Deposition of a former model witness in a 2010 civil suit against Jeffrey Epstein

EFTA00182444¶

EFTA00182445¶

Q. In fact, AH was somebody that was over at Jeffrey Epstein’s house many times, correct? A. I refuse to answer. MR. PIKE: Form. Q. 9/3/2005. Message from saying “I left message for to confirm for 11 a.m. and¶

for 4:30 p.m.” Do you remember leaving that message? A. I refuse to answer. Q. And this is — MR. PIKE: Form. Q. It’s his typical schedule where he schedules one underage minor female to molest in the morning and one in the afternoon, correct? MR. PIKE: Form. A. I refuse to answer. Q. I mean, considering this is — have you ever worked anywhere else where there is somebody sexually molesting underage minor females on a daily basis like this? MR. PIKE: Form. A. I refuse to answer. Q. At some point in time did you tell your parents that this was happening? MR. PIKE: Form. A. I refuse to answer. Q. Did you ever talk to anybody else in the house and say “Hey, look, this is not right”?? A. I refuse to answer. Q. Do you feel sorry for these girls? A. I refuse to answer.¶

Q. And you say you do or you do not remember AH? A. I refuse to answer. Q. Okay. And do you know what happened up in the bedroom between AH as a minor and Jeffrey Epstein? MR. PIKE: Form. A. I refuse to answer. Q. Well, this is what she tells police: “She arrived at the house, went upstairs to the bedroom. She advised she immediately removed her clothing and Epstein were already naked in the bedroom. AH explained that and she had a sexual encounter that included kissing, touching, and oral sex. AH remembered that she climaxed and was removing herself from the massage table. Epstein then turned AH onto her stomach on the massage table and inserted his penis into her vagina. AH stated Epstein began to pump his penis in her vagina. AH became upset over told her head was being held forcibly against the bed as he continued to pump inside her. She screamed ‘No,’ and Epstein stopped. He would normally pay her $200, but for this he apologized and paid her a thousand dollars for that visit.”¶

Are you familiar with that encounter? A. I refuse to answer. MR. PIKE: Form.¶

Q. Do you remember a time when AH as a 16-year-old I believe at this time left her house — left the house visibly upset? MR. PIKE: Form.¶

EFTA00182446¶

A. I refuse to answer. Q. She advised that she was ripped and torn in her vagina area and had difficulty walking to the car; do you remember that? MR. PIKE: Form. A. I refuse to answer. Q. These message pads were message pads that were taken from trash pulls outside of Jeffrey Epstein’s home and for the most — well, there’s so many messages here, but most of them are by somebody other than yourself to my question is who are the other people that would take messages for Jeffrey Epstein for underage minor females to come to the house? MR. PIKE: Form. A. I refuse to answer. Q. And the messages include CL, “Can I come work today?” What does “work” mean? A. I refuse to answer. MR. PIKE: Form. Q. That means come to your house and get paid for¶

Jeffrey Epstein sexually molesting this person while she was underage; is that correct? A. I refuse to answer. MR. PIKE: Form. Q. And it was also pretty frequent that the girls would come in tandem, isn’t that true, two at a time? MR. PIKE: Form. A. I refuse to answer. Q. And one being the girl that would bring the new girl there, would wait downstairs while the new girl was upstairs getting molested but then getting paid? MR. PIKE: Form. A. I refuse to answer. Q. How did Jeffrey Epstein explain himself to you as to why he did this? MR. PIKE: Form. A. I refuse to answer. Q. Do you know when it is that he first became sexually chosed with underage minor females? MR. PIKE: Asked and answered. A. I refuse to answer. MR. PIKE: Form. Q. Did you know that he was a school teacher at the Dalton School?¶

A. I refuse to answer. Q. And at that point in time — well, are you aware of him molesting underage minors while he was a teacher there? A. I refuse to answer. Q. There’s another note that’s not a message pad which I guess I will — since it has your name on it I will mark it as what we on — 3 — wait, C — MR. ROSS: 3. MR. EDWARDS: I messed up. MR. ROSS: 3. (Whereupon, Plaintiff’s Exhibit 3 was marked for identification.) Q. Look at that while I fix what I’ve messed up over here.¶

EFTA00182447¶

MR. ROSS: I’m going to show this to the witness. MR. EDWARDS: Yes. Yes. Q. Do you recognize that document? A. I refuse to answer. Q. There are a lot of different things on here that don’t necessarily relate to you. At least I can’t tell that they do. But it does indicate “parents are going to the embassy on the 23rd.” Do you remember when that happened?¶

