Page 502
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO:502008CA028051XXXXMB AB
Plaintiff,
-vs- VOLUME IV OF IV
JEFFREY EPSTEIN
AND
Defendants.
VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF
Tuesday, February 09, 2010
10:09 - 5:05 p.m.
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1296
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Page 503 Page 505
1 APPEARANCES: 1 PROCEEDINGS
2 On behalf of the Plaintiff.," and
3 BRAD J. EDWARDS. 2
FARMER, JAFFE, WELSSREG, EDWARDS 3 THE VIDEOGRAPHER: We're back on the
FESTOS & 1EHRMAN, P.L
425 North Andrews Avenue record at 1:48 p.m.
5 Suite 2 5 BY MR. LUTHER:
Fort 'da 33301 6 Q. Okay, Ma'am. I want to add that during
6 Phone:
7 On behalfo the Jeffrey Epstein: 7 the morning session, I was asking you some
3 ROBERT D. CRITTON, JR., F5QU1RE 8 questions. I just want to go over a couple of
MARK T. Lunn, ESQUIRE
9 atramAN. CRJTTON, LUTTIER & COLEMAN. ELP 9 things. One of the first things I asked you this
303 Banyan Boulevard 10 morning is whether you understood you were under
10 Suite 400 11 oath today. And you indicated you did understand
West 33401
Phone 12 that?
2 On he fot the De ate, Jeffrey Epstein: 13 A. Comet.
3 JACK ALAN GOLDTJERGER. ESQUIRE
ATTERBURY, GOLDBERGER & WEISS, P.A. 14 Q. Are you, did you, are you aware of the
250 Australian Avenue South 15 fact that it is a crime known as perjury to make a
Suite 1403 16 false statement under oath?
Is West Pa a 33401-5012
Phone: 17 A. Correct.
16 18 Q. Are you also aware that it is a separate
17
18 ALSO PRESENT. kffrey Epsldn, via video conference 19 crime, a federal crime to make a false statement to
17.7ney, Viikographier
Daniel C/4 20 an FBI agent?
19 Visual Evidence, Incorporated 21
20 A. Correct.
21 22 Q. And you've already admitted that you
22 23 committed that federal crime; you lied to the FBI,
23
34 24 according to you.
25 25 A. I was in fear of my son's life, correct.
Page 504 Page 506
1 1 Q. Now, l want to ask you one more time: Is
2 INDEX VOLUME I 2 there anything you want to correct about any of your
3
3 testimony this morning, especially as it relates to
4
5 DIRECT CROSS REDIRECT RECROSS 4 m
workio min s laces of employment that i wiltave termed
5 5 to be at or about or near
7 6
BY MR. LUTHER 4 7 A. Correct. I'm fine on that.
8
9
8 Q. Okay. Isn't it a fact that on Saturda
10 9 January 30th, you went to
11 EXHIBITS 10 A. Yes.
12 11 Q. And you got them, what time, around 8:00?
13 A. Yes.
14 EXHIBIT DESCRIPTION PAGE
13 some point in time you left
15 DEMI
Photo of 512 14 did you not?
16 15 A. Yes.
518 16 Q. And you went to a place called
ad 17 of Palm Beach, did you riot?
634
18 A. Not that I recall. I don't know a name
19 19
20 618 20 Q. Well, would be the
21 Each' located right next door to
21 22 . You're familiar with that, aren't, ''.
22
23 23 A. I thought that was affiliated with
24 24 MI.
25 25 Q. Well, so that ue know —
2 (Pages 503 to 506
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Page 507 Page 509
1 (Cellphone interruption.) 1 v it's to the left side of
2 THE WITNESS: Oh, Pin sorry, my phone. 2 as you look at it. It's got a
3 MR. LUTTIER: Sure. Oo ahead. 3 separate entrance. It's got neon signs on it?
4 THE WITNESS: Okay. Sorry. 4 A. Okay.
5 BY MR. LUTTIER: 5 Q. And it's known as
6 Q. There is whether or not it's 6 You're aware of that place, aren't you
7 affiliated with 1 don't know. When 7 MR. EDWARDS: Fora
8 you referred to your testimontl ming that you 8 THE WITNESS: I'm not aware of any name.
9 didn't go anyplace other than MM Rhinos and BY MR. LUTHER:
10 places affiliated did, with it, did you mean to 10 you w in the establishment known
11 include in those places that you went of 11 as on the evening of
12 Palm Beach? 12 Saturday, January 30th, 2010, were you not?
13 A. I personally never heard ofaiir 13 MR. EDWARDS: Font
14 Beach, but I know that, there, that has 14 THE WITNESS: If that's what it's called,
15 a couple places affiliated with them. long, as far as I know,
16
17
Q. What places do they have that are
affiliated with them?
15
16
17
MM.
of, you know.
that's the name I know it as
18 A. The back and then there's an entrance to 18 BY MR. LUTTIER:
19 another place. That's all ! know. 19 Q. Well, this is a place that has a separate
20 Q. Well, tell me about this entrance to 20 Y don't go through the entrance of
21 another place. What am yo 21 . rate entrance
22 A Well, in the back of there is 22 for a place called
23 a little section that the dancers -- I don't know 23 A. Well —
24 exactly what they do there, but that's where I do sell 24 Q. I want to make sure we're real clear here
25 shoes and my lingerie. 25 we're not playing semantics.
Page 508 Page 510
1 And then there is another entrance that 1 A We're not playing what?
2 you can go through and then there is another it's 2 Q. Semantics.
3 like there's, I know that there's, there's a lot of 3 A. Okay.
4 doors. I don't know what they consist of. 1 don't 4 MR. CRITTON: Word games.
know what they do there, but I know that they are 5 THE WITNESS: Oh.
6 t that they were affiliated with 6 MR. LUTTIER: All right?
7 and that's where I also go to sell 7 THE WITNESS: Yeah.
8 my shoes and purses. 8 BY MR. LUTTIER:
9 Q. Oka about a place in 9 Q. Sil dai rwere in fact, in this place
10 the back of the ou • access 10 called on Saturday, January
11. to by going through the 11 30th, 2010, were you not?
12 establishment? 12 MR. EDWARDS: Object to the fonn.
13 A. Yes. 13 THE WITNESS: I definitely walked through
14 Q. All right. Now, what is this second place 14 an elmitithought was affiliated
15 that you are talkin a out that u say is 15 with
16 affiliated with 16 BY MR. LUTTIER:
17 A. ter go through out the back 17 Q. And there's a black female in there that
18 door of and take a right, and then there 18 works at the front desk, is there not? There was on
19 is a place there that's affiliated with them. 19 Saturday night.
20 Q. Is there a name? Is there a separate 20 A. Oh, I don't know. I don't know who works
21 entrance to the place? 21 there. I don't blow.
22 A. I — they're connected. 22 Q. And the --
23 Q. Is there a separate name on this place? 23 A. I just know that I go into and
24 A. Not that I know of 24 I sell my —
25 Q. Okay. I'm tallthsabout a place that's 25 Q. And —
3 (Pages 507 to 510)
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Page 511. Page 513
2
3
it . — items.
the name that you're known as is
isn't that right?
1
2
3
A. No. I say to the girls, my name is
they know that I sell all ofmy, all ofmy cil an
lingerie and shoes and everything else I sell.
and
4 A. I'm not known as r= 4 Q. But there is no doubt that now that you
5 Q. That's the name you remember we were 5 have seen this picture, you were in that
6 asking you about the cards you used to use? 6 establishment that is depicted on Exhibit No. 3 on
A. Yeah, I was known as =in '07 and '08. 7 January 30th, right?
8 Q. that's the name you've used in the past 8 A. Correct.
9 is 9 Q. And you drive a white Mitsubishi Gallant;
10 A. Yes. 10 is that right?
11 Q. And in fact on Saturda January 30th, you 11 A. Yes.
12 were working in which was. i2 Q. License plate number is is that
13 to use your terms, a were you not? 13 correct.
14 A. NA I was not working there. 14 A. I don't know my license plate number, but 1
15 Q. And you were charging $120 fora halfhour 15 definitely drive a white Mitsubishi Gallant
16 to perform services; isn't that right? 16 Q. And is, was that vehicle parked outside
17 A. No. 17 of the Palm Beach on Saturday night,
18 Q. Andacame out and told somebody your 18 rnatu y e 30th?
19 name was Mend that that was your charge, 19 A. Yes, but like I said before, from my
20 didn't you not? 20 knowledge, I thought this was affiliated with
21. A. No, I did not. All I do is sell shoes and 21
22 purses there. 22 Q. And that car
23 MR. LUTRER: Let me show you a picture 23 A. And they don't like me to park, they don't
24 here which we'll mark as, !guess we want to do 24 like me to park in front of because
25 it in order. It will be Exhibit 3. 25 there are so many clienteleflAgoe n., out. So
Page 512 Page 514
1 (Defendant's Exhibit No. 3 was marked for 1 they need as much parking space as they can.
2 identification.) 2 Q. And you stayed at
3 THE WITNESS: This place, yeah, ifs next 3 until what hour on the
4 to - 4 be January 31st?
5 MR. LUTTIER: Hold on. Hold on. 5 A. I stayed until what time?
6 THE WITNESS: Sorry. 6 Q. Yeah, the morning until — what time on
7 BY MR. LUTTIER: 7 the morning of Sunday, January 31st, did you leave?
8 Q. I have to ask you a couple of questions. A. Well, I would go wail
9 Do you recognize Exhibit 3? 9 closing like 5, .. •t" 1m .le
1 back ofhere, of
10 A. Yes but what I would do, 'would go out of 10 that's like, sometimes they have after
11 from the beck and go into the back 11 parties t This is what I hear from the,
12 entrance of or whatever this place is called. 12 the manager at And like I said,
13 Q. SA so, now upon seeing the picture, you 13 sometimes lam/ MM.; a couple ofdrinks.
14 want to correct our testimon and say, in fact, you 14 And I'm not sure what time I left
15 were in on Saturday? 15 Q. I don't want to know —
16 A. I, from my understanding, from my knowledge, I 16 A. As long estkeep on selling shoes and
17 thought that this place was owned by 17 lingerie, I'm the there.
18 Q. All right. The place of business that's 18 Q. I am not asking about sometimes. T am
19 depicted in Exhibit No.3, were you in that place of 19 talking about Sunday morning, January 31st, 2010,
20 business on Saturday, January 30th? 20 what time did you leave on that day?
21 A. Yes, selling my items. 21 A. I couldn't tell you that. I don't know.
22 Q. And did you, in fact, on that night, on 22 Q. Well, what's your best estimate?
23 Saturday,hus30th, toll individuals that your 23 A. I don't know, sir.
24 name was and that you charged $120 per half 24 Q. Well, first of all you closed
25 howl at, what, 5 in the morning?
a......4:01.3.4SOW.,••••••••.•...mveatilmcnista
4 (Pages 511 to 514)
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Page 515 Page 517
1 A. I closed it? 1 A. And we started talking to people.
2 Q. Yeah, you were them until it closed? 2 Q. Who did you talk to in particular?
3 A. Yes. 3 A. I don't know anyone else.
4 Q. And then you went over to 4 Q. Did you talk to a male there?
5 right? 5 A. Yeah.
6 A. That I thought was from the 6 Q. Have him over at your table?
7 back 7 A. He came closer to — we were at the bar.
8 Q. Whatever. 8 Q. The three of you were talking, were you
9 A. Okay. 9 not?
10 Q. And then, how much longer did you stay 10 A. Yeah.
11 there? 11. Q. Do you remember the guy having a laptop?
12 A. I stayed there a little while because there is 12 A. Yes.
13 more girls there that like to buy my items. 13 Q. What did you-all do on the laptop or what
14 Q. Now, let's talk about your trip to New 14 did he do on the laptop while you were there and you
15 York 15 both were sitting there?
16 A. Okay. 16 Well, I told him that I modeled for
17 Q. Tuesday, February 2nd, 2010. Remember I 17 And I told him if he would like to see my
18 asked you earlier about whether you ever used any 18 pictures, to go onto
19 business cards? 19 Q. So, did you tell him about any other
20 A. Yes. 20 websites?
21. Q. When you went on this trip to New York, 21 A. Excuse me?
22 did you have any cards? 22 Q. Did you tell him about any other websites?
23 A. No, not that I no. 23 A. No, not that I recall.
24 Q. Did M. have any cards? 24 MR.LIMIER: Let's mark this as
25 A. Not that I know of. 25 exhibit — what's this, 4?
Page 516 Page 518
1 Q. Did you, when you went to the Palm Beach 1 THE COURT REPORTER: Four.
2 International Airport, did you give the taxicab 2 MR. LUTHER: Mark this as 4.
3 driver a card? 3 MR. EDWARDS: Is Exhibit 1 and 2 marked —
4 A. Did I give hi card? 4 MR. LUITIER: Yeah.
5 Q. Yeah, you or M., little business card? 5 MR. EDWARDS: in the previous depo?
6 A. I didagive him a card, no. 6 MR. LUTHER: Yeah, the previous depo.
7 Q. Did M. give him a business card? 7 Although I don't know where the exhibits are or
8 A. Not that I know of. • 8 they were.
9 Q. When you went into the Palm Beach MR. EDWARDS: Okay.
10 International Airport, your card — do you recall 10 MR. LUTTIER: It was like answers to
11 going to a bar? 11 interrogatories. Something like that.
12 A. Palm Beach International Airport, yeah, I went 12 MR. EDWARDS: Okay.
13 to a bar there — 13 (Defendants Exhibit No. 4 was marked for
14 Q. What bar do you go to? 14 identification.)
15 A. — because I totally missed the flight. 15 BY MR.
1.6 Q. What bar did you go to? 16 Q. Let me show you what's been marked as
17 A. I think it was Fridays, if I am not mistaken 17 Exhibit 4 and ask you if you can identify that.
18 or not. I don't know what it was called. 18 A. This is —
19 Q. Who went VS bar with you? 19 MR. EDWARDS: Wait until he asks you a
20 A. 1 went withM. to the bar and it was just 20 question.
21 her and 1. 21 BY MR. LUTHER:
22 Q. And for how long was it just the two of 22 Q. Can you identify it?
23 you? 23 A. Yes.
24 A. For like ten minutes. 24 Q. What is it?
25 Q. And then what happened? 25 A. This si— 1modeled forallitand it
_
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Page 519 Page 521
1 is their advertisement now. 1 Q. Did you do anything else that evening?
2 Q. And is this one of the pictures on your 2 A. Yes, we went out to dinner.
3 website? 3 Q. After you — did you leave the apartment
4 A. On my website? 4 and go look around at Grand Central Station and then
5 Q. Yeah or your Facebook, !guess, account 5 keep on walking around or did you come back to the
6 or MySpace, whatever it was. 6 apartment?
7 A. Yeah, I have posted it on there, yeah. 7 A. We went back to the apartment.
8 Q. Is, was this one of the pictures you were 8 Q. Okay. And then there came a time after
9 telling us at your last deposition that you really 9 you came back from sightseeing that you left the
10 wouldn't want your four-year-old son to see? 10 apartment a second time?
11 A. No, that's fine if he sees this. This is, 11 A. Yes.
12 this is very legit. His mother modeled and I am 12 Q. And that was for what purpose?
13 actually very proud of this photo. 13 A. We went to Angelo's.
14 Q. All right. Now, did you do anything else 14 Q. Okay. And how did you get to Angelo's?
15 with this indigaial before you left the bar that 15 A. We got to Angelo's in a taxi.
16 you, you and M. were talking to at the Palm Beach 16 Q. A taxi?
