EFTA00750707

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME I 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 a.m. - 6:10 p.m. 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 (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333.772-1552) 170ae621-3493-40cd-8666.0Do698ca2735 EFTA00750707 Page 4 1 APPEARANCES: 1 2 On Shelf deb* Plaintiff. Jane Doe 2 INDEX 3 BRAD 1. EDWARDS, ESQUIRE 3 ROTHSTEIN ROSENFELDT ADLER Las Dietary Case, Sete 1650 4 WTINESS: DIRECT CROSS REDIRECT RECROSS 401 Es Las Cass Boalceard 5 JANE DOE 5 Mont 33)01 6 BY MR. CRITTON 5 On hLlfof Alley Esidn: ROBERT D.EAMON, At, ESQUIRE BURMAN, CRITTON, LUTHER a COLEMAN.UP EXHIBITS MARKED 9 303 Banyan Hcadevar4 Sake 400 10 , Banda 33401 10 1: DESCRIPTION PAGE 12 Defendant's No. I 12 Ooh of the Defendant. WES'Engel', 13 JACK ALAN GOLDBERGER. ESQUIRE (Copy of Plaintiff)Wimess Identification Card) ATTERBURY. GOLDBERGER & WEISS, PA 13 14 250 Asinlian Mese South Defendant's No. 2 I16 Suite 1400 15 West Aim Bach, Plaids 33401-5012 14 (Victim's Petition) It OnEthan ofPUSHin Added Cu.No. 08-80469. 15 Defendant's No. 3 118 17 iSEDRO M. GARCIA. ESQUIRE GARCIA LAW FIRM. PA (Victim's Motion to Unseal Non-Prosecution Aff u.nt) le 224 Dan Street Stith 900 16 Defendant's No. 4 121 19 C 3340) 17 (Declaration of A. Marie Villafrra) 20 18 On NEN(oflane Does I duo* 8: 19 n (4" Marked off the record.) ADAM D. nortown2, ESQUIRE 20 MERMELSTEIN & HOROWITZ. P.A. 21 11205 Disease Bothnia Suite 2218 elndde 33160 24 24 25 25 Page 3 Page 5 On behalf of the Plaintiff- 1 PROCEEDINOS JACK P. MI, ESQUIRE 2 --- SEARCYDENNEY SCAROIA BARNHART & SHIPLEY, P.A. 3 Deposition taken before Pamela J. Sullivan, 3 2139 Palm Beach Lakes Boulevard :ach, Florida 33409 4 Registered Professional Court Reporter and Notary Public 4 5 in and for the State of Florida at Large, in the above 6 cause. 5 On behalf of the B.B.: 7 6 ADAM J. LAWN°, ESQUIRE LEOPOLD KUVIN (Discussion held off the record.) 2925 PGA Boulevard, Suite 200 9 MR. CRITTON: Let's get started. dens, Florida 33410 10 MR. EDWARDS: Brad Edwards, and I represent 8 11 Jane Doe. ' 9 12 MR. HILL: Jack Hill, on behalf (AM. 10 13 MR. HOROWITZ: Adam Horowitz, on behalf of 11 ALSO PRESENT: 14 Jane Does 2 through 8. 12 Jeffrey Epstein, via video conference Stan Sanders, Vidoograpber 15 MR. LANGINO: Adam Langino, on behalf of B.B. 13 16 MR. CRITTON: Bob Critton, on behalf of 14 17 Jeffrey Epstein. 15 18 MR EDWARDS: And, Mr. Critton, I don't think 16 17 19 we've had this Cant Reporter before, so maybe we 18 20 want to instruct as to how we're dealing with the 19 21 names, how they're going to be typed up. 20 21 22 MR. CRC-TON: Pamela, are you familiar with how Cindy did the names at all? 24 COURT REPORTER: Let's go over it. 24 25 MR. CRITTON: All right. What we -- what 25 2 (Pages 2 to 5) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) fleae621-3493-40cd-8666-000698ca2735 Electronically signed by Pamela Sullivan (501.333-772-1552) EFTA00750708 Page 6 Page 8 1 we've done in the past is, as with regard to anyone 1 trat 2 who's identified as a Plaintiff in the case, and 2 i t, you claimed all sorts of privileges 3 only that group, you know, absent some other 3 and, and other objections and instructed her not to 4 agreement amongst the, the clients or the parties 4 answer. Obviously, the judge has to consider a 5 and their attorneys is, is we will refer to them by 5 transcript. 6 initials only, such as Jane Doe, who's seated in 6 MR. EDWARDS: Agreed. 7 front of us. She will be — well, except she's 7 MR. CRITTON: So I would say as to the 8 gone as lane Doe, so we should keep her as Jam B transcript, no, and with the transcript that Pamela 9 Doe. So much for that ewertion, but... 9 is going to prepare, it's going to have — it won't 10 And Mr. Hill's ellen ., will be 10 disclose Jane Doe's name or Jane Doe's name. All 11 referred to as , because that's how 11 right. So with regard to the video, as' — as 1 12 we referred to her, and she has -- she gave up 12 indicated to you to the extent that the video would 13 anonymity. 13 be necessary to be filed for any purpose or to use 14 Jane Doe's 2 through 8, we may use their real 14 for any purpose, you have 15 days to file 15 names, and then we'll just use, if it's 15 something. lf, in fact, the video was used, I 16 Sally Jones, it would be S.J. And then what you do 16 would do that which was necessary so that 17 is, is on a separate piece of paper, as Cindy did, 17 Jane Doe's face would not be disclosed, so that no 18 you will give us a key that ties in with any name 18 one could identify her. 19 that we've designated by a first or a last name — 19 MR. EDWARDS: Okay. Well, I — if you're 20 or both. 20 only talking about blocking out her face as the 21 MR. EDWARDS: All right. And one other thing 21 only way to protect her anonymity, we, we wouldn't 22 I want to — I want to put on the record, I know 22 feel that that would be accommodating enough to, to that you disagreed last time, but I think that 23 secure her anonymity. 24 it's, to make the record clear, we feel strongly 24 But now I'm understanding that you're saying 25 that this deposition and the transcript and the 25 you may file this with the court, which I have much I Page 7 Page 9 1 video remain confidential, and that the witness's 1 less a problem with than you posting it on the 2 anonymity is protected, absent some court order 2 Internet or using some other device to post it to 3 directing otherwise, as we feel that's consistent 3 the public, which is what was implied last time. 1 with the court orders that have already been 4 And I think the example you gave was that another s entered, as well as the instructions of the various attorney has posted your client's deposition on the 6 judges presiding over these cases. 6 Internet. 7 I'm assuming, if you are in disagreement of MR. CRITTON: All right. Let, let's deal 8 that, then you will allow me 15 days to file a 8 exactly what the issue is. If Spencer Kuvin, for 9 motion in that regard, if you think that's publicity, and for no other reason, contacted 10 necessary. 10 Jose A. Lambiet, who in turn then put it on his 11 MR. CRITTON: Yeah. Well we, we had this 11 website so that everyone could view the question, 12 discussion at the deposition of.l. 12 and he did it to embarrass, to humiliate, it was 13 MR. EDWARDS: Right. 13 improper, it was inappropriate, I hope I wouldn't 14 MR. CR1TTON: And you dealt specifically with 14 use the same conduct or what I would say lack 15 the video, not the transcript, is my recollection. 15 of professionalis to do something like that. m 16 And I said it, with regard to the video, there's — 16 MR. EDWARDS: Well, but, obviously, the 17 there are orders granting your client, and in her 17 difference is Mr. Epstein's anonymity has not been 18 case., and I think in Jane Doe, anonymity. And 18 protected in this case, and these victims have. 19 as such, we don't plan to violate that court enter 19 So... 20 to the extent that the transcript -- and a perfect 20 MR. CRITTON: So it's okay to humiliate and 21 mantS of it is, is, if you think that the — that 21 embarrass someone and to be unprofessional? 22 theM. transcript can't be filed, it's absurd, 22 MR EDWARDS: This has nothing to do with me 23 because.. claimed the Fifth Amendment about 30 or my clients. 24 to 50 times. So in order to get some ruling from 24 MR. CRITTON: All right. 25 the Court, the Court's going to have to look at the 25 1/4 MR. EDWARDS: So arc we noon the same page, AaiGIVaSnes%)4.0..sstnr.M.. A 3 (Pages 6 to 9) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Beetronlcally signed by Pamela Sullivan (601-333-772-1552) I reae621-3493-40cd-8666-00.3698Ca2136 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00750709 Page 10 Page 12 1 and I need to file a motion to protect the 1 Q. At the address where you're currently 2 confidentiali ty of the video and the deposition 2 residing, does anyone live with you? 3 transcript, or do you agree that it's - it should 3 A. Yes. 4 remain confidential, but for whatever motions you 4 Q. Who? 5 have to file and attachments you have to make to 5 A. My daughter and my boyfriend. 6 the court file. 6 Q. Are you living in an apartment, a house? 7 MR. CRITION: You, you need to file whatever 7 What kind of accommodations? 8 motion you think is appropriate. Pm going to do 8 A. A house. 9 nothing to breach the anonymity order that has been 9 Q. What city is the house located in? 10 entered by the Court. So if you if you think 10 MR. EDWARDS: Don't answer. 11 that some additional order is necessary, you have 11 She's not going to answer any other questions 12 15 days to file something with the Court, and then 12 about the location of her address or the location 13 I'll respond to it, Brad. 13 where she's residing, just out of fear for her own 14 MR. EDWARDS: Okay. Thanks. 14 safety and the safety of her daughter. 15 MR. CRITIC/14: Okay. 15 MR. CRJTTON: Okay. 16 And Sid Garcia showed up. 16 BY MR. CRITTON: 17 MR. GOLDBERGER: What am I? 17 Q. Ma'am, has, has anything occurred since 18 MR. CRITTON: And Jack Goldberger, too. 18 you've been represented by Mr. Edwards that causes you 19 Sony, you're not just a potted plant here. 19 concern about your safety or well-being? 20 Thereupon, 20 A. Yes. 21 JANE DOE, 21 Q. What? 22 Having been first duly sworn or affirmed, was examined 22 A. I have seen a lot of cars passing by my and testified as follows: house, watching, looldng at my house, and going by very 24 THE WITNESS: Yes. 24 slowly, several times a day. There have been cars that 25 25 were parked across the street from my house on several Page 11 Page 13 1 DIRECT EXAMINATION 1 different occasions, cars that I had never seen before. 2 BY MR CRITTON: 2 There have been people who have gone to speak to my 3 Q. Would you please tell us your full name, 3 friends and my family members and ask them questions 4 please. 4 about me. 5 A. Jane Doe. 5 Q. So why — why — well, let's start with the 6 Q. And you're going to need to speak up, ma'am, 6 cars. On how many occasions since you well, on how 7 because I could barely hear you. All right 7 many occasions have you seen what you thought were 8 A. Jane Doe. B suspicious cars, as distinct from just like — as 9 Q. What's date of birth? 9 distinct from just cars driving by? 10 A. 10 A. Them have been so many, I can't — I can't 11 Q. And where do you currently reside? 11 count 12 MR. CRITTON: Don't answer. 12 Q. Can you identity any of those suspicious 13 She's not going to give her current address, 13 cars? Color? Make? Model? 14 and it's out of fear for her safety. And that's 14 A. For one, there is a blue Durango SUV that 15 the only question you're likely not going to get an 15 comes by a lot 1,1have taken pictures of it. I have 16 answer to today. 16 taken pictures of all the cars. 17 BY MR. CR/77ON: 17 Q. Oh, you have? And where, where are those 18 Q. Let me ask you this: Do ou 18 pictures? Did you take them on a digital camera? 19 nssidecl over the years at 19 A. Yes. 20 EIR true? 20 Q. Okay. And what did you do with those 21 A. Yes. 21 pictures? 22 Q. All t. And whose address is that? 22 A. I sent them to Brad. 23 A. 23 Q. And Brad, Mr. Edwards? 24 Q. And her name is? 24 A Yes. 25 A. 25 Q. Are you aware whether he's filed any motion 4 (Pages 10 to 13; (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (563) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1552) ffeae621-3493-40“1-8666-00e698ca2735 Electronically signed by Pamela Sullivan (501-333-772-1652) EFTA00750710 Page 14 Page 16 1 with the Court to try to identify who, to keep those 1 talked to families and friends, where they have — let 2 cars away from you? 2 me strike that. 3 A. Not that I'm aware of. 3 You indicated various individuals had done -- 4 Q. Okay. How many pictures have you taken? 4 had talked or had spoken with family and friends about 5 A. Four or five. 5 you -- 6 Q. And, and in terms of parked cars, have you 6 A. Yes. 7 taken pictures of any of the parked cars? 7 Q. correct? 8 A. One. 8 All right Tell me which family members have 9 Q. What was that car? Was that the blue 9 been contacted and asked questions about you. 10 Durango? 10 A. The only one that I really !mow of is my 11 A. No. It was a silver — Pm not sure what 11 sister. 12 kind of car it was. 12 Q. And who's that? 13 Q. Okay. Do you still have -- do you still have 13 A. your photographs of those cars on your camera? 14 Q. And what did tell you? 14 15 A. Not on my camera. 15 A. She just told me that me some people went to 16 Q. Did you take — how did you send them to 16 her house and asked her some questions about me. 17 Mr. Edwards? 17 Q. When did tell you that? 18 A. I have them on a disk. 18 A. lint not sure how long ago it was. She 19 Q. All right. And tell us — tell the members 19 actually sent me a text message. 20 of the jury how many times you've called the police 20 Q. Was it within the last week? Was it in the 21 about this. 21 last month? Was it a year ago? Give me your best 22 A. I haven't called the police, because 22 estimate. 23 they — nobody ever came out and harassed me. I just 23 A. Probably a month, maybe two months. 24 saw the cars passing my. 24 Q. And did she tell you who the people were that 25 Q. All right. So no ones harassed you; no 25 talked to her? Page 15 Page 17 1 one's intimidated you. All you've seen is cars that you 1 A. No. 2 can't identify driving by and/or parking across the 2 Q. Did you ask her? 3 street; is that correct? 3 A. Yes, I did. 4 MR. EDWARDS: Object to the form. 4 Q. And what did she say? 5 MR. CRITION: You can go ahead and answer. A. She said that they worked for 6 MR. EDWARDS: Well, Pm going to object - 6 Jeffrey Epstein. MR. CR1TTON: No, no. 7 Q. And did she say how those people got in 3 MR. EDWARDS: -- and ask her not to answer -- 8 contact with her? 9 MR. CROTON: It's form. 9 A. They went to her house and knocked on het 10 MR. EDWARDS: — if it is attorney-client 10 door. 11 privilege information. Because you're acting like 11 Q. And did she tell you what she said to them? 12 she can't identify than, when, in reality, she may 12 A. No. 13 have been able to identify them. 13 Q. Did she tell you whether she spoke with 14 MR. CRITTON: Is that a form objection? 