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1 
BY MR. 
2 
Q. 
Did you ever see a transcript of that 
3 
conversation? 
4 
A. 
No. 
5 
Q. 
Did you ever see a probable cause affidavit 
6 
that had been drafted with respect to you? 
7 
A. 
No. 
8 
Q. 
Never read it? 
9 
A. 
Never read it. I don't even know what you're 
10 
talking about. 
11 
Q. 
Okay. One last thing before we break for 
12 
lunch. 
13 
A. 
Uh-huh. 
14 
Q. 
We were talking before about phone calls that 
15 
had been made to you after police started their 
16 
investigation. Do you recall those questions generally? 
17 
A. 
Yes. 
18 
Q. 
I want to ask it this way: After the 
19 
investigation began, other than the one call that you 
20 
discussed with us where someone called your house 
21 
wanting to talk to you, 
22 
A. 
Uh-huh. 
23 
Q. 
did anyone else ever call your home to 
24 
discuss with you the investigation, other than your 
25 
lawyers? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-S4e7-90flb7174075 
3501.182-102 
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A. 
No, not that I can remember, no. 
2 
Q. 
Were there any other phone calls that were 
3 
made to your house after the investigation began about 
4 
Jeffrey? 
5 
A. 
No, not that I can remember. 
6 
Q. 
And as you sit here today, your testimony is, 
7 
you never talked to someone that said they worked for 
8 
Jeffrey that told you not to talk about the incident; is 
9 
that your testimony? 
10 
A. 
I don't remember ever having a conversation 
11 
like that. 
12 
MR. 
: Okay. All right. Let's take a 
13 
break for lunch and we'll come back -- and do you 
14 
need 45 or an hour? 
15 
VIDEOGRAPHER: Off the record. 
16 
(Lunch recess.) 
17 
VIDEOGRAPHER: We're back on the video record. 
18 
The time is 2:20 p.m. 
19 
BY MR. 
20 
Q. 
Okay. When we left off we were talking about 
21 
after the police got done with their interview of you 
22 
and you were going home. 
23 
I want to go back for just one second. I did 
24 
forget to ask you something. 
25 
The questions I was asking you about whether 
(5611 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401377476-2895) 
Electronically signed by Sandra Townsend (401377476-2895) 
1f88f113.5663.4dad-94e7-90flb7174075 
3501.182-102 
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1 
or not someone who worked for Jeffrey or represented 
2 
him, that they were from Jeffrey, whether they called 
3 
you after the police had first contacted you. 
4 
I want to go to before the police got to you: 
5 
house and came and talked to you. 
6 
A. 
Okay. 
7 
Q. 
Before that point when the police came, did 
8 
anyone talk to you and say anything about the police 
9 
investigating, what you should say, anything like that? 
10 
A. 
I do not ever remember getting a call at all. 
11 
Q. 
How about in-person conversations? 
12 
A. 
No. 
13 
Q. 
Okay. Just so we're clear, no conversations 
14 
that you can recall, as you sit here today, either 
15 
before or after the police investigation started, from 
16 
either Jeffrey, 
or anyone that represented that 
17 
they were calling on behalf of Jeffrey or talking to you 
18 
in person on behalf of Jeffrey, talked to you about what 
19 
to say or what not to say during the investigation? 
20 
A. 
That's correct. That conversation in person, 
21 
over the phone never happened or on behalf of Jeffrey 
22 
Epstein. 
23 
Q. 
No e-mails? 
24 
A. 
No e-mails. 
25 
Q. 
No texting? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-S4e7-90flb7174075 
3501.182-102 
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A. 
No texting. 
2 
Q. 
Did you ever text anything with 
3 
A. 
I don't believe I ever did, no. 
4 
Q. 
Did you ever e-mail with 
5 
A. 
Never e-mail. 
6 
Q. 
Were there any other communications that you 
7 
ever had with 
, other than phone conversations, in 
8 
any other format, electronic or otherwise? 
9 
A. 
No. 
10 
Q. 
Okay. After the police dropped you off after 
11 
that initial interview, what did you do? 
12 
A. 
Well, I had explained to my parents what had 
13 
just happened and just taken place. 
14 
My -- I don't recall if my dad was there. My 
15 
mom was. 
16 
I sat her down and I discussed what was going 
17 
on and what had happened. 
18 
My dad was immediately contacted. 
• 
• 
• 
• 
• 
• 
• 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-S4e7-90flb7174075 
3501.182-102 
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3 
Q. 
Oh, okay. So at that point a criminal 
4 
attorney was hired by your parents? 
5 
A. 
That's correct. 
6 
Q. 
