UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-CIV-80119-MARRA/JOHNSON
JANE DOE NO. 2,
Plaintiff,
vs-
JEFFREY EPSTEIN,
Defendant.
Related cases:
08-80232, 08-08380, 08-80381, 08-80994,
08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092,
DEPOSITION OF JANE DOE $17 - VOLUME III
(videotaped)
Monday, March 15, 2010
10:02 - 6:49 p.m.
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Rachel W. Bridge, RMR, CRR
Notary Public, State of Florida
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Page 299 Page
APPEARANCES: 1 PROCEEDINGS
On behalfof the Plaintiffs in related cases 2
Nos. 08-80069, 08-80119, 08-80232, 08-80380,
0840381, os-so993, 08-86994: 3 THE VIDEOGRAPHER: We are back on the record
ADAM D. HOROWITZ, ESQUIRE 4 at 4:08 pm.
MERMELSTEIN & HOROWITZ, PA. 5 BY MR. CRITTON:
18205 Biscayne Boulevard 6 Q. Jane Doe 7, in your supplemental answers to
Suite 2218
6 Min4,040. 7 interrogatories, you listed the names and addresses and
8 phone numbers, number 18, and I don't know whether I
7 9 used that as an exhibit — this will be Exhibit 9.
8 On behalf of the Defendant Jeffrey Epstein:
10 (The document was matted Defendant's
9 ROBERT D. CRITTON, JR., ESQUIRE
BURMAN, CRITION, LUTHER & COLEMAN 11 Exhibit 9 for identification.)
10 303 Banyan Boulevard 12 BY MR. CRITTON:
Suite 400 13 Q. There area couple of supplements you filed
11 West P 33401
Teleph 14 which as things come to you, I think, or your attorneys.
12 15 Anyhow, this one deals with males that you had sexual
13 16 activity. You listed Mr. Evans, Bryant —
14 Also Present: Socha Quimby, videographer 17 MR. HOROWITZ: You handed us two different
15
16 18 things. This is a request to produce.
17 19 MR. CRTITON: Oh, Tin sorry.
18 20 MR. HOROWITZ: No problem.
19
20 21 MR. CRT TON: Give this back. This will be
21 22 number nine.
22 23 (Discussion held off the record.)
23 24 BY MR. CRITTON:
24
25 25 Q. Is that the right one that has Mr. Evans?
Page 300 Page 302
1 There is a person listed as Bryant. Who is he?
- - - 2 A. He a friend from Orlando. 1kind of dated
INDEX
3 him.
4 Q. And so of the five individuals you have here,
WITNESS: DIRECT CROSS REDIRECT RECROSS 5 Mr. Evans, Bryant, Mackenzie Russell, PJ Tao and Blake
6 Russell, are the only individuals with whom you have had
Jane Doe #7
7 any type of sexual activity since the time you were ten
By Mr. Critton 5 8 years old?
9 A. Yeah, other than like kissing. I don't
10 remember everybody I kissed and stuff like that.
11 Q. All right. 1 want to go back to a couple of
EXHIBITS
9 12 areas to make sure I got all the information on it.
10 EXHIBIT PAGE 13 At the time that you met with the officers
11 Defendant's 1 233 14 from Palm Beach, you said, do you remember one of them
12 Defendant's2 233 15 being a person named Recarey, R-e-c-a-r-e-y,
13 Defendant's 3 233
14 Defendant's 4 263 16 Officer Recarey7
15 Defendant's 5 268 17 A. Yes.
16 Defendant's 6 274 18 Q. I think you said there were two males. Do you
17 Defendant's 7 280 19 remember who the other male was?
18 DePeadant'S 8 294
19 Defendant's 9 301 20 A. I think his name was Joe something.
20 21 Q. Joe something, all right. And, Mr. Recarey's
21 22 first name, Detective Recarey's first name is Joe
22 23 Recarey.
23
24 24 A. Oh, sorry.
25 25 Q. Do you remember what the other person looked
2 (Pages 299 to 302)
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1 like? Not Mr. Recarey, but the other one. 1 car?
2 A. He was like just an older man. He was kind of 2 A. Yeah, I think so.
3 bigger, gray hair, I think. 3 Q. So they actually showed you, was it a color
4 Q. All right. And in terms of that individual, 4 picture or black and white picture?
5 did he say anything or was it Officer Recarey who 5 A. .Black and white.
6 conducted the interview with you? 6 Q. So they actually had a picture of what, the
7 A. I think it was Officer Recarey mostly. 7 rear ofyour car that had the license plate number?
8 Q. Did you eves have any subsequent contact with 8 A. I'm almost positive.
9 him? Did you ever talk to him after the interview on 9 Q. So when they showed you the picture of your
10 October 4th of2005? 10 car, and you had said that earlier in your testimony,
11 A. I don't think so. I don't remember. 11 you recognized right away as they knew that you had been
12 Q. When he talked to you, that is, when he 12 there?
13 introduced himself to you, did he explain to you how he 13 A. Yes.
14 found you, that is, how he knew that you may have had 14 Q. All right Did you ask him how old the
15 some involvement with Mr. Epstein? 15 picture was?
16 A. I think it was somebody told him. 16 A. No, I didn't.
17 Q. Did he tell you who the somebody was? 17 Q. And they just said that they had had him under
18 A. No. 18 some surveillance fora period of time?
19 Q. Did he tell you when you met with him, and 19 A. Yes.
20 again before he started the tape of the statement, did 20 Q. Did they show you more than one picture of
21 he tell you that, that he had interviewed a number of 21 your car so that, that suggested that they had taken a
22 other females? 22 picture ofyour car on a number of occasions?
23 A. I don't remember if he told me that or not. 23 A. No.
24 Q. Did he tell you, you know, tell us everything 24 Q. Did they tell you whether they knew any other
25 because we've heard stories from other people, so we 25 people who had been to his house? That is, did they use
Page 304 Page 306
1 have an idea of what may have occurred at Mr. Epstein's 1 any names?
2 house? 2 A. I think they j ust said other girls in my high
3 A. Like front the very beginning ofme going? 3 school.
4 Q. No, no, no. When you first met with him after 4 Q. And the only name you gave them was Jane
5 you sent Mom back into the house, did Officer Recarey 5 Doe 4?
6 say to you "Hey, lane Doe 7, you can tell us what went 6 A. AndM
7 on because we've heard stories from other people, so 7 Q. IMI:tid you give t hem too?
8 tell us everything that happened"? 8 A. And S.V., yes.
That is, did he try to make you comfortable so 9 Q. Did they show you any other photographs of
10 you would talk to him? 10 either his house, any other cars, any other vehicles, or
11 MIt HOROWITZ: Form 11 was it just yours?
12 THE WITNESS: I don't exactly remember what he 12 A. I think tlisiright have -- yeah, they showed
13 said, but basically he showed me the picture ofmy 13 me a picture of = and they asked ra tify the
14 car or my license plate or something. He said that 14 girl in the picture, and I identified her
15 they have been like watching Jeffrey and they know 15 Q. Did you ever Imw what last name was?
16 I've been there because they saw my car there. 16 A. It began with al, something.
17 BY MR. CRITTON: 17 Q. Did she ever introduce herself to you?
18 Q. Okay. Did they tell you how long they had 18 A. Yes.
19 been watching Jeffrey? 19 Asil=, or did she just say my name is
20 A. No, I don't think so. 20
21 Q. Did you get the impression that over the last 21 A. I don't remember.
22 few months they had been watching him? 22 Q. Was she nice to you?
23 A. Yes. 23 A. Yes.
24 Q. Okay. And so the picture they had, did they 24 Q. Friendly?
25 have an actual picture of your license plate on your 25 A. Yes.
ata....Gittet•a•45,40 ,
3 (Pages 303 to 306
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1 Q. How old did you thinavms? 1 he suggest things, like we know this, we know that?
2 A. She looked about in her nu twenties. 2 Like your car, we know you were there because here's a
3 Q. All right. And did you tell them that? Did 3 picture of your car and your license plate. Isn't that
4 they ask you about her at all? 4 your car and license plate?
5 A. Yes. I think they just asked if I recognized 5 MR. HOROWITZ: Form.
6 her and just asked what I saw her doing there and stuff 6 THE WITNESS: The only thing he suggested is
7 like that. 7 he just kind of knew I was there, so —
8 Q. And I think you said earlier that. called 8 BY MR. CRITTON:
9 you during the time, either just before or urmg the 9 Q. Did he ever tell you what some of the other
10 time you were being interviewed by the police? 10 females had said had occurred at Mr. Epstein's house?
11 A. Yes. 11 A. I don't remember exactly what he said to me.
12 Q. And did you take her call? 12 Q. Did they ever tell you that some of the other
13 A. No. 13 females were saying that Mr. Epstein did X or Y with
14 Q. Did you call her back? 14 them? X or Y could be anything, but did he say well, we
15 A. No. I just listened to her voicemail. 15 know Female ABC did such and such, or at least she says
16 Q. What did — did you play the voicemail for the 16 she did such and such with Mr. Epstein or he did such
17 police? 17 and such with her?
18 A. Yes. 18 Did he suggest that?
19 Q. Okay. And did they record it? 19 A. I don't remember.
20 A. I think so, yes. 20 Q. Did they ever say and I think they asked
21 Q. What did the voicemail say, to the best of 21 you, because I asked you earlier and you had told them
22 your knowledge or recollection? 22 that at least in the visit that you had under oath with
23 A. Just that "Hi, Jane Doe 7, this is M." I 23 them is that you had, he had not masturbated when you
24 think she just asked if there was cops at my house and 24 were there, correct?
25 if I was talking to them. And she said for me to call 25 MR. HOROWITZ: Form.
Page 308 Page 310
1 her back. 1 BY MR. CRITTON:
2 Q. But you never did? 2 Q. mars what you told them that day?
3 A. No. They told me not to. 3 MR. HOROWITZ: Form.
4 Q. They being the police? 4 THE WITNESS: I believe so.
5 A. Yes. 5 BY MR. CRITION:
6 Q. Did they tell you anything else to do or not 6 Q. And did they say "Well, other females had said
7 to do? 7 that Mr. Epstein masturbated, did he do that when you
8 A. Just not really to talk about it with anybody. 8 were there?"
9 Q. Did they tell you not to tell your parents? 9 Did they suggest things like that in askinr
10 A. No, they never said that. 10 questions?
11 Q. Did they tell you that if somebody called you 11 A. !thinks*, yes.
12 on behalf of Mr. Epstein not to talk to them? 12 Q. Okay. And did he reassert to you, did he tell
13 A. Yes. :3 you at any time "You can tell us anything, you are not
14 Q. Did they mention at that time anything about going to get in any trouble"?
15 the US attorney or the FBI? 15 MR. HOROWITZ: Form.
16 A. No. 16 THE WITNESS: I don't remember if he said that
17 Q. Did anyone else, did either Officer Recarey or 17 or not.
18 anyone else from Palm Beach ever try to recontact you 18 BY MR. CRITTON:
19 for a followup interview or to clarify something? 19 Q. Well, did he ever say to you if in fact you
20 A. No. 20 received money for having taken people to Mr. Epstein's,
21 Q. And I think you told me earlier they never 21 you could be charged with a crime under Florida law?
22 sent you anything? 22 Did he tell you that?
23 A. No. 23 A. No.
24 Q. When Officer Recarey was talking to you, did 24 Q. Okay. Did he ever read you your Miranda
25 he — and i don't mean this in a negative way, but did 25 rights?
4 (Pages 307 to 310
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1 A. No. 1 THE WITNESS: I think so.
2 Q. Were you concerned that you might be charged 2 BY MR. CRITTON:
3 with a crime? 3 Q. Did she have the statement that you had given
4 A. Yes. 4 to the Palm Beach police?
Q. Because you thought you had committed a crime? 5 A. I think so, yes.
MR. HOROWITZ: Form. 6 Q Did she ask you about the statement? That is,
THE WITNESS: I just thought I was going to 7 did she quiz you from the statement?
8 get in trouble for going there. 8 Did it sound like she had a transcript of your
9 BY MR. CRITTON: 9 statement so she was asking you questions, did this
10 Q. Dkly also said that 10 happen, did that happen?
11 called you eras you described. 11 A. Yeah, she basically asked me if what I told
12 Did you know who she was before she called 12 the Palm Beach police was true. She said that she knew,
13 you? 13 you know, a lot of girls did a lot more things with
14 A. No. 14 them, what I have said, and she basically knew, you
15 Q. She just called you out of the blue one day? 15 know, I felt that she knew a lot more.
16 A. I think she called me and — actually, I think 16 So 1just told her the truth, that 1lied to
17 Agent Nezbit from the FBI might have told me something 17 them and that I finally, you know, broke down and told
18 that she, she was the attorney general maybe, I think 18 her everything that happened.
19 I don't 19 Q. And did she encourage you to do that? I mean
20 Q. Nezbit is the female FBI agent, correct? 20 did she tell you "A lot of other girls have come forward
21 A. Yes. 21 and said XY, that XYZ happened at Mr. Epstein's, so
22 Q. And then when she came to (bland° to meet with 22 please tell us everything"?
23 you and you met at Starbuck's, she had a male agent with 23 MB. HOROWITZ: Form.
24 her as well? 24 THE WITNESS: Well, she kind ofacted like she
25 A. Yes. 25 already knew and she knew a lot more went on than
Page 312 Page 314
1 Q. And I think you said you spent an hour and a 1 what I told the officers in Palm Beach.
2 half, two hours with them? 2 BY MR. CR1TTON:
3 A. Yes. 3 Q. And whether she did or not, you don't blow,
4 Q. And you recall that they took a taped 4 that's how she played it, so to speak?
5 statement from you? 5 A. Yes.
6 A. Yes. 6 Q. All right. Did, after the hour or two that
7 Q. Much like FBI did — Pm sorry, much like the 7 you spent with Agent Nezbit, was she someone who — did
8 Palm Beach police did? 8 you get emotional with Agent Nezbit?
9 A. Yes. 9 A. Yeah, I mean I felt like i could like open up
10 Q. Did they talk to you fora period of time 10 to her more than I could guys, you know.
11 before they turned on their tape recorder? 11 Q. Did she give you a hug when you left?
12 A. I don't remember. 12 A. No.
13 Q. You just remember them taking a taped 13 Q. Shake hands?
14 statement? 14 A. Yes.
15 A. Yes. 15 Q. Was she warm, comforting?
16 Q. Okay. Did they also take notes? 16 A. Yeah, she was nice.
17 A. Yes. 17 Q. And did she give you her card and say "Jane
18 Q. And who was taking the notes, the male or the 18 Doe 7, If you ever have any issues associated with this,
19 FBI Agent Nezbit? 19 you can call me any time at this number"?
20 A. The male was. 20 A. Yes.
21. Q. And was the Agent Nezbit, was she, did she 21 Q. All right. And did you ever call her?
22. !mow that you had let me strike that. 22 A. Yes, I called her a couple of times.
23 Did she have the benefit of any information 23 Q. For what?
24 from Palm Beach? 24 A. Just called her to ask what was going on with
25 MR. HOROWITZ: Form. 25 the case and if she heard any news and things like that.
5 (Pages 311 to 314)
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1 Q. Did you ever call her back to get the name of 1 A. Maybe a month maybe.
2 an attorney? 2 Q. Did they arrange that before they came back up
3 A. No. 3 or did they call you out of the blue?
4 Q. And I think you told me she said if you ever 4 A. Well, no, they arranged it to come back up.
5 need the name of an attorney, she could give you one, 5 Q. Why did they tell you they needed to see you
6 but you would have to call her? 6 again?
7 MR. HOROWITZ: Form. 7 A. They just wanted to make sure everything was
THE WITNESS: I think Marie was the one that 8 correct and go over everything with me again.
9 said about the attorney stuff. 9 Q. Did they have like a statement that they were
10 BY MR. CRITTON: 10 now reading ftom?
Q. Okay, when she called you, when she, meaning 11 Did they have an outline that they were
12 Marie,calkdyaa 12 reading from when they came to meet with you on the
13 A. (Witness nods head up and down.) 13 second occasion?
14 Q. Did Officer Nezbit ever call you independently 14 A. I don't remember.
15 of you calling her? 15 Q. How long did that meeting last?
16 A. About what? 16 A. I think about an hour.
17 Q. Whatever. 17 Q. And It was just the two of them?
18 A. No. 18 A. Yes.
19 Q. You said you called her on two occasions to 19 Q. Did they record you at that occasion again?
20 find out status. 20 A. I think so, yes.
21 A. Yeah. 21 Q. So on both occasions that the FBI met with
22 Q. Okay. And I think you told me you don't know 22 you, you recall them taking a recorded statement from
23 when you first talked to her. 23 you?
24 A. She called me again to ask me if there were 24 A. Yes.
25 any details that I left out or anything like that Just 25 Q. Or recording the session, correct?
Page 316 Page 318
1 basically asked me if I remembered anything. She called 1 A. Yes.
2 me about that. 2 Q. And on the second occasion did you provide
3 Q. All right. And you told her what? 3 them any additional information?
4 Did you add any details? 4 A. I don't remember.
5 A. I don't remember. 5 Q. Did they provide you any additional
6 Q. That's when she called you? 6 information, such u we've talked to a number of other
7 A. Yes. 7 females and they have told us X, Y and Z, did this
8 Q. Okay. And then, and that's the only time she 8 happen? Did that happen?
9 ever called you after the first interview? 9 MR. HOROWITZ: Form.
10 A. Well, no, they came back up to Orlando. 10 THE WITNESS: I think they, yeah, they just, I
11 Q. A second time? 11 think they, yeah, said something like that, yeah.
12 A. Yes. 12 BY MR. CRITTON:
13 Q. Oh, I didn't know that. All right, they came 13 Q. So they gave you some more at least
14 back a second time. Meet at Starbucks again? 14 information. Again, you don't know whether it's true or
15 A. No, we met at the Radisson. 15 not, but they said "Well, we found out this or we found
16 Q. All right. Were they staying there? 16 out that. Did that happen to your
17 A. I think, yeah. Well, I don't know if they 17 Did they ask questions like that?
18 were staying there or not actually. 18 A. I believe so.
