EFTA00750707.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME I Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-801092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE Wednesday, September 30, 2009 9:37 a.m. - 6:10 p.m. One Clearlake Centre 250 South Australian Avenue, 1st Floor West Palm Beach, Florida 33401 Reported By: Pamela J. Sullivan, RPR, FPR, CLR Prose Reporting Agency, Inc. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333.772-1552) 170ae621-3493-40cd-8666.0Do698ca2735 EFTA00750707 17 le 19 20 n 24 25 Page 4 1 APPEARANCES: 2 On Shelf deb* Plaintiff. Jane Doe 3 BRAD 1. EDWARDS, ESQUIRE ROTHSTEIN ROSENFELDT ADLER Las Dietary Case, Sete 1650 401 Es Las Cass Boalceard 5 Mont 33)01 On hLlfof Alley Esidn: ROBERT D. EAMON, At, ESQUIRE BURMAN, CRITTON, LUTHER a COLEMAN. UP 9 303 Banyan Hcadevar4 Sake 400 10 , Banda 33401 12 Ooh of the Defendant. WES' Engel', 13 JACK ALAN GOLDBERGER. ESQUIRE ATTERBURY. GOLDBERGER & WEISS, PA 14 250 Asinlian Mese South Suite 1400 15 West Aim Bach, Plaids 33401-5012 It On Ethan of PUSH in Added Cu. No. 08-80469. iSEDRO M. GARCIA. ESQUIRE GARCIA LAW FIRM. PA 224 Dan Street Stith 900 C 3340) On NEN( of lane Does I duo* 8: ADAM D. nortown2, ESQUIRE MERMELSTEIN & HOROWITZ. P.A. 11205 Disease Bothnia Suite 2218 elndde 33160 1 2 3 4 5 6 10 1: 12 13 INDEX WTINESS: DIRECT CROSS REDIRECT RECROSS JANE DOE BY MR. CRITTON 5 EXHIBITS MARKED DESCRIPTION PAGE Defendant's No. I (Copy of Plaintiff)Wimess Identification Card) Defendant's No. 2 14 (Victim's Petition) 15 Defendant's No. 3 118 (Victim's Motion to Unseal Non-Prosecution Aff u.nt) 16 17 18 19 20 21 24 25 I16 Defendant's No. 4 121 (Declaration of A. Marie Villafrra) (4" Marked off the record.) Page 3 On behalf of the Plaintiff- JACK P. MI, ESQUIRE SEARCYDENNEY SCAROIA BARNHART & SHIPLEY, P.A. 3 2139 Palm Beach Lakes Boulevard :ach, Florida 33409 4 5 On behalf of the B.B.: 6 ADAM J. LAWN°, ESQUIRE LEOPOLD KUVIN 2925 PGA Boulevard, Suite 200 33410 8 dens, Florida 9 10 11 ALSO PRESENT: 12 Jeffrey Epstein, via video conference Stan Sanders, Vidoograpber 13 14 15 16 17 18 19 20 21 24 25 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Page 5 PROCEEDINOS - - - Deposition taken before Pamela J. Sullivan, Registered Professional Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. (Discussion held off the record.) MR. CRITTON: Let's get started. MR. EDWARDS: Brad Edwards, and I represent Jane Doe. ' MR. HILL: Jack Hill, on behalf (AM. MR. HOROWITZ: Adam Horowitz, on behalf of Jane Does 2 through 8. MR. LANGINO: Adam Langino, on behalf of B.B. MR. CRITTON: Bob Critton, on behalf of Jeffrey Epstein. MR EDWARDS: And, Mr. Critton, I don't think we've had this Cant Reporter before, so maybe we want to instruct as to how we're dealing with the names, how they're going to be typed up. MR. CRC-TON: Pamela, are you familiar with how Cindy did the names at all? 24 COURT REPORTER: Let's go over it. 25 MR. CRITTON: All right. What we -- what (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 2 (Pages 2 to 5) (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501.333-772-1552) fleae621-3493-40cd-8666-000698ca2735 EFTA00750708 Page 6 1 we've done in the past is, as with regard to anyone 2 who's identified as a Plaintiff in the case, and 3 only that group, you know, absent some other 4 agreement amongst the, the clients or the parties 5 and their attorneys is, is we will refer to them by 6 initials only, such as Jane Doe, who's seated in 7 front of us. She will be — well, except she's 8 gone as lane Doe, so we should keep her as Jam 9 Doe. So much for that ewertion, but... 10 And Mr. Hill's ellen ., will be referred to as , because how 11 that's 12 we referred to her, and she has -- she gave up 13 anonymity. 14 Jane Doe's 2 through 8, we may use their real 15 names, and then we'll just use, if it's 16 Sally Jones, it would be S.J. And then what you do 17 is, is on a separate piece of paper, as Cindy did, 18 you will give us a key that ties in with any name 19 that we've designated by a first or a last name — 20 or both. 21 MR. EDWARDS: All right. And one other thing 22 I want to — I want to put on the record, I know that you disagreed last time, but I think that 24 it's, to make the record clear, we feel strongly 25 that this deposition and the transcript and the Page 8 trat 1 2 i t, you claimed all sorts of privileges 3 and, and other objections and instructed her not to 4 answer. Obviously, the judge has to consider a 5 transcript. 6 MR. EDWARDS: Agreed. 7 MR. CRITTON: So I would say as to the B transcript, no, and with the transcript that Pamela 9 is going to prepare, it's going to have — it won't 10 disclose Jane Doe's name or Jane Doe's name. All 11 right. So with regard to the video, as' — as 1 12 indicated to you to the extent that the video would 13 be necessary to be filed for any purpose or to use 14 for any purpose, you have 15 days to file 15 something. lf, in fact, the video was used, I 16 would do that which was necessary so that 17 Jane Doe's face would not be disclosed, so that no 18 one could identify her. 19 MR. EDWARDS: Okay. Well, I — if you're 20 only talking about blocking out her face as the 21 only way to protect her anonymity, we, we wouldn't 22 feel that that would be accommodating enough to, to 23 secure her anonymity. 24 But now I'm understanding that you're saying 25 you may file this with the court, which I have much I Page 7 1 video remain confidential, and that the witness's 2 anonymity is protected, absent some court order 3 directing otherwise, as we feel that's consistent 1 with the court orders that have already been s entered, as well as the instructions of the various 6 judges presiding over these cases. 7 I'm assuming, if you are in disagreement of 8 that, then you will allow me 15 days to file a 9 motion in that regard, if you think that's 10 necessary. 11 MR. CRITTON: Yeah. Well we, we had this 12 discussion at the deposition of.l. 13 MR. EDWARDS: Right. 14 MR. CR1TTON: And you dealt specifically with 15 the video, not the transcript, is my recollection. 16 And I said it, with regard to the video, there's — 17 there are orders granting your client, and in her 18 case., and I think in Jane Doe, anonymity. And 19 as such, we don't plan to violate that court enter 20 to the extent that the transcript -- and a perfect 21 mantS of it is, is, if you think that the — that 22 theM. transcript can't be filed, it's absurd, 23 because.. claimed the Fifth Amendment about 30 24 to 50 times. So in order to get some ruling from 25 the Court, the Court's going to have to look at the 1 2 3 4 6 8 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 1/4 AaiGIVaSnes%)4.0..sstnr.M.. Page 9 less a problem with than you posting it on the Internet or using some other device to post it to the public, which is what was implied last time. And I think the example you gave was that another attorney has posted your client's deposition on the Internet. MR. CRITTON: All right. Let, let's deal exactly what the issue is. If Spencer Kuvin, for publicity, and for no other reason, contacted Jose A. Lambiet, who in turn then put it on his website so that everyone could view the question, and he did it to embarrass, to humiliate, it was improper, it was inappropriate, I hope I wouldn't use the same conduct or what I would say lack of professionalism to do something like that. MR. EDWARDS: Well, but, obviously, the difference is Mr. Epstein's anonymity has not been protected in this case, and these victims have. So... MR. CRITTON: So it's okay to humiliate and embarrass someone and to be unprofessional? MR EDWARDS: This has nothing to do with me or my clients. MR. CRITTON: All right. MR. EDWARDS: So arc we noon the same page, (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. A 3 (Pages 6 to 9) (561) 832-7506 Beetronlcally signed by Pamela Sullivan (601-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) I reae621-3493-40cd-8666-00.3698Ca2136 EFTA00750709 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 Page 10 and I need to file a motion to protect the confidentiality of the video and the deposition transcript, or do you agree that it's - it should remain confidential, but for whatever motions you have to file and attachments you have to make to the court file. MR. CRITION: You, you need to file whatever motion you think is appropriate. Pm going to do nothing to breach the anonymity order that has been entered by the Court. So if you if you think that some additional order is necessary, you have 15 days to file something with the Court, and then I'll respond to it, Brad. MR. EDWARDS: Okay. Thanks. MR. CRITIC/14: Okay. And Sid Garcia showed up. MR. GOLDBERGER: What am I? MR. CRITTON: And Jack Goldberger, too. Sony, you're not just a potted plant here. Thereupon, JANE DOE, Having been first duly sworn or affirmed, was examined and testified as follows: THE WITNESS: Yes. Page 12 1 Q. At the address where you're currently 2 residing, does anyone live with you? 3 A. Yes. 4 Q. Who? 5 A. My daughter and my boyfriend. 6 Q. Are you living in an apartment, a house? 7 What kind of accommodations? 8 A. A house. 9 Q. What city is the house located in? 10 MR. EDWARDS: Don't answer. 11 She's not going to answer any other questions 12 about the location of her address or the location 13 where she's residing, just out of fear for her own 14 safety and the safety of her daughter. 15 MR. CRJTTON: Okay. 16 BY MR. CRITTON: 17 Q. Ma'am, has, has anything occurred since 18 you've been represented by Mr. Edwards that causes you 19 concern about your safety or well-being? 20 A. Yes. 21 Q. What? 22 A. I have seen a lot of cars passing by my house, watching, looldng at my house, and going by very 24 slowly, several times a day. There have been cars that 25 were parked across the street from my house on several Page 11 1 DIRECT EXAMINATION 2 BY MR CRITTON: 3 Q. Would you please tell us your full name, 4 please. 5 A. Jane Doe. 6 Q. And you're going to need to speak up, ma'am, 7 because I could barely hear you. All right 8 A. Jane Doe. 9 Q. What's date of birth? 10 A. 11 Q. And where do you currently reside? 12 MR. CRITTON: Don't answer. 13 She's not going to give her current address, 14 and it's out of fear for her safety. And that's 15 the only question you're likely not going to get an 16 answer to today. 17 BY MR. CR/77ON: 18 Q. Let me ask you this: Do ou 19 nssidecl over the years at 20 EIR true? 21 A. Yes. 22 Q. All t. And whose address is that? 23 A. 24 Q. And her name is? 25 A. Page 13 1 different occasions, cars that I had never seen before. 2 There have been people who have gone to speak to my 3 friends and my family members and ask them questions 4 about me. 5 Q. So why — why — well, let's start with the 6 cars. On how many occasions since you well, on how 7 many occasions have you seen what you thought were B suspicious cars, as distinct from just like — as 9 distinct from just cars driving by? 10 A. Them have been so many, I can't — I can't 11 count 12 Q. Can you identity any of those suspicious 13 cars? Color? Make? Model? 14 A. For one, there is a blue Durango SUV that 15 comes by a lot 1,1have taken pictures of it. I have 16 taken pictures of all the cars. 17 Q. Oh, you have? And where, where are those 18 pictures? Did you take them on a digital camera? 19 A. Yes. 20 Q. Okay. And what did you do with those 21 pictures? 22 A. I sent them to Brad. 23 Q. And Brad, Mr. Edwards? 24 A Yes. 25 Q. Are you aware whether he's filed any motion (561) 832-7500 4 (Pages 10 to 13; PROSE COURT REPORTING AGENCY, INC. (563) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1552) Electronically signed by Pamela Sullivan (501-333-772-1652) ffeae621-3493-40“1-8666-00e698ca2735 EFTA00750710 Page 14 1 with the Court to try to identify who, to keep those 2 cars away from you? 3 A. Not that I'm aware of. 4 Q. Okay. How many pictures have you taken? 5 A. Four or five. 6 Q. And, and in terms of parked cars, have you 7 taken pictures of any of the parked cars? 8 A. One. 9 Q. What was that car? Was that the blue 10 Durango? 11 A. No. It was a silver — Pm not sure what 12 kind of car it was. 13 Q. Okay. Do you still have -- do you still have 14 your photographs of those cars on your camera? 15 A. Not on my camera. 16 Q. Did you take — how did you send them to 17 Mr. Edwards? 18 A. I have them on a disk. 19 Q. All right. And tell us — tell the members 20 of the jury how many times you've called the police 21 about this. 22 A. I haven't called the police, because 23 they — nobody ever came out and harassed me. I just 24 saw the cars passing my. 25 Q. All right. So no ones harassed you; no Page 16 1 talked to families and friends, where they have — let 2 me strike that. 3 You indicated various individuals had done -- 4 had talked or had spoken with family and friends about 5 you -- 6 A. Yes. 7 Q. correct? 8 All right Tell me which family members have 9 been contacted and asked questions about you. 10 A. The only one that I really !mow of is my 11 sister. 12 Q. 13 A. 14 Q. And what did tell you? 15 A. She just told me that me some people went to 16 her house and asked her some questions about me. 17 Q. When did tell you that? 18 A. lint not sure how long ago it was. She 19 actually sent me a text message. 20 Q. Was it within the last week? Was it in the 21 last month? Was it a year ago? Give me your best 22 estimate. 23 A. Probably a month, maybe two months. 24 Q. And did she tell you who the people were that 25 talked to her? And who's that? Page 15 1 one's intimidated you. All you've seen is cars that you 2 can't identify driving by and/or parking across the 3 street; is that correct? 4 MR. EDWARDS: Object to the form. 5 MR. CRITION: You can go ahead and answer. 6 MR. EDWARDS: Well, Pm going to object - MR. CR1TTON: No, no. 3 MR. EDWARDS: -- and ask her not to answer -- 9 MR. CROTON: It's form. 10 MR. EDWARDS: — if it is attorney-client 11 privilege information. Because you're acting like 12 she can't identify than, when, in reality, she may 13 have been able to identify them. 14 MR. CRITTON: Is that a form objection? 15 MR. EDWARDS: Pm telling her not to answer. 