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APPEARANCES: 
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On behalf of the Plaintiff.: 
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SPENCER KUM, ESQUIRE 
LEOPOLD KUVIN, P.A 
2925 POA Boulevard, Suite 200 
Palm 
Florida 33410 
Phone 
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On behalf 71ILMIrMane Does 24: 
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ADAM HORMEL, ESQUIRE 
MRMELSTEIN & HOROWITZ, PA 
18205 Biscayne Boulevard 
Suite 2218 
9 
Miami
Phone: 
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1.1 
On behalf of Plaintiff Carolyn Andnono 
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TACK Hal, ESQUIRE 
SEARCY, DENNEY. SCAROIA, BARNHART & SHIPLEY, PA 
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2139 Palm Beach Lakes Boulevard 
West 
till 
ride 33409 
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Phone;
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RICHARD/MATS, ESQUIRE (via telephone) 
RICHARD H. WILLITS, P.A. 
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229010th Avenue North, Suite 404 
Lake WS3461 
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Phone 
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On behalf o the Defendant 
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ROBERT CRITTON, ESQUIRE 
BURMAN, CRITTON, LIMIER & COLEMAN 
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515 Nonh Wet Drive 
Suite 400 
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West Ptrida 
33401 
Phone: 
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PROCEEDINGS 
- - 
(Continued from Volume I.) 
VIDEOGRAPHER: We're back on the video record. 
This is the beginning of tape number three. The 
time is 3:02 p.m 
BY MR. KUVTN: 
Q. Okay. Let me do it this way, so we can just 
back up a little bit. 
Ms.
 you're aware that girls, including 
my client, have sued Jeffrey Epstein in civil lawsuits, 
correct? 
A. Yes. 
Q. All right. Arc you also aware that one of the 
defenses has been that these girls volunteered to go to 
the house so, therefore, what are they complaining 
about? Are you aware of that? 
A. Yes, I am. 
Q. Okay. You feel that way yourself? 
A. Absolutely. 
Q. Because you volunteered to go, right? 
A. Absolutely. 
Q. And you haven't sued Mr. Epstein, have you? 
A. I have no intentions of that. 
Q. Did you contemplate it at one point? 
Page 159 
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On behalf of the Witness: 
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DOUGLAS MCINTOSH, ESQUIRE 
CAMILLE E. BLANTON, ESQUIRE 
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MCINTOSH, SAWRAN, PELTZ & CARTAYA, PA. 
1601 Forum Place 
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Suite 1110 
West Pal 
Fonda 33401 
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Phone: 
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ALSO PRESENT: 
MICHAEL DOWNEY, VIDEOORAPHER 
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Page 161 
A. Did I contemplate it? Yeah, it crossed my 
mind a few times. 
WilYi 
A. Nee. use 1 just thought it was the easy way 
out. And then 1 decided this is my life andl have to 
take responsibility for my own actions because 1 did 
volunteer. So I'm handling my grief and my situation a 
different way, and that's by putting this shit behind 
me. 
Q. Got you. Fair enough. 
What I'm wondering then — and the reason 1 
asked the question initially was not to embarrass or 
harass you. But since even yourself, you think to a 
certain extent that these girls bear their own 
responsibility for going? 
A. They don't bear any responsibility. They need 
to take responsibility. 
Q. Got you. Did your dad tell you that? 
A. No. I've learned that. 
Q. What was his response to you about what 
happened then? That's why I asked the question 
initially. 
MS. BLANTON: We are not going to discuss her 
father and mother and relatives or any other 
friends' reactions to these lawsuits or what she's 
j 
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PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
7a82ddcH-69oe-4e 57-9cd8 -8392056001GO 
EFTA01075988

Page 162 
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been through. Again, she's not a Plaintiff. She's 
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not a Defendant. We're not going to do it. 
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The only purpose that serves is to upset her 
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and you've seen that. 
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MR. KUVIN: I certainly don't mean to upset 
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her, but obviously I'm rep cbenting certain 
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individuals who are being — prosecuting their 
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action. And I think that the questions are 
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relevant But if you're not going to let her 
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answer, then we'll move on. 
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BY MR. KUVIN: 
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Q. As you sit here today, did anyone blame you, 
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other than yourself for what happened? 
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MR. CRITTON: Form. 
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THE WITNESS: Yes. 
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BY MR. KUVIN: 
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Q. Who? 
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A. A lot of people. 
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Q. Who? Who can we talk to that blamed you, 
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other than your own personal feelings? 
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A. My sister. 
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Q. Okay. Who else? 
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A. Ifs the only person that I care about that 
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blamed me. 
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Q. Well, anyone that didn't — that you don't 
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Page 164 
A. Yes. 
Q. As you sit here today, do you think that the 
money that he's paid you and the fact that be's paying 
for your lawyers when your parents couldn't afford it 
anymore affects your testimony in any way? 
A. Absolutely not. That's ridiculous. 
Q. Okay. Fair enough. Fair enough. 
Do you think it was right for Mr. Epstein, 
personally, to have underage girls, girls under the age 
of 16 come to his house and give him naked massages? 
You think that was okay? 
MR. CRITTON: Form. 
THE WITNESS: I don't know. 
MS. BLANTON: Object to form. Define okay. 
BY MR. KUVIN: 
Q. Well, personally. I mean, do you think there 
was anything wrong with that, personally? 
MR. CRITTON: Form. 
THE WITNESS: I don't know. 
BY MR. KUVIN: 
Q. You have no opinion about that? 
MS. BLANTON: She's answered that twice. 
MR. CRITTON: Form. Argumentative, if that 
was a question. 
BY MR. KUVIN: 
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way? 
Page 163 
care about? 
A. I think a lot of the other Plaintiffs blame 
me. 
Q. Okay. Do you feel any personal msponsibility 
for any — bringing any of those girls to the house? 
MR. CRITTON: Form. Asked and answered. 
THE WITNESS: Can you repeat the question? 
BY MR. KUVIN: 
Q. Yeah. You said just now that you think some 
of the other girls that you brought blame you? 
A. Ub-hub. 
Q. Correct? 
A. Yes. 
Q. Do you — 
A. Do I blame myself? 
Q. Yeah, for bringing them. 
A. Absolutely not. 
Q. Not at all? 
A. No. 
Q. If Mr. Epstein were not paying for your 
lawyers, think you'd feel the same way? 
A. I would feel this way, no matter what. 
Q. If Mr. Epstein hadn't paid you in excess of 
53,000 over the years, do you think you'd feel the same 
Page 165 
1 
Q. You got no opinion about that? 
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A. I have no opinion about that. 
3 
Q. Okay. Do you remember the address of 
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Mr. Epstein's home? 
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A. No, I do not. 
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Q. Does the name Brillo Way sound familiar to 
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you? 
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A. Brillo Way sounds familiar. 
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Q. Did you ever take a shower in Mr. Epstein's 
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shower? 
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A. No. 
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Q. When you were at Mr. Epstein's house, did the 
13 
chef ever prepare you guys lunch as you were them? 
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MR. CRITTON: Form. 
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THE WITNESS: I don't remember. 
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BY MR. KUVIN: 
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Q. Any one of the girls that you brought to the 
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home, did any of those girls ultimately go to. 
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University, as far as you know? 
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A. Yes. 
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Q. Who? 
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A. Jane Doe 4. 
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Q. And I apologize, but is she the one that you 
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had heard had sex with Mr. Epstein? 
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MR. CRITTON: Form. 
PROSE COURT REPORTING AGENCY, 
Electronically signed by Sandra Townsend (401= 
Electronically signed by Sandra Townsend (401 
• 
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MS. BLANTON: rm sorry. Did you --
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BY MR. KUVIN: 
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Q. There was one of the girls that you had heard 
4 
had sex with them? 
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A. That was 
and I heard that from Jane Doe 
6 
101. 
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Q. Okay. Sony. 
8 
What did Jane Doe 4 do with him, if you know? 
9 
A. I don't. 
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Q. Did you ever tell anyone that you worked for 
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Jeffrey? 
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A. Did I tell anyone I worked for k 
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Q. Yes. 
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A. Yes. 
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Q. Who? 
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A. The girls. 
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Q. What did you mean by that when you said you 
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worked for Jeffrey? 
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A. Worked for Jeffrey, like, got girls to give 
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him massages. When I was introduced to a girl, I would 
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be, like, yeah, I work forJeffrey. I find girls to 
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give him massages. 
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Q. Okay. You weren't on any kind of a payroll or 
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anything, right? 
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A. No. 
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Page 168 
Q. So all of the girls that you brought actually 
recruited other girls as well? 
A. Yes. 
MR. CRITTON: Pont 
BY MR. KUVIN: 
Q. Okay. How do you know that? 
A. I know that because they told me. 
Q. Okay. Which one of them? 
A. Jane Doe 7 brought,. Jane Doe 4 brought 
Jane Doe 3 brought a couple girls, can't recall 
their names.', I think, may have broughten somebody, 
but I can't be accurate on that. And I don't know for 
tut
W
I think Jane Doe 7. may have also brought 
i
Q 
but
and., the sisters. 
Q. So now we're talking about around 12 girls 
that you brought. And then as far as you know, a lot of 
those, if not all of them, brought other girls, at least 
one or two other girls? 
MR. CRITTON: Form. 
BY MR. KUVIN: 
Q. Is that — did I understand you correctly? 
A. Yes, you do. 
Q. So as you sit here today, how many girls are 
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Page 167 
Q. Did you ever bring a girl over with the 
initials •? 
-
A. Pm sorry. What were the initials? 
Q. M. 
A. No, not that I can remember. Not that I can 
recall, no. 
Q. Do you know a girl by the name of
A. No. 
Q. Doesn't sound familiar to you? 
A. M.? 
Q. Yes. 
A. Does not sound familiar at all. 
Q. How about'"? 
Q. Does the name sound familiar to you at all? 
I. as a girl that went over to Mr. Epstein's home at 
some point? 
A. rye heard that name come up a few times. 
Q. Do you remember bringing a'. over to the 
house? 
A. I never brought a 
over to the house. 
Q. Of any of the girls that you brought, do you 
know if any of those girls then did similar to you in 
getting other girls? 
25 
A. All of them. 
Page 169 
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you aware of that were brought to Mr. Epstein's home? 
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A. That I'm aware of? 
