EFTA01107831

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-CIV-80119-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
/ 
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, 
/ 
DEPOSITION OF JANE DOE #7 - VOLUME II 
(videotaped) 
Monday, March 15, 2010 
10:02 - 6:49 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Rachel W. Bridge, RMR, CRR 
Notary Public, State of Florida 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
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APPEARANCES: 
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On behalf of the Plaintiffs in related cases 
Nos 08-80069, 08-80119, 08-80232, 08-80384 
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08-80381, 03-80993, 08-80994: 
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ADAM D. HOROWITZ, ESQUIRE 
MERMELSTEIN & HOROWITZ, P.A. 
5 
18205 Biscayne Boukvad 
Suite 2218 
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Miami, Florida 33160 
Telephone: 305/931.2200 
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On behalf of the Defendant Jeffrey Epstein: 
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ROBERT D. CRITTON. JR, ESQUIRE 
BURMAN, CRl11UN, LUTHER& COLEMAN 
10 
303 Banyan Boulevard 
Suite 400 
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West Palm Beach, Florida 33401 
Telephone: 561/842-2820 
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Also Present: Sasha Quimby, videographer 
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PROCEEDINGS 
THE VIDEOGRAPHER: We're back on the record at 
12:19 p.m. This is marks the beginning of tape 2. 
BY MR. CRITTON: 
Q. When you took F.E. to Mr. Epstein's, 1 think 
you said she asked you to take her. 
A. Yes. She knew about It and she asked me, she 
said she wanted to go. 
Q. Okay. Did you say, and did you tell her "No, 
I don't think you should go'? 
A. No. I never said that. 
Q. Did you take her so you could make money' 
First of all, let me ask you this. Did you 
make money from taking F.E. to Mr. Epstein's home? 
A. Yes. 
Q. How much? 
A. 200. 
Q. Okay. And when F.E. came down, did she give 
Mr. Epstein a massage? 
A. Yes. 
Q. Did she ever say anything inappropriate 
happened during the course of the massage? 
A. No. 
Q. And you took ■ 
and she came, did she give 
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Page 128 
- - - 
INDEX 
WITNESS: 
DIRECT CROSS REDIRECT RECROSS 
Jane Doe N7 
By Mr. Critton 
5 
EXHIBITS 
EXHIBIT 
Defendants 1 
Defendants 2 
Defendant's 3 
Defendant's 4 
Defendant's 5 
Defendant's 6 
Defendant's 7 
Defendants 8 
Defendant's 9 
PAGE 
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Page 130 
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Mr. Epstein a massage? 
2 
A. Yes. 
3 
Q. Did she ever tell you anything inappropriate 
4 
had happened? 
A. We never really talked about it. 
6 
Q. Did you ask them? 
A. No. 
8 
Q. If you talk someone to Mr. Epstein's home to 
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have them give him a massage so they could earn money 
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and you could earn money, did you interpret what you 
11. 
were doing was the same thing in essence that M. was 
12 
doing? 
13 
MR. HOROWITZ; Form. 
14 
THE WITNESS: No. 
15 
BY MR CRITTON: 
16 
Q. Why was it different, in your mind? 
17 
A. Because they wanted to go, and we were all 
18 
just kind of brainwashed by him. And at the time I knew 
19 
it was wrong, but I didn't know how it would affect them 
20 
or affect me in the fixture. And I was just confused by 
21 
everything at that time. 
22 
Q. You knew it was wrong, so what's confusing 
23 
about that? 
24 
A. I felt like it was wrong, but I, I just 
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thought it was -- I was just confused, and I just didn't 
•t
 
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know how much it would affect me in the future and, you 
know, what kind of effects it would have on them. And, 
you know, that's why I feel bad about it now, but at the 
time I was confused and I didn't know. 
Q. Wellj _
let me ask you this. Have you ever 
talked with El about her experience with Mr. Epstein, 
ever? 
A. No. She is in now. 
I don't know, we 
don't really talk. 
Q. What's she doing in 
now? 
A. She lives there now with her sister. 
Q. IIII? 
A. Yeah. 
Q. Is her mom
? 
A. Yes. 
Q. Herded? 
A. Yes. 
Q. So they are all a. 
Why did they go 
back to a, 
if you know? 
A. Because their green card etd. 
Q. Let me ask you again. Did 
ever tell you 
anything bad happened at Mr. Epstein's, or 
inappropriate? 
A. I don't remember. 
Q. So at least — did you only take her the one 
Page 133 
1 
Q. But at least as you sit here today, you can't 
2 
remember anything unusual about her coming down from 
3 
giving Mr. Epstein a massage; would that be a fair 
4 
statement? 
5 
A. I mean yeah, I don't remember. 
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Q. Same thing with F.E., you don't remember 
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anything that stands out in your mind when she came 
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downstairs because you were in the kitchen, right? 
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A. Yeah. 
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Q. Do you remember anything unusual or did she 
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say anything or did she react or have any appearance —
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strike that. 
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Did F.E. either say anything that caused you 
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any concern or did you observe any facial features or 
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anything that she did or the way she acted that would 
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have caused you any concern that you can remember today? 
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A. Not that I can remember. 
18 
Q. Those are the only two people you ever took to 
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Mr. Epstein's? 
20 
A. Yes. 
21 
Q. You went down and had an interview or an 
22 
evaluation by Dr. Kliman, who was the psychiatrist who 
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had been hired from San Francisco to evaluate his 
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clients, including you, correct? 
25 
A. Yes. 
Page 132 
1 
time? 
2 
A. Yes. 
3 
Q. Do you know whether she ever went another 
4 
time? 
5 
A. I don't know. 
6 
Q. All right. But when she came down from giving 
7 
Mr. Epstein a massage, she seemed to be in good spirits, 
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didn't say anything bad had happened; fair? 
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A. She didn't really talk about it. 
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Q. Did she appear to be upset in any way? 
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A. I don't, I don't remember. 
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Q. If she had been upset, that's something you 
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generally would remember, wouldn't you, if she was upset 
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or emotional about it? 
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A. It was so long ago, I just remember taking her 
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there. I don't remember how she reacted or what 
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happened. 
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Q. Did you drive her in your car? You were the 
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transporter? 
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A. I don't remember. 
21 
Q. Was El able to drive at the time? 
22 
A. Yes. 
23 
Q. But you went with her, so either she drove or 
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you drove? 
25 
A. Yes. 
Page 1 
1. 
Q. And you had to fly down from Orlando, true? 
2 
A. Yes. 
3 
Q. Do you remember telling Jane Doe 4 about your 
4 
eicpadence for the evaluation with Dr. Kliman? 
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A. Yes. 
6 
Q. And do you remember telling her that you were 
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supposed to cry a lot and be very emotional during the 
8 
course of the —
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A. No, I never —
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Q. I need to finish the question, ma'am. 
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isn't it true you told Jane Doe 4 that you 
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cried a lot during the interview and tried to be very 
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emotional, because that's what you were supposed to do? 
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A. No. 
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Q. So if you told Jane Doe 4 that, or 'Ilene 
16 
Doe 4 has said that to anyone, that would be a lie? 
17 
A. Yes. 
18 
MR. HOROWITZ: Form. 
19 
BY MR. CRITTON: 
20 
Q. If I use the term crocodile tear, does that 
21 
mean anything to you? Do you know what a crocodile tear 
22 
is? 
23 
A. Yes. 
24 
Q. What is It? 
25 
A. When somebody fake cries. 
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Q. Let me go back to when Jane Doe 4 was living 
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with you this last summer, or I'm sorry, the summer of 
3 
'08 and she told you that she had filed a suit against 
4 
Mr. Epstein. 
5 
As of that date, were you aware of anyone else 
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who had filed suits against Mr. Epstein? 
7 
A. No. 
8 
Q. As you sit here today, other than yourself and 
9 
Jane Doe 4, are you aware of any other plaintiffs or 
10 
individuals who are plaintiffs in lawsuits against 
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Mr. Epstein? 
12 
A. Yes. 
13 
Q Who? 
14 
A. Jane Doe 3. 
15 
Q. Flow do you know 
is a plaintiff in a 
16 
lawsuit? 
17 
A. Because she is my friend and she told me. 
18 
Q. And that's Jane Doe 3? 
19 
A. Yes. 
20 
Q. Were you aware or has Jane Doe 3 told you 
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whether she has given a deposition? 
22 
A. Yes. 
23 
Q. Okay. What did she say about it? 
24 
A. She said that you looked exactly like Jeffrey 
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Epstein. 
Page 137 
1 
Mr. Epstein's home? 
2 
A. No. 
3 
Q. Did she ever talk to you about what occurred 
4 
or what she alleges occurred at Mr. Epstein's home? 
5 
A. No. 
6 
Q. All right. Are you aware of anyone else other 
7 
than Jane Doe 3 and Jane Doe 4 who are plaintiffs? 
8 
A. Just N.R. 
9 
. And who is she? Again, a student at 
10 
with you all? 
11 
A. Yes 
12 
Q. Same grade? 
13 
A. She's a grade ahead of me. 
14 
Q. And did she tell you that she's a plaintiff in 
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a lawsuit? 
