EFTA00182657

Deposition from 2010-02-17, part 2
Duration: 47:45 · 521 segments
Speakers:
SPEAKER_00 SPEAKER_01 SPEAKER_02 SPEAKER_03 SPEAKER_04 SPEAKER_05 UNKNOWN
[0:02]SPEAKER_01:We're back on a video record at 1.15 p.m. Stepson, as it relates to the charges you pled guilty to, are you saying today that those females that you interacted with sexually were prostitutes prior to meeting you?
[0:26]SPEAKER_02:I'm saying I pled guilty to the solicitation of prostitution.
[0:31]SPEAKER_01:Right, and you would certainly agree that that would require yourself and one other individual for that act of prostitution, correct?
[0:41]SPEAKER_02:Form.
[0:44]SPEAKER_02:I plead guilty to solicitation of prostitution.
[0:48]SPEAKER_01:And are you saying that those females that were the victims, at least listed as victims by the state, were prostitutes prior to meeting you?
[1:00]SPEAKER_01:Form.
[1:02]SPEAKER_01:Vague.
[1:03]SPEAKER_02:Irrelevant.
[1:05]SPEAKER_02:I plead guilty to solicitation of prostitution.
[1:09]SPEAKER_00:Do you have any remorse for your actions against these victims that led to your plea of guilty?
[1:18]SPEAKER_02:Form argumentative.
[1:20]SPEAKER_02:I plead guilty to solicitation of prostitution.
[1:23]SPEAKER_02:Not underage prostitution, simply prostitution.
[1:28]SPEAKER_01:Are you saying now that the subjects of that which we're calling victims were not underage when you engaged in sex with them?
[1:37]SPEAKER_03:Form argumentative speculation and assumes facts not in evidence as well as mischaracterizes the witness's testimony.
[1:45]SPEAKER_02:I plead guilty to solicitation of prostitution.
[1:49]SPEAKER_02:Not underage prostitution, solicitation of prostitution.
[1:52]SPEAKER_01:I was of the impression that you plead guilty to a second-degree felony, that being procuring a minor for the purposes of prostitution.
[2:01]SPEAKER_00:That's correct.
[2:02]SPEAKER_00:Okay, so a minor is somebody under the age of 18, and I'm asking for the guilty plea...
[2:11]SPEAKER_01:Related to that count, are you at all remorseful for your interactions with that minor?
[2:16]SPEAKER_01:Same objections.
[2:18]SPEAKER_00:What minor?
[2:20]SPEAKER_00:The charge is procuring a minor.
[2:23]SPEAKER_00:You tell me, who was that minor?
[2:26]SPEAKER_00:I don't know.
[2:30]SPEAKER_00:You were never told during the state attorney's prosecution of you who this person was?
[2:42]SPEAKER_00:No.
[2:47]SPEAKER_00:Why did you plead guilty?
[2:57]SPEAKER_02:Today, my counsel has instructed me to assert my 14th Amendment, 6th Amendment, and 5th Amendment right.
[3:06]SPEAKER_02:And if I do not, in fact, if I answer that question, if I can answer that question, I potentially risk losing my effective counsel and representation.
[3:19]SPEAKER_01:In fact, you told many of these underage minor females not to tell anybody what happened with you in the house or else they would be in trouble.
[3:29]SPEAKER_01:Isn't that true?
[3:30]SPEAKER_01:Four.
[3:33]SPEAKER_02:I'd like to answer that question as well as the other questions.
[3:37]SPEAKER_02:However, my counsel has advised me that today I must assert my 14th Amendment, 6th Amendment, and 5th Amendment rights under the U.S. Constitution.
[3:49]SPEAKER_01:And in fact, those underage minor females that have pursued cases against you and have come forward with what happened inside your house,
[4:07]SPEAKER_01:You have, strike that, the underage minor females that have come forward with information about your sexual interactions with them have been investigated, harassed, humiliated in an effort for you to intimidate them to go away.
[4:30]SPEAKER_01:Is that true?
[4:32]SPEAKER_01:Objection.
[4:33]SPEAKER_03:Argumentative, speculative.
[4:36]SPEAKER_03:Compound, it's overbroad.
[4:38]SPEAKER_03:And it seems facts, not evidence.
[4:44]SPEAKER_01:Can you repeat the question?
[4:45]SPEAKER_01:Sure.
[4:46]SPEAKER_01:Any underage minor female that you engaged in sexual activity with and that has now pursued a lawsuit against you, isn't it true that you've spent a lot of money and a lot of resources investigating them in an effort to intimidate them and hopefully make them go away?
[5:03]SPEAKER_01:Same objections.
[5:07]SPEAKER_02:I believe your client's testimony changed dramatically when she joined up with you and your law firm accused of fraud.
[5:15]SPEAKER_02:When she decided to change her testimony, at least from what these statements said, both to the police and to the FBI, and decided to seek money.
[5:25]SPEAKER_02:However, anything above that or beyond that, I'm going to have to, in fact, assert my Fifth Amendment, Sixth Amendment, and Fourteenth Amendment rights as directed by my competent counsel.
[5:37]SPEAKER_02:Unfortunately, they have told me that if I don't, I risk losing their representation.
[5:42]SPEAKER_01:All right, I'm going to give you a chance here since you keep bringing up her statement to the FBI as opposed to her sworn testimony for 13 hours under oath in this case.
[5:53]SPEAKER_00:Are you saying that the sworn testimony to the FBI was in fact the truth?
[6:00]SPEAKER_02:What I'm saying is it seems her testimony has changed dramatically after she joined your firm.
[6:05]SPEAKER_02:That's all.
[6:07]SPEAKER_00:Okay.
[6:09]SPEAKER_00:Irrespective of her testimony, you've read her testimony to the FBI, and you've watched her deposition when it was being taken.
[6:26]SPEAKER_00:You're making assumptions.
[6:28]SPEAKER_00:I'm sorry.
[6:32]SPEAKER_00:So you just go ahead and let him finish the question.
