EFTA01075988

Page 238 
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VIDEOGRAPHER: We're back on the record. The 
2 
time is approximately 4:30 p.m. This is the 
3 
beginning of tape number four. 
4 
BY MR. HOROWITZ: 
5 
Q. A few more questions. 
6 
On the occasions when you travelled with other 
7 
girls to see Mr. Epstein, before going to his home, did 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
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either you or any of the other girls use alcohol or 
drugs? 
A. I didn't. 
Q. Did any of the girls that you travelled with 
or recruitexl to see him use alcohol or drugs before 
going to his house? 
A. i don't know. 
Q. You were asked earlier whether Mr. Epstein 
gave you money or gifts before, other than the cash he 
gave you for the massages and bringing girls. And you 
said, none; is that correct? 
A. That is. 
Q. Did he pay for anyone to render any services 
for you? 
A. No. 
Q. Did he open any doors, whether it be 
employment opportunities or other opportunities for you? 
A. No. 
Page 240 
1 
Q. What was it in a general sense that you were 
2 
journaling, if not your emotions and feelings? 
3 
MS. BLANTON: Are you asking with regard to 
4 
Jeffrey Epstein or her in general? 
5 
MR. HOROWITZ: No. 
6 
BY MR. HOROWITZ: 
7 
Q. My question was: In a general sense, what is 
8 
it that you were journaling or putting in a diary at 
9 
that period of time? 
10 
A. About things that were going on in my life, 
11 
just things that i was going through that — some didn't 
12 
even have anything to do with Epstein and M. 
And 
13 
sometimes I would just write about how I used to work 
14 
for him and whatever. But it was never anything like 
15 
emotional about him. it was more different things in my 
16 
life. 
17 
Q. If we were to open the pages of the journal, 
18 
we would see somewhere a reference to the fact that you 
19 
worked or used to work for him; it would say something 
20 
like that? 
21 
A. Possibly, yes. 
22 
Q. Would it say something about how you felt 
23 
about working for him or having worked for him? 
24 
A. I don't know. Possibly. 
25 
Q. What sort of things did you write about, 
Page 239 
1 
Q. Did he make offers to assist you in any way? 
2 
Professionally? Educationally? 
3 
A. No. 
4 
Q. Anything Ince that? 
5 
Did you ever ask Jeffrey Epstein for anything 
6 
other than the cash you were given for the massage and 
7 
the bringing of other girls? 
8 
A. Sorry. No. 
9 
Q. Did you ever keep a diary of the events, in 
10 
terms of your dealings with Jeffrey Epstein? 
11 
A. No. 
12 
Q. Did you ever keep a journal or a log of the 
13 
contacts_nLi had with the police or the State Attorney 
14 
or with = 
anything like that? 
15 
A. I kept a journal for my own self about what 
16 
was going on in my life, but nothing about 
and 
17 
Epstein specifically. 
18 
Q. Would there be a reference to either what 
19 
happened with Jeffrey Epstein or how you felt about it? 
20 
A. No. 
21 
Q. Would there be a reference to your emotional 
22 
state or how you were feeling at or about the time that 
23 
you went there or you were bringing other girls to his 
24 
home? 
25 
A. No. 
Page 241 
1 
having worked for Mr. Epstein? 
2 
A. I don't know. 
3 
Q. Would there be any reference to having worked 
4 
for him in a sense of bringing other girls to his home? 
5 
A. Possibly. 
6 
(Brief interruption.) 
7 
BY MR. HOROWITZ: 
8 
Q. Where is this journal? Do you have it at your 
9 
house? 
10 
A. I do not have it at my house. 
11 
Q. Who has your journal? 
12
A. The last place m journal was, was with my old 
13 
roommates down in 
. And I left a bunch 
14 
of my belongings down there, so either it's thrown away 
15 
or she still has it. 
16 
Q. And who is "she? 
17 
A. 
18 
Q. 
19 
A. 
20 
Q. 
21 
A. 
22 
Q. 
23 
A. 
24 
street. 
25 
Q. Did Mg° to 
What is 
last name? 
I do not know. 
Where did u
i  
with ' 
Down in 
by the beach. 
What street? 
I said by the beach. I don't know what 
High School? 
22 (Pages 238 to 241) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Sandra Townsend (401 
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Page 242 
Page 244 
1 
A. No. 
2 
Q. Where did 
go to high school? 
3 
A. I don't ;mow. 
4 
Q. How did you know M? 
5 
A. We worked together. 
6 
Q. Where did you work together? 
7 
A. We danced together. 
8 
Q. Okay. And what dance club was that? 
9 
A. A strip club. 
10 
Q. And do you know 
last name? 
11 
A. No, I do not. 
12 
Q. How long a period of tittle was it that you were 
13 
a stripper? 
14 
MS. BLANTON: rm going to object, .-
15 
MR. HOROWITZ: What? 
16 
MS. BLANTON: — based on earlier concerns. 
17 
This is very private, personal information. With 
18 
regard to how it relates to Jeffrey Epstein, if you 
19 
have some sort of predicate or can explain the 
20 
relevance
 me know. I think you have a right 
21 
to ask = 
last name. She doesn't know it. 
22 
You have a right to ask where the name of the place 
23 
is if you want to try to find her. 
24 
MR. HOROWITZ: Thank you. That wasn't a form 
25 
objection. 
1. 
2 
3 
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8 
10 
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A. You 
she tried out. 
Q. And then what happened? It didn't work out? 
A. She got the job, but she was only up there 
visiting so she didn't keep it. She just wanted quick 
money. 
Q. What was the name of that club? 
A. 
Q. What were the other clubs that ou worked at? 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. That's not a strip club? 
A. No, it's not a strip club. 
You've never heard of 
It's 
not a strip club. 
Q. What do you do at 
A. have. I wait tables. 
MR. CRITTON: You're not local. I take that 
back. You can only ask the question. 
BY MR. HOROWITZ: 
Are you currently working? 
Yes. 
Where are you currently working? 
Page 243 
1 
BY MR. HOROWITZ: 
2 
Q. Where did you dance? 
3 
A. A lot of places. 
4 
Q. Give me the names of the clubs that you worked 
5 
as a stripper. 
6 
MS. BLANTON: I'm going to object based on 
7 
privacy. I do not think she needs to answer that. 
8 
I don't think it has any relevance to this lawsuit. 
9 
BY MR. HOROWITZ: 
10 
Q. Did you work as a stri per with any of the 
11 
girls who went to 
High School? 
12 
A. Not thatl know of, no. 
13 
Q. Did any of the girls who you brought to 
14 
A. Actually, I take that back Jane Doe 4 came 
15 
to visit me in 
and I took her to the strip club 
16 
1 worked with up there and she stripped. 
17 
Q. She went one time? 
18 
A. Yes. 
19 
Q. How long did she strip for? 
20 
A. Maybe three hours and then we left the club. 
21 
Q. It's your testimony she stripped for three 
22 
hours? 
23 
A. Yep. Yes. 
24 
Q. And was she on, like, the payroll? She was 
25 
hired by the — by the strip club the day she went? 
1 
2 
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4 
5 
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10 
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Page 245 
Q. How old were you when Jane Doe 4 came to see 
you at the strip dub you were wetting at? 
A. In 
Q. Yes. 
A. I want to say that I was just turned 20. 
Q. And I'm ptering that since Jane Doe 4 came 
to visit you in 
whatever arguments you had in 
high school, the fistfight, problems with the boyfriend 
or ex-boyfriend, you had kind of worked those things out 
by the time she came to visit you in M? 
MR. CRITTON: Form. 
THE WITNESS: Because of my living 
circumstances with Jane Doe 7, I put our 
differences aside as respect for my roommate. 
BY MR. HOROWITZ: 
Q. So Jane Doe 7 was your roommate in 
while — and she was going to school there? 
A. That's correct. 
Q. How did it come to be that you were no longer 
roommates with Jane Doe 7? 
A. 
After that 
everybody just split up. My parents wanted me to come 
home. This whole 
stein case had 'ust blown up the 
same week 
They felt it would 
be more beneficial for my health that I come home and 
•••
••••••••... 
23 (Pages 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Sandra Townsend (401 
242 to 245) 
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Page 246 
deal with it as a family, instead of being in 
Q. How did it come to be when you came to live 
with Jane Doe? in 
A. I wanted out of
 I was tmhappy 
living at my home. I had just been interrogated by the 
police about the whole Epstein situation. So I thought 
it would be good to get out or
 and start off 
kind of fresh somewhere else. 
which was lane 
Doe Ts roommate, said she wanted to move back home. 
Her boyfriend wanted to as well. So I took her lease 
over in the loft. 
Q. What was the name of the strip club you worked 
at with 
A 
Q. 
MR. HOROWITZ: Thanks. I don't have any 
further questions at this point in time. 
MR. CRITTON: Dick, you're on. 
MR. WILLITS: Thank you very much. 
CROSS EXAMINATION 
BY MR. WILLITS: 
Q. Mr. Kuvin has a picture that I would like for 
him to show you now of a young lady. 
MR. KUVIN: One of us does. Yeah. IR hold 
Page 248 
MR. KUVIN: I've given it to the witness, 
2 
Dick. 
3 
BY MR. WILLITS: 
4 
Q. Do you recognize that young lady? 
5 
A. No. But she kind of looks like that girl that 
6 
killed her kid on tv. What's her name? No. Cayley, 
7 
the whole Cayley Anthony. It resembles her, but I've 
8 
never seen this girl in my life. 
9 
Q. Okay. Thank you very much. 
10 
I want to change the subject and ask ou: 
11 
When is the last time you talked to 
12 
A. Oh, it's been a very long time. Eighteen? 
13 
When I was 18 years old. After I brought 
I cut off 
14 
ties. 
15 
Q. And where did that conversation take place? 
16 
A. At Epstein's house. 
17 
Q. And what was it about? 
18 
A. I don't know. I don't remember. 
19 
We didn't end on bad tams. It was just after 
20 
I brought the last girl, I just never spoke to them 
21 
again. 
22 
MR. WILLITS: I don't have any other 
23 
questions. 
24 
MR. HOROWITZ: Neither does Bob. 
25 
CROSS EXAMINATION 
Page 247 
1 
it up. 
2 
MR. CRITTON: Can we mark it as the next 
3 
Exhibit? 
4 
MR. HOROWITZ: Let's show it to the camera. 
5 
MR. KUVIN: Do you want to mark it? 
6 
MR. WILLITS: Well, don't we have some sort of 
7 
a— do we have a deal or not? 
8 
MR. CRITTON: Yeah. We're not — the pictures 
9 
remain with the lawyers, you know, within the 
10 
confines of the files anyway. They're not going to 
11 
be filed. 
12 
MR. WILLITS: Okay. Sure. Mark it. 
