EFTA00750740.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 II 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 (601.333-772-15521 Electronically signed by Pamela Sullivan (501.333-772-1552) 41151584-6022-4050-b036-0423518c2lb5 EFTA00750740 Page 131 APPEARANCES! ▪ On behalf et the Plaintiff. Jaw Doe: 3 BRAD J. EDWARDS. ESQIARE ROTHSTEIN ROSENFELDT ADLER Las Obs City Cann, Suite 1650 40) East Les Clef Boulevard Fm Loodadok, Plaids 33301 On is . Jeffrey Epstein: ROBERT D. CRITTON. JR . ESQUIRE BURMAN. CE/TION.LATIllER & COLEMAN, LIP e 303 Banyan Boulevard Suite HO 33401 11 12 13 t1 15 14 17 18 19 20 On behalf of hint Dons I chrome, 8: ADAM D. HOROWITZ, ESQUIRE 22 MER).031STEIN & HOROWITZ, P.A. l$205 MST= TH8Mv" 23 Suite 73I8 Mimi. Met 33160 21 Om behn lathe Defendant. Jeffrey Eenciir JACK ALAN GOLDBERGER, ESQUIRE ATTERBURY. G01E/BERGER & WEBS, EA 250 Aisle Mesa Sou& Site 1400 Were Palm Bock Florida 334014012 On behalf of Plaintiff in Related Case No. 0840469: ISIDRO M. GARCIA. &S0USE GARCIA LAW FIRM. P.A. 224 Dana Steel. Site 90D mi W Palm Beech Florida 33401 24 25 1 2 3 4 5 6 7 Page 133 - - - INDEX - - VilINESS: DIRECT CROSS REDIRECT RECROSS JANE DOE BY MR. CRITTON 5 EXHIBITS MARKED 9 10 11 DESCRIFT1ON 12 Defaidrates No. 5 13 (Order) 14 15 16 17 18 19 20 21 22 23 24 25 PAGE 163 Page 132 1 On behalf of the Plaintiff= : 2 JAOC P. HILL, ESQUIRE SEARCY DENNRY SCAROLA BARNHART & SHIPLEY, PA. 3 2139 Palm Beach Lakes Boulevard West Palm Bead), Florida 33409 4 5 On behalf of the B.B.: 6 ADAM 1 LANONO, ESQUIRE LEOPOLD KUVD/ 7 2925 PGA Boulevard, Suite 200 Palm Beach Gradats, Florida 33410 9 10 11 12 13 14 15 16 17 18 19 20 21 22 -23 24 25 ALSO PRESENT: Jeffrey Epstein, via video conference Stan Sanders, Videographer 1 2 3 4 Page 134 PROCEEDINGS (Continued from Volume lof the same day.) VIDEOGRAPHER: Back on the record at 11:52. 5 BY MR. CRITTCIN: 6 Q. Ms. Jane Doe, I have in front of you, I 7 think, Exhibit 4 w be Exhibit 4, which 8 is the declaration . Do you see that? 9 A. Yes. 10 Q. And I will represent to you, and I think you 11 told me you don't know who she is; correct? 12 A. Yes 13 Q. And on Page 2, she says is, "I" — in her 14 declaration says — the first sentence says: "I am the 15 Assistant US — United States Attorney, assigned to the 16 investigation of Jeffrey Epstein," and then — "and the 17 case was investigated by the Fetal Bureau of 18 Investigation, FBI," et cetera, et cetera. 19 Do you see that up at the top? 20 A. Yes. 21. Q. Okay. That's who she says she is. And then 22 she's — on Page 7 of her declaration she says: 1 23 declare, under penalty of perjury, pursuant to 28 USC, 24 Section 1746, that the following is true and correct, to 2 5 the best of my knowledge and belief." And then she (561) 832-7500 2 (Pages 131 to_124) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772.1652) Electronically signed by Pamela Sullivan (501-333-7724652) 4415158d4c22-4460-130354423518e2fb6 EFTA00750741 Page 135 1 signs this on 9th day of July 2008, and then it purports 2 to be what is her signature above her printed name. 3 Do you see that? 4 A. Yes. 5 Q. All right. If I go to paragraph three, down 6 at the bottom it says here -- there's a reference to 7 Jane Doe, Page 3 — I'm sorry — Page 2, paragraph 8 three. Are you with me? 9 A. Yes. 10 Q. Go up — not — not the footnotes. You brow 11 what a footnote is; don't you? 12 A. Yes. 13 Q. All right. Go up from the footnotes, then 14 one, two, three lines up it says: "Jane Doe was 15 identified? 16 Do you see that? 17 A. Yes. 18 Q. You are that Jane Doe; correct, Jane Doe? 19 A. Those are my initials. 20 Q. And -- and if you read in fact, I should 21 probably have you just — why don't you read to yourself 22 paragraph three, because there's a reference to 23 Mr. Edwards and three of his clients,.., M. and 24 Jane Doe. Do you see that? 25 A. Yes, I do. Page 137 1 Do you see that? 2 A. Yes. 3 Q. And then it says: "The FBI's Victim Witness 4 specialist sent a letter to Jane Doe," you, "on May 30, 5 2008." 6 Do you see that? 7 A. Yes, I do. 8 Q. Okay. You indicated that you were -- when I 9 asked you earlier today — excuse me — when you had 10 given your statements and you said, emphatically, you 11 were three and a half months pregnant; correct? 12 A. Yes. 13 . All ri t. You wouldn't dispute 14 and the FBI's agents' statement that 15 they interviewed you on May 28th 01'08; correct? 16 A. No. 17 Q. And I think you — well, I don't think. Let 18 me start again. 19 You've told us — you've testified that you 20 only talked with the FBI on one occasion, and that one 21 occasion bad to have been May 28th of '08; correct? 22 A. Yes. 23 Q. Okay. And that was the first time, at least, 24 that you had told any governmental authority, state, 25 Federal, local, that you had been to Mr. Epstein's home; Page 136 Q. Okay. fl would be M. -- 2 A. Yes. 3 Q. — you would assume. would be II., and 4 you would have to be the Jane Doe; Jane Doe? 5 A. Yes. 6 Q. Are you aware of any individuals that Miss -- 7 Mr. Edwards represents, other than you, ■ ani M.? 8 A. No. 9 Q. All right. Then it goes down — again, 1 10 take you back where it says: "Jane Doe was identified 11. via the FBI's investigation in 2007, but she initially 12 refused to speak to investigators." 13 Doyou see that? 14 MR. EDWARDS: Object to the form. 15 THE WITNESS: Yes, d do. 16 BY MR. CRJ1TON: 17 Q. And that's true; you did refirse to speak with 18 them? 19 MR. EDWARDS: Object to the form. 20 rim WITNESS: Yes. Yes,1 did. 21 BY MR. CRITTON: 22 Q. All right. And then it says: 'Jane Doe's 23 status as a victim of a Federal offense was confirmed 24 when she was interviewed by Federal agents on May 28th, 25 2008." Page 138 1 correct? 2 A. Yes. 3 Q. And if you go to Exhibit 5 — 4 MR. CRITTON: And, Mr. Edwards, if you could 5 help your client. 6 MR- EDWARDS: I haven't seat an Exhibit 5 7 yet, Ideal think. MR. CRITTON: It's — sorry. Exhibit 5 9 to ExhilAt 4. My fault 10 MR. EDWARDS: Okay. Just to show her where 11 it is. It's -- if you look up at the upper, 12 right-hand comer, there's a May 30th letter. 13 MR. CRITTON: May 30, 2008, letter. It's: 14 "Dear Jane Doe," and it's been redacted in part. 15 MR. EDWARDS: Let's see if I can get there, 16 and then rit get her there. 17 BY MR. CRITTON: 18 Q. If you look — you're now loo at 19 Exhibit 5 to our Exhibit 4; correct, to 20 declaration? 21 A. Okay. 22 Q. And you see it's a letter from the US 23 Department ofJustice. It's dated May 30th, 2008, and 24 it says: "Dear Jane Doe," because your name has been 25 redacted; correct? (561) 832-7500 .4.1•••••..n.x4 3 (Pages 135 to 138) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (661.333-772.1652) Electronically signed by Pamela Sullivan (601-333-772-1652) 4f151584-6c22-4c50-b036o423618c2fbS EFTA00750742 Page 139 1 A. Uh-huh. Yes. 2 Q. And is this the Victim's Assistance Program, 3 a letter that you said you received sometime after you 4 met with the FBI? 5 A. Yes. 6 Q. Okay. And I think you said — your -- your 7 best recollection was within a week, which is consistent 8 with this letter, which also then reconfirms that the 9 FBI had to have met with you, as reflected in the 10 declaration on May 28th, 2008, for the very first time; 11 correct? 12 A. Yes. 13 Q. All right. At the time that you received 14 this letter, 'think you also told us that you had not 15 been represented, or you -- Mr. Edwards was not 16 representing you at that time; correct? 17 MR. EDWARDS: Object to the form. 18 THE WITNESS: Yes, it was shortly after. 19 BY MR. CRITTON: 20 Q. All right. If you then go down to Exhibit 7, 21 and it's easier to read. 22 MR. EDWARDS: Flip a few pages. 23 THE WITNESS: Here? 24 MR EDWARDS: Keep going (inaudible). 25 THE WITNESS: Okay. 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 141 does that refresh your recollection that the FBI told you that you could file some sort of civil suit against Mr. Epstein? MR. EDWARDS: Object to the form. THE WITNESS: Yeah, they — they may have mentioned something of it. BY MR. CRITTON: Q. Okay. So that — that refreshes your recollection that the FBI said, You know, you may want to go get your own lawyer and bring a money — a civil suit against Mr. Epstein; we're only criminal people? M. EDWARDS: Object to the form. BY MR. CRITTON: Q. Does that refresh your recollection? A. Which document refreshes her recollection? Any of this? MR. CRITTON: No, I just quoted back to her what she said to me. MR. EDWARDS: Okay. Well, if you know the answer to what he's talking about, then answer it. THE WITNESS: They didn't — I know — I mean, I don't remember what exactly they said to me, but they did mention that I should get a lawyer. Page 140 1 BY MIL CRITTON: 2 Q. This is a letter also from the US Department 3 of Justice. It's from EMS It's directed to 4 Mr. Edwards. It's dated July 9th, 2008. 5 A. Uh-huh. 6 Q. And it says, Re: Jeffrey Epstein/S, and then 7 there's a redaction, ft/Notification of Identified 8 Victim. 9 Do you see that? 10 A. Yes, I do. 11 Q. Okay. Have you ever seen this letter before? 12 A. I don't remember seeing this. 13 Q Now, having seen the affidavit, Exhibit 4, 14 that is the declaration of that reflects 15 that you met with the FBI on May 28th, and consistent 16 with your earlier testimony, that you got the victim's 17 assistance letter shortly thereafter, which we now know, 18 from looking at one of the exhibits to the declaration, 19 was May 30th of '08. 20 Does that in any way refresh your 21 recollection how you got -- or from whom or how you got 22 the card to go find Mr. Edwards? 23 A. Well, no. 24 Q. Okay. And now, having seen the declaration 25 in exhibits -- and the exhibits that we've identified. Page 142 1 BY MR. CRITTON: 2 Q. All right. And that you might be able to get 3 money? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't — leant remember 6 them saying anything to me about money. 7 BY MR. CRITTON: 8 Q. Then why would you need a lawyer under these 9 circumstances for any reason? You weren't — or did. 10 they indicate to you that you were a target of any 11 investigation? 12 MR. EDWARDS: Object to the fain. 13 THE WITNESS: Basically, they just told me 14 that what happened to me was wrong, and that I 15 should do something about it. 16 BY MR. CRITTON: 17 Q. Okay. And you understood that doing 18 something about it was filing a lawsuit against 19 Mr. Epstein and ask for money? 20 MR. EDWARDS: Object to the form. 21 BY MR. CRITTON: 22 Q. Is that a fair statement? 23 A. Well, I wanted to have him prosecuted for 24 what he did, but I obviously can't do that. 25 Q. Because — because you know from your own (561) 832-7500 4 (Pages 139 to 142) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772.1652) Electronically signed by Pamela Sullivan (601.333.7724662) 4f15158d-8c22-4c50-b036-e423618c2fb5 EFTA00750743 Page 143 1 criminal experiences that it's either the State of 2 Florida or the United States Government that prosecutes 3 people, not individuals; true? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't understand. 6 BY MR. CRITI'ON: 7 Q. Well, you know that you can't prosecute -- a 8 citizen doesn't have the right to prosecute. It's — 9 ifs an arm of the Government, and you know from your 10 own experience. That is, when you got in trouble with 11 the law, you know it was the State of Florida versus 12 you; comet? 13 MR. EDWARDS: Object to the form. 14 THE WITNESS: That's not something that I 15 specifically 'mew from my own experience, no. 16 BY MR. CRITTON: 17 Q. Okay. Well, well get to that a little 18 later. Let — let me go back to the discussions that 19 you had with the FBI. I think you told me — well, I 20 know what I wanted to ask you. If you go back to 21 Exhibit 4, Page 2 — 22 A. (Witness complies.) 23 Q. — same paragraph, paragraph three. It says: 24 Attached hereto are copies of letters provided to 25 Mister — or to Bradley Edwards, three clients,.., Page 145 1 Third sentence says: "All three of those 2 clients were victims of Jeffrey Epstein's while they 3 were minors, beginning when they were 15 years old. 4 Do you see that? 5 A. Yes, I do. 6 Q. Okay. SoMM, based upon her 7 knowledge and the interview or the conversation that she 8 had with the FBI and the information they had, have you, 9 mi. anal. all being at least 15 when you first saw 10 Mr. Epstein do you see that, at least what's 11 represented in her sworn statement — 12 MR. EDWARDS: Object to the form. 13 THE WITNESS: Yes, I can see what it says. 14 BY MR. CRITTON: 15 Q. All right. Did the FBI at any time — well, 16 let me — let me ask this question: If the FBI -- if 17 you told the FBI that you were 15 when you first saw 18 Mr. Epstein, based upon this declaration, does that now 19 refresh your recollection that you never went to 20 Mr. Epstein's home for the first time until after you 21 turned 15 which would have been sometime after Mi 22 23 MR. EDWARDS: Object to the form. 24 THE WITNESS: I remember specifically telling 25 than and Jeffrey that I was 14 when I first met Page 144 1 M. and Jane Doe. And then there's a 1 for the 2 footnote. 3 Do you see that? 4 A. Yes. 5 . All • t. And, again, recognizing that 6 is a United States Attorney, and that 7 she's signing this declaration of oath under oath, based 8 on her conversations that she had with the FBI -- at 9 least that's what it purports to say — but go down to 10 Footnote 1. It says: "Attorney Edwards filed this 11 motion on behalf of Jane Doe, without identifying which 12 of his clients is the purported victim." 13 Did I read that correctly? 14 MR. EDWARDS: Object to the form. 15 THE WITNESS: I don't know. 16 BY MR. CRITTON: 17 Q. I want you to follow along. Did I just -- 18 let me read it again. 19 A. Oh, I read it ahead of you. 20 Q. I'm sorry? You're ahead of me? 21 A. Yeah. 22 Q. Okay. Well, then, we'll just — let me go to 23 the second sentence. It says: Accortlin_glyI wil I 24 take --will address facts related toM., M. and 25 Jane Doe. Page 146 1 Jeffrey, and I told him that I was 15. 2 BY MR. CRITTON: 3 Q. Okay. Well, but you would agree with me that 4 at least Miss — the FBI and the US Attorney's Office 5 believed you were 15, based on something that you told 6 them; coned? 