EFTA01076383

Page 154 
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ME VIDEOGRAPHEIt Going off the record at 
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(A brief recess was held.) 
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THE V1DEOGRAPHER: We're back on the 
5 
record at 11:4] 
6 
BY MR. LUT1TER: 
7 
Q. We were talking about U  You said you 
3 
last talked to her while you were in Virginia. 
9 
A. Yes. 
10 
Q. Are you referring to the time period when 
11 
you were living in Virginia? 
12 
A. Sony. Yes. 
13 
Q. Are you still, you still living in 
14 
Virginia? 
15 
A. Yes, I'm back in Virginia. 
16 
Q. So when, when -gLve me the — what year 
17 
it was you last talked to 
18 
A. I just talked to her before I left to Florida 
19 
to tell her I was pregnant when I found out. 
20 
Q. As in pregnant right now? 
21 
A. Yes. 
22 
Q. So you talked to her in the last ten days? 
23 
A. Yes. 
24 
Q. And where were you when you talked to her? 
25 
A. In my house. 
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Page 156, 
other than over the telephone? 
A. On Facebook. 
Q. And is she — you have a Facebook page or 
whatever it is you get these days? 
A. Yes. 
Q. Okay. And she's listed as one of your 
friends? 
A. 
Q. 
A. 
A. 
Q-
A. 
A. 
Q. 
Q. 
A. 
Q. 
Y
listed as one of your friends? 
a l listed as one of your friends? 
No. 
No? 
No. 
lila 
or a? 
is she one of your friends? 
Yes. 
And are you friends on all those people's 
pages that they are friends on yours? 
A. Yes. 
Q. Anybody else that's listed on your 
Facebook as, as — or designated on your Facebook as 
one of your friends that's, that has had any 
involvement with Mr. Epstein? 
Page 155 
1 
Q. In Virginia? 
2 
A. Yes. 
3 
Q. And why were you contacting 
within 
4 
the last ten days? 
5 
A. To tell her I was pregnant. 
6 
Q. So do you have some regular contact with 
7 
her? 
8 
A. Yes. 
9 
Q. With what degree of frequency do you 
10 
communicate with her? 
11 
A. It depends on how busy we both are in our 
12 
lives. But I mean, you {mow, we keep in contact once 
13 
every two weeks or twice a month, or I mean, k depends. 
14 
I mean we're close. 
15 
Q. And, and what — I would like you to tell 
16 
me everything that she's told you about any claim 
17 
she filed against Mr. Epstein. 
18 
A. She just said she had a lawyer and that was 
19 
the last I heard. I never really talked to her about 
20 
that. 
21 
Q. Okay. And what's the status of her claim 
22 
now? 
23 
A. I have no idea. I haven't talked to her about 
24 
that. 
25 
Q. Do you communicate with M. by any method 
Page 157 
1 
A. Not that I'm aware of. Just that I've told 
2 
you. 
3 
Q. What school, what high school did II go 
4 
to? 
5 
A. She went to Wellington and Palm Beach Central, 
6 
and then she moved to Broward. But I don't !mow what 
7 
school she went to there because we lost contact for a 
8 
little while. 
9 
Q. Well, did you and she go to school 
10 
together? 
11 
A. Yeah, in high school and middle school, but we 
12 
were friends in high school. 
13 
Q. And so you, you were a freshman together 
14 
in the same class? 
15 
A. Same class, no. Just in school to 
I
ilOkay. And you both went to, to 
18 
A. Yes. 
I  
sAnd did you, did — you went to 
until when? 
21 
MR. MERMELSTEIN: Form. 
22 
THE WITNESS: 2005. It's 
23 
switched to the alternative scholoNli
r 
24 
BY MR. WITTER: 
25 
Q. And when you switched to the altemath 
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Page 158 
1. 
school was INstilt at 
2 
A. I don't think so. I don't think so. 
3 
Q. She was -- was she in your same class? 
4 
A. No. 
5 
Q. Where was she in relationship to you? 
6 
A. When? 
7 
Q. Like was she a year ahead of you, a year 
8 
behind? 
9 
A. Oh, no, she was the same year as me. 
10 
Q. Okay. So she was -- when I say your same 
11 
class, I didn't mean the particular class. 
12 
A. Oh, same --
13 
Q. I mean the same level. 
14 
A. Yes, yes. 
15 ii
Okay. So, had she already lef
. 
by the time you went to the alternate 
17 
school? 
18 
A. I, I don't recall, but Pm guessing she wasn't 
19 
there, 
20 
Q. Why are you guessing that? 
21 
A. Because we stopped being friends our senior 
22 
year and she moved away, and I don't remember when she 
23 
moved exactly. I don't know if it was before or after 
24 
the alternative school. 
25 
Q. And why did you and she stop being 
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Page 160 
up and then they got back together later on and got 
married. 
Q. &Ehat's )as maiden name? 
A. 1M 
Q. So, she - you knew her as l 
in NH 
school? 
A. In high school. 
Q. She didn't get married to IIII until 
sometime after? 
A. After high school. 
Q. Okay. Now, who told you that -- d your 
husband confum that he had sex with =7 
A. Later on, yes. At first they both denied it. 
But this was in high school; this wasn't when we were 
married or dating. 
Q. I just want to make sure I've got these 
dates right. This would have been when she was 
A. Yes. 
Q. 
d's name is? 
A. les 
No. 5. 
Q. And you first had sex with Mr. Doe No.5. 
back in, what, the ninth grade? 
A. No, it was the summer going into ninth grade. 
Q. Oh, it was before you got to high school? 
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Page 159 
friends? 
A. Over a guy. 
Q. Who was that? 
A. My husband, 
Q. And what, why did you stop being friends 
over your husband? 
A. Because my husband and I, we were, we weren't 
dating but we were together, you know, friends hanging 
out, and then she started liking him. High school 
stuff. 
Q. Well, what do you mean by "stuff"? Did 
she have sexual relations with him? 
A. Yeah, she had sex with him. 
Q. How do you know that? 
A. Because I found out through other people. 
Q. And did you have sex with In's brother? 
A. Its brother? 
Q. Yeah. 
A. NB doesn't have a brother. 
Q. Is there a D. that... 
A. Oh, D. that's, that's her ex-husband. 
Q. You had sex with her ex-husband? 
A. No. When I was in high school I dated 
before. After I dated M. 
she started 
dating 
and then they stayed -- well, they broke 
Page 161 
1 
A. Uh-huh. 
2 
Q. Is when you're — it was right after you 
3 
got out of eighth grade? 
4 
A. Uh-huh. 
5 
THE COURT REPORTER: Is that a yes? 
6 
THE WITNESS: Yes. I'm sorry. 
7 
BY MR. LUTTIER: 
8 
Q. So that puts you at 13? 
9 
A. Thirteen, 14. 
10 
Q. I'm going to get this pinned down. 
11 
MR. MERMELSTEIN: Make, make sure you're, 
12 
you're clear. 
13 
BY MR. LUTHER: 
14 
Q. Yeah. Take your time. 
15 
A. The sinner I was 14. 
16 
Q. Are you sure about that? 
17 
A. No, I'm not positive. Thirteen. 
18 
Q. R was thirteen? 
19 
A. It was the stunner. It was --
20 
Q. It was when you were 13 years old before 
21 
you started high school, right? 
22 
A. It was the summer going into my high school 
23 
for the lust time. 
24 
Q. All right. So that would make you 13? 
25 
A. Thirteen. 
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Page 162 
1 
Q. Okay. And was he the first person that 
2 
you had been sexually active with? 
3 
A. Yes. 
4 
Q. And, in fact, he's, he's the individual 
5 
that you say you lost your virginity to, isn't it? 
6 
A. Yes. 
7 
Q. Now, when you say you lost your virginity, 
8 
you mean that was the first person that you had 
9 
sexual intercourse with? 
10 
A. Yeah. 
11 
Q. Had you had any kind of sexual contact 
12 
with anyone else before you had sexual intercourse 
13 
with Mr. Doe No. 5.? And by that, I mean, when 1 
14 
say •sexual contact," anything of a sexual --
15 
activity of a sexual nature short of actual 
16 
intercourse. So you — that would mean could be 
17 
oral sex, could be, you know, any kind of, of use of 
18 
body parts, anything short of actual intercourse. 
19 
A. Would you consider lensing or... 
Q. No, not kissing. I mean, you know, 
21 
anybody ever, any male before you actually lost your 
22 
virginity to !viz. Doe No. 5 at 13, for example, ever 
23 
rub any portion of your vagina with, you know, their 
24 
band, for example? 