13 
MR. KUVIN: This will be Plaintiffs 5. And, 
14 
Dick, give me one second to just show it to the 
15 
camera. 
16 
(Exhibit number 5 was marked for 
17 
identification purposes.) 
18 
MR. CRITTON: You know, it's probably not a 
19 
bad idea for the court reporter — are you 
20 
attaching Exhibits to the depositions? 
21 
VVIrat you should do is probably put the 
22 
Exhibits in a separate envelope and put a sticker 
23 
on it as warning if it tells us the original, 
24 
whoever gets the original, they don't erroneously 
25 
file something. 
Page 249 
1 
BY MR. CRITTON: 
2 
Q. My name is Bob Critton. I represent 
3 
Mr. Epstein. 
4 
Is it okay if I call you M? 
5 
A. Yes. 
6 
Q. M, you've been asked — let's see. We 
7 
started today at 11:00. It's about quarter to 5:00 and 
8 
I think we took about 45 minutes to an hour for lunch 
9 
and we've had a couple other breaks. So I know you've 
10 
been here a long time, but you've also covered a lot of 
11 
territory that I need to kind of work my way back 
12 
through. 
13 
If I understand it from your testimony 
14 
well, let me ask you this first: Mr. Kuvin, who spent 
15 
the better 
of the day with you represents a person 
rt
16 
named 
I think during one of his last few questions 
17 
he asked you whether you knew her. And I think your 
18 
response was you've never heard of her, correct? 
19 
A. That's correct. 
20 
Q. In the other approximately four hours' worth 
21 
of uestioning, did he ever ask you one question about 
22 
M.? 
23 
A. No. 
24 
Q. All right. With regard to Mr. Epstein, if I 
25 
understood your earlier testimony, is, you learned about 
24 (Pages 246 to 249) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Sandra Townsend (401 
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Page 250 
1 
Mr. Epstein who was referred to as Jeff or Jeffrey from 
2 
Jane Doe 101, correct? 
3 
A. Yes. 
4 
Q. All right. And that occurred at a bar railed 
5 
or a restaurant/bar called, =, 
which is on the 
6 
beach in 
Florida? 
7 
A. Yes. 
8 
Q. And Jane Doe 101 basically said something to 
9 
the effect, is, after you had a discussion with her and 
10 
casual friend is, is, would you like to make a couple 
11 
hundred bucks? 
12 
A. Yes. 
13 
Q. And when she — and if I also understood your 
14 
testimony, is, she basically said, depending on how 
15 
you're dressed, you may cam a little bit more, a little 
16 
less money; is that aftin statement? 
17 
MR. HOROWITZ: Object to the form. 
18 
MR. KUVIN: Join. 
19 
MR. WILLITS: Object to the form. 
20 
THE WITNESS: I'm sorry. Can you repeat the 
21 
question? 
22 
BY MR. CRITTON: 
23 
Q. Sure. If I tmderstood what Jane Doe 101 said 
24 
to you, is, she said a number of thing, is, Jeff-
25 
Jeffrey lived in Palm Beach, had a big house, that you 
Page 252 
1 
MR. HOROWITZ: Form. 
2 
MR. KUVIN: Join. 
3 
THE WITNESS: Yes. 
4 
BY MR. CRITTON: 
5 
Q. Did Mr. Epstein at any time try to use any 
6 
force or coercion or any type of physical force towards 
7 
you? 
A. Never. 
9 
Q. Did he ever threaten you in any way, either 
10 
physically or verbally? 
11. 
A. No. 
12 
Q. Did you find him to be, at least in your 
13 
discussions with him, to be soft spoken; that is, he was 
14 
nice to you? 
15 
A. Yes. 
16 
MR- KUVIN: Objection to form. 
17 
BY MR. CRITTON: 
18 
Q. Was he ever not nice to you or ever rode to 
19 
you in any fashion? 
20 
A. Never. 
21 
MR. HOROWITZ: Form. 
22 
MR. KUVIN: Join. 
23 
BY MR. CRITTON: 
24 
Q. Were you at any time 
25 
MR. WILLITS: Form. 
Page 251 
1 
would give him — that you would be required to give him 
2 
a massage, and that's pretty that's at least some of 
3 
the information that she provided, correct? 
4 
A. Yes. 
5 
Q. Did she tell you what you should wear or 
6 
suggest what you should wear in any way? 
7 
A. No. 
8 
Q. Did she at that time tell you that if you wear 
9 
something or if you take something off, you might get 
10 
paid a little bit more money? 
11 
MR. HOROWITZ: Object to the form. 
12 
MR. KUVIN: Join. 
13 
THE WITNESS: No. 
14 
BY MR. CRITTON: 
15 
Q. And, so — and that's pretty much what you 
16 
knew about Mr. Epstein or Jeff until you got to the 
17 
house? 
18 
A. Yes. 
19 
Q. And if I understood your testimony in response 
20 
to questioning by Mr. Kuvin and Mr. Horowitz, is, you 
21 
went upstairs, you gave the massage. He during the 
22 
course of the massage he reached towards you, you said, 
23 
in essence, stop. and that was the end of him in any vary 
24 
towards you or attempting to touch you; is that a 
25 
correct statement? 
Page 253 
1 
BY MR. CRITTON: 
2 
Q. — concerned about your safety being in 
3 
Mr. Epstein's home? 
4 
A. That's absurd. 
5 
Q. Okay. So the answer is no? 
6 
A. No. 
7 
Q. Were you — did you at any time even 
8 
contemplate yelling or screaming or crying for help at 
9 
any time that you were around Mr. Epstein? 
10 
A. No. 
11 
Q. Were you ever with anyone in his home, at any 
12 
time were you afraid or fearful or concerned at all 
13 
about your safety? 
14 
A. No. 
15 
Q. After the one occasion that you were at 
16 
Mr. Epstein's home and you gave him a massage, ill 
17 
understood your testimony, you never gave him another 
18 
massage? 
19 
A. I never gave him another massage. 
20 
Q. But, in fact, you did bring a number of girls, 
21 
which 1 think you described to be approximately 12,12 
22 
different people, some people more than once, but 12 
23 
different people that you can recall approximately? 
24 
A. Yes. 
25 
Q. And they were females? 
25 (Pages 250 to 253) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 254 
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A. Yes. 
2 
Q. We know that. All right 
3 
A. That I know of, yes. 
4 
Q. And of the females that you brought, if I 
5 
understood your testimony, as to all of those girls you 
6 
basically had or provided pretty much a standard talk or 
7 
a standard — you had kind of a standard explanation as 
8 
to what would occur, is that a fair statement? 
9 
A. That is a fair statement. 
10 
Q. And if I also understood your testimony, is, 
11 
after you brought one or two girls, that the word kind 
12 
of got around in your circle of your friends and/or 
13 
acquaintances and a lot of people wanted -- a number of 
14 
other females wanted to come and to give Mr. Epstein 
15 
massages at his home? 
16 
MR. KUVIN: Fenn. 
17 
THE WITNESS: Yes. 
18 
BY MR. CRITTON: 
19 
Q. And if I understood as well what you said, is, 
20 
the little speech or the information that you provided 
21 
the girls was, is that, there was a man in late forties, 
22 
early fifties, you could make some money, you could give 
23 
him a massage, you would go to his house, he's got a 
24 
nice house in Palm Beach, he's a billionaire, he's nice, 
25 
you don't have to be scared, you know, you don't have to 
Page 256 
1 
reservations about going; that is, did you have to try 
2 
to cajole these people or encourage them to go or did 
3 
all of the 12 basically once you told them what was 
4 
going on and that they could make a couple hundred 
5 
bucks, did all of them willingly go? 
6 
A. Yes. 
7 
Q. As to the girls that went, what I also 
8 
understood your testimony, I think it was in response to 
9 
Mr. Horowitz's questions, is that — is, I think, as you 
10 
said — I think your testimony was, is, you told them, 
11 
in essence, what Jane Doe 101 had told you; that is, if 
12 
they go -- if they — if they do a massage dressed, 
13 
they'll make approximately X amount of dollars. If they 
14 
leave just their bra on or if they take their skirt or 
15 
their pants off or if they go topless, then they might 
16 
make some additional money? 
17 
MR. HOROWITZ: Form. 
18 
MR. KUVIN: Join. 
19 
THE WITNESS: Yes. 
20 
BY MR. CRITTON: 
21 
Q. And the girls that you talked to, that is, the 
22 
12 approximately girls that you brought, did any of them 
23 
ever express to you any reservations or any concern 
24 
about after you told them that they might be asked to 
25 
go topless or to take off their shirt or to do the 
Page 255 
worry about anything when you're there? 
2 
A. Mats correct. 
3 
Q. Did you tell them — did you tell these girls 
4 
that he would be respectful towards them? 
5 
A. Yes. 
6 
Q. Did you tell them that at no time would they 
7 
ever experience any type of physical force or violence 
8 
or any type of coercion? 
9 
A. Yes. 
10 
Q. And did you tell them that — that you had 
11 
never been afraid? 
12 
A. Yes. 
13 
Q. All right. And did some of the people who --
14 
well, let me ask it this way: Of those girls, did you 
15 
tell all of them to tell Mr. Epstein that they were DI 
16 
years old or older? 
17 
A. I told all of them to lie about their age. 
18 
Q. And you told them to lie about their age? 
19 
A. That's correct. 
20 
Q. And did any of them, that is, did any of the 
21 
12 girls that you took, did any of them express any 
22 
cancent about lying about their age? 
23 
A. No. 
24 
Q. Did any of them express, that is, any of the 
25 
12 girls that you took, did any of them ever express any 
Page 257 
1 
massage in their bra and a thong or maybe even with only 
2 
partially clothed, did any of those girls after you told 
3 
them that, express any reservation or concern? 
4 
A. No. 
5 
Q. Now, of the 12 girls that you took to 
6 
Mr. Epstein's home in some fashion, did you transport 
7 
them all or did some of them get there by themselves or 
8 
pick you up and take you there? 
9 
A. Sometimes I drove. Sometimes they drove. 
10 
Q. And of the of the females that went to 
11 
Mr. Epstein's home, the 12 -- and I'm talking about just 
12 
their initial visits, and that would include Jane Doe 4, 
13 
Jane Doe 7 and Jane Doe 3, all who are three Plaintiffs 
14 
in three separate cases here, and — did any of those 
15 
girls, including those three, ever express when they 
16 
came down from being upstairs with Mr. Epstein that they 
17 
were scared or fearful of anything that had occurred at 
18 
the house? 
19 
MR. HOROWITZ: Form. 
20 
THE WITNESS: No. 
21 
BY MR. CRITTON: 
22. 
Q. Did any of those girls during the time — did 
23 
any of those females during the time that they were 
24 
upstairs at any time yell, scream or cry for help? 
25 
A. No. 
Foundation. 
