EFTA00750774

Page 337 
1 
A. I don't remember. 
2 
Q. How much time passed? 
3 
A. I don't remember. 
4 
Q. A week? A month? Six months? 
5 
A. I don't remember. 
6 
Q. And what did you say? When — what did you 
7 
say to. 
when she said, would you lice to go back to 
8 
the house with me? 
9 
A. I don't — I don't remember. 
10 
Q. Well, did you mislead her? Did you say, no, 
11 
I — I don't want to go back? 
12 
A. No. 
13 
Q. Did you tell her, I'm going back on my own? 
14 
Well, let me ask you this: Had you — strike 
15 
the last question. 
16 
lied you gone back to Mr. Epstein's house in 
17 
between the first time and the time that El next asked 
18 
you? 
19 
A. Yes. 
20 
Q. Okay. How many times had you been back as —
21 
how much time transpired between the first time and the 
22 
second time you went to Mr. Epstein's home? 
23 
A. lam not sure. 
24 
Q. Was it a week? A month? A day? 
25 
A. I don't know who — maybe a week or two. 
Page 339 
1 
COURT REPORTER: "Did he ask you whether 
2 
you'd want to come over?" I didn't bear your 
3 
response, if you answered. 
. 
4 
THE WITNESS: Yes. 
5 
BY MR. CRITTON: 
6 
Q. And that one or two occasions that he called 
7 
you, he basically said, do you want to come over? 
8 
MR EDWARDS: Form. 
9 
THE WITNESS: He — I don't remember exactly 
10 
what he said to me. But, normally, when ?Igor 
11 
r
icalled me they would call me ah 
o tune 
12 
to
me that Jeffrey was going to be in town, 
13 
would I like to come over. 
14 
BY MR. CM-TON: 
15 
Q. Right. And that was the extent of the 
16 
conversation? 
17 
A. They would tell me — 
18 
Q. You would say yes or no? 
19 
A. Yes. And they would tell me what day and 
20 
what time to be there. 
21 
Q. All right. And you understood that 
22 
Mr. Epstein has a residence in Palm Beach? 
23 
A. Yes. 
24 
Q. And you understood that he had residences in 
25 
other places? 
Page 338 
1 
Q. All right. And then I think you told me 
2 
someone called you, some — a female called you. 
3 
A. Sometimes -called me, and once in a 
4 
while Jeffrey called me himself. 
5 
Q. Okay. Mr. Epstein never called you directly, 
6 
did he? 
7 
A. Yes. 
8 
Q. You said you went to his house 
9 
approximately — approximately 20 times —
10 
A. Yes. 
11 
Q. 
— during the — during the time span that 
12 
you identified earlier. 
13 
A. Yes. 
14 
Q. All right. Would the vast majority of times 
15 
that he called you — I'm sorry that you were called, 
16 
either MI or 
made the call? 
17 
A. Yes. 
18 
Q. Okay. On how many occasions, your best 
19 
recollection, did Mr. Epstein ever call you? 
20 
A. One. Maybe two. 
21 
Q. And on the one or two occasions that 
22 
Mr. Epstein ever calledyou, did he ask you whether 
23 
you'd want to come ova? What did he say? 
24 
COURT REPORTER: I didn't hear any response. 
25 
MR. CItITTON: Oh, I'm sorry. 
Page 340 
1 
A. Not at the time. 
2 
Q. Okay. And you just thought he lived MI 
3 
time in West Palm Beach 
or in Palm Beach? 
4 
A. No, I — [knew that he went out of town a 
5 
lot. 
6 
Q. All right. So you knew that he went out of 
7 
town for business, as well as doing business here in 
8 
Palm Beach? 
9 
MR. EDWARDS: Form. 
10 
THE WITNESS: I have no idea what he was 
11 
going out of town for. 
12 
BY MR. CRITTON:.
13 
Q. Okay. Did you ever know what his business 
14 
was? 
15 
A. No. 
16 
Q. All right. Was — during the time that you 
17 
ever gave a massage to Mr. Epstein, did he 
was he on 
18 
the phone? 
19 
A. Yes. 
20 
Q. Okay. And often would he be doing what 
21 
appeared to be business over the phone while you were 
22 
giving him a massage — or engaging in conversations 
23 
with someone? 
24 
A. Yes. 
25 
Q. All right. And did it appear from time to 
(561) 832-7500 
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Electronically signed by Pamela Sullivan (501-333-772-1552) 
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Page 341 
1 
time that he was engaged in business? 
2 
MR. EDWARDS: Form. 
3 
THE WITNESS: Sometimes, yes. 
4 
BY MR. CRITTON: 
5 
Q. All right. And you understood that — at 
6 
least you understood that his main residence was in, 
7 
from what you understood dining the time that you went 
8 
there, his main residence was in Palm Beach, Florida, 
9 
and that he would just travel out of town, and then come 
10 
back into town occasionally, you know, he would travel 
11 
out of town occasionally, but basically lived in Palm 
12 
Beath? 
13 
A. I did not !mow. I really... 
14 
Q. You said that was the only residence that 
15 
you — or the only place that you understood that he 
16 
lived? 
17 
A. That's the only place that I knew of, but 
18 
I — I didn't know, you know, what he was doing when he 
19 
was going out of town or whatever he was doing. 
20 
Q But you knew he had — he — that was his 
21 
home, at least one of his homes? 
22 
A. I 'mew that he lived there. 
23 
Q. All right. You never traveled anyplace with 
24 
Mr. Epstein; did you? 
25 
A. No. 
Page 343 
1 
discussed; was it? 
2 
MR. EDWARDS: Form. 
3. 
THE WITNESS: No. 
4 
BY MR. CRITTON: 
5 
Q. Okay. And the one or two times that 
6 
Mr. Epstein ever called you, the subject of — of any 
7 
type of engaging in any type of sexual conduct was never 
8 
dic.nmerad; was it? 
9 
A. No — yes, it was, actually. 
10 
Q. Well, ma'am, you said, no; then you said, 
11 
yes. What is it? What's the answer? 
12 
A. Yes, he did discuss with me that he would pay 
13 
me extra money for having sex with him. 
14 
Q. Did you tell the FBI that? 
15 
A. Yea And he 
be tried to, 'guess, 
16 
convince me to do it by telling me that-- his exact 
17 
words to me were that he used to fuck 
all the time. 
18 
Q. When did — when did this call purportedly 
19 
take place? 
20 
A. I was at his house, and... 
21 
Q. At his house? 
22 
A. Yes. 
23 
Q. What were you doing at his house? 
24 
A. I was giving him a massage. 
25 
Q. Oh, I thought 
okay. Maybe you 
Page 342 
1 
Q. You never accompanied him on any trip; did 
2 
you? 
3 
A. No. 
4 
Q. Mr. Epstein never text -- text'd you by 
5 
phone; did he? 
6 
A. No. 
7 
Q. Mr. Epstein never e-mailed you or sent you 
8 
any type of mail; did he? 
9 
A. No. 
10 
Q. Neither 
nor 
or anyone who worked 
11 
for Mr. Epstein ever texrd you by phone; did they? 
12 
A. No. 
13 
Q. They never sent you anything by e-mail or by 
14' 
mail; did they? 
15 
A. No. 
16 
. Okay. And when they — they, either 
17 
or whoever else may have called, other than 
18 
Mr. Epstein, they basically said, Jeffrey's in town, 
19 
would you like to come over? 
20 
A. Yes. 
21 
Q And then they would give you a time? 
22 
A. Yes. 
23 
And at no time in any conversation with 
24 
or 
or anyone who worked for Mr. Epstein was the 
25 
subject of engaging in any type of sexual conduct ever 
ur 
Page 344 
1 
misunderstood my question. 
2 
When Mr. Epstein — the one or two times that 
3 
you ever spoke with Mr. Epstein over the phone, okay, 
4 
the subject of engaging in any type of sexual activity 
5 
or conduct never attuned; did it? 
6 
MR. EDWARDS: Form. 
7 
THE WITNESS: Not over the phone. 
8 
BY MR. CRITTON: 
9 
Q. I'm sorry? 
10 
A. Not --
11 
Q. Not over the phone? 
12 
A. —over the phone. 
13 
14 
• 
All right. And neither 
= 
nor 
or anyone else, including Mr. Epstein, ever 
15 
attempted to persuade or to induce or to entice you into 
16 
any type of sexual conduct during any phone 
17 
communication; true? 
18 
A. Yes, that's true. 
19 
Q. Did you ever bring anyone to Mr. Epstein's 
20 
house? 
23. 
A. No. 
22 
Q. Do you know a person named 
23 
cousin? 
24 
A. 
25 
. 
Q. 
? 
who's your 
22 (Pages 341 to 344) 
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Electronically signed by Pamela Sullivan (601333-772.1652) 
Electronically signed by Pamela Sullivan (501-333-772-1552) 
(561) 832-7506 
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EFTA00750795

Page 345 
A. Yes. 
Q. Did you brink; 
-- you know — you're 
1 
aware Amanda MI 
went to Mr. Epstein's home? 
4 
A. Yes. I did not bring her, though. 
5 
Q. And she was 19 or 20 when she went; isn't 
6 
that true? 
7 
A. Yes. 
8 
Q. Okay. And who took or asked Amanda 
to 
9 
go to Mr. Epstein's home? 
10 
A. I believe it was.. or.. 
11 
Q. And how did you find out that 
your 
12 
cousin, went to Mr. Epstein's home? 
13 
A. I don't remember. Either she told me, or 
14 
told me, or 
told me. 
15 
Q. And did you ever talk with ■ 
about what 
16 
the did at Mr. Epstein's home? 
17 
A. No. 
18 
Q. Was she aware — she, 
aware that you 
19 
went? 
20 
A. I don't think so. 
21 
Q. And you're aware she went, but you never 
22 
raised the topic with her? 
23 
A. Right. 
24 
Q. By the way, who— who knows that you area 
25 
Plaintiff in the action, Jane Doe versus Epstein? 
1 
2 
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Page 347 
Q. How about your sister, a? 
A. I haven't told her myself, but I'm sure that 
she knows, because other people have gone to her house. 
Q. Okay. Other people have told her, or other 
people have just asked her questions? 
MR. EDWARDS: Form. 
TILE WITNESS: I don't know what she was told. 