7 MR. EDWARDS: Object to the form. 8 THE WITNESS: It looks like that's what they 9 believed. But they obviously misinterpreted what! 10 told them, because I know what I told them. 11 BY MR. CRITTON: 12 Q. Would you agree with me that your 13 recollection back in 2000 -- May of 2008 was probably 14 better than it is today -- 15 MR. EDWARDS: Neet to the form. 16 BY MR. CRIITON: 17 Q. -- in September of 2009? 18 A. What do you mean? 19 Q. Well, would you agree that with another -- 20 let's see — with another 16 months having passed since 21 May of 2008, that your recollection as to the events 22 involving Mr. Epstein were better back in 2008 than they 23 are now? 24 MR. EDWARDS: Object to the form. 25 THE WITNESS: No. 5 (Pages 143 to 146) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1652) (561) 832-7506 4f15158d-6c22.4c50-b036-e423618c21b5 EFTA00750744 Page 147 1 BY MR. CRITTON: 2 Q. Okay. You think your recollection is better 3 now? 4 A. No, I think it's pretty much the same. 5 Q. All right. You told me the FBI well, let 6 me strike that. 7 You said you told the FBI how you came to be 8 at Mr. Epstein's the first time; correct? 9 A. Yes. 10 Q. doiaLin response to their question, you told 11 them than. took you; correct? 12 A. Yes. Yes. 13 Q. How many times did — did you go or 14 take you to Jeffrey Epstein's home? 15 A. One. 16 Q. Just the first time? 17 A. Yes. 18 Q. And what dia. tell you about -- well, let 19 me strike that. 20 You were friends within.? 21 A. Yes. 22 Q. And you say it was, at least your 23 recollection today, is it was sometime in February, plus 24 or minus a month, of '03? 25 A. Yes. Page 149 1 Initially acquaintances, but eventually friends? 2 A. Yes. 3 Q. Let's see. 4 would have been there sixth, seventh and eighth? 5 A. No. I went there for sixth grade, and I 6 moved in seventh grade. 7 Q. Dice stay there? 8 A. I don't know. 9 Q. Where did u o for seventh grade? 10 A. 11 Q. Is that because you moved locations where you 12 were living? 13 A. Yes. 14 Q. Okay. And in sixth grade you would have 15 been — lets see -- sixth grade you would have been how 16 old? 17 A. Eleven. 18 Q. Who were you living with — who were you 19 living with when ou went to 20 A. 21 Q. 22 A. Yes. 23 . O . Who were you living with when you went 24 25 A. I was in between Page 148 1 Q. All right. When you went the first time — 2 or before ou went the first time, how long had you 3 4 A. About three years. 5 Q. And did you meet — how did you meet..? 6 A. I met her in the sixth grade at school. 7 Q. Was she in your class? 8 A. No. 9 Q. Is she older or younger, same age? 10 A. I think she's a little bit younger, but she's 11 about the same age. 12 Q. You mean within a couple of months of one 13 another? 14 A. Yes. 15 Q. How tut..., by the sixth grade did you 16 already know...? 17 A. No. 18 Q. So.. was the first person you knew? 19 A. Yes. 20 Q. What school was that? 21 A. 22 Q. ou were in same si 23 different classes? 24 A. Yes. 25 Q. Did you know — and you became friends? 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 150 mother. Q. Is this during the time that is — between the sixth and the seventh grade, is this the time that MR EDWARDS: Object to the form. THE WITNESS: It was summer before seventh tirade BY MR. CRITION: Q. Is that the reason that you were no longer wit at that point in time, and why you went to A. Yes. Q. Did you stay in touch withMI.? A. No. I (561) 832-7500 6 (Pages 147 to 150) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601433-772-1562) Electronically signed by Pamela Sullivan (601-333-772-1662) 4t15158d-6c22-4c50-b0364423618c2tb5 EFTA00750745 Page 151 1 Q. When you were in sixth grade, did you and 2 used to play together? 3 A. No. 4 Q. Did you -- you just knew each other from 5 school? 6 A. Yes. 7 Q. Did you ever meetEL's mom? 8 A. No. 9 Q. Have you ever met..'s mom? 10 A. No. 11 Q. Hasa. ever talked to you about her morn? 12 A. No. 13 Q. Has anyone ever told you thatle.'s mom is a 14 prostitute? 15 A. No. 16 MR. EDWARDS: Object to the form. 17 BY MR. CRITTON: 18 Q. Have you heard that before today, that..'s 19 mother was a prostitute? 20 A. No. 21 Q. Did you see . during your seventh grade at 22 all? 23 A. No. 24 Q. How about eighth grade? 25 A. We were living close to each other, so I met Page 153 1 A. No. 2 Q. -- legal or illegal? 3 A. No. 4 Q. Prescription drugs that — although they 5 weren't your prescription? 6 A. No. 7 Q. Were you aware that.. was doing drugs -- 8 A. No. 9 Q. — or alcohol back at that poim in time in 10 sixth, seventh and eighth -- sixth and seventh grade? 11 A. No. 12 Q. How about eighth grade, were you — had you 13 started drinking by the time you had hit eighth grade? 14 MR. EDWARDS: Object to the form. 15 BY MR. CRITPON: 16 Q. By drinking, I mean alcohol. 17 A. I —1 had probably had a drink at some 18 point. 19 Q. And had you started doing drugs by the time 20 you were in the eighth grade, illegal drugs? 21 MR. EDWARDS: Object to the form. 22 THE WITNESS: Yes. 23 BY MR. CRITTON: 24 Q. All right. And what had you started? 25 Smoking pot? Page 152 1 her again, yes. 2 th grade, were you still at 3 4 A. Yes. 5 Q. But you were living closer now toll., so 6 you started hanging out together or were friendly, 7 became friends again? 8 A. We hung out once in a while, not a whole lot. 9 Q. And I think you said you never have been to 10 M.'s house? 11 A. No, I had never — 12 Q. Back at that point in time. 13 A. No. 10 Q. Okay. Had she ever been — had you ever 15 brought her over to your house or your grandmother's 16 house or wherever you were living at the time? 17 A. Yes. 18 Q. And this would have been in what, in eighth 19 grade now we're talking about? 20 A. Yes. 21 Q. Okay. When you were in sixth grade and 22 around.., did you and IS ever drink alcohol 23 together? 24 A N 25 Q. Did you ever do any kind of drugs together — racc 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 154 A. Yes. Q. All right. How about the Ecstasy, the one Ecstasy that you say you took, was that back in the eighth Veda MR. EDWARDS: Object to the form. THE WITNESS: I was either 13 or 14. BY MR. CAPTION: Q. So at least before you met Mr. Epstein, you had at least done — you were drinking alcohol, you were using pot, and you had had Ecstasy; true? MR. EDWARDS: Object to the fonn. THE WITNESS: Yes. BY MR. CRITTON: Q. And had you also had Xanax by age 12,13, 14? A. No. Q. Did you ever smoke pot with.? And Pm talking eighth grade. A Probably. Q. And how about Ecstasy, were you or. — well, let me strike that. Had you ever taken Ecstasy when.. was around? A. No. Q. Okay. Who were you with when you had the Ecstasy? (561) 832-7500 PROSE COURT REPORTING AGENCY, 7 (Pages 151 to 154) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 4,15158d-6c22-4c50-b036-e423618c211,5 EFTA00750746 1 2 O. Who? 3 4 5 6 A. I was with an old friend. Page 155 8 Q. Is she a friend of yours? 9 A. [haven't seen her or spoken to her in a few 10 years. 11 Q. Did she used to live out -- or in the area 12 that you did? 13 A. Yes. 14 Q. Is she older, younger, or same age? 15 A. Well, she went to the same school. We were 16 the same age. She was — she's a little bit younger, a 17 few months. 18 Q. Okay. And when you would smoke pot, who did 19 you get that non? 20 MR. EDWARDS: Object to the form. 2/ THE WITNESS: I don't know. 22 BY MR CR11TON: 23 Q. Okay. Did you ever get it from your 24 grandmother? 25 A. No. Page 157 1 A. She was friends with my friend. 2 Q. She being who? a? 3 A. Iff. was friends with my friendM, and 4 that's howl met her. 5 6 A. Yes. 7 Q. What age? Q. So you mean. through..? 8 A. Thirteen or 14, ma I'm not positive. 9 Q. And did you . hit it off right away, 10 once you met through 11 A. No, we did not. 12 Q Did you ever smoke pot with. back at that 13 time? Because she was using drugs, too; wasn't she? 14 MR. EDWARDS: Object to the form. 15 THE WITNESS: I don't know what she was 16 doing. 17 BY MR. CRITIC:1N: 18 Q Okay. Are you saying she wasn't using drugs, 19 or you just don't know, one way or the other? 20 A. I just don't know. 21 Q. But you've used illegal drugs within.; 22 haven't you - 23 MR. EDWARDS: Object to the form. 24 BY MR. CRITTON: 25 Q. - from the time you met her? Page 156 1 Q. Okay. Did you ever smoke pot in your 2 grandmother's house? 3 A. Probably. 4 Q. Okay. Was she aware that you were smoking 5 pot? 6 A. No. 7 Q. in., after -- during eighth grade continued a to be friends? 9 A. Yes. 10 Q. Okay. When you say you went to Epstein's 11 house for the first time, what grade were you in? 12 A. 1 was in eighth grade for the second time. 13 Q. You repeated eighth grade? 14 A. Yes. 15 Q. So ou would have still been at — at that 16 time at 17 A. In the middle of that year I believe I left 18 that school and went to an all girls school. 19 Q Was that la 20 A. Yes. 21 _9. But you were still — you would still see 22 IN. front time to time? 23 A. Yes. 24 Q. Okay. Was was., around this time, as 25 well? Were you friends now with? (561) 8 3 2-7 5 0 0 Page 158 1 A. Yes, 2 Q Now, when you first mail, where was she 3 living? 4 A. She was living with her mom in — 5 Q. Do you know what her mom's name is? 6 A. Eva. 7 Q. Did you ever go ova to.'s house, back at 8 that time period — 9 A. I - 10 Q. - seventh, eighth, ninth grade? 11 A. I went outside her house once. I — I had 12 never been inside of her house. 13 Q. But you met her mom? 14 A. No. 15 Q. You never met her mom? 16 A. I have met her mom, but at that point, no. 17 Q. Okay. Did you meet her mom after this 18 lawsuit has been filed? 19 A. No. 20 Q. Did you meet her at what point in time? 21 A. I met her when I worked at 22 Q. Did she come in as a -- was she a waitress 23 there, or did she — 24 A. She worked there. 25 Q. Did she help you get your job? 8 (Pages 155 to 158) 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) 4.16168d4c22-4c5043038-6423118c2lb5 EFTA00750747 Page 159 1 A. Yes. 2 Q. And was that when you were living within.? 3 A. Yes. 4 Q. Okay. That was when were living with 5 at the apartment with MI? 6 A. Yes. 7 Q. And when — was there & A t else living 8 there at that apartment with you, andM. during 9 that few months that you were there in 2006? 10 A. No. 11 Q. And that's when you met mom — mum -- 12 mother? I'm sorry. 13 MR. EDWARDS: Foam 14 THE WITNESS: Yes. 15 BY MR. CRITTON: 16 Q. And did.. say, you need to get a job, you 17 know, why not -- maybe my mom can help you get a job at 18 IHOP? 19 A. No. I expressed to her that I wanted a job. 20 Q. Had you had a job before that point in time? 21 A. Not really a real job. I had — I had a job, 22 but I — I like went there for a week, and stopped. 23 Q. And that was where? 24 A. 'worked for named 25 Q. Who is IMMI? 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 161 and you were hanging out with..? MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. You were friends — were friends within.? MR. EDWARDS: Object to the form. THE ‘VITNES.S. Yes. BY MR. CRITTON: Q. And at that time that . first approached you, were you aware that been to Mr. Epstein's home? A. I didn't know fora fact, no. Q. I'm sorry? A. II did not know fora fact. Q. And what did — what did.. tell you? A. About going to left E in's house. Q. What did — what did . raise with you? That is how did the — before . ever told you or asked you whether you'd be interested in to Mr. Epstein's home, did she -- that is M. — were you aware that she had been to Mr. Epstein's home? That is had she talked about it amongst you all? MR. EDWARDS: Object to the form. THE WITNESS: I had heard about it, not from . whether or notill. had 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. He is an auctioneer. He is my uncles friend. home? A. No. Q. Another uncle? A. Yes. Q. Another brother of Mr.MIT A. Yes. Q. What's his name? A. Q. Is his first name? A. Yes. Q. What's his last name? A. Q. They - looks like there's a — was it a Page 160 The uncle who drove you to Mr. Epstein's A. Yes. Q. A and__, but they're — are they like stepbrothers with your dad? A. My dad was a first born. He has a different father. Q. All right. So I think you told me you would have been at Mr. Epstein's house you would have been in the eighth grade for the first time, eighth grade, Page 162 1 BY MR. CRITTON: 2 Q. What had you heard and from whom? 3 A. I don't remember who exactly it was. It may 4 have been..'s boyfriend at the time. 5 Q. Which boyfriend would that have been? 6 A. I don't know. I think probably her baby's 7 Either. 8 Q. ENNia? 9 A. Yes. 10 Q. Did you lmow MEM 11 A. Yes. 12 13 with . . Did you ever have sexual relationship 14 A. No. 15 Q. Did you ever have one with Ma? 16 MR. EDWARDS: Object to the form. Fm 17 instructing the witness not to answer, invoking her 18 privacy rights, privacy rights of third parties. 19 MR. CRITTON: Well, let me just do something 20 so we can get this on the record. 21 Is — lame have marked as Exhibit where 22 are we — 5. 23 (Discussion held off the record.) 24 MR. CRITTON: Four was the declaration of 25 Marie Villafana. (561) 832-7500 9 (Pages 159 to 162) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-3334724662) Electronically signed by Pamela Sullivan (501-333472-1662) 4115158d-6c22-4c50-b036-e423618c2035 EFTA00750748 Page 163 1 This is going to be marked as Exhibit 5. 2 (Discussion held off the record.) 3 (Defendants Exhibit No. 5 was marked for 4 identification.) 