  12. A Fifth.
  13. Q During this time period did you feel confused?
  14. MR.YAREMA: Object to the form.
  15. MR.GOLDBERGER: Same —
  16. MR.YAREMA: Same objection.
  17. A Fifth.

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  1. Q Are you currently in love with the defendant?
  2. MR.YAREMA: Object to the form, same objection. That question has no relevance to this… it is inappropriate per Judge Hafele’s order.
  3. MR.GOLDBERGER: Also involves privacy rights of my client. I instruct her not to answer the question.
  4. A Fifth.
  5. Q Have you ever been in love with Jeffrey Epstein?
  6. MR.GOLDBERGER: Same objection.
  7. MR.YAREMA: Same objections.
  8. A Fifth.
  9. MR.LANGINO: Thank you.
  10. CROSS EXAMINATION BY MS.EZELL:
  11. (Discussion off the record.)
  12. Q Good morning, Ms. I’m Katherine Ezell and I represent Jane Doe 103, whose name is A.H. which shall appear as A.H. in the deposition.
  13. Are you aware that in 2004 and 5, there was a sort of hidden staircase that would take

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one from the kitchen upstairs to the master bedroom and massage area? MR. YAREMA: Object to the form. A Fifth.

Q Do you recall there being nude photographs on the staircase? MR. YAREMA: Object to the form. A Fifth.

Q Did you know A.H.? A Fifth.

Q Did A.H. come to the house at 358 El Brillo Way to provide a massage to Jeffrey Epstein? MR. YAREMA: Object to the form. A Fifth.

Q Did that massage become sexual in nature? MR. YAREMA: Object to the form. A Fifth.

Q Did A.H. become a regular visitor at Jeffrey Epstein’s house? MR. YAREMA: Object to the form. A Fifth.

Q Do you remember that she came maybe hundreds of times?

MR. YAREMA: Object to the form.

Q Do you recall that she was under the age of 18 at the time she was coming to Jeffrey Epstein’s home? MR. YAREMA: Object to the form. A Fifth.

Q Were you younger than A.H. at the time? MR. YAREMA: Object to the form. A Fifth.

Q Do you remember occasions when you and Jeffrey Epstein were already in bed when A.H. arrived? MR. YAREMA: Object to the form. A Fifth.

Q Do you recall Jeffrey Epstein instructing A.H. to remove her clothes and join the two of you in bed? MR. YAREMA: Object to the form. A Fifth.

Q Do you recall that you and Jeffrey Epstein bring sex toys in bed for you and A.H. to use on each other? MR. YAREMA: Object to the form. A Fifth.

Q Do you recall that you and Jeffrey Epstein bring sex toys in bed for you and A.H. to use on each other? MR. YAREMA: Object to the form. A Fifth.

Q Do you recall that Jeffrey Epstein would join in by performing oral sex on one or the other of you — you or A.H.? MR. YAREMA: Object to the form. A Fifth.

Q Do you recall that also happening, meaning the oral sex, being performed on the massage table — MR. YAREMA: Objection.

Q — to A.H.? MR. YAREMA: Object to the form. A Fifth.

Q Were you present one day when Jeffrey Epstein held A.H. down on the massage table and while holding her inserted his penis into A.H.’s vagina? MR. YAREMA: Object to the form. A Fifth.

Q Do you recall he stated that he wanted you to observe this? MR. YAREMA: Object to the form. A Fifth.

Q Do you recall that A.H. had rules, lines, that she had stated Jeffrey Epstein was not to cross, in their encounters?

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was under 18?

MR. YAREMA: Object to the form.

A Fifth.

Q Did Jeffrey Epstein watch you and A.H. having sex while he masturbated?

MR. YAREMA: Object to the form.

A Fifth.

Q Are you aware that A.H.’s activities with Jeffrey Epstein escalated further and further as time went on?

MR. YAREMA: Object to the form.

A Fifth.

Q Did you see Jeffrey Epstein use vibrators and strap-on — use vibrators on A.H.?

MR. YAREMA: Object to the form.

A Fifth.

Q Did you and A.H. engage in sex with strap-on penises?

MR. YAREMA: Object to the form.

A Fifth.

Q Did you see Jeffrey Epstein perform oral sex on A.H. numerous times?

MR. YAREMA: Object to the form.

A Fifth.

Q Did Jeffrey Epstein pay A.H. an

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additional $200 to perform oral sex on you?

MR. YAREMA: Object to the form.

A Fifth.

Q Do you recall that each time a new toy or activity was introduced when A.H. was there to give massages, Jeffrey Epstein paid A.H. additional money?

MR. YAREMA: Object to the form.

A Fifth.

Q Would Jeffrey Epstein masturbate while watching you and A.H. perform sexual acts?

MR. YAREMA: Object to the form.

A Fifth.

Q Do you recall that Jeffrey Epstein provided A.H. with gifts of purses and bathingsuits?

MR. YAREMA: Object to the form.

A Fifth.

Q Do you recall that Jeffrey Epstein provided A.H. with a blue 2000 Dodge Neon which had been rented for her?

MR. YAREMA: Object to the form.

A Fifth.

Q Do you recall that Jeffrey Epstein ordered that roses be delivered to A.H. at the

end of a play performance during her senior year?

MR. YAREMA: Object to the form.

A Fifth.

THE VIDEOGRAPHER: Counsel, can we stop for one minute?

MS. EZELL: Sure.

THE VIDEOGRAPHER: Off the video record 11:43 a.m.

(Short pause.)