BY MR. CRITTON: 
Q. Okay. How about I., 
your sister, ME, 
does she know you're a Plaintiff in this lawsuit —
A. No. 
Q. 
— or any lawsuit? 
A. No. 
Q. Okay. Have you sold or agreed to assign any 
portion of any recovery to anyone? 
MR. EDWARDS: Form. 
THE WITNESS: No. 
BY MR. CRITTON: 
Q. Your psychologist, 
he knows 
you're a Plaintiff in a lawsuit? 
A. Yes. 
Q. Okay. Who else knows you're a Plaintiff in a 
civil lawsuit against Mr. Epstein? 
A. I don't know. 
Q. Any of your other friends know? 
Page 346 
1 
knows; right? 
2 
MR. EDWARDS: Object to the form. 
3 
BY MR.. CRITTON: 
4 
Q. First you need to answer that question. 
5 
knows you're a Plaintiff; right? 
6 
MR. EDWARDS: Object to the form. 
7 
THE WITNESS: Yes. 
8 
BY MR. CRITTON: 
9 
Q. Okay. 
knows you're a Plaintiff? 
10 
MR. EDWARDS: Form. 
11 
THE WITNESS: Yes. 
12 
BY MR. CRITTON: 
13 
Q. Does 
know --
14 
A. Yes. 
15 
Q. 
— you're a Plaintiff? 
16 
A. Yes. 
17 
Q. Does 
know you're a Plaintiff? 
18 
A. Yes. 
19 
Q. Does your mother know you're a Plaintiff? 
20 
A. I don't know. 
21 
Q. Did you tell your dad,_? 
22 
A. No. 
23 
Q. . So hes unaware that you're — you have a 
24 
lawsuit that's going? 
25 
A. No -- he is unaware, yes. 
1 
2 
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5 
6 
7 
8 
9 
10 
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Page 348 
A. No. 
Q. Okay. Are you aware that if, in fact, this 
case is not resolved, you may well — the case may be 
tried, and your anonymity may no longer exist —
MR. EDWARDS: Form. 
BY MR. CRITTON: 
Q. -- because everyone may know that you're the 
Plaintiff', Jane Doe, against Mr. Epstein; do you 
understand that fact? 
MR. EDWARDS: Form. 
THE WITNESS: Yes. 
BY MR. CRITTON: 
Q. I think you told me you never brought any 
other girls to Mr. Epstein's home? 
A. No. 
Q. Okay. After you said 
asked you if 
you — if you would like to go back to Mr. Epstein's.—
to it Epstein's house, but you had already been back in 
the interim; true? 
A. Yes. 
• 
Q. Okay. And who — I. 
or someone else had 
called you and asked you if you wanted to come back? 
A. Yes. 
Q. And where were 
living at the time? 
A. With 
_ 
- 
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PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Pamela Sullivan (601-333-772-1552) 
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Page 349 
1 
Q. Who drove you to Mr. Epstein's house? 
2 
A. Cab. 
3 
Q. When the person called and asked whether you 
4 
want — whether you wanted to come back, what did you 
5 
gin 
6 
A. At first I didn't go. 
7 
Q. Okay. So the call 
or whoever 
8 
called, and you said, Pm not interested. 
9 
A. Yes. 
10 
Q. All right. And did you say, don't call me 
11 
again? 
12 
A. No. 
13 
Q. Why not? 
14 
A. I didn't think to say something like that. 
15 
Q. And did you get another call? 
16 
A. Yes. 
17 
Q. And you had a cell phone at the time? 
18 
A. Yes. 
19 
Q. And what cell phone number was that? Was 
20 
that the 584? 
21 
A. No. I don't remember the entire number. It 
22 
was a number that started with 352, though. 
23 
Q. That's the 352 one you don't remember? 
24 
A. Uh-huh. 
25 
Q. But cell phones pop up a number, so you -- do 
Page 351 
1 
A. Yes. 
2 
Q. And she said, you know, I know you couldn't 
3 
come last time. How about coming this. Would you like 
4 
to come? 
5 
A. Yes. 
6 
Q. And did you say, no, not interested anymore, 
7 
don't call me anymore? 
8 
A. No. 
9 
Q. Okay. Son called a second time, and you 
10 
said what? 
11 
A. She told me that she — that Jeffrey needed 
12 
me to come, because he didn't have anybody else who 
13 
could came. SO I came. 
14 
Q. How was that your problem? 
15 
A. It wasn't. 
16 
Q. All right. So she said that — she said what 
17 
you just described, and you made a conscious decision 
18 
that you would go back to Mr. Epstein's home? 
19 
MR. EDWARDS: Form. 
20 
THE WITNESS: Yes. 
21 
BY MR. CRITFON: 
22 
Q. Right. And you voluntarily chose to go back 
23 
to his house a second time? 
24 
A. Yes. 
25 
Q. No one forced you; correct? 
Page 350 
1 
you remember what number that would be called -- that 
2 
is, the number that would be calling you --
3 
A. Yes. 
4 
Q. — from the Epstein home? 
5 
A. Yes. 
6 
Q. That number you do remember? What was the 
7 
number? 
8 
A. I don't — it was always a different number, 
9 
and it normally started with 688. 
10 
Q. Why did you answer it? 
11 
A. I didn't know who it was. 
12 
Q. Okay. So I assume you knew how to do voice 
13 
messages, voice mail; right? 
14 
A. I just answered it. 
15 
Q. My question is, is: Why didn't you just 
16 
let — if you weren't sure who the number was, a lot of 
17 
people just let the phone ring, go to voice mail. Then 
18 
if you want to call them back, you call them back. If 
19 
you don't want to call them back, you don't have to. 
20 
MR. EDWARDS: Form. 
21 
THE WITNESS: Because I wanted to know who it 
22 
was. 
23 
BY MR. CR/TION: 
24 
Q. Okay. So they called, and who was it? III 
25 
seam or someone? 
1 
2 
3 
4 
6 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 352 
A. Correct. 
Q. Okay. And it was your choice. That is, you 
could have said, sony, I'm not going back to the 
Epstein home. Didn't enjoy the experience. Wasn't a 
good experience. Pm done. You could have done that; 
couldn't you? 
A. I didn't think of doing that, no. 
Q. Sure you thought of it because the first 
phone call that you got from
 you said, no, I'm not 
going, So you had to have consciously thought is, I 
don't want to go again; right? 
A. No. 
Q. lint sony? 
A. No. 
Q. No what? 
A. That wasn't my thought. 
Q. But your first thought was, when she called 
you the first time was, is, I don't want to go back; 
HMO 
A. No. 
Q. Okay. So after the first time that you went, 
you had already made up your mind you would go again, if 
they called? 
A. No. 
Q. So what changed your mind? 
24 (Pages 349 to 352) 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Pamela Sullivan (601-333-772-1652) 
Electronically signed by Pamela Sullivan (501-333.772-1652) 
(561) 832-7506 
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Page 353 
1 
A. It's 
it wasn't that my mind was changed. 
2 
I just, l just didn't go the first time. I don't 'mow 
3 
why. I was probably doing something; that's probably 
4 
why. The only reason I ever went back was because he 
5 
made me feel like I was obligated to keep going. 
6 
Q. Why? What obligation did you have to go to 
7 
Mr. Epstein's? 
8 
A. I didn't. He was like just very demanding, 
9 
and he just — he just told me what to do, and ljust 
10 
felt like I needed to do it 
11 
Q. Well, you were able to get away from your 
12 
stalking boyfriend; right? That wasn't a problem for 
13 
you? 
14 
MR. EDWARDS: Form. 
15 
THE WITNESS: He, he still calls me today, 
16 
so, yeah, it is a problem for me. 
17 
BY MR. CRITION: 
18 
Q. That 
were — well, you were able to run 
19 
away from 
house and your mother's house at 
20 
various times and to live with somebody else, before you 
21 
ever met Mr. Epstein; true? 
22 
A. I ran away from my mother's house, yes. 
23 
Q. Okay. And you -- you were strong enough to 
24 
do that, and you knew, at least in your own mind, what 
25 
you wanted to do. You had a mind of your own at that 
Page 355 
1 
you? 
2 
A. It was not an option that I thought that ! 
3 
had. 
4 
Q. Wiry? 
5 
A. Because I was too young to understood. 
6 
Q. Well, you were young enough to run away from 
7 
your mother's house, you understood that, and to go to 
8 
what 
considered to be a safe place at -- was it 
9 
house? 
10 
A. Yes. 
11 
Q. All right You understood that; right? 
12 
A. Yes. 
13 
Q. Okay. You were -- you understood enough that 
14 
you gave varying testimony during the trial and various 
15 
depositions of your father to either help him or hurt 
16 
him, depending on who was influencing you; right? 
17 
MR. EDWARDS: Form. 
18 
THE WITNESS: And during that time I had no 
19 
idea what 1 was doing. 
20 
BY MR. CRITTON: 
21 
Q. All right And you knew when 
or 
22 
whoever called, called you and said, you know, would you 
23 
like to come back, you could say yes or no. it was that 
24 
simple. 
MR. EDWARDS: Form. 
Page 354 
1 
point; true? 
2 
MR. EDWARDS: Form. 
3 
THE WITNESS: I didn't have a choice but to 
4 
leave at the time. 
5 
BY MR. CRITTON: 
6 
Q. All right. Well, you had a choice either to 
7 
go beck to Mr. Epstein's or not to go back to 
8 
Mr. Epstein's. You had to first say, yes, to the person 
9 
who called; correct? You had a choice: I'll say yes, 
10 
or ni say no. Pro living out west of town. 
11 
Mr. Epstein lives in, you know, Palm Beach. He's got no 
12 
hold over me; right? He had no hold over you. 
13 
MR. EDWARDS: Pam. 
14 
THE WITNESS: Yes, but I just knew that they 
15 
would continue to call me. 
16 
BY MR CRITTON: 
17 
Q. So call the police. Why didn't you call the 
18 
police? You knew how to get ahold of the police; right? 
19 
A. That wasn't the — 
20 
Q. You'd had issues with the police before? 
21 
MR. EDWARDS: Form. 
22 
THE WITNESS: That was not the first thing I 
23 
thought of. 
24 
BY MR. CRITTON: 
25 
Q. But it was an option that was available to 
1 
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21' 
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Page 356 
THE WITNESS: It was more like, could you 
please come back. 
