0166 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 5 CASE NO. 08-CIV-80119- 3 4 JANE DOE NO. 2, 5 Plaintiff, 6 -vs- VOLUME II OF Il 7 JEFFREY EPSTEIN, 8 Defendant. 9 10 Related cases: 11 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-80811, 08-80893, 09-80469 12 09-80591, 09-80656, 09-80802, 09-81092 13 14 15 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF 16 17 18 December 4, 2009 10:25 - 5:00 p.m. 19 23 Reported By: 24 Notary Public, State of Florida Prose Court Reporting 25 0167 1 APPEARANCES: 2 On behalf of : 3 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 4 BARNHART & SHIPLEY, P.A. 5 Phone: 6 7 8 On behalf of the Defendant, Jeffrey Epstein: 9 ROBERT D. CRITTON, JR., ESQUIRE MARK T. LUTTIER, ESQUIRE 10 BURMAN. CRITTON, LUTTIER & COLEMAN, LLP file:///C\/Documents%s20and%20Settings/Production/Desktop a :.20 01. 20ILtxt[ 12/11/2009 6:15:58 PM] EFTA00023557

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12 Phone: i’ 15 ALSO PRESENT: 16 —_ Jeffrey Epstein, via video conference 17 Danchuk, Paralegal, Richard H. Willits, PA. 19 Stan Sanders, Videographer Visual Evidence, Incorporated 20 21 22 23 24 25 0168 1 --e 2 INDEX VOLUME II 3 --- 4 5 WITNESS: DIRECT CROSS REDIRECT RECROSS 6 7 CONTINUED 8 BYMR.LUTTIER 170 9 10 i ae 12 EXHIBITS 13 oe 14 15 EXHIBIT DESCRIPTION PAGE 16 DEFENDANT'S NO. 1 i 17 Plaintiff's Notice of Serving Second Amended Answers to Interrogatories 18 DEFENDANT'S NO. 2 29 19 Answers of Interrogatories 20 DEFENDANT'S NO. 3 119 First Amended Complaint 21 DEFENDANT'S NO. 4 254 22 Plaintiff's Notice of Serving Third Amended Answers to Defendant's First 23 Interrogatories 24 25 0169 1 ** * * * 2 THE VIDEOGRAPHER: We're going back on the 3 record at 2:42. 4 BY MR. LUTTIER: 5 Q. Mom -- ma'am, at the break we had just file://C\/Documents%20and%20Settings/Production Desktop EEE -°620V 01.6201 bct[ 12/11/2009 6:15:58 PM] EFTA00023558

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6___been discussing your relationship with a | | . You used the phrase in your testimony 8 earlier, you used the phrase "eat out." Could you 9 describe what that phrase means in the context that 10 —- you were using it? 11 MR. SCAROLA: We will stipulate that what 12 it means is cunnilingus. 13. BY MR. LUTTIER: 14 Q. Okay. Do you know what a sex toy is? 15 MR. SCAROLA: Could you explain what 16 relevance or materiality your understanding of 17 that line -- 18 MR. LUTTIER: Sure. It was -- 19 MR. SCAROLA: -- of questioning might have 20 since there is no allegation that sex toys were 21 ever employed in encounters between and 22 Mr. Epstein? 23 MR. LUTTIER: Well, I dispute that for 24 sure. | just tell you if you read the record 25 carefully, you will find out that is not at all 0170 1 true, and that's why it is relevant. Come up 2 many a time. 3 MR. SCAROLA: In connection with 4 allegations from ? 5 MR. LUTTIER: There and in the IME. 6 MR. SCAROLA: Okay. Well, if you 7 represent, if you represent that that's the 8 case, then proceed. 9 BY MR. LUTTIER: 10 Q. Do you know what a sex toy is? 11 A. Yes. 12 Q. Okay. And what is your understanding of 13 __ that term so that we are understanding each other 14. when I ask you these questions? 15 A. I guess toys used doing sexual things. 16 Q. Okay. And that would include, for 17. example, vibrators? 18 A. Yes. 19 Q. Dildos? 20 A. Yes. 21 Q. Have you used sex toys in the past? 22 A. No. 23 Q. Never? 24 A. Never. 25 Q. Either -- how about with J? 0171 1 A. No. 2 Q. Did you ever tell anybody you had? 3 A. No. 4 Q. Did you, did you ever use any sex toy with 5 Jeffrey Epstein? 6 A. He tried to use a massage thing and | told him 7 no. file://C\/Documents%20and%20Settings/Production Desktop EEE -°620V 01.6201 bct[ 12/11/2009 6:15:58 PM] EFTA00023559

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8 Q. What did you mean by "massage thing"? 9 A. Whatever it was in the hell that he had. 10 Q. Well, what -- describe what you are 11 talking about. 12 A. I just told you. 13 Q. Well, massage thing doesn't tell me 14 anything. What are you talking about? 15 A. I don't know what it was called. I don't know 16 what it is. 17 Q. What did it look like? 18 A. It looked -- it was -- I don't know. It 19 vibrated. It looked like it was a neck massager. 20 Q. But do you know, do you know -- can you 21 describe, physically describe how big it was, what 22 color it was, what it looked like? Can you describe 23. anything about it? 24 A. It was gray and do you want me to draw you a 25 _ picture because I don't know how to describe what it 0172 1 looked like. 2 Q. How large was it? 3 A. It was like this big (indicating). 4 Q. Okay. 5 A. It was like a neck massager. 6 Q. You know like -- you know what Brookstone 7 is, a store? 8 A. Yeah. 9 Q. Have you ever been in there and they have 10 these massages that, like you can reach behind your 11 back and stuff like that. Are we talking about 12 something you know, like that? 13 A. Yeah, but it didn't have a wire, an electrical 14 wire. 15 Q. Okay. 16 A. It was like battery operated. 17 Q. And you say that Mr. Epstein tried to use 18 this on you and you said no? 19 A. Yeah. 20 Q. And then he -- 21 A. That was the end of that. 22 Q._ -- didn't use it? 23 A. He did not, and he's never, it never was 24 brought up again. 25 Q. Have you ever desired to use any kind of 0173 1 sex toy? 2 A. No. 3 Q. And, and then not done it for some reason? 4 A. No. 5 Q. Okay. Back to a. How many 6 sexual encounters would you estimate you had with 7 ? 8 A. I don't know. 9 Q. What's your best estimate with what degree file:///C\/Documents%20and%20Settings/Production/Desktop [EEE -°620Vo1.%2011.oct[ 12/11/2009 6:15:58 PM] EFTA00023560

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10 of frequency did you and she have a sexual 11 relationship? 12 MR. SCAROLA: Those are two different 13 questions, compound. 14 THE WITNESS: What does this -- 15 MR. LUTTIER: With what -- 16 THE WITNESS: What does this have to do 17 with me and Mr. Epstein? 18 BY MR. LUTTIER: 19 __ With what degree of frequency did you and 20 have sexual relations? 21 MR. SCAROLA: That's the second part of 22 the question that you asked. 23 MR. LUTTIER: That's the question. I will 24 break it up then. 25 0174 1 BY MR. LUTTIER: 2 . You've testified earlier that you and || 3 had sexual relations? 4 MR. SCAROLA: Weill stipulate that that 5 occurred on multiple occasions. 6 BY MR. LUTTIER: 7 Q. All right. Tell me with what degree -- 8 MR. SCAROLA: And beyond that an inquiry 9 is intended for no other purpose except to 10 annoy, harass, and embarrass. 11 MR. LUTTIER: With all due respect, I 12 disagree. So, | am going to ask my question. 13 MR. SCAROLA: And I disagree with your 14 disagreement. And I will instruct her not to 15 answer. 16 MR. LUTTIER: Okay. Let me get the 17 question out. 18 BY MR. LUTTIER: 19 Q. On how many occasions did you and || 20 2 have sexual relations? 21 MR. SCAROLA: And the stipulation is that 22 it occurred on multiple occasions and beyond 23 that no relevant inquiry can be made. 24 BY MR. LUTTIER: 25 Q. And when, when your lawyer stipulates that 0175 1 it's multiple occasions, if you had a relationship 2 with her for 12 months, can you estimate how many 3 times it was? 4 A. [refuse -- 5 MR. SCAROLA: Don't answer that question. 6 THE WITNESS: -- to answer. 7 MR. LUTTIER: And you refuse to answer -- 8 MR. SCAROLA: Because her lawyer has 9 instructed her not to answer because the 10 question is obviously intended, after the 11 stipulation, for no other purpose except to file://C\/Documents%20and%20Settings/Production Desktop ERE © 20 V01.962011.vct[ 12/11/2009 6:15:58 PM] EFTA00023561

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SBIDDEBHNSLSOCKPAIAVEWNS Wy -— oS ~ Mh NM cNMhMh — in & ~ ~ SSC rrADAuswne i] 13 file://C\/Documents%20and%20Settings/Production Desktop EEE -°620V 01.6201 bct[ 12/11/2009 6:15:58 PM] annoy, embarrass, and harass the witness. MR. LUTTIER: It's, it's not intended to be annoying. I believe the degree of frequency is absolutely relevant in the case. MR. SCAROLA: To what -- to which element? MR. LUTTIER: Arguable -- well -- MR. SCAROLA: To which element? MR. LUTTIER: I don't want to -- MR. SCAROLA: To which element of the offense? MR. LUTTIER: I am not going to argue my case to you, but it absolutely has an effect on the alleged claim of damages. Beyond that I don't need to tell you the theory of my case but -- MR. SCAROLA: I disagree. MR. LUTTIER: Okay. BY MR. LUTTIER: Q. Do you, do you -- how did your relationship ‘a end? A. I met my son's father. Q. Who is lll A. Yeah. Q. Did your relationship with end on an amicable basis? A. What does that mean? Q. Well, did you she and she both agree you were going to go your separate ways -- A. Yeah. Q. -- or did you just cut it off? A. We agreed we would go separate ways. Q. Did you have —— name or any portion of her name tattooed on your body? A. Yes, I did. Q. And what did you have tattooed on your body? A Q. And when did you have that done? A. While we were -- when I turned 18. Q. So, it would have been about six years, five years after your relationship ended? A. Yeah. Q. And why did you have her name tattooed on your body five years after you ended your relationship with her? A. Because | felt like it. __Did you ever rekindle your relationship with -- A. No. Q. -- after you, after your 13th birthday? A. No. Q. Did you maintain contact with EFTA00023562

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14 after youand she broke off your relationship when 15 you met ? 16 A. No. 17 Q. With respect to the incident that you were 18 — describing earlier when you were at Mr. Epstein's 19 house and you said there was another woman present 20. who was nude, do you recall that testimony? 21 A. Yeah. 22 Q. And was there any discussion between you 23 and she before she began to} on you? 24 A. And I told you no. 25 Q. No words at all exchanged? 0178 A. No. Q. So you were just standing there and this -- A. Yeah. 1 2 3 4 5 Q. And what, if anything, did you say when 6 _ this person began to a on you? 7 A. I didn't say anything. I just felt really 8 weird and | just stood there. 9 Q. And this is a person you had never seen 10 before? 11 A. Yes. 12 __ And for how long a period did this person 14 A. I don't know. 15 Q. And this is while you were standing? 16 A. Yeah. 17 Q. Did, did it, when you say you don't know, 18 are we talking about this went on for 15 or 20 19 minutes or this went on for three minutes? 20 A. Like 15, 20 minutes. 21 Q. Okay. Did you, did you move from where 22 - you were standing to some other location while she 23 was doing this? 24 A. I just said no. 25 Q. Did you have an | 6 0179 A. No. Q. -- asa result of her performing? Did you 1 2 3 at any time during the 15 or 20 minutes that she was 4 a on you say anything to her? 5 A. Yeah, I told her to stop. 6 Q. And when did you tell her to stop? 7 A. After like 15 minutes, I told her to stop and 8 that I felt uncomfortable. 9 Q. And what did she do? 10 A. She stopped. And I told Jeffrey I wanted to 11 leave, and he gave me $300 and I left. 12 Q. So, the first time you told this lady to 13 stop, she stopped? 14 A. Yeah. 15 Q. And you told Jeff you wanted to leave and file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023563

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16 he didn't try to stop you? 17 A. No. 18 Q. Did you perform any sexual act on this 19 woman? 20 A. No. 21 Q. Did you touch her in any way? 22 A. No. 23 Q. And at the time that you were standing 25 I assume she was kneeling or something? Yes. And where was Mr. Epstein during this? Behind her having sex with her. While she was kneeling? Yeah. Did you say anything to Mr. Epstein? Besides that I wanted to leave, no. Which you said after 15 minutes, right? Yeah. How about during the first 15 minutes, did you say anything at all? A. No. Q. Did you say, you know, I am uncomfortable with the set-up; I want to leave? A. I just said no. (Interruption at the door.) MR. LUTTIER: At the time -- THE WITNESS: Can you not ask me questions with somebody in the room? QOPOPOPOPOP SRNR TERDH HS eve wrragauvgswne 20 BY MR. LUTTIER: 21 Q. What do you mean not ask you questions -- 22 A. That man was in here. 23 Q. Had you had any sexual relationship 24 between any other woman other than before this 25 _ incident that you have described that occurred at Mr. Epstein's? A. No. Q. Have you since the incident that occurred at Mr, Epstein's that you've described, where this aT on you, had any sexual contact with any other female? A. No. Q. Did you ever have any discussion with anyone else at any time with respect to your sexual relationship vi A. What? Q. Did you ever have any discussion with anyone at -_ time about your sexual relationship QRAEBR ESC eI AM EYNHKE with A. My mother. Q. And when did you discuss it with your mother? file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023564