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Q. Well, yeah, either that you brought or that 
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you know other people brought. I mean, you've already 
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talked to us about 12. Then where there's -- if they 
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each brought them, then we're talking 12 more, plus some 
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of them may have brought additional ones. You know, 
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simple math, were in the twenties now. How many are 
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you aware of let me strike the statement. 
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How many people are you aware of, either 
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directly or indirectly, girls that were brought to 
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Mr. Epstein's home? 
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MR. CRITTON: Form. 
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THE WITNESS: At least 20. 
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BY MR. KUVIN: 
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Q. At least? 
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A. At least 20. 
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Q. Could it be at least 30? 
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A. I don't know. 
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MR. CR1TTON: Form. 
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THE WITNESS: I don't want to speculate. 
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BY MR. KUVIN: 
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Q. But through either firsthand knowledge, in 
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addition to secondhand knowledge from the girls 
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themselves, you're aware of at least 20? 
4 (Pages 166 to 169) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
7a82dddl-59ee-4e57-9cd8-1339205600fc0 
EFTA01075990

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Page 172 
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A. At least. 
2 
Q. Okay. And of those girls, other than the one 
3 
girl that we've talked about before that was 24 years 
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old, as you sit here today, all those girls were under 
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age 18; is that correct? 
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MR. CRITTON: Form. 
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THE WITNESS: That I know ot yes. 
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BY MR. KUVIN: 
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Q. And the on one 
're aware of that was over 
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that age of 18 was 
ou 
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A. At 23, yes. 
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Q. Did Jane Doe 101 ever tell you how she first 
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heard about Mr. Epstein? 
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A. No, she did not. 
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Q. What I'm hying to understand is, at some 
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point it seemed like, according toyour testimon that 
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there were a number of girls from 
High 
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School that were going over to Mr. Epstein's home during 
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this period of time in 2005, early 2006. 
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What I'm trying to figure out is, if you know, 
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how did Mr. Epstein or his people get entree into your 
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high school initial) in other words, who was the first 
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person at 
High School, if you know, 
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that started this whole thing? 
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MR. CRITTON: Form. 
1 
whatever, at 
word got around campus. And 
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then girls that 1 were bringing were like, yeah, I know 
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so and so and she did that, like, ninth grade. But it's 
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hearsay. 
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Q. I understand. M., how much older than you 
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was she? 
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A. My age. 
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Q. She was your age? 
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A. She's my age now. 
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Q. Well then, she would have been your age then? 
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A. Yeah. 
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Q. Right? 
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A. Yeah. 
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Q. Okay. Unless she's got a time machine that we 
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don't know about. 
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A. She might. 
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Q. You had heard that she went in ninth grade? 
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A. That is what I heard. 
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Q. Who did you hear that from? 
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A. Multiple people. 
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Q. Are you aware, other than her, of anyone else 
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that went over to Jeffrey's house before you that was 
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going to 
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A. Yes. 
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Q. Who else? 
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2 
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El? 
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Page 171 
THE WITNESS: I have no idea. I do not !mow. 
It wasn't me. 
BY MR. KUVIN: 
Q. Right. Because Jane Doe 101 got you? 
A. Jane Doe 101 got me, that's correct. 
Q. And I'm sorry. I know I asked this before. 
But Jane Doe 101, she was a classmate of yours at 
A. No. I went to 
with her. 
Q. Okay. 
A. Her, 
We weren't friends, didn't hang out. 
Just saw each other through the hallways. 
Q. Well, that's interesting then. 
from 
Ar
wathe 
first girl, that you're aware of, 
High School that went to Mr. Epstein's 
home? 
MR. CRTTTON: Font 
THE WITNESS: No. 
BY MR. KUVIN: 
Q. Who was the first girl that you were aware of 
from 
= 
that went there? 
A.
Q. And how did you become aware of her going? 
A. When I started going and I started bringing 
girls that I was friends with, acquaintances with, 
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Page 173 
A. 
Q. When did she go? 
A. I don't know if she ever worked for him or 
gave him a massage, but she was — she's been to his 
house. 
A. O
i 
or 
(phonetics), I 
think. 
Q. Okay. Who else? 
A. On top of my head, that's all 1 can think of. 
Q. Do you know how to spell 
A. 
Q. 
A. 
Q. And 
A. I. 
Q. And 
A. 
Q. Other than 
Brom 
there? 
.A. 
Q. 
Flow do you II= 
anyone else 
that you're aware of that went over 
PROSE COURT REPORTING AGENCY, 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
5 (Pages 170 to 173) 
INC. 
7a82dddl•59e*Ao57-9cd8439205600fc0 
EFTA01075991

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Page 174 
A. 
Q. Who else? 
A. That's it, that I can think of on the top of 
my head that went before I even heard about him. 
Q. Were you all at school talking about going 
over to this old guys house on the beach? 
MR. CRITTON: Form. 
BY MR. KUVIN: 
Q. I mean, were there any conversations that were 
had around the hallways at school about this issue? 
MR. CRITTON: Font 
THE WITNESS: I had no idea that they had even 
gone until after I met Epstein and was already done 
with my situation. 
BY MR. KUVIN: 
Q. Right. 
A. So this is information that I've learned in 
the last three years — 
Q. Okay. 
A. -- that I hadn't known before. 
The girls and the friends that I hung around 
with, they would all talk about it in the hallways 
because they knew that I was taking them or that they 
met him through me. 
Page 176 
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M. was just - I don't even know what 
2 
category I can put her under. 
3 
Jane Doe 3 was definitely promiscuous. 
4 
I don't really have a category to put M. 
5 
under. She was just kind of the younger one, the not so 
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bright one. 
Q. Got you. When you would ask girls to go, 
would you look for the ones you thought were more 
promiscuous? 
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MR. CRITTON: Form. 
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THE WITNESS: No. No. 
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BY MR. KHVIN: 
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Q. How would you decide which ones to ask? 
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A. They were my friends, the girls that I vent to 
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school with, the ones that I kicked it with after 
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school. They were in my circle. It was convenient. 
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Q. Okay. Call me naive, but how do you convince 
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a girl that age to go to an old man's house, even just 
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to give a massage? 
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MS. BLANTON: Object to the form. Go ahead. 
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I think you were handling the answer just fine. 
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MR.. CRTITON: Form. 
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BY MR. KUVIN: 
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Q. Go ahead. 
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A. That's the thing. I didn't have to convince 
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Page 175 
Q. Right. 
A. But if you mean communication through 
different cliques in the hallway, as, like, an issue, 
no, nobody ever spoke about it. 
Q. Okay. All the girls that you took, what was 
their, I guess for lack a better term, social status 
within the school? I mean, were they popular girls? 
Were they not popular girls? Were there, you know,1 
mean, in sane schools there are, like, the cheerleaders 
and the different groups? 
A. Should I be brutally honest? 
MR. HOROWITZ: I'm going to object to the form 
then. 
BY MR. KUVIN: 
Q. Yes. Brutally honest. 
A. Do you want to include myself in this? 
Q. Let's k 
ou out of it for the moment. 
1 46
A. a
was the party animal. 
and 
and, I believe,.. were the 
cheerleaders. 
Q. Okay. 
A. Jane Doe 7 and Jane Doe 4 were the promiscuous 
ones. 
was - 
not promiscuous, but 
more flirtatious. 
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Page 17 
than. 
Q. What do you mean? 
A. I didn't convince anything. I proposed to 
them. They took it. They volunteered. 
Q. Okay. 
A. Sometimes the girls would come up to me and 
ask me if they can work for him this weekend. There was 
no convincing needed. 
Q. Right. So you would just mention it and —
A. They jumped on it, just like I did. 
Q. Then why did it bother you when you did it the 
first time? 
A. It bothered me more so because I just — I 
can't explain it to you. It didn't bother me then as it 
bothered me now. It bothers me now for different 
reasons. 
Q. Well, do you think you were any less sensitive 
than these girls? 
A. I am definitely less sensitive than those 
girls. 
Q. You see yourself as being more sensitive than 
them? 
A. At times, yes. At other times, no. Pm a 
very hard person. Everybody's sensitive when they want 
to be. You strike somewhere where it hurts, you're 
4.4.5.-M14:41A.Vtaattor.? 
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PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Sandra Townsend (401 
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EFTA01075992

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Page 180 
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going to be sensitive. You're going to &IL 
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Q. And this whole issue with Epstein obviously is 
3 
a sensitive point with you? 
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A. It is. 
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Q. Did 
like the fact that 
went over 
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them, if you know? 
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A. I don't know. 
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Q. Did you ever hear that he was upset about you 
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bringing..? 
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A. We did have a falling out. 
Q. After you brought'.? 
A. After I brought When he found out that I 
Ness going to bring her, yeah, he distanced himself from 
her and me. 
Q. Do you know why? 
A. No. 
Q. Did you hear that he actually punched a wall 
he was so upset? 
MR. CRITTON: Form. 
BY MR. KUVIN: 
Q. Did someone tell you that? 
A. No. 
Q. Have you talked to him since? 
A. We're not as close. 
Q. Have you talked to him at all since? 
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BY MR. HOROWITZ: 
2 
Q. Hi. Good afternoon. My name is Adam 
3 
Horowitz, as I mentioned when we started today. 
4 
A. Okay. 
5 
Q. I represent seven of the Plaintiffs. Pm 
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going to be asking you some questions, sort of filling 
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in some blanks in my mind based on the previous 
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questions and also some particular questions about my 
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clients. Okay? 
10 
Sort of at the beginning of the deposition you 
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told us that Jute Doe 101 first mentioned Jeffrey 
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Bpstein's tune to you at the 
Beach Resort; is 
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that right? 
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A. That is correct. 
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Q. Before that time, you had never heard of him; 
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is that right? 
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A. That's right. I had never heard of him 
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before. 
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Q. But you know now that certain 
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classmates of yours wore already going to his house? 
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A. That's correct. 
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Q. Did Jane Doe 101 ever tell you that she, 
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herself, had gotten paid for giving Mr. Epstein a 
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massage or was she simply a recruiter for him? 
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A. We news discussed that 
Page 179 
1 
A. Yes. 
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Q. Did you talk to him about this incident? 
3 
A. No. Ifs not a conversation that me and him 
4 
have had. Ifs not a conversation that I would like to 
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have with him. 
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Q. Is that the only reason you can think of that 
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you two had a falling out? 
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A. Yes. 
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Q. When you were in the room with Mr. Epstein, 
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did you actually see his genitals? 
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A. I don't remember. I tried not to look. 
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Q. Okay. So as you sit here today, you couldn't 
13 
describe them? 
