EFTA00750774.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 III 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 (6014334724662) Electronically signed by Pamela Sullivan (601-33S-772-1552) 9205b62-38a5-4202-0350-6633a5c6813b EFTA00750774 15 16 1, 18 19 20 21 22 23 24 25 APPEARANCES On behalf of the Plaintiff. /me Deo BRAD J. EDWARDS, ESQUIRE ROTHSTEIN ROSENFELDT ADLER Lea au ON Cate, Suite 1650 401 East Las Otat Beamed Fart Lade/dal. Hooch 33301 0.1 behalf of the Defeedmu, kffrey Epstein: ROBERT D. CRITTON, 3R. ESQUIRE BURMAN, CIUTPON, CUTTER & COLEMAN, LIP 9 303 Behan Bculevard Suite 400 10 Nash him Bach Ronda 33401 11 12 On behalf efthe Deem/bet. Jeffrey *Kit 13 JACK ALAN OOLDBEROER, ESQUIRE ATTERBURY, GOIDBERGER & WESS, PA 14 250 AuMeliat Aram Sotth WM 1400 Wall Pam Beach, FIceicla 334014012 On WWI of Itbittiff r Related Carr No. 01680469: SIDRO M. GARCIA, ESQUIRE GARCIA LAW FIRM, PA 224 Da ma Seth Suite 900 11.1113401 On behalf of hem Dom thmedh ADAM D. HOROV/ITZ, ESQUIRE MERMELSTEIN a HORMUZ P.A. 1820$ Blimp* Boulevard Sulk, Z218 Miami. Florida 33160 Page 261 1 2 3 4 5 6 7 9 10 11 DESOUPTION PAGE 12 Page 263 INDEX - - - %WINES& DIRECT CROSS REDIRECT RECROSS JANE DOE BY MR. CRITTON 5 EXHIBITS MARKED Defendants No. 6 390 13 (Plaintiffs AGSMs to Defendant's Interrogatories) 14 Defendants No. 7 (Ur to Edwards from Critton %%Enclosures) 15 16 17 18 19 20 21 22 23 24 25 Marked off the record.) Page 262 1 On behalf of the Plaintiff CM.A.: 2 JACK P. HELL, ESQUIRE SEARCY DENNEY SCAROIA BARNHART & SHIPLEY, PA 3 2139 Palm Beach Lalces Boulevard West Pabn Beach, Oneida 33409 4 5 On o . 6 ADAM J. LANGEt40, ESQUIRE LEOPOLD KINN 7 2925 PGA Boulevard, Sure 200 Palm Beach Galas. Florida 33410 9 10 11 12 1.3 14 15 16 17 18 19 20 21 22 23 24 25 ALSO PRESENT: Jeffrey Epstein, via video conference Stm Sanders, Videograptier 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 264 PROCEEDINGS (Continued from Volume II of the same day.) BY MR. CRITTON: Q. Ms. Jane Doe, other than speaking with your attorney over the lunch hour, did you speak with anyone else? A. No. Q. Are you on any medication today? A. No. Q. 'When is the last time you had any pot, marijuana? MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. And when I say had, smoke. A. Before I was pregnant with my daughter. Q. Okay. And its your testimony that, since the time you've been pregnant, you have not taken — you haven't smoked pot and you haven't taken any drugs or alcohol Tm sorry — any illegal and/or — any illegal drugs or prescription drugs that would have gone to someone else, like a Xanax; is that correct? MR. EDWARDS: Object to the form. THE WITNESS: What was the question? (561) 832-7500 ..2 (P.ages_2_61 to 264) PROSE COURT REPORTING AGENCY, INC. • • (561) 832-7506 • Electronically signed by Pamela Sullivan (501.3357724652) Electronically signed by Pamela Sullivan (501-333-7724552) 92eldb6248.5-42024360-6633a5e6813b EFTA00750775 Page 265 BY MR. CARTON: 2 Q. Ifs your testimony that, since the time you 3 were pregnant, you haven't had any illegal drugs and/or 4 any drugs that weren't prescribed specifically for you? 5 A. Yes, that's true. 6 Q. Okay. And you -- and you have roxy. I asked 7 you earlier whether you knew what that was. My 8 understanding is you smoke that; is that correct? 9 MR. EDWARDS: Object to the form. 10 BY MR. CARTON: 11 Q. You — and it's a smokable drug? 12 MR. EDWARDS: Object to the form. 13 1HE WITNESS: I have heard of people eating 14 them and snorting them and smoking them and 15 shooting them up. 16 BY MR. CRITTON: 17 Q. Okay. And it's your testimony you've never 18 done those? 19 A. Yes. 20 Q. When is the last time you spoke with— well, 21 I asked you a question earlier: Who else was living 22 with you and your boyfriend, MI, and your child at 23 your house? And your attorney instructed you not to 24 answer. Do you remember that? 25 A. Yes. Page 267 1 Q. You need to keep your voice up, because Pm 2 having trouble hearing you, ma'am. 3 A. She's okier than me. 4 Q. Okay. And why did she live with you? 5 A. ;guess her mom was staying in a — in an 6 efficiency, I guess, with her bcSiend, and I guess 7 there really wasn't room for M. She didn't have 8 anywhere to live. 9 Q. And were you living at 10 house at the time? 11 A. Yes. 12 Q. Okay. And how long did M. live with you? 13 A. A month or two. 14 Q. AUSA. Since that other than that one 15 time, has ever lived with you again? 16 A. No. 17 Q. Has she ever stayed with you again? 18 A. No. 19 Q. Do you know where M. is right now? 20 A. No. 21 Q. When is the last time you talked to M.? 22 A. Several months ago. I'm not sure. 23 IIVOkay. And what was the event that caused you 24 and M. to not be close anymore? 25 A. She moved. Page 266 1 Q. Okay. Is the person who — is it more than 2 one additional person who is living with you at that 3 house? 4 A. No. 5 Q. Okay. Is that person still there now? 6 MR. EDWARDS: Don't answer. Other identifying information about the 8 address. I think it's — ifs pretty clear she's 9 not going to answer anything that's going to 10 indicate to you where' he's living currently. Now, 11 all other addresses, you know them, and she'll tell 12 you that. 13 MR. CARTON: I understand. So my position 14 is clear is that person that's been, apparently, is 15 living there, she, she would have information — 16 she or he would have Information regarding aspects 17 of the Plaintiffs claim clearly is a relevant 18 witness, and — 19 MR. EDWARDS: Okay. 1 understand. 20 BY MR. CRITTON: 21 Q. Has Ng ever lived with you? 22 A. Yes. 23 Q. Okay. When? 24 A. We were 14, I believe. She was 14, I was 13, 25 because she's older than I am. Page 268 1 Q. Just she moved? 2 A. She moved far away from me. I don't know 3 where. And I guess she — I don't know. I guess she 4 doesn't... 5 Q. Do you have her phone number? 6 A. No. 7 Q. Okay. Did you have it before she moved? 8 A. Yes. 9 . Have you — when you've talked to M., does 10 ever say,' -- I know where a. is, or I talked to 11 . the other day? 12 A. No. 13 Q. And tell me when the last time was that you 14 spoke with M, 15 A. Probably a month and a half, maybe two months 16 ago. 17 Q. Okay. Which would if we're in the end of 18 September, it would have been sometime in early or mid 19 July? 20 A. Yes. 21 Q. Okay. And did you only talk to her over the 22 phone? 23 A. We went to the beach. 24 Q. Did you take your respective children? 25 A. Yes. •.‘13, (561) 832-7500 YacY•aa14,,,V- 3 (Pages 265 to 268) 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) 92efSb62-38a5-4202-a350-6633a5c6813b EFTA00750776 Page 269 1 Q. Okay. And you talked about this case; didn't 2 you — your cases? 3 A. No, we did not 4 Q. Subject never came up, is your testimony? 5 k No. 6 Q. That's correct? 7 A. That is correct 8 Q. Other than that, have you seen or talked to 9 M.? 10 A. No. 11 Q. Okay. Well, didn't you baby-sit for MA 12 son? 13 A. Yes. 14 Q. Okay. When was that? 15 A. Ito not exactly sure. 16 Q. Wasn't that after you went to the beach, 17 approximately a month and a half to two months ago? 18 A. I don't remember if it was before or after. 19 Q. And did she drop how does — how — what 20 was the occasion that she asked you to sit for her son? 21 A. She had to wodc 22 Q. Where was she working? 23 A. I think she was working in like a — like a 24 skin care place. I'm not sure. 25 Q. How many times did you baby-sit for her son? Page 271 1 Q. Did M. ever tell you she was a call girl? 2 A. No. 3 Q. You know what a call girl is? 4 A. Yes. 5 Q. Did you ever ask M. if she was a 6 prostitute? 7 A. No. 8 Q. Did you ever ask how she made her money? 9 A. No. 10 Q. Is M. a prostitute? 11 A. Not that I know of. 12 Q. lies she am been a prostitute? 13 A. Not that J 'mow of. 14 Q. Do you consider yourself to be a prostitute? 15 A. No, l do not. 16 Q. Have you ever engaged in prostitution? 17 A. Besides Jeffrey Epstein, no. 18 Q. Well, what do you -- what do you consider a 19 prostitute to be? 20 A. Somebody who gets paid for giving sexual 21 favors. 22 Q. Separate and apart from any activities with 23 Mr. Epstein, have you ever performed or given sex, 24 sexual favors, using your term, for money? 25 A. No. Page 270 1 MR. EDWARDS: Object to the form. 2 BY MR. CRITTON: 3 Q. Or watch ber son? 4 MR. EDWARDS: Ever, you mean? 5 MR. CR1TfON: Ever. 6 MR. EDWARDS: Eva. Okay. 7 THE WITNESS: Probably like two or three 8 times. 9 BY MR. CRITTON: 10 Q. Did she pay you? 11 A. Yes. 12 Q. How much did she pay you? 13 A. Well, she only paid me once, like S20 or 14 something. ' 15 Q. Would you let ■ watch your daughter? 16 A. Absolutely. 17 Q. Do you know M. to be or to have been a 18 prostitute? 19 A. No. 20 Q. You know what a prostitute is? 21 A. Yes, I do. 22 Q. Did ■ ever tell you that she received 23 money for giving sexual -- or performing sexual nets for 24 men? 25 A. No. 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 • 22 23 24 25 Page 272 Q. Now, you've worked at some strip clubs; have you not? A. Yes. And ou worked at -down in A. Yes. Q. -- true? A. Yes. . . And I think you said you worked at for approximately eight months? A. Something Lice that, yes. Q. Who was your boss, or who was the manager or the person that you had to report to? A. The owner of the club was named Q. Do you know what his last name was? A. No, I do not. at• that you knew at the time you applied • get — was — was anyone working for the job, the position? A. Yes. Q. Who? A. . And how was it that you came to get a job at that is, why? A. Urn. (561) 832-7500 4 (Pages 269 to 272) 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) 92ef5b62-35a54202-a350.6633a5c6813b EFTA00750777 Page 273 1 Q. This was in 2006? 2 A. It was after I was 18, so... I'm net sure 3 what year. 4 Q. Well, you were bo 5 A. Yes. 6 Q. Okay. 7 All right? So if you worked seven months there or eight 8 months, it would have been sometime after June — what 9 would you say your birthday was? 10 A. Seventeenth. 11 Q. All right. Sometime after June 17th of '06, 12 probably miming into sometime in '07; true? 13 A. Yes. 14 Q. And sole— what caused you to get the 15 job, or why did you come — why did you come to get a 16 job at 17 A. brought me there. 18 Q. Oksy. But your choice to go; right? 19 A. Yes. 20 Q. Okay. And what did you do — what did you 21 or how did it happen that you went to get the job? 22 was dancing there; you knew that? 23 A. Yes. 24 Q. Okay. And she was a stripper? 25 A. Yes. correct? Page 275 1 A. I was living with 2 Q. And were you living at the apartment? 3 A. Yes. 4 Q. That's when she was living with a 5 A. Yes. 6 Q. So you're living at the apartment, and thaim 7 tia you started — you knew she was working a imp so she said, why don't you come with me, or 9 something like that? 10 A. Yes. But this was the second time that I 11 lived with her. 12 Q. I thought you said the second time was in 13 2007. 14 A. I just know that I had tuned 18 since I 15 started dancing, sol may have been close to 19 or 19 16 when I did start 17 Q. Okay. Well, now, was III living at the 18 Royal Palm Bellaire, or was she living in the 19 apartment with 20 A. TIslizal Palm Beach place was an apartment, 21 also, and also lived there. 22 Q. Okay. Well, you testified earlier that in 23 2006 you spent a few -- a few months with her. 24 A. Ult-huh. 25 Q. And then — and that was in the apartment in Page 274 Q. Did she tell you how much money she made? 2 A. No. 3 Q. Did she tell you what she had to do to earn 1 money? 5 A. Dance. 6 Q. What else? 7 A. Take her clothes oft strip. 8 Q. All right. And did she — did she do — did 9 she do bachelor pasties? 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Not that I know of. Q. Okay. Did she do lap dances? A. Yes. Q. All right. And did she work the stage? A. Yes. Q. Did table dances, as well? A. They don't have table dances. Q. What do they have? Lap dances? A. Yes. Q. And what did tell you about that work? A. She just told me that, like, you had to go on stage and dance, and that's how you made money, by dancing. Q. Did you say -- what were you doing at the time? Where were you living in 2006 when you had just turned 18? 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 276 West Palm Beach. And then the second time, 1 thought you said you only spent about a month. I may have been wrong. A. Yes, 1 did only spend about a month. Q. Okay. Was — and the one month was at the Royal Palm Beach house? A. Yes. Q. Okay. s ' r testimony that you went to work at in 2007? A. That's possible. Q. Well, I don't know, because I wasn't there. That's why I'm just trying to ask. Because earlier you testified it was 2006, and I think that's what your answers to interrogatories reflect. So what is it? A. Well, it -- Q. What's the current answer? MR. EDWARDS: Object to the form. THE WITNESS: It was definitely after I armed 18. 1 don't know exactly what day it was. I don't know what month or year. I don't know. I don't like write down, I started stripping today. No, !didn't do that. BY MR. CRITTON: Q. Do you ever keep diaries? A. No. (561) 832-7500 5 (Pages 273 to 276) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 92et6b62-38a6-42024350-8833a6c6813b EFTA00750778 1 2 3 5 6 7 8 9 10 1.1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 277 Q. Have you kept diaries? A No. Never. Q. Have you filed any tax returns? A. No. Q. Have you ever filed a tax retum? A. No. Q. Have you ever consulted anyone about whether you need to file a tax return? A. No. that When you worked — so is it your recoiled ion . was living — or you were living with II. at Royal Palm, or West Palm, at the time you started stripping? A. Royal Palm. Q. What work — before you started stripping, what work had you ever done to make money, other than A. Tithes it. a. ... and I think you told me about A. Yes. Q. That was like a, what, a week or a month or something? A. A week. Q. Excuse tne. And that didn't work out; right? Page 279 1 Q. Okay. Because was when you were 17? A. Yes. 3 Q. So what other jobs did you — had you ever 4 applied for another job, other than I.? 5 A. Yes. 6 Q. Where? 7 A. At the mall. 8 Q. But no one had ever hired you? 9 A. No. 10 Q. So how many different places did you apply 11 for a job? 12 A. A few. Two or three, maybe. 13 Q. So you applied for the jobs. You didn't get 14 those. You quit the job voluntarily, because you 15 didn't like it; right? 16 A. Right. 17 Q. Because you weren't getting along with whom? 18 The boss? 19 A. No. 20 Q. Who? 21 A. It was actually M.'s brother that I was not 22 getting along with. 23 Q. What's his name? 24 A. 25 Q. nwhat? Page 278 1 A. Right. 2 Q. Okay. So the only odier'ob u've had in 3 your entire life was working at E.? 4 A. Yes. 5 Q. OkaiyAnd why did you leave? Once you got 6 thejcb at as a waitress, why did you stop working 7 at Mr/ 8 A. ljust — I don't know. Ijust didn't want 9 to work there anymore. I guess I just wasn't getting 10 along with everybody. 11 Q. Okay. One month? 12 A. Yes. 13 Q. Okay. And you got salary or minimum wage? 14 A. Yes. 15 Q. Plus tips? 16 A- Yes. 17 Q. How much money did you make there? 18 A Not very much. 19 Q. All right. So now you're 18, or over 18, 20 maybe over — closer to 19. The onl er 21 had in your whole life is working at for minimum 22 wage and tips; right? 23 A. Yes. 24 Q. Had you been to yet? 25 A. Yes. Page 2.;Sfl 1 A. 2 Q. And why? Why weren't you getting along with 3 him? 4 A. Because he -- well, I thought that he stole 5 some money from the restaurant while I was working one 6 night. And he called me and said a bunch of nasty 7 things to me, because I was basically implicating that 8 he had stolen some money from the restaurant. . 9 Q. Well, you believed it to be true? 10 A. Yes. 11 Q. Okay. And so what, what happened? 12 A. He was just like really rude to me all the 13 time, and ho told me that he was like — I — I mean, I 14 don't remember specifically what he said, but he told me 15 that, you lmow, he was going to like, you know, do 16 something to hurt me or my family. 17 Q. So you stopped working. Did you tell M. 18 that? 19 A. Yes, I did. 20 Q. And so how, then, did you get the strip job? 21 M. said, well, why don't you come with me; you can 22 strip. 23 A. Yes. 24 Q. And did you say, l don't really want to be a 25 stripper? 6 (Pages 277 to 280) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. ' (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1652) Electronically signed by Pamela Sullivan (501.333.772-1552) 9205662-36a5-4202-a350-6633a5c6813b EFTA00750779 Page 281 1 A. At first I did, yes. 2 Q. And so why did you do it? 3 A. Because I needed money. 4 Q. Well, you could have applied for other jobs; 5 couldn't you? 6 A. I tried to apply at a few places, and I never 7 got the job. 8 Q. Well, you applied for what, one or two places 9 in the mall? 10 A. I applied at some restaurants and some other 11 places I don't exactly remember. 12 Q. So you go down with to 13 A. Yes. 14 Q. And you talked to 1= 15 A. Yes. 16 Q. Is he the one who hired you? 17 A. Yes. 18 Q. Did you have any experience dancing. 19 stripping? 20 A. No. No. 21 Q. And what did you have to do in order to get 22 the job? 23 A. Show them my ID. 24 Q. And did he say, have you stripped before? 25 A. No. Page 283 1 Q. Where did you get them? 2 A. I got a lot of them from the flea market. 3 Q. 45th Street? 4 A. Yes. 5 Q. And they have stripper outfits'? 6 A. Yes. 7 Q. Did a show you any of her tricks of the 8 trade, so to , so you could make money? 9 A. She just showed me how to dance. 10 Q. Did she show you before you went up there 11 that fast time? 12 A. Yes. 13 Q. Where did you — did you practice at home — 14 or at her home? 15 A. No. 16 Q Where did you practice, or didn't you? 17 A. 18 Q. So you ill:Practice during the day before At 19 you actually ended up on stage? 20 A. Yes. 21 Q. Did you know any of the other girls who 22 worked at before you went? 23 A. No. 24 Q. Did you ever work at a place where - 25 worked? 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. A. Q. A. No. Q. Did tell you how — show you how you'd have to dance, in order to make money? A. Yes. . Oka . During the time you worked at did you have a stage name, or did you just use your own name? A. Yes, I did. Q. Yes, you did what? Have a stage name? A. I had a stage name. Q. What was your stage name? MR. EDWARDS: Form. THE WITNESS: BY MR. CRITrON: Q. A. Yes. Q. Okay. And what kind of outfits did you wear? Did you have one outfit that was like the -- your trademark, so to speak? A. No. Q. What kind of outfits did you wear? A. Stripper outfits; I don't know. Page 282 Did he ask you any questions at all? No. Had you ever danced before anyplace? 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 284 A. No. Q. Were you aware where worked? A. No. Q. Okay. Were you ever aware that at .A 10. Q. Do you know what a jack shack is? A. I've heard of it. Q. Okay. Do you know whether M. worked shacks? A. Q. A. Q. A. Q. A. a? Not that I know of. Did you ever ask ha'? Na Do you know a lady -- a person named a? No, I do not. You sure? Yes. She's a fried of E's. You don't know MR. EDWARDS: Object to the form. Asked and answered. THE WfTNESS: I don't know her. BY MR. CRITTON: Q. What were your hours at A. Seven to 2:00. (561 ) 8 32-7 500 7 (Pages 281 to 284) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1652) 92et5b62-38x5.4202.a350.6633a5c6813b EFTA00750780 Page 285 1 Q. Seven p.m. -- 2 A. Yes. 3 Q. — to 2:00 in the morning? 