EFTA00750774

Page 417 
1 
family at the current time? 
2 
A. 'MIMI 
helps us. 
3 
Q. How much does she help you with a month? 
4 
A. Before now she didn't need to help us, but 
5 
since= (phonetic) has lost his job in the last 
6 
three weeks, she's helped us. 
7 
MR. CRITTON: I'm going to adjourn for today 
8 
because of the time. It's about a quarter to 6:00. 
9 
And I can tell you this, that — 'have not gone 
10 
into all of the different events at Mr. Epstein's 
11 
home, because she was there some 20 times. So 
12 
those are areas that I intend to go into. I think 
13 
I can probably complete the deposition in another 
14 
hour and a half to three hours, max. 
15 
And there are some other areas that I — you 
16 
know, if 1 could — and we've been going pretty 
17 
steadily, at a pretty good clip. So if I could 
18 
take some time, I — and can think about my 
19 
thoughts, I'll try to make it even faster than that 
20 
at the next session. 
21 
MR EDWARDS: Well, Tm not going to agree to 
22 
it. We're going to have to have some discussion 
23 
with the Court as to whether or not this deposition 
24 
is going to be completed on another date. I 
25 
provided her here at 9:30. I had her here for the 
Page 419 
1 
I'm on the record. 
2 
COURT REPORTER: Okay. 
3 
MR. CRITTON: Did you not get any of that? 
4 
COURT REPORTER: I have it just... 
5 
VIDEOGRAPHER: You'll be able to get it 
6 
later. 
7 
MR. EDWARDS: I -- I remember what he said. 
8 
Don't worry about it. 
9 
UNIDENTIFIED SPEAKER; He said, on the 
10 
record. He said, on the record, so 1 flamed --
11 
COURT REPORTER: Ill check the video. 
12 
MR. CRITTON: All right. 
13 
UNIDENTIFIED SPEAKER: Clear — clearly, the 
14 
Court Reporter's tired. 
15 
COURT REPORTER: Well -- well, I said 
16 
something to you about l was starting okay. 
17 
This is — 
18 
UNIDENTIFIED SPEAKER: All right. 
19 
COURT REPORTER: We're back on, and III —
20 
UNIDENTIFIED SPEAKER: But you got it? 
21 
COURT REPORTER: And I got it. * CHECK ALL. 
22 
MR. CRITTON: All right. So we spent eight 
23 
hours with chap, who was there for eight months 
24 
and — with — with the various lawyers in that. 
25 
So this is a young lady who claims that she was at 
Page 418 
seven hours, and I think that ru be able to 
2 
demonstrate to the Court that many of the questions 
3 
were redundant, asked and answered over and over 
4 
and over again. And we're here, ready to complete 
5 
the deposition. If you want to (hush it, we'll 
6 
finish it. If you think that you will prevail at 
7 
that hearing and you're going to come back another 
8 
time, that's up to you. 
9 
MR. CRITTON: All right. Well, let's take a 
10 
break for a few minutes, and m decide what I 
11 
want to do. 
12 
MR. EDWARDS: Okay. 
13 
VIDEDDRAPHER: Off the record at 5:48. 
14 
(Discussion held off the record.) 
15 
MR. CRITTON: I'll put on the record, when 
16 
I've finished my 15 minutes of the additional areas 
17 
that I would like to cover with her. And we can go 
18 
to the Court on those particular issues. 
19 
MR. EDWARDS: Alined. 
20 
MR. CRITTON: And, you know we spent seven 
21 
hours — almost eight hours with 
— fm saying 
22 
in a 
23 
deposition in Federal Court. And Mr. 
24 
worked for Mr. Epstein for a period of six to eight 
25 
months. This is a --
Page 420 
1 
Mr. Epstein's house 20 times — well, I'll get to 
2 
that later, so let me get to where I'm going, and 
3 
4 
MR. EDWARDS: Sounds like a good idea. 
5 
MR. CRITTON: Thank you. 
6 
BY MR. CRT-ETON: 
7 
Q. Ms. Jane Doe, what did you do, if anything —
8 
and I don't want to know what conversations you had with 
9 
your lawyer -- to prepare for this deposition today, if 
10 
anything? 