25 
A. Not that I remember. 
21 
Page 164 
1 
other than your, one of your parents, I mean, before 
2 
you had your sex with Mr. Doe No. 5 at 13? 
3 
A. No. 
4 
Q. No, nobody had put their hands up under 
5 
your blouse and 
6 
A. Well -
7 
Q. -- taken your bra off or anything like 
8 
that? 
9 
A. 
I mean, he felt of my breasts, yeah, 
10 
yes. 
11 
Q. Okay. 1 mean, with your bra, you mean 
12 
over your bra or under, took your bra off and --
13 
A. I don't remember. 
14 
Q. You don't remember that? 
15 
A. I don't remember if it was under my bra or 
16 
over my bra. 
17 
Q. How about putting his hand down in your 
18 
pants? 
19 
A. No. 
20 
Q. Anybody ever done that? 
21 
A. Before my husband 
before my 
22 
Q. Right.
23 
A. With=, no. 
24 
Q. Okay. Now, before MI actually had 
25 
sexual Intercourse With you, had you and he engaged 
Page 163 
1 
Q. Any oral sex given by you to anyone before 
2 
you lost your virginity to Mr. Doe No. 5 at age 13? 
3 
A. Not that I recall, no. 
4 
Q: Well, would you recall that? 
5 
A. I'm sorry? 
6 
Q. Would you recall that? 
7 
MR. MERMELSTE1N: Form. 
8 
THE WITNESS: I'm, I'm thinking. You've 
9 
got to give me one second. 
10 
MR. LUTTIER: Sure. 
11 
THE WITNESS: We're going back. No, 1 
12 
don't think so. 
13 
BY MR. LUTTIER: 
14 
Q. In, in other words, it would not be 
15 
uncommon that prior to the time a girl has sexual 
16 
intercourse for the first time, she has engaged in 
17 
some sort of sexual activity short of actual 
18 
intercourse, whether you — I don't know how you 
19 
want to characterize it, but you know what I'm 
20 
talking about? 
21 
A. I mean even touching of the breasts? 
22 
Q. Yeah. 
23 
A. I mean in Fort Lauderdale, 
I mean he 
24 
touched my boob, I mean, but 1... 
25 
Q. Were you ever naked in front of a male, 
Page 165 
1 
in sexual activity, something short of actual 
2 
intercourse? 
3 
k 
Kissing. 
4 
Q. Okay. So your testimony is that there was 
5 
no kind of sexual contact, foreplay or anything like 
6 
that, with Mr. Doe No. 5 until the day you actually 
7 
had intercourse? 
8 
A. I mean, there was kissing and, I mean, we were 
9 
like on top of each other, but it wasn't — that I 
10 
heuQAuber, it was just — I mean, this is so personal 
11 
but I mean, I would be on top of him kissing and stuff. 
12 
It wasn't like he would touch me or anything. 
13 
Q. And you had never performed any sex act.on 
14 
him, whether it was masturbating him by hand or 
15 
anything Ince that? 
16 
A. No. 
17 
Q. Okay. AM right. So Mr. Doe No. 5, you, 
18 
you meet him, you have sex with him at 13? 
9 
A. Uh-huh, yes. 
20 
Q. Then were 
when did your friend, your 
21 
best friend .., have sex with him? 
22 
A. That was in high school. 
23 
Q. Okay. When? 
2 4 
A. My junior year. 
25 
Q. So that's -- would that be before or after 
42 (Pages 162 to 165) 
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Page 166 
Page 168 
you saw Mr. Epstein? 
2 
A. That would be after. 
3 
Q. And when was the first time you were 
4 
suspicious that 
had had sex with your husband? 
A. When — I had suspicions just by the way they 
6 
were acting. But when I first figured out they had sex 
7 
or when I heard about it was from somebody in my class. 
8 
Q. And who was that? 
9 
A. Her name was =. 
10 
Q. Does she have a last name? 
11 
A. She does, but I don't know her last name. 
13 
A. Thati.and 
. had sex. 
Q. And what is it that 
told you? 
ll=
12 
14 
Q. Did she tell you how she knew? 
15 
A. She said that 
came over to her 
16 
boyfriend's house, 
boyfriend's house, and was 
17 
talking about how the condom broke with.. 
18 
Q. And did there come a time that you 
19 
confronted your husband about whether or not he had 
20 
had sex with..? 
21 
A. Yes. 
22 
Q. And when was that? 
23 
A. Right after I found out after school. 
24 
Q. And, and tell me how that conversation 
25 
went. 
1 
A. How many times did we have sex? 
2 
Q. Yeah. I mean, were you having sex 
3 
daily - 
4 
A. It was — 
- or weekly. 
6 
A. I mean, it was, you know, once or twice every 
7 
dine weeks, maybe. 
8 
Q. OW 
9 
A. A month. I mean, it wasn't... 
10 
Q. And, and LI want to make sure I 
11 
understand the terminology you're using When I 
12 
asked you if he was your boyfriend, you seemed to 
13 
indicate that wasn't true. 
14 
A. Yes. 
15 
Q. So having — you, you had sex with people 
16 
that weren't your boyfriend? 
17 
A. I wanted him to be my boyfriend, but he didn't 
18 
want to make a commitment to me. 
19 
Q. Well, were you, were you providing sexual 
20 
favors for him in order to get him to be your 
21 
boyfriend? 
22 
MR. MERMELSTEIN: Form. 
23 
THE WITNESS: No. I just — I really like 
24 
him and I wanted to be with him. And we just 
25 
had sex. 
Page 167 
1 
A. Well, it didn't go good. They both denied it 
2 
and they both were lying about it and said people were 
3 
making things up. 
4 
Q. Well, did you have this conversation with 
5 
them jointly or did you have a conversation with 
6 
them --
7 
A. No, jointl 
was after school, and I 
a 
started talking to 
and M. called over 
and 
9 
they were denying it to me. 
10 
Q. All right. And did you care at that point 
11 
in time? 
12 
A. I cared. Like it really pissed me off because 
13 
she was my best friend and I was like not dating him but 
14 
I was with him. 
15 
Q. And when you say "with him," he was like 
16 
your boyfriend at the time? 
17 
A. Not boy -- we were sexually active at the 
18 
time. 
19 
Q. Meaning you were having sex with him? 
20 
A. Yes. 
21 
Q. But you - I want to go over this. You 
22 
said at the time this occurred you were having sex 
23 
with, with the fellow that became your husband? 
24 
A. Yes. 
25 
Q. And with what degree of frequency? 
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Page 169 
BY MR. LUTTIER: 
Q. So at the time that this happened, in your 
junior year, for what period of time had you and he 
been sexually active? 
A. It started in my junior year. 
Q. Okay. So for six months or --
A. I mean, we started having sex again from when 
we took each other's virginity junior year, and then 
after I found out they had sex, I stopped talking to 
him. 
Q. Okay. Well, my question is: During this 
period of time — when did you recommence having sex 
with him after you had sex —
A- My — 
Q. — with him when you were 13? 
MR. MERMELSTEIN: Objection, asked and 
answered. 
THE WITNESS: My junior year I had sex 
with him. 
BY MR. WITTER: 
Q. Yeah. I !mow, but I am trying to — 
A. And then — 
Q. Okay. 
A. And then we stopped. And then I started 
25 
having sex with him again my senior year. 
43 (Pages 166 to 169) 
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Page 170 
1 
Q. I want to go back to the junior year, 
2 
because you told me that this confrontation that you 
• 3 
had with he and 
happened in your junior year, 
4 
right 
5 
A. Yes. 
6 
Q. You said that at the time that there was 
7 
the confrontation, you and he were sexually active. 
8 
A. Yes. 
9 
Q. You told me when you were 13 you were 
10 
sexually active with him. 
11 
. A. Yet 
12 
Q. You had sex with him and both of you lost 
13 
your virginity. 
14 
A. Yes. 
15 
Q. Then there was a time — when was the next 
16 
time you and he had sex after the first time when 
17 
you lost your virginity? 
18 
A. The date? 
19 
Q. No, I mean 
20 
A. My junior year. 
21 
Q. — six months later. All right. So you 
22 
go from, from after your eighth grade —
23 
A. Yes. 
24 
Q. — which was the first time. There's no 
25 
sex during your ninth-grade year. There's no sex 
Page 172 
1 
773E WITNESS: No, I was just comfortable 
2 
with him. 
3 . • 
BY MR. LUTTD3R: 
4 
Q. Okay. Well, you were having sex with 
5 
other people, too, weren't you? 
