EFTA01104171

Page I UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME I OF II JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JANE DOE NO. 3 Friday, February 19, 2010 10:07 - 5:09 p.m. 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Nofary Public, State of Florida Prose Court Reporting Services Job No.: IIII EXHIBIT PROSE COURT REPORTING AGENCY, INC. EFTA01104171 Page 82 Page 84 1 any additional sworn testimony regarding Mr. Epstein 1 Q. Okay. Did you, did you, did she tell you 2 to anyone? 2 that before you ever went to Epstein's home? 3 A. No. 3 A. Yes. 4 Q. Did you ever give a handwritten report to 4 Q. Okay. And what was the occasion of her 5 anyone as to what occurred at Mr. Epstein's house, 5 telling -- her, telling you what had occurred 6 and I'm not interested again in what happened, once 6 at Epstein — or that she had been to Epstein's 7 you hired Mr. Herman? 7 hone? Do you want me to ask that again — 8 A. I don't remember. 8 A. Yes. 9 Q. At any time — well, let me ask it this 9 Q. — because I confused myself. 10 way: After you filed your — or after the Palm 10 You said that.. told you, before 11 Beach Police Department met with you, Officer 11 you first went to Mr. Epstein's house which you 12 Recarey met with you, did you ever discuss that 12 described as being approximately in June of '04, 13 ' that is the conversation you had with them 13 that she had been to Epstein's home; is that 14 with , that is this is what they asked me; 14 correct? 15 what did they ask you? 15 A. Yes. 16 A. What? 16 Q. Okay. And, and what was the occasion of 17 Q. You said.. was around you at the 17 her telling you, that is how did it come about that 18 dine - 18 she told you she had been to Epstein's home? 19 A. Yes. 19 A. How did she ten me? 20 Q. — when the Palm Beach Police Department 20 Q. No. What was the occasion? Where were 21 came' correct? 23. you and how did you — how did the subject come up? 22 A. Yes. 22 A. asked me if I wanted to do it. 23 Q. Okay. After — did they interview her as 23 Q. SAM meaning 24 well the same day? 24 A. 25 A. No. 25 Q. And where were you-all at the time? Page 83 Page 1 Q. Okay. Do you know whether she ever went 1 A. At a girlfriend's house. 2 to Epstein's? 2 Q. Whose house were you at? 3 A. Yes. 3 A. Jane Doe No. 4's. 4 Q. Okay. And how, how did you know that? 4 Q. Jane Doe No. 4 who? 5 A. She told me. 5 A. Doe No. 4. 6 Q. Okay. Did she tell you before the police 6 Q. And how did you know Jane Doe No. 4? 7 A. I gew up with her in MI I went to 7 department ever contacted you? 8 A. Yes. 8 school with her. 9 Q. Okay. And did you know.. -- was she 9 Q. Same grade? 10 one of your good friends at the time? 10 A. No. 11 A. Yes. 11 Q. Older; younger? 12 Q. Okay. She's still a good friend? 12 at Older. 13 A. Yes. 13 Q. How much older? 14 Q. Okay. Do you know whether she's a 14 A. A year. 15 plaintiff or has ever filed any type of claim? 15 MR. MERMELSTEIN; Just to be dear, your 16 A. I don't know. 16 question as to who was older, her or Jane Doe 17 Q. Okay. Did you ever tell her that you had 17 Na 4? 18 filed a claim? 18 BY MR. CRITTON: 19 A. No. 19 Q. I'm assuming you meant Jane Doe No. 4 was 20 Q. She just knows that you went to Epstein's 20 a year older than you. 21 home? 21 A. Yes, sir. 22 A. Yes. 22 MR. CRITTON: I think it was just you. 23 Q. Okay. Did she ever tell you what happened 23 MR. MERMELSTEN: I'm the only one that 24 at Epstein's home? 24 was confused, right? 25 A. Yes. 25 MR. CRITFON: Yeah 22 (Pages 82 to 85) PROSE COURT REPORTING AGENCY, INC. EFTA01104172 Page 86 Page 88 1 BY MR. CRITTON: 1 A. Don't know exactly where I was. I deal 2 Q. And Jane Doe No. 4, is she from pretty 2 remember. She told me that she gave a massage to 3 much a middle class family as well? 3 Jeffrey for $200. 4 A. Yes. 4 Q. Did she tell you how many times she'd done 5 Q. All right. AM Jane Doe No.4 is the one, 5 it? 6 she's a soccer player, wasn't she? 6 A. No. 7 A. Yes. 7 Q. Did you ask her about Jeffrey? 8 Q. And did you and Jane Doe No. 4 — well, 8 A. No. 9 let me stile that. 9 Q. Did you say, what are you doing giving 10 Let's see, if you went in 10 did she tell you how old Jeffrey was? 1.1 approximately June of'04, approximately when did 11 A. No. 12 this conversation take place, how many months before 12 Q. Okay. Had you ever heard — or let me 13 you ultimately went? 13 strike that. 14 A. What conversation? 14 At the time that., mentioned that, 15 Q. Well, you said theta asked you, if I 15 first mentioned to you that she had given a guy 16 understood you, asked you if you wanted to go? 16 named Jeffrey a massage for $200, had you, had.. 17 A. Yes. 17 ever talked to you at all? 18 Q. Okay. Is that the first time.' had 18 A. Yes. 19 ever brought it up to you? 19 Q. And had talked to you a number of 20 A. No. 20 months before you eventually went to Mr. Epstein's 21 Q. So, at least at the time that 23. home; is that correct? 22 brought up going to Mr. Epstein's house or going 22 A. Yes. 23 to did you know his name was Epstein at that 23 Or to Jeffreys home. Where were you when 24 time? 24 first said something to you about 25 A. Jeffrey. 25 Jeffrey? Page 87 Page 89 1 Q. Just Jeffrey. All right. When she said, A. Jane Doe No. 4's house. 2 she asked you, apparently again, if you were 2 Q. Okay. AM who was there at the time, you, 3 interested in going to Mr. — to, to Jeffrey's house 3 Jane Doe No.4, ; anyone else? 4 to give him a massage, at least on this occasion 4 A. Nope. 5 Jane Doe No. 4 — you were at Jane Doe No. 4's 5 Q. And how many months was this prior to your 6 house, and.. was there 6 ultimately going to Jeffreys home? 7 A. No. 7 A. I don't remember. B Q. — as well as..? Is that wrong? Q. Four months, six months? 9 A. That is wrong. 9 A. I don't remember. 10 Q. Okay. Then let me ask a question. 10 Q. A number of months? 11 thought you — had you learned that II., had, 11 A. I really don t remember. 12 had been at Jeffrey's house sometime before this 12 Q. You don't know whether it was a day or a 13 conversation? 13 number of months? 14 A. Yes. 14 MR. MERMELSTE1N: Objection. She's 15 Q. By "this conversation," I mean when 15 answered the question. 16 asked you, you were at Jane Doe No. 4's house. 16 THE WITNESS: I don't remember. 1, I 17 A. Yes. 17 don't remember. 18 Q. How much earlier was the conversation 18 BY MR. CRITTON: 19 where told you she had been to Jeffrey's house? 19 Q. I just want you to make sure, because I 20 A. A lot earlier. 20 want to make sure that the ladies and gentlemen 21 Q. A number of months? 21 understand. 22 A. Probably, yeah. 22 So, the first conversation where 23 Q. And when • told you that, what did she 23 ever referenced going to JeffieStouse, you were at Jane Doe No. 4 home, you, MI and Jane Doe 24 tell you; that is what were the circumstances of her 24 innanis Who was there? Where were2 ou? „...... 