EXHIBIT 15 (Filed Under Seal)¶
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¶
U.S. Legal Support (561) 835-0220¶
| 26 to his house to sexually molest; is that right? | minor females? | ||
|---|---|---|---|
| 2 | MR. YAREMA: Object to the loon. | ||
| 3 | A Fifth. | ||
| 5 | Epstein's house was in 2002 when she was only 14 | ||
| 6 | years old; is that true? | ||
| 7 | MR. YAREMA: Object to the loon | ||
| 8 | A Fifth. | ||
| 9 | Q In fact in 2002 you were only 18 years | ||
| 0 | old or so yourself; is that right? | ||
| I | A Filth. | ||
| 2 | Q And E.W. Is somebody you observed al | ||
| 3 | Jeffrey Epstein's house on more than 100 | ||
| 4 | occasions between 2002 and 2005, a time period | ||
| 5 | between 14 and 17 years of age for her; is that | ||
| 6 | right? | ||
| 7 | MR. YAREMA: Object to the loon. | ||
| 8 | A Filth. | ||
| 9 | Q And each time E.W. was summoned to | ||
| '3 | MR. YAREMA: Object to the form. | ||
| calling LW.. you observed to call | |||
| 2 | E.W. for the purposes of her coming over and | ||
| 3 | pleasing Jeffrey Epstein sexually, correct? | ||
| 4 | MR. YAREMA: Object to the form. | ||
| 5 | A Fifth. | ||
| 6 | Q And do you remember the instance where | ||
| 7 | Jeffrey Epstein instructed you to lay down naked | ||
| a | and engage in a threesome with E.W. and Jeffrey | ||
| 9 | Epstein? | ||
| .0 | MR. YAREMA Object to the fonn. | ||
| .1 | A Fifth. | ||
| .2 | Q Do you remember that that during that | ||
| .3 | threesome, Jeffrey Epstein demanded E.W. to | ||
| ,4 | straddle you and otherwise engage sexually with | ||
| l7 | MR. YAKIMA: Object to the fonn. | ||
| .t; | A Fifth. | ||
| .9 | Q In addition to your sexual interactions | ||
| !O | with E.W., Isn't it true that you have used | ||
| !2 | minors at Jeffrey Epstein's direction? | ||
| !3 | MR. YAREMA! Object to the town. | ||
| 24 | A Fifth. | ||
| 15 | Q You have given oral sex to underage | ||
| 2 | MR. YAREMA: Object to the loon. | ||
| 3 | A filth | ||
| Q The first time she went to Jeffrey | 4 | Q You have received oral sex from underage | |
| 5 | minor females? | ||
| 6 | MR. YAREMA: Object to the form. | ||
| 7 | A Fifth. | ||
| 8 | Q All of these sexual acts with minor | ||
| 9 | females involving you happened in the presence of | ||
| 10 | Jeffrey Epstein? | ||
| 11 | MR. YAREMA: Object to the Mon. | ||
| 12 | A Fifth. | ||
| 13 | Q During your interaction with underage minor females in a sexual manner, isn't it true | ||
| 15 | that Jeffrey Epstein would participate in the | ||
| 16 | sexual acts and the act would be over upon Jeffrey Epstein ejaculating, correct? | ||
| 18 | MR. YAREM A: Object to the bum | ||
| 19 | A Fifth | ||
| Jeffrey Epstein's house, it was for the purposes | 20 | Q Did Jeffrey Epstein tell you, that when | |
| of .leffrey Epstein sexually molesting her, | 21 | E.W. was an underage minor female, he forced her | |
| correct? | 22 | to give him oral sex? | |
| 23 | Mit. YAREMA: Object to the loon | ||
| A Fifth. | 24 | A Fifth. | |
| Q If It was not Jeffrey Epstein personally | 25 | Q Do you remember E.W. coming over, a | |
| 1 | young girl, with braces on. and going up into | ||
| 2 | Jeffrey Epstein's bedroom un numerous occasions | ||
| 3 | to be sexually molested? | ||
| 4 | MR. YAREMA: Object to the tom,. | ||
| 5 | A Filth. | ||
| 6 | Q Do you know when it was that Jeffrey | ||
| 7 | Epstein developed his plan or scheme to gain | ||
| 8 | access to hundreds of underage minor females for | ||
| 9 | the purposes of his sexual gratification? | ||
| 0 | MR. YAREMA: Object to the form. | ||
| 11 | A Fifth | ||