6 
A. If I had a boyfriend at that time. 
7 
. Q. Well --
8 
A. I wouldn't be with both of them. But if I had 
9 
lace a break, like, if I 
me and my — a boyfriend 
10 
broke up, I would, you know, hang out with 
again 
11 
and, you know, we would have sex. 
12 
Between the first time you had sex with 
13 
=and when you renewed your sexual relationship 
14 
with him in your junior year, you had sex with a 
15 
number of boys, did you not? 
16 
A. Yet 
17 
Q. Okay. So you were having sex with 
in 
18 
your junior year. 
19 
A. Yes. 
20 
Q. You wanted him to be your boyfriend. 
21 
A. Yes. 
22 
Q. Did, did — were you, exclusively at that 
23 
time just having a relationship with him? 
24 
A. My Puler year? 
25 
Q. Yeah. Did you understand that to be an 
Page 171 
1 
during your tenth-grade year. 
2 
A. Right. 
3 
Q. So, it's at least two years. 
4 
A. Yes, we didn't like each other. 
5 
Q. Then in your junior year, did you start 
6 
having sex with him at the beginning of the year? 
7 
A. It was — I'm going to say it was, like, maybe 
8 
the middle of the year, I guess. 
9 
Q. Okay. So if you started in the middle of 
10 
the year, at the time you' had this confrontation 
11 
with he and 
you and he had been having sex 
12 
regularly for a period of months. 
13 
A. It would go off and on. 
14 
Q. Okay, but you had been off and on for a 
15 
period of months? 
16 
A. Yes. Like, it wouldn't be like we were 
17 
definitely together. We'd, you know, hang out for a 
18 
couple of days, and then if we had sex, we did, and we 
19 
wouldn't talk I mean, it was, it was a very confusing 
20 
relationship with him. 
21 
Q. But you, you were comfortable enough with 
22 
your sexuality that it was acceptable to you to have 
23 
sex with individuals who you didn't consider to be 
24 
your boyfriend? 
25 
MR. MERMELSTE1N: Form. 
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exclusive relationship, you and he? 
A. What do you mean by exclusive? 
Q. You two were the only two having — you 
thought he was just having sex with you and you 
were —
A. That's —
C). — just having sex with him? 
A. That's what I thought. He was just having sex 
with me. 
Q. Okay. And that was your understanding? 
A. Yes. 
Q. Okay. And then it came as a surprise to 
you when this perton 
told you that, that your 
best friend had sex with the fellow that you thought 
was the guy you were having an exclusive 
relationship with? 
A. Yes. I knew that there was something going 
on, but I didn't know it went to that level of sex with 
them. 
Q. And you asked them and they denied it? 
A. Constantly. 
Q. Did there come a time that
 husband 
admitted that • 
had sex with El. in your junior 
year or when you were having a sexual relationship 
with him? 
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Page 174 
A. I don't remember exactly when he told me. 
Q. What's your best estimate? 
A. Probably he accidentally admitted it to me 
over either the summer going into my senior year or the 
beginning of my senior year. 
Q. What do you mean, "he accidently admitted 
A. He slipped when he actually was drinking one 
night and told me that he had asked his mom to take him 
to get checked because the condom broke and he was 
scared that he might have something. And that's when I 
said, really, so you did have sex with 
Q. Let me guess, the rest of the conversation 
didn't go well. 
A. No, no, not really. 
Q. Were you a bit upset when — 
A. Well, I was upset. 
Q. — so you sort of cornered him into that 
or — 
A. No, I — he, he just came out and said that. 
I don't.. 
Q. And so what was your reaction when you —
when he made these comments to you and you said, 
then you did have sex with 
A. I already knew from people telling me, you 
Page 176 
BY MR. LUTTIER: 
2 
Q. Once a person lies to you, especially if 
3 
WS 8, aillEal, a man with whom you have had a 
4 
romantic relationship, once he lies to you, do you 
5 
ever trust him again? 
6 
MR. MERMELSIEIN: Form. 
7 
BY MR. LUTTIER: 
Q. Or Is there always that suspicion in the 
9 
back of your mind? 
10 
A. Yes, there's always a suspicion in the back of 
11 
my mind. 
12 
Q. Okay. Because he had made a specific 
13 
straight-out representation to you when you 
14 
confronted him that it didn't happen. 
15 
A. Yes. 
16 
MR. MERMELSTEIN: Form, asked and 
17 
answered. 
18 
BY MR. LUTTIER: 
19 
Q. Now, when she said she had to get, that he 
20 
had asked his mom to get him checked, had, did he 
21 
tell you if the reason he had to get checked was 
22 
because he had some kind of symptoms or something 
23 
that he was worried about? 
24 
A. No. He was just worried because the condom 
25 
broke. 
Page 175 
know, throughout the rest of the year, you know, that 
2 
they knew and they found out. And my reaction, I mean, 
3 
I already 'mew it regardless if he admitted it or not 
4 
When he admitted it, I was just like he's just a liar 
5 
that didn't tell me the truth. I was upset. 
6 
Q. So certainly that caused you at that 
7 
point — did that cause you at that point to, to 
8 
have some level of distrust with him? 
9 
A. Yes. 
10 
Q. Because he had denied something that you 
11 
had specifically asked him about, right? 
12 
A. Yeah. 
13 
Q. You thought you and he had a, a romantic 
14 
relationship that was exclusive to the two of you. 
15 
A. Yes 
16. 
Q. And then you found out he lied to you. 
17 
A. Yes. 
18 
Q. Do you think that contributed a little bit 
19 
to your, some of your marital problems down the 
20 
road? 
21 
MR. MERMELSTEIN: Pam. 
22 
THE WITNESS: It could. It, it could be 
23 
some of it. I mean, 'don't — I wish I knew 
24 
what caused our problems, but, I mean, that's 
25 
part of it. 
Page 177 
1 
Q. Well, what would he get checked for 
2 
because a condom broke? 
3 
A. I guess just berm CP you use a condom so much, 
4 
and if it breaks you just get scared. 
5 
Q. Well, that would be scared primarily of 
6 
pregnancy, right? 
7 
A. Well, that was one of the issues also that I 
8 
found out later. 
9 
Q. Well, he wasn't getting checked. He 
10 
wasn't worried about him being pregnant 
11 
A. No, but he was also getting checked just 
12 
because the penis touched the vagina and, you know, if, 
13 
you don't know what people have. 
14 
Q. Well, was there some issue about whether 
15 
M. had any kind of sexually transmitted disease? 
16 
A. No. 
17 
Q. Did he indicate to you that he had any 
18 
symptomatology that caused him to think that maybe 
19 
he should get checked? 
20 
A. No. 
21 
Q. When you — did there come a time that you 
22 
confronted II. about the fact that she had denied 
23 
that she had had sex with the, the fellow that 
24 
became your husband? 
25 
A. I confronted her, like I said, in the parking 
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Page 178 
lot with a 
They both denied it And at first I 
believed them, but then I had more people telling me 
that it was true. So I don't remember how this 
happened, but she ended up moving to Fort Lauderdale 
when, you know, I had enough people telling me that they 
actually did have sex, and I lost it on her, and she 
still denied it when she moved away. But after that I 
don't, I don't recall her ever -- me and her ever 
talking about it and admitting it. 
Q. Okay. What -- when did you first meet 
MI? 
A. O 
That was middle school. I met her 
at 
I think my middle school was 
called in Wellington, when I moved with my father. But 
I wasn't friends with her in middle school. I just knew 
of her. 
Q. When did you become friends with her? 
A. My freshman or sophomore year. I think it was 
my freshman. 
Q. And when did you first learn that she had 
been to Mr. Epstein's? 
A. She actually went with 
and I wont with 
in the car with them. That's the only time that I 
know of. 
Q. Okay. Let's talk about that. When did it 
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Page 180 
Q. Now, this is an event that happened over 
six years ago? 
A. Yeah, my sophomore year. 
Q. Would you agree with me that your memory 
about that event now is not precise? 
MR. MERMELSTEIN: Form. 
THE WITNESS: I remember pretty much what 
haPPened• 
BY MR. LUTTIER: 
Q. That's not my question. Would you wee 
with me that your memory about the incidents that 
happened in '03, specifically with respect to 
Mr. Epstein, is not precise? 
MR. MERMELSTEIN: Form. 
THE WITNESS: As in exactly what happened? 
BY MR. LUTTIER: 
Q. Yes. 
A. I remember pretty much what happened, yes. 
Q. Can you say with absolute certainty 
everything that happened? 
MR. MERMELSIEIN: Form. 
THE WITNESS: Every little, little detail, 
probably not. But everything that I remember, 
you know, I remember pretty much everything 
that — I mean, I know it's confusing. I'm 
Page 179 
1 
occur, in terms of time, when you and 
and -
2 
went to Mr. Eain's? 