[6:34]SPEAKER_00:And then I'll object and then you'll respond.
[6:37]SPEAKER_00:Which are you saying is the truthful testimony?
[6:42]SPEAKER_00:Her statement to the FBI or the videotape deposition that you watched?
[6:47]SPEAKER_00:I'm going to object for him.
[6:51]SPEAKER_02:What I've said, and I think I repeat myself, is that until she joined your firm and started to seek money, her testimony was different.
[6:59]SPEAKER_02:That's my understanding.
[7:02]SPEAKER_00:Are you denying any sexual involvement with Tatum Miller at this time?
[7:09]SPEAKER_02:I'd like to answer that question.
[7:12]SPEAKER_02:I'd like to answer, as with most of your questions here today.
[7:16]SPEAKER_02:However, my attorneys have advised me that I must assert my rights under the Sixth Amendment, Fourteenth Amendment, and Fifth Amendment, no matter how much I'd like to answer that question, or potentially risk losing my counsel.
[7:33]SPEAKER_01:Isn't your game plan with all of these civil lawsuits that have been filed against you to spend as much money as you can to investigate and harass these young women into hopefully dropping the lawsuits against you?
[7:46]SPEAKER_03:Objection.
[7:48]SPEAKER_03:Irrelevance.
[7:49]SPEAKER_03:Move to strike.
[7:52]SPEAKER_03:It's argumentative.
[7:52]SPEAKER_03:It's harassing.
[7:56]SPEAKER_02:I'd like to answer that question.
[7:59]SPEAKER_02:I think you know the answer to that question.
[8:01]SPEAKER_00:Yes.
[8:02]SPEAKER_02:However, today, my attorneys advise me I must assert my Sixth Amendment rights, my Fourteenth Amendment rights, and my Fifth Amendment rights.
[8:12]SPEAKER_01:And recently...
[8:15]SPEAKER_01:Well, strike that.
[8:17]SPEAKER_01:You don't have any remorse for the sexual abuse that you committed against Tatum Miller, do you?
[8:28]SPEAKER_01:Objection.
[8:30]SPEAKER_03:It's argumentative.
[8:32]SPEAKER_03:It's harassing.
[8:34]SPEAKER_03:It's belief confined underneath the judge's order.
[8:39]SPEAKER_03:And it assumes facts, not in evidence.
[8:43]SPEAKER_02:That being said, I'd like to answer that question today, but my attorneys have advised me that I must assert my 14th Amendment rights, my 5th Amendment rights, and my 6th Amendment rights.
[8:56]SPEAKER_01:In fact, you recently sued Tatum Miller, didn't you?
[9:03]SPEAKER_02:Yes.
[9:05]SPEAKER_02:And you and your firm that's been accused of the largest fraud
[9:10]SPEAKER_02:in Florida's history, described by the U.S. attorney as a criminal enterprise involved in money laundering, conspiracy to commit one crime, excuse me, mail fraud, conspiracy to commit wire fraud.
[9:23]SPEAKER_02:Yes, I sued you, your firm, and Tatum Miller.
[9:29]SPEAKER_01:Tell the jury the basis or the evidence that you have to support the allegations in the complaint against Tatum Miller.
[9:38]SPEAKER_03:Okay, I'm going to instruct the witness not to answer that question in this medium, as it is wholly irrelevant currently as worded to this particular lawsuit.
[9:50]SPEAKER_01:Just so that you can rethink that position, the lack of remorse goes to punitive damages that is an aspect of the case that Tata Miller has against Mr. Epstein.
[10:03]SPEAKER_03:This lawsuit, the current one that Mr. Epstein is noticed for, and the lawsuit in which Mr. Epstein has filed against former Rothstein, Rosenfeld, Nadler, Tata Miller, and Mr. Brad Edwards,
[10:20]SPEAKER_03:is not proper for this medium.
[10:23]SPEAKER_03:I understand your position.
[10:25]SPEAKER_03:In that regard, I'm going to instruct him not to answer any questions relative to that lawsuit because of that objection, as well as it is my understanding that...
[10:38]SPEAKER_03:Mr. Scarola has set Mr. Epstein's deposition, I believe, either early next week or mid-March on the case of Epstein v. RRA.
[10:53]SPEAKER_03:Ross St. Rosenfeld, Mr. Edwards, as well as Tatum Miller.
[10:57]SPEAKER_03:Therefore, when that time approaches, that will be the appropriate time for those type of questions related to that lawsuit.
[11:04]SPEAKER_01:I understand your position completely, Mr. Pike.
[11:08]SPEAKER_01:But as it relates to, obviously, Tatum Miller sued you, making the allegations that you sexually molested her from when she was 13 years old to 16 years old, and now you've sued her in something that is seemingly related to that case.
[11:24]SPEAKER_01:And I just want to understand what your factual basis is or what evidence you're using to support your lawsuit against Tatum Miller so that the jury can evaluate whether that is evidence of lack of remorse that would go to punitive damages claims that Tatum Miller has against you.
[11:40]SPEAKER_03:And I would instruct him not to answer that question for the same reasons stated.
[11:45]SPEAKER_00:Let's mark that.
[11:58]SPEAKER_01:Is it your feeling that because you are wealthy and these children are poor, that you are entitled to sexually abuse them?
[12:09]SPEAKER_01:Argumentative.
[12:10]SPEAKER_01:And speaking about these children, including Tatum Miller?
[12:14]SPEAKER_01:Argumentative, speculative.
[12:16]SPEAKER_01:It's compound.
[12:17]SPEAKER_03:It's vague.
[12:18]SPEAKER_03:It assumes facts not evident.
[12:20]SPEAKER_02:Yes, and in keeping with your firm's propensity to file fallacious, manufactured, sexually charged cases based on nothing but thin air, accused by the U.S. Attorney of the largest fraud in South Florida's history by manufacturing sexual cases, I would like to answer each and every one of your questions, including why I sued you.