(Whereupon at this point in time, Mr. Langino left the proceedings.)

THE VIDEOGRAPHER: Back on the video record 1:43 a.m.

CROSS EXAMINATION (CONTINUED)

BY MS. EZELL:

Q Were you present in October 2005 when the Palm Beach Police Department raided Jeffrey Epstein’s home?

MR. YAREMA: Object to the form.

A Fifth.

Q You and others were aware that there would be a raid at that time; were you not?

MR. YAREMA: Object to the form.

A Fifth.

Q Who informed you that there would be a

raid on the house?

MR. YAREMA: Object to the form.

A Fifth.

Q Did you participate in the removal σ?

that time?
MR.YAREMA: Object to the form.
A Fifth.
Q Do you remember that at times Jeffrey

Epstein paid A.H. to just sleep in his bed in the nude?

MR. YAREMA: Object to the form.

A Fifth.

Q Do you recall at times he paid here

just cuddle with him?

MR. YAREMA: Object to the form.

A Fifth.

Q Did you ever drive A.H. to or from 358

El Brillo Way?

MR. YAREMA: Object to the form.

A Fifth.

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Q Did you ever know to drive A.H. to or from 358 El Brillo Way? MR. YAREMA: Object to the form. A Fifth.

Q Do you remember the houseman at that time as being Alfredo Rodriguez? MR. YAREMA: Object to the form. A Fifth.

Q Do you remember Alfredo Rodriguez being instructed to drive A.H. to or from 358 El Brillo Way? MR. YAREMA: Object to the form. A Fifth.

Q Do you recall a time when Alfredo Rodriguez discovered A.H. asleep upstairs naked? MR. YAREMA: Object to the form. A Fifth.

Q Were you aware Jeffrey Epstein repeatedly asked A.H. to allow him to photograph her in the nude? MR. YAREMA: Object to the form. A Fifth.

Q Did you allow Jeffrey Epstein to take photographs, nude photographs of you? MR. YAREMA: Object to the form.

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A Fifth.

Do you recall a time when A.H. gave in and did allow Jeffrey Epstein to photograph her while nude? MR. YAREMA: Object to the form. A Fifth.

Did you ever see any of those photographs taken by Jeffrey Epstein of A.H. in the nude? MR. YAREMA: Object to the form. A Fifth.

Do you know what kind of camera Jeffrey Epstein liked to use when taking photographs of women posing in the nude? MR. YAREMA: Object to the form. A Fifth.

Did you ever hear here Jeffrey Epstein tell A.H. that she needed to lose ten pounds? MR. YAREMA: Object to the form. A Fifth.

Did you ever hear here him tell her that he would pay her 1,000 or $1,500 if she would lose ten pounds? MR. YAREMA: Object to the form. A Fifth.

Q Did you know A.H. to be a good student? MR. YAREMA: Object to the form. A Fifth.

Q Did it appear that you that A.H. was smart? MR. YAREMA: Object to the form. A Fifth.

Q Did you observe that A.H. was concerned about her grades? MR. YAREMA: Object to the form. A Fifth.

Q Do you recall Jeffrey Epstein expressing interest in A.H.’s college ambitions? MR. YAREMA: Object to the form. A Fifth.

Q Have you known Jeffrey Epstein to brag about donations he’s made to colleges like NYU, Columbia, Harvard and Wharton? MR. YAREMA: Object to the form. A Fifth.

Q Do you know that A.H. wanted very much

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to go to school in New York at NYU or at Columbia? MR. YAREMA: Object to the form. A Fifth.

Q Did you know that Jeffrey Epstein promised to help her get into one of those schools? MR. YAREMA: Object to the form. A Fifth.

Q Do you know whether he did help? MR. YAREMA: Object to the form. A Fifth.

Q Do you know whether he offered to pay some of her college expenses? MR. YAREMA: Object to the form. A Fifth.

Q Did you ever observe Jeffrey Epstein working with A.H. on her college applications? MR. YAREMA: Object to the form. A Fifth.

Q Did you ever see A.H. just hanging out at Jeffrey Epstein’s house studying while nude? MR. YAREMA: Object to the form. A Fifth.

Q Did you know that Jeffrey Epstein gave

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A.H. airline tickets and theater tickets in New York?

MR. YAREMA: Object to the form. A Fifth.

Q Did you and A.H. ever go shopping together?

MR. YAREMA: Object to the form. A Fifth.

Q Did you call A.H. once and ask her to go shopping with you for Jeffrey Epstein on his birthday?

MR. YAREMA: Object to the form. A Fifth.

Q Did you and A.H. purchase adult sex toys to use for Jeffrey Epstein’s birthday, as a show, for him?

MR. YAREMA: Object to the form. A Fifth.

Q Are you aware that Jeffrey Epstein told A.H. he would pay her to bring other young girls to give him massages?

MR. YAREMA: Object to the form. A Fifth.

Q Do you know that Jeffrey Epstein paid A.H.$200 for each girl that she brought to him,

to give him a massage?

MR. YAREMA: Object to the form. A Fifth.

MR. GOLDBERGER: I guess we will have to take a break now, if that’s all right with you.

MS. EZELL: Okay.

THE VIDEOGRAPHER: 11:50 a.m., going off the video record.

MR. GOLDBERGER: I will be done at 1:15 so we can go until 1:30.

(Pause in the proceedings.)

THE VIDEOGRAPHER: We are back on the video record at 1:36 p.m.

CROSS EXAMINATION (CONTINUED)

BY MS. EZELL:

Q Ms. … did you ever have dinner at Jeffrey Epstein’s house, with David Copperfield as a guest, when A.H. was present?

