EFTA00725643

3 
is? 
4 
A. Yeah. 
5 
Q. Did you ever engage in a three-way? 
6 
A. A three-way phone call? 
7 
Q. No. Three-way sexual experience. 
8 
A. Yeah. 
9 
Q. That is, like, have you ever engaged in 
10 
those? 
11 
A. No. 
12 
Q. Have you ever had a sexual encounter with 
13 
another woman? 
14 
A. No. 
15 
Q. Okay. Now, whet." were at 
16 
Mr. Epstein's, you and 
are there. She writes 
17 
this pad out. She writes this note on this pad, 
18 
right? 
19 
A. Yeah. 
20 
Q. And then after she writes on it, you take 
21 
a pen and you draw these two hearts and you sign 
22 
your name? 
23 
A. Yeah. 
24 
Q. Nobody made you do that, right? 
25 
A. No. 
0391 
1 
Q. You did it voluntarily. 
2 
A. Yeah. 
3 
Q. Thought it was funny? 
4 
A. Yeah. 
5 
Q. And you left it there for Mr. Epstein. 
6 
A. Yeah. 
7 
Q. Telling him, call me for a good time. 
8 
MR. MERMELSTEIN: Objection, form. 
9 
BY MR. LUTTIER: 
10 
Q. Right? 
11 
A. Yeah. 
12 
Q. And that's what you wanted him to do, was 
13 
to keep calling and have you come over, wasn't it? 
14 
MR. MERMELSTEIN: Objection to form. 
15 
BY MR. LUTHER: 
16 
Q. Isn't that right? That's the truth, isn't 
17 
it? 
18 
A. That I wanted him to keep calling me? 
19 
Q. Yeah, and you wanted to keep going there; 
20 
isn't that the truth? 
21 
A. I knew he was going to keep calling me. 
22 
He told me I was his favorite in Florida, so it 
23 
wasn't something that I, ever crossed my mind. 
24 
Q. And you wanted him to keep calling you and 
25 
you wanted to keep going; isn't that the truth? 
0392 
1 
MR. MERMELSTEIN: Objection, objection to 
2 
form, asked and answered. 
3 
BY MR. LUTHER: 
4 
Q. Isn't that the truth, ma'am? 
11 le:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PMI 
EFTA00725683

5 
MR. MERMELSTEIN: Objection. 
6 
THE WITNESS: That -- yes. 
7 
BY MR. LUTTIER: 
8 
Q. And the only reason you quit goiusto 
9 
Jeffre E stein after you were already a 
at 
was because you found out the police 
I I 
were investigating him and they showed up at 
12 
and interviewed you; isn't that true? 
13 
MR. MERMELSTEIN: Objection to form. 
14 
THE WITNESS: No. I got in touch with. 
15 
Wait. Ask the question again. 
16 
BY MR. LUTTIER: 
17 
Q. The only reason you quit going to Jeff. 
18 
i stein was because the police showed up at 
19 
and interviewed you. 
20 
A. No, because I was still, Jeffrey was still 
21 
renting me a car. After I knew the police were 
22 
going to everybody and interviewing questions, like 
23 
he had rented me. 
24 
(Brief telephone interruption.) 
25 
THE WITNESS: I was still talking to him 
0393 
1 
after he was interviewing cops. I still talked 
2 
to him after I got interviewed by the cops. I 
3 
talked to him about -- I talked to his lawyers. 
4 
BY MR. LUTTIER: 
5 
Q. Well, why didn't you go back and give him 
6 
more massages after you got interviewed by the --
7 
A. Because he, like, he wasn't even -- he 
8 
didn't stay at his Palm Beach house. He like -- I 
9 
don't even know where he was at. 
10 
Q. You would have gone if he had asked you to 
11 
come back and give him a massage, wouldn't you? 
12 
MR. MERMELSTEIN: Objection to form. 
13 
Calls for speculation. 
14 
BY MR. LUTTIER: 
15 
Q. Would you have gone back? 
16 
A. I don't know. Probably more than likely. 
17 
I don't know. 
18 
Q You would have --
19 
A 
I thought he was my friend. 
20 
Q He never did anything to you, right? 
21 
MR. MERMELSTEIN: Objection to form. 
22 
BY MR. LUTTIER: 
23 
. He didn't do anythin compared to what 
24 
did to ou 
25 
0394 
1 
MR. MERMELSTEIN: Objection to form --
2 
MR. LUTTIER: -- treated you like dirt --
3 
MR. MERMELSTEIN: -- argumentative. 
4 
BY MR. LUTTIER: 
5 
Q. Right? He never did anything like that to 
6 
you, did he? 
file:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.%2Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 
EFTA00725684