16 It's attorney/client information. 17 MR. COTTON: Would you read my question 18 back — 19 MR. EDWARDS: (Inaudible) her attorney. 20 MR. CRITTON: -• please. 21 (Whereupon, the requested portion of the 22 record was read aloud by the Court Reporter.) 23 THE WITNESS: Yes. 24 BY MR. CRITTON: 25 Q. All right. Now, you said some people have 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 17 A. No. Q. Did you ask her? A. Yes, I did. Q. And what did she say? A. She said that they worked for Jeffrey Epstein. Q. And did she say how those people got in contact with her? A. They went to her house and knocked on het door. Q. And did she tell you what she said to them? A. No. Q. Did she tell you whether she spoke with her — spoke with them? A. She said she did talk to them. Q. She did not? A. She did. Q. All right Did she say where — did she talk to them at the house? A. Yes. Q. And did she — and did you say, well, what did you say about me? A. Yes, I did. Q. Okay. And did you say, what questions did they ask? 5 (Pages 14 to 17) (561) 832-750C PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772.1552) Electronically signed by Pamela Sullivan (501-333-772-1552) f7eae821-3493.40cd-8080-00e888ca2735 EFTA00750711 Page 18 Page 20 1 A. Yes, I did. 2 Q. And when you said, what questions did they 3 a*, what did she say? 4 A. She, she said she doesn't really know. I 5 guess she doesn't remember. She says that she was asked 6 if she knew about my going to Jeffrey Epstein's house, 7 and she told them that she gave me a ride there before. 8 Q. And was that true? 9 A. Yes. 10 1Okay. On how many times did your sister, 11 give you a ride to Jeffrey Epstein's home? 12 A. Three, maybe four. 13 Q. And I assume you knew that she had driven you 14 to Mr. Epstein's house, separate and apart from her 15 telling you that the other day, or a month ago. 16 A. Excuse me? 17 m liassume you were aware that your sister, 18 , drove you to Mr. Epstein's house prior to the 19 last month or two; is that correct? 20 A. Yeah. 21 Q. And that is, her telling you that did not 22 refresh your recollection; you knew thatMl. had 23 driven you to Mr. Epstein's home; true? 24 A. Yes, I knew that. 25 Q. Okay. Did she say how long she had spoken to 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. All right. So we've had nine months in '09. Of, of the — of the nine months in 2009, what portion or what months can you • • that you did not have a good relationship wi ? mil have only been on speaking terms with for the past maybe three months. Q. So the past three months, which would be basically June-ish, beginning of June — A. Yeah. Q. — through today, you're on good tents with her? A. Yes. Q. All right. And good terms means you're acting like sisters — like I would say more normal sisters would, have a nice conversation, you can talk to her, you're supportive of each of one another, et cetera? A. Yes. Q. All right. Do you have any other sisters? A. Yes. Q. Okay. First of alla what's her date of ma. A. I don't know what year. Q. How old is she? Page 19 1 the people? 2 A. No. 3 Q. She, meaninga. 4 Did she — other than saying she gave a ride 5 to you to go to Mr. Epstein's house, did she tell the 6 individuals who came to her home anything else? 7 A. Not that I know of. 8 Q. Okay. How long did you — well, let me 9 strike that. 10 r, I alb /lave a good relationship with 11 your siste 12 A. It's on and off. We fight often. 13 Q. Are you on a good relationship with her now? 14 A. Right now l aro. 15 Q. Has that been true for the last six months? 16 A. No. 17 Q. Okay. Was it. sometime within tiniest 18 six months? 19 A. Yeah. 20 Q. When was that? 21 A. Fm not sure exactly how long ago it was. 22 I — 23 Q. Let me — let me rephrase my question. We're 24 in the year 2009, almost at the end of September 30th 25 today. You're aware of that? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 21 A. Q. A. A. Q. A. Q. A. Q. A. Q. And A. She be on Q. She's now. Andes is, you said, was how old, how many years — A. Two years older than me. Q. So she's.? A. Yes. Q. All children of the same marriage, with the same mother and A. My sister., has a different father. Q. What's her father's name? A. I don't know. Q. Does she know? A. No. She's six years older than I am. So do you have another sister? Yes. Older or younger? it Older. her name? How old is-? She is two years older than I am. ow old today? (561) 832-7500 PROSE COURT REPORTING AGENCY, 6 (Pages 18 to 21) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501.333-772.1662) 170a0621-3493.40cd.8666-000698ca2735 EFTA00750712 Page 22 1 Q. No one knows? 2 A. No. 3 Q. So your mother -- your mother — obviously, 4 same mother? 5 A. Yes. 6 Q. a And your mother's name is what? 7 A. 8 Q. Lt name? 9 A. 10 Q. Where does she live? 11 A. I don't }mow her address. 12 Q. When is the last time you saw her? 13 A. About a week or so ago. 14 Q. :Where did you see her? 15 A. She came to my house. 16 Q. So at least you — you at least told your mom 17 where you live? 18 A. Yeah. 19 Q. All right. Now, what — what's her 20 date of 21 A. 22 Q. Good relationship with int 23 A. We don't speak on a regular basis, but we are 24 nice to each other, I guess. 25 Q. Where does she live? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. A. Q. A. Q. A. Page 24 She does not have a home phone number. Does she have a cell phone? Yes. Do you consider a cell phone a phone number? Yes, but not her home number. allit her cell phone number? Q. What's your cell phone number? A. My cell phone number? Q. Yes, ma'am. MR. EDWARDS: Don't answer. mean, you're not going to call her, so I'm, I'm objecting and, and in the witness not to give out her cell phone number on the record right now. BY MR. CRITfON: Q. Okay. Why don't you want to — well, you're going to follow your lawyer's instruction? If he tells you not to answer a question, you're going to follow that instruction? A. Yes. Q. Okay. And — (Discussion held off the record.) BY MR. CRITTON: Q. How long have you — the current cell phone 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 Q. Do you know her phone number? Page 23 A. Alabama. Q. Do you know her address? A. No, I do not. Q. Is she married? A. No. Q. Any children? A. Yes. Q. How many? A. Two. Q. And ever been married? A. No. Q. What does she do for a living? How does she support herself? A. I — I'm Q. Okay. where does she live? A. A. Q. A. Q. Does she live there with anyone? A. Yes. Do you know her address, exact address? Q. A. No. Ws off of Which is whey o West Palm Beach? Yes. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 Page 25 1 that you have now, how long have you had it? 2 A. About two years. 3 Q. Did you have a cell phone before that time? 4 A. Yes. 5 Q. Okay. Bow long did you have that cell phone? 6 A. I'm not sure. I didn't have it for very 7 long, and I lost it. 8 umber? A. Q. Did you ever use a cell phone to call Mr. Epstein's home? A. Yes. Q. issirt the number you would have used, the A. No. Q. Okay. Did you have a prior cell phone number? A. Yes. Q. All right What was that number? A. I don't remember the full number. I remember that it started with 352. Q. Was it your own? Was it under your name? A. No. Q. issis it under? A. (561) 8 32-7 5 0 0 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 17eae621-3493-40cd-8666-00c693ca2735 EFTA00750713 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. III..? A. Q. A. NO. A. A. Q. A. Page S Yes. Does she still have that same cell phone? Who was the service provider, her number? Sprint, i believe. Who's your service provider right now? Metro. I'm sorry? Metro PCS. Q. Have you used your cell phone is a friend of yours? A. Yes. Q. Okay. is a friend of yours? A. Yes. Q. Okay. Are you aware of any other individuals who are Plaintiffs in — and are suing Mr. Epstein for money? A. No. Q. Do you call — do you have a home phone? A. Yes. Q. A land line? A. Yes. All right. I assume you've called bode midi.. on your cell phone? Page 28 1 At some point, Mr. Edwards came to represent 2 you; true? 3 A. Yes. 4 Q. All right. And when did Mr. Edwards — when 5 did you hire Mr. Edwards to represent you? 6 A. Pm not sure exactly what day that was. Q. Clearly, it was before the lawsuit was filed, 8 which was August 13th; correct? 9 A. Ulbhult Yeah. 10 Q. All right How many months prior to that 11 lawsuit being filed did Mr. Edwards begin to represent 12 you? 13 A. I'm not exactly score. 14 . There was another suit that was filed 15 hair:mit, Jane Doe. It dealt with a claim of, 16 of asserting some sort of victim rights. Were you that 17 Jane Doe? 18 A. I don't know. 19 Q. Okay. Well, are you aware of any other 20 lawsuit that's been filed — that was ever filed on your 21 behalf, where Mr. Edwards represented you, other than 22 the current lawsuit, Jane Doe versus Jeffiey Epstein? 23 A. I don't know. 24 Q. Okay. So you — you're unaware of any 25 lawsuit that Mr. Edwards has ever filed on your behalf; Page 27 1 A. Yes. 2 Q. All right. And I assume that you talked to 3 them about your cases from time to time; true? 4 A. No. 5 Q. You so if I ask you is it your testimony, 6 as you sit here today, that since the time you filed the 7 lawsuit against MrStein, you have never discussed 8 your lawsuit withM.? 9 A. No. 10 Q. That's not true — that's not correct? 11 A. What is not correct? 12 Q. All right. Listen -- let me ask the question 3.3 again. 14 Is it a correct statement, that is what Fr() 15 going to say, is this true, that since the time you 16 filed your lawsuit in August of 2008, you have not 17 discussed your lawsuit with M.; is that correct? 18 A. That is comsat. 19 Q. And you've not discussed either your lawsuit 20 or any aspect of your lawsuit or your interaction with 21 Mr. Epstein with.. since August 13th, 2008; is that 22 correct? 23 A. Yes. 24 Q. All right Since August 13th — well, let me 25 strike that. Page 29 other than Jane Doe versus Jeffrey Epstein; is that 2 correct? 3 A. Well, I would probably be aware, but I'm 4 obviously not a lawyer, so I don't really know. 5 Q. You're — before Mr. Edwards filed your 6 lawsuit here, in this instance, you had to give him 7 authority; didn't you? 8 A. Yeah. 9 Q. Okay. Have you ever given Mr. Edwards 10 authority to fide any other lawsuit anyplace on your 11 behalf; yes or no? 12 A. I don't know. 13 Q. Okay. Well, you can't answer that just so 14 for the jury — ladies and gentlemen of the jury, you 15 can't answer that question yes or no; is that what 16 you're telling us? 17 MR. EDWARDS: She's not going to answer the 18 question because you're asking attorney/client 19 privilege information. 20 MR. CRITTON: She's already asked — she 21 already answered the question, so you waived the 22 attorney/client privilege. So now — 23 MR. GARCIA: Right 24 MR. EDWARDS: That's your — that's your 25 opinion, but she's not going to answer — answer (561) 832-7500 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) fteao621-3493-40cd-8666-000698ca2735 EFTA00750714 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 1 any more questions along this line. So — 2 MR. CRITTON: Okay. 3 MR. GARCIA: —you can ask as many questions 4 as you want. 5 MR. CRITTON: She's not your client -- 6 MR GARCIA: That's right. 7 MR. CRTITON: — all right, Mr. Garcia? 8 She — she — 9 MR. GARCIA: You made a misstatement of the 10 law. You can't waive attorney-client privilege. 11 MR. CRITTON: Sure, you can. 12 MR- GARCIA: It has to be knowing and 13 intelligence. And she -- she — 14 MR CRITTON: Well, you bow — okay. Is 15 your objection as to form? 16 MR GARCIA: Fm just saying it's a 17 misstatement of the law. 18 MR. CRAYON: Fine. Then you can object to 19 form. 20 BY MR. CRITTON: 21 Q. Have you hired any other lawyers, or at any 22 time did you hire any other lawyers than Mr. Edwards to 23 pursue your claim? 24 A. No. 25 Q. Okay. Do you know a person by the name of 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 32 A. Last Thursday. Q. You say he's at Okaloosa? A. Right now he's in Martin County, but he was at Okaloosa Prison. Q. Okay. And he's serving a sentence for having murdered a young boy a true? A. Yes. Q. And that occurred when you were how old? A. Twelve. Q. How long have you had the tattoo, ma'am? A. Since lives 18. Where did you get the tattoo done? At the 45th Street flea market Q. Do you remember the name of the place? A. No. Q. Do you have any other tattoos? A. Yes. Where? On my legs. And what are they of? Are they visible? Yes. Q. A. Q. A. Q. A. Q. Okay. Could I see them, please? A. (Witness standing.) That's my nephews (indinting). Q. Page 31 1 Jay Howell? 2 A. No. 3 Q. Okay. Ever heard of the name Jay Howell? 4 A. No. 5 Q. Have you authorized him to represent you? 6 A. No. Q. Ms. Jane Doe, I notice you have a tattoo on your right arm, your right, upper arm; is that correct? A. Yes. Q. And what does it say? A. Q. that's what it spells, IME? A. That's what it would spell, but it's actually Q. That's A. Yes. Q. When did you -- where does he currently reside? A. Martin County jail. Q. And he's serving a sentence there; correct? A. Urn, actually, he's, urn -- he's down from Okaloosa Prison for a hearing Q. Did you see him when he was here? A. Yes. Q. When did you last see him? Page 33 1 A. That's my other sister's two children, niece 2 and nephew (nephew). 3 Q. All right And they — 4 A. Q. And she as one child? 6 A. Yes. 7 Q. Okay. And the other tattoos on your left -- 8 around your left ankle are your -- children? 9 A. Yes. 10 Q. All right. When -- when did you receive, or 11 when did you have the tattoo of= ptn on? 12 A. That was my first one, and so l gotragr 13 I named 18. 14 Q. Where? Where did you get it? 15 A. On my right leg. 16 Q. I'm sorry? 17 A. On my right -- 18 Q. No, no. 1, !saw that. Where, 19 location-wise, did you have the tattoo put on? 20 A. I had tern all done at the same place. 21 Q. 45th Street flea market? 22 A. Yes. 23 Q. And where is the 45th Street flea market? 24 A. On 45th Street 25 Q. . I gathered that, but where? Is it toward is whose child? (561) 832-7500 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-7724662) Electronically signed by Pamela Sullivan (501-333-772-1542) f7eae621-3493-40cd-8666.00e698ca2735 EFTA00750715 Page 34 1 'Dail? Is it toward the dump? Is it toward 2 45th Street toward — toward — toward the east? 3 A. Um, it's it's west of the hospital. 