EXHIBIT 8¶
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA¶
CASE NO. 08-CIV-80119-MARRA [REDACTED]¶
JANE DOE NO. 2,
Plaintiff,¶
-vs- VOLUME I OF III
JEFFREY EPSTEIN,
Defendant.¶
Related cases:
08-80232, 08-08380, 08-80381, 08-80994
(08-80993, 08-80811, 08-80893, 09-80469
09-80591, 09-80656, 09-80802, 09-81092¶
VIDEOTAPED DEPOSITION OF
[REDACTED]¶
Wednesday, March 24, 2010
10:37 - 6:51 p.m.¶
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401¶
Reported By:
Cynthia [REDACTED] RPR, FPR
Notary Public, State of Florida
Prose Court Reporting Services
Job No.: 1484¶
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 502008CA028058XXXXMB AD¶
E.W.,¶
-vs- Plaintiff,
VOLUME I OF III
JEFFREY EPSTEIN,
Defendant.¶
VIDEOTAPED DEPOSITION OF
SARAH KELLEN¶
Wednesday, March 24, 2010
10:37 - 6:51 p.m.¶
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401¶
Reported By:
Cynthia [REDACTED] RPR, FPR
Notary Public, State of Florida
Prose Court Reporting Services
Job No.: 1484¶
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 502008CA028051XXXXMB AB¶
L.M.,
Plaintiff,
-vs- VOLUME I OF III
JEFFREY EPSTEIN,
Defendant.¶
VIDEOTAPED DEPOSITION OF
[REDACTED]¶
Wednesday, March 24, 2010
10:37 - 6:51 p.m.¶
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401¶
Reported By:
Cynthia [REDACTED] RPR, FPR
Notary Public, State of Florida
Prose Court Reporting Services
Job No.: 1484¶
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO.502008CA037319XXXXMB AB¶
B.B.¶
-vs- VOLUME I OF III
JEFFREY EPSTEIN,
AND
Defendants.¶
VIDEOTAPED DEPOSITION OF
[REDACTED]¶
Wednesday, March 24, 2010
10:37 - 6:51 p.m.¶
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401¶
Reported By:
Cynthia [REDACTED] RPR, FPR
Notary Public, State of Florida
Prose Court Reporting Services
Job No.: 1484¶
| 1 | Page 21 answer the question based on her Fifth | Page 23 | |
|---|---|---|---|
| BY AIR. KUVIN • | 1 | ||
| Jeffrey Epstein's home located on El Brill° Way on | 1 | ||
| Palm Beach Island? | 2 | ||
| MR. RHEINHAR I.: Object to the form of tho | 2 | ||
| Amendment privilege. | 1 | witness, and I will instruct the witness not to | |
| THE WITNESS: On the instruction of my | 2 | answer based on her Fifth Amendment privilege. | |
| 3 | TIIE WITNESS. On the insuuction of my | ||
| lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN. Q. Who introduced you to Jeffrey Epstein the first time that you met him? MR. RHEINIIART: Same instruction. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Did Ghislaine Maxwell introduce you to Jeffrey Epstein for the first time? MR. RI lEINHART: Same instruction. THE WITNESS: On the instruction of my lawyer. I must invoke my Fifth Amendment tight. | 4 | lawyer, I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Would you agree with me that Jeffrey Epstein owns numerous planes, private planes? MR. RHEINHART'• Instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right BY MR. KUVIN: Q. And you've been on every one of those private planes; isn't that true? MR. RHEINHART: Object to the form. It | |
| 7 | assumes facts not before the witness, and I | ||
| Q. When was the fret time you were in | 8 | will instruct the witness not to answer based | |
| 9 | on her Fifth Amendment privilege. | ||
| question as compound and assuming facts not before the witness. And I instruct the witness not to answer based on her Fifth Amendment privilege. Page 22 | 0 | THE WITNESS: On the instruction of my lawyer. I must int 'Ike my Fifth Amendment right. BY MR. KUVIN: Q. Ma'am, isn't it true that you've seen the passenger manifest for Jeffrey Epstein's plane? MR. ItHEINHARI: Object to the form. It Page 24 | |
| 1 | THE WITNESS: On the instruction of my | ||
| 2 | lawyer, I must invoke my Fifth Amendment right. | ||
| 3 | BY MR. KUVIN: | ||
| 4 | Q. Would you agree with me that | ||
| 5 | Jeffrey Epstein owns a home at 358 El Brillo Way. | ||
| 7 | MR. RHEINHART: Instruct the witness not | ||
