EXHIBIT 21¶
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶
CASE NO. 08-C1V-80119-MARRA¶
JANE DOE NO. 2, Plaintiff,¶
VOLUME I OF III¶
1 2¶
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AB¶
Plaintiff,¶
VOLUME I OF Ill¶
JEFFREY EPSTEIN, 7 JEFFREY EPSTEIN, Defendant. 8 Defendant.¶
9¶
Related cases: 10 08-80232, 08-08380, 08-80381, 08-80994 11 08-80993, 08-80811, 08-80893, 09-80469 12¶
Nit¶
ITION OF¶
09-80591, 09-80656, 09-80802, 09-81092 13¶
14¶
15 Wednesday, March 24, 2010 VI...1)51710N OF¶
16¶
10:37 - 6:51 p.m.¶
Wednesday, March 24, 2010 17¶
10:37 - 6:51 p.m. 18 250 Australian Avenue South¶
Suite 1500¶
250 Australian Avenue South 19 West Palm Beach, Florida 33401¶
Suite 1500 20 West Palm Beach, Florida 33401 21¶
Reported Cynthia Notary Public,¶
, RPR, FPR State of Florida 22¶
23¶
Cynthia Reporte lis¶
, RPR, FPR¶
Notary Public, State of Florida Prose Court Reporting Services¶
Prose Court Reporting Services 24 Job No.: 1484¶
Job No.: 1484 25¶
Page 2 Page 4¶
1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 1 IN THE CIRCUIT COURT OF 711E FIFTEENTH JUDICIAL¶
IN AND FOR PALM BEACH COUNTY, FLORIDA CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶
2 CASE NO. 502008CA028058XXXXMB AD 2 CASE No.502008CA0373 I9XXXXMB AB¶
3 3¶
4¶
E.W.,¶
4¶
B.B¶
5 Plaintiff, Plaintiff.¶
6 VOLUME I OF III 5¶
7 6 VOLUME I OF III¶
JEFFREY EPSTEIN, 7 JEFF 8 NMIS.¶
Defendant.¶
9 Defendants.¶
10 9 11 SITION OF 10¶
Wednesday, March 24, 2010 10:37 - 6:51 p.m.¶
250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401¶
\ft¶
SITION OF¶
Wednesday, March 24, 2010 10:37 - 6:51 p.m.¶
250 Australian Avenue South Suite 1500¶
West Palm Beach, Florida 33401 19 19¶
20 20 21 21¶
22 Reportecav, 22 Mp vy¶
Cynthia RPR, FPR Cynthia, RPR, FPR 23 Notary Public, State of Florida 23 Notary Public, State of Florida Prose Court Reporting Services Prose Court Reporting Services¶
24 Job No.: 1484 24 Job No.: 1484¶
25 25¶
1 APPEARANCES:
2 On behalf of the Plaintiffs, B.B.:
3 SPENCER T. KUVIN, ESQUIRE
4 LEOPOLD KUVIN
5 2925 PGA Boulevard
Suite 200
Palm Beach Gardens, Florida 33410
Phone: 561.515.1400¶
6 On behalf of the Plaintiffs, L.M., E.W. and
7 Jane Doe:¶
8 MATTHEW WEISSING, ESQUIRE
9 [REDACTED], JAFFE, WEISSING, [REDACTED]
10 FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue
11 Suite 2
Fort Lauderdale, Florida 33301
Phone: 954.524.2820
13 On behalf of Jane Does 1 through 8:
14 ADAM D. HOROWITZ, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
18205 Biscayne Boulevard
Suite 2218
16 Miami, Florida 33160
Phone: 305.931.2200
17 E-mail: Ahorowitz@sexabuseattorney.com
18 On behalf of the Plaintiffs, 101, 102 and 103:
19 KATHERINE W. EZELL, ESQUIRE
AMY JOSEFSBERG EDERI, ESQUIRE
20 PODHURST ORSECK
25 West Flagler Street
Suite 800
Miami, Florida 33130
Phone: 305.358.2800
(Via telephone)¶
1 INDEX
2 ---
3 EXAMINATION DIRECT CROSS REDIRECT
4 [REDACTED]
5 [REDACTED]
6 [REDACTED]
7 BY MR. KUVIN 9¶
8 EXHIBIT DESCRIPTION PAGE
9 PLAINTIFFS EX. 1 PHOTO 16
10 PLAINTIFFS EX. 2 JEGE, INC., 24
11 PASSENGER MANIFEST
12 PLAINTIFFS EX. 3 HYPERION AIR, INC.,
13 PASSENGER MANIFEST
14 PLAINTIFFS EX. 6 PHOTO 63
15 PLAINTIFFS EX. 7 PHOTO 65
16 PLAINTIFFS EX. 8 PHOTO 68
17 PLAINTIFFS EX. 9 PHOTO 71
18 PLAINTIFFS EX. 10 PHOTO 100
19 PLAINTIFFS EX. 11 PHOTO 101
20 PLAINTIFFS EX. 12 PHOTO 103
21 PLAINTIFFS EX. 4 PHONE MESSAGE PADS
22 PLAINTIFFS EX. 5 CELLPHONE RECORDS
23 PLAINTIFFS EX. 13 PHOTO 144
24 [REDACTED]
25 [REDACTED]¶
1 Appearances continued...
2 On behalf of the Plaintiff, Jane Doe II:
3 ISIDRO MANUEL, [REDACTED], ESQUIRE
4 [REDACTED], ELKINS & BOEHRINGER
224 Datura Avenue, Suite 900
West Palm Beach, Florida 33401
Phone: 561.832.8033
5 [REDACTED]
6 [REDACTED]
7 On behalf of the Defendant:
8 JACK ALAN GOLDBERGER, ESQUIRE
ATTERBURY, GOLDBERGER & WEISS, P.A.
9 250 Australian Avenue South
Suite 1400
West Palm Beach, Florida 33401-5012
Phone: 561.659.8300
11 [REDACTED]
12 [REDACTED]
13 On behalf of the Witness:
14 BRUCE E. REINHART, ESQUIRE
LAW OFFICE OF BRUCE E. REINHART
One Clearlake Center
15 250 South Australian Avenue, Suite 1400
West Palm Beach, Florida 33401
Phone: 561.202.6360
17 [REDACTED]
18 [REDACTED]
19 [REDACTED]
20 ALSO PRESENT:
21 Jessica Cadwell, Paralegal
Burman, Critton, Luttier & Coleman, P.A.
22 [REDACTED] Kozak, Videographer
Prose Court Reporting Services¶
1 PROCEEDINGS
2 THE VIDEOGRAPHER: We are now on video
3 record. This is Media No. 1 in the videotaped
4 deposition of [REDACTED] in the matter of
5 Jane Doe versus Jeffrey Epstein, et al. Today
6 is Wednesday, March 24th, 2010. It is
7 10:36 a.m. We are here at Prose Court
8 Reporting, 250 South Australian Avenue, West
9 Palm Beach, Florida.
10 My name is Joe Kozak. I'm the
11 videographer. The reporter is Cindy
12 [REDACTED] from Prose Court Reporting Agency.
13 Would counsel please introduce
14 yourselves, and then the court reporter
15 will swear in the witness.
16 MR. KUVIN: Good morning. Spencer Kuvin
17 on behalf of one of the Plaintiffs.
18 MR. HOROWITZ: Adam Horowitz on behalf of
19 Jane Does 2 through 8. And just for the record
20 purposes, the deposition is also being taken in
21 the federal cases, I believe, case being
22 Jane Doe 2 versus Jeffrey Epstein.
23 MR. WEISSING: Matt Weissing on behalf of
24 three of the Plaintiffs.