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18 A. When I was with a. What does | | 19 have to do with Mr. Epstein? This is why I am here, 20 because of Mr. Epstein. 21 Q. So, if] understand your testimony 22 correct, you would have discussions with your mother 23 about your relationship with sometime while 24 you were 12 years of age; is that right? 25 A. Yes. 0182 Q. What was your mother's reaction? A. She didn't have one. Q. Did she say anything at all to you about it? A. No. Q. Did you ever seek any type of counseling with respect to your relationship with ? A. For what? Q. For anything. Did you ever discuss-- A. No. Q. Did you ever tell any of your mental health counselors about your relationship with i? A. No. Q. Is there any reason why you didn't tell your mental health counselors? A. Because it -- Q. About your relationship with |g A. Because it, it wasn't a problem. What is a SENEZTZESH AHS ve wmragauvgswne 20 problem is you asking me about when I am here 21 about what Mr. Epstein did to me. So, I refuse to 22 answer any more questions that you have about 23 . So, move on, please. 24 Q. What is the most traumatic event that 25 __ occurred in your life prior to late May or June of 0183 2002 when you met Mr. Epstein? A. There wasn't one. Q. So, if] recall your testimony this morning, you were raped before you met Mr. Epstein? A. [have no recollection of it so if -- Q. Wait. You were raped before you met Mr. Epstein? A. Yes, but I don't remember it happening, so I ARwWNMa= SP HADNEWNHE mean -- Q. Were you molested by a relative -- A. Yes. Q. -- before you met Mr. Epstein? A. Yes. Q. And that was your grandfather? A. Yes. 16 Q. And over what period of time were you 17 molested by your grandfather? 18 A. I was a kid, a child, a baby child. 19 Q. Roughly over what period of time? file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023565

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20 A. I don't know the period of time. I was under 21 the age of six. 22 Q. And it went on for an extended period of 23‘ time? 24 A. I don't know how long it went on for. 25 Q. Was that a disturbing event to you? 0184 1 A. A disturbing, yes. 2 Q. Did you talk to your mental health 3. counselors and_advisers about it? 4 A. [told [J when 1 was 13. 5 Q. Were you molested by another relative of 6 yours -- 7 A. Yes. 8 Q. -- at any time? And who else were you 9 molested by? 10 A. My cousin. 11 Q. And approximately how old were you when 12 that occurred? 13 A. I don't know. 14 Q. Did you bring any, or was any action 15 __ brought on your behalf, lawsuit, against your 16 grandfather -- 17 A. No. 18 Q. -- asa result of him molesting you? 19 A. No. 20 Q. Did you sue the individual that raped you? 21 A. I don't know who raped me. 22 Q. Well, did you tell in your 23 ~—s meeting with him that you called the police after 24 the rape and had the individual arrested? 25 A. No, I did not. So if he wrote that, then he 0185 1 lied. 2 Q. Okay. Well, fortunately it is videotaped. 3 MR. SCAROLA: Fortunately it is, because 4 ‘ou have not accurately reflected what is in 5 notes. 6 BY MR. LUTTIER: 7 Q. Okay. Did, did you bring a lawsuit 8 against anyone as a result of your rape? 9 A. No. How can you sue somebody for raping you 10 if you don't know who did it? 11 Q. Well, presumably at some point you went to 12 the beach with this male, correct? 13 A. Yeah. 14 Q. You got there under your own power; that 15 is you walked out there? 16 A. Yes, but I don't remember the person's name. 17 Q. And when you walked down there with this 18 person, you knew who that person was at that time? 19 A. Yes. 20 Q. And you went there with a girlfriend of 21 yours as well, did you not? file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023566

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22 A. Yes. 23 Q. And she had somebody with her? 24 A. Yes. They were her friend. 25 Q. So, you had a girlfriend who knew the name 0186 1 of this person -- 2 A. Yes. 3 Q. -- that went with you? 4 A. But I don't know where that friend is now. 5 Q. And the day or the time that you woke up 6 after this rape, the girlfriend that you went to the 7 beach with was there? 8 A. Yes. 9 Q. And presumably you could have asked her 10. what the name of this boy was? 11 A. Well, I was scared. 12 Q. Did you ask her what the name of the boy 13 was? 14 A. No, I didn't. I was scared. I was confused. 15 Q. Did she call the police? 16 A. I don't know what she did. 17 Q. But in your presence at no time -- 18 A. She did not. 19 Q. You represented earlier, I believe, that 20 you were in some type of car accident? 21 A. Yes. 22 Q. How many car accidents have you been in? 23 A. One. 24 Q. And in what year was that? 25 A. '08. 0187 1 Q. And did, did you bring a claim against 2 anyone as a result of any injury you suffered in 3 that accident? 4 A. I think my, I think my mom, we did, yeah. 5 Q. Well, if you did it in '08, it would have 6 been when you were an adult. You were already 18 7 years of age? 8 A. Yeah, I had just had my daughter. 9 Q. Okay. Then if, if you were an adult, you 10 would have been the one to bring the claim? 11 A. Well, my mom did it. We were at a dead stop 12. and somebody hit us and then we were hit again. 13 Q. Okay. Did you, did, did you and your mom 14 assert a claim against an insurance company or the 15 person that hit you? 16 A. Yeah. 17 Q. Did that result in getting some kind of 18 settlement? 19 A. I don't know. 20 Q. Did -- 21 A. I think my case is still pending with it. 22 Q. Did you, did you have a lawyer 23 representing you in that action? file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023567

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24 A. Yes. 25 Q. Who was the lawyer? 0188 1 A. John Carroll I think. 2 Q. And your recollection is you think there 3 is currently a lawsuit pending? 4 A. Yeah. | am not sure. 5 Q. In your answers to interrogatories you 6 were asked if you had ever been a party to a lawsuit 7 and you responded no. Has the lawsuit -- 8 A. Because my mom is the one that is doing it. I 9 was a passenger in her car, so I don't understand. I 10 don't know. 11 Q. Other than this lawsuit arising out of the 12 automobile accident, is there any other lawsuit in 13. which -- 14 A. No. 15 Q. -- you have ever been a party? 16 A. No. 17 Q. Was your deposition taken in the lawsuit 18 arising out of the car accident? 19 A. Something like this? 20 Q. Yes. 21 A. No. 22 Q. And is the lawsuit pending in Palm Beach 23 ~=County? 24 A. I guess. 25 Q. In this case you've got a couple of 0189 1 lawyers. One is Mr. Willits? 2 A. Right. 3 Q. Let me see if] have got right here. 4 Yeah, Willits. And how did you get to Mr. Willits? 5 Did you know him before this action? 6 No. 7 How was it that you got to Mr. Willits? 8 I looked him up. 9 Where did you look him up? 10 . In the phone book. 11 . Yellow Pages? 12 . Yes, I did. 13 And you were looking up what? What 14 subject matter were you looking up? 15 A. Civil attorneys. 16 Q. Had you ever met Mr. Willits before you 17 18 19 20 21 22 23 24 25 FO porOPer employed him to undertake your representation in this matter? A. Wouldn't that still fall under if | have known him before this? Q. I don't know. So, the first time you ever laid eyes on him or communicated with him is with respect to this suit? A. Obviously, yes. Q. Do you know an individual by the name of file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023568

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i] = xo i] 1 Brad Edwards? 2 A. No. 3 Q. Have you ever heard his name before? 4 A. No. 5 Q. Do you know other women that have brought 6 claims against Mr. Epstein? 7 A. Yes. 8 Q. What other women do you know that have 9 brought claims against Mr. Epstein? 10 A. That's not my information to give you. 11 Q. My question stands. 12 A. I don't feel comfortable telling him. 13 MR. SCAROLA: Well, if you know the names 14 of other women who you know have brought 15 claims. 16 THE WITNESS: | knowl has. I don't 17 know her last name. And I found out after I 18 filed my suit. 19 BY MR. LUTTIER: 20 Q. Anyone else? 21 A. Not that I know of, that are my friends. 22 Q. Well, m estion -- 23 A. Me and haven't talked since this accident 24 — just for the record. 25 Q. My question wasn't limited to your 0191 1 friends. My question was did you know other women, 2. do you know other women that have brought claims to, 3. against Mr. Epstein? 4 A. Personally, no. 5 Q. Well, how would you know them if you 6 didn't know them personally? 7 A. I said no. 8 Q. Well, I'm, I'm getting the impression that 9 you're, you're being -- 10 A. is the only person that I know that has. 11 Q. And what did you mean when you answered 12 earlier to my question when | asked you if you knew 13. other women that had brought claims against 14 Mr. Epstein, you answered yes? 15 A. And you wrote down ., did you not? 16 Q. That's the only person that you were 17 referring to? 18 A. Yes. 19 Pe Have you ever heard of a lady by name of 20 .? 21 A. No. 22 Q. Jane Doe? 23 A. No. 24 Q. Who -- all right. This person, wi. how 25 do you know this person, | & 0192 1 A. She was a friend of mine. file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023569

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Q. And she was a friend of yours commencing when? When did you first meet her? I don't remember. Years ago. Before you went to see Mr. Epstein? No. She, I mether through my friend Who -- what's .'s name? COeADMNFwWhH SOPOPOPr Do you know any other girls that claim to 10 have gone to Mr. Epstein's house to perform massages 11 on him? 12 A. Do what? 13 Q. Do you know any other girls that have gone 14 to Mr. Epstein's house and claimed to have performed 15 massages on him? 16 A. Me, i. and i. those are the only girls 17 that I know. 18 . And how is it that you met a. through 19 .2 20 A. How do you meet your friends through friends? 21 Q. Ihave no idea. I mean, were you guys at 22 a party together, did you get on the phone with each 23 other? What did you do? 24 A. We were hanging out. 25 Q. "Hanging out," what's that mean? 0193 A. When you hang out. Were you at a function and all three of you v were there, for example? A. Obviously we were at something hanging out. Q. And did there come a time that you took anyone to Mr. Epstein's house? A. Yes. Q. When was that? A._1 don't remember the times and dates but I took . and . Q. And which did you take first? A. Q. And in respect to when you went to Mr. Epstein's between May and June of '02 and August of '03, when was it that you took A. Bro, 1 don't know. I just told you I don't know times and dates. Q. I realize you don't know the exact time. But was it in '02 or was it in '03? SRNR TERDH AHS ewragauyswne 20 A. If1, if you know that I don't know the dates, 21 how would you ask me if it was in '02 or '03? 22 Q. Well, what's your best estimate of how 23 many_visits you had made to Mr. Epstein's before you 24 ~— took 25 A. [have no idea. 0194 1 Q. More than ten? 2 A. Probably. 3 Q. How long had you known | | before you file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023570

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4 took her to Mr. Epstein's? 5 A. [have known | | for years. I met i. I 6 — don't know. Ask me the question again, please. 7 Q. How long had you known . before you 8 took her to Mr. Epstein's? 9 For about a year. 10 And how did you meet | 11 She lived down the street from me. 12 Was she a close friend? 13 Yes, she was. She was my best. 14 . You wouldn't do anything to harm her, 15 correct? 16 A. Correct. 17 Q. By the time you took a. to 18 19 20 21 22 23 24 25 OPOPOP Mr. Epstein's, you had performed massages for Mr. Epstein in the total nude; is that correct? A. Uh-huh. THE COURT REPORTER: Is that a yes? THE WITNESS: Yes. BY MR. LUTTIER: Q. You had already had this sexual relationship with this woman that you described 1 earlier at Mr. Epstein's? 2 A. Yes. 3 Q. You mentioned earlier that on these 4 occasions when you gave Mr. Epstein a massage, he 5 would masturbate I believe you said; is that right? 6 A. Yes. 7 Q. Did that occur, that is Mr. Epstein 8 masturbating, on each and every occasion when you 9 — went to Mr. Epstein's from the first occasion to the 10 last occasion? 11 A. Yes. 12 Q. Did you physically see him masturbating? 13 A. Yes. 14 Q. That is there was no towel covering his 15 genitalia or anything like that? 16 A. No. 17 Q. Before you went to Mr. Epstein's for the 18 first time, you had had sexual relations with other 19 males, had you not? 20 A. Yes. 21 Q. And you'd had sexual relations with how 22 many males before you went to Mr. Epstein's for the 23 first time? 24 A. Three. 25 Q. And what did those sexual relationships 0196 1 consist of that you had had before you went 2 Mr. Epstein's? 3 A. Intercourse. 4 Q. Did -- had you, other than with a. 5 had you had any oral sex with any individual file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023571

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6 — other -- 7 A. No. 8 Q. -- than , | before you went to 9 Mr. Epstein's for the first time? 10 A. No. 11 Q. Before you went to Mr. Epstein's for the 12 first time, had you seen any, either these males 13 that you had previous relationships with or any 14 other male masturbate? 15 A. No. 16 Q. Had you seen any pornographic materials 17 before you went to Mr. Epstein's for the first time? 18 A. No. I don't watch porn. 19 Q. Had, have you ever been photographed in 20 the nude? 21 A. No. At Mr. Epstein's, yes. 22 Q. How about any place other than 23. Mr. Epstein's’? 24 A. No. 25 Q. And who photographed you in the nude at 0197 1 Epstein's? 2 A. . 3 Q. who? 4 A. . 5 Q. And when in this time period that you went 6 to Mr. Epstein's did photograph you in the 7 ~~ nude? 8 A. It had to have been in the summer. It was in 9 the summer. 10 Q. And why do you know it was in the summer? 11 A. Because it was summertime. 12 Q. And where did this photographing occur? 13 A. In Mr. Epstein's house. 14 Q. Where in the house? 15 A. Everywhere in the house, outside by the pool, 16 —_ and outside off the dock by the Intracoastal. 17 Q. Were you photographed on more than one 18 occasion? 19 A. No. 20 Q. Let me rephrase the question. You 21 mentioned that you were photographed everywhere in 22 the house? 23 A. Yes. 24 Q. Was there -- 25 A. It was in the same day. 0198 1 Q. But more than one picture was taken? 2 A. Yes. 3 Q. All right. And what type of, do you know 4 — what type of camera was used? Was it a digital 5 camera or a -- 6 A. A digital camera. 7 Q. All right. file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023572