14 her — spoke with them? 15 MR. EDWARDS: Pm telling her not to answer. 15 A. She said she did talk to them. 16 It's attorney/client information. 16 Q. She did not? 17 MR. COTTON: Would you read my question 17 A. She did. 18 back — 18 Q. All right Did she say where — did she talk 19 MR. EDWARDS: (Inaudible) her attorney. 19 to them at the house? 20 MR. CRITTON: -• please. 20 A. Yes. 21 (Whereupon, the requested portion of the 21 Q. And did she — and did you say, well, what 22 record was read aloud by the Court Reporter.) 22 did you say about me? 23 THE WITNESS: Yes. 23 A. Yes, I did. 24 BY MR. CRITTON: 24 Q. Okay. And did you say, what questions did 25 Q. All right. Now, you said some people have 25 they ask? 5 (Pages 14 to 17) (561) 832-750C 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) f7eae821-3493.40cd-8080-00e888ca2735 EFTA00750711 Page 18 Page 20 1 A. Yes, I did. 1 A. Yes. 2 Q. And when you said, what questions did they 2 Q. All right. So we've had nine months in '09. 3 a*, what did she say? 3 Of, of the — of the nine months in 2009, what portion 4 A. She, she said she doesn't really know. I 4 or what months can you • • that you did not have a 5 guess she doesn't remember. She says that she was asked 5 good relationship wi ? have only been on speaking terms with 6 7 8 if she knew about my going to Jeffrey Epstein's house, and she told them that she gave me a ride there before. Q. And was that true? 6 7 milQ. So for the past maybe three months. the past three months, which would be 9 A. Yes. 9 basically June-ish, beginning of June — 10 1Okay. On how many times did your sister, 10 A. Yeah. 11 give you a ride to Jeffrey Epstein's home? 11 Q. — through today, you're on good tents with 12 A. Three, maybe four. 12 her? 13 Q. And I assume you knew that she had driven you 13 A. Yes. 14 to Mr. Epstein's house, separate and apart from her 14 Q. All right. And good terms means you're 15 telling you that the other day, or a month ago. 15 acting like sisters — like I would say more normal 16 A. Excuse me? 16 sisters would, have a nice conversation, you can talk to 17 m liassume you were aware that your sister, 17 her, you're supportive of each of one another, 18 , drove you to Mr. Epstein's house prior to the 18 et cetera? 19 last month or two; is that correct? 19 A. Yes. 20 A. Yeah. 20 Q. All right. Do you have any other sisters? 21 Q. And that is, her telling you that did not 21 A. Yes. 22 refresh your recollection; you knew thatMl. had 22 Q. Okay. First ofalla what's her 23 driven you to Mr. Epstein's home; true? 23 date ma. of 24 A. Yes, I knew that. 24 A. I don't know what year. 25 Q. Okay. Did she say how long she had spoken to 25 Q. How old is she? Page 19 Page 21 1 the people? 1 A. She's six years older than I am. 2 A. No. 2 Q. So do you have another sister? 3 Q. She, meaninga. 3 A. Yes. 4 Did she — other than saying she gave a ride 4 Older or younger? 5 to you to go to Mr. Epstein's house, did she tell the 5 A. Older. Q. her name? 6 7 8 individuals who came to her home anything else? A. Not that I know of. Q. Okay. How long did you — well, let me 6 7 8 A. it Q. How old is-? 9 strike that. 9 A. She is two years older than I am. 10 I alb /lave a good relationship with 10 Q. ow old today? 11 your sister, 11 A. 12 A. It's on and off. We fight often. 12 Q. And 13 Q. Are you on a good relationship with her now? 13 A. She be on 14 A. Right now l aro. 14 Q. She's now. Andes is, you said, was 15 Q. Has that been true for the last six months? 15 how old, how many years — 16 A. No. 16 A. Two years older than me. 17 Q. Okay. Was it. sometime within tiniest 17 Q. So she's.? 18 six months? 18 A. Yes. 19 A. Yeah. 19 Q. All children of the same marriage, with the 20 Q. When was that? 20 same mother and 21 A. Fm not sure exactly how long ago it was. 21 A. My sister., has a different father. 22 I— 22 Q. What's her father's name? 23 Q. Let me — let me rephrase my question. We're 23 A. I don't know. 24 in the year 2009, almost at the end of September 30th 24 Q. Does she know? 25 today. You're aware of that? 25 A. No. 6 (Pages 18 to 21) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) 170a0621-3493.40cd.8666-000698ca2735 Electronically signed by Pamela Sullivan (501.333-772.1662) EFTA00750712 Page 22 Page 24 1 Q. No one knows? 1 A. She does not have a home phone number. 2 A. No. 2 Q. Does she have a cell phone? 3 Q. So your mother -- your mother — obviously, 3 A. Yes. 4 same mother? 4 Q. Do you consider a cell phone a phone number? 5 6 7 a A. Yes. Q. A. And your mother's name is what? 5 6 7 A. Yes, but not her home number. Q. A. allit her cell phone number? 8 Q. Lt name? 8 Q. What's your cell phone number? 9 A. 9 A. My cell phone number? 10 Q. Where does she live? 10 Q. Yes, ma'am. 11 A. I don't }mow her address. 11 MR. EDWARDS: Don't answer. 12 Q. When is the last time you saw her? 12 mean, you're not going to call her, so I'm, 13 A. About a week or so ago. 13 I'm objecting and, and in the witness not 14 Q. :Where did you see her? 14 to give out her cell phone number on the record 15 A. She came to my house. 15 right now. 16 Q. So at least you — you at least told your mom 16 BY MR. CRITfON: 17 where you live? 17 Q. Okay. Why don't you want to — well, you're 18 A. Yeah. 18 going to follow your lawyer's instruction? If he tells 19 Q. All right. Now, what — what's her 19 you not to answer a question, you're going to follow 20 date of 20 that instruction? 21 A. 21 A. Yes. 22 Q. Good relationship with int 22 Q. Okay. And — 23 A. We don't speak on a regular basis, but we are 23 (Discussion held off the record.) 24 nice to each other, I guess. 24 BY MR. CRITTON: 25 Q. Where does she live? 25 Q. How long have you — the current cell phone Page 23 Page 25 1 A. Alabama. 1 that you have now, how long have you had it? 2 Q. Do you know her address? 2 A. About two years. 3 A. No, I do not. 3 Q. Did you have a cell phone before that time? 4 Q. Is she married? 4 A. Yes. 5 A. No. 5 Q. Okay. Bow long did you have that cell phone? 6 Q. Any children? 6 A. I'm not sure. I didn't have it for very long, and I lost it. 7 8 A. Yes. Q. How many? 7 8 9 A. umber? A. Two. 10 Q. And ever been married? 10 Q. Did you ever use a cell phone to call 11 A. No. 11 Mr. Epstein's home? 12 Q. What does she do for a living? How does she 12 A. Yes. 13 support herself? 13 Q. issirt the number you would have 14 A. I — I'm 14 used, the 15 Q. Okay. where does she live? 15 A. No. 16 A. 16 Q. Okay. Did you have a prior cell phone 17 Which is whey o 17 number? 18 A. Ws off of 18 A. Yes. 19 Q. West Palm Beach? 19 Q. All right What was that number? 20 A. Yes. 20 A. I don't remember the full number. I remember 21 Q. Does she live there with anyone? 21 that it started with 352. 22 A. Yes. 22 Q. Was it your own? Was it under your name? Q. Do you know her address, exact address? A. No. 24 A. No. 24 Q. issis it under? 25 Q. Do you know her phone number? 25 A. 7 (Pages 22 to 25) (561) 8 32-7 5 0 0 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772-1652) 17eae621-3493-40cd-8666-00c693ca2735 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00750713 Page S Page 28 1 Q. III..? 1 At some point, Mr. Edwards came to represent 2 A. Yes. 2 you; true? 3 Q. Does she still have that same cell phone? 3 A. Yes. 4 A. NO. 4 Q. All right. And when did Mr. Edwards — when 5 Who was the service provider, her number? 5 did you hire Mr. Edwards to represent you? 6 A. Sprint, i believe. 6 A. Pm not sure exactly what day that was. 7 Who's your service provider right now? Q. Clearly, it was before the lawsuit was filed, 8 A. Metro. 8 which was August 13th; correct? 9 Q. I'm sorry? 9 A. Ulbhult Yeah. 10 A. Metro PCS. 10 Q. All right How many months prior to that 11 Q. Have you used your cell phone is a 11 lawsuit being filed did Mr. Edwards begin to represent 12 friend of yours? 12 you? 13 A. Yes. 13 A. I'm not exactly score. 14 Q. Okay. is a friend of yours? 14 . There was another suit that was filed 15 A. Yes. 15 hair:mit, Jane Doe. It dealt with a claim of, 16 Q. Okay. Are you aware of any other individuals 16 of asserting some sort of victim rights. Were you that 17 who are Plaintiffs in — and are suing Mr. Epstein for 17 Jane Doe? 18 money? 18 A. I don't know. 19 A. No. 19 Q. Okay. Well, are you aware of any other 20 Q. Do you call — do you have a home phone? 20 lawsuit that's been filed — that was ever filed on your 21 A. Yes. 21 behalf, where Mr. Edwards represented you, other than 22 Q. A land line? 22 the current lawsuit, Jane Doe versus Jeffiey Epstein? 23 A. Yes. 23 A. I don't know. 24 All right. I assume you've called bode 24 Q. Okay. So you — you're unaware of any 25 midi.. on your cell phone? 25 lawsuit that Mr. Edwards has ever filed on your behalf; Page 27 Page 29 1 A. Yes. other than Jane Doe versus Jeffrey Epstein; is that 2 Q. All right. And I assume that you talked to 2 correct? 3 them about your cases from time to time; true? 3 A. Well, I would probably be aware, but I'm 4 A. No. 4 obviously not a lawyer, so I don't really know. 5 Q. You so if I ask you is it your testimony, 5 Q. You're — before Mr. Edwards filed your 6 as you sit here today, that since the time you filed the 6 lawsuit here, in this instance, you had to give him 7 lawsuit against MrStein, you have never discussed 7 authority; didn't you? 8 your lawsuit withM.? 8 A. Yeah. 9 A. No. 9 Q. Okay. Have you ever given Mr. Edwards 10 Q. That's not true — that's not correct? 10 authority to fide any other lawsuit anyplace on your 11 A. What is not correct? 11 behalf; yes or no? 12 Q. All right. Listen -- let me ask the question 12 A. I don't know. 3.3 again. 13 Q. Okay. Well, you can't answer that just so 14 Is it a correct statement, that is what Fr() 14 for the jury — ladies and gentlemen of the jury, you 15 going to say, is this true, that since the time you 15 can't answer that question yes or no; is that what 16 filed your lawsuit in August of 2008, you have not 16 you're telling us? 17 discussed your lawsuit with M.; is that correct? 17 MR. EDWARDS: She's not going to answer the 18 A. That is comsat. 18 question because you're asking attorney/client 19 Q. And you've not discussed either your lawsuit 19 privilege information. 20 or any aspect of your lawsuit or your interaction with 20 MR. CRITTON: She's already asked — she 21 Mr. Epstein with.. since August 13th, 2008; is that 21 already answered the question, so you waived the 22 correct? 22 attorney/client privilege. So now — 23 A. Yes. 23 MR. GARCIA: Right 24 Q. All right Since August 13th — well, let me 24 MR. EDWARDS: That's your — that's your 25 strike that. 25 opinion, but she's not going to answer — answer 8 (Pages 26 to 29) (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) fteao621-3493-40cd-8666-000698ca2735 EFTA00750714 Page Page 32 1 any more questions along this line. So — 1 A. Last Thursday. 2 MR. CRITTON: Okay. 2 Q. You say he's at Okaloosa? 3 MR. GARCIA: —you can ask as many questions 3 A. Right now he's in Martin County, but he was 4 as you want. 4 at Okaloosa Prison. 5 MR. CRITTON: She's not your client -- 5 Q. Okay. And he's serving a sentence for having 6 MR GARCIA: That's right. 6 murdered a young boy a true? 7 MR. CRTITON: — all right, Mr. Garcia? 7 A. Yes. 8 She — she — 8 Q. And that occurred when you were how old? 9 MR. GARCIA: You made a misstatement of the 9 A. Twelve. 10 law. You can't waive attorney-client privilege. 10 Q. How long have you had the tattoo, ma'am? 11 MR. CRITTON: Sure, you can. 11 A. Since lives 18. 12 MR- GARCIA: It has to be knowing and 12 Q. Where did you get the tattoo done? 13 intelligence. And she -- she — 13 A. At the 45th Street flea market 14 MR CRITTON: Well, you bow — okay. Is 14 Q. Do you remember the name of the place? 15 your objection as to form? 15 A. No. 16 MR GARCIA: Fm just saying it's a 16 Q. Do you have any other tattoos? 17 misstatement of the law. 17 A. Yes. 18 MR. CRAYON: Fine. Then you can object to 18 Q. Where? 19 form. 19 A. On my legs. 20 BY MR. CRITTON: 20 Q. And what are they of? Are they visible? 21 Q. Have you hired any other lawyers, or at any 21 A. Yes. 22 time did you hire any other lawyers than Mr. Edwards to 22 Q. Okay. Could I see them, please? 23 pursue your claim? 23 A. (Witness standing.) 24 A. No. 24 That's my nephews (indinting). 25 Q. Okay. Do you know a person by the name of 25 Q. Page 31 Page 33 1 Jay Howell? 1 A. That's my other sister's two children, niece 2 A. No. 2 and nephew (nephew). 3 Q. Okay. Ever heard of the name Jay Howell? 3 Q. All right And they — is whose child? 4 A. No. 4 A. 5 Q. Have you authorized him to represent you? Q. And she as one child? 6 A. No. 6 A. Yes. 7 Q. Ms. Jane Doe, I notice you have a tattoo on 7 Q. Okay. And the other tattoos on your left -- 8 around your left ankle are your -- children? 8 your right arm, your right, upper arm; is that correct? 9 A. Yes. 9 A. Yes. 10 Q. And what does it say? 10 Q. All right. When -- when did you receive, or 11 when did you have the tattoo of= ptn on? 11 A. 12 Q. that's what it spells, IME? 12 A. That was my first one, and so l gotragr 13 A. That's what it would spell, but it's actually 13 I named 18. 14 14 Q. Where? Where did you get it? 15 Q. That's 15 A. On my right leg. 16 A. Yes. 16 Q. I'm sorry? 17 Q. When did you -- where does he 17 A. On my right -- 18 currently reside? 18 Q. No, no. 1, !saw that. Where, 19 A. Martin County jail. 19 location-wise, did you have the tattoo put on? 20 Q. And he's serving a sentence there; correct? 20 A. I had tern all done at the same place. 21 A. Urn, actually, he's, urn -- he's down from 21 Q. 45th Street flea market? 22 Okaloosa Prison for a hearing 22 A. Yes. 23 Q. Did you see him when he was here? 23 Q. And where is the 45th Street flea market? 24 A. Yes. 24 A. On 45th Street 25 Q. When did you last see him? 25 Q. . I gathered that, but where? Is it toward 9 (Pages 30 to 33) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-7724662) f7eae621-3493-40cd-8666.00e698ca2735 Electronically signed by Pamela Sullivan (501-333-772-1542) EFTA00750715 Page 34 Page 36 1 'Dail? Is it toward the dump? Is it toward 1 east of the hospital? 2 45th Street toward — toward — toward the east? 2 A. West. 3 A. Um, it's it's west of the hospital. 3 Q. West of the hospital. And it's actually on 4 Q. Pardon? 4 45th Street? 