EFTA00724274

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. 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, 09-81092 DEPOSITION OF Tuesday, May 11, 2010 9:16 A.M. - 10:59 A.M. PROSE COURT REPORTING AGENCY, INC. 3111 West Dr. Martin Luther King, Jr. Boulevard Suite 100 Tampa, Florida 33607 REPORTED BY: MICHELLE OLSEN BADEN, RPR, FPR Notary Public, State of Florida at Large Prose Job No.: 1998 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden.M ) and0i404:4536-414d-8110443419Ciec569 EFTA00724274 EFTA00724275 Page Page 4 APPEARANCES: 1 The deposition of vas taken 2 BRADEDWARDS, ESQUIRE 2 pursuant to Subpoena by counsel for the Defendant on 3 FARMER JAFFE WEISSINO EDWARDS FISTOS & 3 Tuesday, May 11,2010, commencing at 9:16 A.M. at PROSE LEHRMAN, P1. 4 425 North Andrews Avenue, Suite 2 4 COURT REPORTING AGENCY, INC., 3111 West Dr. Martin also, Florida 33301 Luther King, Jr. Boulevard, Suite 100, Tampa, Florida 5 Attorney or Plaintiff in Related 6 33607. Said deposition was reported by Michelle Olsen Case No0840893 7 Baden, RPR. Notary Public, State of Florida at Large. (Appeared via telephone conference call) a 9 WHEREUPON: STUART S. MERMEISTEIN, ESQUIRE MERMELSTEIN & HOROWITZ,PA. 10 THE REPORTER: Please raise your right hand 18205 Biscayne Boulevard, Saute 2218 11 Do you solemnly swear or affirm that the 31 ila 33160 12 a 12 13 testimony you give today in this matter will be the truth, the whole truth and nothing but the truth? Attorney for Plaintiffs in related cases 13 08-80069, 08-80119, 08-80232, 08-80380, 0840381, 14 THE WITNESS: Yes. 0840993, 0840994 15 14 (Appeared via telephone conference call) 15 16 a witness, having been duly sworn to tell the truth, the 16 17 whole truth and nothing but the truth, was examined and MICHAELI. PIKE, ESQUIRE 17 BURMAN CRITTON LUTHER & COLEMAN 18 testified as follows: n Boulevard, Suite 400 19 EXAMINATION 18 Florida 33401 20 BY MR. PIKE: 19 21 Q Morning, Ms. My name is Michael Attorney for Defendant, JEFFREY EPSTEIN 20 (Appeared via telephone conference call) 22 Plke Can you hear me clearly? 21 22 23 A Yes. 23 24 Q fm taking your deposition today via 24 25 25 telephone. Usually, when we have a telephone Page 3 Page 5 1 INDEX . 1 deposition, its very easy for me to talk ova you and PAGE 2 vice versa. So, during this telephone deposition, 2 3 please allow me to finish my questions and I will allow 3 Examination By Mr. Pike 4 4 you to finish your answers, that way you and I can hear Examination By Mr. Edwards.......—....--.72 5 each other clearly. 5 6 If at any time you do not understand my 6 Certificate of Reporter.._......_ 77 7 question, please stop and ask me to repeat the question 7 Catificate of Oath....... .....—...78 8 and I will do so, especially given the fact that we are 9 9 on the telephone. Okay? 10 10 A No problem. 11 11 Q Okay. Would you please state your name for 12 12 the record. 13 13 A 14 14 Q woo you please spell your last name. EXHIBITS 15 A 15 16 Q Ms. where is your current residence? 16 (No exhibits were market) 17 A I live 17 18 18 19 Q And how long have you lived in 19 20 20 A I moved right befo 21 21 Q And what Is your date of . 22 23 24 22 23 24 Q Wlam. ow old are you today? 25 25 Q What is your current telephone number, both 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY INC. IIIIIIIIIIIII Electronically signed by Michelle BadenMa 053d0950-b535-41401118-6434195ae559 EFTA00724276 Page 6 Page 8 home and cell phone? 1 A Nowhere. That was m first lob — or no I'm 2 A IS have a cell, there is no home, and it 2 sorry. I worked 3 3 • •Q was your first place of 4 Q How long have you had that cellular telephone? 4 employment? 5 A As long as I have lived ha. S A Yes, sir. 6 Q Cm sorry, what was the date that you 6 Q I'm going to ask you whether or not you know 7 moveda, just the year? 7 certain individuals, and I would just like you to answer 8 A Roughly, September or — wait. October, rrn 8 me yes, you know them or no, you do not know them. And 9 sorry. 9 the ones that you do know we'll come back to later on, 10 Q Of 2009 or 2008? 10 after I finish figuring out who it is that you know and 11 A 11 who it is you don't know. Okay? 12 Q Where do you currently work? 12 A Okay. 13 A lam not working. 13 Q Do you blow a female by the name of 14 Q Where was ur last lace of em lo t? 14 Jane Doe 2? 15 A I worked s. 15 A No. 16 16 Q Do you 'mow a female by the name of 17 Q What of business is that? 17 Jane Doe 3? 18 A It tvas 18 A No. 19 Q Where that located? 19 Q Do you know a female by the name of 20 A INIMMINIMMIIIMI 20 Jane Doe 4? 21 21 A No. 22 Q Is that also a 22 Q Sometimes pronounced Jane Doe 4? 23 A Yes, sir. 23 A No. 24 QAnd before that where did you work, 24 Q Do you know a female by the name of 25 Ms. ? 25 Jane Doe 5? Page 7 Page 9 1 A I worked 1 A No. 2 Q Where was tha located? 2 Q Do you know a female by the name of 3 A Not exactly sure of the 3 Jane Doe 6? 4 street, maybe , somewhere along there. 4 A Yes. 5 Q And befo where were ou employed? 5 Q Do you 'mow a female by the name of 6 A I worked a 6 Jane Doe 7? 7 7 A No. 8 Q And before 8 Q Do you know a female by the name of 9 A I worked at 9 Jane Doe 8? 10 Q And where is tha 'located, 10 A No. 11 areet-wise? 11 Q Do you know a female by the name of 12 A It's right there on. and 12 A No. 13 13 Q Have you ever metEl? 14 Q What was our osition at 14 A No. Never heard the name. 15 A I was 15 ...Do youlmow a female by the name oil.. 16 Q Okay. How long did you work for 16 17 A I would say a couple months. 17 A No. 18 Q And before= in where did 18 Q Do you know a female by the name of= 19 you work? 19 A No. 20 A I worked at — I'm not sure of the name — I 20 Q Do you latow a female by the name of 21. want to say 21 Jane Doe II? 22 Q How long did you work for the 22 A No. 23 A I would say ma be a month month or two. 23 Q Do you blow a female by the name of Jane Doe? 24 Q And bef where did you 24 A Yes. work? Q Do you know a female by the name ofMIT 1r 4. 3 (Pages 6 to 9) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle BadenIIIMEIM) and09804538-04d-M18-643419bac559 EFTA00724277 Page 10 Page 1 A Yes. 1 A No. 2 Q Do you know a female by the name oliM 2 Q And when I ask that question I mean, from the 3 A Yes. 3 time that you have known her up until today's date, has 4 Q Do you know a female by the name of Si 4 she ever mentioned to you the name Jeffrey Epstein? 5 A Yes. 5 A No. 6 Q Do you know a female by the name SIM 6 MR. EDWARDS: I'm sorry is the "her" that 7 A No. 7 we're talking about Jane Doe 6 still? 8 Q Give me one second. Ms. how is it 8 9 MR. PIKE: Yes. THE WITNESS: Yeah, no, I nova heard anything I 9 that you know Jane Doe 6? 10 A She lives in the neighborhood I use to hang 10 about it. She's never mentioned that name. 11 out in. 11 BY MR. PIKE: 12 Q And what nei borhood is that? 12 Q Did you ever come to team that Jane Doe 6 had 13 A 13 gone to Mr. Epstein's home for any reason? 14 Q Would I that for the record. 14 A No. 15 A I believe. 15 Q Did Jane Doe 6 ever tell you that she went to 16 Q How long have you known Jane Doe 6? 16 Mr. Epstein's home in Palm Beach to give Mr. Epstein a 17 A I woWd say since I was 15. 17 massage? 18 Q Did you guys go to school together? 18 A No. She said she went there, when I last 19 A No. 19 talked to her, but no details. 20 Q How did you meet her? 20 Q Did Jane Doe 6 ever tell you that Mr. Epstein 21 A She was just hanging out with friends, I 21 faced her to do anything against her will? 22 believe. Just everybody hanging out and we met. 22 A No, sir. 23 Q Have you remained friends since the time you 23 MR. MERMELSTEIN: Object to form the question. 