11 
MR. EDWARDS: Object to the form. 
12 
Attorney/client. 
13 
MR. CRITTON: No, I don't want to know what 
14 
your discussions were. I want to know what -- what 
15 
did you — 
16 
MR. EDWARDS: Maybe I missed your question. 
17 
BY MR. CRITTON: 
18 
Q. What did you do to prepare for this 
19 
deposition, if anything, other than converse with your 
20 
attorney? 
21 
A. I went to bed early. I don't know. 
22 
Q. Did you make any notes? 
23 
A. I read through the questions that I answered. 
24 
Q. The interrogatories? 
25 
A. Yes. 
(561) 832-7500 
41 (Pages 417 to 420) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (501.333.772-1562) 
Electronically signed by Pamela Sullivan (601-333-772-1552) 
tbsOMM4ho54202.05NNIXMOIM3b 
EFTA00750814

Page 421 
1 
Q. Excuse me. Did you review any notes that you 
2 
bad made about any of your experiences at Mr. Epstein's 
3 
home? 
A. No, I've never made any notes. 
5 
Q. Have you ever written out — well, let me 
6 
gram that 
7 
Did you review a copy of your complaint? 
9 
A. No. 
9 
Q. Okay. Have you ever seen your complaint? 
10 
A. Yes. 
11 
Q. And do you know what you're asking for in the 
12 
way of damages in your complaint? 
13 
A. Not exactly. 
34 
Q. Okay. Your complaint says you want 
15 
S50 million. What's the basis for that claim? 
16 
MR. EDWARDS: Object to the form. 
17 
THE WITNESS: Pretty much just to hurt 
18 
Jeffrey Epstein. 
19 
BY MR. CRITTON: 
20 
Q. Okay. Not to compensate yourself, but just 
21 
to hurt Jeffrey Epstein; is that correct? 
22 
A. Pretty much. 
23 
Q. When you said you realized some of your 
24 
answers to the interrogatories were incorrect, when did 
25 
you discover that? 
Page 423 
1 
BY MR. CRITTON: 
2 
Q. And did you say it after you read them? 
3 
A. Yes. 
4 
Q. And who did you say whatever you said to 
5 
about some of the answers being incorrect, who did you 
6 
say that to? 
7 
MR. EDWARDS: Objection. Attorney/client 
8 
privilege — 
9 
MR. CRITTON: Okay. 
10 
MR. EDWARDS: — as to who within my firm 
11 
she's talking about, now that you're already 
12 
discussing the substance about — of the 
13 
conversation. 
14 
BY MR. CRITTON: 
15 
Q. Well, you said that you realized some of the 
16 
answers were wrong, so you called somebody. And I don't 
17 
want to know what happened or what erartly you said, but 
18 
you spoke to someone at Mr. Edwards' rum; is that 
19 
correct? 
20 
A. Yes. 
21 
Q. And that was a number of months ago; true? 
22 
A. I'm not I'm not sure when it was. 
23 
Q. If you — you testified —
24 
A. It was — it was at least a month ago. 
25 
Q. Let me show you what I'll mark as Exhibit 
Page 422 
1 
A. I'm not exactly sure. 
2 
Q. Wash yesterday? Was it today? Was it a 
3 
month ago? Was it six months ago? 
4 
A. 1 probably noticed whenever I first got the 
5 
copy of it 
6 
Q. Which was what, shortly after it was signed 
7 
on January 23rd of '09? 
8 
A. I'm not sure if I have a copy of it, but I 
9 
know that I looked over it, and we talked about it 
10 
having some wrong answers. 
11 
Q. And that was months ago? 
12 
A. Not exactly sure how long ago it was. 
13 
Q. Well, it wasn't yesterday; was it? 
14 
A. We did look at it yesterday and talk about 
15 
it, but... 
16 
Q. But you realized the — some of the answers 
17 
were incorrect when you got it sometime in January or 
18 
early February of this year, when you got a copy of it; 
19 
is that correct? 