3 
A. Well, M. and I went first. Do you want to 
4 
know about the instance with la? 
MR. NIERMELSIEIN: That's what he asked 
6 
you. 
7 
MR. LUTTIER: Yeah. 
8 
THE WITNESS: Okay. The time frame? 
9 
BY MR. LUTT/ER: 
10 
Q. Yeah. 
11 
A. It was sophomore year. I was with IN and 
12 
M. and they wanted to go to the house, and I was in 
13 
the car with them. 
14 
Q. Okay. How, how were you able to identify 
15 
it was your sophomore year? 
16 
A. Because when I went, it was when my father 
17 
lived in Rinks Forest, and ! lived in Binks Forest for 
18 
my freshman and my sophomore year. 
19 
Q. Do you have any record which reflects when 
20 
you went to Mr. Epstein's house? 
21. 
A. No. 
22 
Q. Do you know of the existence of any notes 
23 
that you kept or calendars or anything like that 
24 
where you recorded the information? 
25 
A. No. 
Page 181 
1 
sure there's little things that I don't 
2 
remember, but I remember the majority of what 
3 
hwertd 
4 
BY MR. LU'rITER: 
5 
Q. Well, you, you remember I asked you about 
6 
Dr. l= 
earlier? 
7 
.nes. 
8 
Q. You told me you told Dr. 
the truth? 
9 
A. Yes. 
10 
Q.. Whatever you told Dr. 
was the truth 
11 
when you said it? 
12 
A. Yes. 
13 
Q. You told Dr. 
yourself that you 
't
14 
couldn remember a 
of specifics about your 
15 
visits with Dr. — I mean, with Mr. Epstein, didn't 
16 
you? 
17 
MR. MERMELSTEIN: Form. 
18 
THE WITNESS: Which hand he used and 
19 
things like that; I don't seliamber specifics 
20 
like that. 
21 
BY MR. LUTTIER: 
22 
Q. Do you remember telling Dr. ME tir. 
23 
your recollection about what hap 
was? clea; 
24 
MR. MERMELSTEIN: Form. 
. 
2 5 
THE WITNESS: Did he say it in a different 
• 
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Page 182 
way, or did he say it just like you're saying 
it? 
BY MR. LIJITIER: 
Q. I'm, Pm just-- myation to you is: 
Do you recall telling Dr. 
that your 
recollection about events that occurred when you 
were at Dr. — I mean, Mr. Epstein's, wasn't clear? 
MR. MERMELSTEIN: Font. 
THE WITNESS: I don't remember telling him 
that but, !mean, I might have. 
BY MR. LUITIER: 
Q. Do you remember telling him that you 
couldn't remember certain things about what 
happened? 
A. Well, yeah. There's certain, like I just 
said there are certain things that I probably don't 
remember, but I remember the majority of it. 
Q. But there were significant things about 
your visits with Mr. Epstein that you couldn't 
recall; isn't that right? 
MR. MERMELSTEIN: Form, lack of 
foundation. 
THE WITNESS: But as in what? Like, you 
mean —
Page 184 
1 
these are your words, "what hand he used". 
2 
A. I mean, if I don't remember, I don't know how 
3 
Pm supposed to tell you. 
4 
Q. Well, for example, you would admit that 
5 
you don't really recall specifically what clothes, 
6 
that is, which items of clothes you had on at the 
7 
time that you were at Mr. Epstein's, do you? 
8 
A. I don't remember exactly what I was wearing, 
9 
no. 
10 
Q. Well, you don't remember if you had, for 
11 
example, your bra on or you didn't have your bra on, 
12 
do you? 
13 
A. I took my bra off. 
14 
MR. MERMELSTEIN: Form. 
15 
BY MR. LUTHER: 
16 
Q. Do you remember telling Dr. 
that 
17 
you weren't sure whether you had your bra on or off? 
18 
A. Yes, and I remembered. 
19 
Q. So, you told Dr. 
20 
A. Yes. 
21 
Q. — a year ago when you saw him, right? 
22 
A. Yes. Was it a year? 
23 
Q. A year ago. Whenever it was. 
24 
A. Okay. 
25 
Q. Whenever that — okay. And you told him 
Page 163 
1 
BY MR. LUTTIER: 
2 
Q. Well, is there anything, anything that you 
3 
would consider to be a significant part of your 
4 
visits with Mr. Epstein that you admit you cannot 
5 
specifically recall? 
6 
A. In any way? 
7 
Q. In any way. 
8 
A. Yes. 
9 
Q. Okay. What significant events that would 
10 
have occurred when you visited Mr. Epstein do you 
11 
acknowledge that you do not have a specific 
12 
recollection about? 
13 
A. As in, like, which hand he used, I don't 
14 
remember. 
15 
Q. So you don't know what hand he used. 
16 
Anything else that you can — that you admit you 
17 
don't have a specific recollection about? 
18 . 
A. You've got to give me a second. 
19 
I mean, exactly, you know, what was 
20 
on the walls, things like that, exactly what the 
21 
house looked liked. 
22 
Q. !want you to tell me things that you say 
23 
as you sit here today you acknowledge you don't have 
24 
a specific recollection about with respect to your 
25 
visits with Mr. Epstein. So far you've told me, and 
Page 185 
1 
the truth then, right? 
2 
A. Yes. 
3 
Q. So if you told Dr. 
a year ago that 
4 
you don't recall if you had your bra on or not, that 
5 
was a true statement when you made it to him. 
6 
MR. MERMELSTEIN: Form, lack of 
7 
foundation. 
8 
BY MR. LUTHER: 
9 
Q. Is that right? 
10 
A. Yes. 
11 
Q. All right. Are you now telling us that a 
12 
year later you now have a specific recollection? 
13 
A. Yes. 
14 
MR. MERMELSTEIN: Form, lack of 
15 
foundation. 
16 
BY MR. LUTHER: 
17 
Q. And is there something that clarified your 
18 
recollectionteen the last time you saw 
19 
Dr. Lim — 
which I believe was in '09, and 
20 
now? 
21 
A. !just thought about it. Things come back to 
22 
me. 
23 
Q. So six years later, what you couldn't 
24 
recall five years ago, or what you couldn't recall 
1:appened, five yeas previousl1,
s
 you noN. can 
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recall? 
2 
MR. MERMELSTEIN: Form, lack of 
3 
foundation. 
4 
THE WITNESS: Yes. 
5 
BY MR. LU'TTIER: 
6 
Q. And is there anything that refreshed your 
7 
memory? 
8 
MR. MERMELSTEIN: Form, lack of 
9 
foundation. 
10 
THE WITNESS: It could have been that 
I 
11 
mean, I don't remember if I didn't remember 
12 
when I didn't tell him or if I was embarrassed 
13 
because I didn't tell him. I don't remember 
14 
exactly why I didn't tell him or it just 
15 
didn't, you know, hit me when I was talking 
16 
about it. 
17 
BY MR. LUMER: 
18 
Q. well, you, you, you told DE 
the 
19 
whole truth. That's what you told me, right? 
20 
A. Yes. 
21 
Q
111ere was all kinds of sluff you told 
22 
Dr. 
that you would ordinarily fmd to be 
23 
enibarrassing, wasn't there? 
24 
A. Yes, 
25 
Q. You told him about the most intimate 
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17. 
18 
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25 
Q. Going over your case with whom? 
A. My attorneys. 
Q. Okay. So, your — 
MR MERMELSTEIN: And, of course, you kno 
not to talk about what you discussed with your 
attorneys. 
BY MR. LUTI1ER: 
Q. So, the refreshing of your memory comes as 
a result of communications with your lawyer? 
MR. MERMELSTEIN: Objection to form. Do 
not testify. Don't answer that question 
because it —
BY MR. LIMIER: 
Q. Did you tallc — 
MR. to 
is 
— requires 
attorney-client privileged conununications. 
BY MR. LUTI1ER: 
Q. Have you talked to any of your girlfriends 
that went to see Mr. Epstein since you went to 
Dr. 
A Since I went to Dr. a 
Q. Yep. 
A. About the - about what happened at Epstein's 
house? 
Q. 
Page 187 
1 
details about your life, did you not? 
2 
A. Yes. 
3 
Q. So you didn't not tell Dr. 
4 
something because you were embarrassed, did you? 
5 
A. There was embarrassing things that, you know, 
6 
that went through my mind and stuff, and I mean, I told . 
7 
him a lot, yeah. 
8 
Q. Now, my question is specific. There is 
9 
nothing that you did not tell Dr. 
when you 
10 
met with him because you were embarrassed to tell 
11 
him, was there? 
