EFTA00157838.pdf

0166 I UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON 2 3 4 5 Plaintin, 6 -vs- VOLUME II OF II 7 JEFFREY EPSTEIN, 8 Defendant. 9 10 Related cases: 11 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-80811, 08-80893, 09-80469 12 09-80591, 09-80656, 09-80802, 09-81092 13 14 15 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF 16 -■- 17 18 December 4, 2009 10:25 - 5:00 p.m. 19 20 West Palm Beach, Florida 21 22 23 Reported By: Cynthia Hopkins, RPR, FPR 24 Notary Public, State of Florida Prose Court Reporting 25 0167 I APPEARANCES: 2 On behalf of 3 4 5 6 7 8 9 10 11 On behalf of the Defendant, Jeffrey Epstein: ROBERT D. CRITTON, JR., ESQUIRE MARK T. LUTTIER, ESQUIRE BURMAN, CRITTON, LUTHER & COLEMAN, LLP West Palm Beach, Florida lilcifiCl/Documentstleand%20Scitings/ProductionMesktop/M. -%20Vol.%2011.txti12/11/2009 6:15:58 PNI1 3505.044 Page I of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005389 EFTA00157838 12 Phone: 13 14 15 ALSO PRESENT: 16 stein via video conference 17 Paralegal, P.A. 18 19 Stan Sanders, Videographer Visual Evidence, Incorporated 20 21 22 23 24 25 0168 I 2 INDEX VOLUME II 3 4 5 WITNESS: DIRECT CROSS REDIRECT RECROSS 6 7 CONTINUED 8 BY MR. LUTTIER 170 9 10 11 12 EXHIBITS 13 14 15 EXHIBIT DESCRIPTION PAGE 16 DEFENDANTS NO. 1 11 17 Plaintiffs Notice of Serving Second Amended Answers to Interrogatories 18 DEFENDANT'S NO. 2 29 19 Answers of Interrogatories 20 DEFENDANTS NO. 3 119 First Amended Complaint 21 DEFENDANT'S NO. 4 254 22 Plaintiffs Notice of Serving Third Amended Answers to Defendant's First 23 Interrogatories 24 25 0169 1 gi sts: 2 THE VIDEOGRAPHER: We're going back on the 3 record at 2:42. 4 BY MR. LUTTIER: 5 Q. Mom -- ma'am, at the break we had just file://fq/Documentstleand%20SettingsRroduction/Desktop .% ' 20-%20Vol.%2011.txtl12/11/2009 6:15:58 PM1 3505.044 Page 2 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005390 EFTA00157839 6 been discussing your relationship with aa 7 le You used the phrase in your testimony 8 earlier, you used the phrase "eat out." Could you 9 describe what that phrase means in the context that 10 you were usin it? 11 MR. : We will stipulate that what 12 it means is cunnilingus. 13 BY MR. LUTHER: 14 Q. Oka . Do ou know what a sex toy is? 15 MR. : Could you explain what 16 relevance or materiality your understanding of 17 that line -- 18 MR. LUTTIER: Sure. It was -- 19 MR. : -- of questioning might have 20 since there is no allegation that sex toy 21 ever employed in encounters between and 22 Mr. Epstein? 23 MR. LUTTIER: Well, I dispute that for 24 sure. I just tell you if you read the record 25 carefully, you will find out that is not at all 0170 1 true, and that's why it is relevant. Come up 2 many a 3 MR. : In connection with 4 allegations from 5 MR. LUTTIER: There and in the . 6 MR. : Okay. Well, if you 7 represent, if you represent that that's the 8 case, then proceed. 9 BY MR. LUTTIER: 10 Q. Do you know what a sex toy is? 11 A. Yes. 12 Q. Okay. And what is your understanding of 13 that term so that we are understanding each other 14 when I ask you these questions? 15 A. I guess toys used doing sexual things. 16 Q. Okay. And that would include, for 17 example, vibrators? 18 A. Yes. 19 Q. Dildos? 20 A. Yes. 21 Q. Have you used sex toys in the past? 22 A. No. 23 Q. Never? 24 A. Never. 25 0171 2 3 4 5 6 7 Q. Did you ever tell anybody you had? A. No. Q. Did you, did you ever use any sex toy with Jeffrey Epstein? A. He tried to use a massage thing and I told him no. file el , :///q/Documents%20and%20ScitingsRroduction/Dcsktoe% 20-5£20Vol.%2011.txti12/11/2009 6:15:58 PM] 3505.044 Page 3 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005391 EFTA00157840 8 Q. What did you mean by "massage thing"? 9 A. Whatever it was in the hell that he had. 10 Q. Well, what -- describe what you are 11 talking about. 12 A. 'just told you. 13 Q. Well, massage thing doesn't tell me 14 anything. What are you talking about? 15 A. I don't know what it was called. I don't know 16 what it is. 17 Q. What did it look like? 18 A. It looked -- it was -- I don't know. It 19 vibrated. It looked like it was a neck massager. 20 Q. But do you know, do you know -- can you 21 describe, physically describe how big it was, what 22 color it was, what it looked like? Can you describe 23 anything about it? 24 A. It was gray and do you want me to draw you a 25 picture because I don't know how to describe what it 0172 1 looked like. 2 Q. How large was it? 3 A. It was like this big (indicating). 4 Q. Okay. 5 A. It was like a neck massager. 6 Q. You know like -- you know what Brookstone 7 is, a store? 8 A. Yeah. 9 Q. Have you ever been in there and they have 10 these massages that, like you can reach behind your 11 back and stuff like that. Are we talking about 12 something you know, like that? 13 A. Yeah, but it didn't have a wire, an electrical 14 wire. 15 Q. Okay. 16 A. It was like battery operated. 17 Q. And you say that Mr. Epstein tried to use 18 this on you and you said no? 19 A. Yeah. 20 Q. And then he -- 21 A. That was the end of that. 22 Q. -- didn't use it? 23 A. He did not, and he's never, it never was 24 brought up again. 25 Q. Have you ever desired to use any kind of 0173 1 sex toy? 2 A. No. 3 Q. And, and then not done it for some reason? 4 A No 5 6 7 8 9 file:///CVDocumentstleand%20Sctfings/Production/Deskiony 't 2iiVol ' 2011.ixill1/11/2009 6:15:58 PMJ 3505.044 Page 4 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005392 EFTA00157841 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 017 2 3 4 5 6 7 8 9 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 017 2 3 4 5 6 7 8 9 10 11 file:///q/Documentstleand%20Scllings/Production/Deskiopie2M20-%20Vol.%2011.uall1/11f2009 6:15:58 PM] 3505.044 Page 5 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005393 EFTA00157842 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0176 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0177 1 2 3 4 5 6 7 8 9 10 11 12 13 file://fq/Documentstleand%20Settings/Production/Deskio1M.q. 20-%20Vol.%2011.txil I V Iltzom 6:15:58 PNI1 3505.044 Page 6 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005394 EFTA00157843 14 15 16 17 18 19 20 21 22 23 24 25 0178 A. No. 2 Q. So you were just standing there and 3 this -- 4 A. Yeah. 5 Q. And what, if anything, did you say when 6 this person began to perform oral sex on you? 7 A. I didn't say anything. I just felt really 8 weird and I just stood there. 9 Q. And this is a person you had never seen 10 before? 11 A. Yes. 12 Q. And for how long a period did this person 13 perform oral sex on you? 14 A. I don't know. 15 Q. And this is while you were standing? 16 A. Yeah. 17 Q. Did, did it, when you say you don't know, 18 are we talking about this went on for 15 or 20 19 minutes or this went on for three minutes? 20 A. Like 15, 20 minutes. 21 Q. Okay. Did you, did you move from where 22 you were standing to some other location while she 23 was doing this? 24 A. I just said no. 25 Q. Did you have an orgasm -- 0179 1 A No 2 Q. -- as a result of her performing? Did you 3 at any time during the 15 or 20 minutes that she was 4 performing oral sex on you say anything to her? 5 A. Yeah, I told her to stop. 6 Q. And when did you tell her to stop? 7 A. After like 15 minutes, I told her to stop and 8 that I felt uncomfortable. 9 Q. And what did she do? 10 A. She stopped. And I told Jeffrey I wanted to 11 leave, and he gave me $300 and I left. 12 Q. So, the first time you told this lady to 13 stop, she stopped? 14 A. Yeah. 15 Q. And you told Jeff you wanted to leave and Q. With respect to the incident that you were describing earlier when you were at Mr. Epstein's house and you said there was another woman present who was nude, do you recall that testimony? A. Yeah. Q. And was there any discussion between you and she before she began to perform oral sex on you? A. And I told you no. Q. No words at all exchanged? file:///CVDocuments%20and%20Scitings/Production/Desktop .Ma0-%2OVol.