A. I refuse to answer. Q. Why did your parents go to the embassy? A. I refuse to answer. Q. More importantly why was Mr. Epstein concerned that your parents were going to the Embassy? MR. PIKE: Form. A. I refuse to answer. Q. Was — at that point in time was Mr. Epstein assisting your parents with anything? A. I refuse to answer. Q. Are your parents citizens of the United States? MR. ROSS: Form. A. I refuse to answer. Q. Are you? A. No. Q. Has Mr. Epstein ever offered to get you a visa for the United States? A. I refuse to answer. MR. PIKE: Form. Q. Do you know Raer Roshan? A. I refuse to answer. Q. That was Jeffrey Epstein’s partner in RadarOnline, correct? A. I refuse to answer.¶

Q. And if I showed you every single message pad here would you be able to answer any of the questions about any of the messages that were left at Jeffrey Epstein’s house? A. I refuse to answer. MR. EDWARDS: Okay. That saves us a lot of time. MR. ROSS: It did. Q. Have you ever met Bill Clinton? A. I refuse to answer. Q. Is Bill Clinton — was Bill Clinton a friend of Jeffrey Epstein’s? A. I refuse to answer. Q. Is Bill Clinton somebody who Jeffrey Epstein has ever procured underage minor females for? A. I refuse to answer. MR. PIKE: Form. Q. And just — and just for, you know, the sake of what the evidence shows, there’s no evidence that I have that indicates that that happened, but if you were going to answer that question I’m willing to ask it. Have you met him at Jeffrey Epstein’s house in Palm Beach County? MR. PIKE: Form. A. I refuse to answer.¶

EFTA00182448¶

Q. You have flown on Jeffrey Epstein’s airplanes numerous times, correct? A. I refuse to answer. Q. As well has Bill Clinton and you’re aware of that, right? MR. PIKE: Form. A. I refuse to answer. Q. Have you ever seen the flight logs from Jeffrey Epstein’s airplanes? MR. PIKE: Form. A. I refuse to answer. Q. And on many times it is Bill Clinton, Secret Service agents, Jeffrey Epstein, Ghislaine Maxwell, and others. Have you — do you know about those flights? A. I refuse to answer. MR. PIKE: Form. Q. And have you ever witnessed sex on any of Jeffrey Epstein’s flights? A. I refuse to answer. MR. PIKE: Form. Q. Do you know Emmy Taylor? A. I refuse to answer. Q. Is that somebody that is Ghislaine Maxwell’s sex slave?¶

A. I refuse to answer. Q. And isn’t it typical for Jeffrey Epstein to have a sex slave that flies with him on the airplane? A. I refuse to answer. MR. PIKE: Form. Q. And one of the qualifications is that the section slave be underage, correct? MR. PIKE: Form. A. I refuse to answer. Q. And if the sex slave is 15 years old isn’t it your understanding and based on your observations that he will even make them dress as if they’re 11 or 12? MR. PIKE: Form. A. I refuse to answer. Q. Do you know President Andres Pastrana? A. I refuse to answer. Q. Do you know him as somebody who has had sex with underage minor females brought to him by Jeffrey Epstein? MR. PIKE: Form. A. I refuse to answer. Q. Have you ever heard of Ehud Burak? A. I refuse to answer. MR. PIKE: Form.¶

Q. Is that another person that Epstein — Jeffrey Epstein procures underage minor females for? MR. PIKE: Form. A. I refuse to answer. Q. You’ve met Naomi Campbell I’m assuming? A. I refuse to answer. Q. Anytime separate and apart from any dealings with Jeffrey Epstein have you met her in the modeling industry? That’s a model, right? MR. PIKE: Form. MR. ROSS: You can answer the question.¶

EFTA00182449¶

EFTA00182450¶

Jeffrey Epstein’s plane would you say more than 50 times? A. I refuse to answer.¶

