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Pace
UNITED STATES DISTRICT COURT 1 Appearances rationed:
SOUTHERN DISTRICT OF FLORIDA 2 On behalf of the Defendant, Jeffrey Epstein:
3 ROBERT D. CRITTON, JR., ESQUIRE
CASE NO. 502008CAO2S05130000.03 AB 4 i MA fg RK T. LUTHER i ES LU Q T U T IR IE E R & COLEMAN, LLP
a
Plaintiff.
-vs. VOLUME I OF II
JEFFREY EPSTEIN. 6 one:
Defendant 7 On behalf oi 1, Jeffrey Epstein:
8 JACK ALAN GOLDBERGER, ESQUIRE
A URY GOLDBERGER & WEISS, PA.
9
VIDEO-CONTERD4CED AND VIDEOTAPED MORMON OFI .
10
Tbunnky, September 24,2009 one
9:40.5:52 p.m 11
12
13 ALSO PRESENT: Jeffrey Epstein, via video conference
Michael Downey, Videographer
14 Visual Evidence, Incorporated
15
16 IN DEX VOLUME I
3.7
Repotted By: 18
Cynthia Hopkins, RPR, FPR 19 WITNESS: DIRECT CROSS REDIRECT RECROSS
Notary Public. State of Florida 20
Prose Coal Reporting 21
22 LIMIER 10
23
24
25
Page 2 Page 4
1 APPEARANCES: 1 P ROCEEDINGS
2 On behalf of for Plainti 2
3 BRAD J. EDWARDSS,...
RoSENFT_:LOr, AM I R 3 THE VIDEOGRAPHER: We're on the videotape
4 4 record. This is the 24th day ofM I., the
5 year The time is approximately 9:46 a.m.
6 This is the videotape deposition of ■ in the
7 6 On beli..z214tAl: 7 matter of fl Plaintiff versus Epstein, Defendant.
SE' . KUVfN, ESQUIRE a This deposition is being held at.
My
9 9
10 name is Michael Downey. IM the videographer
10
Phone: 11 employed by Visual Evidence.
11 12 Will the attorneys please announce their
12 On behalf o
13 ADAM RE :3 appearances for the record.
ROWITZ. P.A. 14 MR. EDWARDS: Brad Edwards representing..
14 15 MR. HOROWITZ: Adam Horowitz, counsel for
is 16 Plaintiffs
17 MR. KUNIN: Spencer Kuvin on behalf of
16
17 18
19 19 MR. GOLDBERGER: Jack Goldberger on behalf of
19 20 Jeffrey Epstein.
21. MR. CRITTON: Bob Critton on behalf of Jeffrey
20
22 Epstein.
23. 23 MR. LUITIER: Mark Luther on behalf of
22
23 24 Jeffrey Epstein.
24 25 MR. EDWARDS: Before we get started, I know
25
Fek
1 (Pages 1 to 4)
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1 that we're going to use teal names during this 1 anonymity here. And I am not going to agree to
2 deposition rather than pseudonyms. I just want to 2 that, so —
3 make sure that we're all on the same page that when 3 MR. CRITTON: Well, l can tell you I wouldn't
4 the court reporter types it up, it's going to be 4 put a video on. I would not put a video that would
5 typed up in the transcript as the initials like we 5 identify this individual, you're client's face.
6 have in previous depositions. 6 All right. I would do nothing to identify her
7 MR. CRITTON: That, that's fine, but keep in 7 face. So, her anonymity would be, quote, unquote,
8 mind that we need, because a number of the 8 preserved if that's your issue.
9 individuals have multiple first initials and you 9 MIL EDWARDS: My issue is only preserving her
10 have used initials that don't even match your 10 anonymity. So, I mean, are we in agreement that
11 clients names. 13. this is not going to be a video published in a
12 So we're going to have to — Cindy, you're 12 public forum or any way outside of use in a
13 going to need to, ultimately when you finish, if 13 courtroom to be seen by the judge?
14 this is agreeable with everyone, I think we did 14 MR. CRITTON: To the extent her picture or her
15 this before is type up a key and then you can give 15 name would be used, I agree with that. Other than
16 that only to the lawyers and do that as just a 16 that, just go to the court. And as i said, you can
17 privileged or as a confidential document, so that 17 file a motion with the court. if your position is
18 we can insert those 18 is that the deposition, again assuming there is
19 MR. EDWARDS: Along those same lines, as this 19 complete anonymity and her face is blotted out,
20 is being videotaped, I imagine in agreement amongst 20 that the video cannot be filed with the court or
21 the parties this will remain confidential except in 21 used in some other fashion, right, I agree. We're
22 the case that there is a court order that the 22 not going to do anything that in any way impacts
23 videotape and her image is made public in any way. 23 the anonymity absent an order from Judge Hafele in
24 So, if it's going to be made public in any way, 24 this particular case.
25 then, !just ask that it only happen by way of some 25 MR. EDWARDS: All right. We're in agreement
Page 6 Page 8
1 court order, either by way of Marra or Judge 1 then. Okay.
2 Hafele. 2 MR- CRITTON: But, but I want to be clear, it
3 MR. CRITTON: This is only being done in the 3 is to the extent that if the, you still need to
4 ■case. And I will tell you what you can do 4 file a motion with the court to the extent that you
5 is we won't agree to that because Mr. )(Irvin 5 don't, that it's your position that even if her
6 apparently gave Mr. Epstein's video to Jose 6 face was blotted out and even if no names are used,
7 Lambiet, which was then immediately put on the 7 and you think that the video is to remain
8 Post, and then ended up on, all over the country. confidential, then you should file something with
9 And be certainly had no issue associated with 9 the court. And I'll give you, like I said I will
10 confidentiality. So, whatever rules apply. 10 give you ten days so you can proceed to file that
11 What I will tell you is with regard to the 11 motion.
12 video today, we'll give you whatever time you think 12 MR. EDWARDS: Okay. So it's your intention to
13 is necessary -- well, let's do it this way: Within 13 use Ibis video, blot her face out and then post it
14 ten days fiom today you file a motion for 14 somewhere?
15 protective order in front of Hafele with regard to 15 MR. CRITTON: I have no intentions at all.
16 this deposition, and we'll agree that it will 16 MR. EDWARDS: Okay.
17 not — we won't touch it. 17 MR. CRITTON: And if you had brought this up
18 Mil. EDWARDS: I don't see how that's necessary 18 in a motion earlier, I would have addressed it at
19 since we already have the Judge's agreed, we have 19 the same time.
20 an agreed order that we can proceed anonymously. 20 MR. EDWARDS: I think we're all on the same
21 Judge Hafele, as you know, has been very careful in 21 page that the victims in this case are to remain
22 instructing yourself and everybody else in this 22 anonymous. i mean, everybody has been warned
23 case that these individuals are to remain 23 repeatedly about using names outside of the
24 anonymous. And obviously publishing this video in 24 pseudonyms and exposing faces, things like that, to
25 any public forum will decrease or eliminate any 25 the public outside of the court.
2 (Pages 5 to 8)
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MR. CRITTON: I am aware of the court order. 1 I don't know.
2 I am also aware that is a public 2 Q. Okay. How many times have you been deposed?
3 figure now because her lawyers chose to disclose 3 A. Once that I know of. 1
4 her name. 4 Q. Am you referring to an incident where you
MR. EDWARDS.: Right. And that was her choice. gave a sworn statement to the FBI? Is that what you are 4 I
6 MR. CRi'TON: Everything associated with the 6 referring to?
7 her is public. 7 A. Yes, sir.
8 MR. EDWARDS: Right. 8 Q. That's what you — when you said you were
9 MR CRITTON: Tm aware of the other court 9 deposed one time, that's the incident that you're
10 orders in, that are in place and I think, well, I 10 referring to?
11 think we have said enough. 11 A. Yes, sir.
12 MR. EDWARDS: Okay. Agreed. 12 Q. What is ur current address?
13 MR. LUTTIER: Would you please state your 13 A.
14 name. 1 4
15 THE COURT REPORTER: I need to swear the 15 Q. And is that an apartment?
16 witness. 16 A. Yes, sir.
17 MR. LUTTIER: Okay. 17 Q. kit in a development?
18 Thereupon, 18 A. Yes, sir.
19 19 Q. What development is it in?
20 having been first duly sworn or affirmed, was examined 20 A.
21 and testified as follows: 21 Q. And where is that located?
22 DIRECT EXAMINATION 22 A.
23 BY MR. LUTTIER: 23 Q. How Ion have u lived there?
24 Q. Would you please state your full name, ma'am. 24 A.
25 A. El. 25 Q. And does anybody live with you at that address
Page 12
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1 Q. What's your middle name? 1 currently?
2 Al 2 A. My son.
3 Q. (Mr. Luttier spelled her middle name.) 3 Q. And what is your son's name?
4 A. Yes. 4 THE WITNESS: Do I have to say my son's name?
S Q. is there. at the end of it? 5 MR. EDWARDS: lam, lam going to instruct her
6 A. No. 6 not to answer. This is a minor child and she's
7 Q. Okay. n., have you ever been deposed 7 going to her son out of this litigation. This
8 before? 8 is a boy.
9 A. Yes. 9 MR. LUTTIER: Is that some basis-
10 Q. When was the last time you were deposed? 10 THE WITNESS: i don't know why it's relevant
11 A. The date was — I don't know when the date 11 to to have my son's name. I have a
12 was, but it was the last time with Jeffrey Epstein. 12 son.
13 Q. What do you mean by "with Jeffrey Epstein"? 13 MR. EDWARDS: Yeah, the basis of the objection
14 A. i was deposed with Jeffrey Epstein on 14 is that your client is a convicted felon and a sex
15 behalf - I don't know, Jim Eisenberg, the guy who is 15 offender. This is a victim and she is in fear for
16 actually upstairs from here. I don't know the name. 16 the safety of her son. And because of that fear,
17 Q. Who do what guy is upstairs? Who are you 17 she's not going to provide an ore identifying
18 talking about? 18 information about her son.
19 A. You know the last time I was deposed. 19 BY MR. LUTTIER:
20 Q. I don't know of any, ma'am. I assure you I 20 Q. Do you adopt what your lawyer just said?
21 don't know of any time you have been deposed, so that's 21 MR. EDWARDS: Don't answer.
22 what I am trying to find out 22 THE WITNESS: I agree.
23 A. You don't. 23 MR. EDWARDS: Don't answer.
24 Q. No. 24 BY MR LUTTIER:
25 A. Okay. When was the last time i was deposed? 25 Q. Do you have some fear for the safety of your
3 (Pages 9 to 12)
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1 son? 1 Q. All right. So, you have a
2 A. Yes, sir. 2 Somewhere I think I read his name was
3 Q. And what is your fear? 3 or something like that. And have you and he lived just
4 A. Are you kidding me? What is my fear? 4 the two of you at this apartment since at
5 Q. I can tell you, ma'am, there is nothing here 5 A. Yes.
6 at all today that I am going to be asking you that's a 6 Q. Has anyone else lived with the two of you at
7 joke or that I am kidding you about. 7 that apartment since
8 A. Yes.
a A. Okay.
