Draft: efta02780356

EXHIBIT 11 PART 2¶

1 MR. RHEINHART: Same instruction. 2 THE WITNESS: On the instruction of my 3 lawyer, I must invoke my Fifth Amendment 4 privilege. 5 BY MR. KUVIN: 6 Q. Have you ever worked as a professional 7 model? 8 MR. RHEINHART: May I consult? 9 MR. KUVIN: Sure. 10 MR. RHEINHART: You can answer the 11 question. 12 THE WITNESS: Yes. 13 BY MR. KUVIN: 14 Q. When? 15 A. I don't remember. I don't remember the dates. 16 It was at least maybe ten years ago. 17 Q. And you're how old now? 18 MR. RHEINHART: I'll instruct the witness 19 not to answer the question. Nice try. 20 Instruct you not to answer based on 21 your Fifth Amendment privilege. 22 THE WITNESS: On the instruction of my 23 lawyer, I'm going to invoke my Fifth Amendment 24 privilege. 25 MR. KUVIN: I'm just trying to find out¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 assumes facts that have not been established and it's compound. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. MR. RHEINHART: And to clarify the objection is that it assumes that she's ever met or knows anything about Jean-Luc Brunel. BY MR. KUVIN: Q. Were you ever promised anything regarding your modeling career by Jeffrey Epstein? MR. RHEINHART: Same objection, instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. You would agree with me that there is a financial arrangement between Jean-Luc Brunel and Jeffrey Epstein, do you not? MR. RHEINHART: Objection. It assumes she has any knowledge of either Mr. Epstein or Mr. Brunel, and as to that she is going to invoke her Fifth Amendment privilege. The question is compound and therefore ambiguous.¶

1 MR. RHEINHART: Like I said, good try. 2 Move on. 3 BY MR. KUVIN: 4 Q. With respect to your work as a 5 professional model, what company did you work for? 6 MR. RHEINHART: Instruct the witness not 7 to answer based on the Fifth Amendment 8 privilege. 9 THE WITNESS: On the instruction of my 10 lawyer, I invoke my Fifth Amendment privilege. 11 BY MR. KUVIN: 12 Q. What is your understanding of 13 Mr. Epstein's involvement with the modeling 14 industry? 15 MR. RHEINHART: Standing objection, and 16 instruct the witness not to answer based on 17 Fifth Amendment, on that basis. 18 THE WITNESS: Upon the instruction of my 19 lawyer, I must invoke my Fifth Amendment 20 privilege. 21 BY MR. KUVIN: 22 Q. Were you ever promised anything regarding 23 your modeling career by Jean-Luc Brunel? 24 MR. RHEINHART: Instruct the witness not 25 to answer based on Fifth Amendment, also¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Would you agree with me that Ghislaine Maxwell provides underage girls to Mr. Epstein for sex? MR. RHEINHART: Objection to the form. It assumes she knows anything at all about Ghislaine Maxwell and asks her to assume that she does, and therefore it is compound and ambiguous, and I would instruct her not to answer. THE WITNESS: Upon the instruction of my lawyer, I must invoke my Fifth Amendment privilege. MR. KUVIN: That's a good point. Take a look at what we'll mark as Exhibit 10. (Plaintiffs Exhibit No. 10 was marked for identification.) MR. KUVIN: All me to show it to the camera first. MR. RHEINHART: Okay. MR. KUVIN: Okay. THE WITNESS: Okay.¶

1 BY MR. KUVIN:
2 Q. Take a look at what we marked as Exhibit
3 10. Do you recognize the two people in that
4 photograph?
5 MR. RHEINHART: I'll instruct the witness
6 not to answer based on her Fifth Amendment
7 privilege.
8 THE WITNESS: On the instruction of my
9 lawyer, I must invoke my Fifth Amendment
10 privilege.
11 BY MR. KUVIN:
12 Q. Would you agree with me that's
13 Ghislaine Maxwell on the right and Jeffrey Epstein
14 on the left?
15 MR. RHEINHART: Objection to the form. It
16 assumes that she knows who Ghislaine Maxwell
17 and Jeffrey Epstein are, and therefore it's
18 compound and ambiguous, and I would instruct
19 her not to answer.
20 THE WITNESS: On the instruction of my
21 lawyer, I must invoke my Fifth Amendment
22 privilege.
23 MR. KUVIN: Okay. I will mark this as
24 Exhibit 11.
25¶

1 You're asking the witness three
2 questions at the same time, and I would
3 instruct her not to answer based on the
4 Fifth Amendment.
5 THE WITNESS: On the instruction of my
6 lawyer, I must invoke my Fifth Amendment
7 privilege.
8 MR. KUVIN: Just so we're clear, had she
9 answered the first two questions, then
10 obviously I wouldn't have to ask the third one
11 that has all of them in it but --
12 MR. RHEINHART: If you had accepted her
13 answer, you would have known that she wasn't
14 going to answer these, and we could have saved
15 a few minutes.
16 MR. KUVIN: And as you well know, I must
17 ask the question in order to gain the inference
18 at trial.
19 MR. RHEINHART: I understand.
20 MR. KUVIN: All right.
21 (Plaintiff's Exhibit No. 12 was marked for
22 identification.)
23 BY MR. KUVIN:
24 Q. Do you recognize the gentleman that is
25 shown --¶

1 (Plaintiff's Exhibit No. 11 was marked for
2 identification.)
3 BY MR. KUVIN:
4 Q. Let me show you what we marked as
5 Exhibit 11. Hang on one second.
6 MR. RHEINHART: Sure.
7 BY MR. KUVIN:
8 Q. Do you recognize the young lady shown in
9 Exhibit 11?
10 MR. RHEINHART: I'll instruct the witness
11 not to answer based on her Fifth Amendment
12 privilege.
13 THE WITNESS: On the instruction of my
14 lawyer, I must invoke my Fifth Amendment
15 privilege.
16 BY MR. KUVIN:
17 Q. Do you agree with me that the young girl
18 shown in Exhibit 11 was recruited by Ghislaine
19 Maxwell to, for sexual activity with
20 Jeffrey Epstein?
21 MR. RHEINHART: Objection to the form. It
22 assumes she knows who the person is in Exhibit
23 11, and assumes she knows who Ghislaine Maxwell
24 is, and assumes she knows who Jeffrey Epstein
25 is, and is therefore compound.¶

1 MR. RHEINHART: We'll have a job here.
2 MR. KUVIN: That is true.
3 BY MR. KUVIN:
4 Q. -- that is shown in Exhibit 12?
5 MR. KUVIN: Let me hold this for the
6 camera first.
7 MR. RHEINHART: I'm sorry. Is there a
8 question pending?
9 MR. KUVIN: Yes.
10 BY MR. KUVIN:
11 Q. Do you recognize the gentleman shown in
12 Exhibit 12?
13 MR. RHEINHART: I instruct her not to
14 answer based on the Fifth Amendment.
15 THE WITNESS: On the instruction of my
16 lawyer, I must invoke my Fifth Amendment
17 privilege.
18 BY MR. KUVIN:
19 Q. Would you agree with me that that is
20 Prince Andrew shown in Exhibit 12?
21 MR. RHEINHART: Same instruction.
22 THE WITNESS: On the instruction of my
23 lawyer, I must invoke my Fifth Amendment
24 privilege.
25¶

1 BY MR. KUVIN: 2 Q. Would you agree with me that you have been 3 present where Jeffrey Epstein and Prince Andrew have 4 had sexual relations with underage girls? 5 MR. RHEINHART: Objection to the form, 6 it's compound in that it assumes she knows who 7 the person is in Picture 12, she knows who B Prince Andrew is, and she knows who Jeffrey 9 Epstein is. It's compound and ambiguous, and 10 PII instruct her not to answer based on her 11 Fifth Amendment. 12 THE WITNESS: On the instruction of my 13 lawyer, I must invoke my Fifth Amendment 14 privilege. 15 BY MR. KUVIN: 16 Q. Would you agree with me that Prince Andrew 17 and Jeffrey Epstein used to share underaged girls 18 for sexual relations? 19 MR. RHEINHART: Same objection previously 20 stated, requires her to also speculate who 21 Prince Andrew is. I instruct her not to answer 22 based on the Fifth Amendment. 23 THE WITNESS: On the instruction of my 24 lawyer, I must invoice my Fifth Amendment 25 privilege.¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 break now. MR. KUVIN: Okay. THE VIDEOGRAPHER: We're now off video record. The time is 11:57 am. (A luncheon recess was held.) (Plaintiffs Exhibit No's 4 was marked for identification.) (Plaintiffs Exhibit No. 5 was marked for identification.) • THE VIDEOGRAPHER: We're now on video record. The time is 1:02 p.m. MR. KUVIN: All right, counsel. I'm going to ask a couple more general questions, and then when we get into the specifics of the individual girls, I just want to make sure, once again, on the record, as we've done in every deposition in this case, that we'll use the Plaintiff's full name with the understanding that the final transcript will only contain their initials, and there will be a key at the conclusion that's only provided to the parties in this case and their counsel to be kept confidential going forward. But obviously, for the purposes of this deposition, we will be using full names.¶

1 MR. RHEINHART: Also requires speculation 2 as to who Jeffrey Epstein is as well. 3 BY MR. KUVIN: 4 Q. Do you know who Prince Andrew is? 5 MR. RHEINHART: I'll instruct her not to 6 answer based on the Fifth Amendment. 7 THE WITNESS: On the instruction of my 8 lawyer, I must invoke my Fifth Amendment 9 privilege. 10 MR. KUVIN: It's almost 12:00. Do you 11 want to take a quick lunch? 12 MR. RHEINHART: Sure. How much longer do 13 you think you will be, Mr. Kuvin, before we go 14 on to other counsel? 15 MR. KUVIN: Probably not that much longer. 16 MR. RHEINHART: Okay. 17 MR. KUVIN: I have to get through a couple 18 of more generic stuff, and then get into the 19 specifics of my cases and then — 20 MR. RHEINHART: Okay. So, we, but just so 21 we have a sense of planning whether this is the 22 right time for a lunch break. You're not going 23 to finish in the next 15 or 20 minutes? 24 MR. KUVIN: No, not even close. 25 MR. RHEINHART: Okay. Let's take a lunch¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. RHEINHART: Agreed. MR. KUVIN: Okay. Is there any disagreement with that around the table? MR. HOROWITZ: Agreed. MR. WEISSING: Agreed. MS. EZELL: Agreed. MR. KUVIN: Jack, do you agree to the -- MR. GOLDBERGER: I thought I'm not a part of it. MR. KUVIN: Well, you've been playing a part, so I want to make sure you agree. MR. GOLDBERGER: Yeah, I agree. I agree. MR. RHEINHART: Hold on. Let me just explain to her what we're talking about. MR. KUVIN: Please do. MR. RHEINHART: But when the transcript is typed up, it won't have her name it will just have initials. But we'll get a code that explains the name. So that way you would be asked if you recognize the name not a set of initials that you may not understand or a Jane Doe number that you do not know. MR. KUVIN: That's way too confusing. Okay? MR. RHEINHART: Correct.¶

