EFTA00158017.pdf
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE No.08-CIV-80119-MARRA/JOHNSON
•
Plaintiff,
-vs-
JEFFREY EPSTEIN,
Defendant.
Related cases:
08-80232, 08-08380, 08-80381, 08-80994,
08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092,
VIDEOTAPED DEPOSITION OF
Friday, November 6, 2009
9:16 a.m. - 12:43 p.m.
Reported By:
Sandra W. Townsend, FPR
Notary Public, State of Florida
PROSE COURT REPORTING AGENCY
West Palm Beach Office
Electronically signed 1,1
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PROSE COURT REPORTING AGENCY, INC.
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3506-001
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APPEARANCES:
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On behalf of the Plaintiff:
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On behalf of the Defendant:
MARK LUTTIER, ESQUIRE
RTIRMAN. CRTTTON. LUTTIRR & COLEMAN
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-471743728-efS4d28436cf
3506-001
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EXHIBITS
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PROSE COURT REPORTING AGENCY, INC.
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Electronically signed by Sandra Townsend (401
98.21e8e8-101b-4717-0720-ef54d20436cf
3506-001
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PROCEEDINGS
Deposition taken before Sandra W. Townsend, Court
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Reporter and Notary Public in and for the State of
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Florida at Large, in the above cause.
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VIDEOGRAPHER: This is the 6th day of
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November, 2009. The time is 9:16 a.m.
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This is the videotaped deposition of
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in the matter of
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versus Epstein.
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This deposition is being held at
13
, West Palm Beach, Florida.
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My name is Sasha Quinby. I'm the videographer
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representing Visual Evidence, Inc.
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Will the attorneys please announce their
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appearances for the record.
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MR. LUTTIER: Mark Luttier, on behalf of
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Jeffrey Epstein.
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MR.
on behalf of
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THEREUPON,
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having been first duly sworn or affirmed, was examined
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and testified as follows:
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-471743728-ef54d28436cf
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BY MR.
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THE WITNESS: Yes, ma'am.
DIRECT EXAMINATION
LUTTIER:
4
Q.
Please state your full name.
5
A.
III
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Q.
And, Ms.
where do you presently
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live?
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0728-ef54d28436cf
3506-001
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-072S-ef54d28436cf
3506-001
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EFTA00158022
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
Seeletie8-101b-47f7-b728-ef54d28436d
3506-001
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-471743720-ef54d20436cf
3506-001
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EFTA00158024
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0720-ef54d20436cf
3506-001
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EFTA00158025
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-471743728-ef54d28436cf
3506-001
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EFTA00158026
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-4717-0728.154d28436cf
3506-001
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EFTA00158027
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-47(743728-ef54d28436cf
3506-001
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08.21e8e8-101b-471743720-ef54d28436cf
3506-001
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EFTA00158029
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-471743728-ef54d28436cf
3506-001
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EFTA00158030
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-471743728-ef54d20436cf
3506-001
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EFIA_00006138
EFTA00158031
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-47f7-6728-ef54d28436cf
3506-001
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EFTA00158032
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-471743720-ef54d20436cf
3506-001
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EFIA_00006140
EFTA00158033
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-47f7-6728-ef54d20436cf
3506-001
Page 18 of 187
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EFIA_00006141
EFTA00158034
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0728-ef54d20436cf
3506-001
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EFTA00158035
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
90e1ette8-101b-4717-0720-ef54d28436cf
3506-001
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EFTA00158036
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-47(743728-ef54d28436cf
3506-001
Page 21 of 187
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EFTA00158037
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0720-ef54d20436cf
3506-001
Page 22 of 187
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EFTA00158038
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-471743728-efS4d28436cf
3506-001
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EFTA00158039
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-471743728-ef54d28436cf
3506-001
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EFTA00158040
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0728-ef54d28436cf
3506-001
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EFTA00158041
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-471743728-ef54d28436cf
3506-001
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EFIA_00006149
EFTA00158042
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-471743728-ef54d20436cf
3506-001
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EFTA00158043
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-471743728-ef54d20436cf
3506-001
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0720-ef54d28436cf
3506-001
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EFTA00158045
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-47f7-6728-ef54d20436cf
3506-001
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EFTA00158046
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98.21e8e8-101b-4717-0720-ef54d20436cf
3506-001
Page 31 of 187
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EFIA_00006154
EFTA00158047
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-471743720-ef54d20436cf
3506-001
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EFIA_00006155
EFTA00158048
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-47(743728-ef54d20436cf
3506-001
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EFTA00158049
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-471743728-efS4d28436cf
3506-001
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EFTA00158050
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1ette8-101b-4717-0720-ef54d20436cf
3506-001
Page 35 of 187
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EFIA_00006158
EFTA00158051
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98.21e8e8-101b-4717-0720-ef54d20436cf
3506-001
Page 36 of 187
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFIA_00006159
EFTA00158052
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0720-ef54d20436cf
3506-001
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Q.
Did there ever come a time that you learned of
any conduct that your daughter was engaged in that you
didn't approve?
A.
Yeah.
Q.
And when was that?
A.
Probably that's when we moved to the trailer
and
was about 14.
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
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Q.
Page 39
This is when you earlier said you moved to
West Palm Beach?
A.
Yeah.
14?
Q.
So -- and you think that's when she was about
A.
Yes, sir.
Q.
And what kind of problems arose then?
A.
Well, she met some other people in the
neighborhood.
Q.
She met some other people what?
A.
In that neighborhood.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
PROSE COURT REPORTING AGENCY, INC.
98e1e8e8-101b-471743728-ef54d28436cf
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1
Q.
And who did she meet? Do you know who it was?
2
A.
Yeah.
and some of his friends.
3
Q.
Do you know what year this was?
4
A.
No. I couldn't tell you the year.
5
Q.
Okay. And do you know this
6
A.
Yes, I do.
7
Q.
When did you first make his acquaintance?
8
A.
When we first moved to that place.
9
Q.
And how did you make his acquaintance?
10
A.
I guess
told me she was dating him.
11
Q.
Well, you moved there. Obviously there was
12
day one when you moved there?
13
A.
Oh, right.
14
Q.
Was she already dating him?
15
A.
Oh, no. No. No. No. She didn't know
16
anybody.
17
Q.
Okay.
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A.
No, she didn't know anybody. But then she had
19
met
and she met some of
friends. So then
20
she was palling out with
and some of his friends.
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0720-ef54d28436cf
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-47f7-6728-ef54d28436cf
3506-001
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EFTA00158057
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0728-ef54d20436cf
3506-001
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EFTA00158058
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0720-ef54d28436cf
3506-001
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EFTA00158059
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0720-ef54d28436cf
3506-001
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EFTA00158060
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0720-ef54d28436cf
3506-001
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EFTA00158061
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-471743728-ef54d28436cf
3506-001
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Q.
Did there come a time when she quit going to
16
school entirely?
17
A.
Yeah.
18
Q.
When was that?
19
A.
I remember trying to get her into
20
and the school at-would
not accept her
21
because they told me she was too -- too mature for her
22
age.
23
Q.
What do you mean by that?
24
A.
Oh, that it would distract the boys. I
25
clearly remember that.
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-47(7-0720-ef54d28436cf
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Page 48
1
Q.
What did they -- did you ask them what they
2
meant by that?
3
A.
Yeah. They said that she was -- I can't
4
pronounce the word, but she was very well built for her
5
age.
6
Q.
Was she older than the students that -- in
7
whose class she would be put?
8
A.
You know what? I don't believe so. I think
9
they just said that she was too -- what's that word, you
10
know? -- like, too -- she was -- her body was too
11
mature.
12
Q.
Do you have any record where somebody at
13
public school system said that your child couldn't be
14
enrolled because her body was too mature?
15
A.
Yeah. And that's when I tried to enroll
16
her -- that's when I just took her out.
17
Q.
What do you mean, you took her out?
18
A.
Yeah. They told us to go -- because she had
19
to be. Maybe that's when she went to
then, because
20
I remember going to try to help her get her GED from
21
another school on Military. I just don't recall the
22
order of protection, you know, the order of
23
Q.
I want to go back. She was at
. So --
24
A.
But --
25
Q.