MR. YAREMA: Object to the form. A Fifth.

Q Have you met David Copperfield?

A Fifth.

Q Have you ever been given tickets to go see one of his shows?

A The Fifth.

Q Do you know if typically girls who Epstein knew, were given tickets to go to the show, then invited back stage?

MR. YAREMA: Object to the form.

A Fifth.

THE VIDEOGRAPHER: Can you speak up?

THE WITNESS: (Adjust microphone.)

Q Did A.H. ever tell you that David Copperfield tried to feel her batt during dinner?

MR. YAREMA: Object to the form.

A Fifth.

Q Did you ever hear Jeffrey Epstein telling any of the young women who came to give him massages, that he was a brain scientist?

MR. YAREMA: Object to the form.

A Fifth.

Q Did you know A.D.?

A Fifth.

Q And from now on I will use the initials A.D. Do you know that A.D. visited Jeffrey Epstein at 358 El Brillo Way some 15 to 20 times?

MR. YAREMA: Object to the form.

Q Did you ever interact with A.D. while

she was there to give a massage?

MR. YAREMA: Object to the form.

A Fifth.

Q Did you know that at the time she was visiting Mr. Epstein and providing massages, she was under the age of 18?

MR. YAREMA: Object to the form.

Q Do you recall being introduced to A.D. by Mr. Epstein?

MR. YAREMA: Object to the form.

A Fifth.

Q Do you recall that Jeffrey Epstein instructed you and A.D. to kiss and fondle each other around the breasts and buttocks while massaging him?

MR. YAREMA: Object to the form.

A Fifth.

Q Did you ever see Mr. Epstein use a large vibrator/massager on A.D.?

MR. YAREMA: Object to the form.

A Fifth.

Q Did Jeffrey Epstein ever ask you to purchase a digital camera for him to give A.D.?

MR. YAREMA: Object to the form.

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A Fifth. Q Did you know that Jeffrey Epstein gave A.D. a digital camera? MR. YAREMA: Object to the form. A Fifth. MS. EZELL: I don’t have any other questions. Thank you. MR. GOLDBERGER: You still have your microphone on. You must have something on your mind, Brad. REDirect Examination by MR. EDWARDS: Q Ms. through the whole day you’ve taken the Fifth on just about every single question. Is there any reason why we should not presume that the answer to these questions would incriminate you? MR. YAREMA: Object to the form. A The Fifth. Q The reason that you have taken the Fifth is because the questions you have been asked would have been answered in the affirmative and you’re afraid of prosecution for your involvement, true? MR. GOLDBERGER: Don’t answer that

question. It interferes with the attorney/client relationship that I have with Ms. and any discussions she and I may have had would come under that privilege. You can try and dance around that, but I’m simply not going to allow her to answer that question. If you want to bring it up with the Judge, you can. MR. EDWARDS: Thanks, Jack. MR. GOLDBERGER: Okay. THE VIDEOGRAPHER: Off the video record at 1:41 p.m. THE COURT REPORTER: You’re ordering this, Brad? MR. EDWARDS: Yes. Copies? MS. EZELL: Yes. MR. YAREMA: Yes. THE COURT REPORTER: And Adam wanted it is that right? MR. EDWARDS: Yes. (Time noted: 1:45 p.m.)

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above-entitled3:2,12 100:8adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
above-named 3:1358:2 70:20adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
abuse 40:8,1879:18,22adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
abused 40:1348:6 55:13adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
8:7,58 16:4168:3 69:17adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
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abuses 41:9abuses 41:9adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
abusing 40:1649:4,10 55:15adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
academicians48:22adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
access 29:8,1329:8 30:2adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
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accompanied60:24adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
account 39:2561:25 62:3adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
61:25 62:3accurate 39:25adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
accurate ledged101:6adjusted 5:226:10,15,24adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
acquaintances48:23agree 22:21 23:5adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
act 28:16 46:2048:23 46:20adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8adjusted 126:8
59:6 61:1959:6 61:19agree 104:13adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
72:78 79:872:78 79:8agree 104:13adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
action 3:12100:8,15,16airline 91:4adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
actions 42:1942:19airplane 48:12adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
activities 86:886:852:10,14adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
activity 11:1115:14 54:1455:20 63:9adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
25:11 54:1456:18,7airplanes 40:24adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
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75:19 76:1175:19 76:1157:18,24 58:11adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
76:16,2276:16,22allow 25,29 29:20adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
79:25 80:479:25 80:4allow 25,29 29:20adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
87:587:5allow 25,29 29:20adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
acts 16:23 28:816:23 28:8allow 25,29 29:20adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
30:18 30:730:18 30:7allow 25,29 29:20adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
31:10 40:2331:10 40:23allow 25,29 29:20adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
41:27 47:641:27 47:6allow 25,29 29:20adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
45:27 47:645:27 47:6allow 25,29 29:20adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
56:27 57:2056:27 57:20allow 25,29 29:20adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
58:27 61:2558:27 61:25allow 25,29 29:20adjusted 5:22adjusted 80:16adjusted 96:8adjusted 106:8adjusted 116:8adjusted 126:8
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donations 92:2168:25 72:1784:14,24executed 51:2
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dress 49:2 50:3encircled 39:1086:4,9,13,21exhibit 45:12,15
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duties 89:2217:1387:14,19,24EXHIBITS 24:10
duly 3:100:9encircled 30:687:14,24expenses 93:14
duties 21:869:1680:23 91:3,8100:22
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85:25 86:1763:10 19,48escape 24,5,10feebury 5:10
engaged 10:2364:24 65:24escape 24,5,10feebury 5:11
50:8 88:666:16 25,75escape 24,5,10feebury 5:10
59:1 76:2167:10 16,82et 1735:24 36:12
77:23 78:68:18 69:44et 1735:24 36:12
engaging 22:1069:16,21et 1735:24 36:12
50:22 56:2,870:10 72,19,17et 1735:24 36:12
52:19 86:1770:12 74,25,19et 1735:24 36:12
70:25 75:1873:21 73,19,17et 1735:24 36:12
enjoy 13:5 59:1273:25 74,6,18examination 5:635:24 36:12
ENTER 103:375:5,11,17examination 5:635:24 36:12
entering 104:1576:8,14,20examination 5:635:24 36:12
enterprise 43:1178:7,11 81,12examination 5:635:24 36:12