1 BY MR. KUVIN:
2 Q. Let's take a look at what I've marked --
3 premarked as Exhibit 4. It's a stack of documents,
4 just so you understand what this is and your
5 attorney can object or agree or disagree as he sees
6 fit, but this is a stack of documents that was part
7 of the trash pull from Jeffrey Epstein's home as
8 part of the criminal investigation. Just so you're
9 aware of what these are.
10 MR. RHEINHART: That was retrieved, that
11 was retrieved by the Palm Beach Police
12 Department from the trash --
13 MR. KUVIN: That's correct.
14 MR. RHEINHART: -- at the home of what is
15 known to be Mr. Epstein's home?
16 MR. KUVIN: Correct.
17 MR. RHEINHART: Okay.
18 MR. KUVIN: All right. And that's not a
19 question. I just wanted to kind of give you a
20 context for what I'm going to be asking you
21 about.
22 MR. RHEINHART: Thank you.
23 BY MR. KUVIN:
24 Q. All right. In taking a look at Exhibit 4,
25 I'd like you to take a look at the front page, the¶

1 objection to the form.
2 THE WITNESS: At the instruction of my
3 lawyer, I must invoke my Fifth Amendment
4 privilege.
5 BY MR. KUVIN:
6 Q. Yes. Do you know [REDACTED]?
7 MR. RHEINHART: Instruct the witness not
8 to answer the question based on her Fifth
9 Amendment privilege.
10 THE WITNESS: On the instruction of my
11 lawyer, I must exercise my Fifth Amendment
12 privilege.
13 BY MR. KUVIN:
14 Q. Will you agree with me that on the first
15 page of Exhibit 4, you were to arrange for roses to
16 be delivered to Jane Doe No. 103 at her high school
17 performance?
18 MR. RHEINHART: Objection to the form.
19 It's compound in that it assumes this is the
20 witness's handwriting and assumes the witness
21 knows a person by the name of Jane Doe No. 103
22 and the witness otherwise knows Jeffrey Epstein
23 whose name is at the bottom of the paper, and
24 therefore, it's compound and ambiguous, and
25 instruct her not to answer.¶

1 first page of those documents.
2 Is that your handwriting, [REDACTED]?
3 MR. RHEINHART: Instruct the witness not
4 to answer based on the Fifth Amendment
5 privilege.
6 THE WITNESS: At the instruction of my
7 lawyer, I must exercise my Fifth Amendment
8 right.
9 BY MR. KUVIN:
10 Q. And, in fact, that is your handwriting on
11 this notepad, is it not?
12 MR. RHEINHART: Same instruction. It's
13 the same question.
14 THE WITNESS: On the instruction of my
15 lawyer, I must invoke my Fifth Amendment right.
16 BY MR. KUVIN:
17 Q. In this note do you agree that you
18 arranged for an extension of one month on the rental
19 car for a young lady under the age of 16?
20 MR. RHEINHART: Objection to the form. It
21 is compound. It assumes that this is her
22 handwriting. It doesn't identify who the young
23 lady might be, and it's otherwise ambiguous, so
24 I instruct her not to answer on the Fifth
25 Amendment privilege in addition to the legal¶

1 THE WITNESS: On the instruction of my
2 lawyer, I must exercise my Fifth Amendment
3 right.
4 MR. KUVIN: I forgot to mention this at
5 the beginning, but objection to form usually
6 covers all that stuff like vague and compound,
7 and --
8 MR. RHEINHART: Okay.
9 MR. KUVIN: -- I'll leave it up to you,
10 but objection to form as far as the civil arena
11 context will cover all of those.
12 MR. RHEINHART: Just figured I'd make the
13 record clear in case we ever have an issue, or
14 in case you want to correct it based on what I
15 believe to be the improper form, I will give
16 you a chance to correct it.
17 BY MR. KUVIN:
18 Q. No problem. All right. On Page 2 of
19 Exhibit 4, if you'd take a look at that. Is that
20 your handwriting?
21 MR. RHEINHART: Instruct the witness not
22 to answer based on the Fifth Amendment
23 privilege.
24 THE WITNESS: On the instruction of my
25 lawyer, I choose to exercise my Fifth Amendment¶

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 MR. RHEINHART: Objection to the form and 2 instruct the witness not to answer based upon 3 her Fifth Amendment privilege. 4 THE WITNESS: On the instruction of my 5 lawyer, I must invoke my Fifth Amendment right. 6 BY MR. KUVIN: 7 Q. Would you agree with me that Larry was 8 calling to warn Mr. Epstein to leave town because he was going to be arrested? MR. RHEINHART: Objection to the form. The question assumes facts that are not before her, and it requires her to speculate, and also implies that she knows anything at all about Jeffrey Epstein, so I will instruct her not to answer. THE WITNESS: On the instruction of my lawyer, I wish to exercise my Fifth Amendment right. BY MR. KUVIN: Q. Take a look at Page 3 of Exhibit 4, please. Is that your handwriting? MR. RHEINHART: I'll instruct her not to answer based on the Fifth Amendment privilege. MR. KUVIN: Before we do that, would you consult with her?¶

1 right. 2 BY MR. KUVIN: 3 Q. Do you know who Larry is, as referred to 4 in Page 2 of Exhibit 4? 5 MR. RHEINHART: Fm sorry. Can you -- 6 BY MR. KUVIN: 7 Q. Do you know who — 8 MR. RHEINHART: — restate the question? 9 BY MR. KUVIN: 10 Q. Do you know who Larry is as referred to in 11 Page 2 of Exhibit 4? 12 MR. RHEINHART: So, just so I'm clear, 13 what the question is, the document on its face 14 has the name Larry in it. You're just asking 15 this witness whether she knows who this person 16 Larry is? 17 MR. KUVIN: Correct. 18 MR. RHEINHART: Instruct the witness not 19 to answer based on her Fifth Amendment 20 privilege. 21 THE WITNESS: On the instruction of my 22 lawyer, I must invoke my Fifth Amendment right. 23 BY MR. KUVIN: 24 Q. Do you know why Larry was recommending 25 that Mr. Epstein leave?¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. RHEINHART: Okay. I would be happy to. MR. KUVIN: I just want to clarify, because I don't think -- MR. RHEINHART: Okay. MR. KUVIN: I don't think this is a problem, but I just want to clear it up. MR. RHEINHART: Thank you, Mr. Kuvin. I'll let her answer that question. MR. KUVIN: Not a problem. MR. RHEINHART: So the question pending is, is that your handwriting? MR. KUVIN: Correct. BY MR. KUVIN: Q. Is this your handwriting? Just yes or no. A. No. Q. Okay. Thank you. All right. Let's look at Page 4 of Exhibit 4. All right. This one's a little different. Is this your handwriting? MR. RHEINHART: Let me consult with her again. Okay. That's fine. You can answer the question consistent with the conversation we just had. THE WITNESS: No.¶

Page 114¶

Page 116¶

1 BY MR. KUVIN: 2 Q. Do you know who Danielle is as referred to 3 in this note of Page 4 of Exhibit 4? 4 MR. RHEINHART: Instruct the witness not 5 to answer based on her Fifth Amendment 6 privilege. 7 THE WITNESS: On the instruction of my 8 lawyer, I must exercise my Fifth Amendment 9 right. 10 BY MR. KUVIN: 11 Q. All right. Lets look at Page 5, 12 Exhibit 4. 13 Before we go to Page 5, rather, going 14 back to Page 4 for a minute. Will you agree with me 15 that Danielle as referred to in Page 4 of Exhibit 4 16 is a girl that is under the age of 16? 17 MR. RHEINHART: Object to the form. You 18 previously asked if she knew who Danielle was, 19 and she invoked her Fifth Amendment privilege. 20 Since the new question presumes that she does 21 know who Danielle is she is going to invoke her 22 Fifth Amendment privilege upon my instruction. 23 MR. KUVIN: All right. Let's look at 24 Page 5. 25 MR. RHEINHART: Let her answer.¶

1 MR. KUVIN: I'm sorry, go ahead. 2 THE WITNESS: On the instruction of my 3 lawyer, I must invoke my Fifth Amendment 4 privilege. 5 BY MR. KUVIN: 6 Q. All right. Take a look at Page 5, if you 7 would. Have you ever ordered anything, anything 8 yourself from Amazon.com? 9 MR. RHEINHART: You're asking for herself 10 or anyone else if she has ever placed an order 11 with Amazon.com for any reason? 12 MR. KUVIN: I am asking whether she 13 personally has ever placed an order with a 14 company called Amazon.com. 15 MR. RHEINHART: Yes or no. You can answer 16 that. 17 THE WITNESS: Yes. 18 BY MR. KUVIN: 19 Q. Okay. So you would agree with me that you 20 know what Amazon.com is? 21 A. Yes. 22 Q. Okay. Now, have you ever placed an order 23 through Amazon.com for things to be delivered at 24 358 El Brillo Way? 25 MR. RHEINHART: Instruct the witness to¶

1 that Page 5 of Exhibit 4 appears to be a receipt for 2 books ordered through Amazon.com? 3 MR. RHEINHART: You can answer that yes or 4 no. 5 THE WITNESS: It looks like a receipt from 6 Amazon. 7 BY MR. KUVIN: 8 Q. Okay. And did you place this order for 9 Jeffrey Epstein? 10 MR. RHEINHART: Instruct the witness not 11 to answer the question in that the question 12 presumes that she knows who Jeffrey Epstein is, 13 and therefore, I instruct her not to answer. 14 THE WITNESS: On advice of counsel, I must 15 invoke my Fifth Amendment privilege. 16 BY MR. KUVIN: 17 Q. Have you ever read the book identified in 18 Page 5 of Exhibit 4 called Slave Craft: Road Maps 19 for Erotic Servitude - Principals, Skills and Tools? 20 MR. RHEINHART: Instruct the witness not 21 to answer based on her Fifth Amendment 22 privilege. 23 THE WITNESS: On the instruction of my 24 lawyer, I must choose to invoke my Fifth 25 Amendment right.¶