-- did there come a time that she quit going
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-6728-4454d28436d
3506-001
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to
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A.
Yes.
3
Q.
And why was that?
4
A.
She got annoyed.
5
Q.
What do you mean, "she got annoyed?"
6
A.
She got annoyed and she told me that she had
7
found a job.
8
Q.
Well, I don't know -- I'm not understanding
9
what you mean when you said, "she got annoyed."
10
A.
She got annoyed with the people that were
11
there. And at that time that's when
came into
12
play. And then she told me -- she was working with me
13
for a little while in
And then she
14
said she found a job in Palm Beach.
15
Q.
Well, at this point she's -- what? -- 14
16
years old? 15?
17
A.
Maybe 14, going on 15.
18
Q.
So your daughter says she's annoyed with
19
school. What's your reaction to that? What was your
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reaction?
21
A.
I -- what was my reaction? I wasn't very
22
happy. But for some reason, I know she initially didn't
23
come out of school until she was 16, however it worked
24
out. But I know she was still, I believe, involved in
25
. And in the beginning she went to work with me a
PROSE COURT REPORTING AGENCY, INC.
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PROSE COURT REPORTING AGENCY, INC.
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Page
1
2
3
4
5
6
7
8
9
10
Q.
Okay. Back to
. You moved into
11
How long was it after you moved to this
12
trailer on
before you met this fellow?
13
A.
Before I met him personally?
14
Q.
Yeah.
15
A.
Probably -- because I worked
I used to
16
clean houses a lot in
for the elders.
17
don't know. Maybe two, three months.
18
Q.
And you came to know him because your -- did
19
your daughter introduce you to him or --
20
A.
Yeah, he came over with some of his friends
21
and, yeah, my daughter introduced me to him. Seemed
22
like a nice, respectable boy at the time.
23
Q.
And how old was he in relation to your
24
daughter?
25
A.
Honestly, I don't know. I don't -- at that
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2
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Page
time I don't know.
Q.
And, so, you thought he was a fine guy?
A.
Yeah. He dressed very nice. His family lived
4
5
diagonally across. Nice aunt. Nice
he came from a
nice house.
6
7
Q.
So you had no problem with your daughter
hanging out with him?
8
A.
No, I didn't, you know.
9
10
Q.
Did there ever come a time that you learned
anything else about Mr.
?
11
A.
Yeah.
12
Q.
When was that?
13
A.
Probably a little bit after that.
14
15
Q.
Meaning, a little bit after the couple months
after --
16
A.
Yeah. After I met him.
17
Q.
So give me an approximation. When you say, "a
18
little bit after," are we talking about a month later?
19
A.
Maybe a month, two months.
20
Q.
So this would be about three months --
21
A.
Three months maybe.
22
Q.
-- after you moved over to
23
A.
Uh-huh.
24
Q.
Okay. Well, what did you learn?
25
A.
Well,
was hanging out with these
Electronically signed by Sandra Townsend (401
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15
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17
18
19
20
21
22
23
24
25
people and --
Q.
A.
and a boy.
Q.
And who do you mean by, "these people?"
and his friends. There was another girl
What are their names?
A.
I don't remember. I remember the girl working
I want to say I know it, but I know she
attended
School with
because
wa
attending
School. I don't remember her name.
Q.
What do you mean by '
School?"
Q•
Well, what is it you learned about him at that
time?
A.
I just told
, like, kind of beware, you
know. It seemed to me like he was a player-type guy.
Q.
What do you mean by "player?"
A.
You know, he dressed nice, appeared nice,
but -- how would I describe a player? Like, he kind of
knows, like, he knew everything and he was, like, you
know, he was the thing.
Q•
Well, what gave you concern about that?
A.
What gave me the concern about that? Because
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1
a couple of times
didn't get home on time and I,
2
you know, I questioned where she was, what she was
3
doing.
4
And then it wasn't long after that
5
told me that
and this other girl that they were
6
hanging out with helped her get a job. And that was
7
down in -- down in Palm Beach over a bridge.
8
MR. LUTTIER: Okay. I'll take a break now.
9
Go to the restroom.
10
VIDEOGRAPHER: Going off the record at 10:33
11
a.m.
12
(Brief recess.)
13
VIDEOGRAPHER: We're back on the record at
14
10:40 a.m.
15
BY MR. LUTTIER:
16
Q.
Okay. We were talking before the break about
17
this fellow
. And you said there were a
18
couple times when your daughter didn't come home on time
19
and apparently was out with him?
20
A.
Yes, sir.
21
Q.
Did there ever come a time that you learned
22
his age?
23
A.
No. I don't think I -- I didn't know it at
24
that time.
25
Q.
Did you ever ask her if it was --
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8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A.
Yeah.
Q.
-- somebody her age?
A.
But I think I was told he was, like, 7
maybe 16 or 17.
Q.
And your daughter would have been 14?
A.
Fifteen. She was, like, I believe she was,
like, 14, going on 15.
Q.
And did you come -- come a time that you
learned that wasn't true?
A.
Oh, many years later.
Q.
But she told you he was approximately the same
age she was?
A.
Yeah.
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PROSE COURT REPORTING AGENCY, INC.
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PROSE COURT REPORTING AGENCY, INC.
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PROSE COURT REPORTING AGENCY, INC.
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1
2
3
4
5
6
7
Q.
All right. For example, she told you this
8
fellow,
, was an age that he wasn't?
9
A.
Correct.
10
Q.
And she obviously knew how old he was, right?
11
MR.
: Object to the form.
12
THE WITNESS: I don't know that to be true.
13
BY MR. LUTTIER:
14
Q.
And she knew that you would disapprove with
15
her hanging around with him if he was much older than
16
her?
17
A.
Oh, absolutely she'd know that.
18
Q.
Because you told her that, right?
19
A.
She knows that.
20
Q.
And when you said that he was a player, what
21
exactly did you tell her about somebody that was a
22
player? What did you caution her about, if anything?
23
A.
A smooth talker.
24
Q.
I mean, right down graphically what did you
25
tell her about that, if anything else?
PROSE COURT REPORTING AGENCY, INC.
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1
A.
I just told her to watch her step.
2
Q.
Meaning, what?
3
A.
He's a nice dresser. He's a smooth talker.
4
He likes to talk to this woman, talk to that girl, talk
5
to this girl, that girl, whatever. And I just consider
6
a person like that just to be a smooth talker.
7
Q.
Did you tell your daughter anything other than
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
he was a smooth talker?
A.
No.
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1
2
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4
5
6
7
8
9
10
11
12
13
Q.
Well, did there come a time that you were
14
suspicious that she was sexually active?
15
A.
Was there a time?
16
Yeah, there was.
17
Q.
And when was that?
18
A.
That was after my concrete evidence of
19
being sexually active was after
, we moved to
20
. And some people were calling me on my cell
21
phone to talk to
and she got gifts in the mail,
22
negligees and a massage book. I clearly remember that.
23
Q.
Did you ask her about those?
24
A.
Yes, I did.
25
Q.
What did she say?
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A.
She told me that the man she was -- the
2
household, the man in the household that she was working
3
for in Palm Beach, she was doing ironing and cleaning,
4
is what I understood. But this man offered to send her
5
to school.
6
Q.
And, so, is that all? You accepted that as a
7
response to your question?
8
A.
Yeah. I can say I did at that point.
9
Q.
So getting gifts of lingerie fit into that
10
description to you, that she was cleaning his house and
11
he was going to send her to massage school and that's
12
why she got gifts --
13
A.
It wasn't -- how can I explain? It wasn't
14
lingerie that came -- it came from, like, I understood
15
it was a wife that, you know, she goes to New York to
16
these -- she was a model or something and she went to
17
these nice places. And it wasn't like a -- like a
18
frilly negligee that I would consider something to be
19
sexual. It was just, like, you know. But, I mean, then
20
I thought it was nice that the wife thought of her like
21
that.
22
Q.
Did your daughter tell you that she got these
23
gifts from some person's wife?
24
A.
Yeah, she did.
25
Q.
And you saw these gifts, correct?
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A.
Absolutely.
2
Q.
Did you open the packages when they came?
3
A.
No.
