EFTA00750774

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME III 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 (6014334724662) Electronically signed by Pamela Sullivan (601-33S-772-1552) 9205b62-38a5-4202-0350-6633a5c6813b EFTA00750774 Page 261 Page 263 APPEARANCES 1 On behalf of the Plaintiff. /me Deo BRAD J. EDWARDS, ESQUIRE 2 INDEX ROTHSTEIN ROSENFELDT ADLER 3 --- Lea au ON Cate, Suite 1650 401 East Las Otat Beamed 4 %WINES& DIRECT CROSS REDIRECT RECROSS Fart Lade/dal. Hooch 33301 5 JANE DOE 6 BY MR. CRITTON 5 0.1 behalf of the Defeedmu, kffrey Epstein: 7 ROBERT D. CRITTON, 3R. ESQUIRE BURMAN, CIUTPON, CUTTER & COLEMAN, LIP 9 303 Behan Bculevard EXHIBITS MARKED Suite 400 9 10 Nash him Bach Ronda 33401 10 11 11 PAGE 12 On behalf efthe Deem/bet. Jeffrey *Kit DESOUPTION 13 JACK ALAN OOLDBEROER, ESQUIRE 12 ATTERBURY, GOIDBERGER & WESS, PA Defendants No. 6 390 14 250 AuMeliat Aram Sotth WM 1400 13 (Plaintiffs AGSMs to Defendant's Interrogatories) 15 Wall Pam Beach, FIceicla 334014012 14 Defendants No. 7 16 On WWI of Itbittiff r Related Carr No. 01680469: 1, SIDRO M. GARCIA, ESQUIRE (Ur to Edwards from Critton %%Enclosures) GARCIA LAW FIRM, PA 15 18 224 Dama Seth Suite 900 11.1113401 16 19 17 Marked off the record.) 20 18 On behalf of hem Dom thmedh 19 21 ADAM D. HOROV/ITZ, ESQUIRE 20 22 MERMELSTEIN a HORMUZ P.A. 21 1820$ Blimp* Boulevard 23 Sulk, Z218 22 Miami. Florida 33160 23 24 24 25 25 Page 262 Page 264 1 On behalf of the Plaintiff CM.A.: 1 PROCEEDINGS 2 JACK P. HELL, ESQUIRE 2 SEARCY DENNEY SCAROIA BARNHART & SHIPLEY, PA 3 2139 Palm Beach Lalces Boulevard 3 (Continued from Volume II of the same day.) West Pabn Beach, Oneida 33409 4 BY MR. CRITTON: 4 5 Q. Ms. Jane Doe, other than speaking with your 5 On o . 6 attorney over the lunch hour, did you speak with anyone 6 ADAM J. LANGEt40, ESQUIRE 7 else? LEOPOLD KINN 8 A. No. 7 2925 PGA Boulevard, Sure 200 9 Q. Are you on any medication today? Palm Beach Galas. Florida 33410 10 A. No. 11 Q. 'When is the last time you had any pot, 9 12 marijuana? 10 13 MR. EDWARDS: Object to the form. 11 ALSO PRESENT: 12 Jeffrey Epstein, via video conference 14 BY MR. CRITTON: Stm Sanders, Videograptier 15 Q. And when I say had, smoke. 1.3 16 A. Before I was pregnant with my daughter. 14 15 17 Q. Okay. And its your testimony that, since 16 18 the time you've been pregnant, you have not taken — you 17 19 haven't smoked pot and you haven't taken any drugs or 18 20 alcohol Tm sorry — any illegal and/or — any 19 20 21 illegal drugs or prescription drugs that would have gone 21 22 to someone else, like a Xanax; is that correct? 22 23 MR. EDWARDS: Object to the form. 23 24 24 THE WITNESS: What was the question? 25 25 ..2 (P.ages_2_61 to 264) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. • • (561) 832-7506 • Electronically signed by Pamela Sullivan (501.3357724652) Electronically signed by Pamela Sullivan (501-333-7724552) 92eldb6248.5-42024360-6633a5e6813b EFTA00750775 Page 265 Page 267 BY MR. CARTON: 1 Q. You need to keep your voice up, because Pm 2 Q. Ifs your testimony that, since the time you 2 having trouble hearing you, ma'am. 3 were pregnant, you haven't had any illegal drugs and/or 3 A. She's okier than me. 4 any drugs that weren't prescribed specifically for you? 4 Q. Okay. And why did she live with you? 5 A. Yes, that's true. 5 A. ;guess her mom was staying in a — in an 6 Q. Okay. And you -- and you have roxy. I asked 6 Siend, and I guess efficiency, I guess, with her bc 7 you earlier whether you knew what that was. My 7 there really wasn't room forM. She didn't have 8 understanding is you smoke that; is that correct? 8 anywhere to live. 9 MR. EDWARDS: Object to the form. 9 Q. And were you living at 10 BY MR. CARTON: 10 house at the time? 11 Q. You — and it's a smokable drug? 11 A. Yes. 12 MR. EDWARDS: Object to the form. 12 Q. Okay. And how long did M. live with you? 13 1HE WITNESS: I have heard of people eating 13 A. A month or two. 14 them and snorting them and smoking them and 14 Q. AUSA. Since that other than that one 15 shooting them up. 15 time, has ever lived with you again? 16 BY MR. CRITTON: 16 A. No. 17 Q. Okay. And it's your testimony you've never 17 Q. Has she ever stayed with you again? 18 done those? 18 A. No. 19 A. Yes. 19 Q. Do you know where M. is right now? 20 Q. When is the last time you spoke with— well, 20 A. No. 21 I asked you a question earlier: Who else was living 21 Q. When is the last time you talked to M.? 22 with you and your boyfriend, MI, and your child at 22 A. Several months ago. I'm not sure. 23 your house? And your attorney instructed you not to 23 IIVOkay. And what was the event that caused you 24 answer. Do you remember that? 24 andM. to not be close anymore? 25 A. Yes. 25 A. She moved. Page 266 Page 268 1 Q. Okay. Is the person who — is it more than 1 Q. Just she moved? 2 one additional person who is living with you at that 2 A. She moved far away from me. I don't know 3 house? 3 where. And I guess she — I don't know. I guess she 4 A. No. 4 doesn't... 5 Q. Okay. Is that person still there now? 5 Q. Do you have her phone number? 6 MR. EDWARDS: Don't answer. 6 A. No. Other identifying information about the 7 Q. Okay. Did you have it before she moved? 8 address. I think it's — ifs pretty clear she's 8 A. Yes. 9 not going to answer anything that's going to 9 . Have you — when you've talked toM., does 10 indicate to you where' he's living currently. Now, 10 ever say,' -- I know where a. is, or I talked to 11 all other addresses, you know them, and she'll tell 11 . the other day? 12 you that. 12 A. No. 13 MR. CARTON: I understand. So my position 13 Q. And tell me when the last time was that you 14 is clear is that person that's been, apparently, is 14 spoke with M, 15 living there, she, she would have information — 15 A. Probably a month and a half, maybe two months 16 she or he would have Information regarding aspects 16 ago. 17 of the Plaintiffs claim clearly is a relevant 17 Q. Okay. Which would if we're in the end of 18 witness, and — 18 September, it would have been sometime in early or mid 19 MR. EDWARDS: Okay. 1understand. 19 July? 20 BY MR. CRITTON: 20 A. Yes. 21 Q. Has Ng ever lived with you? 21 Q. Okay. And did you only talk to her over the 22 A. Yes. 22 phone? 23 Q. Okay. When? 23 A. We went to the beach. 24 A. We were 14, I believe. She was 14, I was 13, 24 Q. Did you take your respective children? 25 because she's older than I am. 25 A. Yes. •.‘13, YacY•aa14,,V- 3 (Pages 265 to 268) (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) 92efSb62-38a5-4202-a350-6633a5c6813b EFTA00750776 Page 269 Page 271 1 Q. Okay. And you talked about this case; didn't 1 Q. Did M. ever tell you she was a call girl? 2 you — your cases? 2 A. No. 3 A. No, we did not 3 Q. You know what a call girl is? 4 Q. Subject never came up, is your testimony? 4 A. Yes. 5 k No. 5 Q. Did you ever ask M. if she was a 6 Q. That's correct? 6 prostitute? 7 A. That is correct 7 A. No. 8 Q. Other than that, have you seen or talked to 8 Q. Did you ever ask how she made her money? 9 M.? 9 A. No. 10 A. No. 10 Q. Is M. a prostitute? 11 Q. Okay. Well, didn't you baby-sit for MA 11 A. Not that I know of. 12 son? 12 Q. lies she am been a prostitute? 13 A. Yes. 13 A. Not that J 'mow of. 14 Q. Okay. When was that? 14 Q. Do you consider yourself to be a prostitute? 15 A. Ito not exactly sure. 15 A. No, l do not. 16 Q. Wasn't that after you went to the beach, 16 Q. Have you ever engaged in prostitution? 17 approximately a month and a half to two months ago? 17 A. Besides Jeffrey Epstein, no. 18 A. I don't remember if it was before or after. 18 Q. Well, what do you -- what do you consider a 19 Q. And did she drop how does — how — what 19 prostitute to be? 20 was the occasion that she asked you to sit for her son? 20 A. Somebody who gets paid for giving sexual 21 A. She had to wodc 21 favors. 22 Q. Where was she working? 22 Q. Separate and apart from any activities with 23 A. I think she was working in like a — like a 23 Mr. Epstein, have you ever performed or given sex, 24 skin care place. I'm not sure. 24 sexual favors, using your term, for money? 25 Q. How many times did you baby-sit for her son? 25 A. No. Page 270 Page 272 1 MR. EDWARDS: Object to the form. 1 Q. Now, you've worked at some strip clubs; have 2 BY MR. CRITTON: 2 you not? 3 Q. Or watch ber son? 3 A. Yes. 4 MR. EDWARDS: Ever, you mean? 4 And ou worked at -down in 5 MR. CR1TfON: Ever. 5 6 MR. EDWARDS: Eva. Okay. 6 A. Yes. 7 THE WITNESS: Probably like two or three 7 Q. -- true? 8 times. B A. Yes. 9 BY MR. CRITTON: 9 . . And I think you said you worked at 10 Q. Did she pay you? 10 for approximately eight months? 11 A. Yes. 11 A. Something Lice that, yes. 12 Q. How much did she pay you? 12 Q. Who was your boss, or who was the manager or 13 A. Well, she only paid me once, like S20 or 13 the person that you had to report to? 14 something. ' 14 A. The owner of the club was named 15 Q. Would you let ■ watch your daughter? 15 Q. Do you know what his last name was? 16 A. Absolutely. 16 A. No, I do not. 17 Q. Do you know M. to be or to have been a 17 • get — was — was anyone working 18 prostitute? 18 at• that you knew at the time you applied 19 A. No. 19 for the job, the position? 20 Q. You know what a prostitute is? 20 A. Yes. 21 A. Yes, I do. 21 • Q. Who? 22 Q. Did ■ ever tell you that she received 22 A. 23 money for giving sexual -- or performing sexual nets for 23 . And how was it that you came to get a job at 24 men? 24 that is, why? 25 A. No. 25 A. Urn. 4 (Pages 269 to 272) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 92ef5b62-35a54202-a350.6633a5c6813b EFTA00750777 Page 273 Page 275 1 Q. This was in 2006? 1 A. I was living with 2 A. It was after I was 18, so... I'm net sure 2 Q. And were you living at the apartment? 3 what year. 3 A. Yes. 4 Q. Well, you were bo correct? 4 Q. That's when she was living with a 5 A. Yes. 5 A. Yes. 6 Q. Okay. 6 Q. So you're living at the apartment, and thaim 7 All right? So if you worked seven months there or eight 7 tia you started — you knew she was working a 8 months, it would have been sometime after June — what imp so she said, why don't you come with me, or 9 would you say your birthday was? 9 something like that? 10 A. Seventeenth. 10 A. Yes. But this was the second time that I 11 Q. All right. Sometime after June 17th of '06, 11 lived with her. 12 probably miming into sometime in '07; true? 12 Q. I thought you said the second time was in 13 A. Yes. 13 2007. 14 Q. And sole— what caused you to get the 14 A. I just know that I had tuned 18 since I 15 job, or why did you come — why did you come to get a 15 started dancing, sol may have been close to 19 or 19 16 job at 16 when I did start 17 A. brought me there. 17 Q. Okay. Well, now, was III living at the 18 Q. Oksy. But your choice to go; right? 18 Royal Palm Bellaire, or was she living in the 19 A. Yes. 19 apartment with 20 Q. Okay. And what did you do — what did you 20 A. TIslizal Palm Beach place was an apartment, 21 or how did it happen that you went to get the job? 21 also, and also lived there. 22 was dancing there; you knew that? 22 Q. Okay. Well, you testified earlier that in 23 A. Yes. 23 2006 you spent a few -- a few months with her. 24 Q. Okay. And she was a stripper? 24 A. Ult-huh. 25 A. Yes. 25 Q. And then — and that was in the apartment in Page 274 Page 276 Q. Did she tell you how much money she made? 1 West Palm Beach. And then the second time, 1 thought 2 A. No. 2 you said you only spent about a month. I may have been 3 Q. Did she tell you what she had to do to earn 3 wrong. 1 money? 4 A. Yes, 1 did only spend about a month. 5 A. Dance. 5 Q. Okay. Was — and the one month was at the 6 Q. What else? Royal Palm Beach house? 7 A. Take her clothes oft strip. 7 A. Yes. 8 Q. All right. And did she — did she do — did 8 Q. Okay. s' r testimony that you 9 she do bachelor pasties? 9 went to work at in 2007? 10 A. Not that I know of. 10 A. That's possible. 11 Q. Okay. Did she do lap dances? 11 Q. Well, I don't know, because I wasn't there. 12 A. Yes. 12 That's why I'm just trying to ask. Because earlier you 13 Q. All right. And did she work the stage? 13 testified it was 2006, and I think that's what your 14 A. Yes. 14 answers to interrogatories reflect. So what is it? 15 Q. Did table dances, as well? 15 A. Well, it -- 16 A. They don't have table dances. 16 Q. What's the current answer? 17 Q. What do they have? Lap dances? 17 MR. EDWARDS: Object to the form. 18 A. Yes. 18 THE WITNESS: It was definitely after I 19 Q. And what did tell you about that work? 19 armed 18. 1 don't know exactly what day it was. 20 A. She just told me that, like, you had to go on 20 I don't know what month or year. I don't know. I 21 stage and dance, and that's how you made money, by 21 don't like write down, I started stripping today. 22 dancing. 22 No, !didn't do that. 23 Q. Did you say -- what were you doing at the 23 BY MR. CRITTON: 24 time? Where were you living in 2006 when you had just 24 Q. Do you ever keep diaries? 25 turned 18? 25 A. No. 5 (Pages 273 to 276) (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) 92et6b62-38a6-42024350-8833a6c6813b EFTA00750778 Page 277 Page 279 1 Q. Have you kept diaries? 1 Q. Okay. Because was when you were 17? 2 A No. Never. A. Yes. 3 Q. Have you filed any tax returns? 3 Q. So what other jobs did you — had you ever A. No. 4 applied for another job, other than I.? 5 Q. Have you ever filed a tax retum? 5 A. Yes. 6 A. No. 6 Q. Where? 7 Q. Have you ever consulted anyone about whether 7 A. At the mall. 8 you need to file a tax return? 8 Q. But no one had ever hired you? 9 A. No. 9 A. No. 10 1.1 12 that When you worked — so is it your recoiled ion . was living — or you were living with II. at Royal Palm, or West Palm, at the time you started 10 11 12 Q. So how many different places did you apply for a job? A. A few. Two or three, maybe. 13 stripping? 13 Q. So you applied for the jobs. You didn't get 14 A. Royal Palm. 14 those. You quit the job voluntarily, because you 15 Q. What work — before you started stripping, 15 didn't like it; right? 16 what work had you ever done to make money, other than 16 A. Right. 17 17 Q. Because you weren't getting along with whom? 18 A. Tithes it. 18 The boss? 19 ... and I think you told me about 19 A. No. 20 21 a. A. Yes. 20 21 Q. Who? A. It was actually M.'s brother that I was not 22 Q. That was like a, what, a week or a month or 22 getting along with. 23 24 25 something? A. A week. Q. Excuse tne. And that didn't work out; right? Page 278 23 24 25 nwhat? Q. What's his name? A. Q. Page 2.;Sfl 1 A. Right. 1 A. 2 Q. Okay. So the only odier'ob u've had in 2 Q. And why? Why weren't you getting along with 3 your entire life was working at E.? 3 him? 4 A. Yes. 4 A. Because he -- well, I thought that he stole 5 Q. OkaiyAnd why did you leave? Once you got 5 some money from the restaurant while I was working one 6 thejcb at as a waitress, why did you stop working 6 night. And he called me and said a bunch of nasty 7 at Mr/ 7 things to me, because I was basically implicating that 8 A. ljust — I don't know. Ijust didn't want 8 he had stolen some money from the restaurant. 9 to work there anymore. I guess I just wasn't getting .9 Q. Well, you believed it to be true? 10 along with everybody. 10 A. Yes. 11 Q. Okay. One month? 11 Q. Okay. And so what, what happened? 12 A. Yes. 12 A. He was just like really rude to me all the 13 Q. Okay. And you got salary or minimum wage? 13 time, and ho told me that he was like — I — I mean, I 14 A. Yes. 14 don't remember specifically what he said, but he told me 15 Q. Plus tips? 15 that, you lmow, he was going to like, you know, do 16 A- Yes. 16 something to hurt me or my family. 17 Q. How much money did you make there? 17 Q. So you stopped working. Did you tell M. 18 A Not very much. 18 that? 19 Q. All right. So now you're 18, or over 18, 19 A. Yes, I did. 20 maybe over — closer to 19. The onl er 20 Q. And so how, then, did you get the strip job? 21 had in your whole life is working at for minimum 21 M. said, well, why don't you come with me; you can 22 wage and tips; right? 22 strip. 23 A. Yes. 23 A. Yes. 24 Q. Had you been to yet? 24 Q. And did you say, l don't really want to be a 25 A. Yes. 25 stripper? 6 (Pages 277 to 280) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. ' (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1652) Electronically signed by Pamela Sullivan (501.333.772-1552) 9205662-36a5-4202-a350-6633a5c6813b EFTA00750779 Page 281 Page 283 1 A. At first I did, yes. 1 Q. Where did you get them? 2 Q. And so why did you do it? 2 A. I got a lot of them from the flea market. 3 A. Because I needed money. 3 Q. 45th Street? 4 Q. Well, you could have applied for other jobs; 4 A. Yes. 5 couldn't you? 5 Q. And they have stripper outfits'? 6 A. I tried to apply at a few places, and I never 6 A. Yes. 7 got the job. 7 Q. Did a show you any of her tricks of the 8 Q. Well, you applied for what, one or two places 8 trade, so to , so you could make money? 9 in the mall? 9 A. She just showed me how to dance. 10 A. I applied at some restaurants and some other 10 Q. Did she show you before you went up there 11 places I don't exactly remember. 11 that fast time? 12 Q. So you go down with to 12 A. Yes. 13 A. Yes. 13 Q. Where did you — did you practice at home — 14 Q. And you talked to1= 14 or at her home? 15 A. Yes. 15 A. No. 16 Q. Is he the one who hired you? 16 Q Where did you practice, or didn't you? 17 A. Yes. 17 A. At 18 Q. Did you have any experience dancing. 18 Q. So you ill:Practice during the day before 19 stripping? 19 you actually ended up on stage? 20 A. No. No. 20 A. Yes. 21 Q. And what did you have to do in order to get 21 Q. Did you know any of the other girls who 22 the job? 22 worked at before you went? 23 A. Show them my ID. 23 A. No. 24 Q. And did he say, have you stripped before? 24 Q. Did you ever work at a place where - 25 A. No. 25 worked? Page 282 Page 284 1 Q. Did he ask you any questions at all? 1 A. No. 2 A. No. 2 Q. Were you aware where worked? 3 Q. Had you ever danced before anyplace? 3 A. No. 4 A. No. 4 Q. Okay. Were you ever aware that 5 Q. Did tell you how — show you how you'd 5 6 have to dance, in order to make money? 6 at .A 10. 7 A. Yes. 7 Q. Do you know what a jack shack is? 8 . Oka . During the time you worked at 8 A. I've heard of it. did you have a stage name, or did 9 Q. Okay. Do you know whether M. worked 10 you just use your own name? 10 shacks? 11 A. Yes, I did. 11 A. Not that I know of. 12 Q. Yes, you did what? Have a stage name? 12 Q. Did you ever ask ha'? 13 A. I had a stage name. 13 A. Na 14 Q. What was your stage name? 14 Q. Do you know a lady -- a person named a? 15 MR. EDWARDS: Form. 15 A. No,I do not. 16 THE WITNESS: 16 Q. You sure? 17 BY MR.CRITrON: 17 A. Yes. 18 Q. 18 She's a fried ofE's. You don't know 19 20 A. Yes. Q. Okay. And what kind of outfits did you wear? 19 20 a? MR. EDWARDS: Object to the form. Asked and 21 Did you have one outfit that was like the -- your 21 answered. 22 trademark, so to speak? 22 THE WfTNESS: I don't know her. 23 A. No. 23 BY MR. CRITTON: 24 Q. What kind of outfits did you wear? 24 Q. What were your hours at 25 A. Stripper outfits; I don't know. 25 A. Seven to 2:00. 