9 Q. Okay. So what is the fear that you have for 9 Q. Who else has lived there?
10 your son?
10 A.
11 A. I don't lmow if you have kids — 11 Q. How do you spell that last name?
12 Q. Yeah, I do, ma'am 12
13 A. All right. Well, then, if you were in this 13 Q. And for what period of time has
14 deposition, Lam in fear that this, this criminal, 14 lived there?
15 Jeffrey Epstein, could harm him in some way bier on in 15 A. For seven months now.
16 life like he's harmed me and many other women or girls 16 Q. Is he living there now?
17 as that. And I don't want this to be publicity later on 17 A. Yes.
18 in life for him to see what his mother has been through. 18 Q. And is there some relationship between
19 That's why I am in fear for him. 19 and yourself?
20 Q. Okay. Can you tell me specifically what it is 20 A. Yes.
21 that you fear, what specific -- 21 Q. What is that relationship?
22 A. I just told you. 22 A. He is my current boyfriend.
23 Q. — act that you fear is going to happen to 23 Q. And what is occupation?
24 your son? 24 A. He is—he does
25 A. Psychological, mental physical matters for my 25 Q. Does he week for someone or is he
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1 son. 1 self-employed?
2 Q. Can I, can I assume that you would take 2 A. He works for
3 whatever steps you deem necessary to protect your son 3 Q. Has anyone else ever lived with you and your
4 any time you felt that he was in any kind of danger? 4 son since MINIM)
5 A. Yes, sir. 5 A. No, sir.
6 Q. And could I assume that historically, that is 6 Q. Prior to, that is immediately before you moved
7 throughout his life as long as he has been bom, you 7 into the where did you live?
8 have always done anything you could to protect him from 8 A. On
9 any situation where he was put in danger; is that right? 9 Q. What was the address?
10 A. Yes, sir. 10 A. Prom what I recall El Min
11 Q. And if somebody puts your son in danger, you 11
12 know how to file a lawsuit against them and protect them 12 Q. And whereabouts is that located in IMIE)
13 and things like that, right? 13 A. On
14 A. Yes, sir, but I don't want to get to that 14 Q. What kind of structure was that?
15 point. mat's why I am not going to disclose his name. 15 A. A townhouse.
16 Q. Well, you have filed this lawsuit, right? 16 Q. And how long did you live there?
17 A. For mY, for my sake, yes. 17 A. I lived there for about seven months. I'm not
18 Q. And you would file a lawsuit to protect your 18 really sure on that.
19 son if that's what you had to do, would you not? 19 Q Okay. Since approximately somewhere around
20 A. Yes, i would. 20
21 Q. Would it be a fair statement to say that your 21 A. I'm, I'm really not sure.
22 son is the most important thing to you in your life? 22 Maybe — you know what, it was llmigo. n.
23 A. Yes. 23
24 Q. Okay. 24 Q. Okay. And something, it sounds like something
25 A. Yes, yes, yes. 25 that you were able to refer to that triggered your
NEMAIrIO Niada. 10.0W9MV •thik.••••• ••••HA
4 (Pages 13 to 16)
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1 memory as to when that was? 1 A. I have to take the exam in order for me to get
2 the certificate to be licensed.
2 A Yes.
3 Q. What was, what incident that triggered your 3
4 ma A no . ab ten that was? 4 5 a so l m li e i t M hin I g S se O par N ate S that you have to go through b ? e ing
5
6 grilitor me to get licensed to be a
6 Q. ? 7 , I have to take something called the
7 a Q A. . Y H e o s w . do you know the -- was 8 , I think it's called. And after I pass the test,
there something that trigg that you then I will receive my license.
studies a
10 recalled about that day? 10
11 A. Yes, because I t ved in before and I 11
12 had to get th up. 12
13 Q. Did anyone --I your son lived with you 13 Q.
? 14 A.
14 when you were
15 Q. started?
15 A. Always.
16 . ' one else live with you while you wemre 1 16 7 A Q. . Y H e a s d . you ever attended that institution before?
17 a
18 A. Yes.
18 A. No, sir.
19 Q. Are you currently employed? 19 Q. When had you previously attended that
20 institutaia
20 A. No, sir.
21 Q. What are your -- what is your current means of 21
22 Q. Do you recall when?
22 support?
23 A. I have a loan from school. 23 A. No, sir.
24 Q. Was it located at the same location when
24 Q. And wh ilia
25 A. 25 You —
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1 A. Yes, sir.
1 Q. An wh 2 Q. — attended there previously? And for what
2 A. 3 . pu . rp . os r e had ae l y i ou c per: 5,1ot
3
4 Q. And are you pursuing some course of study 4
5
5 there?
6 Q.
was that?
6 A. Yes.
7 Q A. . Skis of study are you pursuing? 7 long you attended it is was
8
9 Q. Is that an institution where you obtain a 9
10 degree upon completion of your studies? 10 A. Yes, sir.
11 Q. And then upon completion of that course of
11 A
12 rote then take a test and get a license as an
12
13
I can be
14 Q. When you complete your studies there, what 14 A. Yes.
15 will you get to signify that you have completed that 15 Q. And about when did you get your lice
16 A. I am pretty sure it was the beginning
16 course of study?
17 A. I wool to and I 17 SiAnd that licensure was issued by the
18
18 would be
19 Q. So, would you get a certificate? 19 A. Yes.
20 Q. Did you your license after you got it in
20 A. Yes.
21 Q. And that after you get your certificate, 21 the beginning of II?
22 you're required to take some kind of exam? 22 A. Yes.
23 Q. How did yomili mi
23 A. Yes.
24 Q. Or do you have to take the exam to get the 24 A. I worked at
25 Q. What's the name of that?
25 certificate?
5 (Pages 17 to 20)
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at a
1
1 A Mt.
2 Q. How do u spell that?
2 MR. EDWARDS: Object to the form.
3 THE WITNESS: No. Fm not sure.
3 A.
4 MR. LUTTIER: Okay.
4 Q. 5 arWITNESS: Maybe a couple months before
5 6 Q A. . A Yc n s d . where is that located? 6 I'm not sure. There is record on my
7 have pay stubs. I don't know.
7 A. That is located
8 BY Mit.
9 Q. Okay. How did you get that job?
9
10 (Ms. Ezell entered the deposition.) 10 A. I filled out a resume and I walked into the
11 place and I asked for a job.
11 BY MR. LIMITER:
12 Q. Is that in like a strip mall center? 12 Q. And do you have a copy of your resume?
13 A Yes. Not with me.
13 A. Yes.
14 Q. And what did do
14 Q. Did you know anyone at that place of business?
15 A. No.
15 A. I was
16 Q Was that the only place of business that you
16 Q. What •
17 submitted your resume to?
17 A. Fad
18 Q Apnedr fwohnanta did does 18 A. No, sir.
19 Q. Who else did submi
19 A. I
20 . And and basicall
20 A. To a couple.. aroun
21 that kind of thin 21 Q. Did you interview for the job?
22 other jobs. I interviewed for
22 A. No sir.
23 e attd they took mc in.
23
24 Q. Do you recall who you interviewed with?
24
25 A No, sir.
25
Page 24
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1 i i ind for what period of time did you work at 1 Q. Did you know anyone a before
2 you went to work there?
2
3 A. That's when the economy kind of went down, so 3 MR. EDWARDS: Object to the fonn.
4 I didn't work there for a long period of time because 4 THE WITNESS: I told you, no, sir.
5 they were allowing me so many hours. I want to say 5 6 BY Q M . R D . L id U y T o I u T k E n R o : w anyone else that had ever
6 three months.
7 Q. Anad tha,t, would that be starting in the 7 worked-
8 9 beg A in . n in I g d on't wan li t k t e o say because I ? 'm not positively 8 9 A Q . . N - o th , s e i r r e . ? And what were the terms of your
10 employment?
10 sure.
11 Q. So, let me ask you this: Is that your best 1 12 1 from A . 9 t I o w — o r s k o e m d e , t s i o m m e e s t I i m w e o s u I l d w w ou o l r d k w fr o o r m k fou w r e h ll o , u 9 r s to 1
1 1 1 1 1 2 4 3 6 5 estima T M T t M e H H ? R R E E . . E L W W D U I I W T T T T N N A I E E E R S S R D S S : S : : : O O S E f o k I m x a ? c y e u . t s im B e l m e e s m e s . a y y E o b x u e c . u a s f e t m er e . . . . 1 1 1 1 4 3 6 5 m t c t h h o u r e u e c l e e h d c d n o o a ' n n t y o r c s e m a a a l l y l l w y b w e e a a e c f s k f a o g , u a r o s d n e in d t t g o h o e d h th y o a e v w j r u e n m s at t e t t h h a e t r t e i m a h I s e a w , m d a a u n o s c d p p h e s r n a h e s e t e t d I y and
17 THE WITNESS: But like I said, Fm not sure. 17 wanted to be there.
18 Q. Who is the "she" you're referring to?
18 BY MR. LLTTTIER:
19 Q. That's after of 19 A. I don't remember her name.
20 A. Yes, sir. I am not exactly sure. 20 Q. Was it the owner?
2 22 1 you Q r . b e O st k e a s y ti . m I a u te n d is e r y s o ta u n w d o it r ' k s e y d o t u h r e e r s e t i f m or a a te p p a r n o d x imately 2 2 22 3 1 you Q A r . . s up A Y e e n r s v d . i y so o r u w do a n s ' o t r - - t h d e o p y e o r u s o r n e c t a h l a l t t y h o e u n a re m p e o r o t f e d w t h o o ?
23 three months?
24 A. No, sir.
24 A. Yes, sir.
25 Q. Which would take you from to about.. 25 Q. Do you recall the name of anyone at
6 (Pages 21 to 24)
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1 a st was employed there or an owner there? 1 A. Yes, sir, but that never ended up, that never
2 A. No, sir. I didn't et close to anyone there. 2 3 wen Q t . t hr S o o u t g h h e . r e did come a time that the basis of
3 4 I ju Q st . , I H w o a w s t m he a o ny n l o y t her employees were there? 4 your, the terms of your employment in terns of how you
6 5 A Q . . T D h o e y re o u w k a n s o a w ct u th a e ll y n a o m nl e y s t o h f r e th e e o o th th e e r r e m em p p lo lo y y ee e s e . s ? 5 6 7 g w o a t A s p g a . o id i I n ' c m g h t a g o n o g m in e a g d k ? t e o c s o a m y m no is b si e o c n a . u s N e o s h o e n e sa c i a d m th e a i t n I . Okay.
