EFTA00182418

22 
correct? 
23 
MR. PIKE: Form. 
24 
A. I refuse to answer. 
25 
Q. Because the only real disqualifications for 
0097 
1 
interacting sexually with Mr. Epstein are if you have 
2 
tattoos, right? 
3 
A. I refuse to answer. 
4 
Q. If you're African-American or black? 
5 
A. I refuse to answer. 
6 
Q. You've never known him to interact with an 
7 
African-American or black girl, have you? 
8 
A. I refuse to answer. 
9 
Q. If you've been pregnant? 
10 
A. I refuse to answer. 
11 
Q. Or if you are pregnant, correct? 
12 
A. I refuse to answer. 
13 
Q. But certainly he was not above having a 
14 
pregnant 16-year-old girl bringing him underage minor 
15 
females, correct? 
16 
A. I refuse to answer. 
17 
Q. In fact --
18 
MR. PIKE: Form. 
19 
Q. -- it was his belief that he was doing her a 
20 
favor in that he was giving her money for providing a 
21 
service, correct? 
22 
MR. PIKE: Form. 
23 
A. I refuse to answer. 
24 
Q. Is it Jeffrey Epstein's belief that he did 
25 
these girls a favor? 
0098 
1 
A. I refuse to answer. 
2 
Q. I mean, doesn't he think that these girls are 
3 
lucky that he ever -- that they ever -- that he ever 
4 
allowed them out of their trailer and into his mansion, 
5 
correct? 
6 
A. I refuse to answer. 
7 
MR. PIKE: Form. 
8 
Q. We've defined the molestation statute or at 
9 
least I read it to you earlier and now we've talked 
10 
about this scheme of Jeffrey Epstein gaining access to 
11 
this number of underage minor females. At the time 
12 
when you were working for him did you recognize him as 
13 
a serial child molester? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. Do you know of anybody that ever worked for 
17 
him that quit working for him because of what he was 
18 
doing? 
19 
A. I refuse to answer. 
20 
MR. PIKE: Form. 
21 
Q. Do you know Michael Friedman? 
22 
A. I refuse to answer. 
23 
Q. Is that somebody you ever met there? 
24 
A. I refuse to answer. 
25 
Q. What countries does Jeffrey Epstein typically 
0099 
1 
bring underage minor females from? 
2 
A. I refuse to answer. 
3 
Q. Do you know why he chooses the countries that 
4 
he chooses to import underage minor females from? 
5 
A. I refuse to answer. 
6 
MR. PIKE: Form. 
EFTA00182458

7 
Q. Was 
-- do you know how old 
was when she came to this country? 
9 
A. I refuse to answer. 
10 
Q. Have you had conversations with 
about Jeffrey Epstein bringing her to this 
12 
country? 
13 
A. I refuse to answer. 
14 
Q. She's been described by some as his 
15 
Yugoslavian lesbian sex slave. Is that something that 
16 
is an accurate description based on the observations 
17 
you have? 
18 
A. I refuse to answer. 
19 
MR. PIKE: Form. 
20 
Q. Did you ever engage in any lesbian sex with 
21 
22 
A. I refuse to answer. 
23 
Q. Has 
ever had sex with Jeffrey 
24 
Epstein? 
25 
MR. PIKE: Form. 
0100 
1 
A. I refuse to answer. 
2 
Q. Do you know how it is that 
met 
3 
Jeffrey Epstein? 
4 
A. I refuse to answer. 
5 
Q. Do you know Story Cowles? 
6 
A. I refuse to answer. 
7 
Q. You know who Sergio Cordero is? 
8 
A. I refuse to answer. 
9 
Q. Well, that's somebody who also assists 
10 
Mr. Epstein in bringing him underage minor females for 
11 
sex, correct? 
12 
A. I refuse to answer. 
13 
MR. PIKE: Form. 
14 
Q. And Khalid Monroe, you know who that is? 
15 
A. I refuse to answer. 
16 
Q. Also somebody that through MC Squared or some 
17 
affiliation with that modeling agency would help for 
18 
Jeffrey Epstein to gain access to underage minor 
19 
females for sex, correct? 
20 
MR. PIKE: Form. 
21 
A. I refuse to answer. 
22 
Q. And do you know of trips that Mr. Cordero, 
23 
Mr. Brunel, and Mr. Epstein took to Brazil specifically 
24 
for the purposes of Mr. Epstein engaging in sex with 
25 
12-year-old girls? 
0101 
1 
MR. PIKE: Form. 
2 
A. I refuse to answer. 
3 
Q. Are you -- you are aware that Jeffrey Epstein 
4 
pled guilty to two felonies related to his sexual 
5 
interactions, correct? 
6 
A. I refuse to answer. 
7 
Q. Okay. 
8 
VIDEOGRAPHER: Excuse me, counsel. 
9 
MR. ROSS: I object on privilege grounds --
10 
attorney-client privilege grounds. 
11 
MR. EDWARDS: Okay, fine. I was trying to get 
12 
into an area we may get answers. 
13 
VIDEOGRAPHER: Could I just get you to put 
14 
your phone on the table? I'm starting to get 
15 
interference. 
16 
MR. ROSS: The phone? 
17 
VIDEOGRAPHER: Yes, sir. 
EFTA00182459