5 BY MR. CFUTTON: 6 Q. Exhibit 5 is the order that Judge Johnson 7 entered on September 4,2009, in the consolidated case 8 that dealt specifically with Mr. Epstein's emergency 9 motion for independent medical exam, and it was directed 10 to Mr. Ifill's client, 11 Within — within that order, on Page 2 she 12 says — or dealt with questions that could be asked, the 13 scope of the exam. But Judge Johnson — 14 MR. CHINON: And I just want to put this on 15 the record, and then we can move on, if your 16 instruction is the same, Brad. 17 But she talks about it in the first paragraph 18 on the second page, first full paragraph. She, 19 Judge Johnson, who's dealing with a discovery 20 issue, says, the remaining issues involve 21 Plaintiffs request for an order limiting the scope 22 of the proposed examination by disallowing repeated 23 questioning regarding, quote, highly sensitive 24 areas of inquiry, including Plaintiffs medical 25 history, psychiatric history, sexual history, 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 1 2 3 4 5 7 9 0 2 3 4 5 6 7 6 0 1 2 3 4 5 Page 165 support her novel position that the Plaintiff who puts her mental, emotional and psychiatric state at issue can place a limitation on the number of times defense counsel, or agents retained by him, can inquire into areas relevant to these 'Min where the subject matter involved is highly personal, embarrassing, sensitive or otherwise humiliating. Plaintiff is seeking millions of dollars in personal injury damages for, among other things, physical injury, pain and suffering, emotional distress, psychological, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity and invasion of her privacy. And she on to describe at least specifically to And then the last two sections I want to just put on the record is on the first — first MI paragraph on Page 4. It says: Under these circumstances, where Plaintiff — MR. EDWARDS: Circumstances of-., that's what we're talking about; right? MR. CIUTTON: Right. Under these circumstances — MR. EDWARDS: Yes. MR. CRITTON: — where Plaintiff is seeking Page 164 1 social history, sexual abuse history, substance 2 abuse history, et cetera, and imposing certain time 3 restraints on the examination itself And the Court goes on to deny — the 5 Plaintiffs request to limit the scope of the 6 examination is denied. 7 And if you go over on Page 3, Judge Johnson 8 says: Presumably, Plaintiff—and there was a -- 9 there was a questionnaire that was being referenced 10 then — she says: Presumably, Plaintiff, who in 11 this instance to this older was-., but it 12 applies to every Federal court Plaintiff, will be 13 asked these questions two or more times, first by 14 defense counsel at And/tone's deposition scheduled 15 to take place shortly, and again by Dr. Hall at the 16 upcoming examination. 17 And then she goes on to say that Plaintiffs 18 objection is that, by having to answer these same 19 questions about the same subject matter three 20 separate times would only serve to embarrass, 21 humiliate, intimidate and further victimize the 22 Plaintiff. 23 She - she - Judge Johnson goes on to say at 24 the next full paragraph: Plaintiffs site no case 25 law, and independent research has uncovered none to 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 Page 166 1 to recover medical expenses associated with these 2 complex medical issues, full knowledge of the 3 Plaintiffs past and present medical, 4 psychological, familial, social histories is 5 essential. And while neither a duplication nor 6 embarrassment is desired, under the circumstances 7 presented, where the number and the scope of 8 damages claimed are vast and the Plaintiffs past 9 history eventful, it may nonetheless be 0 unavoidable. 1 And then she goes: This is not to say that 2 the restrictions on the scope of the questions may 3 never be put into effect, and if the case 4 progresses, and Plaintiff can show that Defendant's 5 invasive questioning is being done in bad faith or 6 for purposes of harassment, the Court may 7 reconsider imposing limitations of the sort 8 requested herein. 9 At this point however, the Court agrees with Defendant that to restrict the number of times 1 defense counsel may ask the Plaintiff personal and 2 sensitive questions concerning some of the pivotal 3 issues in this case would work an injustice by 4 preventing Defendant from being able to defend 5 himself. (561) 832-7500 SALL.N.a..“*.erIbLenf 10 (Pages 163 to 166) 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) 4115158d-t3c22-4c50-b036-e423618c2145 EFTA00750749 Page 167 1 So I don't know ;whether you have seen this 2 order — 3 MR. EDWARDS: Yeah. Well,1— I haven't 4 seen it, but having read that, it certainly doesn't 5 change my position. Ifs clearly talking about a 6 different Plaintiff different set of 7 circumstances. And very seldom, if ever, does it talk about issues regarding the names of sexual 9 partners, sexual positions or sexual activity. It 10 talks about other things that I have let you 11 conduct your examination on. So... 12 MR. HILL: And the other thing is, is I filed 13 the motion so, to be included in this record, the 14 scope of the relief that I was seeking, the motion 15 for protective order. The motion to limit the Chit 16 was regarding repeated questioning in the same 17 areas of inquiry. Nothing about that motion for 18 protective order sought to prevent discussion about 19 past sexual history at all. It was to the number 20 of times it could be disclosed and discussed. 21 So to suggest that that is somehow a ruling 22 that everything is open game is not entirely 23 consistent with the relief that I was seeking in 24 that motion. 25 MR. EDWARDS: So if you want to make this an 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 169 MR. EDWARDS: If it relates to sexual partners' names or sexual positions and things that are obviously intended only to humiliate, yes, that's going to be my objection. MR. CAPTION: Now, Pam, if I could get you to go back to the question I asked. So long, Adam. (Whereupon, Mr. Horowitz left the proceedings.) (Whereupon, the requested portion of the record was read aloud by the Court Reporter.) MR. CRITTON: Let me be clear on the question. Let me see the question preceding. COURT REPORTER: This is the preceding question... (Whereupon, the requested portion of the record was read aloud by the Court Reporter.) BY MR. CRITTON: Q. All right. Let me just ask the question so it is clear: Did you ever have a sexual relationship with MR. EDWARDS: And Pm instructing the witness not to answer, based on her own privacy rights, as well as the privacy rights of third-party, innocent persons. Page 168 1 exhibit, you can. 2 MR. CRITTON: I'm just saying -- 3 MR. EDWARDS: It certainly doesn't change my 4 position. 5 MR. CRITTON: All right. And I'm just saying 6 this is — we're going to come — I will certainty 7 ask the Court for relief - 8 MR. EDWARDS: Sure. 9 MR. CRITTON: -- for sanctions and the costs 10 and fees related to that. 11 ljust wanted to give you the opportunity to 12 read the order and what she said about defense 13 counsel asking repeated questions about these areas 14 or the number of times that they'll be asked, not 15 only by defense counsel — 16 MR. EDWARDS: It sounds like - 17 MR. CRITTON: -- but as well by the doctor. 18 So I think ifs an appropriate area. You can 19 still stay with your same instructions. 20 MR. EDWARDS: Yeah, it sounds like you can 21 ask it as many tunes as you want 22 MR. CRITTON: And you'll continue to object. 23 MR. EDWARDS: Well, it depends on the 24 question. 25 MR. CRITTON: All right. 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 170 BY MR. CRITTON: Q. Were you aware that has — as of today, are you aware that at some i n kai mo n time she had a sexual relationship with A. No. Q. Are you aware Matter...extra' relatio mi st not only with , but as well MR. CRITTON: Did I say..? Did I say — MR. EDWARDS: Well, you just asked the same question twice. BY MR. CRITTON: Q. Right. Are aware that .1 11e. lexual SI ! did..., with both and A. 1 }mew that-, had dated before did. Q. Okay. Were you aware that she had a — had sexual activity, both with — or with A. No. Q. Did she tell you that? A. Yes. SI sisold she had had sexual relationship with A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, 11 (Pages 167 to 170) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4f1S158d•Sc22-4c50-b036-e42361/1c2fb5 EFTA00750750 1 2 . 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 Page 171 Q. Did she tell — did she, la as well tell you she had a sexual relationship or had sexual activity with Mara A. No. Q. Did you ever tell 1 M whether you had sexual activity with a A. No. Q. Did you ever tell whether you had a sexual relationship with A. No. Q. Now back to how you I Mr. Epstein. I think ou said theat lial. who was the father of IM's son? A. Yes. Q. And his name is Mt A. as son? Q. Yes. A. No. Q. What's his name? A. C.M. Ili I'm sorry. 22 COURT REPORTER: Spell? 23 BY MR. CRITTON: 24 25 Q. Sl A. ed? Page 173 1 atiSo if a l has testified under oath that 2 dn't care and just said, bring home the bacon, 3 that would be a surprise to you? 4 MR EDWARDS: Object to the form. 5 THE WITNESS: 't really care whether 6 wanted her to go or not. That's none of my 7 business. 8 BY MR. CRITTON: 9 Q. And that was not my question. So I'm going 10 to ask Pamela to read it back to you, and if you could 11 answer my question, please. 12 (Whereupon, the requested portion of the 13 record was read aloud by the Court Reporter.) 14 BY MR. CRITTON: 15 Q. Latae rephrase it, then. 16 If 1M has testi under oath that 17 said, being aware that I= was getting moat this 18 old guy in Pikgpeach, that his response -- 19 response to SE was, I don't care, just bring home the 20 bacon, that — 21 A. Well, I'm sure -- 22 Q. Let me finish the question. 23 — that would be a surprise to you, based 24 least what you —your impression is from 25 is that correct? Page 172 1 COURT REPORTER: And OM 2 THE WITNESS: I w his last name — 3 MR. CRITTON: I believe. 4 That's how I've seen it answered in 5 interrogatories. 6 BY MR. CRITTON: 7 Q. What did you hear from or what did - 8 what was saying about Mr. Epstein? 9 A. That was seeing some old guy, who was 10 paying her et= 11 Q. And ME, did he think that was a good idea 12 because she was getting money? 13 MR. EDWARDS: Object to the font 14 BY MR. CRITTON: 15 Q. 11/hat did he say? 16 A. I think was probably upset %batk 17 Q. And what makskyou believe that OM may 18 have been upset about going — or seeing some old 19 guy, as you — as he described it to you, who was paying 20 her money? What did he say? 21 A. Idol* remember exactly what he said. I'm 22 sure that he wasn't happy about it, though. 23 Q. What — what makes you believe that? 24 A. Because they were living together, and they 25 were, I guess, in a relationship. Page 174 1 MR. EDWARDS: Object to the form. 2 THE WITNESS: I don't know. 3 BY MR. CRITTON: 4 Q. All right. You might not be surprised one 5 way or the other; true? 6 MR. EDWARDS: Object to the form. 7 THE WITNESS: Yeah, that's true. 8 BY MR. 9 Q. Was working at that time? 10 A. I don't know. 11 Q. How old was at the time th e 12 was — he was having a relationship with M I ? And I 13 guess you both -- if I understood, she probably was in 14 the ninth grade, because you were doing the second year 15 of eighth grade; correct? 16 A. I diggliwww. 17 Q. Is older, younger? 18 A. I don't know how old — 19 Q. Were they — 20 A. —he is. 21 Q. Were they living together? 22 A. Yes. 23 Q. Where were they living together? 24 A. I don't know. Ina trailer. 25 Q. And how long had they been living together? (561) 832-7500 12 (Pages 171 to 174) 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) 0151884(0.22465041036442X418c:db5 EFTA00750751 Page 175 1 A. I don't know. 2 Had you gone over and stayed -- or gone 3 to MM. and I= trailer and stayed — stayed there, 4 partied with them? 5 A. No. 6 Q. Hung out? 7 A. I had gone there before, yes. 8 Q. Okay. When was there? 9 A. Yes. 10 Q. How many months before that you — before 11 that you first went to Epstein's? Had they been living 12 together a number of months? 13 A. I don't know. 14 Q. Okay. How long before had you been to 15 their — before said something to you about IS 16 going over to — that some old guy was paying her? Was 17 that at least a month or two? 18 A. I don't know. 19 Q. Okay. Did they continue to live together for 20 a number of months? 21 A I don't know how long they lived together. 22 Q. How many times did you ever go to their 23 tails's.? 24 A. Two. 25 Q. And did... ever go with you? 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 177 THE WITNESS: I didn't look into it. BY MR. CRITTON: Q. I'm sorry? A. I didn't look into it. Q. Well, wby did even mention it to you? MR. EDWARDS: Object to the form. THE WITNESS: I don't know. BY MR. CRITTON: Q. Did he tell you how much money she was getting? A. No. Q. Did he tell you what she was doing with hirn — A. Q. A. was? A. No. Q. Did he tell you where the guy was — A No. Q. — or where he lived? A. No. Q. He just said, is getting money from some older guy? No. — for the money? No. Okay. Did she — did he tell you who the guy Page 176 1 A. No. 2 Q. When you went to their trailer on those two 3 occasions, would it be a correct statement that you had both alcohol and smoked pot? 5 A. No. 6 Q. Okay. On either occasion did you smoke pot 7 when you were with and M.? 8 A. Probably on one. 9 _10. OksAnd did you ever have alcohol with 10 and =, as well? 11 A. No. 12 Q. Okay. So tells you.. was getting 13 money from some older guy. Did she — 14 MR. EDWARDS: Object to the form. 15 BY MR. CRITTON: 16 g Is that correct? Before — before.. ever 17 referenced anything to you or said anything to you? 18 A. Yes. 19 Q. Okay. And when he said — when told 20 you that, was anybody else present? 21 A. I don't know. 22 Q. What was your reaction-- well, let me ask 23 you this: What did — did you say, well, what do 24 you mean she's getting money from an older guy? 25 MR. EDWARDS: Object to the form Page 178 1 A. Yes. 2 Q. Okay. And what did you interpret that in 3 your own mind to mean? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't know. 6 BY MR. CRITTON: 7 Q. Okay. Did you - did you wonder why.. was 8 being paid money by some person just to go to his house? 9 MR. EDWARDS: Object to the form. 10 THE WTINESS: Sure I wondered, but I didn't 11 at 12 BY MR. CRITTON: 13 Q. Had - to your knowledge, hadll. ever 14 received money from men for doing things, whatever those 15 things might be? 16 MR. EDWARDS: Object to the form. 17 THE WITNESS: I don't know. 18 BY MR. CRITTON: 19 Q. Okay. She may have; she may not. You just 20 don't know, at least at that point in time; right? 21 MR. EDWARDS: Object to the form. 22 THE WITNESS: I don't know. 23 BY MR. CRITTON: 24 Q. That's what I'm Listen to my 25 question. As of the time that raised the issue (561) 8 3 2 -7 5 0 0 13 (Pages 175 to 178) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772-1652) Electronically signed by Pamela Sullivan (501-333-T/2-1552) 4f15158d-6c22.4c50-b036-e423618c2fb5 EFTA00750752 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 179 with you, before you went to Mr. Epstein's the first time, that was getting some money from some old guy, do you do you have any knowledge whether she had ever received money from a young person or an old person for doing anything? A. No. Q. Was anybody else present when MI said that to you? A. I don't know. Q. Well, when's the next time — how much — how much time passed before again the issue of fl getting money for — from some older man — MR. EDWARDS: Object to the fbnn. BY MR. CRITTON: Q. — came up again? A. 1 don't know if it did. O. Oka . Did you tell the FRI that had mentioned that was getting money from an older guy? A. Na Q. Okay. You're tell —just telling us that now? MR. EDWARDS: Object to the form. THE MINIMS: Yes. 