5 A. West of the hospital, St. Mary's, that is 5 A. Yes. 6 also on 45th Street. 6 Q. Okay. Is do you know where the Oalcv/ood 7 Q. All right. Do you know where s? 7 Center is, what used to be the 45th Street Community 8 A. Not exactly. 8 Mental Health Center? s? 9 A. No. 9 Q. Do you know what 10 A. Yes, 'do. 10 Q. Okay. Do you know where Australian Avenue is 11 Q. sin anat s II 11 on 45th Street? 12 A. 12 A. Yes. 13 Q. Okay. Are you aware it's a gentlemen's club? 13 Q. Okay. So the flea market would be between 14 A. Excuse me? 14 Congress and Australian? 15 A. I think it might be before that. I'm not — 15 Q. Are you aware it's a gentlemen's club? 16 I haven't been there in a long time. 16 A. No. I -- 17 Adult entertainment? 17 Q. Okay. When you had the tattoos put on, the 18 A. Yes. 18 three tattoos, two around your ankle and one on your 19 Q. Okay. So in addition to being 19 right, upper arm, were they all put on at the same time? 20 it's also -- it has adult entertainment, with — with 20 A. No. 21 women who take off their clothes, strippers; true? 21 Q. Did they have you fill out a form each time? 22 A. What does that have to do with anything? 22 A. I don't remember. 23 Q. Can you answer my question, yes or no? 23 Q. Okay. Over what period of time did you have 24 A. I, I would guess that that is true, yes. 24 the three tattoos put on? 25 Q. Okay. Well, you're familiar with gentlemen's 25 A. In between 18 and 19. Page 35 Page 37 1 clubs; true? 1 Q. Do you have any other tattoos, other than the 2 A. Yes. 2 tine? 3 Q. Adult entertainmeM? 3 A. No. 4 A. Yes. 4 Q. Were you required to show a form of ID? 5 Q. Becaur you've worked at them; true? 5 A. Yes. 6 A. Yes. 6 Q. All right. Did you show them your driver's 7 so when you said was aMI 7 license? a you also ;mew at the time you answered that 8 A. No. 9 question that it had adult entertainmen t; that is, it 9 Q. What did you show them? 10 was a strip club, as well; true? 10 A. My ID card. 11. A. I have never been to before, so, no, 11 Q. And when you say your ID card, what's an ID 12 I wouldn't know that. 12 card? 13 Q. But you know that from general — fro. 13 A. It's a card with your picture on it and your 14 having been in the buness, so to speak, that 14 O917IC. 15 as well, in addition to serving food, as well, is a 15 Q. All right. And what's it — and where did 16 strip club; true? 16 you get your ID card? 17 A. How would I know that? 17 A. At the MEV. 18 Q MI right. You can tell me you don't know 18 Q. All right So do you have a driver's 19 that. I'm okay with that answer, too. I just want the 19 license? 20 gentlemen — the ladies and gentlemen of the jury to 20 A. No. 21 understand that you — that today is the first time that 21. Q. All right. Have you ever had a driven 22 you learned that actually had adult 22 license? 23 entertainmen t is that correct? 23 A. No. 24 A. Yes. 24 Q. How long have you had a D -- an ID card? 25 Q. All right. 45th Street flea market, so it's 25 A. Since I was 17. 10 (Pages 34 to 37) (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 (501-333-772-1552) 17eae821.3493-40cd-8666-00e898ca2735 EFTA00750716 Page 38 Page 40 1 Q. Do you have the same card now? 1 Where - what adult entertainment establishments have .2 A. Yes. 2 you worked at? 3 Q. Do you have it with you today? 3 A. 4 A. Yes. 4 Q. oPm s 5 Q. Could I see it so we can mark it as an 5 A. 6 exhibit, make a copy and mark it as an exhibit? 6 Q. Where? 7 MR. CRITTON: Go ahead. 7 A. 8 THE WITNESS: (Handing to Mr. Edwards.) B Q. Ali ri t. Where else? 9 BY MR. CRITTON: A. 10 Q. What you've handed me and what we'll mark as 10 Q. Where is that located? 11 Exhibit 1, is that a true and accurate well, is that 11 A. West Palm Beach. 12 the only ID card you've ever had? 12 Q. What's the address forailli? 13 A. Yes. 13' A. I don't know. 14 MR. GOLDBER.Glift It's a duplicate. 14 Q. Do you know what street ifs on? 15 THE WITNESS: Yes, it's a duplicate. 15 A. It's on 16 where is that located in 16 17 18 BY MR. CRTITON: Q. Okay. And why is it a duplicate? So do you have another card, as well? 17 18 •MAnd A. 'think 19 A. No, I lost it 19 Q. During what time 'dad well, let me ask 20 Q. And this obviously doesn't have your current 20 you this: With , were you required to show 21 address on it, because that's the address that you won't 21 the individuals who hired you that you had an adult 22 disclose; correct? 22 entertainment card? 23 A. Yes. 23 A. No. 24 Q. All right. And the 24 Q. Wasn't an adult entertainment card required 25 address is not your current address; correct? 25 at that time? Page 39 Page 4 1. MR. EDWARDS: Objection. She's not going to 1 A. Excuse me? 2 answer the question. 2 Q. Was there a requirement within the County 3 MR. CRITTON: Well — well, we'll get a copy. 3 that you have an adult entertainment card at the time a If you will just leave that out, Ms. Jane Doe, 4 you worked at 5 we're going to make a copy of that, and then well 5 A. I don't know. 6 attach that to the to the deposition. 6 Q. How about-, did they ever require 7 (Whereupon, Mr. Garcia left the proceedings.) 7 WO adult entertainment card? 8 BY MR. CRJTTON: 8 A. No. I only showed ID. 9 Q. Ms. Jane Doe, how many fake ID's have you Q. And Mats the same ID that you have with you 10 had? today that, I assume, is the duplicate, except you have 11 A. Zero. 11 the original? 12 Q. It's your testimony that you've never had a 12 A. Yes. 13 fake ID? 13 Q. Okay. And when did you get your duplicate? 14 A. Yes. 14 A. I'm not sure. 15 Q. Okay. So if there will be witnesses in this 15 Q. All right. Was it within the last six 16 case that will testify that you had a fake ID, they 16 months, within the last year? 17 would be lying; is that true? 17 A. I'm not — I'm not sure where — when I got 18 A. Absolutely. 18 it 19 Q. Have you ever had an adult entertainment 19 Q. I want to go back to a question I asked you 20 card? 20 earlier. I asked you whether you had any 21 A. No. 21 conversations — well, let me strike that. 22 Q But you worked at adult entertainment 22 Now. I asked you when you retained the en , ormr. 24 A. Yes. 24 didn't know. All you know, it was sometime before the 25 Q. Did — did — well, let me ask you this: 25 lawsuit was filed in August, on or about August 13th of 11 (Pages 38 to 41) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1552) fleac621-3403-40cd-8666-000698ca2738 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00750717 Page 42 Page 44 1 2008; correct? 1 A. 2 A. Yes. 2 Q. So people -- you say there were people that 3 Q. Okay. How many months prior to the filing of 3 were going to those houses? 4 the lawsuit had you hired Mr. Edwards? 4 A. People who worked for the FBI. S A. I don't !mow. 5 Q All right So the FBI was corning to your 6 Q. A month? A week? 6 mother's house, your sister's house and your 7 MR.EDWARDS: Objection. Asked and answered. 7 grandmother's house; did you say? 8 BY MR. CRITTON: 8 A. Yes. 9 Q. Two months? Your best estimate. 9 Q. And how did you learn that fact? Fran them? 10 MR. EDWARDS: Object to the form. 10 A. They left cards. They spoke to my family 11 THE WITNESS: I don't know. 11 members who told me about it. 12 BY MR. CRITTON: 12 Q. Okay. Anyone else? That is, other than your 13 Q. Did you hire Mr. Edwards in 2007? 13 grandmother, your mother, -; and your g 14 A. I don't bow what year it was. 14 sister, did the FBI talk to anyone else — 15 Q. Do you know if it was in 2006 that you hired 15 MR. EDWARDS: Object to the form. 16 Mr. Edwards? 16 BY MR. CRITTON: 17 A. I don't know. 17 Q. — that you're aware ot about -- about you? 18 Q. Okay. So you don't know whether you hired 18 A. I don't know. 19 Mr. Edwards in 2006, 2007 or 2008; is that your 19 Q. All you remember is that Ma and NB 20 testimony? 20 your grandmother told you that the FBI had come to their 21 A. Yes. 21 house, asking questions about you — 22 Q. At the time that you hired Mr. Edwards, was 22 A. Yes. 23 he representing either III or IIN? 23 Q. and had left their card? 24 A. I don't —1 don't know. 24 A. Yes. 25 Q. How did you get to Mr. Edwards? 25 Q. Who were the people from the FBI; do you Page 43 Page 45 1 A. I, I got his card somehow. I guess he had 1 know — that were leaving cards? 2 spoken to somebody else and gave them his card, and they 2 A. One of their names was Jason. 3 gave it to me. 3 Q. And — 4 Q. Okay. Who was the person who gave you A. There was a woman, but I don't remember her 5 Mr. Edwards' card? 5 name. 6 A. I don't remember. Were those cards given to you by — 7 Q. 'Ibis is the person who gave you a card for a 7 A. Yes. 8 lawyer, now your lawyer, Mr. Edwards, and you don't 8 Q- — by any of your family members? 9 remember or have any idea who that person was; is that A. Yes. 10 correct? 10 Do you still have them today? 11 A. Yes. 11 A. No. 12 Q. All right. And you don't remember whether 12 What did you do with them? 13 that was in 2006, 2007 or 2008; correct? 13 I don't know. 14 A. Yes. 14 How do you know you don't have them, then? 15 Q. Do you remember whether it was a man or a 15 A. Because I use my wallet often. 16 woman, male or female that gave you the card? 16 All right. And the cards were in your 17 A. No, I don't remember who it was. 17 wallet? 18 Q. Do you remember how they happened to give you 18 A. Yes. 19 the card; that is, what was the event or circumstance 19 Q. Did you — do you remember the timeframe that 20 that caused them to give you the card? 20 the FBI was coming, hying to contact you, that is going 21 A. Um, there were, I guess, people who worked 21. to your family members' houses to contact you? 22 for the FBI who were going to my house and my mother's 22 A. I was pregnant. 23 house and my sister's house, trying to find me, to speak 23 Q. All right. And you have a daughter? 24 tome. 24 A. Yes. 25 Q. Which sister? 25 Q. And what's her name? ya..{.,..,.:¢1 ‘,....,, ,Q•YISI.Com.1 am...... ..,••••3O24.41 : 12 (Pages 42 to 45 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (5a1-333.772.1552) Electronically signed by Pamela Sullivan (501-333-772-1552) thae621-3493-40cd-8666-00e698ca273S EFTA00750718 Page 46 Page 48 1 1 A. Yes. 2 2 Q. An individual who identified herself as an 3 3 FBI, at least on her card? 4 4 A. Yes. 5 5 Q. All right. Did you ever return any of the 6 Q. Bow pregnant were you with the time 6 phone calls to these individuals? 7 that the -- you were hearing from your family members 7 A. Yes, I did. 8 that Jason and some other female FBI agent were 8 Q. At what point in time did you contact them? 9 interested in speaking with you? 9 And just give me that -- well, I think you said — well, 10 A. I heard that they had been there months 10 let me strike that 11 before when I was not pregnant. And when I had actually 11 You said you met with them three and a 12 spoken to them, I was three or four months pregnant -- 12 half you were approximately three and a half months 13 three and a half months pregnant. 13 pregnant at the time; correct? 14 Q. You're sure of that? 14 A. Yes. 15 A. Yes. 15 Q. Okay. And you're sure of that? 16 Q Okay. And how are you sure you were only 16 A. Yes. 17 three and a half months pregnant? 17 Q. AU right. And who did you call; which FBI 18 A. Because I went to a doctor. 18 person did you call? 19 Q. All right. Okay. When when do you 19 A. I don't remember. 20 believe your -- that — that you first became pregnant? 20 Q. Okay. And why did you call the FBI person? 21 Just give me a time that you believe that conception 21 A. I don't know. 22 occurred, I guess, is probably the best way to describe 22 Q. At time that the FBI contacted you, had you 23 it 23 heard anything about anyone contemplating a lawsuit for 24 A. I don't !mow. 24 money damages against Mr. Epstein? 25 Q. All right. Do you know the date that you 25 A. No. Page 47 Page 49 1 met, actually met with FBI individuals? 1 Q. Okay. At the time that you contacted the 2 A. I do not know the exact date. 2 FBI, based on the cards that were given to you, had you 3 Q. Did you meet with the FBI individuals on more 3 spoken with anyone about what you allege occurred at 4 than one occasion? 4 Mr. Epstein's home -- with anyone, anyone from law 5 A. No. S enforcement? 6 Q. Let me just go back. So you heard from 6 A. No. 7 family members that the FBI — certain individuals from 7 Q. Had you ever been contacted by the — by the 8 the FBI, one person being Jason someone, because you had 8 Palm Beach County State Attorney's office? 9 a cant at one point in time, wanted to speak with you, 9 A. I don't /mow. 10 and that was approximately four or five months before 10 Q. Have you ever spoken with anyone from the 11. they ultimately spoke with you? 11 Palm Beach County — Palm Beach County State Attorneys 12 MR. EDWARDS: Form. 12 office? 13 THE WITNESS: Yes. 13 A. I don't know. 14 BY Fat CRITTON: 14 Q. Okay. Well, when I say, spoken with them 15 Q. All right. Did — did your — who -- who 15 about, obviously about your -- similar to the 16 gave you the FBI cards? 16 allegations that you've made in your complaint directed 17 A. and my my mother and my 17 to Mr. Epstein. So what I meant, saying, have you 18 sister. 18 spoken with anybody at the State Attorney's office or 19 Q. fniala 19 anyplace else, I'm interested as to the allegations that 20 A. my mother and my sister. 20 you've raised in this complaint do you understand that? 21 Were all the cards from the same people? 21 A. Yes, I understand that 22 A. No. 22 Q. Have you ever spoken with anyone who 23 There were different cards? 23 represented themselves to be a State Attorney with the 24 A. One was from a woman. 24 Palm Beach County State Attorney's office about 25 But an FBI person? 25 Mr. Epstein? • 13 (Pages 46 to 49) (561) P32-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1562) Electronically signed by Pamela Sullivan (601-333-772-1662) freae621-3493-40ed-B666-00e698ca2735 EFTA00750719 Page 50 Page 52 1 A. Not that I know of. 1 be from the office of the United States Attorney? 2 g Well, you'd know if you spoke with someone — 2 A. No. 