24 first met her? 24 BY MR. PIKE: 25 A Yes. 25 Q And, Mr. there are two other lawyers Page 11 Page 13 1 Q When was the last time you spoke to her? 1 on the phone and they are going to be making legal 2 A I spoke to her what is today, Tuesday. I 2 objections. Basically what that is is an attempt to 3 talked to her on Sunday. 3 preserve the record. Those objections aren't directed 4 Q When you spoke to her on Sunday did you speak 4 at you. Those objections are directed at my questions. 5 about this case? 5 So when you do hear a lawyer make an objection. Please 6 A No. 6 hold offuntil we finish our dialogue and then I'll come 7 Q Have you ever spoken to Jane Doe 6 about this 7 back to you and ask you to finish your answer. Okay? 8 case? 8 A Okay. 9 A I never knew she had anything to do with this 9 Q Did Jane Doe 6 ever tell you that she 10 until she told me the other day. 10 experienced any traumatic events at Jeffrey Epstein's 11 Q Would that be Sunday? 11 home? 12 A No. We -- !just got back from 12 MR. MERMELSTEIN: Objection to form. 13 Q So when you were in you saw her face 13 THE WITNESS: No. 14 to face? 14 BY MR. PIKE: 15 A Yes. 15 Q Did Jane Doe 6 ever tell you that she provided 16 Q And where did you guys meet in NEM 16 Mr. Epstein a massage while her bra was off? 17 A I saw her at her house. I came to say hi. 17 A No, sir. 18 Q What did you guys talk about relative to this 18 Q Is Jane Doe 6 one of your best friends? 19 case? 19 A I wouldn't say best friend but she is a 20 A All I said was that I can't — not talking 20 friend. 21 to because I have to do a deposition and she just 21 Q Is she a close friend? 22 said that she had something to do with it but that's — 22 A I mean, when I go to i go and say hi 23 she didn't go into detail. 23 but that's about it. 24 Q Did she ever talk to you about a gentleman by 24 Q Since you moved to how often do you .!5 the name ofJeffrey Epstein? 25 speak to Jane Doe 6? 4 (Pages 10 to 1 3) PROSE COURT 'REPORTING AGENCY, INC. Electronically signed by Michelle Baden MMIM aa3d0950-6535.414d-81186434195ac559 EFTA00724278 Page 14 Page 16 1 A Only when I go down there, so I would call her 1 A 2 before I go down there and say "Hi," but other than that .2 Q Do you know of any other close friends that 3 we don't talk. 3 have died in Jane Doe 6 lifetime? 4 Q Do you know of any traumatic events that 4 A No —or yes. 5 Jane Doe 6 has experienced in her lifetime? 5 Q And who was that? 6 MR. MERMELSTEIN: Objection to form. 6 A 7 BY MR. PIKE: 7 Q And who is that to Jane Doe 6? 8 Q And your answer was, Ms ? 8 A Good friend. 9 A No. Q Would you consider that a traumatic experience 10 Q Do you know whether or not any one of her 10 for her? 11 boyfriends everMEMS? 11. MR. MERMELSTEIN: Objection to form. 12 A Yes. 12 BY MR. PIKE: 13 Q Would you consider that a traumatic event? 13 Q You can answer. A Slightly, yes, a little a 14 A Yeah. 14 15 Q And how did Mr. die? 15 Q And your answer was, 16 A Yes. 16 A 17 What • was that, to your knowledge, 17 And did they eve1 18 18 19 A I have no idea. 19 A Yes. 20 Q Did Jane Doe 6 ever discuss that traumatic 20 Q And is that person= 23. event with you? 21 A Yes. 22 A No. I heard from somebody else. 22 Q Do you know whether or not Jane Doe 6 has ever 23 Q Who did you hear from? 23 done drugs in front of you? And by "drugs" I mean 24 A I have no idea. Just gossip around the 24 marijuana, amphetamine or any kind of painkillers? 25 neighborhood. I have no idea. 25, A Yes. Page 15 Page 17 1 Q Did you ever have any sexual experiences with 1 Q And what drugs has she done, to your 2 Jane Doe 6? 2 knowledge? 3 A No. 3 A Marijuana in front of me. 4 Dkl ever learn that Jane Doe 6 was an 4 Q What other drugs? 5 at the age of, 5 A She's never done anything else in from of me. A No. 6 Q To your knowledge, do you know whether she has 7 MR, MERMELSTEIN: Objection to fonn. 7 done any other drugs, separate and apart from marijuana? 8 BY MR. PIKE: 8 A . I'm not sure. 9 aor you know whether or not Jane Doe 6 is a 9 Q Do you know whether or not Jane Doe 6 drinks 10 10 alcohol? 11 A I knew shel.Mbut 1 don't see it 11 A No. 12 any farther than that. 12 Q When she did marijuana in front of you, how 13' Q Do you know whether or not she has a 13 old was she and how old were you? 14 relationship with her mother? 14 A 15 and 1 don't know how old she was. 1S A She does, as far as 1 know. 15 Q Have you ever met Jane Doe 6's child? 16 Q Based upon your experience, do you know 16 A Yes. 17 whether or not it is a good relationship or a bad 17 And what is name? 18. relationship? 18 A 19 A 1 would say good. 19 Have you ever met the father? 20 Q Where does her mother live, to your knowledge? 20 A Yes. 21 A 21 And what is his name? 22. Q What about her relationship with her father, 22' A 23 do you know anything about that? 23 And his last name? 24 A I guess they have a good relationship. 24 A 1 have no idea. Q Do you know where her father lives? 25 Do you know who Jane Doe 6 currently dates? 5 (Pages 14 to 17) PROSE COURT REPORTING AGENCY., INC. a53d0950-136364f4d-8118-6434195se659 Electronically signed by Michelle Baden NM= EFTA00724279 Page 18 Page 20 1 A la. 1 A No. We went to the store. 2 Q And doeaMive 2 Q During the times that you hung out with her, 3 A Yes. 3 was she ever crying? 4 Q And what does he do? 4 A No. 5 A I'm not sure.alMni or something. 5 Q During the times you hung out with her 6 Q With regard to the women that you said you 6 recently, did she ever make any mention or complaint 7 knew, were you aware as to whether or not any of those 7 about Jeffrey Epstein? 8 women ever went to Jeffrey Epstein's home in Palm Beach? 8 A No. 9 A 1 only knew about Jane Doe anclia Q Did she seem depressed to you? 10 Q Did you ever go to Jeffrey Epstein's home? 10 A No. 11 A No, sir. 11 Q Did she dist-mg any emotional issues that she 12 Q Ind you ever drop anyone off at Jefftey 12 was having with you? 13 Epstein's home by vehicle? 13 A No, sir. 14 A No. I can't drive. 14 Q Did she discuss at all any happy times in her 15 Q And why can't you drive? 15 life, of the times that you visited with her most 16 A 1 don't have a license and lam afraid of the 16 recently? 17 road. 17 A No. 18 Q Have you ever had a license? 18 Q What did you guys talk about? 19 A No, slr. 19 n't know. Ii 20 Q Why is it that you are afraid of the road? 20 our friend' 21 A I got in a car accident whealwaa 21 22 Q Who was in the car with you? 22 And that would be Ma 23 A My friend= 23 A Yes, sir. 24 Q And what is her last name? 24 Q Ho ' 9 25 A 25 A He Page 19 Page 21 1 Q Anyone else? 1 Q 2 A /N. stn. 2 A Yes, sir. 3 still living today, that is did she 3 Pm sorry, you testified that Mal was Q I 4 die as a result of the car accident? 4 Ma is that correct? 5 A No. She's still living. 5 A Yes. 6 Q When you saw Jane Doe 6 on Stmday, did she 6 vots.What were the circumstances surrounding how he 7 seem happy to you? 7 8 A I don't know. We just stopped by and said 8 A They sa r a lot of stories like 9 "Bye" so — she was just watching a movie. 9 it the but he got basically said you stopped by and said "Bye..."? 10 and then the 10 Q You 11 A Yeah, because we were driving back toME 11 people ran. . 12 Q Who was with you? 12 _10 Where was be living at the time that he was 13 A My boyfriend. 13 NE ou A iflifis m? w 14 Q What is his name? 14 A 15 Q Do you know if Mr was in a gang? 15 16 Q Does lie live in 16 A No, I don't. 17 A Yes. 17 Q Do you know iflane Doe 6 was ever in 2. 18 Q How long did you visit with Jane Doe 6 for? 18 A I don't believe so but I don't know everyb . 19 A I saw her a couple of times since I was there, 19 she knows. I live here now. 20 just hung out for a little and then I was mainly at my 20 Q Did Jane Doe 6 ever talk to you about her 21 mom's. 21. being a prostitute? 22 Q When you hung out with Jane Doe 6, where did 22 A No. 23 you go? 23 Q Do you know whether Jane Doe 6 ever was a 14 A We were at her house. 