| 12 | Q Were you a part of the planning of that | ||
| 13 | scheme of Jeffrey Epstein's to gain access to | ||
| 19 | underage minor females? | ||
| you while Jeffrey Epstein was using vibrators | 5 | MR. YAREMA: Object to the font,. | |
| and/or (Milos on you? | 16 | A Filth. | |
| 17 | Q Do you know Chislaine Maxwell? | ||
| 18 | A Fifth. | ||
| 19 | Q Is that somebody who helped Jeffrey | ||
| 20 | Epstein to devise the scheme to allow him access | ||
| strap-un rind°, and vibrators on other underage | 21 | to various anti a variety of underage Mutat | |
| 22 | females? | ||
| 23 | MR. YAREMA: Object to the loon. | ||
| 24 | A Firth. | ||
| 25 | Q Is somebody that was also |
| 30 | |||
|---|---|---|---|
| 2 | access to underage minor females? | ||
| 3 | MR. YAREMA: Object to the hum. | ||
| 4 | A Fifth. | ||
| 5 | Q When is the First dine that you observed | ||
| 6 | Jeffrey Epstein's method of enticing or inducing | ||
| 7 | Underage minor females into sexual acts with hint | ||
| 8 | inside his bedroom? | ||
| 9 | MR. YAREMA Object to the 'non | ||
| 0 | A Fifth. | ||
| 2 | minor (mule was brought to Jeffrey Epstein's | ||
| 3 | house, typically or Attrition or | ||
| 4 | yonrself would lead that underage minor female to | ||
| 5 | Jeffrey Epstein's bedroom and leave them alone in | ||
| 6 | the room; is that true? | ||
| 9 | Q Then Jeffrey Epstein would uppenr either | ||
| 'o | naked or wearing a towel; is that true? | ||
| '1 | MR. YAREMA: Object to the form. | ||
| '2 | A Fifth. | ||
| !3 | Q This Is his habit or method of | ||
| !4 | operation, every single time, and that's | ||
| '5 | something that he has told you about his sexual | ||
| 2 | MR. YAREMA: Object to the from. | ||
| 3 | A Fifth | ||
| S | instruct the underage minor female to remove her | ||
| 6 | clothing; is that true? | ||
| 7 | MR YAREMA' Object to the limn. | ||
| A Fifth. | |||
| 9 | Q Then he would perform one or more lewd | ||
| 10 | or lascivious or sexual acts on the underage | ||
| 11 | minor female. Is that true? | ||
| 12 | MR. YAREMA: Object to the form. | ||
| 13 | A Fifth | ||
| i4 | Q And you have observed Jeffrey Epstein | ||
| 5 | engage in sexual interaction with underage minor | ||
| l6 | females on hundreds and hundreds of occasions, | ||
| 1.7 | correct? | ||
| 18 | MR. YAREMA: Object to the form | ||
| 20 | Q And you have observed Jeffrey Epstein | ||
| 21 | using vibrators and sexual toys on underage | ||
| 22 | minors, true? | ||
| 23 | MR. YAREMA: Object to the fonn | ||
| 24 | A Fifth. | ||
| 25 | Q In fact, he has also used vibrators and | ||
| insolved in the planning of this scheme to gain | 1 | sex toys on you, correct? | |
| 2 | A Filth. | ||
| 3 | Q And he has instructed you lo use se,. | ||
| 4 | toys and vibrators on other underage minor | ||
| 5 | females, correct? | ||
| 6 | MR. YAREMA Object to the fomi. | ||
| 7 | A Fifth. | ||
| Q Isn't it true that after an underage | 8 | Q You have observed Jeffrey Epstein digitally penetrate the vagina of underage minor females, including E.W., correct? MR. YAREMA. Object to the loon. | |
| A Fifth. | |||
| Q As part of his plan to avoid detection by law enforcement, you have observed Jeffrey EtmeintotmyMneunderagendemrfmmleslobe quiet, correct? | |||
| MR. YAREMA: Object in the limn. A Fillh | MR. YAREMA Object to the foim. A Fifth. | ||
| Q And this is something that he has told you he dues, for the purposes of grooming these underage minor females, and avoiding law enforcement detection, correct? MR YAREMA: Object to the coml. A Fifth. | |||
| 5 | Q Jeffrey Epstein has talked to you about | ||