12 
MR. MERMELSTEIN: Form. 
13 
113E WITNESS: No. 
14 
BY MR. LUTHER: 
15 
Q. Rephrase the question. Was there anything 
16 
that you did not tell Dr. =, 
when you met with 
17 
him, because you were embarrassed to tell him about 
18 
it? 
19 
A. No. 
20 
Q. Okay. &l een done anything since you 
21 
met with Dr. 
to refresh your recollection 
22 
about events that occurred when you were with 
23 
Mr. Epstein? 
24 
A. Just going over my case and thinking about 
25 
what I did. 
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Page 189 
A. Not that I recall. 
Q. Did you for ever have any conversations 
with MI, for example, where you said, you know, 
wont, words to the effect of, you know, do you 
remember what happened and sort of discuss it or 
compare notes about it? 
A. I mean, we, we've talked about his house, but 
we didn't, like, discuss notes about it. 
Q. I mean, when you talked about what 
occurred when you were at his house, did you ever, 
from the, from the day you went to Mr. Epstein's 
until today, ever have a discussion with M. about 
what occurred when you and she were OW. Epstein's 
house? 
A. To since the day we went to his house? 
Q. Absolutely. 
A. Yes. 
Q. Okay. When was the first time you 
discussed it? 
A. Probably right after we left. 
Q. Well, you say "probably." Does that mean 
you're not sure? 
A. Most liltely right after we left. 
Q. Okay. Do you have a specific recollection 
of the conversation? 
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Page 190 
1 
A. Just that we can't believe what just happened 
2 
to us. 
3 
Q. No. Let me — I want do this in, in 
4 
steps. Do you have a specific recollection of your 
5 
conversation with M.? 
6 
A. Parts of it, yes. 
7 
Q. Okay. Are there parts of it you don't 
8 
have a specific recollection about? 
9 
A. Yes. 
10 
Q. All right. So then you acknowledge there 
11 
were some things that you don't remember about your, 
12 
the events that transpired at Mr. Epstein's; is that 
13 
correct? 
14 
MR. MERMELSTEIN: Objection. You're prior 
15 
question was just about her conversation. 
16 
MR. LUTHER: Okay. Wait a minute. 
17 
Don't, don't speak. 
18 
BY MR. LUTTIER: 
19 
Q. We'll take it in two steps. There are, 
20 
there are sub-portions of the conversations you had 
21 
with ■. immediately after going to Mr. Epstein's 
22 
house with her that you don't recall; is that 
23 
correct? 
24 
A. As of right now, yes. 
25 
Q. All right. Would you agree with me 
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Page 192 
part of the year? 
A. Yes. 
Q. Year starts — your sophomore year would 
have started in approximately August of'02? 
A. Yes. 
'03?
A. It ended? 
Q. Yeah. 
A. Yes. 
Q. Okay. So your bea recollection is you 
first heard of Mr. Epstein's name sometime between 
August of'02 and October of'02. You said it was 
the beginning of the year. 
A. Yeah. I mean, yeah 
Q. Let
 make:An:1TM clear. I'm not 
trying to put a date in your memory. 
When you said -- we've identified 
that your sophomore year started in August of'02 
and ended in June of '03, right? 
A. Yes. 
Q. Okay. So when you said you first heard of 
Epstein's name in the beginning of your sophomore 
year — 
A Yes. 
And it concluded in approximately June of 
Page 191 
1 
there's also events that occurred when you and M. 
2 
went to see Mr. Epstein that you don't recall? 
3 
MR. MERMELSTEIN: Form, overbroad. 
4 
THE WITNESS: Today? 
5 
BY MR. LUTHER: 
6 
Q. Yes. 
7 
A. Yes. 
8 
Q. All right. All right. So what's your 
9 
best recollection of your discussion with ■. when 
10 
you and she went to Mr. Epstein's? 
11 
A. The story of what happened? 
12 
Q. Well, if you want us to — let's just 
13 
start — let me, let me back it up. 
14 
There came a point in time that you 
15 
heard something about somebody named Mr. Epstein; is 
16 
that right? 
17 
A. Correct. 
18 
Q. When did you full hear of Mr. Epstein? 
19 
A. It was in high school. 
20 
Q. When in high school? 
21 
A. I'm going to say my sophomore year. 
22 
Q. Okay. When in your sophomore year? 
23 
A. I'm approximating because I don't know the 
24 
exact date, but probably in the beginning. 
25 
Q. Okay. "Beginning" meaning in the first 
Page 193 
1 
Q. -- that would be sometime after August of 
2 
'02? 
3 
A. Yes. 
4 
Q. And when you said the beginning, what do 
5 
you mean, August, September, October, or... 
6 
A. I don't know which month. It was in the 
7 
beginning of the school year. 
8 
Q. Within the first couple months? 
9 
A. Probably. 
10 
Q. So August or September would be a fair 
11 
estimate? 
12 
A. Yes, I mean, I had, yes. 
13 
Q. Okay. So August or September of'02, what 
14 
is it you first hear about Mr. Epstein? 
15 
A. I don't know exactly what I heard. I just 
16 
heard something about, if you go to this man, Jeffrey 
17 
Epstein's house, and you give him a body massage, you 
18 
get $200. 
19 
Q. And in this first occasion that you heard 
20 
about it, was — did Mr. Epstein's name come up, or 
21 
were you just told, if you go to somebody's house 
22 
someplace you can get some money? 
23 
A. It was probably somebody's place; it wasn't 
24 
his specific name probably. 
25 
Q. Before you first went to Mr. Epstein's 
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Page 194 
1 
house for the first time, did you know his name? 
2 
A. Before -- yes, before I went to his house. 
3 
Q. So, at some point before you went there 
4 
for the first time, you knew that you were going to 
5 
go see somebody named Jeffrey Epstein. 
6 
A. Correct. 
7 
Q. Do you recall when it was you first heard 
a 
his name? 
9 
A. No, l don't recall that. 
10 
Q. Do you know it if you heard his name in 
11 
the first conversation about making some money doing 
12 
a massage, or was it in a later conversation? Do 
13 
you understand my question? 
14 
A. I understand your question. I just —
15 
Q. In other words, were you, did you 
16 
initially just hear, you know, nunor, for lack of a 
17 
better -- that you could go give somebody a massage 
18 
for $200, or was it you go give Mr. Epstein a 
19 
massage for $200? 
20 
A. I think it was somebody a massage. 
21 
Q. Okay. And, and did you understand where 
22 
it was going to be, what town? 
23 
A. No, I didn't have all the specifics on it. 
24 
Q. So, so your best recollection today is 
25 
sometime in August, September, October of '02, 
Page 196 
1 
or not —
2 
A. Yes, l am. 
3 
Q. Just, if you're, if you're just 
4 
speculating and guessing, just, just — it would be 
5 
better to tell me you don't know. 
6 
A. Okay. 
7 
Q. All right. But if you, if you have a 
8 
specific recollection, tell me. 
9 
A. Okay. 
10 
Q. But if it's — if you just don't recall, 
11 
there's nothing wrong with just saying you don't 
12 
recall. 
13 
A. Okay. 
14 
Q. All right. So I want to be fair to you. 
15 
I don't want you to speculate. 
16 
A. Okay. 
17 
Q. What happened — what did you do after you 
18 
heard this conversation for the first time? 
19 
A. I believe I mentioned it to 
21 
Q. And what did you tell 
21 
A. That I was interested in going there, but I 
22 
warned her to come with me. 
23 
Q. Well, had 
when — do you recall 
24 
whether or not, 
you first mentioned it to., 
25 
5 
had heard anything about it? 
Page 195 
1 
somebody told you that you could give somebody a 
2 
massage and get $200. 
3 
A. Yes. 
4 
Q. Is there anything more you can recall 
5 
about the first time you became aware of anything 
6 
that was related to Mr. Epstein? 
7 
A. With that conversation, with somebody telling 
me about —
Q. Yeah, was that the first time you heard 
anything about any of it? 
A. Yes. 
Q. Okay. Anything else you can recall about 
the conversation? 
A. No. 
Q. Do you know who told you this? 
A. No. 
Q. Was it while you were at school that you 
heard this? 
A. Yes. 
Q. Okay. Do you know if the person that told 
you was someone that had done that? 
A. Most likely. 
Q. But you can't tell me? 
A. I don't know who it was, though. 
Q. So you're, you're sort of guessing whether 
Page 197 
1 
A. I don't recall. 
2 
Q. When did you form the opinion that you 
3 
wanted to follow up on this manor that you had 
4 
beard? 
