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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA01248007

156 pages
Pages 1–20 / 156
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Page 1 / 156 
Page 1 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE No.502008CA037319XXXXMB AB 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
VIDEOTAPED DEPOSITION OF 
VOLUME I 
Tuesday, November 10, 2009 
11:13 a.m. - 6:12 p.m. 
250 S. Australian Avenue 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Sandra W. Townsend, FPR 
PROSE COURT REPORTING AGENCY 
Notary Public, State of Florida 
West Palm Beach Office 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1f88f113.5663.4dad-94e7-901Po7174075 
3501.182-102 
Page 1 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00094347 
EFTA01248007
Page 2 / 156 
Page 2 
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U 
U 
• 
• 
• 
APPEARANCES: 
On behalf of the Plaintiff III.: 
On behalf of Plaintiffs 
On behalf of Plaintiff 
18 
On behalf of the Defendant: 
19 
ROBERT CRITTON, ESQUIRE 
BURMAN, CRITTON, LUTTIER & COLEMAN 
20 
515 North Flagler Drive 
Suite 400 
21 
West Palm Beach, Florida 33401 
Phone: 561.842.2820 
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23 
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(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1f88f113-5663-4dad44.7-90flb7174075 
3501.182-102 
Page 2 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00094348 
EFTA01248008
Page 3 / 156 
Page 3 
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On behalf of the Witness: 
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ALSO PRESENT: 
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MICHAEL DOWNEY, VIDEOGRAPHER 
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(561) 832-75C0 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1f88f113.5663.4dad-94e7-90flb7174075 
3501.182-102 
Pagc 3 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00094349 
EFTA01248009
Page 4 / 156 
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EXHIBITS 
Page 4 
NUMBER 
DESCRIPTION 
PAGE 
5 
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Plaintiff: 
7 
Exhibit number 1 
Notebook page 
14 
8 
Exhibit number 2 
Photograph 
134 
9 
Exhibit number 3 
Photograph 
137 
10 
Exhibit number 4 
Photograph 
138 
11 
Exhibit number 5 
Photograph 
247 
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Defendant: 
14 
Exhibit number 1 
Transcript 
140 
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(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377476-2895) 
Electronically signed by Sandra Townsend (401-377476-2895) 
1f88f1134663-4dad-94e740ftb7174075 
3501.182-102 
Pagc 4 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA 00094350 
EFTA01248010
Page 5 / 156 
Page 5 
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PROCEEDINGS 
Deposition taken before Sandra W. Townsend, Court 
Reporter and Notary Public in and for the State of 
5 
Florida at Large, in the above cause. 
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- - - 
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VIDEOGRAPHER: We're on the video record. 
8 
This is the 10th day of November, the year 2009. 
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The time is approximately 11:13 a.m. 
This is the videotaped deposition of 
in the matter of III., Plaintiff, versus 
Epstein, Defendant. 
This deposition is being held at 250 South 
Australian Avenue, West Palm Beach, Florida. 
My name is Michael Downey. I'm the 
videographer, employed by Visual Evidence. 
Would the attorneys please announce their 
appearances for the record. 
MR. 
Plaintiff III. 
MR. 
Plaintiffs 
MR. 
• 
Yes. 
, on behalf of 
on behalf of 
on behalf of 
MR. CRITTON: Robert Critton, on behalf of 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377476-2895) 
Electronically signed by Sandra Townsend (401-377476-2895) 
1f88f113-5663-4dad-94e7-90ftb7174075 
3501.182-102 
Page 5 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA 00094351 
EFTA01248011
Page 6 / 156 
Page 6 
1 
Jeffrey Epstein. 
2 
MS. 
and 
3 
here on behalf of witness, 
4 
THEREUPON, 
6 
having been first duly sworn or affirmed, was examined 
7 
and testified as follows: 
8 
THE WITNESS: So help me God. 
9 
MR. CRITTON: Let me just note one thing for 
10 
the record, is -- it's been -- this case for this 
11 
depo has been noticed both in the State Court case. 
12 
It's been noticed as well -- cross noticed by at 
13 
least 
on behalf of his clients two 
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through eight in the Federal Court case. The only 
15 
two lawyers who apparently are not here, but they 
16 
obviously have notice of it. And Mr. 
didn't 
17 
notice it, but obviously he's -- cross notice, but 
18 
he's here -- Mr. 
on behalf of his three 
19 
clients, and apparently Mr. Garcia chose, they 
20 
chose not to come for whatever reason, but they 
21 
would have received notice from everybody. 
22 
DIRECT EXAMINATION 
23 
BY MR. 
24 
Q. 
Good morning. 
25 
A. 
Morning. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377476-2895) 
Electronically signed by Sandra Townsend (401-377476-2895) 
1f88f113-56634dad-94e7-90ftb7174075 
3501.182-102 
Page 6 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA 00094352 
EFTA01248012
Page 7 / 156 
Page 7 
Q. 