7 A. No, sir.
8 . What other services were rendered at Milli 8 9 So I Q d . id S n o 't s m h a e k c e o a n n ti y n c u o e m d t m o i p ss a i y o n y . o u hourly?
9
10 A. Yes, sir.
10 A. 11 Q. Were you supposed to get commissions on top of
11 Q. Anything
12 your hourly wages?
12 A. No, sir.
13 A. If I worked there longer, yes, but no.
1 1 3 4 HM Q. I And what were the terms of your employment in 14 Q. And you still don't know the name of this
15 person that you have referred to as "she"?
1 1 6 5 term A s . o ' f t h w i h n a k t y sh ou e s g t o a t r t p e a d i d m ? e off at -- here again 16 A. No, sir, l don't 'mow the name of anyone
17 am not sure. I think she started me off around ■ 1 1 8 7 the Q re . . Okay. Did you participate in any type of
18 maybe.
19 promotion for the business?
19 Q. Per hour?
2 2 0 1 com A m . is Y si e o s n . b A u n t d n t o h t e m n a g n r y ad p u e a o l p ly le I c w a o m u e l d in w . o S r o k , b a y ll in all 2 2 0 1 A Q . . N A o n , y s k ir i . n d of advertisement or anything like
22 it didn't really work out financially for myself and my 22 that?
23 A. No, sir.
2 2 4 3 fam Q il . y . Did there come a time that she increased the 24 Q. Was your name or likeness, picture or likeness
25 used in any ldnd of promotions?
25 hourly wage —
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1 A. No, sir.
1 A. No, sir. 2 Q. Were you given any information from the owner
2 Q. — that you were being paid?
3 of this .as to how to solicit clients?
3 A. No, sir.
4
5 wer
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6
6 7 Q A . . D Y i e d s , t h si e r r . e cons a time that the basis of your 7 ' had you attended that institution on any
B prior occasion before that?
8 employment or your pay changed?
9 A. No sir.
10 9 A Q . . N So o , , y s o ir u . were always paid hourly by the owner 10 Q. So the first lime you wart
11 there?
11 of the establishment? 12 MR. EDWARDS: Object to the form?
12 A. Yes.
1 1 3 4 any Q on . e D el i s d e y w o h u i r le e c y e o iv u e w a e n r y e o w th o e rk r i c n o g m th p e e r n e s ? a ti F o o n r f e r x o a m m ple, 1 1 3 4 BY Q M . R C . o L r U re T c T t? i E W R: a s t '
15 did people or clients of yours that you did work on give 1 1 5 6 you we M nt R t . o E th D e W ARDS: Object to the form.
16 you tips?
17 THE WITNESS: What does this mean?
1 1 1 7 8 9 abo A Q ut . . b N e Y i o o n , u g s o m ir n . e a n t c io o n rr e m d i s s o s m io e n t h b i a n s g is i . n W an h e a a t r d li i e d r y a o n u s w m e e r a n by 1 1 2 9 8 0 ans M T w H e R r E . . E W I D f I y W T o N u A E d R o S D n S ' S : t : k F n Y r o o w u t c h a e n a a n n s s w w e e r r - i - f you kn I o w w e t n h t e
2 20 1 that A ? . As time went on she said you can work off of 21 there. I attended the two
22 commission, but no one came in. I didn't make a 22 times.
23 MR. LUTHER: Okay.
2 24 3 com Q m . is D si i o d n y . ou agree to change the terms of your 24 THE WITNESS: Okay. One in l and one right
25 employment from hourly to commission basis? 25 now.
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1 BY MR. LUTTIER: 1 Q. You don't know your friend's last name?
2 . How did ou become familiar with or know about 2 A. No, I don't know my friend's last name.
3 the 3 Q. And you don't know last name?
4 A. Maybe the Yellow Pages. Some source of 4 A. No.
5 information on the Internet. 5 Q. How long did you know this friend a
6 Q. Do you recall which it was? Was it the Yellow 6 A. I knew ha from the neighborhood I used to
7 Pages or was it the Internet? 7 live in what I was ten years old. I met ha when I was
8 A. Yellow pages dot corn, MEM. 8 ten years old and that I bumped into her at a store. We
9 Q. That's how you found it? 9 exchanged phone numbers. She introduced me to III an
10 A. Yes, sir. 10 I started
11 Q. And are you a person that considers yourself 11 Q. And although you knew this person since you
12 to be computer proficient? 12 said you were Mold, you can't recall her last
13 A. No, sir. 13 name; is that right?
14 Q. iEnsu use the computer on a regular basis? 14 A. That's right.
15 A. I have been. 15 Q. Is there — by the way, do, do you have any
16 Q. What do you mean by "Mr 16 problem with your memory that you're aware of/
17 A I have been selling a couple of items 17 A. Yes.
18
18 Q. What is your problem with your memory?
19 Q. What kind of items? 19 A. With a lot of negative situations, I tend to
20 A. Items around the house like dresses, shoes, 20 not really, I don't really care to ri..ux.iikgsi than.
21 items that i have. 23. just live every day as it oomes as positive as I can. I
22 • Are, are you selling items as a 22 try to exclude any negativity. And when it comes to
23 for 23 negativity, I choose, I guess I choose not to remember
24 A. LI in them in I never pursued 24 it.
25 it. So, as of right now I am taking the products that I 25 Q. Is there a difference between attanpting to
Page 30 Page 32
1 do have and I am selling them. 1 block out some negative thing and not being able to
2 Q. Okay. When you say that you with 2 remember the negative thing?
3 in what do you mean? 3 A. Okay.
4 A. I paid worth of 4 MR. EDWARDS: Object to the form.
5 THE WITNESS: 1, I do choose to block out. I
5 so I could profit.
6 Q. Turn around and sell it for a profit? 6 remember but I do choose to block out.
7 A. Yes, sir. 7 BY MR. LUTHER:
8 Q. Did you execute some paperwork to become a 8 Q. So, you would say you're a positive type
9 for lack of a better term with IMMI 9 person?
10 A. Yes, sir. 10 A. Yes, sir.
11 Q. Did you deal with someone that was affiliated 13. Q. You believe in positive thinking as opposed to
12 with when you first began to do that? 12 negative thinking?
13 A. Yes, sir. 13 A. Yes, sir.
14 Q. And who was that? 14 Q. You put behind you those things that you don't
15 think were positive for you and you choose to
15 A.
3.6 Q. Did you say 16 concentrate on those things that are positive?
17 A. 17 A. Choose to concentrate on positive things.
18 Q. 18 Q. Are you a person that you would say is a
19 A. Yes, sir. I don't know her last name. 19 forward-looking person; that is a person that looks to
20 Q. And how did you get in touch with her? 20 the future as opposed to the past?
21 A. Through a friend. 21 A. I look to the, I looked to the, I look to the
22 Q. And who was the friend? 22 future, but the past does haunt me.
23 Q. Okay. Now, you mention that although you try
23 A.
24 Q. what? 24 to block these things that you do remember them. So, I
25 want to go back and ask you if you remember last name of
25 A. I don't know.
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1 A. I don't know.
2 A. No, sir. When I was ten, I really didn't care 2 Q. Was it your practice to keep important legal
4 3 to k Q no . w W an e y ll b , o y d o y u ' s s a la id s t y n o a u m f e ir . s t met her when you were 4 3 5 papers M T th H R a E . t E y W o D I u W T s N i A g E R n S ? D S S : : Y O es b . j e T c h t a to t w th a e s f n o 't r m ve . r y important
S ten, right?
6 A. Yeah. She was an acquaintance. 6 to me.
7 Q. And so how long did you know her, from ten 7 BY Q M . R W . L h U at T s H o E rt R o : f important legal documents do you
9 8 unt A il . n o N w o ? , l knew of her, but she was a girl in my 9 keep? Or excuse me, what sort of important document do
1 1 1 1 0 2 3 1 n a b y a e s o s i u w g h e b g o d o r i h t n o o t l o o d f d h e r o e t r h , m r I a a t t d t h w o a e n e n s ' j t t e u o k i s g r n e t h o . s b w a A o w r w n h o h d o n e o F c r d m e e . s i l n O h ik e a h e w , , w y h a h o e s i u . y l e , h B . a a u r A v e t e n n I ' a d t k th id e ; n 1 1 1 1 0 2 3 1 I y S o k e u e c A e k u . p e r i e t a K y p l e l c ? o a e r p f d m m . y 1 y s k t o a e n e x ' p s r e m re tu o c r o n n r e s d y . s o I . r k I d e e k e e r p s e t m p h m a y t s y w S o h o e n c n i a a I l p ll a . y the
1 14 5 s c e o e o h l, o I w ha y v o e u a 'r e k i d d o t i o n o g . i n L e lif t e m . e I g d e o t n y 't o k u n r o n w um h b e e r r la . s L t et me 1 14 5 bills Q . . Anything else that you can think of?
16 A. No, sir.
1 1 1 6 7 8 n in a t m r Q o e d . . u c O e k d a y y o . u B t u o t t i h n e a c n o y n c e e v p e t n o t, f s he's the one that 1 1 7 8 mil iAd f i t d e r y y o o u u e h v a e d r h th a i v s e h a a n p y p e o n th s e ta r n c c o e m m m e u e n ti i n c g a t w io i n th w ith
1 2 2 9 0 1 M M TH R R E . . E L W U D I W T T T N A I E E R S R D S : S : R : Y i O g e h b s. t j e ? c t to the form. 1 2 2 2 9 0 2 1 h t w o e e g i A e r h t a . h d e W r a , c a e t n u h d a a l w d ly e a o h c n a o e d attended to a ° g d t e m i t n h y e g r h s o o . n u W e s e t e i m ll, e .
2 2 2 3 BY Q M . R W . L a U s T sh T e I E a R pe : rson who that was selling NM 2 24 3 pro Q du . ct D th id a t y y o o u u e h v a e d r a pu ct r u ch a a lly se s d e l f l o a r n
24
25 A. Yes.
25 A. Yes.
Page 36
Page 34
1 Q. Did she have some kind of franchievsitIttltem? 1 Q. And during what period of time did you
2 3 She A i . n tr l o a d m uc p e r d e m tty e s t u o r e. She - w s o ig rk n e e d f d o r me up. 3 2 actu A a . l ly W se he ll n p r I o f d ir u s c t t ? st arted, and I would just keep
4 Q. When you say signed you up, wit:1.1)cm? 4 the products in my trunk And if I was out on the
5 A. I filled out paperwork to hand ov 5 6 s w tr h e e e r t e a v t e a r a g as sta ls tion o l i r s g k o in a g t w o o t m he a n g r i o f c t e h r e y y s w to o re u , l d like
6 7 . And did — was part of the arrangement that 7 some And if they did, l proceeded to
8 =would receive some sort of compensation or a 8 sell them to that woman.
portion of your sales? 9 Q. Did you have — was that your sole source of
10 A. Not that I know of. Who knows? I don't know. 10 support at the time?
1
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u nity that I went for and found out 1 12 1 A Q . . N W o h , a s t i r o . t her source of support did you have?