BY MR. CRITTON: 
Q. Okay. So, so they said, please. You could 
say, thanks, but no thanks. You had said, thanks, but 
no thanks, before; right? 
A. I didn't know. I didn't !mow —
Q. &we you — 
A. 
— that that was an option. 
Q. Sure you did, because —
A. Oh, you did? 
Q. Yeah. Because when you were in school at 
both — in eighth grade, that you repeated, and then 
when you were at Paco, you made decisions not to go to 
school and to remain truant from school; didn't you? 
A. That's because 1 could not go to school. 
Q. Why not? 
A. It was not an option forme. 
Q. Why? 
A. Because I was being abused at my mother's 
house. 
Q BY? 
A. And if I went back — if I went to school, 
then that would mean going back to my mom's. 
Q. Okay. Who was abusing you at your mother's 
(562) 832-7500 
25 (Pages 353 to 356) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Pamela Sullivan (501-333.772.1652) 
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Page 357 
1 
house? 
2 
A. My mother. 
3 
Q. Okay. And how was she abusing you? 
4 
A. She wasn't feedin me. 
5
Q. Did you tell 
that? 
6 
A. Yes. 
7 
O. And that's why you went to live with II 
9 
10 
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12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A. Yes. 
Q. Okay. And she wasn't feeding you. Did —
were — had you ever been abused by your father or by 
Mr. Veet? 
A. No. 
Q. Okay. Did any family member, other than your 
mother, ever physically abuse you? 
A. Yes. 
Q. Who? 
A. My uncle. 
Q Which uncle? 
A. 
A. Yes. 
Q. How did he abuse you? How old were you, and 
how did he abuse you? 
A. I don't know. I was probably Ile 15, and he 
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Page 359 
A. No. 
Q. Did you tell your M? 
A. Yes. 
Q. And what did she say? 
A. I don't remember. 
.
Did she call the
nce? 
Q. Police come? 
A. Yes. 
Q. What did they do? 
A. They didn't do anything. 
Q. Did you have any physical marks? 
A. Yes. 
Q. Okay. What did you have? Where did he hit 
you? Did he hit you in the nose? What part of your 
face did he hit? 
A. I had a bump on my head somewhere. I'm 
not — I don't remember where it was. 
Q. But he hit you with his fist? 
A. Yes. 
Q. Did you leave the house after that? 
A. No, he did, because I called the police. 
Q. Did he ever come back? 
A. Yes. 
Q. . Did you consider that a pretty traumatic 
Page 358 
1 
hit me. 
2 
Q. Where did he hit you? 
3 
A. He punched me in the face. 
4 
Q. Was he drunk? Was he on drugs, Jane Doe? 
5 
A. I don't know. 
6 
Q. Where were you at the time? 
7 
A. I was in my bedroom. 
8 
Q. Okay. And did he come into your bedroom? 
9 
A. I was walking out. 
10 
Q. ' And he just cold-cocked you? 
13. 
• A. We were limning. 
• 
12 
Q. What were you arguing about? 
13 
A. I don't remember. 
14 
Q. And he punched you right in the face? 
15 
A. Yes. 
16 
Q. Did he break anything? 
17 
A. No. 
18 
Q. Did you have to go to the hospital? 
19 
A. No: 
20 
Q. You were living where, at your 
21 
house then? 
22. 
A. Yes. 
23 
Q. Did you get blocked down? 
24 
A. No. 
25 
• 
Q. Were you knocked out? 
Q. Where does the 
come from? 
(561) 832-7500 
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Page 360 
event, to have an uncle haul off and hit you in the 
face? 
MR. EDWARDS: Form. 
THE WITNESS: No. 
BY MR. CIIITTON: 
Q. Didn't consider that to be traumatic at all? 
MR. EDWARDS: Form. 
THE WITNESS: Not really. 
BY MR. CRITFON: 
Q. Okay. Had anybody else ever hit you in the 
face like that? 
A. Mykisters. 
Q. 
and 
A. And my brother, yes. 
Q. Which brother? 
A. I only have one brother. 
Q. What's his name? 
A. 
Q. It's 
Is 
in jail? 
A. Not tight now. 
Q. He's been in jail, though, before? 
A. Yes. 
Q. [sit 
MP 
Q.
26 (Pages 357 to 360) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (601-333-772-1552) 
Electronically signed by Pamela Sullivan (601.333-772-1552) 
92ef5b62-38a5-4202-a350-6633a5c6813b 
EFTA00750799

Page 
1 
A. My mother. 
2 
Q. Are there any -- is he a -- is he a El 
3 
child? 
4 
A. Yes. 
5 
Q. Whets he been in jail for? 
6 
A. Robbery. 
7 
Q. On how many occasions? 
A. 
I don't know. 
9 
Q. Are you close to your brother? 
10 
11 
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A. Somewhat. 
Q. When is the last time he was in jail? 
A. 
I don't know. 
Q. Do you consider it traumatic that your 
brother was in jail? 
MR. EDWARDS: Form. 
THE WIDIESS: He put himself in jail. 
BY MR. CRITTON: 
Q. So he -- he basically made his bed, and then 
he slept in it? 
A. Yes. 
Q. Is that the way you feel about your dad, too? 
A. Yes. 
Q. It was his choice to, to assault a young boy, 
and as such, he's paying the penaRy? 
A. Yes, that's the way I feel now about it. 
Page 363 
1 
A. Yeah. Not bad enough to go to the hospital 
2 
or anything. 
3 
Q. Police ever called? 
4 
A. No. 
5 
Q. Did anyone ever attempt to rape you? 
6 
A. No. 
7 
Q. Has anyone ever attempted to molest you? 
8 
A. No. 
9 
Q. Okay. You go back to Mr. Epstein's house the 
10 
second time. You had their phone number; right? 
11 
A. No. 
12 
Q. Well, you had it, because it showed up on 
13 
your phone? 
14 
A. I had seen it. 
15 
Q. Right. But all you have to do is go back to 
16 
recent calls; right? Every — every five-year-old, 
17 
six-year-old, seven-year-old kid in the world can show 
18 
me how to use a cell phone that I don't know how to use. 
19 
I assume you fall within that, too. You know how to use 
20 
a cell phone and how to get voice mail, how to make 
21 
calls, how to pull recent calls out of your phone? 
22 
MR. EDWARDS: Form. 
23 
BY MR. CIFUTION: 
24 
Q. And you knew that —
25 
A. Okay. 
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Page 362 
Q. In your earlier years were you torn, because 
he was your father? 
A. twos very confused, yes. 
Q. And I've seen on various medical records that 
you consider yourself to be suffering from, even today, 
post traumatic stress syndrome that related to that —
MR. EDWARDS: Form. 
BY MR. CRTITON: 
Q. -- related to that, that is your father 
murdering 
M
.
 
A. Yes. 
Q. Any other family member ever physically 
assault you? 
A. No. 
Q. Other -- other than your uncle and you said 
the fights that you got in with your sisters and your 
brothers. I assume those were more sisteribmther type 
fight, or were they real fight-fights? 
A. Both. 
Q. So you got into some real fights — real 
physical fights with your sisters and your brother? 
A. Yes. 
Q. Where people were hurt? 
A. Not —
Q. • Black eyes? Blood? 
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Page 364 
Q. 
— back in '03, '04, '05, '06, '07; didn't 
you? 
MR. EDWARDS: Form. 
11.1E WITNESS: Yeah. 
BY MR. CRITTON: 
Q. Okay. Did you ever — before -- you say a 
taxi was sent to pick you up? 
A. Yes. 
Q. Okay. Before that taxi got there, did you 
say to yourself, you know what, what am I doing, I don't 
need to go back there. Did you ever think of that? 
A. No. 
Q. Would it be a correct statement, ma'am, that 
there's nothing about the rust event, that is the first 
time you were at Mr. Epstein's home, that you found to 
be in any way traumatic? 
A. At the time I didn't think about it, but now 
I do, yes. 
Q. Okay. So when did you — when did you decide 
that going to Mr. Epstein's house was a traumatic event 
in your life? Who helped you come to that conclusion? 
Was that only after you filed a lawsuit in this case? 
MR. EDWARDS: Form. 
THE WITNESS: No. Soon after 1 stopped 
going, it started to bother me a lot. 
27 (Pages 361 to 364) 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 . 
Electronically signed by Pamela Sullivan (501.333-772-1552) 
Electronically signed by Pamela Sullivan (601.333.772-1652) 
92015b62.38a5.4202-a350.6833a5e8813b 
EFTA00750800

Page 365 
1 
BY MR. CRITTON: 
2 
Q. AU right. So you went 20 times to 
3 
Mr. Epstein's house, by your own testimony, and not the 
4 
rust, not the second, not the third, not the fourth, 
5 
not the tenth, not the 15th, not the 17th, not the 20th 
6 
time did you suffer any trauma; true? 
7 
MR. EDWARDS: Form. 
8 
THE WITNESS: Yes, I did. 
9 
BY MR. CRITTON: 
10 
Q. And at what time did you, in your own mind, 
11 
suffer, quote/unquote, trauma or some sort of 
12 
psychological problem as a result of being at 
13 
Mr. Epstein's? 
14 
A. Probably when I went to my program in 
M
E
I
 
15 
Q. That was in 2007? 
16 
A. That was in -- when I was 17. 
17 
Q. Okay. Which was —you went to =right 
18 
after the last time you saw Mr. Epstein? 
19 
A. Yes. 
20 
Q. So of the approximately 20 times that you 
21 
went to Mr. Epstein's, at no time did you believe that 
22 
you had suffered any physical injury; correct? 
23 
A. What do you mean? 
24 
Q. I'm just asking the question: During the 
25 
time — approximately 20 times you went to 
Page 367 
1 
A. 1 was only 17 when I went to 
2 
Q. Okay. At the time that you thought that it 
3 
was wrong to go to Mr. Epstein's, why didn't you just 
4 
say, TM not going anymore? 
5 
A. I — I didn't feel like I had that choice. 
6 
Q. What — what choice? Each time you went to 
7 
Mr. Epstein's, you had to make a choice, am I going or 
8 
am I not going - 
9 
Iva. EDWARDS: Form. 