4
Q.
How is it you saw them?
5
A.
It just so happened that one day I had been
6
there. The package came. And then I saw the book and
7
she said that this was -- came from the family she was
8
working for in Palm Beach, because they were going to
9
send her to school because she had discussed that she
10
wanted to be a massage therapist, because supposedly
11
that's what the wife did or something.
12
And
said, Mom, there's good money in
13
this and they're willing to help me with school. And,
14
Lord knows, I couldn't afford it because I was
15
supporting three kids on my own.
16
And I said,
, well, that's nice. And
17
honestly I didn't think anything of it because I house
18
clean and I've had my clients pull together to buy me a
19
car, you know, for compensation of helping them out and
20
things like that. So -- or they had allowed me to take
21
a small loan from them and pay them back a little bit
22
every week.
23
So I just -- I didn't really think anything
24
further into the picture because I knew that
had
25
this job in Palm Beach. She was making money. She was
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coming home. She was coming home. She was fine. Her
2
attitude was fine. She was happy. And I didn't really
3
think much of it.
4
Q.
Now, you began this area of discussion when I
5
asked you when was the first time you became suspicious
6
that your daughter had been sexually active. And this
7
is the event that you have described to us.
8
So what is it about this event that caused you
9
to wonder whether or not your daughter was sexually
10
active?
11
A.
The way she started carrying herself.
12
Q.
Was this before or after this event? You're
13
talking about an event where you -- she got gifts?
14
A.
It was after this event.
15
Q.
What do you mean by "carrying herself?"
16
A.
I could kind of see her demeanor change where
17
she was now wearing low-cut blouses and tight pants.
18
And she was very -- very prevalent about she always had
19
to have make up on when she went to work and, you know,
20
that was, again, it just -- I don't know. Something
21
didn't seem right.
22
And then I questioned her.
23
And she said, no, Mom. I'm just cleaning
24
house, that where she cleans, I understood there was
25
several people that worked there, that there was, like,
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a crew, they had a cleaning crew, a cooking crew, and...
2
Q.
Okay. Well, did there ever come another point
3
in time that you -- strike that.
4
Is there anything else about this conversation
5
that you had with her when she got these gifts that made
6
you think that she was perhaps sexually active, other
7
than the fact the way she carried herself?
8
A.
No.
9
Q.
Did there
was there ever another time that
10
you questioned whether or not she was sexually active?
11
A.
Yes.
12
Q.
When was that?
13
A.
I -- I guess the people, something happened
14
with the transportation because they would come and get
15
or
would take her to her job because they
16
were kind of dating at that point, so I didn't think
17
anything of it.
would take her to her job or the
18
people would send a car for
19
And, like I said, I didn't think anything of
20
it because I've had clients come and pick me, you know,
21
people that I worked for come and pick me up.
22
And then one day -- I don't know -- something
23
happened, but it was --
had to get to her job
24
and had to get to her job and I drove her there.
25
Q.
And when was this?
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A.
The exact date, I don't remember. I -- T
2
don't remember the exact date.
3
Q.
Do you know what year it was?
4
A.
No. No.
-- it all evolves in the
5
time between maybe 15. Maybe 15.
6
Q.
Do you have any record of when this event
7
would have occurred --
8
A.
Do I have any record?
9
Q.
-- when you drove her to this place?
10
A.
No. I can't say I wrote it down.
11
Q.
Well, did you create any record at any time
12
about it to pinpoint when it happened?
13
A.
No. I remember it was a nice day. Time of
14
year, I can't remember.
15
Q.
Did she ask you to take her there?
16
A.
Yeah. She said if I take her there, her
17
employer would pay me for my travel, you know, to bring
18
her there, because I was very frugal about the way I
19
spent my money because I was supporting three children
20
by myself.
21
And I said,
, I don't have, you know, _
22
have to get through the week. And I remember not having
23
enough gas money to get there.
24
And I said,
, I have gas, but what's in
25
my tank has to stay there.
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So I dropped -- I went down there with
2
. I didn't pull in a driveway. I remember it
3
being on the street.
4
And then
went in a driveway.
5
And then she said, Mom, I'll be right out.
6
They're going to give you money for gas so you don't
7
have to worry.
8
And I said, okay.
9
So -- and then she was taking, like, a minute,
10
so I started to proceed to walk in the driveway.
11
And then
walked out and introduced me
12
to her employer. And I shook her employer's hand and
13
that was Jeffrey. And I shook his hand. He seemed like
14
a very nice person. He said that my daughter, you know,
15
was doing a wonderful job. And, you know, he asked
16
several -- you know, it was a huge house. I never was
17
inside, but there was, like, quarters in the back of it.
18
And I'm telling you there had be 20 beautiful cars that
19
were parked.
20
And I just said, well,
, this is a good
21
deal, you know, you make good money in Palm Beach. I
22
would have liked to have had a cleaning job in Palm
23
Beach.
24
And I had asked, you know, -- and I said,
25
, you know, if they need help, let me know.
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And she said, no.
2
And I left
there.
3
And the man -- Jeffrey said, you know,
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Mr. Epstein said, don't worry, we'll get your daughter
home. You know,
-- I think her name was
she talks with a, I guess, a British accent -- came out
and assured me that she would get my daughter home.
So I said, okay. Thank you. And I went about
my business.
Q.
Did anybody give you money on that occasion?
A.
Yeah. Yeah.
Q.
How much money did you get?
A.
I think $50, because I was totally amazed.
But then I thought about it, well, these people are in
Palm Beach, they have money.
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2
3
4
5
6
7
8
Q.
Who gave you the $50?
9
A.
Mr. Epstein.
10
Q.
Did you ever ask Mr. Epstein what your
11
daughter was doing?
12
A.
Yeah. He told me she was ironing. She was
13
doing ironing work and the laundry. She was in part of
14
the laundry.
15
Q.
Did you ever wonder about your -- how old did
16
you say your daughter was at this time?
17
A.
She, I think, was about 16.
18
Q.
Did you ever wonder about your daughter
19
working at age 16 doing this?
20
A.
No. No. Because back in New York I worked
21
I lied and worked at Burger King at 15, so I didn't
22
think anything of it. My daughter is 16 working. And
23
before that when I was in high school, I used to work
24
and clean houses for the elderly people because I had
25
such good grades.
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Q.
Did your -- did your daughter -- did you take
2
your daughter to this location on any other occasion?
3
A.
Maybe two other times. And it was only she
4
was running in to get her pay.
5
Q.
And how much was her pay?
6
A.
$300.
7
Q.
And that was supposed to be for how long?
8
A.
Honestly, I don't know. I don't know.
9
Q.
Did you know how much she was getting?
10
A.
No.
11
Q.
Did you ask her?
12
A.
Yeah.
13
Q.
And what did she tell you?
14
A.
Well, a couple of times she told me she was
15
getting a hundred dollars. And then she told me on
16
several -- well, I guess, at one point Mr. Epstein, I
17
guess, some of his help was going somewhere and asked
18
if she could bring anybody to work. And as a
19
matter of fact, I was very big in church back then and :
20
21
22
23
24
25
had asked one of the church sisters if she needed to
make money to go, you know, that this Mr. Epstein was
looking for other help. Because I was too busy, you
know, so I gave it to somebody else.
Q.
So did the nun go?
A.
She wasn't a nun.
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Q.
Or a sister, you referred to it?
2
A.
I call her my sister. Yes, she did.
3
Q.
And what was her name?
4
A.
5
Q.
what?
6
A.
Do you want the truth? I don't remember her
7
last name.
8
Q.
So
went over there --
9
MR.
: Yes, he wants the truth.
10
THE WITNESS: I don't remember her last name.
11
BY MR. LUTTIER:
12
Q.
So
went over there and did some -- what_
13
was it? -- ironing?
14
A.
went over there with her -- with her
15
her niece.
16
Q.
And did they ever contact you after that and
17
tell you what they did?
18
A.
Well,
said she left, but she left her
19
niece there, because I think
drove her niece there
20
was the whole thing. But I wasn't close with her niece
21
to have, like, a -- I didn't have her phone number, she
22
didn't have mine and everything was through
You
23
know, and I said to
, you can go ahead and go
24
there.