25 No. 4 were the onlyczle there, correct? 23 (Pages 86 to 89) PROSE COURT REPORTING AGENCY, INC. EFTA01104173 Page 90 Page 92 1 A. Correct. 1 Q. Ever done it with a, with a guy? 2 Q. And then we know you went to Mr. Epstein's 2 A. No. 3 borne, or at least by your testimony, sometime in 3 Q. A boyfriend? June of '04; is that correct? 4 A. No. 5 A. Yes. 5 Q. Did Jane Doe No. 4 say anything at that 6 Q. So, and is it your testimony as to when 6 time when asked you? 7 this conversation first took place, where 7 A. Excuse me. I don't remember. 8 asked you if you wanted to go to Jeffrey's home, you 8 Q. Did you know that Jane Doe No. 4 had 9 don't recall whether that was a week before you 9 gone — 10 ultimately went or months; is that correct? 10 A. No. 11 A. Correct. 11 Q. — to Epstein's home at that time? 12 Q. What did say to you the first 12 A. No. 13 occasion at Jane Doe No. 4's home? 13 Q. Okay. At some point she told you, didn't 14 A. Excuse me. You can make quick money, 200 14 she? 15 bucks just to give a guy a massage. 15 A. She didn't tell me, no. 16 Q. And did she tell you about who the guy 16 Q. At some point did you come to team that 17 was? 17 Jane Doe No. 4 had been to Mr. Epstein's home? 18 A. Yeah, his name is Jeffrey Epstein. 18 A. Yes. 19 Q. And she said Epstein? 19 Q. Okay. From whom did you learn that fact? 20 A. Yes. 20 A. Word ofmouth. 21 Q. Okay. And did she tell you where he 21. Q. When you say, "word of mouth," meaning 22 lived? 22 what, it was just common knowledge? 23 A. On Palm Beach. 23 A. We all hung out together. 24 Q. I assume you'd been to Palm Beach before. 24 Q. So, at some point somebody mentioned that 25 A. Yes. 25 Jane Doe No. 4 had been to Epstein's house? Page 91 Page 93 1 Q. And did she tell you anything about it, 1 A. Yes. 2 that is, his age, what he did? 2 Q. Did you ever ask Jane Doe No. 4, say, hey, 3 A. No. 3 how many times have you been to Epstein's house? 4 Q. Did she tell you anything about how old he 4 A. No. 5 was, that is, whether he was your age, whether he 5 Q. Okay. Did — when the word ofmouth that 6 was an older person? 6 Jane Doe No.4 had been to Mr. Epstein's house, was 7 A. No. 7 that kind of discussed when you guys would get 8 Q. Did you ask? 8 together, that is, who had been to Epstein's house? 9 A. I don't remember. 9 A. Can you repeat that, please? 10 Q. Did, did you say, wait a minute, why 10 Q. Sure. You said you learned that Jane Doe 11 would — well, let me strike that. 11 No. 4 had gone to Mr. Epstein's house by word of 12 Did she,M. say that she had been 12 mouth be you were all friends. 13 there? 13 A. Yes. 14 A. Yes. 14 Q. Okay. And somebody brought it up, but you 15 Q. Did she say that she'd given him a massage 15 can't identify who the person is that brought it up. 16 before? 16 A. Yes. 17 A. No. 17 Q. Okay. And did you team from at least a 18 Q. Okay. Did you say, why are you asking me 18 these conversations, before you ever went to 19 if I would be interested in going? 19 Mr. Epstein's house, that Jane Doe No. 4 had been 20 A. I don't remember. 20 there on many occasions? 21 Q. Okay. Had you ever given a person a 21 A. No, I did not know that. 22 massage before, before that period of time? 22 Q. Okay. Did you — you knew for sure she'd 23 A. Yes. 23 been there once, but you didn't know how many times 24 Q. Okay. To whom had you given a massage? 24 she'd been there? 25 A. My mom, my cousin. 25 A. Correct. 24 (Pages 90 to 93) PROSE COURT REPORTING AGENCY, INC. EFTA01104174 Page 102 Page 104 1 Q. All right. And how much longer did you, 1 friends? 2 the two of you continue to date? 2 A. Excuse me. Yes, me and Jane Doe No. 4 were 3 A. Maybe about two years, a year and a half. 3 good friends, yes. 4 Q. Two years after that? 4 Q. Are you and Jane Doe No. 4 still good 5 A. Yes. 5 friends? 6 Q. So you dated.. about a year, a year to 6 A. No. 7 ayes' and a half before you had this conversation 7 Q. Okay. When did you, you and Jane Doe 8 about giving a massage to Mr. Epstein, and then you 8 No.4 stop being good friends? 9 dated another two years after that? 9 A. When she went lit 10 A. About a year after that. 10 Q. When she went t 11 Q. Okay. 11 A. Yes. 12 A. Yeah. 12 Q. Do you know whether Jane Doe No. 4 is a 13 Q. All tight. So how much time transpired or 13 plaintiff in a lawsuit against Mr. Epstein? 14 passed before you then had a conversation with — 14 A. I don't know. 15 another conversation about the possibility of giving 15 Q. Okay. Do you know if I -- do you know 16 a massage to Jeffrey? 16 whether your current lawyer is representing Ms. Doe 17 A. 'have no idea. 17 No.4? 18 Q. Was ft a month, a week, a year, two years? 18 A. Yes. 19 A. Awhile. 19 Q. Okay. How do you know that? 20 Q. Was it after then? 20 A. Because I've spoken with her. 21 A. I was already broken up with.. 21 Q. With Jane Doe No. 4? 22 Q. All right. So it had to have been about a 22 A. (Witness nods head.) 23 year later. A year — 23 Q. Okay. And so — 24 A. Me and him were on and off. We didn't have a 24 11133 COURT REPORTER: Is that a yes? 25 steady relationship. 25 IHE WITNESS: Yes. Yes, sony. Page 103 Page 105 1 Q. So now yout ves dating or 1 BY MR. CRITTON: 2 you're on and off with at this point in time? 2 Q. Okay. And she told you — when did you 3 A. Yes. 3 last speak with Jane Doe No. 4? 4 Q. And what happens? How does the topic come 4 A. A couple of days ago. 5 up again? 5 Q. All right. 6 A. I was approached again bylM. 6 A. I need to take a break, please. 7 Q. Where were you at the time? 7 Q. Can I have two more minutes? 8 A. I don't remember. 8 A. No, I'm tired. I leed to take a break, 9 Q. Do you remember who was then? 9 please. 10 A. I don't remember. 10 MR. CRITTCK All right 11 Q. How often — were you and good 11 THE VIDEOGRAPHER: We're going off the 12 friends? 12 record at 11:43 a.m. 13 A. No. 13 (A brief recess was held.) 14 Q. Were you friends? 14 THE VIDEOGRAPHER: We're back on the 15 A. Yes. 15 record at 11:57 a.m. 16 Q. Okay. More acquaintance-type friends? 16 BY MR. CRITTON: 17 A. Yes. 17 Q. We were talking about Jane Doe No. 4, and 18 Q Okay. Was she good friends with Jane Doe 18 you said that you spoke with her a couple of days 19 No.4. Were she and Jane Doe No. 4 good friends? 19 ago. 20 A. I don't 'mow their relationship. 20 A. Yes. 21 Q. Okay. Well, at least the fast time 21 Q. How long have you known that Jane Doe 22 when -- that you're at Jane Doe No. 4's house when 22 No. 4 is a plaintiff against Mr. Epstein? 23 mentioned to you, do you, were you interested 23 A. A little while. 24 in making — giving a massage to Jeffrey, there was 24 Q. What's a little while mean to you, a 25 only the three of you. So were any of you good 25 month, a week, a yea/7_ 27 (Pages 102 to 105) PROSE COURT REPORTING AGENCY, INC. EFTA01104175 Page 90 Page 92 1 A. Correct. 