13 Q. Did you read the document that you signed? 13 A. At what period of time?
14 A. I didn't read up to the point where it said 14 Q. You what?
15 that she was going to get profit. I didn't really care 15 A. At what period of lime?
1 1 1 6 7 8 i t f h a s Q h t e y . o g u o T s t h a i e g p n q e r u o d e f ? s it t . i o I n f w sh a e s , d d id id , g y o o o u d r . e ad the document 1 1 1 1 6 7 8 9 L M a . Q g A . . A M a T n W h I d a M t d a w o E r a i y = g s o m i u S y re f , c n a o l t l m w w h y e t h o im n i n c i e l h n y w m I s M o h i u il s r e l c a e y a id o p o u p y f r h v o o e i x b a im i m ll a tel n y o ? . in
1 2 9 0 Q A. . P A a n n d o w f h it a . t part did you read? 20 Approximately when did you initially MINI in
21 A. That I will be spending `so 21
22 A. I couldn't tell you.
22 I can
23 Q. Do you have a copy of the document? 23 Q. Roughly.
24 MR. EDWARDS: Object to the form.
2 24 5 Q A. . N W o h , a s t i h r. a ppened to the document? 25 MR. LITTLER; lam not owing you to a specific
team
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1 date. Within two months. 1 reside with him?
2 MR. EDWARDS: Object to the form. If you 2 A. Around five months.
3 know, answer; if you don't know, you don't know. 3 Q. Okay. But from what date to what date?
4 MR. LUTTiER: You can't recall? 4 A. I told you. You can do the math. I turned, I
5 THE WITNESS: i can't recall. 5 was 18.
6 Q. When were you 18?
6 BY MR. LUTTIER:
7 Q. Okay. And for how long did you sell these 7 A. Excuse me?
8 MR. EDWARDS: Object to the form.
a products?
9 A. Sr, I took the products. They weren't my 9 BY MR. LUTHER:
10 full source of income. I sold them whenever I sold 10 Q. When were you 18?
11 them. When i was at a gas station, maybe I would.. 11 MR. EDWARDS: Object to the form.
12 When I was at the grocery store, I might 12 THE WITNESS: I am 21 now.
13 It wasn't my full source of income. 13 BY MR. LUTTIER:
14 It was just a little gas change. 14 Q. My question is when were you 18?
15 Q. Okay. And at some point you stopped 15 A. When was I 18?
16 attempting to sell the product and decided to try to 16 Q. Yeah.
17 A. Can you give me a piece of paper and a
17 sell them ovellIk
18 pencil-
18 A. Yes.
19 Q. What, what other source of income did you have 19 Q. Sure.
20 while you were trying to se 20 A. — so I can find out --
21 A. i was workisja in and out o 21 Q. No problem.
22 Q. In the yea — and you have testified 22 A. — when in the hell I was 18? How about if
23 earlier that, I think u said about is when you 23 you do the math?
24 first went to, to this -- did you 24 Q. There you go, ma'am.
25 have any source of support, financial support? 25 A. Can you do the math? Is it —
Page 40
Page 38
1 MR. EDWARDS: Object to the form. She will
1 A. Yes, yes.
2 li t What were your sources of financial support in 2 give her date of birth, and it's a, ifs a factual
3 issue as to when she turned 18.
3
4 A. I had a boyfriend that supported me, my son 4 BY MR. LUTTIER:
5 Q. You don't — so, are you telling us here in
5 and I.
6 Q. And what what was that boyfriend's name? 6 this deposition you don't know when you turned 18?
7 A. Sr, i was 18 when i met the man and i turned
7 A.
8 19.
8 Q.
9 Q. And what's the date of your 18th birthday?
9 A.
10 Q. And did he provide the sole support for your 10 A. i don't know of what year.
11 Q. You don't know what year you
11 and son, you and your son?
12 turned 18?
12 A. Yes, he did.
13 Q. Did he live with you at some point in time? 13 A. No, sir.
14 A. I lived with him at some point in time. 14 Q A. . I Wh L en were you born?
15
15 Q. And when was that?
16 A. That was in — I just turned —1 was 18 when 16 Q.
17 lgot with him, and I just named 19. And we were 17 A. Yes.
18 together for, we lived together for around five months. 18 Q. Okay.
19 Q. What did you mean when you said you got with 19 A. I am not so wonderful with math if that's what
20 you're asking.
20 him when you were 18?
21 A. We started dating when I was IS. I moved in 21 Q. So, when you turned 18, which if your numbers
22 his house when I was i8 and then I turned 19. I 22 are correct and if m math is correct, that's going to
23 remember having my 19th birthday. We lived together for 23 put it a
24 A. Okay.
24 around five months.
25 Q. So what, what period of time then did you 25 Q. So, you moved in with him in And
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3 the address o .
3 A. Yes.
4 So that means you were living with hint US 4 Q . ?
5 A. Yes.
5 6 Q. Okay. And where does your dad or where did
6 A. i. 7 your dad live at that time?
7 Q. Yes?
8 A.
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10 9 Q A . . A O n k d ay t . h e A n c w tu h a e ll n y d ] i g d o y t o w u i m th o h v i e m o i u n t . f . r . o m him? 1 1 0 9 1 app Q ro . x i A m n a d te d l id a y tw ou o - m m o o v n e t h in p w er i i t o h d y b o e u t r w d e a e d n for of I
11 Q. Of what year?
12 of. ?
12 A. 1 was 18.
13 A. I moved in with him
13 Q. We established that was
14 Q. Okay. Ofd?
14 s A Q . . O So k a i y f . i t was-, that would make in. 15 A. I.And then 1 moved into the on
right? 16
1 1 6 7 A. I was 18 when I got with him. That was in 17 Q. And did your son move in with your dad with
1 1 8 9 I m E a . t h. F I m do s n o 't r r k y n . ow what year. I am not that good with 1 1 8 9 you A ? . My son has always been with me since he was
20 Q. Well, if you were, which 2 2 0 1 bom Q . . Has there ever been any kind of judicial
21 you've agreed you were, right? 22 proceeding or administrative proceeding brought to
2 2 2 3 Q A. . A Ye n s d . , and if you moved in with him in.' of 23 change where your son lives? In other words, have you
24 the year when were 18, the on,. that could be 24 ever — do you know who.. is?
25 would b isn't that right? 25 A. Yes.
Page 44
Page 42
1. Q. Has there ever been any kind ollilliproceeding
1 A. Sure.
2 that you have been involved?
2 Q. Okay.
3 A. Unfortunately, yes.
3 4 Q A. . I S f o t , h i a t' t s 's y c o o u r r r e r c ec t. o llection as you sit here 4 Q. Were you involved in that proceeding; that is
5 today that you moved in with this entleman in'. of 5 was the proceeding were you a party in that
6 II or that you started dating ii 6 proceeding?
7 A. We started dating and I moved in with him 7 A. i went through a with a
8 previous boyfriend.
8 about two, a month later.
9 Q. Okay. And you lived with him for 10 9 Q A. . O A k n a d y t . h at's how co got involved.
10 approximately five months?
11 Q. Was there a formal investigation?
11 A. Yes.
12 So that, that means you moved out in around 1
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13
1 1 4 5 A Q . i mean 9 of I'm sorry. Right? 1 1 4 5 A Q . . ' O 06 k . a y. Now, I had asked youW roeus whether
16 A. I moved out when I moved into the 7 — or when 16 you had any source of support from all
17 'moved into the which was or 17 forward. And told me —
18 A.
18 which wastzah, 19 Q. — that you lived with this boyfriend. But
19 Q. Of.? 20 now you have described the time that you have lived with
2 2 2 0 2 1 dat Q e A t . . h a Y A t l e y l s o r . u i g m h o t. v S ed o , o t u h t a w t c a o s r rest b o e f li eve n th o e t 2 22 1 t w h i i t s h b h o i y m fr i i e n n l d IM an I d E of tellin S g o m a e p p th a a re t n y t o ly u h m e o w ve a d sn o 't u t
23 providing support to you in
23 of M; is that right?
24 A. No.
24 A. 1 moved out sometime in 25 Q. Did he -- he didn't provide you support after
25 Q. Did you live anyplace —
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1 you quit living with him, did he? 1
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4 Startin 5 Mr. Epstein. Until that issue is resolved, she's
5 6 A Q . . O W k h a a y t . means of support did you have ill.? 6 7 a n d o m t g it o t i e n d g t t o o b a e n i s n w g e a r c s a p l e l c g i i f r i l c . s S ex h u e a w l i i l s l s c u o e n s. t in S u h e e 's
7 A. I worked at —
8 9 M M R R . . C LU RI T T T T IE O R N : : W H h e a c t a , n I ' t m d e o a n th — at. 8 9 to d S o h s e o 's . not going answer the names of the places
10 MR. LUTI1ER: Whoa, whoa, whoa. I don't think 10 where she did it or any Joint's as we feel that
1 12 1 c y l o ie u n c t a w n h s e it n o i v a a m a t n a d k i s n ta g r h t e c r o n d f e e p r o ri s n it g io w n i . t h your 1 1 1 2 1 3 i r a s e n s s s u o w e lv e h e r a d . s , A n w o d e t d ' r b i e t e i o i e n n n s a t c l r o l u y v c o e ti r n n e g t d h . o o u A s r e n c q d l u i e u e n n s t t t i i n o l o n th t s a , t o t w i e s are
1 1 1 1 1 4 3 6 5 7 i d t o 's e M M M a s n n R R R ' a t . . t a E L t E p o D U D p rn T W e W e a T y r A A 1 - t c E R R h l R e D i D e r : S e n S t : I : i s p m O T . r i e h k Y v a a a i o n l y t e ' u , . s g i w c f e a y h i n s o y s u a u I s ' v e k w e — y a g s o o u a t s r a k i - n - g if . It 1 1 1 1 1 4 5 6 7 8 s i r c n i i l l g v e e h o a M n t r k t o R , i r n t f e . i g c p g L o h r h U i r e t v d r T o a , F c T f I y i p I a f E r m t o h i R f v g A a t : h o c m O i y i r n d k a e g - a s n p b y d t a r . o r a e r a r L r y a e k e r i . t n t i , h m g d o i h e v s a , e i t s d j q t u w u o u s a e t e r l l e s s s l . m t o a io s a w n i t n e h s e h d a o v w e n a
18 question.
