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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO:502008CA028051XXXXMB AB 
Plaintiff, 
- vs-
JEFFREY EPSTEIN 
AND 
Defendants. 
VOLUME III OF IV 
VIDEO-CONFERENCED VIDEOTAPED DEPOSITION OFIIII. 
Tuesday, February 09, 2010 
10:09 - 5:05 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting 
Job No.: 1296 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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Page 339 
1 
APPEARANCES: 
2 
On beJulf ofthe Plaintiff lig! 
and Jane Dot 
3 
BRAD J. EDWARDS, 
FARMER, JAFFE, WEISSItla EDWARDS 
4 
I 
9 
On 
of tbe 
Jeffrey Epstein: 
ROBERT D. CROTON, JR., ESQUIRE 
MARK T. LUTHER. ESQUIRE 
LUITIER ea COLEMAN, LLP 
• 2 
On bed o 
• • licfrroYEPslele: 
.3 
JACK ALAN GOLDBERGER, ESQUIRE 
ER Fe WEISS. PA 
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16 
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ALSO PRESENT: kffrey Epstein, via video conference 
Daniel Downey, Videograplicr 
Visual Evidence, Incorporated 
1 
PROCEEDINGS 
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3 
THE VIDEOGRAPHER: This is the 9th day of 
4 
February, 2010. The dine is approximately 
5 
10 imIty.m. This is the videotaped deposition 
6 
OM. in the matter of M. versus Epstein. 
7 
This deposition is being held at 250 South 
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Australian Avenue, West Palm Beach, Florida. 
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My name is Daniel Downey, I am the 
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videographer representing Visual Evidence, 
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Incorporated. Will the attorneys please 
12 
announce their appearances for the record. 
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MR. EDWARDS: Brad Edwards on behalf of 
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MR. LUTTLER: Mark Luttier with the firm 
16 
of Burman, Critton, Luther & Coleman on behalf 
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of Mr. Epstein. 
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MR. CRITMN: Bob Critton on behalf of 
19 
Mr. Epstein. 
20 
Thereupon, 
21 
22 
Having been first duly sworn or affirmed, was 
23 
examined and testified as follows: 
24 
THE WITNESS: I do. 
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1 
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INDEX VOLUME I 
Page 338 
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WITNESS: 
DIRECT CROSS REDIRECT RECROSS 
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BY MR. LUTHER 4 
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11. 
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NO EXHIBITS MARKED 
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DIRECT EXAMINATION 
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BY MR. LLTIT1ER: 
3 
Q. Good morning, Ms... We're here for the 
4 
continuation of your deposition that was started on 
5 
September 24th, 2009. Do you understand that you're 
6 
still under oath today? 
7 
A. Yes, sir. 
8 
Q. Have you had an opportunity to reviewa 
9 
transcript of that portion of your deposition which 
10 
has been completed thus far? 
11 
A. Yes, sir. 
12 
Q. Have you reviewed the full transcript? 
13 
A. Yes, sir. 
14 
Q. And were there any corrections in your 
15 
testimony? 
16 
A. Were there any corrections in my testimony? 
17 
Q. In other words, when you read it did you 
18 
see anything that was incorrect? 
19 
A. No, sir. 
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Q. Do you recall whether or not you silted 
21 
the transcript indicating that all of it was 
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accurate? 
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A. I signed, yes. 
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Q Do you know if the original got sent 
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anywhere or do you stil I have it or dicliou just 
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give it to your lawyer? 
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A. I gave it to my attorney. 
3 
Q. And you signed it without any corrections? 
4 
A. Yes, sir. 
5 
Q. Have you ever been to Mr. Edwards' former 
6 
law firm's office in Fort Lauderdale? That would be 
7 
the firm of Rothstein, Rosenfeldt & Adler. 
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A. What is this address? Is this address on 
9 
Andrews? 
10 
Q. 
1/ 
A. No. 
12 
Q. Have you ever been to a law firm where 
13 
Mr. Edwards was practicing while he's been 
14 
representing you where there are other lawyers 
15 
besides himself present? 
16 
A. No. 
17 
Q. Does the name Rothstein ring a bell to 
18 
you? Do you know who that is? 
19 
A. No. 
20 
Q. Do -- have you ever met with anyone else 
21 
other than your lawyer with respect to the merits of 
22 
this lawsuit and whether or not you believed you 
23 
were likely to recover money in this case? 
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A. No. 
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Q. Has anyone ever approached you arid --
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Page 343 
shown to third parties and they had been asked 
whether or not they wanted to purchase an interest 
in your lawsuit? 
A. No. 
Q. No one had called you and advised you that 
your files were being shown to anybody? 
A. No. 
Q. Have you had any discussions with anyone 
about that issue? 
A. No. 
Q. And when I say anyone I mean 
representative of the Florida Bar Association; have 
you had any discussions with anybody from the 
Florida Bar? 
A. No, sir. 
Q. Any discussions with anybody from the FBI 
about that specific issue? 
A. About what issue, about getting —
. 
Q. About someone attempting to purchase an 
interest in your lawsuit. 
A. No. 
Q. Anyone from the State Attorney's office? 
A. No. 
Q. Okay. Prior to coming here today, have 
you had an opportunity to review a transcript of a 
Page 342 
1 
other than your lawyer -- and discussed with you the 
2 
merits of this case or whether or not you believed 
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you were likely to recover money? 
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A. No. 
Q. Have you been advised that — or let me 
6 
strike that. Have you been provided any information 
7 
that your case and the information contained in it 
8 
was made available to third parties to review to 
9 
determine whether or not they wanted to purchase an 
10 
interest in the outcome of your case? 
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A. No. 
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Q. Have you, prior to me just asking you that 
13 • 
question, did you know that that had occurred? 
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MR. EDWARDS: Object to the fonn. 
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THE WITNESS: Excuse me? 
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MR. EDWARDS: I objected to the form of 
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the question. It assumes that it did occur. 
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BY MR. LUITIER: 
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Q. Before I asked you that question, did you 
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know that that had occurred. 
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A. Sr, I'm not really understanding what you're 
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saying. 
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Q. All right. Let me repeat it. 
24 
. 
A. Okay. 
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Q. Did you know that your case tiles had been 
Page 344 
1 
hearing that was held before the court on 
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November 3rd, 2009, upon your motion to terminate 
3 
the continuation of this deposition? 
4 
A. Excuse me? 
5 
Q. Prior to coming here today have you been 
6 
provided an opportunity to review a transcript of a 
7 
hearing that was held before the court on 
8 
November 3rd, 2009, on your motion to limit this 
9 
deposition? 
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A. I'm not understanding this. 
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Q. You know what a transcript is, don't you? 
12 
A. A transcript, yes. 
13 
Q. This would have been a transcript or 
14 
written record of a court hearing that we had in 
15 
case on November 3rd, 2009, that concerned the 
16 
conducting of this deposition. Have you seen any 
17 
such transcript? 
18 
A. A transcript of what? 
19 
Q. Of that court hearing. 
20 
A. Of what court hearing? 
21 
Q. The one that was held on November 3rd, 
22 
2009. 
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A. That we recently just did, my last deposition? 
24 
Q. No. The, the hearing was held on 
25 
November 3rd, 2009. The subject matter of the 
(561) 832-7500 
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Page 345 
hearing was a motion that was filed by your lawyer 
to limit the continuation of this deposition. 
A. Yes. I knew that we were going to have 
another deposition. 
• 
Have you seen the transcript of that 
hearing wherein the judge gave some specific 
direction to you and your conduct in the 
continuation of this — 
A. Yes. 
Q. 
deposition? 
A. Yes. 
Q. Okay. So you're aware of that? 
A. Yes. 
Q. Okay. Are you still living at the same 
address that you gave me at the last deposition? 
A. Yes, sir. 
Q. Who else is living with you there now? 
A. My son. 
Q. Anyone else? 
A. No, sir. 
Q. Has anyone else lived with you at that 
address since your deposition on September 24th, 
2009, other than your son? 
A. No, sir. Since November, actually, Thomas 
Souder, he had moved, he lived with me until 
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Page 347 
was 13 years old. And on that note, he took it from 
there to just comfort me through the, through the pain 
that I was going through and that I have been going 
through. 
Q. Did any of these discussions concern 
anything else? 
A. No, sir. 
Q Have you, since your deposition on 
September 24th, 2009, had any type of contact with 
anyone else who has filed asuit against 
Mr. Epstein? 
A. Yes. 
Q. M. 
Who have you had contact with? 
A 
Q. Anyone else? 
A. No, sir. 
Q. And when I, I use the word contact, by 
that I mean could be face-to-face contact, could be 
a conversation, could be some sort of computer, 
computer message, a text, Twitter, e-mail, any kind 
of commuter — anything like that, could it be, it 
could be something in writing. Do you understand 
that's What I mean by communication? 