17 International Airport? 17 A. Uh-huh.
18 A. Did we do anything with him? 18 Q. And that was about what time?
19 Did you give him anything, either you or 19 A. Oh, jeez, maybe, maybe 9:00.
20 20 Q. Between the time — what time did you go
21 A. I don't recall givinglupt anything but — 21 looking at Grand Central Station?
22 Q. Well, did you see M. give him anything? 22 A. That was before 9:00.
23 A. No. 23 Q. Okay. And do you remember, do you recall
24 Q. Did either one of you give him a business 24 that evening an individual by name of Martin
25 card? 25 Krouner?
Page 520 Page 522
1 A. I don't have any business cards. I don't — 1 A. Do I know a man named Martin?
2 Q. Well, I don't — you may want to be 2 Q. Uh.huh, Martin Krouner.
3 careful here. I don't want to trick you. lam not 3 A. No.
4 playing semantics. Did either you or give him 4 Q. Do you remember getting in a black
5 a business card? 5 Series 5 BMW when you came out of the condominium?
MR. EDWARDS: Object to the form. 6 A. We, we did take a ride with a man.
7 THE WITNESS: Not that I recall, no, sir. 7 Q. Well, 'thought you just told me you
8 We had a few drinks and, and we were off to our 8 walked to the restaurant.
flight. 9 A. No, 'told you I took a cab to the restaurant.
10 BY MR. LUTTIER: 10 Q. Oh, took a cab to the restaurant?
11 Q. And then you flew to New York and you took 11 A. Yes.
12 a c and u went to this apartment that's located 12 Q. Did you forget about getting in a car with
13 at in New Yor • is that right? That 13 this man?
14 would be the corner of 14 A. He took us a little sightseeing. No, I did
15 A. rings a bell. 15 not forget about that.
16 That's where we stayed? 16 Q. Was that before dinner?
17. Q. Yeah. 17 A. That was before dinner, yes.
18 A. Yeah. 18 Q. Did you just fail to mention that or —
19 Q. Now, on that evening, the first night that 19 this is different than the man who took you
20 you got there on Tuesday, I think earlier you said 20 sightseeing later, isn't it?
21 you-all walked down a street and went to dinner, is 21 A. Yes.
22 that right? 22 Q. Okay. So, tell me who Martin Krouner is.
23 A. We walked down the street and we walked into 23 A. I don't know his name, if that is his name.
24 a, I think it's Grand Central Station. I'm not sure 24 Q. Well, the guy that picked up in the black
25 because I'm not from there and we looked around. Yeah. 25 BMW, who's he?
6 (Pages 519 to 522)
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1 A. I guess a friend of_. 1 fellow here, Mr. Martin Krouner?
2 Q. Well, tell us how old this individual was. 2 A. If that's his name. I don't know if we took a
3 Describe him for us. 3 picture of him, but we definitely took pictures of M.
4 A. He has not a lot of hair. He's about five-six 4 and I.
5 maybe and a little chubby. 5 Q. And, and where did you take those
6 Q. For what purpose were you — and you never 6 pictures?
7 met him before? 7 A. Wherever we were.
8 A. No. 8• Q. Okay. And when this man brought you back,
9 Q. never met him before? 9 did he go to darner with you? •
10 A. No. 10 A. He ended up meeting us there, yes.
11 Q. You didn't have any idea who he was? 11 Q. Did he drop you at the restaurant?
12 A. No. 12 A. He dropped us near so we can get there with a
13 Q You-all climbed in car? 13 taxi. He dropped us somewhere off of the street and we
14 A. Yeah, I thinkit was friend. 14 went with a taxi.
15 Q. Okay. What did tell you about the 15 Q. So, he dropped you off and then you got a
16 guy? 16 taxi to get there?
17 A. She's Chinese. She's like go, go; go, go have 17 A. To go to Angelo's, yeah.
18 fun, go search the town. 18 Q. And then he met you there later?
19 Q. So, where did you go with Martin? 19 A. Lateran.
20 A. We ended up meeting him at Angelo's. 20 Q. Okay. About what time?
21 Q. Wait a minute. You got — first of all 21 A. Oh, God, I don't know the times. Maybe this
22 you got in Martin's car, right? 22 was around, maybe around — I'm — this is total
23 A. I got into Martin's car, yes. 23 ballpark, lace 10 maybe.
24 Q. And then where did you go once you got in 24 Q. Okay. Anal& and then after dinner
25 Martin's car? 25 what did you and M. and he do?
Page 524 Page 526
1 A. We searched around the town. 1 A. Well, we took a taxi back to his car. And we
2 Q. What do you mean you searched around? 2 went up to the, we went up to room and he just --
3 A. We went sightseeing. 3 we just said bye.
4 Q. Okay. Do you remember where you went? 4 Q. And did you receive anything at all of
5 A. And we went sightseeing. 5 value from this man?
6 Q. Do you remember where you want 6 A. No.
7 sightseeing? 7 Q. Did you charge him anything?
8 A. Then we took a taxi. No, because I don't know 8 A. No.
9 the area. 9 Q. Were you paid anything for the time you
10 Q. You went sightseeing in Mr. Kroner's car, 10 spent with him?
11 correct? 11 A. No.
12 A. Yes. 12 Q. Now, who's Robert Fredrick Burke?
13 Q. All right. And, and did there come a time 13 A. Robert Fredrick Burke, I have no idea.
14 that you got of Mr. Kroner's car? 14 Q. Well, on the next day on Wednesday,
15 A. Yeah, and we looked around. It was filming 15 February 3rd, did you go sightseeing again?
16 outside, so it was nice to feel the snow. 16 A. Yes, we did.
17 Q. And where did you get out of the car? 17 Q. And you said that this fellow Bobby came
18 A. Sir, I don't know New York. I don't — 18 to see you at the apartment sometime the morning of
19 Q. Well, was it at a restaurant? Was it at 19 Wednesday, February 3rd?
20 the pool? Was it back at the condo? Where was it? 20 A. He came to see us, ubhuh. I'm not sure what
21 A. R was near a whole bunch of buildings. 21 time it was. I think it was around in the afternoon.
22 Q. By the way, did you take any pictures 22 . Okay. And then after he eft, you and
23 while you were up there? 23 did some more sightseeing?
24 A. I did take pictures. 24 A. Yeah, we walked around town.
25 2. Take a icture of you at and this 25 Q. Do you remember getting in a vehicle with
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1 somebody that night? 1 A. I have no idea.
2 A. Yes. 2 Q. Were they a male's clothes or female's
3 Q. Who did you get in a vehicle with? 3 clothes?
4 A. I told you, I don't know his name. 4 A. I didn't search through the garbage. I just
5 Q. Well, where did you, where did you meet 5 know that I threw out the trash.
6 this person? 6 Q. So you're telling me you don't know whose
7 A. Everybody was =friend. =has a lot 7 they were?
8 of friends. 8 A. No.
9 Q. Well, what did you know about the person? 9 Q. Oistry. Do you know
10 A. Nothing. 10 A. Yes, Id°.
11 Q. How old is the person? 11 Q. And how do you know
12 A. I told you, I don't know anything about him. 12 A. We grew up together. ro bly 'mew her since
13 Q. And what kind of vehicle did you get in? 13 1was 12.
14 A. I don't even know the vehicle. 14 Q. Have you ever been engaged in any kind of
15 Q. Toyota Highlander? 15 a business venture, regardless of whether it was a
16 A. Ls it — I don't know. 16 formally formed business venture like a corporation,
17 Q. And what nationality is this individual? 17 but any kind of business venture with .M?
18 A. I have no idea. 18 A. I went, we went to Jeffrey's togWer.
19 Q. And where did this individual take you? 19 Q. My other kind of business venture, you
20 A. He took us to sightseeing and he took us to 20 and her?
21 the Statue ofLiberty, everywhere. 21 A. No.
22 Q. Did you receive anything of value from 22 Q. Were you ever, did you ever represent or
23 him? 23 attempt to start a business venture with her?
24 A. No. 24 A. This is years ago.
25 Q. Did you charge him anything? 25 Q. How many years ago?
Page 528 Page 530
1 A. No. 1 A. Well, 13, 14, 15, like eight years ago.
2 Q. You or El? 2 Q. Okay. So, this is 2010. We're talking
3 A. I did not charahim anything. 3 about 2002?
4 Q. How about ? 4 A. Yeah.
5 A. I don't know what she does but, no, I don't 5 Q. Okay. So tell us about the venture that
6 think so. 6 you were forming with her?
7 Well, was there ever a time that you and 7 A. I don't know what you're talking about.
8 were not together in this person's presence? 8 Q. Well, you were thinking about something
9 A. Other than me going to the restroom, no. We, 9 because you said years ago. You were the one that
10 I, we were pretty much together the whole time. 10 picked the date. So, what was it you were thinking
11 Q. On the evening ofFebruary 3rd, 2010, do 11 about?
12 you recall throwing a bag of trash in the garbage? 12 A. No, I said years ago we, we knew each other.
13 MR. EDWARDS: Mat date is that? 13 We used to hang out. Like we used to do little girl
14 MR. LUITIER: The evening of February 3rd, 14 stuff, go in the pool and —
15 2010, at approximately 9:00 p.m. 15 Q. No, my question was, was there a business
16 THE WITNESS: In the evening. 16 venture and you said it was years ago.
17 MR. LUTHER: Just before you got in the 17 A. It was years ago that I've known her. Any
18 Toyota Highlander. 18 type of business venture, not that I recall.
19 THE WITNESS: Yes, we did. 19 Q. Have you ever told anyone at all that you
20 BY MR. LIMIER: 20 and were forming a business venture or had a
21 Q. Okay. And do you recall what it was that 21. business venture?
22 was in that bag? 22 A. At 12, no, I don't —
23 A. There was whole bunch of clothes and 23 Q. At any, I don't care, right up until
24 everything that did not want, so we threw it out. 24 today.
25 Q. And whose c other were those? 25 A. No. ?
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1 Q. Did you ever have any sort of a business Q. And you testified that she provided you
2 venture that involved in any way, shape, or form you 2 with drugs?
3 and/or her taking showers? 3 A. Yes.
4 A. No. 4 Q. All right. Now, who provided the drugs to
5 Q. Did you ever tell anybody you did? 5 e?
6 A. No. 6 A. I have no clue.
7 Q. Did you ever have any literature or 7 Q. Well, who provided the drugs to you that
8 written material describing such a venture? 8 you just claim you took when you were with
9 A. Not that I recall, sir. 9 A. I couldn't even say. Maybe, maybe
10 Q. Ever have anything that described such a 10
11 venture or any costs associated with procuring those 11 Q. That's your boyfriend?
12 services if someone wanted to do that? 12 A. At the time he was my boyfriend.
13 A. Taking showers? 13 Q. Well, he was your boyfriend. He became
14 Q. Well, taking showers or watching the two 14 the father of your child, right?
15 ofyou take showers or any combination or 15 A. Yes.
16 permutation that you can think of. 16 Q. Okay. I mean, that would qualify as a
17 A. Not that I can think ofunless we were like 17 boyfriend, right?
18 stupid little girls who — I don't recall anything about 18 A. If that's what you call it
19 any shower or anything like that, no. 19 Q. He was a drug dealer, wasn't he?
20 Q. Did you ever tell anybody that you had 20 A. No.
21 such a business going? 21 MR. EDWARDS: Form.
22 A. No. 22 BY MR. LUTHER:
23 Q. Did you ever tell anybody you had such a 23 Q. Did he provide drugs to you on more than
24 business going with someone other than e? 24 one occasion?
25 A. A business going, no. 25 A. No, he, no, he, if anything, him and his
Page 532 Page 534
1 Q. I don't mean a formal thing, Did you ever 1 friends got together and they were stupid and young and
2 tell anybody that you were involved in any kind of 2 they did a couple of drugs, but I didn't want anything
3 activity involving taking showers for which you got 3 to do with them until I met Jeffrey. And then I wanted
4 paid money? 4 to numb myself to be around Jeffrey. And I know that I
5 A. Definitely not. I don't — I have never. 5 would take drugs hrom him occasionally.
6 And when was the last time you talked to 6 But he didn't like give them to me or sell
7 7 them to me or anything like that.
8 A. Oh, boy. It's been years. Ballpark three 8 Q. Well, what did you do, go steal than from
9 years maybe. 9 him or what?
10 Q. And where did you talk to her three years 10 A. I would probably take him from his stash or
11 ago? 11 something but —
12 A. At the trailer that I had an at. 12 Q. So, he had a lot of drugs?
13 Q. Now, your other friend, 13 A. No, not that I remember. I don't know where I
14 A. Uh-huh. 14 got these drugs from. To telLyau the truth, I really
15 Q. — when is the first time that you can 15 don't recall. I don't know if.. brought them. I
16 recall having done any type of a drug with..? 16 don't blow ifI brought them.
17 A. When we first started seeing Jeffrey we tried 17 Q. Well, did you give these drugs toe.?
18 to numb each other with like downers, you know, 18 A. No, not that I recall.
19 Percocets or somethingjust to ignore really what was 19 Q. One thing you knew was that these were
20 going on between Jeffrey and us. 20 illegal drugs, right?
21 Well, at the lad deposition you told 21 A. Yes.
22 22 Q. You knew it was against the law what you
23 who we know to bed first at u 23 were doing?
24 to Jeffrey's. Do you recall that testimony? 24 A. Yes, especially — Jeffrey Epstein knew it was
25 A. Yes. 25 whist t
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Page 535 Page 537
1 too. 1 A. Probably.
2 MR. LUTHER: Well, Jeffrey Epstein -- 2 ow, you remember going there with
3 move to strike as not responsive. 3 don't you?
4 BY MR. LUTHER: 4 A. Yes, l do.
5 Q. What Jeffrey Epstein told you was that you 5 Q. Two occasions you went and she went in the
6 shouldn't drink and shouldn't do drugs, didn't he? 6 room with you, didn't she?
7 A. He told me that he never drank or did drugs. 7 A. She went in the room with me at the beginning,
8 He was so interested in saint kind of drugs we were on. 8 at the first time, yes.
9 Q. So, not withstanding what you knew to be 9 Q. Went in the room the second time too,
10 clearly -- 10 didn't she?
11 A. He would ask, he would be asking us so how 11 A. I, I think so. I'm not sure about that.
12 does Xanax make you feel, how does coke make you feel, 12 Q. Are you aware that —
13 how does Percocets make you feel, how does this make you 13 A. I bet you have pict huh.
14 feel. 14 Q. Are you aware tha en deposed?
15 Q. He never asked you to take any of those 15 A. Have been what?
16 drugs, did he? 16 Q. Has been deposed, gone through the same
17 A. No, but he would — 17 process you are?
18 Q. He never gave you any of those drugs, did 18 A. Oh, yes, of course. She should be.
19 he? 19 Q. How are you aware ofthat fact?
20 A. No. 20 A. Excuse me?
21 Q. And you claim he had all this money. He 21 Q. How are you aware of that fact?
22, could have provided you with any drughe wanted if 22 A. Everybody's been deposed. Most all, most of
23 he wanted to give you a drug, couldn't he? 23 all these girls have been deposed.
24 A. I guess. 24 Q. Who told you that?
25 Q. And he never provided you with one single 25 A. You know, the girls talk.
Page 536 Page 538
1 illegal drug and told you he never touched drugs? Q. Okay.
2 A. No, but that's not his crime. He fondled me 2 A. It get's around town and it's in the newspaper
3 when I was 13 years old. He didn't sell me drugs. 3 every weekend, so how not know?
