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Testimony

Deposition of an alleged victim in a civil suit against Jeffrey Epstein

Videotaped deposition in which an alleged victim testifies under oath about her claims against Jeffrey Epstein and contacts with state and federal investigatorsMachine-written summary

1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 08-CIV-80119-MARRA/JOHNSON

J 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

VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF

23 Reported By:

Cynthia Hopkins, RPR, FPR

24 Notary Public, State of Florida

Prose Court Reporting

25

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2

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INDEX VOLUME I

WITNESS: DIRECT CROSS REDIRECT RECROSS

BY MR. LUTTIER 5

EXHIBITS

EXHIBIT DESCRIPTION PAGE

DEFENDANT’S NO. 1 11 Plaintiff’s Notice of Serving Second Amended Answers to Interrogatories

DEFENDANT’S NO. 2 29 Answers of Interrogatories

DEFENDANT’S NO. 3 119 First Amended Complaint

DEFENDANT’S NO. 4 254 Plaintiff’s Notice of Serving Third Amended Answers to Defendant’s First Interrogatories

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PROCEEDINGS

Deposition taken before Cynthia Hopkins, Registered Professional Reporter and Florida Professional Reporter, and Notary Public in and for the State of Florida at Large, in the above cause.

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MR. LUTTIER: My name is Mark Luttier, and

I am here on behalf of the Defendant,

Mr. Epstein.

Thereupon,

Having been first duly sworn or affirmed, was examined and testified as follows:

THE WITNESS: Absolutely.

THE COURT REPORTER: Thank you.

DIRECT EXAMINATION

BY MR. LUTTIER:

Q. Would you please tell me your full name, ma’am.

Q. Ms. , have — my name is Mark

Luttier. I represent Mr. Epstein in this pending lawsuit that you have brought. Have you ever had an opportunity to be deposed before?

A. What does that mean?

Q. That’s the process that we’re about to engage in here is known as a deposition.

22 A. No.

Q. All right. I just want to explain sort of the rules to you so that you understand it. First of all, if you want to take a break at any time, if

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A. Yes.

1

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  1. Q. And what is your understanding of the

  2. significance of being under oath?

A. Not to lie to you.

Q. Yeah, you have to tell the truth.

A. And God is watching me.

Q. In other words you understand you have to tell the truth about everything?

A. Yes. That would fall under not lying.

Q. And you understand there are civil and criminal consequences that could be attributed to making statements that are not true while under oath?

Q. Okay. In this particular lawsuit, you’ve had an opportunity to discuss your claims with various other people, have you not?

A. Yes.

A. One more time.

Q. You’ve had an opportunity before you came here today to discuss your various claims that you’ve made about Mr. Epstein with other people?

A. As in my attorneys?

B. As in anybody.

C. I’ve only talked about it with my attorneys.

D. Okay. Did you have a conversation at any

1 time prior to today with anyone from the state

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2 attorney’s office here in the Palm Beach County

3 State Attorney’s Office?

4 A. Yes.

5 Q. Okay.

6 A. And the FBI.

7 Q. All right. Let’s first talk about the

8 state attorney’s office. Do you know with whom you

9 spoke?

10 A. I don’t remember the name.

12 A. I have spoke to a man and a woman.

11 Q. Do you know if it was a man or a woman?

13 Q. How many times did you speak with someone

14 at the State Attorney’s Office?

15 A. Once.

16 Q. And where did you speak with them?

17 A. In a building somewhere off of of

18 here. I don’t remember the name of the building.

19 Q. Do you know if it was at the State

20 Attorney’s Office —

21 A. Yeah.

22 Q. — across from the courthouse?

23 A. The United States Attorney’s Office.

24 Q. Okay. Let me back up a little bit. Now

25 you mentioned the United States Attorneys?

1 A. That’s —

2 Q. That would be someone associated with

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what’s known as the federal system. When I was asking you about the state attorney, that would be someone associated with the State of Florida.

A. I was at a building with United, it was the United State’s State Attorney’s Office.

Q. All right. And would that have been a building you say here on somewhere?

Q. Do you remember the name of either the man or the woman —

A. I do not.

Q. — with whom you met. Did you have a separate meeting with someone from the Florida State Attorney’s Office?

A. I don’t remember.

Q. And the State Attorney’s Office is located across the street from the courthouse downtown in West Palm Beach.

A. I don’t remember.

Q. When you, when you — and by the way, when you say you don’t remember, is it your intent to indicate to me that you have no recollection whether

  1. it happened or didn’t happen?

  2. A. It’s, I don’t remember if that was the

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building I was in.

Q. Okay. Do you recall having met with someone from the State of Florida, a prosecutor from the State of Florida as well as someone from the United States Attorney’s Office?

A. Well, there was a lot of people there.

Q. This, now you’re referring to the initial meeting that you talked to me about?

A. When I had the meeting, I believe, I’m not sure if it was — I know it was the United States State Attorney’s Office. It could have been State of Florida. There was a victim’s advocate there and the FBI was there.

Q. Okay. So, we have a man and a woman that were associated with the, the State Attorney’s Office, whether it was the U.S. Attorney or State Attorney, a victim’s advocate and how many members from the FBI?

A. I was with one lady from the FBI.

Q. Do you, do you know her name?

A. I do not remember.

Q. Do you remember even the first name, first or last name?

  1. A. I don’t remember.

2 Q. Do you remember what race she was?

3 A. She was white. The Victim’s Advocate lady,

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she was black. I remember that.

Q. Do you remember her name?

A. No.

MR. LUTTIER: Let me hand you what we’ll mark as Exhibit No. 1 which purports to be a document entitled Plaintiff’s Notice of Serving Second Amended Answers to Interrogatories. Here’s your copy.

THE WITNESS: Do I get a copy?

MR. LUTTIER: Yeah, I am going to get to you. I’m just going to put a stamp on one.

BY MR. LUTTIER:

Q. Now, let me hand you Exhibit 1. And the first question I have for you is if you will turn to the last page; is that your signature?

A. Yes.

Q. All right. Now, if you will, on the last page you have represented that these answers are true and correct. I want to give you an opportunity to flip through these answers and look at them.

A. Of where, the whole packet?

Q. Right. And tell me if there is anything

  1. in these answers that is not correct or is

  2. incomplete?

  3. MR. : I am going to object to the

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question as compound, vague, and overly broad.

BY MR. LUTTIER:

Q. Let me give you a chance to look through them. And my first question will be is there anything that is inaccurate in these answers.

R. Same objection. You can —

unless I instruct you not to answer,

the objections that I am making are objections that are being made so that the court can look at them at a later time and decide whether the question was appropriate.

You should answer the question regardless of whether I raise an objection unless I tell you not to. Okay?

THE WITNESS: I’m so confused.

MR. : That’s all right. Right now you have been asked to look at these and to determine whether there is any inaccuracy in the answers that you swore to previously.

THE WITNESS: This is what me and you did, right? Then it all should be correct unless somebody else messed with it. Excuse me.

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that you are referring to Page 15?

was paid $100. I was given the amount of $300.

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A. I got paid $300 for me going, but was not given the extra hundred for bringing her.

Q. So, you got 300 for going. You went on this occasion, but you were not given any extra money?

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A. The extra money. yes.

Q. And you brought Ms.

occasion?

A. Yeah.

Q. Okay. And then you’re indicating that

what you did was even though you only got paid 300,

you took 100 of your 300 and gave it to

?

A. Yes.

Q. Okay. Any other corrections to any of your answers to interrogatories?

A. So far that’s — I don’t see any.

Q. Okay.

19 A. That was the only thing.

Q. Let’s then turn to, I’m going to reference

your answer to Interrogatory No. 5 which starts -identify anybody that you believe has information

A. What page -identify anybody that you believe has information

Q. On Page 3, which asks you to give,

25 pertaining to this suit. And I want to —

16

  1. A. Pertaining to what?

2 Q. To this, to this claim.

3 A. Okay.

  1. Q. I will refer to it sometimes as your claim

5 or to this lawsuit that you brought against

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A. Okay.