%2011.txt112/11/20D9 6:15:58 PM] 3505.044 Page 7 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005395 EFTA00157844 16 he didn't try to stop you? 17 A. No. 18 Q. Did you perform any sexual act on this 19 woman? 20 A. No. 21 Q. Did you touch her in any way? 22 A. No. 23 Q. And at the time that you were standing 24 there and this lady was performing oral sex on you, 25 I assume she was kneeling or something? 0180 A. Yes. 2 Q. And where was Mr. Epstein during this? 3 A. Behind her having sex with her. 4 Q. While she was kneeling? 5 A. Yeah. 6 Q. Did you say anything to Mr. Epstein? 7 A. Besides that I wanted to leave, no. 8 Q. Which you said after 15 minutes, right? 9 A. Yeah. 10 Q. How about during the first 15 minutes, did 11 you say anything at all? 12 A. No. 13 Q. Did you say, you know, I am uncomfortable 14 with the set-up; I want to leave? 15 A. 'just said no. 16 (Interruption at the door.) 17 18 19 20 21 22 23 24 25 0181 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 file://fq/Documentstleand%20ScuingsRroduction/Desktop 9a20-%20Vol.%2011.Lxii I VI 1/2009 6:15:58 PNI1 3505.044 Page 8 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005396 EFTA00157845 18 19 20 21 22 23 24 25 0182 2 3 4 5 6 7 8 9 10 I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0183 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 file:///CVDocumentstleand%20Scuings/Production/Deskiopt i. 1M1-%20Vol.%2011.txti 121112(X19 6:15:58 PN11 3505.044 Page 9 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005397 EFTA00157846 20 21 22 23 24 25 018 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 018 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 file:/NC /Documentstleand%20Scuings/ProductionMeskion 21M20-5£20Vo1.562011.txti 1211 1/2069 6:15:58 PMJ 3505-044 Page 10 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005398 EFTA00157847 22 23 24 25 0186 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0187 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 file:///C /Documentstleand%20SettingsRroduction/Desktop %2=20-%20Vol.%2011.txti 12111/2009 6:15:58 PM 3505.044 Page II o167 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005399 EFTA00157848 24 25 0188 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 0189 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 file://tCpflocuments%20and9420Scuings/Production/Desktop .%20M20-%20Vol.%2011.txti 12111/2009 6:15:58 PMJ 3505-044 Page 12 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005400 EFTA00157849 0190 1 2 3 4 5 6 7 Q. Do you know other women that have brought claims against Mr. Epstein? A. Yes. 8 Q. What other women do you know that have 9 brought claims against Mr. Epstein? 10 A. That's not my information to give you. 11 Q. My question stands. 12 A. I don't feel comfortable telling him. 13 MR. : Well, if you know the names 14 of other women who you know have brought 15 claims. 16 THE WITNESS: I know El has. I don't 17 know her last name. And I found out after I 18 filed my suit. 19 BY MR. LUTTIER: 20 Q. Anyone else? 21 A. Not that I know of, that are my friends. 22 Q. Well, misstion -- 23 A. Me and haven't talked since this accident 24 just for the record. 25 Q. My question wasn't limited to your 0191 1 friends. My question was did you know other women, 2 do you know other women that have brought claims to, 3 against Mr. Epstein? 4 A. Personally, no. 5 Q. Well, how would you know them if you 6 didn't know them personally? 7 A. I said no. 8 Q. Well, I'm, I'm getting the impression that 9 you're, yasfr being -- 10 A. I= is the only person that I know that has. 11 Q. And what did you mean when you answered 12 earlier to my question when I asked you if you knew 13 other women that had brought claims against 14 Mr. Epstein, you answered yes? 15 A. And you wrote down.' did you not? 16 Q. That's the only person that you were 17 referring to? 18 A. Yes. 19 Have you ever heard of a lady by name of 20 21 A. 22 23 A. No. 24 , Q. Who -- all right. arrson,e, how 25 do you know this person, 0192 I A. She was a friend of mine. file://flifilocuments%20and%20ScitingsRroduclion/Dcsktop .%21a20Vol.%2011.txt112/11/20D9 6:15:58 PM] 3505.044 Page 13 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005 40 1 EFTA00157850 2 Q. And she was a friend of yours commencing 3 when? When did you first meet her? 4 A. I don't remember. Years ago. 5 Q. Before you went to see Mr. Epstein? 6 A. No. She, I met her through my friend • 7 Q. &-- what's es name? 8 A. 9 Q. Do you know any other girls that claim to 10 have gone to Mr. Epstein's house to perform massages 11 on him? 12 A. Do what? 13 Q. Do you know any other girls that have gone 14 to Mr. Epstein's house and claimed to have performed 15 massages oli? 16 A. Me, and. those are the only girls 17 that I know. 18 . And how is it that you met through 19 20 A. How do you meet your friends through friends? 21 Q. I have no idea. I mean, were you guys at 22 a party together, did you get on the phone with each 23 other? What did you do? 24 A. We were hanging out. 25 Q. "Hanging out," what's that mean? 0193 A. When you hang out. 2 Q. Were you at a function and all three of 3 you were there, for example? 4 A. Obviously we were at something hanging out. 5 Q. And did there come a time that you took 6 anyone to Mr. Epstein's house? 7 A. Yes. 8 Q. When was that? 9 A. I don't remember the times and dates but I 10 took and 11 Q. &which did you take first? 12 A. 13 Q. And in respect to when you went to 14 Mrgpstein's between May and .las_of and August 15 of'. when was it that you took ='? 16 A. Bro, I don't know. I just told you I don't 17 know times and dates. 18 Q. I realize don't know the exact time. 19 But was it in or was it in IM? 20 A. If I, if you know that I don't know the dates, 21 how would you ask me if it was in _≥ 22 Q. Well, what's your best estimate of how 23 many es you had made to Mr. Epstein's before you 24 took 25 A. I have no idea. 0194 1 Q. More than ten? 2 A. Probably. 3 Q. How long had you known. before you file:///q/Documents%20and%20Settings/Production/Dcsktop %20Carolyn%20-%20Vol.%2011.txti 12111/2009 6:15:58 PMI 3505.044 Page 14 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005402 EFTA00157851 4 took her to Mr. Epstein's? 5 A. I have known. for years. I met E l I 6 don't know. Ask me the question a am please. 7 Q. How long had you known before you 8 took her to Mr. Epstein's? 9 A. For about a year. 10 Q. And how did you meet? 11 A. She lived down the street from me. 12 Q. Was she a close friend? 13 A. Yes, she was. She was my best. 14 Q. You wouldn't do anything to harm her, 15 correct? 16 A. Correct. 17 Q. By the time you took. to 18 Mr. Epstein's, you had performed massages for 19 Mr. Epstein in the total nude; is that correct? 20 A. Uh-huh. 21 THE COURT REPORTER: Is that a yes? 22 THE WITNESS: Yes. 23 BY MR. LUTTIER: 24 Q. You had already had this sexual 25 relationship with this woman that you described 0195 I earlier at Mr. Epstein's? 2 A. Yes. 3 Q. You mentioned earlier that on these 4 occasions when you gave Mr. Epstein a massage, he 5 would masturbate I believe you said; is that right? 6 A. Yes. 7 Q. Did that occur, that is Mr. Epstein 8 masturbating, on each and every occasion when you 9 went to Mr. Epstein's from the first occasion to the 10 last occasion? 11 A. Yes. 12 Q. Did you physically see him masturbating? 13 A. Yes. 14 Q. That is there was no towel covering his 15 genitalia or anything like that? 16 A. No. 17 18 19 20 21 22 23 24 25 0196 2 3 4 5 file://fq/Documentstleand9420ScuingsRroduclion/Dcsktop .%21M0-%20Vol.