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Page 74 
BY MR. CRITTON: 
Q. And when you went the second time, what was, 
at least what did you tell the police you were there for 
the second time? 
A. I believe they asked me if I brought anybody 
there. And I believe I said I brought one of the. 
Q. 'Mere is two? 
A. Yes. 
Q. 
A. 
Q. Were they both friends of yours? 
A. Yes. 
Q. Good friends or just friends? 
A. Friends. 
Q. Okay. And how about 
watt she a friend or 
a good friend? 
A. A Blend. 
Q. The police asked you if you brow t somebod , 
and you said yes, I brought either 
correct? 
A. Yes. 
Q. And did the police ask you why you brought 
somebody? 
A. Yes. They asked me if I had brought somebody 
Page 76 
1 
A. Somebody that gets paid for sex, I guess. I 
2 
don't know. 
3 
Q. What's the difference between a pimp and a 
4 
prostitute, in your mind? 
5 
A 
A pimp brings somebody to have sex with 
6 
somebody else. 
7 
Q. And get paid, and gets paid for it? 
8 
A. Yes. 
9 
Q. And did you ever consider yourself to be a 
10 
pimp? 
11 
A. No, not at all. 
12 
Q. Did you ever bring - 
13 
A. No, absolutely not. 
14 
Q. Did you ever bring someone to Mr. Epstein's 
15 
house so that they —
16 
A. If I ever would have thought --
17 
MR. HOROWITZ: Wait for the question. 
18 
MR. CRI17ON: Go ahead. 
19 
MR. HOROWITZ: No,there is no question 
20 
pending. 
21 
BY MR. CRITTON: 
22 
Q. Tell me what you think. 
23 
MR. HOROWITZ: About what? 
24 
MR. CRITTON: What you were just going to 
25 
give. Don't interrupt her. 
Page 75 
1 
and got paid for bringing somebody. 
2 
Q. And did you, did you in fact get paid for 
3 
having brought someone? 
4 
A. Yes. 
5 
Q. Okay. And what were you getting paid for? 
o 
A. Bringing somebody there. 
7 
Q. Okay. Did the police ask you if you were 
procuring people for giving a massage? 
9 
A. Can you say that again? 
10 
Q. Soliciting. Were you procuring someone? Were 
11 
you trying to get, hire someone or obtain someone --
12 
A. I wasn't Dying to hire them. I just told 
13 
them about it and then they would go there and I mean --
14 
yeah, so they never said hiring. 
15 
Q. Who is they? 
16 
A. The police never used that term. 
17 
Q. Did the police ever ask you if you knew what a 
18 
pimp was? 
19 
A. No. 
20 
Q. Okay. Did you know back then what a pimp was? 
21 
A. Net really. 
22 
Q. What do you think a pimp is? 
23 
A. I really hope you don't make this connection 
24 
tome, but I know what a pimp is and —
25 
Q. Tell me what you think a pimp is. 
Page 77 
1 
MR. HOROWffZ: There is no question pending. 
2 
MR. CRITTON: I'm asking a question. Don't 
3 
interrupt her when she is answering. Wait a 
4 
minute, let me just finish and then you can give 
your little speech too. 
6 
You haven't had any problem letting her give 
7 
an answer and extending her answer when it has 
8 
nothing to do with anything. Now she is giving an 
9 
answer and you don't like it, so you are chopping 
10 
her off. 
11 
MR. HOROWITZ: No, no, I don't even know what 
12 
she's going to say. 
13 
MR. CRITTON: Exactly, so let her talk. She's 
14 
responding to my question. 
15 
MR. HOROWITZ: No, the way a deposition wales 
16 
is there is questions and answers. Sometimes the 
17 
questions go in different directions, sometimes the 
18 
answers go in different directions, but at no point 
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should somebody be answering something when there 
20 
is no question pending. 
21 
MR. CRITTON: Rachel, would you read back the 
22 
question and answer. 
23 
THE VIDEOGRAPHER: Can we take a break soon? 
24 
MR. CRITTON: I want to — how much time do we 
25 
have? 
(561) 832-7500 
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PROSE COURT REPORTING AGENCY, INC. 
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Page 78 
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(A portion of the record was read by the 
2 
reporter.) 
3 
BY MR. CRITTON: 
4 
Q. Tell me what you thought. What were you going 
5 
to say to me about if you ever thought what? 
6 
A. I don't really — I mean I think we should 
just move on. I don't 
a 
Q. So you don't remember what your thought was 
9 
now? 
10 
A. I mean I don't want you to try to change it 
11 
around to make me look —
12 
Q. Not trying to change it. lin just trying to 
13 
get what you were going to say. 
14 
A. If I ever would have thought that Jeffrey 
15 
would have done half the things I know that he did now 
16 
to people, I never would have asked anybody to go there. 
17 
MR. CRITTON: Okay. Let's save that thought 
18 
and take a break. 
19 
THE VIDEOGRAPHER: Going off the record at 
20 
11:15 a.m. 
21 
(A recess was taken.) 
22 
THE VIDEOGRAPHER:. We're back on the record at 
23 
11:24 a.m. 
24 
BY MR. CRITTON: 
25 
Q. Back to the statement — in fact, lees go 
Page 80 
1 
said. I just remember telling them in general like what 
2 
happened. 
3 
Q. All right. So if the police report, their 
4 
probable cause affidavit says that the second occasion 
5 
you went, the only other occasion you went, that you 
6 
went with E. and Jane Doe 4, you just don't remember 
7 
that as you sit here? 
8 • 
A. I — now you jogged my memory. I didn't 
9 
remember what exactly 1 told them. It was seven years 
10 
ago. 
11 
Q. Actually it was in 2005. We're in 2010, so it 
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was something less than five years ago. 
13 
A. Sorry, five. It was a while ago. !just — 
14 
Q. Again, when you gave the statement to the 
15 
police in October, on October 4th of 2005, that was very 
16 
close to when you would have been at Mr. Epstein's home, 
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again depending on what year you choose, but as you say, 
18 
five years closer than today, correct? 
19 
A. Yes. 
20 
Q. All right. Now do you remember telling the 
21 
police on the second occasion that you went is that you 
22 
did not provide a massage to Mr. Epstein? 
23 
A. Yeah, I think I just said I went with 
24 
somebody. I remember just going once with. and not 
25 
doing anything, just sitting in the kitchen while she 
I 
Page 79 
1 
back to your statement. Well, lees stick with — lets 
2 
start again. Pm going to stay with what you told the 
3 
Palm Beach police. 
4 
On the second occasion when you went, the 
5 
second and last occasion you told the Palm Beach police 
6 
you went to ht. E 
in's home. I think you said you 
7 
think a. drove, 
may have gone, may not have, and 
B 
either n 
or 
went, correct? 
9 
A. I don't remember. I guess correct. 
10 
Q. And when you went the second time, did you 
11 
tell the police the second and last time, did you tell 
12 
them what occurred on the second time? 
13 
A. I don't remember. 
14 
Q. What's your best recollection as to what you 
15 
did tell them? 