Are you still represented by that criminal 
7 
attorney to this day? 
8 
A. 
'Til this day? 
9 
MS. 
: I don't really know that that's 
10 
an appropriate question. I'm going to instruct her 
11 
not to answer it if the only way she knows the 
12 
answer to that is through talking with her criminal 
13 
attorney or with a civil attorney. 
14 
BY MR. 
15 
Q. 
All right. Well then, I guess, let me ask it 
16 
this way: The attorneys that are here representing you 
17 
here today are your civil attorneys. 
18 
A. 
Yes. 
19 
Q. 
Do you understand that? 
20 
A. 
Uh-huh. 
21 
Q. 
Yes? 
22 
A. 
Yes, I do understand that. 
23 
Q. 
Who's paying their bill? 
24 
MS. 
: I'm going to ask her not to 
25 
answer that if the only way she knows that 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-S4e7-90flb7174075 
3501.182-102 
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information is through her attorneys. 
2 
BY MR. 
3 
Q. 
Okay. Do you know who is paying their bill, 
4 
other than what the attorneys may have said to you? 
5 
A. 
No. I know who's paying my bill from what my 
6 
attorneys have told me. 
7 
Q. 
And that's the only way you know it? 
8 
A. 
And that's the only way I know it. 
9 
Q. 
Let me ask it this way: Are you paying for 
10 
the civil attorneys? 
11 
A. 
No. 
12 
Q. 
Are your parents paying for the civil 
13 
attorneys? 
14 
A. 
No. 
15 
Q. 
Are any of your relatives paying for the civil 
16 
attorneys? 
17 
A. 
No. 
18 
Q. 
Did you find the civil attorneys? 
19 
A. 
Did I find the civil attorneys? 
20 
Q. 
Yes. It's a very good law firm that's 
21 
representing you here today in this civil litigation 
22 
context. 
23 
A. 
No, I did not find my attorneys. My criminal 
24 
lawyer did. 
25 
Q. 
Okay. You got paid $200 every time that you 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-S4e7-90flb7174075 
3501.182-102 
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1 
took a girl to Jeffrey's house. But do you know, as you 
2 
sit here today, the total amount of money that you made 
3 
taking girls there? 
4 
A. 
I do not know. 
5 
Q. 
Would you agree with me that it had to be in 
6 
the thousands? 
7 
A. 
Yes, I can say that. 
8 
Q. 
Had to be in the multiples of thousands? 
9 
A. 
I wouldn't say, multiples of thousands. 
10 
Q. 
Well, if we're talking --
11 
A. 
Wait. What do you mean, "multiples?" Two 
12 
thousand? Three thousand? 
13 
Q. 
Yes. 
14 
A. 
Yes. I'm sorry. I thought you were talking 
15 
about double digits. 
16 
Q. 
No. Let me be more specific. 
17 
If we look at just the 12, the dozen at 200 
18 
each time, that's about $2,400. 
19 
A. 
Plus the time that I massaged, which would 
20 
bring it up to 2600. 
21 
Q. 
And then you brought some girls more than 
22 
once? 
23 
A. 
Okay. 
24 
Q. 
Right? 
25 
A. 
Yes. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-S4e7-90flb7174075 
3501.182-102 
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Q. 
So would you agree with me that the number 
2 
that you made just bringing girls would have to be in 
3 
excess of 3,000? 
4 
A. 
I don't know. 
5 
Q. 
Did you deposit any of the money that you made 
6 
into a bank account? 
7 
A. 
No. 
8 
Q. 
You just kept the cash and then spent it? 
9 
A. 
Yes. 
10 
Q. 
Did Mr. Epstein give you -- let me ask it this 
11 
way: Did Mr. Epstein or someone on his behalf give you 
12 
any money, other than when you brought girls? 
13 
A. 
No. 
14 
Q. 
Did you get a Christmas bonus? 
15 
A. 
No. 
16 
Q. 
Did you get a Western Union telegram of money 
17 
at any point? 
18 
A. 
No. 
19 
Q. 
Are you aware that other girls did? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: I guess I am now. 
22 
BY MR. 
23 
Q. 
Are you learning that through me or did you 
24 
learn that --
25 
A. 
I learned through bonuses. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-94e7-90flb7174075 
3501.182-102 
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Q. 
That's what I'm looking for. Did you get 
2 
bonuses? 
3 
A. 
I did not personally, no. 
4 
Q. 
Did Mr. Epstein give you any gifts? 
5 
A. 
No. 
6 
Q. 
Have you heard that he paid for certain baby 
7 
showers of some girls? 
8 
A. 
A baby shower? No. 
