EFTA00750774

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-CIV-80119-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
VOLUME III 
Related cases: 
08-80232, 08-08380, 08-80381, 08-80994, 
08-80993, 08-80811, 08-80893, 09-80469, 
09-80591, 09-80656, 09-80802, 09-801092 
VIDEO-CONFERENCED AND VIDEOTAPED 
DEPOSITION OF JANE DOE 
Wednesday, September 30, 2009 
9:37 a.m. - 6:10 p.m. 
One Clearlake Centre 
250 South Australian Avenue, 1st Floor 
West Palm Beach, Florida 33401 
Reported By: 
Pamela J. Sullivan, RPR, FPR, CLR 
Prose Reporting Agency, Inc. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (6014334724662) 
Electronically signed by Pamela Sullivan (601-33S-772-1552) 
9205b62-38a5-4202-0350-6633a5c6813b 
EFTA00750774

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APPEARANCES 
On behalf of the Plaintiff. /me Deo 
BRAD J. EDWARDS, ESQUIRE 
ROTHSTEIN ROSENFELDT ADLER 
Lea au ON Cate, Suite 1650 
401 East Las Otat Beamed 
Fart Lade/dal. Hooch 33301 
0.1 behalf of the Defeedmu, kffrey Epstein: 
ROBERT D. CRITTON, 3R. ESQUIRE 
BURMAN, CIUTPON, CUTTER & COLEMAN, LIP 
9 
303 Behan Bculevard 
Suite 400 
10 
Nash him Bach Ronda 33401 
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On behalf efthe Deem/bet. Jeffrey *Kit 
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JACK ALAN OOLDBEROER, ESQUIRE 
ATTERBURY, GOIDBERGER & WESS, PA 
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250 AuMeliat Aram Sotth 
WM 1400 
Wall Pam Beach, FIceicla 334014012 
On WWI of Itbittiff r Related Carr No. 01680469: 
SIDRO M. GARCIA, ESQUIRE 
GARCIA LAW FIRM, PA 
224 Da ma Seth Suite 900 
11.1113401 
On behalf of hem Dom thmedh 
ADAM D. HOROV/ITZ, ESQUIRE 
MERMELSTEIN a HORMUZ P.A. 
1820$ Blimp* Boulevard 
Sulk, Z218 
Miami. Florida 33160 
Page 261 
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DESOUPTION 
PAGE 
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Page 263 
INDEX 
- - - 
%WINES& 
DIRECT 
CROSS REDIRECT RECROSS 
JANE DOE 
BY MR. CRITTON 5 
EXHIBITS MARKED 
Defendants No. 6 
390 
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(Plaintiffs AGSMs to Defendant's Interrogatories) 
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Defendants No. 7 
(Ur to Edwards from Critton %%Enclosures) 
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Marked off the record.) 
Page 262 
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On behalf of the Plaintiff CM.A.: 
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JACK P. HELL, ESQUIRE 
SEARCY DENNEY SCAROIA BARNHART & SHIPLEY, PA 
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2139 Palm Beach Lalces Boulevard 
West Pabn Beach, Oneida 33409 
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On 
o 
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ADAM J. LANGEt40, ESQUIRE 
LEOPOLD KINN 
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2925 PGA Boulevard, Sure 200 
Palm Beach Galas. Florida 33410 
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ALSO PRESENT: 
Jeffrey Epstein, via video conference 
Stm Sanders, Videograptier 
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Page 264 
PROCEEDINGS 
(Continued from Volume II of the same day.) 
BY MR. CRITTON: 
Q. Ms. Jane Doe, other than speaking with your 
attorney over the lunch hour, did you speak with anyone 
else? 
A. No. 
Q. Are you on any medication today? 
A. No. 
Q. 'When is the last time you had any pot, 
marijuana? 
MR. EDWARDS: Object to the form. 
BY MR. CRITTON: 
Q. And when I say had, smoke. 
A. Before I was pregnant with my daughter. 
Q. Okay. And its your testimony that, since 
the time you've been pregnant, you have not taken — you 
haven't smoked pot and you haven't taken any drugs or 
alcohol 
Tm sorry — any illegal and/or — any 
illegal drugs or prescription drugs that would have gone 
to someone else, like a Xanax; is that correct? 
MR. EDWARDS: Object to the form. 
THE WITNESS: What was the question? 
(561) 832-7500 
..2 (P.ages_2_61 to 264) 
PROSE COURT REPORTING AGENCY, INC. 
• 
• (561) 832-7506 
• 
Electronically signed by Pamela Sullivan (501.3357724652) 
Electronically signed by Pamela Sullivan (501-333-7724552) 
92eldb6248.5-42024360-6633a5e6813b 
EFTA00750775

Page 265 
BY MR. CARTON: 
2 
Q. Ifs your testimony that, since the time you 
3 
were pregnant, you haven't had any illegal drugs and/or 
4 
any drugs that weren't prescribed specifically for you? 
5 
A. Yes, that's true. 
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Q. Okay. And you -- and you have roxy. I asked 
7 
you earlier whether you knew what that was. My 
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understanding is you smoke that; is that correct? 
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MR. EDWARDS: Object to the form. 
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BY MR. CARTON: 
11 
Q. You — and it's a smokable drug? 
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MR. EDWARDS: Object to the form. 
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1HE WITNESS: I have heard of people eating 
14 
them and snorting them and smoking them and 
15 
shooting them up. 
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BY MR. CRITTON: 
17 
Q. Okay. And it's your testimony you've never 
18 
done those? 
19 
A. Yes. 
20 
Q. When is the last time you spoke with— well, 
21 
I asked you a question earlier: Who else was living 
22 
with you and your boyfriend, MI, 
and your child at 
23 
your house? And your attorney instructed you not to 
24 
answer. Do you remember that? 
25 
A. Yes. 
Page 267 
1 
Q. You need to keep your voice up, because Pm 
2 
having trouble hearing you, ma'am. 
3 
A. She's okier than me. 
4 
Q. Okay. And why did she live with you? 
5 
A. ;guess her mom was staying in a — in an 
6 
efficiency, I guess, with her bcSiend, and I guess 
7 
there really wasn't room for M. She didn't have 
8 
anywhere to live. 
9 
Q. And were you living at 
10 
house at the time? 
11 
A. Yes. 
12 
Q. Okay. And how long did M. live with you? 
13 
A. A month or two. 
14 
Q. AUSA. Since that 
other than that one 
15 
time, has 
ever lived with you again? 
16 
A. No. 
17 
Q. Has she ever stayed with you again? 
18 
A. No. 
19 
Q. Do you know where M. is right now? 
20 
A. No. 
21 
Q. When is the last time you talked to M.? 
22 
A. Several months ago. I'm not sure. 
23 
IIVOkay. And what was the event that caused you 
24 
and M. to not be close anymore? 
25 
A. She moved. 
Page 266 
1 
Q. Okay. Is the person who — is it more than 
2 
one additional person who is living with you at that 
3 
house? 
4 
A. No. 
5 
Q. Okay. Is that person still there now? 
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MR. EDWARDS: Don't answer. 
Other identifying information about the 
8 
address. I think it's — ifs pretty clear she's 
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not going to answer anything that's going to 
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indicate to you where' he's living currently. Now, 
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all other addresses, you know them, and she'll tell 
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you that. 
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MR. CARTON: I understand. So my position 
14 
is clear is that person that's been, apparently, is 
15 
living there, she, she would have information —
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she or he would have Information regarding aspects 
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of the Plaintiffs claim clearly is a relevant 
18 
witness, and —
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MR. EDWARDS: Okay. 1 understand. 
20 
BY MR. CRITTON: 
21 
Q. Has Ng ever lived with you? 
22 
A. Yes. 
23 
Q. Okay. When? 
24 
A. We were 14, I believe. She was 14, I was 13, 
25 
because she's older than I am. 
Page 268 
1 
Q. Just she moved? 
2 
A. She moved far away from me. I don't know 
3 
where. And I guess she — I don't know. I guess she 
4 
doesn't... 
5 
Q. Do you have her phone number? 
6 
A. No. 
7 
Q. Okay. Did you have it before she moved? 
8 
A. Yes. 
9 
. Have you — when you've talked to M., does 
10 
ever say,' -- I know where a. is, or I talked to 
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. the other day? 
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A. No. 
13 
Q. And tell me when the last time was that you 
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spoke with M, 
15 
A. Probably a month and a half, maybe two months 
16 
ago. 
17 
Q. Okay. Which would if we're in the end of 
18 
September, it would have been sometime in early or mid 
19 
July? 
20 
A. Yes. 
21 
Q. Okay. And did you only talk to her over the 
22 
phone? 
23 
A. We went to the beach. 
24 
Q. Did you take your respective children? 
25 
A. Yes. 
•.‘13, 
(561) 832-7500 
YacY•aa14,,V-
3 (Pages 265 to 268) 
PROSE COURT REPORTING AGENCY, INC.' 
(561) 832-7506 
Electronically signed by Pamela Sullivan (501-333-772.1552) 
Electronically signed by Pamela Sullivan (501.333-772.1552) 
92efSb62-38a5-4202-a350-6633a5c6813b 
EFTA00750776

Page 269 
1 
Q. Okay. And you talked about this case; didn't 
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you — your cases? 
3 
A. No, we did not 
4 
Q. Subject never came up, is your testimony? 
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k 
No. 
6 
Q. That's correct? 
7 
A. That is correct 
8 
Q. Other than that, have you seen or talked to 
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M.? 
10 
A. No. 
11 
Q. Okay. Well, didn't you baby-sit for MA 
12 
son? 
13 
A. Yes. 
14 
Q. Okay. When was that? 
15 
A. Ito not exactly sure. 
16 
Q. Wasn't that after you went to the beach, 
17 
approximately a month and a half to two months ago? 