24. prostitute? 25 Q Any other places? 25 A No. 6 (Pages 18 to 21) PROSE COURT REPORTING. AGENCY, INC. Electronically signed by Michelle Baden .53•10960-b535-0444t184434198ae569 EFTA00724280 Page 22 Page 24 1 Q That is no you don't lmow one way or the 1 A No, sir. 2 other? 2 Q Were you ever out anywhere a 3 A No, I don't know. 3 where you saw.lat a club? 4 Q Do you know whether or not Jane Doe 6 ever 4 A No. 5 vented at any strip clubs and/or gentlemen's clubs? 5 Q Dld you talk to= on the phone? 6 A No. 6 A No. 7 Q That is no, you do not know? 7 Q When was the last time you talked toile 8 A No, I do not know. 8 A !saw her at Wal-Mart when I was, probably, 9 Q Do you know if she ever hung out at any strip 9 It 10 clubs or gentlemen's clubs? 10 Q You said you saw her at Wal-Mart? 11 MR. MERMELSTEIN: Objection to form. 11 A Yeah. 12 BY MR. PIKE: 12 Q I didn't hear you if you testified to this, 13 Q You can answer. 13 Pm sorry. How long ago was that? 14 A I don't 'mow. 14 A I'd say when I was 18. I went down to visit 15 Q Do you know if Jane Doe 6 was ever involved in 15 and she was at Wal-Mart eating at the food 16 a car accident? 16 court and I _saidi "Hi." 17 A I believe so, when she was younger. 17 Q Hass. ever discussed Jeffrey Epstein with 18 Q What do you know about that car accident? 18 you? 19 A I believe it was aMill That is all I 19 A No, sir. 20 remember. 20 t f I remember correctly, you said you knew 21 Q Do you know if anybody passed away in her 21 that M. was going to Jeffrey Epstein's home? 22 vehicle? 22 A I heard Jane Doe mention it but don't know 23 A I don't know. 23 details. 24 Q Do you know if anybody came close to dying 24 Q When you say "Jane Doe" you mean Jane Doe? 25 that was in her vehicle? 25 A Yes, sir. Page 23 Page 25 1 MR. MERMELSTEIN: Objection to form. Q What did Jane Doe mention that you are 2 THE WITNESS: I don't know. 2 talking about now? 3 BY MR. PIKE: 3 A She said that she was at the house that. 4 Q Let's talk abou= You said you knewill.; 4 Q That. was at Mr. Epstein's house? 5 is that correct? 5 A Yeah. 6 A I met.. • Q Have you ever discussed.. going to 7 Q How did you meet.. 7 Mr. Epstein's house with.? 8 A Once again, just everybody knows everybody and 8 A No. 9 she was hanging out one night and I met her. Q What, if anything, do you know about... 10 Q Where did u meet her? 10 going to Mr. Epstein's home?. 11 A at the bead, I believe. 11 MR. EDWARDS: Form. 12 Q How long have you known ha? 12 THE WITNESS: I don't know anything besides 13 A I not her on my 15th birthday, !believe. 13 that she went there. 14 Q Okay. So you have 'mown her for, what,. 14 BY MR. PIKE: 15 years, approximately? 15 Q Do you know whether or not she did anything of 16 A Well, I have only — in that whole time, I 16 sexual in nature at Mr. Epstein's home? 17 have only hung out with her for maybe lute three times. 17 A I have no idea. 18 So that is why I don't say like she's a friend. She's 18 I know that you said you didn't bang out with 19 just an acquaintance. I met her. 19 M. that much, but I have to ask you these questions 20 Q When you hung out with her for those three 20 and I'll try to make them short. 21 times, where did you guys hang out? 21 Did.. discuss with you any traumatic events 22 A We were at the beach. The other times we were 22 that happened to her at Mr. Epstein's home? 23 just, I don't know. I know she was at Jane Doe's once. 23 A No, sir. 24 And then I don't !mow. 24 Q Has.. called you to discuss at all any 25 Q Did you guys ever go out to clubs together? 25 emotional issues that she allegedly has by virtue of 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. at3d0950-b536-4f4d4018-643419Sec669 Electronically signed by Michelle Baden IMMIMID EFTA00724281 Page 26 Page 28 1 having visited Mr. Epstein's home? 1 BY MR. PIKE: 2 A No. 2 Have you ever been AMMAN 3 Q Do you know whether or nail worked at 3 4 strip clubs? 4 A No, sir. 5 A I don't 'mow. 5 Q Do you know whale) is? 6 Q As you sit here coda our testimony is you A A gentlemen's club. 7 don't know whether or node. ever worked as a stripper 7 Q Do you know t nextd Mien- - 8 at a snip club? 8 club is a place call 9 A I have no idea. 9 A I don't even latow is located. 10 Q Did Jane Doe ever tell you than. ever 10 Q Have you ever heard the term "jack shack"? 11 worked at any strip club? 11 A Yeah. Movies. 12 A No. 12 Q What -- bow do you understand that term? 13 Q Do you know whether or no is an admitted 13 A I guess, basically, a place where you go and 14 prostitute? 14 sell yourself. 15 A I don't know. 15 Q Do you know whether or no.. has ever 16 MR. MERMELSTEIN: Form. 16 worked at any jack shacks? 17 BY MR. PIKE: 17 A No. 18 Q Do you know whether or not- ever sold her 18 MR. EDWARDS: Object to the form. 19 body for sex? 19 BY MR. PIKE: 20 MR. EDWARDS: Objection to form. 20 Q That is no, you don't know? 21 THE WITNESS: I have no idea. 21 A No, I don't know. 22 BY MR. PIKE: 22 Q All right let's move on toM. You did 23 Do you know whether or no= ever 23 testify earlier that you knew her, correct? 24 when shewaiters old? 24 A Yes. 25 A I have no idea. 25 Q How do you known.? Page 27 Page 29 1 MR. EDWARDS: Objection to the form of that 1 and 2 3 4 question as well. BY MR. PIKE: Q Do you know whether or no sa 2 3 4 Q A was was that? 5 prostitute? 5 Q And did you go to HAM for. 6 A I don't know. 6 years? 7 142. EDWARDS: Same objection. 7 . A No. 8 BY MR. PUCE: 8 Q 11. ur long did you go- 9 Q Had you ever heard than...as a 9 A El years. 10 prostitute? 10 Q And how long did.. go to that school for? 11 A No. 11 A I'mnql.tia. 12 Q Do you know who.. is currently dating? 12 .Q What= were you in when you first met 13 A No. 13 14 Q What else can you tell me about., if 14 A I was 15 anything, that we haven't discussed during your 15 Q Did You Pr 16 deposition today? 16 A No. 17 A !can say nothing because I don't talk to her. 17 Q How did you meet her? 18 I've only hung out with her a couple times and didn't 18. A I met her brother and then I went to her house 19 really, you know, talk-talk. Just hung out. I don't 19 and met ha. 20 know her. I don't know anything. 20 Q How did you meet her bro ? • 21 Q Do you know whether ently 21 A Just around the neighborhood, like everybody 22 works at a lace call right by 22 knows everybody. 23 in 23. Q Did you ever date her brother? 24 A I don't ;mow. 24 A No. 15 MR. EDWARDS: Object to form. 25 Q Did you ever have any sexual experiences with 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden . and095043536-414d-8116-6434195ac669 EFTA00724282 Page 30 Page 32 1 her brother? 1 MR. EDWARDS: Form. 2 A No. 2 BY MR. PIKE: 3 !ti Did you ever have any sexual experiences with 3 Q When was the last time I 'mow you said you 4 ..? 4 haven't spoke a. in a while. When was the last 5 A No. 5 time you spoke to her? 6 Q Are you aware that.. and.. are friends? 6 A I talked to her, I would say, maybe two years 7 A Yes. 7 ago on the phone. She was with Jane Doe, I believe, and 8 Q How are ou aware of that? 8 I just said "Hi" you know, caught up and asked how we 9 A . htzg_out with me and then she 9 were doing and that was it. 10 started hanging out with., and then we basically 10 Q Did she tell you what she was up to worlovise 11 talk an more. We went separate ways. 11 in that telephone call? 12 Did . ever tell you that.. ever worked 12 A No. 13 13 Q How long did that telephone call last? 14 A No. I haven't talked to.. maybe since I 14 A I would say maybe five, 10 minutes. I was at 15 was 15. 