0166 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON -vs- VOLUME II OF II JEFFREY EPSTEIN, Defendant.
Related cases:
08-80232, 08-08380, 08-80381, 08-80994
08-80993, 08-80811, 08-80893, 09-80469
09-80591, 09-80656, 09-80802, 09-81092
December 4, 2009 10:25 - 5:00 p.m. Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting On behalf of the Defendant, Jeffrey Epstein: ROBERT D. CRITTON, JR., ESQUIRE MARK T. LUTTIER, ESQUIRE BURMAN, CRITTON, LUTTIER & COLEMAN, LLP file:///C|/Documents%20and%20Settings/Production/Desktop/ %20Vol.%20II.txt[12/11/2009 6:15:58 PM] Page 1 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005389 EFTA00157838 ALSO PRESENT: Jeffrey Epstein, via video conference Paralegal, P.A. Stan Sanders, Videographer Visual Evidence, Incorporated WITNESS: DIRECT CROSS REDIRECT RECROSS
CONTINUED
BY MR. LUTTIER 170
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EXHIBIT DESCRIPTIONPAGE
DEFENDANT'S NO. 111
Plaintiff's Notice of Serving Second Amended Answers to Interrogatories
DEFENDANT'S NO. 229
Answers of Interrogatories
DEFENDANT'S NO. 3119
First Amended Complaint
DEFENDANT'S NO. 4 254 Plaintiff's Notice of Serving Third Amended Answers to Defendant's First Interrogatories THE VIDEOGRAPHER: We're going back on the record at 2:42. BY MR. LUTTIER: Q. Mom -- ma'am, at the break we had just file:///C|/Documents%20and%20Settings/Production/Desktop) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005390 EFTA00157839 been discussing your relationship with a You used the phrase in your testimony earlier, you used the phrase "eat out." Could you describe what that phrase means in the context that you were using it?___ MR. : We will stipulate that what it means is cunnilingus. BY MR. LUTTIER: Q. Okay, Do you know what a sex toy is? MR. : Could you explain what relevance or materiality your understanding of that line -true, and that's why it is relevant. Come up many a time.___ MR. LUTTIER: Sure. It was -true, and that's why it is relevant. Come up many a time.___ MR. : -- of questioning might have since there is no allegation that sex toys were ever employed in encounters between and Mr. Enstein? MR. LUTTIER: Well, I dispute that for sure. I just tell you if you read the record carefully, you will find out that is not at all MR. : In connection with allegations from ? MR. LUTTIER: There and in the MR. : Okay. Well, if you represent, if you represent that that's the case, then proceed. BY MR. LUTTIER: BY MR. LUTTIER: Q. Do you know what a sex toy is? A. Yes. Q. Okay. And what is your understanding of that term so that we are understanding each other when I ask you these questions? A. I guess toys used doing sexual things. Q. Okay. And that would include, for example, vibrators? A. Yes. Q. Dildos? A. Yes. Q. Have you used sex toys in the past? A. No. O. Never? A. Never. Q. Did you ever tell anybody you had? A. No. Q. Did you, did you ever use any sex toy with Jeffrey Epstein? A. He tried to use a massage thing and I told him no. file:///C|/Documents%20and%20Settings/Production/Desktop) 3505-044 %20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %2 Page 3 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00005391 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text: "EFTA_00005391". EFTA00157840 Q. What did you mean by "massage thing"? A. Whatever it was in the hell that he had. Q. Well, what -- describe what you are talking about. A. I just told you. Q. Well, massage thing doesn't tell me anything. What are you talking about? A. I don't know what it was called. I don't know what it is. Q. What did it look like? A. It looked -- it was -- I don't know. It Q. But do you know, do you know -- can you describe, physically describe how big it was, what color it was, what it looked like? Can you describe anything about it? A. It was gray and do you want me to draw you a picture because I don't know how to describe what it looked like. Q. How large was it? A. It was like this big (indicating). Q. Okay. A. It was like a neck massager. Q. You know like -- you know what a know like -- you know what Brookstone is, a store? A. Yeah. Q. Have you ever been in there and they have these massages that, like you can reach behind your back and stuff like that. Are we talking about something you know, like that? A. Yeah, but it didn't have a wire, an electrical wire. Q. Okay. A. It was like battery operated. Q. And you say that Mr. Epstein tried to this on you and you said no? A. Yeah. Q. And then he -- A. That was the end of that. Q. -- didn't use it? A. He did not, and he's never A. He did not, and he's never, it never was brought up again. Q. Have you ever desired to use any kind of sex toy? A. No. Q. And, and then not done it for some reason? A. No. file:///C|/Documents%20and%20Settings/Production/Desktop) 0-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %20 3505-044 Page 4 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005392 EFTA00157841 file:///C|/Documents%20and%20Settings/Production/Desktop) %20 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] Page 5 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005393 EFTA00157842 file:///C|/Documents%20and%20Settings/Production/Desktop) 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %20 Page 6 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005394 EFTA00157843 Q. With respect to the incident that you were describing earlier when you were at Mr. Epstein's house and you said there was another woman present who was nude, do you recall that testimony? A. Yeah. B. No. C. Yes. D. Unclear. Q. And was there any discussion here? <. And was there any discussion between you and she before she began to perform oral sex on you? A. And I told you no. Q. No words at all exchanged? A. No. Q. So you were just standing there and this -- A. Yeah. Q. And what, if anything, did you say when this person began to perform oral sex on you? A. I didn't say anything. I just felt really weird and I just stood