EFTA01075988

Page 158 Page 160 APPEARANCES: 1 PROCEEDINGS 2 On behalf of the Plaintiff.: 2 3 SPENCER KUM, ESQUIRE -- LEOPOLD KUVIN, P.A 3 (Continued from Volume I.) 2925 POA Boulevard, Suite 200 Palm Florida 33410 4 VIDEOGRAPHER: We're back on the video record. Phone 5 This is the beginning of tape number three. The t 7 71ILMIrMane On behalf Does 24: 6 time is 3:02 p.m ADAM HORMEL, ESQUIRE MRMELSTEIN & HOROWITZ, PA BY MR. KUVTN: 18205 Biscayne Boulevard Suite 2218 8 Q. Okay. Let me do it this way, so we can just 9 Miami 9 back up a little bit. Phone: 10 Ms. you're aware that girls, including 10 1.1 On behalf ofPlaintiff Carolyn Andnono 11 my client, have sued Jeffrey Epstein in civil lawsuits, 12 TACK Hal, ESQUIRE 12 correct? SEARCY, DENNEY. SCAROIA, BARNHART & SHIPLEY, PA 13 2139 Palm Beach Lakes Boulevard 13 A. Yes. West ride 33409 14 Q. All right. Arc you also aware that one of the 14 Phone;till 15 RICHARD/MATS, ESQUIRE (via telephone) 15 defenses has been that these girls volunteered to go to RICHARD H. WILLITS, P.A. 16 the house so, therefore, what are they complaining 16 229010th Avenue North, Suite 404 Lake WS3461 17 about? Are you aware of that? 17 Phone 18 A. Yes, I am. 18 On behalf o the Defendant 19 ROBERT CRITTON, ESQUIRE 19 Q. Okay. You feel that way yourself? BURMAN, CRITTON, LIMIER & COLEMAN 20 A. Absolutely. 20 515 Nonh Wet Drive Suite 400 21 Q. Because you volunteered to go, right? 21 West Ptrida 33401 22 A. Absolutely. Phone: 22 23 Q. And you haven't sued Mr. Epstein, have you? 23 24 A. I have no intentions of that. 24 25 25 Q. Did you contemplate it at one point? Page 159 Page 161 1 On behalf of the Witness: 1 A. Did I contemplate it? Yeah, it crossed my 2 DOUGLAS MCINTOSH, ESQUIRE 2 mind a few times. CAMILLE E. BLANTON, ESQUIRE 3 WilYi 3 MCINTOSH, SAWRAN, PELTZ & CARTAYA, PA. 4 A. Nee. use 1 just thought it was the easy way 1601 Forum Place 4 Suite 1110 S out. And then 1 decided this is my life andl have to West Pal Fonda 33401 6 take responsibility for my own actions because 1 did 5 Phone: 7 volunteer. So I'm handling my grief and my situation a 6 8 different way, and that's by putting this shit behind ALSO PRESENT: 9 me. B 10 Q. Got you. Fair enough. MICHAEL DOWNEY, VIDEOORAPHER 9 11 What I'm wondering then — and the reason 1 10 12 asked the question initially was not to embarrass or 11 13 harass you. But since even yourself, you think to a 12 14 certain extent that these girls bear their own 13 15 responsibility for going? 14 16 A. They don't bear any responsibility. They need 15 17 to take responsibility. 16 17 18 Q. Got you. Did your dad tell you that? 18 19 A. No. I've learned that. 19 20 Q. What was his response to you about what 20 21 happened then? That's why I asked the question 21 22 initially. 22 23 MS. BLANTON: We are not going to discuss her 23 24 24 father and mother and relatives or any other 25 25 friends' reactions to these lawsuits or what she's j 2 (Pages 158 to 161) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddcH-69oe-4e 57-9cd8 -8392056001GO EFTA01075988 Page 162 Page 164 1 been through. Again, she's not a Plaintiff. She's 1 A. Yes. 2 not a Defendant. We're not going to do it. 2 Q. As you sit here today, do you think that the 3 The only purpose that serves is to upset her 3 money that he's paid you and the fact that be's paying 4 and you've seen that. 4 for your lawyers when your parents couldn't afford it 5 MR. KUVIN: I certainly don't mean to upset 5 anymore affects your testimony in any way? 6 her, but obviously I'm rep cbenting certain 6 A. Absolutely not. That's ridiculous. 7 individuals who are being — prosecuting their 7 Q. Okay. Fair enough. Fair enough. 8 action. And I think that the questions are 8 Do you think it was right for Mr. Epstein, 9 relevant But if you're not going to let her 9 personally, to have underage girls, girls under the age 10 11 answer, then we'll move on. BY MR. KUVIN: 10 11 of 16 come to his house and give him naked massages? You think that was okay? I 12 Q. As you sit here today, did anyone blame you, 12 MR. CRITTON: Form. 13 other than yourself for what happened? 13 THE WITNESS: I don't know. 14 MR. CRITTON: Form. 14 MS. BLANTON: Object to form. Define okay. 15 THE WITNESS: Yes. 15 BY MR. KUVIN: 16 BY MR. KUVIN: 16 Q. Well, personally. I mean, do you think there 17 Q. Who? 17 was anything wrong with that, personally? 18 A. A lot of people. 18 MR. CRITTON: Form. 19 Q. Who? Who can we talk to that blamed you, 19 THE WITNESS: I don't know. 20 other than your own personal feelings? 20 BY MR. KUVIN: 21 A. My sister. 21 Q. You have no opinion about that? 22 Q. Okay. Who else? 22 MS. BLANTON: She's answered that twice. 23 A. Ifs the only person that I care about that 23 MR. CRITTON: Form. Argumentative, if that 24 blamed me. 24 was a question. 25 Q. Well, anyone that didn't — that you don't 25 BY MR. KUVIN: Page 163 Page 165 1 care about? 1 Q. You got no opinion about that? 2 A. I think a lot of the other Plaintiffs blame 2 A. I have no opinion about that. 3 me. 3 Q. Okay. Do you remember the address of 4 Q. Okay. Do you feel any personal msponsibility 4 Mr. Epstein's home? S for any — bringing any of those girls to the house? 5 A. No, I do not. 6 MR. CRITTON: Form. Asked and answered. 6 Q. Does the name Brillo Way sound familiar to 7 THE WITNESS: Can you repeat the question? 7 you? 8 BY MR. KUVIN: 8 A. Brillo Way sounds familiar. 9 Q. Yeah. You said just now that you think some 9 Q. Did you ever take a shower in Mr. Epstein's 10 of the other girls that you brought blame you? 10 shower? 11 A. Ub-hub. 11 A. No. 12 Q. Correct? 12 Q. When you were at Mr. Epstein's house, did the 13 A. Yes. 13 chef ever prepare you guys lunch as you were them? 14 Q. Do you — 14 MR. CRITTON: Form. 15 A. Do I blame myself? 15 THE WITNESS: I don't remember. 16 Q. Yeah, for bringing them. 16 BY MR. KUVIN: 17 A. Absolutely not. 17 Q. Any one of the girls that you brought to the 18 Q. Not at all? 18 home, did any of those girls ultimately go to. 19 A. No. 19 University, as far as you know? 20 Q. If Mr. Epstein were not paying for your 20 A. Yes. 21 lawyers, think you'd feel the same way? 21 Q. Who? 22 A. I would feel this way, no matter what. 22 A. Jane Doe 4. 23 Q. If Mr. Epstein hadn't paid you in excess of 23 Q. And I apologize, but is she the one that you 24 53,000 over the years, do you think you'd feel the same 24 had heard had sex with Mr. Epstein? 25 way? 25 MR. CRITTON: Form. 3 (Pages 162 to 165) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401= Electronically signed by Sandra Townsend (401 7a82dddt-59ee.4e57-9cd8.8392056001c0 • EFTA01075989 Page 166 Page 168 1 MS. BLANTON: rm sorry. Did you -- 1 Q. So all of the girls that you brought actually 2 BY MR. KUVIN: 2 recruited other girls as well? 3 Q. There was one of the girls that you had heard 3 A. Yes. 4 had sex with them? 4 MR. CRITTON: Pont 5 A. That was and I heard that from Jane Doe 5 BY MR. KUVIN: 6 101. 6 Q. Okay. How do you know that? 7 Q. Okay. Sony. 7 A. I know that because they told me. 8 What did Jane Doe 4 do with him, if you know? Q. Okay. Which one of them? 9 A. I don't. 9 A. Jane Doe 7 brought,. Jane Doe 4 brought 10 Q. Did you ever tell anyone that you worked for 10 Jane Doe 3 brought a couple girls, can't recall 11 Jeffrey? 11 their names.', I think, may have broughten somebody, 12 A. Did I tell anyone I worked for k 12 but I can't be accurate on that. And I don't know for 13 Q. Yes. 13 I think Jane Doe 7. may have also brought 14 15 A. Yes. Q. Who? 14 15 Wtuti but 16 A. The girls. 16 Q and., the sisters. 17 Q. What did you mean by that when you said you 17 Q. So now we're talking about around 12 girls 18 worked for Jeffrey? 18 that you brought. And then as far as you know, a lot of 19 A. Worked for Jeffrey, like, got girls to give 19 those, if not all of them, brought other girls, at least 20 him massages. When I was introduced to a girl, I would 20 one or two other girls? 21 be, like, yeah, I work forJeffrey. I find girls to 21 MR. CRITTON: Form. 22 give him massages. 22 BY MR. KUVIN: 23 Q. Okay. You weren't on any kind of a payroll or 23 Q. Is that — did I understand you correctly? 24 anything, right? 24 A. Yes, you do. 25 A. No. 25 Q. So as you sit here today, how many girls are Page 167 Page 169 1 Q. Did you ever bring a girl over with the 1 you aware of that were brought to Mr. Epstein's home? 2 initials •? - 2 A. That I'm aware of? 3 A. Pm sorry. What were the initials? 3 Q. Well, yeah, either that you brought or that 4 Q. M. 4 you know other people brought. I mean, you've already 5 A. No, not that I can remember. Not that I can 5 talked to us about 12. Then where there's -- if they 6 recall, no. 6 each brought them, then we're talking 12 more, plus some 7 Q. Do you know a girl by the name of 7 of them may have brought additional ones. You know, 8 A. No. 8 simple math, were in the twenties now. How many are 9 Q. Doesn't sound familiar to you? 9 you aware of let me strike the statement. 10 A. M.? 10 How many people are you aware of, either 11 Q. Yes. 11 directly or indirectly, girls that were brought to 12 A. Does not sound familiar at all. 12 Mr. Epstein's home? 13 Q. How about'"? 13 MR. CRITTON: Form. 14 14 THE WITNESS: At least 20. 15 Q. Does the name sound familiar to you at all? 15 BY MR. KUVIN: 16 I. as a girl that went over to Mr. Epstein's home at 16 Q. At least? 17 some point? 17 A. At least 20. 18 A. rye heard that name come up a few times. 18 Q. Could it be at least 30? 19 Q. Do you remember bringing a'. over to the 19 A. I don't know. 20 house? 20 MR. CR1TTON: Form. 21 A. I never brought a over to the house. 21 THE WITNESS: I don't want to speculate. 22 Q. Of any of the girls that you brought, do you 22 BY MR. KUVIN: 23 know if any of those girls then did similar to you in 23 Q. But through either firsthand knowledge, in 24 getting other girls? 24 addition to secondhand knowledge from the girls 25 A. All of them. 25 themselves, you're aware of at least 20? 4 (Pages 166 to 169) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddl-59ee-4e57-9cd8-1339205600fc0 EFTA01075990 Page 170 Page 172 1 A. At least. 1 whatever, at word got around campus. And 2 Q. Okay. And of those girls, other than the one 2 then girls that 1 were bringing were like, yeah, I know 3 girl that we've talked about before that was 24 years 3 so and so and she did that, like, ninth grade. But it's 4 old, as you sit here today, all those girls were under 4 hearsay. 5 age 18; is that correct? 5 Q. I understand. M., how much older than you 6 MR. CRITTON: Form. 6 was she? 7 THE WITNESS: That I know ot yes. 7 A. My age. 8 BY MR. KUVIN: 8 Q. She was your age? 9 Q. And the on one ou're aware of that was over 9 A. She's my age now. 10 that age of 18 was 10 Q. Well then, she would have been your age then? 11 A. At 23, yes. 11 A. Yeah. 12 Q. Did Jane Doe 101 ever tell you how she first 12 Q. Right? 13 heard about Mr. Epstein? 13 A. Yeah. 14 A. No, she did not. 14 Q. Okay. Unless she's got a time machine that we 15 Q. What I'm hying to understand is, at some 15 don't know about. 16 point it seemed like, according toyour testimon that 16 A. She might. 17 there were a number of girls from High 17 Q. You had heard that she went in ninth grade? 18 School that were going over to Mr. Epstein's home during 18 A. That is what I heard. 19 this period of time in 2005, early 2006. 19 Q. Who did you hear that from? 20 What I'm trying to figure out is, if you know, 20 A. Multiple people. 21 how did Mr. Epstein or his people get entree into your 21 Q. Are you aware, other than her, of anyone else 22 high school initial) in other words, who was the first 22 that went over to Jeffrey's house before you that was 23 person at High School, if you know, 23 going to 24 that started this whole thing? 24 A. Yes. 25 MR. CRITTON: Form. 25 Q. Who else? Page 171 Page 173 1 THE WITNESS: I have no idea. I do not !mow. 1 A. 2 It wasn't me. 2 Q. When did she go? 3 BY MR. KUVIN: 3 A. I don't know if she ever worked for him or 4 Q. Right. Because Jane Doe 101 got you? 4 gave him a massage, but she was — she's been to his 5 A. Jane Doe 101 got me, that's correct. 5 house. 6 Q. And I'm sorry. I know I asked this before. 6 7 But Jane Doe 101, she was a classmate of yours at 7 8 El? 8 A. iO or (phonetics), I 9 A. No. I went to with her. 9 think. 10 Q. Okay. 10 Q. Okay. Who else? 11 A. Her, We weren't friends, didn't hang out. 11 A. On top of my head, that's all 1 can think of. 12 Just saw each other through the hallways. 12 Q. Do you know how to spell 13 Q. Well, that's interesting then. 13 A. 14 wathe Ar first girl, that you're aware of, 14 Q. 15 from High School that went to Mr. Epstein's 15 A. 16 home? 16 Q. And 17 MR. CRTTTON: Font 17 A. I. 18 THE WITNESS: No. 18 Q. And Flow do you II= 19 BY MR. KUVIN: 19 A. 20 Q. Who was the first girl that you were aware of 20 Q. Other than anyone else 21. from = that went there? 21 Brom that you're aware of that went over 22 A. 22 there? 23 Q. And how did you become aware of her going? 23 .A. 24 A. When I started going and I started bringing 24 Q. 25 girls that I was friends with, acquaintances with, 25 5 (Pages 170 to 173) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddl•59e*Ao57-9cd8439205600fc0 EFTA01075991 Page 174 Page 176 1 1 M. was just - I don't even know what 2 A. 2 category I can put her under. 3 Q. Who else? 3 Jane Doe 3 was definitely promiscuous. 4 A. That's it, that I can think of on the top of 4 I don't really have a category to put M. 5 my head that went before I even heard about him. 5 under. She was just kind of the younger one, the not so 6 Q. Were you all at school talking about going 6 bright one. 7 over to this old guys house on the beach? Q. Got you. When you would ask girls to go, 8 MR. CRITTON: Form. would you look for the ones you thought were more BY MR. KUVIN: promiscuous? 10 Q. I mean, were there any conversations that were 10 MR. CRITTON: Form. 11 had around the hallways at school about this issue? 11 THE WITNESS: No. No. 12 MR. CRITTON: Font 12 BY MR. KHVIN: 13 THE WITNESS: I had no idea that they had even 13 Q. How would you decide which ones to ask? 14 gone until after I met Epstein and was already done 14 A. They were my friends, the girls that I vent to 15 with my situation. 15 school with, the ones that I kicked it with after 16 BY MR. KUVIN: 16 school. They were in my circle. It was convenient. 17 Q. Right. 17 Q. Okay. Call me naive, but how do you convince 18 A. So this is information that I've learned in 18 a girl that age to go to an old man's house, even just 19 the last three years — 19 to give a massage? 20 Q. Okay. 20 MS. BLANTON: Object to the form. Go ahead. 21 A. -- that I hadn't known before. 21 I think you were handling the answer just fine. 22 The girls and the friends that I hung around 22 MR.. CRTITON: Form. 23 with, they would all talk about it in the hallways 23 BY MR. KUVIN: 24 because they knew that I was taking them or that they 24 Q. Go ahead. 25 met him through me. 25 A. That's the thing. I didn't have to convince Page 175 Page 17 Q. Right. 1 than. 2 A. But if you mean communication through 2 Q. What do you mean? 3 different cliques in the hallway, as, like, an issue, 3 A. I didn't convince anything. I proposed to 4 no, nobody ever spoke about it. 4 them. They took it. They volunteered. 5 Q. Okay. All the girls that you took, what was 5 Q. Okay. 6 their, I guess for lack a better term, social status 6 A. Sometimes the girls would come up to me and 7 within the school? I mean, were they popular girls? 7 ask me if they can work for him this weekend. There was Were they not popular girls? Were there, you know,1 8 no convincing needed. 9 mean, in sane schools there are, like, the cheerleaders 9 Q. Right. So you would just mention it and — 10 and the different groups? 10 A. They jumped on it, just like I did. 11 A. Should I be brutally honest? 11 Q. Then why did it bother you when you did it the 12 MR. HOROWITZ: I'm going to object to the form 12 first time? 13 then. 13 A. It bothered me more so because I just — I 14 BY MR. KUVIN: 14 can't explain it to you. It didn't bother me then as it 15 Q. Yes. Brutally honest. 15 bothered me now. It bothers me now for different 16 A. Do you want to include myself in this? 16 reasons. 17 Q. Let's k1 46ou out of it for the moment. 17 Q. Well, do you think you were any less sensitive 18 was the party animal. 18 than these girls? 19 20 A.a cheerleaders. and and, I believe,.. were the 19 20 A. I am definitely less sensitive than those girls. 21 Q. Okay. 21 Q. You see yourself as being more sensitive than 22 A. Jane Doe 7 and Jane Doe 4 were the promiscuous 22 them? 23 ones. 23 A. At times, yes. At other times, no. Pm a 24 was - not promiscuous, but 24 very hard person. Everybody's sensitive when they want 25 more flirtatious. 25 to be. You strike somewhere where it hurts, you're 4.4.5.-M14:41A.Vtaattor.? 6 (Pages 174 to 177) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7082dddf-59ce-4e57-9cd8-8392056001c0 EFTA01075992 Page 178 Page 180 1 going to be sensitive. You're going to &IL 1 BY MR. HOROWITZ: 2 Q. And this whole issue with Epstein obviously is 2 Q. Hi. Good afternoon. My name is Adam 3 a sensitive point with you? 3 Horowitz, as I mentioned when we started today. 4 A. It is. 4 A. Okay. 5 Q. Did like the fact that went over 5 Q. I represent seven of the Plaintiffs. Pm 6 them, if you know? 6 going to be asking you some questions, sort of filling 7 A. I don't know. 7 in some blanks in my mind based on the previous 8 Q. Did you ever hear that he was upset about you 8 questions and also some particular questions about my 9 bringing..? 9 clients. Okay? 10 A. We did have a falling out. 10 Sort of at the beginning of the deposition you 11 Q. After you brought'.? 11 told us that Jute Doe 101 first mentioned Jeffrey 12 A. After I brought When he found out that I 12 Bpstein's tune to you at the Beach Resort; is 13 Ness going to bring her, yeah, he distanced himself from 13 that right? 14 her and me. 14 A. That is correct. 15 Q. Do you know why? 15 Q. Before that time, you had never heard ofhim; 16 A. No. 16 is that right? 17 Q. Did you hear that he actually punched a wall 17 A. That's right. I had never heard of him 18 he was so upset? 18 before. 19 MR. CRITTON: Form. 19 Q. But you know now that certain 20 BY MR. KUVIN: 20 classmates of yours wore already going to his house? 21 Q. Did someone tell you that? 21 A. That's correct. 22 A. No. 22 Q. Did Jane Doe 101 ever tell you that she, 23 Q. Have you talked to him since? 23 herself, had gotten paid for giving Mr. Epstein a 24 A. We're not as close. 24 massage or was she simply a recruiter for him? 25 Q. Have you talked to him at all since? 25 A. We news discussed that Page 179 Page 181 1 A. Yes. 1 MR. CRITTON: Form. 2 Q. Did you talk to him about this incident? 2 BY MR. HOROWITZ: 3 A. No. Ifs not a conversation that me and him 3 Q. Do you — as we sit here today, do you know of 4 have had. Ifs not a conversation that I would like to 4 anything that took place when Jane Doe 101 went to 5 have with him. 5 Jeffrey's house? 6 Q. Is that the only reason you can think of that 6 A. No. 7 you two had a falling out? 7 Q. Do you know if she ever gave him a massage? 8 A. Yes. 8 A. No, l don't 9 Q. When you were in the room with Mr. Epstein, 9 Q. Do you know if they ever had sexual contact? 10 did you actually see his genitals? 10 A. No, I do not. 11 A. I don't remember. I tried not to look. 11 Q. And you told us that Jane Doe 101 did not 12 Q. Okay. So as you sit here today, you couldn't 12 forewarn you that Jeffrey Epstein would touch you in a 13 describe them? 13 sexual manner, is that correct? 14 A. No. I could not describe them for you. 14 MR. CRITTON: Form. 15 Q. I don't mean obviously his face. I'm talking 15 THE WITNESS: That's correct. 16 about his genitals. You could not describe those? 16 BY MR. HOROWITZ: 17 A. I could not describe his genitals for you. 17 Q. Did she ever say that he would touch your 18 Q. Okay. Did you ever talk tot's parents? 18 private parts? 19 A. No. 19 A. No. He never did she never did. 20 MR. KUVIN: All right. I appreciate it. 20 Q. She never told you that? 21 That's all the questions I have at this point 21 A. Sony. 22 Other attorneys, I'm sure, are going to have some 22 Q. Did you ever tell her that, in fact, he had 23 for you. 23 touched you, as you said, below the belt in the front? 24 (Discussion held off the record.) 