18 
MR. EDWARDS: You got a secret phone? 
19 
VIDEOGRAPHER: It's anytime it receives any 
20 
kind of information. 
21 
MR. ROSS: Oh, okay, yeah, it's --
22 
VIDEOGRAPHER: It's not that it's ringing. 
23 
MR. ROSS: Right. It's not doing it now. 
24 
VIDEOGRAPHER: I apologize for the 
25 
interruption. 
0102 
1 
Q. All right. I ask you that question because 
2 
there was also something called a non-prosecution 
3 
agreement. Are you familiar with that document? 
4 
A. I refuse to answer. 
5 
MR. ROSS: Attorney-client privilege. 
6 
Q. And that is also a document that included your 
7 
name as a co-conspirator; are you familiar with that? 
8 
A. I refuse to answer. 
9 
MR. ROSS: Attorney-client privilege. 
10 
Q. And that is because of your involvement with 
11 
calling on the telephone underage minors to bring them 
12 
to Jeffrey Epstein's house, correct? 
13 
A. I refuse to answer. 
14 
Q. Or for your involvement in scheduling 
15 
appointments in Jeffrey Epstein's appointment book for 
16 
underage minor -- underage minor females to be involved 
17 
with Jeffrey Epstein sexually, correct? 
18 
MR. PIKE: Form. 
19 
A. I refuse to answer. 
20 
Q. It is certainly not because you sought out 
21 
this child molestation ring in hopes of rising to the 
22 
top, correct? 
23 
MR. PIKE: Form. 
24 
A. I refuse to answer. 
25 
Q. Didn't you do everything that you did that 
0103 
1 
anybody could ever say is illegal at the direction of 
2 
Jeffrey Epstein? 
3 
A. I refuse to answer. 
4 
Q. And if it wasn't at the direction of Jeffrey 
5 
Epstein it was at the direction of Ghislaine Maxwell or 
6 
, correct? 
7 
MR. PIKE: Form. 
8 
A. I refuse to answer. 
9 
Q. I mean, those things were not things that you 
10 
would have done but for being under the supervision of 
11 
Jeffrey Epstein; isn't that right? 
12 
MR. PIKE: Form. 
13 
A. I refuse to answer. 
14 
Q. And you continued to do these things either 
15 
out of fear or because you were just impressed with 
16 
Jeffrey Epstein's lifestyle? 
17 
A. I refuse to answer. 
18 
Q. Aren't you angry for him involving you in this 
19 
criminal activity? 
20 
A. I refuse to answer. 
21 
MR. PIKE: Form. 
22 
Q. Do you ever intend in the future to talk about 
23 
what he did and what he involved you in? 
24 
MR. PIKE: Form. 
25 
A. I refuse to answer. 
0104 
1 
Q. Wouldn't you like to separate yourself being 
2 
the person that you are from this person who brought 
EFTA00182460

3 
you into this mess? 
4 
MR. PIKE: Form. 
5 
A. I refuse to answer. 
6 
Q. Is Jeffrey Epstein paying for your attorney 
7 
now? 
8 
9 
10 
11 
12 
13 
14 
15 
16 
Q. 
17 
Jeffrey 
18 
19 
20 
21 
22 
23 
24 
25 
0105 
1 
you know? 
2 
A. I refuse to answer. 
3 
MR. PIKE: Form. 
4 
Q. Since being on house arrest has Jeffrey 
5 
Epstein continued to engage in sex with underage minor 
6 
females? 
7 
MR. PIKE: Form. 
8 
A. I refuse to answer. 
9 
Q. Knowing that his habit was more than -- was at 
10 
least two underage minor females for sex every single 
11 
day do you believe that he stopped? 
12 
MR. PIKE: Form. 
13 
A. I refuse to answer. 
14 
Q. Isn't it your belief that he will continue to 
15 
do that once all of these cases are over? 
16 
A. I refuse to answer. 
17 
MR. PIKE: Form. 
18 
Q. Isn't it true that Jeffrey Epstein believes 
19 
that he is entitled to have sex with whomever he wants 
20 
including 12-, 13-, 14-year-old girls? 
21 
MR. PIKE: Form. 
22 
A. I refuse to answer. 
23 
Q. Do you know whether he continues -- do you 
24 
know whether he intends to continue to molest underage 
25 
minors within the United States? 
0106 
1 
MR. PIKE: Form. 
2 
A. I refuse to answer. 
3 
Q. Do you know Mike Sanka? 
4 
A. I refuse to answer. 
5 
Q. That's somebody else that assisted Jeffrey 
6 
Epstein in gaining access to underage minor females 
7 
that were foreigners, correct? 
8 
A. I refuse to answer. 
9 
MR. PIKE: Form. 
10 
Q. He's also involved in the modeling agency, 
11 
too, correct? 
12 
MR. PIKE: Form. 
13 
A. I refuse to answer. 
MR. PIKE: Form. 
A. I refuse to answer. 
MR. ROSS: Well, actually you can answer. 
A. No, my parents help me. 
Q. Are you aware of Jeffrey Epstein's closest 
friends now? 
A. I refuse to answer. 
MR. PIKE: Form. 
Who are the people that you believe are 
Epstein's enemies? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Did you ever find out that Jeffrey Epstein and 
Ghislaine Maxwell had been targeting and preying upon 
underage females for sex for more than a decade? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Who is Jeffrey Epstein's girlfriend now, if 
EFTA00182461