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A. No. I could not describe them for you. 
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Q. I don't mean obviously his face. I'm talking 
16 
about his genitals. You could not describe those? 
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A. I could not describe his genitals for you. 
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Q. Okay. Did you ever talk tot's parents? 
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A. No. 
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MR. KUVIN: All right. I appreciate it. 
21 
That's all the questions I have at this point 
22 
Other attorneys, I'm sure, are going to have some 
23 
for you. 
24 
(Discussion held off the record.) 
25 
CROSS EXAMINATION 
Page 181 
1 
MR. CRITTON: Form. 
2 
BY MR. HOROWITZ: 
3 
Q. Do you — as we sit here today, do you know of 
4 
anything that took place when Jane Doe 101 went to 
5 
Jeffrey's house? 
6 
A. No. 
7 
Q. Do you know if she ever gave him a massage? 
8 
A. No, l don't 
9 
Q. Do you know if they ever had sexual contact? 
10 
A. No, I do not. 
11 
Q. And you told us that Jane Doe 101 did not 
12 
forewarn you that Jeffrey Epstein would touch you in a 
13 
sexual manner, is that correct? 
14 
MR. CRITTON: Form. 
15 
THE WITNESS: That's correct. 
16 
BY MR. HOROWITZ: 
17 
Q. Did she ever say that he would touch your 
18 
private parts? 
19 
A. No. He never did 
she never did. 
20 
Q. She never told you that? 
21 
A. Sony. 
22 
Q. Did you ever tell her that, in fact, he had 
23 
touched you, as you said, below the belt in the front? 
24 
MR. CRITTON: Form. 
25 
THE WITNESS: I don't remember. 
I
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BY MR. HOROWITZ: 
2 
Q. You don't know if you ever told her that? 
3 
A. I don't know if l ever told her that. 
4 
Q. Was it upsetting to you that she didn't tell 
S 
you that that might occur? 
6 
A. I don't remember. 
7 
Q. Are you, as we sit here today, upset — if she 
8 
knew — strike that. 
9 
If she knew that Jeffrey Epstein had a sexual 
10 
interest in girls, would you have liked to have known 
11 
that before you went to his house? 
12 
MR. CRITFON: Form. 
13 
THE WITNESS: I don't know. 
14 
BY MR. HOROWITZ: 
15 
Q. That might be something you didn't care about 
16 
before you went to his house? 
17 
A. I don't know how to answer that. I don't 
18 
know. I'm not being put in that position. 
19 
Q. Well, was it upsetting to you when he touched 
20 
you in a sexual manner and you had no idea he was going 
21 
to do that? 
22 
A. I don't know. I can't recall my feelings at 
23 
that point in time. 
24 
Q. And you don't recall whether you ever told her 
25 
what had taken place? 
1 
going to touch you in a sexual manner? 
2 
MR. CRITTON: Form. 
3 
THE WITNESS: Yes. 
4 
BY MR. HOROWITZ: 
5 
Q. Now, you -- do you know if she recruited other 
6 
girls to go to Jeffrey's house? 
7 
A. I don't know. 
8 
Q. Has she ever told you that she recruited other 
9 
girls to go to Jeffrey's house? 
10 
A. I can't remember. 
11 
Q. Have you heard from anyone that Jane Doe 101 
12 
recruited other girls to go to Jeffrey's house? 
13 
A. Nobody said anything, no. 
14 
Q. As we sit here today, are you aware— is it 
15 
your understanding that you are the only person that she 
16 
recruited or do you have some other fountain of 
17 
information? 
18 
A. To my knowledge, I'm the only girl that she 
19 
recruited. 
20 
Q. And when she recruited you, did she talk about 
21 
the range of girls that Jeffrey preferred? 
22 
A. No. 
23 
Q. Did she indicate to you at any point how long 
24 
it is that she was -- had been recruiting for Jeffrey 
25 
Epstein? 
Page 183 
1 
A. I don't know if I ever told her. 
Q. Now, when you got done with this 
3 
massage/touching encounter, you went downstairs and you 
I 
saw her on the first floor of the house? 
5 
MR. CRITTON: Form. 
6 
BY MR. HOROWITZ: 
7 
Q. is that right? 
A. I went downstairs. I don't know if she came 
9 
up and got me or inflict her down there, but she was 
10 
waiting for me with 
yes. 
11 
Q. And then you proceeded to ride home --
12 
A. Together. 
13 
Q. Together? Did you tell her any of the events 
14 
that had taken place upstairs in the massage room? 
15 
A. I can't recall. 
16 
Q. Do you think she should have told you that 
17 
Jeffrey Epstein was going to touch you in a sexual 
18 
manna? 
19 
A. Should she have? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: I don't know. Yes. 
22 
BY MR. HOROWITZ: 
23 
Q. Well, which is it] don't know or yes? I'll 
24 
ask the question again so it's clear. 
25 
Should she have told you that Jeff Epstein was 
1 
2 
3 
4 
5 
6 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 185 
A. No, she did not. 
Q. And you told us that when you recruited for 
Jeffrey Epstein, you told the girls that you worked for 
Jeffrey; is that eorree.t? 
A. Yes. 
Q. Did she make a similar pitch to you, I work 
for Jeffrey and I'd like you to come for a massage? 
A. I can't remember. 
Q. Okay. Turning your attention to the encounter 
when you were in the massage room with Jeffrey. When 
Jeffrey Epstein reached below your belt in the front, as 
you described it, did you push him away? 
A. I pushed his hand away. 
Q. You pushed his hand away. 
Did you, like, move away as well? 
A. I don't remember. 
Q. Was that your -- was that your indication to 
him that you were uncomfortable with what it is he was 
doing? 
A. Yes. 
Q. What I'm trying to get at is, that's why you 
pushed him away, to indicate to him you didn't want him 
to touch you that way? 
A. That's correct. 
Q. In a sexual way? 
Y.• 
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A. That's correct. 
2 
Q. Did he continue masturbating after you told 
3 
him — after you pushed his hand away? 
4 
MR. CRITTON: Form. 
5 
THE WITNESS: Yes. 
6 
BY MR. HOROWITZ: 
7 
Q. And you — did you hear him, like, breathing 
8 
heavy? 
9 
MR. CRITTON: Form. 
10 
THE WITNESS: I can't remember. 
11 
BY MR. HOROWITZ: 
12 
Q. Was he masturbating, like, with his hand on 
13 
his penis? 
14 
A. Yes, 
15 
MR. CRITTON: Form. 
16 
BY MR. HOROWITZ: 
17 
Q. And had you looked that way, would his 
18 
genitals have been exposed? 
19 
A. Yes. 
20 
Q. And did he suddenly stop masturbating, as in, 
21. 
when someone has a climax or orgasm? 
22 
A. Yes. 
23 
Q. You distinctly recall that? 
24 
A. Yes. 
25 
Q. At the conclusion of this encounter in the 
1 
Q. He said what? 
2 
A. He had just made a comment about her age when 
3 
he was paying me. He just made a comment, like, you 
4 
know, she was old. 
5 
Q. Meaning, the previous girl --
6 
A. Yes. 
7 
Q. — was old? 
8 
Did Jeffrey — now, you told us that the range 
9 
of the other girls you brought was between ages 14 and 
10 
17; is that alma 
11 
A. Besid 
that's right. 
12 
Q. Did Jeffrey Epstein ever express displeasure 
13 
with the 14 to 17 year old girls that you brought? 
14 
A. !don't know. 
15 
Q. I'm just asking, did he ever express it to 
16 
you? 
17 
A. He never expressed it to me. 
18 
Q. Now, when you were bringing these girls over 
19 
to Jeffrey Epstein's house, did you believe that these 
20 
girls were going ova to Epstein's house so that Epstein 
21 
could have sexual contact with them? 
22 
A. I don't know. 
23 
Q. Now — go ahead. 
24 
A. 1 don't know. I never directly stated 
25 
anything about sexual contact 
Page 187 
1 
massage room, you told us, I think, that Jeffrey Epstein 
2 
asked you to bring other girls. Did I get that right? 
3 
A. Yes. 
4 
Q. What was your response? 
5 
A. I told him, okay. 
6 
Q. You were comfortable with that? 
7 
A. Yes. 
8 
Q. And did you tell him, I'll be in touch, or 
9 
anything along those lines? 
10 
A. I don't tensanber. 
11 
Q. But by then you already had 
lumber, 
12 
telephone number? 
13 
A. At some point 1 had 
number. I don't 
14 
recall if it was before or after the massage. 
15 
Q. Okay. All right. Now, you told us that
16 
on one occasion brought an older girl named 
is 
17 
that right? 
18 
A. That is right. 
19 
Q. Was it Jeffrey Epstein who told you she was 
20 
too old? 
21 
A. Yes. 
22 
Q. And did he tell you that when you arrived in 
23 
the first floor of the house or after the massage or 
24 
when did that conversation take place? 
25 
A. The next girl I brought. 
Page 189 
1 
Q. I got that I'm not asking what you said. 
2 
But in your own mind, when you're bringing these girls 
3 
over, did you think in your own mind, these girls are 
4 
going over to Ertein's house and Epstein is going to 
5 
have some type of sexual contact with them, the same way 
6 
he did with me? 
7 
MR. CRITTON: Form. 
THE WITNESS: I don't know. 
9 
BY MR. HOROWITZ: 
10 
Q. It didn't cross your mind that — 
11 
A. I don't know what crossed my mind seven years 
12 
ago. 
13 
Q. Okay. Did you believe that you were being 
14 
paid cash to bring over girls to Epstein's house for 
15 
sexual pleasure? 
16 
A. No. 
17 
MR. CRITTON: Form. 
18 
BY MR. HOROWITZ: 
19 
Q. What did you think the purpose of the money 
20 
that you were getting was? 
21 
A. To introduce him to girls for massages. 
22 
Q. For massages? 
23 
A. Yes. 
2 4 
Q. You thought that a reason that you were 
25 
getting paid $200 was for an untrained high school girl 
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1 
to give a grown man just a massage? 
2 
A. Yes. 
3 
Q. I'm trying to — was there a part of your 
4 
mindset that thought, I'm also going to get paid for 
5 
giving — for bringing girls to give Epstein sexual 
6 
pleasure? 
A. I didn't receive any sexual pleasure, so 1 
8 
can't make that analysis. 
9 
Q. I'm not asking about your sexual pleasure. 
10 
Pm asking about Epstein's sexual pleasure. 