7 
MR. MERMELSTEIN: Objection. 
8 
BY MR. LUTTIER: 
9 
Q. And what you want in this lawsuit is 
10 
money, right? 
11 
A. No. 
12 
Q. That's why you sued him was for money. 
13 
A. No. 
14 
Q. And you were offered money to settle the 
15 
suit, but you don't want that. You want more money; 
16 
isn't that right? 
17 
A. No. 
18 
MR. MERMELSTEIN: Objection. 
19 
BY MR. LUTTIER: 
20 
Q. Well, if you don't want money, what are 
21 
you suing for? 
22 
A. For him to get punished. 
23 
Q. That's the only thing you can get in this 
24 
case is money, right? Your lawyers have explained 
25 
that to you, haven't they? 
0395 
1 
MR. MERMELSTEIN: Objection to form. 
2 
Don't talk about what your lawyers have 
3 
explained to you. 
4 
BY MR. LUTTIER: 
5 
Q. That's the only thing you can get. Are 
6 
you under the impression that you can get some kind 
7 
of relief here other than money? 
8 
MR. MERMELSTEIN: Objection to form. 
9 
THE WITNESS: No. It's not for me. It's 
10 
so that he can get punished for things that 
11 
he's done to me and several other girls. 
12 
MR. LUTTIER: Let me show you the next 
13 
exhibit. What number is this? 
14 
THE COURT REPORTER: Five. 
15 
MR. LUTTIER: Okay. 
16 
(Defendant's Exhibit No. 5 was marked for 
17 
identification.) 
18 
BY MR. LUTTIER: 
19 
Q. Let me show you what's been marked as 
20 
Exhibit 5. It's entitled Psychological/Social 
21 
History. Do you recognize that document? 
22 
A. Yeah. 
23 
Q. Is that your handwriting on it? 
24 
A. Yeah. 
25 
Q. Is this a document that you completed? 
0396 
1 
A. Yeah. 
2 
And did you complete it ort-
3 
4 
A. Yeah. 
5 
Q. And do you remember why you completed this 
6 
document? 
7 
A. Yeah. 
8 
Q. Why? 
11 le:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PMl 
EFTA00725685

9 
A. Because I was, had an appointment with 
10 
11 
Q. Okay. Were all of the answers that you 
12 
gave on this document true and correct? 
13 
MR. MERMELSTEIN: Look at them carefully. 
14 
(Ms. Doe and Mr. Mermelstein were 
15 
conducting a discussion off the record.) 
16 
THE COURT REPORTER: Is this off the 
17 
record? 
18 
MR. MERMELSTEIN: Well, we're kind of on 
19 
the record right now. So, have you read all 
20 
these? 
21 
THE WITNESS: No. I mean there's a few 
22 
that I have questions about, you know. There's 
23 
a few that I have questions about that I am 
24 
kind of like, I am looking at this now and I am 
25 
like --
0397 
1 
MR. MERMELSTEIN: Anything you need to 
2 
clarify. I think was -- what was the question? 
3 
BY MR. LUTHER: 
4 
Q. My question was are all of the answers 
5 
that you gave on this document true and correct? 
6 
MR. MERMELSTEIN: So, now that's just Page 
7 
1. The whole thing. 
8 
BY MR. LUTHER: 
9 
Q. Well, I should -- let me rephrase that. 
10 
Were all the answers that ou ave on this document 
11 
true and correct as o 
or 
12 
whatever date you completed this document? 
13 
A. On this one? 
14 
Q. Yeah. 
15 
MR. MERMELSTEIN: Okay. Go through each 
16 
page and look at that and refresh your mind. 
17 
BY MR. LUTHER: 
18 
Q. In all due respect, the answer is yes or 
19 
no. You can't really consult with your lawyer about 
20 
it. 
21 
MR. MERMELSTEIN: If you're confused by 
22 
something then, then you have to qualify your 
23 
answer. 
24 
THE WITNESS: Okay. 
25 
MR. MERMELSTEIN: But, okay. 
0398 
1 
THE WITNESS: Is everything -- well, 
2 
there's one thing --
3 
MR. MERMELSTEIN: The question is, is 
4 
everything true and correct, that's, that's 
5 
written here, each page. 
6 
THE WITNESS: Well, I am going -- I 
7 
already know the answer to that question. I 
8 
have only gotten to the second page. 
9 
MR. MERMELSTEIN: Do you want to give your 
10 
answer and then you can go or --
file:///CyDocuments%20and%20Settings/Production/Desktop/Doe%20No.%204.%2Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM! 
EFTA00725686

11 
THE WITNESS: Yeah, well, it says, did you 
12 
ever get in trouble while in school? Well 
13 
yeah, when I was in high school I 
14 
but I had circled no. But yeah, when I was in 
15 
high school I got in trouble. 
16 
BY MR. LUTTIER: 
17 
. Well, was this paper given to you by 
18 
to complete? 
19 
A. Yeah. 
20 
Q. Did he tell you to give honest --
21 
A Yeah. 
22 
Q -- and truthful answers? 
23 
A. Yeah. 
24 
Q. Well, why didn't you give him honest and 
25 
truthful answers? 
0399 
1 
MR. MERMELSTEIN: Objection, form. 
2 
THE WITNESS: Because if you, if you read 
3 
up above, it says how far did you go in school. 
4 
MR. LUTTIER: Right. 
5 
THE WITNESS: I said attended college, but 
6 
did no graduate college. So I am guessing, 
7 
like, whenever I looked at this it said did you 
8 
ever get in trouble while in school, I think 
9 
while I was in college. I think my mind frame 
10 
was set to college, not in high school. And 
11 
that's why I'm looking at this now and I'm 
12 
thinking, well, I know in high school I got 
13 
into trouble. So, I know that's not true. 
14 
MR. LUTTIER: Well, did you --
15 
THE WITNESS: And, like, whenever I look 
16 
at something, after reading 17, it says, like, 
17 
I am thinking, I was just thinking while I was 
18 
in college. I don't know. 
19 
BY MR. LUTTIER: 
20 
Q Did 
ask you after you completed 
21 
this, didn't he ask you whether you had any 
22 
questions about it? 
23 
A. I don't remember. 
24 
Q. Did you tell him you had questions and 
25 
didn't understand any of these? 
0400 
1 
A. No, I don't remember. 
2 
Q. Did you tell him any of the answers 
3 
weren't right? 
4 
A. No, I don't remember. 
5 
Q. So, how is somebody supposed to know 
6 
whether you're telling the truth or lying? 
7 
MR. MERMELSTEIN: Objection to form, 
8 
argumentative. 
9 
BY MR. LUTTIER: 
10 
Q. How do, how does one know on what 
11 
occasions you're telling the truth and when you're 
12 
lying about something? 
file:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 P141 
EFTA00725687