26 (Pages 254 to 257) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Sandra Townsend (401 
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Page 259 
1 
Q. Did myone, other than the one person that you 
2 
mentioned, M., I think was her name --
3 
A. Uh-huh. 
4 
Q. -- who was complaining about the amount of 
5 
money or that she and Mr. Epstein had gotten into a 
6 
dispute about the amount of money -- did any of them 
7 
ever explain to you or tell you that they had had any 
8 
problem with what occurred with Mr. Epstein upstairs? 
9 
A. No. 
10 
Q. Did any of them — let me strike that. 
11 
Let me focus on the one person who complained 
12 
about the money, Ms.I.,.. Did she ever — other 
13 
than saying she thought instead of getting 200 or 
14 
whatever the number was she should have gotten 300, was 
15 
that the extent of her complaint? 
16 
A. Yes. 
17 
Q. Did she ever complain or suggest to you that 
18 
she had -- that there had been any type of verbal or 
19 
physical abuse or any inappropriate conduct that had 
20 
caused her any problem or that she complained about? 
21 
A. No. 
22 
Q. Did Ms. — M. go back again, to your 
23 
knowledge? 
24 
A. No. She wanted to, but I didn't feel 
25 
comfortable bringing her back after the dispute, the 
Page 26G 
1 
MR. HOROWITZ: Objection. Fenn. Cumulative. 
2 
MR. KUVIN: Join. 
3 
THE WITNESS: No. 
4 
BY MR. CRITTON: 
5 
Q. Did — with the individuals that went back, 
6 
did that include Jane Doe 7 and Jane Doe 4; that is, 
7 
they went multiple times that you're aware of? 
8 
A. Yes. 
9 
Q. And did that include Jane Doe 3? 
10 
A. I don't know. 
11 
Q. You know for sure she went one time and you 
12 
know she went another time when you and Jane Doe 3 took 
13 
another.? 
14 
A. Yes. 
15 
Q. At the time that -- let me strike that. 
16 
Th.. that %vas — you and Jane Doe 3 took, 
17 
did Jane Doe 3 ever express any concern to you or 
18 
complaint that maybe it would be inappropriate to take 
19 
I. because something bad or inappropriate or humiliating 
20 
or emotionally disturbing had occurred with her? 
21 
A. No. 
22 
MR. KUVIN: Objection to form. 
23 
BY MR. CRITION: 
24 
Q. Did Jane Doe 3 ever tell you that as a result 
25 
of the, at least one visit she had with Mr. Epstein, 
Page 259 
1 
first dispute between them. 
2 
Q. So., even though she had a dispute 
3 
apparently with Mr. Epstein over money, she then came 
I 
back to you and asked if she could go back again? 
5 
A. She wanted to work for him again. And he 
pretty much made it clear that, you know, the whole 
argument was unnecessary and then I felt uncomfortable 
8 
bringing her back, so I wouldn't bring her back. I told 
9 
her no. 
10 
Q. And, so, despite -- despite the financial 
11 
dispute, did it appear there had been any other problem 
12 
or any other issue or any other inappropriate actions by 
13 
Mr. Epstein that would have suggested to you — well, 
14 
let me stole that. 
15 
MR. HOROWITZ: Objection. Cumulative at this 
16 
point, whatever your next question is. 
17 
MR. CRITTON: Ill withdraw that question. I 
18 
think live finished with M. 
19 
BY MR. CRITTON: 
20 
Q. Let me -- with the other I I females, separate 
21 
and apart from.., did any of than ever complain to 
22 
you at any time, whether it was the first or second 
23 
visit or third, that they that anything that had 
24 
occurred with Mr. Epstein was inappropriate or that —
25 
or that they complained about? 
Page 261 
1 
that she suffered any type of emotional or mental 
2 
trauma? 
3 
A. No. 
4 
MR. HOROWITZ: Form. 
5 
BY MR. CRITTON: 
6 
Q. Did she ever tell you, Jane Doe 3, at any time 
7 
after she went to see Mr. Epstein and when she took. 
8 
that she was concerned about.. suffering some sort of 
9 
emotional or mental anguish or trauma or psychological 
10 
or psychiatric damage? 
11 
A. No one ever complained of that. 
12 
Q. Well, I want to stick just with Jane Doe 3. 
13 
Did she ever complain about that? 
14 
A. No. 
15 
Q. Did. Jane Dee 4 at any time after the first 
16 
visit or the second or any other visits that you knew 
17 
she had with Mr. Epstein, did she ever express to you 
18 
that she was humiliated by the experience? 
19 
MR. HOROWITZ: Cumulative. 
20 
THE WITNESS: No. 
21 
BY MR. CROFTON: 
22 
Q. Did she, Jane Doe 4, ever tell that you she 
23 
was embarrassed by having been with Mr. Epstein on the 
24 
multiple occasions? 
25 
MR. HOROWITZ: Form. 
27 (Pages 258 to 261) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
7482dcldf-69ev-4o57-9cd8-8392056001c0 
EFTA01076013

Page 262 
Page 264 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
THE WITNESS: No. 
MR. CRITTON: Form. How can I correct it? 
MR. HOROWITZ: You cant. Cumulative. You 
have asked the same question six different ways and 
you already have the answer. And now you're using 
words. You're using synonyms. 
MR. CR1TTON: Pm sorry I asked. 
MR. KUVIN: You asked. 
MR. HOROWITZ: Like a Thesaurus. 
How many different ways can you say anguish, 
trauma. 
BY MR. CRITTON: 
Q. M, 
did Jane Doe 4 ever tell you she had 
sustained any type of emotional or psychological trauma? 
A. No. 
MR. HOROWITL Cumulative. 
THE WITNESS: It's Jane Doe 4 though. Sony. 
BY MR. CRITTON: 
Q. i 
MR. KUVIN: Now he's going to reask all the 
questions. 
BY MR. CRITTON: 
Q. Did Jane Doe 3 or Jane Doe 4 —
A. Yes. 
Q. — ever tell you that they had lost income as 
1 
A. Yes. 
2 
Q. Did she ever express to you as a result of 
3 
having been with Mr. -- the time she spent with 
4 
Mr. Epstein that she was required to see a psychologist 
5 
or psychiatrist or any other health care professional? 
6 
A. She did tell me something about that 
7 
Q. And when did she tell you that? 
A. When I moved back down here when her, 
9 
and I started hanging out. 
10 
Q. And what did she tell you? 
11 
A. Well, she didn't tell me directly. She told 
12 
that she had to go see a thai
, her and Jane 
13 
Doe 7 had to see some therapist in 
and they flew 
14 
her out there and they had to fake cry and they had to 
15 
pretend like they were damaged. They had to pretend 
16 
that they were being molested. And Jane Doe 7 was 
17 
laughing about it. This is according to what 
19 
told me. 
19 
Q. Okay. Separate and apart from that incident, 
20 
did Jane Doe 4 ever tell you that she had seen a 
21 
psychiatrist or psychologist as a result of any contact 
22 
that she had had with Jeffrey Epstein? 
23 
A. No. 
24 
. B the way when Jane Doe 4 was dancing at 
25 
in EM, and you said thes a strip 
I 
Page 263 
1 
a result of being — of having gone to Mr. Epstein's 
2 
home? 
3 
A. No. 
4 
Q. Did any of them, did either Jane Doe 3 or Jane 
5 
Doe 4 ever tell you that their economic -- their ability 
6 
to earn money in the future had in some way been 
7 
impacted? 
8 
A. No. 
9 
Q. Did Jane Doe 3 ever tell you as a result of 
10 
seeing Mr. Epstein that she was required to see a 
11 
psychologist or psychologist? 
12 
A. No. 
13 
Q. Did Jane Doe 4 ever tell you — and apparently 
14 
you saw her for a number of years following the time 
15 
that she — she was at Mr. Epstein's home, correct? And 
16 
you saw Jane Doe 4 even when she was at college or 
17 
during the time she was at college at 
University? 
18 
A. Yes. 
19 
Q. And ifl understood your response to 
20 
Mr. Horowitz's question, you even got to see her strip 
21 
up at —what was it? 
22 
A. 
23 
Q. 
24 
A- Yes. 
25 
Q. -- up in 
for three hours, right? 
Page 265 
1 
club? 
2 
A. Yes. 
3 
Q. And you said she tried out? 
4 
A. Yes. 
5 
Q. For, I assume, the manager? 
6 
A. The whole club. 
7 
Oh. So Jane Doe 4, the 
player from 
8 
=University, was she in college at the time? 
9 
A. Yes. 
10 
Q. All right. And was she kind of a shy person? 
11 
A. No. 
12 
Q. And I think you also described -- described 
13 
one of the instances why you don't respect her or don't 
14 
think highly of her was, is that, you found her or 
15 
your — who you thought was your boyfriend having sex 
16 
with Jane Doe 4? 
17 
A. It was a guy that I was dating and she was 
18 
having oral sex with him. 
19 
Q. Okay. 
20 
MR. HOROWITZ: Move to strike. 
21 
BY MR.. CRITTON: 
22 
Q. Well, you saw it yourself? 
23 
A. I walked in on them, yes. 
24 
Q. All right. And she was giving him oral sex at 
25 
the time? 
PROSE COURT REPORTING AGENCY, 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
28 (Pages 262 to 265) 
INC. 
7a82dddf-69eo4e57-9cd8-839205400k0 
EFTA01076014

Page 266 
Page 268 
1 
A. That's correct. 
2 
Q. And did you say anything? 
3 
A. We almost got into a second fight. 
4 
Q. And when she came up, so to speak, when she —
5 
you said something to her, did she stop what she was 
6 
doing and then stand up? 
7 
A. Well, she had been drinking and she kind of 
8 
got up off the floor and she got in my face. We had a 
9 
little bit of an altercation. And he pretty much got in 
10 
between us and I walked away. 
11 
MR. HOROWITZ: Move to strike. 
12 
Non-responsive. 
13 
BY MR. CRITTON: 
14 
Q. And the male's name was? 
15 
A. 
16 
Q. Was she, Jane Doe 4, dating anyone at the 
17 
time, to your knowledge? 
18 
A. I don't remember. 
19 
Q. Approximately what time — what time period 
20 
are we dealing with? 
21 
A. We were definitely in high school. I can't be 
22 
accurate about the years. 
23 
■Q. Oh, okay. All right. Let me go back to. 
24 
25 
A. 
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 
MR. KUVIN: Fonn. 
THE WITNESS: Yes. 
BY MR. CRITTON: 
Q. Did she tell you they asked her to stay or to 
come back? 
A. The manager came to me specifically and asked 
me if she wanted the job. 
Q. And of course she had to go back to college? 
A. Yes. 
Q. Let me be specific now with regard to Jane Doe 
7. 
Jane Doe 7. I think you testified you were 
aware that she went to Mr. Epstein's house on a number 
of occasions? 