Q. And by the way, I am sure Mr. explained this to you, and you are doing a fine job any time I ask you a question and you’re not sure what I’m asking or you need me to explain it, just ask me to, and I will be happy to explain it to you.

A. Yeah.

Q. Okay? Now, let me draw your attention over to Page No. 10?

A. Well, what was the point of going to Page No. 3?

Q. Well, Page No. 3 is the list, starts with a list of names of the people that you gave that you said had information concerning this claim. Okay. And I want to now call your attention to Witness Number 31 which is found on Page 10.

A. I don’t understand what you just said.

Q. If you would turn to Page 10, you will see a Number 31. See that Number 31.

A. Uh-huh.

Q. And it indicates that he is an attorney with the Department of Justice which would be the U.S. Attorney. Is, does that name refresh your recollection as to whether or not he was the individual with whom you met from the U.S.

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So, to suggest to that this information originated with her would be incorrect.

that she said she believed had knowledge about the case, and the address she gave reflects he is from the U.S. Department of Justice.

BY MR. LUTTIER:

Q. And my question is, seeing that name, does that refresh your recollection as to whether or not

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8 A. I don’t remember.

7 he was the individual —

9 Q. — with whom you met when you say you met

10 with the —

11 A. There was more —

12 Q. — U.S. Attorney?

13 A. — than four people in the room, so their

15 Q. Okay. So it doesn’t refresh your memory

16 looking at this?

17 A. No.

14 names, I can’t remember.

18 Q. All right. Look at the next witness which

19 is 32. Do you see the name , M.S.W.?

20 A. What does M.S.W. stand for?

21 Q. I imagine it’s Master of Social Work.

22 Does that refresh your recollection as to whether or

23 not that was the victim advocate with whom you met?

24 A. Yes, I remember

  1. Q. Okay. And that would be the person that

1 you previously identified as the victim advocate

2 that was at this meeting?

3 A. Uh-huh.

4 Q. That’s a yes?

5 A. I believe so.

6 Q. If you will turn to the next page, Page

7 11, Number 34, there is a name

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A. Yeah.

Q. Does that name — do you recognize that

name —

A. Yes.

Q. — as being the person with whom you met, and that would have been, was that the woman from the U.S. Attorney’s Office with whom you met on this occasion that you described?

A. I just remember the last name

Q. As being the women that was present for this meeting that you had with the U.S. Attorney?

A. Yes.

Q. Now, in reviewing these names, do you, do you recognize any name in the list that you have given me in response to this interrogatory that is indicative of the man from the U.S. Attorney’s Office?

A. Were does indicative mean?

Q. That is the person, the man with whom you met at the U.S. Attorney’s Office.

A. Okay. Ask me the question one more time now that I know what the meaning of that word is.

Q. You, you said that when you met with the U.S. Attorney’s Office there was one man and one woman from the U.S. Attorney’s Office. You have now

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said that Ms.

was the woman.

A. I remember —

Q. I call your attention to this list of names you gave me. Can you point out to me which individual, if he’s listed, was the man with whom you met at that meeting?

A. And I told you I don’t remember the name.

Q. All right. And, and is it, do you know that the person —

A. It could be possible —

Q. — that’s listed —

A. That’s his name, yes. I don’t know. I said I don’t know, so…

Q. Do you, in looking through this list, can you identify the person that you described as the woman from the FBI?

A. And now I lost my page. I’m upset. I’m sorry. What page were we on?

1 Q. Well, we happen —

  1. A. I just —

  2. Q. The last page we were on is Page 11, but

  3. feel free to look at all of the names?

  4. A. Okay. I do not see the lady-from-the-FBI’s

  5. name.

8 And by that I mean even if it’s not on the answers

  1. Q. Do you have that information anywhere?

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to interrogatories, do you someplace have the

information as to the name of the woman from the FBI

that was present at the meeting?

A. No, but if somebody did and showed me the name, I would definitely remember because it was a weird name.

Q. All right. So, I want you to take your

A. That’s what I am doing -that starts on Page 3 and carefully look at them and

tell me if you recognize -time to look at those lists, that list of witnesses

Q. — the name.

21 A. I don’t see that lady’s name.

Q. Do you know if you have that person’s name anywhere?

A. No. You asked me that already.

Q. Other than a man and a woman from the U.S.

Attorney’s Office, one of whom you identified as

Ms. , Ms. , the victim advocate, and the lady from the FBI, was anyone else present for this meeting that you had with the U.S. Attorney?

A. Yes, and I don’t know their name.

Q. Who else, who else, who were they that were present, even if you don’t know their names?

A. I don’t know. They were —

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9 Q. I just, from what agency were they

10 associated?

11 A. I don’t remember.

12 Q. Were there, was there any lawyer there?

13 A. I don’t remember.

14 Q. Was there any lawyer there on your behalf?

15 A. No.

16 Q. Did you take anyone to the meeting with

17 you?

18 A. No.

19 Q. How many other people were there? You’ve

20 identified five thus far, plus yourself.

21 A. I believe it was five then.

23 A. I was just about to count them.

22 Q. So, you now —

24 Q. So, you now have identified for me

25everyone that was there?
23
  1. A. I believe so.

2 Q. What was discussed at this meeting?

3 A. The incident between me and Jeffrey Epstein.

  1. Q. Which incident is that?

5 A. The incident why we’re here now.

6 Q. Are you referencing a single isolated

7 incident?

8 A. I am talking about the whole situation of all

9 the times I’ve been there, what happened.

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Q. Do you know approximately when this meeting occurred? We can start with the year.

A. I don’t remember the year. It’s, it was a couple of years ago. Actually it was about, I think it was a couple years ago, as a couple not as in two. It was longer than that.

Q. Is there anything that will refresh your memory as to when it happened?

A. That’s what I am trying to think about.

Q. Did you make a note of it, for example?

20 A. My mom would know.

21 Q. Why would she know?

  1. A. Because I called her and told her the FBI was

  2. at our house.

24 Q. Was where, at her house?

25 A. Was at the house, yeah. The FBI came to the 24

1 house.

  1. Q. Was this before this meeting that you had

  2. with the U.S. Attorney?

  3. A. It was before that meeting, yes.

  4. Q. Okay. So, you’ve had to two meetings with

  5. the FBI?

  6. A. I had the meeting when they first came and

  7. knocked on the door and asked me if I know who

  8. Mr. Epstein was.

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Q. Okay.

A. And then they were at the meeting with the

12 United States people, attorney people. But my mom would

3 remember.

Q. Okay. Let’s go back then. Let’s talk

about what we’ll describe as the first meeting with

the FBI. You say they came to your house?

A. Yes.

Q. Where was this house located?

| 20 | Florida |

| :--- | :--- |

21 Q. I take it you were living there at the

22 time?

23 A. Yeah.

24 Q. Was anyone else living with you at that

25time at that residence?
25

1 A. My brothers, my mother.

2 Q. All three of your brothers?

3 A. And I believe it was my daughter’s father was

4 living with me then too.

5 Q. That would be Mr. ?

6 A. Yes.

7 Q. Do you recall when that meeting took

8 place?

9 A. I just said no. I said my mom would

10 approximately know approximately when it happened.

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  1. Q. How many members of the FBI came to meet

12 with you on that occasion?

A. Two, a man and a woman.

Q. Were -to ask me that. That’s why I said no.

A. And I do not recall the names.

Q. Looking at this list of witnesses that you gave me in these answers to interrogatories which have been marked as Exhibit 1, do you recognize the name of either of these -to ask me that. That’s why I said no.

Q. Well, actually I haven’t asked you the question yet. So, do you recognize the name of any of these individuals as being the FBI agents that came to your house at [blank]?

A. And I said no. I already knew you were going

Q. And was it two men or a man and a women or two woman?

A. A man and a woman.

MR. : You already asked that question, and you were told it was a man and a woman.

BY MR. LUTTIER:

Q. And did they meet with you on that occasion?

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BY MR. LUTTIER:

Q. Did you meet inside the house or outside the house?

A. Outside the house.

Q. Was there anyone else present besides you and these two persons from the FBI?

A. No.

Q. Did anyone make any notes during this meeting, the first meeting—

A. The FBI people did.

Q. Do you know whether or not you, anything you said was recorded? And by that I mean like with a tape recording.

A. Not at that present time, no. It was recorded when we went to the United States place.

Q. And was it recorded by via tape recorder, was there a court reporter there like we have here?

A. No, it was on tape recorder.

Q. Have you ever been provided with a transcript, that is a paper writing that reflects

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12 what was said at the meeting that was recorded?

