EFTA00158904.pdf

1 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 CASE NO. 08-CIV-80119-MARRA/JOHNSON 3 4 5 Plaintiff, 6 -vs- VOLUME I OF II 7 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 19 20 21 22 23 Reported By: Cynthia Hopkins, RPR, FPR 24 Notary Public, State of Florida Prose Court Reporting 25 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008052 EFTA00158904 2 1 APPEARANCES: 2 On behalf of 3 4 5 6 7 ESQUIRE 8 On behalf of the Defendant, Epstein: 9 ROBERT D. CRITTON, JR., ESQUIRE MARK T. LUTHER, ESQUIRE 10 BURMAN, CRITTON, LUTHER & COLEMAN, LLP 11 12 13 14 15 ALSO PRESENT: 16 Jeffrey Epstein, via video conference 17 I MMI, Paralegal, P.A. 18 19 Stan Sanders, Videographer Visual Evidence, Incorporated 20 21 22 23 24 25 3 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008053 EFTA00158905 1 2 INDEX VOLUME I 3 _ _ _ 4 5 WITNESS: DIRECT CROSS REDIRECT RECROSS 6 ■• 7 8 9 10 11 EXHIBITS 12 13 14 EXHIBIT DESCRIPTION PAGE 15 BY MR. LUTTIER 5 DEFENDANT'S NO. 1 11 16 Plaintiffs Notice of Serving Second Amended Answers to Interrogatories 17 DEFENDANT'S NO. 2 29 18 Answers of Interrogatories 19 DEFENDANT'S NO. 3 119 First Amended Complaint 20 DEFENDANT'S NO. 4 254 21 Plaintiffs Notice of Serving Third Amended Answers to Defendant's First 22 Interrogatories 23 24 25 4 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008054 EFTA00158906 1 PROCEEDINGS 2 3 Deposition taken before Cynthia Hopkins, 4 Registered Professional Reporter and Florida 5 Professional Reporter, and Notary Public in and for 6 the State of Florida at Large, in the above cause. 7 - - - 8 THE VIDEOGRAPHER: Today is the 4th day of 9 December, 2009. The time is approximately 10 10:25 in the morning. This is the videotape 11 deposition of -- did I 12 pronounce it correctly? 13 THE WITNESS: Yeah. 14 THE VIDEOGRAPHER: -- in the matter of 15 No.nversus Epstein. This 16 deposition is being held at 17 in West Palm Beach, Florida. 18 My name is Stan Sanders. I am the 19 videographer representing Visual Evidence, 20 Incorporated. 21 Will the attorneys please announce their 22 appearances for the record. 23 MR. : My name I am 24 counsel on behalf. With me is 25 M, Paralegal. 5 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008055 EFTA00158907 1 MR. LUTTIER: My name is Mark Luther, and 2 I am here on behalf of the Defendant, 3 Mr. Epstein. 4 Thereupon, 5 6 Having been first duly sworn or affirmed, was 7 examined and testified as follows: 8 THE WITNESS: Absolutely. 9 THE COURT REPORTER: Thank you. 10 DIRECT EXAMINATION 11 BY MR. LUTTIER: 12 Q. Would you please tell me your full name, 13 ma'am. 14 A. 15 Q. Ms. have -- my name is Mark lb Luttier. I represent Mr. Epstein in this pending 17 lawsuit that you have brought. Have you ever had an I R opportunity to be deposed before? 19 A. What does that mean? 20 Q. That's the process that we're about to 21 engage in here is known as a deposition. 22 A. No. 23 Q. All right. I just want to explain sort of 24 the rules to you so that you understand it. First 25 of all, if you want to take a break at any time, if 6 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008056 EFTA00158908 1 you want something to drink, have to go to the 2 bathroom, just let me know. 3 MR. : If it's of any help to you, 4 and I have had an opportunity to talk 5 about the basic procedures involved. 6 MR. LUTTIER: Okay. 7 MR. : And I don't think it's necessary -- 9 MR. LUTTIER: Okay. 10 MR. : -- for you -- 11 MR. LUTTIER: All right. 12 MR. : -- to go through that with 13 her. 14 MR. LUTTIER: All right. 15 MR. : But if you think there's a 16 purpose — 17 MR. LUTTIER: No. 18 MR. : -- of doing it anyway, 19 obviously you have a right to do that. 20 BY MR. LUTTIER: 21 Q. Do you, do you understand the fact that 22 you are under oath now? 23 A. Yes. 24 Q. And do you know what the significance of 25 being under oath is? 7 1 A. Yes. file:///D/...20[SUBJECPY•20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008057 EFTA00158909 2 Q. And what is your understanding of the 3 significance of being under oath? 4 A. Not to lie to you. 5 Q. Yeah, you have to tell the truth. 6 A. And God is watching me. 7 Q. In other words you understand you have to 8 tell the truth about everything? 9 A. Yes. That would fall under not lying. 10 Q. And you understand there are civil and 11 criminal consequences that could be attributed to 12 making statements that are not true while under 13 oath? 14 A. Yes. 15 Q. Okay. In this particular lawsuit, you've 16 had an opportunity to discuss your claims with 17 various other people, have you not? 18 A. One more time. 19 Q. You've had an opportunity before you came 20 here today to discuss your various claims that 21 you've made about Mr. Epstein with other people? 22 A. As in my attorneys? 23 Q. As in anybody. 24 A. I've only talked about it with my attorneys. 25 Q. Okay. Did you have a conversation at any 8 1 time prior to today with anyone from the state SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008058 EFTA00158910 2 attorney's office here in the Palm Beach County 3 State Attorney's Office? 4 A. Yes. 5 Q. Okay. 6 A. And the FBI. 7 Q. All right. Let's first talk about the 8 state attorney's office. Do you know with whom you 9 spoke? 10 A. I don't remember the name. 11 Q. Do you know if it was a man or a woman? 12 A. I have spoke to a man and a woman. 13 Q. How many times did you speak with someone 14 at the State Attorney's Office? 15 A. Once. 16 Q. And where did you speak with them? 17 A. In a building somewhere off of of 18 here. I don't remember the name of the building. 19 Q. Do you know if it was at the State 20 Attorney's Office -- 21 A. Yeah. 22 Q. -- across from the courthouse? 23 A. The United States Attorney's Office. 24 Q. Okay. Let me back up a little bit. Now 25 you mentioned the United States Attorneys? 9 1 A. That's -- 2 Q. That would be someone associated with file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008059 EFTA00158911 3 what's known as the federal system. When I was 4 asking you about the state attorney, that would be 5 someone associated with the State of Florida. 6 A. I was at a building with United, it was the 7 United State's State Attorney's Office. 8 Q. All right. And would that have been a 9 building you say here on somewhere? 10 A. Or It was somewhere in this 11 vicinity of buildings. not exactly sure where. 12 Q. Do you remember the name of either the man 13 or the woman -- 14 A. I do not. 15 Q. -- with whom you met. Did you have a 16 separate meeting with someone from the Florida State 17 Attorney's Office? 18 A. I don't remember. 19 Q. And the State Attorney's Office is located 20 across the street from the courthouse downtown in 21 West Palm Beach. 22 A. I don't remember. 23 Q. When you, when you -- and by the way, when 24 you say you don't remember, is it your intent to 25 indicate to me that you have no recollection whether 10 1 it happened or didn't happen? 2 A. It's. 1 don't remember if that was the file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008060 EFTA00158912 3 building I was in. 4 Q. Okay. Do you recall having met with 5 someone from the State of Florida, a prosecutor from 6 the State of Florida as well as someone from the 7 United States Attorney's Office? 8 A. Well, there was a lot of people there. 9 Q. This, now you're referring to the initial 10 meeting that you talked to me about? 11 A. When I had the meeting, I believe, I'm not 12 sure if it was -- I know it was the United States State 13 Attorney's Office. It could have been State of Florida. 14 There was a victim's advocate there and the FBI was 15 there. 16 Q. Okay. So, we have a man and a woman that 17 were associated with the, the State Attorney's 18 Office, whether it was the U.S. Attorney or State 19 Attorney, a victim's advocate and how many members 20 from the FBI? 21 A. I was with one lady from the FBI. 22 Q. Do you, do you know her name? 23 A. I do not remember. 24 Q. Do you remember even the first name, first 25 or last name? 11 1 A. I don't remember. 2 Q. Do you remember what race she was? 3 A. She was white. The Victim's Advocate lady, file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_0000806 I EFTA00158913 4 she was black. I remember that. 5 Q. Do you remember her name? 6 A. No. 7 MR. LUTTIER: Let me hand you what we'll 8 mark as Exhibit No. 1 which purports to be a 9 document entitled Plaintiffs Notice of Serving 10 Second Amended Answers to Interrogatories. 11 Here's your copy. 12 THE WITNESS: Do I get a copy? 13 MR. LUTTIER: Yeah, I am going to get to 14 you. I'm just going to put a stamp on one. 15 BY MR. LUTTIER: 16 Q. Now, let me hand you Exhibit 1. And the 17 first question I have for you is if you will turn to 18 the last page; is that your signature? 19 A. Yes. 20 Q. All right. Now, if you will, on the last 21 page you have represented that these answers are 22 true and correct. I want to give you an opportunity 23 to flip through these answers and look at them. 24 A. Of where, the whole packet? 25 Q. Right. And tell me if there is anything 12 1 in these answers that is not correct or is 2 incomplete? 3 MR. : I am going to object to the file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008062 EFTA00158914 4 question as compound, vague, and overly broad. 5 BY MR. LUTT1ER: 6 Q. Let me give you a chance to look through 7 them. And my first question will be is there 8 anything that is inaccurate in these answers. 9 MR. : Same objection. You can -- 10 a unless I instruct you not to answer, 11 the objections that I am making are objections 12 that are being made so that the court can look 13 at them at a later time and decide whether the 14 question was appropriate. 15 You should answer the question regardless 16 of whether I raise an objection unless I tell 17 you not to. Okay? 18 THE WITNESS: I'm so confused. 19 MR. : That's all right. Right now 20 you have been asked to look at these and to 21 determine whether there is any inaccuracy in 22 the answers that you swore to previously. 23 THE WITNESS: This is what me and you did, 24 right? Then it all should be correct unless 25 somebody else messed with it. Excuse me. 13 1 2 3 4 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008063 EFTA00158915 5 6 7 8 9 10 11 12 13 14 MR. : Is the absence of signature 15 that you are referring to Page 15? 16 MR. LUTTIER: No, I have got it on this 17 one. 18 MR. : Well, okay. 19 MR. LUTTIER: But I have got it, and it 20 may be that, it may be that that's what I was 21 looking at. 22 THE WITNESS: I was -- 23 MR. LUTTIER: But I can tell you there is 24 another set coming. 25 THE WITNESS: Referring to MM 14 2 MR. : Yes, =M? 3 THE WITNESS: For it says I 4 was paid $100. I was given the amount of $300. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008064 EFTA00158916 5 I wasn't given the extra $100 for bringing her, 6 and I gave her $100 out of my money because he 7 said she was fat. 8 MR. LUTTIER: Okay, now -- 9 MR. : Okay . 10 BY MR. LUTTIER: 11 Q. -- you're referring to your answer to 12 Interrogatory 23? 13 MR. : On Page 14, correct. 14 was just clarifying that response. 