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8 A. It was digital -- it wasn't like a digital 9 camera like, it was like a photography digital camera 10 ‘like a professional camera, a professional digital 11 photography camera. 12 Q. Are you, are you -- 13 A. Not like one you buy at Wal-Mart. 14 Q. When you're describing it as a 15 professional digital camera, are you talking about a 16 camera that's got a big lens on it? 17 A. Yes. 18 Q. And did this -- 19 A. And there, and there was a regular digital 20 camera. She used two different cameras. 21 Q. And you say this was, in addition to being 22 in the house, was that on a dock? 23 A. Yes. 24 Q. And, and were you completely nude for all 25 __ of these photographs? 1 A. Yes. 2 Q. So this happened in the daytime? 3 A. Yes. 4 Q. Lassume the dock is out somewhere near 5 the Intracoastal? 6 A. Yes. 7 Q. Out in plain view? 8 A. But there was nobody outside. I made sure 9 there was nobody that could see me. 10 Q. Had anyone before that occasion ever 11 photographed you in the complete nude? 12 A. And I already said no. 13 Q. And how many photographs would you 14 estimate were taken? 15 A. I don't know. At least ten. 16 Q. Did you -- how, how is it that it -- well, 17 strike that. 18 Did, did [J ask you if she could take 19 photographs of you in the nude? 20 A. She called me and told me that Mr. Epstein 21 would pay me $500 if there could be nude pictures taken 22 of me. And my words to her were only if you take them; 23 | will not let Mr. Epstein take them of me. 24 Q. All right. So you set the conditions 25 __ under which the photographs were to be taken? 1 A. Yes. 2 Q. And the photographs were taken with your 3 knowledge and consent, correct? 4 A. (Witness nods head.) 5 Q. Did you ever see the photographs? 6 A. Since that day, no. I saw them on the camera. 7 ‘I've never seen the actual photographs. 8 Q. Did you make any comment to | | about 9 the photographs? file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023573

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10 A. Yeah, I asked them what would happen with 11 them, and she told me that they were for Mr. Epstein's 12 personal enjoyment. 13 Q. Was Mr. Epstein present when these 14 photographs were taken? 15 A. No, not to my awareness. 16 Q. You -- that is on the occasion that you 17 _ went to the house when these photographs were taken, 18 you never saw Mr. Epstein? 19 A. Yes, I didn't see Mr. Epstein. No. 20 Q. Have you ever been photographed in any 21 kind of sexual act? 22 A. No. 23 Q. Have you ever been filmed in the nude -- 24 A. Yes. 25 Q. -- as supposed to still pictures. When 0201 1 were you filmed in the nude? 2 A. With one of my boyfriends. 3 Q. And which one was that? 4 A. . 5 Q. And when was he your boyfriend? 6 A. Iwas 13. 7 Q. Excuse me? 8 A. When I was 13. 9 Q. And how did you know mz: 10 A. He was my boyfriend. 11 Q. Did you, what did you grow up in the 12. community with you? 13 A. We went to school together. 14 Q. Was this before or after the point in time 15 that you had your relationship with ? 16 A. It was after. Well, it was before. I 17 don't -- it was like during type of thing. Even though 18 she was my girlfriend, we still had boyfriends if that 19 helps you. 20 Q. Who -- was anyone filmed with you in the 21 nude? 22 A. No, just me and him. 23 Q. But the film was of the two of you 24 together as supposed to just you alone? 25 A. Yes. 0202 1 Q. And what were you and he doing in the 2 film? 3 A. Having sex. 4 Q. Just intercourse? 5 A. Yeah. 6 Q. And who was doing the filming? 7 A. The camera. 8 Q. So, it was placed on a tripod or 9 — something? 10 A. Yeah. 11 Q. And where did the filming take place? file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023574

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12 A. In the privacy of our bedroom. 13 Q. At your house? 14 A. Yes. 15 Q. And when I say your house, I mean the 16 house that you were living in at the time. 17 A. No, it was his house. 18 Q. And did, obviously you were aware of the 19 fact you were being filmed? 20 A. Yes. 21 Q. Did, did honetic) ask you -- 22 A. His name is 23 Q. Did ask you ‘if he could do that 24 beforehand? 25 A. Yes. 0203 Q. Did you indicate to him that you had any reservations about it? Did I indicate -- Did you tell him it was okay to do it? Yes. Did you guys watch the film after you did = ™ E opore> OPoF Yes. Was the film -- And we laughed about it. Was the film ever shown to anyone else? No. The tape was destroyed. For what period of time did you have a sexual relationship with a A. I don't know. For as long as we dated. Q. Are we talking about a year? A. No. Less than that. Couple of months. Q. Less than a year. How, roughly on how many occasions would you estimate you had sex with SBIDDEBHNSLSOCKPAIAVEWNS 20 ? 21 A. I don't know. 22 Q. Did you have it with any degree of 23 regularity? I mean, once a week, twice a week? 24 A. Once or twice a week. 25 Q. Did -- when you had sex with ma 0204 1 when you were 13 once or twice a week, did you take 2 any precautions about getting pregnant? 3 A. Yeah. 4 Q. And what precautions did you use? 5 A. A condom. 6 Q. Have you ever had any abortions? 7 A. No. 8 Q. You have two children? 9 A. Yes, I do. 10 Q. And when was your first child born? 11 A. When I was 17. 12 Q. Do youknow your child's birthday? 3A. Yes ill file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023575

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14 Q. And that's the child with [Je 15 A. Yes. 16 __And then you had a daughter with 17 ? 18 A. Yes. 19 Q. And what's your daughter's birthdate? 21 Q. And where was your child with | 22 ~—born? 23 A. Good Samaritan Hospital. 24 Q. Where was the child with [J -- 25 A. Good Samaritan hospital. 0205 1 I planned both my children. 2 Q. Did you, have you at any time lost a 3 pregnancy; that is been pregnant -- 4 A. Yes, I have. 5 Q. Okay. And when did that occur? 6 A. April of '08. 7 Q. Literally a month, less than a month after 8 you had -- 9 A. Before. 10 Q. Your child -- okay. Let's go back because 11 you, if | got your testimony right -- 12 A. Oh, not '08. I'm sorry. 13 Q. Yeah. 14 A. My daughter was born in It was '07. 15 Q. Okay. April of '07 is when you lost a 16 child? 17 A. Uh-huh. 18 Q. And who was the father of that child? 19 A. That's irrelevant. 20 Q. Was it someone other than a: 21 A. Yes. 22 Q. Was it 23 A. No, it was not. 24 Q. Was it ? 25 A. Yes. 0206 1 Q. Had, had that been a planned pregnancy? 2 A. No. 3 Q. Was that, that is the loss of the child 4 that you had with , a traumatic event to 5 you? 6 A. No. 7 Q. And by traumatic | mean were you upset about it? 9 A. No. 10 Q. And do you know why you weren't upset 11 about it? 12 A. Because it obviously wasn't meant to happen 13 because | didn't do anything for my child to die. It 14 —_ just died inside me, so obviously it wasn't meant to be. 15 Q. And where were you at the time that that file://(C//Documents"%20and%20Settings /Production/Desktop EEE -°620Vol.°%2011.txt[ 12/11/2009 6:15:58 PM] EFTA00023576

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te 07 POM oH Se MADAME wWNE 15 16 17 file:///C\/Documents"20and%20Settings/Production/ Desktop i: occurred? That, that I was hospitalized for? No, when you first lost the child. I was in New Jersey. Were you living in New Jersey at sometime? Yes, I was. When did you live in New Jersey? Earlier that year in 2007. And obviously then there had come a time sometime in early 2007 when you changed your BO POPO>O> residency from Florida and moved to New Jersey? A. Yes. And then I moved back to Florida and started having a miscarriage. And I had to have an operation. And the baby was dead inside me, and I was five months pregnant. Q. When you moved to New Jersey, did you move with ois A. Yes. Q. And when did you first meet | A. In'06. Q. When? A. '06. Q. Had -- how would you characterize your relationship with — A. Great. Q. Any domestic violence? A. Nope. Q. Had he ever threatened you? A. Nope. Q. When did you first meet ma: A. When I was 13. Q. Did you, did you meet him before you first went to Mr. Epstein's? A. Yes. Q. Had you had a sexual relationship with HEE obviously? A. Yes Q. Had you had sex with P| before you went to Mr. Epstein's the first time? A. Yes. Q._ And what sexual acts had you engaged in with before you went to Mr. Epstein's? A. Intercourse. Q. And did you consider P| to be your boyfriend? A. Yeah. Q. And were you dating him during the entire period of time that you went to Mr. Epstein's? A. Yeah. Q. And did FY ever physically bring you to Mr. Epstein's house? A. Yes. 20V ol. %201Ltxt[ 12/11/2009 6:15:58 PM] EFTA00023577

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18 Q. Did you ever pay | any money for 19 bringing you to Mr. Epstein's house? 20 A. No. 21 Q. Did | ever bring anyone else to 22. ~‘Mr. Epstein's house? A. My brother came with us but he didn't bring any other females, no. Q. How about 2? 23 24 25 02 1 A. Oh, i. and i. when I went with them. He 2 didn't bring them there by themselves. 3 Q. Let me go back and make sure my question 4 is clear. Was there, was there ever an occasion 5 that drove a vehicle in which there were 6 _ other girls that were delivered to Mr. Epstein's 7 house other than just yourself? 8 A. You say delivered like we're a bunch of 9 flowers for him. 10 Q. Pick whatever, what word would you prefer, 11 dropped off? 12 A. Yes, that sounds a lot more better than 13. delivered. 14 Q. Fine. W hatever you want. Ever any 15 occasion where | brought any females that 16 he dropped off at Mr. in's other than -- 17 A. Yes. me and ., and me and I 18 Q. Did I or . ever pay 19 money for bringing them? any 20 A. No. 21 Q. Did you ever receive any money from 22 Mr. Epstein for bringing .? 23 A. Yes. 24 Q. How much did you get? A. Anextra $100. Q. And did you tell i. that you were paid $100 by Mr. Epstein to bring her to him? 25 0210 1 2 3 A. Yes. 4 Q. And what was her response? 5 A. I want half. 6 Q. And what did you say to that? 7 A. Okay. 8 Q. So, you gave her 50 of the $100? 9 A. Yeah. 10 Q. And everybody was happy? 11 A. Yeah. 12 Q. Did you bring i. on more than one 13 occasion? 14 A. Yes. 15 Q. Did you get paid $100 on each occasion -- 16 A. Yes. 17 . -- that you brought | Did you tell . on each occasion when you got paid $100 to 19 bring her? file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023578

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A. Yes. Q. And did you give her half the 100 or $50 every time -- A. Yes. Q. -- that you were paid? On how many occasions did bring . and get paid $100? 20 21 22 23 24 25 0211 1 A. Three or four times. 2 Q. How much did | | get paid to come to 3 Mr. Epstein's? 4 A. 200, sometimes three. I'm not sure which 5 times. Probably the times when she went there herself. 6 Q. Did fi. go to Mr. Epstein's on occasions 7 other than when she went with you? 8 A. Yes. 9 Q. But she had never been there until you 10 took her the first time? 11 A. Yes. 12 Q. Were you the individual that first 13 suggested to . that she go to Mr. Epstein's? 14 A. Obviously if I'm the one who brought her there 15 for the first time. 16 Q. Well, it would be possible that she could 17 have heard of Mr. Epstein from someplace else. 18 A. No. 19 Q. So the first time she heard the name 20 Jeffrey Epstein was from you? 21 A. Yes. 22 . And on the first occasion when you told 23 Ye Jeffrey Epstein, what did you tell her? 24 A. That we would go there and give him a massage 25 and he might ask you to get topless. 0212 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Q. Did you tell her at the time that you first discussed it with her everything that you had experienced in going to Mr. Epstein's? No. Why not? Because I knew she wouldn't be exposed to it. And this was your best friend? Yes. And you say you knew what? I knew that she wouldn't be exposed to it. . What do you mean she wouldn't be exposed to it? A. Because | knew that I felt uncomfortable with the thing with the girl. And I told Jeffrey if he did it to my friends, | would not bring them. Q. Okay. A. So I knew that she wouldn't have been exposed to it. Q. So, in your, you had some conversation at some point in time with Jeffrey Epstein about -- A. I took -- when he asked me to bring some girls QPOPOPoPr file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023579

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22s my age, I told him that I would not bring my friend if, 23 if that situation was to occur with her because I didn't 24 like it. I felt uncomfortable, and I would not subject 25 my friend to it. 0213 1 Q. Is that the only thing that had occurred 2 when you were at Mr. Epstein's that you did not tell 3 . about? 4 A. Yes. 5 Q. So, you had told that Mr. Epstein 6 — might masturbate while she was there? 7 A. Yes. 8 Q. Did you tell her that he might ejaculate while she was there? A. Noton her but yes. Q. Well, did Mr. Epstein ever ejaculate on you? A. No. Q. Allright. What did you tell i. before you took her there for the first time about what the state of dress that she would be in? A. I just told her to wear clothes. Q. Did you tell her that she may be asked to be totally nude? A. I said that she, she might ask to take off some of her clothes. I didn't specifically say you're going to have to get naked. Q. But you had been, at that point in time that you first took | | there, you had been totally nude for months while performing massages for Mr. Epstein, correct? A. So. Q. Correct? A. Yes. Q. But you didn't tell your best friend that? A. No, because if he was going ask her, that would be him asking her and that would be her own decision. Q. You didn't consider there to be anything dangerous about going to Mr. Epstein, did you? A. No. Q. I mean, you never felt like you were in danger when you went to Mr. Epstein's did you? A. No. Q. You never felt that any harm was going to come to you? A. No. Q. And you really never had any fear about going there, correct? A. Correct. May I take a break to go to the bathroom? MR. LUTTIER: Sure. THE VIDEOGRAPHER: Off the record at 3:30. file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023580