1 Q. Ever done it with a, with a guy? 2 Q. And then we know you went to Mr. Epstein's 2 A. No. 3 home, or at least by your testimony, sometime in 3 Q. A boyfriend? 4 June of '04; is that correct? 4 A. No. 5 7 A. Yes. Q. So, and is it your testimony as this conversation first took place, when a 5 6 7 Q. Did t Doe No. 4 say anything at that time where asked you? A. Excuse me. I don't remember. 8 asked you if you wanted to go to Jeffrey's home, you 8 Q. Did you know that Jane Doe No. 4 had 9 don't recall whether that was a week before you 10 ultimately went or months; is that correct? 10 A. No. 11 A. Correct. 11 Q. — to Epstein's home at that time? 12 Q. What di.. say to you the first 12 A. No. 13 occasion at Jane Doe No. 4's home? 13 Q. Okay. At some point she told you, didn't 14 A. Excuse me. You can make quick money, 200 14 she? 15 lucks just to give a guy a massage. 15 A. She didn't tell me, no. 16 Q. And did she tell you about who the guy 16 Q. At some point did you come to learn that 17 was? 17 Jane Doe No. 4 had been to Mr. Epstein's home? 18 A. Yeah, his name is Jeffrey Epstein. 18 A. Yes. 19 Q. And she said Epstein? 19 Q. Okay. From whom did you learn that fact? 20 A. Yes. 20 A. Word of mouth. 21 Q. Okay. And did she tell you where he 21 Q. When you say, "word of mouth," meaning 22 lived? 22 what, it was just common knowledge? 23 A On Palm Beach. 23 A. We all hung out together. 24 Q. I assume you'd been to Palm Beach before. 24 Q. So, at some point somebody mentioned that 25 A. Yes. 25 Jane Doe No. 4 had been to Epstein's house? Page Page 93 1 Q. And did she tell you anything about it, 1 A. Yes. 2 that is, his age, what he did? 2 Q. Did you ever ask Jane Doe No. 4, say, hey, 3 A. No. 3 how many times have you been to Epstein's house? 4 Q. Did she tell you anything about how old he 4 A. No. 5 was, that is, whether he was your age, whether he 5 Q. Okay. Did -- when the word of mouth that 6 was an older person? 6 Jane Doe No. 4 had been to Mr. Epstein's house, was 7 A. No. 7 that kind of diqmosed when you guys would get 8 Q. Did you ask? 8 together, that is, who had been to Epstein's house? 9 A. I don't remember. 9 A. Can you repeat that, please? 10 Q. Did, did you say, wait a minute, why 10 Q. Sure. You said you learned that Jane Doe 11 would — well, let mE rike that. 11 No.4 had gone to Mr. Epstein's house by word of 12 Did she,MR, say that she had been 12 mouth because you were all friends. 13 there? 13 A. Yes. 14 A. Yes. 14 Q. Okay. And somebody brought it up, but you 15 Q. Did she say that she'd given him a massage 15 can't identify who the person is that brought it up. 16 before? 16 A. Yes. 17 A. No. 17 Q. Okay. And did you learn from at least 18 Q. Okay. Did you say, why are you asking me 18 these conversations, before you ever went to 19 if I would be interested in going? 19 Mr. Epstein's house, that Jane Doe No. 4 had been 20 A. I don't remember. 20 there on many occasions? 21 Q. Okay. Had you ever given a person a 21 A. No, I did not know that. 22 massage before, before that period of time? 22 Q. Okay. Did you — you knew for sure she'd 23 A. Yes. 23 been there once, but you didn't know how many times 24 Q. Okay. To whom had you given a massage? 24 she'd been there? 25 A. My mom, my cousin. 25 A. Correct. aoaata- ekrikgeWAX•Stsfause... face.140-•— 24 (Pages 90 to 93) PROSE COURT REPORTING AGENCY, INC. EFTA01104176 Page 94 Page 96 Q. Okay. Did, did you at some point get the 1 A Not that I remember, no. Okay. Well, did you say, did you say to 2 3 4 drift — not the drift — did you, did you come to at least understand, based on the conversations that were going on before you ever went to Mr. Epstein's, 2 3 4 MI as well, what do I have to do for $200? A. Yes. 5 that she had been there a number of times? 5 Q. Okay. And what did she say? 6 A. No. 6 A. A massage. 7 Q. Just that she had been there? 7 Q. Okay. Did you say, what's the massage 8 A. Correct. 8 consist of? 9 Q. All right. But you understood that she A. I did not say that. 10 had also gone to Epstein's to give him a massage? 10 Q. Okay. Did you say, how long does it have 11 A. Correct 11 to last? 12 Q. Who else did you lean other thanMI 12 A. Yes. 13 and Jane Doe No. 4, at least on the first occasion, 13 Q. And what did she say? 14 did you learn or know that had given Mr. Epstein a 14 A. Half an hour. 15 massage, or purport had given him a massage? 15 Q. All right. And did she tell you where 16 A. I didn't know given, has given Epstein a 16 you'd have to go? 17 massage. 17 A. Yes. 18 Q. You just }mew that she asked you if you 18 Q. Did you say, well, who's going to go there 19 would be interested? 19 with me? 20 A. Yes. 20 A. Yes. 21 Q. Okay. And did you ask her at that time, 21 Q. All right. And she said? 22 say, did you give — have you ever given him a 22 A. She would. 23 massage? 23 Q. All right And did she say — did you 24 A. No. 24 discuss how you were to get there? 25 Q. Okay. At the time she asked — first 25 A. She already said she would drive. Page 95 Page 97 1 asked you, when you were at Jane Doe No. 4's house, 1 Q. Okay. And what, what in, at least in your 2 what was your response? 2 thinking process at that time would cause you even 3 A. I don't know; I'll have to think about it. 3 to Nththat you might have some interest in doing 4 Q. Okay. What questions did you ask before 4 that, that is, going to give some unknown person, 5 you even said, I don't know; TR have to think 5 unknown to you, at their home a half-hour massage 6 about it? 6 for 200 bucks? 7 A. What happens? 7 M.R. MERMELSTEN: Objection to form. 8 Q. Did you — and what did she say? 8 THE WITNESS: Can you repeat that? 9 A. You give him a massage. 9 MR. CRITTON: No, but Cindy can. Cindy 10 Q. Okay. And what did you say, well, I have 10 will. She can and will. 11 never really given --1have never given a man a 11 THE WITNESS: Okay. 12 massage, did you tell her that? 12 (The requested portion of the record was 13 A. No. 13 read by the reporter.) 14 Q. And have you ever given a boyfriend a 14 THE WITNESS: So you want to know my 15 massage, did I ask you that? 15 interest? 16 A. You did ask me that. 16 BY MR. CRITTON: 17 Q. Okay. You were, you were — had, already 17 Q. Yeah, why, why — why you, who is 18 at that point in your time, 2004, had had 18 apparently about 16 at the time would have any 19 relationships with other males, true? 19 interest in giving a massage to some unknown male 20 A. Yes. 20 that you had never met, a half-hour massage which 21 Q. Okay. And you were sexually active at 21 you didn't know what it consisted of, for 200 bucks? 22 that point in time, true? 22 A. I was young and it was $7.00. 23 A. Yes. 23 Q. And if I understood your earlier 24 Q. All right And you had never given a male 24 testimony, you didn't say, well,Et have you 25 a massage? 25 dame it? 25 (Pages 94 to 97) PROSE COURT REPORTING AGENCY, INC. EFTA01104177 Page 214 Page 216 anything improper or otherwise. 