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Patent NumberDateInventor(s)ClassificationApplication
42:12, 17, 2289:3, 18, 12, 1714:25, 15:4, 1069:8, 14, 18, 25genital 17:10
43:3, 9, 13, 1889:21, 25, 90:415:15, 20, 2570:5, 11, 17, 22getting 25:25
43:21, 25, 44:489:0, 13, 17, 2216:9, 14, 20, 2571:2, 7, 12, 1957:8
44:25, 45:7, 989:1, 20, 24, 92:418:3, 18, 13, 1872:25, 73, 51:0Globine 29:17
46:1, 6, 11, 1389:2, 7, 11, 15, 1918:29, 17, 1272:25, 73, 74:433:11, 34:20
46:19, 23, 47:389:24, 93:4, 919:16, 23, 20:474:10, 16, 2158:12, 19, 22
47:9, 11, 18, 2289:12, 16, 2010:21, 19, 2474:10, 2, 14, 2159:1
47:24, 48:9, 1489:32, 94:4, 821:5, 11, 1976:1, 6, 12, 18gifts 49:8, 87:15
48:14, 6, 1689:32, 94:4, 821:5, 11, 1976:1, 6, 12, 18Globine 29:17
49:12, 17, 2389:32, 94:4, 823:22, 24, 3773:21, 78, 1458:12, 68:7
49:25, 50:5, 1089:12, 16, 1224:12, 17, 2278:8, 12, 15, 1869:11, 71, 15
60:16, 20, 2589:16, 29, 47:325:3, 17, 25, 2278:22, 79, 1, 573:24, 74:22
51:13, 19, 2287:8, 12, 18, 2226:2, 7, 17, 2379:9, 12, 15, 1975:24, 94:25
52:1, 3, 17, 2287:8, 15, 14, 1927:4, 10, 17, 2379:23, 80, 2, 6girlfriend 19:10
53:1, 7, 12, 2589:12, 16, 2023:22, 24, 3773:21, 78, 1462:28, 68:7
53:6, 12, 2387:8, 15, 14, 1928:23, 29, 4, 1081:3, 82, 3, 769:11, 71, 15
54:1, 7, 12, 27file 3:1129:15, 30, 3381:3, 82, 14, 1873:24, 74:22
54:17, 21, 55:2financial 9:1030:9, 17, 2183:1, 6, 9, 1475:24, 94:25
55:4, 21, 11, 179:1531:2, 7, 12, 1883:19, 24, 84, 466:6, 68:8
55:24, 56:5, 11financially 8:1731:23, 32, 6, 1184:11, 17, 21, 266:6, 68:8
57:15, 17, 1290:10, 10, 1533:19, 35, 14, 985:11, 17, 2666:6, 68:8
58:15, 10, 14, 16financial 10:1435:13, 16, 2586:6, 11, 15, 1966:6, 68:8
58:21, 25, 59:4fine 5:3, 12, 2136:5, 10, 16, 2086:23, 87, 2, 871:25, 72, 5
59:19, 15, 19, 25first 5:3, 12, 2137:24, 37, 4, 1087:12, 17, 2271:25, 72, 5
60:3, 7, 11, 1626:4, 30, 3537:25, 32, 8, 1287:12, 17, 2294:21, 95:1
60:17, 7, 12, 1860:17, 7, 12, 1838:19, 18, 18, 1888:2, 19, 2394:17, 94:17
61:22, 17, 24FISTOS 3:1640:3, 9, 12, 1489:20, 24, 90, 393:16, 62, 4
62:22, 17, 28flagler 4:940:3, 9, 12, 1489:20, 12, 16, 2163:13, 95, 24
62:22, 63, 27flew 5:6!40:25, 41, 5, 1090:25, 91, 5, 1063:13, 95, 24
63:15, 21, 25flight 5:2, 4, 1941:15, 20, 2591:14, 9, 14, 23giving 67:16
63:15, 62, 14glaucous 6:1, 10, 1441:25, 20, 2591:14, 9, 14, 23Glenn 55:3
65:13, 66, 4, 10flights 5:2, 9, 943:2, 8, 12, 1792:18, 23, 93, 33go 23:2, 34:9
65:13, 66, 4, 10flights 5:2, 9, 943:2, 8, 12, 1792:18, 23, 93, 33go 23:2, 34:9
72:13, 8, 14, 20100:19, 1245:2, 40, 5, 1093:23, 94, 3, 739:4, 93, 11
72:13, 8, 14, 20100:19, 1249:2, 40, 5, 1095:22, 20, 96, 594:5, 9, 95, 11
73:13, 8, 14, 20101:11, 1449:2, 40, 5, 1097:2, 7, 11, 1795:22, 20, 96, 5
73:13, 8, 14, 18103:18, 104:349:2, 40, 5, 1098:18, 102, 545:8, 63, 11
73:24, 74, 51, 11104:7, 2150:15, 19, 24Fort 3:1995:8, 99, 17
74:12, 74, 51, 11104:7, 2151:6, 12, 18, 21forward 40:27Goldberg 10:4, 6
75:9, 15, 2260:13, 18, 2251:6, 12, 18, 21forward 64:47Goldberg 10:4, 6
75:9, 15, 2260:13, 18, 2252:16, 22, 53France 49:1461:5, 12, 6, 13
72:13, 8, 14, 20fly 56!52:16, 22, 53freqent 62:20glove 5:12, 7, 15
76:25, 77:12follows 3:15, 5:553:25, 54, 61!friend 59:565:12, 7, 15
77:14, 18, 22fondle 97!54:16, 20, 55friend 14:3!65:12, 7, 15
78:1, 19, 13, 13forbidden 85!55:10, 16, 23!39:11, 48, 27, 839:11, 48, 27, 8
78:1, 19, 13, 13forbidden 13:1056:10, 16, 23!40:26, 89, 1439:11, 48, 27, 8
79:16, 20, 2428:21, 42!556:10, 16, 23!40:26, 89, 1439:11, 48, 27, 8
79:16, 20, 24forestes 17!257:16, 22, 58!40:26, 89, 1439:11, 48, 27, 8
80:2, 81, 10, 14foregoing 10!259:13, 20, 24!75:6, 10, 13, 1685:12, 81, 7, 15
80:2, 81, 10, 14foregoing 10!259:3, 18, 14!75:6, 10, 13, 1685:12, 81, 7, 15
80:2, 81, 10, 14foregoing 10!260:15, 10, 2075:6, 10, 13, 1685:12, 81, 7, 15
82:13, 8, 12, 272:25, 8, 17, 1961:23, 62, 61!Ggood 81:20, 92, 5
83:15, 84, 5, 1210:2, 19, 12, 1662:13, 62, 61!growth 29:17government 16:3
83:15, 84, 5, 1210:2, 19, 12, 1662:17, 63, 21!30:1, 37, 13!grade 8:23
84:18, 22, 85, 2210:19, 11, 4, 1862:17, 63, 21!gainning 33:23grade 9:23
85:24, 86, 37, 17foregoing 16!1, 1964:10, 24, 50!41:13!graduation 22:22
86:12, 16, 2012:24, 13, 3, 765:22, 63, 9!44:14!grass 6:22
86:24, 87, 3, 913:11, 15, 2065:22, 63, 9!45:14!grass 6:22
87:13, 18, 2313:25, 14, 4, 767:3, 14, 20generically 63:12, 16grass 6:22
88:3, 20, 2414:11, 17, 2168:16, 21, 62!63:12, 16grass 6:22