A. Yes. 
Q. You took her once and you may have gone back 
one or more occasions with her? 
A. Possibly. 
Q. But you were aware from — what? -- from 
speaking with her that she had gone beck on multiple 
occasions? 
A. Yes. 
Q. And I think you told us earlier neither Jane 
Doe 4 nor Jane Doe 7 nor Jane Doe 3 described what 
actually occurred? 
Page 267 
1 
Q. 
. When she you say she tried 
2 
out for the whole club. What time of day was it that 
3 
she was trying out? 
4 
A. I can't be sure. 
5 
Q. Evening? 
6 
A. It was evening. 
7 
Q. And were there patrons in the place? 
8 
A. Yes. 
9 
Q. And wear a costume? 
10 
A. No. 
11 
Q. What did she do? What did you see her do? 
12 
A. Dance in her thong and pasties. 
13 
Q. All right. Did she tell you afterwards she 
14 
enjoyed it? 
15 
A. Yeah. She said she made good money. 
16 
. So that she tried out, she -- at a strip club, 
17 
in M. 
She danced for about three 
18 
hours and made good money? 
19 
A. Uh-huh. 
20 
Q. Yes? 
21 
A. Yes. 
22 
Q. And could she have come back there to her work 
23 
there if she didn't have to go back to school? 
24 
A. Yes. 
25 
Q. From at least what you observed? 
Page 2C 
1 
A. That's correct. 
2 
Q. And because you weren't upstairs, you don't 
3 
know what occurred with them? 
4 
A. That's correct. 
5 
Q. And with regard to Jane Doe 7, did she ever 
6 
tell you that Mr. -- well, let me smite that. 
7 
Did she ever complain to you that Mr. Epstein 
8 
had acted inappropriately with her at any time? 
9 
A. No. 
10 
Q. Did she, Jane Doe 7, ever complain that 
11 
Mr. Epstein had used any type of physical or verbal 
12 
force or violence directed to her? 
13 
MR. HOROWITZ: Form. Cumulative. 
14 
THE WITNESS: No. 
15 
BY MR. CRITTON: 
16 
Q. Did she, Jane Doe 7, ever tell you that she 
17 
had suffered any type of emotional or mental trauma as a 
18 
result of her involvement with Mr. Epstein? 
19 
MR. HOROWITZ: Cumulative. Asked and 
20 
answered. 
21 
THE WITNESS: No. 
22 
BY MR. EPSTEIN: 
23 
Q. Did she ever tell you that she ever suffered a 
24 
loss of income, either past income or the futurability 
25 
to earn income as a result of her relationship with 
lb ammo...4,1.6,s 
29 (Pages 266 to 269) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
7a82(Iddf-59ee-4e57-9cd0-83920560Dre0 
EFTA01076015

Pacie 2;J 
Page 272 
1 
Mr. Epstein? 
2 
A. No. 
3 
Q. Did she, Jane Doe 7, ever tell you that she 
4 
was, as a resuh of her contact with Mr. Epstein, that 
5 
she had been required to see a psychiatrist or a 
6 
psychologist or some sort of mental health counselor? 
A. Not directly, no. 
3 
Q. And the only thing you know is what you heard? 
9 
A. Was told to me from 
10 
Q. All right. Did Jane Doe 7, Jane Doe 3. —
11 
well, let me grace that. 
12 
Did Jane Doe 7 ever tell you that she was 
13 
embarrassed or humiliated as a result of her actions 
14 
with Mr. Epstein? 
15 
MR. HOROWITZ: Form. Cumulative. 
16 
THE WITNESS: No. 
17 
BY MR. CRITTON: 
18 
Q. You said at ono time or on a number of 
19 
occasions various individuals approached you so that 
20 
they could go to Mr. Epstein's home? 
21 
A. Uh-huh. 
22 
Q. Is that correct? 
23 
A. Yes. 
24 
Q. Did that include Jane Doe 7 and Jane Doe 4? 
25 
A. Yes. 
1 
Q. What was 
— let me strike that. 
2 
Did you know anything about'., other than 
3 
that — at the time that you spoke with her, other than 
4 
she was dating 
at the time? 
5 
MR. KUVIN: Form. 
6 
MR. HOROWITZ: Form. 
THE WITNESS: That she was dating-? No. 
8 
I mean, that's all I knew. 
9 
BY MR. CRITTON: 
10 
Q. Well, did you know anything about her 
11 
reputation around school? 
12 
A. Yes. 
13 
Q. What was her reputation? 
14 
MR. KUVIN: Object to the form. 
15 
THE WITNESS: She was promiscuous. 
16 
BY MR. CRITTON: 
17 
Q. And you had heard that from a number of 
18 
people? 
19 
MR. KUVIN: Object to the form. 
20 
THE WITNESS: ! heard that from two people 
21 
BY MR. CRITTON: 
22 
Q. To your knowledge, was she sexually active? 
23 
A. Yes. 
24 
Q. Did she tell you that or did NI tell you 
25 
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 
Page 271 
Q. Did that include Jane Doe 3? 
A. I can't remember. 
Q. Now, Mr. Kuvin did ask a number of questions 
about 
is a person who you told — you told to 
tell Epstein if asked that she was 18? 
A. Yes. 
Q. Did she have any problem with that? 
A. No. 
MR. HOROWITZ: Object to the form. 
MB. KUVIN: Join. 
BY MR. CRITTON: 
Q. What was Is 
did you know who'. was? 
A. Yeah. 
Q. I mean, you knew. from — from high school? 
A. No. 
Q. You knew her throughlM? 
A. Yes. 
Q. All right. And when you told, about or told 
her about — let me strike that. 
Did you tell me she had heard about it —
heard about Epstein from someone else and she approached 
you or did you say you approached I.? 
A. 1 had said something to her and she had asked 
me if I could take her. 
Page 273 
1 
A. Both. 
2 
Q. And serially active, both intercourse and oral 
3 
sex? 
4 
A. Yes. 
5 
Q. And did I. — well, let me strike that. 
6 
Do you know whether. also was a user of 
7 
illegal drugs or non-prescription drugs? 
8 
MR. KUVIN: Objection to form. 
9 
THE WITNESS'. Yes. 
10 
BY MR. CRITTON: 
11 
Q. And what kind of drugs were you aware that she 
12 
used? 
13 
A. Marijuana. 
14 
MR. HOROWITZ: Fenn. 
15 
BY MR. CRITTON: 
16 
Q. Anything else? 
17 
A. Not that I know of 
18 
Q. When'. — so you talked tol. about 
19 
Mr. Epstein. The matter dropped. And did she 
20 
re-contact you, like, right away or within a few days? 
21 
A. We had -- we had talked about it. I had said 
22 
something to her. She had asked me if I could take her. 
23 
And within a day or a couple days we had set it up. 
24 
Q. But she approached you? 
25 
A. Well, 1 had said something about it and then 
30 (Pages 270 to 273) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
7a82dddf-59ec.4e57.9cd8-8392056001c0 
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Page 274 
1 
she had asked me to take her. 
2 
Q. But, again, she could have said, I'm not 
3 
interested, don't —
4 
A- But she didn't. 
5 
MR. KUVIN: Objection to form. Move to 
6 
strike. 
7 
BY MR. CRITTON: 
8 
Q. Did she ever say, I'm not — let me start 
9 
again. 
10 
You told her about it? 
11 
A. Uh-huh, yes. 
12 
Q. Did you then follow up with ha on multiple 
13 
additional conversations or was it'. then who contacted 
14 
you and said, I'd like to go? 
15 
A. It was more we had talked about it, she 
16 
contacted me or I contacted her and then we went. It 
17 
wasn't like a phone tag game, no. 
3.8 
Q. Did you have to push her in any way to go? 
19 
A. No. 
20 
Q. Did she -- was she encouraging you to take 
21 
her? 
22 
A. Yes. 
23 
Q. And did you tell her the same thing that you 
24 
had told the other girls, Le., tell him — lie about 
25 
your age, the more you do, i.e., in terms of how you're 
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 276 
is, you never had -- you never spoke with Mr. Epstein by 
phone, never tested back and forth, nor never -- nor did 
you ever email; is that correct? 
A. That's correct. 
Q. Did -- you knew Jane Doe 7 both before and 
after she had seen Mr. Epstein; is that correct? 
A. Yes 
Q. And as of the last -- and did you see -- after 
Jane Doe 7 stopped going to Mr. Epstein's home, did you 
see her on — well, I think you said you were roommates, 
if I understood correctly? 
A. That's true. 
Q. How long were you all roommates? 
A. Between -- about seven months. 
Q. Give me a time frame, if you could, 
A. 
Q. And did you stay — so at least you saw her 
pretty much everyday dining that time period? 
A. That's true, yes. 
So during the 
you saw Jane Doe 7 on 
almost a daily basis. 
On those 
during that daily basis, did she 
ever appear to be so depressed to you or depressed or 
Page 275 
1 
dressed or how you're undressed, you'll make more money? 
2 
A. That's correct. 
3 
Q. Did she express any concern or reticence about 
4 
going? 
5 
A. No. 
6 
Q. All right. Did she express any -- instead of 
7 
using reticence, probably not a great word — did she 
8 
express any hesitation or concern about going? 
9 
A. No. 
10 
MR. KUVIN: Objection. Cumulative. 
11 
BY MR. CRITTON: 
12 
Q. When she came — well, let me strike that. 
13 
When she came down after you went to Epstein's 
14 
home, did she ever express any type of concern or 
15 
complaints about anything that had occurred with 
16 
Mr. Epstein? 
17 
A. No. 
18 
Q. Did she express to you at any time that there 
19 
had been any inappropriate conduct --
20 
A. Na 
21 
Q. — or contact? 
22 
A. No. 
23 
MR KUVIN: Objection to form. 
24 
BY. MR. CRITTON: 
25 
Q. If I understood your — your earlier testimony 
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 277 
upset to any degree that she did not appear to be 
carrying out ha daily activities of living? 
MR. HOROWITZ: Form. 
THE WITNESS: No. 
BY MR. CRITTON: 
Q. Did you ever see Jane Doe 7 hesitate to go to 
a party or go to a bar? Well, let me stile that. 
Did you ever go with Jane Doe 7 to bars, to 
social gatherings, to parties during that time frame? 
A. Yes. 
Q. And did she ever appear to be emotionally 
disturbed or have any type of depression or concern that 
prevented her from attending parties, going out to bars, 
engaging in social activities, at least from what you 
observed? 
MR. HOROWITZ: Form. 
THE WITNESS: No. 
BY MR. CRITTON: 
Q. Did she ever express to you during that 
approximately six or seven months -- well, let me strike 
that. 
During that six or seven months, did she ever 
talk about Epstein? 