1 after your 17th birthday. You just don't remember? 2 Is there — what, if anything, has caused 2 A. I first visited Jeffrey, like I stated before, • 3 you now that we have finished about an hour or 3 soon after I turned 16. 4 45-minute lunch break that maybe June of'04 was not 4 Q. Okay. But we established just by simple 5 the right date, approximately, that you went to 5 math — 6 Mr. Epstein's home for the first time? 6 A. I'm not a math genius. 7 A. Okay. 7 Q. None ails arc, that's why we Gan I. 8 THE VIDEOGRAPHER: You're fine. 8 if l add 16 to MI because you were born in M. M. 9 THE WITNESS: Okay. Just thinking about 9 that takes me to 2004, Mardi of 2004. Ail rig t:. 10 it, like, I don't want, I don't want to matte 10 I'm not hying to be tricky here. I'm hying to • 11 exact dates and may be wrong. 11 would you agree with me, 16 and IN is 12 BY MR. CRITTON: 12 A. Sixteen, yes. 13 Q. Could it have been *05? 13 Q. All right. So if it MS Sal/clime after 14 A. It could have been, yes. 14 that, then it had to have been in '04, or do you 15 Q. Would it have been before your birthday in 15 want to say it still could have been '05? 16 '05 for the first time, or could it have been 16 A. 'still say it was alter I was 16. 17 afterwards? 17 Q. Okay. And it still could, could have been 18 A. After, I think. 18 in '04; it could have been in 'OS. You're just not 19 Q. Okay. 19 sure? 20 A. I don't know. 20 A. Correct 21 Q. So all you know is that you went to 21 Q. All right. Okay. So let's just stick with 22 Mr. Epstein's home four times. It could have 22 the first Umiak& So they — I know you, you 23 started in '05. It could have started in '04. You 23 told us that =asked if you wanted to go. You 24 just can't tell us as you sit here today? 24 were with Jane Doe No. 4 only. You were at Jane Doe 25 A. Right, I can't tell you exact dates. 25 No. 4's house, just the three of you. You said Page 215 Page 217 1 Q. Okay. And you can't tell us — I mean, 1 you'd think alugatiaiwient back. You talked 2 there's nothing about — well, there, there was. 2 about it with IMeho was your boyfriend 3 You said that one of the visits you had you 3 at that time. He basically said, he discouraged 4 remembered seeing a — some sort of Christmas 4 you, as you described earlier, comet? 5 decoration. 5 A. Yes. 6 A. Correct. 6 . Then sometime later there, now you i 7 Q. Okay. And instead of being in 7 and were either between, either weren't dating 8 December-ish of'04, assuming that's when Christmas 8 anymore or you were — I think you said yigialaren't 9 decorations come out, it could have been as well 9 dating anymore, so somebody — was that Mlagain 10 December of '05. Is that possible? 10 asked you then again? 11 A. I don't know. 11 A. Yes 12 Q. Well, Pm asking you, is that possible, it 12 Okay. And where were you at the time 13 could have been December of '05 as distinct from 13 =asked you? 14 December of'04, or you just don't know one way or 14 A. I don't remember. 15 the other? 15 Q. All right. And when she asked you, do you 16 A. I just know that it was around Christmas one 16 remember whether anyone else was there at the time? 17 of the times. 17 A. I don't remember. 18 Q. But you can't tell me whether it was '04 18 Q. And did — what did she say to you? 19 or '05? 19 A. Do you want to make 5200 and give a guy a 20 A. Correct. 20 massage, or Jeffrey a massage. 21 Q. Because you don't remember when the first 21 Q. And you said — did you say something 22 time was? 22 like, we talked about this before, I said, no? 23 A. Correct. 23 A. No. 24 Q. And that could have been sometime in — 24 Q. Okay. What did you say this time? 25 after your 16th birthday. Could have even been 25 A. I'll call you back. nit get back toyou, 10 (Pages 214 to 217) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins dalled07-Otte4c7a-95e1-dadtiebkf35 EFTA01104178 Page 218 Page 220 something along that line. 1 that you had had. She had set it up and she said, Q. And what happened then? 2 okay, we're going to go at such-and-such a time. 3 A. I agreed to do so and she set it up. 3 And that's all she had said to you at least up until 4 Q. Did you, did you call her or did she call 4 the time that she picked you up? 5 you or did you just see her again? 5 A. Cared. 6 A. She initiated it 6 Q. Okay. That is the phone conversations, 7 Q. Okay. What, she called you or did she see 7 that is the in-person conversations, time one, when 8 you? 8 you decided no; the second time you said, I'll think A. She called sm. 9 about it the third time is you called her back and 10 Q. Okay. And is, and as far as you, you were 10 said, it's okay,FIldo it; and the fourth time is, 11 concerned is that at least you were going to go 11 she said — she calkd you back and said, okay, l 12 there, give this Jeffrey chap a massage, and that 12 set it up for such-and-such a time and I'll pick you 13 was the extent of the conversation? 13 up at such-and-such a time. Is that substantially 14 A. At first, yes. 14 correct, or correct? 15 Q. When you say "at first," you mean at 15 A. She asked me the first time. I had spoken 16 least, at least from the first time she told you — 16 with my boyfriend, so no. And then she asked me the 17 A. Yes. 17 second time, I told her rd to think about it. I agreed 18 Q. — the second time? 18 to it, she set it up. 19 A. Yes. 19 Q. Okay. So second time you did — I thought 20 Q. Okay. And even when she spoke to you on 20 you said you, you told her you'd think about it. 21 the phone, she basically said — or let me say it, 21. A. I said I would think about it, and that I 22 the first time she asked you if you want, you were, 22 agreed to it. 23 when you were at Jane Doe No. 4's house, if you 23 Q. The same — 24 wanted to go give this — give Jeffrey a massage for 24 A. The second time. 25 200 bucks, that was the extent of the conversation, 25 Q. Right there at the second occasion that Page 219 Page 221 1 correct? 1 she mentioned it to you? 2 A. Yes. 2 A. Right 3 Q. Okay. The second time that she mentioned 3 Q. You didn't call her back? You said -- 4 it, again, it was pretty similar as it was give this 4 A. No, I — 5 Jeffrey chap a massage, 200 bucks? 5 Q. You thought about it right then and there? 6 A. Yes. 6 A. No, I called her back. 7 Q. If you want to do it. And you said, I'll 7 Q. Okay. That's what rm getting at. 8 think about it? 8 A. Yes. 9 A. Yes. 9 Q. And you called her back and said this was 10 Q. You called her back and said, rit do it? 10 what, a two, a ten-second conversation, and said, 11 A. Yes. 11 okay, ru do it? 12 Q. Okay. And then she said, okay, P11 let 12 A. Then she said she'll -- 13 you know? 13 Q. Yes? First of all, is that yes? 14 A. Shell set it up. 14 A. Yet 15 Q. All right And so at least at that time, 15 Q. It was like a second ten-second 16 when you talked to her on the phone and she then 16 conversation? 