4 Q. Pardon? 5 A. West of the hospital, St. Mary's, that is 6 also on 45th Street. 7 Q. All right. Do you know where s? 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. A. Q. A. Q. A. Q. A. A. Not exactly. Do you know what s? Yes, 'do. sin an a t s I I Okay. Are you aware it's a gentlemen's club? Excuse me? Are you aware it's a gentlemen's club? No. I -- Adult entertainment? Yes. Q. Okay. So in addition to being it's also -- it has adult entertainment, with — with women who take off their clothes, strippers; true? A. What does that have to do with anything? Q. Can you answer my question, yes or no? A. I, I would guess that that is true, yes. Q. Okay. Well, you're familiar with gentlemen's 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 36 east of the hospital? A. West. Q. West of the hospital. And it's actually on 45th Street? A. Yes. Q. Okay. Is do you know where the Oalcv/ood Center is, what used to be the 45th Street Community Mental Health Center? A. No. Q. Okay. Do you know where Australian Avenue is on 45th Street? A. Yes. Q. Okay. So the flea market would be between Congress and Australian? A. I think it might be before that. I'm not — I haven't been there in a long time. Q. Okay. When you had the tattoos put on, the three tattoos, two around your ankle and one on your right, upper arm, were they all put on at the same time? A. No. Q. Did they have you fill out a form each time? A. I don't remember. Q. Okay. Over what period of time did you have the three tattoos put on? A. In between 18 and 19. Page 35 1 clubs; true? 2 A. Yes. 3 Q. Adult entertainmeM? 4 A. Yes. 5 Q. Becaur you've worked at them; true? 6 A. Yes. 7 a so when you said was aMI a you also ;mew at the time you answered that 9 question that it had adult entertainment; that is, it 10 was a strip club, as well; true? 11. A. I have never been to before, so, no, 12 I wouldn't know that. speak, that Q. But you know that from general — fro. 14 having been in the buness, so to speak, 13 15 as well, in addition to serving food, as well, is a 16 strip club; true? 17 A. How would I know that? 18 Q MI right. You can tell me you don't know 19 that. I'm okay with that answer, too. I just want the 20 gentlemen — the ladies and gentlemen of the jury to 21 understand that you — that today is the first time that 22 you learned that actually had adult 23 entertainment is that correct? 24 A. Yes. 2 5 Q. All right. 45th Street flea market, so it's 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 37 Q. Do you have any other tattoos, other than the tine? A. No. Q. Were you required to show a form of ID? A. Yes. Q. All right. Did you show them your driver's license? A. No. Q. What did you show them? A. My ID card. Q. And when you say your ID card, what's an ID card? A. It's a card with your picture on it and your O917IC. Q. All right. And what's it — and where did you get your ID card? A. At the MEV. Q. All right So do you have a driver's license? A. No. Q. All right. Have you ever had a driven license? A. No. Q. How long have you had a D -- an ID card? A. Since I was 17. (561) 832-7500 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772.1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 17eae821.3493-40cd-8666-00e898ca2735 EFTA00750716 Page 38 1 Q. Do you have the same card now? .2 A. Yes. 3 Q. Do you have it with you today? 4 A. Yes. 5 Q. Could I see it so we can mark it as an 6 exhibit, make a copy and mark it as an exhibit? 7 MR. CRITTON: Go ahead. 8 THE WITNESS: (Handing to Mr. Edwards.) 9 BY MR. CRITTON: 10 Q. What you've handed me and what we'll mark as 11 Exhibit 1, is that a true and accurate well, is that 12 the only ID card you've ever had? 13 A. Yes. 14 MR. GOLDBER.Glift It's a duplicate. 15 THE WITNESS: Yes, it's a duplicate. 16 BY MR. CRTITON: 17 Q. Okay. And why is it a duplicate? So do you 18 have another card, as well? 19 A. No, I lost it 20 Q. And this obviously doesn't have your current 21 address on it, because that's the address that you won't 22 disclose; correct? 23 A. Yes. 24 Q. All right. And the 25 address is not your current address; correct? 1 2 3 4 5 6 7 B 10 11 12 13' 14 15 16 17 18 19 20 21 22 23 24 25 Page 40 Where - what adult entertainment establishments have you worked at? A. Q. Pm s o A. Q. Where? A. Q. A. Q. Ali ri t. Where else? Where is that located? A. West Palm Beach. Q. What's the address forailli? A. I don't know. Do you know what street ifs on? A. It's on Q. •MAnd A. 'think Q. During what time 'dad well, let me ask you this: With , were you required to show the individuals who hired you that you had an adult entertainment card? A. No. Q. Wasn't an adult entertainment card required at that time? where is that located in Page 39 1. MR. EDWARDS: Objection. She's not going to 2 answer the question. 3 MR. CRITTON: Well — well, we'll get a copy. a If you will just leave that out, Ms. Jane Doe, 5 we're going to make a copy of that, and then well 6 attach that to the to the deposition. 7 (Whereupon, Mr. Garcia left the proceedings.) 8 BY MR. CRJTTON: 9 Q. Ms. Jane Doe, how many fake ID's have you 10 had? 11 A. Zero. 12 Q. It's your testimony that you've never had a 13 fake ID? 14 A. Yes. 15 Q. Okay. So if there will be witnesses in this 16 case that will testify that you had a fake ID, they 17 would be lying; is that true? 18 A. Absolutely. 19 Q. Have you ever had an adult entertainment 20 card? 21 A. No. 22 Q But you worked at adult entertainment en , 24 A. Yes. 25 Q. Did — did — well, let me ask you this: 1 2 3 4 5 6 7 8 11 12 13 14 15 16 17 18 19 20 21 22 24 25 Page 4 A. Excuse me? Q. Was there a requirement within the County that you have an adult entertainment card at the time you worked at A. I don't know. Q. How about-, did they ever require WO adult entertainment card? A. No. I only showed ID. Q. And Mats the same ID that you have with you today that, I assume, is the duplicate, except you have the original? A. Yes. Q. Okay. And when did you get your duplicate? A. I'm not sure. Q. All right. Was it within the last six months, within the last year? A. I'm not — I'm not sure where — when I got it Q. I want to go back to a question I asked you earlier. I asked you whether you had any conversations — well, let me strike that. Now. I asked you when you retained the ormr. didn't know. All you know, it was sometime before the lawsuit was filed in August, on or about August 13th of (561) 832-7500 11 (Pages 38 to 41) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) fleac621-3403-40cd-8666-000698ca2738 EFTA00750717 Page 42 1 2008; correct? 2 A. Yes. 3 Q. Okay. How many months prior to the filing of 4 the lawsuit had you hired Mr. Edwards? S A. I don't !mow. 6 Q. A month? A week? 7 MR. EDWARDS: Objection. Asked and answered. 8 BY MR. CRITTON: 9 Q. Two months? Your best estimate. 10 MR. EDWARDS: Object to the form. 11 THE WITNESS: I don't know. 12 BY MR. CRITTON: 13 Q. Did you hire Mr. Edwards in 2007? 14 A. I don't bow what year it was. 15 Q. Do you know if it was in 2006 that you hired 16 Mr. Edwards? 17 A. I don't know. 18 Q. Okay. So you don't know whether you hired 19 Mr. Edwards in 2006, 2007 or 2008; is that your 20 testimony? 21 A. Yes. 22 Q. At the time that you hired Mr. Edwards, was 23 he representing either III or IIN? 24 A. I don't —1 don't know. 25 Q. How did you get to Mr. Edwards? Page 44 1 A. 2 Q. So people -- you say there were people that 3 were going to those houses? 4 A. People who worked for the FBI. 5 Q All right So the FBI was corning to your 6 mother's house, your sister's house and your 7 grandmother's house; did you say? 8 A. Yes. 9 Q. And how did you learn that fact? Fran them? 10 A. They left cards. They spoke to my family 11 members who told me about it. 12 Q. Okay. Anyone else? That is, other than your 13 grandmother, your mother, -; and your 14 sister, did the FBI talk to anyone else — 15 MR. EDWARDS: Object to the form. 16 BY MR. CRITTON: 17 Q. — that you're aware ot about -- about you? 18 A. I don't know. 19 Q. All you remember is that Ma NB and 20 your grandmother told you that the FBI had come to their 21 house, asking questions about you — 22 A. Yes. 23 Q. and had left their card? 24 A. Yes. 25 Q. Who were the people from the FBI; do you Page 43 1 A. I, I got his card somehow. I guess he had 2 spoken to somebody else and gave them his card, and they 3 gave it to me. 4 Q. Okay. Who was the person who gave you 5 Mr. Edwards' card? 6 A. I don't remember. 7 Q. 'Ibis is the person who gave you a card for a 8 lawyer, now your lawyer, Mr. Edwards, and you don't 9 remember or have any idea who that person was; is that 10 correct? 11 A. Yes. 12 Q. All right. And you don't remember whether 13 that was in 2006, 2007 or 2008; correct? 14 A. Yes. 15 Q. Do you remember whether it was a man or a 16 woman, male or female that gave you the card? 17 A. No, I don't remember who it was. 18 Q. Do you remember how they happened to give you 19 the card; that is, what was the event or circumstance 20 that caused them to give you the card? 21 A. Um, there were, I guess, people who worked 22 for the FBI who were going to my house and my mother's 23 house and my sister's house, trying to find me, to speak 24 tome. 25 Q. Which sister? 1 2 3 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 45 know — that were leaving cards? A. One of their names was Jason. Q. And — A. There was a woman, but I don't remember her name. A. Q- A. A. A. wallet? A. Yes. Q. Did you — do you remember the timeframe that the FBI was coming, hying to contact you, that is going to your family members' houses to contact you? A. I was pregnant. Q. All right. And you have a daughter? A. Yes. Q. And what's her name? Were those cards given to you by — Yes. — by any of your family members? Yes. Do you still have them today? No. What did you do with them? I don't know. How do you know you don't have them, then? Because I use my wallet often. All right. And the cards were in your (561) 832-7500 PROSE COURT REPORTING g ya..{.,..,.:¢1 ‘,....,,,Q•YISI.Com.1 am...... ..,••••3O24.41 : 12 (Pages 42 to 45 AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (5a1-333.772.1552) Electronically signed by Pamela Sullivan (501-333-772-1552) thae621-3493-40cd-8666-00e698ca273S EFTA00750718 8 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 46 1 2 3 4 5 6 Q. Bow pregnant were you with the time 7 that the -- you were hearing from your family members 8 that Jason and some other female FBI agent were 9 interested in speaking with you? 10 A. I heard that they had been there months 11 before when I was not pregnant. And when I had actually 12 spoken to them, I was three or four months pregnant -- 13 three and a half months pregnant. 14 Q. You're sure of that? 15 A. Yes. 16 Q Okay. And how are you sure you were only 17 three and a half months pregnant? 18 A. Because I went to a doctor. 19 Q. All right. Okay. When when do you 20 believe your -- that — that you first became pregnant? 21 Just give me a time that you believe that conception 22 occurred, I guess, is probably the best way to describe 23 it 24 A. I don't !mow. 25 Q. All right. Do you know the date that you Page 48 1 A. Yes. 2 Q. An individual who identified herself as an 3 FBI, at least on her card? 4 A. Yes. 5 Q. All right. Did you ever return any of the 6 phone calls to these individuals? 7 A. Yes, I did. 8 Q. At what point in time did you contact them? 9 And just give me that -- well, I think you said — well, 10 let me strike that 11 You said you met with them three and a 12 half you were approximately three and a half months 13 pregnant at the time; correct? 14 A. Yes. 15 Q. Okay. And you're sure of that? 16 A. Yes. 17 Q. AU right. And who did you call; which FBI 18 person did you call? 19 A. I don't remember. 20 Q. Okay. And why did you call the FBI person? 21 A. I don't know. 22 Q. At time that the FBI contacted you, had you 23 heard anything about anyone contemplating a lawsuit for 24 money damages against Mr. Epstein? 25 A. No. Page 47 1 met, actually met with FBI individuals? 2 A. I do not know the exact date. 3 Q. Did you meet with the FBI individuals on more 4 than one occasion? 5 A. No. 6 Q. Let me just go back. So you heard from 7 family members that the FBI — certain individuals from the FBI, one person being Jason someone, because you had a cant at one point in time, wanted to speak with you, and that was approximately four or five months before they ultimately spoke with you? MR. EDWARDS: Form. THE WITNESS: Yes. BY Fat CRITTON: Q. All right. Did — did your — who -- who gave you the FBI cards? A. and my my mother and my sister. Q. fn iala A. A. A. my mother and my sister. Were all the cards from the same people? No. There were different cards? One was from a woman. But an FBI person? 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 49 Q. Okay. At the time that you contacted the FBI, based on the cards that were given to you, had you spoken with anyone about what you allege occurred at Mr. Epstein's home -- with anyone, anyone from law enforcement? A. No. Q. Had you ever been contacted by the — by the Palm Beach County State Attorney's office? A. I don't /mow. Q. Have you ever spoken with anyone from the Palm Beach County — Palm Beach County State Attorneys office? A. I don't know. Q. Okay. Well, when I say, spoken with them about, obviously about your -- similar to the allegations that you've made in your complaint directed to Mr. Epstein. So what I meant, saying, have you spoken with anybody at the State Attorney's office or anyplace else, I'm interested as to the allegations that you've raised in this complaint do you understand that? A. Yes, I understand that Q. Have you ever spoken with anyone who represented themselves to be a State Attorney with the Palm Beach County State Attorney's office about Mr. Epstein? (561) P32-7500 PROSE COURT REPORTIN • 13 (Pages 46 to 49) G AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1562) Electronically signed by Pamela Sullivan (601-333-772-1662) freae621-3493-40ed-B666-00e698ca2735 EFTA00750719 Page 50 1 A. Not that I know of. 2 g Well, you'd know if you spoke with someone — 3 MR. EDWARDS: Object to the form. 4 BY MR. CRITTON: 5 Q. -- from the State Attorney's office; wouldn't 6 you? 7 A. Excuse me? 8 Q. I said, you would !mow if someone said, Pro 9 from — Pm Sam Smith from the State -- Palm Beach 10 County State Attorney's office, I want to talk to you. 11 You would remember that; wouldn't you? 12 MR. EDWARDS: Form. 13 THE WITNESS: There were a lot of people that 14 came to my house, wanting to talk to me. 15 BY MR. CRITTON: 16 Q. You need to answer my question. Okay? Would 17 you Re it read beck to you? 18 A. I don't remember. 