A. No, not that I can remember. 
Q. Did either one of you bring up Epstein? 
PROSE COURT REPORTING AGENCY, 
31 (Pages 274 to 277) 
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Page 278 
1 
A. It was a joke from time to time. 1 mean, we 
2 
joked around about how nice it would be to find an 
3 
Epstein that lived in 
. We joked about it. But 
4 
it wasn't anything derog — well, I mean, you can 
5 
consider that derogatory. But there was nothing about 
6 
her psychiatric health or her ability to move on with 
7 
life. 
8 
Q. Oka
rou say you joked about if you had an 
9 
Epstein in 
meaning what during that time frame? 
10 
A. Meaning, it would just be nice if we had a guy 
11 
for income, I guess. 
12 
Q. And this time you were -- let's see, in 
13 
you were 20 years old? 
14 
A. (Jh-huh. 
15 
Q. And 
or almost, you were just about 19, 
16 
about to nun 20. Is Jane Doe 7 the same age as you or 
17 
you're-
18 
A. Jane Doe 7 is a year younger. 
19 
Q. So she would have been 18, closing in on 
20 
I9, — 
21 
A. Yes. 
22 
Q. -- depending on when her birthday was? 
23 
So if I understand your testimony, the 
24 
discussion that you and Jane Doe 7 had regarding 
25 
Epstein, at least, in — during that six or seven month 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 280 
BY MR CR117ON: 
Q. During the same -- after 
and 1 
understand that you returned because o 
— 
A. Yes. 
Q. And you returned back to the 
area? 
A. Yes. 
Q. And you had little contact with Jane Doe 7 
after that point in time for some of the reasons you 
told us? 
A. That's correct. 
Q. And Jane Doe 4 u u 
did you stay in somewhat
ntil the point that you 
returned
contact with her during the time period that you and 
Jane Doe 7 were roommates? 
A. I wouldn't say friends. When I lived with 
Jane Doe 7. like I said, I respected her as a roommate, 
so I treated Jane Doe 4 differently. But we weren't 
friends. 
Q. All right. All you know is — but she did 
come out with you to go dancing with you at the 
A. Yes. 
MR. CRITFON: I'm sorry. Dancing. Jane Doe 4 
Page 279 
1 
time period was, it would be nice to have an Epstein up 
2 
there, as distinct from, I'd say, either one of you 
3 
complaining or suggesting that you were depressed. 
4 
humiliated, concerned or had any type of emotional 
5 
problems? 
6 
MR. HOROWITZ: Form. Compound. 
7 
MR. KUVIN: Join 
8 
MR. CRITTON: Well, let me rephrase it 
9 
BY MR. CRiTFON: 
10 
Q. If I understood your testimony, is, you and 
11 
Jane Doe 7 joked about, it would be nice to have an 
12 
Epstein up there? 
13 
MR. HOROWITZ: Asked and answered. 
14 
MR KUVIN: Join. 
15 
THE WITNESS: Yes. 
16 
BY MR. CRITTON: 
17 
Q. And did you and Jane Doe 7 ever talk about or 
18 
either one of you ever express any type of that either 
19 
one of you had suffered any type of emotional injury or 
20 
traumatic event as a result of your involvement with 
21 
Mr. Epstein? 
22 
MR. HOROWITZ: Cumulative. Asked and answered 
23 
as to Jane Doe 7. 
24 
MR. KUVIN: Join. 
25 
THE WITNESS: No. 
Page 281 
stripped. 
2 
BY MR. CRITTON: 
3 
Q. Anyhow with regard to when Jane Doe 4 would 
4 
cane up to 
, did she come up on more than one 
5 
occasion —
6 
A. I can't remember. 
7 
Q. — during the time you were roommates with 
8 
Jane Doer 
9 
A. I can't remember. 
10 
Q. You just remember the one time? 
11 
A. That's correct. 
12 
Q. And during the time that she came up there, 
13 
did she stern to have any type of lingering depression or 
14 
psychological condition, at least that she either 
15 
expressed to you or that you observed? 
1 6 
MR. HOROWITZ: Form. Foundation. 
17 
THE WITNESS: No. 
18 
BY MR. CRITTON: 
19 
Q. Did you and Jane Doe 7 - did you and Jane Doe 
20 
4 ever e-mail back and forth, either on My Space or on a 
21 
social networking thing? 
22 
A. I believe My Space. 
23 
Q. And did she ever express to you -- and let me 
24 
strike that 
25 
In the times that she would communicate with 
MoleasaMeeS1 
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you on My Space, did she ever suggest that she was 
2 
Wing any type of emotional problems? 
3 
MR. HOROWITZ: Cumulative. Asked and 
4 
answered. 
5 
BY MR. CRITTON: 
6 
Q. On the My Space? 
7 
A. No. 
Q. Did she ever, in communicating, indicate that 
9 
she was having pretty good life, that things seemed to 
10 
be okay with ha? 
11 
A. Yes. 
12 
Q. And did she — "she," meaning, Jane Doe 4 
13 
did she appear to be enjoying college and the college 
14 
experience? 
15 
A. Yes. 
16 
MS. BLANTON: I need a quick restroom break, 
17 
if you're at a deceit stopping point. 
18 
MR. CRITTON: I'm at a decent stopping point 
19 
and ni try to imish in about 10 or 15 minutes. 
20 
VIDEOGRAPHER: Going off the record. The time 
21 
is 5:18 p.m. 
22 
(Brief recess.) 
23 
VIDEOGRAPFIER: Were beck on the video record. 
24 
The time is 5:22 p.m. 
25 
BY MR. CRITTON: 
Page 284 
1 
she used? 
. 
2 
A. Cocaine. 
3 
Q. To your knowledge, was Ms. Jane Doe 3. ever 
4 
pregnant? Did she ever have an abortion? 
5 
A. I have no idea. 
6 
Q. To your knowledge, did Ms. Jane Doe 3 have any 
7 
STDs? 
8 
A. I have no idea. 
9 
MR. HOROWITZ: Object to the form. 
10 
BY MR. CRITTON: 
11 
Q. To your knowledge, did Ms. Jane Doe 3 have any 
12 
criminal history? 
13 
A. I have no idea. 
14 
Q. Did she ever express to you that she, Ms. Jane 
15 
Doe 3, ever express to you that she had been molested by 
16 
an individual? 
17 
MR. HOROWITZ: Form. 
18 
THE WITNESS: No. 
19 
BY MR. CRITTON: 
20 
Q. By a person namer=? 
21 
A. By who? 
22 
Q. By a person named MI? 
23 
MR. HOROWITZ: Form. 
24 
THE WITNESS: No. 
25 
BY MR. CRITTON: 
Page 283 
1 
Q. I vault to ask you some specific questions 
2 
about a number of the girls. I want to start with Jane 
3 
Doe 3 if I could. 
4 
You described her earlier in response to 
5 
either Mr. Kuvin or Mr. Horowitz's questions that her 
6 
reputation was that she was promiscuous? 
7 
MR. HOROWITZ: Object to the form. 
8 
THE WITNESS: That's correct. 
9 
BY MR. CRITTON: 
10 
Q. And when you say prorniscuim4 what do you 
11 
mean,-? 
12 
A. Sleeping around. Having boys come over and 
13 
stay the night with her. 
14 
Q. And did you from time to time witness that? 
15 
A. I was there one night -- twice actually, two 
16 
different nights. 
17 
Q. And did she — and was this before she ever 
18 
went over to Mr. Epstein's home? 
19 
A. I believe so, yes. 
20 
Q. And with regard to Jane Doe 3, separate and 
21 
apart from being promiscuous, based upon what you heard 
22 
and saw, did she -- were you aware whether she used 
23 
illegal drugs? 
24 
A. Yes, she did. 
25 
Q. And what kind of drugs were you aware of that 
Page 285 
1 
Q. Did she ever indicate to you, again, that Jane 
2 
Doe 3 — let me strike that. 
3 
Did you understand anything about her family 
4 
life? 
5 
A. 
6 
Q. 
7 
A. 
8 
Q. 
9 
3? 
10 
A. That's all I know. 
11 
Q. The 
you were asked a question earlier about 
12 
generically whether — let me strike that. 
13 
The girls that you asked to go or came to you 
14 
10 ask to go to Mr. Epstein's and, in fact, of the 
15 
approximately 12 that went to Mr. Epstein, how would you 
16 
have described them? Would you describe them, like, 
17 
middle class? Upper class? Middle class? Lower middle 
18 
class? 
19 
MR. HOROWITZ: Foundation. Predicate. 
20 
MR.1CUVIN: Form. 
21 
THE WITNESS: Same as me, middle class. 
22 
BY MR. CRITTON: 
23 
Q. And all of the girls that went, the females 
24 
that went to Mr. Epstein's home, did you have -- that 
25 
is, with almost all of them, did you have some idea or 
I knew her sister. 
And her sister, was she in your grade or --
She went to school with my sister. 
Did you know anything else about her, Jane Doe 
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did you know where they lived? 
2 
A. Yes. 
3 
Q. And, so, you were familiar with — of the 12 
4 
females that went to Mr. Epstein's home, you were 
5 
familiar with where they lived, their neighborhood, 
6 
their house, you know, what kind of car they either 
7 
drove or were transported in? 
8 
A. Yes. 
9 
Q. And, so, when you say they were from the 
10 
middle class, that was based upon your observations? 
11 
A. Yes. 
12 
Q. With regard to Jane Doe 4, you knew 
before 
13 
she ever went to Mr. Epstein's home, were you familiar 
14 
with any of her boyfriends? 
15 
A. llh-huh, yes. 
16 
Q. And what was her main — well, let me strike 
17 
that. 
18 
You also described Jane Doe 4 as being 
19 
promiscuous? 
20 
A. Yes. 
21 
Q. And you knew that how? 
22 
A. We were friends. She was dating 
23 
MIE. She was cheating on him every second that we 
24 
were together. She had guys sneaking in and out of her 
25 
window. Whenever her and 
would break up she 
1 
or during the break up? You're kind of — 
2 
BY MR. CRITTON: 
3 
Q. During the entire time she dated him, 
4 
including break ups, did you see her having or engaging 
5 
in some type of sexual activity? 
6 
A. At least two. 
7 
Q. And as to Jane Doe 4, were you aware of 
8 
whether or not she used illegal drugs? 
9 
A. Yes. 
10 
Q. And what illegal drugs were you aware that she 
11 
took? 
12 
MR. HOROWITZ: Form. Foundation. 
13 
THE WITNESS: Xanax, marijuana and cocaine. 
14 
BY MR. CRITTON: 
15 
Q. And did you actually see her take those? 
16 
A. Yes. 
17 
Q. Now, 
=, 
were you -- did -- were 
18 
you ever -- well, let me strike that. 
19 
I assume you knew him? 
20 
A. Yes. 
21. 