11 
Was there a part — was there a part of your 
12 
mind that said, I'm getting paid hundreds of dollars to 
13 
bring young, attractive girls to Jeffrey's house so that 
14 
he can have sexual pleasure? Did that cross your mind? 
15 
A. No, it did not. 
16 
Q. As we sit here today, looking back on the 
17 
large sum of money that Jeffrey paid you, thousands of 
18 
dollars, would you agree that he paid you that money so 
19 
you could bring girls for his sexual pleasure? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: I don't know. No. No. 
22 
BY MR, HOROWITZ: 
23 
Q. Well, in your estimation, what do you think 
24 
was the reason he paid you thousands of dollars? 
25 
A. Fora massage, for me to introduce him to 
Page 192 
1 
bit wiser, in your opinion were you paid thousands of 
2 
dollars for Jeffrey Epstein to get sexual pleasure from 
3 
14 to 17 year old girls? 
4 
MIL CRITTON: Form. 
5 
THE WITNESS: No. 
6 
BY Mr. HOROWITZ: 
7 
Q. Did Jeffrey Epstein tell you in particular, 
8 
specifically, I want these girls ova because they're 
9 
good masseuses, that they really improve my back? 
10 
A. No, he never said that. 
11 
Q. And to your knowledge, is there a single girl 
12 
that you brought over that Jeffrey Epstein did not have 
13 
an orgasm with? 
14 
A. Yes. 
15 
MR. CRITTON: Form. 
16 
BY MR. HOROWITZ: 
17 
Q. There's some girls that he did not achieve 
18 
climax? 
19 
A. Yes. 
20 
MR. CRITTON: Form. 
21 
BY MR. HOROWITZ: 
22 
Q. Are there any girls that you're aware of that 
23 
he didn't touch or try to touch in a sexual manner? 
24 
A. No. 
25 
MR CRITTON: Excuse me. Form to the last 
Page 191 
1 
girls to give him a massage. 
2 
Q. Through your different conversations with 
3 
Jeffrey Epstein, you've come to know that he's a very 
4 
affluent man. I mean, you've described him as a 
5 
billionaire. 
6 
MR. CRITTON: Fenn. 
7 
THE WITNESS: Yes. 
8 
BY MR. HOROWITZ: 
9 
Q. Would you agree that if he wanted to, he could 
10 
have the best masseuses in the world? 
11 
MR. CRITTON: Roan. 
12 
THE WITNESS: Yes. 
13 
BY MR. HOROWITZ: 
14 
Q. And yet he wanted these masseuses, in 
15 
particular, from 14 to 17 year old girls; is that 
16 
correct? 
17 
MR. CRITTON: Form. 
18 
MS. BLANTON: Objection. You're asking her to 
19 
speculate on what Jeffrey Epstein wanted or had in 
20 
his mind. If you want to ask her a question about 
21 
what he told her or what she communicated with him, 
22 
that's fine. 
23 
BY MR. HOROWITZ: 
24 
Q. My question is: As you look back on it now, 
25 
having, you know, being a few years older and a little 
Page 193 
1 
question. 
2 
MR. HOROWITZ: Too late. 
3 
BY MR. HOROWITZ: 
4 
Q. How did --
S
MR. CRITTON: Then you need to slow down. 
6 
MIL HOROWITZ: You need to speed up, old man. 
7 
BY MR. HOROWITZ: 
8 
Q. How did you go about recruiting? 
9 
MR. CARTON: Ill smile. 
10 
BY MR. HOROWITZ: 
11 
Q. How did you go about — how did you go about 
12 
recruiting thegirls that were in your social circle at 
13 
High School? Was it always 
14 
face-to-face or was it ever telephone? E-mail? Text? 
15 
A. Sometimes over the phone. Sometimes when I'd 
16 
run into them in the hallways at school or hang out with 
17 
them, so face-to-face, over the phone. 
18 
Q. Would you always have these 
take a girl 
19 
that you went to high school — give me a name of 
20 
somebody who you went to high school with. 
21 
A. Jane Doe 4. 
22 
Q. Okay. Jane Doe 4. When you spoke to Jane Doe 
23 
4 and told her for the first time about Jeffrey Epstein 
24 
and this opportunity, did you tell her - was anybody 
25 
else there when you told her? 
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2 
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6 
7 
9 
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13 
14 
15 
16 
17 
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20 
21 
22 
23 
24 
25 
A. I don't recall. 
Q Did you tell her in person, by phone or howl 
A. I don't recall. 
Q. What about Jane Doe 7? Did you tell her —
was it a one-on-one type of conversation? 
A. I really don't recall. 
Q. What about Jane Doe 2? Was that in person 
Or •••• 
A. Jane Doe 2. 
Q. Do you recognize that name? 
A. I never brought her. 
Q. Jane Doe 3? 
A. Jane Doe 3, I don't recall. 
Q. You don't recall whether — I didn't even ask 
a question. You don't recall whether it was in person 
or by telephone, anything of that sort? 
A. I don't recall how I told her. 
Q. But each of these girls, it was always, like, 
a private kind of one-on-one conversation or would you 
sort of announce it in the cafeteria or the classroom 
MR. CRITTON: Form. 
THE WITNESS: I don't think I ever announced 
it in the cafeteria, but I don't know. 
BY MR. HOROWITZ: 
1 
THE WITNESS: Yes. 
2 
BY MR. HOROWITZ: 
3 
Q. What would you say? 
4 
A. I would just talk to them, hey, listen, you 
5 
!mow, I know this guy, his name is left hes on the 
6 
Island, he has a lot of money, he's a billionaire, you 
7 
know, he's looking for girls to give massages. Are you 
8 
interested? 
9 
And then obviously if they were interested, I 
10 
would go into a little bit more detail, you know, 
11 
exchange dates and times that they were available. 
12 
Q. And ou would always clear those dates and 
13 
times with 
or somebody else? 
14 
A. 
15 
Q. Am I correct in is all that you told the girls 
16 
in regard to the services they had to render was that 
17 
they were getting money for massages? 
18 
A. I told them they would get $200 for a massage. 
19 
The more you do, the more you make. 
20 
Q. Well, you told us earlier that they were 
21 
getting paid for massages. 
22 
A. They were getting paid for massages. 
23 
Q. And that's what you told them? 
24 
A. That is what I told them. 
25 
Q. Thank you. 
Page 195 
1 
Q. Would you make an effort to have a private 
2 
conversation about this subject? 
3 
A. Depending. Depending on the girl. 
4 
Q. Well, give me the, if you can, the variables. 
5 
What would weigh in favor of making son of a public or 
6 
semi-public announcement about this and what would weigh 
7 
in favor of having a private conversation? 
8 
A. Wellwith Jane Doe 4 it had to be private 
9 
because if 
her old boyfriend, found out, he 
10 
would beat the aap out of her. So she was somebody 
11 
that I went to privately. 
12 
MR. HOROWITZ: Move to strike. 
13 
THE WITNESS: Also, depending on what the 
14 
girls were like, I mean, some are very jealous when 
15 
it comes to money. It depends. The other girls 
16 
didn't like it when they weren't working and the 
17 
other girl was. So usually I probably bad to just 
18 
do it privately. A lot of them were very not 
19 
wanting other girls to work for him. 
20 
BY MR. HOROWITZ: 
21 
Q. Did you— did you have a standard sales 
22 
pitch, so to speak, in recruiting these girls, like, 
23 
what you would tell each of them in order to get them to 
24 
go to Jeffrey Epstein's house? 
25 
MR. CR1TTON: Form. 
Page 197 
1 
You told us that you an understand — a moment 
2 
ago you told us that you had an understanding that the 
3 
more girls did, the more they got; is that right? 
4 
A. Yes. 
5 
Q. Where did you come up with this understanding? 
6 
A. Jane Doe 101 told me that, so I just passed it 
7 
along. 
8 
S 
Was that a theme that — or a message that 
9 
also told you? 
10 
A. No. 
11 
Q. Did Jeffrey ever tell you that? 
12 
A. No. 
13 
Q. Did anybody who worked or was connected with 
14 
Jeffrey tell you that? 
15 
A. No. 
16 
Q. So you took Jane Doe 101 at her word that the 
17 
more — the more the girls did, the more they got paid? 
18 
A. That's comet. 
19 
Q. And do you know if, in fact, that is a true 
20 
statement? 
21 
A. I don't know. 
22 
Q. In terms of the more you get the more you 
23 
do, the more you get paid, what were the — on the low 
24 
end of the scale, the less you did, the less you got 
25 
paid, what would be the lesser activities? 
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A. The lesser activities? I don't know. 
2 
Q. Well, -- and how much would you get paid on 
3 
the lesser end? 
4 
A. I don't know. 
5 
Q. And then on the higher end, when you say the 
6 
more you did, the more you got paid, what sort of things 
7 
are we talking about? 
$ 
A. Whatever the girl allowed him to do or 
9 
whatever their situation was. I don't know. I was 
10 
never in the room with them. I just took what Jane Doe 
11 
101 said and passed it down. 
12 
Q. Well, did anyone ever say, well, what does 
13 
that mean, the more you do, the more you get paid? 
14 
A. Yes. 
15 
Q. And how would you explain that? 
16 
TIE WITNESS: Didn't we already discuss this? 
17 
The more you do, the more you make. If you 
18 
were topless, if you were working in your thong, 
19 
your bra, you're going to make more than a hundred, 
20 
as to somebody who is always complaining about 
21. 
money and never takes off her shirt 
22 
BY MR. HOROWITZ: 
23 
Q. So a hundred is the low end? 
24 
A. You could say that 
25 
Q. What's the high end? If you really did a lot 
Page 200 
1 
A. Either 
would call me or I'd call 
2 
and we'd work it out to where when Jeffrey was coming 
3 
home I would have a girl that would be available for 
4 
those dates and times. 
5 
Q. So you would — you would get a heads up 
6 
before he came into Florida? 
7 
A. Ulthuh. 
8 
Q. Yes? 
9 
A. Yes. 
10 
Q. Okay. And would MI give you that 
11 
information by telephone? 
12 
A. Yes. 
13 
Q. Would she call your home phone or cell phone? 
14 
A. Cell phone. 
15 
Q. And where would she be calling you from? 
16 
A. I don't know. 
17 
Q. Did you get the sense that she lived with 
18 
Jeffrey? 
19 
MR. CRITTON: Form. 
20 
THE WITNESS: Yes. 