15 a store, Thad to go. 16 Q And why did you stop talking to..? 16 2 How did you learn or di ever learn that 17 A Well, she always came to hang out with me and 17 M. went over to her home in 18 then, I don't know, we went our separate ways and, I 18 A Basically you told me. !had I10 idea. 19 don't knowzie•ust lost contact 19 Q So you had no idea — you had no idea up until 20 Q Did . ever discuss whether she went to 20 today's date? 21 Mr. Epstein's home in Palm Beach? 21 A Yes, no idea. 22 A No, sir. 22 Q Did Jane Doe or anyone ever tell you thatI. 23 Q She never discussed that with you? 23 had some sort of experience with Mr. Epstein? 24 A No. 24 A No. 25 Q Did.. ever tell you that she worked at 25 Q Did anyone ever tell you that.. ever gave Page 31 Page 33 1 1 Nix. Epstein massages in exchange for money? 2 A No. 2 A No. 3 Q How long were you friends with..? 3 Q Do you know whetbirar not, during the time 4 A Well, I have known her — I met her when 1 was 4 that you were friends withM. that she ever used 5 likes and we hung out for a couple of years, and then 5 drugs? 6 we just didn't hang out any more, so two years. 6 A Marijuana. 7 Q Pro sorry? 7 Q And how old was she when she was using 8 A Like two years. 8 marijuana? 9 Q So you knew her for two yews? 9 A 15,14. 10 A Yeah. 10 Q Do you know whether or not she used marijuana 11 Q And durittg that two- ear eriod, did she ever 11 on a weekly basis or on a daily basis during that time? 12 tell you that she worked a 12 A I think it was just like a weekend thing. 13 A No. 13 Q Do you know whether or not she ever did 14 Q Did you ever come to learn at any even 14 Ecstasy? 15 up through today's date, that she worked at 15 A I have no idea. 16 A Yeah. 16 Q What about do you know whether or not 17 Q How did you learn that? 17 she did Ecstasy? 18 A Jane Doe. 18 A I have no idea. 19 Q What did Jane Doe tell you about that? 19 Q And Jane Doe 6, do you know whether or not she 20 A She just told me she w 20 ever did Ecstasy? 21 Q Did she tell you which 21 A I don't think so. 22 A No. 22 Q Other than marijuana, are you aware at joy. 23 Q Did she tell you that ever worked at any 23 time, even up until today's date, whether or notEMI. ?4 jack shacks? 24 used any other drugs? A No. 25 A No. 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. a53d0950-b535-4(4d-Sf18-6434195ac559 Electronically signed by Michelle Baden lIMM. EFTA00724283 Page 34 Page 36 1 Q No, you are not aware? 1 BY MR. PIKE: 2 A No, I don't know. I'm not aware. 2 Q You can answer. 3 Q The last time you spoke with., which was 3 A Oh. 4 approximately two years ago, did she discuss whether or 4. Q And are u aware as to why 5 not she was experiencing any emotional or traumatic 5 A or something along 6 experiences in her life? those lines. 7 A No, sir. 7 Now are ou aware as to whether or not he was 8 Q Give me one second. 8 9 A Olcay 9 A I think so. 10 d do you know the circumstances surrounding 10 11 12 Q DWI... ever ask you to go to Mr. Epstein's home? A No. 11 12 ai A No. 13 Q Were you ever asked by anyone to go to 13 Q Do you know whether or not Jane Doe witnessed 1.4 Mr. Epstein's home? 14 an in related to that 15 A Yes, by Jane Doe. 15 16 Q And wall. around at the time that Jane Doe 16 A I believe she was there when it happened. 17 asked you that? 17 Q What, to you ed? 18 A I heard that and she 18 A No. 19 Q DidM. ever attempt to persuade you in any 19 woke up and he was 20 way to go to Mr. Epstein's home? 20 Q And who was that, relative to 21 A No. 23. Jane Doe? 22 Q Let's talk about Jane Doe. When was the first 22 A 23 time you came to know Jane Doe? 23 Do u know whether or not her 24 A 24 25 Q Did you guys live close to each other? 25 A I don't know. Page 35 Page 37 1 A 1 Q Do oulmow what — did Jane Doe ever tell ou 2 Q Would you consider yourselves to be best 2 that her 3 friends? 3 4 A We were. 4 A No. 5 Q So how lonuere you best friends? Q Do you know whether or not lane Doe gave any 6 A Since i was. and then I moved here and we 6 itions related to 7 just don't talk too much any more. We don't talk any 7 8 more, 8 A I think so. 9 Q So is it a fair statement that you were best . 9 Se Do you know whether or not she lied for her 10 friends for approximately= years? 10 in deposition? 11 A Yes. 11 A I don't know. Q And that would be approximately from the time 12 Did she ever tell you that she lied for her 12 13 14 that you both were, up until the time that you were about. 13 14 ME in those depositions? A No, sir. 15 A Yeah. I would say 15 • Do you know how old the1, was that 16 Q And why aren't you best friends today? 16 17 A Well, I would consider her my best friend but 17 A I don't know. I'm not sure. 18 then we went separate ways. I moved here and !just 18 Q You testified that as a 19 haven't talked to her. Since I've moved here I have 19 result of this incident, as we speak today, correct? 20 only talked to her a couple of times. 20 A Yes. • 21 Q I want to talk a little bit about Jane Doe and 21 Q Do you know whether or not Jane Doe has a 22. her childhood. What traumatic experiences are you aware 22 relationship with her today? 23 of that she experienced in her childhood? 23 A I don't know. 24 MR. EDWARDS: I object to the form of the 24 Q o Di" know whether or not she has gone to !p question. 25 visit in the last two years? 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY,. INC. a53(10950-b535-4f4d-8f18-6434195ac559 Beetronicany signed by Michelle Baden =EMS EFTA00724284 Page 38 Page 40 A No. 1 up. Did you ever witness an or physical 2 Q No, she has not or no you don't know? 2 altercations between Mr. and Jane Doe? 3 A No, I don't know. 3 A No. 4 Q Do you Imo" whether or not Mr. ever 4 o lio you know whether or not her - was ever 5 5 EJane Doe? 6 A I don't 'mow. I think so but I don't know for 6 A No, I don't ;mow. 7 sure. 7 Q What other gentleman are you aware of that Do you lmow, as u sit here today, what her 8 Ms. Jane Doe dated, from age 13 up until today's date? 8 9 10 il A No. may have 10 9 A Umm. Q Let's start from the age 13 and move forward. 11 Q Do you know whether or not Jane Doe has a 11 A Wow. Well, she dated — I don't know. The 12 relationship with her father? 12 people she dated was only for a little and I didn't 13 A No. 13 even — I don't know. Let's see. She dated. Oh, she 14 Do u know whether or not her father ever 14 dated 15 15 Q How long did she date him for? 16 A !don't know. 16 A Not too long, couple months. 17 Q Did Jane Doe ever discuss with you her 17 told was she when she was dating 18 fathers MOM? 18 Mr. 19 A No. 1919 A 14,13. 20 Q Did Jane Doe ever discuss with you her 20 Q Did she have intercourse with Mr. IMF 21 father 21. A Yes. 22 A No. 22 Q Dost how many times she had intercourse 23 o you know a gentleman by the name of IM 23 with Mr. 24 25 AliA Yes. 24 25 A No. Q Do you know how many times she had intercourse Page 39 Page 41 1 Q Who is that? 1 with Mr.M? 2 A Her ex-boyfriend. 2 A No. 3 Q Do you know how long they dated for? 3 Q Do know whether or not she performed oral 4 A I would say over a year. 4 sex on Mr. 5 Q And how old was Jane Doe when she started 5 A I don't know. 6 dating Mr. a/ 6 Q Do you know whether or not he performed oral 7 A I would say 16 — no, 16, 17, maybe, yeah. 7 sex on her? 8 16, 17. 8 A I don't know. • 9 Q Ma ni know whether or not she had intercourse 9 Q How did you become aware that Jane Doe had 10 with Mr. during the time that she was dating 10 intercourse with Mr. and Mr.M? 11 him? . 11 A She told me but that's about it. No details. 12. A Yes. 12 Q As you sit here today, do it inow whether or Q The answer is, yes, she did have intercourse? 13 not she had intercourse with Mr. more than five 13 14 A Yes. 14 times? 15 Q Dosi row whether or not she ever gave oral 15 A Probably. 16 sex to Mr. 16 Q And, as you sit here today, do you know 17 A I don't know. 17 whether or not she had sexual. ntercourse with 18 Q Did she ever discuss that with you? 18 Mr. more than five times? 19 A No. 19 A Probably. 