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EFTA00181799

H

habit 30:23 57:19 Hafela 80:16 Guest 58:3 95:19 guess 41:18 guise 21:24

half 7:19 Half 10:17 Hanging 45:20 Hanging 93:21 hanging 28:9 34:4 39:25 hanging 84:6 haree 10:22 40:2 harassing 40:6 harm 41:13 Harvard 92:22 head 22:00 23:27 23:10 33:17 hear 91:21,25 96:13 heard 25:9 heart 80:12 held 84:14 85:12 hilcopter 59:21 help 43:16 44:16 help 93:10 63:10 helped 85:2 19:19 hereinafter 5:4 herewith 104:14 heterosexual 11:17 hide 104:14 hires 8:15 holding 84:15 home 45:3 66:17 66:13 67:27 67:28 67:29 68:9 15,20,25 69:12 20,34 70:10,16,21 71:1,6,10,17 72:1,7,12,17 72:17,24,73 73:14,14,74 74:9,13,19 75:13,75,16 75:16,5,10 76:16,22,83 88:18 homemade 50:21 homesite 50:12 hopes 41:13 Horowitz 2:6 32:12,25 68:8 33:17 34:1

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65:7,11 13,22 77:11 104:23 house 21:15 24:24 25:11 26:1,5 13,20 30:14 32:44 38:14 47:45 40:1 46:44,17 46:24 47:55 46:24 47:55 51:4,16 53:33 54:23 24:72 57:17 13 58:3 63:23 64:12 82:11 21 89:11 houseman 90:5 hundreds 29:8 31:16,16 37:20 82:25

intent 18:17,20 41:12 43:55 67:11 68:24 72:16 instructed 70:20 74:1 75:12 76:15 intentionally 17:9 interact 18:11 21:2 96:25 28:13 11:15,17 41:18 48:11 64:25 interactions 27:19 42,3,8 92:17 intended 100:15 interferes 99:1 international 43:22 interpreted 23:7 interpreted 33:24 interpreted 34:11 intimate 10:23 introduced 87:5 87:9 investigate 53:9 invited 96:4 invocation 52:25 invoke 51:13,19 involvement 101:11 involvement 37:41,18 involvement 98:24 involves 91:17 involve 15:14 involve 28:9 irrelevant 80:15 island 22:15,16 23:21 50:23 60:14,23 72:17 52,14 72:17 52,14 74:9,13,19 75:13,75,16 75:16,5,10 76:16,22,83 88:18 homemade 50:21 homesite 50:12 hopes 41:13 Horowitz 2:6 32:12,25 68:8 33:17 34:1