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. A. Q. A. Q. A. Q• A. Q. A. Q. Okay. You said there were two lawyers, but whatever the card said was who they were? MR. EDWARDS: Object to the form. THE WITNESS: Yes. BY MR. CRITTON: Q. How much time did they spend with you? A. I don't know. Q. More than five minutes? A. I don't 'mow. Q. More than an hour? A. I don't know. Q. Okay. So you can't you said two individuals who — who were there on behalf of Mr. Epstein met with you, talked with you. You don't know — you can't tell me the date or even the year, Page 181 Do you remember when that was? No. Did they give you cards? Yes. Do you still have those cards? No. What did you do with those cards? I don't know. Did you ever turn them over to Mr. Edwards? I don't think so. Page 180 1 BY MR. CRITTON: 2 Q. By the way, have you ever given any 3 statements to anyone else? Anybody else ask you about 4 Epstein at any lime? 5 MR. EDWARDS: Objection. Don't answer. 6 Attorney-client privilege. 7 BY MR. CRITTON: 8 Q. Well, except and I when I ask questions 9 Illce that — and Brad will still make his objections, 10 which will remind me — I'm not interested whether 11 some — Mr. Edwards or someone from his office asked 12 you. You know, I'm — Fm confident that he interviewed 13 you or someone from his office interviewed you. So 14 separate that. 15 Have you ever given any other statements, 16 either in writing, orally, by tape, by stenographer, to 17 any other person, other than the FBI, and talked about 18 Epstein? 19 A. Yes. 20 Q. lowborn? 21 A. I spoke to two lawyers who came to my house, 22 which apparently represented Jeffrey Epstein at the 23 time. 24 Q. On just one occasion? 25 A. Yes. 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 182 1 comet? 2 A. Yes. 3 Q. Okay. That's -- and you can't tell me how 4 long you spoke with then; whether it was five minutes or 5 three hours; correct? 6 A. It wasn't very long. 7 Q. Five to ten minutes? 8 A. Maybe. 9 Q. Did they take any notes? A. I don't know. Q. Did they record a statement from you at all? A. No. Q. Did you tell them the truth? A. I don't know. Q. Okay. Are you in the habit of lying to people? MR. EDWARDS: Object to the fonn. THE WITNESS: Na BY MR. CRITTON: Q. You have lied before, though, in a court proceeding; have you not? A. Yes, I have. Q. All right. And, in fact, in your father's proceedings that involved the charges that were brought against your father for killing is you gave a (561) 832-7500 14 (Pages 179 to 182) 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) 41161584602-4e50-b03644236180fb5 EFTA00750753 Page 183 1 number of conflicting statements — 2 A. Yes. 3 Q. — not only in deposition, but as well in 4 court; true? 5 A. Yes. 6 Q. Okay. And you admitted that in those court 7 proceedings you lied on a number of those statements; 8 true? 9 MR. EDWARDS: Object to the form. 10 THE WITNESS: Yes. 11 BY MR. CRITTON: 12 Q. And you lied to either help your father or to 13 help your mother, depending on which side you were 14 taking on a particular occasion; correct? 15 A. Yes. 16 Q. Other than the statement that you gave to 17 these two individuals on behalf of Mr. Epstein and the 18 FBI, separate and apart from your lawyers, are those the 19 only two statements that you've ever given about any 20 facts or circumstances relating to your visits to 21 Mr. Epstein's home? 22 A. No. 23 Q. Who else have you given a statement to? 24 A. A therapist. 25 Q. Did she take a recorded state — is 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 185 MR. EDWARDS: Object to the form. THE WITNESS: Yes. BY MR. CRITTON: Q. Something like that? A. Yes. Q. Did you inquire and say, well, what's she doing to get money? A. Na Q. Okay. Did you have a job at the time? A. Na Q. Well, who supported you back at this time in seventh ei ninth ade? Who supported you? A. Q. Okay. And that'? A. Yes. Q. Donyour —anddidIIIIIIIIIIMrk during that time period? A. Yes. Q. What kind of work did she do? A. She works ale Q. Does she still work there? A. Yes. Q. And does she own the house on A. Yes. Q. Okay. And where you lived on and she had Page 184 1. Randee Speclale? 2 A. Yes. 3 Q. Did — and I assume that's a she? 4 A. Yes. 5 Q. Did she take a recorded statement, or you've 6 just talked about it with her? 7 A. !just talked to her about it- 8 Q. Let's go back to—. So- 9 told you, at some point before you first went, is that 10 I. was doing something with an older man, and she was 11 getting money; right? 12 MR. EDWARDS: Form. 13 THE WITNESS: Yes. 14 BY MR. CRITTON: 15 Q. Okay. Did he tell you how much money she was 16 getting? 17 A. No. 18 Q. And as to why he told you, do you know why he 19 told you? That is, it just came out of the air, hey, 20 M.'s making money from some old man, and he's paying 21 her money? 22 A. 1think I went to his house at one point when 23 she wasn't there and asked him where she was. 24 Q. Oh, and he said, she's over at some older 25 guys house, and he's paying her money? Page 186 1 scar? 2 A. Yes. 3 Q. And what does she do fo 4 A. She's a manager. 5 Q. is she the G the general manager of the 6 store, or manager of a department? 7 A. Pm not positive. 8 Q. How long has she worked for ? 9 A. I think 11 years. I'm not sum exactly, 10 though. 11 Q. And the house that you lived in or that 12 you were living at the time on how many 13 bedrooms is it? 14 A. Three. 15 Q. Okay. And did you have your own room? 16 A. Yes. 17 Q. Did you share a bathroom, or did you have 18 your own bathroom? 19 A. !have my own bathroom. 20 Q. And did andi, that is your 21 grandmother, did she, if you wanted, if you needed a new 22 pair of shoes, if you needed clothes, would she help you 23 get those? 24 A. When 1 was living her — with her, yes, she 25 did. 15 (Pages 183 to 186) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (501.333.772-1552) Electronically signed by Pamela Sullivan (501.333-772.1552) (561) 832-7506 4f151584-6c22-4c50-b036-0423618c2fla5 EFTA00750754 Page 187 1 Q. So she had a home, so you had shelter, you 2 had -- you had clothing, and — and I assume she fed 3 you. I mean, she bought the groceries so that you all 4 could eat? 5 A. When I was living with ha, yes. 6 Q. And she — she, as well, would you help her 7 do grocery shopping from time to time? 8 A. Yes. 9 Q. And would you help her with the cooking and 10 whatever other ou know 1 • f like a typical person, 11 , you helped with 12 chores around the house, or did you not? 13 MR EDWARDS: Form. 14 THE WITNESS: Yes. 15 BY MR. CRITTON: 16 Q. Okay. You did help? 17 A. Yes. 18 Q. And did she give you an allowance, as well? 19 A. No. 20 Q. Pardon? 21 A. No. 22 Q. Did she give you some spending money? If you 23 needed to go — if you wanted to go to a movie with your 24 friends or you were going out to dinner with your 25 friends, would she say, you know, here's five or tenor 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 189 And did you ever try to get back to your grandma's house? A. No. — and when you were staying with d her family, did they give you food, shelter, clothing, help you out? A. Yeah. Q. Okay. And did all during that time period? A. No. Q. Did your mother help you at that time period? A. No. Q. But it was your choice to run away from your mother, correct? That is, you made a voluntary choice, I don't want to be with mother anymore? A. Well, yes. But... Q. You — you made — you made a voluntary, knowledgeable decision, I don't want to stay with my m on for circumstances, I want to go to and family took you in? A. Yes. elp you at 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 188 15 bucks so you can go do something? MR. EDWARDS: Form. THE WITNESS: Yes, when I was living with her, she did. BY MR. CRITTON: Q. And did you live with her during that time period, that is eighth — eighth grade -- both eighth grades, ninth and tenth? A. I was living with my mom, and I ran away. Q. Okay. And where hnm when you ran? A. I mr syn friend, Q. nor whatever? I probably missed that, probabl A. Q. Did you — • where you went, to-- we'll call her won't butcher her name — you went to house? A. Yes. Q. And would the family let you stay there? A. Yes. Q. Her family? A. Her mother. Q. Her mother. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 190 Q. Okay. Well, what did you do? Did she provide food? A. Not for me. Q. When you were living with her? A. Yes. Q. Where did you get your food? A. My friends. Q. You mean you would go ova to other people's houses to eat? A. Yes Q. Diallir - I've read somewhere she has drug problems. A. Yes. Q. Okay. And has she been on — had significant drug problems ever since you can your earliest memories of her? A. Yes. Q. All right. And I assume that's been a (561) 832-7500 16 (Pages 187 to 190) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1552) Electronically signed by Pamela Sullivan (501-333-772-1662) 4115158d4c22-400-b036.423618c2fb5 EFTA00750755 Page 191 1 substantial burden on you mentally, emotionally? 2 MR. EDWARDS: Object to the form. 3 THE WITNESS: Tye always had 4 SO no. 5 BY MR. CRITTON: 6 Q. So you don't care — I mean, it — it had no 7 impact on you that your mother -- well, let me strike 8 that. 9 I've seen some places that she's a crack 10 addict, is that true? 11 A. Yes. 12 Q. All right. And would you agree with me that 13 has had an emotional impact on your life? 14 MR. EDWARDS: Object to the form. 15 THE WITNESS: Not really. 16 BY MR. CRITTON: 17 Q. Okay. So the fact that has been 18 a crack addict since you can remember or had significant 19 drug problems since your earliest recollection, it's 20 your testimony to this jury that has had no emotional 21 impact on you or psychological impact on you at all? 22 MR. EDWARDS: Object to the form. 23 BY MR. CRITTON: 24 Q. Is that your testimo 25 A. I've always had so no, not Page 193 1 nonprescription drugs? 2 A. No. 3 Q. Have you ever seen him physically or verbally 4 abuse your mother? 5 A. No. 6 Q. It's your testimony you're unaware of any 7 domestic violence issues associated between Mr. Stand 8 your mother, is that -- 9 A. Yes. 10 Q. Are you closer to your father than you are 11 your mother? 12 A. Yes. 13 Q. Why? 14 A. Probably because of 15 Q. Because 16 father's -- 17 A. Mother. 18 Q. -- mother. Right 19 But you, in fact, saw your father kick and 20 physically abuse alto the point where that young man 21 died in 1999; isn't that true? 22 A. I never saw him kick 23 Q. Okay. So, but you've given -- you gave a 24 statement — we'll get to that later — that you 25 actually saw your father physically abuse. is your Page 192 1 really. I never — 2 Q. I also saw in the records that your father 3 and your mother had a very violent relationship -- 4 A. I've been told — 5 Q. — are you aware of that? 6 A. I've been told that, yes. 7 Q. Okay. And then your mother, with a 8 subsequent on named am I saying that right? 9 A. 10 Q. — they also had a very violent, 11 abusive relationship; are you aware of that? 12 A. No. 13 Q. Did your mother ever tell you about that? 14 A. No. 15 Q. Do you know Mr. al 16 A. Yes. 17 Q. Okay. What's your impression of him? 18 A. I -- 19 MR EDWARDS: Object to the form. 20 THE WITNESS: I don't like him. 21 BY MR. CRITTON: 22 Q. Does he have the same type of druWidcohol 23 problems that your mother has always had? 24 A. I don't know. 25 Q. Have you ever seen him use drugs, and I mean Page 194 1 MR. EDWARDS: You're going to get to it 2 later, or we're going to — or you want her to 3 answer — answer the question? 4 MR CRITTON: No, we're going to get —1 5 want an answer to that now, but I'm going to come 6 back to it later. 7 MR. EDWARDS: thscha. THE WITNESS: Yes, l did see him abuse it 9 BY MR. CRITTON: 10 Q. Okay. And you're awarc that, as a result of 11 his physical abuse to INdied? 12 A. Yes, I am. 13 Q. And that has had a huge psychological and 14 emotional impact on you since you were a young child, up 15 through and including even today, isn't that true? 16 MR. EDWARDS: Penn. 17 THE WITNESS: Yes. 18 BY MR. CRITTON: 19 Q. frn scary? 20 A. Yes. 23. Q. Because your father has been in prison since 22 sometime in, what, '99, one place or another? 23 A. Yes. 24 Q. Has he been able to provide any support for 25 you, or does the support all come from his mother, (561) 832-7500 PROSE COURT REPORTING 17 (Pages 191 to 199) AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1552) Electronically signed by Pamela Sullivan (501.333-772-1552) 41.1515Eld-6c22-4c50-b036-e423618c2ib5 EFTA00750756 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 1.8 19 20 21 22 23 24 25 Page 195 IIIIIII A. Yes, all from — Q. All from grandma — A. Yes. Q. — your grandmother? All right. During the — the second half of your second stint, second year that you took eighth grade in '03, then ninth, tenth grade, you — were you in school in ninth and tenth grade, too? A. No. I went to — I, I didn't go to school because of runnin awe . And so I went to another school called Q. A. Yes. Q. Snell it forme. Q. A. A. Q. A. Is that a public school, or a private school? It's a public school. Where is that located? West Palm Beach. How long were you — what grade was that, and how long were you there? A. 1 was in there for the eighth grade again, Page 197 1. Q. For what? What had you done that brought 2 about you getting sent to ME' 3 MR. EDWARDS: Form. 4 THE WITNESS: I crashed 5 BY MR. CRITTON: 6 Q. cony? 7 A. I crashed car. 8 Q. You were charged, at least initially, with 9 grand theft auto for that; weren't you? 10 A. Yes. 11 Q. And did you do a plea deal as a juvenile? 12 A. No. 13 Q. What happened? 14 A. I was sent to the program. 15 Q. Okay. Did you plead guilty, guilty to having 16 stolen a car? 17 MR. EDWARDS: Object to the form. 18 BY MR. CIUTTON: 19 Q. And then they essentially said, okay, you can 2 0 go to the program, and that will be your sentence? 