EFTA00101322

Page 141 
1 
A. 
No. 
2 
Q. 
-- where he believes money was taken? 
3 
MR. CRITTON: Form. 
4 
THE WITNESS: I don't agree with this. 
5 
BY MR. BERGER: 
6 
Q. 
No? 
7 
A. 
No. 
8 
Q. 
Well, he says: "The first" -- at the bottom, 
9 
it says: "The first was over Labor Day weekend, August 
10 
30 to September 1, 2003." 
11 
You see it says that at the bottom? The very 
12 
bottom. 
13 
"The first was over Labor Day weekend, 
14 
August 30 to September 1, 2003." 
15 
Do you see that? 
16 
A. 
Uh-huh 
17 
Q. 
Yes or no? 
18 
A. 
Yes. 
19 
Q. 
And then it says: "The second time was a 
20 
weekend in mid-September 2003." 
21 
Do you see that? 
22 
A. 
Yes. 
23 
Q. 
And then above, do you see where he talked 
24 
about October 4, 2003? You see mention of that? Or 
25 
October 5, 2003? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend (401.377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000417 
3afc3ca0-c86e-4b91-8d01-ba2Obcart87de 
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Page 142 
1 
A. 
Right here. 
2 
Q. 
Right in the middle, it says: "Epstein stated 
3 
at" -- yes. 
4 
A. 
No. I don't agree with this. I never saw 
5 
this. 
6 
Q. 
I'm not asking -- that's not what I'm asking. 
7 
What I'm saying, sir, do you see though that 
8 
the police report refers to three instances; is that 
9 
correct? 
10 
A. 
No. 
11 
Q. 
Okay. But it's correct that the police report 
12 
refers to three instances, correct? 
13 
MR. CRITTON: Form. 
14 
BY MR. BERGER: 
15 
Q. 
The police talk about three instances, right? 
16 
A. 
That's correct. 
17 
MR. CRITTON: Form. 
18 
BY MR. BERGER: 
19 
Q. 
Now, how many times did you take cash from 
20 
Mr. Epstein? 
21 
A. 
Twice. 
22 
Q. 
So do you have any idea what he's talking 
23 
about here? 
24 
A. 
No. 
25 
Q. 
Now, the first time that you took cash, was it 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Tow9A5lAdantgaltl I CYMant Requested / Fed. eatc3ca0-c86e-4b9f-8d01-ba20bcae87de 
GJ SUBPOENA RESPONSE 000418 
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Page 143 
1 
on August 30 to September 1, 2003? 
2 
A. 
I can't remember. 
3 
Q. 
Or September -- mid-September 2003? 
4 
A. 
I can't remember. 
5 
Q. 
Okay. Is the third incident accurate where it 
6 
talks about October 5 or October 4, 2003? 
7 
A. 
I don't know if it's accurate or not, but I 
8 
know that I went to the house twice. 
9 
Q. 
Not three times? 
10 
A. 
Not three times. 
11 
Q. 
Any idea why Mr. Epstein would talk about 
12 
three times? 
13 
A. 
No idea, sir. 
14 
Q. 
And any idea why he would talk about a Glock 
15 
handgun? 
16 
A. 
No, sir. 
17 
MR. CRITTON: Form. 
18 
BY MR. BERGER: 
19 
Q. 
Now, you said that -- that you had a -- okay. 
20 
I've put this aside. I'm going to ask you another 
21 
question, so why don't you -- I don't want to distract 
22 
you. 
23 
Now, you said that your disagreement or your 
24 
falling out with Mr. Epstein was after you left his 
25 
employment. Do you remember saying that? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377.676.2895) 
Electronically signed by Sandra Townsend 1401-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000419 
MOces-aft4b91-801-baNbcaerde 
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Page 144 
1 
A. 
Yes. After -- after this incident. 
2 
Q. 
And what did that disagreement have to do 
3 
with? Did it have to do with these incidents? 
4 
A. 
Of course. I screw it up. 
5 
Q. 
Okay. And do you know who Mr. Adam Fetterman 
6 
is? 
7 
A. 
Yes. 
8 
Q. 