1 invoke her Fifth Amendment privilege as to that 2 question. 3 THE WITNESS: On the instruction of my 4 lawyer, I must invoke my Fifth Amendment 5 privilege. 6 BY MR. KUVIN: 7 Q. Will you agree with me 8 MR. RHEINHART: I'm sorry, Mr. Kuvin, for, 9 for the record, the page, pages of this exhibit 10 are not numbered, but the page we're looking at 11 purports to be a receipt for an order from 12 Amazon.com; is that correct? 13 MR. KUVIN: Correct. I just want her to 14 establish foundation before I got into 15 specifics. 16 MR. RHEINHART: No, but you referred to it 17 as Page 5, but they are not numbered, so I just 18 wanted to make sure that we're looking at the 19 same page on the exhibit. 20 MR. KUVIN: That is true. I'm just trying 21 to establish foundation for the questions I'm 22 about to ask her. 23 MR. RHEINHART: Understood. 24 BY MR. KUVIN: 25 Q. All right. would you agree with me¶

1 BY MR. KUVIN: 2 Q. Did you ever see that book I just 3 described at the home of Jeffrey Epstein on 4 358 El Brillo Way? 5 MR. RHEINHART: Objection to the form in 6 that it presumes she knows Jeffrey Epstein and 7 has ever been to 358 El Brillo Way. So, I 8 instruct her not to answer based on the Fifth 9 Amendment 10 THE WITNESS: On the instruction of my 11 lawyer, I must choose to invoke my Fifth 12 Amendment right. 13 BY MR. KUVIN: 14 Q. Have you ever seen the book, Training With 15 Miss Abernathy: A Workbook for Erotic Slaves and 16 Their Owners, at the home of Jeffrey Epstein on 17 358 El Brillo Way? 18 MR. RHEINHART: Same objection and same 19 instruction as the previous question. 20 THE WITNESS: On the instruction of my 21 lawyer, I must choose to invoke my Fifth 22 Amendment right. 23 BY MR. KUVIN: 24 Q. Have you ever read that book that I just 25 described which is shown in Page 5 of Exhibit 4?¶

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 MR. RHEINHART: Same instruction. 2 THE WITNESS: On the instruction of my 3 lawyer, I must choose to invoke my Fifth 4 Amendment right. 5 BY MR. KUVIN: 6 Q. Let's look at the sixth page of Exhibit 4, 7 please. Is that your handwriting? 8 A. No. Q. All right. Let's look at Page 7. Is that your handwriting? A. No. Q. Okay. Look at the next page which would be Page 8. Is that your handwriting? A. No. Q. Let's see how much quicker this goes. Let's look at Page 9. Is that your handwriting? A. No. Q. Look at Page 9 again, if you would. MR. RHEINHART: When you say Page 9, that's the page that purports to say 10:00. MR. KUVIN: Dr. Bard. MR. RHEINHART: -- Dr. Bard at the top? MR. KUVIN: Correct. MR. RHEINHART: Okay.¶

1 BY MR. KUVIN: 2 Q. This note, Page 9 of Exhibit 4, appears to 3 state that Sarah is trying to move -- and then 4 there's a blanked out name, for II then Brittany 5 could work at 6. Do you know anyone with the name 6 Brittany? 7 MR. RHEINHART: If she knows anyone in the 8 world by that name? 9 MR. KUVIN: Yeah. We could start with 10 that. 11 MR. RHEINHART: Pm saying, in the 12 context, are you asking in the context of this 13 note which you just read, or are you asking, 14 generically, does she know anyone in the world 15 by the name of Brittany? 16 MR. KUVIN: Why don't we first do it in 17 the context of this note. 18 BY MR. KUVIN: 19 Q. Is this note referring to you when it 20 says, "Sarah"? 21 MR. RHEINHART: Instruct the witness not 22 to answer based on her Fifth Amendment 23 privilege. 24 THE WITNESS: On the advice of counsel, I 25 must invoke my Fifth Amendment right.¶

1 BY MR. KUVIN: 2 Q. Do you know who Dr. Bard is? 3 MR. RHEINHART: Instruct the witness not 4 to answer based on the Fifth Amendment, because 5 this sheet of paper has Jeffrey Epstein's name 6 on the bottom, so the question implies that she 7 knows some connection between Dr. Bard and 8 Mr. Epstein. 9 MR. KUVIN: Hang on a minute. Based on 10 the objection, let me reword the question. 11 BY MR. KUVIN: 12 Q. Independent from this note and independent 13 from anyone who may or may not be known as 14 Jeffrey Epstein, do you know anyone by the name of 15 Dr. Bard? 16 A. I'm sorry. Ask the question again. 17 Q. Yes. I don't want you to assume anything 18 from, the purpose of my question has anything to do 19 with someone who may be known as Jeffrey Epstein. 20 All I'm asking you is, generally, do 21 you know a person by the name of Dr. Bard? 22 MR. RHEINHART: Let me consult. 23 MR. KUVIN: Yes, yeah. 24 THE WITNESS: At the advice of counsel, I 25 must invoke my Fifth Amendment right¶

1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. KUVIN: Q. In the context of this note, do you know who Brittany is? MR. RHEINHART: Same instruction. THE WITNESS: On the advice of counsel, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Alt right. Let's look at Page 10. MR. RHEINHART: Mr. Kuvin, let me go back. MR. KUVIN: Sure. MR. RHEINHART: As to Page I of this exhibit, I think you had asked the witness whether this was her handwriting. MR. KUVIN: Do you want to have her go back and answer? MR. RHEINHART: Yes, I would. Having consulted with her further, I will have her go back to this question. MR. KUVIN: Let's do that. P11, I'll go back and ask the question so that we can be clear. BY MR. KUVIN: Q. On the Exhibit 4, the first page of Exhibit 4,M, is that your handwriting? Yes or no. .ue¶

1 A. No. 2 Q. Okay. All right. Let's skip Page 10, 3 because I think that's just a duplicate, and go to 4 Page II, if you would. 5 MR. RHEINHART: Page II is -- 6 MR. KUVIN: It looks like DTG Operations, 7 d/b/a Dollar Rent a Car. 8 MR. RHEINHART: Got it. It's a printed 9 sheet, not a handwritten sheet. 10 MR. KUVIN: Correct. 11 MR. RHEINHART: Okay. Thank you. 12 BY MR. KUVIN: 13 Q. All right. Do you know a gentleman by the 14 name of Janusz Banasiak, spelled J-a-n-u-s-z, 15 B-a-n-a-s-i-a-k? 16 MR. RHEINHART: Instruct the witness not 17 to answer based on her Fifth Amendment 18 privilege. 19 THE WITNESS: On the instruction of, my 20 lawyer, I must invoke my Fifth Amendment 21 privilege. 22 BY MR. KUVIN: 23 Q. =, isn't it true that you rented cars 24 through Dollar Rent a Car for underage girls, girls 25 under the age of 18?¶

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 it in giving my advice, so thank you for 2 clarifying. 3 MR. KUVIN: Absolutely. 4 BY MR. KUVIN: 5 Q. All right. In Page I I of Exhibit 4, 6 there's a reference in the top right-hand corner, a 7 message to a Mr. Goldsmith. Do you see that? 8 A. Uh-huh. Q. Yes? MR. RHEINHART: You have to say yes or no on the record. THE WITNESS: Yes, I see it. BY MR. KUVIN: Q. Okay. All right. Do you know who Mr. Goldsmith is? MR. RHEINHART: I instruct the witness not to answer based on her privilege against self-incrimination. THE WITNESS: At the advice of counsel, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Is this your handwriting on exhibit -- on the messages shown in Exhibit 4, Page I I? MR. RHEINHART: Same instruction. THE WITNESS: At the advice of counsel, I¶

Page 126¶

1 MR. RHEINHART: Instruct the witness not 2 to answer based on the Fifth Amendment 3 privilege. 4 THE WITNESS: On the instruction of my 5 lawyer, I must invoke the Fifth Amendment 6 privilege. 7 BY MR. KUVIN: 8 Q. Did you rent any cars from Dollar Rent a 9 Car in West Palm Beach in the last five years? 10 MR. RHEINHART: Same instruction. 11 THE WITNESS: On the instruction of my 12 lawyer, I must invoke my Fifth Amendment 13 privilege. 14 BY MR. KUVIN: 15 Q. Let's take a look at Page 11. 16 MR. RHEINHART: If we can just -- let me 17 go back, Mr. Kuvin, to clarify the prior two 18 questions. When you say, "did you rent," did 19 you mean did she personally pay for the rental, 20 or was she, in any way, involved in arranging 21 the rental? 22 MR. KUVIN: The second part, in any way 23 involved in arranging for the rental of a 24 vehicle. 25 MR. RHEINHART: That's how I interpreted¶

N wen,¶

Page 128¶

1 must invoke my Fifth Amendment privilege. 2 MR. RHEINHART: Hold on a second, Sarah. 3 MR. KUVIN: Yeah, check. 4 MR. RHEINHART: Okay. Can you repeat the 5 question again? Maybe I misheard it, 6 Mr. Kuvin. 7 MR. KUVIN: Yeah, not a problem. Let me 8 lay a little foundation for it. 9 MR. RHEINHART: That's okay. If you can 10 just ask the question again. I think I just 11 misheard what you were asking. 12 BY MR. KUVIN: 13 Q. Is this your handwriting shown on the 14 messages which is Page 11 of Exhibit 4? 15 A. No. 16 Q. Okay. Is this handwriting that of 17 18 19 20 21 MR. KUVIN: I knew somebody would know. 22 MR. RHEINHART: Did we get a 23 pronunciation, I'm sorry? 24 MR. KUVIN: Yes. 25 ronounce -- I'm so¶

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 BY MR. KUVIN: 2 . Is this the handwriting of 3 if you know? 4 MR. RHEINHART: Hold on. Let me object to 5 the form in that it presumes she knows what 6 handwriting is like or that she's 7 ever known So before you ask the 8 question, try to clarify that. MR. KUVIN: Well, that's what I'm trying to find out. BY MR. KUVIN: 9IS . recognize this as the handwriting of And it can be a yes or no. MR. RHEINHART: My, my objection to the form is that you, you haven't asked her whether she actually knows who is, or whether she would recognize her handwriting if she saw it. MR. KUVIN: I would love to ask that question if she'd answer it. MR. RHEINHART: Well, if she'll answer, that's a different question. But I think you need to ask it first otherwise this question is ambiguous. MR. KUVIN: All right.¶

