## EXHIBIT 22 ## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CV-80893-CIV-MARRA/ JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-8-591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF TAKEN ON BEHALF OF THE PLAINTIFF DATE: April 13, 2010 2 1 2 3 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 April 13,2010 INDEX WITNESS DIRECT CROSS REDIRECT RIECROSS BY MR. EDWARDS 5 98 BY MR. HOROWITZ 65 BY MR. LANGINO 77 BY MS. EZELL 81 EXHIBITS PLAINTIFF'S FOR IDENTIFICATION PAGE I Message dated August 21, 2005. 45 1 1 APPEARANCES (CONTINUED) 2 LEOPOLNKUYIN Attorneys for Plaintiffs 3 LLB. and C.E. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 13410 Tel: 5 BY: ADAM 1. LANGINO, ESQ. 6 7 9 10 11 12 13 15 16 17 18 19 20 21 22 23 24 PODIIURST. ORSECK Attorneys for Jane Does I and 3 Cily National Bank Building. Sone SS 25 West Hagler Sited Miro • ' 1 11110 Tel: BY: A h Ni W. EZELL. ESQ. BURMAN, CROTON, LUMEN & COLEMAN, 1.12 Attorneys few Defendant Jeffrey Erstein 303 Banyan Boulevard. Suite 400 Wes lorida 33401 Tel: BY: DAlIrrrrV.MA. Up. ROBERT CR1TTON, ESQ. ATTERBURY, GOLDBERGER & WEISS Co-Counsel for Defendants One Clearlake Ceara Suite 1400 W lorida 33401 Tel: BY: JACK A. LOBERG ER. ESQ. ALSO PRESENT: JESSICA CADWELL JOE ROVNER, Videogratther (US. Legal) 25 1 THEREUPON. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 123 24 25 being by Terri Becker first duly sworn to tell the whole truth, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MR. EDWARDS: Q Can you tell us your name. A Nadia Q What is your date of birth? A Q What Is your Social Security number? A Under advice of my counsel, I invoke my privileges under the Fifth and Sixth Amendments to the United States Constitution and respectfully decline to answer the question. Q Where were you born? A I'm sorry, though I would like to answer your question, I must invoke my Fifth and Sixth Amendment privileges and refuse to answer your questions. Q What is your current address? MR. GOLDBERGER: There is going to be a continued, obviously, you anticipate I'm sure, continued invocation of Fifth 5 3 led deposition of in the above-entillt.numbered 3 cause, was to en before me, TERRI BECKER, a 4 Registered Professional Reporter and Notary 5 Public for the State of Florida at Large, at 444 6 West Railroad Avenue, in the City of West Palm 7 Beach, Palm Beach County, in the State of 8 Florida, beginning at the hour of 10:00 o'clock 9 a.m., pursuant to the Notice in said cause for 10 the taking of said deposition which is annexed to 11 the court file herein, on behalf of the PLAINTIFF 12 in the above-entitled action pending in the 13 above-named court. 14 The appearances at said time and place 15 were as follows: 16 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL 17 Attorney Plaintiffs Jane Does, L.N. and 18 425 North Andrews Avenue Suite 2 19 Fort 1 rida 33301 20 Tel: BY: BRADLEY J. EDWARDS, ESQ. 21 MERMELSTEIN & HOROWITZ, P.A. 22 Attorneys for Plaintiffs Jane Does, numbers 2 through 8 23 18205 Biscayne Boulevard Suite 2218 24 M ia Tel: 25 BY: ADA . IOROWITZ. ESQ. 1 2 3 4 5 Amendment privileges. If it is okay with all counsel, to shorten things, I'll simply have the witness say "Fifth," if that mlisfies everyone's interest. MR. EDWARDS: That is tine with me. 6 MR. GOLDBERGER: Okay, with that Cathy? 6 visa for you? 7 MS. EZELL: Yes. 7 MR. YAREMA: Object to the form. 8 MR. HOROWITZ: Yes. 8 A The Fifth. 9 Q I'll reask the question, what's your 9 Q Do you know Evelyn Velnsaques? 10 current address? 10 A The Fifth. 11 A Fifth. 11 Q Were you ever a working model in the 12 Q Are you currently living at 358 El 12 United States? 13 Brillo Way with a man named Jeffrey Epstein? 13 A The Fifth. 14 A The Fiflh. 14 Q Can you tell us your parents' names? 15 Q Are you also familiar with an address in 15 A The Fifth. 