18 
A. I don't remember if it was before or after. 
19 
Q. And did she drop 
how does — how — what 
20 
was the occasion that she asked you to sit for her son? 
21 
A. She had to wodc 
22 
Q. Where was she working? 
23 
A. I think she was working in like a — like a 
24 
skin care place. I'm not sure. 
25 
Q. How many times did you baby-sit for her son? 
Page 271 
1 
Q. Did M. ever tell you she was a call girl? 
2 
A. No. 
3 
Q. You know what a call girl is? 
4 
A. Yes. 
5 
Q. Did you ever ask M. if she was a 
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prostitute? 
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A. No. 
8 
Q. Did you ever ask 
how she made her money? 
9 
A. No. 
10 
Q. Is M. a prostitute? 
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A. Not that I know of. 
12 
Q. lies she am been a prostitute? 
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A. Not that J 'mow of. 
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Q. Do you consider yourself to be a prostitute? 
15 
A. No, l do not. 
16 
Q. Have you ever engaged in prostitution? 
17 
A. Besides Jeffrey Epstein, no. 
18 
Q. Well, what do you -- what do you consider a 
19 
prostitute to be? 
20 
A. Somebody who gets paid for giving sexual 
21 
favors. 
22 
Q. Separate and apart from any activities with 
23 
Mr. Epstein, have you ever performed or given sex, 
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sexual favors, using your term, for money? 
25 
A. No. 
Page 270 
1 
MR. EDWARDS: Object to the form. 
2 
BY MR. CRITTON: 
3 
Q. Or watch ber son? 
4 
MR. EDWARDS: Ever, you mean? 
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MR. CR1TfON: Ever. 
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MR. EDWARDS: Eva. Okay. 
7 
THE WITNESS: Probably like two or three 
8 
times. 
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BY MR. CRITTON: 
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Q. Did she pay you? 
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A. Yes. 
12 
Q. How much did she pay you? 
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A. Well, she only paid me once, like S20 or 
14 
something. 
' 
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Q. Would you let ■ 
watch your daughter? 
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A. Absolutely. 
17 
Q. Do you know M. to be or to have been a 
18 
prostitute? 
19 
A. No. 
20 
Q. You know what a prostitute is? 
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A. Yes, I do. 
22 
Q. Did ■ 
ever tell you that she received 
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money for giving sexual -- or performing sexual nets for 
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men? 
25 
A. No. 
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Page 272 
Q. Now, you've worked at some strip clubs; have 
you not? 
A. Yes. 
And ou worked at -down 
in 
A. Yes. 
Q. -- true? 
A. Yes. 
. 
. And I think you said you worked at 
for approximately eight months? 
A. Something Lice that, yes. 
Q. Who was your boss, or who was the manager or 
the person that you had to report to? 
A. The owner of the club was named 
Q. Do you know what his last name was? 
A. No, I do not. 
at• 
that you knew at the time you applied 
• 
get — was — was anyone working 
for the job, the position? 
A. Yes. 
Q. Who? 
A. 
. And how was it that you came to get a job at 
that is, why? 
A. Urn. 
(561) 832-7500 
4 (Pages 269 to 272) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (501433-772-1552) 
Electronically signed by Pamela Sullivan (501-333-772-1552) 
92ef5b62-35a54202-a350.6633a5c6813b 
EFTA00750777

Page 273 
1 
Q. This was in 2006? 
2 
A. It was after I was 18, so... I'm net sure 
3 
what year. 
4 
Q. Well, you were bo 
5 
A. Yes. 
6 
Q. Okay. 
7 
All right? So if you worked seven months there or eight 
8 
months, it would have been sometime after June — what 
9 
would you say your birthday was? 
10 
A. Seventeenth. 
11 
Q. All right. Sometime after June 17th of '06, 
12 
probably miming into sometime in '07; true? 
13 
A. Yes. 
14 
Q. And sole— 
what caused you to get the 
15 
job, or why did you come — why did you come to get a 
16 
job at 
17 
A. 
brought me there. 
18 
Q. Oksy. But your choice to go; right? 
19 
A. Yes. 
20 
Q. Okay. And what did you do — what did you 
21 
or how did it happen that you went to get the job? 
22 
was dancing there; you knew that? 
23 
A. Yes. 
24 
Q. Okay. And she was a stripper? 
25 
A. Yes. 
correct? 
Page 275 
1 
A. I was living with 
2 
Q. And were you living at the apartment? 
3 
A. Yes. 
4 
Q. That's when she was living with a 
5 
A. Yes. 
6 
Q. So you're living at the apartment, and thaim
7 
tia you started — you knew she was working a 
imp so she said, why don't you come with me, or 
9 
something like that? 
10 
A. Yes. But this was the second time that I 
11 
lived with her. 
12 
Q. I thought you said the second time was in 
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2007. 
14 
A. I just know that I had tuned 18 since I 
15 
started dancing, sol may have been close to 19 or 19 
16 
when I did start 
17 
Q. Okay. Well, now, was III living at the 
18 
Royal Palm Bellaire, or was she living in the 
19 
apartment with 
20 
A. TIslizal Palm Beach place was an apartment, 
21 
also, and 
also lived there. 
22 
Q. Okay. Well, you testified earlier that in 
23 
2006 you spent a few -- a few months with her. 
24 
A. Ult-huh. 
25 
Q. And then — and that was in the apartment in 
Page 274 
Q. Did she tell you how much money she made? 
2 
A. No. 
3 
Q. Did she tell you what she had to do to earn 
1 
money? 
5 
A. Dance. 
6 
Q. What else? 
7 
A. Take her clothes oft strip. 
8 
Q. All right. And did she — did she do — did 
9 
she do bachelor pasties? 
10 
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25 
A. Not that I know of. 
Q. Okay. Did she do lap dances? 
A. Yes. 
Q. All right. And did she work the stage? 
A. Yes. 
Q. Did table dances, as well? 
A. They don't have table dances. 
Q. What do they have? Lap dances? 
A. Yes. 
Q. And what did 
tell you about that work? 
A. She just told me that, like, you had to go on 
stage and dance, and that's how you made money, by 
dancing. 
Q. Did you say -- what were you doing at the 
time? Where were you living in 2006 when you had just 
turned 18? 
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Page 276 
West Palm Beach. And then the second time, 1 thought 
you said you only spent about a month. I may have been 
wrong. 
A. Yes, 1 did only spend about a month. 
Q. Okay. Was — and the one month was at the 
Royal Palm Beach house? 
A. Yes. 
Q. Okay. 
s ' 
r testimony that you 
went to work at 
in 2007?
A. That's possible. 
Q. Well, I don't know, because I wasn't there. 
That's why I'm just trying to ask. Because earlier you 
testified it was 2006, and I think that's what your 
answers to interrogatories reflect. So what is it? 
A. Well, it --
Q. What's the current answer? 
MR. EDWARDS: Object to the form. 
THE WITNESS: It was definitely after I 
armed 18. 1 don't know exactly what day it was. 
I don't know what month or year. I don't know. I 
don't like write down, I started stripping today. 
No, !didn't do that. 
BY MR. CRITTON: 
Q. Do you ever keep diaries? 
A. No. 
(561) 832-7500 
5 (Pages 273 to 276) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (601.333-772-1652) 
Electronically signed by Pamela Sullivan (501-333-772-1552) 
92et6b62-38a6-42024350-8833a6c6813b 
EFTA00750778

1 
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Page 277 
Q. Have you kept diaries? 
A No. Never. 
Q. Have you filed any tax returns? 
A. No. 
Q. Have you ever filed a tax retum? 
A. No. 
Q. Have you ever consulted anyone about whether 
you need to file a tax return? 
A. No. 
that
When you worked — so is it your recoiled ion 
. was living — or you were living with II. at 
Royal Palm, or West Palm, at the time you started 
stripping? 
A. Royal Palm. 
Q. What work — before you started stripping, 
what work had you ever done to make money, other than 
A. Tithes it. 
a.
... 
and I think you told me about 
A. Yes. 
Q. That was like a, what, a week or a month or 
something? 
A. A week. 
Q. Excuse tne. And that didn't work out; right? 
Page 279 
1 
Q. Okay. Because 
was when you were 17? 
A. Yes. 
3 
Q. So what other jobs did you — had you ever 
4 
applied for another job, other than I.? 
5 
A. Yes. 
6 
Q. Where? 
7 
A. At the mall. 
8 
Q. But no one had ever hired you? 
9 
A. No. 
10 
Q. So how many different places did you apply 
11 
for a job? 
12 
A. A few. Two or three, maybe. 
13 
Q. So you applied for the jobs. You didn't get 
14 
those. You quit the 
job voluntarily, because you 
15 
didn't like it; right? 
16 
A. Right. 
17 
Q. Because you weren't getting along with whom? 
18 
The boss? 
19 
A. No. 
20 
Q. Who? 
21 
A. It was actually M.'s brother that I was not 
22 
getting along with. 
23 
Q. What's his name? 
24 
A. 
25 
Q. nwhat? 
Page 278 
1 
A. Right. 
2 
Q. Okay. So the only odier'ob
u've had in 
3 
your entire life was working at E.? 
4 
A. Yes. 
5 
Q. OkaiyAnd why did you leave? Once you got 
6 
thejcb at 
as a waitress, why did you stop working 
7 
at Mr/ 
8 
A. ljust — I don't know. Ijust didn't want 
9 
to work there anymore. I guess I just wasn't getting 
10 
along with everybody. 
11 
Q. Okay. One month? 
12 
A. Yes. 
13 
Q. Okay. And you got salary or minimum wage? 
14 
A. Yes. 
15 
Q. Plus tips? 
16 
A- Yes. 