16 
A. I don't remember. 
17 
Q. Did you remember telling them on the second 
18 
time that you went let me strike that. 
19 
Do you remember telling them on the second 
20 
occasion that you took, that you went with El and 
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another girl named Jane Doe 4? 
22 
MR. HOROWITZ: Form. 
23 
BY MR. CRITTON: 
24 
Q. Do you remember saying that to the police? 
25 
A. I told you I don't remember exactly what I 
Page 81 
1. 
went up there and did the massage. 
2 
Q. All right. Do you also remember telling the 
3 
police at no time did Mr. Epstein remove the towel 
4 
sound his body? 
5 
MR. HOROWITZ: Form. 
6 
THE WITNESS: I believe 1 said he just like 
7 
laid it over him, yes. 
8 
BY MR. CRITTON: 
9 
Q. Right. And you also told the police at no 
10 
time did he masturbate, true? 
11 
MR. HOROWITZ: Form. 
12 
THE WITNESS: I don't remember if I told the 
13 
police that or not. 
14 
BY MR. CRITTON: 
15 
Q. But if you told them that, was that true? 
16 
A. If I told them that he never masturbated? 
17 
Q. Yes, meam. 
18 
A. Absolutely not. 
19 
Q. So again, that would have been something else 
20 
now you are saying that you would have lied to the 
21 
police about? 
22 
MR. HOROWITZ: Wait, form. What you aro doing 
23 
is totally disingenuous. The objection is to form. 
24 
BY MR. CRITTON: 
25 
Q. If I were to ask you to assume that you told 
(561) 832-7500 
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Page 82 
1 
the police at no time did you see Mr. Epstein 
masturbate, would that have been a lie? 
A. Can you repeat that? 
Q. Sure. Well, PI I have Rachel read it back, 
dam• 
(A portion of the record was read by the 
reporter•) 
MR. HOROWITZ: Form. 
THE WITNESS: Yes. 
BY MR. CRITFON: 
Q. From October 4th through 2005, including the 
filing of your complaint, your amended complaint, your 
interrogatories, supplemental answer to interrogatories, 
having talked with the FBI as you described earlier, did 
you ever go back and tell the Palm Beach police or offer 
to go back and tell the Palm Beach police that you had 
lied and you now wanted to tell them the truth? 
A. No. I told the FBI that. I had told the FBI 
that I lied to the Palm Beach police, and I figured that 
they would tell the Palm Beach police exactly what 
happened 
MR. CRITTON: Move to strike. Let me ask you 
my question again. 
BY MR. CRITTON: 
Q. At any time did you ever go back from 
Page 84 
1 
A. I told her what happened and asked her if she 
2 
talked to the police, and I can't remember if she talked 
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to than or not. 
4 
Q. Did you tell her that you had lied to the 
5 
police? 
6 
A. I told her I didn't tell the police 
7 
everrilin& 
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Q Did you tell her — my question was did you 
9 
tell her 
10 
A. I don't remember. 
11 
Q. Let me ask the question so it's clear. 
12 
Did you tell Jane Doe 4 that you had lied to 
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the police? 
14 
A. I don't remember. 
15 
Q You are aware that Jane Doe 4 is a plaintiff, 
16 
she's also bringing a suit for $50 million or something 
17 
against Mr. Epstein, correct? 
18 
A. Yes. 
19 
Q. Okay. You are aware that she's represented by 
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your current attorneys? 
21 
A. Yes. 
22 
Q. Okay. How did you find out that Jane Doe 4 
23 
had brought a lawsuit against Mr. Epstein? 
24 
A. She told me. 
25 
Q. Okay. When did she tell you? 
Page 83 
1 
October 4, 2005, up through the filing of your 
2 
complaint, your answers to interrogatories, your 
3 
supplemental answers to interrogatories, up through 
4 
today, have you ever gone back to the Palm Beach Police 
5 
Department and said "I'd like to correct my testimony, 
6 
because I lied to you"? 
7 
it No. I told you I told the FBI -
8 
Q. I don't want to know — go ahead. Just a yes 
9 
a no is fine that question. 
10 
A. No. 
11 
MR. HOROWITZ: Foot 
12 
BY MR. CItITTON: 
13 
Q. Thank you. 
14 
All right, at some point-- well, let me go 
15 
back to the police. You talked to the police for an 
16 
hour, hour and a half. You never spoke with them again. 
17 
correct? 
18 
A. (Witness nods head up and down.) 
19 
Q. Okay. Did you call any of your friends and 
20 
tell them that, that you had spoken to the police? Did 
21 
you call Jane Doe 4? 
22 
A. Yes. 
23 
Q. Why? Why did you call Jane Doe 4? 
24 
A. Because she is one of my good friends. 
25 
Q. What did you tell her? 
Page 85 
1 
A. When we were up, living up in Orlando 
2 
together. 
3 
Q. And during what time period were you and Jane 
4 
Doe 4 living in Orlando together? 
5 
A. It was about a year ago, in the summer she 
6 
moved up there. 
7 
Q. Okay. 
A. So 
9 
Q. Sometime in 2008? 
10 
A. Yes. 
11 
Q. And what brought up the fact that she had 
12 
filed a lawsuit? 
13 
A. I don't remember. 
14 
Q. You had not brought a lawsuit until 
15 
September 10, 2008. So Jane Doe 4's lawsuit was filed 
16 
before yours, correct? 
17 
MR. HOROWITZ: If you know. 
18 
BY MR. CRIT1PON: 
19 
Q. Til ask you to assume that date. 
20 
MR. HOROWITZ: If you know. 
21 
THE WITNESS: I guess, yes. I don't know. 
22 
BY MR. CR1TTON: 
23 
Q. She said she had filed a lawsuit. Did she say 
24 
why? 
25 
A. I don't think so. 
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Page 86 
Q. Did she tell you why she had brought a 
2 
lawsuit? 
3 
A. No. I mean I knew what happened between her 
and Jeffrey, some of it, so I just figured it was 
because of what happened. 
o 
Q. Okay. Well, Jane Doe 4, you knew what lane 
Doe 4 was doing at Mr. Epstein's during the time she was 
going to Mr. Epstein's, true? 
9 
ML HOROWITZ: Form. 
10 
THE WITNESS: I didn't know everything that 
11 
was going on. 
12 
BY MR. CRITION: 
13 
Q. She was telling you, though, some of the 
14 
things that were going on, correct? 
15 
A. A little bit, yes. 
16 
Q. When do you believe Jane Doe 4 started going 
17 
to Mr. Epstein's? 
18 
A. I don't really know. Fm assuming around the 
19 
same time I did. 
20 
Q. Do you know whether she went before or after 
21 
you for the first time? 
22 
A. I think she went after me. I'm not sure, 
23 
though. 
24 
Q. And what makes you think she, Jane Doe 4, went 
25 
after you? 
Page 88 
1 
Q. Before she went back to Lynn University? 
2 
A. Yes. 
3 
Q. And what, when she was up there, was it just 
4 
the two of you living in the apartment? 
5 
A There were two other girls. 