4 A. Yes. 5 Q. Okay. And how were you paid? 6 A. Tips. Q. Did you have to share any with the house? a A. Yes. 9 Q. And what was the percent that you got to 10 keep, and the percent that you had to pay the house? 11 A. I just had to tip the DJ and the manager like 12 $15 each, or something. 13 Q. Okay. And how much did you make generally a 14 night? 15 A. I don't know. Couple of hundred dollars. 16 MR. EDWARDS: Speak a little bit louder, just 17 so that they can hear you. 18 BY MR. CRITTON: 19 Q. Couple of hundred dollars? 20 A. Yes. 21 Q. Okay. Did you ever make more than that? 22 A. Not really. 23 Q. That was pretty much your average take? 24 A. Yes. 25 Q. How many days a week did you work? 1 2 3 4 5 6 7 8 9 10 13. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 287 Have you ever had any kind of plastic surgery? A. No. Q. Any kind of had any kind of breast implants? A. No. Q. In tents ofa in addition to doing the dancing on the stage, did you ever do bachelor parties? A. No. Q. Okay. Did you do lap dances? A. Yes. Q. And how much did you charge for a lap dance? A. There was a house fee, so it was like 25 or $30 for like one song. Q. So in addition to your stage dancing, where you get tips, you also did lap dances? A. Yes. Q. All right. And 'Awe they friction dances? A. Yes. Q. And in terms of the men that you — and these were always all with men; I assume. Any women? Did you have to do lap dances for women at times, too? A. Like once or twice. Q. And when you would do the lap dances for the men, in addition to the house charge, you would try to Page 286 1 A. Whenever I wanted to. 2 Q. All right. How many days a week did you want 3 to work? 4 A. Sometimes it was every night; sometimes it 5 was one or two nights. 6 Q. And how would you decide, just if you needed 7 money? 8 A. Pretty much, or if I felt like it. 9 Q. In addition to doing — you'd dance and you'd . 10 take your clothes off; right? 11 A. Yes. 12 • Q. Okay. And did you take all your clothes off? 13 A. Yes. 14 Q. Okay. Everything, tops and bottoms? 15 MR. EDWARDS: Object to the form. 16 THE WITNESS: Yes. 17 BY MR. CRITTON: 18 Q. And you did that sometimes seven days a week, 19 • sometimes only two or three or four times a week, for 20 eight months; is that correct? 21 A. Yeah. Sometimes I didn't go for two weeks 22 and, you know, I — I just went whenever I felt like it. 23 I mean, sometimes I didn't go for a month. 24 . Did — and and prior to starting at 25 or let me ask you — ask you this: 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 288 do more so that you could get a bettor tip; true? A. No. Q. Okay. Well, you were doing friction dances, and flictice dances are where you're rubbing up against the men; right? A. Yes. Q. All right. And men get erections; truc? MR. EDWARDS: Object to the form. THE WITNESS: That's probably true, but I never touched anybody at the strip club there. BY MR. CRITTON: Q. OkaySo u' re saying you danced for eight months at you're doing friction dances, dancing with men, and it's your testimony you never know you never knew whether any of them ever got an erection; is that true? MR. EDWARDS: Fenn. THE WITNESS: Yes: BY MR. CRITTON: Q. Did you -- did they have a champagne room. or some equivalent of that, at — excuse me — A. Yes. Q. Okay. Did you ever go back into the champagne room? (561) 832-7500 8 (Pages 285 to 288) PROSE COURT REPORTING AGENCY, INC. 1561) 832-7506 Electronically signed by Pamela Sullivan (5014334124652) Electronically signed by Pamela Sullivan (601.333.772-1652) 92efSb62-38a5-4202-a350-6633a5c6813b EFTA00750781 Page 289 1 A. Yes. 2 Q. On how many occasions? At least once a week? 3 Twice a week? More? 4 A. I don't — 5 MR. EDWARDS: Form. 6 THE WITNESS: I don't know. Once a week. 7 BY MR. CRITTON: 8 Q. All right. And when you would go back in the 9 champagne room, it would be you and — and just one man, 10 generally? 11 A. And a bouncer outside the door. 12 Q. Okay. So ifyou needed help, or if 13 something -- • 14 MR. EDWARDS: Form. 15 BY MR. CRITTON: 16 Q. — happened that was inappropriate, then you 17 can call for the bouncer? 18 A. Yes. 19 Q. Okay. And just when you were at -- when you 20 were at that club, if something inappropriate happened, 21 you could turn around and say you could leave the 22 room; right? 23 A. Yes. 24 Q. All right And you — and you knew that -- 25 A. Yes. Page 291 1 BY MR. CRITTON: 2 Q. And did you get more money for that, as well? 3 A. Yes. 4 Q. Okay. And did you strip naked in the 5 champagne room? 6 A. I didn't take my bottoms off. 7 Q. Took your top off? 8 A. Yes. 9 Q. And then you did a — would it be a fair 10 statement to say that would have been a serious friction 11 dance in the champagne room? 12 A. No. It just made it so that other people 13 couldn't see. 14 Q. All right. Well, is — isn't it true, when 15 you went into the champagne room, there's — oftentimes 16 there was some form of sex that occurred? 17 MR. EDWARDS: Fenn. 18 THE WITNESS: That is not true. 19 BY MR. CRITTON: 20 Q. So it's your testimony that in all of the 21 times that you went in the champagne room, that you 22 never had any type of sexual activity with the men in 23 the champagne room? 24 A. That is correct 25 Q. And consistent with what you told me earlier, 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 290 Q. — that if something inappropriate happened, and that you could leave the room, because it was -- it was voluntary for you to either go into the room or not go into the room? A. Yes. Q. You could stay as long or as little as you warn? A. No. Q. Well, you could leave, if the — what you felt the man's conduct was inappropriate; true? A. Yes. Q. Did you ever have to call a bouncef/ A. Yes. Okay. Did any male at that —atIMMI MB ever try to attack you, to we force? A. I — I don't — I wouldn't really say that anybody tried to attack me, but there have been a few times where a man like tried to grab me and pull me on top of him, and I had to call somebody to help me. Q. Okay. And when you were in the champagne room, they'd — the men paid more for that; did they not? MR. EDWARDS: Object to the form. THE WITNESS: Yes. Page 292 1 you never even saw whether a man got an erection when 2 you were in those rooms; is that your testimony? 3 A. Yes. 4 Q. During the time you worked at 5 how many men did you go home with? 6 A. Zero. 7 Q. In addition to -- did you ever do a bachelor 8 party? 9 A. No. 10 Q. Did you ever do a strip-o-gram? 11 A. No. 12 e and apart from the dancing you did 13 at did you ever go to anyone's house to 14 perform any type of strip tease services? 15 A. No. 16 Q. lf someone would testify that you had, that 17 person would be saying would be not telling us the 18 truth? 19 MR. EDWARDS: Object to the 20 BY MR. CRITTON: 21 Q. Is that correct? 22 A. Absolutely. 23 Q. Did you like stripping? 24 A. No. 25 Q. Why did you do it, then? form. (561) 832-7500 9 (Pages 289 to 292) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772.1652) Electronically signed by Pamela Sullivan (501.333-772.1552) 92ef5b62-38351202.3350-6633a5c6813b EFTA00750782 Page 293 1 A. Because I needed money. 2 Q. For what? 3 A. To live. 4 ..thought you were living with — with. 5 at this time. 6 A. Yes. 7 Q. Okay. Well, you said earlier that she 8 supported you. 9 A. Would you like to be 18, asking. 10 for money? 11 Q. My question to you is: You told me that she 12 was supporting you. Did you tell au 13 were stripping? 14 MR. EDWARDS: Object to the form. 15 THE WITNESS: Yes. 16 BY MR. CRITTON: 17 Q. Okay. And what did she say? 18 A. I don't know. 19 Q. She had to have said something. Did she ever 20 say, you don't — I don't want doing that? I'll 21 help you get a job a You can come to work 22 for me. I'm a manager; I can help you get a job. 23 A. No. 24 Q. And did you ever sa h , M, can you 25 help me get a job at I'd like to — 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 29 A. No. Q. Why not? A. I guess they weren't hiring. I don't know. Q. Okay. Did you keep going back? A. Yes. Q. Say, I have experience? A. Yes. Q. How many places do you think you applied before you started stripping? A. I don't know. i . iftierTu left then you went to A. Yes. Q. Were you still living with A. Yes. Q. Were you dating anybody at this time period, this time period being were you dating anybody during the time you were wo A. I started seeing at the time. Q. And that would have been in 2007? A. Yes. Q. Okay. And when did you and start living together? A. I believe it was August of'07. Q. Is he employed? Page 294 1 like to work at You know TM smart. You 2 know I'm qualified. I can do something there. Can you 3 help me do theft 4 A. I can't work at because I live 5 with her. 6 Q. Okay. Well, did you say, can you help me get 7 a job someplace else then? 9 A. No. 9 Q. Why not? 10 A. Because I tried before. 11 Q. Well, if I send you an interrogatory that 12 says, tell me all the places you applied, I should be 13 able to get applications of all these places that you 14 applied; right? 15 MR. EDWARDS: Object to the form. 16 THE WITNESS: So what do you mean? You want 17 the applications that I -- 18 BY MR. CRITTON: 19 Q. • Yeah. How many places did you ever apply 20 before you started stripping? 21 A. I don't know. I went to 22 Q. Two or three? 23 A. I went to the few places at the mall, and I 24 went to all the restaurants that were around my house. 25 Q. And nobody would hire 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 296 A. Not currently. Q. Has he ever been? A. Yes. Q. What kind of work did he do? A. He worked at washing cars. Q. What's his educational background? A. He dropped out in the tenth grade. Q. Is he a Palm Beach County person? A. Q. When is the last time — when you met him, he was working for A. No. Q. Who was he working for, or was he not working? A. He was not working at the time. Q. Okay. When you started living together in August of'07, did he have a job? A. He afterward. Q. At A. Yes. Q. And how long did he work with IM? A. He worked at a restaurant in Boca for like eight months, l think, or seven months, maybe. And then he didn't have a job for, oh, probaayieven months again, and then he got the job at =. SMIL• 44•45... .-.4.,••••01.7a.".•....4...n.le...... , W • J %Ps 10 (Pages 293 to 296) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan ([01.933.772.1652) Electronically signed by Pamela Sullivan (601-333-772-1552) (561) 832-7506 92ef5b62-38a5-4202-a350-6633a5c6813b EFTA00750783 1 2 3 4 5 6 Page 297 Q. But Ws -- are you saying he's working there now? A. He is not working there now. Q Okay. How long did he work -- at the Boca res which restaurant did he work at? AAuartt ). 1 2 3 4 5 6 Page 299 A. For sale of cocaine. Q. So he's a drug dealer —or was a drug dealer -- MR. EDWARDS: Farm. THE WITNESS: He — BY MR. CRITTON: 7 Q. Doing what? 7 Q. — is that true? 8 A. Bus — busboy. 8 A. He got cocaine from a friend of his and sold 9 Q. Okay. And then he was off for aboutak- 9 it to somebody else and — 10 six ors oreven months, and then he got ajob wit 10 Q. So he's a drug dealer; he sold drugs? 11 11 MR. EDWARDS: Form. 12 A. Yes. 12 THE WITNESS: That was not his occupation. 13 Q. Okay. How long did he have that job washing 13 He actually was doing it like as like a one-time 14 cars? 14 thing, and — 15 A. Fm not sure. Probably about the same length 15 BY MR. CRITTON: 16 of time. 16 Q. Being a good neighbor? 17 Q. All right. When — and when did he get — 17 MR. EDWARDS: Form. 18 did he get laid oft; or fired in — well, let me strike 18 THE WITNESS: -- ended up getting caught. 19 that. 19 BY MR. CRITTON: 20 From the restaurant job, did he get laid off, 20 Q. How long has he been using drugs? Since you 21 or fired? 21. two have been dating? 22 A Fm not exactly sure. 22 MR. EDWARDS: Form. 23 Q. Okay. How about-? 23 THE WITNESS: He has not used drugs since I 24 A He - he got another job as a telemarketer. 24 was pregnant with my daughter. 25 and so quit the job ail". And then the 25 Page 298 Page 300 telemarketing job didn't work out. 1 BY MR. CRITTON: 2 2 Q. Okay. Well, when did he when did he get Q. What was that, last for a month or I ing? 3 A. He was -- he stayed there for about three 3 charged with sale of cocaine? 4 weeks, maybe a month, and didn't make any money, so he 4 A. Over a year ago. S ended up having to leave them. 5 Q. Okay. Well, a year ago your daughter had 6 Q. And you say a Boca restaurant. Do you think 6 just been born. Your daughter is a little over a year 7 he was terminated? 7 old right now; right? 8 MR. EDWARDS: Form. 8 A Probably about two years ago. 9 THE WITNESS: I know that he was terminated. 9 Q. Two years ago what? 10 I don't know if he was laid off or fired, though. 10 k He was charged. 11 BY MR. CRTITON: 11 Q. Oh, okay. I thought you said a year ago. 12 Q. And - and with the telemarketing job, when 12 MR. EDWARDS: Form. 13 did he last have the telemarketing job? 13 THE WITNESS: I said over a year ago. 14 A. About a month or two ago. 14 BY MR. CRITTON: 15 Q. Is he out looking fora job? 15 Q. Oh, over a year ago. 16 A He is trying to get a job, yes. 16 So how long has he been on house arrest? 17 Q. Okay. Does he have any type of criminal 17 A. One year. 18 record? 18 Q. Has he been — so he hasn't been able to 19 A. Yes. 19 work? 20 Q. For what? 20 k Yes. 21 A. He is — 21 Q. He has been? 22 MR. EDWARDS: Form. 22 A. He's allowed to work. 23 TI/E WITNESS: He's on house arrest right now. 23 Q. Oh, he got -- he gets work release? 24 BY MR. CAUTION: 24 A. He — 25 Q. For what? 25 MR. EDWARDS: Form. `--Prcatec=ere, 11 (Pages 297 to 300) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772.1652) Electronically signed by Pamela Sullivan (601-333-772.1552) 92e15b82-3844202435048838608813b EFTA00750784 Page 301 1 THE WITNESS: He makes a schedule every week 2 of what het going to be doing all week long. 3 BY MR. CRITTON: 4 Q. Okay. So he gets arrested for the sale of 5 cocaine, but he's he's arrested, but at some point he 6 got put on probation or something so he could do -- or 7 part of his program is he gets a work release so he 8 wouldn't have to be on house arrest; right? 9 MR. EDWARDS: Font]. 10 THE WITNESS: He is on house attest 11 BY MR. CRITTON: 12 Q. But he can go to work? 13 A. Yes. 14 Q. But he doesn't have a job now? 15 A. Not now. 16 Q. How do you guys -- and you don't have a job 17 right now? 18 A. Right. 19 Q. Okay. So how do you two support yourself - 20 when was the last time you had work? 21 A. Since' had my daughter. 22 Q. Okay. So you haven't worked since June — 23 probably before June 29th of '08; coned? 24 A. Yes. 25 Q. Okay. And has not worked since when? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 303 1 Q. Do you — you rent forma family member? 2 MR. EDWARDS: Fan. 3 • THE WITNESS: Yes. 4 BY MR. CRITTON: 5 Q. Isn't it true, ma'am, that lavas 6 selling cocaine so as to help support you and himself 7 and the child? 8 MR. EDWARDS: Form. THE WITNESS: No. BY MR. CRITTON: Q. When is the last time you did work? A. Before 1 became pregnant with my daughter. Q. d you last work? A. Q. Did you laant during the time you were working at A. Yes. anew you wassis ailitv you were working at A. Yes. Q. Okay. What did he think about that? He was okay with that? MR. EDWARDS: Form. THE WITNESS: No. Page 302 A. About three weeks ago. 2 Q. When he was working at rand as a 3 telemarketer, did he make enough money to support you 4 so — in -- in the house that you're living in? 5 A. Yes. 6 Q. Okay. How much did he make as a — as a — 7 working, washing cars at Ilia 8 A. Pm not exactly sure. Like ten dollars an 0 hour. 10 Q. Does anybody help you pay towards your -- do 11 you rent or lease — do you rent or lease — do you 12 lease or pay a mortgage payment on the house? 13 A. Rent. 14 Q. And do you rent from someone you know? 15 A. Yes. 16 Q. Who? 17 MR. EDWARDS: Form. Don't answer. Same 18 objection that we've been going through the whole 19 time; its just going to identify the address. 20 BY MR. CRITTON: 21 Q. How much do you pay a month for rent? 22 A We were paying a hundred dollars every week, 23 so that's $400 a month. 24 Q. Do you pay the electric, too, all utilities? 25 A. No. We just had to pay that Page 304 1 BY MR. CRITTON: 2 Q. Why did you do it, then? Why didn't you get 3 a — try to get another job? You were — well, let me 4 strike that. 5 How long did you work at MEM 6 A. About six or 7 Q. So between_ which was about 8 eight months, and you worked about a year, 9 like 14 to 15, 16 months, doing stripping; is that 10 correct? 11 A. Yes. 12 Q. Okay, rayagglipjo go back to stripping 13 once you finish or once you finish — 14 once your daughter starts school? 15 A. No, 1 do not. 16 Q. You don't have any intention of going back 17 into the stripping business? 18 A. No, I do not 19 Q. When you were at MEN where was that 20 located? 21 A. West Palm Beach. 22 Q. And that's the one off 1 think 23 you said? 24 A. Yes. 25 Q. Okay. And who was your boss there? ,w. (561) 832-7500 PROSE COURT REPORTING AGENCY, 12 (Pages 301 to 304) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (601.333-772-1552) 92ef5b62-38a5-4202-a350-6633a5c6813b EFTA00750785 Page 305 1 A. There were a few managers there. One of them 2 was named 3 Q. Was he the last manager when you left, when 4 you stopped working? 5 A. Yes. 6 Q. What did you have — w was the deal -- 7 financial deal with Tips, and then you had 8 to tip the DJ and the manager again? 9 A. Yeah, but — yeah, pretty much it was the 10 same. 11 Q. Anything different about your financial 12 arrangement there? 13 A. No. 14 Q. And in order to get that job — well, let me 15 strike that 16 Was working there, too? 17 A. No. 18 Q. Was El working there? 19 A. No. 20 Q. Anyone that you knew? 21 A- Yes. 22 Q. Who? 23 A. A girl that I met at 24 Q. Who was? 25 A. I don't know her real name. Page 307 1 A. Sometimes, yes. 2 Q. All right. And you'd get tips from people 3 who would put money wherever? 4 A. They would throw it on the stage — 5 Q. Okay. 6 A. — on the floor. 7 Q. Could — could they put money into your — if 8 you still had your bottoms on, could they — would you 9 allow them to put money into your G-string? 10 A. No, I wore a garter on my leg. 11 Q. Okay. Would you allow them to put money into 12 your garter? 13 A. Yes. 14 Q. Okay. And when you were dancing, did you 15 dance right dugjailaBLof thc-lagisiag men? 16 That is, both "id did they 17 have a bar right that was adjacent to the stage, so 18 that they're they're sitting right at the stage 19 level? 20 A. Yes. 21 Q. All right. And so you're dancing naked in 22 front of them at times; correct? 23 A. Yes. 24 Q. Okay. And as you're dancing, you're going up 25 and down — they have a pole there; I assume? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 1.5 16 17 18 19 20 21 22 23 24 25 Page 306 Q. What was her stage name? QA.t MR. EDWARDS: She'll subpoena her. MR. CRITTON: rm sure you'll -- you'll assort privacy rights. MR. EDWARDS: Good idea. BY MR. CRITTON: Q. Did you do lap dances at MM. A. Yes. Q. And did you do any bachelor parties at= A. No. Q. Okay. Again, friction lap dances at.. A. .Yes. Q. Did they have a champagne room? A. Yes. Q. Same, did you use the champagne room whenever you could because ou would make more money? A. was -- it was kind of different, and I didn't do a lot of champagne rooms there. It was a it felt a lot less safe there. At -- at -- at did you again, when you were on stage, strip down to buck tufted? 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 308 A. Yes. Q. All right. So you're dancing naked, and you're spreading your legs; true? A. What is it — what do you mean? Q. Well, when you're dancing in front of these men and you're completely naked, you're exposing all parts of your body; aren't you, including your genitalia? A. Yes. Q. All right. And you're doing that for then; and you're going close to the bar where those men are being seated — where those men are seated; true? A. No. Q. Okay. So you never went close to the bar? A. No. Q. You just stayed right in the center of the stage? A. Yes. Q. Well, if you stayed in the center of the stage, how could men ever put tips into your garter? A. Because it was at the calf of my leg. Q. So you had to get close enough to the bar that somebody could reach across and put a dollar bill or a five-dollar bill or a 20, or whatever they were tipping, into your garter, right? ••••• ••SMINS•aA .••••••./.• ,•....00.•••• ••JJ•41 13 (Pages 305 to 308) (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 92eft5b62.380-4202.435043833a5c8813b EFTA00750786 10 11 12 13' 14 15 16 17 18 19 20 21 22 23 24 25 Page 309 1 A. Yes. 2 Q. All right. So you did get close to the edge 3 of the stage -- . 4 MR. EDWARDS: Form. 5 BY MR. CRITTON: 6 Q. -- when you were naked: true? 7 MR. EDWARDS: Form. 8 BY MR. CRITTON: 9 Q. You had to. Otherwise, their — their arms 10 could not have reached your garter, ma'am — 11 MR. EDWARDS: Form. 12 BY MR.. CRITTON: 13 Q. -- isn't that true, ma'am? 14 A. Yes, I — !would put my leg far enough to 15 where they could reach it, yes. But I didn't go like 16 right up to them in order to dance in front of their 17 face like that. 18 Q. On the friction dances that you did at lap -- 19 at there were many occasions that you saw 20 men get an erection; isn't that true? 21 MR. EDWARDS: Form. 22 THE WITNESS: No. 23 BY MR. CRITTON: 24 . Oka . Is it our testimony, neither at 25 or did you ever engage in any Page 311 1 MR. CRITTON: Time period for right now. 2 MR. EDWARDS: Okay. 3 THE WITNESS: Probably a kw months after I 4 met Jeffrey Epstein I had sex with my first 5 boyfriend. 6 BY MR. CRITTON: 7 Q. And was that someone that you had dated for a 8 lengthy period of time? 9 A. I dated him for about a year and a half. 10 Q. Before — did it start before Mr. Epstein? 11 A. Before, yes. 12 Q. And what was this person's name? 13 MR. EDWARDS: Object to the form. 14 Instructing her not to answer. 15 BY MR. CRITTON: 16 Q. And when you say you had sex with him, that's 17 sexual Intercourse? 18 A. Yes. 19 Q. Okay. Did you ever have — did you ever 20 have — perform oral sex on him? 21 A. No. 22 Q. Okay. Did you ever have any type of anal sex 23 with him? 24 A. No. 25 Q. Okay. Other than this person, and we'll call Page 310 1 activity where you saw — where you saw a man with an 2 erection; is that true? 3 A. Yes. 4 Q. Okay. And is it your testimony, to the 5 ladies and gentlemen of the "ti , during the time that 6 you worked at both and for 7 some 14, 15, 16 months that you never engaged in any 8 kind of sexual activity, including using your hand on a 9 man's penis to help him ejaculate during the time you worked there? A. No, I did not. Q. And ifs your — is it your testimony that, up until the time you started seeing a that you had never seen a man's penis, other than Mr. Epstein? • MR. EDWARDS: Object to the form. THE WITNESS: No. BY MR. CRITTON: Q. Okay. When — when did you first see a man's penis, other than Mr. Epstein's? MR: EDWARDS: And I'm just going to place the objection that she's not going to give any names of individuals at this time to protect privacy rights of my client, as well as third panics. So I don't know if you're talking about in terms of time Period -- 1 2 3 4 5 6 7 B 9 10 '11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 312 him Mr. A, when is the next time that you had any sexual activity with anyone? And by sexual activity, I mean where -- either intercourse, oral sex, could be anal sex, anything of that nature. A. I don't know. I was 15. Q. And how old were you when you had sex with person, Mr. A? A. I was 14. Q. You never had any sexual activity with Mr. Epstein; did you? MR. EDWARDS: Pont. THE WITNESS: What do you mean? BY MR. CRITTON: Q. You never had sexual intercourse with Mr. Epstein at any time; did you? A. No. Q. You never had any type of anal sex with Mr. Epstein; did you? • A. No. Q. • You never performed oral sex on Mr. Epstein; did you? A. No. Q. He never performed any oral sex on you; did he? A. No. (561) 832-7500 - . • 14 (Pages 309 to 312) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601433.7724652) Electronically signed by Pamela Sullivan (501-333-7724552) 92etsb62-38a5-4202-a350-6assase6813b EFTA00750787 Page 313 1 Q. Therefore, you bad no type of sexual activity 2 with Mr. Epstein — 3 MR. EDWARDS: Object to the form. 4 . BY MR. CRITTON: 5 Q. — at least, as I've defined it thus far; 6 correct? 7 MR. EDWARDS: Object to the form. 8 THE WITNESS: He touched my — 9 BY MR. CRITTON: 10 Q. Go ahead. Finish your question; then I'll — 11 or your response. 12 A. He touched my vagina with his hand and 13 inserted his fingers. 14 Q. When I asked you the question, and you 15 responded that he — that you and Mr. Epstein never had 16 sexual intercourse, never had any type of anal 17 intercourse, you never had any type of -- you never 18 performed oral sex on him, and he never performed oral 19 sex on you, that was true with all of the visits that 20 you ever had to Mr. Epstein's house; true? 21 A. Yes. 22 Q. Now, with person A, which you said you had 23 sexual intercourse at age 14, and there was a person B. 24 Is this another person you had a long-term relationship 25 with, or was this a shorter relationship? 1 2 3 4 5 6 7 8 9 10 11 12 13 1 4 15 16 17 18 19 20 21 22 23 24 25 Page 315 BY MR. CRITTON: Q. — and how old were you? MR. EDWARDS: You can answer the second half. THE WITNESS: I was 16. BY MR. CRITTON: Q. We'll call this person — a man, I assume, male? A. Yes. Q. wen call this Mr. C CRITTON: — because you're going to instruct her not to answer, right? MR. EDWARDS: Right. BY MR. CRITTON: Q. All right. And long-term relationship, or just a short? A. Yes, that was a long relationship. Q. Only sexual intercourse with him? Did you ever have oral sex with him? A. Q. Q. A. A. Yes. Both you to he and he to you? Yes. And that went on over a long period of time? Yes, until after I turned 18. And why did that relationship break up? I — I — I believed he was crazy. Page 314 1 A. Yes, it was a shorter relationship. 2 Q. How old were you then? 3 A I was 15. 4 ' Q. And did you have sexual intercourse with this 5 person? 6 A. Yes. 7 Q. Any oral sex, he to you or you to he? a A. No. 9 Q. Any anal sex? 10 A. No. 11 Q. The next person — and I assume — by who — 12 who is person B? 13 MR. EDWARDS: And my objection is the same. 14 She's not going to give any names of these 15 individuals. 16 MR. CRITTON: You're instructing her not to 17 answer? /.8 MR. EDWARDS: Yes, exactly. 19 BY MR. CRITTON: 20 Q. Okay. And you're going to follow whatever 21 instruction he gives you? 22 A. Yes. 23 Q. All right. Who was the next person, then, 24 you had sexual activity with 25 MR. EDWARDS: Same objection. 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 316 Q. Okay. Was he? You thought he was. A. Yes. Q. Okay. With person A, did you use illegal drugs with person A? A. Yes. Q. Okay. With person B, did you use illegal drugs? A. 'No. Q. Alcohol? A. No. Q. With A, you used both drugs and — illegal — illegal drugs and alcohol; true? A. We both tried our firsts together. We like drank for the first time together, and • Did drugs together? A. Yes. Q. All right. Person C, who you said was crazy, how long was the relationship? A. More than two years. Q. Did you do drugs with him? A.. Yes. Q. Alcohol? A, No. . Q. Okay. Was he a drug dealer? MR. EDWARDS: Form. • 15 (Pages 313 to 316) (561) 832-750C PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601433-7724552) Electronically signed by Pamela Sullivan (601.333-772-1552) 92ef5b62-38a5-4202-a350-6833,15O3813b EFTA00750788 1 2 BY MR. CRITTON: 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 317 THE WITNESS: No. Q. Did he work? A. Yes. Q. What kind of work did he do? A. He laid tile. Q. Did you live together? A. Yes. Q. Where? A. He lived in a — in a trailer in West Palm Beach. Q. Okay. After the two, so 16 through 18, when — during the time that you wore going to Mr. Epstein's house, did you — were you having these relations with A, B, and C? MR. EDWARDS: Form. THE WITNESS: Yes. BY MR. CRITTON: Q. Okay. Wen A— did A, B or C, or any permutation of that group, aware that you were going to Mr. Epstein's? A. No. Q. Did you tell than? A. Na Q. Why not? Page 319 1 you share that, then, with Mr. C or Mr. B, depending on 2 who you were with at the time? 3 A. No. 4 Q. What did you do with your money? 5 A. I bought clothes and things for myself. 6 Q. When you were living with Mr. C,1 think you 7 said, did you where were you living, in a trailer, a 8 house, an apartment? 9 A. We were living in a trailer. 10 Q. And where, what city? 11 A. West Palm Beach. 12 Q. Was he abusive to you in any way, either 13 physically or verbally? 14 A. No. 15 Q. Did you ever have to call the police on him? 16 A. No. 17 Q. You're sure? 18 A. No, fm not sure. 19 Q. Okay. Did he strike you — didn't he? 20 A. He stalked me. 21 Q. Okay. How long — 22 MR. EDWARDS: Is that what you asked, 23 stalked? 24 MR. CRITTON: I said strike. 25 THE WITNESS: He said, did he satin. Page 318 1 A. 1- the only person that knew about it was 2 the last person that I just told you about. 3 Q. C? I A. Yes. 5 Q. Okay. And what did you tell him? He knew 6 you were going to Epstein's? 7 A. He knew that I was going somewhere. 8 Q. How did he know? Did you tell him? 9 A. Yes. 10 Q. What did you tell him? 11 A. I told him that I was going to clean house. 12 Q. Okay. And did you — at the time that you 13 were dating Mr. C, did — how much were you getting paid 14 from Mr. Epstein? 15 A. Usually when I went there, he — he gave me 16 in between two and $300. 17 Q. In cash? 18 A. Yes. 19 Q. Would he give it to you, or would someone 20 else give it to you? 21 A. He would set it down on the counter, 22 sometimes he would give it to me, sometimes somebody 23 else would give it to me. It was different a lot of the 24 times. 25 Q. When you were receiving the money, did — did Page 320 1 MR. EDWARDS: Oh, okay. Sony. 2 MR CRTITON: And she said stalked. 3 MR. EDWARDS: Okay. 4 BY MR. CRITTON: 5 Q. Did he ever strike you? 6 A_ No. 7 Q. When you say he stalked you, !mean did he -- 8 stalking, in my mind, is he would follow or see where 9 you were. 10 A. Yes. He knew things that 1 didn't tell. 11 anybody. He — like I moved and lived withM. so that 12 he wouldn't know where I was, and he found out where I 13 was. 14 Q. Did he come there? 15 A. He would like hide outside in the bushes and 16 stuff. 17 Q. And you knew he was out there? 18 A. Yes. 19 Q. Did you have to call the police and say, fve 20 got a stalker? 21 A. No, I never did that. 22 Q. So were you scared of him? 23 A. Not really. 24 . Q. Were you intimidated by him? 25 A. No. (561) 832-7500 16 (Pages 317 to 320) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333712.1662) Electronically signed by Pamela Sullivan (501333-772.1562) 92ef5b62.38a5-/202-a350.6633a5c6813b EFTA00750789 Page 321 1 Q. Was he harassing you? 2 A. He was harassing me. 3 Q. Okay. I thought 1-- when I asked you 4 earlier and we were talking about, let's see, the 16 and 5 17 year -- let's see, if you lived with Mr. C your 16 6 through 18th year, and you were born in '88 -- 16 -- 7 that takes me to '04 through like 2006. So is that the 8 first time you would have gone tea.'s, when she was 9 living in West Palm Beach, or is this another time you 10 went tca.'s that you didn't remember telling us 11 about? 12 A. No, that was the first time that 1 moved in 13 with'., then, after I left him. 14 15 Q. I thought you bald us you were livi at your house, and you left y house to go 16 live wi 17 A. We were liven in his trailer, and then we 18 were livirtg wi 19 Q. So you were a 16- 17- ear-old irl and you 20 were living with Mr. C a house? 21 A. Yes. 22 Q. What die think about that? 23 A. I don't latow. 24 Q. Well, she let you live there; didn't she? 25 MR. EDWARDS: Form. Page 323 1 true? 2 MR. EDWARDS: Object to the form. 3 THE WITNESS: He touched me. 4 BY MR. CARTON: 5 Q. ! understand that. But he never physically 6 caused you harm? 7 MR. EDWARDS: Form. 8 THE WITNESS: I dent know what you mean by 9 that. 10 BY MR. CRITTON: 11 Q. Well, he never caused an injury to you -- 12 MR. EDWARDS: Form. 13 BY MR. CRITTON: 14 Q. — physical injury to you; true? 15 A. No, he never hit me. I don't know. 16 Q. I'm sorry? 17 A. He never like hit me. 18 Q. After Mr. C — well, let me strike that. 19 How did you get rid of Mr. C, other than you 20 said he was a bit of a nut case, or you thought he was 21 any. 22 A. I just -- I left him. I lived • ' 23 a while, and I moved bads in wi 24 believe my uncle was living there at the time, and he And 25 just,Iguess, moved. Page 322 1 THE WITNESS: Yes. 2 BY MR. CRITTON: 3 Q. During the time that — the some 20 occasions 4 you went to Mr. Epstein's home, would it be a correct 5 statement, Ms. Jane Doe, that he never threatened you 6 with any type of serious harm? 7 MR. EDWARDS: Form. 8 THE WITNESS: Is it true that he never 9 threatened me? 10 BY MR. CAUTION: 11 Q. Right. Mr. Epstein never threatened you at 12 any time you went to his home; isn't that true? 13 A. Yeah, that's true. 14 Q. And he never attempted to physically restrain 15 you; true? 16 A. Yeah. Yeah, that's true. 17 Q. And he never threatened you nor abused you 18 either physically or verbally; true? 19 k He - 20 Q. He never injured you physically? 21 MR. EDWARDS: Is this a different question. 22 • or is she answering the first one? 23 BY MR. CRITTON: 24 Q. Yeah, let me throw it out. Let me ask it 25 this way: He never — never physically injured you; Page 324 1 Q. Okay. Well, was he still living when they 2 moved back in, or did he tell C he had to exit the 3 house -- 4 A. H was 5 Q. -house? 6 A. He was gone. 7 Q. After Mr. C, who was your next relationship 8 with, wished sexual activity? 9 A. 10 4 And Wage time, since the time you 11. started datingMl., which was in what, sometime in 12 2007? 13 A. Yes. 14 Q. Okay. Has he been the only person that you 15 have been sexually active with since Mr. C? 16 A. Yes. 17 Q. So if someone would testify that you were 18 sexual — so if someone were to testify in this case 19 that you were sexually active at the age of 12, what 20 would your response to that be? 21 M. EDWARDS: Form. 22 THE WITNESS: That is not true. 23 BY MR. CAUTION: 24 Q. What was the person you had - Mr. A, how 25 approximately how old was Mr. A? (561) 832-7500 17 (Pages 321 to 324) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772.1652) Electronically signed by Pamela Sullivan (501-333-7721552) 9205b62,18.542024350463.1a6c81113b EFTA00750790 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. A. Q. A. Q. A. Q. A. He was two years older than me. How about Mr. B? Same. How about Mr. C? He was four years older than me. Do you have any piercings? My ears. Other than your ears? No. Page 325 Q. Have you ever advertised for sex, any kind of sexual activity on any website? A. No. Q. When you left Mr. Epstein's house on the very first occasion and you said you and... — I'm sorry — you and.. were walking eastbound on the road? A. Yes. Q. All right. Because you were trying to flag down a cab. A. Yes. Q. Had a cab been called to pick you up? A. Yes. Q. And why were you walking? A. Because the cab didn't come. Q. So you thought maybe it was lost or something? Page 327 1 That is, that's what you thought was going to happen, 2 based on what.. had told you? 3 A. No. 4 Q. Okay. Was it substantially different than 5 what you thought.. had told you would happen? 6 A. Yes. 7 Q. Okay. In fact, you said you didn't think you 8 would have to take your clothes off at all. 9 A. Yes. 10 Q. All right. And you weren't even sure that 11 you'd have to give anyone a massage, because ou 12 thought, based on what you told us, is thatIM. said, 13 I'll give you 200 bucks, just come with me? 14 A. Yes. 15 Q. 16 A. 17 Q. So what, from your perspective, it was hugely 18 different, at least based on what you've told us frorn 19 what.. said you should expect or what you thought was 20 going to happen; correct? 21 A. Yes. 22 Q. So weren't you ticked off at hen weren't you 23 angry with her? 24 A. I don't }mow what to say. 25 Q. Okay. Well, why not? You've been -- you've Come with me to the house; right? Yes. Page 326 1 A. Yes. 2 Q. And that was..'s idea? 3 A. Yes. 4 Q. And as you're walking awa from Mr. Epstein's 5 house the first time, what — did say, well, how 6 did it go? 7 A. No. 8 Q. Okay. Did you yen at.? 9 A No. 10 Q. Were you angry with.? 11 A. No. 12 Q. Did you say anything to.. as to what went 13 on between — excuse me — after she had left? 14 A. No. 15 Q. Why not? 16 A. Because I didn't feel comfortable talking 17 about It. 18 Q. Well, this is — this is the girl who, based 19 on what you've told us, is would be your belief that 20 misled you? 21 MIL EDWARDS: Form. 22 THE WITNESS: What do you mean? 23 BY MR. CRFITON: 24 Q. What occurred at -- what you say occurred at 25 • Epstein's house, is that what you thought the deal 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 328 been angry before. I mean, you -- you testified in court, you testified on depositions you had been a runaway, you know, you know how to pick up and leave if circumstances were not good at a particular house. You had a vast experience in taking care of ourself, to some extent, so why didn't you say toM. something like, what did you get me Into, or what happened, or what was going cm? Did you show any emotion at all to MR. EDWARDS: Form. THE WITNESS: Na BY MR. CRITTON: Q. So youjust got in the car — did you go in a cab? I gather gather a cab came? A. Yes. all:Stkay. Cab came. You get in the car. You andli. aren't talking at all? A. I don't remember any conversation that we had, no. Q. What did you tell the FBI? Didn't the FBI say, what do you mean you didn't say anything to..? MR. EDWARDS: Form. • THE WITNESS: They didn't say that to me. BY MR. CRFFPON: Q. Okay. And then did you tell them that (561) 832-7500 PROSE COURT 18 (Pages 325 to 328) REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333.772-1662) Electronically signed by Pamela Sullivan (501-333-772.1552) 92ef6b62.38a5-4202a350.6633a5c6813b EFTA00750791 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 329 made 200 bucks off of you, a made money off bringing you there? A. Yes. Q. Okay. Did they -- did they tell you, the FBI tell you that if she's making money off of you; she's like your pimp? Did they say that to you? MR. EDWARDS: Form. THE WITNESS: No BY MR. CRITTON: Q. Okay. Do you know do you know what a pimp is? A. Not really. Q. Okay. Do you know that's someone who makes money off of — off of you for taking you someplace where you might make money? MR. EDWARDS: Object to the fonn. THE WITNESS: Why me? BY MR. CRITTON: Q. Pardon? A Why roe? Q. What do you mean, why you? A. What do you mean me? Q. You — well — A I don't have a pimp. Q. I'm sorry? 