17 
Q. How much money did you make there? 
18 
A Not very much. 
19 
Q. All right. So now you're 18, or over 18, 
20 
maybe over — closer to 19. The onl 
er 
21 
had in your whole life is working at 
for minimum 
22 
wage and tips; right? 
23 
A. Yes. 
24 
Q. Had you been to 
yet? 
25 
A. Yes. 
Page 2.;Sfl 
1 
A. 
2 
Q. And why? Why weren't you getting along with 
3 
him? 
4 
A. Because he -- well, I thought that he stole 
5 
some money from the restaurant while I was working one 
6 
night. And he called me and said a bunch of nasty 
7 
things to me, because I was basically implicating that 
8 
he had stolen some money from the restaurant. 
. 9 
Q. Well, you believed it to be true? 
10 
A. Yes. 
11 
Q. Okay. And so what, what happened? 
12 
A. He was just like really rude to me all the 
13 
time, and ho told me that he was like — I — I mean, I 
14 
don't remember specifically what he said, but he told me 
15 
that, you lmow, he was going to like, you know, do 
16 
something to hurt me or my family. 
17 
Q. So you stopped working. Did you tell M. 
18 
that? 
19 
A. Yes, I did. 
20 
Q. And so how, then, did you get the strip job? 
21 
M. said, well, why don't you come with me; you can 
22 
strip. 
23 
A. Yes. 
24 
Q. And did you say, l don't really want to be a 
25 
stripper? 
6 (Pages 277 to 280) 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. ' 
(561) 832-7506 
Electronically signed by Pamela Sullivan (501-333-772-1652) 
Electronically signed by Pamela Sullivan (501.333.772-1552) 
9205662-36a5-4202-a350-6633a5c6813b 
EFTA00750779

Page 281 
1 
A. At first I did, yes. 
2 
Q. And so why did you do it? 
3 
A. Because I needed money. 
4 
Q. Well, you could have applied for other jobs; 
5 
couldn't you? 
6 
A. I tried to apply at a few places, and I never 
7 
got the job. 
8 
Q. Well, you applied for what, one or two places 
9 
in the mall? 
10 
A. I applied at some restaurants and some other 
11 
places I don't exactly remember. 
12 
Q. So you go down with 
to 
13 
A. Yes. 
14 
Q. And you talked to 1= 
15 
A. Yes. 
16 
Q. Is he the one who hired you? 
17 
A. Yes. 
18 
Q. Did you have any experience dancing. 
19 
stripping? 
20 
A. No. No. 
21 
Q. And what did you have to do in order to get 
22 
the job? 
23 
A. Show them my ID. 
24 
Q. And did he say, have you stripped before? 
25 
A. No. 
Page 283 
1 
Q. Where did you get them? 
2 
A. I got a lot of them from the flea market. 
3 
Q. 45th Street? 
4 
A. Yes. 
5 
Q. And they have stripper outfits'? 
6 
A. Yes. 
7 
Q. Did a 
show you any of her tricks of the 
8 
trade, so to 
, so you could make money? 
9 
A. She just showed me how to dance. 
10 
Q. Did she show you before you went up there 
11 
that fast time? 
12 
A. Yes. 
13 
Q. Where did you — did you practice at home —
14 
or at her home? 
15 
A. No. 
16 
Q Where did you practice, or didn't you? 
17 
A. 
18 
Q. So you
ill:Practice during the day before 
At 
19 
you actually ended up on stage? 
20 
A. Yes. 
21 
Q. Did you know any of the other girls who 
22 
worked at 
before you went? 
23 
A. No. 
24 
Q. Did you ever work at a place where -
25 
worked? 
1 
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8 
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Q. 
A. 
Q. 
A. No. 
Q. Did 
tell you how — show you how you'd 
have to dance, in order to make money? 
A. Yes. 
. Oka . During the time you worked at 
did you have a stage name, or did 
you just use your own name? 
A. Yes, I did. 
Q. Yes, you did what? Have a stage name? 
A. I had a stage name. 
Q. What was your stage name? 
MR. EDWARDS: Form. 
THE WITNESS: 
BY MR. CRITrON: 
Q. 
A. Yes. 
Q. Okay. And what kind of outfits did you wear? 
Did you have one outfit that was like the -- your 
trademark, so to speak? 
A. No. 
Q. What kind of outfits did you wear? 
A. Stripper outfits; I don't know. 
Page 282 
Did he ask you any questions at all? 
No. 
Had you ever danced before anyplace? 
1 
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8 
9 
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Page 284 
A. No. 
Q. Were you aware where 
worked? 
A. No. 
Q. Okay. Were you ever aware that 
at .A
10. 
Q. Do you know what a jack shack is? 
A. I've heard of it. 
Q. Okay. Do you know whether M. worked 
shacks? 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
a? 
Not that I know of. 
Did you ever ask ha'? 
Na 
Do you know a lady -- a person named a? 
No, I do not. 
You sure? 
Yes. 
She's a fried of E's. You don't know 
MR. EDWARDS: Object to the form. Asked and 
answered. 
THE WfTNESS: I don't know her. 
BY MR. CRITTON: 
Q. What were your hours at 
A. Seven to 2:00. 
(561 ) 
8 32-7 500 
7 (Pages 281 to 284) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (601-333-772-1652) 
Electronically signed by Pamela Sullivan (501-333-772-1652) 
92et5b62-38x5.4202.a350.6633a5c6813b 
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Page 285 
1 
Q. Seven p.m. --
2 
A. Yes. 
3 
Q. 
— to 2:00 in the morning? 
4 
A. Yes. 
5 
Q. Okay. And how were you paid? 
6 
A. Tips. 
Q. Did you have to share any with the house? 
a 
A. Yes. 
9 
Q. And what was the percent that you got to 
10 
keep, and the percent that you had to pay the house? 
11 
A. I just had to tip the DJ and the manager like 
12 
$15 each, or something. 
13 
Q. Okay. And how much did you make generally a 
14 
night? 
15 
A. I don't know. Couple of hundred dollars. 
16 
MR. EDWARDS: Speak a little bit louder, just 
17 
so that they can hear you. 
18 
BY MR. CRITTON: 
19 
Q. Couple of hundred dollars? 
20 
A. Yes. 
21 
Q. Okay. Did you ever make more than that? 
22 
A. Not really. 
23 
Q. That was pretty much your average take? 
24 
A. Yes. 
25 
Q. How many days a week did you work? 
1 
2 
3 
4 
5 
6 
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8 
9 
10 
13. 
12 
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Page 287 
Have you ever had any kind of plastic surgery? 
A. No. 
Q. Any kind of had any kind of breast 
implants? 
A. No. 
Q. In tents ofa 
in addition to 
doing the dancing on the stage, did you ever do bachelor 
parties? 
A. No. 
Q. Okay. Did you do lap dances? 
A. Yes. 
Q. And how much did you charge for a lap dance? 
A. There was a house fee, so it was like 25 or 
$30 for like one song. 
Q. So in addition to your stage dancing, where 
you get tips, you also did lap dances? 
A. Yes. 
Q. All right. And 'Awe they friction dances? 
A. Yes. 
Q. And in terms of the men that you — and these 
were always all with men; I assume. Any women? Did you 
have to do lap dances for women at times, too? 
A. Like once or twice. 
Q. And when you would do the lap dances for the 
men, in addition to the house charge, you would try to 
Page 286 
1 
A. Whenever I wanted to. 
2 
Q. All right. How many days a week did you want 
3 
to work? 
4 
A. Sometimes it was every night; sometimes it 
5 
was one or two nights. 
6 
Q. And how would you decide, just if you needed 
7 
money? 
8 
A. Pretty much, or if I felt like it. 
9 
Q. In addition to doing — you'd dance and you'd 
. 
10 
take your clothes off; right? 
11 
A. Yes. 
12 
• Q. Okay. And did you take all your clothes off? 
13 
A. Yes. 
14 
Q. Okay. Everything, tops and bottoms? 
15 
MR. EDWARDS: Object to the form. 
16 
THE WITNESS: Yes. 
17 
BY MR. CRITTON: 
18 
Q. And you did that sometimes seven days a week, 
19 • 
sometimes only two or three or four times a week, for 
20 
eight months; is that correct? 
21 
A. Yeah. Sometimes I didn't go for two weeks 
22 
and, you know, I — I just went whenever I felt like it. 
23 
I mean, sometimes I didn't go for a month. 
24 
. Did — and 
and prior to starting at 
25 
or let me ask you — ask you this: 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12. 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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24 
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Page 288 
do more so that you could get a bettor tip; true? 
A. No. 
Q. Okay. Well, you were doing friction dances, 
and flictice dances are where you're rubbing up against 
the men; right? 
A. Yes. 
Q. All right. And men get erections; truc? 
MR. EDWARDS: Object to the form. 
THE WITNESS: That's probably true, but I 
never touched anybody at the strip club there.
BY MR. CRITTON: 
Q. OkaySo u' re saying you danced for eight 
months at 
you're doing friction dances, 
dancing with men, and it's your testimony you never 
know you never knew whether any of them ever got an 
erection; is that true? 
MR. EDWARDS: Fenn. 
THE WITNESS: Yes: 
BY MR. CRITTON: 
Q. Did you -- did they have a champagne room. or 
some equivalent of that, at — excuse me — 
A. Yes. 
Q. Okay. Did you ever go back into the 
champagne room? 
(561) 832-7500 
8 (Pages 285 to 288) 
PROSE COURT REPORTING AGENCY, INC. 