6 
Q. Who were they? 
7 
A. I forget what girls we were living with at the' 
8 
time. I don't remember what girls we were living with. 
9 
I think, because a lot of the girls left to go out of 
10 
town, so — I don't know. 
11 
Q. All right. So sometime May through August of 
12 
'08 she, Jane Doe 4, was living there with you? 
13 
A. Yes. 
14 
Q. All right. And she told you during that time 
15 
that she had filed a lawsuit against Mr. Epstein? 
16 
A. Yes. 
17 
Q. Okay. Did she tell you who her lawyers were? 
18 
A. 'don't think so. 
19 
Q. What did she tell you about the lawsuit? 
20 
A. She didn't tell me much. She just said she 
21 
was filing a lawsuit against him. 
22 
Q. Did she say why? 
23 
A. No. She — no, !just assumed because it was 
24 
what happened. 
25 
Q. Okay. I'm sorry, did you say "Well, Jane Doe 
Page 87 
1 
A. I don't know. I don't remember exactly. 
2 
Q. Did you ever talk to Jane Doe 4, when 
3 
asked you if you wanted to go to Mr. Epstein's, did you 
4 
ever, at that time were you aware that Jane Doe 4 had 
5 
gone? 
6 
A. I don't remember. 
7 
Q. Were you, other than -who you knew had 
8 
gone, were you aware of anyone else who had gone to 
9 
Mr. Epstein's at the time you first wan? 
10 
A. No, I don't think so. 
13. 
_Q. All right. So let's get back to 2008, and 
12 
MI— I'm sorry, Jane Doe 4 was living with you in 
13 
Orlando during the summer of 2008? 
14 
A. (Witness nods bead up and down.) 
15 
Q. Yes? 
16 
A. Yes. 
17 
Q. For how long a time period? 
18 
A. Just for the summer. 
19 
Q. Are we talking June through August? 
20 
A. I think March through May. 
21 
Q. Of '08? 
22 
A. Oh, no, no, sorry, it was May yeah, 
23 
probably May through August. I don't really remember. 
24 
It was during the summer, before her classes started 
25 
again. 
Page 89 , 
1 
4, you went ova there voluntarily. Why would you file 
2 
a lawsuit? 
3 
MR. HOROWITZ: Form. 
4 
THE WITNESS: No, I never said that. 
5 
BY MR. CRITTON: 
6 
Q. Did you say to her "You know, you got paid 
7 
money while you went. Why would you file a lawsuit when 
8 
you knew" — strike that. 
9 
Did Jane Doe 4 ever tell you how many times 
10 
she went to Mr. Epstein's home? 
11 
A. No. 
12 
Q. Did she tell you what happened at 
13 
Mr. Epstein's home on any of the visits? 
14 
A. Briefly. 
15 
Q. What did she tell you? 
16 
A. Told me about how he asked her to go on a trip 
17 
with her — or with him, but I saw the underwear that he 
18 
bought her and I remember him getting her a car. And 
19 
just briefly, I mean we didn't go into detail that much. 
20 
Q. So you and Jane Doe 4 have been great, best 
21 
friends since when? 
22 
A. Well, we've been good friends since my 
23 
freshman year of high school. 
24 
Q. Which would have been '02? 
25 
A. I believe so. 
(561) 832-7500 
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PROSE COURT REPORTING AGENCY, INC. 
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Page 90 
1 
Q. AR right. So from 2002 up through the 
2 
current time, March of 2010, you and Jane Doe 4 have 
3 
been best friends, correct? 
4 
A. Yes. 
5 
Q. All right. And you said I asked you if Jane 
6 
Doe 4 told you why she filed a lawsuit, and you said 
7 
well, she told me about some of the things that 
8 
happened. You say that, one of the aspects you said is 
9 
Mr. Epstein asked her to go on a trip with him, right? 
10 
That's what she told you? 
11 
A. Yes. 
12 
MR. HOROWITZ: FORM 
13 
BY MR. CRITTON: 
14 
Q. Okay. Did she? 
15 
A. No. 
16 
Q. All right. And did she tell you why she 
17 
didn't go on the trip with him? 
18 
A. No. 
19 
Q. All right. And she said that Mr. Epstein also 
20 
bought her some underwear? 
21 
A. Yes. 
22 
Q. All right. Did she wear it? 
23 
A. I don't lmow if she did or not 
24 
Q. So he bought her underwear and what's, what 
25 
was, what in your mind was I'd say inappropriate or 
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Page 92 
seem to be disturbed in any way about that? 
A. Yeah, she thought it was kind of weird. 
Q. Did you say 'Well, gee, when he bought the 
underwear for you, did you ever go back to Mr. Epstein's 
if you thought that was so weird?" 
Did you ask that question? 
A. No, I did not. 
Q. Okay. Is it your testimony that based upon 
the fact that she, Jane Doe 4, related to you that it 
was weird that Mr. Epstein had bought her underwear, you 
would have assumed then, based on her comment to you, 
that she never would have returned to Mr. Epstein's 
after that point because she thought it was weird, 
coned? 
MR. HOROWITZ: Fenn. 
THE WITNESS: I don't remember what exactly 
she thought. 
BY MR. CRITTON: 
Q. What was her reaction to, at least what she 
purportedly told you, that Mr. Epstein had bought her a 
sex toy? 
MR. HOROWITZ: Pam. 
ME WITNESS: I think she just thought it was 
inappropriate. 
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Page 91 
shocking at least as Jane Doe 4 related to you as, that 
Mr. Epstein brought her underwear? What was the problem 
with that? 
A. I think he bought her like a sex toy or 
something too. I just thought it was weird that an old 
man or older guy, sorry, would do that. 
Q. Okay. Did you think, did she tell you that 
she wore the underwear? 
A. She never told me. 
Q. Did she tell you, did she describe a sex toy 
that she alleges that Mr. Epstein bought for her? 
A. No. 
Q. Did she tell you she used it? 
A. I didn't go into the sexual details with her. 
Q. Okay. Did she tell you she used it and she 
enjoyed it? 
A. She never told me that she used it and enjoyed 
it. 
19 
Q. Would that have made a difference to you? 
20 
MR. HOROWITZ: Form. 
21 
THE WITNESS: No. 
22 
BY MR. CRITTON: 
23 
Q. Did the fact, separate and apart from your 
24 
opinion, the fact that Jane Doe 4 said he had bought, 
p..5 
be, Mr. Epstein had bought underwear for her, did she 
(561) 832-7500 
Page 93 
1 
BY MR. CRITTON: 
2 
Q. And did she describe what the sex toy was? 
3 
A. I don't remember. 
4 . 
Q. Did she tell you whether it was a vibrator 
5 
a --
6 
A. I don't think it was a vibrator, but I don't 
7 
remember. 
8 
Q. And you knew what a vibrator was in 2008, 
9 
correct? 
10 
A. Yes. 
11 
Q. Did you know what a vibrator was in 2007? 
12 
A. Yes. 
13 
Q. In 2006? 
14 
A. Yes. 
15 
Q. And since when? How long have you known what 
16 
a vibrator is? 
17 
MR. HOROWITZ: Form. 