9 
MR. CRITTON: Form. 
10 
BY MR. 
11 
Q. 
Never heard about that? 
12 
A. 
No. 
13 
Q. 
Did he ever rent you a car? 
14 
A. 
No. 
15 
Q. 
Did you ever ask him to rent you a car and he 
16 
said no? 
17 
A. 
No. 
18 
Q. 
Did he ever pay for anything, that you can 
19 
think of as you sit here today? 
20 
A. 
He never paid for anything. 
21 
Q. 
So the only thing he gave you was the $200 
22 
cash every time you brought a girl and the time that you 
23 
did the massage yourself? 
24 
A. 
Can I have a minute? 
25 
Q. 
Sure. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1f88f113.5663.4dad-94e7.50f1b7174075 
3501.182-102 
Page 129 of 156 
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MR. CRITTON: What was the question? Would 
2 
you read it back, please? 
3 
MR. 
: Yeah. 
4 
MS. 
: Go ahead. 
5 
MR. 
: Yeah. While you figure it out, 
6 
let her read it back. 
7 
(Pending question was read.) 
8 
MS. 
: I think we've answered that. 
9 
MR. 
: Okay. 
10 
THE WITNESS: That was the only time he paid. 
11 
That's the only time I received money from him. 
12 
BY MR. 
13 
Q. 
Did you receive anything else from him, other 
14 
than money? 
15 
A. 
No. 
16 
Q. 
Did you get anything from 
, other 
17 
than money? 
18 
A. 
No. 
19 
Q. 
Did you get money from 
20 
A. 
No. 
21 
Q. 
Did you get money from anyone other than 
22 
Jeffrey or 
that said that they were working on 
23 
behalf of Jeffrey or that you knew was working on behalf 
24 
of Jeffrey? 
25 
A. 
The only person that ever gave me money was 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad44.7-90flb7174075 
3501.182-102 
Page 130 of 156 
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1 
Epstein. And I have not received anything else. 
2 
Q. 
No one on his behalf? 
3 
A. 
No one on his behalf. 
4 
Q. 
Gave you anything? 
5 
A. 
Gave me anything. 
6 
Q. 
Okay. All right. After the investigation 
7 
began and you talked to police, did you ever have any 
8 
further conversations with Mr. Epstein after that date? 
9 
A. 
No. 
10 
Q. 
Did you ever have any further conversations 
11 
with 
after that date? 
12 
A. 
No. 
13 
Q. 
Do you remember before the police came to your 
14 
house, III. calling you at III 
15 
A. 
Yes, I do recall that. 
16 
Q. 
What did she say to you during that 
17 
conversation, as best you can recall? 
18 
A. 
As best as I can recall, she called once. 
19 
They told her I was busy, to call back later. 
20 
She called back a second time, asked to speak 
21 
with me. 
22 
I then picked up the line. 
23 
She had asked me if she can work for Jeffrey 
24 
again. 
25 
I told her no. I told her that she was 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1f88f113.5663.4dad-94e7
3501.182-102 
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1 
basically full of herself and that I heard she was 
2 
trying to set me up and trying to -- to rat me out, is 
3 
basically what I had said to her. 
4 
Q. 
Have you seen the transcript of that phone 
5 
conversation that you had with her? 
6 
A. 
I have not seen the transcript, no. 
7 
Q. 
Okay. There were two phone calls that you can 
8 
recall, one where you weren't available and the second 
9 
one where you actually talked to her? 
10 
A. 
That's correct. 
11 
Q. 
Because your attorney asked before to see, let 
12 
me just show this to your attorney really quickly. 
13 
MR. CRITTON: You going to mark it as an 
14 
Exhibit? 
15 
MR. 
: No. 
16 
MS. 
: What are you showing me? 
17 
MR. 
: The phone call. 
18 
MS. 
: Can you clarify, like, how this 
19 
was transcribed? Is this something your office 
20 
did? 
21 
MR. 
: From the police. No, it was given 
22 
to me from the State Attorney and the police 
23 
department. 
24 
THE WITNESS: And it was recorded. 
25 
MS. 
: And is this a document you're 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad44.7-90ftb7174075 
3501.182-102 
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Page 133 
going to ask 
some questions about now? 
2 
MR. 
: Yes. 
3 
MS. 
: Then I'm going to have her read 
4 
it as well. 
5 
MR. 
: Okay. That's fine. I didn't know 
6 
if you wanted to read it first. 
7 
MR. CRITTON: Before you start, let me read 
8 
it, too. 
9 
MS. 
: Do you want to get a couple 
10 
copies? 
11 
MR. 
: Do you want to take a second so we 
12 
can all read this? 