A. Yes, sir. 
Q. And so the only person since September 
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Page 346 
January 1st, 2010. 
Q. And am I correct
 told us at your 
last deposition that 
was then your 
current boyfriend? 
A. Yes. 
Q. Has that relationship changed now? 
A. Yes. 
Q. He is no longer your current boyfriend? 
A. Correct 
Q. Is the apartment that you currently live 
in, is that a rental apartment? 
A. Yes. 
Q. Is that rental apartment in your name? 
A. Yes. 
Q. Bite 
was the situation that caused 
you and 
to part company? 
A. It was mutual. 
Q. Was there any domestic violence involved? 
A. No, sir. 
O• Did you have any discussions with 
at any time about this lawsuit? 
A. Yes. 
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Q. What discussions did you have? 
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A. Well, he's saw the news and I pretty much told 
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him that Jeffrey F nCt in has been mol ting MP since I 
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r.! , 
Q. And when did you have communication with 
Page 348 
24th, 2009,. that. yo_u had any contact with that has a 
Ms. Lan cry?
suit pending against Mr. Epstein is E.? 
A. Yes, sir. 
put her microphone on? 
actually getting all of this. 
THE WITNESS: No. 
THE WITNESS: 
MR. CRITION: No, Mr 
MR. LUU1ER: 
MR. CRITTON: Oh, 
MR. LUTIIER: Yeah. 
MR. CRITTON: Okay. 
MR. LUITIER: And when did you 
VIDEOGRAPHER: I can pick her up. 
MR. EDWARD: You can pick — Okay. 
THE VIDEOGRAPHER: That's fine. 
MR. LUTT1ER: That would be a good idea. 
MR. EDWARDS: Let's make sure we're 
MR. LUTTIEFt: Start over. 
MR. EDWARD: We don't need that. 
3 
BY MR. LUTTEER: 
MR. CRITTON: What.did she say? 
MR. EDWARD: Fm sorry. Does she need to 
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A. We are awriates. We're friends. When did I 
2 
have a conversation with ha? 
3 
Q. Yes. Well, I don't want to limit it to a 
4 
conversation. When did you have communication with 
her? 
A. I have communication with her frequently but 
7 
we don't talk about the Jeffrey Epstein case. My 
8 
attorney is not her attorney. We don't choose to talk 
9 
about it. 
10 
Q. When you said you are associates, what do 
11 
you mean? 
12 
A. Well, I have my life and she has her life. 
13 
Q. Well, you said that you were associates 
14 
and then you said friends. But you used the term 
15 
associates. 
16 
A. We are friends. 
17 
Q. Do you have any kind of business 
18 
relationship with her? 
19 
A. Not at all. 
20 
Q. Did you mean the word associates to mean 
21 
something other than just merely being social 
22 
friends? 
23 
A. We are friends. 
24 
Q. Do you have any kind of relationship with 
25 
her other than simply friends? 
Page 351 
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and we can confine (sic) in each other if anything. But 
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as in confining, I mean all I have to do is look in her 
3 
eyes and'we just know the pain that we've went through. 
4 
Q. Am I going to assume correctly that the 
5 
word you mean is confide, you confide in each other? 
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You tell each other - 
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A. No, I told you, as when I confine in her, it's 
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as simple as we will go to a bar. We'll look at each 
9 
other in our eyes and we just realize the pain that 
10 
Jeffrey has caused us. 
11 
Q. Do you have any other discussions with her 
12 
or have you had any other discussions with her in 
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more detail than that? 
14 
A. I have know that she has an attorney and I 
15 
have mine. But other than that, we definitely don't 
16 
talk about the case because ifs negative. We already 
17 
know what we went through. 
18 
Q. Has she indicated to you whether she's 
19 
been in contact with other people that have pending 
20 
claims again Mr. Epstein? 
21 
A. No, sir. 
22 
Q. Has she indicated to you whether or not 
23 
she has sought any professional help? By that I 
24 
mean a mental health professional, psychologist, 
25 
psychiatrist, that thing, that type of thing? 
Page 350 
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A. We're just fiends. 
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Q. You have no common joint venture that 
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3 
you're pursuing? 
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A. No. 
4 
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Q. No business that you're pursuing? 
5 
A. No. 
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Q. Are you-all in clubs together? 
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A. We go out sometimes. 
9 
Q. By clubs I meant — I don't know what 
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10 
clubs women are in no, Junior League or 4-H, that 
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11 
type of thing. I don't mean nightclubs. Are 
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you-all in any organizations together? 
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A. No. 
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Q. Okay. Does — 
14 
15 
A. We go out to a bar once in a blue moon. 
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Q. With what degree of frequency do you have 
16 
17 
contact with her? 
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A. I call her and tell her I love her once a 
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week. 
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Q. Is that something unique to your 
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relationship with her? 
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22 
A. Yes. 
22 
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Q. And what is it about your relationship 
23 
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with her that's unique? 
24 
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A. We've been fighting the Jeffrey Epstein case 
25 
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Page 352 
A. No, sir. 
Q. There were some other — Ms..., is 
that, is that an individual that you took to 
Mr. Epstein? 
A. Yes, sir. 
Q. And on how many occasions did you take her 
to Mr. Epstein? 
A. Around four times, 
Q. And did she go alone after that? 
A. Yes, sir. 
Q. And did she tell you how many times she 
went? 
A. No, sir. 
Q. Has she indicated to you any intent to sue 
you for taking her to Mr. Epstein? 
A. No, sir. 
Q. Did the discussion ever come up? 
A. No, sir. 
Q. Do you feel responsible in some part for 
taking her to Mr. Epstein if she claims that she was 
somehow damaged as a result of going to sec him? 
A. No, sir. 
Q. And did you tell her when you first took 
her to Mr. Epstein that nothing bad was going to 
hapeen, that she wasn'tring to be asked to do 
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anything she didn't want to do? 
2 
A. Correct. 
3 
Q. Did you tell her exactly what to expect 
4 
when she went? 
5 
A. No. 
6 
Q. And did she -- after she went the first 
7 
time, did she indicate to you anything about the 
visit? 
9 
A. Yes. 
10 
Q. What did she say? 
11 
A. She told me she did not like it. 
12 
Q. That would be on the first visit? 
13 
A. Yet 
14 
Q. Did she say Mr. Epstein did anything or 
15 
forced her to do anything that she didn't want to 
16 
do? 
17 
A. Mr. Epstein always told us don't tell anybody. 
18 
He just wanted us to find girls. So, whatever 
19 
transpired between her and Mr. Jeffrey Epstein, i 
20 
don't -- I'm not sure. 
21 
MR. LUTHER: Move to strike as not being 
22 
responsive to the question. My question was, 
23 
if you will read back what my question was to 
24 
the witness. 
25 
(Tbe requested portion of the record was 
Page 355 
1 
anything at all that she didn't want to do that he 
2 
insisted that she do? 
3 
A. No. All she told me is that she was afraid of 
4 
him and she did not want to go back. 
S 
Q. And so what did you tell her after this 
first visit where you took her there and told her 
7 
that she could be as comfortable as she wanted and 
8 
she reported to you that she felt that she had to do 
9 
whatever Mr. Epstein wanted her to do? 
10 
A. Weil, I said why don't we go again and make 
11 
some money. 
12 
Q. So, it was you that encouraged her 
13 
notwithstanding whatever reservations she told you 
14 
to go back to Mr. Epstein? 
15 
A. Yes. 
16 
Q. And you told her let's do that because you 
17 
wanted to make money; is that correct? 
18 
A. Yes. 
19 
Q. And after the second visit, did Ms. • 
20 
tell you that, anything about her visit with 
21. 
Mr. Epstein? 
22 
A. She told me the same thing. She was very 
23 
quiet about it. She said I do not want to go back. 
24 
Q. And notwithstanding that comment did you 
25 
take her back a third time? 
Faye 3 
1 
read by the reporter.) 
2 
THE WITNESS: Yes. 
3 
BY MR. LUTTIER: 
4 
Q. What did she tell you? 
5 
A. She said that she felt very obligated to do 
6 
what Mr. Jeffrey Epstein had asked her to do. 
7 
Q. And what did she say Mr. Epstein asked her 
8 
to do? 
9 
A. Take off her clothes. 
10 
Q. And you had told her before she went that 
11 
that was going to be requested of her, right? 
12 
A. Brom what I remember, I told her that, that 
13 
she would be in a room and we were going to massage his 
14 
thighs. And then oncel left the room you can be as 
15 
comfortable as you want to be with him. 
16 
Q. And did she say anything other than that 
17 
occurred? 