%2011.txtl12/11/2009 6:15:58 PM] 3505.044 Page 15 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005403 EFTA00157852 6 7 8 9 10 1 12 13 14 15 16 17 18 19 20 21 22 23 Q. Had, have you ever been photographed in the nude? A. No. At Mr. Epstein's, yes. Q. How about any place other than Mr. Epstein's? 24 A. No. 25 Q. And who photographed you in the nude at 0197 Epstein's? 2 A. 3 Q. 4 A. 5 Q. And when in this time period that you went 6 to Mr. Epstein's did photograph you in the 7 nude? 8 A. It had to have been in the summer. It was in 9 the summer. 10 Q. And why do you know it was in the summer? 11 A. Because it was summertime. 12 Q. And where did this photographing occur? 13 A. In Mr. Epstein's house. 14 Q. Where in the house? 15 A. Everywhere in the house, outside by the pool, 16 and outside off the dock by the Intracoastal. 17 Q. Were you photographed on more than one 18 occasion? 19 A. No. 20 Q. Let me rephrase the question. You 21 mentioned that you were photographed everywhere in 22 the house? 23 A. Yes. 24 Q. Was there -- 25 A. It was in the same day. 0198 Q. But more than one picture was taken? 2 A. Yes. 3 Q. All right. And what type of, do you know 4 what type of camera was used? Was it a digital 5 camera or a -- 6 A. A digital camera. 7 Q. All right. who? file:///q/Documentstleand%20Scuings/Production/Desktop .a20-%20Vol.%2011.txtl12/11/2009 6:15:58 PM] 3505.044 Page 16 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005404 EFTA00157853 8 A. It was digital -- it wasn't like a digital 9 camera like, it was like a photography digital camera 10 like a professional camera, a professional digital 11 photography camera. 12 Q. Are you, are you -- 13 A. Not like one you buy at Wal-Mart. 14 Q. When you're describing it as a 15 professional digital camera, are you talking about a 16 camera that's got a big lens on it? 17 A. Yes. 18 Q. And did this -- 19 A. And there, and there was a regular digital 20 camera. She used two different cameras. 21 Q. And you say this was, in addition to being 22 in the house, was that on a dock? 23 A. Yes. 24 Q. And, and were you completely nude for all 25 of these photographs? 0199 1 A. Yes. 2 Q. So this happened in the daytime? 3 A. Yes. 4 Q. I assume the dock is out somewhere near 5 the Intracoastal? 6 A. Yes. 7 Q. Out in plain view? 8 A. But there was nobody outside. I made sure 9 there was nobody that could see me. 10 Q. Had anyone before that occasion ever 11 photographed you in the complete nude? 12 A. And I already said no. 13 Q. And how many photographs would you 14 estimate were taken? 15 A. I don't know. At least ten. 16 Q. Did you -- how, how is it that it -- well, 17 strike that. 18 Did, did ask you if she could take 19 photographs of you in the nude? 20 A. She called me and told me that Mr. Epstein 21 would pay me $500 if there could be nude pictures taken 22 of me. And my words to her were only if you take them; 23 I will not let Mr. Epstein take them of me. 24 Q. All right. So you set the conditions 25 under which the photographs were to be taken? 0200 1 A. Yes. 2 Q. And the photographs were taken with your 3 knowledge and consent, correct? 4 A. (Witness nods head.) 5 Q. Did you ever see the photographs? 6 A. Since that day, no. I saw them on the camera. 7 I've never seen the actual photographs. 8 Q. Did you make any comment to about 9 the photographs? fi a le:///CV tl Documents eand%20Salings/Production/Deskion 20-%20Vol.%2011.txti12/11/2009 6:15:58 PM) 3505.044 Page 17 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005405 EFTA00157854 10 A. Yeah, I asked them what would happen with 11 them, and she told me that they were for Mr. Epstein's 12 personal enjoyment. 13 Q. Was Mr. Epstein present when these 14 photographs were taken? 15 A. No, not to my awareness. 16 Q. You -- that is on the occasion that you 17 went to the house when these photographs were taken, 18 you never saw Mr. Epstein? 19 A Yet I didn't tee Mr Pntgrin Nn 20 21 22 23 24 25 0201 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 0202 1 2 3 4 5 6 7 8 9 10 11 file://fq/Documentstleand%20Scllings/Production/Deskia.%20M20-%2OVol.%2011.txtl12/11/20D9 6:15:58 PM] 3505.044 Page 18 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005406 EFTA00157855 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0203 I 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0204 2 3 4 5 6 7 8 9 10 11 12 13 file:///Cl/Documents%2Dand%20Scuings/Production/Deskiop/MISi2M120-%20Vol.%2011.txtr12/11/20D9 6:15:58 PMJ 3505.044 Page 19 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005407 EFTA00157856 14 15 16 17 18 19 20 21 22 23 24 25 0205 2 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0206 2 3 4 5 6 7 8 9 10 12 13 14 15 file:///q/Documents%20and%20Scuings/Production/Desktop .%20e1-%20Vol.%2011.txti 12/1120096:15:58 PMJ 3505.044 Page 20 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005408 EFTA00157857 16 17 IS 19 20 21 23 24 25 020 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Q. When did you first meet Mr. 21 A. When I was 13. 22 Q. Did you, did you meet him before you first 23 went to Mr. Epstein's? 24 A. Yes. 25 Q. Had you had a sexual relationship with 0208 1 Mr. =, obviously? 2 A. Yes. 3 Q. Had you had sex with Mr. before you 4 went to Mr. Epstein's the first time? 5 A. Yes. 6 Q. And what sexual acts had you engaged in 7 with Mr. before you went to Mr. Epstein's? 8 A. Intercourse. 9 Q. And did you consider Mr. to be your 10 boyfriend? 11 A. Yeah. 12 Q. And were you dating him during the entire 13 period of time that you went to Mr. Epstein's? 14 A. Yeah. 15 Q. And did Mr. ever physically bring 16 you to Mr. Epstein's house? 17 A. Yes. file:///q/Docurnents%20and%20Scuings/Production/Deskia.%a0-%2OVol.%2011.txt112/11/2009 6:15:58 PM] 3505-044 Page 21 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005409 EFTA00157858 18 Q. Did you ever pay Mr. any money for 19 bringing you to Mr. Epstein's house? 20 A. No. 21 Q. Did Mr. ever bring anyone else to 22 Mr. Epstein's house? 23 A. My brother came with us but he didn't bring 24 any other females, 25 Q. How about II? 0209 1 A. Oh, IS and when I went with them. He 2 didn't bring them there by themselves. 3 Q. Let me go back and make sure my question 4 is clear. Was there, was there ever an occasion 5 that Mr. drove a vehicle in which there were 6 other girls that were delivered to Mr. Epstein's 7 house other than just yourself? 8 A. You say delivered like we're a bunch of 9 flowers for him. 10 Q. Pick whatever, what word would you prefer, 11 dropped off? 12 A. Yes, that sounds a lot more better than 13 delivered. 14 Q. Fine. Whateysixtv want. Ever any 15 occasion where Mr. brought any females that 16 he dropped off at Mr. E stein's other than -- 17 A. Yes,me and ., and me and 18 Q. Did In. or ever pay 19 money for bringing them? 20 A. No. 21 Q. Did you ever receive any money from 22 Mr. Epstein for bringing 23 A. Yes. 24 Q. How much did you get? 25 A. An extra $100. 0210 1 Q. And did you tell S. that you were paid 2 $100 by Mr. Epstein to bring her to him? 3 A. Yes. 4 Q. And what was her response? 5 A. I want half. 6 Q. And what did you say to that? 7 A. Okay. 8 Q. So, you gave her 50 of the $100? 9 A. Yeah. 10 Q. And everybody was happy? 11 A. Yeah. 12 Q. Did you bring S. on more than one 13 occasion? 14 A. Yes. 15 Q. Did you get paid $100 on each occasion -- 16 A. Yes. 17 g. -- that you brought S.? Did you tell 18 on each occasion when you got paid $100 to 19 bring her? file:///q/Documents%20and%20Scifings/ProductionMesktaM:1-%20Vol.%2011.txt[12/11/2009 6:15:58 PM] 3505-044 Page 22 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005410 EFTA00157859 20 A. Yes. 21 Q. And did you give her half the 100 or S50 22 every time -- 23 A. Yes. 24 Q. -- that you were paid? On how many 25 occasions did bring S. and get paid $100? 