13 A. No.

14 Q. Have you ever asked for it?

15 A. No. I didn’t know I could have.

16 Q. Were you under oath at the meeting that

17 was recorded?

18 A. I don’t believe so.

23 A. Yeah.

  1. Q. Whether you under oath or not, did you

  2. tell them the truth at that meeting?

19 Q. Did you —

20 A. I, I probably was.

24 Q. Did you tell the FBI the truth when they

25 came to your house?

28

A. Yes. I have no absolutely no reason to lie about this situation.

Q. Other than the meeting when the FBI came to your house and when you met with the U.S.

Attorney that you have described thus far, have you had any other contact with the FBI?

A. No.

Q. Have you had any other contact with anyone from the U.S. Attorney’s Office?

10 A. No.

11 MR. LUTTIER: Let’s mark this as

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Exhibit 2.

THE WITNESS: Is this mine to keep?

MR. LUTTIER: Yeah.

(Defendant’s Exhibit No. 2 was marked for identification.)

THE WITNESS: Sorry about that. Like that, right? Okay. I’m sorry now.

BY MR. LUTTIER:

Q. Okay. Now I have handed you what has been marked as Exhibit No. 2 which is a document that is entitled Notice of Serving Answers to

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Interrogatories.

A. Okay.

Q. And this is similar to Exhibit 1 which was supplemental interrogatories; that is they are written questions that were submitted to you. If you turn to Page 19, is that your signature?

A. Yes.

Q. Now, I notice that your signature here does not purport to be a representation under oath that the answers are true and correct?

A. That what?

Q. I notice that your signature on Page 19 does no purport to represent that your answers are

BY MR. LUTTIER:

Q. If you will turn to Page 18, please. You will notice in answer to Interrogatory 23, you state that you were interviewed by the FBI and a State Attorney. In that answer, are you referring to two separate interviews?

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Q. Correct.

A. That would be Number 22.

A. Not 23.

THE WITNESS: Now, okay. So, now what was

MR. LUTTIER: Okay. I’m sorry.

Interrogatory 22, that you were interviewed by the

the question?

20 BY MR. LUTTIER:

A. Yeah.

FBI and a State Attorney?

Q. You answered in answer to

  1. Q. Are you referring now to two separate

meetings or —

A. One.

Q. All right. And is the reference in this answer to the meeting that you’ve described thus far?

A. Okay. Listen. The FBI came to my house one time. And then at this meeting the FBI and the State Attorneys were there.

Q. Okay.

A. So, there was two meetings with the FBI: One when they came to my house and then one when the State Attorney was there and one in that building somewhere around here.

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14 Q. All right.

15 A. Does that help you?

16 Q. Yep.

17 A. Okay. Good.

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14

BY MR. LUTTIER:

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21THE VIDEOGRAPHER: Going off the record at
2211:09.

23 (A brief recess was held.)

THE VIDEOGRAPHER: We’re back on the

record at 11:18.

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BY MR. LUTTIER:

Q. You — one of your claims in this case is that as a result of your meetings with Mr. Epstein, you have incurred medical expenses. Are you aware that that’s one of your claims?

A. Medical expenses?

Q. Yes.

A. Because I have Baker Acted myself due to instability from the trauma of Mr. Epstein.

Q. And where did you Baker Act yourself?

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Q. And did you tell the individuals at

the reason you were Baker Acting

yourself was because of -would not know anything about Mr. Epstein, correct?

A. It was depression. I never spoke about

Mr. Epstein with anybody.

Q. So, the physicians that treated you at

A. No. I told them I was depressed.

Q. And why were you depressed? Why did you tell them you were depressed when you went to

Q. But didn’t tell them that it had anything to do with Mr. Epstein, correct?

A. Correct.

A. Because I was.

Q. As a matter of fact before you filed this lawsuit, you never told anyone that you were ever depressed because of anything that Mr. Epstein did

A. My mother.

Q. When did you first tell her that you were depressed because of Mr. Epstein?

1 A. Probably after I have seen Mr.,after I

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stopped seeing Mr. Epstein.

Q. When would, when is it that you would have told her? Because you, according to your complaint you stopped seeing Mr. Epstein in August of and it’s now December of ‘09.

A. Well, throughout the years.

Q. You can’t remember a specific time that you first told her?

A. I don’t write down dates and times of — I talk to my mom. When you talk to your mom, do you write down dates?

BY MR. LUTTIER:

Q. You were requested to produce your medical bills that you claim you incurred as a result of your interactions with Mr. Epstein and none have been produced. Do you have any?

A. I’ve done what?

Q. You were asked to give us copies of any medical bills you claim you incurred because of Mr. Epstein and we haven’t received anything. Do you have any such bills?

  1. A. I don’t know what — I’m confused.

  2. Q. Did you go, when you went to

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A. I don’t have the bills presently in my purse

5 or anything.

  1. Q. Did you pay any money—

7 A. Did I what?

  1. Q. Did you pay for any services rendered to

10 A. I didn’t pay them, no.

20 there because of the, the abuse by Mr. Epstein. I just

22 (Mr. Critton entered the deposition room.)

23 THE WITNESS: Who is this man walking in?

24 MR. LUTTIER: He’s a lawyer.

1 lawyer. That’s Mr. Critton, and, and he is a

2 partner in the same law firm.

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3THE WITNESS: Of them?
4MR. 黑色：Yeah.
5MR. LUTTIER: Other than your --
6MR. CRITTON: Thanks for the welcome.
7MR. LUTTIER: Other than your claim --
8MR. 黑色：Hello, Robert.
MR. CRITTON: Hi,

BY MR. LUTTIER:

Q. — your claim that you admitted yourself,

that you Baker Acted yourself at___,

what other medical expense do you claim you incurred

as a result of anything that had to do with

Mr. Epstein?

A. I don’t know.

Q. Have you ever been treated by any physician as a result of anything that had to do with Mr. Epstein other than when you claim you Baker Acted yourself at

A. Your question is so confusing to me because I feel like you keep asking it in different forms, and I keep telling you the same answer and I’m — you’re confusing the crap out of me.

Q. Have you gone to any doctor —

  1. A. Other than ，no.

  2. Q. Okay — as result of anything having to do

  3. with Mr. Epstein?

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4

A. And I — no.

Q. Okay. You claim in your amended complain that you have lost some sort of wages as a result of your dealings with Mr. Epstein. Are you aware of that?

1 A. I don’t know what that means.

  1. Q. That you lost income because of your

3 relationship or dealings with Mr. Epstein.

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A. Yeah, I have problems socially with certain people.

Q. Well, let’s talk about specifically lost earnings. What earnings, that is wages, did you lose because of any dealings you had with

Mr. Epstein?

A. I have a very hard time working around older men or in specific situations.

A. Well, I don’t trust men.

17 Q. What — any kind of particular kind of men

8 or just any -employment in the past with men over 40 that you’ve

A. I don’t trust anybody and I don’t feel safe in some places.

Q. What situations would those be?

Q. Well, you say you don’t trust anybody?

A. Older men.

Q. And what’s your definition of “older”?

A. Above 40.

Q. Okay. Did you have some sort of

now lost or cannot, can no longer pursue because of

  1. A. Like if you work in restaurants. I’m, I’m

  2. confused.

3 Q. And what —

4 A. I am totally confused.

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Q. Why can’t you work in a restaurant as a result of having had interactions with Mr. Epstein?

A. I don’t like places where men stare at me. It makes me feel uncomfortable.

Q. But, in fact, after you saw Mr. Epstein, after you quit going to Mr. Epstein, you worked at numerous places where -over 40, have you not?

13 Q. — men saw you, correct?

A. I have.

14 A. Yes.

15 Q. And you have made as much as a thousand

16 dollars a night -over 40, have you not?