| 8 | to answer based ou her Filth Amendment | ||
| 9 | privilege. | ||
| 1t, | TIIE WITNESS: On instruction of my | ||
| 11 | counsel. I must invoke my Fifth Amendment | ||
| 2 | right. | ||
| 13 | BY MR. KUVIN: | ||
| 14 | Q. Would you agree with me that you been | ||
| 15 | in that home numerous times? | ||
| 16 | MR. RHEINHART: Instruct the witness not | ||
| 17 | to answer the question based on her Fifth | ||
| 18 | Atnendment privilege. | ||
| 19 | THE WITNESS: On instruction of my lawyer, | ||
| 20 | I must invoke my Fifth Amendment right. | ||
| 21 | BY MR. KUVIN: | ||
| 22 | Q. Would you agree with me that you have gone | ||
| 23 | on Jellity Epstein's plane numerous times? | ||
| 27: | MR. RHEINFIART: Object to the form. It | ||
| 25 | assumes facts that arc not present for the | ||
| 1 | assumes facts that are not established as known | ||
| 2 | to this witness, and I instruct the witness not | ||
| 3 | to answer the question based on her Fifth | ||
| 4 | Amendment privilege. | ||
| 5 | TIIE WITNESS: On the instruction of my | ||
| Palm Beach Island. Florida? | 6 | lawyer. I must invoke my Fifth Amendment right. | |
| '1 | MR. KUVIN: Let me show you what we'll | ||
| 8 | muck as Exhibit 2. | ||
| 10 | Exhibn No 2 was marked for | ||
| 11 | identification) | ||
| 12 | MR. KUVIN: Thank you. | ||
| 13 | MR. RHEINHART: Do you want to zoom in on | ||
| 14 | it like you did the last time? | ||
| 15 | MR. KUVIN• No, that's fine. | ||
| 16 | MR. RI lEINHART Take your time. | ||
| 17 | MR. KlIVIN7 And flip through. | ||
| 18 | BY MR. KUVIN: | ||
| 19 | Q. All right. =I, would you agree with me | ||
| 20 | that this is a passenget nunifest for one or | ||
| 21 | Jeffrey Epstein's airplanes? | ||
| 22 | MR. RHEINIIART: Instruct the witness not | ||
| 23 | to answer the question based on her Fifth | ||
| 24 | Amendment privilege. | ||
| 25 | THE WITNESS: On the instruction of my |
(561) 632-75U0¶
6 (Pages 21 to 24)¶
PROSE COURT REPORTING AGENCY, INC. (561) 532-7506¶
1 THE VIDEOCIRAPHER. We're now on video I 2 record at 11:01 a m. 3 MR. KUVIN: Just for the video record and 4 for the written record Katherine Ezell and Amy 5 Ederi have now appeared and are present in 6 person. 7 MR. GOLDBERGER: Just one more matter for the record. Jack Goldberger, on behalf of 9 Jeffrey Epstein. Rather than impose a form 10 objection to every question, I think we have I 1 reached an agreement that on behalf of 12 Mr. Epstein. I am adopting the form objections 3 that Mr. Rheinhan is making on behalf of his client mine pro tune to the beginning of this 5 deposition. 16 MR. KUVIN: No objection. 17 MR. GOLDBERGER• Okay 18 BY MR KUVIN: 19 Q. All right. All right. S would 20 you agree with me that there was art ageement 21 between Jeffrey Epstein, Chislaine Maxwell 22 Jean-Luc Brunel, yourself and to 23 bring in girls from out of state that were underage? 24 MR. RHEINHART Object to the form of the ;5 question as leading, as compound, and instruct¶
the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my 4 lawyer I must invoke my Fifth Amendment right. BY MR. KUVIN: 6 Q. Would you agree with me that there was an 7 agreement between Jefficy Epstein, 8 Ohislaine Maxwell, lea -Luc Brunel, yourself and 9 Nadia Marvinkova to bring in girls that were 10 underage from out of state for sexual contact? 11 MR. RHEINHART: Object to the Conn of the 12 question as leading and compound, and I 13 instinct the witness not to answer based on her 14 Fifth Amendment privilege. 15 THE WIl'NESS: On the instruction of my 16 lawyer I must invoke my Fifth Amendment 17 privilege. 18 BY MR. KUVIN: 19 Q. All right. Let me :how you what we've 2:2 preinarked as Plaintiffs Exhibit 3. Do you 21 recognize this as the passenger manifest for one of 22 Jeffrey Epstein's planes? 23 MR. RHEINFIART: I object to the form of 24 the question. It assumes facts that this .5 witness. evidence that this witness has no¶
