EFTA00723105

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME II JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-801092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE Wednesday, September 30, 2009 9:37 Illi. - 6:10 lli. One Clearlake Centre 250 South Australian Avenue, 1st Floor West Palm Beach, Florida 33401 Reported By: Pamela J. Sullivan, RPR, FPR, CLR Prose Reporting Agency, Inc. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772-15521 Electronically signed by Pamela Sullivan (501.333-772-1552) 41151584-6022-4050-b036-0423518c2lb5 EFTA00723105 Page 131 Page 133 APPEARANCES! 1 - -- 6 On behalf of the Plaintiff, /env Doe: 2 INDEX 3 BRAD J. EDWARDS. ESQ1.7IRE ROTHSTEIN ROSIDIPELDT ADLER 3 -- Las Oles City Cant, Stitt 1650 4 DIRECT CROSS REDIRECT RECROSS 401 East Las Clef Soignee:I Fan Lsoladde, Florida 33301 5 JANE DOE 6 BY MR. curroN 5 Onel,alfoftherktadaa, Jeffrey Epstein: 7 ROBERT D. CRITTON.M. ESQUIRE BURMAN, CIUTTON.LAD1TER & COLEMAN, LLP 303 Ewan Boulevard EXHIBITS MARKED Suite 400 North Pahn Beech, Florida 33401 9 10 11 12 On Wu for the Defendant. Jeffrey Eptlein- 11 DESCRIPTION PAGE 13 JACK ALAN GOLDBERGER, ESQUIRE 12 ATTERBURY. GOIDEERGER & WEISS'S t1 250 Auendon Mesa Sou& Deft:odic:Ws No. 5 163 Suite 1400 13 (Order) 15 Were Palm Bach, Florida 334014012 14 On behalf of Plantar inRelated Cass No. 0540469 14 17 ISIDRO M. GARCIA, (RE 15 GARCIA LAW FIRM 18 224 Dame Steel, Suite 16 West Palm Beach, Pkwitla 33401 17 19 561.532.7732 indrotsecia@kelleash.not 18 20 On behalf of lone Dons 1throne, 19 21 20 ADAM D. HOROWTTZ, ESQU 22 MERMELSTERS & HOROW117M7.. 21 18205 Mayne Boatyard 22 23 Suite 2218 Ml&M Floral 33140 23 24 24 25 25 Page 132 Page 134 1 On behalf of the Plaintiff= 1 PROCEEDINGS 2 JACK P. HILL, ESQUIRE 2 SEARCY DENNEY SCAROLA BARNHART & SHIPLEYS. 3 (Continued from Volume lof the same day.) 3 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 4 VIDEOGRAPHER: Back on the record at 11:52. 4 5 BY MR. CRITTCIN: 6 Q. Ms. Jane Doe, I have in front of you, I 5 On behalf of the B.B.: 6 ADAM J. LANGNO, ESQUIRE 7 think, Malt 4 what 1 know to be Exhibit 4, which LEOPOID RUM 8 is the declaration of Ms. Villafana. Do you see that? 7 2925 PGA Boulevard, Suite 200 9 A. Yes. Palm Berndt Girders, Florida 33410 a 10 11 Q. And I will represent to you, and I think you told me you don't know who she is; correct? 9 12 A. Yes 13 Q. And on Page 2, she says is, "I" — in her 11. ALSO PRESENT: 14 declaration says — the first sentence says: "I am the 12 Jeffrey Epstein, via video conference Stan Sanders, Videograpber 15 Assistant US — United States Attorney, assigned to the 13 16 investigation of Jeffrey Epstein," and then — "and the 14 17 case was investigated by the Fetal Bureau of 15 Investigation, FBI," et cetera, et cetera. 16 18 17 19 Do you see that up at the top? 18 20 A. Yes. 19 21. Q. Okay. That's who she says she is. And then 20 21 22 she's — on Page 7 of her declaration she says: "I 22 23 declare, under penalty of perjury, pursuant to 28 USC, -23 24 Section 1746, that the following is true and correct, to 24 25 the best of my knowledge and belief." And then she 25 2 (Pages 131 t o _124 ) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333772.1662) Electronically signed by Pamela Sullivan (501-33347211652) 4415168d4k22-4c60-130364423618e2fb6 EFTA00723106 Page 135 Page 137 1 signs this on 9th day of July 2008, and then it purports 1 Do you see that? 2 Lobe what is her signature above her printed name. 2 A. Yes. 3 Do you see that? 3 Q. And then it says: "The FBI's Victim Witness 4 A. Yes. 4 specialist sent a letter to Jane Doe," you, "on May 30, 5 Q. All right. If I go to paragraph three, down 5 2008." 6 at the bottom it says here -- there's a reference to 6 Do you see that? 7 Jane Doe, Page 3 — sorry — Page 2, paragraph 7 A. Yes, I do. 8 three. Are you with me? 8 Q. Okay. You indicated that you were -- when I 9 A. Yes. 9 asked you earlier today — excuse me — when you had 10 Q. Go up — not — not the footnotes. You brow 10 given your statements and you said, emphatically, you 11 what a footnote is; don't you? 11 were three and a half months pregnant; correct? 12 A. Yes. 12 A. Yes. 13 Q. All right Go up from the footnotes, then 13 Q. All right You wouldn't dispute 14 one, two, three lines up it says: "Jane Doe was 14 Ms. Villafana's and the FBI's agents' statement that 15 identified." 15 they interviewed you on May 28th of '08; correct? 16 Do you see that? 16 A. No. 17 A. Yes. 17 Q. And I think you — well, I don't think. Let 18 Q. You are that Jane Doe; correct, Jane Doe? 18 me start again. 19 A. Those are my initials. 19 You've told us you've testified that you 20 Q. And -- and if you read in fact, I should 20 only talked with the FBI on one occasion, and that one 21 probably have you just — why don't you read to yourself 21 occasion had to have been May 28th of '08; correct? 22 paragraph three, because there's a reference to 22 A. Yes. 23 Mr. Edwards and three of his clients, C.W. and 23 Q. Okay. And that was the first time, at least, 24 Jane Doe. Do you see that? 24 that you had told any governmental authority, state, 25 A. Yes, I do. 25 Federal, local, that you had been to Mr. Er:stain's home; Page 136 Page 138 Q. Okay. would be -- 1. correct? 2 A. Yes. 2 A. Yes. 3 Q. — you would assume. C.W. would be E.W., and 3 Q. And if you go to Exhibit 5 — 4 you would have to be the Jane Doe; Jane Doe? 4 MR. CRITTON: And, Mr. Edwards, if you could 5 A. Yes. 5 help your client. 6 Q. Are you aware of any individuals that Miss - 6 MR- EDWARDS: I haven't seat an Exhibit 5 7 Mr. Edwards represents, other than you,a and E.W.? 7 S yet, I don't think. MR. CRITTON: It's — sorry. Exhibit 5 8 A. No. 9 Q. All right. Then it goes down — again, 1 9 to Exhibit 4. My fault. 10 take you back where it says: "Jane Doe was identified 10 MR. EDWARDS: Okay. Just to show her where 11. via the FBI's investigation in 2007, but she initially 11 it is. It's -- if you look up at the upper, 12 refused to speak to investigators." 12 right-hand corner, there's a May 30th letter. 13 Do you see that? 13 MR. CRITTON: May 30,2008, letter. les: 14 MR. EDWARDS: Object to the form. 14 "Dear Jane Doe," and it's been redacted in part. 15 THE WITNESS: Yes, h do. 15 MR. EDWARDS: Let's see if I can get there, 16 BY MR. CRITTON: 16 and then ru get her there. 17 Q. And Mat's true; you did refine to speak with 17 BY MR. CRITTON: 18 them? 18 Q. If you look — you're now looking at 19 MR. EDWARDS: Object to the form. 19 Exhibit 5 to our Exhibit 4; correct, to Ms. Villafana's 20 THE WITNESS: Yes. Yes, l did. 20 declaration? 21 BY MR. CRITTON: 21 A. Okay. 22 Q. All right. And then it says: 'Jane Doe's 22 Q. And you see it's a letter from the US 23 status as a victim of a Federal offense was confirmed 23 Department ofJustice. It's dated May 30th, 2008, and 24 when she was interviewed by Federal agents on May 28th. 24 it says: "Dear Jane Doe," because your name has been 25 2008." 25 redacted; correct? 3 (Pages 135 to 138) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela moan (5014334724 (552) Electronically signed by Pamela Sullivan (601-333-7724552) 4f151584-6c22-4c50-b036o423618c2fbS EFTA00723107 Page 139 Page 141 1 A. Uh-huh. Yes. 1 does that refresh your recollection that the FBI told 2 Q. And is this the Victim's Assistance Program, 2 you that you could file some sort of civil suit against 3 a letter that you said you received sometime after you 3 Mr. Epstein? 4 met with the FBI? 4 MR. EDWARDS: Object to the form. 5 A. Yes. 5 THE WITNESS: Yeah, they — they may have 6 Q. Okay. And I think you said — your your 6 mentioned something of it. 7 best recollection was within a watt, which is consistent 7 BY MR. CRITTON: 8 with this letter, which also then reconfirms that the 8 Q. Okay. So that — that refreshes your 9 FBI had to have met with you, as reflected in the 9 recollection that the FBI said, You know, you may want 10 declaration on May 28th, 2008, for the very first time; 10 to go get your own lawyer and bring a money — a civil 11 correct? 11 suit against Mr. Epstein; we're only criminal people? 12 A. Yes. 12 M. EDWARDS: Object to the form. 13 Q. All right. At the time that you received 13 BY MR. CRITTON: 14 this letter, 'think you also told us that you had not 14 Q. Does that refresh your recollection? 15 been represented, or you Mr. Edwards was not 15 A. Which document refreshes her recollection? 16 representing you at that time; correct? 16 Any of this? 17 MR. EDWARDS: Object to the form. 17 MR. CRITTON: No, I just quoted back to her 18 THE WITNESS: Yes, it was shortly after. 18 what she said to me. 19 BY MR. CRITTON: 19 MR. EDWARDS: Okay. Well, if you know the 20 Q. All right. If you then go down to Exhibit 7, 20 answer to what he's talking about, then answer it. 21 and it's easier to read. 21 THE WITNESS: They didn't — I know — I 22 MR. EDWARDS: Flip a few pages. 22 mean, I don't remember what exactly they said to 23 THE WITNESS: Here? 23 me, but they did mention that I should get a 24 MR EDWARDS: Keep going (inaudible). 24 lawyer. 25 THE WITNESS: Okay. 25 Page 140 Page 142 1 BY MIL CRITTON: I. BY MR. CRITTON: 2 Q. This is a letter also from the US Department 2 Q. All right. And that you might be able to get 3 of Justice. It's from Ms. Villafana. It's directed to 3 money? 4 Mr. Edwards. It's dated July 9th, 2008. 4 MR. EDWARDS: Object to the form. 5 A. Uh-huh. 5 THE WITNESS: I don't — leant remember 6 Q. And it says, Re: Jeffrey Epstein/S, and then 6 them saying anything to me about money. 7 there's a redaction, ft/Notification of Identified 7 BY MR. CRITTON: 8 Victim. 8 Q. Then why would you need a lawyer under these 9 Do you see that? 9 circumstances for any reason? You weren't — or did. 10 A. Yes, I do. 10 they indicate to you that you were a target of any 11 Q. Okay. Have you ever seen this letter before? 13. investigation? 12 A. I don't remember seeing this. 12 MR. EDWARDS: Object to the form. 13 Q. Now, having seen the affidavit, Exhibit 4, 13 THE WITNESS: Basically, they just told me 14 that is the declaration of Ms. V illafana that reflects 14 that what happened to me was wrong, and that I 15 that you met with the FBI on May 28th, and consistent 15 should do something about it. 16 with your earlier testimony, that you got the victim's 16 BY MR. CRITTON: 17 assistance letter shortly thereafter, which we now know, 17 Q. Okay. And you understood that doing 18 from looking at one of the exhibits to the declaration, 18 something about it was filing a lawsuit against 19 was May 30th of '08. 19 Mr. Epstein and ask for money? 20 Does that in any way refresh your 20 MR. EDWARDS: Object to the form. 21 recollection how you got -- or from whom or how you got 21 BY MR. CRITTON: 22 the card to go find Mr. Edwards? 22 Q. Is that a fair statement? 23 A. Well, no. 23 A. Well, I wanted to have him prosecuted for 24 Q. Okay. And now, having seen the declaration 24 what he did, but I obviously can't do that. 25 in exhibits -- and the exhibits that we've identified. 25 Q. Because — because you know from your own 4 (Pages 139 to 142) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772.1652) Electronically signed by Pamela Sullivan (601.333.772-'1662) 4115158d-6c22-4c50-b036-e423618c2fb5 EFTA00723108 Page 143 Page 145 1 criminal experiences that it's either the State of 1 Third sentence says: "All three of those 2 Florida or the United States Government that prosecutes 2 clients were victims of Jeffrey Epstein's while they 3 people, not individuals; true? 3 were minors, beginning when they were 15 years old. 4 MR. EDWARDS: Object to the form. 4 Do you see that? 5 THE WITNESS: I don't understand. 5 A. Yes, I do. 6 BY MR. CRITTON: 6 Q. Okay. So Ms. Villafana, based upon her 7 Q. Well, you know that you can't prosecute -- a 7 knowledge and the interview or the conversation that she 8 citizen doesn't have the right to prosecute. It's — 8 had with the FBI and the information they had, have you, 9 ifs an arm of the Government, and you know from your 9 NB. and E.W. all being at least 15 when you first saw 10 own experience. That is, when you got in trouble with 10 Mr. Epstein do you see that, at least what's 11 the law, you know it was the State ofFlorida versus 11 represented in her sworn statement — 12 you; comet? 12 MR. EDWARDS: Object to the form. 13 MR. EDWARDS: Object to the form. 13 THE WITNESS: Yes, I can see what it says. 14 THE WITNESS: That's not something that I 14 BY MR. CRITTON: 15 specifically 'mew from my own experience, no. 15 Q. All right. Did the FBI at any time — well, 16 BY MR. CRITTON: 16 let me — let me ask this question: If the FBI -- if 17 Q. Okay. Well, well get to that a little 17 you told the FBI that you were 15 when you first saw 18 later. Let — let me go back to the discussions that 18 Mr. Epstein, based upon this declaration, does that now 19 you had with the FBI. I think you told me — well, I 19 refresh your recollection that you never went to 20 know what I wanted to ask you. If you go back to 20 Mr. Epstein's home for the first time until after you 21 Exhibit 4, Page 2 — 21 turned 15, which would have been sometime after June 22 A. (Witness complies.) 22 17th of 20037 23 Q. — same paragraph, paragraph three. It says: 23 MR, EDWARDS: Object to the form. 24 Attached hereto are copies of letters provided to 24 THE WITNESS: I remember specifically telling 25 Mister — or to Bradley Edwards, three el lects,.., 25 than and Jeffrey that INNIS 14 when I first met Page 144 Page 146 1 C.W. and Jane Doe. And then there's a 1 for the 1 Jeffrey, and I told him that 1 was 15. 2 footnote. 2 BY MR. CRITTON: 3 Do you see that? 3 Q. Okay. Well, but you would agree with me that 4 A. Yes. 4 at least Miss — the FBI and the US Attorney's Office 5 Q. All right. And, again, recognizing that 5 believed you were 15, based on something that you told 6 Ms. Villafana is a United States Attorney, and that 6 them; cone& 7 she's signing this declaration of oath under oath, based 7 MR. EDWARDS: Object to the form. 8 on her conversations that she had with the FBI -- at 8 THE WITNESS: It looks like that's what they 9 least that's what it purports to say — but go down to 9 believed. But they obviously misinterpreted what! 10 Footnote 1. It says: "Attorney Edwards filed this 10 told than, because I know what I told them. 11 motion on behalf oflane Doe, without identifying which 11 BY MR. CRITTON: 12 ofhis clients is the purported victim?' 12 Q. Would you agree with me that your 13 Did I read that correctly? 13 recollection back in 2000 -- May of 2008 was probably 14 MR. EDWARDS: Object to the form. 14 better than it is today 15 THE WITNESS: I don't know. 15 MR. EDWARDS: Object to the form. 16 BY MR. CRITTON: 16 BY MR. CRTITON: 17 Q. I want you to follow along. Did I just -- 17 Q. -- in September of 2009? 18 let me read it again. 