21 
BY MR. HOROWITZ: 
22 
Q. Would she ca/ I you horn his home? 
23 
A. I don't remember. 
24 
Q. You told us or you told Mr. Kuvin that you 
25 
told the girls to say that they were 18 years old? 
Page 199 
1 
of stuff with Jeffrey, what would you — how much money 
2 
could you make? 
3 
MR. CRITTON: Form. 
4 
THE WITNESS: I heard about 300. 
3 
BY MR. HOROWITZ: 
G 
Q. Three hundred. And what sod of sexual 
7 
contact or nudity would you have to do to get that kind 
3 
of money? 
MR. CRITTON: Form. 
10 
THE WITNESS: I don't know. I wasn't in the 
11 
room. 
12 
BY MR. HOROWITZ: 
13 
Q. And you just don't know from hearing it from 
14 
other people? 
15 
A. 1 don't know. 
16 
!t 
How would you know the — you told us that 
17 
I= was always the person who gave you the dates and 
18 
times for appointments. How would she communicate that 
19 
to you? 
20 
A. Can you repeat the question? 
21 
Q. Yeah. If you were to recruit a girl and she 
22 
was interested and you said you would tell her potential 
23 
dates and time and things like that. How would you have 
24 
that knowledge? How would you know available dates and 
25 
times? 
Page 201 
1 
A. Yes. 
2 
Q. Can you specifically recall telling that to 
3 
every we of the girls that you recruited? 
4 
A. Yes. 
5 
Q. And why would you tell them that? 
6 
A. Jane Doe 101 told me to tell him that. 
7 
Q. So you just — 
8 
A. Jane Doe 10I told me. I passed it down. 
9 
Q. Now, were you physically present when all of 
10 
the girls went for their encounters with Jeffrey 
11 
Epstein; meaning, were you upstairs in the massage room 
12 
for any of them? 
13 
A. No. 
14 
Q. So would it be — do you know if any of the 
15 
girls, in fact, told Jeffrey Epstein, I'm 18? 
16 
A. No. 
17 
Q. Do you have — I'm trying to work through this 
18 
because we're getting late in the day. 
19 
Did you get the same payout for each of the 
20 
girls that you brought? 
21 
A. What do you mean? 
22 
Q. For a -- name a particular girl. 
23 
A. Jane Doe 4. 
24 
Q. Would you get paid $200 for every girl that 
25 
you brought? 
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A. Yes. 
2 
Q. Were that any girls that you got paid less 
3 
for? 
4 
A. No. 
5 
Q. Would you ever get paid more than 200 for 
6 
bringing a girl? 
7 
A. No. 
8 
Q. Was your payout based on what Epstein did with 
9 
the girls or what the girls did with Epstein? 
10 
A. No. 
11 
Q. It was just for sort of brokering the deal, 
12 
getting them in the same place at the same time? 
13 
MR. CIUTTON: Form. 
14 
TILE WITNESS: Yes. 
15 
BY MR. HOROWITZ: 
16 
Q. Ii; for instance, a girl you recruited, just 
17 
an example, say, Jane Doe 7. If she came ten times, 
18 
would you get paid ten times or how did that work? 
19 
A. If I — sometimes I would get paid 5200 for 
20 
every girl. Other times, for instance, if I was to 
21 
bring Jane Doe 7 more than once, I might be able to 
22 
sneak in and get paid more than once. But usually it 
23 
was Just 200 for every girl. 
24 
Q. But there were sometimes in some — in the 
25 
case of some girls that you got paid more than once for 
1 
need a restroom break. 
2 
MR. HOROWITZ: That's fine. I'm not holding 
3 
anyone captive. 
4 
VIDEOGRAPHER: Going off the record, 3:45. 
5 
(Brief recess.) 
6 
VIDEOGRAPHER: We're back on the video record. 
7 
The time is 3:57. 
8 
BY MR. HOROWITZ: 
9 
Q. Have you ever been to Jeffrey Epstein's house 
10 
when you were not there to give a massage or to bring a 
11 
girl who was there to give a massage? 
12 
A. No. 
13 
Q. So every time that were you ever somewhere 
14 
other than Jeffrey Epstein's house With Jeffrey Epstein? 
15 
A. No. 
16 
Q. So all of your contact, personal contact with 
17 
him was at his house; is that right? 
18 
A. Yes. 
19 
Q. And it was always in the course of bringing — 
20 
either going with Jane Doe 101 or bringing one or more 
21 
girls? 
22 
A. Yes. 
23 
Q. Have you ever travelled with Jeffrey Epstein? 
24 
A. No. 
25 
Q. Have you ever travelled with someone who 
Page 203 
1 
that same girl? 
2 
A. Yes. 
Q. Now, if one of the girls who you recruited in 
turn recruited another girl, would you get paid as well? 
▪ 
A. I'm cut out of that deal. 
• 
Q. You're cut out of the deal? 
A. Uh-huh. 
a 
Q. Did you ever talk to Jeffrey or 
about 
9 
whether you should be included in that deal? 
10 
A. No. 
11 
Q. Were you always paid in cash? 
12 
A. Yes. 
13 
Q. And who gave you the money, like, physically 
14 
handed you the money? 
15 
A. Epstein. 
16 
Q. While you were upstairs or while you were 
17 
downstairs? 
18 
A. I don't remember. 
19 
Q. And would it 
would you get paid in front of 
20 
the girls you had brought? 
21 
A. No. 
22 
Q. You would — and would they get paid in front 
23 
of you? 
24 
A. Not that I can remember, no. 
25 
MS. BLANTON: If you're at a good point, I 
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 205 
worked for him? 
A. No. 
Q. Have you ever been in a favorer's office with 
Jeffrey Epstein? 
A. No. 
Q. Have you ever been in a vehicle owned or 
controlled by Jeffrey Epstein? 
A. No. 
Q. Have you ever been invited to travel with 
Jeffrey Epstein? 
A. No. 
Q. Did Jeffrey Epstein talk to you about 
properties that he owned? 
A. No. 
Q. Did he ever talk to you about businesses that 
he owned? 
A. No. 
Q. Did he ever talk to you about how he 
accumulated his wealth? 
A. Yes. 
Q. What sort of things would he tell you? 
A. He told me he was a scientist. 
Q. You're laughing. 
A. He did. 
Q. You know he's not a scientist? 
13 (Pages 202 to 205) 
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Page 206 
Page 208 
1 
MR. CRITTON: Form. 
2 
THE WITNESS: Obviously I know that now. 
3 
BY MR. HOROWITZ: 
4 
Q. You lmow he's a child molester? 
5 
MR. CRITTON: Form. Argumentative. 
6 
BY MR. HOROWITZ: 
7 
Q. Right? 
A. No, I do not know that. 
9 
BY MR. HOROWITZ: 
10 
Q. You know he touches underage girls for sexual 
11 
pleasure? 
12 
A. I don't blow that. 
13 
Q. You know he touched at least one girl for 
14 
sexual pleasure, right? 
15 
MR. CRITTON: Form. 
16 
BY MR. HOROWITZ: 
17 
Q. Yes? 
18 
A. I don't ;mow that. 
19 
Q. Do you know if he — well, you've told us he 
20 
touched you for sexual pleasure, correct? 
21 
A. Tried. 
22 
MB. CRITTON: Form. 
23 
BY MR. HOROWITZ: 
24 
Q. !mean — but he did touch you. You told the 
25 
police that'? 
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 
A. I don't even remember. 
Q. I'm going to ask the question again because 
there was — I'm not sure there was an objection, just 
kind of an interruption, exactly. 
Other than a statement that you made in the 
police car regarding MM, 
what else did you 
discuss with the police when you were in the police air? 
MR. CRITTON: Let me just object to the form 
because she just said she couldn't talk about MI 
MR. HOROWITZ: Are you instructing her? I'm 
saying, other than. 
MR. CRITTON: Yeah, but you're trying Sa rick 
her into suggesting that maybe she did say 
M. So you've got to be careful with your 
questioning. I think that was inappropriate. 
THE WITNESS: I don't even remember the ride. 
MR. HOROWITZ: If it was inappropriate --
MR. CRITTON: I don't think it was 
intentional. I don't think it was intentional. 
Maybe you're too young to understand. 
BY MR. HOROWITZ: 
Q. Eliminate — 
MR. HOROWITZ: That's true. 
BY MR. HOROWITZ: 
Page 207 
1 
A. Yes. 
2 
Q. And you know he masturbated while looldng at 
3 
you while you were l6 or I7 years old? 
4 
A. Yes. 
5 
Q. You were asked some questions by Mr. Kuvin 
6 
about your travel in the police car. Do you recall 
7 
those questions? 
8 
A. Yes, Id°. 
9 
Q. Where were you going to? Where were you 
10 
coming from and where were you going to? 
11 
A. They picked me up at my house, took me down to 
12 
the station and then they brought me home to my house. 
13 
Q. So you're going — this conversation that 
14 
you've been talking about was in the —
15 
A. In the police car. 
16 
Q. Going from the police station downtown to your 
17 
home; is that right? 
18 
A. That is right. 
19 
Q. Okay. Other than an statement made in the 
20 
police car regarding 
which your attorney 
21 
has already told you not to answer, what else did you 
22 
discuss with the police? 
23 
MR. BLANTON: I'm sorry. When? 
24 
BY MR. HOROWITZ: 
25 
Q. When you were in the vehicle. 
Page 209 
1. 
Q. Exclude any conversation or non-conversation 
2 
that you had regarding-. 
Put that out of 
3 
your mind, if it at all ever occurred. 
4 
Tell me about what else you discussed with the 
5 
police In the police car. 
6 
A. I don't remember. 
7 
Q. Did you tell the police that Jeffity Epstein 
8 
admitted to you that he was a serial pedophile? 
9 
MR. BLANTON: She just testified that she does 
10 
not — 
11 
MR. HOROWITZ: I'm hying to — there's an art 
12 
of questioning where you try and refresh people's 
13 
recollection. You go with the general and then you 
14 
narrow it to the specific. 
15 
BY MR. HOROWITZ: 
16 
' 
Q. And, so, my question for you is: Did you tell 
17 
the police that Jeffrey Epstein admitted to you that he 
18 
was a serial pedophile? 
19 
A. No, he never admitted.that. That is absurd. 
20 
Q. Did you tell — did you tell the police that 
21 
Jeffrey Epstein was a pedophile who paid you to bring 
22 
girls for his sexual gratification? 