15 MR. LUTTIER: Okay. And your 16 clarification that is an 17 individual that you brought to Mr. home -- 18 Mr. Epstein's home and — 19 THE WITNESS: I was not given the extra 20 money for bringing her. 21 BY MR. LUTTIER: 22 Q. Okay. So you got paid zero for bringing 23 her? 24 A. Yes. 25 Q. Okay. 15 1 A. I got paid $300 for me going, but was not 2 given the extra hundred for bringing her. 3 Q. So, you got 300 for going. You went on 4 this occasion, but you were not given any extra 5 mone).1 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008065 EFTA00158917 6 A. The extra money. yes. 7 Q. And you brought Ms.. on that 8 occasion? 9 A. Yeah. 10 Q. Okay. And then you're indicating that 11 what you did was even though you only got paid 300, 12 you took 100 of your 300 and gave it to IM • 13 14 A. Yes. 15 Q. Okay. Any other corrections to any of 16 your answers to interrogatories? 17 A. So far that's -- I don't see any. 18 Q. Okay. 19 A. That was the only thing. 20 Q. Let's then turn to, I'm going to reference 21 your answer to Interrogatory No. 5 which starts -- 22 A. What page — 23 Q. On Page 3, which asks you to give, 24 identify anybody that you believe has information 25 pertaining to this suit. And I want to -- 16 1 A. Pertaining to what? 2 Q. To this, to this claim. 3 A. Okay. 4 Q. I will refer to it sometimes as your claim 5 or to this lawsuit that you brought against file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008066 EFTA00158918 6 Mr. Epstein? 7 A. Okay. 8 Q. And by the way, I am sure Mr. 9 explained this to you, and you are doing a fine job, 10 any time I ask you a question and you're not sure 11 what I'm asking or you need me to explain it, just 12 ask me to, and I will be happy to explain it to you. 13 A. Yeah. 14 Q. Okay? Now, let me draw your attention 15 over to Page No. 10? 16 A. Well, what was the point of going to Page 17 No. 3? 18 Q. Well, Page No. 3 is the list, starts with 19 a list of names of the people that you gave that you 20 said had information concerning this claim. Okay. 21 And I want to now call your attention to Witness 22 Number 31 which is found on Page 10. 23 A. I don't understand what you just said. 24 Q. If you would turn to Page 10, you will see 25 a Number 31. See that Number 31- 17 1 A. Uh-huh. 2 Q. And it indicates that he is an attorney 3 with the Department of Justice which would be the 4 U.S. Attorney. Is, does that name refresh your 5 recollection as to whether or not he was the 6 individual with whom you met from the U.S. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008067 EFTA00158919 7 Attorney's Office? 8 MR. : Let, let's make sure we 9 understand exactly what this answer is. The 10 information provided is information that was in 11 the possession or control of And 12 obviously some of these names were not provided 13 by but were gathered through the 14 investigation conducted by her attorneys. And 15 we were obliged to disclose that information as 16 her lawyers in response to this interrogatory. 17 So, to suggest to that this 18 information originated with her would be 19 incorrect. 20 MR. LUTTIER: I wasn't suggesting 21 anything. 22 MR. : Okay. 23 MR. LUTTIER: I was just referring to the 24 fact that she gave us in an answer to 25 interrogatory that is someone 18 1 that she said she believed had knowledge about 2 the case, and the address she gave reflects he 3 is from the U.S. Department of Justice. 4 BY MR. LUTTIER: 5 Q. And my question is, seeing that name, does 6 that refresh your recollection as to whether or not file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008068 EFTA00158920 7 he was the individual -- 8 A. I don't remember. 9 Q. -- with whom you met when you say you met 10 with the -- 11 A. There was more — 12 Q. -- U.S. Attorney? 13 A. -- than four people in the room, so their 14 names, I can't remember. 15 Q. Okay. So it doesn't refresh your memory 16 looking at this? 17 A. No. 18 Q. All right. Look at the next witness which 19 is 32. Do you see the name M.S.W.? 20 A. What does M.S.W. stand for? 21 Q. I imagine it's Master of Social Work. 22 Does that refresh your recollection as to whether or 23 not that was the victim advocate with whom you met? 24 A. Yes, I remember 25 Q. Okay. And that would be the person that 19 1 you previously identified as the victim advocate 2 that was at this meeting? 3 A. Uh-huh. 4 Q. That's a yes? 5 A. I believe so. 6 Q. If you will turn to the next page, Page 7 11, Number 34, there is a name file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008069 EFTA00158921 8 A. Yeah. 9 Q. Does that name — do you recognize that 10 name -- 11 A. Yes. 12 Q. -- as being the person with whom you met, 13 and that would have been, was that the woman from 14 the U.S. Attorney's Office with whom you met on this 15 occasion that you described? 16 A. I just remember the last name 17 Q. As being the women that was present for 18 this meeting that you had with the U.S. Attorney? 19 A. Yes. 20 Q. Now, in reviewing these names, do you, do 21 you recognize any name in the list that you have 22 given me in response to this interrogatory that is 23 indicative of the man from the U.S. Attorney's 24 Office? 25 A. Were does indicative mean? 20 1 Q. That is the person, the man with whom you 2 met at the U.S. Attorney's Office. 3 A. Okay. Ask me the question one more time now 4 that I know what the meaning of that word is. 5 Q. You, you said that when you met with the 6 U.S. Attorney's Office there was one man and one 7 woman from the U.S. Attorney's Office. You have now file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008070 EFTA00158922 8 said that Ms. was the woman. 9 A. I remember -- 10 Q. I call your attention to this list of 11 names you gave me. Can you point out to me which 12 individual, if he's listed, was the man with whom 13 you met at that meeting? 14 A. And I told you I don't remember the name. 15 Q. All right. And, and is it, do you know 16 that the person -- 17 A. It could be possible -- 18 Q. -- that's listed -- 19 A. That's his name, yes. I don't know. I said I 20 don't know, so... 21 Q. Do you, in looking through this list, can 22 you identify the person that you described as the 23 woman from the FBI? 24 A. And now I lost my page. I'm upset. I'm 25 sorry. What page were we on? 21 1 Q. Well, we happen -- 2 A. I just -- 3 Q. The last page we were on is Page 11, but 4 feel free to look at all of the names? 5 A. Okay. I do not see the lady-from-the-FBI's 6 name. 7 Q. Do you have that information anywhere? 8 And by that I mean even if it's not on the answers file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008071 EFTA00158923 9 to interrogatories, do you someplace have the 10 information as to the name of the woman from the FBI 11 that was present at the meeting? 12 A. No, but if somebody did and showed me the 13 name, I would definitely remember because it was a weird 14 name. 15 Q. All right. So, I want you to take your 16 time to look at those lists, that list of witnesses 17 that starts on Page 3 and carefully look at them and 18 tell me if you recognize -- 19 A. That's what I am doing -- 20 Q. -- the name. 21 A. I don't see that lady's name. 22 Q. Do you know if you have that person's name 23 anywhere? 24 A. No. You asked me that already. 25 Q. Other than a man and a woman from the U.S. 22 1 Attorney's Office, one of whom you identified as 2 Ms. Ms. the victim advocate, and 3 the lady from the FBI, was anyone else present for 4 this meeting that you had with the U.S. Attorney? 5 A. Yes, and I don't know their name. 6 Q. Who else, who else, who were they that 7 were present, even if you don't know their names? 8 A. I don't know. They were -- file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008072 EFTA00158924 9 Q. I just, from what agency were they 10 associated? 11 A. I don't remember. 12 Q. Were there, was there any lawyer there? 13 A. I don't remember. 14 Q. Was there any lawyer there on your behalf? 15 A. No. 16 Q. Did you take anyone to the meeting with 17 you? 18 A. No. 19 Q. How many other people were there? You've 20 identified five thus far, plus yourself. 21 A. I believe it was five then. 22 Q. So, you now -- 23 A. I was just about to count them. 24 Q. So, you now have identified for me 25 everyone that was there? 23 1 A. I believe so. 2 Q. What was discussed at this meeting? 3 A. The incident between me and Jeffrey Epstein. 4 Q. Which incident is that? 5 A. The incident why we're here now. 6 Q. Are you referencing a single isolated 7 incident? 8 A. I am talking about the whole situation of all 9 the times I've been there, what happened. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008073 EFTA00158925 10 Q. Do you know approximately when this 11 meeting occurred? We can start with the year. 12 A. I don't remember the year. It's, it was a 13 couple of years ago. Actually it was about, I think it 14 was a couple years ago, as a couple not as in two. It 15 was longer than that. 16 Q. Is there anything that will refresh your 17 memory as to when it happened? 18 A. That's what I am trying to think about. 19 Q. Did you make a note of it, for example? 20 A. My mom would know. 21 Q. Why would she know? 22 A. Because I called her and told her the FBI was 23 at our house. 24 Q. Was where, at her house? 25 A. Was at the house, yeah. The FBI came to the 24 1 house. 2 Q. Was this before this meeting that you had 3 with the U.S. Attorney? 4 A. It was before that meeting, yes. 5 Q. Okay. So, you've had to two meetings with 6 the FBI? 7 A. I had the meeting when they first came and 8 knocked on the door and asked me if I know who 9 Mr. Epstein was. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008074 EFTA00158926 10 Q. Okay. 11 A. And then they were at the meeting with the 12 United States people, attorney people. But my mom would 13 remember. 14 Q. Okay. Let's go back then. Let's talk 15 about what we'll describe as the first meeting with 16 the FBI. You say they came to your house? 17 A. Yes. 18 Q. Where was this house located? 19 A. West Palm Beach 20 Florida 21 Q. I take it you were living there at the 22 time? 23 A. Yeah. 24 Q. Was anyone else living with you at that 25 time at that residence? 25 1 A. My brothers, my mother. 2 Q. All three of your brothers? 3 A. And I believe it was my daughter's father was 4 living with me then too. 5 Q. That would be Mr. 6 A. Yes. 7 Q. Do you recall when that meeting took 8 place? 9 A. I just said no. I said my mom would 10 approximately know approximately when it happened. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008075 EFTA00158927 11 Q. How many members of the FBI came to meet 12 with you on that occasion? 13 A. Two, a man and a woman. 14 Q. Were -- 15 A. And I do not recall the names. 16 Q. Looking at this list of witnesses that you 17 gave me in these answers to interrogatories which 18 have been marked as Exhibit I, do you recognize the 19 name of either of these -- 20 A. And I said no. 21 Q. Well, actually I haven't asked you the 22 question yet. So, do you recognize the name of any 23 of these individuals as being the FBI agents that 24 came to your house at 25 A. And I said no. I already knew you were going 26 1 to ask me that. That's why I said no. 2 Q. And was it two men or a man and a women or 3 two woman? 4 A. A man and a woman. 5 MR. : You already asked that 6 question, and you were told it was a man and a 7 woman. 8 BY MR. LUTTIER: 9 Q. And did they meet with you on that 10 occasion? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008076 EFTA00158928 11 MR. : You already asked that 12 question. 13 MR. LUTTIER: Who, was any-- 14 MR. said that a man a 15 woman came to see her and she was there. So 16 there obviously was a meeting. 17 BY MR. LUTTIER: 18 Q. Did you meet inside the house or outside 19 the house? 20 A. Outside the house. 21 Q. Was there anyone else present besides you 22 and these two persons from the FBI? 23 A. No. 24 Q. Did anyone make any notes during this 25 meeting, the first meeting -- 27 1 A. The FBI people did. 2 Q. Do you know whether or not you, anything 3 you said was recorded? And by that I mean like with 4 a tape recording. 5 A. Not at that present time, no. It was recorded 6 when we went to the United States place. 7 Q. And was it recorded by via tape recorder, 8 was there a court reporter there like we have here? 9 A. No, it was on tape recorder. 10 Q. Have you ever been provided with a 11 transcript, that is a paper writing that reflects file:///D/...20( SUBJECPY.20TO%20PROTECT 1 V E%20ORDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008077 EFTA00158929 12 what was said at the meeting that was recorded? 13 A. No. 14 Q. Have you ever asked for it? 15 A. No. I didn't know I could have. 16 Q. Were you under oath at the meeting that 17 was recorded? 18 A. I don't believe so. 19 Q. Did you -- 20 A. I, I probably was. 21 Q. Whether you under oath or not, did you 22 tell them the truth at that meeting? 23 A. Yeah. 24 Q. Did you tell the FBI the truth when they 25 came to your house? 28 1 A. Yes. I have no absolutely no reason to lie 2 about this situation. 3 Q. Other than the meeting when the FBI came 4 to your house and when you met with the U.S. 5 Attorney that you have described thus far, have you 6 had any other contact with the FBI? 7 A. No. 8 Q. Have you had any other contact with anyone 9 from the U.S. Attorney's Office? 10 A. No. 11 MR. LUTTIER: Let's mark this as file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008078 EFTA00158930 12 Exhibit 2. 13 THE WITNESS: Is this mine to keep? 14 MR. LUTT1ER: Yeah. 15 16 17 18 19 20 21 22 23 24 25 29 1 2 3 4 5 (Defendant's Exhibit No. 2 was marked for 6 identification.) 7 THE WITNESS: Sorry about that. Like 8 that, right? Okay. I'm sorry now. 9 BY MR. LUTTIER: 10 Q. Okay. Now I have handed you what has been 11 marked as Exhibit No. 2 which is a document that is 12 entitled Notice of Serving Answers to file:///D/...20[SUBJECPY•20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008079 EFTA00158931 13 Interrogatories. 14 A. Okay. 15 Q. And this is similar to Exhibit 1 which was 16 supplemental interrogatories; that is they are 17 written questions that were submitted to you. If 18 you turn to Page 19, is that your signature? 19 A. Yes. 20 Q. Now, I notice that your signature here 21 does not purport to be a representation under oath 22 that the answers are true and correct? 23 A. That what? 24 Q. I notice that your signature on Page 19 25 does no purport to represent that your answers are 30 1 true and correct? 2 MR. : We will stipulate that it is 3 indeed a representation that -- 4 MR. LUTT1ER: Okay. Good enough. 5 MR. : answers are 6 true and correct. 7 BY MR. LUTT1ER: 8 Q. If you will turn to Page 18, please. You 9 will notice in answer to Interrogatory 23, you state 10 that you were interviewed by the FBI and a State 11 Attorney. In that answer, are you referring to two 12 separate interviews? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008080 EFTA00158932 13 A. That would be Number 22. 14 Q. Correct. 15 A. Not 23. 16 MR. : You did say 23. 17 MR. LUTTIER: Okay. I'm sorry. 18 THE WITNESS: Now, okay. So, now what was 19 the question? 20 BY MR. LUTTIER: 21 Q. You answered in answer to 22 Interrogatory 22, that you were interviewed by the 23 FBI and a State Attorney? 24 A. Yeah. 25 Q. Are you referring now to two separate 31 1 meetings or -- 2 A. One. 3 Q. All right. And is the reference in this 4 answer to the meeting that you've described thus 5 far? 6 A. Okay. Listen. The FBI came to my house one 7 time. And then at this meeting the FBI and the State 8 Attorneys were there. 9 Q. Okay. 10 A. So, there was two meetings with the FBI: One 11 when they came to my house and then one when the State 12 Attorney was there and one in that building somewhere 13 around here. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008081 EFTA00158933 14 Q. All right. 15 A. Does that help you? 16 Q. Yep. 17 A. Okay. Good. 18 19 20 21 22 23 24 25 32 1 2 3 4 5 6 7 8 9 10 11 12 13 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008082 EFTA00158934 14 BY MR. LUTTIER: 15 16 17 18 19 20 21 22 23 24 25 33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008083 EFTA00158935 15 16 17 18 19 20 21 22 23 24 25 34 1 2 3 4 5 6 7 8 10 11 12 13 14 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008084 EFTA00158936 15 16 17 18 19 20 21 22 23 24 25 3 1 2 3 4 5 6 7 8 10 11 12 13 14 15 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008085 EFTA00158937 16 17 18 19 20 21 22 23 24 25 36 1 2 3 4 5 6 7 8 10 11 12 13 14 15 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008086 EFTA00158938 16 17 18 19 20 21 22 23 24 25 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008087 EFTA00158939 17 18 19 20 21 22 23 24 25 3 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008088 EFTA00158940 17 18 19 20 21 22 23 24 25 39 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008089 EFTA00158941 18 19 20 21 22 23 24 25 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008090 EFTA00158942 18 19 20 21 22 23 24 25 41 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008091 EFTA00158943 19 20 21 22 23 24 25 42 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008092 EFTA00158944 19 20 21 22 23 24 25 43 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008093 EFTA00158945 20 21 22 23 24 25 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008094 EFTA00158946 20 21 22 23 24 25 4 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008095 EFTA00158947 21 THE VIDEOGRAPHER: Going off the record at 22 11:09. 23 (A brief recess was held.) 24 THE VIDEOGRAPHER: We're back on the 25 record at 11:18. 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008096 EFTA00158948 21 22 23 24 25 4 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008097 EFTA00158949 22 23 24 25 48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008098 EFTA00158950 22 23 24 25 4 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 file:///D/...20[SUBJECT%20T0%20PROTECTIVE%200RDER%20PARAGRAPHS%207,%208,%209,%2010,%20 I 5,%20and%20171.txtt I 2/10/2025 3:06:21 PMJ EFFA_00008099 EFTA00158951 23 24 25 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008 I 00 EFTA00158952 23 24 25 51 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008101 EFTA00158953 24 25 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008102 EFTA00158954 24 25 53 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008103 EFTA00158955 25 54 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008 104 EFTA00158956 25 55 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 file:///D/...20[SUBJECT%20T0%20PROTECTIVE%200RDER%20PARAGRAPHS%207,%208,%209,%2010,%2015,%2066"20171.1412/10/2025 3:06:21 PMJ EFIA_00008105 EFTA00158957 56 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 57 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008 I 06 EFTA00158958 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 58 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008107 EFTA00158959 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 59 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008108 EFTA00158960 1 2 3 4 5 6 7 8 9 1 1 11 1 1 1 1 1( 1 1 1 2 • 1 21 2 2 2 2 60 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008 109 EFTA00158961 1 2 3 4 5 6 7 8 10 11 12 13 14 BY MR. LUTTIER: 15 Q. You — one of your claims in this case is 16 that as a result of your meetings with Mr. Epstein, 17 you have incurred medical expenses. Are you aware 18 that that's one of your claims? 19 A. Medical expenses? 20 Q. Yes. 21 A. Because I have Baker Acted myself due to 22 instability from the trauma of Mr. Epstein. 23 Q. And where did you Baker Act yourself? 24 A. 25 61 1 file:///D/...20[SUBJECT%20T0%20PROTECTIVE%200RDER°420PARAGRAPHS%207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008110 EFTA00158962 2 3 4 Q. And did you tell the individuals at 5 he reason you were Baker Acting 6 yourself was because of — 7 A. It was depression. I never spoke about 8 Mr. Epstein with anybody. 9 Q. So, the physicians that treated you at 10 would not know anything about Mr. Epstein, 11 correct? 12 A. No. I told them I was depressed. 13 Q. And why were you depressed? Why did you 14 tell them you were depressed when you went to 15 16 A. Because I was. 17 Q. But didn't tell them that it had anything 18 to do with Mr. Epstein, correct? 19 A. Correct. 20 Q. Asa matter of fact before you filed this 21 lawsuit, you never told anyone that you were ever 22 depressed because of anything that Mr. Epstein did? 23 A. My mother. 24 Q. When did you first tell her that you were 25 depressed because of Mr. Epstein? 62 1 A. Probably after I have seen Mr., after I SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008 III EFTA00158963 2 stopped seeing Mr. Epstein. 3 Q. When would, when is it that you would have 4 told her? Because you, according to your complaint 5 you stopped seeing Mr. Epstein in August oU and 6 it's now December of '09. 7 A. Well, throughout the years. 8 Q. You can't remember a specific time that 9 you first told her? 10 A. I don't write down dates and times of -- I 11 talk to my mom. When you talk to your mom, do you write 12 down dates? 13 Q. Are there -- 14 MR. : Don't you want to answer 15 that question? 16 BY MR. LUTTIER: 17 Q. You were requested to produce your medical 18 bills that you claim you incurred as a result of 19 your interactions with Mr. Epstein and none have 20 been produced. Do you have any? 21 A. I've done what? 22 Q. You were asked to give us copies of any 23 medical bills you claim you incurred because of 24 Mr. Epstein and we haven't received anything. Do 25 you have any such bills? 63 1 A. I don't know what — I'm confused. 2 Q. Did you go, when you went to file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008112 EFTA00158964 3 4 A. I don't have the bills presently in my purse 5 or anything. 6 Q. Did you pay any money -- 7 A. Did I what? 8 Q. Did you pay for any services rendered to 9 you 10 A. I didn't pay them, no. 11 12 13 14 15 16 17 18 19 I never told them I was 20 there because of the, the abuse by Mr. Epstein. I just 21 I just — 22 (Mr. Critton entered the deposition room.) 23 WITNESS: Who is this man walking in? 24 MR. LUTTIER: He's a lawyer. 25 MR. : That is another defense 64 1 lawyer. That's Mr. Critton, and, and he is a 2 partner in the same law firm. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMI EFTA_00008113 EFTA00158965 3 THE WITNESS: Of them? 4 MR. : Yeah 5 MR. LUTTIER: Other than your -- 6 MR. CRITTON: Thanks for the welcome. 7 MR. LUTTIER: Other than your claim -- 8 MR. : Hello, Robert. 9 MR. CRITTON: Hi, M. 10 BY MR. LUTTIER: 11 Q. -- your claim that you admitted yourself, 12 that you Baker Acted yourself at 13 what other medical expense do you claim you incurred 14 as a result of anything that had to do with 15 Mr. Epstein? 