| interaction with underage minors; is that true? | 1 | the psychology of brainwashing or grooming | |
| 2 | underage minor females to perform for hint | ||
| 3 | sexually, hasn't he? | ||
| Q And he would direct or demand in | 4 | MR. YAREMA: Object to the loon | |
| 5 | A rink | ||
| 6 | Q And has also spoken with | ||
| 7 | you about the methodology behind gaining access | ||
| 8 | to and grooming underage minor females for sex? | ||
| 9 | MR. YAREMA: Object to form | ||
| 10 | A Filth. | ||
| 1 | Q Isn't it true that Ghislalne (linnet' and | ||
| 12 | yoursell and had access to a | ||
| 13 | list of underage minor females names and phone | ||
| 14 | numbers so that they could be called? | ||
| 15 | MR. GOLDBERGER: Time out. Arc you | ||
| 16 | talking to Inc. counsel? | ||
| 17 | Mlt. BOROWITZ: Nodding my head, back at | ||
| 8 | you. You were nodding at me. | ||
| A Fifth. | 19 | MR. GOLDBERGER: I wasn't nodding at | |
| 20 | you. I'm not talking to you. I'm not | ||
| 21 | communicating with you.. I don't know what | ||
| 22 | you think we nrc doing here. You said "It | ||
| 73 | ix true," and I have no idea what you arc | ||
| 24 | talking tut. Don't intertopt the | ||
| 25 | deposition. okay? |
| <p>1 MR. HOROWITZ: I think you interrupted.</p> <p>2 MR. GOLDBERGER: I didn't do a thing --</p> <p>3 MR. [REDACTED]: I don't know what's</p> <p>4 happened here. It has deteriorated here for</p> <p>5 no reason whatsoever and has nothing to do</p> <p>6 with me or the witness.</p> <p>7 MR. GOLDBERGER: You're 100 percent</p> <p>8 correct.</p> <p>9 MR. [REDACTED]: Can we go back to it.</p> <p>10 MR. GOLDBERGER: Absolutely.</p> <p>11 MR. [REDACTED]: Perfect.</p> <p>12 The silent fight disrupted me. I lost</p> <p>13 where I am now.</p> <p>14 MR. GOLDBERGER: Sorry.</p> <p>15 MR. [REDACTED]: Can you read it back.</p> <p>16 THE COURT REPORTER: Certainly.</p> <p>17 (The record was read.)</p> <p>18 MR. [REDACTED]: I'll rephrase the</p> <p>19 question.</p> <p>20 Q Isn't it true that yourself, Ghislaine</p> <p>21 Maxwell and Sarah [REDACTED] had access to a [REDACTED]</p> <p>22 of list of underage minor females names and phone</p> <p>23 numbers so they could be called for the purpose</p> <p>24 of coming to Jeffrey Epstein's house to be</p> <p>25 sexually molested?</p> | <p>1 A Fifth.</p> <p>2 Q In addition to that system, isn't it</p> <p>3 true that Jeffrey Epstein traffics underage minor</p> <p>4 females through a modeling agency?</p> <p>5 MR. YAREMA: Object to the form.</p> <p>6 A Fifth.</p> <p>7 Q Is a modeling agency that he is involved</p> <p>8 in with Jean Luc Brunel; you know who that is</p> <p>9 right?</p> <p>10 MR. YAREMA: Object to the form.</p> <p>11 A Fifth.</p> <p>12 Q Are you familiar with MC-2 or MC-Squared</p> <p>13 Modeling Agency?</p> <p>14 A Fifth.</p> <p>15 Q You know Jean Luc Brunel, right?</p> <p>16 MR. YAREMA: Object to the form.</p> <p>17 A Fifth.</p> <p>18 Q Is Jean Luc Brunel somebody that you</p> <p>19 have been made to perform on sexually?</p> <p>20 MR. YAREMA: Object to the form.</p> <p>21 A Fifth.</p> <p>22 Q Jean Luc Brunel is somebody that you</p> <p>23 know to also be a child molester, true?</p> <p>24 MR. YAREMA: Object to the form.</p> <p>25 A Fifth.</p> | <p>36</p> <p>37</p> |
|---|---|---|