MR. PIKE: Form. Q. And you flew to his island, right? A. I refuse to answer. MR. PIKE: Form. Q. You flew to New Mexico? A. I refuse to answer. MR. PIKE: Form. Q. You flew to New Jersey? MR. PIKE: Form. A. I refuse to answer. Q. Several of the flights are just yourself, Jeffrey Epstein, and ___. What did you do on those flights? MR. PIKE: Form. A. I refuse to answer. Q. Who’s Adam Perrylang? A. I refuse to answer. Q. Is that somebody that you were made to have sex with? A. I refuse to answer. Q. Did Jeffrey Epstein ever make you have sex with any females? MR. PIKE: Form. A. I refuse to answer. Q. Did he ever make you have sex with any of his friends? MR. PIKE: Form. A. I refuse to answer. Q. Who is Sandy Berger? A. I refuse to answer. Q. That’s somebody else that was affiliated with Bill Clinton at one point in time, correct? A. I refuse to answer. Q. A close friend of Jeffrey Epstein’s? MR. PIKE: Form. A. I refuse to answer. Q. He called the house within three weeks of the search warrant being executed. Did he tip off Jeffrey Epstein? MR. PIKE: Form. A. I refuse to answer. Q. Is he somebody that’s involved with underage minors? A. I refuse to answer. Q. Do you know Igor Zinoviev? A. I refuse to answer. Q. Andrea Metrovich? A. I refuse to answer. Q. Have you flown on the airplane with Alan Dershowitz before?¶

MR. PIKE: Form. A. I refuse to answer. Q. And Jean Luc Brunel is somebody who you have been on the airplane with several times, correct? A. I refuse to answer. MR. PIKE: Form. Q. And when Jean Luc Brunel is on this airplane¶

EFTA00182451¶

EFTA00182452¶

EFTA00182453¶

MR. ROSS: No. MR. EDWARDS: I’ll attach it as whatever it is.¶

MR. ROSS: 4. MR. EDWARDS: 2 — well, I’ll just go 2H since it’s a message. You don’t have a problem with that? 2H?¶

MR. ROSS: Whatever. (Whereupon, Plaintiff’s Exhibit 2H was marked for identification.)¶

Q. Do you still consider Jeffrey Epstein a friend? A. I refuse to answer. MR. PIKE: Form. Q. Did you ever think of Jeffrey Epstein as a friend? MR. PIKE: Form. A. I refuse to answer. Q. Other than the people that I’ve mentioned of — you know, President Pastrana and Ehud Burak and Prince Andrew did you meet any other people of royalty being friends with Jeffrey Epstein?¶

MR. PIKE: Form. A. I refuse to answer. Q. Can you tell us any of the other folks that Jeffrey Epstein would supply underage minor girls to? MR. PIKE: Form. A. I refuse to answer. Q. Do you know a man by the name of Glenn Dubin? A. I refuse to answer. Q. Do you know his wife? A. I refuse to answer. Q. His wife at some point in time was associated with Jeffrey Epstein; is that correct? A. I refuse to answer. Q. And her name’s Eva Dubin; is that right? A. I refuse to answer.¶

Q. Do you know ___? A. I refuse to answer. Q. Is that somebody who also worked for Jeffrey Epstein? A. I refuse to answer. MR. PIKE: Form.¶

Q. Did Jeffrey Epstein ever get a legitimate massage from somebody that’s a masseuse? MR. PIKE: Form. A. I refuse to answer. Q. The underage females that we’ve talked about particularly, LM, EW, and Jane Doe, those girls were not prostitutes, were they? A. I refuse to answer. Q. These were just girls who were in 8th, 9th, 10th grade in high school, right? A. I refuse to answer. Q. These were girls that you knew had never committed prostitution in the past, right? A. I refuse to answer.¶

EFTA00182454¶

Q. And that goes for all of these girls on the phone list of underage minors to call, these were not prostitutes, correct?¶

A. I refuse to answer.¶

Q. You never called a prostitution or escort service for Jeffrey Epstein, did you?¶

MR. PIKE: Form.¶

A. I refuse to answer.¶

Q. And as well you never called a legitimate massage parlor for Jeffrey Epstein, correct?¶

A. I refuse to answer.¶

MR. PIKE: Form.¶

Q. He devised this scheme of having underage minor girls bring him other underage minor girls so that he could gain access to his target age group, 12 to 16 years old, correct?¶