16 A. I don't know. 17 Q. Have you ever been treated by any 18 physician as a result of anything that had to do 19 with Mr. Epstein other than when you claim you Baker 20 Acted yourself at 21 A. Your question is so confusing to me because I 22 feel like you keep asking it in different forms, and I 23 keep telling you the same answer and I'm -- you're 24 confusing the crap out of me. 25 Q. Have you gone to any doctor -- 65 1 A. Other than no. 2 Q. Okay — as result of anything having to do 3 with Mr. Epstein? file:///D/...20[SUBJECPY•20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008114 EFTA00158966 4 A. And I -- no. 1 1 1 1 1 1 1 1 2 2 22 Q. Okay. You claim in your amended complaint 23 that you have lost some sort of wages as a result of 24 your dealings with Mr. Epstein. Are you aware of 25 that? 66 A. I don't know what that means. 2 Q. That you lost income because of your 3 relationship or dealings with Mr. Epstein. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008115 EFTA00158967 4 A. Yeah, I have problems socially with certain 5 people. 6 Q. Well, let's talk about specifically lost 7 earnings. What earnings, that is wages, did you 8 lose because of any dealings you had with 9 Mr. Epstein? 10 A. I have a very hard time working around older 11 men or in specific situations. 12 Q. What situations would those be? 13 A. I don't trust anybody and I don't feel safe in 14 some places. 15 Q. Well, you say you don't trust anybody? 16 A. Well, I don't trust men. 17 Q. What -- any kind of particular kind of men 18 or just any — 19 A. Older men. 20 Q. And what's your definition of "older"? 21 A. Above 40. 22 Q. Okay. Did you have some sort of 23 employment in the past with men over 40 that you've 24 now lost or cannot, can no longer pursue because of 25 your dealings with Mr. Epstein? 67 1 A. Like if you work in restaurants. I'm, I'm 2 confused. 3 Q. And what -- 4 A. I am totally confused. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008116 EFTA00158968 5 Q. Why can't you work in a restaurant as a 6 result of having had interactions with Mr. Epstein? 7 A. I don't like places where men stare at me. It 8 makes me feel uncomfortable. 9 Q. But, in fact, after you saw Mr. Epstein, 10 after you quit going to Mr. Epstein, you worked at 11 numerous places where -- 12 A. I have. 13 Q. -- men saw you, correct? 14 A. Yes. 15 Q. And you have made as much as a thousand 16 dollars a night -- 17 A. Yes. 18 Q. -- going out with people, men that are 19 over 40, have you not? 20 A. Yes, that's true. 21 Q. When before you met Mr. Epstein did you 22 ever earn a thousand dollars a night? 23 A. No, it was after. 24 Q. Never did, correct? 25 A. It was after. 68 1 Q. So, would you agree with me that after 2 that point in time that you stopped seeing 3 Mr. Epstein you actually earned more money than you 4 had ever earned before in your life? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008 117 EFTA00158969 5 A. Yes. 6 Q. Would you agree with me, therefore, that 7 your earning potential and your earning ability had 8 increased and not decreased? 9 A. I suppose. 10 Q. And, by the way, when you were earning a 11 thousand dollars a night, who were you working for? 12 A. I was working for an escort service. 13 14 15 16 17 18 19 20 21 22 23 24 25 6 1 2 3 4 5 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008118 EFTA00158970 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 1 2 3 4 5 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008119 EFTA00158971 6 7 8 9 2 2 2 2 2 2 1 1 2 3 4 5 6 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008120 EFTA00158972 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 1 2 3 4 5 6 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008121 EFTA00158973 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 2 3 4 5 6 7 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_0000 8 1 22 EFTA00158974 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 74 1 2 3 4 5 6 7 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008123 EFTA00158975 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 1 2 3 4 5 6 7 8 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008124 EFTA00158976 9 2 2 2 2 2 2 • 1 1 2 3 4 5 6 7 8 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008125 EFTA00158977 9 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 1 2 3 5 7 8 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008126 EFTA00158978 I0 1 I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 1 2 3 4 5 6 7 8 9 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008127 EFTA00158979 I0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 79 1 2 3 4 5 6 7 8 9 10 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008128 EFTA00158980 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 80 1 2 3 4 5 6 7 8 9 10 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008129 EFTA00158981 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 81 1 2 3 4 5 6 7 8 9 10 11 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008130 EFTA00158982 12 13 14 15 I6 17 18 19 20 21 22 23 24 25 82 1 2 3 4 5 6 7 8 9 10 11 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file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008147 EFTA00158999 20 21 22 23 24 25 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008148 EFTA00159000 21 22 23 24 25 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008149 EFTA00159001 21 22 23 24 25 10 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008150 EFTA00159002 22 23 24 25 102 1 2 3 4 5 6 7 8 9 Q. When did you, other than the cocaine you 10 shot up, when was the first time you used cocaine? 11 A. The first time that Jeffrey Epstein paid me 12 enough money to afford it. 13 Q. When was that? 14 A. When I first started seeing him. 15 Q. On the first occasion that you ever saw 16 Mr. Epstein? 17 A. A couple occasions after 1 started seeing him. 18 Q. Does that mean the third time you saw 19 Mr. Epstein? 20 A. I'm not exactly sure of the exact time. 21 Q. And where did you obtain the cocaine that file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008151 EFTA00159003 22 you took for the first time? 23 A. None of your business. 24 MR. : We'll stipulate that it was 25 not from Mr. Epstein. 103 1 THE WITNESS: No, it was not from 2 Mr. Epstein. 3 BY MR. LUTT1ER: 4 Q. And would you also agree that Mr. Epstein 5 didn't tell you to go get it? Mr. Epstein didn't 6 tell you to go get cocaine, did he? 7 A. No. 8 Q. Mr. Epstein never gave you any drugs. did 9 he? 10 A. No. 11 Q. Mr. Epstein never told you to take any 12 drugs, did he? 13 A. No, but Mr. Epstein knew I was taking drugs. 14 Q. And how did Mr. Epstein know you were 15 taking drugs? 16 A. Because I told him. 17 Q. And what did you tell him? 18 A. I told him that I was under the influence of 19 cocaine. 20 Q. And when did you tell him that? 21 A. When I was at his house. 22 Q. And when was that? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008152 EFTA00159004 23 A. I don't remember the exact date. 24 Q. Which occasion was it that you were at his 25 house that you told him you were under the influence 104 1 of cocaine? 2 A. I don't remember. 3 Q. And was this on one occasion? 4 A. What, that I had gone to his house under the 5 influence? 6 Q. That -- no, that you told him that you 7 were under the influence of cocaine. 8 A. No, there, there was more than one occasion 9 where I have told him. 10 Q. It was your choice to take cocaine before 11 you went to Mr. Epstein's house? 12 A. Anything to mind alter myself not to be there. 13 Q. You did that voluntarily, that is you took 14 whatever drugs you took before you went to 15 Mr. Epstein's? 16 A. Yeah. 17 Q. You bought them with money that you had; 18 is that right? 19 A. From Mr. Epstein, yes. 20 Q. Well, you didn't keep track of the money 21 that you got, right? 22 A. Well, I wasn't receiving income from any other file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008153 EFTA00159005 23 person, so -- 24 Q. And were you doing this cocaine with your 25 boyfriend? 105 1 A. At the time, yes. 2 Q. And that was Mr. 3 A. MR yes. 4 Q. And were you and he doing cocaine 5 away from Mr. Epstein; that is you did it when you 6 weren't at Mr. Epstein's house? 7 A. Yes. But I have done cocaine at Mr. Epstein's 8 house also. 9 Q. When did you do cocaine at Mr. Epstein's 10 house? 11 A. On some occasions while I was there. 12 Q. What occasions were those? 13 A. I don't recall the dates and times. 14 Q. What, where at his house were you doing 15 cocaine? 16 A. I would excuse myself and go to the bathroom. 17 Q. And who was in the bathroom when you were 18 doing this cocaine? 19 A. Myself. 20 Q. And, and what form of cocaine were you 21 using? 22 A. Powder. 23 Q. And did you tell anyone you were taking file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008154 EFTA00159006 24 cocaine? 25 A. Mr. Epstein knew I was high. 106 1 Q. Did you tell Mr. Epstein that you had gone 2 in the bathroom in his house and snorted cocaine? 3 A. Not, per se, in that form. 4 Q. Did you tell him that you were using drugs 5 in his house? 6 A. No. 7 Q. He never told you to use drugs in his 8 house, did he? 9 A. No, he never told me to. 10 Q. He never gave you alcohol in his house, 11 did he? 12 A. No. 13 Q. Did you ever have sexual intercourse with 14 Mr. Epstein? 15 A. No. 16 Q. Do you know what I mean by sexual 17 intercourse, or do I need to go through the various 18 acts? 19 A. Oh, I am pretty sure I know what sexual 20 intercourse is being I have two children. 21 Q. Well, I just want to make sure we're clear 22 about some things. Did Mr. Epstein ever insert his 23 penis into any part of your body at all? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008155 EFTA00159007 24 A. I just said that I've never had sexual 25 intercourse with Mr. Epstein and that I knew what sexual 107 1 intercourse was, and I said no. So, for you to explain 2 to me what it was unnecessary. 3 Q. Okay. Do you just want to answer my 4 question now, ma'am? 5 A. I did four times. I said no. 6 MR. LUTTIER: Would you read back the 7 question I asked? I need an answer to my 8 question. 9 MR. : We will stipulate that the 10 answer to that question is no. 11 BY MR. LUTTIER: 12 Q. Okay. Did you ever perform any sexual act 13 of any kind or nature whatsoever on Mr. Epstein 14 ever? 15 A. Now, you could define, give me a definition of 16 what that would be, because I've never -- giving him a 17 blow job, I've never had sex with him. I did squeeze 18 his nipples or whatever while he was masturbating 19 himself. 20 Q. Any other, did you ever perform any other 21 sexual act on Mr. Epstein? And by, when 1 say 22 other, I'm not acknowledging that squeezing 23 someone's nipples is a sexual act. But it seems 24 that you're defining it as such; is that right? Do file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008156 EFTA00159008 25 you think that's a sexual act? 108 1 MR. : Well, asked you for 2 a definition and - 3 MR. LUTT1ER: Well, actually what we 4 have -- 5 MR. : -- and described to you -- 6 MR. LUTT1ER: Okay. We'll do this -- 7 MR. : -- what she did. 8 BY MR. LUTT1ER: 9 Q. We'll do this, did you ever perform oral 10 sex, that is put Mr. Epstein's penis in your mouth? 