18 
A. Excuse me? 
19 
Q. Did she say anything other than that 
20 
occurred? 
21 
A. She said she wasn't comfortable. 
22 
Q. And did she say that she told Mr. Epstein 
23 
that? 
24 
A. No, she was scared of him. 
25 
Q. She indicate that she told Mr. Epstein 
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Page 356 
A. Yes. 
Q. And what did you tell her after she told 
you she didn't want to go back? 
A. I was stubborn and I said let's go back, and 
please make some more money. 
Q. So, would it be a fair statement to say 
that you coerced her into going back? 
A. Yes. 
Q. Now, why would you coerce a friend of 
yours to go back? 
A. Well, when you're -- at that time I was 14. 
And when you're 14 and you're poor, a young lady is 
going to do anything for money especially when you're 
intimidated by a man who lives in an island that was 
highly, highly known of. And i was very intimidated by 
Jeffrey, and he always wanted me to bring girls. And he 
told me, make sure you have a girl for me. So, at that 
time, I would only, at that specific time i would only 
have 
Q. Had you been brought up with any kind of 
moral upbringing from your parents? 
A. Yes. 
Q. And had you been taught as a, as a child 
from as far back as you can remember not to do 
things that were wrong? 
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A. Yes. 
2 
Q. And you discarded your upbringing and 
3 
decided in order to make money you would tell your, 
4 
one of your good friends that notwithstanding her 
5 
reservations about going back to Mr. Epstein that 
b 
you wanted her to do that; is that correct? 
7 
A. Yes. 
8 
Q. Other than Ms. E 
telling you that she 
9 
felt that she was obligated to do what Mr. Epstein 
10 
wanted her to do, did she tell you anything about, 
11 
anything else about her conversations or 
12 
interactions with Mr. Epstein at any time? 
13 
A. She told me that if Jeffrey told her if she 
14 
was to tell anybody, she would be in trouble. 
15 
Q. Did she tell you anything else? 
16 
A. No. 
17 
Q. Now, at some point in time before you 
18 
filed this lawsuit, the FBI came to visit with you? 
19 
A. Yes. 
20 
Q. Is that correct? 
21 
A. Yes. 
22 
Q. And they took a sworn statement from you, 
23 
correct? 
24 
A. At what time? 
25 
Q. They took a sworn statement sometime 
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Page 359 
Eisenberg at the statement representing you, 
correct? 
A. Yes. 
Q. Okay. And did you tell the FBI what you 
just told me about the conversations you had with 
el ?
A. No. 
Q. In fact what you told the FBI was exactly 
the opposite, was it not? 
A. Correct. 
Q. Now, there are a number of other people 
who in the first deposition you said you had contact 
with in the past. So, I want to make sure we 
haven't missed anybody with respect to my question 
about communications with them since September 24th 
of '09. There was a lady you referred to in your 
previous deposition by the name of 
At the 
time of your prior deposition you sae you
know her last name. Do you now know her last name? 
A. No, sir. 
Q. Say what? 
A. No, sir. 
Q. Does the name Msound 
familiar to 
you? 
A. No, sir. 
Page 358 
1 
before you filed this lawsuit? 
2 
A. Yes. 
3 
Q And you were represented by a lawyer at 
4 
that sworn statement; is that right? 
5. 
MR. EDWARDS: Object, I object to the 
6 
form. And I know that it's not your intention 
7 
to rehash the entire first deposition, but I 
8 
think this area was covered. So, to the extent 
9 
that it wasn't, then obviously the inquiry can 
10 
proceed, but we're not going to rehash the 
11 
entire event as it happened in the first 
12 
deposition. 
13 
MR. LUTHER: I have no intention to. 
14 
BY MR. LUTHER: 
15 
Q. You were represented by a lawyer at that 
16 
time, correct? 
17 
A. On Jeffreys behalf? 
18 
Q. No, on your behalf. There was a lawyer 
19 
there who represented to the FBI that he was your 
20 
lawyer, is that right? 
21. 
MR. EDWARDS: Object to the form. 
22 
THE WITNESS: I am not understanding this, 
23 
sir. • 
24 
BY MR. LIMITER: 
25 
Q. There was a fellow by the name of James 
Page 360 
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Q Have you had any communications with this 
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lady 
since your September 24th, '09, 
3 
deposition 
4 
A. No, sir. 
5 
Q Have you had any communications with a 
6 
lady by the name of Jane Doe II since your September 
7 
24th, '09, deposition? 
8 
A. No, sir. 
9 
Q. Have you had any communications with a 
10 
lady by the name of Jane Doe since your September 
11 
24th, 2009, deposition? 
12 
A. No, sir. 
13 
Q. On your last deposition, you indicated to 
14 
us that at some point in tune Ms. Jane Doe,' 
15 
believe, had watched your son for you on some 
16 
occasion? 
17 
A. Yes. About two occasions. 
18 
Q. Okay. Other than those two occasions that 
19 
you've described in the previous deposition, has 
20 
Ms. Jane Doe ever watched your son since then or on 
21 
any other occasion? 
22 
A. No, sir. 
23 
Q Since your September 24th, '09, deposition 
24 
have you ever had anybody else watch your son or has 
25 
he always been with you since then? 
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1 
A. I have a,1 have a babysitter. 
2 
Q. And who is your babysitter? 
3 
A. 
6 
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zs 
Page 361 
A. I'm not really sure how to spell --
Q. Where —
A. — her 
Q. WherenaZ4IMI 
reside? 
A. She resides in the, in the acreage. I'm not 
positive what the address is. 
Q. With what degree of frequency since 
September 24th, '09, have you utilized her services 
to watch your son? 
A. Very frequently. Ever since December, I mean 
January 1st, 2010, she watches my son regularly. 
Q. Is there like certain days of the week she 
automatically watches him? 
A. No. 
Q. And, and why -- is the frequency with 
which she watches your son since January of 2010 
greater than the frequency with which you had people 
1 
2 
3 
4 
5 
6 
7 
8.
9 
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Page 363 
A. Yes, or at night as well. 
Q. Whose shows do you sell? What line of 
shoes? 
. . 
A. I sell BCBG, Jessica Simpson. Coach. I can 
pretty much get any shoe. 
Q. And where do you get the shoes? 
A. Igo to Macy's. Igo to the clearance rack. 
I buy them for really cheap, and 1 sell them for what 
they are originally. 
Q. So, you would go into a Macy's, if there 
was a clearance and buy a half a dozen pairs of 
shoes? 
A. Yes. 
• 
Q. Without knowing what anybody's size was? 
A. Correct. 
Q. In other words you don't get somebody's 
order first and go fill the order? 
A. I could do that but I really don't — I would 
rather go there and buy a bulk of shoes with whatever 
size. And if someone is interested in a nail salon, you 
know, and if ifs their size, then they'll buy it 
Q. When did you first start selling these 
shoes? 
A. January I st, 2010. 
Q. And did somebody introduce you to this 
Page 362 
1 
watch your son prior to that date? 
2 
A. Excuse me? Can you —
3 
Q. Why is she watching your son frequently 
4 
since January 10? 
5 
A. So I can work. 
6 
Q. Okay. Where are you working? 
7 
A. I sell Mary Kay, shoes, lingerie, and clothes. 
8 
Q. Mary Kay shoes?
9 
A. Lingerie and clothes. 
10 
Q. Lingerie and what else? 
11 
A. And clothes. 
12 
Q. Is that, is that all of that Mary ICay 
13 
items; that is Mary Kay has a line of shoes, or are 
14 
you saying — 
15 
A. No. 
16 
Q. — that you sell Mary Kay cosmetics, plus 
17 
you sell shoes, plus you sell lingerie, plus you 
• 
18 
sell clothes? 
19 
A. Yes. 
20 
Q. All right And do you — what hours do 
23. 
you work? 
22 
A. Well, 1 just, it's on my own hours. I will go 
23' 
to tanning salons to see if anybody wants to buy. I 
24 
will go to nail salons. 
25 
Q. Is this all during the day? 
Page 364 
1 
business? 
2 
A. No. 
3 
Q. This is something you came up with on your 
4 
own? 
5 
A. Yes. 
6 
• Q. Okay. Who do you sell lingerie for? 
7 
A. I go to different areas. I go to, I will go 
8 
to strip clubs and sell lingerie if they want it. My 
9' 
girlfriends. I sell lingerie to. Valentine's is coming 
10 
up. I will be selling a lot of lingerie soon. 
11. 
Q. Who do you get the lingerie from? 
12 
A. Igo to local adult stores and I go to the 
13 
clearance and I buy them in bulk, and then I sell them 
14 
for the original or more price. 
15 
Q So and when do you go to these strip 
16 
clubs, during the day or at night? 
