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Case 1:15-cv-07433-LAP Document 1328-16 Filed 01/05/24 Page 4 of 8 we MmInnewnre 30 involved in the planning of this scheme to gain 1 access to underage minor females? 2 MR. YAREMA: Object to the form. 3 A Fifth. 4 Q > When is the first time that you observed 5 Jeffrey Epstein's method of enticing or inducing 6 underage minor females into sexual acts with him =| 7 inside his bedroom? 8 MR. YAREMA: Object to the form, 9 A Fifth. 10 Q Isn't it true that after an underage 11 minor female was brought to Jeffrey Epstein's 12 house, typically Sarah Kellen, or Adriana or 13 yourself would lead that underage minor female to |14 Jeffrey Epstein's bedroom and leave them alone in {15 sex toys on you, correct? A Fifth. Q_ And he has instructed you to use sex toys and vibrators on other underage minor females, correct? MR. YAREMA: Object to the form, A Fifth. Q You have observed Jeffrey Epstein digitally penetrate the vagina of underage minor females, including E.W., correct? MR. YAREMA: Object (o the form. A Fifth. Q As part of his plan to avoid detection by law enforcement, you have observed Jeffrey Epstein to pay these underage minor females to be quiet, correct? MR. YAREMA: Object to the form, A Fifth. Q And this is something that he has told you he does, for the purposes of grooming these underage minor females, and avoiding law enforcement detection, correct? MR. YAREMA: Object to the form. A. Fifth. Q Jeffrey Epstein has talked to you about the room; is that true? 16 MR. YAREMA: Object to the form. 17 A Fifth. 18 Q Then Jeffrey Epstein would appear either [19 naked or wearing a towel; is that true? 20 MR. YAREMA: Object to the form. 21 A Fifth. 22 Q This is his habit or method of 23 operation, every single time, and that's 24 something that he has told you about his sexual 25 31 interaction with underage minors; is that true? 1 MR. YAREMA: Object to the form. 2 A Fifth. 3 Q And be would direct or demand or 4 instruct the underage minor female to remove her | 5 clothing; is that true? 6 MR. YAREMA: Object to the form. 7 A Fifth. 8 Q Then he would perform one or more lewd 9 or lascivious or sexual acts on the underage 10 minor female. Is that true? 11 MR. YAREMA: Object to the form. 12 A Fifth. 13 Q And you have observed Jeffrey Epstein 14 engage in sexual interaction with underage minor {15 females on hundreds and hundreds of occasions, 16 correct? 17 MR. YAREMA: Object to the form. 18 A Fifth, 19 Q And you have observed Jeffrey Epstein 20 using vibrators and sexual toys on underage 21 minors, true? 22 MR. YAREMA; Object to the form. 23 A Fifth. 24 Q In fact, he has also used vibrators and 33 the psychology of brainwashing or grooming underage minor females to perform for him sexually, hasn't he? MR. YAREMA: Object to the form. A Fifth. Q And Sarah Kellen has also spoken with you about the methodology behind gaining access to and grooming underage minor females for sex? MR, YAREMA: Object to form. A Fifth. Q Isn't it true that Ghislaine Maxwell and yourself and Sarah Kellen had access to a master list of underage minor females names and phone numbers so that they could be called? MR. GOLDBERGER: Time out. Are you talking to me, counsel? MR. HOROWITZ; Nodding my head, back at you. You were nodding at me. MR. GOLDBERGER: | wasn't nodding at you. I'm not talking to you, I’m not communicating with you. | don't know what you think we are doing here, You said "It is true," and | have no idea what you are talking about. Don't interrupt the deposition, okay’? 9 (Pages 30 to 33) U.S. Legal Support (561) 835-0220 GIUFFRE001172