20 
MR. EDWARDS: Object to the form. 
21 
BY MR. CRITTON: 
22 
Q. A copy of Exhibit 6? 
23 
MR. EDWARDS: Form. 
24 
THE WITNESS: I know that 1 — I did say 
2 5 
something about some of the answers. 
Page 424 
1 
Number 7, Composite Exhibit 7. 
2 
(Defendants Composite Exhibit No. 7 was 
3 
matted for identification.) 
4 
MR. CRITTON: Here's an extra copy, Brad. 
5 
BY MR. CRITTON: 
6 
Q Have you seen a copy of the letter which is 
7 
dated March 10, 2009, that I sent to Mr. Edwards before 
8 
today? 
9 
A. I don't know. 
10 
Q. I'm sorry? 
11 
A. I don't know. 
12 
Q. Well, the letter was sent in March of 2009. 
13 
Are you saying that you, now having read the letter, it 
14 
doesn't — you don't recall whether you saw that? 
15 
A. No. 
16 
Q. No, you don't recall one way or the other? 
17 
A. No, I do not recall. 
18 
Q. Okay. Turn — flip the page. There was a 
19 
document — the letter is and just so the record is 
20 
clear I'm enclosing a proposal for settlement in 
21 
order to resolve the action which has been filed by your 
22 
client. And then attached — and that's paraphrasing — 
23 
attached to the letter is a proposal of settlement, sent 
24 
by Mr. Epstein to you, in the amount of $45,000, plus 
25 
$5,000 for attorney's fees. 
42 (Pages 421 to 424) 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Pamela Sullivan (601-333.772-1552) 
Electronically signed by Pamela Sullivan (501-333-772.1552) 
(561) 832-7506 
92ef5b62-3835-4202-a350-6633a5c6813b 
EFTA00750815

Page 425 
1 
Were you aware sometime in March of '09 that 
2 
you were offered $45,000 to resolve the case? 
3 
A. Yes. 
4 
Q. Okay. And did you understand that — that 
5 
if, in fact, Mr. Epstein comes back and gets an award of 
6 
a sum something less than $45,000, say $30,000, or 
7 
you're not successful in getting a judgment in excess of 
8 
35 — 30,000, $32,000, that you'll be responsible — or 
9 
you may be responsible for all of Mr. Epstein's 
10 
attorneys fees and coats that were incurred after the 
11 
proposal for settlement? 
12 
MR. EDWARDS: Form. 
13 
BY MR. CRITTON: 
14 
Q. That is that Mr. Epstein can get a judgment 
15 
against you, maybe hundreds of thousands of dollars, are 
16 
you aware of that fact? 
17 
A. No. 
18 
Q. Okay. And do you know that that will be 
19 
against you for your entire life until you pay that off? 
20 
MR. EDWARDS: Form. 
21 
THE WrrNESS: No. 
22 
MR. HILL: How is that reasonably calculated 
23 
to lead to admissible evidence? 
24 
BY MR. CRITTON: 
25 
Q. Ms. Jane Doe, we've talked about the first 
Page 427 
1 
the Court's order said that we could, if 
2 
appropriate, go longer than seven hours. There are 
3 
a number of additional areas that I want to cover 
4 
with your client, including some background 
5 
information that was not disclosed in her answers 
6 
to interrogatories that I've not yet gotten to. 
7 
I'd like to go into the other visits that she 
8 
had with Mr. Epstein, that is who she saw, what 
9 
occurred, both by her and with Mr. Epstein, and 
10 
anyone else who may have been present at the time. 
11 
1 want to review the various counts of the 
12 
complaint with her, separate and apart from the 
13 
allegations of the various visits. 
14 
There's some other background — family 
15 
background information I want to cover with her, 
16 
and I want to cover with her any other areas of 
17 
which she may have knowledge regarding witnesses.
18 
including with regard to either 
issues, 
19 
issue, or potentially other indiviarrla s who are 
20 
Plaintiffs in this case. 