17 
A. Both. 
18 
Q. And what do you do at these strip clubs? 
19 
MR. EDWARDS: Object to the form You tan 
20 
EMSWer. 
21 
THE WITNESS: Yeah, I walk In with my 
22 
duffel bag MI oldie items I like to sell, 
23 
and the women get to choose what they wait to 
.24. 
buy 
25. 
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Page 365 
1 
BY MR.. LUITIER: 
2 
Q. Do you dance at any of these strip clubs? 
3 
A. No, sir. 
4 
' Q. Have you danced anywhere since September 
5 
24th, 2009? 
6 
A. No, sir. 
7 
Q. Have you worked in any adult establishment 
8 
of any kind or nature since September 24th, 2009? 
9 
A. Not in a strip joint, no. 
10 
Q. Okay. Well, have you worked in any other 
11 
kind of adult establishment other than a strip joint 
12 
since September 24th, '09? 
13 
A. Yes. 
14 
Q. Where have you worked? 
15 
A. I have worked for my private clientele. 
1.6 
Q. What do you mean by "private clientele"? 
17 
A. I have worked, I have been company to a few 
18 
men that I have met ever since the last deposition, and 
19 
I provide company for than. 
20 
Q. The last time you told us you had worked 
21 
for an escort service. Do you recall that? 
22 
A. Correct 
23 
Q. Is this in essence the same thing you're 
24 
still doing? 
25 
A. No. 
1 
2 
3 
4 
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13 
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Page 367 
Q. So, what you are telling the ladies and 
gentlemen of the jury is somebody pays you three to 
$500 an hour just to be in your company and not to 
have any sex with you? 
MR.. EDWARDS: Object to the fonn. 
BY MR. LUTTIER: 
Q. Is that right? 
MR. EDWARDS: And just so that the record 
Is clear, the wage claim, the loss wages and 
loss of earning capacity has been withdrawn in 
the case. 
You can answer the question, if you 
understand the question. 
BY MR. LUTTIER: 
Q. Is that right. 
A. What was the question? 
Q. So you're telling the ladies and gentlemen 
of the jury that men pay you three to $500 an hour 
just for your company but you have no sex with them; 
is that correct? 
MR. EDWARDS: Object to the form. 
111E WITNESS: Correct. 
BY MR. LUTHER: 
Q. Or is sex an additional charge? 
A. No, I don't have sex with them. 
Page 366 
1 
Q. Are you working for an escort service now? 
2 
A. No. 
3 
Q. Have you been working for an escort 
4 
service since September 24th, 2009? 
5 
A. No, sir. 
6 
Q. Do you advertise your services somehow? 
7 
A. No, sir. 
8 
Q. So, how do you — how do these people know 
9 
to retain your services? 
10 
A. Word of mouth. 
1 
Q Okay. And how do they get word of mouth? 
12 
A. I have one client, Bobby, and he has referred 
13 
me to three other clients. 
14 
Q. And what's the difference between what you 
15 
are doling with these clients and what you did with 
16 
the escort service? 
17 
A. Well, the difference is is that I don't 
18 
perform any sexual acts. It's pretty much just I am 
19 
company if — they pay me for my company. 
20 
Q. Well, how much do they pay you for your 
21 
company? 
22 
A. It ranges anyway, any any price is from 300 
23 
to 500. 
24 
g 
300 to 500 what? 
25 
A. An hour. 
Page 368 
1 
Q. Have you ever — or when did you start 
2 
this little escort service that you're describing 
3 
now? 
4 
A. Well, I don't know what your definition of 
5 
escort is. It's pretty much I offer my company to got 
6 
paid. January 5th, 2010. 
7 1 
Q. And how did you fix on the date 
8 
January 5th? 
9 
A. I had met a gentleman named Bobby in CityPlace 
10 
and we sat down for a drink and we just started talking. 
11 
Q. Had you gone there to meet him? 
12 
A. No, I just went there by myself. And I 
13 
just — 
14 
Q. Did you meet him in an establishment at 
15 
CityPlaoe? 
16 
A. I met him at Carousel. 
17 
Q. Okay. That's a restaurant and a bar 
18 
there? 
19 
A. It's a restaurant, correct. 
20 
Q. Okay. Is that Can Can --
21 
A. Can Can Carousel (sic). 
22 
Q. Motive or motif? 
23 
A. Can Can Carousel. 
24 
Q. Right The waitresses are in cancan 
25 
outfits and dance on the tables or something like 
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that? 
2 
A. Yes. 
3 
Q. And were, were you there -- why were you 
4 
there? 
5 
A. I was just — Igo out by myself sometimes 
6 
just to recuperate and have a nice drink and a nice 
7 
dinner by myself. I am single. 
8 
Q. So, were you there for dinner or were you 
9 
there for something else? 
10 
A. I was there fora drink. 
11 
Q. So you went to the bar? 
12 
A. Yes. 
13 
Q. And this fellow happened to be at the bar? 
14 
A. Yes. 
15 
Q. And it wasn't, it wasn't prearranged. He 
16 
just happened to be at the bar? 
17 
A. Correct 
18 
Q. Okay. And then how did it evolve from you 
19 
sitting next to this person who you had no contact 
20 
with prior to that, right? 
21 
A. Correct. 
22 
Q. To suddenly he was lining up escorts for 
23 
you, or lining up people for you to escort? 
24 
A. He did not line up escorts for me at that --
25 
or, I don't know what your definition of escort is. But 
Page 371 
1 
males approximately your age would ask you out to a 
2 
movie or something like that on a date. Has that 
3 
happened to you? 
4 
A. Yes. With these men, yes. 
5 
Q. So, what these people -- you consider 
6 
these people dates; is that what you're telling me? 
7 
A. Yes, we go out to the movies. We go out to 
8 
eat dinner. 
9 
Q. How many dates did you have as a youth 
10 
where people paid you three to 5500 an hour —
11 
A. Sir--
12 
Q 
just to have the opporttmity to date 
13 
you? 
14 
A. Ever since Jeffrey Epstein --
15 
MIL EDWARDS: Object to the form. 
16 
THE WITNESS: -- I have never hung out 
17 
with anyone my age. He has taught me that 
18 
older men have money, and that's all I know. 
19 
BY MR. LUTTIER: 
20 
Q. Is that, is that something that you had to 
21 
be taught that is this was some particularly unique 
22 
thing that you learned from Mr. Epstein, older men 
23 
have money? 
24 
A. Yes. 
25 
Q. And do you believe that statement Is true, 
Page 370 
1 
he didn't line anybody up at that specific time. We, I 
2 
just — I was just at the bar and he just so happened to 
3 
be at the bar as well, and we started talking. I was 
4 
alone. He was alone. He is an older man He told me 
5 
he was married, and he said that he would love to enjoy 
6 
my company. 
7 
Q. And what did you say? 
8 
A. I said sure. 
9 
Q. Is it, is it now your practice to go out 
10 
with older married men without their wives so they 
11 
can enjoy your company? 
12 
A. Sure. 
13 
Q. And what do you think those older married 
14 
men have in mind? 
15 
A. I don't know what they have in mind but with 
16 
the four customers I do have, I know what they have in 
17 
mind. 
18 
Q. These clearly aren't dates, right? These 
19 
are not —
20 
A. They — 
21 
MR. EDWARDS: Object to the form. 
22 
• BY MR. LUTFIER: 
23 
Q. When I say a date, I assume that there 
24 
have been times in your life, and maybe I am wrong 
25 
and cornett me ifl an wrong, where a male, young 
Page 372 
1 
older men have money? 
2 
A. As of right now, yes. 
3 
Q. No such thing as older men without money, 
4 
right? 
5 
MR EDWARDS: Form. 
6 
THE WITNESS: White collar men have money. 
7 
BY MR. LUITIER: 
8 
Q. White collar. You mean the color of the 
9 
shirt they wear? What you did mean by white collar? 
10 
A. Successful men. 
11 
Q. You mean you've figured out how to look at 
12 
an older man and determine whether or not he is 
13 
likely to have money? 
14 
A. Yes, Jeffrey has definitely showed me the 
15 
ambiance and the, the way a man should look to where 
16 
they have money. 
17 
Q. Well, how did he teach you that? 
18 
A. Well, I was with hlm since I was 13, 14, 15, 
19 
16, going onto 17, and I pretty much have an eye for 
20 
that 
21 
Q. What do you mean when you say you were 
22 
with him for that period of time? 
23 
A. I was with Jeffrey —
24 
Q. But I mean - 
25 
A. -- seeing Jeffrey. 
I 
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Page 375 
1 
Q. — did you and he go out to dinner? 
1 
A. Well, I sat down and I talked to him and we 
2 
A. No. 
2 
had a nice conversation. And he pretty much told me 
3 
Q. Didn't — maybe I misunderstood something 
3 
that he has a wife, but he would lilts to take me out to 
4 
from your last deposition, but didn't you simply go 
4 
dinner as much as, you know, as much as possible. 