[12:45]SPEAKER_02:But today I'm not going to be able to.
[12:48]SPEAKER_02:So I'm going to have to simply listen to my counsel and assert my Sixth Amendment, Fourteenth Amendment, and Fifth Amendment right.
[12:56]SPEAKER_01:And this answer that you keep reciting about the Rothstein-Rosenfeld-Adler firm.
[13:05]SPEAKER_01:You do know who they are, right?
[13:07]SPEAKER_01:You are aware, obviously, that all of the lawsuits that were filed against you, including ******,
[13:15]SPEAKER_01:were filed at least a year before, or approximately a year, before Rothstein, Rosenfeld, Adler had any of these cases.
[13:25]SPEAKER_01:You're aware of that, right?
[13:29]SPEAKER_02:I do not know when Rothstein, Adler got involved in these cases.
[13:34]SPEAKER_02:I do know that the moment they did surface, in fact, I understand that you shared information with all the other attorneys that you so like.
[13:42]SPEAKER_02:The jury should understand that the information gathered, according to the U.S. attorney, by illegal means, has been shared with all the other attorneys that you keep representing and filed cases against me.
[13:54]SPEAKER_02:Yes, I'm aware of that.
[13:56]SPEAKER_01:I don't understand that answer.
[13:57]SPEAKER_01:Excuse me?
[13:59]SPEAKER_03:Do you have a question?
[14:01]SPEAKER_01:I want to understand what his answer is, which is familiar in every single deposition.
[14:05]SPEAKER_01:If you don't understand the answer, clarify the answer.
[14:07]SPEAKER_03:No, you have to ask a question.
[14:09]SPEAKER_03:I did, and he's responding to it.
[14:10]SPEAKER_03:The witness has answered the question.
[14:12]SPEAKER_03:Do you have another question to clarify his answer?
[14:16]SPEAKER_03:Yes, please clarify your answer.
[14:17]SPEAKER_03:I'm going to instruct him not to answer.
[14:19]SPEAKER_03:I don't know.
[14:19]SPEAKER_03:It's vague and confusing.
[14:20]SPEAKER_03:It's narrative.
[14:22]Thank you.
[14:23]SPEAKER_01:Me saying clarify your answer is narrative?
[14:26]SPEAKER_03:Yeah, what do you mean clarify the answer?
[14:27]SPEAKER_01:I didn't hear what he said.
[14:29]SPEAKER_03:Say it again so I can hear it.
[14:31]SPEAKER_03:Would you please read back what Mr. Epstein just testified to Madam Court Reporter?
[15:07]SPEAKER_05:This answer that you keep reciting about the Rothstein, Rosenfeld, Adler firm, you do know who they are, right?
[15:14]SPEAKER_05:Question.
[15:14]SPEAKER_05:You are aware, obviously, that all of the lawsuits that were filed against you, including LM, were filed at least before, filed at least, pardon me, a year before or approximately a year before Rothstein, Rosenfeld, Adler had any of these cases.
[15:32]SPEAKER_05:You're aware of that, right?
[15:34]SPEAKER_05:Objection stated on the record.
[15:35]SPEAKER_05:I do not know when Monsignor Adler got involved in these cases.
[15:43]SPEAKER_05:And the witness goes on to say that the information surfaced and I understand you shared information with all the other attorneys that you so dash dash.
[15:52]SPEAKER_05:The jury should understand the information gathered according to the U.S. attorney by illegal means has been shared with all the other attorneys that you keep representing have filed cases against me.
[16:02]SPEAKER_05:Yes, I'm aware of that.
[16:04]SPEAKER_05:I don't understand.
[16:05]SPEAKER_01:Okay.
[16:07]SPEAKER_03:So there was an answer, a question?
[16:10]SPEAKER_01:Mike, I understand.
[16:11]SPEAKER_01:Okay.
[16:11]SPEAKER_01:I don't understand the answer, but now I know the answer.
[16:20]SPEAKER_01:Okay.
[16:20]SPEAKER_01:At this point in time, please tell the jury, what is your defense of the claims being asserted against you in this lawsuit by ***?
[16:34]SPEAKER_01:I'm going to object.
[16:37]SPEAKER_02:calls for a legal conclusion.
[16:41]SPEAKER_02:What are the claims, sir?
[16:42]SPEAKER_02:Since you're representing Tater Mill, can you tell me what the claims are?
[16:46]SPEAKER_01:Yeah, we've gone through it.
[16:47]SPEAKER_01:She went to your house when she was 13, 14, 15, 16 years old.
[16:51]SPEAKER_01:Is that a claim?
[16:52]SPEAKER_01:She was...
[16:54]SPEAKER_01:She was in your bedroom.
[16:57]SPEAKER_01:You instructed her to get naked.
[17:00]SPEAKER_01:You coerced her into recruiting other underage minor females, roughly 50 or so more.
[17:07]SPEAKER_01:These are all claims that have amounted to various counts, coercion into prostitution, intentional infliction of emotional distress, battery, committing various crimes against her.
[17:18]SPEAKER_01:What are your defenses to that?
[17:20]SPEAKER_01:I mean, normal defenses are, I didn't do it.
[17:23]SPEAKER_03:um i did it but it didn't hurt her and we're trying to understand so we so we understand how to put uh provide this case to the jury what are your defenses to these allegations i'm going to object to this line of questioning it's compound as worded it could call for the disclosure of attorney client information as well as work product and i believe in this particular case
[17:49]SPEAKER_03:There is a document filed answering affirmative defenses and those affirmative defenses are set forth and the document there speaks for itself.
[18:01]SPEAKER_01:Okay.
[18:02]SPEAKER_01:The document speaks for itself.
[18:05]SPEAKER_01:So you agree with the affirmative defenses that were filed in your case?
[18:09]SPEAKER_01:If you were to testify, we could expect that to be your testimony?
[18:12]SPEAKER_01:That's not what the witness testified to.
[18:14]SPEAKER_03:The witness testified that the document speaks for itself.