16 New York, 301 East 66th Street? 16 Q How is it that you have supported 17 A The Fifth. 17 yourself financially, since you have been in this 18 Q When Mr. Epstein was incarcerated in 18 country? 19 jail, you went to visit hint on numerous 19 MR. YAREMA: Object to the form. 20 occasions; is that correct? 20 A The Fifth. 21 MR. YAREMA: Objection. 21 Q Have you supported yourself financially? 22 A The Fifth. 22 A The Fifth. 23 Q When you went to visit him you indicated 23 Q What is the last grade you completed in 24 to jail personnel your address was 301 East 66th 24 school? 25 Street, apartment 8-D in New York City, New York; 25 A The Fifth, I take the Fifth Amendment. 1 2 3 4 5 8 A The Fifth. Q Do you know a lady by the name of Maritsa Vazques? A The Fifth. Q Is this somebody who helped to falsify a 7 9 3 A Fifth. 3 Q Have you ever attended any school in the 1 is that correct? 1 Q Are you in school now? 2 MR. YAREMA: Objection. 2 A The Fifth. 4 Q Isn't it true when Mr. Epstein was In 4 United States? 5 jail, you visited hint on more than 50 occasions? 5 A The Fifth. 6 MR. YAREMA: Form objection. 6 Q Have you ever been employed since 7 Q True? 7 residing in the United States? 8 A The Fifth. 8 A The Fifth. 9 Q flow long have you been in the United 9 Q Is Jeffrey Epstein your sole means of 10 States, 10 financial support today? 11 A The Fifth. 11 MR. YAREMA: Object to the form. 12 Q Who brought you to the United States? 12 A The Fifth. 13 MR. YAREMA: Form objection. 13 Q Since coming to this country, hasn't 14 A The Fifth. 14 Jeffrey Epstein always been your sole means of 15 Q What is your current status in this 15 financial support? 16 country? 16 MR. YAREMA: Object to the form. 17 A The Fifth. 17 A The Fifth. 18 MR. YAREMA: Form objection. 18 Q flow much does Jeffrey Epstein pay you 19 MR. GOLDBERGER: Let me take a half a 19 today? 20 second. 20 MR. YAREMA: Object to the form. 21 (Witness and her counsel confer.) 21 A The Fifth. 22 Q Are you a U.S. citizen? 22 Q What does every Epstein pay you for? 23 A The Fifth. 23 MR. YAREMA: Object to the form. 24 Q What type of visa are you here on? 24 A The Fifth. 25 MR. YAREMA: Form objection. 25 Q Does he pay you specifically to be his ![](_page_3_Picture_7.jpeg) 1 2 3 4 S 6 54 A Fifth. Q Do you know Bill Clinton? A Fifth. Q You have been on Jeffrey Epstein's airplane with Bill Clinton? MR. YAREMA: Object to the fonn. 7 A Fifth. Q Isn't take true you have been on Jeffrey 9 Epstein's airplane with Doug Band, Bill Clinton's 9 destination? 10 righthand man? 10 MR. YAREMA: Object to the room 11 MR. YAREMA: Object to the form. 11 A Fifth. 12 A Fifth. 12 Q Isn't it true that he employed numerous 13 Q Have you witnessed improper sexual 13 people for the sole purpose of scheduling 15 while he was in the presence of Bill Clinton? 15 destination he landed? 16 MR. YAREMA: Object to the form. 16 MR. YAREMA: Object to the form. 17 A Fifth. 17 A Fifth. 18 Q How many times have you ridden on the 18 Q What Is Jeffrey Epstein's relationship 19 airplane with Jean Luc Brunei? 19 with Sandy Berger? 20 MR. YAREMA: Object to the form. 20 MR. YAREMA: Object to the fonn. 21 A Fifth. 21 A Fifth. 22 Q Each time that Jean Luc Brunel visits 22 Q Do you know what Jeffrey Epstein's 23 Jeffrey Epstein's house, does he bring underage 23 relationship is with Alan Dershowitz? 24 minors to Jeffrey Epstein's house to engage in 24 MR. YAREMA: Object to the form. 25 sex with? 25 A Fifth. 1 2 3 4 5 6 56 Jeffrey Epstein specifically flew to Palm Beach for the purposes of engaging in sex acts with Jane Doc? MR. YAREMA: Object to the font. A Fifth. Q Generally, isn't it true Jeffrey Epstein 7 would fly front place to place for the purpose of engaging in sexual activity with minors at his 14 activity between Jeffrey Epstein and minors, 14 appointments with underage minor females at each 55 1 MR. YAREMA: Object to the form. 1 Q That's somebody who you know to have 2 A Fifth. 