there. Q. And this is a person you had never seen before? A. Yes. Q. And for how long a period did this perse perform oral sex on you? A. I don't know. Q. And this is while you were standing? A. Yeah. Q. Did, did it, when you say you don't k~ Did, did it, when you say you don't know, are we talking about this went on for 15 or 20 minutes or this went on for three minutes? A. Like 15,20 minutes. Q. Okay. Did you, did you move from where you were standing to some other location while she was doing this? A. I just said no. Q. Did you have an orgasm -performing oral sex on you say anything A. Yeah, I told her to stop. Q. And when did you tell her to stop? A. After like 15 minutes, I told her to stop and Q. -- as a result of her performing? Did you at any time during the 15 or 20 minutes that she was forming oral sex on you say anything to her? that I felt uncomfortable. Q. And what did she do? A. She stopped. And I told Jeffrey I wanted to leave, and he gave me $300 and I left. Q. So, the first time you told this lady to stop, she stopped? A. Yeah. Q. And you told Jeff you wanted to leave and file:///C|/Documents%20and%20Settings/Production/Desktop> 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 7 of 67 %2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005395 EFTA00157844 he didn't try to stop you? A. No. Q. Did you perform any sexual act on this woman? A. No. Q. Did you touch her in any way? A. No. C. And at the time that you were of Q. And at the time that you were standing there and this lady was performing oral sex on you, I assume she was kneeling or something? A. Yes. Q. And where was Mr. Epstein during this? A. Behind her having sex with her. Q. While she was kneeling? A. Yeah. A. Yeah. Q. Did you say anything to Mr. Epstein? A. Besides that I wanted to leave, no. Q. Which you said after 15 minutes, right? A. Yeah. Q. How about during the you say anything at all? A. No. Q. Did you say, you know, I am uncomfortable he set-up: I want to leave? with the set-up; I want to leave? A. I just said no. (Interruption at the door.) file:///C|/Documents%20and%20Settings/Production/Desktop) %2 %20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 8 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005396 EFTA00157845 file:///C|/Documents%20and%20Settings/Production/Desktop/ %2 0-%20Vol.%20fl.txt[12/11/2009 6:15:58 PM] Page 9 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005397 EFTA00157846 file:///C|/Documents%20and%20Settings/Production/Desktop/ %2 %20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] Page 10 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005398 EFTA00157847 file:///C|/Documents%20and%20Settings/Production/Desktop/ %2 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005399 EFTA00157848 file:///C|/Documents%20and%20Settings/Production/Desktop/ %20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005400 EFTA00157849 0190 Q. Do you know other women that have brought claims against Mr. Epstein? A. Yes. Q. What other women do you know that have brought claims against Mr. Epstein? brought claims against A. That's not my information to give you. Q. My question stands. A. I don't feel comfortable telling him. MR. : Well, if you know the names of other women who you know have brought claims. THE WITNESS: I know has. I don't know her last name. And I found out after I filed my suit. BY MR. LUTTIER: Q. Anyone else? A. Not that I know of, that are my friends. Q. Well, my question -- A. Me and haven’t talked since this a A. Me and haven’t talked since this accident just for the record. Q. My question wasn't limited to your friends. My question was did you know other women, do you know other women that have brought claims to, against Mr. Epstein? A. Personally, no. Q. Well, how would you know them if you didn't know them personally? A. I said no. Q. Well, I'm, I'm getting the impress you're, you're being -- A. is the only person that I know that has. Q. And what did you mean when you answered earlier to my question when I asked you if you knew other women that had brought claims against Mr. Epstein, you answered yes? A. And you wrote down did you not? Q. That's the only person that you were referring to? A. Yes. Q. Have you ever heard of a lady by name of A. No. Q. ? A. No. O. Who all Q. Who -- all right. This person, how do you know this person, 2 A. She was a friend of mine. file:///C|/Documents%20and%20Settings/Production/Desktop) %20Vol.%20II.txt[12/11/2009 6:15:58 PM] %20 3505-044 Page 13 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005401 EFTA00157850 Q. And she was a friend of yours commencing when? When did you first meet her? A. I don't remember. Years ago. Q. Before you went to see Mr. Epstein? A. No. She, I met her through my friend Q. Who -- what's its name? A. Q. Do you know any other girls that claim to have gone to Mr. Epstein's house to perform massages on him? A. Do what? B. Do you know any other girls that have gone to Mr. Epstein's house and claimed to have performed massages on him? A. Me, and those are the only girls that I know. Q. And how is it that you met through A. How do you meet your friends through f Q. I have no idea. I mean, were you guys at a party together, did you get on the phone with each other? What did you do? A. We were hanging out. Q. "Hanging out," what's that mean? A. When you hang out. Q. Were you at a function and all three of you 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. I don't remember the time