17 A. Yes.

18 Q. — going out with people, men that are

20 A. Yes, that’s true.

21 Q. When before you met Mr. Epstein did you

22 ever earn a thousand dollars a night?

23 A. No, it was after.

24 Q. Never did, correct?

25 A. It was after.

  1. Q. So, would you agree with me that after

2 that point in time that you stopped seeing

3 Mr. Epstein you actually earned more money than you

4 had ever earned before in your life?

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A. Yes.

Q. Would you agree with me, therefore, that your earning potential and your earning ability had increased and not decreased?

A. I suppose.

Q. And, by the way, when you were earning a thousand dollars a night, who were you working for?

A. I was working for an escort service.

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Q. When did you, other than the cocaine you shot up, when was the first time you used cocaine?

A. The first time that Jeffrey Epstein paid me enough money to afford it.

Q. When was that?

A. When I first started seeing him.

Q. On the first occasion that you ever saw

Mr. Epstein?

17 A. A couple occasions after I started seeing him.

18 Q. Does that mean the third time you saw

19 Mr. Epstein?

20 A. I’m not exactly sure of the exact time.

21 Q. And where did you obtain the cocaine that

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22 you took for the first time?

A. None of your business.

We’ll stipulate that it was

MR.

not from Mr. Epstein.

THE WITNESS: No, it was not from

Mr. Epstein.

3 BY MR. LUTTIER:

Q. And would you also agree that Mr. Epstein

didn’t tell you to go get it? Mr. Epstein didn’t

A. No.

tell you to go get cocaine, did he?

Q. Mr. Epstein never gave you any drugs, did he?

10 A. No.

  1. Q. Mr. Epstein never told you to take any drugs, did he?

13 A. No, but Mr. Epstein knew I was taking drugs.

  1. Q. And how did Mr. Epstein know you were

  2. taking drugs?

16 A. Because I told him.

17 Q. And what did you tell him?

18 A. I told him that I was under the influence of

19 cocaine.

20 Q. And when did you tell him that?

21 A. When I was at his house.

22 Q. And when was that?

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23 A. I don’t remember the exact date.

24 Q. Which occasion was it that you were at his

25 house that you told him you were under the influence 104

1 of cocaine?

2 A. I don’t remember.

3 Q. And was this on one occasion?

  1. A. What, that I had gone to his house under the influence?

  2. Q. That — no, that you told him that you were under the influence of cocaine.

A. No, there, there was more than one occasion where I have told him.

  1. Q. It was your choice to take cocaine before

11 you went to Mr. Epstein’s house?

12 A. Anything to mind alter myself not to be there.

13 Q. You did that voluntarily, that is you took

whatever drugs you took before you went to

15 Mr. Epstein’s?

16 A. Yeah.

17 Q. You bought them with money that you had;

18 is that right?

19 A. From Mr. Epstein, yes.

20 Q. Well, you didn’t keep track of the money

21 that you got, right?

22 A. Well, I wasn’t receiving income from any other

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23

person, so —

24 Q. And were you doing this cocaine with your

25 boyfriend?

105

  1. A. At the time, yes.

away from Mr. Epstein; that is you did it when you

A. Yes. But I have done cocaine at Mr. Epstein’s house also.

Q. When did you do cocaine at Mr. Epstein’s house?

A. On some occasions while I was there.

Q. What occasions were those?

A. I don’t recall the dates and times.

Q. What, where at his house were you doing cocaine?

A. I would excuse myself and go to the bathroom.

Q. And who was in the bathroom when you were doing this cocaine?

A. Myself.

Q. And, and what form of cocaine were you

22 A. Powder.

23 Q. And did you tell anyone you were taking

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24

cocaine?

A. Mr. Epstein knew I was high.

Q. Did you tell Mr. Epstein that you had gone in the bathroom in his house and snorted cocaine?

A. Not, per se, in that form.

Q. Did you tell him that you were using drugs in his house?

A. No.

  1. Q. He never told you to use drugs in his

  2. house, did he?

  3. A. No, he never told me to.

  4. Q. He never gave you alcohol in his house,

  5. did he?

A. No.

Q. Did you ever have sexual intercourse with Mr. Epstein?

A. No.

Q. Do you know what I mean by sexual intercourse, or do I need to go through the various acts?

A. Oh, I am pretty sure I know what sexual intercourse is being I have two children.

Q. Well, I just want to make sure we’re clear about some things. Did Mr. Epstein ever insert his penis into any part of your body at all?

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24

A. I just said that I’ve never had sexual

25 intercourse with Mr. Epstein and that I knew what sexual 107

intercourse was, and I said no. So, for you to explain to me what it was unnecessary.

Q. Okay. Do you just want to answer my question now, ma’am?

A. I did four times. I said no.

MR. LUTTIER: Would you read back the question I asked? I need an answer to my question.

MR. : We will stipulate that the answer to that question is no.

BY MR. LUTTIER:

Q. Okay. Did you ever perform any sexual act of any kind or nature whatsoever on Mr. Epstein ever?

A. Now, you could define, give me a definition of what that would be, because I’ve never — giving him a blow job, I’ve never had sex with him. I did squeeze his nipples or whatever while he was masturbating himself.

Q. Any other, did you ever perform any other sexual act on Mr. Epstein? And by, when I say other, I’m not acknowledging that squeezing someone’s nipples is a sexual act. But it seems that you’re defining it as such; is that right? Do

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25

108

you think that’s a sexual act?

BY MR. LUTTIER:

Q. We’ll do this, did you ever perform oral sex, that is put Mr. Epstein’s penis in your mouth?

A. Did I not just tell you —

Q. Ma’am, you said you needed me to explain —

MR. LUTTIER: Now, I am going to explain it to you. We’re going to make sure we’re clear, ma’am, because I know you want to be specific. Okay.

THE WITNESS: Could I ask if you could read back that I told him that I never gave him a blow job and never had sex with him.

THE WITNESS: I was specific with you.

THE COURT REPORTER: One at a time.

BY MR. LUTTIER:

Q. Did you ever masturbate Mr. Epstein?

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25

A. No.

109

1 Q. Did you ever touch Mr. Epstein’s penis -to do, ever?

2 A. No.

3 Q. — in any way?

4 A. No, no.

  1. Q. Did you ever penetrate with any part of your body any part of Mr. Epstein’s body?

  2. A. Besides touching his nipples, no.

  3. Q. Did you ever do anything physically to

9 Mr. Epstein other than give him a simple massage?

10 A. Squeezed his nipples.

11 Q. Was that part of the massage?

12 A. No.

Q. Okay. So other than squeeze his nipples and give him a massage, did you do anything else physically to Mr. Epstein?

A. No.

Q. Did Mr. Epstein ever make you do anything that you didn’t want to do ever?

A. Make me do anything I didn’t want to do.

20 Q. Force you to do something you didn’t want

22 A. Probably squeeze his nipple.

23 Q. And why do you say he made you do that and

you didn’t want to do it? Did you tell him — well,

25 first of all, did he ask you to squeeze his nipples?

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110

  1. A. Yes.

  2. Q. Did you tell him you didn’t want to do

  3. that?

4 A. Yes.

5 Q. And what did he say when you said that?

7 Q. And did you then do it?

6 A. It would help him go faster or whatever.

8 A. Yes, I did.

9 Q. Did you refuse to do it and say, no, I

10 don’t want to do that?

11 A. Yes, I did refuse; and yes, I still did it.

12 Q. Well, did you do it voluntarily then?

13 A. Obviously.

14 Q. All right. Were there ever any other

15 things ever that Mr. Epstein asked you to do that

16 you refused to do?

17 A. No.

18 Q. Is it a true statement then that

19 Mr. Epstein never forced you to do anything?

20 A. I guess no.

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10 Q. When did you first make an acquaintance or

12 A. When brought me over there.

14 A. A friend of mine who has disappeared.

16 A. I don’t remember.

17 Q. And when you say she brought you over

there, what is the “there” that you are referring

A. To Mr. Epstein’s.

21 Q. And where is that?

22 A. It was at Palm, it was on Palm Beach.

23 Q. Are we talking about a condominium, an

apartment, or —

A. 358 Albrillo Way.

  1. Q. And when was it that your friend,

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brought you to Mr. Epstein’s at 358

Albrillo Way?