18 A. What do you mean? 19 A. Oh I read it ahead of you. 19 Q. Well, would you agree that with another -- 20 Q ■ sorry? You're ahead of me? 20 let's see - with another 16 months having passed since 21 A. Yeah. 21 May of 2008, that your recollection as to the events 22 Q. Okay. Well, then, we'll just — let me go to 22 involving Mr. Epstein were better back in 2008 than they 23 the second sentence. It says: Accordinglywill 23 are now? 24 take — I will address facts related to C.W.,M. and 24 MR. EDWARDS: Object to the form. 25 Jane Doe. 25 THE WITNESS: No. 5 (Pages 143 to 146) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) 4f15158d-6c22.4c50-b036-e423618c21b5 Electronically signed by Pamela Sullivan (501-333-772-1652) EFTA00723109 Page 147 Page 149 1 BY MR. CRTITON: 1 Initially acquaintances, but eventually friends? 2 Q. Okay. You think your recollection is better 2 A. Yes. 3 now? 3 Q. Lets sec. Duncan Middle School, where you 4 A. No, I think it's pretty much the same. 4 would have been there sixth, seventh and eighth? 5 Q. All right. You told me the FBI -- well, let 5 A. No. I went there for sixth grade, and I 6 me strike that. 6 moved in seventh grade. 7 You said you told the FBI how you came to be 7 Q. Dial. stay there? 8 at Mr. Epstein's the first time; correct? 8 A. 1 daft know. 9 A. Yes. 9 Q. Where did you go for seventh grade? 10 Q. diaLin response to their question, you told 10 A. Okeeheelee Middle School. 11 them than. took you; correct? 11 Q. Is that because you moved locations where you 12 A. Yes. Yes. 12 were living? 13 Q. How many times did — did you go or dical. 13 A. Yes. 14 take you to Jeffrey Epstein's home? 14 Q. Okay. And in sixth grade you would have 15 A. One. 15 been - lets see -- sixth grade you would have been how 16 Q. Just the first time? 16 old? 17 A. Yes. 17 A. Eleven. 18 Q. And what dill. tell you about -- well, let 18 Q. Who were you living with — who were you 19 me strike that. 19 living with when you went to Duncan Middle? 20 You were friends within.? 20 A. My grandmother. 21 A. Yes. 21 Q. Ms. Brewer? 22 Q. And you say it was, at least your 22 A. Yes. 23 recollection today, is it was sometime in February, plus 23 Q. (Way. Who were you living with when you went 24 or minus a month, of '03? 24 to Okeeheelee? 25 A. Yes. 25 A. I was in between my grandmother and my Page 148 Page 150 1 Q. All right. When you went the first time - 1 mother. 2 or before ou went the first time, how long had you 2 Q. Is this during the time that is between 3 known.? 3 the sixth and the seventh grade, is this the time that 4 A. About three years. 4 your — that the incident occurred whore your father had 5 Q. And did you meet — how did you meetM.? 5 been charged with, in essence, murdering Joey? 6 A. I met her in the sixth grade at school. 6 MR. EDWARDS: Object to the form. 7 Q. Was she in your class? 7 THE WITNESS: It was summer before seventh 8 A. No. 8 grade. 9 Q. Is she older or younger, same age? 9 BY MR. CRITION: 10 A. I think she's a little bit younger, but she's 10 Q. Is that the reason that you were no longer 11 about the same age. 11 with your grandmother at that point in time, and why you 12 Q. You mean within a couple of months of one 12 went to Okeeheelee? 13 another? 13 A. I was with my grandmother. My grandmother 14 A. Yes. 14 moved because my mother wanted me to go to that school 15 Q. How about E.W., by the sixth grade did you 15 because she wanted the school to believe that I was 16 already know E.W.? 16 living with her. 17 A. No. 17 Q. She wanted you to go to Okeeheelee? 18 Q. Sot was the first person you knew? 18 A. Yes. She wanted -- I dont know who really, 19 A. Yes. 19 but she wanted somebody to believe that I was living 20 Q. What school was that? 20 with her, and not with my grandmother. 21 A. Watson B. Duncan Middle School. 21 Q. So mom said, come, you're staying with me, 22 Q. You were in the same sixth grade, just 22 and — and, ultimately, you went to Okeeheelee? 23 different classes? 23 A. Yes. 24 A. Yes. 24 Q. Did you stay in touch with II.? 25 Q. Did you know -- and you became friends? 25 A. No. 6 (Pages 147 to 150) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601433-772-1552) Electronically signed by Pamela Sullivan (501-333.772.1652) 415158(1-6c22-4c50-b0364423618atb5 EFTA00723110 Page 151 Page 153 1 Q. When you were in sixth grade, did you and 1 A. No. 2 used to play together? 2 Q. -- legal or illegal? 3 A. No. 3 A. No. 4 Q. Did you -- you just knew each other from 4 Q. Prescription drugs that — although they 5 school? 5 weren't your prescription? 6 A. Yes. 6 A. No. 7 Q. Did you ever meet..'s mom? 7 Q. Were you aware that.. was doing drugs -- 8 A. No. 8 A. No. 9 Q. Have you ever met..'s mom? 9 Q. — or alcohol back at that poim in time in 10 A. No. 10 sixth, seventh and eighth -- sixth and seventh grade? 11 Q. Has.. ever talked to you about her morn? 11 A. No. 12 A. No. 12 Q. How about eighth grade, were you — had you 13 Q. Has anyone ever told you that..'s mom is a 13 started drinking by the time you had hit eighth grade? 14 prostitute? 14 MR. EDWARDS: Object to the form. 15 A. No. 15 BY MR. CRITPON: 16 MR. EDWARDS: Object to the form. 16 Q. By drinking, I mean alcohol. 17 BY MR. CRITTON: 17 A. I — I had probably had a drink at some 18 Q. Have you heard that before today, that..'s 18 point. 19 mother was a prostitute? 19 Q. And had you started doing drugs by the time 20 A. No. 20 you were in the eighth grade, illegal drugs? 21 Q. Did you seell. during your seventh grade at 21 MR. EDWARDS: Object to the form. 22 all? 22 THE WITNESS: Yes. 23 A. No. 23 BY MR. CRITTON: 24 Q. How about eighth grade? 24 Q. All right. And what had you started? 25 A. We were living close to each other, so I met 25 Smoking pot? Page 152 Page 154 1 her again, yes. A. Yes. 2 Q. In eighth grade, were you still at 2 Q. All right. How about the Ecstasy, the one 3 Okeeheelee? 3 Ecstasy that you say you took, was that back in the 4 A. Yes. 4 eighth grade? 5 Q. But you were living closer now to.., so 5 MR. EDWARDS: Object to the form. 6 you started hanging out together or were friendly, 6 THE WITNESS: I was either 13 or 14. 7 became friends again? 7 BY MR. CAPTION: 8 A. We hung out once in a while, not a whole lot. 8 Q. So at least before you met Mr. Epstein, you 9 Q. And I think you said you never have been to 9 had at least done — you were drinking alcohol, you were 10 M.'s house? 10 using pot, and you had had Ecstasy; true? 11 A. No, I had never — 11 MR. EDWARDS: Object to the fonn. 12 Q. Back at that point in time. 12 THE WITNESS: Yes. 13 A. No. 13 BY MR. CR1TTON: 14 Q. Okay. Had she ever been — had you ever 14 Q. And had you also had Xanax by age 12,13, 14? 15 brought her over to your house or your grandmother's 15. A. No. 16 house or wherever you were living at the time? 16 Q. Did you ever smoke pot with..? And. 17 A. Yes. 17 talking eighth grade. 18 Q. And this would have been in what, in eighth 18 A Probably. about? 19 Q. And how about Ecstasy, were you or. — 19 grade now we're talking 20 A. Yes. 20 well, let me strike that. 21 Q. Okay. When you were in sixth grade and 21 Had you ever taken Ecstasy when.. was 22 around., did you and. ever drink alcohol 22 around? 23 together? 23 A. No. 24 A N 24 Q. Okay. Who were you with when you had the 25 Q. Did you ever do any kind of drugs together — 25 Ecstasy? racc 7 (Pages 151 to 154) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1652) 4,15158d-6c22-4c50-b036-e423618c211,5 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00723111 Page 155 Page 157 1 A. I was with an old friend. 1 A. She was friends with my friend. 2 Q. Who? 2 Q. She being who? E.W.? 3 A. Melissa. 3 A. E.W. was friends with my friend, Melissa, and 4 Q. What's Melissa's last name? 4 that's how I met her. 5 A. Kapusta. 5 Q. So you met E.W. through Melissa? 6 Q. • sorry? 6 A. Yes. 7 A. K-a-p-u-s-t-a. 7 Q. What age? 8 Q. Is she a friend of yours? 8 A. Thirteen or 14, maybe. S not positive. 9 A. I haven't seen her or spoken to her in a few 9 Q. And did you and E.W. hit it offright away, 10 years. 10 once you met through Melissa? 11 Q. Did she used to live out -- or in the area 11 A. No, we did not. 12 that you did? 12 Q. Did you ever smoke pot with E.W. back at that 13 A. Yes. 13 time? Because she was using drugs, too; wasn't she? 14 Q. Is she older, younger, or same age? 14 MR. EDWARD$: Object to the form. 15 A. Well, she went to the same school. We were 15 THE WITNESS: I don't know what she was 16 the same age. She was — she's a little bit younger, a 16 doing. 17 few months. 17 BY MR. CRITION: 18 Q. Okay. And when you would smoke pot, who did 18 Q. Okay. Are you saying she wasn't using drugs, 19 you get that Ran? 19 or you just don't know, one way or the other? 20 MR. EDWARDS: Object to the form. 20 A. I just don't know. 21 THE WITNESS: I don't know. 21 Q. But you've used illegal dings with E.W.; 22 BY MR. CRITION: 22 haven't you — 23 Q. Okay. Did you ever get it from your 23 MR. EDWARDS: Object to the form. 24 grandmother? 24 BY MR. CRITTON: 25 A. Na 25 Q. - from the time you met her? Page 156 Page 158 1 Q. Okay. Did you ever smoke pot in your 1 A. Yes. 2 grandmother's house? 2 Q. Now, when you first met E.W., where was she 3 A. Probably. 3 living? 4 Q. Okay. Was she aware that you were smoking 4 A. She was living with her mom in — 5 pot? 5 Q. Do you know what her morn's name is? 6 A. No. 6 A. Eva. 7 Q. after -- during eighth grade continued 7 Q. Did you ever go over to E.W.'s house, back at 8 to be friends? 8 that time period — 9 A. Yes. 9 A. I - 10 Q. Okay. When you say you went to Epstein's 10 Q. - seventh, eighth, ninth grade? 11 house for the first time, what grade were you in? 11 A. I went outside her house once. I — I had 12 A. I was in eighth grade for the second time. 12 never been inside ofher house. 13 Q. You repeated eighth grade? 13 Q. But you met her mom? 14 A. Yes. 14 A No. 15 Q. So you would have still been at — at that 15 Q. You never met her mom? 16 time at Okeeheelee? 16 A. I have met her mom, but at that point, no. 17 A. In the middle of that year 1 believe I left 17 Q Okay. Did you meet her mom after this 18 that school and went to an all girls school. 18 lawsuit has been filed? 19 Q. Was that Pace? 19 A. No. 20 A. Yes. 20 Q Did you meet her at what point in time? 21 But you were still — you would still see 21 A. I met her when I worked at IHOP. 22 M. from time to time? 22 Q. Did she come in as a -- was she a waitress 23 k Yes. 23 there, or did she — 24 Q. Okay. Was was E.W. around this time, as 24 A. She worked there. 25 well? Were you friends now with E.W.? 25 Q. Did she help you get your job? • ..4.••••••.••....laaa••••••••••....... 114• ••./.....• 8 (Pages 155 to 158) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4.16168tHic22-4c6043636-6423618c2k6 EFTA00723112 Page 159 Page 161 1 A. Yes. 1 and you were hanging out with..? 2 Q. And was that when you were living with E.W.? 2 MR. EDWARDS: Object to the form. 3 A. Yes. 3 BY MR. CRITTON: 4 Q. Okay. That was when you were living with 4 Q. You were friends — were friends with..? 5 E.W. at the apartment with Jessie? 5 MR. EDWARDS: Object to the Porn. 6 A. Yes. 6 THE WITNESS: Yes. 7 Q. And when — was there anybody else living 7 BY MR. CRITTON: 8 there at that apartment with you, Jessie and E.W. during 8 Q. And at that time that M. first approached 9 that few months that you were there in 2006? 9 you, were you aware that E.W. — whether or not E.W. had 10 A. No. 10 been to Mr. Epstein's home? 11 Q. And that's when you met mom — mum — E.W.'s 11 A. I didn't know fora fact, no. 12 mother? sorry. 12 Q ESOrrY? 13 MR. EDWARDS: Foam 13 A. II did not know fora fact. 14 THE WITNESS: Yes. 14 Q. And what did — what did III. tell you? 15 BY MR. CRITTON: 15 A. About going to Jefft E ins house. 16 Q. And did E.W. say, you need to get a job, you 16 Q. What did — what did . raise with you? 17 know, why not -- maybe my mom can help you get a job at 17 That is how did the — before . ever told you or 18 IHOP? 18 asked you whether.. be interestecS:oing to 19 A. No. I expressed to her that I wanted a job. 19 Mr. Epstein's home, did she -- that is M. — were you 20 Q. Had you had a job before that point in time? 20 aware that she had been to Mr. Epstein's home? That is 21 A. Not really a real job. I had — I had a job, 21 had she talked about it amongst you all? 22 but I — I like went there fora week, and stopped. 22 MR. EDWARDS: Object to the form. 23 Q. And that was where? 23 THE WITNESS: I had heard about it, not from 24 A. I worked foramen named Stan Crooks. 24 25 Q. Who Is Stan Crooks? 25 Page 160 Page 162 1 A. He is an auctioneer. He is my uncle's 1 BY MR. CRITTON: 2 friend. 2 Q. What had you heard and from whom? 3 Q. The uncle who drove you to Mr. Epstein's 3 A. I don't remember who exactly it was. It may 4 home? 4 have been..'s boyfriend at the time. A. No. 5 Q. Which boyfriend would that have been? 6 Q. Another uncle? 6 A. I don't know. I think probably her baby's 7 A. Yes. 7 'Other. 8 Q. Another brother of Mr. Dial? 8 Q. Justin Sprague? 9 A. Yes. 9 A. Yes. 10 Q. What's his name? 10 Q. Did you know Cory Sprague? 11 A. Oakley. 11 A. Yes. 12 Q. Is his first name? 12 Q. Okay. Did you ever have sexual relationship 13 A. Yes. 13 with Justin Sprague? 14 Q. What's his last name? 14 A. No. 15 A. Brown. 15 Q. Did you ever have one with Coxy Swam? 16 Q. They — looks like theres a — was it a 16 MR. EDWARDS: Object to the fonm.•• 17 Jeff Brown? 17 instructing the witness not to answer, invoking her 18 A. Yes. 18 privacy rights, privacy rights of third parties. 19 Q. A Jeff Brown and Oakley Brown, but they're — 19 MR. CRITTON: Well, let me just do something 20 are they like stepbrothers with your dad? 20 so we can get this on the record. 21 A. My dad was a first born. He has a different 21 Is — let me have marked as Exhibit -- where 22 father. 22 are we — 5. 23 Q. All right. So I think you told me you would 23 (Discussion held off the record.) 24 have been at Mr. Epstein's house -- you would have been 24 MR. CRITION: Four was the declaration of 25 in the eighth grade for the first time, eighth grade, 25 Marie Villafana. 9 (Pages 159 to 162) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1662) Electronically signed by Pamela Sullivan (501.333.172.1662) 4115158d-6c22-4c50-b036-e423618c21b5 EFTA00723113 Page 163 Page 165 1 This is going to be marked as Exhibit 5. 1 support her novel position that the Plaintiff who 2 (Discussion held off the record.) 2 puts her mental, emotional and psychiatric state at 3 (Defendants Exhibit No. 5 was marked for 3 issue can place a limitation on the number of times 4 identification.) 4 defense counsel, or agents retained by him, can 5 BY MR. CFUTTON: 5 inquire into areas relevant to these 'Min where 6 Q. Exhibit 5 is the order that Judge Johnson the subject matter involved is highly personal, 7 entered on September 4,2009, in the consolidated case 7 embarrassing, sensitive or otherwise humiliating. 