19 Q. Where did you meet, in the restaurant? 19 Q. All right. Did they, after that second
20 A. No, we met like in a conference center. 20 occasion, did they ever recontact you?
21 Q. Who was t ere other than you? 21 A. Agent Nezbit did, just, she would call me and
22 A. The same two people, just me and her and the 22 fill me in on what was going on.
23 same guy. 23 Q. How many more times did Agent Nezbit call?
24 Q. How much time transpired between the first 24 A. I think once or twice after that. She didn't
25 visit and the second visit? 25 call me a lot.
6 (Pages 315 to 318)
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1 Q. Did she ever ask you what your feelings were 1 questions.
2 about any criminal prosecutions directed to Mr. Epstein? 2 Q. And you said a lawyer to protect yourself.
3 A. No. 3 Protect yourself from what?
4 Q. Pardon? 4 MR. HOROWITZ: Form.
5 A. No. 5 BY MR. CRHITON:
6 Q. Did you know who -- andIn asked you 6 Q. What did she tell you?
7 et me just clarify it. Before 7 A. I don't, I don't know what she was referring
8 called you, did know who she was? 8 to.
9 A. I want to say I don't remember. I think Agent 9 Q. Okay. Did she tell you you might have a civil
10 Nezbit might have said something about her to me. And 10 claim or you would have a civil claim against
11 then she just called and -- 11 Mr. Epstein?
12 Qi.th:iiitifishat she said, she, Nezbil 12 A. No.
13 said 13 Q. Did she tell you the deal that the government
14 A. No. It was towards the end of everything, and 14 had worked out or was attempting to work out would
15 I think she just updated me on everything that was going 15 • provide a civil remedy for individuals who had gone to
16 at. Might have told me like who she was. 16 Mr. Epstein, females who had gone to Mr. Epstein's
17 Q. And at the time, so if — and !know that, I 17 house?
18 think you said that at the time that you spoke with Jane 18 A. No.
19 Doe 4 in the summer of '08, you did not have an 19 Q. Do you ever remember receiving a letter from
20 attorney, a your recollection was you didn't think you 20 her that said you may have a civil remedy that you can
21 had an attorney at that time. You may have spoken with 21 pursue under a specific federal statute?
22 Mr. Herman tut you may not have had an attorney. 22 A. I think I received a letter, but I don't
23 Son= would have had to have spoken with 23 remember what it said. It might have said something
24 you sometime before Jane Doe 4 came to stay with you in 24 like that.
25 the suntmer of '08; is that your best recollection? 25 Q. Do you ever remember receiving a letter from
Page 320 Page 322
A. Yes. 1 Robert Josefsberg from Podhurst Orseck saying he was the
Q. Do you remember how many months before Jane 2 attorney representative who had been appointed to
Doe 4 came there that you would have spoken wit 3 represent individuals who the government had deemed to
4 have been, quote, unquote, victims?
A. Probably I think a while. Probably like, I 5 A. No, I never got a letter from Mm.
don't know, six months. 6 Q. Did you ever hear from any other government
7 Q. All right. And you only spoke with her on 7 agent, government agent for the United States government
8 that one occasion? 8 who purported to work for thegovernment other than the
9 A. Yes. 9 two FBI agents an
10 Q. Did she ever tell you elf you ever have any 10 A. No, I don't think so.
11 questions, you can call me? 11 Q. Did you ever hear from anyone else associated
12 A. Yeah, she gave me a number to call. 12 with any other police department other than
13 Q. Did you ever follow up and try to call her for 13 Officer Recarey and whoever the other Palm Beach police
14 any reason? 14 officer was?
15 A. No. 15 A. No.
16 Q. When she filled you in on what was going on, 16 Q. Did your dad know any of the officers. having
17 what exactly did she say to you? 17 been associated with the Town ofPalm Beach or employed
18 A. She just told me about the criminal case. I 18 by the Town ofPalm Beach?
19 forget exactly what she said. 19 A. No.
20 And then she just explained all the like legal 20 Q. Did he ever see anyone in the Town ofPalm
21 terms and what was going on. She said, you know, "Other 21 Beach about this situation, to your knowledge? That is,
22 people am getting lawyers, if you want to protect 22 did he ever go talk to the mayor or the chief-of-police
23 yourself, you know, you could get a lawyer too" 23 about you and Mr. Epstein?
24 But she didn't give me any names or numbers, 24 A. No.
25 but she did give me a number to call if I had any more 25 Q. Other than the time that you told your mom and
14.....•••••44
7 (Pages 319 to 322)
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1 your dad, you disclosed to them, that is the day that 1 County to work?
2 Officer Recarey was there, October 4 of 2005, has your 2 A. No. They just said wherever I get a job at.
3 mom ever discussed it with you? Not necessarily the 3 Q. Okay. In terms of your parents, are you
4 details, but how she feels about it. 4 closer, like if you had a personal problem or an issue,
S A. I mean she's read the newspapers and obviously 5 would you more likely call your mom or your dad?
6 she doesn't like him, but I mine she actually didn't 6 A. I mean either one really. I'm not more close
7 want me to go ahead with the lawsuit. 7 to either of them.
8 Q. She didn't? Q. Both would be supportive of you, both
A. No. 9 emotionally and as well financially if they thought that
10 Q. Why not? 10 it was necessaty?
11 MR. HOROWITZ Form. 11 MR. HOROWITZ Form.
12 BY MR. CRITTON: 12 THE WITNESS: Yes.
13 Q. What did she tell you? 13 BY MR. CRITTON:
14 A. She thought it would bring more stress and 14 Q. And that's always been true with you and your
15 anxiety on me. 15 family and your mom and your dad?
16 Q. Has it? 16 A. Yes.
17 A. I mean, of course, hearing everything, hearing 17 Q. Okay. If you had a friend or friends that you
18 his name brings anxiety and I get depressed and sad over 18 were going to tum to now that you needed help or
19 it, yeah. 19 assistance in some fashion, you didn't want to tell your
20 Q. Over the lawsuit? 20 mom or your dad, would Jane Doe 4 be one of the people
21 MR. HOROWITZ: Form. 21 you would go to?
22 THE WITNESS: Not just over the lawsuit, but 22 A. Yes,
23 hearing his name, it brings back memories. 23 Q. Who else? Who else would you consider would
24 BY MR. CRITTON: 24 be a good friend that you would go to?
25 Q. How about your dad, how did he feel about the 25 . A. Jane Doe 4 or Jane Doe 3 really.
Page 324 Page 326
1 lawsuit? Did he ever express any opinion? 1 Q. I'm sorry?
2 A. My dad just basically said it was up to me to 2 A. Jane Doe 4 or Jane Doe 3.
3 do what I wanted to do. 3 Q. Jane Doe 3?
4 Q. Has your room ever said to you that she's angry 4 A. Yes.
5 with you for ever having gone there? 5 Q. Looking briefly at your work history, looks
6 A. I mean no. She was upset about it, and at 6 lila, you worked irt,IFIr t m i.ottra to Orlando you
7 first she like asked me how I could have been so stupid 7 worked at
8 and why I would have went there. But I mean she 8 A. Yes.
9 understands that I was young and confiised at the time, 9 Q. And you were a cart girl?
10 so-- 10 A. Yes.
11 Q. Did your dad ever ask you? 11 Q. All right. So you drove around on the golf
12 A. No. My dad didn't really talk about it. 12 course?
13 Q. Are you closer to your mom or your dad? You 13 A. Yes.
14 love them both, right? 14 Q. For refreshments and food for guys? Guys and
15 A. Yeah. 15 gals, whoever was playing golf?
16 Q. And they both love you? 16 A. Yes.
17 A. (Witness nods head up and down.) 17 Q. Allright. And then you worked — and that
18 Q. Supportive of you? 18 was in '07, and is the only job that you have had since
19 A. Yes. 19 then, although I think you said you are working
20 Q. And they are supportive of you getting a 20 someplace now. I'll get
21 career, certainly a job? 21 Then you worked b all. in 2008, the whole
22 A. Yes. 22 year?
23 Q. Every parent wants their child to get a job, 23 A. Yeah, about a year. I don't know actually
24 that's good. 24 have that.
25 Do they want you to come back to Palm Beach 25 Q. So you went £roil
110•••••050i..../
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1
2
MR. HOROWITZ: Do you want to show her that?
MR. CRITTON: That was in Exhibit 2. She
1
2
Q.
A. They are liquor too.
does what? I
3 should have it right in front of her. 3 Q. But they are two different entities?
4 MR. HOROWITZ: That was like eight exhibits 4 A. Yes. One is just like a modeling agency.
5 aga 5 Well, its just like an agency where they have girls
6 MR. CRITTON: I can help you. Maybe you need 6 that they hire to like the liquor company, and that's
7 an assistant to help you sort through the exhibits. 7 out of Tampa, but they have jobs in jobs in Orlando that
8 BY MR. CRITTON: 8 I do. I have driven to Tampa before.
9 say you worked 9 Q So you will go to Tampa to do this work too?
10 at 10 A. Yes, sometimes.
11 A. Yes. 11 Q. How much do you get paid for doing that?
12 Q. In 2007. That was the only job you had in 12 A. $25 an hour.
13 2007, correct? 13 Q. 25 bucks an hour?
14 A. Yes. 14 A. Uh huh.
15 Q. Okay. And then 2008 was part of 15 Q. All you have to do is go to a bar, look
16 your — I think you told us earlier it w pan
toyour 16 pretty, have a cute outfit on, and hand out liquor?
17 work experience through school? 17 MR. HOROWITZ: Form.
18 A. Yes. 18 THE WITNESS: Yes.
19 Q. Okay. And you worked them for all of 2008? 19 BY MR. CRITTON:
20 A. Yes 20 Q. 'filets basically it, isn't it?
21 Q. Did you work anyplace else in 2008? 21 MR. HOROWITZ: You are jealous.
22 A. 2008, no,1 don't believe so. 22 BY MR. CRITTON:
23 Q. way, were you with hum Doe 4 when she 23 Q. This is not professional work. I couldn't do
24 w v up in Orlando and she went P 24 it. I wouldn't look good in a skirt.
25 and tried OM as a stripper? 25 But in essence, they give you 25 bucks an
Page 328 Page 330
1 A. No. 1 hour, and bow long is the gig usually?
2 Q. Are you aware of the circumstances of her 2 . A. It depends. Sometimes ifs like four bars we
3 doing it? 3 go to, sometimes ifs two. Sometimes it's five bars.
4 A. I learned about it. 4 Q. So it might be six to ten hours?
5 Q Who did you hear about it from? 5 A. Its neva ten hours, but ifs usually from
6 A. Jane Doe 4 told me. 6 lace three to five hours.
7 Q. What did she say about it? 7 Q. All right. Do they pay in cash?
8 Nothing really. She just said she went to 8 A. No, I get a paycheck.
9 work and it was her birthday and they were just 9. Q. So you get a 1099?
10 n of joking around. 10 A. Yes.
11 Q. Did she tell you she got up on the stage and 11 you work f
12 danced for a while and made some money? 12 or during the course o a mon
13 A. She didn't tell me she made money. She just 13 A. About e twice a week maybe, so —
14 said she did it as a joke. 14 Q. Is it almost exclusively in Orlando? You said
15 Q. And now where are you currently working again? 15 you have been to Tampa.
16 Tell me a in. 16 A. Yes.
17 A. 17 Q. Have you been to any other cities other than
18 Q. That's what? Is 18 Tampa?
19 that, is that all the same company? 19 A. No.
20 m i l They are two differen 20 Q. If you have to go to Tampa, do they put you up
21 is separate. And then are the 21 overnight?
22 same co n . 22 A. No.
23 Q. are the liquor people, 23 Q. How long have you been doing this twice a
24 right? 24 week?
25 A. Yes. 25 A. I meanIdon't always do it twice a week. I
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started picking up more shifts now that I only have 1 A. No.
three classes. Last semester I was taking six classes, 2 Q. Jane Doe?
3 sol didn't really have time to do that much. 3 A. No.
4 Q. Now you do it approximately two times a week? 4 Q. Jane Doe 6?
5 A. Yeah, I try to pick up as many shifts as I 5 A. No.
6 can. 6 Q. Jane Doe 2?
7 Q. And they just go to different ban in Orlando? 7 A. No.
8 A. Not just bars. Restaurants too. B Q. L.L.?
9 Do you have my Advil at all? 9 A. No.
10 MR. CRITPON: Let's go off the record. 10 Q. K.H.?
11 THE VIDEOGRAPHER: Going off the record, 11 A. Yes.
12 4:21 p.m. 12 Q. How do you know K.H.?
13 (A recess was taken.) 13 A. She goes to my school, or went to my school,
14 THE VIDEOGRAPHER: We're back on the record at 14 high school.
15 4:48 p.m 15 Q. How about Jane Doe 101?
16 BY MR. CRITTON: 16 A. Sounds kind of familiar.
17 Q. Ma'am, have you ever been treated in a drug or 17 Q. But you can't place her?
18 an alcohol program? 18 A. I./ uh.
19 A. No. 19 MR. HOROWITZ: No?
20 Q. Have you ever had an HIV test? 20 THE WITNESS: No.
21 A. No. 21 BY MR. carrroN:
22 Q. To the best of your knowledge, you are not HIV 22 Q. How about L.P, does that mean anything to
23 positive? 23 you?
24 A. No. 24 A. No.
25 Q. All right. Have you ever had any surgery of 25 Q. Is K.H. your age or older?
Page 332 Page 334
1 any kind? 1 A. She's a year older than me.
2 A. Just wisdom teeth. 2 Q. Who was she friends with? Let me rephrase the
3 Q. I'm sorry, have you ever bad any cosmetic 3 question.
4 surgery? 4 Was she friends with any of your friends, your
5 A. No. 5 group?
6 Q. Have you ever been pregnant? 6 A. Yes.
7 A. No. 7 Q. Who?
8 Q. Jane Doe 3, how long have you known her? 8 A. Jane Doe 4 and Jane Doe 3.
9 A. Since i was a sophomore in high school. 9 Q. Do you know whethe= ever went to
10 Q. So that would have been the '03 time period? 10 Mr. Epstein's home?
11 A. Yes. 11 A. Well Id me I think she went there.
12 Q. And was Jane Doe 3 your age? 12 Q. This S t°
13 A. She was a year younger than me. 13 A. Yes, she is also friends witi= too.
14 Q. How did you all become friends? 14 Q. I'm sorry?
15 A. I believe Jane Doe 4 knew her and her sister. 15 A. She is also friends with., good friends.
16 Q. Jane Doe 4? 16 Q. Were you aware, 'think you told me earlier,
17 A. Jane Doe 4. 17 and I may have forgotten, you told me you were aware
18 Q. Does she go by Jane Doe 4? 18 back at the time when you ing to Mr. Epstein's or
19 A. I mean no. T call her Jane Doe 4. 19 around that time period thaarhad been there to
20 Q. Okay. It might have been my heating. So she 20 Epstein's as well?
21 was a friend of Jane Doe 4's? 21 A. Yes.
22 A. (Witness nods head up and down.) 22 And she told you on or about that time that
23 Q. Have you ever met anybody by the name WM? 23 had been there?
24 A. of sounds familiar. 24 A. No, I didn't ford out abotiM. until --
25 25 Q. When did you find that out?
10.1calb:GSPAI t.
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A. When I wiling =when I told you 1 A. We didn't really talk about it. The only
2 recently I talked a about it. 2 girls I talked about it with would be Jane Doe 4 and
3 Q. Did she say anything aboulM., whether she 3 Jane Doe 3.
4 had brought any kind of action against Mr. Epstein or 4 Q. Okay. That's what my uestion is. Did any of
intended to bring any action against him? 5 those individua Jane Doe 3 , Jane
o A. Yeah, I think she said she had a lawyer, but 6 Doe , ever say to you that anything that
she didn't really go into detail. 7 had occurred, at the time that anything that had
Q. Did she know what had happened, whether the 8 occurred was inappropriate?
9 lawyer had filed a lawsuit or not? 9 A. I mean I didn't talk about it with diem.
10 A. No. 10 Q. So nobody brought it up and said "You won't
11 Q. So at least back at the time you lava, 11 believe what happened"? Nobody said something like to
12 but you didn't, you had no knowledge that she had been 12 you?
13 to Mr. Epstein's house? 13 A. No, they all kind of kept it to themselves I
14 A. No, we weren't good friends. I just know of 14 think because they were embarrassed.
15 her because she was friends with my friends. 15. Q. So no one said did anyone ever tell you
16 Q. Of the people that you knew who went to 16 that Mr. Epstein had been in any way aggressive with
17 Mr. Epstein's house back in the time peril. 17 them, had used any kind of physical or verbal force or
18 were there, it would have been Jane Doe 3 18 had coerced them to do anything, or that issue never was
19 A. Yes. 19 discussed back then?
20 Q. You are pretty sure..? 20 A. We just didn't discuss it.
21 A. Yes. 21 Q. But no one raised it? If something had
22 Q. Jane Doe 4? 22 happened and somebody had discussed it, that's something
23 23 that you would have remembered?
24 Q. 24 A. Yes, l don't know.
25 A. Yes. 25 Q. With regard to Jane Doe 3, you said you knew
Page 336 Page 338
1 Q. An 1 her when she was -- so you. ould have been a junior, she
2 A. Yes. 2 would have been a sophomore?
3 Q. Anyone else have I missed? 3 A. I think I knew her my sophomore year when she
4 A. I don't think so. 4 was a freshman.
S Q. okay. As to arm. 5 Q. So she would have been a freshman?