A. What you do you mean when was it?

Q. What date?

A. I don’t know the date

Q. Do you have any record at all anywhere of the date that you first went?

A. No.

Q. In your complaint you allege that the first time you went was in May or June of . Are you aware of that?

A. Yes, I remember it was spring going into summer.

Q. Is there any other basis upon which you concluded that you first went to Mr. Epstein’s in May or June of other than your recollection that it was sometime in the spring?

A. No.

Q. Is there any other fact or circumstances upon which you relied when you alleged that you first went to Mr. Epstein’s in May or June of ?

A. One more time. I’m sorry.

Q. Any other fact or circumstance that you relied upon when you alleged that you first went to

1 Mr. Epstein’s in either May or June of

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2 A. I don’t -when the first time that you went to

3 Q. — than it was the spring?

A. I don’t understand.

Q. How did you know it was May or June of

Mr. Epstein?

A. Oh, because I remember the weather.

which you allege that you first went to

Mr. Epstein’s in May or June of

Q. That’s it. That’s the sole basis upon

A. Yeah.

Q. Did you ever keep any kind of record of your occasions that you went to Mr. Epstein’s?

A. No.

Q. Did you have any communication at all with Mr. Epstein himself before you went to his house for the first time when took you there?

A. No, I didn’t even know he existed.

Q. Did you ever personally see, that is

face-to-face, Mr. Epstein anyplace other than at 358

Albrillo, Palm Beach, Florida?

A. No.

24 Q. And I mean that from the time you first

25 went there when your friend talked 117

1 to you until the last time you went there.

2 A. I have only seen him at that house.

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Q. Right. Which means you haven’t run into

4 him out in town or any other place?

5 A. No.

  1. Q. The only time you ever did it is when you

  2. went to his house?

8 A. Yes.

9 Q. Have, have you ever traveled anyplace

11 A. No.

10 with — Mr. Epstein ever take you anyplace?

12 Q. Anyplace you know, in town, for example,

13 Palm Beach?

14 A. No.

15 Q. Ever take you to concerts?

16 A. He paid for me to go to a concert.

17 Q. Did you ever, did you ever travel outside

18 of Palm Beach County with him?

19 A. No.

20 Q. Never traveled anywhere with him at all,

21 right?

22 A. No.

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Q. Okay. Let me ask, let me ask you a different question. Did you have access to a computer before you went to see Mr. Epstein for the first time?

A. Yeah.

Q. All right. Did you ever communicate with Mr. Epstein via computer; that is, did you ever use the computer?

A. No.

  1. Q. Did you ever e-mail him any messages?

20 A. No.

21 Q. Did you ever receive any e-mails from him?

22 A. No.

23 Q. Did you ever fax anything to him?

24 A. No.

25 Q. Did you ever receive any faxes from him?

  1. A. No.

  2. MR. LUTTIER: I think they have to change

3 the tape.

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THE VIDEOGRAPHER: Off the record at 12:29.

(A brief recess was held.)

THE VIDEOGRAPHER: We’re back on the record at 12:40.

MR. LUTTIER: What exhibit are we on?

THE COURT REPORTER: Three.

MR. LUTTIER: Let me have that marked as 3.

THE WITNESS: Exhibit 3. Thanks.

BY MR. LUTTIER:

Q. Ma’am, what I’ve, what I’ve given you is a document that’s been marked as Exhibit 3. That is a copy of the First Amended Complaint which you filed in this case. And I am giving it to you so that it is available to you if you want to consult it at any time during the deposition.

I will probably ask you some specific

  1. questions about it, in which case I will refer you

2 to the appropriate portion. You don’t have to read

3 it now but I want to make sure you’re aware it’s

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available to you if you want to consult it. All

24 BY MR. LUTTIER:

25 Q. Did you — have you ever had a phone 121

  1. conversation directly with Mr. Epstein?

  2. A. About what?

  3. Q. About anything?

  4. A. Yeah.

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Q. Not, not somebody at Mr. Epstein’s house but Mr. Epstein himself?

A. Yes.

Q. Do you recall on how many occasions you have had phone conversations with him?

A. More than twice.

Q. Do you have any, are you able to estimate anything more accurate than just more than twice?

A. No.

Q. From, from your estimate that it was more than twice, would it be a correct statement that it was infrequent that you had a direct phone conversation with Mr. Epstein?

A. What is infrequent, like not all the time?

Q. Yeah.

A. Yeah.

21 Q. Would it be less than a dozen times?

22 A. Yeah.

23 Q. Okay. Do you recall as you sit here today

24 the substance of any of your conversations with

25 Mr. Epstein, the direct ones that you had?

122

  1. A. Oh, instead of somebody else calling me to ask

2 me to come over, he called himself.

4 now asking you concern themselves strictly with

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phone conversations where you were one part of the conversation; Mr. Epstein himself was the other party. Do you understand that?

A. Yeah.

Q. Okay. All right. Do you remember the substance of any direct phone conversation you ever had with Mr. Epstein?

A. I don’t understand.

Q. Do you remember the specifics about what he said or what you said?

A. About when he got me concert tickets, he called me and asked me if I wanted to go.

Q. Okay. And do you know approximately when that conversation happened?

A. I don’t remember.

Q. Do you recall any other direct phone conversation with Mr. Epstein other than when he called you about concert tickets?

A. He told me he would be sending me lingerie from New York.

Q. Do you recall any other phone conversation

  1. directly with Mr. Epstein?

  2. A. No.

  3. Q. So, other than these two phone

  4. conversations that you had with Mr. Epstein, was

  5. there any other occasion that you and he were on the

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6 phone together?

7 A. I don’t remember.

8 Q. That is you don’t remember any other?

9 A. Yeah.

10 Q. On, on the occasion that he called and

11 asked you about concert tickets, was Mr. Epstein at

12 his house in Palm Beach?

14 Q. Do you know where he was?

13 A. I’m not sure.

15 A. I don’t. He was either in New York or in Palm

16 Beach.

17 Q. Do you know where he was?

18 A. I just said no.

19 Q. Okay. On the conversation when he called

20 and said he would be sending you lingerie, do you

21 know where Mr. Epstein was?

22 A. Unh-unh. No.

Q. On each of those occasions, who placed the

call; that is, did he call you or did you call him?

A. He called me.

  1. Q. Were there ever occasions that you called

2 Mr. Epstein directly, whether or not you talked to

3 him, where you placed a call trying to get

4 Mr. Epstein?

5 A. Yes.

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Q. And how often did that happen?

A. More than four.

Q. And for what reason were you placing calls to try to get Mr. Epstein?

A. To go over there to see him.

Q. Were you seeking the opportunity to go over and massage him and get paid?

A. Yes.

Q. And on these occasions that you called to see if you could go over there and give him a massage, did you talk to him or did you talk to others at his house?

A. I talked to or Maxwell. I have also talked to — I don’t know if it’s the cook or somebody else that was there that took phone messages.

Q. Other than the four occasions when you placed calls to Mr. Epstein’s home looking to come over and perform massages for money, were there any other times that you attempted to contact Mr. Epstein ever?

A. No.

Q. Other than the two times that Mr. Epstein called you, once about concert tickets and once about lingerie, to the best of your knowledge were there, was there ever any other time that

Mr. Epstein attempted to contact you?

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A. Not that I know of. I mean, I don’t think it was him. No, I don’t remember it.

Q. Okay. What, do you recall what phone number you used when you tried to call Mr. Epstein?

A. Yes.

A. The Palm Beach phone, phone numbers.

Q. It would be the number at his house?

for example, for a cellphone?

A. House numbers.

Q. To be distinguished from a phone number

Q. Okay. According to your first amended complaint, Paragraph 195, the last time you saw

Mr. Epstein was August of

A. What page are you on?

Q. It would be Page 84. Is that correct?

22 A. Yeah.

23 Q. All right. So, for purposes of this case,

24 the total period of time that you had any

25 interaction with Mr. Epstein was between May of 126

1 and August of

2 A. Uh-huh.

3 Q. That is another way of saying it is the

4 first time you went is May of and the last time

you went was August of

A. Yeah.

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Q. Didn’t know Mr. Epstein at all prior to

May of , and had no contact with him after August of ?