17 called you back and set it up, as far as you were 17 A. Yes. 18 concerned at that time you were going to give a 18 Q. And then she called you back for another 19 half-hour massage for 200 bucks? 19 ten-second conversation that said, okay, I have set 20 A. Yes. 20 it up for such-and-such a time, and I'll pick you 21 Q. And that was the extent of the 21 up? 22 conversation or, at least, the two conversations and 22 A. Yes. 23 the two phone calls that you two had had? 23 Q. Okay. And that was the extent of the 24 A. At that — what do you mean? 24 conversation, just basically a scheduling issue? 25 0. That was the extent of the conversations 25 A. Correct 11 (Pages 218 to 221) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hooking Electronically signed by cynthia hopkins da88od07-Occo-4c7a-95ol.d4dVlob3cf36 Electronically signed by Cynthia hopkins EFTA01104179 Page I 4 2 Page 144 1 THE WrINESS: Could you restate that? 1 BY MR. CM-TON: 2 BY MR. CRITTON: 2 Q. Because if any of those four people, li ad 3 Q. Sure. You said before you went to 3 Jane Doe No. 4, Jane Doe No. 7 or 4 r or.n.tein's the first time, you learned or heard 4 said anything that would have caused you any 5 that she and Mr. Epstein had gotten into a 5 concern, would it be a correct statement you, more 6 disagreement, correct? 6 likely than not, would not have gone? 7 A. Yes. 7 MR. MERMELSIE1N: Objection to form. 8 Q. Okay. Did you ask her what the nature of 8 THE WITNESS: Yeah. 9 the disagreement was? Because you wouldn't want to 9 BY MR. CRITTON: 10 go to someplace where you might have a disagreement, 10 Q. All right. Because they were friends of 11 right? 11 yours? 12 A. Coned. 12 A. Yes. 13 Q. All right. And what did she say to you 13 Q. All right. And if something bad had 14 when you asked her? 14 happened or something inappropriate had happened, at 15 A. She said that it was in regards to her, her 15 least from their perspective you would have expected 16 not getting paid. 16 them to tell you that, wouldn't you? 17 Q. She didn't get money or — 17 A. Yes, I did. 18 A. Correct. 18 Q. All right. And none of those four friends 19 Q. — it was either she didn't get paid or 19 of yours told you anything or disclosed anything to 20 didn't get the right amount? 20 you that caused you any concern; is that correct? 21 A. She didn't get — that she wasn't going to get 21 A. Correct 22 paid. 22 Q. And if you felt that they had misled you 23 Q. Okay. Did she tell you why she wasn't 23 in any way, you would have been angry with them, 24 going to get paid? 24 wouldn't you? 25 A. Something to do with a question that he had 25 A. Yes. Page 143 Page 145 1 asked her, and she just — !guess she didn't like it 1 Q. After you came back from Mr. Epstein's the 2 and they got into a little disagreement 2 first time, did you ever talk with Jane Doe No. 4, 3 Q. Okay. And did you, did you then think to 3 that is shortly after you were there the first time, 4 yourself as, gee, you know, I could go over them, 4 about what had occurred? 5 give a massage and not . .paid because I could get 5 A. No. 6 into a disagreement like did, or did she make 6 Q. All right. Did you ever suggest to her 7 it out like it was really no big deal? 7 that she had in any way misled you or lied to you or B A. She made it seem like it was not a big major 8 deceived you — 9 concern. A. No. 10 Q. Okay. And Jane Doe No. 4, what did Jane 10 Q. — about her experiences with Mr. Epstein? 11 Doe No. 4 did she ever indicate that you should 11 A. No. 12 have any hesitation going over to Mr. Epstein's 12 Q. Did you ever say anything within a short 13 home? 13 period — and a short period could be a day, it 14 A. No. 14 could be a week, it could be a month, it could be 15 Q. All right. And ME, did she ever 15 six months. Did you ever talk with M.and tell 16 indicate to you that you should hesitate to go over 16 her what had occurred at Mr. EpsteiWi? 17 to Mr. Epstein's home? 17 A. I don't remember. 18 A. Not really, no. 18 Q. Okay. Did you ever express anger with her 19 Q. Okay. So had Jane Doe Na 4, Jane Doe 19 or, or did you ever tell her that she had in some 20 No. 7, M. and ME who all, at least from your 20 way deceived you or misled you? 21 perspective, led you to believe that your going to 21 A. No. 22 Mr. Epstein's home was not a problem, no big deal, 22 Q. Or lied to you? 23 safe, true? 23 A. No. 24 A. True. 24 Q. Okay. Within a short period of time 25 MR. fvfERMELSTEIN: Objection to form. 25 again, you know, a day to six months, did ou ever 37 (Pages 142 to 145) PROSE COURT REPORTING AGENCY, INC. EFTA01104180 Page 222 Page 224 1 Q. All right. You've never spoken with 1 Q. AliridtDdyOUever 2 Mr. Epstein or anyone who works on his behalf by 2 before did come to pick you up that day, 3 phone, have you? 3 whatever the first day is you went to Mr. Epstein's 4 A. No. 4 house? S Q. Okay. Mr. Epstein or anyone on his behalf 5 A. She picked me up, yes. 6 has never twitted you, have they? 6 Q. Okay. And when she picked you up, was it 7 A. No. 7 in her cat? 8 Q. Okay. Has anyone, has either Mr. Epstein 8 A. Yes. 9 or anyone on his behalf corresponded with you or 9 Q. Do you remember what kind of car she had? 10 communicated with you by way of e-mail or over the 10 A. It was a truck. 11 computer? 11 Q. Okay. 12 A. No. 12 A. A maroon truck. 13 Q. Okay. Has Mr. Epstein or anyone on his 13 Q. All right. And when she before you got 14 behalf ever communicated with you by text messages 14 in the truck, did you look in and say well, let 15 or any other type of, you know, electronic 15 me ask you this: What did you have on? Mot were 16 communication? 16 you wearing? 17 A. No. 17 A. A skirt and a shirt. 18 Q. sikAght. So, all right. First time you 18 Q. And under that you had your bra and your 19 turned down. Second time you said you'd think 19 boy shorts? 20 about it. I think you told me in the interim you 20 A. Yet 21 had, you'd known — you had known that Jane Doe No. 21 Q. All right. And what did the sldrt look 22 4 had been there. Isu knew Jane Doe No. 7 had been 22 like? 23 thereS know. had been there. And you knew 23 A. Like a jean sldrt. 24 that had been there, but you didn't know if 24 Q. Short, long? 25 she had done anything, ever given a massage; is that 25 A. Yeah, fingertip length. Page 223 Page 225 1 correct? 1 Q. Okay. And your shirt? 3 4 2 A. Yes. Q. All right. But you how that s, Jane Doe No. 7 had been there, and Jane Doe No. 4 had 2 3 4 a- A. I don't remember what shirt I was wearing. Q. Lace a tank top or a crop top, or was it 5 been there, and none of them expressed to you, 5 A. No, it was a, it was a regular shirt. 6 either by outward signs that you saw or anything 6 Q. Lake a blouse — 7 verbally that would have caused you any concern; is 7 A. Yes. 8 that a fair statement? 