25
And
-- I got the directions because
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that British lady called. I know he was looking for
help and
couldn't go one day and that's why I
think I called Sister
in a hurry and said, do you
4
want to make some money, that this guy had people coming
5
in and they needed extra help.
6
And then
called me and told me that she
7
left there but she left her niece there.
8
Q.
Now, when you say, Sister
that's not
9
really your sister?
10
A.
No. No. No. No. No. It's church term.
11
Q.
What church is it that you --
12
A.
13
Q.
Okay. And did
ever contact you after
14
15
that and tell you anything about the work that her niece
did?
16
A.
Did she? No. She just said --
just,
17
said that her niece said it wasn't -- you know, it
18
wasn't for her. And
said she left her there and,
19
you know, that was it, that it just wasn't for her. Sc
20
that's what I understood.
21
Q.
So did you ever ask your daughter how she
22
why she was getting paid $300?
23
A.
Did I ever ask her? No.
24
Q.
How much were you making cleaning places at
25
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1
A.
How much was I making back then?
2
Q.
Yeah.
3
A.
Oh, I got 40 to $50 a condo. I could do
4
three, four condos in a day, five condos. I'd make $300
5
in a day.
6
Q.
It's work all day though?
7
A.
250 -- yeah.
8
Q.
And your daughter wasn't working all day at
9
this place, was she?
10
A.
I have no idea because I was busy working.
11
Q.
Well, you took her and dropped her off and --
12
A.
That's all I did.
13
Q.
-- you don't know when she got home?
14
A.
No, I don't.
15
Q.
Did you ask her anything more about it?
16
A.
No. Honestly, I didn't.
17
Q.
Did you have any other contact with
18
Mr. Epstein, other than the time that you were there and
19
you claim he said she was ironing?
20
A.
Only on the phone.
21
Q.
And what contact did you have with him on the
22
phone?
23
A.
They would call and make an appointment.
24
Q.
Who is the "they?"
25
A.
Some -- it begins with an M -- Maxine or
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somebody.
2
Q.
Is this with Mr. Epstein?
3
A.
Yes, Max -- Maxine. Could that be her
4
Q.
Well, Mr. Epstein is Jeffrey Epstein?
5
A.
I know, but he had secretaries.
6
Q.
No. My question is: Did you ever have any
7
other direct contact with Jeffrey Epstein?
8
A.
Oh, Jeffrey Epstein called my phone and said
9
he --
10
Q.
Did you talk to him?
11
A.
Yes, I did.
12
Q.
Okay. When was that?
13
A.
I don't know exactly when it was, but he just
14
called to leave a message for
and tell her that
15
he would appreciate it if she could come in at like 3:00
16
at one day. And then another day that he was having
17
company coming over and if she could make it, you know,
18
at a different time. And it just like an appointment
19
thing.
20
Q.
Was this a direct phone conversation you had
21
with him where you exchanged words or is this just some
22
message left on a machine?
23
A.
Oh, no. No. We exchanged words.
24
Q.
And you said, sure, no problem?
25
A.
Yeah. Because
at that time didn't
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have a cell phone or anything.
2
Q.
And when did these conversations occur?
3
A.
Exactly, I don't know when. It was just after
4
I knew that she had the job with him and stuff.
5
Q.
Okay. So you were -- something about all this
6
made you suspicious that she was sexually active, is
7
8
where I think we started the question.
A.
It wasn't so much about that. But then I
9
started question her because she would leave, you know,
10
and occasionally I'd see her come home and I'd say,
11
, you have, like, a such a low-cut blouse on.
12
And you got such short, short shorts. Why -- I don't
13
understand.
14
Oh, Mom, I changed when I got in the house.
15
Q.
Anything else that made you suspicious?
16
A.
She did come home sometimes and I smelled
17
alcohol on her breath.
18
And I said, your employer lets you drink?
19
was concerned about that.
20
Q.
And what did she say?
21
A.
She said, yeah. She says, the people in the
22
kitchen are real nice and she was allowed to go -- I
23
guess there was a certain refrigerator or something that
24
sometimes she'd go sit in the kitchen. And the cooks
25
would cook for her, too.
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Q.
So what did you do? Did you pick up the phone
2
and call this person and say, I don't want my -- what
3
you said was a 15 year old daughter over there drinking?
4
A.
I tried to get in touch with him. I remember
5
that. But I couldn't get through.
6
Q.
Well, did you keep trying?
7
8
A.
Did I keep trying? Yeah.
Q.
Did you ever get in touch with him?
9
A.
No. It was like the man vanished.
10
Q.
Did you get in the car and drive over there?
11
A.
Nobody answered the door.
12
Q.
Did you get in your car and drive over there?
13
A.
Yes, I did and nobody answered the door.
14
Q.
What did you do? Tell me about this occasion
15
when you got in the car and drove over there. Who went
16
with you?
17
A.
Nobody. I went by myself.
18
Q.
And when was this?
19
A.
It had to be after
told me that her and
20
her niece weren't interested in working for him.
21
That's -- time of year, I don't really remember. But I
22
know it was daylight out. I don't remember the time.
23
Q.
So what did you do? You went to the house?
24
A.
Yeah, I tried to knock on the door but there
25
was so many doors I just didn't know where I was
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knocking.
2
Q.
What, did you knock on more than one door?
3
A.
Yeah.
4
Q.
Which door did you knock on?
5
A.
There's a garage that had a big, long thing
6
here. And then there's a front door. And there's
7
another house because
said something about this
8
house in the back.
9
Q.
So how many doors did you knock on?
10
A.
Three.
11
Q.
And -- and you're telling me --
12
A.
Nobody answered.
13
Q.
-- there was nobody there and nobody answered?
14
A.
No.
15
MR.
: Object to the form.
16
BY MR. LUTTIER:
17
Q.
So did you come across anybody on the grounds?
18
A.
No.
19
Q.
So what did you do next?
20
A.
I got in my car and left.
21
Q.
And for what purpose had you gone there on
22
that occasion?
23
A.
Just because I think I wanted to know why he
24
allowed her to drink.
25
Q.
Well, in fact, you were suspicious about what
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was going on by then, weren't you?
2
A.
Yeah, after
told me she didn't want to
3
work for her and
didn't have the heart to tell me,
4
I guess maybe she knew more of the story than I did at
5
that point.
6
Q.
Did you ask
anything else, why isn't it.
7
for your niece?
8
A.
Yeah, I did ask
9
Q.
And what did she say?
10
A.
And
just said her niece just said it
11
wasn't for her.
12
Q.
Did you inquire further?
13
A.
No.
14
Q.
Did you -- by now if you're suspicious, did
15
you ask your daughter more about what was going on?
16
A.
Yeah.
17
Q.
And you said your daughter was always truthful
18
with you, right?
19
A.
Yeah. So she said --
20
MR.
: Object to the form.
21
THE WITNESS: Yeah.
22
So she just said, no, Mom, we're working.
23
And I said, well, why -- your hours are
24
changing now. Like, I don't understand. You know,
25
you don't do a full day or whatever.
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And she said, no. She said, Mom, his company
2
flies in all the time.
3
And sometimes I know that he's in New York,
4
so -- and she still -- she still goes over there,
5
you know. Because a couple times I knew he was in
6
New York because he called from New York.
7
called from New York and said she still had to go
8
to the house.
9
BY MR. LUTTIER:
10
Q.
Who called from New York?
11
A.
I'm sorry?
12
Q.
Who called from New York?
?
13
A.
Yeah.
14
Q.
And did she talk to you?
15
A.
Yeah.
16
Q.
So you talked to
?
17
A.
I talked to
18
Q.
And when did this conversation happen?
19
A.
It was late in the afternoon. She said that
20
Jeffrey was coming in with some -- with some friends,
21
but
needed to be over there, I guess, like, twc
22
hours or three hours before Jeffrey came in with the
23
people to make sure everything was, I guess, in place.
24
Q.
And where was
? Do you know whether or
25
not
was, in fact, in Palm Beach calling you saying
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2
3
4
5
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7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 106
that Mr. Epstein was coming in and wanted your daughter
to come over?
A.
Honestly, I don't know.
Q.