2 stayed at Jeffrey Epstein's house on many 3 Q Do you know Glenn Dubin? 3 occasions, correct? 4 A Fifth. 4 MR. YAREMA: Object to the form. 5 Q Do you know=M? 5 A Fifth. 7 Q Is that somebody that was a sexual abuse 7 been at the house when was in Jeffrey 8 victim at one point In time of Jeffrey Epstein B Epstein's bedroom getting sexually abused, 9 and Jean Lue Brunel? 9 correct? 10 MR. YAREMA: Object to the form. 10 MR. YAREMA: Object to the form. 11 A Fifth. 11 A Fifth. 12 Q Between 2002 and 2005 when M. was 12 Q Alan Dershowitz is also somebody that 14 that Jeffrey Epstein took flights to Palm Beach 14 was being sexually abused in Jeffrey Epstein's 15 for the purposes of sexually abusing n't 15 bedroom, correct? 16 MR. YAREMA: Object to the form. 16 MR. YAREMA: Object to the fonn. 17 A Fifth. 17 A Fifth. 18 Q And between those sante years of 2002 and 18 Q Generally, Alan Dershowitz is familiar 19 2005, isn't it true that Jeffrey Epstein took 19 with Jeffrey Epstein's habit of engaging in 20 airplane flights to Palm Beach from places 20 sexual acts with minors on a daily basis, 21 outside of the State, to engage in sexual acts 21 correct? 22 with MI.? 22 MR. YAREMA: Object to the form. 23 MR. YAREMA: Object to the form. 23 A Fifth. 24 A Fifth. 24 Q When Alan Dershowitz was in town, 25 Q From 2003 through 2005, isn't it true 25 Jeffrey Epstein did not break his schedule for 6 A Fifth. 6 Q And also somebody who you know to have 13 abused by Jeffrey Epstein sexually, isn't it true 13 you also know to have been at the house when M. 58 60 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 Q What was the purpose of that flight? MR. YAREMA: Object to the tbrm. A Fifth. Q Did you sign a confidentiality agreement with Jeffrey Epstein? MR. YAREMA: Object to the form. A Fifth. Q When Is the last time that you observed Jeffrey Epstein have sex with a minor? MR. YAREMA: Object to the fonn. A Fifth. Q Since being on probation, has Jeffrey Epstein been able to, or has he flown to his island? MR. YAREMA: Object to the form. A Filth. Q To your knowledge, has Jeffrey Epstein flown to New York while on probation or community control? MR. YAREMA: Object to the form. A Fifth. Q Isn't It true that he has flown both to New York and to his island, and you have accompanied hint on those trips, since be was on community control? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 59 1 Q You know that Ghislaine Maxwell engaged 2 in sexual acts with underage minor females, true? 3 MR. YAREMA: Object to the form. 4 A Fifth. 5 Q This is yet another friend of Jeffrey 6 Epstein's that is into the act of molesting 7 underage minor females, right? 8 MR. YAREMA: Object to the form. A Fifth. Q Now, you are the next participant In that activity, meaning you have been groomed to enjoy and appreciate the acts of sex with underage minors, true? MR. YAREMA: Object to the form. A Fifth. Q Has Jeffrey Epstein instructed you to lie to his Probation Officer in any way? MR. YAREMA: Object to the fonn. A Fifth. Q Mr. Visoski testified that you took a helicopter flight within the last year with Jeffrey Epstein to Miami. Do you remember that flight? MR. YAREMA: Object to the form. A Fifth. 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 Alan Dershowitz, meaning he continued to sexually 2 abuse minors despite Alan Dershowitz being a 3 guest in the house? 4 MR\_ YAREMA: Object to the form. A Fifth. Q Alan Dershowitz never engaged in any sexual activity with these underage minors; Isn't that true? MR. YAREMA: Object to the form. A Fifth. Q Have you been made to have sex with Ghislaine Maxwell? MR. YAREMA: Object to the form. A Fifth. Q Do you knot A Fifth. Q Similar to you being Jeffrey Epstein's sex slave, Is or win Ghislaine Maxwell's sex slave? MR. YAREMA: Object to the font A Fifth. Q Ghislaine Maxwell is somebody who you know to be bi-sexual, true? MR. YAREMA: Object to the form. A Fifth. > 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 6\_ 1 MR. YAREMA: Object to the fonn. 2 A Fifth. 