8 that dealt specifically with Mr. Epstein's emergency Plaintiff is seeking millions of dollars in 9 motion for independent medical exam, and it was directed 9 personal injury damages for, among other things, 10 to Mr. Ifill's client, 10 physical injury, pain and suffering, emotional 11 Within — within that order, on Page 2 she 1 distress, psychological, mental anguish, 12 says — or dealt with questions that could be asked, the 12 humiliation, embarrassment, loss of self-esteem, 13 scope of the exam. But Judge Johnson — 13 loss ofdignity and invasion of her privacy. And 14 MR. CHINON: And I just want to put this on 14 she on to describe at least specifically to 15 the record, and then we can move on, if your 15 16 instruction is the same, Brad. 16 And then the last two sections I want to just 17 But she talks about it in the first paragraph 17 put on the record is on the first — first MI 18 on the second page, first full paragraph. She, 16 paragraph on Page 4. It says: Under these 19 Judge Johnson, who's dealing with a discovery 1 circumstances, where Plaintiff — 20 issue, says, the remaining issues involve 20 MR. EDWARDS: Circumstances of-., that's 21 Plaintiffs request for an order limiting the scope 21 what we're talking about; right? 22 of the proposed examination by disallowing repeated 22 MR. CIUTTON: Right. 23 questioning regarding, quote, highly sensitive 23 Under these circumstances — 24 areas of inquiry, including Plaintiffs medical 24 MR. EDWARDS: Yes. 25 history, psychiatric history, sexual history, 25 MR. CRITTON: — where Plaintiff is seeking Page 164 Page 166 1 social history, sexual abuse history, substance 1 to recover medical expenses associated with these 2 abuse history, et cetera, and imposing certain time 2 complex medical issues, full knowledge of the 3 restraints on the examination itself 3 Plaintiffs past and present medical, And the Court goes on to deny — the 4 psychological, familial, social histories is 5 Plaintiffs request to limit the scope of the 5 essential. And while neither a duplication nor 6 examination is denied. 6 embarrassment is desired, under the circumstances 7 And if you go over on Page 3, Judge Johnson 7 presented, where the number and the scope of 8 says: Presumably, Plaintiff—and there was a -- 8 damages claimed are vast and the Plaintiffs past 9 there was a questionnaire that was being referenced 9 history eventful, it may nonetheless be 10 then — she says: Presumably, Plaintiff, who in 10 unavoidable. 11 this instance to this older was-., but it 11 And then she goes: This is not to say that 12 applies to every Federal court Plaintiff, will be 12 the restrictions on the scope of the questions may 13 asked these questions two or more times, first by 13 never be put into effect, and if the case 14 defense counsel at And/tone's deposition scheduled 14 progresses, and Plaintiff can show that Defendant's 15 to take place shortly, and again by Dr. Hall at the 15 invasive questioning is being done in bad faith or 16 upcoming examination. 16 for purposes ofharassment, the Court may 17 And then she goes on to say that Plaintiffs 17 reconsider imposing limitations of the sort 18 objection is that, by having to answer these same 18 requested herein. 19 questions about the same subject matter three 19 At this point however, the Court agrees with 20 separate times would only serve to embarrass, 2 Defendant that to restrict the number of times 21 humiliate, intimidate and further victimize the 21 defense counsel may ask the Plaintiff personal and 22 Plaintiff. 22 sensitive questions concerning some of the pivotal 23 She - she - Judge Johnson goes on to say at 23 issues in this case would work an injustice by 24 the next full paragraph: Plaintiffs site no case 24 preventing Defendant from being able to defend 25 law, and independent research has uncovered none to 25 himself. SALL.N.a..“*.erIbLenf 10 (Pages 163 to 166) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4115158d-t3c22-4c50-b036-e423618c2145 EFTA00723114 Page 167 Page 169 1 So I don't know ;whether you have seen this 1 MR. EDWARDS: If it relates to sexual 2 order — 2 partners' names or sexual positions and things that 3 MR. EDWARDS: Yeah. Well,1— I haven't 3 are obviously intended only to humiliate, yes, 4 seen it, but having read that, it certainly doesn't 4 that's going to be my objection. 5 change my position. Ifs clearly talking about a 5 MR. CRITTON: Now, Pam, if I could get you to 6 different Plaintiff different set of 6 go back to the question I asked. 7 circumstances. And very seldom, if ever, does it 7 So long, Adam. 8 talk about issues regarding the names of sexual 8 (Whereupon, Mr. Horowitz left the 9 partners, sexual positions or sexual activity. It 9 proceedings.) 10 talks about other things that 1 have let you 10 (Whereupon, the requested portion of the 11 conduct your examination on. So... 11 record was read aloud by the Court Reporter.) 12 MR. HILL: And the other thing is, is I filed 12 MR. CRITTON: Let me be clear on the 13 the motion so, to be included in this record, the 13 question. Let me see the question preceding. 14 scope of the relief that I was seeking, the motion 14 COURT REPORTER: This is the preceding 15 for protective order. The motion to limit the Chit 15 question... 16 was regarding repeated questioning in the same 16 (Whereupon, the requested portion of the 17 areas of inquiry. Nothing about that motion for 17 record was read aloud by the Court Reporter.) 18 protective order sought to prevent discussion about 18 BY MR. CRITTON: 19 past sexual history at all. It was to the number 19 Q. All right. Let me just ask the question so 20 of times it could be disclosed and discussed. 20 it is clear: Did you ever have a sexual relationship 21 So to suggest that that is somehow a ruling 21 with Cory Sprague? 22 that everything is open game is not entirely 22 MR. EDWARDS: And instructing the witness 23 consistent with the relief that I was seeking in 23 not to answer, based on her own privacy rights, as 24 that motion. 24 well as the privacy rights of third-party, innocent 25 MR. EDWARDS: So if you want to make this an 25 persons. Page 168 Page 170 1 exhibit, you can. 1 BY MR. CRITTON: 2 MR. CRITTON: just saying -- 2 Q. Were you aware that-. has — as of today, 3 MR. EDWARDS: It certainly doesn't change my 3 are you aware that at some point in time she had a 4 position. 4 sexual relationship with Cory Sprague? 5 MR. CRITTON: All right. And just saying 5 A. No. 6 this is — we're going to come — I will certainly 6 Q. Are you aware that. had a sexual 7 ask the Court for relief - 7 relationship, not only with Justin Sprague, but as well 8 MR. EDWARDS: Sure. 8 Cory Sprague? 9 MR. CRITTON: -- for sanctions and the costs 9 MIL CR1TTON: Did I soya? Did 1 say — 10 and fees related to that. 10 MR. EDWARDS: Well, you just asked the same 11 ljust wanted to give you the opportunity to 11 question twice. 12 read the order and what she said about defense 12 BY MR. CRITTON: 13 counsel asking repeated questions about these areas 13 Q. Right. Are aware that E.W. had a sexual 14 or the number of times that they'll be asked, not 14 relationship, as did..., with both Justin Sprague and 15 only by defense counsel — 15 Cory Sprague? 16 MR. EDWARDS: It sounds like - 16 A. I knew that E.W. had dated Justin before 17 MR. CRITTON: -- but as well by the doctor. 17 did. 18 So I think ifs an appropriate area. You can 18 Q. Okay. Were you aware that she had a — had 19 still stay with your same instructions. 19 sexual activity, both with — or with Justin Sprague? 20 MR. EDWARDS: Yeah, it sounds like you can 20 A. No. 21 ask it as many tunes as you want 21 Q. Did she tell you that? 22 MR. CRITTON: And you'll continue to object. 22 A. Well, E-W.? Yes. 23 MR. EDWARDS: Well, it depends on the 23 Q. She told you she had had sexual relationship 24 question. 24 with Justin Sprague? 25 MR. CRITTON: All right 25 A. Yes. 11 (Pages 167 to 170) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772-1552) 4f15158d-Sc22-tic50-b036-e423618c2fb5 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00723115 Page 171 Page 173 1 Q. Did she tell — did she, E.W., as viell tell 1 Q. So if al has testified under oath that 2 you she had a sexual relationship or had sexual activity 2 Justin didn't care and just said, bring home the bacon, 3 with Cory Sprague? 3 that would be a surprise to you? 4 A. No. 4 MR EDWARDS: Object to the form. 5 Q. Did you ever tell E.W. whether you had sexual 5 THE WITNESS: I wouldn't really care whether 6 activity with Cory? 6 Justin wanted her to go or not. That's none of my 7 A. No. 7 business. Q. Did you ever tell whether you had a 8 BY MR. CRITTON: 9 sexual relationship with Cory? 9 Q. And that was not my question. So il going 10 A. No. 10 to ask Pamela to read it back to you, and if you could 11 Q. Now back to how you learned about 11 answer my question, please. 12 Mr. Epstein. I think ou said that Justin Sprague, who 12 (Whereupon, the requested portion of the 13 was the father ofIM's son? 13 record was read aloud by the Court Reporter.) 14 A. Yes. 14 BY MR. CRITTON: 15 Q. And his name is 'a? 15 Q Latae rephrase it, then. 16 A. as son? 16 If has testi under oath that Justin 17 Q. Yes. 17 said, being aware that l= was getting money from this 18 A. No. 18 old guy in P 3each, that his response — Justin's 19 Q. What's his name? 19 response to SE was, I don't care, just bring home the 20 20 bacon, that — A. Well, =sure 21 •Q. al That's right. gm =sorry. 21 22 COURT REPORTER: Spell? 22 Q. Let me finish the question. 23 BY MR. CRITTON: 23 — that would be a surprise to you, based 24 Q. Spelled? 24 upon at least what you —your impression is from 25 A. C-a-i-d-e-n. 25 Justin; is that correct? Page 172 Page 174 1 COURT REPORTER: And Sprague? 1 MR.13DWARDS: Object to the form. 2 THE WITNESS: I don't know his last name — 2 THE WITNESS: I don't know. 3 MR. CRITTON: S-p-r-a-g-u-e, I believe. 3 BY MR. CRJTTON: 4 That's how I've seen it answered in 4 Q. All right. You might not be surprised one 5 interrogatories. 5 way or the other; true? 6 BY MR. CRITTON: 6 MR. EDWARDS: Object to the form. 7 Q. What did you hear fmm Justin, or what did — 7 THE WITNESS: Yeah, that's true. 8 what was Justin saying about Mr. Epstein? 8 BY MR. CRITTON: 9 A. That a was seeing some old guy, who was 9 Q. Was Justin working at that time? 10 paying her money. 10 A. I don't know. 11 Q. And Justin, did he think that was a good idea 11 Q. How old was Justin at the time thte 12 because she was getting money? 12 was — he was having a relationship with MI.? And 1 13 MR. EDWARDS: Object to the font 13 guess you both -- if I understood, she probably was in 14 BY MR. CRITTON: 14 the ninth grade, because you were doing the second year 15 Q. What did he say? 15 of eighth grade; correct? 16 A. I think Justin was probably upset about it. 16 A. I don't know. 17 Q. And what malcskyou believe that Justin may 17 Q. Is Justin older, younger? 18 have been upset about going — or seeing some old 18 A. I don't know how old — 19 guy, as you — as he described it to you, who was paying 19 Q. Were they — 20 her money? What did he say? 20 A. —he is. 21 A. I don't remember exactly what he said. 21 Q. Were they living together? 22 sure that he wasn't happy about it, though. 22 A. Yes. 23 Q. What — what makes you believe that? 23 Q. Where were they living together? 24 A. Because they were living together, and they 24 A. I don't know. Ina trailer. 25 were, I guess, in a relationship. 25 Q. And how long had they been living together? 12 (Pages 171 to 174) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501.333-772-1552) 015188d40.22465044136442X418c:db5 EFTA00723116 Page 175 Page 177 1 A. I don't know. 1 THE WITNESS: I didn't look into it. 2 Had you ever gone over and stayed -- or gone 2 BY MR. CRITPDN: 3 to MM. and Justin's trailer and stayed — stayed there, 3 Q. some? 4 partied with them? 4 A. I didn't look into it 5 A. No. 5 Q. Well, why did Justin even mention it to you? 6 Q. Hung out? 6 MR. EDWARDS: Object to the form. 7 A. I had gone there before, yes. 7 THE WITNESS: I don't know. 8 Q. Okay. When Justin was there? 8 BY MR. CRITTON: 9 A. Yes. 9 Q. Did he tell you how much money she was 10 Q. How many months before that you — before 10 getting? 11 that you first went to Epstein's? Had they been living 11 A. No. 12 together a number of months? 12 Q. Did he tell you what she was doing with 13 A. I don't know. 13 hirn — 14 Q. Okay. How long before had you been to 14 A. No. 15 their — before Justin said something to you about IS 15 Q. — for the money? 16 going over to — that some old guy was paying her? Was 16 A. No. 17 that at least a month or two? 17 Q. Okay. Did she — did he tell you who the guy 18 A. I don't know. 18 was? 19 Q. Okay. Did they continue to live together for 19 A. No. 20 a number of months? 20 Did he tell you where the guy was — 21 A I don't know how long they lived together. 21 A No. 22 Q. How many times did you ever go to their 22 Q. or where he lived? 23 trailer? 23 A. No. 24 A. Two. 24 Q. He just said, is getting money from some 25 Q. And did E.W. ever go with you? 25 older guy? Page 176 Page 178 1 A. No. 1 A. Yes. Q. When you went to their trailer on those two 2 Q. Okay. And what did you interpret that in 3 occasions, would it be a correct statement that you had 3 your own mind to mean? both alcohol and smoked pot? 4 MR. EDWARDS: Object to the form. 5 A. No. 5 THE WITNESS: I don't know. 6 Q. Okay. On either occasion did you smoke pot 6 BY MR. CRITTON: 7 when you were with Justin and a 7 Q. Okay. Did you — did you wonder why.. was 8 A. Probably on one. 8 being paid money by some person just to go to his house? 9 _S. Okay. And did you ever have alcohol with 9 MR. EDWARDS: Object to the form. 10 Ng and Justin, as well? 10 THE WTINESS: Sure I wondered, but I didn't 11 A. No. 11 at 12 Q. Okay. So Justin tells you.. was getting 12 BY MR. CRITTON: 13 money from some older guy. Did she — 13 Q. Had — to your knowledge, hadll. ever 14 MR. EDWARDS: Object to the form. 14 received money from men for doing things, whatever those 15 BY MR. CRITTON: 15 things might be? 16 Q. Is that correct? Before — beforeM. ever 16 MR. EDWARDS: Object to the form. 17 referenced milting to you or said anything to you? 17 THE WITNESS: I don't know. 18 A. Yes. 18 BY MR. CRITTON: 19 Q. Okay. And when he said — when Justin told 19 Q. Okay. She may have; she may not. You just 20 you that, was anybody else present? 20 don't know, at least at that point in time; right? 