19 Q. Have you ever spoken at any time in your life 20 about anything with a State -- the State Attorney or an 21 Assistant State Attorney from Palm Beach County about 22 anything? 23 A. I don't know. 24 Q. Okay. Well, you've been in trouble with the 25 law before; correct? Page 52 1 be from the office of the United States Attorney? 2 A. No. 'don't — !don't remember if I did or 3 not. 4 Q So the, the individuals, at least 5 governmental, • or state or local 6 officials, that you've ever discussed any of the 7 allegations that you've alleged in your complaint 8 against Mr. Fprin would have been with the FBI 9 MR. EDWARDS: Object to the form. 10 BY MR. CRITTON: 11 Q — is that correct? 12 MR. EDWARDS: Fonn. 13 THE WITNESS: Yes. 14 BY MR.. CRITTON: 15 Q. Is that correct? I'm sorry. 16 A. Yes. 17 Q. Asa result of the cards that you received, 18 did you contact one of those individuals? That is, your 19 family gave you cards for the FBI; then you contacted 20 them? 21 A. Yes. 22 Q. Okay. Had your mother, your sister or your 23 grandmother told the FBI where you could be found? 24 A. I don't know. 25 Q. Where were you living at the tine? Page 51 1 A. Yes. 2 Q. Okay. And have you had to deal with State 3 Attorneys under those circumstances? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't know. 6 BY MR. CR1TTON: 7 Q. The State Attorneys, though, you — you 8 understand those are the ones that prosecute you — 9 would have prosecuted you; true? 10 A. Yes. 11 Q. All right. Okay. Have you — and it's your 12 testimony you can't remember -- it's — you have no 13 recollection of having spoken with anyone from the Palm 14 Beach County State Attorney's office? 15 A. No, I do not 16 Q. That's correct. 17 All right. Did you ever speak with anyone 18 from the Palm Beach Police Department regarding any of 19 your allegations that are set forth in your complaint 20 directed to Mr. Epstein? 21 A. No. 22 Q. Did you ever speak with a United States -- 23 well, let me strike that. 24 Did you ever speak with an assistant attorney 25 or an attorney from -- who represented him or herself to Page 53 1 A. With a friend. 2 Q. Who? 3 4 Q. Olcayhiou were living with. at the time. 5 Where does= reside — or where was she living at 6 that time? 7 A. 8 Q. Address, please? 9 A. I don't know the address. 10 Q. What street? 11 A. I don't know the name of the street. 12 Q. HoW did you know how to get there? 13 A. I knew what the neighborhood looked like. 14 Q. Okay. You don't drive a car? 15 A. No. 16 Q. Okay. Have you ever had a car, owned a car? 17 A. No. 18 Q. Have you ever driven a car? 19 A. Yes. 20 Q All right. So you have driven a car, but you 21 haven't had a license? 22 A. Yes. 23 Q. All right. Do you still drive a car, say 24 over the past year, without a license? 25 A. No. b6 ...Y0J•Wawn w.wwW•sa.C.••• •••••••10. .1A4 (561) 832-7500 14 (Pages 50 to 53) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (601.333-772-1552) 17eae621-3493.40cd-8668-00e698ca2736 EFTA00750720 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 54 1 Q. How would you get around when you were living 2 with MI? 3 A. She would take me. 4 How long -- how long had you been living with 5 — well, let me strike that. 6 On how many occasions have you lived with A. Two. Q. During what time -- you and have been childhood friends? A. No. Q. When did you meet s? A. I believe I was 13 when I met her. Q. Do you bow what l's date of birth is? A. No, I do not. Q Do you know what month she is born in, or day? A. rm not positive, no. Q. Okay. You and are still best friends; aren't you? t EDWARDS: Object to the form. THE WITNESS: No, I have nth spoken to MB BY MR. CRJTI'ON: Q. Okay. Were you best friends at the time you were living with het? Page 56 1 Q. A few months? 2 A. Yes. 3 Q. What does a few months mean you to? Tine or 4 four, five, Ethic? S A. About three. 6 Q. Did you — and was she -. was she living at 7 the same place in =En 8 A. No. 9 Q. Where was she living at that time? 10 A. She was living in — I don't remember the 11 name of the apartments that she lived in. It was in 12 West Palm Beach, though. 13 Q. Was she living with anyone, other than — was 14 she living with anyone at the time? 15 A. Her boyfriend. 16 Q. And his name was? 17 A. lb not — I — I don't 'mow who. 18 Q. I'm sorry? 19 A. I'm not sure who he was. 20 Q. Did she have more than one boyfriend living 21 with her during the time, those few months that you " el 22 living with her, when you had just turned 18? 23 A. No, it was none of my business. 24 Q. That's not my question. 1 assume that you, 25 when you were living there, you were literally living Page 55 MR. EDWARDS: Object to the form. 2 TIE WITNESS: No. 3 BY MR. CRTITON: 4 Q. Was M. charging you rent? 5 A. No. 6 Q. So you've knownIE. since 13. During what 7 time periods have you lived with her? 8 A. Excuse me? 9 Q. You said you had lived with her on two 10 separate occasions. 11 A. Yes. 12 Q What are those two occasions? Give me the 13 approximate timeframes. 14 A. The first time, Thad just turned 18 and -- 15 Q. You say the first time, or... 16 A. 1 just turned 18, yes. 17 Q. Did you say the first time? I'm sorry. 1 18 was thinking about something else. 19 A. Yes. 20 Q. Okay. You had just turned 18, so that would 21 have put — 18, that would have put you approximately 22. June or July of 2006; right? 23 A. Yes. 24 Q. And how long did you live with? 25 A. A few months. 1. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 Page 57 there for those few months; correct? MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. You were staying there, sleeping overnight? A. Yes. Q. Okay. So if she had more than one boyfriend, you would know; wouldn't you? I mean, you -- I assume you, if you would see a — A. No, I wouldn't know. Q. — a male in the house, you'd go, hi, I'm Jane Doe? A. No. Q. So you would just, if you would see someone, you would turn your head and walk back into your room? A. I mostly was in my own room. Q. Okay. Were you working at that time? A. I did. Where? Q. Were you also working at -- A. No. at that time or (561) 832-7500 .6...Isam2--c`iwoflin .•axoe.C(.4•w5 ... , ..txxl .‘•• AY' 15 (Pages 54 to 57) PROSE COURT REPORTING AGENCY, .INC. (561) 832-750.6 Electronically signed by Pamela Sullivan (S01-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) freae82144113-40cii48684:104498ca2736 EFTA00750721 Page 60 Page 58 1 A. No. 2 Q. . At any time during the time u were 3 r ., were you working at or 4 -- the first time? 5 A. Not the first time. 6 Okay. Had you — when you were working at 7 =, had you — well, let me strike that. 8 Whennu worked at 1-- how long did you 9 worked atMl? 10 A. About two months. 11 Q. Had you worked at either of the strip clubs 12 before you wonted at-? 13 A. No. 14 Q. Okay. You worked at the strip clubs after 15 you worked atilt? 16 A. Yes. 17 . Oka . Had you — when you started working. 18 was the first one? 19 A. Yes. 20 Q. Okay. How -- how many months did you work 21. there? 22 A. I don't Irnow. 23 Q. Well, did you work a day? Did you work a 24 month? Did you work a year? 25 A. Probably like eight months. 1 Q. Why? That is — well, let me strike that. 2 Where 3 MR. EDWARDS: Object to the form. 4 BY MR. CRITFON: 5 Q. Where did get -- how did you -- other 6 than working at=, how did you support yourself in 7 terms of food, entertainment, recreation, things of that 8 nature? 9 A. 10 Q. Did she give you money? 11 A. Yes. 12 Q. Does she still give you money? 13 A. No. 14 et All right. After the first time you lived 15 with., you were -- you had just tuned 18. You were 16 there a few months. Then when were you -- when did you 17 next live with..? 18 A. Must have been a year later. 19 Q. Sometime in 2007? 20 A. Yes. 21 Q. Okay. And how lot did you live — and this 22 was now at the address, correct? 23 A. Yes. 24 Q. Bylite way, when you were at the 25 what wasM.'s boyfriend's name? 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q point? A_ A A. Q Page 59 Were you still working at the at that No. Did you have any other jobs? No. Just working strictly at Yes. -- for approximately eight months? Yes. Q. When's the second time -- and during the time that you worked with.., did you work anyplace else, other than..? I'm sorry; that may not have been clear. During the first time that you lived with at her house — or was it an apartment and not a home? A. Apartment. Q. — apartment in West Palm Beach, did you work anyplace else, other than ? A. No. Q. So there must have been a time that you were living with. that you also were unemployed? A. Yes. Q. Did she make you pay any rent? A. No. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 61 MR. EDWARDS: Objection. Asked and answered. BY MR. CR1TTON: Q. Well, you said she had one boyfriend. Who was that? MR. EDWARDS: Answer, if you know. MR. CRITTON: Is that a form objection? MR. EDWARDS: If you know. MR. CRITTON: Don't — don't key her, so she can sty, I don't know. Just it's a form; is that right? MR. EDWARDS: Yeah, It's a form objection. MIt CRITTON: All right. MR. EDWARDS: We've gone through this again and again, so... THE WITNESS: Jessie. BY MR. DUTTON: Q. Jessie. So you do know his name. What's his last name? A. I don't know his last name. M. . Was he the only boyfriend that you saw at 's house during the time — I'm sorry — apartment during the time, those few months you lived there? A. Yes. Q. And did he live there with her? A. I guess so. 1,... aaPerye.m.0.62•• •••Nlbaarazeo.•1••...wn4.4 •Paired. (561) 832-7500 16 (Pages 58 to 61) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (SO1-333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1552) fleao621-3493.40cd-8666.00a698ca2735 EFTA00750722 Page 62 1 Q. Did you continue to see him afterwards? By 2 see, see him, I don't mean see him in a relationship. 3 A. Yes, I did. 4 Q. Okay. Does... still see Jessie? A. No. 6 Q. By the way, let me make a couple of things 7 clear. I get to ask you a bunch of questions. I 8 think — Pm confident Mr. Edwards, being the lawyer he 9 is, has told you about this procedure. So you have an 10 idea that I get to ask you questions, and you get to 11 give me answers. And same with the other lawyers that 12 are here; true? You understand that? 13 A. Yes. 14 Q. All right. If you don't tmderstand a 15 question, I'll be happy to rephrase it or to repeat it; 16 do you understand that? 17 A. Yes. 18 Q. Okay. And if you answer a question, I'm 19 going to assume that you understood it and answered it 20 truthfully. That's fair; isn't it? 21 A. Yes. 22 Q. Okay. If you don't know an answer to a 23 question, you can tell me you don't know, or you -- or 24 you can — well, let me strike that 25 If you don't know an answer, you can tell me Page 64 1 with your grandmother; correct? 2 A. Yes. 3 Q. And during the time that you were there — 4 well, let me strike that. 5 Had you been living with your grandmother 6 before the first time you went to stay with..? 7 A. Yes. 8 Q. Okay. Had there been some event in 2006 that 9 had caused u to leave grandma's --Indmother's 10 house, house, and go to... 1s, that is a 11 fight, a battle, something that made you unhappy, so off 12 you went? 13 A. Yes. 14 Q. What? What had occurred in 2006 that caused 15 you to go It's? 16 A. I broke up with my boyfriend. 17 Q. And his natne was — 18 A. 19 Q. 20 A. 21 Q. I'm s 22 A. 23 Q. 24 A. Yes. 25 Q. Is Ma the father of your child? what? Page 63 that. You understand that, as well? 2 A. Yeah. 3 Q. All right. So you don't need Mr. Edwards to 4 say if you know or you don't know. If you don't know 5 something, you're going to tell me you don't know 6 something; fair? 7 A. Yeah. 8 Q. Okay. Second time you lived withM. how 9 long? 10 A. A month. 11 Q. And where had you been living before this one 12 month that went to live with It 13 A. 14 Q. And why did you leave? 15 A. I doirt blow. 16 4 Hew long had you beatifying at your 17 grandmother's house -- house on Edge Hill Road in 18 West Palm Beach before you went tont% for the second 19 time? 20 A. I lived there since I moved out °M.'s the 21 first time. 22 Q. All right So sometime in the latter part of 23 2006ar moved back ton's - I'm sorry -- you moved 24 from M.'s apartment in West Palm Beach, so the latter 25 part of 2006 to sometime In 2007, you were living back 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 65 A. No. Q. Is — have you seen him since you stopped dating him in 2006? A. No. Q. Does he still live in West Palm Beach; do you know? A. No. Q. Do you know where he is -- where he lives or resides now? A. I have been told that he lives in A. Q. Q. A. A Is he in school there? No. What does he do? I don't know. Do you know what his middle name is? No. Do you know what his date of birth is? No. Q. Well, you may not ;mow the year he — well, let me strike that How long did you date this -- how long did you date..? A From the time I was 16. Q. Until you were just a little over 18; (561) 832-7500 17 (Pages 62 to 65) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1662) Electronically signed by Pamela Sullivan (501-333-772-1652) 17eao621-3493-40cd•8666-00e698ca2735 EFTA00750723 Page 66 1 cared? 2 A. Yes. 3 Q. A little over two years? 4 A. Yes. 5 Q. Okay. And you're telling the members of the 6 jury you don't remember his birth date? 7 MR. EDWARDS: Object to the form. 8 BY MR CRITTON: 9 Q. Not the year, but you don't even remember the 10 month or the day; is that correct? 