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 and August of when was it that you took? A. Bro, I 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 or was it in ? A. If I, if you know that I don't know the dates, But was it in or was it in? A. If I, if you know that I don't know the dates, how would you ask me if it was in? 25 A. I 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> %,20Carolyn%20-%20Vol.%20Il.txt[12/11/2009 6:15:58 PM] 3505-044 Page 14 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005402 EFTA00157851 took her to Mr. Epstein's? A. I have known for years. I met I don't know. Ask me the question again, please. don't know. Ask me the question again, please. Q. How long had you known before you took her to Mr. Epstein's? took her to Mr. Epstein s: A. For about a year. Q. And how did you meet? A. She lived down the street from me. Q. Was she a close friend? A. Yes, she was. She was my best. Q. You wouldn't do anything to harm h correct? A. Correct. Q. By the time you took to 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. Q. You had already had this sexual relationship with this woman that you described earlier at Mr. Epstein's? A. Yes. Q. You mentioned earlier that on these Q. You mentioned earlier that on these occasions when you gave Mr. Epstein a massage, he would masturbate I believe you said; is that right? A. Yes. B. No. C. Did that occur, that is Mr. Epstein masturbating, on each and every occasion when you went to Mr. Epstein's from the first occasion to the last occasion? A. Yes. Q. Did you physically see him masturbating? A. Yes. Q. That is there was no towel covering his genitalia or anything like that? A. No. file:///C|/Documents%20and%20Settings/Production/Desktop) %20 0-%20Vol.%20Il.txt[12/11/2009 6:15:58 PM] Page 15 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005403 EFTA00157852 Q. Had, have you ever been photographed in the nude? A. No. At Mr. Epstein's, yes. Q. How about any place other than Mr. Epstein's? A. No. Q. And who photographed you in the nude at Q. And when in this time period that you went to Mr. Epstein's did photograph you in the nude? A. It had to have been in the summer. It was in the summer. Q. And why do you know it was in the summer? A. Because it was summertime. Q. And where did this photographing occur? A. In Mr. Epstein's house. Q. Where in the house? A. Everywhere in the house, outside by the pool, 2. Were you photographed on more than one occasion? A. No. Q. Let me rephrase the question. You mentioned that you were photographed everywhere in the house? A. Yes. Q. Was there -- A. It was in the same day. Q. But more than one picture was taken? A. Yes. Q. All right. And what type of, do you know what type of camera was used? Was it a digital camera or a -- A. A digital camera. Q. All right. file:///C|/Documents%20and%20Settings/Production/Desktop> 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 16 of 67 %2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005404 EFTA00157853 A. It was digital -- it wasn't like a digital camera like, it was like a photography digital camera like a professional camera, a professional digital photography camera. Q. Are you, are you -- A. Not like one you buy at Wal-Mart. Q. When you're describing it as a professional digital camera, are camera that's got a big lens on it? A. Yes. Q. And did this -- A. And there, and there was a regular digital She used two different cameras. Q. And you say this was, in addition to being in the house, was that on a dock? A. Yes. Q. And, and were you completely nude for all of these photographs? of these photographs? A. Yes. Q. So this happened in the daytime? A. Yes. Q. I assume the dock is out somewhere near the Intracoastal? A. Yes. Q. Out in plain view? A. But there was nobody outside. I made sure there was nobody that could see me. Q. Had anyone before that occasion ever 2. Had anyone before that occasion ever photographed you in the complete nude? A. And I already said no. Q. And how many photographs would you estimate were taken? A. I don't know. At least ten. Q. Did you -- how, how is it that it -- well strike that. Did, did ask you if she could take photographs of you in the nude? A. She called me and told me that Mr. Epstein would pay me $500 if there could be nude pictures taken of me. And my words to her were only if you take them; I will not let Mr. Epstein take them of me. Q. All right. So you set the conditions which the photographs were to be taken? under which the photographs 、 -00 A. Yes. Q. And the photographs were taken with your knowledge and consent, correct? A. (Witness nods head.) Q. Did you ever see the photographs? A. Since that day, no. I saw them on the camera. I've never seen the actual photographs. Q. Did you make any comment to about the photographs? file:///C|/Documents%20and%20Settings/Production/Desktop) %20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %2 3505-044 Page 17 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005405 EFTA00157854 A. Yeah, I asked them what would happen with them, and she told me that they were for Mr. Epstein's personal enjoyment. Q. Was Mr. Epstein present when these photographs were taken? A. No, not to my awareness. Q. You -- that is on the occasion that you went to the house when these photographs were taken, you never saw Mr. Epstein? file:///C|/Documents%20and%20Settings/Production/Desktop) 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %20 3505-044 Page 18 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005406 EFTA00157855 file:///C|/Documents%20and%20Settings/Production/Desktop/ 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %2 Page 19 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005407 EFTA00157856 file:///C|/Documents%20and%20Settings/Production/Desktop/ %20 [20-%20Vol.%20II.txt][12/11/2009 6:15:58 PM] 3505-044 Page 20 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005408 EFTA00157857 Q. When did you first meet Mr. ? 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 Mr. , obviously? A. Yes. Q. Had you had sex with Mr. before you went to Mr. Epstein's the first time? A. Yes. Q. And what sexual acts had you engaged in before you went to Mr. Epstein's? with Mr. before you went to Mr. B. A. Intercourse. Q. And did you consider Mr. 