[18:17]SPEAKER_03:And, again, I'm going to object to attorney-client work product and instruct the witness not to answer.
[18:22]SPEAKER_01:Okay, I'm not asking what your legal defense is.
[18:25]SPEAKER_01:I'm asking what is your response to those claims?
[18:28]SPEAKER_02:What is your personal response?
[18:31]SPEAKER_02:I'd like to respond to that question.
[18:33]SPEAKER_02:I'd like to respond today to that question.
[18:37]SPEAKER_02:However, today my attorneys have told me that I cannot respond.
[18:41]SPEAKER_02:They've asked me to assert my 14th Amendment, 6th Amendment, and 5th Amendment rights of the U.S. Constitution, though I would really like to respond, but they told me that if I did so, I lose risking their representation.
[18:59]SPEAKER_01:Okay.
[19:00]SPEAKER_01:I know you've invoked your 5th Amendment rights related to...
[19:03]SPEAKER_01:many of these questions, but isn't it true that you recently contacted at the New York Daily News and spoke with him about the case as well as several of the other girls who have claims against you?
[19:17]SPEAKER_01:Who?
[19:18]SPEAKER_01:New York Daily News.
[19:20]SPEAKER_01:Can you repeat the question?
[19:22]SPEAKER_01:Didn't you recently, within the last year, contact
[19:26]SPEAKER_01:The New York Daily News and discuss these cases that have been filed against you and the allegations made by these various females.
[19:37]SPEAKER_02:I'd like to answer that question, but unfortunately today my attorneys have advised me I cannot.
[19:43]SPEAKER_02:They've advised me I must assert my 14th Amendment, 6th Amendment, and 5th Amendment right.
[19:50]SPEAKER_01:So therefore I will do so.
[19:53]SPEAKER_01:Why is it that you will talk to about this, but you will not talk to the jury about this?
[19:59]SPEAKER_03:Form, argumentative, speculation, it misstates the witness's testimony, it assumes facts, the question assumes facts, not an evidence, and now lacks predicate.
[20:12]SPEAKER_01:Sorry, who's reporter with the New York Daily News?
[20:18]SPEAKER_01:Did you not talk to him?
[20:19]SPEAKER_01:If you didn't talk to him, tell me that.
[20:21]SPEAKER_01:It's fine.
[20:21]SPEAKER_01:Same objections.
[20:24]SPEAKER_02:I'd like to tell you answers to each one of your questions.
[20:27]SPEAKER_02:However, today, my attorneys have demanded that I respond by asserting my 14th Amendment, 6th Amendment, and 5th Amendment privilege.
[20:37]SPEAKER_02:So I'd like to respond.
[20:38]SPEAKER_02:But they said if I do so, I risk losing their representation.
[20:42]SPEAKER_01:Didn't you tell that these underage minors were not victims at all, and that regardless of their age, you did not personally consider them victims?
[20:54]SPEAKER_01:Same objection.
[20:59]SPEAKER_02:I'd like to answer that question, but today, on advice of my counsel, I must have done with mostly each one of your questions.
[21:11]SPEAKER_02:I have to assert my Fifth Amendment, Sixth Amendment and Fourteenth Amendment rights under the U.S. Constitution.
[21:20]SPEAKER_01:You were 51 when ****** was 14 and you were interacting with her sexually.
[21:29]SPEAKER_01:Is it your testimony that despite the disparity in age, you do not consider ****** to be a victim?
[21:37]SPEAKER_03:Argumentative speculation assumes facts, not in evidence.
[21:39]SPEAKER_03:It's compound.
[21:41]SPEAKER_03:Relax, prank it.
[21:43]Okay.
[21:44]SPEAKER_02:Not only does it contradict your own client's statements to the FBI and the sworn testimony, I would like to answer that question.
[21:55]SPEAKER_02:Hopefully one day I can answer that question, but today my attorneys have said I cannot.
[22:00]SPEAKER_02:They advised me I must assert my Sixth Amendment, Fifth Amendment, and Fourth Amendment rights.
[22:06]SPEAKER_01:In the last 10 years, what is the youngest underage minor female that you have interacted with sexually?
[22:14]SPEAKER_03:Argumentative speculation that serves facts, not evidence.
[22:17]SPEAKER_03:Excuse me.
[22:21]SPEAKER_02:The answer to that question is something I'd like to give you an answer to that question today, but my attorneys have advised me I must assert my 14th Amendment rights, my 6th Amendment rights, and 5th Amendment rights.
[22:34]SPEAKER_01:Do you know ****** ring a bell?
[22:38]SPEAKER_01:Okay.
[22:39]SPEAKER_01:Former housekeeper or employee of yours worked at the Palm Beach house?
[22:48]SPEAKER_01:Could.
[22:49]SPEAKER_01:Don't know.
[22:50]SPEAKER_01:Okay.
[22:51]SPEAKER_01:So you would be unable to answer what ****** did for you?
[22:54]SPEAKER_01:Yes.
[22:56]SPEAKER_01:Okay.
[22:56]SPEAKER_01:Are you aware that our investigator spoke with ******, former housekeeper for you or house manager for you out in California?
[23:05]SPEAKER_01:No.
[23:07]SPEAKER_01:No.
[23:13]SPEAKER_01:Any reason why, when asked about the activity that occurred in your house, he would tear up and say, I was hoping to forget everything I saw?
[23:23]SPEAKER_01:Objection.
[23:24]SPEAKER_03:Argumentative.
[23:26]SPEAKER_03:Speculative.
[23:29]SPEAKER_03:And assumes facts, not evidence.
[23:32]SPEAKER_01:Again, it's a question.
[23:32]SPEAKER_01:Is there any reason that when asked, I don't know who he is, it's also hearsay?
[23:40]SPEAKER_04:Okay.
[23:41]SPEAKER_04:Fine.
[23:41]SPEAKER_02:Fine, we'll have the video record at 3.23 p.m. 3.30 now, but a break at 4 gets me out of this.