4 Sony, he just molested me. 4 Q. Did you talk tc
MR. LUTTIER: Move to strike. 5 A. No, I did not.
6 BY MR. LUTHER: 6 4 Okay. So, how did you know had
7 Q. He never provided you with one illegal 7 been deposed if she was deposed?
8 drug, did he? 8 MR. EDWARDS: Object to the form to the
9 A. No. extent —
10 Q. You went and got those all on your own? 10 THE WITNESS: Of course she's been
11 A. Yes. 11 deposed.
12 Q. You and your friends would go and take all 12 MR. EDWARDS: Hold on. Hold on — to the
13 kinds of illegal drugs? 13 extent that you're asking for attorney-client
14 A. Yes, because I was scared to be around an old 14 privilege information which you did —
15 man when he is touching my vagina and masturbating with 15 MR. LUMEII: No.
16 his cock in front me ejaculating all over himself, so 16 MR. EDWARDS: — in the first deposition
17 yes, I would, I think you would take drugs too. 17 and it sounds like you're going there again --
18 Q. So, were you so scared that you said I'm 18 MR: LUTHER I don't want to know
19' not going anymore? 19 anything your lawyer said.
20 A. He was like our master. He's like IM 20 MR. EDWARDS: — about talking to my
21 master. He does, anything he says, we do 21 client
22 because we are intimidated by him. We were scared of 22 BY MR. LUTTEER:
23 him. 23 Q. I don't want to know any • wyer
24 Q. So, if he said run out in front of 24 said. Have you seen a transcript of
25 traffic, you would? 25 de ition?
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Page 539 Page
1 MR. EDWARDS: Object to the form. If she 1 A. Am I religious?
2 has seen a transcript, that would obviously 2 Q. No, do you have a religious affiliation?
3 being something that her attorney has shown 3 'Are you associated with a particular in
4 her. That is not something she would have seen 4 A. Yes.
5 independent of that. So that would be 5 Q. Protestant, Catholic, Jewish?
6 protected information. 6 A. Yes, I am.
7 MR. LUTTIER I, I mean, I don't think - 7 Q. WhatIllwould that be?
8 1think if you show her a copy of a deposition, 8 A. I believer m Jesus Christ.
9 that is not protected by attorney-client 9 Q. Any particular organized -- do you know
10 privilege. If you had a discussion with her, I 10 what I mean by organized religion? There's, theres
11 agree with you, whatever your discussions were. 11 a bunch -
12 But the fact that you showed her the transcript 12 A. !would like to call myself a Christian but I
13 I don't think is protected by the privilege. 13 believe that the Lord, Catholics, Jews, Buddhism, it
14 BY MR LUTTIER: 14 doesn't matter because it shouldn't be judged. It
15 Q. Have ou ever seen a co y of the 15 shouldn't be organized. The Lord doesn't — the Lord
16 transcript o deposition? 16 doesn't organize anything. I just know that I am, I am
17 A. Not that I lcnow o 17 very spiritual and I do love the Lord very much.
18 Q. Well, did ou know that -- or strike that 18 Q. Okay. So you would characterize yourself
19 19 just as a, for lack of a better term Christian?
20 laNwere wit . Tstem on t e secon 20 A. lam very spiritual.
21 occasion when she took you there, isn't it true that 21 Q. Okay.
22 you began a conversation with Jeffrey discussing 22 A. And I pray every day.
23 what you and your mother did and how much you 23 Q. Do, do you participate it an organized
24 charged for various things? 24 religion?
25 A. False. 25 A. Do I go to chinch?
Page 540 Page 542
1 Q. Sexual nature. 1 Q. Yeah.
2 A. No. 2 A. Yes.
3 Q. Is there any reason 3 Q. And where did ou o?
4 would want to make that story tqr 4 A. I've been to Tye been to
5 MR. EDWARDS: Object to the form. 5
6 THE WITNESS: I have no idea. 6 was the last time you were at
7 BY MR. LUTTIER: 7
8 Q. And isn't it true that when you began — 8 mber '08.
9 A. She knew Jeffrey more than I did. 9 Q. And where did you go, for Christmas?
10 Q. Well, didn't -- 10 A. Before Christmas.
11 A. This is the first time or second time I had 11 Okay. And when was the last time you were
12 ever been with Jeffrey. I didn't tell him anything; 12
13. only the questions he asked nte. 13 September '08.
14 Q. And, and isn't it true that when you began 14 Q. Okay. Are you members of either of those
15 to talk to Mr. Epstein and discuss with him what you 15 churches or you just went to them?
16 and your mom did and the prices u would charge for 16 A. If you want to call me a member, I —
17 things that Mr. Epstein to leave 17 Q. Are you a registered in them?
18 the room? 18 A. — I attend, I attend yes.
19 A. I don't even know why my mother is brought up 19 Q. Do you attend it wr some o
20 in this because, no, I would never talk about my mother 20 regularity?
21 as being a prostitute. She did not raise me like that. 21 A. Yes.
22 My mother is a very beautiful person inside and out and 22 Q. And how often?
23 she would never raise me like that. 23 A. As often as I can.
24 Q. By the way, what is your — do you have a 24 Q. Okay. Well, I mean, I don't want to pin
25 religious affiliation? 25 you down to a scpecific number of!latu!.22ow many
11 (Pages 539 to 542)
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1 days a month would you say on average you go? 1 A. You guys have been there before. You should
2 A. As of tight now, one, unfortunately. 2 know.
3 Q. And when you say unfortunately, are you 3 Q. It's the same house she's always lived in?
4 unable to go more days? 4 A. No. She hasn't lived there her whole life.
5 A. No, I would love to go more days. 5 Q. Okay. But I mean while you were a kid,
6 Q Okay. Was there something that prevents 6 when, when you were living with her; is it the same
7 you from going more days? 7 place that she lived in?
9 A. I have a busy life. 8 A. No.
9 Q. Okay. What is it that you're doing that 9 Q. Bow long has she been living where she is
10 prevents you from going more days. 10 now?
11 A. Well, lam trying to get my son enrolled into 11 A. I don't know. There's been a couple of years
12 Christian school, and there's a lot ofbills that need 12 that my mother and I haven't talked.
13 to be paid and things that need to be done, errands that 13 Q. Well, when was the last time you talked to
14 need to be ran, clothes that need to be washed, food 14 your mother?
15 that needs to be bought, time I need to spend with my 15 A. Today.
16 son. 16 Q. And, and when did you talk to her?
17 Q. So, it's errands and clothes, laundry, 17 A. This morning.
16 purchasing groceries and stuff, and time with your 18 Q. And why did you talk to her this morning?
19 son that prevents you from being able to attend more 19 A. So she could pray with me over the phone.
20 frequently; is that right? 20 Q. And when was the last time you talked to
21 IVIR. EDWARDS: Object to the form. 21. her prior to this morning?
22 THE WITNESS: Stn. 22 A. Last night
23 BY W. LUTHER: 23 Q. Did I misunderstand? I thought you said
24 Q. You set your own work hours, right? 24 there was a -
25 A. Yes. 25 A. There was a period in my life that we didn't
Page 544 Page 546
1 Q. Your mother is and I may get 1 talk.
2 this name sort of, is it? 2 Q. Okay. So that's some past period of time?
3 A. Yeah. 3 A. Yes.
4 Q. Did I !announce it right? 4 Q. When did that change?
5 A. No. 5 A. Around May '09.
6 Q. w ou do pronounce that? 6 Q. And what is it that caused the change in
7 A. 7 May of '09?
8 Q. . And is she currently married? 8 A. I was living my life and she was living hers.
9 A. No. Can I have a tissue? 9 Q. What does that mean?
10 Q. And where does she currently live? 10 A. I was living my life and she was living hers.
11 A. In 11 Q. Okay. Why did that, why did that
12 Q. In what development? 12 facilitate —
13 At I don't know what the developments called. 13 m ire was taking cafe of my sister that has
14 MR EDWARDS: Can we take a split second 14 and they were going through a lot, so I left it
15 break to take grab a tissue? 15 alone.
16 MR. LUTTIER: Sure. 16 Q. My question was what caused in May of '09
17 MR. EDWARDS: 1 don't see one right now. 17 this period of estrangement between you and your
18 THE VIDEOGRAPHER: Going off the record at 18 mother to end?
19 228 pm. 19 A. I just told you.
20 (A briefrecess was held.) 20 Q. You said that your mother -
21 THE VIDEOGRAPHER: We're back on the 21 A. My mother and I, she had — my. was
22 record at 2:32 p.m. 22 taking care ofkiter who has severe
23 BY MR. LUTHER: 23 Q. That's 7
24 Q. Okay. You're saying you don't know the 24 A. Yes.
25 development that she lives in 25 9. Oka You mean duri • your riod of
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Page 547 Page 549
1 estrangement? A. Excuse me?
2 A. Yes. 2 Q. Did your mother ever discuss with you
3 Q. Okay. So, you didn't communicate with her 3 whether she had any conversations about you with
4 because she was taking care of your sister? 4 anybody else with respect to this lawsuit?
5 A. Yes. 5 MR. EDWARDS: Is this in addition or
6 Q. Did something happen in May of '09 that 6 different than the previous discussion that wm
7 changed all that? 7 discussed at the first deposition?
8 A. My sister moved away. 8 MR. LurnER: I won't know until she
9 Q. 'iwere did she go to? 9 ansmms
10 A. 10 MR. EDWARDS: But is this a separate
11 Q. And, and when she moved, did she go with a 11 occurrence from what she was asked at the last
12 boyfriend? 12 deposition?
13 A. Yes. 13 THE WITNESS: No, she's never discussed
14 Q. And who is that? 14 anything else with anyone else, no.
15 A. Wu name is 15 BY MR pima
16 Q. Do you know his last name? 16 Q. Okay.
17 A. No. 17 A Not to my knowledge.
18 Q. And she's still living in IMM? 18 Q. And if yourmothertnld ry that
19 A. Yes. historically as a child you used would she be
20 Q. Now, what's the relationship between you 20 telling the truth?
21 and your sister? 21 A. Yes.
22 A She's, she has like she's a little slow, so 22 Q. Do you mho• is?
23 we can't really relate but other than that I love her. 23 A Yes, I dm
24 Q. Well, haven't you in the past been violent 24 Q. And who is that?
25 toward your sister? 25 A Ekriumrent boyfriend.
Page 548 Page 550
1 A. Yeah. 1 Q. And do you believe him to be a truthful
2 Q. And tell us exactly what you did to your 2 individual?
3 sister. 3 A. Yes.
4 A. Well, when I was 14, 15,14, I was like 4 Q. And how long has he known your mother?
5 mentally abusive to her because I guns I was just 5 A. For 15 years.
taking out everything, all of my pain from what was 6 Q Do you know of anything he has told
7 going on with Jeffrey, and I would just take it out all 7 anybody else about what it is your mother used to do
8 on her. 8 fora living?
9 Q. What do you mean by you would take it out 9 A. No.
10 on her? 10 Q Is the first time that you've heard any
11 A. I was mentally abusive to her. 11 reference to your mother being a prostitute in this
12 Q Well, describe what it is you actually 12 case?
13 did. 13 A. No.
14 stuttered; l would make fun of her. She 14 Q. When else have you heard that?
15 has I wouldn't respect it. 15 A. I have never heard that my mother was a
16 Q. And did your sister actually have to get a 16 prostitute.
17 restraining order against you? 17 Q So, what I am saying is, is the first time
18 A. No. 18 that you have heard that issue even come up in this
19 Q. Did your sister ever get a restraining 19 case?
20 order against you? 20 A. This is the first time I am hearing this, yes.
21 A. Not that I know of. She's slow. She's not 21 Q. Did you discuss with your mother the
22 all there. She has like part =. 22 activities you were engaging in with Mr. Epstein at
23 Q. Now, did your mother discuss with you 23 the time that you were engaging in them?
24 about whether she ever had any discussions about you 24 A. I kept everything a secret until years later
25 with an else? 25 when after I had my son and then 1 told her what went
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1 1 WITNESS: I worked at
2
3
on.
. Earlier ou said at 15 you worked for 2
3
at
age-
Once I turned 18, I told everybody my
4 A. Yes, 4 BY MR. LUTHER:
5 Q. And my notes are unclear. I believe I 5 Q. Well, you worked at a place called
6 asked you, did you tell them how old you were. Do 6 when you?
7 you remember me asking you that question? 7 A. I told them I was 19 as well.
8 A. (Witness nods head). 8 Q. When you were how old, 14?
9 Q. And what did you respond? A. Yes.
10 A. I told them 1was 19. 10 Q. Okay. And then what, what was the next
11 Q. Okay. Did you provide them with any kind 11 place yobiliavent to do topless dancing?
12 ofproof/ 12 We'll do separate from to less dancing.
13 A. No. 13 A. I don't know. I worked at when
14 Q. And why did you lie to them and tell them 14 1 was 14. I worked at when I was
15 you were 19 if you were really 15? 15 15, and I worked for Jeffrey throughout all those years.
16 A. Becausei wouldn't be able to work there. 16 Q. X2v. Mfr ts_a lot of other
17 Q. Did you tell other people that you were 17 besides andMN=
18 older than you really were? 18 didn't you?
19 A. Yes. 19 A. Not when 115.
20 Q. Who else did you tell you were older than 20 Q. Well, I want to start there and keep on
21 you really were? 21 going.
22 A. Probably everybody I came across. 22 A. We already know the places I've worked at.
23 Q. So, that would be many people? 23 We've been through this. We've went through this for
24 A. Yes. 24 the last deposition.
25 Q. All of the various adult entertainment 25 Q. That's why —
Page 552 Page 554
1 places you worked at. The places, the topless bars 1 A. And we've already been through this for this
2 you worked at, did you tell all of them you were 2 deposition.
3 older than you really were? 3 Q. — I am giving you the chance to
4 *iad of time when I worked at 4 sturunarize, so let's just go down and —
5 I told everyone I was 19. Jeffrey knew 5 A. You already know the places I worked.
6 how old I was. And Jeffrey new how old every girl I 6 Q. I am asking you as to each one, how old
7 brought there was, and he wanted young girls all the 7 you told them you were.
8 time. 8 A. When I was underage, I told theml was 19
9 Q. Does that have anything to do with the 9 years old.
10 question that I asked? 10 Q. Every place that you worked?
11 MR. LUTT1EFt: 1move to strike. 11 A. Yes. Except Jeffrey's, Jeffrey knew that
12 THE WITNESS: The question you asked has 12 was 13. I'm sick of this.
13 nothing do with Jeffrey. 13 Q. So, at you told than 19. Is that
14 MR. LIJTTIER: Let's, let's go back. If 14 just the number you picked?
15 you will read the question that I asked. If 15 A. On advice of counsel I am invoking my Fifth
16 you will listen to this question, that's the 16 Amendment rights under the United States constitution.
17 one I would like you to answer. 17 MR. EDWARDS: Do you want to take a break
18 THE WITNESS: I know you guys love to get 18 or are you all right?
19 paid but — 19 MR LIMIER: Yeah, do you want to take a
20 (Ile requested portion of the record was 20 break?
21 read by the reporter.) 21 THE WITNESS: No. I want to get this done 1
22 THE WITNESS: At what period of time? 22 and over with. I am sick of it. Jeffrey is —
23 MR. LUTTIER: At any time. From the time 23 it's disgusting.
24 you first worked at one to the last time you 24 BY MR. LUTHER:
25 worked. 25 Q. Flirts xou told them tou were 19?
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A I was — on advice of counsel, l am invoking 1 a—
2 my Fifth Amendment rights under the United States 2 A. Yes.