A. I refuse to answer.¶

Q. Have you heard Jeffrey Epstein say “The younger the better?”¶

A. I refuse to answer.¶

Q. And did Jeffrey Epstein tell you that it made him happy the younger the girl was?¶

A. I refuse to answer.¶

MR. PIKE: Form.¶

Q. The less developed the girl is the more excited Jeffrey Epstein gets; is that true?¶

A. I refuse to answer.¶

Q. Do you ever plan to talk to Jeffrey Epstein in the future?¶

A. I refuse to answer.¶

MR. PIKE: Form.¶

Q. Would you ever work for him again?¶

A. I refuse to answer.¶

Q. Why didn’t you stop working for him sooner?¶

A. I refuse to answer.¶

MR. PIKE: Form.¶

Q. Did you — well, you knew that it was illegal what he was doing at the time you were doing it, correct?¶

A. I refuse to answer.¶

Q. Did you know that you were part of a large child molestation ring?¶

MR. BIKE: Form¶

A. I refuse to answer.¶

Q. Did you continue working there because you were just scared to stop?¶

A. I refuse to answer.¶

MR. PIKE: Form.¶

EFTA00182455¶

Q. Did Ghislaine Maxwell ever threaten you? A. I refuse to answer. B. How was it decided who would call which girl? C. I refuse to answer. D. And by that, just so it’s clear, like I said, there’s going to be many, many, many message pads, I have not counted them, but a lot created by either yourself or someone named Janusz Banaziak or Alfredo Rodriguez, E. various people that we know to have been employed at Jeffrey Epstein’s home. And it seems that on one particular day they may call several girls, you may call several girls, they may call several girls. Who is directing which — which of you, which of the assistants is going to call the underage minor to give them an appointment? A. I refuse to answer. MR. PIKE: Form. Q. And what would happen on the occasions where Jeffrey Epstein says he’s going to be in town and then he’s ultimately not in town but a girl shows up anyway? MR. PIKE: Form. A. I refuse to answer. Q. Weren’t you just told just to pay her to keep her happy?¶

A. I refuse to answer. Q. And isn’t part of the whole scheme that these girls were typically told “Don’t tell anybody what goes on inside this house,” right? MR. PIKE: Form. A. I refuse to answer. Q. And did Jeffrey Epstein tell you that because these girls are young and they’re poor and they’re underprivileged type girls they’re likely not going to say anything anyway? Isn’t that what he told you? MR. PIKE: Form. A. I refuse to answer. Q. Did Ghislaine Maxwell talk to you about that as well? A. I refuse to answer. MR. PIKE: Form. Q. Have you seen Jeffrey Epstein angry? A. I refuse to answer. Q. Isn’t it true that he’s very nice and engaging as long as he gets his way and gets you to cooperate, right? A. I refuse to answer. Q. But if he doesn’t get his way he gets very, very angry and mad and scary; isn’t that true? A. I refuse to answer.¶

Q. And you’ve seen both sides of him, right? A. I refuse to answer. Q. In fact, you know of girls who were 13 years old and cooperated with everything he said because they felt they had no choice up in that bedroom, right? A. I refuse to answer. MR. PIKE: Form. Q. And you also know girls who resisted and were yelled at and told to grab their money and get out of there, right?¶

EFTA00182456¶

EFTA00182457¶

EFTA00182458¶

EFTA00182459¶

MR. EDWARDS: You got a secret phone? VIDEOGRAPHER: It’s anytime it receives any kind of information. MR. ROSS: Oh, okay, yeah, it’s — VIDEOGRAPHER: It’s not that it’s ringing. MR. ROSS: Right. It’s not doing it now. VIDEOGRAPHER: I apologize for the interruption.¶

Q. All right. I ask you that question because there was also something called a non-prosecution agreement. Are you familiar with that document? A. I refuse to answer. MR. ROSS: Attorney-client privilege. Q. And that is also a document that included your name as a co-conspirator; are you familiar with that? A. I refuse to answer. MR. ROSS: Attorney-client privilege. Q. And this is because of your involvement with calling on the telephone underage minors to bring them to Jeffrey Epstein’s house, correct? A. I refuse to answer. Q. Or for your involvement in scheduling appointments in Jeffrey Epstein’s appointment book for underage minor — underage minor females to be involved with Jeffrey Epstein sexually, correct? MR. PIKE: Form. A. I refuse to answer. Q. It is certainly not because you sought out this child molestation ring in hopes of rising to the top, correct? MR. PIKE: Form. A. I refuse to answer. Q. Didn’t you do everything that you did that¶

anybody could ever say is illegal at the direction of Jeffrey Epstein? A. I refuse to answer. Q. And if it wasn’t at the direction of Jeffrey Epstein it was at the direction of Ghislaine Maxwell or correct? MR. PIKE: Form. A. I refuse to answer. Q. I mean, those things were not things that you would have done but for being under the supervision of Jeffrey Epstein; isn’t that right? MR. PIKE: Form. A. I refuse to answer. Q. And you continued to do these things either out of fear or because you were just impressed with Jeffrey Epstein’s lifestyle? A. I refuse to answer. Q. Aren’t you angry for him involving you in this criminal activity? A. I refuse to answer. MR. PIKE: Form. Q. Do you ever intend in the future to talk about what he did and what he involved you in? MR. PIKE: Form. A. I refuse to answer.¶