'don't — !don't remember if I did or 3 MR. EDWARDS: Object to the form. 3 not. 4 BY MR. CRITTON: 4 Q So the, the individuals, at least 5 Q. -- from the State Attorney's office; wouldn't 5 governmental, • or state or local 6 you? 6 officials, that you've ever discussed any of the 7 A. Excuse me? 7 allegations that you've alleged in your complaint 8 Q. I said, you would !mow if someone said, Pro 8 against Mr. Fprin would have been with the FBI from — Pm Sam Smith from the State -- Palm Beach 9 MR. EDWARDS: Object to the form. 9 10 County State Attorney's office, I want to talk to you. 10 BY MR. CRITTON: 11 You would remember that; wouldn't you? 11 Q — is that correct? 12 MR. EDWARDS: Form. 12 MR. EDWARDS: Fonn. 13 THE WITNESS: There were a lot of people that 13 THE WITNESS: Yes. 14 came to my house, wanting to talk to me. 14 BY MR.. CRITTON: 15 BY MR. CRITTON: 15 Q. Is that correct? I'm sorry. 16 Q. You need to answer my question. Okay? Would 16 A. Yes. 17 you Re it read beck to you? 17 Q. Asa result of the cards that you received, 18 A. I don't remember. 18 did you contact one of those individuals? That is, your 19 Q. Have you ever spoken at any time in your life 19 family gave you cards for the FBI; then you contacted 20 about anything with a State -- the State Attorney or an 20 them? 21 Assistant State Attorney from Palm Beach County about 21 A. Yes. 22 anything? 22 Q. Okay. Had your mother, your sister or your 23 A. I don't know. 23 grandmother told the FBI where you could be found? 24 Q. Okay. Well, you've been in trouble with the 24 A. I don't know. 25 law before; correct? 25 Q. Where were you living at the tine? Page 51 Page 53 1 A. Yes. 1 A. With a friend. 2 Q. Okay. And have you had to deal with State 2 Q. Who? 3 Attorneys under those circumstances? 3 4 MR. EDWARDS: Object to the form. 4 Q. Olcayhiou were living with. at the time. 5 THE WITNESS: I don't know. 5 Where does= reside — or where was she living at 6 BY MR. CR1TTON: 6 that time? 7 Q. The State Attorneys, though, you — you 7 A. 8 understand those are the ones that prosecute you — 8 Q. Address, please? 9 would have prosecuted you; true? 9 A. I don't know the address. 10 A. Yes. 10 Q. What street? 11 Q. All right. Okay. Have you — and it's your 11 A. I don't know the name of the street. 12 testimony you can't remember -- it's — you have no 12 Q. HoW did you know how to get there? 13 recollection of having spoken with anyone from the Palm 13 A. I knew what the neighborhood looked like. 14 Beach County State Attorney's office? 14 Q. Okay. You don't drive a car? 15 A. No, I do not 15 A. No. 16 Q. That's correct. 16 Q. Okay. Have you ever had a car, owned a car? 17 All right. Did you ever speak with anyone 17 A. No. 18 from the Palm Beach Police Department regarding any of 18 Q. Have you ever driven a car? 19 your allegations that are set forth in your complaint 19 A. Yes. 20 directed to Mr. Epstein? 20 Q All right. So you have driven a car, but you 21 A. No. 21 haven't had a license? 22 Q. Did you ever speak with a United States -- 22 A. Yes. 23 well, let me strike that. 23 Q. All right. Do you still drive a car, say 24 Did you ever speak with an assistant attorney 24 over the past year, without a license? 25 or an attorney from -- who represented him or herself to 25 A. No. •••••••10. .1A4 b6 ...Y0J•Wawn w.wwW•sa.C.••• 14 (Pages 50 to 53) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 (561) 832-7500 Electronically signed by Pamela Sullivan (501-333-772-1552) 17eae621-3493.40cd-8668-00e698ca2736 Electronically signed by Pamela Sullivan (601.333-772-1552) EFTA00750720 Page 54 Page 56 1 Q. How would you get around when you were living 1 Q. A few months? 2 with MI? 2 A. Yes. 3 A. She would take me. 3 Q. What does a few months mean you to? Tine or 4 How long -- how long had you been living with 4 four, five, Ethic? 5 — well, let me strike that. S A. About three. 6 On how many occasions have you lived with 6 Q. Did you — and was she -. was she living at 7 7 the same place in =En 8 A. Two. 8 A. No. 9 Q. During what time -- you and have been 9 Q. Where was she living at that time? 10 childhood friends? 10 A. She was living in — I don't remember the 11 A. No. 11 name of the apartments that she lived in. It was in 12 Q. When did you meet s? 12 13 West Palm Beach, though. Q. Was she living with anyone, other than — was 13 A. I believe I was 13 when I met her. 14 Q. Do you bow what l's date of birth is? 14 she living with anyone at the time? 15 A. No, I do not. 15 A. Her boyfriend. 16 Q Do you know what month she is born in, or 16 Q. And his name was? 17 day? 17 A. lb not — I — I don't 'mow who. 18 A. rm not positive, no. 18 Q. I'm sorry? 19 Q. Okay. You and are still best friends; 19 A. I'm not sure who he was. 20 aren't you? 20 Q. Did she have more than one boyfriend living 21 t EDWARDS: Object to the form. 21 with her during the time, those few months that you " el 22 THE WITNESS: No, I have nth spoken to MB 22 living with her, when you had just turned 18? 23 BY MR. CRJTI'ON: 23 A. No, it was none of my business. 24 Q. Okay. Were you best friends at the time you 24 Q. That's not my question. 1 assume that you, 25 were living with het? 25 when you were living there, you were literally living Page 55 Page 57 MR. EDWARDS: Object to the form. 1. there for those few months; correct? 2 TIE WITNESS: No. 2 MR. EDWARDS: Object to the form. 3 BY MR. CRTITON: 3 BY MR. CRITTON: 4 Q. Was M. charging you rent? 4 Q. You were staying there, sleeping overnight? 5 A. No. 5 A. Yes. 6 Q. So you've knownIE. since 13. During what 6 Q. Okay. So if she had more than one boyfriend, 7 time periods have you lived with her? 7 you would know; wouldn't you? I mean, you -- I assume 8 A. Excuse me? 8 you, if you would see a — 9 Q. You said you had lived with her on two 9 A. No, I wouldn't know. 10 separate occasions. 10 Q. — a male in the house, you'd go, hi, I'm 11 A. Yes. 11 Jane Doe? 12 Q What are those two occasions? Give me the 12 A. No. 13 approximate timeframes. 13 Q. So you would just, if you would see someone, 14 A. The first time, Thad just turned 18 and -- 14 you would turn your head and walk back into your room? 15 Q. You say the first time, or... 15 A. I mostly was in my own room. 16 A. 1 just turned 18, yes. 16 Q. Okay. Were you working at that time? 17 Q. Did you say the first time? I'm sorry. 1 17 A. I did. 18 was thinking about something else. 18 Where? 19 A. Yes. 19 20 Q. Okay. You had just turned 18, so that would 20 21 have put — 18, that would have put you approximately 23. 22. June or July of 2006; right? 22 23 A. Yes. 23 Q. Were you also working at -- 24 Q. And how long did you live with? 24 A. No. 25 A. A few months. 25 at that time or .6...Isam2--c`iwoflin .•axoe.C(.4•w5 .. , ..txxl .‘•• AY' 15 (Pages 54 to 57) (561) 832-7500 PROSE COURT REPORTING AGENCY, .INC. (561) 832-750.6 Electronically signed by Pamela Sullivan (S01-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) freae82144113-40cii48684:104498ca2736 EFTA00750721 Page 58 Page 60 1 A. No. 1 Q. Why? That is — well, let me strike that. 2 Q. . At any time during the time u were 2 Where 3 r ., were you working at or 3 MR. EDWARDS: Object to the form. 4 -- the first time? 4 BY MR. CRITFON: 5 A. Not the first time. 5 Q. Where did get -- how did you -- other 6 Okay. Had you — when you were working at 6 than working at=, how did you support yourself in 7 =, had you — well, let me strike that. 7 terms of food, entertainment, recreation, things of that 8 Whennu worked at 1-- how long did you 8 nature? 9 worked atMl? 9 A. 10 A. About two months. 10 Q. Did she give you money? 11 Q. Had you worked at either of the strip clubs 11 A. Yes. 12 before you wonted at-? 12 Q. Does she still give you money? 13 A. No. 13 A. No. 14 Q. Okay. You worked at the strip clubs after 14 et All right. After the first time you lived 15 you worked atilt? 15 with., you were -- you had just tuned 18. You were 16 A. Yes. 16 there a few months. Then when were you -- when did you 17 . Oka . Had you — when you started working. 17 next live with..? 18 was the first one? 18 A. Must have been a year later. 19 A. Yes. 19 Q. Sometime in 2007? 20 Q. Okay. How -- how many months did you work 20 A. Yes. 21. there? 21 Q. Okay. And how lot did you live — and this 22 A. I don't Irnow. 22 was now at the address, correct? 23 Q. Well, did you work a day? Did you work a 23 A. Yes. 24 month? Did you work a year? 24 Q. Bylite way, when you were at the 25 A. Probably like eight months. 25 what wasM.'s boyfriend's name? Page 59 Page 61 at that 1 MR.EDWARDS: Objection. Asked and answered. 1 Q Were you still working at the 2 point? 2 BY MR. CR1TTON: 3 A_ No. 3 Q. Well, you said she had one boyfriend. Who 4 Did you have any other jobs? 4 was that? S A No. 5 MR.EDWARDS: Answer, if you know. 6 Just working strictly at 6 MR. CRITTON: Is that a form objection? 7 A. Yes. 7 MR.EDWARDS: If you know. 8 MR. CRITTON: Don't — don't key her, so she 8 Q -- for approximately eight months? 9 Yes. can sty, I don't know. Just it's a form; is that 10 Q. When's the second time -- and during the time 10 right? 11 that you worked with.., did you work anyplace else, 11 MR.EDWARDS: Yeah, It's a form objection. 12 other than..? 12 MIt CRITTON: All right. 13 I'm sorry; that may not have been clear. 13 MR. EDWARDS: We've gone through this again 14 During the first time that you lived with 14 and again, so... 15 at her house — or was it an apartment and not a 15 THE WITNESS: Jessie. 16 home? 16 BY MR. DUTTON: 17 A. Apartment. 17 Q. Jessie. So you do know his name. What's his 18 Q. — apartment in West Palm Beach, did you work 18 last name? 19 anyplace else, other than ? 19 A. I don't know his last name. . Was he the only boyfriend that you saw at 20 21 22 A. No. Q. So there must have been a time that you were living with. that you also were unemployed? 20 21 22 M. 's house during the time — I'm sorry — apartment during the time, those few months you lived there? 23 A. Yes. 23 A. Yes. 24 Q. Did she make you pay any rent? 24 Q. And did he live there with her? 25 A. No. 25 A. I guess so. 1,... aaPerye.m.0.62•• •••Nlbaarazeo.•1••...wn4.4 •Paired. 16 (Pages 58 to 61) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 (561) 832-7500 Electronically signed by Pamela Sullivan (SO1-333-772-1652) fleao621-3493.40cd-8666.00a698ca2735 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00750722 Page 62 Page 64 1 Q. Did you continue to see him afterwards? By 1 with your grandmother; correct? 2 see, see him, I don't mean see him in a relationship. 2 A. Yes. 3 A. Yes, I did. 3 Q. And during the time that you were there — 4 Q. Okay. Does... still see Jessie? 4 well, let me strike that. A. No. 5 Had you been living with your grandmother 6 Q. By the way, let me make a couple of things 6 before the first time you went to stay with..? 7 clear. I get to ask you a bunch of questions. I 7 A. Yes. 8 think — Pm confident Mr. Edwards, being the lawyer he 8 Q. Okay. Had there been some event in 2006 that 9 is, has told you about this procedure. So you have an 9 had caused u to leave grandma's --Indmother's 10 idea that I get to ask you questions, and you get to 10 house, house, and go to... 1s, that is a 11 give me answers. And same with the other lawyers that 11 fight, a battle, something that made you unhappy, so off 12 are here; true? You understand that? 12 you went? 13 A. Yes. 13 A. Yes. 14 Q. All right. If you don't tmderstand a 14 Q. What? What had occurred in 2006 that caused 15 question, I'll be happy to rephrase it or to repeat it; 15 you to go It's? 16 do you understand that? 16 A. I broke up with my boyfriend. 17 A. Yes. 17 Q. And his natne was — 18 Q. Okay. And if you answer a question, I'm 18 A. 19 going to assume that you understood it and answered it 19 Q. what? 20 truthfully. That's fair; isn't it? 20 A. 21 A. Yes. 21 Q. I'm s 22 Q. Okay. If you don't know an answer to a 22 A. 23 question, you can tell me you don't know, or you -- or 23 Q. 24 you can — well, let me strike that 24 A. Yes. 25 If you don't know an answer, you can tell me 25 Q. Is Ma the father of your child? Page 63 Page 65 that. You understand that, as well? 1 A. No. 2 A. Yeah. 2 Q. Is — have you seen him since you 3 Q. All right. So you don't need Mr. Edwards to 3 stopped dating him in 2006? 4 say if you know or you don't know. If you don't know 4 A. No. 5 something, you're going to tell me you don't know 5 Q. Does he still live in West Palm Beach; do you 6 something; fair? 6 know? 7 A. Yeah. 7 A. No. 8 Q. Okay. Second time you lived withM. how 8 Q. Do you know where he is -- where he lives or 9 long? 9 resides now? 10 A. A month. 10 A. I have been told that he lives in 11 Q. And where had you been living before this one 11 12 month that went to live with It 12 Is he in school there? 13 A. 13 A. No. 14 Q. And why did you leave? 14 Q. What does he do? 15 A. I doirt blow. 15 I don't know. 16 4 Hew long had you beatifying at your 16 Q. Do you know what his middle name is? 17 grandmother's house -- house on Edge Hill Road in 17 A. No. 18 West Palm Beach before you went tont% for the second 18 Do you know what his date of birth is? 19 time? 19 A No. 20 A. I lived there since I moved out °M.'s the 20 Q. Well, you may not ;mow the year he — well, 21 first time. 21 let me strike that 22 Q. All right So sometime in the latter part of 22 How long did you date this -- how long did 23 2006ar moved back ton's - I'm sorry -- you moved 23 you date..? 24 from M.'s apartment in West Palm Beach, so the latter 24 A From the time I was 16. 25 part of 2006 to sometime In 2007, you were living back 25 Q. Until you were just a little over 18; 17 (Pages 62 to 65) (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 (501-333-772-1652) 17eao621-3493-40cd•8666-00e698ca2735 EFTA00750723 Page 66 Page 68 1 cared? 1 Q. At the time in 2007, I think you said 2 A. Yes. 2 earlier, when your family members told you the FBI was 3 Q. A little over two years? 3 looking for you or looking to talk with you, you were 4 A. Yes. 4 living with II; correct? 5 Q. Okay. And you're telling the members of the 5 A. Yes. 6 jury you don't remember his birth date? 6 Q. All right. And this was in 2007, and you 7 MR. EDWARDS: Object to the form. 7 were not pregnant at that time, so would it be a correct 8 BY MR CRITTON: 8 statement you didn't call the FBI back in 2007; you 9 Q. Not the year, but you don't even remember the 9 called them back sometime in 2008? 10 month or the day; is that correct? 10 MR. EDWARDS: Object to the forth. 11 MR EDWARDS: Form. 11 THE WITNESS: That's possible. 12 TI-IE WITNESS: 1 haven't seen him in years. 