[23:54]SPEAKER_04:Tell me if you're not tired.
[23:56]SPEAKER_04:We're back in the video record at 3.30 p.m.
[24:04]SPEAKER_01:And this person that I asked you about, is that somebody who has contacted you within the last six months?
[24:18]SPEAKER_01:No.
[24:20]SPEAKER_01:Okay.
[24:20]SPEAKER_01:And in taking a break and thinking about some of these questions, have you remembered who that person is or still no real memory of him at all?
[24:28]SPEAKER_02:No real memory.
[24:30]SPEAKER_01:Best of your knowledge, he never worked for you.
[24:33]SPEAKER_02:Not that I can recall.
[24:35]SPEAKER_02:But there's lots of people who worked for me, so.
[24:37]SPEAKER_01:Okay.
[24:37]SPEAKER_01:Can you tell the jury who the various people are that work for you now?
[24:43]SPEAKER_02:I believe I answered that question already.
[24:47]SPEAKER_01:In that you invoked your Fifth Amendment.
[24:49]SPEAKER_01:That's correct.
[24:53]SPEAKER_01:Have you... Sixth Amendment and Fourteenth Amendment.
[24:56]SPEAKER_01:18th and 21st of November.
[24:58]SPEAKER_01:A little bit of a strike.
[24:59]SPEAKER_01:Okay.
[24:59]SPEAKER_01:Have you... Have you... During this litigation, and by this litigation, I don't only mean the ****** case, I mean the various other lawsuits that have been filed against you by other females alleging sexual misconduct by you against them.
[25:20]SPEAKER_01:Who have you retained attorneys for?
[25:26]SPEAKER_01:What witnesses have you retained attorneys for?
[25:29]SPEAKER_01:Okay.
[25:34]SPEAKER_03:I'm going to object to form.
[25:36]SPEAKER_04:Okay.
[25:36]SPEAKER_03:And I'm going to instruct them not to answer because I don't understand the question.
[25:42]SPEAKER_03:And I... All right.
[25:43]SPEAKER_03:Okay?
[25:44]SPEAKER_01:All right.
[25:45]SPEAKER_01:During this...
[25:47]SPEAKER_01:civil discovery and litigation.
[25:51]SPEAKER_01:Have you paid for and or retained an attorney for any other witnesses?
[26:00]SPEAKER_02:Any other witnesses?
[26:01]SPEAKER_01:Yeah, like I'll give you an example that you may, just to refresh your recollection or tell you what I'm talking about.
[26:06]SPEAKER_01:Luella Rabollo, you know who that is, right?
[26:08]SPEAKER_00:Yes, sir.
[26:09]SPEAKER_00:Okay, she's somebody who works for you now.
[26:11]SPEAKER_00:She's a housekeeper.
[26:12]SPEAKER_00:We took her deposition already.
[26:13]SPEAKER_00:That's at least what her testimony was.
[26:14]SPEAKER_00:For him.
[26:17]SPEAKER_02:I'd like to answer that question, but I'm going to have to assert my 6th Amendment, 14th, and 5th.
[26:23]SPEAKER_01:Okay.
[26:24]SPEAKER_01:That's somebody who has informed us that you paid for and retained an attorney by the name of to represent her during this process.
[26:34]SPEAKER_02:Is that true?
[26:35]SPEAKER_02:Form.
[26:37]SPEAKER_02:I'm going to have to assert my 5th Amendment, 6th Amendment, and 4th Amendment.
[26:41]SPEAKER_01:Right.
[26:41]SPEAKER_01:Other people that have indicated that you've retained and paid for an attorney to represent them are... Have I missed anybody else that during this litigation you've paid for or retained attorneys?
[26:59]SPEAKER_01:Forms and objection.
[27:04]SPEAKER_02:I'm unclear.
[27:05]SPEAKER_02:Are you suggesting I've paid fraternities for all these people?
[27:08]SPEAKER_00:Yes.
[27:12]SPEAKER_02:I'd like to answer those questions today, but on the advice of counsel, I'm going to have to invoke my Sixth Amendment, Fifth Amendment, and Fourteenth Amendment right.
[27:23]SPEAKER_01:And if you have not, tell me which of those on that list that you have not paid for or retained an attorney for.
[27:29]SPEAKER_01:Same objection.
[27:30]SPEAKER_02:Same answer.
[27:32]SPEAKER_02:You're invoking your Fifth Amendment, right?
[27:33]SPEAKER_02:Sixth Amendment.
[27:34]SPEAKER_02:Fourteenth Amendment.
[27:40]SPEAKER_01:Okay.
[27:41]SPEAKER_01:End.
[27:45]SPEAKER_01:Is it a company or is it you personally that is paying for the attorney's fees related to your representation?
[27:56]SPEAKER_03:Okay.
[27:58]SPEAKER_03:I'm going to object to form.
[28:03]SPEAKER_03:I'm going to instruct him not to answer that question based on relevance.
[28:10]SPEAKER_00:It's vague.
[28:10]SPEAKER_03:It's vague also.
[28:13]SPEAKER_01:Okay.
[28:16]SPEAKER_01:Who is writing the check to your attorneys for your representation in this lawsuit?
[28:22]SPEAKER_01:Who's paying the bill?
[28:25]SPEAKER_01:I believe I am.
[28:28]SPEAKER_01:And is it you personally or is this one of your corporations or companies?
[28:33]SPEAKER_01:Form.
[28:34]SPEAKER_01:Speculation.
[28:35]SPEAKER_01:I'm not sure.
[28:37]SPEAKER_01:As you see here today, you're not really sure whether it's coming from one of the other corporations that we've discovered during discovery or it's coming from you personally.
[28:46]SPEAKER_01:Is that correct?
[28:49]SPEAKER_02:That's an answer.
[28:51]SPEAKER_02:I would like the answer, but I'm going to have to invoke my 6th, 4th, and 5th Amendment rights.
[28:56]SPEAKER_01:And as it relates to any of the other witnesses who have had attorneys retained for them, is it also your...