21 
There are some other additional, as I said, 
22 
family background that I wish to explore, as well 
23 
as the medical records, which I have not yet had an 
24 
opportunity to dist, KS with her, which we obtained, 
25 
and her school records. 
Page 426 
1 
time you went to Mr. Epstein's house and, I believe, the 
2 
second time you went to Mr. Epstein's house; correct? 
3 
MR. EDWARDS: Form-
4 
THE WITNESS: Yes. 
5 
BY MR. CRITFON: 
6 
Q. Okay. And you've testified that you went to 
7 
Mr. Epstein's house another approximately 18 times; is 
8 
that correct? 
9 
A. Yes. 
10 
Q. All right. And we have not discussed any of 
11 
those events, at least as of this point today; have we? 
12 
MR. EDWARDS: Form. 
13 
THE WITNESS: I {mow that I have told you 
14 
that every time I ever went to his house, he 
15 
touched me, and I gave him a massage. 
16 
BY MR. CRITTON: 
17 
Q. Okay. But we talked about that generally; we 
18 
haven't gone into each detail as to when the event 
19 
occurred or what occurred at each of those massages; 
20 
have we — other than what you generally have told me; 
21 
correct? 
22 
MR. EDWARDS: Form. 
23 
THE WITNESS: Cornea 
24 
MR. CRITTON: Pm going to adjourn the 
25 
deposition now. It is about five after 6:00, and 
(561) 832-7SOC 
Page 428 
1 
My best estimate for the time for completing 
2 
her deposition is approximately two and half to 
3 
three hours. If I can do it in a more reasonable 
4 
or a quicker fashion, twill certainly do that. 
5 
And as I advised you, Brad, I am going out of 
6 
town on Friday. I'm in the process of moving my 
7 
house. It's supposed to occur on Monday or Tuesday 
8 
of next week. We — it is now, as I said, 
9 
6 o'clock. We started about a little before 
10 
10 o'clock today. I think that the request is not 
11 
unreasonable, and I will also have opportunity to 
12 
have reviewed the transcript, so that I'm not —
13 
that I don't ask duplicative questions or retread 
14 
some area that we've already covered that I think 
15 
has been PI opt, ly covered. 
16 
As I indicated earlier is we spent almost 
17 
eight hours with a person named 
who was 
18 
a house manager for Mr. Epstein or approximately 
1.9 
six months, who was, I'd say, a small-time player. 
20 
And this is a young lady who is seeking 
21 
extensive damages, whose — damages in excess of 
22 
$50 million for both compensatory and punitive 
23 
damages. And I think we have a right to fully 
24 
explore. It's certainly not the intent to harass, 
25 
intimidate or to cause her any undue stress. I'll 
43 (Pages 425 to 428) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (501.333-772.1562) 
Electronically signed by Pamela Sullivan (501333-772.1552) 
92ef5b62-38a5.4202-a350-6633a5e6813b 
EFTA00750816

Page 429 
1 
be glad to work out a time that works for both you 
2 
and Ms. Jane Doe. 
3 
MR. EDWARDS: Just so that it is clear, we 
4 
we will not be in agreement to your proposal. I 
5 
wrote down the various areas you intend to go into. 
6 
Every single one of them was covered. I will be 
7 
able to point to those areas in the transcript when 
8 
we have a hearing on this matter. 
9 
As you pointed out earlier, Mr. Critton, the 
10 
seven-hour time limit was relieved by way of the 
11 
consolidation order, and it was done in the context 
12 
of depositions that are going to require multiple 
13 
attorneys — because there are so many attorneys 
14 
involved in this ultimate litigation — multiple 
15 
attorneys to ask questions of a particular witness 
16 
whose deposition
 to exceed seven hours, 
17 
such as Mr. la 
who was asked questions by 
18 
all seven or eight attorneys. This witness is 
19 
being asked questions by one attorney. That was 
20 
not the intent of the Court's order, and I think 
21 
that Judge Marra is going to have to rude on that 
22 
issue again. Every single one of the issues that 
23 
you intend to go into was covered. 