11 A. Did I not just tell you -- 12 Q. Ma'am, you said you needed me to 13 explain — 14 THE WITNESS: Could I ask if you could 15 read back that I told him that I never gave him 16 a blow job and never had sex with him. 17 MR. LUTTIER: Now, I am going to explain 18 it to you. We're going to make sure we're 19 clear, ma'am, because I know you want to be 20 specific. Okay. 21 THE WITNESS: I was specific with you. 22 THE COURT REPORTER: One at a time. 23 BY MR. LUTT1ER: 24 Q. Did you ever masturbate Mr. Epstein? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008157 EFTA00159009 25 A. No. 109 1 Q. Did you ever touch Mr. Epstein's penis -- 2 A. No. 3 Q. -- in any way? 4 A. No, no. 5 Q. Did you ever penetrate with any part of 6 your body any part of Mr. Epstein's body? 7 A. Besides touching his nipples, no. 8 Q. Did you ever do anything physically to 9 Mr. Epstein other than give him a simple massage? 10 A. Squeezed his nipples. 11 Q. Was that part of the massage? 12 A. No. 13 Q. Okay. So other than squeeze his nipples 14 and give him a massage, did you do anything else 15 physically to Mr. Epstein? 16 A. No. 17 Q. Did Mr. Epstein ever make you do anything 18 that you didn't want to do ever? 19 A. Make me do anything I didn't want to do. 20 Q. Force you to do something you didn't want 21 to do, ever? 22 A. Probably squeeze his nipple. 23 Q. And why do you say he made you do that and 24 you didn't want to do it? Did you tell him -- well, 25 first of all, did he ask you to squeeze his nipples? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDERV020PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008158 EFTA00159010 110 1 A. Yes. 2 Q. Did you tell him you didn't want to do 3 that? 4 A. Yes. 5 Q. And what did he say when you said that? 6 A. It would help him go faster or whatever. 7 Q. And did you then do it? 8 A. Yes, I did. 9 Q. Did you refuse to do it and say, no, I 10 don't want to do that? 11 A. Yes, I did refuse; and yes, I still did it. 12 Q. Well, did you do it voluntarily then? 13 A. Obviously. 14 Q. All right. Were there ever any other 15 things ever that Mr. Epstein asked you to do that 16 you refused to do? 17 A. No. 18 Q. Is it a true statement then that 19 Mr. Epstein never forced you to do anything? 20 A. I guess no. 21 22 23 24 25 111 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008159 EFTA00159011 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 112 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMI EFIA_00008160 EFTA00159012 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 113 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008161 EFTA00159013 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 114 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008162 EFTA00159014 1 2 3 4 5 6 7 8 9 10 Q. When did you first make an acquaintance or 11 meet Mr. Epstein? 12 A. When brought me over there. 13 Q. And who is 14 A. A friend of mine who has disappeared. 15 Q. What is M. a last name? 16 A. I don't remember. 17 Q. And when you say she brought you over 18 there, what is the "there" that you are referring 19 to? 20 A. To Mr. Epstein's. 21 Q. And where is that? 22 A. It was at Palm, it was on Palm Beach. 23 Q. Are we talking about a condominium, an 24 apartment, or -- 25 A. 358 Albrillo Way. 115 1 Q. And when was it that your friend, file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008163 EFTA00159015 2 =, brought you to Mr. Epstein's at 358 3 Albrillo Way? 4 A. What you do you mean when was it? 5 Q. What date? 6 A. I don't know the date 7 Q. Do you have any record at all anywhere of 8 the date that you first went? 9 A. No. 10 Q. In your complaint you allege that the 11 first time you went was in May or June of-. Are 12 you aware of that? 13 A. Yes, I remember it was spring going into 14 summer. 15 Q. Is there any other basis upon which you 16 concluded that you first went to Mr. Epstein's in 17 May or June of a other than your recollection 18 that it was sometime in the spring? 19 A. No. 20 Q. Is there any other fact or circumstances 21 upon which you relied when you alleged that you 22 first went to Mr. Epstein's in May or June of =? 23 A. One more time. I'm sorry. 24 Q. Any other fact or circumstance that you 25 relied upon when you alleged that you first went to 116 1 Mr. Epstein's in either May or June of other — fik:///D/...20[SUBJECP%20T0%20PROTECTIVE%200RDER%20PARAGRAPHS%207,%208,%209,%2010,%2015,%20and%20171.14I2/10/2025 3:06:21 PMJ EFTA_00008164 EFTA00159016 2 A. I don't -- 3 Q. -- than it was the spring? 4 A. I don't understand. 5 Q. How did you know it was May or June of 6 when the first time that you went to 7 Mr. Epstein? 8 A. Oh, because I remember the weather. 9 Q. That's it. That's the sole basis upon 10 which you allege that you first went to 11 Mr. Epstein's in May or June of . 1 12 A. Yeah. 13 Q. Did you ever keep any kind of record of 14 your occasions that you went to Mr. Epstein's? 15 A. No. 16 Q. Did you have any communication at all with 17 Mr. Epstein himself before you went to his house for 18 the first time when MI took you there? 19 A. No, I didn't even know he existed. 20 Q. Did you ever personally see, that is 21 face-to-face, Mr. Epstein anyplace other than at 358 22 Albrillo, Palm Beach, Florida? 23 A. No. 24 Q. And I mean that from the time you first 25 went there when your friend talked 117 to you until the last time you went there. 2 A. I have only seen him at that house. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008165 EFTA00159017 3 Q. Right. Which means you haven't run into 4 him out in town or any other place? 5 A. No. 6 Q. The only time you ever did it is when you 7 went to his house? 8 A. Yes. 9 Q. Have, have you ever traveled anyplace 10 with -- Mr. Epstein ever take you anyplace? 11 A. No. 12 Q. Anyplace you know, in town, for example, 13 Palm Beach? 14 A. No. 15 Q. Ever take you to concerts? 16 A. He paid for me to go to a concert. 17 Q. Did you ever, did you ever travel outside 18 of Palm Beach County with him? 19 A. No. 20 Q. Never traveled anywhere with him at all, 21 right? 22 A. No. 23 24 25 1 2 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008166 EFTA00159018 3 4 5 6 7 8 9 10 Q. Okay. Let me ask, let me ask you a 11 different question. Did you have access to a 12 computer before you went to see Mr. Epstein for the 13 first time? 14 A. Yeah. 15 Q. All right. Did you ever communicate with 16 Mr. Epstein via computer; that is, did you ever use 17 the computer? 18 A. No. 19 Q. Did you ever e-mail him any messages? 20 A. No. 21 Q. Did you ever receive any e-mails from him? 22 A. No. 23 Q. Did you ever fax anything to him? 24 A. No. 25 Q. Did you ever receive any faxes from him? 119 1 A. No. 2 MR. LUTHER: 1 think they have to change 3 the tape. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008167 EFTA00159019 4 5 6 7 8 THE VIDEOGRAPHER: Off the record at 9 12:29. 10 (A brief recess was held.) 11 THE VIDEOGRAPHER: We're back on the 12 record at 12:40. 13 MR. LUTTIER: What exhibit are we on? 14 THE COURT REPORTER: Three. 15 MR. LUTTIER: Let me have that marked 16 as 3. 17 THE WITNESS: Exhibit 3. Thanks. 18 BY MR. LUTTIER: 19 Q. Ma'am, what I've, what I've given you is a 20 document that's been marked as Exhibit 3. That is a 21 copy of the First Amended Complaint which you filed 22 in this case. And I am giving it to you so that it 23 is available to you if you want to consult it at any 24 time during the deposition. 25 I will probably ask you some specific 120 1 questions about it, in which case I will refer you 2 to the appropriate portion. You don't have to read 3 it now but I want to make sure you're aware it's file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008168 EFTA00159020 4 available to you if you want to consult it. All 5 right? 6 A. Okay. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 BY MR. LUTT1ER: 25 Q. Did you -- have you ever had a phone 121 1 conversation directly with Mr. Epstein? 2 A. About what? 3 Q. About anything? 4 A. Yeah. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008169 EFTA00159021 5 Q. Not, not somebody at Mr. Epstein's house 6 but Mr. Epstein himself? 7 A. Yes. 8 Q. Do you recall on how many occasions you 9 have had phone conversations with him? 10 A. More than twice. 11 Q. Do you have any, are you able to estimate 12 anything more accurate than just more than twice? 13 A. No. 14 Q. From, from your estimate that it was more 15 than twice, would it be a correct statement that it 16 was infrequent that you had a direct phone 17 conversation with Mr. Epstein? 18 A. What is infrequent, like not all the time? 19 Q. Yeah. 20 A. Yeah. 21 Q. Would it be less than a dozen times? 22 A. Yeah. 23 Q. Okay. Do you recall as you sit here today 24 the substance of any of your conversations with 25 Mr. Epstein, the direct ones that you had? 122 1 A. Oh, instead of somebody else calling me to ask 2 me to come over, he called himself. 3 Q. I am just, yeah, my -- the questions I am 4 now asking you concern themselves strictly with file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008170 EFTA00159022 5 phone conversations where you were one part of the 6 conversation; Mr. Epstein himself was the other 7 party. Do you understand that? 8 A. Yeah. 9 Q. Okay. All right. Do you remember the 10 substance of any direct phone conversation you ever 11 had with Mr. Epstein? 12 A. I don't understand. 13 Q. Do you remember the specifics about what 14 he said or what you said? 15 A. About when he got me concert tickets, he 16 called me and asked me if I wanted to go. 17 Q. Okay. And do you know approximately when 18 that conversation happened? 19 A. I don't remember. 20 Q. Do you recall any other direct phone 21 conversation with Mr. Epstein other than when he 22 called you about concert tickets? 23 A. He told me he would be sending me lingerie 24 from New York. 25 Q. Do you recall any other phone conversation 123 1 directly with Mr. Epstein? 2 A. No. 3 Q. So, other than these two phone 4 conversations that you had with Mr. Epstein, was 5 there any other occasion that you and he were on the file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008171 EFTA00159023 6 phone together? 7 A. I don't remember. 8 Q. That is you don't remember any other? 9 A. Yeah. 10 Q. On, on the occasion that he called and 11 asked you about concert tickets, was Mr. Epstein at 12 his house in Palm Beach? 13 A. I'm not sure. 14 Q. Do you know where he was? 15 A. I don't. He was either in New York or in Palm 16 Beach. 17 Q. Do you know where he was? 18 A. I just said no. 19 Q. Okay. On the conversation when he called 20 and said he would be sending you lingerie, do you 21 know where Mr. Epstein was? 22 A. Unh-unh. No. 23 Q. On each of those occasions, who placed the 24 call; that is, did he call you or did you call him? 25 A. He called me. 124 1 Q. Were there ever occasions that you called 2 Mr. Epstein directly, whether or not you talked to 3 him, where you placed a call trying to get 4 Mr. Epstein? 5 A. Yes. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008172 EFTA00159024 6 Q. And how often did that happen? 7 A. More than four. 8 Q. And for what reason were you placing calls 9 to try to get Mr. Epstein? 