18 
THE WITNESS: I have no idea. 
19 
BY MR. CRITTON: 
20 
Q. Were you aware of what a vibrator was when you 
21 
were a freshman in high school? 
22 
A. I don't remember. 
23 
Q. How about a sophomore? 
24 
A. I don't really remember when I knew, found out 
25 
what that was. 
24 (Pages 90 to 93) 
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Page 94 
1 
Q. Well, certainly she, meaning lane Doe 4, is 
2 
telling you that he brought her a vibrator, and she 
3 
thought it was inappropriate, right? 
4 
A. Yes. 
5 
Q. All right. And did you say "Gee, did you ever 
6 
go back to Mr. Epstein's home after he brought you the 
7 
vibrator?" 
A. I never asked her that, if she did or not. I 
9 
don't remember when she bought it or he got it for her. 
10 
Q. Well, assuming that he bought the vibrator for 
11 
her sometime during the time she was going to 
12 
Mr. Epstein's house, based at least upon what she said 
13 
to you she thought it was inappropriate, you would have 
14 
expected her never to return to Mr. Epstein's home, 
15 
correct? 
16 
MR. HOROWITZ: Form. 
17 
THE WITNESS: No, I mean that was her opinions 
18 
and her own, I mean status with him. So I didn't 
19 
really know what she was thinking or what she 
20 
thought besides — 
21 
BY MR. CRITTON: 
22 
Q. She thought it was inappropriate, but it 
23 
wouldn't have prevented her, at least what she told you, 
24 
from going to Mr. Epstein's home, correct? 
25 
MR. HOROWITZ: Form. 
Page 96 
1 
MR. HOROWITZ: Pam. 
2 
THE WITNESS: Weird and inappropriate might be 
3 
different from my perspective to her perspective. 
4 
BY MR. CRITTON: 
5 
Q. So you think him having purchased — did he 
6 
ever purchase underwear for you? 
7 
A. No. 
8 
Q. !assume he never bought a 
9 
toy for you? 
10 
A. No. 
11 
Q. So you would have considered those both 
12 
inappropriate and weird if he had done that, the eight 
13 
to ten times you claim that you went, you would have 
14 
said I'm never going back because that's weird and 
15 
Inappropriate, right? 
16 
MR. HOROWITZ: Form. 
17 
THE WITNESS: I mean I don't know what I would 
18 
have thought. If it was in the moment, I don't 
19 
know. I can't really remember what I was thinking 
20 
at that point. 
21 
BY MR. CRITTON: 
22 
Q. I assume, though, if you understood if Jane 
23 
Doe 4 was saying Mr. Epstein getting her underwear and 
24 
getting her a vibrator was weird and inappropriate was 
25 
if you had found something that was weird or 
vibrator or a sex 
1 
2 
3 
4 
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Page 95 
THE WITNESS: I don't remember if she went 
after that. 
BY MR. CRITTON: 
Q. You don't know one way or the other, she just 
told you she thought that him getting a sex toy fix her, 
• vibrator for her was inappropriate? 
A. Yes, she said it was weird, so —
Q. You used the word inappropriate. That's why I 
used it. 
MR. HOROWITZ: Form. 
THE WITNESS: Inappropriate, weird. 
BY MR. CRITTON: 
Q. Sarno thing to you? 
A. Same thing. 
Q. So if something happened that was weird or 
inappropriate from your perspective, you never would 
have gone back to Mr. Epstein's home, would you? 
MR. HOROWITZ: Form. 
THE WITNESS: This is Igm after I stopped 
going. 
BY MR. CRITTON: 
Q. I understand that, but if something weird or 
inappropriate had happened at Mr. Epstein's home during 
the time you were going, you never would have returned, 
would you? 
Page 97 
1 
inappropriate that had happened at Mr. Epstein's house, 
2 
whether it was the first time, the second or third or 
3 
fourth, you wouldn't have returned, would you, because 
4 
you would have said why should I go back to somebody's 
5 
house where something weird or inappropriate is 
6 
happening, correct? 
7 
MR. HOROWITZ: Form. 
8 
THE WITNESS: I thought everything was weird 
9 
and inappropriate that he was doing, so —
10 
BY MR. CRITTON: 
11. 
Q. And you knew that 
12 
MR. HOROWITZ: Wait, you're cutting —
13 
MR. CR/TTON: Go ahead. Now you want her to 
14 
finish. Go ahead. 
15 
MR. HOROWITZ: I always want her to finish. 
16 
MR. CRITTON: Yeah, right. 
17 
MR. HOROWITZ: Move to strike. 
18 
MR. CRITTON: Do you want the answer read back 
19 
so you can fill in the blank? 
20 
THE WITNESS: No. 
21 
BY MR. CRITTON: 
22 
Q. Okay. Were done with your answer? 
23 
A. Yes. 
24 
MR. CRITION: Would you read me the question 
25 
and answer back. In fact, just let me look over 
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your shoulder, Rachel. Okay. 
2 
BY MR. CRITTON: 
3 
Q. Okay. So if I understood your testimony, you 
4 
said that every time or — let me strike again, start 
5 
Win-
6 
If I understand your testimony, it's your 
7 
testimony that everything that occurred at Mr. Epstein's 
8 
house when you were there was weird and inappropriate? 
9 
MR. HOROWITZ: Form. 
10 
THE WITNESS: I mean yes, to some degree I 
11 
thought was. 
12 
BY MR. CRITTON: 
13 
Q. And you knew that at the time it was weird and 
14 
inappropriate, the eight to ten times that you were 
15 
there, correct? 
16 
A. I mean at first I didn't — I mean now I know 
17 
that it's weird and inappropriate. I mean but then I 
18 
think I was so confused and I didn't really know what ! 
19 
was doing, and I mean I don't know, 1 was young and 1 
20 
wasn't thinking. 
21 
Q. Well, however old you were, depending on which 
22 
dates we use here, is it's your testimony that what you 
23 
believe occurred at Mr. Epstein's home, even when you 
24 
were at whatever age you were, whether it was 16 or 17 
25 
or whatever age, you thought it was weird and 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
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Page 100 
her. I don't know, her car might have been not working. 
I don't really remember. 
Q. You mean he like rented a car to help her out? 
A. Yes, I think so. 
Q. Did she think that was weird or inappropriate? 
MR. HOROWITZ: Form. 
THE WITNESS: I don't remember. 
BY MR. CRITTON: 
Q. All right. Well, my original question was 
what did she tell you as to why she was filing a lawsuit 
against Mr. Epstein? And I think your answer was he 
asked her on a trip, underwear and a sex toy and a car. 
MR. HOROWITZ: Form. 
BY MR. CRITTON: 
Q. So my question again is what else, if 
anything, did she tell you as to what the basis of her 
suit was against Mr. Epstein? 
A. I mean I assumed he did to her what he did to 
me, so I'm assuming that's why she would sue him. 
Q. Okay. My question is what did she tell you, 
not what you assumed. What did she tell you? 
A. I don't exactly remember what she told me. 
Q. Did she tell you anything other than the trip, 
the underwear, the vibrator, and the car? 