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J9:10 104:8 JAFFE 3:16

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EFTA00181800

life 40:18 42:475:1 76:536:3 78:1, 14103:20 104:10
know 14:19 96:342:10 62:1382:2, 12, 1638:5 40:22named 27:7 30:20
know 8:2, 9:11342:10 62:1382:2, 12, 1641:26 40:15name 5:8 8:2
know 18:2, 9:11342:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 17:17 19:3, 1042:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 20:6 23, 1542:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 25:20 29:6, 1742:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 33:21 34:342:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 36:14 37:342:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 44:5, 7 45:2242:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 47:10, 12, 1642:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 47:19, 2342:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 50:12 52, 2242:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 54:15, 63:942:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 56:22 71, 1642:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 57:13 58:1542:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 58:23 59:142:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 63:13 64, 61, 6142:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 64:23 77:1142:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 77:11 19:1742:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 79:21 80:1442:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 80:12 82:942:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 89:90:142:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 91:12 16 92:542:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 91:13 19:242:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 91:24 19:242:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 94:24 96:2, 1842:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 97:1442:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
know 98:242:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
knowledge 60:1742:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
knowledge 372, 92:2042:10 62:1382:2, 12, 1644:22 40:15named 6:13 11:12
L30:18, 15:1882:2, 12, 1644:22 40:15named 6:13 11:12
labeled 16:736:22, 15:2745:1, 12, 1444:10, 15nonprosecution 16:2
lady 82:1236:22, 15:2745:1, 12, 1444:10, 15nonprosecution 16:2
language 62:17, 4:536:22, 15:2745:1, 12, 1444:10, 15nonprosecution 16:2
language 62:17, 8:3, 836:22, 15:2745:1, 12, 1444:10, 15nonprosecution 16:2
language 62:17, 9:13, 836:22, 15:2745:1, 12, 1444:10, 15nonprosecution 16:2
languages 10:15, 2236:22, 15:2745:1, 12, 1444:10, 15nonprosecution 16:2
languages 10:21, 2436:22, 15:2745:1, 12, 1444:10, 15nonprosecution 16:2
languages 10:22, 22

EFTA00181801

Page 7

12:6,11,15,1965:2 6:6,3932:8,14 39:494:24
12:24 13:3,766:14,18,2340:23 49:7Palm 3;6,7 4:4
13:11,15,2067:3,14,2060:8 61:214:13,18 21:15
13:25 14:4,767:25 68:51,19obsession 12:2255:14,20 56:11
14:11,17,2168:16,21 69:123:7866:12 67:23
14:25 15:4,1068:16,21 69:12obbiasily 5:2466:12 67:23
15:15,20,2570:5,11,17,22occasion 6:2071:6 74:13
15:14,20,2571:2,12,197:5 19:1577:20 88:17
17:5,19,2372:2,13,1925:10 26:14100:2,18,18
18:19,18,1872:2,13,1925:10 26:14100:2,18,18
19:12,12,1274:10,16,2137:20 41:24104:3,7
19:16,23,2075:2,18,14,2149:7 52:15parenta 8:14
10:21,19,2476:1,6,12,1853:3 57:1312:17
21:5,11,1976:1,6,12,1860:8 61:21perfect 17:17 23:24
22:24,23,778:2,17,28,1474:14 83:1114:19 50:1
24:12,17,2278:2,17,28,14October 88:16participant
26:3,7,15,2278:2,17,28,14offered 93:13participant
26:2,7,17,2379:9,12,15,19offera 35:21participant
27:4,0,17,2379:9,12,15,19offera 24:20participant
27:4,0,17,2380:10,10,2659:776:13,9 89:4
28:23,29,4,1081:3,82,3,7official 100:17participated
29:15,23,3081:4,18,22okay 61:3,6 33:2516:22 20:10
30:9,17,2183:1,6,9,1445:25 65:616:22 20:10
31:5,17,1883:1,6,9,1495:7 99:1116:22 20:10
32:32,36,1183:1,6,9,1495:7 99:1116:22 20:10
32:17,23,3485:1,5,9,15oldt 107:11:1216:22 20:10
37:9,15,5,1185:1,9,23,8626:6,10 38:14particularly
35:13,18,2586:6,11,15,1938:25 49:2322:15
36:14,10,1086:6,11,15,1973:9passed 62:8
36:14,10,1086:6,11,15,19oldt 93:13,19passed 62:8
37:15,22,3887:12,17,22once 94:9passed 62:8
38:7,11,1788:2,19,23operate 47:1763:8
39:1,7,13,2189:2,17,11,16operate 21:21pause 65:16 88:9
39:1,7,13,2189:2,17,11,1647:1395:12
39:1,7,13,2190:2,17,28,14operation 30:2495:12
40:25,41,1590:25,91,15,16oil 27:25 28:4495:12
41:15,20,2591:14,19,2328:22 84:2,792:1,93,13
41:15,20,2592:3,6,10,1482:61 87:1794:20
43:2,8,12,1792:3,6,10,14order 81:6pendling 32:29
43:2,8,12,1792:3,6,10,14order 81:6penetration 85:44
43:2,8,12,1792:3,6,10,14order 81:6penis 84:15 85:8