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 331 THE WITNESS: I do not bow. BY MR. CRITTON: Q. Did you ever ask her how many times she had been at Epstein's home — A. Never. Q. — before she ever took you? A. No. Q. Did she ever tell you what — at any time after the first time that you were at Epstein's home, did she ever tell you how many times she had been there? A. Na Q. Did she ever tell you that she had brought anyplace from 20 to 80 people to Mr. Epstein's home, by her own testimony? A No. Q. Okay. Is that news to you, ass say that to you today? A Yes. Q. So what -- so you don't remember anything that you and, talked about on the way home? A. No. Q. And what did you do with the money that you — that you got, the 200 bucks? A. I bought clothing and things that I wanted. Q. Did III ever ask you to go back to Page 330 1 A. I don't have a pimp. 2 MR. EDWARDS: Form. 3 BY MR. CRITION: 4 Q You know, well, isn't M. — wasn't 5 your pimp? 6 MR. EDWARDS: Form. 7 BY MR. CRITTON: 8 Q. Didn't she take you there? 9 MR. EDWARDS: Form. 10 THE WITNESS: No, she is not my pimp. 11 BY MR. CRITTON: 12 g Well, what is she, then? If she's made money 13 off taking you to Mr. Epstein's, what would you call it? 14 A. Not my pimp. 15 Q. Wasn't your friend; was she? Because she 16 misled you; didn't she? 17 A. She probably didn't know that's what she was 18 doing at the time. 19 Q. She didn't !mow she was doing what? 20 A. What she was doing. 21 Q. How could she not 'mow what she was doing? 22 A. Because she was as young as I was. 23 Q. Okay. Well, how many times had M. been 24 there? 25 MR. EDWARDS: Form. 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 :33: Mr. Epstein's home again? A. No. Q. When you — how did you end up going back to Mr. Epstein's home again? A. I gave him my phone number, and he called me. Q. I'm sorry? A. I gave him my phone number, and I got a call from either him, or Q. Did you meet every first 6me you were there? I think you sat you only met like the blond-headed girl, who subsequently you identified as MR. EDWARDS: Form. THE WITNESS: No, I did not meet the first time I was there. BY MR. CRITTON: Q. Okay. And did someone ask — did Mr. Epstein ask you for your phone number? A. Yes. Q. When you wore upstairs, or when you were downstairs? A. When I was upstairs. Q. And this is you, first time you were there, you've never taken your clothes off — at least that's what you've told us -- in front of any male before, you (561) 832-7500 19 (Pages 329 to 332) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333.772.1652) Electronically signed by Pamela Sullivan (501-333.772-1652) 92ef5b62-38a54202-a350-5633a5c6813b EFTA00750792 Page 333 1 take your clothes off, you give him his massage, yoU • 2 described what occurred that first occasion, he asked 3 for your phone number, and you give it to him? 4 MR. EDWARDS: Form. 5 THE WITNESS: He only told me what to do. He 6 never asked. So I felt like I had to do it — 7 BY MR. EDWARDS: 8 Q. 'Okay. Well -- 9 A. so I did. 10 Q. You had no obligation to do Anything when you 11 were there, ma'am; did you? 12 MR. EDWARDS: Form. 13 THE WITNESS: I feh as if I did. 14 BY MR. CRITTON: 15 Q. Okay. So when you — when he then but 16 whatever you did was completely voluntary on your part? 17 A. Fenn. 18 Q. You could either do it or not? You could 19 have just said, Pm out of here? 20 MR. EDWARDS: Form. 21 THE WITNESS: I only felt like I had to do it 22 because he told me to. He never asked anything. 23 He only would tell me. 24 BY MR. CRITTON: 25 Q. Well, told you what to do. =told 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 335 BY MR. CRITTON: Q. Okay. Well, you — just a minute ago you said, I knew she was bringing other people. Now, did you know she was bringing other people before she brought you? A. Not before she brought me. Q. Okay. Did you find out afterwards that IN had brought a lot of other people? A. No, I only assumed. Q. Okay. Well, did you ever ask a — A. No. Q. — whether she had brought other people? A. No. Q. Okay. So you don't — you didn't know whether she had brought anyone else, and you didn't know what she was thinking, because you never asked her; did you? A. No. Q. So when Mr. Epstein said, could I have your phone number, you had to voluntarily give it to him, because otherwise he couldn't have gotten it; true? MR. EDWARDS: Form. BY MR. CIUTION: Q. You could have given him any number. MR. EDWARDS: Fara. I would just ask that 1 2 3 4 5 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 334 you to take your clothes off. A. He told me to take my clothes off. You know, then you said that you looked at and. was taking her clothes off, and she said, we need to take our clothes off. A. `said that it was ols yes. Q. All right. So, but for being there, you never would have taken your clothes — number one, if it weren't for le you never would have been there; would you? A. `was already convinced that it was okay. Q. How do you know that she was convinced that it was okay? You said you and — A. Because obviously — Q. -- you said you never really talked about it. A. — obviously, she was bringing — Q. So you — A. — other people there. Q. Well, you didn't know that. 'just asked you that a minute ago, whether you knew she -- whether you knew she was bringing anybody else. And you said you didn't know whether she had ever brought anyone else. MIL EDWARDS: Form. THE WITNESS: Well, she brought me. 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 336 you allow the witness to answer your question. BY MR. CRITION: Q. All right. You chose -- you voluntarily gave Mr. Epstein your phone number; didn't you? MR. EDWARDS: Fain. TI-LE WITNESS: He told me to give it to him, so I did, yes. BY MR. CRITTON: Q. You could have given him any number in the whole world. You didn't have to give him your number. How would he know? A. I don't bow. Q. So he asked, and you gave it to him voluntarily; true? MR. EDWARDS: Form. THE WITNESS: Yes. BY MR. CRITTON: Q. Okay. Now, Ms. Jane Doe, when you gay your phone number, I think you said that you told Eff that you had given him your phone number? A. No. Q. Okay. Did ever come to you and say, hey, would you like to go back to Epstein's house again? A. Yes. . Q. Okay. When did she do that? 20 (Pages 333 to 336) ( 5 6 1 ) 8 3 2 - 7 5 0 0 PROSE COURT REPORTING AGENCY; - INC . Electronically signed by Pamela Sullivan (501.333-772.1662) Electronically signed by Pamela Sullivan (501-333-772-1562) (561) 832-7506 92ef5b62.38a5-t202a350.6633a5c6813b EFTA00750793 Page 337 1 A. I don't remember. 2 Q. How much time passed? 3 A. I don't remember. 4 Q. A week? A month? Six months? 5 A. I don't remember. 6 Q. And what did you say? When — what did you 7 say to. when she said, would you lice to go back to 8 the house with me? 9 A. I don't — I don't remember. 10 Q. Well, did you mislead her? Did you say, no, 11 I — I don't want to go back? 12 A. No. 13 Q. Did you tell her, I'm going back on my own? 14 Well, let me ask you this: Had you — strike 15 the last question. 16 lied you gone back to Mr. Epstein's house in 17 between the first time and the time that El next asked 18 you? 19 A. Yes. 20 Q. Okay. How many times had you been back as — 21 how much time transpired between the first time and the 22 second time you went to Mr. Epstein's home? 23 A. lam not sure. 24 Q. Was it a week? A month? A day? 25 A. I don't know who — maybe a week or two. Page 339 1 COURT REPORTER: "Did he ask you whether 2 you'd want to come over?" I didn't bear your 3 response, if you answered. . 4 THE WITNESS: Yes. 5 BY MR. CRITTON: 6 Q. And that one or two occasions that he called 7 you, he basically said, do you want to come over? 8 MR EDWARDS: Form. 9 THE WITNESS: He — I don't remember exactly 10 what he said to me. But, normally, when ?Igor 11 r icalled me they would call me ah o tune 12 to me that Jeffrey was going to be in town, 13 would I like to come over. 14 BY MR. CM-TON: 15 Q. Right. And that was the extent of the 16 conversation? 17 A. They would tell me — 18 Q. You would say yes or no? 19 A. Yes. And they would tell me what day and 20 what time to be there. 21 Q. All right. And you understood that 22 Mr. Epstein has a residence in Palm Beach? 23 A. Yes. 24 Q. And you understood that he had residences in 25 other places? Page 338 1 Q. All right. And then I think you told me 2 someone called you, some — a female called you. 3 A. Sometimes -called me, and once in a 4 while Jeffrey called me himself. 5 Q. Okay. Mr. Epstein never called you directly, 6 did he? 7 A. Yes. 8 Q. You said you went to his house 9 approximately — approximately 20 times — 10 A. Yes. 11 Q. — during the — during the time span that 12 you identified earlier. 13 A. Yes. 14 Q. All right. Would the vast majority of times 15 that he called you — I'm sorry that you were called, 16 either MI or made the call? 17 A. Yes. 18 Q. Okay. On how many occasions, your best 19 recollection, did Mr. Epstein ever call you? 20 A. One. Maybe two. 21 Q. And on the one or two occasions that 22 Mr. Epstein ever calledyou, did he ask you whether 23 you'd want to come ova? What did he say? 24 COURT REPORTER: I didn't hear any response. 25 MR. CItITTON: Oh, I'm sorry. Page 340 1 A. Not at the time. 2 Q. Okay. And you just thought he lived MI 3 time in West Palm Beach or in Palm Beach? 4 A. No, I — [knew that he went out of town a 5 lot. 6 Q. All right. So you knew that he went out of 7 town for business, as well as doing business here in 8 Palm Beach? 9 MR. EDWARDS: Form. 10 THE WITNESS: I have no idea what he was 11 going out of town for. 12 BY MR. CRITTON:. 13 Q. Okay. Did you ever know what his business 14 was? 15 A. No. 16 Q. All right. Was — during the time that you 17 ever gave a massage to Mr. Epstein, did he was he on 18 the phone? 19 A. Yes. 20 Q. Okay. And often would he be doing what 21 appeared to be business over the phone while you were 22 giving him a massage — or engaging in conversations 23 with someone? 24 A. Yes. 25 Q. All right. And did it appear from time to (561) 832-7500 21 (Pages 337 to 340) 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) 92ef5b62-38a5-4202-a350-6633a5c6813b EFTA00750794 Page 341 1 time that he was engaged in business? 2 MR. EDWARDS: Form. 3 THE WITNESS: Sometimes, yes. 4 BY MR. CRITTON: 5 Q. All right. And you understood that — at 6 least you understood that his main residence was in, 7 from what you understood dining the time that you went 8 there, his main residence was in Palm Beach, Florida, 9 and that he would just travel out of town, and then come 10 back into town occasionally, you know, he would travel 11 out of town occasionally, but basically lived in Palm 12 Beath? 13 A. I did not !mow. I really... 14 Q. You said that was the only residence that 15 you — or the only place that you understood that he 16 lived? 17 A. That's the only place that I knew of, but 18 I — I didn't know, you know, what he was doing when he 19 was going out of town or whatever he was doing. 20 Q But you knew he had — he — that was his 21 home, at least one of his homes? 22 A. I 'mew that he lived there. 23 Q. All right. You never traveled anyplace with 24 Mr. Epstein; did you? 25 A. No. Page 343 1 discussed; was it? 2 MR. EDWARDS: Form. 3. THE WITNESS: No. 4 BY MR. CRITTON: 5 Q. Okay. And the one or two times that 6 Mr. Epstein ever called you, the subject of — of any 7 type of engaging in any type of sexual conduct was never 8 dic.nmerad; was it? 9 A. No — yes, it was, actually. 10 Q. Well, ma'am, you said, no; then you said, 11 yes. What is it? What's the answer? 12 A. Yes, he did discuss with me that he would pay 13 me extra money for having sex with him. 14 Q. Did you tell the FBI that? 15 A. Yea And he be tried to, 'guess, 16 convince me to do it by telling me that-- his exact 17 words to me were that he used to fuck all the time. 18 Q. When did — when did this call purportedly 19 take place? 20 A. I was at his house, and... 21 Q. At his house? 22 A. Yes. 23 Q. What were you doing at his house? 24 A. I was giving him a massage. 25 Q. Oh, I thought okay. Maybe you Page 342 1 Q. You never accompanied him on any trip; did 2 you? 3 A. No. 4 Q. Mr. Epstein never text -- text'd you by 5 phone; did he? 6 A. No. 7 Q. Mr. Epstein never e-mailed you or sent you 8 any type of mail; did he? 9 A. No. 10 Q. Neither nor or anyone who worked 11 for Mr. Epstein ever texrd you by phone; did they? 12 A. No. 13 Q. They never sent you anything by e-mail or by 14' mail; did they? 15 A. No. 16 . Okay. And when they — they, either 17 or whoever else may have called, other than 18 Mr. Epstein, they basically said, Jeffrey's in town, 19 would you like to come over? 20 A. Yes. 21 Q And then they would give you a time? 22 A. Yes. 23 And at no time in any conversation with 24 or or anyone who worked for Mr. Epstein was the 25 subject of engaging in any type of sexual conduct ever ur Page 344 1 misunderstood my question. 2 When Mr. Epstein — the one or two times that 3 you ever spoke with Mr. Epstein over the phone, okay, 4 the subject of engaging in any type of sexual activity 5 or conduct never attuned; did it? 6 MR. EDWARDS: Form. 7 THE WITNESS: Not over the phone. 8 BY MR. CRITTON: 9 Q. I'm sorry? 10 A. Not -- 11 Q. Not over the phone? 12 A. —over the phone. 13 14 • All right. And neither = nor or anyone else, including Mr. Epstein, ever 15 attempted to persuade or to induce or to entice you into 16 any type of sexual conduct during any phone 17 communication; true? 18 A. Yes, that's true. 19 Q. Did you ever bring anyone to Mr. Epstein's 20 house? 23. A. No. 22 Q. Do you know a person named 23 cousin? 24 A. 25 . Q. ? who's your 22 (Pages 341 to 344) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (601333-772.1652) Electronically signed by Pamela Sullivan (501-333-772-1552) (561) 832-7506 92ef5b62-38a5-4202.3350-6633a5c6813b EFTA00750795 Page 345 A. Yes. Q. Did you brink; -- you know — you're 1 aware Amanda MI went to Mr. Epstein's home? 4 A. Yes. I did not bring her, though. 5 Q. And she was 19 or 20 when she went; isn't 6 that true? 7 A. Yes. 8 Q. Okay. And who took or asked Amanda to 9 go to Mr. Epstein's home? 10 A. I believe it was.. or.. 11 Q. And how did you find out that your 12 cousin, went to Mr. Epstein's home? 13 A. I don't remember. Either she told me, or 14 told me, or told me. 15 Q. And did you ever talk with ■ about what 16 the did at Mr. Epstein's home? 17 A. No. 18 Q. Was she aware — she, aware that you 19 went? 20 A. I don't think so. 21 Q. And you're aware she went, but you never 22 raised the topic with her? 23 A. Right. 24 Q. By the way, who— who knows that you area 25 Plaintiff in the action, Jane Doe versus Epstein? 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 347 Q. How about your sister, a? A. I haven't told her myself, but I'm sure that she knows, because other people have gone to her house. Q. Okay. Other people have told her, or other people have just asked her questions? MR. EDWARDS: Form. TILE WITNESS: I don't know what she was told. BY MR. CRITTON: Q. Okay. How about I., your sister, ME, does she know you're a Plaintiff in this lawsuit — A. No. Q. — or any lawsuit? A. No. Q. Okay. Have you sold or agreed to assign any portion of any recovery to anyone? MR. EDWARDS: Form. THE WITNESS: No. BY MR. CRITTON: Q. Your psychologist, he knows you're a Plaintiff in a lawsuit? A. Yes. Q. Okay. Who else knows you're a Plaintiff in a civil lawsuit against Mr. Epstein? A. I don't know. Q. Any of your other friends know? Page 346 1 knows; right? 2 MR. EDWARDS: Object to the form. 3 BY MR.. CRITTON: 4 Q. First you need to answer that question. 5 knows you're a Plaintiff; right? 6 MR. EDWARDS: Object to the form. 7 THE WITNESS: Yes. 8 BY MR. CRITTON: 9 Q. Okay. knows you're a Plaintiff? 10 MR. EDWARDS: Form. 11 THE WITNESS: Yes. 12 BY MR. CRITTON: 13 Q. Does know -- 14 A. Yes. 15 Q. — you're a Plaintiff? 16 A. Yes. 17 Q. Does know you're a Plaintiff? 18 A. Yes. 19 Q. Does your mother know you're a Plaintiff? 20 A. I don't know. 21 Q. Did you tell your dad,_? 22 A. No. 23 Q. . So hes unaware that you're — you have a 24 lawsuit that's going? 25 A. No -- he is unaware, 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 Page 348 A. No. Q. Okay. Are you aware that if, in fact, this case is not resolved, you may well — the case may be tried, and your anonymity may no longer exist — MR. EDWARDS: Form. BY MR. CRITTON: Q. -- because everyone may know that you're the Plaintiff', Jane Doe, against Mr. Epstein; do you understand that fact? MR. EDWARDS: Form. THE WITNESS: Yes. BY MR. CRITTON: Q. I think you told me you never brought any other girls to Mr. Epstein's home? A. No. Q. Okay. After you said asked you if you — if you would like to go back to Mr. Epstein's.— to it Epstein's house, but you had already been back in the interim; true? A. Yes. • Q. Okay. And who — I. or someone else had called you and asked you if you wanted to come back? A. Yes. Q. And where were living at the time? A. With _ - (561) 832-7500 23 (Pages 345 to 348) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772.1552) 9205652-38a5.4202-a350-843315e8M3b EFTA00750796 Page 349 1 Q. Who drove you to Mr. Epstein's house? 2 A. Cab. 3 Q. When the person called and asked whether you 4 want — whether you wanted to come back, what did you 5 gin 6 A. At first I didn't go. 7 Q. Okay. So the call or whoever 8 called, and you said, Pm not interested. 9 A. Yes. 10 Q. All right. And did you say, don't call me 11 again? 12 A. No. 13 Q. Why not? 14 A. I didn't think to say something like that. 15 Q. And did you get another call? 16 A. Yes. 17 Q. And you had a cell phone at the time? 18 A. Yes. 19 Q. And what cell phone number was that? Was 20 that the 584? 21 A. No. I don't remember the entire number. It 22 was a number that started with 352, though. 23 Q. That's the 352 one you don't remember? 24 A. Uh-huh. 25 Q. But cell phones pop up a number, so you -- do Page 351 1 A. Yes. 2 Q. And she said, you know, I know you couldn't 3 come last time. How about coming this. Would you like 4 to come? 5 A. Yes. 6 Q. And did you say, no, not interested anymore, 7 don't call me anymore? 8 A. No. 9 Q. Okay. Son called a second time, and you 10 said what? 11 A. She told me that she — that Jeffrey needed 12 me to come, because he didn't have anybody else who 13 could came. SO I came. 14 Q. How was that your problem? 