Page 99 
1 
inappropriate, true? 
2 
MR. HOROWITZ: Form. 
3 
THE WITNESS: I mean yeah, I thought it was 
4 
uncomfortable, yes. 
5 
BY MR. CRITTON: 
6 
Q. All right. And uncomfortable now, that's a 
7 
new word, so can 1- is weird equal to inappropriate 
8 
versus uncomfortable to you? 
9 
MR. HOROWITZ: Form. 
10 
BY MR. CRITTON: 
11 
Q. Can I use those as synonyms, basically the 
12 
same meaning? 
13 
A. Yes. 
14 
Q. All right Now back to Jane Doe 4 again. 
15 
She's telling you, she's now living with you in Orlando 
16 
during the summer of '08. She told you that Mr. Epstein 
17 
asked her on a trip. She thought that was 
18 
inappropriate. She didn't go. He got her underwear and 
19 
a sex toy, vibrator. She thought that was 
20 
inappropriate. You said he got her a car. 
21 
For what? 
22 
MR. HOROWITZ: Form. 
23 
BY MR. CRITTON: 
24 
Q. What did she tell you? 
25 
A. 1 don't exactly remember why he bought it for 
Page 101 
1 
MR. HOROWITZ: Form. 
2 
THE WITNESS: I don't remember. 
3 
BY MR. CRITTON: 
4 
Q. All right. So Jane Doe 4, who is your best 
5 
friend, who was going to Mr. Epstein's during, about the 
6 
same time you were, whatever, if that was in 04, '05, 
7 
whatever the dates were, now she is telling you about a 
8 
lawsuit she's filed, and you can't remember anything 
9 
that she's ever told you about what she did at 
10 
Mr. Epstein's house; is that correct? 
11 
MR. HOROWITZ: Form. 
12 
THE WITNESS: I mean I remember just the main 
13 
points, like I remember the car was like a big 
14 
deal, the sex toy, the underwear. That was a big 
15 
deal. 1 remember like the main things that 
16 
happened. I don't remember every little detail she 
17 
told me about what happened at Jeffrey's. 
18 
BY MR. CRITTON: 
19 
Q. Did she tell you any of the details of what 
20 
happened at Mr. Epstein's? 
21 
A. Like I said, 'don't remember. I knew that he 
22 
tried a lot with her, because she went there a lot, but 
23 
I don't exactly remember what exactly he tried with her 
24 
and did on her. Sono. 
25 
Q. Did she ever tell you? 
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A. I don't remember. She probably did and I just 
2 
forget exactly what she told me. 
3 
Q. At any time during the time she was going to 
4 
Mr. Epstein's home and you knew she was going there, did 
5 
she ever tell you that anything inappropriate had ever 
6 
occurred? 
7 
MR. HOROWITZ: Form. 
8 
THE WITNESS: 1 mean I thought the underwear 
9 
was inappropriate. I thought asking to go on a 
10 
trip is inappropriate. So 1 mean yes. 
11 
BY MR. CRITTON: 
12 
Q. Okay. And as of, during the time again she 
13 
was at Mr. Epstein's house and up until the time that 
14 
the police interviewed you in October, on October 4th of 
15 
2005, did Jane Doe 4 ever tell you that anything that 
16 
had occurred at Mr. Epstein's house had caused her any 
17 
embarrassment or humiliation? 
18 
MR. HOROWITZ: Form. 
19 
THE WITNESS: I don't remember. 
20 
BY MR. CRITTON: 
21 
Q. Did she ever tell you that she was in any way 
22 
assaulted or in any way physically abused at 
23 
Mr. Epstein's home? 
24 
A. !just remember her being like in shock about 
25 
everything and just like I !mow he tried a lot on her 
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 104 
Q. El or- 
one or the other? 
A. I think it was • 
I'm pretty sure, and they 
both knew about it. 
Q. So both. and %knew, because you had 
taken more likely than not 
to Mr. Epstein's home, 
yes? 
A. I mean a lot of girls in our school knew about 
it. 
Q. Knew that you were going there? 
A. Just knew about the whole Jeffrey thing that 
was going on. 
Q. Pretty common knowledge? 
A. I mean I'm not — 
Q. In your school? 
A. Not common, but I mean like m.thriends just 
knew about it because he targeted like El targeted 
lot of my friends. 
Q. Well, she may have asked you, she didn't 
necessarily target — you were her friend? 
MR. HOROWITZ: Form. 
BY MR. CRITTON: 
Q. You don't know whether she targeted you or 
not. She asked you if you wanted to go to Mr. Epstein's 
didn't know? 
MR. HOROWITZ: Fenn. 
Page 103 
1 
just because she went there a lot and he really liked 
2 
her and L.A. 
3 
So I mean I think that's, you know — I 
4 
don't —
5 
Q. Did she, Jane Doe 4, during the time she was 
6 
going to Mr. Epstein's house, did she tell you she was 
7 
in shock? 
8 
MR. HOROWITZ: Fenn. 
9 
THE WITNESS: That was my opinion, that she 
10 
was kind of in shock over everything, because, I 
11 
don't know. 
12 
BY MR. CRITTON: 
13 
Q. I want to focus on a time period. Prior to 
14 
the October 4th visit from the Palm Beach police, okay? 
15 
Before, in essence, someone other than your friends knew 
16 
that, at least from your perspective, that you had been 
17 
to Mr. Epstein's home - in fact, !should probably ask 
18 
it this way. 
19 
Who knew that you had gone to Mr. Epstein's 
20 
home before the 
ice came there? Cenainly. did. 
21 
A. Yes, MI and Jane Doe 4 and 
22 
Q. Because you had taken ■ 
and 
to 
23 
Mr. Epstein's home? 
24 
A. I had just taken. one of the sisters, 
25 
like I told you. 
Page 105 
1 
THE WITNESS: Yes. 
2 
BY MR. CRITTON: 
3 
Q. You could have said yes and you could have 
4 
said no? 
5 
A. I mean yes, that's true. 
6 
Q. All right. And your decision to go to 
7 
Mr. Epstein's was a voluntary one; that is, again, 
8 
because you could have said sure, I'll go; or no, no 
9 
interest, right? 
10 
A. Yes. 
11 
Q. Okay. And my guess is 
u are aware of girls, 
12 
females at your school who El asked to go and they 
13 
said no, Pm not going, or I don't have any interest, 
14 
right? 
15 
A. No. 
16 
Q. So everyone that. ever asked —
17 
A. I don't !mow exactly who 
asked. 
18 
Q. Are you aware of anyone who 
asked that 
19 
didn't want to go? 
20 
A. No. 
21 
right. And in fact, you and others would 
22 
ask MI if you could go to Mr. Epstein's; isn't that 
23 
true? 
24 
A. No. 
Q. Okay. Is it your testimony that you never 
o 
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asked 
if you could go to Mr. Epstein's? 
• 
A. 
asked me twice, and then
 asked me 
• 
from then on. So I never asked. to go. 