16 
A. No, we were just talking about it and somehow 
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she found out that I had a lawsuit and was asking me 
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about it and she said that she had one, and that's all. 
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Q. Did she tell you who her lawyer was? 
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A. No. 
21. 
Q. Did she — when did you last talk to N.R. —
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let me start again. 
23 
When did you have this conversation with N.R. 
24 
about the lawsuit? 
25 
A. I believe it was over Christmas break, I 
Page 136 
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Q. Did she tell you how nice and polite I was and 
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reasonable? 
3 
A. Yes. 
4 
Q. Good. 
5 
MR. HOROWITZ: She did? 
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THE WITNESS: No. 
7 
BY MR. CRITTON: 
8 
Q. I'm taking that as the truth. 
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A. That's a joke. 
10 
Q. All right. You don't think I look like 
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Mr. Epstein, do you? 
12 
A. Yes, kind of. 
13 
Q. I think that's just, l think that's the big 
14 
pitch, so you all can make that pitch at trial. It's a 
15 
nice touch, but I'm not moved by it. 
16 
MR. HOROWITZ: Mow to strike. 
17 
BY MR. CRITION: 
18 
Q. What else did Jane Doe 3 tell you about her 
19 
deposition? 
20 
A. She didn't really tell me anything about it. 
21 
She just basically said she came in here and did it. 
22 
Q. Were you aware that she had been at 
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Mr. Epstein's home during the time she was going? 
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A. I don't remember. 
25 
Q. Do you know how she came to be at 
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think. 
Q. Christmas —
A. I don't know, I was home like on break I 
don't know if it was Christmas break or not. 
Q. Well -
A. I was just, like I come home a lot to visit my 
parents. 
Q. Are you still in school right now? 
A. Yes. 
Q. So when was the last time you were home, 
Christmas before now? 
A. No, I came home recently to visit them, like 
last month. 
Q Was that when you talked to N.R.? 
A. I think so. 
Q. So it would have been approximately February 
of 2010? 
A. Yes. 
Q. And was she at your house or did you see her 
at a bar or were you out at a club or — 
A. I forget where I saw her. I ran into her --
oh, we were at Duffy's. We all went --
Q. Which Duffy's? 
A. 
to dinner. On Northlake. 
Q. RIM near I-95? 
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A. Yes. 
2 
Q. Who was there other than you and N.R.? 
3 
A. Just some friends from high school. 
4 
Q. Any other people that you know? Was Jane 
5 
Doe 4 there? 
6 
A. No, Jane Doe 4 wasn't there. 
7 
Q. Jane Doe 3, was she there? 
A. No. 
9 
Q. Anyone else that you know, any of the other 
10 
people you knew went to Mr. Epstein's home? 
11 
A. No. 
12 
Q. And N.R. said that she was going to file or 
13 
she was a plaintiff also in a lawsuit? 
14 
A. Yes. 
15 
Q. How did she know that you were a plaintiff? 
16 
A. I don't know who told hen 
17 
Q. Were you upset that she knew? 
18 
A. I mean she was one of my good friends in high 
19 
school and she kind of knew what happened, because I 
20 
told her before. So I, she kind of already knew, so I 
21 
wasn't that upset that she knew about that. 
22 
Q. What do you mean you told her about? 
23 
A. I mean she knew about me and Jane Doe 4 going 
24 
there. She went there before, so —
25 
Q. Oh, she had gone there before you? 
1 
A. Well, yeah. She — yeah. 
2 
Q. Okay. How does she know? 
3 
A. Because you guys asked her questions about me, 
4 
and Pm sure she assumed I was a plaintiff suing 
5 
Jeffrey. 
6 
Q. How about your friend El does she know that 
7 
you have brought a lawsuit? 
8 
MR. HOROWITZ: Form. 
9 
THE WITNESS: I'm sure E. told her. 
10 
BY MR. CRITTON: 
11 
Q. Why would.. tell her? 
12 
MR. HOROWITZ: Fenn. 
13 
THE WITNESS: Because they are friends. 
14 
BY MR. CRITTON: 
15 
Q. How do you know El Fuld N. are friends? 
16 
A. Because that's what I have heard. 
17 
Q. When is the last time you talked to 
18 
A. Right around her brother's accident. 
19 
Q. Okay. 
20 
A. So probably, I don't know, like seven months 
21 
ago. 
22 
Q. That's the last time you have spoken with her? 
23 
A. Yes. 
24 
Q. Have you tried to call her or she tried to 
25 
contact you at all? 
Page 140 
1 
A. No. I don't, I don't remember when she had 
2 
gone. She went sometime in high school. 
3 
Q. Did she ever tell you about her experience of 
4 
going to Mr. Epstein's home? 
A. No. I just !mew she went. 
6 
Q. Do you know how many times she went? 
A. No. 
8 
Q. Did you say "Why are you filing a lawsuit? 
9 
A. No. 
10 
Q. So you don't know whether she has — strike 
11 
that. 
12 
You don't know anything about her lawsuit 
13 
other than she has filed a lawsuit against Mr. Epstein? 
14 
A. Yes. 
15 
Q. So you mentioned N.R., Jane Doe 3, Jane Doe 4. 
16 
Anyone else that you are aware that was a 
17 
plaintiff'? 
18 
A. No. 
19 
Q. Who have you told that you area plaintiff in 
20 
a lawsuit? 
21 
A. Just those girls. 
22 
Q. So nobody else knows that you are a plaintiff? 
23 
A. No. 
24 
Q. How about il.? Does 
know you are a 
25 
plaintiff? 
Page 142 
1 
A. Not recently. I don't think so. 
2 
Q. After you said — around the time of her 
3 
brother's accident, since that time, have you tried to 
4 
call her at all? Or seven months ago was the last time 
5 
you had any contact with her? 
6 
A. Yeah. 
7 
Q. Okay. At the time that Jane Doe 4 told you 
8 
that in the summer of '08 that she was bringing a 
9 
lawsuit against Mr. Epstein or had brought a lawsuit 
10 
against Mr. Epstein, had you contacted an attorney at 
11 
that point? 
12 
A. I don't remember. 
13 
Q. Affright. Who was the first — strike that. 
14 
Was it you or your parents who encouraged you 
15 
to bring a lawsuit? 
16 
MR. HOROWITZ: Form. 
17 
THE WITNESS: It was me. 
18 
BY MR. CANTON: 
19 
Q. So your parents had nothing to do with you 
20 
bringing a lawsuit? 
21 
A. No. 
22 
Q. Are your parents aware now, were they aware at 
23 
the time you hired a lawyer? 
24 
A. Yes, I told them. 
25 
Q. Did you hire a lawyer before you told your 
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parents or were they involved in the decision? 
2 
A. No, I told than after. 
3 
Q. And who did you contact — strike that. 
4 
How did you — you know obviously Mr. Horowitz 
is seated immediately to your left, tweet? 
6 
A. Yes. 
7 
Q. Is he the fast lawyer you met from that firm? 
3 
A. No. I met with Jeffrey Herman. 
9 
Q. How did you get in contact with Mr. Herman? 
10 
A. He called me. 
11 
Q. He called you? 
12 
A. Yes. 
13 
Q. And where did he call you from? 
14 
A. I don't know. 
15 
Q. Was it before or after Jane Doe 4 told you 
16 
that she was a plaintiff in a lawsuit? 
1'7 
A. 'think it was before. 
18 
Q. All right. So at the time that Jane Doe 4 
19 
told you she was a plaintiff in a lawsuit, had you 
20 
already spoken with Mr. Herman? 
21 
MR. HOROWITZ: Form. 
22 
BY MR. CRITTON: 
23 
Q. Or did that occur after you spoke with Jane 
24 
Doe 4? 
25 
A. I don't know who had, who did it first. I 
Page 145 
1 
Mr. Herniae 
2 
A. I don't, I don't remember when it was, but I 
3 
just net, just met with him and I —
4 
MR. HOROWITZ: Fm going to ask you not to 
5 
discuss what --
6 
MR. CRITTON: Just dealing with the time 
7 
sequence. Don't tell me what he said right now. 
8 
not there yet 
9 
MR. HOROWITZ: There you go. 
10 
BY MR. CRITTON: 
11 
Q. So if I understand the sequence correctly, you 
12 
got a phone call out of the blue from Mr. Heenan about 
13 
Jeffrey Epstein. 
14 
A. Yes. 
15 
Q. All right. You spoke with him, and he asked 
16 
you a number of questions, right? 
17 
A. All he really asked me was if I, if l was 
18 
involved with Jeffrey Epstein, If I was a witness or 
19 
if— I can't temember exactly what he asked me. 
20 
Q. I'm going to come back to that in just a 
21 
minute. Let me get the time sequence here if 1 can, Ms. 
22 
Jane Doe 7. 
23 
First time he called you, he called you, you 
24 
talked to him a little bit and you gave him the name of 
25 
Jane Doe 4? 
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1 
think it was me. I don't really know. I don't 
2 
remember. 
3 
Q. I'll represent that Jane Doe 4, Jane Doe 4's 
4 
lawsuit was filed well before yours. She's Jane Doe 4. 
5 
A. Yes. 
6 
Q. You are Jane Doe 7. Doesn't necessarily mean 
7 
one came, hired the lawyer earlier or not, but 1 can 
8 
tell you her lawsuit was filed months before yours was. 