15 A. It wasn't. 16 Q. All right. So she said that — she said what 17 you just described, and you made a conscious decision 18 that you would go back to Mr. Epstein's home? 19 MR. EDWARDS: Form. 20 THE WITNESS: Yes. 21 BY MR. CRITFON: 22 Q. Right. And you voluntarily chose to go back 23 to his house a second time? 24 A. Yes. 25 Q. No one forced you; correct? Page 350 1 you remember what number that would be called -- that 2 is, the number that would be calling you -- 3 A. Yes. 4 Q. — from the Epstein home? 5 A. Yes. 6 Q. That number you do remember? What was the 7 number? 8 A. I don't — it was always a different number, 9 and it normally started with 688. 10 Q. Why did you answer it? 11 A. I didn't know who it was. 12 Q. Okay. So I assume you knew how to do voice 13 messages, voice mail; right? 14 A. I just answered it. 15 Q. My question is, is: Why didn't you just 16 let — if you weren't sure who the number was, a lot of 17 people just let the phone ring, go to voice mail. Then 18 if you want to call them back, you call them back. If 19 you don't want to call them back, you don't have to. 20 MR. EDWARDS: Form. 21 THE WITNESS: Because I wanted to know who it 22 was. 23 BY MR. CR/TION: 24 Q. Okay. So they called, and who was it? III 25 seam or someone? 1 2 3 4 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 352 A. Correct. Q. Okay. And it was your choice. That is, you could have said, sony, I'm not going back to the Epstein home. Didn't enjoy the experience. Wasn't a good experience. Pm done. You could have done that; couldn't you? A. I didn't think of doing that, no. Q. Sure you thought of it because the first phone call that you got from you said, no, I'm not going, So you had to have consciously thought is, I don't want to go again; right? A. No. Q. lint sony? A. No. Q. No what? A. That wasn't my thought. Q. But your first thought was, when she called you the first time was, is, I don't want to go back; HMO A. No. Q. Okay. So after the first time that you went, you had already made up your mind you would go again, if they called? A. No. Q. So what changed your mind? 24 (Pages 349 to 352) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (601-333-772-1652) Electronically signed by Pamela Sullivan (501-333.772-1652) (561) 832-7506 92ef5b62-31335-4202-a350-6633a5c6813b EFTA00750797 Page 353 1 A. It's it wasn't that my mind was changed. 2 I just, l just didn't go the first time. I don't 'mow 3 why. I was probably doing something; that's probably 4 why. The only reason I ever went back was because he 5 made me feel like I was obligated to keep going. 6 Q. Why? What obligation did you have to go to 7 Mr. Epstein's? 8 A. I didn't. He was like just very demanding, 9 and he just — he just told me what to do, and ljust 10 felt like I needed to do it 11 Q. Well, you were able to get away from your 12 stalking boyfriend; right? That wasn't a problem for 13 you? 14 MR. EDWARDS: Form. 15 THE WITNESS: He, he still calls me today, 16 so, yeah, it is a problem for me. 17 BY MR. CRITION: 18 Q. That were — well, you were able to run 19 away from house and your mother's house at 20 various times and to live with somebody else, before you 21 ever met Mr. Epstein; true? 22 A. I ran away from my mother's house, yes. 23 Q. Okay. And you -- you were strong enough to 24 do that, and you knew, at least in your own mind, what 25 you wanted to do. You had a mind of your own at that Page 355 1 you? 2 A. It was not an option that I thought that ! 3 had. 4 Q. Wiry? 5 A. Because I was too young to understood. 6 Q. Well, you were young enough to run away from 7 your mother's house, you understood that, and to go to 8 what considered to be a safe place at -- was it 9 house? 10 A. Yes. 11 Q. All right You understood that; right? 12 A. Yes. 13 Q. Okay. You were -- you understood enough that 14 you gave varying testimony during the trial and various 15 depositions of your father to either help him or hurt 16 him, depending on who was influencing you; right? 17 MR. EDWARDS: Form. 18 THE WITNESS: And during that time I had no 19 idea what 1 was doing. 20 BY MR. CRITTON: 21 Q. All right And you knew when or 22 whoever called, called you and said, you know, would you 23 like to come back, you could say yes or no. it was that 24 simple. MR. EDWARDS: Form. Page 354 1 point; true? 2 MR. EDWARDS: Form. 3 THE WITNESS: I didn't have a choice but to 4 leave at the time. 5 BY MR. CRITTON: 6 Q. All right. Well, you had a choice either to 7 go beck to Mr. Epstein's or not to go back to 8 Mr. Epstein's. You had to first say, yes, to the person 9 who called; correct? You had a choice: I'll say yes, 10 or ni say no. Pro living out west of town. 11 Mr. Epstein lives in, you know, Palm Beach. He's got no 12 hold over me; right? He had no hold over you. 13 MR. EDWARDS: Pam. 14 THE WITNESS: Yes, but I just knew that they 15 would continue to call me. 16 BY MR CRITTON: 17 Q. So call the police. Why didn't you call the 18 police? You knew how to get ahold of the police; right? 19 A. That wasn't the — 20 Q. You'd had issues with the police before? 21 MR. EDWARDS: Form. 22 THE WITNESS: That was not the first thing I 23 thought of. 24 BY MR. CRITTON: 25 Q. But it was an option that was available to 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 356 THE WITNESS: It was more like, could you please come back. BY MR. CRITTON: Q. Okay. So, so they said, please. You could say, thanks, but no thanks. You had said, thanks, but no thanks, before; right? A. I didn't know. I didn't !mow — Q. &we you — A. — that that was an option. Q. Sure you did, because — A. Oh, you did? Q. Yeah. Because when you were in school at both — in eighth grade, that you repeated, and then when you were at Paco, you made decisions not to go to school and to remain truant from school; didn't you? A. That's because 1 could not go to school. Q. Why not? A. It was not an option forme. Q. Why? A. Because I was being abused at my mother's house. Q BY? A. And if I went back — if I went to school, then that would mean going back to my mom's. Q. Okay. Who was abusing you at your mother's (562) 832-7500 25 (Pages 353 to 356) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333.772.1652) Electronically signed by Pamela Sullivan (501-333-772.1552) InefSb62-38a5-4202-a350-6633a5c6813b EFTA00750798 Page 357 1 house? 2 A. My mother. 3 Q. Okay. And how was she abusing you? 4 A. She wasn't feedin me. 5 Q. Did you tell that? 6 A. Yes. 7 O. And that's why you went to live with II 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. Okay. And she wasn't feeding you. Did — were — had you ever been abused by your father or by Mr. Veet? A. No. Q. Okay. Did any family member, other than your mother, ever physically abuse you? A. Yes. Q. Who? A. My uncle. Q Which uncle? A. A. Yes. Q. How did he abuse you? How old were you, and how did he abuse you? A. I don't know. I was probably Ile 15, and he 1 2 3 4 5 9 11 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 359 A. No. Q. Did you tell your M? A. Yes. Q. And what did she say? A. I don't remember. . Did she call the nce? Q. Police come? A. Yes. Q. What did they do? A. They didn't do anything. Q. Did you have any physical marks? A. Yes. Q. Okay. What did you have? Where did he hit you? Did he hit you in the nose? What part of your face did he hit? A. I had a bump on my head somewhere. I'm not — I don't remember where it was. Q. But he hit you with his fist? A. Yes. Q. Did you leave the house after that? A. No, he did, because I called the police. Q. Did he ever come back? A. Yes. Q. . Did you consider that a pretty traumatic Page 358 1 hit me. 2 Q. Where did he hit you? 3 A. He punched me in the face. 4 Q. Was he drunk? Was he on drugs, Jane Doe? 5 A. I don't know. 6 Q. Where were you at the time? 7 A. I was in my bedroom. 8 Q. Okay. And did he come into your bedroom? 9 A. I was walking out. 10 Q. ' And he just cold-cocked you? 13. • A. We were limning. • 12 Q. What were you arguing about? 13 A. I don't remember. 14 Q. And he punched you right in the face? 15 A. Yes. 16 Q. Did he break anything? 17 A. No. 18 Q. Did you have to go to the hospital? 19 A. No: 20 Q. You were living where, at your 21 house then? 22. A. Yes. 23 Q. Did you get blocked down? 24 A. No. 25 • Q. Were you knocked out? Q. Where does the come from? (561) 832-7500 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 360 event, to have an uncle haul off and hit you in the face? MR. EDWARDS: Form. THE WITNESS: No. BY MR. CIIITTON: Q. Didn't consider that to be traumatic at all? MR. EDWARDS: Form. THE WITNESS: Not really. BY MR. CRITFON: Q. Okay. Had anybody else ever hit you in the face like that? A. Mykisters. Q. and A. And my brother, yes. Q. Which brother? A. I only have one brother. Q. What's his name? A. Q. It's Is in jail? A. Not tight now. Q. He's been in jail, though, before? A. Yes. Q. [sit MP Q. 26 (Pages 357 to 360) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1552) Electronically signed by Pamela Sullivan (601.333-772-1552) 92ef5b62-38a5-4202-a350-6633a5c6813b EFTA00750799 Page 1 A. My mother. 2 Q. Are there any -- is he a -- is he a El 3 child? 4 A. Yes. 5 Q. Whets he been in jail for? 6 A. Robbery. 7 Q. On how many occasions? A. I don't know. 9 Q. Are you close to your brother? 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Somewhat. Q. When is the last time he was in jail? A. I don't know. Q. Do you consider it traumatic that your brother was in jail? MR. EDWARDS: Form. THE WIDIESS: He put himself in jail. BY MR. CRITTON: Q. So he -- he basically made his bed, and then he slept in it? A. Yes. Q. Is that the way you feel about your dad, too? A. Yes. Q. It was his choice to, to assault a young boy, and as such, he's paying the penaRy? A. Yes, that's the way I feel now about it. Page 363 1 A. Yeah. Not bad enough to go to the hospital 2 or anything. 3 Q. Police ever called? 4 A. No. 5 Q. Did anyone ever attempt to rape you? 6 A. No. 7 Q. Has anyone ever attempted to molest you? 8 A. No. 9 Q. Okay. You go back to Mr. Epstein's house the 10 second time. You had their phone number; right? 11 A. No. 12 Q. Well, you had it, because it showed up on 13 your phone? 14 A. I had seen it. 15 Q. Right. But all you have to do is go back to 16 recent calls; right? Every — every five-year-old, 17 six-year-old, seven-year-old kid in the world can show 18 me how to use a cell phone that I don't know how to use. 19 I assume you fall within that, too. You know how to use 20 a cell phone and how to get voice mail, how to make 21 calls, how to pull recent calls out of your phone? 22 MR. EDWARDS: Form. 23 BY MR. CIFUTION: 24 Q. And you knew that — 25 A. Okay. 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 362 Q. In your earlier years were you torn, because he was your father? A. twos very confused, yes. Q. And I've seen on various medical records that you consider yourself to be suffering from, even today, post traumatic stress syndrome that related to that — MR. EDWARDS: Form. BY MR. CRTITON: Q. -- related to that, that is your father murdering M . A. Yes. Q. Any other family member ever physically assault you? A. No. Q. Other -- other than your uncle and you said the fights that you got in with your sisters and your brothers. I assume those were more sisteribmther type fight, or were they real fight-fights? A. Both. Q. So you got into some real fights — real physical fights with your sisters and your brother? A. Yes. Q. Where people were hurt? A. Not — Q. • Black eyes? Blood? 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 364 Q. — back in '03, '04, '05, '06, '07; didn't you? MR. EDWARDS: Form. 11.1E WITNESS: Yeah. BY MR. CRITTON: Q. Okay. Did you ever — before -- you say a taxi was sent to pick you up? A. Yes. Q. Okay. Before that taxi got there, did you say to yourself, you know what, what am I doing, I don't need to go back there. Did you ever think of that? A. No. Q. Would it be a correct statement, ma'am, that there's nothing about the rust event, that is the first time you were at Mr. Epstein's home, that you found to be in any way traumatic? A. At the time I didn't think about it, but now I do, yes. Q. Okay. So when did you — when did you decide that going to Mr. Epstein's house was a traumatic event in your life? Who helped you come to that conclusion? Was that only after you filed a lawsuit in this case? MR. EDWARDS: Form. THE WITNESS: No. Soon after 1 stopped going, it started to bother me a lot. 27 (Pages 361 to 364) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 . Electronically signed by Pamela Sullivan (501.333-772-1552) Electronically signed by Pamela Sullivan (601.333.772-1652) 92015b62.38a5.4202-a350.6833a5e8813b EFTA00750800 Page 365 1 BY MR. CRITTON: 2 Q. AU right. So you went 20 times to 3 Mr. Epstein's house, by your own testimony, and not the 4 rust, not the second, not the third, not the fourth, 5 not the tenth, not the 15th, not the 17th, not the 20th 6 time did you suffer any trauma; true? 7 MR. EDWARDS: Form. 8 THE WITNESS: Yes, I did. 9 BY MR. CRITTON: 10 Q. And at what time did you, in your own mind, 11 suffer, quote/unquote, trauma or some sort of 12 psychological problem as a result of being at 13 Mr. Epstein's? 14 A. Probably when I went to my program in M E I 15 Q. That was in 2007? 16 A. That was in -- when I was 17. 17 Q. Okay. Which was —you went to =right 18 after the last time you saw Mr. Epstein? 19 A. Yes. 20 Q. So of the approximately 20 times that you 21 went to Mr. Epstein's, at no time did you believe that 22 you had suffered any physical injury; correct? 23 A. What do you mean? 24 Q. I'm just asking the question: During the 25 time — approximately 20 times you went to Page 367 1 A. 1 was only 17 when I went to 2 Q. Okay. At the time that you thought that it 3 was wrong to go to Mr. Epstein's, why didn't you just 4 say, TM not going anymore? 5 A. I — I didn't feel like I had that choice. 6 Q. What — what choice? Each time you went to 7 Mr. Epstein's, you had to make a choice, am I going or 8 am I not going - 9 Iva. EDWARDS: Form. 10 BY MR. CRITTON: 11 Q. —true? 12 A. Not really. 13 Q. Why not? 14 A. Because - 15 Q. How could you not have a choice? Because you 16 lived west of town. He lived east of town. You lived 17 miles apart. You had to take some affirmative action in 18 order to get to Mr. Epstein's home; didn't you? 19 A. No. 20 Q. Why not? 21 A. I had to get in a cab and... 22 Q. That's an affirmative act. You had to either 23 say, I'm going, or I'm not going. 24 MR. EDWARDS: Objection to form. 25 THE WITNESS: I don't know what you mean. Page 366 1 Mr. Epstein's, you didn't believe that you had suffered 2 any kind of physical injury; did you? 3 A. No. 4 Q. No pain and suffering? 5 A. I —1 felt like it was very wrong. I 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Which time? The first time? A. Every time. Q. Okay. Then after the first time you went and 9 you felt that going to his house was wrong — and you 10 knew the difference between right and wrong; didn't you? 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Not really. et You knew committing — well, as of the time that M . took you to Mr. Epstein's the very first time, you knew the difference between right and wrong; didn't you? MR. EDWARDS: Form. THE WITNESS: Not really. BY MR. CRITTON: Q. Okay. Well, how about when ou were - when you were working at or did you know the difference between right and wrong? A. Yes. Okay. Did you were you working at before you went to or after? 1 2 3 4 5 6 7 Page 368 BY MR. CRITTON: Q. Sure you do. You 'mow that — what an affirmative act is, taking some oven act to do a particular task; right? You understand that? MR. EDWARDS: Form. THE WITNESS: I don't know what you mean. BY MR. CRITTON: Q. Well, you — if -- if you have to make a decision, and your decision tree is I can say either do something or not do something, doing something is taking some affirmative act; right? Not doing something is — is a negative act, or not doing an affirmative act. Do you understand that concept? A. I guess. Q. All right. And in order to go to Mr. Epstein's house, you had to actually say you had to make a mental decision, that is you had to make a decision in your own mind, I'm going there. And it's okay. Right? A. Yeah, I guess so. • Q. All right. You —you say that you've lost income and you want -- in your Rule 26 disclosures, which is something that your lawyer provided or filed with the court, you said that you've lost in excess of -- you have a past and fitture lost wages and past and (561) 832-7500 PROSE COURT REPORTIN 28 (Pages 365 to 368) G AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-7M4552) Electronically signed by Pamela Sullivan (501-333-772-1552) 9205b62-38a5-4202-a350-6633a5c6813b EFTA00750801 Page 369 1 future loss of earning capacities — capacity in excess 2 of a million bucks. 3 Okay. What did Mr. Epstein -- that is, what 4 occurred at Mr. Epstein's that has caused you — that 5 caused you to lose any money as of today's date? 6 MR. EDWARDS: Form. 7 717E WITNESS: Pretty much everything. 8 BY MR. CliTTTON: 9 Q. What — what — what has Mister what was 10 your — has your experience Mr. Epstein -- excuse me -- 11 done that has caused you to lose money, as of today's 12 date? 13 A. Pretty much everything that happened at 14 Jeffrey Epstein's house makes me extremely depressed to 15 a point where I don't -- I'm extremely sluggish, and 1 16 don't even feel like tin out of bed sometimes. 17 Q. Other than e — well, let me 18 strike that. 19 If you still did not feel sluggish and you 20 didn't want to get out of bed, would you start stripping 23. again, working at the strip clubs? 22 A. No. 23 Q. Why? 24 A. Because I don't want to do that anymore. 25 Q. Why? Because you have a child? 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 371 A. No. Q. Have you erased anything from your Face Book over the last six months? A. No. Q. Okay. Are there any photographs or information on your face — well, let me strike that. How long have you had Face Book? A. A few months. Q. Starting when? A. I don't know. A few months ago. Q. 2009, you started? A. Yes, this year. Q. Have you put any type of photographs on your Face Book that would in any way — you would find embarrassing to you — A. No. Q. — if someone saw it? Let me get back to the loss of earnings. Other than the jobs that you had — let milt worked as a stripper at Sand you had — you earned money , correct? A. Yes. Q. Okay. How much money did you earn for the year 2006? 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 370 A. That's part of the reason, yes. Q. Okay. Ma'am, have you ever had a My Space page or a Face Book page? A. I have a Face Book. Q. Right now? A. Yes, I do. Q. And what — what's it under; what's the designation under? A. Jane Dee. Q. And how would someone hook up with you by Face Book? What would they put in? A. My name. Q. Jane Doe? A. Yes. Q. And how long have you had a — have you ever had a My Space page? A. Yes. Q. And did you close that down? A. I've really never figured out how to make it. Q. Do you Face Book; do and fl Face Book you? A. No. Have you ever corresponded with either M. . 25 or . through Face Book? 