A. I heard of a girall. but I didn't know her. 6 A. Yeah.
7 Q. Do you leumnbe last name? 7 Q. Were you aware that — let me strike that. Do
8 A. No. 8 you know whether you had gone to Mr. Epstein's before
9 Q. If I said would that mean anything 9 Jane Doe 3 went or whether she went afterward, after you
10 to you? 10 had already gone? Does that make sense?
11 A. I don't know if that was her last name or not. 11 MR. HOROWITZ: No, try that again.
12 Q. Just somebody name= Do you remember 12 BY MR. CRITTON:
13 what she looked like? 13 Q. Okay. Do you know whether you went to
14 A. Blonde hair. 14 Mr. Epstein's first or Jane Doe 3 went to Epstein's
15 Q. Older? 15 first?
16 A. I think she was in our grade. 16 A. No.
17 Q. Just not in your friend group? 17 Q. You don't remember?
18 A. No. 18 A. No.
19 Q. Of the females Jane Doe 3, 19 Q. Okay. if I asked you to assume that Jane Doe
20 Jane Doe 4, did any of those people ever 20 3 says that she went to Mr. Epstein's after you had
21 tell you that Mr. Epstein — and tell you now, not vault 21 already been there, would you dispute that?
22 you assume — that anything had happened back at the 22 A. I mean yes, because I don't really know, I
23 time, that anything had ever occurred at Mr. Epstein's 23 don't remember.
24 house that had been, they considered to be 24 Q. But so if Jane Doe 3 said no, I asked Jane Doe
25 inappropriate? 25 7 and Jane Doe 7 said she had been to Mr. Epstein's
11 (Pages 335 to 338)
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1 before -- 1 Okay. Did you go out with her?
2 MR. HOROWITZ: Fonn. 2 Yes.
3 THE WITNESS: If that's what she said -- 3 Q. Where did you all go?
4 BY MR. CRITTON: 4 A. Went to Noche.
5 Q. Then you would go with her recollection on 5 Up in Palm Beach Gardens?
6 that? A. Yes.
7 MR. HOROWITZ: Form. That's at the Soverel Marina?
8 THE WITNESS: Yes. 8 A. Yes.
9 BY MR. CRITTON: 9 Q. Who else
10 Q. Do you know how many times -- well, let me 10 A. Just her at and two other girls I didn't
11 strike that, because you don't remember of your own 11 know.
12 independent recollection who went first, Jane Doe 3 or 12 Q. MM. nix)?
13 you. 13 A.
14 Did Jaw Doe 3 ever express to you that 14 Q. Do you know whether J.S., was she one of your
15 anything inappropriate — let me strike that. 15 friends too back at that time?
16 Have you ever discussed what Jane Doe 3's 16 A. Yes.
17 visits were with Mr. Epstein? Did you ever discuss that 17 Q. Did she ever go to Epstein's?
18 with her? 18 A. Yes.
19 A. No. I mean she shared her feelings about him 19 Q. How do you know that?
20 with me, but she never discussed what happened. 20 A. Because she told me.
21 Q. And when you said her feelings, is that 21. Q. Why did she tell you? What made her tell you
22 recently? 22 that?
23 A. I mean I don't remember if she did back then, 23 MR. HOROWITZ: Form.
24 but she has recently. 24 THE WITNESS: I don't remember.
25 Q. Pardon? 25
Page 340 Page 342
1 A. I don't remember what she said about him back 1 BY MR. CRITTON:
2 then, but I mean recently she has. 2 Q. Did she know that you had been to Epstein's?
3 Q. And what has she said recently? 3 A. Yes.
4 A. Just that she thinks he's lice a horrible 4 Q. Did she know that you area plaintiff in a
5 person and she thinks that the justice system didn't 5 lawsuit?
6 work for him at all, and she told me about how he's nov, 6 MR. HOROWITZ: Form.
7 on probation and out of jail, and just stuff like that. 7 THE WITNESS: Yes.
8 Q. With Jane Doe 3, have you ever met her 8 BY MR. CRITTON:
9 husband? 9 Q. How did she know you were a plaintiff in a
10 A. No. 10 lawsuit?
11 Q. Did you know she was married? 11 MR. HOROWITZ: Form.
12 A. Yeah, she told me. 12 THE WITNESS: I don't know who told her. She
13 Q. When is the last time you talked to Jane Doe 13 asked me about it.
14 3? 14 BY MR. CRITTON:
15 A. I talked to her recently. 15 Q. Did you confinn to her that you had in fact
16 Q. Last couple of weeks? 16 brought a suit against Mr. Epstein?
17 A. Yes. 17 A. Yes.
18 Q. When is the last time you saw her? 18 Q. If somebody asks you whether you are a
19 A. The last time I was down in Palm Beach. 19 plaintiff in a lawsuit against Mr. Epstein, do you tell
20 Q. Which was when, February? 20 them yes?
21 A. No, I don't really remember. 21 A. If they are one of my close friends. If I
22 Q. Where did you see her? 22 don't know them, no.
23 A. Actually I saw her, I was recently, I was here 23 Q. Okay. Wein, is she a friend as you
24 before I went down to Key West and I saw her. It was 24 described earlier?
25 her birthday. 25 A. Yes.
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1 Q. Or a good friend? 1 A. Yeah.
2 A. She's a friend, yes. 2 Q. And she said she had given a deposition?
3 Q. Someone you might trust or you might not? 3 A. Yes.
4 A. She knew about it before when we were in high 4 Q. Do you know if she's married?
5 school. 5 A. She said she was divorced.
6 Q. She knew what, that you had gone there? 6 Q. She told you she was divorced?
7 A. Yes. 7 A. Or they are separated, not divorced, I think
8 Q. How did she know? Q. Which did she tell you?
9 MR. HOROWITZ• Form. 9 A. !think separated.
10 THE WITNESS: Everybody knew. She was in our 10 . Q. Did she tell you why?
11 friend group. 11 A. I think she was kind of embarrassed about it,
12 BY MR. CRITTON: 12 so she didn't really go into detail with me.
13 Q. So ever/body who was in your Mend group knew 13 Q. Did you go to her wedding %Olen she got
14 who had gone to Epstein's? 14 trawled?
15 A. I mean basically it was me, Jane Doe 4,E, 15 A. No.
16 lane Doe 3, we were all friends, so we all knew. 16 Q. Have you ever — she has a child, doesn't she?
17 Q. And did J.S. ever describe her visits, visit 17 A. No.
18 or visits to Epstein's? 18 Q. She doesn't have a child?
19 A. I think she only watt once. 19 A. No.
20 Q. Did she tell you why? 20 Q. Jane Doe 3, was she someone, Jane Doe 3, did
21 A. Yeah, she said that he like seared her or 21 you see her do, when she drank with you all in high
22 something and tried to like make her do something and 22 school, alcohol?
23 she never went back. 23 A. Yes.
24 Q. Okay. Were you still going to Epstein's at 24 Q. And did you see her do drugs in high school?
25 the time you heard that? 25 A. No.
Page 344 Page 346
1 A. I don't remember when it was. 1 Q. Okay. So if she was doing cocaine or erctacy
2 Q. Did you say to her that never happened to me? 2 or xanax, again, you never saw it?
3 A. I don't remember exactly what I told her. 3 MIt HOROWITZ: Form.
4 just remember her telling me that. 4 THE WITNESS: No. My friends knew I didn't do
5 Q. Did she say that she has any interest in 5 it, so some of than would tsy to hide it or not do
6 bringing a lawsuit against him? 6 it around me. So I never really saw them, whoever
7 A. No. 7 did what.
8 Q. Did she ask you how your lawsuit was going? 8 BY MR. CRITTON:
9 A. Na 9 Q. I think you told too you've never been in a
10 Q. When you saw Jane Doe 3, you went to Noce, 10 hospital?
11 what time did you all meet? 11 MR. HOROWITZ.: Form.
12 A. I think around eleven. I was driving home 12 BY MR. CRITTON:
13 from Orlando to visit my parents and then go to Key 13 Q. Right?
14 West. 14 A. Not that I can recall, no.
15 Q. And how long did you stay? 15 Q. I asked you what you told the Palm Beach
16 A. Not long just like two hours. 16 police the first time you went to Mr. Epstein's house.
17 Q. Had a couple ofdrinks and then headed home? 17 what you told them as to how you ended up going to
18 A. Yes. 18 Epstein's. I asked you what you had told them.
19 Q. Did Jane Doe 3 tell you that she had given her 19 Now my question to you is I never asked you
20 deposition at that point? 20 what you told the FBI. At this point I'm beyond that,
21 A. [don't think she has given it yet, at that 21 so let me ask this question.
22 point, no. 22 How did you first hear that other people in
23 Q. But you subsequently talked to her? 23 your grade or at school were going to Mr. Epstein's
.24 A. Yes, recently. 24 home? Who did you hear that from?
25 Q. Over the phone? 25 A. I mean I just remember the first tirne I beard
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1 about it w' asking me to go. And then after that, 1 A. No.
2 2 Q. All right. She just said "If you want ajob,
3
4
II remember Jane Doe 4 talking about it and then
Q. And you said asked you to go. And at
3
4
you want to make some money, you have to give a
massage."
5 that time I think you said it was, you remembered it 5 You said, "I'm not a professional, but I've
6 being in gym class or something like that. 6 given massages before"?
7 A. Yes.. 7 A. Yes.
Q. AndM. was in your grade? 8 Q. Who had you ever given a massage to?
9 A. She was a grade ahead ofme, but anybody could 9 A. I don't remember, just girlfriends mainly,
10 have gym together. 10 like back massages.
11 Q. So what specifically clid say to you, your 11 Q. So did you este when she said, you know.
12 best recollection? 12 you can make some money, did she tell you how much you
13 A. She asked me it if I needed a job and if I 13 could make?
14 needed money, and then she asked me if I knew how to 14 A. Yeah, l think she said 5200.
15 give a massage. And I said yes, but not professionally. 15 Q. And did she say whether she was going to make
16 And she told me that was fine. 16 any money?
17 And then she told me how she knows a guy that. 17 A. No.
18 lives in Palm Beach and will pay me if I give a massage. 18 Q. And did you say okay, did you say "Yeah, I'm
19 Q. You had been to Palm Beach before? 19 interested"; or "No, I'm not interested, let me think
20 A Yes. 20 *bout it"?
21 Q. And I assume based on what you told me earlier 21 A. I told ha I was interested.
22 you had been to the beach in Palm Beach? 22 Q. Why were you interested in any way well,
23 A. Yes. 23 let me ask you this. Did you say "Well, where exactly
24 Q. And had your dad driven you over there in Palm 24 is the massage going take place?"
25 Beach because this is where I work, this is the kind of 25 A. I didn't ask her any of the details. 'just
Page 348 Page 350
1 houses i inspect? 1 was interested in making money, I
2 A. He works like downtown. He doesn't work like 2 Q. So when is the next time yottle had some
3 on Palm Beach island. 3 conversation about it?
4 Q. Where does he work when you say downtown, West 4 A. The next time is she just, I'm pretty sure
5 Palm? That's where his office is? 5 like when I actually went there.
6 A. Yeah, West Palm. 6 Q. Did she say at school, "Hey, we're going to go
7 Q. Okay. Had he ever driven you over there? 7 on Tuesday or whatever?
8 A. I mean yeah, he's driven over there to go to 8 A. I don't remember.
9 the beach and stuff. 9 Q. On any of the times that you ever went to
10 Q. Had you walked up and down at times, you and 10 Mr. Epstein's, did you ever miss school to go?
11 your mom at times walked up and down Worth Avenue and 11 A I went on — no, I usually went after school.
12 then gone over to the beach just to look? 12 Q. What time? What time did you get out of
13 A. !mean yeah, i guess. 13 school, like two, three o'clock?
14 Q. It's a tourist spot? 14 A. Yes.
15 A. Yes, I've been to Worth Avenue before. 15 Q. So you would go after you got out of school?
16 Q. All you were familiar with Palm 16 A. Yes.
17 Beach befo said — so when she said there is a 17 Q. .And on the first occasion, how did you know
18 guy over in Palm Beach, you knew where Palm Beach was 18 that going to go a particular day?
19 and you had been on the island before, correct? 19 A. told me. i guess she made plans with
20 A. Yes. 20 Sarah or Jeffrey.
21 Q. And did she tell you how old the person was, 21 Q. Tell me what you know at you guess. St
22 how old this guy yeas? 22 let me ask you again. What di say to you?
23 A. No. 23 A. I don't remember exactly. I just remember her
24 Q. She didn't tell you whether he was 20 years 24 asking me, and then I forget how we actually, when we
25 old or 50 years old or 100 years old? 25 made plans to go there, like what day, but — and then I
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1 rememberus mg there. 1 A. Yes.
2 Q. As= drove? 2 Q. What did you anticipate, and their arms and
3 A. Yes. 3 their hands and their feet, necks, their head sometimes?
4 Q. What did she have at the time? Did she have a 4 A. What did 1 anticipate I was going to do?
5 car, a truck, SUV? Q. All right. If you — had you seen that on TV?
6 A. She had a truck. 6 A. I mean yeah, !guess.
7 Q. What did it look like, do you remember? 7 Q. Okay. So if you had seen that on TV, did you
A. Maroon. 8 assume that when you went over to earn money to do a
9 Q. Maroon, all right. Now before you went, did 9 massage and you weren't, as you said, you weren't a
10 you talk with her again and say "Okay, what am 1 10 professional, that you were going to give some guy a
11 supposed to wear?" 11 massage, so you would be massaging basically a large
12 A. No. That first conversation, she just told me 12 part of his body?
13 to dress cute. 13 A. Yes.
14 Q. Dress cute? 14 Q. And you understood, or I assume from having
15 A. Yeah. 15 seen it on TV, you understood that people who have
16 Q. What's that meat to you or what did that mean 16 massages, males or females, oftentimes they are on
17 to you? 17 either their back or their stomach and then their
18 A. I don't know. f just wore like my bathing 18 private parts are covered only with a towel, but they
19 suit, because she said -- like we were planning on going 19 are naked underneath?
20 to the beach after. And then I wore a skirt and a tank 20 A. Yes.
21 top? 21 Q. All right. Now, so you are going over there,
22 Q. So you wore a bathing suit, tank top, skirt 22 at leas= tells you you are going to get 200 bucks
23 and like flip-flops? 23 for giving a massage fora guy, so you knew it was a
24 A. Uh huh. 24 male.
25 Q. Yes? 25 Did you ask her at the time how old is this
Page 352 Page 354
1 A. Yes. 1 person?
2 Q. Did you say "Wait a minute, why do 1 have 2 A. No.
3 to — even if we're going to the beach afterwards, why 3 Q. Why not?
4 do I have to dress cute for this massage?" 4 A. !just, I didn't think about it. I remember
5 A. I don't, I don't really remember. 1 was 5 asking her like why he doesn't just hire somebody to
6 confused. 6 give him a massage, and she told me he doesn't like
Q. What's confusing about that? 7 professional people, lace professional massages.
8 A. 1, she could have meant like dress, you know, 8 Q. Okay. As you described yourself earlier, you
9 professionally, like massage people dress cute, I don't 9 said you arc of above average intelligence, so did you
10 know. I was like 16. I don't remember. 10 say to her at that time wait a minute, why doesn't —
11. Q. Okay. Where had you ever seen -- had you ever 11 you had certainly the common sense to say why doesn't he
12 had a massage yourself? 12 hire a professional masseuse, and she said well, he
13 A. No. 13 doesn't like those.
14 Q. Had you ever been to a spa? 14 Did that send off a little bell in your head
15 A. No. I have seen spas before. I have never 15 to go gee, why am I going and getting paid $200 versus a
16 actually been. 16 professional massager, masseuse?
17 Q. Had you ever seen anyone have a professional 17 MR. HOROWITZ: Form.
18 massage? 18 THE WITNESS: I mean I didn't know. I didn't
19 A. Yeah, like on W I have seen people. Not like 19 really think about it.
20 in person, but I have known the — 20 BY MR. CRITTON:
21 Q. And do you know when you give someone a 21 Q. You thought about it enough to ask why doesn't
22 massage, that is a professional massage, you are 22 he get a professional, right?
23 massaging their legs and their thighs and their back and 23 A. Yeah.
24 their neck, and then they flip over and you do the front 24 Q. Did you say okay —1 assume when you have
25 of their legs, things like that? 25 seen people on TV give massages, you have seen they have
15 (Pages 351 to 354)
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been in basically in uniform, sometimes they are in a 1 A. I think she might have said that.
2 white uniform or may have a polo shirt on and pants or 2 Q. Did she, did you express any concern, like is
3 shorts, right? 3 this guy going to be pushy? Is he nice? Is he an angry
4 MR. HOROWITZ: Form. 4 kind of person? You know, is he going to be physical
THE WITNESS: Yes. 5 with me or verbally abusive in any way?
6 BY MK CRTITON: 6 Did you ask any of those questions?
Q. Have you ever seen people again separate and 7 A. No.
8 about from — well, let me strike that. Q. Did she say anything when you said — I said
9 Have you ever seen people give massages in the 9 did she say anything about that she he was nice and you
10 movies, other than when a guy is giving a girl a massage 10 wouldn't have to worry, and you said you remember her
11 that they have a relationship, where someone shows up in 11 saying something about him being nice, right?
12 a swimsuit or a cute little tank top and a skirt? 12 A. Yes.
13 MR. HOROWITZ: Form. 3 Q. Okay. Did she say that he wouldn't use any
14 774E WITNESS: No. 14 physical force or violence or any kind of coercion, that
15 BY MR. CRITTON• 15 you could feel safe?
16 Q. All right. St tells you to dress cute. 16 MR. HOROV/ITZ: Form.
17 You are going to give a guy who doesn't want 17 THE WITNESS: I mean she never said it that
18 professional massage a massage, and you arc not 18 way.