Who is he? 
9 
A. 
He's my lawyer. 
10 
Q. 
And did Mr. Epstein pay for Mr. Fetterman's 
11 
legal services for you? 
12 
A. 
No. I pay on my own pocket. 
13 
Q. 
Now, let me ask you some questions about some 
14 
property in Palm Beach County, 
15 
Do you remember that in or around 1983 you and 
16 
your wife bought a home at 
n Royal Palm 
17 
Beach? 
18 
A. 
I didn't bought it. I build it. 
19 
Q. 
You built it. You didn't buy it? 
20 
A. 
No. 
21 
Q. 
And do you remember that in April of 1995, you 
22 
and your wife purchased a single-family home in -- on 
23 
n Wellington? Do you remember 
24 
that? 
25 
A. 
It was a lot. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377.676.2895) 
Electronically signed by Sandra Townsend (401-377476-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000420 
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Page 145 
1 
Q. 
It was a lot. Okay. 
2 
A. 
Yes, we purchase that. 
3 
Q. 
Okay. 
4 
MR. CRITTON: What was the first date you gave 
5 
about built home? 
6 
MR. BERGER: July 1983. 
7 
MR. CRITTON: Thank you. 
8 
BY MR. BERGER: 
9 
Q. 
And does the purchase price of $22,600; is 
10 
that correct --
11 
A. 
Sounds familiar. 
12 
Q. 
-- for the -- for the 
13 
lot; is that correct? 
14 
A. 
Uh-huh. 
15 
Q. 
Yes or no? 
16 
A. 
What date was that? 
17 
Q. 
April of 1995. 
18 
A. 
That's correct. 
19 
Q. 
Now, do you recall that in December of 1997 
20 
you and your wife bought apartment number 1902 at 
21 
22 
A. 
That's correct. 
23 
Q. 
-- in West Palm Beach; is that right? 
24 
A. 
Yes, sir. 
25 
Q. 
And does the purchase price of $105,000; is 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) B32-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend (401377-676.2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000421 
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EFTA00101386

Page 146 
1 
that accurate? 
2 
3 
4 
5 
6 
7 
8 
9 
Q. 
you 
A. 
That's correct. 
Q. 
Now, do you recall that in November of 1998 
and 
A. 
Q• 
A. 
your wife bought apartment 1901 at 
Yes. 
And the purchase price was $159,000? 
That's correct. 
So in -- so did you -- as of November of 1998, 
10 
did you own both apartment 1902 and apartment 1901 at 
11 
12 
13 
Beach. I didn't -- I sold that. With that money we 
14 
bought that apartments. 
15 
Q. 
You built the house at the Royal Palm Beach 
16 
address? 
17 
A. 
Yes. 
18 
Q. 
After buying the lot? 
19 
A. 
Yes. We bought the lot years, years back. 
20 
Q. 
Now, in October of 2001, do you remember 
21 
buying a multi-family residential property at 
22 
n Wellington? 
23 
A. 
I still have it. 
24 
Q. 
And do you remember the purchase price being 
25 
$310,000? 
A. 
Yes 
But I didn't own the house in Royal Palm 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Towng8Weglagii616.-289 
I reagent Requested / Fed. 
GJ SUBPOENA RESPONSE 000422 
fc3ca0-c86e-4b9f-13d01-ba20bcae87de 
EFTA00101387

Page 147 
1 
A. 
Yes, sir. 
2 
Q. 
And this is while you worked for Mr. Epstein, 
3 
correct? 2001, October 2001? 
4 
A. 
Yeah. 
5 
Q. 
And you still own it; is that what you said? 
6 
A. 
Yes. 
7 
Q. 
And is that a rental apartment building? 
8 
A. 
Yeah, it's a rental. 
9 
Q. 
And now, do you recall that in September of 
10 
2002 you and your wife purchased a multi-family 
11 
residential property at 
West Palm 
12 
Beach? 
13 
A. 
That's correct. 
14 
Q. 
And the purchase price was $590,000? Do you 
15 
remember that? 
16 
A. 
Yes. 
17 
Q. 