11 MR EDWARDS: Form. 12 TI-IE WITNESS: 1 haven't seen him in years. 13 BY MR. CRITTON: 14 Q. That's not my question. 'just want the 15 members of the jury to understand that you don't 16 remember the person who you dated for over two years, 17 their birth date; is that correct? 18 MR. EDWARDS: (Meet to the form. 19 THE WITNESS: That's correct. 20 BY MR. CRITTON: 21 Q. When you stayed with were working at 22 MP, then you go back to house, your 23 grandmother; correct -- 24 A. Yes. 25 Q. -- sometime in 2006? Page 68 1 Q. At the time in 2007, I think you said 2 earlier, when your family members told you the FBI was 3 looking for you or looking to talk with you, you were 4 living with II; correct? 5 A. Yes. 6 Q. All right. And this was in 2007, and you 7 were not pregnant at that time, so would it be a correct 8 statement you didn't call the FBI back in 2007; you 9 called them back sometime in 2008? 10 MR. EDWARDS: Object to the forth. 11 THE WITNESS: That's possible. 12 BY MR. CRITTON: 13 Q. Why didn't you contact — when you heard the 14 FBI was looking for you, why didn't you call them back? 15 A. Because I didn't want to talk to them. 16 Q. Why not? 17 A. I don't know. 18 Q. At that point in time, did you tell is -. 19 that is, when you were with MB, did you tell her that 20 the FBI was looking for you, or wanted to talk with you? 21 A. No. 22 Q. So as you're living with MI, you knew 23 that — well, let me strike that 24 You had been to Mr. Epstein's house a number 25 of times; true? I Page 67 1 A. Yes. 2 Q. And you stayed there for a number of months 3 into 2007; correct? 4 A. Yee. 5 Q. And then — and then for some reason you left 6 and went back to s house, this time — or back with 7 a in true? 8 A. Yes. 9 Q. Okay. And what occurred at grandma's 10 house -- at your grandmother's house, that caused you to 11 leave and go back to., what event at that time? 12 A. Nothing. 13 Q. You just decided to pick up and leave? 14 A. Yet 15 Q. And you stayed with M. for a month? 16 A. Yes. 17 Q. What time period was that? Give me a 18 approximate date. 19 A. I don't know. 20 Q. Wash early? Were you pregnant at the time? 21 A. No. 22 Q. Which kind of takes me back to the question: 23 When you were with Ms. either in 2006 or 2007, had 24 the FBI contacted her? 25 A. Not that I know of. Page 69 1 A. Yes. 2 Q. Prior to 2006? 3 A. Yes. Q. You knew that had been to Mr. Epstein's 5 home, as well? 6 A. Yes. 7 Q. Did III ever tell you that -- that the FBI 8 VMS baking to talk with her or to speak with her? 9 A. She probably did. 10 Q. And, to your knowledge, did she ever talk 11 with the FBI? 12 A. No. 13 Q. You — well, that's a ■ question. 14 Did she ever talk -- did she tell you she 15 talked with the FBI? 16 A. She did not tell me that she did. 17 Q. Okay. Did she tell you she did not talk with 18 the FBI, or was not going to talk to the FBI? 19 A. No. 20 Q. What did she tell you, if anything? 21 A. She didn't really say anything. 22 Q. So at the time that your family members are 23 telling you she's going to talk -- the FBI is looking to 24 talk with you, you had — this was the second time now 25 you're living with Ww illich you said would have been (561) 832-7500 PROSE COURT REPORTING 18 (Pages 66 to 69) AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-7724652) Electronically signed by Pamela Sullivan (501.333-772.1552) fleae621 -3193-40cd-8566-000698ca2735 EFTA00750724 Page 70 1 sometime in 2007 because you weren't pregnant, and you 2 didn't want to talk to them; correct? 3 A. Yes. 4 Q. All Sit. And it's your testimony you 5 didn't tell I. that the FBI was looking to talk to 6 you; correct? 7 A. Yes, not at that time I didn't. 8 Q. At the time — at the time that the FBI was 9 trying to talk with you in 2007, did you have a lawyer 10 at that time? Did you talk to a buyer about anything. 11 I mean, other than related to any criminal or arrest 12 issue that you had? 13 MR. EDWARDS: Object to the form. 14 THE WITNESS: The first time I spoke to the 15 FBI I did not have a lawyer. 16 BY MR. CRITTON: 17 Q. All right And with — I think you told me 18 earlier that your best recollection is sometime in 2008 19 you spoke with them!- 20 MR. EDWARDS: Object to the form. 21 BY MR. CRFITON: 22 Q. — correct? 23 A. I was three and a half months pregnant 24 Q. Okay. And what -- what makes you know that 25 you were three and a half months pregnant? Page 72 1 cared? 2 A. Yes. 3 Q. When you spoke with the FBI -- and you told 4 us you didn't have a lawyer at that time — was it — 5 did the FBI tell you or give you the card, Mr. Edwards' 6 card, and say, this is someone whom you should contact? 7 A. No. 8 Q. Was it before or after you talked to the FBI 9 that someone gave you Mr. Edwards' card? 10 A. After. 11 Q. And do you remember where you were when 12 Mr. Edwards' card was given to you? 13 A. No. 14 Q. Do you remember how long after you spoke with 15 the FBI you received Mr. Edwards' card? 16 A. Not long. 17 Q. Within a week or so? Two weeks? 18 A. Maybe a month or two. 19 Q. If the person that — what occurred that 20 someone would give you a lawyer's card? Does that make 21 sense to you? That is, let's say you're working at 22 In and someone goes, here, I want to give you 23 Mr. Edwards' card. Did that - 24 A. Well, obviously — 25 Q. Okay. There has to be some reason why Page 71 A. Because I went to a doctor. 2 Q. No, I understand that. But did you go talk 3 to the FBI the same day that you talked to the FBI? 4 MR. EDWARDS: Object to the form, if that's a 5 question. Did you talk to the FBI the same day you 6 talked to the FBI; that's the question? 7 MR. CRTITON: Oh, Fm song. That may have 8 been the question. That was not the intended 9 question. 10 MR. EDWARDS: I can answer that for you. 11 It's yes. 12 BY MR. CRTITON: 13 Q. The day that you spoke, you're — you're 14 convinced that you were three and a half months pregnant 15 at the time. So had you been to a doctor that said 16 you — you know, l— by our calculations, you're three 17 and a half months pregnant, and then you remember that 18 because that ties in with you saw the FBI within a few 19 days? 20 A. Yes. 21 Q. All right. Who was your doctor, your -- your 22 DB/CNN doctor? 23 A. 24 Q And you're almady — we've already 25 established that you only talked with the FBI once; 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 73 someone would give you a lawyer's card. So my question to you is: Where are you — where were you — what's your recollection as to why -- how you came to be in possession of Mr. Edwards' card? A. Well, it must have been somebody who the FBI spoke to and who had his card. Q. So it must — another female? MR. EDWARDS: Object to the form. THE WITNESS: I'm not -- I don't remember who it was who gave me the card. BY MR. CRITTON: Q. Well, how — how would a lawyer's card end up in your hand? In this instance, it was Mister — happened to be Mr. Edwards' card. What — you had to have said something to someone who would have said, you need a lawyer, here's a lawyer's card. And that's what I'm trying to find out. What — what occurred that n. someone gave you d? Were you talking to liM.? Were you talking to A. I donli310W. • Q. An right. So you're telling the gentlemen -- ladies and gentlemen of the Jury you have no recollection of how you got Mr. Edwards' card? MR. EDWARD& Object to the form. (561) 832-7500 19 (Pages 70 to 73) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) fleao621-3493-40cd-8666-00e698ca2735 EFTA00750725 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 74 BY MR. CRITTON: Q. Just that it was sometime after you spoke with the FBI? A. Yes. Q. Okay. And it's your testimony that that the F — that none of the FBI individuals or the people who interviewed you gave you Mr. Edwards' card; is that your testimony here under oath? A. Yes. Q. Did someone call you and refer you to Mr. Edwards, say, I'm going to send you a card, this is a lawyer you need to see? A. No. I don't remember who it was who gave me the card. Q. When you met with the FBI, who was it? MR. EDWARDS: Object to the form. Asked and answered. BY MR. CRITTON: Q. A. Q. A. A. Q. That is a man and a woman? Yes. Okay. Was Jason one of those people? Yes. And you don't recall the woman's name? No. Describe Jason for me. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 76 coming? A. Yes. Q. Okay. Who — who else was living with Ms. Brewer, in addition to yourself, at that time? A. I'm not sure. Q. Okay. Well, was the father of your child — A. Yes. Q. — excuse me -- living there at the time? A. Yes. Q. Okay. So — and he's someone that, until I asked whether he was there, you didn't recall whether he was living there? A. He was living there, but I don't think he was there. . All right. I'm just asking who was living at home at the time that the FBI came. And when I say, who was living in the house, not necessarily they were there when the FBI interviewed you, but who was living at the house. There was Ms. Brewer, your — the father of the child Era A. Yes. Q. Okay. And the father obviously has a name. What's his name? A. Q• Page 75 1 A. He WAS a tall, bald man. 2 Q. Approximate age, best estimate? 3 A. Its thirties. 4 (Discussion held off the record.) 5 BY MR. CRITTON: 6 Q. All right. The woman, describe her for me. 7 A. She was blond. 8 Q. Tall? Short? Medium? 9 A. I believe she was taller than I am. 10 ' Q. Approximate age? 11. A. She was probably in her thirties, also. :2 Q. Where did you meet them? Did you come to 13 them, or did they come to you? 14 A. They came to me. 15 Q. And where did they come where were you 16 living at that time that they came to interview you? 17 Were you still at M.'s? 18 A_ No. 19 . Now you were back at grandma at 20 home? 21 A. Yes. 22 Q. Was anyone else present when they interviewed 23 you? 24 A. No. 25 Q. Did your grandmother know that they were (561) 832-7500 PROSE COURT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 77 Q. You're currently living him -- with him and your child at the address that your attorney has instructed you not to provide me; correct? A. Yes. Q. And nobody else lives at that address with you; is that correct? MR. EDWARDS: Object to the form. Don't answer. MR CRITTON: Well — MR. EDWARDS: It's going to be identifying information about the address. BY MR. CARTON: Q. I want to know, does anyone else live with you at your current address? A. Besides who? Q. Besides the father of the 20 (Pages 74 to 77) REPORTING AGENCY, INC. (561) 832-7506 Elsetrortically signed by Pamela Sullivan (501-333-772-1552) Bactronically signed by Pamela Sullivan (501-333-772.1552) 17ene21.3493.40ed-8666.00e698ca2736 EFTA00750726 Page 78 1 ? 2 A. 3 Q. 4 MR. EDWARDS: Don't answer. 5 MR.. CRITTON: Well, just a yes or no, first. 6 How about that? 7 MR. EDWARDS: Don't answer. 8 MR. CRITTON: Okay. 9 MR. EDWARDS: Whether it's yes or no. 10 MR. CRITTON: And the basis -- the basis for 11 that, just so that the Court can -- 12 MR. EDWARDS: Is that it's going to be 13 identifying information about the address, so that 14 you can give it to your client, so that he can go 15 and harass her or do whatever he wants to or 16 whatever he's done in the past to her. And that's 17 not going to happen to her or her daughter. 18 MR. CRITTON: That's absurd. 19 MR. EDWARDS: That's it. 20 MR. CRITTON: That's absurd. 21 MR. EDWARDS: Yeah, I agree; it is absurd. 22 What's happened -- 23 MR. CRITTON: No, no. What — 24 MR EDWARI:6: — in this case is absurd — 25 MR. CRITTON: Okay. Page 80 1 a house, 2008. Is it just the three of them, 2 the two of them and you? 3 A. Yes. 4 Q. Okay. Sitting at the kitchen table. 5 A. The porch. 6 Q. How much time did you spend with them? 7 A. I don't know. 8 Q. Was it a five-minute conversation? Was it an 9 hour? Was it multiple hours? 10 A. May have been like an hour. 11 Q. Did they ask you questions? 12 A. Yes. 13 Q. Did they take mitten notes? 14 A. I do not know. 15 Q. Did they have a tape recorder? 16 A. I don't believe so. 17 Q. Okay. So you didn't — you did not give 18 anyone from the FBI authority to tape your statement; 19 correct? 20 MR. EDWARDS: Object to the form. 21 BY MR. CRITTON: 22 Q. And that is to take a tape-recorded statement 23 from you; is that correct? 24 MR. EDWARDS: Object to the form. 25 THE WITNESS: I don't remember if they did or Page 79 MR. EDWARDS: — and what's going to happen 2 in the future in this case is absurd. 3 MR. CRITTON: All I'm asking is whether 4 anyone else lives with her at that address. 5 Obviously, that person may well have information 6 regarding the alleged damage claim that your 7 client's making. 8 MR. EDWARDS: Okay. Go to the Court to get 9 information. 10 MR. CRITTON: All right. And I just want 11 you — and you're going to follow your lawyer's 12 advice? 13 MR EDWARDS: Yes. 14 Mk CRITTON: Well, no, Fm asking her. 15 MR. EDWARDS: And she is. 16 BY M:R. CRI1TON: 17 Q. You're going to foamy your lawye's advice? 18 A. Yes. 19 Q. Okay. And we have to come back here and do 20 this in multiple times, and if the Court -- you 21 understand that the Court may grant sanctions under this 22 circumstance; do you understand that? 23 A. That's fine. 24 Q. Two FBI people, they come to your house 25 sometime in 2000 — or the grandmother's house, Page 81 1 not 2 BY MR. CRITTON: 3 Q. So in less than a year ago from today, maybe 4 just a little ova a year, it's your testimony you don't 5 remember whether the FBI taped your statement or not; is 6 that correct? 7 MR EDWARDS: Form. 8 BY MR. CRITTON: 9 Q. Ifs what you're telling us? 10 MR. EDWARDS: Farm. 11 THE WITNESS: Yes. 12 BY MR. CRITTON: 13 Q. Did they have a stenographer with them, 14 similar to Pamela sitting to your immediate right? 