20 Q Do you IcnoW whether or not Mr. ever 20 Q Dayou know whether or not she did any drugs 21 performed oral sex on her? • 21 with Mr. and Mr. a 22 A I don't know. 22 MR. EDWARDS: Object to form. 23 Q Did she ever discuss that with you? 23 THE WITNESS: Marijuana. 24 A No. 24 BY MR. PIKE: . 25 Q Who else are you aware — actually, let's back 25 Q So your testimony is that you have seen her do 11 (Pages 38 to 41) PROSE COURT REPORTING AGENCY; INC.' . Electronically signed by Michelle Baden Mal a5M0960-b535-41,4d4f184434195salS9 EFTA00724285 Page 42 Page 44 1 marijuana with Mr. and Mr. IIIIP 1 A No. 2 A Yeah. 2 MR. EDWARDS: Object to form. 3 MR.. EDWARDS: Object to the form. 3 MR. PIKE: For the record, if the form is I 4 BY MR. PIKE: 4 don't mear~ 5 Q Let me rephrase the question. Have you seen 5 THE WITNESS: Yeah. No. Since she's been 6 Jane Doe do marijuana with Mr. and Mr. 6 withM, I haven't talked to her. 7 A Yes. 7 BY MR. PIKE: 8 Q And how old was she, approximately, when you 8 Q And how long has it been since you've last 9 witnessed these events? 9 spoken to Jane Doe? 10 A 14 and 16, roughly, yeah. 14, 16 10 A I saw her whe 11 Q.o weve tented about Mr. and 11 12 12 Do otica whethex or not Jane Doe ever al mi 13. A Uh-huh. 13 14 Q I want yoti to think a bit and tell me who else 14 A Yes. 15 you can recall that Jane Doe dated? 15 Q And how old was she when 16 A Some kid namedMI. That was a long time 16 A The time I know about, I think, slue was 17 ego and that only lasted for a little while. 17 St Okay. And what were the reasons why she • 18 Q Do you know whether or not she had sexual 18 to your knowledge? 19 intercourse with-? 19 A IfigrAtheYmellIIIIIIIIIIII 20 A No, I don't know. 20 Q What do you mean that? 21 Q How long ago was it that she dated Mr.IM? 21 A I don't knowl 22 A 15. She was 15. 22 23 Q Do you know how long she dated for? 23 Q And when u set " who do ou mean? 24 A Not long at all. 24 A 25 Q Do you blow last name? 25 Q And do you know wiry they were trying to Page 43 Page 45 1 A No idea. Don't even !mow his real first name. 1 MK in your words? 2 Q I figured that. Do you know who Jane Doe is 2 A No. 3 currently dating? 3 Q Have you ever heard of the tent 4 A Somebody named 4 A Yes. 5 Q Is that his real name? 5 Q Were they trying to 6' A I have no idea. 6 A I not sure. Might have, but I don't know. I 7 Q Do you 'mow whether or not they live together? 7 was young too so I just — I don't know. 8 A I think so, yes. 8 Q And do you know, when sheMINIME 9 Q Where does Jane Doe currently live, to your 9 10 Icnowleci 10 A She came to.. •' 11 A 11 Q And at that time were both of your parents 12 wiQ Do know whether or not she still lives 12 or was it just one parent? 13 13 A It was jus and she didn't know the 14 A Yes. 14 situation. 15 Q Did Jane Doe eye Or a 15 Q And does Mr.. live there with them in that 16 residence? 16 period of time? 17 A I'm not positive but as far as I know. 17 A I mean, you could say 18 Q How did she meet Mr. In? 18 We were Just always together. 19 A No idea. 19 Q Let me try — was there a time that she ever 20 Q Do you know whether or not Mr. has 20 due 21 been — has ever been 21 to her 22 22 A I would say a couple of dayilIMI with 23 A I have no idea. 23 me. 14 O Does Jane Doe ever tell you that Mr.Ill was 24 Q At the time that you testified that her 25 25 parents were do you know whether 12 (Pages 42 to PROSE COURT REPORTING'AGENCY, INC. Electronically signed by Michelle BadenIIMM) 853d0950-8535-O48-8118-6434195ac559 EFTA00724286 Page 46 Page 48 1 or not she was doing drugs or alcohol? 1 hand jobs formono 2 A I don't think it was her trying to 2 A No, sir. 3 IIIIIIIthMkftwas But I don't think 3 Have ever heard of the term of the 4 so. Maybe, if it was, marijuana. 4 5 Q Do you know whether or not Jane Doe was ever 5 A I have heard the term, yes. 6 arrested at any time? 6 Do you know whether or not Jane Doe worked in 7 A I think 7 a 8 Q What was she arrested for? 8 A I don't know. 9 A I think Mahe said. 9 Q Have you ever heard the term 10 Q Do you know what she 10 A No. 11 A No. 11 Q Have you ever heard the tenni...? 12 13 14 Q Do you know whether or not Jane Doe was ever arrested for A No. 12. 13 14 Q Do A Yes. you know whether or not Jane Doe ever gave to men in exchange for money? 15 Do ou know whether or not Jane Doe ever. 15 A I don't know. 16 16 Q She never told you? 17 A Oh, yes. Yes. 17 A No. 18 Q How many times? 18 Q Okay. What did Jane Doe discuss with you 19 A 19 about working at these two sIES, that you are 20 Q And was she arrested for that? 20 aware of? 21 A I believe so, now that you mention it. 21 A All she said is she works there. I don't talk 22 Q So there is another arrest that you weren't 22 to her much at all. I say, "Hey, what are you doing? 23 aware of, correct? 23 She says, "Hey, I work hero," and I leave it like that 24 A Well, now that you bring it up I'd say yes, I 24 because I don't want to know the details. 25 was aware ofit, but I didn't even remember that. 25 Q Would she tell you how much money she made? Page 47 Page 49 1 Q You understand you are under oath today, 1 A No. 2 correct? 2 Q Did she ever tell you that she sold her body 3 A Yes, sir. 3 for sex? 4 Q And that oath is for you to tell the truth? 4 A No. 5 A Yes. 5 Q Back when you were 14 to 17, who did Jane Doe 6 Q So I'm going to ask you a question. I want 6 live with? 7 you to take some time and think about this question. 7 A 8 Q And where was her to your knowledge, 8 As you sit here today, having known Jane Doe 9 from the time that you were 13 up until todays date, 9 at this time period? 10 other than the two arrests that we have just discussed, 10 A At her house. 11 are you aware and do you recall any other arrests? 11 Q When you say "her house" do you mean the 12 A No, sir. 12 house or a separate home? 13 Q Ares= whether or not Jane Doe ever 13 A No. A separate home. 14 Q Why did lime Doe and her live apart? 14 worked at 15 A Yes. 15 A They have never got along. I'm not sure the 16 Q Whs' arc you aware of that she 16 reason why they — she left but they have never got 17 wonted at? 17 along, basically. 18 A 18 Do you know whether or not Jane Doe has a. 19 Q What others? 19 20 A I don't Icnow. 20. A No. 21 Q Do you know whether or not is 21 S . But you are aware that there were other". 22 but you don't know the names; is that correct? 22 married? 23 A I think one other one but J don't know the 23 A Oh, wait. Yes. I don't know if she's married name. • 24 but it's a guy named if I'm correct with the name. 24 Okay. Do pan,knotv whether not fr2i la 7:e tu 25 Q Okay. Did Jane Doe tell you that she gave men 25 9 13 (Pages 46 to 49' PROSE COURT REPORTING AGENCY, INC. a53d0950-b535-414d-8118-6434195ac559 Electronically signed by Michelle Baden IMES EFTA00724287 Page 50 Page 52 1 Doe had a relationship, good relationship? 1 we were like 14, 15 and — yeah. 2 A 1 dolt think they got along either. 2 Q Hold on one second, please. 3 Q Do you know why? 3 I want to backtrack a little bit We talked 4 A No. I think he was just a mean guy. 4 about Mr. and Mr. and we talked about 5. Q Did he ever do anything mean to Jane Doe? 5 and we talked about 6 MR- EDWARDS: Object to the form. 6 A Uh-huh. 7 BY MR. PIKE: 7 Q Having discussed them today, are you aware of 8 Q You said he was a mean guy, so I just want to 8 anyone else that she's dated? 9 know did he ever do anything mean to Jane Doe, to your 9 A Off the top of my head, 1can't think of 10 knowledge? 10 anybody right now. I'm thinking but she was with -- 11 A No. Maybe just be an ass. Sorry for my 11 yeah, I think after yeah, after she was still 12 12 dating him when I moved to language. 