21 A. I don't know. 21 MR. EDWARDS: Object to the form. 22 Q. What was your reaction-- well, let me ask 22 THE WITNESS: I don't know. 23 you this: What did Justin — did you say, well, what do 23 BY MR. CRITTON: 24 you mean she's getting money from an older guy? 24 Q. That's what saying. Listen to my 25 MR. EDWARDS: Object to the form. 25 question. As of the time that Justin raised the issue 13 (Pages 175 to 178) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772-1652) 4f15158d-6c22.4c50-b036-e423618c2fb5 Electronically signed by Pamela Sullivan (501-333-T/2-1552) EFTA00723117 Page 179 Page 181 1 with you, before you went to Mr. Epstein's the first 1 Q. Do you remember when that was? 2 time, that was getting some money from some old 2 A. No. 3 guy, do you -- do you have any knowledge whether she had 3 Q. Did they give you cards? 4 ever received money from a young person or an old person 4 A. Yes. 5 for doing anything? 5 Q. Do you still have those cards? 6 A. No. 6 A. No. 7 Q. Was anybody else present when Justin said 7 Q. What did you do with those cards? 8 that to you? 8 A. I don't know. 9 A. I don't know. 9 Q. Did you ever turn them over to Mr. Edwards? 10 Q. Well, when's the next time — how much — how 10 A. I don't think so. 11 much time passed before again the issue of getting 11 Q. Okay. You said there were two lawyers, but 12 money for — from some older nun — 12 whatever the card said was who they were? 13 MR. EDWARDS: Object to the tbnn. 13 MR. EDWARDS: Object to the form. 14 BY MR. CRITTON: 14 THE WITNESS: Yes. 15 Q. -ante up again? 15 BY MR. CRITTON: 16 A. I don't know if it did. 16 Q. How much time did they spend with you? 17 Q. Okay. Did you tell the FRI that 17 A. I don't know. 18 Justin Sprague had mentioned that was getting money 18 Q. More than five minutes? 19 from an older guy? 19 A. I don't know. 20 A. No. 20 Q. More than an hour? 21 Q. Okay. You're tell — just telling us that 21 A. I don't know. 22 now? 22 Q. Okay. So you can't you said two 23 MR. EDWARDS: Object to the form. 23 individuals who — who were there on behalf of 24 THIEWITNESS: Yes. 24 Mr. Epstein met with you, talked with you. You don't 25 25 know — you can't tell me the date or even the year, Page 180 Page 182 1 BY MR. CRITTON: 1 owe& 2 Q. By the way, have you ever given any 2 A. Yes. 3 statements to anyone else? Anybody else ask you about 3 Q. Okay. That's -- and you can't tell me how 4 Epstein at any lime? 4 long you spoke with them, whether it was five minutes or 5 MR. EDWARDS: Objection. Don't answer. 5 three hour: correct? 6 Attorney-client privilege. 6 A. It wasn't very long. 7 BY MR. CRITTON: 7 Q. Five to ten minutes? 8 Q. Well, except -- and 1-- when I ask questions 8 A. Maybe. 9 Illce that — and Emd will still make his objections, 9 Q. Did they take any notes? 10 which will remind me — not interested whether 10 A. I don't know. 11 some — Mr. Edwards or someone from his office asked 11 Q. Did they record a statement from you at all? 12 you. You know, — confident that he interviewed 12 A. No. 13 you or someone from his office interviewed you. So 13 Q. Did you tell them the truth? 14 separate that. 14 A. I don't know. 15 Have you ever given any other statements, 15 Q. Okay. Are you in the habit of lying to 16 either in writing, orally, by tape, by stenographer, to 16 people? 17 any other person, other than the FBI, and talked about 17 MR. EDWARDS: Object to the fonn. 18 Epstein? 18 THE WITNESS: No 19 A. Yes. 19 BY MR. CR1TT 20 Q. lowborn? 20 Q. You have lied before, though, in a c 2]. A. I spoke to two lawyers who came to my house, 21. proceeding; have you not? 22 which apparently represented Jeffrey Epstein at the 22 A. Yes, I have. 23 time. 23 Q. All right. And, in fact, in your father's 24 Q. On just one occasion? 24 proceedings that involved the charges that were brought 25 A. Yes. 25 against your father for killing Joey is you gave a 14 (Pages 179 to 182) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501.333-772-1552) 4116158460244:5040364423$18afb5 EFTA00723118 Page 183 Page 185 1 number ofconflicting statements — 1 MR. EDWARDS: Object to the form. 2 A. Yes. 2 THE WITNESS: Yes. 3 Q. — not only in deposition, but as well in 3 BY MR. CRITTON: 4 court; true? 4 Q. Something like that? 5 A. Yes. 5 A. Yes. 6 Q. Okay. And you admitted that in those court 6 Q. Did you inquire and say, well, what's she 7 proceedings you lied on a number of those statements; 7 doing to get money? 8 true? 8 A. Na 9 MR. EDWARDS: Object to the form. 9 Q. Okay. Did you have a job at the time? 10 THE WITNESS: Yes. 10 A. No. 11 BY MR. CRITTON: 11 Q. Well, who supported you back at this time in 12 Q. Add you lied to either help your father or to 12 seventh, eighth, ninth grade? Who supported you? 13 help your mother, depending on which side you were 13 A. My grandmother. 14 taking on a particular occasion; correct? 14 Q. Okay. And that's Ms. Brewer? 15 A. Yes. 15 A. Yes. 16 Q. Other than the statement that you gave to 16 Q. Does your — and did your grandmother work 17 these two individuals on behalfof Mr. Epstein and the 17 during that time period? 18 FBI, separate and apart from your lawyers, are those the 18 A. Yes. 19 only two statements that you've ever given about any 19 What kind ofwork did she do? 20 facts or circumstances relating to your visits to 20 A. She works at Home Depot 21 Mr. Epstein's home? 21 Q. Does she still work there? 22 A. No. 22 A. Yes. 23 Q. Who else have you given a statement to? 23 Q. And does she own the house on Edge Hill Road? 24 A. A therapist. 24 A. Yes. 25 Q. Did she take a recorded state — is that 25 Q. Okay. And when you lived on — and she had Page 184 Page 186 i. Randee Speclale? 1 scar? 2 A. Yes. 2 A. Yes. 3 Q. Did — and I assume that's a she? 3 Q. And what does she do for Home Depot? 4 A. Yes. 4 A. She's a manager. 5 Q. Did she take a recorded statement, or you've 5 Q. is she the G the general manager of the 6 just talked about it with her? 6 store, or manager of a department? 7 A. !just talked to her about it 7 A. III not positive. 8 Q. Let's go back to Justin Sprague. So Justin 8 Q. How long has she worked for Home Depot? 9 told you, at some point before you first went, is that 9 A. I think II years.Eno( sure exactly, 10 was doing something with an older man, and she was 10 though. 11 getting money; right? 11 Q. And the house that you lived in or that 12 MR. EDWARDS: Form. 12 you were living at the time on Edge Hill Road, how many 13 THE WITNESS: Yes. 13 bedrooms is it? 14 BY MR. CRITTON: 14 A. Three. 15 Q. Okay. Did he tell you how much money she was 15 Q. Okay. And did you have your own room? 16 getting? 16 A. Yes. 17 A. No. 17 Q. Did you share a bathroom, or did you have 18 Q. And as to why he told you, do you know why he 18 your own bathroom? 19 told you? That is, it just came out of the air, hey, 19 A. !have my own bathroom. 20 M.'s making money from some old man, and he's paying 20 Q. And did -- and Ms. Brewer, that is your 21 her money? 21 grandmother, did she, if you wanted, if you needed a new 22 A. 1think I went to his house at one point when 22 pair of shoes, if you needed clothes, would she help you 23 she wasn't there and asked him where she was. 23 get those? 24 Q. Oh, and he said, she's over at some older 24 A. When 1 was living her - with her, yes, she 25 guys house, and he's paying her money? 25 did. • •N.• • • mc-w•V‘ 15 (Pages 183 to 186) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333.772-1552) Electronically signed by Pamela Sullivan (601.333-772.1552) 4f151664-6c22-4c50-b036-0423618c2tb6 EFTA00723119 Page 187 Page 189 1 Q. So she had a home, so you had shelter, you 1 And did you ever try to get back to your 2 had you had clothing, and — and I assume she fed 2 grandma's house? 3 you. I mean, she bought the groceries so that you all 3 A. No. 4 could eat? 4 Q. When and when you were staying with 5 A. When I was living with her, yes. 5 Ms. Kaputsa and her family, did they give you food, 6 Q. And she — she, as well, would you help her 6 shelter, clothing, help you out? 7 do grocery shopping from time to time? 7 A. Yeah. 8 A. Yes. 8 Q. Okay. And did your grandmother help you at 9 Q. And would you help her with the cooking and 9 all during that time period? 10 whatever other, you know, kind of like a typical person, 10 A. No. 11 typical daughter or granddaughter, you helped with 11 Q. Did your mother help you at that time period? 12 chores around the house, or did you not? 12. A. No. 13 MR. EDWARDS: Form. 13 Q. But it was your choice to run away from your 14 THE WITNESS: Yes. 14 mother, correct? That is, you made a voluntary choice, 15 BY MR. CRITTON: 15 I don't want to be with mother anymore? 16 Q. Okay. You did help? 16 A. Well, yes. But... 17 A. Yes. 17 Q. You — you made — you made a voluntary, 18 Q. And did she give you an allowance, as well? 18 knowledgeable decision, l don't want to stay with my moo 19 A. No. 19 anymore, for whatever the circumstances, I want to go to 20 Q. Pardon? 20 Melissa's, and Melissa's family took you in? 21 A. No. 21 A. Yes. 22 Q. Did she give you some spending money? If you 22 Q. Okay. Did you ever — and when you left your 23 needed to go — if you wanted to go to a movie with your 23 grandmother's house — did you leave your grandmother's 24 friends or you were going out to dinner with your 24 house, what, in eighth, ninth grade? What grade? 25 friends, would she say, you know, here's five or tenor 25 A. When we rust moved I was living with my mom, Page 188 Page 190 15 bucks so you can go do something? 1 and I was going back and forth. 2 MR. EDWARDS: Fonn. 2 Q. Between grandmother's and mom? 3 THE WITNESS: Yes, when I was living with 3 A. My mom's, yes. 4 her, she did. 4 Q. All right. And when you were living with 5 BY MR. CRTITON: 5 your mom, she would provide food, shelter, clothing; 6 Q. And did you live with her during that time 6 coned? 7 period, that is eighth — eighth grade -- both eighth 7 A. No. 8 grades, ninth and tenth? 8 Q. Okay. Well, what did you do? Did she 9 A. I was living with my mom, and I ran away. 9 provide food? 10 Q. Okay. And where did you run when you ran? 10 A. Not forme. 11 A. Iran to my friend, Melissa's. 11 Q. When you were living with her? 12 Q. ICaputslca, or whatever? I probably missed 12 A. Yes. 13 that, probably. 13 Q. Where did you get your food? 14 A. Kapusta. 14 A. My friends. 15 Q. Kapusta. 15 Q. You mean you would go ova to other people's 16 A. Kapusta. 16 houses to eat? 17 Q. Kapusta. Did you — is that where you went, 17 A. Yes. 18 to Melissa's — well coiner Melissa, and we won't 18 Q. Did your mother — I've read somewhere she 19 butcher her name — you went to Melissa's house? 19 has drug problems. 20 A. Yes. 20 A. Yes. 21 Q. And would the family let you stay there? 21 Q. Okay. And has she been on — had significant 22 A. Yes. 22 drug problems ever since you can -- your earliest 23 Q. Her family? 23 memories of her? 24 A. Her mother. 24 A. Yes. 25 Q. Her mother. 25 Q. All right. And I assume that's been a 16 (Pages 187 to 190) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1552) Electronically signed by Pamela Sullivan (501-333-772-1652) 4115158d4c22-400-b0364423618c2fb5 EFTA00723120 Page 191 Page 193 1 substantial burden on you mentally, emotionally? 1 nonprescription drugs? 2 MR. EDWARDS: Object to the form 2 A. No. 3 THE WITNESS: rye always had my grandmother, 3 Q. Have you ever seen him physically or verbally 4 SO no. 4 abuse your mother? 5 BY MR. CRITTON: 5 A. No. 6 Q. So you don't care — I mean, it — it had no 6 Q. It's your testimony you're unaware of any 7 impact on you that your mother -- well, let me strike 7 domestic violence issues associated between Mr. Vett and 8 that. 8 your mother, is that -- 9 I've seen some places that she's a crack 9 A. Yes. 10 addict, is that true? 10 Q. Are you closer to your father than you are 11 A. Yes. 11 your mother? 12 Q. All right. And would you agree with me that 12 A. Yes. 13 has had an emotional impact on your life? 13 Q. Why? 14 MR. EDWARDS: Object to the form. 14 A. Probably because ofmy grandmother. 15 THE WITNESS: Not really. 15 Q. Because your grandmother, Ms. Brewer, is your 16 BY MR. CRITTON: 16 father's -- 17 Q. Okay. So the fact that your mother has been 17 A. Mother. 18 a crack addict since you can remember or had significant 18 Q. -- mother. Right. 19 drug problems since your earliest recollection, it's 19 But you, in fact, saw your father kick and 20 your testimony to this jury that has had no emotional 20 physically abuse key to the point where that young man 21 impact on you or psychological impact on you at all? 21 died in 1999; isn't that true? 22 MR. EDWARDS: Object to the form. 22 A. I never saw him kick Joey. 23 BY MR. CANTON: 23 Q. Okay. So, but you've given -- you gave a 24 Q. Is that your testimony? 24 statement — we'll get to that later — that you 25 A. I've always had my grandmother, so no, not 25 actually saw your father physically abuse Joey. Page 192 Page 194 1 really. I never — 1 MR. EDWARDS: You're going to get to it 2 Q. I also saw in the records that your father 2 later, or we're going to — or you want her to 3 and your mother had a very violent relationship -- 3 answer — answer the question? 4 A. I've been told — 4 MR. CRITTON: No, we're going to get —1 5 Q. — are you aware of that? 5 want an answer to that now, but ■ going to come 6 A. I've been told that, yes. 6 back to it later. 7 Q. Okay. And then your mother, with a 7 MR. EDWARDS: Clotcha. 8 subsequent person named Wet - am I saying that right? THE WITNESS: Yes, l did see him abuse Joey. 9 A. Tom Vett. 9 BY MR. CRITTON: 10 Q. — Veet, they also had a very violent, 10 Q. Okay. And you're aware that, as a result of 11 abusive relationship; are you aware of that? 11 his physical abuse to Joey, Joey died? 12 A. No. 12 A. Yes, I am. 13 Q Did your mother ever tell you about that? 13 Q. And that has had a huge psychological and 14 A. No. 14 emotional impact on you since you were a young child, up 15 Q. Do you know Mr. Veet? 15 through and including even today, isn't that true? 16 A. Yes. 16 MR. EDWARDS: Fenn. 17 Q. Okay. What's your impression of him? 17 THE WITNESS: Yes. 18 A. I -- 18 BY MR. CRITTON: 19 hit EDWARDS: Object to the form. 19 Q. II sorry? 20 THE WITNESS: I don't like him. 20 A. Yes. 21 BY MR. CRITTON: 21 Q. Because your father has been in prison since 22 Q. Does he have the same type of druWecohol 22 sometime in, what, '99, one place or another? 23 problems that your mother has always had? 23 A. Yes. 24 A. I don't know. 24 Q. Has he been able to provide any support for 25 Q. Have you ever seen him use drugs, and I mean 25 you, or does the support all come from his mother, 17 (Pages 191 to 199) (5 61) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1552) Electronically signed by Pamela Sullivan (501.333-772-1552) 41.1515Eld-6c22-4c50-b036-e423618c2ib5 EFTA00723121 Page 195 Page 197 1 Ms. Brewer? 1. Q. For what? What had you done that brought 2 A. Yes, all from — 2 about you getting sent to Milton? 3 Q. All from grandma - 3 MR. EDWARDS: Fenn. 4 A. Yes. 4 THE WITNESS: I crashed my grandmother's car. 5 Q. — your grandmother? 