0211 A. Three or four times. 2 Q. How much did S. get paid to come to 3 Mr. Epstein's? 4 A. 200, sometimes three. I'm not sure which 5 times. Probabl the times when she went there herself. 6 Q. Did M. go to Mr. Epstein's on occasions 7 other than when she went with you? 8 A. Yes. 9 Q. But she had never been there until you 10 took her the first time? 11 A. Yes. 12 Q. Were the individual that first 13 suggested to M. that she go to Mr. Epstein's? 14 A. Obviously if I'm the one who brought her there 15 for the first time. 16 Q. Well, it would be possible that she could 17 have heard of Mr. Epstein from someplace else. 18 A. No. 19 Q. So the first time she heard the name 20 Jeffrey Epstein was from you? 21 A. Yes. 22 . And on the first occasion when you told 23 about Jeffrey Epstein, what did you tell her? 24 A. That we would go there and give him a massage 25 and he might ask you to get topless. 0212 1 Q. Did you tell her at the time that you 2 first discussed it with her everything that you had 3 experienced in going to Mr. Epstein's? 4 A. No. 5 Q. Why not? 6 A. Because I knew she wouldn't be exposed to it. 7 Q. And this was your best friend? 8 A. Yes. 9 Q. And you say you knew what? 10 A. I knew that she wouldn't be exposed to it. 11 Q. What do you mean she wouldn't be exposed 12 to it? 13 A. Because I knew that I felt uncomfortable with 14 the thing with the girl. And I told Jeffrey if he did 15 it to my friends, I would not bring them. 16 Q. Okay. 17 A. So I knew that she wouldn't have been exposed 18 to it. 19 Q. So, in your, you had some conversation at 20 some point in time with Jeffrey Epstein about -- 21 A. I took -- when he asked me to bring some girls file://fiCYDocuments%20and%20ScitingsRroduction/Deskiop/Ml.q a-Vi20Vol.%2011.txtl12/11/2009 6:15:58 PM] 3505.044 Page 23 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFfA_000054II EFTA00157860 22 my age, I told him that I would not bring my friend if, 23 if that situation was to occur with her because I didn't 24 like it. I felt uncomfortable, and I would not subject 25 my friend to it. 0213 1 Q. Is that the only thing that had occurred 2 lyign you were at Mr. Epstein's that you did not tell 3 about? 4 A. Yes. 5 Q. So, you had told M. that Mr. Epstein 6 might masturbate while she was there? 7 A. Yes. 8 Q. Did you tell her that he might ejaculate 9 while she was there? 10 A. Not on her but yes. 11 Q. Well, did Mr. Epstein ever ejaculate on 12 you? 13 A. No. 14 Q. All right. What did you tell M. before 15 you took her there for the first time about what the 16 state of dress that she would be in? 17 A. I just told her to wear clothes. 18 Q. Did you tell her that she may be asked to 19 be totally nude? 20 A. I said that she, she might ask to take off 21 some of her clothes. I didn't specifically say you're 22 going to have to get naked. 23 Q. But you had been, at that point in time 24 that you first took M. there, you had been totally 25 nude for months while performing massages for 0214 1 Mr. Epstein, correct? 2 A. So. 3 Q. Correct? 4 A. Yes. 5 Q. But you didn't tell your best friend that? 6 A. No, because if he was going ask her, that 7 would be him asking her and that would be her own 8 decision. 9 Q. You didn't consider there to be anything 10 dangerous about going to Mr. Epstein, did you? 11 A. No. 12 Q. I mean, you never felt like you were in 13 danger when you went to Mr. Epstein's did you? 14 A. No. 15 Q. You never felt that any harm was going to 16 come to you? 17 A. No. 18 Q. And you really never had any fear about 19 going there, correct? 20 21 22 23 file:///CVDocumentstleand9420ScuingsRroduclion/Deskiopa 1MI-%20Vol.%2011.txtl12/11/20D9 6:15:58 PM] 3505-044 Page 24 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005412 EFTA00157861 24 25 0215 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0216 1 2 3 4 5 6 7 Q. Did there -- there obvio a time 8 that you got pregnant with Mr. 9 A. Obviously. 10 Q. Did you and Mr. leave the State of 11 Florida together at some point in time? 12 A. Yes. 13 Q. And approximately when was that? 14 A. I was in July when I was 16. 15 Q. 16 A. eah. 17 Q. Is that the same time that you stopped 18 going to Mr. Epstein's? 19 A. Uh-huh. 20 Q. And is that, in fact -- 21 MR. LUTTIER: Did you get that answer? 22 THE COURT REPORTER: Uh-huh. 23 BY MR. LUTTIER: 24 Q. -- is that in fact why you stopped l 25 to Mr. Epstein's, because you and Mr. were file:ffill/Documents%20and%20Settings/Production/Deskton %20Vol.%2011.txt[12/11/20D9 6:15:58 PMJ 3505.044 Page 25 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005413 EFTA00157862 0217 1 leaving? 2 A. Yes. 3 Q. And where did ,ou and Mr. go? 4 A To 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 021 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0219 file://fq/Documentstleand%20ScItingsRroduclion/Dcsktop .%a20-%20Vol.%2011.txt112/11/2009 6:15:58 P141 3505.044 Page 26 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005414 EFTA00157863 2 3 4 5 6 7 8 9 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0220 A. When I was months pregnant. So. in 2 February. 3 Q. Of 1? 4 A. Yeah. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 022 2 3 there a point in time that you and Mr. returned to Florida? A. Yes. Q. When was that? file:///q/Documentstleand%20SettingsRroduction/Dcsktop %2=20-%20Vol.%2011.txt1 12111/2009 6:15:58 PMJ 3505.044 Page 27 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000054 15 EFTA00157864 4 5 6 7 8 9 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 02 2 3 4 5 6 7 8 9 10 11 How would you describe your life from July 12 en you, approximate when you moved to 13 rough February of g? 14 A. Frustrating. 15 Q. And why was it frustrating? 16 A. Because I had a lot of secrets that I had held 17 from about Mr. Epstein, and I was just felt like I 18 was losin m • mind. 19 20 21 22 23 24 25 022 You say you held secrets rom What 2 secrets did you hold from 3 A. What exactly was happening at Mr. Epstein's 4 house. 5 Q. Well, you indicated that took you to file://fq/Documentstleand%20ScitingsRroduction/Deskiop/MIC2( c, 211Vol.%2011.txti 12)11/20096:15:58 PMJ 3505.044 Page 28 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005416 EFTA00157865 6 Mr. Epstein's on more than one occasion? 7 A. But he didn't know what doing. 8 Q. When was the first time took you to 9 Mr. Epstein's? 10 A. I don't know. 11 Q. But we know it wasn't the first or second 12 time, right? 13 A. Yeah. 14 . Because on those occasions you went with 15 16 A. He only, he only took me sometimes because 17 Mr. Epstein paid for either his drivers to pick me up 18 and drop me off or a Yellow Cab. 19 Q. Well, do you r e first, the 20 incident the first time took you? 21 A. What do you mean the incident? 22 Q. Well, do you recall what you told him 23 first time when you had him take you? 24 A. That I was goiailean his house. 25 Q. And what did say in response? 0224 1 A. Okay. 2 Q. Did you, the next time that he took you, 3 did you tell him anything different? 4 A. No. 5 Q. Did there ever come a time that when 6 took you to Mr. Epstein's you told him anything 7 other than you were going there to clean the house? 8 A. No. 9 Q. Did ever ask you -- or, or strike 10 that. When took you to Mr. Epstein's, did he 11 wait for you or did he come back? 12 A. He waited for me. 13 Q. And where did he wait? 14 A. Outside by the Intracoastal. It was in front 15 of the house the FBI was at. 16 Q. So, he didn't come in the house? 17 A. No. 18 Q. Did he ever meet Mr. Epstein? 19 A. Yes, he has. 20 Q. Did he ever have any discussions with 21 Mr. Epstein? 22 A. Yeah, about the Shelby Cobra that Mr. Epstein 23 has. My wires -- 24 THE COURT REPORTER: The what? 25 THE WITNESS: Shelby Cobra. My wire is 0225 1 stuck in 2 MR. : Hold on. 3 MR. Let's go off the record for 4 just a second, please. 