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103:2126:20 27:22100:1164:3,19 77:6see 45:17,22,22
present 4:2129:9 32:20records 89:595:5 99:2045:24 63:22
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95:1956:2REDIRECT 2:3rights 81:893:21 95:25
presume 98:16purses 87:1598:11Robert 51:24 52:2297:19
prince 14:13,16pursus 3:9referred 71:1665:19 71:22seen 50:6 52:4
prior 13:22,51:11pursus 3:9refuses 64:165:19 71:2277:15,19
51:16 69:29p.m.46:9 25 47:5refuses 5:2068:19 88:14senior 88:11
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81:790:15serves 10:22
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privilege 99:56:9 10:21100:3,2143:14 44:14severe 43:1,6
privileges 5:1411:15,18,21104:1,20roles 30:16 71:23sex 10:14 12,5,9
15:17 60:1445:9 47:15registered 63:23ross 20:612:14,18 13:32
10:2452:20 80:1782:20roughly 10:613:5,10,14,18
probation 24:2081:4,9 98:15related 15:6 20:2ROVERN 42:2218:21 20:11
24:24,25 25:699:1,825:18 41:18royalty 48:2322:10 23:19
59:17 60:12questioning 77:454:9rules 84:2323:24 95:4,10
60:18questions 5:21relationship 56:18,23 99:224:15 27:25
proceedings 65:16,2081:4,9 98:15removal 18:2328:4,22 32:11
71:22 88:1198:7,16,21relevance 81:432:3 33:8
95:12quiet 32:16remember 27,6,1237:14 40:23
procure 16:1228:25 53:743:22 44:11
35:16R59:19 75:2944:22 44:11
procured 38:23R5:282:24 83:1150:25 54:25
procedured 34:14raid 88:22 89:1189:13 90:5,956:2 58:11,18
48:22 100:4raised 88:17remove 89:415:9 59:12
100:21 104:1Railroad 3:6remove 83:1760:9 61:15,16
104:20104:2removed 89:961:22 62:15
profit 43:22ranch 22:9rented 87:2163:18 83:22
44:1read 16:2 13:21recreated 90:1984:23 85:22
protected 93:634:15,17rephase 34:1886:15,17,22
prompt 104:16102:18 103:20repeated 100:687:11 89:5
property 77:16102:18 103:20Reporter 3:489:14
77:20104:1334:16 99:14sexual 10:18
prosecution 98:21reading 102:16100:21 104:2011:10 12:22
prosecution 42:15reads 12:8reports 104:111:10 12:22
48:16reask 6reports 104:111:10 12:22
prostitution 40:19reason 34:5reports 104:111:10 12:22
40:19 42:4,10103:5reports 104:111:10 12:22
protect 43:16measures 82:1return 10:1711:10 12:22
provided 87:15caller 82:5 83:3returned 10:1711:10 12:22
61:0083:16,21 84:11requests 5:2012:14,18 13:32
providing 97:584:16,29requested 62:1513:5,10,14,18
psychological 41:1485:16,21 87:14,14residing 9:718:21 20:11
psychology 33:187:19,24resources 40:1122:10 23:19
public 35:1789:18 90:14requested 42:1323:24 95:4,10
101:14 102:1791:2 92:16respectfully24:15 27:25
101:14 102:1797:9,13result 25:1828:4,22 32:11
101:14 102:17receive 40:17return 40:1732:3 33:8
pumping 85:13received 40:17hidden 40:1737:14 40:23
purchase 94:1448:9,14hidden 40:1743:22 44:11
97:24received 84:4return 40:1750:25 54:25
purpose 10:2248:9,14hidden 40:1756:2 58:11,18
60:11 68:14,1995:9,14 99:12returned 40:1715:9 59:12
60:12 70:3returned 40:1761:22 62:15
73:14hidden 40:1763:18 83:22
purpose 22:495:9,14 99:1284:23 85:22
25:12,2586:15,17,22

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EFTA00181803

Page 9

shaking 22:20

23:47 shopping 103:1, 21 104:14 shorting 6:2 shortening 5:10, 94:15 96:4 showing 15:53 showing 95:25 signing 60:4, 104:18 signing 102:16 silent 14:12 similar 21:16, 21 58:17 similarly 22:10 simply 6:2, 99:7 single 30:24 sola 5:14, 19 slave 10:1, 8, 15 12:5, 10, 14, 18 23:25, 24:6, 11 24:15, 18 58:18, 19 slaves 12:1, 62 16:16 smart 92:9 social 5:12 sola 9:1, 14 somebody 8:5 19:5, 9, 25:24 26:12, 29:19 29:25, 36:18 30:24, 17:4 38:9, 13, 47:4 47:12, 16 49:15, 53:1 55:7, 57:16, 18 57:12, 80, 18 64:1, 61, 11, 64 64:17 sorry 5:18, 34:14 49:3 sort 8:12, 25 South 104:7 Southern 1:1

St. 63:11

staff 44:20 stage 96:4 state 3:5, 7 shortening 10, 19, 22 shortening 5:10, 94:15 96:4 showing 15:53 showing 95:25 signing 60:4, 104:18 signing 102:16 silent 14:12 similar 21:16, 21 58:17 similarly 22:10 simply 6:2, 99:7 single 30:24 sola 5:14, 19 slave 10:1, 8, 15 12:5, 10, 14, 18 23:25, 24:6, 11 24:15, 18 58:18, 19 slaves 12:1, 62 16:16 smart 92:9 social 5:12 sola 9:1, 14 somebody 8:5 19:5, 9, 25:24 26:12, 29:19 29:25, 36:18 30:24, 17:4 38:9, 13, 47:4 47:12, 16 49:15, 53:1 55:7, 57:16, 18 57:12, 80, 18 64:1, 61, 11, 64 64:17 sorry 5:18, 34:14 49:3 sort 8:12, 25 South 104:7 Southern 1:1