13 Q Have you ever witnessed any altercations 13 Q And do you know whether or not Mr. was 14 beriveen Jane Doe and her mother -- 14 verbally and physically abusive to her? • 15 A No. 15 A I don't know. 16 Q -- between the ages of 13 and 17? 16 MR. EDWARDS: Objection; form. 17 A No. 17 BY MR. PIKE: 18 Q Do you know whether or not Jane Doe ever 18 Q You don't know? 19 kick 19 A I don't ;mow. 20 A No. 20 Q Do you know whether or not Jane Doe has ever 21 Have u ever seen Jane Doe physically hurt 21 tried cocaine? 22 22 A I third( -- yeah. 23 A No. 23 Q Do you know whether or not she's ever tried 24 Have ou ever seen Jane Doe physically touch 24 Ecstasy? 25. in an aperessive manner? 25 A Yes. Page 51 Page 53 1 A No. 1 Q Do you know whether or not she's ever tried 2 Have ou ever known Jane Doe to do drugs in 2 pain pills? 3 home? 3 A No. 4 A No. 4 Q Do you Imow whether or not she's ever tried 5 Q As you sit here today, your testimony is that 5 methamphetamines? 6 do not know that Jane Doe has ever done drugs in her 6 A No. 7 home? 7 Q How do yoti know she tried cocaine? 8 A Well, marijuana And that was when we were 8 . A She told me. 9 like 15 no, not even 15. 14, 13. 9 Q How many tines? 10 Q How many times? 10 A I'm not sure. Maybe a couple. 1 don't loww. 11 A I don't know. More than once. Like four 11 We were young. I don't know. 12 times, couple times. 12 Q Do you know how many times she tried Ecstacy? 13 Q And who was with you guys at the time you were 13 -A I don't blow. 14 doing marijuana? That is, who else was doing it with 14 Q Were you with her when she tried Ecstacy? 15 you, if anyone? 15 A Yeah. 16 A It was just us. 16 Q All right. Where were you guys? 17 Q And back in those days, where would you 17 A Well, we were hanging outside and then we went 18 purchase the marijuana? 18 to my house. 19 A I don't !mow. She gait. 19 Q So you guys were doing Ecstacy outside and at 20 Q Do you have any idea where she got it from? 20 your house? 21 A • No. We would just hang out after school. 21 A Yeah. 22 Q Do you know whether or not 22 Q How many times did you do Ecstacy with her? 23 did not want her around because she worked at 23 A . A couple. 24 and did drugs? 24 Q Did you guys ever go to any raves? .5 A No. When -- last time I even heard about 25 A No. (....•••443•Jdnesaryi4a.an iarl 14 (Pages 50 to 53) 'PROSE COURT REPORTING AGENCY, INC: Electronically signed by Michelle Baden a aS3d0950-b535-414d-M184434195acE59 EFTA00724288 Page 54 Page 56 1 Q Do you know where What 1 Q Where did you do Etstacy? 2 I mean by that is state and county or just the county? 2. A We would take it and then we would go inside 3 and hide from my mother. 3 A I just know 4 Q Did you purchase the Ecstacy? 4 Do you know how old Jane Doe was at the time 5 A No. 5 she 6 Q Who got the Ecstacy for you? 6 A Younger than 7 A I'm not even sure. 7 Q Did she ever discuss that with ou? 8 Q Did Jane Doe get it? 8 A She said she woke up and 9 A I don't know. Maybe. I don't know how we got and that's all I know. 10 it. 10 Q Do you know whether or not that was 11 Q Do you know whether or not Jane Doe has ever 11 psychologically impacting for her? 12 done acid? 12 MR. EDWARDS: Object to form. 13 A I don't think so. 13 THE WITNESS: Probably. 14 Q Do you ;mow whether or not Jane Does 14 BY Mt. PIKE: 15 was a serious user? 15 Q And, once again, I'm just going to ask the 16 A I heard. did drugs. 16 question. Did she ever discuss the incident with you at 17 MR. EDWARDS: Form. 17 all? 18 BY MR. PIKE: 18 A Yeah. 19 Q Let me rephrase thesestion. Do you know 19 Q And what did she discuss with youseparate and 20 m telling you that she woke up an' 20 21 22 whether or not Jane Doe's... ever did drugs? A Yeah. Q What do you know about that? 21 22 ai there? A Oh, well that's it. She said she woke up and 23 A I think Jane Doe said■ 23 there was MEN 24 0 Do you know for how ion 24 and said "Oh, m osh, look" or something and she looked 25 25 up and sass Page 55 Page 57 1 A I'm not sure. 1 Q Is that it? 2 Q What is her name? 2 A Yes, sir. 3 Oh, my gosh, leaf* even think of it right 3 Q Let me ask you this question. Did she ever 4 now. 4 tell you that 5 5 and that her was Q Is itelliffM? 6 A Yes. 6 becoming angry as a result of that? 7 Q Do you know whether or not Jane Doe was ever 7 A No. 8 forcibly taken from her home by her 8 Sr Did Jane Doe ever tell ou that she saw that 9 A I have no idea. 9 was not that evening and that 10 Q Did you know whether or not her mother and her 10 she went to he tell him the 11 father had several physical fights in front of Jane Doe? 11 same? 12 A No. 12 A No. 13 Do ou know whether or not there was any 13 Q Did Jane Doe ever discuss with you the to 14 n Jane Doe's home? 14 statement that she gave to n or around ME 15 A No, I don't know. 15 A No, sir. 16 Q Do you know whether or not there was ever an 16 Q Do you know whether or not Jane Doe ever 17 incident back in where or Jane Doe threatened 17 testified that helIMIMIMIIMI 18 to, quote, that 18 A I know she testified but I have no idea what 19 she currently lived in? 19 happened. 20 Do ou know whether or not her ever 20 A No, I have no idea. 21 Do ou know Jane Doe's name? 21 laxly? 22 A 22 A No. I don't know. 23 Q And as his 23 Did Jane Doe ever tell you that her 24 24 '7 25 A I believe so. 25 A No. 15 (Pages 54 to 57) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle BadenMlle a53d0950-b535-414d-8f18-6434195ac559 EFTA00724289 Page 58 Page 60 1 Q You testified earlier that you know of the 1 A No, sir. 2 name Jeffrey Epstein, correct? 2 Q Did she seem happy about receiving the money? 3 A Yes. 3 A I don't know. I don't even think i was there 4 Q And do you know whether or not Jane Doe had 4 when — she wasn't even around when she got the money. 5 any dealings with Mr. Epstein? 5 I have never even physically seen money. 6 A Yeah. 6 • Q Did she ever seem upset about going 7 Q And what are you aware of? 7 Mr. Epstein's home? 8 A I'm aware that she went to his house by taxi 8 A Well, she wasn't with me when she went. She 9 and went there and massaged him naked for money. 9 just told me, so I wasn't even around her. 10 Q And when you say she was naked, can you 10 Q When she told you, did she seem upset? 11 explain that for me? And what I mean is did she have 11 A Maybe a little, but I don't know. She just 12 her panties on and her bra off or everything off? 12 told me she went and that's it. 13 A I heard everything. 13 Q Was she crying when she told you this? 14 MR. EDWARDS: Object to the form of the 14 A No. 15 question. 15 Q Did she ever seem emotionally disturbed as a 16 BY MR. PIKE: 16 result of going to Mr. Epstein's home, to your 17 Q Ybu can answer. What do you mean by "naked"? 17 knowledge? 18 A No clothes. 18 A Not to my knowledge. 19 Q What else did she, Jane Doe, tell you about 19 Q Did she seem to be under any emotional 20 having gone to Mr. Epstein's house? 20 distress as a result of going to Mr. Epstein's home? 21 A That there were other girls there and that's 21 MR. EDWARDS: Object to form. 22 it. 22 THE WITNESS: Not to my knowledge. 23 Q Did Jane Doe tell you how many times she went 23 BY MR. PIKE: 24 to Mr. Epstein's home? 24 Q Do you know whether or not Jane Doe attempted 25 A I don't know. All I !mow of is like two 25 to reauit other girls to allegedly go to Mr. Epstein's Page 59 Page 1 times, three times. 1 home? 2 Q And other than giving him a massage, did Jane 2 A She asked me and that is all I 'mow. 3 Doe say she would do anything else for Mr. Epstein? 3 Q And at that time you were her best friend, 4 A No, sir. 4 correct? 5 MR. EDWARDS: Object to the form. 5 A Correct 6 THE WITNESS: No, sir. 6 Q And what did you say when she asked you to go 7 BY MR. PIKE: 7 to Mr. Epstein's home. 8 Q Did Jane Doe ever tell you that Mr. Epstein 8 A Absolutely not. 9 forced her to do anything inappropriate? 