1 BY MR. KUVIN: 2 Q. Not, not to beat a dead horse on the 3 point, do you know 4 MR. RHEINHART: I instruct the witness not 5 to answer. 6 THE WITNESS: On advice of counsel, I must 7 invoke my Fifth Amendment privilege. 8 BY MR. KUVIN: 9 Q. Have you seen 10 handwriting in the past? 11 MR. RHEINHART: Objection to the form as 12 previously stated. instruct the witness 13 not to answer. 14 THE WITNESS: On advice of counsel, I must 15 invoke my Fifth Amendment privilege. 16 BY MR. KUVIN: 17 Q. Do you recd ize Pa e 11 in Exhibit 4 as 18 the handwriting of 19 MR. RHEINHART: Objection to the form for 20 the reasons previously stated many, many times, 21 and I will instruct her not to answer. 22 THE WITNESS: At the advice of counsel, I 23 must invoke my Fifth Amendment privilege. 24 BY MR. KUVIN: 25 Q. Did you ever see these messages that¶

1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 appear to be directed — well, let me, let me back up. Page II of Exhibit 4 appears to be a message dated October 2nd, 2005, from Sarah. Do you see that top left-hand corner? A. Yes. Q. Okay. At 10:40 a.m. My question is: Did you call and leave a message at 10:40 am. on October 2,2005, stating: Julia's sick and she can't come today? MR. RHEINHART: Instruct the witness not to answer the question based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer I must exercise my Fifth Amendment privilege. BY MR. KUVIN: Q. Upside down at the bottom of Page 11 is another phone message dated 10/1 of 2005. Appears to be written to someone named Sarah. Do you see that? A. Yes. Q. Okay. Do you — MR. RHEINHART: Is it written, I'm sorry, is it written to someone named Sarah or it¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 appears to be a phone call from a person named Sarah? MR. KUVIN: From a person named Sarah. Thank you. BY MR. KUVIN: Q. Did you call someone, anyone on October 1 of 2005 at 9:50 a.m., to confirm two people, one at 11:00 and one at 4:00 p.m.? MR. RHEINHART: Instruct the witness not to answer based on her Fifth Amendment privilege against self-incrimination since this document was seized from Mr. Epstein's home. THE WITNESS: At the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Are you the Sarah that's referred to in these phone messages that we've been looking at? MR. RHEINHART: Instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: 9. Let's skip Page 12 and go to Page 13 of¶

1 this same exhibit, if you would. Okay. 2 Is that your handwriting on Page 13 3 which happens to be a note stating "Johanna S. is 4 coming"? 5 MR. RHEINHART: Okay. Hold on. Can you 6 just show me what page you're looking at? 7 Okay. We skipped a page. 8 THE WITNESS: No. 9 BY MR. KUVIN: 10 Q. Okay. Do you recognize whose it is? 11 MR. RHEINHART: Let me talk to you again. 12 BY MR. KUVIN: 13 Q. If it's a yes, you might want to talk to 14 him; if it's a no, it might be quick. 15 A. No, no. Sony. 16 Q. Let's look at Page 14, same exhibit. The 17 note on the right-hand side states, "The girl from 18 St. Bart's got sick so she won't be able to come. 19 Sarah got message from her." First of all, just 20 generally, do you see the note I'm referring to? 21 A. Yes. 22 Q. Okay. Do you know what that is talking 23 about? 24 A. No. 25 Q. Is that your handwriting?¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Fifth Amendment right. BY MR. KUVIN: Q. Are you aware that Jeffrey Epstein would refer to "work" as performing naked massages for him? MR. RHEINHART: Object to the form of the question. It's compound and I instruct the witness not to answer. THE WITNESS: On advice of counsel, I wish to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Let's take a look at the next page, Page 16. All right. If we look at not the message, the phone message, but the note next to that it says: Haley on Saturday with Sage at 10:30. Do you know who Haley is as referred to in this note? A. On the advice of counsel, I must invoke my Fifth Amendment right. Q. Do you know who Sage is as referred to in this note? A. On the advice of counsel, I must invoke my Fifth Amendment ri t. MR. I haven't heard the counsel give any advice.¶

1 A. No. 2 Q. Did Mr. Epstein obtain girls under the age 3 of 16 from St. Bart's? 4 MR. RHEINHART: Instruct the witness not 5 to answer. Object to the form of the question 6 in that it presumes that she knows who 7 Mr. Epstein is. 8 THE WITNESS: On advice of counsel, I must 9 invoke my Fifth Amendment privilege. 10 BY MR. KUVIN: 11 Q. All right. Let's take a look at the next 12 page. Appears to be a note, phone message of I 13 can't read the date, 2005 to Jeffrey from 14 Just generally, do you see what I'm 15 talking about so we're on the same page here? 16 A. Yes. 17 Q. Okay. Do you know who is? 18 A. On the advice of counsel, I wish to invoke my 19 Fifth Amendment right. 20 Q. All right. The note appears to say: She 21 called again, if she could work any time Monday 22 through Friday. 23 Do you know what that message 24 pertains to? 25 A. On advice of counsel, I wish to invoke my¶

1 MR. RHEINHART: You don't know what we've 2 talked about outside of the room so... 3 MR. : Just changing the procedure 4 is all? 5 MR. RHEINHART: I'm changing the procedure 6 for Mr. Kuvin. 7 MR. KUVIN: Pm all happy for speed. 8 BY MR. KUVIN: 9 Q. All right. Let's look at Page 17 of 10 Exhibit 4. It appears to be a phone message at the 11 bottom dated 9/1/05 to Jeffrey from Jean-Luc. Let 12 me ask this: Do you recognize the phone number 13 that's listed there of (646)286-7000? 14 MR. RHEINHART: Instruct the witness not 15 to answer based on her Fifth Amendment 16 privilege and self-incrimination. 17 THE WITNESS: On advice of counsel, I must 18 invoke my Fifth Amendment right. 19 MR. KUVIN: Let me show this one to the 20 camera if I could. If you could focus on the 21 bottom message for me. 22 THE VIDEOGRAPHER: I can't really read 23 that. 24 MR. KUVIN: Do I need to tilt it? 25 THE VIDEOGRAPHER: I think you need to¶

1 bring the whole paper up closer. 1 Do you — first of all, do you see 3 THE VIDEOGRAPHER: Yes, towards the lens. 3 thing here? 4 MR. KUVIN: Just pass that up so we can 4 A. Yes. 5 get a good shot of the bottom message. 5 Q. Okay. Do you know who "Haley" is 6 THE VIDEOGRAPHER: Up a little higher, 6 referring to in this note? 7 please. Let it focus. That's good. Go out. 7 MR. RHEINHART: Instruct the witness not 8 Okay. 8 to answer based on her Fifth Amendment 9 MR. KUVIN: All right. Thank you very 9 privilege. 10 much. 10 THE WITNESS: On the instruction of my 11 BY MR. KUVIN: 11 lawyer, I must invoke my Fifth Amendment 12 Q. The message appears to read: 9/1/2005 to 12 privilege. 13 Jeffrey, 8:08, Jean-Luc, telephone. He has a 13 BY MR. KUVIN: 14 teacher for you to teach you how to speak Russian. 14 Q. Does your handwriting appear anywhere on 15 She is two times eight years old, not blonde. 15 Page 19 here — 16 Lessons are free and you can have first today if you 16 A. On the -- 17 call. Do you know what that message is referring 17 Q. -- on either note? 19 MR.. RHEINHART: Instruct the witness not 19 Fifth Amendment privilege. 20 to answer the question. Object to the form of 20 Q. Is that your handwriting on the left in 21 the question because in that it presumes she 21 the note that I just read that says: Haley, 22 has knowledge of either Jeffrey or Jean-Luc or 22 11:00 a.m.? 23 that phone number. 23 MR. RHEINHART: Same instruction. 24 THE WITNESS: On the advice of counsel, I 24 THE WITNESS: On the instruction of my 25 wish to invoke my Fifth Amendment right. 25 lawyer, I must invoke my Fifth Amendment¶

2 MR. KUVIN: Towards you? 2 that in front of you? Are we talking about the same 18 to? 18 A. On the advice of my lawyer, I must invoke my¶

1 BY MR. KUVIN: 1 privilege. 2 Q. Would you agree with me that this message 2 BY MR. KUVIN: 3 is a message from Jean-Luc, that he's providing a 3 Q. All right. Let's take a look at the next 4 16-year-old girl to Jeffrey Epstein? 4 page which is Page 20. Is that your handwriting on 5 MR. RHEINHART: Object to the form in that 5 this paper? 6 it calls for speculation and also assumes facts 6 MR. RHEINHART: Let me talk to her. 8 1 instruct her to invoke her Fifth Amendment 8 I wish to invoke my Fifth Amendment privilege. 9 privilege. 9 BY MR. KUVIN: 10 THE WITNESS: On the instruction from my 10 Q. Is this a list of girls that were being 11 lawyer, I must invoke my Fifth Amendment 11 provided to Jeffrey Epstein for sex? 13 BY MR. KUVIN: 13 standing objection previously stated. I will 14 Q. Skip the next page if you would, and the 14 instruct the witness not to answer that 15 following page will be Page 19 of Exhibit 4. It 15 question. 16 should be two messages. 16 THE WITNESS: On the instruction of my 17 MR. RHEINHART: Show me what you're 17 lawyer, I must invoke my Fifth Amendment 18 looking at. 18 privilege. 19 MR. KUVIN: And the top left one says, 19 BY MR. KUVIN: 20 "Friday." 20 Q. Did Jeffrey Epstein not like girls that 21 MR. RHEINHART: Thank you. 21 had tattoos? 22 BY MR. KUVIN: 22 MR. RHEINHART: Objection to the form 23 Q. The message on the left-hand side that 23 based on the standing objection and the same 24 appears to be, have a date of 4/8/05 and a number 7 24 instruction. 25 written on it. It says: Haley, 11:00 am. 25 THE WITNESS: On the instruction of my¶

7 as to Mr. Jean-Luc and Mr. Epstein; therefore, 7 THE WITNESS: On the advice of my lawyer, 12 privilege. 12 MR. RHEINHART: Objection to the form, the¶

1 lawyer, I must invoke my Fifth Amendment
2 privilege.
3 BY MR. KUVIN:
4 Q. Did Jeffrey Epstein not like girls that
5 had blonde hair?
6 MR. RHEINHART: Standing objection and the
7 same instruction.
8 THE WITNESS: On the instruction of my
9 lawyer, I must invoke my Fifth Amendment
10 privilege.
11 BY MR. KUVIN:
12 Q. Take a look at the next page, if you
13 would. This one.
14 MR. RHEINHART: Thank you.
15 BY MR. KUVIN:
16 Q. Is that your handwriting?
17 A. On instruction of my lawyer, I must invoke my
18 Fifth Amendment privilege.
19 Q. Is this an additional -- on Page 21, is
20 this an additional list of girls that were being
21 provided to Jeffrey Epstein for sex?
22 MR. RHEINHART: I'm sorry. Did we change
23 to a different page or the same page?
24 MR. KUVIN: The same page.
25¶