1561) 832-7506 
Electronically signed by Pamela Sullivan (5014334124652) 
Electronically signed by Pamela Sullivan (601.333.772-1652) 
92efSb62-38a5-4202-a350-6633a5c6813b 
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Page 289 
1 
A. Yes. 
2 
Q. On how many occasions? At least once a week? 
3 
Twice a week? More? 
4 
A. I don't —
5 
MR. EDWARDS: Form. 
6 
THE WITNESS: I don't know. Once a week. 
7 
BY MR. CRITTON: 
8 
Q. All right. And when you would go back in the 
9 
champagne room, it would be you and — and just one man, 
10 
generally? 
11 
A. And a bouncer outside the door. 
12 
Q. Okay. So ifyou needed help, or if 
13 
something -- 
• 
14 
MR. EDWARDS: Form. 
15 
BY MR. CRITTON: 
16 
Q. 
— happened that was inappropriate, then you 
17 
can call for the bouncer? 
18 
A. Yes. 
19 
Q. Okay. And just when you were at -- when you 
20 
were at that club, if something inappropriate happened, 
21 
you could turn around and say you could leave the 
22 
room; right? 
23 
A. Yes. 
24 
Q. All right And you — and you knew that --
25 
A. Yes. 
Page 291 
1 
BY MR. CRITTON: 
2 
Q. And did you get more money for that, as well? 
3 
A. Yes. 
4 
Q. Okay. And did you strip naked in the 
5 
champagne room? 
6 
A. I didn't take my bottoms off. 
7 
Q. Took your top off? 
8 
A. Yes. 
9 
Q. And then you did a — would it be a fair 
10 
statement to say that would have been a serious friction 
11 
dance in the champagne room? 
12 
A. No. It just made it so that other people 
13 
couldn't see. 
14 
Q. All right. Well, is — isn't it true, when 
15 
you went into the champagne room, there's — oftentimes 
16 
there was some form of sex that occurred? 
17 
MR. EDWARDS: Fenn. 
18 
THE WITNESS: That is not true. 
19 
BY MR. CRITTON: 
20 
Q. So it's your testimony that in all of the 
21 
times that you went in the champagne room, that you 
22 
never had any type of sexual activity with the men in 
23 
the champagne room? 
24 
A. That is correct 
25 
Q. And consistent with what you told me earlier, 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
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Page 290 
Q. 
— that if something inappropriate happened, 
and that you could leave the room, because it was -- it 
was voluntary for you to either go into the room or not 
go into the room? 
A. Yes. 
Q. You could stay as long or as little as you 
warn? 
A. No. 
Q. Well, you could leave, if the — what you 
felt the man's conduct was inappropriate; true? 
A. Yes. 
Q. Did you ever have to call a bouncef/ 
A. Yes. 
Okay. Did any male at that —atIMMI 
MB ever try to attack you, to we force? 
A. I — I don't — I wouldn't really say that 
anybody tried to attack me, but there have been a few 
times where a man like tried to grab me and pull me on 
top of him, and I had to call somebody to help me. 
Q. Okay. And when you were in the champagne 
room, they'd — the men paid more for that; did they 
not? 
MR. EDWARDS: Object to the form. 
THE WITNESS: Yes. 
Page 292 
1 
you never even saw whether a man got an erection when 
2 
you were in those rooms; is that your testimony? 
3 
A. Yes. 
4 
Q. During the time you worked at 
5 
how many men did you go home with? 
6 
A. Zero. 
7 
Q. In addition to -- did you ever do a bachelor 
8 
party? 
9 
A. No. 
10 
Q. Did you ever do a strip-o-gram? 
11 
A. No. 
12 
e and apart from the dancing you did 
13 
at 
did you ever go to anyone's house to 
14 
perform any type of strip tease services? 
15 
A. No. 
16 
Q. lf someone would testify that you had, that 
17 
person would be saying would be not telling us the 
18 
truth? 
19 
MR. EDWARDS: Object to the 
20 
BY MR. CRITTON: 
21 
Q. Is that correct? 
22 
A. Absolutely. 
23 
Q. Did you like stripping? 
24 
A. No. 
25 
Q. Why did you do it, then? 
form. 
(561) 832-7500 
9 (Pages 289 to 292) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (601.333-772.1652) 
Electronically signed by Pamela Sullivan (501.333-772.1552) 
92ef5b62-38351202.3350-6633a5c6813b 
EFTA00750782

Page 293 
1 
A. Because I needed money. 
2 
Q. For what? 
3 
A. To live. 
4 
..thought you were living with — with. 
5 
at this time. 
6 
A. Yes. 
7 
Q. Okay. Well, you said earlier that she 
8 
supported you. 
9 
A. Would you like to be 18, asking. 
10 
for money? 
11 
Q. My question to you is: You told me that she 
12 
was supporting you. Did you tell au 
13 
were stripping? 
14 
MR. EDWARDS: Object to the form. 
15 
THE WITNESS: Yes. 
16 
BY MR. CRITTON: 
17 
Q. Okay. And what did she say? 
18 
A. I don't know. 
19 
Q. She had to have said something. Did she ever 
20 
say, you don't — I don't want 
doing that? I'll 
21 
help you get a job a 
You can come to work 
22 
for me. I'm a manager; I can help you get a job. 
23 
A. No. 
24 
Q. And did you ever sa h , M, 
can you 
25 
help me get a job at 
I'd like to — 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
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14 
15 
16 
17 
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20 
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Page 29 
A. No. 
Q. Why not? 
A. I guess they weren't hiring. I don't know. 
Q. Okay. Did you keep going back? 
A. Yes. 
Q. Say, I have experience? 
A. Yes. 
Q. How many places do you think you applied 
before you started stripping? 
A. I don't know. 
i
.
iftierTu left 
then you went 
to 
A. Yes. 
Q. Were you still living with 
A. Yes. 
Q. Were you dating anybody at this time period, 
this time period being were you dating anybody during 
the time you were wo 
A. I started seeing 
at the time. 
Q. And that would have been in 2007? 
A. Yes. 
Q. Okay. And when did you and 
start 
living together? 
A. I believe it was August of'07. 
Q. Is he employed? 
Page 294 
1 
like to work at 
You know TM smart. You 
2 
know I'm qualified. I can do something there. Can you 
3 
help me do theft 
4 
A. I can't work at 
because I live 
5 
with her. 
6 
Q. Okay. Well, did you say, can you help me get 
7 
a job someplace else then? 
9 
A. No. 
9 
Q. Why not? 
10 
A. Because I tried before. 
11 
Q. Well, if I send you an interrogatory that 
12 
says, tell me all the places you applied, I should be 
13 
able to get applications of all these places that you 
14 
applied; right? 
15 
MR. EDWARDS: Object to the form. 
16 
THE WITNESS: So what do you mean? You want 
17 
the applications that I --
18 
BY MR. CRITTON: 
19 
Q. • Yeah. How many places did you ever apply 
20 
before you started stripping? 
21 
A. I don't know. I went to 
22 
Q. Two or three? 
23 
A. I went to the few places at the mall, and I 
24 
went to all the restaurants that were around my house. 
25 
Q. And nobody would hire you? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 296 
A. Not currently. 
Q. Has he ever been? 
A. Yes. 
Q. What kind of work did he do? 
A. He worked at 
washing cars. 
Q. What's his educational background? 
A. He dropped out in the tenth grade. 
Q. Is he a Palm Beach County person? 
A. 
Q. When is the last time — when you met him, he 
was working for 
A. No. 
Q. Who was he working for, or was he not 
working? 
A. He was not working at the time. 
Q. Okay. When you started living together in 
August of'07, did he have a job? 
A. He
 afterward. 
Q. At 
A. Yes. 
Q. And how long did he work with IM? 
A. He worked at a restaurant in Boca for like 
eight months, l think, or seven months, maybe. And then 
he didn't have a job for, oh, probaayieven months 
again, and then he got the job at =. 
SMIL•
44•45...
.-.4.,••••01.7a.".•....4...n.le......
, W • 
J 
%Ps 
10 (Pages 293 to 296) 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Pamela Sullivan ([01.933.772.1652) 
Electronically signed by Pamela Sullivan (601-333-772-1552) 
(561) 832-7506 
92ef5b62-38a5-4202-a350-6633a5c6813b 
EFTA00750783

1 
2 
3 
4 
5 
6 
Page 297 
Q. But Ws -- are you saying he's working there 
now? 
A. He is not working there now. 
Q Okay. How long did he work -- at the Boca 
res 
which restaurant did he work at? 
AAuartt
). 
1 
2 
3 
4 
5 
6 
Page 299 
A. For sale of cocaine. 
Q. So he's a drug dealer —or was a drug 
dealer --
MR. EDWARDS: Farm. 
THE WITNESS: He —
BY MR. CRITTON: 
7 
Q. Doing what? 
7 
Q. 
— is that true? 
8 
A. Bus — busboy. 
8 
A. He got cocaine from a friend of his and sold 
9 
Q. Okay. And then he was off for aboutak-
9 
it to somebody else and —
10 
six ors
 oreven months, and then he got ajob wit 
10 
Q. So he's a drug dealer; he sold drugs? 
11 
11 
MR. EDWARDS: Form. 
12 
A. Yes. 
12 
THE WITNESS: That was not his occupation. 
13 
Q. Okay. How long did he have that job washing 13 
He actually was doing it like as like a one-time 
14 
cars? 
14 
thing, and —
15 
A. Fm not sure. Probably about the same length 
15 
BY MR. CRITTON: 
16 
of time. 
16 
Q. Being a good neighbor? 
17 
Q. All right. When — and when did he get —
17 
MR. EDWARDS: Form. 
18 
did he get laid oft; or fired in — well, let me strike 
18 
THE WITNESS: -- ended up getting caught. 
19 
that. 