5 BY MR. CRITTON: 6 All right. During the — the second half of 6 EsonY7 7 your second stint, second year that you took eighth 7 A. I crashed my grandmother's car. 8 grade in '03, then ninth, tenth grade, you — were you 8 Q. You were charged, at least initially, with 9 in school in ninth and tenth grade, too? 9 grand theft auto for that; weren't you? 10 A. No. I went to — I, I didn't go to school 10 A. Yes. 11 because of running away. And so I went to another 11 Q. And did you do a plea deal as a juvenile? 12 school called Jaega Middle School. 12 A. No. 13 Q. Jaega? 13 Q. What happened? 14 A. Yes. 14 A. I was sent to the program. 15 Q. Spell it forme. 15 Q. Okay. Did you plead guilty, guilty to having 16 A. J-a-e-g-a. 16 stolen a car? 17 Q. J-a-e-j -- 17 MR. EDWARDS: Object to the form. 18 A. G-a. 18 BY MR. CRITTON: 19 Q. Is that a public school, or a private school? 19 Q. And then they essentially said, okay, you can 20 A. It's a public school. 20 go to the program, and that will be your sentence? 21 Q. Where is that located? 21 A. I don't know. 22 A. West Palm Beach. 22 Q. Did you have an attorney that represented you 23 Q. How long were you — what grade was that, and 23 in those proceedings? 24 how long were you there? 24 A. I don't blow. 25 A. I was in there for the eighth grade again, 25 Q. All you know is that you ended up at Milton Page 196 Page 198 1 and I didn't go there for very long, maybe a month. 1 for five months, one week and three days? 2 Q. How far did you get in school? 2 A. Yes. 3 A. I only went to the eighth grade, until I got 3 Q. Give me a time period for that, that is when 4 my GED. 4 you were there. 5 Q. When did you get your GED? 5 A. It was I went there in July. 6 A. When I went to a program for girls. 6 Q. Of what year? 7 Q. Was that at Milton? 7 A. When l was 17. And I — I carte out in 8 A. Yes. 8 December, close to -- 9 Q How long were you at Milton? 9 Q. And so that would have been in '05, July of 10 A. Five months, one week and three days. 10 '05? 11 Q. Sounds like you have a very good recollection 11 A. 1— I guess so, if I was 17 in that year. 12 of that. 12 Q. Well, you were born in '88; right? So 17 and 13 A. Yes. 13 88 is what? 14 Q. Where Is Milton located? 14 A. I don't know. 15 A. In Milton, Florida 15 Q. '05. 16 Let me go back to — just trying to 16 Q. Which is where? 17 A. Which is near Okaloosa County. 17 figure out where you were living there in the time 18 Q. sort)/ 18 that — when you went to — when you were -- first went 19 A. Near Okaloosa. 19 to — say you went to Mr. Epstein's house, you would 20 Q. Where is Okaloosa? 20 have been living with Ms. Brewer; right? 21 A. In the Panhandle. 21 A. Yes. 22 Q. And were you required to go there? 22 Q. Okay. How long, then, did you live with 23 A. Yes. 23 Ms. Brewer? Did you — what years did you live with 24 Q. That's like a sentence? 24 Ms. Brewer? I know the beginning of '03. At least by 25 A. Yes. 25 '03 you were living with her, January of '03. How long 1.6•.• 18 (Pages 195 to 198) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) 4f15158d-Sc22-4c50-b036-0423618c21b5 Electronically signed by Pamela Sullivan (501-333.772-1552) EFTA00723122 Page 199 Page 201 1 did you stay with her? 1 A. I don't how. 2 A. I I was a runaway at that time in '03. 2 Q. A month? A week? 3 Q. You had already run away. You weren't 3 A. 1 don't know. 4 staying with your grandmother at that point? 4 Q. Did you ever — and what did say to you? 5 A. I was with my mother, and I ran away. 5 A. She told me that she wanted me to go with her 6 Q. At the time that you had the conversation 6 to this guy's house and -- pretty much she just told me 7 with Tat with Justin Sprague about going over 7 that she wanted me to go with her, and that I would get 8 and get doing something with an older man and getting 8 money for with her. 9 money, were you already a runaway? 9 Q. Did tell you how long she had been 10 A. No. 10 going? 11 Q. You were living with your grandma? 11 A. No. 12 A. I was a runaway until my dad's trial. And 12 Q. Did ig come to your house to tell you this? 13 after that, I was living with — I was living with my 13 Were you at the trailer — her trailer with Justin 14 mother, and then she put me in a shelter for nmaways. 14 Sprague? 15 And then after that my grandmother got custody of me, 15 A. She came to my house. 16 and I lived with her after that. 16 Q. And you were living then with? 17 Q. Do you blOW when you lived with your 17 A. Grandmother. 18 grandmother? 18 Q. And would it be a correct statement that 19 A. I don't know exactly what day it was. 19 during the entire time you went to Mr. Epstein's house, 20 Q. Was it before you went — well, I don't need 20 that period you were always living with your 21 an exact date. Just give me a month and a year. 21 grandmother? 22 A. I don't remember. 22 A. Yes. 23 Q. Were you living with your grandmother at the 23 Q. And so said, why don't you come with me. 24 time you were sentenced to Milton? 24 Did she tell you what the man's name was? 25 A. Yes, I was. 25 A. I don't remember if she told me at that. time. Page 200 Page 202 1 Q. Okay. How long had you been living with your 1 Q. What did she tell you she did? Did you say, 2 grandmother? 2 well, why — why do I want to go there? I mean, she 3 A. I don't 'mow. 3 said, I want you to come to the house to meet this older 4 Q. A year? 4 guy, and he'll pay you some money; right? 5 A. I don't know. I— I don't know. 5 A. Yes. 6 Q. Were you a runaway because you didn't want to 6 Q. Okay. And what did she tell you? Did you 7 testify in your dad's trial? 7 say, well, why? 8 A. I was a runaway because I didn't want to live 8 A. That's what she told me. 9 with my mom. 9 Q. Okay. And what — and did you say, well, why 10 Q. You also didn't want to testify in your dad's 10 is he going to pay me money? 11 trial; did you? 11. A. No. 12 A. Yes, I did. 12 Q. I mean, you were a street smart girl at that 13 Q. Let's go back to Justin Sprague. You had the 13 time. You had run away a number of times; you know, you 14 conversation with — with Justin Sprague? Okay. When 14 had been in shelters; you had done various programs, you 15 is the next time that the issue — any issues involving 15 had, you know, a mother who had significant problems; 16 Mr. Epstein came up — or, or an older man? 16 you had a dad who had significant problems. You 17 A. I don't know. 17 considered yourself pretty street smart at that point; 18 (Whereupon, Ms. Cadwell joined the 18 fair statement? 19 proceedings.) 19 MR. EDWARDS: Object to the form. 20 MR. CRITTON: This is Jessica Cadwell. She's 20 THE WITNESS: At that point I thought that 23. my paralegal. 21 she was going to pay me for going with her. 22 THE WITNESS: I guess not until came 22 BY MR. CRITTON: 23 over to ask me if I would go with her. 23 Q. Did she tell you — 24 BY MR. CRITTON: 24 A. I didn't she didn't tell me she was going 25 Q. How much time passed? 25 to take me to meet somebody. She didn't tell me all of 19 (Pages 199 to 202) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772.1552) Electronically signed by Pamela Sullivan (S01-333-772-1552) 4f15158d4c22-4c50-13036-e423618e2M5 EFTA00723123 Page 203 Page 205 1 that. 1 Q. And what did you talk about on the way over 2 Q. Okay. What did she tell you? She just 2 there? 3 said - 3 A. I don't 'mow. 4 A. Go with me, and you'll get this money. 4 Q. What did you wear? 5 Q And how much did she promise you? 5 A. 1 don't remember. 6 A. $200. 6 Q. All right. You got to the house. You went 7 Q. Okay. And did you say, okay, what do I 7 over to the house. Do you remember what the address 8 get what do I have to do for $200, why is somebody 8 was? 9 going to give me 200 was she going to give you the 9 A. No. 10 money, or was somebody else supposed to give you the 10 Q. Do you remember what the house looked like? 11 money? 11 A. 1— yes. 12 A. I don't know. She just said, go with me, and 12 Q. What did it look like from the outside? 13 you'll get the money. That's it. 13 A. It was a big, pink house. 14 Q. And did she tell you what she had to do? 14 Q. Big, pink house. All right. 15 A. No. 15 And as you got there, the cab let you off? 16 Q. What you were supposed to do? 16 A. Yes. 17 A. No. 17 Q. Did you pay the cab, or did In pay the cab? 18 Q. You just thought, I go with her, I go over to 18 A. No. After we walked inside, somebody else 19 this person's house, and I get 200 bucks? 19 went outside and paid the cab. 20 A. Yes. 20 Q. And did you — when you went inside, who did 21 Q. And you didn't know who was going to give you 21 you neat? A man? A woman? 22 the 200 bucks; correct? 22 A. A woman. 23 A. I thought that S was going to give it to 23 Q. Okay. And where did you go where did you 24 me. 24 enter the house from? 25 Q. And how did you get well, and did she tell 25 A. The kitchen. Page 204 Page 206 1 you how many — did you say, what do you do when you go 1 Q. And what did the kitchen look like — well, 2 over to this house? 2 let me strike that. 3 A. Did I ask her that? 3 Is there a — is there an entrance to the 4 Q. Right 4 kitchen? 5 A. No. 5 A. Yes. 6 Q. Say, where's the house? 6 Q. Is that around where, in relationship to the 7 A. No. 7 house? 8 Q. Did you., are you getting --what do you 8 A. The side of the house on the — 9 get money for, ? 9 Q. Did you ever — oh, sorry. 10 A. No, I didn't. 10 A. It was like right — n toff the driveway. 11 Q. Was anybody else present when she -- 11 like on the side of the house. And it was a, like, 12 A. No. 12 whole glass door, like it had some white around. 13 Q. Was that the — and when she told you that, 13 Q. Olcay. And I think it's your testimony that 14 is this the first time she had ever asked you? 14 you don't remember what you were wearing? 15 A. Yes. 15 A. I was wearing some pants, probably, and a 16 Q. So without asking any questions, you 16 shirt. I don't know. 17 baskally said, okay, I'll go to the house, and I get 17 Q. But you don't remember whether it was long 18 $200 from you? 18 pants or short pants? 19 A. Yes. 19 A. It was long pants. 20 Q. Did they tell you where the house was? 20 Q. Okay. Do you remember the colon? 21 A. No. 21 A. Jeans. 22 Q. How did you get there the first time? 22 Q All right And the top, what kind of top did 23 A. Cab. 23 you have on? 24 Q. What cab? 24 A. I don't know. I had Sponge Bob socks on. 25 A. Yellow Cab. 25 Q. You're sure? 20 (Pages 203 to 206) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4f15158d-6c22.4c50-6036-e423618c2fb5 EFTA00723124 Page 207 Page 209 1 A. Yeah. A. There were stairs behind the door in the 2 Q. Did you have shoes? 2 kitchen. And then we walked up to the — up the stairs 3 A. Yeah. 3 and through a hallway, where there were pictures like on 4 Q. Whet kind of shoes? 4 the walls of lilce bodies. S A. I don't la,rau bet 5 Then we walked through, I guess, what would 6 Q. What did /a have on? 6 be Jeffrey Epstein's bedroom and into the smaller room, 7 A. I don't know. 7 whore there was like a shower and a steam room and a 8 Q. So the door opens, and did you say it was you 8 massage table and a small couch. 9 were greeted by a man or a woman? 9 Q. Okay. Let me stop you for just a minute. 10 A. A woman. 10 The blond-headedga as you were walking 11 Q. And did she tell you what her name was? 11 into the kitchen, says to a, you can go upstairs? 12 A. I don't remember. 12 A. Yes. 13 Q. Did you ever see her again? 13 Q. All right. And did you say to is, whoa? 14 A. Yes. 14 Why didn't you just say, it's okay, wait down here? 15 Q. Did she ever introduce her — introduce 15 MR.. EDWARDS: Font 16 herself, or did you ever come to learn her name? 16 THE WITNESS: I don't know. She -- she son 17 A. The first time that I went there, I believe I 17 of Ifire waved her hand at me l0re — 18 had met a blond woman. And I don't think she told me le BY MR. CRITTON: 19 her name at that point, but later I learned her name was 19 Q. 'sahe? 20 Sarah. And after I started to go back to 20 A. 21 Jeff Epstein's house by myself, I met a woman named 21 Lille come on, you know, waved her hand at me. 22 who i saw often there. • 22 So I just followed her. 23 Q. Okay. And Sarah was a blond-headed girl? 23 Q. Why didn't you call over to the side and 24 A. Yes. 24 say, hey, you need to tell me a little bit more. What's 25 Q. How about i describe -- Sarah, how — in 25 going on? Page 208 Page 210 1 fact, describe fm- me. 1 MR EDWARDS: Form. 2 A. She's very thin, with brown hair, and she had 2 THE WITNESS: I didn't do that at first, but 3 a thick accent. 3 when we got into the reran with him -- 4 Q. Again, first time, so it was the girl that 4 BY MR. CRITTON: 5 you ultimately identified as Sarah? 5 Q. That's — i want to stay -- I want to stay 6 A- Yes. 6 downstairs for a minute, before you ever enter the 7 Q. And you both came into the kitchen area? 7 stairway. Okay? 8 A. Yes. 8 When the blond-headed lady said, okay, 9 Q. And describe the kitchen for me. 9 , okay, you can go upstairs, why didn't you 10 A. . It was like white tile with — with like 10 call aside and say, hey, wait a minute, I need to 11 wood, but it was like really light colored. 11 understand a little bit rgifigiwhat's going on here? 12 Q. Wood on the walls? Wood on the floor? Wood 12 Because you're saying In never told you anything, just 13 on the cabinets? What are you talking about, wood 13 that you were going to get 200 bucks; right? 14 where? 14 A. Yes. 15 A. On the cabinets, I believe it was. 15 Q. Okay. S didn't you say is, wait a 16 Q. Did you sit in the kitchen at all? 16 minute, whiria- what's gags& here? And you, A. Not really. I only saw the kitchen for like 17 you know, been a runaway, been on -- i don't 17 IME PM 18 a second and — 18 want to say on the street, but you had certainly been a 19 Q. What did the blond-headed — did the 19 runaway and had a lot of experiences in your life for 20 blond-headed woman say ant? 20 a -- for your age — 21 A. She just, I guess, told ME. like to go 21 MR. EDWARDS: Object to the form. 22 upstairs or whatever. And there was like a door in the 22 BY MR. aurroN: 23 kitchen, I think it was, and there were some stairs in 23 Q. —right? 24 there. 24 So why didn't you say, M., come on over 25 25 here? Q. II soni? 21 (Pages 207 to 210) (5 61) 8 32 -7 5 0 0 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) 4f1S158d-6c22-4c50-b036-e423618c2fb5 Electronically signed by Pamela Sullivan (501333.772-1552) EFTA00723125 Page 211 Page 213 1 A- I don't know. 1 A. Nude bodies. 2 Q. You just didn't? 2 Q. All right. And all appeared to be adults? 3 A. I just didn't. 3 A. They were like little pieces of lice a 4 Q. But you could have? 4 person's body. I couldn't — I don't blow. 5 MR. EDWARDS: Object to the form. Q. Okay. So you couldn't tell -- they could 6 BY MR. CRITTON: 6 have been whatever age? I mean, they didn't — but they 7 Q. Right? 7 appeared to be adult peoples bodies in pieces — 8 A. Sure. 8 MR. EDWARDS: Object to the form. 9 Q. Okay. And you could have chosen not to go 9 BY MR. CRITTON: 10 and never have gotten in the cab with... that day; 10 Q. — is that a fair statement? 