Q. Were you ever present when Mr. 
22 
bit or physically abused Ms. Jane Doe 4? 
23 
A. Yes. 
24 
Q. On more than one occasion did you see him —
25 
k 
Yes. 
struck, 
1
 
I 
Page 287 
1 
would date another guy for maybe three days and then get 
1 
2 
back with 
. 
2 
3 
Q. And was she hooking up with these guys? Did 
3 
4 
she tell you that? 
4 
0 
MR. HOROWITZ: Objection. Foundation. 
5 
6 
THE WITNESS: I saw it a few times. 
6 
7 
BY MR. CRITTON: 
7 
8 
Q. And you say you saw it on a few occasions? 
8 
3 
THE WITNESS: Yes. 
9 
10 
BY MIt. CRITTON: 
10 
11 
Q. So you — you physically — you have personal 
11 
12 
knowledge during the time that she was dating 
12 
13 
during the times they were broken up, on more than one 
13 
14 
occasion you would see her having or engaging in sexual 
14 
15 
activity with others, other males? 
15 
16 
A. Not necessarily having sex. Engaging, yes. 
16 
17 
Q. Well, in addition — let's see. One of the 
i 7 
18 
individuals was a guy that you were dating, correct? 
18 
19 
A. Yes. 
19 
20 
Q. And did you see her with others as well? 
20 
21 
A. Yes. 
21 
22 
Q. Approximately how many other individuals, 
22 
23 
separate gart from =, 
during the time she was 
23 
24 
dating
. 
24 
25 
MR. HOROWITZ: During the time she was dating 
25 
Page 289 
Q. — physically abuse he 
A. (Nods head.) 
Q. What was her reaction to the physical abuse 
that her boyfriend was doing to her? 
A. Sometimes she would hit back. She would fight 
back. Other times she would spit on him. Sometimes slit 
would run from him. 
Q. You'd see her actually hit and spit — hit him 
back and spit on him? 
A. That's correct. 
Q. Did you ever see him spit on her? 
A. Yes. 
Q. Did she ever -- did you ever discuss with her, 
that is, with Jane Doe 4, that maybe this wasn't a 
healthy relationship? 
A. Several times. 
Q. What was her response? Was this prior to her 
seeing Mr. Epstein or ever meeting Mr. Epstein? 
A. That's correct. 
Q. And what was her response to your 
conversations with her about the phikal and verbal
abusethat MI -- I'm sorry -‘ 
•
that 
was causing her? 
A. We staged an intervention once with her family 
and they called the police. And she told the police 
PROSE COURT REPORTING 
34 (Pages 286 to 289) 
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Page 290 
I. 
officer she didn't want to have a restraining order or 
2 
to press charges against him after she got beat by him. 
3 
We had several conversations about her being 
4 
in an unhealthy relationship and maybe going to a clinic 
5 
where abused women or women with relationship issues 
6 
should go to maybe get therapy as couples or to leave 
7 
him. 
8 
And she looked at me like I was nuts. I'm in 
9 
love with him. I don't want to leave him. He loves me. 
10 
Crazy talk. 
11 
Q. So despite your involvement in speaking with 
12 
her and her family and intervention with her, nobody 
13 
could talk her out of staying in her abusive 
14 
relationship? 
15 
MR. HOROWITZ: Form. 
16 
THE WITNESS: No. 
17 
BY MR. CRITTON: 
18 
Q. In terms of Ms. lane Doe 4, were you ever 
19 
aware whether she was pregnant? 
20 
A. Yes. 
21 
Q. On how many occasions were you aware that she 
22 
was pregnant? 
23 
A. Two or three. 
24 
Q. And did she ever have a child? 
25 
A. No. 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 292 
BY MR. CFUTTON: 
Q. And what did the video depict? 
A. I never saw it myself, but there wereict7res 
of her on the Internet going around with 
lesbian 
pictures in their underwear, their thong, posing on top 
of each other, making out. 
Q. Did you ever see any of those pictures or 
that's just what you were told? 
A. That's what I was told. 
Q. And who told you that? 
A. My boyfriend at the time. 
Q. Who was? 
A. =. 
Q. And in terms of lane Doe 4, did you ever talk 
to her about it, say, hey, I hea.idou did a video with 
— what was her name? — 
A. Yes. 
Q. Did you ever ask her about it? 
A. My boyfriend did while I was present and she 
said that she didn't care, it didn't bother her, and 
that if somebody had a problem with it, they could F 
off. That was pretty much her attitude. 
Q. And you heard her say that? 
A. Yes. 
Q. And did she ever indicate that the pictures 
Page 291 
1 
Q. Did she have abortions? 
2 
A. Yes. 
3 
MR. HOROWITZ: Form. 
4 
BY MR. CRITTON: 
5 
Q. And did she tell you that? 
A. Yes. 
7 
Q. And did she tell other people, as far as you 
3 
know? 
9 
A. Yes. 
10 
Q. Who else did she tell? 
11 
A. Jane Doe 7. She told 
12 
obviously. And that's &Ilk:
M. ,. 
as 
13 
well. 
14 
Q. So at least among that group it was pretty 
15 
common knowledge that she had had three abortions? 
16 
MR. HOROWITZ: Form 
17 
THE WITNESS: Two or three. 
18 
BY MR. CRSITON: 
19 
Q. Two or three abortions. Do you know if she 
20 
ever told her family? 
21 
A. No, I do not. 
22 
Q. Were you ever aware of a video that she made 
23 
with another female? 
24 
lit. HOROWITZ: Form. 
25 
THE WITNESS: Yes, in big' school. 
Page 293 
1 
that were displayed of her having — in her thong, in 
2 
some sort of, at least whatms
rceived to be a 
3 
lesbian relationship with 
that that caused her 
4 
any embarrassment or humiliation? 
5 
MR. HOROWITZ: Form. 
6 
THE WITNESS: No. 
7 
BY MR. CRITfON: 
8 
Q. Well, did you hear — so I'm clear, is, I 
9 
thought -- thought you said that 
asked her about 
10 
the pictures? 
11 
A. Yes, he did. 
12 
Q. And did he describe the pictures as to what, 
13 
say, hey, I hear 
did he say something like, hey, 1 
14 
hear you and 
are on the Internet and shows 
15 
pictures of you guys on top of each other? 
16 
A. No. He had just briefly mentioned that there 
17 
were pictures on the Internet floating around and he 
18 
caught one of them. 
19 
Q. And that's when she said, if you have a 
20 
problem with it, Fa, 
21 
A. Pretty much was her attitude. 
22 
Q. All right. Were you ever aware that she did 
23 
her own photography, made a video of she and 
24 
engaging in various sexual acts? 
25 
MR. HOROWITZ: Form. 
35 (Pages 290 to 293) 
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THE WITNESS: I can't disclose that 
2 
information. 
3 
BY MR. CRIT'fON: 
4 
Q. Let me ask it this way: Did she ever tell 
5 
you? 
6 
A. She never told me. 
7 
Q. Did she or 
ever show you a 
8 
video of the two of them having sex? 
9 
A. No. 
10 
Q. Did =, 
from your observations 
let me 
11 
strike that. 
12 
Wile., were present, did you ever observe 
13 
using illegal drugs? 
14 
A. Yes. 
15 
Q. Was he — did you ever view him or observe him 
16 
taking or drinking excessively? 
17 
A. Yes. 
18 
Q. Did — was 
Ell 
from at least your 
19 
perception, a drug addict? 
20 
MR. HOROWITZ: Form. 
21 
THE WITNESS: Yes. 
22 
BY MR. CRAYON: 
23 
Q. Well let the ask ou this: How would you 
24 
describe 
and his use of illegal drop? 
25 
A. He had an addiction. 
Page 296 
1 
Q. And at the times — on some of the occasions 
2 
that you saw 
present and taking illegal 
3 
drugs, was Jane Doe 4 partaking in the same illegal 
4 
drugs? 
5 
MR. HOROWITZ: Form. 
6 
THE WITNESS: Yes. 
7 
BY MR. CRITTON: 
8 
Q. Was 
known for being a seller 
9 
of drugs? 
10 
MR. HOROWITZ: Form. 
11 
THE WITNESS: I don't know. 
12 
BY MR. CIUTTON: 
13 
Q. All you blow, he was a user? 
14 
A. Yes. 
15 
Q. Was Jane Doe 4 dating 
16 
she was seeing Jeffrey Epstein? 
17 
A. Yes. 
18 
Q. Did she ever tell IM? 
19 
A. She wouldn't. 
20 
MR. HOROWITZ: Form. 
21 
BY MR. CRITTON: 
22 
Q. To your knowledge? 
23 
A. No. 
24 
Q. Did you ever see 
25 
kill or to injure Jane Doe 4? 
during the time 
threaten to 
Page 295 
1 
Q. And what kind of drugs, illegal drugs did he 
2 
take? 
3 
A. Cocaine, pills, alcohol. 
4 
Q. Did you ever see him using those, that is, 
5 
cocaine, pills — cocaine and pills in the presence of 
6 
he and Jane Doe 4? 
7 
A. Yes. 
8 
Q. So if I had to ask you to assume that Jane Doe 
9 
4 has testified in this case that she was unaware that 
10 
abused illegal drugs, would you be surprised to 
11 
hear that testimony? 
12 
MR. HOROWITZ: Form. 
13 
THE WITNESS: Not really. 
14 
BY MR. CRITTON: 
15 
Q. Because you think she doesn't tell the truth? 
16 
MR. HOROWITZ: Form. 
17 
THE WITNESS: She doesn't tell the truth. 
18 
BY MR. CRITTON: 
19 
Q. And, so, let me just ask it this way: Were 
20 
ifisically present when 
when you saw 
21 
taking illegal drugs and Jane Doe 4 was there 
22 
and saw it as well? 
23 
A. Yes. 
24 
MR. HOROWITZ: Form. 
25 
BY MR. CRITTON: 
Page 297 
1 
A. On a regular basis. 
2 
 Q. Literally? 
3 
A. Literally. 
4 
Q. What was her response to that? 
5 
A. She -- upset, start a physical fight. 
6 
Q. At what point were you aware when she stopped 
7 
dating =? 
8 
A. I wasn't aware that they had stopped dating 
9 
until I moved back home and she was with another guy. 
10 
Q. Who was the guy that she was with? 
11 
A. M. 
12 
Q. And who is M? 
13 
A. Her boyfriend. 
14 
Q. Is that — when is the last time you saw Jane 
15 
Doe 4? 
16 
A. I don't remember. I want to say, 
17 
Q. Was that -- was — and who was she there with 
18 
at the time? 
19 
A. It was her and two girls. 
20 
Q. And did you talk about Epstein at all on that 
21 
occasion? 
22 
A. No. 
23 
Q. Did she try to bring it up with you? 
24 
A. No. 
25 
Q. Did you speak to her? 
36 
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7 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
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. No. 