Q. Wouldn’t you like to separate yourself being the person that you are from this person who brought¶

EFTA00182460¶

EFTA00182461¶

Q. That’s a friend of or former friend of Jean Luc Brunel’s? A. I refuse to answer. Q. How many times has Jean Luc Brunel shown up at Jeffrey Epstein’s house with underage minor females? MR. PIKE: Form. A. I refuse to answer. Q. And when that would happen isn’t it true that they would have orgies with these underage minor females? MR. PIKE: Form. A. I refuse to answer.¶

Q. What was done — or let me ask it a different way. Strike that. Where is the scheduling book for the massage appointments for Jeffrey Epstein? MR. PIKE: Form. A. I refuse to answer. Q. Is that something else that was removed from the home prior to the search warrant being executed? A. I refuse to answer. MR. PIKE: Form. Q. Do you know how it is that — well, did Jeffrey Epstein ever tell you that because of the people he knew he would not be going to prison for the crimes that he committed? A. I refuse to answer. MR. PIKE: Form. Q. And is it your understanding that Ken Starr had played major role in devising the non-prosecution agreement or having the government agree not to prosecute Jeffrey Epstein for his crimes against minors? A. I refuse to answer. MR. PIKE: Form. Q. Is it also your understanding that Bill Clinton played somewhat of a role in helping Jeffrey Epstein out of the trouble that he would have been in related to his sexual interactions with minor females? A. I refuse to answer. MR. PIKE: Form. Q. Did Jeffrey Epstein tell you that you need to cooperate if you want the protection that me and my connections can give you for this activity? MR. PIKE: Form. A. I refuse to answer. Q. You admit that you called LM on the telephone for her to come to Jeffrey Epstein’s house to be molested by Jeffrey Epstein when she was an underage female? A. I refuse to answer. MR. PIKE: Form. Asked and answered twice. Q. Do you agree that you called EW on the telephone for the purposes of her coming to Jeffrey Epstein’s house for him to sexually molest her? MR. PIKE: Same objection. A. I refuse to answer. Q. And do you agree that you called Jane Doe and told her to come to your house to work, meaning for Jeffrey Epstein to sexually molest her? MR. PIKE: Asked and answered.¶

EFTA00182462¶

25¶

A. I refuse to answer.¶

Q. The first trial that is set in these cases is in July of this year. Do you intend to be in the local area?¶

MR. ROSS: You can answer.¶

A. Yes.¶

Q. Okay. And what address will you be at?¶

MR. ROSS: You can answer.¶

Q. And I presume that if I needed to find you or locate you or anything else I could go through your attorney?¶

A. Yes.¶

Q. Okay. Who do you live at that address with?¶

MR. ROSS: You can answer.¶

A. With my husband and my mom-in-law and his sister as well.¶

Q. And who else lives at the house with you, I’m¶

A. I refuse to answer.¶

A. I refuse to answer.¶

Q. Have you told your parents?¶

Q. Are your parents in the country now?¶

MR. ROSS: You can answer.¶

A. No.¶

Q. Do they have plans to come back?¶

MR. ROSS: You can answer.¶

A. They may visit, I’m not sure.¶

Q. But on a permanent basis they’re in Poland?¶

A. Yes.¶

Q. Okay. What’s the address where they are in Poland? ___¶

Q. She’s great. I’m sure she got that.¶

A. Would you like me to spell it out?¶

MR. EDWARDS: One way to never find a witness¶

is just move to Poland. There’s no way.¶

MR. ROSS: Couldn’t get anyone to type the subpoena.¶

MR. EDWARDS: Right, exactly. All right. I don’t have any other questions for you. Thank you.¶

THE WITNESS: Thank you.¶

Q. Okay. Mrs. Ross, I have some questions for¶

EFTA00182463¶

you. Your husband, what does he do for a living? A. He’s a Ph.D. student. Q. And what is he a Ph.D. in? A. He works on bone marrow transplant immunology. Q. So is he a medical doctor? A. He’s scientist. He’s working on his Ph.D. degree. Q. And which school is he working on his Ph.D. at? A. University of Miami. Q. And how long has he been doing that? A. I cannot recall when he started but we were already married. Maybe one or two years into my marriage. I do not recall the exact time. Q. And I believe you testified that you met him¶

in Europe, correct? A. Correct. Q. And did he have a different employment or profession then? A. Yes. Q. What was he doing then? A. Well, at that time he was serving in the entertainment business. He was DJing and — yeah. When I met him he came to Europe for a DJ event. DJing event. Q. And where was that in Europe? A. He went to Spain and then I was in Monaco at the time and he knew the people that I was there with and we were introduced. That’s where we met. Q. And did he have connections to modeling in the United States? A. Yes. Q. And how did he have those connections? A. I’m — you know, I’m not sure. I don’t know at this time, but he knew agencies here and he was doing, I believe, some photographic work as well himself. Q. So he was a DJ and a professional photograph — photographer? A. Yes. You may say so, yes.¶