19 masseuse, right? 19 BY MR. CRTITON:
20 A. Yes. 20 Q. Did you assume that?
21 Q. And you didn't ask how old he is, correct? 21 A. When she said he was nice and she's already
22 A. Correct 22 done it, I assumed it
23 Q. Okay. Did you ask who was going to be there? 23 Q. Okay. Did she tell you if he, if you are
24 A. No. 24 asked your age, to say you are over 18?
25 Q. Did you ask where it's going to be done? 25 A. No.
Page 356 Page 358
1 A. Yes. 1 Q. So in. says that's what she told you, that
2 Q. And she said? 2 would not be hue or you just don't remember?
3 A. At his house. 3 A. No, that would be a lie.
4 Q. Okay. Did you say "Why are we doing it at his 4 Q. Kind of like what you told the Palm Beach
5 house?" 5 police?
6 A. I don't remember. 6 MR. HOROWITZ: Form, argumentative.
7 Q. Did you say "Where are you going to do it in 7 BY MR. CR1TTON:
8 the house?" 8 Q. Right?
A. I don't remember. 9 A. I guess you would say that.
10 Q. Did you ask her "Am I going to M., are 10 Q. Did she ever say anything that you might be
11 you going to be there too?" 11 asked to remove your clothes or take off an article of
12 A. She was the one that was bringing me, so yeah, 12 clothing?
13 I obviously assumed she was going to be there. 13 A. No, not the first time I went.
14 Q. So you assumed she was going to be there. So 14 Q. Did she ever give you any indication that you
15 what, did you say "What parts of his body do I have to 15 should be — well, let me strike that.
16 massage?" 16 Okay, so she makes an arrangement for a time.
17 A. Uh uh, ask She told me like — 17 You don't know how, but she tells you we're going over
18 Q. Go ahead. 18 there at such and such a time, dress cute, right?
19 A. She told me his legs and his feet is what she 19 A. Uh huh.
20 usually does, but I then never really. 20 Q. Yes?
21 Q. Okay. Do you remem telling you that, 21 A. Yes.
22 in fact, it was an older man, late miles, fifties? 22 Q. She pit you up?
23 A. No. 23 A. I don't — we 'night have left after school.
24 Q. Do you remember her telling you he was a nice 24 Q. So you might have left right from school?
25 guy? 15 A. Yes.
16 (Pages 355 to 358)
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Q. Did you just take clothes with you from 1 A. 1 think so. I don't remember what I ate. I
2 school? 2 remember like offering food. He was cooking.
3 A. Well, we were going to the beach after, so I 3 Q. Art went upstairs. Did Mr. Epstein come
4 probably, l remember wearing my bathing suit. 4 down?
Q. Did you in fact go to the beach afterwards? 5 A. No, I think she just came back down and told
6 A. Yes. 6 me to go upstairs.
Q. InPalm Beach? 7 Q. Told you to go upstairs?
A. Yes. 8 A. Yes.
9 Q. All right. So do you remember what time of 9 Q. Tice first time that you went to the tein
10 year it was now? In thinking of that, it had to have 10 home, did you actually go up or did onl go up?
11 been warm if you were going to the beach or at least 11 A. I remember I went once wit hen she just
'
12 decent. 12 went up.
13 A. Yes. 13 Q. Was that the first time?
14 Q. And it was just the two of you? 14 A. Yes, I think that was the first time.
15 A. Yes. 15 Q. So the first time you were there --
16 Q. On the way over there, did you discuss what 16 A. Or actually — I don't remember correctly.
17 you were going to be doing? Were you nervous at all? 17 Q. Okay.
18 A. I mean f was a little bit nervous, but I — we 18 A. I don't, I l WIAlliber just going once with her
19 didn't really talk about what we were going to be doing. 19 when she did her s And then —
20 Q. So you got to the house. Did she park on the 20 Q. She meani
21 driveway or on the street? 21 A. Yes. So yeah, I remember the first time 1
22 A. The driveway. 22 went there to do it.
23 S. When you got out of the ear, did you say to 23 Q. Da tell you she had been there before?
24 at any time before you got out of the car, "You 24 A. Yes.
25 know, this doesn't seem like a great idea, I think I 25 Q. Okay. So at least onetime you went wit=
Page 360 Page 362
1 don't want to do it"? 1 where she went up and gave the massage and you just sat
2 A I mean no. When I got there, I was kind of 2 in the kitchen?
3 conflated by everything, but I didn't really say that to 3 A. Yes.
4 her. 4 Q. Do you remember that being the first time or
5 Q. Why not? 5 another time?
6 A. I mean I didn't know what was going to go on. 6 A. I think it was no, it was the second time,
7 Q. Well, you could have t time turned 7 because I didn't know the first time what —
8 around and said, "You know I don't really feel 8 Q. Okay. So the first timMeme back down
9 like doing this," right? 9 and she said you can go upstairs?
10 A. Yes. 10 A. Yes.
11 Q. So you had to -- again, it was your decision. 11 Q. Did she take you upstairs?
12 You could either say yes or no, and you said yes, I'm 12 A. Yeah, she walked up there with me.
13 going to go into the house, right? 13 Q. So you followed her?
14 A. Yes. I mean the first time she didn't tell me 14 A. Yes.
15 what was going on at all, so — 15 Q. Did you go up a stairway, I assume?
16 Q. You go in the house. Was there? 16 A. Stairway, yeah.
17 A. There was a cook there 17 Q. Anything unusual about the stairway?
18 Q. And you were in the kitchen? 18 A. There were just like weird pictures like on
19 A. Yes. 19 the skle of the wall.
20 Q. And what happened then? 20 Q. Of what?
21 They just like offered me food and water and 21 A. They were pictures of like girls, pictures of
22 Milinlintroduced herself to rne. And she went up and got 22 boobs, pictures of like weird drawings.
23 Jeffrey. 23 Q. Arts kind of pictures?
24 Q. Okay. Did you eat anything when you were 24 A. Arts, but then there was some kind of weird
25 there? 25 pictures of girls with boobs and naked pictures.
17 (Pages 359 to 362)
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1 Q. Describe — you said there were some art 1 A. Yes.
2 pictures on the wall that had what, naked people or 2 Q. Did she tell you what you were supposed to do
3 portions of torsos or something? 3 or what you were supposed to use or anything like that?
4 A. Yeah. 4 A. She said there was like massage oil, and she
5 Q. And then you saw a picture of another 5 like pointed to the massage oil. And that's all I think
6 picture where women were, didn't have tops on? 6 I can remember her saying.
7 A. And I saw a picture of a little girl. 7 Q. Were you nervous at all?
8 Q. Okay. And how was she dressed? 8 A. Yes.
9 A. She had like a dress on. 9 Q. Did you say UM "You knew what, I dont
10 Q. All right. 10 think I want to do this, l think I'm out of here"?
11 A. I think that was his daughter that I saw there 1 A. I fek like I was kind of pressured and put in
12 before. 12 a weird position where I just felt hie I kind of had to
13 And then I walked into the room and there were 13 do it because I there.
14 more pictures there of girls and weird art pictures. 4 Q. Becaus had put you in that position?
15 Q. Again, just, you say weird art pictures, 15 A. I mean -
16 just - 16 MR. HOROWITZ: Form.
17 A. Just I don't know, weird torso and boob 17 THE W'ffNESS: Well, Jeffrey walked in.
18 pictures, I guess. 18 BY MR. CRITION:
19 Q. Of different parts of bodies, pictures? 19 Q. No, before Jeffrey got there.
20 A. Yes. 20 A. Well, not just because' no. Just in
21. Q. And there were other pictures of girls? 2.1 general, I already said I would do it.
22 A. Yes. 22 Q. Because you committed kind of?
23 Q. Anyone that you recognized? 23 A. Yes.
24 A. No. 24 Q. So you felt that you — well, all right So
25 Q. Anyone that you had ever seen at the house? 25 you got up there, she shows you the lotions. Does=
Page 364 Page 366
1 A. I don't think so. 1 leave before Jeffrey comes into the room?
2 Q. Were they clothed or unclothed? 2 A. I think so, yes.
3 A. I think they were undressed. 3 Q. Okay. So you are what, just standing by the
4 Q. Completely or just tops? 4 table?
A. I remember their breasts were showing. 5 A. Yeah.
Q. That's what you remember seeing? 6 Q. And what happens?
7 A. Yes. 7 A. And then Jeffrey comes in.
Q. And you don't know who they were? 8 Q. And what's he do? How is he dressed?
9 A. No. 9 A. I think he just had a towel around him.
10 Q. Or how old they were? 10 Q. Okay. What color was the towel?
11 A. No. 11 A. White.
12 Q. Did they appear to be adults to you? 12 Q. And describe it.
13 A. They could have.. 13 A. He just had it like around his waist.
14 Q. So then you go i walks you into a 14 Q. Describe Mr. Epstein.
15 room? 15 A. Like his body?
16 A. Yet 16 Q. Yes. Tall, short?
17 Q. And whafs there? 17 A. He's a taller guy, has gray hair, kind of
18 A. There was a shower, like a vanity, the massage 18 hairy, kind of bigger, not fat, but like bigger build,
19 table. She like already had it set up. 19 blue eyes, like a longer face.
20 Q. Had you ever seen a massage table before? 20 Q. All right Did he introduce himself?
21. A. Just not l mean in movies. 21 A. Yes.
22 Q. Movies again. Did she say anything to you? 22 Q. What did he say?
23 A. She just said that Jeffrey would be in 23 A. Just said "Hi, I'm Jeffrey."
24 shortly. 24 Q. And you said?
25 Q. And did she leave then? 25 A. I said, "Hi, I'm Jane Doe 7, Es friend."
18 ( Pages 363 to 366)
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Q. Did you shake hands? 1 Q. Next to his right ann?
2 A. I thirdcso. 2 A. Well, I mean if you are looking at him this
3 Q. And what did he do? 3 way, I was over here.
4 A. And then that's when he got on the massage 4 Q. Well, you say he was lying down, so as he was
S table and he, that's when basically like the first time 5 lying down, were you near his right shoulder or his left
lgave a massage and he said that he would like his feet 6 shoulder?
7 and his calves massaged, and he was turned over. 7 A. When he was lying down, l was near his left
Q. So he was on his back. How long did the 8 shoulder.
9 session last? 9 Q. As you were massaging his chest —
10 A. It lasted for about, about half an hour, I 10 MR. HOROWITZ: You mean lying down en his back
11 think. 11 or his stomach?
12 Q. About 30 minutes? 12 BY MR. CRITTON:
13 A. Yes. 13 Q. You said he was lying on his back?
14 Q. All right. And did you massage his feet? 14 A. Yes.
15 A. Yes. 15 Q. So you were near his right shoulder?
16 Q. Did you pick the oil that you were going to 16 A. His left shoulder.
17 use? 17 Q. His left shoulder, all right. And were you
18 A. Yes. 18 standing at his side er were you standing at the top of
19 Q. Had you ever used massage oil before? 19 his head, massaging his chest?
20 A. No. 20 A. On the side.
21 vita did you know which one to pick, just from 21 Q. All right And you say you Is.ard a humming
22 told you? 22 and then what happened?
23 A. Yes. 23 A. And then he just started reaching under his
24 Q. So you used the massage oil. You did his 24 towel and then he kind of like grabbed, he grabbed me
25 calves and his feet? 25 towards him and pulled me towards him.
Page 368 Page 370
1 A. Yes 1 Q. Where did he grab you?
2 Q. Did he turn over then? 2 A. He grabbed my buttocks and pulled me to him.
3 A. Towards the end, yes. 3 Q. When you say grabbed you, he put his hand
4 Q. So after what, you are 90 percent done, then 4 behind your buttocks and pulled you toward him?
5 he turned over? 5 A. Yes.
A. Yeah. 6 Q. Which hand?
7 Q. Okay. And he had a towel over him the entire 7 A. His left hand.
8 time? 8 Q. When he did that, what did you do?
9 A. Yes. 9 A. Felt really awkward arid got really scared. I
10 Q. Okay. And when he turned over, what did 10 think he could tell I was scared. And I got nervous and
11 you — did you continue the massage? 11 he, he kind of asked me if I was okay.
12 A. He turned over and then he asked me if I could 12 And I just told him I felt, I felt nervous.
13 like massage his chest. 13 And that's, that's when he like started to masturbate,
14 Q. And did you? 14 and that's when —
15 A. Yes. 15 Q. How do you know he was masturbating?
16 Q. All right. And then what? 16 A. Because I could, I could tell.
17 A. And then I was massaging his chest, and I 17 Q. Had you ever seen a guy masturbate before?
18 don't know, he started making noises. 18 . A. .Yes.
19 Q. Like what? 19 Q. Where?
20 A. Just like humming noises. 20 A. Die on TV.
21 Q. Hununing? 21 Q. On what, like a porno movie or something like
22. A. Yeah. Just, I don't know, weird noises. And 22 that?
23 then — . 23 A. I don't know, I knew what it was.
24 Q. Were you standing to his left or his right? 24 Q. Everybody learns about it at some point in sex
25 A. I was standing on his right. 25 education, right, male and female masturbation, right?
19 (Pages 367 to 370)
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Page 371 Page 373
1 A. Yes. 1 Q. Okay. Did he get up then?
2 Q. All right. It's part of life. You had seen 2 A. Yes.
3 it on TV before? Yes? 3 Q. Keep the towel around him?
4 A. Yes. 4 A. I know he like put on, grabbed a new towel,
5 Q. lied you seen it in the movies before? 5 and then I walked around the side and he got his money
6 A. Yes. 6 and gave me the $200.
7 Q. All right. Had you ever seen it in person 7 And then he asked me for my number. And he
8 before? 8 told me ifl had a friend, asked me if I had a friend
9 A. No. 9 that wanted to make money.
10 Q. All right. So you figured that's what he was 10 Q. And you said? So he asked you for your number
11 doing under the towel, right? 11 and said if you had a friend who would like come --
12 A. Yes. 12 A. Yes,
13 Q. All right. You didn't see it, you just 13 Q. What?
14 assumed that's what was going on? 14 A. l le said if I brought a friend, then I would
15 MR. HOROWITZ: Form. 15 make money.
16 THE WITNESS: Yes. 16 Q. Okay. And he gave you $200. You felt
17 BY MR. CRITTON: 17 awkward, scared and nervous.
18 Q. All right. So had he let go of you Men? He 18 Did you give him your phone number or did you
19 put his hand on your butt and pulled you toward him, 19 give him just a fake phone number?
20 when you said you felt awkward, scared and nervous and 20 A. I gave him mine.
21 he sensed that and you said "Im nervous," did he let go 21 Q. But you could have said "No, thanks, I'm done,
22 of you? 22 Pm not going to give you my phone number," right?
23 A. No. 23 A. Yes. I just felt scared and intimidated, so I
24 Q. Okay. Did he continue to hold on to your 24 gave him my number.
25 butt? 25 Q. But you could have given him any phone number,
Page 372 Page 374
1 A. Yes. 1 true?
2 Q. Did you ever — had you removed any clothing? 2 A. Umm, I suppose.
3 A. No. 3 Q. Okay. Did you feel intimidated?
4 Q. Had he ever asked you to remove any clothing? 4 A. Yes.
5 A. I think the first time, I fen so like nervous 5 Q. Did you feel uncomfortable?
6 and awkward, I don't think he asked me, no. 6 A. Yes.
7 Q. Well, all right. So your best recollection is 7 Q. Did you feel in any way embarrassed or
8 he didn't ask you to take any of your clothes oft? B humiliated?
9 A. The first time. A. I was kind of confused. Like he was like an
10 Q. So he pulled you towards him. You felt 10 older, powerful man and, you know, I just felt confused
11 awkward, scared and nervous, right? 11 about the whole situation at that point.
12 A. Uh huh. 12 MR. CRITTON: Okay. Let's take a break.
13 Q. You told him — yes? 13 THE VIDEOGRAPHER: Going off the record at
14 A. Yes. 14 5:28 pm. This marks the end of tape three.
15 Q. And you told him that? 15 (Disclicsion held off the record.)
16 A. Yes. 16 THE VIDEOGRAPHER: We are back on the record
17 Q. Okay. And then he was, from your perspective, 17 at 531 p.m. This marks the beginning of tape
18 was masturbating under the towel? 18 four.
19 A. Yes. 19 BY MR. CRITTON:
20 Q. And then what happened? 20 Q. You said that you thought Mr. Epstein — did
21 A. And then he was just making noises. And I 21 you know what his last name was at that time or you just
22 didn't see him ejaculate, but I'm assuming he 22 knew his name was Jeffrey?
23 ejaculated, because he stopped. And then that was -- 23 A. I thinkl knew, just thought it was Jeffrey.
24 Q. That was it? 24 Q. You said when he walked in the room, obviously
25 A. Yes. 25 you knew that he was, you know what his approximate age
20 (Pages 371 to 374)
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1 was? 1 money foe.?
2 A. He looked older, yes. 2 A. No.
3 Q. All right. When you say older, how old does 3 Q. Did you well, let me strike that. He gave
4 that mean? 4 you $200 he asked for your phone number and you
5 A. He looked like he was like 45, 50. 5 voluntarily gave it to him, correct?
6 Q. You said he was powerful. What made you think 6 A. Yes.
7 he was powerful? 7 Q. He asked you if you ever wanted to bring
8 A. 1 could just tell by his house. 8 someone else that wanted to come, he'd pay you to do
9 Q. Just because he had a big house? 9 that?
10 A. Yes. 10 A. Yes.
11 Q. Did you know anything about him? 11 Q. Did he tell you how much he'd pay you to do
12 A. No. 12 that?
13 Q. During the eight to ten times you claim that 13 A. 200.
14 you went, did you ever learn anything about him, what he 14 Q. And I think you described yourself at that
15 did fora living? 15 point as awkward, you felt the situation was awkward.