10 A. To go over there to see him. 11 Q. Were you seeking the opportunity to go 12 over and massage him and get paid? 13 A. Yes. 14 Q. And on these occasions that you called to 15 see if you could go over there and give him a 16 massage, did you talk to him or did you talk to 17 others at his house? 18 A. I talked to or Maxwell. I have also 19 talked to -- I don't know if it's the cook or somebody 20 else that was there that took phone messages. 21 Q. Other than the four occasions when you 22 placed calls to Mr. Epstein's home looking to come 23 over and perform massages for money, were there any 24 other times that you attempted to contact 25 Mr. Epstein ever? 125 1 A. No. 2 Q. Other than the two times that Mr. Epstein 3 called you, once about concert tickets and once 4 about lingerie, to the best of your knowledge were 5 there, was there ever any other time that 6 Mr. Epstein attempted to contact you? file:///D/...20[SUBJECPY•20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008173 EFTA00159025 7 A. Not that I know of. I mean, I don't think it 8 was him. No, I don't remember it. 9 Q. Okay. What, do you recall what phone 10 number you used when you tried to call Mr. Epstein? 11 A. The Palm Beach phone, phone numbers. 12 Q. It would be the number at his house? 13 A. Yes. 14 Q. To be distinguished from a phone number 15 for example, for a cellphone? 16 A. House numbers. 17 Q. Okay. According to your first amended 18 complaint, Paragraph 195, the last time you saw 19 Mr. Epstein was August of.. 20 A. What page are you on? 21 Q. It would be Page 84. Is that correct? 22 A. Yeah. 23 Q. All right. So, for purposes of this case, 24 the total period of time that you had any 25 interaction with Mr. Epstein was between May of. 126 1 and August of 2 A. Uh-huh. 3 Q. That is another way of saying it is the 4 first time you went is May ofeind the last time 5 you went was August of 6 A. Yeah. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008174 EFTA00159026 7 Q. Didn't know Mr. Epstein at all prior to 8 May of., and had no contact with him after August 9 oft? 10 A. Correct. 11 Q. On any occasion that you have described 12 where you had a phone conversation with Mr. Epstein, 13 was anyone else on the line to the best of your 14 knowledge? 15 A. No. 16 Q. For example, you didn't have someone on 17 the extension of the phone where you were? 18 A. No. 19 Q. And to the best of your knowledge nobody 20 was on his end of the phone call? 21 A. No. 22 Q. You never had a discussion with him on a 23 speaker phone, for example? 24 A. No, not to my awareness. 25 Q. Did you ever record -- 127 1 A. No. 2 Q. -- any of your — 3 A. No. 4 Q. Let me -- did you ever record any of your 5 communications with Mr. Epstein? 6 A. No. 7 Q. And by that I would mean it could be a file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008175 EFTA00159027 8 tape recording, could be you making notes. You 9 never did anything like that? 10 A. No. 11 Q. All right. Have you told me in this 12 deposition now everything that you can remember 13 about your direct phone conversations with 14 Mr. Epstein? 15 A. Yes. 16 Q. When you said that Mr. Epstein called you 17 about concert tickets, was he, was he asking you to 18 go with him to the concert or just asking if you 19 wanted tickets to the concert? 20 A. If I wanted the tickets to the concert. 21 Q. And did you take the tickets? 22 A. Yes. 23 Q. All right. Would you, would you say that 24 during the period from May of. to August of• 25 Mr. Epstein was good to you? 128 1 A. Yes. 2 Q. He was polite? 3 A. Yes. 4 Q. Never forced you to do anything you didn't 5 want to do? 6 A. Yes. 7 Q. Did he help you with your self-esteem? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008176 EFTA00159028 8 A. No. 9 Q. Did he attempt to build you up and make 10 you feel good about yourself? 11 A. Yeah. 12 Q. Did he ever attempt to make you not feel 13 good about yourself? 14 A. He didn't try to make me not feel good about 15 myself. 16 Q. He never demeaned you in any way when you 17 were with him? 18 A. No. 19 Q. Did he ever -- 20 MR. 21 MR. LUTTIER: Strike you -- 22 MR. : I think you're going to need 23 to sit up because of the video camera, it's 24 going to be difficult for anybody to understand 25 your responses. Okay. Thank you. 129 1 BY MR. LUTTIER: 2 Q. Did he ever, did he ever strike you ever, 3 hit you? 4 A. No. 5 Q. You know what the phrase domestic violence 6 means? 7 A. Yes. 8 Q. Did he ever commit an act of domestic file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008177 EFTA00159029 9 violence against you? 10 A. No. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 1 2 3 4 5 6 7 8 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008178 EFTA00159030 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 13 1 Q. It's just, you know, a question that we 2 have to ask. Did, did Mr. Epstein ever threaten you 3 in any manner? 4 A. No. 5 MR. CRITTON: Pm sorry. I didn't hear 6 that. 7 THE WITNESS: I said no. 8 BY MR. LUTTIER: 9 Q. Did he ever give you any kind of a file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008179 EFTA00159031 10 substance to ingest or otherwise do anything that 11 caused you, for example, to lose consciousness? 12 A. Not to my awareness, no. 13 Q. He never attempted to drug you in any 14 manner, did he? 15 A. Not to my awareness, no. 16 Q. Never even offered you any drugs, correct? 17 A. Correct. 18 Q. What -- when you would go to 19 Mr. Epstein's, would you and he converse? 20 A. Conversate? 21 Q. Would you talk with him while you were 22 giving him massages? 23 A. Yeah. 24 Q. What types of things did you talk to 25 Mr. Epstein about? 132 1 A. He wanted to put me in massage school. 2 Q. Was that something you were interested in? 3 A. I was. 4 Q. And did you indicate to Mr. Epstein you 5 had an interest in going to massage school? 6 A. Yes. 7 Q. And what did Mr. Epstein tell you about 8 that? 9 A. He sent me a book, Massage for Dummies. And file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008180 EFTA00159032 10 he was going to put me in school for it if I really 11 wanted to do it. 12 Q. And did you indicate to him whether you 13 really wanted to do it? 14 A. Yes, I really wanted to do it, but I never, 15 he — I never went to school for it. 16 Q. Did you ever ask him if, if he would pay 17 for you to be enrolled in school? 18 A. He told me he would. 19 Q. All right. So he said he would be willing 20 to, but you had made the decision you didn't want to 21 go forward with it? 22 A. I wasn't old enough to. 23 Q. Okay. Anything else that Mr. Epstein 24 offered to do for you? 25 A. He wanted to send me on vacation somewhere but 133 1 I was too young to go. My mom wouldn't have let me go 2 out of the country. 3 Q. Did you ever represent to Mr. Epstein at 4 any time what your age was? 5 A. Yes. 6 Q. When did you first represent to 7 Mr. Epstein what your age was? 8 A. When I was going to turn 14,1 accidently said 9 I was going to be 14. And his response was, don't let 10 anybody know how old you are. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008181 EFTA00159033 11 Q. Well, you -- we've established that you 12 first went to him in May or June of.. 13 A. I was 13. 14 Q. Right? You were 15 the, right? 15 A. In.? 16 Q. Yeah. 17 A. No. Was I 15? 18 Q. What day -- yeah, maybe my math is wrong. 19 Mr. will correct me. You were born inM? 20 A. Yeah. 21 Q. Okay. If I add 15 years toM1 think I 22 get toM, unless there is someone here that says 23 my math is wrong. 24 MR. LUTTIER: Mr. NM, do you agree 25 with me that it's= 134 1 MR. : I am going to let you do 2 your own math. When the appropriate time comes 3 to correct you — 4 MR. LUTTIER: Okay. 5 MR. : -- you can be sure that I 6 will do that. 7 BY MR. LUTTIER: 8 Q. All right. Well, if we add and we 9 add 15 years to it, we get to M ; do you agree 10 with that? file:///D/...20[SUBJECPY•20T0%20PROTECTIVE%200RDER%20PARAGRAPHS%207,%208,%209,%2010,%20 I 5,%20and.420 I ?limp/10/2025 3:06:21 PMJ EFTA_00008182 EFTA00159034 11 A. I guess, yeah. 12 Q. Okay. All right. So, that would make you 13 15 when you went to Mr. Epstein's the first time, 14 wouldn't it? 15 A. I thought it was 14. 16 Q. But you agree with the math? 17 A. I don't know. I didn't watch you do your 18 math. 19 Q. Okay. All right. You allege in your 20 complaint two incidents in each month from late, 21 late May or early June of. through August of- 22 that you went to Mr. Epstein. In fact, you, you 23 don't have a specific record of when you actually 24 went to Mr. Epstein; is that right? 25 A. That's right. 135 1 Q. You -- and this is, this complaint only 2 contains what you, your estimate is of when you 3 actually went, correct? 4 A. Right. 5 Q. Might have gone fewer times; might have 6 gone more times? 7 A. I know I went over 100 times. 8 Q. How do you know you went over 100 times? 9 Did you count? 10 A. Because I was there. 11 Q. Do you have some place that you recorded file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008183 EFTA00159035 12 it? 13 A. No. 14 Q. You added it up and got to 100? 15 A. No. 16 Q. So, that's just an estimate on your 17 behalf? 18 A. Yes. 19 Q. You allege in your complaint that you went 20 twice a month for every month between June of. 21 and August of.. Do you know whether or not 22 Mr. Epstein was, in fact, in Palm Beach every month 23 between June of sand August of.? 24 A. I don't know. 25 Q. Do you know whether or not Mr. Epstein was 136 1 gone from Palm Beach County -- 2 A. I didn't -- 3 Q. -- for substantial periods of time during 4 the period from June of. to August of .? 5 A. I know that he'd go back and forth to 6 different places, but when he was in Palm Beach, I would 7 get a phone call. 8 Q. Do you know whether or not it was any 9 continuous period of time when he was not in Palm 10 Beach County between June of. and August oft 11 A. I don't know. I would get a phone call when file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008184 EFTA00159036 12 he was in Palm Beach. 13 Q. Would you -- but you would agree that if 14 he wasn't in Palm Beach, you didn't see him? 15 A. Correct. 16 Q. And you would agree that it's, that it's, 17 that it's possible that Mr. Epstein was gone during 18 periods of time that you claim you went to see him? 19 A. I can't claim anything if I don't know. 20 Q. You would agree with me that you cannot 21 recall the specifics of each visit that you had at 22 Mr. Epstein's home? 23 A. I don't remember the times and dates, but I 24 can tell you everything that happened while I was there. 25 Q. In your complaint in each count you allege 137 1 that you went to Mr. Epstein's at his request? 2 A. Uh-huh. 3 Q. In fact Mr. Epstein himself did not 4 contact you on each occasion and request you to 5 come, did he? 6 A. No. He would have or Maxwell call me. 7 Q. Well, there were also occasions when no 8 one from Mr. Epstein called, but rather you called 9 Mr. Epstein's and asked to go? 10 A. Yes. 11 Q. And that was because you wanted to go and 12 earn some money, correct? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008185 EFTA00159037 13 A. Yes. 14 Q. On each occasion that you went to 15 Mr. Epstein's, you went there voluntarily, correct? 16 A. Yes. 17 Q. On each occasion that you went to 18 Mr. Epstein's whatever acts you performed, you 19 performed them voluntarily, correct? 