11 true? 11 A. I don't know. 12 A. Yeah. 12 Q. Okay. When you say they were adult pieces of 13 Q. So you go up the -- you said you went through 13 bodies, you mean it was — it was almost like a — like 14 a door, and then a stairway; correct? 14 a -- like a crossword puzzle — 15 A. Yeah. Mt pretty sure that there was a door. 15 MR. EDWARDS: Object to the form. 16 Q. In order to get into the stairway? 16 BY MR. CRITTON: 17 A. Yes. And we walked throw the hallway - 17 Q. — the pieces? Describe - 18 Q. Let me ask you this — oh, sorry. You 18 A. They were like men's and women's bodies. And 19 know, I just want to — I want to work my way up. 19 I don't know if somebody was lace old or young in those 20 Did the door to the stairway open toward the 20 pictures. I don't know. 21 stairs, or did it open into the kitchen? 21 Q. But they appeared to be something that you — 22 A. I don't teiminber. 22 clearly, where they were art — art photographs? 23 Q. Were the stairs carpeted, wood, or some other 23 MR. EDWARDS: Object to the form 24 surface? 24 BY MR. CRITTON: 25 A. pretty sure they were carpeted. 25 Q. That is, somebody had worked with those Page 212 Page 214 Q. Did the — did the stairway have a rail, or 1 pictures to create a certain image? 2 was the stairway built into the walls? And when I say 2 A. 1don't know. 3 that, you know there was a stairway between two walls. 3 Q. Pardon? 4 A. There was walls next to it. 4 A. I don't know. 5 Q. Were - were there any types of photographs 5 Q. Well, I asked earlier whether you thought 6 or art on the walls? 6 they were art photographs, and you said, yeah? 7 A. Yes, there were pictures of people's bodies. 7 A. Well, there were art books. 8 Q. Okay. AM that's what I was trying to figure 8 Q. You mean, where, on the stairway? 9 out where you said bodies, when you said... 9 A. There — there was like a table with some 10 Have you ever seen art books before? 10 books on it. They looked like art books or something to 11 A. Yes. 11 me. 12 Q. Okay. Is that what you're talking about; 12 Q. The photographs that you saw of the bodies, 13 there were like art pictures or photographs of people's 13 describe the size. How many - how many photographs did 14 bodies in different positions? 14 you see? And this is in the stairway? 15 A. Yes. Yes. 15 MR. EDWARDS: Object to the form. 16 Q. And the pictures of the — of people's 16 THE WITNESS: No, this is after the stairway. 17 bodies, what did they look like? 17 BY MR. CRITTON: 18 A. They were like gray and black and whitish. 18 Q. Okay. Just a minute ago I asked you whether 19 Q. And of -- of the bodies, were they clothed 19 there are any photographs or any pictures as you walked 20 bodies, were they partially clothed bodies, were they — 20 up the stairway, and you said, the bodies, that's where 21 A. They vet te — 21 the bodies what. I thought that's what you said. 22 Q. — completely clothed bodies? 22 So let me ask it again so I — 23 A. They were nude. 23 MR. EDWARDS: Form. 24 Q. Okay. The pictures were completely of nude 24 BY MR. CRITTON: 25 bodies? 25 Q. Were the photographs -- or the,. say, 4...•••• 22 (Pages 211 to 214) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4116158dec22-4c60-b0364423618c21b5 EFTA00723126 Page 217 Page 215 1 Q. Is that his bedroom? 1 white, black and grayish photographs that you saw, were they on the stairway, or were they at the top of the 2 A. To the left you would see his bed — like a 2 stairs? 3 bed. I don't know if it was his bed. And in front of 3 4 you, you would see — I think it was like a bookshelf 4 A. They were at the top of the stairs. 5 Q. All right. So it would be a coned 5 And then to the left of the bookshelf I think there were statement that you didn't see any type of art, 6 doors, or they may have been on the side of the bed. I 6 7 can't remember exactly. 7 photographs on the stairway on either side of the wall 8 Q. Now, before you got into his room, when you 8 as you walked up; true? A. I cannot recall -- 9 get to the top of the stairs you make a right turn; 9 Q. Okay. 10 correct? 10 A. -- at this -- 11 A. Yes. 11 12 Q. Were there any roars on the left or the right 12 Q. As you sit here today, would it be a correct 13 side before you get to the threshold of his bedroom? 13 statement that the only photographs or art that you 14 A. I don't know. 14 recall being on the walls was at the top of the 15 Q. Okay. How many pictures of bodies, art 15 stairway, and not on the walls on the stairway leading up to the top; is that correct? 16 pictures, did you see at the top of the stairs? 16 17 MR. EDWARDS: Object to the form. 17 A. I don't remember. THE VaTNESS: 1 absolutely timw-mber them 18 Q. Was there one, or two, or three, or you don't 18 19 have any recollection? 19 being at the top. I don't remember whether there 20 A. I don't remember exactly how many there were. 20 were anything on the walls in the stairway. 21 I can remember specifically like two of them. 21 BY MR. CRITTON: Q. On the photographs or of the art that you saw 22 Q. Describe the first picture that you can 22 on the walls when you got to the top of the stairs, when 23 recall. Tell me exactly what it looked like. 23 did you go to get to 24 A. It looked like this portion of a woman's 24 you got to the top of the stairs, t was his bedroo m, did you 25 body. 25 Mr. Epstein's, what you though Page 218 Page 216 1 Q. The hip? You're pointing to the -- your 1 go to the right or to the left? A. To the right. 2 right hip area? 2 Q. And did you have to pass any doors before you 3 A. Yes. 3 got into his room? 4 Q. Okay. 4 5 A. Like - 5 A. Yes. 6 Q. Okay. How many doors were -- were the doors 6 Q. And that's all you could see? on the lAior the right? 7 A. — the side, yes. 7 8 A. a -a pretty sure the doors were like on Q. All right. So that's - 9 the far right side. 9 A. Air) — 10 Q. The far right side. So you came up the 10 Q. MI sorry. That was the first picture? 11 A. Yes. 11 stairway. When you hit the top of the stairway, you made a right turn, and then there were two -- there was 12 Q. And — and it was only basically the woman's 12 13 one or two doors that you passed before you got into 13 hip from, basically, I would say, waist down to her Mr. Epstein's bedroom? 14 thigh, but you saw only a side view; correct? 14 15 A. There's one door you pass, or you just walk 15 A. That's one that I can specifically remember. in or whatever. I mean, I don't I don't remember if 16 Q. The second picture that you saw, what did 16 17 we had to go through one or two doors, but it was a 17 that depict? single door. And when we walked into his bedroom, like, 18 A. A man's body. 18 if you were facing forward, like at his bedroom door, as 19 Q. Okay. And what portions of the man's body 19 20 you were looking — 20 did you see? Q. As you're just stepping through the 21 A. The chest area. 21 22 threshold? 22 Q. The chest? A. Yes. 23 A. Yes. 23 24 Q. And that was the only part that was depicted 24 Q. Okay. You're looking straight ahead? A. Ycs. 25 in the photograph -- 25 23 (Pages 215 to 218) (561) 832-7506 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (501-333-772-1652) 4f15158d-6c22-4c50-b036-e423618c2fb5 Electronically signed by Pamela Sullivan (601.333.772-1552) EFTA00723127 Page 219 Page 221 1 A. Yeah. 1 A. Yes. 2 Q. — of the — the art that was on the wall; 2 Q. Okay. And back to my question was, is: As 3 correct? 3 far as you can recall, the only two photographs of the 4 A. Yes. 4 artwork that you saw were the two that you described to 5 Q. Okay. And moving fast forward, on all the 5 us, during the entire time you ever went to 6 other occasions that you went to Mr. Epstein's home 6 Mr. Epstein's house, at least for the back staircase? 7 and I think you said earlier that you at least told the 7 A. Those are two things that I can specifically 8 FBI it was approximately 20 — did that artwork on the 8 remember. There were other things. I just can't 9 walls ever change, that is from the bottom of the stairs 9 remember specifically what they were. 10 up until you went through the threshold of his room -- 10 Q. All right. So you get to the top of the 11 A. I don't know. 11 stairs the first time, and you're walking towards what 12 Q. — or is it always the same? 12 afound out later was his bedroom. Did you ever grab 13 A. I don't know. There were like three 13 M. or say, M, come here, I need to talk to you, 14 different ways to get into that room. 14 you know, what's going on here, I — you need to explain 15 Q. Okay. And did you always come up the 15 this to me? Did you ever do tat? 16 stairway in the kitchen? 16 A. No. 17 A. No. 17 Q. Okay. When you went into his bedroom, and 18 Q. Okay. Did you come up a different way — 18 then you went — I think you said you went around to the 19 other ways in the house? 19 left? 20 A. Yes. 20 A. Uh-huh. 21 Q. Which other ways did you come up in the 21 Q. Is that correct? 22 house? 22 A. Yes. 23 A. I had gone up through the — I guess what 23 Q Okay. And then you went -- went into an area 24 would be like that main staircase, which was like after 24 that you said hada — like a steam and a shower and a 25 you walk through the kitchen and go to your right, I 25 massage table and a small couch. Was the — the blond Page 220 Page 222 1 don't know what room it was in, but you would see the 1 lady there — 2 staircase. And it had like clear — like on the rail it 2 A. No. 3 had like clear things. I don't — I don't remember like 3 Q. whtimu later described? And so it was 4 if it was all clear, but I remember — 4 just you and M.? 5 Q. Are you talking about rails? 5 A. Yes. 6 A. Yes. 6 Okay. Did you then pull M. aside and say, 7 Q. All right. And then you —and so you -- 7 M., what's going on here? You need to tell me. You 8 your testimony, at least, you came up the kitchen 8 know, you said I was going to get 200 bucks. What 9 stairs, you came up the — what you described as the 9 what's going on? 10 main staircase. Any other way that you ever got into 10 MR. EDWARDS: Object to the form. 11 the bedroom? 11 THE WITNESS: She told me that I was going to 12 A. Yes, there was there was like a balcony on 12 meet this guy, and Ifice he was really nice and 13 the side. I mean, not exactly sure where it was, 13 stuff lice that. And she told me like that — I 14 but it was like — like in the area where the pool was. 14 don't know; she just pretty much told me that he 15 And like the balconies, I guess, there was a staircase 15 was a nice guy. So I just like sat in there with 16 where you go up. And there's a — I believe there was 16 her, and then -- 17 like a small balcony. And then there was one door on 17 BY MR. CRITION: 18 each side of where there would — there was like a sink 18 Q. Did she sit down on the couch? 19 and like a big counter, where he had a lot of stuff on 19 A. Yes. 20 that counter. And — 20 Q. Okay. And did you just go, well, wait a 21 Q. I don't want to really to get into the — 21 minute,. in here,. going to meet a nice guy; who's 22 that's fine. I just Want — SO you carne up three 22 paying me the 200 bucks? Did you say that to her? 23 different ways is what you're telling me? 23 A. No. 24 A. Yes. Yes. 24 Q. Did you say, why am I getting 5200 to just 25 Q. That's it? 25 sit here and meet a nice guy? 24 (Pages 219 to 222) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (601-333-772-1552) atlas sed-Se22.4450.bo384423818e2tbs EFTA00723128 Page 223 Page 225 1 A. No. 1 Q. Very friendly? 2 Q. Okay. Did you say, I think this is odd, you 2 A. Yes. 3 know, weird; I think I want to get out of here? 3 Q. Okay. And she seemed to be happy to see him? 4 A. No. 4 A. Yes. 5 Q. Okay. You could have, though; couldn't you? 5 Q. Okay. And did — from everything that she 6 A. I don't know. 6 had told you about Mr. Epstein, she said he's a nice 7 Q. Well, nobody -- 7 guy, he's very polite; right? 8 A. I probably could not have found myself out of 8 A. Yes. 9 that house at that time. 9 Q. Okay. And did she tell you, she said, look, 10 Q. No, but you could have said., I don't 10 you — you — you can feel way safe around him? 11 want to stay here, let's — lees go. You could have 11 A. No. 12 said that; couldn't you? 12 Q. Okay. Did she tell you don't worry? 13 A. I guess. 13 A. Those were not words that she used, no. 14 Q. All right. And you made a voluntary decision 14 Q. Well, what words did she use? She said he's 15 from the time that.. said, do you want to go with me, 15 a nice guy? 16 up until the time you were in that room? It was all 16 A. Yeah. 17 voluntary. You knew — you knew that had made a — 17 Q. That you'll like him? IS or you have made decision to go with. to get 200 18 A. No. She just said that was a nice guy. 19 bucks, and there you were in the room, you and.; 19 Q. Okay. Did you say, meeting a nice 20 correct? 20 guy, so what's going on 21 A. Yes. 21 A. No, I didn't. 22 Q. All right. What happened next? 22 Q. All right. So she goes up to Jeffrey. And 23 A. Jeffrey walked in and -- 23 did — do you remember, did she give him a hug? 24 Q. But you didn't know he was Jeffrey then? 24 A. No, I don't think so. 25 A. No, I did not 25 Q. She just went up, and she looked happy? Page 224 Page 226 Q. A man walked in? 1 A. I don't know — I don't know if she gave him A. A man walked in. 2 a hug or not I don't retnember. Q. Describe him for me. 3 Q. All right. Did she — but she appeared to be A. Had gray hair. He had sweat pants and Illce a 4 very comfortable with him as she — because she -- 5 T-shirt on. I don't know. He was old; he was an older 5 MR. EDWARDS: Objection. Asked and answered. man. And - 6 BY MR. CRITTON: 7 Q. What did he say to you? 7 Q. Let me strike that. 8 A. He said — 8 Did she appear to be comfortable around him 9 Q. Well, in fact, let me — let me strike that 9 when she greeted him? 10 Who did he speak with? He walked in. You 10 MR. EDWARDS: Same objection. 11 described what he was wearing. 11 THE WITNESS: I don't know. 12 A. He talked to.. AndM. said, you know, 12 BY MR. CRITTON: 13 this is my friend, Jane Doe. And he shook my hand. He 13 Q. Well, did she appear to be uncomfortable? 14 said that his name was Jeffrey, and then — I don't 14 A. No. 15 know. I don't know what else he said, but he started to 15 Q. Okay. Well,I mean, you -- you would have 16 walk out of the room. And as he was walking out of the 16 sensed if she felt — you didn't see any fear in her 17 room, he said that we needed to take our clothes off. 17 eyes or any anxiety; did you -- 18 Q. You say he walked to.. Did he have a 18 MR. EDWARDS: Objection to the form. 19 private conversation withM.? 