1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 personal knowledge and instruct het not to answer based on her Fifth Amendment privilege. It's also compound. THE WITNESS: On the instruction of my lawyer I must invoke my Filth Amendment privilege. BY MR. KUVIN: Q. The witness says that you may not have knowledge or we don't know whether you have knowledge regarding this passenger manifest, so let me ask you, do you have any knowledge about this • passenger manifest? MR. RHEINHART. Object to the form of the question as ambiguous as to this and what a manifest is, and also her knowledge, and I will instruct her not to answer based on her Fifth Amendment privilege. THE. WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. Based on the objection, do you know what a manifest is? MR. RHEINHART: Object to the form of the question as ambiguous and instruct her not to¶
1 2 3 4 5 6 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer I must invoke my Fifth Amendment right. BY MR. KUVIN! Q. I lave you heard the word -manifests before? MR. RHEINHART: I'll instruct 1114 witness ' not to answer based on her Filth Amendment privilege. nib: WITNESS: On the instruction of my lawyer I must invoke my Fifth Amendment right • BY MR. KUVIN: Q. Would you agree with me. =, that you have seen this passenger manifest, listed as Exhibit 3. in the past? MR. RHEINHART: I'll instruct the witness not to slum cr based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer I must invoke my Fifth Amendment right. BY MR. KUVIN: Q. Who is MR. RHEINHAR f: I'll instruct the witness not to answer based on her Filth Amendment privilege. 1HE WITNESS: On the instruction of my¶
| 2 3 4 5 6 7 8 10 11 12 13 14 15 16 19 20 21 22 23 24 | Page 97 Page 99 MR. RHEINHART: Same ins:ruction. 1 assumes facts that have not been established THE WITNESS: On the instruction of my 2 and it's compound. lawyer, I must invoke my Fifth Amendment 3 THE WITNESS: On the instruction of my privilege. 4 lawyer, I must invoke my Fifth Amendment BY MR. KUVIN: 5 privilege. Q. Have you ever worked as a professional 6 MR. RHEINHART: And to clarify the model? 7 objection is that it assumes that she's ever MR RHUNIIART: May I consult? 8 met or knows anything about Jean-Luc Brunel. MR. KUVIN: Sum. 9 BY MR. KUVIN: 10 Q. Were you ever promised anything regarding MR. RHEINHART: You can answer the question. 11 your ;nodeling caret by Jeffrey Epstein? 12 MR. RHEP4TIART: Same objection, instruct THE WITNESS: Yes. BY MR. K UV IN. 13 the witness not to answer. Q. When? 14 THE WITNESS: On the instruction of my A I don't remember. I don't remember the dates. 15 lawyer, I must invoke my Fifth Amendment It was at least maybe tea yean ago. 16 privilege. 1'7 BY MR. KUVIN: Q. And you're how old now? 18 Q. You would agree with me that there is a MR. RHEINHART: HI instruct the witness not to answer the question. Nice try. 19 financial arrangement between Jean-Luc Brunel and 20 Jeffrey Epstein. do you not? Instruct you not to answer based on 21 MR. RHEINHART! Objection. It assumes she your Fifth Amendment privilege. 22 has any knowledge of either Mr. Epstein or THE WITNESS: On the instruction of my 23 Mr. Brunel, and as to that she is going to lawyer, Tm going to invoke my Fifth Amendment 24 mvoke her Fifth Amendment privilege The privilege. question is compound and therefore ambiguous. |
|---|---|
| 25 | MR KUVIN: I'm just trying to find out. 25 Page 1011 Page 9d |
| 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? |
| 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. |
| 1 I | BY MR. KUVIN: |
| 12 | Q. What is your understanding of |
| 13 | Mr. Epstent'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. |
| 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 THE WITNESS: On the instruction of my | |
| 2 lawyer, I must invoke my Fifth Amendment | |
| 3 privilege. | |
| 4 BY MR. KUVIN: | |