25 [REDACTED]¶
1 BY MR. KUVIN: 2 Q. Have you ever used the alias of 3 Sarah Bonk? 4 MR. RHEINHART: Objection to the -- I'm 5 sorry. Instruct the witness not to answer 6 based on Fifth Amendment privileges. 7 THE WITNESS: Upon the instruction of my 8 lawyer, I must invoke my Fifth Amendment right 9 BY MR. KUVIN: 10 Q. Do your parents live in North Carolina? 11 MR. RHEINHART: Instruct the witness not 12 to answer the question based on her Fifth 13 Amendment privilege. 14 THE WITNESS: On instruction of my lawyer 15 I must invoke my Fifth Amendment right. 16 BY MR. KUVIN: 17 Q. Do you have any brothers and sisters? 18 MR. RHEINHART: Same instruction as the 19 previous question. 20 THE WITNESS: On the instruction of my 21 lawyer, I must invoke my Fifth Amendment right 22 BY MR. KUVIN: 23 Q. Have your parents met Jeffrey Epstein? 24 MR. RHEINHART: Objection to the form. 25 Standing objection and also instruct the¶
1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 compound. instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment righ BY MR. KUVIN: . Have ou ver used illegal drugs with 9 MR. RHEINHART: Same objection and instruction as to the previous question. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment righ BY MR. KUVIN: Q. Did you ever use the phone number of 655-0995? MR. RHEINHART: Instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment righ BY MR. KUVIN: Q. Have you ever used the phone number 881-81 I6, 881-8116. MR. RHEINHART: Thank you. THE WITNESS: I don't recognize that number.¶
Page 208¶
1 witness not to answer based on her Fifth 2 Amendment privilege. 3 THE WITNESS: On the instruction of my 4 lawyer. I must invoke my Fifth Amendment right 5 BY MR. KUVIN: 6 Q. Do your parents know what you've done with 7 Jeffrey Epstein as it relates to this case? 8 MR. RHEINHART: Objection to the form as 9 stated to the previous question, and same 10 instruction. 11 THE WITNESS: On the instruction of my 12 lawyer, I must invoke my Fifth Amendment right 13 BY MR. KUVIN: 14 Q. I lave you ever used illegal drugs with 15 Jeffrey Epstein? 16 MR. RHEINHART: Objection to the form. 17 Standing objection, instruct the witness not to 18 answer. 19 THE WITNESS: On the instruction of my 20 lawyer, I must invoke my Fifth Amendment right 21 BY MR. KUVIN: 22 Q. Have you ever used illegal drugs with 23 Ghislaine Maxwell? 24 MR. RHEINHART: Objection to the form, 25 assumes knowledge of Ghislaine Maxwell. It's¶
Page 21C¶
1 BY MR. KUVIN: 2 Q. Okay. When the police entered Jeffrey 3 Epstein's home, they took something that's called a 4 bottle of Peach Flavored Joy Jelly. Just a 5 foundation of what I'm about to ask you. 6 Have you ever seen anything called Peach 7 Flavored Joy Jelly ever anywhere, first of all? 8 Have you ever seen that before anywhere? 9 MR. RIIEINHART: Just so I am clear about 10 your question — 11 MR. KUVIN: Not necessarily in a home, 12 just anywhere in her entire life has she ever 13 seen a bottle of something called Peach 14 Flavored Joy Jelly. 15 THE WITNESS: No, I have not. 16 BY MR. KUVIN: 17 Q. Okay. Also taken from the home were, was 18 an adult sex toy called a Twin Torpedo which, 19 according to Detective Recarey during his depositio 20 was a double-headed dildo. Not with respect to 21 Mr. Epstein, but in your life, have you ever seen 22 something called a Twin Torpedo or double-headed 23 dildo? 24 A. No, I have not 25 Q. Also confiscated from the home was soap in¶