A. Correct.

Q. On any occasion that you have described where you had a phone conversation with Mr. Epstein, was anyone else on the line to the best of your knowledge?

Q. For example, you didn’t have someone on the extension of the phone where you were?

A. No.

Q. And to the best of your knowledge nobody was on his end of the phone call?

A. No.

Q. You never had a discussion with him on a speaker phone, for example?

A. No, not to my awareness.

Q. Did you ever record —

  1. A. No.

  2. Q. — any of your —

  3. A. No.

  4. Q. Let me — did you

  5. Q. Let me — did you ever record any of your

  6. Q. Let me — did you ever record any of your communications with Mr. Epstein?

  7. A. No.

  8. Q. And by that I would mean it could be a

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tape recording, could be you making notes. You never did anything like that?

A. No.

Q. All right. Have you told me in this deposition now everything that you can remember about your direct phone conversations with Mr. Epstein?

A. Yes.

Q. When you said that Mr. Epstein called you about concert tickets, was he, was he asking you to go with him to the concert or just asking if you wanted tickets to the concert?

A. If I wanted the tickets to the concert.

B. And did you take the tickets?

C. Yes.

Q. All right. Would you, would you say that during the period from May of to August of Mr. Epstein was good to you?

  1. A. Yes.

  2. Q. He was polite?

  3. A. Yes.

  4. Q. Never forced you to do anything you didn’t

  5. want to do?

  6. A. Yes.

  7. Q. Did he help you with your self-esteem?

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Q. Did he attempt to build you up and make you feel good about yourself?

A. Yeah.

Q. Did he ever attempt to make you not feel good about yourself?

A. He didn’t try to make me not feel good about myself.

Q. He never demeaned you in any way when you were with him?

1 BY MR. LUTTIER:

  1. Q. Did he ever, did he ever strike you ever,

  2. hit you?

  3. A. No.

  4. Q. You know what the phrase domestic violence

  5. means?

  6. A. Yes.

  7. Q. Did he ever commit an act of domestic

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9

violence against you?

A. No.

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Q. It’s just, you know, a question that we have to ask. Did, did Mr. Epstein ever threaten you in any manner?

A. No.

MR. CRITTON: I’m sorry. I didn’t hear

that.

THE WITNESS: I said no.

  1. BY MR. LUTTIER:

Q. Did he ever give you any kind of a

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10 substance to ingest or otherwise do anything that

11 caused you, for example, to lose consciousness?

12 A. Not to my awareness, no.

13 Q. He never attempted to drug you in any

14 manner, did he?

15 A. Not to my awareness, no.

16 Q. Never even offered you any drugs, correct?

17 A. Correct.

18 Q. What — when you would go to

19 Mr. Epstein’s, would you and he converse?

20 A. Conversate?

21 Q. Would you talk with him while you were

22 giving him massages?

23 A. Yeah.

24 Q. What types of things did you talk to

25 Mr. Epstein about?

132

  1. A. He wanted to put me in massage school.

2 Q. Was that something you were interested in?

3 A. I was.

4 Q. And did you indicate to Mr. Epstein you

5 had an interest in going to massage school?

6 A. Yes.

7 Q. And what did Mr. Epstein tell you about

8 that?

9 A. He sent me a book, Massage for Dummies. And

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he was going to put me in school for it if I really wanted to do it.

Q. And did you indicate to him whether you really wanted to do it?

A. Yes, I really wanted to do it, but I never, he — I never went to school for it.

Q. Did you ever ask him if, if he would pay for you to be enrolled in school?

A. He told me he would.

Q. All right. So he said he would be willing to, but you had made the decision you didn’t want to go forward with it?

A. I wasn’t old enough to.

Q. Okay. Anything else that Mr. Epstein offered to do for you?

25 133 A. He wanted to send me on vacation somewhere but

1 I was too young to go. My mom wouldn’t have let me go

2 out of the country.

3Q. Did you ever represent to Mr. Epstein at any time what your age was?
4A. Yes.
6Q. When did you first represent to

7 Mr. Epstein what your age was?

I was going to be 14. And his response was, don’t let

anybody know how old you are.

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A. I guess, yeah.

Q. Okay. All right. So, that would make you 15 when you went to Mr. Epstein’s the first time, wouldn’t it?

A. I thought it was 14.

Q. But you agree with the math?

A. I don’t know. I didn’t watch you do your math.

Q. Okay. All right. You allege in your complaint two incidents in each month from late, late May or early June of through August of that you went to Mr. Epstein. In fact, you, you don’t have a specific record of when you actually went to Mr. Epstein; is that right?

A. That’s right.

Q. You — and this is, this complaint only contains what you, your estimate is of when you actually went, correct?

A. Right.

Q. Might have gone fewer times; might have gone more times?

7 A. I know I went over 100 times.

  1. Q. How do you know you went over 100 times?

  2. Did you count?

10 A. Because I was there.

11 Q. Do you have some place that you recorded

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12 it?

13 A. No.

14 Q. You added it up and got to 100?

15 A. No.

Q. So, that’s just an estimate on your

A. Yes.

Q. You allege in your complaint that you went

A. I don’t know.

and August of . Do you know whether or not

Q. Do you know whether or not Mr. Epstein was

1 gone from Palm Beach County —

Q. — for substantial periods of time during

A. I know that he’d go back and forth to different places, but when he was in Palm Beach, I would get a phone call.

Q. Do you know whether or not it was any

continuous period of time when he was not in Palm

Beach County between June o

A. I don’t know. I would get a phone call when

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he was in Palm Beach.

Q. Would you — but you would agree that if he wasn’t in Palm Beach, you didn’t see him?

A. Correct.

Q. And you would agree that it’s, that it’s, that it’s possible that Mr. Epstein was gone during periods of time that you claim you went to see him?

A. I can’t claim anything if I don’t know.

Q. You would agree with me that you cannot recall the specifics of each visit that you had at Mr. Epstein’s home?

A. I don’t remember the times and dates, but I can tell you everything that happened while I was there.

Q. In your complaint in each count you allege

that you went to Mr. Epstein’s at his request?

A. Uh-huh.

Q. In fact Mr. Epstein himself did not contact you on each occasion and request you to come, did he?

A. No. He would have or Maxwell call n

Q. Well, there were also occasions when no one from Mr. Epstein called, but rather you called Mr. Epstein’s and asked to go?

A. Yes.

  1. Q. And that was because you wanted to go and earn some money, correct?

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A. Yes.

Q. On each occasion that you went to Mr. Epstein’s, you went there voluntarily, correct?

A. Yes.

Q. On each occasion that you went to Mr. Epstein’s whatever acts you performed, you performed them voluntarily, correct?

It is our contention that was legally incapable of consenting to the sexual misconduct in which Mr. Epstein engaged as a consequence of her minority. So, maybe that helps to narrow your questioning down some.

MR. LUTTIER: All right. So, you will stipulate that neither Mr. Epstein nor anyone else forced against her will to perform any act; it’s simply your position that given her age, she could not have consented to those acts?

MR. : That’s correct.

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MR. LUTTIER: Okay.

MR. : She was, she was bribed to engage in that conduct; that is, she was paid very large sums of money and she engaged in those acts without having the legal capacity to consent as a consequence of the large sums of money that were offered to her as well as other gifts.

MR. CRITTON: Ain’t going to work. He, in essence, he gave a speech.

MR. LUTTIER: Yeah, that, I move to strike that part. We were talking about a stipulation.

MR. : You can move to strike anything you want to, but it’s on the record.

MR. LUTTIER: Well, I move to strike it so if it gets played to the jury, it doesn’t get played.

BY MR. LUTTIER:

Q. In each count of your complaint you allege that on the occasions that you went to Mr. Epstein’s you were paid in excess of $200. Do you know how much you were paid on each occasion?

A. Between 200 and $300.

Q. How do you know which times you got paid 200, and which times you got paid more than 200, if

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you know?