5 
A. I don't {MOW who told me, but the person that 
6 
did tell me made it seem like it was just, you go there, 
7 
you give him a massage, you get $200. And to me $200,1 
8 
was hike, yeah, why not. 
9 
Q. And do you blow how long it was from the 
10 
time you first heard it that you approached • 
11 
about doing it? 
12 
A. I don't recall. I don't know. 
13 
Q. Okay. So you were — you — did you 
14 
approach anybody other than 5? 
15 
A. No. 
16 
Q. So you go to 5. and you tell her, I 
17 
heard this story that 1, we can go make $200 giving 
18 
somebody a massage? 
19 
A. Yes. 
21 
Q. Did you tell her anything more at that 
21 
time? 
22 
A. 
23 
Q. 
24 
A. 
25 
Q. 
That's all -- 
Did you know where it was going to be? 
No. 
Did you know it was going to be in Palm 
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1 
Beach? 
2 
A. No. I don't even know how 1 found out it was 
3 
in Palm Beach. It was — the person that told me about 
4 
it, I don't, I don't recall exactly what hmp_ened. But 
5 
somehow when I decided to go there, M, 
6 
Jeffrey Epstein's assistant, contacted me and was the 
7 
one that set up the reservations. 
8 
And after this, can I take, lb 
9 
sony, another break to use the restroom? 
10 
MR. LUTTIER: Sure. We might as well just 
11 
take a lunch break. 
12 
MR. MERMELSTEIN: Yeah. 
13 
THE VIDEOGRAPHER: Going off the record at 
14 
12:24 M. 
15 
(A luncheon recess was held.) 
16 
• • • • * 
17 
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19 
20 
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22 
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Page 199 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
VOLUME II OF II 
Related cases: 
08-80232, 08-08380, 08-80381, 08-80994, 
08-80993, 08-80811, 08-80893, 09-80469, 
09-80591, 09-80656, 09-80802, 09-81092 
VIDEOTAPED DEPOSITION OF 
JANE DOE NO. 5 
Friday, February 26, 2010 
8:07 - 3:44 
250 Australian Avenue 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting Services 
Job No.: 1312 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Cynthia hopkins (S01-061-976-2934) 
Electronically signed by cynthia hopkins (601.061-976-2934) 
Electronically signed by cynthia hopkins (601.051.976-2934) 
1a30246a-bc9d-4107.90a14373e816de0d 
EFTA01076435

EFTA01076436

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Page 200 
APPEARANCE& 
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On behalf of the PlaintifE 
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STUART S. MERMELSTE1N, ESIIRE 
MIRINELSTEIN & HOROWITZ, 
18205 Biscayne Boulevard 
Suite 2218 
Marna, Ibrida 331 
Phone: 
E-mail: 
On be,haif o 
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ROBERT D. CRII7ON, IR, ESQUIRE 
MARK T. LUTTLER. ESQUIRE 
9 
BURMAN, CR111014, LUTT1ER & COLEMAN,UP 
303 Banyan Boulevard 
Suite 400 
West Pallainda
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33401 
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Phone: 
ALSO PRESENT: 
Sasdra Quimby, Vicieographer 
Visual Evidence, Incorporated 
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CONTINUED PROCEEDIN 
Page 202 
GS 
 / 
THE VIDEOGRAPHER: We're back on the 
record at I:38 
BY MR. LUTTI
Q. Okay. I want to go back over one of the 
issues that you mentioned and ask you a little bit 
more about it. 
Can you tell me where you were physically 
when you first heard about the opportunity to give a 
person a massage for the $200? 
A. I was in school. 
Q. Okay. Do you know— and you said you 
don't know who it is that told you. Do, do you know 
what your relationship with the person was that told 
you about this opportunity? 
A. I don't remember who the person was, so I 
don't recall if they were a friend of mine or we were in 
a group of people and somebody mentioned it I don't 
recall exactly what happened. 
Q. Do you know where you were at school when 
this conversation occurred? 
A. No. 
Q. Was there anyone else present when this 
unnamed person told you of this opportunity? 
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Page 201 
INDEX 
EXAMINATION 
DIRECT CROSS REDIRECT 
CONTINUED EXAMINATION OF 
JANE DOE NO. 5 
BY MR. CRITTON 200 
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NO EXHIBITS MARKED 
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Page 203 
A. Not that I remember. It could have been a 
group of people that were — you know, they mentioned 
it, or it could have been, you know, just one person. 
Q. Well, do you recall, when you first beard 
the nosy from this person, other people around and 
saying anything about it? 
A. No. 
Q. Do you recall if this person was 
addressing you alone or anybody else when the 
statements were made? 
A. I don't recall if — I don't recall, like, 
what happened exactly when they were telling me about 
it 
Q. What, what can you recall about the 
entirety of the conversation with this unnamed 
person? 
A. I just remember them telling me -- or it 
was — I don't — see, I don't remember the specifics, 
but I remember, you know, they said, you go to this 
guy's house, give him a massage for $200. 
Q. Did you — how did you respond to that 
statement? 
A. I thought about it. 
Q. So you didn't orally respond to the 
statement? 
2 (Pages 200 to 203 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (801-051-976-2934) 
Electronically signed by cynthia hopkins (601-051.976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
1 a30246a-bc9d-4107-90a1-6373e816de0d 
EFTA01076437

Page 204 
A. Not that I recall. 
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Q. You don't recall malting any statement at 
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all after that? 
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A. I don't recall that. 
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Q. What's the next thing that occurred when 
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you and this person were having this conversation? 
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A. I don't recall. I don't know. 
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Q. And do I understand your testimony to be 
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that you're not sure that these were the words that 
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were actually spoken? 
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A. I know those were the wants that were actually 
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spoken. That's all I knew of it, that it was a massage 
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for $200. 
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Q. So you have a specific recollection 
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somebody, who you don't recall, said to you at 
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school --
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A. 1Uh-huh, yes. 
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Q. — although you don't know if there was 
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anyone else present, that you could go to a person 
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and give him a massage and get $200. 
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A. Yes. 
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Q. Is there anything more you can recall 
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about the conversation? 
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A. No. 
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Q. Was there any name used? 
Page 206 
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the person, right? 
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A. I don't recall If I did. 
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Q. Okay. You —well, you didn't give this 
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person your phone number, did you? 
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A. The person I was speaking to? 
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Q. Right. 
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A. It could have been a friend of mine. I don't 
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remember the person specifically. I don't know if I 
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went back to that specific person and said I was 
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interested, you know, here's my number. I don't, I 
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don't know. 
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Q. What's the vety next thing you can recall 
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about your going to Mr. Epstein's after this 
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conversation with this unnamed person? 
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A. So you're asking what did 1— what was my 
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next step that I remember after this person told me 
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about — 
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Q. The very »eott — yeah, the very next thing 
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that you did that had anything to do with —
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A. Even if it was days later? 
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Q. Whenever it was, ,..
kgituse that's going — 
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A. I remember I toldM. about it. 
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Q. Okay. That's the next thing that 
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happened? Nothing happened between this ag amed 1 
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person telling you of this and you talking toM.? 
Page 205 
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A. As in Jeffrey Epstein's name? 
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Q. Any name. 
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A. I don't recall. 
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Q. Do you recall — I mean, when you say you 
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don't recall, does that mean the name could have 
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been said, or you don't believe that a name was 
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said? 
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A. It could have been said. I don't remember. 
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Q. Did you, did you ask any questions in 
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response to this statement from this person? 
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A. I don't remember if I did. 
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Q. Was there any additional information given 
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to you by this person other than that there was an 
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opportunity to go to a person's house and give the 
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persona massage for $200? 
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MR.. MERMELSTEIN: Objection, asked and 16 
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answered. 
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THE WITNESS: All! recall is that this 
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person told me it was a $200 mmotss age. And 
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2. 
somehow, I don't remember, IIM contacted us 
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and made ttte — for us to go to his house and 
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do the massage. 
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BY MR. LIMIER: 
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Q. Okay. So, so now this person that said 
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 these thin" fl
i
ous
_anz e.sySteneecicto
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'I ' 
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.... 
Page 207 
A. I don't 
'litany, but I thinkI 
probably talkedreta
e.cfirst before I decided to do the 
massage for $200. 
Q. Okay. And you talked to
 because she 
was your best friend at the time? 
A. Yes, we were close. 
Q. Any other reason why you, out of — 
THE VIDEOORAPHER: Excuse me, sir, which 
button did you push? I just got a text that 
this has been muted. 
MR. MERMELSTEIN: Oh great. 
THE VIDEOGRAPHER: Okay. I just got a 
text from my boss saying it's been muted. 