| 5 Q. Would you agree with me that Ghislaine Maxwell provides underage girls to MR. RHEINHART: Instruct the witness not Mr. Epstein fee 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. THE WITNESS: Upon the instruction of my (Plaintiff's 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. |
(561) 832-7500¶
25 (Pages 97 to 100)¶
PROSE COURT REPORTING AGENCY, 1NC. (561) 832-7506¶
1 reasonably designed to lead to discoverable evidence. 3 BY MS. EZELL: 4 Q. Did you facilitate these acts as well as 5 assisting Mr. Epstein in avoiding police detection? MR. REINHART: Same instruction. 7 BY MS. EZELL; Q. Do you know when and by whom the computers 9 were rentovcel fioni the El Bu lb mansion? 10 MR. REINHART: Objection to the fonn, lack of 11 foundation. and it also assumes knowledge of a 12 place known as the El Bgllo mansion. So instruct 13 the witness not to answer the question based on the 14 Fifth Amendment. 15 THE WITNESS: At the instruction of my lawyer. 16 I must invoke my Fifth Amendment right. 1 / BY MS. EZELL: 12 Q. Was Jane No. 103 invited to just ciaMe and hang 19 out at the El Bulk mansion? MR. REINHART: Objection to the form. same as 21 the previous question. It assumes knowledge of a 22 place known as the El Brillo mansion and a prison 23 by the name of lam No. 103. It is compound add 7 4 lacking in foundation. 23 TILE WITNESS. at the instruction of-my lawyer, _ .¶
I must invoke my Fifth Amendment right. BY MS. EZELL: Q. Have you called any girls under the age of I X 4 in Palm Bach or West Palm Beach in the last six years? MR. REINHAR1: For any purpose? 6 MS EZELL: Yes. 7 THE WITNESS: Can you repeat the question? 8 BY MS. EZELL; 9 Q. Have you called any girls under the age of IS 10 in Palm Beach or Wcst Palm Beach in the last six years? MR. REINILIRT: You can answer that yes or no. I2 if you know. 11 THE WITNESS: I don't think so. 14 MS EZELL: Idons have any other questions. 15 Thank you. 1a THE VIDEOGRAPHER: All set? 17 MR. REINHART: Yes 18 THE VIDEOGRAPHER: This concludes today's 19 videotape dccessition of 20 MR. REINHAR r: I told on, I'm sorry, one last 21 thing. Since you're the last defense person or plaintiffs lawyer standing, I guess you noxl re 23 advise her she has the right to read or waive on 24 the record. 2S MS. EZELL- You do have the right to read this¶
8 9 1" 11 12 13 14 15 16 17 18 19 20 21 22 23 29 25 1 deposition or you may waive reading and allow the 2 court reporter to simply type it up and distribute 3 it to the lawyers who order it 4 Do you choose to read or waive? 5 THE WITNESS: Waive. 6 MS. EZELL: Thank you. 7 MR. REINHART: Thank you. THE VIDEOGRAPHER. Oka, this concludes turlay12/ videotape deposition of The tune is 18:51. (Witness excused.) (Deposition was concluded )¶
la in :.10 21 22 :3 1 CLItlIellA I DIE ST It. Ut FLORIDA 3 oarwry OF PAIN BEACH 4 5 I, Rectal W. Br idgo, Raglan:n.1 Plesfessional Reporter. Honda Prefeasionsi Reporter and Notary 6 Public in and for the State of Florida at largo, do Nein meth* not I was audiosInd to and did nport sold Jo:position in stenotype, and that the foregoing pages so; a me and correct uatncrpboo of my 6 shorthand notes of said deposition. 9 I Pother sanity this mad &coat= was Sten as the time and place beranabow ICI fonli.md 1.1 that Me ramp of said tkposmor vat cononamed and ompieted m berainatans in out 11 I funha usitify that t am not snonary or :2 monad of any of the portico,. nor am I a mistisc of sw.ploscs of on, idiom) or al of potty connetted 13 oah the action nor an I Runt/ally miateated in the what :4 The foregoing certification of ilt;, iransermt 15 does not apply to any 'eradiation urine same by any train unless. under the data control anchor direction of the candying seignior. Dated this 9th day &April, atitiaar. FrR¶
- (Pages 445 to 443)
i5C1) 832-7500 PROSE COURT REPORT:NG AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201.272.617.4627) 005d14994cd8-4599-a2a04d38827b0/3c8¶