12 BY MR. CRITTON: 13 BY MR. CRITTON: 13 Q. Why didn't you contact — when you heard the 14 15 Q. That's not my question. 'just want the members of the jury to understand that you don't 14 15 FBI was looking for you, why didn't you call them back? A. Because I didn't want to talk to them. I 16 remember the person who you dated for over two years, 16 Q. Why not? 17 their birth date; is that correct? 17 A. I don't know. 18 MR. EDWARDS: (Meet to the form. 18 is -. Q. At that point in time, did you tell 19 THE WITNESS: That's correct. 19 that is, when you were with MB, did you tell her that 20 BY MR. CRITTON: 20 the FBI was looking for you, or wanted to talk with you? 21 Q. When you stayed with were working at 21 A. No. 22 MP, then you go back to house, your 22 Q. So as you're living with MI, you knew 23 grandmother; correct -- 23 that — well, let me strike that 24 A. Yes. 24 You had been to Mr. Epstein's house a number 25 Q. -- sometime in 2006? 25 of times; true? Page 67 Page 69 1 A. Yes. 1 A. Yes. 2 Q. And you stayed there for a number of months 2 Q. Prior to 2006? 3 into 2007; correct? 3 A. Yes. 4 A. Yee. Q. You knew that had been to Mr. Epstein's 5 Q. And then — and then for some reason you left 5 home, as well? 6 and went back to s house, this time — or back with 6 A. Yes. 7 a in true? 7 Q. Did III ever tell you that -- that the FBI 8 A. Yes. 8 VMS baking to talk with her or to speak with her? 9 Q. Okay. And what occurred at grandma's 9 A. She probably did. 10 house -- at your grandmother's house, that caused you to 10 Q. And, to your knowledge, did she ever talk 11 leave and go back to., what event at that time? 11 with the FBI? 12 A. Nothing. 12 A. No. 13 Q. You just decided to pick up and leave? 13 Q. You — well, that's a ■ question. 14 A. Yet 14 Did she ever talk -- did she tell you she 15 Q. And you stayed with M. for a month? 15 talked with the FBI? 16 A. Yes. 16 A. She did not tell me that she did. 17 Q. What time period was that? Give me a 17 Q. Okay. Did she tell you she did not talk with 18 approximate date. 18 the FBI, or was not going to talk to the FBI? 19 A. I don't know. 19 A. No. 20 Q. Wash early? Were you pregnant at the time? 20 Q. What did she tell you, if anything? 21 A. No. 21 A. She didn't really say anything. 22 Q. Which kind of takes me back to the question: 22 Q. So at the time that your family members are 23 When you were with Ms. either in 2006 or 2007, had 23 telling you she's going to talk -- the FBI is looking to 24 the FBI contacted her? 24 talk with you, you had — this was the second time now 25 A. Not that I know of. 25 you're living with Ww illich you said would have been 18 (Pages 66 to 69) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-7724652) Electronically signed by Pamela Sullivan (501.333-772.1552) fleae621 -3193-40cd-8566-000698ca2735 EFTA00750724 Page 72 Page 70 1 cared? 1 sometime in 2007 because you weren't pregnant, and you 2 A. Yes. 2 didn't want to talk to them; correct? 3 Q. When you spoke with the FBI -- and you told 3 A. Yes. 4 us you didn't have a lawyer at that time — was it — 4 Q. AllSit. And it's your testimony you 5 did the FBI tell you or give you the card, Mr. Edwards' 5 didn't tell I. that the FBI was looking to talk to 6 card, and say, this is someone whom you should contact? 6 you; correct? 7 A. No. 7 A. Yes, not at that time I didn't. 8 Q. Was it before or after you talked to the FBI 8 Q. At the time — at the time that the FBI was 9 that someone gave you Mr. Edwards' card? 9 trying to talk with you in 2007, did you have a lawyer 10 A. After. 10 at that time? Did you talk to a buyer about anything. 11 Q. And do you remember where you were when 11 I mean, other than related to any criminal or arrest 12 Mr. Edwards' card was given to you? 12 issue that you had? 13 A. No. 13 MR. EDWARDS: Object to the form. 14 Q. Do you remember how long after you spoke with 14 THE WITNESS: The first time I spoke to the 15 the FBI you received Mr. Edwards' card? 15 FBI I did not have a lawyer. 16 A. Not long. 16 BY MR. CRITTON: 17 Q. Within a week or so? Two weeks? 17 Q. All right And with — I think you told me 18 A. Maybe a month or two. 18 earlier that your best recollection is sometime in 2008 19 Q. If the person that — what occurred that 19 you spoke with them! - 20 someone would give you a lawyer's card? Does that make 20 MR. EDWARDS: Object to the form. 21 sense to you? That is, let's say you're working at 21 BY MR. CRFITON: 22 Q. — correct? 22 In and someone goes, here, I want to give you 23 Mr. Edwards' card. Did that - 23 A. I was three and a half months pregnant 24 A. Well, obviously — 24 Q. Okay. And what -- what makes you know that 25 Q. Okay. There has to be some reason why 25 you were three and a half months pregnant? Page 73 Page 71 1 someone would give you a lawyer's card. So my question A. Because I went to a doctor. 2 to you is: Where are you — where were you — what's 2 Q. No, I understand that. But did you go talk 3 your recollection as to why -- how you came to be in 3 to the FBI the same day that you talked to the FBI? 4 possession of Mr. Edwards' card? 4 MR. EDWARDS: Object to the form, if that's a 5 A. Well, it must have been somebody who the FBI 5 question. Did you talk to the FBI the same day you 6 spoke to and who had his card. 6 talked to the FBI; that's the question? 7 Q. So it must — another female? 7 MR. CRTITON: Oh, Fm song. That may have 8 MR. EDWARDS: Object to the form. 8 been the question. That was not the intended 9 THE WITNESS: I'm not -- I don't remember who 9 question. 10 it was who gave me the card. 10 MR. EDWARDS: I can answer that for you. yes. 11 BY MR. CRITTON: 11 It's 12 Q. Well, how — how would a lawyer's card end up 12 BY MR. CRTITON: 13 in your hand? In this instance, it was Mister — 13 Q. The day that you spoke, you're — you're 14 happened to be Mr. Edwards' card. What — you had to 14 convinced that you were three and a half months pregnant 15 have said something to someone who would have said, you 15 at the time. So had you been to a doctor that said 16 need a lawyer, here's a lawyer's card. And that's what 16 you — you know, l— by our calculations, you're three 17 I'm trying to find out. What — what occurred that n. 17 and a half months pregnant, and then you remember that d? Were you talking to liM.? 18 someone gave you 18 because that ties in with you saw the FBI within a few to 19 Were you talking 19 days? • 20 A. I donli310W. 20 A. Yes. telling the 21 Q. An right. So you're 21 Q. All right. Who was your doctor, your -- your gentlem en of the Jury you have 22 gentlemen -- ladies and 22 DB/CNN doctor? you got Mr. Edward s' card? A. 23 no recollection of how 23 Object to the form. 24 MR. EDWARD& 24 Q And you're almady — we've already 25 25 established that you only talked with the FBI once; 19 (Pages 70 to 73) (561) 832-7506 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (501.333-772-1552) fleao621-3493-40cd-8666-00e698ca2735 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00750725 Page 74 Page 76 1 BY MR. CRITTON: 1 coming? 2 Q. Just that it was sometime after you spoke 2 A. Yes. 3 with the FBI? 3 Q. Okay. Who — who else was living with 4 A. Yes. 4 Ms. Brewer, in addition to yourself, at that time? 5 Q. Okay. And it's your testimony that that 5 A. I'm not sure. 6 the F — that none of the FBI individuals or the people 6 Q. Okay. Well, was the father of your child — 7 who interviewed you gave you Mr. Edwards' card; is that 7 A. Yes. 8 your testimony here under oath? 8 Q. — excuse me -- living there at the time? 9 A. Yes. A. Yes. 10 Q. Did someone call you and refer you to 10 Q. Okay. So — and he's someone that, until I 11 Mr. Edwards, say, I'm going to send you a card, this is 11 asked whether he was there, you didn't recall whether he 12 a lawyer you need to see? 12 was living there? 13 A. No. I don't remember who it was who gave me 13 A. He was living there, but I don't think he was 14 the card. 14 there. 15 Q. When you met with the FBI, who was it? 15 . All right. I'm just asking who was living at 16 MR. EDWARDS: Object to the form. Asked and 16 home at the time that the FBI came. And 17 answered. 17 when I say, who was living in the house, not necessarily 18 BY MR. CRITTON: 18 they were there when the FBI interviewed you, but who 19 Q. That is a man and a woman? 19 was living at the house. There was Ms. Brewer, your — 20 A. Yes. 20 the father of the childEra 21 Q. Okay. Was Jason one of those people? 21 A. Yes. 22 A. Yes. 22 Q. Okay. And the father obviously has a name. 23 And you don't recall the woman's name? 23 What's his name? 24 A. No. 24 A. 25 Q. Describe Jason for me. 25 Q• Page 75 Page 77 1 A. He WAS a tall, bald man. 1 2 Q. Approximate age, best estimate? 2 3 A. Its thirties. 3 4 (Discussion held off the record.) 4 5 BY MR. CRITTON: 5 6 Q. All right. The woman, describe her for me. 6 7 A. She was blond. 7 8 Q. Tall? Short? Medium? 8 9 A. I believe she was taller than I am. 9 10 ' Q. Approximate age? 10 Q. You're currently living him -- with him and 11. A. She was probably in her thirties, also. 11 your child at the address that your attorney has :2 Q. Where did you meet them? Did you come to 12 instructed you not to provide me; correct? 13 them, or did they come to you? 13 A. Yes. 14 A. They came to me. 14 Q. And nobody else lives at that address with 15 Q. And where did they come where were you 15 you; is that correct? 16 living at that time that they came to interview you? 16 MR. EDWARDS: Object to the form. Don't 17 Were you still at M.'s? 17 answer. 18 A_ No. 18 MR CRITTON: Well — 19 . Now you were back at grandma at 19 MR. EDWARDS: It's going to be identifying 20 home? 20 information about the address. 21 A. Yes. 21 BY MR. CARTON: 22 Q. Was anyone else present when they interviewed 22 Q. I want to know, does anyone else live with 23 you? 23 you at your current address? 24 A. No. 24 A. Besides who? 25 Q. Did your grandmother know that they were 25 Q. Besides the father of the 20 (Pages 74 to 77) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Elsetrortically signed by Pamela Sullivan (501-333-772-1552) Bactronically signed by Pamela Sullivan (501-333-772.1552) 17ene21.3493.40ed-8666.00e698ca2736 EFTA00750726 Page 78 Page 80 1 ? 1 a house, 2008. Is it just the three of them, 2 A. 2 the two of them and you? 3 Q. 3 A. Yes. 4 MR. EDWARDS: Don't answer. 4 Q. Okay. Sitting at the kitchen table. 5 MR.. CRITTON: Well, just a yes or no, first. 5 A. The porch. 6 How about that? 6 Q. How much time did you spend with them? 7 MR. EDWARDS: Don't answer. 7 A. I don't know. 8 MR. CRITTON: Okay. 8 Q. Was it a five-minute conversation? Was it an 9 MR. EDWARDS: Whether it's yes or no. 9 hour? Was it multiple hours? 10 MR. CRITTON: And the basis -- the basis for 10 A. May have been like an hour. 11 that, just so that the Court can -- 11 Q. Did they ask you questions? 12 MR. EDWARDS: Is that it's going to be 12 A. Yes. 13 identifying information about the address, so that 13 Q. Did they take mitten notes? 14 you can give it to your client, so that he can go 14 A. I do not know. 15 and harass her or do whatever he wants to or 15 Q. Did they have a tape recorder? 16 whatever he's done in the past to her. And that's 16 A. I don't believe so. 17 not going to happen to her or her daughter. 17 Q. Okay. So you didn't — you did not give 18 MR. CRITTON: That's absurd. 18 anyone from the FBI authority to tape your statement; 19 MR. EDWARDS: That's it. 19 correct? 20 MR. CRITTON: That's absurd. 20 MR. EDWARDS: Object to the form. 21 MR. EDWARDS: Yeah, I agree; it is absurd. 21 BY MR. CRITTON: 22 What's happened -- 22 Q. And that is to take a tape-recorded statement 23 MR. CRITTON: No, no. What — 23 from you; is that correct? 24 MR EDWARI:6: — in this case is absurd — 24 MR. EDWARDS: Object to the form. 25 MR. CRITTON: Okay. 25 THE WITNESS: I don't remember if they did or Page 79 Page 81 MR. EDWARDS: — and what's going to happen 1 not 2 in the future in this case is absurd. 2 BY MR. CRITTON: 3 MR. CRITTON: All I'm asking is whether 3 Q. So in less than a year ago from today, maybe 4 anyone else lives with her at that address. 4 just a little ova a year, it's your testimony you don't 5 Obviously, that person may well have information 5 remember whether the FBI taped your statement or not; is 6 regarding the alleged damage claim that your 6 that correct? 7 client's making. 7 MR EDWARDS: Form. 8 MR. EDWARDS: Okay. Go to the Court to get 8 BY MR. CRITTON: 9 information. 9 Q. Ifs what you're telling us? 10 MR. CRITTON: All right. And I just want 10 MR. EDWARDS: Farm. 11 you — and you're going to follow your lawyer's 11 THE WITNESS: Yes. 12 advice? 12 BY MR. CRITTON: 13 MR EDWARDS: Yes. 13 Q. Did they have a stenographer with them, 14 Mk CRITTON: Well, no, Fm asking her. 14 similar to Pamela sitting to your immediate right? 15 MR. EDWARDS: And she is. 15 A. No. 16 BY M:R. CRI1TON: 16 Q. Did they video the conference at all? 17 Q. You're going to foamy your lawye's advice? 17 . A. No. 18 A. Yes. 18 Q. When you called well, from the time that 19 Q. Okay. And we have to come back here and do 19 you called oh, I'm sorry -- did you call Jason or the 20 this in multiple times, and if the Court -- you 20 woman to set up the appointment, or did they oontact 21 understand that the Court may grant sanctions under this 21 you? 22 circumstance; do you understand that? 22 A. I think I called them. 23 A. That's fine. 23 Q. And, and why did you call them? What caused 24 Q. Two FBI people, they come to your house 24 you to call the FBI? When they were trying to get ahold 25 sometime in 2000 — or the grandmother's house, 25 of you in 2007, what caused you in late — well, AA, 21 (Pages 78 to 81) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772-1662) treae621-3493-40cd41666.00e69Sca2736 Electronically signed by Pamela Sullivan (501.333.772-1552) EFTA00750727 Page 82 Page 84 1 sometime in 2008 to call them? 1 BY MR. CANTON: 2 MR. EDWARDS: Object to the form. 2 Q. You used pot? How about Xanax? 3 THE WITNESS: I — I was pregnant, and I was 3 A. From time to time. 4 thinking more clearly. And I guess I pretty much 4 Q. Ecstasy? S realized that I needed to call them. 5 A. No. 6 BY MR. CRITTON: 6 Q. So it's your testimony that no one — there 7 Q. Well, what — now that you were pregnant, 7 should be no individual who could say Jane Doe took 8 what caused well, how were you thinking more clearly 8 Ecstasy, because that would be 9 because you were pregnant, versus when you were not 9 A. I have taken it once. 10 pregnant? 