21 A. I don't know. 22 Q. Did you have an attorney that represented you 2 3 in those proceedings? 24 A. I don't blow. 25 Q. All you know is that you ended up at car. Page 196 1 and I didn't go there for very long, maybe a month. 2 Q. How far did you get in school? 3 A. I only went to the eighth grade, until I got 4 my GED. 5 Q. When did you got your GED? 6 A. When I wen gram for girls. 7 Q. Was that at 8 A. Yes. 9 Q How long were you at 10 A. Five months, one week and three days. 11 Q. Sounds like you have a very good recollection 12 of that. 13 A. Yes. 14 Q. When Is located? 15 A. In Florida. 16 Q. Which is where? 17 A. Which is near 18 Q. I'm so 19 A. Near 20 Q. Where is 21 A. 22 Q. 23 A. 24 Q. 25 A. And were you required to go there? Yes. That's like a sentence? Yes. 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 198 for five months, one week and three days? A. Yes. Q. Give me a time period for that, that is when you were there. A. It was -- I went there in July. Q. Of what year? A. When I was 17. And I — I came out in December, close to — Q. And so that would have been in 05, July of '05? A. I I guess so, if I was 17 in that year. A. I on't now. Q. '05. 1,et me go back to — I'm just trying to figure out where you were living there in the time that — when you went to — when you were -- first went to — say you went to Mia g ein's house, you would have been living with right? A. Yes. is . Okay. How long, then, did you live with . Did you — what years did you live with I lcnow the beginning of '03. At least by '03 you were living with her, January of '03. How long (561) 832-7500 18 (Pages 195 to 198) 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) 4t151513d4c22-4c50-b036-0423618c21b5 EFTA00750757 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 199 did you stay with her? A. I -- I was a =away at that time in '03. Q. You had already run away. You weren't staying with at that point? A. I was with my EM, and I ran away. Q. At the time that u had the conversation with with about a going over and get -- doing something with an older man and getting money, were you already a runaway? A. No. Q. You were living with II=M? A. I was a runaway until my dad's trial. And after that, I was living with I was living with my mother, and then she ut me in a shelter for runaways. And then after that got custody of me, and I lived with her after that. . Do ou Icnow when you lived with= A. I don't know exactly what day it was. Q. Was it before you went — well, I don't need an exact date. Just give me a month and a year. A. I don't remember. Q. Were you living with at the time you were sentenced to A. Yes, I was. 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 201 A. I don't how. Q. A month? A week? A. I don't know. Q. Did you ever — and what did. say to you? A. She told me that she wanted me to go with her to this guy's house and -- pretty much she just told me that she wanted me to go with her, and that I would get money forgo' with her. Q. Did.' tell you how long she had been going? A. No. Q. Did come to your house to tell you this? Were you at the trailer her trailer with A. She came to my house. Q. aliisa iving then with? A. Q. wou it a correct statement that during the entire time you went to Mr. Epstein's house, that period you were always living with= IIIIIMIF A. Yes. Q. And soli said, why don't you come with me. Did she tell you what the man's name was? A. I don't remember if she told me at that. time. 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 200 Q. Okay. How long had you been living with!. know. Q. A year? A. I don't know. I — I don't know. Q. Were you a runaway because you didntt want to testify in your dad's trial? A. I was a runaway because I didn't want to live with my mom. Q. You also didn't want to testify in your dad's trial; did you? A. Yes, I did. Q. Let's go bark to You had the conversation with — with Okay. Whcn is the next time that the issue — any issues involving Mr. Epstein came up - or, or an older man? A. I don't know. (Whereupon, Ms. Cadwell joined the proceedings) MR CRITTON: This is Jessica Cadwell. She's my paralegal. THE WITNESS: I guess not until.. came over to ask me if I would go with her. BY MR. CRITF0N: Q. How much time passed? Page 202 1 Q. What did she tell you she did? Did you say, 2 well, why — why do I want to go there? I mean, she 3 said, !want you to come to the house to meet this older 4 guy, and he'll pay you some money; right? 5 A. Yes. 6 Q. Okay. And what did she tell you? Did you 7 say, well, why? 8 A. That's what she told me. 9 Q. Okay. And what — and did you say, well, why 10 is he going to pay me money? 11. A. No. 12 Q. I mean, you were a street smart girl at that 13 time. You had run away a number of times; you know, you 14 had been in shelters; you had done various programs; you 15 had, you know, a mother who had significant problems; 16 you had a dad who had significant problems. You 17 considered yourself pretty street smart at that point; 18 fair statement? 19 MR. EDWARDS: Object to the form. 20 THE WITNESS: At that point I thought that 21 she was going to pay me for going with her. 22 BY MR. CRITTON: 23 Q. Did she tell you — 24 A. I didn't she didn't tell me she was going 25 to take me to meet somebody. She didn't tellme all of I (561) 832-7500 PROSE COURT REPORTING 19 (Pages 199 to 202) AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772.1552) Electronically signed by Pamela Sullivan (501-333-772-1552) M15158d-6c22-4c50-b036-e423618c2tb5 EFTA00750758 Page 203 1 that. 2 Q. Okay. What did she tell you? She just 3 said - 4 A. Go with me, and you'll get this money. 5 Q And how much did she promise you? 6 A. $200. 7 Q. Okay. And did you say, okay, what do I 8 get what do I have to do for $200, why is somebody 9 going to give me 200 was she going to give you the 10 money, or was somebody else supposed to give you the 11 money? 12 A. I don't know. She just said, go with me, and 13 you'll get the money. That's it. 14 Q. And did she tell you what she had to do? 15 A. No. 16 Q. What you were supposed to do? 17 A. No. 18 Q. You just thought, I go with her, I go over to 19 this person's house, and I get 200 bucks? 20 A. Yes. 21 Q. And you didn't know who was going to give you 22 the 200 bucks; correct? 23 A. I thought that S was going to give it to 24 me. 25 Q. And how did you get well, and did she tell Page 205 1 Q. And what did you talk about on the way over 2 there? 3 A. I don't 'mow. 4 Q. What did you wear? 5 A. 1 don't remember. 6 Q. All right. You got to the house. You went 7 over to the house. Do you remember what the address 8 was? 9 A. No. 10 Q. Do you remember what the house looked like? 11 A. 1— yes. 12 Q. What did it look like from the outside? 13 A. It was a big, pink house. 14 Q. Big, pink house. All right. 15 And as you got there, the cab let you off? 16 A. Yes. 17 Q. Did you pay the cab, or did In pay the cab? 18 A. No. After we walked inside, somebody else 19 went outside and paid the cab. 20 Q. And did you — when you went inside, who did 21 you neat? A man? A woman? 22 A. A woman. 23 Q. Okay. And where did you go where did you 24 enter the house from? 25 A. The kitchen. Page 204 1 you how many — did you say, what do you do when you go 2 over to this house? 3 A. Did I ask her that? 4 Q. Right 5 A. No. 6 Q. Say, where's the house? 7 A. No. 8 Q. Did you., are you getting --what do you 9 get money for, ? 10 A. No, I didn't. 11 Q. Was anybody else present when she -- 12 A. No. 13 Q. Was that the — and when she told you that, 14 is this the first time she had ever asked you? 15 A. Yes. 16 Q. So without asking any questions, you 17 baskally said, okay, I'll go to the house, and I get 18 $200 from you? 19 A. Yes. 20 Q. Did they tell you where the house was? 21 A. No. 22 Q. How did you get there the first time? 23 A. Cab. 24 Q. What cab? 25 A. Yellow Cab. Page 206 1 Q. And what did the kitchen look like — well, 2 let me strike that. 3 Is there a — is there an entrance to the 4 kitchen? 5 A. Yes. 6 Q. Is that around where, in relationship to the 7 house? 8 A. The side of the house on the — 9 Q. Did you ever — oh, I'm sorry. Go ahead. 10 A. It was like right — right off the driveway. 11 like on the side of the house. And it was a, like, 12 whole glass door, like it had some white around. 13 Q. Olcay. And I think it's your testimony that 14 you don't remember what you were wearing? 15 A. I was wearing some pants, probably, and a 16 shirt. I don't know. 17 Q. But you don't remember whether it was long 18 pants or short pants? 19 A. It was long pants. 20 Q. Okay. Do you remember the colon? 21 A. Jeans. 22 Q All right And the top, what kind of top did 23 you have on? 24 A. I don't know. I had Sponge Bob socks on. 25 Q. You're sure? (561) 832-7500 PROSE COURT 20 (Pages 203 to 206) REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4f15158d-6c22.4c50-6036-e423618c2fb5 EFTA00750759 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 207 A. Yeah. Q. Did you have shoes? A. Yeah. Q. What kind of shoes? A. T don't rather. Q. What did 2. have on? A. I don't know. Q. So the door opens, and did you say it was you were greeted by a man or a woman? A. A woman. Q. And did she tell you what her name was? A. I don't remember. Q. Did you ever see her again? A. Yes. Q. Did she ever introduce her — introduce herself, or did you ever come to learn her name? A. The first time that I went there, I believe I had met a blond woman. And I don't think she told me her name at that point, but later I leaned her name was And after I started to go back to J r Epstein's house by myself; I met a woman named MI who I saw ofts.pSere. • Q. Okay. And ..was a blond-headed girl? A. Yes. Q. How about i describe -- 1. how — in 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 209 A. There were stairs behind the door in the kitchen. And then we walked up to the — up the stairs and through a hallway, where there were pictures like on the walls of litre bodies. Then we walked through, I guess, what would be Jeffrey Epstein's bedroom and into the smaller room, whore there was like a shower and a steam room and a massage table and a small couch. Q. Okay. Let me stop you for just a minute. The blond-head as you were walking into the kitchen, says to you can go upstairs? A. Yes. Q. All right. And did you say to I. is, whoa? Why didn't you just say, it's okay, III wait down here? MR. EDWARDS: Form. THE WITNESS: I don't know. She -- she son of lilce waved her hod at me like — BY MR. CRITTON: Q. 1's she? A. Like come on, you know, waved her hand at me. So I just followed her. Q. Why didn't you call over to the side and say, bey, you need to tell me a little bit more. What's going on? Page 208 1 fact, `describe 2 A. She's very thin, withill hair, and she had 3 a thick accent. 4 Q. Again, first time, so the girl that 5 you ultimately identified as EM 6 A. Yes. 7 Q. And you both came into the kitchen area? 8 A. Yes. 9 Q. And describe the kitchen for me. 10 A. . It was like white tile with — with like 11 wood, but it was like really light colored. 12 Q. Wood on tho walls? Wood on the floor? Wood 13 on the cabinets? What are you talking about, wood 14 where? 15 A. On the cabinets, I believe it was. 16 Q. Did you sit in the kitchen at all? 17 A. Not really. I only saw the kitchen for lilen 18 a second and — 19 Q. What did the blond-headed — did the 20 blond-headed woman say an l. yri!? 21 A. She just, l guess, told El. like to go 22 upstairs or whatever. And there was like a door in the 23 kitchen, I think it was, and there were some stairs in 24 there. 25 Q. I'm sorry? Page 210 1 MR. EDWARDS: Form. 2 THE WITNESS: I didn't do that at first, but 3 when we got into the room with him-- 4 BY MR. CRITTON: 5 Q. That's — I want to slay — I want to slay 6 downstairs for a minute, before you ever enter the 7 stairway. Okay? 8 When the blond-headed lady said, okay, 9 Il r -- , okay, you can go upstairs, why didn't you 10 calld aside and say, hey, wait a minute, I need to 11 understand a little bit quawhat's going on here? 12 Because you're saying Ill never told you anything, just 13 that you were going to get 200 bucks; right? 14 A. Yes. 15 Q. Okay. S didn't you say is, wait a 16 minute, what's — MM., what's going on hen? And you, 17 you know, you'd been a runaway, you'd been on -- I don't 18 want to say on the street, but you had certainly been a 19 runaway and had a lot of experiences in your life for 20 a -- for your age - 21 MR. EDWARDS: Object to the form. 22 BY MR. CRITTON: 23 Q. —right? 24 So why didn't you say, t, come on over 25 here? 4 21 (Pages 207 to 210) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (501-333472-1552) Electronically signed by Pamela Sullivan (501333.772-1552) (561) 832-7506 4f1S158d-6c22-4c50.b036-e423618c2fb5 EFTA00750760 Page 211 1 A- I don't know. 2 Q. You just didn't? 3 A. I just didn't. 4 Q. But you could have? 5 MR. EDWARDS: Object to the form. 6 BY MR. CRITTON: 7 Q. Right? 8 A. Sure. 9 Q. Okay. And you could have chosen not to go 10 and never have gotten in the cab within. that day; 11 true? 12 A. Yeah. 13 Q. So you go up the -- you said you went through 14 a door, and then a stairway; correct? 15 A. Yeah I'm pretty sure that there was a door. 16 Q. In order to get into the stairway? 17 A. Yes. And we walked through the hallway — 18 Q. Let me ask you this — oh, I'm sorry. You 19 know, I just want to — I want to work my way up. 20 Did the door to the stairway open toward the 21 stairs, or did it open into the kitchen? 22 A. I don't tem‘mber. 23 Q. Were the stairs carpeted, wood, or some other 24 surface? 25 A. Pm pretty sure they were carpeted. Page 213 1 A. Nude bodies. 2 Q. All right. And all appeared to be adults? 3 A. They were like little pieces of lice a 4 person's body. I couldn't — I don't know. Q. Okay. So you couldn't tell -- they could 6 have been whatever age? I mean, they didn't — but they 7 appeared to be adult peoples bodies in pieces — 8 MR. EDWARDS: Object to the form. 9 BY MR. CRITTON: 10 Q. — is that a fair statement? 11 A. I don't know. 12 Q. Okay. When you say they were adult pieces of 13 bodies, you mean it was — it was almost like a — like 14 a -- like a crossword puzzle — 15 MR. EDWARDS: Object to the form. 16 BY MR. CRITTON: 17 Q. — the pieces? Describe - 18 A. They were like men's and women's bodies. And 19 l don't know if somebody was lace old or young in those 20 pictures. I don't know. 21 Q. But they appeared to be something that you — 22 clearly, where they were art — art photographs? 