8 — shirt? Before you got in the car, 9 A. Yes. 9 pulls up in her truck. Before you get in the 10 Q. Okay. Before you got in the car — okay, 10 truck did you say, do I look okay? 11 so at some point you knew that Jeffrey was in — 11 A. No. 12 lived in Palm Beach. 12 Q. Okay. Did — did you say is, you 13 A. Yes. 13 how, I've thought about this, tell me a little bit 14 Q. Did you know that before you went? 14 more about what Pm doing for 200 bucks? 15 A. That he lived in Palm Beach? 15 A. No. 16 Q. Yes, ma'am. 16 Q. Had you ever mark 200 bucks for a 17 A. Yes. 17 half-an-hour's work before? 18 Q. All right. And you knew, did you know 18 A. No. 19 anything about his age at that time? 19 Q. Okay. Had anybody ever paid you 5200 for 20 A. No. 20 doing an hour, a half hour or an hour or two-hours 21 Q. Okay. Did you know, did you think he was 21 worth of work? 22 your age, or did you think he was older, or... 22 A. Yes. 23 A. I don't know. 23 Q. Doing what? 24 Q You just — okay. 24 A. Regrouting tables. 25 A. I had no idea. 25 O. Regroutin2 tables. E lain that for me. 12 (Pages 222 to 225) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cyntNa hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins datad07-Oca-4e7s45•1414.121•1:40135 EFTA01104181 Page 18 Page 20 1 Q. All trying to do is, is ifs your best 1 you recall what approximate date that was? Or if recollection that you remember when you went to 2 you want to use approximately X-time after June of 3 Mr. Epstein's house, approximately June of 2004, 3 '04, that's okay too. 4 henanse you got a used 2006 Toyota Corolla, correct? 4 A. I don't remember. A. I got a 2006 Toyota Corolla for my 16th 5 Q. How about the third time? 0 birthday. 6 A. About close to Christmas. 1 Q. Okay. And you got that at what, 7 Q. And what makes you recall that, that it — 8 approximately three months after your 16th birthday? 8 A. Decorations. 9 A. I got it on my 16th birthday. Q. — that it was close to Christmas? 10 Q. At -- okay. And did you go and get your 10 A. Decorations. 11 driver's license on your 16th birthday or did you 11 Q. Okay. You mean, just decorations around 12 have a learner's permit? 12 town or decorations — that is, where did you see 13 A. I had a learner's permit. 13 decorations that makes you remember the third time 14 Q. So you could drive that car with someone 14 you were at his home? 15 else? 15 A. On a gate. 16 A. Yes. 16 Q. On his gate? 17 Q. And who gave you the ear? 17 A. On a gate. 18 A. My mother. 18 Q. On just a gate when you were going, headed 19 Q. Okay. And any strings attached to it; 19 that way? 20 that is, did you have to pay the insurance? Did you 20 A. Yes. 21 have to pay for the car? Did you have to make any 21 Q. All right. And then the fourth time was 22 payments? 22 approximately when? Was it after Christmas? 23 A. I paid $1,000 down payment, and I paid for the 23 A. Yes. 24 car. 24 Q. Approximately how long after? 25 Q. Okay. And what did your mom pay for it? 25 A. It was hot outside, maybe spring, summer. Page 19 Page 21 1 She obviously -- the got you the car? 1 Q. And that would have been of '05? 2 A. I put the $1,000 down payment. She took care 2 A. Correct. 3 of the rest. 3 Q. So If — of the four times that you went, 4 Q. Oh, okay. So you put 1,000 and your mom 4 last being approximately sprinWsummer of '05 based 5 paid off for the, the remaining balance of the 5 on your testimony, how much after that period or how 6 vehicle, of the car? 6 long a time period transpired before you spoke with 7 A. Well, she bought it from the bank, so... 7 the police, or do you just not have any 8 Q. All right, but she paid it? 8 recollection? 9 A. Uh-huh. 9 A. I don't remember. 10 Q. Yes? 10 Q. And you don't remember whether you spoke 11 A. Yes. 11 to the police in '05 or '06 or '07; is that a 12 Q. An right. So, from your 16th birthday on 12 correct statement? 13 you were able to drive a call 13 A. Correct. 14 A. Yes. 14 Q. And I think part of my question was 15 Q. Okay. Let me go back then to the police 15 you indicated I think you've seen the police 16 statement. The police statement that you gave in 16 statement approximately two or three times? 17 the Epstein — well, let me strike that. 17 A. Correct. 18 You were at Mr. Epstein's home on, 18 Q. Okay. Did you read the entire statement? 19 you say approximately June of 2004. And I think you 19 A. Yes. 20 went on how many additional occasions to his home? 20 Q. Okay. Did you see was anything, do you 21. A. I were a total of four times. 21 know, if I use the word "redacted," do you know what 22 Q. And were they within a short period of 22 that means? 23 time, or were they over a length of time? 23 A. No, sir. 24 A. A length of time. 24 Q. Something's crossed out. 25 Q. And what - for going the second time, do 25 A. Yes, I saw that. 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. EFTA01104182 Page 174 Page 176 1 BY Nill. CRITTON: 1 THE WITNESS: Yes. 2 Q. All right. Let me go back I., okay. 2 BY MR. CRITTON: 3 At the time that Mr. Epstein, at least based on what 3 Q. Okay. And what kind of a friend, at least 4 you testified earlier today, is because Mr. Epstein 4 with Jane Doe No. 2, what kind of a friend exposes 5 did touch your breasts -- well, in fact, I should 5 another good Mend to a shocking, disturbing, 6 probably clear up one thing. He only touched you in 6 emotionally disturbing event? 7 the vaginal area, from what you've testified to 7 MR. MITRMEISTEN: Form, argumentative, 8 today, is over your boy shorts, correct? 8 rhetorical. 9 A. Yes. 9 BY MR. CRITION: 10 Q. And you have said that there was never any 10 Q. Why did you do that? 11 penetration? 11 A. I don't know. 12 A. Correct. 12 Q. Okay. You abo did that ta, 13 Q. Okay. You never touched any of his 13 coned? 14 private parts, true? 14 A. Yes. 15 A. Correct. 15 Q. Okay. Why did you do that with..? 16 Q. Okay. You never had any kind of 16 A. I don't know. 17 intercourse? 17 MR. CRITTON: Let's go about ten more 18 A. No. 18 minutes, and we'll take a break. Okay? 19 Q. All right Never had oral sex? 19 MR. WEIN: All right. Is that 20 A. No. 20 okay? 21 Q. He to you, you to him, correct? 21 ME WITNESS: (Witness nods head.) 22 A. No. 22 MR. MERMELSTEIN: Okay. 23 Q. Any type of other — no type of sexual 23 BY MR. CRITTONL. 24 contact whatsoever? 24 Q. Did you tell., what Did 25 MR. MERMELS TEIN: Objection, form. 25 you tell her what you had tot Page 175 Page 177 1 BY MR. CRITTON: 1 A. Not exactly. 2 Q. That is, your, your sexual organ with one 2 Q. But did you tell her she might be asked to 3 of his sexual organs; that never occurred, correct? 3 take off her clothes? 4 A. You're asking me if I've had sex with him? 4 A. And that you don't have to, yes. 5 Q. No. None of your sexual organs ever came Q. All right And you said you, you may be 6 in contact with his sexual organs, true? 6 asked to take off your clothes, but you don't have 7 A. Correct. 