19 
BY MR. CRITTON: 
20 
From the restaurant job, did he get laid off, 
20 
Q. How long has he been using drugs? Since you 
21 
or fired? 
21. 
two have been dating? 
22 
A Fm not exactly sure. 
22 
MR. EDWARDS: Form. 
23 
Q. Okay. How about-? 
23 
THE WITNESS: He has not used drugs since I 
24 
A He - he got another job as a telemarketer. 
24 
was pregnant with my daughter. 
25 
and so quit the job ail". 
And then the 
25 
Page 298 
Page 300 
telemarketing job didn't work out. 
1 
BY MR. CRITTON: 
2 
2 
Q. Okay. Well, when did he 
when did he get 
Q. What was that, last for a month or 
I 
ing? 
3 
A. He was -- he stayed there for about three 
3 
charged with sale of cocaine? 
4 
weeks, maybe a month, and didn't make any money, so he 
4 
A. Over a year ago. 
S 
ended up having to leave them. 
5 
Q. Okay. Well, a year ago your daughter had 
6 
Q. And you say a Boca restaurant. Do you think 
6 
just been born. Your daughter is a little over a year 
7 
he was terminated? 
7 
old right now; right? 
8 
MR. EDWARDS: Form. 
8 
A Probably about two years ago. 
9 
THE WITNESS: I know that he was terminated. 
9 
Q. Two years ago what? 
10 
I don't know if he was laid off or fired, though. 
10 
k 
He was charged. 
11 
BY MR. CRTITON: 
11 
Q. Oh, okay. I thought you said a year ago. 
12 
Q. And - and with the telemarketing job, when 
12 
MR. EDWARDS: Form. 
13 
did he last have the telemarketing job? 
13 
THE WITNESS: I said over a year ago. 
14 
A. About a month or two ago. 
14 
BY MR. CRITTON: 
15 
Q. Is he out looking fora job? 
15 
Q. Oh, over a year ago. 
16 
A He is trying to get a job, yes. 
16 
So how long has he been on house arrest? 
17 
Q. Okay. Does he have any type of criminal 
17 
A. One year. 
18 
record? 
18 
Q. Has he been — so he hasn't been able to 
19 
A. Yes. 
19 
work?
20 
Q. For what? 
20 
k 
Yes. 
21 
A. He is — 
21 
Q. He has been? 
22 
MR. EDWARDS: Form. 
22 
A. He's allowed to work. 
23 
TI/E WITNESS: He's on house arrest right now. 
23 
Q. Oh, he got -- he gets work release? 
24 
BY MR. CAUTION: 
24 
A. He —
25 
Q. For what? 
25 
MR. EDWARDS: Form. 
`--Prcatec=ere, 
11 (Pages 297 to 300) 
(561) 832-7500 
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(561) 832-7506 
Electronically signed by Pamela Sullivan (601.333-772.1652) 
Electronically signed by Pamela Sullivan (601-333-772.1552) 
92e15b82-3844202435048838608813b 
EFTA00750784

Page 301 
1 
THE WITNESS: He makes a schedule every week 
2 
of what het going to be doing all week long. 
3 
BY MR. CRITTON: 
4 
Q. Okay. So he gets arrested for the sale of 
5 
cocaine, but he's 
he's arrested, but at some point he 
6 
got put on probation or something so he could do -- or 
7 
part of his program is he gets a work release so he 
8 
wouldn't have to be on house arrest; right? 
9 
MR. EDWARDS: Font]. 
10 
THE WITNESS: He is on house attest 
11 
BY MR. CRITTON: 
12 
Q. But he can go to work? 
13 
A. Yes. 
14 
Q. But he doesn't have a job now? 
15 
A. Not now. 
16 
Q. How do you guys -- and you don't have a job 
17 
right now? 
18 
A. Right. 
19 
Q. Okay. So how do you two support yourself -
20 
when was the last time you had work? 
21 
A. Since' had my daughter. 
22 
Q. Okay. So you haven't worked since June —
23 
probably before June 29th of '08; coned? 
24 
A. Yes. 
25 
Q. Okay. And 
has not worked since when? 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 303 
1 
Q. Do you — you rent forma family member? 
2 
MR. EDWARDS: Fan. 
3 
• THE WITNESS: Yes. 
4 
BY MR. CRITTON: 
5 
Q. Isn't it true, ma'am, that lavas 
6 
selling cocaine so as to help support you and himself 
7 
and the child? 
8 
MR. EDWARDS: Form. 
THE WITNESS: No. 
BY MR. CRITTON: 
Q. When is the last time you did work? 
A. Before 1 became pregnant with my daughter. 
Q. 
d
you last work? 
A. 
Q. Did you laant 
during the time you 
were working at 
A. Yes. 
anew 
you wassis 
ailitv 
you were working at 
A. Yes. 
Q. Okay. What did he think about that? He was 
okay with that? 
MR. EDWARDS: Form. 
THE WITNESS: No. 
Page 302 
A. About three weeks ago. 
2 
Q. When he was working at rand 
as a 
3 
telemarketer, did he make enough money to support you 
4 
so — in -- in the house that you're living in? 
5 
A. Yes. 
6 
Q. Okay. How much did he make as a — as a —
7
working, washing cars at Ilia 
8 
A. Pm not exactly sure. Like ten dollars an 
0 
hour. 
10 
Q. Does anybody help you pay towards your -- do 
11 
you rent or lease — do you rent or lease — do you 
12 
lease or pay a mortgage payment on the house? 
13 
A. Rent. 
14 
Q. And do you rent from someone you know? 
15 
A. Yes. 
16 
Q. Who? 
17 
MR. EDWARDS: Form. Don't answer. Same 
18 
objection that we've been going through the whole 
19 
time; its just going to identify the address. 
20 
BY MR. CRITTON: 
21 
Q. How much do you pay a month for rent? 
22 
A We were paying a hundred dollars every week, 
23 
so that's $400 a month. 
24 
Q. Do you pay the electric, too, all utilities? 
25 
A. No. We just had to pay that 
Page 304 
1 
BY MR. CRITTON: 
2 
Q. Why did you do it, then? Why didn't you get 
3 
a — try to get another job? You were — well, let me 
4 
strike that. 
5 
How long did you work at MEM 
6 
A. About six or 
7 
Q. So 
between_ 
which was about 
8 
eight months, and 
you worked about a year, 
9 
like 14 to 15, 16 months, doing stripping; is that 
10 
correct? 
11 
A. Yes. 
12 
Q. Okay, rayagglipjo go back to stripping 
13 
once you finish 
or once you finish —
14 
once your daughter starts school? 
15 
A. No, 1 do not. 
16 
Q. You don't have any intention of going back 
17 
into the stripping business? 
18 
A. No, I do not 
19 
Q. When you were at MEN 
where was that 
20 
located? 
21 
A. West Palm Beach. 
22 
Q. And that's the one off 
1 think 
23 
you said? 
24 
A. Yes. 
25 
Q. Okay. And who was your boss there? 
,w. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, 
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Page 305 
1 
A. There were a few managers there. One of them 
2 
was named 
3 
Q. Was he the last manager when you left, when 
4 
you stopped working? 
5 
A. Yes. 
6 
Q. What did you have — w 
was the deal --
7 
financial deal with 
Tips, and then you had 
8 
to tip the DJ and the manager again? 
9 
A. Yeah, but — yeah, pretty much it was the 
10 
same. 
11 
Q. Anything different about your financial 
12 
arrangement there? 
13 
A. No. 
14 
Q. And in order to get that job — well, let me 
15 
strike that 
16 
Was 
working there, too? 
17 
A. No. 
18 
Q. Was El working there? 
19 
A. No. 
20 
Q. Anyone that you knew? 
21 
A- Yes. 
22 
Q. Who? 
23 
A. A girl that I met at 
24 
Q. Who was? 
25 
A. I don't know her real name. 
Page 307 
1 
A. Sometimes, yes. 
2 
Q. All right. And you'd get tips from people 
3 
who would put money wherever? 
4 
A. They would throw it on the stage —
5 
Q. Okay. 
6 
A. — on the floor. 
7 
Q. Could — could they put money into your — if 
8 
you still had your bottoms on, could they — would you 
9 
allow them to put money into your G-string? 
10 
A. No, I wore a garter on my leg. 
11 
Q. Okay. Would you allow them to put money into 
12 
your garter? 
13 
A. Yes. 
14 
Q. Okay. And when you were dancing, did you 
15 
dance right dugjailaBLof thc-lagisiag men? 
16 
That is, both 
"id 
did they 
17 
have a bar right that was adjacent to the stage, so 
18 
that they're 
they're sitting right at the stage 
19 
level? 
20 
A. Yes. 
21 
Q. All right. And so you're dancing naked in 
22 
front of them at times; correct? 
23 
A. Yes. 
24 
Q. Okay. And as you're dancing, you're going up 
25 
and down — they have a pole there; I assume? 
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Page 306 
Q. What was her stage name? 
QA.t 
MR. EDWARDS: She'll subpoena her. 
MR. CRITTON: rm sure you'll -- you'll 
assort privacy rights. 
MR. EDWARDS: Good idea. 
BY MR. CRITTON: 
Q. Did you do lap dances at MM. 
A. Yes. 
Q. And did you do any bachelor parties at= 
A. No. 
Q. Okay. Again, friction lap dances at.. 
A. .Yes. 
Q. Did they have a champagne room? 
A. Yes. 
Q. Same, did you use the champagne room whenever 
you could because ou would make more money? 
A. 
was -- it was kind of different, 
and I didn't do a lot of champagne rooms there. It was 
a it felt a lot less safe there. 
At -- at -- at 
did you again, 
when you were on stage, strip down to buck tufted? 