16 A. Yes, I think he told somebody — 16 scared, I think you used the word weird, you thought it
17 Q. No, what he told you, not somebody. 17 was inappropriate and you felt uncomfortable. Fair?
18 MR. HOROWITZ: No, no, that's how she learned. MR. HOROWITZ: Form.
19 She is explaining to you. 19 THE WITNESS: Yeah.
20 BY MR. CRITTON: 20 MR. HOROWITZ: Confused too.
21 Q. Let me stick with my question. Did you ever 21 BY MR. CRITTON:
22 learn from him what he did? 22 Q. Let's put confused there too. I'll add that.
23 A. No, he would talk about his friends in finance 23 So as you left, you gave him your phone
24 and he would be on phone calls sometimes when I was like 24 number, you listened to what he said about bringing
25 giving him massages. 25 somebody else, and what happened then? Did he go off?
Page 376 Page 379
1 And then he talked to me about how his friends 1 A. Yeah, I just left witty
2 like own yachts and, you know sail, because I told him I 2 Q. No, no, did he go off before you went back
3 wanted to get into hospitality and travel. So he told 3 downstairs?
4 me about his friends, and he said he would introduce me 4 A. Like walked off?
5 to one of his friends if I wanted to, because his friend 5 Q. Did he leave the room?
6 has like a yacht, and 1 could work on his yacht and just 6 A. I think he just walked me to the stairs.
7 stuff like that. So 1 just kind of assumed things. 7 Q. And he still had a towel around him?
8 Q. The friends, did he ever tell you who his 8 A. I think so, yeah, or a robe maybe.
9 friends were? 9 Q. You never saw him completely naked that day,
10 A. I saw pictures of like Bill Clinton, I think, 10 did you?
11 and 1 saw a picture with Donald Trump. He never told me 11 A. No.
12 who they were. 12 Q. Then he wallatyau to the stairs, you went
13 Q. He just said he had friends? 13 back down the staff rl= was still there?
14 A. Yes. 14 A. Yes.
15 Q. And you saw some pictures? 15 Q. And did you have anything to eat or drink
16 A. Yes. 16 before you left?
17 Q. And you dont know whether those people were 17 A. No.
18 his friends or not, you just know that you saw pictures 18 Q. Did you see again?
19 with those people? 19 A. Yeah, l saw w I was leaving.
20 A. I mean he had his arm around them and they 20 Q. Did she say anything to you?
21 looked like they were friends. 21 A. Just goodbye, I think. Something like that.
22 Q. So Mr. Epstein was in the picture, one picture 22 Q. And what did you say?
23 with Trump, another picture with Clinton? 23 A. Just said bye. Just wanted to get out of
24 A. Yes. 24 there.
25 Q. Yawn he gave you the $200, did he give you any 25 Q. You wanted to get out of there because you
21 (Pages 375 to 378)
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EFTA01107897
Page 379 Page 381
1 thought it was a really weird situation; fair statement? 1 A. Yeah.
2 A. Yes. 2 Q. All right. You just went to that beach,
3 Q. And you were very uncomfortable and scared and 3 parked at the meters, and just went down to the beach
4 nervous, true? 4 fee a while?
S MR. HOROWITZ: Form. 5 A. Yes.
6 THE WITNESS: I mean yeah, I was confused by 6 Q. And then to get home from there, what is it,
everything. I saw like a rich, powerful guy, and 7 about a 30-minute ride?
a then he was, you know, and very nice to me, but at 8 A. Yes.
9 the same time like I, you know, Mt uneasy and 9 Q. So you ancM. go to the beach fora period
10 just confused by everything that was going on. 10 of time and you ride home. Were you aware wheth.
11 BY MR. CRITTON: 11 had received any money at that point?
12 Q. Had you ever been with a guy before, a male 12 A. I don't remember.
13 before where he had masturbated, even if you didn't see 13 Q. Did you learn later that H.R. had received
14 it? 14 money?
15 A. No. 15 A. Yes.
16 Q. Had you ever been with one of your, a guy 16 Q. Did she tell you?
17 friend and the guy had masturbated? 17 A. I don't remember if she told me. I think she
18 A. No. 18 did.
19 Q. Or you thought he was masturbating? 19 Q. Did she tell you how much money she received?
20 A. No. 20 A. I think just 200, like he pays everybody.
21 Q. You both leave the kitchen, you leave the 21 Q. And were you offended that she had received
22 house, you get back in the truck. 22 S200 for bringing you?
23 A. (Witness nods head up and down.) 23 A. I don't remember what I thought back then.
24 Q. Do you start screaming a= going "What in 24 Q. Dld, when you were on the beach or on the way
25 God's name did you get me into here" 25 home, so there bad to have been at least 30 minutes plus
Page 380 Page 382
1 A. Actually, I was just like really embarrassed 1 the time you rode from Mr. Epstein's house to the beach,
2 about everything, and I forget my conversation with her 2 sat there a while nutes, an hour, maybe longer,
3 that day, though. 3 did you ever, di ever ask you what had happened or
4 Q. Well, did you say to her — did she say 4 if you were okay, what had happened?
5 anything to you like "Well, everything go okay?" 5 A. I don't remember. It was seven years ago. I
6 A. No. 6 don't remember what we talked about.
7 Q. So how far — did she take you home or did you 7 Q. Well, depending on the time period, maybe five
8 guys go to the beach? 8 years ago.
9 A. I believe we went to the beach after that. 9 A. Five,
10 Q. How long did you stay at the beach? 10 Q. Maybe six years ago, maybe seven years, fm
11 A. I don't remember. 11 not sure, based on your r testimony.
12 Q. An hour, ten minutes, five minutes? 12 So you woe wi Did you express any
13 A. I have no idea. 13 anger -
14 Q. Did you go in the ocean? 14 A. I'm mean I'm sure I was angry —
15 A. I don't remember. I just remember we went to 15 Q. Let me finish the question. Did you express
16 the beach after that. 16 any anger or anxiety to her with regard to what had
17 Q. And then you went home. Did she drive you 17 occurred between you and Mr. Epstein?
18 home? 18 A. I mean Fm sure she could tell I was
19 A. Yes. 19 uncomfortable and upset because of what happened, but I
20 Q. What's it from Palm Beach to the beach — did 20 don't rernanber what I said to her, what she said to me
21 you go to the beach offof Worth Avenue, that area? 21 exactly.
22 A. Just when you keep driving straight down 22 Q. Why would she notice that you were upset?
23 Okeechobee to -- yeah, the one straight, all the way 23 A. Because she didn't tell me everything that was
24 down. 24 going to go on, so of course I would have been upset.
25 Q. The end on Royal Palm Way? 25 Q. Why? How would she know that you were upset
"...4.6•1••••••••
22 (Pages 379 to 382)
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Electronically signed by Rachel Bridge (201-272417-4627) fo3b20 74.4 669-4a4d-ac93-e54696fd7921
EFTA01107898
Page 383 Page 385
3
1 if you didn't express it? 1 deceived you and misrepresented what was going to occur,
2 A. I don't remember if I said something about 2 why didn't you then at that point say no way under God's
3 her -- I mean I'm sure I did say something like why 3 green earth am I going back to Mr. Epstein's house again
4 didn't you tell me the whole story or something like 4 under any circumstances?
5 that, but I don't -- 5 A. Just because I was young and I wasn't thinking
6 Q. Did you feel that you had been misled? 6 and I was just confused, and I heard my friends started
A. Yes. 7 going there and then, you know, waited a little bit.
3 Q. Did you feel that. had deceived you? 8 And I mean, I don't know, I just wasn't in the right
9 A. Yes. 9 mindset. I was —
10 Q. Did you feel that she had misrepresented the 10 Q. Well, you knew that he couldn't force you to
11 circumstances of you giving the massage? 11 go back, right?
12 A. Yes. 12 A. Yes.
13 Q. Did you feel she had lied to you? 13 Q. And you knew he had no power over you? Once
14 A. I just felt like she didn't tell me everything 14 you left that house, from your perspective, you were no
15 that was going to go on. 15 longer committed to anything, you never had to go back.
16 Q. All right. So did you express something like 16 you never had to go back to Mr. Epstein's house for any
17 that to her? 17 reason under any circumstances, did you?
18 A. I'm sure I did. !just don't remember exactly 18 A. No.
19 what I said. 19 Q. Okay. And you could have said I found what I
20 Q. Okay. And did you tell her, do you remember 20 did inappropriate, Pm embarrassed, I'm humiliated about
21 telling her you felt the situation was awkward, you were 21 going, I'm not going back?
22 scared, you were nervous, you were confused, you were 22 MR. HOROWITZ: Form.
23 uneasy, you thought that his actions were inappropriate, 23 BY MR. CRITTON:
24 you felt uncomfortable? 24 Q. You could have marksaigt decision right then
25 Did you tell her all that? 25 and there on the beach with= that day, right?
Page 384 Page 386
1 MR. HOROWITZ: Form. 1 A. Yes.
2 BY MR. CRITTON: 2 Q. All right. And you felt embarrassed and
3 Q. Or something like that? 3 humiliated, didn't you?
4 A. I'm sure I did. I don't remember exactly what 4 MR. HOROWITZ.: Form.
5 I told her. 5 THE WITNESS: Yes.
6 Q. All right. So at that point, that is, after 6 BY MR. CRITTON:
7 that, describe that as a pretty miserable experience for 7 Q. All right. Did you think it was kind of
8 you yourself? 8 traumatic what he had done? You had never seen a guy or
9 A. Yes. 9 you had never been in the presence where another male
10 Q. So this miserable experience having occurred, 10 had masturbated. Even though you didn't see him, that's
11 I assume you made a decision right then and there that 11 what you thought he was doing, right?
12 you would never go back to Mr. Epstein's house, because 12 A. Yes.
13 why would you put yourself in such a situation which was 13 Q. All right. And that you found completely
14 awkward, where you would be weird, you would be scared, 14 inappropriate, right?
15 nervous, anxious, and what he did from your view was 15 A. I mean yes. I was just confused at the time.
16 inappropriate and uncomfortable for you? 16 Q. What's there to be confused about? You came
17 MR. HOROWITZ: Form. 17 away from that experience having been embarrassed and
18 THE WITNESS: Well, you know I went eight to 18 humiliated. You felt the situation was inappropriate.
19 ten times, so obviously you know l went back after 19 You were uncomfortable, scared and nervous.
20 that. 20 What would you ever be thinking why you would
21 BY MR. CRITTON: 21 have any interest in going back to Mr. Epstein's after
22 Q. That's my question to you, was if you found 22 that occasion?
23 the situation awkward, weird, you were scared, nervous, 23 A. Well, I wasn't planning on going back for a
24 you felt what he did was inappropriate and you were 24 Italia And then I just heard girls stared going
25 uncomfortable and confused and you felt Ilia ad 25 and alled me and asked me if I wanted to bring
23 (Pages 383 to 386)
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Electronically signed by Rachel Bridge (201.2724174627) fe3b2074-4669-4a4d-ac93-064696fd7921
EFTA01107899
Page 387 Page 389
1 anybody, and tibriLotber girls started going, and that's 1 Q. And did you say sit back and think — did you
2 when I believe= asked me about it (MI one of 2 say to yourselfI'm sorry I ever gave him my phone
3 them. And that's when I took one of those girls. 3 number?
4 Q. All right Soon the second occasion is when 4 A I just tried not like to think about it I
5 you took somebody else? 5 just, I don't remember.
6 A. Yes. 6 Q. Did you say geez, that was a traumatic
7 Q. All ri t. So on the second occasion you took 7 experience for me, l don't want to go back there or have
8 either , right? 8 anything to do with those people?
9 A. Yes. 9 MR. HOROWITZ: Form.
10 Q. Do you remember which one now, having thought 10 THE WITNESS: I don't remember exactly.
11 about it? 11 BY MR. CRITTON:
12 A. No. I mean I {mow now I'm pretty sure it 12 Q. Okay. But again, when you heard iron=
13 wa., but I can't remember which one I 13 did all those feelings of being uncomfortable and
14 took first. 14 anxious and scared, did all those feelings come back to
15 Q. All right. And, all right, on the second 15 you when she called you?
16 occasion you said= called you and asked you whether 16 A. Yeah, a little bit.
17 you wanted to come back or whether you had someone else 17 And did you say to yourself, you know, when
18
19
that would like to come?
A. Yeah, she said either.
18
19
.... strike that.
Wher=called you and asked you if you
20 Q. All right. And did she say to you when she 20 wanted to bring someone else, did you say no?
21 called you 'Do you have someone else that would like to 21 MR. HOROWITZ: Form.
22 give Mr. Epstein a massage?" 22 THE WITNESS: I believe I just said I didn't
23 A. Yes. 23 know and I'd call her back.
24 Q. Or did she say to come and work? What did she 24 BY MR. CRITTON:
25 say? 25 Q. Allright Did you then decide right, I'm not
Page 388 Page 390
1 A. She asked me both if I wanted to come work or 1 calling this lady back, I want nothing to do with them?
2 if1knew somebody what wanted to come work. 2 A. I don't know what I decided o than I 'Int
3 Q. Those were her exact words? 3 ranembe= found out about it
4 MR. HOROWITZ: Form. 4 asked me ifI went and ifI could bring her.
5 THE WITNESS: Pretty much. 5 Q. And did you say you had been there?
6 BY MR. CRTTTON: 6 A. Yes.
7 Q.Whssibitsaid that — again, you have never 7 Q. Okay. And why didn't you, when you said you
8 texted widt= have you? 8 had been there and she said "Could you take me," why
9 A. I don't remember. I don't think so. 9 didn't you just say "Go talk t' I have got no
10 g You never communicated by Facebook or social 10 interest in going back"?
11 networking "= 11 A. Because she asked me to take her and I 'mew I
12 A. No. 12 could make money. And I told her, you know, what
13 Q. Or Imam on behalf ofMr. Epstein? 13 happened. And she said that she wanted to make money or
14 MR. HOROWITZ: Fenn 14 needed money, so —
15 THE WITNESS: No. 15 Q. So you were going to make money of.
16 BY MR. CRITTON: 16 making money by taking her to Mr. Epstein's. Did you
17 Q. All right And when you talked witMand 17 consider yourself acting as a pimp?
18 she said would you like to come and work or do you have 18 MR. HOROWITZ: Form.
19 a friend that would like to come and work, you said 19 THE WITNESS: No.
20 what? 20 BY MR. CRITTON:
21 A. 'told her that I didn't know and that I would 21 Q. Pardon?
22 call her back. 22 A. No.
23 Q. And did you at that time — how much time had 23 Q. What did you consider yourself doing? What
24 passed since the time you were there the first time? 24 was your role?
25 A. I'm not sure. I think like two weeks or so. 25 A. If she, ifI brought her there and told her
24 (Pages 387 to 390)
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EFTA01107900
Page 391 Page 393
1 nothing lit, did mc, there is like a difference. 1 A. I don't remember.
2 Q. Okay. So did you to what had happened 2 Q. What was her reputation around school?
3 with you? 3 A. It was good.
4 A. Yes. 4 All right. So what did you do? Did you call
5
6
Q. Okay. a you told her exactly what you
just told us had happened?
5
6 Mill . ba
Nclair "Yep,iyrcal
m bonginga .friend"?then
7
8
MR. HOROWITZ: Fam.
THE WITNESS: Yes, at the time I told her what
happened.
7
9
conillir
I toll I, yes, I had a friend that wanted to
Q. And she said,Maid "Okay, just set up a
10 BY MR. CRITTON: 10 time"?
11 Q. And did you tell her that you had massaged 11 A. Yes.
12 him, including his chest, he had turned over and then he 12 And did you set up a time and did you take
13
14
15
had masturbated under a towel?
A. Yes.
Q. And she said what, no problem?
13
14
15
midQ.
ere?
•I'remember.
, was she driving at the time?
16 A. She said she still wanted to go. 16 A. Yes.
17 Q. All right. And did you tell her that you 17 Q. Did you say you were in the same class?
18 found the whole situation with Mr. Epstein weird and 18 A. Yes.
19 awkward? 19 Q. So one of the two of you drove, and I think
20 A. Yes, Fm sure I said that. 20 you told us earlier maybe M. went, you just don't
21 Q. And did you tell her you were scared and 21 remember, or you think just two of you went?
22 nervous when you were up there? 22 A. I don't remember.
23 A. I told her it was, you know, awkward. I felt 23 Q. So you drive over there. Din ask you any
24 weird and I told her what happened, but I don't remember 24 questions as you were going over there?
25 exactly what words I used. 25 A. I don't remember.
Page 392 Page 394
1 Q. Did you tell her the hadn't told you the 1 Q. Did you feel like you had give= full
2 truth, that she had deceived you and misrepresented what 2 disclosure as to at least what your experience was?
3 was going to happen? 3 MR. HOROWITZ: Form.
4 A. I don't remember if I told her that. 4 THE WITNESS: Yes.
5 Q. Okay. Did you tell her — did she say "Well, 5 BY MR. CRITTON:
6 would you go back up there with him?" 6 Q. So even though yours waslit ble
7 A. She never asked me that. 7 experience, you found it frame • 11 wanted to
8 Q. Okay. So you told her you were, it had been 8 go?
9 awkward and weird, that you were scared and nervous? 9 MR. HOROWITZ: Form.
10 Did you tell her that? 10 THE WITNESS: Yes.
11 A. I don't remember. 11 BY MR. CRMON:
12 Q. Did you tell her that he had grabbed your 12 Q. So you get over there. You go into the
13 butt? 13 kitcza was
do you
there
set
a: alit
14 A. Yes. 14
15 Q. Okay. And she gill said "I'll go"? 15 Q. Anyone else?
16 A. Yes, 16 A. And wn-haired girl. I forget her name.
17 Q. Okay. What was S.V.'s reputation at school? 17 I thinIcit's the 'rt.
18 Was she someone who dated a bunch of guys? 18 Q. Who is th girl?
19 MR. HOROWITZ: Form. 19 A. The brown-haired girl that was always over
20 BY MR. CRITTON: 20 there.
21 Q. I mean was she someone who had intimate 21 Q. Did you meet her at some point?
22 relationship with guys, from what you knew? 22 A. Yes.