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 A. I don't know. Q. Did you ever keep track of it? A. No. Q. How about 2007? A. I don't know. Q. Okay. Did you ever talk with anyone about the need to file Federal income tax — A. No. Q. — on the money? A. No. Q. And I think you told me earlier you've never filed income taxes? A. Right. Q. Okay. Approximately, do you have any idea how much money you made in 2006 or 2007? A. No. Q. But you were able to dance in 2006 and 2007, so what loss of income did Mr. Epstein — your experience with Mr. Epstein cause you? MR. EDWARDS: Form. Calls for a legal conclusion. THE WITNESS: I guess afterward, when I— I guess I just haven't, you know, felt like good enough to get another job. (561) 832-7500 let 29 (Pages 369 to 372) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772.1562) Electronically signed by Pamela Sullivan (501433-772-1652) 92ef5b62-38a5-4202-a350-6633a5c6613b EFTA00750802 Page 373 1 BY MR. CRITTON: 2 Q. Well, your PTSD plays a role in that, as 3 well; doesn't it? 4 MR. EDWARDS: Form. 5 THE WITNESS: Not really anymore. 6 BY MR. CRITTON: 7 Q. If anybody has asked you since the time that 8 you last saw Mr. Epstein, not only S but 9 if anybody asks about your mental state or your 10 emotional state, do you tell them everything? 11 MR. EDWARDS: Form. 12 THE WITNESS: No. 13 BY MR. CRITTON: 14 Q. Why not? 15 A. Because I don't find it easy to talk about 16 that. 17 Q. Do you think ifs easy to talk about having 18 seen your father murder the son of his girlfriend? 19 A. Not at all. 20 Q. Is that easier for you to talk about — 21 MR. EDWARDS: Form. 22 THE WITNESS: Not at all. 23 BY MR. CRITTON: 24 Q. — than your experience with Mr. Epstein? 25 A. Not at all. Page 375 1 both of those are difficult for you to talk about? 2 A. Yes. 3 Q. Okay. And each -- each one is equally 4 difficult in your own mind; isn't it? 5 A. Yes. 6 Q. And so if you mentioned one, you'd probably 7 mention both, or you wouldn't mention either one; 8 correct? 9 MR. EDWARDS: Form. 10 THE WITNESS: Yes. 11 BY MR. CRITTON: 12 Q. The second tint you went back to 13 MT. Epstein's home, aisthire different happen than the 14 first time, other than M. wasn't there? 15 A. Not really. 16 Q. When is the next time you went back, then? 17 A. I don't know. 18 Q. How many banes did you go back in the year 19 2003? 20 A. I don't know. 21 Q. How many times did you go back in the year 22 2004? 23 A. I don't know. 24 Q. 25 2005? How many times did you go back in the year Page 374 1 Q. But you mention that, if somebody asks; don't 2 you? 3 MR. EDWARDS: Form. 4 BY MR. DUTTON: 5 Q. Or do you not mention that, either? 6 A. If somebody asked what? 7 Q. If somebody says, well, what — what -- how 8 do you feel? Lace when you've seen physicians, been in 9 the hospitals, and they say, you know, what's your -- 10 how do you feel, you know, are you — are you depressed. 11 are you happy? And what do you tell them? 12 A. I don't !mow. 13 Q. You don't know what you told them? 14 A. No. 15 Q. But whatever you would have said in response 16 to if a nurse or a physician asked you, or a hospital 17 asked you, what how you — how do you feel from a -- 18 from a psychological or an emotional standpoint, you'd 19 tell them the truth; wouldn't you? 20 A. 1 don't know. 21 Q. Okay. So you might lie to your doctor or to 22 the hospital? 23 A. Ifs not easy for me to talk about that. 24 Q. About what? Either — either event? Either 25 what your father did and you witnessed, or Mr. Epstein, Page 376 1 A. I don't !mow. 2 Q. How about in the year 2006? 3 A. I don't know. 4 Q. In fact, did you go at all in 2006? 5 A. I'm not sure. 6 Q. When is the last time you believe you went to 7 Mr. Epstein's home? 8 A. I was 17 years old. 9 Q. Did you ever put any of the money that you 10 received from Mr. Epstein in a bank account? 11 A. No. 12 Q. At any time during the time you went to 13 Mr. Epstein's house did the -- what you've described as 14 occurred on the first occasion, did that ever change? 15 A. I don't know. I guess after I went more and 16 more times, he got like more comfortable, and I guess 17 lila more like aggressive kind of. 18 Q. How many times had you gone before there was 19 a change? 20 A. I don't know. Probably like six or so. 21• Q. What year are we in now? 22 A. I don't know. Probably -- probably 2004. 23 Q. You'rejust guessing? 24 A. Yes. 25 Q. When you say something changed, did he ••••••14....w4•L•evwSV•a . , ..`, 35• Wtwaa (561) 832-7500 PROSE COURT REPORTING AGENCY, 30 (Pages 373 to 376) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 92ef5b62-38a5-4202-3350-6633a5c6813b EFTA00750803 Page 377 1 ever — did he ever touch you? 2 A. Yes. 3 Q. Okay. On how many occasions? 4 A. He always did, but he just got more 5 aggressive about it. And, eventually, he wanted to use 6 like sex toys on me. 7 Q. Did he — did he ever physically touch you on 8 any occasion? 9 MR. EDWARDS: Object to the form. Asked and 10 answered. 11 THE WITNESS: What do you mean? 12 BY MR. CRITTON: 13 Q. Did he ever touch you? You — you were 14 touching him, because you were giving him a massage; 15 right? 16 A. Yes. 17 Q. And that's something that you were doing 18 voluntarily? 19 MR. EDWARDS: Form. 20 THE WRNESS: That was something that he told 21 me to do, yes. 22 BY MR. CARTON: 23 Q. But you had to get to the house. There's no 24 way you could give him a massage, unless you made the 25 decision to go to his house; correct? 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 379 touch you on any of the visits? A. He always — Q. Is that what you said, about the sixth time? A. He always touched me. Q. Where? A. He touched my breasts. He touched my vagina. He always touched me. Q. Did you ever tell him — well, let me strike that. He couldn't touch you, unless you allowed him to touch you; correct? MR. EDWARDS: Form. BY MR. CRITTON: Q. You had to vohmtarily allow him to touch you? MR. EDWARDS: Form. THE WITNESS: I don't know what you mean. BY MR. CRITTON: Q. Well, the very first time you were there, I think you said he didn't touch you; correct? A. No, I did not say that. Q. Okay. Did he touch you the very first time you were there? A. Yes. Q. Okay. Where? Page 378 1 MR. EDWARDS: Form. 2 THE WITNESS: Yes. 3 BY MR. CRITTON: 4 Q. Okay. Because he couldn't force you to do 5 anything, unless you were at the home. And even if you 6 were at the home, all you had to do was to say, no; 7 correct? 8 MR. EDWARDS: Form. 9 THE WITNESS: I didn't feel that way, no. 10 BY MR. CRITTON: 11 Q. Well, if you did -- if you didn't feel that 12 way, that is that you didn't have a choice, your choice 13 was then nn not going to Jeffrey Epstein's home ever I4 again; true? 15 A. No. 16 Q. Okay. Did you take money every time you went 17 to Mr. Epstein's home? 18 A. Yes. 19 Q. Did you ever say, Mr. Epstein, I don't want 20 your money, I don't want to come back again? 21 A. No. 22 Q. You could have, though; couldn't you? 23 A. I didn't know that I could have. 24 g You said he touched you. How did he touch 25 you — well, let me ask you this: When did he first 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 380 A. My vagina. Q. And when he touched you there, did he — did he — was there any type of penetration, or did he just touch you? MR. EDWARDS: Form. ME WITNESS: I don't remember. BY MR. CRITTON: Q. Okay. When he touched your vagina -- with his hand? A. Yes. Q. What did you say to him? A. I didn't Say anything. Q. Okay. Had anyone ever touched your vagina before? Had a male ever touched your vagina before? A. No. Q. And when he touched your vagina, did you say — and your -- when you say your vagina, on the exterior of your body; right? A. Yes. Q. Did you say, please don't do drat? A. I didn't say anything. Q. You could have. You just didn't; true? MR. EDWARDS: Form THE WITNESS: I didn't know what to say. (561) 832-7500 31 (Pages 377 to 380) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601,333-772-1552) Electronically signed by Pamela Sullivan (601 -333-772-1552) 92et5b62-38354202.3350-6633a5c6813b EFTA00750804 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24. 25 Page 381 I BY MR. CANTON: 2 • Q. Well, if you -- if you had said, don't touch 3 me — did you ever tell him, don't touch me, or don't do that? 5 A. I didn't think of that, no. e Q. Okay. So the 20-some-odd times you were 7 there, you never said or never thought about telling him 8 not to do something; correct? 9 A. That's coned. 10 Q. Okay. So at least from his perspective -- 11 well, let me strike that. 12 Did you ever tell him that you didn't like 13 him touching you? 14 A. I don't remember. 15 Q. You don't remember telling him that; do you? 16 A. I don't remember. 17 Q. Okay. Well, you would remember if you said, 18 don't touch me there, or if you had pushed his band 19 away; wouldn't you? 20 MR. EDWARDS: Form. 21 THE WITNESS: I do remember that I was like 22 miserable, and I know that I looked miserable. And 23 so he would pretty much tell me that, ifs okay. 24 BY MR. CRITTON: 25 Q. You'd say you looked miserable, what do 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 383 BY MR. CRITTON: Q. You may not have thought you bad a choice, but it was your choice; true? MR. EDWARDS: Form. THE WITNESS: I don't know. BY MR. CRITTON: Q. You knew — MR. CRITTON: Well, why don't we take a break. We only have a couple of minutes left (A brief recess was taken.) BY MR. CRITTON: ane Doe, do you know a pan named A. Do you know him by any other name? Q. I don't kno I'm just asking whether you know A. I'm not sure. Q. Did you know HIM A. Q. A. I have met him once. Q. Okay. And how do you know do — how do you know him? A. A friend of a friend had his baby. Q. I'm sorry? A friend of a — Page 392 1 mean? 2 A. Like I obviously didn't look like I was 3 enjoying what was happening. Q. Okay. And were you enjoying what was 5 happening? 6 A. Absolutely not. 7 Q. Okay. Then why did you go bacht Why didn't 8 you say, don't do that, Mr. Epstein — or what did you call him, Jeffrey, or did you call him Mr. Epstein? A. I didn't call him anything. Q. You never called him by his first name or his last name? A. No. Q. Is it your testimony that you never told him — well, let me strike that. It is your testimony you never told him not to do anything correct? MR, EDWARDS: Form. THE WITNESS: Correct. BY MR. CRITT0N: Q. And everything that you did there was voluntarily — voluntary; it was your choice? MR. EDWARDS: Form. 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. A friend of a friend had his baby. Okay. Ant friend of a friend? A. r ewhat? (phonetit Do you know Na Do you know IMIN Q. A. Q. A. Q. A. I — Page 384 (phonetic)? A. I have meta guy named but I don't know his last Q 'nrougs mill? A. Yes. U . Okay. Do you know whether — that's 's boyfriend, or someone she lived with at one time? A. I believe that he was her boyfriend. Q Okay. Do you know someone namecIIIMM. A. Yes. Q. Okay. How do him? A. I met him throuYghlir Q. Okay. Is that it's one of her boyfriends? A. Yes. Q. • Okay. How ab (phonetic)? A. I had never met but) head about him. (561) 832-7500 32 (Pages 381 to 384) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-313-7721 552) Electronically signed by Pamela Sullivan (601.333-772-1552) 92ef5b62-38a5-4202-2350-6633aScS813b EFTA00750805 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 385 Q. What did you hear? A. I heard that he was with M. in the past, and he abused her. Q. A. Q. A. Q. A. Q. Q. A. Okay. Physically abused her? I don't know. I — I don't know. Was he into drugs, M? I don't know. Okay. How about M? Yes. was into drugs? Yes. What kind of drugs? Was he a drug dealer? I don't know. Q. You don't blow, you just know he was into drugs? A. Yes. Q. Okay. Did M. tell you that? A. You can pretty much tell. Q. From seeing him? A. Yes. Q. How? A. He -- he looked like he was on drugs every time I ever saw him. Did you ever know someone named M. dated? that Page 387 1 Q. What was his last name? 2 A. I don't know. 3 Q. Another-. person? 4 A. Yes. 5 Q. Okay. These are all people that she had 6 relationships with? 7 A. im:ss so. 8 Q. MI (phonetic), is that the 9 you were talking about? 10 A. Yes. 11 Q. Okay. Did M. ever tell you that she had 12 been raped or molested? 13 A. No. 14 Q. Did.. ever tell you that she had been 15 raped or molested? 16 A. No. 17 Q. Ma'am, have you ever had an abortion? 18 A No. 19 Q. Have you ever been pregnant, other than the 20 one time with this — your current child? 21. A. No. 22 . Q. Ms. Jane Doe, didn't M. tell you before 23 you — she first took you to Mr. Epstein's house that — 24 didn't she say specifically, I told her that we were 25 going to go to just an old guy's house, he is really Page 386 1 A. what? 2 Q. I'm not sure. 3 A. Yes. 4 Q. Did you know an ai 5 A. Yes. 6 Q. What was his last name? 7 A. I — I'm not sure, but I — !know that my 8 uncle was friends with his uncle, whose last name was 9 10 Q. IL ? 11 A. 12 Q. 13 A. Yes. 14 4.O1. And soft could have been 15 16 A. Yes, possibly. 17 Q. All right. Was that — was that Uncle si 18 A. Yes. 19 Q. How about — and — and vvas a drug 20 guy, too?. 21 A. I don't know. 22.. Q. How about a person named ='? 23 A. 24 Q. 25 A. Yes, I met him. Page 388 1 rich, and he has a beautiful mansion, and we're going to 2 go upstairs and give him a massage. I told her, her 3 meaning lane Doe, that I would be there with her for 4 half the time, and I would leave the room. And when I 5 left the room, he is going to tum over and do himself, 6 by meaning ejaculating. 7 She told you that before you went to 8 Mr. Epstein's house the first time; didn't she? 9 A. No. 10 Q. Okay. Didn't she also tell you on the first 11 occasion that you would have to be topless? 12 MR. EDWARDS: Fans. 13 THE WITNESS: No. 14 BY MR. CRITIDN: 15 Q. Didn't she tell you that Jeffrey was a nice 16 guy and wouldn't make you do anything that didn't 17 want to do, or words to that effect? Didn't M. tell 18 you that before the first time? 19 A. That is not exactly what she said to me. 20 .Q. That's what you understood, though? 21 A. No. 22 Q. Okay. Well, did she tell you that, that 23 Jeffrey was — that the older man was a nice guy that 24 wouldn't make you do anything that you don't want to do? 25 A. No. (561. ) '832.-7500 33 (Pages 385 to 388) PROSE COURT REPORTING AGENCY, INC. ' (561) 832-7506 . Electronically signed by Pamela Sullivan (601-333-772.1552) Electronically signed by Pamela Sullivan (501.333.772-1552) 9205b82-3844-4202-a3804633•Se6813b EFTA00750806 Page 389 1 Q. Okay. Didn't she tell you that you were 2 going to see him ejaculate? 3 A No. 4 M. If.. had said those things, your position 5 is M. is lying right? 6 MR. EDWARDS: Form. 7 TIM WITNESS: She certainly could have been 8 mistaken. 9 BY MR. CRITTON: 10 Q. Well, assuming she testified under oath, 11 there's a difference between mistaken and being lie — 12 and lying isn't there, in your mind? 13 MR. EDWARDS: Form. 14 THE WITNESS: If she thought that she told me 15 that, then she was mistaken, bonus,. she did not 16 tell me that. 17 BY MR. CRITTON: 18 Q. Has anybody ever told you that you may have a 19 cause of action against for having brought you to 20 Mr. Epstein's house the first time? 21 MR, EDWARDS: Form 22 THE WITNESS: No. 23 BY MR. CANTON: 24 Q. Have you ever signed a — you're aware that 25 Mister — we established earlier that Mr. Edwards Page 391 1 and — you and your attorney answered them — or you 2 answered them on January 23rd of 2009 — at least that's 3 when they were sent to me. 4 Do you remember receiving these written 5 questions? 6 A. I remember discussing these questions over 7 the phone with Brad. 8 Q. Okay. And you don't have to tell me what was 9 discus'' but you and your attorney consulted one 10 another? 11 A. Yes. 12 Q. Okay. And you see, if you go to the very 13 last page, there's a verification. It says: "The 14 foregoing answers to interrogatories are true and 15 correct, to the best of my knowledge, information and 16 belief." And it has Jane Doe, Plaintiff. Is that your 17 Jane Doe? 18 A. Yes. 19 Q. All right. And all of the answers to these 20 interrogatories you represented to be true and accurate; 21 correct? 22 A. I did look over some of them with Brad, and 23 some of them were not right 24 Q. Okay. Well, that's not my question. When 25 you sent these out to me, or when Mr. Edwards — take it 1 3 4 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 390 represents M. Have you ever signed a waiver of conflict letter about that you would agree not to sue Int? A. Not that I know of. Q. Are you aware that you have a claim -- that you may well have a claim against M. for having taken you to Mr. Epstein's the first time? MR. EDWARDS: Form. THE WITNESS: No. BY MR. CRITTON: Q. Did you ever reach an agreement with that you wouldn't sue her? A. No. Q. Do you have a side agreement with oh, I won't sue you, me, A. No. MR. CRITTON: This is Number 6. Let me show you Exhibit 6, which are your answers to interrogatories. liere you go, Brad, there's a copy for you. (Defendant's Exhibit No. 6 was marked for identification.) BY MR. CRITTON: Q. These are interrogatories that were sent to you, ma'am, back in I believe in December. And you Page 392 1 back 2 When you signed these answers to the 3 interrogatories on January 23rd, 2009, and verified 4 they're true and correct, you represented to me and to 5 the Cowl that those answers wens true and correct. You 6 understood that, yes; correct? 7 MR. EDWARDS: Form. 8 THE WITNESS: Yes. 9 BY MR. CRITTON: 10 Q. All right. And as of todays date, which is 11 September 30,2009, you have made no corrections to 12 these interrogatories; have you? 13 MR. EDWARDS: Form. 14 THE WITNESS: I have told Brad that there 15 were some. 16 BY MR. CRITTON: 17 Q. Okay. You need to listen to my question, 18 ma'am. 19 . As of todays date, you have filed — at . 20 least, you're unaware of any filing that's been made on 21 your behalf to correct any of these answers to 22 interrogatories; true? 23 MR. EDWARDS: Fonn. And I'd like you to let 24 the witness answer the question, as she was. As 25 you know, no Plaintiffs file anything; the (561) 832-7500 PROSE COURT REPORTING AGENCY, 34 (Pages 389 to 392) INC:' (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-7724 552) Electronically signed by Pamela Sullivan (501-333-772-1552) 92efSb62-SilaS-4202-a3S0-6633a5c6813b EFTA00750807 Page 393 1 attorneys do it for them. And she was going to 2 answer your question. 3 MR. CRITTON: Well, if she tells me -- you're 4 going to let her — she's trying to say what Brad 5 told me, or something. So if you're going -- 6 willing to waive the attorney/client privilege, 7 I'll let her go ahead. I was just trying to help 8 you out here. Good Samaritan. 9 MR EDWARDS: Yeah. 10 She has made me aware of better answers, and 11 I will file. 12 BY MR.. CRITTON: 13 Q. At least as of today, you have done nothing? 14 You have — you have not signed any papers that would 15 change the exhibit — the answers in Exhibit 6; true? 16 MR. EDWARDS: Form. 17 THE WITNESS: Right. 18 BY MR. CRITTON: 19 Q. Have you ever worked as an escort? 20 A. No. 21 Q. Man of — our i that you did at 22 either or , did -- did any male 23 or female ever ask you to go out with them on a date? 24 A. Yes. 25 Q. Okay. Did you ever go with any of those Page 395 1 Q Well, how about average days per month, did 2 you work at least ten days a month? 