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nn vst pet peek pt . —_ Onn Ahwwoe Se rIAMFwYNHHEK HERR 16 file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] (A brief recess was held.) THE VIDEOGRAPHER: We're back on the record at 3:43. BY MR. LUTTIER: __ You mentioned earlier that you had seen a i? . Is that A. Yes, . Q. Have you consulted with any other, what we call expert witness in this case, that is someone that's been hired to assist you in your case, not your lawyers but -- A. No. Q. Okay. Do you, have you spoken with anyone else about the possibility of testifying in this case? A. Like who? Q. Anybody. A. No. Probably my son's father because he took me there. Q. That would be -- A. My mother. A. Yes. And my mother. __ And. and when did your relationship with end, if it ended? A. When I was 18. Q. That's '05? A. Yeah. Q. So you were with him from what did you tell me, 0 -- A. 'OL. Q. '01 to '05, correct? A. Yes. Q. Did there -- there obviously came a time that you got pregnant with a: A. Obviously. Q. Did you and | leave the State of Florida together at some point in time? Yes. And approximately when was that? It was in July when I was 16. '03? Yeah. Is that the same time that you stopped going to Mr. Epstein's? A. Uh-huh. Q. And is that, in fact -- MR. LUTTIER: Did you get that answer? THE COURT REPORTER: Uh-huh. BY MR. LUTTIER: Q._ -- is that in fact why you stopped goin to Mr. Epstein's, because you and EEE cc OPOrPOP EFTA00023581

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0217 leaving? A. Yes. Q. And where did you and | go? A. To Rome, Georgia. Q. And when I said, when I say that you went there, did you physically move your residency to start living there? A. Obviously. Q. And did you live with some relatives or friends or something in Rome? A. His relatives. Q. And who would that have been? A. His father and his aunt and uncle. __ When you left to go to Rome, Georgia, with in July of '03, did you know you were pregnant? A. No. Q. When did you first learn you were pregnant? A. In August. Q. Of'03? A. Yes. Q. And when you learned you were pregnant in August of '03 for how long had you been pregnant? A. I, actually I think we left in June because in August I had already been three months pregnant. Q. Had you and Mr., not Mr. -- had you used any drugs, nonprescription drugs between June of '03 and August of '03? A. No. Q. When was the last time you had used any drug for which you didn't have a prescription? That's a bad question. A. I don't know. Q. Starting in August of '03 and going back in time, when was the last time? A. Probably in the beginning of '03. Q. Beginning of '03-- A. We left, we left -- Q. You mean January of '03? A. No, if you would let me finish. We left the State of Florida because we had a bad cocaine habit by that point. With all the money that I received from Mr. Epstein I could afford it. So, we had made a decision to leave the State of Florida and I had been clean for about a month and we couldn't handle it. So we decided to leave the State of Florida so we wouldn't have to worry about it anymore. Q. So, if you left in June of '03 that means your last use of cocaine would have been in May of e SCNHNNNNN Kee eee eee SCNHNNNN ND & BeBe eee eee _ PARDO HE SSCHIADEWNHSPFAADVFYWNKHARKHNHNKESSHZIAUEWNH SOPAIAVFSWN — _ ad oo '03? file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023582

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A. May, June, yeah. Q. And at that point in time, that is in May of '03, what form of cocaine were you using? A. Powder. Q. As of May of 03, had you, had you ever used crack cocaine? A. No. Q. From May of '03, or I should say after May 10 of '03, when you became aware that you were pregnant 11 in August of '03, did you use any drugs at all 12 during your pregnancy? COeADMNFwWhH 13 A. No. Other than nicotine. 14 Q. Say what? 15 A. Other than nicotine. 16 __And you had a healthy child born wu 18 A. Yes, I did. 19 Q. Born where, at what state, Florida or 20 Georgia? 21 A. In Florida. 22 __ Was there a point in time that you and 23 | returned to Florida? 24 A. Yes. 25 Q. When was that? 0220 1 A. When I was eight months pregnant. So, in 2 February. 3 Q. Of'04? 4 A. Yeah. 5 Q. And, and why did you return to Florida? 6 A. Because it was too cold for my mother. 7 Q. And what did your mother have do with it? 8 A. My mother moved to Georgia with me when she 9 found out I was pregnant. 10 Q. And that would have been when? 11 A. Obviously -- 12 Q. You, you found out you were pregnant in 13 August? 14 A. I was pregnant in August. 15 Q. Did you tell her that? 16 A. Yes. And she moved up there immediately. My 17 mom had moved up there because | thought I was pregnant 18 and she was there the day I took the pregnancy test. 19 __ And did she live, literally live with you 20 ~~ and or live in a separate place? 21 A. She had boughten (sic) her own place. 22 Q. And she stayed there from August of '03 to 23 February of '04 -- 24 A. Yes. 25 Q. -- continuously? 0221 A. Yes. 1 2 Q. Were you, after a. did you 3 remain -- strike that. Did you use any drugs, file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023583

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SI MMM Nhe eR RR ABRUNOH=SCHIDDEBWNH SOP RADMSE b da dd fa pth tek tk tk tek tek te o cee eS > Nm M&M hy wnNe oS Mh oe 0223 oe eo file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] illegal drugs after | tsi A. Yes, I did. Q. When was the first time you used an illegal drug after March of '04? A. When I turned 18. Q. Which would have been -- A. January. Q. January of -- A. '05. Q. So, you were absolutely drug free, that is you didn't use any illegal drug whatsoever from May of '03 to January of '05? A. Yes. Q. Did you, during that period from May of '03 to January '05 go to any kind of a drug rehabilitation -- A. No. Q. -- clinic? Did you have to seek any kind of -- A. No. Q. -- medical assistance to stop using drugs? A. No. Did you, did you use anything, patches or any of the products that are available in the general public to try to get off of drugs? A. No. Q. So, you were able on just strictly on your own will -- A. Yeah. Q. -- to stop using all drugs from May of '03 to January of '05? A. Yes. Q. How would you describe your life from July of '03 when you, approximately when you moved to Georgia through February of '04? A. Frustrating. Q. And why was it frustrating? A. Because I had a lot of secrets that I had held from about Mr. Epstein, and | was just felt like I was losing my mind. Q. Did you seek any medical attention through the period from July 3rd to February '04. July of '03 to February '04? A. Yes, when I was pregnant, yes, I did. I went to a baby doctor. Q. Did you seek any mental health treatment? A. No. Q. You say you held secrets from a. What secrets did you hold from ? A. What exactly was happening at Mr. Epstein's house. Q. Well, you indicated that | | took you to EFTA00023584

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6 Mr. Epstein's on more than one occasion? 7 A. But he didn't know what_L was doing. 8 Q. When was the first time took you to 9 Mr. Epstein's? 10 A. I don't know. 11 Q. But we know it wasn't the first or second 12 time, right? 13 A. Yeah. 14 Q. Because on those occasions you went with 15 Jane Doe No. 102? 16 A. He only, he only took me sometimes because 17. Mr. Epstein paid for either his drivers to pick me up 18 and drop me off or a Yellow Cab. 19 Q. Well, do you recall the first, the 20 __ incident the first time took you? 21 A. What do you mean the incident? 22 Q. Well, do you recall what you told him 23 first time when you had him take you? 24 A. That I was going to clean his house. 25 Q. And what did say in response? A. Okay. Q. Did you, the next time that he took you, did you tell him anything different? A. No. Q. Did there ever come a time that when | | took you to Mr. Epstein's you told him anything other than you were going there to clean the house? A. No. Q. Did ever ask you -- or, or strike that. When took you to Mr. Epstein's, did he wait for you or did he come back? A. He waited for me. Q. And where did he wait? A. Outside by the Intracoastal. It was in front of the house the FBI was at. Q. So, he didn't come in the house? A. No. Q. Did he ever meet Mr. Epstein? A. Yes, he has. SRNR TERDH HS ewrgauvswne 20 Q. Did he ever have any discussions with 21 Mr. Epstein? 22 A. Yeah, about the Shelby Cobra that Mr. Epstein 23 has. My wires -- 24 THE COURT REPORTER: The what? 25 THE WITNESS: Shelby Cobra. My wire is 0225 1 stuck in this chair. 2 MR. DANCHUK: Hold on. 3 MR. SCAROLA: Let's go off the record for 4 just a second, please. 5 (A brief recess was held.) 6 BY MR. LUTTIER: 7 Q. Were you present for any discussions file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023585

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14 23 24 25 0227 1 2 3 4 5 6 7 8 9 file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] between | | and Mr. Epstein? A. Yes, I was. Q. And where did they take place? A. Outside in the driveway in front of the garage that had all the cars. Q._ When was the last time you had contact with ? Thanksgiving. Of this year? Yeah. And what did that contact consist of? Eating turkey. . Did you-all celebrate Thanksgiving together? Yes. You do. We do. We celebrate every holiday together. And where was that? OPOro>r At my mother's house. Did you discuss with | this case? Absolutely not. Has ever discussed with you his contact or discussions with Mr. Epstein? Yes. He told me that you guys tried to hire OFPOF QOPO> = B > Who do you mean by "you guys"? Mr. Epstein's law firms. Which firms are you talking about? The ones that defend Mr. Epstein. Did you know how many law firms that is? . [have no idea. All I know is that his law s tried to hire my son's father. And when did he tell you that? Last year. Meaning calendar year '08? Yep. And was | | incarcerated recently? Yes, he was. And when was he incarcerated? I believe it was -- was it -- I think it was last year. Q. That would be '08? A. Yes. ZB >opoPre fi POPOPOPO Q. When did he get released from incarceration? A. I don't know the date. Q. So, did these lawyers that were trying to hire him go meet him in jail? Is that what you are saying? A. I don't know. Mr. Epstein was in jail with him. Q. So, Mr. Epstein and FY met each EFTA00023586

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10 other while they were both incarcerated in the same 11 institution? 12 A. No. Mr. | | and Mr. Epstein, or | 13 and Mr. Epstein met each other while I was still going 14. to Mr. Epstein's house, but then again met while they 15 were incarcerated together. 16 Q. Did | | ever share with you what he told 17. Mr. Epstein about you? 18 A. No. 19 Q. Did he ever tell you that he discussed you 20 with Mr. Epstein? 21 A. Yes. 22 Q. But he didn't tell you what he said? 23 A. No. 24 Q. Did he ever tell you what he said about 25. what information you knew about Mr. Epstein before 0228 you went -- A. No. Q. -- to see him the first time? Did he ever tell you about what you told the other girls before you took them to Mr. Epstein's? A. No. Q. Did he ever tell you that he attempted to get employment from Mr. Epstein? A. Yes. Q. And what did he tell you Mr. Epstein said in response to that? A. [have no idea. But if you would like to let me know, go ahead. Q. Is as far as you know, an honest person? CHIADMABHWNHE SORADVWHWNS A. No. Q. He is not honest? A. Absolutely not. Q. So you wouldn't believe what he says? 20 A. No. Would you? 21 Q. No meaning that my statement is correct, 22 you would not believe what he says? 23 A. That's what I am saying. 24 Q. So, you don't really believe the statement 25 he made to you that, what somebody tried to hire -- 0229 1 A. No, I believe that you guys tried to hire him. 2 Q. How do you decide which statements he 3 makes you believe and which you don't? 4 A. He showed me the address. 5 Q. The address of what? 6 A. Your guys's law firm. 7 Q. Well, you keep saying, you guys. What 8 firm is that? 9 A. The attorneys on Mr. Epstein's side off of 10 ‘Flagler Drive. 1 Q. And did he tell you, did J teu! file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023587

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12. _- you that he came to meet with those lawyers? 13 A. Yes, he did. 14 Q. Did he tell you whether or not every 15 single word he said had been recorded? 16 A. Ihave no idea. He didn't tell me anything 17 about it. 18 Q. Did he tell you who-all was present at the 19 meeting? 20 A. No, he didn't. 21 Q. He didn't tell you anything about what he 22 said at that meeting, did he? 23 A. No. 24 Q. And in particular he didn't say what he 25 said about you, did he? 0230 1 A. No. 2 Q. You didn't ask him either, did you? 3 A. I did and he wouldn't tell me. 4 Q. Did you wonder why he wouldn't tell you 5 what he had told Mr. Epstein's lawyers about you? 6 A. No, and I could really care less because he 7 didn't go through half the traumatic things I did with 8 Mr. Epstein. 9 Q. Well, what traumatic things did you go 10‘ through? 11 A. Well, being that I was an underage girl with 12 an old man masturbating in front of me and bribing me 13. with hundreds and hundreds of dollars -- 14 Q. And how did that, how did that result in 15 any injury to you? 16 A. Well, my mental stability is nothing like it 17 _used to be before I met Mr. Epstein. 18 Q. What do you mean by mental stability? 19 A. I'm scared to go places by myself. I have 20 trust issues with people now. I don't like when older 21 guys stare at me. 22 Q. Well, after you worked -- anything else? 23 A. Oh, no, you can go ahead. 24 Q. No, I want to get all your injuries that 25 you claim you have suffered as a result of going to 0231 1 Mr. Epstein's. Anything else? 2 A. You may continue. 3 Q. Is there anything else or have you now 4 told me everything and I will go back and ask you 5 about it? 6 A. You can continue asking me questions. 7 Q. Is there any other way you suffered any 8 — damage as a result of going to Mr. Epstein other 9 than your mental stability is not the same, you're 10 scared to go places by yourself, that older guys, 11 you don't like it when older guys stare at you. 12 A. [have trust issues. 13 Q. Trust issues. Anything else? file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023588

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14 A. I don't know right now. 15 Q. Do you know of any way you suffered any 16 damage? 17 A. What? 18 MR. SCAROLA: Well, you have already heard 19 repeatedly -- 20 MR. LUTTIER: No speaking -- Other than 21 what you have told me in this deposition. 22 MR. SCAROLA: That's fine. 23. +BY MR. LUTTIER: 24 Q. Okay. Is that it? 25 A. Yeah, that's it. 0232 1 Q. Okay. Now, what do you mean when you say 2 you have trust issues. 3 A. Exactly what I said. 4 Q. Well, I don't understand that. Explain 5 that. Explain that to me. What do you mean you 6 have trust issues? 7 8 A. Ihave trust issues with people. Q. Meaning what, you can't trust people? 9 A. No, I can't. 10 Q. Anybody? 11 A. Guys particularly. 12 Q. Males? 13 A. Males, older males. 14 Q. Any males, older males? 15 A. Yes. 16 Q. What age male does it have to be for you 17 not to be able trust them? 18 A. Older than myself. 19 Q. So, any man that is older than you, you 20 — don't feel like you can trust him? 21 A. No. 22 Q. How has that impacted you in your daily 23 ~—silife? 24 A. Well, I go outside and there is men 25 everywhere. 0233 1 Q. Okay. So, what effect does that have on 2 you? You can't trust the people -- 3 A. Exactly -- 4 Q. -- according to you? 5 A. -- it. I can't trust nobody. 6 Q. So, you're not asking them to do anything 7 or do anything for you, are you? 8 A. No, because I don't want them to. 9 Q. Okay. So, help me understand how has this 10 — impacted you at all that you claim you can't trust 11 men that are older than you? 12 A. Because I can't trust them. What else do you 13 want me to say? 14 Q. Well, I want you to describe how -- 15 A. I can't -- file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023589