10 Q — a boldfaced lie; is that right? 11 A. I was not drinking or I wasn't — I — I just 11 A. One time I have taken it, yes. 12 was taking better care of myself. 12 Q. Okay. So you have taken Ecstasy - 13 Q. Okay. Well, before you became pregnant, you 13 MR. EDWARDS: Object to the form. 14 also used illegal drugs; didn't you? 14 BY MR. CRITTON: 15 A. Yea 15 Q. -- true? 16 Q. So were you drinking and using illegal drugs 16 A. One time, yes. 17 up through the time that you became pregnant? 17 Q. You've used cocaine, as well; haven't you? 18 A. Excuse me? 18 A. Yes, I have. 19 Q Were — did you continue to drink — and I - 19 Q. On many occasions; true? 20 when I say drink, you mean alcohol; don't you? 20 A. More than one. 21 A. Yes. 21 Q. More than ton? 22 Q. Okay. And I assume that when you say you 22 A. No. 23 weren't drinking, you would drink alcohol to excess 23 Q. So if witnesses tome in and say, yep, Pve 24 prior to the time that you were pregnant with your 24 seen Jane Doe use coke a lot of times, they would be 25 daughter; comet? 25 boldfaced liars; is that true? Page 83 Page 85 MR. EDWARDS: Object to the form. 1 MR. EDWARDS: Object to the form. 2 THE WITNESS: Yes. 2 THE WITNESS: Yes. 3 BY MR. CRITTON: 3 BY MR. CRITTON: 4 Q. Okay. And you would drink to the extent that 4 Q. Okay. How many times do you think you wed 5 you would from time to time pass out; true? 5 coke? Approximately ten? 6 MR. EDWARDS: Form. 6 MR. EDWARDS: Object to the form. 7 THE WITNESS: No. 7 THE WITNESS: Five. 8 BY MR. CRTITON: 8 BY MR. CRITTON: 9 Q. Okay. So you would drink a lot, you would 9 Q. Maybe more? 10 drink to excess, but you never passed out — 10 A. No. 11 MR. EDWARDS: Object to the form. 11 Q. How about crack cocaine, do you use that? 12 BY MR. CRITTON: 12 A. No. 13 Q. -- is that your testimony? 13 Q. Oxyocntin? 14 A. Yes. 14 A. No. 15 Q. Okay. And prior to becoming pregnant, you 15 Q. How about Roxycontin — 16 also used illegal drugs on a regular basis; didn't you? 16 A. No. 17 A. Not on a regular basis. 17 Q. — Roxicodone? 18 Q. Okay. Well, you — you were using them at 18 A. No. 19 least a number of days out of event month prior to the 19 Q. Do you know what a rosy is? 20 time that you became pregnant fora long period of time; 20 A. Yes, I do. 21 isn't that true? 21 Q. What is a roxy? 22 A. Yes. 22 MR.. EDWARDS: Object to the form. 23 Q. And what kind of drugs did you use? 23 THE WITNESS: It's a pill. 24 MR. EDWARDS: Form 24 BY /4R. CRITTON: 25 THE WITNESS: Marijuana. 25 Q. Okay. And what does it do? What do you 22 (Pages 82 to 85) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 8 32-7 50 6 Electronically signed by Pamela Sullivan (501.333-772-1552) fl eao521-3493-40cd-8666-00e698ca2735 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00750728 Page 86 Page 88 1 understand a roxy does? 1 and meet with you at the Edge Hill — 2 A. I do not ;mow. 2 A. One or two. 3 Q. Have you ever taken roxies? 3 Q. — address? One or two days later? 4 A. No. 4 A. One or two, yes. Q. So if someone said, 1 saw Jane Doe take 5 Q. Did they give you any pieces of paper when 6 roxies, I've given her roxies, that person would be 6 they met with you? 7 lying; is that what you're saying? 7 A. They gave me their card. MR EDWARDS: Econ. 8 Q. Just their card? 9 THE WITNESS: Yes. 9 A. Yes. 10 BY MR. CRITTON: 10 Q. So you had the cards that your family members 11 Q. Since the time you've had your daughter, do 11 had given you, and you also had the cards that they gave 12 you continue to drink? 12 you that day? 13 A. I have not. I have drunken when I turned 21, 13 A. Yes. 14 and that's it. 14 Q. And what did they tell you? That is, when 15 Q. How about drugs, have you continued to use 15 you called them to say, okay, I'll talk with you now, in 16 drugs since you gave binh to your daughter on 16 2008, did you say, what do you want to talk about? Did 17 17 you say, I'm Jane Doe, you've let me — been trying to 18 A. No. 18 pat ahold of me. 19 Q. Okay. So if someone said they'd seen you 19 A. Yes. 20 using drugs, you're saying that person would be lying? 20 Q. So here I am; I'll talk to you — 21 A. Absolutely. 21 A. Yes. 22 Q. Back to the FBI They came to your porch 22 Q. — right? 23 sometime in 2008, spent about an hour with you, I think 23 A. Yes. 24 you said? 24 Q. And what did you say to them? Did you say, 25 MR. EDWARDS: Form. 25 what do you want to talk about? Or did you know? Page 87 Page 89 / 1 THE WITNESS: Uh-huh. 1 A. I don't remember. 2 BY MR. CRITTON: 2 Q. Did -- well, did you know that it involved 3 Q. Yes? 3 Mr. Epstein? 4 A. Yes. 4 A. Yes, I did. 5 Q. And you don't remember whether they took 5 Q. How did you know that? 6 notes, you don't remember giving them permission to 6 A. Because I have a brain. 7 use - to take a tape-recorded statement, and you don't 7 Q. All right That's good. We -- and — and 8 remember whether they took a tape-recorded statement, 8 you — you don't have any type of mental disability; 9 all taste; correct? 9 correct? 10 A. I'm sure that they took notes, but I do not 10 A. Meaning? 11 remember if they recorded it. 11 Q. You don't have any mental disability; that is 12 Q. Did you sign any — excuse me did they 12 you - you understand when people talk to you? That is 13 take any kind of statement from you in handwriting, and 13 you've never had any kind of learning disability? 14 then ask you to sign it? 14 MR EDWARDS: Object to the form. 15 A. I don't remember. 15 THE WITNESS: Yes. 16 Q. Did they give you a copy of any notes or 16 BY MR. CRITTON: 17 statement that day? 17 Q. Pardon? 18 A. No. 18 A. Yes. 19 Q. Okay. Is that the only occasion, other 19 Q. You —you say you do have a learning 20 than — well, let me strike that 20 disability? 21 I think — who did you say you called to set 21 A. No, I don't. 22 up the appointment? Was it Jason or the woman? 22 Q. Okay. Well, that's what Inn saying is I've 23 A. I think it was the woman. 23 looked at your school records, and I've looked at 24 Q. Okay. And how many days after you called 24 your — you know, the FCATS and some of those reports 25 them and say, I'll talk to you, did they come out and - 25 that have been turned over to us in discovery. And it 23 (Pages 86 to 89) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-7/2-1662) Bectrenkally signed by Pamela Sullivan (601.333-772.1652) from.621-3493-40a14616-00e69Ses2735 EFTA00750729 Page 90 Page 92 1 appears that you have — that you've scored pretty well, 1 with you? 2 very well in some instances, on standardized testing; 2 A. Yes. 3 correct? 3 Q. And they say, okay, well be out in two days, 4 MR. EDWARDS: Form. 4 or a day or hvo? 5 THE WITNESS: Yes. 5 A. Yes. 6 BY MR. CRITTON: 6 Q. Okay. What, five-minute conversation? 7 Q. Okay. So you said you have a brain, and — 7 A. Probably. 8 and you knew that's why the FBI wanted to talk to you. a Q. So they come out. What did they tell you 9 How did you -- how did you know that? I mean, separate 9 before they started the conversation? 10 from just being smart, how did you know that the FBI 10 A. They wanted to show me their ID, so that I 11 wanted to talk to you about Mr. Epstein? That is, what 11 knew that they were who they said they were. 12 was going on that made you know that? 12 Q. Okay. So they showed you the ID. Then what 13 A. Because I watch the news. 13 did they say? 14 Q. So in 2008 you had seen something on the news 14 A. They wanted to talk to me about 15 about Mr. Epstein? 15 Jeffrey Epstein. 16 A. Yes. 16 Q. And did they— and they proceeded to did I 17 Q. Okay. What had you seen? 17 they both ask you questions, or just one person? 18 A. I -- I think it was a newspaper where I just 18 A. Mostly the woman. 19 saw his face. 19 Q. She asked what, 90 percent of the questions? 20 Q. And you— so you saw his bee. Did you read 20 A. Yes. 21 the article? 21 Q. And what did you tell? What — what 22 A. Yes. 22 questions did she ask you; what's your best 23 Q. Okay. You — and you — did — were you 23 recollection? Okay? And what did you tell her? 24 reading the newspaper regularly at that time? 24 A. She asked me how many times I had gone to 25 A. No. I just — the newspaper was being 25 Jeffrey Epstein's house. Page 91 Page 93 1 delivered regularly to my house. 1 Q. And -- 2 Q. So you happened to see some article about 2 A. And I told her that I couldn't remember 3 Mr. Epstein? 3 exactly how many times it was. It was probably at least 4 A. Yes. 4 20.. 5 Q. Do you remember what the ankle was about, 5 Q. Did you tell her that? 6 other than seeing his face? 6 A. Yes. She asked me who brought me to 7 A. It was about him being arrested. 7 Jeffrey Epstein's house. 8 Q. All right. And was it after you saw that he 8 Q. What did you tell her? 9 was arrested that then you called the FBI, or did you 9 A. I told her that'll. brought me there. 10 continue to wait a lengthy period of time? 10 Q. Ma 11 A. I waited -- 11 A. Yes. 12 Q. Why? 12 Q. All right. Let me just -- and then I'm going 13 A. — some time. 13 to get back to the conversation. 14 Excuse me? 14 At the time that you saw or were staying with 15 Q. Just didn't want to be involved? 15 either on the first occasion or the second 16 A. I was afraid. 16 occasion, I assume you were friends at that time, good 17 Q. What were you afraid of? 17 friends? 18 A. I don't know. 18 A. Yes. 19 Q. There wore no cars watching you; right? And 19 Q. Okay. And you continued to be good friends, 20 you didn't see any suspicious activity; correct? 20 even when you were apart, during that interim time 21 A. Not at that time. 21 period between the first and second; correct? 22 Q. MI right. So they come out; they spend an 22 A. You mean, were we still friends after I 23 hour with you. What did they ask you? Well, let me -- 23 didn't live with her? 24 let me go back to when you set up the appointment. How 24 Q. Yeah. After the first time and you went back 25 long was that? Did you say, I'm Jane Doe, I'll talk 25 to your grandmother's house, you still continued to be 24 (Pages 90 to 93) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501333.772.1552) Electronically signed by Pamela Sullivan (SO1-333-772-1652) 17eao621-3493-40cd -8666.00c 698ca2735 EFTA00750730 Page 94 Page 96 1 good friends with. — 1 BY MR. CRIITON: 2 A. Yes. 2 Q. Separate and apart from what Mr. Edwards may 3 Q. -- before you went back the second time: 3 or may not have read to you has anyone else shown you 4 correct? 4 or read to you portions on.'s deposition? 5 A. Yes. 5 A. No. 6 Q. And when you were with.., did you sec. 6 (,Z.— Are you aware that she was deposed last 7 from time to time? 7 week- A. Yes. 8 MR. EDWARDS: Objection. Attorney/client 9 Q. Okay. And would — did you consider.. to 9 privilege. 10 be one of your good friends? 10 BY MR. CRITION: 11 A. Yes. 11 Q. — and had given her deposition -- 12 Q. And is she still one of your good friends 12 MR. EDWARD$: You're not answering the 13 today? 13 question_ 14 A. Yes. 14 BY MR. CRITTON: 15 Q. And you said.. is not a good friend 15 Q. Let me ask you this: Separate and apart from 16 today — 16 Mr. Edwards, were you aware than. was going to give 17 MR. EDWARDS: Object to the form. 17 a deposition? 18 BY MR. CRITTON: 18 A. No, l was not. 19 Q. -- is that correct? 19 Q. After — and so -- let me strike that. 20 A. I haven't spoken to.. in some time. 20 So separate and apart from whatever your attorney may have told you, you had no knowledge that 21 22 Q. How long? A. About at least six months. Pm not 21 22 23 E. either was going to give a deposition or had given a deposition; is that correct? 23 positive. 24 Q. And what happened to cause you not to be 24 A. That is correct. 25 friends? 25 Q. Did. -- did.. — did — did you tell Page 95 Page 97 1 A. She was living in the same neighborhood as 1 either.. ore. that you were going to meet with the 2 me, and she moved. I don't know. We just — 2 FBI? 3 Q. Call her by cell phone? 3 A. No. 4 A. We just lost contact. I don't know. 4 Q. Did they-tell you that they had met with the 5 Q. Do you know what she's doing now? 5 FBI? 6 A. No, I do not. 6 A. No. 7 Q. And you don't know where she's living now? 7 Q. Or anyone else? 8 A. No, I do not. 8 A. No. 9 Q. But you've stayed in touch within.? 9 Q. Did you tell anyone, other than -- let me 10 A. We talk probably once every other month. 10 strike that. 11 Q. Did you talk to her after she gave her 11 Did you tell your grandmother you were going 12 deposition last week? 12 to meet with the FBI? 13 A. No, I have not. 13 A. Yes. 14 Q. Did you read her deposition? 1.4 Q. Did you tell any other family member you were 15 A. No, I did not. 15 going to meet with the FBI? 16 Q. Have you seen any portions ofher deposition? 16 A. No. 17 A. I haven't read it. 17 Q. Did your grand — your grandmother knew that 18 Q. My question is: Have you seen any 18 you had gone to Mr. Bpstein's home; didn't she? 19 portion o .'s deposition? 19 A. She didn't know any details. 20 A. No. 20 Q. Let me ask — answer my question. 21 Q. Okay. Has anyone read any portions of that 21 Your grandmother knew that you had gone to 22 deposition to you? 22 Mr. Epstein's home on a number of occasions; true? 23 MR. EDWARDS: Object to the form. She's not 23 MR. EDWARDS: Object to the form. 24 answering the question, attorney-client privilege. 24 THE WITNESS: She knew after I told her, yes. 25 25 25 (Pages 94 to 97) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 (561) 832-7500 Electronically signed by Pamela Sullivan (5D1-333-772-1552) t7eao621.3493.40cd-8666-00o698ca2736 Electronically signed by Pamela Sullivan (501-333-772-1652) EFTA00750731 Page 98 Page 100 1 BY MR. CRITTON: 1 A. No, that is not true. 2 Q. But evai during that time period she knew 2 Q. Well, what makes you think it was February, 3 that you were going to Mr. Epstein's home from time to 3 a plus or minus a month? 4 time? 4 A. Because I told Jeffrey Epstein that I was 15 5 MR. EDWARDS: Object to the form. 5 and that my birthday was in January. And I knew that it 6 THE WITNESS: During what time period? 