3 Constittigis. 3 Q. — store?
4 Q. whatever, = whatever it 4 A. Yes.
5 was, you told them you were 19? 5 Q. And that was upsetting to you?
A. 6 A. Yes.
Q. whatever. 7 Q. Why was it upsetting to you?
A. I was of age. 8 A. I was trying to say hello tomitle sister
9 Okay. How about when you were at ■ 9 who was three at the time. And was mad at my
10 were you of age then? 10 father and she didn't want me talking to my little
11 A. 11 sister. So, she doesn't know the American rights
12 Q. Showgirls? 12 because she's from Mexico and she totally mazed me when
13 A. Yes, I was of a . 13 I was trying to hug my little sister.
14 Q. And how about were you 14 (Mr. Goldberger entered the deposition
15 of age then? 15 room.)
16 A. On advice of counsel I invoke my Fifth 16 THE WITNESS: I just hope Jeffrey gets
17 Amendment rights under the United States Constitution. 17 what he deserves.
18 Q. Did you wort( ata 18 BY MR. LUTT1ER:
19 A. On advice of council I'm invoking my Fifth 19 Q. And what's that, Ma'am?
20 Amendment rights under the United States Constitution. 20 A. Punishment for putting us girls through all
21 And what work did you do at 21 this.
22 22 Q. That is those things that you are talking
23 A. I'm over this shit. 23 about the times that you elected to go back to his
24 MR. EDWARDS: Let's take a break. 24 house and get paid to give him massages?
25 THE WTTNESS: No. On advice of counsel I 25 A. He demanded us to over the phone, sir.
Page 556 Page 558
1 am invoking my Fifth Amendment rights under the 1 Q. But nobody made you do it, right?
2 United States Constitution. 2 A. No. But Jeffrey demanded us for us to do it.
3 BY MR. LUTTIER: 3 And as young girls we were scared of Jeffrey. And you
4 Q. Are you fearful that you're in to be 4 know what, he will get what he deserves
5 t's see. You lived out by
5
6
7
prosecuted for something about
A. No.
Q. So, well then, what are you asserting the
?
6
7
IS A. Yes, I did.
8 Fifth Amendment for? 8 Q. He lived in Palm Beach?
9 A. Because I want to. 9 A. Yes.
10 Q. Because what? 10 Q. How many miles was it, would you say
11 A. Because I want to. 11. between those two houses?
12 MR. EDWARDS: Listen, don't engage with 12 A. I don't know, five, six.
13 him. Just read. 13 Q. And you didn't, you didn't have a car
14 BY MR. LUTTIER: 14 because you weren't driving, right?
15 Q. Do you know 15 A. No. He sent taxies to my house to come get
16 (phonetic). 16 me.
17 A. I know a 17 Q. So, then you could have said I am not
18 Q. Okay. And who is that? 18 getting in any of the taxies you wanted me to. You
19 A. My step-mother. 19 could have said I'm not going, just like a bunch of
20 Q. Married to your father, 20 your friends did, right? They said after, boom, I
21 A. Yes, sir. 21. don't want to go anymore, tight?
22 Q. And have you had a confrontation with her? 22 A. I could have said no.
23 A. What kind of confrontation is this now? 23 Q. As a matter of fact you had friends that
24 Q. Did you ever have a confrontation with 24 you took, you found them, Jeffrey Epstein didn't
25 her, a physical confrontation in the parking lot of 25 find them, ru found them.
J
15 (Pages 555 to 558)
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A. Yeah. Because he wanted me to find them. He 1
2 said you better find me a girl the next day, or I am not 2
3 going to call you anymore. 3
4 Q. And you took them to Jeffrey Epstein's and 4
5 you told them don't worry, this is what's going to 5
6 happen, ifs easy money, right? 6
7 A. Yeah, because I was tried of Jeffrey. 7
8 Q. And some of those girls went one time and 8
9 said they didn't want to go back, right? 9
10 A. C,omxt. Because they were afraid of Jeffrey. 10
11 Q. And you could have done the same thing, 11
12 couldn't you? 12
13 A. Correct. 13
14 Q. But you wanted the money? 14
15 A. I was a poor little girl who couldn't even 15
16 afford a pair of shoes, yes. 16
17 Q. You wanted the money? 17
18 A. Yes. 18
19 Q. And not only did you want the money but 19
20 you wanted to make money taking other girls there? 20
21 A. Yes. 21
22 22
23 23
24 24
25 25
Page 560 Page 562
1
2 2
3 3
4 4 MR. EDWARDS: Objection, asked and
5 5 answered.
6 6 BY MR. LUTHER:
7 7 Q. If there isn't any, fine. If there is I
8 8 want to get them that's all. Do you know of any
9 9 others?
10 10 A. No.
11 11
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15 15
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20 20.
21 21
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16 (Pages 559 to 562)
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1 responsive. Please, listen to the question.
2 2 The court reporter is going to read it back and
3 3 just answer my question.
4 4 (The requested portion of the record was
5 5 read by the reporter.)
6 6 THE WITNESS: No.
7 7
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25 MR.LUTTIER: Move to strike. Not 25
17 (Pages 563 to 566)
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16 16 Q. And you last saw Mr. Epstein in 2005?
17 17 A. I went to his house pregnant when I was --
18 18 2006, or no, I was pregnant. 1had my son 2005, and
19 19 then 1 went to his house after 1 was pregnant
20 20 Q. I believe you told us in the last
21 21 deposition the latest you could have seen him was
22 22 September of '05. Are you changing that or is that
23 23 comet?
24 24 A. Sir, you know what, when people go through a
25 25 lot of drama in their life, choose not to really
18 (Pages 567 to 570
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Page 571 Page 573
1 recall a lot of stuff but I blow I saw him after I had 1
2 my son. 2
3 Q. Well, you had your so. 3
4 right? 4
5 A. Yes. So, it could have been July, August, 5
6 September, October, November, December. Then maybe it 6
7 could have went on to '0,'06. 7
8 Q. Well, do you know? 8
9 A. I'm not positive but I know that I went there 9
10 after I was pregnant. 10
11 Q. That's all you -- 11.
12 A. That's all l can tell you. 12
13 Q. All right. 13
14 A. And he didn't want me because he doesn't like 14
15 women that had a kid regardless of what their age is. 15
16 So, I had to bring another girl. 16
17 Q. And that was upsetting to you? 17
18 A. No. 18
19 Q. You thought you were his favorite girl at 19
20 one point? 20
21. A. No. 21
22 Q. That's what you told us in the last depo, 22
23 didn't you? 23
24 A. I told I was his favorite girl? 24
25 Q. That you thought you were special and you 25
Page 572 Page 574
1 were his favorite girl? 1
2 A. He made me feel special. He made me feel like 2
3 I was his favorite girl. 3
4 Q. And it upset you when you found out there 4 you e two
5 were other people going? 5 right?
6 A. Did it upset me? 6 A. Okay. Great. Well, that goes to my son.
7 Q. Yeah. 7 MR. EDWARDS: Object to form,
8 A. No. 8 argumentative.
9 9 BY MR. LUTTIER:
10 10 Q. You would go and sell your wares, your
11 11 shoes.
12 12 A. So, what all the money I owe, or all the money
13 13 that l eam, goes to 'iv son.
14 14 Q. And you didn't even pay --
15 15 A. Not to suits.
16 16 Q. You didn't even --
17 17 A. Not to 'ceipts.
18 18 Q. You didn't even —
19 19 A. Not to paper.
20 20 Q. And you didn't even pay taxes on money you
21 21 earned, did you?
22 22 MR. EDWARDS: Object to the form.
23 23 THE WITNESS: I did pay taxes.
24 24 BY MR. LUTTIER:
25 25 Q. Did you ?ay taxes in '08?
19 (Pages 571 to 574)
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1 A. Yes, I did. 1
2 Q. And did you pay on the amount of income 2
3 you actually earned? 3
4 MR. EDWARDS: Object to the form. 4
5 THE WITNESS: It's none of your damn 5
6 business. 6
7. BY MR. LUTTIER: 7
8 Q. Do you know that filing a false tax return 8
9 is a crime? 9
10 A. Yeah, and it wasn't false. Kiss my ass. 10
11 Q. So your, your tax return is in '08 is 11
12 correct; is that right? Is that what you are 12
13 telling us? 13
14 A. No. 14
15 Q. Is it false? 15
16 MR. EDWARDS: Just read. 16
17 17
18 18
19 19
20 20
21 21
22 Q. Well, ma'am — 22
23 A. Can you tell I am suffering? I hate Jeffrey 23
24 Epstein, and I hope he burns in hell. 24
25 On advice of counsel, I am invoking my 25
Page 576 Pa.e 578
1 Fifth Amendment rights under the United States 1
2 Constitution. 2
3 Q. To anything in particular or just making 3
4 that statement? 4
S A. To the question you asked me about my taxes. 5
6 Q. That question has already been answered. 6
7 A. Oh, 0 . Next. 7
a 8
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Page 581
2 2
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4 4
5 5
6 6
7 7
8 8 Q. Who did
9 9 A. aezd o
10 10 Q.
11 11 A. I don't know his last name.
12 12 Q. Where did you meet him?
13 13 A. I don't know.
14 14
15 15
16 16
17 17
18 18
19 19 s some y you to .
20 20 A. No.
21 21 Q. Is he someone with whom you had some kind
22 22 ofrelationship?
23 23 A. Yeah.
24 24 Q. What kind ofrelationship did you have
25 25 with him?
Pa •e 580 Page 582
1 A. Our sons would play together.
2 2 Q. Do they still play together?
3 3 A. No.
4 4 Q. Was he a client of yours?
5 5 A. No.
6 6
7 7
8 B
9 9
10 10 el, o 'ow, a invasion — w
11 11 do you mean when you say you've suffered invasion of
12 12 your privacy?
13 13 A. Are you serious? Well, here is one. Here is
14 14 two.
15 15 Q. So, you're talking about things that you
16 16 did --
17 17 A. Investigators.
18 18 Q. — in the public?
19 19 A. All my damn, all these years that I've, after
20 20 Jeffrey they wanted -- invasion ofmy privacy, are you
21 21 kidding me? I can't go anywhere without anyone knowing
22 22 where I'm going. The FBI, the investigators following
23 23 me everywhere. I can't take my son out with anybody
24 24 knowing me.
25 25 Invasion ofmy privacy?. Everybody knows
21 (Pages 579 to 582).
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Page 583 Page 585
1 that Jeffrey Epstein molested me. So, if my son 1 all out. Everybody knows. Okay. You can sit there and
2 wants to go out and play with somebody, oh, no, 2 act like you, you can act like an attorney and --
3 she's the little girl that was in prostitution for 3 Q. Has the words —
4 Jeffrey Epstein, so we don't want her playing with 4 A. — say where has your name been? My name is
5 our son. 5 out there everywhere. Okay. l am the prostitute of
6 Q. So, or do they say she's the lady that 6 Jeffrey Epstein. I have brought young underaged girls
7 ems her own escort service, we don't want her 7 there. I am so horrible.
8 playing with our son? 8 My son can't play with certain kids
9 A. No one knows about that shit except you guys. 9 because ofJeffrey Epstein now. He has ruined my
10 Q. How about when you were working for 10 fucking life. He has brought me into this industry
11 another escort service? 11 that this is all I know. And now I can't even, I
12 A. How about what? 12 can't even explain to you the hard things that I've
13 Q. You don't think anybody knew about that? 13 been through my life because of Jeffrey Epstein,
14 A. No. 14 because he has taught me and many other girls how to
15 Q. How about when you were — 15 pull money from older men.
16 A. lam very discrete what I do. l don't put my . 16 Q. Let's just be honest for the ladies and
17 name in the newspaper like Jeffrey Epstein saying that I 17 gentleman of the jury: Ho didn't force you to do
18 am a prostitute or a slave for Jeffrey Epstein. 18 anything?
19 Q. How about when you were top, dancing 19 A. But he taught me from a young age —
20 topless at bars? Do you think maybe people said — 20 Q. Wait a minute. Let me finish.
21 A. I did that out of, like not locally. 21 A. — when I was 13 years old.
22 Q. So, maybe, well, 1mean — 22 Q. You --
23 A. Well - 23 A. He taught me how to get money real quick.
24 Q. You wouldn't exa tl call 24 Q. Do you —
25 A. . I 25 A. — from an old man. Don't sit here and tell
Page 584 Page 586
live in West Palm. 1 me that I was not forced or anything like that.
2 Q. So, you meant within the immediate 2 Q. That's exactly what I'm suggesting. ma'am.
3 geographic area. And maybe they said, well, this is 3 Do you believe that you owe, that you have a certain
the lady that goes and sells her wares at all these 4 le''el ofresponsibility for your own conduct?
5 topless bars; we don't want our children playing 5 A. Now I k
6 with her. 6 Q. You're.. years old.
7 A. No, not all. They see Jeffrey Epstein and my 7 A. When I was 13 years old, 1didn't, I wasn't,
8 name all over the place and they say, you know what, I 8 no, I did not have that demeanor.
9 don't even want anything to with this girl because she 9 Q. So, a what you thought, because you
10 was a prostitute for Jeffrey Epstein. 10 want to clean up your imagine for your son, right?
11 Can I talk to him without you in his ear? 11 You want him to look up —
12 Amidone talking? 12 A. Yes, I do.
13 Q. Could you just tell me one place where 13 Q. So, as part of tha ess what you
14 your name has appeared anywhere as being someone who 14 thought you would do aM is you would agree to
15 saw Jeffrey Epstein? 15 hire out to strange men whom you don't know for
16 A. It's everywhere. 16 between 3300 and $500 for what you say is to go sit
17 Q. Well, where? Just tell me one place. 17 in rooms naked with them, and that's how you thought
18 A. Where have you been? 18 you would prove?
19 Q. Just tell me one place. Can you cite 19 A. Because that's all I know. I'm Sony.
20 me — 20 Q. And Jeffrey Epstein didn't make you do
21 A. Ifs in the newspaper. 21 that, did he? You decided to do that, didn't you?
22 Q. What newspaper ever ran your name? 22 A. You know what
23 A. The Initials ofmy name? 23 Q. A whole new business that you decided to
24 Q. No, your name. 24 do on your own; is that right?
25 A. It doesn't matter. The It's 25 MR. EDWARDS: Object to form.
22 (Pages 583 to 586)
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Page 587 Page 589
1 THE WITNESS: — before! -- 1 Tape 3.
2 MR. EDWARDS: Argumentative, asked and 2 MR. EDWARDS: Before we get started I just
3 answered. 3 want to put something on the record that there
4 BY MR. LUTTIER: 4 was a hearing, I believe it was November 3rd,
5 Q. Did Jeffrey Epstein ever give you the 5 2009, and the judge suggested that the defense
6 business advice on a business plan to go out — 6 only have one attorney there. And his
7 A. Yes, he did. He gave me business advice. 7 recommendation was such because of the
8 Q. Wait. You started this in January? 8 breakdown —
9 A. You know what he told me this: He said, you 9 MR. LUTTIER: Well, let's —
10 inc girls, this is business. Let's talk business, 10 MR. EDWARDS: — in the first deposition.
11 I. You get me girls, twill pay you. Is that not 11 You can, you can make a record after. That is
12 called business? 12 fine. Was because of the breakdown in the
13 Q. So, and you quit doing that when? 13 first deposition, and he thought that that type
14 A. You get me girls, and I brought him.two girls 14 of intimidation by more than one attorney would
15 a day, one girl a day, $200 each. That's not business? 15 lead to an additional meltdown.