1 BY MR. KUVIN:
2 Q. Is this an additional list of girls that
3 were --
4 MR. RHEINHART: Thank you.
5 BY MR. KUVIN:
6 Q. -- being provided to Jeffrey Epstein for
7 sex?
8 MR. RHEINHART: Objection to the form.
9 The same objection and the same instruction.
10 THE WITNESS: On the instruction of my
11 lawyer, I must invoke my Fifth Amendment
12 privilege.
13 BY MR. KUVIN:
14 Q. Page 22. Note on the right appears to
15 say: Johanna has a friend, Andrea, that would like
16 to work tonight. Do you know who Johanna is refer,
17 referring to in that note?
18 MR. RHEINHART: Instruct the witness not
19 to answer based on the privilege against
20 self-incrimination.
21 THE WITNESS: On the advice of my lawyer,
22 I wish to assert my Fifth Amendment right.
23 BY MR. KUVIN:
24 Q. Do you know who Andrea is referring to in
25 that note?¶

1 MR. RHEINHART: Same instruction.
2 THE WITNESS: On the advice of my lawyer,
3 I must choose to invoke my Fifth Amendment
4 right.
5 BY MR. KUVIN:
6 Q. Do you know who E.W. is?
7 MR. RHEINHART: Same instruction.
8 THE WITNESS: On the advice of my lawyer,
9 I wish to invoke my Fifth Amendment privilege.
10 BY MR. KUVIN:
11 Q. Do you know who L.M. is?
12 MR. RHEINHART: Let me consult for a
13 second.
14 MR. KUVIN: Yep.
15 (A discussion was held off the record.)
16 MR. RHEINHART: Mr. Kuvin, I'm just asking
17 you to clarify. Are you asking if she's ever
18 heard the name of these people or whether she's
19 actually ever met someone she knows to have
20 that name?
21 MR. KUVIN: Second part, whether she knows
22 someone personally by that name. I don't want
23 to know what somebody may have told her.
24 MR. RHEINHART: Sure.
25 MR. KUVIN: Certainly not attorneys or¶

1 anything like that. I want to know whether she
2 has any personal knowledge of someone by the
3 name of L.M.
4 MR. RHEINHART: Okay. Based on our
5 conversation, she can answer or not answer the
6 question.
7 THE WITNESS: On the advice of my lawyer,
8 I choose to invoke my Fifth Amendment right.
9 MR. KUVIN: Okay. It's like a
10 cough/sneeze.
11 MR. [REDACTED]: I tried to stifle it, but --
12 MR. GOLDBERGER: You got it all over me.
13 Just kidding.
14 MR. [REDACTED]: You don't want to get this.
15 I've had if for a couple of days.
16 MR. KUVIN: What number are we on? 13.
17 That's why I always leave some with numbers
18 still on there to show the picture to the
19 camera.
20 Exhibit 13 will be pursuant to
21 confidentiality and the identities of the
22 girls involved in this case.
23 MR. RHEINHART: As I presume the prior
24 questions were as well.
25 MR. KUVIN: Yes. Absolutely. This is¶

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 privilege. 2 BY MR. KUVIN: 3 Q. Do you agree with me that you arranged to 4 have the girl shown in Exhibit 13 be brought to 5 Mr. Epstein's home for sex with Mr. Epstein? 6 MR. RHEINHART: Objection to the form as 7 compound, and also the standing objection, and 8 instruct the witness not to answer. THE WITNESS: On the advice of my lawyer, I must choose to exercise my Fifth Amendment privilege. BY MR. KUVIN: Q. Would you agree with me that the girl shown in Exhibit 13 did, in fact, come to Mr. Epstein's home in 2005? MR. RHEINHART: Same objection previously stated. It's compound as to the date, place, person, and also presumes knowledge of Mr. Epstein, so I would instruct her not to answer. THE WITNESS: On the advice of my lawyer, I must choose to exercise my Fifth Amendment privilege. BY MR. KUVIN: Q. Do you agree with me that the girl shown¶

1 different because it's an exhibit. 2 MR. RHEINHART: Agreed. 3 MR. KUVIN: Okay. 4 (Plaintiffs Exhibit No. 13 was marked for 5 identification.) 6 MR. RHEINHART: We're moving off of 7 Exhibit 12? 8 MR. KUVIN: Yes. 9 MR. RHEINHART: I was looking at the next 10 exhibit. 11 MR. KUVIN: We're done with the trash. 12 MR. RHEINHART: Okay. 13 BY MR. KUVIN: 14 Q. Just take a look at Exhibit 13. Do you 15 recognize the girl in that photograph? 16 A. On the advice of my lawyer, I must choose to 17 exercise my Fifth Amendment privilege. 18 Q. Do you agree with me that that girl shown 19 in that photograph is B.B.? 20 MR. RHEINHART: Objection to the form for 21 the reasons previously stated, causes her to 22 speculate, and I instruct her not to answer 23 based on her Fifth Amendment privilege. 24 THE WITNESS: On the advice of my lawyer, 25 1 must choose to exercise my Fifth Amendment¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in Exhibit 13 came to Mr. Epstein's home when she was only IS years old? MR. RHEINHART: Objection to the form based on the standing objection, also speculation as to any age and instruct the witness not to answer. THE WITNESS: On the advice of my lawyer, I must choose to exercise my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree with me that when you arranged to have this girl come to Mr. Epstein's home, that you were aware that she was 15 years old? MR. RHEINHART: Objection to the form. It is compound. It assumes facts that are not admitted by this witness, and it's ambiguous in that regard, and therefore I instruct her not to answer. THE WITNESS: On the advice of my lawyer, I must choose to exercise my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree that when this girl was brought to Mr. Epstein's home, that she performed a massage on Mr. Epstein while he was naked?¶

1 MR. RHEINHART: Objection to the form, 2 standing objection. The question assumes that 3 this witness has any knowledge of 4 Jeffrey Epstein or whether this person ever 5 came to Mr. Epstein's home. It is therefore 6 ambiguous, and I instruct her not to answer. 7 THE WITNESS: On the instruction of my 8 lawyer, I must choose to exercise my Fifth 9 Amendment right. 10 BY MR. KUVIN: 11 Q. Do you agree with me that this girl shown 12 in Exhibit 13 was 15 years old at the time she was 13 asked by Jeffrey Epstein to remove her clothes? 14 MR. RHEINHART: Objection to the form. It 15 requires speculation and assumes facts relating 16 to Mr. Epstein and events that may have 17 occurred which this witness has no knowledge 18 and has not admitted any knowledge. And 19 instruct her not to answer. 20 THE WITNESS: On advice of counsel I must 21 choose to exercise my Fifth Amendment right. 22 BY MR. KUVIN: 23 Q. Do you agree that you described for the 24 girl as shown in Exhibit 13 — by the way, her name 25 is B.B. — that you described to B.B. how to set up¶

1 the massage table in Jeffrey Epstein's bathroom?
2 MR. RHEINHART: Objection to the form for
3 the reasons previously stated, and instruct the
4 witness not to answer.
5 THE WITNESS: On the advice of counsel, I
6 must choose to exercise my Fifth Amendment
7 right.
8 BY MR. KUVIN:
9 Q. Do you agree that you showed B.B. where
10 the massage oils are kept in Jeffrey Epstein's
11 bathroom in his home?
12 MR. RHEINHART: Objection to the form in
13 that it assumes knowledge of Jeffrey Epstein,
14 knowledge that this person was ever at
15 Jeffrey Epstein's home none of which is
16 admitted or acknowledged by this witness, and
17 instruct the witness not to answer.
18 THE WITNESS: On advice of counsel I must
19 choose to invoke my Fifth Amendment right.
20 BY MR. KUVIN:
21 Q. Do you agree that you showed B.B., as
22 shown in Exhibit 13, where Mr. Epstein kept the
23 vibrators in his bathroom at his house?
24 MR. RHEINHART: Same objection as stated
25 to the previous question as to the form of the¶

1 question, and instruct the witness not to
2 answer.
3 THE WITNESS: On advice of counsel, I must
4 choose to exercise my Fifth Amendment right.
5 BY MR. KUVIN:
6 Q. Do you agree with me that in 2005 you
7 knowingly provided B.B., a 15-year-old girl, to
8 Mr. Epstein so that he could sexually abuse her?
9 MR. RHEINHART: Objection to the form as
10 to it calling for a legal conclusion as to
11 assuming multiple facts, since therefore
12 compound and instruct the witness not to
13 answer.
14 THE WITNESS: On advice of counsel, I must
15 choose to invoke my Fifth Amendment right.
16 BY MR. KUVIN:
17 Q. Do you agree with me that B.B. was given
18 to Mr. Epstein to perform a naked massage of him
19 while he touched B.B.?
20 MR. RHEINHART: Objection to the form.
21 Standing objection and other facts that are
22 assumed in the question to which this witness
23 does not admit, and therefore the witness is
24 instructed not to answer the question.
25 THE WITNESS: On the instruction of my¶

1 counsel, I must choose to invoke my Fifth
2 Amendment right.
3 BY MR. KUVIN:
4 Q. Do you agree with me that during the
5 massage that B.B. was forced to give to Mr. Epstein,
6 that he touched her between her legs?
7 MR. RHEINHART: Objection to the form. It
8 is ambiguous including the term "forced." It
9 assumes facts that this witness has not
10 admitted or that this witness has not
11 acknowledged any personal knowledge and
12 instruct her not to answer.
13 THE WITNESS: On the instruction of my
14 lawyer, I must therefore invoke my Fifth
15 Amendment right.
16 BY MR. KUVIN:
17 Q. Do you agree with me that Mr. Epstein
18 touched B.B. between her legs?
19 MR. RHEINHART: Objection to the form and
20 the question presumes knowledge of
21 Jeffrey Epstein. Instruct the witness not to
22 answer.
23 THE WITNESS: On the instruction of my
24 lawyer, I must choose to invoke my Fifth
25 Amendment right.¶

1 BY MR. KUVIN:
2 Q. Do you agree with me that B.B. told
3 Mr. Epstein to stop touching him there -- touching
4 her there?
5 MR. RHEINHART: Same objection previously
6 stated to the last question and instruct the
7 witness not to answer.
8 THE WITNESS: On the instruction of my
9 lawyer, I must invoke my Fifth Amendment right.
10 BY MR. KUVIN:
11 Q. Do you agree with me that you have
12 personal knowledge that after telling Mr. Epstein to
13 stop touching her between her legs, Mr. Epstein
14 apologized and then touched her again between her
15 legs?
16 MR. RHEINHART: Objection to the form and
17 the standing objection previously stated as
18 well as the question is compound and instruct,
19 and ambiguous, and I instruct the witness not
20 to answer.
21 THE WITNESS: On the instruction of my
22 lawyer, I must choose to exercise my Fifth
23 Amendment right.
24 BY MR. KUVIN:
25 Q. Do you agree with me that Mr. Epstein¶