7 (Pages 281 to 284) (561) 8 32-7 500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1652) 92et5b62-38x5.4202.a350.6633a5c6813b EFTA00750780 Page 285 Page 287 1 Q. Seven p.m. -- 1 Have you ever had any kind of plastic surgery? 2 A. Yes. 2 A. No. 3 Q. — to 2:00 in the morning? 3 Q. Any kind of had any kind of breast 4 A. Yes. 4 implants? 5 Q. Okay. And how were you paid? 5 A. No. 6 A. Tips. 6 Q. In tents ofa in addition to Q. Did you have to share any with the house? 7 doing the dancing on the stage, did you ever do bachelor a A. Yes. 8 parties? 9 Q. And what was the percent that you got to 9 A. No. 10 keep, and the percent that you had to pay the house? 10 Q. Okay. Did you do lap dances? 11 A. I just had to tip the DJ and the manager like 13. A. Yes. 12 $15 each, or something. 12 Q. And how much did you charge for a lap dance? 13 Q. Okay. And how much did you make generally a 13 A. There was a house fee, so it was like 25 or 14 night? 14 $30 for like one song. 15 A. I don't know. Couple of hundred dollars. 15 Q. So in addition to your stage dancing, where 16 MR. EDWARDS: Speak a little bit louder, just 16 you get tips, you also did lap dances? 17 so that they can hear you. 17 A. Yes. 18 BY MR. CRITTON: 18 Q. All right. And 'Awe they friction dances? 19 Q. Couple ofhundred dollars? 19 A. Yes. 20 A. Yes. 20 Q. And in terms of the men that you — and these 21 Q. Okay. Did you ever make more than that? 21 were always all with men; I assume. Any women? Did you 22 A. Not really. 22 have to do lap dances for women at times, too? 23 Q. That was pretty much your average take? 23 A. Like once or twice. 24 A. Yes. 24 Q. And when you would do the lap dances for the 25 Q. How many days a week did you work? 25 men, in addition to the house charge, you would try to Page 286 Page 288 1 A. Whenever I wanted to. 1 do more so that you could get a bettor tip; true? 2 Q. All right. How many days a week did you want 2 A. No. 3 to work? 3 Q. Okay. Well, you were doing friction dances, 4 A. Sometimes it was every night; sometimes it 4 and flictice dances are where you're rubbing up against 5 was one or two nights. 5 the men; right? 6 Q. And how would you decide, just if you needed 6 A. Yes. 7 money? 7 Q. All right. And men get erections; truc? 8 A. Pretty much, or if I felt like it. 8 MR. EDWARDS: Object to the form. 9 Q. In addition to doing — you'd dance and you'd . 9 THE WITNESS: That's probably true, but I 10 take your clothes off; right? 10 never touched anybody at the strip club there. 11 A. Yes. 11 BY MR. CRITTON: 12 • Q. Okay. And did you take all your clothes off? 12. Q. OkaySo u're saying you danced for eight 13 A. Yes. 13 months at you're doing friction dances, 14 Q. Okay. Everything, tops and bottoms? 14 dancing with men, and it's your testimony you never 15 MR. EDWARDS: Object to the form. 15 know you never knew whether any of them ever got an 16 THE WITNESS: Yes. 16 erection; is that true? 17 BY MR. CRITTON: 17 MR. EDWARDS: Fenn. 18 Q. And you did that sometimes seven days a week, 18 THE WITNESS: Yes: 19 • sometimes only two or three or four times a week, for 19 BY MR. CRITTON: 20 eight months; is that correct? 20 Q. Did you -- did they have a champagne room. or 21 A. Yeah. Sometimes I didn't go for two weeks 21 some equivalent ofthat, at — excuse me — 22 and, you know, I — I just went whenever I felt like it. 22 23 I mean, sometimes I didn't go for a month. 23 A. Yes. 24 . Did — and and prior to starting at 24 Q. Okay. Did you ever go back into the 25 or let me ask you — ask you this: 25 champagne room? 8 (Pages 285 to 288) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 1561) 832-7506 Electronically signed by Pamela Sullivan (5014334124652) Electronically signed by Pamela Sullivan (601.333.772-1652) 92efSb62-38a5-4202-a350-6633a5c6813b EFTA00750781 Page 289 Page 291 1 A. Yes. 1 BY MR. CRITTON: 2 Q. On how many occasions? At least once a week? 2 Q. And did you get more money for that, as well? 3 Twice a week? More? 3 A. Yes. 4 A. I don't — 4 Q. Okay. And did you strip naked in the 5 MR. EDWARDS: Form. 5 champagne room? 6 THE WITNESS: I don't know. Once a week. 6 A. I didn't take my bottoms off. 7 BY MR. CRITTON: 7 Q. Took your top off? 8 Q. All right. And when you would go back in the 8 A. Yes. 9 champagne room, it would be you and — and just one man, 9 Q. And then you did a — would it be a fair 10 generally? 10 statement to say that would have been a serious friction 11 A. And a bouncer outside the door. 11 dance in the champagne room? 12 Q. Okay. So ifyou needed help, or if 12 A. No. It just made it so that other people 13 something -- • 13 couldn't see. 14 MR. EDWARDS: Form. 14 Q. All right. Well, is — isn't it true, when 15 BY MR. CRITTON: 15 you went into the champagne room, there's — oftentimes 16 Q. — happened that was inappropriate, then you 16 there was some form of sex that occurred? 17 can call for the bouncer? 17 MR. EDWARDS: Fenn. 18 A. Yes. 18 THE WITNESS: That is not true. 19 Q. Okay. And just when you were at -- when you 19 BY MR. CRITTON: 20 were at that club, if something inappropriate happened, 20 Q. So it's your testimony that in all of the 21 you could turn around and say you could leave the 21 times that you went in the champagne room, that you 22 room; right? 22 never had any type of sexual activity with the men in 23 A. Yes. 23 the champagne room? 24 Q. All right And you — and you knew that -- 24 A. That is correct 25 A. Yes. 25 Q. And consistent with what you told me earlier, Page 290 Page 292 1 Q. — that if something inappropriate happened, 1 you never even saw whether a man got an erection when 2 and that you could leave the room, because it was -- it 2 you were in those rooms; is that your testimony? 3 was voluntary for you to either go into the room or not 3 A. Yes. 4 go into the room? 4 Q. During the time you worked at 5 A. Yes. 5 how many men did you go home with? 6 Q. You could stay as long or as little as you 6 A. Zero. 7 warn? 7 Q. In addition to -- did you ever do a bachelor 8 A. No. 8 party? 9 Q. Well, you could leave, if the — what you 9 A. No. 10 felt the man's conduct was inappropriate; true? 10 Q. Did you ever do a strip-o-gram? 11 A. Yes. 11 A. No. 12 Q. Did you ever have to call a bouncef/ 12 e and apart from the dancing you did 13 A. Yes. 13 at did you ever go to anyone's house to 14 Okay. Did any male at that —atIMMI 14 perform any type of strip tease services? 15 MB ever try to attack you, to we force? 15 A. No. 16 A. I — I don't — I wouldn't really say that 16 Q. lf someone would testify that you had, that 17 anybody tried to attack me, but there have been a few 17 person would be saying would be not telling us the 18 times where a man like tried to grab me and pull me on 18 truth? 19 top of him, and I had to call somebody to help me. 19 MR. EDWARDS: Object to the form. 20 Q. Okay. And when you were in the champagne 20 BY MR. CRITTON: 21 room, they'd — the men paid more for that; did they 21 Q. Is that correct? 22 not? 22 A. Absolutely. 23 MR. EDWARDS: Object to the form. 23 Q. Did you like stripping? 24 THE WITNESS: Yes. 24 A. No. 25 25 Q. Why did you do it, then? 9 (Pages 289 to 292) (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) 92ef5b62-38351202.3350-6633a5c6813b EFTA00750782 Page 293 Page 29 1 A. Because I needed money. 1 A. No. 2 Q. For what? 2 Q. Why not? 3 A. To live. 3 A. I guess they weren't hiring. I don't know. 4 ..thought you were living with — with. 4 Q. Okay. Did you keep going back? 5 at this time. 5 A. Yes. 6 A. Yes. 6 Q. Say, I have experience? 7 Q. Okay. Well, you said earlier that she 7 A. Yes. 8 supported you. 8 Q. How many places do you think you applied 9 A. Would you like to be 18, asking. 9 before you started stripping? 10 for money? 10 A. I don't know. 11 Q. My question to you is: You told me that she 11 . iftierTu left then you went 12 13 was supporting you. Did you tell au were stripping? 12 13 toi A. Yes. 14 MR. EDWARDS: Object to the form. 14 Q. Were you still living with 15 THE WITNESS: Yes. 15 A. Yes. 16 BY MR. CRITTON: 16 Q. Were you dating anybody at this time period, 17 Q. Okay. And what did she say? 17 this time period being were you dating anybody during 18 A. I don't know. 18 the time you were wo 19 Q. She had to have said something. Did she ever 19 A. I started seeing at the time. 20 say, you don't — I don't want doing that? I'll 20 Q. And that would have been in 2007? 21 help you get a job a You can come to work 21 A. Yes. 22 for me. I'm a manager; I can help you get a job. 22 Q. Okay. And when did you and start 23 A. No. 23 living together? 24 Q. And did you ever sa h , M, can you 24 A. I believe it was August of'07. 25 help me get a job at I'd like to — 25 Q. Is he employed? Page 294 Page 296 1 like to work at You know TM smart. You 1 A. Not currently. 2 know I'm qualified. I can do something there. Can you 2 Q. Has he ever been? 3 help me do theft 3 A. Yes. 4 A. I can't work at because I live 4 Q. What kind of work did he do? 5 with her. 5 A. He worked at washing cars. 6 Q. Okay. Well, did you say, can you help me get 6 Q. What's his educational background? 7 a job someplace else then? 7 A. He dropped out in the tenth grade. 9 A. No. 8 Q. Is he a Palm Beach County person? 9 Q. Why not? 9 A. 10 A. Because I tried before. 10 Q. When is the last time — when you met him, he 11 Q. Well, if I send you an interrogatory that 11 was working for 12 says, tell me all the places you applied, I should be 12 A. No. 13 able to get applications of all these places that you 13 Q. Who was he working for, or was he not 14 applied; right? 14 working? 15 MR. EDWARDS: Object to the form. 15 A. He was not working at the time. 16 THE WITNESS: So what do you mean? You want 16 Q. Okay. When you started living together in 17 the applications that I -- 17 August of'07, did he have a job? 18 BY MR. CRITTON: 18 A. He afterward. 19 Q. • Yeah. How many places did you ever apply 19 Q. At 20 before you started stripping? 20 A. Yes. 21 A. I don't know. I went to 21 Q. And how long did he work with IM? 22 Q. Two or three? 22 A. He worked at a restaurant in Boca for like 23 A. I went to the few places at the mall, and I 23 eight months, l think, or seven months, maybe. And then 24 went to all the restaurants that were around my house. 24 he didn't have a job for, oh, probaayieven months 25 Q. And nobody would hire you? 25 again, and then he got the job at =. SMIL• 44•45... .-.4.,••••01.7a.".•....4...n.le...... , W• J %Ps 10 (Pages 293 to 296) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan ([01.933.772.1652) Electronically signed by Pamela Sullivan (601-333-772-1552) 92ef5b62-38a5-4202-a350-6633a5c6813b EFTA00750783 Page 297 Page 299 1 Q. But Ws -- are you saying he's working there 1 A. For sale of cocaine. 2 now? 2 Q. So he's a drug dealer —or was a drug 3 A. He is not working there now. 3 dealer -- 4 Q Okay. How long did he work -- at the Boca 4 MR. EDWARDS: Farm. 5 resAA uartt which restaurant did he work at? 5 THE WITNESS: He — 6 ). 6 BY MR. CRITTON: 7 Q. Doing what? 7 Q. — is that true? 8 A. Bus — busboy. 8 A. He got cocaine from a friend of his and sold 9 Q. Okay. And then he was off for aboutak- 9 it to somebody else and — 10 even months, and then he got ajob wit six or s 10 Q. So he's a drug dealer; he sold drugs? 11 11 MR. EDWARDS: Form. 12 A. Yes. 12 THE WITNESS: That was not his occupation. 13 Q. Okay. How long did he have that job washing 13 He actually was doing it like as like a one-time 14 cars? 14 thing, and — 15 A. Fm not sure. Probably about the same length 15 BY MR. CRITTON: 16 of time. 16 Q. Being a good neighbor? 17 Q. All right. When — and when did he get — 17 MR. EDWARDS: Form. 18 did he get laid oft; or fired in — well, let me strike 18 THE WITNESS: -- ended up getting caught. 19 that. 19 BY MR. CRITTON: 20 From the restaurant job, did he get laid off, 20 Q. How long has he been using drugs? Since you 21 or fired? 21. two have been dating? 22 A Fm not exactly sure. 22 MR. EDWARDS: Form. 23 Q. Okay. How about-? 23 THE WITNESS: He has not used drugs since I 24 A He - he got another job as a telemarketer. 24 was pregnant with my daughter. 25 and so quit the job ail". And then the 25 Page 298 Page 300 telemarketing job didn't work out. 1 BY MR. CRITTON: 2 Q. What was that, last for a month or I ing? 2 Q. Okay. Well, when did he when did he get 3 A. He was -- he stayed there for about three 3 charged with sale of cocaine? 4 weeks, maybe a month, and didn't make any money, so he 4 A. Over a year ago. S ended up having to leave them. 5 Q. Okay. Well, a year ago your daughter had 6 Q. And you say a Boca restaurant. Do you think 6 just been born. Your daughter is a little over a year 7 he was terminated? 7 old right now; right? 8 MR. EDWARDS: Form. 8 A Probably about two years ago. 9 THE WITNESS: I know that he was terminated. 9 Q. Two years ago what? 10 I don't know if he was laid off or fired, though. 10 k He was charged. 11 BY MR. CRTITON: 11 Q. Oh, okay. I thought you said a year ago. 12 Q. And - and with the telemarketing job, when 12 MR. EDWARDS: Form. 13 did he last have the telemarketing job? 13 THE WITNESS: I said over a year ago. 14 A. About a month or two ago. 14 BY MR. CRITTON: 15 Q. Is he out looking fora job? 15 Q. Oh, over a year ago. 16 A He is trying to get a job, yes. 16 So how long has he been on house arrest? 17 Q. Okay. Does he have any type of criminal 17 A. One year. 18 record? 18 Q. Has he been — so he hasn't been able to 19 A. Yes. 19 work? 20 Q. For what? 20 k Yes. 21 A. He is — 21 Q. He has been? 22 MR. EDWARDS: Form. 22 A. He's allowed to work. 23 TI/E WITNESS: He's on house arrest right now. 23 Q. Oh, he got -- he gets work release? 24 BY MR. CAUTION: 24 A. He — 25 Q. For what? 25 MR. EDWARDS: Form. `--Prcatec=ere, 11 (Pages 297 to 300) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772.1652) 92e15b82-3844202435048838608813b Electronically signed by Pamela Sullivan (601-333-772.1552) EFTA00750784 Page 301 Page 303 1 THE WITNESS: He makes a schedule every week 1 Q. Do you — you rent forma family member? 2 of what het going to be doing all week long. 2 MR. EDWARDS: Fan. 3 BY MR. CRITTON: 3 • THE WITNESS: Yes. 4 Q. Okay. So he gets arrested for the sale of 4 BY MR. CRITTON: 5 cocaine, but he's he's arrested, but at some point he 5 Q. Isn't it true, ma'am, that lavas 6 got put on probation or something so he could do -- or 6 selling cocaine so as to help support you and himself 7 part of his program is he gets a work release so he 7 and the child? 8 wouldn't have to be on house arrest; right? 8 MR. EDWARDS: Form. 9 MR. EDWARDS: Font]. 9 THE WITNESS: No. 10 THE WITNESS: He is on house attest 10 BY MR. CRITTON: 11 BY MR. CRITTON: 11 Q. When is the last time you did work? 12 Q. But he can go to work? 12 A. Before 1became pregnant with my daughter. 13 A. Yes. 13 Q. you last work? 14 Q. But he doesn't have a job now? 14 A. d 15 A. Not now. 15 Q. Did you laant during the time you 16 Q. How do you guys -- and you don't have a job 16 were working at 17 right now? 17 A. Yes. 18 A. Right. 18 anew you wassis 19 Q. Okay. So how do you two support yourself - 19 ailitv you were working at 20 when was the last time you had work? 20 A. Yes. 21 A. Since' had my daughter. 21 Q. Okay. What did he think about that? He was 22 Q. Okay. So you haven't worked since June — 22 okay with that? 23 probably before June 29th of'08; coned? 23 MR. EDWARDS: Form. 24 A. Yes. 24 THE WITNESS: No. 25 Q. Okay. And has not worked since when? 25 Page 302 Page 304 A. About three weeks ago. 1 BY MR. CRITTON: 2 Q. When he was working at rand as a 2 Q. Why did you do it, then? Why didn't you get 3 telemarketer, did he make enough money to support you 3 a — try to get another job? You were — well, let me 4 so — in -- in the house that you're living in? 4 strike that. 5 A. Yes. 5 How long did you work at MEM 6 Q. Okay. How much did he make as a — as a — 6 A. About six or 7 working, washing cars at Ilia 7 Q. So which was about 8 A. Pm not exactly sure. Like ten dollars an 8 eight months, and between_ you worked about a year, 0 hour. 9 like 14 to 15, 16 months, doing stripping; is that 10 Q. Does anybody help you pay towards your -- do 10 correct? 11 you rent or lease — do you rent or lease — do you 11 A. Yes. 12 lease or pay a mortgage payment on the house? 12 Q. Okay, rayagglipjo go back to stripping 13 A. Rent. 13 once you finish or once you finish — 14 Q. And do you rent from someone you know? 14 once your daughter starts school? 15 A. Yes. 15 A. No, 1 do not. 16 Q. Who? 16 Q. You don't have any intention of going back 17 MR. EDWARDS: Form. Don't answer. Same 17 into the stripping business? 18 objection that we've been going through the whole 18 A. No, I do not time; its just going to identify the address. 19 Q. When you were at MEN where was that 19 20 BY MR. CRITTON: 20 located? 21 Q. How much do you pay a month for rent? 21 A. West Palm Beach. 22 A We were paying a hundred dollars every week, 22 Q. And that's the one off 1 think 23 so that's $400 a month. 23 you said? 24 Q. Do you pay the electric, too, all utilities? 24 A. Yes. 25 A. No. We just had to pay that 25 Q. Okay. And who was your boss there? ,w. 12 (Pages 301 to 304) (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) 92ef5b62-38a5-4202-a350-6633a5c6813b EFTA00750785 Page 305 Page 307 1 A. There were a few managers there. One of them 1 A. Sometimes, yes. 2 was named 2 Q. Allright. And you'd get tips from people 3 Q. Was he the last manager when you left, when 3 who would put money wherever? 4 you stopped working? 4 A. They would throw it on the stage — 5 A. Yes. 5 Q. Okay. 6 Q. What did you have — w was the deal -- 6 A. — on the floor. 7 financial deal with Tips, and then you had 7 Q. Could — could they put money into your — if 8 to tip the DJ and the manager again? 8 you still had your bottoms on, could they — would you 9 A. Yeah, but — yeah, pretty much it was the 9 allow them to put money into your G-string? 10 same. 10 A. No, I wore a garter on my leg. 11 Q. Anything different about your financial 11 Q. Okay. Would you allow them to put money into 12 arrangement there? 12 your garter? 13 A. No. 13 A. Yes. 14 Q. And in order to get that job — well, let me 14 Q. Okay. And when you were dancing, did you 15 strike that 15 dance right dugjailaBLof thc-lagisiag men? 16 Was working there, too? 16 That is, both "id did they 17 A. No. 17 have a bar right that was adjacent to the stage, so 18 Q. Was El working there? 18 that they're they're sitting right at the stage 19 A. No. 19 level? 20 Q. Anyone that you knew? 20 A. Yes. 21 A- Yes. 21 Q. All right. And so you're dancing naked in 22 Q. Who? 22 front of them at times; correct? 23 A. A girl that I met at 23 A. Yes. 24 Q. Who was? 24 Q. Okay. And as you're dancing, you're going up 25 A. I don't know her real name. 25 and down — they have a pole there; I assume? Page 306 Page 308 1 2 3 A.t Q. What was her stage name? Q 1 2 3 A. Yes. Q. All right. So you're dancing naked, and you're spreading your legs; true? 4 MR. EDWARDS: She'll subpoena her. 4 A. What is it — what do you mean? 5 MR. CRITTON: rm sure you'll -- you'll 5 Q. Well, when you're dancing in front of these 6 assort privacy rights. 