13 
MR. MERMELSTEIN: Objection to form, 
14 
argumentative. 
15 
BY MR. LUTTIER: 
16 
Q How does somebody know? 
17 
MR. MERMELSTEIN: Objection. 
18 
THE WITNESS: They should know. 
19 
BY MR. LUTTIER: 
20 
Q. Well, first of all, you talked to the 
21 
police under oath, and you're telling us you lied to 
22 
th 
Police, right? 
23 
MR. MERMELSTEIN: Objection, asked and 
24 
answered. 
25 
0401 
1 
BY MR. LUTTIER: 
2 
Q. Is that right? That's what you're telling 
3 
us. 
4 
MR. MERMELSTEIN: Asked and answered. 
5 
THE WITNESS: Yeah. 
6 
BY MR. LUTTIER: 
7 
Q. So, we don't really know, even when you're 
8 
under oath, whether you're telling the truth or 
9 
you're lying, do we? 
10 
A. No. 
11 
MR. MERMELSTEIN: Objection. 
12 
BY MR. LUTTIER: 
13 
Q. Okay. All right. So what other answers 
14 
are, do you say are incorrect on here, 
15 
notwithstanding the fact, that you gave to 
16 
after he told you to answer truthfully? 
17 
MR. MERMELSTEIN: I'm going to object to 
18 
the form of that question. 
19 
THE WITNESS: It says have you had any 
20 
major changes in income during the last two 
21 
years. 
22 
BY MR. LUTTIER: 
23 
Q. What number is that? 
24 
A. Thirty. 
25 
Q. Okay. 
0402 
1 
A. I said no, but durin the summers I worked 
2 
at, like, I worked at 
so I made a 
3 
little bit of money, but I put no because if you 
4 
read the question, it says no, increasing 
5 
significantly or decrease significantly. I only had 
6 
a summer job. 
7 
Q. Okay. Well, in 39 you reflect that you 
8 
had a summer job, right? 
9 
A. I'm sorry. I didn't read that far. 
10 
THE WITNESS: Can I ask a question? Yes, 
11 
or no? 
12 
MR. MERMELSTEIN: Huh? 
13 
THE WITNESS: Can I ask you a question? 
14 
MR. MERMELSTEIN: You really can't. 
11 le:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 
EFTA00725688

15 
THE WITNESS: Okay. 
16 
MR. MERMELSTEIN: Again remember to keep 
17 
in mind what the question was that he 
18 
originally asked about. 
19 
THE WITNESS: Uh-huh. How would you --
20 
BY MR. LUTTIER: 
21 
Q. What number? 
22 
A. Fifty-five, how would you describe your 
23 
illegal drug usage. I said I never used drugs. 
24 
Q. That wasn't true, was it? 
25 
A. No. 
0403 
1 
Q. You lied to 
right? 
2 
A. Yes. 
3 
Q. What should the answer have been? 
4 
A. I didn't --
5 
MR. MERMELSTEIN: Objection, that's been 
6 
asked and answered. 
7 
BY MR. LUTTIER: 
8 
Q. What should the answer have been of those 
9 
choices? 
10 
A Well, out of all those choices, it would 
11 
be two. 
12 
. Once or twice a year? And you didn't want 
13 
to know that, did you? 
14 
A. No. 
15 
Q. You knew when you answered that question 
16 
you were giving him a false answer, didn't you? 
17 
A 
It was --
18 
MR. MERMELSTEIN: Objection. 
19 
BY MR. LUTTIER: 
20 
Q. You knew that when you answered the 
21 
question you were giving a false answer, didn't you? 
22 
MR. MERMELSTEIN: Objection to form. 
23 
THE WITNESS: Yeah. 
24 
MR. LUTTIER: Okay. 
25 
MR. CRITTON: You know, you could all go 
0404 
1 
off the record. 
2 
MR. MERMELSTEIN: I suppose. 
3 
MR. CRITTON: We're just burning up tape 
4 
there. Just go ahead and finish looking. 
5 
MR. MERMELSTEIN: Are you ready? 
6 
THE WITNESS: No. 
7 
MR. LUTTIER: Did you have a question? 
8 
MR. MERMELSTEIN: Well --
9 
THE WITNESS: If he's going to leave, can 
10 
I use the bathroom? 
11 
MR. LUTTIER: Well, no, I am not going to 
12 
leave. Okay. Go ahead. 
13 
MR. MERMELSTEIN: Yeah, because it's kind 
14 
of a question pending, so let's, let's just 
15 
finish this and then you can go to the 
16 
bathroom. 
file:///CyDocuments%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM! 
EFTA00725689