6 7 BY MR. CRITTON: 7 Q. Okay. And why would you tell him you were 8 Q. During the time you — time period that you 15, rather 14 — 9 went to Mr. Epstein's home. A. I don't — 10 A. No, she did not ;mow. 10 Q. — assuming that's true? What was — what 11 Q. Didn't you give your grandmother's cell phone 11. was the big difference to you about that? 12 to someone at Mr. Epstein's home — not Mr. Epstein, but 12 A. I have no idea. 13 to someone at Mr. Epstein's home? 13 Q. Did M. tell you to say that? 14 A. Her cell phone? 14 A. No. 15 Q. Or her phone number? 15 Q. In fact, a. had told you to say that you 16 A. It was a phone number that 1 was using, yes. 16 were IS; isn't that true? 17 Q. And that phone number belonged to whom? 17 A. That is not true. 18 A. Me — well, was paying for it, 18 Q. Okay. Well, didn't M., before she took you 19 but it was my phone number. 19 there the first time, say, look, tell Mr. Epstein you 20 Q. All right. So other than your grandmother, 20 are 18, if he's — if you're asked? 21 did anyone know — else know that the FBI was coming? 21 A. That is absolutely not true. 22 A. No. 22 Q. So if would — has testified to that 23 Q. So they asked you the number of times you had 23 wider oath, that would be a lie? 24 gone to Mr. Epstein's house. You said you didn't 24 MR. EDWARDS: Object to the form. 25 remember, but you thought it was about 20 times. They 25 THE WITNESS: Yes. Page 99 Page 101 1 asked you — 1 BY MR. CRITTON: 2 A. Yes. 2 Q. Did you ever keep a log a any kind of diary 3 Q. Correct? 3 or paperwork of any kind that as to the dates that A. Yes. 4 you went to Mr. Epstein's home? Q. And they asked you who brought you, and you 5 A. No. 6 Said ■ - 6 Q. When is the last time you went to 7 A. Yes. 7 Mr. Epstein's home? 8 Q. — correct? 8 A. I was 17. 9 What else did they ask you? 9 Q. Give me a date. 10 A. They asked me — they asked me what happened 10 A. It was after I tamed 17. It must have been 11 the first time I went to Jeffrey Epstein's house. 11 very shortly after June something. 12 Q. Did -- did you tell them the first time that 12 Q. So it would have been June, July of '05? 13 you went to Mr. Epstein's house? 13 A. The beginning of July, though. 14 A. Yes. 14 Q. So you're — is it — are you telling us that 15 Q. Okay. And when was the first date that you 15 over basically a three-, almost four-year span, you went 16 went to Mr. Epstein's home? 16 to Mr. Epstein's -- which is about 48 months or 17 A. I believe that it was in February of'03. 17 something less, 40 to 48 months — you went to 18 Q. And what makes you think it was in February 18 Mr. Epstein's house approximately 20 times? 19 of'03? 19 A. Probably more, but, yes. 20 A. Because I was — I was definitely 14, and 20 Q. Well, you told the FBI it was approximately 21 Fm — Fm not exactly positive that it was — like if 21 20; right? 22 it was February or the month before or after. I just 22 A. Yes. 23 know it was around that time. 23 Q. And they asked you what happened on the first 24 Q. Isn't it true, ma'am, the first time you went 24 occasion, and did you tell than? 25 to Mr. Epstein's home you were 15 years old? 25 A. Yes, I did. 40' n04. ab.lar—e- 26 (Pages 98 to 101) (561) 832-750O 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) freae621.3493-40cd.8666-000698ca2735 EFTA00750732 Page 102 Page 104 1 Q. Okay. And did you tell the FBI that you were 1 MR. EDWARDS: Object to the form. 2 14 years old when you went? 2 BY MR. CRITTON: 3 A. Yes, I did. 3 Q. Do you know the difference between the State 4 Q. You're sure of that? 4 and the Federal system? 5 A. Yes. 5 A. No. 6 Q. Other than telling them what happened on the 6 Q. All right. As of the time that you received 7 first occasion, what else did they ask you? 7 the letter from the FB1, they talked to you about Victim 8 A. What happened on every other. 8 Services, had you at this time retained Mr. Edwards? 9 Q. Did they go through all 20 — approximately 9 A. Before I went to Victim Services, yes, I did. 10 20 occasions that you were at Mr. Epstein's home? 10 Q. Okay. Do you remember when you first went to 11 A. No. They just wanted to know what normally 11 Victim Services? 12 would happen. 12 A. No, I don't. 13 Q. And at the end of the conversation, what did 13 Q. Did the people — did the yeoman and the man 14 they tell you — a the end of the interview? 14 from the FBI discuss with you that you could bring a 15 A. I don't remember. I'm sure that I — I know 15 civil suit and recover substantial money damages from 16 that the woman was telling me somewhere along the lines 16 Mr. Epstein? 17 that it was wrong. She was telling me that it was 17 A. I don't remanber. 18 wrong, and -- 18 Q. Okay. Well, in fact — well, let me strike 19 Q. The FBI lady told you that? 19 that. 20 A. Yes. 20 Did the FBI tell you at all that you might 21 Q. All right. And did the man say anything? 21 have a civil cause of action against Mr. Epstein? 22 A. He — he pretty much just agreed with her. 22 A. I don't remember. 23 He didn't say much. 23 Q. That's pretty would be pretty significant, 24 Q. Did you ask any questions? 24 because you tiled a lawsuit in this instance, against 25 A. No. 25 Mr. Epstein; true? Page 103 Page 105 1 Q. Like, what are they doing with Mr. Epstein? 1 A. Yes. 2 A. No,1 did not. 2 Q. All right. And how much money do you want 3 Q. And what did you think would happen as a 3 from Mr. Epstein? 4 result of your interviewing with the FBI or talking to 4 MR. EDWARDS: Object to the form. 5 them? 5 THE WITNESS: I don't care about 6 A. I just thought that it would help. I just 6 Jeffrey Epstein's money. 7 thought it would help. 7 BY MR. CRTITON: 8 Q. What — when they left that day — or before 8 Q. Okay. What do you want? 9 they left that day, did they give you any paperwork a 9 A. I want Jeffrey Epstein to go to prison for 10 any documents? 10 the rest of his life. 11 A. No. 11 Q. Okay. Is it your do you believe that the 12 Q. Okay. Did they subsequently, after the 12 lawsuit that you have filed against Mr. Epstein will 13 interview, send you some documents later on? 13 cause him to go to prison for the rest of his life? 14 A. Yes. 14 A. No, I do not. 15 Q. Okay. Like a week later, couple of days 15 Q. Do you believe that the — well, what do you 16 later? 16 believe the purpose of your lawsuit is in this instance, 17 A. Probably a week. 17 that is that we're here on today that you're giving a 18 Q. And what did you receive? 18 deposition? 19 A. I just received some papers saying that they 19 A. 1 know that Jeffrey Epstein will not go to 20 would help me by giving me a phone number to something 20 prison for what he did, and so... 21 called Victim Services, where I could talk to somebody. 21 Q. Are you aware he's been in prison? 22 Q. And did you subsequently call the Victim 22 MR. EDWARDS: Object to the form. 23 Service person? 23 THE WITNESS: Yes, but he didn't go to prison 24 A. Yes, I did. 24 for the time he deserved to. 25 Q. Is that in the Federal system? 25 V...a.T.f.e.4.?laTrtralas 27 (Pages 102 to 105) (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 (501-333472-1552) freae621-3493-40cd-8666-00e698ca2735 EFTA00750733 Page 106 Page 108 1 BY MR. atITfON: 1 from? Well, if it comes from Mr. Epstein, where do you 2 Q. From your perception; right? 2 think it goes? 3 MR. EDWARDS: Object to the form. 3 A. Ijust want something — I just want some 4 BY MR. CRITTON: 4 sort ofjustice. It's not it hasn't been — 5 Q. You believe ho should have gone away longer? 5 Q. Pm sorry? 6 A. I icnow that he hurt a lot of people, and he 6 A. it hasn't been right in this. Just 7 deserves it. 7 because Jeffrey Epstein has money, he doesn't have to go 8 Q. The question to you is, is your opinion is, 8 to prison; that's not fair. 9 is that Mr. Epstein should have gone to prison for a 9 Q. So in order to resolve this case with 10 longer period of time; correct? 10 Mr. Epstein, how much money do you want? 11 A. I believe that is a fact. 11 MR. EDWARDS: Object — 12 Q. Okay. Now, with maid to this lawsuit, what 12 THE WITNESS: It doesn't matter. 13 do you want from this lawsuit, then? If you — if you 13 BY IvER. CRITTON: 14 can't send him to prison, what do you want? 14 Q. Ill say, NI pay you X-amount of dollars 15 A. I want to hurt him. 15 today, how much do you want? 16 Q. Okay. So you want to hurt him. And what do 16 MR. EDWARDS: Object to the form. 17 you want in this lawsuit? Do you want money? 17 THE WITNESS: It doesn't matter. It doesn't 18 A. I want something that will hurt him. 18 matter. That is not the point. 19 Q. Okay. And what is that? 19 BY MR. CRITTON: 20 A. Whatever he's got. 20 Q. So whether it's a dollar or a million dollars 21 Q. What do you mean, whatever he's got? 21 doesn't make any difference to you? 22 A. Well, if he loves money, and I can take that 22 MR. EDWARDS: Object to the form. 23 away from him, then I hurt him. 23 BY MR. CRITTON: 24 Q. So you're asking for money in this instance 24 Q. It's just getting sane money from 25 from him; correct? 25 Mr. Epstein; is that true? Page 107 Page 109 1 MR. EDWARDS: Object to the form. 1 A /40. 2 BY MR. CRITTON: 2 Q. Okay. Well, what — what do you want, then, 3 Q. Do you know whether you're asking for money 3 from Mr. Epstein? What do you think this case is about? 1 in this instance? 4 A. Getting justice. 5 A. Yes. 5 Q. Okay. And how would you intend to get 6 Q. How much money do you want? 6 justice? What's your perception of getting Mister -- 7 A. I don't care. 7 justice for Mr. Epstein? 8 Q. A dollar? A hundred dollars? 8 A. Well, he hurt me and changed my life, and 9 A. I don't care. 9 that's what I would like to do to him. 10 Q. Do you know what you've asked foe? 10 Q. What? To hurt him and change his life? 11 A. No, 11. A. Yes. 12 Q. How much money do you want in this how 12 Q. But you have no idea whether you want a 13 much money would you like to -- in order to resolve this 13 dollar in this case, a hundred thousand dollars, more or 14 case with Mr. Epstein, how much money would you take? 14 less; is that a fair statement? 15 MR. EDWARDS: Object to the form. 15 MR. EDWARDS: Object to the form. 16 THE WITNESS: Whatever would hurt him. 16 BY MR. CRITTON: 17 BY MR. CRITTON: 17 Q. Is that true? 18 Q. Okay. So you want to hurt Mr. Epstein, as 18 A. I just want to take something from him. 19 distinct from really getting any money yourself; is that 19 Q. Okay. And whether ifs a dollar or a hundred 20 a fair statement? 20 dollars or a hundred thousand dollars, you don't care 21 A. I don't understand. 21 one — 22 ' Q. Okay. Well, if you want to hurt Mr. Epstein 22 MR. EDWARDS: Objection to the form. Asked 23 by taking money, then what do you want for yourself? 23 and answered. 24 A. I want — 24 BY MR. CRITTON: 25 Q. Where do you think the money is going to carte 25 Q. You just want something from him; true? 28 (Pages 106 to 109) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) PfeeeS21.3493-40ed-8666-00e698ca2735 Electronically signed by Pamela Sullivan (501-333-772.1552) EFTA00750734 Page 110 Page 112 1 A. No. 1. 2 Q. What do you want, then? 2 3 A. I want something that will cause him damage, 3 4 something that will hurt him like he hurt me. 4 5 Q. And what is that something? S 6 A. If there's nothing else, its obviously that. 6 7 Q. It's money. So how much? 8 A. I don't know. 9 Q. Let me ask you: On the back to the FBI. 10 Did you ever tell — when the FBI left that day, did you 10 11 tell your grandmother what your conversation had 11 12 consisted of? 12 Q. Where does he live, or where did he live at 13 A. No. 13 the tint? 14 Q. Okay. Did you tell anyone at that time? 14 A. He— he was living with 15 A. No. 15 Q. Does he still? 16 Q. Again, at some point, then, you got this card 16 A. No. 17 from Mr. Edwards — from Mr. Edwards about — let me 17 Q. He moved out? Did — 18 start again. 18 A. Yes. 19 At some point you got a card that had 19 Q. When he would take you to Mr. Epstein's 20 Mr. Edwards' name on it, law offices of Brad Edwards or 20 house, would he wait for you? 21 something like that; correct? 21 A. No. 22 A. Yes. 22 Q. He would just drop you off? 23 Q. AU right. So people just generally don't 23 A. Yes. 24 give out lawyer cards to individuals for no reason at 24 Q. On how occasions did 25 all. What occurred? What did you say? You must have 25 you take you? Page 111 Page 113 1 said something to somebody that resulted in you getting 1 A. About two. 2 Mr. Edwards' card. 2 Q. Did anyone else drive you to Mr. Epstein's 3 MR. EDWARDS: Object to the form. 3 home, other than your uncle and 4 BY MR. CRITTON: 4 A. Cabs. 5 Q. And I want to 'mow — 5 Q. Okay. Separate and apart from a cab. 6 MR. EDWARDS: It's been asked and answered. 6 A. No. 7 BY MR. CRITTON: 7 Q. At the time you saw Mr. Edwards for the very 8 Q. — what was that? 8 first time, bade. already retained his services? 9 A. Well, obviously, it was somebody who knew. 9 MR. EDWARDS: Object to the form. 10 Q. Who was that person who knew? Who had you 10 THE WITNESS: I don't latow. 11 told about what had occurred at Mr. Epstein's or that 11 BY MR. CRITTON: 12 you had been to Mr. Epstein's, other than your 12 Q. Had.. retained his services? 13 grandmother, who knew you had gone; right? 13 MR. EDWARDS: Same objection. 14 A. Yes. 14 THE WITNESS: I don't know. 15 le Okay. — and I think you told us earlier 15 BY MR. CRITTON: 16 your sister, knew you bad gone, because she 16 You were aware that Mr. Edwards represents 17 had driven you on a number of occasions, three or four 17 M. and M., in addition to you? 18 times; correct? 18 MR. EDWARDS: Objection. Don't answer. 19 A. Yes. 19 Attomey-client privilege. 20 Q. All right. Had anyone else taken you or 20 BY MR. CRITTON: 21 driven you to Mr. Epstein's home, other than 21 Q. Well, I don't want to know what he's told 22 A. Yes. 22 you. Are you aware that Mr. Edwards represents 0 23 Q. Who? 23 MR. EDWARDS: Outside of any conversations 24 A. My uncle. 24 I've everhad with my client? 25 Q. What's his name? 25 MR. CRITTON: Sure. 29 (Pages 110 to 113) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772-1M) Electronically signed by Pamela Sullivan (601.333-772.1562) f7eae621349340cd.8666.00e698ca2736 EFTA00750735 Page 114 Page 116 I. BY MR. CRIITON: 1 through today's date? 2 Q. She's told you that; hasn't she? 2 A. No. 3 A. What? 3 Q. Okay. Not even casually? Not over the 4 Q. has told you that Brad Edwards 4 phone, not when you would get together? When you would 5 represents her; hasn't she? 5 get together, you two would just simply not talk about 6 A. She may have. 6 these lawsuits at all; correct? 