14 
Q. That's a friend of or former friend of Jean 
15 
Luc Brunel's? 
16 
A. I refuse to answer. 
17 
Q. How many times has Jean Luc Brunel shown up at 
18 
Jeffrey Epstein's house with underage minor females? 
19 
MR. PIKE: Form. 
20 
A. I refuse to answer. 
21 
Q. And when that would happen isn't it true that 
22 
they would have orgies with these underage minor 
23 
females? 
24 
MR. PIKE: Form. 
25 
A. I refuse to answer. 
0107 
1 
Q. What was done -- or let me ask it a different 
2 
way. Strike that. 
3 
Where is the scheduling book for the massage 
4 
appointments for Jeffrey Epstein? 
5 
MR. PIKE: Form. 
6 
A. I refuse to answer. 
7 
Q. Is that something else that was removed from 
8 
the home prior to the search warrant being executed? 
9 
A. I refuse to answer. 
10 
MR. PIKE: Form. 
11 
Q. Do you know how it is that -- well, did 
12 
Jeffrey Epstein ever tell you that because of the 
13 
people he knew he would not be going to prison for the 
14 
crimes that he committed? 
15 
A. I refuse to answer. 
16 
MR. PIKE: Form. 
17 
Q. And is it your understanding that Ken Starr 
18 
had played a major role in devising the non-prosecution 
19 
agreement or having the government agree not to 
20 
prosecute Jeffrey Epstein for his crimes against 
21 
minors? 
22 
A. I refuse to answer. 
23 
MR. PIKE: Form. 
24 
Q. Is it also your understanding that Bill 
25 
Clinton played somewhat of a role in helping Jeffrey 
0108 
1 
Epstein out of the trouble that he would have been in 
2 
related to his sexual interactions with minor females? 
3 
A. I refuse to answer. 
4 
MR. PIKE: Form. 
5 
Q. Did Jeffrey Epstein tell you that you need to 
6 
cooperate if you want the protection that me and my 
7 
connections can give you for this activity? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
10 
Q. You admit that you called LM on the telephone 
11 
for her to come to Jeffrey Epstein's house to be 
12 
molested by Jeffrey Epstein when she was an underage 
13 
female? 
14 
A. I refuse to answer. 
15 
MR. PIKE: Form. Asked and answered twice. 
16 
Q. Do you agree that you called EW on the 
17 
telephone for the purposes of her coming to Jeffrey 
18 
Epstein's house for him to sexually molest her? 
19 
MR. PIKE: Same objection. 
20 
A. I refuse to answer. 
21 
Q. And do you agree that you called Jane Doe and 
22 
told her to come to your house to work, meaning for 
23 
Jeffrey Epstein to sexually molest her? 
24 
MR. PIKE: Asked and answered. 
EFTA00182462

25 
A. I refuse to answer. 
0109 
1 
Q. The first trial that is set in these cases is 
2 
in July of this year. Do you intend to be in the local 
3 
area? 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
n 
presume 
a i 
needed to find you or 
14 
locate you or anything else I could go through your 
15 
attorney? 
16 
A. Yes. 
17 
Q. Okay. Who do you live at that address with? 
18 
MR. ROSS: You can answer. 
19 
A. With my husband and my mom-in-law and his 
20 
sister as well. 
21 
Q. 
22 
A. 
23 
Q. 
24 
A. 
25 
Q. And who else lives at the house with you, I'm 
0110 
1 
sorry? 
2 
A. 
3 
Q. 
4 
A. 
5 
6 
7 
A. I refuse to answer. 
8 
Q. Have you told your parents? 
9 
A. I refuse to answer. 
10 
Q. Are your parents in the country now? 
11 
MR. ROSS: You can answer. 
12 
A. No. 
13 
Q. Do they have plans to come back? 
14 
MR. ROSS: You can answer. 
15 
A. They may visit, I'm not sure. 
16 
Q. But on a permanent basis they're in Poland? 
17 
A. Yes. 
18 
Q. Okay. What's the address where they are in 
19 
Poland? 
20 
A. 
21 
Q. She's great. I'm sure she got that. 
22 
A. Would you like me to spell it out? 
23 
24 
25 
MR. EDWARDS: One way to never find a witness 
0111 
1 
is just move to Poland. There's no way. 
2 
MR. ROSS: Couldn't get anyone to type the 
3 
subpoena. 
4 
MR. EDWARDS: Right, exactly. All right. I 
5 
don't have any other questions for you. Thank you. 
6 
THE WITNESS: Thank you. 
7 
CROSS-EXAMINATION 
8 
BY MR. MERMELSTEIN: 
9 
Q. Okay. Mrs. Ross, I have some questions for 
A. 
4. 
MR. ROSS: 
Yes. 
Okay. And what address will you be at? 
MR. ROSS: You can answer. 
You can answer. 
EFTA00182463

8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0113 
1 
2 
3 
4 
5 
6 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0112 
1 
2 
3 
4 
5 
6 
you. Your husband, 
what does he do for a 
living? 
A. He's a Ph.D. student. 
Q. And what is he a Ph.D. in? 
A. He works on bone marrow transplant immunology. 
Q. So is he a medical doctor? 
A. He's scientist. He's working on his Ph.D. 
degree. 
Q. And which school is he working on his Ph.D. 
at? 
A. University of Miami. 
Q. And how long has he been doing that? 
A. I cannot recall when he started but we were 
already married. Maybe one or two years into my 
marriage. I do not recall the exact time. 
Q. And I believe you testified that you met him 
in Europe, correct? 
A. Correct. 
Q. And did he have a different employment or 
profession then? 
A. Yes. 
Q. What was he doing then? 
7 
A. Well, at that time he was serving in the 
entertainment business. He was DJing and -- yeah. 
When I met him he came to Europe for a DJ event. DJing 
event. 
Q. And where was that in Europe? 
A. He went to Spain and then I was in Monaco at 
the time and he knew the people that I was there with 
and we were introduced. That's where we met. 
Q. And did he have connections to modeling in the 
United States? 
A. Yes. 
Q. And how did he have those connections? 
A. I'm -- you know, I'm not sure. I don't know 
at this time, but he knew agencies here and he was 
doing, I believe, some photographic work as well 
himself. 
Q. So he was a DJ and a professional 
photograph -- photographer? 
A. Yes. You may say so, yes. 
Q. And a scientist as well? 
A. 
Q. 
agencies 
A. 
Yes. 
Did he do work for particular modeling 
in the United States? 
I mean, do you -- I don't understand your 
question. Do you mean like --
7 
Q. Well, did he perform work or services for 
8 
particular modeling agencies in the United States? 
9 
A. Well, I believe he would hire models from 
10 
modeling agencies, yes. 
11 
Q. He would hire models? 
12 
A. Yes, for -- you know, that's how -- how it 
13 
works. You hire a model from a modeling agency for a 
14 
particular job, a client that you may have. 
15 
Q. So as a photographer he would hire models for 
16 
a particular modeling agency? 
17 
MR. PIKE: Form. 
18 
A. Yes. 
19 
Q. And do you know which modeling agencies he 
20 
typically worked with? 
EFTA00182464