1 specifically targeted young underage girls that were
2 economically disadvantaged for his own sexual
3 pleasure?
4 MR. RHEINHART: Objection to the form.
5 Several of the terms are ambiguous and it
6 assumes knowledge of Mr. Epstein and his
7 habits, and therefore, I instruct the witness
8 not to answer the question.
9 THE WITNESS: On the instruction of my
10 lawyer, I must choose to exercise my Fifth
11 Amendment right.
12 BY MR. KUVIN:
13 Q. Do you agree with me that Mr. Epstein
14 would pay these girls 2 to $300 for this sexual
15 massage?
16 MR. RHEINHART: Objection to the form.
17 Standing objection and assumes knowledge of
18 Mr. Epstein and his practices, so therefore, I
19 instruct the witness not to answer.
20 THE WITNESS: On the instruction of my
21 lawyer, I must choose to invoke my Fifth
22 Amendment right.
23 BY MR. KUVIN:
24 Q. Do you agree with me that you handed B.B.
25 $200?¶

1 MR. RHEINHART: Objection to the form,
2 instruct the witness not to answer.
3 THE WITNESS: On the instruction of my
4 lawyer, I must choose to invoke my Fifth
5 Amendment right.
6 BY MR. KUVIN:
7 Q. And just so we're clear, do you agree with
8 me that you handed B.B. in 2005, $200 after she was
9 in the bathroom with Mr. Epstein at his home?
10 MR. RHEINHART: Objection to the form.
11 The question presumes knowledge of a person by
12 the name of B.B., therefore I instruct the
13 witness not to answer the question.
14 THE WITNESS: On the instruction of my
15 lawyer, I must choose to invoke my Fifth
16 Amendment right.
17 BY MR. KUVIN:
18 Q. Do you agree with me that Mr. Epstein had
19 a plan -- let me rephrase that.
20 Do you agree with me that Mr. Epstein
21 had an enterprise, a sexual enterprise, established
22 by which young girls would be brought to his home,
23 introduced to you, where you would then set up a
24 massage table, show them where the oils were, and
25 have these young girls under the age of 18, give¶

1 Mr. Epstein naked massages?
2 MR. RHEINHART: Object to the form. It's
3 multiple layers of compound questioning,
4 includes terms like "enterprise" that are
5 ambiguous and may call for a legal conclusion
6 that this witness is not competent to give. I
7 instruct the witness not to answer.
8 THE WITNESS: On the instruction of my
9 lawyer, I must choose to exercise my Fifth
10 Amendment right.
11 BY MR. KUVIN:
12 Q. Do you agree with me that there is a
13 staircase leading out of Mr. Epstein's kitchen in
14 his home on Palm Beach?
15 MR. RHEINHART: Objection to the form,
16 presumes knowledge of Mr. Epstein or his home
17 on Palm Beach. Instruct the witness not to
18 answer.
19 THE WITNESS: On the instruction of my
20 lawyer, I must choose to invoke my Fifth
21 Amendment right.
22 BY MR. KUVIN:
23 Q. Do you agree with me that when B.B. was
24 brought to Mr. Epstein's bathroom, that he walked
25 out of the shower wearing a towel?¶

1 MR. RHEINHART: Objection to the form in
2 that it presumes knowledge of [REDACTED]
3 B.B. was ever at Mr. Epstein's home, that this
4 witness knows anything about Mr. Epstein or his
5 home; therefore, the question is compound and
6 ambiguous, and I instruct her not to answer.
7 THE WITNESS: On the instruction of my
8 lawyer, I must choose to assert my Fifth
9 Amendment right.
10 BY MR. KUVIN:
11 Q. Do you know C.L.?
12 A. On the instruction of my lawyer, I must choose
13 to assert my Fifth Amendment privilege.
14 Q. Did you have C.L. -- excuse me, strike
15 that. Did you tell C.L. to come over to
16 Mr. Epstein's home to give Mr. Epstein a massage?
17 MR. RHEINHART: Objection to the form.
18 It's compound. Stand objection, standing
19 objection, sorry. Instruct the witness not to
20 answer.
21 THE WITNESS: On the instruction of my
22 lawyer, I must choose to invoke my Fifth
23 Amendment right.
24 BY MR. KUVIN:
25 Q. Did you introduce C.L. to Jeffrey Epstein?¶

1 MR. RHEINHART: Objection to the form, 1 BY MR. KUVIN: 2 standing objection. Instruct the witness not 2 Q. Would you agree with see that you visited 4 THE WITNESS: On the instruction from my 4 jail in Palm Beach County? 5 lawyer, I must choose to invoke my Fifth 5 MR. RHEINHART: Objection to the form, 6 Amendment right. 6 standing objection. Assumes other facts that 7 BY MR. KUVIN: 7 this witness has not acknowledged, and instruct 8 Q. Do you agree with me that Mr. Epstein 8 her not to answer. 9 threatened C.L. with physical violence? 9 THE WITNESS: Upon instruction from the 10 MR. RHEINHART: Objection to the form, the 10 lawyer, I must choose to invoke my Fifth 11 standing objection, as well as ambiguous as to 11 Amendment right. 12 the term "threaten." Instruct the witness not 12 BY MR. KUVIN: 13 to answer. 13 Q. Do you agree that you arranged to have 14 THE WITNESS: Upon instruction from my 14 C.L. come to Jeffrey Epstein's home for a nude 15 lawyer, I must choose to invoke my Fifth 15 massage? 16 Amendment right 16 MR. RHEINHART: Objection to the form, 17 BY MR. KUVIN: 17 standing objection previously stated. 18 Q. Do you agree with me that Jeffrey Epstein 18 THE WITNESS: On the instruction of my 19 told C.L. that if she talks to anyone about what had 19 lawyer, I must choose to invoke my Fifth 20 occurred at his home, bad things would happen to 20 Amendment right. 21 her? 21 BY MR. KUVIN: 22 MR. RHEINHART: Objection to the form, 22 Q. Do you agree that C.L. has been to 23 it's compound, and a standing objection. Also 23 358 El Brillo Way on at least two orrasions? 24 assumes numerous other facts that this witness 24 MR. RHEINHART: Objection to the form. It 25 has not acknowledge nor admitted, and therefore 25 assumes knowledge of C.L. and of 358 El Brillo¶

3 to answer. 3 a man by the name of Jeffrey Epstein while he was in¶

1 I instruct her not to answer. 1 Way, to which the witness has not acknowledged, 9 MR. RHEINHART: Objection to the form. 9 MR. RHEINHART: Objection to the form of 19 MR. RHEINHART: Objection to the form as 19 MR. RHEINHART: Objection to the form, and¶

2 THE WITNESS: On the instruction from my 2 and instruct the witness not to answer. 3 lawyer, I must choose to invoke my Fifth 3 THE WITNESS: On the instruction of my 4 Amendment privilege. 4 lawyer, I must choose to invoke my Fifth 5 BY MR. KUVIN: 5 Amendment right. 6 Q. Would you agree with me that in 2005 that 6 BY MR. KUVIN: 7 Jeffrey Epstein was between the ages of 45 and 55 7 Q. Do you agree that Mr. Epstein has an 8 years old? 8 odd-shaped penis? 10 Standing objection as to any knowledge of 10 the question. It assumes knowledge of 11 Jeffrey Epstein. Instruct the witness not to 11 Mr. Epstein. It assumes knowledge of 12 answer. 12 Mr. Epstein's body parts, and instruct the 13 THE WITNESS: The instruction of my 13 witness not to answer. 14 lawyer, I must choose to assert my Fifth 14 THE WITNESS: On advice — on the 15 Amendment right. 15 instruction of my lawyer, I must choose to 16 BY MR. KUVIN: 16 invoke my Fifth Amendment right. 17 Q. Would you agree with me that 17 BY MR. KUVIN: 18 Jeffrey Epstein has tremendous wealth? 18 Q. Have you seen Jeffrey Epstein's penis? 20 stated in the previous question, and instruct 20 we're getting awfully close to a line here, Mr. 21 the witness not to answer. 21 Kuvin. 22 THE WITNESS: On the instruction from the 22 MR. KUVIN: I think the identity of 23 lawyer, I must choose to invoke my Fifth 23 something that young 14 and 15-year-old girls 24 Amendment right. 24 have seen is directly relevant to the issues in 25 25 this case. If they can describe it, then¶

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 obviously it's important because they are the 2 only ones that are answering questions in this 3 case. 4 MR. RHEINHART: Well, people have rights. 5 People will assert their rights, and I am just 6 telling you, we're getting close to a line 7 here. 8 MR. KUVIN: I think I'm being respectful — MR. RHEINHART: You haven't crossed it yet because I'm still here, but I'm just warning you. Instruct the witness not to answer any question that presumes existence or any knowledge of Jeffrey Epstein or any of his body parts. MR. KUVIN: Okay. THE WITNESS: On the instruction of my lawyer, I must choose to assert my Fifth Amendment right. BY MR. KUVIN: Q. Do you know whether or not Mr. Epstein has any identifying characteristics to any of his private genitalia? MR. RHEINHART: Objection to the form for¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. KUVIN: The Epstein matter. MR. RHEINHART: I instruct the witness not to answer. Objection to the form as compound and assumes the existence of Mr. Epstein which, again, we are not acknowledging, and therefore am instructing her not to answer. THE WITNESS: On the instruction of my lawyer, I choose to assert my Fifth Amendment right. BY MR. KUVIN: Q. Are you aware that Mr. Epstein negotiated for your immunity from prosecution in the non-prosecution agreement that was entered into with the United States Attorney's Office for the Southern District of Florida? MR. RHEINHART: Again, objection to the form for the reasons previously stated as to the standing objection and instruct her not to answer. THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree with me that B.B. was emotionally traumatized as a result of the incidents¶