16 Q. And when you — 16 We have been fine thus far today despite
17 A. He taught me business and now I run business. 17 there at a minimum always being two attorneys
18 Q. And so — 18 and in the last 15 to 20 minutes not only was
19 A. Just like you run business. 19 Mark Luttier here and Bob Critton as it has
20 Q. And when did that, when did you start — 20 been all day, but Jack Goldberger was also in
21 A. Just like you learned how to do this, I 21 the room.
22 learned how to do this. 22 And once it was lined up three attorneys
23 Q. What — so, you kamed to be a 23 over there, either passing notes, talking in
24 prostitute? 24 each other's ear, and otherwise assisting in
25 A. Yes, I did. 25 the deposition or at least that was the feeling
Page 588 Page 590
1 Q. And you enjoy it? 1 from the witness, we began to have another
2 A. No, !don't enjoy it, and I can't wait to get 2 meltdown.
3 the hell out of it. 3 So, hopefully we can proceed with less
4 Q. And that's why in January of '010 you 4 attorneys and we can get through this process.
5 decided what you would do is start getting men to s But I just wanted to put on the record exactly
pay you S300 to $500 an hour to sit around naked 6 who was in the room when everything started to
7 with them, is that right? 7 break down just now.
8 MR. EDWARDS: Form. 8 MIL LUTIIER: Well —
9 THE WITNESS: Yes, that's right. 9 MR. EDWARDS: If you have something to
10 BY MR. LUTTIER: 10 say, that's fine.
11 Q. And the last time you took a girl to 11 MR. LUTHER: That just is not factually
12 Jeffrey Epstein was when? 12 correct. Mr., first of all the judge ordered
13 THE WITNESS: Did we already ask this 13 that Mr. Critton and I could be present
14 question? 14 throughout this deposition. Mr. Critton and I
15 MR. LUTTIER: When? No, the last time — 15 have been present throughout this deposition,
16 MR. EDWARDS: Object to the form. 16 and he and I have communicated throughout the
17 MR. LUTTIER: — you said you went was — 17 deposition.
18 MR. CRTITON: You're out of time. 18 Mr. Goldberger walked in here. I didn't
19 MR. LUTT1ER: Okay. 19 put a stopwatch on how long he was there. He
20 THE V1DEOGRAPHER: Going off the record at 20 is not even here now. He was here for maybe
21 3:14 p.m. This is the end of Tape 2. 21 ten minutes. I had no communication at all
22 (A brief recess was held and 22 with him. He carne. He sat here. He got up
23 Mr. Goldberger did not re-enter the room.) 23 and he walked out.
24 THE VIDEOGRAPHER: We're back on the 24 This breakdown that you're talking about
25 record at 3:24 p.m. This is the start of 25 occurred Ions before Mr. Goldberger ever of
23 (Pages 587 to 590)
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Page 591 Page 593
here. So, I dispute — 1 MR EDWARDS: mats the —
2 THE WITNESS: No. 2 MR. LUTHER: Defendants unverified
3 MR. LUTHER: — the facts, but it's sort 3 better answers to first interrogatories to
4 of a moot issue now anyway, so — 4 Plaintiff. Later I'm going to come to the
5 MR. EDWARDS: But if we're going to get S Plaintiffs supplemental better answers to
6 into that, then every time he comes into the 6 Defendant's Interrogatory No. 19.
7. room do we need to now put it on the record 7 MR. EDWARDS: Okay. But you said the date
8 that he is in the room? 8 of service meaning you saved on us?
9 MR. LUTHER: I have absolutely no 9 MR LUTHER: No, no. Your answers,
10 problem — 10 better answers.
11 MR. EDWARDS: And each time — 11 MR. EDWARDS: Got it. I am looking as the
12 MR. LUTTIER: Anytime he comes in, we'll 12 same document you are.
13 stop him and well let him know he can't come 13 BY MR. LUTHER:
14 in here. Quite frankly, if you would have said 14 Q. All right. Ma'am, in response to some
15 something to me about it, I was examining the 15 interrogatories you stated that from the end of 2007
16 witness, I would have stopped right then and 16 to November of 2008 you worked at
17 said, Jack, get out of the room. 17 earning S1100 a week. So that would have been a
18 MR. EDWARDS: And I know in all fairness 18 period of approximately one year; is that right?
19 to what you just said I am not saying that to 19 MR. EDWARDS: Read.
20 you was not factually accurst; what you just 20 THE WITNESS: On advice of counsel I am
21 said, but you weren't able to see what was 21 invoking myFifth Amendment rights again under
22 behind you, the passing of the cellphone and 22 the United States Constitution.
23 other things that the witnesses notices. 23 BY MR. LUTHER:
24 I am just telling you that this impacts 24 Q. From, f of time that
25 the deposition. So, I just want to make it 25 you worked at what did you do for
Page 592 Page 594
1 clear so that you would know exactly what's 1 your money?
2 happening and maybe we can get through this. 2 A. On advice of counsel I'm invoking my Fifth
3 You know, it's all of our goals to get through 3 Amendment rights under the United States Constitution.
4 this day. So, I,I think the witnesses is 4 Q. In continuing in answering that particular
5 ready if you're ready, Mr. Luttier. 5 imar.saici that in 2008 worked at
6 MR. LUTTIER: I'm ready. 6 . Where is
7 MR. EDWARDS: Okay. 7 located?
8 MR. CRITTON: What time did we start 8 A. On advice of counsel I'm invoking my Fifth
9 because we haven't we've been on the record, Amendment rights under the United States Constitution.
10 but we haven't asked a single question. 10 Q. What did you do at
11 THE VIDEOGRAPHER: les 3:28 right now. 11 A. On advice of counsel I'm invoking my Fifth
12 Three and a half minutes. 12 Amendment rights under the United States Constitution.
13 MR. CRITTON: Thank you. 13 Q. Did you have any communication with
14 BY MR. LUTTffiR: 14 Jeffrey Epstein after the phone call you made to him
15 Q. I am now referring to your, your 15 following the FBI's interview ofyou?
16 interrogatory answers. These are answers that you 16 A. I talked to ing Oh, my God. I don't know
17 gave to written questions that were sent to you in 17 what I am going through. I'm like shaking.
18 this case. And they are entitled Defendant's 18 Q. I am talking about now a conversation with
19 unverified better answers to first interrogatories. 19 Mr. Epstein.
20 I believe they may have been marked as Exhibit 1 to 20 MR. EDWARDS: The question was, did you
21 the first deposition, but there is only one set of 21 talk to him after you called him —
22 them. 22 MR. LUTHER: Right
23 • MR. LUTHER: And Brad, they are, the date 23 MR. EDWARDS: — after the FBI statement?
24 of service on, I don't know, wait. Date of 24 MR. LUTHER: Right.
25 service is August 4th, 2009. 25
24 (Pages 591 to 594)
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BY MR. LUTTIER: 1 with Mr. =bout being a witness? That is what
2 Q. And the date of your FBI statement for 2 would he be offering as testimony in the case?
3 your information was April 241h, 2007. Did you have 3 A. What would he be offering?
4 any conversation with Jeffrey Epstein after that . 4 Q. Yeah. Why did you ask him about being a
5 date? 5 witness?
6 A. After I, after I had called my attorney? 6 A. I didn't ask him about being a witness. I
7 Q. After April 24th, '07, which is the date 7 .told him about what happened to me when 1 was 13 years
8 that you gave a st FBI. 8 old.
9 A. I talked toatlisic) or whatever her 9 Q. Okay.
10 name is. 10 A. I'm not asking anybody to be a witness as of
13. Q. Did you have any conversation with Jeffrey 11 right now.
12 Epstein? 12 Q. What is -- •
13 A. No. I don't think so, no. 13 A. I'm my own witness.
14 Q. Other than the witnesses you have listed 14 MR. EDWARDS: Listen to his question.
15 in answer to Interrogatory No. 5, do you know of any 15 THE WITNESS: I am trying. I can't think
16 other witnesses or do you intend to call any 16 right now.
17 witnesses in the trial of this matter? 17 MR. EDWARDS: He wasn't asking you about
18 A. What? 18 being a witness.
19 MR. EDWARDS: Objection. Attorney-client 19 BY MIL WrrIER:
20 privilege. I don't want her answering 20 Q. Where does Mr. =live now?
21. questions as to whether, as to information that 21 A. West Palm Beach. •
22 she and I have spoken about in terms of what 22 Q. est Palm?
23 witnesses will be called at trial or our trial 23 A.
24 strategy. 24 Q. When did you last have communication with
25 25 him?
Page 596 Page 598
1 BY MR. LUTHER: 1 A. January 3rd, 2010.
2 Q. Have you spoken to anyone with respect to 2 Q. And for what purpose did you have
3 their willingness or your intention to call them as 3 communication with him on that date?
4 a witness to the trial of this matter? 4 A. I had to give him some of his clothes.
5 MR.. EDWARDS: Not who I have spoken to. 5 Q. When was the last were in
6 MR. LUTHER: Yeah, you. 6 tion with Mr. that would be
7 THE WITNESS: What? 7
8 BY MR. LUTHER: 8 A. lie's my son's father. So, I talked to him two
9 Q. Have you spoken to anybody about being a 9 weeks ago.
10 witness • • is matter? 10 Q. And where was he when you talked to him?
11 A. 11 A. Fort Myers.
12 Q. Anyone else? 12 Q. And do you know how he's employed now?
13 A. Not that I know of. 13 A. .No. He says he's not employed.
14 Q. And when did you speak with Mr. 14 Q. Have you discussed with him in the last
15 about being a witness? 15 year anything about this lawsuit?
16 A. May `09. 16 A. Yes. .
17 Q. And what is it you told him or asked him 17 Q. What have you discussed with him?
18 about being a witness? 18 A. I told him I'm going through a lawsuit.
19 A. I told him that Jeffrey Epstein molested me 19 Q. And what did he say?
20 since I was 13 years old. 20 A. He said okay.
21 Q. Okay. And he wasn't around at the time 21 Q. Have you asked him to be a witness?
22 that you alleged Mr. Epstein molested you, correct? 22 A. No.
23 A. He wasn't around at the time when Jeffrey 23 Q. Have you ' nication with any .
24 Epstein was molesting me. 24 other members of Mr, family in the last
25 .
aS= Okay. S r what stdid you confer 25 two years?
25 (Pages 595 to 598)
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1 A. Yes. 1 Q. Is that the last time she's seen your son?
2 Q. 2 A. Approximately, yeah.
3 AA. 3 Q. ' ur son when you were
4 Q. illi
Who is nit c). 4 down at m 8:00 at night until
5 A. His sister. 5 in the
6 Q. And where does she live? 6 A.
7 A. Wellington. 7 Q. I ho you
8 Q And for what purpose have you been in 8 identified earlier? rather?
9 touch with her? 9 A. Yeah.
10 A. She's my son's aunt 10 Q. And where was she watching him?
11 Q. And with what degree of frequency are you 11 A. At my house.
12 in communication with her? 12 Q. So, does she come spend the night at your
13 A. She asked me to attend her wedding via e-mail 13 house?
14 this March of '010. 14 A. Yes.
15 Q. Have you discussed with her anything about 15 d there, was there ever a time that you
16 Mr. Epstein? 16 and 1M lived together?
17 A. No. 17 A. Yes.
18 Q. Does she to the best of your knowledge 18 Q. When was that?
H know anything about it? 19 A. When we were 13, 14.
20 A. Yes. 20 Q. Thirteen and 14. Was any adult living
21 Q. Did you say no? 21 with you?
22 A. Yes. 22 A. My father.
23 Q. Does she know anything about? 23 Q. Since you were 13 or 14 has a ever
24 A. Yes. 24 lived with you?
25 Q. What does she know about it? 25 ANo. 4
Page 600 Page 602
1 A. That Jeffrey Epstein's a child molester. 1 Q. Did you tell why you needed
2 Q. And how did she get that information? 2 to have haisall night when you were
3 A. From the news, from friends, from the 3 down at
4 neighbor/mod -- A. Hold her I need to work.
5 Q. Did — Q. Do you tell her what you do for work?
6 A. From her brother. A. Yes.
7 Q. — has she asked you any questions about 7 Q. What did you tell her?
8 your relationship or interaction with Mr. Epstein? 8 A. I sell lingerie and shoes and purses and Mary
9 A. She said I am sorry that you're going through 9 Kay.
10 the trauma that you're going through. 10 Q. Do you have any personal knowledge of the
11 Q. Have you tmitation with any 11. matters about which the witnesses listed in your
12 other member of Mr. family? 12 answers to interrogatories that these witnesses
13 A His mother. 13. have, have information about?
14 Q. illy t's her name? 14 MR. EDWARDS: Objection, attorney-client
15 A. 15 privilege. And we do this all the time.
16 Q. And where is she located? 16 BY MR. LUITIER:
17 A. Fort Myers. 17 Q. This is just a list as prepared by your
18 Q. And when did you last have communication 18 lawyer. You don't know what any one of these
19 with her? 19 witnesses would say?
20 A. I don't know. A year ago. 20 MR. EDWARDS: And if she does, it's going
21 Q. And for what purpose did you have 21 to be information that I have talked to her
22 communication with her at that time? 22 about which you know is protected by
23 A. Dropping my son off with her. 23. attorney-client privilege and so do L
24 24 If you're asking her independent of her
25 2: SC, 25 information I have told her, fine.
4. , ...••••••••••••4
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1 MR. LUTTIER: That's exactly what I am 1 all that you said I don't want to do this and Jeff
2 asking her. 2 said you had to do it anyway?
3 MR. EDWARDS: Okay. Let's ask it that way 3 A. Yeah. I told him that at times I did not want
4 because it doesn't sound like that. 4 to bring girls, and he says, yes, I want you to do it
5 BY MR. LUTTIER: 5 anyway; you need to do it anyway.
6 Q. Do you know of any information that these 6 Q. And did you tell all the girls that you
7 witnesses have based on your communications with 7 brought that Jeffrey would respect their wishes, and
8 them? 8 if they were uncomfortable doing anything, that they
9 A. Excuse me? 9 should just tell him that, and he wouldn't ask them
10 Q. Do you know any information that any of 10 to do anything that they weren't comfortable doing?
11 these witnesses have about this case based on your 11 A. Yes, because I was scared.
12 personal contact with them? 12 Q. And that's, in fact, how he treated you,
13 A. What witnesses? 13 fir?
14 Q. That are listed in the Answers to 14 A. Yes.
15 Interrogatory 5. 15 Q. You previously earned a degree as an
16 MR. EDWARDS: Just answer his question, 16 esthetician; is that right?
17 yes or no. 17 A Yes.
18 THE WITNESS: No. I don't know these 18 Q. And you now earned a degree since going to
19 people. 19 Mr. Epstein in massage therapy, correct?
20 BY MR. LUTTIER: 20 A. Yes.
21 Q. On any visit that you went to see Jeffrey 21 Q. And you emillairnom the same
22 Epstein, did he ever ask you to do anything that you 22 school located on
23 said you did not want to do? 23 A. Yes.
24 A. Yes. 24 Q. And you could pursue a profession as an
25 Q. What did he ask you to do that you said 25 esthetician, a massage therapist if you so chose,
Page 604 Page 606
1 you didn't want to do? 1 could you not?
2 k At one occasion he wanted to stick his lingers 2 A. No, not as a massage therapist.
3 like all the way inside of me and 1 said no? 3 Q. Why not?