9 Q Okay. And why did you make that decision? 10 A No, sir. 10 A Because I would never do that or put myself in 11 MR. EDWARDS: Object to the form. 11 a position to do anything like that. 12 MR. PIKE: You didn't like that answer, did 12 Q Did she tell you what she did for Mr. Epstein 13 you, Brad? 13 when she made this offer for you to go to his home? 14 MR. EDWARDS: I didn't like your question. 14 A .Yeah, I Ian the circumstances. 15 BY MR. PIKE: 15 Q Explain to me how you understood the 16 Q Did Jane Doe ever all you that Mr. Epstein 16 circumstances at that time? 17 forced her to do anything? 17 A Well, she told me she would massage him naked 18 A No. 18 and I said, "Pm never going. 1 would never do that" 19 Q Did Jane Doe tell you that she gave 19 Q Did she ever say that she touched his penis? 20 Mr. Epstein a massage in exchange for money? 20 A No. 21 A Yes. 21 Q And where would she massage him, to your 22 Q What did she tell you, just that? 22 knowledge? 23 A Yes. 23 A In atom. 24 Q Do you know how much she claims Mr. Epstein 24 Q Ina room? 25 gave you? 25 A Yeah. ?1,1UNSOAEAredites.... .....00,4•4•4 16 (Pages 58 to 61) PROSE COURT REPORTING AGENCY, INC. a53d0250-b535-414d-M18-6434195ac559 Electronically signed by Michelle Baden MIMI EFTA00724290 Page 62 Page 64 1 Q What body parts did she touch, to your 1 Q You can answer the miestion, if you recall. 2 knovdedge, if at all? 2 A I don't know about every day. I don't !mow 3 A I don't know if she touched anything. I don't 3 about every day. 4 know anything like that 4 Q What about every other day, do you have any 5 Q So, to your knowledge, the massage was just a 5 knowledge as to that? 6 regular massage but naked? 6 A No. 7 A Yes. To my knowledge, yes. 7 Q Have you ever done cocaine with Jane Doe? 8 Q Do you know whether or not Mr. Epstein ever 8 A Yes. 9 touched her in a sexual nature? 9 Q And where did you do cocaine with Jane Doe 10 A I have no idea. 10 venue-wise? Where was the location? 11 Q Did she ever tell you that Mr. Epstein 11. A My house hiding from my mother. 12 masturbated during any one of these alleged massages? 12 Q And did ou ever do cocaine with Jane Doe at 13. A Yes. 13 Jane Doe's house? 14 Q What did she tell you? 14 A No, sir. 15 A She said he masturbated while she massaged him 15 Q How many times did you do cocaine with Jane 16 or something. 16 Doe? 17 Q And when she told you this, was she laughing? 17 A I don't know. More than once. 18 A No. 18 Q More than five times? 19 Q Was she crying? 19 A No. She stopped. She didn't like it anymore. 20 A No. 20 Q After she stopped using cocaine, what other 21 Q Did she seem depressed? 21 drugs, if any, did she continue to use? 22 A No. 22 A I don't think any. Just marijuana, I think, 23 Q How much money did she tell you she received 23 if that 24 as a result of this massage? 24 Q Did she ever tell you that Mr. Epstein 25 A She never told me money amount. 25 threatened or intimidated her for any reason? Page 63 Page 65 1 Q So when she told you that she would give 1 A No, sir. 2 Mr. Epstein a massage naked and she invited you to come 2 Q Did she ever tell you that Mr. Epstein forced 3 with her, she didn't tell you how much money you could 3 her to anything? do 4 make? 4 A No. 5 A No, because I basically wanted to end the 5 Q When she discussed having you potentially come 6 conversation because I don't want to hear about that. 6 over to Mr. Epstein's home, did she tell you you would 7 Q Do you know whether or not Jane Doe recruited 7 have to lie about your age? 8 any other girls? 8 A No. 9 A I don't know. 9 Q Did she discuss anything about your quote, 10 Q Do you know whether or not Jane Doe and 10 age? 11 worked at the same 11 A No. 12 A I don't know. 12 Q Do you know whether or not Jane Doe was seeing 13 Q Do you know whether or not Jane Doe's drug use 13 a psychologist or a counselor between the ages Aland 14 affected her memory? 14 today's date? 15 A I don't blow. 15 A Maybe a counselor, but I don't know. 16 Q I'll have ou assume that Jane Doe testified 16 Q Have you ever heard the tenn 17 that sh un an every-day basis. Does that 17. 18 refresh our recollection as to whether or not Jane Doe 18 A Yes. 19 n an every-day basis? 19 Q How did you come to learn about that term? 20 MR. EDWARDS: Object to the form as it 20 A TV, just learning it. 21 completely mischaracterizes the witness' testimony. 21 Qail ane mm Doe ever tell i out that she suffered 22 If this witness Is going to be basing her answer on 22 froci 23 a hypothetical then Pm going to object to all of 23 A No. 24 those questions. 24 Q Did Jane Doe ever tell you that she had any .5 BY MR. PIKE: 25 emotional disorders? 17 (Pages 62 to 65) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle BadenIMIEM aS3d0950-b535-414d-8118-6434195ac559 EFTA00724291 Page 66 Page 68 1 A No. 1 to Mr. Epstein's home? Q Did Jane Doe ever tell you that she had any 2 A No, sir. 3 emotional problems? 3 Q Give me one second. When was the last time 4 A I mean, her life has been crazy. Her whole 4 you talked to Jane Doe? 5 life, so 5 A Last time I talked to her is when sant. that, if you could be 6 came to serve me these papers and I was i and 6 Q And what do you mean by a little more specific? 7 I called her and I asked why they were giving me papers. 8 A I mean, *ust her i growiad then the stuff 8 Q And what did she tell you? with oing on and has nothing to do 9 A She told me because I was her friend and they 10 with her. The only person that cares for her is her 10 wanted to ask me questions. 11 =I, so, I don't know. 11 Q Have you ever been contacted by any 12 Q Have you 'mown Jane Doe since you were. 12 investigators to discuss this matter? 13 A Yes. 13 A No, sir. 14 Q Did you see any emotional change or emotional 14 - Q Have you been contacted by any lawyers at any 15 • distress after you learned that Jane Doe was going to 15 time to discuss this matter? 16 Mr. Epatein's home? 16 A No. 17 A No. 17 Q Has Mr. Edwards ever talked with you over the 18 Q Do you know whether or not Jane Doe worked at 18 phone or in person? 19 19 A No. 20 A I believe she might have mentioned that one, 20 Q Has anyone by the name of Stuart Mermelstein, 21 theMMIIM kind of rings a bell but I'm not sure. 21 Adam Horowitz or Jessica Arbor (phonetic) ever talked to 22 .1.3o you know whether or not she ever worked at 22 you over the phone or face to face? 23 23 A No. 24 A I have no idea. 24 Q Tell me exactly — understanding that you're 25 Q What about 25 under oath, tell me exactly, ma'am, what Jane Doe talked Page 67 Page 69 1 A I have no idea. 1 with you about relative to this case at any time? 2 Q What abo 2 A Okay. She told me she would get in a cab and 3 A No idea. The only one I ;mow is liken 3 go to Palm Beach. There would be other girls at the 4 4 house, and she would go in a room and massage him naked 5 Q Do you know whether or not Jane Doe's uncle 5 and he would give her money and she would leave. And 6 took her to Mr. Epstein's home? 6 that's all 1 know. 7 A I have no idea. 7 Q Did she tell you that she filed a lawsuit 8 Q You said that you learned that Jane Doe went 8 against Mr. Epstein? 9 to Mr. Epstein's home by cab? 9 A Yes. 10 A Yes. 10 Q What did she tell you about that? 11 Q How did you learn that? 11 A That's it. Just ended it right there at that. 12 A She told me. 12 Q Did she tell you that she wanted to file a 13 Q And did she tell you how many times she went 13 lawsuit or that she was convinced by lawyers to file a 14 to Mr. Epstein's home by cab? 14 lawsuit? 15. A No, sir. 15 A She just said there was a lawsuit and that's 16 Q Do you know whether or not it was ever 16 all! know. Like I haven't talk to her. 17 to the police that Jane Doe 17 Q Have you talked to anyone, other than Jane Doe 18 18 about this lawsuit? 