17 
THE WITNESS: 
18 
19 
20 
BY MR. LUTTIER: 
21 
22 
A. 
23 
Q. 
24 
A. 
25 
Q. 
0405 
1 
A. Yeah. 
2 
. And ou knew when this uestion was asked 
3 
tha 
4 
didn't you? 
5 
A. Yeah. 
6 
Q. So you knew you were giving 
a 
7 
false answer. 
8 
A. Yeah. 
9 
You didn't want him to know 
10 
. did you? 
11 
A. 1 didn't want anybody to know. 
12 
Q. You didn't want him to know because ou 
13 
were
 to have to tell him 
14 
weren't you? 
15 
MR. MERMELSTEIN: Objection, 
16 
argumentative. 
17 
BY MR. LUTTIER: 
18 
Q And you didn't want to have to do that; 
19 
isn't that right? 
20 
A Yeah. 
21 
MR. MERMELSTEIN: Objection. 
22 
MR. CRITTON: Just so you know, you're not 
23 
getting it because she's got the paper in front 
24 
of her face. 
25 
MR. LUTTIER: Yeah, you have that. 
0406 
1 
BY MR. LUTHER: 
2 
You didn't want to tell 
that 
3 
4 
, right? 
5 
A. Yeah. 
6 
Q. And you didn't want to have to tell him 
7 
that, right? 
8 
MR. MERMELSTEIN: Objection to form. 
9 
THE WITNESS: Yeah. 
10 
BY MR. LUTHER-
11 
Q. 
12 
A. Yeah. 
13 
Q. 
14 
A. Yeah. 
15 
Q. 
16 
A. Yeah. 
17 
18 
file:///CyDocuments%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM! 
EFTA00725690

19 
MR. MERMELSTEIN: Think about the question 
20 
before you answer. Objection to form. 
21 
THE WITNESS: Yeah. 
22 
BY MR. LUTTIER: 
23 Sr
24
25 
A. Yeah. 
0407 
2 
3 
A. (No verbal response.) 
4 
5 
BY MR. LUTTIER: 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
BY MR. LUTHER: 
19 
20 
21 
22 
23 
THE WITNESS: 
24 
MR. MERMELSTEIN: Objection. 
25 
0408 
1 
BY MR. LUTHER: 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
13 •
12 
14 
A. No. 
15 
Q. Have you now told me all the questions you 
16 
answered false? 
17 
A. What was --
18 
Q. Have you now told me each of the questions 
19 
that appear in this exhibit that you answered false, 
20 
falsely? 
MR. MERMELSTEIN: Objection to form. 
MR. MERMELSTEIN: Objection to form. r
THE WITNESS: 
file:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 
EFTA00725691

21 
A. Yeah. 
22 
Q. Well let's look at Question 52. Question 
23 
52 says which of the following have you used. And 
24 
it refers to 12 different drugs. What did you 
25 
answer? 
0409 
1 
A. I stated that one. I already said that. 
2 
Q. And what should the answer -- you, you 
3 
wrote none, right? 
4 
A. Right. 
5 
Q. Or you circled it. And what should it 
6 
have been? 
7 
A. Cocaine. 
8 
Q. That would be two. What else? 
9 
A. Marijuana. 
10 
Q. Nine. What else? 
11 
MR. MERMELSTEIN: You've got the paper in 
12 
front of your face again. You might want to 
13 
try to hold it down just a bit. 
14 
BY MR. LUTTIER: 
15 
Q. Two and nine and what else? 
16 
A. What is barbit -- what is --
17 
Q. Barbiturates. 
18 
A. Yeah, what are those? 
19 
. So if you didn't know, you would ask 
20 
what that meant? 
21 
MR. MERMELSTEIN: Objection to form. Go 
22 
ahead and try. 
23 
BY MR. LUTTIER: 
24 
Q. At least two of these drugs you'd used, 
25 
you knew you'd used, and you just, you just gave a 
0410 
1 
false answer to 
right? 
2 
A. Yeah, I already told you that I --
3 
Q. Okay. Let's take --
4 
A. -- already told you that. 
5 
Q. Let's take 53. The question was, have you 
6 
ever, have you ever felt there was a time you drank 
7 
too much alcohol. You answered, yes, on one 
8 
occasion. 
9 
A. Yeah. 
10 
Q. That wasn't truthful, was it? 
11 
A. Actually, I drank alcohol on more than one 
12 
occasion. It didn't ask me if I ever thought I did. 
13 
Q. It says, have you ever felt there was a 
14 
time you drank too much alcohol, and you had four 
15 
choices. One of the choices was, yes, on several 
16 
occasions, one was yes on more than several 
17 
occasions. But you answered, yes, on one occasion. 
18 
That's a false answer, wasn't it? 
19 
A. No. 
20 
Q. There was more than one time in your life, 
21 
prior to the time you answered this that you felt 
22 
you drank too much, wasn't there? 
file:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.%2Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 
EFTA00725692