23 MR. EDWARDS: Object to the fort. 24 BY MR. CRITTON: 25 Q. That is, somebody had worked with those Page 212 Q. Did the — did the stairway have a rail, or 2 was the stairway built into the walls? And when I say 3 that, you know there was a stairway between two walls. 4 A. There was walls next to it. 5 Q. Were - were there any types of photographs 6 or art on the walls? 7 A. Yes, there were pictures of people's bodies. 8 Q. Okay. AM that's what I was trying to figure 9 out where you said bodies, when you said.. 10 Have you ever seen art books before? 11 A. Yes. 12 Q. Okay. Is that what you're talking about; 13 there were like art pictures or photographs of people's 14 bodies in different positions? 15 A. Yes. Yes 16 Q. And the pictures of the — of people's 17 bodies, what did they look like? 18 A. They were like gray and black and whitish. 19 Q. And of -- of the bodies, were they clothed 20 bodies, were they partially clothed bodies, were they — 21 A. They were — 22 Q. — completely clothed bodies? 23 A. They were nude. 24 Q. Okay. The pictures were completely of nude 25 bodies? Page 214 1 pictures to create a certain image? 2 A. I don't know. 3 Q. Pardon? 4 A. I don't know. 5 Q. Well, I asked earlier whether you thought 6 they were art photographs, and you said, yeah? 7 A. Well, there were art books. 8 Q. You mean, where, on the stairway? 9 A. There — there was like a table with some 10 books on it. They looked like art books or something to 11 me. 12 Q. The photographs that you saw of the bodies, 13 describe the size. How many — how many photographs did 14 you see? And this is in the stairway? 15 MR. EDWARDS: Object to the form. 16 THE WITNESS: No, this is after the stairway. 17 BY MR. CRITTON: 18 Q. Okay. Just a minute ago I asked you whether 19 there are any photographs or any pictures as you walked 20 up the stairway, and you said, the bodies, that's where 21 the bodies where. I thought that's what you said. 22 So let me ask it again so I - 2 3 MR. EDWARDS: Form. 24 BY MR. CRITTON: 2 5 Q. Were the photographs -- or the, I'd say, (561) 832-7500 4...•••• 22 (Pages 211 to 214) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-15521 Electronically signed by Pamela Sullivan (501-333-772-1552) 41161 58d4e22-4e60-b0364423618e21b5 EFTA00750761 Page 215 1 white, black and grayish photographs that you saw, were 2 they on the stairway, or were they at the top of the 3 stairs? 4 A. They were at the top of the stairs. 5 Q. All right. So it would be a comet 6 statement that you didn't see any type of art, 7 photographs on the stairway on either side of the wall 8 as you walked up; true? 9 A. I cannot recall -- 10 Q. Okay. 11 A. -- at this -- 12 Q. As you sit here today, would it be a correct 13 statement that the only photographs or art that you 14 recall being on the walls was at the top of the 15 stairway, and not on the walls on the stairway leading 16 up to the top; is that correct? 17 MR. EDWARDS: °Wool to the form. 18 THE VaTNESS: 1 absolutely umiv-Luber them 19 being at the top. I don't remember whether there 20 were anything on the walls in the stairway. 21 BY MR. CRITION: 22 Q. On the photographs or of the art that you saw 23 on the walls when you got to the top of the stairs, when 24 you got to the top of the stairs, did you go to get to 25 Mr. Epstein's, what you thought was his bedroom, did you Page 217 1 Q. Is that his bedroom? 2 A. To the left you would see his bed — like a 3 bed. I don't know if it was his bed. And in front of 4 you, you would see — I think it was like a bookshelf 5 And then to the left of the bookshelf I think there were 6 doors, or they may have been on the side of the bed. I 7 can't remember exactly. 8 Q. Now, before you got into his room, when you 9 get to the top of the stairs you make a right turn; 10 correct? 11 A. Yes. 12 Q. Were there any rooms on the left or the right 13 side before you get to the threshold of his bedroom? 14 A. I don't know. 15 Q. Okay. How many pictures of bodies, art 16 pictures, did you see at the top of the stairs? 17 A. I don't remember. 18 Q. Was there one, or two, or three, or you don't 19 have any recollection? 20 A. I don't remember exactly how many there were. 21 I can remember specifically like two of them. 22 Q. Describe the first picture that you can 23 recall. Tell me exactly what it looked like. 24 A. It looked like this portion of a woman's 25 body. Page 216 1 go to the right or to the left? 2 A. To the right. 3 Q. And did you have to pass any doors before you 4 got into his room? 5 A. Yes. 6 Q. Okay. How many doors were -- were the doors 7 on the left, or the right? 8 A. I'm — I'm pretty sure the doors were like on 9 the far right side. 10 Q. The far right side. So you came up the 11 stairway. When you hit the top of the stairway, you 12 made a right turn, and then there were two -- there was 13 one or two doors that you passed before you got into 14 Mr. Epstein's bedroom? 15 A. There's one door you pass, or you just walk 16 in or whatever. I mean, I don't — I don't remember if 17 we had to go through one or two doors, but it was a 18 single door. And when we walked into his bedroom, like, 19 if you were facing forward, like at his bedroom door, as 20 you were looking — 21 Q. As you're just stepping through the 22 threshold? 23 A. Yes. 24 Q. Okay. You're looking straight ahead? 25 A. Yes. Page 218 1 Q. The hip? You're pointing to the -- your 2 right hip area? 3 A. Yes. 4 Q. Okay. 5 A. Like - 6 Q. And that's all you could see? 7 A. — the side, yes. Q. All right. So that's — 9 A. And — 10 Q. Pm sorry. That was the first picture? 11 A. Yes. 12 Q. And — and it was only basically the woman's 13 hip from, basically, I would say, waist down to her 14 thigh, but you saw only a side view, correct? 15 A. That's one that I can specifically remember. 16 Q. The second picture that you saw, what did 17 that depict? 18 A. A man's body. 19 Q. Okay. And what portions of the man's body 20 did you see? 21 A. The chest area. 22 Q. The chest? 23 A. Yes. 24 Q. And that was the only part that was depicted 25 in the photograph 23 (Pages 215 to 218) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (501-333-772-1652) Electronically signed by Pamela Sullivan (601.333.772-1552) (561) 832-7506 4f15158d-6c22-4c50-b036-e423618c2fb5 EFTA00750762 Page 219 1 A. Yeah. 2 Q. — of the — the art that was on the wall; 3 correct? 4 A. Yes. 5 Q. Okay. And moving fast forward, on all the 6 other occasions that you went to Mr. Epstein's home 7 and I think you said earlier that you at least told the 8 FBI it was approximately 20 — did that artwork on the 9 walls ever change, that is from the bottom of the stairs 10 up until you went through the threshold of his room -- 11 A. I don't know. 12 Q. — or is it always the same? 13 A. I don't know. There were like three 14 different ways to get into that room. 15 Q. Okay. And did you always come up the 16 stairway in the kitchen? 17 A. No. 18 Q. Okay. Did you come up a different way — 19 other ways in the house? 20 A. Yes. 21 Q. Which other ways did you come up in the 22 house? 23 A. !had gone up through the — I guess what 24 would be like that main staircase, which was like after 25 you walk through the kitchen and go to your right, I Page 221 1 A. Yes. 2 Q. Okay. And back to my question was, is: As 3 far as you can recall, the only two photographs of the 4 artwork that you saw were the two that you described to 5 us, during the entire time you ever went to 6 Mr. Epstein's house, at least for the back staircase? 7 A. Those are two things that I can specifically 8 remember. There were other things. I just can't 9 remember specifically what they were. 10 Q. All right. So you get to the top of the 11 stairs the first time, and you're walking towards what 12 afound out later was his bedroom. Did you ever grab 13 M. or say, M, come here, I need to talk to you, 14 you know, what's going on here, I — you need to explain 15 this to me? Did you ever do tat? 16 A. No. 17 Q. Okay. When you went into his bedroom, and 18 then you went — I think you said you went around to the 19 left? 20 A. Uh-huh. 21 Q. Is that correct? 22 A. Yes. 23 Q Okay. And then you went -- went into an area 24 that you said hada — like a steam and a shower and a 25 massage table and a small couch. Was the - the blond Page 220 1 don't know what room it was in, but you would see the 2 staircase. And it had like clear — like on the rail it 3 had like clear things. I don't — I don't remember like 4 if it was all clear, but I remember — 5 Q. Are you talking about rails? 6 A. Yes. 7 Q. All right. And then you —and so you-- 8 your testimony, at least, you came up the kitchen 9 stairs, you came up the — what you described as the 10 main staircase. Any other way that you ever got into 11 the bedroom? 12 A. Yes, there was — there was like a balcony on 13 the side. I mean, I'm not exactly sure where it was, 14 but it WaS like — like in the area where the pool was. 15 And like the balconies, I guess, there was a staircase 16 where you go up. And there's a — I believe there was 17 like a small balcony. And then there was one door on 18 each side of where there would — there was like a sink 19 and like a big counter, where he had a lot of stuff on 20 that counter. And — 21 Q. I don't want to really to get into the — 22 that's fine. I just want — SO you carne up three 23 different ways is what you're telling me? 24 A. Yes. Yes. 25 Q. That's it? Page 222 1 lady there — 2 A. No. 3 Q. whiau later described? And so it was 4 just you and ? 5 A. Yes. 6 Okay. Did you then pull M. aside and say, 7 M., what's going on here? You need to tell me. You 8 know, you said I was going to get 200 bucks. What 9 what's going on? 10 MR. EDWARDS: Object to the form. 11 THE WITNESS: She told me that I was going to 12 meet this guy, and Ifice he was really nice and 13 stuff like that. And she told me like that — I 14 don't know; she just pretty much told me that he 15 was a nice guy. So I just like sat in there with 16 her, and then -- 17 BY MR. CRUTON: 18 Q. Did she sit down on the couch? 19 A. Yes. 20 Q. Okay. And did you just go, well, wait a 21 minute, Tm in here, I'm going to meet a nice guy; who's 22 paying me the 200 bucks? Did you say that to her? 23 A. No. 24 Q. Did you say, why am I getting 5200 to just 2 5 sit here and meet a nice guy? (561) 832-7500 PROSE COURT REPORTING AGENCY, 24 (Pages 219 to 222) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (601-333-772-1552) 4f44188d4k22-4440-b0384423818atbs EFTA00750763 Page 223 1 A. No. 2 Q. Okay. Did you say, I think this is odd, you 3 know, weird; I think I want to get out of here? 4 A. No. 5 Q. Okay. You could have, though; couldn't you? 6 A. I don't know. 7 Q. Well, nobody -- 8 A. I probably could not have found myself out of 9 that house at that time. 10 Q. No, but you could have said., I don't 11 want to stay here, lees — lees go. You could have 12 said that; couldn't you? 13 A. I guess. 14 Q. All right. And you made a voluntary decision 15 from the time that.. said, do you want to go with me, 16 up until the time you were in that room? It was all 17 voluntary. You knew — you knew that had made a — IS or you have made decision to go with. to get 200 19 bucks, and there you were in the room, you and.; 20 correct? 21 A. Yes. 22 Q. All right. What happened next? 23 A. Jeffrey walked in and -- 24 Q. But you didn't know he was Jeffrey then? 25 A. No I did not Page 225 1 Q. Very friendly? 2 A. Yes. 3 Q. Okay. And she seemed to be happy to see him? 4 A. Yes. 5 Q. Okay. And did — from everything that she 6 had told you about Mr. Epstein, she said he's a nice 7 guy, he's very polite; right? 8 A. Yes. 9 Q. Okay. And did she tell you, she said, look, 10 you — you — you can feel way safe around him? 11 A. No. 12 Q. Okay. Did she tell you don't worry? 13 A. Those were not words that she used, no. 14 Q. Well, what words did she use? She said he's 15 a nice guy? 16 A. Yeah. 17 Q. That you'll like him? 18 A. No. She just said that he was a nice guy. 19 Q. Okay. Did you say, nice meeting a 20 guy, so what's going on 9 21 A. No, I didn't. 22 Q. All right. So she goes up to Jeffrey. And 23 did — do you remember, did she give him a hug? 24 A. No, I don't think so. 25 Q. She just went up, and she looked happy? Page 224 Q. A man walked in? A. A man walked in. Q. Describe him for me. A. Had gray hair. He had sweat pants and Illce a 5 T-shirt on. I don't know. He was old; he was an older .5 man. And - 7 Q. What did he say to you? 8 A. He said — 9 Q. Well, in fact, let me — let me strike that 10 Who did he speak with? He walked in. You 11 described what he was wearing. 12 A. He talked to.. AndM. said, you blow, 13 this is my friend, Jane Doe. And he shook my hand. He 14 said that his name was Jeffrey, and then — I don't 15 know. I don't know what else he said, but he started to 16 walk out of the room. And as he was walking out of the 17 room, he said that we needed to take our clothes off. 18 Q. You say he walked to.. Did he have a 19 private conversation with M.? 20 A. Yes. 21 Q. Okay. And when he walked into the room 22 dressed as he did, did she go up to him at all? 23 A. Yes. 24 Q. Did she give him a hug? 25 A. I don't think so. Page 226 1 A. I don't know — I don't know if she gave him 2 a hug or not I don't retnember. 3 Q. All right. Did she — but she appeared to be 4 very comfortable with him as she — because she -- 5 MR. EDWARDS: Objection. Asked and answered. 6 BY MR. CRFITON: 7 Q. Let me strike that. 8 Did she appear to be comfortable around him 9 when she greeted him? 10 MR. EDWARDS: Same objection. 11 THE WITNESS: I don't know. 12 BY MR. CRITTON: 13 Q. Well, did she appear to be uncomfortable? 