7 to? 8 Q. All rig o, again, what — based on 8 A. Yes. 9 what you told that he did touch your breasts, 9 Q. Okay. And did you say he might try to 10 and that you did take your shirt and your skirt off 10 touch you, but if he does, just tell him you're not 11 but left on your bra and your boy shorts, that you 11 comfortable? 12 were in shock and emotionally disturbed at what 12 MR. MERMELSTEIN: Form. 13 within — at the time, and then you told 13 ME WITNESS: Can you — 14 Within an hour how upset you were, you also 14 BY MR. CRITTON: 15 took Jane Doe Na 2 there, correct? 15 Q. Yeah. Did you, did you tell her as well, 16 A. Yes. 16 is if he tries to touch you, just tell him you don't 17 Q. All right. And was Jane Doe No. 2 a good 17 feel comfortable? 18 friend of yours, then? 18 MR. MERMELSTEIN: Form. 19 A. Yes. 19 ME WITNESS: I told her if he tries to do 20 Q. All right So despite this, I'd say, 20 anything, you can say no. 21 shocking incident to you, you were willing to expose 21 BY Mt. CRITTON: 22 your friend Jane Doe No. 2 as well to, at least 22 Q. Okay. And, and then he will stop? 23 based on your testimony, to this shocking, 23 A. Yes. 24 disturbing experience that you had had, true? 24 Q. Okay. And did you tell Jane Doe No. 2 the 25 MR. MERMELSTEIN: Form. 25 same thin -- 45 (Pages 174 to 177 PROSE COURT REPORTING AGENCY, INC. EFTA01104183 Page 258 Page 260 1 Q. En house? 1 there the first time, but you don't recall seeing 2 A. Yes. 2 her either the second or the third time but only the 3 Q. Okay. And, and what did you do there? 3 fourth time when you took her? 4 A. Get ready to go out or do something. I don't 4 A. Correct. 5 remember. 5 Q. And when you took Jane Doe No. 2 the 6 Q. Did you go out that night? 6 second time, you already described for me, so I 7 A. We did. I don't ;mow. 7 won't belabor it as to say what your c,onvefrigMn 8 Q. Did something? 8 was with both Jane Doe No. 2 and as wellW 9 A. I don't remember. We did something. I don't 9 Remember we talked about that a little earlier? 10 remember. 10 A. Yes. 11 Q. The three of you did something? 11 THE VIDEOGRAPHER: Sir, you're covering 12 A. We did something. 12 your microphone. 13 Q. Okay. Do you remember what you did with 13 BY MR. CRITFON: 14 the money? 14 Q. We talked about that earlier, correct? 15 A. No. 15 A. Yes. 16 Q. Okay. Did you buy anything, or you just 16 Q. Okay. So when you, when you took Jane Doe 17 don't remember one way or the other? 17 No. 2 the second time, did you pick her up? 18 A. I bought a beer. 18 A. Yes. 19 Q. All right. Usually beers aren't 200 19 Q. And did you pick her up in your 2006 20 bucks. 20 Toyota Corolla? 21 A. Right. 21 MR. MERMELSTEIN: Objection to form. 22 Q. Especially in — all right. And you don't 22 THE WITNESS: I picked her up in my car, 23 remember what you did with the rest of the money? 23 yes. 24 A. No. 24 BY MR. CRITTON: 25 Q. The, the next time you went, I think you 25 Q. Which was the 2006 Toyota Corolla? Page 259 Page 261 1 said, was the next time you went around the 1 MR. MERMELSTEIN: Form. 2 Christmastime date, or did you go the second time 2 THE WITNESS: Or I don't know what year it 3 before Christmas? 3 was. I don't remember. 4 A. Maybe around -- I don't know. I don't 4 BY MR. CRITTON: 5 remember. 5 Q. Pm just — Pm telling you what -- I'm 6 Q. And do you remember who, how it was that 6 repeating back what you told me earlier today. 7 you went the second time? 7 A. Well, I think I'm going to correct you. I 8 A. I don't remember. 8 think it was an older model, model than that. 9 Q. Okay. Do you remember who you went with 9 Q. Okay. So, anyhow, you picked her up in 10 the second time? 10 your car? 11 A. I believe it was with Jane Doe No. 2. 11 A. Yep. 12 Q. Okay. Jane Doe No. 2? 12 Q. And when you got in the car did you say, 13 A. Yes. 13 did you say anything else to her other than what you 14 Q. So your recollection is you went with Jane 14 told early, told me earliathat you said to both 15 Doe No. 2 the second time, just the two of you? 15 Jane Doe No. 2 and toa. about him maybe asking 16 A. Yes. 16 you to take your clothes off, him asking you that he 17 Q. Okay. Did Jane Doe No. 4 go with you the 17 may try to touch you, and do what you feel 18 second time? 18 comfortable with? 19 A. I don't remember. 19 A. That you're not allowed to talk to hint 20 Q. Did, did Jane Doe No. 4 ever go with you 20 Q. Okay. Anything else? 21 again? 21 A. Not that I remember, no. 22 A. Yes. 22 Q. Okay. And when you got over there, how, 23 Q. Okay. When did she go with you again? 23 how were the arrangements made for you to bring Jane 24 A. When I took her. 24 Doe N there? 25 9. So our recollection is that she, she was 25 A. 21 (Pages 258 to 261) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins dattEted07-0ece-4e7s-95•1-d4d2lobitt35 EFTA01104184 Page 262 Page 264 1 Q. Well set it up? Q. Did she at any time say to you, you know, 2 A. Yes. I don't think I really want to do this? 3 Q. Okay. But you're sure she didn't go with 3 A. No. 4 you? 4 Q. Okay. Did you ever discourage her from A. I believe so. 5 doing it? 6 Q You don't believe? 6 A. Not that I remember. 7 A. I do believe so. 7 Q. Okay. I think you already told me earlier 8 Q. You, you believe she did not go? is despite the fact that you were shocked, were 9 A. Correct. 9 emotionally disturbed, that you thought it was a 10 Q. Okay. So, so you get over there. You 10 terrible experience, you still took Jane Doe No. 2? 11 drive over to the same location. Did you remember 11 A. Yes. 12 how to get there, or did you have to get directions? 12 MR. MERMELSTEIN: Objection, asked and 13 A. I don't remember. 13 answered numerous times. 14 Q. And when you got over there -- but somehow 14 BY MR CRTITON: 15 you got over there. And did you go in the same 15 Q. So, you go up — so she goes upstairs. 16 entrance again? 16 How long was she upstairs? 17 A. Yes. 17 A. I don't know. 18 Q. Okay. And when you were there, what did 18 Q. What did you do when you were downstairs? 19 you do? That is, you parked your car. Did you pull 19 A. Hang out in the kitchen. 20 into the driveway? 20 Q. Did you have anything to eat, drink? 21 A. Yes. 23. A. No. 22 Q. Did you go in the side door again? 22 Q. Just hung in the kitchen? 23 A. The ldtchen. 23 A. (Witness nods head.) 24 Q. The kitchen. And when you get into the 24 Q. All right. 25 kitchen, who was there on this occasion? 25 THE COURT REPORTER: That's ayes? Page 263 Page 265 1. A. The chef. 1 TIE WITNESS: Yes, sorry. 2 Anyone else? 2 BY MR. CRITTON: 3 The housekeeper. 3 Q. Okay. Anything else happen? Anything 4 • Q. Okay. Do you remember what her name was? 4 else unusual, usual, or you just hung in the 5 A. I was never -- 5 kitchen; you waited for her to come back? 6 Q. He or she, was it a he or she? 6 A. Correct. 7 A. It was a her. 7 Q. Okay. And she comes back downstairs? 8 All right. And what happened, then? 8 A. Yes. 9 A. I got let in the house. We went into the 9 Q. And do you leave? 