St. 63:11

staff 44:20 stage 96:4 state 3:5, 7 shortening 10, 19, 22 shortening 5:10, 94:15 96:4 showing 15:53 showing 95:25 signing 60:4, 104:18 signing 102:16 silent 14:12 similar 21:16, 21 58:17 similarly 22:10 simply 6:2, 99:7 single 30:24 sola 5:14, 19 slave 10:1, 8, 15 12:5, 10, 14, 18 23:25, 24:6, 11 24:15, 18 58:18, 19 slaves 12:1, 62 16:16 smart 92:9 social 5:12 sola 9:1, 14 somebody 8:5 19:5, 9, 25:24 26:12, 29:19 29:25, 36:18 30:24, 17:4 38:9, 13, 47:4 47:12, 16 49:15, 53:1 55:7, 57:16, 18 57:12, 80, 18 64:1, 61, 11, 64 64:17 sorry 5:18, 34:14 49:3 sort 8:12, 25 South 104:7 Southern 1:1

St. 63:11

staff 44:20 stage 96:4 state 3:5, 7 shortening 10, 19, 22 shortening 5:10, 94:15 96:4 showing 15:53 showing 95:25 signing 60:4, 104:18 signing 102:16 silent 14:12 similar 21:16, 21 58:17 similarly 22:10 simply 6:2, 99:7 single 30:24 sola 5:14, 19 slave 10:1, 8, 15 12:5, 10, 14, 18 23:25, 24:6, 11 24:15, 18 58:18, 19 slaves 12:1, 62 16:16 smart 92:9 social 5:12 sola 9:1, 14 somebody 8:5 19:5, 9, 25:24 26:12, 29:19 29:25, 36:18 30:24, 17:4 38:9, 13, 47:4 47:12, 16 49:15, 53:1 55:7, 57:16, 18 57:12, 80, 18 64:1, 61, 11, 64 64:17 sorry 5:18, 34:14 49:3 sort 8:12, 25 South 104:7 Southern 1:1

T

table 8:4, 18 5:13 tactic 40:6 task 11:9, 25 tactic

U. S. Legal Support

| (561) | 835-0220 |

| :--- | :--- |

EFTA00181804

United 1:1 5:15

7:9,12 8:12 9:4,7 10:5 upstairs 8:21 9:0,15 use 8:23 8:32 9:11,7 9:41,14 9:6,20 9:71,19 10:4,15 upper 25:13 U8,42 7:22 104:1,18

V5:2 10:32

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va 1:6

13,3 8,13,21 74,1,8 11,17,17,22 70,3,9,14,15 70,20,25

W

W 4:10 want 23:6 45:17 99,8 wear 24:9 84,19 92,25 99,19 wants 25:11 warrant 51,17,17 want’s 21:7 watch 50,17,21 86,4 watching 87:11 way 6:11,16 75,91,17 82,12 89,6,23 80,21 96,22 weakened 43:7 wearing 30:20 Wearman 7:21 WEISM 8:16 104:6 WEISSING 3:16 went 6:19,23 west 86,14,10 West 6,4,9 4:13,18 21:15 100,18 104:2 104,3,7 West 10,10 Wharton 92:22 whatsover 34:5 willing 71:16 witnesses 23,6,13 71,12 46,45 20:20 96,8 100,7,8 100,11,17 102,15 104:13 102,15 104:13 witnessed 37:19 37:24 38,4 54,13 104:13 woman 91:18 worker 40,6,46 working 8:11 93,18 wouldn’t 42,3,9 42,14 WRITE 103:3 wrong 80:13

Y

Yarema 4:14 16:42 7:2,6,13,18 7:25 8,7,19 9:11,16,20,23

W 10:2,9 12,16

10:19 11,14,8 11:13,19 12,12 12:6,11,15,19 12:24 13,3,7 13:11,15,20 13:25 14,17 14:17,17,21 14:25 15,14,10 15,15,20,25 16,9,14,20,25 18,3,13,18 18:2,19 17,12 19:16,23 20,14 20,12,19,24 21,15,13,18 21,17,13,18 23,22 24,3,7 25,31,17,12 27,14,17,23 27,40,17,23 28,2,6,11,18 28,2,3,6,11

U.S. Legal Support (561) 835-0220

EFTA00181805

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19th 100:1945 2:12
1985 5:11463-4346 4:10
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2 3:18, 225 2:5 81:24
20 96:2250 7:5 38:24
200 4:341:24
2000 87:20515-1400 4:4
2001 65:62 66:5552-2920 3:19
71 6:14 72:1561 4:4, 14:19
72:6 75:25561 835-0220
2002 26:5, 9, 14104:3
55:12, 18 71:66
71:14 72:1, 665 2:6
78:25659-8300 4:19
2003 52:18 55:2566th 6:16, 24
69:12 74:1462:19, 25
74:197
2004 66:13, 2077 2:7
67:24 68:4, 138
74:4, 12 81:2483:22 63:3
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2004 66:13, 208/21 45:13
68:16800.04 37:18
2006 65:23 66:581 2:8
2010 1:20 2:1842-2820 4:14
100:19 101:788 4:8
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2011 100:23954 3:19 4:10
101:15 104:2298 2:5
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22 22:18
2218 3:23
25 4:9
250 104:7
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303 4:13
305 3:24
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358 6:12 82:11
89:6, 22 90:2
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4:00 46:9, 24
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400 4:13
425 3:18
444 3:5 104:2

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