Q. And a scientist as well? A. Yes. Q. Did he do work for particular modeling agencies in the United States? A. I mean, do you — I don’t understand your question. Do you mean like — Q. Well, did he perform work or services for particular modeling agencies in the United States? A. Well, I believe he would hire models from modeling agencies, yes. Q. He would hire models? A. Yes, for — you know, that’s how — how it works. You hire a model from a modeling agency for a particular job, a client that you may have. Q. So as a photographer he would hire models for a particular modeling agency? MR. PIKE: Form. A. Yes. Q. And do you know which modeling agencies he typically worked with?¶

EFTA00182464¶

A. Well, I presume Elite Models because, you know, he had connection and he invited me. I think just various Miami Beach — you know, Miami, South Beach modeling agencies.¶

Q. Did he work for MC Squared?¶

A. I refuse to answer. Q. In 2004 and 2005 you were employed by Jeffrey Epstein, correct? MR. PIKE: Form. A. I refuse to answer. Q. And as an employee of Jeffrey Epstein you were under his instruction and supervision, correct? MR. PIKE: Form. A. I refuse to answer. MR. PIKE: Let’s go off the record for a second. MR. MERMELSTEIN: Sure. VIDEOGRAPHER: Off the record at 12:12 p.m. (Discussion off the record.) MR. MERMELSTEIN: I’ll be brief on the general questions. VIDEOGRAPHER: On the record, 12:14 p.m. BY MR. MERMELSTEIN: Q. And as an employee of Jeffrey Epstein were you also subject to the — to the instructions and supervision of Ghislaine Maxwell? MR. PIKE: Form. A. I refuse to answer. Q. And as an employee of Jeffrey Epstein did you work under the supervision and instruction of his primary assistant?¶

MR. PIKE: Form. A. I refuse to answer. Q. Okay. Did Jeffrey Epstein tell you that — that he recruited from western Palm Beach County underage girls to come to his Palm Beach mansion for sexual activity? MR. PIKE: Form. A. I refuse to answer. Q. And did Jeffrey Epstein have a computer database at his Palm Beach mansion where he listed underage high school girls in Palm Beach County and their contact information so that he could have these underage minors come to his house for sexual activity? MR. PIKE: Form. A. I refuse to answer. Q. And did Jeffrey Epstein tell you that the reason he brought in underage minors from western Palm Beach County is because he anticipated they would be impressed, in awe, and intimidated by his wealth? MR. PIKE: Form. A. I refuse to answer. Q. And as young girls who were impressed and in awe and intimidated of his wealth they would do what he asked them to do?¶

MR. PIKE: Form. A. I refuse to answer. Q. And as young underage girls who were impressed, intimidated, and in awe of his wealth they would be unlikely to — to complain to authorities that¶

EFTA00182465¶

he was engaging in sexual activity with them?¶

A. I refuse to answer. MR. PIKE: Form.¶

Q. Okay. Did Jeffrey Epstein instruct you to call girls on the telephone to schedule appointments for them to come to his Palm Beach house for massages which were, in fact, to be sexual activity? MR. PIKE: Form.¶

A. I refuse to answer. Q. Prior to May 2005 did you call Jane Doe 4 to schedule appointments for her to come to the Epstein house to engage in — to give Jeffrey Epstein a massage which would, in fact, be sexual activity with Jeffrey Epstein?¶

MR. PIKE: Form.

A. I refuse to answer. Q. Okay. Prior to May 2005 while you were at the Epstein house in Palm Beach did you receive calls from Jane Doe 4 regarding the scheduling of an appointment for her to come to the Epstein house to give Jeffrey¶

17¶

Epstein a massage?¶

MR. PIKE: Form.

A. I refuse to answer. Q. When Jane Doe 7 — let me strike that. Do you know Jane Doe 7? A. I refuse to answer. Q. When Jane Doe 7 was a minor female did you call Jane Doe 7 to schedule appointments for her to come to the Epstein house in Palm Beach to give Epstein a massage?¶

MR. PIKE: Form.