5 
to Mr. Epstein's house -- 
5 
Q. Well, did you ask him — did that seem 
6 
A. Correct. 
6 
unusual or strange to you? 
7 
Q. 
to perform massages? 
7 
A. At this time in my life, no. 
8 
A. Correct That's in the past 
B 
Q. Because you had worked as an escort in an 
9 
Q. So, he wasn't taking you out in public to 
9 
escort service for a substantial period of time in 
10 
movies or dinners or shows or things like that 
10 
the past, right? 
11 
correct? 
11 
A. Correct 
12 
A. No, but he has sent me out with a couple of 
12 
MR. EDWARDS: Object to form. 
13 
girls to buy a movie, he's rode me around in his car. 
13 
BY MR. LUTHER: 
14 
Q. So, how did he show you how to identify an 
14 
Q. And you knew what married men that wanted 
15 
older man that you believe has money? 
15 
to go out with young women really meant, correct? 
16 
A. Well, as a younger girl when I am 13, and 14, 
16 
MR. EDWARDS: Form. 
17 
and 15 years old, and I am going to a mansion once or 
17 
THE WITNESS: Correct. 
18 
twice a day, and I see that environment, subconsciously 
18 
BY MR. LUTHER: 
19 
you, you, you learn that 
19 
Q. And you knew that's exactly what Bobby had 
20 
Q. So, what you have done is you believe you 
20 
in mind, right? 
21 
have acquired a skill and that skill is how to look 
21 
A. No, be told me he did not want to have sexual 
22 
and figure out whether or not older men have money, 
22 
intercourse. He just wanted company. He's an old man 
23 
correct? 
23 
that has an old wife and he just simply wants a young 
24 
A. Jeffrey taught me that — 
24 
woman to have company with. 
25 
Q. That wasn't my question. 
25 
Q. And you think it's perfectly acceptable to 
Page 374 
Page 376 
1 
A. — lifestyle. 
1 
charge him — what do you charge him, by the way, 
2 
MR. LUTTIER: Move to strike, not 
2 
300 or 500 an hour? 
3 
responsive. Would you read my question back to 
3 
MR. EDWARDS: Object to the form. 
4 
her? 
4 
THE WITNESS: Whatever he wants to give 
5 
MR. EDWARDS: Object to the form. And the 
5 
me. 
6 
answer was responsive to the question. 
6 
BY MR. LUTHER: 
7 
THE WITNESS: I believe it was. 
7 
Q. Well, what's your — what do you tell him 
. 
8 
MR. LUTHER: Go ahead and read back my 
8 
the charge Is? 
9 
question. 
9 
A. I don't tell him anything. Whatever he wants 
10 
(The requested portion of the record was 
10 
to give me. 300 most of the time. 
11 
read by the reporter.) 
11 
Q. How many times have you gone out with him? 
12 
MIL LUITIER: Now, would you answer — 
12 
A. Around five times now. 
13 
THE WITNESS: Correct 
13 
Q. Okay. Tell us where you have gone. 
14 
MR. LUTHER: Okay. 
14 
A. We've went to several, actually we went to 
15 
BY Mft. LUTTIER: 
15 
several hotels. 
16 
Q. Now, how did you know when you were 
16 
Q. What do you mean several hotels? 
17 
sitting there — strike that. Was this individual 
17 
A. We've been to La Quinta. 
18 
who I believe you said his name was Bobby that you 
18 
Q. What is there at La Quints? 
19 
met at the Carousel bar, was he one of those 
19 
A. A hotel room. 
20 
individuals that you identified as an older man with 
20 
Q. Is there a bar them or something? 
21 
money? 
21 
A. No, it's just a room. 
22 
A. Correct. 
22 
Q. You went to a hotel room with him? 
23 
Q. And how were you able to determine sitting 
23 
A. Correct, because he has wife and I can't go to 
24 
at a bar meeting this stranger for the first time 
24 
his house to have company with hint 
25 
that he was an older man with money? 
25 
Q. So, what exactly did you and Bobby do at 
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the La Quinta? 
2 
A. 'just gave him company. 
3 
Q. Okay. Well, how do you, to use your 
4 
phrase, give him company? 
5 
A. Like I am giving you company right now, l talk 
6 
to him. He confines in me and we have conversations. 
7 
Q. And where do you do this, in his hotel 
8 
. room? 
9 
A. Yes. 
10 
Q. And why wouldn't you just do that out in 
11 
public if that's all you were doing? 
12 
A. We have done that out in public. 
13 
Q. Well, why would 
I don% understand why 
14 
Bobby took you to the La Quinta and took you into a 
15 
hotel room if all you were — 
16 
A. How can you not understand that? 
17 
Q. — if all you were going to do is share 
18 
company? Had you suggested to him that you should 
19 
get a motel room? 
20 
A. No. 
21 
Q. Was that his idea? 
22 
A. Yes. 
23 
Q. Did he tell you why he thought you should 
24 
get a motel room? 
25 
A. So, we can have silence instead of always 
Page 379 
1 
happened. 
2 
MR. EDWARDS: Form 
3 
BY MR. LUITIER: 
4 
'Q. What is Bobby — 
5 
A. That is what happened. 
6 
Q. What is Bobby's last name? 
7 
A. Oh, l have no idea. 
8 
Q. When you, weren't you at all concerned 
9 
about going out with a stranger? Didn't you want to 
10 
know at least what his name was? 
11 
A. I bow his name is Bobby. 
12 
Q. Is that all thought you needed to know? 
13 
A. That's all I felt I needed to know. 
14 
Q. Where does he live? 
15 
A. I don't know. I don't care where he lives and 
16 
I don't want him to know where I live. He has a wife. 
17 
Q. How, how did, how did you and he meet at 
18 
the La Quinta? Did he come pick you up someplace? 
19 
Did you pick him up? 
20 
A. No, we just drove there. 
21 
Q. Is, was this a prearranged place to meet? 
22 
A. Yes. 
23 
Q. All right. And how did that 
24 
prearrangement occur? 
25 
A. Well, I gave him my number and he calls me. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
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Page 378 
being at a restaurant. 
Q. How were you dressed on that occasion? 
A. Just like this. 
Q. Did you at any time in the hotel room 
undress? 
A. No. 
Q. Partially or completely? 
A. No. 
Q. Did you ever place your hands on Bobby — 
A. No. 
Q. ' — while you were in the motel room? 
A. No. 
Q. Did he ever place his hands on you? 
A. No. 
Q. Any kissing? 
A. No. 
Q. So, Bobby here pays you $500 or $300 to go 
17 
to a La Quints and literally sit across the room 
18 
from him; is that right? 
19 
A. Yes. 
20 
MR. EDWARDS: Form. 
21 
THE WITNESS: Some people have money like 
22 
that. 
23 
BY MR. LUITIER: 
24 
Q. At least that's what you're saying 
25 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
Page 383 
Q. And he says — 
A. I do not have his number. 
Q. And what did he say? 
A. Hi, would you like to meet at the La Quinta. 
Q. And you say sure? 
A. Yes. 
Q. And do you do that during the day, do you 
do that during the day or at night? 
A. At night — or during the day, sorry. 
Q. Well, which was it? 
A. Day. 
Q. And what La Quinta was this? 
A. On Okeechobee. 
Q. Out by the Turnpike? 
A. Correct. 
Q. And who selected the hotel? 
• A. Bobby. 
Q. And what's Bobby do? 
A. I have no idea. 
Q. Did you ever ask him? 
A. No. 
Q. Did you ever ask him anything about him. 
A. He talks about his wife. No, we just have 
nice conversations. 
. As far as you're concerned this is 'ust 
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2 
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Page 381 
strictly a business deal, right? 
A. Yeah, and a friendship as well. 
Q. Where else have you gone with Bobby? 
A. Out to eat. 
Q And you said you went about five times. 
So if once to the La Quinta, and the other four 
times were out to eat? 
• A. No, we went to the La Quinta again. 
Q. Same La Quinta? 
A Yes. 
Q. Same room? 
A. No. 
Q. Okay. So La Quinta times two? 
A. Okay. 
Q. And where did you go to eat? 
A. To the Carousel again. 
Q. Anyplace else? 
A. We went to — and then the fifth one is New 
York. 
Q.' And when did you go to New York? 
A. February 2nd through the 4th. 
Q. Of 2007? 
A. Correct. 
Q. Tell me how that occurred. Bobby just 
calls you up and says — well, go ahead and tell me 
Page 383 
1 
A. Oh, I don't know the address. I know it's 
2 
near Grand Central Station. 