24 MR. CRITTON: Form. 25 CROSS EXAMINATION 25 THE WITNESS: I don't remember. I 7 (Pages 178 to 181) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dridt-Sgee-4e57-9cd8-8392056001c0 EFTA01075993 Page 182 Page 184 1 BY MR. HOROWITZ: 1 going to touch you in a sexual manner? 2 Q. You don't know if you ever told her that? 2 MR. CRITTON: Form. 3 A. I don't know if l ever told her that. 3 THE WITNESS: Yes. 4 Q. Was it upsetting to you that she didn't tell 4 BY MR. HOROWITZ: S you that that might occur? 5 Q. Now, you -- do you know if she recruited other 6 A. I don't remember. 6 girls to go to Jeffrey's house? 7 Q. Are you, as we sit here today, upset — if she 7 A. I don't know. 8 knew — strike that. 8 Q. Has she ever told you that she recruited other 9 If she knew that Jeffrey Epstein had a sexual 9 girls to go to Jeffrey's house? 10 interest in girls, would you have liked to have known 10 A. I can't remember. 11 that before you went to his house? 11 Q. Have you heard from anyone that Jane Doe 101 12 MR. CRITFON: Form. 12 recruited other girls to go to Jeffrey's house? 13 THE WITNESS: I don't know. 13 A. Nobody said anything, no. 14 BY MR. HOROWITZ: 14 Q. As we sit here today, are you aware— is it 15 Q. That might be something you didn't care about 15 your understanding that you are the only person that she 16 before you went to his house? 16 recruited or do you have some other fountain of 17 A. I don't know how to answer that. I don't 17 information? 18 know. I'm not being put in that position. 18 A. To my knowledge, I'm the only girl that she 19 Q. Well, was it upsetting to you when he touched 19 recruited. 20 you in a sexual manner and you had no idea he was going 20 Q. And when she recruited you, did she talk about 21 to do that? 21 the range of girls that Jeffrey preferred? 22 A. I don't know. I can't recall my feelings at 22 A. No. 23 that point in time. 23 Q. Did she indicate to you at any point how long 24 Q. And you don't recall whether you ever told her 24 it is that she was -- had been recruiting for Jeffrey 25 what had taken place? 25 Epstein? Page 183 Page 185 1 A. I don't know if I ever told her. 1 A. No, she did not. Q. Now, when you got done with this 2 Q. And you told us that when you recruited for 3 massage/touching encounter, you went downstairs and you 3 Jeffrey Epstein, you told the girls that you worked for I saw her on the first floor of the house? 4 Jeffrey; is that eorree.t? 5 MR. CRITTON: Form. 5 A. Yes. 6 BY MR. HOROWITZ: 6 Q. Did she make a similar pitch to you, I work 7 Q. is that right? for Jeffrey and I'd like you to come for a massage? A. I went downstairs. I don't know if she came 8 A. I can't remember. 9 up and got me or inflict her down there, but she was 9 Q. Okay. Turning your attention to the encounter 10 waiting for me with yes. 10 when you were in the massage room with Jeffrey. When 11 Q. And then you proceeded to ride home -- 11 Jeffrey Epstein reached below your belt in the front, as 12 A. Together. 12 you described it, did you push him away? 13 Q. Together? Did you tell her any of the events 13 A. I pushed his hand away. 14 that had taken place upstairs in the massage room? 14 Q. You pushed his hand away. 15 A. I can't recall. 15 Did you, like, move away as well? 16 Q. Do you think she should have told you that 16 A. I don't remember. 17 Jeffrey Epstein was going to touch you in a sexual 17 Q. Was that your -- was that your indication to 18 manna? 18 him that you were uncomfortable with what it is he was 19 A. Should she have? 19 doing? 20 MR. CRITTON: Form. 20 A. Yes. 21 THE WITNESS: I don't know. Yes. 21 Q. What I'm trying to get at is, that's why you 22 BY MR. HOROWITZ: 22 pushed him away, to indicate to him you didn't want him 23 Q. Well, which is it] don't know or yes? I'll 23 to touch you that way? 24 ask the question again so it's clear. 24 A. That's correct. 25 Should she have told you that Jeff Epstein was 25 Q. In a sexual way? Y.• 8 (Pages 182 to 185) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddd1.59o0.4057.9cd8.839205600fc0 EFTA01075994 Page 186 Page 188 A. That's correct. 1 Q. He said what? 2 Q. Did he continue masturbating after you told 2 A. He had just made a comment about her age when 3 him — after you pushed his hand away? 3 he was paying me. He just made a comment, like, you 4 MR. CRITTON: Form. 4 know, she was old. 5 THE WITNESS: Yes. 5 Q. Meaning, the previous girl -- 6 BY MR. HOROWITZ: 6 A. Yes. 7 Q. And you — did you hear him, like, breathing 7 Q. — was old? 8 heavy? 8 Did Jeffrey — now, you told us that the range 9 MR. CRITTON: Form. 9 of the other girls you brought was between ages 14 and 10 THE WITNESS: I can't remember. 10 17; is that alma 11 BY MR. HOROWITZ: 11 A. Besid that's right. 12 Q. Was he masturbating, like, with his hand on 12 Q. Did Jeffrey Epstein ever express displeasure 13 his penis? 13 with the 14 to 17 year old girls that you brought? 14 A. Yes, 14 A. !don't know. 15 MR. CRITTON: Form. 15 Q. I'm just asking, did he ever express it to 16 BY MR. HOROWITZ: 16 you? 17 Q. And had you looked that way, would his 17 A. He never expressed it to me. 18 genitals have been exposed? 18 Q. Now, when you were bringing these girls over 19 A. Yes. 19 to Jeffrey Epstein's house, did you believe that these 20 Q. And did he suddenly stop masturbating, as in, 20 girls were going ova to Epstein's house so that Epstein 21. when someone has a climax or orgasm? 21 could have sexual contact with them? 22 A. Yes. 22 A. I don't know. 23 Q. You distinctly recall that? 23 Q. Now — go ahead. 24 A. Yes. 24 A. 1don't know. I never directly stated 25 Q. At the conclusion of this encounter in the 25 anything about sexual contact Page 187 Page 189 1 massage room, you told us, I think, that Jeffrey Epstein 1 Q. I got that I'm not asking what you said. 2 asked you to bring other girls. Did I get that right? 2 But in your own mind, when you're bringing these girls 3 A. Yes. 3 over, did you think in your own mind, these girls are 4 Q. What was your response? 4 going over to Ertein's house and Epstein is going to 5 A. I told him, okay. 5 have some type of sexual contact with them, the same way 6 Q. You were comfortable with that? 6 he did with me? 7 A. Yes. 7 MR. CRITTON: Form. 8 Q. And did you tell him, I'll be in touch, or THE WITNESS: I don't know. 9 anything along those lines? 9 BY MR. HOROWITZ: 10 A. I don't tensanber. 10 Q. It didn't cross your mind that — 11 Q. But by then you already had lumber, 11 A. I don't know what crossed my mind seven years 12 telephone number? 12 ago. 13 A. At some point 1had number. I don't 13 Q. Okay. Did you believe that you were being 14 recall if it was before or after the massage. 14 paid cash to bring over girls to Epstein's house for 15 Q. Okay. All right. Now, you told us that 15 sexual pleasure? 16 on one occasion brought an older girl named is 16 A. No. 17 that right? 17 MR. CRITTON: Form. 18 A. That is right. 18 BY MR. HOROWITZ: 19 Q. Was it Jeffrey Epstein who told you she was 19 Q. What did you think the purpose of the money 20 too old? 20 that you were getting was? 21 A. Yes. 21 A. To introduce him to girls for massages. 22 Q. And did he tell you that when you arrived in 22 Q. For massages? 23 the first floor of the house or after the massage or 23 A. Yes. 24 when did that conversation take place? 24 Q. You thought that a reason that you were 25 A. The next girl I brought. 25 getting paid $200 was for an untrained high school girl 9 (Pages 186 to 1 8 9) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Tandddf-69eo4o57-9cd8-839205600fc0 EFTA01075995 Page 190 Page 192 1 to give a grown man just a massage? 1 bit wiser, in your opinion were you paid thousands of 2 A. Yes. 2 dollars for Jeffrey Epstein to get sexual pleasure from 3 Q. I'm trying to — was there a part of your 3 14 to 17 year old girls? 4 mindset that thought, I'm also going to get paid for 4 MIL CRITTON: Form. 5 giving — for bringing girls to give Epstein sexual 5 THE WITNESS: No. 6 pleasure? 6 BY Mr. HOROWITZ: A. I didn't receive any sexual pleasure, so 1 7 Q. Did Jeffrey Epstein tell you in particular, 8 can't make that analysis. 8 specifically, I want these girls ova because they're 9 Q. I'm not asking about your sexual pleasure. 9 good masseuses, that they really improve my back? 10 Pm asking about Epstein's sexual pleasure. 10 A. No, he never said that. 11 Was there a part — was there a part of your 11 Q. And to your knowledge, is there a single girl 12 mind that said, I'm getting paid hundreds of dollars to 12 that you brought over that Jeffrey Epstein did not have 13 bring young, attractive girls to Jeffrey's house so that 13 an orgasm with? 14 he can have sexual pleasure? Did that cross your mind? 14 A. Yes. 15 A. No, it did not. 15 MR. CRITTON: Form. 16 Q. As we sit here today, looking back on the 16 BY MR. HOROWITZ: 17 large sum of money that Jeffrey paid you, thousands of 17 Q. There's some girls that he did not achieve 18 dollars, would you agree that he paid you that money so 18 climax? 19 you could bring girls for his sexual pleasure? 19 A. Yes. 20 MR. CRITTON: Form. 20 MR. CRITTON: Form. 21 THE WITNESS: I don't know. No. No. 21 BY MR. HOROWITZ: 22 BY MR, HOROWITZ: 22 Q. Are there any girls that you're aware of that 23 Q. Well, in your estimation, what do you think 23 he didn't touch or try to touch in a sexual manner? 24 was the reason he paid you thousands of dollars? 24 A. No. 25 A. Fora massage, for me to introduce him to 25 MR CRITTON: Excuse me. Form to the last Page 191 Page 193 1 girls to give him a massage. 1 question. 2 Q. Through your different conversations with 2 MR. HOROWITZ: Too late. 3 Jeffrey Epstein, you've come to know that he's a very 3 BY MR. HOROWITZ: 4 affluent man. I mean, you've described him as a 4 Q. How did -- 5 billionaire. S MR. CRITTON: Then you need to slow down. 6 MR. CRITTON: Fenn. 6 MIL HOROWITZ: You need to speed up, old man. 7 THE WITNESS: Yes. 7 BY MR. HOROWITZ: 8 BY MR. HOROWITZ: 8 Q. How did you go about recruiting? 9 Q. Would you agree that if he wanted to, he could 9 MR. CARTON: Ill smile. 10 have the best masseuses in the world? 10 BY MR. HOROWITZ: 11 MR. CRITTON: Roan. 11 Q. How did you go about — how did you go about 12 THE WITNESS: Yes. 12 recruiting thegirls that were in your social circle at 13 BY MR. HOROWITZ: 13 High School? Was it always 14 Q. And yet he wanted these masseuses, in 14 face-to-face or was it ever telephone? E-mail? Text? 15 particular, from 14 to 17 year old girls; is that 15 A. Sometimes over the phone. Sometimes when I'd 16 correct? 16 run into them in the hallways at school or hang out with 17 MR. CRITTON: Form. 17 them, so face-to-face, over the phone. 18 MS. BLANTON: Objection. You're asking her to 18 Q. Would you always have these take a girl 19 speculate on what Jeffrey Epstein wanted or had in 19 that you went to high school — give me a name of 20 his mind. If you want to ask her a question about 20 somebody who you went to high school with. 21 what he told her or what she communicated with him, 21 A. Jane Doe 4. 22 that's fine. 22 Q. Okay. Jane Doe 4. When you spoke to Jane Doe 23 BY MR. HOROWITZ: 23 4 and told her for the first time about Jeffrey Epstein 24 Q. My question is: As you look back on it now, 24 and this opportunity, did you tell her - was anybody 25 having, you know, being a few years older and a little 25 else there when you told her? 10 (Pages 190 to 193) PROSE COURT REPORTING AGENCY, INC. ElectroMcally signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82deldf.59ee-4e57-9cd8-839205600fc0 EFTA01075996 Page 194 Page 196 1 A. I don't recall. 1 THE WITNESS: Yes. 2 Q Did you tell her in person, by phone or howl 2 BY MR. HOROWITZ: 3 A. I don't recall. 3 Q. What would you say? 4 Q. What about Jane Doe 7? Did you tell her — 4 A. I would just talk to them, hey, listen, you 5 was it a one-on-one type of conversation? 5 !mow, I know this guy, his name is left hes on the 6 A. I really don't recall. 6 Island, he has a lot of money, he's a billionaire, you 7 Q. What about Jane Doe 2? Was that in person 7 know, he's looking for girls to give massages. Are you Or •••• 8 interested? 9 A. Jane Doe 2. 9 And then obviously if they were interested, I 10 Q. Do you recognize that name? 10 would go into a little bit more detail, you know, 11 A. I never brought her. 11 exchange dates and times that they were available. 12 Q. Jane Doe 3? 12 Q. And ou would always clear those dates and 13 A. Jane Doe 3, I don't recall. 13 times with or somebody else? 14 Q. You don't recall whether — I didn't even ask 14 A. 15 a question. You don't recall whether it was in person 15 Q. Am I correct in is all that you told the girls 16 or by telephone, anything of that sort? 16 in regard to the services they had to render was that 17 A. I don't recall how I told her. 17 they were getting money for massages? 18 Q. But each of these girls, it was always, like, 18 A. I told them they would get $200 for a massage. 19 a private kind of one-on-one conversation or would you 19 The more you do, the more you make. 20 sort of announce it in the cafeteria or the classroom 20 Q. Well, you told us earlier that they were 21 21 getting paid for massages. 22 MR. CRITTON: Form. 22 A. They were getting paid for massages. 23 THE WITNESS: I don't think I ever announced 23 Q. And that's what you told them? 24 it in the cafeteria, but I don't know. 24 A. That is what I told them. 25 BY MR. HOROWITZ: 25 Q. Thank you. Page 195 Page 197 1 Q. Would you make an effort to have a private 1 You told us that you an understand — a moment 2 conversation about this subject? 2 ago you told us that you had an understanding that the 3 A. Depending. Depending on the girl. 3 more girls did, the more they got; is that right? 4 Q. Well, give me the, if you can, the variables. 4 A. Yes. 5 What would weigh in favor of making son of a public or 5 Q. Where did you come up with this understanding? 6 semi-public announcement about this and what would weigh 6 A. Jane Doe 101 told me that, so I just passed it 7 in favor of having a private conversation? 7 along. 8 A. Wellwith Jane Doe 4 it had to be private 8 S Was that a theme that — or a message that 9 because if her old boyfriend, found out, he 9 also told you? 10 would beat the aap out of her. So she was somebody 10 A. No. 11 that I went to privately. 11 Q. Did Jeffrey ever tell you that? 12 MR. HOROWITZ: Move to strike. 12 A. No. 13 THE WITNESS: Also, depending on what the 13 Q. Did anybody who worked or was connected with 14 girls were like, I mean, some are very jealous when 14 Jeffrey tell you that? 15 it comes to money. It depends. The other girls 15 A. No. 16 didn't like it when they weren't working and the 16 Q. So you took Jane Doe 101 at her word that the 17 other girl was. So usually I probably bad to just 17 more — the more the girls did, the more they got paid? 18 do it privately. A lot of them were very not 18 A. That's comet. 19 wanting other girls to work for him. 19 Q. And do you know if, in fact, that is a true 20 BY MR. HOROWITZ: 20 statement? 21 Q. Did you— did you have a standard sales 21 A. I don't know. 22 pitch, so to speak, in recruiting these girls, like, 22 Q. In terms of the more you get the more you 23 what you would tell each of them in order to get them to 23 do, the more you get paid, what were the — on the low 24 go to Jeffrey Epstein's house? 24 end of the scale, the less you did, the less you got 25 MR. CR1TTON: Form. 25 paid, what would be the lesser activities? 11 (Pages 194 to 197) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7.82dthif-50co.4o57-9cd8-839205600fc0 EFTA01075997 Page 198 Page 200 1 A. The lesser activities? I don't know. 1 A. Either would call me or I'd call 2 Q. Well, -- and how much would you get paid on 2 and we'd work it out to where when Jeffrey was coming 3 the lesser end? 3 home I would have a girl that would be available for 4 A. I don't know. 4 those dates and times. 5 Q. And then on the higher end, when you say the 5 Q. So you would — you would get a heads up 6 more you did, the more you got paid, what sort of things 6 before he came into Florida? 7 are we talking about? 7 A. Ulthuh. $ A. Whatever the girl allowed him to do or 8 Q. Yes? 9 whatever their situation was. I don't know. I was 9 A. Yes. 10 never in the room with them. I just took what Jane Doe 10 Q. Okay. And wouldMI give you that 11 101 said and passed it down. 11 information by telephone? 12 Q. Well, did anyone ever say, well, what does 12 A. Yes. 13 that mean, the more you do, the more you get paid? 13 Q. Would she call your home phone or cell phone? 14 A. Yes. 14 A. Cell phone. 15 Q. And how would you explain that? 15 Q. And where would she be calling you from? 16 TIE WITNESS: Didn't we already discuss this? 16 A. I don't know. 17 The more you do, the more you make. If you 17 Q. Did you get the sense that she lived with 18 were topless, if you were working in your thong, 18 Jeffrey? 19 your bra, you're going to make more than a hundred, 19 MR. CRITTON: Form. 20 as to somebody who is always complaining about 20 THE WITNESS: Yes. 21. money and never takes offher shirt 21 BY MR. HOROWITZ: 22 BY MR. HOROWITZ: 22 Q. Would she ca/I you horn his home? 23 Q. So a hundred is the low end? 23 A. I don't remember. 24 A. You could say that 24 Q. You told us or you told Mr. Kuvin that you 25 Q. What's the high end? If you really did a lot 25 told the girls to say that they were 18 years old? Page 199 Page 201 1 ofstuff with Jeffrey, what would you — how much money 1 A. Yes. 2 could you make? 2 Q. Can you specifically recall telling that to 3 MR. CRITTON: Form. 3 every we of the girls that you recruited? 4 THE WITNESS: I heard about 300. 4 A. Yes. 3 BY MR. HOROWITZ: 5 Q. And why would you tell them that? G Q. Three hundred. And what sod of sexual 6 A. Jane Doe 101 told me to tell him that. 7 contact or nudity would you have to do to get that kind 7 Q. So you just — 3 ofmoney? 8 A. Jane Doe 10I told me. I passed it down. MR. CRITTON: Form. 9 Q. Now, were you physically present when all of 10 THE WITNESS: I don't know. I wasn't in the 10 the girls went for their encounters with Jeffrey 11 room. 11 Epstein; meaning, were you upstairs in the massage room 12 BY MR. HOROWITZ: 12 for any of them? 13 Q. And you just don't know from hearing it from 13 A. No. 14 other people? 14 Q. So would it be — do you know if any of the 15 A. 1 don't know. 15 girls, in fact, told Jeffrey Epstein, I'm 18? 16 !t How would you know the — you told us that 16 A. No. 17 I= was always the person who gave you the dates and 17 Q. Do you have — I'm trying to work through this 18 times for appointments. How would she communicate that 18 because we're getting late in the day. 19 to you? 19 Did you get the same payout for each of the 20 A. Can you repeat the question? 20 girls that you brought? 21 Q. Yeah. If you were to recruit a girl and she 21 A. What do you mean? 22 was interested and you said you would tell her potential 22 Q. For a -- name a particular girl. 23 dates and time and things like that. How would you have 23 A. Jane Doe 4. 24 that knowledge? How would you know available dates and 24 Q. Would you get paid $200 for every girl that 25 times? 25 you brought? 12 (Pages 198 to 201) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-59ce-4eS7.9cd8-839205600(c0 EFTA01075998 Page 202 Page 204 1 A. Yes. 1 need a restroom break. 2 Q. Were that any girls that you got paid less 2 MR. HOROWITZ: That's fine. I'm not holding 3 for? 3 anyone captive. 4 A. No. 4 VIDEOGRAPHER: Going off the record, 3:45. 5 Q. Would you ever get paid more than 200 for 5 (Brief recess.) 6 bringing a girl? 6 VIDEOGRAPHER: We're back on the video record. 7 A. No. 7 The time is 3:57. 8 Q. Was your payout based on what Epstein did with 8 BY MR. HOROWITZ: 9 the girls or what the girls did with Epstein? 9 Q. Have you ever been to Jeffrey Epstein's house 10 A. No. 10 when you were not there to give a massage or to bring a 11 Q. It was just for sort of brokering the deal, 11 girl who was there to give a massage? 12 getting them in the same place at the same time? 12 A. No. 13 MR. CIUTTON: Form. 13 Q. So every time that were you ever somewhere 14 TILE WITNESS: Yes. 14 other than Jeffrey Epstein's house With Jeffrey Epstein? 15 BY MR. HOROWITZ: 15 A. No. 16 Q. Ii; for instance, a girl you recruited, just 16 Q. So all of your contact, personal contact with 17 an example, say, Jane Doe 7. If she came ten times, 17 him was at his house; is that right? 