And then in October of 2004 you bought the --
16 
you bought a multi-family residential property -- strike 
19 
that. 
20 
In October of 2004 your wife purchased a 
21 
multi-family residential property 
22 
Drive, Boynton Beach? 
23 
A. 
That is not correct. That is a house. 
24 
Q. 
That's where you live now? 
25 
A. 
That's where we live now. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra 
Mni
T"n
g8IX aiitTentraiefr2e8aVent Requested / Fed. 
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atc3ca0-c86e-4b91-8d01-ba20bcao87de 
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Page 148 
1 
Q. 
And that's just a single-family home? 
2 
A. 
That's a single-family home. 
3 
Q. 
Okay. And now, did Mr. Epstein contribute any 
4 
money to the purchase of any of these properties? 
5 
A. 
He contribute the -- he contribute the $20,000 
6 
towards the purchase of the first property. 
7 
Q. 
Well, the first property was back in 1983? 
8 
A. 
No. No. The first property at 
9 
10 
Q. 
That's apartment 1902? 
11 
A. 
1902. 
12 
Q. 
Did he contribute any other money towards any 
13 
of the other properties? 
14 
A. 
No. 
15 
Q. 
So you paid $590,000 for the property at 
16 
without the assistance of Jeffrey Epstein? 
17 
A. 
That's correct. I had a loan, took a big loan 
18 
on that. 
19 
Q. 
So he had absolutely nothing to do with your 
20 
purchase of that property? 
21 
A. 
Nothing. 
22 
Q. 
And he contributed nothing towards any 
to 
23 
the purchase of any of the other properties that I 
24 
mentioned? 
25 
A. 
Nothing. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townwg e1Sgraigerest en[ Requested! Fed. 
afc3ca0-c869-4b91-8d01-ba20bcae87de 
9.11Tr
GJ SUBPOENA RESPONSE 000424 
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Page 149 
1 
Q. 
Okay. 
2 
MR. BERGER: Mark this as Exhibit 4, please. 
3 
(Exhibit number 4 was marked for 
4 
identification purposes.) 
5 
BY MR. BERGER: 
6 
Q. 
Look at Exhibit 4, sir. It's two pages. And 
7 
it's from Florida Department of State, Division of 
8 
Corporations? 
9 
A. 
Yeah. 
10 
Q. 
And would you turn to the next page, the 
11 
second page? 
12 
On the second page, do you see your signature 
13 
and your wife's? 
14 
A. 
Yes. 
15 
Q. 
And do you recognize this as an application 
16 
for registration of a fictitious name? 
17 
A. 
Yes. 
18 
Q. 
And is that -- did you and your wife apply for 
19 
registration of a fictitious name? 
20 
A. 
Right. This was done by our lawyer, 
21 
Fetterman. 
22 
Q. 
And was that done in January of 2003? Look in 
23 
the upper right. 
24 
A. 
Yes. 
25 
O. 
Is that correct? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra TownpiNg elgrbiagirap.}289 
eatr5nent Requested / Fed. 
GJ SUBPOENA RESPONSE 000425 
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EFTA00101390

Page 150 
1 
A. 
Uh-huh. 
2 
Q. 
Yes? 
3 
A. 
Yes. 
4 
Q. 
And the fictitious name wa 
5 
Properties, correct? 
6 
A. 
That's correct. 
7 
Q. 
And did Jeffrey Epstein have anything 
8 
whatsoever to do with the registration of this 
9 
fictitious name? 
10 
A. 
Absolutely nothing. 
11 
MR. BERGER: Mark this as the next Exhibit. 
12 
13 
14 
15 
16 
17 
18 
19 
Q. 
The next Exhibit, sir, has 
20 
Department of State, Division of 
21 
see it makes reference t 
22 
the top. 
23 
24 
name." And then under that it says, "Florida limited 
25 
liability company." 
(Exhibit number 5 was marked for 
identification purposes.) 
MR. WILLITS: Spell the name of that last --
MR. BERGER: It's 
Properties. 
MR. WILLITS: Thank you. 
