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Q. 
Right. 
2 
A. 
And then it looks like she called my house 
3 
again. 
4 
And then it looked like maybe she called • 
I 
6 
Q. 
Okay. In looking at the conversation 
7 
beginning on page 3, do you see that? 
8 
A. 
Yes. 
9 
Q. 
All right. Let's start from the top. 
10 
Do you know whether there was a III working at 
11 
12 
A. 
Yes. 
13 
Q. 
-- when you worked there? 
14 
Who? III who? 
15 
A. 
16 
Q. 
Okay. Friendly with her? Just a working 
17 
friend? 
18 
A. 
Employee. 
19 
Q. 
Do you recall III being the one that took the 
20 
call and got you to get you on the phone? 
21 
A. 
I don't remember. 
22 
Q. 
Do you recall I. calling you and saying, I 
23 
need some money, I was wondering if you could take me to 
24 
Jeff's house? 
25 
A. 
I remember I was having a conversation about 
(5611 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) 
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me taking her back to Jeff's house. 
2 
Q. 
And it says here on line 11: "I was wondering 
3 
if you could take me back to Jeff's house." 
4 
Do you recall her saying that? 
S 
A. 
No. But like I said, this was a couple years 
6 
ago. 
7 
Q. 
It notes here, the next line on page -- on 
8 
line 12 and 13: "I don't know. The last time I did 
9 
that, um, I heard that your dad wanted to press charges 
10 
and stuff." 
11 
What were you referring to? 
12 
A. 
Well, 
went around telling everybody that 
13 
she was going to have me arrested and she was going to 
14 
have her parents press charges against me because of 
15 
everything that took place. So once I found out about 
16 
that, I pretty much let her knew -- let her know that : 
17 
knew what was going on. 
18 
Q. 
Okay. How did you hear about that? 
19 
A. 
• 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377476-2895) 
Electronically signed by Sandra Townsend (401-377476-2895) 
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Q. 
So you heard from 
that I. was telling 
2 
3 
4 
5 
6 
7 
people 
that she was going to press charges 
or somebody from her family was going to press charges? 
A. 
That's correct. 
Q. 
Made you upset? 
A. 
Shocked. 
Q. 
Made you mad? 
8 
A. 
No. Shocked. 
9 
Q. 
Okay. Weren't mad at her at all for this? 
10 
A. 
Shocked. 
11 
Q. 
Do you recall her saying in response: "I 
12 
don't even live with my dad anymore?" 
13 
A. 
I don't remember that. 
14 
Q. 
It says here on line 15: "Oh, well. I don't 
15 
know. It was going around that you were going to press 
16 
charges and get me in trouble and shit." 
17 
Do you remember saying something like that? 
18 
A. 
I don't remember. Like I said, this was years 
19 
ago. I can't recall it. 
20 
Q. 
Okay. Despite what may have been said, do you 
21 
recall mentioning to her that you would call Jeffrey and 
22 
see if you could set it up? 
23 
A. 
I don't recall that, either. 
24 
Q. 
Because it appears on the next page, line 5, 
25 
you say: "Okay. I'll definitely give you a call 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
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tomorrow." 
2 
Do you remember saying anything like that? 
3 
A. 
I don't, no. 
4 
Q. 
Okay. Did you have any further conversations 
5 
with I. about Jeffrey after this phone call, that you 
6 
can recall? 
7 
A. 
I don't ever recall her -- I don't ever recall 
8 
calling her back after this took place. I don't ever 
9 
recall setting up another appointment with Epstein. 
10 
could have just been telling her what she wanted to 
11 
hear. 
12 
Q. 
Do you think that if it hadn't been for I. 
13 
that this would have never -- "this," being, the 
14 
criminal and civil and all this other stuff -- would 
15 
have never happened? 
16 
MR. CRITTON: Form. 
17 
MS. 
: Objection. You're asking her to 
18 
speculate. 
19 
THE WITNESS: I don't know. 
20 
BY MR. 
21 
Q. 
Before I had asked you about who was paying 
22 
for your civil attorneys. Do you recall those 
23 
questions? 
24 
A. 
Yeah, I do. 
