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Page 318 
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When is the last thne you saw 
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A. On the back of some kid's crotch rocket at 
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Target when I was with my cousin a couple years ago, 
4 
maybe a year ago. 
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Q. Crotch rocket, you mean some kind of a —
6 
A. Bike. 
7 
Q. 
fast motorcycle? 
8 
A. Yes. 
9 
Q. Did you talk to her? 
10 
A. No. 
11 
Q. Did you have 
when is the last time you ever 
12 
had any communication with her whatsoever? 
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A. When she tried getting me to bring her back to 
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Epstein. 
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Q. Back when she was I4? 
16 
A. Yes. 
17 
Q. So whether or not she regrets and feels bad 
18 
and has emotional trauma and is upset, much like you 
19 
testified that you are, you have no idea today? 
20 
MR. CRITTON: Form. 
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THE WITNESS: No idea about what? 
22 
BY MR. KUVIN: 
23 
Q. Whether she regrets what happened back then 
24 
when she was younger. 
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A. No, I don't care. 
Page 320 
1 
Q. And because of the small town, what? 
2 
A. I lmow a lot of people. 
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Q. And all — many of them seem to be drug users 
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and drug sellers? 
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A. Yes. 
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Q. As you sit idle and sort of watch them while 
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they use and sell drugs or do you participate --
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MS. BLANTON: Do not answer that question. 
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BY MR. HOROWITZ: 
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Q. — and partake in the drug use and sales? 
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MR. CRITTON: Form. 
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MS. BLANTON: That question has been asked. 
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I've stated my full objection. Fm instructing her 
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to assert her Fifth Amendment Right. And if you 
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would like for her to do it again, she will. 
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BY MR. HOROWITZ: 
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Q. Isn't it true that the people who you 
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identified as drug users and drug sellers, you have 
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sold, purchased or consumed drugs with? 
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MR. CRITTON: Form. 
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MS. BLANTON: Do not answer that question. 
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And do not ask her another question that has 
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already been asked and her Amendments have been 
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asserted to — her Fifth Amendments Rights have 
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been asserted. If you have a different question, 
Page 319 
1 
Q. You don't really care about any of these girls 
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and what they feel, do you? 
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MS. BLANTON: Objection. 
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THE WITNESS: No. 
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BY MR. KUVIN: 
6 
Q. You could care a less whether they're 
7 
emotionally traumatized or not? 
A. Yes. I could care less. 
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MR. KIJVIN: Okay. Perfect. Thank you. 
10 
That's all I got. 
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MR. CRITTON: Microphone. 
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RECROSS EXAMINATION 
13 
BY MR. HOROWffZ: 
14 
Q. Within your social circles when you were in 
15 
high school, you've identified several people who were 
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users and/or sellers of drugs, correct? 
17 
A. Yes. 
18 
Q. In your examination by Mr. Epstein's attorney, 
19 
do you remember telling us several people who you felt 
20 
were drug dealers or drug users? Yes? 
21 
A. Yes. 
22 
Q. How is it that you seem to know so many drug 
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users and sellers? How is it that you come into social 
24 
contact with all these people? 
25 
A. 
s a small town. 
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Page 321 
please move on. 
BY MR.. HOROWITZ: 
Q. Isn't it true that like some of the other 
girls you mentioned, you also slept around with 
boyfriends while you were in high school? 
MS. BLANTON: Do not answer that question. It 
has been asked. I've asserted my objection. 
Do you have another question —
MR. HOROWITZ: I have many more questions. 
MS. BLANTON: — or else this deposition is 
over. 
MR. HOROWITZ: I have many more questions. 
MS. BLANTON: Do you have one that has not 
been asked? 
MR. HOROWITZ: I have many more questions. 
BY MR. HOROWITZ: 
Q. Isn't it true that you have had sexual 
intercourse with Jane Doe 4? You've had sexual contact 
with her? 
MS. BLANTON: Objection. 
THE WITNESS: Oh, what? 
MS. BLANTON: Do not answer that question. 
BY MR. HOROWITZ: 
Q. Isn't it true that you slept with Jane Doe 4's 
boyfriend? 
42 (Pages 318 to 321) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Sandra Townsend (401 
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Page 322 
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MS. BLANTON: Do not answer the question. 
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THE WITNESS: I'm done. 
3 
MS. BLANTON: Do you have a question that has 
not -- you don't have to say anything. 
Do you have another question that has not been 
5 
asked? 
BY MR. HOROWITZ: 
Q. You described Mr. Epstein to his lawyer as 
9 
being a nice person; is that right? You were asked, is 
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he nice? And you said, yes, he's nice? 
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A. Yes. 
12 
Q. In your mind, was it nice of Mr. Epstein to 
13 
masturbate in front of you when you were a child? 