21 
A. Well, I presume Elite Models because, you 
22 
know, he had connection and he invited me. I think 
23 
just various Miami Beach -- you know, Miami, South 
24 
Beach modeling agencies. 
25 
Q. Did he work for MC Squared? 
0114 
1 
A. I refuse to answer. 
2 
Q. In 2004 and 2005 you were employed by Jeffrey 
3 
Epstein, correct? 
4 
MR. PIKE: Form. 
5 
A. I refuse to answer. 
6 
Q. And as an employee of Jeffrey Epstein you were 
7 
under his instruction and supervision, correct? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
10 
MR. PIKE: Let's go off the record for a 
11 
second. 
12 
MR. MERMELSTEIN: Sure. 
13 
VIDEOGRAPHER: Off the record at 12:12 p.m. 
14 
(Discussion off the record.) 
15 
MR. MERMELSTEIN: I'll be brief on the general 
16 
questions. 
17 
VIDEOGRAPHER: On the record, 12:14 p.m. 
18 
BY MR. MERMELSTEIN: 
19 
Q. And as an employee of Jeffrey Epstein were you 
20 
also subject to the -- to the instructions and 
21 
supervision of Ghislaine Maxwell? 
22 
MR. PIKE: Form. 
23 
A. I refuse to answer. 
24 
Q. And as an employee of Jeffrey Epstein did you 
25 
work under the supervision and instruction of his 
0115 
1 
primary assistant 
2 
MR. PIKE: Form. 
3 
A. I refuse to answer. 
4 
Q. Okay. Did Jeffrey Epstein tell you that --
5 
that he recruited from western Palm Beach County 
6 
underage girls to come to his Palm Beach mansion for 
7 
sexual activity? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
10 
Q. And did Jeffrey Epstein have a computer 
11 
database at his Palm Beach mansion where he listed 
12 
underage high school girls in Palm Beach County and 
13 
their contact information so that he could have these 
14 
underage minors come to his house for sexual activity? 
15 
MR. PIKE: Form. 
16 
A. I refuse to answer. 
17 
Q. And did Jeffrey Epstein tell you that the 
18 
reason he brought in underage minors from western Palm 
19 
Beach County is because he anticipated they would be 
20 
impressed, in awe, and intimidated by his wealth? 
21 
MR. PIKE: Form. 
22 
A. I refuse to answer. 
23 
Q. And as young girls who were impressed and in 
24 
awe and intimidated of his wealth they would do what he 
25 
asked them to do? 
0116 
1 
MR. PIKE: Form. 
2 
A. I refuse to answer. 
3 
Q. And as young underage girls who were 
4 
impressed, intimidated, and in awe of his wealth they 
5 
would be unlikely to -- to complain to authorities that 
EFTA00182465

6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0117 
1 
Epstein a massage? 
2 
MR. PIKE: Form. 
3 
A. I refuse to answer. 
4 
Q. When Jane Doe 7 -- let me strike that. 
5 
Do you know Jane Doe 7? 
6 
A. I refuse to answer. 
7 
Q. When Jane Doe 7 was a minor female did you 
8 
call Jane Doe 7 to schedule appointments for her to 
9 
come to the Epstein house in Palm Beach to give Epstein 
10 
a massage? 
11 
MR. PIKE: Form. 
12 
A. I refuse to answer. 
13 
Q. When Jane Doe 7 was a minor female did you 
14 
receive calls from Jane Doe 7 while you were at the 
15 
Epstein house for her to come to the house by 
16 
appointment and give Jeffrey Epstein a massage? 
17 
MR. PIKE: Form. 
18 
A. I refuse to answer. 
19 
Q. The computer database that Jeffrey Epstein 
20 
maintained girls from western Palm Beach County who 
21 
would come to the house in Palm Beach to give Epstein a 
22 
massage, did that computer database include the name 
23 
and contact information for Jane Doe 2? 
24 
MR. PIKE: Form. 
25 
A. I refuse to answer. 
0118 
1 
Q. Do you know who Jane Doe 2 is? 
2 
A. I refuse to answer. 
3 
Q. Do you know who Jane Doe 5 is? 
4 
A. I refuse to answer. 
5 
Q. Did the computer database that Epstein 
6 
maintained on his computers in his home have the name 
7 
and contact information for Jane Doe 5 so that Epstein 
8 
could contact her for -- for massages in his Palm Beach 
9 
home? 
10 
MR. PIKE: Form. 
11 
A. I refuse to answer. 
12 
Q. Do you know the name Jane Doe 6? 
13 
A. I refuse to answer. 
14 
Q. Did the computer database that Epstein 
15 
maintained in his home of underage girls who he would 
16 
have come over for massages and sexual activity did 
he was engaging in sexual activity with them? 
A. I refuse to answer. 
MR. PIKE: Form. 
Q. Okay. Did Jeffrey Epstein instruct you to 
call girls on the telephone to schedule appointments 
for them to come to his Palm Beach house for massages 
which were, in fact, to be sexual activity? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Prior to May 2005 did you call Jane Doe 4 to 
schedule appointments for her to come to the Epstein 
house to engage in -- to give Jeffrey Epstein a massage 
which would, in fact, be sexual activity with Jeffrey 
Epstein? 
MR. PIKE: Form. 
A. I refuse to answer. 
Q. Okay. Prior to May 2005 while you were at the 
Epstein house in Palm Beach did you receive calls from 
Jane Doe 4 regarding the scheduling of an appointment 
for her to come to the Epstein house to give Jeffrey 
EFTA00182466