6 men and you're completely naked, you're exposing all 7 MR. EDWARDS: Good idea. 7 parts of your body; aren't you, including your 8 BY MR. CRITTON: 8 genitalia? 9 Q. Did you do lap dances at MM. 9 A. Yes. 10 A. Yes. 10 Q. All right. And you're doing that for then; 11 Q. And did you do any bachelor parties at= 11 and you're going close to the bar where those men are 12 12 being seated — where those men are seated; true? 13 A. No. 13 A. No. 14 Q. Okay. Again, friction lap dances at.. 14 Q. Okay. So you never went close to the bar? 1.5 15 A. No. 16 A. .Yes. 16 Q. You just stayed right in the center of the 17 Q. Did they have a champagne room? 17 stage? 18 A. Yes. 18 A. Yes. 19 Q. Same, did you use the champagne room whenever 19 Q. Well, if you stayed in the center of the 20 you could because ou would make more money? 20 stage, how could men ever put tips into your garter? 21 A. was -- it was kind of different, 21 A. Because it was at the calf of my leg. 22 and I didn't do a lot of champagne rooms there. It was 22 Q. So you had to get close enough to the bar 23 a it felt a lot less safe there. 23 that somebody could reach across and put a dollar bill 24 At -- at -- at did you again, 24 or a five-dollar bill or a 20, or whatever they were 25 when you were on stage, strip down to buck tufted? 25 tipping, into your garter, right? ••••• ••SMINS•aA .••••••./.• , •....00.•••• ••JJ•41 13 (Pages 305 to 308) (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) 92eft5b62.380-4202.435043833a5c8813b EFTA00750786 Page 309 Page 311 1 A. Yes. 1 MR. CRITTON: Time period for right now. 2 Q. All right. So you did get close to the edge 2 MR. EDWARDS: Okay. 3 of the stage -- . 3 THE WITNESS: Probably a kw months after I 4 MR. EDWARDS: Form. 4 met Jeffrey Epstein I had sex with my first 5 BY MR. CRITTON: 5 boyfriend. 6 Q. -- when you were naked: true? 6 BY MR. CRITTON: 7 MR. EDWARDS: Form. 7 Q. And was that someone that you had dated for a 8 BY MR. CRITTON: 8 lengthy period of time? 9 Q. You had to. Otherwise, their — their arms 9 A. I dated him for about a year and a half. 10 could not have reached your garter, ma'am — 10 Q. Before — did it start before Mr. Epstein? 11 MR. EDWARDS: Form. 11 A. Before, yes. 12 BY MR.. CRITTON: 12 Q. And what was this person's name? 13 Q. -- isn't that true, ma'am? 13 MR. EDWARDS: Object to the form. 14 A. Yes, I — !would put my leg far enough to 14 Instructing her not to answer. 15 where they could reach it, yes. But I didn't go like 15 BY MR. CRITTON: 16 right up to them in order to dance in front of their 16 Q. And when you say you had sex with him, that's 17 face like that. 17 sexual Intercourse? 18 Q. On the friction dances that you did at lap -- 18 A. Yes. 19 at there were many occasions that you saw 19 Q. Okay. Did you ever have — did you ever 20 men get an erection; isn't that true? 20 have — perform oral sex on him? 21 MR. EDWARDS: Form. 21 A. No. 22 THE WITNESS: No. 22 Q. Okay. Did you ever have any type of anal sex 23 BY MR. CRITTON: 23 with him? 24 . Oka . Is it our testimony, neither at 24 A. No. 25 or did you ever engage in any 25 Q. Okay. Other than this person, and we'll call Page 310 Page 312 1 activity where you saw — where you saw a man with an 1 him Mr. A, when is the next time that you had any sexual 2 erection; is that true? 2 activity with anyone? And by sexual activity, I mean 3 A. Yes. 3 where -- either intercourse, oral sex, could be anal 4 Q. Okay. And is it your testimony, to the 4 sex, anything of that nature. 5 ladies and gentlemen of the "ti , during the time that 5 A. I don't know. I was 15. 6 you worked at both and for 6 Q. And how old were you when you had sex with 7 some 14, 15, 16 months that you never engaged in any 7 person, Mr. A? 8 kind of sexual activity, including using your hand on a B A. I was 14. 9 man's penis to help him ejaculate during the time you 9 Q. You never had any sexual activity with 10 worked there? 10 Mr. Epstein; did you? 11 A. No, I did not. '11 MR. EDWARDS: Pont. 12 Q. And ifs your — is it your testimony that, 12 THE WITNESS: What do you mean? 13' up until the time you started seeing a that you 13 BY MR. CRITTON: 14 had never seen a man's penis, other than Mr. Epstein? 14 Q. You never had sexual intercourse with 15 • MR. EDWARDS: Object to the form. 15 Mr. Epstein at any time; did you? 16 THE WITNESS: No. 16 A. No. 17 BY MR. CRITTON: 17 Q. You never had any type of anal sex with 18 Q. Okay. When — when did you first see a man's 18 Mr. Epstein; did you? • 19 penis, other than Mr. Epstein's? 19 A. No. 20 MR: EDWARDS: And I'm just going to place the 20 Q. • You never performed oral sex on Mr. Epstein; 21 objection that she's not going to give any names of 21 did you? 22 individuals at this time to protect privacy rights 22 A. No. 23 of my client, as well as third panics. So I don't 23 Q. He never performed any oral sex on you; did 24 know if you're talking about in terms of time 24 he? 25 Period -- 25 A. No. -.• 14 (Pages 309 to 312) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601433.7724652) Electronically signed by Pamela Sullivan (501-333-7724552) 92etsb62-38a5-4202-a350-6assase6813b EFTA00750787 Page 313 Page 315 1 Q. Therefore, you bad no type of sexual activity 1 BY MR. CRITTON: 2 with Mr. Epstein — 2 Q. — and how old were you? 3 MR. EDWARDS: Object to the form. 3 MR. EDWARDS: You can answer the second half. 4. BY MR. CRITTON: 4 THE WITNESS: I was 16. 5 Q. — at least, as I've defined it thus far; 5 BY MR. CRITTON: 6 correct? 6 Q. We'll call this person — a man, I assume, 7 MR. EDWARDS: Object to the form. 7 male? 8 THE WITNESS: He touched my — 8 A. Yes. 9 BY MR. CRITTON: 9 Q. wen call this Mr. C 10 Q. Go ahead. Finish your question; then I'll — 10 CRITTON: — because you're going to 11 or your response. 11 instruct her not to answer, right? 12 A. He touched my vagina with his hand and 12 MR. EDWARDS: Right. 13 inserted his fingers. 13 BY MR. CRITTON: 14 Q. When I asked you the question, and you 14 Q. All right. And long-term relationship, or 15 responded that he — that you and Mr. Epstein never had 15 just a short? 16 sexual intercourse, never had any type of anal 16 A. Yes, that was a long relationship. 17 intercourse, you never had any type of -- you never 17 Q. Only sexual intercourse with him? Did you 18 performed oral sex on him, and he never performed oral 18 ever have oral sex with him? 19 sex on you, that was true with all of the visits that 19 A. Yes. 20 you ever had to Mr. Epstein's house; true? 20 Q. Both you to he and he to you? 21 A. Yes. 21 Yes. 22 Q. Now, with person A, which you said you had 22 Q. And that went on over a long period of time? 23 sexual intercourse at age 14, and there was a person B. 23 A. Yes, until after I turned 18. 24 Is this another person you had a long-term relationship 24 And why did that relationship break up? 25 with, or was this a shorter relationship? 25 A. I — I — I believed he was crazy. Page 314 Page 316 1 A. Yes, it was a shorter relationship. 1 Q. Okay. Was he? You thought he was. 2 Q. How old were you then? 2 A. Yes. 3 A I was 15. 3 Q. Okay. With person A, did you use illegal 4 ' Q. And did you have sexual intercourse with this 4 drugs with person A? 5 person? 5 A. Yes. 6 A. Yes. 6 Q. Okay. With person B, did you use illegal 7 Q. Any oral sex, he to you or you to he? 7 drugs? a A. No. 8 A. 'No. 9 Q. Any anal sex? 9 Q. Alcohol? 10 A. No. 10 A. No. 11 Q. The next person — and I assume — by who — 11 Q. With A, you used both drugs and — illegal — 12 who is person B? 12 illegal drugs and alcohol; true? 13 MR. EDWARDS: And my objection is the same. 13 A. We both tried our firsts together. We like 14 She's not going to give any names of these 14 drank for the first time together, and 15 individuals. 15 • Did drugs together? 16 MR. CRITTON: You're instructing her not to 16 A. Yes. 17 answer? 17 Q. All right. Person C, who you said was crazy, /.8 MR. EDWARDS: Yes, exactly. 18 how long was the relationship? 19 BY MR. CRITTON: 19 A. More than two years. 20 Q. Okay. And you're going to follow whatever 20 Q. Did you do drugs with him? 21 instruction he gives you? 21 A.. Yes. 22 A. Yes. 22 Q. Alcohol? 23 Q. All right. Who was the next person, then, 23 A, No. 24 you had sexual activity with 24 . Q. Okay. Was he a drug dealer? 25 MR. EDWARDS: Same objection. 25 MR. EDWARDS: Form. • 15 (Pages 313 to 316) (561) 832-750C PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601433-7724552) Electronically signed by Pamela Sullivan (601.333-772-1552) 92ef5b62-38a5-4202-a350-6833,15O3813b EFTA00750788 Page 317 Page 319 1 THE WITNESS: No. 1 you share that, then, with Mr. C or Mr. B, depending on 2 BY MR. CRITTON: 2 who you were with at the time? 3 Q. Did he work? 3 A. No. 4 A. Yes. 4 Q. What did you do with your money? 5 Q. What kind of work did he do? 5 A. I bought clothes and things for myself. 6 A. He laid tile. 6 Q. When you were living with Mr. C,1 think you 7 Q. Did you live together? 7 said, did you where were you living, in a trailer, a 8 A. Yes. 8 house, an apartment? 9 Q. Where? 9 A. We were living in a trailer. 10 A. He lived in a — in a trailer in West Palm 10 Q. And where, what city? 11 Beach. 11 A. West Palm Beach. 12 Q. Okay. After the two, so 16 through 18, 12 Q. Was he abusive to you in any way, either 13 when — during the time that you wore going to 13 physically or verbally? 14 Mr. Epstein's house, did you — were you having these 14 A. No. 15 relations with A, B, and C? 15 Q. Did you ever have to call the police on him? 16 MR. EDWARDS: Form. 16 A. No. 17 THE WITNESS: Yes. 17 Q. You're sure? 18 BY MR. CRITTON: 18 A. No, fm not sure. 19 Q. Okay. Wen A— did A, B or C, or any 19 Q. Okay. Did he strike you — didn't he? 20 permutation of that group, aware that you were going to 20 A. He stalked me. 21 Mr. Epstein's? 21 Q. Okay. How long — 22 A. No. 22 MR. EDWARDS: Is that what you asked, 23 Q. Did you tell than? 23 stalked? 24 A. Na 24 MR. CRITTON: I said strike. 25 Q. Why not? 25 THE WITNESS: He said, did he satin. Page 318 Page 320 1 A. 1- the only person that knew about it was 1 MR. EDWARDS: Oh, okay. Sony. 2 the last person that I just told you about. 2 MR CRTITON: And she said stalked. 3 Q. C? 3 MR. EDWARDS: Okay. I A. Yes. 4 BY MR. CRITTON: 5 Q. Okay. And what did you tell him? He knew 5 Q. Did he ever strike you? 6 you were going to Epstein's? 6 A_ No. 7 A. He knew that I was going somewhere. 7 Q. When you say he stalked you, !mean did he -- 8 Q. How did he know? Did you tell him? 8 stalking, in my mind, is he would follow or see where 9 A. Yes. 9 you were. 10 Q. What did you tell him? 10 A. Yes. He knew things that 1 didn't tell. 11 A. I told him that I was going to clean house. 11 anybody. He — like I moved and lived withM. so that 12 Q. Okay. And did you — at the time that you 12 he wouldn't know where I was, and he found out where I 13 were dating Mr. C, did — how much were you getting paid 13 was. 14 from Mr. Epstein? 14 Q. Did he come there? 15 A. Usually when I went there, he — he gave me 15 A. He would like hide outside in the bushes and 16 in between two and $300. 16 stuff. 17 Q. In cash? 17 Q. And you knew he was out there? 18 A. Yes. 18 A. Yes. 19 Q. Would he give it to you, or would someone 19 Q. Did you have to call the police and say, fve 20 else give it to you? 20 got a stalker? 21 A. He would set it down on the counter, 21 A. No, I never did that. 22 sometimes he would give it to me, sometimes somebody 22 Q. So were you scared of him? 23 else would give it to me. It was different a lot of the 23 A. Not really. 24 times. 24 . Q. Were you intimidated by him? 25 Q. When you were receiving the money, did — did 25 A. No. 16 (Pages 317 to 320) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333712.1662) Electronically signed by Pamela Sullivan (501333-772.1562) 92ef5b62.38a5-/202-a350.6633a5c6813b EFTA00750789 Page 321 Page 323 1 Q. Was he harassing you? 1 true? 2 A. He was harassing me. 2 MR. EDWARDS: Object to the form. 3 Q. Okay. I thought 1-- when I asked you 3 THE WITNESS: He touched me. 4 earlier and we were talking about, let's see, the 16 and 4 BY MR. CARTON: 5 17 year -- let's see, if you lived with Mr. C your 16 5 Q. ! understand that. But he never physically 6 through 18th year, and you were born in '88 -- 16 -- 6 caused you harm? 7 that takes me to '04 through like 2006. So is that the 7 MR. EDWARDS: Form. 8 first time you would have gone tea.'s, when she was 8 THE WITNESS: I dent know what you mean by 9 living in West Palm Beach, or is this another time you 9 that. 10 went tca.'s that you didn't remember telling us 10 BY MR. CRITTON: 11 about? 11 Q. Well, he never caused an injury to you -- 12 A. No, that was the first time that 1 moved in 12 MR. EDWARDS: Form. 13 with'., then, after I left him. 13 BY MR. CRITTON: 14 Q. I thought you bald us you were livi at your 14 Q. — physical injury to you; true? 15 house, and you left y house to go 15 A. No, he never hit me. I don't know. 16 live wi 16 Q. I'm sorry? 17 A. We were liven in his trailer, and then we 17 A. He never like hit me. 18 were livirtg wi 18 Q. After Mr. C — well, let me strike that. 19 Q. So you were a 16- 17- ear-old irl and you 19 How did you get rid ofMr. C, other than you 20 were living with Mr. C a house? 20 said was a bit of a nut case, or you thought he was he 21 A. Yes. 21 any. 22 Q. What die think about that? 22 A. I just -- I left him. I lived • ' 23 A. I don't latow. 23 a while, and I moved bads in wi And 24 Q. Well, she let you live there; didn't she? 24 believe my uncle was living there at the time, and he 25 MR. EDWARDS: Form. 25 just,Iguess, moved. Page 322 Page 324 1 THE WITNESS: Yes. 1 Q. Okay. Well, was he still living when they 2 BY MR. CRITTON: 2 moved back in, or did he tell C he had to exit the 3 Q. During the time that — the some 20 occasions 3 house -- 4 you went to Mr. Epstein's home, would it be a correct 4 A. H was 5 statement, Ms. Jane Doe, that he never threatened you 5 Q. -house? 6 with any type of serious harm? 6 A. He was gone. 7 MR. EDWARDS: Form. 7 Q. After Mr. C, who was your next relationship 8 THE WITNESS: Is it true that he never 8 with, wished sexual activity? 9 threatened me? 9 A. 10 BY MR. CAUTION: 10 4 And Wage time, since the time you 11 Q. Right. Mr. Epstein never threatened you at 11. started datingMl., which was in what, sometime in 12 any time you went to his home; isn't that true? 12 2007? 13 A. Yeah, that's true. 13 A. Yes. 14 Q. And he never attempted to physically restrain 14 Q. Okay. Has he been the only person that you 15 you; true? 15 have been sexually active with since Mr. C? 16 A. Yeah. Yeah, that's true. 16 A. Yes. 17 Q. And he never threatened you nor abused you 17 Q. So if someone would testify that you were 18 either physically or verbally; true? 18 sexual — so if someone were to testify in this case 19 k He - 19 that you were sexually active at the age of 12, what 20 Q. He never injured you physically? 20 would your response to that be? 21 MR. EDWARDS: Is this a different question. 21 M. EDWARDS: Form. 22 • or is she answering the first one? 22 THE WITNESS: That is not true. 23 BY MR. CRITTON: 23 BY MR. CAUTION: 24 Q. Yeah, let me throw it out. Let me ask it 24 Q. What was the person you had - Mr. A, how 25 this way: He never — never physically injured you; 25 approximately how old was Mr. A? 17 (Pages 321 to 324) (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 (501-333-7721552) 9205b62,18.542024350463.1a6c81113b EFTA00750790 Page 325 Page 327 1 A. He was two years older than me. 1 That is, that's what you thought was going to happen, 2 Q. How about Mr. B? 2 based on what.. had told you? 3 A. Same. 3 A. No. 4 Q. How about Mr. C? 4 Q. Okay. Was it substantially different than 5 A. He was four years older than me. 5 what you thought.. had told you would happen? 6 Q. Do you have any piercings? 6 A. Yes. 7 A. My ears. 7 Q. Okay. In fact, you said you didn't think you 8 Q. Other than your ears? 8 would have to take your clothes off at all. 9 A. No. 9 A. Yes. 10 Q. Have you ever advertised for sex, any kind of 10 Q. All right. And you weren't even sure that 11 sexual activity on any website? 11 you'd have to give anyone a massage, because ou 12 A. No. 12 thought, based on what you told us, is thatIM. said, 13 Q. When you left Mr. Epstein's house on the very 13 I'll give you 200 bucks, just come with me? 14 first occasion and you said you and... — I'm sorry — 14 A. Yes. 15 you and.. were walking eastbound on the road? 15 Q. Come with me to the house; right? 16 A. Yes. 16 A. Yes. 17 Q. All right. Because you were trying to flag 17 Q. So what, from your perspective, it was hugely 18 down a cab. 18 different, at least based on what you've told us frorn 19 A. Yes. 19 what.. said you should expect or what you thought was 20 Q. Had a cab been called to pick you up? 20 going to happen; correct? 21 A. Yes. 21 A. Yes. 22 Q. And why were you walking? 22 Q. So weren't you ticked off at hen weren't you 23 A. Because the cab didn't come. 23 angry with her? 24 Q. So you thought maybe it was lost or 24 A. I don't }mow what to say. 25 something? 25 Q. Okay. Well, why not? You've been -- you've Page 326 Page 328 1 A. Yes. 1. been angry before. I mean, you -- you testified in 2 Q. And that was..'s idea? 2 court, you testified on depositions you had been a 3 A. Yes. 3 runaway, you know, you know how to pick up and leave if 4 Q. And as you're walking awa from Mr. Epstein's 4 circumstances were not good at a particular house. You 5 house the first time, what — did say, well, how 5 had a vast experience in taking care of ourself, to 6 did it go? 6 some extent, so why didn't you say toM. something 7 A. No. 7 like, what did you get me Into, or what happened, or 8 Q. Okay. Did you yen at.? 8 what was going cm? Did you show any emotion at all to 9 A No. 9 10 Q. Were you angry with.? 10 MR. EDWARDS: Form. 11 A. No. 11 THE WITNESS: Na 12 Q. Did you say anything to.. as to what went 12 BY MR. CRITTON: 13 on between — excuse me — after she had left? 13 Q. So youjust got in the car — did you go in a 14 A. No. 14 cab? I gather gather a cab came? 15 Q. Why not? 15 A. Yes. 16 A. Because I didn't feel comfortable talking 16 all:Stkay. Cab came. You get in the car. You 17 about It. 17 andli. aren't talking at all? 18 Q. Well, this is — this is the girl who, based 18 A. I don't remember any conversation that we 19 on what you've told us, is would be your belief that 19 had, no. 20 misled you? 20 Q. What did you tell the FBI? Didn't the FBI 21 MIL EDWARDS: Form. 21 say, what do you mean you didn't say anything to..? 22 THE WITNESS: What do you mean? 22 MR. EDWARDS: Form. 23 BY MR. CRFITON: 23 • THE WITNESS: They didn't say that to me. 24 Q. What occurred at -- what you say occurred at 24 BY MR. CRFFPON: 25 • Epstein's house, is that what you thought the deal was? 25 Q. Okay. And then did you tell them that 18 (Pages 325 to 328) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333.772-1662) Electronically signed by Pamela Sullivan (501-333-772.1552) 92ef6b62.38a5-4202a350.6633a5c6813b EFTA00750791 Page 329 Page 331 1 made 200 bucks off of you, a made money off bringing 1 THE WITNESS: I do not bow. 2 you there? 2 BY MR. CRITTON: 3 A. Yes. 3 Q. Did you ever ask her how many times she had 4 Q. Okay. Did they -- did they tell you, the FBI 4 been at Epstein's home — 5 tell you that if she's making money off of you; she's 5 A. Never. 