25 
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Page 308 
A. Yes. 
Q. All right. So you're dancing naked, and 
you're spreading your legs; true? 
A. What is it — what do you mean? 
Q. Well, when you're dancing in front of these 
men and you're completely naked, you're exposing all 
parts of your body; aren't you, including your 
genitalia? 
A. Yes. 
Q. All right. And you're doing that for then; 
and you're going close to the bar where those men are 
being seated — where those men are seated; true? 
A. No. 
Q. Okay. So you never went close to the bar? 
A. No. 
Q. You just stayed right in the center of the 
stage? 
A. Yes. 
Q. Well, if you stayed in the center of the 
stage, how could men ever put tips into your garter? 
A. Because it was at the calf of my leg. 
Q. So you had to get close enough to the bar 
that somebody could reach across and put a dollar bill 
or a five-dollar bill or a 20, or whatever they were 
tipping, into your garter, right? 
•••••
••SMINS•aA 
.••••••./.• ,•....00.••••
••JJ•41 
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Page 309 
1 
A. Yes. 
2 
Q. All right. So you did get close to the edge 
3 
of the stage -- 
. 
4 
MR. EDWARDS: Form. 
5 
BY MR. CRITTON: 
6 
Q. 
-- when you were naked: true? 
7 
MR. EDWARDS: Form. 
8 
BY MR. CRITTON: 
9 
Q. You had to. Otherwise, their — their arms 
10 
could not have reached your garter, ma'am —
11 
MR. EDWARDS: Form. 
12 
BY MR.. CRITTON: 
13 
Q. -- isn't that true, ma'am? 
14 
A. Yes, I — !would put my leg far enough to 
15 
where they could reach it, yes. But I didn't go like 
16 
right up to them in order to dance in front of their 
17 
face like that. 
18 
Q. On the friction dances that you did at lap --
19 
at 
there were many occasions that you saw 
20 
men get an erection; isn't that true? 
21 
MR. EDWARDS: Form. 
22 
THE WITNESS: No. 
23 
BY MR. CRITTON: 
24 
. Oka . Is it our testimony, neither at 
25 
or 
did you ever engage in any 
Page 311 
1 
MR. CRITTON: Time period for right now. 
2 
MR. EDWARDS: Okay. 
3 
THE WITNESS: Probably a kw months after I 
4 
met Jeffrey Epstein I had sex with my first 
5 
boyfriend. 
6 
BY MR. CRITTON: 
7 
Q. And was that someone that you had dated for a 
8 
lengthy period of time? 
9 
A. I dated him for about a year and a half. 
10 
Q. Before — did it start before Mr. Epstein? 
11 
A. Before, yes. 
12 
Q. And what was this person's name? 
13 
MR. EDWARDS: Object to the form. 
14 
Instructing her not to answer. 
15 
BY MR. CRITTON: 
16 
Q. And when you say you had sex with him, that's 
17 
sexual Intercourse? 
18 
A. Yes. 
19 
Q. Okay. Did you ever have — did you ever 
20 
have — perform oral sex on him? 
21 
A. No. 
22 
Q. Okay. Did you ever have any type of anal sex 
23 
with him? 
24 
A. No. 
25 
Q. Okay. Other than this person, and we'll call 
Page 310 
1 
activity where you saw — where you saw a man with an 
2 
erection; is that true? 
3 
A. Yes. 
4 
Q. Okay. And is it your testimony, to the 
5 
ladies and gentlemen of the "ti , during the time that 
6 
you worked at both 
and 
for 
7 
some 14, 15, 16 months that you never engaged in any 
8 
kind of sexual activity, including using your hand on a 
9 
man's penis to help him ejaculate during the time you 
worked there? 
A. No, I did not. 
Q. And ifs your — is it your testimony that, 
up until the time you started seeing a 
that you 
had never seen a man's penis, other than Mr. Epstein? 
• 
MR. EDWARDS: Object to the form. 
THE WITNESS: No. 
BY MR. CRITTON: 
Q. Okay. When — when did you first see a man's 
penis, other than Mr. Epstein's? 
MR: EDWARDS: And I'm just going to place the 
objection that she's not going to give any names of 
individuals at this time to protect privacy rights 
of my client, as well as third panics. So I don't 
know if you're talking about in terms of time 
Period --
1 
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Page 312 
him Mr. A, when is the next time that you had any sexual 
activity with anyone? And by sexual activity, I mean 
where -- either intercourse, oral sex, could be anal 
sex, anything of that nature. 
A. I don't know. I was 15. 
Q. And how old were you when you had sex with 
person, Mr. A? 
A. I was 14. 
Q. You never had any sexual activity with 
Mr. Epstein; did you? 
MR. EDWARDS: Pont. 
THE WITNESS: What do you mean? 
BY MR. CRITTON: 
Q. You never had sexual intercourse with 
Mr. Epstein at any time; did you? 
A. No. 
Q. You never had any type of anal sex with 
Mr. Epstein; did you? 
• 
A. No. 
Q. • You never performed oral sex on Mr. Epstein; 
did you? 
A. No. 
Q. He never performed any oral sex on you; did 
he? 
A. No. 
(561) 832-7500 
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14 (Pages 309 to 312) 
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Page 313 
1 
Q. Therefore, you bad no type of sexual activity 
2 
with Mr. Epstein —
3 
MR. EDWARDS: Object to the form. 
4 . 
BY MR. CRITTON: 
5 
Q. 
— at least, as I've defined it thus far; 
6 
correct? 
7 
MR. EDWARDS: Object to the form. 
8 
THE WITNESS: He touched my —
9 
BY MR. CRITTON: 
10 
Q. Go ahead. Finish your question; then I'll —
11 
or your response. 
12 
A. He touched my vagina with his hand and 
13 
inserted his fingers. 
14 
Q. When I asked you the question, and you 
15 
responded that he — that you and Mr. Epstein never had 
16 
sexual intercourse, never had any type of anal 
17 
intercourse, you never had any type of -- you never 
18 
performed oral sex on him, and he never performed oral 
19 
sex on you, that was true with all of the visits that 
20 
you ever had to Mr. Epstein's house; true? 
21 
A. Yes. 
22 
Q. Now, with person A, which you said you had 
23 
sexual intercourse at age 14, and there was a person B. 
24 
Is this another person you had a long-term relationship 
25 
with, or was this a shorter relationship? 
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Page 315 
BY MR. CRITTON: 
Q. 
— and how old were you? 
MR. EDWARDS: You can answer the second half. 
THE WITNESS: I was 16. 
BY MR. CRITTON: 
Q. We'll call this person — a man, I assume, 
male? 
A. Yes. 
Q. wen call this Mr. C 
CRITTON: — because you're going to 
instruct her not to answer, right? 
MR. EDWARDS: Right. 
BY MR. CRITTON: 
Q. All right. And long-term relationship, or 
just a short? 
A. Yes, that was a long relationship. 
Q. Only sexual intercourse with him? Did you 
ever have oral sex with him? 
A. 
Q. 
Q. 
A. 
A. 
Yes. 
Both you to he and he to you? 
Yes. 
And that went on over a long period of time? 
Yes, until after I turned 18. 
And why did that relationship break up? 
I — I — I believed he was crazy. 
Page 314 
1 
A. Yes, it was a shorter relationship. 
2 
Q. How old were you then? 
3 
A I was 15. 
4 
' 
Q. And did you have sexual intercourse with this 
5 
person? 
6 
A. Yes. 
7 
Q. Any oral sex, he to you or you to he? 
a 
A. No. 
9 
Q. Any anal sex? 
10 
A. No. 
11 
Q. The next person — and I assume — by who —
12 
who is person B? 
13 
MR. EDWARDS: And my objection is the same. 
14 
She's not going to give any names of these 
15 
individuals. 
16 
MR. CRITTON: You're instructing her not to 
17 
answer? 
/.8 
MR. EDWARDS: Yes, exactly. 
19 
BY MR. CRITTON: 
20 
Q. Okay. And you're going to follow whatever 
21 
instruction he gives you? 
22 
A. Yes. 
23 
Q. All right. Who was the next person, then, 
24 
you had sexual activity with 
25 
MR. EDWARDS: Same objection. 
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Page 316 
Q. Okay. Was he? You thought he was. 
A. Yes. 
Q. Okay. With person A, did you use illegal 
drugs with person A? 
A. Yes. 
Q. Okay. With person B, did you use illegal 
drugs? 
A. 'No. 
Q. Alcohol? 
A. No. 
Q. With A, you used both drugs and — illegal —
illegal drugs and alcohol; true? 
A. We both tried our firsts together. We like 
drank for the first time together, and 
• 
Did drugs together? 
A. Yes. 
Q. All right. Person C, who you said was crazy, 
how long was the relationship? 
A. More than two years. 
Q. Did you do drugs with him? 
A.. Yes. 
Q. Alcohol? 
A, No. 
. 
Q. Okay. Was he a drug dealer? 
MR. EDWARDS: Form. 
• 
15 (Pages 313 to 316) 
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PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Pamela Sullivan (601433-7724552) 
Electronically signed by Pamela Sullivan (601.333-772-1552) 
92ef5b62-38a5-4202-a350-6833,15O3813b 
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1 
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BY MR. CRITTON: 
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Page 317 
THE WITNESS: No. 
Q. Did he work? 
A. Yes. 
Q. What kind of work did he do? 
A. He laid tile. 
Q. Did you live together? 
A. Yes. 
Q. Where? 
A. He lived in a — in a trailer in West Palm 
Beach. 
Q. Okay. After the two, so 16 through 18, 
when — during the time that you wore going to 
Mr. Epstein's house, did you — were you having these 
relations with A, B, and C? 
MR. EDWARDS: Form. 
THE WITNESS: Yes. 