23 
A. Apparently not at that time, no. 
24 
Q. You'd been drunk a bunch of times before 
25 
you answered this, weren't you? 
0411 
1 
MR. MERMELSTEIN: Objection to form. 
2 
THE WITNESS: Have you ever drank too much 
3 
alcohol? No, I -- yeah, I drank, but never got 
4 
to the point where I was, like, wasted. 
5 
BY MR. LUTTIER: 
6 
Q. You got completely drunk on more than one 
7 
occasion before this? 
8 
A. Yeah. I mean --
9 
MR. MERMELSTEIN: Objection to form. 
10 
BY MR. LUTTIER: 
11 
Q. Just so we're clear, you didn't think that 
12 
meant that, that there was a time when you drank too 
13 
much alcohol, those occasions when you got 
14 
completely drunk? 
15 
A. I drank more -- yeah, I drank before, but 
16 
I guess, I am sorry, yeah. 
17 
Q. Okay. And then over on No. 57, it says --
18 
or 87, I'm sure, what is the primary problem 
19 
bothering you. You answered other. So none of the 
20 
first 13 items applied, but there was some other 
21 
that you answered, but you didn't say what the other 
22 
was, right? 
23 
A. Yeah. 
24 
Q. Okay. That was a truthful answer, right? 
25 
A. Yeah. 
0412 
1 
Q. And then 88 says, how long ago did you 
2 
begin to be troubled by this problem, and you had 
3 
circled, does not apply, and then you crossed that 
4 
out. And you just didn't answer that question, 
5 
right? 
6 
A. I didn't answer it. 
7 
Q. And then 89, rank the degree to which this 
8 
problem has affected your life. You initially had 
9 
circled a little, and then you changed it to does 
10 
not apply, correct, meaning that whatever problem it 
11 
was wasn't a problem that affected your life, 
12 
correct? 
13 
MR. MERMELSTEIN: Objection, form. 
14 
THE WITNESS: No. 
15 
BY MR. LUTTIER: 
16 
Q. Why do you say it doesn't apply then? 
17 
MR. MERMELSTEIN: Same objection. 
18 
THE WITNESS: I don't know. 
19 
BY MR. LUTTIER: 
20 
Q. What did you mean by that when it said 
21 
rate the degree to which this problem has affected 
22 
your life, and you answered, does not apply. What 
23 
did you mean? 
24 
A. I don't know why I didn't answer it. I 
file:///q/Documents%20and%20Senings/Production/Desktop/Doe%20No.%204.1620Jane%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 P141 
EFTA00725693

25 
don't know why I didn't answer that question. 
0413 
1 
Q. Well, you answered it. You answered with 
2 
a specific answer does not apply. So, what were 
3 
you telling 
4 
A. It means that I don't want to answer that 
5 
question. 
6 
MR. MERMELSTEIN: Objection to form. 
7 
BY MR. LUTHER: 
8 
Q. Mean what? 
9 
A. That I don't want to answer that question. 
10 
Q. Well, it doesn't say I don't want to 
11 
answer. It says it doesn't apply. 
12 
MR. MERMELSTEIN: Objection. 
13 
THE WITNESS: That's what I, that's 
14 
what --
15 
MR. MERMELSTEIN: Objection. 
16 
THE WITNESS: Meaning I don't want to 
17 
answer that question. 
18 
BY MR. LUTTIER: 
19 
Q. Well, let's look at the next one, No. 90. 
20 
How often do you experience this problem? Again you 
21 
answered, does not apply, correct? 
22 
A. Yeah. 
23 
Q. Again you're saying it has no application 
24 
to your life; isn't that right? 
25 
MR. MERMELSTEIN: Objection to form. 
0414 
1 
THE WITNESS: No. 
2 
BY MR. LUTTIER: 
3 
Q. Then the next one says what other kinds of 
4 
problems are bothering you, and there's 14 specific 
5 
items listed. You didn't answer any of those, and 
6 
you answered No. 15 does not apply. 
7 
A. Yeah. 
8 
Q. Indicating that none of those things 
9 
applied as a problem that was bothering you. 
10 
MR. MERMELSTEIN: Objection. 
11 
THE WITNESS: Because I don't want to 
12 
answer that question. 
13 
BY MR. LUTHER: 
14 
Q. 
15 
A. It doesn't mean that the don't a 
I . 
16 
17 
18 
A. I don't know. 
19 
Q. 
20 
A. I don't know. 
21 
Q. You have no knowledge about them? 
22 
A. No. 
23 
Q. Okay. And what drugs do you know from 
24 
your own personal knowledge that Jane Doe No. 7 has 
25 
used? 
0415 
file:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.%2Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 
EFTA00725694