23 
MR. CRITTON: Form. 
24 
THE WITNESS: No, I did not tell the police 
25 
that [told him he was a serial pedophile that paid 
e.V.I•movaVa.mi-wnwv 
14 (Pages 206 to 209) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
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Page 210 
me for sexual acts or brought anybody or for sexual 
2 
acts. 
3 
BY MR. HOROWITZ: 
4 
Q. Did you tell the police that Jeffrey Epstein 
5 
had paid you thousands of dollars to bring 14 to 17 year 
6 
old girls to his home so he could masturbate? 
MR. CRM'ON: Form. 
DIE WITNESS: I don't recall that. 
9 
BY MR. HOROWITZ: 
10 
Q. Did you tell the police that Jeffrey Epstein 
11 
admitted sexually abusing Jane Doe 7? 
12 
A. No, he didn't admit to sexually abusing Jane 
13 
Doe 7. 
14 
Q. Did you ever have a conversation with him 
15 
about what took place with Jane Doe 7? 
16 
A. No. 
17 
Q. Did you ever have a conversation with Jeffrey 
18 
Epstein about what took place between him and Jane Doe 
19 
4? 
20 
A. Yes. 
21 
Q. Did you ever have a conversation with Jeffrey 
22 
Epstein as to what took place between him and Jane Doe 
23 
3? 
24 
A. No. 
25 
Q. Tell me everything that Jeffrey Epstein told 
Page 212 
1 
4 that Jeffrey Epstein said that she was one of his 
2 
favorites? 
3 
A. I don't terember. 
4 
Q. Was she — do you know — strike that. 
5 
How many times did you go to Jeffrey Epstein's 
6 
house with Jane Doe 4? 
A. I don't recall. 
8 
Q. Was it more than once? 
9 
A. Possibly. I don't recall. 
10 
Q. Was it at least once? 
11 
A. At least once. 
12 
Q. And you're not sure if it was more than once 
13 
then? 
14 
A. I'm not sure if it was more than once. 
15 
Q. Do you have a specific recollection about what 
16 
took place on the one occasion that you do recall? 
17 
A. No. 
18 
Q. Do you know whether you drove in a vehicle 
19 
with her to Jeffrey Epstein's house on that occasion? 
20 
A. I do remember an occasion me and Jane Doe 4 
21 
being in a car driving and pulling up to Epstein's house 
22 
in her mom's Buick. 
23 
Q. In her mom's Buick. And who was driving? 
24 
A. I don't remember. 
25 
Q. And were you an older, younger or in the same 
1 
2 
3 
4 
5 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 211 
you about what he and Jane Doe 4 talked about or did 
together. 
A. All he said was that she was like day and 
night She had this wild side to her and he had, like, 
a nickname of, like, 
or some ridiculous thing 
like that. It's the only thing we discussed when it 
came to Jane Doe 4. 
Q. You also told us that she was one of his 
favorites, correct? 
A. Yes. 
Q. And another one of his favorites wasl.; is 
that right? 
A. Yes. 
Q. And thinking about the two of them when they 
14 
were 16, 17 years old, did they share any common 
15 
physical characteristics? 
16 
A. No. 
17 
Q. Do they resemble each other physically? 
18 
A. No. 
19 
Q. Nothing at all? 
20 
A. No. 
21 
Q. Did you ever ask Jeffrey Epstein what he meant 
22 
when he said that Jane Doe 4 was one of his favorites? 
23 
A. No. 
24 
Q. Did you ever ask — did you ever tell Jane Doe 
25 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
Page 213 
grade as Jane Doe 4? 
A. I was in a grade above her. 
Q. Was she younger than you? 
A. That's right. 
Q. What grade was she in when you pulled up to 
Jeffrey Epstein's house with her? 
A. I don't recall. 
Q. Do you know if it was when she was in the 
ninth grade? 
A. No, I do not 
Q. Do you know if it was when she was in the 
tenth grade? 
A. N0,11 do not 
Q. Do you know if it was when she was in the 11th 
grade? 
A. No, I do not 
Q. And what took place after you and Jane Doe 4 
arrived at Jeffrey Epstein's house? 
A. I don't remember. 
Q. Do you have a recollection of seeing her of 
her getting paid? 
A. No. 
Q. Do you have a recollection of you getting 
paid? 
A. No. 
PROSE COURT REPORTING AGENCY, 
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Electronically signed by Sandra Townsend (401 
15 (Pages 210 to 213) 
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Page 214 
Page 216 
1 
Q. Were you paid? 
2 
A. I don't remember. 
3 
Q. Do you know how long the two of you stayed at 
4 
his house? 
5 
A. No. 
6 
Q. Do you know if anybody else was home or in 
7 
Jeffrey Epstein's house when the two of you went? 
8 
A. I don't recall. 
9 
Q. Anything stand out or, you know, that you can 
10 
recall, other than what you've told us about the day 
11 
that you and Jane Doe 4 went to Jeffrey Epstein's house? 
12 
A. It was cold out. We went out afterwards. 
13 
Q. Anything else? 
14 
A. (Nods head.) 
15 
Q. Did no? 
16 
A. No. 
17 
Q. Did she tell you at any point what took place 
18 
on that particular day? 
19 
A. No. 
20 
Q. Did you ask her? 
21 
A. Yes. 
22 
Q. And what did she say? 
23 
A. I don't recall. 
24 
Q. Was it a weekday or weekend? 
25 
A. I don't know. 
1 
a vehicle together? 
2 
A. Yes. 
3 
Q. And had you scheduled this with M? 
4 
A. Yes. 
5 
Q. By telephone? 
6 
A. Yes. 
7 
Q. And who drove? 
8 
A. I don't remember. 
9 
Q. AM when you arrived, what took place? 
10 
A. I don't recall. 
11 
Q. Do you recall how long you were there? 
12 
A. No. 
13 
Q. Do you recall getting paid for bringing Jane 
14 
Doe 7? 
15 
A. Yes. 
16 
Q. Do you recall her getting paid? 
17 
A. I don't remember. 
18 
Q. Do you recall anything you told her about what 
19 
you thought might take place? 
20 
A. No, I don't remember. 
21 
Q. Do you recall if she told you what it is that, 
22 
in fad, did take place between her and Jeffrey Epstein? 
23 
A. I don't remember. 
24 
Q. Do you recall her going upstairs to the 
25 
massage room? 
Page 215 
1 
Q. Given that you were in high school when you 
2 
were recruiting these girls, was it fair to say you 
3 
would always go after school or on the weekends when you 
4 
went to Jeffrey Epstein's house? 
5 
A. It would be fair to say that it was either 
6 
after school or on the weekends. 
7 
Q. Would you ever miss school or go during school 
8 
to Jeffrey Epstein's house? 
9 
A. No. 
10 
Q. Did -- was Jeffrey Epstein familiar with your 
11 
school schedule, such that he could schedule 
12 
appointments after your school day ended? 
13 
A. No. 
14 
Q. Well, how is it — how did it come to be that 
15 
you would never get scheduled to come in during the 
16 
school day? 
17 
MR. CRITION: Form. 
18 
THE WITNESS: I don't know. It was usually 
19 
the weekends. 
20 
BY MR. HOROWITZ: 
21 
Q. How many times did you take Jane Doe 7 to 
22 
Jeffrey Epstein's house? 
23 
A. I know for sure once, but I can't be positive 
24 
anything else after. 
25 
Q. Tell me how — did the two of you ride over in 
Page 217 
1 
A. I don't remember. 
2 
Q. Did you set up the massage table that day? 
3 
A. Don't remember. 
4 
Q. Did you wait downstairs while she was giving a 
5 
massage? 
6 
A. I don't remember. 
7 
Q. Anything you do remember about the time you 
8 
spent at Jeffrey Epstein's house with Jane Doe 7? 
9 
A. No,1 don't remember. 
10 
Q. And you can't recall if it was more than once? 
11 
A. I can't recall. 
12 
Q. Are you aware whether or not she went more 
13 
than once to his house? 
14 
A. She did go more than once. 
15 
Q. You know that because she told you or some 
16 
other way? 
17 
A. Because she told me. 
18 
MR. CRITTON: We're on Jane Doe 7 now? 
19 
MR. HOROWITZ: Yes. 
20 
BY MR. HOROWITZ: 
21 
Q. And briefly just going back to Jane Doe 4, are 
22 
you aware whether or not she went more than once? 
23 
A. She definitely went more than once. 
24 
Q. And how do you know that? From her, Jeffrey 
25 
or some other place? 
16 (Pages 214 to 217) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 218 
1 
A. Her, Jeffrey. Jane Doe 7 told me. 
2 
also told me a couple times. 
3 
Q. And in the case of Jane Doe 4, would you have 
4 
been paid your $200 introductory fee once or more than 
5 
once? 
6 
A. I don't remember. 
7 
Q. And what about with Jane Doe 7? 
8 
A. I don't remember. 
9 
Q. And next we're on to Jane Doe 3. Do you know 
10 
how many times you were there at Jeffrey Epstein's house 
11 
when she was also there? 
12 
A. I took her once. Anything after that I don't 
13 
remember. 
14 
Q. Go ahead. 
15 
A. I went once to take her for a massage and then 
16 
me and her brought another girl named'. So that's 
17 
twice I know that she worked with him, once that me and 
18 
her went together to take a girl. Other than that, I 
19 
don't know if she went back, how many times or who she 
20 
brought. 
21 
Q. The day when you brought this other girl named 
22 
I. — is that her name? 
23 
A. Yes. 
24 
Q. Was that a mutual friend of you and Jane Doe 
25 
3? 
Page 220 
THE WITNESS: I mean, there was — the house 
2 
was -- there was always people in the house, 
3 
regardless if it was models, a chef, a chauffeur, 
4 
butler, whatever. There was always somebody in the 
5 
house. 
6 
BY MR. HOROWITZ: 
7 
Q. And do you recall ever talking to them? 
8 
A. I'm sure I did. 
9 
Q. Did anything — do you remember any of the 
10 
conversations you had or the subjects you talked about? 
11 
A. No. 
12 
Q. Did they ever feed you at that house? 
13 
A. I've eaten there, yes. 
14 
Q. Was it a meal you made yourself or someone 
15 
made it for you? 
16 
A. No. 
17 
Q. Who made it for you? 
18 
A. The chef. 
19 
Q. Did you ever lay out at the pool? 
20 
A. Not in a bathing suit. A girl upstairs was 
21 
giving a massage and I was laying out by the pool in my 
22 
clothes, just waiting for her to come downstairs. I 
23 
wasn't doing it to get sun. 