A. I remember.

Q. Well, how many times were you paid 200?

A. I was paid $200 two times and $300 the rest.

Q. Is there a reason why in your complaint you then alleged that after the two, first two visits you were simply paid in excess of $200 as opposed to alleging you were paid 300?

A. What?

Q. In your complaint you just say you were paid in excess of 200?

A. Where are you in this complaint, man?

Q. You can pick any page you want. I happen to be looking at Page 84 but —

MR. : Well, the form of the question is improper. This an unverified complaint. If you have a question about the underlying facts, then you should ask the question about the underlying facts. But a reference to the complaint is not relevant or material or reasonably calculated to lead to the discovery of admissible evidence.

We would be happy to answer questions about the underlying facts.

BY MR. LUTTIER:

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14 Q. You, you — were you ever paid less than

15 $200.

16 A. No.

  1. Q. Have you ever told anyone you were paid less than $200?

Q. What did you do with the money that you were paid?

22 A. I bought things until I bought drugs.

Q. What kinds of things did you buy with the money?

25 A. Clothes, things for my mom, things for school.

141

  1. Q. Did you enjoy the things that you bought

  2. with the money?

A. Yeah.

  1. Q. Did you want to — after the first time

  2. you went to Mr. Epstein’s, did you want to go back

  3. and continue to perform massages and earn money?

  4. A. Yeah.

  5. Q. What did you say, yes?

  6. A. Yes.

10 Q. Did you enjoy the occasions when you went

11 to Mr. Epstein’s?

12 A. Yes. Like enjoyed collecting the money, yes.

13 Q. Well, you enjoyed what you were doing,

14 didn’t you? You enjoyed spending time with him?

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A. Not exactly spending time with him. I enjoyed going to be able to collect that much money.

Q. Is it a fact that Mr. Epstein treated you better than many of your own acquaintances treated you?

A. No.

  1. Q. Did he treat you better than your own

  2. boyfriends treated you?

\3. A. No.

24 Q. You had boyfriends that, that beat you up,

25 didn’t you?

142

  1. A. Yeah, but that doesn’t mean that he treated me

  2. better than my boyfriends treated me.

  3. Q. Mr. Epstein ever beat you up?

  4. A. No.

  5. Q. You had a boyfriend that held a gun to your head, didn’t you?

  6. A. Yes.

  7. Q. Mr. Epstein never did that?

  8. A. No.

Q. Would you agree with me that Mr. Epstein’s conduct towards you was better than your boyfriend’s conduct towards you when he beat you up and held a gun to you?

A. I suppose, but Mr. Epstein never — I don’t

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Q. Did you — have you alleged in your complaint everything that occurred when you went to Mr. Epstein’s?

see how that would —

MR. : I’m going to object to the form of that question. It is vague, overly broad, ambiguous, and improper in its reference to the contents of the complaint. We’ll be happy to answer any questions you may have regarding the underlying facts.

MR. LUTTIER: Well, my question stands.

BY MR. LUTTIER:

BY MR. LUTTIER:

Q. In your complaint — all right. Let me, let me ask you about the first time that you went to Mr. Epstein’s.

A. Uh-huh.

Q. Were you fully clothed during the entire

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16 period of time that you were there?

17 A. No.

18 Q. For, for what period of time were you

19 fully clothed?

20 A. For the first half hour.

22 A. He asked me to take off my shirt.

21 Q. Then what happened?

24 A. Okay.

23 Q. And what did you tell him?

25 Q. Did you tell him you didn’t want to?

  1. A. Yeah.

  2. Q. Did you say you still didn’t want to?

3 A. I would get extra money if I did.

2 Q. And what did he say?

5 A. Yeah, but I also wanted the extra money.

7 it?

6 Q. So he didn’t, he didn’t force you to do

8 A. No, he bribed me to do it.

9 Q. Okay. And how much were you originally

10 going to get paid on the first occasion?

11 A. $200.

12 Q. And what did he say to you about any

13 additional money?

14 A. That if I took off my shirt, he would give me

15 extra money. So therefore he bribed me into taking off

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my clothes for money.

Q. So, how much did you get paid on the first visit?

A. $300.

Q. So, your testimony earlier that the first two visits you only got two paid 200 is incorrect?

MR. : That wasn’t her testimony.

I think you misunderstood her testimony.

MR. LUTTIER: Was it a form objection? It was what her testimony was, but I am not going

to argue with you.

MR. : I disagree. That’s not the way I recall it, but the record is what the record is.

BY MR. LUTTIER:

Q. When you took your shirt off, did you have a bra on underneath?

MR. LUTTIER: Yeah.

A. Yes.

Q. Was it any different than going to the beach in a bathing suit?

A. I wasn’t at a beach. I was at somebody’s house.

Q. Was your bra any different than or did it cover less than your bathing suit top?

A. No. It covered more than my bathing suit top.

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17 Q. Yeah. All right. So on the first occasion, other than taking off your shirt off when you had a bra underneath, were you otherwise dressed?

A. Yeah. I only had, I only had my jeans and a bra on.

23 Q. Okay.

24 A. Or my shorts. I was wearing shorts. I’m

25 sorry.

  1. Q. On the — and that was throughout the rest of the time you were there on the first occasion?

  2. A. Uh-huh.

  3. Q. On the second—

  4. A. Yes.

6 Q. On the second occasion, were you fully dressed?

A. No.

Q. How were you dressed during the second occasion?

  1. A. I was clothed up until I was wearing a bra and underwear.

13 Q. That is you started out to give this

14 massage clothed?

15 A. Yes.

16 Q. And then you removed clothing?

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A. Yes. He asked me if I would take off my clothes, and I told him I didn’t feel comfortable getting naked like he wanted me to. So, I only, I stayed in my bra and underwear.

24 Q. And you said you didn’t want to?

Q. So, did he specifically ask you to get naked?

| 25 | A. Yeah. |

| :--- | :--- |

| 147 | |

23 A. Yeah.

  1. A. Well, after he asked me for five minutes, and

  2. I told him no, yeah.

  3. Q. And he honored that wish?

Q. Did you tell him that you would be willing to take your shirt and pants off and be in your underwear and your bra?

A. Yeah.

Q. And then you remained in that state of dress on the second occasion?

A. Yes.

  1. Q. On the third occasion were you fully

  2. dressed?

13 A. No.

14 Q. How were you dressed the third occasion?

15 A. Well, I was fully dressed when I got there,

17 Q. Okay. Did you — were you fully dressed

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18 throughout the massage?

19 A. I took off my bra that time.

20 Q. Did he ask you to take off your bra?

21 A. Yeah.

22 Q. And what did you say?

23 A. I, I, at first I didn’t want to, and then I

24 did.

25 148 Q. Well, when you said you didn’t want to,

  1. did he make you take it off?

2 A. Well, he asked me. He kept asking me to.

3 Q. And you said no, right?

4 A. Yeah.

5 Q. And he honored that, your statement,

6 correct?

7 A. Yeah, but he kept asking me, so I did.

  1. Q. He didn’t offer you any more money, did

  2. he?

10 A. No, but I wasn’t going to get the money if I

11 didn’t do it so did I it.

12 Q. Who, who — why do you say you weren’t

13 going to get the money?

15 Q. What exactly did he tell you?

14 A. Because he told me I wasn’t.

17 Q. This is on the third visit?

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18 A. So I said fine.

19 Q. Was anyone else present for this

20 conversation?

21 A. No.

22 Q. Okay. So you got $300 on that occasion?

24 Q. And you were topless?

25 A. (Witness nods head.)

23 A. Yeah.

  1. Q. On the fourth time that you went, were you

  2. fully dressed?

A. I don’t remember from, like — I don’t

remember the specific fourth, fifth, sixth, seventh,

eighth times I was there. So, if you’re going to

continue on the fifth and the sixth and the seventh, I’m

not — I don’t remember so -most you got was 300 and you got that by the third

Q. Well -most you got was 300 and you got that by the third

A. I am trying to help you out here.

Q. Is it true that when you went, you

11 voluntarily removed your clothes?

12 A. He bribed me with money.

13 Q. Wait a minute. You, you told me that the

visit, correct?