24 
And To like to also put on the lewtd that 
25 
in your last 15 minutes you proceeded to go into 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21' 
22 
23 
24 
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Page 431 
CERTIFICATE OF OATH 
THE STATE OF FLORIDA 
COUNTY OF PALM BEACH 
1, the undersigned authority, certify that 
JANE DOE personally appeared before me and was duly 
sworn. 
Dated this 13th day of October, 2009. 
Pamela J. Sullivan, RPR, 
Notary Public - State of Flon 
My Commission Expires: June 10, 2010 
My Commission No.: DD 560380 
Page 430 
1 
proposals for settlement, which you know are not 
2 
admissible, nor reasonably calculated to lead to 
3 
admissible evidence, and you did that at your own 
4 
peril. And so, if we are going to resume any 
5 
deposition of Jane Doe, then it will be by way of 
6 
court order. 
7 
MR. CRITTON: We're done. end 6:09 p.m. 
8 
(Whereupon, the Deposition was suspended at 
9 
6:09 p.m.) 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1. 
2 
3 
4 
5 
6 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
10 
19 
20 
21 
22 
23 
24 
25 
Page 432 
CERTIFICATE 
THESTATEOF FLORIDA 
COUNlY OF PALM BEACH 
I, Pamela J. Sullivan, Reclaimed Prolessienal 
Cant Reporter and Nola, Public in and for the State of 
Florida at lint, do hereby certify that I was 
authorized to and did report said deposition in 
stenotype, and that the foregoing pages are a true and 
correct transcription of my shorthand notes of said 
deposition 
I further certify that said deposition ins taken at 
the time and place hereinabove set forth and tint the 
taking of said deposition was commenced and completed as 
hereinabove set out 
IBM:her certify that I am not attorney or counsel 
limy of the parties, nor am I a relative or employee 
of any attorney or counsel of party connected with the 
action, nor am I financially interested in the action 
The foregoing certification of this transcript does 
net apply to any reproduction of the same by any means 
Sass tinder the direct control and/or direction of the 
mthlYinemparter 
Dated this 13th day of October, 2009. 
Parnelal. Sttaivmt, RPR. FFE.CLR 
44 (Pages 429 to 432) 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Pamela Sullivan (501.333-772-1552) 
. Electronically signed by Pamela Sullivan (501.333-772.1552) 
(561) 832-7506 
92.15b62-38a5-4202-a350-6633a5c6813b 
EFTA00750817

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Page 433 
Page 435 
ERRATA SHEET 
2 
IN RE: JANE DOE V. JEFFREY EPSTEIN 
3 
Qt: PASHA J. SULLIVAN, RPR, FPR, CLR 
4 
DEPOSITION OF: JANE DOE 
5 
DATE TAKEN: September 30, 2009 
6 
DO NOT WRITE ON TRANSCRIPT- ENTER CHANGES HERE 
7 
PACE. LINE /I CHANGE 
REASON 
10 
11 
12 
13 
14 
IS 
16 
17 
18 
19 
Hesse forward the original signed CROW sheet to this 
office so that copies may be distribute:dwell parties. 
20 
Under penalty of perjum I declare Om I hat read my 
21 
deposition and that it is true and correct subject to 
any changes in form cc substance emceed hens. 
22 
23 
DATE: 
24 
25 
SIGNATURE OF DEPONENT' 
Page 434 
1 
CERTIFICATE 
2 
3 
THE STATE OF FLORIDA 
4 
COUNTY OF PALM BEACH 
5 
I hereby artily that I have read the foregoing 
6 
deposition by me given, and that the statements 
7 
contained herein are hue end correct to the best of my 
8 
knowledge and belief, with the exception of any 
9 
corrections or notations made on the errata sheet, if 
10 
one was executed. 
11 
12 
Dated this 
day of 
, 2009. 
13 
14 
15 
16 
17 
JANE DOE 
18 
19 
20 
21 
22 
23 
24 
25 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, 
45 (Pages 433 to 435) 
INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (501-333-772-1652) 
Electronically signed by Pamela Sullivan (501-333-772-1552) 
92ef5b62-38a5-4202-a350-6633a6c6S13b 
EFTA00750818