| <p>1 MR. YAREMA: Object to the form.</p> <p>2 A Fifth.</p> <p>3 Q How many underage minor females are on</p> <p>4 that [REDACTED] list?</p> <p>5 MR. YAREMA: Object to the form.</p> <p>6 A Fifth.</p> <p>7 Q Are there photographs of these underage</p> <p>8 minor females on that [REDACTED] list?</p> <p>9 MR. YAREMA: Object to the form.</p> <p>10 A Fifth.</p> <p>11 Q Is that [REDACTED] list saved on a computer</p> <p>12 system, as has been testified to in the past?</p> <p>13 MR. YAREMA: Object to the form.</p> <p>14 A Fifth.</p> <p>15 Q Has Jeffrey Epstein talked to you about</p> <p>16 the success of his scheme to procure underage</p> <p>17 minor females?</p> <p>18 MR. [REDACTED]: Object to the form.</p> <p>19 A Fifth.</p> <p>20 Q By that, I mean, the method where he</p> <p>21 molests an underage minor female, then offers</p> <p>22 them additional money if they will bring him</p> <p>23 other underage minor females to molest; are you</p> <p>24 familiar with that system?</p> <p>25 MR. YAREMA: Object to the form.</p> | <p>1 Q This is somebody who for years the</p> <p>2 public has known of Jean Luc Brunel as a child</p> <p>3 molester, true?</p> <p>4 MR. YAREMA: Object to the form.</p> <p>5 A Fifth.</p> <p>6 Q In fact, that is the only thing Jeffrey</p> <p>7 Epstein and Jean Luc Brunel have in common, is</p> <p>8 their obsession for underage minor females,</p> <p>9 correct?</p> <p>10 MR. YAREMA: Object to the form.</p> <p>11 A Fifth.</p> <p>12 Q And the modeling agency is but one other</p> <p>13 mechanism used by Jeffrey Epstein to gain access</p> <p>14 to underage minor females for sex, true?</p> <p>15 MR. YAREMA: Object to the form.</p> <p>16 A Fifth.</p> <p>17 Q I read you the statute earlier on Lewd</p> <p>18 and Lascivious Molestation, Chapter 800.04, and</p> <p>19 that's something that you have witnessed Jeffrey</p> <p>20 Epstein violate on hundreds of occasions,</p> <p>21 correct?</p> <p>22 MR. YAREMA: Object to the form.</p> <p>23 A Fifth.</p> <p>24 Q And something that you have witnessed</p> <p>25 Jeffrey Epstein specifically violate, against</p> | <p>36</p> <p>37</p> |
1 2 3 4 5 46 A Fifth. Q That particular message indicates it is from Nadia. You're the only "Nadia" in the house; is that correct? Mit. YAREMA: Object to the loon. Q This is a call front you indicating that 7 that correct? 8 catinot work today and will be 8 MR. YAREMA: Object to the loon. 9 here at 4:00 p.m.;" is that right? 9 A Fifth. 10 Mit. YAREMA: Object to the form? 10 Q Was that typical of Jeffrey Epstein anti 11 A Fifth. 11 Chislaine Maxwell to sexually abuse minors on 12 Q Who isM? 12 Jeffrey Epstein's airplane? 13 A Fifth. 13 MR. YAREMA: Object to the form. 14 Mit. YAREMA: Object to the form. 14 A Fifth. 15 Q That's an underage minor female that was 15 Q And also typical of (Antoine Maxwell 16 scheduled to be molested at Jeffrey Epstein's 16 and Jeffrey Epstein to prostitute or pimp out 17 house? 17 underage minors to friends? 18 MR. YAREMA: Object to the fonn. 18 MR. YAREMA: Object to the lixm. 19 A Fifth. 19 A Fifth. 20 Q You scheduled that act of molestation; 20 C) By "friends," I ant talking specifically 21 is that right? 21 about people of royalty, politicians, 23 A Fifth. 3 or personal acquaintances? 24 Q And will be at the house at 4:00 4 MR. YAREMA: Object to the form 25 p.m. Is another underage minor female; 5 A Fifth.¶
1 Ghislaine Maxwell's sexual interaction with Jane 2 Doe-102 when she was a minor? 3 MR. YAREMA: Object to the form. 4 Q This is one of many underage minor 5 females that was trafficked basically around the A Fifth. 6 globe to be sexually exploited and abused; is 22 MR. YAREMA: Object to the form. 22 academicians, businessmen and other professional¶
47 49 3 A Fifth. 3 12 -- sorry, three 12-year olds for the purposes 7 her, while she was an underage minor, true? 7 Q How many occasions have you observed B MR. YAREMA: Object to the form. 8 Jeffrey Epstein to receive ns gifts from friends, 9 A Fifth. 9 underage minor females for the purposes of him L4 MR. YAREMA: Object to the form. 14 France. Were they sent to hint on his birthday by 8 A Fifth. 18 Q Ilave you ever been made to engage in sex¶