10 
BY MR. CRITTON: 
11 
Q. —true? 
12 
A. Not really. 
13 
Q. Why not? 
14 
A. Because -
15 
Q. How could you not have a choice? Because you 
16 
lived west of town. He lived east of town. You lived 
17 
miles apart. You had to take some affirmative action in 
18 
order to get to Mr. Epstein's home; didn't you? 
19 
A. No. 
20 
Q. Why not? 
21 
A. I had to get in a cab and... 
22 
Q. That's an affirmative act. You had to either 
23 
say, I'm going, or I'm not going. 
24 
MR. EDWARDS: Objection to form. 
25 
THE WITNESS: I don't know what you mean. 
Page 366 
1 
Mr. Epstein's, you didn't believe that you had suffered 
2 
any kind of physical injury; did you? 
3 
A. No. 
4 
Q. No pain and suffering? 
5 
A. I —1 felt like it was very wrong. I 
6 
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Q. Which time? The first time? 
A. Every time. 
Q. Okay. Then after the first time you went and 
9 
you felt that going to his house was wrong — and you 
10 
knew the difference between right and wrong; didn't you? 11 
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A. Not really. 
et
You knew committing — well, as of the time 
that 
M
.
 
took you to Mr. Epstein's the very first time, 
you knew the difference between right and wrong; didn't 
you? 
MR. EDWARDS: Form. 
THE WITNESS: Not really. 
BY MR. CRITTON: 
Q. Okay. Well, how about when ou were - when 
you were working at 
or 
did 
you know the difference between right and wrong? 
A. Yes. 
Okay. Did you 
were you working at 
before you went to 
or after? 
1 
2 
3 
4 
5 
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Page 368 
BY MR. CRITTON: 
Q. Sure you do. You 'mow that — what an 
affirmative act is, taking some oven act to do a 
particular task; right? You understand that? 
MR. EDWARDS: Form. 
THE WITNESS: I don't know what you mean. 
BY MR. CRITTON: 
Q. Well, you — if -- if you have to make a 
decision, and your decision tree is I can say either do 
something or not do something, doing something is taking 
some affirmative act; right? Not doing something is —
is a negative act, or not doing an affirmative act. Do 
you understand that concept? 
A. 
I guess. 
Q. All right. And in order to go to 
Mr. Epstein's house, you had to actually say you had 
to make a mental decision, that is you had to make a 
decision in your own mind, I'm going there. And it's 
okay. Right? 
A. Yeah, I guess so. 
• 
Q. All right. You —you say that you've lost 
income and you want -- in your Rule 26 disclosures, 
which is something that your lawyer provided or filed 
with the court, you said that you've lost in excess 
of -- you have a past and fitture lost wages and past and 
(561) 832-7500 
PROSE COURT REPORTIN 
28 (Pages 365 to 368) 
G AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (601.333-7M4552) 
Electronically signed by Pamela Sullivan (501-333-772-1552) 
9205b62-38a5-4202-a350-6633a5c6813b 
EFTA00750801

Page 369 
1 
future loss of earning capacities — capacity in excess 
2 
of a million bucks. 
3 
Okay. What did Mr. Epstein -- that is, what 
4 
occurred at Mr. Epstein's that has caused you — that 
5 
caused you to lose any money as of today's date? 
6 
MR. EDWARDS: Form. 
7 
717E WITNESS: Pretty much everything. 
8 
BY MR. CliTTTON: 
9 
Q. What — what — what has Mister 
what was 
10 
your — has your experience Mr. Epstein -- excuse me --
11 
done that has caused you to lose money, as of today's 
12 
date? 
13 
A. Pretty much everything that happened at 
14 
Jeffrey Epstein's house makes me extremely depressed to 
15 
a point where I don't -- I'm extremely sluggish, and 1 
16 
don't even feel like 
tin out of bed sometimes. 
17 
Q. Other than e 
— well, let me 
18 
strike that. 
19 
If you still did not feel sluggish and you 
20 
didn't want to get out of bed, would you start stripping 
23. 
again, working at the strip clubs? 
22 
A. No. 
23 
Q. Why? 
24 
A. Because I don't want to do that anymore. 
25 
Q. Why? Because you have a child? 
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Page 371 
A. No. 
Q. Have you erased anything from your Face Book 
over the last six months? 
A. No. 
Q. Okay. Are there any photographs or 
information on your face — well, let me strike that. 
How long have you had Face Book? 
A. A few months. 
Q. Starting when? 
A. I don't know. A few months ago. 
Q. 2009, you started? 
A. Yes, this year. 
Q. Have you put any type of photographs on your 
Face Book that would in any way — you would find 
embarrassing to you — 
A. No. 
Q. 
— if someone saw it? 
Let me get back to the loss of earnings. 
Other than the jobs that you had — let milt 
worked 
as a stripper at 
Sand 
you had — you earned money , 
correct? 
A. Yes. 
Q. Okay. How much money did you earn for the 
year 2006? 
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Page 370 
A. That's part of the reason, yes. 
Q. Okay. Ma'am, have you ever had a My Space 
page or a Face Book page? 
A. I have a Face Book. 
Q. Right now? 
A. Yes, I do. 
Q. And what — what's it under; what's the 
designation under? 
A. Jane Dee. 
Q. And how would someone hook up with you by 
Face Book? What would they put in? 
A. My name. 
Q. Jane Doe? 
A. Yes. 
Q. And how long have you had a — have you ever 
had a My Space page? 
A. Yes. 
Q. And did you close that down? 
A. I've really never figured out how to make it. 
Q. Do you Face Book; do 
and fl
 Face Book 
you? 
A. No. 
Have you ever corresponded with either M. 
.
25 
or 
. through Face Book? 
1 
2 
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Page 
A. I don't know. 
Q. Did you ever keep track of it? 
A. No. 
Q. How about 2007? 
A. I don't know. 
Q. Okay. Did you ever talk with anyone about 
the need to file Federal income tax —
A. No. 
Q. 
— on the money? 
A. No. 
Q. And I think you told me earlier you've never 
filed income taxes? 
A. Right. 
Q. Okay. Approximately, do you have any idea 
how much money you made in 2006 or 2007? 
A. No. 
Q. But you were able to dance in 2006 and 2007, 
so what loss of income did Mr. Epstein — your 
experience with Mr. Epstein cause you? 
MR. EDWARDS: Form. Calls for a legal 
conclusion. 
THE WITNESS: I guess afterward, when I— I 
guess I just haven't, you know, felt like good 
enough to get another job. 
(561) 832-7500 
let 
29 (Pages 369 to 372) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (501.333.772.1562) 
Electronically signed by Pamela Sullivan (501433-772-1652) 
92ef5b62-38a5-4202-a350-6633a5c6613b 
EFTA00750802

Page 373 
1 
BY MR. CRITTON: 
2 
Q. Well, your PTSD plays a role in that, as 
3 
well; doesn't it? 
4 
MR. EDWARDS: Form. 
5 
THE WITNESS: Not really anymore. 
6 
BY MR. CRITTON: 
7 
Q. If anybody has asked you since the time that 
8 
you last saw Mr. Epstein, not only S 
but 
9 
if anybody asks about your mental state or your 
10 
emotional state, do you tell them everything? 
11 
MR. EDWARDS: Form. 
12 
THE WITNESS: No. 
13 
BY MR. CRITTON: 
14 
Q. Why not? 
15 
A. Because I don't find it easy to talk about 
16 
that. 
17 
Q. Do you think ifs easy to talk about having 
18 
seen your father murder the son of his girlfriend? 
19 
A. Not at all. 
20 
Q. Is that easier for you to talk about —
21 
MR. EDWARDS: Form. 
22 
THE WITNESS: Not at all. 
23 
BY MR. CRITTON: 
24 
Q. 
— than your experience with Mr. Epstein? 
25 
A. Not at all. 
Page 375 
1 
both of those are difficult for you to talk about? 
2 
A. Yes. 
3 
Q. Okay. And each -- each one is equally 
4 
difficult in your own mind; isn't it? 
5 
A. Yes. 
6 
Q. And so if you mentioned one, you'd probably 
7 
mention both, or you wouldn't mention either one; 
8 
correct? 
9 
MR. EDWARDS: Form. 
10 
THE WITNESS: Yes. 
11 
BY MR. CRITTON: 
12 
Q. The second tint you went back to 
13 
MT. Epstein's home, aisthire different happen than the 
14 
first time, other than M. wasn't there? 
15 
A. Not really. 
16 
Q. When is the next time you went back, then? 
17 
A. I don't know. 
18 
Q. How many banes did you go back in the year 
19 
2003? 
20 
A. I don't know. 
21 
Q. How many times did you go back in the year 
22 
2004? 
23 
A. I don't know. 
24 
Q. 
25 
2005? 
How many times did you go back in the year 
Page 374 
1 
Q. But you mention that, if somebody asks; don't 
2 
you? 
3 
MR. EDWARDS: Form. 
4 
BY MR. DUTTON: 
5 
Q. Or do you not mention that, either? 
6 
A. If somebody asked what? 
7 
Q. If somebody says, well, what — what -- how 
8 
do you feel? Lace when you've seen physicians, been in 
9 
the hospitals, and they say, you know, what's your --
10 
how do you feel, you know, are you — are you depressed. 
11 
are you happy? And what do you tell them? 
12 
A. I don't !mow. 
13 
Q. You don't know what you told them? 
14 
A. No. 
15 
Q. But whatever you would have said in response 
16 
to if a nurse or a physician asked you, or a hospital 
17 
asked you, what how you — how do you feel from a --
18 
from a psychological or an emotional standpoint, you'd 
19 
tell them the truth; wouldn't you? 
20 
A. 1 don't know. 
21 
Q. Okay. So you might lie to your doctor or to 
22 
the hospital? 
23 
A. Ifs not easy for me to talk about that. 
24 
Q. About what? Either — either event? Either 
25 
what your father did and you witnessed, or Mr. Epstein, 
Page 376 
1 
A. I don't !mow. 
2 
Q. How about in the year 2006? 
3 
A. I don't know. 
4 
Q. In fact, did you go at all in 2006? 
5 
A. I'm not sure. 
6 
Q. When is the last time you believe you went to 
7 
Mr. Epstein's home? 
8 
A. I was 17 years old. 
9 
Q. Did you ever put any of the money that you 
10 
received from Mr. Epstein in a bank account? 