19 BY MR. CRITTON: 20 A. Yes. 20 Q. -- in either ha mannerisms or her face? 21 Q. Okay. And when he walked into the wont 21 MR. EDWARDS: Form. 22 dressed as he did, did she go up to him at all? 22 THE WITNESS: No. 23 A. Yes. 23 BY MR. CRITTON: 24 Q. Did she give him a hug? 24 Q. Okay. And she certainly hadn't told you 25 A. I don't think so. 25 anything that would cause you to be fearful or scared or 25 (Pages 223 to 226) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (504333-7724552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4f15158d-6c22-4c50-b036-e423618c2114 EFTA00723129 Page 22.: Page 229 1 anxious; true? 1 Q. Okay. Had you ever seen her or observed her 2 A. I guess not. 2 in any kind of sexual activity with a man before? 3 Q. All right. But you were anxious, because you 3 A. No. 4 didn't know what was at least, based on your 4 Q. Were you aware thatM. was sexually active 5 testimony, because you weren't sure what was going to 5 at that point? happen happen- 6 A. No. 6 7 A. Yes. 7 Q. Well, she was living with Justin Sprague. 8 Q. — at least your testimony? I don't know 8 What did you think was going on? 9 what — whetherM. will say that, but that's your 9 MR. EDWARDS: Object to the form. 10 testimony; right? 10 BY MR. CRITION: 11 MR. EDWARDS: Object to the form. 11 Q. When the two were living together, did you 12 THE WITNESS: Yes. 12 think that was a platonic — if I say — ifl use the 13 BY MR. CRITIDN: 13 word platonic, do you know what that means? 14 Q. Now, so as he leaves, you said he said what? 14 A. Yes, I do. 15 A. He said that we need to take our clothes off. 15 Q. Okay. Platonic means probably no sexual 16 Q. Okay. And then did he leave the room? 16 activity. 17 A. Yes. 17 A. I know what it means. 18 Q. Where did he go? 18 Q. Okay. You understood, or at least you 19 A. I don't know. 19 surmised that Justin Sprague and.., who were living 20 Q. He just left? 20 in the trailer together, were sexually active; true? 21 A. Yes. 21 MR. EDWARDS: Object to the form. 22 Q. Okay. And did you turn to.. and say 22 BY MR. CRITTON: 23 some hi 23 Q. It's not rocket science. You understood that 24 A. kind of turned to me and like, 'don't 24 to be a fact didn't you? 25 know, she kind of just told me that I should do it. 25 MR. EDWARDS: Object to the Tom. Page 228 Page 230 1 Q. Was.. taking her clothes off/ 1 THE WITNESS: I didn't I don't 'mow. 2 A. Yes. 2 'BY MR. CRITI'ON: 3 Q. Okay. And what and you — I think you 3 Q. Come on. Ms. Jane Doe, are saying that 4 told me you don't remember what had on? 4 you know — you were aware that.. and Justin Sprague 5 A. No. 5 were living together in a walla, and had been for a 6 7 Q. Did. - off in your presence? and what clothes did.. take 6 7 number of months, and you don't believe they had any type of sexual relationship between one another, is that 8 A. All of them. 8 what you're telling the members of the jury? 9 Q. How many times had you seen.. naked before 9 MR. EDWARDS: Object to the fern'. 10 this first time that you had been to Mr. Epstein's home? 10 THE WITNESS:. not saying that I don't 11 A. 1 don't know. We were friends fora long 11 believe that. • saying that I do not know that. 12 time. We changed in front of each other. 12 BY MR. CRITTON: 13 Q. Okay. Because you were kid friends 13 Q. So now we're back at Mr. Epstein's home. 14 together - 14 starts taking off her clothes. Mr. Epstein had 15 A. Yeah. 15 said, you can take off your clothes. What did you 16 Q. — so you probably had seen each other's 16 say to M.? 17 bodies at some point when you were changing clothes or 17 A. I didn't say anything to her. She just 18 running from the shower; right? 18 turned to me and told me that I should do it. 19 A. Yes. 19 Q. And you — or at least by what you've told us 20 Q. Okay. Had you ever seen naked in the 20 so far, is you that ou were going to go over, meet 21 presence of another person? And I don't mean another, 21 an older man, and M. was going to pay you 200 bucks; 22 you know, girls were all, you know, after PE or sports 22 right? 23 together or something like that. Had you ever seen her 23 A. Yes. 24 in the presence Ma naked man before? 24 Q. Okay. So when he says, take off your 25 A. No. 25 clothes, and she says — she - she,.., starts taking 26 (Pages 227 to 230) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-75O6 Electronically signed by Pamela Sullivan (501433-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 41615846O24c504303644236184fb8 EFTA00723130 Page 231 Page 233 1 off her clothes, does like the proverbial red flag go up 1 BY MFt. CRITTON: 2 to or a light come on to say, well, wait a minute, 2 Q. All right. And you had been through the 3 III, what's going on here? 3 whole — a number of depositions and court proceedings 4 A. I didn't say anything to her. 4 involving your lethal correct? 5 Q. Why not? S MR. EDWARDS: Object to the form. 6 A. I don't know why not. 6 THE WITNESS: Yes. 7 Q. Okay. Jane Doe, prior to this first occasion 7 BY MR. CRITTON: 8 that you had been in Mr. Epstein's house, on how many 8 Q. All right. Did you take off all of your 9 occasions had you taken your clothes off in the presence 9 clothes? 10 of a man who was not -- or a male who was not a parent? 10 A. Yes, I did. 11 A. Excuse me? 11 Q. And now my question again is, is: Prior to 12 Q. O Well, let me — let me ask: Did 12 that occasion at Mr. Epstein's house, had you ever 13 you as On's taking all of her clothes off, did you 13 completely taken off your clothes for — in the presence 14 then take all of your clothes off? 14 of a male who was not a family member? 15 A. Yeah, when she told me that I should, yes, I 15 A. No. 16 did. 16 Q. Were you sexually active prior to the time 17 Q Well, she could tell you to jump off the 17 that you first went to Mr. Epstein's home? 18 building, but it doesn't mean — I mean, you're your own 18 A. No. 19 person. You already told me that; right? 19 Q. Had you ever had any type of sexual activity 20 MR. EDWARDS: Object to the form. 20 with a male — 21 THE WITNESS: Yes. 21 MR. EDWARDS: Object to the form. 22 BY MR. CRITTON: 22 BY MR. CRITTON: 23 Q. And you were your own person back in 2003; 23 Q. — prior to being at Mr. Epstein's home? 24 weren't you? 24 A. No. 25 MR. EDWARDS: Object to the form. 25 Q. Had you ever - and let me define sexual Page 232 Page 234 1 THE WITNESS: Yes. 1 activity. 2 BY MR. CRITTON: 2 Had you ever been with a male, where you 3 Q. And you knew the difference between, in your 3 placed your hand on his penis? 4 mind, at least, right and wrong; correct? 4 A. No. 5 A. No, I didn't 5 Q Had a male ever touched your breast or — 6 Q. You had found a way to run away from home and 6 your breast at any time, prior to the time you went to 7 go live with various people and to survive; correct — 7 Mr. Epstein's? 8 MR. EDWARDS: Object to the form. 8 A. No. 9 BY MR. CRITTON: 9 Q. Had you ever — had a male ever touched any 10 Q — prior to ever meeting Mr. Epstein? 10 part of your genitalia — 11 A. Yeah. 11 A. No. 12 Q. Right. And you had been through some rather 12 Q. — prior to ever being at Mr. Epstein's? 13 significant psychological and emotional events in your 13 A. No. 14 life prior to ever meeting Mr. Epstein — 14 Q. Had you ever given a male oral sex at anytime 15 A. Yes. 15 prior to being at Mr. Epstein's? 16 Q. — including not only the murder of Joey, but 16 A. No. 17 as well what you learned to be domestic abuse between 17 Q. Had you ever had sexual intercourse with a 18 your mother and your real father, Mr. Dial; correct? 18 male prior to your first time you ever went to 19 MR. EDWARDS: Object to the form. 19 Mr. Epstein's? 20 THE WITNESS: I never witnessed any abuse. 20 A. No. 21 BY MR_ CRITTON: 21 Q. Had you ever had any type of anal sex prior 22 Q. I know that, but you were aware that it 22 to the time you first went to Mr. Epstein's? 23 existed, because your heard about it; true? 23 A. NO. 24 MR. EDWARDS: Object to the form. 24 Q And ifs your testimony — well, let me ask 25 THE WITNESS: I was told, yes. 25 you this: Had you ever disrobed in any state, just 27 (Pages 231 to 234) (5 61) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772-1552) 4115158d-6c22-4c50-b036-e423618c21b5 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00723131 Page 235 Page 237 1 taking your top off so that you would have exposed your 1. Q. Sure, you did. 2 breasts to a male -- 2 A. No. 3 • A. No. 3 MIL EDWARDS: Object to the form. 4 Q. — other -- other than a family member, prior 4 BY MR. CIU17O1.1: 5 to corning to Mister — prior to going to Mr. Epstein's 5 Q. could have said to I. at that point in 6 home on the first occasion? 6 auttI want to go borne. time, Mt 7 A. No. 7 MR. EDWARDS: Object to the form. 8 Q. So when ■ says to you -- or Mr. Epstein 8 BY MR. CRITTON: 9 says, take off your clothes, he leaves the 9 Q. nue? 10 room, why didn't you say tol: that point, what is 10 A. The point is that I didn't know that then. 11 going on here? 11 Q. Inc. - 12 MR. EDWARDS: Object to the form. 12 A. Yeah, now, that's true; I know that now. But 13 THE WITNESS: I don't know. I didn't — I 13 then? No, I didn't Imovat 14 didn't really know what else to do or say. I just 14 Q. Did you say to la, MI, I don't want to 15 thought that I had to do it. I didn't know I had a 15 stay here? 16 choice. 16 A. No. 17 BY MR. CRITTON: 17 Q. Was I. your friend? 18 Q. No -- no one was forcing you to do anything 18 A. Yes. 19 at that point; were they? 19 Q. She was a good friend? 20 MR. EDWARDS: Form. 20 A. Yes. 21 THE WITNESS: No, but I didn't }mow that 21 Q. All right Did you say, I., why did you 22 there was a choice there, that I could say, no. I 22 bring me here? I don't want to do that? 23 didn't ;mow that at that time. 23 A. No, I didn't. 24 BY MR. CRITTON: 24 Q. But you could have? 25 Q. Sure you did, because you knew that all you 25 MR. EDWARDS: Object to the form. Page 236 Page 238 1 had to -- 1 THE WITNESS: I didn't know that. 2 hfft- EDWARDS: Objection. Argumentative. 2 BY MR. CRITTON: 3 MR. CRITTON: I need to ask the question 3 Q. You could have, whether you — I understand 4 fast. 4 that you're saying you — you didn't know you could. 5 MR. EDWARDS: Well, you're Just telling her a 5 But I — my question's, is: You could have done — you 6 comment and arguing with her. Ask a question. 6 had a chgigatligyou could have said, I don't want to 7 MR. CRITTON: Want me to read back Arod and 7 WS, anot taking ow clothes off. Sony. 8 Alessie's (phonetic) deposition? 8 IN out of here. 9 MR. EDWARDS: Sure. Into this record? 9 MR. EDWARDS: Object to the form 10 MR. CRITTON: Na 10 BY MR. CRITTON: 13. MR. EDWARDS: Yes, please. 11 Q. You could have chosen that; true? 12 MR. CRITTON: You 'mow your questions or 12 k That's true, but I didn't know that at that 13 let me say your statements... Well, let me go back 13 time. 14 to my question. 14 _Q. Did you ten I don't want to do this, 15 BY MR. CRITTON: 15 16 Q. Ma'am, you had— you had a choice at the 16 MR. EDWARDS: Same objection, form 17 time Mr. Epstein left the room, and he had said, okay, 17 THE WITNESS: I didn't know that I had a 18 take your clothes off, or whatever you say he ssaw 18 choice at that time. 19 you and You could say, this isn't forme, MI, 19 BY MR. CRITTON: 20 what's going on. You could have done that, and you 20 Q. Okay. 21 chose not to; true? 21 A. Now I know that I could have said, no, and I 22 A. At this point I know, yeah, I could have done 22 could have left. But when I was there at that time and 23 that. 23 place, I had no idea that I could have said, you know 24 Q. At that point you maid have? 24 what, I -rjarant to leave. 25 A. i did not know that. 25 Q. M. takes off her clothes. Did you wait —warreer=ersaar.. 28 (Pages 235 to 238) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772.1552) 4415168d43c224660403414423818c2tb5 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00723132 Page 239 Page 241 1 till she was fully disrobed before you took your clothes 1 2 off? 2 BY MR. CRITTON: 3 3 Q. You need to answer my question. asking A. No. 4 Q Did you say, hey, can I leave on my 4 you to assume — 5 underwear, my bra and my panties? Did you have a bra? S MR. EDWARDS: Object to the form. 6 A. Yes. 6 BY MR. CRITTON: 7 Q. Okay. Did you say, just feel more 7 Q. - Mate. has testified under oath that 8 comfortable if I didn't take my clothes off? 8 she told you that you didn't have to do anything you 9 A. No. 9 didn't want to do. 10 Q Okay. Didn't she tell you, look, you don't 10 A. She did not tell me that. 11 have to do anything you don't want to do? 11 Q. All right. So if she's testified that that's 12 A. No, she did not. 12 what she did tell you, that's a lie; correct? 13 So if she says that, she's lying? She -- if 13 MR. EDWARDS: The witness has answered the 14 says, I told Jane Doe, as I told all the other 14 question. Object to the form, again. 15 girls that I took, is if they didn't want to do 15 THE WITNESS: She did not tell me that 16 something or if they felt uncomfortable, they didn't 16 BY MR. CRITTON: 17 have to do that? 17 Q. So if she's testified — if she testifies or 18 MR. EDWARDS: Object to the form. 18 has testified that she said that, that would be a lie; 19 BY MR. CRITTON: 19 is that correct? 20 Q. She told you that; didn't she? 20 MR. EDWARDS: Object to the form. 21 A. No. 21 THE WITNESS: Yes. 22 Q. So if she — ill. testifies that that's 22 BY MR. CRITTON: 23 what she told you, you're sayingli. lied to me — 23 Q All right. Take your clothes off;.. now 24 MR. EDWARDS: Object to the form. 24 has her clothes off. What happens next? 25 25 A. Jeffrey walked back in with only a towel on. Page 240 Page 242 1 BY MR.. CRITTON: 1 Q. Like a bath towel? 2 Q. that's a lie; right? 2 A. Yes. 3 MR. EDWARDS: Object to the form. Compound 3 Q. Okay. Around his waist? 4 question. 4 A. Yes. 5 BY MR. CRITTON: 5 Q. All right. And what happens next? 6 Q. Let me reask it so it's clear: If.. has 6 A. He laid down on his belly on the massage 7 testified that she told you that you didn't have to do 7 table, and we tubbed his back and his legs. B anything that you weren't comfortable with doing, your 8 Q. St. . And who told you to do that? 9 testimony would be a liar -- 9 A. M. did. 10 MR. EDWARDS: Object to the form. 10 Q. And didll., when she was out - 11 BY MR. CRITTON: 11 sorry when he was out of the room, did., tell 12 Q. — is that correct? 12 you - did you say, what's -- what are we doing? Now, I 13 A. I just know that.. did not say that tome. 13 got my clothes off. Now, what's next? 14 So if you're tellin me that, then you're a liar. 14 A. No. 15 Q. No. Ife telling you that that's what.. 15 Q. Okay. Did you know you were going to give 16 has testified that she told you — 16 him a massage? 17 A. How do I know that, though? 17 A. No. 18 Q. • asking you to assume it. Ifs what's 18 Q. Okay. Had you ever given a man a massage 19 called a hypothetical question. 19 before? 20 Okay. If. testified, I told Jane Doe 20 A. No. 21 that she didn't have do anything she didn't want to to 21 Q. Given anyone a massage before? 