4 Q. And what did he then do when you said no. 4 A. Because I've told you once before I need to
5 A. He said okay. So then he just penetrated my 5 take the nationals.
6 vagina with his tinge's. 6 Q. But no one has prevented you from taking
7 Q. What did he, did he —when you said you 7 test, right?
8 didn't want him to do that, did he respect your 8 A. I have to wait to take the test. It only
9 wishes and not do it? 9 happens twice a year.
10 A. No. Actually he, he pushed it. He tried to 10 Q. And has — did you pass the first
11 do it and he said, okay, no, it's going to be okay. 11 opportunity you had?
12 It's going to be okay. And I backed off and I said no. 12 A. No.
13 Q. And then he stopped? 13 Q. Okay. So, when's, when's the test coming
14 A. Then he decided to respect my wishes. 14 up?
15 Q. Okay. Any other — and this is on one 15 A. In a few months.
16 occasion? 16 Q. And are you going to take it?
17 A. Many occasions. 17 A. Yes.
16 Q. Well, on — so on many occasions he would 18 Q. And you could have been working as an
19 say he wanted to penetrate your vagna. You would 19 esthetician ever since you went to Jeffrey
20 say you didn't want — well, actually what you said 20 Epstein's?
21 was he wanted to penetrate your vagina deeply I 21 A. And I did work as an esthetician.
22 think And, and you said no and he respected your 22 Q. No one has prevented you from doing that,
23 wishes and didn't do it? 23 correct?
24 A. Correct. 24 A. No.
25 Q. Okay. Was there ever anything that at 25 9. You made the decision to drop out of
27 (Pages 603 to 606)
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school before you ever met Jeffrey Epstein, did you 1 six. But then I did go back and I got my high school
2 not? 2 diploma, and like you said I have two degrees.
A. I'm pretty sure I was going to school when I 3 Q. When did you get your, your GED?
Was seeing Jeffrey Epstein. 4 A. Yes.
5 Q. But, but you made the decision to drop out 5 Q. When did you get that?
6 based on other facts and circumstances that had 6 A. What I turned 18.
7 nothing to do with seeing Jeff Epstein; isn't that 7
a correct? 8 Al
9 A. Excuse me? Q. So, you got a high school equivalency
10 Q. You decided to drop out ofschool for your 10 diploma at the same time you would have gotten a
11 own reasons particularly 1think you said because 11 high school graduation certificate —
12 you got pregnant, didn't you? 12 A. Correct.
13 A. No. 13 Q. -- had you stayed in school?
14 Q. Well, why did you decide to drop out of 14 A. Correct.
15 school? 15 Q. And then you were free to pursue the same
16 A. I was trying to find girls to bring to 16 pursuits as anybody else that had graduated from
17 Jeffrey's house. 17 high school whether that would be college or a trade
18 Q. Well, didn't you tell us the last 18 school or whatever you want to?
19 deposition that you dropped out when you got 19 A. No, no. If I would have stayed in school, I
20 pregnant? 20 could have got some type ofscholarship. I could have
21 A. I was going to school when I was pregnant. 21 had many opportunities in school to learn higher
22 Q. Yeah. And then you dropped out, right? 22 education than just the GED.
23
24
25
ass A. I dropped out when I was
drop out of
and then go to
pregnant. 23
24
25
Q. Well, when you got —
A. And I could have — traveled and I could have
went to a college, a bigger college, a state college.
Page 608 Page 610
1 A. Because ever since I met Jeffrey I— before 1 Q. How do you know that?
2 Jeffrey I made wonderful grades. And then ever since I 2 A. les common sense.
3 met Jeffrey my grades went down and I was failing, so I 3 Q. Well, you don't know what your grades
4 had to go to a school to bring my grades a up. 4 would have been, right?
S 1i. But you opted to drop out of the 5 A. No, I don't know what my grades would have
6 MIE before you graduated? 6 been.
7 A. Yes. I was four months pregnant 7 Q. And at —
A. Do you know what tomorrow is grimy, bring?
8
9
Q. And that's why you dropped out?
A. Well, I needed to make money to buy a house, a 9
10
siAt went
the
time
that
you
into MI
you were qmillpally failing, weren't you?
10 trailer so I could have my baby.
11 Q. Because you were pregnant? 11 A. Yeah, but they help girls, young girls
12 A. Yes. 12 bring up their grades so you can go back into high
13 Q. Had you not been pregnant, you would have 13 school and accomplish making more, bettering your grades
14 continued in school, correct? 14 so you can get a scholarship.
15 A. I can't answer that question. I don't know. 15 Q. Well, in fact you got a scholarship for
16 Q. Well, the point is the direct reason why 16 your massage therapy, didn't you?
17 you dropped out was you were pregnant? 17 A. No. How could I?
18 A. And I was making so much money off of Jeffrey 18 Q. Did you tell us in the last deposition
19 that I didn't think school was so necessary at that 19 that you got some kind of scholarship for going
20 time. 20 there?
21 Q. Did you consult with your parents or any 21 A. I didn't get a scholarship for going. No.
22 counselors about that? 22 I've never got a scholarship.
23 A. I didn't tell my parents about Jeffrey. 23 Q. Did they lend you money to go to school
24 Q. How much were you making at that time? 24 there?
25 A. 1WaSJnakilik $200 pretty much a day or 400 or 25 A. For massage therapy but not for esthetics.
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1 Q. That's what I was talking about was 1
2 massage therapy. 2
3 A. That's not a scholarship. 3
4 Q. Okay. 4
5 A. That's a loan that I have to still payback. 5
6 Q. Did you ever travel anyplace with Jeffrey 6
7 Epstein? 7
8 A. Nope. 8
9 Q. Are you — you're a person that uses the 9
10 computer now, correct? 10
11 A. Yep. 11
12 Q. Did you ever communicate with Jeff Epstein 12
13 on the computer? 13
14 A. No not that I recall 14
15 15
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Page 621
1 1 BY MR. LUTHER:
2 2 Q. Did you she ever approach you about that?
3 3 A. No.
4 4 Q. Did she ever tell the police she was
5 concerned about that?
6 A. No.
7 MR. EDWARDS: Object to the form.
8
9 9
10 10
11 11 MR. EDWARDS: Form, predicate.
12 12 MR. CRITTON: What's the form?
13 13 THE WITNESS: She was probably concerned.
14 14 MR. EDWARDS: You're asking -
15 15 MR. LUTTIER: Was your mother -
16 16 MR. EDWARDS: You're asking to tell
17 17 you whether she knows how her mother was
18 18 feeling at some certain time.
19 19 Y MR. LUTHER:
20 20
21 21
22 22
23 23 MR. EDWARDS: Same objection.
24 24 THE WITNESS: She probably was concerned,
25 25 yet
Page 620 Page 622
1 A. Yes. 1 LTIER:
2 Q. Do you know of -(phonetic)? 2
2 A. Yeah. 3
4 Q. Who is that? 4
5 A. Ifs actually my sister's son or daughter's 5
6 father's cousin. 6
7 Q. Sister's daughter? Your sister has a 7
8 daughter? 8 Tr " . • i gcm,
9 A. Yes. 9 predicate.
10 Q. So daughter's cousin's father? 10 THE WITNESS: A mother's love. I don't
11 A. y's father, his cousin. 11 know. I can't speak for my mother. I am
12 ii?kay. When did you first meet 12 sorry.
13 13 BY MR. LUTTIER:
14 A. Probabl knew him since]. was 11. 14 Q. Were you doing something that gave her
15 15 that concern?
16 16 MR. EDWARDS: Object to the form,
17 17 speculation.
18 18 THE WITNESS: I don't know.
19 19 BY MR. LUTHER:
20 20 . Are a aware of the fact that your father
21 21
22 22 uly of
23 23 '04?
24 24 A. Ile fi led for what?
25 25 What's called a
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1. A. Concern?
2 2 Q. Yeah. I mean were you afraid?
3 A. I never went to any program or anything. 3 A. Only for that one night that he was on coke.
Q Yeah, but do you know he filed a petition 4 He was just trying to, like, get in my house and I
5 in the court claiming that you come home when you 5 didn't want him in there.
6 want to, you're in trouble with the police, and that 6 o* ou know a lady by the name of
8
9
know he filed that in July of'04?
A. No.
Did you 7
8
9
Q.D#
Q. How do you know
10 Q. You didn't know that? 10 A. Ob, my. I know herii.r
11 A. (Witness shakes head.) 11 Q. Who is
12 Q. you, in fact, taking 12 A. A friaamine.
13 in July of'04? 13 Q. Where did ou meet ?
14 A. Yes. I apologized to my father. 14 A 'Through yfriend.
15 Q. So, he had a legitimate concern at that 15 Q. And wbos boyfriend?
16 time? 16 MR. EDW : you ve a question,
17 MR. EDWARDS: Form. 17 Bob?
18 THE WITNESS: Yes. 18 MR. CRITTON: He was telling me to ask her
19 BY MR. LUTTIER: 19 what n's --
20 And with what degree were you taking 20 IvfirEDWARDS: Oh, sony --
21 at that time? 21. MR. LUIT1ER: -- full name is. We'll get
22 A. I was a confused little girl with Jeffrey 22 to that.
23 Epstein and that always, leaving Jeffrey Epstein's house 23 MR. EDWARDS: Okay.
24 always lead me to do more drugs and more drugs. I was 24 THE WITNESS: I don't — oh, God, I don't
25 uncomfortable about my body. 25 remember his name but they were both no good.
Page 624 Page 626
1 Q. What were you — 1 They were like gang members.
2 A. I didn't like the way Jeffrey made me feel. 2 BY MR. LLITTIER:
3 Q. What were you uncomfortable about your 3 Q. That+is 7
4 body about? 4 A. No, and her boyfriend.
5 A. I felt insulted. I felt used. 5 Q. Okay. you don't remember the
6 Q. Did you tell him that? 6 boyfriends's name? How did you — what was your
7 A. No. 7 relationship with
8 Q. Did you tell anybody that? B A. AssociatePPIII, in a while.
9 A. Yeah. 9 Q. When did you first meet her?
10 Q. Who did you tell? 10 A. In — I don't know. Maybe when I was 14.
11
12
A. a
Q. On the, on the way over to Jeffrey
11
12
Q. Did she live in your neighborhood?
A. No.
13 Epstein's when you were taking her there? 13 Q. How did you meet her?
14 A. Yeah. We would tell each other that we didn't 14 A. I'm not sure.
15 like the way we felt. 15 Q. Was she a friend?
16 Q. Did tu file a complaint that your 16 A. She became an associate.
17 boyfriend was stalking you? 17 Q. Is there a difference between an associate
18 A. Yes. 18 and a friend?
19 Q. Was be, in fact, stalking you? 19 A. Yeah. A friend is someone who's always by
20 A. He got -- he was on coke one day, and I was 20 your side and who you can talk to daily, and an
21 scared because he was trying to get in the house and I 23. associate is just someone you can, that you know.
22 didn't want nothing to do with him. 22 Q. Did you socialize with her?
23 Q. Did that give you some concern? 23 A. Yeah.
24 A. Excuse me? 24 Q. What kinds of things did you do with her?
25 Q. Did that give you concern? 25 A. Not good things.
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1 1 A. Yeah.
2 2 Q. And she threatened to kill you?
3 3 A. Yeah, she threatened a lot of stuff.
4 4 Q. And did you believe she had the capacity
5 5 to do that?
6 6 A. No.
7 7 Q. What gang was she in?
8 A. y(phonetic).
9 Q. did you know her to be a violent
10 10 person?
11 Q. And this was during the time that you were 11 A. Yeah. But she's like 80-pounds soaking wet so
12 seeing Mr. Epstein? 12 Tut not worried about her. She's just lost and God
13 A. Yeah. 13 bless her soul.
14 Q. What else did you and she do together? 14 Q. Now, let's talk about Mr., is it =or
15
16
17
A. Nothing.
Q. Did you-all live together at some point?
A. I asked her to -- she asked me if she could
15
16
17
a (phonetic)?
Q. "And you have described earlier a
18 room with me when I was living in my trailer and 1gave 18 confrontation that you had with him. And was his
19 her a chance. About a week later 1found out that she 19 mother present for that confrontation?
20 was not the kind of friend for me at all and she was 20 A. Yes.
21 into no good things. And I have a son so I couldn't 21 Q. And, and did it initially start out that
22 have her around. 22 Mr.t rh was physically abusive towards his
23 Q. What do you mean she was into no good 23 mo
24 things? 24 A. Yes. I had told him to leave and his mother
25 A. She was into drugs and stealing and -- 25 came to pick up his daughter from my house. When she
Page 628 Page 630
1 Q. Did you and she have a physical 1 arrived, he started pushing and shoving his mother into
2 confrontation? 2 the car. I could tell that he was on drugs. So, I said
3 A. She brought --1told her when she moved in 3 this is uncalled, uncalled for. I called the cops and
4 for that one week I told her do not bring anyone into 4 that was that. He ran. I guess you can say 1have a
5 this house. She brought a man into my house. I opened 5 good heart and I give the wrong people chances.
6 her bedroom door, found her giving him oral sex. I got 6 Q. Well, that was one incident when, when the
7 angry. I said, please leave. She was on drugs. 7 mother was present, right?
8 She got angrier and came into the bathroom 8 A. Yes, and that night actually --
9 and hit me or tried to hit me on my head. So, I 9 Q. There was a second incident, was there
10 pretty much held her down until the cops came 10 not?
11 because 1called the cops to get her out. 11 A. Yes. That night he — that's when he pushed
12 Q. Was it an upsetting event to you? 12 me down a couple times and that's when I hit him and
13 A. No. I just couldn't wait for her to get out. 13 then he spit blood all over the house. And that's when
14 Q. Was that a common thing for you to have 14 D, DCF got involved. So, 1, three days later,
5 fistfights with other women? 15 immediately moved out of the house and moved to
16 A. No. I didn't throw a fist. No, it was not a 16 And the next thing I know the week that 1move
17 common thing. 17 . wed at m house.
18 Q. And did she threaten you on the way out? 18
19 A. Yes. 19
20 Q. And you said she was in a gang? 20
21 A. Yeah. 21
22 Q. And what did she tell you on the way out? 22
23 ' A. O6,1 don't remember. I'm going to regret it. 23
24 Q. Well, did she say, I am going to get you, 24
25 bitch? 25
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1 A. Yes.
2 2 MR. LUITTER: Let's mark this as our next,
3 3 whatever number we're on.
4 4 THE COURT REPORTER: Five.
5 5 MR. LUTTIER: Five.
6 6 (Defendants Exhibit No. 5 was marked for
7 7 identification)
8 8 BY MR. LUTTIER:
9 9 Q. Let me show you what is now marked as
10 10 Exhibit 5 and ask ou if that's a co of the
11 11
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10 10 MR. LUTT1ER: Let me mark that as 6, our
11 11 next. And ask you if you can identify this
12 12 document.
13 13 (Defendants Exhibit No. 6 was marked for
1.4 14 identification.)
15 15 THE WITNESS: I've had some crazy
16 16 boyfriends, but for three years everything's
17 17 been fine.
18 18 BY MR. LUTHER:
19 19 Q. Let a show ou what has been marked as
20 20 Exhibit 6.
21 21
22 22 A. tat a outa.
23 23 MR. EDWARDS: lie was just showing it to
24 24 you.
25 25 THE WITNESS: Yes, I saw it before.
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1 3. A. No.
2 2 Q. Do you know if any of them have consulted
3 3 with any lawyers about that other than your lawyers?
4 4 A. No. What they want to sue me along with
S S Jeffrey?
6 6 Q. Have you ever discussed yourself with them
7 7 their feelings about you having taken them to see
8 8 Mr. Epstein?