11 
A. No. 
12 
Q. At any time during the time you went to 
13 
Mr. Epstein's house did the -- what you've described as 
14 
occurred on the first occasion, did that ever change? 
15 
A. I don't know. I guess after I went more and 
16 
more times, he got like more comfortable, and I guess 
17 
lila more like aggressive kind of. 
18 
Q. How many times had you gone before there was 
19 
a change? 
20 
A. I don't know. Probably like six or so. 
21• 
Q. What year are we in now? 
22 
A. I don't know. Probably -- probably 2004. 
23 
Q. You'rejust guessing? 
24 
A. Yes. 
25 
Q. When you say something changed, did he 
••••••14....w4•L•evwSV•a
.
, ..`, 35•
Wtwaa 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, 
30 (Pages 373 to 376) 
INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (501.333-772-1552) 
Electronically signed by Pamela Sullivan (501-333-772-1552) 
92ef5b62-38a5-4202-3350-6633a5c6813b 
EFTA00750803

Page 377 
1 
ever — did he ever touch you? 
2 
A. Yes. 
3 
Q. Okay. On how many occasions? 
4 
A. He always did, but he just got more 
5 
aggressive about it. And, eventually, he wanted to use 
6 
like sex toys on me. 
7 
Q. Did he — did he ever physically touch you on 
8 
any occasion? 
9 
MR. EDWARDS: Object to the form. Asked and 
10 
answered. 
11 
THE WITNESS: What do you mean? 
12 
BY MR. CRITTON: 
13 
Q. Did he ever touch you? You — you were 
14 
touching him, because you were giving him a massage; 
15 
right? 
16 
A. Yes. 
17 
Q. And that's something that you were doing 
18 
voluntarily? 
19 
MR. EDWARDS: Form. 
20 
THE WRNESS: That was something that he told 
21 
me to do, yes. 
22 
BY MR. CARTON: 
23 
Q. But you had to get to the house. There's no 
24 
way you could give him a massage, unless you made the 
25 
decision to go to his house; correct? 
1 
2 
3 
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Page 379 
touch you on any of the visits? 
A. He always —
Q. Is that what you said, about the sixth time? 
A. He always touched me. 
Q. Where? 
A. He touched my breasts. He touched my vagina. 
He always touched me. 
Q. Did you ever tell him — well, let me strike 
that. 
He couldn't touch you, unless you allowed him 
to touch you; correct? 
MR. EDWARDS: Form. 
BY MR. CRITTON: 
Q. You had to vohmtarily allow him to touch 
you? 
MR. EDWARDS: Form. 
THE WITNESS: I don't know what you mean. 
BY MR. CRITTON: 
Q. Well, the very first time you were there, I 
think you said he didn't touch you; correct? 
A. No, I did not say that. 
Q. Okay. Did he touch you the very first time 
you were there? 
A. Yes. 
Q. Okay. Where? 
Page 378 
1 
MR. EDWARDS: Form. 
2 
THE WITNESS: Yes. 
3 
BY MR. CRITTON: 
4 
Q. Okay. Because he couldn't force you to do 
5 
anything, unless you were at the home. And even if you 
6 
were at the home, all you had to do was to say, no; 
7 
correct? 
8 
MR. EDWARDS: Form. 
9 
THE WITNESS: I didn't feel that way, no. 
10 
BY MR. CRITTON: 
11 
Q. Well, if you did -- if you didn't feel that 
12 
way, that is that you didn't have a choice, your choice 
13 
was then nn not going to Jeffrey Epstein's home ever 
I4 
again; true? 
15 
A. No. 
16 
Q. Okay. Did you take money every time you went 
17 
to Mr. Epstein's home? 
18 
A. Yes. 
19 
Q. Did you ever say, Mr. Epstein, I don't want 
20 
your money, I don't want to come back again? 
21 
A. No. 
22 
Q. You could have, though; couldn't you? 
23 
A. I didn't know that I could have. 
24 
g 
You said he touched you. How did he touch 
25 
you — well, let me ask you this: When did he first 
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Page 380 
A. My vagina. 
Q. And when he touched you there, did he — did 
he — was there any type of penetration, or did he just 
touch you? 
MR. EDWARDS: Form. 
ME WITNESS: I don't remember. 
BY MR. CRITTON: 
Q. Okay. When he touched your vagina -- with 
his hand? 
A. Yes. 
Q. What did you say to him? 
A. I didn't Say anything. 
Q. Okay. Had anyone ever touched your vagina 
before? Had a male ever touched your vagina before? 
A. No. 
Q. And when he touched your vagina, did you 
say — and your -- when you say your vagina, on the 
exterior of your body; right? 
A. Yes. 
Q. Did you say, please don't do drat? 
A. I didn't say anything. 
Q. You could have. You just didn't; true? 
MR. EDWARDS: Form 
THE WITNESS: I didn't know what to say. 
(561) 832-7500 
31 (Pages 377 to 380) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Pamela Sullivan (601,333-772-1552) 
Electronically signed by Pamela Sullivan (601 -333-772-1552) 
92et5b62-38354202.3350-6633a5c6813b 
EFTA00750804

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Page 381 
I 
BY MR. CANTON: 
2 
• Q. Well, if you -- if you had said, don't touch 
3 
me — did you ever tell him, don't touch me, or don't do 
that? 
5 
A. I didn't think of that, no. 
e 
Q. Okay. So the 20-some-odd times you were 
7 
there, you never said or never thought about telling him 
8 
not to do something; correct? 
9 
A. That's coned. 
10 
Q. Okay. So at least from his perspective --
11 
well, let me strike that. 
12 
Did you ever tell him that you didn't like 
13 
him touching you? 
14 
A. I don't remember. 
15 
Q. You don't remember telling him that; do you? 
16 
A. I don't remember. 
17 
Q. Okay. Well, you would remember if you said, 
18 
don't touch me there, or if you had pushed his band 
19 
away; wouldn't you? 
20 
MR. EDWARDS: Form. 
21 
THE WITNESS: I do remember that I was like 
22 
miserable, and I know that I looked miserable. And 
23 
so he would pretty much tell me that, ifs okay. 
24 
BY MR. CRITTON: 
25 
Q. You'd say you looked miserable, what do you 
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Page 383 
BY MR. CRITTON: 
Q. You may not have thought you bad a choice, 
but it was your choice; true? 
MR. EDWARDS: Form. 
THE WITNESS: I don't know. 
BY MR. CRITTON: 
Q. You knew — 
MR. CRITTON: Well, why don't we take a 
break. We only have a couple of minutes left 
(A brief recess was taken.) 
BY MR. CRITTON: 
ane Doe, do you know a pan named 
A. Do you know him by any other name? 
Q. I don't kno 
I'm just asking 
whether you know 
A. I'm not sure. 
Q. Did you know HIM 
A. 
Q. 
A. I have met him once. 
Q. Okay. And how do you know 
do — how do 
you know him? 
A. A friend of a friend had his baby. 
Q. I'm sorry? A friend of a — 
Page 392 
1 
mean? 
2 
A. Like I obviously didn't look like I was 
3 
enjoying what was happening. 
Q. Okay. And were you enjoying what was 
5 
happening? 
6 
A. Absolutely not. 
7 
Q. Okay. Then why did you go bacht Why didn't 
8 
you say, don't do that, Mr. Epstein — or 
what 
did you call him, Jeffrey, or did you call him 
Mr. Epstein? 
A. I didn't call him anything. 
Q. You never called him by his first name or his 
last name? 
A. No. 
Q. Is it your testimony that you never told 
him — well, let me strike that. 
It is your testimony you never told him not 
to do anything correct? 
MR, EDWARDS: Form. 
THE WITNESS: Correct. 
BY MR. CRITT0N: 
Q. And everything that you did there was 
voluntarily — voluntary; it was your choice? 
MR. EDWARDS: Form. 
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A. 
Q. 
A friend of a friend had his baby. 
Okay. Ant 
friend of a friend? 
A. r
ewhat? 
(phonetit 
Do you know 
Na 
Do you know IMIN 
Q. 
A. 
Q. 
A. 
Q. 
A. I — 
Page 384 
(phonetic)? 
A. I have meta guy named 
but I don't 
know his last 
Q 'nrougs
mill? 
A. Yes. 
U .
Okay. Do you know whether 
— that's 
's boyfriend, or someone she lived with at one time? 
A. I believe that he was her boyfriend. 
Q Okay. Do you know someone namecIIIMM. 
A. Yes. 
Q. Okay. How do 
him? 
A. I met him throuYghlir 
Q. Okay. Is that it's one of her boyfriends? 
A. Yes. 
Q. • Okay. How ab 
(phonetic)? 
A. I had never met 
but) head about him. 
(561) 832-7500 
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Page 385 
Q. What did you hear? 
A. I heard that he was with M. in the past, 
and he abused her. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
Q. 
A. 
Okay. Physically abused her? 
I don't know. I — I don't know. 
Was he into drugs, M? 
I don't know. 
Okay. How about M? 
Yes. 
was into drugs? 
Yes. 
What kind of drugs? Was he a drug dealer? 
I don't know. 
Q. You don't blow, you just know he was into 
drugs? 
A. Yes. 
Q. Okay. Did M. tell you that? 
A. You can pretty much tell. 
Q. From seeing him? 
A. Yes. 
Q. How? 
A. He -- he looked like he was on drugs every 
time I ever saw him. 
Did you ever know someone named 
M. dated? 
that 
Page 387 
1 
Q. What was his last name? 
2 
A. I don't know. 
3 
Q. Another-. person? 
4 
A. Yes. 
5 
Q. Okay. These are all people that she had 
6 
relationships with? 
7 
A. im:ss so. 
8 
Q. MI 
(phonetic), is that the 
9 
you were talking about? 
10 
A. Yes. 
11 
Q. Okay. Did M. ever tell you that she had 
12 
been raped or molested? 
13 
A. No. 
14 
Q. Did.. ever tell you that she had been 
15 
raped or molested? 
16 
A. No. 
17 
Q. Ma'am, have you ever had an abortion? 
18 
A No. 
19 
Q. Have you ever been pregnant, other than the 
20 
one time with this — your current child? 
21. 
A. No. 
22 
. 
Q. Ms. Jane Doe, didn't M. tell you before 
23 
you — she first took you to Mr. Epstein's house that —
24 
didn't she say specifically, I told her that we were 
25 
going to go to just an old guy's house, he is really 
Page 386 
1 
A. 
what? 