18 would you get paid ten times or how did that work? 18 A. Yes. 19 A. If I — sometimes I would get paid 5200 for 19 Q. And it was always in the course of bringing — 20 every girl. Other times, for instance, if I was to 20 either going with Jane Doe 101 or bringing one or more 21 bring Jane Doe 7 more than once, I might be able to 21 girls? 22 sneak in and get paid more than once. But usually it 22 A. Yes. 23 was Just 200 for every girl. 23 Q. Have you ever travelled with Jeffrey Epstein? 24 Q. But there were sometimes in some — in the 24 A. No. 25 case of some girls that you got paid more than once for 25 Q. Have you ever travelled with someone who Page 203 Page 205 1 that same girl? 1 worked for him? 2 A. Yes. 2 A. No. Q. Now, if one of the girls who you recruited in 3 Q. Have you ever been in a favorer's office with turn recruited another girl, would you get paid as well? 4 Jeffrey Epstein? ▪ A. I'm cut out of that deal. 5 A. No. • Q. You're cut out of the deal? 6 Q. Have you ever been in a vehicle owned or A. Uh-huh. 7 controlled by Jeffrey Epstein? a Q. Did you ever talk to Jeffrey or about 8 A. No. 9 whether you should be included in that deal? 9 Q. Have you ever been invited to travel with 10 A. No. 10 Jeffrey Epstein? 11 Q. Were you always paid in cash? 11 A. No. 12 A. Yes. 12 Q. Did Jeffrey Epstein talk to you about 13 Q. And who gave you the money, like, physically 13 properties that he owned? 14 handed you the money? 14 A. No. 15 A. Epstein. 15 Q. Did he ever talk to you about businesses that 16 Q. While you were upstairs or while you were 16 he owned? 17 downstairs? 17 A. No. 18 A. I don't remember. 18 Q. Did he ever talk to you about how he 19 Q. And would it would you get paid in front of 19 accumulated his wealth? 20 the girls you had brought? 20 A. Yes. 21 A. No. 21 Q. What sort of things would he tell you? 22 Q. You would — and would they get paid in front 22 A. He told me he was a scientist. 23 of you? 23 Q. You're laughing. 24 A. Not that I can remember, no. 24 A. He did. 25 MS. BLANTON: If you're at a good point, I 25 Q. You know he's not a scientist? 13 (Pages 202 to 205) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-59ite-4e57-9cd8-8392056001c0 EFTA01075999 Page 206 Page 208 1 MR. CRITTON: Form. 1 A. I don't even remember. 2 THE WITNESS: Obviously I know that now. 2 Q. I'm going to ask the question again because 3 BY MR. HOROWITZ: 3 there was — I'm not sure there was an objection, just 4 Q. You lmow he's a child molester? 4 kind of an interruption, exactly. 5 MR. CRITTON: Form. Argumentative. 5 Other than a statement that you made in the 6 BY MR. HOROWITZ: 6 police car regarding MM, what else did you 7 Q. Right? 7 discuss with the police when you were in the police air? A. No, I do not know that. 8 MR. CRITTON: Let me just object to the form 9 BY MR. HOROWITZ: 9 because she just said she couldn't talk about MI 10 Q. You know he touches underage girls for sexual 10 11 pleasure? 11 MR. HOROWITZ: Are you instructing her? I'm 12 A. I don't blow that. 12 saying, other than. 13 Q. You know he touched at least one girl for 13 MR. CRITTON: Yeah, but you're tryingSa rick 14 sexual pleasure, right? 14 her into suggesting that maybe she did say 15 16 MR. CRITTON: Form. 15 16 M . So you've got to be careful with your questioning. I think that was inappropriate. BY MR. HOROWITZ: 17 Q. Yes? 17 THE WITNESS: I don't even remember the ride. 18 A. I don't ;mow that. 18 MR. HOROWITZ: If it was inappropriate -- 19 Q. Do you know if he — well, you've told us he 19 MR. CRITTON: I don't think it was 20 touched you for sexual pleasure, correct? 20 intentional. I don't think it was intentional. 21 A. Tried. 21 Maybe you're too young to understand. 22 MB. CRITTON: Form. 22 BY MR. HOROWITZ: 23 BY MR. HOROWITZ: 23 Q. Eliminate — 24 Q. !mean — but he did touch you. You told the 24 MR. HOROWITZ: That's true. 25 police that'? 25 BY MR. HOROWITZ: Page 207 Page 209 1 A. Yes. 1. Q. Exclude any conversation or non-conversation 2 Q. And you know he masturbated while looldng at 2 that you had regarding-. Put that out of 3 you while you were l6 or I7 years old? 3 your mind, if it at all ever occurred. 4 A. Yes. 4 Tell me about what else you discussed with the 5 Q. You were asked some questions by Mr. Kuvin 5 police In the police car. 6 about your travel in the police car. Do you recall 6 A. I don't remember. 7 those questions? 7 Q. Did you tell the police that Jeffity Epstein 8 A. Yes, Id°. 8 admitted to you that he was a serial pedophile? 9 Q. Where were you going to? Where were you 9 MR. BLANTON: She just testified that she does 10 coming from and where were you going to? 10 not — 11 A. They picked me up at my house, took me down to 11 MR. HOROWITZ: I'm hying to — there's an art 12 the station and then they brought me home to my house. 12 of questioning where you try and refresh people's 13 Q. So you're going — this conversation that 13 recollection. You go with the general and then you 14 you've been talking about was in the — 14 narrow it to the specific. 15 A. In the police car. 15 BY MR. HOROWITZ: 16 Q. Going from the police station downtown to your 16 ' Q. And, so, my question for you is: Did you tell 17 home; is that right? 17 the police that Jeffrey Epstein admitted to you that he 18 A. That is right. 18 was a serial pedophile? 19 Q. Okay. Other than an statement made in the 19 A. No, he never admitted.that. That is absurd. 20 police car regarding which your attorney 20 Q. Did you tell — did you tell the police that 21 has already told you not to answer, what else did you 21 Jeffrey Epstein was a pedophile who paid you to bring 22 discuss with the police? 22 girls for his sexual gratification? 23 MR. BLANTON: I'm sorry. When? 23 MR. CRITTON: Form. 24 BY MR. HOROWITZ: 24 THE WITNESS: No, I did not tell the police 25 Q. When you were in the vehicle. 25 that [told him he was a serial pedophile that paid e.V.I•movaVa.mi-wnwv 14 (Pages 206 to 209) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddt-59ee-4e57-9cd8-839205600fc0 EFTA01076000 Page 210 Page 212 me for sexual acts or brought anybody or for sexual 1 4 that Jeffrey Epstein said that she was one of his 2 acts. 2 favorites? 3 BY MR. HOROWITZ: 3 A. I don't terember. 4 Q. Did you tell the police that Jeffrey Epstein 4 Q. Was she — do you know — strike that. 5 had paid you thousands of dollars to bring 14 to 17 year 5 How many times did you go to Jeffrey Epstein's 6 old girls to his home so he could masturbate? 6 house with Jane Doe 4? MR. CRM'ON: Form. A. I don't recall. DIE WITNESS: I don't recall that. 8 Q. Was it more than once? 9 BY MR. HOROWITZ: 9 A. Possibly. I don't recall. 10 Q. Did you tell the police that Jeffrey Epstein 10 Q. Was it at least once? 11 admitted sexually abusing Jane Doe 7? 11 A. At least once. 12 A. No, he didn't admit to sexually abusing Jane 12 Q. And you're not sure if it was more than once 13 Doe 7. 13 then? 14 Q. Did you ever have a conversation with him 14 A. I'm not sure if it was more than once. 15 about what took place with Jane Doe 7? 15 Q. Do you have a specific recollection about what 16 A. No. 16 took place on the one occasion that you do recall? 17 Q. Did you ever have a conversation with Jeffrey 17 A. No. 18 Epstein about what took place between him and Jane Doe 18 Q. Do you know whether you drove in a vehicle 19 4? 19 with her to Jeffrey Epstein's house on that occasion? 20 A. Yes. 20 A. I do remember an occasion me and Jane Doe 4 21 Q. Did you ever have a conversation with Jeffrey 21 being in a car driving and pulling up to Epstein's house 22 Epstein as to what took place between him and Jane Doe 22 in her mom's Buick. 23 3? 23 Q. In her mom's Buick. And who was driving? 24 A. No. 24 A. I don't remember. 25 Q. Tell me everything that Jeffrey Epstein told 25 Q. And were you an older, younger or in the same Page 211 Page 213 1 you about what he and Jane Doe 4 talked about or did 1 grade as Jane Doe 4? 2 together. 2 A. I was in a grade above her. 3 A. All he said was that she was like day and 3 Q. Was she younger than you? 4 night She had this wild side to her and he had, like, 4 A. That's right. 5 a nickname of, like, or some ridiculous thing 5 Q. What grade was she in when you pulled up to 6 like that. It's the only thing we discussed when it 6 Jeffrey Epstein's house with her? 7 came to Jane Doe 4. 7 A. I don't recall. a Q. You also told us that she was one of his 8 Q. Do you know if it was when she was in the 9 favorites, correct? 9 ninth grade? 10 A. Yes. 10 A. No, I do not 11 Q. And another one of his favorites wasl.; is 11 Q. Do you know if it was when she was in the 12 that right? 12 tenth grade? 13 A. Yes. 13 A. N0,11 do not 14 Q. And thinking about the two of them when they 14 Q. Do you know if it was when she was in the 11th 15 were 16, 17 years old, did they share any common 15 grade? 16 physical characteristics? 16 A. No, I do not 17 A. No. 17 Q. And what took place after you and Jane Doe 4 18 Q. Do they resemble each other physically? 18 arrived at Jeffrey Epstein's house? 19 A. No. 19 A. I don't remember. 20 Q. Nothing at all? 20 Q. Do you have a recollection of seeing her of 21 A. No. 21 her getting paid? 22 Q. Did you ever ask Jeffrey Epstein what he meant 22 A. No. 23 when he said that Jane Doe 4 was one of his favorites? 23 Q. Do you have a recollection of you getting 24 A. No. 24 paid? 25 Q. Did you ever ask — did you ever tell Jane Doe 25 A. No. 15 (Pages 210 to 213) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Ta82ddd1-59ee4e57-9cd8.8392056001c0 EFTA01076001 Page 214 Page 216 1 Q. Were you paid? 1 a vehicle together? 2 A. I don't remember. 2 A. Yes. 3 Q. Do you know how long the two ofyou stayed at 3 Q. And had you scheduled this withM? 4 his house? 4 A. Yes. 5 A. No. 5 Q. By telephone? 6 Q. Do you know if anybody else was home or in 6 A. Yes. 7 Jeffrey Epstein's house when the two of you went? 7 Q. And who drove? 8 A. I don't recall. 8 A. I don't remember. 9 Q. Anything stand out or, you know, that you can 9 Q. AM when you arrived, what took place? 10 recall, other than what you've told us about the day 10 A. I don't recall. 11 that you and Jane Doe 4 went to Jeffrey Epstein's house? 11 Q. Do you recall how long you were there? 12 A. It was cold out. We went out afterwards. 12 A. No. 13 Q. Anything else? 13 Q. Do you recall getting paid for bringing Jane 14 A. (Nods head.) 14 Doe 7? 15 Q. Did no? 15 A. Yes. 16 A. No. 16 Q. Do you recall her getting paid? 17 Q. Did she tell you at any point what took place 17 A. I don't remember. 18 on that particular day? 18 Q. Do you recall anything you told her about what 19 A. No. 19 you thought might take place? 20 Q. Did you ask her? 20 A. No, I don't remember. 21 A. Yes. 21 Q. Do you recall if she told you what it is that, 22 Q. And what did she say? 22 in fad, did take place between her and Jeffrey Epstein? 23 A. I don't recall. 23 A. I don't remember. 24 Q. Was it a weekday or weekend? 24 Q. Do you recall her going upstairs to the 25 A. I don't know. 25 massage room? Page 215 Page 217 1 Q. Given that you were in high school when you 1 A. I don't remember. 2 were recruiting these girls, was it fair to say you 2 Q. Did you set up the massage table that day? 3 would always go after school or on the weekends when you 3 A. Don't remember. 4 went to Jeffrey Epstein's house? 4 Q. Did you wait downstairs while she was giving a 5 A. It would be fair to say that it was either 5 massage? 6 after school or on the weekends. 6 A. I don't remember. 7 Q. Would you ever miss school or go during school 7 Q. Anything you do remember about the time you 8 to Jeffrey Epstein's house? 8 spent at Jeffrey Epstein's house with Jane Doe 7? 9 A. No. 9 A. No,1don't remember. 10 Q. Did -- was Jeffrey Epstein familiar with your 10 Q. And you can't recall if it was more than once? 11 school schedule, such that he could schedule 11 A. I can't recall. 12 appointments after your school day ended? 12 Q. Are you aware whether or not she went more 13 A. No. 13 than once to his house? 14 Q. Well, how is it — how did it come to be that 14 A. She did go more than once. 15 you would never get scheduled to come in during the 15 Q. You know that because she told you or some 16 school day? 16 other way? 17 MR. CRITION: Form. 17 A. Because she told me. 18 THE WITNESS: I don't know. It was usually 18 MR. CRITTON: We're on Jane Doe 7 now? 19 the weekends. 19 MR. HOROWITZ: Yes. 20 BY MR. HOROWITZ: 20 BY MR. HOROWITZ: 21 Q. How many times did you take Jane Doe 7 to 21 Q. And briefly just going back to Jane Doe 4, are 22 Jeffrey Epstein's house? 22 you aware whether or not she went more than once? 23 A. I know for sure once, but I can't be positive 23 A. She definitely went more than once. 24 anything else after. 24 Q. And how do you know that? From her, Jeffrey 25 Q. Tell me how — did the two of you ride over in 25 or some other place? 16 (Pages 214 to 217) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401M Electronically signed by Sandra Townsend (401 7a82dddt-69ee-4e57-9cd8-8392056001c0 EFTA01076002 Page 218 Page 220 1 A. Her, Jeffrey. Jane Doe 7 told me. THE WITNESS: I mean, there was — the house 2 also told me a couple times. 2 was -- there was always people in the house, 3 Q. And in the case of Jane Doe 4, would you have 3 regardless if it was models, a chef, a chauffeur, 4 been paid your $200 introductory fee once or more than 4 butler, whatever. There was always somebody in the 5 once? 5 house. 6 A. I don't remember. 6 BY MR. HOROWITZ: 7 Q. And what about with Jane Doe 7? 7 Q. And do you recall ever talking to them? 8 A. I don't remember. 8 A. I'm sure I did. 9 Q. And next we're on to Jane Doe 3. Do you know 9 Q. Did anything — do you remember any of the 10 how many times you were there at Jeffrey Epstein's house 10 conversations you had or the subjects you talked about? 11 when she was also there? 11 A. No. 12 A. I took her once. Anything after that I don't 12 Q. Did they ever feed you at that house? 13 remember. 13 A. I've eaten there, yes. 14 Q. Go ahead. 14 Q. Was it a meal you made yourself or someone 15 A. I went once to take her for a massage and then 15 made it for you? 16 me and her brought another girl named'. So that's 16 A. No. 17 twice I know that she worked with him, once that me and 17 Q. Who made it for you? 18 her went together to take a girl. Other than that, I 18 A. The chef. 19 don't know if she went back, how many times or who she 19 Q. Did you ever lay out at the pool? 20 brought. 20 A. Not in a bathing suit. A girl upstairs was 21 Q. The day when you brought this other girl named 21 giving a massage and I was laying out by the pool in my 22 I. — is that her name? 22 clothes, just waiting for her to come downstairs. I 23 A. Yes. 23 wasn't doing it to get sun. 24 Q. Was that a mutual friend of you and Jane Doe 24 Q. Getting paid while you were lying out at the 25 3? 25 pool? Page 219 Page 221 1 A. It was more so Jane Doe 3's friend, but I had 1 A. Waiting for the girl to come downstairs, yes. 2 it to where me and her would split the profit. 2 Q. Did you ever go kind of snooping around the 3 Q. That was my next question, who got the 3 house, looking around to see the different rooms in the 4 commission? 4 house? 5 A. We split it. 5 A. No. 6 Q. IIt nsuilit it. Okay. 6 Q. Did ever show you a datebook or 7 . went -- ME go upstairs to the 7 appointment book? 8 massage room? a A. I don't remember. 9 A. Yes. 9 Q. Did she ever show you a calendar where you 10 Q. Did you and Jane Doe 3 wait downstairs? 10 could sort of fit in your appointments? 11 A. I don't recall. 11 A. No. 12 Q. Do you recall anything about what you and Jane 12 Q. Did she ever talk to you about having — 13 Doe 3 did while you were in Jeffrey Epstein's house 13 keeping a datebook -- 14 while' was giving a massage? 14 A. No. 15 A. I don't remember. 15 Q. -- or a calendar with appointments? 16 Q. Do you recall whether anyone was in the house, 16 A. A calendar, no. 17 Jeffrey Epstein's house? 17 Q. When — did Jeffrey Epstein ever take pictures 18 A. I don't recall. 18 of you? 19 Q. Thinking back on it, when you would bring 19 A. Not that I !mow of. 20 girls over to Jeffrey Epstein's house and you would wait 20 Q. When you went to his house, did you ever 21 downstairs while the girl and Jeffrey Epstein went 21 notice there was surveillance cameras? 22 upstairs, was someone at his house watching you or 22 MR. CRITTON: Form. 23 looking after you to make suit you didn't get into 23 THE WITNESS: No, I did not !mow that. 24 trouble or take anything or -- 24 BY MR. HOROWITZ: 25 MR. CRITTON: Form. 25 Q. Did -- did Jeffrey Epstein have anyone that VCAOL.4.ee'ves••••••1•4N 17 (Pages 218 to 221) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7082ddd1.59ee-4057-9cd8-839205600tc0 EFTA01076003 Page 222 Page 224 1 you might characterize as a girlfriend or a partner? 1 upstairs with one of the kids? 2 A. Somebody that I can characterize as? 2 MR. CRITTON: Form. 3 Q. Somebody that you — that you sort of looked 3 THE WITNESS: I never heard anything. 4 at and said, okay, that's his girlfriend? 4 BY MR. HOROWITZ: 5 A. 5 Q. Is Jane Doe 7 someone that you considered a Q. And what about their relationship led you to 6 friend at the time that you recruited her to go to' 1 think that they were boyfriend/girlfriend? 7 Jeffrey Epstein's house? 9 A. Just the way they were towards each other, how 8 A. Not necessarily a friend. A party buddy. 9 she always helped him out. She always set his 9 Q. Social — social acquaintance? 10 appointments. There was one time — I don't know if I 10 A. Yes. 11 was taking a girl upstairs or if it was my massage that 11 Q. Someone that you had a good time with? 12 I gave him — but she was in the shower, coming out of 12 A. Yes. 13 the shower with him. 13 Q. Is she someone that you would now go out and 14 Q. You were where? 14 have a good time with? 15 A. I don't know. I can't remember if I was 15 A. Never. 16 bringing — if I had brought a woman up there to give a 16 Q. What took place between then and now — well. 17 massage or if I had -- was there to give him my massage. 17 let me backup. 18 But either/or I do recollect her and Epstein coming out 18 Do you not -- do you not like her at this 19 of the shower together. 19 point in time? 20 Q. Okay. Appearing as if they had showered 20 A. I don't wish ill upon her. 21 together? 21 Q. My question is: Do you not like her? 22 A. That's correct. 22 A. I don't like her. 23 Q. And were they affectionate to each other? 23 Q. What took place between then and now that you 24 MR. CRITTON: Form. 24 do not like Jane Doe 7? 25 BY MR. HOROWITZ: 25 A. When and I came home Page 223 Page 225 1 Q. From your perspective did she appear to be 1 in tears sobbing, I was very emotional. It was a very jjj 2 affectionate? 2 trying day forme. I had gone into my bedroom and I w•as 3 A. I don t recall. 3 throwing things. I was very upset. 4 Q. Would they say the types of things or call 4 She came in and told me to put some clothes on 5 each other, honey, sweetheart or anything like that? 5 and to come out drinking with her and =. And I 6 A. Not that I can remember. 6 just felt at that point in my life, I hit a low point 7 Q. Were they physically affectionate, meaning, 7 and you are supposed to be my roommate, you're supposed 8 sort of touch each other in a way that a 8 to be my somewhat friend, acquaintance, we live boyfriend/girlfriend might touch their partner? 9 together, you have no heart, you show no love to me 10 A. Not that I saw. 10 after all these years and all you want me to do is go 11 Q. Did they ever kiss? 11 and get completely annihilated with you? 12 A. Not around me. 12 Q. Is that the reason you don't like her anymore? 13 Q. When Jeffrey Epstein, when you came to his 13 A. That's one of the reasons. 14 house, would he ever kiss or embrace you when you saw 14 Q. I'm trying to get a full list or if there's -- 15 him each time? 15 or however many masons there are. 16 A. No. 16 What are the other reasons you don't like Jane 17 Q. I mean, he would just say, hello? 17 Doe 7? 18 A. Yes. 18 A. She -- when me and her, we would go out and 19 Q. I hate to do this, but try and think back to 19 party sometimes, every guy I would talk to she would end 20 the day you were in his massage room and he's 20 up with at the end of the night A lot of back 21 masturbating, his hand is on his penis. Is he groaning, 21 stabbing. Her and Jane Doe 4 would go behind my back 22 making noises? 