Q. Okay. Did you ever make a call to=? 
▪ 
A. No,Milivould always call — 
MR. HOROWITZ: Let him finish. You know what 
7 
each other is going to say, but let him finish. 
8 
BY MR. CRITTON: 
9 
Q. Did you ever make a call to M? 
10 
A. No, not that I could remember. 
11 
Q. And if 
called you, she basically said, 
12 
in essence the conversation was "Would you like to conic 
13 
over today?" 
14 
A. Yeah, she asked me what my schedule was and 
15 
when I had school and classes and like what days I could 
16 
come. 
17 
Q. And that was the extent of the conversation, 
18 
it was strictly a scheduling? 
19 
A. No, and she asked me if I knew anybody too 
20 
that I would want to bring for a massage. 
21 
Q. Okay. And that was the extent of the 
22 
conversation, at least as to you? Whatever 
23 
conversations you had with Sarah, she may have called 
24 
you on the phone and she said basically is what's your 
25 
schedule? Can you come at a certain time, or what times 
Page 108 
1 
been confused because you had time to think about it and 
2 
say no or simply not go, correct? 
3 
MR. HOROWITZ: Rim. 
4 
THE WITNESS: I mean I guess you would say 
5 
that. 
6 
BY MR. CRI1TON: 
7 
Q. All right And in temis of — all right, I'll 
8 
come back to that in a bit Lame get back to, I think 
9 
I was on Jane Doe 4 before I got off on a little tangent 
10 
here, so let me go back to Jane Doe 4. 
11 
When she told you through the summer 
well, 
12 
let me strike that. 
13 
During the time that she was going to 
14 
Mr. Epstein's, you said she never said she was 
15 
embarrassed or humiliated or had been traumatized, 
16 
correct? 
17 
MR. HOROWITZ: Form. 
18 
BY MR. CRITTON: 
19 
Q. That is, she never told you that? 
20 
A. I mean I could tell that obviously she, she 
21 
was just kind of under a spell of him lace buying her 
22 
things and giving her things and going them so much. 
23 
And I could tell she was just kind of — you 'mow, he 
24 
was just kind of brainwashing her, her and L.A. That's 
25 
why I stopped going, because it just had got too much 
Page 107 
1 
can you come? 
That was one aspect of the conversation, 
3 
comet? 
A. Yes. 
5 
Q. Okay. And if you didn't want to go, you would 
6 
have said rm not interested, correct? 
7 
A. Yes. 
8 
Q. All right. So you had to again make a 
9 
voluntary decision, number one, to pick up the phone if 
10 
Sarah was calling you so you could talk to her and say 
3.1 
either yes or no, correct? 
12 
A. Yes. 
13 
Q. AM then you had to make a volun er ail
14 
consensual decision once you talked witL 
i a
to giVe 
15 
her your schedule or not, correct? 
16 
A. Yes. 
17 
Q. And then you had to ultimately schedule a time 
18 
to go over to Mr. Epstein's, and then you would have to 
19 
get in your car or however you — mostly your car so you 
20 
could transport yourself over there, true? 
21 
A. Yes. 
22 
Q. So in all of those, you had to make a decision 
23 
to say yes, yes, yes, yes, right? 
24 
A. Yes. 
25 
Q. And in each those instances, you wouldn't have 
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 
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Page 109 
the last visit. So —
Q. This is, L.A. is LA.? 
A. Yes. 
Q. Okay. And did L.A. go to Mr. Epstein's home 
too? 
A. Yes. 
Q. Were you ever present when LA. was there? 
A. No. 
Q. How old was LA. when she went? 
MR. HOROWITZ: Form. 
THE WITNESS: I don't remember. I think 18. 
BY MR. CRITTON: 
Q. And therefore, at 18 she could decide to 
either go or not go, just like Jane Doe 4 or you or 
anyone else, true? 
A. Yes. 
Q. All right. Were you ever — I may have just 
asked you this. I was thinking about something else. 
Were you ever present when L.A. was there? 
A. No. 
Q. Are you aware that LA. ever went with Jane 
Doe 4? 
A. I think they went together before. 
Q. Okay. Did they tell you that? 
A. I think Jane Doe 4 told me she went with L.A. 4
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11 
12 
13 
14 
15 
16 
17 
18 
19 
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25 
Page 110 
1 
I don't  
ICI ber. 
2 
Q. Did either L.A. or Jane Doe 4 ever describe to 
3 
you up until the time you were interviewed by the Palm 
4 
Beach Police Department that they were, had been in any 
5 
way embarrassed, humiliated or traumatized by any of 
6 
their visits to Mr. Epstein's home? 
7 
MR. HOROWITZ: Form. 
8 
THE WITNESS: Well, at that point nobody knew 
9 
about it yet, so I'm sure they wouldn't have been 
10 
embarrassed, because I mean their parents didn't 
11 
!mow like they do now, or Jane Doe 4's sister or 
12 
anybody else, you guys depositioned for her. So I 
13 
mean at that point they probably wouldn't have been 
14 
embarrassed. 
15 
BY MR. CRITTON: 
16 
Q. Or humiliated, right, because they chose to go 
17 
there? 
18 
MR. HOROWITZ: Form. 
19 
THE WITNESS: At the point they were young and 
20 
they weren't really thinking, as I. So —
21 
BY MR. CRITTON: 
22 
Q. All I'm asking is what they have told you 
23 
okay? Or whet you observed. 
24 
So would it be a correct statement as of the 
25 
time you were interviewed by the Palm Beach police, you 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 112 
awful experience, that's something that you would 
generally remember, isn't it? 
MR. HOROWITZ: Forth. 
BY MR. CRITTON: 
Q. Especially a good friend lace Jane Doe 4? 
A. Yeah, I {mew he tried a lot of stuff on her 
and she was definitely uneasy with it and, you know, I 
just think she just kept going for the money basically. 
Q. Did she tell you she was uneasy with it? 
MR. HOROWITZ: Form. 
THE WITNESS: I forget exactly what she told 
me, but the summary of it was that she —
BY MR. CRITTON: 
Q. Summer of '08 now she is telling you this? 
MR. HOROWITZ: She said the sum of It, I 
think. 
BY MR. CRITTON: 
Q. Are you saying the sum of it. 
A. The sum of it was that she was uneasy and 
didn't want to go there, but she was basically just 
going for the int.nrry. 
Q. Well, did she tell you that she was going back 
to Mr. Epstein's because she wanted to make money? 
A. No, that's what I asstnned. 
Q. Again, I want to know what she told you versus 
Page 111 
1 
didn't notice that Jane Doe 4 was either embarrassed or 
2 
humiliated for having gone to Mr. Epstein's, true? 
3 
A. I don't think she was embarrassed or 
4 
humiliated, because nobody knew about it, so —
5 
Q. And from at least what she either told you or 
6 
what you observed, she didn't say she was traumatized in 
7 
any way because she kept going, right? 
MR. HOROWITZ: Form. 
THE WITNESS: Yeah, I mean she was obviously 
didn't want to go, but she kept going I think just 
for the money and just because he was good at 
smooth talking and I mean just made her feel 
comfortable. 