2 
Q. I'm not sure. 
3 
A. Yes. 
4 
Q. Did you know an ai 
5 
A. Yes. 
6 
Q. What was his last name? 
7 
A. I — I'm not sure, but I — !know that my 
8 
uncle was friends with his uncle, whose last name was 
9
10 
Q. IL
?
11 
A. 
12 
Q. 
13 
A. Yes. 
14 
4.O1. 
And soft could have been 
15 
16 
A. Yes, possibly. 
17 
Q. All right. Was that — was that Uncle si 
18 
A. Yes. 
19 
Q. How about — and — and vvas 
a drug 
20 
guy, too?. 
21 
A. 
I don't know. 
22.. 
Q. How about a person named ='? 
23 
A. 
24 
Q.
25 
A. Yes, I met him. 
Page 388 
1 
rich, and he has a beautiful mansion, and we're going to 
2 
go upstairs and give him a massage. I told her, her 
3 
meaning lane Doe, that I would be there with her for 
4 
half the time, and I would leave the room. And when I 
5 
left the room, he is going to tum over and do himself, 
6 
by meaning ejaculating. 
7 
She told you that before you went to 
8 
Mr. Epstein's house the first time; didn't she? 
9 
A. No. 
10 
Q. Okay. Didn't she also tell you on the first 
11 
occasion that you would have to be topless? 
12 
MR. EDWARDS: Fans. 
13 
THE WITNESS: No. 
14 
BY MR. CRITIDN: 
15 
Q. Didn't she tell you that Jeffrey was a nice 
16 
guy and wouldn't make you do anything that
 didn't 
17 
want to do, or words to that effect? Didn't M. tell 
18 
you that before the first time? 
19 
A. That is not exactly what she said to me. 
20 
.Q. That's what you understood, though? 
21 
A. No. 
22 
Q. Okay. Well, did she tell you that, that 
23 
Jeffrey was — that the older man was a nice guy that 
24 
wouldn't make you do anything that you don't want to do? 
25 
A. No. 
(561. ) '832.-7500 
33 (Pages 385 to 388) 
PROSE COURT REPORTING AGENCY, INC. ' 
(561) 832-7506 . 
Electronically signed by Pamela Sullivan (601-333-772.1552) 
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Page 389 
1 
Q. Okay. Didn't she tell you that you were 
2 
going to see him ejaculate? 
3 
A No. 
4 
M.
If.. 
had said those things, your position 
5 
is M. is lying right? 
6 
MR. EDWARDS: Form. 
7 
TIM WITNESS: She certainly could have been 
8 
mistaken. 
9 
BY MR. CRITTON: 
10 
Q. Well, assuming she testified under oath, 
11 
there's a difference between mistaken and being lie —
12 
and lying isn't there, in your mind? 
13 
MR. EDWARDS: Form. 
14 
THE WITNESS: If she thought that she told me 
15 
that, then she was mistaken, bonus,. she did not 
16 
tell me that. 
17 
BY MR. CRITTON: 
18 
Q. Has anybody ever told you that you may have a 
19 
cause of action against 
for having brought you to 
20 
Mr. Epstein's house the first time? 
21 
MR, EDWARDS: Form 
22 
THE WITNESS: No. 
23 
BY MR. CANTON: 
24 
Q. Have you ever signed a — you're aware that 
25 
Mister — we established earlier that Mr. Edwards 
Page 391 
1 
and — you and your attorney answered them — or you 
2 
answered them on January 23rd of 2009 — at least that's 
3 
when they were sent to me. 
4 
Do you remember receiving these written 
5 
questions? 
6 
A. I remember discussing these questions over 
7 
the phone with Brad. 
8 
Q. Okay. And you don't have to tell me what was 
9 
discus'' but you and your attorney consulted one 
10 
another? 
11 
A. Yes. 
12 
Q. Okay. And you see, if you go to the very 
13 
last page, there's a verification. It says: "The 
14 
foregoing answers to interrogatories are true and 
15 
correct, to the best of my knowledge, information and 
16 
belief." And it has Jane Doe, Plaintiff. Is that your 
17 
Jane Doe? 
18 
A. Yes. 
19 
Q. All right. And all of the answers to these 
20 
interrogatories you represented to be true and accurate; 
21 
correct? 
22 
A. I did look over some of them with Brad, and 
23 
some of them were not right 
24 
Q. Okay. Well, that's not my question. When 
25 
you sent these out to me, or when Mr. Edwards — take it 
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Page 390 
represents M. Have you ever signed a waiver of 
conflict letter about that you would agree not to sue 
Int? 
A. Not that I know of. 
Q. Are you aware that you have a claim -- that 
you may well have a claim against M. for having taken 
you to Mr. Epstein's the first time? 
MR. EDWARDS: Form. 
THE WITNESS: No. 
BY MR. CRITTON: 
Q. Did you ever reach an agreement with 
that you wouldn't sue her? 
A. No. 
Q. Do you have a side agreement with 
oh, I 
won't sue you, me, 
A. No. 
MR. CRITTON: This is Number 6. 
Let me show you Exhibit 6, which are your 
answers to interrogatories. 
liere you go, Brad, there's a copy for you. 
(Defendant's Exhibit No. 6 was marked for 
identification.) 
BY MR. CRITTON: 
Q. These are interrogatories that were sent to 
you, ma'am, back in 
I believe in December. And you 
Page 392 
1 
back 
2 
When you signed these answers to the 
3 
interrogatories on January 23rd, 2009, and verified 
4 
they're true and correct, you represented to me and to 
5 
the Cowl that those answers wens true and correct. You 
6 
understood that, yes; correct? 
7 
MR. EDWARDS: Form. 
8 
THE WITNESS: Yes. 
9 
BY MR. CRITTON: 
10 
Q. All right. And as of todays date, which is 
11 
September 30,2009, you have made no corrections to 
12 
these interrogatories; have you? 
13 
MR. EDWARDS: Form. 
14 
THE WITNESS: I have told Brad that there 
15 
were some. 
16 
BY MR. CRITTON: 
17 
Q. Okay. You need to listen to my question, 
18 
ma'am. 
19 
. 
As of todays date, you have filed — at 
. 
20 
least, you're unaware of any filing that's been made on 
21 
your behalf to correct any of these answers to 
22 
interrogatories; true? 
23 
MR. EDWARDS: Fonn. And I'd like you to let 
24 
the witness answer the question, as she was. As 
25 
you know, no Plaintiffs file anything; the 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, 
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INC:' 
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Electronically signed by Pamela Sullivan (501-333-7724 552) 
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92efSb62-SilaS-4202-a3S0-6633a5c6813b 
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Page 393 
1 
attorneys do it for them. And she was going to 
2 
answer your question. 
3 
MR. CRITTON: Well, if she tells me -- you're 
4 
going to let her — she's trying to say what Brad 
5 
told me, or something. So if you're going --
6 
willing to waive the attorney/client privilege, 
7 
I'll let her go ahead. I was just trying to help 
8 
you out here. Good Samaritan. 
9 
MR EDWARDS: Yeah. 
10 
She has made me aware of better answers, and 
11 
I will file. 
12 
BY MR.. CRITTON: 
13 
Q. At least as of today, you have done nothing? 
14 
You have — you have not signed any papers that would 
15 
change the exhibit — the answers in Exhibit 6; true? 
16 
MR. EDWARDS: Form. 
17 
THE WITNESS: Right. 
18 
BY MR. CRITTON: 
19 
Q. Have you ever worked as an escort? 
20 
A. No. 
21 
Q. Man of 
— our i 
that you did at 
22 
either 
or 
, did -- did any male 
23 
or female ever ask you to go out with them on a date? 
24 
A. Yes. 
25 
Q. Okay. Did you ever go with any of those 
Page 395 
1 
Q Well, how about average days per month, did 
2 
you work at least ten days a month? 
3 
A. Yes. 
4 
Q. Okay. And if you worked ten days a month, 
S 
and you were getting SI0 — I'm sorry — ten days a 
6 
month times 200 bucks, you would get about $2,000 a 
7 
month? So you had to have been earning at a minimum of 
8 
about 2,000— $2,000 a month times 16 months, you would 
9 
have made about S32,000 minimum, working for 
10 
and 
right? That's just math. 
11 
MR. EDWARDS: Form. 
12 
THE WITNESS: Possibly. 
13 
BY MR. CRITTON: 
14 
Q. You may have made more? 
15 
A. I probably actually made less. 
16 
Q. Okay. Well, you could have made more; could 
17 
have made a little less — 
18 
MR. EDWARDS: Form. 
19 
BY MR. CRITTON: 
20 
Q. —right? 
21. 
A. No. 
22 
Q. No what? 
23 
A. 1 didn't make more than that. 
24 
Q. Okay. How do you know that, if you never --
25 
if you didn't keep track of your records? And I'm Just 
Page 394 
individuals? 
2 
A. No. 
3 
Q. During the time that you worked — and I was 
4 
hying to — worked at — that you worked at Platinum, 
5 
and then MEM, 
you worked, I think we worked out 
6 
about, let's see — six — four —14 to 16 months that 
7 
you would have worked at -
8 
something. Does that sound about right? 
9 
A. Yes. 
10 
Q. Okay. And you said that your — your general 
11 
take was approximately $200 a night? 
12 
A. Yes. 
13 
Q. Okay. And if you, over that 14- to 16-month 
14 
time period, would you say that you waited an average of 
3.5 
about five days a week? 
16 
A. No. 
17 
Q How many days a week? 
18 
A. Um. 
19 
Q. I know you said sometimes you work seven; 
20 
sometimes you might not work for — 
21 
A. Sometimes 1 didn't work fora month or two. 
22 
Q. Approximately, out of those 14 to 16 months, 
23. 
approximately how many 
what would have been your 
24 
average number of days that you would have worked? 
25 
A. I have no idea. 
and MIM 
Page 396 
1 
trying to use your numbers. So it was about $200 a thy, 
2 
times ten days a month, times 16 months, would be about 
3 
32,000 bucks; right? 
4 
A. If I made $200 every time. 
5 
Q. Well, if — if you did — how many lap dances 
6 
would you generally do a night? 
7 
A. I don't know. 
8 
Q. Did you always get at least one lap dance a 
9 
night? 