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 Mr. ever physically bring you to Mr. Epstein's house? A. Yes. file:///C|/Documents%20and%20Settings/Production/Desktop) 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 21 of 67 %20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00005409 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text. EFTA00157858 bringing you to Mr. Epstein's house? A. No. Q. Did Mr. ever bring anyone else to Q. Did you ever pay Mr. any money for Mr. Epstein's house? A. My brother came with us but he didn't bring any other females, no. A. Oh, and when I went with them. He didn't bring them there by themselves. house other than just yourself: A. You say delivered like we're a bunch of flowers for him. Q. Pick whatever, what word would you prefer, dropped off? A. Yes, that sounds a lot more better than delivered. Q. Fine. Whatever you want. Ever any occasion where Mr. brought any females that he dropped off at Mr. Epstein's other than -- A. Yes, me and , and me and . Q. Did . or . ever pay any money for bringing them? A. No. Q. Did you ever receive any money from Mr. Epstein for bringing .? A. Yes. Q. How much did you get? A. An extra $100. Q. And did you tell . that you were paid $100 by Mr. Epstein to bring her to him? A. Yes. Q. And what was her response? A. I want half. Q. And what did you say to that? A. Okay. Q. So, you gave her 50 of the $100? A. Yeah. Q. And everybody was happy? A. Yeah. Q. Did you bring on more than one occasion? A. Yes. Q. Did you get paid $100 on each occasion -- A. Yes. Q. -- that you brought .? Did you tell file:///C|/Documents%20and%20Settings/Production/Desktop) 0-%20Vol.%20IIl.txt[12/11/2009 6:15:58 PM] 3505-044 Page 22 of 67 %20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005410 EFTA00157859 A. Yes. Q. And did you give her half the 100 or $50 time-every time -- A. Yes. Q. -- that you were paid? On how many did bring and get paid $100? occasions did bring. a. A. Three or four times. Q. How much did . get paid to come to Mr. Epstein's? A. 200, sometimes three. I'm not sure which times. Probably the times when she went there herself. Q. Did . go to Mr. Epstein's on occasions other than when she went with you? A. Yes. Q. But she had never been there until you took her the first time? A. Yes. Q. Were you the individual that first conducted to . that she go to Mr. Epstein's? suggested to . that she go to Mr. Eps A. Obviously if I'm the one who brought her there for the first time. have heard of Mr. Epstein from someplace else. A. No. Q. So the first time she heard the name Jeffrey Epstein was from you? A. Yes. Q. And on the first occasion when you told about Jeffrey Epstein, what did you tell her? A. That we would go there and give him a massage and he might ask you to get topless. 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? A. No. Q. Why not? A. Because I knew she wouldn't be exposed to it. Q. And this was your best friend? A. Yes. Q. And you say you knew what? A. I knew that she wouldn't be exposed to it. Q. What do you mean she wouldn't be exposed to it? A. Because I knew that I felt uncomfortable with the thing with the girl. And I told Jeffrey if he did it to my friends, I 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 file:///C|/Documents%20and%20Settings/Production/Desktop> +%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 23 of 67 %20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00005411 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text: "EFTA_00005411". EFTA00157860 my age, I told him that I would not bring my friend if, if that situation was to occur with her because I didn't like it. I felt uncomfortable, and I would not subject my friend to it. Q. Is that the only thing that had occurred when you were at Mr. Epstein's that you did not tell about? A. Yes. B. No. C. Maybe. D. Never. Q. So, you had told that Mr. Epstein might masturbate while she was there? A. Yes. Q. Did you tell her that he might ejaculate while she was there? Q. Well, did Mr. Epstein ever ejaculate on you? A. No. Q. All right. What did you tell 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. O. But you didn't 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? file:///C|/Documents%20and%20Settings/Production/Desktop) %20Vol.%20II.txt[12/11/2009 6:15:58 PM] %2 3505-044 Page 24 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005412 EFTA00157861 Q. Did there -- there obviously came a time that you got pregnant with Mr. ? A. Obviously. Q. Did you and Mr. leave the State of Florida together at some point in time? A. Yes. Q. And approximately when was that? A. It was in July when I was 16. Q. ? A. Yeah. Q. Is that the same time that you stopped Mr. Epstein's? 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 going to Mr. Epstein's, because you and Mr. were file:///C|/Documents%20and%20Settings/Production/Desktop> %20Vol.%20II.txt[12/11/2009 6:15:58 PM] %2 3505-044 Page 25 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005413 EFTA00157862 0217 file:///C|/Documents%20and%20Settings/Production/Desktop) 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %20 3505-044 Page 26 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005414 EFTA00157863 Q. Was there a point in time that you and Mr. returned to Florida? A. Yes. Q. When was that? A. When I was months pregnant. So, in February. Q. Of'? A. Yeah. file:///C|/Documents%20and%20Settings/Production/Desktop> 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] Page 27 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005415 EFTA00157864 Q. How would you describe your life from July of when you, approximately when you moved to through February of ? 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 I was just felt like I was losing my mind. Q. You say you held secrets from . What secrets did you hold from ? A. What exactly was happening at Mr. Epstein's house. ___ Q. Well, you indicated that took you to file:///C|/Documents%20and%20Settings/Production/Desktop) 0-%20Vol.