14 
A. I don't know. I wasn't a child. 
15 
MR. CRITTON: Form. 
16 
BY MR. HOROWITZ: 
17 
Q. When you were a 16 year old girl and 
18 
Mr. Epstein was masturbating in front of you, exposing 
19 
his genitals, was that a nice thing of him to do? 
20 
MR. CRITT0N: Form. 
21 
THE WITNESS: I don't know. 
22 
BY MR. HOROWITZ: 
23 
Q. You have no opinion? 
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A. i have no opinion. 
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Q. When Mr. Epstein had his hand on his penis, on 
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Page 324 
A. I don't know. 
Q. You have no knowledge of her going into the 
champagne room and giving a lap dance to a grown man and 
taking off her clothes, correct? 
A. i don't know. 
Q. But that, if she were to do thaL that would 
be something tilt promiscuous? 
A. I don't know. 
MS. BLANTON: Object to the form. 
BY MR. HOROWITZ: 
Q. With regard to Jane Doe 4, other than a 
three-hour try out where she didn't continue to work at 
a strip club, you're not aware of her ever working at a 
strip club, correct? 
A. I don't know. 
Q. And with regard to Jane Doe 7, you have no 
knowledge of her working at a strip club, correct? 
A. I don't know. 
Q. Those would be the kinds of things that 
promiscuous girls would do, correct? 
A. I don't know. 
MR. CRITTON: Pam. 
MS. BLANTON: Object to the form. 
BY MR. HOROWITZ: 
Q. You described Jane Doe 4, in your opinion, as 
Page 323 
1 
his shaft and he's stroking it and he's coming — having 
2 
orgasm, was that a nice thing of him to do to you? 
3 
A. I don't know. 
• 
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MR. CRITTON: Let me object to the form. It's 
5 
intimidating, It's dying to harass her. 
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MS. BLANTON: Wine as well. 
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MR, CRITTON: I think it serves no purpose. 
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BY MR. HOROWITZ:
9 
Q. And when you look back on it, is that a nice 
10 
memory that you have? 
11 
MR. CRITTON: Form. 
12 
THE WITNESS: I don't know. 
13 
MS. BLANTON: Let the record reflect that it's 
14 
after 6:00. You've been here for over seven hours 
15 
and these questions not only serve to intimidate, 
16 
harass and embarrass her, theyre very ill willed 
17 
and worded at this point. 
18 
BY MR. HOROWITZ: 
19 
Q. You described — you described Jane Doe 3 as 
20 
promiscuous? 
21 
A. Yes, 
22 
Q. Now, she wasn't the kind of girl who would 
23 
give lap dances at a strip club, was she? 
24 
A. I don't know. 
25 
Q. You have no knowledge that she did that? 
Page 325 
1 
being not an honest person, correct? 
2 
A. That's true. 
3 
Q. And if we were to ask Jane Doe 4 today whether 
4 
you were an honest person, would you agree that she 
5 
would likely say that you were dishonest? 
6 
MS. BLANTON: Object to the form. You're 
7 
asking her to --
8 
MR. CRITTON: Form. 
9 
THE WITNESS: i don't know. 
10 
MS. BLANTON: — speculate. 
11 
BY MR. HOROWITZ: 
12 
Q. You wouldn't be surprised if she said that you 
13 
were a liar? 
14 
A. i wouldn't be surprised if she told me she was 
15 
a raging alcoholic lesbian who loved monkeys. it would 
16 
not shock me. 
17 
Q. And although you described Jane Doe 4 as being 
18 
promiscuous for a period of years, you actually remained 
19 
friends with her; is that right? 
20 
A. Acquaintances. 
21 
Q. More than acquaintances. You actually staged 
22 
an intervention for her benefit is that correct? 
23 
MS. BLANTON: Is there a question? 
24 
THE WITNESS: I pitied her, yes. 
25 
BY MR. HOROWITZ: 
. 43 (Pages 322 to 325 
PROSE COURT REPORTING AGENCY, INC. 
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Page 326 
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Q. Pardon me? 
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A. Yes. I pitied her. 
3 
Q. You cared for her enough you wanted to --
4 
A. I care for any woman that gets battered by 
5 
their boyfriend or husband, yes. 
6 
Q. And you wanted her to have a better life and, 
7 
so, that's what you thought was the appropriate thing to 
8 
do? 
9 
A. I thought that was the appropriate thing. 
10 
Q. So even though she had a tumultuous 
11 
relationship and in your mind was promiscuous and a drug 
12 
user, you still you still were within her social 
13 
circles, right? 
14 
A. I still wanted to help her. 
15 
Q. You still went to parties with her where you 
16 
claim that she used drugs? 