3 
Q. So, so, all Bobby said was I'm going to 
4 
New York, and, and do you want to go book a flight? 
5 
A. Yes. 
6 
Q. Did he say that you were going to do 
7 
anything when you got to New York or did he just say 
8 
go take a trip to New York? 
9 
A. He said take a trip to New York. And he said 
10 
I will meet you at Anna's. You know, I will meet you at 
11 
Anna's one time and Mars it. 
12 
Q. Did you know this Anna before you went? 
13 
A. No. 
14 
Q. Had you — 
15 
A. I just thought it was a nice opportunity to go 
16 
to New York. 
17 
Q. So, what are you 22 now? 
18 
A. Twenty-one. 
19 
Q. Twenty-one. So, and how long had you 
20 
known Bobby at that point in time? 
23. 
A. Oh, since January, January 5th, 2010. 
22 
Q. So, you had known him for less than a 
23 
month? 
24 
A. Yes. 
25 
Q You met him kt a bar? 
Page 382 
1 
what occurred. 
2 
A. Bobby calls me. He says, well, you can, I'm 
3 
going to New York with my wife and I said okay. He says 
4 
you should come sanetime. I said all right. He said if 
5 
you would like to, you can, you can book yourself a 
6 
flight. So, I had booked myself a flight to New York. 
7 
Q. Well, this is like — this was last 
8 
Tuesday? 
9 
A. Yes. 
10 
Q. I mean, does he tell you — well, you were 
11 
just flying into New York. New York City is a big 
12 
city, a big state. Does he tell you where you're 
13 
going or anything? 
14 
A. Yes. 
15 
Q. Where were you going? 
16 
A. He has a friend Anna that owns a condo, and I 
17 
stayed with her for two days. 
18 
Q. I'm going to guess that Anna is not his 
19 
wife. 
20 
A. No. 
21 
Q. Who's Anna? What age is she, your age? 
22 
A. No, she's an older woman. 
23 
Q. What do you mean by older? 
24 
A. She's probably in her 40s. 
25 
Q. Does anybody else — where was this condo? 
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Page 384 
A. Uh-huh. 
Q. You knew — didn't know his last name? 
A. No. 
Q. You know nothing about what he does? 
A. No. 
Q. Don't know if he's got a criminal 
background? 
A. No. 
Q. Literally you know nothing about him? 
A. Correct. 
Q. Other than you believe he has a lot of 
money? 
A. Correct 
Q. He says go to New York and stay with a 
friend of mine named Anna? 
A. Correct. 
Q. You don't know who Anna is? 
A. No. 
Q. Never met her? 
A. No. 
Q. Don't know how old she is? 
A. No. 
Q. Don't know what she does for a living? 
A. No. 
• 
Q Don't know if she has a criminal 
13 (Pages 381 to 384) 
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background? 
2 
A. Correct. 
3 
Q. You buy yourself a ticket, pay for a 
4 
ticket? 
5 
A. Yes. 
6 
Q. You get on a plane and you fly to New 
7 
York? 
8 
A. Correct. 
9 
Q. You go to La Guardia? La Guardia Airport, 
10 
is that where you want in? 
11 
A. J.F.K. 
12 
Q. You go into J.F.K. You get in a cab? 
13 
A. Correct. 
14 
Q. You give them the address of wherever Anna 
15 
is or did somebody come pick you up from the 
16 
airport? 
17 
A. No, Thad, I had an address on a piece of 
18 
paper, and I gave him, the taxi --
19 
Q. The cab driver? 
20 
A. — driver, yeah. 
21 
Q. So, you go to this Anna place, this Anna 
22 
lady's, woman's residence? 
23 
A. Yes, her condo. 
24 
Q. And you have never seen her? 
25 
A. No. 
Page 387 
1 
A. I told Bobby I would rather have a girl go 
2 
with me because I don't want to go by myself. I would 
3 
Lilco to enjoy New York with a friend of mine. 
4 
Q. Well, why were you afraid to go alone? 
5 
A. I wasn't afraid to go alone. I just would 
6 
rather go with a friend instead of myself. 
7 
Q. I just want to make sure I understand 
8 
this. You had no fear or trepidation about going on 
9 
this trip? 
10 
A. Of muse I did a little bit, but it was an 
11 
opportunity for me to go to New York and I took it. 
12 
Q. Okay. What happens when you get to New 
13 
York, and you ring the doorbell at this lady's, 
14 
Anna's condominium or apartment or whatever she 
15 
lived. 
16 
A. I introduce myself. 
introduces herself 
17 
to Anna and it was nice. 
18 
Q. What does Anna say toyou? Does she 
19 
say — 
20 
A. HIi, welcome, come in. 
21 
Q. And does she say, ever tell you what her 
22 
relationship to Bobby is? 
23 
A. No. She said Bobby's a friend. 
24 
Q. And so do you stay at this condominium? 
25 
A. Yes. 
Page 386 
1 
Q. All right. And what do you do? Do you 
2 
get to her condominium and just go ring the 
3 
doorbell? 
4 
A. Yes. 
5 
Q. Did anybody else go with you on this trip? 
6 
A. Yes. 
7 
Q. Who else went 
th you? 
8 
A. My girlfriend,M. 
9 
Q. I thought I asked you earlier whether you 
10 
had any communications with anyone since September 
11 
24th who's flied a claims against Mr. Epstein. You 
12 
said, no, other than 
• 
13 
A. Oh, well, 
•, that's, this is her attorney 
14 
as well. 
15 
Q. But she's got a claim going against 
16 
Mr. Epstein with — 
17 
A. Fm sony. I didn't think about that 
18 
Q. — the same lawyer you have. 
19 
A. I thought you mgelsomeone. 
20 
Q. Okay. Now, so
. is going on this trip? 
21 
A. Yes. 
22 
Q. Does... know old Bobby? 
23 
A. No. 
24 
. Q. Did Bobby tell you to bring
. along 
25 
too? 
Page 388 
1 
Q. And, and who-all is staying in this 
2 
condominit 
3 
A. JustM., I, and Anna. 
4 
Q. Does there — what time do you get to New 
5 
York? 
6 
A. Well, we missed our flight, so we — I am 
7 
pretty sure we got there around 4. I'm guessing. 
8 
Q. Ballpark. Does there come a time that 
9 
Bobby hooks up with you someplace? 
10 
MR. EDWARDS: Object to the form. 
11 
THE WITNESS: He went to Anna's house on 
12 
Wednesday. 
13 
BY MR. LUTFIER: 
14 
Q. Is Anna's house the same as the 
15 
condominium yodre staying in? 
16 
A. Yes. 
17 
Q. Okay. So he comes to where you're 
18 
staying? 
19 
A. Yes. 
20 
Q. But he doesn't come on Tuesday, the day 
21 
you come up. He comes on. Wednesday? 
22 
A. Correct. 
23 
Q. So, what do you all do on Tuesday after 
24 
you get there? 
25 
A. We just han out havi 
a good time — 
(561) 832-7500 
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Page 389 
Q. Sit around in a condominium? 
A. — drinking champagne. Yeah. 
Q. Did you go out --
A. I'm in New York 
Q. — and see — do you go out and see the 
city Of just —
A. YetALI went out to the see the city. I 
walked. 
and I walked around by ourselves. We ate 
hot dogs, dressed in New York clothes, and we just went 
sightseeing. 
Q. You said you were drinking champagne? 
A. We had a couple of glasses of champagne on 
Wednesday with Bobby. 
Q. That's Wednesday. Okay. Well, I am going 
to get to Wednesday. Let's stay on Tuesday. 
Tuesday is the day you fly up there. Champagne on 
Tuesday? 
A. Yeah, we were tired. No, not —
Q. Any drinking going on any time on Tuesday? 
A. Na that I recall. I was very tired. So — 
Q. Okay. And —
A. Tuesday, Tuesday night S 
and I did go out 
to a restaurant, Angelo's. So, yes, I did have a 
Merlot. 
Q. Did Bobby go? 
Page 391 
1 
Q. Did you, did you go out shopping with this 
2 
fellow? Did he go buy you stuff while you were in 
3 
New York? 
4 
A. With Bobby? 
5 
Q. Bobby, yeah-
6 
A. No. 
7 
Q. He pay — did he gigisup your dinner tab? 
8 
A. No. !writ to - IM and I had took a taxi 
9 
to Angelo's. 
10 
Q. Right. 
11 
A. We heard that was a good restaurant. And 
12 
actually we, we met up with a guy there that I have no 
13 
idea who he is but he was by himself and he offered to 
14 
buy us dinner. 
15 
Q. And what was his name? 
16 
A. I don't even 
ber. 