15 A. No. 16 Q. Did they video the conference at all? 17 . A. No. 18 Q. When you called well, from the time that 19 you called oh, I'm sorry -- did you call Jason or the 20 woman to set up the appointment, or did they oontact 21 you? 22 A. I think I called them. 23 Q. And, and why did you call them? What caused 24 you to call the FBI? When they were trying to get ahold 25 of you in 2007, what caused you in late — well, (561) 832-7500 AA, 21 (Pages 78 to 81) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772-1662) Electronically signed by Pamela Sullivan (501.333.772-1552) treae621-3493-40cd41666.00e69Sca2736 EFTA00750727 Page 82 1 sometime in 2008 to call them? 2 MR. EDWARDS: Object to the form. 3 THE WITNESS: I — I was pregnant, and I was 4 thinking more clearly. And I guess I pretty much S realized that I needed to call them. 6 BY MR. CRITTON: 7 Q. Well, what — now that you were pregnant, 8 what caused well, how were you thinking more clearly 9 because you were pregnant, versus when you were not 10 pregnant? 11 A. I was not drinking or I wasn't — I — I just 12 was taking better care of myself. 13 Q. Okay. Well, before you became pregnant, you 14 also used illegal drugs; didn't you? 15 A. Yea 16 Q. So were you drinking and using illegal drugs 17 up through the time that you became pregnant? 18 A. Excuse me? 19 Q Were — did you continue to drink — and I - 20 when I say drink, you mean alcohol; don't you? 21 A. Yes. 22 Q. Okay. And I assume that when you say you 23 weren't drinking, you would drink alcohol to excess 24 prior to the time that you were pregnant with your 25 daughter; comet? Page 84 1 BY MR. CANTON: 2 Q. You used pot? How about Xanax? 3 A. From time to time. 4 Q. Ecstasy? 5 A. No. 6 Q. So it's your testimony that no one — there 7 should be no individual who could say Jane Doe took 8 Ecstasy, because that would be 9 A. I have taken it once. 10 Q — a boldfaced lie; is that right? 11 A. One time I have taken it, yes. 12 Q. Okay. So you have taken Ecstasy- 13 MR. EDWARDS: Object to the form. 14 BY MR. CRITTON: 15 Q. -- true? 16 A. One time, yes. 17 Q. You've used cocaine, as well; haven't you? 18 A. Yes, I have. 19 Q. On many occasions; true? 20 A. More than one. 21 Q. More than ton? 22 A. No. 23 Q. So if witnesses tome in and say, yep, Pve 24 seen Jane Doe use coke a lot of times, they would be 25 boldfaced liars; is that true? Page 83 MR. EDWARDS: Object to the form. 2 THE WITNESS: Yes. 3 BY MR. CRITTON: 4 Q. Okay. And you would drink to the extent that 5 you would from time to time pass out; true? 6 MR. EDWARDS: Form. 7 THE WITNESS: No. 8 BY MR. CRTITON: 9 Q. Okay. So you would drink a lot, you would 10 drink to excess, but you never passed out — 11 MR. EDWARDS: Object to the form. 12 BY MR. CRITTON: 13 Q. -- is that your testimony? 14 A. Yes. 15 Q. Okay. And prior to becoming pregnant, you 16 also used illegal drugs on a regular basis; didn't you? 17 A. Not on a regular basis. 18 Q. Okay. Well, you — you were using them at 19 least a number of days out of event month prior to the 20 time that you became pregnant fora long period of time; 21 isn't that true? 22 A. Yes. 23 Q. And what kind of drugs did you use? 24 MR. EDWARDS: Form 25 THE WITNESS: Marijuana. Page 85 1 MR. EDWARDS: Object to the form. 2 THE WITNESS: Yes. 3 BY MR. CRITTON: 4 Q. Okay. How many times do you think you wed 5 coke? Approximately ten? 6 MR. EDWARDS: Object to the form. 7 THE WITNESS: Five. 8 BY MR. CRITTON: 9 Q. Maybe more? 10 A. No. 11 Q. How about crack cocaine, do you use that? 12 A. No. 13 Q. Oxyocntin? 14 A. No. 15 Q. How about Roxycontin — 16 A. No. 17 Q. — Roxicodone? 18 A. No. 19 Q. Do you know what a rosy is? 20 A. Yes, I do. 21 Q. What is a roxy? 22 MR.. EDWARDS: Object to the form. 23 THE WITNESS: It's a pill. 24 BY /4R. CRITTON: 25 Q. Okay. And what does it do? What do you (561) 832-7500 22 (Pages 82 to 85) PROSE COURT REPORTING AGENCY, INC. (561) 8 32-7 50 6 Electronically signed by Pamela Sullivan (501.333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) fleao521-3493-40cd-8666-00e698ca2735 EFTA00750728 Page 86 Page 88 1 2 3 4 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 understand a roxy does? A. I do not ;mow. Q. Have you ever taken roxies? A. No. Q. So if someone said, 1 saw Jane Doe take roxies, I've given her roxies, that person would be lying; is that what you're saying? MR EDWARDS: Econ. THE WITNESS: Yes. BY MR. CRITTON: Q. Since the time you've had your daughter, do you continue to drink? A. I have not. I have drunken when I turned 21, and that's it. Q. How about drugs, have you continued to use drugs since you gave binh to your daughter on A. No. Q. Okay. So if someone said they'd seen you using drugs, you're saying that person would be lying? A. Absolutely. Q. Back to the FBI They came to your porch sometime in 2008, spent about an hour with you, I think you said? MR. EDWARDS: Form. 1 and meet with you at the Edge Hill — 2 A. One or two. 3 Q. — address? One or two days later? 4 A. One or two, yes. 5 Q. Did they give you any pieces of paper when 6 they met with you? 7 A. They gave me their card. 8 Q. Just their card? 9 A. Yes. 10 Q. So you had the cards that your family members 11 had given you, and you also had the cards that they gave 12 you that day? 13 A. Yes. 14 Q. And what did they tell you? That is, when 15 you called them to say, okay, I'll talk with you now, in 16 2008, did you say, what do you want to talk about? Did 17 you say, I'm Jane Doe, you've let me — been trying to 18 pat ahold of me. 19 A. Yes. 20 Q. So here I am; I'll talk to you — 21 A. Yes. 22 Q. — right? 23 A. Yes. 24 Q. And what did you say to them? Did you say, 25 what do you want to talk about? Or did you know? Page 87 1 THE WITNESS: Uh-huh. 2 BY MR. CRITTON: 3 Q. Yes? 4 A. Yes. 5 Q. And you don't remember whether they took 6 notes, you don't remember giving them permission to 7 use - to take a tape-recorded statement, and you don't 8 remember whether they took a tape-recorded statement, 9 all taste; correct? 10 A. I'm sure that they took notes, but I do not 11 remember if they recorded it. 12 Q. Did you sign any — excuse me did they 13 take any kind of statement from you in handwriting, and 14 then ask you to sign it? 15 A. I don't remember. 16 Q. Did they give you a copy of any notes or 17 statement that day? 18 A. No. 19 Q. Okay. Is that the only occasion, other 20 than — well, let me strike that 21 I think — who did you say you called to set 22 up the appointment? Was it Jason or the woman? 23 A. I think it was the woman. 24 Q. Okay. And how many days after you called 25 them and say, I'll talk to you, did they come out and - Page 89 / 1 A. I don't remember. 2 Q. Did -- well, did you know that it involved 3 Mr. Epstein? 4 A. Yes, I did. 5 Q. How did you know that? 6 A. Because I have a brain. 7 Q. All right That's good. We -- and — and 8 you — you don't have any type of mental disability; 9 correct? 10 A. Meaning? 11 Q. You don't have any mental disability; that is 12 you - you understand when people talk to you? That is 13 you've never had any kind of learning disability? 14 MR EDWARDS: Object to the form. 15 THE WITNESS: Yes. 16 BY MR. CRITTON: 17 Q. Pardon? 18 A. Yes. 19 Q. You —you say you do have a learning 20 disability? 21 A. No, I don't. 22 Q. Okay. Well, that's what Inn saying is I've 23 looked at your school records, and I've looked at 24 your — you know, the FCATS and some of those reports 25 that have been turned over to us in discovery. And it (561) 832-7500 PROSE COURT REPORTING AGENCY, 23 (Pages 86 to 89) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-7/2-1662) Bectrenkally signed by Pamela Sullivan (601.333-772.1652) from.621-3493-40a14616-00e69Ses2735 EFTA00750729 Page 90 1 appears that you have — that you've scored pretty well, 2 very well in some instances, on standardized testing; 3 correct? 4 MR. EDWARDS: Form. 5 THE WITNESS: Yes. 6 BY MR. CRITTON: 7 Q. Okay. So you said you have a brain, and — 8 and you knew that's why the FBI wanted to talk to you. 9 How did you -- how did you know that? I mean, separate 10 from just being smart, how did you know that the FBI 11 wanted to talk to you about Mr. Epstein? That is, what 12 was going on that made you know that? 13 A. Because I watch the news. 14 Q. So in 2008 you had seen something on the news 15 about Mr. Epstein? 16 A. Yes. 17 Q. Okay. What had you seen? 18 A. I -- I think it was a newspaper where I just 19 saw his face. 20 Q. And you— so you saw his bee. Did you read 21 the article? 22 A. Yes. 23 Q. Okay. You — and you — did — were you 24 reading the newspaper regularly at that time? 25 A. No. I just — the newspaper was being Page 92 1 with you? 2 A. Yes. 3 Q. And they say, okay, well be out in two days, 4 or a day or hvo? 5 A. Yes. 6 Q. Okay. What, five-minute conversation? 7 A. Probably. a Q. So they come out. What did they tell you 9 before they started the conversation? 10 A. They wanted to show me their ID, so that I 11 knew that they were who they said they were. 12 Q. Okay. So they showed you the ID. Then what 13 did they say? 14 A. They wanted to talk to me about 15 Jeffrey Epstein. 16 Q. And did they— and they proceeded to did 17 they both ask you questions, or just one person? 18 A. Mostly the woman. 19 Q. She asked what, 90 percent of the questions? 20 A. Yes. 21 Q. And what did you tell? What — what 22 questions did she ask you; what's your best 23 recollection? Okay? And what did you tell her? 24 A. She asked me how many times I had gone to 25 Jeffrey Epstein's house. I Page 91 1 delivered regularly to my house. 2 Q. So you happened to see some article about 3 Mr. Epstein? 4 A. Yes. 5 Q. Do you remember what the ankle was about, 6 other than seeing his face? 7 A. It was about him being arrested. 8 Q. All right. And was it after you saw that he 9 was arrested that then you called the FBI, or did you 10 continue to wait a lengthy period of time? 11 A. I waited -- 12 Q. Why? 13 A. — some time. 14 Excuse me? 15 Q. Just didn't want to be involved? 16 A. I was afraid. 17 Q. What were you afraid of? 18 A. I don't know. 19 Q. There wore no cars watching you; right? And 20 you didn't see any suspicious activity; correct? 21 A. Not at that time. 22 Q. MI right. So they come out; they spend an 23 hour with you. What did they ask you? Well, let me -- 24 let me go back to when you set up the appointment. How 25 long was that? Did you say, I'm Jane Doe, I'll talk 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 93 Q. And -- A. And I told her that I couldn't remember exactly how many times it was. It was probably at least 20.. Q. Did you tell her that? A. Yes. She asked me who brought me to Jeffrey Epstein's house. Q. What did you tell her? A. I told her that'll. brought me there. Q. Ma A. Yes. Q. All right. Let me just -- and then I'm going to get back to the conversation. At the time that you saw or were staying with either on the first occasion or the second occasion, I assume you were friends at that time, good friends? A. Yes. Q. Okay. And you continued to be good friends, even when you were apart, during that interim time period between the first and second; correct? A. You mean, were we still friends after I didn't live with her? Q. Yeah. After the first time and you went back to your grandmother's house, you still continued to be (561) 832-7500 24 (Pages 90 to 93) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501333.772.1552) Electronically signed by Pamela Sullivan (SO1-333-772-1652) 17eao621-3493-40cd -8666.00c 698ca2735 EFTA00750730 Page 94 Page 96 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 good friends with. — A. Yes. Q. -- before you went back the second time: correct? A. Yes. Q. And when you were with.., did you sec. from time to time? A. Yes. Q. Okay. And would — did you consider.. to be one of your good friends? A. Yes. Q. And is she still one of your good friends today? A. Yes. Q. And you said.. is not a good friend today — MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. -- is that correct? A. I haven't spoken to.. in some time. Q. How long? A. About at least six months. Pm not positive. Q. And what happened to cause you not to be friends? 1 BY MR. CRIITON: 2 Q. Separate and apart from what Mr. Edwards may 3 or may not have read to you has anyone else shown you 4 or read to you portions on.'s deposition? 5 A. No. 6 (,Z.— Are you aware that she was deposed last 7 wee k- 8 MR. EDWARDS: Objection. Attorney/client 9 privilege. 10 BY MR. CRITION: 11 Q. — and had given her deposition -- 12 MR. EDWARD$: You're not answering the 13 question_ 14 BY MR. CRITTON: 15 Q. Let me ask you this: Separate and apart from 16 Mr. Edwards, were you aware than. was going to give 17 a deposition? 18 A. No, l was not. 19 Q. After — and so -- let me strike that. 20 So separate and apart from whatever your 21 attorney may have told you, you had no knowledge that 22 E. either was going to give a deposition or had given 23 a deposition; is that correct? 24 A. That is correct. 25 Q. Did. -- did.. — did — did you tell Page 95 1 A. She was living in the same neighborhood as 2 me, and she moved. I don't know. We just — 3 Q. Call her by cell phone? 4 A. We just lost contact. I don't know. 5 Q. Do you know what she's doing now? A. No, I do not. Q. And you don't know where she's living now? A. No, I do not. Q. But you've stayed in touch within.? A. We talk probably once every other month. Q. Did you talk to her after she gave her deposition last week? A. No, I have not. Q. Did you read her deposition? A. No, I did not. Q. Have you seen any portions of her deposition? A. I haven't read it. Q. My question is: Have you seen any portion o .'s deposition? A. No. Q. Okay. Has anyone read any portions of that deposition to you? MR. EDWARDS: Object to the form. She's not answering the question, attorney-client privilege. 1 2 3 4 5 6 7 8 9 10 11 12 13 1.4 15 16 17 18 19 20 21 22 23 24 25 Page 97 either.. ore. that you were going to meet with the FBI? A. No. Q. Did they-tell you that they had met with the FBI? A. No. Q. Or anyone else? A. No. Q. Did you tell anyone, other than -- let me strike that. Did you tell your grandmother you were going to meet with the FBI? A. Yes. Q. Did you tell any other family member you were going to meet with the FBI? A. No. Q. Did your grand — your grandmother knew that you had gone to Mr. Bpstein's home; didn't she? A. She didn't know any details. Q. Let me ask — answer my question. Your grandmother knew that you had gone to Mr. Epstein's home on a number of occasions; true? MR. EDWARDS: Object to the form. THE WITNESS: She knew after I told her, yes. (561) 832-7500 25 (Pages 94 to 97) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (5D1-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1652) t7eao621.3493.40cd-8666-00o698ca2736 EFTA00750731 Page 98 Page 100 1 BY MR. CRITTON: 2 Q. But evai during that time period she knew 3 that you were going to Mr. Epstein's home from time to 4 time? 5 MR. EDWARDS: Object to the form. 6 THE WITNESS: During what time period? 