25 
Q. 
Going back to that subject for a moment. 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) 
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your mom ever with you when you had conversations with 
2 
the civil attorneys? 
3 
A. 
No. 
4 
Q. 
Physically present in the room at any point? 
5 
A. 
No. 
6 
Q. 
Does your mom know who's paying for the civ._ 
7 
attorneys? 
8 
A. 
Yes. 
9 
Q. 
How does she know? 
10 
A. 
I told her. 
11 
Q. 
What did you tell her? 
12 
A. 
I told her what I was told. 
13 
Q. 
Which was? 
14 
A. 
I told her that my attorney was being paid by 
15 
Mr. Epstein. 
16 
Q. 
Why is he paying for your civil attorney, if 
17 
you know? 
18 
A. 
23 
MS. 
: I'm going to stop you there. 
24 
anything beyond this point is specifically with 
25 
regard to conversations you've had with 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377476-2895) 
Electronically signed by Sandra Townsend (401-377476-2895) 
1f88f113-5663-4dad-94e7-90ftb7174075 
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and 
and/or myself, I do not want you 
2 
to disclose any of the information. 
3 
THE WITNESS: Okay. 
4 
And 
took us to 
7 
BY Mr. 
8 
Q. 
I don't want to know about conversations 
9 
you've had with the civil attorneys. 
10 
But why did you think -- you -- think that you 
11 
needed civil attorneys to help you in this process? 
12 
20 
BY MR. 
21 
Q. 
And I don't want to know anything the lawyers 
22 
said to you. I want to know why you think you need 
23 
civil attorneys for something --
24 
MS. 
: And if the reason is because 
25 
your criminal or civil attorney told you, you need 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377476-2895) 
Electronically signed by Sandra Townsend (401-377476-2895) 
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a civil attorney, you do not need to disclose that 
2 
reason. 
3 
THE WITNESS: Okay. 
4 
I'm going to plead the Fifth on that one. 
5 
MS. 
: You don't have to plead the 
6 
Fifth. 
7 
THE WITNESS: Whatever. This is confusing. 
8 
I'm not answering it. 
9 
MS. 
: No. You do not need to answer 
10 
that. 
11 
THE WITNESS: I'm not answering it. 
12 
MS. 
: If it is -- if it is a 
13 
conversation you had with one of your attorneys, 
14 
you do not need to disclose any of that 
15 
conversation. That is all privileged. 
16 
BY MR. 
17 
Q. 
So we can avoid conversations you've had with 
18 
attorneys, let's just talk about family now. 
19 
A. 
Uh-huh. 
20 
Q. 
You're over the age of 18. You're an adult. 
21 
But you still, nonetheless, had conversations with you 
22 
mother and your father about this whole thing, I assume? 
23 
A. 
Yes. 
24 
Q. 
Did you talk to them about having an attorney 
25 
present for your deposition here today? 
(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) 
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A. 
Of course. 
2 
Q. 
Okay. And, in fact, your mom was here 
3 
earlier? 
4 
A. 
Yes. 
5 
Q. 
Okay. I assume you had a conversation with 
6 
her about why you felt you would need an attorney here 
7 
today. Did you? 
8 
A. 
No. 
9 
Q. 
Never talked to her about why you'd be 
10 
represented by a lawyer here at this deposition? 
11 
A. 
Me and my mom never had a conversation like 
12 
that, no. 
13 
Q. 
You mentioned life savings and retirement and 
14 
all that. 
15 
A. 
Uh-huh. 
16 
Q. 
Did that get used up with respect to the 
17 
criminal proceeding, --
18 
A. 
Yes. 
19 
Q. 
-- paying the criminal lawyers? 
20 
A. 
Yes. 
21 
Q. 
Did you come out of pocket at all to help pay 
22 
for the criminal lawyers? 
23 
A. 
Not me, personally, no. 
24 
Q. 
Your parents paid for that? 
25 
A. 
That's correct. 
(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-94.7-90flb7174075 
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Q. 