19 MR. LUTHER: Okay. What - 19 and then you can --
20 THE WITNESS: I worked -- 20 MR. EDWARDS: Sure.
21 MR. EDWARDS: The question is what she was 21 MR. LIMIER: — assert your objection.
22 BY MR. LUTT1ER:
22 doing to make money? 23 Q. You said that you worked inet are
2 24 3 BY Q M . R W . L h U at T f P o T rm ER s : o f su rt did you have or means of 24 the names of the, what you referred lt o where
25 you worked?
25 support did you have in=?
Page 48
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1 MR. EDWARDS: Same objection. Don't answer.
1 2 A Q . . I W w h o a r t k R e i d n d in o fd? 2 MR. LUTI7ER: What, what specifically is the
3 A. Icindba m 3 objection to that?
4 What do you mean kinds of 4 MR. EDWARDS: The objection is that this issue
5 is up on appeal. And the Fourth District Court of
5 6 Appeal has issued a Rule to Show Cause Order
6 A. I worked as an escort.
8 7 Q A . . W Wh o a w t , d I o w y o o r u k e m d e a a s n a b c y a e ll s c g o ir r l t . ? I worked as an 7 8 d re ir s e o c lv te e d d , t o w w e a 'r r e d n s o M t a r. n E sw ps e t r e i i n n g . t U ha n t t q il u th e a s t t i i s s s . u T e h is e
10 9 esc Q or . t . M D a o ' a y m ou , I n w ot a k n n t o to w m w a h k a e t s a u n r e e s w co e r d t o is n ? 't have a 10 9 b th a e s i p s r o iv f a t c h y a t r i i s p su a e o i f s t t h hi e r d p r p iv a a rt c i y es r i a g s h w ts e ° ll F a M s th . e ,
11 definitional problem. So now you have said you worked 11 invocation ofa.'s Fifth Amendment tight to
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14 MR. EDWARDS: Object to the form. 1
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15 BY MR. LIMIER:
16 Q. So, in your, in teens of this deposition, if 16 a portion of interrogatory 19 where you chose to
17 you refer to a call girl or an escort, those things mean 17 answer certain portions and not to answer other
18 the same thing in your mind, correct? 18 portions. Portion dealt with, in essence, prior
1 2 9 0 A Q . . I O t k m ay ea . n W s t e h l e l, s t a e m ll e m t e h i w n h g a i t n y e o v u e r d y i b d o a d s y a 's c m al i l n d. 1 2 9 0 tim T e. h e A c n o d u r I t w h i a l s l p n u o t t i i t s s o u u e t d i , f J n u e d c g e e s s H ar a y f . e le didn't
21 preclude any type of questioning with regard to
21 girl, escort inl.?
22 A. I performed sexual, sexual things for men for 2 2 2 3 i w n o co rk m e e d - , r w el h a a te t d s h is e s d u i e d s , a h s o s w oc s ia h t e e d m w ad it e h h w er h e m re o n s e h y e , bow
23 money.
24 Q. And what sort of sexual things did you perform 24 much income she did make.
25 You have a claim for loss of canting, loss of
25 for men for money ina?
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1 2 e a a p r p n e i a n l g n c o a r p d a i c d i t y y o h u e o re b . j e N c o t t n o e t h o a f t t . h a Y t o w u e d n e t u al p t on 1 2 BY Q M . R U . L n UM e? . E:. You said since, but did
3 specifically with some aspects of prior sexual 3 you mean until?
4 A I stopped. Until
4 6 5 h th is e t S o u o r p y c I . o b m eg in t g o a d p if p f e e a r. l is T h u a n t d 's e n r o th t e p a c r ir t c o um f w s h ta a n t ces. 6 5 rec Q al . l as O m ka a y r . k in Is g t t h h e e r e p o a i s n p t e in ci f ti i m c e e v t e h n a t t t y h o a u t y q o u u it c b a e n in g
7 And I think it's inappropriate. Well, well let 7 a prostitute?
the judge decide what is appropriate or not under 8 A. Specific event?
9 Q. Yes
9 the circumstance.
10 MR EDWARDS: She will testify to what money 10 A.
1 12 1 s J h o e h n m s a . d T e h , a ju t' s s t i n t. o t S t o h e I u n n am de e r s s t o an f t d h t e h p a l t a w ce e s h a a n v d e t a h e 1 12 1 you Q t . o s A ta n te d t w h h at a t t h is a t i t w t a h s a t t h y e o d u a c t a e n in re w ca h l i l c t h h a y t o a u l l q o u w it s
1 1 3 4 disa M gr R e . e G m O en L t D . T B h E a R t' G s m ER y : p o I s n i e ti e o d n . t o clarify one thing. 1 1 3 4 bein A g . a I p r a o n s t t s it i u c t k e o ? f the lifestyle. That's what I can
15 Jack Goldberger on behalf of Mr Epstein. 15 recall.
1 1 6 7 que Y s o tio u n h : a P ve ri r v a a i c se y, d t h th e r e is e s o u b e j t e h c a ti t o 's n o s n t o a p th p a e t a l and 1 1 6 7 dec Q is . i on S b o, y i t y o w u a s o n n 't a ecific event t I h t a w t y a o s u a n o longer
18 the Fifth Amendment. Should your objections be 18 wished to be a prostitute; is that correct?
1 2 2 2 9 0 2 1 o t b in h v e a t e e h t r ' n a s ru d l o f l t e o n o d f a i y n o p o n v p u o e t r h a k c e l e i l i n r t e h ig n t e h h t ? F e t i o F ft o f h p u A r r i t v m h a D e c n y C d a A m n , e d d n o o t n p y r t o h iv u e i l s e is t g s il e u l s e on 1 2 2 2 9 0 2 1 i m ll a A Q ki . . n o g f C A I t I h o n , e r d r e d w d c e a u t c . s r i i s n t i h o g e n t r h e a e t a p a n e n y r y t i h o t i i d n m g f e r t o h d m a u t r p in re g v t e h n a t t e p d e y • r i o o u d t f t o r h o a m t
23 MR. EDWARDS: I'm sorry, what was the last 2 2 3 4 you A w . is i h e d d o n to 't u q n u d it e b rs e t i a n n g d a w p h ro a s t t y it o u u te a ? r c a in I me.
2 2 4 5 par M t? R. GOLDBERGER: Yes. Should your objections 25 Q. Was there anything between and
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1 be overruled, overruled on privacy issues and on 1 of that prevented you from quitting being a
2 4 3 t C in he t o e w i n ss d l u o t e o f s A i n t p h v p a o e t k a a e r l e F a s b i f e t t o h fo t A r h e m is t e h q n e u d F e m s o t e u io n rt n t h , p D y ri o v is u il t e s ri g t c i e t ll s on 2 4 3 pros A Q ti . . t u N D te i o ? d . n W 't y e o l u l, y ju e s a t h a , s y k o m u e s a th id e y q o u u e d st id io n n ' , t sir?
5 understand it, so I asked it again.
behalf of your client?
6 7 8 w ad o v M u e l r R d s e c . o E in n D f c e W e re d A n e c R t e h D s a S t t h y : a o I t u y d a o o r u e . b e A e n n l t i d i e tl v u e e n d d y t e o o r u w t h a h r a a e t t e p v o e in r t we 6 7 8 any A Q th . . in F i g s t r a h o i a d t I m p w re a . v s e s n i t c e k d o yo f t u h t e f o r l o if l m e l s s ty t o o le p . f . p . i ng is b t e h i e n r g e a
9 prostitute at any time during that od?
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12 whatever other relief is appropriate under the 1 1 2 3 tiss Q ue . ? You were seeing ralMil between —
1 1 3 4 circ M um R s . t E an D c W es A . RDS: Of course. Whatever the judge 14 MR. EDWARDS: Let me just grab the witness a
15 tissue.
15 decides. 16 MR. LUTHER: I am going to take a bathroom
16 BY MR. LUITIER:
17 Q. MIN were you working as a prostitute? 17 brealc.
18 MR- EDWARDS: Okay.
1 1 8 9 A Q . . H Y a es v . e you ever worked — or for what period of 19 THE VIDEOGRAPHER: Arc we going off the
20 time in did you work as a prostitute? 20
21 MR. EDWARDS: Sure.
2 2 2 1 Q A. . W Ye h s a . t F p r e o r m iod a o l f time? until when? 22 THE VIDEOGRAPHER: Going off the record. The
23 A. Until, well, - since ofI . 23 time is 10:41 am.
24 (A brief recess was held.)
24 MR. CRITTON: I'm sorry? 25 THE VIDEOGRAPHER: We're back on the video
25
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record. The time is approximately 10:52 a.m. 1 Q. And that would be when? What date?
2 MR. EDWARDS: Okay. We had an issue come up 2 A. 2002.
3 where everybody that represents Mr. Epstein decided 3 Q. And that's when you first became sick of what
4 to chime in on a certain issue. And I know that 4 you have described as the lifestyle?
5 that was an isolated incident. I am assuming that 5 A. Yes.
6 everybody realizes, you know, the rules here and 6 Q. How long have you been a prostitute?
7 you have chosen your examiner, and that's going to 7 A Well, ever since I was lured into Jeffrey's
8 be the person speaking for Mr. Epstein, or on his 8 house.
9 behalf for the reminder of the deposition. We're 9 Q. Which is when?
10 not going to get double or tripled teamed. 10 A. 2002 when i was 13.
11 MR. CRITTON: I get -- let me speak to that. 11 MR. GOLDBERGER: Can we just stop for a
12 MR. EDWARDS: Okay. 12 second? We're having a technical issue upstairs.
13 MR. CRIITON: You have got five lawyers, five 13 Apparently we're, we're mooted. Can we do
14 to seven lawyers here on Plaintiffs on every 14 something about that? Thanks. I appreciate it.
15 deposition that i have attended- I have had five 15 MR. LUITIER: Okay. What was the last
16 separate Plaintiff groups that all chime in on, on 16 question? I mean, what was the last answer?
17 everything. We arc not impacted in the deposition 17 (The requested portion of the record was read
18 with your client at all, i.e., we're not chiming in 18 by the reporter.)
19 to question her at all. 19 BY MR. LUTHER:
20 What we are is Mr. Goldberger has certain 20 Q correct, you said were you
21 information that I am unaware of, so he deals, 21 born
22 dealt only with the objection. It was a 22 MR. EDWARD$: Object to the form
23 lawyer-to-lawyer issue. There are certain 23 MR. LUTT1ER: And i haven't asked a question
24 information that I have that Mr. Luttier does not 24 yet.