Okay. And by the way, when you're having
these conversations with either the time that
Mr. Epstein called or when you say you talked to
did you ever ask them about -- more about what was going
on?
A.
No. They informed me that she was cleaning
and she was doing a good job. They were happy to have
her.
Q.
Well, you told me that Mr. Epstein said she
was ironing; is that right?
A.
She was ironing and she was in charge of,
like, the ironing and the laundry.
Q.
Did you ever have any other conversation with
Mr. Epstein where you asked him what was going on?
A.
No.
Q.
Did you have a conversation with
whe'
she called and asked her what was going on?
A.
No.
Q.
Did you ever directly confront your daughter
about what was going on?
A.
No.
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Q.
Now, by the time that she met
and you
17
claim that she was going over to Mr. Epstein's house,
18
had you discovered that your daughter was using drugs?
19
A.
I suspected it because I'll tell you what.
20
and this girl,
this girl,
21
and
, because
and
used to
22
drive over there a lot.
23
Q.
Over where?
24
A.
To Jeffrey Epstein's, because I know
25
I
worked for him and he was sending
MI
Lc
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Page 109
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school, too.
2
And then -- I don't know. Then I found out --
3
I guess then I found out she went to
or something,
4
somewhere weird. And we -- I never talked to her -- you
5
know, we never talked to her again. But
III
s
working for Jeffrey, too, cleaning. That's how
actually got the job, was through
Ililland
Q.
So what -- the question was about being
suspicious that she was using drugs.
A.
Because -- I'll tell you why. Because I
noticed a couple times that
-- when I'd see
in
III II and
, they had white powder on their
nose.
Q.
And you knew what that was, right?
A.
I'm sure it wasn't baby powder.
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2
3
4
5
6
Q.
When did you first suspect she was using
Xanax?
7
A.
I didn't know about Xanax.
8
Q.
When did you first suspect she was using
9
Xanax?
10
A.
I guess when her friends -- I guess when her
11
friends and Jeffrey Epstein turned her on and had her
12
doctor shopping.
13
Q.
Well, what do you mean by that? You said two
14
things.
15
A.
Oh, she came from Jeffrey Epstein's a few
16
times a little looped.
17
Q.
What was she looped on?
18
A.
I couldn't tell you because I wasn't there.
19
Q.
Well then, how do you know she came from
20
Jeffrey Epstein's looped?
21
A.
Because the last I knew she was working.
22
Q.
No. No. I want to know, you said she came
23
from Jeffrey Epstein's looped. Did you see her when she
24
came from Jeffrey Epstein's looped?
25
A.
Well, when I got to the house and she was
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looped and she told me she just got off of work, that's
2
where I assumed she'd been.
3
Q.
Oh, you assumed, --
4
A.
Yes.
5
Q.
-- but you didn't know?
6
So you didn't go pick her up from Jeffrey
7
Epstein's?
8
A.
No, sir.
9
Q.
Well, let's assume that -- that she told you
10
that she'd just gotten off work and you saw her and she
11
was looped. That would have then caused you even
12
greater concern about what was going on at
13
Mr. Epstein's, right?
14
A.
Yeah.
15
Q.
So did you pick up the phone or go over to
16
Mr. Epstein's at that point to find out why your
17
daughter was -- to use your words -- looped?
18
A.
Honestly, no, I didn't.
19
Q.
Okay. Because you weren't that concerned
20
about it?
21
A.
No, sir. That's not why.
22
Q.
Okay. Was she still hanging out with this
23
fellow,
, at the time?
24
A.
Yes, she was, and
25
Q.
And what did you do, if anything, about
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interceding with her at her age, which was -- what?
2
15, hanging out with this
III I and
and
3
, who you now have said as to
III land
4
, you observed them with white powder on their
5
nose?
6
A.
Sir, you know what? It's a very hard thing to
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
say because, you know what? I went to business. So
it's just like you if you have children. When you leave
your house, do you know what your kids do 24/7? No, I
don't.
When I leave to go to work, I don't know. My
daughter could say she's home and, sir, I don't know if
she's there or if she stepped out.
Q.
Okay. So you say the first time you were
aware or concerned about your daughter using Xanax was
on some occasion when she was with her friends?
A.
I didn't say my daughter -- I didn't -- I
didn't say I was concerned about my daughter using Xanax
at all. You said it, not me.
Q.
Well, the truth of the matter is, you did
believe your daughter was using Xanax, didn't you?
A.
No, I can't honestly say I did. I had
suspicion.
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We have to change tapes.
2
VIDEOGRAPHER: Going off the record at 11:28
3
a.m. This marks the end of tape one.
4
(Brief recess.)
5
VIDEOGRAPHER: We're back on the record at
6
11:30 a.m. This marks the beginning of tape two.
7
BY MR. LUTTIER:
8
Q.
Now, you say that there were several
9
occasions, I think you described two, where you say you,
10
personally, talked to Jeffrey Epstein on the phone. Do
11
you recall that?
12
A.
Yes, I talked to him personally on the phone.
13
Q.
Do you know how many times?
14
A.
No.
15
Q.
And were these occasions when he was at his
16
house in Palm Beach?
17
A.
You know, I know a couple of occasions he was
18
in New York getting ready to come back. And just that
19
told
when he was coming back to -- that he needs
20
her to work at the house.
21
Q.
When you say, he told
, I thought you
22
were having this conversation with him?
23
A.
No. Sometimes
would be there and I'd
24
give her the phone.
25
Q.
I want to know
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A.
But I know he called.
2
Q.
I want to know about now specifically the
3
conversations that you, personally, had with Mr. Epstein
4
on the other end of the phone. That's my question. How
5
many times did it occur that you, personally, had phone
6
conversations with Mr. Epstein?
7
A.
I would say, maybe three, four, because he
8
called a couple times to tell me there was some kind of
9
music tickets coming -- he was Fed-Exing her music
10
tickets.
11
Q.
On those occasions that you had direct phone
12
contact with Mr. Epstein, was he in his house in Palm
13
Beach?
14
A.
I don't know, sir.
15
Q.
Do you know where he was?
16
A.
No, sir.
17
Q.
Now, you said, and there were other phone
18
conversations where he called and all you did was give
19
the phone to
20
A.
Yes.
21
Q.
You didn't participate in those phone
22
conversations?
23
A.
No. If
was there, I handed her the
24
phone directly. But on occasion that they would tell me
25
just if I, you know, when I contacted her, let her know
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if she could work this day or time or whatever.
2
Q.
Do you -- did your daughter ever tell you what
3
the basis of her compensation was?
4
MR.
: Object to the form. Asked and
5
answered.
6
BY MR. LUTTIER:
7
Q.
Did she get paid hourly or by the day?
8
A.
No. I never discussed that with her.
9
Q.
All right. And did she ever tell you what the
10
total compensation she received was?
11
MR.
: Object to the form. Asked and
12
answered.
13
THE WITNESS: No.
14
BY MR. LUTTIER:
15
Q.
And by "total," I mean, you know, collectively
16
for a month or two months.
17
A.
No.
18
Q.
Now, this happened -- this was all occurring
19
during a period of time that you claim you thought she
20
was in school; is that right?
21
A.
Yes.
22
Q.
Didn't you know that she had already dropped
23
out of school by then?
24
A.
No.
25
Q.
And you -- were you home on all occasions when
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your daughter went to Mr. Epstein's?
2
A.
Absolutely not.
3
Q.
So you didn't really know where she was?
4
A.
Absolutely not.
5
Q.
So in the day, all you knew is, you left and
6
you had no idea if she was in school or at Mr. Epstein's
7
8
or at the beach or anyplace else?
A.
Correct.
9
Q.
And when you came home, all you knew is she
10
was either home or she wasn't home, right?
11
A.
That's correct.
12
Q.
Did you ever tell her that you didn't want her
13
hanging out with this guy,
14
A.
Yeah.
15
Q.
And what did you tell her specifically?
16
A.
I told her I just didn't want her to hang out
17
with him, that his aunt didn't want them to hang out
18
and...
19
Q.
Whose aunt?
20
A.
aunt.
21
Q.
aunt?
22
A.
Yeah.
23
Q.