14 A. No. 15 Q. Okay. Well, I mean, you -- you would have 16 sensed if she felt — you didn't see any fear in her 17 eyes or any anxiety; did you -- 18 MR. EDWARDS: Objection to the form. 19 BY MR. CRITION: 20 Q. -- in either ha mannerisms or her face? 21 MR. EDWARDS: Form. 22 THE WITNESS: No. 23 BY MR. CRITTON: 24 Q. Okay. And she certainly hadn't told you 25 anything that would cause you to be fearful or scared or (561 ) 832-7500 PROSE COURT 25 (Pages 223 to 226) REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (504333-7724552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4f15158d-6c22-4c50-b036-e423618c2145 EFTA00750764 Page 1 anxious; true? 2 A. I guess not. 3 Q. All right. But you were anxious, because you 4 didn't know what was at least, based on your 5 testimony, because you weren't sure what was going to 6 happen happen- 7 A. Yes. 8 Q. — at least your testimony? I don't know 9 what — whetherM. will say that, but that's your 10 testimony; right? 11 MR. EDWARDS: Object to the form. 12 THE WITNESS: Yes. 13 BY MR. CRITIDN: 14 Q. Now, so as he leaves, you said he said what? 15 A. He said that we need to take our clothes off. 16 Q. Okay. And then did he leave the room? 17 A. Yes. 18 Q. Where did he go? 19 A. I don't know. 20 Q. He just left? 21 A. Yes. 22 Q. Okay. And did you turn to.. and say 23 some hi 24 A. kind of turned to me and like, 'don't 25 know, she kind of just told me that I should do it. Page 229 1 Q. Okay. Had you ever seen her or observed ha 2 in any kind of sexual activity with a man before? 3 A. No. 4 Q. Were you aware thatM. was sexually active 5 at that point? 6 A. No. 7 Q. Well, she was living with 8 What did you think was going on? 9 MR. EDWARDS: Object to the form. 10 BY MR. CRITTON: 11 Q. When the two were living together, did you 12 think that was a platonic — if I say — ifl use the 13 word platonic, do you know what that means? 14 A. Yes, I do. 15 Q. Okay. Platonic means probably no sexual 16 activity. 17 A. I know what it means. 18 Q. Okay. You understood, or at least you 19 surmised that and.., who were living 20 in the trailer together, were sexually active; true? 21 MR. EDWARDS: Object to the form. 22 BY MR. CRITTON: 23 Q. It's not rocket science. You understood that 24 to be a fact didn't you? 25 MR. EDWARDS: Object to the form. Page 228 1 Q. Was.. taking her clothes off'? 2 A. Yes. 3 Q. Okay. And what and you — I think you 4 told me you don't remember what had on? 5 A. No. 6 Q. Did. - and what clothes did.. take 7 off in your presence? 8 A. All of them. 9 Q. How many times had you seen.. naked before 10 this first time that you had been to Mr. Epstein's home? 11 A. 1 don't know. We were friends fora long 12 time. We changed in front of each other. 13 Q. Okay. Because you were kid friends 14 together - 15 A. Yeah. 16 Q. — so you probably had seen each other's 17 bodies at some point when you were changing clothes or 18 running from the shower; right? 19 A. Yes. 20 Q. Okay. Had you ever seen naked in the 21 presence of another person? And I don't mean another, 22 you know, girls were all, you know, after PE or sports 23 together or something like that. Had you ever seen her 24 in the presence Ma naked man before? 25 A. No. Page 230 1 THE WITNESS: I didn't I don't 'mow. 2 'BY MR. CRITTON: 3 Q. Come on. Ms. Jane Doe, are nu i that 4 you know — you were aware that'll. and 5 were living together in a walla, and had been for a 6 number of months, and you don't believe they had any 7 type of sexual relationship between one another, is that 8 what you're telling the members of the jury? 9 MR. EDWARDS: Object to the form. 10 THE WITNESS: I'm not saying that I don't 11 believe that I'm saying that I do not know that. 12 BY MR. CRITTON: 13 Q. So now we're back at Mr. Epstein's home. 14 starts taking off her clothes. Mr. Epstein had 15 said, you can take off your clothes. What did you 16 say to M.? 17 A. I didn't say anything to her. She just 18 turned to me and told me that I should do it. 19 Q. And you — or at least by what you've told us 20 so far, is you that ou were going to go over, meet 21 an older man, and M. was going to pay you 200 bucks; 22 right? 23 A. Yes. 24 Q. Okay. So when he says, take off your 25 clothes, and she says — she — she,.., starts taking (561) 832-7500 26 (Pages 227 to 230) PROSE COURT REPORTING AGENCY, INC. (561) 832-75O6 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 41616846O24c50430364423618c2fb6 EFTA00750765 Page 231 1 off her clothes, does like the proverbial red flag go up 2 to or a light come on to say, well, wait a minute, 3 III, what's going on here? 4 A. I didn't say anything to her. 5 Q. Why not? 6 A. I don't know why not. 7 Q. Okay. Jane Doe, prior to this first occasion 8 that you had been in Mr. Epstein's house, on how many 9 occasions had you taken your clothes off in the presence 10 of a man who was not -- or a male who was not a parent? 11 A. Excuse me? 12 Q. O Well, let me — let me ask: Did 13 you as On's taking all of her clothes off, did you 14 then take all of your clothes off? 15 A. Yeah, when she told me that I should, yes,1 16 did. 17 Q Well, she could tell you to jump off the 18 building, but it doesn't mean —1 mean, you're your own 19 person. You already told me that; right? 20 MR. EDWARDS: Object to the form. 21 THE WITNESS: Yes. 22 BY MR. CRITTON: 23 Q. And you were your own person back in 2003; 24 weren't you? 25 MR. EDWARDS: Object to the form. Page 233 1 BY MFt. CRITTON: 2 Q. All right. And you had been through the 3 whole — a number of depositions and court proceedings 4 involving your lethal correct? S MR. EDWARDS: Object to the form. 6 THE WITNESS: Yes. 7 BY MR. CRITTON: 8 Q. All right. Did you take off all of your 9 clothes? 10 A. Yes, I did. 11 Q. And now my question again is, is: Prior to 12 that occasion at Mr. Epstein's house, had you ever 13 completely taken off your clothes for — in the presence 14 of a male who was not a family member? 15 A. No. 16 Q. Were you sexually active prior to the time 17 that you first went to Mr. Epstein's home? 18 A. No. 19 Q. Had you ever had any type of sexual activity 20 with a male — 21 MR. EDWARDS: Object to the form. 22 BY MR. CRITTON: 23 Q. — prior to being at Mr. Epstein's home? 24 A. No. 25 Q Had you ever — and let me define sexual Page 232 1 THE WITNESS: Yes. 2 BY MR. CRITTON: 3 Q. And you knew the difference between, in your 4 mind, at least, right and wrong; correct? 5 A. No, I didn't 6 Q. You had found a way to run away from home and 7 go live with various people and to survive; correct — 8 MR. EDWARDS: Object to the form. 9 BY MR. CRITTON: 10 Q — prior to ever meeting Mr. Epstein? 11 A. Yeah. 12 Q. Right. And you had been through some rather 13 significant psychological and emotional events in your 14 life prior to ever meeting Mr. Epstein — 15 A. Yes. 16 Q. — including not only the murder of , but 17 as well what you learned to be domestic abuse between 18 your mother and your real father, Mr. correct? 19 MR. EDWARDS: Object to the form. 20 THE WITNESS: I never witnessed any abuse. 21 BY MR_ CRITTON: 22 Q. I know that, but you were aware that it 23 existed, because your heard about it; true? 24 MR. EDWARDS: Object to the form. 25 THE WITNESS: I was told, yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, Page 234 1 activity. 2 Had you ever been with a male, where you 3 placed your hand on his penis? 4 A. No. 5 Q Had a male ever touched your breast or - 6 your breast at any time, prior to the time you went to 7 Mr. Epstein's? 8 A. No. 9 Q. Had you ever — had a male ever touched any 10 part of your genitalia — 11 A. No. 12 Q. - prior to ever being at Mr. Epstein's? 13 A. No. 14 Q. Had you ever given a male oral sex at anytime 15 prior to being at Mr. Epstein's? 16 A. No. 17 Q. Had you ever had sexual intercourse with a 18 male prior to your first time you ever went to 19 Mr. Epstein's? 20 A. No. 21 Q. Had you ever had any type of anal sex prior 22 to the time you first went to Mr. Epstein's? 23 A. No. 24 Q And it's your testimony — well, let me ask 25 you this: Had you ever disrobed in any state, just 27 (Pages 231 to 234) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-712-1552) Electronically signed by Pamela Sullivan (S01-333-772-1552) 4f15158d-6c22-4e5043036-e423618c2fb5 EFTA00750766 Page 235 1 taking your top off so that you would have exposed your 2 breasts to a male -- 3 • A. No. 4 Q. - other -- other than a family member, prior 5 to corning to Mister — prior to going to Mr. Epstein's 6 home on the fust occasion? 7 A. No. 8 Q. So when ■ says to you -- or Mr. Epstein 9 says, take off your clothes, he leaves the 10 room, why didn't you say toll: that point, what is 11 going on here? 12 MR. EDWARDS: Object to the form. 13 THE WITNESS: I don't know. I didn't — I 14 didn't really know what else to do or say. I just 15 thought that I had to do it. I didn't know I had a 16 choice. 17 BY MR. CRITTON: 18 Q. No -- no one was forcing you to do anything 19 at that point; were they? 20 MFt. EDWARDS: Form. 21 THE WITNESS: No, but l didn't }mow that 22 there was a choice there, that I could say, no. I 23 didn't ;mow that at that time. 24 BY MR. CRITTON: 25 Q. Sure you did, because you knew that all you 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 237 Q. Sure, you did. A. No. MIL EDWARDS: Object to the form. BY MR. CIU17O1.1: Q. could have said to I. at that point in autt time, Mt I want to go borne. MR. EDWARDS: Object to the foam BY MR. CRITTON: Q. nue? A. The point is that I didn't know that then. Q. True -- A. Yeah, now, that's true; I know that now. But then? No, I didn't Imovat Q. Did you say to MI, MI, I don't wain to stay here? A. No. Q. Was I. your friend? A. Yes. Q. She was a good friend? A. Yes. Q. All right Did you say, I., why did you bring me here? I don't want to do that? A. No, I didn't. Q. But you could have? MR. EDWARDS: Object to the form. Page 236 1 had to -- 2 MIL EDWARDS: Objection. Argumentative. 3 MR. CRITTON: I need to ask the question 4 lust. 5 MR. EDWARDS: Well, you're Just telling her a 6 comment and arguing with her. Ask a question. 7 MR. CRITTON: Want me to read baclaid 8 (phonetic) deposition? 9 MR. EDWARDS: Sure. Into this record? 10 MR. CRITTON: Na 13. MR. EDWARDS: Yes, please. 12 MR. CRITTON: You 'mow your questions or 13 let me say your statements... Well, let me go back 14 to my question. 15 BY MR. CRITTON: 16 Q. Ma'am, you had— you had a choice at the 17 time Mr. Epstein left the room, and he had said, okay, 18 take your clothes off, or whatever you say he ssaw 19 you and You could say, this isn't forme, MI, 20 what's going on. You could have done that, and you 21 chose not to; true? 22 A. At this point I know, yeah, I could have done 23 that. 24 Q. At that point you amid have? 25 A. I did not laiow that. —731===ESZSMsr=M• Page 238 1 THE WITNESS: I didn't know that. 2 BY MR. CRITTON: 3 Q. You could have, whether you — I understand 4 that you're saying you — you didn't know you could. 5 But 1— my question is, is: You could have done — you 6 had a chgitighthat you could have said, I don't want to 7 do this, I'm not taking my clothes off. Sony. 8 I'm out of here. 9 MR. EDWARDS: Object to the form. 10 BY MR. CRITTON: 11. Q. You could have chosen that; true? 12 A. That's true, but I didn't know that at that 13 time. 14 _Q. Did you tell I don't want to do this, 15 16 MR. EDWARDS: Same objection, Ram 17 THE WITNESS: I didn't know that I had a 18 choice at that time. 19 BY MR. CRITTON: 20 Q. Okay. 21 A. Now I know that I could have said, no, and I 22 could have left. But when I was there at that time and 23 place, I had no idea that I could have said, you know 2 4 what, I -rjarant to leave. 25 Q. M. takes off her clothes. Did you wait 28 (Pages 235 to 238) AGENCY, INC. (561) 832-7506 (561) 832-7500 PROSE COURT REPORTING Electronically signed by Pamela Sullivan (501-333-772.1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 415168d4c224660-00344423618c2fb5 EFTA00750767 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 239 till she was fully disrobed before you took your clothes off? A. No. Q. Did you say, hey, can I leave on my underwear, my bra and my panties? Did you have a bra? A. Yes. Q. Okay. Did you say, rd just — rd feel more comfortable if I didn't take my clothes off? A. No. Q Okay. Didn't she tell you, look, you don't have to do anything you don't want to do? A. No, she did not. So if she says that, she's lying? She -- if says, I told Jane Doe, as I told all the other girls that I took, is if they didn't want to do something or if they felt uncomfortable, they didn't have to do that? MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. She told you that; didn't she? A. No. Q. So if she — ifig testifies that that's what she told you, you're sayingli. lied to me — MR. EDWARDS: Object to the form. 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 241 BY MR. CRITTON: Q. You need to answer my question. I'm asking you to assume — MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. -- Mate. has testified under oath that she told you that you didn't have to do anything you didn't want to do. A. She did not tell me that. Q. All right. So if she's testified that that's what she did tell you, that's a lie; correct? MR. EDWARDS: The witness has answered the question. Object to the form, again. THE WITNESS: She did not tell me that BY MR. CRITTON: Q. So if she's testified — if she testifies or has testified that she said that, that would be a lie; is that correct? MR. EDWARDS: Object to the form. THE WITNESS: Yes. BY MR. CRITTON: Q All right. Take your clothes off; now has her clothes off. What happens next? A. Jeffrey walked back in with only a towel on. Page 240 1 BY MR.. CRITTON: 2 Q. -- that's a lie; right? 3 MR. EDWARDS: Object to the form. Compound 4 question. 5 BY MR. CRITTON: 6 Q. Let me reask it so it's clear: Ifni has 7 testified that she told you that you didn't have to do anything that you weren't comfortable with doing, your 9 testimony would be a liar -- 10 MR EDWARDS: Object to the form. 11 BY MR. CRITTON: 12 Q. - is that correct? 13 A. I just know that.. did not say that tome. 14 So if you're telling me that, then you're a liar. 15 Q. No. If I'm telling you that that's what.. 16 has testified that she told you — 17 A. How do I know that, though? 18 Q. fin asking you to assume it. Ifs what's 19 called a hypothetical question. 20 Okay. testified, I told Jane Doe 21 that she didn't have to do anything she didn't want to 22 at Mr. Epstein's house, if I asked you to assume that as 23 being true, you would sly In is a liar; correct? 24 MR. EDWARDS: Object to the form. 25 THE WITNESS: M. didn't say that to me, Page 242 1 Q. Like a bath towel? 2 A. Yes. 3 Q. Okay. Around his waist? 