5 (A brief recess was held.) 6 BY MR. LUTTIER: 7 Q. Were you present for any discussions file://fq/Documents%20and%20ScitingsRroductionecsktop .% 20-%20Vo1.562011.txti 12!11120096:15:58 PMJ 3505.044 Page 29 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005417 EFTA00157866 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 022 2 3 4 Q. Has ever discussed with you his 5 contact or discussions with Mr. Epstein? 6 A. Yes. He told me that you guys tried to hire 7 him. 8 Q. Who do you mean by "you guys"? 9 A. Mr. Epstein's law firms. 10 Q. Which firms arc you talking about? 11 A. The ones that defend Mr. Epstein. 12 Q. Did you know how many law firms that is? 13 A. I have no idea. All I know is that his law 14 firms fried to hire my father. 15 Q. And when did e tell you that? 16 A. Last year. 17 Q. Meaning calendar year '08? 18 A. Yep. 19 Q. And was incarcerated recently? 20 A. Yes, he was. 21 Q. And when was he incarcerated? 22 A. I believe it was -- was it -- I think it was 23 last year. 24 Q. That would be '08? 25 A. Yes. 0227 1 Q. When did he get released from 2 incarceration? 3 A. I don't know the date. 4 Q. So, did these lawyers that were trying to 5 hire him go meet him in jail? Is that what you are 6 saying? 7 A. I don't know. Mr. Epstein was in jail with 8 him. 9 Q. So, Mr. Epstein and Mr. met each 8 between and Mr. Epstein? A. Yes, I was. Q. And where did they take place? A. Outside in the driveway in front of the garage that had all the cars. file:///q/Documents%21:1and%20Satingseroduclion/Daktone0-%20Vol.%2011.txti12/11/2009 6:15:58 PM] 3505.044 Page 30 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005418 EFTA00157867 10 other while they were both incarcerated in the same 11 institution? 12 A. No. Mr. and Mr. Epstein, or Mr. 13 and Mr. Epstein met each other while I was still going 14 to Mr. Epstein's house, but then again met while they 15 were inc together. 16 Q. Did ever share with you what he told 17 Mr. Epstein about you? 18 A. No. 19 Q. Did he ever tell you that he discussed you 20 with Mr. Epstein? 21 A. Yes. 22 Q. But he didn't tell you what he said? 23 A. No. 24 Q. Did he ever tell you what he said about 25 what information you knew about Mr. Epstein before 0228 you went -- 2 A. No. 3 Q. -- to see him the first time? Did he ever 4 tell you about what you told the other girls before 5 you took them to Mr. Epstein's? 6 A. No. 7 Q. Did he ever tell you that he attempted to 8 get employment from Mr. Epstein? 9 A. Yes. 10 Q. And what did he tell you Mr. Epstein said 11 in response to that? 12 A. I have no idea. But if you would like to let 13 me know. Co ahead. 14 15 16 17 18 19 20 21 22 23 24 . o, you on rca y ieve e s a omen 25 he made to you that, what somebody tried to hire -- 0229 I A. No, I believe that you guys tried to hire him. 2 Q. How do you decide which statements he 3 makes you believe and which you don't? 4 A. He showed me the address. 5 Q. The address of what? 6 A. Your guys's law firm. 7 Q. Well, you keep saying, you guys. What 8 firm is that? 9 A. The attorneys on Mr. Epstein's side off of 10 Flagler Drive. 11 Q. And did he tell you, did Mr. tell file://fq/Documents%20and%20Scuings/ProductionMesktopeal:1-%20Vol.%2011.txti 12/1120096:15:58 PM] 3505.044 Page 31 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005419 EFTA00157868 12 you that he came to meet with those lawyers? 13 A. Yes, he did. 14 Q. Did he tell you whether or not every 15 single word he said had been recorded? 16 A. I have no idea. He didn't tell me anything 17 about it. 18 Q. Did he tell you who-all was present at the 19 meeting? 20 A. No, he didn't. 21 Q. He didn't tell you anything about what he 22 said at that meeting, did he? 23 A. No. 24 Q. And in particular he didn't say what he 25 said about you, did he? 0230 1 A. No. 2 Q. You didn't ask him either, did you? 3 A. I did and he wouldn't tell me. 4 Q. Did you wonder why he wouldn't tell you 5 what he had told Mr. Epstein's lawyers about you? 6 A. No, and I could really care less because he 7 didn't go through half the traumatic things I did with 8 Mr. Epstein. 9 Q. Well, what traumatic things did you go 10 through? 11 A. Well, being that I was an underage girl with 12 an old man masturbating in front of me and bribing me 13 with hundreds and hundreds of dollars -- 14 Q. And how did that, how did that result in 15 any injury to you? 16 A. Well, my mental stability is nothing like it 17 used to be before I met Mr. Epstein. 18 Q. What do you mean by mental stability? 19 A. I'm scared to go places by myself. I have 20 trust issues with people now. I don't like when older 21 guys stare at me. 22 Q. Well, after you worked -- anything else? 23 A. Oh, no, you can go ahead. 24 Q. No, I want to get all your injuries that 25 you claim you have suffered as a result of going to 0231 1 Mr. Epstein's. Anything else? 2 A. You may continue. 3 Q. Is there anything else or have you now 4 told me everything and I will go back and ask you 5 about it? 6 A. You can continue asking me questions. 7 Q. Is there any other way you suffered any 8 damage as a result of going to Mr. Epstein other 9 than your mental stability is not the same, you're 10 scared to go places by yourself, that older guys, 11 you don't like it when older guys stare at you. 12 A. I have trust issues. 13 Q. Trust issues. Anything else? file://fq/Documentstleand%20Satings/Production/Dcsktop .%n%20Vol.%2011.txt112/11/2009 6:15:58 PM] 3505.044 Page 32 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005420 EFTA00157869 14 A. I don't know right now. 15 Q. Do you know of any way you suffered any 16 damage? 17 A. What? 18 MR. Well, you have already heard 19 repeatedly -- 20 MR. LUTTIER: No speaking -- Other than 21 what you have told me in this deposition. 22 MR. That's fine. 23 BY MR. LUTHER: 24 Q. Okay. Is that it? 25 A. Yeah, that's it. 0232 Q. Okay. Now, what do you mean when you say 2 you have trust issues. 3 A. Exactly what I said. 4 Q. Well, I don't understand that. Explain 5 that. Explain that to me. What do you mean you 6 have trust issues? 7 A. I have trust issues with people. 8 Q. Meaning what, you can't trust people? 9 A. No, I can't. 10 Q. Anybody? 11 A. Guys particularly. 12 Q. Males? 13 A. Males, older males. 14 Q. Any males, older males? 15 A. Yes. 16 Q. What age male does it have to be for you 17 not to be able trust them? 18 A. Older than myself. 19 Q. So, any man that is older than you, you 20 don't feel like you can trust him? 21 A. No. 22 Q. How has that impacted you in your daily 23 life? 24 A. Well, I go outside and there is men 25 everywhere. 0233 1 Q. Okay. So, what effect does that have on 2 you? You can't trust the people -- 3 A. Exactly -- 4 Q. -- according to you? 5 A. -- it. I can't trust nobody. 6 Q. So, you're not asking them to do anything 7 or do anything for you, are you? 8 A. No, because I don't want them to. 9 Q. Okay. So, help me understand how has this 10 impacted you at all that you claim you can't trust 11 men that are older than you? 12 A. Because I can't trust them. What else do you 13 want me to say? 14 Q. Well, I want you to describe how -- 15 A. I can't -- fi le://fCVDoc uments%20and%20Sct6 ngs/Production/Desktop .%21:n3-%20Vol.%2011.txti 12)11/2009 6:15:58 PM] 3505.044 Page 33 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000542 I EFTA00157870 16 Q. How your damage -- what is it that you 17 want these men to do -- 18 A. Nothing, I don't want them to do anything. 19 Q. -- that -- wait a minute. 20 A. I want them all to leave me alone. 21 Q. What is it that you want these men to do 22 that you can't trust them to do? 23 A. There is nothing that I don't want, that I 24 want them to do. 25 Q. Have you ever asked a man older than you 0234 to do something? 