And how did you know
aunt didn't want
24
them to hang out?
25
A.
Because we've had conversations.
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Q.
A.
Q.
A.
Page 121
Well, did she tell you something?
No.
That is, did
aunt tell you something?
No. It was just
that's when I found out
5
that
was a little older than
and --
6
Q.
When did you find that out?
7
A.
-- the people that -- I would say, maybe
8
was the end of 16, going on 17. And
9
think, was 21, 20.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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7
8
9
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11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q.
But on the other hand, you told me that
was taking her to Mr. Epstein's?
A.
Correct. But I wasn't aware of that. I was
at work.
Q.
So I thought you -- so the only way you know
that
was taking her to Epstein's is something
somebody told you at some point later in time?
A.
No, because in the very beginning when
met Mr. Epstein through
and this girl,
because Mr. Epstein needed additional help at his
estate.
Q.
Well, somebody told you that, right? Somebody
told you that Mr. Epstein needed additional help?
A.
Yeah, my daughter did. She says -- she was
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very excited that
M
I and
brought her to
2
this estate and she was going to have a job.
3
Q.
So this is the story that your daughter told
4
you?
5
A.
Absolutely.
6
Q.
So you had -- you and
aunt wanted
7
and your daughter not to see each other?
8
A.
Right. But I didn't know.
9
Q.
So you told her not to hang around with
10
A.
Right. Because he was much older than she
11
was.
12
Q.
So you never physically were present to see
13
pick her up and take her anywhere?
14
A.
I really can't say that because I know
15
sometimes he borrowed my car to take her.
16
Q.
Let's see now. You just told me that you
17
didn't want
and your daughter to hang out. You
18
told your daughter not to hang out with him?
19
A.
Yeah. But that was prior -- that was prior
20
to -- that was prior to us declaring that we didn't want
21
them to hang out.
22
Q.
What was prior to you declaring that you
23
didn't --
24
A.
That
had taken
to Jeff Epstein's
25
a couple of times in my car.
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q.
Did there come a time that your daughter told
you a different story about what was going on when she
went to Mr. Epstein's?
A.
No.
Q.
Right up until today?
A.
I'll be honest with you. The way I found out
is when an FBI agent knocked on my door.
Q.
Okay. And when did that happen?
A.
We were living at the trailer then, so it was
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somewhere
trailer
in the time that we were
Page 128
living at this
, a man and a woman
3
came to the house. And they told me I couldn't even
4
listen to the conversation, it had nothing to do with
5
me, it pertained to my daughter.
6
Q.
So who was present at this meeting?
7
A.
A woman, a man and my daughter. And they said
8
they were from the FBI.
9
Q.
And did you participate in this conversation?
10
A.
No, I didn't, sir. They wouldn't let me.
11
Q.
Well, they said you couldn't participate, but
12
were you --
13
A.
No, I wasn't. I was in the house.
14
Q.
How old was your daughter at the time?
15
A.
Oh, this just -- it happened while we were at
16
the trailer, so it was probably about -- maybe a year
17
and a half ago.
18
Q.
She was over 18 by then?
19
A.
Yeah, uh-huh, I think so.
20
Q.
And that's the first time that you suspected
21
22
that something different was going on than cleaning the
house?
23
A.
That's the first time I found out something
24
different was going on.
25
Q.
And how did you find it out, if you weren't
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present in that meeting?
2
A.
Because when they were done with my daughter,
3
I specifically asked these people. And they said they
4
had to talk to her about Jeffrey Epstein. So that's the
5
person she worked for, so I just assumed being the
6
brilliant person I am that, you know, something more is
7
going on.
8
Q.
Okay. But did these -- did these two people
9
that you've identified as FBI agents tell you anything
10
else was going on?
11
A.
No, I don't recall them.
12
Q.
Did your daughter ever tell you anything else
13
was going on?
14
A.
That's when my daughter spilled the beans.
15
And she told me she was going to Mr. Epstein's and she
16
was bringing girls there from
school and she'd get
17
paid a hundred dollars for every girl she brought there,
18
plus she would get $300. And that's when she told me
19
that what was going on, because she felt like it didn't
20
matter now because she hadn't been over there for, you
21
know, for a -- you know, a year or two years, whatever
22
it was, a year. So, I mean, it was like water under the
23
bridge. And that's when
told me.
24
And she goes, Mom, the negligees, and he took
25
pictures of me.
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And I said, well, what do you mean?
2
And
took pictures of her and this Maxine
3
or Max -- Max -- I don't know, but all's I know it was
4
Max something.
5
Q.
Maxine what? What was she saying about this
6
Maxine person?
7
A.
That -- that this Maxine person would take
8
pictures and
would -- she modeled for them.
9
And she said, Mom, that's why, you know, that
10
different lingerie -- it was just, like, you know, stuff
11
like that.
12
And I said, well, what's this massage book
13
about?
14
And that's when she told me.
15
Q.
Told you what?
16
A.
That's when
actually admitted to me
17
that
would put on these little outfits and
18
Jeffrey Epstein would ejaculate in front of her.
19
Q.
Is that what she told you?
20
A.
Uh-huh.
21
Q.
Now, is this all in this immediately following
22
the occasion that the --
23
A.
FBI came.
24
Q.
-- two people from the FBI? So it happened
25
right after that meeting on the same day?
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A.
That's -- well, pretty much so, yeah. That's
2
when I questioned
. And I said, could you please
3
tell me what's really going on? What kind of trouble
4
are you in?
5
And she said, Mom, I'm not in no trouble.
6
I said, well, what is this all about?
7
And that's when
told me. She says,
8
you know that place you took me to with Jeffrey Epstein
9
and you met him and his nice car? Well, that's Jeffrey
10
Epstein and he took pictures of me.
11
Q.
Did she tell you anything more about other
12
than just that he, quote, took pictures of me?
13
A.
No. He would do sex acts with some other
14
girl. I guess it was his wife.
15
Q.
Sex acts -- when she said pictures, did she
16
describe anything more about the pictures, what her
17
state of dress was, whether she was in lingerie?
18
A.
No. Just that she was in lingerie and
19
sometimes she wasn't. And he would go into a bath --
20
guess this room was a bathroom or something and Jeffrey
21
would just come out with a towel wrapped around him.
22
And then one time he asked her to sit on him
23
or -- I don't know -- sit on him or something. And
24
-- I don't know whether she did or didn't
25
because I was really getting disgusted and sick to my
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stomach.
2
Q.
Well, back to the pictures. You said
3
sometimes she said she was in lingerie and sometimes she
4
wasn't?
5
A.
Yeah.
6
Q.
Meaning, what was she in, if she wasn't in the
7
lingerie?
8
A.
I guess she was nude.
9
Q.
Did she tell you she was nude or she just said
10
she was in some other outfit?
11
A.
No. She just said that just sometimes she was
12
in lingerie and she wasn't.
13
Q.
Did she tell you she was nude?
14
A.
Honestly, I don't recall.
15
Q.
How about these other pictures that you claim
16
that either
or this Maxine -- did she claim that
17
or Maxine took pictures of her?
18
A.
Yeah.
19
Q.
And what did she say her state of dress was
20
for that?
21
A.
She was wearing a -- she said she was wearing,
22
like, lingerie-type clothing.
23
Q.
Is that for both the pictures that
took
24
and the pictures that allegedly --
25
A.
Honestly, I'm not sure.
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Q.
-- Maxine took?
2
Did she ever tell you that she was ever --
3
anybody took any picture of her when she was naked or is
4
that just the assumption you made?
5
A.
I don't recall her telling me that.
6
Q.
And then -- so have you now told me everything
7
she told you about anyone taking pictures of her?
8
A.
As -- yeah.
9
Q.
And then you said
did she say that she gave
10
massages to Mr. Epstein?
11
A.
Yeah. That's why he was sending her massage
12
books because --
13
Q.
Did she describe those massages at all to you?
14
A.
She told me she didn't want to discuss it with
15
me because it would hurt me.
16
Q.
So she didn't tell you about it?
17
A.
No. She just said that she was -- that she
18
would give Jeffrey massages.
19
Q.
Then you say she said that -- what did she
20
tell you about what Mr. Epstein --
21
A.