%20Il.txt[12/11/2009 6:15:58 PM] %20 3505-044 Page 28 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005416 EFTA00157865 Mr. Epstein's on more than one occasion? A. But he didn't know what I was doing. Q. When was the first time took you to Mr. Epstein's? A. I don't know. Q. But we know it wasn't the first or second right? time, right? A. Yeah. Q. Because on those occasions you went with A. He only, he only took me sometimes because Mr. Epstein paid for either his drivers to pick me up and drop me off or a Yellow Cab. incident the first time took you? A. What do you mean the incident? Q. Well, do you recall what you told first time when you had him take you? A. That I was going to clean his house. 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 Q. So, he didn't come in the house? A. No. Q. Did he ever meet Mr. Epstein? A. Yes, he has. Q. Did he ever have any discussions with Mr. Epstein? A. Yeah, about the Shelby Cobra that Mr. Epstein has. My wires -- THE COURT REPORTER: The what? THE WITNESS: Shelby Cobra. My wire is Hold on. Let's go off the record for just a second, please. (A brief recess was held.) BY MR. LUTTIER: Q. Were you present for any discussions file:///C|/Documents%20and%20Settings/Production/Desktop [20-%20Vol.%20II.txt][12/11/2009 6:15:58 PM] % 3505-044 Page 29 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005417 EFTA00157866 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. A. Yes. He told me that you guys tried to hire him. Q. Has ever discussed with you his contact or discussions with Mr. Epstein? Q. Who do you mean by "you guys"? A. Mr. Epstein's law firms. Q. Which firms are you talking about? A. The ones that defend Mr. Epstein. Q. Did you know how many law firms that is? A. I have no idea. All I know is that his law firms tried to hire my father. Q. And when did he tell you that? A. Last year. Q. Meaning calendar year '08? A. Yep. Q. And was incarcerated recently? A. Yes, he was. Q. And when was he incarcerated? A. I believe it was -- was it -- I th last year. Q. That would be '08? A. Yes. Q. When did he get released from incarceration? A. I don't know the date. Q. So, did these lawyers that were trying 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 Mr. met each file:///C|/Documents%20and%20Settings/Production/Desktop) 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %20 3505-044 Page 30 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005418 EFTA00157867 other while they were both incarcerated in the same institution? ___ ___ A. No. Mr. and Mr. Epstein, or Mr. and Mr. Epstein met each other while I was still going to Mr. Epstein's house, but then again met while they were incarcerated together. Mr. Epstein about you? A. No. Q. Did he ever tell you that he discussed you with Mr. Epstein? A. Yes. Q. But he didn't tell you what he said? A. No. Q. Did he ever tell you what he said about what information you knew about Mr. Epstein before 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. I have no idea. But if you would like to let me know, go ahead.___ Q. So, you don't really believe the statement he made to you that, what somebody tried to hire -- A. No, I believe that you guys tried to hire him. Q. How do you decide which statements he makes you believe and which you don't? A. He showed me the address. Q. The address of what? A. Your guys's law firm. Q. Well, you keep saying, you guys. What firm is that? A. The attorneys on Mr. Epstein's side off of Flagler Drive. Q. And did he tell you, did Mr. tell file:///C|/Documents%20and%20Settings/Production/Desktop) 0-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 31 of 67 %2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005419 EFTA00157868 you that he came to meet with those lawyers? A. Yes, he did. Q. Did he tell you whether or not every had been recorded? single word he said had been recorded. A. I have no idea. He didn't tell me anything about it. Q. Did he tell you who-all was present at the meeting? A. No, he didn't. Q. He didn't tell you anything about what he said at that meeting, did he? A. No. Q. And in particular he didn't say what he said about you, did he? A. No. Q. You didn't ask him either, did you? A. I did and he wouldn't tell me. Q. Did you wonder why he wouldn't tel Q. Did you wonder why he wouldn't tell you what he had told Mr. Epstein's lawyers about you? A. No, and I could really care less because he didn't go through half the traumatic things I did with Mr. Epstein. Q. Well, what traumatic things did you go through? A. Well, being that I was an underage girl with an old man masturbating in front of me and bribing me with hundreds and hundreds of dollars -- Q. And how did that, how did that result in any injury to you? A. Well, my mental stability is nothing like it used to be before I met Mr. Epstein. Q. Well, after you worked -- anything else? A. Oh, no, you can go ahead. Q. No, I want to get all your injuries that you claim you have suffered as a result of going to Mr. Epstein's. Anything else? A. You may continue. Q. Is there anything else or have you now told me everything and I will go back and ask you about it? A. You can continue asking me questions. Q. Is there any other way you suffered any damage as a result of going to Mr. Epstein other than your mental stability is not the same, you're scared to go places by yourself, that older guys, you don't like it when older guys stare at you. Q. Trust issues. Anything else? file:///C|/Documents%20and%20Settings/Production/Desktop <%20Vol.