2 A. Other than my attorneys, no. 3 Q. All right. 4 A. No offense to you guys. 5 Q. So, there has never been an occasion since 6 you last went to Mr. Epstein where you asked a man 7 that was older than you to do something and you 8 counted on trusting them? 9 A. I counted -- well, my attorneys, but that's 10 it. 11 Q. Okay. But there has never been a time 12 that you've placed your trust -- 13 A. I refuse -- 14 Q. Wait a minute. 15 A. No, I don't let them, allow them. 16 Q. Now, so, you haven't even attempted to, 17 quote, to use your words, trust a man that's older 18 than you since you last saw Mr. Epstein; is that 19 correct? 20 A. Yes. That's correct. 21 Q. Now, when you say trust, do you mean you 22 don't want to be in their physical presence? 23 A. I don't, no, I don't want to be in their 24 physical presence. 25 023 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 file://fq/Documentstleand%20ScuingsRroduction/Dcsktona-%20Vol.%2011.txti 12/1120096:15:58 PM] 3505.044 Page 34 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005422 EFTA00157871 18 19 20 21 22 23 24 25 0236 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0237 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 file:///CVDocumentstleand%20ScuingsRroduction/Dcsktop .%20M0-%2OVol.%2011.txti 12/112009 6:15:58 PMJ 3505.044 Page 35 o167 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005423 EFTA00157872 20 21 22 23 24 25 023 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0239 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 file:///q/Documents%20and%20ScuingsRroduction/Deskione-%20Vol.%2011.txtl12/11/20D9 6:15:58 PMJ 3505.044 Page 36 o167 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005424 EFTA00157873 22 23 24 25 0240 2 3 4 5 6 7 8 9 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0241 2 3 4 5 6 7 8 9 10 11 12 13 14 I5 16 17 18 19 20 21 22 23 lilc:///q/Documents%20and%20ScitingsRroduction/Desktopal3-%20Vol.%2011.txti 12/1120D9 6:15:58 PMJ 3505.044 Page 37 o167 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005425 EFTA00157874 24 25 1 2 3 4 5 6 7 8 9 I0 1 12 13 14 I5 16 17 18 19 20 21 22 23 24 25 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 A. Q. Was it after Mr. Epstein? Yes. I left because I felt degraded. During the time that after you left -- strike that. After you last went Mr. Epstein i me which you say is in August of' did ou have a normal sexual relationship with ? A. No. Q. Were you having sex with him as frequently as twice a day? A. No. Q. Have you ever told anyone that that's what you did? A. No. Q. Was there ever a time that you had sex with twice a day? A. Yes. 24 Q. When was that? 25 A. Before Mr. Epstein. file:///C /Docurnents%20and%20Satings/Production/Deskia5a20-%2OVol.%2011.txti 12111/2009 6:15:58 PM] 3505.044 Page 38 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005426 EFTA00157875 0244 1 Q. And when did it change? 2 A. When I started going to Mr. Epstein's. 3 Q. And what did it change to? 4 A. To once or twice a week. 5 Q. And why did it change? 6 A. Because I felt disgusting. 7 Q. Did there ever come a time after you went 8 to Mr. Epstein's that you resumed having sexual 9 r ships with the same degree of frequency with 10 or anyone else? 11 A. With what? 12 Q. With 13 A. What do you mean? 14 Q. Did there ever come a time -- 15 A. That I went back to the same -- 16 Q. Right. 17 A. No. 18 19 20 21 22 23 24 25 0245 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 0246 file://fq/Documents%21:1and%20Sctfings/Production/Desktopa 1=-%20Vol.%2011.txti 12/112009 6:15:58 PM] 3505.044 Page 39 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005427 EFTA00157876 2 3 4 5 6 7 8 9 I0 1 12 13 14 I5 16 17 18 19 20 21 22 23 24 25 0244 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 024/ 2 3 file:/NC /Documentstleand%20Settings/Production/Desktapd=ty 20II.ixil I VII /2009 6:15:58 PMJ 3505.044 Page 40 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005428 EFTA00157877 4 5 6 7 8 9 I0 1 12 13 14 I5 16 17 18 19 20 21 22 23 24 25 024 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 025 2 3 4 5 file:///q/Documentstleandc+20Scitings/Production/Deskion MO-%20Vol.%2011.txti 12/ 11 /2069 6:15:58 PMJ 3505.044 Page 41 o167 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005429 EFTA00157878 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0251 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0252 1 2 3 4 5 6 7 file://fq/Documentstleand%20Scuings/Production/DeskupS 0-%20Vol.%2011.txti 12/112069 6:15:58 PM 3505.044 Page 42 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005430 EFTA00157879 8 9 10 I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 025 2 3 4 5 6 7 8 9 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 025 2 3 4 5 6 7 8 9 file://fq/Documentstleand%20ScuingsRroduction/DesktopME.ty 111S-%20Vol.%2011.txtl12/11/20D9 6:15:58 PMJ 3505.044 Page 43 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005431 EFTA00157880 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 025! 1 3 4 5 6 7 8 9 I0 1 12 13 14 I5 16 17 18 19 20 21 22 23 24 25 025( 2 3 4 5 6 7 8 9 10 I1 lilc://q/Documentstleand%20ScuingsRroduction/Desktopa20. 20-%20Vol.%2011.txti 1211 1 /2009 6:15:58 PM 3505.044 Page 44 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005432 EFTA00157881 12 13 14 15 16 17 18 19 20 21 22 23 24 25 025' 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 025E 2 3 4 5 6 7 8 9 10 11 12 13 file:///q/Documentstleand%20Scuings/ProductionMeskioS.% 20-%20Vol.%2011.txtl 1211 1/2069 6:15:58 PMJ 3505.044 Page 45 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005433 EFTA00157882 14 15 16 17 18 19 20 21 22 23 24 25 0259 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0260 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 file:///CVDocuments%21:1and%20Scuings/Production/Deskiop %2=20-%2OVol.%2011.txtl12/11/20D9 6:15:58 PMJ 3505.044 Page 46 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005434 EFTA00157883 16 17 18 19 20 21 22 23 24 25 0261 1 2 3 4 5 6 7 8 9 I0 11 12 13 14 IS . Was there another occasion that 16 was physically violent towards you? 17 A. Yes. 18 Q. When was that? 19 A. When he tried to drown me in a canal. 20 Q. When was that? 21 A. I don't recall. 22 Q. Was it before you went toMr 23 after? 24 A. Before. 25 Q. Was it while you were going to 0262 I Mr. Epstein's? 2 A. Yep. 3 Q. Did you tell Mr. Epstein about it? 4 A. Yes, I did. 5 Q. And when did you tell Mr. Epstein about 6 it? 7 A. On one of the occasions I went to his house. 8 Q. And what did he say? 9 A. I don't know. He talked to me about it. 10 Q. Was he sympathetic toward you? 11 A. A little bit. 12 Q. Did you tell you you ought to get away 13 from this guy? 14 A. Yeah. 15 Q. Did you pay attention to what he said? 16 A. Obviously not, if I had a kid with him some 17 years later. file:///q/Documents%20and%20Scitings/Production/Deskiopa0-%20Vol.%2011.txti 12111/2009 6:15:58 PM] 3505.044 Page 47 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005435 EFTA00157884 18 19 20 21 22 23 24 25 026 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 02 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 file://fq/DocumentstleandlneScuings/Production/Deskion 2( IM-%20Vol.%2011.txti 12/1120096:15:58 PMJ 3505.044 Page 48 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005436 EFTA00157885 2C 21 22 22 24 25 02 2 3 4 5 6 7 8 9 IC 1 12 12 14 IS If IE IS 2C 21 22 22 24 25 02 2 3 4 5 6 7 8 9 IC 1 12 12 14 IS If 11 IE IS 2C 21 file://fq/Documents%21:1and%20ScuingsRroduction/Desktopay' 2a9b 20Vol.