3 A. Yes. 4 Q. Okay. And if you worked ten days a month, S and you were getting SI0 — I'm sorry — ten days a 6 month times 200 bucks, you would get about $2,000 a 7 month? So you had to have been earning at a minimum of 8 about 2,000— $2,000 a month times 16 months, you would 9 have made about S32,000 minimum, working for 10 and right? That's just math. 11 MR. EDWARDS: Form. 12 THE WITNESS: Possibly. 13 BY MR. CRITTON: 14 Q. You may have made more? 15 A. I probably actually made less. 16 Q. Okay. Well, you could have made more; could 17 have made a little less — 18 MR. EDWARDS: Form. 19 BY MR. CRITTON: 20 Q. —right? 21. A. No. 22 Q. No what? 23 A. 1 didn't make more than that. 24 Q. Okay. How do you know that, if you never -- 25 if you didn't keep track of your records? And I'm Just Page 394 individuals? 2 A. No. 3 Q. During the time that you worked — and I was 4 hying to — worked at — that you worked at Platinum, 5 and then MEM, you worked, I think we worked out 6 about, let's see — six — four —14 to 16 months that 7 you would have worked at - 8 something. Does that sound about right? 9 A. Yes. 10 Q. Okay. And you said that your — your general 11 take was approximately $200 a night? 12 A. Yes. 13 Q. Okay. And if you, over that 14- to 16-month 14 time period, would you say that you waited an average of 3.5 about five days a week? 16 A. No. 17 Q How many days a week? 18 A. Um. 19 Q. I know you said sometimes you work seven; 20 sometimes you might not work for — 21 A. Sometimes 1 didn't work fora month or two. 22 Q. Approximately, out of those 14 to 16 months, 23. approximately how many what would have been your 24 average number of days that you would have worked? 25 A. I have no idea. and MIM Page 396 1 trying to use your numbers. So it was about $200 a thy, 2 times ten days a month, times 16 months, would be about 3 32,000 bucks; right? 4 A. If I made $200 every time. 5 Q. Well, if — if you did — how many lap dances 6 would you generally do a night? 7 A. I don't know. 8 Q. Did you always get at least one lap dance a 9 night? 10 A. No. 11 Q. And some nights nobody was interested in 12 doing a lap dance with you? 13 A. That's right. 14 Q. Did you have some nights that maybe a few 15 people were interested in a lap dance? 16 A. Yes. 17 Q. Okay. When you were at — working et 18 and at a were you still taking 19 drugs? You were still working with illegal drugs; 20 weren't you? 21 MR. EDWARDS: Form. 22 THE WITNESS: At times. 23 BY MR. CRITTON: 24 Q. Okay. Did you ever take illegal drugs before 25 you went to Mr. Epstein's house? 35 (Pages 393 to 396) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (501.333-772.1562) Electronically signed by Pamela Sullivan (501-333-772-1552) (561) 832-7506 92ef5b62-38a54202-a350-6633a5c6813b EFTA00750808 2 3 4 A. 5 Q. 6 A. 7 Q. Her too. Let me start again. 8 With Melissa did you ever take her 9 to Mr. Epstein's house? 10 A. No. 11 Q. Okay. Why not? 12 A. I didn't want to. 13 Q. Did you ever tell her about what you were 14 doing at Epstein's house? 15 A. No. 16 Q. Okay. Did you ever tell anyone? 17 A. No. 18 — did sister or or ever say to you, what do you mean you're 19 20 cleaning this guy's house over in Palm Beach, what's 21 going on here, you're coming home with a couple of 22 hundred bucks each time? 23 A. No. 24 Q. Okay. Did you ever spend more than an hour 25 at Mr. Epstein's home? Page 397 A. No. Q. Separate and aS-- you -- you mentioned your friend - give me her last name. (phonetic). 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 399 A. Yes. Q. Was it a psychiatrist or a psychologist or a licensed mental health counselor? A. I don't know. Have you ever seen any of the records from A. No. Q. You're yawning. Were you up late last night? A. No. Q. Okay. You're certain you're not on any kind of medication today? A. Yes. Q. Any kind of prescription or nonprescription medication? A. Yes. Q. Okay. What you were at. !think you said — how often would you talk to a psychologist or a -- some sort of a mental health counselor type person? A. I don't know. Q. Once a day? Once a week? Once a month? A. About once a week. Q. Did you talk to them about did Epstein ever come up? A. No. Q. Okay. Did your — the murder trial that you Page 398 1 A. No. 2 Q. Okay. So you would get 200 bucks, or then 3 300 I think you said later on, for being at 4 Mr. Epstein's. Did you show them how much money you 5 got? 6 k No. 7 Q. Did you ever pay or your uncle for 8 taking you? 9 A. Yes. 10 Q. How much did you pay them? 11 A. I don't know, 25, maybe 450. 12 I think you said that you — you ended up at 13 School as a result of a -- of the prosecution 14 relating to grand theft auto; correct? 15 A. Yes. 16 Q. And during the time you wae at did 17 you see a psychologist? 18 A. Yes. 19 Q. Was that part of your therapy or part of the 20 sentence? 21 A. Yes. 22 Q. Okay. Did you talk with a therapist about 23 do you remember the name of the therapist? 24 A. No. 25 Q. Was it more than one therapist? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 16 19 20 21 22 23 24 25 Page 400 testified in come up? A. Yes. Q. Did your trouble with the law, that is the grand theft auto and other problems that you had, did you discuss that with the therapist? MR. EDWARDS: Form. THE WITNESS: I discussed common knowledge with them, yes. BY MR. CRITTON: Q. Common knowledge? A. Things that everybody pretty much knew. Q. What do you mean by that? I don't know what you mean by common knowledge. A. Stuff that you can just find out. Q. Got to help me here. Ideal know what you mean. A. Well, obviously, I was charged with a crime to be sent there, so they knew about that. Q. Which was the grand theft auto? MR. EDWARDS: Form. THE WITNESS: Yes. BY MR. CRITTON: Q. Okay. What other crimes had you committed by that point in time? We have an offense where you shoplifted in Palm Beach County; right? 36 (Pages 397 to 400) (561 ) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 9205b62-38a5-4202-a350-6633a5c6813b EFTA00750809 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 401 MR. EDWARDS: Form. THE WIINESS: Yes. BY MR. CR1TTON: Q. Okay. Any other crimes that you can remember off the top of your head as sitting here? A. Running away. Q. And did you discuss those all with the therapist? A. Yes. Q. Okay. And how would the therapist have known about your testimony and your involvement with regard to seeing your father murder A. Because my mother asked that I work on that. Q. And you say that nothing ever came up with regard to Mr. Epstein or any of the — what had occurred at Epstein's with the therapist? A. No. Q. Why not? Why didn't you bring it up if it was such an important event for you? A. Because I did not want my family to know. Q. But and then the only people in your family as far as you know, today that know, is your A. Yes. Q. Did you ever tell your sisters and Page 403 1 Q. Have you been evaluated by any psychiatrist or psychologist at the request of your attorney? A. No. air you ever seen a person by the name of A. Yes. Q. Okay. Well, who do you think she is? 8 A. A psychologist or a psychiatrist or 9 something, 10 Q• okay. And how did you get — when did 11 Ms. Sdo an evaluation on you? 12 A. She did not. 13 Q. Okay. When did you see her? 14 A. I don't 'mow. 15 Q. This year? 16 A. Yes. Not long ago, like — 17 Q. In the past — sony; go ahead. 18 A. — a month, maybe two. 19 Q. Okay. And hwaija it get set up that you 20 would meet with Ms. 21 MR. EDWARDS: Objection. Do not answer. 22 Attorney/client privilege. 23 BY MR. CRITION: 24 Q. Did you meet with her? 25 A. Yes. 2 3 4 5 6 7 Page 402 1 that you were making money from giving -- for 2 giving massages to Mr. Epstein? 3 A. No. 4 Q. Did you ever tell either 5 that you liked going to Mr. Epstein's house? 6 A. No. 7 Q. Did you -- did - o r ever meet 8 Mr. Epstein? 9 A. No. 10 Q. Did Ms. Brewer ever meet Mr. Epstein? 11 A. No. 12 Q. Have ou seen — other than — well, who I — at least , looking 13 you've seen 14 at her resume, she's a licensed mental health counselor 15 through Victim Services. Is that -- am I right? 16 MR. EDWARDS: Form. 17 THE WITNESS: Yes. 18 BY MR. CRITTON: 19 Q. Other than IMIM, have you seen any 20 other psychologist, psychiatrist or licensed mental 21 health counselor relating to any damages you claim in 22 this case that were caused by Mr. Epstein? 23 A. No. 24 Q. Why not? 25 A. Because I'm embarrassed. or Page 404 1 Q. Okay. Where did you meet with ha? 2 A. Somewhere downtown. I — I don't exactly 3 remember where it was. 4 Q. Downtown in West Palm Beach? 5 A. Yes. 6 Q. AM how long — bow much time did you spend 7 with her? A. Not very much. 9 Q. And why not? 10 MR. EDWARDS: Objection. It was a 11 consultation, and we're claiming a privilege. 12 She's not going to divulge the circumstsa or the 13 conversation between herself and Ms. INE — 14 Dr. Mig 15 MR. CRITTON: — are you 16 intending to use Ms. MI as an expert in this 17 case? 18 MR. EDWARDS: No. 19 BY MR. CRITTON: 20 Q. Okay. I asked you earlier whether your 21 attorney — whether your attorney had set up any 22 meetings for you to meet with a psychologist or a 23 psychiatrist or a licensed mental health counselor, and 24 you said, ritwapd it wasn't until I said, did you ever 25 meet Amy EN or someone like her, and you go, yeah, I (561) 832-7500 37 (Pages 401 to 404) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772-1652) Electronically signed by Pamela Sullivan (601-333.772-1552) 92ef6b62-38a5-4202-a350-6633a6c6813b EFTA00750810 Page 405 1 did. Why didn't you tell — 2 A. You asked me if -- 3 Q. — me what — 4 A. -- I had an evaluation, which I did not. 5 Q. Oh, okay. So you -- you met Ms. III but 6 she never did an evaluation? 7 A. Yes. 8 Q. Okay. Was it your choice — did you not want 9 her to evaluate you? 10 MR. EDWARDS: Objection. The witness is not 11 answering the question as to Dr. alor that 12 meeting. We're claiming a priir as to that 13 communication between Dr. nd the Plaintiff. 14 And, as well, this pertains to attorney/client 15 information. Any answers that she gives will 16 violate one or two of those privileges. She's not 17 going to answer any more questions on this topic. 18 BY MR. CRITTON: 19 Q. With regard to have you seen, other than 20 whatever — whatever time ou s t with Ms. el 21 Dr. and your visits with have you 22 seen any other psychiatrists, psychologists, licensed 23 mental health counselor, physician, medical health 24 provider, relating to any damages that you are claiming 25 in this case? 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 407 Ms. lare helpful? A. Sometimes. Q. Okay. And how often do you see her? A. I was seeing her once a week. I haven't seen her in a while now, though. Q. Why not? When is the last time — well, let me strike that. When did you last see her? A. About a month or so ago. Q. And why haven't you seen her again? A. I don't know. Q. Do you intend to go back to see her, or Just going to kind of wait and see? A. Yes, I do. . • I'm sorry? A. Yes, I do. Q. Has — has she called you or you called her in the month or so that you have not seen her? A. Yes. Q. Did she call you, or did you call her? A. She called me. Q. Did she say, why haven't you come in? A. She was reminding me of an appointment that we had. Q. All right. And you said what? 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 406 A. No. Q. Have you sustained — have you incurred any medical bills, psychiatric bills, psychological bills, any type of bills associated with damages that you are claiming in this case against Mr. Epstein as of today's date? A. No. Q. Has anybody told you that you will incur any medical bills or expenses in the future as a result of any claims that you have made against Mr. Epstein? MR. EDWARDS: Objection. Attorney/client PriYilege. BY MR. CRITTON: Q. Other than Mr. Edwards. not interested in what he told you. I'm interested, but I'm not entitled to know. A. I don't know. Like who? Q. I don't knew. Has —has anybody told you. has — has said — has Doctor or Miss — Ms told you is that — well, Si strike that. Let me ask it.this way: Has Ms. told.you that she thinks you're doing better, that you're improving? . A. I don't Icnow. Q. Do you feel like the sessions with 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 408 A. That I would come. Q. But you haven't been back yet; correct? A. The appointment has not come up yet. Q. When is the next appointment? A. I — ideal know the exact date. It's October something. Q. Other than Mr. A, B and C who you identified, have you had a sexual relationship or any sexual activity with any other person, male or female?. A. Yes. Q. Who else have you had sexual activity with? MR. EDWARDS: She's not going to identify People- BY MR. CRITION: Q. First let's — it's when -- when else did you have any type of sexual activity, either wait° or a female, other than Mr. A, B and C and A. [guess in between the time that I had a relationship one — with one person, to the time that I had a relationship with another person. Q. Okay. Well, your lawyers kept me to Mr. A, B and C, so who do we fit in here? Where do we fit this other person into? B and C, C and • post pre You need to help'me with the date; then I can ask an intelligent question. (561) 832-7500 38 (Pages 405 to 908) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333.772.1562) Electronically signed by Pamela Sullivan (501-333-772-1552) 92ef5b62.38a5-4202-a350-6633a5c6813b EFTA00750811 P A. Yes, before =. 1 Page 411 BY MR. CRITTON: 2 Q. So it would have been after the stalker, 2 Q. Did you ever spend the night with him? 3 Mr. C? 3 A. No. A. Yes. 4 Q. Did he spend the night with you? 5 Q. And before 5 A. No. 6 A. Yes. 6 Q. Did you just meet and have sex? 7 Q. Okay. You didn't mention him earlier. You 7 A. We met and spoke to each other fora period 8 told me earlier today that you had had no sexual 8 of time before we had sex. 9 activity or the next sexual activity that you had 9 Q. Where did you meet him? 10 after Mr. C was . That wasn't true; was it? 10 A. I met him in my neighborhood. 11 A. That was the next relationship that I had. 11 Q. And let me just ask you: What's his name? 12 Q. I wasn't asking about — talking about 12 MR. EDWARDS: She's not going to give it. 13 sexual activity. I don't care about -- k's not that I 13 MR. CRITTON: You're instructing -- your 14 don't care. 14 objection is? 15 When's the next sexual activity? Was it 15 MR. EDWARDS: My objection is based on the 16 after Mr. C? 16 privacy rights of this individual answering the 17 A. Yes. 17 questions, as well as third-party individuals. 18 Q. Okay. And who was that with? we call him 18 BY MR. CRITTON: 19 Mr. D? Was Raman cowman? 19 Q. Over what period of time, then, did you have 20 A. It was a man. 20 sexual relations with him? Four or five months? 21 Q. And Mr. D was short-term, long-term, 21 A. It was during the entire time that I worked 22 one-night stand, multiple? 22 at 23 A. I — I never had a relationship with him, but . 23 Q. Which was about eight months? 24 I was seeing him for some time. 24 A. Yes. 25 Q. How long a time period? 25 Q. All right. So over a period of about once a Page 410 Page 412 A. Probably the whole time I waked a 1 week you would meet and you would have sexual relations. 2 a 2 Are we talking about intercourse? 3 What did he do fora living? 3 A. Not every time. 4 A. I don't know. 4 Q. Okay. Well, that's why I asked. So, but 5 Q. Did you meet him at a? 5 many of the times you would have sexual activity. 6 A. No. Intercourse? 7 Q. Did you meet him through a/ 7 A. Some of the times, yes. 8 A. No. 8 Q. Did you also have oral? 9 Q. What did he do the guy — you said you 9. A. No. 10 don't know what he did for a living? 10 Q. Strictly sexual intercourse? 11 A. No. 11 A. Yes. 12 Q. So saw him the whole time you were 12. Q. Okay. Anyone else that you've had sexual - 13 working at which was eight months, and 13 any sexual activity with, other than Mr. A, B, C, D and 14 you never know what kind of work he did? 14 15 A. No. 15 A. No. 16 Q. You never knew what kind of work he did? 16 Q. Nobody else? 17 A. No. 17 MR. EDWARDS: Object to the form. 18 Q. Are you — are you serious? 18 BY MIL CRITTON: 19 A. I only saw him maybe once a week. 19 Q. Male a female, is that correct? 20 Q. Okay. So you saw him once a week for eight 20 A. Yes. 21 months. All right. And you're telling the members of 21 Q. Have you ever had sex with a female? 22 the — the ladies and gentlemen of the jury that you 22 A. No. 23' have no idea what this man did for a living? 23 Q. Did Mr. D ever provide you money at any time? 24 MR. EDWARDS: Object to the form. 24 A. No. 25 THE WITNESS: Yes. 25 Q. Did he ever provide you any kind of like kind (561) 832-7500 39 (Pages 409 to 412) PROSE COURT REPORTING AGENCY, INC.' (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772.1852) Electronically signed by Pamela Sullivan (501.333.772.1552) 9205b62-313a5-4202-a350-4.633a5c6813b EFTA00750812 Page 413 1 compensation? And by that, he's made -- you know, 2 probably bought you — probably ate out and had dinner 3 or something. But separate from that, did he buy you 4 clothes, did he buy you perfume, did he buy you anything 5 or give you anything? 6 MR EDWARDS: Form. 7 ITIE WITNESS: No. 8 BY MR. CRITTON: 9 Q. Are you currently involved in any type of 10 civil or criminal proceedings, other than this 11 proceeding with Mr. Epstein? 12 A. What does that mean? 13 Q. I'm sorry? 14 A. What does that mean? 15 Q. Are you under any type of house arrest at the 16 current time? 17 A. No. 18 Q. Okay. Are there any criminal proceedings 19 that are outstanding directed to you, anything from a 20 traffic ticket up? Have you been arrested for any other 21 circumstance that's pending at the current time? 22 A. Yes. 23 Q. What? 24 A. Traffic ticket. 25 Q. All right For what? What did you do? 1 Q. 2 car? Page 415 What else happened that they impounded the 3 A. My brother was driving the car, and — 4 Q. In the commission of a crime? 5 A. I do not know. 6 Q. Okay. Why did they — why would they impound 7 the car, if your brother was just driving the car? Does 8 he have a license? 9 A. No. 10 Q. He doesn't have a license, either? 11 A. No. He was being questioned by a police 12 officer, and he ran. 13 Q. He fled in the mu'? 14 A. No, he ran on foot. And the car was 15 impounded because he left it wherever it was, at the 16 store or something. 17 Q. Okay. So it wasn't impounded because you 18 were driving without a license, and it wasn't impounded 19 because you were driving the wrong way on a one -- on a 20 street; right? 21 A. Yes. 22 Q. It was because of". 23 A. Yes. 24 Q. Okay. Any other criminal or misdemeanor or 25 traffic type events in your life at the current time? 3 2 3 4 5 6 7 8 9 Lo 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 414 A. Driving without a license. Q. And whose car were you driving? A. Q. This is the — did she authorize you to take the vehicle, or is this another time that you stole the car from her? A. No. She gave me the car because she bought a new car, and I was supposed to get my license. Q. And do you still have the car? A. No. Q. What happened to the car? A. It was impounded. Q. All right. Did you get into an accident? A. No. Q. How did you get caught? A. I was driving the wrong way. Q. On a street? A. Uh-huh. Q. Yes? A. Yes. Q. Okay. Is — is it — I've gotten reasonably good advice that they don't impound a car for driving without a license. So why did they impound the car in this instance? 