17 
that computer database include the name and contact 
18 
information for Jane Doe 6? 
19 
A. I refuse to answer. 
20 
Q. Do you know the name Jane Doe 3? 
21 
A. I refuse to answer. 
22 
Q. Did the computer database that Jeffrey Epstein 
23 
maintained in his home include the name and contact 
24 
information of Jane Doe 3 so that he could contact Jane 
25 
Doe 3 to come to his Palm Beach home and give him a 
0119 
1 
massage which would become sexual activity? 
2 
A. I refuse to answer. 
3 
Q. Did the computer database that Jeffrey Epstein 
4 
maintained in his home include the name Jane Doe 4? 
5 
MR. PIKE: Form. 
6 
A. I refuse to answer. 
7 
Q. Do you know Jane Doe 4? 
8 
A. I refuse to answer. 
9 
Q. Did the -- did Jeffrey Epstein tell you that 
10 
he maintained the contact information for Jane Doe 4 in 
11 
his computer database in his home so that he could 
12 
contact her to come to his Palm Beach mansion for 
13 
massages? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. Did you know for a fact that the computer 
17 
database included the name Jane Doe 4 so that Jeffrey 
18 
Epstein could contact her and she would come to the 
19 
Palm Beach mansion to give Jeffrey Epstein a massage? 
20 
MR. PIKE: Form. 
21 
A. I refuse to answer. 
22 
Q. Did you know that the computer database that 
23 
Jeffrey Epstein maintained his home contained the name 
24 
and contact information of Jane Doe 7 --
25 
A. I refuse -- sorry. 
0120 
1 
Q. I'm sorry -- so he would contact Jane Doe 7 
2 
and have her come to his house to give him a massage? 
3 
A. I refuse to answer. 
4 
Q. Are you aware that the computer database that 
5 
Jeffrey Epstein maintained in his home contained the 
6 
name Jane Doe 8 so that he could contact Jane Doe 8 and 
7 
have him come to the house in Palm Beach for purposes 
8 
of giving him a massage? 
9 
MR. PIKE: Form. 
10 
A. I refuse to answer. 
11 
Q. You removed three computers from the Palm 
12 
Beach house with another gentleman prior to the search 
13 
warrant being issued by the Palm Beach police; isn't 
14 
that correct? 
15 
A. I refuse to answer. 
16 
MR. PIKE: Form. Asked and answered. 
17 
Q. And Jeffrey Epstein instructed you to remove 
18 
those computers; is that correct? 
19 
MR. PIKE: Form, asked and answered. 
20 
A. I refuse to answer. 
21 
Q. And Jeffrey Epstein told you that the reason 
22 
he was instructing you to remove the computers was to 
23 
hide his sexual activities with underage minors from 
24 
the authorities? 
25 
MR. PIKE: Form. 
0121 
1 
A. I refuse to answer. 
EFTA00182467

2 
Q. As an employee of Jeffrey Epstein did you know 
3 
Janusz Banaziak? 
4 
A. I refuse to answer. 
5 
MR. PIKE: Form. 
6 
Q. Was Janusz Banaziak also an employee of 
7 
Jeffrey Epstein? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
10 
Q. When Janusz Banaziak testified that you and 
11 
another gentleman removed the three computers from 
12 
Jeffrey Epstein's home he was telling the truth, 
13 
correct? 
14 
A. I refuse to answer. 
15 
MR. PIKE: Form. 
16 
Q. Did you observe Jeffrey Epstein persuading, 
17 
inducing, or enticing underage girls to engage in 
18 
sexual activities with him? 
19 
A. I refuse to answer. 
20 
Q. Did you -- strike that. 
21 
Did you observe Jeffrey Epstein persuading, 
22 
inducing, or enticing girls who came to his house for 
23 
the purpose of giving him a massage to engage in sexual 
24 
activity with him? 
25 
MR. PIKE: Form. 
0122 
1 
A. I refuse to answer. 
2 
Q. Did Jeffrey Epstein tell you that he induced, 
3 
persuaded, or enticed underage girls to engage in 
4 
sexual activities with him when they came to his Palm 
5 
Beach mansion to give him a massage? 
6 
MR. PIKE: Form. 
7 
A. I refuse to answer. 
8 
Q. Would you instruct -- when you spoke to 
9 
underage girls to schedule appointments for massage in 
10 
Epstein's home would you instruct these girls to lie 
11 
about their ages and say they were 18 years old when 
12 
you knew that they were younger than 18? 
13 
A. I refuse to answer. 
14 
Q. Did Jeffrey Epstein instruct you as to what to 
15 
say to the girls who you contacted by telephone to make 
16 
appointments to schedule massages in Epstein's home? 
17 
A. I refuse to answer. 
18 
MR. PIKE: Form. 
19 
Q. And would Jeffrey Epstein tell you to have the 
20 
girls who you contacted by the telephone to make 
21 
appointments to come to the mansion to give Jeffrey 
22 
Epstein massages, that they should -- that these girls 
23 
should lie about their ages to Jeffrey Epstein? 
24 
MR. PIKE: Form. 
25 
A. I refuse to answer. 
0123 
1 
2 
3 
4 
5 
6 
7 
Q. 
8 
4 would 
9 
massage 
10 
A. 
11 
12 
Q. 
Q. Prior to May 2005 are you aware that Jeffrey 
Epstein had numerous appointments with Jane Doe 4 for 
her to come to the mansion to come to give him a 
massage? 
A. I refuse to answer. 
MR. PIKE: Form. 
Prior to May 2005 are you aware that Jane Doe 
come to the mansion to give Jeffrey Epstein a 
on a frequent and regular basis? 
I refuse to answer. 
MR. PIKE: Form. 
Are you aware that prior to May 2005 Jeffrey 
EFTA00182468