Q. You saw her, but neither one of you spoke? 
A. Yes. 
Q. With 'regard to MI, her boyfriend, do you 
know what his last name is? 
A. No, I do not. 
Did you ever know a boy that she dated named 
A. Yes. 
Q. And how did you know M? 
A. I didn't know him personally. She talks about 
him. They had dated for a short period of time. I'm 
guessing this is either in between M. 
I can't be 
sure. His name came up a lot, but that's it. 
Q. Did she ever indicate to you whether while she 
was dating • 
she was cheating on him? 
A. No, she never indicated that. 
Q. With regard to 
M
.
 
do you knoW anything 
about him? 
A. Hes a drug dealer. 
Q. And how do you know 
is a drug dealer? 
A. I was around them both. 
Q. Were you around 
when he was using 
illegal drugs? 
A. Yes. 
1 
A. Yes. 
2 
Q. Did she tell you that? 
3 
A. Yes. 
4 
Q. What was her -- was she concerned about that? 
5 
A. She said he was going to eventually stop. 
6 
MR. KUVIN: I'm sorry•. Is
 a Plaintiff 
7 
in one of these cases? 
8 
I was just curious. 
9 
BY MR. CRITTON: 
10 
Q. When is the last — when is the last time you 
11 
had any conversation with Jane Doe 4? 
12 
A. When I sent her a text message — text message 
13 
letting her know that I knew what was going on about the 
14 
whole lawsuit. 
15 
Q. Do you know anything about Jane Doe 4's home 
16 
life? 
17 
A. Yes. 
18 
MR-HOROWITZ: Form. Vague. 
19 
MR. CRITTON: I'm sorry? 
20 
MR. HOROWITZ: Vague. Her home life. What 
21 
does that mean? 
22 
BY MR. CRITTON: 
23 
Q. You know where she lived? 
24 
A. Yes. 
25 
Q. Okay. Do you know anything about her parents? 
Page 299 
1 
Q. And what kind of illegal drugs was he using? 
2 
A. Cocaine. 
3 
Q. And at the time — and this was well after 
4 
Epstein; that is, you had — either one of you had seen 
Mr. Epstein? 
A. I'm sorry? 
Q. Was the time that she when she — "she," 
meaning, Jane Doe 4 -- started dating MI, was that 
after the time that she had seen Mr. Epstein? 
A. Yes. 
Q. And when she started dating M, were you 
ever present when you saw her taking illegal drugs with 
MR. HOROWITZ: Form. 
THE WITNESS: No. 
BY MR. CRITTON: 
Q. You just saw 
using cocaine? 
A. Yes. 
Q. And in terms of 
being a drug dealer, is 
that — did Jane Doe 4 — did you ever ask Jane Doe 4 
one way about it? 
A. Me and her had a conversation, me coming from 
similar situation, I tried to give her advice. And she 
didn't want to listen. 
Q. Was she aware that 
was a drug dealer? 
Page 301 
1 
A. Yes. 
2 
Q. What do you know about her father? 
3 
MR. HOROWITZ: Vague. 
4 
THE WITNESS: Crazy. 
5 
BY MR. CRITTON: 
6 
Q. And what do you mean, "crazy?" 
7 
A. He — when be talks, he always sniffed. And 
8 
it used to be a joke with me and Jane Doe 4's friends 
9 
until we understood that he was a drug user when he was 
10 
younger. 
11 
Q. Do you know anything about -- as far as you 
12 
know though, during the time that you know him, was he a 
13 
drug user? 
14 
A. I have no idea. 
15 
MR. HOROWITZ: Form. 
16 
BY MI. CRITTON: 
17 
Q. How about her mother? 
18 
A. Nice lady. 
19 
Q. Jane Doe 4's. What do you know about her? 
20 
A. Nice lady. 
21 
Q. Si 
Ina nice home? 
22 
A. 
23 
Q. Pit
o? 
24 
A. 
25 
Q. They live in a nice home? 
I 
I 
1
 
37 (Pages 298 to 301) 
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1 
A. Yes. 
2 
Q. Did Jane Doe 4 have access to nice clothes and 
3 
to, you know, living in a -- being able to drive around 
4 
in a vehicle? 
5 
A. Yes. 
6 
Q. At least have access to a vehicle? 
7 
A. Yes. 
8 
Q. Would you have considered either Jane Doe 3, 
9 
Jane Doe 7, or Jane Doe 4 to be underprivileged or dirt 
10 
poor in any way? 
11 
MR. HOROWITZ: Form. 
12 
THE WITNESS: No, not at all. 
13 
BY MIL CRITTON: 
14 
Q. Did Jane Doe 4 ever tell you how many times 
15 
she had been to Mr. Epstein's home? 
16 
A. No. 
17 
Q. Let me tum to Jane Doe 7. 
18 
You knew Jane Doe 7 from high school? 
19 
A. Yes. 
20 
Q. And you met her through whom? That is, did 
21 
you know Jane Doe 4 first or Jane Doe 77 
22 
A. I knew — I knew Jane Doe 7 first, but me and 
23 
Jane Doe 4 shared a class together. 
24 
Q. Jane Doe 7. Had you ever been to her home? 
25 
A. Yes. 
1 
A. Both. 
2 
Q. And in tams of Jane Doe 7 having a lot of 
3 
boyfriends, did she have anybody that was steady or did 
4 
she go with a lot of men? 
5 
A. She went with a lot of men. 
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Q. From your observations and at least watching 
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her -- well, let me strike that. 
8 
Prior to — well, let me strike that. 
9 
At any time did you ever see Jane Doe 7 using 
10 
any type of illegal drugs? 
11 
MR. HOROWITZ: Fonn. 
12 
THE WITNESS: Yes. 
13 
BY MR. CRITTON: 
10 
Q. What type of drugs did you see her use? 
15 
A. Marijuana and Xanax. 
16 
Q. And did you see her use those before -- let me 
17 
strike that. 
18 
When you all were in high school together, did 
19 
you see her using marijuana and Xanax? 
20 
A. Yes. 
21 
Q. And post-high school and when
were living 
22 
up north — not north — living up in
did she 
23 
continue to use these illegal drugs, at least from what 
24 
you observed? 
25 
A. What I observed? No. 
Page 303 
1 
Q. Nice home? 
2 
A. Yes. 
3 
Q. Ha mother and father, what did you know about 
4 
her home life, in terms of her parents, from what you 
5 
observed? 
6 
A. They spoiled her. 
7 
Q. In what way? 
8 
A. Paid for everything. She never had to work a 
9 
day in her life. They bought her cars all the time. 
10 
Paid her phone bill. Let her pretty much do anything 
11 
she wanted. 
12 
Q. From your observations, at least with Jane Doc 
13 
7, did she seem to be spoiled? 
14 
A. Yes. 
15 
Q. And what was Jane Doe 7 -- from your 
16 
observations, did Jane Doe 7 have a lot of boyfriends --
17 
A. Yes. 
18 
Q. -- when you knew her, again, before 
19 
Mr. Epstein? 
20 
A. Yes. 
21 
Q. And, again, I think you described her as being 
22 
as well promiscuous? 
23 
A. Yes. 
24 
Q. And is that something you observed or was that 
25 
her reputation at school? 
Page 305 
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Q. Did she continue — let me strike that. 
2 
After you were her roommate, did she continue 
3 
to be sexually active? 
4 
A. I don't know. 
5 
Q. Did she continue to date on a regular basis? 
6 
A. I don't know. 
7 
Q. Did she go out -- did she go out often? 
8 
A. I don't know. 
9 
Q. Not right now. When you were roommates? 
10 
A. When we were roommates, yes. 
11 
Q. And did you ever observe — did you ever go 
12 
out with her or out with a group of friends --
13 
A. Yes. 
14 
Q. — to bars? Did she appear to be, at least 
15 
during the time that you were living in 
she 
16 
appeared to date on a regular basis? 
17 
A. Yes. 
18 
Q. Do you know whether Jane Doe 7 -- and I don't 
19 
think I asked you about Jane Doe 4. Do you know whether 
20 
she ever had any type of sexually transmitted dise2se? 
21 
MR. HOROWITZ: Form. Come on, Bob. That's 
22 
just not right 
23 
THE WITNESS: Jane Doe 7.1 heard, but I don't 
24 
know. 
25 
BY MR. CRITTON: 
AL. 
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Page 306 
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Q. Did she ever discuss it with you? 
2 
A. No. 
3 
MR. HOROWITZ: Bob. 
4 
BY MR. CRITTON: 
5 
Q. How about Jane Doe 7, do you know whether she 
6 
ever had any type of — 
7 
A We just talked about Jane Doe 7. 
MR. HOROWITZ: Form. 
9 
BY MR. CRITTON: 
10 
Q. I'm sorry. I meant Jane Doe 4. 
11 
A. Yes. 
12 
MR. HOROWITZ: Form. 
13 
BY MR. CRITTON: 
14 
Q. Let me go back to Jane Doe 4. 
15 
Did Jane Doe 4 ever tell you that she had any 
16 
type of STD? 
17 
A. Yes. 
18 
Q. What did she tell you? 
19 
MR. HOROWITZ: Form. 
20 
THE WITNESS: She told me that 
gave 
21. 
her HPV, which led to warts. 
22 
BY MR. CRITTON: 
23 
Q. And did she tell you that she was embarrassed 
24 
or humiliated about that? 
25 
MR. HOROWITZ: Form. 
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Page 308 
MR. HOROWITZ Form. Cumulative. 
BY MR. CRITTON: 
Q. Is'. the only person you're aware of that 
Jane Doe 7 brought to Mr. Epstein's, that is, by name? 
A. By name, yes. 
Q. Did she indicate to you that she had taken 
other people there? 
A. She didn't and I don't want to speculate. 
Q. And I think you said that Jane Doe 4 said that 
she had brought at least one person there, correct? 
A. Yes. 
Q. Did either Jane Doe 7 or Jane Doe 4 tell you 
what they had — well, let me strike that. 
Did Jane Doe 7 ever tell you what she had told 
before taking her to Mr. Epstein's? 
A. No. 
ai
Did Jane Doe 4 ever tell you what she had told 
before she took her to Epstein's? 
MS. BLANTON: You okay? You need a break? 
THE WITNESS: No. I'm good. 
MS. BLANTON: We're getting long. 
THE WITNESS: It's okay. 
MS. BLANTON: Tell me. 
THE WITNESS: My butt is numb. 
MS. BLANTON: You want to stand up, walk 
Page 307 
1 
THE WITNESS: She told me — well, she asked 
2 
me politely not to mention anything, and that she 
3 
had gone to the gyro and had it taken care of. But 
4 
she didn't realize that 
had given it to 
5 
het 
6 
BY MR. CRITTON: 
Q. And I think you said — I asked you about Jane 
8 
Doe 7. 