I asked her what she massaged.
22
Q.
Okay. And what did she say?
23
A.
She says, Mom, I don't want to get into it.
24
You know enough.
25
Q.
Did you ever push at any time after that to
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find out more?
2
A.
No.
3
Q.
Then you say Mr. Epstein would ejaculate?
4
A.
Yes.
5
Q.
What did she specifically say about that?
6
A.
He would jerk himself off --
7
Q.
Okay. Did she tell you --
8
A.
-- while
took pictures.
9
Q.
Of who?
10
A.
Honestly, I'm not sure.
11
Q.
Did she tell you anything else about the
12
massages?
13
A.
No. But she did tell me that occasionally
14
there was other men that were present. And whether it
15
was a one-on-one with that man and her or however it
16
worked, I don't know, but my daughter didn't tell me
17
specifics.
18
Q.
Did she say she was involved with other men?
19
A.
Jeffrey Epstein brought people there, I guess,
20
yeah.
21
Q.
But was she telling you -- what was she
22
telling you about the other men as it related to her?
23
A.
Oh, that the phone call, I guess, the phone
24
calls that I was getting for
to meet at the
25
house was because there was men, I guess, other men
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flying in from somewhere and they wanted -- I guess
2
Jeffrey Epstein set a date up for
and the other
3
man.
4
Q.
You keep saying, you guess. Do you not know?
5
A.
Well, sir, it's only what I heard. I don't
6
know for surely. I wasn't there.
7
Q.
It's not something you know. All right.
8
Did your daughter tell you on any occasion she
9
went and there was some male person there
10
A.
Yes, she did.
11
Q.
What did she tell you about that?
12
A.
She just told me that there was another --
13
another -- she had to meet one of Jeffrey Epstein's
14
friends.
15
Q.
When she said, meet, what was she telling you?
16
What do you mean, meet one of Jeffrey Epstein's friends?
17
A.
She just told me that she had to meet one of
18
Jeffrey Epstein's friends at the house.
19
Q.
What did she tell you happened when -- did she
20
tell you that she actually met this person?
21
A.
Yeah.
22
Q.
What did she tell you happened when she met
23
this person?
24
A.
Honestly, I don't remember because I was just
25
totally disgusted by the whole situation.
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Q.
Did she claim that she had performed a massage
2
on someone other than Mr. Epstein?
3
A.
Yes. In Mr. Epstein's presence, yes.
4
Q.
So she told you specifically that there was an
5
occasion that she went to Mr. Epstein's house and
6
performed a massage on some other man and Mr. Epstein
7
was present?
8
A.
Yes.
9
Q.
Did she tell you anything about that massage?
10
A.
No.
11
Q.
Did she tell you whether or not that happened
12
on any occasion more than this one occasion?
13
A.
Well, I know
also told me about
14
something about two girls and Mr. Epstein observed it.
15
Q.
What did she tell you about two girls?
16
A.
Well, actually I think Mr. Epstein, I guess
17
his wife -- I guess it was his wife is what she told me,
18
that he -- Mr. Epstein wanted
and his wife to
19
perform sexual acts on each other.
20
Q.
Did she say what acts?
21
A.
Honestly, I said, please don't go any further
22
because it's turning my stomach.
23
Q.
Did she tell you whether she, in fact, engaged
24
in any sexual act with this per --
25
A.
No.
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Q.
She didn't tell you or she said she didn't?
2
A.
No, I didn't say she didn't. I don't know
3
because my daughter knew I was not feeling easy with the
4
situation. And she already knew that I was diagnosed
5
being sick, and my daughter just didn't want to put any
6
more on my head.
7
Q.
Okay. Did she tell you anything else about
8
going over to Mr. Epstein's, other than what you've told
9
me thus far?
10
A.
No.
11
Q.
Did she tell you how much she was getting paid
12
for each of these visits?
13
A.
After -- when the FBI, I found out she was
14
getting $300 per session. And every time she brought a
15
friend there he would pay a hundred to $200 to her, just
16
like a finder's fee.
17
Q.
And you say the FBI told you that?
18
A.
No. I said
did.
19
Q.
Okay.
20
And she told you she was bringing people from
21
the
school?
22
A.
Yes.
23
Q.
Did she ever tell you who she brought?
24
A.
No.
25
Q.
Did she ever tell you anything more about
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this -- who was this person that you said that --
2
A.
3
Q.
Yeah,
• Did she tell you anything
4
more about this
MI
person?
5
A.
I met
IIIII quite -- a very, very nice
6
girl, very attractive. And I don't -- I don't know what
7
happened to
II because she was, like, there one
8
day and gone the next.
9
And then I guess
talked to somebody or
10
talked to somebody and they told me that Jeffrey
11
Epstein sent her somewhere to go to school to increase
12
her knowledge in, I guess, physical therapist then.
13
And then I heard she got married to
14
somebody -- I don't remember where they told me she got
15
married. And that's where she is, but...
16
Q.
Have you had any other contact with
17
Mr. Epstein, other than what you've described
18
A.
No, uh-uh.
19
Q.
-- in this deposition?
20
A.
No.
21
Q.
Now, your daughter told you these things,
22
whatever day it was the FBI came by, and you think that
23
was around a year ago?
24
MR.
: No. Object to the form.
25
MR. LUTTIER: Did I get that wrong?
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BY MR. LUTTIER:
2
Q.
Refresh my memory. About how long ago do you
3
think this meeting was with the FB --
4
A.
Oh, I don't know. All's I could tell you is
5
exactly it was the time we were living in this trailer.
6
Q.
The one you're in now or --
7
A.
Uh-huh.
8
Q.
All right. Was the statement recorded, do you
9
know?
10
A.
I couldn't tell you, sir.
11
Q.
Were they in a separate room from where you
12
were?
13
A.
Sir, they were sitting outside on my patio.
14
was in the house.
15
Q.
For the entire conference?
16
A.
Yes, sir.
17
Q.
And you say it was a man and a woman?
18
A.
Yes, sir.
19
Q.
Black? White?
20
A.
Sir, I don't remember.
21
Q.
To the best of your knowledge, were there any
22
other meetings with the FBI?
23
A.
Sir, I don't know.
24
Q.
Has your daughter discussed it? Other than
25
the discussion you had with her immediately following
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her meeting with the FBI, have you had any other
2
discussions with her
3
A.
No, sir.
4
Q.
-- about Jeffrey Epstein?
5
A.
No, sir.
6
Q.
Right up until today?
7
A.
No. Because she knows the way I feel about
8
it.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q.
Your daughter had a lot of issues involving
drugs and psychiatric care, did she not?
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MR.
: Object to the form.
2
THE WITNESS: Let me put it to you this way:
3
I wouldn't say anything out of the normal for a
4
child growing up, but it got progressively worse
5
after she met Mr. Epstein. Okay? Thank you very
6
much.
7
BY MR. LUTTIER:
8
Q.
Well, it also got progressively worse after
9
she fell in with this fellow,
and got pregnant by
10
him, didn't it?
11
A.
Well,
was the one that introduced her to
12
Mr. Epstein, sir.
13
Q.
And the drug use that she was using was when
14
she was away from Mr. Epstein's house, wasn't it?
15
A.
Sir, I couldn't testify to that because I
16
don't know.
17
Q.
So you don't know. You don't know whether or
18
not
was giving her the drugs or she was buying it
19
off the street, do you?
20
21
22
23
24
25
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3506-001
Page 163 of 187
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S
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Q.
By the way, did your daughter ever say that
12
Mr. Epstein ever hit her?
13
A.
No.
14
Q.
Ever say that he gave her drugs?
15
A.
Not directly, no.
16
Q.
Ever say that he physically hurt her?
17
A.
Physically hurt her? No.
18
Q.
Yes.
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-4717-0728-ef54d20436cf
3506-001
Pagc 164 of 187
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0728-ef54d20436cf
3506-001
Pagc 165 of 187
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0720-ef54d20436cf
3506-001
Pagc 166 of 187
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 91101151 and 17
EFTA_00006289
EFTA00158182
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-4717-0720-ef54d20436cf
3506-001
Pagc 167 of 187
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-4717-0728-ef54d20436cf
3506-001
Page 168 of 187
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
90e1e8e8-101b-4717-0720-ef54d20436cf
3506-001
Pagc 169 of 187
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
90e1e8e8-101b-4717-0720-ef54d28436cf
3506-001
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-4717-0720-ef54d20436cf
3506-001
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Q.
