EXHIBIT 1¶
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶
CASE NO. 08-CI V-80119-MARRa¶
JANE DOE NO. 2,¶
Plaintiff,¶
-vs. VOLUME I OF III JEFFREY EPSTEIN. Defendant.¶
1 2 IN ThE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AB¶
9¶
L.M.,¶
Plaintiff,¶
-vs- VOLUME I OF III JEFFREY EPSTEIN, Defendant.¶
Related cases: 10¶
08.80232, 08-08380, 08-80381, 08-80994 11 08-80993, 08-80811, 08-80893, 09-80469 12 VIDEOTAPED DEPOSITION OF 09-80591. 09-80656, 09-80802. 09-81092 13¶
/ 14¶
VID AP D DE ITION OF 15 Wednesday, March 24, 2010 10:37 - 6:51 p.m.¶
16¶
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¶
22 Reported By:¶
Cynthia RPR, FPR 23 Notary POTTrSra, .te of Florida Prose Court Reporting Services¶
Reportedl ii¶
Cynthia RPR. FPR Notary Pu ic, tale of Florida Prose Court Reporting Services 24 Job No.: 1484 Job No.: 1484 25¶
Page 2 Page 4¶
1 IN THE CIRCUIT COURT OF THE ISTH JUDICIAL CIRCUIT 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 2 CASE NO. 502008CA028058XXXXME1 AD 2 CASE No.502008CA0373 I9XXXXMB AB¶
IN AND FOR PALM BEACH COUNTY, FLORIDA CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶
3 3 E.W.,¶
4 5 Plaintiff Plaintiff, 6 VOLUME I OF III 5 7 6 -vs- VOLUME I OF III JEFFREY EPSTEIN, 7 JEFFREY EPSTEIN 8 AND Defendant 8¶
4¶
B.B.¶
9 Defendants. 10 9 11 VIDEOTAPED DEPOSMON OF 10 12 13¶
14 Wednesday, March 24, 2010 10:37 - 6:51 p.m¶
VIDEOTAPED DEPOSITION OF¶
Wednesday, March 24, 2010¶
10:37 - 6:51 p.m. 15 15 16 16 17 250 Australian Avenue South 17 250 Australian Avenue South Suite 1500 Suite 1500 18 West Palm Beach, Florida 33401 18 West Palm Beach, Florida 33401¶
19 19 20 20¶
21 21 22 Reported B . Ili,¶
Cynthia R PR. FPR 23 Notary Public,State of Florida 23 Notary u of Florida 24 Job No.: 1484 24 Job No.: 1484¶
22 Reported By:¶
Cynthiapipl atRePR. FPR Prose Court Reporting Services Prose Court Reporting Services¶
25 25¶
..•••6• COMIWS•Orimmameali-•¶
1 APPEARANCES:
2 On behalf of the Plaintiffs, B.B.:
3 SPENCER T. KUVIN, ESQUIRE
4 LEOPOLD KUVIN
5 2925 PGA Boulevard
Suite 200
6 Palm Beach Gardens, Florida 33410
Phone: 561.515.1400
7 On behalf of the Plaintiffs, L.M., E.W. and
Jane Doe:
8
9 MATTHEW WEISSING, ESQUIRE
10 [REDACTED] JAFFE, WEISSING, [REDACTED]
11 FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue
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)¶
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1 Appearances continued...
2 On behalf of the Plaintiff, Jane Doe II:
3 ISIDRO MANUEL [REDACTED], ESQUIRE
4 [REDACTED], ELKINS & BOEHRINGER
West Palm Beach, Florida 33401
Phone: 561.832.8033
5
6
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
12
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
16
17
18
19
20 ALSO PRESENT:
21 Jessica Cadwell, Paralegal
Burman, Critton, Luttier & Coleman, P.A.
22 [REDACTED] Kozak, Videographer
Prose Court Reporting Services
23
24
25¶
1 PROCEEDINGS
2
3 THE VIDEOGRAPHER: We are now on video
record. This is Media No. 1 in the videotaped
deposition of [REDACTED] in the matter of
4 Jane Doe versus Jeffrey Epstein, et al. Today
5 is Wednesday, March 24th, 2010. It is
6 10:36 a.m. We are here at Prose Court
7 Reporting, 250 South Australian Avenue, West
8 Palm Beach, Florida.
9 My name is Joe Kozak. I'm the
10 videographer. The reporter is Cindy
11 [REDACTED] from Prose Court Reporting Agency.