(Discussion off the record.) 
THE VIDEOGRAPHER: Let muga ahead and 
stop it. Going off the record at 3:45... 
Oh, Pm sorry, 1:45. 
(A brief recess was held.) 
THE VIDEIIRAPHER: We're back on the 
record at 1:50 
MR. LUMER: All right. What was the 
last question? 
(The requested portion of the record was 
read by the reporter.) 
j 
3 (Pages 204 to 207 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Cynthia hopkins (601-051.976.2934) 
Electronically signed by Cynthia hopkins (601.051.976-2934) 
Electronically signed by Cynthia hopkins (601-051.976.2934) 
la30246a-bc9d-4107-90a1-6373e816de0d 
EFTA01076438

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Page 208 
BY MR. LUTHER: 
Q. And I apologize if I asked this, because I 
lost my train of thought: How long was it between 
the time you first heard this and you talked to 
A. I said I didn't recall how long it was. It 
could have been a couple of days. I, I don't remember. 
Q. Could it have been weeks? 
A. It could have been. I don't remember 
specifically. 
Q. Did it take you this period of time before 
you &alai. to decide whether or not you were going 
to do this? 
A. I'm sorry. What did you say? 
Q. Did it take you that period of time 
between when you first heard it and talked tea. 
to make up your mind whether or not you wanted to do 
this? 
A. Yeah. 
Q. So, you had given this conscious thought? 
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A. I gave it a thought of, it was a massage for 
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$200. I was young, naive, and it was $200 in my pocket 
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fora massage. 
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Q. Had you ever given anybody a massage ever 
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in your life up to that point in time? 
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Page 210 
it, but —
Q. Okay. What is it that you recall that 
causes you to say that you know it was along those 
lines? 
A. What is it that I recall? Because I know she 
questioned it when I made that statement. She was 
curious about the situation. 
Q. And, and what did you tell her in 
response? 
A. I said, yeah, that's what I was told. 
Q. And did you tell her who had told you 
that? 
A. I don't remember. 
Q. Okay. 
A. !just, I mean, there's... 
Q. After the first time this unnamed person 
told you about this opportunity, did you ever have a 
conversation with that unnamed person again about 
it? 
A. Like I said weviously, I don't recall if I 
did, but someho 
got my number, so I'm guessing I 
might have went back to the same person that told me and 
said, yeah, I would like to do it and they probably gave 
them my number. I don't know. Honestly, I have -- I 
don't really remember. 
Page 209 
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A. With — you know, with my friends and stuff, 
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like but it wasn't, l wasn't a masseuse. 
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Q. Did you know anything about how much a 
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massage cost? 
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A. No. 
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Q. Did you ask anybody? 
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A. No. 
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Q. Did you ever make any inquiry about 
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anybody receiving $200, you know, the going rate, 
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for example, anything like that? 
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A. No, it sounded good. 
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Q. Okay. So, when you toldM., what was 
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her fast statement to you? 
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A. You've got to give roe a second. 
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I'm not 100 percent positive, but I think 
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it was something along the lines as of all we have 
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to do is give a massage for 200. That's it. 
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Q. That's, that's Alas.,. said to you? 
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A. Yes. 
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Q. Was it a statement or a question? 
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A. It was question. Like, you know, from what 
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I've heard, I was like, yeah. 
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Q. Okay. 
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A. And I don't know if it was exactly that, but I 
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know it was al 
the lines of ou blow 
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Page 211 
Q. Well, you have no recollection at all 
about that; is that right? 
A. Yes, I flies)... 
Q. So you, you — this isn't a situation 
where you have -- you, you recall doing that, but 
you can't remember the exact words. You don't 
really have a recollection about whether you did 
that or not? 
A. As in what? Like, Ala? 
Q. That you went back to this person and 
said — 
A. Yeah, I don't know. I ;mow that 
contacted me. I don't know how. 
Q. Well, let me get over there. Did you 
have — do you have a specific recollection of 
giving your phone number to anybody with respect to 
this opportunity? 
A. I don't 
Q. All right. Did you, did — were you the 
person that took the next step insissing this 
series of events to occur, or didM. do something? 
A. I'm pretty sure I did it. 
Q. Okay. Now, isn't it afitgifiat you were 
the one that callginthis lady, =II? 
A. I called =? 
4 (Pages 208 to 211) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthla napkins (001.051-976.2934) 
Electronically signed by cynthia hopkins (601.051.976.2934) 
Electronically signed by cynthia hopkins (601-051-976.2934) 
la30246a-bc9d-4107-90a1-6373e816de0d 
EFTA01076439

Page 212 
Q. Yeah. 
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A. I don't recall calling. I know I called to 
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get directions, stuff like that, but... 
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Q. My, my question — have you ever told 
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anybody that you were the one that called -t
o 
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set up the, the massage? 
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MR. MERMELSIEIN: Form 
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THE WITNESS: No. 
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BY MR. LUTTIER: 
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Q. If you told someone that in the past, 
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would it have been accurate when you told them that? 
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MERMELSTEIN: Objection to form. 
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THE WITNESS: No. 
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BY MR. LUMER: 
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Q. In other words, you wouldn't have just 
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made it up, right? 
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MR. MERMELSTEIN: Objection to form, 
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foundation. 
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BY MR. LUTTIER: 
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Q. Would, would you have just made. 
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statement to the effect that you contacted 
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MR. MERMELSTEIN: Objection to onn. 
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THE WITNESS: No. 
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BY MR. LUTHER: 
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Q All right. Did you ever tell anyone that 
Page 214 
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A. I'm not 
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met with Dr. 
ou told him the absolute truth 
Q. Specifica*ou told me that when you 
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4 
about everything; isn that right? 
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A. Yes. 
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You told me that when you met with 
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Dr. 
ou told him the absolute truth about 
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ng. 
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A. Yes. 
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. So if you made a statement to either 
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Dr. 
or Dr. allg ait was a true statement that 
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you 
to him; is 
right? 
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A. Yes. 
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Q. So, if you told Dr. 
a Dr. 
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that you and/or 1. call 
that=fime 
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you made the sta ement to them, i was true? 
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MR. MERMELSTEIN: FORD. 
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THE WITNESS: I didn't say that. 
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BY MR. LUTITER: 
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Q. Well, that's not my question. You, you 
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admit that if you made that statement to either 
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Dr. Moe Dr. a 
it was true when you made 
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the statement? 
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MR. MERMELSTEIN: Fonn. 
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THE WITNESS: If I made a statement to 
Page 213 
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it was either you or 
but one of the two of 
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you, that contacted 
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MR. MERMELSTEIN: Form. 
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THE WITNESS: I don't recall that 
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BY MR. LUTHER: 
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Q. If you did tell someone that in the past, 
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was it true when you made the statement? 
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MR. MERMELSTEIN: Font. 
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THE WITNESS: Say that one more time. 
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BY MR. LUMER: 
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Q.' If you did tell someone that in the past, 
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was it true when you made the statement to them? 
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MR. MERMELSTEIN: Form. 
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THE WITNESS: No, because I didn't. I 
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don't do that. 
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BY MR. LUTHER: 
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Q. Well, you would, you — if you made that 
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statement, you believed at the time you made the 
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statement that it was a true statement, did you not? 
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MR. MERMELSTEIN: Form. 
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IRE WITNESS: You're confusing me. I'm 
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confused. 
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BY MR. LUITlER: 
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Q. Well, I want to make sure you're clear 
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about this. 
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Page 215 
them? 
BY MR. LUTHER: 
Q. Yep. 
A. Yes, it would be true. 
Q. Okay. Now, you just said you didn't tell 
either one of those individuals that. How do you 
know that? 
A. Because I don't recall. All I recall is that 
she called me somehow. So why would I say that —
Q. 
fact — 
A. — that I called them? 
Q. — of the matter is that you really don't 
know whether or not ou made that statement to 
gi 
Dr. 
or Dr. 
you're just guessing that 
you 
make the 
ement, aren't you?
MR. MERMELSTEIN: Form. Your question 
calls for her to guess. 
THE WITNESS: I know I, I wouldn't make 
that statement berange Pm telling you what 1 
feel, end what I feel is from what I remember, 
is I didn't call 
BY MR. L
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Q. Would it be son of to cut to the 
chase, would it be a fair statement to say you 
really don't recall who called who? 
PROSE COURT REPORTING AGENCY 
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INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601.051.976.2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
1030246a-bad-4107-90a1-8373e816610d 
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Page 216 
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MR. MERMELSTEIN: Form. 
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THE WITNESS: I knovI know that I didn't 
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call her first. I didn't call arst. 