24 
Q. Getting paid while you were lying out at the 
25 
pool? 
Page 219 
1 
A. It was more so Jane Doe 3's friend, but I had 
2 
it to where me and her would split the profit. 
3 
Q. That was my next question, who got the 
4 
commission? 
5 
A. We split it. 
6 
Q. IIt
n ui
s lit it. Okay. 
7 
. went -- ME go upstairs to the 
8 
massage room? 
9 
A. Yes. 
10 
Q. Did you and Jane Doe 3 wait downstairs? 
11 
A. I don't recall. 
12 
Q. Do you recall anything about what you and Jane 
13 
Doe 3 did while you were in Jeffrey Epstein's house 
14 
while' was giving a massage? 
15 
A. I don't remember. 
16 
Q. Do you recall whether anyone was in the house, 
17 
Jeffrey Epstein's house? 
18 
A. I don't recall. 
19 
Q. Thinking back on it, when you would bring 
20 
girls over to Jeffrey Epstein's house and you would wait 
21 
downstairs while the girl and Jeffrey Epstein went 
22 
upstairs, was someone at his house watching you or 
23 
looking after you to make suit you didn't get into 
24 
trouble or take anything or --
25 
MR. CRITTON: Form. 
Page 221 
1 
A. Waiting for the girl to come downstairs, yes. 
2 
Q. Did you ever go kind of snooping around the 
3 
house, looking around to see the different rooms in the 
4 
house? 
5 
A. No. 
6 
Q. Did 
ever show you a datebook or 
7 
appointment book? 
a 
A. I don't remember. 
9 
Q. Did she ever show you a calendar where you 
10 
could sort of fit in your appointments? 
11 
A. No. 
12 
Q. Did she ever talk to you about having —
13 
keeping a datebook --
14 
A. No. 
15 
Q. -- or a calendar with appointments? 
16 
A. A calendar, no. 
17 
Q. When — did Jeffrey Epstein ever take pictures 
18 
of you? 
19 
A. Not that I !mow of. 
20 
Q. When you went to his house, did you ever 
21 
notice there was surveillance cameras? 
22 
MR. CRITTON: Form. 
23 
THE WITNESS: No, I did not !mow that. 
24 
BY MR. HOROWITZ: 
25 
Q. Did -- did Jeffrey Epstein have anyone that 
VCAOL.4.ee'ves••••••1•4N 
17 (Pages 218 to 221) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 222 
1 
you might characterize as a girlfriend or a partner? 
2 
A. Somebody that I can characterize as? 
3 
Q. Somebody that you — that you sort of looked 
4 
at and said, okay, that's his girlfriend? 
5 
A. 
Q. And what about their relationship led you to 
1 
think that they were boyfriend/girlfriend? 
9 
A. Just the way they were towards each other, how 
9 
she always helped him out. She always set his 
10 
appointments. There was one time — I don't know if I 
11 
was taking a girl upstairs or if it was my massage that 
12 
I gave him — but she was in the shower, coming out of 
13 
the shower with him. 
14 
Q. You were where? 
15 
A. I don't know. I can't remember if I was 
16 
bringing — if I had brought a woman up there to give a 
17 
massage or if I had -- was there to give him my massage. 
18 
But either/or I do recollect her and Epstein coming out 
19 
of the shower together. 
20 
Q. Okay. Appearing as if they had showered 
21 
together? 
22 
A. That's correct. 
23 
Q. And were they affectionate to each other? 
24 
MR. CRITTON: Form. 
25 
BY MR. HOROWITZ: 
Page 224 
1 
upstairs with one of the kids? 
2 
MR. CRITTON: Form. 
3 
THE WITNESS: I never heard anything. 
4 
BY MR. HOROWITZ: 
5 
Q. Is Jane Doe 7 someone that you considered a 
6 
friend at the time that you recruited her to go to' 
7 
Jeffrey Epstein's house? 
8 
A. Not necessarily a friend. A party buddy. 
9 
Q. Social — social acquaintance? 
10 
A. Yes. 
11 
Q. Someone that you had a good time with? 
12 
A. Yes. 
13 
Q. Is she someone that you would now go out and 
14 
have a good time with? 
15 
A. Never. 
16 
Q. What took place between then and now — well. 
17 
let me backup. 
18 
Do you not -- do you not like her at this 
19 
point in time? 
20 
A. I don't wish ill upon her. 
21 
Q. My question is: Do you not like her? 
22 
A. I don't like her. 
23 
Q. What took place between then and now that you 
24 
do not like Jane Doe 7? 
25 
A. When 
and I came home 
Page 223 
1 
Q. From your perspective did she appear to be 
2 
affectionate? 
3 
A. I don t recall. 
4 
Q. Would they say the types of things or call 
5 
each other, honey, sweetheart or anything like that? 
6 
A. Not that I can remember. 
7 
Q. Were they physically affectionate, meaning, 
8 
sort of touch each other in a way that a 
boyfriend/girlfriend might touch their partner? 
10 
A. Not that I saw. 
11 
Q. Did they ever kiss? 
12 
A. Not around me. 
13 
Q. When Jeffrey Epstein, when you came to his 
14 
house, would he ever kiss or embrace you when you saw 
15 
him each time? 
16 
A. No. 
17 
Q. I mean, he would just say, hello? 
18 
A. Yes. 
19 
Q. I hate to do this, but try and think back to 
20 
the day you were in his massage room and he's 
21 
masturbating, his hand is on his penis. Is he groaning, 
22 
making noises? 
23 
A. I can't recall. 
24 
Q. Did you ever hear Jeffrey Epstein groaning, 
25 
making noises while you were downstairs and he was 
Page 225 
1 
in tears sobbing, I was very emotional. It was a very 
jjjj
2 
trying day forme. I had gone into my bedroom and I w•as 
3 
throwing things. I was very upset. 
4 
She came in and told me to put some clothes on 
5 
and to come out drinking with her and =. 
And I 
6 
just felt at that point in my life, I hit a low point 
7 
and you are supposed to be my roommate, you're supposed 
8 
to be my somewhat friend, acquaintance, we live 
9 
together, you have no heart, you show no love to me 
10 
after all these years and all you want me to do is go 
11 
and get completely annihilated with you? 
12 
Q. Is that the reason you don't like her anymore? 
13 
A. That's one of the reasons. 
14 
Q. I'm trying to get a full list or if there's --
15 
or however many masons there are. 
16 
What are the other reasons you don't like Jane 
17 
Doe 7? 
18 
A. She -- when me and her, we would go out and 
19 
party sometimes, every guy I would talk to she would end 
20 
up with at the end of the night A lot of back 
21 
stabbing. Her and Jane Doe 4 would go behind my back 
22 
and talk very bad about me and say things and judge me, 
23 
which friends don't do. That's why I classify her as a 
2 4 
party buddy. 
25 
Q. Okay. 
18 (Pages 222 to 225 
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Electronically signed by Sandra Townsend (401 
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1 
A. Other than that, I don't have a personal 
2 
vendetta against her. 
3 
Q. Does anything — I asked you if you don't like 
4 
her and you said, yes. Does any of the reasons you 
5 
don't like her have anything to do with Jeffrey Epstein? 
6 
A. Yes. 
7 
Q. I'm trying to get all these reasons out of 
8 
you. Tell me all the reasons. 
9 
A. She volunteered for this. 
10 
Q. You don't like her for that reason? 
11 
A. She volunteered for this. I didn't. I've 
12 
paid a higher price than I feel she has. AM everybody 
13 
knew what they were getting themselves into prior to 
14 
this. 
15 
Why am I sitting here having to explain myself 
16 
while you party it up? 
17 
Q. You don't like her because she volunteered-
18 
A. Togo. 
19 
Q. 
to go to Jeffrey Epstein's house? 
20 
A. That's correct. 
21 
Q. Unlike you, who — did you volunteer? 
22 
A. I volunteered, too. 
23 
Q. And would it be a fair statement you don't 
24 
want her to get any money in this lawsuit; is that 
25 
right? Because you don't like her? 
Page 228 
1 
this lawsuit berimce she's a bad -- you don't like her? 
2 
A. I don't care. I don't care either way. 
3 
MR. CRTITON: Form. 
4 
BY MR. HOROWITZ: 
5 
Q. You don't care either way. 
6 
It would be okay with you if she gets millions 
7 
of dollars for her pain and suffering? 
8 
A. Sure. 
9 
Q. What are all the reasons you don't like her? 
10 
A. Oh, one of the guys I was dating she was 
11 
sleeping with behind my back. Didn't find out until 
12 
later. As well as her lies build up. When we were 
13. 
party buddies, like I said, her and Jane Doe 7 did a lot 
14 
of scheming and scamming behind my back, a lot of lies. 
15 
What else? We got into a fistfight my 
16 
sophomore year of high school. 
17 
She also told me that she was not suing 
18 
Jeffrey Epstein and that she thinks Jane Doe 7 is a 
19 
complete idiot and a moron and then goes behind my back 
20 
thinking that I'm dumb and Is a complete hypocrite. 
21 
Q. Anything else? 
22 
A. She lets men beat on her. That's why I don't 
23 
like her. 
24 
Q. You don't like her because men beat on her and 
25 
she doesn't put up a fight? 
Page 227 
1 
A. I can't care either way. 
2 
Q. You don't care whether she gets money? 
3 
A. She's out of my life. That's all I know. 
4 
Q. Would it be okay with you if she gets millions 
5 
of dollars for the pain and suffering she endured? 
6 
MR. CRTITON: Form. 
7 
THE WITNESS: That's fine. 
8 
BY MR. HOROWITZ: 
9 
Q. Jane Doe 4. Is she someone that you 
10 
considered a friend when you recruited her to go to 
11 
Jeffrey Epstein's house? 
12 
A. Party buddy. 
13 
Q. Not a friend? 
14 
A. Not a friend. 
15 
Q. Never was a friend? 
16 
A. Never was a friend. 
17 
Q. Do you like her now? 
18 
A. No. 
19 
Q. You — that's someone you really don't like? 
20 
A. Don't like her. 
21 
Q. You don't like her? 
22 
A. I don't like her. 
23 
Q. You see her, you go the other way? 
24 
A. Oh, yes. High tail it. 
25 
Q. And you don't want her to get any money in 
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1 
A. She doesn't do anything. It's weak. 
2 
Q. Any other reasons you don't like her? You've 
3 
given us a few. Tm trying to find all of them. 