22 and talk very bad about me and say things and judge me, 23 A. I can't recall. 23 which friends don't do. That's why I classify her as a 24 Q. Did you ever hear Jeffrey Epstein groaning, 24 party buddy. 25 making noises while you were downstairs and he was 25 Q. Okay. 18 (Pages 222 to 225 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddd1.59ee•4o57.9cd8-839205600fc0 EFTA01076004 Page 226 Page 228 1 A. Other than that, I don't have a personal 1 this lawsuit berimce she's a bad -- you don't like her? 2 vendetta against her. 2 A. I don't care. I don't care either way. 3 Q. Does anything — I asked you if you don't like 3 MR. CRTITON: Form. 4 her and you said, yes. Does any of the reasons you 4 BY MR. HOROWITZ: 5 don't like her have anything to do with Jeffrey Epstein? 5 Q. You don't care either way. 6 A. Yes. 6 It would be okay with you if she gets millions 7 Q. I'm trying to get all these reasons out of 7 ofdollars for her pain and suffering? 8 you. Tell me all the reasons. 8 A. Sure. 9 A. She volunteered for this. 9 Q. What are all the reasons you don't like her? 10 Q. You don't like her for that reason? 10 A. Oh, one of the guys I was dating she was 11 A. She volunteered for this. I didn't. I've 11 sleeping with behind my back. Didn't find out until 12 paid a higher price than I feel she has. AM everybody 12 later. As well as her lies build up. When we were 13 knew what they were getting themselves into prior to 13. party buddies, like I said, her and Jane Doe 7 did a lot 14 this. 14 of scheming and scamming behind my back, a lot of lies. 15 Why am I sitting here having to explain myself 15 What else? We got into a fistfight my 16 while you party it up? 16 sophomore year of high school. 17 Q. You don't like her because she volunteered - 17 She also told me that she was not suing 18 A. Togo. 18 Jeffrey Epstein and that she thinks Jane Doe 7 is a 19 Q. to go to Jeffrey Epstein's house? 19 complete idiot and a moron and then goes behind my back 20 A. That's correct. 20 thinking that I'm dumb and Is a complete hypocrite. 21 Q. Unlike you, who — did you volunteer? 21 Q. Anything else? 22 A. I volunteered, too. 22 A. She lets men beat on her. That's why I don't 23 Q. And would it be a fair statement you don't 23 like her. 24 want her to get any money in this lawsuit; is that 24 Q. You don't like her because men beat on her and 25 right? Because you don't like her? 25 she doesn't put up a fight? Page 227 Page 229 1 A. I can't care either way. 1 A. She doesn't do anything. It's weak. 2 Q. You don't care whether she gets money? 2 Q. Any other reasons you don't like her? You've 3 A. She's out ofmy life. That's all I know. 3 given us a few. Tm trying to find all of them. 4 Q. Would it be okay with you if she gets millions 4 A. I can't think of any other reason why I 5 of dollars for the pain and suffering she endured? 5 wouldn't like her. 6 MR. CRTITON: Form. 6 Q. Who is the boyfriend that you said she was 7 THE WITNESS: That's fine. 7 with? 8 BY MR. HOROWITZ: 8 A. The guy I was dating at one point in my life, 9 Q. Jane Doe 4. Is she someone that you 9 1 was dating him, went to bed, woke up in the middle of 10 considered a friend when you recruited her to go to 10 the night and his pants were around the ankles in the 11 Jeffrey Epstein's house? 11 kitchen with Jane Doe 4. 12 A. Party buddy. 12 Q. And who is that? 13 Q. Not a friend? 13 A. 14 A. Not a friend. 14 Q. And you said you had a fistfight with her. 15 Q. Never was a friend? 15 When was that? What grade was that? 16 A. Never was a friend. 16 A. I don't recall. 17 Q. Do you like her now? 17 Q. Was it before or after you introduced her to 18 A. No. 18 Jeffrey Epstein? 19 Q. You — that's someone you really don't like? 19 A. I can't remember. 20 A. Don't like her. 20 Q. It could have been before? 21 Q. You don't like her? 21 A. Could have been before. 22 A. I don't like her. 22 Q. Did you patch up that issue, such that you 23 Q. You see her, you go the other way? 23 were able to have a conversation and tell her how to 24 A. Oh, yes. High tail it. 24 make money and make yourselfmoney? 25 Q. And you don't want her to get any money in 25 MR. cRrrron nw=====i 19 (Pages 226 to 229) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddctf-59ee-4857-9cd8-8392056001c0 EFTA01076005 Page 230 Page 232 1 THE WITNESS: We eventually patched things up. 1 A. I found out, like, two days later. 2 BY MR. HOROWITZ: 2 Q. That she what? 3 Q. And do any of the reasons that you don't like 3 A. Was a Plaintiff. 4 Jane Doe 4 have anything to do with Jeffrey Epstein, 4 Q. Do you know if at that point she had filed a 5 other than, I think you told us she denied being a 5 lawsuit? 6 Plaintiff in the lawsuit? 6 A. Yes. 7 A. Yes. 7 Q. You know that because who told you? 8 Q. What reasons are there pertaining to Jeffrey 8 A. 9 Epstein? 9 Q. And, in fact, you knew when Jane Doe 4 lied — 10 A. Same thing as Jane Doe 7. You volunteered, 10 you knew when Jane Doe 4 told you that she wasn't a 11 you knew yourself what you were getting into. You were 11 Plaintiff that she was a Plaintiff? 12 a hypocrite to my face, told me that it's stupid for 12 MR. BLANTON: She's already answered that 13 Jane Doe 7 to sue. You disagree with her decision. You 13 question. 14 go behind my back, you do it. And then what? This is 14 THE WITNESS: I already answered. 15 it? I don't — I don't care for either one of them. 15 BY MR. HOROWITZ: 16 Q. And, so, because of that, you don't think 16 Q. Isn't it true you sent her a text message 17 she's been harmed. You don't want to see her get any 17 saying, I always knew you were a Plaintiff? 18 money because she volunteered for it; is that correct? 18 A. Yes. 19 MR. CRITTON: Form. 19 Q. In fact, even when she told you she wasn't, 20 MR. BLANTON: Object to form. She's asked and 20 you knew she was, correct? 21 answered that before. 21 A. No. 22 THE WITNESS: I don't care either way. 22 MR. BLANTON: She's answered that three times. 23 BY MR. HOROWITZ: 23 BY MR. HOROWITZ: 24 Q. Is it your opinion that Jane Doe 4 should tell 24 Q. But why would you send her an e-mail saying 25 everyone that she's a Plaintiffin the lawsuit? 25 that, in fact, you knew she was? Page 231 Page 233 1 A. No. But she shouldn't deny it. 1 A. Because I wasn't going to let her have the 2 Q. She should answer truth -- she should answer 2 satisfaction of thinking she threw me for a loop, 3 to everyone that, in fact, she's a Plaintiff, if anybody 3 thinking that she had ono over me. 4 asks her? 4 Q. So she —you lied to her? 5 A. Yes. 5 A. Yes. 6 Q. Did you know the answer before you asked her? 6 Q. You lied to her so that she wouldn't think 7 A. No. 7 that she got one ova on you? 8 Q. So you believed her when she said she wasn't a 8 A. Yes. 9 Plaintiff? 9 Q. Okay. lane Doe 3. Is she someone you can -- 10 A. Yes. 10 at the time you recruited her, is she someone you 11 Q. And it upsets you that she didn't want to tell 11 considered a friend? 12 you that she was a Plaintiff? 12 A. No. 13 A. No. It upsets me that she lied to my face and 13 Q. Was she ever a — I think you called a 14 was fake to my face and told me one thing and then went 14 Icyparty— 15 behind my back and did another thing. That's scandalous 15 A. Party buddy. 16 and ifs not right. 16 Q. Party buddy? 17 Q. What's the other thing she did? 17 A. No. 18 A. She told me to my face that she wasn't a 18 Q. Do you have any feelings for her one way or 19 Plaintiff and that she disagreed. It's not the fact 19 the other today different than when you did then? 20 that she didn't want to tell me. She could have just 20 A. I have nothing bad or good to say about her. 21 said, it's not your business. But for her to lie to my 21 Q. Okay. Are you friends with anybody who you 22 face and then put down somebody else for the same thing 22 are aware ofhas filed a lawsuit against Jeffrey 23 you're doing is a little hypocritical. 23 Epstein? 24 Q. Do you know if, in fact, she was a Plaintiff 24 A. No. 25 at the time she denied being a Plaintiff? 25 MR. CRITTON: Object to the form. She may not 20 (Pages 230 to 233) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401M Electronically signed by Sandra Townsend (401 lati2dddl.Sece-4057-9cd8.819205600fc0 EFTA01076006 Page 234 Page 236 1 know. 1 MR. HOROWITZ: We may have to deal with that 2 MR. HOROWITZ: That's the way I framed the 2 one again. 3 question the way I did. I said, that you are — 3 BY MR. HOROWITZ: 4 MR. CR1TTON: Oh, okay. 4 Q. There was a girl namedEwho earned a 5 BY MR. HOROWITZ: 5 thousand dollars from Jeffrey Epstein? 6 Q. You told us that you have not caranunicated -- 6 MR. CRITION: Form. 7 have you communicated with Jeffrey Epstein since his 7 THE WITNESS: What I heard. 8 arrest? 8 BY MR. HOROWITZ: 9 A. No. 9 Q. What you heard. Who recruited her? 10 Q. And how is it that you ended up with an 10 A. 1have no idea. 11 attorney who he is paying for, if you have not 11 Q. Was she a High School student? 12 communicated? 12 A. I have no idea. I know that she went to 13 MR. BLANTON: Object to the form. Do not 13 I don't know where she went to high 14 answer that question. 14 school. She may have been a. 15 We've had this conversation. She will not be 15 Q. And from — sorry. From who did you hear that 16 dittencsing that any further. 16 she earned a thousand dollars? 17 BY MR. HOROWITZ: 17 A. Jane Doe 101. 18 Q. You recall signing an affidavit in this 18 Q. Did Jane Doe 101 claim to have recruited..? 19 lawsuit? 19 A. I'm sorry? 20 A. Yeah. To be more specific, I've signed a lot 20 Q. Did Jane Doe 101 claim to have recruited.? 21 of paperwork. 21 A. No. She never said either way. 22 Q. Do you recall signing, like, a sworn statement 22 Q. And what is — can you — 'don't think you've 23 that said — that detailed an encounter with a couple of 23 spelled her last name for us. 24 the Plaintiffs? You met one at and 24 A. I? 25 another one at another nightclub? 25 Q. Yeah. Page 235 Page 237 1 A. I remember signing an affidavit about a 1 A. I. 2 Plaintiff and me at an incident that we had at 2 Q. And is he she older, younger, or the same? 3 yes. 3 A. Same age. 4 Q. Did Mr. Epstein's attorneys ask you to sign an 4 Q. Same grade, as far as you 'mow? 5 affidavit pertaining to those facts? 5 A. Yes. 6 MR. BLANTON: Do not answer that unless you 6 Q. Yes. Okay. How many times would you estimate 7 know it somehow other than speaking to me. And I 7 that you have been to Jeffrey Epstein's home? 8 am your attorney. So if that aff -- if you had 8 A. Estimate? 9 dealings with that affidavit outside ofmy 9 Q. Or if you know specifically, you can tell me. 10 presence, you may answer. Otherwise, you are not 10 But I was trying to help you out. 11 to answer that question. 11 A. I don't know specifically. But if I'm telling 12 THE WITNESS: Okay. 12 you that I brought about a dozen girls and sometimes 13 BY MR. HOROWITZ: 13 went more than twice, I think it would be fair to say 14 Q. Did Mr. Epstein —1'm not interested in what 14 maybe two dozen times, a dozen and a half to two dozen 15 your attorneys said to you or asked you to do. Did 15 times maybe. 16 Mr. Epstein's attorneys ask you to sign an affidavit? 16 Q. Eighteen to 24 roughly? 17 A. I don't know. 17 A. Possibly. 18 Q. You just did it because it felt right? How 18 Q. That's your best estimate? 19 did it come to be that you signed this affidavit? 19 A. Best estimation. 20 MR. BLANTON: If you can answer that without 20 MR. HOROWITZ: Let's take a break and I'll try 21 disclosing the conversations that you had with your 21 to wrap it up and maybe Mr. Willits will have 22 attorney. 22 questions. 23 THE WITNESS: I can't answer that. 23 VIDEOGRAPHER: Going off the record. The time 24 MR. BLANTON: That information is privileged. 24 is 4:25 p.m. This is the end of tape number three. 25 She will not be disclosing that. 25 (Brief recess.) 21 (Pages 234 to 237) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401= Electronically signed by Sandra Townsend (401 7a82dddf-59eo-4e57.9cd8.839205600fc0 EFTA01076007 Page 238 Page 240 1 VIDEOGRAPHER: We're back on the record. The 1 Q. What was it in a general sense that you were 2 time is approximately 4:30 p.m. This is the 2 journaling, if not your emotions and feelings? 3 beginning of tape number four. 3 MS. BLANTON: Are you asking with regard to 4 BY MR. HOROWITZ: 4 Jeffrey Epstein or her in general? 5 Q. A few more questions. 5 MR. HOROWITZ: No. 6 On the occasions when you travelled with other 6 BY MR. HOROWITZ: 7 girls to see Mr. Epstein, before going to his home, did 7 Q. My question was: In a general sense, what is either you or any of the other girls use alcohol or 8 it that you were journaling or putting in a diary at 9 drugs? 9 that period of time? 10 A. I didn't. 10 A. About things that were going on in my life, 11 Q. Did any of the girls that you travelled with 11 just things that i was going through that — some didn't 12 or recruitexl to see him use alcohol or drugs before 12 even have anything to do with Epstein andM. And 13 going to his house? 13 sometimes I would just write about how I used to work 14 A. i don't know. 14 for him and whatever. But it was never anything like 15 Q. You were asked earlier whether Mr. Epstein 15 emotional about him. it was more different things in my 16 gave you money or gifts before, other than the cash he 16 life. 17 gave you for the massages and bringing girls. And you 17 Q. If we were to open the pages of the journal, 18 said, none; is that correct? 18 we would see somewhere a reference to the fact that you 19 A. That is. 19 worked or used to work for him; it would say something 20 Q. Did he pay for anyone to render any services 20 like that? 21 for you? 21 A. Possibly, yes. 22 A. No. 22 Q. Would it say something about how you felt 23 Q. Did he open any doors, whether it be 23 about working for him or having worked for him? 24 employment opportunities or other opportunities for you? 24 A. I don't know. Possibly. 25 A. No. 25 Q. What sort of things did you write about, Page 239 Page 241 1 Q. Did he make offers to assist you in any way? 1 having worked for Mr. Epstein? 2 Professionally? Educationally? 2 A. I don't know. 3 A. No. 3 Q. Would there be any reference to having worked 4 Q. Anything Ince that? 4 for him in a sense of bringing other girls to his home? 5 Did you ever ask Jeffrey Epstein for anything 5 A. Possibly. 6 other than the cash you were given for the massage and 6 (Briefinterruption.) 7 the bringing of other girls? 7 BY MR. HOROWITZ: 8 A. Sorry. No. 8 Q. Where is this journal? Do you have it at your 9 Q. Did you ever keep a diary of the events, in 9 house? 10 terms ofyour dealings with Jeffrey Epstein? 10 A. I do not have it at my house. 11 A. No. 11 Q. Who has your journal? 12 Q. Did you ever keep a journal or a log of the 12 A. The last place m journal was, was with my old 13 contacts_nLi had with the police or the State Attorney 13 roommates down in . And I left a bunch 14 or with = anything like that? 14 ofmy belongings down there, so either it's thrown away 15 A. I kept a journal for my own self about what 15 or she still has it. 16 was going on in my life, but nothing about and 16 Q. And who is "she? 17 Epstein specifically. 17 A. 18 Q. Would there be a reference to either what 18 Q. What is last name? 19 happened with Jeffrey Epstein or how you felt about it? 19 A. I do not know. 20 A. No. 20 Q. Where did i u with ' 21 Q. Would there be a reference to your emotional 21 A. Down in by the beach. 22 state or how you were feeling at or about the time that 22 Q. What street? 23 you went there or you were bringing other girls to his 23 A. I said by the beach. I don't know what 24 home? 24 street. 25 A. No. 25 Q. DidMg° to High School? 22 (Pages 238 to 241) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddt-59ee-4o57-9cd8-8392056001c0 EFTA01076008 Page 242 Page 244 1 A. No. 1. A. You she tried out. 2 Q. Where did go to high school? 2 Q. And then what happened? It didn't work out? 3 A. I don't ;mow. 3 A. She got the job, but she was only up there 4 Q. How did you know M? 4 visiting so she didn't keep it. She just wanted quick 5 A. We worked together. 5 money. 6 Q. Where did you work together? 6 Q. What was the name of that club? 7 A. We danced together. 7 A. 8 Q. Okay. And what dance club was that? 8 Q. What were the other clubs that ou worked at? 9 A. A strip club. 10 Q. And do you know last name? 10 11 A. No, I do not. 11 Q. Are you currently working? 12 Q. How long a period of tittle was it that you were 12 A. Yes. 13 a stripper? 13 Q. Where are you currently working? 14 MS. BLANTON: rm going to object, .- 14 A. 15 MR. HOROWITZ: What? 15 Q. 16 MS. BLANTON: — based on earlier concerns. 16 A. 17 This is very private, personal information. With 17 Q. That's not a strip club? 18 regard to how it relates to Jeffrey Epstein, if you 18 A. No, it's not a strip club. 19 have some sort of predicate or can explain the 19 You've never heard of It's 20 relevance me know. I think you have a right 20 not a strip club. 21 to ask = last name. She doesn't know it. 21 Q. What do you do at 22 You have a right to ask where the name of the place 22 A. have. I wait tables. 23 is if you want to try to find her. 23 MR. CRITTON: You're not local. I take that 24 MR. HOROWITZ: Thank you. That wasn't a form 24 back. You can only ask the question. 25 objection. 25 BY MR. HOROWITZ: Page 243 Page 245 1 BY MR. HOROWITZ: 1 Q. How old were you when Jane Doe 4 came to see 2 Q. Where did you dance? 2 you at the strip dub you were wetting at? 3 A. A lot of places. 3 A. In 4 Q. Give me the names of the clubs that you worked 4 Q. Yes. 5 as a stripper. 5 A. I want to say that I was just turned 20. 6 MS. BLANTON: I'm going to object based on 6 Q. And I'm ptering that since Jane Doe 4 came 7 privacy. I do not think she needs to answer that. 7 to visit you in whatever arguments you had in 8 I don't think it has any relevance to this lawsuit. 8 high school, the fistfight, problems with the boyfriend 9 BY MR. HOROWITZ: 9 or ex-boyfriend, you had kind of worked those things out 10 Q. Did you work as a stri per with any of the 10 by the time she came to visit you in M? 11 girls who went to High School? 11 MR. CRITTON: Form. 12 A. Not thatl know of, no. 12 THE WITNESS: Because of my living 13 Q. Did any of the girls who you brought to 13 circumstances with Jane Doe 7, I put our 14 A. Actually, I take that back Jane Doe 4 came 14 differences aside as respect for my roommate. 15 to visit me in and I took her to the strip club 15 BY MR. HOROWITZ: 16 1 worked with up there and she stripped. 16 Q. So Jane Doe 7 was your roommate in 17 Q. She went one time? 17 while — and she was going to school there? 18 A. Yes. 18 A. That's correct. 19 Q. How long did she strip for? 19 Q. How did it come to be that you were no longer 20 A. Maybe three hours and then we left the club. 20 roommates with Jane Doe 7? 21 Q. It's your testimony she stripped for three 21 A. After that 22 hours? 22 everybody just split up. My parents wanted me to come 23 A. Yep. Yes. 23 home. This whole stein case had 'ust blown up the 24 Q. And was she on, like, the payroll? She was 24 same week They felt it would 25 hired by the — by the strip club the day she went? 25 be more beneficial for my health that I come home and ••• ••••••••... 23 (Pages 242 to 245) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82cIddf.59et-4e57-9cd8-8392056001c0 EFTA01076009 Page 246 Page 248 1 deal with it as a family, instead of being in MR. KUVIN: I've given it to the witness, 2 Q. How did it come to be when you came to live 2 Dick. 3 with Jane Doe? in 3 BY MR. WILLITS: 4 A. I wanted out of I was tmhappy 4 Q. Do you recognize that young lady? 5 living at my home. I had just been interrogated by the 5 A. No. But she kind of looks like that girl that 6 police about the whole Epstein situation. So I thought 6 killed her kid on tv. What's her name? No. Cayley, 7 it would be good to get out or and start off 7 the whole Cayley Anthony. It resembles her, but I've 8 kind of fresh somewhere else. which was lane 8 never seen this girl in my life. Doe Ts roommate, said she wanted to move back home. 9 Q. Okay. Thank you very much. 10 Her boyfriend wanted to as well. So I took her lease 10 I want to change the subject and ask ou: 11 over in the loft. 11 When is the last time you talked to 12 Q. What was the name of the strip club you worked 12 A. Oh, it's been a very long time. Eighteen? 