22 at Mr. Epstein's house, if I asked you to assume that as 22 A. No. 23 being true, you would say.. is a liar; correct? 23 Q. Did — so he comes in, he lies down, he still 24 MR. EDWARDS: Object to the form. 24 has his towel on; right? 25 THE WITNESS: M. didn't say that to me. 25 A. Yes. 29 (Pages 239 to 242) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (S01-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772.1552) 4f15158(1-6c22-4c50-b036-e423618c2fb5 EFTA00723133 Page 243 Page 245 1 Q. And he's lying on his stomach? 1 Q. And had you shown Mr. Epstein an ID at any 2 A. Yes. 2 time? 3 Q. And what did.. tell you to do? 3 A. Na 4 A. She just told me to like give him a massage. 4 Q. Did you ever show him an ID? 5 Q. Okay. And how did you know how to give him a 5 A. No. 6 massage? 6 Q. You're sure of that? You didn't have a fake 7 A. I don't know. I just like did what she was 7 ID? 8 doing. 8 A. You think he was !Ding people? No. 9 Q. Okay. Was she standing next to you the Q. • just asking the questions, maam. 10 entire time? 10 What else did you talk about? 11 A. Yes. 11 A. I talked about school and -- I don't know. I 12 Q. And Mr. Epstein was what, was lying face 12 mean, I didn't talk much to him. 13 down? 13 Q Was M. doing most of the talking? 14 A. Yes. 14 A. !guess. 15 Q. And his face was what, pointed down toward 15 Q. Okay. He — if he was looki down or away 16 the floor on the massage table? 16 from you, did you ever try to talk to and say, you 17 A. I don't know -- I don't remember. 17 blow, this is odd, or I don't want to be hue, or let's 18 Q. Okay. Where were his arms? To the side? 18 go? 19 A. I don't know. 19 MR. EDWARDS: Object to the form. 20 Q. Or was his leaning on them, like it was his 20 THE WITNESS: No. 21 head on his arms? 21 BY MR. CRITTON: 22 A. He was laying down, getting a massage. 22 Q. You could have, though, said something to 23 Q. All right. Were his arms at his side, or 23 heel 24 were they over his shoulders? 24 MR. EDWARDS: Object to the form. 25 A. I don't know. 25 Page 244 Page 246 1 Q. How long did this last? 1 BY MR. CRITTON: 2 A. Thirty or so minutes. 2 Q. Right? 3 Q. And so you rubbed where? Where did you and 3 A. Yes. 4 start — were you doing it in tandem, together? 4 Q. Okay. And you could have said, you know, S A. His back and his legs. 5 enough of the massage,'" putting my clothes on, I'll 6 Q. So you rubbed his back and his legs for 6 meet you downstairs? 7 approximately how long? 7 MR. EDWARDS: Object to the form. 8 A. Thirty minutes. 8 BY MR. CRITTON: 9 Q. And at the end of the 30 minutes, did you 9 Q. Right/ 10 both leave? 10 A. Yes, I could have said that. 11 A. No. 11 Q. At the end of 30 minutes, you've now massaged 12 Q. Okay. So you rubbed his back and his legs 12 his back and his legs? 13 for 30 minutes? 13 A. Yes. 14 A. Yes. 14 Q. Oka . What happened next? 15 Q. Did he talk to you at all? 15 A. IMI. said that she was going to go downstairs 16 A. Yes. 16 for a little bit, and she was going to come back. 17 Q. Did you talk to him? 17 Q. Okay. And when -- did she grab her clothes 18 A. Yes. 18 and go? 19 Q. And what did — what did you talk about? Was 19 A. Yes. 20 he talking to M., too? 20 Q. So she — says,. going dovmstairs for 21 A. Yes. 21 a bit. She takes her clothes and leaves? 22 Q. Okay. What did he ask? 22 A. She put her clothes on and left. 23 A. He asked me how old 1 was. 23 Q. Right in front of you? 24 Q. And what did you tell him? 24 A. Yes. 25 A. I told him that I was 15. 25 Q. And what were you doing all this time? 30 (Pages 243 to 246) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (601.333.772.1652) 4P151684-6c22-4450-b036-e423618c2fb5 EFTA00723134 Page 247 Page 249 1 A. I don't know. 1 A. He asked me to squeeze his nipples really 2 Q. Did you say ton., you know, I ready 2 hard. So I did. 3 to go, too? 3 Q. All right. And then what happened? 4 A. No. 4 A. And then he started masturbating, and I 5 Q. Did you say,.., don't leave me? 5 just — I don't know, l ldnd of just tried to like not 6 A. No. 6 look at his face. And I just did whatever he said, and 7 Q. Did you say, I don't want to be left alone? 7 waited until he was done, and left. 8 A. No. 8 Q. I-lad you ever seen a man masturbate before? 9 Q. Did you say, I want to put my clothes back 9 A. No. 10 on, too? 10 Q. Have you seen a man masturbate since? 11 A. No. 11 NM. EDWARDS: Object to the form. 12 Q. You could have done any of those things — 12 THE WITNESS: No. 13 MR. EDWARDS: Object to the form. 13 BY MR. CRITTON: 14 BY MR. CRITTON: 14 Q. Okay. So Mr. Epstein -- Mr. Epstein is the 15 Q. — couldn't you? 15 only person whom you've ever seen masturbate? 16 A. I didn't ;mow that at the time. 16 A. Yes. 17 Q. Nobody was preventing you from putting your 17 Q. Okay. Have you ever been involved — have 18 clothes on or leaving that room; true? 18 you ever given a man — have you manually, with your 19 A. No, but he should have given me that option. 19 hand, given — had a man -- masturbated a man to 20 Q. Answer my question: No one prevented 20 ejaculation? 21 from putting your clothes on and leaving with M.; did 21 A. No. 22 they? 22 Q. Had you ever seen a man's penis before? 23 MR. EDWARDS: Object to the form. 23 A. Before -- 24 THE WITNESS: No. 24 Q. Before that first time you were at 25 25 Mr. Epstein's. Page 248 Page 250 1 BY MR. CRITTON: 1 A. No. 2 Q. No one forced you to stay in the room with 2 Q. Okay. Separate — and, obviously, you've 3 Mr. Epstein; did they? 3 seen pictures in books? 4 MR. EDWARDS: Object to the form. 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: No. 5 BY MR. CRITTON: 6 BY MR. CRITTON: 6 Q. All right. But before you ever went to 7 Q. No one tried to restrain you from leaving 7 Mr. Epstein's, you knew what a — what a man's genitalia 8 that room; did they? 8 looked like; fair statement? seen, at least, 9 MR. EDWARDS: Form. 9 pictures in a book? 10 THE WITNESS: No. 10 A. Yes. 11 BY MR. CRSITON: 11 Q. Okay. Is it your testimony that you had 12 Q. No physical force was ever used at any time 12 never seen a man's penis before that? 13 by Mr. Epstein directed to you; was it? 13 A. Yes. 14 A. No. 14 Q. But you've seen a man's penis since then; 15 Q. M. leaves? 15 true? 16 A. 1.1h-huh. 16 A. Yes. 17 Q He's still lying on his stomach? 17 Q. AU right. Mr. Epstein's penis look any 18 A. No. 18 different than others that you've seen? And assume that 19 Q. All right. How much longer did you spend in 19 women's breasts look different between women, I believe. 20 the room with Mr. Epstein? 20 Anything different with Mr. Epstein's penis than you've 21 A. About 30 minutes. 21 seen with other men's penises? 22 Q. So you were there approximate ly an hour the 22 A. Yeah. 23 first time? 23 Q. What? 24 A. Yes. 24 A. It was like — I don't know. I mean, I guess 25 Q. Okay. What happened next? 25 it was small and -- I don't know. It looked like he 31 (Pages 247 to 250) (5 61) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-712.1552) O16158d-6c22-4c50-b036-0423618c2fb5 Electronically signed by Pamela Sullivan (501.333-772.1552) EFTA00723135 Page 251 Page 253 1 like wasn't circumcised right or something. 1 Q. All right. So you get — you get i cab. 2 Q. Okay. Let me ask you this: So after he 2 Did you say — have any conversation wide. after you masturbated, did he ejaculate? 3 came down, up until the time you got in the cab? 3 4 A. Yes. 4 A. No. We actually ended up walking up his 5 Q. All right. And did you look, or did you turn 5 street and flagging a cab driver down. 6 away? 6 Q. All right And as u're walking up the 7 A. I did not look. I turned away. 7 street, what did you say tMl.? 8 Q. All right When that was complete, what 8 A. I didn't talk to her about it. 9 happened? 9 Q. Pardon? 10 A. lie got in the shower, and I put my clothes on 10 A. I did not talk to her about Jeffrey Epstein. 11 and left. 11 Q. Why not? 12 Q. Okay. Did he — did you see him again before 12 A. I did not feel comfortable. 13 you left -- Mr. Epstein? 13 Q. Did she already L: i you 5200 by that point? 14 A. Oh, yeah, I — 'went down — downstairs to 14 A. Yes -- no — well'. pretty sure that 15 where.. was and sat with her for a second. And I 15 whenever Jeffrey had came into the kitchen, when -- when 16 don't know how long it was, but he came into the kitchen 16 we were both in there, he asked her if she had given me 17 and like laughed with. about something — I don't 17 the money or not. And that -- 18 know what it was. And I guess we were waiting for the 18 Q. And she said? 19 cab to come back and get us, and then we left. 19 A. That's when she gave it tome. 20 Q. Did he give you any money? Did anyone give 20 Q. Did — did she tell you that she had gotten 21 you any money? 21 money? 22 A. It gave me money. 22 A. Yes. 23 Q. Once you got in the cab? 23 Q. And why did she get money? 24 A. Yes. 24 MR. EDWARDS: Object to the form. 25 Q. Okay. How much did she give you? 25 THE WITNESS: I don't know. Page 252 Page 254 1 A. $200. 1 BY MR. CRYITON: 2 Q. And when you were waiting downstairs, did you 2 Q. Did she ever tell you she got money because 3 have anything to eat or drink — and by drink, I mean 3 she brought you? 4 like a soda or water or anything? 4 A. I would assume that's why, but she never 5 A. I didn't, but.. did. 5 actually said that to me, no. 6 Q. Okay. Was she eating when you came down? 6 Q. But you were able to make that assumption 7 A. Yes. 7 pretty easily; weren't you? 8 Q. Was she eating and drinking something? 8 A. Yes. 9 A. I don't know. 9 Q. All right. Did you ever say anything to her 10 Q. Okay. You've never been on the occasions 10 that day? 11 that you've been at Mr. Epstein's house, you've never 11 A. No. 12 had — alcohol has never been served to you; has it? 12 Q. Okay. As you're walking up the street, did 13 A. No. 13 you say, I don't want the money, I don't — I don't want 14 Q. Okay. And never any type ofdrugs, 14 anything to do with Mr. Epstein? 15 prescription or otherwise, have ever — or tobacco has 15 A. No. 16 ever been used at Mr. Epstein's house; true? 16 Q. Did you keep the money? 17 MR. EDWARDS: Object to the form. 17 A. Yes. 18 THE WITNESS: sure I smoked cigarettes. 18 Q What did you do with it? 19 BY MR. CRITTON: 19 A. I don't know. I probably bought clothes with 20 Q. Outside? 20 it or something. 21 A. Outside ofhis house, yes. 21 MR. CRITTON: Let's take a lunch break. 22 Q. Okay. Mr. Epstein has never given you 22 (A luncheon recess was taken.) 23 tobacco or any type of alcohol or drugs, nor has anyone 23 (Continued in Volume III of the same day.) 24 in his house; true? 24 25 A. Yeah, that's true. 25 44. 32 (Pages 251 to 254) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela (lellIvan (501.333.772.1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 41151580.6c22-4c5043036-e423618c2fb5 EFTA00723136 Page 255 Page 257 1 004Per B, et') 1 CERTIFICATE OF OATH I IANE COO G0B9ADJ EDWARDS, Venn 2 THE STATE OF FLORIDA 3 Reatio, Rimed* Adkr 3 COUNTY OF PALM BEACH Ls OW City Ceett. Suite 1610 401 Eel Las et:s Bederrted 4 Fort Lauderelet Fl. 33101 5 IN RE SH0RI STI1E 6 I, the undersigned authority, certify that CASE NO • 02d,6211944ARRAnalleON 7 Dal Ms /we Doe, 7 JANE DOE personally appeared before me and was duly Pluto teke Apia frat on Weenediy. oa sus. 8 sworn. iv, xrp, yc2 ant rot amnion InIhe aboneerbrnal mac, Meat time, ytu al won 21242,24• 9 is now rec.:eery due'« sip woo tkpodrityt 10 M goevlouoty tweed M. an temnirt4 41114 10 Dated this 13th day of October, 2009. tomiesd toy= One rue eyed «coined fa 11 Mime Pa»read ire foltosisenket 11 uttlay, 12 Ai de ad <fee tnronift5ixt **glee 12 «mu tat As you mod 3014 &prism, is! 242541 13 13 aar>sa<uaaapuauauaul.eauddarrolMu Sonia:tort ti4ngpogrinl lbe Neer «yid 14 14 <Wet IMWTutatmMbama{ellufr 02oe tee hoe read du enneerim ate mood an eldeeet, be ss seem sigo an! dete Ge ant, Shed lit rend:vie 15 Pamela J. Sullivan, RPR, Pen u,ee 16 Ilya: doze Itbi ad sip ite &Sox& •ithin a Notary Public - State of for ressamkto time, the (tent laiKfi As *city teem 17 keured it> 64 <Sett seamy, toty Po Mod MO. 16 My Commission Expires: June 10, 2010 the Cleric ofte Cast IFyoo Me to net scr My Commission No.: DI) 560380 a Set«, 222 ycur ma»In ta blank 2 die banana d ilk kiwi and mum tout 17 19 Very indy 'out*. 18 19 at Pieto1a J. San*.21,R, Sae, Cla 20 Rue Cox% Asse:y,Irt OD: Cle212o, e 21 250S Mandan Mena Um 1:40 %%kg Pete Bieck flot1441140) 22 5614327540 23 410 herby .the my dean 25 24 MNE DOB 25 JAN0 DOE Page 256 Page 258 1 CERTIFICATE 1 CERTIFICATE 2 THE STATE OF FLORIDA 2 3 COUNTY OF PALM BEACH 4 3 THE STATE OF FLORIDA Pamela 1 Sullivan, Registered Profess:wet 4 COUNTY OF PALM BEACH Court Reporter and Notary Public in and for the State of 5 I hereby certify that I have read the foregoing 6 nœldo a longs do hereby certify that I was authorized to and did report said deposition in 6 deposition by me given, and that the statements 7 stenotype, and that the foregoing pages are a true and 7 contained herein are tine and correct to the best of my correct transcription of my shorthand notes of end e deposition. 8 knowledge and belief, with the exception of any 9 I further certify that said deposition we taken at 9 corrections or notations made on the errata sheet, if the time and place hereinabove set forth and that the 10 one was executed. 10 taking of said deposition was commenced and completed as hereinabove set out. 11 11 12 Dated this day of , 2009. I further certify that not attorney or counsel 12 of any of the parties, nor am I a relative or employee 13 of any attorney or counsel of party crewed with the 14 13 action nor am I financially interested in the onion. 15 14 The foregoing certification of this transcript does not apply to any reproduction of tiro same by any means 16 15 unless wen rho direct control and/or direction of the 17 catlfiong reporter. JANE DOE 16 Doted this 13th day ofOctober. 2009. 18 17 19 18 19 20 20 21. 22 21 Pamela/. Sullivan. RFR, FPR, CLIO 22 23 23 24 24 25 25' 33 (Pages 255 to 258) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333.772.1552) Electronically signed by Pamela Sullivan (501.333.772-1552) 4f15168445e22.4060430.18-4423818c2185 EFTA00723137 Page 259 1 ERRATA SHEET 2 IN RE: JANE DOE V. JEFFREY EPSTEIN 3 C . PAMELA I SULLIVAN, RPR, FPR, CLR 4 DEPOSMON OF: JANE DOE 5 DATE TAKEN: September 30, 2009 6 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HUE 7 PAGER LINEN CHANGE REASON 3 9 10 11 12 13 19 15 16 17 18 19 Please forward the angina signed errata sheet to this office so!bat copies inay be distributed to ail parties. 20 Under penalty of pajury. I declare that 1have rest my 21 deposition and that it is true and correct subject to any changes in tbeni or substaxe entered here. 22 23 DATE: 24 25 SiGNATURE OF DEPONENT: .. ... .. . • 34 (Page 259) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 441515846c22-4c50-b036-0423618c2fb5 EFTA00723138