BY MR. CRITTON: 
Q. Okay. Wen A— did A, B or C, or any 
permutation of that group, aware that you were going to 
Mr. Epstein's? 
A. No. 
Q. Did you tell than? 
A. Na 
Q. Why not? 
Page 319 
1 
you share that, then, with Mr. C or Mr. B, depending on 
2 
who you were with at the time? 
3 
A. No. 
4 
Q. What did you do with your money? 
5 
A. I bought clothes and things for myself. 
6 
Q. When you were living with Mr. C,1 think you 
7 
said, did you 
where were you living, in a trailer, a 
8 
house, an apartment? 
9 
A. We were living in a trailer. 
10 
Q. And where, what city? 
11 
A. West Palm Beach. 
12 
Q. Was he abusive to you in any way, either 
13 
physically or verbally? 
14 
A. No. 
15 
Q. Did you ever have to call the police on him? 
16 
A. No. 
17 
Q. You're sure? 
18 
A. No, fm not sure. 
19 
Q. Okay. Did he strike you — didn't he? 
20 
A. He stalked me. 
21 
Q. Okay. How long —
22 
MR. EDWARDS: Is that what you asked, 
23 
stalked? 
24 
MR. CRITTON: I said strike. 
25 
THE WITNESS: He said, did he satin. 
Page 318 
1 
A. 1- the only person that knew about it was 
2 
the last person that I just told you about. 
3 
Q. C? 
I 
A. Yes. 
5 
Q. Okay. And what did you tell him? He knew 
6 
you were going to Epstein's? 
7 
A. He knew that I was going somewhere. 
8 
Q. How did he know? Did you tell him? 
9 
A. Yes. 
10 
Q. What did you tell him? 
11 
A. I told him that I was going to clean house. 
12 
Q. Okay. And did you — at the time that you 
13 
were dating Mr. C, did — how much were you getting paid 
14 
from Mr. Epstein? 
15 
A. Usually when I went there, he — he gave me 
16 
in between two and $300. 
17 
Q. In cash? 
18 
A. Yes. 
19 
Q. Would he give it to you, or would someone 
20 
else give it to you? 
21 
A. He would set it down on the counter, 
22 
sometimes he would give it to me, sometimes somebody 
23 
else would give it to me. It was different a lot of the 
24 
times. 
25 
Q. When you were receiving the money, did — did 
Page 320 
1 
MR. EDWARDS: Oh, okay. Sony. 
2 
MR CRTITON: And she said stalked. 
3 
MR. EDWARDS: Okay. 
4 
BY MR. CRITTON: 
5 
Q. Did he ever strike you? 
6 
A_ No. 
7 
Q. When you say he stalked you, !mean did he --
8 
stalking, in my mind, is he would follow or see where 
9 
you were. 
10 
A. Yes. He knew things that 1 didn't tell. 
11 
anybody. He — like I moved and lived withM. so that 
12 
he wouldn't know where I was, and he found out where I 
13 
was. 
14 
Q. Did he come there? 
15 
A. He would like hide outside in the bushes and 
16 
stuff. 
17 
Q. And you knew he was out there? 
18 
A. Yes. 
19 
Q. Did you have to call the police and say, fve 
20 
got a stalker? 
21 
A. No, I never did that. 
22 
Q. So were you scared of him? 
23 
A. Not really. 
24 
. Q. Were you intimidated by him? 
25 
A. No. 
(561) 832-7500 
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Page 321 
1 
Q. Was he harassing you? 
2 
A. He was harassing me. 
3 
Q. Okay. I thought 1-- when I asked you 
4 
earlier and we were talking about, let's see, the 16 and 
5 
17 year -- let's see, if you lived with Mr. C your 16 
6 
through 18th year, and you were born in '88 -- 16 --
7 
that takes me to '04 through like 2006. So is that the 
8 
first time you would have gone tea.'s, when she was 
9 
living in West Palm Beach, or is this another time you 
10 
went tca.'s that you didn't remember telling us 
11 
about? 
12 
A. No, that was the first time that 1 moved in 
13 
with'., then, after I left him. 
14 
15 
Q. I thought you bald us you were livi at your 
house, and you left y 
house to go 
16 
live wi 
17 
A. We were liven in his trailer, and then we 
18 
were livirtg wi
19 
Q. So you were a 16- 17- ear-old irl and you 
20 
were living with Mr. C a 
house?
21 
A. Yes. 
22 
Q. What die 
think about that? 
23 
A. I don't latow. 
24 
Q. Well, she let you live there; didn't she? 
25 
MR. EDWARDS: Form. 
Page 323 
1 
true? 
2 
MR. EDWARDS: Object to the form. 
3 
THE WITNESS: He touched me. 
4 
BY MR. CARTON: 
5 
Q. ! understand that. But he never physically 
6 
caused you harm? 
7 
MR. EDWARDS: Form. 
8 
THE WITNESS: I dent know what you mean by 
9 
that. 
10 
BY MR. CRITTON: 
11 
Q. Well, he never caused an injury to you --
12 
MR. EDWARDS: Form. 
13 
BY MR. CRITTON: 
14 
Q. — physical injury to you; true? 
15 
A. No, he never hit me. I don't know. 
16 
Q. I'm sorry? 
17 
A. He never like hit me. 
18 
Q. After Mr. C — well, let me strike that. 
19 
How did you get rid of Mr. C, other than you 
20 
said he was a bit of a nut case, or you thought he was 
21 
any. 
22 
A. I just -- I left him. I lived 
• 
' 
23 
a while, and I moved bads in wi 
24 
believe my uncle was living there at the time, and he 
And 
25 
just,Iguess, moved. 
Page 322 
1 
THE WITNESS: Yes. 
2 
BY MR. CRITTON: 
3 
Q. During the time that — the some 20 occasions 
4 
you went to Mr. Epstein's home, would it be a correct 
5 
statement, Ms. Jane Doe, that he never threatened you 
6 
with any type of serious harm? 
7 
MR. EDWARDS: Form. 
8 
THE WITNESS: Is it true that he never 
9 
threatened me? 
10 
BY MR. CAUTION: 
11 
Q. Right. Mr. Epstein never threatened you at 
12 
any time you went to his home; isn't that true? 
13 
A. Yeah, that's true. 
14 
Q. And he never attempted to physically restrain 
15 
you; true? 
16 
A. Yeah. Yeah, that's true. 
17 
Q. And he never threatened you nor abused you 
18 
either physically or verbally; true? 
19 
k 
He - 
20 
Q. He never injured you physically? 
21 
MR. EDWARDS: Is this a different question. 
22 
• or is she answering the first one? 
23 
BY MR. CRITTON: 
24 
Q. Yeah, let me throw it out. Let me ask it 
25 
this way: He never — never physically injured you; 
Page 324 
1 
Q. Okay. Well, was he still living when they 
2 
moved back in, or did he tell C he had to exit the 
3 
house --
4
A. H was 
5 
Q. -house? 
6 
A. He was gone. 
7 
Q. After Mr. C, who was your next relationship 
8 
with, wished 
sexual activity? 
9 
A. 
10 
4 
And Wage time, since the time you 
11. 
started datingMl., which was in what, sometime in 
12 
2007? 
13 
A. Yes. 
14 
Q. Okay. Has he been the only person that you 
15 
have been sexually active with since Mr. C? 
16 
A. Yes. 
17 
Q. So if someone would testify that you were 
18 
sexual — so if someone were to testify in this case 
19 
that you were sexually active at the age of 12, what 
20 
would your response to that be? 
21 
M. EDWARDS: Form. 
22 
THE WITNESS: That is not true. 
23 
BY MR. CAUTION: 
24 
Q. What was the person you had - Mr. A, how 
25 
approximately how old was Mr. A? 
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A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
He was two years older than me. 
How about Mr. B? 
Same. 
How about Mr. C? 
He was four years older than me. 
Do you have any piercings? 
My ears. 
Other than your ears? 
No. 
Page 325 
Q. Have you ever advertised for sex, any kind of 
sexual activity on any website? 
A. No. 
Q. When you left Mr. Epstein's house on the very 
first occasion and you said you and... — I'm sorry —
you and.. were walking eastbound on the road? 
A. Yes. 
Q. All right. Because you were trying to flag 
down a cab. 
A. Yes. 
Q. Had a cab been called to pick you up? 
A. Yes. 
Q. And why were you walking? 
A. Because the cab didn't come. 
Q. So you thought maybe it was lost or 
something? 
Page 327 
1 
That is, that's what you thought was going to happen, 
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based on what.. had told you? 
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A. No. 
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Q. Okay. Was it substantially different than 
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what you thought.. had told you would happen? 
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A. Yes. 
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Q. Okay. In fact, you said you didn't think you 
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would have to take your clothes off at all. 
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A. Yes. 
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Q. All right. And you weren't even sure that 
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you'd have to give anyone a massage, because ou 
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thought, based on what you told us, is thatIM. said, 
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I'll give you 200 bucks, just come with me? 
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A. Yes. 
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Q. 
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A. 
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Q. So what, from your perspective, it was hugely 
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different, at least based on what you've told us frorn 
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what.. said you should expect or what you thought was 
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going to happen; correct? 
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A. Yes. 
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Q. So weren't you ticked off at hen weren't you 
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angry with her? 
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A. I don't }mow what to say. 
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Q. Okay. Well, why not? You've been -- you've 
Come with me to the house; right? 
Yes. 
Page 326 
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A. Yes. 
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Q. And that was..'s idea? 
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A. Yes. 
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Q. And as you're walking awa from Mr. Epstein's 
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house the first time, what — did 
say, well, how 
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did it go? 
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A. No. 
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Q. Okay. Did you yen at.? 
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A No. 
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Q. Were you angry with.? 