All right. Has anyone told you, other than 
2 
the lawyers, that there is no concern for criminal 
3 
prosecution, as you sit here today, other than what the 
4 
civil or criminal lawyers have told you? In other 
5 
words, did a -- did your parents tell you that you don't 
6 
have to worry about criminal prosecution anymore? Did 
7 
any witnesses tell you that? Anything like that? 
8 
A. 
Yes. 
9 
Q. 
Who? 
10 
A. 
My father. 
11 
Q. 
What did he say? 
12 
A. 
Just told me that the criminal part is pretty 
13 
much over. This is the civil part. This is where 
14 
things get ugly, messy, and then it will all be 
15 
finished. 
16 
Q. 
Okay. All right. What did your father think 
17 
of this when this whole thing broke open? 
18 
MR. CRITTON: Form. 
19 
THE WITNESS: I don't know. 
20 
BY MR. 
21 
Q. 
Did you talk to him about it? I mean, you 
22 
obviously had to inform him after you went and talked to 
23 
the police? 
24 
A. 
I did. 
25 
(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 
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I 
I 
4 
Q. 
What was his reaction? 
5 
MR. CRITTON: Object to form. The question 
6 
serves no purpose, other than you're trying to 
7 
harass her and intimidate her or make her life 
8 
miserable at this point. 
9 
MS. 
: And I'm allowing a little bit, 
10 
but not much more. 
11 
MR. 
: Actually, I'm not. I'm showing 
12 
what the common, ordinary individual's reaction 
13 
would be to a man molesting a 16 year old little 
14 
girl, if you really want to get into it. 
15 
MR. CRITTON: Same. 
16 
BY MR. 
17 
Q. 
What did your father think of all this when 
18 
you told him about what had happened? 
19 
A. 
He cried. 
20 
Q. 
Did he blame you? 
21 
MR. CRITTON: Form. 
22 
MS. 
: Objection. And I'm going to 
23 
instruct her not to answer that question. 
24 
MR. 
: Come on. 
25 
MS. 
: I don't think it's relevant to 
(5611 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
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2 
this case. 
MR. 
: 
Page 151 
I'll tell you exactly why it's 
3 
relevant. 
4 
MR. CRITTON: Let her finish. 
5 
MR. 
: I'm sorry. Go ahead. 
6 
MS. 
: She's not a Plaintiff. She's 
7 
not a Defendant. She has not put her character at 
a 
issue. This is a private matter. It serves no 
9 
purpose, other than to upset and harass her, as you 
10 
can see it's doing right now. 
11 
MR. 
: I have no intent to upset her or 
12 
harass her. But when a pervert like Jeffrey 
13 
Epstein is molesting 16 year old girls, I have 
14 
every right to ask a girl who's been through it 
15 
what it made ordinary people think of. And when 
16 
he's saying in defense to the civil action that 
17 
these girls had it coming to them because they 
18 
volunteered for it, I'm curious what an ordinary 
19 
individual's parent would think, much like all of 
20 
the other girls that were brought to this home fo:: 
21 
this man to molest. 
22 
MS. 
: You have not noticed her father 
23 
or her mother for deposition today. 
24 
MR. 
: And I don't want to have to go 
25 
there. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377476-2895) 
Electronically signed by Sandra Townsend (401-377476-2895) 
1f88f113-5663-4dad-94e7-90ftb7174075 
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MS. 
: You're asking her how her 
2 
parents feel. You're asking her to speculate as to 
3 
how her parents feel. And that serves no other 
4 
purpose than to 
5 
MR. 
: I don't want to know what her 
6 
parents felt. I want to know what her parents' 
7 
reaction was that she witnessed and heard. And I 
8 
think that's entirely relevant to, not only the 
9 
claims in this case, but the defenses that have 
10 
been raised by Mr. Epstein. 
11 
MR. CRITTON: Let me add to my form objection. 
12 
It is, number one, I object to your speech. I 
13 
think it was inappropriate. 
14 
Number two is, many of the Plaintiffs' lawyers 
15 
have fought me even getting this kind of 
16 
information from Plaintiffs in this case, less some 
17 
witness who has -- is neither a party, nor has any 
18 
involvement in the case, other than is a 
19 
third-party witness. 