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BY MR. LUTHER: 
5 
Q. Well, if you, if you don't — what Pm 
6 
trying to find out is, is whether you have a 
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specific recollection or you're just concluding what 
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happened based upon your recollection of other 
events. Do you know what Pm saying? 
MR. MERMELSTEIN: Form. 
BY MR. LUTTIER: 
Q. In other words, you either know for a 
fact, you have a specific recollection of who called 
who, or you don't have a recollection, but you're, 
you're assuming that they called you, or whatever, 
from a different set of facts. 
A. No, l know they called me. 
Q. Okay. So if you know that they called 
yousa would you tell either Dr. 
or 
Dr. 
that you iliodrEgla
lled 
ME
MR. 
: Form, lack of 
foundation. 
MR. LUTHER: If you did. 
THE WITNESS: But I didn't. 
1 
that conversation? 
2 
A. From what I remember, it was when I can go to 
3 
the house to do the massage and how to get there. 
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Q. Well, wait a minute. I'm going to go take 
5 
this in steps. Do you, as you sit here today, have 
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a specific recollection of the conversation? 
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A. Yes, it was along those lines. 
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Q. No, I want to know. Can you tell me what 
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was said to you by this person on the other end of 
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the phone? 
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A. I can't tell you every little detail. 
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Q. Can you tell me what you said to this 
3 
person on the other end of the phone? 
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A. No. 
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Q. I want to know what -- when, when you 
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first got this phone call that you claim you got, 
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where were you? 
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A. I was probably at home. That's not --
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Q. And I don't want to know probably. Are 
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you saying you don't know? 
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A. I don't know. 
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Q. Okay. Fair enough. Do you remember how 
23 
long it was between the time you first heard of this 
24 
opportunity and when you allegedly got this call? 
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A. I don't blow. 
Page 218 1 
Page 217 
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BY MR. LUTT1ER: 
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Q. Okay. Well, let's just assume for the 
3 
purpose of this question that you made that 
4 
statement Tell me why that would ever be possible 
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for ou to have to have made a statement to either 
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Dr. 
or Dr. 
that you or. 
called 
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MR. MERMELSTEIN: Form, lack of 
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foundation 
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THE WITNESS: I don't, I don't — I'm, Pm 
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getting confused because you're asking me a 
12 
question which I don't — I didn't make a 
13 
statement about that, so how can I answer that? 
14 
BY MR. LUTTIER: 
15 
Q. Okay. Now, do you have a specific 
16 
recollection of a phone conversation that you 
17 
personally had with this person you say is M? 
19 
Q. 'ever you say im is. 
18 
A. 
Epstein's assistant? 
20 
A. 
I
.
,
 
Epstein's assistant, that got the girls 
21 
to come there? 
22 
Q. I don't know who it is. You said there 
23 
was somebody named 
that called you. 
24 
A. Yeah, there's a 
25 ' 
9.  Do you have a spec] c recollection of 
Page 219 
1 
Q. Do you remember on what phone you received 
2 
this alleged call? 
3 
A. It was most likely my cellphone. 
4 
Q. Doyou know specifically? 
5 
A Yes, because I wouldn't give them my house 
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phone. 
7 
Q. Why not? 
8 
A. Because my cellphone is on me at all times end 
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I was never home. 
10 
Q. Are you, are you certain — are you 
11 
guessing that you didn't give your home phone 
12 
because you carry your cellphone, or do you know for 
13 
a fact? 
14 
A. Well, l know fora fact that's what 
the 
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phone I use all the time. 
16 
Q. And what— how did this person that 
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called, how did they introduce themselves to you? 
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A. She said her name, hello, I'm =. 
I work 
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for Jeffrey Epstein. And then I In: rdru were 
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interested in the massage, and it went along those 
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lines. I don't know the exact conversation. This 
22 
was — you know, it was a while ago for the phone call. 
23 
Q. Six, seven years ago? 
24 
A. Yes. 
25 
Q. And did this eaytIleir 
name was 
PROSE COURT REPORTING 
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AGENCY; INC. 
Electronically signed by cynthia hopkins (601-061.976-2934) 
Electronically signed by cynthia hopkins (601.061.976-2934) 
Electronically signed by cynthia hopkins (601-061.976.2934) 
1O024O-bc9d-4107-90a1-6373a 6dOd 
EFTA01076441

Page 220 
1 
a 
or did they tell you their full name? 
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A. 1 don't remember. 
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Q. And arc you sure they said they worked for 
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Jeffrey Epstein? 
5 
A. Pretty sure. 
6 
Q. Was that the first time you ever heard his 
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name? 
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A. I don't recall. 
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Q. Did you say anything to him (sic) like 
10 
who's Jeffrey Epstein? 
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MR. MERMELSTEIN: Form. 
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THE WITNESS: No, I don't — 
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BY MR. LUTHER: 
14 
Q. Have you ever in your life received a, 
15 
just a call out of the blue from somebody saying, 
16 
gee, would you like to come over and give me a 
17 
massage or give somebody a massage? 
18 
MR. MERMELSTEIN: Form. 
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THE WITNESS: No. 
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BY MR. LUTHER: 
21 
Q. So it was an unusual phone call? 
22 
A. No, because I discussed this with somebody 
23 
previously. 
24 
Q. Well, this was ■, right? 
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A. Well, in high school was when somebody told me 
Page 221 
1 
about the situation. So, like I'm saying, I'm not going 
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to give you facts when I don't know exactly when it was 
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when I spoke to the person, when — I, i can't give you 
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a fact of what happened if I gave, you know, them my 
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number when I don't remember that part. 
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Q. Okay. What did you say to this person in 
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response? 
a 
A. What person? 
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Q. Whoever it is you claim you had a 
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conversation with. 
11 
A. Like I said, l da* remember. 
12 
Q. So you can remember what they said to you, 
13 
but you have no recollection what you said to them; 
14 
is that right? 
15 
A. There's -- no. Mores things you're going to 
16 
ask me that fm going to remember and I'm not going to 
17 
remember. 
18 
Q. Well, let's what I'm going to get that 
19 
point — 
20 
A. Yeah. There's — 
21 
Q. — so that the jury understands. You can 
22 
remember what this person said to you, but you can't 
23 
remember what you said to than; is that right? 
24 
A. Yes. 
25 
l liow long did this conversation take? 
Page 222 
1 
A. Between me and this unknown person? 
2 
Q. Yeah. 
3 
A. I don't know. 
4 
Q. Do you recall what day of the week it was? 
5 
A. It was a school day. 
6 
Q. And how do you know that? 
7 
A. Because I was in school when I heard about it. 
8 
Q. I thought I asked you where you were when 
9 
you got the phone call, and you said you didn't 
10 
recall. 
11 
A. The phone call or when I talked to the unknown 
12 
person? 
13 
Q. No, when you, when you received the phone 
14 
call from this person. 
15 
MR. MERMELSTEIN: Well, you know, yintre 
16 
confusing her because shes already identified 
17 
the person she got the phoneys!l from as 
18 
The unknown person was the person she 
19 
'poke to. 
. 
MR. LUTTIER: No, no. Let me go back. 
21 
BY MR. LUTHER: 
22 
Q. You, you're the one, I believe, that made 
23 
a reference to a phone call from an unknown person. 
24 
The person —
25 
MR. MERMELSTEIN: No, she said a 
Page 223 
1 
consistently. 
2 
BY MR. LUTTIER: 
3 
Q. The person that you talked to that you 
4 
claimed was unknown wasn't a person that you had a 
5 
phone call with, was it? 
6 
A. The person i had a phone call with was 
7 
Q. Right. So the only thing you can possibly
8 
be talking about when you talked about a phone call 
9 
here, was this alleged call with M, right? 
10 
A. Yeah, -was 
—
11 
Q. Didn't you tell me earlier you didn't know 
12 
where you were when you got that phone call? 
13 
A. No, I don't know where I was when I got the 
14 
phone call. 
15 
Q. So you don't know if you were at school or 
16 
not. 
17 
A. No. I — when I talked to the tuilmovm person, 
18 
I was at school. 
19 
Q. Well, I just asked you when you got the 
20 
phone call — 
• 
21 
A. From the unknown person. 
22. 
Q. — and you said it vvas, it was during the 
23 
school week, right? 
24 
A. I must have miss I must have misunderstood 
25 
ou, because you said the nokociuni 
7 (Pages 220 to 223) 
PROSE COURT REPORTING AGENCY 
INC.. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051.976.2934) 
Electronically signed by cynthia hopkins (601-051-976-29341 
la30246a-bc9d-4107-90a1-6373e816doOd 
EFTA01076442