[29:08]SPEAKER_01:response to invoke your Fifth Amendment rights rather than to provide me with an answer as to who is paying the bill for those attorneys?
[29:18]SPEAKER_02:I'd like to answer those questions, but today my attorneys have asked me not to respond to any questions that may be relevant to this lawsuit.
[29:26]SPEAKER_02:So I must follow their advice and invoke the Sixth Amendment, Fourteenth Amendment, and Fifth Amendment right.
[29:32]SPEAKER_01:Have you interacted sexually with any underage minors in the last year while on house arrest or work release from jail?
[29:40]SPEAKER_03:I'm going to object.
[29:44]SPEAKER_02:Argumentative and compound and lax predicate.
[29:48]SPEAKER_02:I'd like to answer that question, but as an advice of counsel, at least today, they've advised me I must invoke my 6th Amendment, 14th, and 5th Amendment rights.
[30:06]SPEAKER_01:Which also overbroad.
[30:12]SPEAKER_01:If me narrowing it down would help you to respond, I will.
[30:16]SPEAKER_01:Okay.
[30:16]SPEAKER_01:Is there any need for that?
[30:18]SPEAKER_01:No.
[30:18]SPEAKER_01:Okay.
[30:20]I'm sorry.
[30:22]SPEAKER_01:Is it your intent to interact sexually with minors in the future?
[30:27]SPEAKER_01:Same objection.
[30:28]SPEAKER_02:I'd like to answer that question.
[30:32]SPEAKER_02:But today, my counsel has advised me I must invoke the rights of the Sixth Amendment, the Fourteenth Amendment, the Fifth Amendment, and the U.S. Constitution.
[30:41]SPEAKER_01:Are you currently treating with a psychologist related to any sex addiction that you have with minors?
[30:52]SPEAKER_02:I'd like to answer that question as well as most of the other questions you asked me today.
[30:59]SPEAKER_02:However, on advice of counsel, they've asked me to invoke my 6th Amendment, 14th Amendment, and 5th Amendment right.
[31:08]SPEAKER_02:Therefore, though I'd like to answer that question, as well as the other ones, I risk losing their representation if I do so.
[31:15]SPEAKER_03:More of an objective relevance, as I have in the past, is medical history is not at issue in this case under the legal terms.
[31:32]SPEAKER_01:you would agree, wouldn't you, that you targeted these underage girls, including Tate and Miller, because of their young age?
[31:42]SPEAKER_03:Argumentative, speculative, harassing, and assumes facts, not evidence.
[31:52]SPEAKER_02:I would like to answer that question as well as most of the other questions you've asked me here today.
[31:57]SPEAKER_02:My counsel has advised me that I must assert my 14th Amendment, 6th Amendment, 5th Amendment right.
[32:04]SPEAKER_02:Though I'd like to answer those questions today, if I do so, I have risk losing their representation.
[32:12]SPEAKER_01:You would also agree, wouldn't you, that you targeted these underage females for sex, including ******, because they were poor.
[32:24]SPEAKER_01:Same objections.
[32:29]SPEAKER_02:I'd like to answer that question.
[32:32]SPEAKER_02:I'd really like to answer that question as well as the other questions you've asked me here today.
[32:37]SPEAKER_02:However, on advice of my counsel, they've demanded that I assert my Fifth Amendment, Sixth Amendment, and Fourteenth Amendment rights.
[32:48]SPEAKER_02:And if I answer that question, I risk losing their representation.
[32:52]SPEAKER_01:You would agree, wouldn't you, that you sexually molested ****** for three years?
[32:58]SPEAKER_01:Same objections.
[33:00]SPEAKER_02:I think you've asked me that question before.
[33:03]SPEAKER_02:I don't serve the same rights as before.
[33:05]SPEAKER_01:Mr. 5th, 6th, and 14th Amendment, just so the record's clear.
[33:08]SPEAKER_01:You would agree, wouldn't you, that you coerced ****** into prostitution?
[33:17]SPEAKER_03:Same objections.
[33:20]SPEAKER_02:I believe her own testimony reflects, at least the sworn statement of the FBI, reflects that is not the case.
[33:28]SPEAKER_02:And though I'd like to answer that question in great detail, I cannot do so today on the advice of counsel that's asked me to assert my Sixth Amendment, Fifth Amendment, and Fourth Amendment rights.
[33:40]SPEAKER_02:And if I do so, I risk losing their representation.
[33:44]SPEAKER_01:You would agree, wouldn't you, that you groomed...
[33:47]SPEAKER_01:into becoming a prostitute?
[33:50]SPEAKER_03:An object, argumentative, speculative, certainly lacks predicate and assumes facts not in evidence.
[34:00]SPEAKER_02:You know I'd like to answer that question, but I can't today.
[34:04]SPEAKER_02:Under advice of counsel, I'm going to have to assert my 14th Amendment, 6th Amendment, and 5th Amendment rights.
[34:11]SPEAKER_02:If I answer the question, I risk losing their counsel.
[34:16]SPEAKER_01:You'd agree, wouldn't you, that you brainwashed ****** into believing that this lifestyle of prostitution was right.
[34:24]SPEAKER_01:Same objections.
[34:29]SPEAKER_02:I'd like to answer that question, as most of you other questions here today, Mr. ******.
[34:37]SPEAKER_02:On advice of counsel today, I'm going to have to assert my 5th Amendment, 6th Amendment, and 14th Amendment rights, because if I answer that question, I risk losing their representation.
[34:49]SPEAKER_01:Would you agree that your interaction with when she was a minor was degrading to her?
[34:58]SPEAKER_01:Same objections.
[35:01]SPEAKER_02:I'd like to answer that question.
[35:05]SPEAKER_02:I'd like to answer all your questions here today.
[35:08]SPEAKER_02:However, my counsel has advised me that I must assert my 14th Amendment rights, my 6th Amendment rights, and my 5th Amendment rights.
