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1 
Q. 
Let me get back to the police here. 
2 
So the police sit and they interview you for 
3 
an hour and a half to two hours, and during that, not 
4 
only the sworn part of the testimony out of your 
5 
statement, but as well you're saying that you lied to 
6 
them during part of, part of what you've said, both 
7 
sworn and unsworn, and as well you didn't provide them 
8 
all the information, right? 
9 
A. 
Yes. 
10 
Q. 
Now, you filed your lawsuit in this case 
11 
against Mr. Epstein and you are seeking, at least your 
12 
lawyers are asking in part of the complaint for 
13 
$50 million. Are you aware of that? 
14 
A. 
No, my lawyers take care of all that. 
15 
Q. 
All right. Let me show you I'll mark as 
16 
Exhibit 1. 
17 
(The document was marked Defendant's 
18 
Exhibit 1 for identification.) 
19 
BY MR. CRITTON: 
20 
Q. 
Exhibit 1 is the amended complaint that you 
21 
filed, that your lawyers -- it's the second complaint 
22 
that actually was filed in this action. The original 
23 
complaint was filed on September 10th of '08, all right? 
24 
A. 
Uh huh. 
25 
Q. 
Yes? 
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1 
A. 
Yes. 
2 
Q. 
All right. So between the time that the 
3 
lawsuit was filed on September -- let me strike that --
4 
that you gave a statement to the police officers under 
5 
which you, about which you've admitted you did not tell 
6 
the truth on 
, 2005, up until three years 
7 
later -- almost three years later, September 10th of 
8 
'08, did you recontact the police and tell the police 
9 
that you had not told them the truth? In fact, you had 
10 
lied to them and withheld information? 
11 
A. 
I told the FBI that when they came up to visit 
12 
me 
13 
Q. 
That wasn't my question. 
14 
MR. HOROWITZ: Form. 
15 
BY MR. CRITTON: 
16 
Q. 
My question was did you talk to the Palm Beach 
17 
police department --
18 
A. 
I never talked to them after that. 
19 
Q. 
I need to finish the question. 
20 
A. 
I'm sorry. 
21 
Q. 
-- from the time that you first spoke with 
22 
them on 
of 2005 up until the time that the 
23 
complaint was filed, that is, to bring this lawsuit 
24 
seeking damages in excess of $50 million against 
25 
Mr: Epstein, did you ever call or recontact the Palm 
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you first went to Mr. Epstein's home? 
2 
A. 
I believe I went the end of my sophomore year 
3 
till about the end of my junior year. I'm not sure if 
4 
it was the beginning or the end of my sophomore year. 
5 
Somewhere around there. 
6 
Q. 
Well, you told the police that you were 
7 
approximately 17 when you first went to Mr. Epstein's 
8 
home, didn't you? 
9 
A. 
I don't exactly remember what, when I said 
10 
that, I first told them I went. 
11 
Q. 
If I asked you to assume that the police 
12 
report reflects that the statement that you gave to 
13 
them, that you were there when you were 17 years old, 
14 
all right? 
15 
A. 
Okay. 
16 
Q. 
If you were 17 years old and you were born in, 
17 
let's see, 
so it would have been 
18 
approximately June, the end of June of 2004, correct, 
19 
that you first went there? 
20 
MR. HOROWITZ: Form. 
21 
THE WITNESS: I, I don't exactly know, to be 
22 
honest with you. 
23 
BY MR. CRITTON: 
24 
Q. 
You mean when you first went to Mr. Epstein's? 
25 
A. 
I can't put a date on it. I just remember it 
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was my sophomore year to my junior year. 
2 
Q. 
When you gave a statement to the police on 
3 
, 2005, whether you were 16 or 17, what 
4 
difference would it have made to the police officers? 
5 
Why would being scared or confused, why would you lie 
6 
about your age when you first went to Mr. Epstein's? 
7 
MR. HOROWITZ: Form. 
8 
THE WITNESS: I don't know. 
9 
BY MR. CRITTON: 
10 
Q. 
Maybe in fact --
11 
A. 
I mean I did go when I was 17 too, so I may 
12 
have just said 17, I don't really know. 
13 
Q. 
Well, you were 18 -- again, would you agree 
14 
with me that your recollection of the events involving 
15 
Mr. Epstein would have been better in October of '05 
16 
than it is at the current time? 
17 
MR. HOROWITZ: Form. 
18 
THE WITNESS: Yes. 
19 
BY MR. CRITTON: 
20 
Q. 
And if you told the police officers you were 
21 
17 when you first went to Mr. Epstein's home, would you 
22 
agree with me that that, there would have been no reason 
23 
for you to lie about your age at that time --
24 
MR. HOROWITZ: Form. 
25 
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BY MR. CRITTON: 
2 
Q. 
-- to the police officers? 
3 
MR. HOROWITZ: Form. 
4 
BY MR. CRITTON: 
5 
Q. 
Whether you were scared or confused at that 
6 
time, you probably would have given them at least your 
7 
accurate age when you first went to Mr. Epstein's? 
8 
MR. HOROWITZ: Form. 
9 
THE WITNESS: I may have said it because I was 
10 
scared and I didn't want to them to think I 
11 
actually went that long, or I don't know why I said 
12 
it. I honestly don't know. 
13 
BY MR. CRITTON: 
14 
Q. 