1 is that correct? 1 Q Were you with Jeffrey Epstein on his 2 MR. YAREMA: Object to the form. 2 birthday when one of his friends sent to him 4 Q That's somebody else that you were 4 of Jeffrey Epstein sexually abusing them? S scheduling to come to his house at 4:00 p.m. for 5 MR. YAREMA: Object to the form. 6 Jeffrey Epstein to engage in sexual acts with 6 A Fifth. LO Q Do you know Les Wexner? 10 sexually abusing them? 1 A Fifth. 12 MR. YAREMA, Object to the frm. 12 Q That's somebody that you know owns and 2 A Fifth. L3 operates the Victoria's Secret, the Limited? 13 Q These three 12-year olds were from 15 A is that a question? 15 Jean Luc Brunel or by somebody else? 16 Q Is that somebody that you know to own 16 MR. YAREMA: Object to form. L7 Victoria's Secret or operate Victoria's Secret? 17 A Fifth. L 9 Q Do you know if Jeffrey Epstein still 19 with I2-year olds? ≥0 talks with Leslie Wexner? 20 MR. YAREMA: Object to the loon. MR. YAREMA: Object to the form. 21 A Fifth. ≥2 A Fifth. 22 (2 Is it true that Jeffrey Epstein makes 23 Q Do you know Jane Doc-102? 23 you dress up as a 12-year old? ?4 A Fink 24 MR. YAREMA: Object to the loon. ≥5 Q Are you aware of Jeffrey Epstein and 25 A Fifth.¶
58 Alan Dershowitr, meaning he continued to sexually 1 7 abuse minors despite Alan Denhowilt being a 2 MR. YAREMA. Object to the loon. 3 guest in the house? 3 A Fifth. 4 MR. YAREMA Object to the form. 4 Q Did you sign a confidentiality agreement 5 A Fifth. 5 with Jeffrey Epstein? 6 Q Alan Dershowar never engaged in any 6 MIt. YAREMA: Object to the form. 7 sexual activity with these underage minors; isn't 7 A Fifth. 8 that true? 8 Q When is the last time that you observed 9 MR_ YAREMA Object to the form 9 Jeffrey Epstein have sex with a minor? 10 A Fifth. 10 MR. YAREMA: Object to the hum. 11 Q Have you been made to have sex with 11 A Fifth. 12 Ghislaine Maxwell? 12 Q Since being on probation, has Jeffrey 13 MR. YAREMA: Object to the form. 13 Epstein been able to, or has he flown to his 14 A Fifth. 14 island? 15 Q Do you know 15 MR. YAREMA: Object to the than. 16 A Filth. 16 A Filth. 17 Q Similar to you being Jeffrey Epstein's 17 Q To your knowledge, has Jeffrey Epstein 19 Ghislaine Maxwell's sex slave? 19 control? 20 MR. YAREMA: Object to the form. 20 MR. YAREMA Object to die form. 21 A Fifth. 21 A Firth. 22 Q Ghislaine Maxwell is somebody who you 22 Q Isn't it true that he has flown both to 23 know to be bl-sexual, true? 23 New York and to his island, and you have 24 MR. YAltEMA: Object to the form. 24 accompanied him on those trips, shire he was on 25 A Fifth. 25 community control?¶
60 Q What was the purpose of that flight? 18 sex slave, is, or WSW 18 flown to New York while on probation or community¶
59 61¶
1 Q You know that Ghislaine Maxwell engaged 1 MR. YAREMA: Object to the form. 2 in sexual acts with underage minor females, true? 2 A Fifth. 3 MR. YAREMA: Object to the form. 3 Q Isn't it also true that Jeffrey Epstein 4 A Filth. 4 has indicated to you that he will always engage 5 Q This is yet another friend of Jeffrey 5 in sex nets with underage minor females? 6 Epstein's that is into the act of molesting 6 MR. YAREMA: Object to the fonw 7 underage minor females, right? 7 A Fifth. 8 MR. YAREMA: Object to the fools 8 Q In fact, that's something that he has 9 A Fifth. 9 told you, that he believes he is entitled to do; 10 Q Now, you are the next participant in 10 isn't that right? 