[35:16]SPEAKER_02:And though I would like to answer those questions, if I do so, I risk losing their representation.
[35:21]SPEAKER_02:Can we take a break and get some air?
[35:22]SPEAKER_01:Is that okay?
[35:23]SPEAKER_01:We have 15 minutes and we're done.
[35:25]SPEAKER_01:Oh, fine.
[35:25]SPEAKER_01:I'll stay.
[35:26]SPEAKER_01:Continue then?
[35:26]SPEAKER_01:Yep.
[35:27]SPEAKER_01:Okay.
[35:32]SPEAKER_01:Would you agree that...
[35:36]SPEAKER_01:You intentionally indoctrinated into this very deviant sexual lifestyle.
[35:44]SPEAKER_01:Okay.
[35:44]SPEAKER_03:I'm going to object.
[35:45]SPEAKER_03:It's argumentative.
[35:47]SPEAKER_03:It's confusing.
[35:48]SPEAKER_03:It's speculative.
[35:51]SPEAKER_03:Vague.
[35:53]SPEAKER_03:Black's predicate assumes facts, not in evidence.
[35:56]SPEAKER_02:And on top of that, I'd like to answer that question, but...
[36:02]SPEAKER_02:My counsel has advised me that I must assert my 14th Amendment, 6th Amendment, and 5th Amendment rights under the U.S. Constitution.
[36:09]SPEAKER_02:Though I'd like to answer all your questions here today, I cannot do so by risking losing their representation.
[36:19]SPEAKER_01:Would you agree that you are personally responsible for destroying her life?
[36:28]SPEAKER_03:Same exact objections.
[36:29]SPEAKER_03:Her life?
[36:36]SPEAKER_02:I'd like to answer that question.
[36:38]SPEAKER_02:And I understand how your firm has been accused of fabricating sexually charged lawsuits in order to fleece investors locally in South Florida.
[36:50]SPEAKER_02:The U.S. attorney has called a criminal enterprise based on filing fallacious sexually charged cases.
[36:58]SPEAKER_02:And though I'd like to answer that question today, Mr.
[37:03]SPEAKER_02:Counselors told me that I have to assert my rights on the 6th Amendment, 5th Amendment, and 14th Amendment.
[37:09]SPEAKER_02:And if I don't do so, I risk losing their representation.
[37:13]SPEAKER_01:We have a factual basis for asking every question and making every allegation, and I want to provide you with a last opportunity to tell the jury which of these allegations, if any, being made by T.O.P.
[37:27]SPEAKER_01:are false or fabricated in any way.
[37:30]SPEAKER_01:Same objections.
[37:32]SPEAKER_03:Mr. Edwards, you know the tenor of that question.
[37:38]SPEAKER_03:cannot be answered without waiver of 5th, 6th, and 14th.
[37:44]SPEAKER_03:I appreciate the question and the semantics of it, but it's... Can you rephrase it?
[37:55]SPEAKER_01:Yeah.
[37:56]SPEAKER_01:Many times, you know the allegations now.
[37:59]SPEAKER_01:We've gone through...
[38:00]SPEAKER_01:allegations and assertion of facts as to what happened between you and her when she was 13, 14, and 15 years old, and you were 50, 51, 52 years old.
[38:11]SPEAKER_01:And several times you responded saying something about her FBI statement or what have you.
[38:20]SPEAKER_01:And I want to give you a chance to tell the jury
[38:24]SPEAKER_01:Which of her allegations, if any, that you believe now are false or fabricated in any way?
[38:32]SPEAKER_01:Same objections.
[38:33]SPEAKER_02:I'd like to respond to that question.
[38:35]SPEAKER_02:The fact that her firm, the law firm representing her, has been accused.
[38:42]SPEAKER_02:by the U.S. attorney of being a criminal enterprise manufacturing, fabricating out of thin air cases involving sexual allegations, sexual allegations, in order to simply fleece local investors out of millions of dollars.
[39:01]SPEAKER_02:So I would very much like to answer that question regarding the truthfulness of Ms. Tatum Miller's allegations.
[39:07]SPEAKER_02:However, today,
[39:09]SPEAKER_02:My counsel has told me that I must assert my Fifth Amendment rights, Sixth Amendment rights, and Sixth Amendment rights under the U.S. Constitution, though I would very much like to answer those questions, but if I do, I risk losing their representation.
[39:23]SPEAKER_01:Would you agree that you owe s***?
[39:26]SPEAKER_01:at least $15 million to compensate her for the damage that you have caused?
[39:31]SPEAKER_01:No objection.
[39:33]SPEAKER_03:I'm going to move to strike.
[39:34]SPEAKER_03:Argumentative, compound, lacks substantial predicate, and assumes facts, not in evidence.
[39:46]SPEAKER_02:As you might imagine, though your law firm has been accused of...
[39:52]SPEAKER_02:perpetrating a fraud involving millions and millions of dollars on unsuspecting investors here in South Florida.
[39:58]SPEAKER_02:Millions of dollars by fabricating similar allegations, convincing people to give money to the firm that helped bring this lawsuit.
[40:09]SPEAKER_02:I'm afraid I'd like to answer those questions, but no matter how much I'd like to answer those questions, I'm going to have to decline based on my counsel's advice to invoke, at least today, my Fifth Amendment, Sixth Amendment, and Fourth Amendment rights under the U.S. Constitution.
[40:23]SPEAKER_02:Because if I don't, I risk losing my representation.
[40:27]SPEAKER_01:Is it true that you are currently worth more than $1 billion personally?
[40:42]SPEAKER_02:I'd like to answer that question as I'd like to answer most of your other questions.
[40:46]SPEAKER_02:I know that's a lot of money.
[40:48]SPEAKER_02:It's actually the amount of money that the U.S. attorneys accused your firm of trying to steal from the people of South Florida.
[40:54]SPEAKER_02:It was $1.2 billion.