A. I refuse to answer. Q. When Jane Doe 7 was a minor female did you receive calls from Jane Doe 7 while you were at the Epstein house for her to come to the house by appointment and give Jeffrey Epstein a massage?¶

MR. PIKE: Form.

A. I refuse to answer.¶

9. The computer database that Jeffrey Epstein maintained girls from western Palm Beach County who would come to the house in Palm Beach to give Epstein a massage, did that computer database include the name and contact information for Jane Doe 2?

   MR. PIKE: Form.

A. I refuse to answer.¶

18¶

Q. Do you know who Jane Doe 2 is?¶

A. I refuse to answer.¶

Q. Do you know who Jane Doe 5 is?¶

A. I refuse to answer.¶

Q. Did the computer database that Epstein maintained on his computers in his home have the name and contact information for Jane Doe 5 so that Epstein could contact her for — for massages in his Palm Beach home?¶

MR. PIKE: Form.

A. I refuse to answer.¶

Q. Do you know the name Jane Doe 6?¶

A. I refuse to answer.¶

Q. Did the computer database that Epstein maintained in his home of underage girls who he would have come over for massages and sexual activity did¶

EFTA00182466¶

that computer database include the name and contact information for Jane Doe 6? A. I refuse to answer. Q. Do you know the name Jane Doe 3? A. I refuse to answer. Q. Did the computer database that Jeffrey Epstein maintained in his home include the name and contact information of Jane Doe 3 so that he could contact Jane Doe 3 to come to his Palm Beach home and give him a¶

massage which would become sexual activity? A. I refuse to answer. Q. Did the computer database that Jeffrey Epstein maintained in his home include the name Jane Doe 4? MR. PIKE: Form. A. I refuse to answer. Q. Do you know Jane Doe 4? A. I refuse to answer. Q. Did the — did Jeffrey Epstein tell you that he maintained the contact information for Jane Doe 4 in his computer database in his home so that he could contact her to come to his Palm Beach mansion for massages? MR. PIKE: Form. A. I refuse to answer. Q. Did you know for a fact that the computer database included the name Jane Doe 4 so that Jeffrey Epstein could contact her and she would come to the Palm Beach mansion to give Jeffrey Epstein a massage? MR. PIKE: Form. A. I refuse to answer. Q. Did you know that the computer database that Jeffrey Epstein maintained his home contained the name and contact information of Jane Doe 7 — A. I refuse — sorry.¶

Q. I’m sorry — so he would contact Jane Doe 7 and have her come to his house to give him a massage? A. I refuse to answer. Q. Are you aware that the computer database that Jeffrey Epstein maintained in his home contained the name Jane Doe 8 so that he could contact Jane Doe 8 and have him come to the house in Palm Beach for purposes of giving him a massage? MR. PIKE: Form. A. I refuse to answer. Q. You removed three computers from the Palm Beach house with another gentleman prior to the search warrant being issued by the Palm Beach police; isn’t that correct? A. I refuse to answer. MR. PIKE: Form. Asked and answered. Q. And Jeffrey Epstein instructed you to remove those computers is that correct? MR. PIKE: Form, asked and answered. A. I refuse to answer. Q. And Jeffrey Epstein told you that the reason he was instructing you to remove the computers was to hide his sexual activities with underage minors from the authorities? MR. PIKE: Form.¶

A. I refuse to answer.¶

EFTA00182467¶

Q. As an employee of Jeffrey Epstein did you know Janusz Banaziak? A. I refuse to answer. MR. PIKE: Form Q. Was Janusz Banaziak also an employee of Jeffrey Epstein? MR. PIKE: Form A. I refuse to answer. MR. PIKE: Form Q. When Janusz Banaziak testified that you and another gentleman removed the three computers from Jeffrey Epstein’s home he was telling the truth, correct? A. I refuse to answer. MR. PIKE: Form Q. Did you observe Jeffrey Epstein persuading, inducing, or enticing underage girls to engage in sexual activities with him? A. I refuse to answer. Q. Did you — strike that. Did you observe Jeffrey Epstein persuading, inducing, or enticing girls who came to his house for the purpose of giving him a massage to engage in sexual activity with him? MR. PIKE: Form¶