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A. No. 
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Q. Did you say anything to.. 
as to what went 
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on between — excuse me — after she had left? 
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A. No. 
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Q. Why not? 
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A. Because I didn't feel comfortable talking 
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about It. 
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Q. Well, this is — this is the girl who, based 
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on what you've told us, is would be your belief that 
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misled you? 
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MIL EDWARDS: Form. 
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THE WITNESS: What do you mean? 
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BY MR. CRFITON: 
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Q. What occurred at -- what you say occurred at 
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• 
Epstein's house, is that what you thought the deal was? 
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Page 328 
been angry before. I mean, you -- you testified in 
court, you testified on depositions you had been a 
runaway, you know, you know how to pick up and leave if 
circumstances were not good at a particular house. You 
had a vast experience in taking care of ourself, to 
some extent, so why didn't you say toM. something 
like, what did you get me Into, or what happened, or 
what was going cm? Did you show any emotion at all to 
MR. EDWARDS: Form. 
THE WITNESS: Na 
BY MR. CRITTON: 
Q. So youjust got in the car — did you go in a 
cab? I gather 
gather a cab came? 
A. Yes. 
all:Stkay. Cab came. You get in the car. You 
andli. aren't talking at all? 
A. I don't remember any conversation that we 
had, no. 
Q. What did you tell the FBI? Didn't the FBI 
say, what do you mean you didn't say anything to..? 
MR. EDWARDS: Form. 
• 
THE WITNESS: They didn't say that to me. 
BY MR. CRFFPON: 
Q. Okay. And then did you tell them that 
(561) 832-7500 
PROSE COURT 
18 (Pages 325 to 328) 
REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (601.333.772-1662) 
Electronically signed by Pamela Sullivan (501-333-772.1552) 
92ef6b62.38a5-4202a350.6633a5c6813b 
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Page 329 
made 200 bucks off of you, a made money off bringing 
you there? 
A. Yes. 
Q. Okay. Did they -- did they tell you, the FBI 
tell you that if she's making money off of you; she's 
like your pimp? Did they say that to you? 
MR. EDWARDS: Form. 
THE WITNESS: No 
BY MR. CRITTON: 
Q. Okay. Do you know 
do you know what a pimp 
is? 
A. Not really. 
Q. Okay. Do you know that's someone who makes 
money off of — off of you for taking you someplace 
where you might make money? 
MR. EDWARDS: Object to the fonn. 
THE WITNESS: Why me? 
BY MR. CRITTON: 
Q. Pardon? 
A Why roe? 
Q. What do you mean, why you? 
A. What do you mean me? 
Q. You — well — 
A I don't have a pimp. 
Q. I'm sorry? 
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Page 331 
THE WITNESS: I do not bow. 
BY MR. CRITTON: 
Q. Did you ever ask her how many times she had 
been at Epstein's home —
A. Never. 
Q. 
— before she ever took you? 
A. No. 
Q. Did she ever tell you what — at any time 
after the first time that you were at Epstein's home, 
did she ever tell you how many times she had been there? 
A. Na 
Q. Did she ever tell you that she had brought 
anyplace from 20 to 80 people to Mr. Epstein's home, by 
her own testimony? 
A No. 
Q. Okay. Is that news to you, ass say that to 
you today? 
A Yes. 
Q. So what -- so you don't remember anything 
that you and, 
talked about on the way home? 
A. No. 
Q. And what did you do with the money that 
you — that you got, the 200 bucks? 
A. I bought clothing and things that I wanted. 
Q. Did III ever ask you to go back to 
Page 330 
1 
A. I don't have a pimp. 
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MR. EDWARDS: Form. 
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BY MR. CRITION: 
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Q You know, well, isn't M. — wasn't 
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your pimp? 
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MR. EDWARDS: Form. 
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BY MR. CRITTON: 
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Q. Didn't she take you there? 
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MR. EDWARDS: Form. 
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THE WITNESS: No, she is not my pimp. 
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BY MR. CRITTON: 
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g 
Well, what is she, then? If she's made money 
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off taking you to Mr. Epstein's, what would you call it? 
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A. Not my pimp. 
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Q. Wasn't your friend; was she? Because she 
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misled you; didn't she? 
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A. She probably didn't know that's what she was 
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doing at the time. 
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Q. She didn't !mow she was doing what? 
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A. What she was doing. 
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Q. How could she not 'mow what she was doing? 
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A. Because she was as young as I was. 
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Q. Okay. Well, how many times had M. been 
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there? 
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MR. EDWARDS: Form. 
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Page :33: 
Mr. Epstein's home again? 
A. No. 
Q. When you — how did you end up going back to 
Mr. Epstein's home again? 
A. I gave him my phone number, and he called me. 
Q. I'm sorry? 
A. I gave him my phone number, and I got a call 
from either him, 
or
Q. Did you meet 
every first 6me you 
were there? I think you sat you only met like the 
blond-headed girl, who subsequently you identified as 
MR. EDWARDS: Form. 
THE WITNESS: No, I did not meet 
the 
first time I was there. 
BY MR. CRITTON: 
Q. Okay. And did someone ask — did Mr. Epstein 
ask you for your phone number? 
A. Yes. 
Q. When you wore upstairs, or when you were 
downstairs? 
A. When I was upstairs. 
Q. And this is you, first time you were there, 
you've never taken your clothes off — at least that's 
what you've told us -- in front of any male before, you 
(561) 832-7500 
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PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Pamela Sullivan (601.333.772.1652) 
Electronically signed by Pamela Sullivan (501-333.772-1652) 
92ef5b62-38a54202-a350-5633a5c6813b 
EFTA00750792

Page 333 
1 
take your clothes off, you give him his massage, yoU 
• 
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described what occurred that first occasion, he asked 
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for your phone number, and you give it to him? 
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MR. EDWARDS: Form. 
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THE WITNESS: He only told me what to do. He 
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never asked. So I felt like I had to do it —
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BY MR. EDWARDS: 
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Q. 'Okay. Well --
9 
A. 
so I did. 
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Q. You had no obligation to do Anything when you 
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were there, ma'am; did you? 
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MR. EDWARDS: Form. 
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THE WITNESS: I feh as if I did. 
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BY MR. CRITTON: 
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Q. Okay. So when you — when he then 
but 
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whatever you did was completely voluntary on your part? 
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A. Fenn. 
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Q. You could either do it or not? You could 
19 
have just said, Pm out of here? 
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MR. EDWARDS: Form. 
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THE WITNESS: I only felt like I had to do it 
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because he told me to. He never asked anything. 
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He only would tell me. 
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BY MR. CRITTON: 
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Q. Well, 
told you what to do. =told 
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Page 335 
BY MR. CRITTON: 
Q. Okay. Well, you — just a minute ago you 
said, I knew she was bringing other people. Now, did 
you know she was bringing other people before she 
brought you? 
A. Not before she brought me. 
Q. Okay. Did you find out afterwards that IN 
had brought a lot of other people? 
A. No, I only assumed. 
Q. Okay. Well, did you ever ask 
a
 
—
A. No. 
Q. — whether she had brought other people? 
A. No. 
Q. Okay. So you don't — you didn't know 
whether she had brought anyone else, and you didn't know 
what she was thinking, because you never asked her; did 
you? 
A. No. 
Q. So when Mr. Epstein said, could I have your 
phone number, you had to voluntarily give it to him, 
because otherwise he couldn't have gotten it; true? 
MR. EDWARDS: Form. 
BY MR. CIUTION: 
Q. You could have given him any number. 
MR. EDWARDS: Fara. I would just ask that 
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Page 334 
you to take your clothes off. 
A. He told me to take my clothes off. 
You know, then you said that you looked at 
and. 
was taking her clothes off, and she said, 
we need to take our clothes off. 
A. `said that it was ols yes. 
Q. All right. So, but for 
being there, you 
never would have taken your clothes — number one, if it 
weren't for le 
you never would have been there; would 
you? 
A. `was already convinced that it was okay. 
Q. How do you know that she was convinced that 
it was okay? You said you and —
A. Because obviously —
Q. -- you said you never really talked about it. 
A. 
— obviously, she was bringing —
Q. So you — 
A. 
— other people there. 
Q. Well, you didn't know that. 'just asked you 
that a minute ago, whether you knew she -- whether you 
knew she was bringing anybody else. And you said you 
didn't know whether she had ever brought anyone else. 
MIL EDWARDS: Form. 
THE WITNESS: Well, she brought me. 
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Page 336 
you allow the witness to answer your question. 
BY MR. CRITION: 
Q. All right. You chose -- you voluntarily gave 
Mr. Epstein your phone number; didn't you? 
MR. EDWARDS: Fain. 
TI-LE WITNESS: He told me to give it to him, 
so I did, yes. 
BY MR. CRITTON: 
Q. You could have given him any number in the 
whole world. You didn't have to give him your number. 
How would he know? 
A. I don't bow. 
Q. So he asked, and you gave it to him 
voluntarily; true? 
MR. EDWARDS: Form. 
THE WITNESS: Yes. 
BY MR. CRITTON: 
Q. Okay. Now, Ms. Jane Doe, when you gay
your phone number, I think you said that you told Eff 
that you had given him your phone number? 
A. No. 
Q. Okay. Did 
ever come to you and say, 
hey, would you like to go back to Epstein's house again? 
A. Yes. 
. Q. Okay. When did she do that? 
20 (Pages 333 to 336) 
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PROSE COURT REPORTING AGENCY; - INC . 
Electronically signed by Pamela Sullivan (501.333-772.1662) 
Electronically signed by Pamela Sullivan (501-333-772-1562) 
(561) 832-7506 
92ef5b62.38a5-t202a350.6633a5c6813b 
EFTA00750793