9 9 A. Yeah.
10 10 Q. ./that did they tell you?
11 11 A. is very sensitive towards it. She
12 MR. LUTTIER: I need to take a quick 12 didn't like it at all. She just was a poor little girl
13 break. 13 that I guess was influenced by me to go to Jeffrey's
14 THE VIDEOGRAPHER: Going off the record at 14 house.
15 4:19 p.m. 15 Q. But I mean has she ever asked you why did
16 (A briefrecess was held.) 16 you do that knowing what you knew or anything like
17 THE VIDEOGRAPHER: We're back on the 17 that or said she holds you responsible?
18 record at 4.30 p.m. 18 A. In 'don't 'mow the exact words but
19 BY MR. LUTTIER: 19 she's definitely came to me and said why would you even
20 Q. Do you actually, yourself, call 20 do that, why would we go there? You know, it, it hurts
21 Mr. Epstein's home asking him if you could come 21 our self-esteem.
22 work, did you not? 22 And in M.'s aspect she was extremely
23 MR. EDWARDS: Object to the form, 23 scared to go the first time. And me being one of
24 predicate, time-frame. 24 her best friends at the time, she just finally wont
25 25 after I begged her many times when I couldn't fmd
Page 640 Page 642
1 BY MR. WITIER: 1 any other girl. And no, they both didn't like it.
Q. During this period of time that you were 2 Who would like it?
3 going to see Mr. Epstein. Sometimes you called and 3 Q. Did you have any friends better thenM,
4 asked his people at his house whether, you know, you 4 You know, would you consider her, she was your best
5 could come work, did you not? 5 friend, or is your best friend?
6 A. Yeah. Because he told me to call if I had a 6 A. At that time, no.
7 girl. SO, I would call and ask is he available. 7 Q. Who is your best friend now?
8 Q. Now, I want to askot couple questions 8 A.
9 about your ttke friends, and again M. 9 Q. .How about now?
10 A. Excuse me. 10 A. My son.
11 Q. You took to Mr. Epstein, did you 11 Q. Okay. Other than your son, a friend not
12 not? 12 family. is she, is she your best friend still?
13 A. Yes, I did. 13 A. Jesus, myself, my son. Why are you looking at
14 Q. How many times did you take her? 14 me crazy?
15 A. I dolifiv. 15 Q. Is she your best friend was the question.
16 Q. Has orIII. or anyone else that 16 A. I don't have a best friend. Actually, yes, l
17 you took to Mr. Epstein discussed with you or anyone 17 do.
18 else that you know of the potential for them suing 18 Q. Who?
19 you? 19 A.
20 A. Who suing me? 20 Q. Who is she?
21 Q. My girl that you took to Mr. Epstein. 21 A.
22 A. No. • 22 Q. Is she another person that is suing Jeff
23 Q. Do you know if any of them talked to their 23 Epstein?
24 lawyers about suing you as a result of you taking 24 A. Nope. She was affiliated with
25 them to see Mr. Epstein? 25 who died.
ti 4006......146.44.114 ••••>...••••••••
36 (Pages 639 to 642)
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I Q Wbala? 1 times you actually went?
2 A. Yeah. 2 MR. EDWARDS: Form.
3 'allow was she affiliated with 3 THE WITNESS: What does that mean?
4 4 MR. EDWARDS: Answer if you know what that
5 A. She was good friends with ha and I met 5 means. Do you have physical proof, videotape.
6 through her. And If took 6 Answer his question if you know what the answer
to Jeffiey Epstein's house. 7 is..
8 Q. Where does live? THE WITNESS: No. No one videotaped me
9 A. Rhode Island. 9 and no, we didn't keep a log, no.
10 Q. Do you have the phone number for this 10 BY MR. LUTIIER:
11 babysitter you say you use? 11 Q. There is no record that you could consult
12 A. Yes. 12 that would say I !mow I went 21 times or exactly how
13 Q. 13 many times because you kept a record of it?
14 A. Yes. 14 MR. EDWARDS: Font
15 Q. What's her number? 15 THE WITNESS: No.
16 A. I don't know it off the top of my head. 16 MR. EDWARDS: This is outside of whatever
17 Q. Is she listed in the phone book? 17 records are in your client's possession.
18 A. Probably. 18 BY MR. LUTTIER:
19 Q. Is she — you say she lives in the 19 Q. And since you and ed.. are
20 Acreage? 20 all represented by the same lawyer, do you recognize
21 A. Yes. 21 that there is an inherent conflict amonathree
22 Q. Is she married? 22 in terms of any accusations that M. and
23 A. No. 23 would have against you for taking them to
24 Q. Have you ever been to her house? 24 Mr. Epstein?
25 A. Yeah. 25 MR. EDWARDS: Object to the form.
Page 644 Page 646
Q. Does she rent, does she own, do you know? 1 THE WITNESS: I don't understand what the
2 A. No. 2 hell —
3 Q. Live alone or with somebody else? 3 BY MR. LUTTER:
A. Her brother. 4 Q. There is a conflict of interest.
Q. Same last name -- 5 Mr. Edwards can't represent one, one client suing
A. I don't know. 6 another one of his clients; you recognize that,
7 as her and her brother, last name is 7 don't you?
a 8 MR. EDWARDS: Form.
9 A. I don't know. • 9 THE WITNESS: Okay.
10 THE VIDEOGRAPHER: Your Sc is on your 10 BY MR. LU1TIER:
11 chair. 11 Q. Have you seen deposition?
12 BY MR. WITTER: 12 A. No.
13 Q. Now, you've told us when you believe you 13 Q. Have you been told anything about it?
14 first went to Jeffrey Epstein and when you went the 14 A. No.
15 last time. If I and I may have asked you at the 15 O. Have you been told anything about
16 last deposition: You have no physical proof of when 16 case .
17 you actually went, right, the actual dates that you 17 A. No.
18 went? 18 Q. Who is actually representing you now? Do
19 MR. EDWARDS: Object to the form. 19 you know the name of the law firm that now
20 MR. LUTTIER: That would be like a 20 represents you?
21 calendar or notes, something like that. 21 A. Whatever this law firm's called.
• 22 MR. EDWARDS: Form. 22 Q. Is it — did you sign a new fee agreement
23 THE WITNESS: Nope. 23 with the new law firm?
24 BY MR- LUTTIER: 24 A. Yes.
25 Q. And you have no physical proof of how many 25 Q. So, it's whatever firm IMINIM is now
37 (Pages 643 to 646)
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1 with? 1 A. Okay. I have to pick my son up by 6 so —
2 A. Yes. 2 MR. EDWARDS: Well be done.
3 Q. meet any of the people 3 BY MR. LUTHER:
4 from the 4 Q. At the beginning of this deposition you
5 A. No. 5 asked a question about whether or not somebody else
6 ' any investigators from the 6 was going to be here I think on behalf of you. And
7 7 you made some reference to somebody you had met with
8 A. No. 8 about this deposition. Do you recall making that
Q. Have you ever been interviewed by any of 9 statement, asking whether or not this other person
10 the investigators from there? 10 was going to be here?
11 A. No. 1 A. Uhhuh, yes.
12 Q. Who were you referring to?
12
13
14
ar Do you know a man by the name ofII
A. No.
13
14
A. His name is I don't know his name.
Q. Is it a lawyer?
15 Q. Ha v heard ofhis name? 15 A. Hp's an attorney.
16 A. 16 Q. Not a paralegal. A guy named Fanner,
17 Q- 17 Mr. Farmer?
18 A. No. 18 A. I daft know.
19 Q. Do you have this babysitter's phone number 19. Q. Have you net this other person?
20 in your cellphone? 20 A. Yes.
21 A. No. I don't keep it in my cellphone. 21 Q. Where did you meet this other person?
22 Q. You, you don't keep your babysitters 22 A. At the law firm.
23 number in your cellphone? 23 Q. Mr. Edward's law firm?
24 A. No. 24 A. Yes.
25 Q. And you don't have it memorized? 25 Q. Down in Fort Lauderdale?
Page 648 Page 650
1 A. No. A. Yes.
2 Q. So, what do you have to do when you want 2 Q. So, you've been down to his new law firm?
3 to call a babysitter? 3 A. Yes.
4 A. Ifs at home. 4 Q. Did you review anything in preparation for
5 Q. So, if you're out and about and you need 5 today's deposition?
6 to call the babysitter and tell her you'll be 6 A. Yesterday I talked to my attorney.
7 A. I usually keep it in my purse. 7 Q. Did you review any documents?
8 Q. — there late you don't have any way to do 8 A. I reviewed a document, yes.
9 that until you get home? 9 Q. What document?
10 A. I usually keep it in my purse and I am not 10 A. I don't know. I don't know what document,
11 late. 11. sir. Sorry.
12 Q. Where do you keep it? Do you have a phone 12 Q. You say you reviewed a document or
13 book in your purse? 13 documents?
14 A. No. I have a piece of paper with her number. 14 A. I reviewed a document.
15 Q. Okay. Do you have that with you here 15 Q. One piece of paper?
16 today? 16 A. A few, a few pieces of paper.
17 A. No. 17 Q. Okay. What were they? What did they have
18 Q. So, as you sit here todq=illo not have 18 on them?
19 on your person anywhere Ms. phone number, 19 MR. EDWARDS: Objection as to this line of
20 is that right? 20 questioning calls for attorney-client privilege
21 A. I do not have her number with me, no. 21 information. She's not going it answer it as
22 Q Do you know somebody by the name of■ 22 to exactly what we went over in preparation for
23 (phonetic)? 23 the deposition.
24 A. No. What time is it? 24 BY MR. LUTTIER:
25 Q. 4:41. 25 . Other than notes created by our lawyer
ewe
38 (Pages 647 to 650)
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which I don't want to know about, did you review any 1 in the garbage.
other documents in preparation for your deposition? 2 Q. Well, at the time we took your deposition
A. No. I have to be out of here at 5:30. 3 in September, you told us under oath that it was at
4 your home. Did you do something with it since --
5 A. No.
6 Q. — your deposition on
7 A. No.
8 Q. Well, it just didn't disappear, did it?
9 9 MR. EDWARDS: Form.
10 10 THE WITNESS: No. Are you being sarcastic
11 11 with me?
12 12 BY MR. LUTHER:
13 13 Q. No. I mean you had to do something with
14 14 it, right?
15 15 MR. EDWARDS: Form.
16 16 THE WITNESS: I didn't touch it. I can't
17 17 find it. I don't know where it is. It's not
18 18 in the house, so, song.
19 19 BY MR. LUTTIER:
20 20 Q. Well, where did you think it was when you
21 21 testified definitively that it was in your home?
22 Q. Did you ever hear anything about how your 22 A. I thought it was in a couple of my papers that
23 case may have been involved in any of that? 23 I have and it's not. I thought it was where my Social
24 A. No. It's irrelevant to me right now. 24 Security card was. It's not them, sir. End of
25 Q. Does that mean you have never heard 25 dismission.
Page 652 Page 654
1 anything or you just disregarded what you heard? 1 Q. Do you know the names of any of your
2 A. I disregarded what I heard. 2 clients that you had when you were working — other
3 Q. So, what did you hear? 3 than the ones you've aheady identified here,
4 MR. EDWARDS: You're asking her though 4 clients you had when you were working for any of the
5 what she heard outside of any conversation with 5 escort services?
6 me obviously? 6 A. No. Why would they want me to know their
7 MR. LUTHER: Yeah, oh, yeah. I don't 7 names? I don't want to know their names either.
8 want you to tell me, I don't want you to ever 8 Q. I have no idea.
9 tell me anything your lawyer told you. 9 A. They have wives.
10 THE WITNESS: Oh, no, I didn't hear 10 Q. All your clients have wives?
11 nothing. 11 A. Probably. We don't — it's not about
12 BY MR. LUTTIER: 12 relationships, man. It's about —
13 Q. Okay. Now, in your previous deposition 13 Q. When you were wmtirag for those —
14 you indicated that you had a book. I think you said 14 A — mo and out.
15 it had a red — it was a red book. !don't remember 15
16 if the color was right and you said it had a Bible 16
17 verse on it. Do you remember that testimony? 17
18 A. Yes. 18 MR. EDWARDS: Form.
19 Q. And at that deposition you told us 19 MR. LUTTIER: Right?
20 definitively that you had that at your home? 20 MR. EDWARDS: Fonn.
21 A. Yes. 21 BY MR. LUTTIER:
22 Q. Where is that book now? 22
23 A. I can't find it. It's nowhere to be found. 23
24 Q. Well, what did you do with it? 24
25 A. I don't know. I moved a lot so it's rehab! 25
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Q. Well, why did you do it? 1 And you know I don't want to do this in the
2 A. That's all I know. It's what Jeffrey taught 2 future. I absolutely despise what I do. I
3 me. 3 hate what I do. I don't want to do what I do.
4 4 This is what I have learned from Jeffrey
5 5 Epstein and I hate it, and I can't wait to get
6 6 out of it.
7 Q. Well, Jeffrey wasn't married, was he? 7 BY MR. LUTHER:
A. I don't1=w. 8 Q. That's what you said in
9 Q. Well, did you ever ask him? 9 wasn't it?
10 A. He lied to me about everything. 10 A. Yeah.
11 Q. Did you ever ask him? 11 Q. Didn't stop you, did it? You still went
12 A. Yeab, I think I did. 12 ahead and you keep on doing the same thing you've
13 Q. And what did he tell you? 13 always done?
14 A. He said no. 14 MR. EDWARDS: Form.
15 Q. Do you have any information that Jeffrey 15 BY MR.. LUTHER:
16 Epstein is married? 16 Q. — ben tledl you want the money, isn't that
17 A. No. 17 right?
18 Q. Do you have any information that he was 18 A. Yeah.
19 ever married when you were -- 19 Q. That's the — the bottom line is --
20 20 A. Well, actually I put myself through school
21 21 through it.
22 22 Q. The bottom line is —
23 23 A. I wanted to go back to school. Bottom line, I
24 24 wanted to go back to school so I did it to go to school.
25 And— 25 Q. Well, have you saved up money to go to
Page 656 Page 658
1 A. It's wrong either way. 1 school?
2 A. Yes, I did.
3 Q. How natal have you saved?
4 MR. EDWARDS: Form.
5 THE WITNESS: It's none of your business.
6 BY MR. LUTHER:
7 Q. Where's the money?
8 A. None of your business.
9 9 MR. EDWARDS: Form.
10 10 BY MR. LUTTIER:
11 11 Q. Got it in a bank account?
12 12 MR. EDWARDS: Form.
13 13 THE WITNESS: It's none of your business.
14 14 BY Kt. LUTTIER:
15 15 Q. Well, how are we going to test the
16 16 credibility of what you say when you say you saved
17 A. How do you justify you sitting here 17 money unless we know where it is?
18 representing a pedophile? You know? You're silly. But 18 A. Who cares? Who gives a shit if you, if I save
19 I'm sorry. 19 money or not and if I -- you Icnow, the money I saved,
20 MR. LUTTIER: Move to strike? 20 who cares. You got money?
21 THE WITNESS: I don't know. 21 Q. Well, your justification as I understand
22 MR. LIMIER: And now answer my question. 22 it for doing what you do is so that you can save
23 THE WITNESS: I have to go home every day 23 money to go to school, is that right?
24 and put a poker face in front of my son. I 24 A. Yeah, and so my son can go to Christian
25 don't ever want him to know what I have done. 25 school.
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1 Q. So, I am asking you, did you save money 1 A !could.
2 and if so where is the money? 2 Q. How many jobs hgvagaga•ktalor?