13 
Epstein engaged with -- engaged in sexual activities 
14 
with Jane Doe 4 at the Palm Beach mansion 50 to a 
15 
hundred times? 
16 
A. I refuse to answer. 
17 
MR. PIKE: Form. 
18 
Q. Did Jeffrey Epstein admit to you that on 
19 
numerous occasions he -- when Jane Doe 4 was an 
20 
underage minor he touched her breasts? 
21 
MR. PIKE: Form. 
22 
A. I refuse to answer. 
23 
Q. Did Jeffrey Epstein admit to you that on 
24 
numerous occasions when Jane Doe 4 was an underage 
25 
minor he touched and groped her buttocks? 
0124 
1 
A. I refuse to answer. 
2 
Q. Did Jeffrey Epstein admit to you on numerous 
3 
occasions when Jane Doe 4 was an underage minor that he 
4 
rubbed Jane Doe 4's vagina? 
5 
A. I refuse to answer. 
6 
MR. PIKE: Form. 
7 
Q. Did Jeffrey Epstein admit to you that on 
8 
occasions prior to Jane Doe 4 turning the age of 18 
9 
that he performed oral sex on Jane Doe 4? 
10 
MR. PIKE: Form. 
11 
A. I refuse to answer. 
12 
Q. Did Jeffrey Epstein admit to you that on 
13 
numerous occasions prior to Jane Doe 4 reaching the age 
14 
of 18 he would place a vibrator on Jane Doe 4's 
15 
genitals? 
16 
MR. PIKE: Form. 
17 
A. I refuse to answer. 
18 
Q. Did Jeffrey Epstein admit to you that prior to 
19 
Jane Doe 4 becoming 18 years of age he would masturbate 
20 
in her presence? 
21 
A. I refuse to answer. 
22 
MR. PIKE: Form to the last question. 
23 
MR. MERMELSTEIN: Hum? 
24 
MR. PIKE: Form to the last question. 
25 
Q. Did Jeffrey Epstein admit to you that prior to 
0125 
1 
Jane Doe 7 reaching the age of 18 years old he would 
2 
touch her breasts? 
3 
MR. PIKE: Form. 
4 
A. I refuse to answer. 
5 
Q. Did Jeffrey Epstein admit to you that prior to 
6 
Jane Doe 7 reaching the age of 18 he would grope her --
7 
grope Jane Doe 7's buttocks? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
10 
Q. And did Jeffrey Epstein admit to you that 
11 
prior to Jane Doe 7 reaching the age of 18 he would rub 
12 
Jane Doe 7's vagina? 
13 
A. I refuse to answer. 
14 
MR. PIKE: Form. 
15 
Q. Do you know who 
is? 
16 
A. I refuse to answer. 
17 
Q. Did Jeffrey Epstein instruct you to call 
on numerous occasions to recruit underage girls 
19 
to come to the Palm Beach Mansion to give Jeffrey 
20 
Epstein a massage? 
21 
MR. PIKE: Form. 
22 
A. I refuse to answer. 
23 
Q. Did Jeffrey Epstein instruct you on numerous 
EFTA00182469

24 
occasions to contact 
for the purpose of 
25 
scheduling underage girls for appointments to come to 
0126 
1 
the Palm Beach mansion and give Jeffrey Epstein a 
2 
massage? 
3 
A. I refuse to answer. 
4 
MR. PIKE: Form. 
5 
Q. Did Jeffrey Epstein advise you that 
was his contact in western Palm Beach County 
7 
high schools for the purpose of recruiting underage 
8 
girls to come to the Palm Beach mansion where he would 
9 
then engage in sexual activity with them? 
10 
A. I refuse to answer. 
11 
MR. PIKE: Form. 
12 
Q. Did 
instruct you on how to 
13 
contact underage girls for the purpose of bringing them 
14 
to the Palm Beach mansion for massages and what to say 
15 
to these young girls? 
16 
MR. PIKE: Form. 
17 
A. I refuse to answer. 
18 
Q. Did 
train you in how to contact 
19 
girls and recruit them to come to the Palm Beach 
20 
mansion and -- and provide Jeffrey Epstein with 
21 
massages? 
22 
A. I refuse to answer. 
23 
MR. PIKE: Form. 
24 
Q. Was one of your primary duties scheduling 
25 
regular appointments, at least two per day, for Jeffrey 
0127 
1 
Epstein to have underage girls come to the mansion to 
2 
give him a massage? 
3 
MR. PIKE: Asked and answered, form. 
4 
A. I refuse to answer. 
5 
MR. MERMELSTEIN: Okay. That's all I have. 
6 
MR. PIKE: I have no questions. 
7 
MR. EDWARDS: I only have a couple. 
8 
I'll go ahead and mark this as Number 4. 
9 
(Whereupon, Plaintiff's Exhibit 4 was marked 
10 
for identification.) 
11 
REDIRECT EXAMINATION 
12 
BY MR. EDWARDS: 
13 
Q. This photograph appears to be Jeffrey Epstein, 
14 
yourself, and Maer Roshan in this photograph taken from 
15 
an internet newspaper. Can you tell me where that 
16 
picture was taken? 
17 
A. I refuse to answer. 
18 
MR. PIKE: May I see that, counsel? 
19 
Q. Was this related -- this event, was it related 
20 
to MC Squared? 
21 
A. I refuse to answer. 
22 
Q. All right. What is -- I know that you told us 
23 
that you're not employed now because you're in school. 
24 
What was your last employment? 
25 
A. I was working at the local CPA firm. 
0128 
1 
Q. Excuse me? 
2 
A. CPA firm. 
3 
Q. Okay. What was the name of that CPA firm? 
4 
A. William Owens, CPA, P.A. 
5 
Q. William Owens. And is that in Miami? 
6 
A. Correct. 
7 
Q. Where did you work prior to that? 
8 
A. I worked for maybe less than a month at a 
EFTA00182470