11 that activity, meaning you have been groomed to 11 MR. YAREMA Object to the form. 12 enjoy and appreciate the acts of sex with 12 A Fifth. 13 underage minors, true? 13 Q Isn't it true that Jeffrey Epstein 14 MR. YAREMA: Object to the form. 14 believes and has told you that If he doesn't 15 A Fifth. 15 physically force the underage minor female into 16 Q Ilas Jeffrey Epstein instructed you to 16 any act, then he is entitled to engage in sex 17 lie to his Probation Officer in any way? 17 with any underage minor female despite the age? 18 MR. YAREMA: Object to the form. 18 MR. YAREMA: Object to the form. 19 A Fifth_ 19 A Fifth. 20 Q Mr. Visoski testified that you took a 20 Q What is the youngest female you have 21 helicopter flight within the last year with 21 witnessed or observed Jeffrey Epstein to engage 22 Jeffrey Epstein to Miami. Do you remember that 22 In sex with? 23 flight? 23 MR. YAREMA: Object to the form. 24 MR. YAREMA: Object to the form. 24 A Fifth. 25 A Fifth. 25 Q Do you have a bank account al Chase Rank¶
1 A Fifth.
2 Q Did you know that Jeffrey Epstein gave
3 A.D. a digital camera?¶
4 MR. YAREMA: Object to the form.¶
5 A Fifth.
6 MS. EZELL: I don't have any other
7 questions. Thank you.¶
8 MR. GOLDBERGER: You still have your
9 microphone on. You must have something on
10 your mind, Brad.¶
11 REDIRECT EXAMINATION
12 BY MR. [REDACTED]¶
13 [REDACTED] through the whole day
14 you've taken the Fifth on just about every single
15 question. Is there any reason why we should not
16 presume that the answer to these questions would
17 incriminate you?¶
18 MR. YAREMA: Object to the form.
19 A The Fifth.¶
20 Q The reason that you have taken the Fifth
21 is because the questions you have been asked
22 would have been answered in the affirmative and
23 you're afraid of prosecution for your
24 involvement, true?¶
25 MR. GOLDBERGER: Don't answer that¶
1 THE STATE OF FLORIDA)
2 COUNTY OF PALM BEACH)
3 I, TERRI BECKER, a Registered
4 Professional Reporter and Notary Public for the
5 State of Florida at Large, do hereby certify that
6 I reported the videotaped deposition of [REDACTED]
7 [REDACTED] the WITNESS, called by the PLAINTIFF
8 in the above-entitled action; that the witness
9 was duly sworn by me; that the foregoing pages,
10 numbered from 1 to 104, inclusive, constitute a
11 true record of the deposition by said witness.¶
12 I further certify that I am not attorney
13 or counsel of any of the parties, nor a relative
14 or employee of any attorney or counsel connected
15 with the action, nor financially interested in
16 the action.¶
17 WITNESS MY HAND and official seal in the
18 City of West Palm Beach, County of Palm Beach,
19 State of Florida, this 19th day of April 2010.¶
20
21
22
23
24
25¶
1 question. It interferes with the
2 attorney/client relationship that I have
3 with [REDACTED] and any discussions she
4 and I may have had would come under that
5 privilege.¶
6 You can try and dance around that, but
7 I'm simply not going to allow her to answer
8 that question. If you want to bring it up
9 with the Judge, you can.¶
10 MR. [REDACTED] Thanks, Jack.¶
11 MR. GOLDBERGER: Okay.
12 THE VIDEOGRAPHER: Off the video record
13 at 1:41 p.m.¶
14 THE COURT REPORTER: You're ordering
15 this, Brad?¶
16 MR. [REDACTED] Yes. Copies?¶
17 MS. EZELL: Yes.¶
18 MR. YAREMA: Yes.
19 THE COURT REPORTER: And Adam wanted it;
20 is that right?¶
21 MR. [REDACTED] Yes.
22 (Time noted: 1:45 p.m.)¶
1 THE STATE OF FLORIDA)
2 COUNTY OF PALM BEACH)¶
3 The foregoing certificate was
4 acknowledged before me this _____
5 day of _____ 2010.¶
6 _____
7 Notary Public, State of Florida.
8 My commission No.
9 Expires March 13, 2011.¶