4 
A. I can't think of any other reason why I 
5 
wouldn't like her. 
6 
Q. Who is the boyfriend that you said she was 
7 
with? 
8 
A. The guy I was dating at one point in my life, 
9 
1 was dating him, went to bed, woke up in the middle of 
10 
the night and his pants were around the ankles in the 
11 
kitchen with Jane Doe 4. 
12 
Q. And who is that? 
13 
A. 
14 
Q. And you said you had a fistfight with her. 
15 
When was that? What grade was that? 
16 
A. I don't recall. 
17 
Q. Was it before or after you introduced her to 
18 
Jeffrey Epstein? 
19 
A. I can't remember. 
20 
Q. It could have been before? 
21 
A. Could have been before. 
22 
Q. Did you patch up that issue, such that you 
23 
were able to have a conversation and tell her how to 
24 
make money and make yourself money? 
25 
MR. cRrrron
nw=====i
PROSE COURT REPORTING 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
19 (Pages 226 to 229) 
AGENCY, INC. 
7a82ddctf-59ee-4857-9cd8-8392056001c0 
EFTA01076005

Page 230 
1 
THE WITNESS: We eventually patched things up. 
2 
BY MR. HOROWITZ: 
3 
Q. And do any of the reasons that you don't like 
4 
Jane Doe 4 have anything to do with Jeffrey Epstein, 
5 
other than, I think you told us she denied being a 
6 
Plaintiff in the lawsuit? 
7 
A. Yes. 
8 
Q. What reasons are there pertaining to Jeffrey 
9 
Epstein? 
10 
A. Same thing as Jane Doe 7. You volunteered, 
11 
you knew yourself what you were getting into. You were 
12 
a hypocrite to my face, told me that it's stupid for 
13 
Jane Doe 7 to sue. You disagree with her decision. You 
14 
go behind my back, you do it. And then what? This is 
15 
it? I don't — I don't care for either one of them. 
16 
Q. And, so, because of that, you don't think 
17 
she's been harmed. You don't want to see her get any 
18 
money because she volunteered for it; is that correct? 
19 
MR. CRITTON: Form. 
20 
MR. BLANTON: Object to form. She's asked and 
21 
answered that before. 
22 
THE WITNESS: I don't care either way. 
23 
BY MR. HOROWITZ: 
24 
Q. Is it your opinion that Jane Doe 4 should tell 
25 
everyone that she's a Plaintiff in the lawsuit? 
Page 232 
1 
A. I found out, like, two days later. 
2 
Q. That she what? 
3 
A. Was a Plaintiff. 
4 
Q. Do you know if at that point she had filed a 
5 
lawsuit? 
6 
A. Yes. 
7 
Q. You know that because who told you? 
8 
A. 
9 
Q. And, in fact, you knew when Jane Doe 4 lied —
10 
you knew when Jane Doe 4 told you that she wasn't a 
11 
Plaintiff that she was a Plaintiff? 
12 
MR. BLANTON: She's already answered that 
13 
question. 
14 
THE WITNESS: I already answered. 
15 
BY MR. HOROWITZ: 
16 
Q. Isn't it true you sent her a text message 
17 
saying, I always knew you were a Plaintiff? 
18 
A. Yes. 
19 
Q. In fact, even when she told you she wasn't, 
20 
you knew she was, correct? 
21 
A. No. 
22 
MR. BLANTON: She's answered that three times. 
23 
BY MR. HOROWITZ: 
24 
Q. But why would you send her an e-mail saying 
25 
that, in fact, you knew she was? 
Page 231 
1 
A. No. But she shouldn't deny it. 
2 
Q. She should answer truth -- she should answer 
3 
to everyone that, in fact, she's a Plaintiff, if anybody 
4 
asks her? 
5 
A. Yes. 
6 
Q. Did you know the answer before you asked her? 
7 
A. No. 
8 
Q. So you believed her when she said she wasn't a 
9 
Plaintiff? 
10 
A. Yes. 
11 
Q. And it upsets you that she didn't want to tell 
12 
you that she was a Plaintiff? 
13 
A. No. It upsets me that she lied to my face and 
14 
was fake to my face and told me one thing and then went 
15 
behind my back and did another thing. That's scandalous 
16 
and ifs not right. 
17 
Q. What's the other thing she did? 
18 
A. She told me to my face that she wasn't a 
19 
Plaintiff and that she disagreed. It's not the fact 
20 
that she didn't want to tell me. She could have just 
21 
said, it's not your business. But for her to lie to my 
22 
face and then put down somebody else for the same thing 
23 
you're doing is a little hypocritical. 
24 
Q. Do you know if, in fact, she was a Plaintiff 
25 
at the time she denied being a Plaintiff? 
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 233 
A. Because I wasn't going to let her have the 
satisfaction of thinking she threw me for a loop, 
thinking that she had ono over me. 
Q. So she —you lied to her? 
A. Yes. 
Q. You lied to her so that she wouldn't think 
that she got one ova on you? 
A. Yes. 
Q. Okay. lane Doe 3. Is she someone you can --
at the time you recruited her, is she someone you 
considered a friend? 
A. No. 
Q. Was she ever a — I think you called a 
Icyparty—
A. Party buddy. 
Q. Party buddy? 
A. No. 
Q. Do you have any feelings for her one way or 
the other today different than when you did then? 
A. I have nothing bad or good to say about her. 
Q. Okay. Are you friends with anybody who you 
are aware of has filed a lawsuit against Jeffrey 
Epstein? 
A. No. 
MR. CRITTON: Object to the form. She may not 
20 (Pages 230 to 233) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Sandra Townsend (401 
lati2dddl.Sece-4057-9cd8.819205600fc0 
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Page 234 
1 
know. 
2 
MR. HOROWITZ: That's the way I framed the 
3 
question the way I did. I said, that you are —
4 
MR. CR1TTON: Oh, okay. 
5 
BY MR. HOROWITZ: 
6 
Q. You told us that you have not caranunicated --
7 
have you communicated with Jeffrey Epstein since his 
8 
arrest? 
9 
A. No. 
10 
Q. And how is it that you ended up with an 
11 
attorney who he is paying for, if you have not 
12 
communicated? 
13 
MR. BLANTON: Object to the form. Do not 
14 
answer that question. 
15 
We've had this conversation. She will not be 
16 
dittencsing that any further. 
17 
BY MR. HOROWITZ: 
18 
Q. You recall signing an affidavit in this 
19 
lawsuit? 
20 
A. Yeah. To be more specific, I've signed a lot 
21 
of paperwork. 
22 
Q. Do you recall signing, like, a sworn statement 
23 
that said — that detailed an encounter with a couple of 
24 
the Plaintiffs? You met one at 
and 
25 
another one at another nightclub? 
Page 236 
1 
MR. HOROWITZ: We may have to deal with that 
2 
one again. 
3 
BY MR. HOROWITZ: 
4 
Q. There was a girl named Ewho earned a 
5 
thousand dollars from Jeffrey Epstein? 
6 
MR. CRITION: Form. 
7 
THE WITNESS: What I heard. 
8 
BY MR. HOROWITZ: 
9 
Q. What you heard. Who recruited her? 
10 
A. 1 have no idea. 
11 
Q. Was she a 
High School student? 
12 
A. I have no idea. I know that she went to 
13 
I don't know where she went to high 
14 
school. She may have been a. 
15 
Q. And from — sorry. From who did you hear that 
16 
she earned a thousand dollars? 
17 
A. Jane Doe 101. 
18 
Q. Did Jane Doe 101 claim to have recruited..? 
19 
A. I'm sorry? 
20 
Q. Did Jane Doe 101 claim to have recruited.? 
21 
A. No. She never said either way. 
22 
Q. And what is — can you — 'don't think you've 
23 
spelled her last name for us. 
24 
A. I? 
25 
Q. Yeah. 
Page 235 
1 
A. I remember signing an affidavit about a 
2 
Plaintiff and me at an incident that we had at 
3 
yes. 
4 
Q. Did Mr. Epstein's attorneys ask you to sign an 
5 
affidavit pertaining to those facts? 
6 
MR. BLANTON: Do not answer that unless you 
7 
know it somehow other than speaking to me. And I 
8 
am your attorney. So if that aff -- if you had 
9 
dealings with that affidavit outside of my 
10 
presence, you may answer. Otherwise, you are not 
11 
to answer that question. 
12 
THE WITNESS: Okay. 
13 
BY MR. HOROWITZ: 
14 
Q. Did Mr. Epstein —1'm not interested in what 
15 
your attorneys said to you or asked you to do. Did 
16 
Mr. Epstein's attorneys ask you to sign an affidavit? 
17 
A. I don't know. 
18 
Q. You just did it because it felt right? How 
19 
did it come to be that you signed this affidavit? 
20 
MR. BLANTON: If you can answer that without 
21 
disclosing the conversations that you had with your 
22 
attorney. 
23 
THE WITNESS: I can't answer that. 
24 
MR. BLANTON: That information is privileged. 
25 
She will not be disclosing that. 
Page 237 
1 
A. I. 
2 
Q. And is he she older, younger, or the same? 
3 
A. Same age. 
4 
Q. Same grade, as far as you 'mow? 
5 
A. Yes. 
6 
Q. Yes. Okay. How many times would you estimate 
7 
that you have been to Jeffrey Epstein's home? 
8 
A. Estimate? 
9 
Q. Or if you know specifically, you can tell me. 
10 
But I was trying to help you out. 
11 
A. I don't know specifically. But if I'm telling 
12 
you that I brought about a dozen girls and sometimes 
13 
went more than twice, I think it would be fair to say 
14 
maybe two dozen times, a dozen and a half to two dozen 
15 
times maybe. 
16 
Q. Eighteen to 24 roughly? 
17 
A. Possibly. 
18 
Q. That's your best estimate? 
19 
A. Best estimation. 
20 
MR. HOROWITZ: Let's take a break and I'll try 
21 
to wrap it up and maybe Mr. Willits will have 
22 
questions. 
23 
VIDEOGRAPHER: Going off the record. The time 
24 
is 4:25 p.m. This is the end of tape number three. 
25 
(Brief recess.) 
21 (Pages 234 to 237) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401= 
Electronically signed by Sandra Townsend (401 
7a82dddf-59eo-4e57.9cd8.839205600fc0 
EFTA01076007