9 
A. He called me originally at first, and then he 
10 
asked me if I lotew any witnesses or anything, and I 
11 
think I game him Jane Doe 4's number, but I never agreed 
12 
to start a lawsuit until later on. 
13 
Q. So when Mr. Herman called you, you gave him 
14 
Jane Doe 4 — he called you about being a witness? 
15 
A. I believe so. 
16 
Q. All right. And did you talk to him? 
17 
A. Yes. 
18 
Q. Over the phone or in person? 
19 
A. Over the phone. 
20 
Q. And then you gave him the name of other 
21 
individuals? 
22 
A. Just Jane Doe 4, I think. 
23 
Q. And then sometime after you met with or Jane 
24 
Doe 4 was living with you in the summer, then did you 
25 
subsequently speak with him again, him meaning 
Page 146 
1 
A. Yes. 
2 
Q. Okay. And then sometime later you called him 
3 
or did he call you back? 
4 
A. I called him. 
5 
Q. How much time transpired between the first 
6 
call that he made and the second call that you made? 
7 
A. I don't know. 
8 
Q. Was it a week? Was it a month? Was it 
9 
months? 
10 
A. I don't remember how long it was. 
11 
Q. Okay. On the first conversation that you had, 
12 
how long did that conversation last? 
13 
A. Just like five minutes. 
14 
Q. Did he tell you he was representing anyone? 
15 
A. No. 
16 
Q. Did you ask him how he got your name? 
17 
A. No. I didn't know — the first time he 
18 
called, I didn't I was kind of really, I didn't know 
19 
who was who and who was representing who. So I was, 
20 
just kind of told him that I would take his number and I 
21 
would think about it and call him back. 
22 
Q. Okay. Well, think about what? 
23 
A. Well he asked me if we wanted to meet. And I 
24 
told him that I would think about it and call him back. 
2 5 
Q. Was he pitching basically I could represent 
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you in the case? 
2 
A. No. He just asked me if I knew about Jeffrey 
3 
and witnessed what happened with Jeffrey, and that's 
4 
about it. And he asked me if we wanted to meet and 
5 
talk. And I said that I wasn't sure, you know, because 
6 
I've had private detectives corning. 
And I wasn't sure who was on whose side, so I 
. 
told him that I would call him back. 
Q. Was he soliciting or pitching his services to 
you as a lawyer? 
MR. HOROWITZ: Form. 
THE WITNESS: No. 
BY MR. CRITPON: 
Q. Well, why did he want to meet with you? 
MR. HOROWITZ: Form. 
BY MR. CRITTON: 
Q. What did he tell you? 
A. He Just wanted to talk about the whole Jeffrey 
thing with me. 
Q. Why would you want to talk with him about it? 
MR HOROWITZ: Form. 
THE WITNESS: Because I heard that, you know, 
there's like stuff going on with, with people, so I 
kind of wanted to protect myself. 
1 
BY MR. CRITION: 
2 
Q. Why did she call you? 
3 
MR. HOROWITZ: Forni 
4 
THE WITNESS: She called me m fill me in on 
5 
the case, and I knew she was like who she said she 
6 
was, because Agent 
at the FBI told me she 
7 
would be calling me. She pretty much told me what 
8 
was going on in his criminal case, and that's about 
9 
it. And she said you might want to protect 
10 
yourself and get a lawyer, and that's about it. 
11 
BY MIL CIRITTON: 
12 
Q. Okay. Did she recommend anybody, any lawyers? 
13 
A. I don't remember. 
14 
Q. Do you remember her giving you any names of a 
15 • 
lawyer saying 'Tm going it give you three names," or 
16 
"If you need some help finding a lawyer, I'll give you a 
17 
name'? 
18 
A. She said if I wanted a lawyer, to call back. 
19 
And she had a list, I think, but she didn't recommend 
20 
anybody. 
21 
Q. Did you ever call her back for her 
22 
recommendation? 
23 
A. No. I talked to Agent 
about it, and 
24 
she said basically what I was supposed to do. And she 
25 
said it was up to me basically if I wanted to hire a 
2 
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Page 148 
BY MR. CRITTON: 
Q. What did you hear was going on with people? 
A. Nothing. I just heard that, it was when —I 
forget who called me and said — I think it was Maria or 
something. She said, you know, to protect yourself, you 
might want to get a lawyer. 
Q. Who is Maria, MIME
)
A. I think so. 
Q. Was that the US attorney? 
A. Yes. 
Q. And had you ever met with IM 
A. No. 
Q. You never met the lady? 
A. No. 
Q. So somebody who you just referred to as 
calls you out of the blue. Why would —
A. She--
Q. Let me finish my question. 
You said you 
let me ask you this. Did the 
ady, who you have now identified as 
assistant US attorney, did she call you 
before Mr. Hemian or after Mr. Heiman? 
MR. HOROWITZ: Form. 
THE WITNESS: Before. 
(561) 832-7500 
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Page 150 
lawyer or not. 
Q. Did Agent 
give you any names? 
A. No. 
Q. Did anyone from the FBI or US attorney's 
office ever give you a name of a lawyer —
A. No. 
Q. — to contact? 
A. No. 
Q. Did you speak with — let mat back. 
When you spoke with Ms. 
that before or after Mr. Herman contacted you? 
A. It was before. 
Q. And then how much time transpired or rested 
before Mr. Herman contacted you about whether you were 
involved or to ask you questions about Jeffrey Epstein? 
A. About a couple of months. 
Q. And do you know when Mr. Herman approximately 
timewise called you? 
A. No. 
Q. Was it before Jane Doe 4 moved in with you 
that sununer? 
A. Yes. 
Q. Was it shortly aver the 
contacted you? 
A. No. It was a little while after that. 
police had 
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Q. Was it after the FBI interview? 
2 
A. Yes. 
3 
Q. Do you know when the FBI interview took pi 
4 
A. I third( I was a sophomore in college or 
5 
maybe --
6 
Q. That's '05, that would have been --
7 
A. I think I was a sophomore or freshman. 
8 
Q. So that would have been what, approximately 
9 
'07? 
10 
A. Yes. 
11 
Q. Let me just stick with — so when Mr. Haman 
12 
called you the first time, did he say what he was doing? 
13 
He obviously wanted to get some information about 
14 
Jeffrey Epstein and you, right? 
15 
MR. HOROWITZ: Form. 
16 
THE WITNESS: It didn't sound like it. 
17 
BY MR. CAI-ETON: 
18 
Q. Did you say "How did you get my name?" 
19 
A. No. 
20 
• Q. Were you surprised that sane lawyer out of the 
21 
blue called you to ask you about Jeffrey Epstein and you 
22 
didn't know who they were a how they had gotten your 
23 
,me? 
24 
A. I thought — I had no idea. That's why I 
25 
didn't agree to meet with him at first, because I didn't 
Page 153 i 
Q. Okay. And did you investigate him at all? 
2 
A, Yes. 
3 
Q. Did you go online? 
4 
A. !looked his name up. 
5 
Q. Where? 
6 
A. Online. 
7 
Q. And what did you find out? 
8 
A. That he was a sexual abuse attorney. 
9 
Q. And did you ask him before you hired him 
10 
whether he was representing any other people associated 
11 
with the Epstein matter? 
12 
A. No. 
13 
Q. When you called him back and before you hired 
14 
him, did you ask him how he ever got your name? 
15 
A. No. 
16 
MR. HOROWITZ: 
going to assert the 
17 
privilege. I understand what you're trying to do, 
18 
but I'm going to assert the privilege as to the 
19 
conversation in that the entire conversation was 
20 
leading towards the result of obtaining a lawyer. 
21 
So that's my position, and we can --
22 
BY MR. CRITTON: 
23 
Q. Are you going to follow your lawyer's — if he 
24 
tells you — if he claims a privilege, are you asserting 
25 
that privilege? 
Page 152 
1 
know if he was, you know, on your side or their side or 
2 
hying to check me or whatever, so that's why I waited a 
3 
little bit to call him back. 
4 
Q. When you did call him back, however much time 
5 
transpired, what did you say to him? 
6 
MR. HOROWITZ: We're going to assert the 
7 
privilege on that, but you can make the proffer. 
8 
BY MR. CRITTON: 
9 
Q. You called him back, correct? 
10 
A. Yes. 
11 
Q. Okay. All you knew, he was a lawyer? 
12 
A. Yes. 
13 
Q. You didn't know who he represented? 
14 
A. No. 
15 
Q. If anyone? 
16 
A. No. 
17 
Q. Okay. He could have been Mr. Epstein's 
18 
lawyer, he could have been anybody's lawyer, for all you 
19 
'mew, right? 
20 
A. I mean he told me he —10ce no, I think he 
. 
21 
told me he wasn't — he was like representing — I don't 
22 
know, he didn't say -- I don't know. I don't remember 
23 
why I actually called him back. 
24 
. 
Q. Why did you call him back? 
25 
A. Because I wanted to hear what he had to say. 
Page 154 
1 
A. Yes. 
2 
MR. HOROWITZ: Yes. I just want to tell her 
3 
what I'm invoking. 