BY MR. CRITTON: 
Q. Move to strike. Let me ask you my question 
again. 
Did Jane Doe 4 ever tell you she was 
traumatized as of the date you gave your interview to 
the Palm Beach police, October 4th of 2005, that she had 
been traumatized in any way by Mr. Epstein? 
MR. HOROWITZ: Farr 
THE WITNESS: I don't remember. 
BY MR. CRITTON: 
Q. All right. Well, if one of your friends told 
you that they had had a traumatic experience or some 
Page 113 
1 
what you assumed. 
2 
So would it be a correct statement, she didn't 
3 
tell you she was in any way traumatized or emotional ly 
4 
or psychologically damaged by anything that was 
5 
occurring with Mr. Epstein? 
6 
She never said that to you, did she? 
7 
MR. HOROWITZ: Form. 
8 
BY MR. CRITTON: 
9 
Q. Let me rephrase the question. Did Jane Doe 4, 
10 
as of October 4 of 2005 when the Palm Beach police came 
11 
to interview you, up to that point, had Jane Doe 4 ever 
12 
said to you that she was in any way traumatized either 
13 
emotionally or mentally by any of her visits to 
14 
Mr. Epstein's home? 
15 
MR. HOROWITZ: Form. 
16 
BY MR. CRITTON: 
17 
Q. What she told you. 
18 
A. 1 don't remember exactly if she ever told me 
19 
she was traumatized or what — it was so long ago, 1 
20 
can't remember everything she said to me. I just 
21 
remember the main parts that stick out. 
22 
Q. The car, the trip, the sex toy and the 
23 
underwear. That's what you remember? 
24 
A. Yes. 
25 
Q. And that's what she told you in May or the 
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1 
summer of '08 when she was living with you? 
2 
MR. HOROWITZ: Form. 
3 
BY MR. CRITTON: 
4 
Q. Right? 
5 
A. Yes. 
Q. And you don't remember anything else --
7 
A. Well, I mean I knew about the car I mean 
B 
before she was living with me. 
9 
Q. I understand, but at least that's the first 
1.0 
time — strike that. 
11 
At least as of October 4th of '05 when you 
12 
were interviewed by the Palm Beach police, you don't 
13 
remember anything else that stands out in your mind 
14 
where Jane Doe 4 told you anything bad had occurred at 
15 
Mr. Epstein's? 
16 
MR. HOROWITZ: Form. 
17 
BY MR. CRITTON: 
18 
Q. As you sit here today that you can relate, 
19 
correct? 
20 
MR. HOROWITZ: Form. 
21 
THE WITNESS: I mean she did tell me stuff I 
22 
knew the was going a lot and I know he was really 
23 
trying stuff on her, and I just can't remember the 
24 
details. I 'mew about all that before the police 
25 
even came, and I knew about the car before the 
Page 116 
A. Yes. 
2 
Q. And as of the time you were interviewed, you 
3 
were no longer seeing Mr. Epstein? 
4 
A. Yes. 
5 
Q. Had you made a decision not to see him anymore 
6 
at some point? 
7 
A. Yes. 
8 
Q. And even though you were at whatever age, you 
9 
made a conscious decision I don't want to go to 
10 
Mr. Epstein's home anymore? 
11 
A. Yes. 
12 
Q. Right? And you could have made that decision 
13 
on the first visit, the second, the third, the fourth, 
14 
the fifth, any time up until the time you stopped, 
15 
right? 
16 
A. Yes. 
17 
Q. And with regard to Jane Doe 4, was she aware 
18 
that you had been to Mr. Epstein's on a number of 
19 
occasions? 
20 
MR. HOROWITZ: Form. 
21 
BY MR. CRITTON: 
22 
Q. Did you tell her? 
23 
A. Yes. 
24 
Q. Did you ever tell her why you stopped going to 
25 
Mr. Epstein's? 
Page 115 
1 
police came. I don't know if I knew — I don't 
2 
know if the underwear was before or after the 
3 
police. 
4 
BY MR. CRITTON: 
5 
Q. Did you ever say to her if he was, quote, 
6 
unquote, trying stuff is why are you going back? 
7 
A. No. I mean that's her own deal and her own 
decision. 
9 
Q. All right. And in fact she was 18 at the 
10 
time? 
11 
MR. HOROWITZ: Form. 
12 
BY MR. CRITTON: 
13 
Q. She was a 
her of 2005, 
14 
she's iS a freshmanfillia, 
right? 
15 
A. Yes. 
16 
Q. Okay. And you and Jane Doe 4 are the same 
17 
age? 
18 
A. We're around the same age, yeah_ Well, yeah. 
19 
Q. I mean, I'm sorry, you may not be the exact 
20 
same age, but you were also now at 
Itip in 
21 
Orlando? 
22 
A. Yes, 
23 
Q. In '05, correct? 
24 
A. Yes, 
25 
Q. So you were away at college too? 
 
vaamemsedsessamisseransaw— 
Page 117 
1 
A. I believe so. 
2 
Q. What did you tell her? 
3 
A. I don't really remember. I just remember 
4 
telling her the last time was, made me feel really 
5 
uncomfortable and he definitely had forcefully tried to 
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do stuff with me, and that's why I stopped going. 
7 
Q. Okay. And at least from your perspective, if 
8 
he hadn't as you allege forcefully tried to do 
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something, you would have continued to go see 
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Mr. Epstein? 
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MR. HOROWITZ: Form. 
12 
THE WITNESS: No, because every time I went 
13 
there, he would try more and more and more, and to 
14 
the point where I was done. And so I wouldn't have 
15 
continued to keep going. 
16 
BY MR. CRITTON: 
17 
Q. Okay. And you told that, it's your testimony 
18 
you told Jane Doe 4 that? 
19 
MR. HOROWITZ: Form. 
20 
THE WITNESS: I don't remember. I think I 
21 
told her. I just, I don't remember for sure 
22 
exactly. I think I did tell her. 
23 
BY MR. CRITTON: 
24 
Q. All right. 
25 
A. Because I think she asked me why 1 didn't go 
30 (Pages 114 to 117) 
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Page 118 
1 
there anymore. I don't remember exactly what 1 told 
2 
her, though. 
3 
Q. Did she, Jane Doe 4, tell you that she enjoyed 
going to Mr. Epstein's? 
5 
A. No. 
6 
Q. Would you be surprised if
 her deposition 
she testified to that fact? 
Mit HOROWTM: Penn. 
TIME WITNESS: I manlike Dolman. he 
brainwashed everybody. At the point where he was 
asking her to get on private jets and go on 
vacations, maybe, I don't 
BY MR. CANTON: 
Q. My question is did she tell you? There is a 
distinction between what you are assuming and what she 
mid you. 
In fact, Rachel, would you go back —
MR. HOROWITZ: Your question was —
MR CRITTON: Fm going to have it read back. 
(A portion of the record was read by the 
reporter.) 
BY MR. CRITTON: 
Q. When you tented with Jane Doe 4 in May or 
during the summer of '08 when she told you she had 
brought her lawsuit, did she tell you what she was 
Page 120 
1 
lawyers had anything to do with you going to 
2 
Mr. Epstein's the first time, did they? 