1 
A. I don't know. 
2 
Q. None? You don't know of any drugs that 
3 
Jane Doe No. 7 has used? 
4 
A. Maybe -- I don't know. 
5 
Q. Well, let's make sure we're clear here. 
6 
Are you telling me under oath that you don't know of 
7 
any drugs that Jane Doe No. 7 has used? 
8 
A. No, I don't know. 
9 
Q. Never seen her use any drugs? She's never 
10 
told you she used any drugs? You're sure? 
11 
A. Not like, hey, what kind of drugs do you 
12 
do. It's not like we're drug addicts. It's not 
13 
like --
14 
Q. My question is under oath whether you're 
15 
aware, either from drugs you've seen her use or what 
16 
she's told you drugs she's used? 
17 
A. I have seen her drink. 
18 
Q. Okay. 
19 
A. Maybe smoke pot, maybe. Other than 
20 
that --
21 
MR. MERMELSTEIN: Do you remember? 
22 
BY MR. LUTTIER: 
23 
Q. Well, what do you mean, maybe? 
24 
THE WITNESS: No, I don't remember. 
25 
MR. MERMELSTEIN: Okay. 
0416 
1 
BY MR. LUTTIER: 
2 
Q. Your testimony under oath is you've never 
3 
seen Jane Doe No. 7 smoke pot? 
4 
MR. MERMELSTEIN: No, no. 
5 
THE WITNESS: No, I didn't say I've never 
6 
seen her. I just don't remember. 
7 
BY MR. LUTTIER: 
8 
Q. You may have seen her smoke pot? 
9 
A. When I was in high school, I hung out with 
10 
her at high school parties. I don't remember. I 
11 
mean, everybody -- I don't know. I don't remember. 
12 
Q. My question is very simple. You may have 
13 
seen her smoke pot? 
14 
A. Yeah. 
15 
Q. What other drugs do you know that Jane Doe 
16 
No. 7 has used? 
17 
A. I don't know. 
18 
Q. Don't have any idea? 
19 
A. No. 
20 
Q. How about Jane Doe No. 3, what other 
21 
drugs, what drugs have you, do you know that Jane 
22 
Doe No. 3 has used? 
23 
A. Drinking and smoke pot. 
24 
Q. Any others? 
25 
A. No. 
0417 
1 
Q. Are you sure? 
2 
A. Yeah. 
file:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.%2Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 
EFTA00725695

3 
. Oka . 
4 
5 
r
A. I don't know. 
6 
7 
8 
A. I don't know. 
9 
Q. You filled out a health insurance or a 
I 0 
health questionnaire at 
saying that 
I I 
a friend of yours had MRSA. Do you know what MRSA 
12 
is? 
I 3 
A. Yeah, it's where you get like in the 
14 
hospital after having, like, surgery. 
15 
Q. And who are you referring to when you said 
16 
you had a friend that had MRSA? 
17 
A. 
18 
Q. 
19 
A. At his, yeah, or -- yeah. 
20 
Q. How about any of your girlfriends that 
21 
went to Jeffrey Epstein's, were you referring to any 
22 
of them as having MRSA? 
23 
A. No. 
24 
Q. Do you know about any of the girls that 
25 
went to Jeffrey Epstein having MRSA? 
0418 
1 
4 
A. No. 
No. 
2 
3 
5 
A. No. 
6 
Q. Have you suffered any economic loss; that 
7 
is, have you lost any money as a result of going to 
8 
see Jeffrey Epstein? And, obviously, you got paid 
9 
for what you went, but have you lost any money as a 
10 
result of going to see Jeffrey Epstein? 
11 
A. No. 
12 
Q. Okay. Do you know what a pimp is? 
13 
A. Yeah. 
14 
Q. A pimp is someone that gets paid money to 
15 
prostitute somebody or to, to facilitate the service 
16 
of a prostitute. Is that what you understand a pimp 
17 
is? 
18 
A. Yeah. 
19 
Q. Would you agree with me that you were, in 
20 
essence, acting as a im • that is you got paid 
21 
money for taking 
to Jeff Epstein? 
22 
MR. MERMELSTEIN: Objection, 
23 
argumentative. 
24 
THE WITNESS: Yeah. 
25 
0419 
1 
BY MR. LUTTIER: 
2 
Q. And were you a prostitute at one time? 
3 
A. No. 
4 
MR. MERMELSTEIN: Objection, form. 
11 le:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PMI 
EFTA00725696

5 
BY MR. LUTTIER: 
6 
Q. Did you ever consider yourself to have 
7 
been a prostitute? 
8 
A. No. 
9 
Q. Okay. You mentioned that, you were 
10 
talking about Mr. Epstein, and one other event that 
11 
you said was, you said, I think to use your 
12 
language, he licked your clit. 
13 
A. Yeah. 
14 
Q. When did that occur? 
15 
A. It happened one time. 
16 
Q. Was it afte 
17 
A. 
18 
Q. Of high school? 
19 
A. Yeah. 
20 
Q. How do you know it was in 
21 
in high school? 
22 
A. Because after that moment, I said I never, 
23 
never again. 
24 
Q. Never what again? 
25 
A. Like he is not, like, licking my clit. 
0420 
1 
Q. Did he ask you --
2 
A. He kept begging me. 
3 
Q. Did he ask you to lick your clit? 
4 
A. Yeah, he kept begging me. 
5 
Q And did you --
6 
A Finally, I gave in. 
7 
Q. Did you say, no? 
8 
A. No. 
9 
Q. Had you said --
10 
A. Yes, I said no. And finally I said, yes. 
11 
Q. Had you said no on prior occasions? 
12 
A. No. 
13 
Q. He never asked you to lick your clit prior 
14 
to the time that, that he did it the first time? 
15 
A. No. 
16 
Q. Okay. So the first time he asked to lick 
17 
your clit, you said okay? 
18 
A. No, I said no. And then he kept begging 
19 
me and asking me to lick it that day. And finally 
20 
after saying no, like, three or four times, I said, 
21 
okay. 
22 
Q. Okay. So every time you said no, he 
23 
didn't do it, right? When you said no, he didn't 
24 
lick your clit? 
25 
A. Yeah. 
0421 
1 
Q. And then when you said yes, then you say 
2 
he licked your clit? 
3 
A. Yeah. 
4 
Q. And for how long did this go on? 
5 
A. A couple of seconds. 
6 
Q. A couple of seconds. Now, you had had 
file:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 
EFTA00725697