1 the shape of a penis and vagina. Once again, not 2 necessarily with respect to Mr. Epstein's home, in 3 your entire life have you ever seen soap in the 4 shape of a penis and vagina? 5 A. Not that I recall. 6 Q. Do you ever recall being in Ohio? 7 MR. RHEINHART: Ever in her life? 8 MR. KUVIN: The state, ever in her life. 9 BY MR. KUVIN: 10 Q. Let's start there, recall being in the 11 State of Ohio for any reason? 12 A. Maybe for a layover, but not that I 13 specifically remember. 14 Q. Okay. Do you know an Ivan Robles? 15 A. No. 16 Q. Have you seen a gentleman by the name o 17 Alan Dershowitz at the home of Jeffrey Epstein 18 before? 19 MR. RHEINHART: Objection to the form. 20 Standing objection. presumes knowledge of 21 Jeffrey Epstein or his home. Instruct the 22 witness not to answer. 23 THE WITNESS: On the instruction of my 24 lawyer, I must exercise my Fifth Amendment 2 5 right.¶
1 THE WITNESS: On the instruction of my 2 lawyer, I must invoke my Fifth Amendment right 3 BY MR. KUVIN: 4 Q. Do you agree that these corporations that 5 I just mentioned were utilized by Jeffrey Epstein in 6 an attempt to have sexual relationships with 7 underage girls? 8 MR. RIIEINHART: Objection to the form as 9 to compound, and also assumes knowledge of 10 Mr. Epstein. asks for more than one answer to 1: the question. I would instruct her not to 12 answer based on her Fifth Amendment privilege 13 because the question assumes knowledge of 14 Mr. Epstein. 15 THE WITNESS: Upon instruction of my 16 lawyer I must invoke my Fifth Amendment right. 17 MR. KUVIN: I think I am done. Hang on 18 one second. 19 All right. I appreciate it. That's all 20 the questions I have at this time. Reserve the 21 right to ask any follow-up questions if other 22 attorneys raise new and different issues by 23 their questioning. 24 MR. RHEINHART: Understood. 25 MR. KUVIN: Pass the witness at this time.¶
Page 212¶
BY MR. KUVIN: 2 Q. Have you ever heard of the El Zorro Ranch 3 Corporation? 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. Have you ever heard of the New York :2 Strategy Group? 13 MR. RHEINHART: Same instruction. 14 THE WITNESS: On the instruction of my 15 lawyer. I must invoke my Fifth Amendment right 16 BY MR. KUVIN: 17 Q. Have you ever heard of the Ghislaine 18 Corporation? 19 MR. RHEINHART: Same instruction. 20 THE WITNESS: On the instruction of my 21 lawyer, I must invoke my Fifth Amendment right 22 BY MR. KUVIN: 23 Q. Have you ever heard of the Financial 24 Strategy Group? 25 MR. RHEINHART: Same instruction.¶
Page 214¶
1 Who wants to go? Mr. Horowitz, do you have a 2 microphone? 3 MR. HOROWITZ: I do. 4 CROSS 5 BY MR. HOROWITZ: 6 Q. , did you use the telephone 7 number, the (917)855-3363 at any time between 2001 8 and 2006? 9 A. On the advice of my lawyer, I must exercise m 10 Fifth Amendment right. 11 Q. Did you use the telephone number 12 (917)855-3363 between 2001 and 2006 at Jeffrey 13 Epstein's expense? 14 MR. RHEINHART: Objection to the form in 15 that it assumes knowledge of Jeffrey Epstein. 16 Standing objection as previously stated with 17 Mr. Kuvin. Instruct the witness not to answer. 18 based on her Fifth Amendment right. 19 THE WITNESS: On the instruction of my 20 lawyer, I must exercise my Fifth Amendment 21 right. 22 BY MR. HOROWITZ: 23 Q. Did you use the telephone number 24 (917)855-3363 at Jeffrey Epstein's direction? 25 MR. RIIEINHART: Same objection as the¶