%20Il.txt[12/11/2009 6:15:58 PM] % 3505-044 Page 32 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005420 EFTA00157869 A. I don't know right now. Q. Do you know of any way you suffered any repeatedly -- MR. LUTTIER: No speaking -- Other than what you have told me in this deposition. MR. : That's fine. BY MR. LUTTIER: Q. Okay. Is that it? A. Yeah, that's it. Q. Okay. Now, what do you mean when you say you have trust issues. A. Exactly what I said. Q. Well, I don't understand that. Explain that. Explain that to me. What do you mean yo have trust issues? A. I have trust issues with people. Q. Meaning what, you can't trust people? A. No, I can't. Q. Anybody? A. Guys particularly. Q. Males? A. Males, older males. Q. Any males, older males? A. Yes. Q. What age male does it? not to be able trust them? A. Older than myself. Q. So, any man that is older than you, you don't feel like you can trust him? A. No. Q. How has that impacted you in your daily A. Well, I go outside and there is men everywhere. Q. Okay. So, what effect does that have on you? You can't trust the people -- A. Exactly -- Q. -- according to you? A. -- it. I can't trust nobody. Q. So, you're not asking them or do anything for you, are you? A. No, because I don't want them to. Q. Okay. So, help me understand how b impacted you at all that you claim you can't trust men that are older than you? A. Because I can't trust them. What else do you want me to say? Q. Well, I want you to describe how -- A. I can't -- file:///C|/Documents%20and%20Settings/Production/Desktop> 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 33 of 67 %20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00005421 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text. EFTA00157870 Q. How your damage -- what is it that you men to do -want these men to do -- A. Nothing, I don't want them to do anything. Q. -- that -- wait a minute. A. I want them all to leave me alone. Q. What is it that you want these men to that you can't trust them to do? A. There is nothing that I don't want, that I Q. Have you ever asked a man older than you to do something? A. Other than my attorneys, no. Q. All right. A. No offense to you guys. Q. So, there has never been an occasion since you last went to Mr. Epstein where you asked a man that was older than you to do something and you counted on trusting them? A. I counted -- well, my attorneys, but that's Q. Okay. But there has never been a time that you've placed your trust -- A. I refuse -- Q. Wait a minute. A. No, I don't let them, allow them. Q. Now, so, you haven't even attempted to, quote, to use your words, trust a man that's older than you since you last saw Mr. Epstein; is that correct? A. Yes. That's correct. Q. Now, when you say trust, do you mean you don't want to be in their physical presence? A. I don't, no, I don't want to be in their physical presence. file:///C|/Documents%20and%20Settings/Production/Desktop> 20-%20Vol.%20Il.txt[12/11/2009 6:15:58 PM] %2 3505-044 Page 34 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005422 EFTA00157871 file:///C|/Documents%20and%20Settings/Production/Desktop) %20 Page 35 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005423 EFTA00157872 file:///C|/Documents%20and%20Settings/Production/Desktop) 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %2 3505-044 Page 36 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005424 EFTA00157873 file:///C|/Documents%20and%20Settings/Production/Desktop/ 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 37 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005425 EFTA00157874 Q. Was it after Mr. Epstein? A. Yes. I left because I felt degraded. Q. During the time that after you left -- strike that. After you last went to Mr. Epstein which you say is in August of , did you have a casual relationship with ? normal sexual relationship $ _{ \mathrm{F}} $ A. No. Q. Were you having sex with him as frequently as twice a day? A. No. O. Have you ever told anyone that that's what Q. Have you ever told anyone that that's what you did? A. No. Q. Was there ever a time that you had se with twice a day? A. Yes. Q. When was that? A. Before Mr. Epstein. file:///C|/Documents%20and%20Settings/Production/Desktop) 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %2 3505-044 Page 38 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005426 EFTA00157875 0244 Q. And when did it change? A. When I started going to Mr. Epstein's. Q. And what did it change to? A. To once or twice a week. Q. And why did it change? A. Because I felt disgusting. Q. Did there ever come a time after you to Mr. Epstein's that you resumed having sexual relationships with the same degree of frequency with or anyone else? A. With what? Q. With ? A. What do you mean? Q. Did there ever come a time -- A. That I went back to the same -- Q. Right. A. No file:///C|/Documents%20and%20Settings/Production/Desktop> %2 +-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 39 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005427 EFTA00157876 file:///C|/Documents%20and%20Settings/Production/Desktop) %2 0-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] Page 40 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005428 EFTA00157877 file:///C|/Documents%20and%20Settings/Production/Desktop) % 20-%20Vol.%20Il.txt[12/11/2009 6:15:58 PM] 3505-044 Page 41 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005429 EFTA00157878 file:///C|/Documents%20and%20Settings/Production/Desktop/ 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %2 Page 42 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005430 EFTA00157879 file:///C|/Documents%20and%20Settings/Production/Desktop/ %20 3505-044 Page 43 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00005431 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text. EFTA00157880 file:///C|/Documents%20and%20Settings/Production/Desktop/ %20 %20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] Page 44 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005432 EFTA00157881 file:///C|/Documents%20and%20Settings/Production/Desktop/ %2 %20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 45 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005433 EFTA00157882 file:///C|/Documents%20and%20Settings/Production/Desktop) %2 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 46 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005434 EFTA00157883 Q. Was there another occasion that was physically violent towards