BY MR. BERGER: 
Corporations. 
papers from the 
Do you 
Up at 
It says: "Detail by officer/registered agent 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377476-2895) 
Electronically signed by Sandra 
ri 1441
Thvin 3lAe-i5tilignig6Irgagellent Requested / Fed. 
GJ SUBPOENA RESPONSE 000426 
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Page 151 
1 
A. 
Where is that, sir? Just point it. 
2 
Q. 
Then it says, 
is that 
3 
right? 
4 
A. 
Yes, sir. 
5 
Q. 
Then do you see the next couple pages includes 
6 
a letter from Adam Fetterman to the Department of State? 
7 
Do you see that? 
8 
A. 
Yes, sir. 
9 
Q. 
And then the next -- the next page is an 
10 
articles -- articles of organization for Florida limited 
11 
liability company. Do you see that? 
12 
A. 
Yes, sir. 
13 
Q. 
And then on the very last page, is that your 
14 
signature? 
15 
A. 
Yes, sir. 
16 
Q. 
Okay. Is that your application to organize 
17 
the Florida limited liability company, 
18 
19 
A. 
Yes. I just sign it. This was done by the 
20 
lawyer. 
21 
Q. 
Did Jeffrey Epstein have anything to do with 
22 
the creation of this company? 
23 
A. 
Absolutely nothing. 
24 
Q. 
Did Jeffrey Epstein pay for Mr. Fetterman's 
25 
services to do this? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townpg 81813/4616289 ) 
ireatgrent Requested / Fed. 
GJ SUBPOENA RESPONSE 000427 
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Page 152 
1 
A. 
Absolutely no. 
2 
Q. 
Now, this was -- thi 
3 
4 
Do you recall that? Does that sound correct? 
5 
A. 
Yeah. 
6 
Q. 
And 
7 
Mr. Epstein's employment, and August of 2003, when you 
8 
incorporate 
9 
Jeffrey Epstein? 
10 
A. 
Never spoke 
11 
Q. 
Or with anybody on 
12 
staff or an investigator for him? Anybody? 
13 
A. 
Nothing. 
14 
Q. 
Okay. Did you go to his home between January 
15 
and August of 2003? 
16 
A. 
No. Except twice, the two incidents that it 
17 
happened. 
18 
Q. 
But those -- and those happened later, after 
19 
August of 2003, correct? Those happened either --
20 
A. 
Yeah. I never went to the home for any reason 
21 
to talk to him or to anybody. 
22 
Q. 
Okay. So in September and October when you 
23 
went to Mr. Epstein's house --
24 
A. 
Yeah. 
25 
Q. 
-- uninvited, --
2003. 
it appears to have been incorporated in August of 
between December 
again. 
of 2002, 
his 
when 
id you 
you left 
speak to 
behalf, such as his 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377.676.2895) 
Electronically signed by Sandra Townsend (401-377-676.2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000428 
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Page 153 
1 
A. 
Uh-huh. 
2 
Q. 
-- you just assumed that he would have money 
3 
in his briefcase? 
4 
A. 
I assume. 
Q. 
You hadn't talked to him in nine months; is 
6 
that your testimony? 
7 
A. 
That's my testimony. 
8 
Q. 
And you said that you needed that money 
9 
because of a woman that you were mixed up with? 
10 
A. 
That's correct. 
11 
Q. 
What's her name? 
12 
A. 
13 
Q. 
And where does she --
14 
A. 
I'm sorry. 
15 
already forgot the name. 
16 
Q. 
17 
A. 
18 
Q. 
Where is she now? Where does she live? 
19 
A. 
I have no idea. She left -- she left the 
20 
state. She was a girl from Brazil. The biggest mistake 
21 
of my life. 
22 
Q. 
And then you said during the questioning of 
23 
one or two of the attorneys that you entered into a 
24 
separation agreement with Mr. Epstein that included a 
25 
confidentiality agreement and a release. Do you 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra TowinslEM1allitiniFav ent Requested! Fed. 
GJ SUBPOENA RESPONSE 000429 
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Page 154 
1 
remember saying that? 
2 
A. 
Yeah. 
3 
MR. CRITTON: Form. 
4 
BY MR. BERGER: 
5 
Q. 