17 
A. Not went to parties with her. 
18 
Q. You went to parties — you went to parties 
19 
where you saw her and you were within close enough 
20 
proximity that you could see her purportedly using 
21 
drugs, right? 
22 
A. It's called, keeping order. 
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Q. Keeping whose order? 
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A. Keeping order. 
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Q. What does that mean? 
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Page 328 
Q. Do you have a specific recollection of her 
using drugs in the 11th grade? 
A. Yes. 
Q. And in the 12th grade? 
A. Yes. 
Q. And would you agree that her — any ding use 
she had increased over time? 
A. I don't know that. 
MR. CRITTON: Form. 
BY MR. HOROWITZ: 
Q. Did the types of drugs that she used increase 
over time, meaning, more substantial? 
A. No. It's the same drugs. 
Q. And you described, I think, one or two 
incidences of her breaking up and being with other —
other guys when she was in break ups, right? 
A. Uh-huh. 
Q. What grade did that take place in? 
A. Well, she was with 
her junior and 12th 
grade years, so it happened then. 
Q. Okay. And you described — didn't you tell us 
that you felt that Jane Doe 3 used drugs? 
A. Jane Doe 3 did use drugs. 
Q. In what grades do you think she used drugs in? 
I lth? 12th? Tenth? Ninth? 
Page 327 
1 
A. I'm out in public. I'm going to be cordial 
2 
whether I like you or not. That's just me. 
3 
Q. But you stayed close enough to her that you 
4 
could supposedly watch her use drugs? 
5 
MS. BLANTON: Asked. Answered. 
6 
BY MR. HOROWITZ: 
7 
Q. Is that right? 
8 
A. Sure, yes. 
9 
Q. And not only that, you were sufficiently 
10 
familiar with the relationship she had with her 
11 
boyfriend, such that, you could see the type of 
12 
tumultuous relationship that you've described to us? 
13 
A. Yes. 
14 
Q. You didn't uy and stay out of her life; you 
15 
kept in close contact with her so that you could know 
16 
the ins an outs of her relationship with her boyfriend? 
17 
A. I didn't stay too close to her. 
18 
Q. What age or what grade do you think — strike 
19 
that. 
20 
Can you have a specific recollection of Jane 
21 
Doe 4 using drugs in the ninth grade? 
22 
A. Yes. 
23 
Q. What — do you have a specific recollection of 
24 
her using drugs in the tenth grade? 
25 
A. I can't recall. 
Page 329 
1 
MR. CRITTON: Form. 
2 
THE WITNESS: Tenth. 
3 
BY MR. HOROWITZ: 
4 
Q. Okay. Any — any other grade? 
5 
A. I can't recall. 
6 
Q. And what ages do you think 
what grades do 
7 
you think she was promiscuous, in your mind? 
8 
A. I can't recall what grade she was in. 
9 
Q. And when you describe someone as being 
10 
promiscuous, are you comparing it to sort of your own 
11 
values and morals or — 
12 
MS. BLANTON: Object to the form. 
13 
And do not answer that. 
14 
THE WITNESS: I'm not going to. 
15 
MR. HOROWITZ: No. I think I'm entitled to 
16 
understand her foundation, the predicate upon which 
17 
she's calling someone promiscuous. 
18 
BY MR. HOROWITZ: 
19 
Q. And who are you comparing that to? 
20 
A. I'm not comparing it to anybody. Obviously 
21 
when a girl is having a threesome in a bedroom, that's 
22 
promiscuous to me. 
23 
Q. And you were watching this? 
24 
A. I walked in on it. 
25 
Q. And you just kind of did what? 
 tra 
44 (Pages 326 to 329) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
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Page 330 
Page 332 
A. Shut the door. We were at a party. 
2 
Q. And when you are dancing at strip dubs, do 
3 
you ever give lap dances to two men at a time? 
4 
MS. BLANTON: Object. Do not answer. 
5 
MR. HOROWITZ: No other questions. 
6 
MR. CRITTON: I have one question. 
7 
RECROSS EXAMINATION 
8 
BY MR. CRITTON: 
9 
Q. And Mr. Horowitz didn't want to follow up on 
10 
it. But he said, he asked you what — your definition 
11 
of promiscuous. And you said, walking in or seeing 
12 
someone in a threesome falls within your definition of 
13 
promiscuous? 
14 
A. Yes. 
15 
Q. Who did you see in a threesome and where were 
16 
you? 
17 
A. Jane Doe 3. 
18 
Q. Was with what, another girl and a guy? Two 
19 
guys? 
20 
A. Two guys. 
21 
Q. Wbat was she doing? 
22 
A. I just saw her naked over the bed. That's it. 
23 
MR. CRITTON: All right That's all I have. 
24 
RECROSS EXAMINATION 
25 
BY MR. HOROWITZ: 
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CERTIFICATE OF OATH 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
1 the undersi 
authority, certify that 
personally appeared before me and was duly 
sworn on the 10th day of November, 2009. 