you? A. Yes. A. Yes. Q. When was that? A. When he tried to drown me in a canal. Q. When was that? A. I don't recall. Q. Was it before you went to or after? A. Before. Q. Was it while you were going to Mr. Epstein's? A. Yep. Q. Did you tell Mr. Epstein about it? A. Yes, I did. Q. And when did you tell Mr. Epstein it? A. On one of the occasions I went to his house. Q. And what did he say? A. I don't know. He talked to me about it. Q. Was he sympathetic toward you? A. A little bit. Q. Did you tell you you ought to get away from this guy? A. Yeah. Q. Did you pay attention to what he said? A. Obviously not, if I had a kid with him some years later. file:///C|/Documents%20and%20Settings/Production/Desktop) 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 47 of 67 %2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005435 EFTA00157884 file:///C|/Documents%20and%20Settings/Production/Desktop) 0-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %20 Page 48 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005436 EFTA00157885 file:///C|/Documents%20and%20Settings/Production/Desktop) %2 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 49 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005437 EFTA00157886 A. Uh-huh. That was the missing Q. You mentioned the name earlier in the deposition, ___? s, whatever Jeffrey did with her, boyfriend. Q. When did you first meet Mr. ___? A. A couple of weeks before I saw Mr. Epstein for the first time. That was his boyfriend. Q. When was the last time you spoke with file:///C|/Documents%20and%20Settings/Production/Desktop) 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %20 3505-044 Page 50 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005438 EFTA00157887 file:///C|/Documents%20and%20Settings/Production/Desktop/ 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %2 Page 51 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005439 EFTA00157888 file:///C|/Documents%20and%20Settings/Production/Desktop/ %20 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 52 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005440 EFTA00157889 Q. When did you first use cocaine? A. During the time I met Mr. Epstein. I was going Mr. Epstein's. Q. And you never, prior to that had you used it in any form, powder or crack? A. No. Q. Had you told anyone that you had used cocaine prior to the time that you went to Mr. Epstein's? A. No. Q. When did you first use marijuana? A. Prior to the time I went to Mr. Epstein's. A. Prior to the time I went to Mr. Epstein's. That was the only drug I ever used before I met Mr. Epstein. file:///C|/Documents%20and%20Settings/Production/Desktop) %20 0-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 53 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005441 EFTA00157890 Q. You said you took Ms. to Mr. Epstein's as well, correct? A. Yes. Q. What did you tell Ms. before you took her there the first time? A. I told her what was going to happen. Q. What exactly did you tell -- A. But she did more things willingly than I even told her. Q. How do you know that? A. Because I was there and I left the room. Q. What did you see . do? A. She was offering
asked me to leave the room, and I was leaving the room.
Q. Offering information on what?
A. On things that her and her mother did.
Q. Like what?
A. I have no idea. I don't remember. I just
I have no idea. I don't remember. I just remember her saying things that her and her mother did and I felt uncomfortable. And her and Mr. Epstein were laughing and he asked me to leave the room and I left the room. Q. Well, if you have a recollection that she said something about -- A. I said I don't have the recollection of exactly what she said. I remember -- Q. What's your best recollection of the file:///C|/Documents%20and%20Settings/Production/Desktop> %20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 54 of 67 %20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005442 EFTA00157891 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. Q. And when you, before in 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 I told you before. Q. When you took .the first time did you go with her? A. Yes. Q. Did you get paid? A. Yes. Q. How much? A. $400. Q. Just for taking her. A. Well, 300 that I always get and an extra 100 for taking her. O. On the time that you took the first time, did you go in with her and Mr. Epstein? A. Yes. Q. Did you take a second time. A. Yes, and that's when I was asked to leave the room. 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 1 you present in the room with Mr. Epstein the entire time when she was there? 2 A. Other than the what -- 3 Q. When you went the first time -- 4 A. The first time -- 5 Q. With . -- 6 A. -- yes, I was there the whole time. file:///C|/Documents%20and%20Settings/Production/Desktop> 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] %20 3505-044 Page 55 of 67 EFTA_00005443 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA00157892 Q. 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. Q. And was the state of dress for you and ? A. We were naked. Q. Totally? A. Uh-huh. Q. And wk 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 her back? A. No. Q. Were you present the second time she went? A. Yes. Q. That's the second time is when you eventually walked out? A. Yes. That's when I walked out. Q. What occurred before you walked out? A. They were joking and laughing. She was telling him about some stuff that her mom and her did sexually for money or some stuff like that. I don't really remember the whole conversation word for word. file:///C|/Documents%20and%20Settings/Production/Desktop) %2 -%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 56 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005444 EFTA00157893 So, I was going file:///C|/Documents%20and%20Settings/Production/Desktop) 0-%20Vol.