19 Does that refresh your recollection? 19 A I briefly scanned over to my family but not 20 A I have no idea. 20 giving details, just because they asked why I was 21 Do you know whether or not Jane Doe was ever 21 getting served papers. 22 22 Q Let's talk about you for a minute. Have you 23 A No. 23 ever been arrested? 24 Q Other than the individuals we've discussed 24 A No, sir. 15 today, are you aware of anyone else that allegedly went 25 Q Have you ever been charged with a crime? 18 (Pages 66 to 69, PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden a aS3d0950-b5354f4d-8118-6434195ac559 EFTA00724292 Page 70 Page 72 1 A No. 1 I was liken and I haven't talked to her probably 2 Q Have you ever been detained by a police 2 since then. 3 officer? 3 Did ou talk with her at all while she was in 4 A No, sir. 4 5 Q Have you ever worked at any strip clubs? 5 A No. 6 Q Do you know whether or not does drugs or 6 A No. 7 Q What about jack shacks? 7 not? 8 A No. 8 A I have no idea. • 9 Q Have you ever sold your body for sex? 9 Q When is the last time you s eke to her? 10 A Probabl when I w lik Maybe like 10 A No. Q Has anyone offered you any money in this case 11 see her be like 11 "Hp, 12 relative to your testimony today? 12 13 A No. Well, I have a $45 witness fee. That's 13 Q What reputation, if any, do you recall her 14 it. 14 having in middle school? 15 Q Thank you. 15 A 'don't know. She was a good kid. 16 A I just looked over to that. 16 Q Do you recall any ofher boyfriends in middle 17 Q When you spoke to Jane Doe 6, did Jane Doe 6 17 school? 18 tell you that she was assaulted or humiliated by 18 A No. 19 Jeffrey Epstein? 19 Q Do you know whether or not she had intercourse 20 MR. MERMELSTEIN: Objection to form. 20 while she was in middle school? 21 THE WITNESS: No. 21 A I have no idea. 22 BY MR. PIKE: 22 Q Okay. I have no further questions. 23 Q Did she ever tell you that? 23 MR. EDWARDS: All right. I have a few. 24 A Na 24 EXAMINATION 25 Q Give me one second. 25 BY MR. EDWARDS: Page 71 Page 73 1 A Okay. 1 Q Melissa, this is Brad Edwards and I represent 2 Q Let me ask you this: What was -- if you 2 Jane Doe and I also reportlill. and.. 3 recall, what was Jane Doe's reputation in high school? 3 A Uh-huh. 4 A She never went to high school with me. 4 Q My question is do you know how many girls 5 Q Do you know what her reputation was though? 5 Jeffrey Epstein has molested? 6 A No. 6 A I have no idea. 7 Q Was she ever referred to as a girl that was 7 MR. PIKE: Object to forth on that. 8 easy to get sex from? 8 Hey, let's do the court reporter a favor. 9 A No. 9 Let's kind of slow down the question and answer so I 10 Q What about Jane Doe 6? 10 can get a "coml." in. 11 A No. 11 MR. EDWARDS: I'll just assume you are going 12 Q What about...? 12 to object to the form of every one of my questions 13 A I don't know. I don't even know her but no, I 13 consistent with form. 14 haven't heard anythirs_. 14 MR. PIKE: I agree, I probably will. If the 15 Q What aboutM., to your knowledge, has her 15 court reporter doesn't hear it, then madam court 16 reputation ever been to be an easy girl? 16 reporter let's put a form objection in there for 17 A No, not when I knew her. 17 each ofhis objections, but twill put one on the 18 Q Tell me about., what do you know about 18 record as well. Okay. 19 her? 19 BY MR. EDWARDS: 20 A Thad no idea she was even in this case, but I 20 Q Melissa, do you know how many underage females 21 with her. 21 that Jeffrey Epstein has performed oral sex on? went t. 22 Q Tell me what you know about her, other than 22 MR. PIKE: Form. 23 23 THE WITNESS: I have no idea. 24 A Absolute nothing. !just know her from 24 BY MR. EDWARDS: 15 . She use to come to my birthdays when 25 Q Do you know whether Jeffrey Epstein has 19 (Pages 70 to 73) PROSE COURT REPORTING AGENCY, INC. a53d0950-b535-4f4d-8f18-6434195ac559 Electronically signed by Michelle Baden =ME) EFTA00724293 Page 74 Page 76 1 engaged in sex with underage transvestites? 1 MR. EDWARDS: This is Brad Edwards. III take 2 A Oh, no idea. 2 a copy. I dent need a mini, ASCII or anything 3 Q Do you know whether that he's made comments to 3 else. I'll take a copy since Mr. Pike ordered it. 4 underage transvestite in the course of sexual 4 MR. MERMELSTEIN: This is Stuart Mermelstein. 5 interaction such as, 'I love how young you are. You 5 I'm not going to order at the present time. 6 have a tight butt like a baby"? 6 Thank you. 7 MR. PIKE: Fenn. 7 (At 10:59 am. no further questions were 8 THE WITNESS: No idea. B propounded to the witness.) 9 BY MR. EDWARDS: 9 10 Q Do you know if Jeffrey Epstein has given or 10 11 received anal sex from men? 11 12 MR. PIKE: Form. 12 13 THE WITNESS: I don't know. 13 14 BY MR. EDWARDS: 14 15 Q Do you know if Jeffrey Epstein has engaged in 15 16 sexual intercourse with underaged females as young as 12 16 17 years old? 17 18 MR. PIKE: Form. 18 19 THE WITNESS: I don't know. 19 20 BY MR. EDWARDS: 20 21 Q All right. Other than the individuals that we 21 22 spoke about today, do you know of any of the names of 22 23 the other young females that have been molested by 23 24 Jeffrey Epstein in the last 20 years? 24 25 MR. PIKE: Form. 25 Page 75 Page 77 1 THE WITNESS: No, sir. 1 CERTIFICATE OF REPORTER 2 MR. EDWARDS: Okay. All right. 1 appreciate 2 3 your tirne. That's all Fve got. 3 STATE OF FLORIDA ) 4 COUNTY OF HIUSBOROUGH) 4 THE WITNESS: Okay. 5 5 MR. MERMELSTEIN: This is Stuart Mermelstein. 6 LIvEchelkOlstmBacWI,RPR,O:11Whalwas 6 1 have no questions. 7 authorized to and did stenographically report the 7 MR. PIKE: Okay. Ma'am, you have the option 8 deposition; that a review of the transcript was not 8 to read your deposition or waive that right. If you 9 requested; and that the foregoing pages are a true and 9 choose to read your deposition, you will be provided 10 complete record of my stenographic notes taken during 10 with a sheet called an errata sheet. You can read 11 said deposition. 11 your deposition and look for corrections that you 12 12 may find that were incorrect, or you can waive that 13 I further certify that I am not a relative, 13 right today if you feel that the testimony you have 14 employee, attorney, or counsel of any of the parties, 14 given today is truthful and you do not want to read 15 nor am 1 a relative or employee of any of the parties' 15 your deposition to make any corrections. 16 attorneys or counsel connected with the action, nor am I 17 financially interested in the action. 16 THE WITNESS: I believe it's truthful but I 18 17 could reread it if — I don't know. I mean, 19 Dated this 24th day of May, 2010. 18 everything I said is truthful but — 20 19 MR. PIKE: It's really your choice. You can 21 20 read it or you can waive that right 22 21 THE WITNESS: I don't know. I'll waive it. 23 22 MR. PIKE: Okay. Thank you very much. Michelle Olsen Baden 23 THE REPORTER: This is the court reporter. 24 Registered Professional Reporter 24 Does anybody need this transcript? Florida Professional Reporter MR. PIKE: Yes. I do, Michael Pike. 25 20 (Pages 74 to 77) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden as3d09504$36-4(4441I18-6434issacs69 EFTA00724294 Page 78 CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF HILLSBOROUGH) 3 4 5 6 I, the undersigned authority, certify that 7 the witness in this matter personally appeared before me 8 and was duly sworn on the 11th day of May, 2010. 9 10 WITNESS my hand and official seal this 24th of 11 May, 2010. 12 13 14 15 16 17 18 19 Nebel's Olsen Baden, R Notary Public 20 State of Florida at Large My Commission Number. DD537984 21. Expires: 6/20/2010 22 23 24 25 21 (Page 78) PROSE COURT REPORTING AGENCY, INC. EJectronically signed by Michelle BadenIMIE=Ib a53d0950-b535-414d-8f18-6434195ac559 EFTA00724295