20 MR. : Excuse me. Let me state for 21 the record that there is no allegation of any 22 physical coercion. There is no allegation that 23 any third party compelled to engage in 24 those acts in which she engaged with 25 Mr. Epstein. 138 1 It is our contention that was 2 legally incapable of consenting to the sexual 3 misconduct in which Mr. Epstein engaged as a 4 consequence of her minority. So, maybe that 5 helps to narrow your questioning down some. 6 MR. LUTTIER: All right. So, you will 7 stipulate that neither Mr. Epstein nor anyone 8 else forced against her will to perform 9 any act; it's simply your position that given 10 her age, she could not have consented to those 11 acts? 12 MR. : That's correct. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008186 EFTA00159038 13 MR. LUTT1ER: Okay. 14 MR. : She was, she was bribed to 15 engage in that conduct; that is, she was paid 16 very large sums of money and she engaged in 17 those acts without having the legal capacity to 18 consent as a consequence of the large sums of 19 money that were offered to her as well as other 20 gifts. 21 MR. CRITTON: Ain't going to work. He, in 22 essence, he gave a speech. 23 MR. LUTT1ER: Yeah, that, I move to strike 24 that part. We were talking about a 25 stipulation. 139 1 MR. : You can move to strike 2 anything you want to, but it's on the record. 3 MR. LUTT1ER: Well, I move to strike it so 4 if it gets played to the jury, it doesn't get 5 played. 6 BY MR. LUTT1ER: 7 Q. In each count of your complaint you allege 8 that on the occasions that you went to Mr. Epstein's 9 you were paid in excess of $200. Do you know how 10 much you were paid on each occasion? 11 A. Between 200 and $300. 12 Q. How do you know which times you got paid 13 200, and which times you got paid more than 200, if file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008187 EFTA00159039 14 you know? 15 A. I remember. 16 Q. Well, how many times were you paid 200? 17 A. I was paid $200 two times and $300 the rest. 18 Q. Is there a reason why in your complaint 19 you then alleged that after the two, first two 20 visits you were simply paid in excess of $200 as 21 opposed to alleging you were paid 300? 22 A. What? 23 Q. In your complaint you just say you were 24 paid in excess of 200? 25 A. Where are you in this complaint, man? 140 1 Q. You can pick any page you want. I happen 2 to be looking at Page 84 but -- 3 MR. : Well, the form of the 4 question is improper. This an unverified 5 complaint. If you have a question about the 6 underlying facts, then you should ask the 7 question about the underlying facts. But a 8 reference to the complaint is not relevant or 9 material or reasonably calculated to lead to 10 the discovery of admissible evidence. 11 We would be happy to answer questions 12 about the underlying facts. 13 BY MR. LUTTIER: file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008188 EFTA00159040 14 Q. You, you — were you ever paid less than 15 $200. 16 A. No. 17 Q. Have you ever told anyone you were paid 18 less than $200? 19 A. No. 20 Q. What did you do with the money that you 21 were paid? 22 A. I bought things until I bought drugs. 23 Q. What kinds of things did you buy with the 24 money? 25 A. Clothes, things for my mom, things for school. 141 1 Q. Did you enjoy the things that you bought 2 with the money? 3 A. Yeah. 4 Q. Did you want to -- after the first time 5 you went to Mr. Epstein's, did you want to go back 6 and continue to perform massages and earn money? 7 A. Yeah. 8 Q. What did you say, yes? 9 A. Yes. 10 Q. Did you enjoy the occasions when you went 11 to Mr. Epstein's? 12 A. Yes. Like enjoyed collecting the money, yes. 13 Q. Well, you enjoyed what you were doing, 14 didn't you? You enjoyed spending time with him? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008189 EFTA00159041 15 A. Not exactly spending time with him. I enjoyed 16 going to be able to collect that much money. 17 Q. Is it a fact that Mr. Epstein treated you 18 better than many of your own acquaintances treated 19 you? 20 A. No. 21 Q. Did he treat you better than your own 22 boyfriends treated you? 23 A. No. 24 Q. You had boyfriends that, that beat you up, 25 didn't you? 142 1 A. Yeah, but that doesn't mean that he treated me 2 better than my boyfriends treated me. 3 Q. Mr. Epstein ever beat you up? 4 A. No. 5 Q. You had a boyfriend that held a gun to 6 your head, didn't you? 7 A. Yes. 8 Q. Mr. Epstein never did that? 9 A. No. 10 Q. Would you agree with me that Mr. Epstein's 11 conduct towards you was better than your boyfriend's 12 conduct towards you when he beat you up and held a 13 gun to you? 14 A. I suppose, but Mr. Epstein never -- I don't file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008190 EFTA00159042 15 see how that would -- 16 Q. Did you -- have you alleged in your 17 complaint everything that occurred when you went to 18 Mr. Epstein's? 19 MR. : I'm going to object to the 20 form of that question. It is vague, overly 21 broad, ambiguous, and improper in its reference 22 to the contents of the complaint. We'll be 23 happy to answer any questions you may have 24 regarding the underlying facts. 25 MR. LUTTIER: Well, my question stands. 143 1 BY MR. LUTTIER: 2 Q. Did you allege everything that occurred -- 3 MR. : I am going to instruct -- 4 MR. LUTTIER: -- when you were at 5 Mr. Epstein's without going though every 6 word -- 7 MR. : I am going to instruct 8 not to answer that question. It's 9 really not susceptible of a response. 10 BY MR. LUTTIER: 11 Q. In your complaint -- all right. Let me, 12 let me ask you about the first time that you went to 13 Mr. Epstein's. 14 A. Uh-huh. 15 Q. Were you fully clothed during the entire file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008191 EFTA00159043 16 period of time that you were there? 17 A. No. 18 Q. For, for what period of time were you 19 fully clothed? 20 A. For the first half hour. 21 Q. Then what happened? 22 A. He asked me to take off my shirt. 23 Q. And what did you tell him? 24 A. Okay. 25 Q. Did you tell him you didn't want to? 144 1 A. Yeah. 2 Q. And what did he say? 3 A. I would get extra money if I did. 4 Q. Did you say you still didn't want to? 5 A. Yeah, but I also wanted the extra money. 6 Q. So he didn't, he didn't force you to do 7 it? 8 A. No, he bribed me to do it. 9 Q. Okay. And how much were you originally 10 going to get paid on the first occasion? 11 A. $200. 12 Q. And what did he say to you about any 13 additional money? 14 A. That if I took off my shirt, he would give me 15 extra money. So therefore he bribed me into taking off file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008192 EFTA00159044 16 my clothes for money. 17 Q. So, how much did you get paid on the first 18 visit? 19 A. $300. 20 Q. So, your testimony earlier that the first 21 two visits you only got two paid 200 is incorrect? 22 MR. : That wasn't her testimony. 23 I think you misunderstood her testimony. 24 MR. LUTTIER: Was it a form objection? It 25 was what her testimony was, but I am not going 145 1 to argue with you. 2 MR. : I disagree. That's not the 3 way I recall it, but the record is what the 4 record is. 5 MR. LUTTIER: Yeah. 6 BY MR. LUTTIER: 7 Q. When you took your shirt off, did you have 8 a bra on underneath? 9 A. Yes. 10 Q. Was it any different than going to the 11 beach in a bathing suit? 12 A. I wasn't at a beach. I was at somebody's 13 house. 14 Q. Was your bra any different than or did it 15 cover less than your bathing suit top? 16 A. No. It covered more than my bathing suit top. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008193 EFTA00159045 17 Q. Yeah. All right. So on the first 18 occasion, other than taking off your shirt off when 19 you had a bra underneath, were you othenvise 20 dressed? 21 A. Yeah. I only had, I only had my jeans and a 22 bra on. 23 Q. Okay. 24 A. Or my shorts. I was wearing shorts. I'm 25 sorry. 146 1 Q. On the -- and that was throughout the rest 2 of the time you were there on the first occasion? 3 A. Uh-huh. 4 Q. On the second - 5 A. Yes. 6 Q. On the second occasion, were you fully 7 dressed? 8 A. No. 9 Q. How were you dressed during the second 10 occasion? 11 A. I was clothed up until I was wearing a bra and 12 underwear. 13 Q. That is you started out to give this 14 massage clothed? 15 A. Yes. 16 Q. And then you removed clothing? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008194 EFTA00159046 17 A. Yes. He asked me if I would take off my 18 clothes, and I told him I didn't feel comfortable 19 getting naked like he wanted me to. So, I only, I 20 stayed in my bra and underwear. 21 Q. So, did he specifically ask you to get 22 naked? 23 A. Yeah. 24 Q. And you said you didn't want to? 25 A. Yeah. 147 1 Q. And he honored that wish? 2 A. Well, after he asked me for five minutes, and 3 I told him no, yeah. 4 Q. Did you tell him that you would be willing 5 to take your shirt and pants off and be in your 6 underwear and your bra? 7 A. Yeah. 8 Q. And then you remained in that state of 9 dress on the second occasion? 10 A. Yes. 11 Q. On the third occasion were you fully 12 dressed? 13 A. No. 14 Q. How were you dressed the third occasion? 15 A. Well, I was fully dressed when I got there, 16 yes- 17 Q. Okay. Did you — were you fully dressed file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008195 EFTA00159047 18 throughout the massage? 19 A. I took off my bra that time. 20 Q. Did he ask you to take off your bra? 21 A. Yeah. 22 Q. And what did you say? 23 A. I, 1, at first I didn't want to, and then I 24 did. 25 Q. Well, when you said you didn't want to, 148 1 did he make you take it off? 2 A. Well, he asked me. He kept asking me to. 3 Q. And you said no, right? 4 A. Yeah. 5 Q. And he honored that, your statement, 6 correct? 7 A. Yeah, but he kept asking me, so I did. 8 Q. He didn't offer you any more money, did 9 he? 10 A. No, but I wasn't going to get the money if 1 11 didn't do it so did I it. 12 Q. Who, who -- why do you say you weren't 13 going to get the money? 14 A. Because he told me I wasn't. 15 Q. What exactly did he tell you? 16 A. He said, well, then, I'm not going to pay you. 17 Q. This is on the third visit? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008196 EFTA00159048 18 A. So I said fine. 19 Q. Was anyone else present for this 20 conversation? 21 A. No. 22 Q. Okay. So you got $300 on that occasion? 23 A. Yeah. 24 Q. And you were topless? 25 A. (Witness nods head.) 149 1 Q. On the fourth time that you went, were you 2 fully dressed? 3 A. I don't remember from, like -- I don't 4 remember the specific fourth, fifth, sixth, seventh, 5 eighth times I was there. So, if you're going to 6 continue on the fifth and the sixth and the seventh, I'm 7 not -- I don't remember so -- 8 Q. Well -- 9 A. I am trying to help you out here. 10 Q. Is it true that when you went, you 11 voluntarily removed your clothes? 12 A. He bribed me with money. 13 Q. Wait a minute. You, you told me that the 14 most you got was 300 and you got that by the third 15 visit, correct? 16 A. Yeah. So — 17 Q. So — 18 A. I guess, yes, it would be voluntarily I took file:///D/...20[SUBJECPY•20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008197 EFTA00159049 19 my clothes off. 20 Q. Were you -- did there come a time that 21 when you went to give a massage, would you just go 22 over there and take all your clothes off before you 23 started the massage? 