1 the reason previously stated, because it 2 presumes that she has any knowledge of who 3 Jeffrey Epstein is or what his body parts look like, and I would instruct her not to answer. 5 THE WITNESS: On the instruction of my 6 lawyer, I must choose to assert my Fifth 7 Amendment right. 8 BY MR. KUVIN: 9 Q. Have you heard anyone other than your 10 lawyers that have described what any of 11 Mr. Epstein's body parts look like? 12 MR. RHEINHART: Objection to the form. It 13 is irrelevant what she's heard from other 14 people, and again, it presumes facts that she's 15 not acknowledged. It is compound, and it is 16 harassing at this point. 17 THE WITNESS: On instruction of my lawyer, 18 I must choose to invoke my Fifth Amendment 19 right. 20 BY MR. KUVIN: 21 Q. Were you consulted with respect to the 22 non-prosecution agreement that was entered into with 23 the United States Attorney's Office for the Southern 24 District of Florida as it relates to this case? 25 MR. RHEINHART: Which case?¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that occurred Jeffrey Epstein's home in 2005? MR. RHEINHART: Objection to the form. It assumes any knowledge of B.B. or any incidents that would have occurred at a home purporting to belong to a person by the name of Jeffrey Epstein, and instruct her not to answer. THE WITNESS: Upon instruction from my lawyer, I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Do you agree with me that C.L. was emotionally traumatized as a result of the incidents that occurred at Jeffrey Epstein's home? MR. RHEINHART: Same objection as to the previous question, and instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Do you know Jane Doe No. 102? MR. RHEINHART: Instruct the witness not to answer based on Fifth Amendment privilege. THE WITNESS: On instruction of my lawyer, I must choose to invoke my Fifth Amendment¶

1 right. 2 BY MR. KUVIN: 3 Q. Have you known Jeffrey Epstein to keep 4 underage, under the age of 18, sex slaves? 5 MR. RHEINHART: Objection to the form both 6 as to ambiguity as to what you mean by "sex 7 slaves," and "keep," also the standing 8 objection as to any knowledge of Mr. Epstein 9 and instruct the witness not to answer. 10 THE WITNESS: On the instruction of my 11 lawyer, I must choose to invoke my Fifth 12 Amendment right. 13 BY MR. KUVIN: 14 Q. Where do most of the models come from that 15 are part of MC Squared Modeling Agency? 16 MR. RHEINHART: Objection to the form. It 17 assumes knowledge of an entity by the name of 18 MC Squared Modeling which the witness has not 19 acknowledged and therefore I instruct her not 20 to answer, and the question is compound. 21 THE WITNESS: On the instruction of my 22 lawyer, I must choose to invoke my Fifth 23 Amendment privilege. 24 BY MR. KUVIN: 25 Q. Who gets visas for the models at MC¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in New York? MR. RHEINHART: Instruct the witness not to answer based on the Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Are you aware that various underage girls brought in from out of the country live at 301 East 66th Street? MR. RHEINHART: Objection to the form. It's compound, and instruct the witness not to answer. THE WITNESS: On the instruction from my lawyer, I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. You've stayed at that address before, have you not? MR. RHEINHART: Instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth Amendment right.¶

1 Squared, if you know? 2 MR. RHEINHART: Same, same objection as to 3 the previous question, same instruction. 4 THE WITNESS: On the instruction of my 5 lawyer, I must choose to invoke my Fifth 6 Amendment right. 7 BY MR. KUVIN: 8 Q. Do you work with Jeffrey Epstein to get 9 visas for out-of-the-country models or models that 10 are strike that. 11 Do you work with Jeffrey Epstein to 12 get visas for girls that are underage and bring them 13 into the United States so that they can work as 14 models for MC Squared? 15 MR. RHEINHART: Objection to the form and 16 assumes knowledge as to Mr. Epstein and as to 17 MC Squared and other matters that are not 18 admitted or acknowledged by this witness. The 19 question is compound. I would instruct her not 20 to answer. 21 THE WITNESS: On the instruction from my 22 lawyer, I must choose to invoke my Fifth 23 Amendment right. 24 BY MR. KUVIN: 25 Q. Do you know who owns 301 East 66th Street¶

1 BY MR. KUVIN: 2 Q. You've stayed there hundreds of times, 3 have you, hundreds of times have you not? 4 MR. RHEINHART: Instruct the witness not 5 to answer. 6 THE WITNESS: On instruction from my 7 lawyer, I must choose to invoke my Fifth 8 Amendment right. 9 BY MR. KUVIN: 10 Q. Are you aware that Mr. Epstein obtains 11 visas for girls from out of the country to work as 12 models and then prostitutes them out? 13 MR. RHEINHART: Objection to the form of 14 the question in that it is ambiguous and it 15 assumes numerous facts that have not 16 acknowledged that this witness has any 17 knowledge of, and the term "prostitutes them 18 out" is ambiguous, so I would instruct her not 19 to answer the question. 20 THE WITNESS: On the instruction of my 21 lawyer, I must choose to invoke my Fifth 22 Amendment right. 23 BY MR. KUVIN: 24 Q. You know what Radar Online is, do you not? 25 MR. RHEINHART: Instruct the witness not¶

1 to answer the question based on her Fifth 1 THE WITNESS: On the instruction from my 2 Amendment privilege. 2 lawyer, I choose to invoke my Fifth Amendment 3 THE WITNESS: On the instruction of my 3 right. 4 lawyer, I must choose to invoke my Fifth 4 BY MR. KUVIN: 5 Amendment right. 5 Q. Would you agree with me that Jeffrey 6 BY MR. KUVIN: 6 Epstein has a list of underage girls that live 7 Q. In fact, you were around when 7 within a close proximity to all of his different 8 Jeffrey Epstein bought Radar Online, were you not? 8 homes in every different state? 9 MR. RHEINHART: Objection to the form, 9 MR. RHEINHART: Objection to the form in 10 standing objection as to any knowledge of 10 that it assumes Mr. Epstein has homes in every 11 Jeffrey Epstein or of Radar Online, and 11 single state and that she knows who Mr. Epstein 12 instruct the witness not to answer. 12 is, and therefore I instruct her not to answer. 13 THE WITNESS: On the instruction from my 13 THE WITNESS: On advice of my lawyer, I 14 lawyer, I must choose to invoke my Fifth 14 must choose to invoke my Fifth Amendment right. 15 Amendment right. 15 BY MR. KUVIN: 16 BY MR. KUVIN: 16 Q. You're aware Mr. Epstein has a home in New 17 Q. Are you aware that Jeffrey Epstein 17 York, right? 18 accessed or obtained underage girls through his 18 MR. RHEINHART: Instruct the witness not 19 Radar connection? 19 to answer, and standing objection of knowledge 20 MR. RHEINHART: Same objection as 20 of Mr. Epstein. 21 previously stated to the last question and same 21 THE WITNESS: On the instruction of my 22 instruction. 22 lawyer, I must invoke my Fifth Amendment right. 23 THE WITNESS: On the instruction from my 23 BY MR. KUVIN: 24 lawyer, I must choose to invoke my Fifth 24 Q. Are you aware that he has a home in New 25 Amendment privilege. 25 Mexico?¶

Page 170 Page 172¶

1 BY MR. KUVIN: 1 MR. RHEINHART: By he, you mean 2 Q. How many different properties does 2 Mr. Epstein? 3 Jeffrey Epstein own? 3 MR. KUVIN: Yeah. 4 MR. RHEINHART: Objection to the form, 4 MR. RHEINHART: Got to make sure the 5 standing objection. Instruct the witness not 5 question is clear. 6 to answer. 6 MR. KUVIN: Yes. 8 lawyer, I must choose to invoke my Fifth 8 form and instruct the witness not to answer. 9 Amendment right. 9 THE WITNESS: On the instruction from my 10 BY MR. KUVIN: 10 lawyer, I must choose to invoke my Fifth 11 Q. You've been to all of Jeffrey Epstein's 11 Amendment privilege. 12 home, have you not? 12 BY MR. KUVIN: 13 MR. RHEINHART: Same objection as 13 Q. Are you aware he has a home in the U.S. 14 previously stated to the last question. Same 14 Virgin Islands? 15 instruction. 15 MR. RHEINHART: Same instruction. same 16 THE WITNESS: On the instruction from my 16 objection. 17 lawyer, I must invoke my Fifth Amendment right. 17 THE WITNESS: On the instruction of my 18 BY MR. KUVIN: 18 lawyer, I must choose to invoke my Fifth 19 Q. You agree with me that Jeffrey Epstein 19 Amendment right. 20 keeps a list of girls in the nearby areas around all 20 BY MR. KUVIN: 21 of his homes and properties? 21 Q. And isn't it true that you kept a list of 22 MR. RHEINHART: Objection to the form, for 22 underage girls that could service, in other words, 23 the standing objection as well as ambiguous as 23 give Mr. Epstein naked massages in every place that 24 to "nearby," and "all of his properties," so I 24 he has one of those homes I just described? 25 instruct the witness not to answer. 25 MR. RHEINHART: Same objection as¶

7 THE WITNESS: On the instruction of my 7 MR. RHEINHART: Standing objection to the¶

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 lawyer, I choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. And there was a complete list of girls, underage girls, that was stored on Mr. Epstein's computer system; isn't that true? MR. RHEINHART: Objection to the form. Ifs ambiguous as to what a complete list is, and also a standing objection to any knowledge of Mr. Epstein, and instruct the witness not to answer. THE WITNESS: On the instruction from my lawyer, I must choose to invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. In fact, you've seen the list of underage girls that exists on Mr. Epstein's computer, have you not? MR. RHEINHART: Objection to the form, standing objection. THE WITNESS: On the instruction from my lawyer, I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. When underage minor females were brought¶

1 previously stated, the standing objection and 2 instruct her not to answer. 3 THE WITNESS: On the instruction of my 4 lawyer, I must choose to invoke my Fifth 5 Amendment right. 6 BY MR. KUVIN: 7 Q. Now, you're also aware, are you not, that 8 Jeffrey Epstein would pay other girls to bring 9 additional underage girls to him for naked massages, 10 are you not? 11 MR. RHEINHART: Standing objection and 12 instruct the witness not to answer. 13 THE WITNESS: On the instruction from my 14 lawyer, I must choose to invoke my Fifth 15 Amendment privilege. 16 BY MR. KUVIN: 17 Q. And, in fact, you frequently would pay 18 other girls to bring additional girls under the age 19 of 18 to Mr. Epstein for naked massages? 20 MR. RHEINHART: Objection to the form, 21 standing objection as to Mr. Epstein, also as 22 to any knowledge of any naked massages by 23 anybody to anybody. Instruct the witness not 24 to answer. 25 THE WITNESS: On the instruction of my¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to Mr. Epstein's house on Palm Beach, you were aware that they were brought so that Mr. Epstein could molest them, correct? MR. RHEINHART: Objection to the form as to knowledge of Mr. Epstein, as to knowledge of any home on Palm Beach, and ambiguous as to the term "molest," and instruct the witness not to answer. THE WITNESS: On the instruction from my lawyer, I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. You're aware that Mr. Epstein raped several underage minors in his bedroom? MR. RHEINHART: Objection to the form as to knowledge of Mr. Epstein, and also ambiguous as to the term "rapt" THE WITNESS: On the instruction of my lawyer, l must choose to invoke my Fifth Amendment rights. BY MR. KUVIN: Q. Do you know what the term "rape" means? MR. RHEINHART: Not as you used it. If you want to tell us what you mean by when you used it, we'll be happy to answer¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. KUVIN: I want to know if — MR. RHEINHART: — or evaluate your question. MR. KUVIN: I want to know if she has her own definition of what the phrase or word "rape" means, so that we can use her definition of that word. I want to make sure it's completely unambiguous. MR. RHEINHART: Your asking the question. If you want to define the term, she'll respond to your question. BY MR. KUVIN: Q. Do you what the term or word "rape" means? A. Yes. Q. Okay. What is your understanding of that word? MR. RHEINHART: Now, we're not answering that question. It's your term. It's your question. If you want to define it, you can go ahead and define it. MR. KUVIN: Well, I beg — MR. RHEINHART: If you want to give her specifics as to what she — you can define it. MR. KUVIN: I beg to differ with you, and I don't know that that's a proper objection.¶