4 
As to this second telephone conversation, I'm 
5 
instructing you that you have a privilege not to 
6 
answer questions about the second conversation. 
7 
THE WITNESS: Okay. 
8 
BY MR. CRITTON: 
9 
Q. Did you hire Mr. Herman in the course of the 
10 
second conversation? lust yes or no. 
11 
A. He came to Orlando and we met and then --
12 
Q. No, no. Well get there. 
13 
In the second conversation, did you say "I 
14 
want to hire you" or did you just say --
15 
A. No. 
16 
Q. — "I'd lilte to meet with you"? 
17 
A. "I'd like to meet with you." 
18 
Q. Okay. So how long did the second conversation 
19 
last? 
20 
A Not long. 
21 • 
Q. • Five 'minutes? 
22 
A. Just about. 
23 
Q. What did you tell him? 
24 
MR. HOROWITZ: I'll instruct her not to 
25 
answer. Well assert the privilege, a privilege, 
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the attorney/client privilege. 
MR. CRiTFON: I understand. 
3 
BY MR. CRITTON: 
4 
Q. And you are going to follow his direction, 
5 
correct? 
6 
A. Yes. 
Q. And until Mr. Herman came to Orlando -- strike 
that. 
9 
How much time passed between the second 
10 
conversation and Mr. Herman came to Orlando? 
11 
A. Not long. Maybe a couple weeks. 
12 
Q. Did anyone else come up with Mr. Herman to 
13 
meet with you? 
14 
A. No. 
15 
Q. Just you and Mr. Herman met? 
16 
A. Yes. 
17 
Q. Where did you meet? 
18 
A. At Starbuck's. 
19 
Q. Okay. And did you sign an agreement then to 
20 
have him represent you? 
21 
A. After lmet with him and heard everything he 
22 
said, yes, I did. 
23 
Q. Okay. Before that, that is, before you 
24 
actually hired him, bad you discussed with him what had 
25 
happened to you, that is — well, let me strike that. 
Page 157 
I. 
everybody and her parents fording out and her sister 
2 
finding out and her being depressed and humiliated, I 
3 
mean yeah, I would assume that's some trauma for her. 
4 
Q. Okay. Has she told you she's depressed? 
5 
A. Yeah, and when she found, her parents found 
6 
out and all that, she was depressed, she told me. 
7 
Q. The way you've described it is Jane Doe 4's 
8 
main emotional or psychological — let me strike that. 
9 
Her main psychological injury from at least 
10 
the way you've described it is she's been humiliated and 
11 
depressed because somebody other than her friends, in 
12 
particular, her parents and her sister, found out that 
13 
she had gone to Mr. Epstein's house? 
14 
A. Not from that. From just going when she was 
15 
younger. She regrets it, and she even told me i wish I 
16 
never went when I was younger. i was confused and --
17 
Q. She — fm sorry. 
18 
A. Go ahead. 
19 
Q. Did she tell you that she went — well, you 
20 
!mew she went both before she was 18 and after she was 
21 
18, right? 
22 
A. Yeah, l guess. 
23 
Q. All right. And did she tell you she was more 
24 
confined when she was 17 than when she was 18, or did 
.25 
she ever describe to you that there was a difference 
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Page 156 
In the second conversation did you give him 
any information as a witness as distinct from your own 
personal circumstances? 
MR. HOROWITZ: i have to assert the privilege. 
BY MR. CRITTON: 
Q. And you are going to follow his direction? 
MR. HOROWITZ: Yes. Good try. 
MR. CRITTON: That's not a good try. Just --
BY MR. CRITTON: 
Q. Has Jane Doe 4 told you — let me strike that. 
I'd ask you to assume that she's brought the 
same S50 million lawsuit that you have, different facts, 
but she wants 50 million bucks too, at least in her 
complaint that she's asserted against Mr. Epstein. 
Did she ever tell you any injuries or damages 
that she ever sustained as a result of being at 
Mr. Epstein's home? Has she ever said anything to you 
about it? 
A. We never really talked about her. 
Q. Even through today's date, she's never told 
you any damages or how she was damaged or any injuries, 
psychological or otherwise, that she ever sustained at 
Mr. Epstein's house; is that correct? 
She's never discussed that with you? 
A. I mean other than being humiliated by 
Page 158 
1 
when she went at 17 or 18? 
2 
A. I don't know. She never described anything to 
3 
me. 
4 
Q. Did she ever say "Gees, the day I turned 18 
5 
and was a freshman at college, i still went to see 
6 
Mr. Epstein"? 
7 
A. No. 
8 
Q. Okay. Did she ever say, "Well, gee, just 
9 
before I turned 18, i had these emotional injuries, but 
10 
at 18 everything was okay when I went to Mr. Epstein's'"? 
11. 
Did she ever say that to you? 
12 
MR. HOROWITZ:. Fa 
13 
THE WITNESS: No. 
14 
BY MR. CRITTON: 
15 
Q. All right. Did she ever distinguish to you 
16 
having been to Mr. Epstein's before she was 18 or after 
17 
she was 18; that is, that any time period was different 
18 
for her? 
19 
A. I don't remember. 
20 
Q. You don't remember her telling you that, 
21 
correct? 
22 
A. No -- yes. I don't remember her telling me. 
23 
Q. All right, I understand. 
24 
Now you've known Jane Doe 4 for a long time? 
25 
A. Yes. 
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Page 161 
1 
Q. Since '02, I think you told me. 
2 
She's been through some rather traumatic 
3 
events in her life, has she not? 
4 
A. I guess you could say that. 
5 
Q. Well, you know she's been arrested before? 
6 
A. Yes, when we were younger. 
7 
Q. Pardon? 
8 
A. When we were younger. 
9 
ri I. And she haditliend named 
10 
You knew 
didn't you? 
11 
A. Yes. 
12 
Q. What did you think of_? 
Pretty 
13 
upstanding, great guy? 
14 
A. No. 
15 
Q. Okay. He was a jerk, wasn't he? 
16 
A. Yeah. 
17 
Q Pardon? 
18 
A. Yes. 
19 
Q. And 
beat Jane Doe 4, didn't he? 
20 
Physically abused her? 
21 
A. I mean he pushed her. He didn't beat her up, 
22 
but yes, he pushed her before. 
23 
Q. Did you ever see him slam her face down into 
24 
the hood of the car, into the dashboard of a car? 
25 
A. No. 
1 
BY MR. CRITTON: 
2 
Q. Did you ever hear him call her a-? 
3 
A. No. 
4 
Q. What kind of things did you hear 
5 
to her to verbally abuse her? 
6 
A. Just bitch, and I don'ttellkAlrber. We were in 
7 
high school. Just, I mean I never heard him call her a 
8 
whore or anything else you said. 
9 
Q. Fm sorry? 
10 
A. I said or anything else you said. 
11 
Q. But you were aware that he was both physically 
12 
and verbally abusive to her? 
13 
A. Yes. 
14 
Q. All right. And did you ever tell Jane Doe 4 
15 
`You got to get away from this guy, he's bad news"? 
16 
A. Yes. 
17 
Q. What was her reaction? 
18 
A. She was in love. So she didn't really -- 
19 
Q. And she carried oniacal, a long-term 
20 
physical relationship with
did she not? 
21 
A. Yes. 
22 
(*.you ever, were you ever aware whether she 
23 
and
were pregnant? 
24 
MR. HOROWITZ: Form. 
25 
THE WITNESS: No. 
say 
1 
2 
3 
4 
5 
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7 
8 
9 
10 
11 
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13 
14 
15 
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Page 160 
MR. HOROWITZ: Form. 
BY MR. CRITTON: 
Q. Are you aware, did she ever tell you that that 
happened? 
A. No. 
Q. Did you see 
spitting on her? 
A. No. 
Q. Did you see her spitting back at 
A. No. 
Q. Were you aware that had occurred? 
A. No. 
Q. Were you aware 
was a drug addict? 
A. Yes. 
Q. Were you aware that he was an alcoholic? 
MR. HOROWITZ: Form. 
THE WITNESS: Yes. 
BY MR. CRITTON: 
Q. You were around when he verbally abused her 
and called her awful names, weren't you? 
A. One or two times. 
Q. Okay. Did you ever hear him refer to her as a 
whore? 
MR. HOROWITZ: Form. 
THE WITNESS: No. 
Page 162 
1 
MR. HOROWITZ: I bow what you mean. 
2 
BY MR. CRITTON: 
3 
Q. Of coarse he can't 
but are you aware that 
4 
she became pregnant with
? 
5 
A. Yes. 
6 
Q. Did she tell you that? 
7 
A. Yes. 
8 
Q. On how many occasions did Jane Doe 4 disclose 
9 
to you that she had become pregnant within 
10 
MIL HOROWITZ: Form. 
11 
THE WITNESS: Just once. 
12 
BY MR. CRITTON: 
13 
Q. Okay. She never told you — so let me strike 
14 
that. Are 
aware that she became pregnant, even if 
15 
not with ME, on two other occasions? 
16 
MR. HOROWITZ: Object to the form, and let me 
17 
just, I have to say this. You are potentially 
18 
disclosing very intimate personal medical 
19 
information about one person to another, and I 
20 
think you are touching on some boundaries that you 
21 
shouldn't be going on, but go ahead. 