6 like your pimp? Did they say that to you? 6 Q. — before she ever took you? 7 MR. EDWARDS: Form. 7 A. No. 8 THE WITNESS: No 8 Q. Did she ever tell you what — at any time 9 BY MR. CRITTON: 9 after the first time that you were at Epstein's home, 10 Q. Okay. Do you know do you know what a pimp 10 did she ever tell you how many times she had been there? 11 is? 11 A. Na 12 A. Not really. 12 Q. Did she ever tell you that she had brought 13 Q. Okay. Do you know that's someone who makes 13 anyplace from 20 to 80 people to Mr. Epstein's home, by 14 money off of — off of you for taking you someplace 14 her own testimony? 15 where you might make money? 15 A No. 16 MR. EDWARDS: Object to the fonn. 16 Q. Okay. Is that news to you, ass say that to 17 THE WITNESS: Why me? 17 you today? 18 BY MR. CRITTON: 18 A Yes. 19 Q. Pardon? 19 Q. So what -- so you don't remember anything 20 A Why roe? 20 that you and, talked about on the way home? 21 Q. What do you mean, why you? 21 A. No. 22 A. What do you mean me? 22 Q. And what did you do with the money that 23 Q. You — well — 23 you — that you got, the 200 bucks? 24 A I don't have a pimp. 24 A. I bought clothing and things that I wanted. 25 Q. I'm sorry? 25 Q. Did III ever ask you to go back to Page 330 Page :33: 1 A. I don't have a pimp. 1 Mr. Epstein's home again? 2 MR. EDWARDS: Form. 2 A. No. 3 BY MR. CRITION: 3 Q. When you — how did you end up going back to 4 Q You know, well, isn't M. — wasn't 4 Mr. Epstein's home again? 5 your pimp? 5 A. I gave him my phone number, and he called me. 6 MR. EDWARDS: Form. 6 Q. I'm sorry? 7 BY MR. CRITTON: 7 A. I gave him my phone number, and I got a call 8 Q. Didn't she take you there? from either him, or 9 MR. EDWARDS: Form. 9 Q. Did you meet every first 6me you 10 THE WITNESS: No, she is not my pimp. 10 were there? I think you sat you only met like the 11 BY MR. CRITTON: 11 blond-headed girl, who subsequently you identified as 12 g Well, what is she, then? If she's made money 12 13 off taking you to Mr. Epstein's, what would you call it? 13 MR. EDWARDS: Form. 14 A. Not my pimp. 14 THE WITNESS: No, I did not meet the 15 Q. Wasn't your friend; was she? Because she 15 first time I was there. 16 misled you; didn't she? 16 BY MR. CRITTON: 17 A. She probably didn't know that's what she was 17 Q. Okay. And did someone ask — did Mr. Epstein 18 doing at the time. 18 ask you for your phone number? 19 Q. She didn't !mow she was doing what? 19 A. Yes. 20 A. What she was doing. 20 Q. When you wore upstairs, or when you were 21 Q. How could she not 'mow what she was doing? 21 downstairs? 22 A. Because she was as young as I was. 22 A. When I was upstairs. 23 Q. Okay. Well, how many times had M. been 23 Q. And this is you, first time you were there, 24 there? 24 you've never taken your clothes off — at least that's 25 MR. EDWARDS: Form. 25 what you've told us -- in front of any male before, you 19 (Pages 329 to 332) (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 (501-333.772-1652) 92ef5b62-38a54202-a350-5633a5c6813b EFTA00750792 Page 333 Page 335 1 take your clothes off, you give him his massage, yoU • 1 BY MR. CRITTON: 2 described what occurred that first occasion, he asked 2 Q. Okay. Well, you — just a minute ago you 3 for your phone number, and you give it to him? 3 said, I knew she was bringing other people. Now, did 4 MR. EDWARDS: Form. 4 you know she was bringing other people before she 5 THE WITNESS: He only told me what to do. He 5 brought you? 6 never asked. So I felt like I had to do it — 6 A. Not before she brought me. 7 BY MR. EDWARDS: 7 Q. Okay. Did you find out afterwards that IN 8 Q. 'Okay. Well -- 8 had brought a lot of other people? 9 A. so I did. 9 A. No, I only assumed. 10 Q. You had no obligation to do Anything when you 10 Q. Okay. Well, did you ever ask a — 11 were there, ma'am; did you? 11 A. No. 12 MR. EDWARDS: Form. 12 Q. — whether she had brought other people? 13 THE WITNESS: I feh as if I did. 13 A. No. 14 BY MR. CRITTON: 14 Q. Okay. So you don't — you didn't know 15 Q. Okay. So when you — when he then but 15 whether she had brought anyone else, and you didn't know 16 whatever you did was completely voluntary on your part? 16 what she was thinking, because you never asked her; did 17 A. Fenn. 17 you? 18 Q. You could either do it or not? You could 18 A. No. 19 have just said, Pm out of here? 19 Q. So when Mr. Epstein said, could I have your 20 MR. EDWARDS: Form. 20 phone number, you had to voluntarily give it to him, 21 THE WITNESS: I only felt like I had to do it 21 because otherwise he couldn't have gotten it; true? 22 because he told me to. He never asked anything. 22 MR. EDWARDS: Form. 23 He only would tell me. 23 BY MR. CIUTION: 24 BY MR. CRITTON: 24 Q. You could have given him any number. 25 Q. Well, told you what to do. =told 25 MR. EDWARDS: Fara. I would just ask that Page 334 Page 336 1 you to take your clothes off. 1 you allow the witness to answer your question. 2 A. He told me to take my clothes off. 2 BY MR. CRITION: 3 You know, then you said that you looked at 3 Q. All right. You chose -- you voluntarily gave 4 and. was taking her clothes off, and she said, 4 Mr. Epstein your phone number; didn't you? 5 we need to take our clothes off. 5 MR. EDWARDS: Fain. 6 A. `said that it was ols yes. Q. All right. So, but for being there, you 6 7 TI-LE WITNESS: He told me to give it to him, so I did, yes. never would have taken your clothes — number one, if it BY MR. CRITTON: 9 weren't for le you never would have been there; would 9 Q. You could have given him any number in the 10 you? 10 whole world. You didn't have to give him your number. 11 A. `was already convinced that it was okay. 11 How would he know? 12 Q. How do you know that she was convinced that 12 A. I don't bow. 13 it was okay? You said you and — 13 Q. So he asked, and you gave it to him 14 A. Because obviously — 14 voluntarily; true? 15 Q. -- you said you never really talked about it. 15 MR. EDWARDS: Form. 16 A. — obviously, she was bringing — 16 THE WITNESS: Yes. 17 Q. So you — 17 BY MR. CRITTON: 18 A. — other people there. 18 Q. Okay. Now, Ms. Jane Doe, when you gay 19 Q. Well, you didn't know that. 'just asked you 19 your phone number, I think you said that you told Eff 20 that a minute ago, whether you knew she -- whether you 20 that you had given him your phone number? 21 knew she was bringing anybody else. And you said you 21 A. No. 22 didn't know whether she had ever brought anyone else. 22 Q. Okay. Did ever come to you and say, 23 MIL EDWARDS: Form. 23 hey, would you like to go back to Epstein's house again? 24 THE WITNESS: Well, she brought me. 24 A. Yes. 25 25 . Q. Okay. When did she do that? 20 (Pages 333 to 336) (561 ) 832-750 0 PROSE COURT REPORTING AGENCY;- INC . (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772.1662) Electronically signed by Pamela Sullivan (501-333-772-1562) 92ef5b62.38a5-t202a350.6633a5c6813b EFTA00750793 Page 337 Page 339 1 A. I don't remember. 1 COURT REPORTER: "Did he ask you whether 2 Q. How much time passed? 2 you'd want to come over?" I didn't bear your 3 A. I don't remember. 3 response, if you answered. . 4 Q. A week? A month? Six months? 4 THE WITNESS: Yes. 5 A. I don't remember. 5 BY MR. CRITTON: 6 Q. And what did you say? When — what did you 6 Q. And that one or two occasions that he called 7 say to. when she said, would you lice to go back to 7 you, he basically said, do you want to come over? 8 the house with me? 8 MR EDWARDS: Form. 9 A. I don't — I don't remember. 9 THE WITNESS: He — I don't remember exactly 10 Q. Well, did you mislead her? Did you say, no, 10 what he said to me. But, normally, when?Igor 11 I — I don't want to go back? 11 r to icalled me they would call me ah o tune 12 A. No. 12 me that Jeffrey was going to be in town, 13 Q. Did you tell her, I'm going back on my own? 13 would I like to come over. 14 Well, let me ask you this: Had you — strike 14 BY MR. CM-TON: 15 the last question. 15 Q. Right. And that was the extent of the 16 lied you gone back to Mr. Epstein's house in 16 conversation? 17 between the first time and the time that El next asked 17 A. They would tell me — 18 you? 18 Q. You would say yes or no? 19 A. Yes. 19 A. Yes. And they would tell me what day and 20 Q. Okay. How many times had you been back as — 20 what time to be there. 21 how much time transpired between the first time and the 21 Q. All right. And you understood that 22 second time you went to Mr. Epstein's home? 22 Mr. Epstein has a residence in Palm Beach? 23 A. lam not sure. 23 A. Yes. 24 Q. Was it a week? A month? A day? 24 Q. And you understood that he had residences in 25 A. I don't know who — maybe a week or two. 25 other places? Page 338 Page 340 1 Q. All right. And then I think you told me 1 A. Not at the time. 2 someone called you, some — a female called you. 2 Q. Okay. And you just thought he lived MI 3 A. Sometimes -called me, and once in a 3 time in West Palm Beach or in Palm Beach? 4 while Jeffrey called me himself. 4 A. No, I — [knew that he went out of town a 5 Q. Okay. Mr. Epstein never called you directly, 5 lot. 6 did he? 6 Q. All right. So you knew that he went out of 7 A. Yes. 7 town for business, as well as doing business here in 8 Q. You said you went to his house 8 Palm Beach? 9 approximately — approximately 20 times — 9 MR. EDWARDS: Form. 10 A. Yes. 10 THE WITNESS: I have no idea what he was 11 Q. — during the — during the time span that 11 going out of town for. 12 you identified earlier. 12 BY MR. CRITTON:. 13 A. Yes. 13 Q. Okay. Did you ever know what his business 14 Q. All right. Would the vast majority of times 14 was? 15 that he called you — I'm sorry that you were called, 15 A. No. 16 either MI or made the call? 16 Q. All right. Was — during the time that you 17 A. Yes. 17 ever gave a massage to Mr. Epstein, did he was he on 18 Q. Okay. On how many occasions, your best 18 the phone? 19 recollection, did Mr. Epstein ever call you? 19 A. Yes. 20 A. One. Maybe two. 20 Q. Okay. And often would he be doing what 21 Q. And on the one or two occasions that 21 appeared to be business over the phone while you were 22 Mr. Epstein ever calledyou, did he ask you whether 22 giving him a massage — or engaging in conversations 23 you'd want to come ova? What did he say? 23 with someone? 24 COURT REPORTER: I didn't hear any response. 24 A. Yes. 25 MR. CItITTON: Oh, I'm sorry. 25 Q. All right. And did it appear from time to 21 (Pages 337 to 340) (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) 92ef5b62-38a5-4202-a350-6633a5c6813b EFTA00750794 Page 341 Page 343 1 time that he was engaged in business? 1 discussed; was it? 2 MR. EDWARDS: Form. 2 MR. EDWARDS: Form. 3 THE WITNESS: Sometimes, yes. 3. THE WITNESS: No. 4 BY MR. CRITTON: 4 BY MR. CRITTON: 5 Q. All right. And you understood that — at 5 Q. Okay. And the one or two times that 6 least you understood that his main residence was in, 6 Mr. Epstein ever called you, the subject of — of any 7 from what you understood dining the time that you went 7 type of engaging in any type of sexual conduct was never 8 there, his main residence was in Palm Beach, Florida, 8 dic.nmerad; was it? 9 and that he would just travel out of town, and then come 9 A. No — yes, it was, actually. 10 back into town occasionally, you know, he would travel 10 Q. Well, ma'am, you said, no; then you said, 11 out of town occasionally, but basically lived in Palm 11 yes. What is it? What's the answer? 12 Beath? 12 A. Yes, he did discuss with me that he would pay 13 A. I did not !mow. I really... 13 me extra money for having sex with him. 14 Q. You said that was the only residence that 14 Q. Did you tell the FBI that? 15 you — or the only place that you understood that he 15 A. Yea And he be tried to, 'guess, 16 lived? 16 convince me to do it by telling me that-- his exact 17 A. That's the only place that I knew of, but 17 words to me were that he used to fuck all the time. 18 I — I didn't know, you know, what he was doing when he 18 Q. When did — when did this call purportedly 19 was going out of town or whatever he was doing. 19 take place? 20 Q But you knew he had — he — that was his 20 A. I was at his house, and... 21 home, at least one of his homes? 21 Q. At his house? 22 A. I 'mew that he lived there. 22 A. Yes. 23 Q. All right. You never traveled anyplace with 23 Q. What were you doing at his house? 24 Mr. Epstein; did you? 24 A. I was giving him a massage. 25 A. No. 25 Q. Oh, I thought okay. Maybe you Page 342 Page 344 1 Q. You never accompanied him on any trip; did 1 misunderstood my question. 2 you? 2 When Mr. Epstein — the one or two times that 3 A. No. 3 you ever spoke with Mr. Epstein over the phone, okay, 4 Q. Mr. Epstein never text -- text'd you by 4 the subject of engaging in any type of sexual activity 5 phone; did he? 5 or conduct never attuned; did it? 6 A. No. 6 MR. EDWARDS: Form. 7 Q. Mr. Epstein never e-mailed you or sent you 7 THE WITNESS: Not over the phone. 8 any type of mail; did he? 8 BY MR. CRITTON: 9 A. No. 9 Q. I'm sorry? 10 Q. Neither nor or anyone who worked 10 A. Not -- 11 for Mr. Epstein ever texrd you by phone; did they? 11 Q. Not over the phone? 12 A. No. 12 A. —over the phone. 13 Q. They never sent you anything by e-mail or by 13 • All right. And neither = nor 14' mail; did they? 14 or anyone else, including Mr. Epstein, ever 15 A. No. 15 attempted to persuade or to induce or to entice you into 16 . Okay. And when they — they, either ur 16 any type of sexual conduct during any phone 17 or whoever else may have called, other than 17 communication; true? 18 Mr. Epstein, they basically said, Jeffrey's in town, 18 A. Yes, that's true. 19 would you like to come over? 19 Q. Did you ever bring anyone to Mr. Epstein's 20 A. Yes. 20 house? 21 Q And then they would give you a time? 23. A. No. 22 A. Yes. 22 Q. Do you know a person named who's your 23 And at no time in any conversation with 23 cousin? 24 or or anyone who worked for Mr. Epstein was the 24 A. 25 subject of engaging in any type of sexual conduct ever 25 . Q. ? 22 (Pages 341 to 344) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601333-772.1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 92ef5b62-38a5-4202.3350-6633a5c6813b EFTA00750795 Page 345 Page 347 A. Yes. 1 Q. How about your sister, a? Q. Did you brink; -- you know — you're 2 A. I haven't told her myself, but I'm sure that 1 aware Amanda MI went to Mr. Epstein's home? 3 she knows, because other people have gone to her house. 4 A. Yes. I did not bring her, though. 4 Q. Okay. Other people have told her, or other 5 Q. And she was 19 or 20 when she went; isn't 5 people have just asked her questions? 6 that true? 6 MR. EDWARDS: Form. 7 A. Yes. 7 TILE WITNESS: I don't know what she was told. 8 Q. Okay. And who took or asked Amanda to 8 BY MR. CRITTON: 9 go to Mr. Epstein's home? 9 Q. Okay. How about I., your sister, ME, 10 A. I believe it was.. or.. 10 does she know you're a Plaintiff in this lawsuit — 11 Q. And how did you find out that your 11 A. No. 12 cousin, went to Mr. Epstein's home? 12 Q. — or any lawsuit? 13 A. I don't remember. Either she told me, or 13 A. No. 14 told me, or told me. 14 Q. Okay. Have you sold or agreed to assign any 15 Q. And did you ever talk with ■ about what 15 portion of any recovery to anyone? 16 the did at Mr. Epstein's home? 16 MR. EDWARDS: Form. 17 A. No. 17 THE WITNESS: No. 18 Q. Was she aware — she, aware that you 18 BY MR. CRITTON: 19 went? 19 Q. Your psychologist, he knows 20 A. I don't think so. 20 you're a Plaintiff in a lawsuit? 21 Q. And you're aware she went, but you never 21 A. Yes. 22 raised the topic with her? 22 Q. Okay. Who else knows you're a Plaintiff in a 23 A. Right. 23 civil lawsuit against Mr. Epstein? 24 Q. By the way, who— who knows that you area 24 A. I don't know. 25 Plaintiff in the action, Jane Doe versus Epstein? 25 Q. Any of your other friends know? Page 346 Page 348 1 knows; right? 1 A. No. 2 MR. EDWARDS: Object to the form. 2 Q. Okay. Are you aware that if, in fact, this 3 BY MR.. CRITTON: 3 case is not resolved, you may well — the case may be 4 Q. First you need to answer that question. 4 tried, and your anonymity may no longer exist — 5 knows you're a Plaintiff; right? 5 MR. EDWARDS: Form. 6 MR. EDWARDS: Object to the form. 6 BY MR. CRITTON: 7 THE WITNESS: Yes. 7 Q. -- because everyone may know that you're the 8 BY MR. CRITTON: 8 Plaintiff', Jane Doe, against Mr. Epstein; do you 9 Q. Okay. knows you're a Plaintiff? 9 understand that fact? 10 MR. EDWARDS: Form. 10 MR. EDWARDS: Form. 11 THE WITNESS: Yes. 11 THE WITNESS: Yes. 12 BY MR. CRITTON: 12 BY MR. CRITTON: 13 Q. Does know -- 13 Q. I think you told me you never brought any 14 A. Yes. 14 other girls to Mr. Epstein's home? 15 Q. — you're a Plaintiff? 15 A. No. 16 A. Yes. 16 Q. Okay. After you said asked you if 17 Q. Does know you're a Plaintiff? 17 you — if you would like to go back to Mr. Epstein's.— 18 A. Yes. 18 to it Epstein's house, but you had already been back in 19 Q. Does your mother know you're a Plaintiff? 19 the interim; true? 20 A. I don't know. 20 A. Yes. • 21 Q. Did you tell your dad,_? 21 Q. Okay. And who — I. or someone else had 22 A. No. 22 called you and asked you if you wanted to come back? 23 Q. . So hes unaware that you're — you have a 23 A. Yes. 24 lawsuit that's going? 24 Q. And where were living at the time? 25 A. No -- he is unaware, yes. 25 A. With _ - 23 (Pages 345 to 348) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772.1552) 9205652-38a5.4202-a350-843315e8M3b EFTA00750796 Page 349 Page 351 1 Q. Who drove you to Mr. Epstein's house? 1 A. Yes. 2 A. Cab. 2 Q. And she said, you know, I know you couldn't 3 Q. When the person called and asked whether you 3 come last time. How about coming this. Would you like 4 want — whether you wanted to come back, what did you 4 to come? 5 A. Yes. 5 gin 6 A. At first I didn't go. 6 Q. And did you say, no, not interested anymore, 7 Q. Okay. So the call or whoever 7 don't call me anymore? 8 called, and you said, Pm not interested. 8 A. No. 9 A. Yes. 9 Q. Okay. Son called a second time, and you 10 Q. All right. And did you say, don't call me 10 said what? 11 again? 11 A. She told me that she — that Jeffrey needed 12 A. No. 12 me to come, because he didn't have anybody else who 13 Q. Why not? 13 could came. SO I came. 14 A. I didn't think to say something like that. 14 Q. How was that your problem? 15 Q. And did you get another call? 15 A. It wasn't. 16 A. Yes. 16 Q. All right. So she said that — she said what 17 Q. And you had a cell phone at the time? 17 you just described, and you made a conscious decision 18 A. Yes. 18 that you would go back to Mr. Epstein's home? 19 Q. And what cell phone number was that? Was 19 MR. EDWARDS: Form. 20 that the 584? 20 THE WITNESS: Yes. 21 A. No. I don't remember the entire number. It 21 BY MR. CRITFON: 22 was a number that started with 352, though. 22 Q. Right. And you voluntarily chose to go back 23 Q. That's the 352 one you don't remember? 23 to his house a second time? 24 A. Uh-huh. 24 A. Yes. 25 Q. But cell phones pop up a number, so you -- do 25 Q. No one forced you; correct? Page 350 Page 352 1 you remember what number that would be called -- that 1 A. Correct. 