3 MR. EDWARDS: Form. 3 A. 'used to work at being an
4 THE WITNESS: Yeah. 1 saved money and 4 esthetician.
3 it's under my bed. 5 Q. How many — in the last two years, how
6 MR. EDWARDS: Don't be sarcastic. Just 6 many jobs have you applied for?
give him an answer, the truth. 7 _As I actually worked und le r the
3 THE WITNESS: No, Fm not. It's under my 8 sending out things for I do side
9 bed with rubber-bands. 9 jobs. I do cleaning jobs. There is I do
10 BY MR. LUTTIER: 10 to make money.
11 Q. All right. Well, how much have you saved 11. Q. First of all, my question was how many
12 then since it's under your bed? 12 jobs have you applied for in the last two years?
13 MR. EDWARDS: Object to the form. 13 A. In the last two years probably five, and I
14 BY MR. LUTHER: 14 have got them all.
15 Q. How much have you saved? 15 Q. Okay. Where did you, where did you put in
16 MR. EDWARDS: Form, asked and answered. 16 your applications f. five Sobs?
17 Harassing at this point. 17 A. One for
18 BY MR. LUITIER: 18 Q.
19 Q. Do you have a record ofit anywhere? 19 A
20 A. Nope. I have headache. 20 Q. Wait a minute. Is, is the
21 Q. Have you ever applied, applied for 21 ed something different
22 financial assistance at any college or university? 22
23 A. Yes. 23 A. No. Ifs just
24 Q. Where did y >Iv or a. istance? 24 Q. So, the big company, you
25 A. Through the 25 submitted an application?
Page 66 Page 662
Q. And did you get any financial aide? 1 A Yeah.
2 A. Yep. 2 Q. And did you get hired?
3 Q. What? 3 A. Yep.
4 A. Yeah. 4 Q. Okay. How much did they pay you?
5 Q. Was that the loan you described earlier? 5 A Fifteen bucks an hour.
6 A. Yes. 6 Q. So, you were able to get jobs in the labor
7 Q. So, you have been able to finance your 7 market just like everybody else, right?
8 education by simply applying for financial aide? 8 A. Yeah.
9 A. Correct. 9 Q. Where else did
10 Q. So, you didn't have to do what you're 10 A. I have applied
11 doing in order to go to college. 11 Q.
12 A. Thad to finance and then I had to make the 12 A
13 money back to pay for it. I don't have a mommy and 13 Q. Okay. In the last two years?
14 daddy that takes care of me and I am not going to be 14 A. Yeah.
15 working at Burger King. 15 Q. And did you get hired?
16 Q. What's wrong with working at Burger King? 16 A. Yep.
17 A. You make $7 an hour. 17 Q. And how much did they pay you?
18 Q. And that's really why you do what you want 18 A. Twelve an how.
19 to do is you don't want to go get a job that pays 19 Q. Okay. S that job. Are you
20 less than the amount of money you can make doing 20 still working for
21 what you do, isn't that right? 21 A. No.
22 A. No, you're wrong. 22 Q. Why did you quit?
23 MR. EDWARDS: Object to the form. 23 A. It was seasonal.
24 BY MR. LUTHER: 24 Are you still forking'for
25 Q. You could gowork al BurgerKing, right? 25
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1 A. Nope. 1 A. Ten dollars an hour.
2 Q. Why did you quit? 2 Q. And when was the last time you did that?
3 A. The economy just went down and she only could 3 A. Like before I went to New York.
4 hire me three days out of the week so — 4 Q. And whose houses, did you clean the same
5 Q. Where else did you apply in the last two 5 clients' houses?
6 years? 6 A. It's just actually friends' houses.
7 A. I always—. 7 Q. Anyplace else you've applied for work?
8 Q. Well, that's not an application is it? 8 A. No, that I can recall.
9 A. Well, you got to sign up to 9 ou said you worked for the-
10
11
Q. That's just you selling stuff that you
have al
10
11
il Did I hear that?
A. Well that was for, that's incorporated with
12 A. Okay. Well, if that's how you want it. 12
13 Q. Where else hrsyou applied for a job? 13 Q. The - never
14 A. I've been at IME and they paid me under the 14 employed you, did they?
15. table. 15 A. That is in — intertwined with
16 Q. When did you apply fora job at M? 16 to my question. The
17 A. Last year. 17 never employed ou did the n
18 Q. What dk iu do for them? 18 A. No. I didn't apply for
19 A. 19 so they couldn't deny me.
20 Q. Okay. How much did you get paid? 20 Q. Well, you SU ested the were a in ou
21 A. That was like $9 an hour. 21 under the table. The
22 Q. is
Ok Where s else did you apply? 22 never paid you under the table.
23 A. 23 I never, I never worked for the_
24 Q What did you do there? 24 sir. So keep on bring it up so we can keep on
25 A. I was one of the instructors for 25 going over it again.
Page 664 Page 666
1 group. 1 THE WITNESS: What time Is it?
2 Q. And, and how much did you get paid for 2 MR. EDWARDS: You got time. It's 5.
3 that? 3
4 A. Nine dollars an hour. 4
5 Q. And are you still working there? 5
6 A. No. 6 • •elx
7 Q. Why not? 7 Q. Is it current?
8 A. Because it's not paying the bills. $ A. I don't know. I don't use it.
9 Q. So, you quit? Q. Were you provided with a copy of a
10 A. Yeah. 10 document that's called a proposal for settlement in
11 Q. Did you quit M7 11 this case?
12 A No. 12 A. Idon't Know: Was 1?
13 Q. Did they fire you? 13 Q. I mean I can show it to you. !don't want
14 A. No. 14 to mark it on the — I don't want to have it in the
15 Q. Still there? 15 record because I don't want it to be a — but I will
16 A. No. 16 show it to you so you can recognize the document.
17 Q. What happened? 17 Let me just show you the document.
18 A. They, they just needed help fora couple 18 • . A. You can't help me.
19 months. 19 Q. Just go ahead and read it.
20 Q. Okay. Any other places you have applied 20 A. Jeffrey Epstein is not admitting, he is in
21 for jobs? 21 fact denying all liability or responsibility because he
22 A. I clean houses -- 22 did it —
23 Q. For who? 23 THE COURT REPORTER: If you could read --
24 A. —once in a while. For people. 24 MR. EDWARDS: Just read it to yourself
25 Q. How much do you get paid to clean a house? 25 because if you say the words, she has to take
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Page 667 Page 669
1 them down. 1 A. Yeah, I do have problems sleeping.
2 THE WITNESS: Oh, okay. I don't want to 2 Q. Do you — well, other than the fact that
3 read anymore. I'm good. 3 you're out until 5:00 --
4 BY MR. LUTHER: 4 A. Actually
5 Q. Did you see that — 5 Q. Other, other than the fact that you're out
6 A. Yeah. 6 until 5:00 in the morning at strip clubs, do you
7 Q. Have you seen that before today? 7 have any problem sleeping?
8 A. You know what, send Jeffrey to jail for 20 8 A. Oh, you're so cute. I have trouble sleeping
9 years and then I will take zero dollars. I need 9 over Jeffrey, yeah.
10 justice. I want what's fair for all of us, for all of :0 Q. Well I me it doesn't keep you from
11 us guts. 11 going out to until 5:00 in the
12 Q. What you want is money, right? 12 morning, does it?
13 A. No. I want justice and I want what's fair. 13 A. It keeps me up.
14 And what's fair is that he should serve jail time. He 14 Q. Okay.
15 didn't sense jail time forme and my girlfriends. He 15 A. People got to do what you got to do. Just
16 sat with his little rich butt -- 16 hire you got sit here and defend a child molester, you
17 Q. And who told you that? 17 know. I got sit here and go to and make
18 A. — in a little office doing community service 18 money, too. What's the difference, right?
19 which was probably nothing for him because money talks. 19 Now, you testified last time that you were
20 And you know what, I want justice. So, I tell you what, 20
21 give me no money right now and send Jeffrey to jail for 21
22 20 years, and 1will walk out of here with a smile from 22 A. Girls. I don't know.
23 ear to ear. 23 Q. What are their names?
24 Q. Have you ever gone to jail, ma'am? 24 A. I don't know. They have stage
25 A. Nope. 25 names. I really could not tell you.
Page 668 Page 670
1 Q. You don't know how long Mr. Epstein was in 1 Q. Well, did you guys work together?
2 jail, do you? 2 A. A few times.
3 A. I heard he was in jail for 18 months but -- 3 Q. And when you say you worked together, what
4 Q. You don't know what it was like in jail, 4 does that mean?
5 do you? 5 A. That we worked totether.
6 A. Oh, God. For Jeffrey, poor old Jeffrey, oh, 6
7 he went to jail because he molested over 100 little 7
8 girls. I hope he was molested or rapped, whatever the 8
9 definition is. He needs more torture than that, jail. 9
10' Yeah, he needs to stay in there for 20 years, not 18 10
11 months. 11
12 Q. What do you think you should do as a 12
13 result of you having taken a bunch of your best 13
14 friends and girlfriends and knowing exactly what was 14
15 going to happen in taking them to Jeffrey Epstein? 15
16 A. Call all of them and say, I am sorry,1 was 13 16
17 years old, I apologize for being naive and a stupid 17
18 littlegirland I hope that everybody can get 18
19 counseling. And 1 hope that everybody can get served 19
20 justice. I hope we can see Jeffrey's face in the 20 MR. EDWARDS: Object to the form.
21 newspaper saying that finally this jerk-off is in jail 21 THE WITNESS: No.
22 for 20 years, and now all ofus can go to sleep 22 •
23 peacefully. 23
24 Q. You don't have any problem sleeping, do 24
25 you? 25
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1
2 2 CERTIFICATE OF OATH
3 3 THE STATE OF FLORIDA
4
4 COUNTY OF PALM BEACH
5 A. Sometimes. So, will Jeffrey go to jail for 20 6
6 years if he gives nobody money or he can't stand it? 7 the undersigned authority, certify that
7
S
Q. Have you sold any interest in this lawsuit
to anybody?
8
9
M . personally appeared before me and was duly
sworn on the 9th day of February, 2010.
9 A. No. 10
10 Q. In other words have you received money 11 Dated this 19th day ofFebruary, 2010.
11 from anybody and in return given them an interest in 12
13
12 this lawsuit?
14
13 A. No. 15
14 Q. Have you received any money or any other
15 kind of consideration from any company with respect 16 aWif
16 to this lawsuit? Cynthia Hopkins, RPR, FPR
17 A. No. 17 Notary Public - State ofFlorida
18 Q. Any attorney with respect to this lawsuit? My Commission Expires: February 25, 2011
19 A. No. 18 My Commission No.: DD 643788
20 19
Q. Any other person with respect to this 20
21 lawsuit? 21
22 A. No. 22
23 Q. Have you been provided any money advances, 23
24 that is money — 24
25 A. No. 25
Page 672 Page 674
Q. - as an advance against an outcome in 1 CERTIFICATE
2 THE STATE OF FLORIDA
2 return for a sharing of the percentage of it? 3 COUNTY OF PALM BEACH
3 A. No.
5 ;Cynthia Hopkins, Registered Professional
Q. Have you assigned any interest in this Reporter. Florida Psofessionsl /tenacity and Notary
lawsuit to anyone? 6 PuNic in and for the State of Florida at large, do
hereby certify that I ass authorized to and did
A. No. 7 report said deposition in stenotype and that the
7 MR. LUTTIER: Okay. Fro done. Any cross? foregoing pages arc a true and cornet transcription
8 MR. EDWARDS: We'll read. 8 of my shorthand notes of said deposition
9 I further amid& that said deposition vas
THE VIDEOGRAPHER Going off the record at till= at the tirne and place hereinabove set fonds
10 5:05 p.m. This is the end of Tape 3 of the 10 and that the taking of said deposition was commenced
and completed as hereinabove set out.
11 deposition. 11
12 THE COURT REPORTER: Do you want to order I tut certify that 1 am not anomey or
12 cowed of any of the Indies, nor am a relative
13 this? or employee of any ancimey or counsel of party
14 MR. LUTTIER: Yes. 13 connected with the action, nor am 1 financially
interested in the acme
15 THE COURT REPORTER: Would you like a 14
16 cOPY? The foregoing cenitication of this transcript
15 does not apply to any reproduction of the same by
17 MR. EDWARDS: Yes, please. any moon unless tinder the dinxt control andkr
18 (Witness excused.) 16 direction of the oertifyin reporter.
19 (Deposition was concluded.) 17 Dated this 19th day of retailer% 2010
18
20 19
21 20
21
22 ia Hopkins,
23 22
23
24 24
25 25
44 (Pages 671 to 674)
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by cynthia napkin*
Electronically signed by cynthia hooking
Electronically signed by cynthia napkins b5S42lel-d299.4041-9ba6-85aad27f4405
EFTA01076202
Page 675 Page 677
DATE: Febnery 19t, 2030
TO.
1 ERRATA SHEET
e/MAD J. EDWARDS, ESQUIRE 2 IN RE: VS. EPSTEIN
FARMER, JAFFE, WEISSING, EDWARDS CR: HopkiltPR, PPR
FISTOS & LEBRMAN. 3 DEPOSITION OF:
42S North Ansley«. Avenue
Suite 2
TAKEN: February , 0
Port ale, Florida 33201 4
IN RE: vs. EySleiri 5 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
CASE 14D s CA02805I =MAE Att PAGE I LINEN CHANGE
Please take nonce that on Tuesday. the 9th of REASON
February, 20)0. you gam your deposition kite
6
abcoc-refsued mattes. At that tulia. you not
wave ligature. It is oar neorstuy that you sign 8
you deposition 9
As Menai* agreed to, the transcript sell be 10
firmased se you trot* yea counsel. Max read
the Folloun antimafia...1 carefully. 11
At the end of the transcript you wilt find et 12 I
twin then As you read yotx depos:non, any 13
2 changes or (mottoes that you wish to make should
be noted on the errata tires, caing page and line 14
13 number of raid chrism DO NOT unto on the 15
aaracrim itself. Once you law read the 16
14 rransciipt md noted any changes. be sure to tops
and due the nails:es and return time pages to
17 Please forward the original signed meta sheet to
15 me this office so that copies may be distnlnued to all
If you do not tad and sign the dcposibon 18 parties.
16 within a reasonable time, the original. which has 19 Under penalty of pajury, I declare that I have read
abraly ban Ibilwaided io the Waal Malay, may
17 00 filed wins the Clak tithe Can lf you MA my deposition and that it is true and correct
to waive your ri&tature, sign your name in the blank 20 subject to any changes in form or substance entered
Sr a the bottom of this letter and scans is to us here.
19 Very t-Ar you,. 21
20
21
22 DATE:
22 23
23 I de hereby waive my Sigialutt. 24 SIGNATURE OF
24
25 • 25
DEPONENT:
Page 676
CERTIFICATE
2
3 THE STATE OF FLORIDA
4 COUNTY OF PALM BEACH
5 I hereby certify that I have read the foregoing
6 deposition by me given, and that the statements
7 contained herein are tme and correct to the best of
8 my knowledge and belief, with the exception of any
9 corrections or notations made on the errata sheet,
10 if one was executed.
11
12 Dated this day of
13 2009. 1
14
15
16
17
18
19
20
21
22
23
24
25
45 (Pages 675 to 677,
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Cynthia hopkins 601.0 1-97
Electronically signed by Cynthia hopkins
Electronically signed by Cynthia hopkina b5542tcl-c1299-404liba6.B5aad27,4405
EFTA01076203