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Case No. 08-80736-CV-MARRA 
P-008548 
EFTA00226556

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
IN RE: OPERATION LEAP YEAR 
Federal Grand Jury, 07-103 
West Palm Beach, Florida 
May 8, 2007 
APPEARANCES: 
ESQUIRE 
Assistant United States Attorney 
, Foreperson 
TESTIMONY 
OF 
Exhibit 24 
EFTA00226558

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The sworn testimony ofIIIIIIIIIIII 
2 
was taken before the Federal Grand Jury, West Palm 
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Beach Division, West Palm Beach, Palm Beach County, 
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State of Florida, on the 8th day of May, 2007. 
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Philip W. May, Court Reporter, was authorized to 
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and did report the sworn testimony. 
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(The witness entered the grand jury room.) 
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having been duly sworn by the grand jury foreperson, 
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was examined and testified on her oath as follows: 
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EXAMINATION 
6 
BY MS. 
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Q 
Could you start by reminding us of your name and 
where you're employed. 
A 
I work for the FBI here in West 
Palm Beach on their violent crimes squad. 
Q 
And you are one of the case agents in Operation 
Leap Year? 
A 
Yes, I am. 
Q 
Did you recently participate in an interview of 
A 
Yes. 
• 
Can you tell us 
s date of birth? 
A 
A 
Q 
A 
Tatum was born on July 26, 1988. 
And you spoke with her recently? 
Yes, we did. 
So she was 18 at the time of the interview? 
Yes, I believe she was. 
Who is Tatum Miller? 
was identified by the Palm Beach 
EFTA00226560

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Police Department as one of the girls who had frequented 
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Mr. Epstein's house. 
3 
Q 
How exactly did the Palm Beach Police Department 
4 
determine that she was one of those girls? 
A 
When they did their search warrant at 
6 
Mr. Epstein's residence, some message pads were obtained 
7 
at his residence, and they had several calls from a girl 
8 
named Tatum, and phone numbers. So they were able to 
9 
track back those messages back to 
10 
Q 
Did the Palm Beach Police Department try to 
11 
interview Miss 
12 
A 
They did. 
13 
Q 
Did she agree to speak with them? 
14 
A 
No. She stated that she loved Jeffrey Epstein, 
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and that she would not say anything positive or negative 
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about what occurred. 
17 
Q 
After the FBI became involved in this 
8 
investigation, did you try to interview 
19 
A 
We did, as well, with no such luck, as well. 
J 0 
Q 
How long ago was it that you first made contact 
21 
with Miss Miller? 
22 
A 
It was back in November of '06. 
23 
Q 
Did you try to serve her with a subpoena issued 
24 
on behalf of this grand jury? 
25 
A 
Yes, we did. 
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Q 
What happened? 
2 
A 
She refused service of the grand jury subpoena. 
3 
But she was notified of when her appearance was expected 
4 
here, and a subpoena was left with her. 
5 
Q 
After that, did she obtain an attorney? 
6 
A 
Yes, she did. 
Q 
Who was that? 
8 
A 
Jim Eisenberg. He's a well-known defense 
9 
attorney here in West Palm Beach. 
10 
Q 
Who paid for that attorney? 
11 
A 
Mr. Epstein is paying for 
attorney. 
12 
Q 
Now once Miss 
secured the attorney, did 
13 
she agree to be interviewed? 
14 
A 
Yes, she did, after she was granted 6001 
15 
immunity. She requested immunity. 
16 
Q 
Did the justice department authorize that grant 
17 
of immunity? 
18 
A 
Yes, they did. 
19 
Q 
After that, did she agree to be interviewed? 
20 
A 
Yeah. It was only after she was given that 
21 
immunity that she would talk with us. 
22 
Q 
When did the interview take place? 
23 
A 
It took place at the end of April of this year, 
24 
so just a few weeks ago. 
25 
Q 
Who was present at that interview? 
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A 
Myself; my partner, agent Richards; the AUSA, 
2 
;
her attorney, Jim Eisenberg, and his 
3 
investigator; as well as
4 
Q 
What did Miss 
tell you about Jeffrey 
5 
Epstein? 
6 
A 
She stated that she had met an individual by the 
7 
name of Caroline at a party who had asked her if she 
8 
wanted to make a few bucks by giving a man a massage. She 
9 
was told that Mr. Epstein preferred them to be topless, 
10 
and she agreed to go to his house to give him a massage. 
11 
Q 
How old did Miss MI 
tell you she was at that 
12 
time? 
13 
A 
She stated she was 16 when she first started 
14 
giving Mr. Epstein massages. 
15 
Q 
Based upon your review of the evidence, is that 
16 
correct? 
17 
A 
No. We have phone records where Sara Kellin 
18 
(phonetic), Mr. Epstein's assistant, is contacting 
19 
on her cell phone, or using her cell phone to call Tatum's 
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cell phone starting in April of 2004, which makes 
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15. 
22 
Q 
So she said that she was 16, but your evidence 
23 
shows that she was 15, and she said that she was told she 
24 
could make a few bucks giving a topless massage? 
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A 
Yes. 
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Q 
What else did Miss 
tell you? 
2 
A 
That she went to Mr. Epstein's residence, that 
3 
Caroline took her there the first time, that when she went 
4 
upstairs she was paid $200 when she first got there by 
S 
Sara Kellin. Then she goes upstairs, and Mr. Epstein 
6 
comes in, he disrobes, puts on a towel, lays down on the 
7 
massage table and she begins to massage him. 
8 
She tells Epstein that she heard he likes 
9 
topless massages, and he told her that he did. And she 
10 
said, "Who wouldn't?" And she ended up taking of her top 
11 
during the first massage. But 
is clear that Mr. 
12 
Epstein did not at any point touch her during the massage. 
13 
Q 
But does she admit that he touched himself? 
14 
A 
Yes. On the second massage, Mr. Epstein asked 
15 
her to leave her phone number with Sara. Her phone number 
16 
was left there. On the second massage, she returned the 
17 
very next day and gave him another massage. This time, 
18 
Mr. Epstein masturbated in Iront of her. 
19 
Q 
Did Miss Miller admit that he masturbated on 
Z 0 
more than one occasion in her presence? 
21 
A 
Yes, masturbated. And I think her term was that 
22 
he "released," meaning that he ejaculated. 
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Q 
How long of a period of time did Miss 
24 
tell you that she performed massages? 
25 
A 
She wasn't able to give us a number of massages, 
EFTA00226564