22 
BY M. CRITTON: 
23 
Q. Do you want the question back? 
24. 
A.. No. 
25 
Q. No what? That was your answer? 
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Page 163 
1 
A. I don't want the question back. 
2 
Q. Do you remember the question? 
3 
A. Yes. 
Q. Okay. I don't. 
3 
(A portion of the record was read by the 
reporter.) 
MR. HOROWITZ: Form. 
THE WITNESS: I don't think that we should 
really be talking about her details, intimate 
details. 
BY MR. CRITTON: 
Q. Can you answer my question? 
MR. HOROWITZ: Just answer what you know. 
THE WITNESS: I just told you I know once what 
happened. 
BY MR. CRITTON: 
Q. That's all you know, that she became pregnant? 
A. Yes. 
Q. Did she tell you how the pregnancy was 
terminated? 
A. Abortion. 
Q. Was she pretty upset about that? 
A. Yes. 
Q. What kind of drugs did 
take? Was he a 
seller? Let me strike this. 
1 
2 
3 
4 
5 
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7 
8 
9 
10 
11 
12 
13 
14 
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Page 161: 
Q. So at least in high school, you're saying that 
you drank alcohol, right? 
A. Yes. 
Q. Even though you were underaged? 
A. Yes. 
Q. And did you use pot? 
A. No, not in high school. 
Q. Never? 
A. No. 
Q. Okay. Did you ever use any other type of 
illegal drugs? 
A. No. 
Q. Any prescription drugs from someone else, like 
a XBIKax or percocet or —
MR. HOROWITZ: Talking about high school? 
MR. CRITTON: High school. 
THE WITNESS: No. 
BY MR. CRITTON: 
Q. Since high school, you have continued to 
drink? 
A. Yes. 
Q. And I've seen both in the Kliman report is you 
continue to drink alcohol, sometimes you will drink to 
excess? 
A. Yes. 
Page 164 
1 
Was 
also selling drugs? 
A. I don't know. 
Q..liou ever see Jane Doe 4 use illegal drugs 
with 
A. No. Just drink. 
6 
Q. Okay. So you guys are best friends and - 
7 
A. She would never do it in front of me, because 
8 
I don't do it in front of her or I would never do 
9 
anything in front of her. 
10 
Q. If you do drugs, you don't do them in front of 
11 
her. 
12 
A. Well, she knows — sorry, I didn't mean to say 
13 
that. She knows I don't do drugs, so if she ever did 
14 
drugs, she would never do it in front of me, because she 
15 
know I was really against that in high school. 
16 
I was good. The most I would — like I drank, 
17 
but so if she had ever done drugs with him, she wouldn't 
18 
have done it in front of me. She would just drink. 
19 
Q. So if she's used Xanax and she's used pot and 
20 
she's used ecstasy and if she's used cocaine, any other 
21 
drugs, that would be news to you? 
22 
A. I mean I know she did like some of that. I'm 
23 
not going to — whatever. But I, but she wouldn't do it 
24 
in front of me, because she knew that I wasn't like 
25 
that. 
Page 166 
1 
Q. All right. And as well, you have used pot? 
2 
A. Yes. 
3 
Q. Since high school. How often do you use 
4 
marijuana? 
5 
A. I have, hardly ever. 
6 
Q. Xanax, have you had Xanax? 
7 
A. No. 
8 
Q. Have you ever tried cocaine? 
9 
A. Na 
10 
Q. Never? So if someone says that you have used 
11 
cocaine and they have seen you, that would be a lie? 
12 
MR. HOROWITZ: Form. 
13 
THE WITNESS: I don't ever remember doing —1 
14 
don't do drugs at all. 
15 
BY MR. CRITTON: 
16 
Q. My question is if someone says they have seen 
17 
you do coke, that would be a lie? 
18 
MR. HOROWITZ: Form. 
19 
BY MR. CRITTON: 
20 
Q. Or is it possible you did do coke and you just 
21 
don't remember? 
22 
A. I ?neon I might have tried it once, but I don't 
23 
do coke atoll, so 
24 
Q. Would the same thing be true of Xanax, that if 
25 
someone said they had seen you take Xanax, you may have 
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Page 167 
tried it once or twice, but you don't do it regularly? 
A. That would have a lie. I don't do Xanax. 
Q. You've never done it? 
A. No, I don't do prescription chugs. Only thing 
I have ever done is Adderall. 
Q. Did you get that from friends? 
A. Yes. 
Q. Let me go to the FBI for just a minute. When 
did the FBI contact you? 
A. I believe it was my freshman year of college, 
I think. 
Q. Let's see, that would have been the '05-'06 
school year? 
A. Yes. 
Q. And now you were at EM? 
A. Yes. 
Q. And that's in Orlando. Is that a community 
college? 
A. Yes. 
Q. I asked two questions there. It's an Orlando 
community college, correct? 
A. Yes. 
..And did you get, did you graduate from 
A. Yes, I did. 
Page 169 
1 
finished in May of '09, correct? 
2 
A. Yes. 
3 
Q. But you are still there right now? 
4 
A. Yes. 
5 
Q. And why are you in your fifth year? 
6 
A. Because Pm getting a minor too. 
7 
Q. Whalwasot
or? 
8
A. 
9 
Q. Wh
.ik
ur minor? 
10
A. 
11 
Q. 
12 
A. 
13 
Q. 
14 
get the courses that you want, you had to be there an 
15 
extra year? 
16 
A. Yeah, about. I mean I could really finish 
17 
this semester, but I wanted to study abroad for the 
18 
hospitality trip in the summer, so I'm just waiting for 
19 
that and then I'm graduating in the summer. 
20 
Q. At the end of the summer? 
21 
A. Yes. 
22 
Q. Where is the summer trip taking you? 
23 
A. To Italy. 
24 
Q. All right. Where will you go? 
25 
A. To Florence. 
And when did you decide to take a minor? 
I decided about a year after I got there. 
So that's what, an extra year? In order to 
Page 168 
1 
Q. Did you get an AA degree? 
2 
A. Yes. 
3 
Q. In what? 
4 
A. Just general. 
5 
Q. Kind of liberal arts? 
6 
A. Yes. 
7 
Q. After getting your -- when did you graduate? 
8 
A. Around '07. 
9 
Q. Spring of'07? 
10 
A. Yes. 
11 
Q. And where did you go to school after that? 
12 
A. 
13 
Q. 
also in 
14 
Orlando? 
15 
A. Yes. 
16 
Q. And have you graduated ftom IN yet? 
17 
A. Not yet. 
18 
Q. So if -- you would have started ■ 
in the 
19 
fall of'07? 
20 
A. Yes. 
21 
Q. So if you had two more years, you had two more 
22 
years to finish at 
M
,
 
assuming you took full loads? 
23 
A. Yeah. 
24 
Q. All right. So '07 to '08 and '08 to '09, so 
25 
if you had finished in two years, you would have 
Page 170 
1 
MR. HOROWITZ: Cool. 
2 
BY MR. CROTON: 
3 
How long will you be there? 
4 
For about a month. 
5 
And this is through.? 
6 
Yes. 
7 
And who pays for this, your parents? 
8 
A. I'm taking out loans for it. 
9 
Q. And your school, did your parents do Bright 
10 
Futures? Start again. Were you entitled to Bright 
11 
Futures? 
12 
A. No. 
13 
Q. Any form of the Bright Futures program? 
14 
A. No. 
15 
Q. There is another one. 
16 
A. No. 
17 
Q. How about did your parents do prepaid at all? 
18 
A. I don't know. I don't think so. 
19 
Q. Have your parents supported you while you have 
20 
been at least the four years in school? 
21 
MR. HOROWITZ: Form. 
22 
THE WITNESS: Yeah, I mean I always worked 
23 
too. 
24 
BY MR. CRITTON: 
25 
Q. Okay. Let me just go back to the FBI for just 
Q. 
A. 
Q. 
A. 
Q. 
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1 
a minute. So the FBI came to you during your freshman 
2 
year at IMMI, which would have been '05-'06. 
• 3 
Did they come du
Sthe 
'05 time period, that 
4 
is, shortly after the 
police, or was it into 
5 
the '06 time period? 
6 
A. I don't remember. 
7 
Q. Who came? 
8 
A. Agent=. 
9 
Q. Just her? 
10 
A. Her and another guy. I forget his name. 
3.1 
Q. They drove to Orlando? 
12 
A. Yes. 
13 
Q. Where did you meet them? 
14 
A. Starbuck's. 
15 
Q. Sarno place you met Mr. Herman? 
16 
A. Yes. 
17 
Q. Did you meet anybody else there? 
18 
A. No. 
19 
Q. All right. So you are at Starbudc's. How 
20 
much time did you spend with the FBI at Starbuck's? 
21 
A. Probably about two hours. 
22 
Q. Who bought the coffee, do you remember? 
23 
A. They did. 
24 
Q. All right. And did they take a taped 
25 
statement from you at all? 
Page 173 
1 
strike that. What did they say to you first? 
2 
A. They just asked me what happened with Jeffrey 
3 
and they said that, that I had to tell them, you know, 
4 
exactly what happened. 