23 A. I mean she had boyfriends. 23 Q. What did she look like?
24 Q. Do you know whether she was in a sexual 24 A. She's like really tall and skinny and brown
25 relationship with those boyfriends? 25 hair, pretty.
25 (Pages 391 to 394)
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EFTA01107901
Page 393 Pc..1
1 Q. S' have been there an 1 her like it had been to you?
2 A. Sarah was there. 2 MR. HOROWITZ: Form.
3 Q. And what happened? The two ofyou come in. 3 THE WITNESS: She didn't go into any detail.
4 everybody says hi, and what happens next? 4 I'm sure she was embarrassed.
5 A. I just introduce ., andMi 5 BY MR. CIUTTON:
6 talked t=. fora little bit, and they went upstairs 6 Q. As you had been, right?
7 and I waited in the kitchen. 7 A. Yes.
8 Q. Okay. And how long w- gone? 8 Q. Okay. And did she say anything else?
9 A. For about halfan hour. 9 A. Not that I can remem
10 Q. She comes back down the stairs? 1.0 Q. To your knowledge, :lie. ever go back to
11 A. Yes. 11 Mr. Epstein's?
12 Q. Okay. Did you ever see Jeffrey that day? 12 A. I don't know.
13 A. Yes. 13 Q. You never took her?
14 Q. Did he come down the stairs wit.? 14 A. No. I never took her again.
15 A. Yes. 15 Q. All right. On the third occasion that you
16 Q. What did he say to you? 16 went to Mr. Epstein's, is this when you would have taken
17 A. We went over in like his livingroom and then 17
18 he just gave meauzey. I forget what he said to me. 18 A. Yes, I believe so.
19 Q. And diet see you getting money for 19 Q. So the third time, how did that happen?
20 bringing her? 20 A. I don't remember exactly. 'just remember me
21 A. I don't remember. 21 taking her there. I think I mi t have drove, and
22 Q. Did she understand that you were going to get 22 basically the same wt
23 money for bringing ha? 23 Q. Did you tel what your experience had
24 MR. HOROWITZ: Form. 24 been?
25 THE WITNESS: I don't remember. 25 A. Yes, but she also heard about it from other
Page 396 Page 398
1 BY MR. CRITFON: 1 girls at school, so she also kind of knew what was going
2 Q. Did you ever tell her? 2 on.
3 A. I don't remember. 3 Q. Had she, did she say, after told her your
4 Q. When you got back in the car, did you go back 4 experience — I mean you told her again that he had
5 home, both of you? 5 grabbed your butt.
6 A. Yes. 6 A. (Witness nods head up and down.)
7 Q. Did you askencnv was it," or what was 7 Q. Yes?
8 your — you know, "Everything go okay?" 8 A. Yes.
9 A. I don't remember exactly what we talked about. 9 Q. Okay. You told her that you had massaged his
10 I just, I knew she said something about lute he was 10 legs, he had turned over and he had masturbated, at
11 weird and, you know, she was kind ofcreeped out. And 11 least from your perception, under the towel?
12 that's, she didn't really go into detail with me. 12 A. Yes.
13 Q. So she thought Mr. Epstein was weird and she 13 Q. Okay. And did she seem to be bothered by that
14 was creeped out by the whole experience. 14 stall?
15 MR. HOROWITZ: Form. 15 MR. HOROWITZ: Form.
16 TIM WITNESS: Yes. 16 THE WITNESS: I don't remember.
17 BY MR. ORITION: 17 BY MR. CRITTON:
18 Q. Okay. And she told you that? 18 Q. Had she heard that, though, from other girls?
19 A. Yes. That's what I, the summary of what I 19 A. I think so, yes.
20 remember. 20 Q. And she left you with that impression, "Yeah,
21 Q. Okay. And that was consistent with how you 21 I've heard he does that"?
22 felt after the fast time, because you thought it was 22 A. Yes.
23 weird and you were creeped out too, weren't you? 23 Q. Did you tell her that you had taken
24 A. Yes. 24 A. I don't remember.
25 Q. Did she seem to be a traumatic experience to 25 Q. Okay. Well, did you tell her as you ton
26 (Pages 395 to 398)
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EFTA01107902
Page 399 Page 401
1 that you found the situation weird and awkward and you 1 this occasion?
2 were uncomfortable, confused, and nervous and scared? 2 A. I believeMand maybe, the girl,
3 MR. HOROWITZ: Form. 3 brown-haired girl.
4 THE WITNESS: I don't remember, because she 4 Q. I'm sort and, an
5 already kind of knew about it, so I don't remember 5 A. Yeah,
6 what I said to her. 6 Q. You pull into the kitchen. Was the cook
7 BY MR. CRITTON: 7 there?
8 Q. But you told her that you didn't feel 8 A. I think so, yeah. There was usually a cook
9 comfortable being there, didn't you? 9 there.
10 MR. HOROWITZ: Fr. 10 Q. Did you have anything to eat?
11 THE WITNESS: I don't remember. 11 A. I don't remember.
12 BY MR. CRITTON: 12 . So you sat in the kitchen and did. take
13 Q. Well, did you mislead her and misrepresent 13 oPstaks?
14 what was going to happen, or did you tell her that it 14 A. Yes.
15 was a very uncomfortable experience for you? 15 Q. How long was she up there, about 30 minutes?
16 MR.. HOROWITZ: Form. 16 A. Yes-
17 THE WITNESS: I don't know if she asked me 17 Q. She comes back down. Did Mr. Epstein come
18 about it, but she already knew what was going on. 18 back down again?
19 BY MR. CRITTON: 19 A. Umm, umm, actually I think that was the time
20 Q. Well, do you remember telling her your 20 that Sarah brought me up there and Jeffrey was, was in
21 experience? That's what Pm interested in. I mean 21 Ike a smaller room kind of by the bathroom.
22 whether she knew it from somebody else, did you tell her 22 And he gave me the money and he said something
23 your experience? 23 Ike "good job," and then just tried to grab my butt
24 MR HOROWITZ.: Forth. 24 again. And then I was kind e pulled away, and he
25 THE WITNESS: I don't remember. 25 gave me the money and came out and then we
Page 400 Page 402
1 BY MR. CRITTON: 1 left
2 Q. Okay. Well, whether she asked you whether she 2 Q. So when he reached out for your butt, you
3 could go a not, you were in a situation that you found 3 moved away?
4 traumatic, you thought he acted inappropriately, you 4 A. Yes.
5 felt uncomfortable, nervous, scared, and confused. 5 Q. So the third occasion, so you an. then
6 Did you disclose — didn't you feel you had an 6 walked downstairs?
7 obligation to disclose that to her before you allowed 7 A. Yes.
8 her or took her to the house? 8 Q. Did you go to the beach? Did you go shopping,
9 MR. HOROWITZ: Form. 9 or did you take her home?
10 THE WITNESS: She already knew like what was 10 A. I don't rer»ember what we did. A lot of times
11 the deal, like what was going on. So ifs not like 11 I would go to the beach after, but I don't remember
12 I hid anything from her. And any time they would 12 specifically. an.
13 ask me, I would tell them straight up, you know. 13 Q. Were you friends?
14 BY MR. CRITTU 14 A. Yes.
15 Q. So you an o. You think she !mew 15 Q. Did anything about the episode? Did
16 everything at least that you knew, plus she had heard 16 she say said, like "This is really weird,
17 stuff from other girls? 17 this really creeped me out"?
18 A. Yes. 18 A. Yeah, I think she was kind of — I think ever)
19 Q. So you felt that she had full knowledge, full 19 girl that watt kind of had that feeling — like not
20 disclosure, so to speak? 20 every girl, but I mean a lot of the girls, the first
21 MR HOROWITZ: Form. 21 time theysvere kind of confused by everything.
22 BY MR. CRITTON: 22 Q. S ave you at least the impression she
23 Q. Is that fair? 23 thought it was weird and she was kind of creeped out
24 A. Yes. 24 too?
25 Q. You go in the house. Who was in the house on 25 A. I mean she didn't tell me, but I would assume.
27 (Pages 399 to 402)
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1 Q. You don't have to assume. I want to know what 1 money. You had a job at the time or you didn't have a
2 she said. Did she say anything to you? 2 job?
3 MR. HOROWITZ: Form. 3 A. I don't think I had a job, no.
4 THE WITNESS: I don't remember what she said 4 Q. So did you ask your parents for money?
5 to me. 5 A. My parents like rarely gave me money. Like
6 BY MR. CRITTON: 6 just when I needed things like bad, like for school.
7 Q. Well, did she say anything or did she suggest 7 Q. Who paid for your gas?
8 to you — strike that 8 A. I would have to like wash my dad's car or
9 Did she tell you that anything inappropriate 9 clean the yard. I would have to do chores to get —
10 had happened? 10 Q. Soto speak, an honest days work for an
1/. MR. HOROWITZ: Form. 11 honest days pay?
12 THE WITNESS: I don't remember. 12 A. Pretty much.
13 BY MR. CRUTON: 13 Q. All right. So and how about for insurance,
14 Q. Okay. Did she say he had touched her in any 14 who paid the car payment and the insurance payment for
15 way or assaulted her? 15 the car, your parents?
16 A. No. She didn't say assaulted. 16 A. My dad.
17 Q. Well, did she say that anything had happened 17 Q. All right. Did your parents ever ask you
18 that was in any way inappropriate? 18 where you went when you were going over to Palm Beach,
19 MR. HOROWITZ: Form. 19 or did they not know you were going to Palm Beach?
20 THE WITNESS: I don't remember. 20 A. They didn't Icnigr agoing.
21 BY MR. CRITTON: 21 Q. All right So i Iled, you said you
22 Q. Again, neither ever came down 22 needed some money, so you said you'd go again?
23 looking distraught or crying or upset, did they? 23 A. Yes.
24 A. I mean yeah, they kind of looked like upset 24 Q. Now the fourth time, this is the fourth of the
25 and weirded out. None of them ever cried, but — 25 eight to ten times you went?
Page 404 Page 406
1 Q. Did they ever call for help when they were 1 A. Yes.
2 there? 2 Q. So you go on the fourth time, you go. Who was
3 A. No. 3 in the kitchen at the time?
4 Q. Did you after the first visit ever call the 4 MR. HOROWITZ: Form.
5 Palm Beach Police Department? 5 BY MR. CRITTON:
6 A. No. 6 Q. Let me strike that.
7 Q. Okay. Diver say, "You know what? 7 Was there anyone in the kitchen at the time?
8 This guy did something unappropriate, we should call the 8 MR. HOROWITZ: No, that's not my objection.
9 pollee? 9 BY MR. CRITTON:
10 A. No. 10 Q. Fourth visit
11 Q. How about and you? DiMisay anything 11 MR. HOROWITZ: That is a better question.
12 to you about calling the police that maybe what was 12 BY MR. CRITTON:
13 going on was inappropriate? 13 Q. You went to his house the fourth time.
14 A. No. 14 correct?
15 Q. All right. So you made another 200 bucks for 15 A. Yes.
16 taking somebody else, right? 16 Q. You went to the did you always go to the
17 A. Yes. 17 kitchen entrance?
18 Q. Okay. The fourth time now you went, how did 18 A. Yes.
19 it happen that you went a fourth time? 19 Q. Did you ring the bell?
20 A. I just heard about, you know girls going, and 20 A. No.
21 then I just needed money and like kept calling me, 21 Q. You just walked in?
22 so then I just decided to go back, but it's hard to 22 A. I think so, yeah.
23 distinct from time to time. !just remember like major 23 Q. Was anyone in the kitchen?
24 things that happened when I was there. 24 A. I don't remember exact like lime to time. I
25 Q. Okay. The fourth time, you say you needed 25 just, I remember usually there was a cook in the
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1 kitchenaape I saw Shairl there. One time 1 right?
2 1saw dein there was usually always 2 MR. HOROWITZ: Form.
3 there. 3 THE WITNESS: Like I said earlier, I just, I
4 Q. Can you tell me, can you identify the fourth 4 was confused. I wasn't thinking. I was young.
5 time and what happened at the fourth time? And a lot ofmy friends were going and I just
6 A. I think the fourth time was when he was in the 6 started getting more comfortable because my friends
7 shower and I went up there. 7 were going. It wasn't like he was a mean man. He
8 Q. So you went up. Dialtake you up or you was like really nice to me, and I mean other than
9 just !mew how to get up there? 9 what he did. But I mean I don't know why.
10 A. I think she took me up. 10 BY MR. CRITTON:
11 Q. Okay. Now this is the fourth time you went. 11 Q. Okay. Each of the subsequent times, each of
12 You went one time, you were, you felt the situation 12 the times from the fourth time through the eighth or the
13 completely inappropriate, you were traumatized, you were 13 tenth time, whatever it was, with the second and third
14 scared and confused. 14 time taking someone else and not you participating, you
15 The next two times you take friends. You 15 voluntarily consented to go to Mr. Epstein's home, true?
16 explain to them what was going to go on, and they knew, 16 A. Yes.
17 they heard it from other people. 17 Q. And in each instance, when you were asked
18 Why did you put yourself in a position to go 18 whether you wanted to come and work, you had to make a
19 back now a second time yourself after the first 19 decision to say, number one, yes; and then number two,
20 experience was traumatic and awful for you? 20 to get in the car and to transport yourself over there?
21 MR. HOROATfZ: Form. 21 A. lb huh.
22 THE WITNESS: I don't know, I just, I wanted 22 Q. Yes?
23 money. And I mean a lot ofmy high school 23 A. Yes.
24 girlfriends were going and I thought it was kind of 24 toldOX AN right. And in any instance you could have
25 like, you know, getting to be normal almost. And 25 that you had no interest incoming
Page 408 Page 410
1 don't know, I was just young and confused, and so I 1 back to Mr. Epstein's house, correct?
2 went there again. 2 A. Yes. She would call me a lot, though.
3 BY MR. CRITTON: 3 Q. I'm sorry?
4 Q. But had you ever had had you ever put your 4 A. She called me a lot.
5 hand on or near a kitchen — do you have a gas or an 5 Q. All you had to do was say don't, do not call
6 electric range? 6 me again, correct?
7 A. Gas. 7 A. Yes.
a Q. Okay. Did you ever put your hand too close to 8 Q. That's all you had to say?
9 the flame and it bums? 9 MR. HOROWITZ: Form.
10 A. Yes. 10 BY MR. CRITTON:
11 Q. Not a pleasant experience, right? 11 Q. Did you ever al= "Don't call me
12 A. Yes. 12 anymore, I have no interest in coining to your house"?
13 Q. What's it teach you? Even as a small child, 13 A. No.
14 you learn you don't do that again, right? 14 Q. Okay. Have you ever told someone — my guess
15 MR. HOROWITZ: Form. 15 is you've told males before who wanted to date you, you
16 THE WITNESS: Yes. 16 have said "Look, I have no interest in dating you, don't
17 BY MR. CRITTON: 17 call me anymore."
18 Q. All right. So in this instance you had a very You have said that to men, haven't you?
19 unpleasant experience with Mr. Epstein — 19 A. Yes.
20 A. Yes. 20 Q. And my guess is you probably said that to some
21 Q. — from the first occasion. Traumatic, as 21 females over the years, some people that you don't want
22 you've described it. 22 to associate with if they call you and say "Look, I'm
23 So why would you put yourselfback in that 23 sorry I did this to you. Look, don't call me"
24 position again? I mean you had a lot of time to think 24 You have said that to people, haven't you?
25 it before you ever went back a second time for yourself. 25 A. Yes.
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1 Q. And you could have said that t•MI could 1 Q. Again, you are there. Were all these sessions
2 you not? 2 about a half hour?
3 A. Yes. 3 A. Yes.
4 Q. All right. But you chose not to for whatever 4 Q. So you massage his feet and his legs again.
5 reason, true? 5 Is he talking to you?
6 A. Uh huh. 6 A. Yes.
7 Q. Yes? 7 Q. Does he ever ask you your age?
8 A. Yes. 8 A. No.
9 Q. All right. So the fourth time you go over, 9 Q. Do you ever tell him your age?
10 you say you saw him, he was in the shower. 10 A. I don't think so. I remember telling him I
11 A. Yes. 11 was in high school.
12 Q. All right. So what did you do? 12 Q. You did ever show him your fake IDs?
13 A. He was just talking to me while he was in the 13 A. No.
14 shower. And I think he asked me how school was or 14 Q. Did you tell him you had a fake ID?
15 something. 15 A. No.
16 And he said he needed to take a shower because 16 Q. If he had asked for the ID, you would have
17 he just went for a jog, and we were just briefly 17 given him the fake ID?
18 talking. Then he got out and he grabbed a towel. He 18 MR. HOROWITZ: Form.
19 was like all naked and just kind of dried off and then 19 THE WITNESS: NO.
20 asked me if I was ready to do the massage. 20 BY MR. CRITTON:
21 Q. Were you looking at him when he got out of the 21 Q. Why not?
22 shower or did you turn away? 22 A. I mean why would I have?
23 A. !saw him naked and then I tamed away. 23 Q. Were you concerned at all about your age?
24 Q. Okay. Did you say anything to him when you 24 MR. HOROWITZ: Form.
25 say him naked, say "Look, you know, I don't need that"? 25 T E WTTNESS: No.