25 have. So that's again a lawyer-to-lawyer issue 25 MR. EDWARDS: Well, that's not what the
Page 54 Page 56
1 only on the record. It does not deal with — only 1 witness said. That's not the date of her birth,
2 one lawyer is going to be asking questions. Only 2 That's not the answer she gave. So, i am just
3 one lawyer will do any objections or comments with 3 correcting you to help you out.
4 regard to III 4 BY MR. LUMER:
MR. EDWARDS: Okay. 5 Q. Okay. What, what you did say your date of
6 BY MR. LUrlIER: 6 birth wilaa'ag?
7 Q. the question I had asked you before we 7 A. ISM -
8 took the break was whether there was anything that MR. LUCITE! 't read my handwriting.
9 prevented you from t • empluaent vat 9 Stand corrected. Ma Thank you counselor.
10 prostitute between and ME of to BY
11 A. i was sick of the lifestyle. 11 QN. INA' So accorgwase
12 Q. Okay. And when did you become, to use your 12 calculations, if my math is right,E MI of 2001 is
13 words, sick of the lifestyle? 13 when you would have turned 13, correct?
14 A. I never liked the lifestyle but you can only 14 A. If that's, if that's right.
15 endure so much pain for so long. 15 Q. And it was sometime in 2002 that you recall
16 Q. And what you say pain, are you referring to 16 that you first met Jeffrey?
17 physical pain or are you referring to mental pain? 17 A. Yes.
18 A. Both. 18 Q. Now, prior to the first time you met Jeffrey,
19 Q. And when did you first become, to use your 19 had you been a prostitute?
20 words, sick of the lifestyle? 20 A. No.
21 A. Since I met Jeffrey. 21 Q. Did you do anything prior to the first time
22 Q. Which is when? 22 you met Jeffrey with respect to receiving money or
23 A. When' was 13 years old. 23 anything of value in return for any type of sexual
24 Q. Thirteen now. Is that what you said? 24 favor? J
25 A. Yes, 13. 25 A. No.
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1 3 2 4 a fo s r a m n . o e n s D e c u o y r r , t i w n a h n a d th t u y i t s o y n p u p e e t w s r i e i l o o . r d f e a f d c r o o ts i m n d g id s e y , x o u w u a h p l e e t t h n r o i f n y o l g o r l m s u , f w o o e n o r r m r m e e e a n n c ? ti ng 1 2 3 4 s n w e ig o l Q h f u -c t ld s . o . n n W e D tr e a e i d d c l t l t , o y o l o r . b m u e I e w d d a o o o n r n n k d e ' t b i . d k o n S y th o o o ? w m u e h w T t o h i o m w a rk t e ' l s s o d i w n a t y g h t s a a t , h k t d a e I i s t d a s t m y w e o x o t u u r m y a w i l n i n o n g e u rk t e t o e d s .
5 MR. EDWARDS: Don't answer. This deals with 5 get
6 7 I a n p te p r e r l o la g t a e t i o s r s y u N e, o in . s 1 t 9 ru . c T t h in is g i t s h e p a cl r i t e o n f t t t h h e e refore 6 7 A Q . . B W o o th u . l d you typically work at night?
8 9 n th o e t F to o a u n rt s h w D e i r s t t h ri i c s t q C u o e u st r i t o o n f u A n p t p il e it a 's l a re s s t o o l v w e h d e b th y e r 8 9 A Q . . N So o , . you were worldng during the day primarily?
10 she has to answer on specific sexual acts So, 10 A. Yes.
11 she's not going to answer today. 11 Q. As an escort?
1 1 2 3 obj M ec R tio . L n U o T r a I1 re E y R o : u I a s l s th o a in t c th o e r p s o o r le a t b in a g si y s o o u f r t hat 1 1 2 3 Q A. . A Ye n a d h d . id you keep any record of your earnings?
14 objection on the Fifth Amendment? 14 A. I have in the past.
15 MR. EDWARDS: I am incorporating into that 15 Q. h Du . rin . g what period?
1 1 6 7 o h b e j r e r c ig ti h o t n o th f p e r F iv if a t c h y A a m nd e n th d e m p e r n iv t a a c rg y u r m ig e h n ts t a o s f well as 1 1 6 7 2 A A . nd what record did you keep of your earnings
18 in
18 third parties.
19 A. A day-to-day record.
19 BY MR. LUITIER:
20 Q. How much money did you earn in.. as a 20 Q. What?
21 A. A day-to-day, daily record.
21 prostitute?
22 Q. Okay. Like a journal?
22 A. I couldn't count. A lot.
2 24 3 Q A . . D W o h a y t o d u o w y a o n u t m m e e a t n o b te y l " l a yo lo u t h "? o w much moneyl 2 2 3 4 A Q . . Y A e n s d . what would you — was this a book that you
25 kept?
25 made in that whole year?
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1 Q. Yeah. I mean, I don't expect 1 A. Yes.
2 Q Is it like a — describe the boot( Is it a
2 A. Not possible.
3 Q. — you to know the exact dime, to the dime 3 diary or something like that?
4 5 but ap M pr R ox . i E m D at W el A y h R o D w S m : u O c b h j e d c id t t y o o t u h e m f a o k r e m i . n I S? 4 A Q . . Y O e k s a . y . And do you still have this diary?
6 A. Yes.
6 If you know.
7 THE WITNESS: I don't know. 7 Q. Okay. What do you call this diary?
8 A. A book.
BY MR. LUTTLER:
9 Q. What did you mean when you said a lot? Q. Is it -- does it have a name on it?
10 A. I would make sometimes a thousand dollars a 10 A. No.
11 day; sometimes $2,000 a day; sometimes $300 a day; 11 Q. Describe the book
12 sometimes $400 a day-, maybe $500 a day; maybe $600 a 12 A. It's red.
13 Q. It's got -- are them pages in it?
13 day.
14 Q. And, and so what was -- when you said you made 14 A. Actually it has a Bible verse on it.
15 a lot in., what did you mean? 15 Q. Are there pages in it?
16 MR. EDWARDS: Same objection. 16 A. Yes, there's pages in it.
17 THE WITNESS: Sir, I don't know. Like I told 17 Q. Are the pages blank?
1 1 2 8 9 0 d y n o a e u y x ; , t I o d n m a e y a . g d I r e a d $ n o 2 d n 0 m ' 0 t a k a y n b d o e a w y o . o n n e c d e a ; y 2 ; , m $ a 3 y 0 b 0 e a t w da o y g ; r $ a 4 n 0 d 0 t h a e 1 1 2 8 9 0 r a e n m s M w a R e in r . . s E I i n l D e v n W o t k a A i s n R t g D o h S w e : h r a F O t i b f is t j h e in c A t t m t h o e i s t n h b d e o m f o o e k r n . m t r . i g D h o t n to 't
2 22 1 BY Q M . R A . L n U d T h T ow 1E w R e : r e you paid? 2 2 2 2 3 1 B w Y o Q r M d . s R a M . r c L y U t h q T e u y T e s p IE t a io g R n e : s is o a f r b e l a th n e k p p a a g p e e s r b o l r a a n r k e ? t h In ey o l t i h n e e r d
23 A. Cash.
24 Q. Did you have hours that you worked in 24 pages?
25 A. Did I have hours than worked? I was my own 25 A. The are lined.
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1 Q. Is it — does it have a name on it lac diary 1 2 BY Q M . R D . i L d U y T o I u T k E e R ep : in this book the names of any
2 on it?
3 A. It has a Bible verse on it. 3 individuals?
4 A. No.
4 Q. On the cover of it? 5 Q. For what purpose did you keep this book? OrT
6 5 Q A. . Y O e k s a . y . And, and you kept this book fort! 6 7 s h h a o v u e l t d e n s ' t t i s fi a e y d t t h h i e s r b e o i o s k m . o T re h e th se a n b o o o n k e s , c b o e r c r a e u c s t? e you, you
7 9 p i e th r A i i o n . d k o I I f r h e t a i c m v o e r e d ? k ept m it y i i n n whe f n o ra y I e w ar a . s working, and 10 8 9 a A n m s M w en e R d r . m t E h e D i n s W t q r u A i e g R s h t t D i o o S n n : . t o O S t h b h e j a e t i c s a t s i t n o w v t o e h l k e l i . n fo g r h m e . r F D i o ft n h ' t
10 Q. From net 11 MR. LIJITIER: The question for what purpose
11 A. Alto
12 Q. Those complete calendar years? 1 1 2 3 did M yo R u . k E e D e W p t A he R s D e b S o : o C k o s? rr ect. That's something that
1 14 3 A Q . . Y H e a s d . you ever kept a record of zps.income for 14 should she provide an answer could provide a link
15 any prior year, that is any year before =' 15 in the chain
16 A. I have some record of a couple of months but 1 1 6 7 BY Q M . R W . L h U er T e H ar E e R th : ese — how many of these books are
17 not as much as the whole year.
18 Q. Cou le of months of what year? 18 there?
19 A. Two or three.
1 2 9 0 Q A. . Are all of those records in the same book or 2 2 0 1 . Q M A R n . d E w D h W er A e R ar D e S th : e O y b cu je r c re t n to tl y th l e o c fo a r te m d . ? Don't
2 2 2 1 are A th . ey D in if f d e i r f e fe n r t e b n o t o b k o s o w ks it ? h lined paper. 22 answer. invoking her Fifth Amendment right as to
23 Q. And what information did you record in these 2 24 3 the M lo R ca . t L io IM n. ITER: How is the location going to
24 books?
25 MR. EDWARDS: Don't answer. invoking her 25 violate the Fifth Amendment?
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1 Fifth Amendment right to remain silent as to the 1 MR. EDWARDS: I stated my objection.
2 language that is in these various books.
3
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3 MR. LUTTIER: Before --
4 MR. EDWARDS: -- outside the fact that she's 4 A. No, sir.
5 admitted to keeping a tally of the money made. 5 6 Q. M N R o . o E n D e W at A al R l? D S: Object to the form, asked and
6 BY MR. LUIIIER:
7 Q. Before we get to the, exactly what the books 7 answered.
8 said, I want to ask you about what information is THE WITNESS: No, sir.
9 BY MR. LUITIER:
10 9 con A ta . i ne M d y th i e n r c e o . m D e o . e W s t e h 'r is e - t - alking about my income. 10 Q. Did you utilize the information that was
11 contained in these books for any reason?
1 1 1 1 2 3 Q Q A . . . S T T o h h a i t s t h ' b s is o w - o - h k a c t' o s n c t o a n in ta s i d ne o d ll a in r f t i h g e u b re o s o ? k . 1 12 3 A. M N R o . , G si O r. L M D y B o E w R n G p E e R rs : o C na a l n k w n e o w ju l s e t d g g o e off the record
14 A. Yes. My income, dollar figures. 14 for one second.
1 1 5 6 the Q d . a te D o o n e w s i h t i c c o h n y ta o i u n r - e - c a e l i l v r e i d g h ce t. r t D ai o n e d s o i l t l a re r f s l ? e ct 1 1 5 6 T M H R E . L V U ID T E T O IE G R R : A S P u H re E . R: Going off the video record.