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16 Q. How your damage -- what is it that you 17 want these men to do -- 18 A. Nothing, I don't want them to do anything. 19 Q.. -- that -- wait a minute. 20 A. I want them all to leave me alone. 21 Q. What is it that you want these men to do 22 that you can't trust them to do? 23 A. There is nothing that I don't want, that I 24 _~want them to do. 25 Q. Have you ever asked a man older than you 0234 1 to do something? 2 A. Other than my attorneys, no. 3 Q. All right. 4 A. No offense to you guys. 5 Q. So, there has never been an occasion since 6 you last went to Mr. Epstein where you asked a man 7 that was older than you to do something and you 8 counted on trusting them? 9 A. I counted -- well, my attorneys, but that's 10 it. 11 Q. Okay. But there has never been a time 12 that you've placed your trust -- 13 A. [refuse -- 14 Q. Wait a minute. 15 A. No, I don't let them, allow them. 16 Q. Now, so, you haven't even attempted to, 17 —_ quote, to use your words, trust a man that's older 18 than you since you last saw Mr. Epstein; is that 19 correct? 20 A. Yes. That's correct. 21 Q. Now, when you say trust, do you mean you 22. don't want to be in their physical presence? 23 A. I don't, no, | don't want to be in their 24 physical presence. 25 Q. But in fact as you testified earlier, you 0235 1 worked for at least two escort services where you 2 have gone out and been paid to be in the presence of 3 men older than you, correct? 4 A. Correct. 5 Q. Didn't feel like you were in any kind of 6 danger, right? 7 A. No, sometimes I did. And I already told you 8 those times. 9 Q. Well, you wouldn't have gone if you 10 thought you were in any danger, would you? 11 A. Exactly. 12 Q. Okay. So there were many occasions that 13. the driver came and got you, and you were going out 14 with somebody at the escort services where they were 15 older than you and you had no fear of anything; 16 _ isn't that right? 17 A. Yes. file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023590

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18 Q. By the way, when you worked for these 19 escort services, would they call you up and tell you 20 — on such-and-such a day there is somebody that wants 21 to go out with you? Is that how it was done? 22 A. Yes. 23 Q. What would they tell you about the person 24 that wanted to go out with you, if anything? 25 A. They would tell me where, what the occasion 0236 1 was, what I would be doing, what kind of wear I would 2 have to wear, formal, outside, the type of dress I 3. needed to wear. 4 Q. Did they -- well, what specifically did 5 they tell you about what you had to wear? Did they 6 tell you, describe what kind of clothes or just-- 7 A. I just said formal. 8 Q. But did they say, for example, wear 9 something that's low cut or don't wear a bra or, you 10 know, wear this or wear that? 11 A. No. 12 Q. Or this is just a formal or this is a 13 semi-formal occasion? 14 A. It's a formal or semi-formal for the fourth 15 time now I| am telling you. So I am done answering 16 — questions about that. 17 Q. What else did they tell you other than 18 — what to wear? 19 A. Nothing. 20 Q. Did they tell you anything at all about 21 the person with whom you would be going out? 22 A. Sometimes. 23 Q. And with what degree of frequency would 24 they tell you about the person that you were going 25 out with? Did they always do that? 0237 1 A. Sometimes. I just said sometimes. 2 Q. More than half the time? 3 A. Sometimes. If it was -- 4 Q. More than half -- 5 A. -- more than half the time, I would have said 6 more than half the time, but it's sometimes. 7 Q. So that was -- 8 A. Sometimes yes and sometimes no, sometimes. 9 Q. Would you estimate that it was less than 10 half the time? 11 A. I'm not answering that question seriously 12 because I have said sometimes. 13 Q. Describe sometimes to me by percentage. 14 A. I don't know the percentage of sometimes. 15 Sometimes. 16 Q. Well, let's -- we all know what 50 percent 17 is, right? 18 A. So 50 percent. There you go. There is your 19 sometimes. file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023591

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20 Q. Don't let me put words in your mouth, 21 ma'am. You were there, not me. 22 A. I said sometimes. 23 Q. Ifyou could just tell me if it was more 24 or less than 50 percent of the time? 25 MR. SCAROLA: And you have been told 0238 1 repeatedly that she is unable to do that for 2 you. 3. BY MR. LUTTIER: 4 Q. So, how can you quantify for me by 5 definition your phrase sometimes? 6 MR. SCAROLA: And the answer to that 7 question is she's been unable to. So we're 8 sorry that we can't give you more specific 9 information. But "sometimes" obviously means 10 more than once and less than always. 11 THE WITNESS: So you figure it out. 12. BY MR. LUTTIER: 13 Q. Well, now, ma'am, it would be hard for me 14.‘ to do that. I wasn't there. So, it could have been 15 as much, according to your definition, as 99 percent 16 of the time, right? 17 MR. SCAROLA: At this point those 18 questions are annoying, embarrassing, and 19 harassing, and I will instruct the witness not 20 to answer. 21 BY MR. LUTTIER: 22 Q. What else, if anything, were you told 23 about the individuals that you were going to be 24 — going out with when you were working for the escort 25 services? 0239 1 A. What does this have to do with the original 2 question at hand? 3 Q. Ifyou can just answer my question now. 4 A. And | already told you what they would tell 5 me. 6 Q. Were you told anything else? 7 A. No. 8 Q. Were you told the person's name? 9 A. Yes. 10 Q. All right. Were you told the person's 11 name each time? 12 A. Yes. 13 Q. Allright. So there's a piece of 14 information that you got every time. Were you told 15 __ the person's age? 16 A. No. 17 Q. Ever? 18 A. No. 19 Q. Did you tell the people at the escort 20 _ service that you only wanted to go out with people 21 of a certain age bracket? file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023592

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22 A. No. 23 Q. You had to -- it was like a come and take 24 all? You had to go out with whoever they said? 25 A. Yes. 0240 1 Q. Did you have the right to say no to 2 somebody? 3 A. Yes. 4 Q. Did you ever, did they ever call you and 5 say they had someone for you to go out with and you 6 said, no, I don't want to go out with them? 7 A. No. 8 Q. So everybody that was ever, I will say offered to you, you accepted? A. Yes. Q. What's your best estimate about how many escorts you had between these two escort services? I don't know. More than 50? No. More than 25? No. About 25 people. Were you told the person's race? Yes. Did you give the escort service any criteria about the type of person you would agree to go out with? A. Yes. Q. What criteria did you give them? A. I wouldn't go out with black guys because Lopopore> black people are abusive and controlling. And I have, I just felt unsafe. And I would only go out with people that didn't want sex or anything sexual. Q. So you said no black guys and you said no one that wants anything, sex or anything that's sexual? A. Yes. Q. Did you have to describe for the escort service -- A. No, I didn't. Q. -- what you meant by sexual? A. Anybody in their right mind what know what sexual and sexual things are. Q. So, you didn't give them any age bracket, right? A. No. Q. You didn't give them a weight bracket, correct? A. No. Q. And on how many occasions did you have men that you went out with that were older than you? A. Every time. Q. Did you ever have to seek any kind of file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023593

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24 medical care or attention after going out with one 25 of these individuals that was provided through an 1 escort service? 2 A. No. 3 Q. Did you ever seek any kind of mental 4 health counseling? 5 A. No. 6 Q. Or mental health services as a result of 7 having gone out with anyone through the escort 8 service? 9 A. No. 10 Q. Were you ever physically hurt in any 11 manner whatsoever as a result of going out with 12 anyone through one of these escort services? 13 A. Would that qualify under me having to seek 14 medical attention? 15 Q. No. Were you ever hurt in any manner as a 16 result of going out with anyone through any of these 17 escort services? 18 A. No. 19 Q. After you quit going to Mr. Epstein's, did 20 you work at one or more topless bars or 21 establishments? 22 A. No. 23 Q. Have you ever worked at a topless 24 establishment? 25 A. I was a stripper for one night. 0243 1 Q. And where? 2 A. For three hours, not even. 3 Q. Where was that? 4 A. I don't remember the name. | think it was 5 Platinum Showgirls or something. 6 Q. And when was that? 7 A. I don't remember the year. 8 Q. Was it after Mr. Epstein? 9 A. Yes. I left because I felt degraded. 10 Q. During the time that after you left -- 11 strike that. After you last went to Mr. Epstein 12. which you say is in August of '03. did you have a 13. normal sexual relationship with ? 14 A. No. 15 Q. Were you having sex with him as frequently 16 as twice a day? 17 A. No. 18 Q. Have you ever told anyone that that's what 19 you did? 20 A. No. 21 Q._Was there ever a time that you had sex 22. with twice a day? 23 A. Yes. 24 Q. When was that? 25 A. Before Mr. Epstein. file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023594

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& 1 Q. And when did it change? 2 A. When I started going to Mr. Epstein's. 3 Q. And what did it change to? 4 A. To once or twice a week. 5 Q. And why did it change? 6 A. Because I felt disgusting. 7 Q. Did there ever come a time after you went 8 to Mr. Epstein's that you resumed having sexual 9 relationships with the same degree of frequency with 10 or anyone else? 11 A. With what? 12 Q. With 13 A. What do you mean? 14 Q. Did there ever come a time -- 15 A. That I went back to the same -- 16 Q. Right. 17 A. No. 18 __ Did you have sexual relationships with 19 ? 20 A. Yes. 21 Q. And you met him after Mr. Epstein, right? 22 A. (Witness nods head.) 23 Q. Did you have a normal sexual relationship 24 with him? 25 A. Yes. 0245 Q. With what degree of frequency did you have sex with him? A. No, but I see my son as often as I would like. And as fast as I get out of here is as fast as I can go pick him up. Q. You say you did not relinquish your parental rights? 1 2 3 A. Once, twice, or three times a week. 4 Q. As often as you wanted it? 5 A. As often as I could stand it. 6 Q. Did you have it as often as he wanted it? 7 A. No. 8 Q. Did you have a baby with him as well? 9 A. Yes. 10 Q. And the baby that you had with [ that 11 baby's name is what? 12 A. . 13 Q. And have you what is known as relinquished 14 ‘your parental rights for ? 15 16 17 18 19 20 A. I did not, 21 Q. Was , that is your son, ever taken 22. away from you? 23 A. I signed my parental rights over to his 24 aunt -- 25 Q. Okay. Well, that's what I meant by the 0246 1 word-- file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023595

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A. -- for his financial stability. Q. Maybe you didn't understand what I meant by the word relinquished. Did you ever give up or sign away your parental rights to your son, = A. Yes, I did. Q. Would you explain the facts and circumstances surrounding you doing that? A. I was not financially stable enough to take care of him. Q. And how about m7. your boyfriend, the father of your son? A. He doesn't have rights to him either. Q. And was there a legal proceeding brought to get that accomplished? A. Yes, there was. Q. And who brought that legal proceeding? A. What do you mean who brought that? Q. Who, who filed, who was the moving party? Did DCF bring that proceeding? A. Yes. Q. And as part of that proceeding, did DCF tell you that they were going to take away your parental rights if you didn't sign them off? A. No. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 Q. And was that action brought here in Palm 2 Beach County? 3 A. Yes. 4 Q. And isn't it true that you, that DCF told 5 you you had no choice but to either voluntarily sign 6 over your rights, or they were going to take your 7 son? 8 A. No. 9 Q. What did they tell you about what your 10 choices were? 11 A. They told me I had to go through classes and 12 all kinds of things. But I still, whether I did the 13. class or not, I wouldn't have been financially stable 14 enough to take care of my son. So, I signed my rights 15 over to his aunt who was financially able to take care 16 of my child. 17 Q. And you, in fact, had gone to court and 18 — gotten a child support award from , had you 19 not? 20 A. A child support order? 21 _ An award of child support from, from 22 . You filed a judicial action and made a 23. complaint against him said you wanted child support? 24 A. That's when I still had my son, yes. 25 Q. All right. So, so, and the court entered 0248 1 2 an order that said he had to pay you a certain amount of child support, right? 3 A. Which he never did. file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023596

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Q. Did that child support ever come to your mother, for example? A. We never got child support from i. Q. Did you ever have a complaint that your mother was taking your child support? A. No. Q. Did you ever complain to anyone that your mother was taking your child support? A. No. Q. And your daughter's name is what? Q. Well is it. is it -- A. Q. Does it cause you any kind of upset that you have signed over your parental rights to your son ? 2 A. Ofcourse I am upset about it, but I did what 2 was best for him. Q. Doyou have parental rights for your 23. daughter — A. No, I do not. I signed my rights over to her 25. grandmother. Q. And did DCF bring an action to take away your parental rights in that case? A. They tried. Q. And as a result of that did you voluntarily relinquish your rights? A. Yes, I did. Q. And again did DCF insist that in order for you to see your child, you would have to do certain things? A. Yes. Q. And did you decide that what you would do is sign over parental rights rather than do those things? A. No, I, I did some of the things that I was supposed to do. Q. Do you know what a performance agreement is? A. No. Q. Did you do all the things that DCF said SRNR TERDH HS ewrgauvswne 20 you had to do? 21 A. Everything except for domestic violence class. 22 Q. And did DCF say that as a result of you 23 not doing everything, they were going to take your 24 child away? 25 A. They said they were going to terminate my 0250 1 rights. so I signed my parental rights over to | 3 Q. So, in both the situation involving your 4 son and your daughter, DCF had told you -- 5 A. Yes. file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023597