%20Il.txt[12/11/2009 6:15:58 PM] 3505-044 | %2 | Page 57 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005445 EFTA00157894 through a lot. Why does anybody take up using drugs or -- Q. What boyfriend are you referring to, Q. Now, why do you say you lost because of Mr. Epstein? A. Because he found out finally we got into an argument and I just told him everything that had happened and -- Q. And when did you do that? A. After I had my Q. While you were in A. No, while we were in Florida. I ha Florida. Q. And that's the first time you told everything? A. Yeah. Q. And what was his reaction? A. Obviously it wasn't good if I am not with him. Q. Well, did he, on that particular occasion leave and say he didn't want anything to do with you? A. No. We argued for a while. We tried to make it work and it just wouldn't work. Q. Anything else that caused you to use crack in January of [ ]? A. I was depressed about my whole life. And I felt disgusted by Mr. Epstein. Q. When you talk about being disgusted -- A. Why don't you get naked in front of an old man and play with his nipples while he masturbates. You do that and then you tell me if you feel good. Q. And as you mentioned earlier, you did that file:///C|/Documents%20and%20Settings/Production/Desktop> 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 58 of 67 %2 EFTA_00005446 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA00157895 Q. When did you first use Ecstasy? A. I think when I was 14. Q. Before you met Mr. Epstein? A. No, during, meeting Mr. Epstein. Q. What? 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. : 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) 20-%20Vol.%20Il.txt[12/11/2009 6:15:58 PM] 3505-044 Page 59 of 67 %2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005447 EFTA00157896 using Ecstasy. A. I was at a party. Q. Where? A. In West Palm Beach. Who was there, I don't
20know.A bunch of people.
21Q. And who provided the drug?
22A.I don't know.
23Q. Mr. Epstein certainly wasn't there, right?
24A.No, Mr. Epstein was not there.
25Q.Okay. Did somebody give you the drug or
did you purchase the drug? A. Somebody gave it to me. Q. Had you ever used it before? A. No. file:///C|/Documents%20and%20Settings/Production/Desktop> %2 %20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 60 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005448 EFTA00157897 file:///C|/Documents%20and%20Settings/Production/Desktop) 0-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 61 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005449 EFTA00157898 file:///C|/Documents%20and%20Settings/Production/Desktop/ %2 3505-044 Page 62 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005450 EFTA00157899 file:///C|/Documents%20and%20Settings/Production/Desktop/ %2 0-%20Vol.%20Il.txt[12/11/2009 6:15:58 PM] 3505-044 Page 63 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00005451 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text. EFTA00157900 # CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that personally appeared before me and was duly sworn on the 4th day of December, 2009. Dated this 11th day of December, 2009. Cynthia Hopkins, RPR, FPR Notary Public - State of Florida My Commission Expires: February 25, 2011 My Commission No.: DD 643788 file:///C|/Documents%20and%20Settings/Production/Desktop) %2 %20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 64 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005452 EFTA00157901
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## CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH I, Cynthia Hopkins, Registered Professional Reporter, Florida Professional Reporter and Notary Public in and for the State of Florida at large, do hereby certify that I was authorized to and did report said deposition in stenotype; and that the foregoing pages are a true and correct transcription of my shorthand notes of said deposition. I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out. I further certify that I am not attorney or counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter. Dated this 11th day of December, 2009. Cynthia Hopkins, RPR, FPR Please take notice that on Friday, the 4th of file:///C|/Documents%20and%20Settings/Production/Desktop) %20 -%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 65 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005453 EFTA00157902 December, 2009, you gave your deposition in the above-referred matter. At that time, you did not waive signature. It is now necessary that you sign your deposition. As previously agreed to, the transcript will be furnished to you through your counsel. Please read the following instructions carefully: At the end of the transcript you will find an errata sheet. As you read your deposition, any changes or corrections that you wish to make should be noted on the errata sheet, citing page and line number of said change. DO NOT write on the transcript itself. Once you have read the transcript and noted any changes, be sure to sign and date the errata sheet and return these pages to me. If you do not read and sign the deposition within a reasonable time, the original, which has already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your signature, sign your name in the blank at the bottom of this letter and return it to us. Very truly yours, Cynthia Hopkins, RPR, FPR 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. file:///C|/Documents%20and%20Settings/Production/Desktop) %2 20-%20Vol.%20II.txt[12/11/2009 6:15:58 PM] 3505-044 Page 66 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005454 EFTA00157903 22 23 24 25 0301 # ERRATA SHEET IN RE: [ ] [ ] [ ] VS. EPSTEIN CR: Cynthia Hopkins DEPOSITION OF: [ ] M. TAKEN: December 4th, 2009 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES 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:___ file:///C|/Documents%20and%20Settings/Production/Desktop) % 3505-044 20-%20Vol.%20Il.txt[12/11/2009 6:15:58 PM] Page 67 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00005455 EFTA00157904