12 [REDACTED]
13 Would counsel please introduce
14 yourselves, and then the court reporter
15 will swear in the witness.
16
17 MR. KUVIN: Good morning. Spencer Kuvin
18 on behalf of one of the Plaintiffs.
19
20 MR. HOROWITZ: Adam Horowitz on behalf of
Jane Does 2 through 8. And just for the record
21 purposes, the deposition is also being taken in
22 the federal cases, I believe, case being
MR. KUVIN: Good morning. Spencer Kuvin
23 on behalf of one of the Plaintiffs.
24
25 MR. WEISSING: Matt Weissing on behalf of
three of the Plaintiffs.¶
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 Sid= for Jane Doe, 2 Roman Numeral II. 3 MR. GOLDBERGER: Jack Goldberger on behalf 4 of Jeffrey Epstein. 5 MS. CADWELL: Jessica Cadwell, paralegal, 6 on behalf of Jeffrey Epstein. 7 MR. RHEINHART: Bruce Rheinhart on behalf 8 of the witness. MR. KUVIN: Kathy, your turn. MS. EZELL: Okay. Kathy Ezell and Amy Ederi on behalf of Plaintiff, Jane Doe 103. Thereupon, Having been first duly sworn or affirmed, was examined and testified as follows: DIRECT EXAMINATION BY MR. KUVIN: Q. Good morning. A. Morning. Q. Could ou ive us your full name, please. A. Q. Do you have a middle name? A. Lynnelle. Q. Would you spell that for us? A.¶
iS J¶
Q. What's your current address? MR. RHEINHART: I'm going to instruct the witness not to answer that question on the basis of her Fifth and 14th Amendment privileges against self-incrimination. MR. KUVIN: Okay. We had spoken before with respect to there are likely going to be answers similar to that throughout this deposition. I have agreed to a procedure that we can do a shortened answer. However you want to handle that, I leave it up to you. But I do agree that whatever the shortened answer is, that it will satisfy the length, lengthy answer that she would like to give. So, do we want to do that with this question, or how do you want to handle that procedurally? MR. RHEINHART: Well, I think I have given the instruction. I think she, will give her the same instruction in the future to the extent that its relevant, and I think that if we can all just agree that if she simply says orl simply say "The Fifth Amendment," that will qualify as giving a sufficient answer to - as a matter oflaw, and will invoke that¶
1 privilege. 2 MR. KUVIN: I'll agree with that 3 procedure. 4 MR. RHEINHART: Anyone object to that 5 procedure? 6 MR. GOLDBERGER: Actually I think if, in 7 fact, this deposition is used in a trial, I 8 think you would want the lengthier answer as 9 being the answer that is played to the jury. 10 So either you guys can agree that it gets cut 11 in or she's going to have to -- I can't tell 12 you what to do, but I would suggest that she 13 give the lengthier answer each time. 14 But there's got to be a way that you 15 guys can reach an agreement though, that 16 from a technology perspective, that the 17 lengthy answer that she just gave would be 18 used during any trial testimony. Can that 19 be done? 20 MR. KUVIN: I don't know procedurally 21 whether it can be done. 22 MR. GOLDBERGER: I think -- 23 MR. KUVIN: I don't know that, well — 24 MR. GOLDBERGER: And again, it's not my, 25 it's not my deal. I'm just telling you how¶
1 we've done it in the past. 2 MR. KUVIN: I hear you, and I have a 3 number of issues primary, primarily of which 4 that you're not here to represent anyone 5 currently. 6 MR. GOLDBERGER: Yeah, I am. Pm 7 actually, I'm actually here representing 8 Jeffrey Epstein, so... 9 MR. KUVIN: Okay. With respect to all the 10 civil cases, though, you're not here to 11 represent anyone, so — 12 MR. GOLDBERGER: Yes, I am. 13 MR. KUVIN: With the exception — 14 MR. GOLDBERGER: I represent — I am -- I 15 don't mean to interrupt you, but I am counsel 16 of record in the civil cases. 17 MR. KUVIN: Okay. Okay. 18 MR. RHEINHART: If we have a stipulation, 19 what's the problem? Are you -- 20 MR. KUVIN: There is none. 21 MR. RHEINHART: — worried about a waiver? 22 MR. GOLDBERGER: No, I'm not worried about 23 that at all. I'm worried about what is played 24 to a jury if this gets tried. 25 MR. KUVIN: Okay. And I appreciate you¶
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.¶
I¶
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¶