7 
your clit licked before that event, had you not? 
8 
A. Yeah. 
9 
Q. 
had done it, right? 
10 
A. Yeah. 
11 
Q. Other boys had done it, right? 
12 
A. No. 
13 
MR. MERMELSTEIN: Objection. 
14 
BY MR. LUTTIER: 
15 
Q. And, and then, while he was licking your 
16 
clit, did you tell him you wanted him to stop? 
17 
A. Yeah. 
18 
Q. And did he stop? 
19 
A. Yeah. 
20 
Q. Okay. And when you say he licked your 
21 
clit, did he penetrate your vagina or just lick your 
22 
clitoris? 
23 
A. No, he licked my cult. 
24 
Q. Okay. And, and how were you positioned at 
25 
the time that this happened? 
0422 
1 
A. I was standing. There was a massage table 
2 
to the right of me and there was a couch to the left 
3 
of me, and I had my right leg lifted up on the 
4 
massage table, and he was on his knees. 
5 
Q. So, you had positioned yourself for this? 
6 
A. Yeah, I was -- yeah, I guess. I didn't 
7 
position it for me to go like that. He kept begging 
8 
me and begging me. 
9 
Q Well, you --
10 
A Yeah, well, then, yes, I did. 
11 
Q. You had to put your leg up on the massage 
12 
table, right? 
13 
A. Yeah. 
14 
Q. And open up your vagina, right, your 
15 
legs --
16 
MR. MERMELSTEIN: Objection. 
17 
BY MR. LUTTIER: 
18 
Q 
so he could lick your clit, right? 
19 
MR. MERMELSTEIN: Objection. 
20 
BY MR. LUTTIER: 
21 
Q. That took you some time to do, right? 
22 
A. Yeah. 
23 
Q. So you did all that voluntarily. right? 
24 
A. Yeah. 
25 
Q. You could have said, no, and that would 
0423 
1 
have been the end of it, right? 
2 
A. Yeah. 
3 
Q. You -- at any time while you were going to 
4 
see Jeffrey Epstein, you could have just said, no, 
5 
I'm not going back anymore, couldn't you? 
6 
A. Yeah. 
7 
Q. Nobody coerced you to do it. You were 
8 
going voluntarily, correct? 
11 le:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.%2Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PMI 
EFTA00725698

9 
A. Yeah. 
10 
. Oka . 
I I 
12 
1 3 
A. No. 
14 
Q. Wh not? 
Ii 
A. 
16 
17 
Q. Did you, you told 
that you were 
18 
uncomfortable with, what you referred to as, your 
19 
body. I think the words used was "down there"; do 
20 
you remember that? 
21 
A. Yeah. 
22 
Q. Are you talking about your vagina or your 
23 
crotch area? 
24 
A. Yeah. 
25 
Q. Okay. And you said you'd been 
0424 
1 
uncomfortable with it for some period of time. 
2 
A. Yeah. 
3 
Q. And you said that it didn't -- you, 
4 
something about you looked at other girls and you 
5 
thought yours looked different or something like 
6 
that? 
7 
A. Yeah. 
8 
Q. What is it you're referring to? 
9 
A. The way that my vagina is shaped compared 
10 
to other girls. 
11 
Q. And what is it that's different about your 
12 
vagina that's --
13 
A. My lips are a lot larger than other girls' 
14 
lips are. They come out more, and that's why 
15 
Jeffre E stein said that I was his favorite girl in 
16 
17 
Q. Okay. And, and that's been true your 
18 
whole life? 
19 
A. Uncomfortable? Yeah. 
20 
Q. Didn't prevent you from having sex with 
21 
other men, right? 
22 
A. You mean with =? 
23 
Q. With anybody else. Your lawyer hadn't let 
24 
you answered about the other people you've had sex 
25 
with. 
0425 
1 
A. Maybe that's -- maybe that's why I've been 
2 
with him for on and off with him for five or six 
3 
years. So yeah, I was uncomfortable with other 
4 
guys. 
5 
Q. Your current boyfriend, you had sex with 
6 
him, right? 
7 
A. After being with somebody that's abused me 
8 
for like seven year, five years, do you think I'm 
9 
comfortable -- do you think I would go back to being 
10 
with him if I was comfortable with my body? 
file:///CyDocuments%20and%20Seitings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 
EFTA00725699