Was there ever anything that your daughter
asked that she be permitted to do with Mr. Epstein that
you forbad her to do?
A.
No.
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-471743728-ef54d20436cf
3506-001
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EFTA00158188
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0728-ef54d28436cf
3506-001
Pagc 173 of 187
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 9/ 10, 15, and 17
EFTA_00006296
EFTA00158189
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98.21e8e8-101b-4717-0720-ef54d20436cf
3506-001
Pagc 174 of 187
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17
EFTA_00006297
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Page 175
1
What you're describing as normal with your
2
kids is telling your kids, call me to let me know that
3
you're not dead and in a dumpster yet; is that right?
4
A.
No. Actually, I've said that to my daughter
5
because she disappears.
6
Q.
And that's been a consistent problem, correct?
7
A.
Not until recent.
8
Q.
What do you mean by recently?
9
A.
Not until after her escapades with Jeffrey
10
Epstein. That's when she really became out of control.
11
Q.
That's when she ran off with this
12
and went to
right?
13
A.
Yep.
14
15
16
17
Q.
Okay. But had a baby with him, right?
18
A.
Yes.
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-47(7-0720-ef54d20436cf
3506-001
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2
Q.
Mr. Epstein doesn't have anything to do with
3
any of that, does he?
4
MR.
: Object to the form.
5
BY MR. LUTTIER:
6
Q.
Wasn't around for any of that, was he, ma'am?
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A.
I don't know.
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98.21e8e8-101b-471743720-ef54d20436cf
3506-001
Page 176 of 187
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EFTA00158192
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98.21e8e8-101b-4717-0720-ef54d20436cf
3506-001
Page 177 of 187
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paw:, 178
MR. LUTTIER: Okay. Let me take a break and
might be done.
VIDEOGRAPHER: Going off the record at 12:29
p.m.
(Brief recess.)
VIDEOGRAPHER: We are back on the record at
12:39 p.m.
BY MR. LUTTIER:
Q.
Other than the occasions that you took your
daughter to the -- to the location in Palm Beach where
you said Mr. Epstein lived, have you ever taken your
daughter anybody place else to meet Mr. Epstein?
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-4717-0720-ef54d20436cf
3506-001
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A.
No.
Q.
Have you described for me in this deposition
all personal contact, that is, one-on-one contact you've
had with Mr. Epstein?
A.
Just one time.
Q.
And I meant, which would either be when you,
personally, saw him or you, personally, spoke to the
person who you believe is him --
A.
No. I'm talking about when I physically was
on his property in his driveway.
Q.
And have you described for me in this
deposition all occasions when you've personally spoken
with him on the phone?
A.
Yeah.
Q.
Has your daughter told you anything else about
Mr. Epstein, other than what you've told me --
A.
No.
Q.
-- during this deposition?
MR. LUTTIER: I don't have any other
questions.
MR.
: I don't have lien
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-4717-0728-ef54d28436cf
3506-001
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-4717-0720-ef54d28436cf
3506-001
Page ISO of 187
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EFTA_00006303
EFTA00158196
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-47(7-0720.154d28436cf
3506-001
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VIDEOGRAPHER: Going off the record at 12:43
p.m. This marks the end of the deposition.
MR. LUTTIER: You have the right to either
this will get typed up. You have the right to read
it, in which case you can read the transcript and
if there's any inaccuracies, you can change it.
THE WITNESS: No. I want to read it.
MR. LUTTIER: And she'll make arrangements
through you, I assume, to take care of it.
(Witness excused.)
(Deposition was concluded.)
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-47(7-0720-ef54d20436cf
3506-001
Page 182 of 187
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Page 183
1
CERTIFICATE OF OATH
2
STATE OF FLORIDA
3
COUNTY OF PALM BEACH
4
5
6
I, the undersigned authority, certify that
7
personally appeared before me and was
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duly sworn on the 6th day of November, 2009.
Dated this 19th day of November, 2009.
Sandra W. Townsend, Court Repd1
Notary Public - State of Florida
My Commission Expires: 6/26/12
My Commission No.: DD 793913
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98.21e8e8-101b-471743720-ef54d28436cf
3506-001
Page 183 of 187
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Page 184
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2
STATE OF FLORIDA
3
COUNTY OF PALM BEACH
4
CERTIFICATE
5
I, Sandra W. Townsend, Court Reporter and
Notary Public in and for the State of Florida at Large,
6
do hereby certify that the aforementioned witness was by
me first duly sworn to testify the whole truth; that I
7
was authorized to and did report said deposition in
stenotype; and that the foregoing pages numbered 1 to
8
182, inclusive, are a true and correct transcription of
my shorthand notes of said deposition.
9
I further certify that said deposition was
10
taken at the time and place hereinabove set forth and
that the taking of said deposition was commenced and
11
completed as hereinabove set out.
12
I further certify that I am not attorney or
counsel of any of the parties, nor am I a relative or
13
employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the
14
action.
15
The foregoing certification of this transcript
does not apply to any reproduction of the same by any
16
means unless under the direct control and/or direction
of the certifying reporter.
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Dated this 19th day of November, 2009.
Sandra W. Townsend, Court Reporter
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08.21e8e8-101b-4717-0720-ef54d20436cf
3506-001
Pagc 184 of 187
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Page 185
1
DATE:
November 19, 2009
2
TO:
c o
, Esquire
3
4
IN RE:
III II vs. Epstein
5
CASE NO.: 08-CIV-80119-MARRA/JOHNSON
6
Please take notice that on Friday, the 6th of
7
November, 2009, you gave your deposition in the
above-referred matter. At that time, you did not waive
8
signature. It is now necessary that you sign your
deposition.
9
Please call our office at the below-listed
number to schedule an appointment between the hours of
10
9:00 a.m. and 4:30 p.m., Monday through Friday, at the
Esquire office located nearest you.
11
If you do not read and sign the deposition
within a reasonable time, the original, which has
12
already been forwarded to the ordering attorney, may be
filed with the Clerk of the Court. If you wish to waive
13
your signature, sign your name in the blank at the
bottom of this letter and return it to us.
14
Very truly yours,
15
16
17
Sandra W. Townsend, FPR
PROSE COURT REPORTING AGENCY
18
19
20
I do hereby waive my signature.
21
22
23
I do hereby waive my signature:
24
cc: Via transcript: All Counsel of Record; file copy
25
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-4717-0720-ef54d20436cf
3506-001
Page 185 of 187
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Page 186
1
CERTIFICATE
2
3
THE STATE OF FLORIDA
4
COUNTY OF PALM BEACH
5
I hereby certify that I have read the
6
foregoing deposition by me given, and that the
7
statements contained herein are true and correct to the
8
best of my knowledge and belief, with the exception of
9
any corrections or notations made on the errata sheet,
10
if one was executed.
11
12
Dated this
day of
13
2009.
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PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-4717-0720-ef54d20436cf
3506-001
Pagc 186 of 187
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Page 187
1
ERRATA
SHEET
2
IN RE:
MI
VS. EPSTEIN CR: S. TOWNSEND
3
DEPOSITION OF:
4
TAKEN: 11/6/09
5
6
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
7
PAGE 4 LINE 4
CHANGE
REASON
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Please forward the original signed errata sheet to this
office so that copies may be distributed to all parties.
19
Under penalty of perjury, I declare that I have read my
20
deposition and that it is true and correct subject to
any changes in form or substance entered here.
21
22
DATE:
23
24
SIGNATURE OF DEPONENT:
25
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
98e1e8e8-101b-4717-0728-ef54d28436cf
3506-001
Page 187 of 187
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EFTA_00006310
EFTA00158203
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| Filename | EFTA00158017.pdf |
| File Size | 5545.5 KB |
| OCR Confidence | 85.0% |
| Has Readable Text | Yes |
| Text Length | 117,670 characters |
| Indexed | 2026-02-11T10:59:27.341782 |