13 at with 13 When I was 18 years old. After I brought I cut off 14 A 14 ties. 15 Q. 15 Q. And where did that conversation take place? 16 16 A. At Epstein's house. 17 MR. HOROWITZ: Thanks. I don't have any 17 Q. And what was it about? 18 further questions at this point in time. 18 A. I don't know. I don't remember. 19 MR. CRITTON: Dick, you're on. 19 We didn't end on bad tams. It was just after 20 MR. WILLITS: Thank you very much. 20 I brought the last girl, I just never spoke to them 21 CROSS EXAMINATION 21 again. 22 BY MR. WILLITS: 22 MR. WILLITS: I don't have any other 23 Q. Mr. Kuvin has a picture that I would like for 23 questions. 24 him to show you now of a young lady. 24 MR. HOROWITZ: Neither does Bob. 25 MR. KUVIN: One of us does. Yeah. IR hold 25 CROSS EXAMINATION Page 247 Page 249 1 it up. 1 BY MR. CRITTON: 2 MR. CRITTON: Can we mark it as the next 2 Q. My name is Bob Critton. I represent 3 Exhibit? 3 Mr. Epstein. 4 MR. HOROWITZ: Let's show it to the camera. 4 Is it okay if I call you M? 5 MR. KUVIN: Do you want to mark it? 5 A. Yes. 6 MR. WILLITS: Well, don't we have some sort of 6 Q. M, you've been asked — let's see. We 7 a— do we have a deal or not? 7 started today at 11:00. It's about quarter to 5:00 and 8 MR. CRITTON: Yeah. We're not — the pictures 8 I think we took about 45 minutes to an hour for lunch 9 remain with the lawyers, you know, within the 9 and we've had a couple other breaks. So I know you've 10 confines of the files anyway. They're not going to 10 been here a long time, but you've also covered a lot of 11 be filed. 11 territory that I need to kind of work my way back 12 MR. WILLITS: Okay. Sure. Mark it. 12 through. 13 MR. KUVIN: This will be Plaintiffs 5. And, 13 If I understand it from your testimony 14 Dick, give me one second to just show it to the 14 well, let me ask you this first: Mr. Kuvin, who spent 15 camera. 15 the better of the day with you represents a person 16 (Exhibit number 5 was marked for 16 named rtI think during one of his last few questions 17 identification purposes.) 17 he asked you whether you knew her. And I think your 18 MR. CRITTON: You know, it's probably not a 18 response was you've never heard of her, correct? 19 bad idea for the court reporter — are you 19 A. That's correct. 20 attaching Exhibits to the depositions? 20 Q. In the other approximately four hours' worth 21 VVIrat you should do is probably put the 21 of uestioning, did he ever ask you one question about 22 Exhibits in a separate envelope and put a sticker 22 M.? 23 on it as warning if it tells us the original, 23 A. No. 24 whoever gets the original, they don't erroneously 24 Q. All right. With regard to Mr. Epstein, if I 25 file something. 25 understood your earlier testimony, is, you learned about 24 (Pages 246 to 249) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddd1-59ee.4e57.9cd8.839205600fc0 EFTA01076010 Page 250 Page 252 1 Mr. Epstein who was referred to as Jeff or Jeffrey from 1 MR. HOROWITZ: Form. 2 Jane Doe 101, correct? 2 MR. KUVIN: Join. 3 A. Yes. 3 THE WITNESS: Yes. 4 Q. All right. And that occurred at a bar railed 4 BY MR. CRITTON: 5 or a restaurant/bar called, =, which is on the 5 Q. Did Mr. Epstein at any time try to use any 6 beach in Florida? 6 force or coercion or any type of physical force towards 7 A. Yes. 7 you? 8 Q. And Jane Doe 101 basically said something to A. Never. 9 the effect, is, after you had a discussion with her and 9 Q. Did he ever threaten you in any way, either 10 casual friend is, is, would you like to make a couple 10 physically or verbally? 11 hundred bucks? 11. A. No. 12 A. Yes. 12 Q. Did you find him to be, at least in your 13 Q. And when she — and if I also understood your 13 discussions with him, to be soft spoken; that is, he was 14 testimony, is, she basically said, depending on how 14 nice to you? 15 you're dressed, you may cam a little bit more, a little 15 A. Yes. 16 less money; is that aftin statement? 16 MR- KUVIN: Objection to form. 17 MR. HOROWITZ: Object to the form. 17 BY MR. CRITTON: 18 MR. KUVIN: Join. 18 Q. Was he ever not nice to you or ever rode to 19 MR. WILLITS: Object to the form. 19 you in any fashion? 20 THE WITNESS: I'm sorry. Can you repeat the 20 A. Never. 21 question? 21 MR. HOROWITZ: Form. 22 BY MR. CRITTON: 22 MR. KUVIN: Join. 23 Q. Sure. If I tmderstood what Jane Doe 101 said 23 BY MR. CRITTON: 24 to you, is, she said a number of thing, is, Jeff - 24 Q. Were you at any time 25 Jeffrey lived in Palm Beach, had a big house, that you 25 MR. WILLITS: Form. Page 251 Page 253 1 would give him — that you would be required to give him 1 BY MR. CRITTON: 2 a massage, and that's pretty that's at least some of 2 Q. — concerned about your safety being in 3 the information that she provided, correct? 3 Mr. Epstein's home? 4 A. Yes. 4 A. That's absurd. 5 Q. Did she tell you what you should wear or 5 Q. Okay. So the answer is no? 6 suggest what you should wear in any way? 6 A. No. 7 A. No. 7 Q. Were you — did you at any time even 8 Q. Did she at that time tell you that if you wear 8 contemplate yelling or screaming or crying for help at 9 something or if you take something off, you might get 9 any time that you were around Mr. Epstein? 10 paid a little bit more money? 10 A. No. 11 MR. HOROWITZ: Object to the form. 11 Q. Were you ever with anyone in his home, at any 12 MR. KUVIN: Join. 12 time were you afraid or fearful or concerned at all 13 THE WITNESS: No. 13 about your safety? 14 BY MR. CRITTON: 14 A. No. 15 Q. And, so — and that's pretty much what you 15 Q. After the one occasion that you were at 16 knew about Mr. Epstein or Jeff until you got to the 16 Mr. Epstein's home and you gave him a massage, ill 17 house? 17 understood your testimony, you never gave him another 18 A. Yes. 18 massage? 19 Q. And if I understood your testimony in response 19 A. I never gave him another massage. 20 to questioning by Mr. Kuvin and Mr. Horowitz, is, you 20 Q. But, in fact, you did bring a number of girls, 21 went upstairs, you gave the massage. He during the 21 which 1 think you described to be approximately 12,12 22 course of the massage he reached towards you, you said, 22 different people, some people more than once, but 12 23 in essence, stop. and that was the end of him in any vary 23 different people that you can recall approximately? 24 towards you or attempting to touch you; is that a 24 A. Yes. 25 correct statement? 25 Q. And they were females? 25 (Pages 250 to 253) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-5See-4e57-9cd8-8392056001c0 EFTA01076011 Page 254 Page 256 1 A. Yes. 1 reservations about going; that is, did you have to try 2 Q. We know that. All right 2 to cajole these people or encourage them to go or did 3 A. That I know of, yes. 3 all of the 12 basically once you told them what was 4 Q. And of the females that you brought, if I 4 going on and that they couldmake a couple hundred 5 understood your testimony, as to all of those girls you 5 bucks, did all of them willingly go? 6 basically had or provided pretty much a standard talk or 6 A. Yes. 7 a standard — you had kind of a standard explanation as 7 Q. As to the girls that went, what I also 8 to what would occur, is that a fair statement? 8 understood your testimony, I think it was in response to 9 A. That is a fair statement. 9 Mr. Horowitz's questions, is that — is, I think, as you 10 Q. And if I also understood your testimony, is, 10 said — I think your testimony was, is, you told them, 11 after you brought one or two girls, that the word kind 11 in essence, what Jane Doe 101 had told you; that is, if 12 of got around in your circle of your friends and/or 12 they go -- if they — if they do a massage dressed, 13 acquaintances and a lot of people wanted -- a number of 13 they'll make approximately X amount of dollars. If they 14 other females wanted to come and to give Mr. Epstein 14 leave just their bra on or if they take their skirt or 15 massages at his home? 15 their pants off or if they go topless, then they might 16 MR. KUVIN: Fenn. 16 make some additional money? 17 THE WITNESS: Yes. 17 MR. HOROWITZ: Form. 18 BY MR. CRITTON: 18 MR. KUVIN: Join. 19 Q. And if I understood as well what you said, is, 19 THE WITNESS: Yes. 20 the little speech or the information that you provided 20 BY MR. CRITTON: 21 the girls was, is that, there was a man in late forties, 21 Q. And the girls that you talked to, that is, the 22 early fifties, you could make some money, you could give 22 12 approximately girls that you brought, did any of them 23 him a massage, you would go to his house, he's got a 23 ever express to you any reservations or any concern 24 nice house in Palm Beach, he's a billionaire, he's nice, 24 about after you told them that they might be asked to 25 you don't have to be scared, you know, you don't have to 25 go topless or to take off their shirt or to do the Page 255 Page 257 worry about anything when you're there? 1 massage in their bra and a thong or maybe even with only 2 A. Mats correct. 2 partially clothed, did any of those girls after you told 3 Q. Did you tell them — did you tell these girls 3 them that, express any reservation or concern? 4 that he would be respectful towards them? 4 A. No. 5 A. Yes. 5 Q. Now, of the 12 girls that you took to 6 Q. Did you tell them that at no time would they 6 Mr. Epstein's home in some fashion, did you transport 7 ever experience any type of physical force or violence 7 them all or did some of them get there by themselves or 8 or any type ofcoercion? 8 pick you up and take you there? 9 A. Yes. 9 A. Sometimes I drove. Sometimes they drove. 10 Q. And did you tell them that — that you had 10 Q. And ofthe of the females that went to 11 never been afraid? 11 Mr. Epstein's home, the 12 -- and I'm talking about just 12 A. Yes. 12 their initial visits, and that would include Jane Doe 4, 13 Q. All right. And did some of the people who -- 13 Jane Doe 7 and Jane Doe 3, all who are three Plaintiffs 14 well, let me ask it this way: Of those girls, did you 14 in three separate cases here, and — did any of those 15 tell all of them to tell Mr. Epstein that they were DI 15 girls, including those three, ever express when they 16 years old or older? 16 came down from being upstairs with Mr. Epstein that they 17 A. I told all of them to lie about their age. 17 were scared or fearful of anything that had occurred at 18 Q. And you told them to lie about their age? 18 the house? 19 A. That's correct. 19 MR. HOROWITZ: Form. Foundation. 20 Q. And did any of them, that is, did any of the 20 THE WITNESS: No. 21 12 girls that you took, did any of them express any 21 BY MR. CRITTON: 22 cancent about lying about their age? 22. Q. Did any of those girls during the time — did 23 A. No. 23 any of those females during the time that they were 24 Q. Did any of them express, that is, any of the 24 upstairs at any time yell, scream or cry for help? 25 12 girls that you took, did any of them ever express any 25 A. No. 26 (Pages 254 to 257) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7aB2dddf-59ce4e57-9cd8-8392056001c0 EFTA01076012 Page 259 Page 26G 1 Q. Did myone, other than the one person that you 1 MR. HOROWITZ: Objection. Fenn. Cumulative. 2 mentioned, M., I think was her name -- 2 MR. KUVIN: Join. 3 A. Uh-huh. 3 THE WITNESS: No. 4 Q. -- who was complaining about the amount of 4 BY MR. CRITTON: 5 money or that she and Mr. Epstein had gotten into a 5 Q. Did — with the individuals that went back, 6 dispute about the amount of money -- did any of them 6 did that include Jane Doe 7 and Jane Doe 4; that is, 7 ever explain to you or tell you that they had had any 7 they went multiple times that you're aware of? 8 problem with what occurred with Mr. Epstein upstairs? 8 A. Yes. 9 A. No. 9 Q. And did that include Jane Doe 3? 10 Q. Did any of them — let me strike that. 10 A. I don't know. 11 Let me focus on the one person who complained 11 Q. You know for sure she went one time and you 12 about the money, Ms.I.,.. Did she ever — other 12 know she went another time when you and Jane Doe 3 took 13 than saying she thought instead of getting 200 or 13 another.? 14 whatever the number was she should have gotten 300, was 14 A. Yes. 15 that the extent of her complaint? 15 Q. At the time that -- let me strike that. 16 A. Yes. 16 Th.. that %vas — you and Jane Doe 3 took, 17 Q. Did she ever complain or suggest to you that 17 did Jane Doe 3 ever express any concern to you or 18 she had -- that there had been any type of verbal or 18 complaint that maybe it would be inappropriate to take 19 physical abuse or any inappropriate conduct that had 19 I. because something bad or inappropriate or humiliating 20 caused her any problem or that she complained about? 20 or emotionally disturbing had occurred with her? 21 A. No. 21 A. No. 22 Q. Did Ms. — M. go back again, to your 22 MR. KUVIN: Objection to form. 23 knowledge? 23 BY MR. CRITION: 24 A. No. She wanted to, but I didn't feel 24 Q. Did Jane Doe 3 ever tell you that as a result 25 comfortable bringing her back after the dispute, the 25 of the, at least one visit she had with Mr. Epstein, Page 259 Page 261 1 first dispute between them. 1 that she suffered any type of emotional or mental 2 Q. So., even though she had a dispute 2 trauma? 3 apparently with Mr. Epstein over money, she then came 3 A. No. I back to you and asked if she could go back again? 4 MR. HOROWITZ: Form. 5 A. She wanted to work for him again. And he 5 BY MR. CRITTON: pretty much made it clear that, you know, the whole 6 Q. Did she ever tell you, Jane Doe 3, at any time argument was unnecessary and then I felt uncomfortable 7 after she went to see Mr. Epstein and when she took. 8 bringing her back, so I wouldn't bring her back. I told 8 that she was concerned about.. suffering some sort of 9 her no. 9 emotional or mental anguish or trauma or psychological 10 Q. And, so, despite -- despite the financial 10 or psychiatric damage? 11 dispute, did it appear there had been any other problem 11 A. No one ever complained of that. 12 or any other issue or any other inappropriate actions by 12 Q. Well, I want to stick just with Jane Doe 3. 13 Mr. Epstein that would have suggested to you — well, 13 Did she ever complain about that? 14 let me stole that. 14 A. No. 15 MR. HOROWITZ: Objection. Cumulative at this 15 Q. Did.Jane Dee 4 at any time after the first 16 point, whatever your next question is. 16 visit or the second or any other visits that you knew 17 MR. CRITTON: Ill withdraw that question. I 17 she had with Mr. Epstein, did she ever express to you 18 think live finished withM. 18 that she was humiliated by the experience? 19 BY MR. CRITTON: 19 MR. HOROWITZ: Cumulative. 20 Q. Let me -- with the other I I females, separate 20 THE WITNESS: No. 21 and apart from.., did any of than ever complain to 21 BY MR. CROFTON: 22 you at any time, whether it was the first or second 22 Q. Did she, Jane Doe 4, ever tell that you she 23 visit or third, that they that anything that had 23 was embarrassed by having been with Mr. Epstein on the 24 occurred with Mr. Epstein was inappropriate or that — 24 multiple occasions? 25 or that they complained about? 25 MR. HOROWITZ: Form. 27 (Pages 258 to 261) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7482dcldf-69ev-4o57-9cd8-8392056001c0 EFTA01076013 Page 262 Page 264 1 THE WITNESS: No. 1 A. Yes. 2 MR. CRITTON: Form. How can I correct it? 2 Q. Did she ever express to you as a result of 3 4 5 MR. HOROWITZ: You cant. Cumulative. You have asked the same question six different ways and you already have the answer. And now you're using 3 4 5 having been with Mr. -- the time she spent with Mr. Epstein that she was required to see a psychologist or psychiatrist or any other health care professional? I 6 words. You're using synonyms. 6 A. She did tell me something about that 7 MR. CR1TTON: Pm sorry I asked. 7 Q. And when did she tell you that? MR. KUVIN: You asked. A. When I moved back down here when her, 9 MR. HOROWITZ: Like a Thesaurus. 9 and I started hanging out. 10 How many different ways can you say anguish, 10 Q. And what did she tell you? 11 trauma. 11 A. Well, she didn't tell me directly. She told 12 BY MR. CRITTON: 12 that she had to go see a thai , her and Jane 13 Q. M, did Jane Doe 4 ever tell you she had 13 Doe 7 had to see some therapist in and they flew 14 sustained any type of emotional or psychological trauma? 14 her out there and they had to fake cry and they had to 15 A. No. 15 pretend like they were damaged. They had to pretend 16 MR. HOROWITL Cumulative. 16 that they were being molested. And Jane Doe 7 was 17 THE WITNESS: It's Jane Doe 4 though. Sony. 17 laughing about it. This is according to what 18 BY MR. CRITTON: 19 told me. 19 Q. i 19 Q. Okay. Separate and apart from that incident, 20 MR. KUVIN: Now he's going to reask all the 20 did Jane Doe 4 ever tell you that she had seen a 21 questions. 21 psychiatrist or psychologist as a result of any contact 22 BY MR. CRITTON: 22 that she had had with Jeffrey Epstein? 23 Q. Did Jane Doe 3 or Jane Doe 4 — 23 A. No. 24 A. Yes. 24 . B the way when Jane Doe 4 was dancing at 25 Q. — ever tell you that they had lost income as 25 in EM, and you said thes a strip Page 263 Page 265 1 a result of being — of having gone to Mr. Epstein's 1 club? 2 home? 2 A. Yes. 3 A. No. 3 Q. And you said she tried out? 4 Q. Did any of them, did either Jane Doe 3 or Jane 4 A. Yes. 5 Doe 4 ever tell you that their economic -- their ability 5 Q. For, I assume, the manager? 6 to earn money in the future had in some way been 6 A. The whole club. 7 impacted? 7 Oh. So Jane Doe 4, the player from 8 A. No. 8 =University, was she in college at the time? 9 Q. Did Jane Doe 3 ever tell you as a result of 9 A. Yes. 10 seeing Mr. Epstein that she was required to see a 10 Q. All right. And was she kind of a shy person? 11 psychologist or psychologist? 11 A. No. 12 A. No. 12 Q. And I think you also described -- described 13 Q. Did Jane Doe 4 ever tell you — and apparently 13 one of the instances why you don't respect her or don't 14 you saw her for a number of years following the time 14 think highly of her was, is that, you found her or 15 that she — she was at Mr. Epstein's home, correct? And 15 your — who you thought was your boyfriend having sex 16 you saw Jane Doe 4 even when she was at college or 16 with Jane Doe 4? 17 during the time she was at college at University? 17 A. It was a guy that I was dating and she was 18 A. Yes. 18 having oral sex with him. 19 Q. And ifl understood your response to 19 Q. Okay. 20 Mr. Horowitz's question, you even got to see her strip 20 MR. HOROWITZ: Move to strike. 21 up at —what was it? 21 BY MR.. CRITTON: 22 A. 22 Q. Well, you saw it yourself? 23 Q. 23 A. I walked in on them, yes. 24 A- Yes. 24 Q. All right. And she was giving him oral sex at 25 Q. -- up in for three hours, right? 25 the time? 28 (Pages 262 to 265) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-69eo4e57-9cd8-839205400k0 EFTA01076014 Page 266 Page 268 1 A. That's correct. 1 MR. KUVIN: Fonn. 2 Q. And did you say anything? 2 THE WITNESS: Yes. 3 A. We almost got into a second fight. 3 BY MR. CRITTON: 4 Q. And when she came up, so to speak, when she — 4 Q. Did she tell you they asked her to stay or to 5 you said something to her, did she stop what she was 5 come back? 6 doing and then stand up? 6 A. The manager came to me specifically and asked 7 A. Well, she had been drinking and she kind of 7 me if she wanted the job. 8 got up off the floor and she got in my face. We had a 8 Q. And of course she had to go back to college? 9 little bit of an altercation. And he pretty much got in 9 A. Yes. 10 between us and I walked away. 10 Q. Let me be specific now with regard to Jane Doe 11 MR. HOROWITZ: Move to strike. 11 7. 12 Non-responsive. 12 Jane Doe 7. I think you testified you were 13 BY MR. CRITTON: 13 aware that she went to Mr. Epstein's house on a number 14 Q. And the male's name was? 14 of occasions? 15 A. 15 A. Yes. 16 Q. Was she, Jane Doe 4, dating anyone at the 16 Q. You took her once and you may have gone back 17 time, to your knowledge? 17 one or more occasions with her? 18 A. I don't remember. 18 A. Possibly. 19 Q. Approximately what time — what time period 19 Q. But you were aware from — what? -- from 20 are we dealing with? 20 speaking with her that she had gone beck on multiple 21 A. We were definitely in high school. I can't be 21 occasions? 