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WDAKHUSPWNHE Case 1:15-cv-07433-LAP Document 1328-15 Filed 01/05/24 Page 4 of 6 Page 37 THE VIDEOGRAPHER: We're now on video record at 11:01 a.m. MR. KUVIN: Just for the video record and for the written record Katherine Ezell and Amy Ederi have now appeared and are present in person. MR. GOLDBERGER: Just one more matter for the record. Jack Goldberger, on behalf of Jeffrey Epstein. Rather than impose a form objection to every question, I think we have reached an agreement that on behalf of Mr. Epstein, | am adopting the form objections that Mr. Rheinhart is making on behalf of his client nune pro tunc to the beginning of this deposition. MR. KUVIN: No objection. MR. GOLDBERGER: Okay. BY MR. KUVIN: Q. Allright. Allright. Ms. Kellen, would you agree with me that there was an agreement between Jeffrey Epstein, Ghislaine Maxwell, Jean-Luc Brunel, yourself and Nadia Marcinkova to bring in girls from out of state that were underage? MR. RHEINHART: Object to the form of the question as leading, as compound, and instruct OWNIADUSPWNHE Page 39 personal knowledge and instruct her not to i answer based on her Fifth Amendment privilege. It's also compound. | THE WITNESS: On the instruction of my lawyer I must invoke my Fifth Amendment privilege. BY MR. KUVIN: Q. The witness says that you may not have knowledge or we don't know whether you have t 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 fi 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 E Page 38 the witness not to 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. Would you agree with me that there was an agreement between Jeffrey Epstein, Ghislaine Maxwell, Jean-Luc Brunel, yourself and Nadia Marcinkova to bring in girls that were underage from out of state for sexual contact? MR. RHEINHART: Object to the form of the question as leading and compound, and I instruct the witness 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. All right. Let me show you what we've premarked as Plaintiff's Exhibit 3. Do you recognize this as the passenger manifest for one of Jeffrey Epstein's planes? MR. RHEINHART: I object to the form of the question. It assumes facts that this itness, evidence that i Page 40} 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: iq Q. Have you heard the word "manifest" before? MR. RHEINHART: I'll instruct the witness | not to 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. Would you agree with me, ma'am, that you have seen this passenger manifest, listed as Exhibit 3, in the past? MR. RHEINHART; I'll instruct the witness not to 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. Who is Zinta Broukis? MR. RHEINHART: I'll instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instructi 10 (Pages 37 rm 40) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 GIUFFRE00 1680