0122 A. I refuse to answer. Q. Did Jeffrey Epstein tell you that he induced, persuaded, or enticed underage girls to engage in sexual activities with him when they came to his Palm Beach mansion to give him a massage? MR. PIKE: Form A. I refuse to answer. Q. Would you instruct — when you spoke to underage girls to schedule appointments for massage in Epstein’s home would you instruct these girls to lie about their ages and say they were 18 years old when you knew that they were younger than 18? A. I refuse to answer. Q. Did Jeffrey Epstein instruct you as to what to say to the girls who you contacted by telephone to make appointments to schedule massages in Epstein’s home? A. I refuse to answer. MR. PIKE: Form Q. And would Jeffrey Epstein tell you to have the girls who you contacted by the telephone to make appointments to come to the mansion to give Jeffrey Epstein massages, that they should — that these girls should lie about their ages to Jeffrey Epstein? MR. PIKE: Form A. I refuse to answer.¶

0123 Q. Prior to May 2005 are you aware that Jeffrey Epstein had numerous appointments with Jane Doe 4 for her to come to the mansion to come to give him a massage? A. I refuse to answer. MR. PIKE: Form Q. Prior to May 2005 are you aware that Jane Doe 4 would come to the mansion to give Jeffrey Epstein a massage on a frequent and regular basis? A. I refuse to answer. MR. PIKE: Form Q. Are you aware that prior to May 2005 Jeffrey¶

EFTA00182468¶

EFTA00182469¶

EFTA00182470¶

EFTA00182471¶

EFTA00182472¶

Q. All right. Is there anybody else that you’re able to — to tell me where you worked? MR. ROSS: Invoke as to any further information. THE WITNESS: I’m sorry? MR. ROSS: Invoke your privilege. A. I refuse to answer any questions. MR. EDWARDS: All right. That’s all I got. MR. MERMELSTEIN: Can I just follow up a couple?¶

RECROSS-EXAMINATION¶

BY MR. MERMELSTEIN: Q. In what has been marked as Exhibit 2C is a phone message from you to Adri — from you to Jeffrey Epstein dated September 10th, 2005 at 1:15 p.m. And the message that you left was “Lauren confirmed 4 p.m.”, is that correct? A. I refuse to answer. Q. Is the Lauren referred to in this message?¶

MR. PIKE: Form.¶

A. I refuse to answer. Q. And did you schedule Lauren — MR. PIKE: Form.¶

Q. — to come to the Palm Beach mansion as an underage female to give Jeffrey Epstein massages? MR. PIKE: Form. A. I refuse to answer. Q. Also what has been marked as Exhibit 2F is a phone message from you to Jeffrey Epstein dated September 11th, 2005 at 9:15 a.m. And the message was that you got a car for a particular person. Do you recall that? MR. PIKE: Form. A. I refuse to answer. Q. Is the car that you obtained on September 11th, 2005 for Jane Doe 4? MR. PIKE: Form. A. I refuse to answer. Q. And Jane Doe 4 is a girl who had been coming to the Palm Beach mansion to give Jeffrey Epstein a massage and engage in sexual activities with him for a substantial period of time; is that correct? A. I refuse to answer. Q. And also what has been marked as Exhibit 2H —¶

actually — MR. EDWARDS: Is that G? MR. MERMELSTEIN: Are they similar? MR. EDWARDS: Yeah, I guess they blocked out names on one of them and they didn’t on the other. MR. MERMELSTEIN: Right. Okay. Q. And what has been marked as Exhibit 2G is a message from you to Jeffrey Epstein dated September 3rd, 2005 at 8:50 p.m. And the message you left is, quote, “I left message for to confirm for 11:00 a.m. and for 4:30 p.m.” Did you, in fact, leave that message? MR. PIKE: Form. A. I refuse to answer. Q. And this message that you left confirmed an¶

EFTA00182473¶

CERTIFICATE OF OATH¶

I, Janet L. McKinney, Registered Professional Reporter, Florida Professional Reporter, Certified LiveNote Reporter, Notary Public, State of Florida, certify that personally appeared before me on March 15, 2010 and was duly sworn.¶

Signed this 21st day of March, 2010.¶

Janet L. McKinney¶

Registered Professional Reporter¶

Florida Professional Reporter¶

Certified LiveNote Reporter¶

Notary Public, State of Florida¶

Commission No.: DD552183¶

Expires: June 2, 2010¶

EFTA00182474¶

CERTIFICATE OF REPORTER¶

I, Janet McKinney, Registered Professional Reporter, Florida Professional Reporter, Certified LiveNote Reporter, certify that I was authorized to and did stenographically report the deposition of¶

, pages 1 through 138; that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes.¶

I further certify that I not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties’ attorneys or counsel connected with the action, nor am I financially interested in the action.¶

Dated this 21st day of March, 2010.¶

Janet L. McKinney, RPR, FPR, CLR Registered Professional Reporter Florida Professional Reporter Certified LiveNote Reporter¶

EFTA00182475¶