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but just said that it was a lot, and that she had been 
giving him massages lor a year. 
Q 
You mentioned to the grand jury that Miss 
said that Mr. Epstein never touched her, correct? 
A 
Yes. 
Q 
And she was very adamant about that? 
A 
Yes, she was. 
Q 
Were there other things that she was adamant 
about in her interview with you? 
A 
well, she talked about what she would tell the 
girls that -- and that she told Mr. Epstein that she was 
18. I'm sorry, I take that back. She was told to say 
that she was 18, and she told us that she had a fake I.D. 
showing that she was 18. 
So she passed that information along to the 
other girls when she brought -- eventually she brought 
other girls to perform massages, and that was one of the 
things that she told -- she told us first that she brought 
18- to 20-year old girls. And then she stated that if the 
girls lied, and they were underage, she told them that 
they needed to tell Epstein that they were 18. 
Q 
Have you been able to identify some of the girls 
that Miss 
brought to Mr. Epstein's home? 
A 
Yes. 
• 
Were any of those girls over 18? 
EFTA00226565

Page 9 
1 
A 
No, not that we found so far. 
2 
Q 
Have any of the girls told investigators about 
3 
what Mr. Epstein knew about their ages? 
4 
A 
I'm sorry, say that again. 
5 
Q 
Have any of the girls who came through Tatum 
6 
been interviewed about what Mr. Epstein knew about 
7 
their ages? 
8 
A 
We did interview them regarding that, and I'm 
9 
not sure if he asked them. They were all told to say they 
10 
were 18, but not on every occasion would Mr. Epstein 
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inquire about their age. 
12 
Q 
Do you want to check your records on that? 
13 
A 
Yes, could I do that? 
14 
Q 
Yes, please do. 
15 
A 
I can tell you that one of the girls that she 
16 
brought -- this girl told Mr. Epstein that she was in high 
17 
school, and actually told him her true age, which was 
18 
under 18. 
19 
Q 
So what 
told you about, that wasn't 
20 
really the case? 
21 
A 
No, that wasn't. Sorry. 
22 
Q 
That's all right, I just wanted to make sure 
23 
it's clear. 
24 
So Miss 
told you that she had been told 
25 
to say she was 18, and she also told you that she had a 
EFTA00226566