3 Q Isn't it also true that Jeffrey Epstein 4 has indicated to you that he will always engage 5 in sex acts with underage minor females? MR. YAREMA: Object to the fonn. A Fifth. Q In fact, that's something that he has told you, that he believes he is entitled to do; isn't that right? MR. YAREMA: Object to the form. A Fifth. Q Isn't it true that Jeffrey Epstein believes and has told you that if he doesn't physically force the underage minor female into any act, then he is entitled to engage in sex with any underage minor female despite the age? MR. YAREMA: Object to the fonn. A Fifth. Q What is the youngest female you have witnessed or observed Jeffrey Epstein to engage in sex with? MR. YAREMA: Object to the fonn. A Fifth. Q Do you have a bank account at Chase Dank 98 100 5 Slate of Florida at Large, do hereby certify that 6 MS. EZELL: I don't have any other 7 S ow wErNEss, called by the PLAINTIFF 14 or employee of any attorney or counsel connected ' TERRI rtr, t ECI Registered '.........."/ Professional Reporter and 22 Notary Public, State of Florida 1 A Fifth. 1 THE STATE OF FLORIDA) 2 Q Did you know that Jeffrey Epstein gave 2 COUNTY OF PALM BEACH) 3 A.D. a digital camera? 3 ',TERRI BECKER, a Registered 4 MR. YAREMA: Object to the fonn. 4 Professional Reporter and NotaryPublic for the 5 A Fifth. 6 I reported the videotaped deposition of\_ 7 questions. Thank you. 8 in the above-entitled action; that the witness 8 MR. GOLDBERGER: You still have your 9 was duly sworn by me; that the foregoing pages, 9 microphone on. You must have something on 10 numbered front Ito 104, inclusive, constitute a 10 your mind, Brad. 11 true record of the deposition by said witness. 11 REDIRECT EXAMINATION 12 I \[antler certify that I ant not attorney 12 BY M12. EDWARDS: 13 or counsel ofany of the parties, nor a relative 13Q through the whole day is with the action, nor financially interested in 14 you've taken the Fifth on just about every single 16 the action. 15 question. Is there any reason why we should not 17 WITNESS MY HAND and official seal iii the 16 presume that the answer to these questions would 18 City of West Palm Beach, County of Palm Beach, 17 incriminate you? 19 State or Florida, this 19th day of April 2010. 18 MR. YAREMA: Object to the fonti. 20 CTh rz i -A,FE 19 20 A The Fifth. Q The reason that you have taken the Fifth 21 21 is because the questions you have been asked 22 would have been answered in the affirmative anti at Large. My Commission expires 23 you're afraid of prosecution for your 23 March 13,2011. 24 Involvement, true? 24 25 MR. GOLDBERGER: Don't answer that 25 1 question. It interferes with the 1 THE STATE OF FLORIDA) 2 attorney/client relationship that I have 2 COUNTY OF PALM BEACH) 3 with and any discussions she 3 4 and I may have had would come under that 4 5 privilege. 5 The foregoing certificate was 6 You can try and dance around that, but 6 acknowledged before me this day of 2010. 7 I'm simply not going to allow her to answer 8B that question. If you want to bring it up 9 with the Judge, you can. 10 10 MR. EDWARDS: Thanks, Jack. 11 11 MR. GOLDBERGER: Okay. 12 12 THE VIDEOGRAPHER: Off the video record 13 13 at 1:41 p.m. 14 14 THE COURT REPORTER: You're ordering Notary Public, State of Florida. 15 this, Brad? 15 My commission No. 16 MR. EDWARDS: Yes. Copies? Expires March 13,2011. 17 MS. EZELL: Yes. 16 18 MR. YAREMA: Yes: 17 19 THE COURT REPORTER: And Adam wanted it; 18 19 20 is that right? 21 MR. EDWARDS: Yes. 21 22 (Time noted: 1:45 p.m.) 22 23 23 24 24 25 25