2 is, the number that would be calling you -- 2 Q. Okay. And it was your choice. That is, you 3 A. Yes. 3 could have said, sony, I'm not going back to the 4 Q. — from the Epstein home? 4 Epstein home. Didn't enjoy the experience. Wasn't a 5 A. Yes. good experience. Pm done. You could have done that; 6 Q. That number you do remember? What was the 6 couldn't you? 7 number? A. I didn't think of doing that, no. 8 A. I don't — it was always a different number, 8 Q. Sure you thought of it because the first 9 and it normally started with 688. 9 phone call that you got from you said, no, I'm not 10 Q. Why did you answer it? 10 going, So you had to have consciously thought is, I 11 A. I didn't know who it was. 11 don't want to go again; right? 12 Q. Okay. So I assume you knew how to do voice 12 A. No. 13 messages, voice mail; right? 13 Q. lint sony? 14 A. I just answered it. 14 A. No. 15 Q. My question is, is: Why didn't you just 15 Q. No what? 16 let — if you weren't sure who the number was, a lot of 16 A. That wasn't my thought. 17 people just let the phone ring, go to voice mail. Then 17 Q. But your first thought was, when she called 18 if you want to call them back, you call them back. If 18 you the first time was, is, I don't want to go back; 19 you don't want to call them back, you don't have to. 19 HMO 20 MR. EDWARDS: Form. 20 A. No. 21 THE WITNESS: Because I wanted to know who it 21 Q. Okay. So after the first time that you went, 22 was. 22 you had already made up your mind you would go again, if 23 BY MR. CR/TION: 23 they called? 24 Q. Okay. So they called, and who was it? III 24 A. No. 25 seam or someone? 25 Q. So what changed your mind? 24 (Pages 349 to 352) (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 (501-333.772-1652) 92ef5b62-31335-4202-a350-6633a5c6813b EFTA00750797 Page 353 Page 355 1 A. It's it wasn't that my mind was changed. 1 you? 2 I just, l just didn't go the first time. I don't 'mow 2 A. It was not an option that I thought that ! 3 why. I was probably doing something; that's probably 3 had. 4 why. The only reason I ever went back was because he 4 Q. Wiry? 5 made me feel like I was obligated to keep going. 5 A. Because I was too young to understood. 6 Q. Why? What obligation did you have to go to 6 Q. Well, you were young enough to run away from 7 Mr. Epstein's? 7 your mother's house, you understood that, and to go to 8 A. I didn't. He was like just very demanding, 8 what considered to be a safe place at -- was it 9 and he just — he just told me what to do, and ljust 9 house? 10 felt like I needed to do it 10 A. Yes. 11 Q. Well, you were able to get away from your 11 Q. All right You understood that; right? 12 stalking boyfriend; right? That wasn't a problem for 12 A. Yes. 13 you? 13 Q. Okay. You were -- you understood enough that 14 MR. EDWARDS: Form. 14 you gave varying testimony during the trial and various 15 THE WITNESS: He, he still calls me today, 15 depositions of your father to either help him or hurt 16 so, yeah, it is a problem for me. 16 him, depending on who was influencing you; right? 17 BY MR. CRITION: 17 MR. EDWARDS: Form. 18 Q. That were — well, you were able to run 18 THE WITNESS: And during that time I had no 19 away from house and your mother's house at 19 idea what 1 was doing. 20 various times and to live with somebody else, before you 20 BY MR. CRITTON: 21 ever met Mr. Epstein; true? 21 Q. All right And you knew when or 22 A. I ran away from my mother's house, yes. 22 whoever called, called you and said, you know, would you 23 Q. Okay. And you -- you were strong enough to 23 like to come back, you could say yes or no. it was that 24 do that, and you knew, at least in your own mind, what 24 simple. 25 you wanted to do. You had a mind of your own at that MR. EDWARDS: Form. Page 354 Page 356 1 point; true? 1 THE WITNESS: It was more like, could you 2 MR. EDWARDS: Form. 2 please come back. 3 THE WITNESS: I didn't have a choice but to 3 BY MR. CRITTON: 4 leave at the time. 4 Q. Okay. So, so they said, please. You could 5 BY MR. CRITTON: 5 say, thanks, but no thanks. You had said, thanks, but 6 Q. All right. Well, you had a choice either to 6 no thanks, before; right? 7 go beck to Mr. Epstein's or not to go back to 7 A. I didn't know. I didn't !mow — 8 Mr. Epstein's. You had to first say, yes, to the person 8 Q. &we you — 9 who called; correct? You had a choice: I'll say yes, 9 A. — that that was an option. 10 or ni say no. Pro living out west of town. 10 Q. Sure you did, because — 11 Mr. Epstein lives in, you know, Palm Beach. He's got no 11 A. Oh, you did? 12 hold over me; right? He had no hold over you. 12 Q. Yeah. Because when you were in school at 13 MR. EDWARDS: Pam. 13 both — in eighth grade, that you repeated, and then 14 THE WITNESS: Yes, but I just knew that they 14 when you were at Paco, you made decisions not to go to 15 would continue to call me. 15 school and to remain truant from school; didn't you? 16 BY MR CRITTON: 16 A. That's because 1 could not go to school. 17 Q. So call the police. Why didn't you call the 17 Q. Why not? 18 police? You knew how to get ahold of the police; right? 18 A. It was not an option forme. 19 A. That wasn't the — 19 Q. Why? 20 Q. You'd had issues with the police before? 20 A. Because I was being abused at my mother's 21 MR. EDWARDS: Form. 21' house. 22 THE WITNESS: That was not the first thing I 22 Q BY? 23 thought of. 23 A. And if I went back — if I went to school, 24 BY MR. CRITTON: 24 then that would mean going back to my mom's. 25 Q. But it was an option that was available to 25 Q. Okay. Who was abusing you at your mother's 25 (Pages 353 to 356) (562) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333.772.1652) Electronically signed by Pamela Sullivan (501-333-772.1552) InefSb62-38a5-4202-a350-6633a5c6813b EFTA00750798 Page 357 Page 359 1 house? 1 A. No. 2 A. My mother. 2 Q. Did you tell yourM? 3 Q. Okay. And how was she abusing you? 3 A. Yes. 4 A. She wasn't feedin me. 4 Q. And what did she say? 5 Q. Did you tell that? 5 A. I don't remember. 6 A. Yes. . Did she call the nce? 7 O. And that's why you went to live with II Q. Police come? 9 A. Yes. 9 A. Yes. 10 Q. Okay. And she wasn't feeding you. Did — 10 Q. What did they do? 11 were — had you ever been abused by your father or by 11 A. They didn't do anything. 12 Mr. Veet? 12 Q. Did you have any physical marks? 13 A. No. 13 A. Yes. 14 Q. Okay. Did any family member, other than your 14 Q. Okay. What did you have? Where did he hit 15 mother, ever physically abuse you? 15 you? Did he hit you in the nose? What part of your 16 A. Yes. 16 face did he hit? 17 Q. Who? 17 A. I had a bump on my head somewhere. I'm 18 A. My uncle. 18 not — I don't remember where it was. 19 Q Which uncle? 19 Q. But he hit you with his fist? 20 A. 20 A. Yes. 21 21 Q. Did you leave the house after that? 22 A. Yes. 22 A. No, he did, because I called the police. 23 Q. How did he abuse you? How old were you, and 23 Q. Did he ever come back? 24 how did he abuse you? 24 A. Yes. 25 A. I don't know. I was probably Ile 15, and he 25 Q. . Did you consider that a pretty traumatic Page 358 Page 360 1 hit me. 1 event, to have an uncle haul off and hit you in the 2 Q. Where did he hit you? 2 face? 3 A. He punched me in the face. 3 MR. EDWARDS: Form. 4 Q. Was he drunk? Was he on drugs, Jane Doe? 4 THE WITNESS: No. 5 A. I don't know. 5 BY MR. CIIITTON: 6 Q. Where were you at the time? 6 Q. Didn't consider that to be traumatic at all? 7 A. I was in my bedroom. 7 MR. EDWARDS: Form. 8 Q. Okay. And did he come into your bedroom? 8 THE WITNESS: Not really. 9 A. I was walking out. 9 BY MR. CRITFON: 10 Q. ' And he just cold-cocked you? 10 Q. Okay. Had anybody else ever hit you in the 13. • A. We were limning. • 11 face like that? 12 Q. What were you arguing about? 12 A. Mykisters. 13 A. I don't remember. 13 Q. and 14 Q. And he punched you right in the face? 14 A. And my brother, yes. 15 A. Yes. 15 Q. Which brother? 16 Q. Did he break anything? 16 A. I only have one brother. 17 A. No. 17 Q. What's his name? 18 Q. Did you have to go to the hospital? 18 A. 19 A. No: 19 Q. It's Is in jail? 20 Q. You were living where, at your 20 A. Not tight now. 21 house then? 21 Q. He's been in jail, though, before? 22. A. Yes. 22 A. Yes. 23 Q. Did you get blocked down? 23 Q. [sit MP 24 A. No. 24 Q. 25 • Q. Were you knocked out? 25 Q. Where does the come from? 26 (Pages 357 to 360) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1552) Electronically signed by Pamela Sullivan (601.333-772-1552) 92ef5b62-38a5-4202-a350-6633a5c6813b EFTA00750799 Page Page 363 1 A. My mother. 1 A. Yeah. Not bad enough to go to the hospital 2 Q. Are there any -- is he a -- is he a El 2 or anything. 3 child? 3 Q. Police ever called? 4 A. Yes. 4 A. No. 5 Q. Whets he been in jail for? 5 Q. Did anyone ever attempt to rape you? 6 A. Robbery. 6 A. No. 7 Q. On how many occasions? 7 Q. Has anyone ever attempted to molest you? A. I don't know. 8 A. No. 9 Q. Are you close to your brother? 9 Q. Okay. You go back to Mr. Epstein's house the 10 A. Somewhat. 10 second time. You had their phone number; right? 11 Q. When is the last time he was in jail? 11 A. No. 12 A. I don't know. 12 Q. Well, you had it, because it showed up on 13 Q. Do you consider it traumatic that your 13 your phone? 14 brother was in jail? 14 A. I had seen it. 15 MR. EDWARDS: Form. 15 Q. Right. But all you have to do is go back to 16 THE WIDIESS: He put himself in jail. 16 recent calls; right? Every — every five-year-old, 17 BY MR. CRITTON: 17 six-year-old, seven-year-old kid in the world can show 18 Q. So he -- he basically made his bed, and then 18 me how to use a cell phone that I don't know how to use. 19 he slept in it? 19 I assume you fall within that, too. You know how to use 20 A. Yes. 20 a cell phone and how to get voice mail, how to make 21 Q. Is that the way you feel about your dad, too? 21 calls, how to pull recent calls out of your phone? 22 A. Yes. 22 MR. EDWARDS: Form. 23 Q. It was his choice to, to assault a young boy, 23 BY MR. CIFUTION: 24 and as such, he's paying the penaRy? 24 Q. And you knew that — 25 A. Yes, that's the way I feel now about it. 25 A. Okay. Page 362 Page 364 1 Q. In your earlier years were you torn, because 1 Q. — back in '03, '04, '05, '06, '07; didn't 2 he was your father? 2 you? 3 A. twos very confused, yes. 3 MR. EDWARDS: Form. 4 Q. And I've seen on various medical records that 4 11.1E WITNESS: Yeah. 5 you consider yourself to be suffering from, even today, 5 BY MR. CRITTON: 6 post traumatic stress syndrome that related to that — 6 Q. Okay. Did you ever — before -- you say a MR. EDWARDS: Form. 7 taxi was sent to pick you up? 8 BY MR. CRTITON: 8 A. Yes. 9 Q. -- related to that, that is your father 9 Q. Okay. Before that taxi got there, did you 10 murdering M. 10 say to yourself, you know what, what am I doing, I don't 11 A. Yes. 11 need to go back there. Did you ever think of that? 12 Q. Any other family member ever physically 12 A. No. 13 assault you? 13 Q. Would it be a correct statement, ma'am, that 14 A. No. 14 there's nothing about the rust event, that is the first 15 Q. Other -- other than your uncle and you said 15 time you were at Mr. Epstein's home, that you found to 16 the fights that you got in with your sisters and your 16 be in any way traumatic? 17 brothers. I assume those were more sisteribmther type 17 A. At the time I didn't think about it, but now 18 fight, or were they real fight-fights? 18 I do, yes. 19 A. Both. 19 Q. Okay. So when did you — when did you decide 20 Q. So you got into some real fights — real 20 that going to Mr. Epstein's house was a traumatic event 21 physical fights with your sisters and your brother? 21 in your life? Who helped you come to that conclusion? 22 A. Yes. 22 Was that only after you filed a lawsuit in this case? 23 Q. Where people were hurt? 23 MR. EDWARDS: Form. 24 A. Not — 24 THE WITNESS: No. Soon after 1 stopped 25 Q. • Black eyes? Blood? 25 going, it started to bother me a lot. 27 (Pages 361 to 364) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 . Electronically signed by Pamela Sullivan (501.333-772-1552) Electronically signed by Pamela Sullivan (601.333.772-1652) 92015b62.38a5.4202-a350.6833a5e8813b EFTA00750800 Page 365 Page 367 1 BY MR. CRITTON: 1 A. 1 was only 17 when I went to 2 Q. AU right. So you went 20 times to 2 Q. Okay. At the time that you thought that it 3 Mr. Epstein's house, by your own testimony, and not the 3 was wrong to go to Mr. Epstein's, why didn't you just 4 rust, not the second, not the third, not the fourth, 4 say, TM not going anymore? 5 not the tenth, not the 15th, not the 17th, not the 20th 5 A. I — I didn't feel like I had that choice. 6 time did you suffer any trauma; true? 6 Q. What — what choice? Each time you went to 7 MR. EDWARDS: Form. 7 Mr. Epstein's, you had to make a choice, am I going or 8 THE WITNESS: Yes, I did. 8 am I not going - 9 BY MR. CRITTON: 9 Iva. EDWARDS: Form. 10 Q. And at what time did you, in your own mind, 10 BY MR. CRITTON: 11 suffer, quote/unquote, trauma or some sort of 11 Q. —true? 12 psychological problem as a result of being at 12 A. Not really. 13 Mr. Epstein's? 13 Q. Why not? 14 A. Probably when I went to my program in MEI 14 A. Because - 15 Q. That was in 2007? 15 Q. How could you not have a choice? Because you 16 A. That was in -- when I was 17. 16 lived west of town. He lived east of town. You lived 17 Q. Okay. Which was —you went to =right 17 miles apart. You had to take some affirmative action in 18 after the last time you saw Mr. Epstein? 18 order to get to Mr. Epstein's home; didn't you? 19 A. Yes. 19 A. No. 20 Q. So of the approximately 20 times that you 20 Q. Why not? 21 went to Mr. Epstein's, at no time did you believe that 21 A. I had to get in a cab and... 22 you had suffered any physical injury; correct? 22 Q. That's an affirmative act. You had to either 23 A. What do you mean? 23 say, I'm going, or I'm not going. 24 Q. I'm just asking the question: During the 24 MR. EDWARDS: Objection to form. 25 time — approximately 20 times you went to 25 THE WITNESS: I don't know what you mean. Page 366 Page 368 1 Mr. Epstein's, you didn't believe that you had suffered 1 BY MR. CRITTON: 2 any kind of physical injury; did you? 2 Q. Sure you do. You 'mow that — what an 3 A. No. 3 affirmative act is, taking some oven act to do a 4 Q. No pain and suffering? 4 particular task; right? You understand that? 5 A. I —1 felt like it was very wrong. I 5 MR. EDWARDS: Form. 6 6 THE WITNESS: I don't know what you mean. Q. Which time? The first time? 7 BY MR. CRITTON: 8 A. Every time. Q. Well, you — if -- if you have to make a 9 Q. Okay. Then after the first time you went and 9 decision, and your decision tree is I can say either do 10 you felt that going to his house was wrong — and you 10 something or not do something, doing something is taking 11 knew the difference between right and wrong; didn't you? 11 some affirmative act; right? Not doing something is — 12 A. Not really. 12 is a negative act, or not doing an affirmative act. Do 13 et You knew committing — well, as of the time 13 you understand that concept? 14 thatM. took you to Mr. Epstein's the very first time, 14 A. I guess. 15 you knew the difference between right and wrong; didn't 15 Q. All right. And in order to go to 16 you? 16 Mr. Epstein's house, you had to actually say you had 17 MR. EDWARDS: Form. 17 to make a mental decision, that is you had to make a 18 THE WITNESS: Not really. 18 decision in your own mind, I'm going there. And it's 19 BY MR. CRITTON: 19 okay. Right? 20 Q. Okay. Well, how about when ou were - when 20 A. Yeah, I guess so. 21 you were working at or did 21 • Q. All right. You —you say that you've lost 22 you know the difference between right and wrong? 22 income and you want -- in your Rule 26 disclosures, 23 A. Yes. 23 which is something that your lawyer provided or filed 24 Okay. Did you were you working at 24 with the court, you said that you've lost in excess 25 before you went to or after? 25 of -- you have a past and fitture lost wages and past and 28 (Pages 365 to 368) (561) 832-7500 PROSE COURT REPORTIN G AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-7M4552) Electronically signed by Pamela Sullivan (501-333-772-1552) 9205b62-38a5-4202-a350-6633a5c6813b EFTA00750801 Page 369 Page 371 1 future loss of earning capacities — capacity in excess 1 A. No. 2 of a million bucks. 2 Q. Have you erased anything from your Face Book 3 Okay. What did Mr. Epstein -- that is, what 3 over the last six months? 4 occurred at Mr. Epstein's that has caused you — that 4 A. No. 5 caused you to lose any money as of today's date? 5 Q. Okay. Are there any photographs or 6 MR. EDWARDS: Form. 6 information on your face — well, let me strike that. 7 717E WITNESS: Pretty much everything. 7 How long have you had Face Book? 8 BY MR. CliTTTON: A. A few months. 9 Q. What — what — what has Mister what was 9 Q. Starting when? 10 your — has your experience Mr. Epstein -- excuse me -- 10 A. I don't know. A few months ago. 11 done that has caused you to lose money, as of today's 11 Q. 2009, you started? 12 date? 12 A. Yes, this year. 13 A. Pretty much everything that happened at 13 Q. Have you put any type of photographs on your 14 Jeffrey Epstein's house makes me extremely depressed to 14 Face Book that would in any way — you would find 15 a point where I don't -- I'm extremely sluggish, and 1 15 embarrassing to you — 16 don't even feel like tin out of bed sometimes. 16 A. No. 17 Q. Other than e — well, let me 17 Q. — if someone saw it? 18 strike that. 18 Let me get back to the loss of earnings. 19 If you still did not feel sluggish and you 19 Other than the jobs that you had — let milt 20 23. didn't want to get out of bed, would you start stripping again, working at the strip clubs? 20 21 Sand worked as a stripper at you had — you earned money , 22 A. No. 22 correct? 23 Q. Why? 23 A. Yes. 24 A. Because I don't want to do that anymore. 24 Q. Okay. How much money did you earn for the 25 Q. Why? Because you have a child? 25 year 2006? Page 370 Page A. That's part of the reason, yes. 1 A. I don't know. 2 Q. Okay. Ma'am, have you ever had a My Space 2 Q. Did you ever keep track of it? 3 page or a Face Book page? 3 A. No. 4 A. I have a Face Book. 4 Q. How about 2007? 5 Q. Right now? 5 A. I don't know. 6 A. Yes, I do. 6 Q. Okay. Did you ever talk with anyone about 7 Q. And what — what's it under; what's the 7 the need to file Federal income tax — 8 designation under? A. No. 9 A. Jane Dee. 9 Q. — on the money? 10 Q. And how would someone hook up with you by 10 A. No. 11 Face Book? What would they put in? 11 Q. And I think you told me earlier you've never 12 A. My name. 12 filed income taxes? 13 Q. Jane Doe? 13 A. Right. 14 A. Yes. 14 Q. Okay. Approximately, do you have any idea 15 Q. And how long have you had a — have you ever 15 how much money you made in 2006 or 2007? 16 had a My Space page? 16 A. No. 17 A. Yes. 17 Q. But you were able to dance in 2006 and 2007, 18 Q. And did you close that down? 18 so what loss of income did Mr. Epstein — your 19 A. I've really never figured out how to make it. 19 experience with Mr. Epstein cause you? 20 20. MR. EDWARDS: Form. Calls for a legal 21 Q. Do you Face Book; do and fl Face Book 21 conclusion. 