24 A. He asked me to take my clothes off. 25 Q. At the beginning of the massage? 150 1 A. Yeah. 2 Q. All right. And you said okay? 3 A. Yeah. 4 Q. Was there ever a time that you said, I 5 don't want to, and he said, no, you have to? 6 A. Yeah, there were times where he said that. 7 Q. Okay. And did you not take them off? 8 A. No, l took them off. 9 Q. Well, when did he say you had to take your 10 clothes off? 11 A. When he told me I have to take my clothes off 12 Q. And, and but did you just remove your 13 clothes, or did you say I don't want to? 14 A. I said I don't want to. 15 Q. Did you leave? 16 A. And he said, well, can you remove your 17 clothes? 18 Q. And what you did say then? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008198 EFTA00159050 19 A. I said 1 would prefer not to, but I did it 20 anyways. 21 Q. Okay. He didn't force you to do it 22 though? 23 A. If he -- he didn't physically take them off of 24 me, no. 25 Q. You could have left. Nothing prevented 151 1 you from leaving? 2 A. Right. 3 Q. You said that some friend of yours named 4 • • whose last name you can't remember, 5 took you there for the first time? 6 A. Yeah. 7 Q. How did you know this person, IM • 8 9 A. Through friends of mine. 10 Q. What friends? 11 A. My, my son's father, MB and his 12 friend. It was his friend, his friend's girlfriend. 13 Q. Okay. It was 14 was friend girlfriend? 15 A. Yes. 16 Q. Who was friend? 17 A. 18 Q. Did you know from 19 anyplace? • IM file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008199 EFTA00159051 20 A. No. I knew him from went to 21 school him. 22 Q. Okay. And this MI was 23 girlfriend? 24 A. Yes. 25 Q. When did she -- how was it that she came 152 1 about taking you over to Epstein? 2 A. She asked me. 3 Q. And when did she ask you in relationship 4 to when you went? 5 A. What do you mean? 6 Q. Well, was it the day before you went that 7 she asked you? 8 A. No, it was the same day. 9 Q. So, was that the first time she asked you? 10 A. Yeah. 11 Q. So, the day that you went, sometime 12 earlier that day, she asked you if you wanted to do 13 what? 14 A. She didn't explain to me what was going to 15 happen. All she said was a friend of mine, we can go 16 over there. You give him a massage and he will pay. 17 Q. Did you know how old he was? 18 A. No. 19 Q. And did she tell you, did she tell you file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMI EFTA_00008200 EFTA00159052 20 anything about roughly how old he was? 21 A. She said he was older. 22 Q. Okay. And what did you understand that to 23 mean? 24 A. He was older than me. 25 Q. And when you got there, you saw him, 153 1 correct? 2 A. Yeah. 3 Q. Could have left at that point, right? 4 A. Oh, well, not exactly, because being that I 5 that was her car and I didn't know where the hell I was. 6 Q. Did you tell MIMI when you saw 7 Mr. Epstein, stop, 1 don't want to do this. 8 A. No, because I didn't know I was going to have 9 to remove any clothes. 10 Q. All right. Did she tell you anything 11 other than you were going to go over and give a 12 massage to an older man? 13 A. No. 14 Q. Certainly after the first time you knew 15 what was involved, right? 16 A. Not exactly. I didn't know I was going to 17 have to get naked in the future. 18 Q. Well, at the very first time after you 19 left there, you knew what that incident involved 20 because you just experienced it, right? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_0000820 I EFTA00159053 21 A. Well, he only -- he never forced me to take 22 off my clothes other than -- yes, I took off my shirt 23 and I stayed in my bra and my jeans. 24 Q. Right. My point is that after the first 25 time, if you didn't want to, you could have simply 154 1 said I am not going back under any circumstances, 2 right? 3 A. Right, but -- 4 Q. Okay. Now, when this • 5 took you over, after you left did — what did you 6 tell her, if anything, about having been there? 7 A. I didn't really talk to her about it. 8 Q. Did IM • give you any kind of 9 drug before you went there? 10 A. No. 11 Q. Did you give MM any of the 12 money that you received when you went there the 13 first time? 14 A. No. 15 Q. Did I. MI get paid to take you 16 there the first time, do you know? 17 A. I have no idea. 18 Q. Did there, did you go with MI 19 on more than one occasion? 20 A. No. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008202 EFTA00159054 21 Q. The second time you went did anybody take 22 you there? 23 A. No. 24 Q. Have you ever told anyone that you went 25 with or that took 155 1 you there on more than one occasion? 2 A. No. 3 Q. Had, did anyone else ever take you to 4 Mr. Epstein's, any other girl other than 5 6 A. No. 7 Q. And why is it that, under, under what set 8 of circumstances did you go back to Mr. Epstein's 9 without going with MM? 10 A. Because Mr. Epstein asked me for my phone 11 number and I gave it to him and he called me for me to 12 go over there. 13 Q. Did you and ever have a 14 disagreement about that fact? 15 A. No. 16 Q. Did you know that M. I was 17 getting paid money take you there? 18 A. No. 19 Q. Did there come a time that you asked 20 others to go to Mr. Epstein's? 21 A. Yes. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008203 EFTA00159055 22 Q. And for how long had you been going to 23 Mr. Epstein's before you asked someone else to go? 24 A. Couple of months, more — well, I can't — a 25 couple, more than two. 156 1 Q. And at the point in time that you asked 2 someone to go, had you, had you performed massages 3 for Mr. Epstein totally nude? 4 A. Yes. 5 Q. What else had occurred during your 6 massages with Mr. Epstein at the point in time that 7 you asked others to go? Do you understand my 8 question? 9 A. No. 10 Q. All right. You, you had been giving him 11 massages in the nude, right? 12 A. Uh-huh. 13 Q. Anything else? 14 A. Has anything else happened while I was there? 15 Q. Up to that point in time involving you? 16 A. He had some girl eat me out and he had sex 17 with her. 18 Q. And that was before you asked someone else 19 to go? 20 A. Yeah. 21 Q. And do you recall when that was? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008204 EFTA00159056 22 A. I don't remember the dates and times. 23 Q. Have you ever told anyone prior to today 24 that that event occurred? 25 A. Besides my attorneys, no. Oh, and those 157 1 people I talked to, the FBI and the state people. 2 Q. Do you remember me asking as there is 3 nothing in your complaint about this. So, do you 4 know why that would be? 5 MR. : That's an improper question. 6 You don't need to answer that. 7 MR. LUTTIER: Did you review — 8 MR. : It's not required, it's not 9 required to be in her complaint. The 10 suggestion that it is improper. Questioning 11 her about the contents of the complaint is 12 improper. 13 MR. LUTTIER: If you want to tell her not 14 to answer, that's fine. We don't need to go 15 through it. 16 MR. : That's fine. 17 BY MR. LUTTIER: 18 Q. Did you read the complaint before it was 19 filed? 20 A. Yeah, I read the complaint. 21 Q. Did you -- when you read the complaint did 22 you notice there was anything missing from it? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008205 EFTA00159057 23 A. No, I trust my attorneys. That's why they're 24 my attorneys. 25 Q. Did you tell anyone, your lawyers or 158 1 anybody else that there was, there were other facts 2 and circumstances that weren't included -- 3 MR. : Don't answer that question. 4 That is obviously a privileged communication. 5 BY MR. LUTTIER: 6 Q. All right. When did this event happen 7 where you say there was another girl involved? 8 A. I just told you I didn't know the dates and 9 times. 10 Q. Well, you said that, correct me if I am 11 wrong -- well, let me rephrase the question. 12 Approximately how many months had you been going 13 before you asked someone else, or took somebody else 14 there? 15 A. I don't know. More than two months. 16 Q. More than two. Anything more specific? 17 Could it have been a year? 18 A. Three, four, five, maybe even six months. 19 Q. All right. So, sometime within the first 20 six months this event happened involving this other 21 girl? 22 A. Yeah. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008206 EFTA00159058 23 Q. All right. Tell me the facts and 24 circumstances that occurred on that occasion 25 starting with when you went to Mr. Epstein. 159 1 A. I got there and some other girl came in and 2 said she was going to help me. And -- or he came in and 3 introduced me to her. He took a shower. She said she 4 was going to help me do the massage. And the next thing 5 I know, that's what was happening. 6 Q. Well, who was this person? 7 A. I don't remember her name. She was really 8 pretty, though. 9 Q. Had you ever seen her before? 10 A. No. And I have never seen her again. 11 Q. Did she identify herself to you? 12 A. I don't remember her name. 13 Q. At the time did she introduce herself to 14 you? 15 A. Yes. 16 Q. Did she say who she was? 17 A. Yes. 18 Q. What did she say? 19 A. I don't remember her name. 20 Q. Okay. Other than her name did she say -- 21 A. She said hi, I'm — and I am going to help you 22 today. 23 Q. She didn't say, for example, I am the lawn file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008207 EFTA00159059 24 man here or something like that? She didn't 25 identify what her status or position was, if any? 160 1 A. I just told you no. 2 Q. Okay. 3 A. I just told you what she said to me. 4 Q. Okay. So, this, this, a girl is in the 5 room. Mr. Epstein takes a shower. What occurs 6 next? 7 A. I was standing there ready for him to like lay 8 on the massage table. And she got down on her knees and 9 started eating me out. 10 Q. Were you dressed at the time? 11 A. No, I was naked. 12 Q. Had you removed your clothes voluntarily 13 at that point? 14 A. Yes. 15 Q. Was this other woman dressed! 16 A. No, she was naked too. 17 Q. When did she get naked in relationship to 18 when you came in the room? 19 A. She came into the room and Mr. Epstein asked 20 us to get naked and he got into the shower. So we were 21 already naked by the time he got out of the shower. 22 Q. Okay. So, that, did that, the fact that 23 this other girl was naked in the room cause you, did file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008208 EFTA00159060 24 you say anything like I want to leave or -- 25 A. No. 161 1 Q. Did you ask her any questions? 2 A. No. 3 Q. Seem unusual to you? 4 A. No. 5 Q. Okay. Wasn't the first time you saw 6 another woman naked, right? 7 A. No. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008209 EFTA00159061 25 1( 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008210 EFTA00159062 25 Q. So, a one-year period? 163 1 2 3 4 5 6 7 8 9 1 11 12 13 14 15 16 17 18 19 2 21 22 23 24 25 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008211 EFTA00159063 164 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 16 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008212 EFTA00159064 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 * * * * * 22 23 24 25 file:///D/...20[SUBJECPY*20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008213 EFTA00159065