11 
MR. MERMELSTEIN: Take it easy. Answer 
12 
the question. 
13 
BY MR. LUTTIER: 
14 
Q. By the way, even after you went and got an 
15 
injunction against domestic violence because of all 
16 
the horrible things that 
did, you 
17 
the 
18 
19 
20 
21 
22 
23 
24 
A. 
25 
Q. 
042 
1
2 
A. Yeah. 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
Yeah 
MR. MERMELSTEIN: Ob'ection. 
THE WITNESS: 
BY MR. LUTHER: 
Objection, form. 
MR. MERMELSTEIN: 
BY MR. LUTHER: 
Q. Is that right? 
A. Yeah. 
Q. I mean, wouldn't -- have you discussed 
that with this s chiatrist that ou said ou had 
one
 in 
9 
A. 
Q. Yeah. Have you talked to him a little bit 
about that? 
A. I haven't got a chance to. 
25 
Q. Well, how many times have you been to him? 
0427 
1 
A. Well, yeah, I mean, I don't remember. We 
2 
talked about several different things. So I am 
3 
sure, yeah. 
4 
Q. How many times have you been to him? 
5 
A. How many times have I been? 
6 
7 
A. To 
? 
Q. Yeah how man times have you been to him? 
8 
Q. Yeah. 
9 
A. Yeah. I don't know, but I have been going 
10 
there sinceM, maybe once or twice a week I've 
11 
been going to see him. I don't know, maybe • 
12 
times. 
file:///CyDocuments%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM! 
EFTA00725700

13 
Q. Have you, has everything that you told him 
14 
been the truth? 
15 
A. Yes. 
16 
Q. I'm going to tell you, we're going to get 
17 
his records. 
18 
A. Yeah. 
19 
Q. All right. And have you told him the 
20 
whole truth? 
21 
A. Yeah. 
22 
MR. MERMELSTEIN: Objection. 
23 
BY MR. LUTTIER: 
24 
Q. Told him about 
right? 
25 
A. Yeah. 
0428 
1 
Q. Told him about =I? 
2 
MR. MERMELSTEIN: Objection. 
3 
BY MR. LUTTIER: 
4 
Q. Did you tell him 
was violent 
5 
towards you? Did you tell him that? 
6 
A. Yeah. 
7 
Q. Did you tell him everything that you've 
8 
told me in this deposition? 
9 
MR. MERMELSTEIN: Objection, form, 
10 
overbroad. 
11 
THE WITNESS: Not every single -- he knows 
12 
a broad, broad information about certain 
13 
things. 
14 
BY MR. LUTTIER: 
15 
Q. Okay. Who's paying his bill? 
16 
A. I am. 
17 
Q. Okay. And where is his office? 
18 
A. 
19 
How would you get toM 
20 
• 
to get this fellow 
? How did you get 
21 
to him? Who referred you to him? 
22 
A. I have somebody that I -- my boyfriend's 
23 
mother. 
24 
Q. Who is that? 
25 
A. 
0429 
1 
Q. By the way, this guy that you had the 
2 
domestic violence with that you got arrested for --
3 
A. That was my ex-boyfriend. 
4 
5 
A. No, I live in 
Q. -- are you still livin with him? 
6 
. Did ou go hunting recently for 
7 
8 
A. Hunting for=? 
9 
Q Yeah. 
10 
A No. 
I I 
Q. Did you go try to find her at her place of 
12 
employment? 
13 
A. No. 
14 
Q. Do you know why anybody would say you were 
file:///q/Documents%20and%20Seitings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 P141 
EFTA00725701

15 
at her place of employment looking for her? 
16 
A. No. 
17 
Q. Do you -- do you know where she works? 
18 
A. Yeah. 
19 
Q. You know where she works, don't you? 
20 
Where does she work? 
21 
A. 
22 
Q. 
located where? 
23 
A. In 
24 
Q. Okay. And that's where you went Friday 
25 
night and the domestic violence thing, isn't it? 
0430 
1 
A. I didn't o there lookin for her. 
2 
3 
4 
5 
6 
7 
8 
9 
Q Did ou tell --
10 
A 
11 
12 
. Did you tell anybody when ou were at the 
13 
that you were working for 
9 
14 
A. No, I didn't even bring u 
name. 
15 
Q. Do you know why a message would have been 
16 
left if you were looking for her? 
17 
A. No, because I never even brought up her 
18 
name. 
19 
O. Okay. Now, you say -- what's this 
20 
or whatever this boyfriend's name is, 
21 
what's his mother's name? 
22 
A. 
23 
Q. 
(sic) what? 
24 
A. 
25 
Q. 
what? 
0431 
1 
A. I don't know her last name. She has been 
2 
remarried. 
3 
Q. Well, where do ou find this lady? 
4 
A. She lives in
. I don't 
5 
know. 
6 
Q. How, how is it, how is it you got ahold of 
7 
her? 
8 
A. I didn't get ahold of her. She didn't 
9 
tell me. She gave 
the, the name, and I got 
10 
the name throu h 
11 
11
13 
14 
15 
16 
A. Have I talked to her on the phone? Yeah. 
Q. Have you ever talked to her on the phone? 
file:///CyDocuments%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 
EFTA00725702