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6 Q. -- before you signed over your rights that 7 they were going to terminate your rights? 8 A. Yes. 9 Q. And is it also distressing to you that you 10 had to relinquish your rights to your daughter 11 ? 12 A. Ofcourse it's distressing. 13 Q. And where does live? 14 A. In Texas. 15 Q. How often do you see her? 16 A. Once a month. 17 Q. And how is it that you see her? 18 A. Her grandmother brings her here. 19 ; a father is a guy name 20 ? 21 A. No. His first name is i. Q. What's his last name? A Q. Now, has violent to you? Yes. When was he violent to you? When I was pregnant. What did he do? He slapped me. And where were you when that happened? Ata restaurant. Was that distressful to you? Yeah. Q. Upset you at the time? A. Obviously. Q. Was, was that the first time a man had been physically violent towards you? POPOPOPOP A. No. 15 Q. Who was the first person -- 16 A. . 17 __-- that was physically violent? And what 18 did do to you that was vio -- physically 19 violent? 20 A. He held a gun to my head. 21 Q. And when was that? 22 A. I don't remember the time and day. 23 Q. Was that before you went to Georgia? 24 A. Yes. 25 Q. And was that while you were going to 0252 1 Mr. Epstein? 2 A. Yep, it was while I was going to 3 Mr. Epstein's. 4 Q. And was, did he hold a gun to your head 5 __ because he thought you had been cheating on him? 6 A. Yeah, but not with Mr. Epstein. 7 Q. And had you, in fact, been cheating on file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023598

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8 him? 9 A. No. He was cheating on me with . 10 Q. That is he had sexual relations with es 11 your best friend? 12 A. Yes, yes. 13 Q. And when did that happen? 14 A. I don't know the time and date. 15 Q. While you were going to Mr. Epstein? 16 A. Yes. 17 __ Did you know that your then boyfriend, 18 had had sexual relations with your 19 __ best friend, ., before you took her to 20 Mr. Epstein's? 21 A. No. 22 Q. Did you ever discuss with | | the fact 23 that she had had sex with your boyfriend? 24 A. Yes. 25 Q. And what was her response? 0253 1 A. She was sorry. 2 Q. And have you two mended your ways since 3. then? 4 A. Absolutely not. 5 Q. You no longer associate with her? 6 A. Hell, no. 7 Q. And is it because that you're upset that 8 she had sex with a while you were dating 9 him? 10 A. Yeah. 11 Q. Is there any other reason? Was there any 12 other rift between the two of you? 13 A. No. 14 Q. Did, did you and she have this 15 confrontation before you stopped going to see 16 Mr. Epstein? 17 A. Yes. 18 Q. And as a result | iii having 19 sexual relations with ., did you have sexual 20 relations with somebody else? 21 A. Yes, I did. 22 Q. Who did you have sex with? 23 A. best friend. 24 Q. Sort of like as they say, what's good for 25 the goose is good for the gander? 0254 1 A. A tit fora tat. Yes. it was. 2 Q. And who was Fe best friend. 3k. 4 Q. What's | | last name? 5 A. I don't remember. 6 Q. Is the person you had sex with you, you 7 can't remember his last name? 8 A. I can't remember his last name. I'm sorry. 9 Q. Did you have -- have you had sex with more file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023599

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10 than one person whose name you can't remember? 11 A. No. 12 Q. | | the only person? 13 A. I can't remember his last name. 14 Q. Well, you recently filed some answers, 15 some amended answers to interrogatories. Let me -- 16 MR. LUTTIER: What number are we on? 17 THE COURT REPORTER: Four. 18 THE WITNESS: Exhibit 4. 19 MR. LUTTIER: These are, I think, Jack, 20 are the ones | was talking about. 21 BY MR. LUTTIER: Q. Let me show you what's been marked as Exhibit 4 which purport to be your Third Amended Answers to Defendant's Interrogatories. These do not contain a signature by you. So I would like you 22 23 24 25 02 1 to look at those, and tell me if the answers are 2 true and correct and complete. 3 A. Yeah, those are the people that I have had sex 4 — with in my life. 5 6 A. I didn't put name. Would you like me 7 ‘to reapply it? 8 Q. You actually answered one, two, three. 9 You have three answers that you have amended here. 10 So, I want you to look at all three, and now while 11 you're under oath, | am going to ask you if these 12 answers are true and correct and if they are 13. complete. 14 So, if you need to take some time, fine. 15 When you're done, let me know and I'll -- Q. Okay. W if _ have answered -- 16 A. Yeah, they're all right. 17 Q. Okay. With, with the following exception, 18 right, in 18, in answer to_18 there should be 19 another person's name, somebody? 20 A. Yep. 21 Q. And where would he fit in in terms of the 22 chronology here? 23 A. Between PY and . 24 Q. Now, you said that you dated --I 25 don't know where it is -- from 2001 to 2005. In 0256 1 your answers to interrogatories, you indicate that 2. you had sexual intercourse with a when 3 you were 15 to 16 years old? 4 A. So -- 5 __ So. does this mean that you had sex with 6 | while you were dating | 7 A. Yes, 8 Q. Did | | know about that? 9 A. Yes. 10 Q. Did you tell him about it before it 11 happened? file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023600

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12 A. No. 13 How did it happen that you had sex with 14 while you were dating ? 15 . went to Georgia. 16 Q. Okay. So -- 17 A. So, went to Georgia. 18 Q. He went to Georgia without you? 19 A. Obviously. 20 Q. When did he go to Georgia in relationship 21 to the testimony -- 22 A. To see- 2 Q. -- you gave me earlier -- 24 A. To see -- 25 Q. -- that you went there in June of '03? 0257 1 A. He went with his family when we first started 2 dating like, well, towards the first year we were 3 dating. 4 Q. Before you went and saw Mr. Epstein? 5 A. Yeah. 6 _ Allright. So the sex that you had with 7 an is sex that you had prior to the 8 9 time that you first met Mr. Epstein? A. No. 10 Q. When you say that you dated | | from 11 January, from '01 to '05 and that that was 12 continuous -- 13 A. Right. 14 Q. Was he living in Georgia part of the time? 15 A. No. He went there on vacation. 16 Q. Okay. So how long was he gone for this 17 vacation? 18 A. I don't remember. Like a week. 19 Q. All right. So, while he was gone on 20 vacation for a week during the period of time that 21 you were dating him between 2001 and 2005, you had 22 sexual relations with ? 23 A. Yes, I did. 24 Q. And, and did you tell || about it after 25 the fact? 0258 1 A. Yes. 2 Q. And that wasn't any problem for you? You 3 didn't have any trust issues with a at the 4 time? 5 A. No, I didn't have trust issues with i. 6 Q. So, by, by your acknowledgment in these 7 answers to interrogatories before you ever went to 8 Mr. Epstein's house the first time, you had had 10 , and somebody whose last name you 11 can't remember, and -- 12 A. And that's it. 13 Q. And iP file://(C//Documents"%20and%20Settings /Production/Desktop EEE -°620Vol.°%2011.txt[ 12/11/2009 6:15:58 PM] EFTA00023601

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14 A. No. 15 Q. Not a. but up through | 16 A. Yes. 17 Q. And, and the, the relationship you 18 testified about earlier with Hj. Now, during this 19 period of time with between '01 and 20 —'05, tell me about what the facts and circumstances 21 were surrounding him holding a_gun to your head? 22 A. He cheated on me with . and I suppose he 23 felt guilty about it. So, he tried to say I was 24 cheating on him and | wasn't cheating on him. He was 25 cheating on me and felt guilty, and then decided he was going to try to kill me. Q. And you were afraid -- where were you when this gun was held to your head? A. In the middle of a field. Q. Where? A. In West Palm Beach. Q. And you were fearful at that time that he might shoot you? A. Obviously. Q. Well, can -- would you agree that it was a traumatic event to you to have somebody hold a gun to your head? A. Wouldn't it be for you? Q. I would assume so. A. Yeah. Q. As they say you see your life flash before your eyes? A. I guess. Q. Did you ever seek any kind of counseling SBIDDEBHNSLSOCPAAWEWNS 20 or treatment for that traumatic event? 21 A. No. 22 Q. Hadanyone else ever threatened your life 23 other than | as of that time? 24 A. No. 25 Q. Has anyone ever threatened your life since 0260 that event? A. No. Q. Have you ever been affiliated with a gang? A. No. Q. Have any of the individuals that you have dated ever been affiliated with a gang? A. No. Q. Have you been present when Fs claimed that he was affiliated with a gang? A. Nope. Q. Have you told others that you cannot answer the question about whether you're affiliated with a gang because if you did, it would risk personal harm to you? A. No. I said I can't speak for anybody else if ARwWNmWoH SP MADNEWNHE file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023602

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16 __ they're in a gang because I don't know about it. And if 17 they were in a gang, it's none of my business to let 18 — anybody else know about it. I can't tell somebody 19 something about somebody else if I don't know if it's 20 true or not. 21 Q. Have you ever participated in any gang 22. membership ritual? 23 A. No. 24 Q. For approximately how long did the event 25 __ take place that | held a gun to your head? 0261 1 A. Like five minutes and then we kissed and made 2 upand had sex. 3 Q. In the field? 4 A. Yep. 5 Q. Isn't it a fact that you tol 6 that he held a gun on your head for a good hour? 7 A. No. We were arguing for an hour. He didn't 8 hold the gun to my head for an hour. That doctor is on 9 some other shit. 10 Q. And you genuinely feared that you were 11 going to die on that occasion, did you not? 12 A. Well, somebody holds a gun to your head, I am 13 __ pretty sure that anybody would feel that they are going 14 to die. 15 __ Was there another occasion that | | 16 = was physically violent towards you? 17 A. Yes. 18 Q. When was that? 19 A. When he tried to drown me in a canal. 20 Q. When was that? 21 A. I don't recall. 22 Q. Was it before you went to Georgia or 23 after? 24 A. Before. 25 Q. Was it while you were going to 0262 1 Mr. Epstein's? 2 A. Yep. 3 Q. Did you tell Mr. Epstein about it? 4 A. Yes, I did. 5 Q. And when did you tell Mr. Epstein about 6 it? 7 A. On one of the occasions | went to his house. 8 Q. And what did he say? 9 A. I don't know. He talked to me about it. 10 Q. Was he sympathetic toward you? 11 A. A little bit. 12 Q. Did you tell you you ought to get away 13 from this guy? 14 A. Yeah. 15 Q. Did you pay attention to what he said? 16 A. Obviously not, if I had a kid with him some 17 years later. file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023603

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18 Q._ You elected not to sever your relationship 19 with correct? 20 A. What? I wasn't going to leave i. 21 Q. Voluntary decision on your part, right? 22 A. I love | 23 Q. Nobody -- 24 A. Istill love [IL 25 Q. Nobody forced you into it. 0263 1 Big girl, you made your own decision, correct? 2 A. And I had stayed with I yes. 3 Q. And let's talk a little bit more about it. 4 When you say he tried to drown you, exactly what did 5 he do? 6 A. Stuck my head in canal water. 7 Q. And where was this canal? 8 A. On the street where any canal would be. 9 Q. Where, in, in West Palm Beach? A 10 . Yes. 11 Q. And what was the event that led to him 12 _ sticking your head in canal water? 13 A. Ihave absolutely no idea. 14 Q. And were you terrified? 15 A. A little. 16 Q. How long did he hold your head under 17 water? 18 A. I'm -- I wasn't looking at my watch. 19 Q. Were you running out of breath? 20 A. No. He was lifting me back up. I caught my 21 breath. 22 Q. So, he was dunking you in and out of 23 water? 24 A. Yeah. 25 Q. So, you didn't ever have to fight to get 0264 1 up and get your head out of water? 2 A. While I was trying to fight to get my head out 3. of the water, the whole time he was trying to drown me. 4 Q. Were you fighting with him at the time? 5 A. We were in an argument. 6 Q. Was it a traumatic event to you? 7 A. Kind of. 8 Q. Did you seek any type of counseling or -- 9 A. No. 10 Q. -- medical care. 11 THE WITNESS: What time is it? 12 MR. SCAROLA: We're getting close. 13 MR. LUTTIER: 4:32. 14 MR. SCAROLA: Less than a half hour. 15 THE WITNESS: Thank God. 30 more minutes 16 of this crap. These things are really good. 17. BY MR. LUTTIER: 18 Q. When you met with the FBI and the U.S. 19 Attorney -- file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023604

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15 20 21 file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] A. Yes. Q.. -- did you tell them that you had worked for escort services? A. I don't think so. I don't remember. Q. Did you tell them that you had been sexually active prior to the time that you went to Mr. Epstein's? A. I don't remember. Q. Did you tell them that you had been raped before you went to Mr. Epstein's? A. I don't remember. Q. Did you tell them that you had been molested by your grandfather? A. I don't remember. Q. Tell them that you had been molested by your cousin? A. I don't remember. Q.__Did you tell them about your relationship with ? A. I don't remember. Q. Did you tell them about physical violence that had been inflicted upon you by or by i”? A. I don't remember. They more wanted to know about what happened with the child molester. Q. Other than the occasion when slapped you while you were pregnant, was ever physically violent with you? A. Nope. Q. Was there ever_an occasion that the police came to visit you and when you had your child with you? A. Other than the time you mean that my child was born? Q. No. When they came to where you were living and your child was there with you. A. We had gotten in a fight with my brother and his girlfriend. And after the fight was over, I went a got my daughter from the neighbor's house. Q. Did the police come? A. Yes. Q. Was there ever a time that the police came when your child was there and they found drug —_— or drugs on either you or i? A. Drug paraphernalia? Q. Or drugs. A. No. Q. Was there ever a time that Fe was arrested in your presence because he had drugs on his possession. A. [have no idea. EFTA00023605