22 accurate about the years. 22 A. Yes. 23 ■ Q. Oh, okay. All right. Let me go back to. 23 Q. And I think you told us earlier neither Jane 24 24 Doe 4 nor Jane Doe 7 nor Jane Doe 3 described what 25 A. 25 actually occurred? Page 267 Page 2C 1 Q. . When she you say she tried 1 A. That's correct. 2 out for the whole club. What time of day was it that 2 Q. And because you weren't upstairs, you don't 3 she was trying out? 3 know what occurred with them? 4 A. I can't be sure. 4 A. That's correct. 5 Q. Evening? 5 Q. And with regard to Jane Doe 7, did she ever 6 A. It was evening. 6 tell you that Mr. -- well, let me smite that. 7 Q. And were there patrons in the place? 7 Did she ever complain to you that Mr. Epstein 8 A. Yes. 8 had acted inappropriately with her at any time? 9 Q. And wear a costume? 9 A. No. 10 A. No. 10 Q. Did she, Jane Doe 7, ever complain that 11 Q. What did she do? What did you see her do? 11 Mr. Epstein had used any type of physical or verbal 12 A. Dance in her thong and pasties. 12 force or violence directed to her? 13 Q. All right. Did she tell you afterwards she 13 MR. HOROWITZ: Form. Cumulative. 14 enjoyed it? 14 THE WITNESS: No. 15 A. Yeah. She said she made good money. 15 BY MR. CRITTON: 16 . So that she tried out, she -- at a strip club, 16 Q. Did she, Jane Doe 7, ever tell you that she 17 in M. She danced for about three 17 had suffered any type of emotional or mental trauma as a 18 hours and made good money? 18 result of her involvement with Mr. Epstein? 19 A. Uh-huh. 19 MR. HOROWITZ: Cumulative. Asked and 20 Q. Yes? 20 answered. 21 A. Yes. 21 THE WITNESS: No. 22 Q. And could she have come back there to her work 22 BY MR. EPSTEIN: 23 there if she didn't have to go back to school? 23 Q. Did she ever tell you that she ever suffered a 24 A. Yes. 24 loss of income, either past income or the futurability 25 Q. From at least what you observed? 25 to earn income as a result of her relationship with lbammo...4,1.6,s 29 (Pages 266 to 269) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82(Iddf-59ee-4e57-9cd0-83920560Dre0 EFTA01076015 Pacie 2;J Page 272 1 Mr. Epstein? 1 Q. What was — let me strike that. 2 A. No. 2 Did you know anything about'., other than 3 Q. Did she, Jane Doe 7, ever tell you that she 3 that — at the time that you spoke with her, other than 4 was, as a resuh of her contact with Mr. Epstein, that 4 she was dating at the time? 5 she had been required to see a psychiatrist or a 5 MR. KUVIN: Form. 6 psychologist or some sort of mental health counselor? 6 MR. HOROWITZ: Form. A. Not directly, no. THE WITNESS: That she was dating-? No. 3 Q. And the only thing you know is what you heard? 8 I mean, that's all I knew. 9 A. Was told to me from 9 BY MR. CRITTON: 10 Q. All right. Did Jane Doe 7, Jane Doe 3. — 10 Q. Well, did you know anything about her 11 well, let me grace that. 11 reputation around school? 12 Did Jane Doe 7 ever tell you that she was 12 A. Yes. 13 embarrassed or humiliated as a result of her actions 13 Q. What was her reputation? 14 with Mr. Epstein? 14 MR. KUVIN: Object to the form. 15 MR. HOROWITZ: Form. Cumulative. 15 THE WITNESS: She was promiscuous. 16 THE WITNESS: No. 16 BY MR. CRITTON: 17 BY MR. CRITTON: 17 Q. And you had heard that from a number of 18 Q. You said at ono time or on a number of 18 people? 19 occasions various individuals approached you so that 19 MR. KUVIN: Object to the form. 20 they could go to Mr. Epstein's home? 20 THE WITNESS: ! heard that from two people 21 A. Uh-huh. 21 BY MR. CRITTON: 22 Q. Is that correct? 22 Q. To your knowledge, was she sexually active? 23 A. Yes. 23 A. Yes. 24 Q. Did that include Jane Doe 7 and Jane Doe 4? 24 Q. Did she tell you that or did NI tell you 25 A. Yes. 25 that? Page 271 Page 273 1 Q. Did that include Jane Doe 3? 1 A. Both. 2 A. I can't remember. 2 Q. And serially active, both intercourse and oral 3 Q. Now, Mr. Kuvin did ask a number of questions 3 sex? 4 about 4 A. Yes. 5 is a person who you told — you told to 5 Q. And did I. — well, let me strike that. 6 tell Epstein if asked that she was 18? 6 Do you know whether. also was a user of 7 A. Yes. 7 illegal drugs or non-prescription drugs? 8 Q. Did she have any problem with that? 8 MR. KUVIN: Objection to form. 9 A. No. 9 THE WITNESS'. Yes. 10 MR. HOROWITZ: Object to the form. 10 BY MR. CRITTON: 11 MB. KUVIN: Join. 11 Q. And what kind of drugs were you aware that she 12 BY MR. CRITTON: 12 used? 13 Q. What wasIs did you know who'. was? 13 A. Marijuana. 14 A. Yeah. 14 MR. HOROWITZ: Fenn. 15 Q. I mean, you knew. from — from high school? 15 BY MR. CRITTON: 16 A. No. 16 Q. Anything else? 17 Q. You knew her throughlM? 17 A. Not that I know of 18 A. Yes. 18 Q. When'. — so you talked tol. about 19 Q. All right. And when you told, about or told 19 Mr. Epstein. The matter dropped. And did she 20 her about — let me strike that. 20 re-contact you, like, right away or within a few days? 21 Did you tell me she had heard about it — 21 A. We had -- we had talked about it. I had said 22 heard about Epstein from someone else and she approached 22 something to her. She had asked me if I could take her. 23 you or did you say you approached I.? 23 And within a day or a couple days we had set it up. 24 A. 1 had said something to her and she had asked 24 Q. But she approached you? 25 me ifI could take her. 25 A. Well, 1 had said something about it and then 30 (Pages 270 to 273) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-59ec.4e57.9cd8-8392056001c0 EFTA01076016 Page 274 Page 276 1 she had asked me to take her. 1 is, you never had -- you never spoke with Mr. Epstein by 2 Q. But, again, she could have said, I'm not 2 phone, never tested back and forth, nor never -- nor did 3 interested, don't — 3 you ever email; is that correct? 4 A- But she didn't. 4 A. That's correct. 5 MR. KUVIN: Objection to form. Move to 5 Q. Did -- you knew Jane Doe 7 both before and 6 strike. 6 after she had seen Mr. Epstein; is that correct? 7 BY MR. CRITTON: 7 A. Yes 8 Q. Did she ever say, I'm not — let me start 8 Q. And as of the last -- and did you see -- after 9 again. 9 Jane Doe 7 stopped going to Mr. Epstein's home, did you 10 You told her about it? 10 see her on — well, I think you said you were roommates, 11 A. Uh-huh, yes. 11 if I understood correctly? 12 Q. Did you then follow up with ha on multiple 12 A. That's true. 13 additional conversations or was it'. then who contacted 13 Q. How long were you all roommates? 14 you and said, I'd like to go? 14 A. Between -- about seven months. 15 A. It was more we had talked about it, she 15 Q. Give me a time frame, if you could, 16 contacted me or I contacted her and then we went. It 16 A. 17 wasn't like a phone tag game, no. 17 3.8 Q. Did you have to push her in any way to go? 18 Q. And did you stay — so at least you saw her 19 A. No. 19 pretty much everyday dining that time period? 20 Q. Did she -- was she encouraging you to take 20 A. That's true, yes. 21 her? 21 So during the 22 A. Yes. 22 you saw Jane Doe 7 on 23 Q. And did you tell her the same thing that you 23 almost a daily basis. 24 had told the other girls, Le., tell him — lie about 24 On those during that daily basis, did she 25 your age, the more you do, i.e., in terms of how you're 25 ever appear to be so depressed to you or depressed or Page 275 Page 277 1 dressed or how you're undressed, you'll make more money? 1 upset to any degree that she did not appear to be 2 A. That's correct. 2 carrying out ha daily activities of living? 3 Q. Did she express any concern or reticence about 3 MR. HOROWITZ: Form. 4 going? 4 THE WITNESS: No. 5 A. No. 5 BY MR. CRITTON: 6 Q. All right. Did she express any -- instead of 6 Q. Did you ever see Jane Doe 7 hesitate to go to 7 using reticence, probably not a great word — did she 7 a party or go to a bar? Well, let me stile that. 8 express any hesitation or concern about going? 8 Did you ever go with Jane Doe 7 to bars, to 9 A. No. 9 social gatherings, to parties during that time frame? 10 MR. KUVIN: Objection. Cumulative. 10 A. Yes. 11 BY MR. CRITTON: 11 Q. And did she ever appear to be emotionally 12 Q. When she came — well, let me strike that. 12 disturbed or have any type of depression or concern that 13 When she came down after you went to Epstein's 13 prevented her from attending parties, going out to bars, 14 home, did she ever express any type of concern or 14 engaging in social activities, at least from what you 15 complaints about anything that had occurred with 15 observed? 16 Mr. Epstein? 16 MR. HOROWITZ: Form. 17 A. No. 17 THE WITNESS: No. 18 Q. Did she express to you at any time that there 18 BY MR. CRITTON: 19 had been any inappropriate conduct -- 19 Q. Did she ever express to you during that 20 A. Na 20 approximately six or seven months -- well, let me strike 21 Q. — or contact? 21 that. 22 A. No. 22 During that six or seven months, did she ever 23 MR KUVIN: Objection to form. 23 talk about Epstein? 24 BY. MR. CRITTON: 24 A. No, not that I can remember. 25 Q. If I understood your — your earlier testimony 25 Q. Did either one of you bring up Epstein? 31 (Pages 274 to 277) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddelf-59e04057-9cd8-8392056001c0 EFTA01076017 Page 278 Page 280 1 A. It was a joke from time to time. 1mean, we 1 BY MR CR117ON: 2 joked around about how nice it would be to find an 2 Q. During the same -- after — and 1 3 Epstein that lived in . We joked about it. But 3 understand that you returned because o 4 it wasn't anything derog — well, I mean, you can 4 5 consider that derogatory. But there was nothing about 5 A. Yes. 6 her psychiatric health or her ability to move on with 6 Q. And you returned back to the 7 life. 7 area? 8 Q. Oka rou say you joked about if you had an 8 A. Yes. 9 Epstein in meaning what during that time frame? Q. And you had little contact with Jane Doe 7 10 A. Meaning, it would just be nice if we had a guy 10 after that point in time for some of the reasons you 11 for income, I guess. 11 told us? 12 Q. And this time you were -- let's see, in 12 A. That's correct. 13 you were 20 years old? 13 Q. And Jane Doe 4 u until the point that you 14 A. (Jh-huh. 14 returned did you stay in somewhat 15 Q. And or almost, you were just about 19, 15 contact with her during the time period that you and 16 about to nun 20. Is Jane Doe 7 the same age as you or 16 Jane Doe 7 were roommates? 17 you're - 17 A. I wouldn't say friends. When I lived with 18 A. Jane Doe 7 is a year younger. 18 Jane Doe 7. like I said, I respected her as a roommate, 19 Q. So she would have been 18, closing in on 19 so I treated Jane Doe 4 differently. But we weren't 20 I9, — 20 friends. 21 A. Yes. 21 Q. All right. All you know is — but she did 22 Q. -- depending on when her birthday was? 22 come out with you to go dancing with you at the 23 So if I understand your testimony, the 23 24 discussion that you and Jane Doe 7 had regarding 24 A. Yes. 25 Epstein, at least, in — during that six or seven month 25 MR. CRITFON: I'm sorry. Dancing. Jane Doe 4 Page 279 Page 281 1 time period was, it would be nice to have an Epstein up stripped. 2 there, as distinct from, I'd say, either one of you 2 BY MR. CRITTON: 3 complaining or suggesting that you were depressed. 3 Q. Anyhow with regard to when Jane Doe 4 would 4 humiliated, concerned or had any type ofemotional 4 cane up to , did she come up on more than one 5 problems? 5 occasion — 6 MR. HOROWITZ: Form. Compound. 6 A. I can't remember. 7 MR. KUVIN: Join 7 Q. — during the time you were roommates with 8 MR. CRITTON: Well, let me rephrase it 8 JaneDoer 9 BY MR. CRiTFON: 9 A. I can't remember. 10 Q. If I understood your testimony, is, you and 10 Q. You just remember the one time? 11 Jane Doe 7 joked about, it would be nice to have an 11 A. That's correct. 12 Epstein up there? 12 Q. And during the time that she came up there, 13 MR. HOROWITZ: Asked and answered. 13 did she stern to have any type of lingering depression or 14 MR KUVIN: Join. 14 psychological condition, at least that she either 15 THE WITNESS: Yes. 15 expressed to you or that you observed? 16 BY MR. CRITTON: 16 MR. HOROWITZ: Form. Foundation. 17 Q. And did you and Jane Doe 7 ever talk about or 17 THE WITNESS: No. 18 either one of you ever express any type of that either 18 BY MR. CRITTON: 19 one of you had suffered any type ofemotional injury or 19 Q. Did you and Jane Doe 7 - did you and Jane Doe 20 traumatic event as a result of your involvement with 20 4 ever e-mail back and forth, either on My Space or on a 21 Mr. Epstein? 21 social networking thing? 22 MR. HOROWITZ: Cumulative. Asked and answered 22 A. I believe My Space. 23 as to Jane Doe 7. 23 Q. And did she ever express to you -- and let me 24 MR.KUVIN: Join. 24 strike that 25 THE WITNESS: No. 25 In the times that she would communicate with MoleasaMeeS1 32 (Pages 278 to 281) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-Sgeo-4e57-9cd8-13392056001c0 EFTA01076018 Page 282 Page 284 1 you on My Space, did she ever suggest that she was 1 she used? . 2 Wing any type of emotional problems? 2 A. Cocaine. 3 MR. HOROWITZ: Cumulative. Asked and 3 Q. To your knowledge, was Ms. Jane Doe 3. ever 4 answered. 4 pregnant? Did she ever have an abortion? 5 BY MR. CRITTON: 5 A. I have no idea. 6 Q. On the My Space? 6 Q. To your knowledge, did Ms. Jane Doe 3 have any 7 A. No. 7 STDs? Q. Did she ever, in communicating, indicate that 8 A. I have no idea. 9 she was having pretty good life, that things seemed to 9 MR. HOROWITZ: Object to the form. 10 be okay with ha? 10 BY MR. CRITTON: 11 A. Yes. 11 Q. To your knowledge, did Ms. Jane Doe 3 have any 12 Q. And did she — "she," meaning, Jane Doe 4 12 criminal history? 13 did she appear to be enjoying college and the college 13 A. I have no idea. 14 experience? 14 Q. Did she ever express to you that she, Ms. Jane 15 A. Yes. 15 Doe 3, ever express to you that she had been molested by 16 MS. BLANTON: I need a quick restroom break, 16 an individual? 17 if you're at a deceit stopping point. 17 MR. HOROWITZ: Form. 18 MR. CRITTON: I'm at a decent stopping point 18 THE WITNESS: No. 19 and ni try to imish in about 10 or 15 minutes. 19 BY MR. CRITTON: 20 VIDEOGRAPHER: Going off the record. The time 20 Q. By a person namer=? 21 is 5:18 p.m. 21 A. By who? 22 (Briefrecess.) 22 Q. By a person named MI? 23 VIDEOGRAPFIER: Were beck on the video record. 23 MR. HOROWITZ: Form. 24 The time is 5:22 p.m. 24 THE WITNESS: No. 25 BY MR. CRITTON: 25 BY MR. CRITTON: Page 283 Page 285 1 Q. I vault to ask you some specific questions 1 Q. Did she ever indicate to you, again, that Jane 2 about a number of the girls. I want to start with Jane 2 Doe 3 — let me strike that. 3 Doe 3 if I could. 3 Did you understand anything about her family 4 You described her earlier in response to 4 life? 5 either Mr. Kuvin or Mr. Horowitz's questions that her 5 A. I knew her sister. 6 reputation was that she was promiscuous? 6 Q. And her sister, was she in your grade or -- 7 MR. HOROWITZ: Object to the form. 7 A. She went to school with my sister. 8 THE WITNESS: That's correct. 8 Q. Did you know anything else about her, Jane Doe 9 BY MR. CRITTON: 9 3? 10 Q. And when you say prorniscuim4 what do you 10 A. That's all I know. 11 mean,-? 11 Q. The you were asked a question earlier about 12 A. Sleeping around. Having boys come over and 12 generically whether — let me strike that. 13 stay the night with her. 13 The girls that you asked to go or came to you 14 Q. And did you from time to time witness that? 14 10 ask to go to Mr. Epstein's and, in fact, of the 15 A. I was there one night -- twice actually, two 15 approximately 12 that went to Mr. Epstein, how would you 16 different nights. 16 have described them? Would you describe them, like, 17 Q. And did she — and was this before she ever 17 middle class? Upper class? Middle class? Lower middle 18 went over to Mr. Epstein's home? 18 class? 19 A. I believe so, yes. 19 MR. HOROWITZ: Foundation. Predicate. 20 Q. And with regard to Jane Doe 3, separate and 20 MR.1CUVIN: Form. 21 apart from being promiscuous, based upon what you heard 21 THE WITNESS: Same as me, middle class. 22 and saw, did she -- were you aware whether she used 22 BY MR. CRITTON: 23 illegal drugs? 23 Q. And all of the girls that went, the females 24 A. Yes, she did. 24 that went to Mr. Epstein's home, did you have -- that 25 Q. And what kind of drugs were you aware of that 25 is, with almost all of them, did you have some idea or 33 (Pages 282 to 285) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddt-59ee-4e57-9cd8-839205400fcg EFTA01076019 Page 286 Page 288 1 did you know where they lived? 1 or during the break up? You're kind of — 2 A. Yes. 2 BY MR. CRITTON: 3 Q. And, so, you were familiar with — of the 12 3 Q. During the entire time she dated him, 4 females that went to Mr. Epstein's home, you were 4 including break ups, did you see her having or engaging 5 familiar with where they lived, their neighborhood, 5 in some type of sexual activity? 1 6 their house, you know, what kind of car they either 6 A. At least two. 7 drove or were transported in? 7 Q. And as to Jane Doe 4, were you aware of 8 A. Yes. 8 whether or not she used illegal drugs? 9 Q. And, so, when you say they were from the 9 A. Yes. 10 middle class, that was based upon your observations? 10 Q. And what illegal drugs were you aware that she 11 A. Yes. 11 took? 12 Q. With regard to Jane Doe 4, you knew before 12 MR. HOROWITZ: Form. Foundation. 13 she ever went to Mr. Epstein's home, were you familiar 13 THE WITNESS: Xanax, marijuana and cocaine. 14 with any of her boyfriends? 14 BY MR. CRITTON: I 15 A. llh-huh, yes. 15 Q. And did you actually see her take those? 16 Q. And what was her main — well, let me strike 16 A. Yes. 17 that. 17 Q. Now, =, were you -- did -- were 18 You also described Jane Doe 4 as being 18 you ever -- well, let me strike that. 19 promiscuous? 19 I assume you knew him? 20 A. Yes. 20 A. Yes. 21 Q. And you knew that how? 21. Q. Were you ever present when Mr. struck, 22 A. We were friends. She was dating 22 bit or physically abused Ms. Jane Doe 4? 23 MIE. She was cheating on him every second that we 23 A. Yes. 24 were together. She had guys sneaking in and out of her 24 Q. On more than one occasion did you see him — 25 window. Whenever her and would break up she 25 k Yes. Page 287 Page 289 1 would date another guy for maybe three days and then get 1 Q. — physically abuse he 2 back with . 2 A. (Nods head.) 3 Q. And was she hooking up with these guys? Did 3 Q. What was her reaction to the physical abuse 4 she tell you that? 4 that her boyfriend was doing to her? 0 MR. HOROWITZ: Objection. Foundation. 5 A. Sometimes she would hit back. She would fight 6 THE WITNESS: I saw it a few times. 6 back. Other times she would spit on him. Sometimes slit 7 BY MR. CRITTON: 7 would run from him. 8 Q. And you say you saw it on a few occasions? 8 Q. You'd see her actually hit and spit — hit him 3 THE WITNESS: Yes. 9 back and spit on him? 10 BY MIt. CRITTON: 10 A. That's correct. 11 Q. So you — you physically — you have personal 11 Q. Did you ever see him spit on her? 12 knowledge during the time that she was dating 12 A. Yes. 13 during the times they were broken up, on more than one 13 Q. Did she ever -- did you ever discuss with her, 14 occasion you would see her having or engaging in sexual 14 that is, with Jane Doe 4, that maybe this wasn't a 15 activity with others, other males? 15 healthy relationship? 16 A. Not necessarily having sex. Engaging, yes. 16 A. Several times. 17 Q. Well, in addition — let's see. One of the i7 Q. What was her response? Was this prior to her 18 individuals was a guy that you were dating, correct? 18 seeing Mr. Epstein or ever meeting Mr. Epstein? 19 A. Yes. 19 A. That's correct. 20 Q. And did you see her with others as well? 20 Q. And what was her response to your 21 A. Yes. 21 conversations with her about the phikal and verbal 22 Q. Approximately how many other individuals, 22 abusethat MI •-- I'm sorry -‘ that 23 separate gart from =, during the time she was 23 was causing her? 24 dating . 24 A. We staged an intervention once with her family 25 MR. HOROWITZ: During the time she was dating 25 and they called the police. And she told the police 34 (Pages 286 to 289) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7andddf-59eu-4057-9cd8-839205600fc0 EFTA01076020 Page 290 Page 292 I. officer she didn't want to have a restraining order or 1 BY MR. CFUTTON: 2 to press charges against him after she got beat by him. 2 Q. And what did the video depict? 