7 BY MR. CRITTON: 8 Q. During the time you — time period that you 9 went to Mr. Epstein's home. 10 A. No, she did not ;mow. 11 Q. Didn't you give your grandmother's cell phone 12 to someone at Mr. Epstein's home — not Mr. Epstein, but 13 to someone at Mr. Epstein's home? 14 A. Her cell phone? 15 Q. Or her phone number? 16 A. It was a phone number that 1 was using, yes. 17 Q. And that phone number belonged to whom? 18 A. Me — well, was paying for it, 19 but it was my phone number. 20 Q. All right. So other than your grandmother, 21 did anyone know — else know that the FBI was coming? 22 A. No. 23 Q. So they asked you the number of times you had 24 gone to Mr. Epstein's house. You said you didn't 25 remember, but you thought it was about 20 times. They 1 2 3 4 5 6 7 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. No, that is not true. Q. Well, what makes you think it was February, a plus or minus a month? A. Because I told Jeffrey Epstein that I was 15 and that my birthday was in January. And I knew that it Q. Okay. And why would you tell him you were 15, rather 14 — A. I don't — Q. — assuming that's true? What was — what was the big difference to you about that? A. I have no idea. Q. Did M. tell you to say that? A. No. Q. In fact, a. had told you to say that you were IS; isn't that true? A. That is not true. Q. Okay. Well, didn't M., before she took you there the first time, say, look, tell Mr. Epstein you are 18, if he's — if you're asked? A. That is absolutely not true. Q. So if would — has testified to that wider oath, that would be a lie? MR. EDWARDS: Object to the form. THE WITNESS: Yes. 1 2 3 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 99 asked you — A. Yes. Q. Correct? A. Yes. Q. And they asked you who brought you, and you Said ■ - A. Yes. Q. — correct? What else did they ask you? A. They asked me — they asked me what happened the first time I went to Jeffrey Epstein's house. Q. Did -- did you tell them the first time that you went to Mr. Epstein's house? A. Yes. Q. Okay. And when was the first date that you went to Mr. Epstein's home? A. I believe that it was in February of'03. Q. And what makes you think it was in February of'03? A. Because I was — I was definitely 14, and Fm — Fm not exactly positive that it was — like if it was February or the month before or after. I just know it was around that time. Q. Isn't it true, ma'am, the first time you went to Mr. Epstein's home you were 15 years old? Page 101 1 BY MR. CRITTON: 2 Q. Did you ever keep a log a any kind of diary 3 or paperwork of any kind that as to the dates that 4 you went to Mr. Epstein's home? 5 A. No. 6 Q. When is the last time you went to 7 Mr. Epstein's home? 8 A. I was 17. 9 Q. Give me a date. 10 A. It was after I tamed 17. It must have been 11 very shortly after June something. 12 Q. So it would have been June, July of '05? 13 A. The beginning of July, though. 14 Q. So you're — is it — are you telling us that 15 over basically a three-, almost four-year span, you went 16 to Mr. Epstein's -- which is about 48 months or 17 something less, 40 to 48 months — you went to 18 Mr. Epstein's house approximately 20 times? 19 A. Probably more, but, yes. 20 Q. Well, you told the FBI it was approximately 21 20; right? 22 A. Yes. 23 Q. And they asked you what happened on the first 24 occasion, and did you tell than? 25 A. Yes, I did. 40' n04. ab.lar—e- (561) 832-750O PROSE COURT REPORTING AGENCY, 26 (Pages 98 to 101) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772.1552) freae621.3493-40cd.8666-000698ca2735 EFTA00750732 Page 102 1 Q. Okay. And did you tell the FBI that you were 2 14 years old when you went? 3 A. Yes, I did. 4 Q. You're sure of that? 5 A. Yes. 6 Q. Other than telling them what happened on the 7 first occasion, what else did they ask you? 8 A. What happened on every other. 9 Q. Did they go through all 20 — approximately 10 20 occasions that you were at Mr. Epstein's home? 11 A. No. They just wanted to know what normally 12 would happen. 13 Q. And at the end of the conversation, what did 14 they tell you — a the end of the interview? 15 A. I don't remember. I'm sure that I — I know 16 that the woman was telling me somewhere along the lines 17 that it was wrong. She was telling me that it was 18 wrong, and -- 19 Q. The FBI lady told you that? 20 A. Yes. 21 Q. All right. And did the man say anything? 22 A. He — he pretty much just agreed with her. 23 He didn't say much. 24 Q. Did you ask any questions? 25 A. No. Page 104 1 MR. EDWARDS: Object to the form. 2 BY MR. CRITTON: 3 Q. Do you know the difference between the State 4 and the Federal system? 5 A. No. 6 Q. All right. As of the time that you received 7 the letter from the FB1, they talked to you about Victim 8 Services, had you at this time retained Mr. Edwards? 9 A. Before I went to Victim Services, yes, I did. 10 Q. Okay. Do you remember when you first went to 11 Victim Services? 12 A. No, I don't. 13 Q. Did the people — did the yeoman and the man 14 from the FBI discuss with you that you could bring a 15 civil suit and recover substantial money damages from 16 Mr. Epstein? 17 A. I don't remanber. 18 Q. Okay. Well, in fact — well, let me strike 19 that. 20 Did the FBI tell you at all that you might 21 have a civil cause of action against Mr. Epstein? 22 A. I don't remember. 23 Q. That's pretty would be pretty significant, 24 because you tiled a lawsuit in this instance, against 25 Mr. Epstein; true? Page 103 1 Q. Like, what are they doing with Mr. Epstein? 2 A. No,1 did not. 3 Q. And what did you think would happen as a 4 result of your interviewing with the FBI or talking to 5 them? 6 A. I just thought that it would help. I just 7 thought it would help. 8 Q. What — when they left that day — or before 9 they left that day, did they give you any paperwork a 10 any documents? 11 A. No. 12 Q. Okay. Did they subsequently, after the 13 interview, send you some documents later on? 14 A. Yes. 15 Q. Okay. Like a week later, couple of days 16 later? 17 A. Probably a week. 18 Q. And what did you receive? 19 A. I just received some papers saying that they 20 would help me by giving me a phone number to something 21 called Victim Services, where I could talk to somebody. 22 Q. And did you subsequently call the Victim 23 Service person? 24 A. Yes, I did. 25 Q. Is that in the Federal system? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 105 A. Yes. Q. All right. And how much money do you want from Mr. Epstein? MR. EDWARDS: Object to the form. THE WITNESS: I don't care about Jeffrey Epstein's money. BY MR. CRTITON: Q. Okay. What do you want? A. I want Jeffrey Epstein to go to prison for the rest of his life. Q. Okay. Is it your do you believe that the lawsuit that you have filed against Mr. Epstein will cause him to go to prison for the rest of his life? A. No, I do not. Q. Do you believe that the — well, what do you believe the purpose of your lawsuit is in this instance, that is that we're here on today that you're giving a deposition? A. 1 know that Jeffrey Epstein will not go to prison for what he did, and so... Q. Are you aware he's been in prison? MR. EDWARDS: Object to the form. THE WITNESS: Yes, but he didn't go to prison for the time he deserved to. (561) 832-7500 V...a.T.f.e.4.?laTrtralas 27 (Pages 102 to 105) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333472-1552) freae621-3493-40cd-8666-00e698ca2735 EFTA00750733 Page 106 1 BY MR. atITfON: 2 Q. From your perception; right? 3 MR. EDWARDS: Object to the form. 4 BY MR. CRITTON: 5 Q. You believe ho should have gone away longer? 6 A. I icnow that he hurt a lot of people, and he 7 deserves it. 8 Q. The question to you is, is your opinion is, 9 is that Mr. Epstein should have gone to prison for a 10 longer period of time; correct? 11 A. I believe that is a fact. 12 Q. Okay. Now, with maid to this lawsuit, what 13 do you want from this lawsuit, then? If you — if you 14 can't send him to prison, what do you want? 15 A. I want to hurt him. 16 Q. Okay. So you want to hurt him. And what do 17 you want in this lawsuit? Do you want money? 18 A. I want something that will hurt him. 19 Q. Okay. And what is that? 20 A. Whatever he's got. 21 Q. What do you mean, whatever he's got? 22 A. Well, if he loves money, and I can take that 23 away from him, then I hurt him. 24 Q. So you're asking for money in this instance 25 from him; correct? Page 108 1 from? Well, if it comes from Mr. Epstein, where do you 2 think it goes? 3 A. Ijust want something — I just want some 4 sort of justice. It's not it hasn't been — 5 Q. Pm sorry? 6 A. it hasn't been right in this. Just 7 because Jeffrey Epstein has money, he doesn't have to go 8 to prison; that's not fair. 9 Q. So in order to resolve this case with 10 Mr. Epstein, how much money do you want? 11 MR. EDWARDS: Object — 12 THE WITNESS: It doesn't matter. 13 BY IvER. CRITTON: 14 Q. Ill say, NI pay you X-amount of dollars 15 today, how much do you want? 16 MR. EDWARDS: Object to the form. 17 THE WITNESS: It doesn't matter. It doesn't 18 matter. That is not the point. 19 BY MR. CRITTON: 20 Q. So whether it's a dollar or a million dollars 21 doesn't make any difference to you? 22 MR. EDWARDS: Object to the form. 23 BY MR. CRITTON: 24 Q. It's just getting sane money from 25 Mr. Epstein; is that true? Page 107 1 MR. EDWARDS: Object to the form. 2 BY MR. CRITTON: 3 Q. Do you know whether you're asking for money 1 in this instance? 5 A. Yes. 6 Q. How much money do you want? 7 A. I don't care. 8 Q. A dollar? A hundred dollars? 9 A. I don't care. 10 Q. Do you know what you've asked foe? 11 A. No, 12 Q. How much money do you want in this how 13 much money would you like to -- in order to resolve this 14 case with Mr. Epstein, how much money would you take? 15 MR. EDWARDS: Object to the form. 16 THE WITNESS: Whatever would hurt him. 17 BY MR. CRITTON: 18 Q. Okay. So you want to hurt Mr. Epstein, as 19 distinct from really getting any money yourself; is that 20 a fair statement? 21 A. I don't understand. 22 ' Q. Okay. Well, if you want to hurt Mr. Epstein 23 by taking money, then what do you want for yourself? 24 A. I want — 25 Q. Where do you think the money is going to carte Page 109 1 A /40. 2 Q. Okay. Well, what — what do you want, then, 3 from Mr. Epstein? What do you think this case is about? 4 A. Getting justice. 5 Q. Okay. And how would you intend to get 6 justice? What's your perception of getting Mister -- 7 justice for Mr. Epstein? 8 A. Well, he hurt me and changed my life, and 9 that's what I would like to do to him. 10 Q. What? To hurt him and change his life? 11. A. Yes. 12 Q. But you have no idea whether you want a 13 dollar in this case, a hundred thousand dollars, more or 14 less; is that a fair statement? 15 MR. EDWARDS: Object to the form. 16 BY MR. CRITTON: 17 Q. Is that true? 18 A. I just want to take something from him. 19 Q. Okay. And whether ifs a dollar or a hundred 20 dollars or a hundred thousand dollars, you don't care 21 one — 22 MR. EDWARDS: Objection to the form. Asked 23 and answered. 24 BY MR. CRITTON: 25 Q. You just want something from him; true? (561) 832-7500 28 (Pages 106 to 109) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772.1552) PfeeeS21.3493-40ed-8666-00e698ca2735 EFTA00750734 Page 110 Page 112 1 A. No. 2 Q. What do you want, then? 3 A. I want something that will cause him damage, 4 something that will hurt him like he hurt me. 5 Q. And what is that something? 6 A. If there's nothing else, its obviously that. 7 Q. It's money. So how much? 8 A. I don't know. 9 Q. Let me ask you: On the back to the FBI. 10 Did you ever tell — when the FBI left that day, did you 11 tell your grandmother what your conversation had 12 consisted of? 13 A. No. 14 Q. Okay. Did you tell anyone at that time? 15 A. No. 16 Q. Again, at some point, then, you got this card 17 from Mr. Edwards — from Mr. Edwards about — let me 18 start again. 19 At some point you got a card that had 20 Mr. Edwards' name on it, law offices of Brad Edwards or 21 something like that; correct? 22 A. Yes. 23 Q. AU right. So people just generally don't 24 give out lawyer cards to individuals for no reason at 25 all. What occurred? What did you say? You must have 1. 2 3 4 S 6 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Where does he live, or where did he live at the tint? A. He— he was living with Q. Does he still? A. No. Q. He moved out? Did — A. Yes. Q. When he would take you to Mr. Epstein's house, would he wait for you? A. No. Q. He would just drop you off? A. Yes. Q. On how occasions did you take you? Page 111 1 said something to somebody that resulted in you getting 2 Mr. Edwards' card. 3 MR. EDWARDS: Object to the form. 4 BY MR. CRITTON: 5 Q. And I want to 'mow — 6 MR. EDWARDS: It's been asked and answered. 7 BY MR. CRITTON: 8 Q. — what was that? 9 A. Well, obviously, it was somebody who knew. 10 Q. Who was that person who knew? Who had you 11 told about what had occurred at Mr. Epstein's or that 12 you had been to Mr. Epstein's, other than your 13 grandmother, who knew you had gone; right? 14 A. Yes. 15 le earlier Okay. — and I think you told us earli 16 your sister, knew you bad gone, because she 17 had driven you on a number of occasions, three or four 18 times; correct? 19 A. Yes. 20 Q. All right. Had anyone else taken you or 21 driven you to Mr. Epstein's home, other than 22 A. Yes. 23 Q. Who? 24 A. My uncle. 25 Q. What's his name? Page 113 1 A. About two. 2 Q. Did anyone else drive you to Mr. Epstein's 3 home, other than your uncle and 4 A. Cabs. 5 Q. Okay. Separate and apart from a cab. 6 A. No. 7 Q. At the time you saw Mr. Edwards for the very 8 first time, bade. already retained his services? 9 MR. EDWARDS: Object to the form. 10 THE WITNESS: I don't latow. 11 BY MR. CRITTON: 12 Q. Had.. retained his services? 13 MR. EDWARDS: Same objection. 