9 
To your knowledge, did Jane Doe 7 ever discuss 
10 
with you whether she had an STD? 
11 
MR. HOROWITZ: Form. Asked and answered. 
12 
THE WITNESS: Jane Doe 7 never discussed that 
13 
with me. 
14 
BY MR. CRITTON: 
15 
Q. I think you said Jane Doe 7 brought someone 
16 
named, to Mr. Epstein's home? 
17 
A. Yes. 
18 
Q. Did -- and how did you know that? Did Jane 
19 
Doe 7 tell you? 
20 
A. Uh-huh, yes. 
21 
Q. Yes? Did Jane Doe 7 ever say, you know, my 
22 
experience was so — with Mr. Epstein was so 
23 
inappropriate, I don't want — 1 shouldn't expose any 
24 
other person to Mr. Epstein? 
25 
A. No. 
Page 309 
1 
around? You okay? 
2 
THE WITNESS: I'm good. 
3 
BY MR. CRITTON: 
4 
. Did 
u ever discuss Mr. Epstein with Jane Doe 
5 
Tat
6 
A. Yes. 
7 
Q. And did she approach you? 
8 
A. Yes. 
9 
Q. Or did you approach her? 
10 
A. She approached me and the group I was standing 
11. 
with. 
12 
Q. And who was she with? 
13 
A. A random guy. 
14 
Q And —
15 
MR. CRITTON: I'm sorry? 
16 
MR. HOROWITZ: Go ahead. 
17 
BY MR. CRITTON: 
18 
Q. And when she approached you with this random 
19 
person, were you aware that she was a Plaintiff in these 
20 
lawsuits? 
21 
A. Yes. 
22 
Q. And did she say anything to you about the 
23 
lawsuit or her being a Plaintiff and suing Mr. Epstein? 
24 
MR. HOROWITZ: Asked and answered. 
25 
THE WITNESS: We had discussed it, yes. 
39 (Pages 306 to 309) 
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Page 310 
1 
BY MR. CRITTON: 
2 
Q. AM did she ever tell you why she was bringing 
3 
a lawsuit against Mr. Epstein? 
4 
A. She told me her parents were pushing her to. 
5 
Q. Did she indicate that she really didn't want 
6 
to bring the lawsuit but that her parents vivre pushing 
7 
her? 
8 
MR. HOROWITZ: Form. 
9 
THE WITNESS: She said it wasn't her fault and 
10 
that her parents had really been pushing the issue. 
11 
BY MR. CRITTON: 
12 
Q. Did you ever know a person named M.? 
13 
A. Yes. 
14 
Q. Do you know whether she went to Epstein's? 
15 
A. She did. 
16 
Q. And do you know who took her? 
17 
A. !can't be quite sure. I don't remember. 
18 
MR. CRITTON: I think I'm almost done. Give 
19 
me about one minute. Just look at my notes. 
20 
BY MR. CRITTON: 
21 
Q. M, 
with regard to — I'm going to ask the 
22 
same question with each of the three — but with regard 
23 
to Jane Doe 3 — Jane Doe 3, did she ever tell you that 
24 
she was sexually assaulted or battered; that is, 
25 
physically touched by Mr. Epstein? 
Page 312 
1 
VIDEOORAPHER: We're back on the video record. 
2 
The time is approximately 5:58 p.m. This is the 
3 
beginning of tape number five. 
4 
REDIRECT EXAMINATION 
5 
BY MR. KUVIN: 
6 
Q. Are you aware that Jeffrey entered into a 
7 
non-prosecution agreement with the Federal Government 
8 
with respect to the claims of all the girls that came to 
9 
his house? Did anyone ever talk to you about that, 
10 
other than your lawyers? 
11 
MS. BLANTON: Other than your lawyers. 
12 
THE WITNESS: No. 
13 
BY MR. KUVIN: 
14 
Q. Are you aware as a part of that agreement he 
15 
essentially hung you out to dry, didn't put you in the 
16 
agreement? 
17 
MS. BLANTON: Anything you know about that 
18 
agreement that you did not learn from your 
19 
attorneys, you can discuss; otherwise, you are not 
20 
to discuss it. 
21 
MR. CRITTON: Form. 
22 
THE WITNESS: Can you repeat the question? 
23 
BY MR. KUVIN: 
24 
Q. Yeah. Are you aware, other than conversations 
25 
with your attorneys, that Jeffrey Epstein did not get 
Page 311 
3. 
A. No. 
2 
Q. Did she ever tell you that she had suffered 
3 
some sort of intentional infliction of some huge or 
4 
severe emotional distress? 
5 
A. No. 
6 
Q. Did Jane Doe 4 ever tell you that she had been 
7 
sexually assaulted or physically battered by 
8 
Mr. Epstein? 
9 
MR. HOROWITZ: Cumulative. 
10 
THE WITNESS: No. 
11 
BY MR. CRITTON: 
12 
Q. Did Jane Doe 7 ever tell that you that they 
13 
had been — that she had been sexually assaulted or 
14 
battered or physically —
15 
ME. HOROWITZ: Cumulative. 
16 
BY MR. CRITTON: 
17 
Q. — touched by Mr. Epstein? 
18 
A. No. That's ridiculous. 
19 
MR. CRITTON: That's all I have. Thank you, 
20 
ma'am. 
21 
THE WITNESS: Can
 get a two-minute 
22 
break? 
23 
VIDEOGRAPHER: Going off the mord. This is 
24 
the end of tape number four. The time is 5:52. 
25 
(Brief recess.) 
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Page 313 
immunity for you with the Federal Government when he was 
negotiating on behalf of 
Lesley Graaf (phonetics), 
(phonetics)? 
MR. CRITTON: Form. 
THE WITNESS: No. 
BY MR. KUVIN: 
Q. Obviously when you were going to Jeffrey's 
house and bringing girls to him it was before December 7 
of 2080 — I'm sorry 
before October 29 of 2007, 
wasn't it? 
A. I don't remember. 
Q. It was before 2007, wasn't it? 
A. Oh, before 2007, yes. 
Q. Okay. Other than what your attorneys may have 
told ou, arc ou aware that he negotiated for immunity 
for 
Lesley Graaf and 
trot. CRITTON: Form. 
THE WITNESS: No. 
BY MR. KUVIN: 
Q. Other than your attorneys, did anyone discuss 
whether or not he should negotiate for immunity for you? 
A. No. 
Q. You seem to have no problems talking about 
other girls being promiscuous, boys being promiscuous. 
40 (Pages 310 to 313) 
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Electronically signed by Sandra Townsend (401 
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Page 314 
blow jobs, sex, abortions, illegal drug use, Xanax, 
marijuana, alcohol, vaginal warts, people who are 
spoiled, drug dealers, sex videos and lesbianism of 
people that may be Plaintiffs in other lawsuits, as well 
as you seem to have no problem talking about people that 
may not be Plaintiffs in civil lawsuits. 
As you sit here today, when did you first 
start having sex? 
MR. CRITION: Form. 
MS. BLANTON: Objection. This was asked 
previously. The objection is the same and her 
instructions not to answer that question are the 
same. 
BY MR. KUVIN: 
Q. So you had no problem talking about other 
peoples promiscuity, drug use, vaginal warts and other 
sexual conduct, but you're not going to sit here and 
tell us anything about your sexual activity; is that 
true? 
MS. BLANTON: You do not need to answer that. 
You do not need to answer that. 
THE WITNESS: Nope. 
MS. BLANTON: Pm instructing you not to 
answer that very argumentative question, if there 
is even is question in it. 
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Page 316 
A. No. 
MR. CRITTON: Form. 
BY MR. KUVIN: 
Q. When did you stop? 
MS. BLANTON: Objection. 
THE WITNESS: I'm asserting my Fifth Amendment 
Right 
BY MR. KUVIN: 
Q. Okay. So you're not using them today? 
A. Asserting my Fifth Amendment Right. 
MS. BLANTON: Objection. I'm instructing her 
not to respond to any more of your questions. 
MR. KUVIN: Oh, we're done? 
MS. BLANTON: No. With what you are doing 
right now we are done. 
MR. KUVIN: Okay. 
BY MR. KUVIN: 
Q. You mentioned before abortions from other 
girls. Have you had an abortion? 
MS. BLANTON: Objection. 
THE WITNESS: I'm asserting my Fifth Amendment 
Right. 
MS. BLANTON: You do not -- Its not even a 
Fifth Amendment Right. It's a right to privacy. 
You are not a Plaintiff or a Defendant in this 
Page 315 
1 
BY MR. KUVIN: 
2 
Q. And you've got no problem talking about other 
3 
people's drug habits, but you're still going to stand by 
4 
a privilege objection or privacy objection as to your 
5 
drug use? 
6 
MS. BLANTON: With regard to drug use, I would 
7 
instruct my client to assert her Fifth. 
8 
BY MR. KUVIN: 
9 
Q. Okay. So you've used marijuana before, have 
10 
you not? 
11 
A. I'm asserting my Fifth Amendment Right 
12 
Q. You've used Xanax before, have you not? 
13 
A. I'm asserting my Fifth Amendment Right. 
14 
Q. You've used cocaine before? 
15 
A. I'm asserting my Fifth Amendment Right. 
16 
Q. You've used LSD before? 
17 
A. Pm asserting my Fifth Amendment Right 
18 
Q. You've used — you used cocaine on a regular 
19 
basis in the past, have you not? 
20 
A. I'm asserting my Fifth Amendment Right 
21 
Q. You've used Xanax on a regular basis in the 
22 
past, have you not? 
23 
A. I am asserting my Fifth Amendment Right. 
24 
Q. You continue to still use Xanax, cocaine, 
25 
marijuana, and other illegal drugs, don't you? 
Page 317 
1 
suit. 
2 
We've had these discussions earlier. It's the 
3 
same objections. 
4 
You do not need to answer that question 
5 
without a Court Order. 
6 
BY MR. KUVIN: 
7 
Q. You talked about boys that have gotten blow 
8 
jobs that aren't Plaintiffs in lawsuits. 
9 
Have you given blow jobs before when you were 
10 
14? 
11 
MS. BLANTON: Objection. You do not need to 
12 
answer that question. 
13 
MR. CRITTON: Form. 
14 
BY MR. KUVIN: 
15 
Q. You talked about other people who had made sex 
16 
videos. Did you ever make a sex video? 
17 
MS. BLANTON: You do not need to answer that 
18 
question. 
19 
Same objection. And it's going to be the same 
20 
objection. 
21 
BY Mr. KUVIN: 
22 
Q. Okay. You talked about whether'. -- I'm 
23 
sorry — whether 
the youngest girl that you brought 
24 
to Jeffrey, was -- seemed emotionally traumatized or 
25 
upset over the incident. 
I 
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