Page 10 
1 
fake I.D.? 
2 
A 
Yes. 
3 
Q 
Did she ever say that Mr. Epstein either asked 
4 
for her age or asked to see her I.D.? 
5 
A 
No, the topic never came up. 
6 
Q 
Did you also ask her about how appointments were 
7 
made? 
8 
A 
Yes. She was very clear in the fact that Sara 
9 
Kellin would call her to arrange the appointments, but 
10 
that Sara Kellin would call her once Jeffrey was in town. 
11 
Q 
So she was adamant that the calls only happened 
12 
when she was already here? 
13 
A 
Yes. 
14 
Q 
Were you made aware that Epstein's counsel was 
15 
informed that he was being investigated for traveling to 
16 
engage in prostitution, which means that the appointments 
17 
would have been made before the traveling? 
18 
A 
Yes. 
19 
Q 
Was there anything else, besides the issue of 
20 
age and the issue of when the appointments were made, that 
21 
sounded coached or that she was especially adamant about? 
22 
A 
No, I wouldn't say coached. I mean, we talked 
23 
about the preferences that Jeffrey discussed, as far as 
24 
which girls he would like 
to bring. 
25 
Once 
started giving massages to Epstein, 
EFTA00226567

Page 11 
told us that he liked different faces, so he would 
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Q 
And he didn't allow that girl to perform a 
18 
massage? 
19 
A 
No. 
20 
Q 
was there anything else that Miss Miller talked 
21 
about in the interview that you want to share with the 
22 
grand jury? 
23 
24 
was in love with Mr. Epstein. She looked into the camera 
25 
and said that she loved him like a friend. But then she 
ask her to bring other girls. We asked her if he ever 
gave any preferences of what he preferred, and her 
response was that Epstein liked girls like her, which is 
thin and blond and attractive. 
Q 
And how old was she at the time? 
A 
She was 15. 
Q 
So thin, blonde, attractive and --
A 
Young, girls like her. I guess we asked if she 
ever made a mistake, or ever brought somebody that Mr. 
Epstein didn't take to. She said that she had screwed up 
and that she had brought a black girl to Mr. Epstein, and 
that Epstein was not interested in black girls. But he 
did pay her, and said that he wasn't a racist. He paid 
her the S200 for her time, but did not want her to perform 
a massage for him. 
A 
I did ask her at the end of the interview if she 
EFTA00226568

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Page 12 
kind of looked into the camera and gave a wink and a smile 
and said, "But with your money, I'd marry you any time, 
Jeffrey." 
Q 
Did she also say that she considered him to be 
an "awesome guy"? 
A 
Several times she referred to him as an "awesome 
guy". She said that the girls begged her to come and that 
the girls didn't have a complaint, and the girls would 
share with her everything that happened after the massage, 
and that Jeffrey never touched any of the girls. But as I 
informed you, we did interview some of the girls that she 
took, and he has touched them. 
Q 
In preparation for your testimony today, did you 
also speak with someone who is considered to be an expert 
in these cases? 
A 
Yes. 
Q 
And what is that person's name? 
A 
Ken Lanning. 
Q 
Has Mr. Lanning been qualified to testify as an 
expert in federal and state courts in cases that involve 
what he calls "compliant victims"? 
A 
Yes. 
Q 
What does he mean by the term "compliant 
victims"? 
A 
A compliant victim is when a victim is not 
EFTA00226569

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necessarily forced into the conduct that the offender 
wants them to engage into, that they actually consent to 
that kind of activity. 
Q 
So that would include minors who are subjected 
to sexual activity but weren't necessarily kidnapped or 
forced at gunpoint, or something like that? 
A 
Exactly. 
Q 
Did he discuss with you the difficulties that 
exist when you interview those types of victims? 
A 
Yes. He stated that a compliant victim is often 
times embarrassed that they went along with the behavior. 
They are also likely to deny the behavior, especially when 
being interviewed by investigators, that they'll deny it 
or they'll minimize it. Sometimes it takes two, three or 
multiple interviews to get compliant victims to either 
trust their interviewer or realize that their interviewer 
is not going to be judgemental. 
Q 
In this case, have you found that to be the case 
with some of the interviews? 
A 
Yes, I have. 
Q 
In addition to being embarrassed, sometimes 
these victims feel guilty about the fact that they were 
involved in this type of activity? 
A 
Oh, yes. 
Q 
Does Mr. Lanning also have expertise in sexual 
EFTA00226570

Page 14 
1 
preference of offenders? 
2 
A 
Yes, he does. 
3 
Q 
Did he explain why an offender would select the 
4 
types of victims that are involved in this case, girls 
5 
between 14 and 17-years-old? 
6 
A 
This type of offender, the sexual preference he 
7 
has is for post-pubescent females that are physically 
8 
developed but not necessarily mentally matured. The girls 
9 
ranging in this age are sometimes inexperienced, they are 
10 
possibly naive, not as worldly. 
11 
An offender of this type could also maybe not 
12 
feel sexually adequate or feel competent dealing with his 
13 
own age group. So knowing that these girls are less 
14 
experienced, may focus on them as well. 
15 
Q 
In addition to their emotional immaturity, did 
16 
Mr. Lanning talk about whether or not younger girls are 
17 
easier to manipulate than grown women? 
18 
A 
Yes. 
19 
Q 
Did he talk to you about "grooming"? 
20 
A 
Yeah. That's what an offender will use with a 
21 
compliant victim. He told us that grooming is a technique 
22 
where you gain the cooperation of those victims by 
23 
focusing on their interests and playing up to those 
24 
interests. It's a type of seduction, he called it. That 
25 
was his words for it. And we actually see this in this 
EFTA00226571