14 THE WITNESS: I don't know. 15 BY MR. CRITTON: 16 You were aware that Mr. Edwards represents 17 M. and M., in addition to you? 18 MR. EDWARDS: Objection. Don't answer. 19 Attomey-client privilege. 20 BY MR. CRITTON: 21 Q. Well, I don't want to know what he's told 22 you. Are you aware that Mr. Edwards represents 0 23 MR. EDWARDS: Outside of any conversations 24 I've everhad with my client? 25 MR. CRITTON: Sure. (561) 832-7500 29 (Pages 110 to 113) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772-1M) Electronically signed by Pamela Sullivan (601.333-772.1562) f7eae621349340cd.8666.00e698ca2736 EFTA00750735 Page 114 Page 116 I. BY MR. CRIITON: 2 Q. She's told you that; hasn't she? 3 A. What? 4 Q. has told you that Brad Edwards 5 represents her; hasn't she? 6 A. She may have. 7 Q. Olten iAnd — and you know that Brad Edwards 8 represents M., separate and apart from anything 9 Mr. Edwards has told you; true? 10 A. III. may have told me before. 11 Q. And you're aware that Mr. Edwards, separate 12 and apart from anything that Brad may have said, 13 represents too, t-o-o; correct? 14 A. Excuse me? 15 Q. Separate and apart from anything Mr. Edwards 16 told you, you're aware that M . is a — is a Plaintiff 17 She's suing Mr. Epstein, as well; right? You're aware 18 of that fact? 19 A. I have never spoke about this really with 20 21 Q. So it's your testimony that you have never 22 discussed the fact, even, that Mr. Edwards represents 23 you in a lawsuit against Mr. Epstein? You've neva 24 discussed that with ■ at any time up through today's 25 date, which is September 30, 2009; correct? • 1 through today's date? 2 A. No. 3 Q. Okay. Not even casually? Not over the 4 phone, not when you would get together? When you would 5 get together, you two would just simply not talk about 6 these lawsuits at all; correct? 7 A. Yes. a Q. Okay. Same thing with M. is, is that, even 9 though you would see each other or talk with each other 10 occasionally, or once a month, as you -- I think you've 11 described, or once every other month, as you've 12 described, you've never discussed the lawsuits at all; 13 correct? 14 A. Yes. 15 Q. Thais correct? 16 A. Yes. 17 Q. Let me show you what Fll mark as Exhibit 2. 18 rib just write -- handwrite down at the bottom for 19 right now, and then Pamela can come back and do 20 something with it. 21 And that's for you. 22 (Defendant's Exhibit No.2 was marked for 23 identification.) 24 BY MR. CflITTON: 25 Q. This is a document entitled, In Re: Page 115 1 MR. EDWARDS: Object to the fan 2 THE WITNESS: I'm not sure. 3 BY MR. CRITION: 4 Q. Nov you're not sure. 5 Is — is — were you aware that M. well, 6 . let me strike that. 7 Has M. ever told you that she — that 8 Mr. Edwards represents her? 9 A. Not specifically, no. 10 Q. How about =specifically? 11 MR. EDWARDS: Object to the form. 12 BY MR. CRIITON: 13 Q. What do you mean by, not specifically? 14 A. She has not actually said to me, Brad Edwards 15 represents me. 16 Q. And ill understood your testimony earlier, 17 you — you have never discussed — she's never discussed 18 any aspects of her lawsuit with you since the time it 19 was filed; correct? 20 A. Yes. 21 Q. Okay. And a., while she represented to you 22 or told you that Mr. Edwards represents her, has she 23 ever discussed her lawsuit — 24 A. No. 25 Q. -- up through from the time it was filed up Page 1', 1 Jane Doe, Emergency Victim's Petition for Enforcement of 2 Crime Victim's Rights. And that's your copy. 3 Take a look at that, if you would, please. 4 MR. EDWARDS: Do you want her to read the 5 whole thing? Is that what you're asking her to do? 6 MR. CIUTTON: Just look at just look -- 7 just locdc at the — 8 MR. EDWARDS: The style or something. 9 MR. CIIITTON: — look at the tint page. 10 BY MR. CRITTON: 11 Q. Does anything on this first page look in any 12 way familiar you to, ma'am? 13 A. You mean, have I ever seen this? 14 Q. Yes. 15 A. No, l haven't 16 Q. All right. This was a pleading that 17 Mr. Edwards filed on behalf of a Jane Doe on July 7th, 18 2008. And it's to assert -- at least the allegations 19 are that -- that the Jane Doe, as a minor child, was a 20 victim of Federal crimes. And — and then it goes on to 21 attempt to assert certain rights. 22 Are you the Jane Doe who's in this lawsuit? 23 Do you know whether you're the lane Doe who's in this 24 lawsuit? 25 MR. EDWARDS: Object to the font (561) 832-7500 VIIICL=ICgde—CPZ—,laitus•ahfe.e.ALA.... 30 (Pages 114 to 117) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signod by Pamela Sullivan (501-333-772-1552) f7s0214493-40448446404691k427218 EFTA00750736 Puy. Page 120 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE WITNESS: I don't know. BY MR. CRITTON: Q. Well, you've never given Mr. Edwards permission to file any lawsuit, other than the lawsuit that's currently pending; is that correct? A. I'm sure that if he asked, I would, without even reading. Q. Okay. Well, did you ever tell well, did he let me strike that. You just don't know whether you're this Jane Doe — A. No, I don't. Q. - in this lawsuit; correct? A. That's correct. Q. Let me show you Exhibit 2 (sic). MR. CRITTON: And I'm going to blot out with the copy that I give the Court Reporter, because it's just my initials. There's a reference here, and then my initials and an F, for filing. And I'll blot that out on the exhibit that we use, if that's okay with everyone. (Defendant's Exhibit No. 3 was marked for identification.) BY MR. CRITTON: Q. Let me show you Exhibit 2 (sic) — 1 agreement? 2 A. Yes, I have. 3 Q. All right. And do you have it in your 4 possession -- not today, but do you have a copy of it at 5 home? 6 A. Yes, I do. 7 Q. Okay. And did you review it? 8 A. Yes, I did. 9 Q. And with the nonprosecution agreement -- 10 excuse me — or looking at Exhibit 3, now, Victim's 11 Motion to Unseal Nonprosecution Agreement, are you 12 Jane Doe One or Jane Doe Two? 13 MR. EDWARDS: Object to the form. 14 BY MR. CRITTON: 15 Q. Or do you know? 16 A. I don't blow. 17 Q. Would it be a cored statement as to 18 Exhibits 2 and 3, you've never seen those exhibits 19 before today's date? 20 A. I could have, without remembering. 21 Q. But at least as of today's date, you're not 22 sure, one way or the other; is that correct? 23 A. Not sure, no. 24 MR. CRITTON: Let me show you what I'll mark 25 as Exhibit 4. 1 2 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 119 MR. CRITTON: Here's your copy, Brad. BY MR. CRITTON: Q. — Em sorry, Exhibit 3. And this document is entitled Victim's Motion to Unseal Nonprosecution Agreement. And it looks — it appears to be a pleading that was electronically filed by Mr. Edwards on or about September 25th of '08. And if you will just read excuse me -- the first paragraph refers to now, it's the — it's the same case style, except now there's a Jane Doe One and a Jane Doe Two that are referenced — excuse me — that Mr. Edwards represents. And it's a Motion to Unseal the 12 Nonprosecution Agreement that has been provided — that 13 was provided to both Jane Doe One and Jane Doe Two. 14 Do you know what the -- if I use the term 15 nonprosecution or NPA, does that mean anything to you? 16 Or aml — 17 1 2 3 4 5 7 8 10 11 A. Yes. Q. — speaking Greek? A. Yes. Q. I'm speaking Greek? A. No. Q. You understand what it is? A. Yes. Q. Okay. Have you seen the nonprosecution 25 18 19 20 21 22 23 24 Page 121 And here's your copy, Brad. (Defendant's Exhibit No. 4 was marked for identification.) BY MR. CRITION: Q. And this is Declaration of in Support of the United States Response to Vi 's Emergency Petition. And it was — at least, it was entered on the system on July 15th of '08, but there's a stamp for July 9th of '08. Do you know who is? A No, I do not. Q. I would represent to you that -- let me strike that. Do you know what an affidavit is? A. No, I don't. Q. Ora declaration is? A No. Q. Okay. Do you 'mow what an — and I think you said you don't know what an affidavit is, either; correct? A. No, I do not. Q. All right. When you signed your interrogatories in this case that — you received written questions from me that I seat to your lawyer. You and your lawyer put together the answers, and you 31 (Pages 118 to 121) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1552) Electronically signed by Pamela Sullivan (5014334724552) freat6214493-40014666-006698ca2735 EFTA00750737 Page 122 1 had to sign an affirmation or an oath that everything 2 set forth on those answers to interrogatories, other 3 than the objections, was true and correct, under penalty 4 of perjury; do you understand that? 5 A. No. 6 Q. Okay. Do you remember signing 7 interrogatories that said these are my answers to 8 written questions? 9 A. What questions? 10 Q. Okay. Do you ever remember answering some 11 questions in this case? 12 A. Yes. 13 Q. Okay. And I assume — and I dont want to 14 know what Mr. Edwards said -- but I assume that you 15 worked with your attorney to get the correct answers or 16 responses to those questions; true? 17 A. What questions are we talking about? 18 Q. Well, you've only received one set of written 19 questions in this case; correct? That is, I sent you 20 questions like, state your name and address, et cetera. 21 A. Oh, okay. Yes. I do know. 22 Q. All right. And you answered them in 23 conjunction with your attorney? 24 A. Yes. 25 Q. All right. And when you finished answering 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 124 question was wrong, here is the correct answer. Are you aware of any document that's been prepared that you've signed that said, prior answers to interrogatories were wrong, these are correct, these are the new — the new, improved version, or the better answers? MR. EDWARDS: Object to the form. THE WITNESS: No. BY MR. CRITTON: Q. All right. Anyhow, let me get back to Exhibit — MR. CRTTTON: How much time do I have? VlDEOGRAPILER: One minute. MR. CRITTON: Okay. Let's take a break. VIDEOORAPHER: Off the record at 11:34. MR. CRITTON: Let's take five. (A brief recess was taken.) (Continued in Volume II of the same clay.) Page 123 1 those question; you reviewed them to make sure that 2 they were accurate; correct? 3 A. There were some that were not 4 Q. Okay. Well, at the time you reviewed did S you review than at the time and sign them, under penalty 6 of perjury? Well get to that later, but you remember 7 answering the questions and then signing your name; 8 correct? 9 A. I answered them over the phone. 10 Q. That's not my question. Do you remember 11 signing them? 12 MR. EDWARDS: Object to the form. 13 BY MR. CRITTON: 14 Q. Did you -- do you remember giving answers to 15 your attorney or a representative in his office, in 16 order to answer those questions? 17 A. I answered these questions over the phone. 17 18 Q. Okay. So is -- if you answer something over 19 the phone, they don't have to be true, but if you answer 20 something in person, it does have to be true; is that 21 how you interpret the law? 22 A. No, but there were some things that he 23 obviously typed up smog. 24 Q. You've never filed any -- at least as of 25 today I haven't seen any document that says, that 1 2 3 4 S 7 9 10 11 12 13 14 15 16 18 19 20 21 22 23 24 25 Page 125 CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that JANE DOE personally appeared before me and was duly sworn. Dated this 13th day of October, 2009. Pamela J. Sullivan, RPR, Notary Public - State of Mon My Commission Expires: June 10,2010 My Commission No.: DD 560380 (561) 832-7500 32 (Pages 122 to 125) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (601-333-772-1552) f7eae621-349340cd-8666-00e698ca2735 EFTA00750738 Page 126 Page 128 i CERTIFICATE 2 THE STATEOF FLORIDA 3 COUNTY OP PAIDA BEACH 4 5 1, Pamela J. Sullivan, Registand Proessicnal Court Reporter and Notar). Public in rid for the Sute of 6 Florida r large, do Imeby certify that I was atahorized to and did ropar said deposition in 7 stenotype; and that the fortraina pages ase a true arid circa transcription of my shortband notes of said 8 deposition, 9 1 further ceztify that said depceition was taken at the time and piacei hereinabove set fortl. and that die 10 uting of seid depositicen was commenced and conipleted as hertinabove set out 11 I fintier catify Madam not attorney or counsel 12 of any of the partiell, nor am la relative or employee of any atomey a counsa of party cmmied with the 13 anion, na am I financially interested in the action 14 The fcregoing certification of this transeript dem not apply to any repeoduceon of the time by any means 15 urless ude et direet control and/or direction of thc oertifying reperter. 16 17 18 19 20 21 22 23 24 25 Dated this llth day of October, 2009 Pamela I. Sulirwn, RPR, FPR, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATE IIIE STATE OF FLORIDA COUNTY OF PALM BEACH I horeby certify that I have read the foregoing deposition by me given, and that the statements contained herein are true and conect to the best of my knowledge and belief, with the exception of any com:ctions or notations made on die errate sheet, if one was executed. Dated this day of 2009. JANE DOE 1 Onder /3,2200 2 IiiiNEDDE Cae IsAD I. EDWARDS.11891.11RE 3 Remis ParerüldiAdls 114.9 CiiiiOne. 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See »00 FIMdalle) I do Well rin,' iny rtgroin .1.`e Dö2 JANT DOE _ Page 127 Page 129 1 ERRATA SHEET 2 IN RE JANE DOE V. JEFFREY EPSTEIN 3 at PAMELAJ. SULLIVAN, RPR, FPR, CLR 4 DEPOSITION 0P: JANE DOE 5 DATE TAREN: Stramber 30, 2009 6 DO NOT WRITE ON TRANSCRWT • ENTER CHANOES HERB 7 PAGEN UNEN MANGE REASON 8 9 10 11 12 13 15 16 17 16 19 20 Under patze of ixejury, l declare the I have read my 21 deposition and that it is ane and torosa subjett to any changes in form or surtana enered hat. 22 23 DATE: 24 25 Name forvaud the original signed enata sheet to this Office so that copies may be distributed to all panis. SIONATURE OF DEPONaTP (561) 832-7500 PROSE COURT REPORTING AGENCY, 33 (Pages 126 to 129) INC. (561) 832-7506 Electronicalty signed by Pamela Sullivan (501-333-772-1552) Electronically signod by Pamola Sullivan (601-333-772-1552) freas621•3493-40cd.8666-00e698ca2735 EFTA00750739