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22 Q. Were you ever present when | 23. _was arrested? 24 A. Yeah. 25 Q. How many times? A. I don't recall. Q. More than once? A. I don't remember. __And what is your current relationship with i? A. I don't talk to him. He is incarcerated. Q. And why is he incarcerated? A. Because he beat up his pregnant girlfriend. Q. And, and the pregnant girlfriend would be who. A. I don't know her name and I could care less about the bitch. Q. You say what? You could careless about what? A. About the bitch. Q. Okay. Did you know the girl? A. Ihave no idea who she is. Q. You mentioned the name earlier in the pat pet ett pee pet pet te _o CHEIANBwWNHNE SVPHRADUNFHYWN 5 ~~ 20 A. Uh- huh, That was s the missing Jane Doe No. 21 102's, whatever Jeffrey did with her, boyfriend. 22 Q. When did you first meet —, 23 A. A couple of weeks before I saw Mr. Epstein for 24 the first time. That was Jane Doe No. 102's boyfriend. 25 Q. When was the last time you spoke with 0268 In A. A couple of days after Jane Doe No. 102 went missing. Q. Now, earlier you were making reference to injecting drugs and I asked you a question about, I don't remember if | asked you about a needle or a syringe, so I need to go back and clarify. Was it your testimony that you were able to go to a drug store without a prescription and purchase a syringe with a needle on it? A. Yes. Q. And what drug store was that? A. One that sells them. Would that be a drug store here in Palm Beach County? A. It's a drug store in every county. Q. Did you purchase a syringe with a needle here in Palm Beach County -- SZNESTESZH AMS ec wmrAagauvswne A. Yes. 20 Q. -- without a prescription? 21 A. Yes. 22 Q. Do you have any prescription that allows 23 you to, specifically for hypodermic needles? file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023606

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24 A. You don't need one. 25 Q. Are you diabetic or anything like that? 0269 1 A. No. 2 Q. Have you ever used a needle that had been 3. used before? 4 A. Not by anybody else, no. 5 Q. Not my question? 6 A. No, I have never shared a needle, no. 7 Q. Did you ever use -- 8 A. No. Q. You need to listen to my question. A. I heard you. You asked me if I ever used a needle that's been used before and I said no. Q. And what you said was, not one that had been used by somebody else. So, which leaves open the possibility, have you ever used a needle that had been used before, even if it was used on you? A. Even if it was used on me? Q. Yes. A. Well, then the answer would be yes, because | had always, I had always used my own needle. Q. You used a needle on yourself which you had used before? MR. SCAROLA: How about this: Have you used the same needle more than once? MR. LUTTIER: Fine. THE WITNESS: Yes. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0270 1 BY MR. LUTTIER: 2 Q. Okay. And when was it that you did that? 3 A. I don't know. 4 Q. When was the last time you used a needle? 5 A. Back in July when I gave myself a staph 6 infection. 7 Q. And the needle that you used in July, had 8 you used it before? 9 A. Obviously if 1 gave myself staph with it. 10 Q. And when had you used it before July? 11 A. In the same day or two. I don't remember. 12 Q. And for what reason had you used it in the 13. same day or two? 14 A. Because it was the last one I had. 15 Q. But what did you use it for in the same 16 day or two? 17 A. To inject my prescription Roxicodone. 18 Q. So, in July you had injected yourself at 19 lease three times with Roxicodone? 20 A. I told you two. 21 Q. So, the needle that you used in July, when 22 you injected Roxicodone, you had used either same 23 __ time day or the day before to inject yourself with 24 ~— Roxies? 25 A. Uh-huh. file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023607

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0271 Q. Which would mean that would be the second time you used it, right? Yes. Had you used it at any time before that? No. So this needle you only used twice? Yes. Were there other needles that you had used in the past on yourself that you had used on yourself more than once? A. No. It's raining. MR. SCAROLA: Uh-huh. BY MR. LUTTIER: Q. Isn't it, is it true at that Wellington Regional would not discharge you because they deemed you to be an IV drug user? A. That's not true. Q. Did you give them a history that you were an IV drug user? A. I led them, | told them I was an IV drug user. Q. What exactly did you tell them about your IV drug usage? A. That I am an IV drug user. Q. And did you give them anything, any more detail than that? OPOro>r A. I told them that I shot Roxies. Q. Did you tell them that you, that you shot Roxi pursuant to a prescription? A. Pursumed (phonetic). Q. Pursuant to a prescription. A. What does that mean? Q. That the reason that you did it was you had a prescription to do it? A. Yeah. Q. You are sure that you told them it was pursuant to a prescription? A. I told them. They asked me. | told them I had a prescription. I no longer have that prescription, and I no longer go to that doctor. Q. When did you, when did that prescription expire? A. Earlier this year or last year. Q. Being '08? A. Yeah. Q. And when you say the prescription expired, what do you mean? A. Well, it didn't really expire. I mean, I never went and got a new prescription. Q. When you say the prescription expired, do you mean you ran out of the pills that you had BONN NNNNE See eee eee SCNHNNNNN BRB ee eee eee _ See ee ee ee eee eS em on eeeeeeeeeee” w i) purchased? file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023608

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2 A. Yeah. 3 Q. And that happened in '08? 4 A. Yeah. 5 Q. So, in July of '09 when you were shooting 6 — up Roxicodone, where did you get those Roxicodone? 7 A. Oh, no. I still had the prescription but I 8 never went back to the doctor to get a new one. | had 9 the same prescription from '08 in '09. 10 Q. And you got it refilled? 11 A. No. 12 Q. Okay. Let's go back. 13 A. No. I saved the Roxie pills. 14 Q. I thought you told me a minute ago that 15 your prescription had expired and by definition -- 16 A. I meant as -- 17 Q. And by definition that you had used up all 18 of the pills that you gotten initially? 19 A. No. I misunderstood you. That's why I was 20 trying to -- 21 Q. So, you still had pills left? 22 A. Yes. I never went back to the doctor to get a 23 new prescription, so | still had some in the bottle from 24 last year. 25 Q. When did you first use cocaine? 1 A. During the time I met Mr. Epstein. I was 2 going Mr. Epstein's. 3 Q. And you never, prior to that had you used 4 it in any form, powder or crack? 5 A. No. 6 Q. Had you told anyone that you had used 7 cocaine prior to the time that you went to 8 Mr. Epstein's? 9 A. No. 10 Q. When did you first use marijuana? 11 A. Prior to the time I went to Mr. Epstein's. 12. That was the only drug I ever used before I met 13. Mr. Epstein. 14 Q. And you started using marijuana at age 15 what? 16 A. Thirteen. 17 Q. And you used it with what degree of 18 frequency? 19 I don't know, every day. 20 And you were able to purchase that? 21 Yeah. 22 At 13? 23 Yeah. 24 Where did you get the money to buy that 25 marijuana? 0275 1 2 LO POPO> A. Allowance, about all I could -- Q. Did you get the allowance from your 3 mother? file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023609

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4 A. Yeah, or cleaning people's houses or yard 5 work, stupid stuff kids do. 6 Q. And have you ever had a sexually 7 transmitted disease? 8 A. If you want to -- pelvic inflammatory disease, but I got it from a tampon. Q. Other than Roxicodone, have you ever obtained -- well, strike that. Have you ever obtained any type of pill from any source whatsoever other than through a prescription issued by a doctor? A. What do you mean like have | gotten a pill -- Q. Yep. A. -- from anywhere else? Q. Yep. Somebody gave you pills. You bought the pills. Anything like that? A. Yeah. Q. And what kind of pills had you taken that you didn't have a prescription for? A. Percocet. Q. And with what degree of frequency? A. Like I took one one time. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0276 1 Q. At what age did you start taking pills 2 that you didn't have prescriptions for? 3 A. Twenty-two. 4 Q. You said you took Ms. [i to 5 Mr. Epstein's as well, correct? 6 A. Yes. 7 Q. What did you tell Ms. a. before you took 8 her there the first time? 9 A. I told her what was going to happen. 10 Q. What exactly did you tell -- 11 A. But she did more things willingly than I even 12 told her. 13 Q. How do you know that? 14 A. Because I was there and I left the room. 15 Q. What did you see [. do? 16 A. She was offering information and Mr. Epstein 17 asked me to leave the room, and I was leaving the room. 18 Q. Offering information on what? 19 A. On things that her and her mother did. 20 Q. Like what? 21 A. Ihave no idea. | don't remember. | just 22 remember her saying things that her and her mother did 23. and I felt uncomfortable. And her and Mr. Epstein were 24 laughing and he asked me to leave the room and I left 25 the room. 0277 1 Q. Well, if you have a recollection that she 2 said something about -- 3 A. I said I don't have the recollection of 4 exactly what she said. I remember -- 5 Q. What's your best recollection of the file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023610

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subject matter about which she was talking? A. That her and her mom have had, her mom does things and has prices for things. Something of that matter. I don't -- Q. Sexual nature? A. Yeah. Q. What kinds of things? A. I don't remember. . And when you, before you took || to Mr. Epstein the first time, what you did you tell her was going to happen? A. I told her that he might ask her to get nude. And I told her that you were just going to massage him. Q. Did you tell her anything about your experience with the other woman? A. I didn't tell anybody that experience about, with that other woman like] told you before. Q. When you took | | the first time did you go with her? A. Yes. Did you get paid? Yes. How much? $400. Just for taking her. . Well, 300 that I always get and an extra 100 for taking her. Q. On the time that you took [the first time, did you go in with her and Mr. Epstein? A. Yes. Q. Did you take i. a second time. A. Yes, and that's when I was asked to leave the POPO>O Q. Did you take her a third time? A. No. Q. After the second time did she go back herself? A. I don't know. Ask her. Q. Did you tell her that you were getting paid to take her? A. No. Q. Did you share that money that you got for bringing her with her? A. No. Q. After you took her the first time, were you present in the room with Mr. Epstein the entire time when she was there? Other than the what -- When you went the first time -- The first time -- with i -- 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0278 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0279 1 2 3 4 5 6 7 -- yes, | was there the whole time. POPOP file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023611

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_ What occurred at the first meeting of you and . and Mr. Epstein? A. We gave him a massage. She played with one nipple. I played with the other, and he masturbated. Pe And was the state of dress for you and 9 A. We were naked. Q. Totally? A. Uh-huh. Q. And when, and when you left did you and she discuss your encounter? A. No. Q. Did she have any complaints about it when you left? A. No. Q. Did she -- A. All she said was that was easy. Q. Did she ask you if you, if you could take 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0280 1 her back? 2 A. No. 3 Q. Were you present the second time she went? 4 A. Yes. 5 Q. That's the second time is when you 6 — eventually walked out? 7 A. Yes. That's when I walked out. 8 Q. What occurred before you walked out? 9 A. They were joking and laughing. She was 10 telling him about some stuff that her mom and her did 11 sexually for money or some stuff like that. I don't 12 really remember the whole conversation word for word. 13 I need a drink. I have the hiccups really 14 bad. I am getting antsy. 15 MR. SCAROLA: Countdown is to about ten 16 minutes. 17 THE WITNESS: Good. 18 BY MR. LUTTIER: 19 Q. When was the first time you did acid? 20 A. When I was 19. 21 Q. And when you say acid, what specific drug 22 _~were you doing? 23 . Acid. 24 . And in what form was it? 25 . Paper. 0281 1 2 3 4 5 6 7 8 9 And you swallowed it? No, it dissolves on your tongue. And did you do it more than once? I only did it once. And were you with anyone else? Yeah, my friends. Who? I'm not giving you their names. It's irrelevant. POPOPOPO pop file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023612

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10 Q. Okay. You're refusing to answer that 11 question? 12 A. Yes, yes, | am. 13 Q. Who provided the acid? 14 A. That's irrelevant and | refuse to answer that 15 one too. 16 Q. Was this after you got back from Georgia? 17 A. Yeah. 18 Q. So, there came a point in time after you 19 had been drug free -- 20 A. Yes. 21 Q. -- from Georgia that you decided to take 22 sit up again, right? 23 A. Yep. 24 Q. When was the first time you started doing 25 drugs again after you had been drug free until 0282 1 January of '05? 2 A. When I was 18. When I was 18. 3 Q. Do you remember the event? 4 A. Dol remember the event that I did the drug? 5 Q. Yeah. 6 A. Yeah. 7 Q. And was it, was it on your birthday? 8 A. No. 9 Q. All right. Was it in January of '05? 10 A. No. 11 Q. When was it? 12 A. I was 18 but I don't remember the direct 13. month. 14 Q. Okay. 15 A. I know it was not by my birthday. 16 Q. Okay. And can you describe the event? 17 A. Some other people were doing it, so I did it. 18 Q. What drug? 19 A. Crack. 20 Q. And where were you? 21 A. Ina house. 22 Q. First time you had done it? 23 A. Yeah. 24 Q. And who was with you? 25 A. People. Not giving you their names because 0283 1 it's irrelevant. 2 Q. And what house? 3 A. One that somebody lived in. 4 Q. And who supplied the crack? 5 A. I don't know. 6 Q. And after having been drug free from May 7 of '03 to January '05, why did you decide to do 8 crack? 9 A. I was going through a lot of things in my 10 brain. I had lost my boyfriend due to Mr. Epstein. I 11 lost my kid due to his stupid father. So, | was going file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023613