22 you? 22 THE WITNESS: I guess afterward, when I— I 23 A. No. 23 guess I just haven't, you know, felt like good 24 Have you ever corresponded with either M. 24 enough to get another job. 25 or . . through Face Book? 25 let 29 (Pages 369 to 372) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772.1562) Electronically signed by Pamela Sullivan (501433-772-1652) 92ef5b62-38a5-4202-a350-6633a5c6613b EFTA00750802 Page 373 Page 375 1 BY MR. CRITTON: 1 both of those are difficult for you to talk about? 2 Q. Well, your PTSD plays a role in that, as 2 A. Yes. 3 well; doesn't it? 3 Q. Okay. And each -- each one is equally 4 MR. EDWARDS: Form. 4 difficult in your own mind; isn't it? 5 THE WITNESS: Not really anymore. 5 A. Yes. 6 BY MR. CRITTON: 6 Q. And so if you mentioned one, you'd probably 7 Q. If anybody has asked you since the time that 7 mention both, or you wouldn't mention either one; 8 you last saw Mr. Epstein, not only S but 8 correct? 9 if anybody asks about your mental state or your 9 MR. EDWARDS: Form. 10 emotional state, do you tell them everything? 10 THE WITNESS: Yes. 11 MR. EDWARDS: Form. 11 BY MR. CRITTON: 12 THE WITNESS: No. 12 Q. The second tint you went back to 13 BY MR. CRITTON: 13 MT. Epstein's home, aisthire different happen than the 14 Q. Why not? 14 first time, other than M. wasn't there? 15 A. Because I don't find it easy to talk about 15 A. Not really. 16 that. 16 Q. When is the next time you went back, then? 17 Q. Do you think ifs easy to talk about having 17 A. I don't know. 18 seen your father murder the son of his girlfriend? 18 Q. How many banes did you go back in the year 19 A. Not at all. 19 2003? 20 Q. Is that easier for you to talk about — 20 A. I don't know. 21 MR. EDWARDS: Form. 21 Q. How many times did you go back in the year 22 THE WITNESS: Not at all. 22 2004? 23 BY MR. CRITTON: 23 A. I don't know. 24 Q. — than your experience with Mr. Epstein? 24 Q. How many times did you go back in the year 25 A. Not at all. 25 2005? Page 374 Page 376 1 Q. But you mention that, if somebody asks; don't 1 A. I don't !mow. 2 you? 2 Q. How about in the year 2006? 3 MR. EDWARDS: Form. 3 A. I don't know. 4 BY MR. DUTTON: 4 Q. In fact, did you go at all in 2006? 5 Q. Or do you not mention that, either? 5 A. I'm not sure. 6 A. If somebody asked what? 6 Q. When is the last time you believe you went to 7 Q. If somebody says, well, what — what -- how 7 Mr. Epstein's home? 8 do you feel? Lace when you've seen physicians, been in 8 A. I was 17 years old. 9 the hospitals, and they say, you know, what's your -- 9 Q. Did you ever put any of the money that you 10 how do you feel, you know, are you — are you depressed. 10 received from Mr. Epstein in a bank account? 11 are you happy? And what do you tell them? 11 A. No. 12 A. I don't !mow. 12 Q. At any time during the time you went to 13 Q. You don't know what you told them? 13 Mr. Epstein's house did the -- what you've described as 14 A. No. 14 occurred on the first occasion, did that ever change? 15 Q. But whatever you would have said in response 15 A. I don't know. I guess after I went more and 16 to if a nurse or a physician asked you, or a hospital 16 more times, he got like more comfortable, and I guess 17 asked you, what how you — how do you feel from a -- 17 lila more like aggressive kind of. 18 from a psychological or an emotional standpoint, you'd 18 Q. How many times had you gone before there was 19 tell them the truth; wouldn't you? 19 a change? 20 A. 1 don't know. 20 A. I don't know. Probably like six or so. 21 Q. Okay. So you might lie to your doctor or to 21• Q. What year are we in now? 22 the hospital? 22 A. I don't know. Probably -- probably 2004. 23 A. Ifs not easy for me to talk about that. 23 Q. You'rejust guessing? 24 Q. About what? Either — either event? Either 24 A. Yes. 25 what your father did and you witnessed, or Mr. Epstein, 25 Q. When you say something changed, did he ••••••14....w4•L•evwSV•a . , ..`, 35• Wtwaa 30 (Pages 373 to 376) (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) 92ef5b62-38a5-4202-3350-6633a5c6813b EFTA00750803 Page 377 Page 379 1 ever — did he ever touch you? 1 touch you on any of the visits? 2 A. Yes. 2 A. He always — 3 Q. Okay. On how many occasions? 3 Q. Is that what you said, about the sixth time? 4 A. He always did, but he just got more 4 A. He always touched me. 5 aggressive about it. And, eventually, he wanted to use 5 Q. Where? 6 like sex toys on me. 6 A. He touched my breasts. He touched my vagina. 7 Q. Did he — did he ever physically touch you on 7 He always touched me. 8 any occasion? 8 Q. Did you ever tell him — well, let me strike 9 MR. EDWARDS: Object to the form. Asked and 9 that. 10 answered. 10 He couldn't touch you, unless you allowed him 11 THE WITNESS: What do you mean? 11 to touch you; correct? 12 BY MR. CRITTON: 12 MR. EDWARDS: Form. 13 Q. Did he ever touch you? You — you were 13 BY MR. CRITTON: 14 touching him, because you were giving him a massage; 14 Q. You had to vohmtarily allow him to touch 15 right? 15 you? 16 A. Yes. 16 MR. EDWARDS: Form. 17 Q. And that's something that you were doing 17 THE WITNESS: I don't know what you mean. 18 voluntarily? 18 BY MR. CRITTON: 19 MR. EDWARDS: Form. 19 Q. Well, the very first time you were there, I 20 THE WRNESS: That was something that he told 20 think you said he didn't touch you; correct? 21 me to do, yes. 21 A. No, I did not say that. 22 BY MR. CARTON: 22 Q. Okay. Did he touch you the very first time 23 Q. But you had to get to the house. There's no 23 you were there? 24 way you could give him a massage, unless you made the 24 A. Yes. 25 decision to go to his house; correct? 25 Q. Okay. Where? Page 378 Page 380 1 MR. EDWARDS: Form. 1 A. My vagina. 2 THE WITNESS: Yes. 2 Q. And when he touched you there, did he — did 3 BY MR. CRITTON: 3 he — was there any type of penetration, or did he just 4 Q. Okay. Because he couldn't force you to do 4 touch you? 5 anything, unless you were at the home. And even if you 5 MR. EDWARDS: Form. 6 were at the home, all you had to do was to say, no; 6 ME WITNESS: I don't remember. 7 correct? 7 BY MR. CRITTON: 8 MR. EDWARDS: Form. 8 Q. Okay. When he touched your vagina -- with 9 THE WITNESS: I didn't feel that way, no. 9 his hand? 10 BY MR. CRITTON: 10 A. Yes. 11 Q. Well, if you did -- if you didn't feel that 11 Q. What did you say to him? 12 way, that is that you didn't have a choice, your choice 12 A. I didn't Say anything. 13 was then nn not going to Jeffrey Epstein's home ever 13 Q. Okay. Had anyone ever touched your vagina I4 again; true? 14 before? Had a male ever touched your vagina before? 15 A. No. 15 A. No. 16 Q. Okay. Did you take money every time you went 16 Q. And when he touched your vagina, did you 17 to Mr. Epstein's home? 17 say — and your -- when you say your vagina, on the 18 A. Yes. 18 exterior of your body; right? 19 Q. Did you ever say, Mr. Epstein, I don't want 19 A. Yes. 20 your money, I don't want to come back again? 20 Q. Did you say, please don't do drat? 21 A. No. 21 A. I didn't say anything. 22 Q. You could have, though; couldn't you? 22 Q. You could have. You just didn't; true? 23 A. I didn't know that I could have. 23 MR. EDWARDS: Form 24 g You said he touched you. How did he touch 24 THE WITNESS: I didn't know what to say. 25 you — well, let me ask you this: When did he first 25 31 (Pages 377 to 380) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601,333-772-1552) Electronically signed by Pamela Sullivan (601-333-772-1552) 92et5b62-38354202.3350-6633a5c6813b EFTA00750804 Page 381 Page 383 I BY MR. CANTON: 1 BY MR. CRITTON: 2 • Q. Well, if you -- if you had said, don't touch 2 Q. You may not have thought you bad a choice, 3 me — did you ever tell him, don't touch me, or don't do 3 but it was your choice; true? that? 4 MR. EDWARDS: Form. 5 A. I didn't think of that, no. 5 THE WITNESS: I don't know. e Q. Okay. So the 20-some-odd times you were 6 BY MR. CRITTON: 7 there, you never said or never thought about telling him 7 Q. You knew — 8 not to do something; correct? 8 MR. CRITTON: Well, why don't we take a 9 A. That's coned. 9 break. We only have a couple ofminutes left 10 Q. Okay. So at least from his perspective -- 10 (A brief recess was taken.) 11 well, let me strike that. 11 BY MR. CRITTON: 12 Did you ever tell him that you didn't like 12 ane Doe, do you know a pan named 13 him touching you? 13 14 A. I don't remember. 14 A. Do you know him by any other name? 15 Q. You don't remember telling him that; do you? 15 Q. I don't kno I'm just asking 16 A. I don't remember. 16 whether you know 17 Q. Okay. Well, you would remember if you said, 17 A. I'm not sure. 18 don't touch me there, or if you had pushed his band 18 Q. Did you know HIM 19 away; wouldn't you? 19 A. 20 MR. EDWARDS: Form. 20 Q. 21 THE WITNESS: I do remember that I was like 21 A. I have met him once. 22 miserable, and I know that I looked miserable. And 22 Q. Okay. And how do you know do — how do 23 so he would pretty much tell me that, ifs okay. 23 you know him? 24 BY MR. CRITTON: 24 A. A friend of a friend had his baby. 25 Q. You'd say you looked miserable, what do you 25 Q. I'm sorry? A friend of a — Page 392 Page 384 1 mean? 1 A. A friend of a friend had his baby. 2 A. Like I obviously didn't look like I was 2 Q. Okay. Ant friend of a friend? 3 ewhat? 3 5 6 enjoying what was happening. Q. Okay. And were you enjoying what was happening? A. Absolutely not. 4 5 7 A.r Q. A. Q. A. Na Do (phonetit you know 7 Q. Okay. Then why did you go bacht Why didn't 8 you say, don't do that, Mr. Epstein — or what 8 Q. Do you knowIMIN 9 did you call him, Jeffrey, or did you call him 9 A. I — 10 Mr. Epstein? 10 (phonetic)? 11. A. I didn't call him anything. 11 A. I have meta guy named but I don't 12 Q. You never called him by his first name or his 12 know his last 13 last name? 13 Q 'nrougs mill? 14 A. No. 14 A. Yes. 15 Q. Is it your testimony that you never told 15 Okay. Do you know whether — that's 16 him — well, let me strike that. 16 U .'s boyfriend, or someone she lived with at one time? 17 It is your testimony you never told him not 17 A. I believe that he was her boyfriend. 18 to do anything correct? 18 Q Okay. Do you know someone namecIIIMM. 19 MR, EDWARDS: Form. 19 A. Yes. 20 THE WITNESS: Correct. 20 Q. Okay. How do him? 21 BY MR. CRITT0N: 21 A. I met him throuYghlir 22 Q. And everything that you did there was 22 Q. Okay. Is that it's one ofher boyfriends? 23 voluntarily — voluntary; it was your choice? 23 A. Yes. 24. MR. EDWARDS: Form. 24 Q. • Okay. How ab (phonetic)? 25 25 A. I had never met but) head about him. 32 (Pages 381 to 384) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-313-7721552) Electronically signed by Pamela Sullivan (601.333-772-1552) 92ef5b62-38a5-4202-2350-6633aScS813b EFTA00750805 Page 385 Page 387 1 Q. What did you hear? 1 Q. What was his last name? 2 A. I heard that he was with M. in the past, 2 A. I don't know. 3 and he abused her. 3 Q. Another-. person? 4 Q. Okay. Physically abused her? 4 A. Yes. 5 A. I don't know. I — I don't know. 5 Q. Okay. These are all people that she had 6 Q. Was he into drugs, M? 6 relationships with? 7 A. I don't know. 7 A. im:ss so. 8 Q. Okay. How about M? 8 Q. MI (phonetic), is that the 9 A. Yes. 9 you were talking about? 10 Q. was into drugs? 10 A. Yes. 11 Yes. 11 Q. Okay. Did M. ever tell you that she had 12 Q. What kind of drugs? Was he a drug dealer? 12 been raped or molested? 13 A. I don't know. 13 A. No. 14 Q. You don't blow, you just know he was into 14 Q. Did.. ever tell you that she had been 15 drugs? 15 raped or molested? 16 A. Yes. 16 A. No. 17 Q. Okay. Did M. tell you that? 17 Q. Ma'am, have you ever had an abortion? 18 A. You can pretty much tell. 18 A No. 19 Q. From seeing him? 19 Q. Have you ever been pregnant, other than the 20 A. Yes. 20 one time with this — your current child? 21 Q. How? 21. A. No. 22 A. He -- he looked like he was on drugs every 22 . Q. Ms. Jane Doe, didn't M. tell you before 23 time I ever saw him. 23 you — she first took you to Mr. Epstein's house that — 24 Did you ever know someone named that 24 didn't she say specifically, I told her that we were 25 M. dated? 25 going to go to just an old guy's house, he is really Page 386 Page 388 1 A. what? 1 rich, and he has a beautiful mansion, and we're going to 2 Q. I'm not sure. 2 go upstairs and give him a massage. I told her, her 3 A. Yes. 3 meaning lane Doe, that I would be there with her for 4 Q. Did you know an ai 4 half the time, and I would leave the room. And when I 5 A. Yes. 5 left the room, he is going to tum over and do himself, 6 Q. What was his last name? 6 by meaning ejaculating. 7 A. I — I'm not sure, but I — !know that my 7 She told you that before you went to 8 uncle was friends with his uncle, whose last name was 8 Mr. Epstein's house the first time; didn't she? 9 9 A. No. 10 Q. IL ? 10 Q. Okay. Didn't she also tell you on the first 11 A. 11 occasion that you would have to be topless? 12 Q. 12 MR. EDWARDS: Fans. 13 A. Yes. 13 THE WITNESS: No. 14 4.O1. And soft could have been 14 BY MR. CRITIDN: 15 15 Q. Didn't she tell you that Jeffrey was a nice 16 A. Yes, possibly. 16 guy and wouldn't make you do anything that didn't 17 18 Q. All right. Was that — was that Uncle A. Yes. si 17 18 want to do, or words to that effect? Didn't M. tell you that before the first time? 19 Q. How about — and — and vvas a drug 19 A. That is not exactly what she said to me. 20 guy, too?. 20 .Q. That's what you understood, though? 21 A. I don't know. 21 A. No. 22.. Q. How about a person named ='? 22 Q. Okay. Well, did she tell you that, that 23 A. 23 Jeffrey was — that the older man was a nice guy that 24 Q. 24 wouldn't make you do anything that you don't want to do? 25 A. Yes, I met him. 25 A. No. 33 (Pages 385 to 388) (561. ) '832.-7500 PROSE COURT REPORTING AGENCY, INC. ' (561) 832-7506 . Electronically signed by Pamela Sullivan (601-333-772.1552) Electronically signed by Pamela Sullivan (501.333.772-1552) 9205b82-3844-4202-a3804633•Se6813b EFTA00750806 Page 389 Page 391 1 Q. Okay. Didn't she tell you that you were 1 and — you and your attorney answered them — or you 2 going to see him ejaculate? 2 answered them on January 23rd of 2009 — at least that's 3 A No. 3 when they were sent to me. 4 If.. had said those things, your position 4 Do you remember receiving these written 5 is M. is M. lying right? 5 questions? 6 MR. EDWARDS: Form. 6 A. I remember discussing these questions over 7 TIM WITNESS: She certainly could have been 7 the phone with Brad. 8 mistaken. 8 Q. Okay. And you don't have to tell me what was 9 BY MR. CRITTON: 9 discus'' but you and your attorney consulted one 10 Q. Well, assuming she testified under oath, 10 another? 11 there's a difference between mistaken and being lie — 11 A. Yes. 12 and lying isn't there, in your mind? 12 Q. Okay. And you see, if you go to the very 13 MR. EDWARDS: Form. 13 last page, there's a verification. It says: "The 14 THE WITNESS: If she thought that she told me 14 foregoing answers to interrogatories are true and 15 that, then she was mistaken, bonus,. she did not 15 correct, to the best of my knowledge, information and 16 tell me that. 16 belief." And it has Jane Doe, Plaintiff. Is that your 17 BY MR. CRITTON: 17 Jane Doe? 18 Q. Has anybody ever told you that you may have a 18 A. Yes. 19 cause of action against for having brought you to 19 Q. All right. And all of the answers to these 20 Mr. Epstein's house the first time? 20 interrogatories you represented to be true and accurate; 21 MR, EDWARDS: Form 21 correct? 22 THE WITNESS: No. 22 A. I did look over some of them with Brad, and 23 BY MR. CANTON: 23 some of them were not right 24 Q. Have you ever signed a — you're aware that 24 Q. Okay. Well, that's not my question. When 25 Mister — we established earlier that Mr. Edwards 25 you sent these out to me, or when Mr. Edwards — take it Page 390 Page 392 1 represents M. Have you ever signed a waiver of 1 back conflict letter about that you would agree not to sue 2 When you signed these answers to the 3 Int? 3 interrogatories on January 23rd, 2009, and verified 4 A. Not that I know of. 4 they're true and correct, you represented to me and to Q. Are you aware that you have a claim -- that 5 the Cowl that those answers wens true and correct. You 6 you may well have a claim against M. for having taken 6 understood that, yes; correct? you to Mr. Epstein's the first time? 7 MR. EDWARDS: Form. 8 MR. EDWARDS: Form. 8 THE WITNESS: Yes. 9 THE WITNESS: No. 9 BY MR. CRITTON: 10 BY MR. CRITTON: 10 Q. All right. And as of todays date, which is 11 Q. Did you ever reach an agreement with 11 September 30,2009, you have made no corrections to 12 that you wouldn't sue her? 12 these interrogatories; have you? 13 A. No. 13 MR. EDWARDS: Form. 14 Q. Do you have a side agreement with oh, I 14 THE WITNESS: I have told Brad that there 15 16 won't sue you, A. No. me, 15 16 were some. BY MR. CRITTON: 17 MR. CRITTON: This is Number 6. 17 Q. Okay. You need to listen to my question, 18 Let me show you Exhibit 6, which are your 18 ma'am. 19 answers to interrogatories. 19 . As of todays date, you have filed — at . 20 liere you go, Brad, there's a copy for you. 20 least, you're unaware of any filing that's been made on 21 (Defendant's Exhibit No. 6 was marked for 21 your behalf to correct any of these answers to 22 identification.) 22 interrogatories; true? 23 BY MR. CRITTON: 23 MR. EDWARDS: Fonn. And I'd like you to let 24 Q. These are interrogatories that were sent to 24 the witness answer the question, as she was. As 25 you, ma'am, back in I believe in December. And you 25 you know, no Plaintiffs file anything; the 34 (Pages 389 to 392) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC: ' (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-7724 552) Electronically signed by Pamela Sullivan (501-333-772-1552) 92efSb62-SilaS-4202-a3S0-6633a5c6813b EFTA00750807 Page 393 Page 395 1 attorneys do it for them. And she was going to 1 Q Well, how about average days per month, did 2 answer your question. 2 you work at least ten days a month? 3 MR. CRITTON: Well, if she tells me -- you're 3 A. Yes. 4 going to let her — she's trying to say what Brad 4 Q. Okay. And if you worked ten days a month, 5 told me, or something. So if you're going -- S and you were getting SI0 — I'm sorry — ten days a 6 willing to waive the attorney/client privilege, 6 month times 200 bucks, you would get about $2,000 a 7 I'll let her go ahead. I was just trying to help 7 month? So you had to have been earning at a minimum of 8 you out here. Good Samaritan. 8 about 2,000— $2,000 a month times 16 months, you would 9 MR EDWARDS: Yeah. 9 have made about S32,000 minimum, working for 10 She has made me aware of better answers, and 10 and right? That's just math. 11 I will file. 11 MR. EDWARDS: Form. 12 BY MR.. CRITTON: 12 THE WITNESS: Possibly. 13 Q. At least as of today, you have done nothing? 13 BY MR. CRITTON: 14 You have — you have not signed any papers that would 14 Q. You may have made more? 15 change the exhibit — the answers in Exhibit 6; true? 15 A. I probably actually made less. 16 MR. EDWARDS: Form. 16 Q. Okay. Well, you could have made more; could 17 THE WITNESS: Right. 