16 A. Yeah. So —

17 Q. So —

18 A. I guess, yes, it would be voluntarily I took

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19 my clothes off.

20 Q. Were you — did there come a time that

21 when you went to give a massage, would you just go

22 over there and take all your clothes off before you

23 started the massage?

24 A. He asked me to take my clothes off.

25 Q. At the beginning of the massage?

  1. A. Yeah.

2 Q. All right. And you said okay?

3 A. Yeah.

4 Q. Was there ever a time that you said, I

5 don’t want to, and he said, no, you have to?

6 A. Yeah, there were times where he said that.

7 Q. Okay. And did you not take them off?

8 A. No, I took them off.

9 Q. Well, when did he say you had to take your

10 clothes off?

11 A. When he told me I have to take my clothes off.

12 Q. And, and but did you just remove your

13 clothes, or did you say I don’t want to?

14 A. I said I don’t want to.

15 Q. Did you leave?

16 A. And he said, well, can you remove your

17 clothes?

18 Q. And what you did say then?

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  1. A. I said I would prefer not to, but I did it

  2. anyways.

  3. Q. Okay. He didn’t force you to do it

  4. though?

  5. A. If he — he didn’t physically take them off of

  6. me, no.

  7. Q. You could have left. Nothing prevented

151

  1. you from leaving?

  2. A. Right.

  3. Q. You said that some friend of yours named whose last name you can’t remember,

  4. took you there for the first time?

  5. A. Yeah.

  6. Q. How did you know this person,

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school him.

A. Yes.

Q. When did she — how was it that she came

  1. about taking you over to Epstein?

  2. A. She asked me.

Q. And when did she ask you in relationship to when you went?

A. What do you mean?

Q. Well, was it the day before you went that she asked you?

A. No, it was the same day.

Q. So, was that the first time she asked you?

A. Yeah.

Q. So, the day that you went, sometime earlier that day, she asked you if you wanted to do what?

A. She didn’t explain to me what was going to happen. All she said was a friend of mine, we can go over there. You give him a massage and he will pay.

Q. Did you know how old he was?

18 A. No.

19 Q. And did she tell you, did she tell you

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20 anything about roughly how old he was?

21 A. She said he was older.

22 Q. Okay. And what did you understand that to

23 mean?

24 A. He was older than me.

25 Q. And when you got there,you saw him,

2 A. Yeah.

  1. correct?

Q. Could have left at that point, right?

A. Oh, well, not exactly, because being that I that was her car and I didn’t know where the hell I was.

Q. Did you tell when you saw

A. No, because I didn’t know I was going to have to remove any clothes.

Mr. Epstein, stop, I don’t want to do this.

Q. All right. Did she tell you anything other than you were going to go over and give a massage to an older man?

A. No.

Q. Certainly after the first time you knew what was involved, right?

A. Not exactly. I didn’t know I was going to have to get naked in the future.

left there, you knew what that incident involved

because you just experienced it, right?

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A. Well, he only — he never forced me to take off my clothes other than — yes, I took off my shirt and I stayed in my bra and my jeans.

Q. Right. My point is that after the first time, if you didn’t want to, you could have simply

said I am not going back under any circumstances, right?

took you over, after you left did — what did you tell her, if anything, about having been there?

Q. Did give you any kind of drug before you went there?

Q. Did you give any of the money that you received when you went there the first time?

there the first time, do you know?

/ A. I have no idea.

18 Q. Did there, did you go with

19 on more than one occasion?

20 A. No.

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Q. The second time you went did anybody take you there?

A. No.

  1. you there on more than one occasion?

  2. A. No.

  3. Q. Had, did anyone else ever take you to Mr. Epstein’s, any other girl other than

A. No.

Q. And why is it that, under, under what set of circumstances did you go back to Mr. Epstein’s without going with ?

A. Because Mr. Epstein asked me for my phone number and I gave it to him and he called me for me to go over there.

getting paid money take you there?

A. No.

Q. Did there come a time that you asked others to go to Mr. Epstein’s?

A. Yes.

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22 Q. And for how long had you been going to

Mr. Epstein’s before you asked someone else to go?

A. Couple of months, more — well, I can’t — a

25 couple, more than two.

156

Q. And at the point in time that you asked someone to go, had you, had you performed massages for Mr. Epstein totally nude?

Q. What else had occurred during your massages with Mr. Epstein at the point in time that you asked others to go? Do you understand my question?

A. Yes.

A. No.

Q. All right. You, you had been giving him massages in the nude, right?

A. Uh-huh.

Q. Anything else?

A. Has anything else happened while I was there?

Q. Up to that point in time involving you?

16 A. He had some girl eat me out and he had sex

17 with her.

Q. And that was before you asked someone else to go?

A. Yeah.

21 Q. And do you recall when that was?

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A. I don’t remember the dates and times.

Q. Have you ever told anyone prior to today that that event occurred?

A. Besides my attorneys, no. Oh, and those

people I talked to, the FBI and the state people.

Q. Do you remember me asking as there is nothing in your complaint about this. So, do you know why that would be?

MR. LUTTIER: If you want to tell her not to answer, that’s fine. We don’t need to go through it.

Q. Did you read the complaint before it was filed?

A. Yeah, I read the complaint.

Q. Did you — when you read the complaint did you notice there was anything missing from it?

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A. No, I trust my attorneys. That’s why they’re my attorneys.

Q. Did you tell anyone, your lawyers or

anybody else that there was, there were other facts and circumstances that weren’t included —

MR.

That is obviously a privileged communication.

Don’t answer that question.

BY MR. LUTTIER:

Q. All right. When did this event happen where you say there was another girl involved?

A. I just told you I didn’t know the dates and times.

Q. Well, you said that, correct me if I am wrong — well, let me rephrase the question.

Approximately how many months had you been going before you asked someone else, or took somebody else there?

Q. More than two. Anything more specific?

Could it have been a year?

A. I don’t know. More than two months.

A. Three, four, five, maybe even six months.

Q. All right. So, sometime within the first six months this event happened involving this other girl?

A. Yeah.

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Q. All right. Tell me the facts and

circumstances that occurred on that occasion

25 starting with when you went to Mr. Epstein.

159

A. I got there and some other girl came in and said she was going to help me. And — or he came in and introduced me to her. He took a shower. She said she was going to help me do the massage. And the next thing I know, that’s what was happening.

Q. Well, who was this person?

A. I don’t remember her name. She was really pretty, though.

9 Q. Had you ever seen her before?

10 A. No. And I have never seen her again.

11 Q. Did she identify herself to you?

12 A. I don’t remember her name.

13 Q. At the time did she introduce herself to

14 you?

15 A. Yes.

16 Q. Did she say who she was?

17 A. Yes.

18 Q. What did she say?

19 A. I don’t remember her name.

20 Q. Okay. Other than her name did she say —

21 A. She said hi, I’m — and I am going to help you

22 today.

23 Q. She didn’t say, for example, I am the lawn

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24 man here or something like that? She didn’t

25identify what her status or position was, if any?
160
  1. A. I just told you no.

2 Q. Okay.

3 A. I just told you what she said to me.

4 Q. Okay. So, this, this, a girl is in the

5room. Mr. Epstein takes a shower. What occurs
6next?

7 A. I was standing there ready for him to like lay

8 on the massage table. And she got down on her knees and

9 started eating me out.

11 A. No, I was naked.

12 Q. Had you removed your clothes voluntarily

10 Q. Were you dressed at the time?

13 at that point?

14 A. Yes.

15 Q. Was this other woman dressed?

16 A. No, she was naked too.

Q. When did she get naked in relationship to

when you came in the room?

A. She came into the room and Mr. Epstein asked

us to get naked and he got into the shower. So we were

already naked by the time he got out of the shower.

23 this other girl was naked in the room cause you, did

Q. Okay. So, that, did that, the fact that

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24 you say anything like I want to leave or —

25 A. No.

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  1. Q. Did you ask her any questions?

2 A. No.

3 Q. Seem unusual to you?

4 A. No.

  1. Q. Okay. Wasn’t the first time you saw

  2. another woman naked, right?

  3. A. No.

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25

Q. So, a one-year period?

163

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