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12 through a lot. Why does anybody take up using drugs 13 or -- 14 Q. What boyfriend are you referring to, 15 saying you lost your boyfriend? 16 . . 17 Q. Now, why do you say you lost | | because 18 — of Mr. Epstein? 19 A. Because he found out finally we got into an 20 argument and I just told him everything that had 21 happened and -- 22 Q. And when did you do that? 23 A. After I had my son. 24 Q. While you were in Georgia? 25 A. No, while we were in Florida. I had my son in 0284 1 Florida. 2 Q. And that's the first time you told [I 3. everything? 4 A. Yeah. 5 Q. And what was his reaction? 6 A. Obviously it wasn't good if 1 am not with him. 7 Q. Well, did he, on that particular occasion 8 leave and say he didn't want anything to do with 9 you? 10 A. No. We argued fora while. We tried to make 11 it work and it just wouldn't work. 12 _ Okay. Other than the fact that you and 13 had broken up and you had lost your kid, and 14 the kid that you're talking about there, is that 15 2 16 A i 17 Q. Anything else that caused you to use crack 18 — in January of '05? 19 A. I was depressed about my whole life. And I 20 felt disgusted by Mr. Epstein. 21 Q. Well, actually the sexual encounters that 22 you had with others were far more extensive than 23 anything -- 24 A. What are you talking about-- 25 Q. -- anything you had ever done with 0285 1 Mr. Epstein, right? 2 A. -- sexual encounters? 3 Q. I mean you, you had done, you had engaged 4 in sex with others, you engaged in sex with both 5 sexes. You had done all sorts of things that 6 Mr. Epstein never did with you, hadn't you? 7 A. So, what does that have to do with 8 Mr. Epstein, my sex life. 9 Q. When you talk about being disgusted -- 10 A. Why don't you get naked in front of an old man 11 and play with his nipples while he masturbates. You do 12 that and then you tell me if you feel good. 13 Q. And as you mentioned earlier, you did that file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023614

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to get money? A. So? It still doesn't make it right. Q. And any other reason why you decided to go back and start using crack cocaine? A. What do you mean go back and start using it? Q. Any other reason why you started to go back to drugs and in particular crack co, start using crack cocaine in January of '05? A. I never heard of it and it was the first time so I tried it. Q. Had you ever seen your mother use crack cocaine? 14 15 16 17 18 19 20 21 22 23 24 25 0286 1 A. No. 2 Q. Had you ever been present when your 3. mothers was arrested for using crack cocaine? 4 A. No. 5 Q. Did you tell anybody your mother used 6 crack cocaine ever? 7 A. My mom used to be an alcoholic, whether she 8 used -- 9 Q. That's not my question. Did you ever tell 10 anybody ever -- 11 A. No. 12 Q. -- that your mother used crack cocaine? 13 A. No. 14 Q. Not a. not anybody else? 15 A. No. 16 Q. Did you ever prostitute yourself for 17 drugs? 18 A. No. 19 Q. Did you do acid on more than one occasion? 20 A. No. 21 Q. When did you first use Ecstasy? 22 A. | think when I was 14. 23 Q. Before you met Mr. Epstein? 24 A. No, during, meeting Mr. Epstein. 25 Q. What? 0287 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 A. After I had met Mr. Epstein. Q. Well, you didn't meet him until you were 15. A. I don't think that's right. I met him when I was 14. I think I saw him for longer than just that year. Q. Well, according to your complaint the first time you meet him was when you were 15? A. I don't -- that, I don't know. MR. SCAROLA: That may be an error. THE WITNESS: Yeah, I think that's an error. BY MR. LUTTIER: Q. When did you -- what were the circumstances surrounding, surrounding you first file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023615

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16 using Ecstasy. 17 A. I was at a party. 18 Q. Where? 19 A. In West Palm Beach. Who was there, I don't 20 know. A bunch of people. 21 Q. And who provided the drug? 22 A. I don't know. 23 Q. Mr. Epstein certainly wasn't there, right? 24 A. No, Mr. Epstein was not there. 25 Q. Okay. Did somebody give you the drug or 0288 did you purchase the drug? . Somebody gave it to me. Had you ever used it before? No. Did you ever use it again? No. Did you enjoy it? No. It was kind of weird. When was the first time you used heroin? . When I was 21. . And what were the circumstances surrounding you using heroin? A. I was just trying it to try to escape my problems. And where were you? In my house. Where your mother lives? No. In mine and house. Did use it with you? Yeah. Who provided the heroin? I don't know. Some dude. __Was there more people there than just you and ? Yep. QOPOPOPOPO?P b SRNR TERDH HS eve wrragauvgswne ty — oS b POPOPOPO vs] eo And how did you take the heroin? I snorted it. And did you use it again? No. No one forced you to do it? Donny did. How did he force you to do it? He told me to do it. So he -- And I didn't want to. And he didn't like grab me and tell me to do it, but I didn't want to and he argued with me about it, so I just did it to stop arguing. Q. When was the first time you used crystal meth? A. I was, I was like 18. Q. And where did you use that? GRRE SES ITS eC wmyaVawn-SRPRL pOPOPOPFOFO > file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023616

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18 A. Ina house. 19 Q. With, who were you living with at the 20 ‘time? 21 A. I was living with myself. Some people were 22 ~~ doing it. I snorted it. 23 Q. People you invited over? 24 A. People | invited over. People other people 25 invited over. 0290 1 Q. Was it given to you or did you buy it? 2 A. It was given to me. 3 Q. And why did you do it? 4 A. Something new to do. 5 Q. Have you ever gone through detox? 6 A. Yes. 7 Q. How many times? 8 A. Twice. 9 Q. When was the first time? 10 A. Earlier this year. 11 Q. That is earlier of '09? 12 A. Yes. 13 Q. Do you remember what month? 14 A. No. 15 Q. And where did you go through detox the 16 first time? 17 A. In my living room. I went -- 18 Q. And you were detoxing yourself? 19 A. Yes. And also I detoxed at CARP. 20 Q. Both, is that the, this is what you have 21 indicated is the first time both in your living room 22 ~~ and at CARP? 23 A. (Witness nods head.) 24 THE COURT REPORTER: Is that a yes? 25 THE WITNESS: Yes. 0291 1 BY MR. LUTTIER: 2 Q. And the second time when did you detox? 3 A. AtCARP. 4 Q. When? 5 A. I don't know. 6 Q. Well, you said the first was early '09. 7 Does that mean the second was sometime after that? 8 A. Yeah. 9 Q. How long -- 10 A. It was all in '09. 11 Q. How long after the first time? 12 A. Like a month or two later. 13 Q. And what were you detoxing yourself from 14 the first time in '09? 15 A. Roxies. 16 Q. Well, that was the drug that you were 17 taking pursuant to your prescription? 18 A. Yes. 19 Q. When did you become addicted to it? file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023617

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20 A. While I was being prescribed it. 21 Q. Did you tell the doctor you had been 22 ~~ become addicted to it? 23 A. Yes, this is why I no longer get a 24 prescription for it. 25 Q. And what were you getting detoxed from the 0292 1 second time at CARP? 2 A. Roxies. 3 Q. So you had to be detoxed twice from 4 Roxies? 5 A. Well, yes, because I detoxed the first time 6 and then | went back to using them again because of my 7 back pain. 8 Q. Did you report to the physician that was 9 giving you the prescription that you had been 10 —_detoxed one time before you went back to using? 11 A. No. Because if you recall in your notes, I 12 saved the prescription to the next year after I had 13 stopped going to that doctor. 14 Q. So, you continued to take the drug even 15 though you had detoxed from the drug? 16 A. Yes. 17 Q. You knew you were addicted to it in the 18 past? 19 A. Yes. 20 Q. Opted, by your own choice, to do it again? 21 A. Yes. So, if that makes me a criminal, then 22 sobeit. How much time do we have left? I want to go 23s get my son. 24 MR. SCAROLA: About two minutes. 25 THE WITNESS: Good. Yeah. I really want 0293 1 to go get my kid; the kid that I signed my 2 rights over to by the way. 3. BY MR. LUTTIER: 4 Q. What was the last grade you completed in 5 school? 6 A. Seventh. 7 Q. And what school were you attending? 8 A. Bear Lakes. Actually, yeah, actually the last 9 year I completed was seventh. I started eighth grade 10 and they kicked me out of school because I was too 11 physically developed. 12 Q. What do you mean by that? 13 A. My boobs were too big and I got sexually 14 harassed by the kids in school. So they called my mom 15 and told her she needed to sign me out. And if you 16 don't believe me, you take it up with Bear Lakes. 17 Q. So, did you enroll in another school? 18 A. No. 19 Q. Why not? 20 A. Because | didn't feel like it at the time. 21 Q. And you were, then you were what they call file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023618

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22 a truant at that point? 23 A. I wasn't truant. At 16 years of age, you 24 ~~ don't have to go to school anymore. It's legal. 25 Q. So, you opted by your own free will to 0294 1 quit going to school at that time? 2 A. Yes. I got pregnant and now have a 3. six-year-old son. 4 Q. You, did you get pregnant before you had 5 dropped out of school? 6 A. No. I| got pregnant after. 7 Q. What did you do during the days after you 8 — dropped out of school? A. Watched TV. Q. Had you had run-in's with the law prior to that? A. When I was 18 years old, I did. Q. Had you had an incident while you were a juvenile where you were arrested for throwing a knife at your brother or something? A. Yeah, he tried to kill my cat, and then he tried to kill me, so I threw a knife at him. Q. Had you and your brothers been removed from your mom's care on an occasion -- A. Never. Q. -- when your mom was arrested? A. Never. Q. Do you remember being placed with some neighbors and the neighbors calling the authorities and saying they wanted someone to come pick you-all up? A. No. We have never been removed out of my mother's care or custody. Q. Do you remember you and your brothers being present on an occasion when your mother was arrested and taken away? A. No, I have never watched my mom be arrested. Q. Do you remember any occasion where she was arrested for possession of drug paraphernalia? A. Yes. And if you look the DNA, the court did DNA, and my mother's DNA was not on that paraphernalia. So that charge was dropped. Q. Were you present when these charges were made? A. I was present but I wasn't in the presence of it happening. Q. What do you mean by you were present but you weren't? A. I wasn't in the presence of it happening. Q. Did you mean -- A. I know about it. Q. Okay. Well, where were you in geographical proximity to this event? file:///C\/Documents%20and%20Settings/ Production Desktop EEE -°620Vol.°6201L txt[ 12/11/2009 6:15:58 PM] EFTA00023619

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24 A. I was at my house. 25 Q. And was your mother at the house? 0296 A. No. I know two minutes is up. MR. SCAROLA: Yeah, do you want to get to. I mean, you set a 5:00 time limit. MR. LUTTIER: Yeah, I do, I've got to go. MR. SCAROLA: And we're there so -- MR. LUTTIER: All right. We'll just break now. THE WITNESS: Break to what? I thought 5:00 was at the end. I've got to go pick up my kid. MR. SCAROLA: Yes. MR. LUTTIER: We'll reconvene you deposition. | will put it on hold for right now until we can get a new day. THE WITNESS: Peace out. ARBDNMoH Se KADANUEWNE 16 THE VIDEOGRAPHER: Off the record at 5:00. 17 (A discussion was held off the record.) 18 THE COURT REPORTER: Do you want to order 19 this? 20 MR. LUTTIER: Yes. 21 THE COURT REPORTER: Do you want a copy? 22 MR. SCAROLA: Yes. 23 (Witness excused.) 24 (Deposition was adjourned.) 25 0297 CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH 1 2 3 4 5 6 L the undersigned authority, certify that 7 personally appeared before me 8 9 10 and was duly sworn on the 4th day of December, 2009. 11 Dated this 11th day of December, 2009. 17 Notary Public - State of Florida My Commission Expires: February 25, 2011 18 My Commission No.: DD 643788 19 20 21 2? file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023620

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24 25 0298 1 CERTIFICATE 2 THE STATE OF FLORIDA 3. COUNTY OF PALM BEACH 4 5 I, a. Registered Professional Reporter, Florida Professional Reporter and Notary 6 Public in and for the State of Florida at large, do hereby certify that I was authorized to and did 7 report said deposition in stenotype; and that the foregoing pages are a true and correct transcription 8 of my shorthand notes of said deposition. 9 I further certify that said deposition was taken at the time and place hereinabove set forth 10 and that the taking of said deposition was commenced and completed as hereinabove set out. 11 I further certify that | am not attorney or 12 counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party 13. connected with the action, nor am | financially interested in the action. 14 The foregoing certification of this transcript 15 does not apply to any reproduction of the same by any means unless under the direct control and/or 16 direction of the certifying reporter. 17 Dated this 11th day of December, 2009. 18 19 20 21 —— 22 23 24 25 0299 1 DATE: _ December 11th, 2009 2 TO: c/o Jack Scarola, Esquire 3 SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. —_— Ll 5 IN RE: Jane Doe No. 2 vs. Epstein 6 CASE NO.: 08-CIV-80119- 7 file://(C//Documents"%20and%20Settings /Production/Desktop EEE -°620Vol.°%2011.txt[ 12/11/2009 6:15:58 PM] Please take notice that on Friday, the 4th of EFTA00023621

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o December, 2009, you gave your deposition in the above-referred matter. At that time, you did not 9 waive signature. It is now necessary that you sign your deposition. 10 As previously agreed to, the transcript will be furnished to you through your counsel. Please read 11 the following instructions carefully: At the end of the transcript you will find an 12 errata sheet. As you read your deposition, any changes or corrections that you wish to make should 13 be noted on the errata sheet, citing page and line number of said change. DO NOT write on the 14 transcript itself. Once you have read the transcript and noted any changes, be sure to sign 15 and date the errata sheet and return these pages to me. 16 If you do not read and sign the deposition within a reasonable time, the original, which has 17 already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish 18 to waive your signature, sign your name in the blank at the bottom of this letter and return it to us. Very truly yours, I do hereby waive my signature. tM NM NM in & We hw Ne i] vs) i] i] CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH I hereby certify that I have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of 2009. POM oH Se eMADAMNEwWNE 15 file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] EFTA00023622

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ee) & wh 25 0301 ARBRE SSLID aa Oo 90 ized — NmNmNhy WN N an file:///C\/Documents%20and%20Settings/Production/ Desktop EEE -°620V 01.2011 vct[ 12/11/2009 6:15:58 PM] ERRATA SHEET IN RE: JANE DOE NO. 2 VS. EPSTEIN CR: DEPOSITION OF: TAKEN: December 4th, 2009 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGE # LINE # CHANGE REASON Please forward the original signed errata sheet to this office so that copies may be distributed to all parties. Under penalty of perjury, I declare that I have read my deposition and that it is true and correct subject to any changes in form or substance entered here. DATE: SIGNATURE OF DEPONENT: EFTA00023623