And maybe it was the truth at the time? 
15 
MR. HOROWITZ: Form. 
16 
THE WITNESS: I mean I really don't know. 
17 
BY MR. CRITTON: 
18 
Q. 
So it may have been the truth, it may not have 
19 
been the truth; even today you don't know, correct, 
20 
whether you were 17 when you first went to 
21 
Mr. Epstein's? 
22 
A. 
I believe I was 16, because I believe it was 
23 
the end of my sophomore year. So I at least think I was 
24 
16. 
25 
Q. 
So you are meeting with two police officers 
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from the Town of Palm Beach in basically a secure 
2 
environment, nothing can happen to you there. You told 
3 
them that you were 17 years old when you first went to 
4 
Mr. Epstein's. 
5 
Now that you are seeking $50 million in a 
6 
lawsuit that was filed on September 10 of '08, now all 
7 
of a sudden maybe you were 16? Is that your testimony? 
8 
MR. HOROWITZ: Let me object to form. You are 
9 
mischaracterizing the testimony. 
10 
BY MR. CRITTON: 
11 
Q. 
You can go ahead and answer, ma'am. 
12 
A. 
Well, I told you that I didn't tell them the 
13 
complete truth. So what would it matter if I told them 
14 
I was 17 or 16, when I already told you I didn't tell 
15 
them the complete truth and I didn't tell them 
16 
everything that happened? 
17 
Q. 
Well, again, my point is merely is --
18 
A. 
I understand. 
19 
Q. 
I want you to confirm that you didn't even 
20 
tell them the correct age, or at least your position is 
21 
you may have lied to the police officers even about the 
22 
age when you first went to Mr. Epstein's house? 
23 
A. 
I believe the only reason I would have lied 
24 
about my age, because I was scared and I didn't want 
25 
them obviously when I was 16 to think that I went there 
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as well as 17 and if I didn't really want to be involved 
2 
in it, so maybe that's why I said I was 17. I don't 
3 
remember that far back what I was thinking. 
4 
Q. 
Okay. I understand that. But in fact it 
5 
could have been true that the first time you went to 
6 
Mr. Epstein's house you were 17 years old, correct? 
7 
MR. HOROWITZ: Form. 
8 
THE WITNESS: No, I remember going around the 
9 
end of my sophomore year. 
10 
BY MR. CRITTON: 
11 
Q. 
Give me your best exact date when you first 
12 
went to Mr. Epstein's home. 
13 
A. 
I remember III. was 
and she 
14 
asked me to go, and I'm almost positive that was my 
15 
towards the end of my sophomore year. She was in 
16 
class. 
17 
Q. 
That takes you now to your sophomore year? 
18 
A. 
Yes. 
19 
Q. 
Okay. 
20 
A. 
Yes. 
21 
Q. 
Which would have been when? 
22 
A. 
When I was 16. 
23 
Q. 
You were a senior -- let's just get the dates 
24 
right. You were senior as of August of '05 -- I'm 
25 
sorry, of '04, correct? 
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1 
A. 
Yes. 
2 
Q. 
And as of August of '04, you would have been 
3 
17 years old as a senior; is that correct? 
4 
A. 
Yes. 
5 
Q. 
Okay. So as a junior, you would have been 16 
6 
years old and you would have started in August of '03 to 
7 
'04, right? 
8 
A. 
Yes. 
9 
Q. 
If '05, 04-05 is your senior year and you were 
10 
17 during your whole senior year; is that correct? 
11 
A. 
Yes. 
12 
Q. 
All right. So you would have been 16 during 
13 
your entire junior year? 
14 
A. 
Uh huh. 
15 
Q. 
Yes? 
16 
A. 
Yes. 
17 
Q. 
Okay. But you just said 
. asked you to go 
18 
to Mr. Epstein's house now when you were in your 
19 
sophomore year. 
20 
A. 
Yes. 
21 
Q. 
Okay. So you would have been 15 then? 
22 
A. 
I guess so. I wasn't really going by age. I 
23 
was just trying to remember when she was in 
24 
class, and I can't remember if it was my sophomore or my 
25 
junior year. 
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1 
Q. 
So now you are saying it really could be the 
2 
junior year? 
3 
A. 
I really, I really don't know. I can't 
4 
remember. I just remember her being 
5 
asking me to go. 
6 
Q. 
So maybe it's '03, maybe it's '04, maybe it's 
7 
'05, you are just not sure? 
8 
MR. HOROWITZ: Form. 
9 
THE WITNESS: It's not '05. It was either 
10 
2003, I'm pretty sure it was 2003 -- or 2002 or 
11 
2003 through 2004. It wasn't 2005 at all. 
12 
BY MR. CRITTON: 
13 
Q. 
All right. Let me show you what I'll mark as 
14 
Exhibit 2. 
15 
(The document was marked Defendant's Exhibit 
16 
2 for identification.) 
17 
MR. CRITTON: Here's extra copy for you. 
18 
MR. HOROWITZ: Okay. 
19 
BY MR. CRITTON: 
20 
Q. 
These are interrogatory answers that you 
21 
signed on January 23, 2008. Do you see that? 
22 
A. 
Yes. 
23 
Q. 
Would you go to the second, go to the 
24 
second-to-last page. 
25 
MR. HOROWITZ: What, is there a question? 
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