And those were signed by you? 
6 
A. 
And Mr. Epstein. 
7 
Q. 
And was that signed after the October 
8 
incident? 
9 
A. 
No. This was signed in January 2003. 
10 
Q. 
When you left? 
11 
A. 
Right after I left. 
12 
Q. 
Okay. 
13 
A. 
Right after I left, it was done through the 
14 
office in New York. Mr. Epstein never spoke to me 
15 
again. It was done through the lawyers in New York. 
16 
They send me the paper via Fed Ex. They send us a 
17 
check. That was the end of it. That happened in 
18 
January, January 2003. 
19 
Q. 
Do you have a copy of those documents? 
20 
A. 
Not in here. 
21 
Q. 
Do you have them at home? 
22 
A. 
Yes, I do. 
23 
Q. 
And let me just make sure I know what the 
24 
documents are. 
25 
There's a separation agreement? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend (401.377.676.2895) 
FOIA Confidential Treatment Requested! Fed. 
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Page 155 
1 
A. 
Just a separation agreement. 
2 
Q. 
And that includes a confidentiality provision? 
3 
A. 
It was a 
there's a provision inside. 
4 
Q. 
And it also includes in it a release or is the 
5 
release separate? 
6 
A. 
I don't know. Lawyer terms. I'm not familiar 
7 
with that. 
8 
Q. 
Did you have a lawyer represent you in 
9 
connection with that? 
10 
A. 
No. I never need it. 
11 
Q. 
And you said Mr. Epstein paid you $30,000 to 
12 
you and $20,000 to your wife? 
13 
A. 
That's correct. 
14 
Q. 
And how was that paid to you? 
15 
A. 
Cash -- I mean, check. It was a check but it 
16 
was taken -- taxes were taken out. So it was minus 
17 
taxes. 
18 
Q. 
Was it one check for each of you? 
19 
A. 
Yes. 
20 
MR. CRITTON: Can we take a five-minute break? 
21 
MR. BERGER: Sure. 
22 
MR. CRITTON: Do you want to finish one line 
23 
of questioning? 
24 
MR. BERGER: No, go ahead. Go ahead. 
25 
VIDEOGRAPHER: Off the record at 2:15. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000431 
3atc3ca0-c86e4b9(-8d01-ba2Obcae87de 
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Page 156 
1 
(Brief recess.) 
2 
VIDEOGRAPHER: We're back on the record at 
3 
2:21. 
4 
BY MR. BERGER: 
5 
Q. 
How many times have you talked with 
6 
investigators of Mr. Epstein? 
7 
A. 
One time. 
8 
Q. 
And that's the one time that you've mentioned 
9 
already? 
10 
A. 
Yes. 
11 
Q. 
And have you met -- talked to Mr. Critton 
12 
before today? 
13 
A. 
Oh, wait a minute. Sorry. I have to go back 
14 
on that. Twice. One time when the criminal case 
15 
started when they, like, find the card and Jeffrey says, 
16 
I cannot talk to you, somebody will call you. I talked 
17 
the investigator that I told you. 
18 
And the second time was, I guess, you -- I 
19 
don't know who was it, but they send -- they send me 
20 
the -- I don't know if it was an investigator or they 
21 
just give me your notice that I was going to be 
22 
subpoena. 
23 
MR. CRITTON: I think that came from 
24 
Mr. Willits' office. 
25 
MR. WILLITS: Jack Hill's office. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend (401.377.676.2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000432 
3afc3ca0-c86e-4b91-8d01-ba20bcae87de 
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Page 157 
1 
MR. CRITTON: That wasn't an investigator. It 
2 
was a subpoena server? 
3 
THE WITNESS: Yeah. 
4 
BY MR. BERGER: 
5 
Q. 
Process server. Process server. 
6 
Now, this is Mr. Robert Critton. Have you 
7 
talked to him before today? 
8 
A. 
Yes, sir. 
9 
Q. 
How many times have you talked to Mr. Critton? 
10 
A. 
Once in my house. And we talk about ten 
11 
minutes yesterday? Monday? Monday? 
12 
Q. 