10 
A. No. 
11 
Q. And some nights nobody was interested in 
12 
doing a lap dance with you? 
13 
A. That's right. 
14 
Q. Did you have some nights that maybe a few 
15 
people were interested in a lap dance? 
16 
A. Yes. 
17 
Q. Okay. When you were at — working et 
18 
and at a 
were you still taking 
19 
drugs? You were still working with illegal drugs; 
20 
weren't you? 
21 
MR. EDWARDS: Form. 
22 
THE WITNESS: At times. 
23 
BY MR. CRITTON: 
24 
Q. Okay. Did you ever take illegal drugs before 
25 
you went to Mr. Epstein's house? 
35 (Pages 393 to 396) 
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PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Pamela Sullivan (501.333-772.1562) 
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2 
3 
4 
A. 
5 
Q. 
6 
A. 
7 
Q. 
Her too. Let me start again. 
8 
With Melissa 
did you ever take her 
9 
to Mr. Epstein's house? 
10 
A. No. 
11 
Q. Okay. Why not? 
12 
A. I didn't want to. 
13 
Q. Did you ever tell her about what you were 
14 
doing at Epstein's house? 
15 
A. No. 
16 
Q. Okay. Did you ever tell anyone? 
17 
A. No. 
18 
— did sister 
or 
or 
ever say to you, what do you mean you're 
19 
20 
cleaning this guy's house over in Palm Beach, what's 
21 
going on here, you're coming home with a couple of 
22 
hundred bucks each time? 
23 
A. No. 
24 
Q. Okay. Did you ever spend more than an hour 
25 
at Mr. Epstein's home? 
Page 397 
A. No. 
Q. Separate and aS-- 
you -- you 
mentioned your friend 
- give me her last name. 
(phonetic). 
1 
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Page 399 
A. Yes. 
Q. Was it a psychiatrist or a psychologist or a 
licensed mental health counselor? 
A. I don't know. 
Have 
you ever seen any of the records from 
A. No. 
Q. You're yawning. Were you up late last night? 
A. No. 
Q. Okay. You're certain you're not on any kind 
of medication today? 
A. Yes. 
Q. Any kind of prescription or nonprescription 
medication? 
A. Yes. 
Q. Okay. What you were at. 
!think you 
said — how often would you talk to a psychologist or 
a -- some sort of a mental health counselor type person? 
A. I don't know. 
Q. Once a day? Once a week? Once a month? 
A. About once a week. 
Q. Did you talk to them about 
did Epstein 
ever come up? 
A. No. 
Q. Okay. Did your — the murder trial that you 
Page 398 
1 
A. No. 
2 
Q. Okay. So you would get 200 bucks, or then 
3 
300 I think you said later on, for being at 
4 
Mr. Epstein's. Did you show them how much money you 
5 
got? 
6 
k 
No. 
7 
Q. Did you ever pay 
or your uncle for 
8 
taking you? 
9 
A. Yes. 
10 
Q. How much did you pay them? 
11 
A. I don't know, 25, maybe 450. 
12 
I think you said that you — you ended up at 
13 
School as a result of a -- of the prosecution 
14 
relating to grand theft auto; correct? 
15 
A. Yes. 
16 
Q. And during the time you wae at 
did 
17 
you see a psychologist? 
18 
A. Yes. 
19 
Q. Was that part of your therapy or part of the 
20 
sentence? 
21 
A. Yes. 
22 
Q. Okay. Did you talk with a therapist about 
23 
do you remember the name of the therapist? 
24 
A. No. 
25 
Q. Was it more than one therapist? 
1 
2 
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Page 400 
testified in come up? 
A. Yes. 
Q. Did your trouble with the law, that is the 
grand theft auto and other problems that you had, did 
you discuss that with the therapist? 
MR. EDWARDS: Form. 
THE WITNESS: I discussed common knowledge 
with them, yes. 
BY MR. CRITTON: 
Q. Common knowledge? 
A. Things that everybody pretty much knew. 
Q. What do you mean by that? I don't know what 
you mean by common knowledge. 
A. Stuff that you can just find out. 
Q. Got to help me here. Ideal know what you 
mean. 
A. Well, obviously, I was charged with a crime 
to be sent there, so they knew about that. 
Q. Which was the grand theft auto? 
MR. EDWARDS: Form. 
THE WITNESS: Yes. 
BY MR. CRITTON: 
Q. Okay. What other crimes had you committed by 
that point in time? We have an offense where you 
shoplifted in Palm Beach County; right? 
36 (Pages 397 to 400) 
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Electronically signed by Pamela Sullivan (501-333-772-1552) 
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Page 401 
MR. EDWARDS: Form. 
THE WIINESS: Yes. 
BY MR. CR1TTON: 
Q. Okay. Any other crimes that you can remember 
off the top of your head as sitting here? 
A. Running away. 
Q. And did you discuss those all with the 
therapist? 
A. Yes. 
Q. Okay. And how would the therapist have known 
about your testimony and your involvement with regard to 
seeing your father murder 
A. Because my mother asked that I work on that. 
Q. And you say that nothing ever came up with 
regard to Mr. Epstein or any of the — what had occurred 
at Epstein's with the therapist? 
A. No. 
Q. Why not? Why didn't you bring it up if it 
was such an important event for you? 
A. Because I did not want my family to know. 
Q. But 
and then the only people in your 
family as far as you know, today that know, is your 
A. Yes. 
Q. Did you ever tell your sisters 
and 
Page 403 
1 
Q. Have you been evaluated by any psychiatrist 
or psychologist at the request of your attorney? 
A. No. 
air
you ever seen a person by the name of 
A. Yes. 
Q. Okay. Well, who do you think she is? 
8 
A. A psychologist or a psychiatrist or 
9 
something, 
10 
Q• okay. And how did you get — when did 
11 
Ms. Sdo 
an evaluation on you? 
12 
A. She did not. 
13 
Q. Okay. When did you see her? 
14 
A. I don't 'mow. 
15 
Q. This year? 
16 
A. Yes. Not long ago, like —
17 
Q. In the past — 
sony; go ahead. 
18 
A. — a month, maybe two. 
19 
Q. Okay. And hwaija it get set up that you 
20 
would meet with Ms. 
21 
MR. EDWARDS: Objection. Do not answer. 
22 
Attorney/client privilege. 
23 
BY MR. CRITION: 
24 
Q. Did you meet with her? 
25 
A. Yes. 
2 
3 
4 
5 
6 
7 
Page 402 
1 
that you were making money from giving -- for 
2 
giving massages to Mr. Epstein? 
3 
A. No. 
4 
Q. Did you ever tell either 
5 
that you liked going to Mr. Epstein's house? 
6 
A. No. 
7 
Q. Did you -- did 
-
o
r
 
ever meet 
8 
Mr. Epstein? 
9 
A. No. 
10 
Q. Did Ms. Brewer ever meet Mr. Epstein? 
11 
A. No. 
12 
Q. Have ou seen — other than 
— well, 
who I — at least , looking 
13 
you've seen 
14 
at her resume, she's a licensed mental health counselor 
15 
through Victim Services. Is that -- am I right? 
16 
MR. EDWARDS: Form. 
17 
THE WITNESS: Yes. 
18 
BY MR. CRITTON: 
19 
Q. Other than IMIM, 
have you seen any 
20 
other psychologist, psychiatrist or licensed mental 
21 
health counselor relating to any damages you claim in 
22 
this case that were caused by Mr. Epstein? 
23 
A. No. 
24 
Q. Why not? 
25 
A. Because I'm embarrassed. 
or 
Page 404 
1 
Q. Okay. Where did you meet with ha? 
2 
A. Somewhere downtown. I — I don't exactly 
3 
remember where it was. 
4 
Q. Downtown in West Palm Beach? 
5 
A. Yes. 
6 
Q. AM how long — bow much time did you spend 
7 
with her? 
A. Not very much. 
9 
Q. And why not? 
10 
MR. EDWARDS: Objection. It was a 
11 
consultation, and we're claiming a privilege. 
12 
She's not going to divulge the circumstsa or the 
13 
conversation between herself and Ms. INE 
—
14 
Dr. Mig 
15 
MR. CRITTON: 
— are you 
16 
intending to use Ms. MI as an expert in this 
17 
case? 
18 
MR. EDWARDS: No. 
19 
BY MR. CRITTON: 
20 
Q. Okay. I asked you earlier whether your 
21 
attorney — whether your attorney had set up any 
22 
meetings for you to meet with a psychologist or a 
23 
psychiatrist or a licensed mental health counselor, and 
24 
you said, ritwapd it wasn't until I said, did you ever 
25 
meet Amy EN or someone like her, and you go, yeah, I 
(561) 832-7500 
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Page 405 
1 
did. Why didn't you tell —
2 
A. You asked me if --
3 
Q. 
— me what — 
4 
A. -- I had an evaluation, which I did not. 
5 
Q. Oh, okay. So you -- you met Ms. III but 
6 
she never did an evaluation? 
7 
A. Yes. 
8 
Q. Okay. Was it your choice — did you not want 
9 
her to evaluate you? 
10 
MR. EDWARDS: Objection. The witness is not 
11 
answering the question as to Dr. alor that 
12 
meeting. We're claiming a priir 
as to that 
13 
communication between Dr. 
nd the Plaintiff. 
14 
And, as well, this pertains to attorney/client 
15 
information. Any answers that she gives will 
16 
violate one or two of those privileges. She's not 
17 
going to answer any more questions on this topic. 
18 
BY MR. CRITTON: 
19 
Q. With regard to have you seen, other than 
20 
whatever
 — whatever time ou s 
t with Ms. el 
21 
Dr. 
and your visits with 
have you 
22 
seen any other psychiatrists, psychologists, licensed 
23 
mental health counselor, physician, medical health 
24 
provider, relating to any damages that you are claiming 
25 
in this case? 
1 
.2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
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24 
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Page 407 
Ms. lare 
helpful? 
A. Sometimes. 
Q. Okay. And how often do you see her? 
A. I was seeing her once a week. I haven't seen 
her in a while now, though. 
Q. Why not? When is the last time — well, let 
me strike that. 
When did you last see her? 
A. About a month or so ago. 
Q. And why haven't you seen her again? 
A. I don't know. 
Q. Do you intend to go back to see her, or Just 
going to kind of wait and see? 