1 So can we focus on the specific questions 2 that she can answer or from which you can draw 3 an adverse inference if asked properly, and 4 let's move it along. 5 MS. EZELL: Each young woman's case is an 6 individual case, and we have the right to ask, 7 ask whatever questions that we need to with 8 regard to each one. 9 MR. RHEINHART: I-10 MR. GOLDBERGER: Let's just go forward 11 until 5:00 and see where we're at. 12 BY MR. WEISSING: 13 Q. Did you know that Jeffrey Epstein received 14 sexual gratification from directing others to 15 sexually abuse minor children? 16 MR. RHEINHART: Objection to the form. 17 THE WITNESS: On the instruction of my 18 lawyer, I must invoke the Fifth Amendment 19 right. 20 BY MR. WEISSING: 21 Q. Did you know that Jeffrey E stein received 22 sexual gratification from directing to 23 sexually abuse minor children? 24 MR. RHEINHART: Objection to the form. It 25 assumes knowledge of a person named¶
1 THE WITNESS: On the instruction of my 2 lawyer, I must invoke my Fifth Amendment 3 privilege. 4 BY MR. WEISSING: 5 Q. Do you know Alan Dershowitz? 6 MR. RHEINHART: The question was asked and 7 answered about three-and-a-half hours ago. 8 THE WITNESS: On the instruction of my 9 lawyer, I must invoke my Fifth Amendment 10 privilege. 11 BY MR. WEISSING: 12 Q. Do you know David Copperfield? 13 MR. RHEINHART: That question was asked 14 about three-and-a-half-hours ago. 15 TIIE WITNESS: On the instruction of my 16 lawyer, I must invoke my Fifth Amendment 17 privilege. 18 BY MR. WEISSING: 19 Q. In addition to his place at, in Palm 20 Beach, are you aware that Jeffrey Epstein has an 21 apartment located at 301 East 66th Street, Apartment 22 I4G through E in New York? 23 MR. RHEINHART: That question was asked 24 about four hours ago. It's been asked and 25 answered.¶
Page 316¶
1 It is otherwise compound and objectionable. 2 THE WITNESS: On the instruction of my 3 lawyer, I must invoke my Fifth Amendment right. 4 MR. WEISSING: Let's go off the record for 5 a moment. 6 THE VIDEOGRAPHER: Are we all good wit 7 going off the record? 8 MR. RHEINHART: Yeah, that's fine. 9 MR. HOROWITZ: Yes. 10 THE VIDEOGRAPHER: We're now off the 11 record at 4:22 p.m. 12 (A brief recess was held.) 13 THE VIDEOGRAPHER: We are now on the 14 record. It is 4:24 p.m. 15 BY MR. WEISSING: 16 Q. Do you know 17 MR. KUVIN: 18 TILE WITNESS: On the instruction of my 19 lawyer, I must invoke my Fifth Amendment 20 privilege. 21 BY MR. WEISSING: 22 Q. Do you know -- have you procured minor 23 children to have sexual relations with 24 at Jeffrey Epstein's mansion? 25 MR. RHEINHART: Objection to the form.¶
Page 318¶
1 THE WITNESS: At the instruction of my 2 lawyer, I invoke my Fifth Amendment privilege. 3 BY MR. WEISSING: 4 Q. While in New York, have you procured 5 underage minor children to engage in sexual acts 6 with Jeffrey Epstein at that location? 7 MR. RHEINHART: Object to the form. 8 THE WITNESS: On the instruction of my 9 lawyer, I must invoke my Fifth Amendment 10 privilege. 11 BY MR. WEISSING: 12 Q. With regard to the minor children procured 13 for him at that location, were they school children 14 in the New York area? 15 MR. RHEINHART: The previous question, 16 objection to the form. The same as all the 17 previous questions, it assumes a fact that's 18 not been established. It can't fairly be 19 answered. 20 THE WITNESS: On the instruction of my 21 lawyer, I must invoke my Fifth Amendment 22 privilege. 23 BY MR. WEISSING: 24 Q. Did Jeffrey Epstein have sexual encounters 25 with underage people while at that apartment?¶
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 BY MS. EZELL: 2 Q. Do you know whether Jeffrey Epstein attended 3 the Edge Science dinner in Monterey, California? 4 MR. REINHART: Objection to the form, lack of 5 foundation. Instruct the witness not to answer. 6 THE. WITNESS: At the instruction of my lawye-7 1 must invoke my Fifth Amendment right. 8 BY MS. EZELL: 9 Q. You testified a moment ago that you were photographed nude by your boyfriend or a former boyfriend and that you hoped there are no photographs disseminated elsewhere. At what age were those photographs taken? MR. REINHART: I'm going to instruct her not to answer that. It has nothing to do with anything. It's not reasonably calculated to lead to discoverable evidence. We can move on. BY MS. EZELL: Q. Were you in any way damaged by that experience? MR. REINHART: Same instruction. Let's move on. BY MS. EZELL: Q. Do you have any regrets? MR. REINHART: Same instruction. Move on.¶