4 A. Yes. 5 Q. All right. And what happens next? 6 A. He laid down on his belly on the massage 7 table, and we rubbed his back and his legs. 8 Q. . And who told you to do that? 9 A. M. did. 10 Q. And didll., when she was out — -- I'm 11 sorry —when he was out of the room, did'''. tell 12 you - did you say, what's -- what are we doing? Now, I 13 got my clothes off. Now, what's next? 14 A. No. 15 Q. Okay. Did you know you were going to give 16 Win a massage? 17 A. No. 18 Q. Okay. Had you ever given a man a massage 19 before? 20 A. No. 21 Q. Given anyone a massage before? 22 A. No. 23 Q. Did — so he comes in, he lies down, he still 24 has his towel on; right? 25 A. Yes. (561) 832-7500 29 (Pages 239 to 242) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (S01-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772.1552) 4f15158d-6c22-4c50-6036-e423618c21b5 EFTA00750768 Page 243 1 Q. And he's lying on his stomach? 2 A. Yes. 3 Q. And what did.. tell you to do? 4 A. She just told me to like give him a massage. 5 Q. Okay. And how did you know how to give him a 6 massage? 7 A. I don't know. 1 just like did what she was 8 doing. 9 Q. Okay. Was she standing next to you the 10 entire time? 11 A. Yes. 12 Q. And Mr. Epstein was what, was lying face 13 down? 14 A. Yes. 15 Q. And his face was what, pointed down toward 16 the floor on the massage table? 17 A. I don't know -- I don't remember. 18 Q. Okay. Where were his arms? To the side? 19 A. I don't know. 20 Q. Or was his leaning on them, like it was his 21 head on his arms? 22 A. He was laying down, getting a massage. 23 Q. All right. Were his arms at his side, or 24 were they over his shoulders? 25 A. I don't know. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. time? A. Q. A. Q. ID? A. You think he was !Ding people? No. Q. I'm just asking the questions, maam. What else did you talk about? A. I talked about school and -- I don't know. I mean, I didn't talk much to him. Q Was M. doing most of the talking? A. !guess, Q. Okay. He — if he was looki down or away from you, did you ever fly to talk to and say, you blow, this is odd, or I don't want to be hue, or let's go? Page 245 And had you shown Mr. Epstein an ID at any Na Did you ever show him an ID? No. You're sure of that? You didn't have a fake MR. EDWARDS: Object to the form. THE WITNESS: No. BY MR. CRITTON: Q. You could have, though, said something to her? MR. EDWARDS: Object to the form. Page 244 1 Q. How long did this last? 2 A. Thirty or so minutes. 3 Q. And so you rubbed where? Where did you and 4 start - were you doing it in tandem, together? 5 A. His back and his legs. 6 Q. So you rubbed his back and his legs for 7 approximately how long? 8 A. Thirty minutes. 9 Q. And at the end of the 30 minutes, did you 10 both leave? 11 A. No. 12 Q. Okay. So you rubbed his back and his legs 13 for 30 minutes? 14 A. Yes. 15 Q. Did he talk to you at all? 16 A. Yes. 17 Q. Did you talk to him? 18 A. Yes. 19 Q. And what did — what did you talk about? Was 20 he talking to M., too? 21 A. Yes. 22 Q. Okay. What did he ask? 23 A. He asked me how old 1 was. 24 Q. And what did you tell him? 25 A. I told him that I was 15. Page 246 1 BY MR. CRITTON: 2 Q. Right? 3 A. Yes. 4 Q. Okay. And you could have said, you know, 5 enough of the massage, Tin putting my clothes on, I'll 6 meet you downstairs? 7 MR. EDWARDS: Object to the form. 8 BY MR. CRITTON: 9 Q. Right/ 10 A. Yes, I could have said that. 11 Q. At the end of 30 minutes, you've now massaged 12 his back and his legs? 13 A. Yes. 14 Q. Oka . What happened next? 15 A. IMI. said that she was going to go downstairs 16 for a little bit, and she was going to come back. 17 Q. Okay. And when -- did she grab her clothes 18 and go? 19 A. Yes. 20 Q. So she —M. says, I'm going downstairs for 21 a bit. She takes her clothes and leaves? 22 A. She put her clothes on and left. 23 Q. Right in front of you? 24 A. Yes. 25 Q. And what were you doing all this time? (561) 832-7500 30 (Pages 243 to 246) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (601.333.772.1652) 4f151615:1-6c22-4450-b036-e423618c2fb5 EFTA00750769 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 247 A. I don't know. Q. Did you say ton., you know, I — I'm ready to go, too? A. No. Q. Did you say,.., don't leave me? A. No. Q. Did you say, I don't want to be left alone? A. No. Q. Did you say, I want to put my clothes back on, too? A. No. Q. You could have done any of those things — MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. — couldn't you? A. I didn't ;mow that at the time. Q. Nobody was preventing you from putting your clothes on or leaving that room; true? A. No, but he should have given me that option. Q. Answer my question: No one prevented from putting your clothes on and leaving with M.; did they? MR. EDWARDS: Object to the form. THE WITNESS: No. Page 249 1 A. He asked me to squeeze his nipples really 2 hard. So I did. 3 Q. All right. And then what happened? 4 A. And then he started masturbating, and I 5 just — I don't know, l ldnd of just tried to like not 6 look at his face. And I just did whatever he said, and 7 waited until he was done, and left. 8 Q. I-lad you ever seen a man masturbate before? 9 A. No. 10 Q. Have you seen a man masturbate since? 11 NM. EDWARDS: Object to the form. 12 THE WITNESS: No. 13 BY MR. CRITTON: 14 Q. Okay. So Mr. Epstein -- Mr. Epstein is the 15 only person whom you've ever seen masturbate? 16 A. Yes. 17 Q. Okay. Have you ever been involved — have 18 you ever given a man — have you manually, with your 19 hand, given — had a man -- masturbated a man to 20 ejaculation? 21 A. No. 22 Q. Had you ever seen a man's penis before? 23 A. Before -- 24 Q. Before that first time you were at 25 Mr. Epstein's. Page 248 1 BY MR. CRITTON: 2 Q. No one forced you to stay in the room with 3 Mr. Epstein; did they? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: No. 6 BY MR. CRITTON: 7 Q. No one tried to restrain you from leaving 8 that room; did they? 9 MR. EDWARDS: Form. 10 THE WITNESS: No. 11 BY MR. CRSITON: 12 Q. No physical force was ever used at any time 13 by Mr. Epstein directed to you; was it? 14 A. No. 15 Q. M. leaves? 16 A. 1.1h-huh. 17 Q He's still lying on his stomach? 18 A. No. 19 Q. All right. How much longer did you spend in 20 the room with Mr. Epstein? 21 A. About 30 minutes. 22 Q So you were there approximately an hour the 23 first time? 24 A. Yes. 25 Q. Okay. What happened next? Page 250 1 A. No. 2 Q. Okay. Separate — and, obviously, you've 3 seen pictures in books? 4 MR. EDWARDS: Object to the form. 5 BY MR. CRITTON: 6 Q. All right. But before you ever went to 7 Mr. Epstein's, you knew what a — what a man's genitalia 8 looked like; fair statement? You'd seen, at least, 9 pictures in a book? 10 A. Yes. 11 Q. Okay. Is it your testimony that you had 12 never seen a man's penis before that? 13 A. Yes. 14 Q. But you've seen a man's penis since then; 15 true? 16 A. Yes. 17 Q. AU right. Mr. Epstein's penis look any 18 different than others that you've seen? And assume that 19 women's breasts look different between women, I believe. 20 Anything different with Mr. Epstein's penis than you've 21 seen with other men's penises? 22 A. Yeah. 23 Q. What? 24 A. It was like - I don't know. I mean, I guess 25 it was small and -- I don't know. It looked like he (561) 832-7500 31 (Pages 247 to 250) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-712.1552) Electronically signed by Pamela Sullivan (501.333-772.1552) 4f15158d-6c22-4c50-b036-0423618c2fb5 EFTA00750770 Page 251 1 like wasn't circumcised right or something. 2 Q. Okay. Let me ask you this: So after he 3 masturbated, did he ejaculate? 4 A. Yes. 5 Q. All right. And did you look, or did you turn 6 away? 7 A. I did not look. I turned away. 8 Q. All right When that was complete, what 9 happened? 10 A. lie got in the shower, and I put my clothes on 11 and left. 12 Q. Okay. Did he — did you see him again before 13 you left -- Mr. Epstein? 14 A. Oh, yeah, I — 'went down — downstairs to 15 where.. was and sat with her for a second. And I 16 don't know how long it was, but he came into the kitchen 17 and like laughed with. about something — I don't 18 know what it was. And I guess we were waiting for the 19 cab to come back and get us, and then we Icti. 20 Q. Did he give you any money? Did anyone give 21 you any money? 22 A. It gave me money. 23 Q. Once you got in the cab? 24 A. Yes. 25 Q. Okay. How much did she give you? Page 253 1 Q. All right. So you get — you get i cab. 2 Did you say — have any conversation wide. after you 3 came down, up until the time you got in the cab? 4 A. No. We actually ended up walking up his 5 street and flagging a cab driver down. 6 Q. All right And as u're walking up the 7 street, what did you say tMl.? 8 A. I didn't talk to her about it. 9 Q. Pardon? 10 A. I did not talk to her about Jeffrey Epstein. 11 Q. Why not? 12 A. I did not feel comfortable. 13 Q. Did she already give you $200 by that point? 14 A. Yes -- no — well, I'm pretty sure that 15 whenever Jeffrey had came into the kitchen, when -- when 16 we were both in there, he asked her if she had given me 17 the money or not. And that -- 18 Q. And she said? 19 A. That's when she gave it tome. 20 Q. Did — did she tell you that she had gotten 21 money? 22 A. Yes. 23 Q. And why did she get money? 24 MR. EDWARDS: Object to the form. 25 THE WITNESS: ldon't know. Page 252 1 A. $200. 2 Q. And when you were waiting downstairs, did you 3 have anything to eat or drink — and by drink, I mean 4 like a soda or water or anything? 5 A. I didn't, but.. did. 6 Q. Okay. Was she eating when you came down? 7 A. Yes. 8 Q. Was she eating and drinking something? 9 A. I don't know. 10 Q. Okay. You've never been on the occasions 11 that you've been at Mr. Epstein's house, you've never 12 had — alcohol has never been served to you; has it? 13 A. No. 14 Q. Okay. And never any type of drugs, 15 prescription or otherwise, have ever — or tobacco has 16 ever been used at Mr. Epstein's house; true? 17 MR. EDWARDS: Object to the form. 18 THE WITNESS: Fm sure I smoked cigarettes. 19 BY MR. CRITTON: 20 Q. Outside? 21 A. Outside of his house, yes. 22 Q. Okay. Mr. Epstein has never given you 23 tobacco or any type of alcohol or drugs, nor has anyone 24 in his house; true? 25 A. Yeah, that's true. 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 254 BY MR. CRYITON: Q. Did she ever tell you she got money because she brought you? A. I would assume that's why, but she never actually said that to me, no. Q. But you were able to make that assumption pretty easily; weren't you? A. Yes. Q. All right. Did you ever say anything to her that day? A. No. Q. Okay. As you're walking up the street, did you say, I don't want the money, I don't — I don't want anything to do with Mr. Epstein? A. No. Q. Did you keep the money? A. Yes. Q What did you do with it? A. I don't know. I probably bought clothes with it or something. MR. CRITTON: Let's take a lunch break. (A luncheon recess was taken.) (Continued in Volume III of the same day.) (561) 832-7500 PROSE COURT REPORTING AGENCY, 44. 32 (Pages 251 to 254) INC. (561) 832-7506 Electronically signed by Pamela (lellIvan (501.333.772.1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 41151580.6c22-4c5043036-e423618c2fb5 EFTA00750771 Page 255 1 CERTIFICATE OF OATH 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 6 I, the undersigned authority, certify that 7 JANE DOE personally appeared before me and was duly 8 9 10 11 12 13 14 sworn. Dated this 13th day of October, 2009. 15 Pamela J. Sullivan, RPR, Notary Public - State of for 16 My Commission Expires: June 10, 2010 My Commission No.: DI) 560380 17 18 19 20 21 22 23 24 25 1 004Per B, et') I IANE COO G0B9ADJ EDWARDS, Venn 3 Reatio, Rimed* Adkr Ls OW City Ceett. 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Pieto1a J. San*. 21,R, Sae, Cla Rue Cox% Asse:y,Irt OD: Cle212o, e 250S Mandan Mena Um 1:40 %%kg Pete Bieck flot1441140) 5614327540 410 herby .the my dean MNE DOB JAN0 DOE Page 257 Page 256 1 CERTIFICATE 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 Pamela 1 Sullivan, Registered Profess:wet Court Reporter and Notary Public in and for the State of 6 nœldo a longs do hereby certify that I was authorized to and did report said deposition in 7 stenotype, and that the foregoing pages are a true and correct transcription of my shorthand notes of end e deposition. 9 I further certify that said deposition we taken at the time and place hereinabove set forth and that the 10 taking of said deposition was commenced and completed as hereinabove set out. 11 I further certify that not attorney or counsel 12 of any of the parties, nor am I a relative or employee of any attorney or counsel of party crewed with the 13 action nor am I financially interested in the onion. 14 The foregoing certification of this transcript does not apply to any reproduction of tiro same by any means 15 unless wen rho direct control and/or direction of the catlfiong reporter. 16 17 18 19 20 21 22 23 24 25' Doted this 13th day of October. 2009. Pamela/. Sullivan. RFR, FPR, CLIO 1 CERTIFICATE Page 258 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the foregoing 6 deposition by me given, and that the statements 7 contained herein are tine and correct to the best of my 8 knowledge and belief, with the exception of any 9 corrections or notations made on the errata sheet, if 10 one was executed. 11 12 Dated this day of , 2009. 13 14 15 16 17 18 19 20 21. 22 23 24 25 JANE DOE (561) 832-7500 PROSE COURT REPORTING AGENCY, 33 (Pages 255 to 258) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333.772.1552) Electronically signed by Pamela Sullivan (501.333.772-1552) 4f15168445e22.4060430.18-4423818c2185 EFTA00750772 Page 259 1 ERRATA SHEET 2 IN RE: JANE DOE V. JEFFREY EPSTEIN 3 C . PAMELA I SULLIVAN, RPR, FPR, CLR 4 DEPOSMON OF: JANE DOE 5 DATE TAKEN: September 30, 2009 6 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HUE 7 PAGER LINEN CHANGE REASON 9 10 11 12 13 19 15 16 17 18 19 Please forward the angina signed errata sheet to this office so !bat copies inay be distributed to ail parties. 20 Under penalty of pajury. I declare that 1 have rest my 21 deposition and that it is true and correct subject to any changes in tbeni or substaxe entered here. 22 23 DATE: 24 25 SiGNATURE OF DEPONENT: 3 • . . . . . . . . 34 (Page 259) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 441515846c22-4c50-b036-0423618c2fb5 EFTA00750773