Page 412 Page 414
1 A. I mean no, I was kind of nervous. I was just 1 BY MR. CRITTON:
2 put in an awkward situation, pretty much. 2 Q. So again the fourth time, but the second time
3 Q. So again, you felt in a very awkward and 3 you alone, you massage his feet and his legs.
4 unoomfortable position? 4 What happens? Is it the exact same as the
5 A. Uh huh. 5 fast occasion?
6 Q. Yes? 6 A. No.
7 A. Yes. 7 Q. How is it different?
8 Q. All right. Did you say, you know, "I really 8 A. It was worse. Like every time it gradually
9 don't feel like doing this, I don't feel well, I think 9 got worse. That was the time when he like grabbed my
10 III go downstairs"? 10 buttocks and pulled me closer and after the massage, and
11 A. No. 11 then he tried grabbing my breasts and asked me to take
12 Q. Okay. I mean you've gotten out of other 12 my shirt off.
13 events in your life, whether it's a party or going out 13 And I think I always wore like a bathing suit
14 with someone by saying "Look, I don't feel well, I have 14 there, and he told me that I had like a nice body and I
15 got a headache, l feel sick," and then you didn't have 15 was pretty. And then he would ask me things, like if l
16 to go to dinner with the person or didn't have to go 16 was still a virgin.
17 out? 17 Q. I'm just talking about the fourth visit now.
18 You have done that before? 18 A. Okay.
19 A. Yes. 19 Q. This all happened on the fourth visit, the
20 Q. All right. So he puts a towel around himself 20 second time you were there alone?
21 Does he come over and get on the table then? 21 A. I can't distinct visit to visit. I just
22 A. Yes. 22 remember the fourth until certain big events that
23 Q. Did you start massaging his feet and his legs 23 happened.
24 again? 24 Q. You say they got worse and worse. So as of
25 A. Yes. 25 the second time, you say he grabbed your butt again.
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1 A. Yes. 1 Q. And you had your swimsuit on underneath?
2 Q. And then you said he tried grabbing your or 2 A. Yes.
3 touching your breasts? 3 Q. Which would have been the top and the bottom?
4 A. Yes. 4 At IA huh, yeah.
5 Q. Did he? 5 Q. Your swimsuit, was it a thong or full
6 A. I don't lmow if he did it on the tomtit or the 6 swimsuit?
7 fifth time, but eventually, yes, he did. 7 A. It was like a full swimsuit.
8 Q. Okay. But on the fourth at least he tried is 8 Q. Um a two-piece?
9 what you are saying? 9 A. Yes.
10 A. Yes. 10 Q. But not like a thong bikini?
11 Q. And you described, you felt that this was a 11. A. No.
12 worse situation than the first time that you had been 12 Q. So on the fourth time did he masturbate again,
13 there alone? 13 or what you perceived to be masturbating?
14 A. Yes. 14 A. Yes.
15 Q. All right. Did you feel more scared? 15 Q. And again, under the towel?
16 A. Yes. 16 A. Yes.
17 Q. More anxious? 17 Q. And at the end of the session, at the end of
18 A. Yes. 18 the massage session, were you again anxious, scared,
19 Q. And did you feel that his conduct was more 19 very uncomfortable?
20 inappropriate? 20 A. Yes.
21 A. Yes, 21 Q. All right. Felt again traumatized by the
22 Q. And vane you more traumatized because he was 22 events?
23 more what you perceived to be a little more aggressive? 23 A. Yes, I felt upset about everything and
24 MR. HOROWITZ: Form. 24 embarrassed, yeah.
25 THE WITNESS: Yes. 25 Q. And he again paid you 200 bucks?
Page 916 Page 418
1 BY MR. CRITTON: 1 A. Yes.
2 Q. Okay. Did he ask you — did you remove any of 2 Q. And when you left that time, you had come
3 your clothing on that visit? This is the second — the 3 alone, so you went home alone, right?
4 fourth time recognizing — I don't want to keep 4 A. Yes.
5 repeating this, but the same you brought and 5 Q. And did you make a vow to yourself, I'm not
6 the third time you brou 6 going back there again, this was worse than the last
7 So the fourth time, did you remove any of your 7 time, than the first time when I was there alone, I have
8 clothing? 8 no interest in ever going back to this place?
9 A. 1 remember, I just remember him grabbing my 9 A. No. I would wait a little bit again and then
butt and trying to grab my boobs and just like being 10 just kind of, you know, just wait. And ther would
10
11 more rough with me than the first time I went there. 11 keep calling me again, and then I finally gave in again
12 I don't know if It was the fourth or the fifth 12 and went. And I mean yeah.
13 time when I took off my shirt. 13 Q. The fifth time, so between the fourth time and
14 Q. All right. So whether it was the fourth or 14 the fifth time, how much time transpired? How much time
15 the fifth, we'll kind of combine those two, but between 15 usually transpired between visits?
16 the fourth and the fifth, did it get worse from your 16 MR. HOROWITZ: Form.
17 perspective than two? 17 THE WITNESS: I don't remember, sometimes a
18 A. Yes. 18 week, sometimes a month.
19 Q. Did he ask you to take off your shirt on 19 BY MR. CRITFON:
20 either let's say on the fifth time? 20 Q. Were you telling other people, were your
21 A. Yes. 21 Mends aware that you had gone back?
22 Q. And did you have a tank top cm? 22 A. Just Jane Doe 4, and I dont know if I told
23 A. I don't remember exactly what I was wearing. 23 Jane Doe 3.
24 I usually just wear like a skirt and cute shirt, tank 24 Q. Okay. Did you tell them what was going on?
25 top. 25 A. I don't remember what I told them.
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1 Q. Well, did the three ofyou talk about what 1 Q. And he said something to the effect of well.
2 went on when you were there? 2 you've been here before.
3 A. I mean I don't remember generally. I'm sure 3 A. (Witness nods head up and down.)
4 we talked about it, but I don't remember what was said. 4 Q. And you still moved away from him?
5 Q. Okay. Did you know or did Jane Doe 4, did she 5 A. Yes.
6 ever mention that he masturbated? 6 Q. Is that correct?
7 A. I don't remember. 7 A. Yes.
8 Q. Did Jane Doe 3 ever tell you that Mr. Epstein 8 Q. All right. So as of the sixth visit, you had
9 masturbated when she was there? 9 tatter' your top off, he had put his hand on your butt and
10 A. I don't remember. 10 pulled you closer each time; is that true?
11 Q. The fifth time you say you removed your shirt, 11 A. Yes.
12 but you still had your top on. 12 Q. All right. And he tried to touch your breast,
13 A. Yes. • 13 but was not successful, correct? That is, under your
14 Q. Did he touch you in any way? 14 swimsuit?
15 A. Yes. He touched my breast. 15 A. Yes.
16 Q. Over your swimsuit? 16 Q. And on each of the visits did he masturbate,
17 A. Yeah, and tried to reach under it 17 at least from your perception, under the towel?
18 Q. He tried, but he didn't? 18 A. Yes.
19 A. The fifth time he didn't. He just kept trying 19 Q. All right. What happened on the — what event
20 to grab my breast. 20 occurred next, whether it was the seventh or the last
21 Q. Did you tell him not to? 21 visit, if the last visit was the eighth, what happened
22 A. Youth, I kind ofliked pulled away and I was 22 next?
23 like 1 don't feel comfortable." 23 A. Well, I remember being just like, I took off
24 And he's like "Well, you know, yottve been 24 my bottoms and I was just in a bathing suit.
25 here before, you should know." He said something like 25 Q. Is this now the last time you went?
Page 420 Page 422
1 that. 1 A. No, this is around the sixth or the seventh
2 Q. Did he ever pay you more than S200? 2 time probably, and I was just in my bathing suit And
3 A. No. 3 then he pretty much did the same thing.
4 Q. So he ahvays paid you $200? 4 And then he just kept asking me more like
5 A. Yes. 5 vulgar questions every time and —
6 Q. Okay. Now on that occasion, on the sixth now, 6 Q. Vulgar questions?
7 you say again — well, were you on the fifth or the 7 A. Yes.
8 sixth? 8 Q. Me what?
9 A. They kind of blend together forme, so — 9 A. Like asked me what I have done with guys and
10 Q. On the fifth or the sixth, what happened 10 why I was still a virgin.
11 again — now let's go to the sixth. What happened 11 Q. Because you told him that you had done nothing
12 differently on the sixth than the fifth? 12 with guys?
13 MR. HOROWITZ: Form 13 A. Yes.
14 THE WITNESS: I honestly can't remember every 14 Q. Other than kissing, making out?
15 visit. I just remember like really the things that 15 A. Yes.
16 stood out. Like it's so painful for me to 16 Q. I think you testified earlier that you had not
17 remember, like I don't know, ifs hard to bring 17 had sexual intercourse with a man by then?
18 backup, and I just remember the main things that 18 A. No.
19 happened. 19 Q. And you had not engaged in oral sex, either
20 BY MR. CRITTON: 20 giving or receiving; is that correct?
21 Q. Well, at some visit, whether it was the fifth 21 A- Yes.
22 or the sixth, you say he tried to touch your breasts. 22 Q. So you said, whatever question he asked, you
23 You moved away from him and said you didn't feel 23 said, "I haven't engaged in sex, it was my own choice,"
24 comfortable with that. 24 right?
25 A. Yes. 25 MR. HOROWITZ: Form.
cab
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1 BY MR. CRITTON: 1 BY MR. CRITION:
2 Q. Strike that. Did you tell him when he said 2 Q. Go ahead.
3 "Why arc you still a virgin," what did you say? 3 A. I don't remember. Maybe like I, I don't — it
4 A. I said I hadn't fallen in love yet and 1was 4 was so long ago, I don't remember exactly what happened
5 waiting until I found somebody I fell in love with. 5 in high school and what guys, you )(now, tried to touch
6 Q. So you certainly had the presence ofmind with 6 me or if a guy tried to touch me. Irernernber, of
7 other males, males your age or a few years older or 7 course, I made out with people and, you know.
8 younger, my guess is guys had encouraged you to by to 8 Q. Had you ever tried to touch a guy?
9 have sex with them? 9 A. No.
10 MR.11OROWITZ: Form. 10 Q. All right. So you are at Mr. Epstein's house.
11 THE WITNESS: I mean not really. I just, I 11 It's now the sixth or the seventh time. You are in a
12 just, I mean I'm sure guys like hit on tne and this 12 bathing suit.
13 and that, but I've never really been in that 13 On each occasion you felt that he acted
14 position where 1was with Jeffrey wherel felt so 14 inappropriately, both from a physical standpoint and
15 obligated to do things and just like in that 15 from a verbal standpoint at this point, right? The
16 situation. 16 questions he was asking you?
17 BY MR. CRITTON: 17 A. Yes.
18 Q. Ur me ask you this. Before you ever went to 18 Q. All right. You felt that the questions were
19 Mr. Epstein's house, had you ever been in a position 19 becoming more inappropriate?
20 with a boy who tried to get more aggressive than just 20 A. Yes.
21 kissing you, with a male? 21 Q. And making you more uncomfortable.
22 A. I mean I don't think so. I don't remember. 22 A. Yes.
23 Q. So you're either 15, 16 or 17 when you are 23 Q. And you were uncomfortable not only with the
24 going to Mr. Epstein's house, depending on what your 24 questions that he was asking you, but with his actions,
25 interrogatories and what you have told us today and what 25 that is, in pulling you close to him by putting his hand
Page 424 Page 426
1 you told the Palm Beach police, whatever that date or 1 on your buttocks, right?
2 whatever that time period was, is it your testimony that 2 A. Yes.
3 no male had, or that you had done nothing with a male 3 Q. And trying to reach and touch your breast over
4 other than kissing them? 4 your swimsuit?
5 MR. HOROWITZ: Form. 5 A. ' Yes.
6 THE WITNESS: While I was going to Jeffrey's? 6 Q. And again, you felt awkward, scared, nervous,
7 BY MR. CRITTON: 7 and you felt the situation was weird?
8 Q. Yes, during the torte that you were going to 8 A. Yes, but at the same time he was also like
9 Jeffrey's. 9 very nice to me and would ask me questions and say that
10 MR. HOROWITZ: Fenn. 10 he would like get me jobs and he was a good person to
11 THE WITNESS: Yeah, I was a virgin. I didn't 11 know, so I was confused by the whole situation. It was
12 do anything. 12 kind of conflicting in my head.
13 BY MR. CRITTON: 13 Q. You may have had some conflict, but on each
14 Q. And no guy, no male had ever put his hand on 14 occasion when you came away from Mr. Epstein's,
15 your breast, either on the exterior of your clothes, 15 certainly as of the sixth or seventh time, you felt that
16 under your bra; is that what you arc testifying to? 16 the situation from your perspective was escalating, was
17 MR. HOROWITZ: Form. 17 getting worse, right?
18 THE WITNESS: I don't really remember. It was 18 A. Yes.
19 high school. Fm sure some guy tried to touch me 19 Q. And you felt more uncomfortable than you had
20 or — 20 the first time and with each time thereafter felt
21 BY MR. CRITTON: 21 equally -- in fact, more uncomfortable?
22 Q. Had a guy touched you? 22 A. Yes.
23 MR HOROWITZ: Hold on. You are cutting her 23 Q. And you felt his behavior was more
24 off. Go ahead. 24 uncomfortable each time?
25 25 A. Uh huh.
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1 Q. Yes? 1 MR. HOROWITZ: Form
2 A. Yes. 2 BY MR. CRITTON:
3 Q. And so on any of those occasions, whether 3 Q. On the eighth time, the next time, what event
4 before you went back on the fifth, the sixth, the 4 happened? Is the next time the last tint you were
5 seventh or the eighth, all you had to do was tell 5 there?
I a I'm not coming, I don't feel comfottable," 6
7
MR. HOROWITZ: Form.
THE WITNESS: Yeah, the last time was the
net
8 A. Yes. 8 worst.
9 MR. HOROWITZ: Form. 9 BY MR. CRITTON:
10 BY MR. CRITTON: 10 Q. Okay. So on the eighth time when you were
11 Q. You didn't even have to give a reason, all you 11 there, what happened?
12 had to do was say Tm not coming"? 12 MR. HOROWITZ: Form.
13 MR. HOROWITZ: Form. 13 THE WITNESS: The last time he I had my
14 THE WITNESS: Yes. 14 shkt off. I had a bra and underwear on, and I
15 BY MR. CRITION: 15 gave him a massage. And then that time he was just
16 Q. "Ifs over, I have no interest in corning 16 the most aggressive with me. And that's when be
17 anymore," true? 17 like pulled me close to him and he asked me to take
18 A. Yes. 18 my underwear off, and I said no.
19 Q. And you could have told Mr. Epstein when you 19 And then he tried to grab it and pull it down,
20 were there and he is asking you these questions that you 20 and I was like "No, I just don't feel comfortable."
21 felt were inappropriate, WI you had to do was say 21 And he was Illce "You've been here plenty of
22 "Jeffrey, I'm never coming back here if you keep asking 22 times before." And then he — I took my shirt off.
23 me questions like that." 23 And then he was grabbing my breast, and I kept
24 Did you ever say that? 24 pulling away and he kept grabbing it.
25 A. I remember telling him something like "I don't 25 And then he just like pulled me closer to him.
Page 428 Page 430
1 feel comfortable telling you about, you know, guys and 1 And that's when he like tried to like reach under
2 talking about this," and then he just kept pressuring me 2 my — well, he did reach under my underwear and
3 and asking me why not. 3 touch my vagina and he was, like tried fingering
4 Ink just he's good at talking and he's good 4 me.
5 at making you feel like you could tell him stuff; and 5 BY MR. CRITTON:
b he's good at like making you feel like it's okay to do 6 Q. This last time, were you still giving him a
7 stuff. 7 massage?
3 Q. But you knew, you felt it was inappropriate, 8 A. Well, I was like massaging his chest while he
9 right? 9 was like doing this.
10 So whether he is trying to make you feel 10 Q. But you were doing the same kind ofmassage
11 comfortable or not, you in your own mind knew that the 11 you had done before, you were doing his feet, his legs
12 questions were very uncomfortable and inappropriate, 12 and then he would turn over?
13 true? 13 A. Uh huh
14 A. Yes, and I told him about it. 14 Q. Ms. jane Doe 7, you say he got a little more
15 Q. All right. So seventh time, now you are in 15 aggressive. So did you take off your bra?
16 your swimsuit, he's asking you more direct questions. 16 A. I don't remember. I think he tried to unhook
17 You felt even more uncomfortable. 17 it and pull it down —
18 Again, be masturbated under the towel? 18 Q. But you didn't let him do that?
19 MR. HOROWITZ: Form. 19 A. — and grab my breast. I think he pulled it
20 THE WITNESS: Yes. 20 down. I didn't take it all the way off, but he pulled
21 BY MR. CRITTON: 21 it down.
22 Q. All right. And then you would, he would get 22 Q. Did he touch your breast?
23 up and go take a shower or he would leave the room and 23 A. Yes.
24 you would take your 200 bucks and leave the house? 24 Q. Both or just one?
25 A. Yes. 25 A. I know he touched one. I think he touched
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1 both. 1 want to tell anybody.
2 Q. If he was lying on the table, how is he able 2 Q. That's the last time you went Mr. Epstein's?
3 to do that? 3 A. Yes.
4 A. Touching, Ince going from — this is so 4 Q. And on that last occasion that you went to his
5 embarrassing. 5 house, when you left, where did you go?
6 Q. With his left hand or with his right hand? 6 A. I don't remember. I think I went home.
MR. HOROWITZ: Take your time. Just try to 7 Q. All right. Did you ever tell anyone about it?
answer the question as best you can. 8 A. No.
9 THE WITNESS: It was with his left hand. 9 Q. Did you ever tell Jane Doe 47
10 BY MR. CRITfON: 10 A. I mean Jane Doe 4 is maybe the only person ]
11 Q. Okay. So you are saying he pulled down your 11 ever told.
12 In and then was able to touch your breast with the same 12 Q. Did you tell her at the time?
13 hand that he was pulling your bra down? 13 A. I don't remember.
14 A. Well, he pulled it down and then grabbed it. 14 Q. At some point did you tell her?
15 Q. When he pulled it down, did you move away from 15 A. I don't remember.
16 him? 16 Q. So you don't even lmow what you told Jane
17 A. Yeah, and then he pulled it down again and he 17 Doe 4?
18 was being very aggressive. 18 MR. HOROWITZ: Form.