Yesterday? 
13 
A. 
Yesterday. 
14 
Q. 
Okay. And what did you discuss? 
15 
A. 
Discuss the same questions that you telling 
16 
me 
And he told me basically, say the truth. Tell the 
17 
truth, nothing but the truth. And be firm and be --
18 
speak your mind and don't be afraid. 
19 
I thought that this incident about my life 
20 
never would have come out. I wish it would have never 
21 
come out. But I guess it come out and it's too late. 
22 
Q. 
Well, you know what this case is about, don't 
23 
you? 
24 
A. 
Of course. I think it's a case against 
25 
Mr. Epstein. But it's not a case against me, is it? 
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Page 158 
1 
Q. 
No. 
2 
A. 
Oh. 
3 
Q. 
And you know it's 
4 
(Brief interruption.) 
5 
BY MR. BERGER: 
6 
Q. 
And you know it's a serious case for the 
7 
people that are bringing it? 
8 
THE COURT: Form. 
9 
THE WITNESS: Absolutely. 
10 
BY MR. BERGER: 
11 
Q. 
So you had this conversation with Mr. Critton 
12 
yesterday? 
13 
A. 
Not about the seriousness, no. 
14 
Q. 
No. No. But the conversation that you had 
15 
with Mr. Critton was yesterday, correct? 
16 
A. 
Yes. Told him he -- he told me basically he 
17 
was going to be here, that a bunch of lawyers were going 
18 
to ask me questions and that I should be truthful and 
19 
nothing else, basically. 
20 
Q. 
Well, what else did he say? 
21 
A. 
What else did Mr. Critton says? Nothing. He 
22 
asked me about my health, because I was in the hospital 
23 
this week. He asked me how I felt. 
24 
And I says, well, I want to get this done. I 
25 
want to get it over, done, and go on with my life for 
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Page 159 
1 
the rest of my life. I want to finish with this. I 
2 
don't want nothing to do with Jeffrey Epstein or this 
3 
case, once and for all. 
4 
Q. 
Did you talk to him about the confidentiality 
5 
agreement that you mentioned? 
6 
A. 
No. 
7 
Q. 
Or the separation agreement? 
8 
A. 
No. 
9 
Q. 
Or the arrest? 
10 
A. 
No. 
11 
Q. 
Or the $30,000 that you were paid? 
12 
A. 
No. 
13 
Q. 
Did he tell you that this case that we're here 
14 
about --
15 
A. 
$30,000 where? What $30,000? 
16 
Q. 
You said you were paid $30,000 and your wife 
17 
was paid $20,000. 
18 
A. 
Yes. Yes. The separation agreement. No. 
19 
No. 
20 
Q. 
You didn't talk about that? 
21 
A. 
No. 
22 
Q. 
Did he tell you there were young women suing 
23 
Mr. Epstein? Did he tell you that yesterday? 
24 
A. 
No. He mentioned to me that it was a lot of 
25 
lawsuits against Mr. Epstein, criminal and civil suits. 
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Page 160 
1 
And -- not yesterday, but when he was in my house with 
2 
his secretary. 
3 
Q. 
Not yesterday? 
4 
A. 
Not yesterday. 
5 
Q. 
When was he was at your house with the 
6 
secretary? 
7 
A. 
About two months ago, a month and a half ago. 
8 
Q. 
You can't look to him to answer. You've got 
9 
to answer. 
10 
A. 
I cannot remember exactly the date, but I 
11 
would say it was about a month ago. 
12 
Q. 
Maybe I misunderstood. Was Mr. Critton at 
13 
your house yesterday? 
14 
A. 
No. He called me yesterday. 
15 
Q. 
He called you yesterday? 
16 
A. 
Yes, sir. 
17 
Q. 
And you talked for about ten minutes yesterday 
18 
on the phone? 
19 
A. 
No more. 
20 
Q. 
Did you tell me everything that you and 
21 
Mr. Critton talked about yesterday? 
22 
A. 
Yes. 
23 
Q. 
Now, he visited your house --
24 
A. 
Yes. 
25 
Q. 
-- a month and a half or two months ago --
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