5 
So I admitted — they asked me ill told the 
6 
officers everything when they came, and I admitted that, 
7 
you blow, I didn't tell them everything. 
8 
And then so I just basically went into detail 
9 
with them and, you know, told them everything about what 
10 
happened. 
11 
Q. Okay. Now is it your testimony that you told 
12 
them the truth? 
13 
A. Yes. 
14 
Q. Okay. Did you make any errors in what you 
15 
told -- strike that. 
16 
Did you misrepresent, lie or deceive the FBI 
17 
in any way? 
18 
A. No. 
19 
Q. So if I got the FBI statement, you would say 
20 
that would be accurate even if you've testified 
21 
differently today? 
22 
MR. HOROWITZ: Form. 
23 
BY MR. CRITTON: 
24 
Q. Right? 
25 
A. I mean yes. I told them, I didn't tell the 
Page 172 
1 
A. I can't remember if they did. 
2 
Q. Did they take a statement at all? Was anybody 
3 
writing? 
A. They took a statement, yeah. 
Q. Did you ever sign anything? 
A. I think so, yes. 
Q. Have you ever seen the statement that you 
B 
signed that you gave to the FBI? 
9 
A. No. 
10 
Q. Have you ever requested it? 
11 
A. No. 
12 
Q. Did they ever ask you to read it? 
13 
A. No. 
14 
Q. So you don't know whether they took down 
15 
correctly what you told them? 
16 
A. Yeah, I mean I actually, I think they did have 
17 
a tape recorder with them. 
18 
Q. Are you sure? 
19 
A. I think so, yes. 
20 
Q. Did they swear you to tell the truth? 
21. 
MR. HOROWITZ: I don't know. 
22 
THE WITNESS: I can't remember. Pm pretty 
23 
sure they did. 
24 
BY MR. CRITTON: 
25 
Q. Okay. And whardid you tell them -- let me 
Page 174 
1 
cops everything, and I pretty much told them -- it took 
2 
me awhile, but I told them, you know, what happened. 
3 
Q. Okay. After you talked with the FBI on that 
4 
occasion, did they tell you that you might have the 
5 
ability to bring a civil lawsuit for money? 
6 
A. No. 
7 
Q. Did they mention anything about a civil 
8 
lawsuit? 
9 
A. No. 
10 
Q. Did they mention anything about any criminal 
11 
charges that they were investigating? 
12 
A. Yes. 
13 
. Q. Did they tell you why they were investigating 
14 
criminal charges, that is, why it was a federal matter 
15 
as distinct from a state matter? 
16 
A. Because I think he, I guess 'think it got 
17 
turned down by the state or something, because he hired 
18 
great lawyers that represented him well, and I don't 
19 
think — I think the judge turned it down. So they, the 
20 
federal government picked it up, because they didn't 
21 
think it was fair, the sentence the state gave him. 
22 
Q. You mean the FBI said that to you? 
23 
A. Well, 'think Mars what they — something 
24 
Ince that, l don't know. 
25 
Q. You could have only gotten that idea from 
(561) 832-7500 
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1 
them, because you didn't know at the time, did you? 
2 
A. Yeah, they just said it was a federal 
3 
investigation now, but now I know why. 
4 
Q. Did, at that time did they mention IM 
5 
at all, the assistant US attorney? 
6 
A. No, I don't think so. 
7 
Q Did you ever get any papers from either the 
8 
FBI or from the US attorney's office? 
9 
A. I don't remember. 
10 
Q. When you said — culler today you said 
11 
called. And then I said 
and you saids 
12 
How many times have you spoken with 
13 
14 
A. I think just once when she pretty much wrapped 
15 
up the whole case. 
16 
Q. When you say she wrapped up the case, at the 
17 
time that she called you to tell you about what was 
18 
going on, what did she tell you? 
19 
A. I don't remember exactly. She just said about 
20 
what was, told me what happened with the criminal case 
21 
or what was going on with it or something. 
22 
MR. CRITTON: Okay. Let's go about ten more 
23 
minutes. Is that all right? 
24 
MR. HOROWITZ: Are you okay? 
25 
THE WITNESS: Yes. 
Page 177 
1 
Q, M? 
2 
A. Just the letter 
3 
Q. Okay. Do you have any siblings? 
4 
A. Just a brother. 
5 
Q. How old? 
6 
A. I think he's like 36, 37. 
7 
Q. Are you close? 
8 
A. Thirty-seven. No. I mean he lives in a 
9 
different state, so — 
10 
Q. You are how old now? 
11 
A. I am 22. 
12 
Q. So there is a 14-year difference between the 
13 
two of you? 
14 
A. I thinlc, yeah. I think he's like 36 or 37. 
15 
Q. So when he was almost out of high school, y ou 
16 
were only four years old? 
17 
A. Yeah, I guess so. 
18 
Q. He would have been about 18, you would have 
19 
been about four, if there is a 14-year difference. 
20 
A. I remember him, he was always in college. He 
21 
was off to college and he would come home. 
22 
Q. Where did he go to college? 
23 
A. He went to IUP. 
24 
Q. IUP? 
25 
A. Uh huh. 
Page 176 
BY MR, CRITI'ON: 
2 
Q. Tell me, you were born in Pittsburgh? 
3 
A. Yes. 
4 
Q. You moved to Florida when you were a freshman 
5 
in high school? 
6 
A. Yes. 
7 
Q. Which would have been the 0 —
8 
A. 2000. 
9 
Q. I'm sorry, 2000? 
10 
A. Yes. 
11 
MR. HOROWITZ: That doesn't sound right. 
12 
THE WITNESS: Or 2001, I think. 
13 
MR. HOROWITZ: Fm sorry. 
14 
THE WITNESS: Yeab, I think it was 2001. 
15 
. 
MR. HOROWITZ: You are right, Tin wrong. 
16 
BY MR. CFUTTON: 
17 
Q. And did you start — so it would be 2001 
18 
through May approximately of 2002, right? 
19 
A. (Witness nods head up and down.) 
20 
Q. Would have been your freshman year? 
21 
A. I believe so. 
22 
Q. All right. Where did our 
is move to? 
23 
A. They moved to 
24 
Q. What was the address? 
(561) 832-7500 
Page 1.7 
1 
Q. What's that? 
2 
A. That's in Indiana somewhere. 
3 
Q. What does he do fora living? 
A. Hes a cop. 
5 
Q. When the Palm Beach police officers called 
6 
you — let at strike that 
7 
Does your brother know that you were involved 
8 
with Mr. Epstein or that you are involved in a lawsuit' 
9 
A. I've never told him, but unless my parents 
10 
told him, I don't think so. 
11 
Q. When the police called, did you ever think of 
12 
calling your brother, who was a police officer at the 
13 
time? 
14 
A. No. 
15 
Q. Why not? 
3.6 
A. Because we're not, we don't really share 
17 
everything. Like he's a guy. I didn't want him to find 
18 
out what happened with Jeffrey. 
19 
Q. Your parents, when you moved down here, 
20 
describe your house for me that you moved in. The house 
21 
on 
Road, did you live there during all four years in 
22 
high school? 
23 
A. Uh huh. 
24 
Q. Describe it forme. How big a house was it? 
25
A. It was just late a three-bedroom house. 
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Page 179 
1 
Q. Three bedroom, three bath, two bath? 
2 
A. Yeah. 
3 
Q. Did you have your own room? 
4 
A. Yes. 
5 
Q. Okay. And when you were what, 15, I saw in 
Kliman's report you got your own car, a red Cavalier? 
7 
Yes? 
A. Yes. 
Q. Who bought that for you, Mom and Dad? 
A. Yes. 
Q. Brand new car? 
A. No. It was used. 
Q. And did you have that so you could use it 
during high school? 
A. Yes. 
la
d you take that car with you then to 
A. No. 
Q. Did they give you another car? 
A. I got into a car accident and the car got 
totaled. And so yeah, so they got me a Mustang that I 
use. 
Q Do you still have that today? 
A. Yes. 
Q What year is that? 
Page 181 
1 
A. Yes. 
2 
a...1 
saw someplace else, does he have a. 
too? 
4 
A. Yeah, me and him, we had started it when I was 
5 
younger, but we just kind of restarted it back up 
6 
rece
.f
u
 
So we just sel 
It's like an online website. 
8 
Q. So you order them from like a Cushnut or 
9 
whoever happens to be — 
10 
A. Buyers. 
11 ▪ i.
Who did yousupply — do you supply toe 
or individuals? 
13 
A. Just individuals. Like it's all online. 
14 
Q. So you've never had hie a warehouse where you 
15 
actually buy and sell means? 
16 
A. No. 
17 
Q. It's strictly 
parts? 
18 
A. And accessories, yes. 
19 
Q. How about your mom? Did she work outside the 
20 
home or was she a stay-at-home morn? 
21 
A. She worked at a craft store when I was 
22 
younger, and other than that, she was home. 
23 
And she just recently got a job, but she's 
24 
mostly home. 
25 
Q. What does she do now? 
Page 180 
Page 182 
1 
A. She works at a craft store again. 
2 
Q. Okay. But basically your dad was the sole 
3 
source of support for you and your family? 