19 Q. When he gabbed your bra and pulled it down, 19 THE WITNESS: I don't exactly icn nber what I
20 why didn't you just move away from him? 20 told Jane Doe 4 why I stopped going, like if I told
21 A. I did move away. 21 her everything. I mean I was embarrassed. I
22 Q. Well, why did you ever move back near him 22 didn't want to like share all my details.
23 then? 23 BY MR. CRITP0N:
24 A. Because he pulled me back near him with his 24 Q. Did anyone, did Sarah ever call you again to
25 arm. 25 work?
Page 432 Page 434
1 Q. Did you say something to him like "Let me go"? 1 A. Yes.
2 A. Yeah. I said, I just told him, I was like "I 2 Q. What did you tell her?
3 just can't do this," like no. I don't remember the 3 A. !just like ignored her phone calls.
4 exact words I used. 4 Q. And you could have done that after the very
5 And he just made me feel like really stupid 5 first time you had been at Mr. Epstein's home, true?
6 and belittled. He was like "You have been here so many 6 A. Yes.
7 times and, you know, you should know like what goes on 7 Q. So at least after the eighth visit, you were
8 by now." 8 . able 03 ignore phone calls without a problem at
9 And then I just felt like in that position 9 all?
10 where like I just felt like obligated or just like I was 10 MR. HOROWITZ: Form.
11 just put in that weird position. And then that's when 11 THE WITNESS: Yeah, l was just in shock and
12 he pulled me closer to him again, and that's when he 12 over it. And I just felt so embarrassed and like
13 pulled down my underwear, and then that's when he 13 ashamed ofmyself. And then so that was the last
14 touched my vagina and tried to finger me. 14 time.
15 And then after that, I was just, I was like 15 MR. HOROWITZ: Critton, it's now 6:30.
16 no, Fin done after that. And I was just so, I was fed 16 How far in this tape are we, sir?
17 up with everything. I was like this has gone way too 17 THE VIDEOGRAPHER: Fifty-seven minutes into
18 far. 18 this tape, sir.
19 Q. Did you tell him that? 19 MR. HOROWITZ: Tick, tick, tick.
20 A. Yeah, I was like fm done. He knew I felt 20 ' MR. CRITTON: Let's go off the record for just
21 really in shock And then he was like okay, okay. And 21 a minute.
22 then he was just mad at me and just like gave me dirty 22 711E VIDEOGRAPHER: Going off the record at
23 looks and just made me feel stupid. 23 6:29 p.m.
24 Q. Did you ever call for help? 24 (A recess was taken.)
25 A. No. I mean I was so embarrassed. I didn't 25 THE VIDEOGRAPHER: We are back on the record
35 (Pages 431 to 434)
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1 at 6:36 p.m. 1 Q. Anything else in the drawer?
2 BY MR. CRITTON: 2 A. I don't remember what else was in the drawer.
3 Q. Ma'am, the last time that you went, you were 3 Q. What were you doing in the drawer?
4 at Mr. Epstein's house, did he masturbate or not? 4 A. The drawer was open.
A. Yeah, I believe he was masturbating. Well, he 5 Q. And what did the vibrator look like or the
6 was masturbating. I don't know if he finished, 6 massager look like?
7 because — 7 MR. HOROWITZ: Form.
8 Q. He climaxed? 8 THE WITNESS: I'm pretty sure it was just
9 A. Yes. 9 white.
10 Q. He had the towel over himself again? 10 BY MR. CRITTON:
11 A. Yes. I mean 1- 11 Q. Do you know the difference? Have you ever
12 Q. You always, each time you were there, he had a 12 used a vibrator?
13 towel ova himself and you believe that he was 13 MR. HOROWITZ: Form.
14 masturbating? 14 THE WITNESS: Yeah no, I mean like a
15 A. I knew he was masturbating. 15 massager?
16 Q. You )(new it because you could what? 16 BY MR. CRITTON:
17 A. I could tell by his hand. I could feet it. I 17 Q. Well, your lawyer was laughing when I
18 know. 18 interchanged the massager for the vibrator.
19 Q. All right. But you never saw him masturbate, 19 MR. HOROWITZ: That's because she called it a
20 you just saw him doing it under the towel, coned? 20 vibrator and you are calling it a massager.
21 A. Yes, and I neva wanted to look. rd always 21 MR. CRITTON: Well, I'm not sure what it is,
22 look the other way while he was doing it 22 so we're going to find out. So you don't have to
23 Q. He always had a towel on? 23 laugh and nobody else does too.
24 A. Yes. 24 MR. HOROWITZ: I wasn't laughing.
25 Q. The only time, if I understood, that you saw 25
Page 436 Page 438
1 him naked was one timei he got out of the shower before 1 BY MR. CRITTON:
2 he put a towel around himself? 2 Q. Do you know what the distinction between a
3 A. I believe so. 3 massager and a vibrator?
4 Q. And if I also understood your testimony, you 4 A. Yes.
5 never took off your swimsuit, nor your bra, nor your 5 Q. Okay. What do you understand a massager is?
6 underwear at any time, correct? 6 A. Massager, I just, I know the difference. I'm
7 MR. HOROWITZ: Form. 7 not -
8 THE WITNESS: Well, my bra did come like down, 8 Q. Okay. What you saw in the drawer, was it a
9 but not completely off. 9 massager or it was a vibrator?
10 BY MR. CRITTON: 10 A. It looked to me like a vibrator.
11 Q. But you never took it off? 11 Q. What did it look like? Describe it, please.
12 A. No. 12 A. The one I saw was just white and it had like,
13 Q. Did he ever ask you to take your bra off? 13 I don't know, a big thing on the end that was white.
14 A. Yes. 14 Q. Did it look like something that you would get
15 Q. And you declined? 15 at like an adult store or did it look like something you
16 A. Yes. 16 would get from Brookstone, or do you know?
17 Q. Did you ever tell -- strike that. 17 A. I mean I don't know. I mean I heard he uses
18 Did he ever use any type of -- he, 18 that as the, as the vibrator. So I'm assuming that was
19 Mr. Epstein, did he ever have a massage or any kind of 19 the vibrator.
20 what you would have perceived to be a sexual toy? 20 Q. You heard that from Jane Doe 4?
21 A. Yeah, he had a vibrator, but he never used it 21 A. Yes.
22 with me. 22 Q. From anyone else?
23 Q. How do you know he had one? 23 A. I don't think so.
24 A. Because Jane Doe 4 and them told me about it 24 Q. And as to whether it was a vibrator or a
25 and also it was laying right there in the drawer he had. 25 massager, if you purchased it, whether it would be
36 (Pages 435 to 438)
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1 considered a vibrator or a massager, you don't know; 1 Q. Okay.
2 would that be a fair statement? 2 A. It was like a really bad dream.
3 MR. HOROWITZ: Form. 3 Q. Is that the last dream you've had about that
4 THE WITNESS: Yes. 4 separate and apart from the flashbacks?
5 BY MR. CRITTON: 5 A. I remember having other dreams, but they
6 Q. Okay. But he never used that on you, nor did 6 weren't like as bad. They weren't like, nothing like
7 he ever attempt to use that on you, whatever it was, 7 significant that I could remember. I just ri.nomtber that
8 correct? 8 one, like I woke up crying and felt like I was having a
9 A. Yes. 9 panic attack.
10 Q. That's correct? 10 A vas, actually it was when I
11 A. Yes. 11 worked I aloon, because I had a dream that lie
12 Q. Did you ever discuss with your boyfriends, 12 came there to Visit me. And my parents were there and
13 even the long terms, a from 107, '08 and '09, 13 it was just like a really bad nightmare that I had.
14 did you ever tell them anything about Mr. Epstein? 14 Q. Okay. Is that the last time you had a dream
15 A. Absolutely not. 15 about it separate and apart from the flashbacks?
16 Q. Okay. You said that you bad flashbacks. 16 A. I mean I've seen him, like I have had dreams,
17 Describe what you mean by a flashback. 17 but none that 1 could really remember like
18 A. Just when somebody would say his name or I 18 significantly.
19 would just even hear Jeffrey, just like me being there, 19 Q. Okay.
20 the massage table, him in the shower, I would just get 20 MR. CRITTON: How about another five minutes
21 flashbacks. 21 and then I'm done.
22 Q. You had bad memories of that? 22 MR. HOROWITZ: Five is fine. You are on the
23 A. Yes. Even, sometimes even nobody had to say 23 clock.
24 anything. Like I would just be lilt's in a bad mood or 24 BY MR. CRII7ON:
25 upset and I would just get, you know, just memories or 25 Q. I asked you earlier when's.- culd call
Page 440 Page 442
1 fit 1 you, and I think — well, let me strike that.
2 Q. Does that happen very often or is that just 2 When I asked you earlier, I think you said
3 really if you, if someone brings up the episode, like if 3 that Sarah never texted you through the phone, nor did
4 you have something to do with this case or you would 4 she ever communicate with you over the computer,
5 read about Mr. Epstein, then you would think back of the 5 correct?
6 time that you were there? 6 A. I don't believe, I definitely never had any
7 A. I mean the flashbacks like have always 7 e-mails or computer, but I don't think she ever texted
8 happened. 8 me.
9 Q. I'm sorry? 9 Q. All right. And the only communication
10 A. They have always happened, but it gets worse 10 sePtrapart from the conversation that you had
11 when, you know, I hear about the case or somebody says 11 wi the voice message that she left you when
12 something to me about it or I have to, you know, talk to 12 you were with the Palm Beach poilitiagg they wore
13 somebody about it. 13 interviewing you, all other calls f were dealing
14 Q. Did in terms of have you ever had a dream? 14 with could you come or could you bring someone else to
15 A. Yes. 15 come to work?
16 Q. How often do you have a dream or how many 16 MR. HOROWITZ: Form.
17 dreams have you ever had about having been at 17 THE WITNESS: Yes.
18 Mr. Epstein? 18 BY MIL CRITTON:
19 MR. HOROWITZ: Form. 19 Q. And you understood that to mean could you come
20 THE WITNESS: I don't exactly, but I 20 and give Mr. Epstein a massage?
21 remember one that like stood out really clearly. 21 MR. HOROWITZ: Form.
22 BY MR. CARTON: 22 THE WITNESS: Yes. Well, she said -- well,
23 Q. How long ago? 23 basically, yeah.
24 A. It was about when l was talking to the FBI, so 24 BY MR. CRITTON:
25 probably about three years ago. 25 Q. And she never, that i never said to
37 (Pages 439 to 442)
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1 you "I want you to come to work to provide sexual 1 Q. Does she work now?
2 services for Mr. Epstein"? 2 A. Yes.
3 She never said that, did she? 3 Q IS her boyfriends name?
4 MR. HOROWITZ: Form. 4 A
5 THE WITNESS: No. 5
6 BY MR. CRITTON: 6 A. a - don't know.
7 Q. All based on what you told me, 7 . Is that that used to be friends
8 just told me never attempted to persuade or to 8
9 induce or to entice you to engage in any sexual conduct 9 A. No.
10 with Mr. Epstein during any phone conversation, did she? 10 Q. Different
11 MR. HOROWITZ: Form. 11. A. Yes, differen
12 THE WITNESS: Just the massages and basically 12 Q. Did you know nice
13 that. 13 A. Yes.
14 BY MR. CRITTON: 14 Q. Since Jane Doe 4 an' broke up —
15 Q. Right. And she's the only one who ever called 15 A. Yes.
16 you, true? 16 Q. -- have you seen= at all since then?
17 A. I think so. 17 A. I think I just saw him once when I was
18 Q. Has anyone, separate and apart from the 18 downtown.
19 allegations you have made in this complaint, has anyone 19 Q Okay. Did you consider him kind of a scary
20 ever attempted to sexually assault you or to rape you? 20 character? Was he someone you were scared of?
21 A. No. 21 A. I was never scared of him. !just thought he
22 Q. At any time? Have you ever been attacked by 22 was, thought he was an asshole. I never really liked
23 anyone? 23 him because of what happened with Jane Doe 4.
24 A. No. 24 . Did ou ever know Jane Doe 4's boyfriend,
25 Q. Other than your trip to Italy this coming 25
Page 444 Page 446
:1 summer, any other plans for trips, vacations -- 1 A. Yes.
2 A. No. 2 Q. Nice guy?
3 Q. — when you finish college? 3 A. Really nice guy.
4 A. No. fm just saving up for Italy. 4 MR. CRITTON: Okay, that's all I've got.
5 Q. Do you plan to stay, when you finish your 5 Thuile you. Read?
6 month in Italy, do you plan to try to save up enough 6 MR. HOROWITZ: We'll read, and we'll take a
7 money so you can travel a little bit before you can come 7 copy if it's ordered.
8 to the states? 8 THE VIDEOGRAPHER: Going off the deposition at
9 A. I don't think so. llure are certain dates, 6:49. This is the end of the deposition.
10 it's only like a month, and everybody is pretty much 10 (Witness excused.)
n leaving together. 11 (Deposition was concluded.)
12 Q. Are any of your friends going with you? 12
13 A. Not — there are just people from school. 13
14 Q. Okay. I asked you earlier -- this is my last 14
15 short series. I asked you, you said Jane Doe 4 is your 15
16 best friend. Who is your next best friend? 16
17 A. can probablM 17
18 QM? 18
19 A. Yes. 19
20 Q. Next down the scale from. would be whom? 20
21 A. J 3. 21
22 Q. I still in town, in the West Palm Beach 22
23 area, Palm Beach County? 23
24 A. Sometimes she's in town became her parents 24
25 live here, but she lives with her boyfriend in Atlanta. 25
.:a•l•teesas•brualtatalr•N•• . •
38 (Pages 443 to 4 46)
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1 CERTIFICATE OF OATH 1 DATE: Morn 25, 2010
2 TO. Jaw Dee te7
2 STATE OF FLORIDA do Adam Diforowlis, Esq.
3 COUNTY OF PALM BEACH 3 Parmelstein & Horowio, P.A.
4 18205 Bivouac Boulevard
Sale 2218
5 Mimi, Florida 33160
6 I, the undersigned authority, certify that 5
7 !BRE: /ane Doe No. 2 vt. Epstein
Jane Doe #7 personally appeared before me and was duly 6
8 sworn on the 15th day of March, 2010. 7 The transcript of your deposition taken on
9 3. 5.10 has been completed and amity reading and
8 sigiung. As recousty ameech the trans* well to
10 Witness my hand and official seal this 25th finished to you through you, counsel
11 day of March, 2010. 9 Attend of the ttansonpt youwillfmdas
cram sheet As son read your deposition, my dames
12 10 or met mottos that you wish to make should he noted on
13 the arse sheet Ming page and tine number of said
14 II thane, Onto yea hurt read the transcript and noted any
changes, be sure to sign and date the errata Meet and
15 12 Mtn there pager to me
If yet: do not lewd and ogs the deposition
13 within a numonahle time, the original. which has
16 already been formided to the ordering canny, tray be
Rachel W. Bridge, RMR, 14 filed with the Ckric of the Court. Ifre wish to wave
17 your signature, lign you name in the blank at the
Notary Public - State ofFlorida 15 boom of this Icon and ;duns it to to
My Commission Expires: 5/11 16 Sincerely,
18 My Commission No.: DD 607230 17
18 Ftachd W. Bridge. RAIL ad
19 PROSE COURT REPORTING AGENCY
20 19 250 Amnion Mama Scud; MI500
21 pWbecat
rinlit 33401
20
22 21 I dobertby waive my swam.
23 22
23 beeDan
24 24
25 25
Page 448 Page 450
1 CERTIFICATE 1 CERTIFICATE
2 STATE OF FLORIDA
3 COUNTY OF PALM BEACH 2
4 3 THE STATE OF FLORIDA
5 Reehd W. Bridge, Certified Realtime 4 COUNTY OF PALM BEACH
Reporter and Notary Public in and for the State of
6 Florida at Large, do hereby catify this the 5 I hereby certify that I have read the
aforementioned witness was by me first duly swam to 6 foregoing deposition by me given, and that the
7 testify the a** truth; that I was authorized to and
did report said deposition in stenotype and that the 7 statements contained herein are true and correct to the
8 foregoing pages numbered 1 to 446, inclusive, we a true 8 best of my knowledge and belief; with the exception of
and correct transcription of my shorthand notes ofsaid
9 deposition. 9 any corrections or notations made on the errata shed,
10 1 further certify that said deposition was 10 if one was executed.
taken at the time and place beronaberee set forth and
11 that the taking of said deposition was commented and
11
completed as hereirebOVe set Cu. 12 Dated this day of
12 13
I gather candy that I am not attorney or 2010.
13 counsel of any of the parties, nor am 1a relative or 14
employee of any attorney or counsel of potty connected 15
14 with the *elite, nor am I financially imerested in the
action 16
15 • 17
The foregoing certification of this transcript
16 does not apply to any reproduction of the urns by any 18
means unless under the direct control and/or direction 19 JANE DOE #7
17 of the certifying reponer.
18
20
19 is 25th day of March, 2010. 21
20 22
21 14-) .
22 Ilieb
acd. Bridge, CRR 23
29 24
24
25 25
39 (Pages 447 Lo 450)
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Page 451
ERRATA SHEET
2 IN RR Jane Doe No. 2 vs. Epstein CR: Rachel Bridge
3 DEPOSITION On JANE DOE 47
4 TAKEN: 3-15-10
5 DO NOT WRITEON TRAICCIUFT - ENTER CHANGES HERE
6 PAGER LINER CHANGE REASON
7
8
9
10
11
12
13
14
15
16
17
18 Please forward the mignui signed c nW 010:1 to this
office so that copies may be distributed to ail ponies.
59
Under penalty of perjury. I desist that I have real my
20 deposition and that it is true and ccirect subject to
any changes in form or substance entered here.
21
22 DATE:
23
24 SIGNATURE OF DEPONENT:
25
40 (Page 451)
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