1 1 7 8 Inv M ok R in . g E h D e W r F A if R th D A S m : O en b d j m ec e t n io t n r . i g D ht o a n s 't t a o n t s h w at e r. 1 1 1 7 9 8 The T ( A t H i m d E i e s V c is u ID s 1 s E 1 i : o O 0 n G 5 w R as a A m s P h I e L ld E R of : f W the e ' r re e c b o a r c d k ) o n the record.
19 question.
20 The time is 11:05.
20 BY MR LUTTIER:
2 2 2 2 2 1 3 4 oth Q e F r i . f i t n M h D f o R A o r . m e m E s e a D i n t t i d W o re m n f A l e w e n R c h t D t a , r t i S d s g o o : h e e t D v s a e o t s r h n t o e ' o t t b a h t o h n e o a s r w t k t h q e r a u e r n . e f l s d e i t n c i o o v t l n l o a a n k a r i y s f n i w g g u e h r l e e l. r s ? 2 2 2 2 2 1 3 4 B d co e Y p u Q o n M s s . i e R t l 1 i o . h j L n u a U s s f t r i T o w n m T v a o I n t E k h t e R e t d o : b y c e l o g a u i r n r if n r y i i g n s h g o t m o t f o e i t t t h h u i e n n g F ti . i l f D n th o u , w r p i r n y i g v o i u t l h r e i g s e s
25 afforded you under the Fifth Amendment.
25
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1 2 'asserti A ng re t h y a o t u r i i g n h co t r to po th ra e t F in i g ft t h h a A t m ri e g n h d t? m e A n r t e ? you 1 2 are, Q a . n d W h h o e w n h y e o i u s , s a a n y d h o h w ow I h a e m i s a . n d my co-counsels here,
4 3 5 you A Q in . . co A W r m p e o l I l r , a a y t l o i l n o u g w r h l i a n is w g i y n h e v im r o s c t a a o i t d i - o - i n t. o B f y u o t u a r r e F y if o th u , A a m re e ndment 4 3 6 w m yo h e u a A t t a a . d r l e k o I i s n y m t g o ic e , u k b a m i n u n e t g t i h a f u a n s p t b i s f f y o o y m t r h o t a a u h t n i ? s s y a s y o i c t y h k o e m u r l h a it a n t v l , e e a n g c d i h r i l i l s f d s t r h e n a n o t t a a j n u re d s t
6 right?
7 A. Am I allowing him to say it? 8 7 talk Q in . g , A y n o d u' r a e r e s i y c o k u . referring to your past actions
8 Q. Yes.
9 with Mr. Epstein?
9 A. Yes.
10 Q. So, it's your desire, you are invoking that 1 1 0 1 A Q . . Y A e n a d h , . a nd you believe that whatever your
11 Fifth Amendment right, correct?
12 interaction was with Mr. Epstein, that was wrong; is
12 A. Yes, I am.
13 MR. EDWARDS: Just read it whenever he says 13 that right?
14 A. Excuse me?
14 it.
15 MR. LUTHER: This might be lawyer technical 15 Q. You believe whatever your interaction with
1 1 1 6 7 8 r s i t g u h T ff t , H , b y E u o t u W I h b I a T e v N l e ie E t v o S e S a i s f : s y O e o r n t u t ' a r h e d e v g r i i o c g i e n h o g t s f to o c o - in - u v n o s k e e l - t - hat 1 1 1 1 6 7 8 9 M o w v e r e . A r r e E . 1 f p r 0 s o I 0 t m e t g h in i i t r n h l w s k e a a a f s o n g i r d e n a s t h t o 5 h e 0 e f l - 1 i p y t 2 a e tl , s a e t t r o , - g o t h i h r l a d a ls v t m e i th t a t a h w n t e a I t m s o b w t s r a o e r k o u e e n g , t o g h o v ? t h e t h a r a , v t e him
1 2 9 0 BY Q M . R H . L o U ld T o H n. E L R e : t me ask a question. As to those 20 see different vaginas without hairs on it when he is 50
21 questions that you were previously asked during this 21 years old, to masturbate and to get off like that, I
2 2 3 2 d A e m p e o n s d iti m on e n w t h ri e g r h e t in , d y o o y u o r u c o in u t n e s n e d l i t n o v i o n k v e o d k e y o th u a r t F r i i f g t h h t as 2 2 2 3 2 4 p th r i e n t k ty i t A s 's i n c p k d r . e fo I t t r d y y o s o n ic u 't k g k i u n n y o s t w h t e o i f h b y e e o a d u d e . g f u e y n s d h in a g v h e i m an , y t hat's
2 2 4 5 wel A l? . On advice of counsel, I invoke my Fifth 25 daughters, but would you want your daughter at Jeffrey
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1 Amendment rights under the United States Constitution. 1 Epstein's house while he is massaging and touching her,
2 3 thu Q s f . a r A w s h t e o r e e a y c o h u q r u c e o s u t n io s n e l t h in a v t' o s k b e e d e n th a o s s k e e r d ig o ht f s y ? o u 2 3 her Q va . gi H na o ? w W lon o g u h ld a y v o e u y l o ik u e b t e h e a n t ? o f this opinion?
4 A. Of this opinion, I think everybody has an
4 A. Yes, sir.
5 6 dep Q o . s it N io o n w a , f w ew he m n i n w u e t e to s o a k g a o , b w re h a e k n d y u o r u in c g a m th e is b ack in the 6 5 opin Q io . n H li o k w e t l h o a n t g . have you held the beliefs that you
room, did I hear you say that you wanted to have 7 just expressed?
a Mr. Epstein in the room? 8 A. How long have I held the beliefs?
9 Q. That's right, ma'am.
9 A. I really doe care.
10 Q. So you have no fear of Mr. Epstein being at 1 10 1 wow A. , I h P a ro v b e a a b l l i y tt w le h b e o n y I , h if a d an m yb y o s d o y n w a a n s d t I o r e to a u li c z h e d h , i m
11 the deposition; is that correct? 12 and screw up his mind like they screwed up mine and hurt
12 A. Being here —
13 me --
1 1 3 4 Q A. . R — i 1 g d h o t n't have fear of him. 1 would actually 14 Q. So, it was the birth of your son that was the
1 15 6 love Q f . o r D h i i d m y t o o u s k e n e o w w h a yo t h u e to p o u k t m th e e p th o r s o i u ti g o h n i i f n h c e o c u a r r t es. 1 1 5 6 eve A nt . th M at a c y a b u e s e th d a y t o m u a t d o e r e m a e li z w e a a ke ll u th p e a se li t t h tl i e ng m s? o re.
17 that you didn't want him present and that you, you were 1
1
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at it was wrong at the beginning.
18 fearful of having him in the room?
19 Q. When did you 'mow it was wrong?
19 A. Yes.
20 Q. When did that fear disappear?
20 A. I knew it was wrong the first second I stepped
21 A. As of about right now when you are stirring up 21 into hiS house.
22 all these emotions in me, I would love to look him right 22 Q. Do you know what a pimp is?
23 A. Yeah, I know what a pimp is.
23 in the face.
24 Q. What is a pimp?
2 2 4 5 Q A. . O A k n a d y t . o tell him how sick he is and how you 25 A. A pimp to me is a man who sends out women to
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1 do sexual acts and bring back the money to the pimp. 1 going over to his house because the answers may be
2 Q. Have you ever had a relationship with a pimp? 2 different. I am not sure.
3 A. No, sir. 3 BY MR. LUTHER:
4 Q. Have you ever acted as a pimp? 4 Q. Well, -- let me clarify. When was the
5 A. If you want to say when I was, you know, under 5 last time you went to Mr. Epstein's house?
6 the age of 18 bringing girls to Jeffrey Epstein, sure. 6 A. At the beginning of -- I went there when I was
7 You can call me Jeffreys pimp. 7 16 And I went that again after i had my
8 Q. And what do you mean by that? 8 So, it was after, it was either at the end of when
9 A. You don't understand? 9 I was 16 or at the beginning when I was 17.
10 Q. No. I want to know what you mean, ma'am. to Q. You age 16?
11 What I understand doesn't really matter. 11 A. Yes, I was.
12 A. I just gave you the definition of a pimp. 12 Q.
13 Okay. 13
14 Q. Were you — so, so, you were bringing girls to 14 A. Thank God.
15 Mr. Epstein- 15 Q. You never had sexual intercourse with
16 A. Yeah. 16 Mr. Epstein, did you?
17 Q. at some point, correct? 17 A. Penis inserted into a vagina, no.
18 A. Yeah. 18 Q. Did he ever insert his penis into your mouth?
19 Q. You knew that the girls were going to come to 19 A. No.
20 perform massages on Mr. Epstein when you brought them 20 Q. Did ever insert his penis into your anus?
21 is that correct? 21 A. No.
22 A. Oh, yeah, and more. Not just massages. 22 Q. Did every insert his penis into your vagina?
23 Q. And did, and did you get paid money to do 23 A. No.
24 that? 24 Q. Did he ever insert his penis anywhere in your
25 A. Yeah. 25 body?
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1 Q. And did you share that money with anybody? 1 A. No, but he would bring my hand closer to his
2 A. Did I share that money with anybody? 2 penis.
3 Q. Uh-huh. 3 Q. What do you mean by he would bring his (sic)
4 A. No. Why would I share my money with somebody? 4 hand closer to his penis?
5 Q. Just asking if you shared it with anybody. 5 A. Do you want me to show you? Here is my hand.
6 A. No. 6 I am Jeffrey. Here is my penis. Come closer, like
7 Q. Now, you indicated previously that you had 7 that
8 been seeing, I think to use your words MIS Do you 8 Q. Did you ever hold his penis in your hand?
9 recall that testimony? 9 A. No.
10 A. I never said IME I said I saw a 10 Q. Did you ever perform any sexual act on Jeffrey
11
11 Epstein?
12 Q. When is the first time in your 12 A. Yeah.
13 life you ever saw a la? 13 Q. What act did you perform on Jeffrey Epstein?