know what the Edge Group was, but whatever, you car 2 answer the question. 3 THE WITNESS: At the instruction of my lawyer, 4 I must choose to invoke my Fifth Amendment right. 5 BY MS. EZELL: 6 Q. Do you know Max Brockman? 7 MR. REIN'HART: I'm sorry, can you repeat? 8 BY MS. EZELL: 9 Q. Do you know a Max Brockman? 10 MR. REINHART: I believe that was asked and 11 answered already, but -- 12 THE WITNESS: At the instruction of my lawyer, 13 I must invoke my Fifth Amendment right. 14 BY MS. EZELL: 15 Q. Have you ever been photographed with Max 16 Brockman at an Edge Science dinner? 17 A. At the instruction of my lawyer, I must invoke 18 my Fifth Amendment right. 19 MR. REINHART: You should let me --I need to 20 object to the form of the question first, but go 21 ahead. I know we all want to get out of here. Go 22 ahead. 23 THE WITNESS: Say it again. 24 MR. REINHART: No, you are okay. Go ahead, 25 Ms. Ezell. Thank you.¶
1 BY MS. EZELL:¶
2 Q. Do you want to respond? I didn't give you 3 time.¶
4 MR. REINHART: I've instructed her not to 5 answer the question. Let's move on.¶
6 BY MS. EZELL:¶
7 Q. Do you recall a dinner at El Brillo Way 8 attended by David Copperfield where Jane No. 103 was 9 guest?¶
MR. REINHART: Objection to the form, lack of 11 foundation, and a standing objection as to her 12 knowledge of anything involving El Brillo Way or 13 Jeffrey Epstein. Instruct her not to answer.¶
14 THE WITNESS: At the instruction of my lawyer 15 I must invoke my Fifth Amendment right.¶
16 BY MS. EZELL:¶
17 Q. What is the relationship between Jeffrey 18 Epstein and David Copperfield?¶
19 MR. REINHART: Objection to form, lack of 20 foundation as to her knowledge of either one of 21 those people. Instruct her not to answer.¶
22 THE WITNESS: At the instruction of my lawyer, 23 I must invoke my Fifth Amendment right.¶
24 BY MS. EZELL:¶
25 Q. To your knowledge, do they recruit girls for¶
Page 434¶
Page 436¶
1 one another?¶
2 MR. REINHART: Object to the form, compoun 3 and again, lack of foundation. Instruct her not to 4 answer.¶
5 THE WITNESS: At the instruction of my lawyee, 6 I must invoke my Fifth Amendment right.¶
7 BY MS. EZELL:¶
8 Q. To your knowledge, are they involved in any 9 sexual trafficking of young women?¶
10 MR. REINHART: Object to the form for the 11 reasons previously stated. Also calls for a legal 12 conclusion as to what sexual trafficking is. 13 Instruct her not to answer.¶
14 THE WITNESS: At the instruction of my lawye-15 I must invoke my Fifth Amendment right.¶
16 BY MS. EZELL:¶
17 Q. I believe you asked about'. Dershowitz 18 earlier.¶
19 MR. REINHART: Twice.¶
20 BY MS. EZELL:¶
21 Q. And were instructed not to answer.¶
22 MR. REINHART: Twice.¶
23 BY MS. EZELL:¶
24 Q. All right. I'm going to ask again on behalf 25 of my client. Are you aware of the friendship between¶