Just want to make sure he was done. 
2 
I introduced myself in the beginning, but my 
3 
name is 
. I represent one of the 
4 
Plaintiffs in a lawsuit filed against Mr. Epstein. And 
5 
I'm here today to ask you a bunch of questions. 
6 
As you saw at the beginning, you're under 
7 
oath. It's just like you're on the stand at trial, 
8 
except there's no Judge here in the room with us. So 
9 
when I ask you questions, just give it a breath for a 
10 
minute because there may be objections for other lawyers 
11 
in the room. 
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Since there's not a Judge here, nobody's going 
13 
to rule on those objections, so the lawyer has to put 
14 
that objection on the record. Just pause for a minute 
15 
and then if you understand the question, go ahead and 
16 
answer. 
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The only exception to that rule is, if your 
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two lawyers look at you and say, don't answer that 
19 
question. At that point I don't want you to say a word. 
20 
And then they lodge an objection and advise you not to 
21 
say anything. Okay? 
22 
A. 
Okay. 
23 
Q. 
If you do answer a question, there's two 
24 
things I'm going to assume. I'm going to assume that 
25 
you understood the question being asked and that you're 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1188f113-5663.4dad-94e7-90flb7174075 
3501.182-102 
Page 7 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00094353 
EFTA01248013
Page 8 / 156 
Page 8 
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answering truthfully. Fair enough? 
A. 
Yes. 
Q. 
If you don't understand any of my questions, 
please let me know and I'll be happy to rephrase it 
5 
until you can understand it. 
6 
It's a nerve-racking procedure and I know 
7 
you're nervous. It's delving into very touchy areas, so 
8 
it's going to be delicate. I'm going to try and handle 
9 
it as respectfully and delicately as possible, but I am 
10 
going to have to ask a whole bunch of difficult 
11 
questions. Okay? Fair enough? 
12 
A. 
Understand. 
13 
Q. 
Okay. If you would, could you give us your 
14 
full name, please? 
15 
A. 
16 
Q. 
Where do you currently live? 
17 
A. 
• 
• 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377476-2895) 
Electronically signed by Sandra Townsend (401-377476-2895) 
1f88f113-5663-4dad-94e7-90ftb7174075 
3501.182-102 
Pagc 8 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00094354 
EFTA01248014
Page 9 / 156 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electron Gaily signed by Sandra Townsend (401.377-676.2895) 
Elecironicaily signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-S4e7-90flb7174075 
3501.182-102 
Page 9 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFrA_00094355 
EFTA01248015
Page 10 / 156 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-94.7-90flb7174075 
3501.182-102 
Page 10 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00094356 
EFTA01248016
Page 11 / 156 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401477476-2895) 
Electronically signed by Sandra Townsend (401477476-2895) 
1f88f113-5663-4dad-94e7-90ftb7174075 
3501.182-102 
Page 11 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA 00094357 
EFTA01248017
Page 12 / 156 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401477476-2895) 
Electronically signed by Sandra Townsend (401477476-2895) 
1f88f113-5663-4dad-94e7-90ftb7174075 
3501.182-102 
Page 12 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00094358 
EFTA01248018
Page 13 / 156 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-S4e7-90flb7174075 
3501.182-102 
Page 13 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFrA_00094359 
EFTA01248019
Page 14 / 156 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401477476-2895) 
Electronically signed by Sandra Townsend (401477476-2895) 
1f88f113-5663-4dad-94e740ftb7174075 
3501.182-102 
Page 14 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA 00094360 
EFTA01248020
Page 15 / 156 
(5611 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-S4e7-90flb7174075 
3501.182-102 
Page 15 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00094361 
EFTA01248021
Page 16 / 156 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-Ne7-90ftb7174075 
3501.182-102 
Page 16 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00094362 
EFTA01248022
Page 17 / 156 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1 f88f113-5663-4dad-94.7-90flb7174075 
3501.182-102 
Page 17 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFrA_00094363 
EFTA01248023
Page 18 / 156 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377476-2895) 
Electronically signed by Sandra Townsend (401-377476-2895) 
1,88f113-5663-4dad-94e740ftb7174075 
3501.182-102 
Page 18 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00094364 
EFTA01248024
Page 19 / 156 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401477476-2895) 
Electronically signed by Sandra Townsend (401477476-2895) 
1f88f113-5663-4dad-94e7-90ftb7174075 
3501.182-102 
Page 19 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA 00094365 
EFTA01248025
Page 20 / 156 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377-676.2895) 
Electronically signed by Sandra Townsend (401.377-676.2895) 
1188f113-5663-4dad-S4e7-90ftb7174075 
3501.182-102 
Page 20 of 156 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00094366 
EFTA01248026
Pages 1–20 / 156
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