13 
THE WITNESS: What is this? Is U-N-K unknown 
14 
caller? Is that me? 
15 
MR. 
: It's one of the things I was going 
16 
to ask you. 
17 
MS. 
: Let's get copies of all this for 
18 
everybody, since no one seems to have it. 
19 
MR. CRITTON: Why don't you mark it as an 
20 
Exhibit, too. Why don't we call it Exhibit 2 and 
21 
have it copied, put a sticker on it, please. 
22 
MR. 
: They got to stop talking for you 
23 
to copy it. I know. 
24 
VIDEOGRAPHER: You want to go off the record? 
25 
MR. 
: Yeah. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad44.7-90ftb7174075 
3501.182-102 
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1 
VIDEOGRAPHER: Going off the video record. 
2 
The time is 2:35 p.m. 
3 
(Brief recess.) 
4 
VIDEOGRAPHER: We're back on the video record. 
5 
The time is 2:35 p.m. 
6 
BY MR. 
7 
Q. 
While they're making copies of the other 
8 
document I was going to ask you about, I want to go 
9 
through some of these photographs, if I could, for a 
10 
minute. 
11 
I'm going to mark this one as Exhibit 2 to 
12 
your deposition. Let me just hold it up for the camera 
13 
first. 
14 
MR. CRITTON: I think we marked the statement 
15 
number 2. 
16 
MR. 
: No. You wanted to mark the 
17 
statement number 2, but I never agreed to that. 
18 
this is number 2. 
19 
VIDEOGRAPHER: That's fine. 
20 
(Exhibit number 2 was marked for 
21 
identification purposes.) 
22 
BY MR. 
23 
Q. 
All right. I'm going to show you what is 
24 
Exhibit 2. And let me just ask you, first, do you 
25 
recognize the photograph? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-S4e7-90flb7174075 
3501.182-102 
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Page 135 
A. 
Yes. 
2 
Q. 
Who took it? 
3 
A. 
4 
Q. 
What was it for? 
5 
A. 
6 
Q. 
And how old were you in this photo? 
7 
A. 
Eighteen, 19 maybe. 
8 
Q. 
And this is you? 
9 
A. 
This is me. 
10 
Q. 
Where was this posted on the Internet? 
11 
A. 
This was posted on my --
12 
Q. 
Initially? 
13 
A. 
Initially on My Space page. 
14 
Q. 
Subsequently it was posted a lot of different 
15 
places on the Internet. You're aware of that, correct? 
16 
A. 
No. What are you talking about? 
17 
Q. 
In news stories regarding Mr. Epstein, have 
18 
you seen this posted in other places? 
19 
A. 
Yes. 
20 
Q. 
They've used this photograph when talking 
21 
about --
22 
A. 
Wait. I'm confused. 
23 
Q. 
Let me back up. 
24 
This is a photo that you put on the Internet 
25 
yourself? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1f88f113-5683-4dad-94e7
3501.182-102 
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1 
A. 
Yes. 
2 
Q. 
On your My Space page? 
3 
A. 
Yes. 
4 
Q. 
And it shows you at around 18 years old? 
5 
A. 
Yes. 
6 
Q. 
Have you seen it 
7 
MR. CRITTON: Form of the last question. You 
8 
said 18 or 19. 
9 
MR. 
: Eighteen or 19. 
10 
BY MR. 
11 
Q. 
Have you seen this posted any other place, 
12 
other than your My Space page, on the Internet? 
13 
A. 
That, and a lot of the blogs about Epstein and 
14 
the whole situation in Google. Other than that, no. 
15 
Q. 
This particular photo of you, have you had any 
16 
physical changes to your body subsequent to this 
17 
photograph being taken? 
18 
MS. 
: Objection. I'm not sure where 
19 
or why you're going with this. I don't think it's 
20 
relevant. You haven't laid any type of predicate. 
21 
And this is a private matter for 
, who is not 
22 
a Plaintiff or a Defendant in this case. 
23 
I'm going to instruct her not to answer that 
24 
question. 
25 
BY MR. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401477476-2895) 
Electronically signed by Sandra Townsend (401477476-2895) 
1f88f113-5663-4dad-94e7-90ftb7174075 
3501.182-102 
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Q. 
Okay. Did you post any photos of yourself on 
2 
the Internet younger than the age of 18; in other words, 
3 
on your My Space page, were there any photos of you 
4 
younger than 18? 
5 
A. 
I don't remember. 
6 
Q. 
You have photos of you at the time when you 
7 
were 16, 15, 17 years old? 
8 
A. 
Possibly. 
9 
Q. 