10 house. 10 A. Yes. 11 Q. Who went upstairs with Jane Doe No. 2? 11 Q. Okay. Did you see anyone else? 12 A. I don't remember. 12 A. Not that I remember. 13 Q. Did you go? 13 Q. Okay. So you get back in your car and 14 No. 14 where did you two go? 15 Q. Okay. Because you never went up again? 15 Well, in fact, before that is, did you 16 Right 16 receive any money for bringing, having brought Jane 17 Q. Did you ever see Mr. Epstein again at his 17 Doe No. 2 there on the second occasion? 18 house? 18 A. Yes. 19 A. Yes. 19 Q. And who gave you the money? 20 Q. Okay. But not that occasion? 20 A. I don't remember who gave it to me. 21 A. Correct. 21 Q Do you know how you got the money? Was h 22 Q. So somehow Jane Doe No. 2 got upstairs? 22 handed to you? Did you get it when you were there? 23 A. (Witness nods head.) 23 Did you — 24 Q. Yes? 24 A. I don't remember. 25 A. Yes, I don't -- 25 Q. So, but how much did you arn• • ..µ.1 .irmewa.s.n“.44)440100.8041411Silal 22 (Pages 262 to 265) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins da88ed07-Occe-4c7a-9501.d4d2leb3c135 Electronically signed by cynthla hopkins EFTA01104185 Page 266 Page 268 1 A. A hundred. 1 the cook? 2 Q Did Jane Doe No. 2 know that you had 2 A. I don't remember. 3 received money for taking her there? 3 Q. Do you know whether it was the same cook? 4 A. Yes. 4 A_ No. 5 Q. Because you told her? 5 Q. So you both go into the kitchen. Other 6 A. Yes. 6 than the cook, was anybody else there? This is now 7 Q. You got back in the car. Did Jane Doe No. 7 the third visit. 8 2 say anything to you? 8 A. No. 9 A. Not that I remember. 9 Q. So, how did M. get upstairs to give the 10 Q. All right. And so you drove where? Where 10 massage? 11 did you go after that? 11 A. I don't remember who took her up. 12 A. I don't remember. 12 Q. You don't remember seeing anybody else 13 Q. Did you go back to anybody's house? Did 13 other than the cook, though, at least before she 14 you go out that night, or do you have any 14 went upstairs, correct? 15 recollection? 15 A. Correct. 16 A. I do not remember what we did after. 16 Q. All rig,ht. And I think, again, so as not 17 Q. All right The, the third time you went, 17 to repeat it, what you told me earlier about Ms.— 18 you took who, M.? 18 takings and what you told Jane Doe No. 2, that 19 A. Yes. 19 would apply to what. you had told her going, up until 20 Q. All right. And did anyone go with you on 20 the time she went upstairs, correct? 21 that oc asion? 21 A. I'm confused on what you're saying. 22 A. No, I went by myself. 22 Q. Well, we talked — I don't want to have to 23 Q. Okay. You're sure neither nor, 23 repeat &valise Stuart will object as I'm being 24 excuse me, Jane Doe No. 4 went with you? 24 repetitious, so when we talked about what you had 25 A. Yes, I'm sure. 25 told — Page 267 Page 269 1 Q. And how did you make gements to take 1 A. Oh, yes. 2 your -- one of your best friends,, there? 2 Q. -- about everything, you know, what to — 3 A. 3 what to, in essence, what to expect, you, you, I 4 Q. All right And when you, did you 4 don't need to repeat that -- 5 basically follow the same procedure you had with S A. Yes. 6 Jane Doe No. 2; that is, you drove to the house. 6 Q. -- correct? 7 You went in the kitchen? 7 A. Yes. 8 A. Yes. 8 Q. All right. And did you tell, did you tell 9 Q. Okay. Was anybody there at that time in 9 either of them if you're asked your age to tell them 10 the kitchen? 10 you're 19? 11 A. No. 11 A. No. 12 Q. Okay. So you're in the house. How did 12 Q. Had you told either one of them then? 13 you get in the door or was it open? 13 A. No. 14 A. No. Some -- the, the chef was always there. 14 Q. All right. Do you know how old Jane Doe 15 Q. All right. So the chefs in the kitchen. 15 No. 2 was at the time you took her? 16 Did he open the door for you? 16 A. No. 17 A. Yes. 17 Q. Do you know how old.. was when you took 18 Q. Okay. So the two of you come in? 18 her? 19 A. Yes. 19 A. No. 20 Q. All right. And do you remember what.. 20 Q. Were they approximate — were they in your 21 had on? 21 age, in your class at school? And I think you said 22 A. No. 22 Jane Doe No. 2 was. 23 Q. Okay. Do you remember what you had on? 23 A. Janeae No. 2 was, yes. 24 A. No. 24 Q. WasM. older? 25 9. so, you sit in, you — did you recognize 25 A. Yes. 4.4•0414...1 .0••••••••••••••••••Sa". 23 (Pages 266 to 269) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins daSeed07-Occe-4c7a-95el-d4d2leb3c136 EFTA01104186 Page 2 Page 4 APPEARANCES: 1 PROCEEDINGS Oa behalf of the Plaintiff: 2 STUART S. MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, PA 3 Deposition taken before Cynthia Hopkins, 18205 Biscayne Boulevard 4 Registered Professional Reporter, Florida Suite 2218 5 Professional Reporter, and Notary Public in and for Miami, 6 the State of Florida at Large, in the above cause. Phone: 7 On behalf of the Defendant 8 THE VIDEOGRAPHER: This is the 19th day ot ROBERT D. CRITION, IR, ESQUIRE 9 February, 2010. The time is 10:07 a.m. This BURMAN, CR1TTON, LUTHER & COLEMAN, LLP 303 Banyan Boulevard 10 is the videotaped deposition of lane Doe No. 3 Suite 400 11 in the matter of Jane Doe No.2 versus Epstein. West 'de 33401 12 This deposition is being held at 250 Phone: 13 Australian Avenue South, West Palm Beach, E-mail: 14 Florida My name is Sascha Quimby. I am the 15 videogmpher representing Visual Evidence, Inc. ALSO PRESENT: 16 Will the attorneys please announce their 17 appearances for the record. Sesdm Quimby, Vidcographer Visual Evidence, Incorporated 18 MR. MERMELSTEIN: Stuart Mermelstein for 19 Plaintiff Jane Doe 3. 20 MR. CRITTON: Bob Critton on behalf of 21 Jeffrey Epstein. 22 Thereupon, 23 (JANE DOE NO.3) 24 having been first duly sworn or affirmed, was 25 examined and testified as follows: Page 3 Page 5 1 THE WITNESS: Yes. INDEX 2 DIRECT EXAMINATION 3 BY MR. CRITTON: 4 Q. Would you please tell me your full name. EXANENATION DIRECT CROSS REDIRECT 5 A. Jane Doe No. 3. JANE DOE NO.3 6 Q. Give me our date of birth, please. 7 A. BY MR. CRITION 4 8 Q. And do you know your Social Security 9 number? 10 A. 111111111. EXHIBITS 11 Q. Ms. Jane Doe No. 3, have you ever had your 12 deposition taken before? 13 A. Yes. • EXHIBIT DESCRIPTION PAGE 14 Q. When? DEFENDANTS EX. I 115 15 A. From the police department. PSYCHOLOGICAL/SOCIAL HISTORY FORM 16 Q. That was a sworn statement? DEFENDANTS EX. 2 170 17 A. Okay. So then, no. SECOND AMENDED COMPLAINT 18 Q. Was there a court reporter there that took 19 it or was it — 20 A. No. 21 . Q. In what fashion did you give a sworn 22 statement to the police department? 23 A. Explain further. 24 Q. What were the circumstances of your giving 25 a sworn statement? Jcomm4.1......Crai, A,ftiValliwieinseNwaiftWf,MWINI,Mw011ign , =======WOCOMAI. 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. EFTA01104187