7 Q. Olten iAnd — and you know that Brad Edwards 7 A. Yes. 8 represents M., separate and apart from anything a Q. Okay. Same thing with M. is, is that, even 9 Mr. Edwards has told you; true? 9 though you would see each other or talk with each other 10 A. III. may have told me before. 10 occasionally, or once a month, as you -- I think you've 11 Q. And you're aware that Mr. Edwards, separate 11 described, or once every other month, as you've 12 and apart from anything that Brad may have said, 12 described, you've never discussed the lawsuits at all; 13 represents too, t-o-o; correct? 13 correct? 14 A. Excuse me? 14 A. Yes. 15 Q. Separate and apart from anything Mr. Edwards 15 Q. Thais correct? 16 told you, you're aware that M. is a — is a Plaintiff 16 A. Yes. 17 She's suing Mr. Epstein, as well; right? You're aware 17 Q. Let me show you what Fll mark as Exhibit 2. 18 of that fact? 18 rib just write -- handwrite down at the bottom for 19 A. I have never spoke about this really with 19 right now, and then Pamela can come back and do 20 21 • Q. So it's your testimony that you have never 20 21 something with it. And that's for you. 22 discussed the fact, even, that Mr. Edwards represents 22 (Defendant's Exhibit No.2 was marked for 23 you in a lawsuit against Mr. Epstein? You've neva 23 identification.) 24 discussed that with ■ at any time up through today's 24 BY MR. CflITTON: 25 date, which is September 30, 2009; correct? 25 Q. This is a document entitled, In Re: Page 115 Page 1', 1 MR. EDWARDS: Object to the fan 1 Jane Doe, Emergency Victim's Petition for Enforcement of 2 THE WITNESS: I'm not sure. 2 Crime Victim's Rights. And that's your copy. 3 BY MR. CRITION: 3 Take a look at that, if you would, please. 4 Q. Nov you're not sure. 4 MR. EDWARDS: Do you want her to read the 5 Is — is — were you aware that M. well, 5 whole thing? Is that what you're asking her to do? 6. let me strike that. 6 MR. CIUTTON: Just look at just look -- 7 Has M. ever told you that she — that 7 just locdc at the — 8 Mr. Edwards represents her? 8 MR. EDWARDS: The style or something. 9 A. Not specifically, no. 9 MR. CIIITTON: — look at the tint page. 10 Q. How about =specifically? 10 BY MR. CRITTON: 11 MR. EDWARDS: Object to the form. 11 Q. Does anything on this first page look in any 12 BY MR. CRIITON: 12 way familiar you to, ma'am? 13 Q. What do you mean by, not specifically? 13 A. You mean, have I ever seen this? 14 A. She has not actually said to me, Brad Edwards 14 Q. Yes. 15 represents me. 15 A. No, l haven't 16 Q. And ill understood your testimony earlier, 16 Q. All right. This was a pleading that 17 you — you have never discussed — she's never discussed 17 Mr. Edwards filed on behalf of a Jane Doe on July 7th, 18 any aspects of her lawsuit with you since the time it 18 2008. And it's to assert -- at least the allegations 19 was filed; correct? 19 are that -- that the Jane Doe, as a minor child, was a 20 A. Yes. 20 victim of Federal crimes. And — and then it goes on to 21 Q. Okay. And a., while she represented to you 21 attempt to assert certain rights. 22 or told you that Mr. Edwards represents her, has she 22 Are you the Jane Doe who's in this lawsuit? 23 ever discussed her lawsuit — 23 Do you know whether you're the lane Doe who's in this 24 A. No. 24 lawsuit? 25 Q. -- up through from the time it was filed up 25 MR. EDWARDS: Object to the font VIIICL=ICgde—CPZ—,laitus•ahfe.e.ALA.... 30 (Pages 114 to 117) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signod by Pamela Sullivan (501-333-772-1552) f7s0214493-40448446404691k427218 EFTA00750736 Puy. Page 120 THE WITNESS: I don't know. 1 agreement? BY MR. CRITTON: 2 A. Yes, I have. 3 Q. Well, you've never given Mr. Edwards 3 Q. All right. And do you have it in your 4 permission to file any lawsuit, other than the lawsuit 4 possession -- not today, but do you have a copy of it at 5 that's currently pending; is that correct? 5 home? 6 A. I'm sure that if he asked, I would, without 6 A. Yes, I do. 7 even reading. 7 Q. Okay. And did you review it? Q. Okay. Well, did you ever tell well, did 8 A. Yes, I did. 9 he let me strike that. 9 Q. And with the nonprosecution agreement -- 10 You just don't know whether you're this 10 excuse me — or looking at Exhibit 3, now, Victim's 11 Jane Doe — 11 Motion to Unseal Nonprosecution Agreement, are you 12 A. No, I don't. 12 Jane Doe One or Jane Doe Two? 13 Q. - in this lawsuit; correct? 13 MR. EDWARDS: Object to the form. 14 A. That's correct. 14 BY MR. CRITTON: 15 Q. Let me show you Exhibit 2 (sic). 15 Q. Or do you know? 16 MR. CRITTON: And I'm going to blot out with 16 A. I don't blow. 17 the copy that I give the Court Reporter, because 17 Q. Would it be a cored statement as to 18 it's just my initials. There's a reference here, 18 Exhibits 2 and 3, you've never seen those exhibits 19 and then my initials and an F, for filing. And 19 before today's date? 20 I'll blot that out on the exhibit that we use, if 20 A. I could have, without remembering. 21 that's okay with everyone. 21 Q. But at least as of today's date, you're not 22 (Defendant's Exhibit No. 3 was marked for 22 sure, one way or the other; is that correct? 23 identification.) 23 A. Not sure, no. 24 BY MR. CRITTON: 24 MR. CRITTON: Let me show you what I'll mark 25 Q. Let me show you Exhibit 2 (sic) — 25 as Exhibit 4. Page 119 Page 121 1 MR. CRITTON: Here's your copy, Brad. 1 And here's your copy, Brad. 2 BY MR. CRITTON: 2 (Defendant's Exhibit No. 4 was marked for 3 Q. — Em sorry, Exhibit 3. 3 identification.) 4 And this document is entitled Victim's Motion 4 BY MR. CRITION: 5 to Unseal Nonprosecution Agreement. And it looks — it 5 Q. And this is Declaration of appears to be a pleading that was electronically filed in Support of the United States Response to Vi 's 7 by Mr. Edwards on or about September 25th of '08. 7 Emergency Petition. And it was — at least, it was 8 And if you will just read excuse me -- the 8 entered on the system on July 15th of '08, but there's a first paragraph refers to now, it's the — it's the same stamp for July 9th of '08. 10 case style, except now there's a Jane Doe One and a 10 Do you know who is? 11 Jane Doe Two that are referenced — excuse me — that 11 A No, I do not. 12 Mr. Edwards represents. And it's a Motion to Unseal the 12 Q. I would represent to you that -- let me 13 Nonprosecution Agreement that has been provided — that 13 strike that. 14 was provided to both Jane Doe One and Jane Doe Two. 14 Do you know what an affidavit is? 15 Do you know what the -- ifI use the term 15 A. No, I don't. 16 nonprosecution or NPA, does that mean anything to you? 16 Q. Ora declaration is? 17 Or aml — 17 A No. 18 A. Yes. 18 Q. Okay. Do you 'mow what an — and I think you 19 Q. — speaking Greek? 19 said you don't know what an affidavit is, either; 20 A. Yes. 20 correct? 21 Q. I'm speaking Greek? 21 A. No, I do not. 22 A. No. 22 Q. All right. When you signed your 23 Q. You understand what it is? 23 interrogatories in this case that — you received 24 A. Yes. 24 written questions from me that I seat to your lawyer. 25 Q. Okay. Have you seen the nonprosecution 25 You and your lawyer put together the answers, and you 31 (Pages 118 to 121) (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 (5014334724552) freat6214493-40014666-006698ca2735 EFTA00750737 Page 122 Page 124 1 had to sign an affirmation or an oath that everything 1 question was wrong, here is the correct answer. Are you 2 set forth on those answers to interrogatories, other 2 aware of any document that's been prepared that you've 3 than the objections, was true and correct, under penalty 3 signed that said, prior answers to interrogatories were 4 of perjury; do you understand that? 4 wrong, these are correct, these are the new — the new, 5 A. No. 5 improved version, or the better answers? 6 Q. Okay. Do you remember signing 6 MR. EDWARDS: Object to the form. 7 interrogatories that said these are my answers to 7 THE WITNESS: No. 8 written questions? a BY MR. CRITTON: 9 A. What questions? 9 Q. All right. Anyhow, let me get back to 10 Q. Okay. Do you ever remember answering some 10 Exhibit — 11 questions in this case? 11 MR. CRTTTON: How much time do I have? 12 A. Yes. 12 VlDEOGRAPILER: One minute. 13 Q. Okay. And I assume — and I dont want to 13 MR. CRITTON: Okay. Let's take a break. 14 know what Mr. Edwards said -- but I assume that you 14 VIDEOORAPHER: Off the record at 11:34. 15 worked with your attorney to get the correct answers or 15 MR. CRITTON: Let's take five. 16 responses to those questions; true? 16 (A brief recess was taken.) 17 A. What questions are we talking about? 17 (Continued in Volume II of the same clay.) 18 Q. Well, you've only received one set of written 18 19 questions in this case; correct? That is, I sent you 19 20 questions like, state your name and address, et cetera. 20 21 A. Oh, okay. Yes. I do know. 21 22 Q. All right. And you answered them in 22 23 conjunction with your attorney? 23 24 A. Yes. 24 25 Q. All right. And when you finished answering 25 Page 123 Page 125 1 those question; you reviewed them to make sure that 1 2 they were accurate; correct? 2 CERTIFICATE OF OATH 3 A. There were some that were not 3 THE STATE OF FLORIDA 4 Q. Okay. Well, at the time you reviewed did 4 COUNTY OF PALM BEACH S S you review than at the time and sign them, under penalty 6 of perjury? Well get to that later, but you remember 7 I, the undersigned authority, certify that 7 answering the questions and then signing your name; JANE DOE personally appeared before me and was duly 8 correct? 9 sworn. 9 A. I answered them over the phone. 10 10 Q. That's not my question. Do you remember 11 Dated this 13th day of October, 2009. 11 signing them? 12 12 MR. EDWARDS: Object to the form. 13 14 13 BY MR. CRITTON: 15 14 Q. Did you -- do you remember giving answers to 15 your attorney or a representative in his office, in 16 Pamela J. Sullivan, RPR, 16 order to answer those questions? Notary Public - State of Mon 17 A. I answered these questions over the phone. 17 My Commission Expires: June 10,2010 18 Q. Okay. So is -- if you answer something over My Commission No.: DD 560380 19 the phone, they don't have to be true, but if you answer 18 20 something in person, it does have to be true; is that 19 21 how you interpret the law? 20 21 22 A. No, but there were some things that he 22 23 obviously typed up smog. 23 24 Q. You've never filed any -- at least as of 24 25 today I haven't seen any document that says, that 25 32 (Pages 122 to 125) (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) f7eae621-349340cd-8666-00e698ca2735 EFTA00750738 Page 126 Page 128 i CERTIFICATE 1 CERTIFICATE 2 THE STATEOF FLORIDA 3 COUNTY OP PAIDA BEACH 2 4 3 IIIE STATE OF FLORIDA 5 1, Pamela J. Sullivan, Registand Proessicnal 4 COUNTY OF PALM BEACH Court Reporter and Notar). Public in rid for the Sute of 6 Florida r large, do Imeby certify that I was 5 I horeby certify that I have read the foregoing atahorized to and did ropar said deposition in 6 deposition by me given, and that the statements 7 stenotype; and that the fortraina pages ase a true arid circa transcription of my shortband notes of said 7 contained herein are true and conect to the best of my 8 deposition, 8 knowledge and belief, with the exception of any 9 1further ceztify that said depceition was taken at 9 com:ctions or notations made on die errate sheet, if the time and piacei hereinabove set fortl. and that die 10 uting of seid depositicen was commenced and conipleted as 10 one was executed. hertinabove set out 11 11 I fintier catify Madam not attorney or counsel 12 Dated this day of 2009. 12 of any of the partiell, nor am la relative or employee 13 ofany atomey a counsa ofparty cmmied with the 14 13 anion, na am I financially interested in the action 14 The fcregoing certification ofthis transeript dem 15 not apply to any repeoduceon of the time by any means 16 15 urless ude et direet control and/or direction of thc 17 oertifying reperter. 16 JANE DOE Dated this llth day of October, 2009 18 17 18 19 19 20 20 21 21 Pamela I. Sulirwn, RPR, FPR, 22 22 23 23 24 24 25 25 Page 127 Page 129 1 Onder /3,2200 1 2 IiiiNEDDE ERRATA SHEET CaeIsADI. EDWARDS.11891.11RE 2 INRE JANE DOE V. JEFFREY EPSTEIN 3 RemisParerüldiAdls 114.9 CiiiiOne. Dale 100 3 at PAMELAJ. SULLIVAN, RPR, FPR, CLR 40/ ridt Lee (11016/214ved 4 DEPOSITION 0P: JANE DOE Poft laudeda 14.33301 5 DATE TAREN: Stramber 30, 2009 tNPI* MORI STYLE 6 DO NOT WRITE ON TRANSCRWT • ENTER CHANOES HERB 6 CA515103.: Ceeleil01194.LARRAMIOINSON PAGEN UNEN MANGE D•42>e 1.0Der 7 REASON a 11/01.Wim4n4aMWØ.sdey,au4PN 9 30,21/09.Wegienstur demdito it Ae abeeirefeced mau Jid du dee )av bei ni wirre alsmuse 6 8 li idnetteeetry rsur &Feakts 10 Aspealeiedy egeed stnezde eilte 9 MISS le tbeeith » 46 cet 0464611rce 11 Flairdit Meist res0the Wiede imtuctim melde 12 10 N leetiedefüre timain Auafind ist etwa Ehen )ouread yott depoidott gory chär..ges 11 13 awnnaMtar tivviihbieakedeutdhmneEM 12 Ihc stuLl ihre. Øt W0° lad line miete «seil 14 chuir. DO NOT veseorobc bansirFt ies,X Ora 13 >eu Arm iutdwa trinielpi W Nee anYelurYPt le IS sm so 644:6 axl *KM mauIkeund Teen iscie mim, reize 15 14 11)in de admirliad enlimiladde0 • itaimige daie,Seardt Malm der beiz 16 :2 ftesarile0 lad 111»warlebo OS %et 17 Gek eil•Coin. MWbWveyes 10 alrqaat*yatiidlnYbMrYteecmd 16 IS 19 Name forvaud the original signed enata sheet to this womencen, Office so that copies may be distributed to all panis. 20 20 21 Paneh me.1229.)714. alt Under patze ofixejury, l declare the I have read my 22 heia ConItig Atem% It 21 deposition and that it is ane and torosa subjett to Cee Clertie 23 265 $ Aintrulen Amts. See »00 any changes in form or surtana enered hat. FIMdalle) 22 24 I do Well rin,' iny rtgroin 23 DATE: 26 24 .1.`e Dö2 JANT DOE 25 SIONATURE OF DEPONaTP _ 33 (Pages 126 to 129) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronicalty signed by Pamela Sullivan (501-333-772-1552) Electronically signod by Pamola Sullivan (601-333-772-1552) freas621•3493-40cd.8666-00e698ca2735 EFTA00750739