3 We had several conversations about her being 3 A. I never saw it myself, but there wereict7res 4 in an unhealthy relationship and maybe going to a clinic 4 of her on the Internet going around with lesbian 5 where abused women or women with relationship issues 5 pictures in their underwear, their thong, posing on top 6 should go to maybe get therapy as couples or to leave 6 of each other, making out. 7 him. 7 Q. Did you ever see any of those pictures or 8 And she looked at me like I was nuts. I'm in 8 that's just what you were told? 9 love with him. I don't want to leave him. He loves me. A. That's what I was told. 10 Crazy talk. 10 Q. And who told you that? 11 Q. So despite your involvement in speaking with 11 A. My boyfriend at the time. 12 her and her family and intervention with her, nobody 12 Q. Who was? 13 could talk her out of staying in her abusive 13 A. =. 14 relationship? 14 Q. And in terms oflane Doe 4, did you ever talk 15 MR. HOROWITZ: Form. 15 to her about it, say, hey, I hea.idou did a video with 16 THE WITNESS: No. 16 — what was her name? — 17 BY MR. CRITTON: 17 A. Yes. 18 Q. In terms ofMs. lane Doe 4, were you ever 18 Q. Did you ever ask her about it? 19 aware whether she was pregnant? 19 A. My boyfriend did while I was present and she 20 A. Yes. 20 said that she didn't care, it didn't bother her, and 21 Q. On how many occasions were you aware that she 21 that if somebody had a problem with it, they could F 22 was pregnant? 22 off. That was pretty much her attitude. 23 A. Two or three. 23 Q. And you heard her say that? 24 Q. And did she ever have a child? 24 A. Yes. 25 A. No. 25 Q. And did she ever indicate that the pictures Page 291 Page 293 1 Q. Did she have abortions? 1 that were displayed ofher having — in her thong, in 2 A. Yes. 2 some sort of, at least whatms rceived to be a 3 MR. HOROWITZ: Form. 3 lesbian relationship with that that caused her 4 BY MR. CRITTON: 4 any embarrassment or humiliation? 5 Q. And did she tell you that? 5 MR. HOROWITZ: Form. A. Yes. 6 THE WITNESS: No. 7 Q. And did she tell other people, as far as you 7 BY MR. CRITfON: 3 know? 8 Q. Well, did you hear — so I'm clear, is, I 9 A. Yes. 9 thought -- thought you said that asked her about 10 Q. Who else did she tell? 10 the pictures? 11 A. Jane Doe 7. She told 11 A. Yes, he did. 12 obviously. And that's M. &Ilk: ,. as 12 Q. And did he describe the pictures as to what, 13 well. 13 say, hey, I hear did he say something like, hey, 1 14 Q. So at least among that group it was pretty 14 hear you and are on the Internet and shows 15 common knowledge that she had had three abortions? 15 pictures of you guys on top of each other? 16 MR. HOROWITZ: Form 16 A. No. He had just briefly mentioned that there 17 THE WITNESS: Two or three. 17 were pictures on the Internet floating around and he 18 BY MR. CRSITON: 18 caught one of them. 19 Q. Two or three abortions. Do you know if she 19 Q. And that's when she said, if you have a 20 ever told her family? 20 problem with it, Fa, 21 A. No, I do not. 21 A. Pretty much was her attitude. 22 Q. Were you ever aware ofa video that she made 22 Q. All right. Were you ever aware that she did 23 with another female? 23 her own photography, made a video of she and 24 lit. HOROWITZ: Form. 24 engaging in various sexual acts? 25 THE WITNESS: Yes, in big' school. 25 MR. HOROWITZ: Form. 35 (Pages 290 to 293) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddill-69eo-4e57-9cd8-8392056001c0 EFTA01076021 Page 294 Page 296 1 THE WITNESS: I can't disclose that 1 Q. And at the times — on some of the occasions 2 information. 2 that you saw present and taking illegal 3 BY MR. CRIT'fON: 3 drugs, was Jane Doe 4 partaking in the same illegal 4 Q. Let me ask it this way: Did she ever tell 4 drugs? 5 you? 5 MR. HOROWITZ: Form. 6 A. She never told me. 6 THE WITNESS: Yes. 7 Q. Did she or ever show you a 7 BY MR. CRITTON: 8 video of the two of them having sex? 8 Q. Was known for being a seller 9 A. No. 9 of drugs? 10 Q. Did =, from your observations let me 10 MR. HOROWITZ: Form. 11 strike that. 11 THE WITNESS: I don't know. 12 Wile., were present, did you ever observe 12 BY MR. CIUTTON: 13 using illegal drugs? 13 Q. All you blow, he was a user? 14 A. Yes. 14 A. Yes. 15 Q. Was he — did you ever view him or observe him 15 Q. Was Jane Doe 4 dating during the time 16 taking or drinking excessively? 16 she was seeing Jeffrey Epstein? 17 A. Yes. 17 A. Yes. 18 Q. Did — was Ell from at least your 18 Q. Did she ever tell IM? 19 perception, a drug addict? 19 A. She wouldn't. 20 MR. HOROWITZ: Form. 20 MR. HOROWITZ: Form. 21 THE WITNESS: Yes. 21 BY MR. CRITTON: 22 BY MR. CRAYON: 22 Q. To your knowledge? 23 Q. Well let the ask ou this: How would you 23 A. No. 24 describe and his use of illegal drop? 24 Q. Did you ever see threaten to 25 A. He had an addiction. 25 kill or to injure Jane Doe 4? Page 295 Page 297 1 Q. And what kind of drugs, illegal drugs did he 1 A. On a regular basis. 2 take? 2 Q. Literally? 3 A. Cocaine, pills, alcohol. 3 A. Literally. 4 Q. Did you ever see him using those, that is, 4 Q. What was her response to that? 5 cocaine, pills — cocaine and pills in the presence of 5 A. She -- upset, start a physical fight. 6 he and Jane Doe 4? 6 Q. At what point were you aware when she stopped 7 A. Yes. 7 dating =? 8 Q. So if I had to ask you to assume that Jane Doe 8 A. I wasn't aware that they had stopped dating 9 4 has testified in this case that she was unaware that 9 until I moved back home and she was with another guy. 10 abused illegal drugs, would you be surprised to 10 Q. Who was the guy that she was with? 11 hear that testimony? 11 A. M. 12 MR. HOROWITZ: Form. 12 Q. And who isM? 13 THE WITNESS: Not really. 13 A. Her boyfriend. 14 BY MR. CRITTON: 14 Q. Is that — when is the last time you saw Jane 15 Q. Because you think she doesn't tell the truth? 15 Doe 4? 16 MR. HOROWITZ: Form. 16 A. I don't remember. I want to say, 17 THE WITNESS: She doesn't tell the truth. 17 Q. Was that -- was — and who was she there with 18 BY MR. CRITTON: 18 at the time? 19 Q. And, so, let me just ask it this way: Were 19 A. It was her and two girls. 20 ifisically present when when you saw 20 Q. And did you talk about Epstein at all on that 21 taking illegal drugs and Jane Doe 4 was there 21 occasion? 22 and saw it as well? 22 A. No. 23 A. Yes. 23 Q. Did she try to bring it up with you? 24 MR. HOROWITZ: Form. 24 A. No. 25 BY MR. CRITTON: 25 Q. Did you speak to her? 36 (Pages 294 to 297) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-59ea-4e57-9cd8-839205600fc0 EFTA01076022 Page 298 Page 300 1 A. No. 1 A. Yes. 2 Q. You saw her, but neither one of you spoke? 2 Q. Did she tell you that? 3 A. Yes. 3 A. Yes. 4 Q. With 'regard to MI, her boyfriend, do you 4 Q. What was her -- was she concerned about that? 5 know what his last name is? 5 A. She said he was going to eventually stop. 6 A. No, I do not. 6 MR. KUVIN: I'm sorry•. Is a Plaintiff 7 Did you ever know a boy that she dated named 7 in one of these cases? 8 8 I was just curious. 9 A. Yes. 9 BY MR. CRITTON: 10 Q. And how did you know M? 10 Q. When is the last — when is the last time you 11 A. I didn't know him personally. She talks about 11 had any conversation with Jane Doe 4? 12 him. They had dated for a short period of time. I'm 12 A. When I sent her a text message — text message 13 guessing this is either in between M. I can't be 13 letting her know that I knew what was going on about the 14 sure. His name came up a lot, but that's it. 14 whole lawsuit. 15 Q. Did she ever indicate to you whether while she 15 Q. Do you know anything about Jane Doe 4's home 16 was dating • she was cheating on him? 16 life? 17 A. No, she never indicated that. 17 A. Yes. 18 Q. With regard to M. do you knoW anything 18 MR-HOROWITZ: Form. Vague. 19 about him? 19 MR. CRITTON: I'm sorry? A. Hes a drug dealer. 20 MR. HOROWITZ: Vague. Her home life. What 20 21 I 21 Q. And how do you know is a drug dealer? does that mean? 22 A. I was around them both. 22 BY MR. CRITTON: 23 Q. Were you around when he was using 23 Q. You know where she lived? 24 25 illegal drugs? A. Yes. 24 25 A. Yes. Q. Okay. Do you know anything about her parents? I Page 299 Page 301 1 1 Q. And what kind of illegal drugs was he using? 1 A. Yes. 2 A. Cocaine. 2 Q. What do you know about her father? 3 Q. And at the time — and this was well after 3 MR. HOROWITZ: Vague. 4 Epstein; that is, you had — either one of you had seen 4 THE WITNESS: Crazy. Mr. Epstein? 5 BY MR. CRITTON: A. I'm sorry? 6 Q. And what do you mean, "crazy?" 7 Q. Was the time that she when she — "she," 7 A. He — when be talks, he always sniffed. And meaning, Jane Doe 4 -- started dating MI, was that 8 it used to be a joke with me and Jane Doe 4's friends after the time that she had seen Mr. Epstein? 9 until we understood that he was a drug user when he was 10 A. Yes. 10 younger. 11 Q. And when she started dating M, were you 11 Q. Do you know anything about -- as far as you 12 ever present when you saw her taking illegal drugs with 12 know though, during the time that you know him, was he a 13 13 drug user? 14 MR. HOROWITZ: Form. 14 A. I have no idea. 15 THE WITNESS: No. 15 MR. HOROWITZ: Form. 16 BY MR. CRITTON: 16 BY MI. CRITTON: 17 Q. You just saw using cocaine? 17 Q. How about her mother? 18 A. Yes. 18 A. Nice lady. 19 Q. And in terms of being a drug dealer, is 19 Q. Jane Doe 4's. What do you know about her? 20 that — did Jane Doe 4 — did you ever ask Jane Doe 4 20 A. Nice lady. 21 one way about it? 21 Q. Si Ina nice home? 22 A. Me and her had a conversation, me coming from 22 A. 23 similar situation, I tried to give her advice. And she 23 Q. Pit o? 24 didn't want to listen. 24 A. 25 Q. Was she aware that was a drug dealer? 25 Q. They live in a nice home? 37 (Pages 298 to 301) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7/032dddt-69ee-4e57-9cd8-8392056001c0 EFTA01076023 Page 302 Page 304 1 A. Yes. 1 A. Both. 2 Q. Did Jane Doe 4 have access to nice clothes and 2 Q. And in tams of Jane Doe 7 having a lot of 3 to, you know, living in a -- being able to drive around 3 boyfriends, did she have anybody that was steady or did 4 in a vehicle? 4 she go with a lot of men? 5 A. Yes. 5 A. She went with a lot of men. 6 Q. At least have access to a vehicle? 6 Q. From your observations and at least watching 7 A. Yes. 7 her -- well, let me strike that. 8 Q. Would you have considered either Jane Doe 3, 8 Prior to — well, let me strike that. 9 Jane Doe 7, or Jane Doe 4 to be underprivileged or dirt 9 At any time did you ever see Jane Doe 7 using 10 poor in any way? 10 any type of illegal drugs? 11 MR. HOROWITZ: Form. 11 MR. HOROWITZ: Fonn. 12 THE WITNESS: No, not at all. 12 THE WITNESS: Yes. 13 BY MIL CRITTON: 13 BY MR. CRITTON: 14 Q. Did Jane Doe 4 ever tell you how many times 10 Q. What type of drugs did you see her use? 15 she had been to Mr. Epstein's home? 15 A. Marijuana and Xanax. 16 A. No. 16 Q. And did you see her use those before -- let me 17 Q. Let me tum to Jane Doe 7. 17 strike that. 18 You knew Jane Doe 7 from high school? 18 When you all were in high school together, did 19 A. Yes. 19 you see her using marijuana and Xanax? 20 Q. And you met her through whom? That is, did 20 A. Yes. 21 you know Jane Doe 4 first or Jane Doe 77 21 Q. And post-high school and when were living 22 A. I knew — I knew Jane Doe 7 first, but me and 22 up north — not north — living up in did she 23 Jane Doe 4 shared a class together. 23 continue to use these illegal drugs, at least from what 24 Q. Jane Doe 7. Had you ever been to her home? 24 you observed? 25 A. Yes. 25 A. What I observed? No. Page 303 Page 305 1 Q. Nice home? 1 Q. Did she continue — let me strike that. 2 A. Yes. 2 After you were her roommate, did she continue 3 Q. Ha mother and father, what did you know about 3 to be sexually active? 4 her home life, in terms of her parents, from what you 4 A. I don't know. 5 observed? 5 Q. Did she continue to date on a regular basis? 6 A. They spoiled her. 6 A. I don't know. 7 Q. In what way? 7 Q. Did she go out -- did she go out often? 8 A. Paid for everything. She never had to work a 8 A. I don't know. 9 day in her life. They bought her cars all the time. 9 Q. Not right now. When you were roommates? 10 Paid her phone bill. Let her pretty much do anything 10 A. When we were roommates, yes. 11 she wanted. 11 Q. And did you ever observe — did you ever go 12 Q. From your observations, at least with Jane Doc 12 out with her or out with a group of friends -- 13 7, did she seem to be spoiled? 13 A. Yes. 14 A. Yes. 14 Q. — to bars? Did she appear to be, at least 15 Q. And what was Jane Doe 7 -- from your 15 during the time that you were living in she 16 observations, did Jane Doe 7 have a lot of boyfriends -- 16 appeared to date on a regular basis? 17 A. Yes. 17 A. Yes. 18 Q. -- when you knew her, again, before 18 Q. Do you know whether Jane Doe 7 -- and I don't 19 Mr. Epstein? 19 think I asked you about Jane Doe 4. Do you know whether 20 A. Yes. 20 she ever had any type of sexually transmitted dise2se? 21 Q. And, again, I think you described her as being 21 MR. HOROWITZ: Form. Come on, Bob. That's 22 as well promiscuous? 22 just not right 23 A. Yes. 23 THE WITNESS: Jane Doe 7.1 heard, but I don't 24 Q. And is that something you observed or was that 24 know. 25 her reputation at school? 25 BY MR. CRITTON: AL. 38 (Pages 302 to 305 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddr-69se-0e57.9cd8.839205600fc0 EFTA01076024 Page 306 Page 308 1 Q. Did she ever discuss it with you? 1 MR. HOROWITZ Form. Cumulative. 2 A. No. 2 BY MR. CRITTON: 3 MR. HOROWITZ: Bob. 3 Q. Is'. the only person you're aware of that 4 BY MR. CRITTON: 4 Jane Doe 7 brought to Mr. Epstein's, that is, by name? 5 Q. How about Jane Doe 7, do you know whether she 5 A. By name, yes. 6 ever had any type of — 6 Q. Did she indicate to you that she had taken 7 A We just talked about Jane Doe 7. 7 other people there? MR. HOROWITZ: Form. A. She didn't and I don't want to speculate. 9 BY MR. CRITTON: 9 Q. And I think you said that Jane Doe 4 said that 10 Q. I'm sorry. I meant Jane Doe 4. 10 she had brought at least one person there, correct? 11 A. Yes. 11 A. Yes. 12 MR. HOROWITZ: Form. 12 Q. Did either Jane Doe 7 or Jane Doe 4 tell you 13 BY MR. CRITTON: 13 what they had — well, let me strike that. 14 Q. Let me go back to Jane Doe 4. 14 Did Jane Doe 7 ever tell you what she had told 15 Did Jane Doe 4 ever tell you that she had any 15 before taking her to Mr. Epstein's? 16 type of STD? 16 A. No. 17 A. Yes. 17 Did Jane Doe 4 ever tell you what she had told 18 19 Q. What did she tell you? MR. HOROWITZ: Form. 18 19 ai before she took her to Epstein's? MS. BLANTON: You okay? You need a break? 20 THE WITNESS: She told me that gave 20 THE WITNESS: No. I'm good. 21. her HPV, which led to warts. 21 MS. BLANTON: We're getting long. 22 BY MR. CRITTON: 22 THE WITNESS: It's okay. 23 Q. And did she tell you that she was embarrassed 23 MS. BLANTON: Tell me. 24 or humiliated about that? 24 THE WITNESS: My butt is numb. 25 MR. HOROWITZ: Form. 25 MS. BLANTON: You want to stand up, walk Page 307 Page 309 1 THE WITNESS: She told me — well, she asked 1 around? You okay? 2 me politely not to mention anything, and that she 2 THE WITNESS: I'm good. 3 had gone to the gyro and had it taken care of. But 3 BY MR. CRITTON: 4 she didn't realize that had given it to 4 . Did u ever discuss Mr. Epstein with Jane Doe 5 het 5 Tat 6 BY MR. CRITTON: 6 A. Yes. Q. And I think you said — I asked you about Jane 7 Q. And did she approach you? 8 Doe 7. 8 A. Yes. 9 To your knowledge, did Jane Doe 7 ever discuss 9 Q. Or did you approach her? 10 with you whether she had an STD? 10 A. She approached me and the group I was standing 11 MR. HOROWITZ: Form. Asked and answered. 11. with. 12 THE WITNESS: Jane Doe 7 never discussed that 12 Q. And who was she with? 13 with me. 13 A. A random guy. 14 BY MR. CRITTON: 14 Q And — 15 Q. I think you said Jane Doe 7 brought someone 15 MR. CRITTON: I'm sorry? 16 named, to Mr. Epstein's home? 16 MR. HOROWITZ: Go ahead. 17 A. Yes. 17 BY MR. CRITTON: 18 Q. Did -- and how did you know that? Did Jane 18 Q. And when she approached you with this random 19 Doe 7 tell you? 19 person, were you aware that she was a Plaintiff in these 20 A. Uh-huh, yes. 20 lawsuits? 21 Q. Yes? Did Jane Doe 7 ever say, you know, my 21 A. Yes. 22 experience was so — with Mr. Epstein was so 22 Q. And did she say anything to you about the 23 inappropriate, I don't want — 1 shouldn't expose any 23 lawsuit or her being a Plaintiff and suing Mr. Epstein? 24 other person to Mr. Epstein? 24 MR. HOROWITZ: Asked and answered. 25 A. No. 25 THE WITNESS: We had discussed it, yes. 39 (Pages 306 to 309) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf•69ee.4e57.9cd8-839205600fc0 EFTA01076025 Page 310 Page 312 1 BY MR. CRITTON: 1 VIDEOORAPHER: We're back on the video record. 2 Q. AM did she ever tell you why she was bringing 2 The time is approximately 5:58 p.m. This is the 3 a lawsuit against Mr. Epstein? 3 beginning of tape number five. 4 A. She told me her parents were pushing her to. 4 REDIRECT EXAMINATION 5 Q. Did she indicate that she really didn't want 5 BY MR. KUVIN: 6 to bring the lawsuit but that her parents vivre pushing 6 Q. Are you aware that Jeffrey entered into a 7 her? 7 non-prosecution agreement with the Federal Government 8 MR. HOROWITZ: Form. 8 with respect to the claims of all the girls that came to 9 THE WITNESS: She said it wasn't her fault and 9 his house? Did anyone ever talk to you about that, 10 that her parents had really been pushing the issue. 10 other than your lawyers? 11 BY MR. CRITTON: 11 MS. BLANTON: Other than your lawyers. 12 Q. Did you ever know a person namedM.? 12 THE WITNESS: No. 13 A. Yes. 13 BY MR. KUVIN: 14 Q. Do you know whether she went to Epstein's? 14 Q. Are you aware as a part of that agreement he 15 A. She did. 15 essentially hung you out to dry, didn't put you in the 16 Q. And do you know who took her? 16 agreement? 17 A. !can't be quite sure. I don't remember. 17 MS. BLANTON: Anything you know about that 18 MR. CRITTON: I think I'm almost done. Give 18 agreement that you did not learn from your 19 me about one minute. Just look at my notes. 19 attorneys, you can discuss; otherwise, you are not 20 BY MR. CRITTON: 20 to discuss it. 21 Q. M, with regard to — I'm going to ask the 21 MR. CRITTON: Form. 22 same question with each of the three — but with regard 22 THE WITNESS: Can you repeat the question? 23 to Jane Doe 3 — Jane Doe 3, did she ever tell you that 23 BY MR. KUVIN: 24 she was sexually assaulted or battered; that is, 24 Q. Yeah. Are you aware, other than conversations 25 physically touched by Mr. Epstein? 25 with your attorneys, that Jeffrey Epstein did not get Page 311 Page 313 3. A. No. 1 immunity for you with the Federal Government when he was 2 Q. Did she ever tell you that she had suffered 2 negotiating on behalf of 3 some sort of intentional infliction of some huge or 3 Lesley Graaf (phonetics), (phonetics)? 4 severe emotional distress? 4 MR. CRITTON: Form. 5 A. No. 5 THE WITNESS: No. 6 Q. Did Jane Doe 4 ever tell you that she had been 6 BY MR. KUVIN: 7 sexually assaulted or physically battered by 7 Q. Obviously when you were going to Jeffrey's 8 Mr. Epstein? 8 house and bringing girls to him it was before December 7 9 MR. HOROWITZ: Cumulative. of 2080 — I'm sorry before October 29 of 2007, 10 THE WITNESS: No. 10 wasn't it? 11 BY MR. CRITTON: 11 A. I don't remember. 12 Q. Did Jane Doe 7 ever tell that you that they 12 Q. It was before 2007, wasn't it? 13 had been — that she had been sexually assaulted or 13 A. Oh, before 2007, yes. 14 battered or physically — 14 Q. Okay. Other than what your attorneys may have 15 ME. HOROWITZ: Cumulative. 15 told ou, arc ou aware that he negotiated for immunity 16 BY MR. CRITTON: 16 for Lesley Graaf and 17 Q. — touched by Mr. Epstein? 17 18 A. No. That's ridiculous. 18 trot. CRITTON: Form. 19 MR. CRITTON: That's all I have. Thank you, 19 THE WITNESS: No. 20 ma'am. 20 BY MR. KUVIN: 21 THE WITNESS: Can get a two-minute 21 Q. Other than your attorneys, did anyone discuss 22 break? 22 whether or not he should negotiate for immunity for you? 23 VIDEOGRAPHER: Going off the mord. This is 23 A. No. 24 the end of tape number four. The time is 5:52. 24 Q. You seem to have no problems talking about 25 (Brief recess.) 25 other girls being promiscuous, boys being promiscuous. 