Dated this 20th day of November, 2009. 
&Air
:tut 
Sandra W. Townsend, Court R 
16 
Notary Public - State of Florida 
My Commission Expires: 6t26/12 
17 
My Commission No.: DO W3913 
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Page 331 
Q. And what grade was she in when this supposedly 
took place? 
A. I can't recall. 
MR. HOROWITZ: Thank you. 
MR. CRITTON: You going to read? 
MS. BLANTON: Yes, please. 
VIDEOGRAPHF.R: Going off the record. This is 
the end of tape number five. The time is 6:12 p.m. 
(Witness excused.) 
(Deposition was concluded.) 
1 
CERTIFICATE 
2 
STATE OF FLORIDA 
3 
COUNTY OE PALM BEACH 
4 
Sandra W. Towson& Court Reporter sad 
Notary Public in and for the State of Florida at Urge, 
6 
do Itchy et-iffy Om the aforementioned witruna was lyy 
me first clay swan to testify the whale Mork that I 
wall authorized to and did Itfort said doposmon 
stenotype; and this the foregoing pages rumbaed 157 
to 329. inclusive, aro a Int and correct hartxripion
of my sbonhand noies Maid deposition. 
I funk( certify that said deposition was 
10 
taken at the time and place hatirtabovc set forth and 
that the taking of said deposition wn connanced and 
11 
completed as hereinabose set at. 
12 
I further certify Oat I am tot attorney or 
Camel of any of the parties, nor am! a relative or 
13 
employee Many attorney or counsel of party emanated 
with the action, nor am I finan.ially interested in On 
14 
action. 
15 
The foregoing eaufleabon of this incorript 
does not apply to any reproduction ti the same by any 
16 
nails unless under die dimes cordrd and/or direction 
of the certifying reporter. 
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Dated this 20th day of November, 2009 
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Cia2hdrAELAC/L 
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Sandra W. Townsend Court Reporter 
Page 333 
45 (Pages 330 to 333) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
7082dd669eo-4o57-9cd8-839205600fe0 
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fags 334 
Page 336 
DATE, 
2 
TO 
Go 
i 
non, Esquire 
3 
MCINTOSH. SAWRAN, PELTZ & CARTAYA, P.A. 
1601 Fawn Place. Suite 1110 
W 
Bach, Florida 33401 
CASE NO.: 
08CA0373 I 97000M3 AB 
eC
IN RE 
Epstein
vs. 
Please take notice that on Tuesday, the 10th 
of November, 2009, you gave your depositica in the 
above-referred matter At that time, you did not wain 
signature It is now necessity that you sign your 
9 
deposition_ 
Please all as office at the below-listed 
10 
number to schedule an appointment between the hours of 
9110 a.m. and 4:30 p m., Monday through Enday, it the 
11 
Esquire office located nearest you. 
If you do not read and sign the deposition 
12 
within a reasonable time, the original, which has 
already been forwarded to the ordering attorney, may be 
13 
• filed with the Chili of the Court Byars wish to waive 
your signature. sign your name in the blank at the 
14 
bottom ofthis letter and return it to us. 
15 
Very truly yours, 
16 
17 
18 
Sandra W. Townsend, FPR 
PROSE COURT REPORTING AGENCY 
19 
250S. Australian Avenue, Suite 1500 
West Palm Beach, Florida 33401 
20 
21 
22 
23 
24 
2S 
2 
3 
THE STATE OF FLORIDA 
4 
COUNTY OF PALM BEACH 
5 
I hereby certify that I have read the 
6 
foregoing deposition by me given, and that the 
7 
statements contained herein are true and correct to the 
8 
best of my knowledge and belief, with the exception of 
9 
any corrections or notations made on the errata sheet, 
10 
if one was executed. 
11 
12 
Dated this 
day of 
13 
2009. 
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15 
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I do hereby waive my sigranire 
waive my signature. 
Cc Via transcript: All Counsel of Record; file copy 
CERTIFICATE 
Page 335 
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PAGE LINES CHANGE 
REASON 
RRATA SHEET 
IN RE: I. 
VS. 
t
WISEND
DEPOS ON O 
TAKEN. 11/10(19 
DONDE WRITE ON TRANSCRIPT - ENTER CHANGES HERE 
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Please forward the original signed errata sheet to this 
office so that copies may be distributed to all parties. 
Under penally of perjury,1 declare that 1 have read my 
20 
deposition and that it is true and correct subject to 
any changes in &an or substance enteral here. 
DATE: 
SIGNATURE OP DEPONENT. 
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46 (Pages 334 L._ 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsond (401 
7a82dddf-69oe-44757-9cd8-839205600fc0 
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