24 A. Not right now. A. They did not impound it on that instance. 25 Q. And who's providing support for you and your Page 416 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 A. No. Q. Okay. Have you ever been under house arrest? A. No. Q. Any other civil proceedings that are pending at the =rent time? A. No. Q. Any proceedings with the Department of Children and Family Services? Na Q. You and planning to get married? Any plans, or just living together? A. We have talked about it. Q. Okay. I'm sorry? A. We have talked about it. Q. Well, you've been going together since when, '07? A. Yes. Q. Okay. And it's now '09. and you have a child together, so have you just been talking about it for those two years? A. About the past year we have. Q. Does he provide any support at the current time for the child? 40 (Pages 413 to 416) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (601-333-772-1552) 92d6b82-380542024360-6633a50813b EFTA00750813 Page 417 1 family at the current time? 2 A. 'MIMI helps us. 3 Q. How much does she help you with a month? 4 A. Before now she didn't need to help us, but 5 since= (phonetic) has lost his job in the last 6 three weeks, she's helped us. 7 MR. CRITTON: I'm going to adjourn for today 8 because of the time. It's about a quarter to 6:00. 9 And I can tell you this, that — 'have not gone 10 into all of the different events at Mr. Epstein's 11 home, because she was there some 20 times. So 12 those are areas that I intend to go into. I think 13 I can probably complete the deposition in another 14 hour and a half to three hours, max. 15 And there are some other areas that I — you 16 know, if 1 could — and we've been going pretty 17 steadily, at a pretty good clip. So if I could 18 take some time, I — and can think about my 19 thoughts, I'll try to make it even faster than that 20 at the next session. 21 MR EDWARDS: Well, Tm not going to agree to 22 it. We're going to have to have some discussion 23 with the Court as to whether or not this deposition 24 is going to be completed on another date. I 25 provided her here at 9:30. I had her here for the Page 419 1 I'm on the record. 2 COURT REPORTER: Okay. 3 MR. CRITTON: Did you not get any of that? 4 COURT REPORTER: I have it just... 5 VIDEOGRAPHER: You'll be able to get it 6 later. 7 MR. EDWARDS: I -- I remember what he said. 8 Don't worry about it. 9 UNIDENTIFIED SPEAKER; He said, on the 10 record. He said, on the record, so 1 flamed -- 11 COURT REPORTER: Ill check the video. 12 MR. CRITTON: All right. 13 UNIDENTIFIED SPEAKER: Clear — clearly, the 14 Court Reporter's tired. 15 COURT REPORTER: Well -- well, I said 16 something to you about l was starting okay. 17 This is — 18 UNIDENTIFIED SPEAKER: All right. 19 COURT REPORTER: We're back on, and III — 20 UNIDENTIFIED SPEAKER: But you got it? 21 COURT REPORTER: And I got it. * CHECK ALL. 22 MR. CRITTON: All right. So we spent eight 23 hours with chap, who was there for eight months 24 and — with — with the various lawyers in that. 25 So this is a young lady who claims that she was at Page 418 seven hours, and I think that ru be able to 2 demonstrate to the Court that many of the questions 3 were redundant, asked and answered over and over 4 and over again. And we're here, ready to complete 5 the deposition. If you want to (hush it, we'll 6 finish it. If you think that you will prevail at 7 that hearing and you're going to come back another 8 time, that's up to you. 9 MR. CRITTON: All right. Well, let's take a 10 break for a few minutes, and m decide what I 11 want to do. 12 MR. EDWARDS: Okay. 13 VIDEDDRAPHER: Off the record at 5:48. 14 (Discussion held off the record.) 15 MR. CRITTON: I'll put on the record, when 16 I've finished my 15 minutes of the additional areas 17 that I would like to cover with her. And we can go 18 to the Court on those particular issues. 19 MR. EDWARDS: Alined. 20 MR. CRITTON: And, you know we spent seven 21 hours — almost eight hours with — fm saying 22 in a 23 deposition in Federal Court. And Mr. 24 worked for Mr. Epstein for a period of six to eight 25 months. This is a -- Page 420 1 Mr. Epstein's house 20 times — well, I'll get to 2 that later, so let me get to where I'm going, and 3 4 MR. EDWARDS: Sounds like a good idea. 5 MR. CRITTON: Thank you. 6 BY MR. CRT-ETON: 7 Q. Ms. Jane Doe, what did you do, if anything — 8 and I don't want to know what conversations you had with 9 your lawyer -- to prepare for this deposition today, if 10 anything? 11 MR. EDWARDS: Object to the form. 12 Attorney/client. 13 MR. CRITTON: No, I don't want to know what 14 your discussions were. I want to know what -- what 15 did you — 16 MR. EDWARDS: Maybe I missed your question. 17 BY MR. CRITTON: 18 Q. What did you do to prepare for this 19 deposition, if anything, other than converse with your 20 attorney? 21 A. I went to bed early. I don't know. 22 Q. Did you make any notes? 23 A. I read through the questions that I answered. 24 Q. The interrogatories? 25 A. Yes. (561) 832-7500 41 (Pages 417 to 420) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1562) Electronically signed by Pamela Sullivan (601-333-772-1552) tbsOMM4ho54202.05NNIXMOIM3b EFTA00750814 Page 421 1 Q. Excuse me. Did you review any notes that you 2 bad made about any of your experiences at Mr. Epstein's 3 home? A. No, I've never made any notes. 5 Q. Have you ever written out — well, let me 6 gram that 7 Did you review a copy of your complaint? 9 A. No. 9 Q. Okay. Have you ever seen your complaint? 10 A. Yes. 11 Q. And do you know what you're asking for in the 12 way of damages in your complaint? 13 A. Not exactly. 34 Q. Okay. Your complaint says you want 15 S50 million. What's the basis for that claim? 16 MR. EDWARDS: Object to the form. 17 THE WITNESS: Pretty much just to hurt 18 Jeffrey Epstein. 19 BY MR. CRITTON: 20 Q. Okay. Not to compensate yourself, but just 21 to hurt Jeffrey Epstein; is that correct? 22 A. Pretty much. 23 Q. When you said you realized some of your 24 answers to the interrogatories were incorrect, when did 25 you discover that? Page 423 1 BY MR. CRITTON: 2 Q. And did you say it after you read them? 3 A. Yes. 4 Q. And who did you say whatever you said to 5 about some of the answers being incorrect, who did you 6 say that to? 7 MR. EDWARDS: Objection. Attorney/client 8 privilege — 9 MR. CRITTON: Okay. 10 MR. EDWARDS: — as to who within my firm 11 she's talking about, now that you're already 12 discussing the substance about — of the 13 conversation. 14 BY MR. CRITTON: 15 Q. Well, you said that you realized some of the 16 answers were wrong, so you called somebody. And I don't 17 want to know what happened or what erartly you said, but 18 you spoke to someone at Mr. Edwards' rum; is that 19 correct? 20 A. Yes. 21 Q. And that was a number of months ago; true? 22 A. I'm not I'm not sure when it was. 23 Q. If you — you testified — 24 A. It was — it was at least a month ago. 25 Q. Let me show you what I'll mark as Exhibit Page 422 1 A. I'm not exactly sure. 2 Q. Wash yesterday? Was it today? Was it a 3 month ago? Was it six months ago? 4 A. 1 probably noticed whenever I first got the 5 copy of it 6 Q. Which was what, shortly after it was signed 7 on January 23rd of '09? 8 A. I'm not sure if I have a copy of it, but I 9 know that I looked over it, and we talked about it 10 having some wrong answers. 11 Q. And that was months ago? 12 A. Not exactly sure how long ago it was. 13 Q. Well, it wasn't yesterday; was it? 14 A. We did look at it yesterday and talk about 15 it, but... 16 Q. But you realized the — some of the answers 17 were incorrect when you got it sometime in January or 18 early February of this year, when you got a copy of it; 19 is that correct? 20 MR. EDWARDS: Object to the form. 21 BY MR. CRITTON: 22 Q. A copy of Exhibit 6? 23 MR. EDWARDS: Form. 24 THE WITNESS: I know that 1 — I did say 2 5 something about some of the answers. Page 424 1 Number 7, Composite Exhibit 7. 2 (Defendants Composite Exhibit No. 7 was 3 matted for identification.) 4 MR. CRITTON: Here's an extra copy, Brad. 5 BY MR. CRITTON: 6 Q Have you seen a copy of the letter which is 7 dated March 10, 2009, that I sent to Mr. Edwards before 8 today? 9 A. I don't know. 10 Q. I'm sorry? 11 A. I don't know. 12 Q. Well, the letter was sent in March of 2009. 13 Are you saying that you, now having read the letter, it 14 doesn't — you don't recall whether you saw that? 15 A. No. 16 Q. No, you don't recall one way or the other? 17 A. No, I do not recall. 18 Q. Okay. Turn — flip the page. There was a 19 document — the letter is and just so the record is 20 clear I'm enclosing a proposal for settlement in 21 order to resolve the action which has been filed by your 22 client. And then attached — and that's paraphrasing — 23 attached to the letter is a proposal of settlement, sent 24 by Mr. Epstein to you, in the amount of $45,000, plus 25 $5,000 for attorney's fees. 42 (Pages 421 to 424) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (601-333.772-1552) Electronically signed by Pamela Sullivan (501-333-772.1552) (561) 832-7506 92ef5b62-3835-4202-a350-6633a5c6813b EFTA00750815 Page 425 1 Were you aware sometime in March of '09 that 2 you were offered $45,000 to resolve the case? 3 A. Yes. 4 Q. Okay. And did you understand that — that 5 if, in fact, Mr. Epstein comes back and gets an award of 6 a sum something less than $45,000, say $30,000, or 7 you're not successful in getting a judgment in excess of 8 35 — 30,000, $32,000, that you'll be responsible — or 9 you may be responsible for all of Mr. Epstein's 10 attorneys fees and coats that were incurred after the 11 proposal for settlement? 12 MR. EDWARDS: Form. 13 BY MR. CRITTON: 14 Q. That is that Mr. Epstein can get a judgment 15 against you, maybe hundreds of thousands of dollars, are 16 you aware of that fact? 17 A. No. 18 Q. Okay. And do you know that that will be 19 against you for your entire life until you pay that off? 20 MR. EDWARDS: Form. 21 THE WrrNESS: No. 22 MR. HILL: How is that reasonably calculated 23 to lead to admissible evidence? 24 BY MR. CRITTON: 25 Q. Ms. Jane Doe, we've talked about the first Page 427 1 the Court's order said that we could, if 2 appropriate, go longer than seven hours. There are 3 a number of additional areas that I want to cover 4 with your client, including some background 5 information that was not disclosed in her answers 6 to interrogatories that I've not yet gotten to. 7 I'd like to go into the other visits that she 8 had with Mr. Epstein, that is who she saw, what 9 occurred, both by her and with Mr. Epstein, and 10 anyone else who may have been present at the time. 11 1 want to review the various counts of the 12 complaint with her, separate and apart from the 13 allegations of the various visits. 14 There's some other background — family 15 background information I want to cover with her, 16 and I want to cover with her any other areas of 17 which she may have knowledge regarding witnesses. 18 including with regard to either issues, 19 issue, or potentially other indiviarrla s who are 20 Plaintiffs in this case. 21 There are some other additional, as I said, 22 family background that I wish to explore, as well 23 as the medical records, which I have not yet had an 24 opportunity to dist, KS with her, which we obtained, 25 and her school records. Page 426 1 time you went to Mr. Epstein's house and, I believe, the 2 second time you went to Mr. Epstein's house; correct? 3 MR. EDWARDS: Form- 4 THE WITNESS: Yes. 5 BY MR. CRITFON: 6 Q. Okay. And you've testified that you went to 7 Mr. Epstein's house another approximately 18 times; is 8 that correct? 9 A. Yes. 10 Q. All right. And we have not discussed any of 11 those events, at least as of this point today; have we? 12 MR. EDWARDS: Form. 13 THE WITNESS: I {mow that I have told you 14 that every time I ever went to his house, he 15 touched me, and I gave him a massage. 16 BY MR. CRITTON: 17 Q. Okay. But we talked about that generally; we 18 haven't gone into each detail as to when the event 19 occurred or what occurred at each of those massages; 20 have we — other than what you generally have told me; 21 correct? 22 MR. EDWARDS: Form. 23 THE WITNESS: Cornea 24 MR. CRITTON: Pm going to adjourn the 25 deposition now. It is about five after 6:00, and (561) 832-7SOC Page 428 1 My best estimate for the time for completing 2 her deposition is approximately two and half to 3 three hours. If I can do it in a more reasonable 4 or a quicker fashion, twill certainly do that. 5 And as I advised you, Brad, I am going out of 6 town on Friday. I'm in the process of moving my 7 house. It's supposed to occur on Monday or Tuesday 8 of next week. We — it is now, as I said, 9 6 o'clock. We started about a little before 10 10 o'clock today. I think that the request is not 11 unreasonable, and I will also have opportunity to 12 have reviewed the transcript, so that I'm not — 13 that I don't ask duplicative questions or retread 14 some area that we've already covered that I think 15 has been PI opt, ly covered. 16 As I indicated earlier is we spent almost 17 eight hours with a person named who was 18 a house manager for Mr. Epstein or approximately 1.9 six months, who was, I'd say, a small-time player. 20 And this is a young lady who is seeking 21 extensive damages, whose — damages in excess of 22 $50 million for both compensatory and punitive 23 damages. And I think we have a right to fully 24 explore. It's certainly not the intent to harass, 25 intimidate or to cause her any undue stress. I'll 43 (Pages 425 to 428) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772.1562) Electronically signed by Pamela Sullivan (501333-772.1552) 92ef5b62-38a5.4202-a350-6633a5e6813b EFTA00750816 Page 429 1 be glad to work out a time that works for both you 2 and Ms. Jane Doe. 3 MR. EDWARDS: Just so that it is clear, we 4 we will not be in agreement to your proposal. I 5 wrote down the various areas you intend to go into. 6 Every single one of them was covered. I will be 7 able to point to those areas in the transcript when 8 we have a hearing on this matter. 9 As you pointed out earlier, Mr. Critton, the 10 seven-hour time limit was relieved by way of the 11 consolidation order, and it was done in the context 12 of depositions that are going to require multiple 13 attorneys — because there are so many attorneys 14 involved in this ultimate litigation — multiple 15 attorneys to ask questions of a particular witness 16 whose deposition to exceed seven hours, 17 such as Mr. la who was asked questions by 18 all seven or eight attorneys. This witness is 19 being asked questions by one attorney. That was 20 not the intent of the Court's order, and I think 21 that Judge Marra is going to have to rude on that 22 issue again. Every single one of the issues that 23 you intend to go into was covered. 24 And To like to also put on the lewtd that 25 in your last 15 minutes you proceeded to go into 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 431 CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH 1, the undersigned authority, certify that JANE DOE personally appeared before me and was duly sworn. Dated this 13th day of October, 2009. Pamela J. Sullivan, RPR, Notary Public - State of Flon My Commission Expires: June 10, 2010 My Commission No.: DD 560380 Page 430 1 proposals for settlement, which you know are not 2 admissible, nor reasonably calculated to lead to 3 admissible evidence, and you did that at your own 4 peril. And so, if we are going to resume any 5 deposition of Jane Doe, then it will be by way of 6 court order. 7 MR. CRITTON: We're done. end 6:09 p.m. 8 (Whereupon, the Deposition was suspended at 9 6:09 p.m.) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1. 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 10 19 20 21 22 23 24 25 Page 432 CERTIFICATE THESTATEOF FLORIDA COUNlY OF PALM BEACH I, Pamela J. Sullivan, Reclaimed Prolessienal Cant Reporter and Nola, Public in and for the State of Florida at lint, do hereby certify that I was authorized to and did report said deposition in stenotype, and that the foregoing pages are a true and correct transcription of my shorthand notes of said deposition I further certify that said deposition ins taken at the time and place hereinabove set forth and tint the taking of said deposition was commenced and completed as hereinabove set out IBM:her certify that I am not attorney or counsel limy of the parties, nor am I a relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action The foregoing certification of this transcript does net apply to any reproduction of the same by any means Sass tinder the direct control and/or direction of the mthlYinemparter Dated this 13th day of October, 2009. Parnelal. Sttaivmt, RPR. FFE.CLR 44 (Pages 429 to 432) (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 92.15b62-38a5-4202-a350-6633a5c6813b EFTA00750817 3 4 S 9 20 12 23 14 25 16 17 :0 29 1 Z2 :3 1 0da* 13.2009 2 SAM GCE CloSSAD1 EDWARDS. MUM RAMS. P4004144 Alit Las Olt Cry COOT. Sint. 1650 401 East La Nis Boulevar4 Rol Laudaido.R.13301 N R@ St1MT STYLE CASS NO. 0549.10)194.4ARRNICHNSON Nit 1b. as Dot Thom St Reeks Om n Wednesday. M SM of 10. 2000 ,A.0 give Otwiaktein ot-n-04.09441 mar. Al Out 60.9. nOlblireApatult le tent Welty OS fbi 'v., 'ow depomwo As peowaly npac.1 la, the tittrualid ...id to (imbed 299,9 thr..2h 3%.,2 comod or coral it Phietlff ?Uwe mei the etelceettti wina.cni 4495.219. Az teed of the isten.:O21 yo: *tit rod in 4nsra Aro Mr, re4.2”. drpRAKI1k <llama at ccneceocceth.v. Ku 902 10 mole eltc915 29 noicd the esu thio. 02.4/ {egg lad Ike runty of 994 <bawl IXJ NOT .rsoe envautplemlf Once )90 d910.4 elnielipt dad NS Sly du./46CI. W To lip vol (beide mot that 401 re900 title rumeoln r SwacItC4 mad aid apt the *MOUS ideal I 09.9,9444 tee 0•4 04O11 ewe hit limey tire. 199.94.9.4 a Or wilovis own,. soy by filed 902 00 (Mk ells Can If x.t wisb a weivt pat OP010,14 ,1 Wtlit Oak* is *0 Mod enhe baron or Ow kw ad menu tom Vtly MAY )00m, Panda &Arn Rit.FM.Clit non Can Awning Army, be. Os Curdle Coat 230 Mum, Woe 1920 %i Pt enettaon& 33401 511.132/100 I Oolenterfalnwalplea H IE D IE DOE Page 433 Page 435 ERRATA SHEET 2 IN RE: JANE DOE V. JEFFREY EPSTEIN 3 Qt: PASHA J. SULLIVAN, RPR, FPR, CLR 4 DEPOSITION OF: JANE DOE 5 DATE TAKEN: September 30, 2009 6 DO NOT WRITE ON TRANSCRIPT- ENTER CHANGES HERE 7 PACE. LINE /I CHANGE REASON 10 11 12 13 14 IS 16 17 18 19 Hesse forward the original signed CROW sheet to this office so that copies may be distribute:dwell parties. 20 Under penalty of perjum I declare Om I hat read my 21 deposition and that it is true and correct subject to any changes in form cc substance emceed hens. 22 23 DATE: 24 25 SIGNATURE OF DEPONENT' Page 434 1 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby artily that I have read the foregoing 6 deposition by me given, and that the statements 7 contained herein are hue end 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 JANE DOE 18 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, 45 (Pages 433 to 435) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 92ef5b62-38a5-4202-a350-6633a6c6S13b EFTA00750818