40 (Pages 310 to 313) PROSE *COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-69eo-4e57-9cd8.839205600Ic0 EFTA01076026 Page 314 Page 316 1 blow jobs, sex, abortions, illegal drug use, Xanax, 1 A. No. 2 marijuana, alcohol, vaginal warts, people who are 2 MR. CRITTON: Form. 3 spoiled, drug dealers, sex videos and lesbianism of 3 BY MR. KUVIN: 4 people that may be Plaintiffs in other lawsuits, as well 4 Q. When did you stop? S as you seem to have no problem talking about people that 5 MS. BLANTON: Objection. 6 may not be Plaintiffs in civil lawsuits. 6 THE WITNESS: I'm asserting my Fifth Amendment 7 As you sit here today, when did you first 7 Right 8 start having sex? 8 BY MR. KUVIN: MR. CRITION: Form. 9 Q. Okay. So you're not using them today? 10 MS. BLANTON: Objection. This was asked 10 A. Assertingmy Fifth Amendment Right. 11 previously. The objection is the same and her 11 MS. BLANTON: Objection. I'm instructing her 12 instructions not to answer that question are the 12 not to respond to any more of your questions. 13 same. 13 MR. KUVIN: Oh, we're done? 14 BY MR. KUVIN: 14 MS. BLANTON: No. With what you are doing 15 Q. So you had no problem talking about other 15 right now we are done. 16 peoples promiscuity, drug use, vaginal warts and other 16 MR. KUVIN: Okay. 17 sexual conduct, but you're not going to sit here and 17 BY MR. KUVIN: 18 tell us anything about your sexual activity; is that 18 Q. You mentioned before abortions from other 19 true? 19 girls. Have you had an abortion? 20 MS. BLANTON: You do not need to answer that. 20 MS. BLANTON: Objection. 21 You do not need to answer that. 21 THE WITNESS: I'm asserting my Fifth Amendment 22 THE WITNESS: Nope. 22 Right. 23 MS. BLANTON: Pm instructing you not to 23 MS. BLANTON: You do not -- Its not even a 24 answer that very argumentative question, if there 24 Fifth Amendment Right. It's a right to privacy. 25 is even is question in it. 25 You are not a Plaintiffor a Defendant in this Page 315 Page 317 1 BY MR. KUVIN: 1 suit. 2 Q. And you've got no problem talking about other 2 We've had these discussions earlier. It's the 3 people's drug habits, but you're still going to stand by 3 same objections. 4 a privilege objection or privacy objection as to your 4 You do not need to answer that question 5 drug use? 5 without a Court Order. 6 MS. BLANTON: With regard to drug use, I would 6 BY MR. KUVIN: 7 instruct my client to assert her Fifth. 7 Q. You talked about boys that have gotten blow 8 BY MR. KUVIN: 8 jobs that aren't Plaintiffs in lawsuits. 9 Q. Okay. So you've used marijuana before, have 9 Have you given blow jobs before when you were 10 you not? 10 14? 11 A. I'm asserting my Fifth Amendment Right 11 MS. BLANTON: Objection. You do not need to I 12 Q. You've used Xanax before, have you not? 12 answer that question. 13 A. I'm asserting my Fifth Amendment Right. 13 MR. CRITTON: Form. 14 Q. You've used cocaine before? 14 BY MR. KUVIN: 15 A. I'm asserting my Fifth Amendment Right. 15 Q. You talked about other people who had made sex 16 Q. You've used LSD before? 16 videos. Did you ever make a sex video? 17 A. Pm asserting my Fifth Amendment Right 17 MS. BLANTON: You do not need to answer that 18 Q. You've used — you used cocaine on a regular 18 question. 19 basis in the past, have you not? 19 Same objection. And it's going to be the same 20 A. I'm asserting my Fifth Amendment Right 20 objection. 21 Q. You've used Xanax on a regular basis in the 21 BY Mr. KUVIN: 22 past, have you not? 22 Q. Okay. You talked about whether'. -- I'm 23 A. I am asserting my Fifth Amendment Right. 23 sorry — whether the youngest girl that you brought 24 Q. You continue to still use Xanax, cocaine, 24 to Jeffrey, was -- seemed emotionally traumatized or 25 marijuana, and other illegal drugs, don't you? 25 upset over the incident. 41 (Pages 314 to 317) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-69ee-4057-9cd0-839205600fc0 EFTA01076027 Page 318 Page 320 1 When is the last thne you saw 1 Q. And because of the small town, what? 2 A. On the back of some kid's crotch rocket at 2 A. I lmow a lot of people. 3 Target when I was with my cousin a couple years ago, 3 Q. And all — many of them seem to be drug users 4 maybe a year ago. 4 and drug sellers? 5 Q. Crotch rocket, you mean some kind of a — 5 A. Yes. 6 A. Bike. 6 Q. As you sit idle and sort of watch them while 7 Q. fast motorcycle? 7 they use and sell drugs or do you participate -- 8 A. Yes. 8 MS. BLANTON: Do not answer that question. 9 Q. Did you talk to her? 9 BY MR. HOROWITZ: 10 A. No. 10 Q. — and partake in the drug use and sales? 11 Q. Did you have when is the last time you ever 11 MR. CRITTON: Form. 12 had any communication with her whatsoever? 12 MS. BLANTON: That question has been asked. 13 A. When she tried getting me to bring her back to 13 I've stated my full objection. Fm instructing her 14 Epstein. 14 to assert her Fifth Amendment Right. And if you 15 Q. Back when she was I4? 15 would like for her to do it again, she will. 16 A. Yes. 16 BY MR. HOROWITZ: 17 Q. So whether or not she regrets and feels bad 17 Q. Isn't it true that the people who you 18 and has emotional trauma and is upset, much like you 18 identified as drug users and drug sellers, you have 19 testified that you are, you have no idea today? 19 sold, purchased or consumed drugs with? 20 MR. CRITTON: Form. 20 MR. CRITTON: Form. 21 THE WITNESS: No idea about what? 21 MS. BLANTON: Do not answer that question. 22 BY MR. KUVIN: 22 And do not ask her another question that has 23 Q. Whether she regrets what happened back then 23 already been asked and her Amendments have been 24 when she was younger. 24 asserted to — her Fifth Amendments Rights have 25 A. No, I don't care. 25 been asserted. If you have a different question, Page 319 Page 321 1 Q. You don't really care about any of these girls 1 please move on. 2 and what they feel, do you? 2 BY MR.. HOROWITZ: 3 MS. BLANTON: Objection. 3 Q. Isn't it true that like some of the other 4 THE WITNESS: No. 4 girls you mentioned, you also slept around with 5 BY MR. KUVIN: 5 boyfriends while you were in high school? 6 Q. You could care a less whether they're 6 MS. BLANTON: Do not answer that question. It 7 emotionally traumatized or not? 7 has been asked. I've asserted my objection. A. Yes. I could care less. 8 Do you have another question — 9 MR. KIJVIN: Okay. Perfect. Thank you. 9 MR. HOROWITZ: I have many more questions. 10 That's all I got. 10 MS. BLANTON: — or else this deposition is 11 MR. CRITTON: Microphone. 11 over. 12 RECROSS EXAMINATION 12 MR. HOROWITZ: I have many more questions. 13 BY MR. HOROWffZ: 13 MS. BLANTON: Do you have one that has not 14 Q. Within your social circles when you were in 14 been asked? 15 high school, you've identified several people who were 15 MR. HOROWITZ: I have many more questions. 16 users and/or sellers of drugs, correct? 16 BY MR. HOROWITZ: 17 A. Yes. 17 Q. Isn't it true that you have had sexual 18 Q. In your examination by Mr. Epstein's attorney, 18 intercourse with Jane Doe 4? You've had sexual contact 19 do you remember telling us several people who you felt 19 with her? 20 were drug dealers or drug users? Yes? 20 MS. BLANTON: Objection. 21 A. Yes. 21 THE WITNESS: Oh, what? 22 Q. How is it that you seem to know so many drug 22 MS. BLANTON: Do not answer that question. 23 users and sellers? How is it that you come into social 23 BY MR. HOROWITZ: 24 contact with all these people? 24 Q. Isn't it true that you slept with Jane Doe 4's 25 A. s a small town. 25 boyfriend? 42 (Pages 318 to 321) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401M Electronically signed by Sandra Townsend (401 7a82dddf-59oo-4e57.9cdB-839205800fce EFTA01076028 Page 322 Page 324 1 MS. BLANTON: Do not answer the question. 1 A. I don't know. 2 THE WITNESS: I'm done. 2 Q. You have no knowledge of her going into the 3 MS. BLANTON: Do you have a question that has 3 champagne room and giving a lap dance to a grown man and not -- you don't have to say anything. 4 taking off her clothes, correct? Do you have another question that has not been 5 A. i don't know. 5 asked? 6 Q. But that, if she were to do thaL that would BY MR. HOROWITZ: 7 be something tilt promiscuous? Q. You described Mr. Epstein to his lawyer as 8 A. I don't know. 9 being a nice person; is that right? You were asked, is 9 MS. BLANTON: Object to the form. 10 he nice? And you said, yes, he's nice? 10 BY MR. HOROWITZ: 11 A. Yes. 11 Q. With regard to Jane Doe 4, other than a 12 Q. In your mind, was it nice ofMr. Epstein to 12 three-hour try out where she didn't continue to work at 13 masturbate in front ofyou when you were a child? 13 a strip club, you're not aware of her ever working at a 14 A. I don't know. I wasn't a child. 14 strip club, correct? 15 MR. CRITTON: Form. 15 A. I don't know. 16 BY MR. HOROWITZ: 16 Q. And with regard to Jane Doe 7, you have no 17 Q. When you were a 16 year old girl and 17 knowledge of her working at a strip club, correct? 18 Mr. Epstein was masturbating in front of you, exposing 18 A. I don't know. 19 his genitals, was that a nice thing ofhim to do? 19 Q. Those would be the kinds of things that 20 MR. CRITT0N: Form. 20 promiscuous girls would do, correct? 21 THE WITNESS: I don't know. 21 A. I don't know. 22 BY MR. HOROWITZ: 22 MR. CRITTON: Pam. 23 Q. You have no opinion? 23 MS. BLANTON: Object to the form. 24 A. i have no opinion. 24 BY MR. HOROWITZ: 25 Q. When Mr. Epstein had his hand on his penis, on 25 Q. You described Jane Doe 4, in your opinion, as Page 323 Page 325 1 his shaft and he's stroking it and he's coming — having 1 being not an honest person, correct? 2 orgasm, was that a nice thing ofhim to do to you? 2 A. That's true. 3 A. I don't know. • 3 Q. And if we were to ask Jane Doe 4 today whether 4 MR. CRITTON: Let me object to the form. It's 4 you were an honest person, would you agree that she 5 intimidating, It's dying to harass her. 5 would likely say that you were dishonest? 6 MS. BLANTON: Wine as well. 6 MS. BLANTON: Object to the form. You're 7 MR, CRITTON: I think it serves no purpose. 7 asking her to -- 8 BY MR. HOROWITZ: 8 MR. CRITTON: Form. 9 Q. And when you look back on it, is that a nice 9 THE WITNESS: i don't know. 10 memory that you have? 10 MS. BLANTON: — speculate. 11 MR. CRITTON: Form. 11 BY MR. HOROWITZ: 12 THE WITNESS: I don't know. 12 Q. You wouldn't be surprised if she said that you 13 MS. BLANTON: Let the record reflect that it's 13 were a liar? 14 after 6:00. You've been here for over seven hours 14 A. i wouldn't be surprised if she told me she was 15 and these questions not only serve to intimidate, 15 a raging alcoholic lesbian who loved monkeys. it would 16 harass and embarrass her, theyre very ill willed 16 not shock me. 17 and worded at this point. 17 Q. And although you described Jane Doe 4 as being 18 BY MR. HOROWITZ: 18 promiscuous for a period of years, you actually remained 19 Q. You described — you described Jane Doe 3 as 19 friends with her; is that right? 20 promiscuous? 20 A. Acquaintances. 21 A. Yes, 21 Q. More than acquaintances. You actually staged 22 Q. Now, she wasn't the kind of girl who would 22 an intervention for her benefit is that correct? 23 give lap dances at a strip club, was she? 23 MS. BLANTON: Is there a question? 24 A. I don't know. 24 THE WITNESS: I pitied her, yes. 25 Q. You have no knowledge that she did that? 25 BY MR. HOROWITZ: . 43 (Pages 322 to 325 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddr-59oo-4e57.9cd8.8392056001c0 EFTA01076029 Page 326 Page 328 1 Q. Pardon me? 1 Q. Do you have a specific recollection of her 2 A. Yes. I pitied her. 2 using drugs in the 11th grade? 3 Q. You cared for her enough you wanted to -- 3 A. Yes. 4 A. I care for any woman that gets battered by 4 Q. And in the 12th grade? 5 their boyfriend or husband, yes. 5 A. Yes. 6 Q. And you wanted her to have a better life and, 6 Q. And would you agree that her — any ding use 7 so, that's what you thought was the appropriate thing to 7 she had increased over time? 8 do? A. I don't know that. 9 A. I thought that was the appropriate thing. 9 MR. CRITTON: Form. 10 Q. So even though she had a tumultuous 10 BY MR. HOROWITZ: 11 relationship and in your mind was promiscuous and a drug 11 Q. Did the types of drugs that she used increase 12 user, you still you still were within her social 12 over time, meaning, more substantial? 13 circles, right? 13 A. No. It's the same drugs. 14 A. I still wanted to help her. 14 Q. And you described, I think, one or two 15 Q. You still went to parties with her where you 15 incidences ofher breaking up and being with other — 16 claim that she used drugs? 16 other guys when she was in break ups, right? 17 A. Not went to parties with her. 17 A. Uh-huh. 18 Q. You went to parties — you went to parties 18 Q. What grade did that take place in? 19 where you saw her and you were within close enough 19 A. Well, she was with her junior and 12th 20 proximity that you could see her purportedly using 20 grade years, so it happened then. 21 drugs, right? 21 Q. Okay. And you described — didn't you tell us 22 A. It's called, keeping order. 22 that you felt that Jane Doe 3 used drugs? 23 Q. Keeping whose order? 23 A. Jane Doe 3 did use drugs. 24 A. Keeping order. 24 Q. In what grades do you think she used drugs in? 25 Q. What does that mean? 25 I lth? 12th? Tenth? Ninth? Page 327 Page 329 1 A. I'm out in public. I'm going to be cordial 1 MR. CRITTON: Form. 2 whether I like you or not. That's just me. 2 THE WITNESS: Tenth. 3 Q. But you stayed close enough to her that you 3 BY MR. HOROWITZ: 4 could supposedly watch her use drugs? 4 Q. Okay. Any — any other grade? 5 MS. BLANTON: Asked. Answered. 5 A. I can't recall. 6 BY MR. HOROWITZ: 6 Q. And what ages do you think what grades do 7 Q. Is that right? 7 you think she was promiscuous, in your mind? 8 A. Sure, yes. 8 A. I can't recall what grade she was in. 9 Q. And not only that, you were sufficiently 9 Q. And when you describe someone as being 10 familiar with the relationship she had with her 10 promiscuous, are you comparing it to sort of your own 11 boyfriend, such that, you could see the type of 11 values and morals or — 12 tumultuous relationship that you've described to us? 12 MS. BLANTON: Object to the form. 13 A. Yes. 13 And do not answer that. 14 Q. You didn't uy and stay out ofher life; you 14 THE WITNESS: I'm not going to. 15 kept in close contact with her so that you could know 15 MR. HOROWITZ: No. I think I'm entitled to 16 the ins an outs of her relationship with her boyfriend? 16 understand her foundation, the predicate upon which 17 A. I didn't stay too close to her. 17 she's calling someone promiscuous. 18 Q. What age or what grade do you think — strike 18 BY MR. HOROWITZ: 19 that. 19 Q. And who are you comparing that to? 20 Can you have a specific recollection of Jane 20 A. I'm not comparing it to anybody. Obviously 21 Doe 4 using drugs in the ninth grade? 21 when a girl is having a threesome in a bedroom, that's 22 A. Yes. 22 promiscuous to me. 23 Q. What — do you have a specific recollection of 23 Q. And you were watching this? 24 her using drugs in the tenth grade? 24 A. I walked in on it. 25 A. I can't recall. 25 Q. And you just kind of did what? tra 44 (Pages 326 to 329) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7ancIddt-Stlee4e57-9cd81139205600fc0 EFTA01076030 Page 330 Page 332 A. Shut the door. We were at a party. 1 CERTIFICATE OF OATH 2 Q. And when you are dancing at strip dubs, do 2 STATE OF FLORIDA 3 you ever give lap dances to two men at a time? 3 COUNTY OF PALM BEACH 4 4 MS. BLANTON: Object. Do not answer. 5 5 MR. HOROWITZ: No other questions. 6 1 the undersi authority, certify that 6 MR. CRITTON: I have one question. 7 personally appeared before me and was duly 7 RECROSS EXAMINATION 8 sworn on the 10th day ofNovember, 2009. 8 BY MR. CRITTON: 9 9 Q. And Mr. Horowitz didn't want to follow up on 10 Dated this 20th day ofNovember, 2009. 10 it. But he said, he asked you what — your definition 11 11 of promiscuous. And you said, walking in or seeing 12 12 13 someone in a threesome falls within your definition of 14 13 promiscuous? 14 A. Yes. 15 &Air :tut 15 Q. Who did you see in a threesome and where were Sandra W. Townsend, Court R 16 you? 16 Notary Public - State ofFlorida 17 A. Jane Doe 3. My Commission Expires: 6t26/12 18 Q. Was with what, another girl and a guy? Two 17 My Commission No.: DO W3913 19 guys? 18 20 A. Two guys. 19 20 21 Q. Wbat was she doing? 21 22 A. I just saw her naked over the bed. That's it. 22 23 MR. CRITTON: All right That's all I have. 23 24 RECROSS EXAMINATION 24 25 BY MR. HOROWITZ: 25 Page 331 Page 333 1 Q. And what grade was she in when this supposedly 1 CERTIFICATE 2 STATE OF FLORIDA 2 took place? 3 COUNTY OE PALM BEACH 3 A. I can't recall. 4 Sandra W. Towson& Court Reporter sad 4 MR. HOROWITZ: Thank you. Notary Public in and for the State ofFlorida at Urge, 5 MR. CRITTON: You going to read? 6 do Itchy et-iffy Om the aforementioned witruna was lyy me first clay swan to testify the whale Mork that I 6 MS. BLANTON: Yes, please. 7 wall authorized to and did Itfort said doposmon 7 VIDEOGRAPHF.R: Going off the record. This is stenotype; and this the foregoing pages rumbaed 157 to 329. inclusive, aro a Int and correct hartxripion 8 the end of tape number five. The time is 6:12 p.m. of my sbonhand noies Maid deposition. 9 9 (Witness excused.) I funk( certify that said deposition was 10 (Deposition was concluded.) 10 taken at the time and place hatirtabovc set forth and that the taking of said deposition wn connanced and 11 11 completed as hereinabose set at. 12 12 I further certify Oat I am tot attorney or Camel ofany of the parties, nor am! a relative or 13 13 employee Many attorney or counsel of party emanated 14 with the action, nor am I finan.ially interested in On 14 action. 15 15 The foregoing eaufleabon of this incorript 16 does not apply to any reproduction ti the same by any 16 nails unless under die dimes cordrd and/or direction 17 of the certifying reporter. 18 17 18 19 Dated this 20th day of November, 2009 20 19 20 21 Cia2hdrAELAC/L 22 21 Sandra W. Townsend Court Reporter 23 22 24 23 24 25 25 45 (Pages 330 to 333) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7082dd669eo-4o57-9cd8-839205600fe0 EFTA01076031 fags 334 Page 336 DATE, 1 RRATA SHEET 2 TO 2 IN RE:I. VS. WISEND Go i non, Esquire 3 DEPOS ON Ot 3 MCINTOSH. SAWRAN, PELTZ & CARTAYA, P.A. 4 TAKEN. 11/10(19 1601 Fawn Place. Suite 1110 S WeC Bach, Florida 33401 6 DONDE WRITE ON TRANSCRIPT - ENTER CHANGES HERE IN RE vs. Epstein 7 PAGE LINES CHANGE REASON CASE NO.: 08CA0373 I 97000M3 AB Please take notice that on Tuesday, the 10th 8 of November, 2009, you gave your depositica in the above-referred matter At that time, you did not wain signature It is now necessity that you sign your 9 deposition_ Please all as office at the below-listed 10 10 number to schedule an appointment between the hours of 9110 a.m. and 4:30 p m., Monday through Enday, it the 11 11 Esquire office located nearest you. If you do not read and sign the deposition 12 12 within a reasonable time, the original, which has already been forwarded to the ordering attorney, may be 13 13 • filed with the Chili of the Court Byars wish to waive 14 your signature. sign your name in the blank at the 15 14 bottom ofthis letter and return it to us. 16 15 Very truly yours, 17 16 18 Please forward the original signed errata sheet to this 17 office so that copies may be distributed to all parties. 18 Sandra W. Townsend, FPR 19 PROSE COURT REPORTING AGENCY Under penally of perjury,1 declare that 1have read my 19 250S. Australian Avenue, Suite 1500 20 deposition and that it is true and correct subject to West Palm Beach, Florida 33401 20 any changes in &an or substance enteral here. 21 I do hereby waive my sigranire 21 22 22 DATE: 23 23 24 waive my signature. 24 SIGNATURE OP DEPONENT. 2S Cc Via transcript: All Counsel of Record; file copy 25 Page 335 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the 6 foregoing deposition by me given, and that the 7 statements contained herein are true and correct to the 8 best ofmy knowledge and belief, with the exception of 9 any corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2009. 14 15 16 17 18 19 20 21 22 23 24 25 46 (Pages 334 L._ PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsond (401 7a82dddf-69oe-44757-9cd8-839205600fc0 EFTA01076032