17 
Q. So, you and ago to New York You go 
18 
to a restaurant. You meet a person who would be, 
19 
who was an absolute stranger to you and —
20 
A. Yes, we're in New York having a good time. 
21 
Q. And he says, why don't you girls have 
22 
dinner with me and you say fine? 
23 
A. Yes. He was alone and obviously saw two hot 
24 
girls and offered for, to pay a tab for dinner, yeah. 
25 
Q. Okay. What do you mean by hot girls? 
Page 390 
1 
A. No. 
2 
Q. Okay. So where is Angeles in 
3 
relationship to where you're staying? 
4 
A. I don't know NOW York, sir, sir. 
5 
Q. Did you walk there or did you have to get 
6 
a cab? 
7 
A. We, we got a cab. 
8 
Q. All right. So, you go to, you go out to 
9 
dinner. By the way, who is paying for all of this? 
10 
A. What do you mean? 
11 
Q. Who paid for the trio Who paid for the 
12 
flight ticket to begigavith? 
13 
A. I paid for III% flier and Bobby had paid 
14 
for my 
15 
Q. Did you go first class? 
16 
AL NO. 
17 
Q. So, how much did you pay for 
18 
flight? 
19 
A. 478. 
20 
Q. And you just took her along just because 
21 
she was a friend of yours? 
22 
A. Yes, she's a very good friend of mine. 
23 
Q. And then when you got up there, I assume 
24 
you didn't pay anything to stay at kolta's place? 
25 
A. No. 
(561) 832-7500 
Page 392 
1 
A. Two good looking girls —
2 
MR. EDWARDS: Form. 
3 
THE WITNESS: — walking in Angelo's, 
4 
definitely not from New York. We weren't 
5 
wearing all black. 
6 
BY MR. LUTHER: 
7 
Q. What did you do after dinner? 
A. We went right back to the hotel. 
9 
Q. Did this fellow take you? 
10 
A. No, we took a taro. 
11. 
Q. And when you say hotel you mean the condo? 
12 
A. Yes. 
13 
Q. Okay. And then the next day do you hook 
14 
up with Bobby? 
15 
A. Wednesday, yes. 
16 
Q. And what do you do when you — when does 
17 
he hook up with you? 
18 
A. He came over in the mid day, maybe around 
19 
1:00, and we had a couple of glasses of champagne and — 
20 
Q. With Anna? 
21 
A. No, not with Anna. 
22 
Q. Was she gone from the condo? 
23 
A. No, she was there. 
24 
Q. Okay. But you guys didn't have champagne 
25 
in the condo? 
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A. Yes, we drank champagne in the condo. 
2 
Q. Bobby nd you — 
• 3 
A. 
4 
Q. — an 
. But Anna, She was there but 
5 
didn't have champagne, or she wasn't there? 
6 
A. I, I don't believe she had champagne. She was 
7 
there, yes. 
8 
Q. Okay. All right. All right. So you guys 
9 
have some champagne and what happens next? 
10 
A. We had a conversation. We just hung out, had 
11 
a good time, watched TV. 
12 
Q. Did you ever go anywhere? 
13 
A. No. 
14 
Q. So, Bobby comes to this condo, stays 
15 
there. You guys are there and then at some point he 
16. 
leaves? 
17 
A. Yes. 
18 
Q. When does he leave? 
19 
A. Couple of hours later. 
20 
Q. What do you-all do the rest of the day? 
21 
A. We just hung out. 
22 
Q. What does that mean? 
23 
A. We hung out in the condo. 
24 
Q. Did you ever go out that day? 
25 
A. That day, yes. We walked down the same street 
Page 395 
1 
take you out to dinner? 
2 
A. Yeah. 
3 
Q. And so you go with him? 
4 
A. Yes. 
5 
Q. Again you don't know anything about the 
6 
PO 
7 
A. No. 
8 
Q. And how old is this fellow? 
9 
A. I don't know. 
10 
Q. Older than you? 
11 
A. Yes. 
12 
Q Okay. Did he look lie he had money? 
13 
A. I didn't care if he had money or not. i just 
14 
wanted to see the town. 
15 
Q. Okay. Just an opportunity? 
16 
A. Exactly. 
17 
Q. So, you and
. go with this fellow to, 
18 
out to dinner? 
19 
A. Yes. 
20 
Q. And he picks up the tab? 
21 
A. Yes. 
22 
Q. And where do you guys go then? 
23 
A. He actually took us to see the Statue of 
24 
Liberty. We did not go on the boat. We just actually 
25 
saw it from — 
1 
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Page 394 
that we walked down -- I think it's Grand Central 
Station. I'm not sure because I'm not from there, but 
we went sightseeing. 
Q. Okay. 
A. A little sightseeing, nothing special. 
Q. Did you have a meal out again? 
A. No. On Wednesday, on Wednesday, yes, at 
night. Yes, on Wednesday night. 
Q. Where did you go and with whom? 
A. We went with -- oh, my goodness. i can't 
remember his name but someone from New York and he took 
us to Saigon Grill. 
Q. Well, who was this individual? 
A. We didn't know him either. 
Q. Where did you meet him? 
A. II. and I were just looking for opportunities 
to go and look around town. 
Q. Did you meet him in a bar earlier in the 
day or was it somebody that Bobby knew --
A. No, on the street. 
Q. -- or setup? You met this guy on the 
street? 
A. Yeah, we were walking. 
Q. Two hot girls walking down the street in 
New York You ran into this guy and he offers to 
(561) 832-7500 
PROSE COURT 
1 
Q. Did you ever during this time that he was 
2 
buying you dinner and taking you to the Statue of 
3 
Liberty manage to get his name? 
4 
A. I did know his name but I don't remember it. 
5 
Q. Get a phone number from him and call him? 
6 
A. No, I gave him my phone number. 
7 
Q. Okay. When you pass out your phone 
8 
number, do you have like a card that you give 
9 
people? 
10 
A. No. 
11 
Q. You just scribble it on an envelope or 
12 
napkin or something? 
13 
A. Or they put it in their phone. 
14 
Q. Have you ever had business cards? 
15 
A. I have in '07, '08, but it wasn't for any 
16 
escort or any personal company like that. It was 
17 
actually for, to sell shoes and purses. 
18 
Q. To sell shoes and purses for who? 
19 
A. For myself. 
20 
Q I thought you said you just started the 
21 
shoe business in January of 2010. 
22 
A. I didn't say I just started it. i've 
23 
always — I do it once in a while just to make extra 
24 
money. 
25 
Q. Is it — did you do it with a business 
Page 396 i
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Page 397 
name or —
A. No, I just wrote III on the card and then my 
number and then I said if you're ever interested in any 
shoes or purses, give me a call. 
Q. Has there ever been any type of — I'm 
going to call it a business cant You know what a 
business card is? 
A. Yes. 
Q. Has there ever been any type of business 
card that contained a number which is a number at 
which you could be reached with either your name on 
it, your real name, or any other name that you used 
for any purpose whatsoever? Does any such card 
exist in the world? 
A. Yes. There was a card that said al and then 
my old number. 
Q. Okay. And is that the only thing that was 
on that card? 
A. The only thing with two kissy marks. 
Q. Now I want to make sure you understand my 
question. Other than that card is there any other 
business card that's ever existed from the beginning 
of the world until now that had your phone number on 
it —
A. Uh-huh. 
Page 399 
1 
Q. And you say three years ago. Are you --
2 
does that mean it was in the year 2007? 
3 
A. Yeah, beginning of '07. 
4 
Q. .For what period of time did you dispense 
5 
those cards, give them out? 
6 
A. I didn't really dispense a lot of them at all. 
7 
1, maybe like for a five month period. I didn't really 
8 
dispense them at all. 
9 
Q. And who did you give them to? 
10 
A. Back three years ago I would give them to 
11 
potential clients. 
12 
Q. What do you mean potential clients? 
13 
A. Potential clients. 
14 
Q. What kind of clients? 
15 
A. To run escort. 
16 
Q. This is when you were working for an 
17 
escort service? 
18 
A. No, I was working for myself. 
19 
Q. You were a self-employed escort? 
20 
A. Yes, self, yeah. 
21 
Q. And what, and what were you doing business 
22 
as? What was your name? Did you have a name for 
23 
your business? 
24 
A. No. 
25 
Q. And why were you using a fake name? 
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Page 398 
Q. — and a name? 
A. Yes. 
Q. — whether it was your real name or some 
stage name or some other name that you've used? 
A. Yes, there has been. 
Q. Okay. There mere a bunch of those, 
weren't there? 
MR. EDWARDS: Form. 
THE WITNESS: What do you mean a bunch of 
those? 