17 have made a little less — 18 BY MR. CRITTON: 18 MR. EDWARDS: Form. 19 Q. Have you ever worked as an escort? 19 BY MR. CRITTON: 20 A. No. 20 Q. —right? 21 Q. Man of — our i that you did at 21. A. No. 22 either or , did -- did any male 22 Q. No what? 23 or female ever ask you to go out with them on a date? 23 A. 1didn't make more than that. 24 A. Yes. 24 Q. Okay. How do you know that, if you never -- 25 Q. Okay. Did you ever go with any of those 25 if you didn't keep track of your records? And I'm Just Page 394 Page 396 individuals? 1 trying to use your numbers. So it was about $200 a thy, 2 A. No. 2 times ten days a month, times 16 months, would be about 3 Q. During the time that you worked — and I was 3 32,000 bucks; right? 4 hying to — worked at — that you worked at Platinum, 4 A. If I made $200 every time. 5 and thenMEM, you worked, I think we worked out 5 Q. Well, if — if you did — how many lap dances 6 about, let's see — six — four —14 to 16 months that 6 would you generally do a night? 7 you would have worked at - andMIM 7 A. I don't know. 8 something. Does that sound about right? 8 Q. Did you always get at least one lap dance a 9 A. Yes. 9 night? 10 Q. Okay. And you said that your — your general 10 A. No. 11 take was approximately $200 a night? 11 Q. And some nights nobody was interested in 12 A. Yes. 12 doing a lap dance with you? 13 Q. Okay. And if you, over that 14- to 16-month 13 A. That's right. 14 time period, would you say that you waited an average of 14 Q. Did you have some nights that maybe a few 3.5 about five days a week? 15 people were interested in a lap dance? 16 A. No. 16 A. Yes. 17 Q How many days a week? 17 Q. Okay. When you were at — working et 18 A. Um. 18 and at a were you still taking 19 Q. I know you said sometimes you work seven; 19 drugs? You were still working with illegal drugs; 20 sometimes you might not work for — 20 weren't you? 21 A. Sometimes 1 didn't work fora month or two. 21 MR. EDWARDS: Form. 22 Q. Approximately, out of those 14 to 16 months, 22 THE WITNESS: At times. 23. approximately how many what would have been your 23 BY MR. CRITTON: 24 average number of days that you would have worked? 24 Q. Okay. Did you ever take illegal drugs before 25 A. I have no idea. 25 you went to Mr. Epstein's house? 35 (Pages 393 to 396) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772.1562) Electronically signed by Pamela Sullivan (501-333-772-1552) 92ef5b62-38a54202-a350-6633a5c6813b EFTA00750808 Page 397 Page 399 A. No. 1 A. Yes. 2 Q. Separate and aS-- you -- you 2 Q. Was it a psychiatrist or a psychologist or a 3 mentioned your friend - give me her last name. 3 licensed mental health counselor? 4 5 6 A. Q. A. (phonetic). 4 5 6 Have A. I don't know. you ever seen any of the records from 7 Q. Her too. Let me start again. 7 A. No. 8 With Melissa did you ever take her 8 Q. You're yawning. Were you up late last night? 9 to Mr. Epstein's house? 9 A. No. 10 A. No. 10 Q. Okay. You're certain you're not on any kind 11 Q. Okay. Why not? 11 of medication today? 12 A. I didn't want to. 12 A. Yes. 13 Q. Did you ever tell her about what you were 13 Q. Any kind of prescription or nonprescription 14 doing at Epstein's house? 14 medication? 15 A. No. 15 A. Yes. 16 Q. Okay. Did you ever tell anyone? 16 Q. Okay. What you were at. !think you 17 A. No. 17 said — how often would you talk to a psychologist or 18 — did sister or or 18 a -- some sort of a mental health counselor type person? 19 ever say to you, what do you mean you're 19 A. I don't know. 20 cleaning this guy's house over in Palm Beach, what's 20 Q. Once a day? Once a week? Once a month? 21 going on here, you're coming home with a couple of 21 A. About once a week. 22 hundred bucks each time? 22 Q. Did you talk to them about did Epstein 23 A. No. 23 ever come up? 24 Q. Okay. Did you ever spend more than an hour 24 A. No. 25 at Mr. Epstein's home? 25 Q. Okay. Did your — the murder trial that you Page 398 Page 400 1 A. No. 1 testified in come up? 2 Q. Okay. So you would get 200 bucks, or then 2 A. Yes. 3 300 I think you said later on, for being at 3 Q. Did your trouble with the law, that is the 4 Mr. Epstein's. Did you show them how much money you 4 grand theft auto and other problems that you had, did 5 got? 5 you discuss that with the therapist? 6 k No. 6 MR. EDWARDS: Form. 7 Q. Did you ever pay or your uncle for 7 THE WITNESS: I discussed common knowledge 8 taking you? 8 with them, yes. 9 A. Yes. 9 BY MR. CRITTON: 10 Q. How much did you pay them? 10 Q. Common knowledge? 11 A. I don't know, 25, maybe 450. 11 A. Things that everybody pretty much knew. 12 I think you said that you — you ended up at 12 Q. What do you mean by that? I don't know what 13 School as a result of a -- of the prosecution 13 you mean by common knowledge. 14 relating to grand theft auto; correct? 14 A. Stuff that you can just find out. 15 A. Yes. 15 Q. Got to help me here. Ideal know what you 16 Q. And during the time you wae at did 16 mean. 17 you see a psychologist? 17 A. Well, obviously, I was charged with a crime 18 A. Yes. 16 to be sent there, so they knew about that. 19 Q. Was that part of your therapy or part of the 19 Q. Which was the grand theft auto? 20 sentence? 20 MR. EDWARDS: Form. 21 A. Yes. 21 THE WITNESS: Yes. 22 Q. Okay. Did you talk with a therapist about 22 BY MR. CRITTON: 23 do you remember the name of the therapist? 23 Q. Okay. What other crimes had you committed by 24 A. No. 24 that point in time? We have an offense where you 25 Q. Was it more than one therapist? 25 shoplifted in Palm Beach County; right? 36 (Pages 397 to 400) (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) 9205b62-38a5-4202-a350-6633a5c6813b EFTA00750809 Page 401 Page 403 1 MR. EDWARDS: Form. 1 Q. Have you been evaluated by any psychiatrist 2 THE WIINESS: Yes. 2 or psychologist at the request ofyour attorney? 3 BY MR. CR1TTON: 3 A. No. you ever seen a person by the name of 4 5 6 Q. Okay. Any other crimes that you can remember off the top of your head as sitting here? A. Running away. 4 5 6 air A. Yes. 7 Q. And did you discuss those all with the 7 Q. Okay. Well, who do you think she is? 8 therapist? 8 A. A psychologist or a psychiatrist or A. Yes. 9 something, 10 Q. Okay. And how would the therapist have known 10 Q• okay. And how did you get — when did 11 about your testimony and your involvement with regard to 11 Ms. Sdo an evaluation on you? 12 seeing your father murder 12 A. She did not. 13 A. Because my mother asked that I work on that. 13 Q. Okay. When did you see her? 14 Q. And you say that nothing ever came up with 14 A. I don't 'mow. 15 regard to Mr. Epstein or any of the — what had occurred 15 Q. This year? 16 at Epstein's with the therapist? 16 A. Yes. Not long ago, like — 17 A. No. 17 Q. In the past — sony; go ahead. 18 Q. Why not? Why didn't you bring it up if it 18 A. — a month, maybe two. 19 was such an important event for you? 19 Q. Okay. And hwaija it get set up that you 20 A. Because I did not want my family to know. 20 would meet with Ms. 21 Q. But and then the only people in your 21 MR. EDWARDS: Objection. Do not answer. 22 family as far as you know, today that know, is your 22 Attorney/client privilege. 23 23 BY MR. CRITION: 24 A. Yes. 24 Q. Did you meet with her? 25 Q. Did you ever tell your sisters and 25 A. Yes. Page 402 Page 404 1 that you were making money from giving -- for 1 Q. Okay. Where did you meet with ha? 2 giving massages to Mr. Epstein? 2 A. Somewhere downtown. I — I don't exactly 3 A. No. 3 remember where it was. 4 Q. Did you ever tell either or 4 5 Q. Downtown in West Palm Beach? A. Yes. 5 that you liked going to Mr. Epstein's house? 6 A. No. 6 Q. AM how long — bow much time did you spend 7 Q. Did you -- did -or ever meet 7 with her? 8 Mr. Epstein? A. Not very much. 9 A. No. 9 Q. And why not? 10 Q. Did Ms. Brewer ever meet Mr. Epstein? 10 MR. EDWARDS: Objection. It was a 11 A. No. 11 consultation, and we're claiming a privilege. 12 Q. Have ou seen — other than — well, 12 She's not going to divulge the circumstsa or the 13 you've seen who I — at least, looking 13 conversation between herself and Ms. INE — 14 at her resume, she's a licensed mental health counselor 14 Dr. Mig 15 through Victim Services. Is that -- am I right? 15 MR. CRITTON: — are you 16 MR. EDWARDS: Form. 16 intending to use Ms. MI as an expert in this 17 THE WITNESS: Yes. 17 case? 18 BY MR. CRITTON: 18 MR. EDWARDS: No. 19 Q. Other thanIMIM, have you seen any 19 BY MR. CRITTON: 20 other psychologist, psychiatrist or licensed mental 20 Q. Okay. I asked you earlier whether your 21 health counselor relating to any damages you claim in 21 attorney — whether your attorney had set up any 22 this case that were caused by Mr. Epstein? 22 meetings for you to meet with a psychologist or a 23 A. No. 23 psychiatrist or a licensed mental health counselor, and 24 Q. Why not? 24 you said, ritwapd it wasn't until I said, did you ever 25 A. Because I'm embarrassed. 25 meet Amy EN or someone like her, and you go, yeah, I 37 (Pages 401 to 404) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772-1652) Electronically signed by Pamela Sullivan (601-333.772-1552) 92ef6b62-38a5-4202-a350-6633a6c6813b EFTA00750810 Page 405 Page 407 1 did. Why didn't you tell — 1 Ms. lare helpful? 2 A. You asked me if -- .2 A. Sometimes. 3 Q. — me what — 3 Q. Okay. And how often do you see her? 4 A. -- I had an evaluation, which I did not. 4 A. I was seeing her once a week. I haven't seen 5 Q. Oh, okay. So you -- you met Ms. III but 5 her in a while now, though. 6 she never did an evaluation? 6 Q. Why not? When is the last time — well, let 7 A. Yes. 7 me strike that. 8 Q. Okay. Was it your choice — did you not want 8 When did you last see her? 9 her to evaluate you? 9 A. About a month or so ago. 10 MR. EDWARDS: Objection. The witness is not 10 Q. And why haven't you seen her again? 11 answering the question as to Dr. alor that 11 A. I don't know. 12 meeting. We're claiming a priir as to that 12 Q. Do you intend to go back to see her, or Just 13 communication between Dr. nd the Plaintiff. 13 going to kind of wait and see? 14 And, as well, this pertains to attorney/client 14 A. Yes, I do. 15 information. Any answers that she gives will 15 • . I'm sorry? 16 violate one or two of those privileges. She's not 16 A. Yes, I do. 17 going to answer any more questions on this topic. 17 Q. Has — has she called you or you called her 18 BY MR. CRITTON: 18 in the month or so that you have not seen her? 19 Q. With regard to have you seen, other than 19 A. Yes. 20 whatever — whatever time ou s t with Ms. el 20 Q. Did she call you, or did you call her? 21 Dr. and your visits with have you 21 A. She called me. 22 seen any other psychiatrists, psychologists, licensed 22 Q. Did she say, why haven't you come in? 23 mental health counselor, physician, medical health 23 A. She was reminding me of an appointment that 24 provider, relating to any damages that you are claiming 24 we had. 25 in this case? 25 Q. All right. And you said what? Page 406 Page 408 1 A. No. 1 A. That I would come. 2 Q. Have you sustained — have you incurred any 2 Q. But you haven't been back yet; correct? 3 medical bills, psychiatric bills, psychological bills, 3 A. The appointment has not come up yet. 4 any type of bills associated with damages that you are 4 Q. When is the next appointment? 5 claiming in this case against Mr. Epstein as of today's 5 A. I — ideal know the exact date. It's 6 date? 6 October something. 7 A. No. 7 Q. Other than Mr. A, B and C who you 8 Q. Has anybody told you that you will incur any 8 identified, have you had a sexual relationship or any 9 medical bills or expenses in the future as a result of sexual activity with any other person, male or female?. 10 any claims that you have made against Mr. Epstein? 10 A. Yes. 11 MR. EDWARDS: Objection. Attorney/client 11 Q. Who else have you had sexual activity with? 12 PriYilege. 12 MR. EDWARDS: She's not going to identify 13 BY MR. CRITTON: 13 People- 14 Q. Other than Mr. Edwards. not interested 14 BY MR. CRITION: 15 in what he told you. I'm interested, but I'm not 15 Q. First let's — it's when -- when else did you 16 entitled to know. 16 have any type of sexual activity, either wait° or 17 A. I don't know. Like who? 17 a female, other than Mr. A, B and C and 18 Q. I don't knew. Has —has anybody told you. 18 A. [guess in between the time that I had a 19 has — has said — has Doctor or 19 relationship one — with one person, to the time that I 20 Miss — Ms told you is that — well, Si 20 had a relationship with another person. 21 strike that. Let me ask it.this way: Has Ms. 21 Q. Okay. Well, your lawyers kept me to Mr. A, B 22 told.you that she thinks you're doing better, that 22 and C, so who do we fit in here? Where do we fit this 23 you're improving? . 23 other person into? B and C, C and 24 A. I don't Icnow. 24 • post pre You need to help'me 25 Q. Do you feel like the sessions with 25 with the date; then I can ask an intelligent question. 38 (Pages 405 to 908) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333.772.1562) Electronically signed by Pamela Sullivan (501-333-772-1552) 92ef5b62.38a5-4202-a350-6633a5c6813b EFTA00750811 P Page 411 A. Yes, before =. 1 BY MR. CRITTON: 2 Q. So it would have been after the stalker, 2 Q. Did you ever spend the night with him? 3 Mr. C? 3 A. No. A. Yes. 4 Q. Did he spend the night with you? 5 Q. And before 5 A. No. 6 A. Yes. 6 Q. Did you just meet and have sex? 7 Q. Okay. You didn't mention him earlier. You 7 A. We met and spoke to each other fora period 8 told me earlier today that you had had no sexual 8 of time before we had sex. 9 activity or the next sexual activity that you had 9 Q. Where did you meet him? 10 after Mr. C was . That wasn't true; was it? 10 A. I met him in my neighborhood. 11 A. That was the next relationship that I had. 11 Q. And let me just ask you: What's his name? 12 Q. I wasn't asking about — talking about 12 MR. EDWARDS: She's not going to give it. 13 sexual activity. I don't care about -- k's not that I 13 MR. CRITTON: You're instructing -- your 14 don't care. 14 objection is? 15 When's the next sexual activity? Was it 15 MR. EDWARDS: My objection is based on the 16 after Mr. C? 16 privacy rights of this individual answering the 17 A. Yes. 17 questions, as well as third-party individuals. 18 Q. Okay. And who was that with? we call him 18 BY MR. CRITTON: 19 Mr. D? Was Raman cowman? 19 Q. Over what period of time, then, did you have 20 A. It was a man. 20 sexual relations with him? Four or five months? 21 Q. And Mr. D was short-term, long-term, 21 A. It was during the entire time that I worked 22 one-night stand, multiple? 22 at 23 A. I — I never had a relationship with him, but . 23 Q. Which was about eight months? 24 I was seeing him for some time. 24 A. Yes. 25 Q. How long a time period? 25 Q. All right. So over a period of about once a Page 410 Page 412 A. Probably the whole time I waked a 1 week you would meet and you would have sexual relations. 2 a 2 Are we talking about intercourse? 3 What did he do fora living? 3 A. Not every time. 4 A. I don't know. 4 Q. Okay. Well, that's why I asked. So, but 5 Q. Did you meet him at a? 5 many of the times you would have sexual activity. 6 A. No. Intercourse? 7 Q. Did you meet him through a/ 7 A. Some of the times, yes. 8 A. No. 8 Q. Did you also have oral? 9 Q. What did he do the guy — you said you 9. A. No. 10 don't know what he did for a living? 10 Q. Strictly sexual intercourse? 11 A. No. 11 A. Yes. 12 Q. So saw him the whole time you were 12. Q. Okay. Anyone else that you've had sexual - 13 working at which was eight months, and 13 any sexual activity with, other than Mr. A, B, C, D and 14 you never know what kind of work he did? 14 15 A. No. 15 A. No. 16 Q. You never knew what kind of work he did? 16 Q. Nobody else? 17 A. No. 17 MR. EDWARDS: Object to the form. 18 Q. Are you — are you serious? 18 BY MIL CRITTON: 19 A. I only saw him maybe once a week. 19 Q. Male a female, is that correct? 20 Q. Okay. So you saw him once a week for eight 20 A. Yes. 21 months. All right. And you're telling the members of 21 Q. Have you ever had sex with a female? 22 the — the ladies and gentlemen of the jury that you 22 A. No. 23' have no idea what this man did for a living? 23 Q. Did Mr. D ever provide you money at any time? 24 MR. EDWARDS: Object to the form. 24 A. No. 25 THE WITNESS: Yes. 25 Q. Did he ever provide you any kind of like kind 39 (Pages 409 to 412) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC.' (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772.1852) Electronically signed by Pamela Sullivan (501.333.772.1552) 9205b62-313a5-4202-a350-4.633a5c6813b EFTA00750812 Page 413 Page 415 1 compensation? And by that, he's made -- you know, 1 Q. What else happened that they impounded the 2 probably bought you — probably ate out and had dinner 2 car? 3 or something. But separate from that, did he buy you 3 A. My brother was driving the car, and — 4 clothes, did he buy you perfume, did he buy you anything 4 Q. In the commission of a crime? 5 or give you anything? 5 A. I do not know. 6 MR EDWARDS: Form. 6 Q. Okay. Why did they — why would they impound 7 ITIE WITNESS: No. 7 the car, if your brother was just driving the car? Does 8 BY MR. CRITTON: 8 he have a license? 9 Q. Are you currently involved in any type of 9 A. No. 10 civil or criminal proceedings, other than this 10 Q. He doesn't have a license, either? 11 proceeding with Mr. Epstein? 11 A. No. He was being questioned by a police 12 A. What does that mean? 12 officer, and he ran. 13 Q. I'm sorry? 13 Q. He fled in the mu'? 14 A. What does that mean? 14 A. No, he ran on foot. And the car was 15 Q. Are you under any type of house arrest at the 15 impounded because he left it wherever it was, at the 16 current time? 16 store or something. 17 A. No. 17 Q. Okay. So it wasn't impounded because you 3 18 Q. Okay. Are there any criminal proceedings 18 were driving without a license, and it wasn't impounded 19 that are outstanding directed to you, anything from a 19 because you were driving the wrong way on a one -- on a 20 traffic ticket up? Have you been arrested for any other 20 street; right? 21 circumstance that's pending at the current time? 21 A. Yes. 22 A. Yes. 22 Q. It was because of". 23 Q. What? 23 A. Yes. 24 A. Traffic ticket. 24 Q. Okay. Any other criminal or misdemeanor or 25 Q. All right For what? What did you do? 25 traffic type events in your life at the current time? Page 414 Page 416 A. Driving without a license. 1 A. No. 2 Q. And whose car were you driving? 2 Q. Okay. Have you ever been under house arrest? 3 A. 3 A. No. 4 Q. This is the — did she authorize you to take 4 Q. Any other civil proceedings that are pending 5 the vehicle, or is this another time that you stole the 5 at the =rent time? 6 car from her? 6 A. No. 7 A. No. She gave me the car because she bought a 7 Q. Any proceedings with the Department of 8 new car, and I was supposed to get my license. 8 Children and Family Services? 9 Q. And do you still have the car? 9 Na Lo A. No. 10 Q. You and planning to get married? Any 11 Q. What happened to the car? 11 plans, or just living together? 12 A. It was impounded. 12 A. We have talked about it. 13 Q. All right. Did you get into an accident? 