OH* l•••••••¶

1 I'm asking her her understanding of the word.
2 MR. RHEINHART: And I am instructing her
3 not to answer it because that question is not
4 likely to lead to discoverable evidence. It's
5 simply meant to harass her. And you can define
6 the term in your question.
7 MR. KUVIN: Well, with all due respect,
8 it's certainly not to harass if there have been
9 girls that were alleging that they were raped.
10 MR. RHEINHART: Well, you define what you
11 mean by when you say that they allege that they
12 have been raped, and she will be happy to
13 evaluate your question.
14 MR. KUVIN: And that's what I'm trying to
15 understand.
16 MR. RHEINHART: She's not going to
17 speculate on what you mean when you frame a
18 word in your question.
19 MR. KUVIN: That's exactly what I'm trying
20 to do. I'm trying to make sure that we are
21 using the same definition, so I would like to
22 use her definition of the word.
23 MR. RHEINHART: Right. She's not going to
24 answer it, so you can either move on we can
25 stop.¶

1 MR. KUVIN: Okay. So you're instructing
2 her not to answer the question?
3 MR. RHEINHART: I am instructing her not
4 to answer the question for the third time.
5 MR. KUVIN: Okay. I just want to be
6 clear.
7 MR. [REDACTED]: What's the legal objection?
8 MR. RHEINHART: I've already stated what
9 my legal objection is. It's meant solely for
10 harassment. It's not likely to lead to
11 discoverable evidence.
12 BY MR. KUVIN:
13 Q. Okay. For the purpose of my question, I
14 would like to, because your attorney won't allow you
15 to define the word "rape," I would like you to use
16 the word and understand the word "rape" to mean
17 sexual contact with an individual, including
18 sexual -- well, let me clarify here. Hang on. You
19 know what, if we're going to do it, let's do it
20 right since we can't use your definition.
21 MR. RHEINHART: You can use whatever
22 definition you like, but you need to tell me
23 what it is.
24 MR. KUVIN: Let's use the definition of
25 "rape" as defined by Florida law as oral, anal¶

1 or vaginal penetration or union with the sexual
2 organ of another, or oral, anal or vaginal
3 penetration of another with any other object,
4 or with any object. Excuse me. All right?
5 MR. RHEINHART: Okay.
6 BY MR. KUVIN:
7 Q. Do you understand that definition as I
8 have explained it to you, or would you like me to
9 read it again?
10 A. Read it again, please.
11 Q. Absolutely. Florida law defines "rape" as
12 oral, anal or vaginal penetration by, or union with
13 the sexual organ of another; or oral, anal or
14 vaginal penetration by another with any object. And
15 obviously that is without the other's consent.
16 A. You did not say that.
17 MR. RHEINHART: Okay.
18 BY MR. KUVIN:
19 Q. Adding without the other's consent,
20 obviously, to that definition.
21 Now, let's use that definition for
22 "rape," because that's as it's defined by Florida
23 law. Using that definition, are you aware, as you
24 sit here today, that Jeffrey Epstein has raped
25 underage girls?¶

1 MR. RHEINHART: Standing objection to the
2 form of the question, and I would instruct the
3 witness not to answer.
4 THE WITNESS: On the instruction of my
5 lawyer, I must choose to invoke my Fifth
6 Amendment right.
7 BY MR. KUVIN:
8 Q. Are you aware as you sit here today that
9 Jeffrey Epstein raped B.B.?
10 MR. RHEINHART: Objection to the form.
11 The question assumes that he did, or that she
12 has any knowledge of whether he did, so I
13 instruct the witness not to answer.
14 THE WITNESS: On the instruction of my
15 lawyer, I must choose to invoke my Fifth
16 Amendment privilege.
17 BY MR. KUVIN:
18 Q. Are you aware as you sit here today, that
19 Jeffrey Epstein -- well, let me rephrase that.
20 You are aware, are you not, as you
21 sit here today, that Jeffrey Epstein raped C.L.?
22 MR. RHEINHART: Objection to the form as
23 leading, and also again assumes -- your
24 question assumes that she knows things that
25 she's not acknowledged that she knows or¶

1 doesn't know, and I instruct her not to answer. 2 THE WITNESS: On the instruction of my 3 lawyer, I must choose to invoke my Fifth 4 Amendment right. 5 BY MR. KUVIN: 6 Q. Do you agree that Jeffrey Epstein has 7 raped hundreds of girls under the age of 18? 8 MR. RHEINHART: Objection to the form, 9 standing objection as to any knowledge of 10 Jeffrey Epstein. Instruct the witness not to 11 answer. 12 THE WITNESS: On the instruction of my 13 lawyer, I must choose to invoke my Fifth 14 Amendment privilege. 15 BY MR. KUVIN: 16 Q. You're aware, are you not, that 17 Jeffrey Epstein has raped hundreds of girls under 18 the age of 17? 19 MR. RHEINHART: Objection to the form as 20 leading. Instruct the witness not to answer 21 for the reasons previously stated to the last 22 the question. 23 THE WITNESS: On the instruction of my 24 lawyer,1 must choose to assert my Fifth Amendmet riglib¶

1 MR. RHEINHART: Same objection as 2 previously stated as to ambiguity and compound, 3 and instruct the witness not to answer. 4 THE WITNESS: On the instruction of my 5 lawyer, I must choose to invoke my Fifth 6 Amendment right 7 BY MR. KUVIN: 8 Q. Have you ever had sexual contact in any 9 manner with any underage girls that were brought to 10 Mr. Epstein's home? 11 MR. RHEINHART: Objection to the form. 12 Standing objection, compound, instruct the 13 witness not to answer. 14 THE WITNESS: On the instruction of my 15 lawyer, I must choose to invoke my Fifth 16 Amendment right. 17 BY MR. KUVIN: 18 Q. Did you keep an appointment book for 19 Mr. Epstein? 20 MR. RHEINHART: Objection to the form, 21 standing objection. Instruct the witness not 22 to answer. 23 THE WITNESS: On the instruction of my 24 lawyer, I must choose to invoke my Fifth 25 Amendment right.¶

1 BY MR. KUVIN: Q. You're aware, as you sit here today, are you not, that Jeffrey Epstein has raped hundreds of girls under the age of 16? MR. RHEINHART: Objection to the form. 6 Standing objection. It assumes numerous facts 7 mixed in a compound question, and therefore I 8 instruct the witness not to answer. 9 THE WITNESS: On the instruction of my 10 lawyer, l must choose to assert my Fifth 11 Amendment right. 12 BY MR. KUVIN: 13 Q. Isn't it true that Mr. Epstein had at 14 least one or two scheduled appointments for sex with 15 underage girls every day while he was here in Palm 16 Beach County in the year 2005? 17 MR. RHEINHART: Objection to the form. 18 It's compound, standing objection as well, and 19 instruct the witness not to answer. 20 THE WITNESS: On the instruction of my 21 lawyer, I must choose to invoke my Fifth 22 Amendment right. 23 BY MR. KUVIN: 24 Q. Did you actually locate underage girls in 25 Palm Beach for Jeffrey Epstein to rape?¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. KUVIN: Q. Did you preserve a document that shows the appointments kept for Mr. Epstein in the years 2004? MR. RHEINHART: Objection to the form, the standing objection, compound question and instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Same question with respect to any appointments kept for Mr. Epstein in 2005. MR. RHEINHART: Same objection previously stated to the previous question. THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Same with respect to any appointments kept for Mr. Epstein in 2006. MR. RHEINHART: Same objection as previously stated to the last two questions. THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth Amendment privilege.¶

1 BY MR. KUVIN: 2 Q. Have you provided any appointment books to 3 anyone with respect to appointments for Mr. Epstein? 4 MR. RHEINHART: Same standing objection as 5 to knowledge of Mr. Epstein. The question is 6 compound and instruct the witness not to 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 answer. THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would Ep -- Mr. Epstein pay the underage girls more money if they took off both their tops and their bottoms? MR. RHEINHART: Objection to the form, standing objection. Instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must choose to invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would Mr. Epstein pay the underage girls more if they would actually touch his penis? MR. RHEINHART: Same instruction, same objection.¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. RHEINHART: Yeah, whenever you get to a convenient point in your questioning, I think we can use a break. If you're in the middle of something, I don't want to stop you. MR. KUVIN: No, this is fine. We can take a quick break. Five minutes? MR. RHEINHART: Yes, thank you. THE VIDEOGRAPHER: We're now off the record. It is 2:08 p.m. (A brief recess was held.)¶

1 THE WITNESS: On the instruction of my 2 lawyer, I must choose to assert my Fifth 3 Amendment right. 4 BY MR. KUVIN: 5 Q. Would Mr. Epstein pay the underage girls 6 more if he would allow them to have sex with them? 7 MR. RHEINHART: Can you restate that 8 again? 9 MR. KUVIN: Yes. 10 BY MR. KUVIN: 11 Q. Would Mr. Epstein pay the underage girls 12 more money if they would allow him to have sex with 13 them? 14 MR. RHEINHART: Objection to the form, 15 standing objection. Instruct the witness not 16 to answer. 17 THE WITNESS: On the instruction of my 18 lawyer, I must invoke my Fifth Amendment right. 19 MR. KUVIN: Hang on one second. You can 20 stop at any time I'll sign it. 21 MR. RHEINHART: Mr. Kuvin, I don't know if 22 you're getting to a convenient breaking point 23 but 24 MR. KUVIN: Do you want to take a quick 25 one?¶