4 
A. Yes. 
5
Q. And that's 
his be' 
an employee of 
6 
the city ot the Town o 
7 
A. Yes. 
8 
Q. All right. And would you have considered 
9 
yourself at least in your own mind, were you middle 
10 
class, upper middle class? 
11 
A. I would say middle class. 
12 
Q. Dad go to college? 
13 
A. No. 
14 
Q. Mom? 
15 
A. No. 
16 
Q. Are you the — your brother went to college? 
17 
A. Yes. 
18 
Q. And now you've been able to go to college? 
19 
A. Yes. 
20 
Q. Pretty happy childhood? 
21 
A. Yes. 
22 
Q. Any kind of traumatic events in your childhood 
23 
23 
in anyway? 
24 
24 
A. No. 
25 
Q. Soho's an employee of the cityalli
a
l
Q. „Anyone during your life that's very close to 
acti
15 (Pages 179 to 182) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
A. A'99. 
Q. In addition, the house that you lived at on 
some acreage? 
A. It had, I think it's an acre. 
Q. Pool? 
A. Yes. 
Q. In-ground pool? 
A. Yes. 
Q. And your mom and dad both had cars? 
A. Yea. 
Q. Did your — what kind of work did your dad do? 
A. He does work for the city, building 
inspections. 
Q. Novi? 
A. Yeah, he still does it now. 
Q. Is he a contractor or was he at one point? 
A. I think he does some contracting. 
Q. So he inspects, does building inspections for 
what ci 
Q. The city o 
A. Uh huh. 
Q. Yes? 
A. Yes. 
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you that has died, has passed any? 
A. No. 
3 
Q. Ever been in any kind of automobile accidents 
or any kind of accidents where you were a plaintiff in a 
lawsuit -- well, where you were injured? 
0 
A. No. 
7 
Q. I saw a reference someplace to Cameron & 
Gomalez or something like that. 
Do you know a lawyer named Glenn Cameron? 
A. (Wittsz shakes head from side to side.) 
Q. No? Doesn't mean anything to you? 
A. Uhuh. 
Q. Other than this lawsuit, have you ever been, 
have you ever made a claim against anyone? 
MR. HOROWITZ: Form. 
BY MR. CRITTON: 
Q. For any type of injuries? 
A. No. 
Q. Emotional or otherwise? 
A. No. 
Q. Have your parents ever been a plaintiff or a 
defendant in a lawsuit? 
MR. HOROWITZ: Form. 
THE WITNESS: I don't think so. 
1 
have on a nice Vineyard Vines shirt today. 
2 
A. Thank you. I like to look presentable. 
3 
Q. Pardon? 
4 
A. I said I wanted to look presentable. 
5 
Q. All right. Do you stay up on fashion like 
6 
Tory Burch, those kind of things, those types of 
7 
designers? Are you up on other designers? Do you like 
8 
to wear design clothes? 
9 
A. Just Abercrombie I lice, and maybe not 
10 
anything too expensive, but —
11 
Q. And during the time that you were in high 
12 
school and now that you are in college, and I know you 
3 
said you have worked as well part of the time that you 
14 
were in college, do you tend to buy, to keep up with 
15 
fashion? Lace to dress up? 
16 
A. I by to. 
17 
Q. I'm sorry? 
18 
A. I try to, yes. 
19 
Q. All right. And during the time that you were 
20 
in high school, did your parents, were they able to 
21 
provide for you so that you always felt that you were 
22 
well dressed among your peers? 
23 
A. Actually, I had to buy all of my clothes. 
24 
Q. And were you working at the time? 
25 
A. Yes, I was. 
Page in; 
1 
BY MR. CRITTON: 
2 
Q. Have you ever been convicted of a crime? 
3 
A. No. 
4 
Q. Have you ever been arrested for any reason? 
5 
A. No. 
6 
Q. Have you ever had to hire the services of a 
7 
lawyer at any time before? 
A. No. 
9 
MR. CRITTON: All right. Let's take a break 
10 
for lundh. 
11 
THE VIDEOGRAPHER: Going off the record at 
12 
1:11 pm. 
13 
(A lunch recess was taken.) 
14 
THE VIDEOGRAPHER: We're back on the record at 
15 
1:56 pm. 
16 
BY MR. CRITTON: 
17 
Q. Jane Doe 7, we're back from lunch now, and as 
18 
you know, I've done, certainly you know I've done the 
19 
deposition of Jane Doe 4. I have also done the 
20 
deposition of Ms. Jane Doe 3 in pan. 
21 
Would it be correct to describe you as someone 
22 
who is interested in fashion, pretty much up on fashion, 
23 
likes to dress fashionably? 
24 
A. I guess you could say that. 
25 
Q. Pm not saying that's bad or good, and you 
Page 186 
Q. All right. When you say -- your parents never 
2 
bought you anything? 
3 
A. I mean they bought me a few things, but mostly 
4 
I bought my clothes. 
5 
Q. Starting when? 
6 
A. About when I was in high school. 
7 
Q. When you were a freshman? 
8 
A. Yeah. 
9 
Q. Well, when you were still living in 
10 
Pittsburgh, did you ever have a job? 
11. 
A. No. 
12 
Q. Okay. When you started working in, or when 
13 
you moved down to South Florida in your freshman year, 
14 
did you have a job? 
15 
A. No. 
16 
Q. When did you lust obtain any kind of 
17 
employment? 
18 
A. I first got a job, I think it was, I was at, I 
19 
worked at Ultimate Fitness, and I think that was when 1 
20 
was 16,1 think. 
21 
Q. Actually you say in your answer to 
22 
interrogatory number two, which is Exhibit 2, you say 
23 
your first job was at Ultimate Fitness out in Wellington 
24 
at the kids club at the front desk in 2004, 2005, which 
25 
would have been your senior year? 
(561) 832-7500 
PROSE COURT 
I 
Sr 
16 (Pages 183 to 186) 
REPORTING AGENCY, INC. 
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Page 189 
1 
A. Yes, it was my senior year. 
2 
Q. So would it be a correct statement up until 
3 
the time of your senior year, your parents provided for 
4 
you in terms of clothes and what you needed to wear or 
5 
what you needed for high school? 
6 
A. I mean yeah, they tried to. 
Q. Sure. And you thought that you, amongst your 
8 
peers, you wore well dressed? 
9 
A. I mean I tried to be. 
10 
Q. All right. And then when you started working 
11 
for Ultimate Fitness, and then it looks like during the 
12 
summer of '05 before you went to college, you worked at 
13 
Abercrombie & Fitch? 
14 
A. Yes. 
15 
Q. So you got a discount on what you bought? 
16 
A. Yes. 
17 
Q. With the money you use earned from Ultimate 
18 
Fitness and Abercrombie, did you use that to buy 
19 
clothes, purses, whatever else you wanted? Was that 
20 
kind of like your spending money? 
21 
A. Yes. 
22 
Q. With the money that you received from 
23 
Mr. Epstein, did you use that to buy clothes and other 
24 
'Wok-knacks, do fir things that you wanted to do? 
25 
A. !mean I actually saved a lot of it up until 
1 
THE WITNESS 
2 
BY MR. CRI17O 
3 
Q. Pardon? 
4 
A. Yes. 
5 
Q. Okay. So i 
6 
that you were work 
7 
you, then you had 
8 
MR. HOW 
9 
BY MR. 
10 
Q. Did you pu 
11 
received finm Mr. 
12 
MR. HORO 
13 
THE WITNESS 
14 
form, so — 
15 
BY MR. 
16 
Q You wouldn 
17 
the IRS expects you 
18 
received. 
19 
MIL HORO 
20 
BY MR. CRITTO 
21 
Q. Did you put 
22 
A. No, I never 
23 
Q. Did you ev 
24 
A. I don't mil 
25 
make me till out f 
: Yes. 
N: 
n the '04, for the '04 time period 
ing for Ultimate, because they 1099'd 
o do like a 1040 form, tax return? 
WITZ: Form. 
CRITTON:
t in any of the money you had 
Epstein? 
WITZ: Form. 
: He never made me fill out a tax 
CRI TTON: 
it. Mr. Epstein is not the IRS, but 
to record income that you've 
WM: Form. 
N: 
that on your 2004 tax return? 
filed taxes. 
er file a tax return? 
ly know. 1 fill out whatever they 
or a job. 
Page 188 
1 
college, but I'm sure I spent some of it on food and 
2 
clothes, I mean whatever. 
3 
Q. How much money did you earn during the time 
4 
that you went to Mr. Epstein's house? 
5 
A. Mini( it was around 2000 over —
6 
Q. Did you put that on your tax rennet? 
MR. HOROWITZ: Form. 
8 
THE WITNESS: No. 
9 
BY MR. CRITTON: 
10 
Q. Did you file loxes during that time period? 
11 
A. )(didn't make enough money to have to file 
12 
taxes. 
13 
Q. When you worked at Ultimate in '04 and '05, 
14 
they would have given you — were you an employee or 
15 
were you an independent contractor, they gave you a 
16 
1099? 
17 
A. Yes. 
18 
Q. Yes, a 1099? 
19 
A. Yes. 
20 
Q. Did you therefore have to pay taxes? 
21 
MR. HOROWITZ: Form. 
22' 
BY MR. CRITTON: 
23 
Q. Let me withdraw that. 
24 
Did you have to fill out a tax return? 