3 
A. Of course not, no. 
4 
Q. Okay. In fact, it was, more importantly, the 
5 
second time you went to Mr. Epstein's, that was 
6 
completely a voluntary consensual decision that you made 
7 
in your own mind to go back to his home, not 
8 
Mr. Epstein, but your decision, correct? 
9 
MR. HOROWITZ: Form. 
10 
THE WITNESS: Yeah, when I was around 16 at 
11 
the time. I mean yeah. 
12 
BY MR. CRITTON: 
13 
Q. Just a yes or a no, okay? I know you want to 
14 
justify what you did or not did, so kt me ask a clean 
15 
question. 
16 
At the time you went to Mr. Epstein's the 
17 
second time -- you went to Mr. Epstein's the first time 
18 
with El correct? 
19 
A. Uh huh. 
20 
Q. All right Yes? 
21 
A. Yes. 
22 
Q. Okay. The second time you went to 
23 
Mr. Epstein's, that was completely your decision, right? 
24 
MR. HOROWITZ: Font 
25 
THE WITNESS: I already told you that, yes. 
Page 119 
1 
looking for? That is, what did she want from 
2 
Mr. Epstein? 
3 
A. She just wanted justice. She was upset like 
4 
every other girl and she just wanted, you know, more 
5 
than anything to see him in jail, and I mean yeah. 
6 
Q. And ultimately he was in jail at that time, 
was he not? 
8 
A. That was like a slap on the wrist basically. 
9 
Q. How do you know? It's the justice system. 
10 
Let me start again. 
11 
A. Because I read all the newspapers and I think 
12 
'know — 
13 
Q. Okay. 
14 
A. I mean if you have money, I mean he could 
15 
hire, afford to hire you and other great lawyers that 
16 
make girls feel like crap and don't mind doing it, so --
17 
Q. Well, I had nothing to do with your going to 
18 
Mr. Epstein's the first occasion, did I? 
19 
A. I mean — 
20 
Q. Yes or no? 
21 
A. You don't think it was wrong what he did? 
22 
Q. Yes or no, did I have anything to do with you 
23 
ever going to Mr. Epstein's? 
24 
A. Of course not. I didn't know you back then. 
25 
Q. Thank you. And in fact, none of Mr. Epstein's 
Page 1.. 
1 
BY MR. CRITTON: 
2 
Q. And Mr. Epstein had nothing to do with that, 
3 
it was your decision to either go or not go? 
4 
A. He's the one that got the girls to go there. 
5 
He had everything to do with it. 
6 
Q. But it was your decision to go or not, not 
7 
Mr. Epstein's? 1 mean he could ask r ru to come back. 
8 
A. He never would have asked 
to hunt down 
9 
girls to bring them there. I never would have went 
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there, I never would have been put in that position. I 
11 
don't think anybody when they are 16 years old should 
12 
have been put in that position by a 55 or however old he 
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Ismail. 
14 
Q Let me ask you this. I think you said you 
15 
took 
to Mr. Epstein's home. 
16 
A. Yes. 
17 
Q. How many times had you been to Mr. Epstein's 
18 
home before you took IMI.? 
19 
A. I think I took her like the second visit, lace 
20 
around the second visit 
21 
Q. Okay. 
22 
A. He didn't really try that much with me the 
23 
first visit. If1 would have known everything he was 
24 
doing with girls like I have known now, I never would 
25 
have asked any other girlfriends to go. 
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Page 122 
Q. Move to strike. 
I think you said you took 
after your 
second visit, or was it —
A. I think around the second or the third. I 
don't know exactly. 
Q. When did you take. if she's the one you 
took? When did you take her? 
A. I think around — I don't know. I don't 
remember what visit, but I remember it was towards the 
beginning. 
Q. Did you not, those are the only two you ever 
took? 
A. Yes. 
Q. Why would you take — I mean you had to make 
the decision, you in essence did the same thing —
A. 
Q. !have to ask the question. 
A Sony. 
Q. When
 took-you were doing the sane 
thing that MI was doing, were you not? 
MR. HOROWITZ: Form. 
THE WITNESS: el asked me to go. 
BY MR. CRITTON: 
Q. Whether she asked you or not, when el asked 
you to go, asked you to take her, in essence, you were 
Page 124 
1 
I heard about, my friends were doing it and going there 
2 
and —
3 
Q. Do you think whir 
did was wrong? 
4 
A. Honestly, I think 
was just brainwashed by 
5 
hint, and I feel bad for her, because I maul that was 
6 
wrong what he did, brainwashing her to bring other 
7 
girls. 
8 
Q. When you took — 
9 
MR. CRITTON: How much time? 
10 
THE VIDEOGRAPHER: Two minutes. 
11 
BY MR. CRITTON: 
12 
Q. All right. You took 
correct? 
13 
A. Yes. 
14 
Q. And 
did you ask her if she wanted to go? 
15 
A. No. She heard about it too and she asked me 
16 
about it. And I told her I went, and then she asked me, 
17 
she was like "Oh, well, can you bring me there?" 
18 
Q. Did you say "No, I don't think it's — I think 
19 
it's uncomfortable, weird and inappropriate, I don't 
20 
think Til take you there"? 
21 
A. At the time, like it was towards the very 
22 
beginning when I was going that And he wasn't really 
23 
doing this much or trying as math with the girls as 
24 
towards the end that I heard about 
25 
Q. Okay. So you think you took el about the 
Page 123 
1 
doing the same thing that el was doing, right? 
2 
MR. HOROWITZ: Form. 
3 
THE WITNESS: No. 
4 
BY MR. CRITTON: 
5 
Q. You see it in a different view because. 
asked you if you could go to Mr. Epstein's? 
A 
asked me to go to take her there. She 
6 
wanted to go. 
9 
Q. Okay. So I assume when you took el to 
10 
Mr. Epstein's, you didn't take any money from 
11 
Mr. Epstein from having brought her there; is that true? 
12 
A. T did take money. 
13 
Q. You did take money. How much money did you 
14 
take for el asking you if you could go to Mr. 
15 
Epstein's? 
16 
A. $200. 
17 
Q. Did you say, "Gee, 
I'm not going to take 
18 
any money for bringing you to Mr. Epstein's, that's 
19 
wrong. That's not something I should do. I don't want 
20 
to do the same thing, in essence, that. is doing"? 
21 
A. I didn't realize at the point that it was 
22 
something bad and wrong until now obviously I do, but 
23 
back then when I was 16, I didn't really realize, you 
24 
know, that it was wrong. And I, I was confused and 
25 
just, I mean all the girls in my high school were, that 
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Page 125 
third or fourth time you were there? 
A. 'think it was around the second or third as I 
took. and 
Q. Did you take them the same day? 
A. No, I took one like around the second time and 
one around the third time. I don't really remember. 
MR. CRITTON: Okay, let's have a break 
THE VIDEOGRAPHER: Going off the record at 
12:09 am. This marks the end of tape one. 
(A recess was taken.) 
(End of Volume 1) 
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