At home? 
10 
A. 
Yeah. 
11 
Q. 
Okay. Let me show you what we'll mark as 
12 
Exhibit 3. Ask you if you recognize anyone in this 
13 
particular photograph. 
14 
(Exhibit number 3 was marked for 
15 
identification purposes.) 
16 
MR. 
: And hold this up for the camera 
17 
first. 
18 
VIDEOGRAPHER: Okay. 
19 
MR. CRITTON: Let me see it again, please. 
20 
MR. 
: Got your own. 
21 
BY MR. 
22 
Q. 
Take a look at that photo. 
23 
Do you recognize anyone in the photograph 
24 
we've marked as Exhibit 3? 
25 
A. 
The middle girl looks like 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1188f113-5663-4dad-S4e7-90flb7174075 
3501.182-102 
Page 137 of 156 
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Page 138 
Q. 
Recognize any of the men in that photograph? 
2 
A. 
No, I don't. 
3 
Q. 
All right. When you say, ' 
," you mean, 
4 
5 
A. 
Yeah. 
6 
Q. 
And 
is the girl that you met at 
7 
Jeffrey Epstein's house? 
8 
A. 
Yes. 
9 
Q. 
Let me show you what we'll mark as Exhibit 
10 
MR. CRITTON: Did you have any extra copies of 
11 
Exhibit 2 for us all? 
12 
MR. 
: I do. 
13 
MR. CRITTON: Thank you. 
14 
MR. 
: Mark the photograph as Exhibit 4. 
15 
(Exhibit number 4 was marked for 
16 
identification purposes.) 
17 
BY MR. 
18 
Q. 
Show this one to you. Camera first. 
19 
Okay? Let me show you what we marked as 
20 
Exhibit 4. 
21 
First of all, do you recognize the gentleman 
22 
in that photograph? 
23 
A. 
Mr. Jeffrey Epstein. 
24 
Q. 
Do you recognize the girl in that photo? 
25 
A. 
No. I don't remember her. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electron Gaily signed by Sandra Townsend (401.377-676.2895) 
Elecnonicaily signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-94e7-90flb7174075 
3501.182-102 
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Page 139 
Q. 
Does not look familiar to you? 
2 
A. 
I don't remember her. 
3 
Q. 
Let's go now. 
4 
MR. 
: We've got the copies of the 
5 
statement brought back? 
6 
MS. 
: Yes. You need a copy? 
7 
MR. 
: You got my original? 
8 
MS. 
: Take your time and read the 
9 
whole thing. 
10 
MR. 
: Somebody's got one that's 
11 
highlighted. Who's got it? 
12 
THE WITNESS: I think I have it. 
13 
MR. CRITTON: I think I do. 
14 
THE WITNESS: Nevermind. 
15 
BY MR. 
16 
Q. 
Go ahead. I want you to read it. It's only 
17 
four pages. 
18 
MR. CRITTON: Can we mark it as Exhibit 5? Do 
19 
you have any objection to doing that? If not, I'll 
20 
just mark it as a Defense Exhibit. It's an Exhibit 
21 
you're showing to her. 
22 
MR. 
: I just don't know. Let me ask 
23 
some questions and I'll figure it out. 
24 
MR. CRITTON: Well, I'm going to direct it be 
25 
marked by the reporter. It's a statement that's 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1f88f113.5663.4dad-94e7
3501.182-102 
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Page 140 
being shown to her. 
2 
Mark it as Defense Exhibit 1, please. 
3 
MR. 
: I think you can only do that 
4 
during your examination, but... 
5 
MR. 
: I think so, too, but... 
6 
MR. CRITTON: I'm doing it now. Call me in 
7 
front of the Judge on it. 
8 
MR. 
: Bob Critton rules of taking 
9 
deposition. It's a different rule book. 
10 
Get up in years, you're allowed to do that. 
11 
(Defendant's Exhibit number 1 was marked for 
12 
identification purposes.) 
13 
BY MR. 
14 
Q. 
Okay. Does that help refresh your 
15 
recollection about the phone call that I. placed to you 
16 
that was being recorded? 
17 
A. 
I don't really remember it like this, but, 
18 
then again, it was years ago. I do remember her calling 
19 
twice though. 
20 
Q. 
And you noticed in this, what's now, I guess, 
21 
been marked as Defendant's Exhibit 1, you remember or 
22 
you've seen that there's two phone calls noted here in 
23 
this Exhibit? 
24 
A. 
Well, I was kind of confused because it looked 
25 
like she called my house. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-Sile7-90ftb7174075 
3501.182-102 
Page 140 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA j0O94486 
EFTA01248146