[40:55]SPEAKER_02:The U.S. attorney claimed that your firm perpetrated the largest fraud in South Florida's history by stealing that sum of money from local investors based on false allegations of sexually charged claims
[41:09]SPEAKER_02:And so, though I'd like to answer these questions with specificity, under advice of counsel today, I'm going to have to refuse based on my Sixth Amendment, Fourteenth Amendment, and Fifth Amendment right.
[41:21]SPEAKER_02:And though I'd like to answer the question, I've been told that if I do so, I risk losing their representation, Mr. Edwards.
[41:26]SPEAKER_01:All right.
[41:27]SPEAKER_01:I'm simply asking, what is your personal net worth at this time?
[41:31]SPEAKER_01:Form.
[41:33]SPEAKER_01:I think I've answered the question, but...
[41:36]SPEAKER_01:What is your personal net worth at this time?
[41:39]SPEAKER_01:So the answer should be a number, or it should be you invoking your Fifth Amendment rights.
[41:43]SPEAKER_01:Seemed like the options.
[41:44]SPEAKER_01:That's an answer.
[41:45]SPEAKER_01:He did invoke his Fifth, Sixth, and Fourteenth.
[41:48]SPEAKER_01:His answer included something about stealing some certain amount of money, which obviously is non-responsive.
[41:55]SPEAKER_01:I'd move to strike it, and I'd ask that he actually respond to the question with something that is responsive.
[41:59]SPEAKER_01:His options are, answer the question, invoke your Fifth Amendment rights, but get out of here.
[42:05]SPEAKER_01:Let's start over again.
[42:08]SPEAKER_01:Can you please tell the jury what your personal net worth is currently?
[42:14]SPEAKER_02:I'd like to do that today.
[42:15]SPEAKER_02:However, I'm sure one of the reasons is since your firm has been accused of stealing millions of dollars from local investors based on fabricated, totally fabricated claims.
[42:26]SPEAKER_02:This is not by me, but by the U.S. attorney.
[42:28]SPEAKER_02:has called your firm a criminal enterprise charged with stealing hundreds of millions of dollars, frankly, from local investors based on false claims of sexually charged nature.
[42:39]SPEAKER_02:I'd like to answer that question in detail.
[42:42]SPEAKER_02:However, my attorneys have advised me that I cannot answer any questions that may be relevant to this lawsuit.
[42:47]SPEAKER_02:And by doing so, I must invoke my 6th Amendment, 5th Amendment, and 14th Amendment right.
[42:52]SPEAKER_02:And by answering the question, I risk losing their representation.
[42:55]SPEAKER_01:Okay, so is it true that you're worth $1.8 billion?
[43:00]SPEAKER_01:Same objection.
[43:01]SPEAKER_01:Same answer.
[43:04]SPEAKER_01:Go ahead and put the answer.
[43:05]SPEAKER_02:For the record, yeah.
[43:06]SPEAKER_02:For the record, I'm sure that's an interesting question, and I'd like to answer that question for you.
[43:13]SPEAKER_02:I'm sure you'd like to know, as your firm has been charged with stealing over $1 billion from local investors,
[43:19]SPEAKER_02:Your senior partner of both you and me is shaking his head, sits in jail, accused of policing local Florida investors based on false sexual claims from people.
[43:31]SPEAKER_02:And though I'd like to answer that question like I'd answer most of your other questions, my counsel has advised me that today, ladies and gentlemen of the jury, I cannot answer that question.
[43:41]SPEAKER_02:Maybe I will in the future.
[43:44]SPEAKER_02:If I do so today, I risk losing that representation.
[43:47]SPEAKER_02:So I must assert those rights on the 6th, 5th, and 14th of November.
[43:51]SPEAKER_01:You would agree, would you not, that it would take a jury award of at least $45 million in punitive damages to punish you for doing what you did to...
[44:04]SPEAKER_01:Same objections.
[44:09]SPEAKER_02:I would like to answer that question as I'd like to answer all your other questions today.
[44:15]SPEAKER_02:However, while he sits shaking his head, I'm going to have to respond.
[44:20]SPEAKER_02:My counsel has advised me I could not answer that question today, though I'd like to.
[44:25]SPEAKER_02:Though I'd like to answer with specificity, however, if I do so, I risk losing their representation.
[44:30]SPEAKER_02:So I must assert my rights under 6th, 5th, and 14th Amendment.
[44:35]SPEAKER_01:Isn't it true, Mr. Dean, that as long as you have the money to do it, you will continue to engage in sex with minors?
[44:43]SPEAKER_03:Again, extremely argumentative and speculative.
[44:48]SPEAKER_03:I'm allowing the question to give leeway so we don't have to come back here again.
[44:51]SPEAKER_03:It's harassing.
[44:56]SPEAKER_02:And with that, I'm sure this, ladies and gentlemen of the jury, will be able to see you and your partner whose firm has been accused of massive fraud in South Florida, trying to steal hundreds of millions of dollars from local investors, from creating, fabricating malicious, sexually charged claims.
[45:18]SPEAKER_02:called by the U.S. attorney a criminal enterprise charged with money laundering conspiracy to commit other federal violations.
[45:28]SPEAKER_02:So though I'd like to answer that question, I must invoke my 6th, 5th, and 14th Amendment rights advised by counsel or risk losing their representation.
[45:39]SPEAKER_01:And am I correct in my understanding that you have invoked your Fifth Amendment rights because your answers would incriminate you and lead to your prosecution?
[45:50]SPEAKER_01:I'm going to.
[45:52]SPEAKER_01:Exactly as phrased by Mr. Luthier towards Tatum Miller, I did not say anything but allowed her to answer the question.
[45:57]SPEAKER_01:I'm going to answer that question in objective form.
[46:01]SPEAKER_02:In fact, since you are a lawyer, I'm sure you're aware the Supreme Court has said that the Fifth Amendment is used more often to protect innocent people.
[46:10]SPEAKER_02:That's today the advice of counsel, taking that right.
[46:18]SPEAKER_03:I have no questions.
[46:19]SPEAKER_04:No further questions.