Page 15 
case. 
2 
Q 
Can you give us an example of some of the types 
3 
of grooming that Mr. Epstein used? 
4 
S 
today, 
P., it's very apparent interviewing her how 
6 
Epstein groomed her. She only went to three or lour 
7 
massages at this time, that she's admitted to. We feel 
8 
that due to her phone conversations, the multiple calls, 
9 
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14 
that shyness. He told her that she was pretty. He asked 
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bit more -- I guess he sees that it's not working. This 
A 
With one of the girls we're going to talk about 
that there may be more there. At this point she has 
stated to us that she has performed three or four massages 
for Mr. Epstein. 
What he did is when she first went there he 
played upon -- she was very shy, and he would play upon 
her to remove her clothing, and she would not. So he kind 
of kidded around with her shyness and complimented her, 
showed interest in her, talked about her boyfriend and 
different interests she had. 
At the end of that interview, because she did 
not take off her clothes, he tells her that if she's 
willing to do more, she will make more. He also tells her 
that he would pay her if she would bring other girls. As 
the massages increased, you can see that the next time she 
comes he plays again to that shyness, but he gets a little 
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time she does comply and takes off her -- he asked her to 
disrobe on the second massage. She takes off her blouse, 
but she refuses to take off the bra after Mr. Epstein 
asked her to. 
So you can see that he tries through showing 
interest. And then he actually -- when he sees that this 
isn't working, he takes a more authoritative role with her 
in the last massage. She said that throughout all of 
these massages he was very nice, and then at the end he 
was much more frustrated and irritated. She does get down 
to her bra and panties on that one, he's just much 
more authoritative. 
So he started with the grooming process, tried 
to get her interest, tried to use that to get her to 
comply with removing her clothes. But as often happens, 
at the end of this, he took over and was much more 
forceful with his requests. 
Q 
Have other girls described that same situation 
where every time they went back, he tried to push it one 
step further and one step further? 
A 
Yes. Several of the girls have said that he 
would always push for more and more. 
Q 
Did Mr. Lanning explain why it is that a 
compliant child victim cannot legally consent to the 
sexual conduct? 
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A 
Yeah. He stated that -- you know, we talked 
about how the law protects children, and stated that we 
hold adults accountable. When it comes to adolescents, 
they go through normal tendencies that mature offenders 
may try to take advantage of. But the law is in place lor 
that reason, to protect -- in the federal law, to protect 
those individuals under the age of 18. 
• 
And that's because of the different maturity 
levels of the --
A 
The offender versus the victims, exactly. 
Q 
Did you put together the photographs of the 
defendants in this case? 
A 
Yes, I did. 
Q 
Are these photographs of the four human 
defendants who are named in the proposed indictment? 
A 
Yes. 
• 
With their names underneath them? 
A 
Yes. 
• 
Agent, who is in the top left-hand corner? 
A 
That's Jeffrey Epstein. 
Q 
When was this photograph taken? 
A 
Recently. There was an article that just came 
out regarding Mr. Epstein and his connection, or his 
personal relationship with Prince Andrew, and that was a 
picture that was in that article. 
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Q 
Who is in the to ri ht-hand corner? 
A 
That's 
Q 
Again, this is a relatively recent photograph? 
A 
Yes, that's his personal assistant. 
Q 
And the bottom left-hand corner? 
A 
Again, that is one of Mr. Epstein's personal 
assistants, that's Adriana Mousenska (phonetic). 
Has Miss Mousenska since gotten married? 
A 
Yes, her name now is 
Q 
And the bottom right-hand corner? 
A 
That is 
She is, again, a 
personal assistant to Mr. Epstein. There has been some 
talk that she is also romantically -- or I should say 
sexually involved with Mr. Epstein. 
Q 
How old are the defendants? 
A 
Jeffrey is in his mid-fifties, and the three 
girls are in their early twenties. 
Do you have a copy of the draft indictment in 
front of you? 
A 
Yes, I do. 
You mentioned when we were looking at the 
photographs that the three females work as personal 
assistants for Mr. Epstein, is that correct? 
A 
Yes. 
So he is their employer? 
EFTA00226575