BY MR.. LUTTIER: 
Q. Go ahead. Tell me about the other cards 
that existed. 
A. One card, it was a black card. This was 
probably three years ago. Yes, three years ago. It 
had, rm pretty sure, a fake name on there and a number 
to contact me and that's it. 
Q. And what else was on the card? 
A. I think it was roses. I'm not sure. 
Q. What else, what other words were on the 
card? 
A. No words. Just my name and my number. 
Q. And do you remember the name that you 
used? 
. A. If anything it mould be 
Page 400 
1 
A. Why use my real name? 
2 
Q. Any other reason why you were using a fake 
3 
name? 
4 
A. Yeah, because I don't want stalkers. 
5 
Q. Now at the time you were using this card, 
6 
you would give that to prospective escorts; that is 
7 
males that would pay you money to go out with you, 
8 
right? 
9 
A. Correct. 
10 
Q. And again were you 
did you figure out 
11 
how to target what you thought were older men with 
12 
money? 
13 
A. Col I ei.t. 
14 
Q. Now, when you were using the card that 
15 
said Taneal, not only were you going out with these 
16 
individuals but you would pertain' sexual acts with 
17 
these individuals, did you not? 
18 
A. Correct. 
19 
Q. What — and you say this went on for a 
20 
five-month period roughly? 
21 
.A. Dispensing of the cards. 
22 
Q. For what period of time, though, were you 
23 
conducting your own escort' ervice? 
24 
MR. EDWARDS: Form. 
25 
THE WITNESS: I can't tell you that. 
•(561) 832-7500 
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1 
BY MR. LUTDER 
2 
Q. Well, was It throughout the whole year —
3 
A. I've always before January 2010, I've always 
4 
been independent in some way or another except when I 
5 
was with 
or 11 months. 
6 
Q. What do you mean by you were independent? 
7 
You mean you were, you were running your own escort 
8 
service? 
9 
A. No, I was running me. 
10 
Q. Okay. But I mean what you were running 
11 
was an escort service with one person, that being 
12 
you? 
13 
A. Correct 
14 
Q. All tight. Now, was there a particular 
15 
clientele that you targeted while you were operating 
16 
as your one-man or one-woman escort service? 
17 
A. Old men. 
18 
Q What, old men? 
19 
A. Yep. 
20 
Q. You liked older men better than younger 
21 
men? 
22 
A. Yes. 
23 
Q. And why did you like older men better? 
24 
A. Beeanse Jeffrey had money, so I assumed that 
25 
older men had money. 
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Page 403 
Q. Okay. Did you ever get paid $2000 a day 
when you were working for yourself? 
A. No. 
Q. What's the most you recall getting paid 
when you worked for yourself? 
MR. EDWARDS: Form. 
THE WITNESS: On advise of counsel I am 
invoking my Fifth Amendment rights under the 
United States Constitution. 
BY MR. LUMER: 
Q. And what why would you be invoking your 
right under the Fifth Amendment? Do you think you 
committed some kind of crime? 
A. On advice of counsel I am invoking my Fifth 
Amendment tights wider the United States Constitution. 
Q. Tell the ladies and gentlemen of the jury 
what acts and activities you engaged in with these 
older men that you had targeted and thought were 
rich for which you got paid between $50 and $2,000? 
A. Between what dates? 
Q. While you were operating your own escort 
savice. 
A. Between what dates? 
Q. Well, let's take, you said it was 2007. 
So, let's take 2007. 
1 
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Page 402 
Q. So, you, your reason for picking old men 
was you thought they were rich? 
it Correct. 
Q. And that's what you wanted was rich 
people? 
A. Correct. 
Q. And how much would you get paid by these 
clients? 
A. Anywhere froni $50 to — sir, I don't recall 
what I made. I can't I can't answer that question 
truthfially. 
Q. Well, you said in your last deposition, 
but I don't know if this is while you were working 
on your own escort service or when you were working 
for somebody else, that you made as much as $2,000 a 
day; do you recall that? 
MR. EDWARDS: Object to the form. 
THE WITNESS: Correct 
BY MR. LUTHER: 
Q. Okay. All nee. So, is that while you 
were working for somebody else's escort service or 
is that while you were self-employed in your own 
escort service? 
A. I did that together. I worked for escort 
services and I've also worked for nwself. 
1 
2 
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L7 
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Page 404 
A. Sexual intercourse, oral, and just strictly 
company, naked company. 
Q. Naked company? 
A. Correct 
Q. Meaning? 
A. Sitting there naked and talking, having a 
conversation. 
Q. So, a customer would pay you — by the way 
when you were running your own escort service, how 
would you actually meet the client? Would they come 
pick you up, would you pick them up, that kind of 
thing? 
MR. EDWARDS: Object to the form. 
THE WITNESS: I would meet them at their 
house. 
BY MR. LUTITER: 
Q. Okay. Was that typically what you did, 
you would go to a client's house? 
A. Correct. 
Q. And so some of these clients that you went 
to, all of whom were, fit within the category of 
rich older men? 
A. Correct. 
Q. .You— some of them you would just go, go 
in and disrobe and sit in their house and talk to 
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Page 405 
them? 
2 
A. Correct. Or take a bath, either/or. 
Q. Take a bath with them or alone? 
A. With them or without them. 
5 
Q. Would you get calls from individuals whom 
6 
you had never met before? 
7 
A. Correct. 
8 
Q. And then would you have some clients that 
9 
would be repeat business that would call you again? 
10 
A. Correct. 
11 
Q. How would you know if someone called you 
12 
on the phone whether or not that's, anything about 
13 
the person? 
14 
A. How would I know? 
15 
Q. If the person called you on the phone, 
16 
would they typically just give you an address and 
17 
say come meet me there? 
18 
A. Correct. 
19 
Q. So how — what did you know about this 
20 
person before you went to their home? 
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MR. EDWARDS: Form. 
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THE WITNESS: That he has a penis and that 
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he has money. 
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BY MR. WITTER: 
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Q. And how would you be able to ascertain he 
Page 407 
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discussion about dollars, how much? • 
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A. If you want to pay my phone bill, I can give 
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you naked company. If you want to pay my son's tuition, 
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I can give you naked company. Bargaining, you know. 
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Q. Would the, would the person actually do 
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that, sort of barter and actually pay your phone 
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bill as opposed to giving you the money? Is that 
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just the amount of money that he would give you is 
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what your phone bill was? 
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A. It would go either way. 
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Q. So, let's — 
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A. rd say, hey, I need my phone bill paid; you 
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can pay my phone bill. 
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Q. Let's use the example of your son's 
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tuition. 
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A. Ifit-huh. 
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Q. Is that, is that an actual event where you 
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told somebody I need my son's tuition paid? 
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A. Yet 
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Q. Okay. And how much was the tuition 
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roughly? 
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A. It's $400 a month. 
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Q. Okay. So you go to this client and you 
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say I need to have my son's tuition paid. That's 
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400 bucks a month. Now, are you — did you 
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Page 406 
bad money? 
A. I'm not working for free. 
Q. Well, would you have a discussion up front 
in the first phone call about money? 
A. Sometimes. 
Q. Because these are people -- 
A. I don't hie to talk over the phone. I would 
rather talk in person. 
Q. Okay. But these would be people that you 
had, they had gotten your number someplace but you 
had never met the first time, right? 
A. Correct 
Q. Okay. So then, so a guy calls. You talk 
to hint You say you don't want to talk money the 
first phone call, so then you go to his house? 
A. Coned. 
Q. Do you have a discussion with him at that 
point in time about money? 
A. Correct. 
Q. Okay. And, and what would that discussion 
be? 
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A. 1 can accommodate you with whatever your needs 
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are, and you can accommodate me with whatever my needs 
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are. 
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Q. And would you, would you have a specific 
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Page 408 
communicate him that you needed just one month's 
paid or more than one month? 
A. If they want to pay one month, great, if they 
want to pay two, greater. 
Q. I mean, what did the client say to you 
when you say I need my son's tuition paid? 
A. He would either say, yes, I agree, or, no, I 
don't agree. 
Q. Okay. So. he says, yes, I will agree. 
How does that determine, how do you determine what 
specific acts you're going to engage in? 
A. Whatever he wants. Does he want sexual 
intercourse in 'O7. Does he want oral sex in 2007, or 
does he just want simple company? 
Q So, it didn't, it didn't matter. It 
wasn't like certain things cost more so to speak? 
A. No, I, no, I just went with the flow. 
Q. Okay. What -- and, and you had no 
concerns about that? 
A. Of course. I am always in fear for what I do. 
Q. I mean, did you use like a condom? 
A. Yes. 
Q. MI right: What was the, what event can 
you recall that was the most expensive event you 
performed, or the one for which you got paid the 
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