A. Yes, I do. 
.
• 
I'm sorry? 
A. Yes, I do. 
Q. Has — has she called you or you called her 
in the month or so that you have not seen her? 
A. Yes. 
Q. Did she call you, or did you call her? 
A. She called me. 
Q. Did she say, why haven't you come in? 
A. She was reminding me of an appointment that 
we had. 
Q. All right. And you said what? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
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20 
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Page 406 
A. No. 
Q. Have you sustained — have you incurred any 
medical bills, psychiatric bills, psychological bills, 
any type of bills associated with damages that you are 
claiming in this case against Mr. Epstein as of today's 
date? 
A. No. 
Q. Has anybody told you that you will incur any 
medical bills or expenses in the future as a result of 
any claims that you have made against Mr. Epstein? 
MR. EDWARDS: Objection. Attorney/client 
PriYilege. 
BY MR. CRITTON: 
Q. Other than Mr. Edwards. 
not interested 
in what he told you. I'm interested, but I'm not 
entitled to know. 
A. I don't know. Like who? 
Q. I don't knew. Has —has anybody told you. 
has — has 
said — has Doctor or 
Miss — Ms 
told you is that — well, Si 
strike that. Let me ask it.this way: Has Ms. 
told.you that she thinks you're doing better, that 
you're improving? 
. 
A. I don't Icnow. 
Q. Do you feel like the sessions with 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
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22 
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Page 408 
A. That I would come. 
Q. But you haven't been back yet; correct? 
A. The appointment has not come up yet. 
Q. When is the next appointment? 
A. I — ideal know the exact date. It's 
October something. 
Q. Other than 
Mr. A, B and C who you 
identified, have you had a sexual relationship or any 
sexual activity with any other person, male or female?. 
A. Yes. 
Q. Who else have you had sexual activity with? 
MR. EDWARDS: She's not going to identify 
People-
BY MR. CRITION: 
Q. First let's — it's when -- when else did you 
have any type of sexual activity, either wait° 
or 
a female, other than Mr. A, B and C and 
A. [guess in between the time that I had a 
relationship one — with one person, to the time that I 
had a relationship with another person. 
Q. Okay. Well, your lawyers kept me to Mr. A, B 
and C, so who do we fit in here? Where do we fit this 
other person into? 
B and C, C and 
• post 
pre 
You need to help'me 
with the date; then I can ask an intelligent question. 
(561) 832-7500 
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PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Pamela Sullivan (601.333.772.1562) 
Electronically signed by Pamela Sullivan (501-333-772-1552) 
92ef5b62.38a5-4202-a350-6633a5c6813b 
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P 
A. Yes, before =. 
1 
Page 411 
BY MR. CRITTON: 
2 
Q. So it would have been after the stalker, 
2 
Q. Did you ever spend the night with him? 
3 
Mr. C? 
3 
A. No. 
A. Yes. 
4 
Q. Did he spend the night with you? 
5 
Q. And before 
5 
A. No. 
6 
A. Yes. 
6 
Q. Did you just meet and have sex? 
7 
Q. Okay. You didn't mention him earlier. You 
7 
A. We met and spoke to each other fora period 
8 
told me earlier today that you had had no sexual 
8 
of time before we had sex. 
9 
activity or the next sexual activity that you had 
9 
Q. Where did you meet him? 
10 
after Mr. C was 
. That wasn't true; was it? 
10 
A. I met him in my neighborhood. 
11 
A. That was the next relationship that I had. 
11 
Q. And let me just ask you: What's his name? 
12 
Q. I wasn't asking about — 
talking about 
12 
MR. EDWARDS: She's not going to give it. 
13 
sexual activity. I don't care about -- k's not that I 
13 
MR. CRITTON: You're instructing -- your 
14 
don't care. 
14 
objection is? 
15 
When's the next sexual activity? Was it 
15 
MR. EDWARDS: My objection is based on the 
16 
after Mr. C? 
16 
privacy rights of this individual answering the 
17 
A. Yes. 
17 
questions, as well as third-party individuals. 
18 
Q. Okay. And who was that with? we call him 
18 
BY MR. CRITTON: 
19 
Mr. D? Was Raman cowman? 
19 
Q. Over what period of time, then, did you have 
20 
A. It was a man. 
20 
sexual relations with him? Four or five months? 
21 
Q. And Mr. D was short-term, long-term, 
21 
A. It was during the entire time that I worked 
22 
one-night stand, multiple? 
22 
at 
23 
A. I — I never had a relationship with him, but . 
23 
Q. Which was about eight months? 
24 
I was seeing him for some time. 
24 
A. Yes. 
25 
Q. How long a time period? 
25 
Q. All right. So over a period of about once a 
Page 410 
Page 412 
A. Probably the whole time I waked a 
1 
week you would meet and you would have sexual relations. 
2 
a 
2 
Are we talking about intercourse? 
3 
What did he do fora living? 
3 
A. Not every time. 
4 
A. I don't know. 
4 
Q. Okay. Well, that's why I asked. So, but 
5 
Q. Did you meet him at a? 
5 
many of the times you would have sexual activity. 
6 
A. No. 
Intercourse? 
7 
Q. Did you meet him through a/ 
7 
A. Some of the times, yes. 
8 
A. No. 
8 
Q. Did you also have oral? 
9 
Q. What did he do the guy — you said you 
9. 
A. No. 
10 
don't know what he did for a living? 
10 
Q. Strictly sexual intercourse? 
11 
A. No. 
11 
A. Yes. 
12 
Q. So 
saw him the whole time you were 
12.
Q. Okay. Anyone else that you've had sexual - 
13 
working at 
which was eight months, and 13 
any sexual activity with, other than Mr. A, B, C, D and 
14 
you never know what kind of work he did? 
14 
15 
A. No. 
15 
A. No. 
16 
Q. You never knew what kind of work he did? 
16 
Q. Nobody else? 
17 
A. No. 
17 
MR. EDWARDS: Object to the form. 
18 
Q. Are you — are you serious? 
18 
BY MIL CRITTON: 
19 
A. I only saw him maybe once a week. 
19 
Q. Male a female, is that correct? 
20 
Q. Okay. So you saw him once a week for eight 
20 
A. Yes. 
21 
months. All right. And you're telling the members of 
21 
Q. Have you ever had sex with a female? 
22 
the — the ladies and gentlemen of the jury that you 
22 
A. No. 
23' 
have no idea what this man did for a living? 
23 
Q. Did Mr. D ever provide you money at any time? 
24 
MR. EDWARDS: Object to the form. 
24 
A. No. 
25 
THE WITNESS: Yes. 
25 
Q. Did he ever provide you any kind of like kind 
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Page 413 
1 
compensation? And by that, he's made -- you know, 
2 
probably bought you — probably ate out and had dinner 
3 
or something. But separate from that, did he buy you 
4 
clothes, did he buy you perfume, did he buy you anything 
5 
or give you anything? 
6 
MR EDWARDS: Form. 
7 
ITIE WITNESS: No. 
8 
BY MR. CRITTON: 
9 
Q. Are you currently involved in any type of 
10 
civil or criminal proceedings, other than this 
11 
proceeding with Mr. Epstein? 
12 
A. What does that mean? 
13 
Q. I'm sorry? 
14 
A. What does that mean? 
15 
Q. Are you under any type of house arrest at the 
16 
current time? 
17 
A. No. 
18 
Q. Okay. Are there any criminal proceedings 
19 
that are outstanding directed to you, anything from a 
20 
traffic ticket up? Have you been arrested for any other 
21 
circumstance that's pending at the current time? 
22 
A. Yes. 
23 
Q. What? 
24 
A. Traffic ticket. 
25 
Q. All right For what? What did you do? 
1 
Q. 
2 
car? 
Page 415 
What else happened that they impounded the 
3 
A. My brother was driving the car, and —
4 
Q. In the commission of a crime? 
5 
A. I do not know. 
6 
Q. Okay. Why did they — why would they impound 
7 
the car, if your brother was just driving the car? Does 
8 
he have a license? 
9 
A. No. 
10 
Q. He doesn't have a license, either? 
11 
A. No. He was being questioned by a police 
12 
officer, and he ran. 
13 
Q. He fled in the mu'? 
14 
A. No, he ran on foot. And the car was 
15 
impounded because he left it wherever it was, at the 
16 
store or something. 
17 
Q. Okay. So it wasn't impounded because you 
18 
were driving without a license, and it wasn't impounded 
19 
because you were driving the wrong way on a one -- on a 
20 
street; right? 
21 
A. Yes. 
22 
Q. It was because of". 
23 
A. Yes. 
24 
Q. Okay. Any other criminal or misdemeanor or 
25 
traffic type events in your life at the current time? 
3
2 
3 
4 
5 
6 
7 
8 
9 
Lo 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 414 
A. Driving without a license. 
Q. And whose car were you driving? 
A. 
Q. This is the — did she authorize you to take 
the vehicle, or is this another time that you stole the 
car from her? 
A. No. She gave me the car because she bought a 
new car, and I was supposed to get my license. 
Q. And do you still have the car? 
A. No. 
Q. What happened to the car? 
A. It was impounded. 
Q. All right. Did you get into an accident? 
A. No. 
Q. How did you get caught? 
A. I was driving the wrong way. 
Q. On a street? 
A. Uh-huh. 
Q. Yes? 
A. Yes. 
Q. Okay. Is — is it — I've gotten reasonably 
good advice that they don't impound a car for driving 
without a license. So why did they impound the car in 
this instance? 
24 
A. Not right now. 
A. They did not impound it on that instance. 
25 
Q. And who's providing support for you and your 
Page 416 
1 
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4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
A. No. 
Q. Okay. Have you ever been under house arrest? 
A. No. 
Q. Any other civil proceedings that are pending 
at the =rent time? 
A. No. 
Q. Any proceedings with the Department of 
Children and Family Services? 
Na 
Q. You and 
planning to get married? Any 
plans, or just living together? 
A. We have talked about it. 
Q. Okay. I'm sorry? 
A. We have talked about it. 
Q. Well, you've been going together since when, 
'07? 
A. Yes. 
Q. Okay. And it's now '09. and you have a child 
together, so have you just been talking about it for 
those two years? 
A. About the past year we have. 
Q. Does he provide any support at the current 
time for the child? 
40 (Pages 413 to 416) 
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