 
MR. HOROWITZ. Form. 
(561) 832-7500 
1 
2 
3 
4 
5 
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9 
10 
11 
12 
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14 
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Page 190 
Q. I don't know what you have done or haven't 
done. My question to you is have you ever filled out a 
form to report your income to the IRS? 
A. Yes. 
Q. And did you strut doing that when you rust 
started working for Ultimate? 
A. Yes. 
Q. During the time you worked for Ultimate, which 
was 2004, which is one of the years that different 
places that you have alleged that you were with 
Mr. Epstein, did you ever report any of the income that 
you received from Mr. Epstein? 
MR. HOROWITZ: Form. 
THE WITNESS: No. 
BY MR. CRITTON: 
Q. Okay. And some of the money that you did earn 
(tom Mr. Epstein, ifl understood it, you saved it and 
you used it for college or during your college years? 
A. I mean I saved it. I don't really remember 
what I used it for. 
Q. Okay. You indicated earlier that you would 
drink alcohol prior to your turning 21, so you were 
drinking as an underaged person, correct? 
A. Yes. 
Q. And it looks -- not looks, but from having 
17 (Pages 187 to 190) 
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Page 191 
deposed Ms. Jane Doe 3 and Ms. Jane Doe 4, it appears 
that you all go to clubs and have been going to clubs 
3 
for a long period of time. 
MR. HOROWITZ: Form. 
BY MR. CRITTON: 
Q. Fair statement? 
A. I mean yes, I go out. 
Q. Okay. And before you were 21, did you have a 
fake ID? 
A. Yes. 
Q. All right. And when did you first start using 
a fake ID, ma'am? 
A. I don't remember. 
Q. Was it when you watt away to college or did 
you have one when you were in high school? 
A. 1 thinIcI had one in high school. 
Q. And obviously it said you were what, 21 ? 
A. Eighteen. 
Q. Well, falce ID to say you were 18? 
A. Toga into the clubs, you only needed to be 
18. 
Q. So your first fake ID said you were 18 so you 
could get into the clubs? 
A. (Witness nods head up and down.) 
Q. Yes? 
Page 192 
A. Yes. 
2 
Q. And did you eventually obtain a fake ID that 
3 
said you were 21? 
4 
A. Yes. 
Q. MI right. And how many different fake IDs 
did you have? 
A. I don't remember. 
Q. More than one? 
A. Yeah. Maybe like two or three. 
Q. And who did you get them from? 
A. I don't remember. 
Q. Did you have them made or was it a fiend's 
older sister or something like that? 
A. People that looked like me. 
Q. And how would you get it? How would you get 
the fake ID? 
A Just gave it to me, people that looked like 
me. 
Q. If they looked like you and they were over 21, 
they would give you their fake ID? 
A Yeah. I remember one girl that I worked with, 
she kind of looked like me and she gave me her II) 
because she had two of them. 
Q. When she had to what? 
A. She gave me her ID because she had two. 
(561) 832-7500 
Page 193 
1 
Q. Did you use the hike ID from time to time to 
2 
get into clubs which required you to be 21 or to drink 
3 
alcohol? 
4 
A. Yes. 
5 
Q. And you knew that that was a crime? 
6 
MR. HOROWITZ: Form. 
7 
. 
THE WITNESS: Yes. 
8 
BY MR. CRITTON: 
9 
Q. And were you ever stopped by the police and —
10. 
well, let me strike that. 
11 
Did the police ever look at your fake ID, that 
12 • 
is, were you ever in a club when you were ID'd and 
13 
someone said this isn't your ED? 
14 
A. No. 
15 
Q. You were able to successfully use the fake ID 
16 
without ever being called on it, is that correct? 
17 
A- Right 
18 
. Q. And even though you knew it was a crime, you 
19 
still did it, correct? 
20 
MR. HOROWITZ: Form. 
21 
BY MR. CRITTON: 
22 
Q. You still used the ID? 
23 
A. Yes. 
24 
Q. Any tattoos? 
25 
A. No. 
Page 194 
1 
Q. Morality? 
2 
A. Just my ears, 
3 
Q. During the time that you were through the 
4 
time you were In high school, which would be the summer, 
5 
la ss the summer of '05 before you went away to 
6 
did you and your parents go away for 
7 
vacations? 
8 
A. We had just gone up to Pennsylvania to go 
9 
visit my family up there, and we went down to Key West 
10. 
once or twice. 
11 
Q. Where did you stay when you went down to Key 
12 
West? 
13 
A. We stayed in Islamorada at a hotel. Sony, we 
14 
went to Islamorada once, and then we went to Key West 
15 
and stayed at a hotel down there. 
16 
Q. On another trip or the same trip? 
17 
A. Another trip. 
18 
Q. Have you ever been to the Bahamas? 
19 
A. Yes. 
20 
- Q. Where? 
21 
A. Nassau. 
22 
Q, With whom did you go to Nassau? 
23 
A. I went on 
senior cruise. 
24 
Q. Senior mINIa 
25 
Yes, a senior trip. 
18 (Pages 191 to 194) 
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Page 195 
Page 197 
1 
Q. ForI 
2 
A. Yes. 
3 
Q. How many days were you gone? 
4 
A Three days. 
5 
Q. Who were your roommates? 
6 
A. I think Jane Doe 4. 
7 
Q. Jane Doe 4? 
8 
A. Yes. 
9 
Q. Anyone else? How about Ms. Jane Doe 3, was 
10 
she there too? 
11 
A. No. 
12 
Q. Is she younger than you? 
13 
A. Yes. 
14 
Q. Other than the cruise to Nassau, is that the 
15 
only time you've been to the Bahamas? 
16 
A. Yes. 
17 
Q. Have you ever been, other than being 
18 
Pittsburgh -- Fm sorry, Pennsylvania when you have 
19 
driven up there and been to the Bahamas, have you ever 
20 
been outside of the state of Florida other than that? 
21 
A. Yes. 
22 
Q. Where have you gone? 
23 
A. I went to, for like my 21st birthday, me and a 
24 
group of girls went to Vegas. 
25 
Q. Where did you stay? 
1 
Q. Are they friends from.? 
2 
A. Yes. 
3 
Q. And when did you go to New York? 
4 . 
A. I weriaphomore year. 
5 
Q. At 
6 
A. Actually, maybe it was my junior year at 
7 
I think. 
8 
Q. Were you there for five, six days? 
9 
A. I think we were there for like five days. 
10 
Q. And where did you stay? 
11 
A. Her aunt has a place in the city. She's like 
12 
a stockbroker and she has a place in the city she let us 
13 
stay at 
14 
Q. Did you go see shows when you were there, any 
15 
shows? 
16 
A. No. 
17 
Q. Shopped? 
18 
A. We went to Canal Street. 
19 
Q. Any other trips outside the state of Florida? 
20 
A. Chicago. 
21 
Q. When did you go to Chicago? 
22 
A. We went there I think when I was a sophomore 
23 
in college or junior. 
24 
Q. And who, when you went to Chicago, with whom 
25 
did you go? 
Page 196 
1 
A We stayed in The Palms. 
2 
Q. The Palms, all right. Upscale. 
3 
A. Well — 
4 
Q. Did you get to go upstairs on the spike where 
5 
the club was on the top of The Palms? 
6 
A. Oh, yeah. My friends mom paid for like ow 
7 
trip and then she paid for the hotel room, so we all —
8 
Q. Who went? 
9 
A Me and my friend 
and then her friend 
10 
= 
and 1 forget the other girl's name that went. 
11 
Q. How many days were you in Vegas? 
12 
A. For about four days. 
13 
Q. She flew you out there from West 
14 
A. Well, I paid for my ticket. 
15 
Q. You paid for your ticket, but they paid for 
16 
the room, friend? 
17 
. 
A. Yeah. 
18 
Q. All right. Where else have you been outside 
19 
the state of Florida? 
20 
A. I went to New Yost 
21 
Q. When did you go to New York? 
22 
A. We went there on a spring break trip. 
23 
Q. Who is we? 
24 
A. Me and m friend =I 
a different =, 
2
l—ess
5 
and my friend 
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• 
Page 198 
1 
A. I went with Jane Doe 4. 
2 
Q. Which Jane Doe 4? 
3 
A. Jane Doe 4. 
4 
Q. Who else? 
5 
A. My friend =I. 
6 
Q. All right. Anyone else? 
7. 
A. M other friend, 
8 
Q. Is .= 
the one you went to Vegas with? 
9 
A. Yes. 
10 
Q. Anyone else? 
11 
A. I don't think so, WI uh. 
12 
Q. How did you get up to Chicago? 
13 
A. A friend of mine, like it was my friend's 
14 
birthday. 
15 
Q. Which friend's. 
16 
A. My friend El it was her birthday, so we 
17 
went to — my friend invited us up there for her 
18 
birthday. 
19 
• Q. Olcay. Where did you stay? Which hotel? 
20 
' A. My friend has a place up there, so he let us 
21 
stay at his place. 
22 
Q. Your friend, it was your friend's birthday. 
23 
Is it a he? 
24 
. 
A. Yes. 
25 
Q. What was his name? 
19 (Pages 195 to 198) 
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