9 
clothing store. 
10 
Q. What clothing store? 
11 
A. Club Monaco. 
12 
Q. Where's that? 
13 
A. South Beach. 
14 
Q. Where in South Beach? 
15 
A. It's on Collins Avenue and I believe maybe 6th 
16 
and 8th, I'm not sure. 
17 
Q. Okay. Why'd you leave there? 
18 
A. The clothing store? 
19 
Q. Correct. 
20 
A. Because I got the accounting job. 
21 
Q. And that's what you want to be you said? 
22 
A. Yes, um-hum. 
23 
Q. Okay. And I suppose that you left the 
24 
accounting firm because you went to school to finish 
25 
your degree? 
0129 
1 
A. Well, I was working part-time and going to 
2 
school part-time and it just became too challenging. 
3 
The accounting program is very demanding, so I wanted 
4 
to dedicate myself to study. 
5 
Q. How long were you at this accounting firm 
6 
Williams Owens -- William Owens? 
7 
A. Maybe two and a half years about maybe. 
8 
Something like that. 
9 
Q. All right. So we're in -- when was it that 
10 
you left there? 
11 
A. May of 2009. 
12 
Q. Okay. May '09, so that brings us back to late 
13 
2006 or something when you started there? 
14 
A. Yes. That would be about right, yes. 
15 
Q. And then it was sometime earlier than that in 
16 
2006 when you were at the clothing store? 
17 
A. Yes. 
18 
Q. And you were there for about a month? 
19 
A. About, yes. 
20 
Q. Give or take 
21 
A. Yes. 
22 
Q. -- a week or so? 
23 
Where -- where did you work prior to the 
24 
clothing store Club Monaco? 
25 
A. I was modeling. 
0130 
1 
Q. And where were you modeling? 
2 
A. In Miami. New York. 
3 
Q. For what agency? 
4 
A. In Miami I was with Elite Models. I was with 
5 
Michele Pommier --
6 
Q. Who's that? 
7 
A. Michele Pommier Agency. 
8 
Q. Okay. How do you spell the last name? 
9 
A. P-O-M-M-I-E-R. And then --
10 
Q. Okay. That was in Miami? 
11 
A. Yes. 
12 
Q. And then what agency did you work through in 
13 
New York? 
14 
A. ID Models. 
15 
Q. Excuse me? 
16 
A. ID Models. 
17 
Q. ID? 
18 
A. Yes. 
19 
Q. Just in the letter I --
EFTA00182471

20 
A. Yes. 
21 
Q. -- letter D? 
22 
And who was the person that got you hooked up 
23 
at ID Models? 
24 
A. My husband had that contact. 
25 
Q. Okay. How long did you work with ID Models? 
0131 
1 
A. I'm trying to think. I do not recall exact 
2 
timeframe. 
3 
Q. All right. Well, if the clothing store was 
4 
sometime late 2006 are we talking about earlier in the 
5 
year 2006 when you were working with Elite in Miami and 
6 
ID Models in New York? 
7 
MR. ROSS: I'm going to ask you to invoke. 
8 
THE WITNESS: I'm sorry? 
9 
MR. ROSS: You should invoke with regard to 
10 
this timeframe you're talking about now. 
11 
MR. EDWARDS: Okay. 
12 
A. I refuse to answer. 
13 
Q. Okay. Can you tell me about any job that you 
14 
had modeling or otherwise prior to working at ID Models 
15 
or with Elite? 
16 
A. Recall -- just name any 
17 
Q. Any -- what was your -- what employment did 
18 
you have just prior to working with Elite Models and ID 
19 
Models? 
20 
A. I was working as a model in Europe. I 
21 
graduated from high school in 2002 and I dedicated that 
22 
year to modeling and so I was modeling. I did not have 
23 
employment. 
24 
Q. All right. So just so I understand you were 
25 
modeling in Europe, you came over here in 2002. 
0132 
1 
A. Um-hum. 
2 
Q. There's a period of time from 2002 through 
3 
2006 where -- you know, 2006 you start with ID Models 
4 
and again with Elite. I know when you came over here 
5 
in 2002 you were with Elite also, right? 
6 
A. I'm sorry, you're confusing me with the 
7 
timeframe. 
8 
Q. I'm confusing myself, how about that. Let's 
9 
start over. 
10 
2002 you come over to the United States, 
11 
you're working at Elite? 
12 
A. Yes, I've been invited by Elite. 
13 
Q. Okay. And then if I understand you correctly 
14 
over time you continue to work with or through Elite? 
15 
A. Well, I've been, you know, changing agencies 
16 
throughout the period. 
17 
Q. Okay. What are some of the other modeling 
18 
agencies you have worked for or with? 
19 
A. I refuse to answer. 
20 
Q. Okay. The only other names of modeling 
21 
agencies that you can answer are ID Models and Elite; 
22 
is that correct? 
23 
THE WITNESS: Should I? 
24 
MR. ROSS: Well, she's already answered also 
25 
Michele Pommier. 
0133 
1 
MR. EDWARDS: But I thought that was somebody 
2 
through Elite, like they're --
3 
MR. ROSS: No, no, no, Michele Pommier is a --
4 
MR. EDWARDS: Different, okay. 
EFTA00182472