20 
So I would suggest, is that, with the 
21 
difficulty and the fighting that I've had from 
22 
Plaintiffs' lawyers to get responses to those 
23 
questions, I'm not sure that either Judge Hafele in 
24 
this particular -- Judge Hafele, who I think will 
25 
have an opportunity to look at this record if it's 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
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Page 153 
brought in front of him, would necessarily find 
2 
that that's appropriate questioning. But that's 
3 
just my form objection. And obviously she has 
4 
her -- she has her own lawyer that's going to 
5 
instruct her to do, so you and I can talk as long 
6 
as we want, but it's not going to change her 
7 
lawyer's directions, I assume. 
8 
MS. 
: I'm instructing you not to 
9 
answer that question now absent a Court Order. 
10 
(Brief interruption.) 
11 
MR. 
: Hello. 
12 
MR. 
: Yes. I'm calling in to take 
13 
place. 
14 
MR. 
: He's sitting right here. 
15 
MR. 
: Does that mean I'm out, 
16 
MR. 
: You're out. 
17 
MR. 
: All right, buddy. 
18 
MR. 
: The A team is coming in. 
19 
MR. CRITTON: I'd like that on the record, 
20 
please. 
21 
MR. 
: All right. I'm going to shut it 
22 
down, but, 
, you have -- you have the baton, so 
23 
to speak. 
24 
MR. 
: Okay. 
25 
BY MR. 
(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) 
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Page 154 
Q. 
All right. I'm going to ask the question and 
2 
a lawyer, your lawyer is going to either let you respond 
3 
or not let you respond, so just wait, if you would. 
4 
You already told us that when you told your 
5 
father about what had happened with Jeffrey Epstein that 
6 
he cried. What I'm asking now is: What did he say to 
7 
you; in other words, did he say, it's your fault? Did 
8 
he blame you? 
9 
MS. 
: Objection. Predicate. 
10 
Relevance. And I believe these questions serve nc 
11 
purpose, other than to harass and upset Ms. 
12 
who, again, is not a Plaintiff or a Defendant. 
13 
She's merely a witness and should not be subjected 
14 
to what she's going through right now. Absent a 
15 
Court Order, I'm asking her to refrain from 
16 
answering those questions. And I'd also ask for a 
17 
break, if we could take one, so she can compose 
18 
herself. 
19 
MR. 
: Okay. I'll definitely give you 
20 
the break. I certainly don't think I'm harassing, 
21 
but I'll give you the break. 
22 
VIDEOGRAPHER: Going off the record on tape 
23 
number two. The time is 2:57 p.m. 
24 
(Brief recess.) 
25 
(Deposition continued to Volume II.) 
(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 
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Page 155 
1 
2 
3 
4 
5 
CERTIFICATE OF OATH 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
6 
I, the undersigned authority, certify that 
7 
8 
sworn on the 10th day of November, 2009. 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
personally appeared before me and was duly 
Dated this 20th day of November, 2009. 
Sandra W. Townsend, Court Repo? 
Notary Public - State of Florida 
My Commission Expires: 6/26/12 
My Commission No.: 
DD 793913 
(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) 
1188f113-5663-4dad-94e7-90ftb7174075 
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CERTIFICATE 
2 
STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
I, Sandra W. Townsend, Court Reporter and 
Notary Public in and for the State of Florida at Large, 
do hereby certify that the aforementioned witness was by 
me first duly sworn to testify the whole truth; that I 
was authorized to and did report said deposition in 
stenotype; and that the foregoing pages numbered 1 to 
154, inclusive, are a true and correct transcription of 
my shorthand notes of said deposition. 
I further certify that said deposition was 
taken at the time and place hereinabove set forth and 
that the taking of said deposition was commenced and 
completed as hereinabove set out. 
I further certify that I am not attorney or 
counsel of any of the parties, nor am I a relative or 
employee of any attorney or counsel of party connected 
with the action, nor am I financially interested in the 
action. 
The foregoing certification of this transcript 
does not apply to any reproduction of the same by any 
means unless under the direct control and/or direction 
of the certifying reporter. 
Dated this 20th day of November, 2009. 
Sandra W. Townsend, Court Reporter 
(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
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