%2011.txt1 12/1120096x15:58 PMJ 3505-044 Page 49 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005437 EFTA00157886 22 23 24 25 026 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Q. Yon mentioned the name earlier in the deposition, M Uh-huh. That was the missing IMI IN lin , whatever Jeffrey did with her, lx ..'rie nd. Q. When did you first meet Mr. ? A. A couple of weeks before I saw Mr. Epstein for 24 the first time. That was. IN 's boyfriend. 25 Q. When was the last time you spoke with 0268 1 Mr. ? 2 A. A couple of days after ME went missing. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 file:///q/Documents%21:1and%20Scuings/Production/Deskiop .C+2(a-%20Vol.%2011.txti 1211 1 /2069 6:15:58 PMJ 3505.044 Page 50 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005438 EFTA00157887 24 25 0269 1 2 3 4 5 6 7 8 9 I0 1 12 13 14 I5 16 17 18 19 20 21 22 23 24 25 0270 2 3 4 5 6 7 8 9 10 11 12 13 14 I5 16 17 18 19 20 21 22 23 24 25 file://fq/Documentstleandc+20Scitings/Production/Deskionba0-%20Vol.%2011.txti 12111/2009 6:15:58 PMJ 3505.044 Page 51 o167 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005439 EFTA00157888 0271 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 027: 2 3 4 5 6 7 8 9 10 I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 027 file:///q/Documentstleand%20Sctfings/Production/Deskia.%2=20-%20Vol.%2011.txti 12/11/2069 6:15:58 PMJ 3505.044 Page 52 o167 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005440 EFTA00157889 2 3 4 5 6 7 8 9 I0 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. When did you first use cocaine? 0274 A. During the time I met Mr. Epstein. I was 2 going Mr. Epstein's. 3 Q. And you never, prior to that had you used 4 it in any form, powder or crack? 5 A. No. 6 Q. Had you told anyone that you had used 7 cocaine prior to the time that you went to 8 Mr. Epstein's? 9 A. No. 10 Q. When did you first use marijuana? 11 A. Prior to the time I went to Mr. Epstein's. 12 That was the only drug I ever used before I met 13 Mr. Epstein. 14 15 16 17 18 19 20 21 22 23 24 25 027 2 3 file:///q/Documentstleand%20Scuings/Production/Deskun 2( M0-%20Vol.%2011.txti 1211 1120D9 6:15:58 PMJ 3505.044 Page 53 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000544 I EFTA00157890 4 5 6 7 8 9 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 027 2 3 4 Q. You said you took Ms. M. to 5 Mr. Epstein's as well, correct? 6 A. Yes. 7 Q. What did you tell Ms... before you took 8 her there the first time? 9 A. I told her what was going to happen. 10 Q. What exactly did you tell -- 11 A. But she did more things willingly than I even 12 told her. 13 Q. How do you know that? 14 A. Because I was there and I left the room. 15 Q. What did you see fl do? 16 A. She was offering information and Mr. Epstein 17 asked me to leave the room, and I was leaving the room. 18 Q. Offering information on what? 19 A. On things that her and her mother did. 20 Q. Like what? 21 A. I have no idea. I don't remember. I just 22 remember her saying things that her and her mother did 23 and I felt uncomfortable. And her and Mr. Epstein were 24 laughing and he asked me to leave the room and I left 25 the room. 0277 Q. Well, if you have a recollection that she 2 said something about -- 3 A. I said I don't have the recollection of 4 exactly what she said. I remember -- 5 Q. What's your best recollection of the file:///q/Documents%20and%20SettingsRroduction/Deskiop/Mic2e, 2(lVol 20II.ixil 1211120096:15:58 PMJ 3505.044 Page 54 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005442 EFTA00157891 6 subject matter about which she was talking? 7 A. That her and her mom have had, her mom does 8 things and has prices for things. Something of that 9 matter. I don't -- 10 Q. Sexual nature? 11 A. Yeah. 12 Q. What kinds of things? 13 A. I don't remember. 14 Q. And when you, before you took M. to 15 Mr. Epstein the first time, what you did you tell 16 her was going to happen? 17 A. I told her that he might ask her to get nude. 18 And I told her that you were just going to massage him. 19 Q. Did you tell her anything about your 20 experience with the other woman? 21 A. I didn't tell anybody that experience about, 22 with that other woman like I told you before. 23 Q. When you took M. the first time did you 24 go with her? 25 A. Yes. 0278 Q. Did you get paid? 2 A. Yes. 3 Q. How much? 4 A. $400. 5 Q. Just for taking her. 6 A. Well, 300 that I always get and an extra 100 7 for taking her. 8 Q. On the time that you took the first 9 time, did you go in with her and Mr. Epstein? 10 A. Yes. 11 Q. Did you take M. a second time. 12 A. Yes, and that's when I was asked to leave the 13 room. 14 Q. Did you take her a third time? 15 A. No. 16 Q. After the second time did she go back 17 herself? 18 A. I don't know. Ask her. 19 Q. Did you tell her that you were getting 20 paid to take her? 21 A. No. 22 Q. Did you share that money that you got for 23 bringing her with her? 24 A. No. 25 Q. After you took her the first time, were 0279 I you present in the room with Mr. Epstein the entire 2 time when she was there? 3 A. Other than the what -- 4 Q. When you went the first time -- 5 A. The fatime -- 6 Q. With M. -- 7 A. -- yes, I was there the whole time. file:ffill/Documents%20and%20Scuings/Production/Desktoine0-%2OVol.%2011.txt112/11/2009 6:15:58 PMJ 3505.044 Page 55 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005443 EFTA00157892 8 What occurred at the first meeting of you 9 and M. and Mr. Epstein? 10 A. We gave him a massage. She played with one 11 nipple. I played with the other, and he masturbated. 12 . And was the state of dress for you and 13 M.? 14 A. We were naked. 15 Q. Totally? 16 A. Uh-huh. 17 Q. And when, and when you left did you and 18 she discuss your encounter? 19 A. No. 20 Q. Did she have any complaints about it when 21 you left? 22 A. No. 23 Q. Did she -- 24 A. All she said was that was easy. 25 Q. Did she ask you if you, if you could take 0280 1 her back? 2 A. No. 3 Q. Were you present the second time she went? 4 A. Yes. 5 Q. That's the second time is when you 6 eventually walked out? 7 A. Yes. That's when I walked out. 8 Q. What occurred before you walked out? A. They were joking and laughing. She was telling him about some stuff that her mom and her did sexually for money or some stuff like that. I don't really remember the whole conversation word for word. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 028 1 2 3 4 5 6 7 8 9 file://fq/Documents%2Dand%20Settings/Produation/Dc‘ktapa =1-%20Vol.%2011.txti 12/11 /2069 6:15:58 PM] 3505.044 Page 56 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005444 EFTA00157893 10 11 12 13 14 I5 16 17 I8 I9 20 21 22 23 24 25 028 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 028 2 3 4 5 6 2 6 And after having been drug free from May 7 of a to Januarys why did you decide to do 8 crack? 9 A. I was going through a lot of things in my 10 brain. I had lost my boyfriend due to Mr. Epstein. 11 So, I was going file://fq/Documents%20and%20Salings/Production/DeskiopilM.q 2=0-%20Vol.%2011.txti 12111/2009 6:15:58 PMJ 3505.044 Page 57 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005445 EFTA00157894 12 through a lot. Why does anybody take up using drugs 13 or -- 14 Q. What boyfriend are you referring to, 15 saying at your boyfriend? 16 A. 17 Q. Now, why do you say you lost because 18 of Mr. Epstein? 19 A. Because he found out finally we got into an 20 argument and I just told him everything that had 21 happened and -- 22 Q. And when did.Hdo that? 23 A. After I had my 24 25 Q. While you were in A. No, while we were III. I had inMn 0284 1 Florida. 2 Q. And that's the first time you told 3 everything? 4 A. Yeah. 5 Q. And what was his reaction? 6 A. Obviously it wasn't good if I am not with him. 7 Q. Well, did he, on that particular occasion 8 leave and say he didn't want anything to do with you? A. No. We argued for a while. We tried to make it work and it iust wouldn't work. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0285 2 3 4 5 6 7 8 9 Q. When you talk about being disgusted -- 10 A. Why don't you get naked in front of an old man 11 and play with his nipples while he masturbates. You do 12 that and then you tell me if you feel good. 13 Q. And as you mentioned earlier, you did that Q. Anythin else that caused you to use crack in January of M? A. I was depressed about my whole life. And I felt disgusted by Mr. Epstein. file:///q/Documents%20and%20Scuingseroduction/Dcskiop %2=20-%20Vol.%2011.txti 12/11 /2069 6:15:58 PM] 3505.044 Page 58 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005446 EFTA00157895 14 to get money? 15 A. So? It still doesn't make it right. 16 17 18 19 20 21 22 23 24 25 0286 2 3 4 5 6 7 8 9 I0 1 12 13 14 15 16 17 18 19 20 21 22 23 Q. When did you first use Ecstasy? A. I think when I was 14. Q. Before you met Mr. Epstein? 24 A. No, during, meeting Mr. Epstein. 25 Q. What? 0287 A. After I had met Mr. Epstein. 2 Q. Well, you didn't meet him until you were 3 15. 4 A. I don't think that's right. I met him when I 5 was 14. I think I saw him for longer than just that 6 year. 7 Q. Well, according to your complaint the 8 first time you meet him was when you were 15? 9 10 A. I do ' -- don't know. MR. : That may be an error. 11 THE WITNESS: Yeah, I think that's an 12 error. 13 BY MR. LUTTIER: 14 Q. When did you -- what were the 15 circumstances surrounding, surrounding you first file:///q/Docurnents%20and%20Salings/Production/DeskiopME.g 2=0-%20Vol.%2011.txt[12111/20D9 6:15:58 PMJ 3505.044 Page 59 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005447 EFTA00157896 16 using Ecstasy. 17 A. I was at a party. 18 Q. Where? 19 A. In West Palm Beach. Who was there, I don't 20 know. A bunch of people. 21 Q. And who provided the drug? 22 A. I don't know. 23 Q. Mr. Epstein certainly wasn't there, right? 24 A. No, Mr. Epstein was not there. 25 Q. Okay. Did somebody give you the drug or 0288 I did you purchase the drug? 2 A. Somebody gave it to me. Q. Had you ever used it before? A. No. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0289 2 3 4 5 6 7 8 10 12 13 14 15 16 17 file:///Cl/Documentstleand9420ScItingsRroduclion/Dcsktop %2 %20Vol.%2011.txtl12/11/20D9 6:15:58 PMJ 3505.044 Page 60 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005448 EFTA00157897 18 19 20 21 22 23 24 25 029 2 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0291 2 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 lilc:NCl/Documents%21.1and%20Sctfings/Production/Dc•kwp. 20Vol.% 2011.tztl I VI 1/2009 6:15:58 PMJ 3505-044 Page 61 o167 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005449 EFTA00157898 20 21 22 23 24 25 029 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0293 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 file:///q/Documents%21:1and%20Scuings/Production/Deskioal:1-%20Vol.%2011.txtl12111/20D9 6:15:58 PMJ 3505.044 Page 62 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 ■ EFTA_00005450 EFTA00157899 22 23 24 1129 25 4 5 6 7 8 9 I0 1 12 13 14 I5 16 17 18 19 20 21 22 23 24 25 0295 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 lilc://q/Documents%21:land%20ScuingsRroduclion/Dcsktop .%2MO-%20Vol.%2011.txti 12/112009 6:15:58 PMJ 3505.044 Page 63 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000545 I EFTA00157900 24 25 0296 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0297 1 CERTIFICATE OF OATH 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 6 nde -ioned auth rity, certify that 7 personally appeared before me 8 and was duly sworn on the 4th day of December, 2009. 9 10 11 Dated this I Ith day of December, 2009. 12 13 14 15 16 Cynthia Hopkins, RPR, FPR 17 Notary Public - State of Florida My Commission Expires: February 25, 2011 18 My Commission No.: DD 643788 19 20 21 22 file://fq/Documentstleand9420Scuings/Production/Deskion 2M%20Vol.%2011.txt[12/11/20D9 6:15:58 PM] 3505.044 Page 64 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005452 EFTA00157901 23 24 25 0298 CERTIFICATE 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 I, Cynthia Hopkins, Registered Professional Reporter, Florida Professional Reporter and Notary 6 Public in and for the State of Florida at large, do hereby certify that I was authorized to and did 7 report said deposition in stenotype; and that the foregoing pages are a true and correct transcription 8 of my shorthand notes of said deposition. 9 I further certify that said deposition was taken at the time and place hereinabove set forth 10 and that the taking of said deposition was commenced and completed as hereinabove set out. 11 I further certify that I am not attorney or 12 counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party 13 connected with the action, nor am I financially interested in the action. 14 The foregoing certification of this transcript 15 does not apply to any reproduction of the same by any means unless under the direct control and/or 16 direction of the certifying reporter. 17 Dated this I I th day of December, 2009. 18 19 20 21 Cynthia Hopkins, RPR, FPR 22 23 24 25 0299 1 DATE: December 11th. 2009 2 TO: do •ui 3 4 5 6 7 West Palm Beach, Florida IN RE: vs. Epstein CASE NO.: 08-CIV-80119-MARRA/JOHNSON Please take notice that on Friday, the 4th of file://fq/Documents%21:1and%20ScitingsRroduction/Dcsktop .%20M-%20Vol.%2011.txtl12/11/2069 6:15:58 PM] 3505.044 Page 65 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005453 EFTA00157902 8 December, 2009, you gave your deposition in the above-referred matter. At that time, you did not 9 waive signature. It is now necessary that you sign your deposition. 10 As previously agreed to, the transcript will be furnished to you through your counsel. Please read 11 the following instructions carefully: At the end of the transcript you will find an 12 errata sheet. As you read your deposition, any changes or corrections that you wish to make should 13 be noted on the errata sheet, citing page and line number of said change. DO NOT write on the 14 transcript itself. Once you have read the transcript and noted any changes, be sure to sign 15 and date the errata sheet and return these pages to me. 16 If you do not read and sign the deposition within a reasonable time, the original, which has 17 already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you with 18 to waive your signature, sign your name in the blank at the bottom of this letter and return it to us. 19 Very truly yours, 20 21 Cynthia Hopkins, RPR, FPR 22 23 I do hereby waive my signature. 24 25 0300 1 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 1 hereby certify that I have read the foregoing 6 deposition by me given, and that the statements 7 contained herein are true and correct to the best of 8 my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. 9 10 11 12 13 14 15 16 17 18 19 20 21 Dated this day of 2009. file:///CVDocuments%21:1and%20Scuings/Production/Deskiona0-%20Vol.%2011.txti 121112(X19 6:15:58 PNI1 3505.044 Page 66 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005454 EFTA00157903 22 23 24 25 0301 ERRATA SHEET 2 IN RE: --=VS. EPSTEIN CR: Cynthia Hopkins 3 DEPOSITION OF: M. TAKEN: December 4th, 2009 4 5 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGE # LINE # CHANGE REASON 6 7 8 9 10 11 12 13 14 15 16 17 Please forward the original signed errata sheet to this office so that copies may be distributed to all 18 parties. 19 Under penalty of perjury, I declare that I have read my deposition and that it is true and correct 20 subject to any changes in form or substance entered here. 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 25 file://fq/Documents%2Dand%20Scuings/Production/Deskiop/M.q. al-%20Vol.%2011.txt[12/11/2069 6:15:58 PMJ 3505.044 Page 67 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005455 EFTA00157904