5 
Q. All right. Is there anybody else that you're 
6 
able to -- to tell me where you worked? 
7 
MR. ROSS: Invoke as to any further 
8 
information. 
9 
THE WITNESS: I'm sorry? 
10 
MR. ROSS: Invoke your privilege. 
11 
A. I refuse to answer any questions. 
12 
MR. EDWARDS: All right. That's all I got. 
13 
MR. MERMELSTEIN: Can I just follow up a 
14 
couple? 
15 
RECROSS-EXAMINATION 
16 
BY MR. MERMELSTEIN: 
17 
Q. In what has been marked as Exhibit 2C is a 
18 
phone message from you to Adri -- from you to Jeffrey 
19 
Epstein dated September 10th, 2005 at 1:15 p.m. 
20 
And the message that you left was "Lauren 
21 
confirmed 4 p.m.", is that correct? 
22 
A. I refuse to answer. 
23 
Q. Is the Lauren referred to in this message 
24 
? 
25 
MR. PIKE: Form. 
0134 
1 
A. I refuse to answer. 
2 
Q. And did you schedule Lauren --
3 
MR. PIKE: Form. 
4 
Q. -- 
to come to the Palm Beach 
5 
mansion as an underage female to give Jeffrey Epstein 
6 
massages? 
7 
MR. PIKE: Form. 
8 
A. I refuse to answer. 
9 
Q. Also what has been marked as Exhibit 2F is a 
10 
phone message from you to Jeffrey Epstein dated 
11 
September 11th, 2005 at 9:15 a.m. And the message was 
12 
that you got a car for a particular person. Do you 
13 
recall that? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. Is the car that you obtained on 
17 
September 11th, 2005 for Jane Doe 4? 
18 
MR. PIKE: Form. 
19 
A. I refuse to answer. 
20 
Q. And Jane Doe 4 is a girl who had been coming 
21 
to the Palm Beach mansion to give Jeffrey Epstein a 
22 
massage and engage in sexual activities with him for a 
23 
substantial period of time; is that correct? 
24 
A. I refuse to answer. 
25 
Q. And also what has been marked as Exhibit 2H --
0135 
1 
actually --
2 
MR. EDWARDS: Is that G? 
3 
MR. MERMELSTEIN: Are they similar? 
4 
MR. EDWARDS: Yeah, I guess they blocked out 
5 
names on one of them and they didn't on the other. 
6 
MR. MERMELSTEIN: Right. Okay. 
7 
Q. And what has been marked as Exhibit 2G is a 
8 
message from you to Jeffrey Epstein dated 
9 
September 3rd, 2005 at 8:50 p.m. And the message you 
10 
left is, quote, "I left message for 
to confirm 
11 
for 11:00 a.m. and 
for 4:30 p.m." 
12 
Did you, in fact, leave that message? 
13 
MR. PIKE: Form. 
14 
A. I refuse to answer. 
15 
Q. And this message that you left confirmed an 
EFTA00182473

16 
appointment for Jane Doe 4 for 4:30 p.m., correct? 
17 
A. I refuse to answer. 
18 
MR. MERMELSTEIN: All right. That's all I 
19 
have. 
20 
MR. ROSS: Waive. 
21 
MR. MERMELSTEIN: All right. 
22 
VIDEOGRAPHER: Off the record, 12:42 p.m. 
23 
THE REPORTER: Are you ordering? 
24 
MR. EDWARDS: Yes. 
25 
MR. PIKE: I want a copy, a mini, no ASCii, 
0136 
1 
and no word index. 
2 
MR. MERMELSTEIN: I'll take a copy with a 
3 
mini. 
4 
(The deposition was concluded at 12:42 p.m.) 
5 
(Reading and signing of the deposition was 
6 
waived by the witness and all parties.) 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0137 
1 
CERTIFICATE OF OATH 
2 
STATE OF FLORIDA 
3 
COUNTY OF BROWARD 
4 
5 
I, Janet L. McKinney, Registered Professional 
6 
Reporter, Florida Professional Reporter, Certified 
7 
LiveNote Reporter, Notary Public, State of Florida, 
8 
certify that 
personally appeared before me 
9 
on March 15, 2010 and was duly sworn. 
10 
Signed this 21st day of March, 2010. 
11 
12 
13 
14 
Janet L. McKinney 
Registered Professional Reporter 
15 
Florida Professional Reporter 
Certified LiveNote Reporter 
16 
Notary Public, State of Florida 
Commission No.: DD552183 
17 
Expires: June 2, 2010 
18 
19 
20 
21 
22 
EFTA00182474

23 
24 
25 
0138 
1 
CERTIFICATE OF REPORTER 
2 
STATE OF FLORIDA 
3 
COUNTY OF BROWARD 
4 
5 
I, Janet McKinney, Registered Professional 
6 
Reporter, Florida Professional Reporter, Certified 
7 
LiveNote Reporter, certify that I was authorized to and 
8 
did stenographically report the deposition of 
, pages 1 through 138; that a review of the 
10 
transcript was not requested; and that the transcript 
11 
is a true record of my stenographic notes. 
12 
I further certify that I not a relative, 
13 
employee, attorney, or counsel of any of the parties, 
14 
nor am I a relative or employee of any of the parties' 
15 
attorneys or counsel connected with the action, nor am 
16 
I financially interested in the action. 
17 
Dated this 21st day of March, 2010. 
18 
19 
Janet L. McKinney, RPR, FPR, CLR 
20 
Registered Professional Reporter 
Florida Professional Reporter 
21 
Certified LiveNote Reporter 
22 
23 
24 
25 
EFTA00182475