14 A. That I recall, after the Jeffrey Epstein, 14 A. Well, I would go there multiple times.
15 after seeing Jeffrey Epstein and I saw 15 50-year-old man would be sitting on the couch talking on
16 because of him. 16 the phone. i would sit there naked with my legs wide
17 Q. My question is when was the first time? 17 open. But what really sickens me is that if this was
18 A. I don't know when the first time was. 18 any Joe Schmo on the road who didn't have any money, he
19 Q. When did you last see Jeffrey Epstein? 19 would be in jail for a long time or he would be shot.
20 A. When did I last see Jeffrey Epstein? I think 20 But he is not, right. He is the multi billionaire so he
21 I was about to tum -- no, when i was at the end of 16 21 is allowed. He is probably fucking jacking offr ight
22 or the beginning of 17. 22 now. I am sorry. I am 21. You can't jack-off to me,
23 MR. EDWARDS: Just so it's clear, you, when 23 but you lmow —
24 you're asking the question when was the last time 24 MR. LUTTEER: Move to strike the soliloquy as
25 saw him, do you mean physically saw him or was 25 not being responsive to the question.
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1 2 3 4 w m a h m u a T l a t t H i s p d s E l i a e d g W t e J i e m t I f a T f e b r N s e l . e y E m I d S c o S a a s : t n s o ' a W t m g c i h o e n a u ? g t n h d I t i . i w s d A l e I e n n g d t d s o u . I t p o w H t J h o e e e u w f r l f d e o re u b y l e d a o n tu n d r n 1 2 3 4 h w i o s Q A u h l o . . d u t s T Y a e l a o k t l u o k t o e s m a d m i d a - n - y o o f . t n h e I e g w g u o i y r u l t s l h d t a h t t a a m l t k w o r t e n re just w f a . r n o I d m e ring
6 5 o p v u e t r a . v H ag is in p a e o n r is a w v o ib u r l a d t o b r e t h o a m ng y i n v g a g o i u n t a . H H e e w w o o u u l l d d 5 6 aro Q un . d S hi o s y h o o u u s s e a . y , you gave us a phone number that
7 touch my vagina with his fingers. He would touch 7 you say you called, right?
8 9 w m o y u b l r d e b as r t i s n . g H m e y w ha o n u d ld s b to y w t a o r d k s i s h s i m s p y e m ni o s. u t H h. e H w e o uld 8 9 nun A liW . i I a I n k t n n o o w t p t o h s a i t t i a v e lo i t f o th f a h t i s w p a h s o h n i e s n p u h m on b e e rs started
1 1 0 1 a ju s s k t t s h e e e l y it o tl u e r g v i a r g ls i n th a a , t c a I n w I a j s u w st i t s h e , e h i e t y , e , v ca en n i I f 1 1 0 1 wi Q t. . .. Y ou mentioned and some other people.
12 they would say no. Can I, oh, I know, but let me 12 Did you ever call Mr. Epstein directly?
13 just see it. Let me just see it. Sick mother 1 1 3 4 A Q . . Y D e id a h y . o u ever have a conversation with him?
14 fucker.
15 A. Yes.
15 I would like him in this room.
16 Q. And when did that happen?
1 1 1 6 7 8 BY Q A M . . k A I s L n t y U h a T s t e T n x L o u E t a l R a a : s c e t x t u h a a l t a y c o t u w p h e e r n fo y rm ou e d p u w t i a th Jeff? 1 1 7 8 that A I . st F op ro p m ed t h g e o i t n im g t e h t e h r a e t . I I w a e lw nt a t y h s e t r a e l k to e d th t e o t J i e m ff e r ey
1 2 9 0 vibr Q a . t or A to n y y o a u ct r t w h i a f t e y 's o p u u p s e s r y f ; o i r s m th ed at w n i o t t h a M se r. x E ua p l s a te c i t n ? 1 2 9 0 on t Q he . p Y ho o n u e a . lways, what do you mean by "always." I
23. thought you said you talked AS.
21 that you haven't described thus far?
2 22 3 The A re . w L a e s t m m u e l t s i e p e le . t I h w in e g n s t t t h h a e t r e I h m a u v l e t i d p o le n e ti m w e it s h . Jeffrey 2 2 24 2 3 w I w ou A o l u d . l d t I a t l a w k lk o t c u t l i d i a i l i w i. a ys , w ta I h l w k o o e to v ul e J d r e t f a a f n r l s k e w y t e e a r i e . li d a k th tP e l p i I o h o n n c e. And
2 2 4 5 and Q J . e ff M re y y q h u as e s d t o io n n e s w ta i n th d s m . e D . id you perform any act 25 then sometimes Jeffrey wanted to get on the phone
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1 with Mr. Epstein other than what you have described thus 1 because he wanted to tell me what kind of specific girl
2 he wanted that day or tomorrow or the next day.
2 3 far? A . Besides standing there with my legs wide open 3 Frequently! would talk to Jeffrey Epstein on the phone.
4 5 6 a i l s n 2 p d -y r h o e i b a s a r - l b i o t l l t y d l e g g f e i e t r t t l i i f n s r h i g e w h n a d it r h s d t a m r n ig e d h i p t n i n g n o c n w h e i x n — t g t w h o i i m s th n e m i , p b y p o l l t e i h t s t n l — e a k h e e d , 4 5 6 u an nd d Q e y r . o st u Y a n w o d u e i r n u e g s t e c a d o lk r t i r h n e e g c w t t l o y o , d r y d if o " f u e a r l a w e r n e a t y s p a s e . y " o i n p I g l f e y I o o a n u m d w if e f r e e r e c n a t l ling
7 no, I can't think of any other sexual acts I have done 7 occasions; is that right?
8 A. Yeah.
8 9 wit Q h . J ef A fr n e d y , . and did you say that you went there 9 Q. Okay. And do you have any record of your
10 conversations or the number of times you called and
10 multiple times?
11 claimed that you talked to Mr. Epstein?
11 A. Yeah.
12 Q. How many times would you say you went? 12 A. Do I personally have a record?
13 A. More than, more than 50 times. 13 Q. Yeah.
14 Q. Did you keep a record of the number of times 14 A. No, but you can talk tole about that and
15 Jeffrey. Jeffrey has a record.
15 you went?
16 A. Unfortunately I didn't. 16 Q. So, you don't have it?
1 1 1 2 7 8 9 0 e y i o th u Q A e b . r . e M a A T l r h l n . o e d E w y p w e w s d e te o r t e i u o n l t d c h o o e r c m r a p e l e e l o o o m c p v c e l a e e m s r o ? io o n n s h t s i o w s f b h t e h e h n e a t y l i f o m a u e s c k , o b in n u g t t a , t c y h t e e a s d t , 1 1 1 2 7 8 9 0 o w r o s Q A u o l . . m d y e N U o o n o n u f w e o s , a e r o t y l u s n y e n o a t i h t f u e e y l c s y o a e , u l m n l e c o u d o . l , u t i i l n p d i l t c e i o a t m t i e m d e e a o s , v c h e a o r l l w t o a m s M k a r. i n E n .y p g j s i t = m ei n?
2 2 2 1 the Q re . w A as n m d u fo lt r i , p a le n d ti m w e h s o I d w id o y u o ld u c c a a l l l l ? th em. 2 22 1 call A ed . a W nd e l h l e , w w h o e u n l d I c fi a r l s l t a s n ta d r t c e a d ll g a o n i d n g c a th ll e a r n e d h e ca ll.
23 A. I called the house phone, I don't 23 And he told me from that point be said, listen, you
24 know. There was multiple house numbers. I would talk 24 call me when you find somebody. Ifl didn't have
25 to I would tallc to the one — 25 somebody new, then he didn't want me calling. III
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1 found a new girl, he wanted me calling right away. 1 Q. Well, were you a in high school —
2 Right way. I would go there two times a day. 2 A. No.
3 Can I have a water, please? 3 Q. — when you first went to
4 5 M MI R L . L ED U W TH A E R R D : S S : u L r e e t . ' s I t d ak o e n t a s b e r e ie a f n b y r e u a p k t h u e n r ti e l . I 4 5 A Q . . W No. e resillan school when you
6 find a water and well come back on. 6 first went to
7 8 M M R R . G ED O W LD A B R E D R S G : E It R m : a T y h b e e re i n is t a h e c o c o o l o e l r e r o v b e u r t t I h ere. 7 8 Q A. N W o. e reanill school when you
9 first went to
9 don't see
10 THE COURT REPORTER: lean go upstairs. It 10 A. Might have been.
11 will take me a couple of minutes. 11 Q. That would be thellEgrade?
12 THE VIDEOGRAPHER: Are we going off the 1 1 2 3 toQ A. M Di i d g ht ha a v t e te b n e d e a n n . y high school before you went
13 record?
14 MR_ EDWARDS: Yes.
14 ?
15 THE VIDEOGRAPHER: Going off the video record. 15 A. Yes.
16 Q. What high school did u attend?
16 The time is 11:01.
17 A. I have attende .
1 1 7 8 ( T A H b E r i V ef I D re E c O es G s R w A as P h H e E ld R .) : We're back on the video 18 Q. The question is what high school did you
19 record. The time is 11:33 a.m. 1 2 9 0 atte A nd . ? I am to think, sir. I have attended
20 BY MR LUTHER:
21 Q. In your, in one of your prior answers you said 21
22 something about a 12 year old being present with you. 22 Q. What year?
23 A. I don't know.
23 Do you recall that testimony? 24 Q. When I say what year I mean as a freshman or
24 A. Yes.
25 Q. Who arc you referring to? 25 as a sophomore or junior or senior?
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1 A. That is multiple ones. I do know one. Her 1 A. ma .
2 Q. So as a
2 name is
3 A. Maybe.
3 4 Q A . . w I' h m a t n ? o t -- I don't know the spelling is. 4 Q. Well, if wasn't the , it would have
5 been the 10th, 1 Ith, or 1 2111: t?
5 Q. Is in. 6 A. Yes, sir. Probably from what I
6 A. (Witness spelled name maybe.
7 Q. And how do you -- did you Imow
7 recall.
8 Q. You are talkin about the-
8 A. Yes. 9 located in is that correct?
9 Q. How did you know her?
10 A. Yes.
10 A. School.
11 Q. And it only begins in the
11 Q. What school?
12 A. Yes. So
12 A.
MN? 13 Q. Did you attend
13 Q. She was a student at 14 for your entire year?
14 A. Yes.
15 Q. And when did you first make her a • tance? 1 1 5 6 tran A sf . er ' r d e o d n t ' o t think I did, sir. I thin a k n d I after that I
16 A. When I started going to school at
17 transferred to
17
18 Q. When did you start going to school at- 18 Q. Well, lees sta
19 Why did you attend
1 2 9 0 A. I F II o . r ? th e record, lam mall bad with math and 20 by that I mean --
21 A. My 'nether lived in
21 years. So, the first year that 22 Q. OOkkaayy.. Where did your mom live?
22 opened up was the first year that I went.
23 Q. And what ear of school were you in when you 23 A. My mother lived in
24 Q. In a devisnent like
24 first went to NM?
25 A. Like I said, I'm not good with years. 25 A. Mill
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