13 Q. Okay. I'm sorry? 14 A. No. 14 A. We have talked about it. 15 Q. How did you get caught? 15 Q. Well, you've been going together since when, 16 A. I was driving the wrong way. 16 '07? 17 Q. On a street? 17 A. Yes. 18 A. Uh-huh. 18 Q. Okay. And it's now '09. and you have a child 19 Q. Yes? 19 together, so have you just been talking about it for 20 A. Yes. 20 those two years? 21 Q. Okay. Is — is it — I've gotten reasonably 21 A. About the past year we have. 22 good advice that they don't impound a car for driving 22 Q. Does he provide any support at the current 23 without a license. So why did they impound the car in 23 time for the child? 24 this instance? 24 A. Not right now. 25 A. They did not impound it on that instance. 25 Q. And who's providing support for you and your 40 (Pages 413 to 416) (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) 92d6b82-380542024360-6633a50813b EFTA00750813 Page 417 Page 419 1 family at the current time? 1 I'm on the record. 2 A. 'MIMI helps us. 2 COURT REPORTER: Okay. 3 Q. How much does she help you with a month? 3 MR. CRITTON: Did you not get any of that? 4 A. Before now she didn't need to help us, but 4 COURT REPORTER: I have it just... 5 since= (phonetic) has lost his job in the last 5 VIDEOGRAPHER: You'll be able to get it 6 three weeks, she's helped us. 6 later. 7 MR. CRITTON: I'm going to adjourn for today 7 MR. EDWARDS: I -- I remember what he said. 8 because of the time. It's about a quarter to 6:00. 8 Don't worry about it. 9 And I can tell you this, that — 'have not gone 9 UNIDENTIFIED SPEAKER; He said, on the 10 into all of the different events at Mr. Epstein's 10 record. He said, on the record, so 1 flamed -- 11 home, because she was there some 20 times. So 11 COURT REPORTER: Ill check the video. 12 those are areas that I intend to go into. I think 12 MR. CRITTON: All right. 13 I can probably complete the deposition in another 13 UNIDENTIFIED SPEAKER: Clear — clearly, the 14 hour and a half to three hours, max. 14 Court Reporter's tired. 15 And there are some other areas that I — you 15 COURT REPORTER: Well -- well, I said 16 know, if 1 could — and we've been going pretty 16 something to you about l was starting okay. 17 steadily, at a pretty good clip. So if I could 17 This is — 18 take some time, I — and can think about my 18 UNIDENTIFIED SPEAKER: All right. 19 thoughts, I'll try to make it even faster than that 19 COURT REPORTER: We're back on, and III — 20 at the next session. 20 UNIDENTIFIED SPEAKER: But you got it? 21 MR EDWARDS: Well, Tm not going to agree to 21 COURT REPORTER: And I got it. * CHECK ALL. 22 it. We're going to have to have some discussion 22 MR. CRITTON: All right. So we spent eight 23 with the Court as to whether or not this deposition 23 hours with chap, who was there for eight months 24 is going to be completed on another date. I 24 and — with — with the various lawyers in that. 25 provided her here at 9:30. I had her here for the 25 So this is a young lady who claims that she was at Page 418 Page 420 seven hours, and I think that ru be able to 1 Mr. Epstein's house 20 times — well, I'll get to 2 demonstrate to the Court that many of the questions 2 that later, so let me get to where I'm going, and 3 were redundant, asked and answered over and over 3 4 and over again. And we're here, ready to complete 4 MR. EDWARDS: Sounds like a good idea. 5 the deposition. If you want to (hush it, we'll 5 MR. CRITTON: Thank you. 6 finish it. If you think that you will prevail at 6 BY MR. CRT-ETON: 7 that hearing and you're going to come back another 7 Q. Ms. Jane Doe, what did you do, if anything — 8 time, that's up to you. 8 and I don't want to know what conversations you had with 9 MR. CRITTON: All right. Well, let's take a 9 your lawyer -- to prepare for this deposition today, if 10 break for a few minutes, and m decide what I 10 anything? 11 want to do. 11 MR. EDWARDS: Object to the form. 12 MR. EDWARDS: Okay. 12 Attorney/client. 13 VIDEDDRAPHER: Off the record at 5:48. 13 MR. CRITTON: No, I don't want to know what 14 (Discussion held off the record.) 14 your discussions were. I want to know what -- what 15 MR. CRITTON: I'll put on the record, when 15 did you — 16 I've finished my 15 minutes of the additional areas 16 MR. EDWARDS: Maybe I missed your question. 17 that I would like to cover with her. And we can go 17 BY MR. CRITTON: 18 to the Court on those particular issues. 18 Q. What did you do to prepare for this 19 MR. EDWARDS: Alined. 19 deposition, if anything, other than converse with your 20 MR. CRITTON: And, you know we spent seven 20 attorney? 21 hours — almost eight hours with — fm saying 21 A. I went to bed early. I don't know. 22 in a 22 Q. Did you make any notes? 23 deposition in Federal Court. And Mr. 23 A. I read through the questions that I answered. 24 worked for Mr. Epstein for a period of six to eight 24 Q. The interrogatories? 25 months. This is a -- 25 A. Yes. 41 (Pages 417 to 420) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1562) Electronically signed by Pamela Sullivan (601-333-772-1552) tbsOMM4ho54202.05NNIXMOIM3b EFTA00750814 Page 421 Page 423 1 Q. Excuse me. Did you review any notes that you 1 BY MR. CRITTON: 2 bad made about any ofyour experiences at Mr. Epstein's 2 Q. And did you say it after you read them? 3 home? 3 A. Yes. A. No, I've never made any notes. 4 Q. And who did you say whatever you said to 5 Q. Have you ever written out — well, let me 5 about some of the answers being incorrect, who did you 6 gram that 6 say that to? 7 Did you review a copy of your complaint? 7 MR. EDWARDS: Objection. Attorney/client 9 A. No. 8 privilege — 9 Q. Okay. Have you ever seen your complaint? 9 MR. CRITTON: Okay. 10 A. Yes. 10 MR. EDWARDS: — as to who within my firm 11 Q. And do you know what you're asking for in the 11 she's talking about, now that you're already 12 way of damages in your complaint? 12 discussing the substance about — of the 13 A. Not exactly. 13 conversation. 34 Q. Okay. Your complaint says you want 14 BY MR. CRITTON: 15 S50 million. What's the basis for that claim? 15 Q. Well, you said that you realized some of the 16 MR. EDWARDS: Object to the form. 16 answers were wrong, so you called somebody. And I don't 17 THE WITNESS: Pretty much just to hurt 17 want to know what happened or what erartly you said, but 18 Jeffrey Epstein. 18 you spoke to someone at Mr. Edwards' rum; is that 19 BY MR. CRITTON: 19 correct? 20 Q. Okay. Not to compensate yourself, but just 20 A. Yes. 21 to hurt Jeffrey Epstein; is that correct? 21 Q. And that was a number ofmonths ago; true? 22 A. Pretty much. 22 A. I'm not I'm not sure when it was. 23 Q. When you said you realized some of your 23 Q. If you — you testified — 24 answers to the interrogatories were incorrect, when did 24 A. It was — it was at least a month ago. 25 you discover that? 25 Q. Let me show you what I'll mark as Exhibit Page 422 Page 424 1 A. I'm not exactly sure. 1 Number 7, Composite Exhibit 7. 2 Q. Wash yesterday? Was it today? Was it a 2 (Defendants Composite Exhibit No. 7 was 3 month ago? Was it six months ago? 3 matted for identification.) 4 A. 1probably noticed whenever I first got the 4 MR. CRITTON: Here's an extra copy, Brad. 5 copy ofit 5 BY MR. CRITTON: 6 Q. Which was what, shortly after it was signed 6 Q Have you seen a copy of the letter which is 7 on January 23rd of '09? 7 dated March 10, 2009, that I sent to Mr. Edwards before 8 A. I'm not sure if I have a copy of it, but I 8 today? 9 know that I looked over it, and we talked about it 9 A. I don't know. 10 having some wrong answers. 10 Q. I'm sorry? 11 Q. And that was months ago? 11 A. I don't know. 12 A. Not exactly sure how long ago it was. 12 Q. Well, the letter was sent in March of 2009. 13 Q. Well, it wasn't yesterday; was it? 13 Are you saying that you, now having read the letter, it 14 A. We did look at it yesterday and talk about 14 doesn't — you don't recall whether you saw that? 15 it, but... 15 A. No. 16 Q. But you realized the — some of the answers 16 Q. No, you don't recall one way or the other? 17 were incorrect when you got it sometime in January or 17 A. No, I do not recall. 18 early February of this year, when you got a copy of it; 18 Q. Okay. Turn — flip the page. There was a 19 is that correct? 19 document — the letter is and just so the record is 20 MR. EDWARDS: Object to the form. 20 clear I'm enclosing a proposal for settlement in 21 BY MR. CRITTON: 21 order to resolve the action which has been filed by your 22 Q. A copy ofExhibit 6? 22 client. And then attached — and that's paraphrasing — 23 MR. EDWARDS: Form. 23 attached to the letter is a proposal of settlement, sent 24 THE WITNESS: I know that 1 — I did say 24 by Mr. Epstein to you, in the amount of $45,000, plus 25 something about some of the answers. 25 $5,000 for attorney's fees. 42 (Pages 421 to 424) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333.772-1552) 92ef5b62-3835-4202-a350-6633a5c6813b Electronically signed by Pamela Sullivan (501-333-772.1552) EFTA00750815 Page 425 Page 427 1 Were you aware sometime in March of '09 that 1 the Court's order said that we could, if 2 you were offered $45,000 to resolve the case? 2 appropriate, go longer than seven hours. There are 3 A. Yes. 3 a number of additional areas that I want to cover 4 Q. Okay. And did you understand that — that 4 with your client, including some background 5 if, in fact, Mr. Epstein comes back and gets an award of 5 information that was not disclosed in her answers 6 a sum something less than $45,000, say $30,000, or 6 to interrogatories that I've not yet gotten to. 7 you're not successful in getting a judgment in excess of 7 I'd like to go into the other visits that she 8 35 — 30,000, $32,000, that you'll be responsible — or 8 had with Mr. Epstein, that is who she saw, what 9 you may be responsible for all of Mr. Epstein's 9 occurred, both by her and with Mr. Epstein, and 10 attorneys fees and coats that were incurred after the 10 anyone else who may have been present at the time. 11 proposal for settlement? 11 1 want to review the various counts of the 12 MR. EDWARDS: Form. 12 complaint with her, separate and apart from the 13 BY MR. CRITTON: 13 allegations of the various visits. 14 Q. That is that Mr. Epstein can get a judgment 14 There's some other background — family 15 against you, maybe hundreds of thousands of dollars, are 15 background information I want to cover with her, 16 you aware of that fact? 16 and I want to cover with her any other areas of 17 A. No. 17 which she may have knowledge regarding witnesses. 18 Q. Okay. And do you know that that will be 18 including with regard to either issues, 19 against you for your entire life until you pay that off? 19 issue, or potentially other indiviarrla s who are 20 MR. EDWARDS: Form. 20 Plaintiffs in this case. 21 THE WrrNESS: No. 21 There are some other additional, as I said, 22 MR. HILL: How is that reasonably calculated 22 family background that I wish to explore, as well 23 to lead to admissible evidence? 23 as the medical records, which I have not yet had an 24 BY MR. CRITTON: 24 opportunity to dist,KS with her, which we obtained, 25 Q. Ms. Jane Doe, we've talked about the first 25 and her school records. Page 426 Page 428 1 time you went to Mr. Epstein's house and, I believe, the 1 My best estimate for the time for completing 2 second time you went to Mr. Epstein's house; correct? 2 her deposition is approximately two and half to 3 MR. EDWARDS: Form- 3 three hours. If I can do it in a more reasonable 4 THE WITNESS: Yes. 4 or a quicker fashion, twill certainly do that. 5 BY MR. CRITFON: 5 And as I advised you, Brad, I am going out of 6 Q. Okay. And you've testified that you went to 6 town on Friday. I'm in the process of moving my 7 Mr. Epstein's house another approximately 18 times; is 7 house. It's supposed to occur on Monday or Tuesday 8 that correct? 8 of next week. We — it is now, as I said, 9 A. Yes. 9 6 o'clock. We started about a little before 10 Q. All right. And we have not discussed any of 10 10 o'clock today. I think that the request is not 11 those events, at least as of this point today; have we? 11 unreasonable, and I will also have opportunity to 12 MR. EDWARDS: Form. 12 have reviewed the transcript, so that I'm not — 13 THE WITNESS: I {mow that I have told you 13 that I don't ask duplicative questions or retread 14 that every time I ever went to his house, he 14 some area that we've already covered that I think 15 touched me, and I gave him a massage. 15 has been PI opt, ly covered. 16 BY MR. CRITTON: 16 As I indicated earlier is we spent almost 17 Q. Okay. But we talked about that generally; we 17 eight hours with a person named who was 18 haven't gone into each detail as to when the event 18 a house manager for Mr. Epstein or approximately 19 occurred or what occurred at each of those massages; 1.9 six months, who was, I'd say, a small-time player. 20 have we — other than what you generally have told me; 20 And this is a young lady who is seeking 21 correct? 21 extensive damages, whose — damages in excess of 22 MR. EDWARDS: Form. 22 $50 million for both compensatory and punitive 23 THE WITNESS: Cornea 23 damages. And I think we have a right to fully 24 MR. CRITTON: Pm going to adjourn the 24 explore. It's certainly not the intent to harass, 25 deposition now. It is about five after 6:00, and 25 intimidate or to cause her any undue stress. I'll 43 (Pages 425 to 428) (561) 832-7SOC PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772.1562) Electronically signed by Pamela Sullivan (501333-772.1552) 92ef5b62-38a5.4202-a350-6633a5e6813b EFTA00750816 Page 429 Page 431 1 be glad to work out a time that works for both you 1 CERTIFICATE OF OATH 2 and Ms. Jane Doe. 2 THE STATE OF FLORIDA 3 MR. EDWARDS: Just so that it is clear, we 3 COUNTY OF PALM BEACH 4 4 we will not be in agreement to your proposal. I 5 5 wrote down the various areas you intend to go into. 6 1, the undersigned authority, certify that 6 Every single one of them was covered. I will be 7 JANE DOE personally appeared before me and was duly 7 able to point to those areas in the transcript when 8 sworn. 8 we have a hearing on this matter. 9 9 As you pointed out earlier, Mr. Critton, the 10 Dated this 13th day of October, 2009. 10 seven-hour time limit was relieved by way of the 11 11 consolidation order, and it was done in the context 12 13 12 of depositions that are going to require multiple 14 13 attorneys — because there are so many attorneys 14 involved in this ultimate litigation — multiple 15 Pamela J. Sullivan, RPR, 15 attorneys to ask questions of a particular witness Notary Public - State of Flon 16 whose deposition to exceed seven hours, 16 My Commission Expires: June 10, 2010 17 such as Mr. la who was asked questions by My Commission No.: DD 560380 18 all seven or eight attorneys. This witness is 17 19 being asked questions by one attorney. That was 18 20 19 not the intent of the Court's order, and I think 20 21 that Judge Marra is going to have to rude on that 21' 22 issue again. Every single one of the issues that 22 23 you intend to go into was covered. 23 24 And To like to also put on the lewtd that 24 25 in your last 15 minutes you proceeded to go into 25 Page 430 Page 432 1 proposals for settlement, which you know are not 1. CERTIFICATE 2 THESTATEOF FLORIDA 2 admissible, nor reasonably calculated to lead to 3 COUNlY OF PALM BEACH 3 admissible evidence, and you did that at your own 4 5 I, Pamela J. Sullivan, Reclaimed Prolessienal 4 peril. And so, if we are going to resume any Cant Reporter and Nola, Public in and for the State of 5 deposition of Jane Doe, then it will be by way of 6 Florida at lint, do hereby certify that I was 6 authorized to and did report said deposition in court order. stenotype, and that the foregoing pages are a true and 7 MR. CRITTON: We're done. end 6:09 p.m. correct transcription of my shorthand notes of said 8 (Whereupon, the Deposition was suspended at 8 deposition 9 I further certify that said deposition ins taken at 9 6:09 p.m.) the time and place hereinabove set forth and tint the 10 10 taking of said deposition was commenced and completed as hereinabove set out 11 11 12 IBM:her certify that I am not attorney or counsel 12 limy of the parties, nor am I a relative or employee 13 of any attorney or counsel of party connected with the 14 13 action, nor am I financially interested in the action 15 14 The foregoing certification of this transcript does net apply to any reproduction of the same by any means 16 15 Sass tinder the direct control and/or direction of the 17 mthlYinemparter 16 18 Dated this 13th day of October, 2009. 19 17 10 20 19 21 20 22 21 Parnelal. Sttaivmt, RPR. FFE.CLR 23 22 24 23 24 25 25 44 (Pages 429 to 432) (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) 92.15b62-38a5-4202-a350-6633a5c6813b EFTA00750817 Page 433 Page 435 1 0da* 13.2009 ERRATA SHEET 2 SAM GCE CloSSAD1 EDWARDS. MUM 2 IN RE: JANE DOE V. JEFFREY EPSTEIN 3 RAMS. P4004144 Alit 3 Qt: PASHA J. SULLIVAN, RPR, FPR, CLR Las Olt Cry COOT. Sint. 1650 4 401 East La Nis Boulevar4 4 DEPOSITION OF: JANE DOE Rol Laudaido.R.13301 5 DATE TAKEN: September 30, 2009 S N R@ St1MT STYLE 6 DO NOT WRITE ON TRANSCRIPT- ENTER CHANGES HERE CASS NO. 0549.10)194.4ARRNICHNSON 7 PACE. LINE /I CHANGE REASON Nit 1b. as Dot Thom St Reeks Om n Wednesday. M SM of 10. 2000 ,A.0 give Otwiaktein ot-n-04.09441 9 mar. Al Out 60.9. nOlblireApatult le tent Welty OS fbi 'v., 'ow depomwo 20 As peowaly npac.1 la, the tittrualid ...id to (imbed 299,9 thr..2h 3%.,2 comod or coral it Phietlff ?Uwe mei the etelceettti wina.cni 4495.219. 10 12 Az teed of the isten.:O21 yo: *tit rod in 4nsra Aro Mr, re4.2”. 10 drpRAKI1k <llama 11 23 at ccneceocceth.v. Ku 902 mole eltc915 29 noicd the esu thio. 02.4/ {egg lad Ike runty of 994 12 14 <bawl IXJ NOT .rsoe envautplemlf Once 13 )90 d910.4 elnielipt dad NS Sly du./46CI. 25 W To lip vol (beide mot that 401 re900 title 14 rumeoln IS 16 r SwacItC4 mad aid apt the *MOUS ideal I 16 09.9,9444 tee 0•4 04O11 ewe hit limey tire. 17 199.94.9.4 a Or wilovis own,.soy by filed 902 17 00 (Mk ells Can If x.t wisb a weivt pat :0 OP010,14 ,1 Wtlit Oak* is *0 Mod enhe baron or 18 Ow kw ad menu tom 19 Hesse forward the original signed CROW sheet to this 29 Vtly MAY )00m, office so that copies may be distribute:dwell parties. 20 1 Panda &Arn Rit.FM.Clit Under penalty of perjum I declare Om I hat read my Z2 non Can Awning Army, be. 21 deposition and that it is true and correct subject to Os Curdle Coat :3 230 Mum, Woe 1920 any changes in form cc substance emceed hens. %i Pt enettaon& 33401 22 511.132/100 I Oolenterfalnwalplea 23 DATE: 24 IE D HIE DOE 25 SIGNATURE OF DEPONENT' Page 434 1 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby artily that I have read the foregoing 6 deposition by me given, and that the statements 7 contained herein are hue end correct to the best of my 8 knowledge and belief, with the exception of any 9 corrections or notations made on the errata sheet, if 10 one was executed. 11 12 Dated this day of , 2009. 13 14 15 16 17 JANE DOE 18 19 20 21 22 23 24 25 45 (Pages 433 to 435) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 92ef5b62-38a5-4202-a350-6633a6c6S13b EFTA00750818