1 i Dershowitz and Jeffrey Epstein? 2 MR. REINHART: And for the third time, I'll 3 object to the form and instruct her not to answer 4 the question. 5 THE WITNESS: For the third time, I take the 6 advice of my lawyer and invoke my Fifth Amendment 7 right. 8 BY MS. EZELL: 9 Q. When Dershowitz comes to Palm Beach, he 10 stays at the El Brillo mansion, doesn't he? 11 MR. REINHART: Objection to the forrn. There 12 is no foundation for her having any knowledge of 13 anything having to do with a person by the name of 14 Dershowitz I instruct her not to answer. 15 THE WITNESS: At the instruction of my lawyer. 16 I must invoke my Fifth Amendment right. 17 BY MS. EZELL: 18 Q. WhenIM Dershowitz, or has Dershowitz 19 ever been there when young ladies came to give massages() 20 MR. REINHART: Same objection stated to the 21 previous question. Same instruction. 22 THE WITNESS: At the instruction of my lawyer, 23 I must invoke my Fifth Amendment right. 24 BY MS. EZELL: 25 Q. Has Dershowitz ever been the beneficiary¶
1 BY MS. EZELL: 2 Q. Do you know that when David Copperfield is in 3 town, he gives Jeffrey Epstein tickets and Jeffrey gives 4 some to young women to attend those shows? 5 MR. REINHART: Object to the form, multiple, 6 compound question, and a complete lack of 7 foundation. Instruct the witness not to answer. 8 THE WITNESS: At the instruction of my lawyer, 9 I must invoke my Fifth Amendment right. 10 BY MS. EZELL: 11 Q. And do you know that those girls are invited 12 back stage after the show? 13 MR. REINHART: Same objection, complete lack 14 of foundation, and standing objection previously 15 stated. 16 THE WITNESS: At the instruction of my lawyer, 17 I must invoke my Fifth Amendment right. 18 BY MS. EZELL: 19 Q. Do you remember on or about, in or about March 20 of 2005 having conversations with one of the young wom 21 who came to the house to give massages about her 22 conversations with Jane No. 103? 23 MR. REINHART: Objection to the form, standing 24 objection, lack of foundation. Instruct the 25 witness not to answer, because the question implies¶
2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 of those massages? MR. REINHART: Same objection and same instruction. THE WITNESS: At the instruction of my lawye 1 must invoke my Fifth Amendment right. BY MS. EZELL: Q. Do you know John Casablanca? A. Never heard that name before. Q. Have you ever heard of a world-famous illusionist whose stage name is David Copperfield? MR. REINHART: That's also been asked at leas three times. I'll instruct her again not to answer the question. THE WITNESS: At the instruction of my lawye-I must invoke my Fifth Amendment right. BY MS. F-ZELL: Q. Have you ever gone to one of David Copperfield's shows? MR. REINHART: Objection to form, lack of foundation as to knowledge of any person by the name of David Copperficld. Instruct her not to answer. THE WITNESS: At the instruction of my lawye I must invoke my Fifth Amendment right.¶
that she has any knowledge at all of El Brillo Way. 2 BY MS. EZELL: 3 Q. Same question — sorry. 4 A. At the instruction of my lawyer, I must choose 5 to invoke my Fifth Amendment privilege. 6 Q. Same question as to March of 2006. 7 MR. REINHART: Same objection and same 8 instruction. 9 THE WITNESS: At the instruction of my lawyer, 10 I must choose to invoke my Fifth Amendment 11 privilege. 12 BY MS. EZELL: 13 Q. Do you have any recollection of a conversation 14 in which one of the young women told Jane No. 103 tha 15 those girls who, those girls who would help Jeffrey in 16 regard to the investigation would be compensated and 17 those who would not or who would hurt him in the 18 investigation would be dealt with? 19 MR. REINHART: Objection to the form, lack of 20 foundation, compound question. Instruct the 21 witness not to answer, because the question implies 22 some knowledge of anything relating to a person by 23 the name of Jeffrey Epstein. 24 THE WITNESS: At the instruction of my lawyer 25 1 must invoke my Fifth Amendment right.¶